Tab C - Testimony of Marc Keyser.pdf
Read topic-matched comments in ER26-3552
Topics in the text: Connecting load and generation · Reliability and curtailment · Cost allocation
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TAB C
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TAB C Tab C UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Midcontinent Independent ) Docket No.Read this passage
I. PROFESSIONAL BACKGROUND AND QUALIFICATIONS
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PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND RELATIONSHIP TO 2 THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC. 3Read this passage
A. My name is Marc Keyser. I am the Director, Central Region—External Affairs for the
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I am the Director, Central Region—External Affairs for the 4 Midcontinent Independent System Operator, Inc. (“MISO”).Read this passage
A. In my current role, I provide advisory services across MISO business areas and manage
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In my current role, I provide advisory services across MISO business areas and manage 20 relationships with key MISO stakeholders across the central region of the MISO footprint. 21 Given my length and breadth of experience, I was chosen to act as the MISO liaison to the 22 newly-formed Large Load…Read this passage
A. No. This is the first testimony that I have provided in any regulatory proceeding.
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This is the first testimony that I have provided in any regulatory proceeding. 8Read this passage
II. PURPOSE OF TESTIMONY
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II.Read this passage
A. My testimony supports two related items. First, my testimony supports the proposed Tariff
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First, my testimony supports the proposed Tariff 11 revisions submitted in this docket to implement Zero Injection Generator Interconnection 12 Service (“ZG Interconnection Service”) and a Zero Injection Generator Interconnection 13 Agreement (“ZGIA”) to govern and memorialize the terms of this…Read this passage Filed comments: Connecting load and generation
A. ZGIA implementation is needed to: (1) provide MISO with visibility into generating
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The ZGIA construct also provides a benefit to the 6 interconnection queue, because it provides a parallel path for differently situated generators 7 to be studied for interconnection service. 8 Q.Read this passage Filed comments: Connecting load and generation
A. As discussed in the Show Cause Order, the Commission has taken numerous actions in the
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As discussed in the Show Cause Order, the Commission has taken numerous actions in the 10 past year to address unprecedented increases in requests for transmission service to serve 11 large loads and the growing interest in the co-location of loads with generating facilities 12 (i.e., co-location…Read this passage
III. THE CURRENT STATE OF THE MISO QUEUE AND THE NEED FOR ZG
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THE CURRENT STATE OF THE MISO QUEUE AND THE NEED FOR ZG 10 INTERCONNECTION SERVICE 11 Q.Read this passage Filed comments: Connecting load and generation
A. MISO’s Interconnection Queue, known as the Definitive Planning Phase (“DPP”),
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MISO’s Interconnection Queue, known as the Definitive Planning Phase (“DPP”), 14 provides a valuable tool that processes a significant volume of generation requests each 15 study cycle.Read this passage Filed comments: Connecting load and generation
A. MISO is proposing a new form of interconnection service because the existing service
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As a result, the ERIS studies must evaluate potential impacts to the 19 entire MISO Transmission System.Read this passage Filed comments: Connecting load and generation
A. The ZGIA construct serves a number of purposes, including: (i) providing visibility into
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The ZGIA construct serves a number of purposes, including: (i) providing visibility into 5 Transmission connected generation that does not plan to inject onto the Transmission 6 System; (ii) providing a needed framework to confirm lack of injection and enforce 7 commitments; (iii) enabling a…Read this passage Filed comments: Connecting load and generation
A. The ZG Interconnection Service requirements differ from those applicable to
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As ZG Interconnection Service limits the ZG 19 Resource to serving only its designated ZG Associated Load, documenting this relationship 20 is necessary to prevent speculative Interconnection Requests that are not tied to actual load. 21 Second, the Interconnection Customer seeking ZG…Read this passage Filed comments: Connecting load and generation
A. The study performed under the DPP process differs from the ZGIA study in several
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Under the DPP, Interconnection Requests are evaluated through a 16 three-phase, grouped study process that includes decisions points designed to identify and 17 remove speculative projects as more information is discovered about the impact of adding 18 a generating resource to the Transmission…Read this passage Filed comments: Connecting load and generation
A. The service award limitation of ZG Interconnection Service serves to ensure that the
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The service award limitation of ZG Interconnection Service serves to ensure that the 11 maximum expected energy production of the ZG Resource is no greater than the maximum 12 demand of the ZG Associated Load, and as a result, the ZG Resource does not inject more 13 broadly onto the Transmission…Read this passage Filed comments: Connecting load and generation
A. MISO developed this requirement after extensive stakeholder discussions and considering
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MISO developed this requirement after extensive stakeholder discussions and considering 1 various alternatives including both limiting ZG Interconnection Service to the same Point 2 of Interconnection or, conversely, expanding it to allow the generation and ZG Associated 3 Load to be separated by…Read this passage Filed comments: Connecting load and generation
A. MISO proposes ZG Interconnection Service as a permanent product because the service is
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MISO proposes ZG Interconnection Service as a permanent product because the service is 12 designed for co-location arrangements in which generation is electrically tied to a specific 13 load at the same substation and voltage level and can be prevented from injecting into the 14 broader…Read this passage Filed comments: Connecting load and generation
