The Midcontinent Independent System Operator (MISO), one of North America's largest regional transmission organizations, has struggled for years with completing studies of the growing volume of projects in its interconnection queue. On Monday, March 17, MISO filed their Expedited Resource Addition Study (ERAS) proposal at the Federal Energy Regulatory Commission (FERC) to speed up resource deployment and address the backlog in their interconnection queue.

Discussion of MISO’s proposal through the stakeholder process allowed very little time between meetings for stakeholders to provide feedback, and for MISO to fully review that feedback. The result was a stakeholder process held from November ‘24 to March ‘25 that didn’t meaningfully consider or incorporate stakeholder input. At a December 6 workshop for instance, MISO openly admitted that they hadn’t fully reviewed stakeholder comments before modifying their proposal.

While there was ample feedback in following meetings, notably from the developer community which holds the majority of projects in the interconnection queue, this feedback was not meaningfully considered in the final proposal that went to FERC. While the intent is to bring resources online quickly to meet rapidly growing demand, the proposal creates a separate interconnection study process that could delay existing projects and ultimately fail to expedite new ones. A better solution lies in utilizing MISO’s existing Provisional Generator Interconnection Agreement (PGIA) framework, which can meet the same goals without disrupting projects already in the queue.

The Problems with ERAS

In MISO’s FERC filing, there is a broad statement that ERAS is needed to fulfill urgent and pressing resource adequacy needs throughout their footprint. However, this need is based mainly on new large load customers - like data centers and manufacturing - rather than gaps created by retiring generation, or limited performance of resources during risk periods. MISO’s case also rests on an assessment made in their 2024 Organization of MISO States (OMS) report which indicates a significant resource adequacy need of 2.7GW’s by the year 2029 or sooner.

The problem is that this report uses the years 2020-22 when the pace of new resource additions were much slower, and it recognizes zero additions of battery energy storage resources. This is highly incongruous. In MISO South alone, there are roughly 3.9GW’s of solar and 1GW of battery energy storage projects that already have an interconnection agreement and are projected to be online in the next three years. Including what is in MISO’s queue for MISO South, there are over 17GW’s of energy storage and hybrid (solar and storage combined) resources in the queue that have an Commercial Operation Date (COD) between 2026-28. MISO’s assumption in the OMS Report is that none of these resources will come online, which is a major gap in their reasoning.

MISO has yet to demonstrate that ERAS will improve the interconnection queue process. In fact, it is likely to create additional problems, undermining the goal of expediting new generation to meet urgent resource needs. The ERAS process will allow certain projects from their existing queue to move to the ERAS queue. However, removing projects from MISO’s Definitive Planning Process (DPP) will trigger interconnection restudies, further delaying other projects already in the queue.

Additionally, MISO has not proposed any limitations on the number or size of ERAS projects in each cycle. This lack of limits could lead to long study times and introduce the same issues currently plaguing the queue. Furthermore, MISO’s already overburdened resources make it unlikely that their interconnection team will be able to support the implementation of ERAS without further delays to the existing queue.

Another significant concern is the time allocated for ERAS projects to reach Commercial Operation Date. MISO is proposing up to six years for expedited projects to achieve COD, which does not accelerate deployment of resources any quicker than projects already in the queue. This extended timeline fails to justify an expedited study process, as it doesn’t significantly shorten the construction phase for urgently needed resources - it just helps them get an interconnection agreement quicker.

Another challenging aspect is the preferential treatment granted to Load Serving Entities (LSEs), which will likely be allowed to jump ahead of projects in the queue. While MISO includes in the ERAS proposal that ‘other agreements’ between Independent Power Producers (IPPs) and LSE’s for a resource adequacy need endorsed by a RERRA, can enter the ERAS queue, there isn’t clarity on what ‘other agreements’ qualify. Ultimately, the advantage rests with the LSE that has contracted a new load addition to propose a project that will serve it, and this is much more likely to happen. There simply isn’t an opportunity for IPPs to participate on an even playing field with LSE’s that are attempting to submit projects to the ERAS process. Additionally, the requirement that projects must be under review by a state or RERRA adds another unnecessary barrier, as IPPs typically do not seek such approvals before submitting projects to MISO.

One of the biggest problems from a technical standpoint is that the ERAS process uses a completely different study model for processing interconnection requests, using instead MISO’s Transmission Expansion Plan (MTEP) model, rather than the DPP model used for their existing interconnection queue. This is problematic, because if you’re reserving capacity in the MTEP model, but not in the DPP, that capacity is still reserved regardless. And there is a clear advantage for ERAS projects which move faster through their study process to reserve capacity on transmission lines in advance of projects in the existing queue. There is a very real possibility that ERAS projects could unfairly take advantage of available transmission capacity in MTEP while their project is not commercially operational for multiple years, all the while depriving projects in DPP of that capacity. This dynamic of first-come, first-served could also shift upgrade costs to projects in the DPP queue.

