{"document":{"slug":"filing-20260908-5341","title":"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","issued":"2026-09-08","accession":"20260908-5341","docket":"ER26-3552-000","group":"MISO filings","filer":"Community Collaboration on Climate ChangeMichigan Environmental Justice CoalitionMidwest Tribal Energy Resources Association ,Sierra Club ,Natural Resources Defense Council ,Clean Grid Alliance ,","kind":"filing","file":"sources/originals/20260908-5341_01.pdf","url":"https://sustainableferc.org/wp-content/uploads/2026/09/ER26-3552-Community-Orgs-and-Clean-Energy-Advocates-Protest.pdf","sha256":"460e52ad30528d82dc2268ae49cba9e9cb6a7e0a2b11e5e6a463d77a968a2d12","pages":32,"tokens":9334,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":213,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nMidcontinent Independent System Operator, Inc. \nDocket No. ER26-3552-000 \n \n \n \nPROTEST OF COMMUNITY ORGANIZATIONS AND  \nCLEAN ENERGY ADVOCATES \n \nI. \nINTRODUCTION \nCommunity Organizations1 and Clean Energy Advocates2 and their respective members reside \nthroughout the Midcontinent Independent System Operator Inc.’s (“MISO”) footprint.  They rely \non MISO to provide affordable and reliable wholesale service to power many aspects of their lives, \nincluding their residences, businesses, hospitals, places of worship, and schools.  Their members \nalso rely on MISO’s adherence to non-discriminatory practices that enable a diverse set of energy \ngeneration technologies, namely distributed energy resources, to provide low-cost energy options \nthat will help lower their energy bills without increasing pollution in their communities.  \nAdditionally, one of Clean Energy Advocates is an organization including energy project \ndevelopers that regularly use MISO’s interconnection services. \n \n1 Community Organizations are Community Collaboration on Climate Change and Michigan Environmental Justice \nCoalition, which are nonprofit organizations chartered under the laws of Michigan; and Midwest Tribal Energy \nResources Association, a nonstock corporation chartered under the laws of Wisconsin. \n2 Clean Energy Advocates consist of Sierra Club and Natural Resources Defense Council, which are nonprofit \nenvironmental organizations with members throughout MISO territory; and Clean Grid Alliance, a nonprofit \ncorporation chartered under the laws of Minnesota."},{"page":2,"startToken":213,"endToken":490,"text":"2 \nOn June 18, 2026, the Commission issued an order to show cause (“OSC” or “Show Cause \nOrder”) to MISO and its transmission owners (“TOs”) directing them to either provide more \noptions to fast track the grid interconnection of large load customers, which at the moment are \nprimarily data centers, or explain why MISO’s tariff is sufficient.  MISO submitted its Zero \nInjection Generator Interconnection Agreement (“ZGIA”) proposal (the “Proposal”) to respond to \nthe co-location requirements in the Commission’s OSC.3   Our organizations do not oppose the \nintended design of MISO’s ZGIA Proposal—a co-location arrangement that results in no injections \nor withdrawals of electrons to MISO’s transmission system and, therefore, does not require \nnetwork upgrades nor cause negative impacts to the Definitive Planning Phase (“DPP”) process.  \nRather, we oppose the lack of processes and tariff provisions to make those design elements a \nreality.  \nWithout proper tariff provisions, this process could have the opposite of MISO’s intended \neffect by instead operationalizing ongoing cost shifts that will be difficult, if not impossible, for \nstates to untangle, triggering otherwise preventable reliability shortalls, and allowing generators \nwith ZGIA service (“ZG Resource”) to perpetually gain an unfair advantage over projects in DPP, \nfrustrating the implementation of Order 2023’s queue reforms to the detriment of market \nparticipants and consumers, like our members.  As discussed below, we urge the Commission to \ndirect MISO to address these tariff and procedural defects through either a deficiency letter or \ndirect further compliance via the show cause proceeding.  \n \n \n \n3 Midcontinent Indep. Sys. Op., Inc.’s Transmittal Letter for Zero Injection Generator Interconnection Agreement \nFiling, Docket No. ER26-3552-000 (Aug. 18, 2026), Accession No. 20260818-5152 (“MISO Transmittal” or \n“Transmittal Letter”)."},{"page":3,"startToken":490,"endToken":774,"text":"3 \nTABLE OF CONTENTS \nI. \nINTRODUCTION .................................................................................................................. 1 \nII. \nARGUMENT .......................................................................................................................... 3 \nA. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators. .......................... 3 \n1. ZG Generating Facilities that Make Unauthorized Injections Should Be Penalized. ...... 3 \n2. ZGIA’s Requirement for System Protection Facilities is Poorly Defined. ...................... 9 \n3. Length of the Transient Tolerance Window Should be Set According to Clear \nStandards. ....................................................................................................................... 12 \nB. The Proposal Lacks Required Transparency...................................................................... 14 \nC. The ZGIA Program’s Scope Should Have a Defined Limitation. ..................................... 16 \nD. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will Be Paid \nby Other than the Cost Causers. ........................................................................................ 18 \n1. Overview of MISO’s Cost-Shifting Safeguards ............................................................ 19 \n2. MISO’s Safeguards are Inadequate to Prevent Cost-Shifting of Network Upgrades to \nInterconnection Customers and Load. ........................................................................... 21 \nE. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources. .............. 26 \nF. \nDrafting Errors ................................................................................................................... 27 \n1. Limitation on Injections ................................................................................................. 27 \n2. Reference to Interconnection Study ............................................................................... 29 \nIII. \nCONCLUSION ................................................................................................................. 29 \n \n \nII. \nARGUMENT \nA. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators. \n1. \nZG Generating Facilities that Make Unauthorized Injections Should Be \nPenalized.  \nZero injection is an extremely clear program design element in this Proposal,4 but MISO fails \nto ensure that zero means zero.  The Transmittal Letter, testimony, and proposed tariff language \nare silent about what happens when a ZG Generator exports power to the grid outside the Point of \n \n4 Transmittal Letter at 8 (MISO stating that the “new generator with ZGIA Interconnection Service cannot inject past \nthe interconnecting substation…”); id at 13 (MISO stating that the “ZG Interconnection Service is limited to \nrequesting and being awarded Interconnection Service at a level that does not exceed the peak demand of the ZG \nAssociated Load.”"},{"page":4,"startToken":774,"endToken":1095,"text":"4 \nInterconnection (“POI”) and the Transient Tolerance Window.  Yet the Commission clearly stated \nin the Show Cause Order that it is concerned with the lack of tariff provisions that “specify \nrequirements for necessary control technologies and protections systems” needed to limit \nwithdrawals consistent with study arrangements and related agreements.5  The Commission should \nrequire MISO to modify its ZGIA proposal to include robust operational penalties for ZGIA \nGenerating Facilities that make unauthorized injections into the MISO transmission system \nnotwithstanding the use of control technologies and/or protection systems.6  MISO cannot be silent \non its enforcement procedures in light of the serious reliability risks to the grid that may arise if a \nZGIA Generating Facility fails to limit its injections as promised. The Commission should require \nMISO to impose strict operational penalties to give ZG Generating Facilities adequate incentives \nto limit their injections as expected or risk termination of their transmission service if they fail to \nperform. \ni. Unauthorized injections are likely to increase reliability risks in MISO. \nUnauthorized injections on the transmission system can lead to increased reliability risks, \nmaking it imperative that generators are properly incentivized to follow zero-injection \nrequirements.  