A. No. ZG Interconnection Service is fundamentally different from ERIS or NRIS service.
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ZG Interconnection Service is fundamentally different from ERIS or NRIS service. 6 ZG Interconnection Service enables interconnection but excludes injections beyond the 7 substation where the ZG Resource and ZG Associated Load are interconnected. (except for 8 certain inevitable transient injection…Read this passage Filed comments: Connecting load and generation
A. Yes. An Interconnection Customer with ZG Interconnection Service is free to submit an
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An Interconnection Customer with ZG Interconnection Service is free to submit an 19 Interconnection Request into MISO’s queue for ERIS and/or NRIS.Read this passage Filed comments: Connecting load and generation
A. Assume a Generating Facility obtains ZG Interconnection Service for its full 500 MW of
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Under such a configuration, the Generating Facility may still be allowed to 2 provide energy to the co-located load above the 300 MW Interconnection Service level 3 because such energy would not enter the Transmission System and the GIA would 4 appropriately bind such Interconnection Customer to…Read this passage Filed comments: Connecting load and generation
A. No. The ZGIA facilitates the interconnection of a generator at the same substation as ZG
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Like all MISO interconnection agreements, a ZGIA provides the 12 interconnection service to a resource, but does not provide Transmission Service.Read this passage Filed comments: Connecting load and generation
A. The ZGIA construct is one tool to enable speed to power for generation, specifically
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The ZGIA construct is one tool to enable speed to power for generation, specifically 22 generation that is located geographically and electrically close to the load it plans to serve. 23 Tab C Page 18 A ZGIA enables these uniquely situated generators to avoid the costs and time of 1 unnecessary…Read this passage
A. Only resources that have an accepted GIA are eligible for inclusion in MTEP studies.
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However, the MISO interconnection queue does not 15 move this fast.Read this passage Filed comments: Connecting load and generation
A. Attachment FF provides for, among other things, the process of studying the Network
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In order to ensure that the 7 load integration study is an accurate representation of future conditions, there must be 8 certainty that the Non-Transmission Alternative becomes operational and remains 9 operational.Read this passage
A. Fundamentally, HILLGA and ZG Interconnection Service serve the same goal: allowing
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Fundamentally, HILLGA and ZG Interconnection Service serve the same goal: allowing 18 for the rapid study and development of generation needed on an accelerated basis to serve 19 a specific load need.Read this passage Filed comments: Connecting load and generation
A. MISO selected the ZGIA approach to promote an efficient interconnection process and
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MISO selected the ZGIA approach to promote an efficient interconnection process and 21 accelerate service to load, while also preserving equitable treatment of interconnection 22 customers and accommodating preexisting arrangements.Read this passage
A. Historically, MISO has only rarely encountered Interconnection Customers seeking to
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Therefore, it is now important to 12 implement a service type and study process that specifically recognizes both the challenges 13 and opportunities associated with large loads, leverages the increased commercial 14 attractiveness of pairing generation with a specific nearby load, and tailors an…Read this passage Filed comments: Connecting load and generation
IV. THE PROPOSED ZGIA CONSTRUCT
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PLEASE DESCRIBE ZG INTERCONNECTION SERVICE. 4Read this passage Filed comments: Connecting load and generation
A. ZG Interconnection Service is service limited to serving specifically designated load that
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Like other forms 7 of Interconnection Service in MISO, ZG Interconnection Service is not Transmission 8 Service and does not exempt a transmission customer, including a transmission customer 9 serving a large load, from procuring Transmission Service. 10 Q.Read this passage Filed comments: Connecting load and generation
A. As noted below, ZG Interconnection Service allows the Interconnection Customer to
