Motion for Leave to Answer and Answer of Community Organizations and Clean Energy Advocates to Midcontinent Independent System Operator, Inc.’s 09/23/2026 Answer
Read topic-matched comments in ER26-3552
Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment
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Opening text
opening text · Topic match: Cost allocation
MOTION FOR LEAVE TO ANSWER AND ANSWER Pursuant to Rule 213(a)(3) of the Federal Energy Regulatory Commission’s (“FERC”) Rules of Practice and Procedure,1 Community Organizations and Clean Energy Advocates respectfully submit this Motion for Leave to Answer and Answer to MISO’s Answer filed on…Read this passage Filed comments: Cost allocation
B. MISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of Potential
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B.Read this passage Filed comments: Cost allocation
C. MISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall Limits
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C.Read this passage
D. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource
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D.Read this passage
ATTACHMENT A: TESTIMONY OF HOUTAN MOAVENI, GRID STRATEGIES…….24
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ER25-1674 last year. 4 cost allocation methods that shift certain types of costs from ZG resources by socializing them more broadly; and the lack of system-wide limits on the ZGIA process, of which MISO fails to appropriately consider the broader implications.Read this passage Filed comments: Cost allocation
A. MISO’s Answer Does Not Cure Concerns with ZGIA’s Operational Requirements.
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It is well-established precedent that key terms must be included in the tariff.23 This precedent is important.Read this passage Filed comments: Connecting load and generation
B. MISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of
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MISO further avers that the transparency measures requested by Community Organizations and Clean Energy Advocates are not required of requests in the Definitive Planning Phase, and that MISO does not propose to reduce any generally applicable transparency requirement.82 As Mr.Read this passage Filed comments: Cost allocation
C. MISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall
printed heading · Topic match: Reliability and curtailment
Moaveni explains, “the Filing does not examine how a growing share of generation dedicated to specific loads affects resource adequacy for the rest of the system.”88 Moreover, at a time in which the high cost of new entry continues to be prohibitively expensive and capacity prices continue to…Read this passage Filed comments: Reliability and curtailment
D. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource
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Moaveni notes four areas of uncertainty that such a framework would 91 Community Organizations and Clean Energy Advocates Protest at 16-18. 92 Id. at 26-27. 93 MISO Answer at 20-21. 94 Id. at 21. 95 Id. at 20. 96 Moaveni Testimony at 41. 21 create for hybrid resources, “where the defining…Read this passage Filed comments: Connecting load and generation
CONCLUSION
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Doshi Ada Statler Christine Powell Aaliyah Adkins Earthjustice 311 S.Read this passage Filed comments: Cost allocation
CERTIFICATE OF SERVICE
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DATED: October 8, 2026 /s/ Ada Statler Ada Statler Earthjustice 180 Steuart St. #194330 San Francisco, CA 94105 astatler@earthjustice.orgRead this passage
ATTACHMENT A
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ER26-3552-000 ) Testimony of Houtan Moaveni in Support of the Protest of Community Organizations and Clean Energy AdvocatesRead this passage Filed comments: Cost allocation
I. Introduction
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I.Read this passage
A. My name is Houtan Moaveni. I am a Vice President at Grid Strategies LLC, where I advise on
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I am a Vice President at Grid Strategies LLC, where I advise on energy policy, siting and permitting, transmission planning, and generation interconnection.Read this passage
A. The purpose of my testimony is to evaluate the Zero Injection Generator Interconnection
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Page citations to the MISO Answer are to the pages of the filed PDF. 3 A properly designed zero-injection interconnection service could facilitate generation dedicated to serving new load and avoid unnecessary transmission construction, and MISO narrowed the product in several respects during its…Read this passage Filed comments: Connecting load and generation
II. Summary of Findings
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Please summarize MISO’s proposed new form of interconnection service.Read this passage Filed comments: Connecting load and generation
A. MISO proposes a new form of interconnection service, ZG Interconnection Service, for a
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MISO proposes a new form of interconnection service, ZG Interconnection Service, for a generating facility that connects at the same voltage level of the same substation as a Point of Withdrawal of an identified load, and that serves only that load.3 The amount of interconnection service is capped…Read this passage Filed comments: Connecting load and generation
A. Based on my review of the Filing, I have identified the following issues:
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ZGIA studies exclude pending Interconnection Requests without executed agreements, and the Definitive Planning Phase (DPP) base case is not updated for ZGIAs approved mid-cycle.Read this passage Filed comments: Connecting load and generation
III. Enforceability of the Operating Requirements
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What measures does MISO propose to ensure that resources with ZGIAs comply with the operating requirements?Read this passage
A. MISO proposes the following:
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Equipment obligations in the agreement: The interconnection customer must install communications and monitoring equipment enabling it to monitor the demand of the associated load; install equipment enabling it to reduce injections to a level not exceeding that demand within the Transient Tolerance…Read this passage
A. The proposed measures do not provide adequate assurance that the zero-injection obligation
