Midcontinent Independent System Operator (MISO) is proposing another round of interconnection queue reform.  On December 31, 2015, MISO filed proposed revisions to its Open Access Transmission, Energy and Operating Reserve Markets Tariff with the Federal Energy Regulatory Commission (FERC). The revisions, which amend MISO’s Generator Interconnection Procedures, would be MISO’s fourth significant set of queue reforms since 2008, but the first since 2012. MISO is seeking to address what it describes in its filings as “significant delays” in the generator interconnection queue, particularly in the Definitive Planning Phase (DPP), that MISO argues are primarily caused by higher-queued projects withdrawing from the queue and forcing unscheduled restudies of the lower-queued projects.  To address these delays and to prepare for anticipated “significant new renewable and gas development in the footprint in response to the changing regulatory landscape,”  MISO says that it is seeking with this proposal to “optimize the restudy process” while also addressing other concerns identified by MISO and in the stakeholder process.  MISO has requested that its proposed tariff revisions be effective as of March 30, 2016.

Highlights of the proposal include:

  • A System Impact Study at each of the three DPP Phases;
  • Two “designated off-ramps” or Decision Points, allowing a customer to withdraw from the queue on a “more structured basis,” and which occur immediately after the System Impact Studies in DPP Phases I & II;
  • Addition of two new milestone payments, M3 and M4, in DPP Phases II and III, incentivizing withdrawal at the Decision Points and funding cost increases caused by withdrawing projects (the immediately preceding milestone payment would be refundable to a withdrawing project);
  • Removal of the required restudy due to a change to a higher-queued project for any Interconnection Customers with a completed Generator Interconnection Agreement, unless ordered by FERC;
  • A voluntary “Pre-Queue Feasibility Phase” to replace the current Interconnection Feasibility Study and System Planning and Analysis Phase

MISO’s cover letter summarizing the 1,600-page filing is available here. (pdf)

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Photo of Emma Fazio Emma Fazio

Emma Fazio is an attorney in the Energy Development group. Emma assists clients with energy regulatory and transactional matters. Prior to joining the Firm, Emma was a judicial law clerk to the Honorable Matthew E. Johnson at the Minnesota Court of Appeals in…

Emma Fazio is an attorney in the Energy Development group. Emma assists clients with energy regulatory and transactional matters. Prior to joining the Firm, Emma was a judicial law clerk to the Honorable Matthew E. Johnson at the Minnesota Court of Appeals in St. Paul, Minnesota. She also clerked at the Minnesota Pollution Control Agency in St. Paul, Minnesota (2014) and the Department of Justice, Environmental and Natural Resources Division in Washington, D.C. (2013).

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Sarah Johnson Phillips is a partner in the firm’s Energy Development practice group, where she focuses on energy project development; buying, selling and financing energy projects; and energy regulatory matters. She advises large wind and solar project developers on permitting and real estate…

Sarah Johnson Phillips is a partner in the firm’s Energy Development practice group, where she focuses on energy project development; buying, selling and financing energy projects; and energy regulatory matters. She advises large wind and solar project developers on permitting and real estate matters, including obtaining major project permits, negotiating leases and easements, and title work.  She also has particular experience working on distributed solar and community-shared solar projects, including negotiating offtake agreements, leases, financing arrangements, M&A transactions, interconnection agreements, and regulatory matters. In addition, Sarah works with large energy consumers on a range of regulatory issues and proceedings affecting ratepayers and regularly appears before the Minnesota Public Utilities Commission.

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