In the October 16, 2024, meeting of the Planning Advisory Committee (PAC), MISO discussed the cap refiling proposal and requested feedback.
Comments are due by October 25.
At the 10/16 PAC meeting, MISO stated that it intends to move forward with filing its cap proposal at FERC in the coming weeks and is removing the RERRA exemption from the proposal. MISO explained that it has another RERRA framework proposal forthcoming, but that it does not intend to delay the cap proposal until the RERRA exemption proposal is finalized. Many stakeholders, including Duke Energy and OMS, expressed concern over these filings not being submitted to FERC at the same time. Consumers Energy shares in these concerns over the gap between the proposed cap filing and any future RERRA exemption filing. These two proposals cannot be viewed independent of, or in isolation from, one another. The reasonableness of a cap proposal hinges on how MISO intends to deal with state approved projects needed to address reliability and clean energy needs. MISO stated in the PAC meeting that the next queue study cycle would not open until likely late Q2 or early Q3 2025. Given this timing, rushing the cap proposal to filing before the RERRA exemption is addressed is unwarranted. Consumers Energy reiterates thoughts raised by other stakeholders on the PAC call and asks that MISO delay the cap filing until the RERRA exemption proposal is finalized.
Apex Clean Energy appreciates the opportunity to provide its feedback on the queue cap refiling proposal MISO presented during the October 16, 2024, Planning Advisory Committee (PAC) meeting.
Apex believes that further refinement to the proposed queue cap refiling proposal is needed to ensure just and reasonable treatment of all generation interconnection customers.
Specifically, Apex provides the following feedback:
1. In order for a hard MW cap to be just and reasonable and fair to all generation developers, there needs to be a process for ensuring that all developers can participate in any given queue cycle.
2. Apex is very concerned about the issue of queue crashing and rushing the application window.
a. The simple cluster caps MISO has proposed leave open the possibility that any developer might submit large numbers of projects and MWs in an attempt to “lock up” the generation interconnection queue for several years.
b. This in turn leads other developers to believe that they must rush the application window opening to avoid being left out of the study upon the cap being reached.
3. Fundamentally, Apex does not support the concept of all projects in a cycle that are submitted after the cap is met being included in the following cycle.
a. Every generation developer should have an equal opportunity to participate in every window. This is critical to maintaining a fair and competitive environment.
b. Apex believes that an equal opportunity for participation will lead to a more diverse and robust market, ultimately benefiting all stakeholders.
c. To implement this, MISO should maintain the concept of queue application “windows.”
d. There should be a cap on the number of projects/MWs any given developer can submit into a given window.
i. This could be either a pro-rata rationing of the MWs under the cap amongst the developers that submitted projects during a defined queue submission window, or
ii. A straightforward per developer MW cap as a percentage of the applicable planning region cap.
iii. To ensure that multiple entities are accounted for under “parent” corporations, MISO could implement a simple attestation process.
4. Finally, MISO should review the results of the first “capped” queue process immediately upon closing the queue to determine whether queue crashing is occurring or other unintended adverse consequences have been the result of its proposal.
Thank you for considering our feedback.
We appreciate MISO's efforts in continuously improving the interconnection process and look forward to seeing positive changes implemented.
This feedback is submitted on behalf of the Louisiana Public Service Commission Staff ("LPSC Staff") to the PAC: Queue Improvements Cap Proposal (PAC-2023-1) (20241016). While the LPSC Staff understands the need for improvements to the interconnection queue process, it cannot support the current MISO queue cap proposal that no longer includes a RERRA exemption. Any queue cap proposal must include provisions to guarantee that projects needed to serve retail loads will not be excluded from the queue. The plan to file the queue cap proposal now and discuss the RERRA exemption or its replacement later is misguided. The queue cap proposal filing should be delayed until a RERRA exemption, or its replacement are resolved on a mutually acceptable basis after an adequate stakeholder process has been completed.
AES Clean Energy appreciates the opportunity to provide further feedback on the revised Queue Cap Proposal and tariff redlines.
AES Clean Energy continues to oppose the queue cap but appreciates MISO’s efforts to respond to our concerns that MISO evaluate the level of queue intake relative to expected resource additions needed over the next 20 years to facilitate Future 2A. To the extent that the Futures get refreshed before the post-three-cycle evaluation, MISO should also re-evaluate if the 50% queue cap is sufficient to meet these revised resource addition targets. If deficits are predicted, MISO should file any modification to the cap (if approved by FERC) even before the three cycles if necessary.
Furthermore, AES CE request that MISO expand Section 4.1.1.5 of the tariff to elucidate on how MISO will determine “effectiveness” of the queue cap. Some criteria could be reduction in queue processing times, higher conversion rates, and reduced variability in network upgrade costs from phase to phase. This review should also include a refreshed analysis similar to what is presented on slide 8, and include how effective the replacement process is at providing replacement MWs for retiring assets, expected load growth, RA needs, etc.
AES Clean Energy opposes exempt resources counting towards meeting the 50% queue cap. Up until the final proposal, MISO had discussed exemptions as being above and beyond the cap. MISO own analysis on slide 7 showed that the cap could be as large as 60% of peak load and still produce reasonable study models/results. Therefore, MISO should continue to exclude exempt resources from meeting the 50% cap. MISO has also articulated that they expect eligible exempt resources to be limited, therefore they should either cap exemptions at 10% of peak load or include the possible need to further limit exemptions during the post-three cycle evaluation.
