Groups of generation owners and developers have asked MISO to adopt a queue fast lane only as a last resort and employ a more limited process that involves scoring criteria to gain entry.

MISO intends to open an express lane in its interconnection queue beginning in June through the end of 2028 for state-designated generation projects that meet resource adequacy targets. The bypass would be meant for projects that can reach commercial operation in three to five years. (See MISO Tells Board RA Fast Lane in Interconnection Queue is a Must and MISO Outlines Plan on Fast-track Queue for Resource Adequacy.)

However, the Coalition of Midwest Power Producers (COMPP) said MISO should establish a screening process for the fast lane based on project readiness and limit the process to just two accelerated studies — one in 2025 and one in 2026. The two studies should be open to all interconnection customers, independent power producers and load-serving entities alike, COMPP said.

Speaking at a Jan. 22 Planning Advisory Committee meeting, COMPP representative Travis Stewart said MISO’s expedited process as proposed creates the possibility of discriminatory treatment in the interconnection queue. This is especially a concern, he said, because designated resource adequacy projects might get first dibs on some of the billions of dollars in freshly constructed transmission capacity MISO has approved in recent years.

Stewart suggested MISO introduce a scoring system to permit projects in the express lane to make sure it’s accepting “commercially mature” projects that meet resource adequacy needs. He said project proposals could earn points based on developers’ ability to show that projects will serve resource adequacy needs, the completeness of an engineering design and equipment procurement, and that projects have been selected through either regulators or load-serving entities’ competitive solicitation. He said the burden to show project need and readiness would be on developers, with MISO to simply “trust and then verify” information from developers and regulators.

Stewart said COMPP’s idea, which he dubbed the Alternative Resource Connection Queue, could accept 50 of the highest-scoring projects apiece in 2025 and 2026 to proceed with faster studies aimed at interconnection agreements within 90 days.

“COMPP is concerned that an unchecked, uncapped [express] queue that can continue in perpetuity will likely mimic the ‘lane expansion’ phenomena in which creating new highway lanes does not improve the flow of traffic but only creates more lanes with more traffic,” Stewart said.

Some stakeholders said that asking MISO to institute more evaluation and scoring criteria will inherently slow down and convolute a queue lane designed to be faster.

“We’d rather have some small hurdles set up at the beginning to demonstrate commercial maturity … than have MISO dedicate their engineering expertise to study a project that ultimately doesn’t get built,” Stewart said, adding that “two weeks of evaluation upfront is better than four months” of ultimately wasted analysis.

NextEra Energy’s Erin Murphy, representing a group of MISO generation developers, said MISO’s proposal raises fundamental discrimination and undue preference concerns. She agreed with Stewart that a fast lane should be open to independent power producers and load-serving entities alike.

“We are concerned that the most constructable projects and the ones most able to address RA concerns won’t get online under this process,” Murphy said.

Murphy said while a limited fast track might ultimately prove necessary, MISO should focus first on improving operations of the existing queue to reduce the backlog. She said MISO should increase staffing and allow time for its recently approved queue regulations with FERC to take hold before it establishes specialized processing.

“We’re of the firm belief that the volume currently in the queue is more than enough to meet projected resource adequacy needs,” Murphy said. She argued that MISO first should take stock of projects already in the queue to ascertain which can meet the footprint’s resource adequacy needs. She implied MISO is establishing a fast lane while disregarding viable projects in the regular queue that already have been vetted.

“There’s a heck of a lot of value in the queue that’s locked up,” Murphy argued.

Murphy said if an imminent resource adequacy gap persists after that, any express lane should come equipped with a scoring system “so the best projects come online in a timely manner.” She also said a fast lane option shouldn’t “erode” the value of the existing queue.

But WEC Energy Group’s Chris Plante said identifying resource adequacy needs is a subjective exercise today.

“It’s not as simple as meeting a reserve margin. It used to be that simple,” Plante said. He said today’s variable requirements in seasons, the sloped demand curve now in place in MISO capacity auctions and more volatile accreditation values year-over-year complicate the picture.

“There’s a tremendous amount of uncertainty in determining resource adequacy needs,” Plante said.

Murphy agreed and suggested resource adequacy needs could begin with states articulating them and then MISO validating them.

MISO’s Andy Witmeier said MISO is delaying its FERC filing into mid-March to consider stakeholders’ suggestions. He said MISO would return to the February Planning Advisory Committee to present a final proposal.

However, Witmeier said the point of the fast track is to get projects online quickly as load grows. He said MISO’s new queue regulations approved in January 2024 — which include higher fees, automatic withdrawal penalty costs and stricter evidence of land use — will take a few years to bear results.

“We’re facing a new phenomenon with spot loads,” Witmeier explained.

Witmeier confirmed that projects that elect to drop out of the regular queue to join the fast-tracked queue will face automatic withdrawal penalties.

MISO also plans to collect higher fees from fast-lane developers than in the regular queue. It will start with a $100,000 nonrefundable upfront fee and then a milestone payment of $24,000/MW. Customers in the regular queue pay $8,000/MW.

Clean Grid Alliance’s David Sapper argued that MISO’s proposal still appears to “violate” FERC’s mandate on open access and nondiscriminatory treatment.

Minnesota Public Utilities Commissioner Joe Sullivan said he heard stakeholders offer fair recommendations to MISO.

“I think we have to find a way to treat the existing queue reasonably and fairly,” Sullivan said.

Sustainable FERC Project’s Natalie McIntire said it seemed MISO wasn’t requiring enough proof that projects are ready to embark on construction. She said MISO might consider requiring engineering designs, fuel contracts if applicable and their permitting progress. McIntire said there’s “strong stakeholder support” to ensure projects will be able to meet demand in the timeframe MISO needs them.

MISO so far requires details like synchronization and commercial operation dates, interconnection facilities finish dates, generator output, manufacturer and model numbers, fuel type and facility and transformer data.