{"document":{"slug":"filing-er26-3552-miso-zgia-attachment-3","title":"Tab C - Testimony of Marc Keyser.pdf","issued":"2026-08-18","accession":"20260818-5152","docket":"ER26-3552-000","group":"MISO filings","filer":"Midcontinent Independent System Operator, Inc.","kind":"attachment","file":"sources/originals/20260818-5152_04.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260818-5152","parent":"filing-er26-3552-miso-zgia","sha256":"0011179ee22d74702e0ca884d88557ff9ccdaa47f59cd728d3b87b2f683b0a18","pages":48,"tokens":12958,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":2,"text":"TAB C"},{"page":2,"startToken":2,"endToken":34,"text":"Tab C \n \n \n \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \nMidcontinent Independent   \n \n \n) \n \nDocket No. ER26-___-000 \n  System Operator, Inc. \n  \n \n \n) \n \n \n \nPREPARED DIRECT TESTIMONY OF  \nMARC KEYSER \nDIRECTOR, CENTRAL REGION—EXTERNAL AFFAIRS"},{"page":3,"startToken":34,"endToken":314,"text":"Tab C \n \n \n \nPage 1 \n \n \nI. \nPROFESSIONAL BACKGROUND AND QUALIFICATIONS \n1 \nQ. \nPLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND RELATIONSHIP TO \n2 \nTHE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC. \n3 \nA. \nMy name is Marc Keyser.  I am the Director, Central Region—External Affairs for the \n4 \nMidcontinent Independent System Operator, Inc. (“MISO”).  My business address is 720 \n5 \nCity Center Drive, Carmel, IN 46032. \n6 \nQ. \nPLEASE BRIEFLY DESCRIBE YOUR EDUCATION AND PROFESSIONAL \n7 \nBACKGROUND. \n8 \nA. \nI hold a Bachelor of Science and Engineering Degree in Nuclear Engineering, a Bachelor \n9 \nof Science and Engineering Degree in Engineering Physics, and a Master of Science and \n10 \nEngineering Degree in Nuclear Engineering – Plasma Physics.  I have been employed by \n11 \nMISO since February, 2007 in a variety of different roles. I spent six years in a market \n12 \ndesign and market / operational engineering role.  As MISO worked to launch its Energy \n13 \nand Ancillary Services Markets, I led the design of the Automatic Generation Control \n14 \nSystem.  Since that time, I have held leadership roles in Client and Stakeholder Relations, \n15 \nCorporate Strategy, and Program Management.  Prior to joining MISO, I worked from \n16 \n2002-2007 in various system operation roles for Consumers Energy, an investor-owned \n17 \nutility in Michigan.  \n18 \nQ. \nPLEASE DESCRIBE YOUR CURRENT ROLE AND RESPONSIBILITIES. \n19 \nA. \nIn my current role, I provide advisory services across MISO business areas and manage \n20 \nrelationships with key MISO stakeholders across the central region of the MISO footprint.  \n21 \nGiven my length and breadth of experience, I was chosen to act as the MISO liaison to the \n22 \nnewly-formed Large Load Working Group (“LLWG”) in March 2026.  As the LLWG \n23"},{"page":4,"startToken":314,"endToken":589,"text":"Tab C \n \n \n \nPage 2 \n \n \nliaison, I coordinate MISO’s planned activities with respect to our large load stakeholder \n1 \nefforts.  Since October 2025, I have also led MISO’s effort to create and formalize the \n2 \nproposal accompanying my testimony. As part of this responsibility, I have closely \n3 \nexamined existing and proposed co-location arrangements in the MISO region and the rule \n4 \nsets that govern them.  \n5 \nQ.  \nHAVE YOU PREVIOUSLY SUBMITTED TESTIMONY IN A REGULATORY \n6 \nPROCEEDING? \n7 \nA. \nNo. This is the first testimony that I have provided in any regulatory proceeding. \n8 \nII. \nPURPOSE OF TESTIMONY \n9 \nQ. \nWHAT IS THE PURPOSE OF YOUR TESTIMONY? \n10 \nA. \nMy testimony supports two related items.  First, my testimony supports the proposed Tariff \n11 \nrevisions submitted in this docket to implement Zero Injection Generator Interconnection \n12 \nService (“ZG Interconnection Service”) and a Zero Injection Generator Interconnection \n13 \nAgreement (“ZGIA”) to govern and memorialize the terms of this service.  Second, my \n14 \ntestimony also explains how the ZGIA addresses certain findings and directives in the \n15 \nCommission’s Show Cause Order related to large load integration issued to MISO in \n16 \nDocket No. EL26-70-000 on June 18, 2026 (“Show Cause Order”).  This includes, but is \n17 \nnot limited to, how the ZGIA process aims to provide Speed to Power by increasing the \n18 \npace of generating capacity additions in the MISO region and to provide a mechanism to \n19 \nbetter evaluate the reliability impacts of co-location and similar arrangements.  In providing \n20 \nthis testimony, capitalized terms not otherwise defined herein have the meeting set forth in \n21 \nMISO’s Tariff.  \n22 \nQ. \nWHY IS THE ZGIA CONSTRUCT NEEDED? \n23"},{"page":5,"startToken":589,"endToken":895,"text":"Tab C \n \n \n \nPage 3 \n \n \nA. \nZGIA implementation is needed to: (1) provide MISO with visibility into generating \n1 \nresources that plan to connect to the Transmission System but not inject onto the \n2 \nTransmission System; and (2) the ZGIA will allow MISO to establish a framework to \n3 \nprovide the necessary studies to ensure reliability of the Transmission System, without \n4 \nsubjecting generators that are not expected to have significant system impacts to the more \n5 \nprotracted interconnection queue.  The ZGIA construct also provides a benefit to the \n6 \ninterconnection queue, because it provides a parallel path for differently situated generators \n7 \nto be studied for interconnection service.  \n8 \nQ. \nPLEASE EXPLAIN WHY THIS PROPOSAL IS TIME SENSITIVE. \n9 \nA. \nAs discussed in the Show Cause Order, the Commission has taken numerous actions in the \n10 \npast year to address unprecedented increases in requests for transmission service to serve \n11 \nlarge loads and the growing interest in the co-location of loads with generating facilities \n12 \n(i.e., co-location agreements).  These actions, coupled with the Commission ANOPR \n13 \naddressing the need to take additional actions related to the addition of large and co-located \n14 \nloads, highlight the urgent need to implement solutions to address large load integration \n15 \nand co-location arrangements in the MISO region.  \n16 \n \nMISO agrees that it is experiencing an unprecedented surge in large load additions, \n17 \nprimarily from data centers. In recognition of the urgent need to address speed to reliable \n18 \npower and associated network upgrades, MISO established the Expedited Resource \n19 \nAddition Study (“ERAS”) process to accelerate the generator interconnection process and \n20 \nimproved MTEP’s Expedited Project Review (“EPR”) process to quickly approve \n21 \ntransmission network upgrades needed to integrate large loads.  While existing processes \n22 \nhave effectively integrated new large loads, MISO needs to continue to evolve its approach \n23"},{"page":6,"startToken":895,"endToken":1164,"text":"Tab C \n \n \n \nPage 4 \n \n \nand develop long-term solutions to maintain reliability while enabling accelerating load \n1 \ngrowth. \n2 \nThis accelerating load growth poses an increasing reliability challenge to the grid, and has \n3 \nbeen discussed, documented and highlighted in various MISO and non-MISO reports.1   \n4 \nFinally, large load can have different enablement needs and pose operational challenges \n5 \nand opportunities that differ from traditional load additions.  This filing is urgently needed \n6 \nto provide an enablement path directly responsive to the specific needs of co-located \n7 \ngeneration and large loads.  As MISO continues to receive such requests, having a ZGIA \n8 \nprocess available will improve the speed, efficiency, and reliability of such integrations.  \n9 \nIII. \nTHE CURRENT STATE OF THE MISO QUEUE AND THE NEED FOR ZG \n10 \nINTERCONNECTION SERVICE \n11 \nQ. \nPLEASE DESCRIBE THE EFFECTIVENESS OF MISO’S INTERCONNECTION \n12 \nQUEUE PROCESS FOR ADDRESSING THE NEEDS OF LARGE LOADS. \n13 \nA. \nMISO’s Interconnection Queue, known as the Definitive Planning Phase (“DPP”), \n14 \nprovides a valuable tool that processes a significant volume of generation requests each \n15 \nstudy cycle.  The DPP processes most Interconnection Requests for new Generating \n16 \nFacilities and Energy storage Resources.  It will continue to be the primary tool for meeting \n17 \nmost load growth needs, including some large loads.  \n18 \n \n1  \n1.EIA - https://www.eia.gov/todayinenergy/detail.php?id=67704 , 2.Berkeley Labs report - \nhttps://bies.lbl.gov/news/berkeley-lab-report-evaluates-increase-electricity-demand-data-centers , 3. 2026 OMS \nSurvey results - https://cdn.misoenergy.org/20260604%20OMS-\nMISO%20Survey%20Results%20Workshop%20Presentation761711.pdf, 4, 2026 PRA Results - \nhttps://cdn.misoenergy.org/2026%20PRA%20Results%20Posting%2020260522%20-\n%20Corrections754715.pdf."},{"page":7,"startToken":1164,"endToken":1483,"text":"Tab C \n \n \n \nPage 5 \n \n \nHowever, the number of generator interconnection requests in the MISO queue continues \n1 \nto be extraordinary and unprecedented. As of July 2026, MISO’s generator interconnection \n2 \nqueue contains 802 active Interconnection Requests comprising 167 GW of proposed new \n3 \ngenerator interconnection capacity. This considerable volume of applications is spread \n4 \nover all five of MISO’s study regions and includes queue cycles going back to 2021.  MISO \n5 \nhas engaged in significant reform efforts to address the speed of processing the queue.  For \n6 \nexample, since MISO’s last major queue reform in 2017, MISO has made numerous \n7 \nimprovements to its queue rules.  In 2019, MISO made a filing with the Commission to \n8 \nstrengthen certain milestone and site control requirements. In 2021, MISO filed \n9 \nimprovements to its Option to Build, harm test calculation, and provisional GIA \n10 \nrequirements as well as filings to classify fuel type change requests made in the DPP \n11 \nprocess as a Material Modification and allow Interconnection Customers to request Surplus \n12 \nInterconnection Service earlier in the interconnection study process.  In 2022, MISO filed \n13 \nan innovative proposal to reduce the GIP timeline by offering enhanced flexibility and an \n14 \noptional path for Interconnection Customers to execute GIAs in under one year.  In 2023, \n15 \nduring the pendency of the Order No. 2023 process, MISO further strengthened its DPP \n16 \nprocess and worked to discourage speculative Interconnection Requests through adoption \n17 \nof an Automatic Withdrawal Penalty and further refinements of its site control \n18 \nrequirements. In addition, MISO worked with its RTO neighbors, PJM Interconnection, \n19 \nLLC (“PJM”) and Southwest Power Pool, Inc. (“SPP”), to improve affected system studies \n20 \nprocedures and requirements that are contained in MISO’s Joint Operating Agreements.  \n21 \nIn addition to these efforts, MISO and SPP developed and filed the Joint Targeted \n22 \nInterconnection Queue Study (“JTIQ”) process, which has sped the queue up considerably \n23"},{"page":8,"startToken":1483,"endToken":1792,"text":"Tab C \n \n \n \nPage 6 \n \n \nby providing an alternative to the backlogged affected systems study process with SPP \n1 \nwhile providing both more efficient solutions to the needs of multiple cycles of \n2 \nInterconnection Customers and greater up-front cost certainty regarding potentially \n3 \nsignificant affected systems costs.  In 2024 and 2025, MISO developed and filed an \n4 \ninnovative ERAS process as a temporary solution to address urgent near-term resource \n5 \nadequacy and reliability concerns due to load growth, generation retirement, and delays in \n6 \nthe interconnection process.  Beyond these filed processes, MISO has worked to develop \n7 \ninternal process and software improvements, such as integrated modeling software Suite \n8 \nof Unified Grid Analyses with Renewables (“SUGAR”), for Phase 1 DPP studies with \n9 \nplans to integrate in Phase 2 and 3.  The SUGAR software leverages powerful circuit \n10 \nsimulation methods developed to study billion-transistor electronic systems. SUGAR \n11 \nreduced DPP phase 1 cycle time significantly from the status quo as evidenced in the DPP \n12 \n2022, 2023 and 2025 cycles.  \n13 \nWhile these reforms are producing—and will continue to produce—significant \n14 \nprocess efficiencies and allow MISO to shorten the study time needed, it would not be \n15 \nfeasible or desirable to truncate the DPP to the degree needed to meet the short lead times \n16 \ndemanded by data centers and other large loads to meet their need by dates—some of which \n17 \nseek to go online within a year—without compromising the utility for the DPP for all other \n18 \ntypes of Interconnection Requests.  \n19 \nThe DPP enables system reliability by studying new generation sources for \n20 \ntechnical and operational impacts on the Transmission System and identifying and \n21 \nassigning the costs for the necessary upgrades required to connect the new resources safely \n22 \nand reliably.  However, in limited circumstances involving generation serving load at the \n23"},{"page":9,"startToken":1792,"endToken":2093,"text":"Tab C \n \n \n \nPage 7 \n \n \nsame substation or behind the same Point of Interconnection where the proposed \n1 \nconfiguration presents a minimal likelihood of impacting the Transmission System, a \n2 \nseparate, expedited study process and corresponding form of Interconnection Service is \n3 \nfeasible and needed to meet the frequently short lead times required by certain loads, \n4 \nincluding large loads associated with data centers. \n5 \nQ. \nPLEASE DESCRIBE THE RATIONALE FOR MISO’S PROPOSAL TO \n6 \nESTABLISH A NEW FORM OF INTERCONNECTION SERVICE. \n7 \nA. \nMISO is proposing a new form of interconnection service because the existing service \n8 \ntypes are studied in a manner that is inherently broader, because they study more significant \n9 \nfar reaching impacts to the Transmission System.  This type of study is unnecessarily time-\n10 \nconsuming and expensive for Interconnection Customers who seek to serve load at the \n11 \nsame substation.  \n \n \n12 \nSome Interconnection Customers—particularly those serving large loads— seek to \n13 \ninstall generation to meet the needs of adjacent large loads, do not require access to the \n14 \ntransmission system and, in fact, may never intend to inject onto the MISO Transmission \n15 \nSystem or, if they do plan on injecting, it is only to move energy to an adjacent bay of the \n16 \nsame substation.  Under the current Tariff, these Interconnection Customers are required \n17 \nto pursue at a minimum ERIS, which grants “as available” access to the full MISO \n18 \nTransmission System.  As a result, the ERIS studies must evaluate potential impacts to the \n19 \nentire MISO Transmission System.  These studies must be robust, lengthy, and often \n20 \nperformed on groups of Interconnection Requests because they can affect the same \n21 \nconstraints.  Such a study process is excessive for customers whose electrical impacts are \n22 \nconfined to a single substation or adjacent load.  \n23"},{"page":10,"startToken":2093,"endToken":2397,"text":"Tab C \n \n \n \nPage 8 \n \n \nIt would be unnecessary and burdensome to require Interconnection Customers \n1 \nwho do not plan to inject onto the Transmission System to proceed through the DPP due \n2 \nto their limited needs.  It is unnecessary for Interconnection Customers willing to commit \n3 \nto highly limited injection because the ERIS study is configured for broad “as available” \n4 \nsystem access and the Network Upgrades needed to allow such service would not be \n5 \nrequired by the limited Interconnection Customer.  Requiring Interconnection Customers \n6 \nparticipating in these limited co-location arrangements to obtain ERIS would require MISO \n7 \neither to model the impacts of these units far more narrowly than other Interconnection \n8 \nCustomers to accurately represent their impact, or to ignore the limitations on their \n9 \ninjection and model them as Interconnection Requests that are not as limited as planned.  \n10 \nThe latter approach would inflate the costs of such co-location arrangements, and the \n11 \nformer approach essentially adds delays to what can be a much narrower and faster study \n12 \nin order to maintain consistency of timing in the study group.  Neither approach is efficient \n13 \nor likely to promote the expeditious development of generation to serve adjacent large \n14 \nloads.  Despite the inefficiency of the DPP with respect to differently situated large loads, \n15 \nand the mismatch of existing interconnection service products for Interconnection \n16 \nCustomers serving a single substation or adjacent load, some form of interconnection \n17 \nservice is needed to: (1) address the actual impacts of limited injection and ensure the \n18 \nInterconnection Customer pays for any necessary upgrades associated with these limited \n19 \nimpacts; (2) validate the sufficiency of the Interconnection Customer’s proposed \n20 \nmechanisms to limit injection; and (3) memorialize commitments, including control \n21 \nequipment and operational limitations, in a binding agreement.  MISO developed ZG \n22"},{"page":11,"startToken":2397,"endToken":2677,"text":"Tab C \n \n \n \nPage 9 \n \n \nInterconnection Service and the resulting ZGIA to provide transparency through a more \n1 \ntargeted and efficient study process.  \n2 \nQ. \nPLEASE DESCRIBE THE PURPOSE OF THE ZERO INJECTION GENERATOR \n3 \nINTERCONNECTION AGREEMENT. \n4 \nA. \nThe ZGIA construct serves a number of purposes, including: (i) providing visibility into \n5 \nTransmission connected generation that does not plan to inject onto the Transmission \n6 \nSystem; (ii) providing a needed framework to confirm lack of injection and enforce \n7 \ncommitments; (iii) enabling a streamlined interconnection process for projects that do not \n8 \nhave significant system impacts; (iv) providing a lower cost Interconnection Service that \n9 \nwill be highly useful to large loads; and (v) ensuring that general requirements that should \n10 \napply to all generators connected to the Transmission System are uniformly applied. \n11 \nQ. \nPLEASE \nDESCRIBE \nHOW \nTHE \nZG \nINTERCONNECTION \nSERVICE \n12 \nREQUIREMENTS DIFFER FROM AN INTERCONNECTION REQUEST IN THE \n13 \nMISO QUEUE? \n14 \nA. \nThe ZG Interconnection Service requirements differ from those applicable to \n15 \nInterconnection Requests in the queue in several respects.  First, the resource seeking ZG \n16 \nInterconnection Service must demonstrate a documented relationship with load connected \n17 \nat the same voltage side of the same substation.  This ZG Associated Load must affirm its \n18 \nintention to be served by the ZG Resource.  As ZG Interconnection Service limits the ZG \n19 \nResource to serving only its designated ZG Associated Load, documenting this relationship \n20 \nis necessary to prevent speculative Interconnection Requests that are not tied to actual load. \n21 \nSecond, the Interconnection Customer seeking ZG Interconnection Service, while not \n22 \nlimited in the quantity of nameplate capacity of ZG Resource they choose to build, is \n23"},{"page":12,"startToken":2677,"endToken":2969,"text":"Tab C \n \n \n \nPage 10 \n \n \nlimited to requesting and being awarded Interconnection Service at a level that does not \n1 \nexceed the peak demand of the ZG Associated Load.  This helps ensure that expected \n2 \nproduction does not exceed load and therefore helps prevent injections onto the \n3 \nTransmission System.  Third, the ZG Interconnection Service Study must model the ZG \n4 \nAssociated Load when studying the Interconnection Request and confirm that the proposed \n5 \nequipment to limit injections is sufficient.  Fourth, the ZG Resource must interconnect at \n6 \nthe same substation and voltage level as the Point(s) of Withdrawal through which it will \n7 \nserve the ZG Associated Load.  Fifth, the ZG Interconnection Study must determine that \n8 \nthe ZG Resource will not require Network Upgrades beyond the substation except for \n9 \nsystem protection facilities at adjacent substations.  If all of these criteria are met, the ZG \n10 \nInterconnection study process affords an accelerated study process leading to a ZGIA \n11 \nwithin 90 days that memorializes the proposed configuration and limited injection.  \n12 \nQ. \nWHAT ARE THE KEY DISTINCTIONS BETWEEN THE STUDY PERFORMED \n13 \nUNDER THE DPP PROCESS AND THE STUDY CONDUCTED FOR A ZGIA? \n14 \nA. \nThe study performed under the DPP process differs from the ZGIA study in several \n15 \nimportant respects.  Under the DPP, Interconnection Requests are evaluated through a \n16 \nthree-phase, grouped study process that includes decisions points designed to identify and \n17 \nremove speculative projects as more information is discovered about the impact of adding \n18 \na generating resource to the Transmission System.  Because projects all impact the \n19 \nTransmission System and are studied in groups, each Interconnection Request is affected \n20 \nby higher-queued and same-group projects, introducing complexity and uncertainty, \n21 \nparticularly when withdrawals occur.  \n22"},{"page":13,"startToken":2969,"endToken":3255,"text":"Tab C \n \n \n \nPage 11 \n \n \nThe ZGIA study, in contrast, will be conducted on a serial, first-come, first-served basis, \n1 \nrather than in groups.  The ZGIA study incorporates analyses specific to the limited-\n2 \ninjection nature of the ZG Interconnection Service to ensure system reliability, including a \n3 \nrequired scenario where the ZG Associated Load trips offline.  Due to the different nature \n4 \nof the interconnection of ZG Resources, the ZGIA study framework is sensible because of \n5 \nthe minimal impacts beyond the substation and therefore can be completed on a faster \n6 \ntimeline, in parallel to the DPP. \n7 \nQ. \nWHY IS THE AMOUNT OF SERVICE REQUESTED AND AWARDED LIMITED \n8 \nTO THE PEAK DEMAND OF THE ZG ASSOCIATED LOAD AND THE \n9 \nNAMEPLATE CAPACITY OF THE ZG RESOURCE IS NOT LIMITED? \n10 \nA. \nThe service award limitation of ZG Interconnection Service serves to ensure that the \n11 \nmaximum expected energy production of the ZG Resource is no greater than the maximum \n12 \ndemand of the ZG Associated Load, and as a result, the ZG Resource does not inject more \n13 \nbroadly onto the Transmission System. The additional nameplate capacity allows the ZG \n14 \nResource to achieve sufficient accredited capacity to meet the ZG Associated Load within \n15 \nthe MISO capacity construct, where accreditation varies by resource type.  It is also \n16 \npermissible because nameplate capacity does not determine the level of Interconnection \n17 \nService.  An Interconnection Customer may not inject in excess of its Interconnection \n18 \nService level. \n19 \nQ. \nWHY DOES MISO PROPOSE TO LIMIT ZG INTERCONNECTION SERVICE \n20 \nTO ARRANGEMENTS WHERE THE ZG RESOURCE AND THE ZG \n21 \nASSOCIATED LOAD ARE LOCATED ON THE SAME VOLTAGE SIDE OF THE \n22 \nSAME SUBSTATION? \n23"},{"page":14,"startToken":3255,"endToken":3571,"text":"Tab C \n \n \n \nPage 12 \n \n \nA. \nMISO developed this requirement after extensive stakeholder discussions and considering \n1 \nvarious alternatives including both limiting ZG Interconnection Service to the same Point \n2 \nof Interconnection or, conversely, expanding it to allow the generation and ZG Associated \n3 \nLoad to be separated by one or more substations.  As part of these discussions, MISO \n4 \nreceived strong stakeholder opposition to broadening ZG Interconnection Service to \n5 \nembrace what the Show Cause Order refers to as electrically proximate load.  Stakeholders, \n6 \nincluding developers, Transmission Owners, and other entities argued that this broader \n7 \nscope was more than what was needed to enable large loads and would undermine the \n8 \nability to ensure limited injection to the rest of the Transmission System.   \n9 \nStakeholders, including those who have developed or plan to develop large loads \n10 \nfor interconnection to the MISO Transmission System, also opined that limiting ZG \n11 \nInterconnection Service to a single Point of Interconnection may unduly restrict the utility \n12 \nof the product or unnecessarily increase its cost because Interconnection Customers and \n13 \nTransmission Owners would be denied the flexibility to utilize adjacent bays at the \n14 \nsubstation for the generation and load lead lines when this is more practical or cost-\n15 \neffective than expanding the single bay that constitutes the Point of Interconnection to \n16 \naccommodate both the load and generation lead lines.  The proposed language affords a \n17 \nmodicum of flexibility while still maintaining clear and narrow limits.  \n18 \nAfter considering stakeholder feedback and precedent on generator replacement, \n19 \nMISO determined that allowing the load to connect at the same voltage level of the same \n20 \nsubstation as the generation would be electrically indistinguishable from requiring them to \n21 \nconnect behind the same Point of Interconnection and that with the appropriate equipment, \n22 \ninjection to the rest of the Transmission System could be effectively limited in both \n23"},{"page":15,"startToken":3571,"endToken":3870,"text":"Tab C \n \n \n \nPage 13 \n \n \nscenarios.  Based on these considerations and stakeholder opposition to allowing ZG \n1 \nInterconnection Service to address broader proximate load and generation configurations, \n2 \nMISO determined that the proposed scope struck the best balance for the MISO footprint \n3 \nbetween enabling large loads and protecting the Transmission System from broader \n4 \nimpacts.  \n5 \n \n \nMISO will continue to work with stakeholders on developing rules tailored to the \n6 \nmore dispersed proximate load and generation scenarios contemplated by the Show Cause \n7 \nOrder.  However, these solutions will be addressed in a separate Federal Power Act Section \n8 \n205 Filing.  The current filing does not impede that separate effort.  \n9 \nQ. \nWHY DOES MISO PROPOSE ZG INTERCONNECTION SERVICE AS A \n10 \nPERMANENT PRODUCT? \n11 \nA. \nMISO proposes ZG Interconnection Service as a permanent product because the service is \n12 \ndesigned for co-location arrangements in which generation is electrically tied to a specific \n13 \nload at the same substation and voltage level and can be prevented from injecting into the \n14 \nbroader Transmission System.  A temporary service would create unnecessary costs and \n15 \nuncertainty for generation and load in such configurations.  There are several reasons for \n16 \nthis determination.  First, allowing a permanent service will provide greater up-front \n17 \nfinancial and operational certainty to the Interconnection Customer seeking ZG \n18 \nInterconnection Service.  Second, as I testified earlier, ERIS is a broader product than is \n19 \nneeded to enable these types of arrangements.  If MISO were to make ZG Interconnection \n20 \nService temporary, this would result in the ZG Interconnection Customer that intends to \n21 \nonly continue to serve its co-located Load, later needing to pay unknown costs to go back \n22 \nthrough the queue to obtain a service that it does not need and will not use.  Third, the \n23"},{"page":16,"startToken":3870,"endToken":4181,"text":"Tab C \n \n \n \nPage 14 \n \n \nlimitations on injections to the rest of the Transmission System mitigate concerns about \n1 \nimpacts over time from the ZG Resource with ZG Interconnection Service because the \n2 \nlimitations on its injection are a core component of the product.  Should an Interconnection \n3 \nCustomer seek to change its configuration to allow broader injections, this would require \n4 \na new Interconnection Request for an appropriate service, such as ERIS or NRIS.  Fourth, \n5 \nit would not be efficient or fair to weigh down the DPP with Interconnection Requests that \n6 \nrestudy generation and load that do not need to change their previously-studied \n7 \nconfiguration because a time limit was placed on the original service type.  MISO \n8 \ndetermined that the better limitation is the prohibition on injection.  If an Interconnection \n9 \nCustomer with ZG Interconnection Service seeks to serve different load or remove the \n10 \nlimitations included in ZG Interconnection Service, it may seek ERIS or NRIS service \n11 \nthrough an appropriate Interconnection Request.  Barring such a change, the value of \n12 \nhaving a durable service-when coupled with the limited configuration options that ZG \n13 \nInterconnection Service authorizes—provides more value to the MISO footprint than \n14 \nscoping ZG Interconnection Service as a temporary but electrically broader product. The \n15 \nappropriate limiting feature for ZG Interconnection Service is the prohibition on injection \n16 \nto the Transmission System, not an arbitrary time expiration. Given that ZG \n17 \nInterconnection Service is continuously bounded by a narrow set of configurations and \n18 \noperational options and is studied to ensure it does not affect the broader Transmission \n19 \nSystem, a permanent service strikes the appropriate balance between reliability and \n20 \nadministrative efficiency.   \n21 \n \n \nTo be clear, I am not stating that a temporary service is inappropriate for more \n22 \ndispersed resource and load pairs—such as those that resemble the “proximate” \n23"},{"page":17,"startToken":4181,"endToken":4454,"text":"Tab C \n \n \n \nPage 15 \n \n \nconfigurations that the Commission describes in the Show Cause Order.  In fact, MISO \n1 \ncurrently is exploring processes that accommodate such broader configurations with \n2 \nstakeholders. \n3 \nQ. \nCAN INTERCONNECTION CUSTOMERS COMBINE ZG INTERCONNECTION \n4 \nSERVICE WITH OTHER INTERCONNECTION SERVICE TYPES? \n5 \nA. \nNo.  ZG Interconnection Service is fundamentally different from ERIS or NRIS service. \n6 \nZG Interconnection Service enables interconnection but excludes injections beyond the \n7 \nsubstation where the ZG Resource and ZG Associated Load are interconnected. (except for \n8 \ncertain inevitable transient injection scenarios that I discuss below), while ERIS allows \n9 \ninjections of a specified amount as available, and NRIS allows unrestricted injections of a \n10 \nspecified amount.  ZG Interconnection Service and the ZGIA require configurations and/or \n11 \ncontrol technology to restrict injections onto the broader Transmission System.  \n12 \nFundamentally, a resource cannot be interconnected with a prohibition on injection and \n13 \nalso have the right to inject onto the Transmission System.  For this reason, no amount of \n14 \nERIS or NRIS can be held by a Resource  at the same time that it has ZG Interconnection \n15 \nService. \n16 \nQ. \nCAN AN INTERCONNECTION CUSTOMER WITH ZG INTERCONNECTION \n17 \nSERVICE OBTAIN ERIS OR NRIS? \n18 \nA. \nYes.  An Interconnection Customer with ZG Interconnection Service is free to submit an \n19 \nInterconnection Request into MISO’s queue for ERIS and/or NRIS.  Once the \n20 \nInterconnection Customer completes studies and obtains ERIS or NRIS for its ZG \n21 \nResource, this automatically would supersede any ZG Interconnection Service that such \n22 \nZG Resource has and the parties would replace or amend the ZGIA with a GIA reflecting \n23"},{"page":18,"startToken":4454,"endToken":4786,"text":"Tab C \n \n \n \nPage 16 \n \n \nthe new service levels.  This process applies, even where the Interconnection Customer \n1 \nobtains a lesser megawatt amount of ERIS or NRIS than the ZG Interconnection Service it \n2 \npreviously had.  The reason for this is because the prohibition on injections and requirement \n3 \nfor equipment that electrically isolates the ZG Resource from the broader Transmission \n4 \nSystem is being replaced with an ability to inject at some level. In such a circumstance, the \n5 \nZG Resource would then be treated as any other Generating Facility that has obtained \n6 \nInterconnection Service below its installed capacity.  \n7 \nQ. \nPLEASE PROVIDE AN EXAMPLE OF THIS SCENARIO. \n8 \nA. \nAssume a Generating Facility obtains ZG Interconnection Service for its full 500 MW of \n9 \ninstalled capacity in order to serve a ZG Associated Load that is behind the Point of \n10 \nInterconnection of the Generating Facility.  The Generating Facility would receive a 500 \n11 \nMW ZGIA and its appendices would describe the equipment necessary to limit injection \n12 \nto the rest of the Transmission System.  Several years later, the Interconnection Customer \n13 \nof this service decides that it wants to use same Generating Facility to serve loads elsewhere \n14 \non the Transmission System at certain times when the Demand associated with its co-\n15 \nlocated load may be reduced by 300 MW.  The Interconnection Customer would be able \n16 \nto submit an Interconnection Request for 300 MW of ERIS or NRIS and proceed through \n17 \nMISO’s queue (i.e., DPP) as would any other Interconnection Request.  At the conclusion \n18 \nof the DPP, the Interconnection Customer would obtain a 300 MW GIA for ERIS or NRIS.  \n19 \nThe appendices to such GIA would describe the Generating Facility, including its installed \n20 \ncapacity, as well as any metering or other equipment required under MISO’s ordinary \n21 \nTariff processes to facilitate such service below capacity.  This would replace the \n22 \nrequirement to maintain equipment that limits all injections beyond the substation \n23"},{"page":19,"startToken":4786,"endToken":5073,"text":"Tab C \n \n \n \nPage 17 \n \n \ndescribed in the ZGIA and the corresponding descriptions of such equipment in the \n1 \nappendices.  Under such a configuration, the Generating Facility may still be allowed to \n2 \nprovide energy to the co-located load above the 300 MW Interconnection Service level \n3 \nbecause such energy would not enter the Transmission System and the GIA would \n4 \nappropriately bind such Interconnection Customer to MISO’s Tariff rules, including rules \n5 \ngoverning unauthorized use of the Transmission System.   \n6 \nQ. \nDOES THE PROCUREMENT OF TRANSMISSION SERVICE BY ZG \n7 \nASSOCIATED \nLOAD \nDIFFER \nFROM \nTHE \nPROCUREMENT \nOF \n8 \nTRANSMISSION SERVICE BY LOAD SERVED BY GENERATORS THAT \n9 \nENTER THE DPP? \n10 \nA. \nNo.  The ZGIA facilitates the interconnection of a generator at the same substation as ZG \n11 \nAssociated Load.  Like all MISO interconnection agreements, a ZGIA provides the \n12 \ninterconnection service to a resource, but does not provide Transmission Service.  Using \n13 \nlanguage already in MISO’s pro forma GIA, the ZGIA explicitly states that it does not \n14 \ngrant or otherwise convey Transmission Service to the ZG Associated Load.  The current \n15 \nfiling does not establish different rules regarding obtaining transmission service from those \n16 \nthat generally apply to load.  I am aware that the Show Cause Order contemplated changes \n17 \nto transmission service for co-located, proximately located, and other large load scenarios.  \n18 \nMISO intends to address those matters in a separate filing.  \n19 \nQ. \nPLEASE DESCRIBE HOW THE ZGIA AND ZGIA PROCESS FIT INTO MISO’S \n20 \nBROADER LARGER LOAD ENABLEMENT EFFORT. \n21 \nA. \nThe ZGIA construct is one tool to enable speed to power for generation, specifically \n22 \ngeneration that is located geographically and electrically close to the load it plans to serve.  \n23"},{"page":20,"startToken":5073,"endToken":5373,"text":"Tab C \n \n \n \nPage 18 \n \n \nA ZGIA enables these uniquely situated generators to avoid the costs and time of \n1 \nunnecessary participation in the queue, provided impacts to the rest of system can be \n2 \nisolated.  Further, the framework provides visibility into generation behavior in \n3 \ncircumstances where MISO may not otherwise have that visibility due to lack of a GIA.  \n4 \nSpeed to power is achieved because the framework allows for the ZG Associated Load – \n5 \nwhich in many cases may be a large load - to have generation modelled when being studied \n6 \nin the MISO Transmission Expansion Plan (“MTEP”).  The ZGIA construct is also a step \n7 \ntowards integrated transmission and generation studies through tighter coordination \n8 \nbetween the generation and load.  \n9 \nQ. \nPLEASE ELABORATE ON HOW THE ZGIA PROCESS PROVIDES SPEED TO \n10 \nPOWER TO LARGE LOAD ENABLEMENT. \n11 \nA.  \nOnly resources that have an accepted GIA are eligible for inclusion in MTEP studies.  \n12 \nMISO’s MTEP process–including its Expedited Project Review (“EPR”) process, that \n13 \nprovides a clear picture of network upgrade facilities and costs required to integrate a new \n14 \nload–can move on a 90-day timeline.  However, the MISO interconnection queue does not \n15 \nmove this fast.  The ZGIA process will provide an interconnection customer with an \n16 \nagreement within 90 days. With an interconnection agreement in hand, the ZGIA Resource \n17 \ncan then be modeled as an input to the subsequent MTEP (or MTEP EPR) load study for \n18 \nits ZG Associated Load.  The ZGIA Process provides a much faster timeline for studying \n19 \nlarge load integrations and creates the potential for reduced total cost of transmission \n20 \nnetwork upgrades needed to integrate the new load, given the recognition of additional \n21 \nnearby generation in the MTEP (or MTEP EPR) study. \n22"},{"page":21,"startToken":5373,"endToken":5679,"text":"Tab C \n \n \n \nPage 19 \n \n \nQ. \nDESCRIBE THE CHANGES MADE TO ATTACHMENT FF OF THE TARIFF TO \n1 \nSPECIFY THE RELATIONSHIP BETWEEN A ZG RESOURCE AND ITS ZG \n2 \nASSOCIATED LOAD. \n3 \nA. \nAttachment FF provides for, among other things, the process of studying the Network \n4 \nUpgrades needed to integrate new loads onto the Transmission System.  This process \n5 \nincludes the capability for Non-Transmission Alternatives, such as Resources (and in this \n6 \ncase, a ZG Resource) to offset the need for Network Upgrades.  In order to ensure that the \n7 \nload integration study is an accurate representation of future conditions, there must be \n8 \ncertainty that the Non-Transmission Alternative becomes operational and remains \n9 \noperational.  