Google, Xcel and Others Back MISO’s 'Zero Injection' Plan to Fast-Track Generation for Large Colocated Loads

The Midcontinent Independent System Operator (MISO) has filed a proposed Zero Injection Generator Interconnection Agreement (ZGIA) at the Federal Energy Regulatory Commission (FERC) designed to speed interconnection for generation that serves large, colocated loads. The filing, dated Aug. 18, would bundle study procedures, operational rules and market/resource adequacy provisions to create a streamlined pathway for low‑impact projects.

What the ZGIA Would Do

The ZGIA would allow expedited, 90‑day reviews for so‑called zero‑injection resources that have little or no effect on the wider transmission system. Under the proposal, an eligible generating project could not have more nameplate capacity than the load it serves. It also would prevent the generating resource from triggering network upgrades beyond the host substation, with the limited exception of system protection equipment at an adjacent substation.

Support From Industry and Clean‑Energy Groups

Major technology, utility and industry players filed in favor of MISO's approach. Supporters include Google, Xcel Energy, AES Indiana, Ameren, Dairyland Power Cooperative, Advanced Energy United (AEU) and the Solar Energy Industries Association (SEIA).

"MISO's proposed ZGIA framework would establish a uniform and tailored interconnection service that will provide regional benefits to generation and load with safeguards to avoid disruptions to the Transmission System and MISO's current interconnection process," utilities said in a joint FERC filing.

"Improving the 'speed to power' for colocated loads that will have little to no impact on the broader transmission system will help reduce pressure on an already backlogged interconnection queue," AEU said.

"The proposal appropriately limits Zero Injection Generation Interconnection service to co‑located configurations, addressing deliverability concerns," SEIA added.

Google called the ZGIA a "step forward" while urging MISO to expand eligibility to configurations where load and generation are connected via two substations — a common arrangement in planned "energy parks" — so more generation could be expedited.

Concerns From Environmental and Community Groups

A coalition of environmental and community organizations, including the Sierra Club and the Natural Resources Defense Council (NRDC), urged FERC to require MISO to revise the proposal. Opponents say the concept could institutionalize cost shifts onto existing utility customers, grant an ongoing competitive advantage to projects receiving ZGIA service, and potentially create reliability risks if safeguards are inadequate.

"This process could have the opposite of MISO's intended effect by operationalizing ongoing cost shifts that will be difficult, if not impossible, for states to untangle, triggering otherwise preventable reliability shortfalls, and allowing generators with ZGIA service … to perpetually gain an unfair advantage over projects in [the Definitive Planning Phase]," the Sierra Club and allied groups told FERC.

Context and Next Steps

MISO framed the ZGIA in part as a response to FERC's mid‑June "show cause" orders, which found that independent system operators and regional transmission organizations may lack adequate rules for interconnecting very large loads. FERC ordered grid operators to respond by mid‑November. MISO also notes the ZGIA emerged from its newly formed Large Load Working Group and is one element of a broader effort to accommodate planned large load additions — primarily data centers and cryptocurrency mining facilities.

The working group is simultaneously developing a fast‑track Load Addition and Resource Study to evaluate transmission needs for new large loads and their associated generation. FERC review and stakeholder feedback will shape whether and how the ZGIA is adopted across MISO's footprint, which stretches roughly from Louisiana to Minnesota.