On December 1, 2025, the Midcontinent Independent System Operator (“MISO”) announced its second cycle of projects to be evaluated under its Expedited Resource Addition Study (“ERAS”) process, which is intended to expedite the study and approval of interconnection projects needed to address resource adequacy and/or reliability needs. This second cycle is comprised of 6.1 GW of proposed new capacity, with battery storage projects as the primary project type and with the majority of this proposed new capacity (approximately two-thirds) to be sourced from natural gas projects. MISO’s next cycle is set to kick off on March 2, 2026.
MISO, which operates the transmission system in the Midwest and Southern United States, is one of the two regional transmission organizations (“RTOs”)/independent system operators (“ISOs”) which have received Federal Energy Regulatory Commission (“FERC”) authorization to implement fast-track interconnection processes aimed to accelerate the addition of critical generation sources across the country. Southwest Power Pool (“SPP”) has its own ERAS process, as well as a newly approved Priority Process for new capacity at existing generating facilities. Additionally, PJM Interconnection (“PJM”) is in the process of developing a proposal for an Expedited Interconnection Track (“EIT”) with a purpose similar to the ERAS processes of MISO and SPP.
Generator interconnection processes typically involve a detailed process of studying reliability impacts and system upgrades required for generation projects to connect to the electric grid. However, according to MISO and SPP, interconnection processes have faced delays, including due to an increased volume of projects applying to connect, bogged down further by speculative projects, as well as supply chain, permitting, or financing issues. Project withdrawals also lead to further delays for the projects that remain in the queue. The MISO and SPP ERAS processes both provide a limited and temporary expedited study process reportedly designed to accelerate the addition of needed generating resources to the respective grids. The costs of necessary transmission upgrades identified in the ERAS study processes will be allocated to ERAS interconnection customers.
MISO ERAS
MISO’s ERAS process allows resources meeting certain eligibility criteria to bypass MISO’s standard interconnection queue reviews. The approved program involves a quarterly first-come, first-served serial study process to facilitate the rapid study of interconnection requests for certain generating resources, with a resulting Expedited Generator Interconnection Agreement (“EGIA”) within a three-month timeframe. MISO requires additional eligibility requirements on top of all other requirements applicable to interconnection requests processed through the normal queue, including the need to demonstrate a clear resource adequacy connection by the ability to meet specific localized resource adequacy and reliability needs with Relevant Electric Retail Rate Authority (“RERRA”) (e.g., state utility commission) verification.
MISO ERAS is temporary, set to sunset by August 31, 2027, and allows for no more than 68 projects to be processed with a maximum of 10 projects to be studied per quarter. MISO ERAS reviewed 10 projects in Cycle 1, representing about 5.3 GW of capacity, and three of those projects have executed generator interconnection agreements with the other seven expected to be completed this month. Cycle 2 brings the total capacity under MISO ERAs review to around 11.2 GW.
FERC’s Order Accepting MISO’s revisions to its Generator Interconnection Procedures (“GIP”) and pro forma GIA within its Open Access Transmission, Energy and Operating Reserve Markets Tariff, establishing the ERAS process, can be found here.
SPP ERAS
SPP’s ERAS process was a one-time accelerated study pathway for qualified generation projects nominated by load responsible entities (“LREs”) to be placed on a fast-track for review. Projects were required to demonstrate eligibility through relevant showings, including that the project would help address an LRE’s projected resource adequacy deficit as calculated by SPP, would meet a 2030 commercial operation date, and that the needs to be met by the project could not be cost-effectively addressed by another resource available and known to the nominating LRE. Applications also required financial and project readiness requirements which exceeded the requirements in SPP’s GIP.
The SPP ERAS submission window opened on September 2, 2025 and closed on October 2, 2025, with studies having begun on October 17, 2025. SPP estimates the execution of GIAs to occur beginning March 20, 2026. According to SPP’s Active Generator Interconnect Requests table, as last updated on December 16, 2025, SPP ERAS is in the process of considering about 13 GW of capacity, with hybrid solar/storage projects as the majority project type after thermal projects (including combustion turbine, diesel, coal, and combined cycle as fuel types).
FERC’s Order Accepting SPP’s revisions to its Open Access Transmission Tariff with the addition of Attachment AW including its ERAS Procedures and revisions to its GIP, establishing the ERAS process, can be found here.
Regarding the ERAS processes, skeptics have expressed concern over their approval and implementation, arguing that such processes provide an unfair advantage over projects in standard interconnection queues, particularly to non-gas-powered projects. However, FERC rejected such arguments that the processes discriminated against certain types of resources. Supporting approval of its ERAS process, MISO emphasized that it faces urgent near-term resource adequacy and reliability concerns due to load growth, generation retirement, and delays within the interconnection process, all contributing to an imminent shortfall by 2028. Similarly, SPP emphasized that it faces a resource adequacy crisis and expects its region to have insufficient capacity to meet peak demand by 2030. In the face of interconnection queue delays, the fast-track processes aim to address near-term resource adequacy needs in the respective territories of MISO and SPP, and gas-powered resources, as well as battery projects, seem to be able to take advantage of such processes more than others.
SPP Priority Process
Relatedly, on November 28, 2025, FERC approved SPP’s proposal for the establishment of a temporary accelerated study process for incremental capacity additions at existing generating facilities, the Priority Process, which SPP intends to be complementary to its ERAS process. The Priority Process will allow owners or affiliates of owners of existing generating facilities to increase their maximum injection capability by as much as 20% without the need to go through SPP’s normal interconnection process. The Priority Process may only be used once per facility. In addition to meeting normal interconnection requirements, applicants must meet heightened financial commitment requirements and demonstrate that the expansion is shovel-ready and can be operational within five years. The Priority Process is available only to interconnection customers with effective GIAs and existing generating facilities at existing points of interconnection and only at the applicable existing voltage level.
Validated Priority Process requests will be placed ahead of all requests submitted during a normal interconnection queue cluster window which has not yet closed. The Priority Process is set to sunset on the date when SPP’s Consolidated Planning Process (“CPP”) becomes effective, which is proposed to be March 1, 2026.
FERC’s Order Accepting SPP’s revisions to its GIP in Attachment V of its Open Access Transmission Tariff, establishing the SPP Priority Process, can be found here, making SPP’s tariff revisions effective on December 1, 2025.
For more information and assistance, please contact Bhaveeta K. Mody, Sean M. Neal, and Andrea I. Sarmentero Garzón.
Article by Paige Punzalan
