MISO’s 90-Day Fast Lane for Co-Located Generation Draws Google’s Backing and the Sierra Club’s Objection

Google, Xcel Energy and several Midwest utilities have told federal regulators they back a faster interconnection path. It would serve generators built to feed one large load. The Midcontinent Independent System Operator filed the plan at the Federal Energy Regulatory Commission on Aug. 18. It creates a Zero Injection Generator Interconnection Agreement, known as a ZGIA. Qualifying projects would get a 90-day review instead of a full queue study.

The agreement covers generation sitting at the same substation and the same voltage level as the load it feeds. MISO runs the wholesale market and the electric system from Louisiana to Minnesota. The grid operator argues these resources have little or no effect on the transmission system. On that reading they do not need the study a grid-injecting plant needs.

Two limits define the category. An eligible project must hold no more nameplate capacity than the load it serves. It also must not require network upgrades beyond its own substation, apart from system protection facilities at an adjacent one.

What Is Being Filed

The filing answers part of a show-cause order FERC issued in mid-June. The commission found that grid operators appeared to lack adequate rules for interconnecting large loads. It gave them until mid-November to respond. ZGIA is the first proposal out of MISO’s recently created Large Load Working Group. That group is also building a fast-track Load Addition and Resource Study process.

AES Indiana, Ameren and Dairyland Power Cooperative filed jointly in support. They wrote that the framework would “provide regional benefits to generation and load with safeguards to avoid disruptions to the Transmission System.” Advanced Energy United said better “speed to power” for co-located load would “help reduce pressure on an already backlogged interconnection queue.” The Solar Energy Industries Association said the proposal “appropriately limits” the service to co-located configurations.

Google called the proposal a “step forward” and then asked for more. The company wants MISO to cover cases where load and generation connect through two substations rather than one. Google said that layout is common in an energy park. Wider coverage would “unlock more new generation on an expedited basis,” the company told FERC.

The Sierra Club, the Natural Resources Defense Council and allied groups asked FERC to send the plan back. They support co-located load as a goal. They argue the filing lacks safeguards and would push costs onto existing utility customers. The process risks “operationalizing ongoing cost shifts that will be difficult, if not impossible, for states to untangle,” the groups wrote. They also warned of preventable reliability shortfalls. A ZGIA holder would gain an unfair edge, they said, over projects still grinding through MISO’s Definitive Planning Phase.

The objections are not new to this docket. RTO Insider reported in May that utilities opposed an earlier version of the zero-injection plan, citing reliability and legal concerns. Utilities in the same footprint filed in support this time.

Why It Matters

This fight is about who pays for speed. A 90-day review is worth real money to a developer otherwise waiting years in an interconnection queue. The cost question turns on whether a plant that never injects still relies on the shared system. MISO’s own drafting concedes part of that point. The no-network-upgrades condition exists precisely because those upgrades would be spread across other ratepayers.

Developers reading this docket should watch the two-substation question Google raised. Say FERC accepts the single-substation boundary as filed. An energy park with a slightly different electrical layout then stays in the ordinary queue. The difference between those two outcomes is measured in years, not in equipment.

Critical Perspective

The filing grants a benefit that follows from its own premise. A ZGIA resource earns the 90-day path because it has little or no effect on the transmission system. None of these sources describes how MISO tests that claim against a specific project before it grants the faster review.

The nameplate cap is a limit on paper. An eligible generator must not exceed the capacity of the load it serves, and that holds at full output. Nothing in this record addresses the hours when the load runs well below nameplate. Those are the hours when injection becomes physically possible.

The cost-shift dispute rests on numbers nobody has put on the record. The Sierra Club says the framework operationalizes ongoing cost shifts. The supporting utilities say safeguards prevent disruptions. Neither position in these sources carries a figure.

Google’s own comment cuts against the boundary its allies praise. SEIA backs the proposal because it limits the service to co-located configurations, which it says addresses deliverability concerns. Google calls the same proposal a step forward and asks MISO to stretch it across two substations. Both readings do not hold at once.

Sources

• Utility Dive: Google, Xcel, others back MISO’s ‘zero injection’ large-load proposal
• MISO: LLWG ZGIA Proposal Framework (PAC-2024-4b) stakeholder feedback
• RTO Insider: Utilities Object to MISO Zero-injection Gen Plan for Large Loads

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