MISO has acknowledged the reliability risks associated with large loads, including \nthe risk associated with frequency and voltage instability, system balancing, and Area Control \nError volatility.7 MISO’s Board previously made a commitment to address the operational risks \nassociated with large loads, particularly with respect to ramping, adequacy, and stability.8  Yet, in \n \n5 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212, P 64 (2026). \n6 See generally, PJM Interconnection LLC, 193 FERC ¶ 61,217 at P 212 (2025) (“PJM Co-location Order”). \n7 Interconnection of Large Loads to the Interstate Transmission System, Comments of the Midcontinent Independent \nSystem Operator, Inc., Docket No. RM26-4-000, Accession No. 20251121-5472 at 30 (Nov. 21, 2025).  \n8 Id. at 29, n.29."},{"page":5,"startToken":1095,"endToken":1457,"text":"5 \nthis filing, MISO fails to adequately address the severity of potential reliability issues that could \nbe caused by unauthorized injections on the system.  \nRecent grid fluctuation events illustrate the serious reliability risks that could result from \nunplanned injections on the system.  In July 2026, over three GW of data centers on the PJM grid \nsuddenly disconnected, causing voltage and frequency fluctuations that could be detected from \nVirginia to Illinois.9  While operators can typically correct grid disturbances within milliseconds, \nthis event took almost 10 minutes to stabilize.10  A similar event occurred two years prior, also in \nPJM, where 1.5 GW of data center load suddenly dropped in Northern Virginia, forcing operators \nto make emergency adjustments to prevent cascading outages.11  There is growing concern from \nthe North American Electric Reliability Corporation (“NERC”) about the increased amount of \ncustomer initiated load reduction events as large, extended fluctuations can lead to cascading \nfluctuations and system blackouts.12  \nThe Commission should require MISO to impose strict operational penalties to prevent similar \ngrid fluctuation events from occurring in MISO’s territory.  MISO anticipates that ZG Associated \nLoads may, at some point, suddenly decrease their load.13  The ZGIA proposal establishes a \nTransient Tolerance Window during which the ZGIA Generating Facility will ramp down to match \n \n9 Lee Shaver, Data Centers are Already Stressing the Grid. Regulators are Playing Catch-up, Union of Concerned \nScientists (Aug. 6, 2026), https://blog.ucs.org/lee-shaver/data-centers-are-already-stressing-the-grid-regulators-are-\nplaying-catch-up.  \n10 Tim McLaughlin, Massive Disconnect of Power Roils Largest US Electric Grid, Reuters (Jul. 22, 2026), \nhttps://www.reuters.com/business/energy/massive-disconnect-power-roiled-largest-us-electric-grid-2026-07-22.  \n11 Rachel Mural, et. al, AI, Data Centers, and the U.S. Electric Grid: A Watershed Moment, Belfer Center for \nScience and International Affairs (Feb. 10, 2026), https://www.belfercenter.org/research-analysis/ai-data-centers-us-\nelectric-grid.  \n12 NERC, Characteristics and Risks of Emerging Large Loads: Large Loads Task Force White Paper (July 2025), \nhttps://www.nerc.com/globalassets/who-we-are/standing-committees/rstc/whitepaper-characteristics-and-risks-of-\nemerging-large-loads.pdf, at 21-36; NERC, Level 3 Alert: Computational Load Modeling, Studies, Instrumentation, \nCommissioning, Operations, Protection, and Control (May 4, 2026), \nhttps://www.nerc.com/globalassets/programs/bpsa/alerts/level-3-computational-load-alert.pdf, at 8.  \n13 Transmittal Letter at 21."},{"page":6,"startToken":1457,"endToken":1767,"text":"6 \nthe reduced load level.14  MISO’s filing acknowledges that ZG Generating Facilities cannot \ninstantaneously ramp down to meet the associated load loss, which presents increased risks of grid \nfluctuations as ZGIA arrangements attempt to stabilize.  If multiple ZG Generating Facilities fail \nto ramp down as expected, either by choice or by misoperation of control technology, the MISO \ngrid could experience cascading fluctuations across its system. As demonstrated in PJM, as more \nGWs of load drop from the system, fluctuations are harder to manage.  If MISO anticipates that \nlarge loads will use the ZGIA service to connect to the grid, it must ensure that ZG Generating \nFacilities will limit their injections when necessary.  The control equipment and management \nmeasures contemplated in the Proposal, even if optimally chosen,15 are not sufficient. \nii. Strong Operational Penalties Are Needed to Ensure That ZG Resources \nWill Not Make Unauthorized Injections That Could Lead to Greater \nReliability Risks. \nThe Commission must require MISO to implement strong penalties to prevent ZG Resources \nfrom making unauthorized injections into MISO’s transmission system above their authorized \nlevel of service (namely, zero), consistent with the Commission’s prior finding that transmission \ncustomers should be subject to penalties for unreserved use of the transmission system.16  Absent \nsuch penalties, the Proposal cannot be found just and reasonable. \nMISO’s ZGIA proposal fails to discuss any penalties to be levied on ZGIA Generating \nFacilities that violate the rule against unauthorized injections outside the Transient Tolerance \nWindow.17  Similarly, MISO’s proposal states that the ZG Interconnection Service Study must \n \n14 Id.  \n15 As discussed infra in section II.A.2, MISO has not optimally or adequately structured its requirements for control \nequipment and measures. \n16  PJM Co-location Order at P 212 (2025) (directing PJM to brief appropriate penalty charges for transmission \ncustomers’ unreserved use of the PJM transmission system).  \n17 Transmittal Letter at 43."},{"page":7,"startToken":1767,"endToken":2049,"text":"7 \nconfirm that a generator’s proposed equipment can sufficiently limit injections, but is silent as to \nany consequences if the equipment malfunctions and allows the generator to inject into the \ntransmission system outside the Transient Tolerance Window.18 \nThe Proposal contains no specific penalty schedule or mandatory reporting of injection events \nand control failures.  There seems to be no consequence for an unauthorized injection—no charge, \ncurtailment, suspension, mandatory retesting, or graduated penalty.  This lackadaisical approach \nto enforcement is inconsistent with the serious reliability risks that would occur if ZG Generating \nFacilities made unauthorized injections into the system.  When faced with potential consequences \nas serious as widespread outages, MISO must implement operational penalties that are just as \nserious. \nThe Commission has already found that operational and financial penalties are just and \nreasonable to ensure that customers follow curtailment directives, especially where there are \nsignificant reliability risks if customers fail to curtail.19  In its recent proceeding on co-location \narrangements in PJM, the Commission directed PJM to establish an appropriate penalty charge \nand “any other remedial action” that PJM should take to address a customer’s unreserved use of \nthe transmission system or excess energy withdrawals.20   PJM established three separate penalties \nthat escalated in severity based on the potential harm to the transmission system—a pause in \nservice, disqualification, and financial penalties—where customers rely on control technologies \nthat fail more than once, fail to follow Load Shedding and Curtailment directives, or make \n \n18 Transmittal Letter at 13, 14.  \n19 PJM Interconnection, L.L.C., Order on Rehearing, Clarification, Compliance Filing, and Paper Hearing, 195 \nFERC ¶ 61,209, at P 515 (2026) (“PJM Co-Location Rehearing Order”). \n20 PJM Co-location Order at P 212."