AES CE does support the roll-over provision that would allow projects not accepted in the current queue cycle to roll over to subsequent cycles. While this will likely result in the queue being subscribed years in advance and delay the market’s ability to respond to investment signals, the roll-over is important to maintain open access. Additionally, if MISO did not roll over projects, we expect that those projects would quickly reapply to the next queue cycle and lead to the same ordering of projects, but with the added possibility of crashing MISO’s application portal.
While Steelhead continues to believe that a cap is unwarranted, we do have input on MISO's latest cap proposal.
For exemptions, it is not clear how capacity will be counted toward the cap. Requests to convert ERIS to NRIS have already gone through a prior study process and should not be counted toward the MW cap. The cap, in general, should only consider ERIS capacity, as not every generator requests NRIS. Approved Replacement Generating Facilities seeking additional interconnection service should only have the incremental capacity counted toward the MW cap.
We continue to be frustrated with the lack of certainty in joining the next queue cycle. While MISO will provide some visibility into how many requests have been received, this information is incomplete without the MW cap - to be posted "at least ten (10) Business Days prior to the application deadline" - and the amount of exemptions. If the 2023 Queue Cycle is used as a comparison, the next queue cycle could hit the MW cap, in some regions, well before the cycle closes. This leaves generators wondering for months if they've made the next cycle or will be bumped to the next year's cycle. To remedy this, we have two suggestions:
1) We strongly encourage MISO to post the MW cap earlier in the process. This number should be available from the base set of powerflow models used to build the GI models.
2) We would also propose that MISO set a nominal MW cap on exemptions for each region. For example, if the Central Region is capped at 18.3 GW, exemptions could be capped at 1%, or 1.8 GW.
With the total cap and exemptions known, generators would have certainty if they'll be included in the next cycle, once their projects are validated and they are under the MW cap (16.5 MW in this Central Region example). If the capacity set aside for exemptions is not utilized, MISO would pull from the next generators in the queue until the total cap is reached.
Clean Wisconsin, Environmental Law & Policy Center, Fresh Energy, Natural Resources Defense Council, Sustainable FERC Project, and Union of Concerned Scientists welcome the opportunity to comment on the changes to MISO’s proposed queue cap. First, we appreciate the analysis and shared data that indicate the proposed queue cap could still meet Future 2A resource expansion goals, but wonder whether such a cap effectively eliminates MISO’s ability to reach a Future 3A scenario, particularly given recent observations from stakeholders that Future 3A may be more indicative of MISO’s trajectory than Future 2A. Also, we maintain concerns about the upcoming RERRA exemption that MISO plans to propose in November, and support MISO’s plan to separate that part of the original proposal from the rest of the filing to allow more time to explore whether the RERRA exemption is workable or necessary. Finally, we disagree with MISO’s proposed timing to file the cap proposal before there is a better understanding of how MISO’s initial queue reforms have impacted the queue.
Overall, we agree that it is imperative for generation interconnection studies to be processed faster to add more generation to the footprint. MISO continues to push for a queue cap to meet that shared objective. However, we have concerns that a queue cap mechanism may not in fact ensure the faster study timelines that MISO anticipates. Therefore, we strongly recommend that MISO adjust the timeline for reevaluation of the cap. Rather than reevaluating in 3 years, we recommend that MISO conduct a meaningful review that they can share with stakeholders, coinciding with each queue cycle to ensure the cap is having its intended effect of accelerating queue study processing. In addition to evaluating the impacts of a MW cap after each GI queue cycle, we encourage MISO to continue to consider other ways it can improve the speed of processing interconnection requests.
MISO plans to file the queue cap proposal at FERC as soon as possible. Given that MISO has yet to experience a full queue cycle following its most recent interconnection queue reforms, we also recommend that MISO wait until the 2023 queue kickoff in January, when the queue reform penalties imposed on queue dropouts commences. That would allow MISO and FERC to more fully evaluate the effectiveness of the first set of reforms thereby enabling a more informed understanding of how the cap does or does not complement these initial reforms.
American Municipal Power (AMP) appreciates the opportunity to provide feedback on MISO’s generator interconnection queue cap refiling proposal and offers the following comments for consideration.
In the Queue Improvements Cap Proposal from the PAC meeting of October 16, 2024, MISO states on slide 2 that MISO is removing the RERRA exemptions from the proposal but keeping exemptions for Interconnection Requests related to Existing Generators, and that MISO is working on a future reform that will better address concerns that necessitated the need for RERRA exemptions while also allowing MISO members to meet future resource adequacy.
AMP recommends MISO delay the filing date for the Queue Cap Proposal until such time as MISO develops a complete proposal that includes RERRA exemptions. However, if MISO proceeds with a projected filing date of November 2024 for the Queue Cap Proposal, then AMP recommends that MISO specifically state in the filing that MISO will address RERRA exemptions in a future filing projected for the first quarter of 2025.
COMMENTS OF INVENERGY SOLAR DEVELOPMENT NORTH AMERICA LLC
AND INVENERGY WIND DEVELOPMENT NORTH AMERICA LLC
TO MISO QUEUE IMPROVEMENT CAP PROPOSAL
October 25, 2024
Invenergy Solar Development North America LLC And Invenergy Wind Development North America LLC (“Invenergy”) submits these comments to the Queue Improvements Cap Proposal that was presented at Planning Advisory committee on October 16, 2024.
Preliminary Remarks
Invenergy encourages MISO to allow time to assess the impact of its recent queue reform measures recently accepted by FERC. Those measures imposed significant additional risk and restrictions on generator developers aimed at limited queue entry.
