MISO’s Expedited Project Request forms need standardization.
SPP's HILL = MISO's EPR. Load interconnection costs at MISO are all over the board.
Following SPP’s Large Load Integration efforts, I was curious about how MISO had recently modified the Expedited Project Request (EPR) process, which is MISO’s term for SPP’s High Impact Large Load (HILL).
For sure, there are process changes between SPP’s new proposed process and MISO’s. MISO’s process is written in Section 4.1.4. of the Transmission Planning Business Practices Manual.
Some of these changes are:
Once an EPR is received, MISO will conduct its analysis “no less frequently than every other month”. MISO states it will “post all proposed EPRs to be included as part of the analysis to MISO’s current Expedited Project Review portion of the MISO’s MTEP public webpage and send notice of their posting via email within two weeks after the start of each EPR study cycle.”
MISO states that it “will present the results at a monthly regional stakeholder meeting, generally a Technical Studies Task Force (TSTF). The stakeholder meeting is the main forum for MISO stakeholders to provide feedback or address concerns regarding the EPR”.
After the TSTF meeting, MISO will send a notice to the Planning Advisory Committee (PAC) and stakeholders will have 5 business days to provide written comments.
MISO states that “[a]fter the comment period closes, the EPR projects are considered approved by MISO, the status in the MTEP Portal for the project will be moved to Appendix A, and the requesting Transmission Owner is expected to move forward with the implementation of the project to meet its obligations and requirements as provided for in Section xx of the Transmission Owner’s Agreement”.
MISO states that all EPR projects approved prior to the 3rd Sub-regional Planning Meeting will be listed in the current year MTEP as Appendix A projects. In other words, all transmission projects approved before September 2024 SPM will be included in the MTEP24.
MISO makes a point of noting that Market Efficiency Projects (MEP) are not eligible for the expedited treatment. I am unsure why MISO is drawing attention to this distinction.
MISO explicitly calls out that Transmission Owners (TO) enjoy exceptions to the rule that these expedited requests need not wait until MISO completes its annual transmission planning process. MISO expects the TOs to “review the reasons why the needs driving the project are urgent and why the project was not identified early enough to be reviewed in the full MTEP review cycle” at a Sub-regional Planning Meeting (SPM) or at a Technical Study Task Force (TSTF) meeting.
One of the key questions that I receive from potential clients is around load interconnection costs at MISO. I then began reviewing the Appendix A projects with “other” as the Project Type and “Load Growth” as the Other Type in the Appendix A spreadsheet provided by MISO for each MTEP cycle. I confined my initial research to “MTEP24 Appendix A - New Local Reliability Projects”.
Source: Potomac Economics (Thanks to Simon Mahan @X)
To find an answer to the cost question of load interconnections, I began reading the project descriptions in Appendix A for the Load Growth projects. Surprisingly, most project descriptions do not provide a clear MW size of the load interconnection.
Source: MISO
For example, from a project description like this “MDU has new customer requesting service on our 41.6 kV system near our Leola substation of 50 MW. MDU will need to add 2-10 Mvar capacitors and add additional 41.6 kV breaker to the Leola substation.” I can surmise that 50 MW of load is seeking interconnection and the cost is $3.6 Million (provided in another column of the spreadsheet). Hence, the cost of interconnection on a $/MW basis is $72K at Montana Dakota Utility in South Dakota.
MDU provided a similar project description for another project, “MDU has an additional load request at Ellendale, ND for a total demand of 225 MW. MDU will serve the customer from its Ellendale 345 substation from the 230 kV. A 230 kV line will run to a new sub where a 230/34.5 transformer will be added along with the 34.5 kV breakers.” To interconnect 225 MW load, the cost was $16.776 Million. Hence, the cost of interconnection on a $/MW basis is nearly $75K. The ballpark value for load interconnection at MDU is $ 72,000-$75,000.
I cannot find similar MW values for load interconnection in the Project Description for other projects in the West region of MISO. The South region has significant costs, but I am unable to calculate $/MW values for load interconnection because the project description does not specify the load interconnection in MW. With only three projects in East, I thought my job was easier, but that’s not the case. Assuming 225 MVA is a 225 MW load, I calculate $128.667K per MW value for a load interconnection.
Source: MISO (this is an example of a good project description - 200 MW load for $12 Million equals $60K per MW of load)
I have better luck in the Central region of MISO. I was unable to calculate $ per MW for all 18 projects, but I was able to calculate $/MW for 5 of the projects based on the Project description. These $/MW were all over the board. Started with $10K/MW for a project in Ameren Missouri on one end to $556K/MW for a project in Ameren Illinois. Northern Indiana Public Service Company had a project with $60K/MW, Duke Energy Indiana had a project with $90K/MW and another Duke Energy Indiana had a cost of $275K/MW.
Source: MISO (this is an example of a project that does not provide cost to calculate $/MW load interconnection)
The wide variation in costs for load interconnection in one region of MISO (Central) suggests one reason for standardizing EPR forms and the information provided to MISO.
Some TOs give a long description (“Terre Haute Project Tonic Water new load: 130MW/43MVARs; located north of the Vigo Co. Industrial Park in the 13821 ckt; new 138kV line loop to be 954ACSS@200C; 138kV sub to be 7 breakers in a breaker and 1/2 layout; (2) dedicated customer-owned 138kV outlet lines to their load; (2) 36MVAR-138kV capacitors” whereas others are more cryptic (“This project will facilitate the connection of a 250 MW datacenter load at Montgomery (161 kV) Substation with a new straight bus and terminal”).
Source: MISO
The second reason is that, if you look at the Project Names in the above example, only two MTEP Project IDs (25367 and 50174) have “New Substation” in the Project Name; the remaining 16 don’t start with “New” in their Project Name. Therefore, we need to review the Project Description to determine if a new substation has been constructed as a result of this load interconnection.
Given the high volume of Expedited Project Requests at MISO, it is time for MISO to standardize the information provided. This will lead to transparency around load interconnection costs.