MISO's zero-injection plan backed by Google, Xcel for large

Google, Xcel Energy, and several utilities and clean energy trade groups have filed support with the Federal Energy Regulatory Commission for a Midcontinent Independent System Operator proposal. The plan would create a new framework for interconnecting power generation that serves large loads at the same substation and voltage level.

MISO's Zero Injection Generator Interconnection Agreement proposal, filed on August 18, promises 90-day reviews for such projects. The grid operator says these "zero-injection" resources would have little to no effect on the broader transmission system. The proposal includes related study processes, operational requirements, and market provisions.

Stakeholder support and opposition

A coalition including AES Indiana, Ameren, and Dairyland Power Cooperative supports the plan. In a joint FERC filing, they said the framework would establish a uniform and tailored interconnection service with regional benefits. They argued it contains safeguards to avoid disruptions to the transmission system and MISO's existing interconnection queue.

Advanced Energy United and the Solar Energy Industries Association also back the proposal. AEU stated it would improve the "speed to power" for colocated loads, reducing pressure on a backlogged interconnection queue. SEIA said the plan appropriately limits the service to co-located configurations, addressing deliverability concerns.

However, environmental advocates oppose the approach. The Sierra Club, Natural Resources Defense Council, and other groups urged FERC to order MISO to rework its proposal. They support the goal of help colocated load but argue the plan is flawed. Their primary concern is that it could perpetuate cost shifts onto existing utility customers.

Proposal details and requirements

MISO's proposal is a partial response to FERC's mid-June "show cause" orders. Those orders found that regional transmission organizations appeared to have inadequate rules for interconnecting large loads. FERC has ordered grid operators to respond by mid-November. MISO says it had been developing the zero-injection plan with stakeholders before FERC's order.

The proposal sets specific eligibility requirements. An eligible generating project can have no more nameplate capacity than the load it would serve. Also, the generating resource cannot require network upgrades beyond the substation. An exception is made for system protection facilities at an adjacent substation.

Context within MISO's large load efforts

This zero-injection proposal is one part of MISO's broader effort to handle a surge in planned large load additions. The grid operator cites data centers and cryptocurrency miners as primary drivers. It is the first proposal to emerge from MISO's recently created Large Load Working Group.

That working group is also developing a separate fast-track process called the Load Addition and Resource Study. This process would assess the transmission infrastructure needed for new large loads and the generation to serve them.

Requests for expansion and warnings

Google told FERC the proposal is a "step forward." The company urged MISO to expand the concept to include configurations where load and generation are connected by two substations. Google said this configuration would be common in an "energy park" and unlocking more configurations could expedite more new generation.

The coalition of environmental groups issued a strong warning in their filing. They argued the process could have the opposite of MISO's intended effect. It might "operationalize ongoing cost shifts" difficult for states to untangle and trigger preventable reliability shortfalls. They also warned it could allow zero-injection projects to gain an unfair perpetual advantage over projects in MISO's standard Definitive Planning Phase study process.