ER26-3552-000 · 2026-08-18 · Midcontinent Independent System Operator, Inc.

MISO proposes a zero-injection generator interconnection agreement

Midcontinent Independent 
System Operator, Inc. 
317.249-5400 
www.misoenergy.org 
720 City Center Drive 
Carmel, Indiana 46032 
2985 Ames Crossing Road 
Eagan, Minnesota 55121 
1700 Centerview Drive 
Little Rock, AR 72211 
 
Christopher Supino 
Managing Senior Corporate Counsel 
Direct Dial:  317-517-2963 
Email:  csupino@misoenergy.org 
 
August 18, 2026 
VIA ELECTRONIC FILING 
The Honorable Debbie-Anne Reese  
Secretary 
Federal Energy Regulatory Commission 
888 First Street, NE 
Washington, DC  20426 
Re: 
Midcontinent Independent System Operator, Inc.’s  
Zero Injection Generator Interconnection Agreement 
Docket No. ER26-___-000 
 
Dear Secretary Reese: 
The Midcontinent Independent System Operator, Inc. (“MISO”), through this filing,1 
submits proposed revisions to its Open Access Transmission, Energy and Operating Reserve 
Markets Tariff (“Tariff”),2 to establish a Zero Injection Generator Interconnection Agreement 
(“ZGIA”),3 associated study process and operational requirements, and market and resource 
adequacy rules to accommodate Zero-Injection Generation Resources (“ZG Resource”) that intend 
to serve load interconnecting at the same substation as the Generating Facility.  The ZGIA proposal 
will help streamline the MISO generator interconnection process by providing expedited review 
of the addition of ZG Resources that have little or no impact on the Transmission System because 
they are limited to serving load at the same substation and voltage level. 
The ZGIA proposal is responsive to certain of the concerns raised by the Commission in 
the Order Instituting Proceeding Under FPA Section 206 4 in Docket No. EL26-70-000 (“Show 
Cause Order” or “SCO”) by proposing a permanent solution for generation resources that provides: 
(i) an interconnection service framework for generation supporting load at the same substation, 
 
1  
This filing is made pursuant to section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d, and Part 35 of 
the regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 35.1, et 
seq. 
2  
Unless otherwise indicated by the text or context of this transmittal letter, all terms used herein have the definitions 
set forth in Module A of the Tariff. 
3  
For the purposes of this filing, references to “ZGIA” may refer to the specific Zero Injection Generator 
Interconnection Agreement or may be used as a general reference to the processes and operational requirements 
that are part of the proposal submitted herein. 
4  
Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order” or “SCO”).

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 2 
 
 
including co-located load; (ii) a defined interconnection study processes tailored to zero-injection 
configurations, including co-location arrangements; (iii) potential reductions in Network Upgrade 
requirements where a more limited form of Interconnection Service is all that is needed, and (iv) 
clear allocation of operational and planning responsibilities.  Specifically, this filing responds to 
the Commission’s concerns by presenting a set of just and reasonable Tariff revisions setting forth 
the generator interconnection study process and generator interconnection service applicable to 
generation serving co-located load.  However, MISO notes that this filing is not intended to address 
all issues raised in the Show Cause Order.   
As acknowledged in the Show Cause Order, MISO began development of ZG 
Interconnection Service and the ZGIA through its stakeholder process months prior to the issuance 
of the Show Cause Order.   While MISO has adapted elements of its proposed process to better 
comply with the requirements of the Show Cause Order, this filing addresses a specific need within 
the MISO region, adapting existing and proven processes to provide a valuable tool to address co-
location concerns, including many of those raised in the Show Cause Order.  MISO therefore 
submits that the proposed ZG Interconnection Service construct is just, reasonable, and useful in 
the MISO region independent of its responsiveness to the Show Cause Order.  Other issues raised 
in the Show Cause Order, including the appropriate transmission service for large and co-located 
loads and the treatment of generation serving electrically proximate large loads, will be addressed 
through MISO’s forthcoming large load proposals. 
MISO requests that the Tariff revisions submitted herewith be made effective October 18, 
2026, which is more than sixty (60) days—and less than one hundred twenty (120) days—from 
the date of this submission.  As discussed below and in the supporting testimony of Mr. Keyser,5 
action is needed in the near term to address the reliability impacts and resource adequacy needs 
associated with the impending interconnection of Load, including the anticipated interconnection 
of significant large loads. 
I. 
EXECUTIVE SUMMARY 
A. 
Background  
 
The United States is in the midst of an unprecedented energy transition.  Large load 
customers, including artificial intelligence (“AI”) data centers and next-generation manufacturing 
technologies, are driving a surge in interconnection requests.  This growth is driven primarily by 
data center investment.6  As observed by the North American Electric Reliability Corporation 
(“NERC”), the largest contributor to this accelerated demand growth is data center additions with 
 
5  
Prepared Direct Testimony of Marc Keyser, Director—Central Region, External Affairs, attached hereto as Tab 
C (“Keyser”) at 3-4. 
6  
Long-Term Reliability Assessment, NERC, at 15, 25 (Jan. 2026), available at 
https://www.nerc.com/globalassets/our-work/assessments/nerc_ltra_2025.pdf.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 3 
 
 
18 GW of data center loads projected by 2035.7  The MISO region is no exception to this energy 
transition.  Energy-intensive loads such as data centers, manufacturing expansion, and 
electrification are adding sustained, concentrated load at levels not seen in decades.8  While 
electricity demand growth has been relatively flat with an annual average of just 0.5% between 
2009 and 2024, MISO is projecting a substantial increase of 1% to 2% per year through 2044, with 
even higher growth rates in the near term.9   
 
This growth has understandably drawn the focus of Relevant Electric Retail Rate 
Authorities (“RERRA”), stakeholders and federal policymakers.  On January 23, 2025, President 
Trump issued an Executive Order stating, “[i]t is the policy of the United States to sustain and 
enhance America’s global AI dominance in order to promote human flourishing, economic 
competitiveness, and national security.”10  On July 23, 2025, an Executive Order titled 
“Accelerating Federal Permitting of Data Center Infrastructure,” the Trump Administration 
announced its intention to pursue bold, large-scale industrial plans to incentivize critical 
manufacturing and data center development:  
 
We will pursue bold, large-scale industrial plans to vault the United 
States further into the lead on critical manufacturing processes and 
technologies that are essential to national security, economic 
prosperity, and scientific leadership.  These plans include artificial 
intelligence (AI) data centers and infrastructure that powers them, 
including high-voltage transmission lines and other equipment.  It 
will be a priority of my Administration to facilitate the rapid and 
efficient buildout of this infrastructure by easing Federal regulatory 
burdens.11 
 
On October 23, 2025, the Secretary of Energy directed the Commission to consider an 
Advance Notice of Proposed Rulemaking (“ANOPR”) focused on the timely and orderly 
interconnection of large loads to the interstate transmission system.12  The Secretary’s 
 
7  
Long-Term Reliability Assessment, NERC, at 15 (Jan. 2026), available at 
https://www.nerc.com/globalassets/our-work/assessments/nerc_ltra_2025.pdf.   
8  
2026 Reliability Imperative Report, MISO, at. 4 (Feb. 2026), available at 
https://cdn.misoenergy.org/2026%20Reliability%20Imperative%20Report744320.pdf.  
9  
2026 Reliability Imperative Report, MISO, at 4 (Feb. 2026), available at 
https://cdn.misoenergy.org/2026%20Reliability%20Imperative%20Report744320.pdf.  
10  Executive Order 14179 of January 23, 2025, “Removing Barriers to American Leadership in Artificial 
Intelligence,” Federal Register 90 (20) 8741, www.govinfo.gov/content/pkg/FR-2025-01-31/pdf/2025-
02172.pdf.  
11  Accelerating Federal Permitting of Data Center Infrastructure, Executive Order 14318, 90 FR 35385 (July 23, 
2025), https://www.whitehouse.gov/presidentialactions/2025/07/accelerating-federal-permitting-of-data-center-
infrastructure/.  
12  Letter from C. Wright, Secretary of Energy, to the Federal Energy Regulatory Commission, Docket No. RM26-
4-000 (Oct. 23, 2025).

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 4 
 
 
correspondence to the Commission in support of the ANOPR emphasized the importance of the 
timely, orderly, and non-discriminatory integration of large loads:   
 
To usher in a new era of American prosperity, we must ensure all 
Americans and domestic industries have access to affordable, 
reliable, and secure electricity.  To do this, large loads, including AI 
data centers, served by public utilities must be able to connect to the 
transmission system in a timely, orderly, and non-discriminatory 
manner.  This is an urgent issue that requires prompt attention.13 
 
On June 18, 2026, the Commission issued the Show Cause Order.14  The Show Cause Order 
recognizes the unprecedented increase in requests for transmission service to serve large loads 
along with the growing interest in co-location arrangements to serve those large loads.15  The Show 
Cause Order cites a lack of clarity and consistency in Regional Transmission Organizations’ or 
Independent System Operators’ tariffs regarding the rates, terms, and conditions of service that 
apply to flexible large loads, co-location arrangements, load with behind the meter generation, and 
generating facilities with electrically proximate large load or co-located load.16  Ultimately, the 
Show Cause Order requires MISO to show cause as to why the Tariff remains just and reasonable 
without provisions addressing certain large load and co-location issues or, in the alternative, 
explain what changes to the Tariff would remedy the Commission’s concerns.17  
 
 
B. 
Addressing the Influx of Large Loads in the MISO Region 
 
The MISO region is experiencing a significant influx of large load additions—primarily 
from data centers, cryptocurrency miners, and other processes that require larger load 
interconnections.  Large load growth presents a unique challenge because MISO must balance 
multiple objectives simultaneously.  MISO seeks to facilitate economic development and timely, 
cost-effective access to the Transmission System while maintaining reliability and operational 
integrity.   
 
MISO, its member states, and stakeholders are developing multiple initiatives to address 
evolving system conditions and to support efficient interconnection prior to and after the issuance 
of the Show Cause Order.  In recognition of urgent needs to address large load and co-located load 
growth, MISO established a temporary, targeted Expedited Resource Addition Study (“ERAS”) 
process to accelerate the generator interconnection process limited to generators necessary to serve 
certain critical, near-term load additions.   
 
