MISO files revised proposal for expedited power project queue at FERC

The Midcontinent Independent System Operator has revised and refiled with federal regulators a proposal to create an expedited interconnection queue process for power projects, which would address near-term resource adequacy and reliability concerns across the region.

MISO submitted its revised Expedited Resource Addition Study proposal (ER25-2454) to the US Federal Energy Regulatory Commission June 6, saying it addresses concerns FERC identified in a May 16 order that rejected the original ERAS proposal.

FERC nixed the original proposal over concerns that MISO did not have any limits on the number of projects that could enter the ERAS process, also saying in its order that the grid operator did not adequately show that ERAS would solve the region's identified reliability and resource adequacy needs.

MISO said in the refiling that it has inserted additional guardrails in the proposal to ensure that ERAS will be "narrowly tailored" and used as intended, including a cap on the number of applications, limits on the number of study cycles and language to ensure projects identify the load addition and/or resource adequacy deficiency they will be addressing. MISO also has added tariff language that will incorporate retail choice states within its footprint—Illinois and parts of Michigan —into the ERAS process, and the cap has been structured to accommodate the needs of retail choice states and independent power producers.

MISO, which manages the electric grid across 15 states in the Midwestern and Southern US, is requesting that FERC issue an order on "an expedited basis" by July 22, with an effective date of Aug. 6. MISO also asked FERC to establish a 10-day comment period for the filing, with June 16 as the comment date.

The grid operator said an expedited order will give interconnection customers certainty as they prepare their applications for the first ERAS quarterly study period, which is anticipated to start Sept. 2.

"The requested order and effective dates will ensure that the proposed changes are implemented to accelerate the study of projects to address the looming resource adequacy and reliability needs in the MISO footprint in the next few years," MISO said in the filing.

Details of revised proposal

ERAS calls for MISO to create a process separate from its standard queue by which eligible projects can be studied serially each quarter and granted expedited generator interconnection agreements within 90 days. The process aims to facilitate new generation to enter service and meet resource adequacy and reliability needs identified by relevant electric retail regulatory authorities.

The original proposal did not limit the number of eligible projects, but the latest version caps the number at 68. The 68-project limit includes a carve-out of 10 projects that may be submitted only by IPPs that have offtake agreements with entities other than load-serving entities and an additional carve-out of eight projects that may be submitted only by retail choice states for resource adequacy deficiencies.

This is a change from a draft of the revised proposal presented at a May 28 meeting of MISO's Planning Advisory Committee, in which the limit was indicated to be 50 projects.

"These carve-outs will allow these groups of applicants to participate on equal footing with other applicants proposing ERAS projects and must meet the same eligibility requirements to participate in ERAS," MISO said in the filing. "MISO added the carve-out for IPPs to address concerns that LSEs had an advantage over other entities when submitting projects to ERAS. The carve-out for the retail states also enables developers in those areas to participate in ERAS and set aside a portion of the projects to ensure they are able to participate."

No more than 10 projects will be studied per quarter, according to the filing. In addition, ERAS will sunset at the earlier of the completion of the 68-project study or on Aug. 31, 2027.

Other additional requirements for ERAS projects included in the filing:

• Documentation from a RERRA (e.g., a state utility commission) that verifies the project is needed to support a resource adequacy/reliability need
• Interconnection service must not exceed 150% of the identified megawatt need
• Project and resource adequacy/reliability must be within the same local resource zone
• Interconnection customer must identify specific load addition and/or resource adequacy deficiency the project will address (megawatt value, location, etc.), information that will be made public

All projects will be required to have a commercial operation date of no later than three years from submission, and all are eligible to use the grace period of up to three years that is afforded in MISO's pro forma generator interconnection agreements. Previous requirements, including application fees, will remain the same for ERAS applicants.

Retail choice states

The revised ERAS proposal also includes language that will incorporate retail choice states within MISO's footprint—Illinois and parts of Michigan—into the new process, a matter that was not fully addressed in the initial filing as the grid operator worked to develop this language with the parties involved. In retail choice jurisdictions, consumers have the option to purchase power from alternative suppliers other than their utility.

The proposed language says that if an interconnection customer's new generating facility will serve retail choice load, the customer will be required to provide proof of the resource adequacy deficiency, but will not have to include a written verification from a RERRA with their ERAS request. MISO will contact the respective RERRA in the retail state about the request, and the RERRA will then have 10 days from this date to state that the request should not be included in ERAS.