},{"page":8,"startToken":2049,"endToken":2356,"text":"8 \nunreserved use of the transmission system.21  The Commission found that it was just and \nreasonable to establish these operational penalties because (1) PJM’s new services for co-location \narrangements were designed for Eligible Customers that are willing and able to limit their \nwithdrawals from the transmission system; and (2) there are significant reliability risks if Eligible \nCustomers fail to curtail.22   \nSimilarly, MISO’s ZGIA proposal is designed on the assumption that ZGIA Generation \nFacilities can and will limit their injections on the system and that (like in PJM), there are serious \nreliability risks if ZGIA Generating Facilities fail to limit their injections when directed to. MISO’s \nproposal states that “[t]he premise of ZG Interconnection Service is that injections beyond the \ninterconnecting substation can be limited.”23  ZG Generating Facilities, and their ZG Associated \nLoads, would be allowed to interconnect quickly on the assumption that they will adhere to strict \nlimitations on injections.24  Under the proposed ZG Interconnection Agreement, a Generating \nFacility taking ZG Interconnection Service agrees to the requirements to install equipment to \nreduce its injections at times when the ZG Associated Load reduces its demand and to cease all \ninjections onto the transmission system when necessary.25  Allowing ZGIA Generating Facilities \nto connect quickly through ZGIA on the basis that they will limit their injections, but not enforcing \nany penalties against them when they fail to limit those injections would, as PJM said with respect \nto its co-location penalties filing, “implicitly bless such dangerous behavior.”26  \n \n21 Initial Brief of PJM Interconnection, L.L.C., Docket No. EL25-49-000, at 50 (Feb. 23, 2026), Accession No. \n20260223-5189 (“PJM Initial Brief”). \n22 PJM Co-Location Rehearing Order at P 515. \n23 Transmittal Letter at 42.  \n24 Transmittal Letter at 7.  \n25 Proposed Att. X, App’x 19, § 9.7.4.7.  \n26 PJM Initial Brief at 42."},{"page":9,"startToken":2356,"endToken":2668,"text":"9 \nMISO should terminate or pause a ZG Generating Facility’s ability to use the transmission \nsystem if the generator fails to stay true to its promise to limit its injections.  Otherwise, ZGIA \nGenerating Facilities would receive the benefits of connecting to the grid quickly without \nproviding a commensurate benefit to the grid, and at worst, would risk endangering the stability \nof the transmission system.  The failure of a ZG Generating Facility to limit its injections could \ncause reliability risks similar to those contemplated in PJM’s Co-Location docket, including a \nhigher risk of widespread outages across the bulk power system.27  In order to ensure that the \nsevere risks of failing to limit injections are weighed equally to the benefits that ZGIA Generation \nFacilities receive from the ZG Interconnection Service, the Commission should require MISO to \nimpose operational penalties on Generating Facilities that fail to limit their injections as directed. \n2. \nZGIA’s Requirement for System Protection Facilities is Poorly Defined. \nNext, MISO falls short in its unnecessarily weak standard for System Protection Facilities that \nwill ensure zero injection.  The applicant ZG Generating Facility is required to identify “any \nproposed system protection facilities”28 in its Interconnection Request.  Although not capitalized \nin that passage, System Protection Facilities is an existing defined term meaning, as relevant, \n“equipment [] required to protect [] the Transmission System or other delivery systems or other \ngenerating systems from faults or other electrical disturbances occurring at the Generating \nFacility.”29  It is apparent from the filing that “System Protection Facilities” (or system protection \nfacilities) in this context is intended to “control injection onto the rest of the Transmission \n \n27 NERC, Characteristics and Risks of Emerging Large Loads: Large Loads Task Force White Paper, supra note 12, \nat 20.  \n28 Proposed Att. X § 3.11(ii); Att. X, App’x 1 § 10 and Att. A-5. \n29 Att. X § 1 (definition of System Protection Facilities)."},{"page":10,"startToken":2668,"endToken":3039,"text":"10 \nSystem,”30 although that is not codified in the proposed tariff.  Following the Interconnection \nRequest, the proposed ZG Facilities Study is to identify “any required system protection facilities \nand equipment,”31 with such facilities memorialized in the ZG Interconnection Agreement.32 \nMISO’s proposal falls short of what is needed to ensure that zero means zero by missing any \nminimum configuration of System Protection Facilities necessary to block unauthorized power \ninjections to the grid beyond the POI.  Outside the proposed tariff, MISO narrates its intentions: \n“MISO anticipates reviewing a variety of configurations, physical equipment, and \noperational requirements that may independently, or in sum, prevent injections on \nthe Transmission System beyond the substation where the Point of Interconnection \nis located. For example, the injection limitation may be implemented through \nequipment controls such as export-limiting controls, directional relays, interlocks, \nand fail-safe trip logic. Operational requirements may include generation limits, \ncurtailment obligations, outage coordination, and restrictions on operation. These \noperational requirements are in addition to any monitoring, testing, or maintenance \nrequirements.”33 \n \nThe lack of clarity with this choose-your-own-adventure configuration approach is precisely \nwhy the Commission directed transmission providers to submit tariff proposals or explain why \nthey are not needed.34  No export-limiting control device (nor control over such device) is \nrequired anywhere in the proposed tariff. MISO proposes to give itself discretion to judge \nwhether the “proposed control equipment and/or operating procedures […] are sufficient to \nprevent injections”35 (emphasis added), suggesting that a protocol for manual intervention alone \n \n30 Transmittal Letter at 28; see also proposed Att. X, App’x 19 § 9.7.4.7 (requiring the ZG Generating Facility to \n“install equipment” required to comply with the zero-injection requirement outside the Transient Tolerance Window. \n31 Proposed Att. X. § 3.2.5.2.2. \n32 Proposed Att. X, App’x 19, App’x A §§ 2, 5. \n33 Keyser Test. at 33; see also proposed Att. X § 3.2.5.2.1 \n34 See generally, Show Cause Order at P 21 (cautioning against stand-alone study agreements); id at P 49 (requiring \na degree of clarity and specificity in the tariff regarding studies for customers to avoid a variety of issues including \ndisputes regarding how studies are conducted). \n35 Proposed Att. X § 3.2.5.2.1."},{"page":11,"startToken":3039,"endToken":3337,"text":"11 \nby the ZG Generating Facility’s operator might be acceptable to MISO.  The Commission in the \nShow Cause Order called for MISO to develop generator interconnection service that reflects “a \ngenerating facility with necessary control technologies and/or protection systems, which may \ninclude a special protection scheme, that ensure that the injection does not exceed the limit in the \n[…] interconnection agreement.”36  “Special protection scheme” was defined there as in the PJM \nCo-Location Rehearing Order,37 which in turn referenced the PJM Co-Location Order: “a plan \ndesigned to detect abnormal system conditions and to automatically take appropriate corrective \naction, to maintain system stability, acceptable system voltages, and acceptable facility \nloading”38 (emphasis added). But, defying the Commission’s directives, MISO here proposes no \nrequirement for automatic corrective action. \nAdditionally, the Proposal fails to be just and reasonable in missing any specific requirements \nfor testing the protective measures.  The ZG Interconnection Agreement gives MISO a “right to \ninspect” the ZG Generating Facility’s “System Protection Facilities and other protective \nequipment,” including looking at tests, inspections, settings, and maintenance records, but sets \nno requirement for MISO to do so at any particular interval.39  Similarly, the agreement requires \nthe ZG Generating Facility to test its System Protection Facilities “[a]t intervals suggested by \nGood Utility Practice” but does not set any interval or require MISO to verify the testing.40  This \nstands in contrast to, for example, the clear requirement for a ZG Generating Facility’s metering \nequipment to be testified at least biennially.41 \n \n36 Show Cause Order at P 113. \n37 PJM Co-Location Rehearing Order at P 480. \n38 PJM Co-Location Order at P 204. \n39 Proposed Att. X, App’x 19 § 6.4. \n40 Id. §§ 9.7.4.5, 9.7.4.6. \n41 Proposed Att. X, App’x 19 § 7.4."