13  Letter from C. Wright, Secretary of Energy, to the Federal Energy Regulatory Commission, Docket No. RM26-
4-000 (Oct. 23, 2025).  
14  See generally SCO.  
15  Id. at P 1.  
16  Id.   
17  Id. at P 3.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 5 
 
 
 
In addition, MISO improved the MISO Transmission Expansion Plan’s (“MTEP”) 
Expedited Project Review (“EPR”) process to quickly study Network Upgrades needed to support 
large loads.  MISO also initiated the MISO-SPP Joint Targeted Interconnection Queue Study 
(“JTIQ”) which aims at building transmission network upgrades along the MISO-SPP seams to 
enable large amounts of new generation.  While these initiatives provide important benefits, they 
neither fully address the reliability and operational challenges associated with accelerating large 
load growth, nor do they address all concerns raised in the Show Cause Order.  Accordingly, MISO 
recognizes that additional Tariff-based solutions are necessary to establish clear reliability 
expectations, improve operational visibility, and facilitate timely integration of large loads in a 
manner that is both reliable and non-discriminatory.  These solutions must also consider and 
address the unique planning and operational characteristics of large load interconnection customers 
and hyperscale data centers, in particular.  The ZGIA is one of these forthcoming solutions. 
 
MISO’s ZGIA proposal is well aligned with the Commission’s goals and objectives of 
transparency, affordability and reliability.  This proposal is one element in MISO’s response to the 
Commission’s desire for prompt action to address the rapid growth of large loads, related 
interconnection requests, and a surge in interest in co-located generation.  The Show Cause Order 
addresses the unprecedented increase in requests for transmission service to serve large load, as 
well as the growing interest in the co-location of loads with generation facilities (i.e., co-location 
arrangements), while acknowledging the challenges associated with providing the transmission 
service necessary to reliably serve the ongoing influx of large loads.18  The Show Cause Order 
states that MISO has not yet proposed Tariff revisions to address the challenges associated with 
the integration of large and co-located loads.19  The Show Cause Order requires MISO to show 
cause as to how its Tariff remains just and reasonable, or to explain what changes would remedy 
the Commission’s concerns.20   
 
MISO is moving quickly on proposals that had been previously incorporated into the Large 
Load Working Group (“LLWG”) workplan and is also engaging with stakeholders, including the 
Organization of MISO States, Inc. (“OMS”), in an expedited manner to develop the broader set of 
solutions outlined in the August 3, 2026, motion filed by MISO and the MISO Transmission 
Owners to hold all proceedings related to the Show Cause Order in abeyance for 90 days.21  The 
Abeyance Motion explained that MISO and the MISO Transmission Owners required additional 
time to continue the stakeholder process and submit FPA section 20522 filings that address the 
 
18  SCO at P 1.  
19  Id. at P 2.  
20  Id. at P 3.  
21  Motion of the Midcontinent Independent System Operator, Inc. and the MISO Transmission Owners to Hold 
Proceeding in Abeyance and Request for Shortened Comment Period and Expedited Treatment, Docket No. 
EL26-70-000 (Aug. 3, 2026) (“Abeyance Motion”).   
22  16 U.S.C. § 824d.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 6 
 
 
concerns raised in the Show Cause Order.23  The Commission granted the 90-day abeyance 
requested in the Abeyance Motion on August 14, 2026.24    
 
The Abeyance Motion emphasized that MISO, in collaboration with stakeholders and the 
OMS, has been working to identify and implement solutions to facilitate speed to reliable power.25  
These efforts include two already-implemented initiatives: (1) the one-time, targeted ERAS 
process to accelerate generator interconnection for near-term resource adequacy needs; and (2) 
improving the MTEP EPR process to enable the rapid study and approval of transmission upgrades 
necessary for the addition of large loads.26  MISO explained that it also created the LLWG to 
provide a dedicated and consolidated stakeholder forum for prioritizing and focusing efforts to 
both identify critical issues and develop corresponding solutions to integrate large loads reliably 
and cost effectively.27   
 
MISO has developed a prioritized work plan to accelerate consideration of the challenges 
presented by large load growth in the MISO region through its stakeholder process.28  This process 
has resulted in the development of groups of potential solutions and improvements to various 
MISO processes, which MISO intends to submit for Commission review in a series of filings.29  
The present filing represents the first of this series.  
 
C. 
The ZGIA Proposal Supports Co-Location and Provides Speed to Power 
 
Co-location has been widely recognized as one of the most valuable tools in achieving 
“speed to power” in a reliable and efficient manner and MISO’s ZGIA co-location solution has 
been prioritized within the LLWG’s efforts.  The ZGIA and related study process proposed in this 
filing is the first of the proposed solutions to come from the LLWG.  The ZGIA construct is the 
product of significant effort by MISO, the OMS, and stakeholders that began prior to the Show 
Cause Order and was refined in response to the Show Cause Order.  The ZGIA framework will 
address not only large load interconnections and co-located generation but it also will help 
streamline the interconnection process for Interconnection Customers serving co-located load.30  
 
23  Abeyance Motion at 2.  
24  Midcontinent Independent System Operator, Inc., et. al., 196 FERC ¶ 61,133 (August 14, 2026) (“Abeyance 
Order”). 
25  Abeyance Motion 3.  
26  Id.  
27  Id.  
28  Id. at 4.  
29  Id.   
30  MISO uses the term “co-location” in this filing to refer to arrangements where the Load’s Point of Withdrawal 
and the Generating Facility’s proposed Point of Interconnection are located at the same substation and at the same 
voltage level.  These may be at the same Point of Interconnection or involve lead lines in adjacent bays.  MISO 
recognizes that this is a slightly broader definition than that used by the Commission in the Show Cause Order.  
As explained below, after extensive discussions, MISO determined that its proposed scope is a better fit for the

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 7 
 
 
Hence, the ZGIA proposal serves two important purposes.  First, the ZGIA framework addresses 
several of the Commission’s concerns raised in the Show Cause Order.  Second, the ZGIA 
framework addresses improvements to the interconnection process in addition to the Commission's 
stated concerns, such that it will have independent benefits for all interconnection customers.   
 
MISO explored several potential scopes for its ZG Interconnection Service product through 
the stakeholder process including limiting it to load and generation connecting to the Transmission 
System behind the same Point of Interconnection and expanding it to encompass load located 
“proximate” to generation.  After extensive consideration, MISO determined that limiting ZG 
Interconnection Service to load and generation behind the same Point of Interconnection is too 
strict an approach for the MISO Transmission System as it would exclude configuration options 
that MISO is aware that developers are considering for adjacent load and generation where 
injections to the broader Transmission System can be effectively limited and monitored.  
Following further discussion and evaluation with stakeholders, MISO also determined that 
expanding the ZGIA and ZG Interconnection Service construct to accommodate “electrically 
proximate” load and generation would have raised novel reliability and transmission service 
challenges that would not be easily resolved in a timely manner for the unique processes that 
underpin MISO’s transmission and interconnection services.  In addition, stakeholders raised 
concerns that extending the proposal to serving proximate load beyond the same substation could 
result in the potential for retail wheeling and conflict with retail regulatory constructs.  Rather than 
delay a significant and important tool to support co-location, MISO chose not to incorporate a 
“proximate” load solution in this initial filing.31  Accordingly, this filing is limited to addressing 
generation and load at the same substation and does not attempt to resolve the separate issues 
presented by generation serving electrically proximate large load.  MISO’s forthcoming Load 
Addition Resource Study (“LARS”) process is intended to address those issues by providing a 
coordinated study framework for load additions and associated new generation that are electrically 
proximate but do not satisfy the ZGIA’s narrower requirements. 
 
This filing proposes Tariff revisions to establish the ZGIA construct as a Tariff-defined 
process to take advantage of the benefits of co-location of generation and load.  The ZGIA 
framework creates a path for a planned generator that will connect at the same substation and 
voltage level as existing or proposed load (including large loads) to interconnect quickly, with 
strict limitations on injections further onto the Transmission System, which and correspondingly 
reduce potential for Transmission System Impacts and expensive Network Upgrade.  Load 
customers, including large load customers, will benefit from ZGIA interconnection studies that 
recognize on-site generation, potentially reducing network upgrade requirements to interconnect.  
As discussed in more detail below, the proposed ZGIA framework includes a new load at the same 
substation and voltage level as a generation resource.  The figure below depicts load taking firm-
 
types of interconnection arrangements that MISO has seen and expects it will continue to see in accommodating 
the integration of larger loads in its region. 
31  Keyser at 11-14, 19-20.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 8 
 
 
service Network Integration Transmission Service (“NITS”).32  The load is permitted to withdraw 
and take energy delivery from other system resources, but the new generator with ZGIA 
Interconnection Service cannot inject past the interconnecting substation, and netting of the load 
and generation for transmission service or market settlement purposes is not allowed:33 
 
 
 
 
With these proposed Tariff changes, the ZGIA proposal will partially address several of the 
issues raised by the Commission related to co-location of generation and large loads by proposing 
a permanent solution for generation resources seeking to interconnect to the Transmission System 
at the same substation as an associated load.  In particular, the ZGIA partially addresses the 
Commission’s concerns regarding the absence of a generator interconnection service and study 
process tailored to the operational characteristics of generation serving co-located load, including 
a study process that recognizes the potentially reduced Transmission System impacts where 
generation is limited to serving its associated load.34  As visualized below, because the ZGIA 
process can take place quickly, with the ZG Impact Assessment completed within 90 Calendar 
Days, the subsequent MTEP load study can result in a more optimal and potentially reduced set of 
network upgrades needed to reliably serve the load.  The subsequent proposal to address the case 
of electrically proximate load and generation, LARS, will further address the Commission’s 
 
32  This filing does not establish new rules regarding transmission service.  However, existing Tariff rules require 
Load to obtain transmission service in order to be served using the Transmission System.  For Load served by a 
Load Serving Entity in the MISO region, the transmission service utilized is almost always NITS. 
33  Consideration of Zero-Injection GIA, MISO Planning Advisory Committee (Jan 21, 2026), available at 
https://cdn.misoenergy.org/20260121%20PAC%20Item%2009%20Market%20Participation%20and%20Registr
ation%20of%20Co-Located%20Load%20and%20Generation%20(PAC-2024-4)736238.pdf. MISO notes that 
this description explains how ZGIA will serve large loads and fit within existing Tariff constructs.  This filing 
does not prejudice MISO’s ability to revise transmission service rules through other 205 filings responding to the 
Show Cause Order. 
34  See SCO at PP 58, 94, 113, 115, 117 and 118.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 9 
 
 
concerns through a process that can potentially reduce the set of Network Upgrades needed to 
serve both the load and the resource. 
 
