EL26-70-000 · 2026-08-12 · Sparkfund

Comments of Sparkfund on Midcontinent Independent System Operator Inc.’s Informational Report filed on 07/20/2026

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
Midcontinent Independent System Operator, 
Inc. 
 
 
Docket No. EL26-70-000 
  
COMMENTS OF SPARKFUND ON MISO’S INFORMATIONAL REPORT 
​
Spark Community Investment Fund (d/b/a Sparkfund) appreciates the informational 
report filed by the Midcontinent Independent System Operator (MISO) describing the efforts 
MISO is undertaking to integrate large loads. Sparkfund submits these comments to provide 
further information on how MISO’s existing and pending DER models are enabling DERs to be 
a means to integrate large loads, and how this model can be further replicated throughout MISO.  
Distributed resources are increasingly providing capacity to integrate large loads, through 
utility programs and MISO’s existing participation models. This distributed capacity potential is 
documented through Rewiring America’s Homegrown Energy blueprint;1 the recent 16 GW 
nationwide VPP announced by Tesla, Sunrun, and Renew Home;2 and Voltus’s Bring Your Own 
Capacity model.3 While MISO diligently works towards full implementation of FERC Order 
2222 in 2029/2030, aggregators and utilities within MISO are able to deploy distributed 
resources as capacity today using the existing participation models. 
 ​
One example illustrates how a MISO utility is already leveraging the distribution system 
to deploy power plant scale capacity to integrate large loads. The Minnesota Public Utilities 
3 Voltus Launches “Bring Your Own Capacity” Product to Support Data Center Growth and Grid Resiliency (Sept. 
30, 2025), available at https://www.voltus.co/press/bring-your-own-capacity-data-centers.  
2  See vppcapacity.com, documenting hundreds of megawatts available in MISO states through existing batteries and 
HVAC loads. 
1 Rewiring America, Homegrown Energy (May 2026), available at 
https://www.rewiringamerica.org/research/homegrown-energy-report-policy-affordable-household-upgrades. 
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Commission recently approved Xcel Energy’s Capacity*Connect program, to deploy up to 200 
MW of front-of-the-meter, distribution-sited 1-3 MW battery energy storage systems (BESS) by 
the end of 2028,4 with the potential for 500 MW by 2031.5 The Capacity*Connect program is a 
form of distributed capacity procurement (DCP), in which the BESS would be owned and 
operated by Xcel, and intentionally sited where the resources could best benefit the distribution 
grid.6 The BESS will use MISO’s DRR Type 1 Participation model, which allows the resources 
to participate in MISO’s energy and ancillary service markets.7 DRRs can act as capacity 
resources that count towards an LSE’s Planning Reserve Margin Requirement (PRMR), just like 
a generator.8 
Xcel’s Capacity*Connect program illustrates several points about distributed capacity 
supporting large load integration in MISO. First, MISO’s existing participation models provide 
several options for utilities and third-parties within MISO to deploy distributed energy resources 
that, in aggregate, reach power plant scale.9 Second, Capacity*Connect provides a mechanism to 
deploy new capacity to serve data centers while also delivering localized, distribution-level 
benefits: Google’s new Pine Island, MN data center facility has entered an Electric Service 
Agreement that includes $50 million towards Xcel’s Capacity*Connect battery portfolio in 
exchange for matched capacity credits.  Google’s purchase of capacity credits from 
Capacity*Connect offsets a portion of Xcel’s total cost.10  
10 Id. at 10. 
9 Id. at 8 discussing multiple participation pathways in MISO’s market.   
8 Id. at n. 14. 
7 Capacity*Connect Briefing Papers at 8. 
6 Capacity*Connect Order at 4-5. 
5 Staff Briefing Papers at 7, In the Matter of the Petition of Northern States Power Company, d/b/a Xcel Energy, for 
Approval of Capacity*Connect, a Distributed Capacity Procurement Program, Docket No. E-002/M-25-378 (Mar. 
18, 2026) (Capacity*Connect Briefing Papers). 
4 Order at 5, In the Matter of the Petition of Northern States Power Company, d/b/a Xcel Energy, for Approval of 
Capacity*Connect, a Distributed Capacity Procurement Program, Docket No. E-002/M-25-378 (May 13, 2026) 
(“Capacity*Connect Order”). 
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Third, when well-designed programs align with functioning markets the combination can 
be net negative on residential electricity bills.  Xcel’s compliance filing calculates that 
Capacity*Connect will deliver average residential bill savings of approximately $0.13 per month 
over the twenty-year analysis period, with Google’s $50 million contribution further increasing 
those savings by another $0.04 per month, to approximately $0.17 per month.11  
Capacity*Connect therefore demonstrates that distributed capacity can be deployed to integrate 
large loads while simultaneously lowering residential bills.   
Fourth, distributed capacity could meaningfully contribute to MISO’s resource adequacy: 
multiple utilities deploying 200-500 MW of utility-owned and operated distributed capacity 
could amount to gigawatts across the MISO footprint. Other utilities within the MISO footprint 
have taken notice of Capacity*Connect and are actively exploring and establishing distributed 
capacity programs of their own. This exploration is taking shape across multiple regulatory and 
commercial pathways, including existing integrated resource planning (IRP) processes, both 
existing and newly-proposed large-load tariffs designed to serve data center customers, and 
emerging bring-you-own-capacity (BYOC) structures. These efforts are particularly notable 
given the potential for distributed batteries to value-stack across both wholesale market 
opportunities and distribution-level benefits, an opportunity that Xcel has detailed for the 
Minnesota Public Utilities Commission during its review of the Capacity*Connect.12  
Finally, distributed capacity is a way to “right size” the capacity to meet load growth 
needs. For example, 127 MW of distributed capacity could be deployed as a bridge solution 
while traditional thermal generation is being built.  
12 Capacity*Connect Order at 4-6.  
11 See Compliance Filing – Bill Impact Analysis, at 2-5, In the Matter of the Petition of Northern States Power 
Company, d/b/a Xcel Energy, for Approval of Capacity*Connect, a Distributed Capacity Procurement Program, 
Docket No. E-002/M-25-378 (Apr. 24, 2026). 
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Sparkfund provides the above information to spotlight what distributed capacity is 
capable of doing in MISO today, while noting that this potential only grows as MISO and other 
markets implement FERC Order No. 2222.  
 
 
Dated: August 12, 2026 
 
 
Sincerely, 
 
 
 
 
Allison Bates Wannop 
Vice President, Regulatory Affairs and Wholesale Markets 
Sparkfund 
allison.wannop@sparkfund.com 
617-548-6221 
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