},{"page":12,"startToken":3337,"endToken":3656,"text":"12 \n3. \nLength of the Transient Tolerance Window Should be Set According to \nClear Standards. \nA third infirmity in ensuring that zero means zero is how MISO proposes to set the “Transient \nTolerance Window,” which is “the period of time after a reduction or loss of load by the ZG \nAssociated Load by the end of which window the [ZG] Generating Facility must have” ceased \ninjections to the grid.42  In other words, this time span, defined as no more than 20 seconds,43 is \nthe time for a ZG Generating Facility to ramp down production as needed when its co-located load \ndrops.  This time window is a fundamental engineering parameter of ZGIA service, but MISO has \nnot justified why a maximum period of 20 seconds is either operationally attainable by a generator \n(or if a greater or lesser time window would be more appropriate), or operationally acceptable for \nthe transmission grid to remain stably within reliability criteria while receiving unexpected \ninjections over that time interval. \nMISO states that it “determined that a 20-second limit provides the best system-wide balance \nbetween what is technically feasible and commercially practical on the one hand, and minimizing \neven transient injections on the other hand”;44 and MISO’s witness Keyser opines that 20 seconds \nwas chosen “in order to align with the MTEP modeling interval of 20 seconds for transient stability \nanalysis.”45  The physical or even customary basis of 20 seconds remains obscure, as this figure is \nmentioned neither in the existing Attachment FF (Transmission Expansion Planning Protocol) nor \nin Business Practices Manual 20 (Transmission Planning).  MISO should better justify the specific \ntime interval chosen with reference to NERC standards, local planning criteria, or some other \ngrounding in electrical engineering realities. \n \n42 Proposed Att. X § 1; proposed Att. X, App’x 19, Art. 1 (proposed definition of Transient Tolerance Window). \n43 Id. \n44 Transmittal Letter at 21-22. \n45 Keyser Test. at 25:20-22"},{"page":13,"startToken":3656,"endToken":3976,"text":"13 \nAn additional deficiency with MISO’s definition of Transient Tolerance Window is its \nallowance that 20 seconds would be the maximum period allowed, while the time period could be \n“further described by the Business Practices Manual for Large Load.”46  MISO gives more color \nits intentions in its filing letter, offering that “there may be circumstances where a narrower \nwindow is necessary and practical given electrical topography on certain parts of the MISO \nSystem, or Applicable Local Planning Criteria.  It would be impractical to identify all such \ncircumstances in the Tariff.  Therefore, the definition allows for the creation of Business Practices \nManual (“BPM”) rules that narrow the window based on specific circumstances[.]”47  A tariff that \nremained silent about all the standards and intentions in the prior quotation while reserving \nauthority for MISO to make discretionary changes outside the Commission’s oversight would \nviolate the Rule of Reason, which requires that provisions that (1) significantly affect rates, terms, \nand conditions of service, (2) are realistically susceptible of specification, and are (3) not generally \nunderstood in a contractual agreement must be included in the tariff.48  While the D.C. Circuit has \nrecently recognized that “even specifiable practices that significantly affect rates need not be \nincluded if they are clearly implied by the tariff’s express terms,”49 the proposed tariff’s passing \nreference to the BPM hardly implies anything as to how MISO will consider varying the 20-second \nrule. \nAs a policy matter, users of ZGIA service, not to mention regulators and stakeholders, will \nwant to develop reasonable expectations about how the 20-second interval for unauthorized \ninjections might evolve; but the placement of untariffed policies in the Business Practices Manual \n \n46 Proposed Att. X § 1. \n47 Transmittal Letter at 21. \n48 City of Cleveland v. FERC, 773 F.2d 1368, 1376 (D.C. Cir. 1985). \n49 Hecate Energy Greene Cnty. 3 LLC v. FERC, 72 F.4th 1307, 1314 (D.C. Cir. 2023)"},{"page":14,"startToken":3976,"endToken":4292,"text":"14 \nwill complicate that.  A Transient Tolerance Window that MISO can adjust by standardless fiat \nhardly supports orderly market development. \nB. The Proposal Lacks Required Transparency. \nThe Commission found in the Show Cause Order that MISO must provide “cost transparency \nmeasures […] to provide stakeholders with sufficient information and visibility regarding the \nNetwork Upgrades, and their associated costs, needed to provide transmission service to Eligible \nCustomers on behalf of large loads.”50  The Commission further found that MISO’s tariff is not \njust and reasonable to the extent “it does not require the provision of data on MISO’s website in a \nsingle location, and in an easily accessible format that is searchable and allows users to filter the \ndata, that identifies the Network Upgrades that are needed to accommodate requests for \ntransmission service by Eligible Customers on behalf of large loads, and the costs of those Network \nUpgrades.”51  Despite this clear command from the Commission for transparency of large load52-\ninduced costs, and MISO’s stated attempt to respond to the Show Cause Order, MISO has fallen \nwell short of the Order’s clear requirements on transparency.  It is simply not correct that the \n“ZGIA proposal is well aligned with the Commission’s goals and objectives of transparency,” as \nMISO avers.53  \n \n50 Show Cause Order at P 71. \n51 Id. P 77. \n52 Although the ZGIA proposal is not restricted to serving only large loads, it is reasonable to expect that large loads \nwill be a significant share of the end-use customers benefiting from the program. “MISO notes that this description \n[generally outlining ZGIA] explains how ZGIA will serve large loads”; “The ZGIA proposal represents another \ncritical tool to help support the timely, reliable, cost-effective integration of new large loads into the MISO system”; \n“the ZGIA is particularly responsive to the needs of a large load[.]” Transmittal Letter at 8 n.33, 9, 11. \n53 Transmittal Letter at 5."},{"page":15,"startToken":4292,"endToken":4644,"text":"15 \nMISO is  aware of how to design an interconnection program with deliberate transparency, as \nthe Commission found last year.54  Yet, no provision within the ZGIA proposal requires MISO to \npost ZGIA study reports, required Network Upgrades identified or deferred, or affected-system \nresults.  No provision requires the publication of costs of such upgrades, once known. Without the \nunderlying studies and upgrade information, stakeholders and regulators may be unable to quantify \nincremental costs attributable to an expedited project or evaluate whether later MTEP upgrades \nresult from assumptions made in the ZGIA process.  The existing generator interconnection tariff \nincludes various precedents55 for required publication of data, and there is no reason why MISO \ncould not post vital information on Network Upgrades. \nMISO may rest on its requirement that a ZG Generating Facility can qualify for ZG \nInterconnection Service only if the ZG Impact Assessment and ZG Facilities Study find that the \nproposed interconnection “[w]ill not require the construction or modification of any Network \nUpgrades to address impacts to the Transmission System with the exception of Network Upgrades \nlocated at the same substation as the POI, except for System Protection Facilities at adjacent \nsubstations.”56  However, to the extent the ZG Generating Facility is owned by a vertically \nintegrated, state-regulated utility, the costs of Network Upgrades, even if borne by the generator’s \nutility owner, may be allocated in indeterminate ways at the retail level.  The ZG studies may also \nidentify foregone Network Upgrades that would have been required to interconnect the generator \nabsent the ZG Associated Load, or Network Upgrades that would have been required to \naccommodate the new load absent the ZG Generating Facility.  It will be important to track these \n \n54 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064, at P 197 (noting “MISO’s commitment to \npublicly post detailed information about each ERAS interconnection request and its corresponding type of load \nserved”). \n55 Att. X §§ 3.3.4, 3.4.2.1 – 3.4.2.6. \n56 Proposed Att. X § 3.2.5.1(2); also see §§ 3.2.5.2.1, 3.2.5.2.2, 3.11(iii)."