Specific Comments On The Current Proposal
Invenergy provides the following feedback and encourages MISO to provide additional clarity on the following areas of its proposal.
Capping at 50% load still appears arbitrary; MISO should provide its modeling results for Stakeholder review and comment; MISO’s data also supports a 60% Cap.
Capping the queue at 50% of MTEP/DPP model non-coincident peak load is arbitrary. MISO has not provided supporting evidence that such a MW level would allow MISO to process study groups in line with expected tariff timeframes. Invenergy raised this point in earlier comments.
MISO now justifies the 50% cap by stating that, by applying the 50% cap to 2022 test case cycles, it resulted in no backbone network upgrades to the MISO or Affected System RTO system. This has the appearance of a benefit: network upgrade costs will be less if a 50% cap is imposed. However, MISO has not provided any of the models for stakeholders to review. The details and assumptions are critical. Further, this is just one isolated assessment. MISO must provide the modeling results and allow for a comment period and then address those comments before the Proposal moves forward resulting in any Tariff filing.
Invenergy notes that MISO’s information also shows no backbone upgrades in MISO or Affected System RTOs under the 60% case. 60% would add another 13 GW into the cycles. If MISO plans to move forward with the proposal, it should adjust the cap to 60% as a stakeholder compromise supported by MISO’s data that shows benefit.
Additional Process Transparency Detail is Necessary
MISO has communicated a seven (7) step process and associated flow chart which is helpful. However, based on how many additional questions MISO fielded at the last PAC meeting, this supports the notion that additional details need to be provided to stakeholders. Developing a FAQ document, memorializing the many questions being asked would be helpful. This level of detail is necessary for generator customers to be fully informed when planning well in advance for all possible outcomes should FERC approve MISO’s proposal.
RERRA Exemptions Invites Discrimination Against Fully Ready Projects
Invenergy applauds MISO’s decision to remove the RERRA exemption. That exemption will result in undue discrimination and preference for certain generating units and projects and should not be revived by MISO. MISO should continue to act as the independent RTO and protect the nature of its queue. Whether the cap is 50% or 60%, the resources will be used to serve load. MISO explains as much equating the capped amounts to Futures 2A amounts. LSEs can also get in the queue just like all other generation developers. If LSEs believe they will not have the resources to serve load, they can file a complaint at the FERC, seek a waiver from MISO tariff provisions and attempt to justify the need. When MISO tackles the RERRA exemptions again, they should also consider allowing such exemptions to go on top of their proposed cap as an option for stakeholders to consider.
PGIA, NRIS and Replacement Exemptions
Invenergy opposes MISO’s proposal to reduce the GW in a capped cycle based on these exemptions. MISO calls them exemptions, but they have changed character to reductions. MISO explained that, if there are 2 GW of requests in these areas, for example, the 68 MW will be reduced to 66 MW. This, again, shows preference and implicates queue jumping that the FERC has opposed. If MISO retains the measure, then it should be applied with balance: those projects can advance but it will be an exemption that is added to the 68 GW so MISO will process 70 GW in this example. MISO is confident that these 2 GW are not speculative, which supports adding to what MISO processes in the cycle study.
Details Pertaining to Resource Adequacy is Lacking
FERC specified in their rejection of the cap “any future section 205 filing to propose a study cycle cap must demonstrate how the cap ensures that MISO can study new generation seeking to interconnect in a manner that appropriately accounts for its future resource adequacy needs.” MISO addresses this by estimating the queue cap throughput volume exceeds the projected Futures 2A net additions. However, MISO’s resource adequacy construct is also “locational,” whereby individual Local Resource Zones each have their own Planning Reserve Margin Requirements (PRMR) and Local Clearing Requirements (LCR). As demonstrated in past Planning Resource Auctions (PRA), single LRZ’s can impact the Auction Clearing Price (ACP) of Sub-Regions or other LRZs. MISO has presented no data showing that the individual sub-regional caps equate to the generation that MISO projects in those same sub-regions in Futures 2A. Stakeholders must be provided with this data and an opportunity to comment, with MISO responding, before MISO moves to any filing at FERC. It is prudent for MISO to do so, or it risks another rejection at FERC.
Sunset Rather than Re-Evaluation
At a high level or conceptually, Invenergy supports evaluation of the cap provisions on a cyclical timeframe, however MISO provides no detail on the criteria MISO would use to evaluate if the cap rules should be adjusted.
Invenergy recommends that MISO incorporate a sunset provision should it proceed with the cap proposal. MISO says it is making strides to deliver studies faster and make use of technology. Furthermore, MISO’s recent queue reform measures accepted by the FERC will act to limit entry into the queue. Thus, at most, the cap should apply for a three-year period so the consequences and state of the queue can be assessed. If it proves needful, the cap could be re-initiated. If the cap no longer is needed, it will end and allow for open access and competition to flourish.
Feedback for MISO Queue Cap Changes
Duke Energy Indiana appreciates the opportunity to comment on the most recent queue cap proposal presented at the PAC committee. Duke would like to comment on a couple of aspects of the proposal.
Removal of the RERRA Exemptions
Duke’s primary issue with the proposal is with the elimination of the RERRA exemptions. These RERRA exemptions were key in allowing LSEs to maintain their goal of providing reliable resources to meet the load obligations. Given the load challenges ahead, on top of a very crowded interconnection queue, MISO needs to reconsider this exemption to maintain adequate supply for the increasing demand. MISO commented on working on a future reform that will better address these concerns but the lack of detail around this issue creates uncertainty for LSEs.