 
 
 
The ZGIA proposal represents another critical tool to help support the timely, reliable, cost-
effective integration of new large loads into the MISO system.  It efficiently leverages existing 
MISO processes and practices to serve as a robust incremental solution.  MISO notes that this is 
one of several upcoming Tariff solutions that will be filed with the Commission to collectively 
address the issues raised in the Show Cause Order.  MISO appreciates the guidance and direction 
provided in the Show Cause Order and is committed to continuing its collaborative efforts with 
the states and stakeholders to deliver additional tools to meet the unique challenges associated with 
integrating large loads.   
 
D. 
Anticipated Complementary Solutions 
 
MISO has been advancing a coordinated set of solutions designed to balance speed to 
power, fairness, and, most importantly, reliability.  In particular, MISO has developed two solutions 
that are responsive to the Commission’s concerns noted in the Show Cause Order surrounding the 
interconnection and study processes for co-location arrangements and service of proximate large 
loads.   
 
The ZGIA proposal identified in this filing is the product of a stakeholder process that 
began prior to the Show Cause Order to address not only large load interconnection and co-location 
issues, but also improvements to the interconnection process in general.  By formalizing the ZGIA 
construct in the Tariff,35 MISO can provide a limited, structured option to support large load 
integration, co-location, and refinements to the interconnection process through: 
 
35  MISO notes that it has accommodated zero-injection generator interconnection arrangements in limited 
circumstances in the past using existing Tariff mechanisms, including filing non-conforming generator 
interconnection agreements with the Commission.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 10 
 
 
 
• An interconnection service framework for generation that is supporting co-located 
load; 
• Defined interconnection study processes tailored to zero-injection configurations; 
• Potentially reduced network upgrade requirements where appropriate; and 
• Clear allocation of operational and planning responsibilities. 
This construct enables a pathway for certain large load configurations to achieve speed to 
reliable power while maintaining system reliability.   
 
The ZGIA framework represents an initial step in a broader set of solutions to address the 
concerns expressed in the Show Cause Order and to meet the evolving needs of the MISO region.  
These ongoing efforts reflect the iterative nature of MISO’s response to rapidly changing load 
conditions and the need for continued stakeholder collaboration.  To that end, as noted above, 
MISO will be submitting additional proposals to further address large load integration as discussed 
in the Abeyance Motion. 
 
In addition to the ZGIA proposal submitted herein, MISO is also developing through the 
stakeholder process at the LLWG its Load Addition and Resource Study process.  LARS will assess 
the transmission infrastructure needed to meet new large loads and new generation in an efficient 
process that can be executed on a shorter timeline, further supplementing the opportunities 
available for members to facilitate new large spot loads effectively.  This process is expected to 
position MISO and its members to ensure resource adequacy and protect customers from 
unnecessary investments relating to spot large load siting. 
 
More specifically, LARS will analyze generation and transmission using the same study 
assumptions applied in the standard generator interconnection process and MISO’s MTEP.  The 
studies will be run in parallel, and will finish at approximately the same time—within 120 days—
with the load/transmission model incorporating both the planned generation and planned load.36  
LARS, as currently conceived, will address similar issues to those the Show Cause Order identified 
related to interconnection customers serving electrically proximate large load or co-located load.37  
Thus, while the instant ZGIA filing addresses the generator interconnection service and study 
framework for generation serving ZG Associated Load, LARS will address the distinct study issues 
presented by new generation and large load that are electrically proximate but are not eligible for 
ZG Interconnection Service.  It is important to note that neither the ZGIA construct nor LARS 
proposal include new transmission service products specific to serving co-located or proximate 
load or address flexible large loads willing to limit transmission service.  Transmission service 
 
36  MISO included a description of this Joint Study Process in its Informational Report submitted in this docket on 
July 20, 2026. 
37  SCO at P 113 (preliminarily finding that MISO’s Tariff may be unjust and unreasonable because it does not contain 
provisions that will allow an interconnection customer to seek the generator interconnection service(s) that reflects 
the operational dynamics of serving either: (1) an electrically proximate large load; or (2) a co-located load, that 
has a high peak load (i.e., large co-located loads that are 50 MW or greater)).

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 11 
 
 
products to address related concerns raised in the Show Cause Order will be evaluated through the 
LLWG and ultimately presented to the Commission in a separate FPA section 205 filing.  MISO 
will continue to develop the LARS process through the LLWG and expects to submit the LARS 
filing by November 16, 2026, or earlier, if feasible.   
 
II. 
OVERVIEW OF ZGIA PROPOSAL AND HOW IT ADDRESSES THE SHOW CAUSE ORDER 
The ZGIA construct allows for generation to connect to the Transmission System without 
injection rights, making it suitable to serve loads, including large loads, at the same substation.  
This proposed construct not only formalizes the existing practice, but it also addresses a discrete 
subset of the concerns identified by the Commission in the Show Cause Order, specifically those 
concerning generator interconnection service and the study of generation serving co-located load.   
More specifically, the ZGIA construct provides a limited, structured option to support large 
load integration through: (i) an interconnection service framework for generation that is supporting 
co-located load; (ii) defined interconnection study processes tailored to zero-injection 
configurations; (iii) potentially reduced network upgrade requirements where appropriate; and (iv) 
clear allocation of operational and planning responsibilities.  The ZGIA construct enables one 
pathway for certain large load configurations to achieve speed to reliable power while maintaining 
system reliability.  The ZGIA framework is not, however, limited to large loads.  While the ZGIA 
is particularly responsive to the needs of a large load, a ZG Associated Load38 does not have to be 
a large load. 
MISO notes that this filing does not include a proposed definition of “Large Load.”  MISO 
is continuing to refine the definition of “Large Load” through the ongoing stakeholder process at 
the LLWG and expects to file the proposed definition of “Large Load” with the Commission in a 
subsequent FPA section 205 filing that is responsive to certain additional concerns raised in the 
Show Cause Order that are not specifically addressed herein.  The ZGIA proposal remains just and 
reasonable without inclusion of a definition of “Large Load” because the ZGIA proposal and the 
identification of ZG Associated Load is open to application for all loads in the MISO region and 
is not limited to only large loads.  In addition, the Show Cause Order explains that it appears that 
it would be reasonable to define a large load as: (1) a new commercial or industrial customer, (2) 
located at a single site behind one or more points of interconnection, (3) that has a peak load of 50 
MW or greater, (4) interconnects to the transmission system at a voltage level of greater than 69 
kV, and (5) is not part of a co-location arrangement.39 
A. 
The Rates, Terms, and Conditions of Service that Apply to Interconnection 
Customers Serving Co-Located Load  
 
38  Zero Injection Generation (ZG) Associated Load shall mean a source of electrical load that has a Point of 
Withdrawal that is at the same substation as the Point of Interconnection to the Transmission System (i.e. same 
voltage level at the interconnecting substation) as the Generating Facility with ZG Interconnection Service that 
will serve it. 
39  See SCO at fn 2 (emphasis added), see also SCO at P 58.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 12 
 
 
The Show Cause Order posits that MISO’s Tariff appears to be unjust and unreasonable 
because it lacks provisions addressing with sufficient clarity and consistency the rates, terms, and 
conditions of service that apply to interconnection customers serving co-located load.40  This filing 
proposes to address the Show Cause Order’s concerns relating to the rates, terms, and conditions 
of service that apply to interconnection customers serving co-located load as explained below:  
MISO proposes to implement a new type of service, called ZG Interconnection Service.  
ZG Interconnection Service is service limited to serving specifically designated load that is either 
at the same Point(s) of Interconnection (“POI”) or has a Point(s) of Withdrawal (“POW”) on the 
same voltage side of the same substation as the ZGIA.  ZG Interconnection Service is not 
Transmission Service and does not exempt a Transmission Customer from procuring Transmission 
Service.  Accordingly, the ZGIA addresses the generator interconnection component of a co-
location arrangement; it does not establish or modify the Transmission Service that must be 
obtained to serve the ZG Associated Load.  MISO intends to address the separate transmission 
service issues identified in the Show Cause Order through subsequent filings developed through 
the LLWG.   
ZG Interconnection Service is fundamentally a limited product.  ZG Interconnection 
Service will be limited to a POI and POW that are at the same substation, with the same voltage 
level.  The ZGIA process will ultimately offer a ZGIA for limited operations, with operation limited 
to ensure system reliability based upon the results of the impact assessment and facilities studies.  
ZG Interconnection Service does not allow the Interconnection Customer to serve other load or 
inject energy onto the Transmission System for purposes other than serving the ZG Associated 
Load identified in the Interconnection Request and memorialized in the ZGIA.  After engaging in 
the stakeholder process, MISO determined that the same substation and voltage level limitation on 
ZG Interconnection Service to only serve load or inject onto the Transmission System for purposes 
of serving ZG Associated Load strikes the appropriate balance between offering a constrained 
product that can be studied to ensure minimal impact on other projects and enabling an expedited 
study process without hindering MISO’s ability to process the Definitive Planning Phase (“DPP”). 
The rates, terms, and conditions for service under the ZGIA construct differ from ordinary 
interconnection requests in several key areas listed below. 
First, the resource seeking ZG Interconnection Service must demonstrate a relationship 
with load connected at the same voltage side of the same substation, defined as ZG Associated 
Load, under which the ZG Associated Load signifies its intention to be served by the ZG Resource.  
Mr. Keyser explains that, because ZG Interconnection Service allows the ZG Resource to serve 
only its designated ZG Associated Load, documenting the relationship between ZG Associated 
Load and the ZG Resource is necessary to prevent speculative Interconnection Requests from 
using the process.41   
 
