{"document":{"slug":"filing-er26-3552-miso-zgia","title":"MISO proposes a zero-injection generator interconnection agreement","issued":"2026-08-18","accession":"20260818-5152","docket":"ER26-3552-000","group":"MISO filings","filer":"Midcontinent Independent System Operator, Inc.","kind":"filing","file":"sources/originals/20260818-5152_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260818-5152","sha256":"f9c5d6e391132c81088abfb805f53bf3006d8990325cde3be59b9d32e7452eaf","pages":48,"tokens":22347,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":396,"text":"Midcontinent Independent \nSystem Operator, Inc. \n317.249-5400 \nwww.misoenergy.org \n720 City Center Drive \nCarmel, Indiana 46032 \n2985 Ames Crossing Road \nEagan, Minnesota 55121 \n1700 Centerview Drive \nLittle Rock, AR 72211 \n \nChristopher Supino \nManaging Senior Corporate Counsel \nDirect Dial:  317-517-2963 \nEmail:  csupino@misoenergy.org \n \nAugust 18, 2026 \nVIA ELECTRONIC FILING \nThe Honorable Debbie-Anne Reese  \nSecretary \nFederal Energy Regulatory Commission \n888 First Street, NE \nWashington, DC  20426 \nRe: \nMidcontinent Independent System Operator, Inc.’s  \nZero Injection Generator Interconnection Agreement \nDocket No. ER26-___-000 \n \nDear Secretary Reese: \nThe Midcontinent Independent System Operator, Inc. (“MISO”), through this filing,1 \nsubmits proposed revisions to its Open Access Transmission, Energy and Operating Reserve \nMarkets Tariff (“Tariff”),2 to establish a Zero Injection Generator Interconnection Agreement \n(“ZGIA”),3 associated study process and operational requirements, and market and resource \nadequacy rules to accommodate Zero-Injection Generation Resources (“ZG Resource”) that intend \nto serve load interconnecting at the same substation as the Generating Facility.  The ZGIA proposal \nwill help streamline the MISO generator interconnection process by providing expedited review \nof the addition of ZG Resources that have little or no impact on the Transmission System because \nthey are limited to serving load at the same substation and voltage level. \nThe ZGIA proposal is responsive to certain of the concerns raised by the Commission in \nthe Order Instituting Proceeding Under FPA Section 206 4 in Docket No. EL26-70-000 (“Show \nCause Order” or “SCO”) by proposing a permanent solution for generation resources that provides: \n(i) an interconnection service framework for generation supporting load at the same substation, \n \n1  \nThis filing is made pursuant to section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d, and Part 35 of \nthe regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 35.1, et \nseq. \n2  \nUnless otherwise indicated by the text or context of this transmittal letter, all terms used herein have the definitions \nset forth in Module A of the Tariff. \n3  \nFor the purposes of this filing, references to “ZGIA” may refer to the specific Zero Injection Generator \nInterconnection Agreement or may be used as a general reference to the processes and operational requirements \nthat are part of the proposal submitted herein. \n4  \nMidcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order” or “SCO”)."},{"page":2,"startToken":396,"endToken":846,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 2 \n \n \nincluding co-located load; (ii) a defined interconnection study processes tailored to zero-injection \nconfigurations, including co-location arrangements; (iii) potential reductions in Network Upgrade \nrequirements where a more limited form of Interconnection Service is all that is needed, and (iv) \nclear allocation of operational and planning responsibilities.  Specifically, this filing responds to \nthe Commission’s concerns by presenting a set of just and reasonable Tariff revisions setting forth \nthe generator interconnection study process and generator interconnection service applicable to \ngeneration serving co-located load.  However, MISO notes that this filing is not intended to address \nall issues raised in the Show Cause Order.   \nAs acknowledged in the Show Cause Order, MISO began development of ZG \nInterconnection Service and the ZGIA through its stakeholder process months prior to the issuance \nof the Show Cause Order.   While MISO has adapted elements of its proposed process to better \ncomply with the requirements of the Show Cause Order, this filing addresses a specific need within \nthe MISO region, adapting existing and proven processes to provide a valuable tool to address co-\nlocation concerns, including many of those raised in the Show Cause Order.  MISO therefore \nsubmits that the proposed ZG Interconnection Service construct is just, reasonable, and useful in \nthe MISO region independent of its responsiveness to the Show Cause Order.  Other issues raised \nin the Show Cause Order, including the appropriate transmission service for large and co-located \nloads and the treatment of generation serving electrically proximate large loads, will be addressed \nthrough MISO’s forthcoming large load proposals. \nMISO requests that the Tariff revisions submitted herewith be made effective October 18, \n2026, which is more than sixty (60) days—and less than one hundred twenty (120) days—from \nthe date of this submission.  As discussed below and in the supporting testimony of Mr. Keyser,5 \naction is needed in the near term to address the reliability impacts and resource adequacy needs \nassociated with the impending interconnection of Load, including the anticipated interconnection \nof significant large loads. \nI. \nEXECUTIVE SUMMARY \nA. \nBackground  \n \nThe United States is in the midst of an unprecedented energy transition.  Large load \ncustomers, including artificial intelligence (“AI”) data centers and next-generation manufacturing \ntechnologies, are driving a surge in interconnection requests.  This growth is driven primarily by \ndata center investment.6  As observed by the North American Electric Reliability Corporation \n(“NERC”), the largest contributor to this accelerated demand growth is data center additions with \n \n5  \nPrepared Direct Testimony of Marc Keyser, Director—Central Region, External Affairs, attached hereto as Tab \nC (“Keyser”) at 3-4. \n6  \nLong-Term Reliability Assessment, NERC, at 15, 25 (Jan. 2026), available at \nhttps://www.nerc.com/globalassets/our-work/assessments/nerc_ltra_2025.pdf."},{"page":3,"startToken":846,"endToken":1291,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 3 \n \n \n18 GW of data center loads projected by 2035.7  The MISO region is no exception to this energy \ntransition.  Energy-intensive loads such as data centers, manufacturing expansion, and \nelectrification are adding sustained, concentrated load at levels not seen in decades.8  While \nelectricity demand growth has been relatively flat with an annual average of just 0.5% between \n2009 and 2024, MISO is projecting a substantial increase of 1% to 2% per year through 2044, with \neven higher growth rates in the near term.9   \n \nThis growth has understandably drawn the focus of Relevant Electric Retail Rate \nAuthorities (“RERRA”), stakeholders and federal policymakers.  On January 23, 2025, President \nTrump issued an Executive Order stating, “[i]t is the policy of the United States to sustain and \nenhance America’s global AI dominance in order to promote human flourishing, economic \ncompetitiveness, and national security.”10  On July 23, 2025, an Executive Order titled \n“Accelerating Federal Permitting of Data Center Infrastructure,” the Trump Administration \nannounced its intention to pursue bold, large-scale industrial plans to incentivize critical \nmanufacturing and data center development:  \n \nWe will pursue bold, large-scale industrial plans to vault the United \nStates further into the lead on critical manufacturing processes and \ntechnologies that are essential to national security, economic \nprosperity, and scientific leadership.  These plans include artificial \nintelligence (AI) data centers and infrastructure that powers them, \nincluding high-voltage transmission lines and other equipment.  It \nwill be a priority of my Administration to facilitate the rapid and \nefficient buildout of this infrastructure by easing Federal regulatory \nburdens.11 \n \nOn October 23, 2025, the Secretary of Energy directed the Commission to consider an \nAdvance Notice of Proposed Rulemaking (“ANOPR”) focused on the timely and orderly \ninterconnection of large loads to the interstate transmission system.12  The Secretary’s \n \n7  \nLong-Term Reliability Assessment, NERC, at 15 (Jan. 2026), available at \nhttps://www.nerc.com/globalassets/our-work/assessments/nerc_ltra_2025.pdf.   \n8  \n2026 Reliability Imperative Report, MISO, at. 4 (Feb. 2026), available at \nhttps://cdn.misoenergy.org/2026%20Reliability%20Imperative%20Report744320.pdf.  \n9  \n2026 Reliability Imperative Report, MISO, at 4 (Feb. 2026), available at \nhttps://cdn.misoenergy.org/2026%20Reliability%20Imperative%20Report744320.pdf.  \n10  Executive Order 14179 of January 23, 2025, “Removing Barriers to American Leadership in Artificial \nIntelligence,” Federal Register 90 (20) 8741, www.govinfo.gov/content/pkg/FR-2025-01-31/pdf/2025-\n02172.pdf.  \n11  Accelerating Federal Permitting of Data Center Infrastructure, Executive Order 14318, 90 FR 35385 (July 23, \n2025), https://www.whitehouse.gov/presidentialactions/2025/07/accelerating-federal-permitting-of-data-center-\ninfrastructure/.  \n12  Letter from C. Wright, Secretary of Energy, to the Federal Energy Regulatory Commission, Docket No. RM26-\n4-000 (Oct. 23, 2025)."},{"page":4,"startToken":1291,"endToken":1707,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 4 \n \n \ncorrespondence to the Commission in support of the ANOPR emphasized the importance of the \ntimely, orderly, and non-discriminatory integration of large loads:   \n \nTo usher in a new era of American prosperity, we must ensure all \nAmericans and domestic industries have access to affordable, \nreliable, and secure electricity.  To do this, large loads, including AI \ndata centers, served by public utilities must be able to connect to the \ntransmission system in a timely, orderly, and non-discriminatory \nmanner.  This is an urgent issue that requires prompt attention.13 \n \nOn June 18, 2026, the Commission issued the Show Cause Order.14  The Show Cause Order \nrecognizes the unprecedented increase in requests for transmission service to serve large loads \nalong with the growing interest in co-location arrangements to serve those large loads.15  The Show \nCause Order cites a lack of clarity and consistency in Regional Transmission Organizations’ or \nIndependent System Operators’ tariffs regarding the rates, terms, and conditions of service that \napply to flexible large loads, co-location arrangements, load with behind the meter generation, and \ngenerating facilities with electrically proximate large load or co-located load.16  Ultimately, the \nShow Cause Order requires MISO to show cause as to why the Tariff remains just and reasonable \nwithout provisions addressing certain large load and co-location issues or, in the alternative, \nexplain what changes to the Tariff would remedy the Commission’s concerns.17  \n \n \nB. \nAddressing the Influx of Large Loads in the MISO Region \n \nThe MISO region is experiencing a significant influx of large load additions—primarily \nfrom data centers, cryptocurrency miners, and other processes that require larger load \ninterconnections.  Large load growth presents a unique challenge because MISO must balance \nmultiple objectives simultaneously.  MISO seeks to facilitate economic development and timely, \ncost-effective access to the Transmission System while maintaining reliability and operational \nintegrity.   \n \nMISO, its member states, and stakeholders are developing multiple initiatives to address \nevolving system conditions and to support efficient interconnection prior to and after the issuance \nof the Show Cause Order.  In recognition of urgent needs to address large load and co-located load \ngrowth, MISO established a temporary, targeted Expedited Resource Addition Study (“ERAS”) \nprocess to accelerate the generator interconnection process limited to generators necessary to serve \ncertain critical, near-term load additions.   \n \n13  Letter from C. Wright, Secretary of Energy, to the Federal Energy Regulatory Commission, Docket No. RM26-\n4-000 (Oct. 23, 2025).  \n14  See generally SCO.  \n15  Id. at P 1.  \n16  Id.   \n17  Id. at P 3."},{"page":5,"startToken":1707,"endToken":2191,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 5 \n \n \n \nIn addition, MISO improved the MISO Transmission Expansion Plan’s (“MTEP”) \nExpedited Project Review (“EPR”) process to quickly study Network Upgrades needed to support \nlarge loads.  MISO also initiated the MISO-SPP Joint Targeted Interconnection Queue Study \n(“JTIQ”) which aims at building transmission network upgrades along the MISO-SPP seams to \nenable large amounts of new generation.  While these initiatives provide important benefits, they \nneither fully address the reliability and operational challenges associated with accelerating large \nload growth, nor do they address all concerns raised in the Show Cause Order.  Accordingly, MISO \nrecognizes that additional Tariff-based solutions are necessary to establish clear reliability \nexpectations, improve operational visibility, and facilitate timely integration of large loads in a \nmanner that is both reliable and non-discriminatory.  These solutions must also consider and \naddress the unique planning and operational characteristics of large load interconnection customers \nand hyperscale data centers, in particular.  The ZGIA is one of these forthcoming solutions. \n \nMISO’s ZGIA proposal is well aligned with the Commission’s goals and objectives of \ntransparency, affordability and reliability.  This proposal is one element in MISO’s response to the \nCommission’s desire for prompt action to address the rapid growth of large loads, related \ninterconnection requests, and a surge in interest in co-located generation.  The Show Cause Order \naddresses the unprecedented increase in requests for transmission service to serve large load, as \nwell as the growing interest in the co-location of loads with generation facilities (i.e., co-location \narrangements), while acknowledging the challenges associated with providing the transmission \nservice necessary to reliably serve the ongoing influx of large loads.18  The Show Cause Order \nstates that MISO has not yet proposed Tariff revisions to address the challenges associated with \nthe integration of large and co-located loads.19  The Show Cause Order requires MISO to show \ncause as to how its Tariff remains just and reasonable, or to explain what changes would remedy \nthe Commission’s concerns.20   \n \nMISO is moving quickly on proposals that had been previously incorporated into the Large \nLoad Working Group (“LLWG”) workplan and is also engaging with stakeholders, including the \nOrganization of MISO States, Inc. (“OMS”), in an expedited manner to develop the broader set of \nsolutions outlined in the August 3, 2026, motion filed by MISO and the MISO Transmission \nOwners to hold all proceedings related to the Show Cause Order in abeyance for 90 days.21  The \nAbeyance Motion explained that MISO and the MISO Transmission Owners required additional \ntime to continue the stakeholder process and submit FPA section 20522 filings that address the \n \n18  SCO at P 1.  \n19  Id. at P 2.  \n20  Id. at P 3.  \n21  Motion of the Midcontinent Independent System Operator, Inc. and the MISO Transmission Owners to Hold \nProceeding in Abeyance and Request for Shortened Comment Period and Expedited Treatment, Docket No. \nEL26-70-000 (Aug. 3, 2026) (“Abeyance Motion”).   \n22  16 U.S.C. § 824d."},{"page":6,"startToken":2191,"endToken":2664,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 6 \n \n \nconcerns raised in the Show Cause Order.23  The Commission granted the 90-day abeyance \nrequested in the Abeyance Motion on August 14, 2026.24    \n \nThe Abeyance Motion emphasized that MISO, in collaboration with stakeholders and the \nOMS, has been working to identify and implement solutions to facilitate speed to reliable power.25  \nThese efforts include two already-implemented initiatives: (1) the one-time, targeted ERAS \nprocess to accelerate generator interconnection for near-term resource adequacy needs; and (2) \nimproving the MTEP EPR process to enable the rapid study and approval of transmission upgrades \nnecessary for the addition of large loads.26  MISO explained that it also created the LLWG to \nprovide a dedicated and consolidated stakeholder forum for prioritizing and focusing efforts to \nboth identify critical issues and develop corresponding solutions to integrate large loads reliably \nand cost effectively.27   \n \nMISO has developed a prioritized work plan to accelerate consideration of the challenges \npresented by large load growth in the MISO region through its stakeholder process.28  This process \nhas resulted in the development of groups of potential solutions and improvements to various \nMISO processes, which MISO intends to submit for Commission review in a series of filings.29  \nThe present filing represents the first of this series.  \n \nC. \nThe ZGIA Proposal Supports Co-Location and Provides Speed to Power \n \nCo-location has been widely recognized as one of the most valuable tools in achieving \n“speed to power” in a reliable and efficient manner and MISO’s ZGIA co-location solution has \nbeen prioritized within the LLWG’s efforts.  The ZGIA and related study process proposed in this \nfiling is the first of the proposed solutions to come from the LLWG.  The ZGIA construct is the \nproduct of significant effort by MISO, the OMS, and stakeholders that began prior to the Show \nCause Order and was refined in response to the Show Cause Order.  The ZGIA framework will \naddress not only large load interconnections and co-located generation but it also will help \nstreamline the interconnection process for Interconnection Customers serving co-located load.30  \n \n23  Abeyance Motion at 2.  \n24  Midcontinent Independent System Operator, Inc., et. al., 196 FERC ¶ 61,133 (August 14, 2026) (“Abeyance \nOrder”). \n25  Abeyance Motion 3.  \n26  Id.  \n27  Id.  \n28  Id. at 4.  \n29  Id.   \n30  MISO uses the term “co-location” in this filing to refer to arrangements where the Load’s Point of Withdrawal \nand the Generating Facility’s proposed Point of Interconnection are located at the same substation and at the same \nvoltage level.  These may be at the same Point of Interconnection or involve lead lines in adjacent bays.  MISO \nrecognizes that this is a slightly broader definition than that used by the Commission in the Show Cause Order.  \nAs explained below, after extensive discussions, MISO determined that its proposed scope is a better fit for the"},{"page":7,"startToken":2664,"endToken":3177,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 7 \n \n \nHence, the ZGIA proposal serves two important purposes.  First, the ZGIA framework addresses \nseveral of the Commission’s concerns raised in the Show Cause Order.  Second, the ZGIA \nframework addresses improvements to the interconnection process in addition to the Commission's \nstated concerns, such that it will have independent benefits for all interconnection customers.   \n \nMISO explored several potential scopes for its ZG Interconnection Service product through \nthe stakeholder process including limiting it to load and generation connecting to the Transmission \nSystem behind the same Point of Interconnection and expanding it to encompass load located \n“proximate” to generation.  After extensive consideration, MISO determined that limiting ZG \nInterconnection Service to load and generation behind the same Point of Interconnection is too \nstrict an approach for the MISO Transmission System as it would exclude configuration options \nthat MISO is aware that developers are considering for adjacent load and generation where \ninjections to the broader Transmission System can be effectively limited and monitored.  \nFollowing further discussion and evaluation with stakeholders, MISO also determined that \nexpanding the ZGIA and ZG Interconnection Service construct to accommodate “electrically \nproximate” load and generation would have raised novel reliability and transmission service \nchallenges that would not be easily resolved in a timely manner for the unique processes that \nunderpin MISO’s transmission and interconnection services.  In addition, stakeholders raised \nconcerns that extending the proposal to serving proximate load beyond the same substation could \nresult in the potential for retail wheeling and conflict with retail regulatory constructs.  Rather than \ndelay a significant and important tool to support co-location, MISO chose not to incorporate a \n“proximate” load solution in this initial filing.31  Accordingly, this filing is limited to addressing \ngeneration and load at the same substation and does not attempt to resolve the separate issues \npresented by generation serving electrically proximate large load.  MISO’s forthcoming Load \nAddition Resource Study (“LARS”) process is intended to address those issues by providing a \ncoordinated study framework for load additions and associated new generation that are electrically \nproximate but do not satisfy the ZGIA’s narrower requirements. \n \nThis filing proposes Tariff revisions to establish the ZGIA construct as a Tariff-defined \nprocess to take advantage of the benefits of co-location of generation and load.  The ZGIA \nframework creates a path for a planned generator that will connect at the same substation and \nvoltage level as existing or proposed load (including large loads) to interconnect quickly, with \nstrict limitations on injections further onto the Transmission System, which and correspondingly \nreduce potential for Transmission System Impacts and expensive Network Upgrade.  Load \ncustomers, including large load customers, will benefit from ZGIA interconnection studies that \nrecognize on-site generation, potentially reducing network upgrade requirements to interconnect.  \nAs discussed in more detail below, the proposed ZGIA framework includes a new load at the same \nsubstation and voltage level as a generation resource.  The figure below depicts load taking firm-\n \ntypes of interconnection arrangements that MISO has seen and expects it will continue to see in accommodating \nthe integration of larger loads in its region. \n31  Keyser at 11-14, 19-20."},{"page":8,"startToken":3177,"endToken":3543,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 8 \n \n \nservice Network Integration Transmission Service (“NITS”).32  The load is permitted to withdraw \nand take energy delivery from other system resources, but the new generator with ZGIA \nInterconnection Service cannot inject past the interconnecting substation, and netting of the load \nand generation for transmission service or market settlement purposes is not allowed:33 \n \n \n \n \nWith these proposed Tariff changes, the ZGIA proposal will partially address several of the \nissues raised by the Commission related to co-location of generation and large loads by proposing \na permanent solution for generation resources seeking to interconnect to the Transmission System \nat the same substation as an associated load.  In particular, the ZGIA partially addresses the \nCommission’s concerns regarding the absence of a generator interconnection service and study \nprocess tailored to the operational characteristics of generation serving co-located load, including \na study process that recognizes the potentially reduced Transmission System impacts where \ngeneration is limited to serving its associated load.34  As visualized below, because the ZGIA \nprocess can take place quickly, with the ZG Impact Assessment completed within 90 Calendar \nDays, the subsequent MTEP load study can result in a more optimal and potentially reduced set of \nnetwork upgrades needed to reliably serve the load.  The subsequent proposal to address the case \nof electrically proximate load and generation, LARS, will further address the Commission’s \n \n32  This filing does not establish new rules regarding transmission service.  However, existing Tariff rules require \nLoad to obtain transmission service in order to be served using the Transmission System.  For Load served by a \nLoad Serving Entity in the MISO region, the transmission service utilized is almost always NITS. \n33  Consideration of Zero-Injection GIA, MISO Planning Advisory Committee (Jan 21, 2026), available at \nhttps://cdn.misoenergy.org/20260121%20PAC%20Item%2009%20Market%20Participation%20and%20Registr\nation%20of%20Co-Located%20Load%20and%20Generation%20(PAC-2024-4)736238.pdf. MISO notes that \nthis description explains how ZGIA will serve large loads and fit within existing Tariff constructs.  This filing \ndoes not prejudice MISO’s ability to revise transmission service rules through other 205 filings responding to the \nShow Cause Order. \n34  See SCO at PP 58, 94, 113, 115, 117 and 118."},{"page":9,"startToken":3543,"endToken":3840,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 9 \n \n \nconcerns through a process that can potentially reduce the set of Network Upgrades needed to \nserve both the load and the resource. \n \n \n \n \nThe ZGIA proposal represents another critical tool to help support the timely, reliable, cost-\neffective integration of new large loads into the MISO system.  It efficiently leverages existing \nMISO processes and practices to serve as a robust incremental solution.  MISO notes that this is \none of several upcoming Tariff solutions that will be filed with the Commission to collectively \naddress the issues raised in the Show Cause Order.  MISO appreciates the guidance and direction \nprovided in the Show Cause Order and is committed to continuing its collaborative efforts with \nthe states and stakeholders to deliver additional tools to meet the unique challenges associated with \nintegrating large loads.   \n \nD. \nAnticipated Complementary Solutions \n \nMISO has been advancing a coordinated set of solutions designed to balance speed to \npower, fairness, and, most importantly, reliability.  In particular, MISO has developed two solutions \nthat are responsive to the Commission’s concerns noted in the Show Cause Order surrounding the \ninterconnection and study processes for co-location arrangements and service of proximate large \nloads.   \n \nThe ZGIA proposal identified in this filing is the product of a stakeholder process that \nbegan prior to the Show Cause Order to address not only large load interconnection and co-location \nissues, but also improvements to the interconnection process in general.  By formalizing the ZGIA \nconstruct in the Tariff,35 MISO can provide a limited, structured option to support large load \nintegration, co-location, and refinements to the interconnection process through: \n \n35  MISO notes that it has accommodated zero-injection generator interconnection arrangements in limited \ncircumstances in the past using existing Tariff mechanisms, including filing non-conforming generator \ninterconnection agreements with the Commission."},{"page":10,"startToken":3840,"endToken":4333,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 10 \n \n \n \n• An interconnection service framework for generation that is supporting co-located \nload; \n• Defined interconnection study processes tailored to zero-injection configurations; \n• Potentially reduced network upgrade requirements where appropriate; and \n• Clear allocation of operational and planning responsibilities. \nThis construct enables a pathway for certain large load configurations to achieve speed to \nreliable power while maintaining system reliability.   \n \nThe ZGIA framework represents an initial step in a broader set of solutions to address the \nconcerns expressed in the Show Cause Order and to meet the evolving needs of the MISO region.  \nThese ongoing efforts reflect the iterative nature of MISO’s response to rapidly changing load \nconditions and the need for continued stakeholder collaboration.  To that end, as noted above, \nMISO will be submitting additional proposals to further address large load integration as discussed \nin the Abeyance Motion. \n \nIn addition to the ZGIA proposal submitted herein, MISO is also developing through the \nstakeholder process at the LLWG its Load Addition and Resource Study process.  LARS will assess \nthe transmission infrastructure needed to meet new large loads and new generation in an efficient \nprocess that can be executed on a shorter timeline, further supplementing the opportunities \navailable for members to facilitate new large spot loads effectively.  This process is expected to \nposition MISO and its members to ensure resource adequacy and protect customers from \nunnecessary investments relating to spot large load siting. \n \nMore specifically, LARS will analyze generation and transmission using the same study \nassumptions applied in the standard generator interconnection process and MISO’s MTEP.  The \nstudies will be run in parallel, and will finish at approximately the same time—within 120 days—\nwith the load/transmission model incorporating both the planned generation and planned load.36  \nLARS, as currently conceived, will address similar issues to those the Show Cause Order identified \nrelated to interconnection customers serving electrically proximate large load or co-located load.37  \nThus, while the instant ZGIA filing addresses the generator interconnection service and study \nframework for generation serving ZG Associated Load, LARS will address the distinct study issues \npresented by new generation and large load that are electrically proximate but are not eligible for \nZG Interconnection Service.  It is important to note that neither the ZGIA construct nor LARS \nproposal include new transmission service products specific to serving co-located or proximate \nload or address flexible large loads willing to limit transmission service.  Transmission service \n \n36  MISO included a description of this Joint Study Process in its Informational Report submitted in this docket on \nJuly 20, 2026. \n37  SCO at P 113 (preliminarily finding that MISO’s Tariff may be unjust and unreasonable because it does not contain \nprovisions that will allow an interconnection customer to seek the generator interconnection service(s) that reflects \nthe operational dynamics of serving either: (1) an electrically proximate large load; or (2) a co-located load, that \nhas a high peak load (i.e., large co-located loads that are 50 MW or greater))."},{"page":11,"startToken":4333,"endToken":4870,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 11 \n \n \nproducts to address related concerns raised in the Show Cause Order will be evaluated through the \nLLWG and ultimately presented to the Commission in a separate FPA section 205 filing.  MISO \nwill continue to develop the LARS process through the LLWG and expects to submit the LARS \nfiling by November 16, 2026, or earlier, if feasible.   \n \nII. \nOVERVIEW OF ZGIA PROPOSAL AND HOW IT ADDRESSES THE SHOW CAUSE ORDER \nThe ZGIA construct allows for generation to connect to the Transmission System without \ninjection rights, making it suitable to serve loads, including large loads, at the same substation.  \nThis proposed construct not only formalizes the existing practice, but it also addresses a discrete \nsubset of the concerns identified by the Commission in the Show Cause Order, specifically those \nconcerning generator interconnection service and the study of generation serving co-located load.   \nMore specifically, the ZGIA construct provides a limited, structured option to support large \nload integration through: (i) an interconnection service framework for generation that is supporting \nco-located load; (ii) defined interconnection study processes tailored to zero-injection \nconfigurations; (iii) potentially reduced network upgrade requirements where appropriate; and (iv) \nclear allocation of operational and planning responsibilities.  The ZGIA construct enables one \npathway for certain large load configurations to achieve speed to reliable power while maintaining \nsystem reliability.  The ZGIA framework is not, however, limited to large loads.  While the ZGIA \nis particularly responsive to the needs of a large load, a ZG Associated Load38 does not have to be \na large load. \nMISO notes that this filing does not include a proposed definition of “Large Load.”  MISO \nis continuing to refine the definition of “Large Load” through the ongoing stakeholder process at \nthe LLWG and expects to file the proposed definition of “Large Load” with the Commission in a \nsubsequent FPA section 205 filing that is responsive to certain additional concerns raised in the \nShow Cause Order that are not specifically addressed herein.  The ZGIA proposal remains just and \nreasonable without inclusion of a definition of “Large Load” because the ZGIA proposal and the \nidentification of ZG Associated Load is open to application for all loads in the MISO region and \nis not limited to only large loads.  In addition, the Show Cause Order explains that it appears that \nit would be reasonable to define a large load as: (1) a new commercial or industrial customer, (2) \nlocated at a single site behind one or more points of interconnection, (3) that has a peak load of 50 \nMW or greater, (4) interconnects to the transmission system at a voltage level of greater than 69 \nkV, and (5) is not part of a co-location arrangement.39 \nA. \nThe Rates, Terms, and Conditions of Service that Apply to Interconnection \nCustomers Serving Co-Located Load  \n \n38  Zero Injection Generation (ZG) Associated Load shall mean a source of electrical load that has a Point of \nWithdrawal that is at the same substation as the Point of Interconnection to the Transmission System (i.e. same \nvoltage level at the interconnecting substation) as the Generating Facility with ZG Interconnection Service that \nwill serve it. \n39  See SCO at fn 2 (emphasis added), see also SCO at P 58."},{"page":12,"startToken":4870,"endToken":5368,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 12 \n \n \nThe Show Cause Order posits that MISO’s Tariff appears to be unjust and unreasonable \nbecause it lacks provisions addressing with sufficient clarity and consistency the rates, terms, and \nconditions of service that apply to interconnection customers serving co-located load.40  This filing \nproposes to address the Show Cause Order’s concerns relating to the rates, terms, and conditions \nof service that apply to interconnection customers serving co-located load as explained below:  \nMISO proposes to implement a new type of service, called ZG Interconnection Service.  \nZG Interconnection Service is service limited to serving specifically designated load that is either \nat the same Point(s) of Interconnection (“POI”) or has a Point(s) of Withdrawal (“POW”) on the \nsame voltage side of the same substation as the ZGIA.  ZG Interconnection Service is not \nTransmission Service and does not exempt a Transmission Customer from procuring Transmission \nService.  Accordingly, the ZGIA addresses the generator interconnection component of a co-\nlocation arrangement; it does not establish or modify the Transmission Service that must be \nobtained to serve the ZG Associated Load.  MISO intends to address the separate transmission \nservice issues identified in the Show Cause Order through subsequent filings developed through \nthe LLWG.   \nZG Interconnection Service is fundamentally a limited product.  ZG Interconnection \nService will be limited to a POI and POW that are at the same substation, with the same voltage \nlevel.  The ZGIA process will ultimately offer a ZGIA for limited operations, with operation limited \nto ensure system reliability based upon the results of the impact assessment and facilities studies.  \nZG Interconnection Service does not allow the Interconnection Customer to serve other load or \ninject energy onto the Transmission System for purposes other than serving the ZG Associated \nLoad identified in the Interconnection Request and memorialized in the ZGIA.  After engaging in \nthe stakeholder process, MISO determined that the same substation and voltage level limitation on \nZG Interconnection Service to only serve load or inject onto the Transmission System for purposes \nof serving ZG Associated Load strikes the appropriate balance between offering a constrained \nproduct that can be studied to ensure minimal impact on other projects and enabling an expedited \nstudy process without hindering MISO’s ability to process the Definitive Planning Phase (“DPP”). \nThe rates, terms, and conditions for service under the ZGIA construct differ from ordinary \ninterconnection requests in several key areas listed below. \nFirst, the resource seeking ZG Interconnection Service must demonstrate a relationship \nwith load connected at the same voltage side of the same substation, defined as ZG Associated \nLoad, under which the ZG Associated Load signifies its intention to be served by the ZG Resource.  \nMr. Keyser explains that, because ZG Interconnection Service allows the ZG Resource to serve \nonly its designated ZG Associated Load, documenting the relationship between ZG Associated \nLoad and the ZG Resource is necessary to prevent speculative Interconnection Requests from \nusing the process.41   \n \n40  SCO at PP 94 and 97. \n41  Keyser at 9."},{"page":13,"startToken":5368,"endToken":5825,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 13 \n \n \nSecond, while an Interconnection Customer seeking ZG Interconnection Service is not \nlimited in the quantity of nameplate capacity of generation they choose to build, the \nInterconnection Customer seeking ZG Interconnection Service is limited to requesting and being \nawarded Interconnection Service at a level that does not exceed the peak demand of the ZG \nAssociated Load.  As explained by Mr. Keyser, this is an important design feature of the ZGIA \nprocess because it serves to ensure that the maximum expected energy production of the ZG  \nResource is no greater than the maximum demand of the ZG Associated Load.42 \nThird, the ZG Interconnection Service Study must model the ZG Associated Load when \nstudying the Interconnection Request and confirm that the proposed equipment to limit injections \nis sufficient to accomplish this task.  This requirement is consistent with the Commission’s \ndiscussion regarding the need for a new generator interconnection service tailored to co-location \narrangements using control technologies and/or protection systems to ensure there is no injection \non the Transmission System.43 \nIn this manner, the ZGIA study evaluates the generation and associated load together, rather \nthan studying the generating facility without regard to the load it is intended to serve.  