Stakeholders have several lingering questions as MISO continues to draw up a “zero-injection” avenue for large loads with planned on-site generation.

Marc Keyser, with MISO’s external affairs team, said the RTO is looking to define and standardize the process, though it already maintains a few signed generator interconnection agreements with no electricity injection specified.

The RTO said in late 2025 that it would create interconnection agreements where generation dedicated to large load facilities is barred from injecting into its system. Those generation projects would be able to bypass the generator interconnection queue and interconnect in a matter of months, not years. (See MISO Floats ‘Zero Injection’ Agreements to Bring Co-located Gen Online.)

“We would like to make a filing soon. The first quarter is a great goal to have,” Keyser said at a Planning Advisory Committee meeting Jan. 21.

MISO Director of Expansion Planning Jeanna Furnish added that the RTO would also continue to vet the proposal through its stakeholder process over spring.

“We understand that there are a lot of questions we have to work through,” Furnish said.

Keyser said a zero-injection agreement would restrict local generation to providing for its co-located load. He said the generation would be prohibited from running if the load isn’t operating to accept it.

“It’s potentially reducing network upgrades to interconnect,” Keyser said of the arrangement that would get new generation on — and simultaneously keep it off — the system.

MISO’s plan specifies that load can extract generation from the larger network if the generation isn’t on, but its designated generation can never inject into the system from its point of interconnection.

But stakeholders still had questions about how MISO would prevent the netting of behind-the-meter generation with load, a practice FERC prohibits.

Keyser said MISO would require separate metering and telemetry data of the load and generation. “This is not an opportunity to net load and generation behind the meter,” he said.

MISO Director of Resource Utilization Andy Witmeier said the process won’t allow netting because the RTO will have full visibility into both the generation and load from a planning and operations perspective.

For studies, MISO said a zero-injection resource would be modeled the same as any other resource. It plans to study NERC contingencies and conduct reliability analysis, accounting for steady-state, voltage stability and dynamic stability.

“Broadly, our studies are designed to capture contingencies,” Keyser said. However, MISO said reliability studies will always include scenarios where zero-injection resources are offline.

MISO said network upgrades wouldn’t be needed for zero-injection resources even when the most severe contingency occurs and generation trips offline. Keyser said the studies would be designed to “quickly reflect” that load has sought its own generation.

Staff said MISO has struck zero-injection agreements for three unnamed customers so far, including chemical processing plants in MISO South.

“I wouldn’t say this is readily available,” Witmeier said of the arrangements. He said the process isn’t documented in MISO’s tariff or Business Practices Manuals.

Mississippi Public Service Commission consultant Bill Booth asked if the prohibition on generation injections would be voluntary or if MISO would require physical elements to prevent injection. “How can you rely on voluntary participation if you’re not scanning the system for injections?” he asked.

Keyser said that of MISO’s existing zero-injection agreements, some have equipment to bar injections while others have committed to not injecting.

Booth said barring an electric interlock, the RTO should deliberate on the difference between a voluntary promise not to inject and a guarantee to not inject.

The Sustainable FERC Project’s Natalie McIntire asks what would happen if a large load supported by a dedicated generator tripped offline suddenly and the affiliated generator could not turn off output “really quickly.”

“We know that we owe it to stakeholders to be more specific about what it means to be zero,” Keyser said. “It’s an important question. We do plan on addressing it.”

He said MISO is holding conversations about operational reliability and is discussing elements such as how long it’s appropriate for a 150-MW generator, for example, to churn out 151 MW.

“I just don’t want MISO to gloss over all of these really technical questions as you’re trying to develop this really quickly,” McIntire said.

Arkansas Electric Cooperative Corp.’s David McRae said interrupting inertial generators can harm the generation. He asked how the RTO envisions dedicated generation ramping down over multiple cycles, if needed.

Keyser acknowledged that MISO has more work to do on those details as well.

At a Dec. 18 Organization of MISO States meeting, OMS counsel Brad Pope said the RTO’s zero-injection plan could harbor some “real reliability concerns” if it isn’t carefully thought out. OMS has scheduled a Jan. 23 meeting to discuss the proposal with RTO officials.

WEC Energy Group’s Chris Plante said the no-netting rule should apply universally across all markets, including the capacity market. He asked how MISO would accredit generation dedicated solely to a single customer.

“I would encourage MISO not to design this behind closed doors and include stakeholders on the design,” Plante said.

Booth said the RTO must figure out where the co-located load fits into a load-serving entity’s obligation to serve. “We can’t ignore it.”

Anthony Alvarez, of the Iowa Office of Consumer Advocate, asked if the co-located load could become demand response or load-modifying resources.

Keyser said MISO will have to explore that more, but the large loads would be firm, full-rights load and other loads are entitled to become LMRs.

However, Keyser also said MISO would have to work out “what does demand response and market participation look like.”

Wolverine Power Cooperative’s Sawyer McClure said he didn’t see why would-be zero-injection generation wouldn’t just pursue retail behind-the-meter generation status to serve the large loads.

But Keyser said behind-the-meter status is meant for only generation connected at the distribution level.

“If the required connection is at the transmission level, that wouldn’t work,” Keyser said.

MISO said it would provide more details on its proposal at the PAC’s meeting Feb. 25.

“This is not the extent of large load integration or ‘helps’ to incorporate large load,” Keyser said of MISO’s proposal.

Additionally, MISO will hold a workshop on how it plans to handle future large loads Jan. 30.