ER26-3552-000 · 2026-09-08 · Community Collaboration on Climate ChangeMichigan Environmental Justice CoalitionMidwest Tribal Energy Resources Association ,Sierra Club ,Natural Resources Defense Council ,Clean Grid Alliance ,

Protest of Community Collaboration on Climate Change, et al. re the Midcontinent Independent System Operator, Inc.’s filing proposing revisions to establish the Zero Injection Generator Interconnection Agreement

Read topic-matched comments in ER26-3552

Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment

Responses and related views

No section-specific public response is linked for this document.

Source sections

Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.

Opening text

opening text

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Midcontinent Independent System Operator, Inc.
Read this passage

I. INTRODUCTION

printed heading

I.
Read this passage

INTRODUCTION

printed heading · Topic match: Cost allocation

Without proper tariff provisions, this process could have the opposite of MISO’s intended effect by instead operationalizing ongoing cost shifts that will be difficult, if not impossible, for states to untangle, triggering otherwise preventable reliability shortalls, and allowing generators with…
Read this passage Filed comments: Cost allocation

TABLE OF CONTENTS

printed heading

TABLE OF CONTENTS I.
Read this passage

D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will Be Paid

printed heading

D.
Read this passage

II. ARGUMENT

printed heading

II.
Read this passage

A. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators.

printed heading · Topic match: Connecting load and generation

A third infirmity in ensuring that zero means zero is how MISO proposes to set the “Transient Tolerance Window,” which is “the period of time after a reduction or loss of load by the ZG Associated Load by the end of which window the [ZG] Generating Facility must have” ceased injections to the…
Read this passage Filed comments: Connecting load and generation

B. The Proposal Lacks Required Transparency.

printed heading · Topic match: Connecting load and generation

The Commission found in the Show Cause Order that MISO must provide “cost transparency measures […] to provide stakeholders with sufficient information and visibility regarding the Network Upgrades, and their associated costs, needed to provide transmission service to Eligible Customers on behalf…
Read this passage Filed comments: Connecting load and generation

C. The ZGIA Program’s Scope Should Have a Defined Limitation.

printed heading · Topic match: Connecting load and generation

While acknowledging stakeholders’ “[r]equests to ensure ZGIA is a transitional construct and does not replace the standard GIA process,” MISO wholly ignored the point in its response to related comments: 63 To achieve the narrow tailoring required by the Commission’s open access precedents, a…
Read this passage Filed comments: Connecting load and generation

D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will

printed heading · Topic match: Connecting load and generation

X, Generator Interconnection Procedures, Section 3.2.5.1(2); see also id. at 3.2.5.2.1 (“For ZG Interconnection Service to be granted, these analyses must determine that no Network Upgrades are needed to maintain system reliability other than Network Upgrades at the same substation as the Point of…
Read this passage Filed comments: Connecting load and generation

E. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources.

printed heading · Topic match: Connecting load and generation

Additionally, a ZG Generating Facility shall be metered “separate from any metering used for the ZG Associated Load,”93 but the Proposal should clarify whether a constituent storage unit within a ZGIA Hybrid Resource must be separately metered from the constituent generator and whether its charging…
Read this passage Filed comments: Connecting load and generation

F. Drafting Errors

printed heading · Topic match: Connecting load and generation

X, App’x 19 § 9.7.4.7 (requiring a ZG Generating Facility to reduce injections to match the ZG Associated Load’s Demand). 28 To support a ZG Generating Facility’s requirement to avoid grid injections and produce only the power its ZG Associated Load demands, MISO proposes to require that, after a…
Read this passage Filed comments: Connecting load and generation

III. CONCLUSION

printed heading

III.
Read this passage

CONCLUSION

printed heading · Topic match: Cost allocation

CONCLUSION To effectuate MISO’s zero injection concept without raising the risk of adverse reliability events and cost shifts, Community Organizations and Clean Energy Advocates respectfully ask the Commission to use its authority to help MISO course correct.
Read this passage Filed comments: Cost allocation

CERTIFICATE OF SERVICE

printed heading

Wacker Dr., 14th Floor Chicago, IL 60606 sdoshi@earthjustice.org
Read this passage