40  SCO at PP 94 and 97. 
41  Keyser at 9.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 13 
 
 
Second, while an Interconnection Customer seeking ZG Interconnection Service is not 
limited in the quantity of nameplate capacity of generation they choose to build, the 
Interconnection Customer seeking ZG Interconnection Service is limited to requesting and being 
awarded Interconnection Service at a level that does not exceed the peak demand of the ZG 
Associated Load.  As explained by Mr. Keyser, this is an important design feature of the ZGIA 
process because it serves to ensure that the maximum expected energy production of the ZG  
Resource is no greater than the maximum demand of the ZG Associated Load.42 
Third, the ZG Interconnection Service Study must model the ZG Associated Load when 
studying the Interconnection Request and confirm that the proposed equipment to limit injections 
is sufficient to accomplish this task.  This requirement is consistent with the Commission’s 
discussion regarding the need for a new generator interconnection service tailored to co-location 
arrangements using control technologies and/or protection systems to ensure there is no injection 
on the Transmission System.43 
In this manner, the ZGIA study evaluates the generation and associated load together, rather 
than studying the generating facility without regard to the load it is intended to serve.  This directly 
responds to the Commission’s concern that MISO’s existing generator interconnection process 
may fail to recognize the reduced Transmission System impacts of generation that is operationally 
limited to serving co-located load.   
Fourth, the ZG Resource must interconnect at the same substation and voltage level as one 
of the POWs of the ZG Associated Load it serves; and, the ZG Interconnection Study must 
determine that the ZG Resource will not require Network Upgrades beyond the substation except 
for system protection facilities at adjacent substations.   
If all of these criteria are met, the ZG Interconnection study process affords a 90-day 
accelerated study process leading to a ZGIA that memorializes the proposed configuration and 
limited injection. 
B. 
Generator Interconnection Study Process  
The Show Cause Order preliminarily found that MISO’s Tariff appears to be unjust and 
unreasonable because it lacks provisions allowing an interconnection customer to seek the 
generator interconnection service(s) that reflects the operational dynamics of serving either: (1) an 
electrically proximate large load; or (2) a co-located load that has a high peak load (i.e., large co-
located loads that are 50 MW or greater).44  In particular, the Commission noted that the Tariff 
appears to be unjust and unreasonable because it lacks a generator interconnection study process 
and/or generator interconnection service to reflect an interconnection customer’s commitment in 
an interconnection agreement to limit the generating facility’s output to minimize the impact on 
 
42  Keyser at 10-11. 
43  See SCO at P 118. 
44  SCO at P 113.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 14 
 
 
the transmission system while serving an electrically proximate large load or large co-located 
load.45  The Show Cause Order also observed that where a generating facility’s output is matched 
to the demand of the electrically proximate large load or large co-located load or if the generating 
facility’s output is limited to ensure no new injection, the impacts to the transmission system of 
interconnecting the generating facility to serve that electrically proximate large load or large co-
located load may be limited, thereby potentially reducing the need for Network Upgrades, which 
can accelerate the generator interconnection process.46 
The ZGIA addresses this concern with respect to co-located load that satisfies the ZG 
Associated Load requirements.  As discussed above, the separate application of this concept to 
generation service for electrically proximate large load will be addressed through MISO’s 
forthcoming LARS proposal.  As explained by Mr. Keyser, the ZGIA proposal will complement 
the Definitive Planning Phase (“DPP”), which is MISO’s current Interconnection Queue process 
for addressing the needs of large loads.47  The DPP process is quite broad and enables system 
reliability by studying new generation sources for technical and operational impacts and 
identifying and assigning the costs for the necessary upgrades required to connect the new 
resources safely and reliably.  Under the DPP, Interconnection Requests are evaluated through a 
three-phase, grouped study process.  Because projects all impact the Transmission System and are 
studied in groups, each Interconnection Request is affected by higher-queued and same-group 
projects, introducing complexity and uncertainty, particularly when withdrawals occur.  This 
process is not always necessary for all customers because some Interconnection Customers—
particularly those serving large loads—seek to install generation to meet the needs of adjacent 
large loads, and do not require access to the transmission system and, in fact, may never intend to 
inject onto the MISO Transmission System or, if they do plan on injecting, it is only to move 
energy to an adjacent bay of the same substation.  In such circumstances, a separate, expedited 
study process and corresponding form of Interconnection Service is both feasible and responsive 
to the Commission’s directive to address the needs of certain loads, including large loads 
associated with data centers.   
 
The ZGIA proposal implements that proposed, expedited process.  The study requirements 
necessary for a ZGIA to provide ZG Interconnection Service are still extensive, including 
obligations to implement equipment and/or operational procedures to prevent injections and to 
limit any inadvertent injections to a defined Transient Tolerance Window in the event of an 
unexpected load reduction or trip.48 
Interconnection Requests submitted through the ZGIA process will be studied in a serial 
“first-come, first served” fashion based on the order the projects were submitted.  It will follow a 
quarterly cadence established by proposed MISO timelines, ultimately culminating in the project 
 
45  SCO at P 113.  
46  SCO at P 113.  
47  Keyser at 7-9. 
48  Keyser at 20–22.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 15 
 
 
receiving a ZGIA in approximately 90 days.  The ZGIA model build will include all Existing 
Generating Facilities, including those from completed DPP cycles, the ERAS Interconnection 
Request, and the latest MTEP base case with all approved MTEP projects, and any recently 
approved EPR projects.  This is the same process utilized for DPP studies except the DPP models 
include all higher queued Interconnection Requests from earlier cycles and all Interconnection 
Requests within that DPP cycle.  ZGIA studies will not include Interconnection Requests currently 
in the generator interconnection queue that do not have a GIA. 
 
Before every ZGIA cycle, all Interconnection Requests with a GIA approved since the last 
base case was created will be added to the base case for the ZGIA cycle but will not be added in 
any ongoing DPP studies.  The base case for each DPP cycle is never updated once the study 
process is kicked off except for generation changes due to Interconnection Request withdraws or 
generator retirements.  This ensures that the transmission capacity made available for DPP projects 
is not being taken away by ZGIA Interconnection Requests approved outside of the DPP cycle.  
 
Once the DPP cycle has concluded, the output from that process, and any completed ZGIA 
and EPR projects, will be used to populate a new MTEP base case.  Any transmission issues 
identified by reconciling the cases will thus be addressed through the existing MTEP process.  The 
next DPP cycle will then use the latest approved MTEP base case that has reconciled the models.  
This insulates existing DPP projects from negative impacts or cost shifts due to the existence of 
the ZGIA process.  The contingent facilities listed in the ZGIA would only be those facilities in 
the model used for the ZGIA study and those Network Upgrades that come up as part of the ERAS 
study.    
 
Subsequently, the standing MISO DPP three phase and ERAS processes will not be 
impacted by ZGIA, as ZGIA will not be utilizing any available transmission capacity in those 
studies. 
 
It should be noted that the ZGIA study process includes the load and a simulation of the 
scenario in which the load trips offline.  As Mr. Keyser explains, this analysis will help validate 
the specific protection schemes needed for the specific ZGIA project.49 
 
As previously discussed, ZG Associated Load that is studied and eligible for 
interconnection is a firm network load, obligated under existing Tariff rules to pay for transmission 
service on a gross basis, and eligible for all the benefits of being a network load, including being 
served by all MISO resources on any and all transmission paths.  
 
Taken together, these provisions establish the tailored generator interconnection study 
process contemplated by the Show Cause Order for generation serving co-located load, while 
preserving for subsequent filings the distinct issues associated with Transmission Service and 
electrically proximate load.  
 
 
49  Keyser at 28.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 16 
 
 
III. 
DESCRIPTION OF PROPOSED TARIFF REVISIONS 
To implement the ZGIA construction proposed herein, MISO is requesting approval of 
new Tariff provisions, as well as revisions to several existing provisions.50  
A. 
Module A (Common Tariff Provisions).  MISO is proposing both to add several 
new terms and definitions to Module A, as well as to revise the definition of several existing terms, 
as follows: 
1. 
Proposed New Module A Tariff Provisions.  MISO is requesting approval 
to add five (5) newly defined terms to Module A of its Tariff.  The new terms and proposed 
definitions include: 
a. Point(s) of Withdrawal:  The point(s) where a non-transmission facility that is 
used to withdraw Energy from the Transmission System to serve Load connects 
to the Transmission System. 
 
b. Zero Injection Generation (ZG) Associated Load:  A source of electrical load 
that has a Point of Withdrawal that is at the same substation as the Point of 
Interconnection to the Transmission System (i.e. same voltage level at the 
interconnecting substation) as the Generating Facility with ZG Interconnection 
Service that will serve it. 
 
c. Zero Injection Generation (ZG) Interconnection Service:  A limited form of 
Interconnection Service that allows an Interconnection Customer to connect its 
Generating Facility to the Transmission System or Distribution System, as 
applicable, for the limited purpose of delivering energy to ZG Associated Load.  
ZG Interconnection Service does not grant any right to inject energy onto the 
Transmission System except as may be authorized by Section 3.11 of the 
Generator Interconnection Procedures.  ZG Interconnection Service does not 
convey Transmission Service.  ZG Interconnection Service also does not 
provide a right to serve, or a right to Transmission Service to serve, a ZG 
Associated Load or retail customer except as allowed by applicable state law. 
 
d. Zero Injection Generation (ZG) Resource:  A generating resource with an 
Attachment X defined ZG Interconnection Agreement.  A ZG Resource may 
participate as a Generation Resource, Dispatchable Intermittent Resource, 
Electric Storage Resource, or Behind the Meter Generation resource. 
 
2. 
Proposed Revised Module A Tariff Provisions.  MISO is proposing to revise 
the definition of several terms currently included in Module A.  The struck-through language 
 
50  This transmittal letter frequently quotes proposed Tariff revisions to facilitate its explanation.  In the event of a 
conflict between the Tariff language as discussed in this letter and that reflected in the attached Tariff sheets, 
MISO intends that the language in the attached Tariff sheets control.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 17 
 
 
shown below will be deleted from the definition and the words or phrases shown in italics will be 
added.  MISO’s proposed revisions are as follows: 
a. Forecast Maximum Limit:  For a Dispatchable Intermittent Resource, The the 
maximum MW level at which a Dispatchable Intermittent the Resource is 
forecasted to operate.  In addition, for a ZG Resource participating as a DIR, 
the maximum MW level at which a Resource may operate shall be less than the 
Demand of the Resource’s ZG Associated Loads.   
 
b. Hourly Economic Maximum Limit:  The maximum MW level at which a 
Generation Resource, Demand Response Resource Type II, or External 
Asynchronous Resource may operate under normal system conditions that may 
be submitted to override the default value submitted during the asset registration 
process.  In addition, for a ZG Resource participating as a Generation 
Resource, the maximum MW level at which the Resource may operate under 
normal system conditions shall be less than the Demand of the Resource’s ZG 
Associated Loads. 
 
c. Hourly Economic Maximum Discharge Limit:  The maximum injection MW 
level at which an Electric Storage Resource may operate under normal system 
conditions that may be submitted to override the default value submitted during 
the asset registration process.  In addition, for a ZG Resource participating as 
an Electric Storage Resource, the maximum MW level at which the Resource 
may operate under normal system conditions shall be less than the Demand of 
the Resource’s ZG Associated Loads. 
 