For these reasons, the ERAS proposal will not effectively ensure the timely addition of new generation to meet resource needs, and will harm projects in the existing queue. It may help a project get a GIA but that is not the same as having a project online helping to meet new demand. Instead, it will harm interconnection customers already in the queue that have done their due diligence in following the MISO interconnection study processes paying required study costs, complying with recent MISO study reforms, while playing a crucial role in providing cost competitive solutions to power needs throughout MISO. ERAS represents an approach to interconnecting new generation resources that is anti-competition, and potentially violates FERC rules on non-discriminatory, open access to wholesale markets with little benefit in return.

Why MISO's ERAS is Different from PJM's RRI

MISO’s ERAS proposal differs significantly from the PJM Reliability Resource Initiative (RRI), an expedited interconnection process recently approved by FERC. However, MISO has failed to consider key elements from the RRI process, which should serve as a model.

• ​Discriminatory Practices and Open Access Violations: One key difference between ERAS and RRI is that the RRI allows IPPs equal access to submit projects, whereas ERAS allows LSEs to submit any project that meets capacity but restricts all other interconnection customers to only those projects with executed PPAs. FERC’s approval of the RRI made it clear that equal access for all resources is essential to prevent undue discrimination, something MISO’s ERAS process fails to address. By placing IPPs at a disadvantage, ERAS runs counter to FERC’s principles of non-discriminatory open access as outlined in Order No. 888.
• One-Time vs. Recurring Process: Another distinction is that RRI is a one-time process for a limited number of projects, whereas ERAS proposes a recurring process with no limitations on the number or size of projects in each cycle. FERC made it clear that if the RRI were not a one-time emergency process, it would not have found it to be just and reasonable. This is the same allowance for the Southwest Power Pool’s (SPP) proposal for a one time process, that allows Load Responsible Entities (like electric utilities) to submit generation projects to a separate queue that allows them to jump ahead of projects in the existing interconnection queue. While still under consideration by stakeholders in a recent Revision Request issued by SPP, another key difference about SPP’s process is that it requires projects to come online within five years of a signed interconnection agreement, in contrast to the six years allowed by MISO’s ERAS. MISO’s repeated push for an ongoing expedited interconnection process ignores important guidance from FERC, and more limited interconnection fast lane approaches from neighboring RTO’s that are much more considerate of open-access rules.
• Concerns Over COD and Timeline: In the RRI Order, FERC expressed concern that some RRI projects might not achieve COD in time to address the emergency reliability shortfall. Similarly, organizations such as the Clean Grid Alliance, the Organization of MISO States, and the MISO Developer Coalition have urged MISO to limit ERAS projects’ in-service dates to three years without an automatic three-year extension. Granting up to six years for expedited projects to achieve COD is excessive and does not meet the urgency implied by the ERAS proposal.
• Impact on the Existing Queue: FERC also evaluated the impact of the RRI process on the existing interconnection process, ensuring that RRI projects would be studied alongside projects in the Transition Cycle #2 study. This prevented RRI projects from receiving preferential treatment. In contrast, as has already been discussed, MISO’s ERAS process creates a parallel interconnection process using a different model, which could significantly disrupt the existing queue and complicate the process for other projects and delay their progress.

The Case for PGIA as a Better Solution

Rather than pushing forward with ERAS, MISO should fully implement the queue reforms that have been approved at FERC over the past two years. In 2024, MISO’s Commercial Readiness Reforms were approved by FERC and implemented for their 2023 Queue Cycle. But this cycle is set to kick off officially in May 2025, and will include interconnection requests subject to this reform and higher standards for commercial readiness, including significant financial commitments. The purpose of these stringent requirements is to shrink the number of requests, with the rationale being that not all developers will be interested in pursuing projects that have the possibility of being unviable. Additionally, to further trim the queue, MISO’s pursued their Queue Cap reform that was approved by FERC in January of this year, and will be applied to their 2025 Queue Cycle. In MISO’s reasoning, both reforms will allow them to process interconnection queue cycles much faster, by shrinking the number of requests; but MISO is not  allowing enough time to test their hypothesis and prove their case before suggesting another reform. The wise course of action is to see how these reforms address the queue backlog, and to focus on modifying the PGIA framework to suit the same needs as ERAS.

PGIA can achieve the same objective of expediting new generation without causing delays or restudies for projects in the queue. The PGIA is an existing process within MISO’s tariff that allows projects to demonstrate readiness and be constructed more quickly. These projects are studied using both the DPP and operational models, ensuring consistency and addressing reliability concerns while avoiding the disruptive effects of ERAS.

Moreover, PGIA addresses how network upgrade costs will be allocated, something that ERAS fails to do adequately. By adopting PGIA or a similar process, MISO could prioritize existing queue projects while ensuring that new generation can be rapidly deployed to meet the growing energy demand.

Conclusion

SREA strongly advocates for the PGIA framework already included in MISO’s tariff to tackle the increasing demand within their region. PGIA can enable the expedited deployment of new resources without the harmful disruptions and delays that ERAS could cause. This approach would better serve the needs of the energy market, promote fair access, and align with FERC’s principles of non-discriminatory open access.