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The proposed measures do not provide adequate assurance that the zero-injection obligation will be met, in three respects.Read this passage
A. The proposed contractual remedy functions only as a last-resort backstop. It offers no
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The injection-limiting 12 scheme must act whenever the load’s withdrawal falls, not only when the load trips entirely, and termination removes the load’s dedicated supply for the remainder of the term, long after the event that triggered it.Read this passage Filed comments: Connecting load and generation
A. Only in part. The standard that determines whether an injection is permitted is not in the Tariff,
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The standard that determines whether an injection is permitted is not in the Tariff, and the Tariff does not specify what a resource must do to stay within it.Read this passage
A. Only in part. The requirements to verify compliance with the proposal’s operational provisions
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At a minimum, those criteria should specify the maximum permitted export and its duration; the time within which the limiting action must begin and the rate at which output must then be reduced; the required behavior on loss of communications between the load and the generating facility, or loss of…Read this passage Filed comments: Connecting load and generation
IV. Modeling Assumptions and Cost Allocation
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How could MISO’s proposal affect responsibility for transmission costs?Read this passage Filed comments: Cost allocation
A. Two features of MISO’s proposal bear on who bears transmission costs and when. The first is
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Two features of MISO’s proposal bear on who bears transmission costs and when.Read this passage
A. MISO attributes much of the value of a ZGIA to transmission planning. MISO’s witness states
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Specifically, the Answer explains that the ZG Interconnection Study must find that a project requires no Network Upgrades beyond the interconnecting substation, and concludes that “the ZGIA process does not permit MISO simply to defer broader Network Upgrades and their associated costs.”41 MISO…Read this passage Filed comments: Filing procedure
A. The models used to study ZG requests exclude the pending interconnection queue. MISO states
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MISO’s Answer states that a ZG resource seeking Energy Resource Interconnection Service (ERIS) or Network Resource Interconnection Service (NRIS) must submit a new Interconnection Request and proceed through the DPP on the same footing as other requests,53 which is correct as to injection rights;…Read this passage Filed comments: Connecting load and generation
A. Yes. The ERAS process has produced executed interconnection agreements, and one of them
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A §§ A5, A6-1, A6-2. 35 as resembling the ERAS process in its study aspects, timing, and financial obligations,59 and ZGIA studies likewise exclude pending requests without executed agreements.Read this passage Filed comments: Connecting load and generation
A. No. The Filing contains several provisions that bear on the question, but none of them functions
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The upgrades at issue are those needed to serve the associated load, which are determined later, in a different process, under different cost allocation rules.Read this passage Filed comments: Connecting load and generation
A. No. The Filing’s one meaningful transparency provision is that executed ZGIAs will be filed
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MISO’s Answer responds that these disclosures are not required of requests in the Definitive Planning Phase, and that MISO does not propose to reduce any generally applicable transparency requirement.68 MISO is not reducing existing transparency, but the question is whether existing procedures…Read this passage Filed comments: Cost allocation
V. Eligibility and Limitations on the ZGIA Process
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Eligibility and Limitations on the ZGIA Process Q.Read this passage
A. MISO states that the requirements are facially neutral, fuel-agnostic, and open to any resource
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MISO has stated in the stakeholder process that charging by a storage resource with a ZGIA “will follow the same process as other storage resources – storage charging is not considered during the interconnection queue process; instead, it is studied as an obligation to secure transmission service…Read this passage Filed comments: Connecting load and generation
A. The Filing imposes several project-level eligibility constraints, while the program as a whole
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The Filing also includes one express process-wide throughput limit, under which MISO will study no more than ten Interconnection Requests in each quarterly study period, with overflow rolling forward in submission order.75 That is a throughput constraint governing the rate at which requests are…Read this passage
A. The Filing contains no sunset date for the ZGIA process. It contains no aggregate cap on the
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It contains no locational or electrical concentration limit, so ten requests in a single quarter may be located at electrically adjacent substations, with the 75GIP § 3.11.2. 43 cumulative short-circuit and protection effects discussed in Section IV.Read this passage Filed comments: Connecting load and generation
A. There are two principal consequences. First, the Filing does not examine how a growing share
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A ZG resource may not serve any load other than its associated load, and its capacity credits must be used in a Fixed Resource Adequacy Plan or Reliability-Based Demand Curve opt-out rather than offered into the Planning Resource Auction.79 Whether that matters depends on whether the pathway…Read this passage Filed comments: Reliability and curtailment
VI. Conclusion
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VI.Read this passage
A. Yes.
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ER26-3552-000 ) VERIFICATION I, Houtan Moaveni, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that: I am the same Houtan Moaveni referred to in the foregoing document entitled “Testimony of Houtan Moaveni in Support of the Protest of Community Organizations and Clean Energy…Read this passage