d. Hourly Emergency Maximum Limit:  The maximum MW level at which a 
Generation Resource, an External Asynchronous Resource, or Demand 
Response Resource Type II may operate under Emergency conditions that may 
be submitted to override the default value submitted during the asset registration 
process.  In addition, for a ZG Resource participating as a Generation 
Resource, the maximum MW level at which a Resource may operate under 
Emergency conditions shall be less than the Demand of the Resource’s ZG 
Associated Loads. 
 
e. Hourly Emergency Maximum Discharge Limit:  The maximum injection MW 
level at which an Electric Storage Resource may operate under Emergency 
system conditions that may be submitted to override the default value submitted 
during the asset registration process.  In addition, for a ZG Resource 
participating as an Electric Storage Resource, the maximum MW level at which 
the Resource may operate under Emergency system conditions shall be less than 
the Demand of the Resource’s ZG Associated Loads.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 18 
 
 
f. Hourly Regulation Maximum Discharge Limit:  The maximum injection MW 
level at which an Electric Storage Resource can respond to automatic control 
signals, that may be submitted to override the default value submitted during 
the asset registration process.  In addition, for a ZG Resource participating as 
an Electric Storage Resource, the maximum MW level at which the Resource 
can respond to automatic control signals shall be less than the Demand of the 
Resource’s ZG Associated Loads. 
 
g. Hourly Regulation Maximum Limit:  The maximum MW output at which a 
Generation Resource, Demand Response Resource – Type II, or External 
Asynchronous Resource can respond to automatic control signals that may be 
submitted to override the default value submitted during the asset registration 
process.  In addition, for a ZG Resource participating as a Generation 
Resource, the maximum MW level at which a Resource can respond to 
automatic control signals shall be less than the Demand of the Resource’s ZG 
Associated Loads. 
 
B. 
Module C (Energy and Operating Reserve Markets).  MISO is proposing to 
implement a registration requirement for a ZG Resources greater than 5 MW in size.  This 
requirement provides visibility of the ZG Resource to MISO and is necessary for MISO to account 
for the gross amount of ZG Associated Load, which will facilitate the requirement that the ZG 
Associated Load is required to pay for transmission service, ancillary services, and other services 
they receive on a gross basis, as contemplated by the Show Cause Order.51  
 
C. 
Module E-1 (Resource Adequacy). MISO is proposing to both add new provisions 
to Module E-1 and to revise several existing provisions, as follows: 
 
1. 
Proposed New Module E-1 Tariff Provisions.  MISO is requesting approval 
to add one (1) new subsection to Module E-1.  The subsection is limited to: 
a. Section 69A.4.1 (Seasonal Accredited Capacity of Capacity Resources): MISO 
is proposing to add a new subsection providing that the Seasonal Accredited 
Capacity for a ZG Resource shall be based on its participation type and subject 
to certain enumerated requirements, including that the Seasonal Accredited 
Capacity is capped at the specified portion of the Coincident Peak Demand 
forecast attributable to the ZG Associated Load less any Seasonal Accredited 
Capacity (“SAC”) assigned to the ZG Associated Load and that the SAC shall 
be grossed-up by the amount of avoided Transmission Losses. 
 
2. 
Proposed Revised Module E-1 Tariff Provisions. MISO is proposing to 
revise several provisions of Module E-1 to establish the basis on which a ZG Resource and ZG 
Associated Load may participate in MISO’s Resource Adequacy construct and associated rules 
 
51  SCO at P 96.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 19 
 
 
related to the accreditation of ZG Resources.  The nature of the proposed revisions to Module E-1 
reflect the fact that a ZG Resource cannot serve load in the MISO region beyond the substation 
and voltage level of its co-located ZG Associated Load.  As such, these revisions limit the 
participation of a ZG Resource in MISO’s Planning Resource Auction (“PRA”) to inclusion in a 
Fixed Resource Adequacy Plan (“FRAP”) or Reliability Based Demand Curve (“RBDC”) Opt-
Out, and do not allow the use of uncleared Zonal Resource Credits (“ZRC”) for replacement. 
Participation by ZG Resources in the PRA are further limited – a ZG Resource can qualify for 
ZRCs up to the lesser of its otherwise applicable accreditation, or the seasonal coincident peak 
demand of the ZG Associated Load, plus an accounting for losses not experienced due to the co-
location of the two.  The proposed revisions to Module E-1 are just and reasonable because they 
reflect the limited nature of ZG Interconnection Service, while accommodating the participation 
of ZG Resources and ZG Associated Loads in the PRA.  The proposed revisions to Module E-1 
are as follows: 
a. Section 68A.8 (Calculation of Transmission Losses):  MISO is proposing minor 
changes to this section to state that ZG Resources will be treated the same as 
BTMGs that are not interconnected to the Transmission System and Demand 
Resources by grossing up the MW quantity of such resources by (1.0 + the 
appropriate LBA transmission loss percentage). 
 
b. Section 69A.1.1 (Forecasted Demand Identification):  MISO is proposing 
revisions to this section to require the supplied Coincident Peak Demand 
forecast to identify, in MW, the expected contribution of each ZG Associated 
Load and identify its associated ZG Resource, and to provide that a ZG 
Resource is ineligible for SAC unless its ZG Associated Load is explicitly 
identified in the Coincident Peak Demand forecast. 
 
c. Section 69A.3.1.g (Determination of Deliverability):  MISO is proposing 
revisions to this section to provide that the deliverable amount of certain 
resources may include the amount of ZG Interconnection Service under 
Attachment X only for a ZG Resource. 
 
d. Section 69A.3.1.h (Replacement of Planning Resources):  MISO is proposing 
revisions to clarify that the Planning Resources subject to ZRC replacement 
obligations may include a ZG Resource of any type. 
 
e. Section 69A.3.3 (Load Modifying Resources):  MISO is proposing revisions to 
clarify that a ZG Resource may qualify as a BTMG if not registered as a 
Generation Resource or DIR.  
 
f. Section 69A.3.6 (Behind the Meter Generation Eligibility):  MISO is proposing 
revisions to clarify that a Market Participant registering as a BTMG or ZG 
Resource participating as a BTMG must meet certain requirements.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 20 
 
 
g. Section 69A.3.9 (Penalty Provisions for LMRs): MISO is proposing revisions 
to clarify that ZG Resources participating as BTMG will be subject to 
enumerated penalties applicable to LMRs.  
 
h. Section 69A.4.1 (Seasonal Accredited Capacity of Capacity Resources): MISO 
is proposing revisions to clarify that the SAC for a Capacity Resource that is a 
Generation Resource, but not a ZG Resource, is based on certain enumerated 
criteria. 
 
i. Section 69A.4.5 (Attributes of ZRCs): MISO is proposing revisions to provide 
that all ZRCs associated with a ZG Resource must be used as part of an LSE’s 
FRAP or RBDC Opt Out.  MISO is proposing additional revisions to provide 
that, if the Capacity Resource has ZG Interconnection Service, the Seasonal 
Accredited Capacity will be allocated as one-hundred percent (100%) of SAC. 
 
j. Section 69A.7.3 (Uncleared ZRCs): MISO is proposing revisions to provide 
that ZRCs associated with a ZG Resource that are not used in a FRAP may not 
be used as Uncleared ZRCs. 
 
k. Section 69A.7.8 (Self-Scheduling Option): MISO is proposing revisions to 
provide that ZRCs obtained from a ZG Resource may not be used in a Self-
Schedule. 
 
l. Section 69A.9 (Use of FRAP in the Planning Resource Auction): MISO is 
proposing revisions to provide that all ZRCs associated with a ZG Resource 
must be used as part of an LSE’s FRAP or RBDC Opt Out, and that all ZRCs 
associated with a ZG Resource that are not used in a FRAP shall have no 
capacity value as set forth in Section 69A.7.3. 
 
m. Section 69A.9.1 (Use of RBDC Opt Out in the Planning Resource Auction): 
MISO is proposing revisions to provide that all ZRCs associated with a ZG 
Resource must be used as part of an LSE’s FRAP or RBDC Opt Out.  MISO is 
proposing additional revisions to provide that, if an LSE owns or controls ZRCs 
that are not included in the LSE’s RBDC Opt Out, then such LSE may submit 
ZRC Offers into the PRA for all such excess ZRCs, subject to Module D, and 
that such ZRC Offers may not include ZRCs associated with a ZG Resource. 
 
D. 
Attachment X (Generator Interconnection Procedures).  
The proposed Tariff revisions implement the ZGIA process and are necessary to distinguish 
the key differences in how the ZG Interconnection Service study process and the resulting ZGIA 
will operate in comparison to MISO’s standard three-phase generator interconnection queue.  For 
convenience, MISO discusses the revisions to the GIP by section, below.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 21 
 
 
1. Section 1: Definitions 
 
MISO proposes the following new definitions for addition to the GIP (and ZGIA): 
Point(s) of Withdrawal (POW) shall mean the point(s) where a non-transmission 
facility that is used to withdraw Energy from the Transmission System to serve Load 
connects to the Transmission System. 
MISO proposes this definition in order create a load equivalent to the existing defined term, 
Point of Interconnection, which is used to describe the point at which the Interconnection Facilities 
connect to the Transmission System.  Because the relative location and configuration of Load with 
respect to the Generating Facility and to the Transmission System is a critical component of ZG 
Interconnection Service, vocabulary is needed to discuss the point where Load connects to the 
Transmission System in reference to the Point of Interconnection.  The term “Point(s) of 
Withdrawal” provides a delineation between the two points that facilitates clearer Tariff rules. 
MISO notes that this term can be plural as certain large loads may have more than one point where 
they connect to the Transmission System. 
Transient Tolerance Window shall mean the period of time after a reduction or loss of 
load by the ZG Associated Load by the end of which window the Generating Facility 
with ZG Interconnection Service must have reduced its injections to an amount not 
greater than the Load of the ZG Associated Load.  The Transient Tolerance Window shall 
be no greater than 20 seconds, and is further described by the Business Practices Manual 
for Large Load.  The Transient Tolerance Window will be subject to Transmission Owner 
local planning criteria. 
 