For this reason, language has been added to Attachment FF that requires an \n10 \nexecuted agreement between the ZG Resource and the ZG Associated Load, that the term \n11 \nof the agreement be at least five years which aligns with the MTEP planning horizon, and \n12 \nthat allows the Transmission Provider to require the delay of the in-service date of the ZG \n13 \nAssociated Load until alternate Network Upgrade solutions, needed due to the failure of \n14 \nthe ZG Resource as a Non-Transmission Alternative, can be put in place. \n15 \nQ. \nWHAT ARE THE DIFFERENCES BETWEEN MISO’S APPROACH AND SPP’S \n16 \nHILLGA APPROACH?  \n17 \nA. \nFundamentally, HILLGA and ZG Interconnection Service serve the same goal: allowing \n18 \nfor the rapid study and development of generation needed on an accelerated basis to serve \n19 \na specific load need.   Both constructs balance a need for rapid study with protection of the \n20 \nTransmission System and avoidance of negative impacts to other Interconnection \n21 \nCustomers.  Both also rely on proximity of the generation to the load to minimize impacts \n22 \nto the broader system.  In minimizing the potential for unexpected impacts to the \n23"},{"page":22,"startToken":5679,"endToken":6003,"text":"Tab C \n \n \n \nPage 20 \n \n \nTransmission System, there are two design considerations that can be scoped in relation to \n1 \neach other to achieve balance: (1) duration of service, and (2) narrowness of design scope.  \n2 \nThe more of the transmission system that is allowed to be used (i.e., the permitted electrical \n3 \nremoteness of the generation and load), the greater the potential for impacts to the system \n4 \nto change in unexpected ways.  This is because it becomes harder to truly isolate injections.  \n5 \nThe main protections against system impacts thus are reliable modelling and the \n6 \nconsistency of the generation and load to the modelling assumptions.  This is more of a \n7 \nshort-term focused solution.  The longer that service is allowed to remain, the more it \n8 \nprovides upfront cost certainty to Interconnection Customers.  But the tradeoff is that the \n9 \nsystem will change over time and impact assumptions may change with it.  Shorter term \n10 \nservice like SPP’s HILLGA allows for impacts to be mitigated or made temporary because \n11 \nthe service will be replaced with something permanent after only a few years.  A permanent \n12 \nproduct, like ZG Interconnection Service relies on tight geographical requirements (i.e., \n13 \nco-location of the ZG Resource and ZG Associated Load at the same substation) and \n14 \nisolation from the rest of the Transmission System (i.e. prevention of injection) to ensure \n15 \nthat even if the Transmission System changes over the course of decades, the impact of the \n16 \nZG Resource will remain similar to the initial impacts modeled as part of the ZGIA study \n17 \nprocess.  \n18 \nQ. \nWHY IS MISO PROPOSING THE ZGIA CONSTRUCT AS A PERMANENT \n19 \nPRODUCT INSTEAD OF A SHORTER-TERM PRODUCT? \n20 \nA. \nMISO selected the ZGIA approach to promote an efficient interconnection process and \n21 \naccelerate service to load, while also preserving equitable treatment of interconnection \n22 \ncustomers and accommodating preexisting arrangements.  Stated differently, the ZGIA \n23"},{"page":23,"startToken":6003,"endToken":6306,"text":"Tab C \n \n \n \nPage 21 \n \n \nframework balances the requirement that generators injecting onto the Transmission \n1 \nSystem be studied and appropriately mitigated with the recognition that certain on-site \n2 \ngeneration serves local load without exporting power to the broader Transmission System. \n3 \nThe ZGIA approach builds from experience in the MISO footprint and recognizes both \n4 \nstakeholder preferences and the types of co-location and near co-location configurations \n5 \nthat MISO has encountered and expects to see in the future.    \n6 \nQ. \nWHY IS IT IMPORTANT TO HAVE A GIA FOR A GENERATOR THAT DOES \n7 \nNOT PLAN TO INJECT ENERGY ONTO THE TRANSMISSION SYSTEM? \n8 \nA. \nHistorically, MISO has only rarely encountered Interconnection Customers seeking to \n9 \nconnect to the Transmission System without injecting energy.  However, with the advent \n10 \nof significant large load additions, MISO has seen these types of arrangements become \n11 \nmore common and expects this trend to continue.  Therefore, it is now important to \n12 \nimplement a service type and study process that specifically recognizes both the challenges \n13 \nand opportunities associated with large loads, leverages the increased commercial \n14 \nattractiveness of pairing generation with a specific nearby load, and tailors an \n15 \nInterconnection Service study process to their needs.  The proposed ZG Interconnection \n16 \nService and ZGIA framework provide a critical first step to better enabling large loads \n17 \nwhile also maintaining equitable interconnection principles–resource injections on the grid \n18 \nmust be studied, and their impacts to prior-queued and operational resources must be \n19 \nmitigated, and other Interconnection Requests should not be harmed. \n20 \nIf a Generating Facility is connected to MISO’s Transmission System and has the \n21 \nability to inject energy onto the Transmission System, MISO must have visibility into how \n22 \nthat Generating Facility is configured and will operate in order to determine whether the \n23"},{"page":24,"startToken":6306,"endToken":6611,"text":"Tab C \n \n \n \nPage 22 \n \n \ninterconnection poses reliability risks to the Transmission System, regardless of whether \n1 \nthe Generating Facility intends to inject energy onto the Transmission System.  Relatedly, \n2 \nwhile the owner of a Generating Facility may state an intention not to inject onto the MISO \n3 \nTransmission System, an agreement is required to ensure that such an intention becomes a \n4 \nbinding commitment to promote the reliable operation of the Generating Facility and \n5 \nprovide recourse if the Generating Facility operates contrary to its stated intent.   \n6 \nAs a practical example, MISO’s Resource Utilization team has encountered several \n7 \nsituations where the owner of a generating facility claimed that its equipment or \n8 \nconfiguration actually affirmatively prevented injections, thus removing the need for \n9 \nInterconnection Service.  However, absent a generator interconnection agreement or \n10 \nsimilar form of agreement, MISO would have no way to require the Generating Facility to \n11 \nbe constructed as represented to MISO.  This includes ensuring that sufficient protection \n12 \nequipment is in place to prevent injection onto the Transmission System, as contemplated \n13 \nby the Show Cause Order.  Given the risks to Transmission System reliability of addressing \n14 \nunauthorized injections only after they happen or attempting to impose operational \n15 \nlimitations on a Generating Facility once it is already constructed, MISO determined that \n16 \nit is both prudent and necessary to require the developers of Generating Facilities that \n17 \nconnect to the MISO Transmission System to become Interconnection Customers and \n18 \nexecute a GIA to establish necessary safeguards upfront.  However, MISO recognizes that \n19 \nthese Generating Facilities were not intended to inject energy onto the Transmission \n20 \nSystem.  It therefore was neither necessary for them to request an amount of ERIS or NRIS \n21 \nInterconnection Service above 0 MW nor fair to make them enter MISO’s queue simply to \n22"},{"page":25,"startToken":6611,"endToken":6884,"text":"Tab C \n \n \n \nPage 23 \n \n \nvalidate and memorialize a commitment not to inject.  The ZGIA provides a targeted \n1 \nsolution to this problem. \n2 \nIV. \nTHE PROPOSED ZGIA CONSTRUCT \n3 \nQ. \nPLEASE DESCRIBE ZG INTERCONNECTION SERVICE. \n4 \nA. \nZG Interconnection Service is service limited to serving specifically designated load that \n5 \nis either at the same Point of Interconnection (“POI”) or has a Point of Withdrawal \n6 \n(“POW”) on the same voltage side of the same substation as the ZGIA.  Like other forms \n7 \nof Interconnection Service in MISO, ZG Interconnection Service is not Transmission \n8 \nService and does not exempt a transmission customer, including a transmission customer \n9 \nserving a large load, from procuring Transmission Service.  \n10 \nQ. \nWHAT IS A POINT OF WITHDRAWAL AND HOW DOES IT RELATE TO THE \n11 \nZGIA? \n12 \nA. \nA Point of Withdrawal is a newly-defined term that describes the point that a Load \n13 \ninterconnects to the Transmission System.  It is the Load analog to the generation-specific \n14 \nterm “Point of Interconnection”.  It is important that this connection point is specified with \n15 \nrespect to ZG Interconnection Service, because resources are limited to taking ZG \n16 \nInterconnection Service only at the same substation and voltage level of the Point(s) of \n17 \nWithdrawal of their ZG Associated Load. \n18 \nQ. \nPLEASE EXPAND ON HOW ZG INTERCONNECTION SERVICE IS A LIMITED \n19 \nPRODUCT. \n20 \nA. \nAs noted below, ZG Interconnection Service allows the Interconnection Customer to \n21 \nconnect at the substation and voltage level of its ZG Associated Load.   ZG Interconnection \n22 \nService does not allow the Interconnection Customer to serve other load or inject energy \n23"},{"page":26,"startToken":6884,"endToken":7174,"text":"Tab C \n \n \n \nPage 24 \n \n \nonto the Transmission System for purposes other than serving the co-located ZG \n1 \nAssociated Load identified in the Interconnection Request and memorialized in the ZGIA. \n2 \nThe study requirements necessary for a ZGIA to provide ZG Interconnection \n3 \nService are robust, including obligations to implement equipment and/or operational \n4 \nprocedures to prevent injections onto the Transmission System beyond the substation \n5 \nwhere the ZG Resource and ZG Associated Load are located, and to limit any inadvertent \n6 \ninjections to a defined Transient Tolerance Window, as described below, in the event of an \n7 \nunexpected load reduction or trip. \n8 \nQ. \nWILL ZG INTERCONNECTION SERVICE BE AVAILABLE ONLY TO \n9 \nGENERATORS SERVING LARGE LOADS? \n10 \nA. \nNo.  While the tool is particularly responsive to the needs of large loads, a ZG Associated \n11 \nLoad does not have to be a large load. \n12 \nQ. \nIS THERE A LIMIT ON THE NUMBER OF ZGIA PROJECTS STUDIED PER \n13 \nCYCLE? \n14 \nA. \nYes.  MISO will process the ZGIA Interconnection Requests outside of its Definitive \n15 \nPlanning Phase using a serial “first-come, first-served” approach based on the date and \n16 \ntime the application was submitted. The first ten projects to submit applications to be \n17 \nstudied in the ZGIA process will be tentatively selected until MISO has finalized its \n18 \nscreening process of all ten projects to ensure that they meet the ZGIA eligibility \n19 \nrequirements.  After the ten projects in a cycle are finalized, the remaining projects that \n20 \napplied in the cycle will be deferred to the next available ZGIA cycle in order of submission \n21 \ntime.  This limit was developed to prevent disruption to MISO’s DPP, and to ensure that \n22 \nstaffing resources are available.  \n23"},{"page":27,"startToken":7174,"endToken":7475,"text":"Tab C \n \n \n \nPage 25 \n \n \nQ. \nPLEASE DESCRIBE HOW MISO WILL MONITOR AND LIMIT INJECTIONS. \n1 \nA. \nAmong other elements, The ZG Interconnection Study includes a review of the control \n2 \nequipment proposed by the Interconnection Customer to determine whether the proposed \n3 \nconfiguration, equipment, and/or operating procedures are sufficient to prevent injections \n4 \nonto the Transmission System beyond the voltage level and substation where the Point of \n5 \nInterconnection is located, within a Transient Tolerance Window.  \n6 \nQ. \nPLEASE DESCRIBE WHY MISO IS UTILIZING A TRANSIENT TOLERANCE \n7 \nWINDOW? \n8 \nA. \n The Transient Tolerance Window is a requirement for the ZG Resource to disconnect or \n9 \nreduce output if the ZG Associated Load trips or has a significant load reduction. In this \n10 \nevent, if the same breaker does not supply both the ZG Resource and the ZG Associated \n11 \nLoad, the Resource will not automatically disconnect along with the ZG Associated Load.  \n12 \nTherefore it is not realistic to prohibit all transient injections.  Some time period must be \n13 \nallowed for the generator to ramp down or disconnect to match the demand of the ZG \n14 \nAssociated load.  During this time, incidental flows onto the Transmission System can \n15 \noccur.  The Transient Tolerance Window provides a required time frame for the ZG \n16 \nResource to disconnect or match ZG Associated Load demand.    \n17 \nQ.  \nWHY DID MISO CHOOSE 20 SECONDS AS THE TRANSIENT TOLERANCE \n18 \nWINDOW? \n19 \nA.  \nThe Transient Tolerance Window is limited to values less than or equal to 20 seconds in \n20 \norder to align with the MTEP modeling interval of 20 seconds for transient stability \n21 \nanalysis.  