FERC has approved MISO’s new generation replacement provision that allows replacements to reconnect at more preferred points on the grid over clean energy groups’ concern that it plays favorites.
The commission said replacement generation in MISO should be able to link up at different points of interconnection (ER25-1802). MISO proposed that it would allow the interconnection point substitutions when they’re “electrically equivalent to the original point of interconnection” and when they don’t cause material adverse impact to MISO’s transmission system.
Clean energy groups, including American Clean Power Association, the Solar Energy Industries Association, Advanced Energy United and Clean Grid Alliance, had argued MISO’s proposal should be rejected because it’s unfair to other planned generating facilities. The groups said the plan would discriminate between similarly situated projects.
However, a group of utilities, including Alliant, Lansing Board of Water and Light, Consumers Energy, DTE, ITC, Michigan Public Power Agency, MidAmerican Energy, Muscatine Power and Water, Wolverine Power Supply Cooperative and WPPI Energy, said the proposal would allow replacement generation to connect at more favorable interconnection points that have similar impacts on the grid.
FERC decided the plan would allow “more cost-effective and timely replacement of existing generating facilities, which will help address regional resource adequacy needs and allow interconnection customers to avoid investing in redundant infrastructure.” The commission further said the replacement facilities would dodge duplicative contracts, deeds and site control costs that might come with both a new site for a replacement facility and “a path to connect that site to the original point of interconnection.”
The commission said it agreed with the Organization of MISO States that MISO’s plan would remain in keeping with MISO’s current methods for discovering and minimizing adverse impacts on the transmission system. FERC said it would pair “offering increased flexibility to interconnect new generation resources in a more efficient manner” with “supporting state resource planning and ratepayer affordability.”
FERC said the new prerequisites MISO placed on moving an interconnection point in addition to its usual replacement study process — interconnecting at the same voltage level, not introducing new constraints and not forcing a distribution factor change of more than 5% — “will ensure that an alternate point of interconnection is electrically equivalent to the existing point of interconnection.”
The commission disagreed with arguments that by allowing replacement facilities to move their points of interconnection, MISO was creating a process that more closely resembled a new interconnection request with the added bonus of skipping the queue.
“We do not believe that providing this limited flexibility to replacement generating facilities to interconnect at a different, but electrically equivalent, point of interconnection results in an unduly discriminatory interconnection process,” FERC wrote in the May 27 order.
FERC said MISO’s commitment to preventing a replacement generator from adversely affecting the grid should take care of clean energy groups’ concern that permission to move a point of interconnection would drive up network upgrade costs by replacements claiming spots on the grid that other interconnection customers had “reasonably expected” to use.
MISO has said its generator replacement process has been instrumental in limiting the impacts of power plant retirements. Since it began the process in 2019, MISO said it has accepted about 5.9 GW in replacement requests and is studying 4.9 GW of replacement requests.
The RTO expects 25 GW of coal retirements through 2030, up 5% from its 2024 forecast. In the same time frame, MISO’s membership plans to add about 10 GW of solar generation and significantly more gas generation.