MISO's ERAS Adds Chaos to an Already Complex Process
ST. PAUL, MINN. (March 19, 2025) – Last summer, MISO and the Organization of MISO States (OMS) released a report indicating a capacity shortfall ranging from a 2.7 Gigawatt (GW) shortfall to a 1.1 GW surplus starting in the summer of 2025, prompting a need for faster resource additions. In response, MISO introduced the Expedited Resource Addition Study (ERAS) to address perceived resource adequacy concerns, interconnection queue delays, and growing large load demands. MISO filed the ERAS proposal at FERC on March 17, 2025.
Clean Grid Alliance, a leader in renewable energy policy and grid planning in the MISO region, warns that ERAS overcomplicates an already complex system:
"ERAS has been introduced primarily to address the demands of a few states within the MISO footprint that are seeking to prioritize resources not currently in the existing interconnection queue, despite ample availability of generating resources that have completed the queue and are ready for commercial operations," said CGA Vice President, Transmission and Markets, David Sapper.
ERAS is being pursued as a response to delays and inefficiencies in MISO's queue management process. Instead, ERAS adds a new layer to an already complex system, overlapping with processes like the MISO Transmission Expansion Plan (MTEP), definitive planning phase, interregional transmission planning, and expedited project reviews. This additional complexity, compounded by the need to coordinate affected system studies with PJM and SPP and allocate transmission capacity to new generation, risks creating significant chaos and operational challenges.
Even with a 21% completion rate, the queue has 18GW of storage and hybrid capacity, and planned transmission expansion could increase that to 29GW, far exceeding the projected shortfall. Furthermore, ERAS is moving forward before the full effect of recent queue reforms is seen, which has already reduced the queue by approximately 33%.
CGA advocates for solutions that maintain open access, avoid delays to existing processes, and leverages faster-constructing resources that are already in the queue.
"There is no need to upset the apple cart. Rather, we encourage MISO to embrace the simplest solution, which is to stick with their existing Tariff because it already allows for expediting serious projects," said CGA Executive Director Beth Soholt. "The existing Provisional Generator Integration Agreement (PGIA) maintains competition, efficiency, and reliability and can quickly interconnect the most certain, non-speculative projects, including gas. It's technology-neutral and inherently prioritizes the need. Existing processes can bring capacity online quickly, while maintaining open access that keep costs down. This fast and fair solution to meeting large load demands is good for everyone."
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Clean Grid Alliance (CGA) is a 501(c)(3) nonprofit organization based in St. Paul, Minn., whose mission is to advance renewable energy in the Midwest. CGA has been an active stakeholder in the MISO process at the state and regional levels and a leading organization working on transforming state energy policy. CGA's membership includes industry representatives working in wind, solar, and storage as well as environmental nonprofit organizations, public interest groups, clean energy advocates, farm groups, and businesses providing goods and services to the clean energy industry who come together to reduce carbon and deliver a clean energy future. Learn more at cleangridalliance.org.