This ensures that a generator will be robustly evaluated for stability impacts to \n22 \nensure that it will operate without unnecessary tripping for momentary conditions that do \n23"},{"page":28,"startToken":7475,"endToken":7733,"text":"Tab C \n \n \n \nPage 26 \n \n \nnot affect the Transmission System. Transmission Owner Local Planning Criteria could \n1 \nfurther limit the Transient Tolerance Window to values less than 20 seconds. \n2 \nQ. \nPLEASE \nDESCRIBE \nTHE \nELIGIBILITY \nREQUIREMENTS \nFOR \nZG \n3 \nINTERCONNECTION SERVICE. \n4 \nA. \nMISO has developed a balanced set of requirements for participation in ZGIA to ensure \n5 \nthat the accelerated study is utilized for projects that are commercially viable.  These \n6 \nrequirements were significantly shaped by stakeholder discussions and feedback.  As such, \n7 \nMISO is proposing the following technical requirement for ZGIA that must be met at the \n8 \ntime of application submission: The Interconnection Request must include a model and \n9 \none-line in which both the ZG Resource  and load must be independently represented.  This \n10 \nenables MISO to study the generation in connection with the ZG Associated Load and \n11 \nverify the sufficiency of the configuration and proposed control equipment to limit \n12 \ninjections.  \n13 \n• The Interconnection Request must specify a Point of Interconnection and Point of \n14 \nWithdrawal at the same voltage level of the same substation. \n15 \n• A $150,000 non-refundable D1 fee must be paid by the Interconnection Customer to \n16 \nfacilitate processing.  \n17 \n• The amount of ZG Interconnection Service applied for is limited to and shall not exceed \n18 \nthe total Demand of the ZG Associated Load for the proposed ZG Resource. \n19 \n• 100% Site Control for the ZG Resource as well as 100% Interconnection Customer’s \n20 \nInterconnection Facilities (“ICIF”) Site Control will be required when the application \n21 \nis submitted. \n22"},{"page":29,"startToken":7733,"endToken":8030,"text":"Tab C \n \n \n \nPage 27 \n \n \n• The Interconnection Request for ZG Interconnection Service shall be accompanied by \n1 \nan executed agreement evidencing that the full output of the ZG Resource for which \n2 \nZG Interconnection Service is sought is intended to be used by the entity(s) with the \n3 \nZG Associated Load with a minimum term of five years in order to allow it to be relied \n4 \nupon in MTEP. \n5 \n• The submitted Interconnection Request cannot include a request for any other type of \n6 \nInterconnection Service (e.g., ERIS or NRIS).   \n7 \n• The ZG Interconnection Studies cannot identify the need for any Network Upgrades \n8 \nbeyond the substation where the Point of Interconnection is to be located other than \n9 \nbreakers on electrically adjacent substations.  \n10 \nQ. \nHOW IS ZG ASSOCIATED LOAD IDENTIFIED AND STUDIED IN THE ZG \n11 \nINTERCONNECTION PROCESS? \n12 \nA. \nSection 3.11 of the proposed GIP requires an Interconnection Request for ZG \n13 \nInterconnection Service to include a one-line diagram that includes the Generating Facility \n14 \nand associated electrical equipment with appropriate rating and impedance information and \n15 \nall the ZG Associated Load including all Point(s) of Withdrawal and the Point of \n16 \nInterconnection of the Generating Facility to the Transmission System for the \n17 \nInterconnection Request.  It also requires a detailed power flow model for the proposed \n18 \nGenerating Facility that includes all ZG Associated Load, Point(s) of Withdrawal and the \n19 \nPoint of Interconnections for the Interconnection Request, as well as any proposed system \n20 \nprotection facilities.  Inclusion of this detailed modeling of the ZG Associated Load will \n21 \nensure that the interconnection study has flows and impacts that are relevant given the \n22 \nknown relationship and co-location of the ZG Resource and its ZG Associated Load. \n23"},{"page":30,"startToken":8030,"endToken":8338,"text":"Tab C \n \n \n \nPage 28 \n \n \nThe ZG Interconnection System Impact Study will generally follow the already established \n1 \nstudies and criteria for DPP studies (steady state, stability and short circuit). However, one \n2 \nimportant difference will be that during the ZG Interconnection System Impact Study, \n3 \nenergy from the Generating Facility is modeled as serving the ZG Associated Load rather \n4 \nthan injecting into the Transmission System as under a System Impact Study that assumes \n5 \nERIS.  However, the study will also include a scenario where the load is tripped in the \n6 \nstability analysis.  This is to ensure that the Transmission System remains reliable under \n7 \nthe scenarios where the ZG Resource is required to curtail when the ZG Associated Load \n8 \nis tripped. \n9 \nQ. \nWHY IS THE ZG INTERCONNECTION CUSTOMER REQUIRED TO MOVE \n10 \nITS POINT OF INTERCONNECTION IF THE ZG ASSOCIATED LOAD \n11 \nMOVES? \n12 \nA. \nThis requirement is essential to ZG Interconnection Service due to the required electrical \n13 \nrelationship between the ZG Resource and the ZG Associated Load, and the serial nature \n14 \nof the relevant integration studies.  Because the ZG Interconnection Study must take place \n15 \nbefore the load integration study of the ZG Associated Load, it is possible that the ZG \n16 \nAssociated Load may decide or be required to move its Point(s) of Withdrawal in some \n17 \nway after ZG Interconnection Studies are in process or completed.  Ordinarily, an \n18 \nInterconnection Customer attempting to move its Point of Interconnection after studies \n19 \nhave begun would be subject to material modification rules due to the fact that changing \n20 \nthe Point of Interconnection alters electrical flows on the Transmission System.  With ZG \n21 \nInterconnection Service, the mechanism for avoiding impacts to the rest of the \n22 \nTransmission System is requiring the Generating Facility and the ZG Associated Load to \n23"},{"page":31,"startToken":8338,"endToken":8661,"text":"Tab C \n \n \n \nPage 29 \n \n \nconnect at the same voltage level and substation with injections to the rest of the \n1 \nTransmission System restricted.  Because it is not practical to prevent the ZG Associated \n2 \nLoad from moving before its studies have even begun, it is necessary to ensure that the \n3 \nGenerating Facility follows any movement of the Load and remains at the same substation \n4 \nas the ZG Associated Load.   \n5 \nQ. \nWILL ACTIVE DPP PROJECTS BE ABLE TO TRANSFER TO A ZGIA? \n6 \nA.  \nYes.  If the project meets the eligibility requirements to enter the ZGIA interconnection \n7 \nprocess, DPP projects in active DPP cycles at or before Decision Point 2 may transfer to \n8 \nthe ZGIA process. MISO will not allow Interconnection Requests to transfer from the \n9 \nexisting interconnection queue after Decision Point 2 to avoid Phase restudies due to late \n10 \nwithdrawals, which contribute to ongoing queue delays.  If an Interconnection Request is \n11 \nbeyond Decision Point 2, then it can still drop out of the DPP process; however, it cannot \n12 \nsubmit a ZGIA until a year has passed since the withdrawal.  All projects withdrawing \n13 \nfrom the DPP process and entering ZGIA will be subject to all existing DPP penalties and \n14 \nharm calculations as outlined in the Tariff.  This approach balances flexibility for projects \n15 \nin earlier stages of the DPP to instead seek ZG Interconnection Service as the service better \n16 \nsuited to their needs while discouraging late dropouts after established DPP Decision \n17 \nPoints, which can disrupt the timing and expectations of other Interconnection Customers. \n18 \nQ. \nPLEASE DESCRIBE HOW INTERCONNECTION SERVICE GRANTED \n19 \nTHROUGH A ZGIA WILL BE STUDIED. \n20 \nA. \nAs explained previously in my testimony, Interconnection Requests seeking ZG \n21 \nInterconnection Service will be studied in a serial “first-come, first served” fashion based \n22 \non the order the projects were submitted.  It will follow a quarterly cadence established by \n23"},{"page":32,"startToken":8661,"endToken":8984,"text":"Tab C \n \n \n \nPage 30 \n \n \nproposed MISO timelines, ultimately culminating in the project receiving a ZGIA in \n1 \napproximately 90 days.  During the ZGIA model build, all Existing Generating Facilities, \n2 \nand the latest MTEP base case with all approved MTEP projects, including any recently \n3 \napproved EPR projects will be utilized as the starting point for the ZG Impact Analysis.  \n4 \nThis is the same process utilized for the DPP, except the DPP models include all higher \n5 \nqueued Interconnection Requests from early cycle and all Interconnection Requests within \n6 \nthat DPP cycle.  ZGIA studies will not include Interconnection Requests currently in the \n7 \ngenerator interconnection queue that do not have a GIA.   \n8 \nBefore every ZGIA cycle, all Interconnection Requests with a GIA approved since \n9 \nthe last base case was created will be added to the base case for the following ZGIA cycle \n10 \nbut are not included in any ongoing DPP studies.  The base case for each DPP cycle is \n11 \nnever updated once the study process is kicked off except for generation changes due to \n12 \nInterconnection Request withdraws or generator retirements.  This ensures that the \n13 \ntransmission capacity made available for DPP projects is not being taken away by ZGIA \n14 \nInterconnection Requests approved outside of the DPP cycle.   \n15 \nOnce the DPP cycle has concluded, the output from that process and any completed \n16 \nZGIA and EPR projects will be used to populate a new MTEP base case.  Any transmission \n17 \nissues identified by reconciling the cases will thus be addressed through the existing MTEP \n18 \nprocess.  The impacts from the ZGIA are expected to be minimal given the requirements \n19 \nfor ZG Interconnection Service. The next DPP cycle will then use the latest approved \n20 \nMTEP base case that has reconciled the models.  This insulates existing DPP projects from \n21 \nnegatives impacts or cost shifts due to the existence of the ZGIA process.  The contingent \n22"},{"page":33,"startToken":8984,"endToken":9288,"text":"Tab C \n \n \n \nPage 31 \n \n \nfacilities listed in the ZGIA would only be those facilities in the model used for the ZGIA \n1 \nstudy.  \n2 \nThe ZGIA study process will resemble the DPP study process and criteria with two \n3 \nimportant changes.  First, ZG Interconnection Service will not be granted if a Network \n4 \nUpgrade is required beyond the substation where the Point of Interconnection is located \n5 \nother than System Protection Facilities. Second, the study will include a simulation of the \n6 \nscenario where the ZG Associated Load trips offline.  This is to ensure that specific \n7 \nprotection schemes are validated for the ZGIA project.  These two changes are needed to \n8 \nreflect the limited nature of the ZG Interconnection Service.  \n9 \nQ. \nPLEASE EXPLAIN WHY ONLY CERTAIN NETWORK UPGRADES WILL BE \n10 \nALLOWED WITH THE ZG STUDY? \n11 \nA. \n Working together with stakeholders, MISO developed Network Upgrade guardrails that \n12 \nultimately prevent injections on the Transmission System beyond the substation where the \n13 \nPoint of Interconnection is located, and ensure that other Interconnection Customers are \n14 \nnot impacted by the interconnection of a ZG Resource.  Interconnection of a ZG Resource \n15 \nmust not require the construction of Network Upgrades except for Network Upgrades at \n16 \nthe substation of the POI, and System Protection Facilities that could be required beyond \n17 \nthe substation where the Point of Interconnection is located.  This limits the Network \n18 \nUpgrades (other than System Protection Facilities) to only those introduced as part of the \n19 \nZGIA project itself—that is, facilities needed to connect the ZG Resource to the \n20 \nTransmission System.  For example, new equipment at the bay of the Point of \n21 \nInterconnection may be required to accommodate the Resource.  The reason that system \n22 \nprotection facilities on neighboring substations are allowed is because  the reliable \n23"},{"page":34,"startToken":9288,"endToken":9577,"text":"Tab C \n \n \n \nPage 32 \n \n \noperation of the Transmission System may require installation of a breaker or similar \n1 \nequipment and, from a practical engineering perspective, the proper place for such \n2 \nequipment may be at the neighboring substation rather than the substation where the POI \n3 \nis located.  Installation of such Network Upgrades is consistent with the goal of ZG \n4 \nInterconnection Service of limiting injections and impacts to the rest of the Transmission \n5 \nSystem.  