Future Reform to Address Resource Adequacy
MISO introduced this concept in this proposal. While Duke is supportive of this reform, we believe this should be done as one with the queue cap proposal, not as a separate issue and done sooner (now) rather than later.
3-Year Review of Effectiveness of the Queue Cap
Duke applauds MISO for its proposal to review its Cap process. As this is a major issue facing all market participants, adding a review is a valuable instrument for stakeholders and MISO.
Estimated Queue Cap compared to Future 2 A Net Additions
Duke question on this analysis along with a comment. Does the Future 2A look at the type of resource as far as projected DLOL when doing this analysis? If not, it may be valuable to see how the resource mix in the queue compares to the needs of the system.
Comments of Southern Renewable Energy Association on MISO Queue Cap Proposal
The Southern Renewable Energy Association submits the following comments on MISO’s Queue Cap Proposal presented at the October 16th Planning Advisory Committee. We continue to share an overarching concern with many stakeholders that MISO’s ability to increase throughput for interconnection studies in a timely manner will not be solved meaningfully by a MW Cap. MISO has struggled to complete interconnection studies before queue submissions climbed in recent years, and there are still 18.2GW’s of projects from MISO’s 2020 Cycle [1], a cycle that was much closer to the size of the footprint-wide MW Cap proposed by MISO, that has not proceeded through the queue. This evidence points to another factor delaying the processing of interconnection requests. TO delays are a common feature of delays reported in DPP Updates throughout MISO, and to address these delays MISO and TO’s must work together to streamline the process to better increase throughput.
Filing Date
Another concern of SREA is around the process MISO is pursuing to file their MW Cap proposal at FERC before the 2023 Cycle kick-off. This will not take into account the full effect of the Queue Reforms approved by FERC earlier this year, because queue submissions that withdraw before kickoff will be allowed to do so without incurring a penalty. As the date draws nearer and nearer for IC’s to withdraw projects without penalty, it’s expected that there will be more dropouts prior to kickoff, and not accounting for these dropouts provides an inaccurate representation of the effectiveness in reducing the overall queue cycle’s volume - MISO’s purpose for pursuing FERC approval of the readiness requirements, and a MW Cap. We advocate that MISO delay filing until a more accurate picture of the Queue Reform’s impact is presented at kickoff.
Review Period
We also believe that MISO’s proposal to review the MW Cap policy every 3 years to assess its effectiveness at reducing queue volumes is much too long to wait. If it is not effective at reducing queue volumes at the kickoff of a new cycle under the MW Cap policy, MISO should not hesitate to reconsider its effectiveness, and we consider yearly assessment of the MW Cap policy to be prudent. Afterall, MISO has proven that they are willing to exert considerable effort to provide analysis to develop two MW Cap proposals in an expedient timeframe, and the same rigor and efficiency should be applied to its removal if analysis proves it is not successful in reducing queue volumes.
RERRA Exemption
SREA members are appreciative of the removal of the RERRA exemption because they are concerned about discriminatory nature of the RERRA exemption, which undermines the stated purpose of the MW Cap proposal. However, MISO is not declining to put forth a RERRA exemption proposal but merely deferring a RERRA proposal to a later date, to be filed with FERC after filing the MW Cap proposal. Both the MW Cap proposal and the RERRA exemption proposal are dependent on each other and filing them apart from each other does not change that. SREA proposes that MISO resolve this issue by resuming stakeholder discussion of the RERRA exemption before filing with FERC. Doing so would also allow time for MISO to assess the effectiveness of the readiness reforms as projects withdraw from the 2023 Queue Cycle prior to kickoff.
SREA appreciates MISO’s solicitation of comments on this issue, but we urge MISO to consider the perspective of IC’s whom this process is supposed to accommodate. In order to maintain a competitive atmosphere for the generation procurement process across MISO states, it’s crucial that MISO maintain a competitive interconnection queue. The livelihood of SREA’s members depend on MISO increasing throughput of their interconnection queue, and we ask that MISO consider deeper underlying issues driving long-standing queue delays long before steep inclines in volumes in recent years.
[1] MISO Queue data as of 10/23 filtered for requests marked ‘Active’ and ‘2020 DPP Cycle’ in ‘Phase 1, 2, and 3’
The Independent Power Producer and Exempt Wholesale Generators (IPP) Sector thanks MISO for the opportunity to comment on MISO’s Queue Improvements Cap Proposal (PAC-2023-1). While the IPP Sector appreciates MISO’s efforts to make a queue cap more palatable by removing exemptions for Relevant Electric Retail Regulatory Authorities (RERRA) from its most recent queue cap proposal, the IPP Sector remains deeply concerned with MISO’s continued push for a generation interconnection queue cap as it does not resolve the underlying symptoms of MISO’s queue backlog and is potentially anti-competitive. Additionally, capping the amount of generation that may be developed in MISO does not support resource adequacy.
MISO’s Proposal Does Not Resolve Queue Backlog, Does Incent Speculative Projects and Greater Amount of Interconnection Requests
The IPP Sector supports efficient interconnection of resources to the MISO footprint, and believes reforms are necessary to solve a very real problem in MISO’s building queue backlog. However, MISO’s theory that a smaller queue size will equal faster queue execution is not supported by historical data. MISO’s 2018, 2019, and 2020 generation interconnection queue clusters were 39.7 GW, 44.1 GW, and 52.4 GW, respectively, all significantly under MISO’s proposed queue cap of approximately 68 GW. Nevertheless, each of those years’ interconnection queues have taken close to five years to complete, well over MISO’s 373-day goal for DPP cycles.[1] For DPP2021, only one study Region has succeeded in making it past DPP 2, now almost three years since application submittals. Fundamentally, MISO has no evidence to support that capping the queue will result in more efficient and accurate queue execution.
