By Michael Brooks

MISO told FERC last week that a group of wind generators alleging special treatment for external generators misunderstands the purpose of the M2 milestone payment in the RTO’s interconnection process (EL15-99).

The generators — EDF Renewable Energy, E.ON Climate & Renewables N.A. and Invenergy — complained to FERC earlier this month that revisions to MISO’s rules would exempt generation outside the RTO’s footprint from providing a cash-at-risk deposit in order to enter the definitive planning phase of the study queue. They argued this was unfair to internal generators, which are required to make the deposit, known as the M2 milestone. (See MISO Beats Challenge on Wind Exports.)

MISO said the complainants are asking that existing external generators seeking network resource interconnection service (NRIS) pay the M2 milestone, which is only required for new generation, regardless of its location. The RTO said the milestone isn’t charged to existing internal generation that only seeks NRIS.

The payment, approved by the commission in 2012, is to discourage speculative projects from entering the queue; withdrawals from the queue result in time-consuming and costly restudies.

“The M2 milestone is a ‘readiness’ milestone, designed to demonstrate that projects are ready to proceed to commercial operation,” MISO said. “External NRIS projects need not demonstrate ‘readiness’ because they must be ‘existing’ generators by definition under the MISO Tariff.”

MISO also disputed the complaint’s claim that not having to paying the M2 milestone gave external generators an unfair competitive advantage. Because it treats existing generation the same regardless of location, MISO said, “under complainants’ theory, internal NRIS-only projects within MISO also would have an unfair advantage, and by extension, also should pay the M2 milestone. Such a position is a collateral attack on the commission-approved Tariff that provides for different payments for NRIS-only projects as just and reasonable.”

‘Unripe Complaint’

MISO also criticized the generators’ decision to file an ‘unripe complaint,’ saying that the language of the revisions was not final. The RTO said such filings circumvent the stakeholder process and that FERC should continue to discourage them.

The generators said that their decision to file was based in part on an e-mail from MISO to Wind on the Wires that said the Business Practice Manual revisions concerning M2 milestone payments was final.

The Planning Advisory Committee in August tabled WoW’s proposal that all external generators seeking NRIS pay a portion of the M2 milestone.

The issue was to be taken up again at the PAC’s Sept. 16 meeting but was struck from the agenda at the request of WoW’s Sean Brady.

Brady said he asked to remove the item from the agenda because of MISO’s email. “Making the BPM language effective immediately indicated that this matter was resolved and a vote on the M2 milestone payment was moot,” he said.