Defining a “Transient Tolerance Window” is necessary to establish rules regarding how 
quickly a Generating Facility must match ZG Associated Load reductions in Demand.  As 
explained further below and in the attached testimony of Mr. Keyser, even with tight coordination 
between a Generating Facility and ZG Associated Load, a Generating Facility generally will not 
be able to ramp down instantaneously in the event of a sudden decrease in Load.52  However, rules 
are needed to require rapid disconnection or reduction in order to prevent impacts to the 
Transmission System from unintended injections.  The concept of a Transient Tolerance Window 
therefore provides a reasonable vehicle for establishing realistic and enforceable rules about how 
quickly a Generating Facility must reduce output.   
After careful consideration, MISO determined that a 20-second limit provides the best 
system-wide balance between what is technically feasible and commercially practical on the one 
hand, and minimizing even transient injections on the other hand.  MISO notes that there may be 
circumstances where a narrower window is necessary and practical given electrical topography on 
certain parts of the MISO System, or Applicable Local Planning Criteria.  It would be impractical 
to identify all such circumstances in the Tariff.  Therefore, the definition allows for the creation of 
Business Practices Manual rules that narrow the window based on specific circumstances existing 
 
52  Keyser at 25-26.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 22 
 
 
on parts of the Transmission System.  By creating an outer window in the Tariff and allowing more 
situation-specific rules to be developed through the Business Practices Manual, this definition 
strikes a needed balance between clear Tariff rules and flexibility to adjust timing based on detailed 
technical considerations.53 
Zero Injection Generation (ZG) Associated Load shall mean a source of electrical load 
that has a Point of Withdrawal that is at the same substation as the Point of Interconnection 
to the Transmission System (i.e. same voltage level at the interconnecting substation) as 
the Generating Facility with ZG Interconnection Service that will serve it. 
 
Adding this defined term to the Tariff provides the vocabulary needed for discussing the specific 
load that a Generating Facility with ZG Interconnection Service is limited to serving.  
Zero Injection Generation (ZG) Interconnection Service shall mean a limited form of 
Interconnection Service that allows an Interconnection Customer to connect its Generating 
Facility to the Transmission System or Distribution System, as applicable, for the limited 
purpose of delivering energy to ZG Associated Load.  ZG Interconnection Service does not 
grant any right to inject energy onto the Transmission System except as may be authorized 
by Section 3.11 of the Generator Interconnection Procedures.  ZG Interconnection Service 
does not convey Transmission Service.  ZG Interconnection Service also does not provide 
a right to serve, or a right to Transmission Service to serve, a ZG Associated Load or retail 
customer except as allowed by applicable state law. 
MISO’s proposed definition of Zero Injection Generation Interconnection Service 
describes a limited form of Interconnection Services that enables a Generating Facility to serve 
Load at the same substation and voltage level as the Generating Facility without authorizing use 
of the broader Transmission System.  The terms of this definition reflect its development through 
the stakeholder process as a limited tool to enable functional co-location arrangements that can be 
rapidly studied and implemented without broader impacts to the Transmission System.  The term 
“zero injection” refers to the lack of injection onto the Transmission System beyond the immediate 
interconnecting substation.  The third sentence of this definition reflects the standard disclaimer 
that Interconnection Service does not convey Transmission Service, which language is also present 
in the existing definitions of ER Interconnection Service and NR Interconnection Service.  The 
fourth sentence of this definition was added to allay concerns that an Interconnection Customer 
could use ZG Interconnection Service to circumvent state law restrictions on serving load or 
inadvertently authorize retail wheeling.  This sentence does not add any new restriction on service 
but merely respects those that may exist at the state level. 
Zero Injection Generation (ZG) Resource shall mean a generating resource with an 
Attachment X defined ZG Interconnection Agreement.  A ZG Resource may participate as 
 
53  This flexibility is limited given that MISO would still be required to define the situations under which the 
Transient Tolerance Window would be reduced in a stakeholder-reviewed Business Practices Manual before 
applying them to a given interconnection.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 23 
 
 
a Generation Resource, Dispatchable Intermittent Resource, Electric Storage Resource, or 
Behind the Meter Generation resource. 
 
The definition of ZG Resource reflects how these Generating Facilities integrate into 
MISO’s market structures and provides a shorter form of identification than “Generating Facilities 
with ZG Interconnection Service” improving Tariff readability where these are discussed.  
Generally, ZG Resources may participate in MISO markets and resource adequacy constructs in 
the same way as generators with other types of Interconnection Service, subject to the limitation 
that their participation is limited to serving, and being credited for serving, the ZG Associated 
Load. 
 
 
MISO proposes the following definitions for ZG Facility Study and ZG Impact 
Assessment: 
 
ZG Facilities Study shall mean the study described in Section 3.2.5.2.2 of these GIP that 
is used to identify any Network Upgrades or Interconnection Facilities that may be needed 
to for an Interconnection Request seeking ZG Interconnection Service. 
 
and 
 
ZG Impact Assessment shall mean the study described in Section 3.2.5.2.1 of these GIP 
that is used to evaluate the impact of an Interconnection Request seeking ZG 
Interconnection Services. 
 
These definitions describe the studies that MISO will conduct for an Interconnection 
Request seeking ZG Interconnection Service.  MISO notes that because only limited injection is 
allowed and Network Upgrades required on the Transmission System beyond the interconnecting 
and neighboring substations generally would preclude the granting of ZG Interconnection Service, 
the scope of these studies is more focused and can be accelerated from the timeframe of System 
Impact Studies and Facilities Studies under the DPP.  
 
 
MISO proposes the following definition for the pro forma agreement that would be 
tendered to an Interconnection Customer at the conclusion of ZG Interconnection Services: 
 
ZG Interconnection Agreement (ZGIA) shall mean the form of interconnection 
agreement governing the terms and conditions of ZG Interconnection Service, set forth in 
Appendix 19 to these Generator Interconnection Procedures. This agreement shall follow 
the form of the Transmission Provider’s pro forma Generator Interconnection Agreement 
with modifications to reflect ZG Interconnection Service and the ZG Interconnection 
Service study process.  Unless otherwise provided in the GIP, all requirements applicable 
to the pro forma Generator Interconnection Agreement shall apply to the ZGIA.  A ZGIA 
is a form of GIA and, where used in the Tariff, references to Generator Interconnection 
Agreements or GIAs encompasses ZGIAs.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 24 
 
 
MISO notes that the ZGIA is closely based on the MISO’s pro forma GIA in Tariff 
Attachment X, Appendix 6 with modifications as described below to provide for ZG 
Interconnection Service.  MISO ultimately expects to merge the ZGIA and GIA, as described 
below.  However, as noted below, MISO has replicated the provisions of the GIA in Appendix 6 to 
Attachment X of the Tariff and added the revisions necessary to implement ZG Interconnection 
Service into Appendix 19 rather than Appendix 6 for administrative reasons.  However, a ZGIA is 
intended to be a form of GIA and MISO intends that references in the Tariff to GIAs refer to ZGIAs 
as well unless otherwise expressly stated.  MISO includes the last sentence of this definition to 
avoid any confusion and clarify that the numerous references in other sections of the Tariff to GIAs 
include ZGIAs by default.  
 
 
Finally, MISO proposes the following defined term to refer to the quarterly study that 
MISO will perform for Interconnection Requests seeking ZG Interconnection Service: 
 
ZG Interconnection Process Quarterly Study Period shall mean the period of time in 
which Interconnection Requests seeking ZG Interconnection Service are submitted to the 
Transmission Provider and compiled for study.  There are four study periods in a year 
with the following start and end dates: 
 
Quarter 1: The first Business Day of March through the last Business Day of 
May; 
Quarter 2: The first Business Day of June through the last Business Day of 
August; 
Quarter 3: The first Business Day of September through the last Business Day of 
November; 
Quarter 4: The first Business Day of December through the last Business Day of 
February. 
 
This definition is based on the definition for the ERAS Quarterly Study schedule and MISO 
proposes a similar quarterly cadence for ZG Interconnection Studies. 
2. Section 3.2.5—ZG Interconnection Service 
MISO proposes to add new section 3.2.5 to the GIP establishing ZG Interconnection 
Service as a new type of interconnection service available under the GIP.  The first proposed new 
paragraph of Section 3.2.5.1 explains that ZG Interconnection Service is, 
restricted Interconnection Service that allows an Interconnection Customer to 
connect its Generating Facility to the Transmission System or Distribution System, 
as applicable, for the limited purpose of delivering energy to a source of electrical 
load that is at the same substation as the Point of Interconnection to the

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 25 
 
 
Transmission System (i.e. same voltage level at the interconnecting substation) as 
the Generating Facility with ZG Interconnection Service that will serve it.54 
 
This service would provide a vehicle for a Generating Facility to serve a large load (or 
other load) that is either located behind the same Point of Interconnection as the Generating 
Facility as well as situations where the Point of Withdrawal of the load source is at the same 
substation and voltage level as the Generating Facility.  As Mr. Keyser explains in his testimony, 
generators that are serving co-located load may not require the same degree of access to the 
Transmission System as those seeking ERIS to serve Load farther afield.  And the limited distance 
over which energy would need to be—and is permitted to—flow allows for a more targeted study.55   
MISO worked closely with its stakeholders over many months, and prior to the issuance of 
the Show Cause Order, to determine the appropriate permissible electrical distance between the 
Generating Facility and load source that should be allowed for ZG Interconnection Service.  As 
part of this process, MISO initially considered allowing ZG Interconnection Service for a 
Generating Facility to serve Load located several buses or substations away.  However, 
stakeholders across differing MISO sectors did not support such a broad reach, citing concerns 
about the practicality of limiting injections to the rest of the Transmission System once the 
generation and load were allowed to be at separate substations, the likelihood of unconstrained 
power flows56 changing over time in unanticipated ways from what was studied, and the potential 
for retail wheeling. 
MISO also considered limiting ZG Interconnection Service to load and generation located 
behind the same Point of Interconnection.  However, after discussions with stakeholders and 
review of proposed configurations, MISO determined that such a restriction would be too narrow 
for the MISO region.  Several potential Interconnection Customers planned to utilize adjacent bays 
in the same substation to run the lead lines for the Generating Facility and Load as a more 
pragmatic and cost-effective approach than expanding one substation bay to house both lead lines 
in order to maintain the same Point of Interconnection.  These stakeholders argued that using an 
adjacent bay would be electrically indistinguishable from housing both the Generating Facility and 
Load behind the same bay given the requirement to install equipment limiting injections to the rest 
of the Transmission System.  Ultimately, MISO recognized that requiring the Generating Facility’s 
Point of Interconnection and the Load’s Point of Withdrawal to be at the same voltage level of the 
same substation provided the right balance of flexibility to enable expected large load co-location 
arrangements while ensuring a minimal use of the Transmission System consistent with a 
permanent zero injection based product.  In reaching this decision, MISO noted that ‘same voltage 
level at the same substation’ is the test applied for whether Points of Interconnection are electrically 
identical under MISO’s Generating Facility Replacement Process.57  Limiting the electrical 
 