In fact, a more likely result of MISO’s proposed queue cap is that interconnection customers will face longer, multi-year waiting periods before even being studied, and developers will seek to avoid these longer delays at the cost of queue efficiency and accuracy. Presently, the prudent process for a resource development not ready for the queue is to wait and focus on preparing the project for the next queue. Resource developers benefit from taking the time to, potentially, collaborate with MISO and/or the applicable Transmission Owner (TO) to ensure sufficient due diligence prior to submitting a generation interconnection application. This ensures greater application success and minimizes the exposure to financial costs for the developer. However, MISO’s queue cap proposal creates a serial, first come first serve approach that incentivizes getting in line above all else. By implementing a cap, instituting a rollover from queue cycle to cycle, and allowing projects to be bumped from within the cap to outside the cap via exemptions, MISO is placing immense value on the earliest time stamp in line. Such an incentive structure will lead to an even larger queue with greater amounts of speculative projects because the greatest risk to the developer would become being pushed years down the line to subsequent interconnection queue cycles.
MISO’s Queue Cap Raises Concerns of Anti-Competitive, Barriers to Entry
With a first-in-line incentive structure in place, MISO will have also created an environment that favors larger generation developers with significant resources to the detriment of smaller developers, stifling competition that benefits consumers. To defend against the risk of projects not being studied for potentially years, larger companies with the resources to do so may submit substantial amounts of projects at the start of the cluster application window to reserve valuable spots in the limited queue cluster cycles. Developers who do not have the financial ability to reserve as many positions in line will see less opportunity to develop projects in MISO. Furthermore, with the possibility of developers being booted from one queue to another subsequent cluster cycle, all developers take on additional financial risk to the extent their Interconnection Requests require site control or financial security to be maintained until the start of a subsequent queue cycle. This risk is greater for smaller generator developers. These scenarios reflect barriers to entry and an anti-competitive environment contrary to FERC precedent and goals to facilitate new entry and support robust competitive wholesale markets as laid out in FERC Orders 888 and 2003.
MISO’s Queue Cap is Concerning Given MISO’s Need for More Generation.
MISO’s queue cap proposal will limit the amount of generation being added to MISO’s footprint at a time when MISO is indicating capacity entering the footprint is insufficient to keep pace with retiring capacity and increasing load.[2] Given MISO needs more generation, not less, MISO should focus efforts on increasing study efficiencies and boosting queue throughput. The IPP Sector commends MISO’s efforts in this regard related to automation related initiatives with Pearl Street’s SUGAR platform and would support similar efforts to enhance MISO’s queue study capabilities rather than simply limiting the amount of generation that can be studied. Especially considering historical data discussed above suggests smaller queue sizes do not correspond to completing interconnection studies on time, MISO’s queue cap proposal is likely to further ensure generation additions continue to fall short of future resource adequacy needs.
For the above reasons, the IPP Sector remains opposed to a generation interconnection queue cap. However, should MISO continue down the path of seeking a queue cap, MISO should delay a queue cap filing till, at a minimum, MISO and its members can see the impact of MISO’s FERC accepted queue reforms in Docket No. ER24-340-000 as well as the efficiency outcomes of implementing the Pearl Street SUGAR platform. Doing so would allow MISO and its members to better identify the impacts of each implementation and assess if further queue reform is necessary.
[1] BPM 15 Section 4.5.1
[2] MISO Update to the Board re Reliability Imperative, September 19, 2024. https://cdn.misoenergy.org/20240919%20Board%20of%20Directors%20Item%2008%20Reliability%20Imperative%20Update647828.pdf
Advanced Energy United appreciates the opportunity to submit these comments in response to the Midcontinent Independent System Operator, Inc.’s (MISO) request for stakeholder feedback on its proposed reforms for Generator Interconnection Queue Improvements (PAC-20230-1) following the October 16, 2024 Planning Advisory Committee (PAC) meeting.
Advanced Energy United is a national association of businesses making the energy we use secure, clean, and affordable. Advanced Energy United is the only industry association in the United States that represents the full range of advanced energy technologies and services, both grid-scale and distributed. Advanced energy includes energy efficiency, demand response, energy storage, wind, solar, hydro, nuclear, electric vehicles, and more. The comments expressed in this submission represent the position of Advanced Energy United but may not represent the views of any particular member.
Projects seeking to connect to the MISO grid have faced challenges with transparency, timeliness, costs, and uncertainty in the overall process. These procedures have led to extensive delays, and withdrawals of many projects. MISO plans on filing a proposal to set a MW cap on its interconnection queue. As described in our previous comments, this approach fails to address the deeper interconnection issues causing queue delays and will only exacerbate the current issues. Even more significant, with this initiative, MISO has failed to consider and account for the feedback of its stakeholders. The interconnection queue is a high priority for many stakeholders, with nearly 30 sets of different comments being submitted during the last request. Most commenters provided feedback opposing the cap or expressed that they could not support it in its current form. None outright supported it as is. With the most recent changes described during the 10/16/2024 PAC, even more will likely oppose the latest version. MISO needs to pause developing and filing a cap, listen to its stakeholders, and return with a thorough, robust set of interconnection reforms before considering filing with FERC.
