Motion for Acceptance of Late-Filed Comments and Comments in Conditional Support of the Organization of MISO States, Inc. re Midcontinent Independent System Operator, Inc.’s proposed tariff revisions
Read topic-matched comments in ER26-3552
Topics in the text: Connecting load and generation · Reliability and curtailment · Cost allocation
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Opening text
opening text · Topic match: Reliability and curtailment
OMS cautiously supports the ZGIA proposal but highlights several critical reliability and resource adequacy concerns for the Commission’s consideration.Read this passage Filed comments: Reliability and curtailment
I. MOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS
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MOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure, OMS respectfully requests that the Commission accept these late-filed comments.2 On September 8, 1 Midcontinent Indep.Read this passage
II. COMMENTS
printed heading · Topic match: Reliability and curtailment
Furthermore, nothing in the ZGIA Filing shall supplant state and local rules regarding generation and load application, approval, and interconnection processes.Read this passage Filed comments: Reliability and curtailment
A. OMS Supports ZGIA as a Potential Tool to Interconnect Large Loads, Subject to
printed heading · Topic match: Connecting load and generation
MISO began developing the ZGIA framework with the recognition that co-located arrangements were necessary to quickly integrate large loads and their associated generation while shielding existing customers from any resulting costs.5 The ZGIA framework is further premised on the understanding that a…Read this passage Filed comments: Connecting load and generation
B. Reliability Protections Must Be Fundamental to the ZGIA Framework.
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Reliability Protections Must Be Fundamental to the ZGIA Framework.Read this passage Filed comments: Connecting load and generation
C. The Initial ZGIA Framework Should Be Limited to Generation and Load at the
printed heading · Topic match: Connecting load and generation
MISO’s ZGIA Filing limits ZG Interconnection Service to generation and associated load located at the same substation and voltage level.Read this passage Filed comments: Connecting load and generation
D. MISO Must Prevent Cost Shifting When the Associated Generation or Load Does
printed heading · Topic match: Cost allocation
MISO Must Prevent Cost Shifting When the Associated Generation or Load Does Not Materialize.Read this passage Filed comments: Cost allocation
E. Resource Adequacy Treatment Must Be Complete, Transparent, and Consistent
printed heading · Topic match: Reliability and curtailment
Resource Adequacy Treatment Must Be Complete, Transparent, and Consistent with Physical Capability.Read this passage Filed comments: Reliability and curtailment
F. ZGIA Should Provide a Clear Transition Path Without Circumventing the DPP.
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OMS recognizes that MISO’s proposal expressly permits a ZG Resource to pursue another form of interconnection service separately, including full integration and injection rights through Network Resource Interconnection Service (“NRIS”) through MISO’s Definitive Planning Process (“DPP”), with the…Read this passage Filed comments: Connecting load and generation
G. OMS Supports Transparency and Meaningful State and Stakeholder Oversight.
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OMS Supports Transparency and Meaningful State and Stakeholder Oversight.Read this passage
H. ZGIA Should Complement, Not Displace, Broader Transmission and Large-Load
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Consistent with OMS’s support for MISO and the MISO Transmission Owners’ abeyance request, the Commission should therefore evaluate ZGIA as one component of a broader, comprehensive framework for large load integration rather than as a standalone solution.12 That framework should address the…Read this passage Filed comments: Filing procedure
III. CONCLUSION
printed heading · Topic match: Cost allocation
OMS’s support, however, is conditioned on maintaining the fundamental principles of reliability, cost causation, transparency, and equitable treatment of customers and market participants as detailed above.Read this passage Filed comments: Cost allocation
CERTIFICATE OF SERVICE
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Pope Brad Pope Director of Legal & Regulatory Affairs Organization of MISO States 811 E.Read this passage