Dated filed: April 7, 2025
Venue: Federal Energy Regulatory Commission
Docket No. ER25-1674-000
The Electric Power Supply Association (EPSA) filed comments urging the Federal Energy Regulatory Commission (FERC) to reject the Midcontinent Independent System Operator (MISO)’s Expedited Resource Addition Study (ERAS) proposal for generator interconnection. While acknowledging and sympathetic to MISO’s urgent need to address near-term resource adequacy challenges, EPSA finds the proposal flawed and insufficient. EPSA recommends that MISO should instead develop a non-discriminatory process that resolves highlighted short-term resource concerns.
EPSA draws a key comparison to its support for PJM’s recently approved Reliability Resource Initiative (RRI), which was designed to expedite critical generation projects under clear, fair, and transparent criteria. Unlike PJM’s RRI, which includes a scoring system and guardrails to ensure projects are viable and serve reliability needs, MISO’s ERAS lacks essential elements and discriminates against certain states and market participants.
Specifically, EPSA highlights that the ERAS proposal is:
- Incomplete and Discriminatory: Illinois and Michigan—both retail choice states—are excluded, leaving them without access to the program and vulnerable to reliability risks as other states move ahead.
- Lacking Guardrails: ERAS has no cap on project submissions, no standardized criteria for evaluating resource adequacy needs, and offers an overly long project timeline that doesn’t align with MISO’s own stated urgency.
- Biased Against Independent Power Producers (IPPs): The requirement for IPPs to secure Power Purchase Agreements (PPAs) before interconnection effectively blocks their participation, unlike load-serving entities who face no such barrier.
- Out of Step With Commission Policy: The proposal includes a serial queue structure, which FERC has discouraged, and delegates too much authority to individual states—raising concerns about fairness and federal oversight.
EPSA argues that, as currently designed, ERAS would fail to deliver the timely, equitable, and effective resource additions MISO needs. The association calls on FERC to reject the filing without prejudice and direct MISO to refile a comprehensive, nondiscriminatory proposal that aligns with Commission precedent and best practices, such as those reflected in PJM’s RRI.