United recognizes the challenges MISO faces as it processes a large number of interconnection requests, but reiterates its position that a cap will not speed up, nor enable MISO to manage the increasingly large volume of projects within its queue. Rather than implement a temporary, band-aid solution such as this cap, MISO needs to develop more thorough changes to address the root causes of its queue backlog. While too many exemptions have the potential to undermine the intent of the cap depending on their design, separating and deferring the discussion on queue prioritization for resource adequacy deprives stakeholders of the opportunity to consider the interactions between a queue cap and possible prioritization measures. Any cap would also create a barrier for states to achieve clean energy goals by restricting the overall queue.
Advanced Energy United encourages MISO to continue discussions on interconnection reforms. To allow thorough collaboration, MISO should pause the cap proposal until it is fully vetted, including all proposed components. MISO is already moving forward with promising automation initiatives, and should consider solutions such as software improvements, devoting additional resources to supporting the necessary studies and analysis or additional pre-queue screening, as well as other, more robust reforms, such as those highlighted in the recent report, Unlocking America’s Energy: How to Efficiently Connect New Generation to the Grid. These could include developing a more efficient and cost-effective approach to queue management, such as an entry-fee framework to provide upfront cost certainty, creating opportunities to fast-track projects, and optimizing study processes.
Despite this opportunity to consider additional reforms, United offers the following feedback on the current design:
In sum, MISO should listen to its stakeholders and pause this process, taking the opportunity for more robust reforms. Throughout several rounds of discussion, MISO has not clearly demonstrated how a cap would speed the interconnection process, address underlying inefficiencies, or decrease speculative projects. While a cap would limit the overall volume of requests for MISO to review, it would not speed up the process, reduce uncertainty that adds risk and cost, nor ensure advancement of the most-ready projects. MISO should also consider how artificially limiting the interconnection queue restricts the supply of new generation, which could lead to higher prices and costs for customers. It has failed to show how imposing a cap would lead to more just and reasonable rates. MISO should pursue more durable and impactful solutions to improve its interconnection processes.
Advanced Energy United appreciates the opportunity to provide these comments and looks forward to continuing to work with MISO to explore options to further improve the generator interconnection process in MISO. Please reach out to Lisa Barrett with any questions.
Respectfully submitted,
Lisa Barrett
202.380.1950 x3177
lbarrett@advancedenergyunited.org
Cordelio appreciates the opportunity to provide feedback on MISO’s Queue Improvements Cap Proposal (PAC-2023-1). Cordelio remains opposed to the queue cap proposal. Cordelio described its concerns in comments submitted to the Interconnection Process Working Group on August 19, 2024.
At the October 16 PAC meeting MISO proposed filing a queue cap now and a RERRA exemption later. Cordelio encourages MISO to develop and file these concepts as a single filing later. It would be beneficial for all parties to review and provide feedback on a complete proposal rather than removing a key component to be filed in the future.
Cordelio is concerned with MISO’s proposal to count MWs that are currently being submitted to the open queue towards the queue cap. Absent a FERC order, developers do not have all the information necessary to make decisions about submitting projects to the queue. Allowing projects to count towards the cap is also detrimental to MISO, since it encourages developers to rush to submit immature projects to the queue in order to get their place in line. Cordelio recommends MISO implement all queue cap components only after a final order is issued. At that time, MISO can open a queue cycle and allow those projects to count towards the cap, if a cap is approved.
Cordelio is also concerned with MISO’s proposal to implement a rolling queue cap. Again, this policy would be to MISO’s detriment. Developers would be encouraged to submit projects exclusively to guarantee a spot in the following queue and could flood the queue with immature projects.
Cordelio would also like to reiterate that a queue cap could limit competition and may not be permitted under the Federal Power Act.
As stated in previous comments, Cordelio encourages MISO to address queue delay concerns through better tools and additional staff rather than imposing a queue cap.
In response to the proposed generation interconnection queue cap presented at the October 16 PAC, the MISO Transmission Owners (Owners) have the following comments.
The Owners appreciate MISO providing details on how it arrived at the 50% non-coincident summer peak load threshold for the MW cap value. The Owners are supportive of the study models used in the interconnection studies having realistic dispatch assumptions and believe a MW cap is needed to achieve appropriate study models. Directionally, MISO’s MW cap proposal is an improvement to where the queue is today.
The Owners are interested in more information from MISO on the resource adequacy reforms under development and encourage MISO to pursue, sooner rather than later, reforms and/or exemptions to address the resource adequacy needs of its members. This additional information is needed to determine what, if any, sector positions are taken on the exemptions portion of the proposal.
Clean Grid Alliance Comments on MISO’s Queue Cap Proposal
Oct 25, 2024
Clean Grid Alliance appreciates the opportunity to provide feedback on MISO’s updated queue cap proposal presented at the Planning Advisory Committee on Oct 16th, 2024. We support MISO’s removal of the proposed RERRA exemption, which had no MW cap, and therefore would have defeated the purpose of a queue cap, essentially creating only a “queue jumping” mechanism, rather than limiting the queue in any way.
Clean Grid Alliance agrees with the many other stakeholders at the PAC (including utilities and state regulatory entities ) who requested that MISO wait and file the queue cap together with the replacement to the RERRA exemption that MISO noted intention to file prior to the next DPP study cycle kick off. While all stakeholders will not likely agree on the provisions of any RERRA exemptions “replacement”, it is very telling that there was full stakeholder consensus on waiting and filing both together next year, to understand the full proposal. Also, given that there are delays to starting the next DPP cycle regardless of any cap filing, there is no benefit to filing the cap earlier than the broader exemption filing.FERC and stakeholders will be deprived of the opportunity to evaluate the proposals together to understand implications for the queue.