},{"page":16,"startToken":4644,"endToken":4970,"text":"16 \nforegone upgrades should either the ZG Associated Load or ZG Generating Facility depart the co-\nlocated arrangement in the future, putting upgrade costs back on the table.  Overall, the Proposal \nfalls well short of the necessary transparency urged by the Commission. \nC. The ZGIA Program’s Scope Should Have a Defined Limitation. \nThe Commission’s two orders last year on the ERAS fast-track interconnection program \nemphasized the Commission’s longstanding policy on open access to the transmission system and \nrequirement to limit the scope of departures therefrom.  The first ERAS order denied MISO’s \ninitial proposal as not just and reasonable, in part because it lacked a program size cap (in either \nproject counts or project megawatts).57  The Commission also found that the proposed program \nend date of December 2028, allowing for three and a half years’ worth of project selections, would \n“exacerbate[] the potential for a volume of ERAS interconnection requests untethered to reliability \nor resource adequacy needs” and would “make[] it difficult to determine […] whether the solution \nis narrowly tailored to fix the problem.”58  MISO altered the time limit on its ERAS proposal when \nit re-filed, setting August 2027 (two years after program commencement) as the sunset date, and \ncapping the size of the program at 68 total projects.  The Commission credited these limitations in \nultimately approving the second ERAS proposal, finding that “the limited, one-time design of the \n[proposed ERAS] process weighed significantly on our decision here.”59 \nDespite this precedent, MISO now comes to the Commission with a new fast-track \ninterconnection pathway that is similar to the one it rejected.  The program has a structure of 10 \napplications processed per quarter,60 but otherwise no limit on the long-term availability of the \n \n57 Midcontinent Independent System Operator, Inc., 191 FERC ¶ 61,131, at PP 199-201. \n58 Id. at P 199. \n59 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064, at PP 84, 195, 203, 265. \n60 Proposed Att. X § 3.11.2."},{"page":17,"startToken":4970,"endToken":5240,"text":"17 \nprogram for new applicants, the total project number,61 or the total megawatts of capacity.  MISO \ncalls it “fundamentally a limited product”62 but offers no limitations on the scope of the program.  \nWitness Keyser explains in testimony why ZGIA service is proposed as a “permanent product” for \na given participating generating plant but ignores why MISO is not capping the number or size of \nparticipating projects, or the overall lifespan of the program.  This mirrors MISO’s approach to \nstakeholder feedback earlier this year.  While acknowledging stakeholders’ “[r]equests to ensure \nZGIA is a transitional construct and does not replace the standard GIA process,” MISO wholly \nignored the point in its response to related comments: \n63 \nTo achieve the narrow tailoring required by the Commission’s open access precedents, a \nprogram that bypasses the traditional interconnection queue must have some limitation on how \nlarge it could get.  Such limitation would be consistent with, for example, the Commission’s \napproval earlier this year of Southwest Power Pool’s HILLGA (“High-Impact Large Load \nGeneration Assessment”) interconnection program, which limits the HILLGA service for any \n \n61 MISO expressly acknowledged this point at a stakeholder meeting earlier this year: “there is no limitation on the \nnumber of ZGIA requests[.]” Minutes of April 22, 2026 Planning Advisory Committee meeting, \nhttps://cdn.misoenergy.org/20260527%20PAC%20Item%2001c%20Minutes%2020260422754915.pdf, at 6. \n62 Transmittal Letter at 12. \n63 MISO, Consideration of Zero-Injection GIA (Interconnection and Planning Draft Tariff Updates), Presentation to \nPlanning Advisory Committee (April 22, 2026), \nhttps://cdn.misoenergy.org/20260422%20PAC%20Item%2006%20Consideration%20of%20Zero-\nInjection%20GIA%20%20(PAC-2024-4)752672.pdf, at 23."},{"page":18,"startToken":5240,"endToken":5563,"text":"18 \ngiven generator to five years.64  For MISO ZGIA, a pilot program, for example, with a defined \ntime limit of availability for new applicants or a defined time limit for each given interconnection \nagreement, followed by Commission review for renewal, could allow the Commission to consider \nwhether continued derogation from open access should continue.  Absent those guardrails, ZGIA \nis not just and reasonable.   \nD. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will \nBe Paid by Other than the Cost Causers. \nMISO’s ZGIA proposal includes two primary mechanisms that together are designed to prevent \ncost-shifting from ZGIA projects to other interconnection customers or load. These mechanisms \ninvolve: 1) a requirement that, in order to qualify for ZG Interconnection Service to begin with, \nthe ZG Generating Facility will not require additional large-scale network upgrades, and 2) that \nMISO can credit the ZG Generating Facility as a “Non-Transmission Alternative” as a result of \nsigning five-year commitments with ZGIA load.  However, as further described below, those \nprotective measures do not sufficiently insulate Network Upgrade costs from instances when some \nor all the ZG Associated Load is not placed in service.  \nSpecifically, as discussed in section II.D.2 below, there are at least three principal flaws with \nthe Proposal that can result in cost-shifting: 1) the five-year commitment is insufficiently concrete \nto provide the requisite certainty that the load integration study and its assumptions regarding \nneeded upgrades are accurate; 2) the structure of the Proposal creates a fast-track ZGIA to GIA \nprocess whereby ZG Generating Facility could later convert to ERIS or NRIS service and thereby \n \n64 The HILLGA program requires an applicant generator to be within two substations of the large load it serves, such \nthat the generator will be “injecting within the local area of the [large load]” similar to the MISO ZGIA Proposal.  \nSouthwest Power Pool, Inc., 194 FERC ¶ 61,031 (Jan. 14, 2026) at PP 25, 28, 33."},{"page":19,"startToken":5563,"endToken":5864,"text":"19 \nskip ahead of the normal interconnection queue while also potentially avoiding network upgrades; \nand 3) the mismatch in the timing of the various study cycles can result in further cost-shifts. \n1. \nOverview of MISO’s Cost-Shifting Safeguards \nThe first mechanism in the Proposal is a condition of obtaining ZG Interconnection Service \nwhich states that a ZG Generating Facility is eligible for the service only if it does not require \nconstruction or modification of large-scale Network Upgrades, except for same-substation \nupgrades and certain System Protection Facilities.65  The analysis for this determination is \nperformed through the ZG Impact Assessment, which is a screening process used to examine \nwhether the project is eligible for ZG Interconnection Service.66  Pursuant to this assessment, the \nproposed tariff states that a project must “not require the construction or modification of any \nNetwork Upgrades to address impacts to the Transmission System with the exception of Network \nUpgrades located at the same substation as the POI, except for System Protection Facilities at \nadjacent substations.”67  \nIn other words, the ZG Impact Assessment must find that no broader transmission upgrades \nare needed, reliability can be maintained without Network Upgrades beyond the interconnection \nsubstation, and only same-substation upgrades or protection facility upgrades may be required.68  \nIf broader transmission upgrades are needed for the proposed project, it will not qualify for the ZG \n \n65 See Transmittal Letter at 13. \n66 Id. at 28. \n67 See Proposed Att. X, Generator Interconnection Procedures, Section 3.2.5.1(2); see also id. at 3.2.5.2.1 (“For ZG \nInterconnection Service to be granted, these analyses must determine that no Network Upgrades are needed to \nmaintain system reliability other than Network Upgrades at the same substation as the Point of Interconnection or \nSystem Protection Facilities.” \n68 See Transmittal Letter at 28."