This directly \nresponds to the Commission’s concern that MISO’s existing generator interconnection process \nmay fail to recognize the reduced Transmission System impacts of generation that is operationally \nlimited to serving co-located load.   \nFourth, the ZG Resource must interconnect at the same substation and voltage level as one \nof the POWs of the ZG Associated Load it serves; and, the ZG Interconnection Study must \ndetermine that the ZG Resource will not require Network Upgrades beyond the substation except \nfor system protection facilities at adjacent substations.   \nIf all of these criteria are met, the ZG Interconnection study process affords a 90-day \naccelerated study process leading to a ZGIA that memorializes the proposed configuration and \nlimited injection. \nB. \nGenerator Interconnection Study Process  \nThe Show Cause Order preliminarily found that MISO’s Tariff appears to be unjust and \nunreasonable because it lacks provisions allowing an interconnection customer to seek the \ngenerator interconnection service(s) that reflects the operational dynamics of serving either: (1) an \nelectrically proximate large load; or (2) a co-located load that has a high peak load (i.e., large co-\nlocated loads that are 50 MW or greater).44  In particular, the Commission noted that the Tariff \nappears to be unjust and unreasonable because it lacks a generator interconnection study process \nand/or generator interconnection service to reflect an interconnection customer’s commitment in \nan interconnection agreement to limit the generating facility’s output to minimize the impact on \n \n42  Keyser at 10-11. \n43  See SCO at P 118. \n44  SCO at P 113."},{"page":14,"startToken":5825,"endToken":6313,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 14 \n \n \nthe transmission system while serving an electrically proximate large load or large co-located \nload.45  The Show Cause Order also observed that where a generating facility’s output is matched \nto the demand of the electrically proximate large load or large co-located load or if the generating \nfacility’s output is limited to ensure no new injection, the impacts to the transmission system of \ninterconnecting the generating facility to serve that electrically proximate large load or large co-\nlocated load may be limited, thereby potentially reducing the need for Network Upgrades, which \ncan accelerate the generator interconnection process.46 \nThe ZGIA addresses this concern with respect to co-located load that satisfies the ZG \nAssociated Load requirements.  As discussed above, the separate application of this concept to \ngeneration service for electrically proximate large load will be addressed through MISO’s \nforthcoming LARS proposal.  As explained by Mr. Keyser, the ZGIA proposal will complement \nthe Definitive Planning Phase (“DPP”), which is MISO’s current Interconnection Queue process \nfor addressing the needs of large loads.47  The DPP process is quite broad and enables system \nreliability by studying new generation sources for technical and operational impacts and \nidentifying and assigning the costs for the necessary upgrades required to connect the new \nresources safely and reliably.  Under the DPP, Interconnection Requests are evaluated through a \nthree-phase, grouped study process.  Because projects all impact the Transmission System and are \nstudied in groups, each Interconnection Request is affected by higher-queued and same-group \nprojects, introducing complexity and uncertainty, particularly when withdrawals occur.  This \nprocess is not always necessary for all customers because some Interconnection Customers—\nparticularly those serving large loads—seek to install generation to meet the needs of adjacent \nlarge loads, and do not require access to the transmission system and, in fact, may never intend to \ninject onto the MISO Transmission System or, if they do plan on injecting, it is only to move \nenergy to an adjacent bay of the same substation.  In such circumstances, a separate, expedited \nstudy process and corresponding form of Interconnection Service is both feasible and responsive \nto the Commission’s directive to address the needs of certain loads, including large loads \nassociated with data centers.   \n \nThe ZGIA proposal implements that proposed, expedited process.  The study requirements \nnecessary for a ZGIA to provide ZG Interconnection Service are still extensive, including \nobligations to implement equipment and/or operational procedures to prevent injections and to \nlimit any inadvertent injections to a defined Transient Tolerance Window in the event of an \nunexpected load reduction or trip.48 \nInterconnection Requests submitted through the ZGIA process will be studied in a serial \n“first-come, first served” fashion based on the order the projects were submitted.  It will follow a \nquarterly cadence established by proposed MISO timelines, ultimately culminating in the project \n \n45  SCO at P 113.  \n46  SCO at P 113.  \n47  Keyser at 7-9. \n48  Keyser at 20–22."},{"page":15,"startToken":6313,"endToken":6795,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 15 \n \n \nreceiving a ZGIA in approximately 90 days.  The ZGIA model build will include all Existing \nGenerating Facilities, including those from completed DPP cycles, the ERAS Interconnection \nRequest, and the latest MTEP base case with all approved MTEP projects, and any recently \napproved EPR projects.  This is the same process utilized for DPP studies except the DPP models \ninclude all higher queued Interconnection Requests from earlier cycles and all Interconnection \nRequests within that DPP cycle.  ZGIA studies will not include Interconnection Requests currently \nin the generator interconnection queue that do not have a GIA. \n \nBefore every ZGIA cycle, all Interconnection Requests with a GIA approved since the last \nbase case was created will be added to the base case for the ZGIA cycle but will not be added in \nany ongoing DPP studies.  The base case for each DPP cycle is never updated once the study \nprocess is kicked off except for generation changes due to Interconnection Request withdraws or \ngenerator retirements.  This ensures that the transmission capacity made available for DPP projects \nis not being taken away by ZGIA Interconnection Requests approved outside of the DPP cycle.  \n \nOnce the DPP cycle has concluded, the output from that process, and any completed ZGIA \nand EPR projects, will be used to populate a new MTEP base case.  Any transmission issues \nidentified by reconciling the cases will thus be addressed through the existing MTEP process.  The \nnext DPP cycle will then use the latest approved MTEP base case that has reconciled the models.  \nThis insulates existing DPP projects from negative impacts or cost shifts due to the existence of \nthe ZGIA process.  The contingent facilities listed in the ZGIA would only be those facilities in \nthe model used for the ZGIA study and those Network Upgrades that come up as part of the ERAS \nstudy.    \n \nSubsequently, the standing MISO DPP three phase and ERAS processes will not be \nimpacted by ZGIA, as ZGIA will not be utilizing any available transmission capacity in those \nstudies. \n \nIt should be noted that the ZGIA study process includes the load and a simulation of the \nscenario in which the load trips offline.  As Mr. Keyser explains, this analysis will help validate \nthe specific protection schemes needed for the specific ZGIA project.49 \n \nAs previously discussed, ZG Associated Load that is studied and eligible for \ninterconnection is a firm network load, obligated under existing Tariff rules to pay for transmission \nservice on a gross basis, and eligible for all the benefits of being a network load, including being \nserved by all MISO resources on any and all transmission paths.  \n \nTaken together, these provisions establish the tailored generator interconnection study \nprocess contemplated by the Show Cause Order for generation serving co-located load, while \npreserving for subsequent filings the distinct issues associated with Transmission Service and \nelectrically proximate load.  \n \n \n49  Keyser at 28."},{"page":16,"startToken":6795,"endToken":7205,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 16 \n \n \nIII. \nDESCRIPTION OF PROPOSED TARIFF REVISIONS \nTo implement the ZGIA construction proposed herein, MISO is requesting approval of \nnew Tariff provisions, as well as revisions to several existing provisions.50  \nA. \nModule A (Common Tariff Provisions).  MISO is proposing both to add several \nnew terms and definitions to Module A, as well as to revise the definition of several existing terms, \nas follows: \n1. \nProposed New Module A Tariff Provisions.  MISO is requesting approval \nto add five (5) newly defined terms to Module A of its Tariff.  The new terms and proposed \ndefinitions include: \na. Point(s) of Withdrawal:  The point(s) where a non-transmission facility that is \nused to withdraw Energy from the Transmission System to serve Load connects \nto the Transmission System. \n \nb. Zero Injection Generation (ZG) Associated Load:  A source of electrical load \nthat has a Point of Withdrawal that is at the same substation as the Point of \nInterconnection to the Transmission System (i.e. same voltage level at the \ninterconnecting substation) as the Generating Facility with ZG Interconnection \nService that will serve it. \n \nc. Zero Injection Generation (ZG) Interconnection Service:  A limited form of \nInterconnection Service that allows an Interconnection Customer to connect its \nGenerating Facility to the Transmission System or Distribution System, as \napplicable, for the limited purpose of delivering energy to ZG Associated Load.  \nZG Interconnection Service does not grant any right to inject energy onto the \nTransmission System except as may be authorized by Section 3.11 of the \nGenerator Interconnection Procedures.  ZG Interconnection Service does not \nconvey Transmission Service.  ZG Interconnection Service also does not \nprovide a right to serve, or a right to Transmission Service to serve, a ZG \nAssociated Load or retail customer except as allowed by applicable state law. \n \nd. Zero Injection Generation (ZG) Resource:  A generating resource with an \nAttachment X defined ZG Interconnection Agreement.  A ZG Resource may \nparticipate as a Generation Resource, Dispatchable Intermittent Resource, \nElectric Storage Resource, or Behind the Meter Generation resource. \n \n2. \nProposed Revised Module A Tariff Provisions.  MISO is proposing to revise \nthe definition of several terms currently included in Module A.  The struck-through language \n \n50  This transmittal letter frequently quotes proposed Tariff revisions to facilitate its explanation.  In the event of a \nconflict between the Tariff language as discussed in this letter and that reflected in the attached Tariff sheets, \nMISO intends that the language in the attached Tariff sheets control."},{"page":17,"startToken":7205,"endToken":7609,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 17 \n \n \nshown below will be deleted from the definition and the words or phrases shown in italics will be \nadded.  MISO’s proposed revisions are as follows: \na. Forecast Maximum Limit:  For a Dispatchable Intermittent Resource, The the \nmaximum MW level at which a Dispatchable Intermittent the Resource is \nforecasted to operate.  In addition, for a ZG Resource participating as a DIR, \nthe maximum MW level at which a Resource may operate shall be less than the \nDemand of the Resource’s ZG Associated Loads.   \n \nb. Hourly Economic Maximum Limit:  The maximum MW level at which a \nGeneration Resource, Demand Response Resource Type II, or External \nAsynchronous Resource may operate under normal system conditions that may \nbe submitted to override the default value submitted during the asset registration \nprocess.  In addition, for a ZG Resource participating as a Generation \nResource, the maximum MW level at which the Resource may operate under \nnormal system conditions shall be less than the Demand of the Resource’s ZG \nAssociated Loads. \n \nc. Hourly Economic Maximum Discharge Limit:  The maximum injection MW \nlevel at which an Electric Storage Resource may operate under normal system \nconditions that may be submitted to override the default value submitted during \nthe asset registration process.  In addition, for a ZG Resource participating as \nan Electric Storage Resource, the maximum MW level at which the Resource \nmay operate under normal system conditions shall be less than the Demand of \nthe Resource’s ZG Associated Loads. \n \nd. Hourly Emergency Maximum Limit:  The maximum MW level at which a \nGeneration Resource, an External Asynchronous Resource, or Demand \nResponse Resource Type II may operate under Emergency conditions that may \nbe submitted to override the default value submitted during the asset registration \nprocess.  In addition, for a ZG Resource participating as a Generation \nResource, the maximum MW level at which a Resource may operate under \nEmergency conditions shall be less than the Demand of the Resource’s ZG \nAssociated Loads. \n \ne. Hourly Emergency Maximum Discharge Limit:  The maximum injection MW \nlevel at which an Electric Storage Resource may operate under Emergency \nsystem conditions that may be submitted to override the default value submitted \nduring the asset registration process.  In addition, for a ZG Resource \nparticipating as an Electric Storage Resource, the maximum MW level at which \nthe Resource may operate under Emergency system conditions shall be less than \nthe Demand of the Resource’s ZG Associated Loads."},{"page":18,"startToken":7609,"endToken":8048,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 18 \n \n \nf. Hourly Regulation Maximum Discharge Limit:  The maximum injection MW \nlevel at which an Electric Storage Resource can respond to automatic control \nsignals, that may be submitted to override the default value submitted during \nthe asset registration process.  In addition, for a ZG Resource participating as \nan Electric Storage Resource, the maximum MW level at which the Resource \ncan respond to automatic control signals shall be less than the Demand of the \nResource’s ZG Associated Loads. \n \ng. Hourly Regulation Maximum Limit:  The maximum MW output at which a \nGeneration Resource, Demand Response Resource – Type II, or External \nAsynchronous Resource can respond to automatic control signals that may be \nsubmitted to override the default value submitted during the asset registration \nprocess.  In addition, for a ZG Resource participating as a Generation \nResource, the maximum MW level at which a Resource can respond to \nautomatic control signals shall be less than the Demand of the Resource’s ZG \nAssociated Loads. \n \nB. \nModule C (Energy and Operating Reserve Markets).  MISO is proposing to \nimplement a registration requirement for a ZG Resources greater than 5 MW in size.  This \nrequirement provides visibility of the ZG Resource to MISO and is necessary for MISO to account \nfor the gross amount of ZG Associated Load, which will facilitate the requirement that the ZG \nAssociated Load is required to pay for transmission service, ancillary services, and other services \nthey receive on a gross basis, as contemplated by the Show Cause Order.51  \n \nC. \nModule E-1 (Resource Adequacy). MISO is proposing to both add new provisions \nto Module E-1 and to revise several existing provisions, as follows: \n \n1. \nProposed New Module E-1 Tariff Provisions.  MISO is requesting approval \nto add one (1) new subsection to Module E-1.  The subsection is limited to: \na. Section 69A.4.1 (Seasonal Accredited Capacity of Capacity Resources): MISO \nis proposing to add a new subsection providing that the Seasonal Accredited \nCapacity for a ZG Resource shall be based on its participation type and subject \nto certain enumerated requirements, including that the Seasonal Accredited \nCapacity is capped at the specified portion of the Coincident Peak Demand \nforecast attributable to the ZG Associated Load less any Seasonal Accredited \nCapacity (“SAC”) assigned to the ZG Associated Load and that the SAC shall \nbe grossed-up by the amount of avoided Transmission Losses. \n \n2. \nProposed Revised Module E-1 Tariff Provisions. MISO is proposing to \nrevise several provisions of Module E-1 to establish the basis on which a ZG Resource and ZG \nAssociated Load may participate in MISO’s Resource Adequacy construct and associated rules \n \n51  SCO at P 96."},{"page":19,"startToken":8048,"endToken":8506,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 19 \n \n \nrelated to the accreditation of ZG Resources.  The nature of the proposed revisions to Module E-1 \nreflect the fact that a ZG Resource cannot serve load in the MISO region beyond the substation \nand voltage level of its co-located ZG Associated Load.  As such, these revisions limit the \nparticipation of a ZG Resource in MISO’s Planning Resource Auction (“PRA”) to inclusion in a \nFixed Resource Adequacy Plan (“FRAP”) or Reliability Based Demand Curve (“RBDC”) Opt-\nOut, and do not allow the use of uncleared Zonal Resource Credits (“ZRC”) for replacement. \nParticipation by ZG Resources in the PRA are further limited – a ZG Resource can qualify for \nZRCs up to the lesser of its otherwise applicable accreditation, or the seasonal coincident peak \ndemand of the ZG Associated Load, plus an accounting for losses not experienced due to the co-\nlocation of the two.  The proposed revisions to Module E-1 are just and reasonable because they \nreflect the limited nature of ZG Interconnection Service, while accommodating the participation \nof ZG Resources and ZG Associated Loads in the PRA.  The proposed revisions to Module E-1 \nare as follows: \na. Section 68A.8 (Calculation of Transmission Losses):  MISO is proposing minor \nchanges to this section to state that ZG Resources will be treated the same as \nBTMGs that are not interconnected to the Transmission System and Demand \nResources by grossing up the MW quantity of such resources by (1.0 + the \nappropriate LBA transmission loss percentage). \n \nb. Section 69A.1.1 (Forecasted Demand Identification):  MISO is proposing \nrevisions to this section to require the supplied Coincident Peak Demand \nforecast to identify, in MW, the expected contribution of each ZG Associated \nLoad and identify its associated ZG Resource, and to provide that a ZG \nResource is ineligible for SAC unless its ZG Associated Load is explicitly \nidentified in the Coincident Peak Demand forecast. \n \nc. Section 69A.3.1.g (Determination of Deliverability):  MISO is proposing \nrevisions to this section to provide that the deliverable amount of certain \nresources may include the amount of ZG Interconnection Service under \nAttachment X only for a ZG Resource. \n \nd. Section 69A.3.1.h (Replacement of Planning Resources):  MISO is proposing \nrevisions to clarify that the Planning Resources subject to ZRC replacement \nobligations may include a ZG Resource of any type. \n \ne. Section 69A.3.3 (Load Modifying Resources):  MISO is proposing revisions to \nclarify that a ZG Resource may qualify as a BTMG if not registered as a \nGeneration Resource or DIR.  \n \nf. Section 69A.3.6 (Behind the Meter Generation Eligibility):  MISO is proposing \nrevisions to clarify that a Market Participant registering as a BTMG or ZG \nResource participating as a BTMG must meet certain requirements."},{"page":20,"startToken":8506,"endToken":8936,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 20 \n \n \ng. Section 69A.3.9 (Penalty Provisions for LMRs): MISO is proposing revisions \nto clarify that ZG Resources participating as BTMG will be subject to \nenumerated penalties applicable to LMRs.  \n \nh. Section 69A.4.1 (Seasonal Accredited Capacity of Capacity Resources): MISO \nis proposing revisions to clarify that the SAC for a Capacity Resource that is a \nGeneration Resource, but not a ZG Resource, is based on certain enumerated \ncriteria. \n \ni. Section 69A.4.5 (Attributes of ZRCs): MISO is proposing revisions to provide \nthat all ZRCs associated with a ZG Resource must be used as part of an LSE’s \nFRAP or RBDC Opt Out.  MISO is proposing additional revisions to provide \nthat, if the Capacity Resource has ZG Interconnection Service, the Seasonal \nAccredited Capacity will be allocated as one-hundred percent (100%) of SAC. \n \nj. Section 69A.7.3 (Uncleared ZRCs): MISO is proposing revisions to provide \nthat ZRCs associated with a ZG Resource that are not used in a FRAP may not \nbe used as Uncleared ZRCs. \n \nk. Section 69A.7.8 (Self-Scheduling Option): MISO is proposing revisions to \nprovide that ZRCs obtained from a ZG Resource may not be used in a Self-\nSchedule. \n \nl. Section 69A.9 (Use of FRAP in the Planning Resource Auction): MISO is \nproposing revisions to provide that all ZRCs associated with a ZG Resource \nmust be used as part of an LSE’s FRAP or RBDC Opt Out, and that all ZRCs \nassociated with a ZG Resource that are not used in a FRAP shall have no \ncapacity value as set forth in Section 69A.7.3. \n \nm. Section 69A.9.1 (Use of RBDC Opt Out in the Planning Resource Auction): \nMISO is proposing revisions to provide that all ZRCs associated with a ZG \nResource must be used as part of an LSE’s FRAP or RBDC Opt Out.  MISO is \nproposing additional revisions to provide that, if an LSE owns or controls ZRCs \nthat are not included in the LSE’s RBDC Opt Out, then such LSE may submit \nZRC Offers into the PRA for all such excess ZRCs, subject to Module D, and \nthat such ZRC Offers may not include ZRCs associated with a ZG Resource. \n \nD. \nAttachment X (Generator Interconnection Procedures).  \nThe proposed Tariff revisions implement the ZGIA process and are necessary to distinguish \nthe key differences in how the ZG Interconnection Service study process and the resulting ZGIA \nwill operate in comparison to MISO’s standard three-phase generator interconnection queue.  For \nconvenience, MISO discusses the revisions to the GIP by section, below."},{"page":21,"startToken":8936,"endToken":9429,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 21 \n \n \n1. Section 1: Definitions \n \nMISO proposes the following new definitions for addition to the GIP (and ZGIA): \nPoint(s) of Withdrawal (POW) shall mean the point(s) where a non-transmission \nfacility that is used to withdraw Energy from the Transmission System to serve Load \nconnects to the Transmission System. \nMISO proposes this definition in order create a load equivalent to the existing defined term, \nPoint of Interconnection, which is used to describe the point at which the Interconnection Facilities \nconnect to the Transmission System.  Because the relative location and configuration of Load with \nrespect to the Generating Facility and to the Transmission System is a critical component of ZG \nInterconnection Service, vocabulary is needed to discuss the point where Load connects to the \nTransmission System in reference to the Point of Interconnection.  The term “Point(s) of \nWithdrawal” provides a delineation between the two points that facilitates clearer Tariff rules. \nMISO notes that this term can be plural as certain large loads may have more than one point where \nthey connect to the Transmission System. \nTransient Tolerance Window shall mean the period of time after a reduction or loss of \nload by the ZG Associated Load by the end of which window the Generating Facility \nwith ZG Interconnection Service must have reduced its injections to an amount not \ngreater than the Load of the ZG Associated Load.  The Transient Tolerance Window shall \nbe no greater than 20 seconds, and is further described by the Business Practices Manual \nfor Large Load.  The Transient Tolerance Window will be subject to Transmission Owner \nlocal planning criteria. \n \nDefining a “Transient Tolerance Window” is necessary to establish rules regarding how \nquickly a Generating Facility must match ZG Associated Load reductions in Demand.  As \nexplained further below and in the attached testimony of Mr. Keyser, even with tight coordination \nbetween a Generating Facility and ZG Associated Load, a Generating Facility generally will not \nbe able to ramp down instantaneously in the event of a sudden decrease in Load.52  However, rules \nare needed to require rapid disconnection or reduction in order to prevent impacts to the \nTransmission System from unintended injections.  The concept of a Transient Tolerance Window \ntherefore provides a reasonable vehicle for establishing realistic and enforceable rules about how \nquickly a Generating Facility must reduce output.   \nAfter careful consideration, MISO determined that a 20-second limit provides the best \nsystem-wide balance between what is technically feasible and commercially practical on the one \nhand, and minimizing even transient injections on the other hand.  MISO notes that there may be \ncircumstances where a narrower window is necessary and practical given electrical topography on \ncertain parts of the MISO System, or Applicable Local Planning Criteria.  It would be impractical \nto identify all such circumstances in the Tariff.  Therefore, the definition allows for the creation of \nBusiness Practices Manual rules that narrow the window based on specific circumstances existing \n \n52  Keyser at 25-26."},{"page":22,"startToken":9429,"endToken":9931,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 22 \n \n \non parts of the Transmission System.  By creating an outer window in the Tariff and allowing more \nsituation-specific rules to be developed through the Business Practices Manual, this definition \nstrikes a needed balance between clear Tariff rules and flexibility to adjust timing based on detailed \ntechnical considerations.53 \nZero Injection Generation (ZG) Associated Load shall mean a source of electrical load \nthat has a Point of Withdrawal that is at the same substation as the Point of Interconnection \nto the Transmission System (i.e. same voltage level at the interconnecting substation) as \nthe Generating Facility with ZG Interconnection Service that will serve it. \n \nAdding this defined term to the Tariff provides the vocabulary needed for discussing the specific \nload that a Generating Facility with ZG Interconnection Service is limited to serving.  \nZero Injection Generation (ZG) Interconnection Service shall mean a limited form of \nInterconnection Service that allows an Interconnection Customer to connect its Generating \nFacility to the Transmission System or Distribution System, as applicable, for the limited \npurpose of delivering energy to ZG Associated Load.  ZG Interconnection Service does not \ngrant any right to inject energy onto the Transmission System except as may be authorized \nby Section 3.11 of the Generator Interconnection Procedures.  ZG Interconnection Service \ndoes not convey Transmission Service.  ZG Interconnection Service also does not provide \na right to serve, or a right to Transmission Service to serve, a ZG Associated Load or retail \ncustomer except as allowed by applicable state law. \nMISO’s proposed definition of Zero Injection Generation Interconnection Service \ndescribes a limited form of Interconnection Services that enables a Generating Facility to serve \nLoad at the same substation and voltage level as the Generating Facility without authorizing use \nof the broader Transmission System.  The terms of this definition reflect its development through \nthe stakeholder process as a limited tool to enable functional co-location arrangements that can be \nrapidly studied and implemented without broader impacts to the Transmission System.  The term \n“zero injection” refers to the lack of injection onto the Transmission System beyond the immediate \ninterconnecting substation.  The third sentence of this definition reflects the standard disclaimer \nthat Interconnection Service does not convey Transmission Service, which language is also present \nin the existing definitions of ER Interconnection Service and NR Interconnection Service.  The \nfourth sentence of this definition was added to allay concerns that an Interconnection Customer \ncould use ZG Interconnection Service to circumvent state law restrictions on serving load or \ninadvertently authorize retail wheeling.  This sentence does not add any new restriction on service \nbut merely respects those that may exist at the state level. \nZero Injection Generation (ZG) Resource shall mean a generating resource with an \nAttachment X defined ZG Interconnection Agreement.  A ZG Resource may participate as \n \n53  This flexibility is limited given that MISO would still be required to define the situations under which the \nTransient Tolerance Window would be reduced in a stakeholder-reviewed Business Practices Manual before \napplying them to a given interconnection."},{"page":23,"startToken":9931,"endToken":10325,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 23 \n \n \na Generation Resource, Dispatchable Intermittent Resource, Electric Storage Resource, or \nBehind the Meter Generation resource. \n \nThe definition of ZG Resource reflects how these Generating Facilities integrate into \nMISO’s market structures and provides a shorter form of identification than “Generating Facilities \nwith ZG Interconnection Service” improving Tariff readability where these are discussed.  \nGenerally, ZG Resources may participate in MISO markets and resource adequacy constructs in \nthe same way as generators with other types of Interconnection Service, subject to the limitation \nthat their participation is limited to serving, and being credited for serving, the ZG Associated \nLoad. \n \n \nMISO proposes the following definitions for ZG Facility Study and ZG Impact \nAssessment: \n \nZG Facilities Study shall mean the study described in Section 3.2.5.2.2 of these GIP that \nis used to identify any Network Upgrades or Interconnection Facilities that may be needed \nto for an Interconnection Request seeking ZG Interconnection Service. \n \nand \n \nZG Impact Assessment shall mean the study described in Section 3.2.5.2.1 of these GIP \nthat is used to evaluate the impact of an Interconnection Request seeking ZG \nInterconnection Services. \n \nThese definitions describe the studies that MISO will conduct for an Interconnection \nRequest seeking ZG Interconnection Service.  MISO notes that because only limited injection is \nallowed and Network Upgrades required on the Transmission System beyond the interconnecting \nand neighboring substations generally would preclude the granting of ZG Interconnection Service, \nthe scope of these studies is more focused and can be accelerated from the timeframe of System \nImpact Studies and Facilities Studies under the DPP.  \n \n \nMISO proposes the following definition for the pro forma agreement that would be \ntendered to an Interconnection Customer at the conclusion of ZG Interconnection Services: \n \nZG Interconnection Agreement (ZGIA) shall mean the form of interconnection \nagreement governing the terms and conditions of ZG Interconnection Service, set forth in \nAppendix 19 to these Generator Interconnection Procedures. This agreement shall follow \nthe form of the Transmission Provider’s pro forma Generator Interconnection Agreement \nwith modifications to reflect ZG Interconnection Service and the ZG Interconnection \nService study process.  Unless otherwise provided in the GIP, all requirements applicable \nto the pro forma Generator Interconnection Agreement shall apply to the ZGIA.  A ZGIA \nis a form of GIA and, where used in the Tariff, references to Generator Interconnection \nAgreements or GIAs encompasses ZGIAs."},{"page":24,"startToken":10325,"endToken":10731,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 24 \n \n \nMISO notes that the ZGIA is closely based on the MISO’s pro forma GIA in Tariff \nAttachment X, Appendix 6 with modifications as described below to provide for ZG \nInterconnection Service.  MISO ultimately expects to merge the ZGIA and GIA, as described \nbelow.  However, as noted below, MISO has replicated the provisions of the GIA in Appendix 6 to \nAttachment X of the Tariff and added the revisions necessary to implement ZG Interconnection \nService into Appendix 19 rather than Appendix 6 for administrative reasons.  However, a ZGIA is \nintended to be a form of GIA and MISO intends that references in the Tariff to GIAs refer to ZGIAs \nas well unless otherwise expressly stated.  MISO includes the last sentence of this definition to \navoid any confusion and clarify that the numerous references in other sections of the Tariff to GIAs \ninclude ZGIAs by default.  \n \n \nFinally, MISO proposes the following defined term to refer to the quarterly study that \nMISO will perform for Interconnection Requests seeking ZG Interconnection Service: \n \nZG Interconnection Process Quarterly Study Period shall mean the period of time in \nwhich Interconnection Requests seeking ZG Interconnection Service are submitted to the \nTransmission Provider and compiled for study.  There are four study periods in a year \nwith the following start and end dates: \n \nQuarter 1: The first Business Day of March through the last Business Day of \nMay; \nQuarter 2: The first Business Day of June through the last Business Day of \nAugust; \nQuarter 3: The first Business Day of September through the last Business Day of \nNovember; \nQuarter 4: The first Business Day of December through the last Business Day of \nFebruary. \n \nThis definition is based on the definition for the ERAS Quarterly Study schedule and MISO \nproposes a similar quarterly cadence for ZG Interconnection Studies. \n2. Section 3.2.5—ZG Interconnection Service \nMISO proposes to add new section 3.2.5 to the GIP establishing ZG Interconnection \nService as a new type of interconnection service available under the GIP.  The first proposed new \nparagraph of Section 3.2.5.1 explains that ZG Interconnection Service is, \nrestricted Interconnection Service that allows an Interconnection Customer to \nconnect its Generating Facility to the Transmission System or Distribution System, \nas applicable, for the limited purpose of delivering energy to a source of electrical \nload that is at the same substation as the Point of Interconnection to the"},{"page":25,"startToken":10731,"endToken":11272,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 25 \n \n \nTransmission System (i.e. same voltage level at the interconnecting substation) as \nthe Generating Facility with ZG Interconnection Service that will serve it.54 \n \nThis service would provide a vehicle for a Generating Facility to serve a large load (or \nother load) that is either located behind the same Point of Interconnection as the Generating \nFacility as well as situations where the Point of Withdrawal of the load source is at the same \nsubstation and voltage level as the Generating Facility.  As Mr. Keyser explains in his testimony, \ngenerators that are serving co-located load may not require the same degree of access to the \nTransmission System as those seeking ERIS to serve Load farther afield.  And the limited distance \nover which energy would need to be—and is permitted to—flow allows for a more targeted study.55   \nMISO worked closely with its stakeholders over many months, and prior to the issuance of \nthe Show Cause Order, to determine the appropriate permissible electrical distance between the \nGenerating Facility and load source that should be allowed for ZG Interconnection Service.  As \npart of this process, MISO initially considered allowing ZG Interconnection Service for a \nGenerating Facility to serve Load located several buses or substations away.  However, \nstakeholders across differing MISO sectors did not support such a broad reach, citing concerns \nabout the practicality of limiting injections to the rest of the Transmission System once the \ngeneration and load were allowed to be at separate substations, the likelihood of unconstrained \npower flows56 changing over time in unanticipated ways from what was studied, and the potential \nfor retail wheeling. \nMISO also considered limiting ZG Interconnection Service to load and generation located \nbehind the same Point of Interconnection.  However, after discussions with stakeholders and \nreview of proposed configurations, MISO determined that such a restriction would be too narrow \nfor the MISO region.  Several potential Interconnection Customers planned to utilize adjacent bays \nin the same substation to run the lead lines for the Generating Facility and Load as a more \npragmatic and cost-effective approach than expanding one substation bay to house both lead lines \nin order to maintain the same Point of Interconnection.  These stakeholders argued that using an \nadjacent bay would be electrically indistinguishable from housing both the Generating Facility and \nLoad behind the same bay given the requirement to install equipment limiting injections to the rest \nof the Transmission System.  Ultimately, MISO recognized that requiring the Generating Facility’s \nPoint of Interconnection and the Load’s Point of Withdrawal to be at the same voltage level of the \nsame substation provided the right balance of flexibility to enable expected large load co-location \narrangements while ensuring a minimal use of the Transmission System consistent with a \npermanent zero injection based product.  In reaching this decision, MISO noted that ‘same voltage \nlevel at the same substation’ is the test applied for whether Points of Interconnection are electrically \nidentical under MISO’s Generating Facility Replacement Process.57  Limiting the electrical \n \n54  Attachment X at Section 3.2.5.1. \n55  Keyser at 7-8. \n56  I.e., power flows that it is not practical to contain within a defined area through control equipment.  \n57  See Attachment X at Section 3.7.1."},{"page":26,"startToken":11272,"endToken":11799,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 26 \n \n \ndistance between the Point of Interconnection and Point of Withdrawal in this way allows MISO \nto offer ZG Interconnection Service on a permanent basis (subject to 15 year automatically \nrenewing term provisions) similar to other Interconnection Service products.  This duration is an \nimportant feature of the ZG Interconnection Service.  MISO understands the Show Cause’s Order’s \nproposed distinction between a potentially permanent co-location service and a temporary \n“proximate location service.”58  ZG Interconnection Service is more of a co-location construct than \nit is a proximate load construct, with the only departure from using a strict ‘same POI’ requirement  \nbeing some very limited flexibility within a single substation to recognize the often complex ways \nthat large loads connect—including long-standing large industrial loads connected to the MISO \nTransmission System.  \nThe second paragraph of proposed Section 3.5.2 outlines several key requirements for ZG \nInterconnection Service.  The first is that the studies must determine that granting ZG \nInterconnection Service will not result in any injections of Energy onto the Transmission System \nbeyond the interconnecting substation except for transient injections.  This requirement is \nnecessary because limiting injection onto the broader Transmission System is the foundational \nfeature of ZG Interconnection Service, and what allows for vastly accelerated study process \noutside of the DPP.  As Mr. Keyer explains, however, there may be limited instances where a \nGenerating Facility configured to serve only co-located load may nonetheless make transient \ninjections.  This can occur where the ZG Associated Load’s demand abruptly decreases.59  Even \nwith communications and other equipment linking the Generating Facility and the ZG Associated \nLoad, it often can take a Generating Facility a small period time to lower its own production in \nresponse.  The Transient Tolerance Window recognizes this fact and allows MISO to properly \naccount for it in studies for ZG Interconnection Service, thus avoiding negative impacts to the \nTransmission System.   \nThe second proposed requirement—that granting ZG Interconnection Service will not \nrequire Network Upgrades beyond the same substation except for System Protection Facilities—\nis important to ensuring that the grant of ZG Interconnection Service is not negatively impacting \nthe rest of the Transmission System.  It is not necessary to include this limited product in DPP \nstudies because its lack of injection prevents it from having impacts on the broader Transmission \nSystem and, without impacts to mitigate, it is not necessary for these Interconnection Customers \nto be included in a regional study group.  However, this lack of interaction with other \nInterconnection Requests assumes that the Generating Facility does not drive the need for Network \nUpgrades elsewhere on the Transmission System.  If such upgrades were needed, that would both \ncall into question the lack of injection and raise cost-shifting risk for other Interconnection \nCustomers.  Therefore, the requirement that no Network Upgrades be required beyond the \ninterconnecting substation acts as a key guardrail.  The limited exception to this rule for system \nprotection facilities acknowledges that short circuit and other transient study results could require \nfacilities to be upgraded beyond the substation, even though injections will be limited to be less \n \n58  Show Cause Order at PP 89, 94-98, 112-115. \n59  Keyser at 25-26."},{"page":27,"startToken":11799,"endToken":12339,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 27 \n \n \nthan the Transient Tolerance Window.60  Such equipment is limited to that required to limit \ninjection consistent with ZG Interconnection Service.  The costs of such equipment would be borne \nentirely by the ZG Interconnection Customer, obviating the risk of cost shifts to other \nInterconnection Customers or to Load. \n \nThe third paragraph of proposed Section 3.2.5.1 provides that ZG Interconnection Service \nis restricted to serving the specific Load identified in the Interconnections Request and included \nin the ZGIA.  This requirement allows MISO to model the load in ZG Interconnection Service  \nstudies and validate that the proposed configuration is consistent with this service type. Restricting \nZG Interconnection Service to a specific load is consistent with a co-location concept and ensures \nthat the Generating Facility will operate as initially contemplated for its service life, because it has \nno authorization to serve any other load.61  The statement in the fourth sentence that ZG \nInterconnection Service does not convey Transmission Service is consistent with the currently-\neffective language in the GIP explaining that Interconnection Service does not convey \nTransmission Service.62  The instant filing does not alter the obligations of the Load/Transmission \nCustomer to obtain appropriate Transmission Service.63 \n \nThe final sentence of the third paragraph and the fourth paragraph are included to allay \nconcerns expressed during the stakeholder process that ZG Interconnection Service could be read \nas conflicting with state and local laws by allowing the owner of a generator that is not a Load \nServing Entity to serve load when not authorized to do so by state law.  The inclusion of this \nlanguage neither imposes, nor is intended to impose, any independent restrictions on an \nInterconnection Customer. \n3. Section 3.2.5.2—ZG Interconnection Service Study \nProposed Section 3.2.5.2 establishes the studies that MISO will perform for \nInterconnection Requests.  The first paragraph explains that the ZG Resource will be studied and \ngranted service at a level not to exceed the Demand of the ZG Associated Load.  This language is \nappropriate and important because ZG Interconnection Service allows the Generating Facility to \nserve only the ZG Associated Load.  Limiting the level of service to the peak Demand of the ZG \nAssociated Load effectuates this relationship and provides the necessary study inputs to allow \n \n60  Keyser at 31-32.  \n61  As discussed below, this does not prevent an Interconnection Customer that wants to use its ZG Resource to serve \na different load from obtaining ERIS or NRIS by submitting a new Interconnection Request and proceeding \nthrough the DPP and obtaining a new GIA without the injection limitations.  \n62  Tariff Attachment X at Section 2.4 (No Applicability to Transmission Service). See also, Id. at Section 1: \nDefinitions—“Energy Resource Interconnection Service (“Energy Resource Interconnection Service does not \nconvey transmission service”) and  Network Resource Interconnection Service (“Network Resource \nInterconnection Service does not convey transmission service.”). \n63  MISO is aware of the show Cause Order’s directives requiring MISO to address the Transmission Service \nimplications of various Large Load arrangements and will address them in a forthcoming 205 filing.  The current \nfiling addresses only Interconnection Service and is both independently needed as well as a building block for \nfurther Tariff constructs."},{"page":28,"startToken":12339,"endToken":12896,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 28 \n \n \nMISO to verify that the ZG Resource can serve only the ZG Associated Load.  MISO notes that \nstudying a ZG Resource at the level of service not to exceed the ZG Load does not place a limit \non the installed capacity of the ZG Resource.  Under generally applicable Tariff rules,  \nInterconnection Customers may propose Generating Facilities with a higher installed capacity than \nthe granted Interconnection Service. \n4. Sections 3.2.5.2.1 and 3.2.5.2.2—ZG Impact Assessment and ZG Facilities \nStudy \nSection 3.2.5.2.1 establishes the system impact study that will be used to Study ZG \nInterconnection Service Requests.  As explained by Mr. Keyser, this study is similar to that used \nfor ERIS evaluation, with changes necessary to accurately reflect the scope of ZG Interconnection \nService and determine its impacts.  In this respect, an examination of the electrical connection \nbetween the Generating Facility, ZG Associated Load, and the Transmission system, and the \nproposed control equipment becomes a critical aspect of the study because it is necessary to verify \nthat the limiting injections are viable under the proposed configuration.  Therefore, the ZG Impact \nAssessment will start with a close review of the diagrams and equipment lists included in the \nInterconnection Requests.  Unlike other system impact studies, the ZG Impact Assessment must \ndetermine that no Network Upgrades are needed to maintain reliability, with the stability and \nsteady state analyses testing the impact of injections if the ZG Associated Load trips offline for the \nduration of the Transient Tolerance window. \nSection 3.2.5.2.2 performs the same analysis of the specific facilities needed to \naccommodate the interconnection and is similar to the facilities studies performed for ERIS and \nNRIS Interconnection Requests  during Phases 2 and 3 of the Definitive Planning Phase,64 but with \na more limited scope reflecting that requirement that no Network Upgrades can be needed other \nthan Network Upgrades at the interconnecting substation and system protection facilities to control \ninjection onto the rest of the Transmission System.  In order to accommodate an accelerated ZG \nInterconnection Service process timeline, MISO proposes to sequence the ZG Facilities Study \ndifferently than facilities studies performed in the DPP.  Specifically, MISO proposes to begin the \nportion of the ZG Facilities Study that examines required interconnection facilities at the same \ntime MISO begins the ZG Impact Assessment.  This differs from the DPP process, where \nInterconnection Facilities studies are not started until Phase 3, after both a preliminary System \nImpact Study and a Revised System Impact Study have been performed. This approach is \nreasonable for ZG Interconnection Service because Interconnection Facilities are not dependent \non the results of the ZG Impact Assessment and thus can be studied separately or in parallel. \nRunning these studies in parallel allows MISO to have results available within 90 days from study \ncommencement, in time for the Interconnection Customer to receive a draft ZGIA.65  For the \n \n64  See Attachment X at Section 7.3.2 et seq. \n65  Due to the enhanced readiness requirements of the ZG Interconnection Service process, including higher deposits \nand an agreement with the load it will serve, MISO has reduced concern that dedicating resources to study \ninterconnection facilities at the beginning of the ZG Interconnection Service would be premature. as opposed to \nthe DPP."},{"page":29,"startToken":12896,"endToken":13321,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 29 \n \n \nportion of the ZG Facilities Study that focuses on Network Upgrades, MISO proposes to begin \nthis portion of the ZG Facilities Study upon the identification of the need for such Network \nUpgrade during the ZG Impact Assessment and no later than one business day after the end of the \nZG Impact Assessment.  This approach recognizes that a facility study to address a need cannot \nbegin before the underlying need is identified.  To expedite the study process, the proposed \nlanguage in the last paragraph of Section 3.2.5.2.2 contemplates MISO commencing portions of \nthe study responsive to Network Upgrade as early as possible during the process. This approach is \nmade practical by the limited scope of the ZG Impact Assessment and more limited Network \nUpgrades to be studied.  \n5. Section 3.3.1—Valid Interconnection Request  \nMISO proposes to add a reference to ZG Interconnection Service under the fourth \nparagraph clarifying when changes to the D1 study deposit take effect for Interconnection Requests \nseeking ZG Interconnection Service.  This revision is necessary because the current language of \nthis paragraph establishes the effectiveness of periodic increases in the D1 with respect to the \napplication deadline of study groups.  Because ZG Interconnection Requests are not studied in a \ngroup study format, it is necessary to specify the timing of D1 increases with respect to such \nInterconnection Requests.  MISO’s proposal to make such increases effective to Interconnection \nRequests seeking ZG Interconnection Service received after the date of posting such increase \nfacilitates orderly processing and ensures such increases are applied only prospectively.    \nIn the fifth paragraph, MISO proposes to add Interconnection Requests seeking ZG \nInterconnection Service to the list of Interconnection Requests subject to the $150,000 D1 payment \nin order to provide funding for these studies.  Interconnection Requests seeking ZG \nInterconnection Service and Surplus Interconnection Service currently are subject to the $150,000 \nD1 payment and the study for ZG Interconnection Service is not less complex or resource intensive \nthan these other studies to conduct. MISO submits that this requirement therefore is just and \nreasonable. \n6. Section 3.5.3—Affected System Coordination \nMISO proposes new Section 3.5.3 governing coordination with affected systems in the \nevaluation of ZG Interconnection Requests.  At the outset, MISO notes that the limited injection \nnature of ZG Interconnection Service significantly reduces the likelihood that these Generating \nFacilities will have impacts on neighboring transmission systems requiring network upgrades.  \nHowever, MISO cannot entirely eliminate the possibility that a ZG Resource could have impacts"},{"page":30,"startToken":13321,"endToken":13825,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 30 \n \n \non a neighboring Transmission System depending on their location and configuration.66  It \ntherefore is necessary to make provision for affected system coordination.67 \nProposed Section 3.5.3 closely follows the affected systems coordination procedure \naccepted for ERAS Interconnection Requests.  Specifically, proposed Section 3.5.3 provides that \nMISO will apply the same coordination procedures and screening criteria as that used for \nInterconnection Requests in the DPP with several exceptions necessary to recognize the differing \ntiming and study processes applicable to serially studied ZG Interconnection Requests.  These \nexceptions include: (1) providing ZG Interconnection Re quest to the affected system not later than \nten days prior to the start of the ZG Impact Assessment; (2) providing results to ZG Interconnection \nCustomers at such time as they are received; (3) proceeding to issue a ZGIA with an obligation to \nexecute study any affected systems study agreements within fifteen days after such agreement is \ntendered for execution to the Interconnection Customer; (4) submitting ZG interconnection \nRequests serially to affected systems; and (5) seeking a relative queue priority date based on the \ndate that the ZG Impact study begins. \nMISO submits that these rules are appropriate because they provide a structure for \nprocessing Interconnection Requests for ZG Interconnection Service rapidly and in a manner that \nrecognizes the serial nature of such studies.  Requiring ZG Interconnection Customers to execute \nZGIAs where affected systems information has not yet been provided is necessary to maintain the \naccelerated speed of the ZG Interconnection Study process and to provide certainty to ZG \nInterconnection Requests in subsequent ZQ Quarterly study groups whose models will be built \nfrom the prior completed quarterly study.  In arriving at this balance between certainty and speed, \nMISO notes that any need for mitigating impacts to an affected system is likely to be minimal and \nlargely a function of the location, configuration, and control equipment selected by the \nInterconnection Customer. \n7. Section 3.11—Additional Requirements for Interconnection Requests \nSeeking ZG Interconnection Service \nMISO proposes several additional requirements for Interconnection Requests for ZG \nInterconnection Service, which requirements are needed to ensure the limited nature of ZG \nInterconnection Service and facilitate studies consistent with this concept.  \nFirst, MISO proposes in Section 3.11(i) and (ii) to require that the Interconnection Request \nfor ZG Interconnection service include a one line diagram showing the Generating Facility and \nassociated electrical equipment and all the ZG Associated Loads including all Point(s) of \n \n66  For example, such flows could be possible if the Interconnection Customer seeking ZG Interconnection Service \nproposes a Point of Interconnection at a seam between the MISO Transmission System and a neighboring \nTransmission System.  In such circumstances, the system protection facilities that may need to be installed on \nadjacent substations may be located on a neighboring transmission system.  \n67  MISO cannot control the study processes of neighboring Transmission Providers but will work with its seems \npartners to develop any additional coordination rules necessary to appropriately model and process ZG \nInterconnection Requests."},{"page":31,"startToken":13825,"endToken":14378,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 31 \n \n \nWithdrawal and the Point of Interconnection of the Generating Facility as well as a power flow \nmodel including this data and any proposed system protection facilities. Because ZG \nInterconnection Service is restricted to serving a specified load, the ZG Associated Load, \nsubmission of detailed and accurate one line diagrams and power flow models showing both the \nGenerating Facility, the ZG Associated Load, protection facilities, and their configuration with \nrespect to the Transmission System is critical to accurately studying how a proposed ZG Resource \nwill interact with the Transmission System and ensuring limited impacts.  In addition, it is essential \nto document this configuration in the resulting ZGIA because the results of the ZG Impact Study \nwill depend on the proposed configuration remaining as proposed.  Subsection (ii) contains the \ncrucial limitation that Point of Interconnection of the Generating Facility and a Point of \nWithdrawal for the ZG Associated Load be at the same voltage level of a common substation.  This \nrestriction is necessary to ensure the limited interaction with the rest of the Transmission System \nthat underpins ZG Interconnection Service.  \nSecond, proposed subsection (iii) requires that the grant of ZG Interconnection Service not \nrequire the construction of Network Upgrades beyond the substation where the Point of \nInterconnection is located other than System Protection Facilities.  As explained by Mr. Keyser, \nthis requirement complements and enforces the expectation that ZG Interconnection Service can \nbe granted without adversely impacting the broader transmission system.  A proposed \ninterconnection that triggers a need for Network Upgrades elsewhere on the system would not be \nconsistent with the intended scope of the service as it assumes an impactful injection.  \nInterconnection Requests with such impacts are better processed through the DPP where they can \nstudy in a cluster with other Interconnection Requests with potential impacts on the broader \nTransmission System and mitigation costs than under the ZG Interconnection Service process \nproposed herein. \nThird, MISO proposes to require that an Interconnection Request for ZG Interconnection \nservice be submitted 180 Calendar Days before the earlier of the Commercial Operation Date of \nthe Generating Facility or the need-by date for the ZG Associated Load.  The reason for this \nrequirement is to allow MISO sufficient time to study the proposed interconnection, including the \ninformation on both the Generating Facility and the ZG Associated Load included in the \nInterconnection Request, and to provide time for other processes that must be completed prior to \ncommercial operation and the need by date.68  Further, this requirement allows sufficient time for \nthe subsequent MTEP study of the ZG Associated Load to take place. The limited exception to the \nrequirement to submit 180 days in advance of the need-by date is necessary to allow the ZGIA \nProcess to be used by loads that already are online who, in the absence of such an exception, would \nnot be able to utilize this process.  \nFourth, MISO proposes to limit the amount of ZG Interconnection Service to the total \nDemand69 of the ZG Associated Load.  Because ZG Interconnection Services may be used only to \n \n68  Attachment X at proposed Section 3.11.iv. \n69  As defined in MISO’s Tariff, “Demand” refers to the peak demand.  Module A—Definitions: Demand: (“The \nmaximum integrated hourly sum of Load occurring over a specified period, such as Day, Month, Season, or"},{"page":32,"startToken":14378,"endToken":14928,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 32 \n \n \nserve ZG Associated Load, authorizing a service level that is higher than what the ZG Associated \nLoad has been studied to require would be inconsistent with the limited nature of this product.  \nMISO again notes that the limitation on service does not limit the installed capacity of the \nGenerating Facility.  As Mr. Keyser explains in his testimony, this approach recognizes the \ndiffering dispatch levels of various fuel types and allows the Interconnection Customer flexibility \nto build the installed capacity that they require to serve the ZG Associated Load. \nFifth, the Interconnection Request must include modeling and other technical data as \ndescribed in MISO’s Generator Interconnection Business Practices Manual for the ZG Associated \nLoad in order to enable MISO to study the connections between the Generating Facility, ZG \nAssociated Load, and the Transmission System in order to verify that ZG Interconnection Service \ncan be granted and understand impacts to the Transmission System.  Including the specific \ntechnical data needed in the Business Practices Manual is consistent with requirements for other \ntypes of Interconnection Requests and provides needed flexibility to update specific technical \ndetails as MISO and its stakeholders gain experience with ZG Interconnection Service Requests. \nSixth, MISO proposes to require the Interconnection Customer to submit an executed \nagreement between itself and the entity with the ZG Associated Load specifying that the full output \nof the Generating Facility is intended to be used by the ZG Associated Load, with an expected \nterm of at least five years.70  This requirement is necessary both to prevent speculative \nInterconnection Requests,71 and verify that the load intends to use the output of the Generating \nFacility.  In the context of ZGIA, the agreement takes on added importance because the \nInterconnection Request must include detailed diagrams and technical information pertaining to \nthe ZG Associated Load.  It therefore is imperative to verify that the ZG Associated Load has \nmature arrangements with the owner of the Generating Facility in order for MISO to rely on their \ntechnical information in conducting studies. \nThe language of the agreement requirement is based on, and largely identical to, the \nrequirements applicable to ERAS Interconnection Requests72 with several differences warranted \nby the design and purpose of ZG Interconnection Service.  First, ZG Interconnection Service \nimposes a requirement that the ZG Associated Load at least intend to use the output of the \nGenerating Facility for at least 5 years.  As Mr. Keyser explains in his testimony, this requirement \nexists because when MISO studies transmission service for the ZG Associated Load as part of the \ntransmission planning process, the ZG Resource may be relied upon as an alternative mitigation \nto Transmission System Upgrades.  To consider this as an alternative mitigation, MISO must have \n \nYear, expressed in MWs.”).  Under this definition, MISO tracks the highest level of load demand as the \nmaximum.  \n70  Attachment X at Proposed Section 3.11(vii). \n71  ZG Interconnection Service is only useful if the Interconnection Customer and entity with the ZG Associated \nLoad (or the obligation to serve it) have already agreed to use the Generating Facility specifically for that load.  \nIf such an agreement does not exist then an Interconnection Request for ZG Interconnection Service is, at the very \nleast, premature.  \n72  Attachment X at currently effective Section 3.9.1(2)."},{"page":33,"startToken":14928,"endToken":15471,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 33 \n \n \nsome confidence that it will be available for at least the five-year planning horizon.  This said, \nMISO acknowledges that it may be difficult for Interconnection Customers and ZG Associated \nLoads to agree to a firm minimum term of at least five years.  To accommodate these commercial \nconsiderations, MISO therefore only requires that the agreement specify an intent to use the full \noutput of the Generating Facility for at least five years rather than a firm commitment.  MISO \nviews this as the minimum level of certainty needed to rely on the ZGIA in transmission service \nstudies.73  Second, MISO has proposed an acknowledgement of self-supply as a permissible \nmechanism for satisfying the agreement requirement where the Interconnection Customer is the \nentity that owns the ZG Associated Load.  This is intended to recognize that, in many states within \nthe MISO footprint, Load is permitted to service itself with its own onsite generation.  The \nacknowledgment requires the Interconnection Customer to verify that they both intend and are \npermitted by applicable law to do this.74 \nThe remaining four forms of agreement are identical to those accepted for the ERAS \nprocess and, given the flexibility included for an “other agreement” under proposed Section \n3.11(viii)(d), provide sufficient flexibility to account for a wide array of commercial arrangements \nwhile still acting as a process safeguard.  \nSeventh, MISO proposes to include a requirement that a ZG Interconnection Request not \ninclude a request for any other type of Interconnection Service.75  This requirement is needed \nbecause the underlying non-injection assumptions behind ZG Interconnection Service would \nconflict with pairing this with other kinds of Interconnection Service, which authorize injections.76  \nThis requirement also facilitates MISO’S study of ZG Interconnection Service as a more limited \nproduct in an accelerated timeframe. This language does not prevent an Interconnection Customer \nfrom submitting a separate Interconnection Request for another type of Interconnection Service \nfor the same Generating Facility using the process specified by these Generator Interconnection \nProcedures for such request type.  In the event that an Interconnection Customer obtains another \nform of Interconnection Service for the same Generating Facility, such service shall be deemed to \nsupersede any previously-granted ZG Interconnection Service upon its effective date. MISO does \nnot intend this requirement to preclude an Interconnection Customer from separately or later \nseeking another form of Interconnection Service and includes language in the second and third \nsentence of this subsection that expressly allows the Interconnection Customer to separately obtain \nsuch service and have it supplant the more limited ZG Interconnection Service upon its effective \ndate.  This would allow, for example, an Interconnection Customer to obtain ZG Interconnection \nService rapidly to address an urgent need-by date for its associated load while separately pursuing \nNRIS through the DPP. \n \n73  Should the Generating Facility ceased to be used by the ZG Associated Load, MISO likely would need to restudy \nthe impacts of transmission service for that Load and either delay the service date or suspend service for that load \nwhile an alternative mitigation is found in order to prevent adverse reliability impacts to the Transmission System. \n74  Attachment X at Proposed Section 3.11(viii)(e). \n75  Attachment X at proposed Section 3.11(ix).  \n76  Keyser at 15."},{"page":34,"startToken":15471,"endToken":16034,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 34 \n \n \n8. Sections 3.11.1 and 4.4—Modification of Interconnection Requests for ZG \nInterconnection Service \nMISO proposes new Section 1.11.1 to prohibit modifications to ZG Interconnection \nRequests after submission.  This prohibition is necessary and reasonable given the 90-day \ntimeframe for studies of Interconnection Requests for ZG Interconnection Service. To make this \ntimeframe workable and avoid delays that would impact other Interconnection Customers, it is \nnecessary to require that these Interconnection Services be well-considered and provide certainty \nwith respect to the details to be studied at the time they are submitted.  This readiness requirement \nis mitigated by the fact that MISO will study ZG Interconnection Requests on a quarterly basis.  \nTherefore, an Interconnection Customer that is not certain of the details to be included in its \nInterconnection Request would only need to wait until the following quarter for another \nopportunity to be studied.   \n \nSection 3.11.1 includes one exception made necessary by process sequencing.  MISO \nproposes to require, and therefore allow, the ZG Interconnection Customer to move its Point of \nInterconnection to the Transmission System if the ZG Associated Load subsequently moves the \nPoint of Withdrawal to not be at the same substation and voltage level as the Point of \nInterconnection.  In such circumstance, the Interconnection Customer would need to move its \nproposed Point of Interconnection to match the move made by the ZG Associated Load. MISO \nproposes to permit this move for several reasons.  First, because the premise of ZG Interconnection \nService is based on the relative location of the ZG Associated Load and the ZG Resource, it is \nmore important from a system impact study perspective to prevent the Point of Interconnection \nand Point of withdrawal from separating than it is to prevent the Point of Interconnection from \nmoving if the load’s location moves.77  Second, MISO expects that Interconnection Requests for \nZG Interconnection Service often will be submitted to MISO before transmission service is \nrequested by or on behalf of the ZG Associated Loads.  This sequencing allows MISO to consider \nthe executed ZGIA in the transmission service study. Because the Interconnection Request for ZG \nInterconnection Service likely will precede the transmission service study process, it is not \npractical to hold the load to a proposed Point of Withdrawal before it has even submitted its own \napplication; doing so would undermine the scoping discussions between the load, its Load Serving \nEntity, and the applicable Transmission Owner that occur during the load study process. This is \ntrue under MISO’s current Tariff and business practices surrounding load integration studies and \nMISO expects this sequencing to continue under other study processes currently being developed \nto address the concerns raised in the Show Cause Order.  MISO therefore submits that both the \ngeneral prohibition on modifications and the Point of Withdrawal move exception are reasonable.  \n \n \nConsistent with proposed Section 3.11.1, MISO proposed to add a new paragraph at the \nend of Section 4.4 (Modifications) to implement the move of a POI to correspond to a POW move.  \nThe proposed new language reiterates the requirement to move the POI when the POW moves and \nrequires that this be done prior to the change taking effect, which is necessary to allow MISO to \nstudy the impact of the move.  When such a change is submitted, MISO would revalidate the \n \n77  Keyser at 28-29."},{"page":35,"startToken":16034,"endToken":16570,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 35 \n \n \nInterconnection Request and determine whether it has material adverse impacts. If such impacts \nare identified, the Interconnection Request will be assigned a new queue position.  This is \nconsistent with existing tariff rules on material impacts applicable to Interconnection Requests.  \nThe final proposed sentence addresses the situation in which such a modification occurs after the \nZGIA has become effective, requiring a restudy and an amendment to document such restudy and \nany associated costs, or terminate the ZGIA within 60 Calendar Days after the restudy is \ncompleted.  This language recognizes that an Interconnection Customer may not have any ability \nto control the timing of the Load’s transmission service study process and that such changes may \nneed to be made even after the ZGIA is completed.  The proposed language prevents negative \nimpacts to other Interconnection Customers from post-ZGIA changes and facilitates timely \ncoordination between the ZG Interconnection Service Customer and its ZG Associated Load. \n \n9. Section 3.11.2 Evaluation Process and Study Limits  \n \nMISO proposes a quarterly study cadence for ZG Interconnection Service Interconnection \nRequests as well as a limit of ten such Interconnection Requests per quarter.  The quarterly cadence \naligns with the expected duration of the ZG Impact Assessment in order to avoid overlapping \nstudies.  MISO determined that 10 such Interconnection Requests is an appropriate quarterly limit \nbecause it balances opportunities for prompt study with avoiding the reduction of personnel and \nresources needed to process the DPP, which will remain the primary focus of MISO’s \ninterconnection process.  ZG Interconnection Service, while valuable, is a niche tool.  MISO does \nnot expect to receive more than ten such Interconnection Requests a quarter as the process matures.  \nThe proposed limit thus is a safeguard in case ZGIAs prove more popular than expected. \n \nIn order to avoid undue disruption to the DPP, MISO proposes to allow Interconnection \nRequests in the DPP to withdraw and commence the ZG Interconnection Service study process \nonly if they have not yet reached Decision Point II of their DPP cycle. This avoids the risk of \nunscheduled restudy to other DPP Interconnection Requests because Interconnection Customers \ncurrently can withdraw from the DPP at Decision Point II with such withdrawals being accounted \nfor in Phase 3 of the DPP.  For the same reason, MISO does not propose to excuse withdrawing \nInterconnection Requests from the currently-applicable penalty provisions of Section 7.6.2.1.1 and \n7.8 of the DPP.  The prohibition withdrawals after Decision Point II will be enforced through a one \nyear waiting period before an Interconnection Request for the same project can be processed for \nZG Interconnection Service.  MISO believes that this is a sufficient deterrent against late stage \ntransfers.   \n \n10. Section 3.11.3—ZG Interconnection Service-Notice to Proceed  \n \nProposed Section 3.11.3 provides that the Interconnection Customer shall inform MISO \nwhether it intends to proceed to a ZGIA within 5 Business Days after having received the results \nof the ZG Impact Analysis.  As noted above, MISO has designed the process to allow for the \nsimultaneous commenced of the portion of the ZG Facilities Study focusing on Interconnection \nFacilities at the same time as the ZG Impact assessment commences.  Given the same 90 Calendar"},{"page":36,"startToken":16570,"endToken":17114,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 36 \n \n \nDay timeline, the Interconnection Customer therefore should have results from both of those \nstudies at the time it elects to proceed to ZGIA.  \n \nMISO’s proposed process also allows for the commencement of ZG Facilities Studies as \nthe needs driving them become identified.  While this admittedly does not guarantee that the \nportion of the ZG Facilities Study focused on Network Upgrades will be completed at the time an \nelection to proceed must be made, MISO believes that this tradeoff is reasonable to allow for a \nquarterly study process and facilitate the rapid interconnection of co-location arrangements with \nshort need-by dates.  In reaching this conclusion, MISO considered the fact that the planning-level \ncosts for addressing system impacts will be provided in the ZG Impact Assessment, with the ZG \nFacilities Study focusing more on the specific design details of the Network Upgrade.  Thus, an \nInterconnection Customer will have this cost information at the time it must elect to proceed.  \nSecond, given the limited scope of potential Network Upgrades that can be required in a process \nthat does not allow for Network Upgrades other than system protection facilities beyond the \ninterconnecting substation, both the risk and uncertainty of potential Network Upgrade costs is far \nmore limited in the ZG Interconnection Service process than under other processes where \nsignificant Network Upgrades on other parts of the Transmission System may be required.  For \nsimilar reasons, and as noted above, MISO also will not delay the election to proceed until the \nreceipt of any affected systems analysis.  \n \n11. Section 3.11.4—ZGIA for ZG Generating Facility  \n \nProposed section 3.11.4 provides that MISO will tender a draft pro forma ZGIA or \namendments within 5 Business Days after receiving the Interconnection Customer’s Notice to \nProceed.  This accelerated timeframe reflects a shortening of the DPP’s deadline to tender a ZGIA \nfrom 30 Calendar Days to 5 Business Days and is consistent with the equivalent shortening of the \nInterconnection Customer’s time to elect whether to proceed from 30 Calendar Days to 5 Business \nDays in Section 3.11.3.  This section further reinforces MISO’s obligation to complete all portions \nof the ZG Facilities study by the specified deadline.78   \n \n12.  Section 11.1-11.3—Tender, Negotiation, Execution, and Filing Processes \nMISO proposed revisions to Sections 11.1 (Tender), 11.2 (Negotiation), and 11.3 \n(Execution and Filing) to list ZGIAs along with the currently referenced GIAs and EGIAs as forms \nof agreements subject to the tender, negotiation, and execution processes.79  In designing the ZG \nInterconnection Service process, MISO determined to align the tender, negotiation, and execution \n \n78  As a practical matter, this will refer only to the portion of the ZG Facilities Study examining Network Upgrades \nbecause the portion focusing on Interconnection Facilities must be completed on the same timeframe as the ZG \nImpact Analysis whereas the portion of the ZG Facilities Study addressing Network Upgrades cannot begin until \nthe impact requiring such Network Upgrade to address is identified through the ZG Impact Assessment.  However, \nas previously noted, this need not delay the tender of a draft ZGIA because the costs of needed Network Upgrades \nwould be identified in the ZG Impact Analysis.  \n79  Attachment X at Sections 11.1—11.3."},{"page":37,"startToken":17114,"endToken":17592,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 37 \n \n \nand filing periods with the timeframes applicable to EGIAs rather than standard GIAs in order to \nexpedite the agreement process.  Building on MISO’s previous experience with ERAS, these  \naccelerated timeframes represent the amount of time MISO believes is practical to reduce \ntimeframes while maintaining a robust, detail-oriented process.  Like EGIAs, ZGIAs are intended \nfor ready projects where the load and generator already have an agreement.  Under the ZG \nInterconnection Service process, specific configuration details as between generation and load \nmust be planned in advance in order to be included in the Interconnection Request for ZG \nInterconnection Service, and the potential Network Upgrades as more limited than either under \nERAS or the DPP.  