FERC Indicates "M2 Milestone Payment" Should Apply To All MISO Interconnection Customers

On March 29, 2016, FERC granted in part and denied in part a complaint filed by a group of merchant generators (the "Internal MISO Generation") against the Midcontinent Independent System Operator, Inc. ("MISO") which challenged, among other things, MISO's protocol for providing network resource interconnection service ("NRIS") delivery product to generators external to MISO that want to participate in MISO's capacity and energy markets, without requiring the external generators to make an "M2 Milestone Payment." The M2 Milestone Payment is a payment that certain classes of interconnection customers entering the final phase of MISO's interconnection process are required to make to MISO, and is used to help alleviate the costs of necessary network upgrades and restudies that are shifted to other interconnection customers in the event that an interconnection customer withdraws from the interconnection queue. In its order, FERC initiated an investigation to analyze, among