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How does MISO’s queue reform change the economics of battery development?

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How does MISO’s queue reform change the economics of battery development?

MISO’s Definitive Planning Process (DPP) reforms, aimed at reducing connection queues, took effect in 2024, doubling upfront deposits and introducing automatic withdrawal penalties. A 200 MW battery project now commits approximately $1.9 million before studies begin and risks forfeiting up to $1.6 million if it exits during Generator Interconnection Agreement (GIA) negotiations.

The reforms punish wait-and-see strategies. Developers can no longer hold speculative queue positions cheaply. Projects entering closer to final investment decision will benefit. Projects that entered hoping to flip or defer face narrower exit windows and escalating penalties.

Key Findings for Battery Developers

  1. In MISO, upfront capital requirements doubled to $1.9 million for a 200 MW project, with $1.6 million at risk by GIA negotiations.
  2. MISO South clears projects roughly 9 months faster than MISO North.
  3. Battery projects average 3.2 years before GIA, longer than any other resource type.
  4. Site control requirements escalate to 100% before GIA, with no financial substitute allowed.
  5. The reformed process targets 373 days to GIA, a 26% reduction from prior cycles.

In this research, we look at:

  • How the new deposit and penalty structure changes the cost of holding a queue position.
  • Where capital and time are now at risk across the interconnection queue stages.
  • Why site control requirements matter earlier in the process.
  • What storage developers should do differently under the reformed queue.

How much capital do BESS projects commit upfront in MISO?

A 200 MW battery project now commits approximately $1.9 million before Phase 1 studies begin. MISO’s reforms doubled the 2nd milestone readiness deposit from $4,000/MW to $8,000/MW.

The total includes three components: a $5,000 non-refundable application fee (D1), approximately $320,000 in study deposits (D2, refundable), and a $1,600,000 readiness deposit (M2). MISO designed the structure to shift costs from projects that withdraw to projects that complete.


What happens if a battery project withdraws from MISO’s queue?

Withdrawal penalties escalate automatically based on when a project exits. There is no discretion. The forfeiture schedule is built into the tariff.

For a 200 MW project with a $1.6 million M2 deposit:

  • Decision Point 1: 10% forfeited ($160,000)
  • Decision Point 2: 35% forfeited ($560,000)
  • Phase 3: 75% forfeited ($1,200,000)
  • GIA negotiations and beyond: 100% forfeited ($1,600,000)

Penalty-free withdrawal windows have narrowed. Developers can only exit without penalty between phases, and only if network upgrade costs plus affected system costs increase by 50% (P1 to P2) or 35% (P2 to P3).

This structure targets MISO’s withdrawal problem. Historically, 73% of interconnection requests withdrew, causing study rework and delays for remaining projects.

However, the reformed process targets 373 days from application to GIA, a 26% reduction from prior cycles. Current cycles show active delays. In the East (ATC) DPP-2021 cycle, two projects withdrew after final SIS posting, triggering a 60-day re-study.


How long do battery projects spend in MISO’s interconnection queue?

Battery projects average 3.2 years in MISO’s queue, longer than any other resource type.

Regional variation is significant. MISO South clears projects roughly 9 months faster than MISO North, which handles 70% of queue volume. The Central region shows the longest timelines: 4 to 5 years from DPP entry to GIA execution.


When must battery developers demonstrate site control in MISO?

Site control means the developer has legal rights to the land, whether through ownership, lease, or option agreement. The reforms introduce escalating requirements at each milestone.

MISO’s reforms impose escalating site control requirements that eliminate financial substitutes at later stages. Projects that entered with speculative site positions now face hard deadlines to acquire control or withdraw.

At application, developers must demonstrate legal rights to 50% of the land from the generator to the point of interconnection. Projects without site control can post $80,000 per mile as security instead. Before Phase 2, developers must control 50% of the switchyard footprint. This is the land where the project connects to the transmission system.

Before GIA execution, developers must control 100% of all land. No financial substitute is allowed at this final stage. Projects that cannot demonstrate full site control cannot proceed to a Generator Interconnection Agreement.


What does MISO’s DPP-2025 queue look like for batteries?

MISO’s DPP-2025 cycle launched January 6, 2025 with 78 GW seeking interconnection. Central and South regions lead submissions.

Solar and hybrid projects dominate. Standalone storage represents a smaller share, though 50 GW of BESS sits in MISO’s total 650 GW queue.

The near-absence of 2023-vintage projects (1.1 GW versus 73 GW in 2022) reflects MISO’s June 2023 decision to halt new applications pending reform approval.


What should battery developers do differently under MISO’s reformed queue?

MISO’s DPP reforms reward projects that enter closer to final investment decision.

Three strategic implications:

First, budget for forfeiture. A 200 MW project should model scenarios where $160,000 to $1.6 million of the M2 deposit is lost.

Second, secure site control earlier. The 100% requirement at GIA leaves no room for last-minute land acquisition. Lock site control before entering Phase 2.

Third, select regions strategically. MISO South’s faster timelines reduce capital lock-up by roughly 9 months versus MISO North. Projects in the Central region should plan for 4+ year durations.

The reforms transfer costs from projects that withdraw to projects that complete. Developers with mature projects and strong capital backing benefit.