54  Attachment X at Section 3.2.5.1. 
55  Keyser at 7-8. 
56  I.e., power flows that it is not practical to contain within a defined area through control equipment.  
57  See Attachment X at Section 3.7.1.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 26 
 
 
distance between the Point of Interconnection and Point of Withdrawal in this way allows MISO 
to offer ZG Interconnection Service on a permanent basis (subject to 15 year automatically 
renewing term provisions) similar to other Interconnection Service products.  This duration is an 
important feature of the ZG Interconnection Service.  MISO understands the Show Cause’s Order’s 
proposed distinction between a potentially permanent co-location service and a temporary 
“proximate location service.”58  ZG Interconnection Service is more of a co-location construct than 
it is a proximate load construct, with the only departure from using a strict ‘same POI’ requirement  
being some very limited flexibility within a single substation to recognize the often complex ways 
that large loads connect—including long-standing large industrial loads connected to the MISO 
Transmission System.  
The second paragraph of proposed Section 3.5.2 outlines several key requirements for ZG 
Interconnection Service.  The first is that the studies must determine that granting ZG 
Interconnection Service will not result in any injections of Energy onto the Transmission System 
beyond the interconnecting substation except for transient injections.  This requirement is 
necessary because limiting injection onto the broader Transmission System is the foundational 
feature of ZG Interconnection Service, and what allows for vastly accelerated study process 
outside of the DPP.  As Mr. Keyer explains, however, there may be limited instances where a 
Generating Facility configured to serve only co-located load may nonetheless make transient 
injections.  This can occur where the ZG Associated Load’s demand abruptly decreases.59  Even 
with communications and other equipment linking the Generating Facility and the ZG Associated 
Load, it often can take a Generating Facility a small period time to lower its own production in 
response.  The Transient Tolerance Window recognizes this fact and allows MISO to properly 
account for it in studies for ZG Interconnection Service, thus avoiding negative impacts to the 
Transmission System.   
The second proposed requirement—that granting ZG Interconnection Service will not 
require Network Upgrades beyond the same substation except for System Protection Facilities—
is important to ensuring that the grant of ZG Interconnection Service is not negatively impacting 
the rest of the Transmission System.  It is not necessary to include this limited product in DPP 
studies because its lack of injection prevents it from having impacts on the broader Transmission 
System and, without impacts to mitigate, it is not necessary for these Interconnection Customers 
to be included in a regional study group.  However, this lack of interaction with other 
Interconnection Requests assumes that the Generating Facility does not drive the need for Network 
Upgrades elsewhere on the Transmission System.  If such upgrades were needed, that would both 
call into question the lack of injection and raise cost-shifting risk for other Interconnection 
Customers.  Therefore, the requirement that no Network Upgrades be required beyond the 
interconnecting substation acts as a key guardrail.  The limited exception to this rule for system 
protection facilities acknowledges that short circuit and other transient study results could require 
facilities to be upgraded beyond the substation, even though injections will be limited to be less 
 
58  Show Cause Order at PP 89, 94-98, 112-115. 
59  Keyser at 25-26.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 27 
 
 
than the Transient Tolerance Window.60  Such equipment is limited to that required to limit 
injection consistent with ZG Interconnection Service.  The costs of such equipment would be borne 
entirely by the ZG Interconnection Customer, obviating the risk of cost shifts to other 
Interconnection Customers or to Load. 
 
The third paragraph of proposed Section 3.2.5.1 provides that ZG Interconnection Service 
is restricted to serving the specific Load identified in the Interconnections Request and included 
in the ZGIA.  This requirement allows MISO to model the load in ZG Interconnection Service  
studies and validate that the proposed configuration is consistent with this service type. Restricting 
ZG Interconnection Service to a specific load is consistent with a co-location concept and ensures 
that the Generating Facility will operate as initially contemplated for its service life, because it has 
no authorization to serve any other load.61  The statement in the fourth sentence that ZG 
Interconnection Service does not convey Transmission Service is consistent with the currently-
effective language in the GIP explaining that Interconnection Service does not convey 
Transmission Service.62  The instant filing does not alter the obligations of the Load/Transmission 
Customer to obtain appropriate Transmission Service.63 
 
The final sentence of the third paragraph and the fourth paragraph are included to allay 
concerns expressed during the stakeholder process that ZG Interconnection Service could be read 
as conflicting with state and local laws by allowing the owner of a generator that is not a Load 
Serving Entity to serve load when not authorized to do so by state law.  The inclusion of this 
language neither imposes, nor is intended to impose, any independent restrictions on an 
Interconnection Customer. 
3. Section 3.2.5.2—ZG Interconnection Service Study 
Proposed Section 3.2.5.2 establishes the studies that MISO will perform for 
Interconnection Requests.  The first paragraph explains that the ZG Resource will be studied and 
granted service at a level not to exceed the Demand of the ZG Associated Load.  This language is 
appropriate and important because ZG Interconnection Service allows the Generating Facility to 
serve only the ZG Associated Load.  Limiting the level of service to the peak Demand of the ZG 
Associated Load effectuates this relationship and provides the necessary study inputs to allow 
 
60  Keyser at 31-32.  
61  As discussed below, this does not prevent an Interconnection Customer that wants to use its ZG Resource to serve 
a different load from obtaining ERIS or NRIS by submitting a new Interconnection Request and proceeding 
through the DPP and obtaining a new GIA without the injection limitations.  
62  Tariff Attachment X at Section 2.4 (No Applicability to Transmission Service). See also, Id. at Section 1: 
Definitions—“Energy Resource Interconnection Service (“Energy Resource Interconnection Service does not 
convey transmission service”) and  Network Resource Interconnection Service (“Network Resource 
Interconnection Service does not convey transmission service.”). 
63  MISO is aware of the show Cause Order’s directives requiring MISO to address the Transmission Service 
implications of various Large Load arrangements and will address them in a forthcoming 205 filing.  The current 
filing addresses only Interconnection Service and is both independently needed as well as a building block for 
further Tariff constructs.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 28 
 
 
MISO to verify that the ZG Resource can serve only the ZG Associated Load.  MISO notes that 
studying a ZG Resource at the level of service not to exceed the ZG Load does not place a limit 
on the installed capacity of the ZG Resource.  Under generally applicable Tariff rules,  
Interconnection Customers may propose Generating Facilities with a higher installed capacity than 
the granted Interconnection Service. 
4. Sections 3.2.5.2.1 and 3.2.5.2.2—ZG Impact Assessment and ZG Facilities 
Study 
Section 3.2.5.2.1 establishes the system impact study that will be used to Study ZG 
Interconnection Service Requests.  As explained by Mr. Keyser, this study is similar to that used 
for ERIS evaluation, with changes necessary to accurately reflect the scope of ZG Interconnection 
Service and determine its impacts.  In this respect, an examination of the electrical connection 
between the Generating Facility, ZG Associated Load, and the Transmission system, and the 
proposed control equipment becomes a critical aspect of the study because it is necessary to verify 
that the limiting injections are viable under the proposed configuration.  Therefore, the ZG Impact 
Assessment will start with a close review of the diagrams and equipment lists included in the 
Interconnection Requests.  Unlike other system impact studies, the ZG Impact Assessment must 
determine that no Network Upgrades are needed to maintain reliability, with the stability and 
steady state analyses testing the impact of injections if the ZG Associated Load trips offline for the 
duration of the Transient Tolerance window. 
Section 3.2.5.2.2 performs the same analysis of the specific facilities needed to 
accommodate the interconnection and is similar to the facilities studies performed for ERIS and 
NRIS Interconnection Requests  during Phases 2 and 3 of the Definitive Planning Phase,64 but with 
a more limited scope reflecting that requirement that no Network Upgrades can be needed other 
than Network Upgrades at the interconnecting substation and system protection facilities to control 
injection onto the rest of the Transmission System.  In order to accommodate an accelerated ZG 
Interconnection Service process timeline, MISO proposes to sequence the ZG Facilities Study 
differently than facilities studies performed in the DPP.  Specifically, MISO proposes to begin the 
portion of the ZG Facilities Study that examines required interconnection facilities at the same 
time MISO begins the ZG Impact Assessment.  This differs from the DPP process, where 
Interconnection Facilities studies are not started until Phase 3, after both a preliminary System 
Impact Study and a Revised System Impact Study have been performed. This approach is 
reasonable for ZG Interconnection Service because Interconnection Facilities are not dependent 
on the results of the ZG Impact Assessment and thus can be studied separately or in parallel. 
Running these studies in parallel allows MISO to have results available within 90 days from study 
commencement, in time for the Interconnection Customer to receive a draft ZGIA.65  For the 
 
64  See Attachment X at Section 7.3.2 et seq. 
65  Due to the enhanced readiness requirements of the ZG Interconnection Service process, including higher deposits 
and an agreement with the load it will serve, MISO has reduced concern that dedicating resources to study 
interconnection facilities at the beginning of the ZG Interconnection Service would be premature. as opposed to 
the DPP.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 29 
 
 
portion of the ZG Facilities Study that focuses on Network Upgrades, MISO proposes to begin 
this portion of the ZG Facilities Study upon the identification of the need for such Network 
Upgrade during the ZG Impact Assessment and no later than one business day after the end of the 
ZG Impact Assessment.  This approach recognizes that a facility study to address a need cannot 
begin before the underlying need is identified.  To expedite the study process, the proposed 
language in the last paragraph of Section 3.2.5.2.2 contemplates MISO commencing portions of 
the study responsive to Network Upgrade as early as possible during the process. This approach is 
made practical by the limited scope of the ZG Impact Assessment and more limited Network 
Upgrades to be studied.  
5. Section 3.3.1—Valid Interconnection Request  
MISO proposes to add a reference to ZG Interconnection Service under the fourth 
paragraph clarifying when changes to the D1 study deposit take effect for Interconnection Requests 
seeking ZG Interconnection Service.  This revision is necessary because the current language of 
this paragraph establishes the effectiveness of periodic increases in the D1 with respect to the 
application deadline of study groups.  Because ZG Interconnection Requests are not studied in a 
group study format, it is necessary to specify the timing of D1 increases with respect to such 
Interconnection Requests.  MISO’s proposal to make such increases effective to Interconnection 
Requests seeking ZG Interconnection Service received after the date of posting such increase 
facilitates orderly processing and ensures such increases are applied only prospectively.    
In the fifth paragraph, MISO proposes to add Interconnection Requests seeking ZG 
Interconnection Service to the list of Interconnection Requests subject to the $150,000 D1 payment 
in order to provide funding for these studies.  Interconnection Requests seeking ZG 
Interconnection Service and Surplus Interconnection Service currently are subject to the $150,000 
D1 payment and the study for ZG Interconnection Service is not less complex or resource intensive 
than these other studies to conduct. MISO submits that this requirement therefore is just and 
reasonable. 
6. Section 3.5.3—Affected System Coordination 
MISO proposes new Section 3.5.3 governing coordination with affected systems in the 
evaluation of ZG Interconnection Requests.  At the outset, MISO notes that the limited injection 
nature of ZG Interconnection Service significantly reduces the likelihood that these Generating 
Facilities will have impacts on neighboring transmission systems requiring network upgrades.  
However, MISO cannot entirely eliminate the possibility that a ZG Resource could have impacts

