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Solar Energy Industry Associations Push Back Against MISO's Generator Replacement Filing

Strategic Insights

— 2 min read

The Solar Energy Industries Association (SEIA), along with Advanced Energy United, the American Clean Power Association (ACP), and Clean Grid Alliance, has submitted a motion for leave to answer and answer to the Midcontinent Independent System Operator's (MISO) generator replacement filing. The associations argue that MISO's proposal to allow a change in the point of interconnection (POI) for generator replacement is unjust, unreasonable, and unduly discriminatory.

The associations claim that MISO's proposal will undermine the efficiency of reusing existing infrastructure and potentially harm existing queued projects. They argue that the proposed evaluation study will not consider the cumulative impacts of nearby projects in all three DPP phases, excluding every project in the DPP 2021, 2022, 2023, and 2025 cycles - approximately 284 GW of queued capacity.

Key Takeaways:

  • MISO's proposed generator replacement filing is deemed unjust, unreasonable, and unduly discriminatory by the solar energy industry associations.
  • The associations argue that allowing a change in POI will undermine the efficiency of reusing existing infrastructure and potentially harm existing queued projects.
  • MISO's proposed evaluation study will not consider the cumulative impacts of nearby projects in all three DPP phases, excluding every project in the DPP 2021, 2022, 2023, and 2025 cycles - approximately 284 GW of queued capacity.
  • MISO's precedent of accepted process improvements does not justify their proposal to allow a change in POI.
  • The associations claim that MISO's proposal is similar to a waiver granted in Wisconsin Electric, but this example is not applicable to the current proposal.
  • MISO's attempt to analogize Wisconsin Electric misses the concern of the Clean Energy Associations and the findings of the Commission in accepting the 2019 Generator Replacement Proposal.
  • The associations urge the Federal Energy Regulatory Commission (FERC) to reject MISO's Generator Replacement Filing.

Statistics:

  • 284 GW of queued capacity excluded from the proposed evaluation study (Source: CEA Protest at 6)
  • 3 process improvements proposed by MISO previously accepted by FERC (Source: MISO Answer at 5)
  • 1 "waiver of GIP section 3.7.1(i)" granted in Wisconsin Electric (Source: Id. at 7)
  • 230 kV voltage at which the Oak Creek Replacement Units interconnect (Source: Id. at 7)
  • 2019 order in which FERC accepted the Generator Replacement Proposal (Source: CEA Protest at 4)
  • May 1, 2025: MISO submitted its Answer (Source: MISO Answer)
  • May 12, 2025: The associations submitted their motion for leave to answer and answer (Source: Certificate of Service)

Sources:

  • Motion for Leave to Answer and Answer of the Clean Energy Associations, Docket No. ER25-1802-000 (May 12, 2025)
  • MISO Answer, Docket No. ER25-1802-000 (May 1, 2025)
  • CEA Protest, Docket No. ER25-1802-000 (April 18, 2025)
  • 18 C.F.R. SSSS 385.212, 213 (2025)
  • PJM Interconnection, L.L.C., 161 FERC P 61,252 (2017)
  • Sunflower Elec. Power Corp. v. Kansas Municipal Energy Agency, 148 FERC P 61,022 (2014)
  • Midcontinent Indep. Sys. Operator, Inc., 167 FERC P 61,146 (2019)
  • Comments of the Solar Energy Industries Association, Docket No. ER21-2717 (Sept. 9, 2021)
  • Wisconsin Electric Power Co., (Source: MISO Answer at 7)

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