},{"page":20,"startToken":5864,"endToken":6227,"text":"20 \nInterconnection Service.69  If it does qualify, the interconnection customer then generally bears \nthose costs of those limited upgrades, if any. \nThe second mechanism involves the way in which MISO can credit a ZG Generating Facility \nas a “Non-Transmission Alternative” under the proposal and defer upgrades that would otherwise \nbe needed to serve the ZG Associated Load.70  Attachment FF describes the “process of studying \nthe Network Upgrades needs to integrate new loads onto the Transmission System,” which \nincludes an the “capability of [ZG Resources] to offset the need for Network Upgrades.71 The \nproposal also requires “(1) an executed [five-year] agreement72 between the entity with the ZG \nAssociated Load and the [ZGIA] Generating Facility […] and (2) that the Generating Facility \nassociated with the ZG Associated Load has achieved Commercial Operation by the time that the \ntransmission solution would otherwise need to be in service.”73 “In the event that the Generating \nFacility associated with the ZG Associated Load fails to achieve Commercial Operation by the \ndate that the transmission solution would otherwise need to be in service or the contract between \nthe ZG Associated Load and the associated Generating Facility terminates, then the Transmission \n \n69 Id. \n70 See Keyser Test. at 19. \n71 Id. \n72 Transmittal Letter at 32-33 (“MISO proposes to require the Interconnection Customer to submit an executed \nagreement between itself and the entity with the ZG Associated Load specifying that the full output of the \nGenerating Facility is intended to be used by the ZG Associated Load, with an expected term of at least five years. \n[…] The language of the agreement requirement is based on, and largely identical to, the requirements applicable to \nERAS Interconnection Requests with several differences[:] […] First, ZG Interconnection Service imposes a \nrequirement that the ZG Associated Load at least intend to use the output of the Generating Facility for at least 5 \nyears […] [but] MISO [] only requires that the agreement specify an intent [emphasis in original] to use the full \noutput of the Generating Facility for at least five years rather than a firm commitment”); see also proposed Att. X § \n3.11(vii). \n73 Att. FF § I.D.1.b (as proposed for amendment)."},{"page":21,"startToken":6227,"endToken":6494,"text":"21 \nProvider may require the applicable Load Serving Entity to delay the in-service date of ZG \nAssociated Load until such time as an alternative solution can be placed in service.”74 \n2. \nMISO’s Safeguards are Inadequate to Prevent Cost-Shifting of Network \nUpgrades to Interconnection Customers and Load. \nThe safeguards described above were, in several different ways, inadequately designed to \nprevent cost shifts of Network Upgrades being socialized to non-ZGIA load.  MISO’s proposal is \nunjust and unreasonable until such time that it closes the gaping holes in its proposal that are \nparticularly vulnerable to gaming and undue cost shifting. \ni. \nThe proposed five-year commitment requirement does not provide \ncertainty that the load integration study and its assumptions regarding \nneeded upgrades are accurate \n \nFirst, for new ZG Associated Load, the Proposal does not require adequate financial security, \ncost-recovery agreements, or true-ups for the cost of deferred transmission upgrades if the ZG \nGenerating Facility fails to materialize, retires early, or becomes permanently unavailable.  For \nexample, if the ZG Generating Facility or its contractual arrangement terminates, and a deferred \nupgrade is identified and becomes necessary through a later MTEP cycle, MISO’s proposal would \nnot specifically have those costs assigned to either the ZG Generating Facility or to the associated \nLSE.  Therefore, the upgrade[s] would likely be allocated under ordinary MTEP rules and spread \nto other transmission customers.  MISO itself acknowledges that such reconciliation occurs after-\nthe-fact: “Any transmission issues identified by reconciling the cases will thus be addressed \nthrough the existing MTEP process.”75 The ZGIA’s contingent facilities are fixed at execution, and \n \n74 Id. \n75 Transmittal Letter at 15."},{"page":22,"startToken":6494,"endToken":6807,"text":"22 \nthe filed ZGIA provides no apparent mechanism for adding cost responsibility later to the \nappropriate ZGIA project.76 \nRelatedly, the five-year commitment requirement is insufficient to protect against this cost-\nshift pathway.  Here, MISO made a deliberate choice. as described in its submission, to \naccommodate “commercial considerations” at the expense of ensuring just and reasonable rates, \nby “only requir[ing] that the agreement specify an intent to use the full output of the Generating \nFacility for at least five years rather than a firm commitment.”77  Specifically, MISO justifies this \nchoice by speculating about the “difficult[y]” of “Interconnection Customers and ZG Associated \nLoads to agree to a firm minimum term of at least five years.”78  Beyond this bald statement, MISO \nprovides no evidentiary basis for choosing this inadequate formulation and therefore is arbitrary. \nWhere MISO allows MTEP to rely on a ZG Generating Facility as a Non-Transmission \nAlternative, but later identifies a needed reliability upgrade under a ZG Resource outage \ncontingency, the Proposal does not clearly specify whether that upgrade is treated as a load-driven \ncost of the ZG arrangement or as a generally socialized reliability project.  MISO has stated that \n“Generator outages are accounted for in the MTEP process as P11 or P31 planning events used in \nthe MTEP Reliability Analysis. ZGIA generator outages will be accounted for in this manner.”79  \nTherefore, to the extent a later MTEP review identifies that a ZGIA generator outage necessitates \nNetwork Upgrades, there is nothing in the proposal to expressly prevent those upgrades being \nassigned through the normal MTEP process. \n \n76 See proposed Att. X, App’x 19 at passim. \n77 Transmittal Letter at 33 (emphasis original). \n78 Id. \n79 See MISO Response to Feedback, ZGIA Proposal Framework (PAC-2024-4) (April 15, 2026): available at \nhttps://cdn.misoenergy.org/PAC%20ZGIA%20Proposal%20Framework%20(PAC-2024-\n4)%20Feedback%20Response%20(20260225)751481.pdf, slide 3."},{"page":23,"startToken":6807,"endToken":7113,"text":"23 \nMoreover, MISO’s compromised position belies an irreconcilable tension in its filing.  MISO \nstates that “[i]n order to ensure that the load integration study is an accurate representation of future \nconditions, there must be certainty that the Non-Transmission Alternative becomes operational \nand remains operational.”80  However, here there is no such certainty, as the contracts merely \nrequire a statement regarding contractual expectations and intent.  This weak construct has the \neffect of undermining the accuracy and reliability of the assumptions and outputs of the ZG load \nintegration study.  MISO should instead study each arrangement both with and without the ZG \nGenerating Facility, identify every upgrade deferred in reliance on that resource, and require \nfinancial security or a cost-responsibility agreement covering nonperformance.  The proposed five-\nyear “intended” commercial arrangement is not a reasonable basis for deferring transmission \nfacilities with much longer planning lives. \nii. \nThe structure of the proposal distorts the normal interconnection \nqueue process by providing a fast-track to ZGIA Generating Facilities \nthat later convert to ERIS or NRIS service \n \nNext, the structure of the proposal also provides a fast-track pathway for ZGIA resources to \nconnect to the gird while also allowing them to avoid needed network upgrades if they later convert \nto ERIS or NRIS service.  In other words, not only can the ZGIA resource energize faster as \ncompared to resources in the traditional DPP queue, the ZGIA resource can also avoid the network \nupgrades they would otherwise be responsible for.  This structure presents serious gaming \nopportunities for ZG Resources seeking to energize quickly. \nAs described in the filing: “[a]n Interconnection Customer with ZG Interconnection Service is \nfree to submit an Interconnection Request into MISO’s queue for ERIS and/or NRIS.  Once the \nInterconnection Customer completes studies and obtains ERIS or NRIS for its ZG Resource, this \n \n80 Keyser Test. at 19 (emphasis added)."