CGA continues to have concerns that MISO will present another “queue-jumping” proposal, which is something we are opposed to. While the queue size is already down and a queue MW cap not likely needed, we are skeptical that a cap will do anything but limit competition, limit natural transmission expansion, and open the door for queue jumping. MISO’s 2020 and 2021 DPP cycles were around the size of the requested cap, but were not processed in a timely manner. Therefore, if MISO genuinely believes that a cap will allow for faster processing of the queue, we encourage MISO to work swiftly to implement the financial penalties from Order 2023 and add a financial penalty on itself if unable to meet the timelines it claims a cap will allow it to remain within. Having a specific set of metrics along with a financial penalty for not meeting those metrics will ensure that MISO is not just providing empty and abstract promises to push forward a queue-jumping proposal, but that it backs a queue cap as being necessary and effective. MISO has made a lot of changes to tighten interconnection customer requirements and costs but still lacks any direct policy or change to address their own and Transmission Owner accountability for not completing on-time, accurate studies.
Clean Grid Alliance encourages MISO to post the most recent coincident peak loads by study region on the GI website (ideally as part of the DPP study schedule spreadsheet). Looking at the tariff redlines, MISO will not have an obligation to post the cap MW until 10 business days before the application deadline. It would be helpful for MISO to provide preliminary amounts well ahead of time (similar to how 2023 estimates were provided in the Oct 16th presentation).
While CGA remains strongly opposed to any exemption, if MISO proceeds with the three remaining exemptions, CGA is strongly opposed to including the non-RERRA exemptions within the cap, preferring “on top of the cap” as had been previously proposed up to this point. This is a late change in the proposal that stakeholders first saw on Oct 16th. MISO up to that point had continuously presented that exempt resources would not count towards meeting the cap, but at the 11th hour has changed this. MISO’s analysis showed that the cap could be as high as 60% of load with ease of model convergence, so MISO should continue to exclude exempt resources from the cap and also raise the overall cap level to 60%. This is particularly relevant in light of the fact that MISO is not planning to backfill after study kick-off, when a significant amount of projects are expected to drop the queue. The remaining proposed exemptions are expected to be very small, unlike the RERRA exemptions which were projected to be at the tens of GW level. We also encourage MISO to provide criteria on why these exemptions are considered “not speculative”, yet other proposed exemptions are. Detailed explanations are critical to help stakeholders understand why the proposed exemptions do not result in undue discrimination or preference, which is prohibited by section 205 of the Federal Power Act.
While the queue cap has been framed as a solution, we believe it is not a step in the right direction. It fails to address the fundamental issue driving unsustainably low queue volumes: the significant cost and schedule uncertainties facing interconnection customers. Instead of focusing on reducing competition, MISO should concentrate on improving these core concerns. Recent queue reforms have done little to address the errors and delays caused by Transmission Owners (TOs), despite increasing costs and requirements for interconnection customers. Rather than limiting competition, MISO should focus on resolving these core issues. Additionally, we strongly urge MISO to adopt an explicit sunset provision in the tariff for the queue cap, rather than relying on the current, less definitive commitment to merely “review the effectiveness” of the cap after three study cycles. A clear expiration mechanism will limit the harms to interconnection customers of a permanent queue cap while allowing for necessary further queue reforms in a timely manner.
And finally, we want to bring attention to a small typo highlighted with bold and italics below in MISO’s redlined section 4.1.1.5. The bolded italic text below should instead read “…whether to terminate or modify the queue size limitation.”
4.1.1.5 Upon conclusion of the third DPP study cycle following the effective
of the Tariff revisions accepted in Commission Docket No. ER25-__
the Transmission Provider will conduct a review of the effectiveness of
the limitation on queue study cycle size with stakeholders and determine
whether to terminate or modify the size of the queue study cycle. In the
event the Transmission Provider determines not to file modifications or a
termination of the queue size limitation, the Transmission Provider shall
submit an informational report to the Commission describing the results of
this review upon completion of the stakeholder process.
The Arkansas Public Service Commission understands that MISO is not soliciting feedback on the decision for the removal of the RERRA exemption to MISO’s proposed queue cap. The Arkansas Public Service Commission submits this feedback to MISO to express its disappointment that MISO is refusing further stakeholder discussion regarding that exemption. The Arkansas Public Service Commission urges MISO to delay its queue cap Filing until its proposed future RERRA exemption is unveiled. The Arkansas Public Service Commission views the RERRA exemption as vitally important for states to maintain their own resource adequacy environment, especially since the queue caps are calculated and set by Planning Region and not individual local resource zones. If each LRZ were given a queue cap, then the needs of that LRZ could not be frustrated by desires and needs by other LRZs within the same planning region. MISO’s proposal also potentially makes it more difficult to account for individual Local Clearing Requirements, since certain amounts of generation must be maintained within an LRZ. The queue cap, and the mechanism to simply overflow generation interconnection requests to subsequent Queue Cycles potentially will prevent local LSEs from maintaining enough generation in their LCR requirements.
