MISO Updates Interconnection Rules

18 October 2017 Renewable Energy Outlook Blog
Authors: Thomas McCann Mullooly Olya Petukhova

FERC approved MISO’s proposed changes to its generator interconnection procedure (“GIP”) and generator interconnection agreement (“GIA”), designed to streamline MISO’s interconnection queue process. These changes will affect all interconnection requests made after January 4, 2017 and all prior requests that have not yet completed a system impact study.

The new provisions are largely designed to address delays in the Definitive Planning Phase (“DPP”) of the interconnection process caused by the need for unplanned restudies triggered when higher-queued projects leave the queue. The revised interconnection procedures contain the following changes:

  • The DPP will be divided into three phases, each involving its own system impact study (Phase I – preliminary system impact study; Phase II – revised system impact study, and Phase III – final system impact study). Each phase will require a milestone payment to enter, and (following the customer’s receipt of the results of the impact study conducted during that phase), a “decision point” where the customer can withdraw from queue and receive a refund for its previous milestone payment.
  • A mandatory scoping meeting (previously optional) between the interconnection customer, MISO, and the transmission owner to discuss alternative interconnection methods.
  • Increased site control requirements: the interconnection customer must demonstrate 75% site control (as opposed to previous 50%) at the time of the interconnection request, and full site control at the second phase of the DPP.
  • New language allowing a customer to request a Provisional GIA at any time up to and including the “decision point” in Phase II of the DPP, and (in the event of significant delays in the interconnection process) at the “decision point” in Phase III. The GIP previously did not address when a customer could make such a request.
  • A new pro-forma study services agreement between MISO and any transmission owner or consultant performing interconnection studies, designating the interconnection customer as the intended beneficiary.
  • Modifications to milestone payment refund provisions: a customer is entitled to a full refund of milestone payments where the cost estimates in the current DPP phase system impact study increased by more than 25% and more than $10,000 per MW over the previous phase’s study (formerly, a customer would be entitled to a refund if the network upgrade costs estimate increased by more than 25% between the system impact study and the facilities study). FERC also ordered MISO to propose, in a compliance filing, additional provisions allowing refunds in the event of significant changes to cumulative network upgrade costs over the entire DPP process (not just between two phases).
  • Changes to the provisions requiring restudies for customers with executed GIAs. FERC accepted MISO’s proposal whereby, instead of conducting restudies (as it had previously done) upon a withdrawal of a higher-queued project, MISO will simply determine if any common use or shared network upgrades are still needed and if so, reallocate the upgrade costs “among the remaining projects that require the upgrade(s) in question.” FERC also ordered MISO to clarify in a compliance filing what events (besides withdrawal of higher-queued projects) would trigger restudies.

The order was released on January 3, 2017 in Docket ER17-156-000, a link to which can be found here.

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