By Simon Mahan

Picture this: It’s late on a school night and a kid asks their parents for a last-minute trip to the store. There’s a project due the next day, and without an emergency run to the market, disaster looms. What follows is familiar: some back-and-forth about how this happened, a short lecture on procrastination and finally a reluctant agreement to make an exception.

Lately, it’s hard not to feel like state and federal energy regulators are playing this game, facing utilities that waited too long and now insist everything is urgent.

A clear example is FERC’s recent approval of ERAS processes in both MISO and SPP (the Expedited Resource Addition Study and Expedited Resource Adequacy Study, respectively). These new processes allow certain power plants to effectively jump the interconnection line, skipping ahead of hundreds of other projects already waiting their turn. (See FERC Dismisses Rehearing Ask for SPP’s ERAS Process.)

When ERAS was proposed through stakeholder processes, the underlying rationale was widely understood: Utilities had not planned far enough ahead, particularly for new natural gas plants, and now wanted a faster path forward.

When ERAS was first proposed in 2024, MISO and SPP together had more than 300 GW of generation projects in their queues. The vast majority were wind, solar and battery storage by competitive developers, with relatively little natural gas by the utilities. In fact, MISO’s queue grew so large that the grid operator was forced to cap new entries altogether. Yet at the same time, utilities and planners began warning of an imminent reliability crisis.

Integrated resource planning (IRP) processes exist specifically to avoid this outcome. Many utilities conduct IRPs every two to three years to forecast demand and identify future resource needs. Those plans routinely show large additions of solar, wind and battery storage, often alongside some natural gas.

The labyrinth of interconnection studies can take three to four years. Renewable projects often can be built in one to two years once contracted. Natural gas plants frequently take much longer. Utilities know this all too well, yet many failed to submit gas projects early enough to align with their own forecasts.

Now, with electricity demand rising from data centers, industrial growth and electrification, utilities are asking regulators to let them cut in line.

MISO already has received more than 60 ERAS project requests, with nearly three-quarters of the proposed megawatts coming from natural gas. These projects often skip competitive solicitations, too. They are self-identified by utilities as “needed” and advanced on an expedited basis. Entergy alone has submitted more than 8,500 MW of gas generation through ERAS. (See MISO Accepts 6 GW of Mostly Gas Gen in 2nd Queue Fast Lane Class.)

Traditionally, state commissions approve new power plants only after reviewing a full certificate application, including cost estimates, alternatives analysis and transmission impacts. ERAS turns that structure upside down. Under these expedited processes, regulators are asked to effectively bless projects before a formal application is even filed. Once a project receives accelerated interconnection treatment, it becomes far harder to later reject it or disallow its costs.

After all, once you’re already standing in the checkout line with emergency school supplies in hand, it’s difficult for a parent to say, “You’re on your own, kid.”

In this case, tens of billions of dollars are at stake.

To be clear, ERAS technically is resource neutral. Wind, solar, battery storage, gas and even nuclear projects are eligible. A few have been submitted. But they pale in comparison to the surge of utility-owned, non-competitively selected natural gas plants now racing ahead of the queue.

Fast-tracking these projects risks rewarding exactly the behavior regulators should be discouraging.

So, what can regulators do instead? Here are three practical solutions:

• • IRPs must be more than a paper exercise. They provide value only if regulators are actively engaged, assumptions are realistic, load forecasts are transparent and modeling reflects real-world timelines.
  • Competitive procurement is essential. Requiring utilities to issue requests for proposals ensures that regulators and consumers can see what the market is offering. Competition disciplines costs. Sole-source generation does not.
  • Diversification and transmission expansion must remain central to reliability planning. A grid built around a narrow set of resources is inherently more fragile, not less. Maybe there’s merit in a connect and manage interconnection option, like what ERCOT has.

ERAS may be described as a temporary emergency valve, but history suggests that “temporary” exceptions have a way of becoming permanent precedents.

If regulators aren’t careful, today’s emergency trip won’t be the last time.

And that’s a lesson ratepayers shouldn’t be forced to pay for.

Simon Mahan is executive director of the Southern Renewable Energy Association.