CARMEL, Ind. — MISO announced it will move forward on an annual interconnection queue cap based on 50% of peak load for the year in question, this time removing exemptions for projects regulators deem essential.  

Stakeholders learned at an Oct. 16 Planning Advisory Committee meeting that MISO plans to scrap a regulator exemption from the annual megawatt cap it has designed for its generator interconnection queue. The deletion appeared unpopular among some stakeholders and state regulatory agencies.  

MISO’s Ryan Westphal said removal of regulators’ ability to name exempted generation projects will prevent the cap from being diluted with exceptions to the rule. He also said MISO heard stakeholders’ concerns about how MISO would limit the number of regulators’ exemptions and how it would give those exemptions priority.  

FERC last year rejected MISO’s first attempt to institute an annual megawatt cap on the queue based on concerns over too many cap exemptions, the formula to establish the cap and potential resource adequacy deficits from limiting new generation onto the grid. (See FERC Rejects MW Cap, Approves MISO’s Other Stricter Interconnection Queue Rules.)   

Westphal said MISO needs a “reasonable number of resources and a reasonable dispatch” to be able to build sound study models.  

“All of us can agree that in the 2022, 2023 modeling, there are a lot of resources in there that are creating a lot of difficulties, engineering problems,” Westphal said.  

Westphal also said a 50% peak load cap should eliminate the need for “backbone” network upgrades, where interconnection customers are responsible for large transmission projects.  

MISO previously said regulatory authorities would be allowed exemptions to the cap when generation additions are needed for resource adequacy or to serve documented load that regulators have authority over. MISO said it would allow one cap exemption per 3 GW of documented load that the regulatory authority serves. (See MISO: 50% Peak Load Cap, Software Help Key for Crowded, Delayed Queue.) 

MISO has said that even with a cap in place, it could achieve a total 310-GW queue throughput through 2042. The RTO assumed a 68-GW annual cap based on its current annual peak and took its historic 21% completion rate into account to come up with 14.3 GW per year in completed projects. MISO has about 320 GW in active interconnection requests in its queue. 

MISO staff have said controlling the cadence of project submissions is key to improving the quality of initial studies and potentially reducing network upgrade costs by being able to use a more true-to-life resource dispatch in models. MISO said once a cap is met for an interconnection cycle, projects will line up for the next year’s study cycle.  

The RTO has also committed to a three-year review of the effectiveness of the queue cap. 

MISO: 2nd Filing on the Way to Address Regulators’ Necessities

MISO’s Andy Witmeier said MISO dropped regulators’ exemption because planners didn’t see how a single exemption could address the multitude of imminent resource adequacy troubles.  

Instead, Witmeier said MISO will develop a separate, “more holistic” proposal with stakeholders to find ways to speed up queue processing for projects that keep MISO in the black on resource needs.  

Duke Energy’s Jay Rasmussen said he thought MISO is missing an opportunity to address resource adequacy issues within the cap.

Rasmussen pointed out that large load additions are on the horizon for load-serving entities. He said filing to implement a cap without acknowledging generation needs creates a “lag” for interconnection customers. 

Illinois Commerce Commissioner Michael Carrigan said while the Organization of MISO States sympathizes with how difficult queue studies have become for MISO, “states very clearly value their respective authority.” Carrigan said he didn’t see a path to states supporting MISO’s queue cap proposal at FERC without some sort of exception for generation needed to preserve resource adequacy. 

“This is a concern and could be very problematic,” Carrigan said.  

“Our decision is that we need to address these in separate filings because they’re separate issues,” Witmeier said. He said MISO staff plan to discuss how to expedite generation projects necessary to resource adequacy in upcoming Planning Advisory Committee meetings through January. He said MISO could be ready for a separate filing by the first quarter of 2025.  

At a Sept. 12 Organization of MISO States board meeting, OMS Director of Legal and Regulatory Affairs Brad Pope said MISO’s queue cap needs a “workable” exemption for regulatory agencies when they are reliant on a developer’s generation submittal. 

While it’s jettisoning its regulator exemption, MISO said it would maintain cap exemptions for existing resources. Those resources may need to enter the queue to replace their output with an approved generation facility, receive provisional interconnection agreements or upgrade their current basic, unguaranteed energy resource interconnection service to the higher-quality, firm network resource interconnection service. Staff said those reasons don’t include proposing speculative generation projects and can earn exemptions.  

Bill Booth, consultant to the Mississippi Public Service Commission, argued that projects regulators approve under utilities’ integrated resource plans are not speculative.  

“The goal of this whole approach is to reduce speculative projects. Do you think projects approved under a state IRP process are speculative?” he asked rhetorically.  

Witmeier said the past few times MISO discussed its proposed cap with stakeholders, the regulator exemption proved to be a sticking point.  

“Folks are concerned about what it means and how it will be managed,” he said.  

Some stakeholders asked MISO to delay its planned early November filing with FERC for a queue cap until it devises a way to address projects deemed necessary by states for resource adequacy.  

NextEra Energy’s Erin Murphy said a “brief pause” makes sense considering MISO is working with tech startup Pearl Street to automate some study processes. She said perhaps MISO could wait to gauge the effectiveness of the new software’s ability to shrink wait times before it limits entrants.  

Witmeier, however, said a queue cap has been in the works in MISO’s stakeholder process for two years. He said the need for a queue cap and creating a means to usher resource adequacy projects through faster are unrelated matters.  

“I see no need to put it on the shelf just because we’re going to go after a separate process,” Witmeier said.  

Booth said MISO required a little “intellectual integrity.” He said instead of MISO polishing and explaining a regulator exemption, MISO simply chopped its filing in half, with no guarantee of when it would address state-required generation projects.  

Consumers Energy’s Dan Alfred said his utility’s support of the queue cap hinges on a companion resource adequacy exemption.  

“I don’t understand why you’re not listening to the feedback here,” Alfred said.