NextEra Energy Resources
Comments on MISO’s Queue Cap Proposal
October 25, 2024
NextEra Energy Resources (NextEra) appreciates the opportunity to comment on MISO’s latest version of its Queue Cap proposal, as presented to stakeholders on October 16, 2024. After MISO’s original request for a queue cap was rejected by FERC earlier this year, MISO has been discussing its intentions to refine and refile a queue cap proposal. NextEra remains concerned that a queue cap will not address the problems with the queue and will instead exacerbate issues by creating a rush to be first in line. These projects may not be quality projects and would prevent more buildable projects from making it under the cap in the first place. MISO has not provided a clear or compelling basis for the need for a queue cap, and it does not address MISO’s current delays caused by its backlogged cycles. Even if MISO decides to file the proposal, there are a number of elements of the proposal that should be revised. As discussed below, NextEra urges MISO to allow its previously-approved queue reforms to take effect, technology solutions to be implemented, and development of its RERRA proposal to occur before proceeding with filing a queue cap proposal at FERC.
NextEra provides the following feedback on elements of MISO’s revised proposal, as presented on October 16, 2024:
· MISO has not justified a cap of 50% peak load, by region. MISO has provided some preliminary assessment of the queue volumes, but the data shared to-date indicates a cap could be set at 60% of peak load at a minimum. MISO has not explained why it is proposing a cap lower than what the data suggests it could process. Furthermore, MISO has not explained why a cap will be an effective solution when it has not solved prior queue cycles with volumes well below the 50% cap it’s currently proposing.
· If MISO is determined to file a cap proposal with FERC, MISO should set a firm sunset date on the cap and commit to a review one year after implementationWhile MISO is planning to include a three-year review period in its filing, this is insufficient because MISO has provided no metrics on how it will evaluate whether the cap is working as intended. Three years is too long to wait to determine a cap’s effectiveness. Moreover, MISO has acknowledged that the cap is intended to be a temporary solution, and the proposal should reflect this and provide greater certainty to resource owners.
· MISO should eliminate the waterfall concept from the proposal, in which projects over the cap will be automatically placed in the subsequent queue cycle. This aspect of the proposal will create a rush to enter the queue and projects that get pushed to subsequent queue cycles may sit for long periods of time. During this period, project carrying costs such as land leases will continue to accumulate, driving up customer costs unnecessarily. Additionally, subsequent projects that enter the queue will not have transparency on how long they have to wait, creating uncertainty for projects. MISO should instead establish clear queue windows and not automatically push projects over the cap to the next queue cycle.
· Elimination of the RERRA exemptions process from the cap filing and the plan to instead file a separate proposal at a later date creates a significant disconnect for evaluating these various queue reforms. The RERRA exemptions proposal itself runs counter to open access, non-discrimination requirements. Until October 16, MISO addressed the cap and exceptions to the cap together as a single proposal. MISO has provided little information about the separate queue process it intends to reveal in November. As a result, it is impossible for stakeholders to holistically evaluate the impacts, desired outcomes, or unintended consequences of any of these proposals. MISO should take up these related queue reforms together, not in a piecemeal approach.
· MISO should delay any new queue reforms, including pursuit of a cap or RERRA exemptions process until the queue reforms accepted by FERC in early 2024 can take effect and until the process and technology enhancements it is pursuing with Pearl Street to streamline Phase 1 and automate the interconnection process are in place, which MISO has stated would be in February 2025. MISO proposed and FERC accepted significant reforms aimed at reducing speculative queue positions and subsequent restudies. However, MISO has not yet processed a queue cycle with these stricter requirements in place. Before moving forward with additional queue reforms, MISO should wait to see the benefits of those reforms on queue processing. Furthermore, the automation improvements MISO currently is pursuing will significantly speed up queue processing times. MISO should focus its efforts on ensuring these solutions go-live on time as intended in early 2025, instead of moving ahead with a queue cap filing now when any impacts from a cap likely will not result for another three to four years. Technology automation, not a cap, is how queue processing will be improved and MISO should focus its efforts on that value-adding work.
MISO is going to need as much generation as possible to meet anticipated load coming on the system, transition to a cleaner grid, and respond to extreme weather events. MISO will need to implement effective solutions that fix the problems with the queue and allow constructible projects to be built that meet the customer demand for the resources seeking interconnection on the MISO system. A cap proposal does not achieve those ends. Accordingly, NextEra urges MISO to delay pursuing a queue cap at FERC until automation solutions are in place, MISO sees the impacts of the queue reforms adopted in early 2024, and MISO has developed its RERRA proposal.
The OMS Transmission Planning (TPWG) provides this feedback to MISO in response to its Queue Improvements Cap Proposal at the October 16 PAC meeting. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.
The TPWG is working to understand the latest iteration of MISO’s queue cap proposal, and OMS members have expressed varying opinions on MISO’s decision to remove the RERRA exemption. Some TPWG members believe that the RERRA exemption is not needed in the queue cap proposal and would support MISO filing without it. Other members view the RERRA exemption as a critical component to the queue cap proposal, and if it is not included, they will consider protesting the filing at FERC as an inappropriate infringement on state authority over resource adequacy.
The TPWG would like additional detail as soon as possible regarding MISO’s recently announced expedited study process for resources that address resource adequacy needs. The TPWG is open to meeting with MISO to discuss this proposal and to help develop a workable framework.
Generally, the TPWG supports the inclusion of the exemptions for interconnection requests relating to existing generators (e.g., provisional GIA, ERIS to NRIS, and approved replacements), but we have not developed a position on whether this should be submitted in a separate (but simultaneous) filing from the queue cap, as MISO currently proposes.