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As noted below, ZG Interconnection Service allows the Interconnection Customer to 21 connect at the substation and voltage level of its ZG Associated Load.Read this passage Filed comments: Connecting load and generation
A. No. While the tool is particularly responsive to the needs of large loads, a ZG Associated
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While the tool is particularly responsive to the needs of large loads, a ZG Associated 11 Load does not have to be a large load. 12 Q.Read this passage
A. Yes. MISO will process the ZGIA Interconnection Requests outside of its Definitive
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MISO will process the ZGIA Interconnection Requests outside of its Definitive 15 Planning Phase using a serial “first-come, first-served” approach based on the date and 16 time the application was submitted.Read this passage
A. Among other elements, The ZG Interconnection Study includes a review of the control
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Among other elements, The ZG Interconnection Study includes a review of the control 2 equipment proposed by the Interconnection Customer to determine whether the proposed 3 configuration, equipment, and/or operating procedures are sufficient to prevent injections 4 onto the Transmission System…Read this passage
A. The Transient Tolerance Window is a requirement for the ZG Resource to disconnect or
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Some time period must be 13 allowed for the generator to ramp down or disconnect to match the demand of the ZG 14 Associated load.Read this passage
A. The Transient Tolerance Window is limited to values less than or equal to 20 seconds in
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PLEASE DESCRIBE THE ELIGIBILITY REQUIREMENTS FOR ZG 3 INTERCONNECTION SERVICE. 4Read this passage Filed comments: Connecting load and generation
A. MISO has developed a balanced set of requirements for participation in ZGIA to ensure
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This 10 enables MISO to study the generation in connection with the ZG Associated Load and 11 verify the sufficiency of the configuration and proposed control equipment to limit 12 injections. 13 • The Interconnection Request must specify a Point of Interconnection and Point of 14 Withdrawal at the…Read this passage Filed comments: Connecting load and generation
A. Section 3.11 of the proposed GIP requires an Interconnection Request for ZG
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Section 3.11 of the proposed GIP requires an Interconnection Request for ZG 13 Interconnection Service to include a one-line diagram that includes the Generating Facility 14 and associated electrical equipment with appropriate rating and impedance information and 15 all the ZG Associated Load…Read this passage Filed comments: Connecting load and generation
A. This requirement is essential to ZG Interconnection Service due to the required electrical
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Because the ZG Interconnection Study must take place 15 before the load integration study of the ZG Associated Load, it is possible that the ZG 16 Associated Load may decide or be required to move its Point(s) of Withdrawal in some 17 way after ZG Interconnection Studies are in process or completed.Read this passage Filed comments: Connecting load and generation
A. Yes. If the project meets the eligibility requirements to enter the ZGIA interconnection
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MISO will not allow Interconnection Requests to transfer from the 9 existing interconnection queue after Decision Point 2 to avoid Phase restudies due to late 10 withdrawals, which contribute to ongoing queue delays.Read this passage Filed comments: Connecting load and generation
A. As explained previously in my testimony, Interconnection Requests seeking ZG
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As explained previously in my testimony, Interconnection Requests seeking ZG 21 Interconnection Service will be studied in a serial “first-come, first served” fashion based 22 on the order the projects were submitted.Read this passage Filed comments: Connecting load and generation
A. Working together with stakeholders, MISO developed Network Upgrade guardrails that
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Because such equipment may be the best method of limiting injections and is 6 limited in scope, we determined that otherwise viable Interconnection Requests seeking 7 ZG Interconnection Service should not be disqualified on the basis of such limited Network 8 Upgrades. 9 Q.Read this passage Filed comments: Connecting load and generation
A. No. Under this model framework, the standing MISO DPP three-phase process will not be