Thus, MISO submits that it is reasonable to accelerate the tender, negotiation, \nexecution, and filing processes for ZGIAs to match other expedited process timeframes. \n13. Miscellaneous Revisions to Attachment X  \nIn addition to the foregoing, MISO also proposes conforming revisions to other portions \nof Attachment X to list the ZGIA or ZG Interconnection Service in Tariff Sections listing other \ntypes of service or agreements.  Specifically, MISO proposes the following revisions: \n• Section 2.1 (Application of Generator Interconnection Procedures: MISO proposes new \nsubsection (j) providing that a Request for ZG Interconnection Service is within the scope \nof the GIP. \n• Section 3.2 (Identification of Types of Services): MISO proposes to add ZG \nInterconnection Service to the list of service types. \n• Section 11.4 (Commencement of Interconnection Activities): MISO proposes to add \n“ZGIAs” where GIAs are listed to clarify that these provisions also apply to ZGIAs. \n• Sections 13 (Confidentiality) including subsections 13.1, 13.4, 13.5.1, 13.5.2, 13.6: MISO \nproposes to add “ZGIAs” where GIAs are listed to clarify that these provisions also apply \nto ZGIAs. \n• List of Appendices to GIP:  MISO proposes to add the JTIQ Commitment Agreement an \nZG Interconnection Agreement to the list of Appendices.  This is a ministerial change.  The \nJTIQ Commitment Agreement is accepted by the Commission and not in any way changed \nby this filing.  MISO here is simply adding it to the list.  \n \nE. \nAttachment X – Appendix 1 (Interconnection Request for a Generating \nFacility). \n \nMISO is proposing to revise this Appendix to integrate the ZGIA framework into the \ninterconnection request form.  These revisions include adding new options for interconnection \nrequests and interconnection service to accommodate the new ZG Interconnection Service, \nconfirm that the amount of ZG Interconnection Service cannot exceed the total amount of its ZG \nAssociated Load, requirements to describe the ZG Associated Load and facilities to connect to the \nTransmission System, along with System Protection Facilities or operating procedures to prevent \ninjections onto the Transmission System beyond the substation and voltage level where the \nResource is located, and requirements for the disclosure of additional information for MISO to \nevaluate the request.  The specific changes are:"},{"page":38,"startToken":17592,"endToken":18004,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 38 \n \n \n \n• Section 2: MISO has added a new checklist item for a Generating Facility to indicate the \nrequest is for processing through the ZG Interconnection Service study process. \n \n• Section 3: MISO has added a new checklist item to select ZG Interconnection Service as \nthe requested service type.  \n \n• Section 4: MISO has added a new row for ZG Interconnection Service to the table of \nrequired information by type of service requested. This row requires the Interconnection \nCustomer to indicate the MW/MVAR of the request and states that the amount of ZG \nInterconnection Service cannot exceed the total Demand of the ZG Associated Load.  \n \n• Section 9:  MISO has added new Section 9 requiring the Interconnection Customer to \nprovide a description of the ZG Associated Load, including its need by date, and \nconnecting facilities, system protection facilities, and any proposed operating \nrequirements necessary to prevent injections beyond the interconnecting substation.  This \ninformation is critically important in evaluating the potential impacts of the Generating \nFacility. \n \n• Attachment A-5: MISO has added a new paragraph below the dynamic modelling \ninformation required for other types of Interconnection Requests to require \nInterconnection Customers seeking ZG Interconnection Service to provide a detailed \npower flow model that includes all ZG Associated Loads, their Point(s) of Withdrawal and \nthe POI for the Interconnection Request, as well as system protection facilities.  This \nprovides necessary information for MISO to study the Interconnection Request.  \n \n• Attachment A-6: MISO has added a paragraph requiring the one line diagram submitted \nwith a ZG Interconnection Request to include all ZG Associated Loads and their Point(s) \nof Withdrawal in order to facilitate accurate study of the Generating Facility and ZG \nAssociated Load. \nMISO submits that these requirements are just, reasonable, and necessary to the performance of \nZG Interconnection Service given the centrality of the configuration of the Generating Facility and \nZG Associated Load to this new type of service.  \nF. \nAttachment X – Appendix 19 (ZG Interconnection Agreement (“ZGIA”)).   \nMISO is proposing to add a new Appendix 19 to Attachment X, titled “ZG Interconnection \nAgreement” (“ZGIA”).  This new appendix contains the ZGIA to be executed between the \nInterconnection Customer, the Transmission Owner, and MISO, and contains the material \nprovisions relating to ZG Interconnection Service.  At the outset, MISO notes that it developed the \nrevisions to its pro forma Generator Interconnection Agreement needed to accommodate ZG \nInterconnection Service to fit as an option within the same pro forma agreement currently used for"},{"page":39,"startToken":18004,"endToken":18535,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 39 \n \n \nall other types of Interconnection Service—Attachment X, Appendix 6.80  MISO proposes the \nZGIA a new Appendix 19 to the GIP in this filing as a pragmatic means of avoiding potential \nadministrative impacts to the rest of the queue.  MISO currently anticipates that DPP cycles \nscheduled to proceed to GIA in the next 6 months to result in hundreds of GIAs being negotiated, \nexecuted, and submitted to the Commission for existing service types.  Introducing new revisions \nto the pro forma GIA at this time would complicate this process considerably and risk processing \ndelays81  Incorporating these revisions temporarily into a new Appendix 19 avoids these \ncomplications.  MISO intends to make a subsequent 205 filing, following the acceptance of the \nrevisions proposed in this docket to incorporate the provisions of Appendix 19 into Appendix 6 \nand remove Appendix 19 from the Tariff82 with a proposed effective date timed to avoid agreement \nexecution processing disruptions.   \nMISO includes the foregoing discussion because it is necessary to explain the structure of \nthe revisions proposed herein.  MISO views the proposed ZGIA as part of its GIA construct rather \nthan as a separate agreement. MISO therefore has not proposed to eliminate accepted language \ncontained in Appendix 6 or develop a customized agreement tailored only to ZG interconnection \nService.  MISO therefore discusses the Tariff language herein as revisions to the existing pro forma \nGIA (Attachment X Appendix 6) that ultimately will be housed therein and requests the \nCommission review them in that light.83  To facilitate discussion, revisions to the pro forma GIA \nare grouped by article and appendix below: \n1. Revisions to Recitals  \nMISO proposes a new third recital for use in the ZGIA that explains that the output of the \nGenerating Facility will be used to serve the ZG Associated Load. Including this recital provides \nclarity about what the ZGIA does at the front of the document.84  MISO also proposes to revise the \nfinal recital to remove the reference to a Provisional Generator Agreement because MISO has not \nproposed to develop a provisional ZGIA.85 \n \n80  Attachment X—Appendix 6 is used for ERIS, NRIS, Generating Facility Replacement, Surplus Interconnection \nService, etc.  \n81  The group nature of DPP studies means that studies complete and GIA processing deadlines become due in waves. \nPutting this version of the pro forma GIA in a new appendix avoids versioning issues that could otherwise impact \ninterconnection Customers, especially if compliance is required.   \n82  Because Appendix 19 is built on the current version of the pro forma GIA, the subsequent filing would largely be \nministerial.  MISO would select an effective date that avoids disruption to Interconnection Customers. \n83  Consistent with this approach, MISO has included as Tab D to this filing a redline comparing Attachment X—\nAppendix 19 to Attachment X—Appendix 6. \n84  When merged with Appendix 6, MISO would include this recital in brackets indicating it is to be used only for \nZGIAs. \n85  MISO has not proposed a provisional ZGIA in part because the ZG Interconnection Process is rapid and in part \nbecause the ZG Impact assessment is necessary to verify non-injection.  MISO will address how this recital would"},{"page":40,"startToken":18535,"endToken":19054,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 40 \n \n \n2. Revisions to Article 1—Definitions \nMISO proposes to include the same new and revised definitions in the ZGIA that are \nproposed for inclusion in the GIP.   The proposed  terms and definition language is identical to that \ndescribed above for GIP revisions except for non-substantive edits needed to reflect the location \nof the definition in the ZGIA rather than the GIP.86  MISO refers to its discussion above and asks \nthat the Commission accept the definition changes as just and reasonable for the reasons explained \nin the discussion of these changes.  \n3. Revisions to Article 2—Effective Date, Term, and Termination  \nMISO proposes to include a sentence after the second sentence of Article 2.3.1 clarifying \nthat for the purposes of the ZGIA, Commercial Operation refers to supplying Energy to the ZG \nAssociated Load and excludes commercial arrangements with other parties.  This provision \nensures consistency with the limited nature of ZG Interconnection Service and avoids potential \nconfusion about what constitutes “Commercial Operation” for a ZG Resource.  \nIn addition, MISO also proposes to revise Article 2.4.1 regarding cancellation of Network \nUpgrades and Interconnection Facilities in the event of termination to provide that the financial \nimpact analysis performed under Section 7.8 of the GIP and the Automatic Withdrawal Penalty \nunder Section 7.8.1 are not applicable to ZGIAs.  These revisions are appropriate because ZG \nInterconnection Service does not proceed through the Definitive Planning Phase and thus do not \npay DPP milestones, DPP Decision Points, or have other Interconnection Requests in their study \ngroup.  Thus, these GIP provisions would not apply to ZG Interconnection Requests. The revisions \nto Article 2.4.1 thus avoid potential confusion about the applicability of DPP provisions to ZG \nInterconnection Service Requests being terminated after a ZGIA has been issued.  The non-\napplicability of GIP Sections 7.8 and 7.8.1 is reasonable for the additional reason that ZG \nInterconnection Service Requests cannot trigger the need for Network Upgrades beyond the \ninterconnecting substation except for system protection facilities at the adjacent substation and \ntheir Interconnection Requests are not expected to have material impacts on Interconnection \nCustomers in the DPP. \n4. Article 4—Revisions to Scope of Service \nMISO also proposes to include new sections 4.1.4 through 4.1.4.2 into the ZGIA and add \na sentence to the end of Article 4.3 describing ZG Interconnection Service and its Transmission \nService implications.  The language of these sections is functionally identical to its counterpart in \nGIP Section 3.2.5.1 and is just and reasonable for the same reasons discussed with respect to that \nsection.  MISO again notes that the ZGIA does not alter existing requirements, obligations, or \nprocesses with respect to obtaining Transmission Service.  MISO intends to address Transmission \n \nbe made applicable only to ZGIAs once Appendix 19 and Appendix 6 are merged in the subsequent 205 filing \nthat merges them.  \n86  These changes consists of revising “these GIP” to “the GIP” in Appendix 19 in order to avoid confusion.  The \nchange is not intended to be substantive."},{"page":41,"startToken":19054,"endToken":19462,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 41 \n \n \nService, including the provision of Transmission Service to co-located loads, in a separate 205 \nfiling.  \n5. Article 7—Revisions to Metering and Market Registration Requirement \n \nMISO proposes to add a sentence to the end of Article 7.1 of the ZGIA a requirement that \nInterconnection Customers granted ZG Interconnection Service must install and meter separately \nfrom any metering used for the ZG Associated Load.  In addition, MISO proposes new Article \n7.1.1 establishing a market registration requirement for ZGIAs, as follows: \n \n \n7.1.1: Market Registration:  An Interconnection customer with a Generating \nFacility granted ZG Interconnection Service greater than 5 MW shall submit a \ncompleted Market Participant Application pursuant to Section 38.2 et seq. of the \nTariff (Module C) not later than thirty (30) Calendar Days after the executing or \nrequesting the unexecuted filing of this Agreement  Interconnection Customer with \nZG Interconnection Service shall take all steps required by the MISO Tariff and \napplicable Business Practices Manual to complete registration as a Generation \nResource, Energy Storage Resource, or Dispatchable Intermittent Resource based \non its applicable operating characteristics prior to its Commercial Operation Date \nand shall maintain such registration for the duration of its ZG Interconnection \nService.87 \n \n \nThe reason for these requirements is to provide a mechanism for accurately measuring \nflows between the ZG Generator and ZG Associated Load, which facilities charges and credits, \nand serves as a mechanism for verifying compliance with the Interconnection Service limits under \nthe ZGIA.  With respect to market registration, Mr. Keyser explains that ZG Resources and their \nZG Associated Loads are allocated a share of market-distributed costs and that some market \ncharges, such as ancillary services for load, and administrative charges, are billed based on gross \nMW volumes in the Day-Ahead and Real-Time markets.88  Requiring ZGIA Resources to register \nas market resources is needed to allow the MW volumes for both load and generation to be captured \nseparately, resulting in appropriate billing of these charges.89  Including this requirement also \nallows the ZGIA construct to respond to the concerns the Commission raised in the Show Cause \nOrder relating to ensuring that loads participating in co-location arrangements are properly subject \nto transmission service and ancillary service rates.90 \n \n6. Revisions to Article 9.7—Outages and Interruptions \n \n \n87  Attachment X, Appendix 19 at proposed Article 7.1.1. \n88  Keyser at 38. \n89  Id.  \n90  Show Cause Order at PP 95-96."},{"page":42,"startToken":19462,"endToken":19959,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 42 \n \n \n \nMISO proposes to add new article 9.7.4.7 establishing the obligation of a Generating \nFacility with ZG Interconnection Service to reduce production of energy under certain conditions.  \nThe new requirement provides, in relevant part: \n \n \n…a Generating Facility with ZG Interconnection Service shall: \na.  Install communications and monitoring equipment to enable it to monitor the \ndemand of the ZG Associated Load. \nb. Install equipment to enable the Generating Facility with ZG Interconnection service \nto reduce its injections to a level that does not exceed the Demand of the ZG \nAssociated Load within the Transient Tolerance Window. \nc. Cease all injection of Energy onto the Transmission System within the time permitted \nby the Transient Tolerance Window in the event that any Transmission Facility over \nwhich Energy must flow in order to reach the point of interconnection or Point of \nWithdrawal of the ZG Associated Load trips offline.  \n \nThe equipment to be used by the Generating Facility with ZG Interconnection Service to \ncomply with the requirements of this 9.7.4.7 shall be identified in Appendix A of this \nZGIA.  Appendix A of this ZGIA shall include a one line diagram showing the Generating \nFacility and associated electrical equipment with appropriate rating and impedance \ninformation and all the ZG Associated loads including all Point(s) of Withdrawal and the \nPoint of Interconnection of the Generating Facility to the Transmission System for the \nInterconnection Request.91 \n \nThese requirements to install monitoring and communication equipment to monitor the \ndemand of the ZG Associated Load, install equipment that enables the Generating Facility to \nreduce injections to a level that does not exceed Deman and to actually reduce its output within \nthe Transient Tolerance Window are key features of the ZGIA and necessary to enabling the ZG \nInterconnection Service construct to function as intended.  The premise of ZG Interconnection \nService is that injections beyond the interconnecting substation can be limited and that energy will \nflow to the ZG Associated Load.  Therefore, if there is a decrease in the ZG Associated Load’s \ndemand, it is important to correspondingly reduce the output of the ZG Resource to prevent power \nfrom flowing out onto the Transmission System.  The requirements of subsection 9.7.4.7(a) ensure \ncommunications between the ZG Resource and ZG Associated Load.  This works with the \nrequirements of 9.7.4.7(b) to install equipment capable of enabling the Generating Facility to \nreduce its Load within the Transient Tolerance Window and the requirements of 9.7.4.7(c) to \nactually cease injections if an element of any Transmission Facility over which energy flows trips \noffline.   \n \n \nMISO has built flexibility into framework for the Interconnection Customer to select the \nequipment that it believes is most appropriate for its configuration by listing this in its \nInterconnection Request.  MISO will verify that the ZG Resource can limit injections as proposed \n \n91  Attachment X Appendix 19 at proposed Article 9.7.4.7."},{"page":43,"startToken":19959,"endToken":20483,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 43 \n \n \nand will document the required equipment and configuration in Appendix A of the GIA.  Article \n9.7.4.7 makes this an enforceable term of the ZG Interconnection Service granted. \n \n \nIn addition, MISO proposes to add a sentence at the end of Article 9.7.5 (Requirements for \nProtection) clarifying that for ZG Resources, transient injections do not violate the requirements \nof that article as long as they remain within the Transient Tolerance Window.  This language is \nreasonable because it recognizes that the Generating Facility may not be able to switch of \ninstantaneously and instead sets its obligation to be consistent with the Transient Tolerance \nWindow, which is incorporated into the ZG Impact Analysis.  This sentence references the \nBusiness Practices Manual for Large Load given the technical nature of the requirement.  This \nappropriately balances the certainty providing the parameters of the Transient Tolerance Window \nestablished through its definition in the Tariff with needed flexibility to define how the Transient \nTolerance Window is applied under specific conditions as MISO develops its Business Practices \nManual revisions through the stakeholder process.  \n \n7. Revisions to Article 11.3—Network Upgrades, System Protections \nFacilities, and Distribution Upgrades \nMISO proposes to include two new sentences at the end of section 11.3 stating that the \nGenerating Facility with ZG Interconnection Service must connect at the same voltage level and \nsubstation as the Point(s) of Withdrawal for the ZG Associated Load it serves and not require the \nconstruction of Network Upgrades beyond the substation where the Point of Interconnection is \nlocated other than System Protection Facilities.  This language restates the requirements of GIP \nSection 3.11(ii) and (iii) for a proposed Generating Faciltiy, ensuring that these requirements are \nreflected in the resulting ZGIA.  \n8. ZGIA Appendices \nMISO proposes several revisions to Appendix A in order to implement ZG Interconnection \nService.  First, MISO proposes to include a new Section 2 that identifies the MW, Point(s) of \nWithdrawal and need by date of the ZG Associated Load.  This section requires a single line \ndiagram illustrating the connections between the Generating Facility, ZG Associated Load, and the \nTransmission System and the identification of the equipment and configurations that prevent \ninjections outside of the Transient Tolerance Window.  This section reflects the technical \nrequirements applicable to ZG Interconnection Service and makes the studied equipment and \nconfiguration a part of the ZGIA that can be enforced.  This requirement works with MISO’s \nmaterial modification rules in the same way that section 1 operates to ensure that changes to the \nconfiguration of the AG Associated Load that could affect the impacts of the ZG Interconnection \nService as studied are subject to the same modification rules applicable to the Generating Facility \nunder Section 1 of Appendix A.  This is necessary and appropriate given the importance of these \nconfiguration details to the provision of ZG Interconnection Service. \nIn appendix B, MISO proposes new milestone 1h requiring the Interconnection Customer \nto submit a completed Marekt Participant Application within 30 Calendar days after execution or \nthe request for an unexecuted filing of the ZGIA.  MISO also proposes a milestone 18 requiring"},{"page":44,"startToken":20483,"endToken":20980,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 44 \n \n \nthe Interconnection Customer to complete the market registration process before its commercial \noperation date.  These milestones implement the requirements proposed for inclusion in ZGIA \nArticle 7.1.1.  MISO proposes an obligation to begin the market registration process as well as a \nrequired completion date because, in MISO’s experience, market registration can take several \nmonths from the time a completed application is submitted.  As explained above, market \nregistration is needed in order to inform transmissions service and ancillary services rates \napplicable to the ZG Associated Load. Therefore the process must be completed prior to \nCommercial Operation.  Requiring that the application be started early in the process avoids \nsurprises to the Interconnection Customer near the end of the development process that could delay \nCommercial Operation because it allows MISO and the Interconnection Customer to work together \nto resolve any deficiencies or other problems with the market registration process early to avoid \npotential delays.  This is consistent with the approach accepted as part of MISO’s Joint Targeted \nInterconnection Queue framework, which imposes similar market application submission and \ncompletion requirements.92  \n9. Miscellaneous  Revisions \nMISO has revised references to the “GIA” to instead refer to the “ZGIA” or “GIA or ZGIA” \nas appropriate in order to correctly identify this agreement is a ZGIA.  These revisions do not have \na substantive impact but do provide clarity about the agreement being referred to.  \nH. \nAttachment FF (Transmission Expansion Planning Protocol).   \nMISO is proposing to revise this Attachment to require contractual commitments \nassociated with ZG Associated Load to include demonstration that both (1) an executed agreement \nbetween the entity with the ZG Associated Load and the Generating Facility with the associated \nZG Interconnection Service is in place and spans at least the five year planning horizon; and (2) \nthe Generating Facility associated with the ZG Associated Load has achieved Commercial \nOperation by the time that the transmission solution would otherwise need to be in service.  The \nproposed revisions state that, in the event that the Generating Facility associated with the ZG \nAssociated Load fails to achieve Commercial Operation by the date that the transmission solution \nwould otherwise need to be in service or the contract between the ZG Associated Load and the \nassociated Generating Facility terminates, then the Transmission Provider may require the \napplicable Load Serving Entity to delay the in-service date of ZG Associated Load. \nI. \nSchedule 53 (Seasonal Accredited Capacity Calculation).   \nMISO is proposing to revise this Schedule to provide that certain ZG Resources, either (i) \nthose that do not have at least 60 days of Real-Time offered availability when designed for RAR \nover the last three (3) years for each Season or (ii) Resources on Catastrophic Generator outage \nduring a season they are designated for RAR, will not have a SAC value that exceeds the identified \nCoincident Peak Demand forecast of the ZG Associated Load, if any. \n \n92  See, Tariff Attachment X—Appendix 18 (JTIQ Commitment Agreement) at Article 4.1."},{"page":45,"startToken":20980,"endToken":21447,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 45 \n \n \nIV. \nSTAKEHOLDER ENGAGEMENT \nMISO has engaged in detailed discussions with stakeholders on Large Load issues since \n2024 through various stakeholder entities and workshops.  MISO first discussed Large Loads with \nstakeholders in the context of Expedited Project Review process improvements at the Planning \nAdvisory Committee (“PAC”) and Planning Subcommittee (“PSC”) in 2024 and 2025.  Moreover, \nsince 2024, MISO has discussed coordinating the MISO Transmission Expansion Plan (“MTEP”) \nand Definitive Planning Phases processes to accommodate Large Loads at the PSC.  MISO \nadditionally discussed Large Load citing methodology at the November 18, 2025 Futures Redesign \nWorkshop. \nMISO first introduced ZGIA to stakeholders at the PSC on December 3, 2025.93  At the \nmeeting, MISO provided a high-level overview of the ZGIA concept and solicited feedback from \nstakeholders.  MISO subsequently discussed the proposal at the PAC and the Large Load Working \nGroup.  At the January 21, 2026 PAC, MISO described how ZGIA resource configurations may \nlead to reduced transmission network upgrade needs and detailed the stakeholder feedback \nsubmitted in response to the December 3, 2025 PSC presentation.  At the February 25, 2026 PAC, \nMISO began laying out a proposal for formalizing ZGIA by providing the interconnection and \nplanning elements of the proposal, the first two elements of the proposal. MISO requested \nstakeholder feedback on the proposal.  At the first LLWG meeting on April 20, 2026, MISO \ndescribed the elements of the ZGIA proposal relating to resource adequacy and markets and \nreliable operations, the last two elements of the proposal, and requested stakeholder feedback.  \nMISO also provided materials outlining MISO’s response to previously submitted stakeholder \nfeedback.   \nAt the April 22, 2026 PAC, MISO shared draft Tariff language with stakeholders reflecting \nthe interconnection and planning elements of the ZGIA proposal.  The draft Tariff language \nincluded specifics that originated from stakeholder feedback, including language ensuring that a \nZGIA disconnects if the facilities connecting it to its associated load.  MISO also provided \nmaterials outlining MISO’s response to previously submitted stakeholder feedback.  MISO \nrequested stakeholder feedback on the proposed draft Tariff language.  \nAt the May 14, 2026 LLWG, MISO shared draft Tariff language reflecting the elements \nZGIA proposal relating to resource adequacy and markets and reliable operations.  The draft Tariff \nlanguage incorporated stakeholder feedback regarding planning studies and multiple Points of \nInjection.  Specifically, in response to stakeholder feedback regarding MISO’s initial proposal \nallowing multiple POIs, MISO proposed only allowing multiple POIs if the ZGIA is located at one \nof the stations, i.e. Points of Withdrawal, of a Large Load Campus.  MISO requested stakeholder \nfeedback on the draft Tariff language.  \nAt the May 27, 2026 PAC, MISO shared updated draft Tariff language with stakeholders \non the interconnection and planning elements of the ZGIA proposal.  The draft Tariff language \n \n93  See Keyser, Attachment A – Table of Stakeholder Meetings."},{"page":46,"startToken":21447,"endToken":21959,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 46 \n \n \nincorporated stakeholder feedback, including language specifying further detail of the ZGIA \ninterconnection studies, language clarifying that ZGIAs do not supersede state jurisdiction, and \nrevising the POI rules.  MISO additionally decided not to pursue the campus approach in response \nto stakeholder feedback.  MISO requested stakeholder feedback on the proposed draft Tariff \nlanguage.  At the June 10, 2026 LLWG, MISO reviewed the final ZGIA proposal with stakeholders \nand provided draft Tariff language that incorporated stakeholder feedback.  At the June 29, 2026 \nLLWG, MISO continued the dialogue regarding the ZGIA proposal to provide stakeholders an \nopportunity to provide feedback on any remaining concerns and in response to the Show Cause \nOrder.  \nAt the July 15, 2026 PAC, MISO stated in its Liaison Report that the MISO Steering \nCommittee approved reassigning the ZIGA issue to the LLWG.  The Liaison Report noted that it \nreceived feedback in June on ZIGA Tariff redlines and that it posted a feedback response.  For the \nJuly 16, 2026 LLWG meeting, MISO posted ZGIA redlines for stakeholders to review.  At the July \n27, 2026 LLWG, MISO focused on other large load issues, but it provided a preliminary filing \ntimeframe that include the ZGIA filing.  MISO discussed ZGIA at the August 12, 2026 LLWG and \nprovided updated Tariff redlines for stakeholders to review.  \nV. \nDOCUMENTS SUBMITTED IN THIS FILING \nIn addition to this Transmittal Letter, this submission includes: \nTab A – Redline Tariff;94,95 \nTab B – Clean Tariff;  \nTab C – Prepared Direct Testimony of Marc Keyser; and \nTab D – Redline ZGIA to pro forma GIA (for informational purposes. \n \n94  Language currently pending before the Commission in the following, unrelated dockets is highlighted in yellow: \nDocket Nos.  ER24-2046-003, ER26-2974-000, and ER26-3267-000.  MISO requests that the Commission treat \nsuch highlighted language as subject to the outcomes of those pending proceedings.  MISO commits to file any \nrevisions to this highlighted language as necessary to comply with any Commission orders in those proceedings.  \nIn addition, MISO has not included language that has future effective dates of:  6/1/2027 in Docket No. ER26-\n1882-001, 6/12/2028 in Docket No. ER26-2825-000, 6/1/2029 in Docket No. ER22-1640-003, 9/1/2027 in \nDocket No. ER26-2974-000, 9/1/2027 in Docket No. ER25-1886-002 and 12/31/9998 in Docket No. ER26-1915-\n001.  If needed, MISO commits to file any revisions to comply with any Commission orders in these proceedings \nand MISO commits to make subsequent filings with the Commission to reflect the most up-to-date version of the \nthen-current Tariff provisions prior to the effective dates of the language. \n95  In this filing, MISO reconciled both the GIP (GIP Version 187) and ZGIA (GIA Version 111) to reflect the most \ncurrent tariff language, which now incorporates provisions filed in compliance with FERC Order Nos. 2023 and \n2023-A.  MISO requests that the Commission treat such pending language in Docket No. ER24-2406-003 as \nsubject to the outcome of the pending proceeding.  Additionally, MISO commits to submit any necessary revisions \nto the pending language to comply with any Commission orders in the proceeding."},{"page":47,"startToken":21959,"endToken":22225,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 47 \n \n \nVI. \nEFFECTIVE DATE \nMISO requests an effective date of October 18, 2026 for the Tariff revisions submitted \nherein, which is not less than 60 days nor more than 120 days, after the filing date.  This effective \ndate will allow the revisions proposed herein to be effective expeditiously for stakeholders \ncurrently seeking a process to facilitate the types of co-location arrangements that this filing \nenables.  \nVII. \nCOMMUNICATIONS \nMISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of \nPractice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the \ndesignation of more than two persons for service on behalf of MISO in this proceeding and requests \nall communications related to this filing be directed to: \nChristopher D. Supino \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System \nOperator, Inc. \n720 City Center Drive  \nCarmel, Indiana 46032  \nTelephone: (317) 249-5400 \ncsupino@misoenergy.org \nmkessler@misoenergy.org \n \nJames C. Holsclaw \nCalfee, Halter & Griswold LLP \n3900 Salesforce Tower \n111 Monument Circle \nIndianapolis, Indiana 46204 \nTelephone: (317) 308-4266 \njholsclaw@calfee.com  \n \nVIII. \nNOTICE AND SERVICE \nMISO has served a copy of this filing electronically upon all parties listed on the \nCommission’s eService list, and upon all Tariff customers, MISO Members, Member \nrepresentatives of Transmission Owners and non-Transmission Owners, as well as all state \ncommissions within the MISO Region and the Organization of MISO States.  The filing has been \nposted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for \nother interested parties in this matter."},{"page":48,"startToken":22225,"endToken":22347,"text":"The Honorable Debbie-Anne Reese \nAugust 18, 2026 \nPage 48 \n \n \n \nIX. \nCONCLUSION \nFor all of the foregoing reasons, MISO respectfully requests that the Commission accept \nthis filing and grant waiver of any Commission regulations the Commission deems applicable, but \nnot specifically addressed above in order for the Commission to accept it as proposed. \nRespectfully submitted, \n \n/s/ Christopher D. Supino \nChristopher D. Supino \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System \nOperator, Inc. \n720 City Center Drive  \nCarmel, Indiana 46032  \nTelephone: (317) 249-5400 \nmkessler@misoenergy.org \ncsupino@misoenergy.org \n \nJames C. Holsclaw \nCalfee, Halter & Griswold LLP \n3900 Salesforce Tower \n111 Monument Circle \nIndianapolis, Indiana 46204 \nTelephone: (317) 308-4266 \njholsclaw@calfee.com   \n \nAttorneys for the Midcontinent Independent \nSystem Operator, Inc."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":2314,"startToken":0,"endToken":733},{"p":2,"at":2314,"title":"I. EXECUTIVE SUMMARY","method":"printed heading","endPage":2,"endAt":2318,"startToken":733,"endToken":734},{"p":2,"at":2318,"title":"EXECUTIVE SUMMARY","method":"printed heading","endPage":2,"endAt":2337,"startToken":734,"endToken":736},{"p":2,"at":2337,"title":"A. Background","method":"printed heading","endPage":2,"endAt":2341,"startToken":736,"endToken":737},{"p":2,"at":2341,"title":"Background","method":"printed heading","endPage":4,"endAt":1593,"startToken":737,"endToken":1527},{"p":4,"at":1593,"title":"B. Addressing the Influx of Large Loads in the MISO Region","method":"printed heading","endPage":6,"endAt":1443,"startToken":1527,"endToken":2405},{"p":6,"at":1443,"title":"C. The ZGIA Proposal Supports Co-Location and Provides Speed to Power","method":"printed heading","endPage":9,"endAt":918,"startToken":2405,"endToken":3681},{"p":9,"at":918,"title":"D. Anticipated Complementary Solutions","method":"printed heading","endPage":11,"endAt":405,"startToken":3681,"endToken":4398},{"p":11,"at":405,"title":"II. OVERVIEW OF ZGIA PROPOSAL AND HOW IT ADDRESSES THE SHOW CAUSE ORDER","method":"printed heading","endPage":11,"endAt":2901,"startToken":4398,"endToken":4784},{"p":11,"at":2901,"title":"A. The Rates, Terms, and Conditions of Service that Apply to Interconnection","method":"printed heading","endPage":13,"endAt":2161,"startToken":4784,"endToken":5689},{"p":13,"at":2161,"title":"B. Generator Interconnection Study Process","method":"printed heading","endPage":16,"endAt":63,"startToken":5689,"endToken":6804},{"p":16,"at":63,"title":"III. DESCRIPTION OF PROPOSED TARIFF REVISIONS","method":"printed heading","endPage":16,"endAt":275,"startToken":6804,"endToken":6834},{"p":16,"at":275,"title":"A. Module A (Common Tariff Provisions). MISO is proposing both to add several","method":"printed heading","endPage":18,"endAt":1099,"startToken":6834,"endToken":7775},{"p":18,"at":1099,"title":"B. Module C (Energy and Operating Reserve Markets). MISO is proposing to","method":"printed heading","endPage":18,"endAt":1636,"startToken":7775,"endToken":7862},{"p":18,"at":1636,"title":"C. Module E-1 (Resource Adequacy). MISO is proposing to both add new provisions","method":"printed heading","endPage":20,"endAt":2125,"startToken":7862,"endToken":8879},{"p":20,"at":2125,"title":"D. Attachment X (Generator Interconnection Procedures).","method":"printed heading","endPage":37,"endAt":2331,"startToken":8879,"endToken":17468},{"p":37,"at":2331,"title":"E. Attachment X – Appendix 1 (Interconnection Request for a Generating","method":"printed heading","endPage":37,"endAt":2335,"startToken":17468,"endToken":17469},{"p":37,"at":2335,"title":"Attachment X – Appendix 1 (Interconnection Request for a Generating","method":"printed heading","endPage":38,"endAt":2178,"startToken":17469,"endToken":17913},{"p":38,"at":2178,"title":"F. Attachment X – Appendix 19 (ZG Interconnection Agreement (“ZGIA”)).","method":"printed heading","endPage":38,"endAt":2182,"startToken":17913,"endToken":17914},{"p":38,"at":2182,"title":"Attachment X – Appendix 19 (ZG Interconnection Agreement (“ZGIA”)).","method":"printed heading","endPage":44,"endAt":1627,"startToken":17914,"endToken":20720},{"p":44,"at":1627,"title":"H. Attachment FF (Transmission Expansion Planning Protocol).","method":"printed heading","endPage":44,"endAt":2714,"startToken":20720,"endToken":20882},{"p":44,"at":2714,"title":"I. Schedule 53 (Seasonal Accredited Capacity Calculation).","method":"printed heading","endPage":45,"endAt":63,"startToken":20882,"endToken":20989},{"p":45,"at":63,"title":"IV. STAKEHOLDER ENGAGEMENT","method":"printed heading","endPage":46,"endAt":1454,"startToken":20989,"endToken":21668},{"p":46,"at":1454,"title":"V. DOCUMENTS SUBMITTED IN THIS FILING","method":"printed heading","endPage":47,"endAt":63,"startToken":21668,"endToken":21968},{"p":47,"at":63,"title":"VI. EFFECTIVE DATE","method":"printed heading","endPage":47,"endAt":478,"startToken":21968,"endToken":22032},{"p":47,"at":478,"title":"VII. COMMUNICATIONS","method":"printed heading","endPage":47,"endAt":1300,"startToken":22032,"endToken":22149},{"p":47,"at":1300,"title":"VIII. NOTICE AND SERVICE","method":"printed heading","endPage":48,"endAt":65,"startToken":22149,"endToken":22234},{"p":48,"at":65,"title":"IX. CONCLUSION","method":"printed heading","endPage":48,"endAt":70,"startToken":22234,"endToken":22235},{"p":48,"at":70,"title":"CONCLUSION","method":"printed heading","endPage":48,"endAt":938,"startToken":22235,"endToken":22347}]}