Because such equipment may be the best method of limiting injections and is \n6 \nlimited in scope, we determined that otherwise viable Interconnection Requests seeking \n7 \nZG Interconnection Service should not be disqualified on the basis of such limited Network \n8 \nUpgrades. \n9 \nQ. \nWILL ZG RESOURCES NEGATIVELY IMPACT EXISTING PROJECTS IN THE \n10 \nGENERATOR INTERCONNECTION QUEUE? \n11 \nA. \nNo.  Under this model framework, the standing MISO DPP three-phase process will not be \n12 \nimpacted by the ZG Interconnection Service Study Process. This is true for several reasons.  \n13 \nFirst, because a ZG Resources cannot inject beyond the substation where it has a POI and \n14 \nbecause it cannot be approved if it triggers the need for Network Upgrades on other parts \n15 \nof the Transmission System, effectively limiting their potential interaction with other \n16 \nInterconnection Requests.  Second, Interconnection Requests seeking ZG Interconnection \n17 \nService will not be included in ongoing DPP studies, thereby not utilizing any available \n18 \ntransmission capacity in those studies.  The normal DPP process uses the most up to date \n19 \nMTEP base case when the study is kicked off and is not modified to include later approved \n20 \nMTEP projects or ZGIAs.  The models from ZG Interconnection Studies and the DPP will \n21 \nbe reconciled through MTEP.   \n22"},{"page":35,"startToken":9577,"endToken":9877,"text":"Tab C \n \n \n \nPage 33 \n \n \nQ. \nPLEASE PROVIDE SOME EXAMPLES OF OPERATING PROCEDURES \n1 \nCONSISTENT WITH PROPOSED SECTION 3.2.5.2. \n2 \nA. \nMISO anticipates reviewing a variety of configurations, physical equipment, and \n3 \noperational requirements that may independently, or in sum, prevent injections on the \n4 \nTransmission System beyond the substation where the Point of Interconnection is located.  \n5 \nFor example, the injection limitation may be implemented through equipment controls such \n6 \nas export-limiting controls, directional relays, interlocks, and fail-safe trip logic. \n7 \nOperational requirements may include generation limits, curtailment obligations, outage \n8 \ncoordination, and restrictions on operation.  These operational requirements are in addition \n9 \nto any monitoring, testing, or maintenance requirements.  It is important to note that \n10 \nTransmission Owner Local Planning Criteria could serve to further limit the set of feasible \n11 \napproaches that the Interconnection Customer can propose to limit injections. \n12 \nQ. \nHOW WILL THE 10 PROJECTS BE SELECTED FOR THE STUDY? \n13 \nA. \nOnce the ZGIA process is approved, MISO will process the ZGIA Interconnection \n14 \nRequests using a serial “first-come, first-served” approach based on the date and time the \n15 \napplication was submitted.  The first ten projects to submit applications to be studied in \n16 \nZGIA will be tentatively selected until MISO has finalized its screening process of all ten \n17 \nprojects to ensure that they meet the ZGIA eligibility requirements.  After the ten projects \n18 \nin a cycle are finalized, the remaining projects that applied in the cycle will be deferred to \n19 \nthe next available ZGIA cycle in order of submission time.  Since only ten projects will be \n20 \nstudied at a time, serial review of the applications will expedite the review process.  MISO \n21 \nexpects the ZGIA Interconnection Requests to apply when they are ready and meet all the \n22"},{"page":36,"startToken":9877,"endToken":10181,"text":"Tab C \n \n \n \nPage 34 \n \n \nnecessary eligibility requirements to participate.  All application deadlines and ZGIA \n1 \nInterconnection Requests will be posted on the MISO public website in a timely fashion. \n2 \nQ. \nWHY DID MISO CHOOSE TO USE A OFFTAKE AGREEMENT PROCESS \n3 \nSIMILAR TO THAT USED IN THE ERAS PROCESS? \n4 \nA. \nBecause the ZG Resource can only serve its ZG Associated Load, the ZGIA process \n5 \nrequires a clear contractual relationship between the two. The set of acceptable contractual \n6 \narrangements that is currently effective for the ERAS process serves that role well, with \n7 \none exception. Since some jurisdictions allow resource ownership directly by the retail \n8 \ncustomer, an acceptable contractual arrangement could be “an acknowledgement by the \n9 \nentity that owns the ZG Associated Load that such entity is both permitted by applicable \n10 \nlaw and intends to self-supply its ZG Associated Load through using onsite generation”. \n11 \nQ. \nWILL ZG INTERCONNECTION REQUESTS GO THROUGH THE AFFECTED \n12 \nSYSTEM EVALUATION PROCESS? \n13 \nA. \nYes.  While MISO does not anticipate a ZG Resource to cause impacts to Affected \n14 \nSystems, due to the nature of the service, it is reasonable for Affected Systems to have the \n15 \nopportunity to study ZG Resources for impacts if they believe it necessary.  The language \n16 \nproposed in Section 3.5.3 of the GIP establishes a framework for how such studies are \n17 \ncoordinated in a similar fashion as other Interconnection Requests.  The affected system \n18 \nlikely would not need to engage in more than a limited review to verify that injections are \n19 \nlimited and either do not reach the affected system or are addressed through system \n20 \nprotection facilities at the neighboring substation.  The language allows flexibility for \n21 \nMISO to work with its seams partners to develop any ZG Interconnection-specific process \n22"},{"page":37,"startToken":10181,"endToken":10428,"text":"Tab C \n \n \n \nPage 35 \n \n \nrefinements that are mutually agreeable while also providing a reasonable default \n1 \nframework.  \n2 \nQ. \nHOW DID MISO ACCOUNT FOR OPEN ACCESS REQUIREMENTS WHEN \n3 \nDEVELOPING THE ZG PROCESS?  \n4 \nA. \nThe ZGIA requirements are facially neutral, fuel-agnostic, and allow for the potential \n5 \ninclusion of any resource regardless of technology.  Any Interconnection customer with \n6 \nZG Associated Load may be studied for ZG Interconnection Service regardless of their \n7 \nidentity as long as they meet the applicable state’s legal requirements. \n8 \nQ. \nCAN A RESOURCE WITH ZG INTERCONNECTION SERVICE PARTICIPATE \n9 \nIN THE REPLACEMENT PROCESS? \n10 \nA. \nYes.  Once a ZG project receives a ZGIA, it is eligible to participate in the replacement \n11 \nprocess under the same rules as other Interconnection Requests.  However, because these \n12 \nfacilities would have ZG Interconnection Service, they could only replace it with another \n13 \nGenerating Facility that has ZG Interconnection Service in the same location.  Should such \n14 \nInterconnection Customer seek a different service type, they would need to submit an \n15 \nInterconnection Request through the DPP. \n16 \nQ. \nWILL ZGIAS BE SUBJECT TO MISO’S REGIONAL PLANNING PROCESS? \n17 \nA. \nYes.  Resources seeking ZG Interconnection Service will be subject to the specific local \n18 \nplanning criteria of the MISO Transmission Owners.  These are based on applicable \n19 \nreliability standards such as NERC FAC-002 and outline the requirements that each \n20 \nTransmission Owner deems necessary to maintain local reliability within their planning \n21 \nprocesses. \n22 \n \n23"},{"page":38,"startToken":10428,"endToken":10692,"text":"Tab C \n \n \n \nPage 36 \n \n \nV. \nZG RESOURCE PARTICIPATION IN RESOURCE ADEQUACY \n1 \nQ. \nHOW DOES THE ZGIA CONSTRUCT SUPPORT RESOURCE ADEQUACY IN \n2 \nTHE MISO REGION? \n3 \nA. \nAs detailed in MISO’s Information Report on Resource Adequacy submitted on June 18, \n4 \n2026, in this docket, MISO continues to work diligently with the states both individually \n5 \nand through the Organization of MISO States (“OMS”), as well as its member utilities, to \n6 \nsupport resource adequacy for planned load growth in a manner that maintains customer \n7 \naffordability, efficiency and regional reliability.  The ZGIA construct is particularly \n8 \nresponsive to the challenges presented by large loads additions as it will facilitate the \n9 \naccelerated interconnection of generation needed to serve a specific nearby load source \n10 \nwhere broader injection onto the broader Transmission System is not needed and system \n11 \nimpacts—and corresponding Network Upgrades—can be limited to roughly the substation \n12 \nlevel.  This provides a valuable option for generation to be co-located with large loads \n13 \nwithout having to enter the DPP of MISO’s generation interconnection queue or obtain a \n14 \nform of Interconnection Service that is broader and potentially more costly than what is \n15 \nneeded. \n16 \nQ. \nCAN \nZGIAS \nPARTICIPATE \nIN \nMISO’S \nRESOURCE \nADEQUACY \n17 \nCONSTRUCT? \n18 \nA. \nYes.  A ZGIA Resource can participate as a Generation Resource, Dispatchable \n19 \nIntermittent Resource, or Electric Storage Resource, and in some cases, as Behind the \n20 \nMeter Generation; thereby qualifying them as a Capacity Resource.  Participation \n21 \neligibility and participation obligations are subject to the currently effective Tariff Module \n22 \nE-1. \n23"},{"page":39,"startToken":10692,"endToken":10974,"text":"Tab C \n \n \n \nPage 37 \n \n \nQ. \nHOW \nWILL \nA \nZG \nRESOURCE’S \nACCREDITATION \nVALUE \nBE \n1 \nDETERMINED? \n2 \nA. \nZG Resources will be accredited like any other Capacity Resource of the appropriate \n3 \ntechnology type except that a ZG Resource will offset no more than the coincident peak \n4 \ndemand of the ZG Associated Load, plus an accounting for system losses not experienced \n5 \ndue to the co-location of load and generation.  ZG Resources will not be able to offset any \n6 \nother loads, because the ZG Resource is not able to inject onto the Transmission System. \n7 \nQ. \nIS A ZG RESOURCE THAT PARTICIPATES IN MISO’S RESOURCE \n8 \nADEQUACY CONSTRUCT SUBJECT TO A MUST OFFER REQUIREMENT? \n9 \nA. \nYes.  As a Capacity Resource, a ZG Resource will be subject to the “must offer” obligation \n10 \ninto the MISO’s Day-Ahead Energy Markets when it clears the PRA, with the exception \n11 \nthat the must-offer obligation is limited to the expected demand of the ZG Associated Load \n12 \nfor the next Operating Day. \n13 \nQ.  \nHOW IS A ZG RESOURCE ABLE TO PARTICIPATE IN MISO’S RESOURCE \n14 \nADEQUACY CONSTRUCT? \n15 \nA. \nTo ensure that the limitations of the ZG Resource are respected, and to prevent the potential \n16 \nfor ZRC sales from a ZG Resource to a load other than the ZG Associated Load, ZGIA \n17 \nResources must be in a Fixed Resource Adequacy Plan (“FRAP”) or RBDC Opt-Out of \n18 \nthe Market Participant that has the Planning Reserve Margin Requirement of the ZG \n19 \nAssociated Load. Further, ZG Resource are not eligible to replace ZRCs throughout the \n20 \nPlanning Year.  \n21 \nVI. \nZG RESOURCE PARTICIPATION IN THE ENERGY  \n22 \nAND OPERATING RESERVE MARKETS \n23"},{"page":40,"startToken":10974,"endToken":11254,"text":"Tab C \n \n \n \nPage 38 \n \n \nQ. \nARE ZGIA RESOURCES REQUIRED TO REGISTER AND PARTICIPATE IN \n1 \nMISO MARKETS? \n2 \nA. \n ZGIA Resources that are greater in size than 5 MW will be required to register and \n3 \nparticipate as either Generation Resources, Dispatchable Intermittent Resources, or Energy \n4 \nStorage Resources in the MISO Energy and Ancillary Service Markets.  This requirement \n5 \nensures that ZG Resources  and their ZG Associated Loads are allocated a share of market-\n6 \ndistributed costs in proportion to the benefits received. Certain market charges such as the \n7 \nprovision of ancillary services for load, and administrative charges, are billed based on \n8 \ngross MW volumes in the Day-Ahead and Real-Time markets.  By requiring ZGIA \n9 \nResources to register as market resources, MW volumes for both load and generation will \n10 \nbe captured separately, resulting in appropriate billing of these charges under already-\n11 \napplicable Tariff rules for market settlements. \n12 \nQ. \nWHY ARE ALL ZGIA RESOURCES NOT REQUIRED TO REGISTER AND \n13 \nPARTICIPATE IN MISO MARKETS? \n14 \nA. \nMISO proposes not to require any ZG Resource smaller than 5 MW in size to register and \n15 \nparticipate as a market resource, because this is the de minimis size threshold that MISO \n16 \ntypically provides for Resource registration.  \n17 \nQ.  \nHOW WILL A ZG RESOURCE MAINTAIN ITS OUTPUT BELOW THE \n18 \nCONSUMPTION OF THE ZG ASSOCIATED LOAD WHILE RESPONDING TO \n19 \nDISPATCH INSTRUCTIONS FROM MISO? \n20 \nA.  \nMISO’s Day-Ahead and Real-Time markets create economically efficient dispatches to \n21 \ngenerators that account for the physical and economic capabilities of resources.  ZG \n22 \nResources are required to submit maximum limit offers that are at most equal to the demand \n23"},{"page":41,"startToken":11254,"endToken":11529,"text":"Tab C \n \n \n \nPage 39 \n \n \nexpectation of the ZG Associated Load. With this requirement, the Offers of a ZG Resource \n1 \nwill have to be updated throughout the Operating Day.  