Public utilities are facing mounting challenges to meet reliability standards, including an aging generation fleet, accelerating retirements, surging load growth, and a bottleneck of interconnection processes.

In response, the Midcontinent Independent System Operator, Inc. (MISO) developed the Expedited Resource Addition Study (ERAS) in an attempt to expedite interconnection study processes for certain projects needed for reliability.

Projects admitted to the ERAS process must demonstrate that they can achieve commercial operation within an accelerated time frame – typically three to six years – compared to traditional queue timelines. MISO limits the number of projects studied through the ERAS process per quarter and overall, with the current framework capped at 68 projects through August 2027. Federal Energy Regulatory Commission (FERC) rejected MISO’s first iteration of ERAS, but approved MISO’s second version, which included the commercial operation requirement and 68 project cap.^[1]

Now this version is being challenged by public interest groups claiming that projects selected for the ERAS have an unfair advantage.^[2]

In the first month ERAS was available, MISO received 47 applications across 12 states, totaling 26,500 megawatts of proposed capacity.^[3] In September, MISO selected the first 10 projects to be evaluated under the ERAS process – five natural gas, three solar, one wind, and one battery. Of these, three projects have ties to Wisconsin utilities: Wisconsin Electric Power Company’s Red Oak Ridge Energy Center in Kenosha and two Alliant Energy projects to be sited in Iowa.^[4]

More About ERAS

At its core, ERAS is meant to fast-track resources that address short-term reliability or resource adequacy needs – pushing priority projects through MISO’s interconnection queue.^[5] Despite being proposed by MISO and approved by FERC, the ERAS process relies on state regulatory entities (e.g., commissions, municipalities, co-op boards) to act as gatekeepers.

ERAS applicants are subject to eligibility requirements including verification by the Relevant Electric Retail Regulatory Authority (RERRA) in each jurisdiction.^[6] Specifically, ERAS applicants must demonstrate that the requested interconnection is needed to meet an identified resource adequacy or reliability need through written verification from the RERRA where the load to be served by the generating facility is located.^[7]

In other words, any project tied to Wisconsin load-seeking ERAS treatment hinges on verification from a state regulator.

The Role of The Public Service Commission of Wisconsin

As FERC explained in its order approving ERAS, the role of RERRAs “recognizes the states’ jurisdictional authority over the resource planning and generation mix within their boundaries” and tasks RERRAS with “assessing and verifying non-speculative interconnection requests that address an identified resource adequacy deficiency.”^[8]

Accordingly, the Public Service Commission of Wisconsin serves as the state-level regulator regulatory responsible for certifying that a proposed project addresses a legitimate resource adequacy or reliability need for Wisconsin’s investor-owned utilities (IOU) customers, while reserving its right to approve or deny projects in subsequent proceedings.

In practice, the commission’s role is relatively straightforward. The commission evaluates applications from investor-owned utilities (Load Serving Entities, or LSEs in MISO’s parlance) and developers seeking ERAS certification to determine whether the project addresses a resource adequacy deficiency. The commission can support this determination in several ways including, but not limited to: (1) a state energy forecast; (2) commencement of a state proceeding; (3) procurement plans; or, (4) response to a request for proposals.^[9]

In response to MISO’s ERAS filing, Wisconsin utilities hoping to take advantage of the ERAS process filed requests for the commission, as a RERRA, to verify their projects meet the requirements to participate in ERAS, detailing how their project meets MISO’s ERAS criteria and is needed for reliability.

Each applicant received a verification letter. The commission’s verification underscores a mutual understanding of the importance and need for reliability and resource adequacy between the Commission and Wisconsin utilities. In its request, Wisconsin Electric Power Company stated that while projects are being advanced through MISO’s normal queue, “ERAS is needed to provide more certainty on the timing and interconnection costs for these projects, which are needed to provide reliable energy to eastern Wisconsin, comprising MISO Local Resource Zone 2 (LRZ 2), and Wisconsin Electric’s customers.”^[10]

Importantly, verification by the commission – and even inclusion in the ERAS queue – does not guarantee state approval, certification, or authorization of prudence. Projects still must undergo full state regulatory review. In fact, the ERAS sample verification form explicitly reserves such determinations for the RERRA and states that “any retail RERRA process required under retail law and regulations is not waived.”^[11]

Moreover, RERRA verification “shall not be used as evidence by any party to support or justify a request for siting, a Certificate for Public Convenience and Necessity, cost recovery or any other required RERRA retail jurisdictional determination.”^[12]

Still, the ERAS process allows Wisconsin utilities a chance to bring resources online much more quickly than MISO’s normal queue. And, given that every utility that sought a verification received one, it appears the commission intends to take an active role in strengthening resource adequacy throughout MISO LRZ 2. Working together, Wisconsin utilities and the Commission can put forth projects that serve Wisconsin.

This article was originally published on the State Bar of Wisconsin’s Public Utilities Blog. Visit the State Bar sections or the Public Utilities Section webpages to learn more about the benefits of section membership.

Endnotes

[1] Midcontinent Independent System Operator (MISO), “Expedited Resource Addition Study attracts large, diverse applicant pool,” Aug. 26, 2025. ↩

[2] Ethan Howland, “Groups sue FERC over MISO, SPP fast-track interconnection programs,” Utility Dive, Nov. 19, 2025. ↩

[3] MISO, “Expedited Resource Addition Study.” ↩

[4] MISO, ERAS Cycle 1. ↩

[5] MISO, “FERC approves MISO’s Expedited Resource Addition Study,” July 22, 2025. ↩

[6] MISO, “Generator Interconnection and Retirement”, and “Expedited Resource Addition Study Informational Guide.” ↩

[7] 192 FERC ¶ 61,064 at 7-8. ↩

[8] 192 FERC ¶ 61,064 at 51. ↩

[9] Id. ↩

[10] See Docket No. 05-EI-2025 (PSC REF# 557480). ↩

[11] Sample RERRA Verification Form for New Load Additions, cdnmisoenergy.org. ↩

[12] Id. ↩