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This is true for several reasons. 13 First, because a ZG Resources cannot inject beyond the substation where it has a POI and 14 because it cannot be approved if it triggers the need for Network Upgrades on other parts 15 of the Transmission System, effectively limiting their potential interaction…Read this passage Filed comments: Connecting load and generation
A. MISO anticipates reviewing a variety of configurations, physical equipment, and
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MISO anticipates reviewing a variety of configurations, physical equipment, and 3 operational requirements that may independently, or in sum, prevent injections on the 4 Transmission System beyond the substation where the Point of Interconnection is located. 5 For example, the injection limitation…Read this passage Filed comments: Reliability and curtailment
A. Once the ZGIA process is approved, MISO will process the ZGIA Interconnection
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Once the ZGIA process is approved, MISO will process the ZGIA Interconnection 14 Requests using a serial “first-come, first-served” approach based on the date and time the 15 application was submitted.Read this passage
A. Because the ZG Resource can only serve its ZG Associated Load, the ZGIA process
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WILL ZG INTERCONNECTION REQUESTS GO THROUGH THE AFFECTED 12 SYSTEM EVALUATION PROCESS? 13Read this passage
A. Yes. While MISO does not anticipate a ZG Resource to cause impacts to Affected
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The language 16 proposed in Section 3.5.3 of the GIP establishes a framework for how such studies are 17 coordinated in a similar fashion as other Interconnection Requests.Read this passage
A. The ZGIA requirements are facially neutral, fuel-agnostic, and allow for the potential
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Any Interconnection customer with 6 ZG Associated Load may be studied for ZG Interconnection Service regardless of their 7 identity as long as they meet the applicable state’s legal requirements. 8 Q.Read this passage Filed comments: Connecting load and generation
A. Yes. Once a ZG project receives a ZGIA, it is eligible to participate in the replacement
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Once a ZG project receives a ZGIA, it is eligible to participate in the replacement 11 process under the same rules as other Interconnection Requests.Read this passage Filed comments: Connecting load and generation
A. Yes. Resources seeking ZG Interconnection Service will be subject to the specific local
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Resources seeking ZG Interconnection Service will be subject to the specific local 18 planning criteria of the MISO Transmission Owners.Read this passage Filed comments: Connecting load and generation
V. ZG RESOURCE PARTICIPATION IN RESOURCE ADEQUACY
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ZG RESOURCE PARTICIPATION IN RESOURCE ADEQUACY 1 Q.Read this passage Filed comments: Reliability and curtailment
A. As detailed in MISO’s Information Report on Resource Adequacy submitted on June 18,
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As detailed in MISO’s Information Report on Resource Adequacy submitted on June 18, 4 2026, in this docket, MISO continues to work diligently with the states both individually 5 and through the Organization of MISO States (“OMS”), as well as its member utilities, to 6 support resource adequacy for…Read this passage Filed comments: Connecting load and generation
A. Yes. A ZGIA Resource can participate as a Generation Resource, Dispatchable
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A ZGIA Resource can participate as a Generation Resource, Dispatchable 19 Intermittent Resource, or Electric Storage Resource, and in some cases, as Behind the 20 Meter Generation; thereby qualifying them as a Capacity Resource.Read this passage
A. ZG Resources will be accredited like any other Capacity Resource of the appropriate
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IS A ZG RESOURCE THAT PARTICIPATES IN MISO’S RESOURCE 8 ADEQUACY CONSTRUCT SUBJECT TO A MUST OFFER REQUIREMENT? 9Read this passage
A. Yes. As a Capacity Resource, a ZG Resource will be subject to the “must offer” obligation
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As a Capacity Resource, a ZG Resource will be subject to the “must offer” obligation 10 into the MISO’s Day-Ahead Energy Markets when it clears the PRA, with the exception 11 that the must-offer obligation is limited to the expected demand of the ZG Associated Load 12 for the next Operating Day. 13…Read this passage
A. To ensure that the limitations of the ZG Resource are respected, and to prevent the potential
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To ensure that the limitations of the ZG Resource are respected, and to prevent the potential 16 for ZRC sales from a ZG Resource to a load other than the ZG Associated Load, ZGIA 17 Resources must be in a Fixed Resource Adequacy Plan (“FRAP”) or RBDC Opt-Out of 18 the Market Participant that has…Read this passage Filed comments: Reliability and curtailment