},{"page":24,"startToken":7113,"endToken":7436,"text":"24 \nautomatically would supersede any ZG Interconnection Service that such ZG Resource has and \nthe parties would replace or amend the ZGIA with a GIA reflecting the new service levels.”81  \nWitness Keyser further states, “[i]f [a] project meets the eligibility requirements to enter the ZGIA \ninterconnection process, DPP projects in active DPP cycles at or before Decision Point 2 may \ntransfer to the ZGIA process.”82  Therefore, if the ZG Associated Load disappears, which is a \nmaterial possibility based on the weak contractual requirements,83 the ZG Generating Facility will \nhave skipped interconnection queue line as it can then apply for NRIS/ERIS, while also possibly \navoiding the Network Upgrades that it may have otherwise been assigned had it completed the \nDPP interconnection process in the first instance.  This structure creates a fast-track ZGIA to GIA \nprocess where ZG Resources could use the ZG Interconnection Service to get ahead of DPP \nresources.  MISO’s proposal includes no safeguards applicable to the ZG Generating Facilities in \nthe form of weighted escrow, securities, or other mechanism to protect against this opportunity for \ngaming and cost-shifting. \niii. \nMISO’s proposal will result in further cost shifts as a result of  \nmismatched study cycle timing \n \n \nLastly, a study timing mismatch yields yet another opportunity for undue cost-shifting, as \nsome deferred upgrades, like missed cumulative fault-duty and other reliability effects,84 that show \nup in MTEP but not the ZGIA study cycle may be charged to load more generally.  An energized \ngenerator contributes fault current even when it is not exporting real power, which is why the Tariff \npermits, among other things, System Protection Facilities at adjacent substations as the sole extra-\n \n81 Id. at 15-16. \n82 Id. at 29. \n83 As describe above, the ZG Associated Load is required to have only an agreement evincing an “intent” to take the \nZG Generating Facility’s power for five years.  \n84 Such as protection coordination, voltage performance, and dynamic stability."},{"page":25,"startToken":7436,"endToken":7753,"text":"25 \nsubstation upgrade.  However, the system impacts of these effects may be lost because of the timing \nof ZGIA and DPP studies. \nMISO plans to include all interconnection requests with an approved GIA in the base case for \neach ZGIA cycle, but not to the base case for DPP cycles if the DPP studies are ongoing.85  Once \nthe DPP cycle is finished, the output from the cycle and the completed ZGIA and the MTEP’s \nExpedited Review Projects will be included in the new MTEP base case.86  MISO plans to \nreconcile any differences caused by the different study assumptions in the ZGIA and the DPP \nthrough the MTEP process.  The next DPP cycle will then use the latest MTEP base case.87  \nHowever, waiting until the MTEP process to reconcile differences between the ZGIA and DPP \nstudy assumptions means that the Network Upgrades potentially caused by ZG Resources, but not \nidentified until the MTEP process, will be spread to load in MISO through either its regional or \nsubregional cost allocation processes.  Unlike in the generator interconnection process, where \ngenerators pay for Network Upgrades, in the MTEP, Network Upgrade costs are generally \nallocated across load.88  As a result, any transmission upgrades that are not identified in the ZGIA \nand DPP process will be identified in the MTEP process and will be paid for by load.  \nIn other words, successive ZGIAs do “see” one another because MISO adds each GIA \napproved since the last base case to the following ZGIA cycle.  The gap therefore runs between \nZG Resources and pending DPP requests in both directions: the DPP base case is likewise frozen \nat kickoff and not updated for ZGIAs approved mid-cycle.  Projects in each track may therefore \nbe studied against models that omit the other.  MISO has not adequately explained how their \n \n85 Transmittal Letter at 15. \n86 Id. \n87 Id. \n88 Att. FF § III.A.2."},{"page":26,"startToken":7753,"endToken":8071,"text":"26 \ncumulative short-circuit, protection, voltage, and stability effects will be reconciled before \napprovals become final.  That gap could cause upgrades to be identified later through MTEP, \nwithout a corresponding ZGIA cost true-up.  The Tariff should identify the required base case; \nrequire cumulative modeling of prior ZGIAs and relevant pending projects such as projects in DPP \nPhase 2; establish minimum short-circuit, protection, steady-state, and stability analyses; and \nprovide clear restudy and cost-allocation rules.  The current provision making thermal and voltage \nanalysis discretionary “if necessary” is too open-ended.  Ultimately, this means that residential \nratepayers and small industrial customers may end up paying for upgrades caused by these \nresources and their associated loads. \nE. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources. \nThe Proposal allows for Hybrid Resources to apply for ZG Interconnection Service.89  \nHowever, there are two distinct problems in the Proposal that may hinder Hybrid Resources from \nfully participating on a level playing field with other types of resources.  First, the Proposal sets \nthe capacity accreditation of a ZG Generating Facility that is a Hybrid Resource based in part on \na cap at “the level of firm interconnection service.”90  As ZG Interconnection Service may be \ninterpreted as not “firm,” Hybrid Resources in the ZGIA program could receive capacity \naccreditation of zero without clarification.   \nSecond, the Proposal is silent as to important dimensions of how the battery storage component \nof a Hybrid Resource will be treated within the ZGIA construct.  MISO has stated elsewhere that \n \n89 Under the Proposal, “[a] ZG Resource may participate as a Generation Resource, Dispatchable Intermittent \nResource, Electric Storage Resource, or Behind the Meter Generation resource”; while Hybrid Resources are \nalready defined as a type of Generation Resource.  Proposed Module A § 1 (proposed definition of Zero Injection \nGeneration (ZG) Resource); Module A § 1 (definition of Hybrid Resource).  \n90 Proposed Module E-1 § 69A.4.1(i); Module E-1 § 69A.4.1(f)."},{"page":27,"startToken":8071,"endToken":8427,"text":"27 \na storage unit’s charging activity will be considered in the DPP interconnection study,91 but MISO’s \nProposal leaves unclear how, for a Hybrid Resource within ZGIA, the constituent storage unit’s \ncharging behavior would be considered in the study.  Relatedly, in the required ZG Impact \nAssessment, “the stability and steady state analyses [will] test[] the impact of injections if the ZG \nAssociated Load trips offline for the duration of the Transient Tolerance window,”92 but the \nProposal leaves unclear whether any such tripping potential by the constituent storage unit would \nbe considered in the study.  Additionally, a ZG Generating Facility shall be metered “separate from \nany metering used for the ZG Associated Load,”93 but the Proposal should clarify whether a \nconstituent storage unit within a ZGIA Hybrid Resource must be separately metered from the \nconstituent generator and whether its charging behavior should be netted from the ZG Generating \nFacility’s “injections” to the extent they must not exceed94 the Load or Demand of the ZG \nAssociated Load. \nF. Drafting Errors \nWhile Community Organizations and Clean Energy Advocates continue to believe the \nProposal is not just and reasonable as filed, we write here to highlight what may be unintended \nerrors in the Proposal as submitted. \n1. \nLimitation on Injections \n \n91 MISO, Removing Storage Charging Limitations in GIAs (PAC-2024-3) (Jun. 10, 2026), \nhttps://cdn.misoenergy.org/20260610%20PSC%20Item%2005%20Removing%20Storage%20Limitations%20in%20\nGIAs%20(PAC-2024-3)762998.pdf, at passim; MISO, Removing Storage Charging Limitations in GIAs (PAC-2024-\n3) (Aug. 26, 2026), \nhttps://cdn.misoenergy.org/20260826%20PAC%20Item%2007a%20Removing%20Storage%20Limitations%20in%\n20GIAs%20 (PAC-2024-3)776961.pdf, at passim. \n92 Transmittal Letter at 15, 28 (discussing proposed Att. X § 3.2.5.2.1); Keyser Test. at 11:2-4, 31:6-7. \n93 Proposed Att. X, App’x 19 § 7.1. \n94 See, e.g., proposed Att. X § 1 (definition of Transient Tolerance Window); proposed Att. X § 3.11(v) (limiting the \nZG Interconnection Service amount to the ZG Associated Load’s Demand); proposed Att. X, App’x 19 § 9.7.4.7 \n(requiring a ZG Generating Facility to reduce injections to match the ZG Associated Load’s Demand)."