With this maximum limit in place, \n2 \nthe dispatch instruction from MISO will be less than or equal to the offsetting demand of \n3 \nthe ZG Associated Load, with no resulting injections. \n4 \nQ. \nCAN A ZG RESOURCE QUALIFY TO PROVIDE OPERATING RESERVES? \n5 \nA. \nYes. A ZGIA Resource that meets the eligibility requirements can provide operating \n6 \nreserves.  Operating Reserves are cleared when energy dispatches of a resource are between \n7 \nits maximum and minimum limits, and Operating Reserve deployments do not result in \n8 \nresource setpoint instructions exceeding the maximum limit.  By requiring a maximum \n9 \nlimit that is less than the demand expectation of the ZG Associated Load, operating reserve \n10 \ndeployments will not result in injections.  Again, the Offers of a ZGIA Resource will have \n11 \nto be updated throughout the Operating Day to reflect the expected demand of the ZG \n12 \nAssociated Load  \n13 \nQ. \nWILL ZG RESOURCES BE ELIGIBLE TO PROVIDE REACTIVE POWER? \n14 \nA. \nYes.  Reactive power does not perform the useful work of the power grid; instead, it \n15 \nsupports the system voltage and magnetic fields necessary for reliable operation of the grid.  \n16 \nThe need for reactive power varies by location and system conditions.  Because the \n17 \nprovision of reactive power is distinctive from the injection of real power,  ZG Resources \n18 \nwill be eligible to provide reactive power. \n19 \nVII. \nSTAKEHOLDER PROCESS \n20 \nQ. \nPLEASE DESCRIBE THE STAKEHOLDER PROCESS USED TO DEVELOP \n21 \nTHIS PROPOSAL. \n22"},{"page":42,"startToken":11529,"endToken":11823,"text":"Tab C \n \n \n \nPage 40 \n \n \nA. \nMISO has engaged in detailed discussions with stakeholders on Large Load issues since \n1 \n2024 through various stakeholder entities and workshops.  MISO first discussed Large \n2 \nLoads with stakeholders in the context of EPR process improvements at the Planning \n3 \nAdvisory Committee (“PAC”) and Planning Subcommittee (“PSC”) in 2024 and 2025.  \n4 \nMoreover, since 2024, MISO has discussed coordinating the MISO Transmission \n5 \nExpansion Plan and Definitive Planning Phases processes to accommodate Large Loads at \n6 \nthe PSC.   \n7 \n \nMISO first introduced the ZGIA concept to stakeholders at the PSC on December 3, \n8 \n2025.  At the meeting, MISO provided a high-level overview of the ZGIA concept and \n9 \nsolicited feedback from stakeholders.  MISO subsequently discussed the proposal at the \n10 \nPAC and the Large Load Working Group.  At the January 21, 2026  PAC, MISO \n11 \ndescribed how ZGIA resource configurations may lead to reduced transmission network \n12 \nupgrade needs and detailed the stakeholder feedback submitted in response to the \n13 \nDecember 3, 2025 PSC presentation.  At the February 25, 2026 PAC, MISO began laying \n14 \nout a proposal for formalizing ZGIA by providing the interconnection and planning \n15 \nelements of the proposal, the first two elements of the proposal. MISO requested \n16 \nstakeholder feedback on the proposal.  At the first LLWG meeting on April 20, 2026, \n17 \nMISO described the elements of the ZGIA proposal relating to resource adequacy and \n18 \nmarkets and reliable operations, the last two elements of the proposal, and requested \n19 \nstakeholder feedback.  MISO also provided materials outlining MISO’s response to \n20 \npreviously submitted stakeholder feedback.   \n21 \nAt the April 22, 2026 PAC, MISO shared draft Tariff language with stakeholders \n22 \nreflecting the interconnection and planning elements of the ZGIA proposal.  The draft \n23"},{"page":43,"startToken":11823,"endToken":12123,"text":"Tab C \n \n \n \nPage 41 \n \n \nTariff language included specifics that originated from stakeholder feedback, including \n1 \nlanguage ensuring that a ZGIA disconnects if the facilities connecting it to its associated \n2 \nload disconnects and language requiring ZGIA zonal resource credits to be included in a \n3 \nfixed resource adequacy plan.  MISO also provided materials outlining MISO’s response \n4 \nto previously submitted stakeholder feedback.  MISO requested stakeholder feedback on \n5 \nthe proposed draft Tariff language.  \n6 \nAt the May 14, 2026 LLWG, MISO shared draft Tariff language reflecting the elements \n7 \nZGIA proposal relating to resource adequacy and markets and reliable operations.  The \n8 \ndraft Tariff language incorporated stakeholder feedback regarding planning studies and \n9 \nmultiple Points of Injection.  Specifically, in response to stakeholder feedback regarding \n10 \nMISO’s initial proposal allowing multiple POIs, MISO proposed only allowing multiple \n11 \nPOIs if the ZGIA is located at one of the stations, i.e. Points of Withdrawal, of a large \n12 \nload.  MISO requested stakeholder feedback on the draft Tariff language.  \n13 \nAt the May 27, 2026 PAC, MISO shared updated draft Tariff language with stakeholders \n14 \non the interconnection and planning elements of the ZGIA proposal.  The draft Tariff \n15 \nlanguage incorporated stakeholder feedback, including language specifying further detail \n16 \nof the ZGIA interconnection studies, language clarifying that ZGIAs do not supersede \n17 \nstate jurisdiction, and revising the POI rules.  MISO additionally decided not to pursue \n18 \nthe campus approach in response to stakeholder feedback.  MISO requested stakeholder \n19 \nfeedback on the proposed draft Tariff language.  At the June 10, 2026 LLWG, MISO \n20 \nreviewed the final ZGIA proposal with stakeholders and provided draft Tariff language \n21 \nthat incorporated stakeholder feedback.  At the June 29, 2026 LLWG, MISO continued \n22 \nthe dialogue regarding the ZGIA proposal to provide stakeholders an opportunity to \n23"},{"page":44,"startToken":12123,"endToken":12406,"text":"Tab C \n \n \n \nPage 42 \n \n \nprovide feedback on any remaining concerns and in response to the Show Cause Order.  \n1 \nAdditional presentations were made at the July 15, 2026 PAC and the August 12, 2026 \n2 \nLLWG and updated Tariff language was presented to stakeholders on the same day.  A \n3 \ntable listing the stakeholder meetings, including links to the presentations, is provided as \n4 \nAttachment A hereto. \n5 \nQ. \nWHAT WAS MISO’S RESPONSE TO CONCERNS AND RECOMMENDATIONS \n6 \nFROM STAKEHOLDERS? \n7 \nA. \nAs described above, throughout the stakeholder engagement period, MISO has solicited \n8 \nfeedback from stakeholders and provided written and verbal responses to that feedback.  \n9 \nMISO’s stakeholder process has contributed to substantive design changes in MISO’s \n10 \nfiling and the collaborative process with stakeholders resulted in a comprehensive ZGIA \n11 \nproposal.  MISO appreciates the willingness of all its stakeholders and state regulators to \n12 \nreview and comment on this final proposal, which MISO believes reasonably \n13 \naccommodates concerns raised by stakeholders.  Due to stakeholder feedback, MISO \n14 \nmodified the ZGIA proposal by reducing the geographic scope of allowable ZGIA \n15 \ninterconnection points, the specific requirements and expectations of the ZG \n16 \nInterconnection study, and accreditation value of ZG Resources. \n17 \nQ.  \nDID MISO MODIFY ITS ZGIA PROPOSAL DUE TO THE SHOW CAUSE \n18 \nORDER ISSUED BY THE FEDERAL ENERGY REGULATORY COMMISSION? \n19 \nA.  \nYes.  Given both stakeholder feedback, and concerns raised in the Show Cause Order, \n20 \nMISO modified its proposal to add the market registration requirement for ZG Resources \n21 \ngreater than 5 MW that have a ZG Associated Load.  This change reflects appropriate cost \n22 \ncausation principles, and will ensure that Large Loads are responsible for market payments \n23"},{"page":45,"startToken":12406,"endToken":12650,"text":"Tab C \n \n \n \nPage 43 \n \n \nbased on their actual output, and not netted based on the presence of co-located generation.  \n1 \nAdditionally, the ZG Associated Load will under existing Tariff rules be required to obtain \n2 \nTransmission Service. MISO has not expanded the scope of ZG Interconnection Service to \n3 \naddress “proximate location” service and related matters raised in the Show Cause Order \n4 \nbecause the scope of ZG Interconnection Service is core part of its design.  However, ZGIS \n5 \ndoes not preclude MISO from developing other process improvements.  MISO has begun \n6 \nwork on further filings, including those that address transmission service refinements \n7 \nrelating to large load, that will complement ZGIS and address matters discussed in the \n8 \nShow Cause Order. \n9 \nVIII. CONCLUSION \n10 \nQ. \nIN YOUR OPINION, IS MISO’S FILING JUST AND REASONABLE? \n11 \nA. \nYes.  It addresses certain specific needs that MISO, the Commission and the stakeholder \n12 \nprocess identified.  The proposed new Tariff revisions address noted Commission and \n13 \nstakeholder concerns and will significantly enhance MISO’s ability to ensure resource \n14 \nadequacy and reliability needs.  The proposed Tariff revisions will enable a pathway for \n15 \ncertain large load and generation configurations to achieve speed to reliable power and \n16 \nsupport the responsible growth and use of these assets, while offering customers optimized \n17 \ntransmission solutions and greater certainty to support siting, financing, and state \n18 \ncoordination. \n19 \nQ. \nDOES THIS CONCLUDE YOUR TESTIMONY? \n20 \nA. \nYes, it does. \n21"},{"page":46,"startToken":12650,"endToken":12737,"text":"COUNTY OF HAMILTON ) \n) \nSTATE OF INDIANA \n) \nAffidavit of Marc Keyser \nMarc Keyser, being duly sworn, deposes and states that he prepared the Prepared Direct \nTestimony of Marc Keyser, and the statements contained therein are true and correct to the best \nof his knowledge and belief. \nSUBSCRIBED AND SWORN BEFORE ME, this J 'l .J,,,.. day of A1/_5u s__.f \n, 2026. \n,,,,11111111,, \nJENNIFER- L MILLER \nS-~.,.v-~.!'.lli\"':, Notary Public, State of Indiana \n.::- ~.· \n··<, \n?~:• \n~o~ --\nBoone County \n; :_SEAL,:*~ Commission Number NP0897079 \n~• /•·· ••• ·.,. ~ \nMy Commission Expires \n~,,!~:tit,,,,\" \nFebruary 22, 2033 \n)"},{"page":47,"startToken":12737,"endToken":12739,"text":"Attachment A"},{"page":48,"startToken":12739,"endToken":12958,"text":"Attachment A \nTable of Stakeholder Meetings and Materials \nMEETING DATE \nMATERIALS \nDecember 3, 2025 PSC \nConsideration of Zero-Injection GIA \nJanuary 21, 2026 PAC \nConsideration of Zero-Injection GIA \nFebruary 25, 2026 PAC \nMarket Participation and Registration of Co-\nLocated Load and Generation (PAC-2024-4): \nConsideration of Zero-Injection GIA \nApril 20, 2026 LLWG \nLarge Load Overview \n \nConsideration of Zero-Injection GIA \nResource: Adequacy Participation and \nMarkets and Reliable Operations \nApril 22, 2026 PAC \nConsideration of Zero-Injection GIA \n(Interconnection and Planning Draft Tariff \nUpdates): Market Participation and \nRegistration of Co-Located Load and \nGeneration (PAC-2024-4A) \nMay 14, 2026 LLWG \nConsideration of Zero-Injection GIA \n(Resource Adequacy, Markets & Reliable \nOperations Draft Tariff): Market Participation \nand Registration of Co-Located Load and \nGeneration (PAC-2024-4B) \n \nZGIA Q&A \nMay 27, 2026 PAC \nConsideration of Zero-Injection GIA \n(Interconnection and Planning Draft Tariff \nUpdates): Market Participation and \nRegistration of Co-Located Load and \nGeneration (PAC-2024-4A) \nJune 10, 2026 LLWG \nConsideration of Zero-Injection GIA: Market \nParticipation and Registration of Co-Located \nLoad and Generation (PAC-2024-4B) \nJune 29, 2026 LLWG \nConsideration of Zero-Injection GIA: Market \nParticipation and Registration of Co-Located \nLoad and Generation (PAC-2024-4B) \nJuly 15, 2026 PAC \nLiaison Report \nJuly 16, 2026 LLWG \nMISO Posted Items: ZGIA Market \nParticipation and Registration of Co-Located \nLoad and Generation: Consideration of Zero-\nInjection GIA (PAC-2024-4B) \nJuly 27, 2026 LLWG \nLiaison Report  \nAugust 12, 2026 LLWG \nPosted Tariff revisions"}],"sections":[{"p":1,"at":0,"title":"TAB C","method":"PDF bookmark","endPage":3,"endAt":25,"startToken":0,"endToken":38},{"p":3,"at":25,"title":"I. PROFESSIONAL BACKGROUND AND QUALIFICATIONS","method":"printed heading","endPage":3,"endAt":201,"startToken":38,"endToken":62},{"p":3,"at":201,"title":"A. My name is Marc Keyser. I am the Director, Central Region—External Affairs for the","method":"printed heading","endPage":3,"endAt":1420,"startToken":62,"endToken":252},{"p":3,"at":1420,"title":"A. In my current role, I provide advisory services across MISO business areas and manage","method":"printed heading","endPage":4,"endAt":500,"startToken":252,"endToken":392},{"p":4,"at":500,"title":"A. No. This is the first testimony that I have provided