On January 19, 2024, FERC accepted MISO’s filing (ER24-340) to increase milestone payments, adopt an automatic withdrawal penalty, revise withdrawal penalty provisions, and expand site control requirements. These provisions are designed to further expedite the GIQ process and maximize transparency and certainty. 

The filing was developed through extensive collaboration in the stakeholder process, including multiple discussions in the Planning Advisory Committee and Interconnection Process Working Group. 


What is changing? 

Milestone Payment Increases 

  • Increase in Milestone 2 (M2), Milestone 3 (M3), and Milestone (M4) payments. 
    • M2 increased from $4,000/MW to $8,000/MW 
    • M3 is the greater of 20% of network upgrade costs minus M2 or $1,000/MW 
    • M4 is 30% of network upgrade costs minus M2 and M3 payments 

Site Control Requirements Increases 

  • Increased Point of Interconnection (POI) site control requirements. 
    • 50% site control from generator site to POI upon application, or $80,000/mile for the entire line mileage to POI 
    • 50% site control from generator site to POI and 50% of interconnection switchyard, if necessary, prior to Phase 2 
    • 100% site control from generator to POI, including interconnection switchyard, if necessary, prior to the Generator Interconnection Agreement (GIA) execution, or within 180 days of execution with an approved exception 

Escalating Automatic Withdrawal Penalty 

  • A new escalating automatic penalty upon withdrawal and adjustment to the calculation for harm imposed by the withdrawal. 
    • 10% of M2 at Decision Point 1 of the process 
    • 35% of M2 at Decision Point 2 of the process 
    • 75% of M2 during Phase 3 
    • 100% of M2 during GIA negotiations (five business days after final system integration study is posted) and beyond 

Penalty Free Withdrawal Provision Adjustments 

  • Adjusted penalty free withdrawal provisions to simplify calculation and reduce availability. 
    • Only applies between Phase 1 (P1) and P2, and again between P2 and P3 
    • Combined Network Upgrade (NU) and Affected System (AS) cost increased by 50% from P1 and P2, or increased by 35% from P2 and P3 



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Why is it changing? 

These reforms are needed to reduce the number of queue requests withdrawing from the process. The fewer projects in studies, the quicker it takes to complete; the fewer projects that withdraw, the more certain phase 1 and 2 study results are. 

Historically, about 70% of projects submitted to the queue withdraw, resulting in extensive rework and delays, as studies must be redone when projects withdraw. 


Historical Queue Completion/Dropouts Since 2017 




A reduction in withdrawals will lead to less changes in the network upgrades between studies thereby increasing upfront certainty for customers. Adjustments to refunds and removal of penalty free withdrawal will result in a transfer of funds from projects that drop out to projects that sign a generator interconnection agreement, reducing the overall costs of projects that will be built. 


Where can I go to learn more or get help? 

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