By Amanda Durish Cook
MISO’s latest Order 1000 compliance filing — which revises the developer selection process and outlines a pro forma selected developer agreement (SDA) — has drawn criticism from developers and transmission owners seeking additional changes (ER15-2657).
MISO’s proposed Tariff changes, filed Sept. 16, include relaxing deadlines and participation requirements for the annual transmission developer qualification process to allow for “broader participation” in the competitive developer qualification and selection model. MISO prequalified 35 developers to bid on competitive transmission projects in 2014. This year, the RTO added 13 more developers.
Transource Energy, however, said that the changes to the selection process unreasonably grant MISO too much authority in transmission projects and their cost. The company said that under the revisions, MISO is allowed to unilaterally terminate developers’ SDAs and force them to bear the costs. Transource also accused the RTO of ignoring its feedback in the stakeholder process.
Similarly, Xcel Energy said that some of the changes “inappropriately expand the role of MISO.” For example, the company said, selected developers would be required to self-report any “potential violations” of federal or state law to MISO.
In a joint filing, International Transmission Co., Michigan Electric Transmission and ITC Midwest took issue with the requirement that developers submit projected revenue requirement information. This provision “could negatively impact an existing transmission owner’s ability to submit competitive bids because two developers with the same estimated costs will calculate different revenue requirements if one developer already has [a] plant in service in MISO.”
Little Rock-based Republic Transmission accused MISO of overlooking its duty to protect ratepayers in the interest of saving money for the RTO. The company said MISO ignored suggestions from stakeholders and provisions designed to cap or minimize the costs of projects in CAISO and PJM.
“MISO does not propose to ‘improve’ its developer selection process in a manner that protects MISO ratepayers by shifting its current minimal selection focus on cost to more heavily rely on the cost components of bids,” asserted Republic Transmission in its protest filing. “Much work remains in MISO for ratepayers to benefit from Order No. 1000.”
MISO seeks to implement the changes by Nov. 16, with the aim of posting its first competitive transmission project for bidding in January. Technically, MISO’s compliance obligations to meet Order 1000 ended on March 31, but the RTO elected to keep working with transmission owners and non-incumbent developers to refine Tariff language and develop a binding selected developer agreement.
“These enhancements and clarifications reflect MISO’s experience and discussions with stakeholders during the first year of the prequalification process as well as lessons learned from observing the processes of other RTOs,” MISO said.
MISO’s competitive transmission developer selection process has been the subject of four rounds of FERC compliance filings and, according to the RTO, 16 months of consultation with stakeholders. The RTO said it will make another compliance filing next month addressing other areas needing improvement.