in any regulatory proceeding.","method":"printed heading","endPage":4,"endAt":591,"startToken":392,"endToken":408},{"p":4,"at":591,"title":"II. PURPOSE OF TESTIMONY","method":"printed heading","endPage":4,"endAt":669,"startToken":408,"endToken":422},{"p":4,"at":669,"title":"A. My testimony supports two related items. First, my testimony supports the proposed Tariff","method":"printed heading","endPage":5,"endAt":25,"startToken":422,"endToken":593},{"p":5,"at":25,"title":"A. ZGIA implementation is needed to: (1) provide MISO with visibility into generating","method":"printed heading","endPage":5,"endAt":771,"startToken":593,"endToken":708},{"p":5,"at":771,"title":"A. As discussed in the Show Cause Order, the Commission has taken numerous actions in the","method":"printed heading","endPage":6,"endAt":784,"startToken":708,"endToken":1010},{"p":6,"at":784,"title":"III. THE CURRENT STATE OF THE MISO QUEUE AND THE NEED FOR ZG","method":"printed heading","endPage":6,"endAt":1009,"startToken":1010,"endToken":1046},{"p":6,"at":1009,"title":"A. MISO’s Interconnection Queue, known as the Definitive Planning Phase (“DPP”),","method":"printed heading","endPage":9,"endAt":548,"startToken":1046,"endToken":1874},{"p":9,"at":548,"title":"A. MISO is proposing a new form of interconnection service because the existing service","method":"printed heading","endPage":11,"endAt":257,"startToken":1874,"endToken":2434},{"p":11,"at":257,"title":"A. The ZGIA construct serves a number of purposes, including: (i) providing visibility into","method":"printed heading","endPage":11,"endAt":1053,"startToken":2434,"endToken":2552},{"p":11,"at":1053,"title":"A. The ZG Interconnection Service requirements differ from those applicable to","method":"printed heading","endPage":12,"endAt":1247,"startToken":2552,"endToken":2873},{"p":12,"at":1247,"title":"A. The study performed under the DPP process differs from the ZGIA study in several","method":"printed heading","endPage":13,"endAt":805,"startToken":2873,"endToken":3102},{"p":13,"at":805,"title":"A. The service award limitation of ZG Interconnection Service serves to ensure that the","method":"printed heading","endPage":14,"endAt":26,"startToken":3102,"endToken":3259},{"p":14,"at":26,"title":"A. MISO developed this requirement after extensive stakeholder discussions and considering","method":"printed heading","endPage":15,"endAt":833,"startToken":3259,"endToken":3695},{"p":15,"at":833,"title":"A. MISO proposes ZG Interconnection Service as a permanent product because the service is","method":"printed heading","endPage":17,"endAt":339,"startToken":3695,"endToken":4227},{"p":17,"at":339,"title":"A. No. ZG Interconnection Service is fundamentally different from ERIS or NRIS service.","method":"printed heading","endPage":17,"endAt":1380,"startToken":4227,"endToken":4384},{"p":17,"at":1380,"title":"A. Yes. An Interconnection Customer with ZG Interconnection Service is free to submit an","method":"printed heading","endPage":18,"endAt":696,"startToken":4384,"endToken":4564},{"p":18,"at":696,"title":"A. Assume a Generating Facility obtains ZG Interconnection Service for its full 500 MW of","method":"printed heading","endPage":19,"endAt":725,"startToken":4564,"endToken":4897},{"p":19,"at":725,"title":"A. No. The ZGIA facilitates the interconnection of a generator at the same substation as ZG","method":"printed heading","endPage":19,"endAt":1659,"startToken":4897,"endToken":5041},{"p":19,"at":1659,"title":"A. The ZGIA construct is one tool to enable speed to power for generation, specifically","method":"printed heading","endPage":20,"endAt":880,"startToken":5041,"endToken":5215},{"p":20,"at":880,"title":"A. Only resources that have an accepted GIA are eligible for inclusion in MTEP studies.","method":"printed heading","endPage":21,"endAt":177,"startToken":5215,"endToken":5404},{"p":21,"at":177,"title":"A. Attachment FF provides for, among other things, the process of studying the Network","method":"printed heading","endPage":21,"endAt":1358,"startToken":5404,"endToken":5592},{"p":21,"at":1358,"title":"A. Fundamentally, HILLGA and ZG Interconnection Service serve the same goal: allowing","method":"printed heading","endPage":22,"endAt":1752,"startToken":5592,"endToken":5967},{"p":22,"at":1752,"title":"A. MISO selected the ZGIA approach to promote an efficient interconnection process and","method":"printed heading","endPage":23,"endAt":673,"startToken":5967,"endToken":6107},{"p":23,"at":673,"title":"A. Historically, MISO has only rarely encountered Interconnection Customers seeking to","method":"printed heading","endPage":25,"endAt":143,"startToken":6107,"endToken":6634},{"p":25,"at":143,"title":"IV. THE PROPOSED ZGIA CONSTRUCT","method":"printed heading","endPage":25,"endAt":232,"startToken":6634,"endToken":6647},{"p":25,"at":232,"title":"A. ZG Interconnection Service is service limited to serving specifically designated load that","method":"printed heading","endPage":25,"endAt":1432,"startToken":6647,"endToken":6841},{"p":25,"at":1432,"title":"A. As noted below, ZG Interconnection Service allows the Interconnection Customer to","method":"printed heading","endPage":26,"endAt":778,"startToken":6841,"endToken":7003},{"p":26,"at":778,"title":"A. No. While the tool is particularly responsive to the needs of large loads, a ZG Associated","method":"printed heading","endPage":26,"endAt":1004,"startToken":7003,"endToken":7047},{"p":26,"at":1004,"title":"A. Yes. MISO will process the ZGIA Interconnection Requests outside of its Definitive","method":"printed heading","endPage":27,"endAt":94,"startToken":7047,"endToken":7189},{"p":27,"at":94,"title":"A. Among other elements, The ZG Interconnection Study includes a review of the control","method":"printed heading","endPage":27,"endAt":612,"startToken":7189,"endToken":7265},{"p":27,"at":612,"title":"A. The Transient Tolerance Window is a requirement for the ZG Resource to disconnect or","method":"printed heading","endPage":27,"endAt":1499,"startToken":7265,"endToken":7413},{"p":27,"at":1499,"title":"A. The Transient Tolerance Window is limited to values less than or equal to 20 seconds in","method":"printed heading","endPage":28,"endAt":291,"startToken":7413,"endToken":7516},{"p":28,"at":291,"title":"A. MISO has developed a balanced set of requirements for participation in ZGIA to ensure","method":"printed heading","endPage":29,"endAt":871,"startToken":7516,"endToken":7876},{"p":29,"at":871,"title":"A. Section 3.11 of the proposed GIP requires an Interconnection Request for ZG","method":"printed heading","endPage":30,"endAt":922,"startToken":7876,"endToken":8178},{"p":30,"at":922,"title":"A. This requirement is essential to ZG Interconnection Service due to the required electrical","method":"printed heading","endPage":31,"endAt":489,"startToken":8178,"endToken":8423},{"p":31,"at":489,"title":"A. Yes. If the project meets the eligibility requirements to enter the ZGIA interconnection","method":"printed heading","endPage":31,"endAt":1722,"startToken":8423,"endToken":8619},{"p":31,"at":1722,"title":"A. As explained previously in my testimony, Interconnection Requests seeking ZG","method":"printed heading","endPage":33,"endAt":845,"startToken":8619,"endToken":9123},{"p":33,"at":845,"title":"A. Working together with stakeholders, MISO developed Network Upgrade guardrails that","method":"printed heading","endPage":34,"endAt":876,"startToken":9123,"endToken":9422},{"p":34,"at":876,"title":"A. No. Under this model framework, the standing MISO DPP three-phase process will not be","method":"printed heading","endPage":35,"endAt":133,"startToken":9422,"endToken":9599},{"p":35,"at":133,"title":"A. MISO anticipates reviewing a variety of configurations, physical equipment, and","method":"printed heading","endPage":35,"endAt":1111,"startToken":9599,"endToken":9735},{"p":35,"at":1111,"title":"A. Once the ZGIA process is approved, MISO will process the ZGIA Interconnection","method":"printed heading","endPage":36,"endAt":318,"startToken":9735,"endToken":9928},{"p":36,"at":318,"title":"A. Because the ZG Resource can only serve its ZG Associated Load, the ZGIA process","method":"printed heading","endPage":36,"endAt":1062,"startToken":9928,"endToken":10042},{"p":36,"at":1062,"title":"A. Yes. While MISO does not anticipate a ZG Resource to cause impacts to Affected","method":"printed heading","endPage":37,"endAt":223,"startToken":10042,"endToken":10215},{"p":37,"at":223,"title":"A. The ZGIA requirements are facially neutral, fuel-agnostic, and allow for the potential","method":"printed heading","endPage":37,"endAt":675,"startToken":10215,"endToken":10282},{"p":37,"at":675,"title":"A. Yes. Once a ZG project receives a ZGIA, it is eligible to participate in the replacement","method":"printed heading","endPage":37,"endAt":1262,"startToken":10282,"endToken":10372},{"p":37,"at":1262,"title":"A. Yes. Resources seeking ZG Interconnection Service will be subject to the specific local","method":"printed heading","endPage":38,"endAt":26,"startToken":10372,"endToken":10432},{"p":38,"at":26,"title":"V. ZG RESOURCE PARTICIPATION IN RESOURCE ADEQUACY","method":"printed heading","endPage":38,"endAt":167,"startToken":10432,"endToken":10455},{"p":38,"at":167,"title":"A. As detailed in MISO’s Information Report on Resource Adequacy submitted on June 18,","method":"printed heading","endPage":38,"endAt":1369,"startToken":10455,"endToken":10639},{"p":38,"at":1369,"title":"A. Yes. A ZGIA Resource can participate as a Generation Resource, Dispatchable","method":"printed heading","endPage":39,"endAt":105,"startToken":10639,"endToken":10708},{"p":39,"at":105,"title":"A. ZG Resources will be accredited like any other Capacity Resource of the appropriate","method":"printed heading","endPage":39,"endAt":690,"startToken":10708,"endToken":10808},{"p":39,"at":690,"title":"A. Yes. As a Capacity Resource, a ZG Resource will be subject to the “must offer” obligation","method":"printed heading","endPage":39,"endAt":1103,"startToken":10808,"endToken":10879},{"p":39,"at":1103,"title":"A. To ensure that the limitations of the ZG Resource are respected, and to prevent the potential","method":"printed heading","endPage":39,"endAt":1578,"startToken":10879,"endToken":10961},{"p":39,"at":1578,"title":"VI. ZG RESOURCE PARTICIPATION IN THE ENERGY","method":"printed heading","endPage":40,"endAt":111,"startToken":10961,"endToken":10992},{"p":40,"at":111,"title":"A. ZGIA Resources that are greater in size than 5 MW will be required to register and","method":"printed heading","endPage":40,"endAt":1090,"startToken":10992,"endToken":11144},{"p":40,"at":1090,"title":"A. MISO proposes not to require any ZG Resource smaller than 5 MW in size to register and","method":"printed heading","endPage":40,"endAt":1497,"startToken":11144,"endToken":11212},{"p":40,"at":1497,"title":"A. MISO’s Day-Ahead and Real-Time markets create economically efficient dispatches to","method":"printed heading","endPage":41,"endAt":430,"startToken":11212,"endToken":11327},{"p":41,"at":430,"title":"A. Yes. A ZGIA Resource that meets the eligibility requirements can provide operating","method":"printed heading","endPage":41,"endAt":1161,"startToken":11327,"endToken":11443},{"p":41,"at":1161,"title":"A. Yes. Reactive power does not perform the useful work of the power grid; instead, it","method":"printed heading","endPage":41,"endAt":1588,"startToken":11443,"endToken":11512},{"p":41,"at":1588,"title":"VII. STAKEHOLDER PROCESS","method":"printed heading","endPage":42,"endAt":26,"startToken":11512,"endToken":11533},{"p":42,"at":26,"title":"A. MISO has engaged in detailed discussions with stakeholders on Large Load issues since","method":"printed heading","endPage":44,"endAt":500,"startToken":11533,"endToken":12204},{"p":44,"at":500,"title":"A. As described above, throughout the stakeholder engagement period, MISO has solicited","method":"printed heading","endPage":44,"endAt":1491,"startToken":12204,"endToken":12347},{"p":44,"at":1491,"title":"A. Yes. Given both stakeholder feedback, and concerns raised in the Show Cause Order,","method":"printed heading","endPage":45,"endAt":789,"startToken":12347,"endToken":12529},{"p":45,"at":789,"title":"VIII. CONCLUSION","method":"printed heading","endPage":45,"endAt":875,"startToken":12529,"endToken":12543},{"p":45,"at":875,"title":"A. Yes. It addresses certain specific needs that MISO, the Commission and the stakeholder","method":"printed heading","endPage":45,"endAt":1588,"startToken":12543,"endToken":12645},{"p":45,"at":1588,"title":"A. Yes, it does.","method":"printed heading","endPage":47,"endAt":0,"startToken":12645,"endToken":12737},{"p":47,"at":0,"title":"Attachment A","method":"printed heading","endPage":48,"endAt":0,"startToken":12737,"endToken":12739},{"p":48,"at":0,"title":"Attachment A","method":"printed heading","endPage":48,"endAt":1703,"startToken":12739,"endToken":12958}]}