},{"page":28,"startToken":8427,"endToken":8761,"text":"28 \nTo support a ZG Generating Facility’s requirement to avoid grid injections and produce only \nthe power its ZG Associated Load demands, MISO proposes to require that, after a reduction or \nloss of load by the ZG Associated Load, the ZG generator shall “reduce its injections to a level \nthat does not exceed the Demand of the ZG Associated Load within the Transient Tolerance \nWindow [after a load reduction]”95 or “reduce[] its injections to an amount not greater than the \nLoad of the ZG Associated Load.”96 \nA probable error is in the phrase “reduce its injections” (emphasis added). As the name of the \ninterconnection program suggests, grid injections are supposed to be zero, after the Transient \nTolerance Window elapses. The intent of the referenced phrase may be better captured by MISO’s \nstatement: “it is important to correspondingly reduce the output of the ZG Resource to prevent \npower from flowing out onto the Transmission System”97 or statements in the Show Cause Order \ncontemplating that under this type of arrangement, “a generating facility’s output is matched to the \ndemand of the electrically proximate large load or large co-located load.”98 The Commission \nshould, at minimum, clarify whether MISO intended to write “output” rather than “injections” in \nthe referenced quotations. If MISO intended the phrasing as written, further clarification may be \nneeded to avoid creating a data center-sized loophole: “injections” in the quoted tariff language in \nAttachment X, Section 1 and in Attachment X, Appendix 19, Section 9.7.4.7 can mean only \ninjections within the circuit up to the POI, with zero injections beyond that. \nIt is also unclear whether the reference to Demand in Section 9.7.4.7 of the ZGIA \nInterconnection Agreement was intended to say Load, as Demand is defined in Module A as a \n \n95 Proposed Att. X, App’x 19 § 9.7.4.7(b). \n96 Proposed Att. X § 1 (definition of “Transient Tolerance Window”). \n97 Transmittal Letter at 42. \n98 Show Cause Order at P 113."},{"page":29,"startToken":8761,"endToken":9058,"text":"29 \nmaximum amount of Load over a specified period. If “Demand” was intended, then (i) the \ninconsistency with the use of “Load” in the definition of Transient Tolerance Window is \nunexplained; (ii) it is not clear how the Demand of the ZG Associated Load is to be calculated for \nthis purpose; and (iii) it is unclear why the ZG Generating Facility would be allowed to indefinitely \ninject power at the level of some maximum level of Load. \n2. \nReference to Interconnection Study \nIn proposed new Attachment X, Section 3.2.5.1, the tariff language provides that “This [ZGIA] \nservice is available only if the study required by Section 3.2.3.2 of these GIP determines that the \nproposed interconnection…” (emphasis added).  This appears to be an error; the reference should \nhave been to (proposed new) Section 3.2.5.2 on the next page of Attachment X.  The same \nreference error is also found at proposed new Attachment X, Appendix 19, Section 4.1.4.1. \n \nIII. \nCONCLUSION \nTo effectuate MISO’s zero injection concept without raising the risk of adverse reliability \nevents and cost shifts, Community Organizations and Clean Energy Advocates respectfully ask the \nCommission to use its authority to help MISO course correct.  Given the demonstrated reliability \nconcerns interconnecting and serving large load customers, no countervailing reasons justify \nfailing to establish operational penalties and transparent baseline requirements for system \nprotection mechanisms.   Similarly, as the Commission noted in the OSC, cost transparency is \nparamount given the scale and pace of forecasted load growth.  Without publishing study \ninformation and reducing instances for mismatching cost responsibility between the multiple \ngenerator interconnection queue processes, MISO’s ZGIA process could unduly shift cost burdens \nto other ratepayers without giving states and other advocates visibility to identify or resolve the \nissues."},{"page":30,"startToken":9058,"endToken":9199,"text":"30 \n Since MISO has the structure for a reasonable co-location program, we urge the Commission \nto direct MISO to cure the deficiencies with filing before accepting it.   \nDATED: September 8, 2026 \nRespectfully submitted, \n/s/ Sameer H. Doshi \nSameer H. Doshi \nChristine Powell \nAaron Stemplewicz \nAaliyah Adkins \nEarthjustice \n311 S. Wacker Dr., 14th Floor \nChicago, IL 60606 \nsdoshi@earthjustice.org \ncpowell@earthjustice.org \nastemplewicz@earthjustice.org \naadkins@earthjustice.org \nAttorneys for Michigan Environmental Justice \nCoalition and Community Collaboration on \nClimate Change \nKareem Scales \nCo-Chair \nCommunity Collaboration on Climate Change \nGrand Rapids, MI \nkareem@c4gr.org \nWesley Watson \nPolicy Associate \nMichigan Environmental Justice Coalition \n1401 W. Fort St., P.O. Box 44080 \nDetroit, MI 48233 \nwesley@michiganej.org \n/s/ Jonah Baskin \nJonah Baskin \nAssociate Attorney \nSierra Club Environmental Law Program \n50 F Street NW, Eighth Floor \nWashington, DC 20001 \njonah.baskin@sierraclub.org"},{"page":31,"startToken":9199,"endToken":9274,"text":"31 \n \n \n \n/s/ Daniel Wiggins Jr. \n \n \nDaniel Wiggins Jr. \n \nExecutive Director \n \nMidwest Tribal Energy Resources Association \n \n3136 W. Kilbourn Ave., Suite 200 \n \nMilwaukee, WI 53208 \n \ndaniel.wiggins@mtera.org  \n   \n \n/s/ Natalie McIntire \n \n \nNatalie McIntire \n \nSenior Advocate \n \nNatural Resources Defense Council \n \n20 North Wacker Drive, Suite 1600 \n \nChicago, IL 60606 \n \n(312) 995-5907 \n \nnmcintire@nrdc.org \n \n \n/s/ Beth Soholt \n \n \nBeth Soholt \n \nExecutive Director \n \nClean Grid Alliance \n \n3433 Broadway St. NE, Suite 240 \n \nMinneapolis, MN 55413 \n \nbsoholt@cleangridalliance.org"},{"page":32,"startToken":9274,"endToken":9334,"text":"32 \nCERTIFICATE OF SERVICE \nI hereby certify that the foregoing has been served in accordance with 18 C.F.R. § \n385.2010 upon each party designated on the official service list in this proceeding by email. \nDATED: September 8, 2026 \n \n/s/ Sameer H. Doshi \n \n \nSameer H. Doshi \n \nEarthjustice \n \n311 S. Wacker Dr., 14th Floor \n \nChicago, IL 60606 \n \nsdoshi@earthjustice.org"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":230,"startToken":0,"endToken":27},{"p":1,"at":230,"title":"I. INTRODUCTION","method":"printed heading","endPage":1,"endAt":234,"startToken":27,"endToken":28},{"p":1,"at":234,"title":"INTRODUCTION","method":"printed heading","endPage":3,"endAt":3,"startToken":28,"endToken":491},{"p":3,"at":3,"title":"TABLE OF CONTENTS","method":"printed heading","endPage":3,"endAt":1029,"startToken":491,"endToken":569},{"p":3,"at":1029,"title":"D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will Be Paid","method":"printed heading","endPage":3,"endAt":2186,"startToken":569,"endToken":646},{"p":3,"at":2186,"title":"II. ARGUMENT","method":"printed heading","endPage":3,"endAt":2201,"startToken":646,"endToken":648},{"p":3,"at":2201,"title":"A. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators.","method":"printed heading","endPage":14,"endAt":144,"startToken":648,"endToken":3996},{"p":14,"at":144,"title":"B. The Proposal Lacks Required Transparency.","method":"printed heading","endPage":16,"endAt":273,"startToken":3996,"endToken":4686},{"p":16,"at":273,"title":"C. The ZGIA Program’s Scope Should Have a Defined Limitation.","method":"printed heading","endPage":18,"endAt":421,"startToken":4686,"endToken":5304},{"p":18,"at":421,"title":"D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will","method":"printed heading","endPage":26,"endAt":812,"startToken":5304,"endToken":7863},{"p":26,"at":812,"title":"E. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources.","method":"printed heading","endPage":27,"endAt":1080,"startToken":7863,"endToken":8238},{"p":27,"at":1080,"title":"F. Drafting Errors","method":"printed heading","endPage":29,"endAt":957,"startToken":8238,"endToken":8929},{"p":29,"at":957,"title":"III. CONCLUSION","method":"printed heading","endPage":29,"endAt":963,"startToken":8929,"endToken":8930},{"p":29,"at":963,"title":"CONCLUSION","method":"printed heading","endPage":32,"endAt":4,"startToken":8930,"endToken":9275},{"p":32,"at":4,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":32,"endAt":372,"startToken":9275,"endToken":9334}]}