By Amanda Durish Cook
CARMEL, Ind. — MISO has settled on a transition plan for its new interconnection queue rules and intends to file Tariff changes with FERC by the end of the year, despite wind advocates’ complaints that the process has been rushed.
MISO said it plans to stagger implementation, “processing some projects under the existing rules and transitioning certain projects to a portion of the new process.”
Between Feb. 20 and May 20, MISO plans to finalize existing generation interconnection agreements and facilities studies, with GIAs completed for the latter by late August. These GIAs will be at the top of the queue for all study cycles to follow.
The RTO will also finish all incomplete system impact studies by Aug. 27 and give the owners of those projects an option by early September to either move into phase three of definitive planning under the existing rules, paying an M4 milestone, or enter phase one of definitive planning under the revamped queue without having to pay another M2 milestone fee.
Projects that haven’t yet entered into a system impact study by Feb. 20 will be rolled into the reformed queue.
Vikram Godbole, senior manager of MISO’s generator interconnection planning group, said interconnection customers with pending GIAs as of Feb. 20 will be targeted first to complete negotiations.
“It’s a tall order, I realize that,” Godbole said of the dates outlined in the transition plan.
Throughout the process, staff representing Minnesota-based Wind on the Wires have complained that the adoption of the new queue timeline and rules has been rushed. The wind advocacy group says that costs remain too high under the new rules and wants MISO to eliminate the M4 milestone payment and create a cost cap on network upgrades. It has asked that MISO delay implementation of the rules until it reaches an agreement with the group.
Godbole said that the new queue will be implemented despite any future required Tariff changes to the interconnection process that may arise due to resource adequacy Tariff revisions. He said those will be handled in the future “as necessary.”
He added, “Any aspects from a technical perspective will be done at the [Business Practices Manuals] level. We’ll take those on next year.”
MISO will use the M2, M3 and M4 milestone payments surrendered by owners of non-viable projects to compensate other interconnection projects that were negatively impacted by the withdrawals.
Godbole said the new queue rules are intended to reduce the number of customers who keep non-viable projects in the queue until the “tail-end.”
“We’re doing this for interconnection customers,” Godbole said. “We want to make sure that people who come into the process ready are rewarded.”
In early December, stakeholders said interconnection customers should be able to use their M2, M3 and M4 payments to fund their initial milestone payment in the 30 days following completion of a generator interconnection agreement. Although MISO denied the request, the grid operator offered a willingness to discuss the option with stakeholders and, depending on the outcome, file Tariff revisions sometime in 2016.
During the last round of comments on Dec. 7, stakeholders requested the addition of a third penalty-free withdrawal option if estimated costs increase more than 25% between MISO’s system impact study and facilities study. Godbole said that MISO evaluated the merits of a third off-ramp “intensely” but ultimately determined not to provide it because the proposed queue reform is more economical for interconnection customers than the queue currently in place.
Stakeholders also criticized the M3 and M4 milestone floors of $2,000/MW, arguing that the cost never actually dips to $2,000, so the threshold is “illusory.” MISO declined to raise the floor, saying that the limit was FERC-approved and costs could come down in the future. (See MISO Cuts Queue Admission, Adds ‘Off-Ramps’.)