VI. ZG RESOURCE PARTICIPATION IN THE ENERGY
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ZG RESOURCE PARTICIPATION IN THE ENERGY 22 AND OPERATING RESERVE MARKETS 23 Tab C Page 38 Q.Read this passage
A. ZGIA Resources that are greater in size than 5 MW will be required to register and
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ZGIA Resources that are greater in size than 5 MW will be required to register and 3 participate as either Generation Resources, Dispatchable Intermittent Resources, or Energy 4 Storage Resources in the MISO Energy and Ancillary Service Markets.Read this passage
A. MISO proposes not to require any ZG Resource smaller than 5 MW in size to register and
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MISO proposes not to require any ZG Resource smaller than 5 MW in size to register and 15 participate as a market resource, because this is the de minimis size threshold that MISO 16 typically provides for Resource registration. 17 Q.Read this passage
A. MISO’s Day-Ahead and Real-Time markets create economically efficient dispatches to
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MISO’s Day-Ahead and Real-Time markets create economically efficient dispatches to 21 generators that account for the physical and economic capabilities of resources.Read this passage
A. Yes. A ZGIA Resource that meets the eligibility requirements can provide operating
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A ZGIA Resource that meets the eligibility requirements can provide operating 6 reserves.Read this passage
A. Yes. Reactive power does not perform the useful work of the power grid; instead, it
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Reactive power does not perform the useful work of the power grid; instead, it 15 supports the system voltage and magnetic fields necessary for reliable operation of the grid. 16 The need for reactive power varies by location and system conditions.Read this passage
VII. STAKEHOLDER PROCESS
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PLEASE DESCRIBE THE STAKEHOLDER PROCESS USED TO DEVELOP 21 THIS PROPOSAL. 22 Tab C Page 40Read this passage
A. MISO has engaged in detailed discussions with stakeholders on Large Load issues since
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At the first LLWG meeting on April 20, 2026, 17 MISO described the elements of the ZGIA proposal relating to resource adequacy and 18 markets and reliable operations, the last two elements of the proposal, and requested 19 stakeholder feedback.Read this passage Filed comments: Reliability and curtailment
A. As described above, throughout the stakeholder engagement period, MISO has solicited
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As described above, throughout the stakeholder engagement period, MISO has solicited 8 feedback from stakeholders and provided written and verbal responses to that feedback. 9 MISO’s stakeholder process has contributed to substantive design changes in MISO’s 10 filing and the collaborative process…Read this passage
A. Yes. Given both stakeholder feedback, and concerns raised in the Show Cause Order,
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MISO has not expanded the scope of ZG Interconnection Service to 3 address “proximate location” service and related matters raised in the Show Cause Order 4 because the scope of ZG Interconnection Service is core part of its design.Read this passage Filed comments: Connecting load and generation
VIII. CONCLUSION
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IN YOUR OPINION, IS MISO’S FILING JUST AND REASONABLE? 11Read this passage
A. Yes. It addresses certain specific needs that MISO, the Commission and the stakeholder
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It addresses certain specific needs that MISO, the Commission and the stakeholder 12 process identified.Read this passage
A. Yes, it does.
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Yes, it does. 21 COUNTY OF HAMILTON ) ) STATE OF INDIANA ) Affidavit of Marc Keyser Marc Keyser, being duly sworn, deposes and states that he prepared the Prepared Direct Testimony of Marc Keyser, and the statements contained therein are true and correct to the best of his knowledge and belief.Read this passage
Attachment A
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Attachment ARead this passage
Attachment A
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Attachment A Table of Stakeholder Meetings and Materials MEETING DATE MATERIALS December 3, 2025 PSC Consideration of Zero-Injection GIA January 21, 2026 PAC Consideration of Zero-Injection GIA February 25, 2026 PAC Market Participation and Registration of Co- Located Load and Generation…Read this passage Filed comments: Connecting load and generation