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 30 
 
 
on a neighboring Transmission System depending on their location and configuration.66  It 
therefore is necessary to make provision for affected system coordination.67 
Proposed Section 3.5.3 closely follows the affected systems coordination procedure 
accepted for ERAS Interconnection Requests.  Specifically, proposed Section 3.5.3 provides that 
MISO will apply the same coordination procedures and screening criteria as that used for 
Interconnection Requests in the DPP with several exceptions necessary to recognize the differing 
timing and study processes applicable to serially studied ZG Interconnection Requests.  These 
exceptions include: (1) providing ZG Interconnection Re quest to the affected system not later than 
ten days prior to the start of the ZG Impact Assessment; (2) providing results to ZG Interconnection 
Customers at such time as they are received; (3) proceeding to issue a ZGIA with an obligation to 
execute study any affected systems study agreements within fifteen days after such agreement is 
tendered for execution to the Interconnection Customer; (4) submitting ZG interconnection 
Requests serially to affected systems; and (5) seeking a relative queue priority date based on the 
date that the ZG Impact study begins. 
MISO submits that these rules are appropriate because they provide a structure for 
processing Interconnection Requests for ZG Interconnection Service rapidly and in a manner that 
recognizes the serial nature of such studies.  Requiring ZG Interconnection Customers to execute 
ZGIAs where affected systems information has not yet been provided is necessary to maintain the 
accelerated speed of the ZG Interconnection Study process and to provide certainty to ZG 
Interconnection Requests in subsequent ZQ Quarterly study groups whose models will be built 
from the prior completed quarterly study.  In arriving at this balance between certainty and speed, 
MISO notes that any need for mitigating impacts to an affected system is likely to be minimal and 
largely a function of the location, configuration, and control equipment selected by the 
Interconnection Customer. 
7. Section 3.11—Additional Requirements for Interconnection Requests 
Seeking ZG Interconnection Service 
MISO proposes several additional requirements for Interconnection Requests for ZG 
Interconnection Service, which requirements are needed to ensure the limited nature of ZG 
Interconnection Service and facilitate studies consistent with this concept.  
First, MISO proposes in Section 3.11(i) and (ii) to require that the Interconnection Request 
for ZG Interconnection service include a one line diagram showing the Generating Facility and 
associated electrical equipment and all the ZG Associated Loads including all Point(s) of 
 
66  For example, such flows could be possible if the Interconnection Customer seeking ZG Interconnection Service 
proposes a Point of Interconnection at a seam between the MISO Transmission System and a neighboring 
Transmission System.  In such circumstances, the system protection facilities that may need to be installed on 
adjacent substations may be located on a neighboring transmission system.  
67  MISO cannot control the study processes of neighboring Transmission Providers but will work with its seems 
partners to develop any additional coordination rules necessary to appropriately model and process ZG 
Interconnection Requests.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 31 
 
 
Withdrawal and the Point of Interconnection of the Generating Facility as well as a power flow 
model including this data and any proposed system protection facilities. Because ZG 
Interconnection Service is restricted to serving a specified load, the ZG Associated Load, 
submission of detailed and accurate one line diagrams and power flow models showing both the 
Generating Facility, the ZG Associated Load, protection facilities, and their configuration with 
respect to the Transmission System is critical to accurately studying how a proposed ZG Resource 
will interact with the Transmission System and ensuring limited impacts.  In addition, it is essential 
to document this configuration in the resulting ZGIA because the results of the ZG Impact Study 
will depend on the proposed configuration remaining as proposed.  Subsection (ii) contains the 
crucial limitation that Point of Interconnection of the Generating Facility and a Point of 
Withdrawal for the ZG Associated Load be at the same voltage level of a common substation.  This 
restriction is necessary to ensure the limited interaction with the rest of the Transmission System 
that underpins ZG Interconnection Service.  
Second, proposed subsection (iii) requires that the grant of ZG Interconnection Service not 
require the construction of Network Upgrades beyond the substation where the Point of 
Interconnection is located other than System Protection Facilities.  As explained by Mr. Keyser, 
this requirement complements and enforces the expectation that ZG Interconnection Service can 
be granted without adversely impacting the broader transmission system.  A proposed 
interconnection that triggers a need for Network Upgrades elsewhere on the system would not be 
consistent with the intended scope of the service as it assumes an impactful injection.  
Interconnection Requests with such impacts are better processed through the DPP where they can 
study in a cluster with other Interconnection Requests with potential impacts on the broader 
Transmission System and mitigation costs than under the ZG Interconnection Service process 
proposed herein. 
Third, MISO proposes to require that an Interconnection Request for ZG Interconnection 
service be submitted 180 Calendar Days before the earlier of the Commercial Operation Date of 
the Generating Facility or the need-by date for the ZG Associated Load.  The reason for this 
requirement is to allow MISO sufficient time to study the proposed interconnection, including the 
information on both the Generating Facility and the ZG Associated Load included in the 
Interconnection Request, and to provide time for other processes that must be completed prior to 
commercial operation and the need by date.68  Further, this requirement allows sufficient time for 
the subsequent MTEP study of the ZG Associated Load to take place. The limited exception to the 
requirement to submit 180 days in advance of the need-by date is necessary to allow the ZGIA 
Process to be used by loads that already are online who, in the absence of such an exception, would 
not be able to utilize this process.  
Fourth, MISO proposes to limit the amount of ZG Interconnection Service to the total 
Demand69 of the ZG Associated Load.  Because ZG Interconnection Services may be used only to 
 
68  Attachment X at proposed Section 3.11.iv. 
69  As defined in MISO’s Tariff, “Demand” refers to the peak demand.  Module A—Definitions: Demand: (“The 
maximum integrated hourly sum of Load occurring over a specified period, such as Day, Month, Season, or

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 32 
 
 
serve ZG Associated Load, authorizing a service level that is higher than what the ZG Associated 
Load has been studied to require would be inconsistent with the limited nature of this product.  
MISO again notes that the limitation on service does not limit the installed capacity of the 
Generating Facility.  As Mr. Keyser explains in his testimony, this approach recognizes the 
differing dispatch levels of various fuel types and allows the Interconnection Customer flexibility 
to build the installed capacity that they require to serve the ZG Associated Load. 
Fifth, the Interconnection Request must include modeling and other technical data as 
described in MISO’s Generator Interconnection Business Practices Manual for the ZG Associated 
Load in order to enable MISO to study the connections between the Generating Facility, ZG 
Associated Load, and the Transmission System in order to verify that ZG Interconnection Service 
can be granted and understand impacts to the Transmission System.  Including the specific 
technical data needed in the Business Practices Manual is consistent with requirements for other 
types of Interconnection Requests and provides needed flexibility to update specific technical 
details as MISO and its stakeholders gain experience with ZG Interconnection Service Requests. 
Sixth, MISO proposes to require the Interconnection Customer to submit an executed 
agreement between itself and the entity with the ZG Associated Load specifying that the full output 
of the Generating Facility is intended to be used by the ZG Associated Load, with an expected 
term of at least five years.70  This requirement is necessary both to prevent speculative 
Interconnection Requests,71 and verify that the load intends to use the output of the Generating 
Facility.  In the context of ZGIA, the agreement takes on added importance because the 
Interconnection Request must include detailed diagrams and technical information pertaining to 
the ZG Associated Load.  It therefore is imperative to verify that the ZG Associated Load has 
mature arrangements with the owner of the Generating Facility in order for MISO to rely on their 
technical information in conducting studies. 
The language of the agreement requirement is based on, and largely identical to, the 
requirements applicable to ERAS Interconnection Requests72 with several differences warranted 
by the design and purpose of ZG Interconnection Service.  First, ZG Interconnection Service 
imposes a requirement that the ZG Associated Load at least intend to use the output of the 
Generating Facility for at least 5 years.  As Mr. Keyser explains in his testimony, this requirement 
exists because when MISO studies transmission service for the ZG Associated Load as part of the 
transmission planning process, the ZG Resource may be relied upon as an alternative mitigation 
to Transmission System Upgrades.  To consider this as an alternative mitigation, MISO must have 
 
Year, expressed in MWs.”).  Under this definition, MISO tracks the highest level of load demand as the 
maximum.  
70  Attachment X at Proposed Section 3.11(vii). 
71  ZG Interconnection Service is only useful if the Interconnection Customer and entity with the ZG Associated 
Load (or the obligation to serve it) have already agreed to use the Generating Facility specifically for that load.  
If such an agreement does not exist then an Interconnection Request for ZG Interconnection Service is, at the very 
least, premature.  
72  Attachment X at currently effective Section 3.9.1(2).

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 33 
 
 
some confidence that it will be available for at least the five-year planning horizon.  This said, 
MISO acknowledges that it may be difficult for Interconnection Customers and ZG Associated 
Loads to agree to a firm minimum term of at least five years.  To accommodate these commercial 
considerations, MISO therefore only requires that the agreement specify an intent to use the full 
output of the Generating Facility for at least five years rather than a firm commitment.  MISO 
views this as the minimum level of certainty needed to rely on the ZGIA in transmission service 
studies.73  Second, MISO has proposed an acknowledgement of self-supply as a permissible 
mechanism for satisfying the agreement requirement where the Interconnection Customer is the 
entity that owns the ZG Associated Load.  This is intended to recognize that, in many states within 
the MISO footprint, Load is permitted to service itself with its own onsite generation.  The 
acknowledgment requires the Interconnection Customer to verify that they both intend and are 
permitted by applicable law to do this.74 
The remaining four forms of agreement are identical to those accepted for the ERAS 
process and, given the flexibility included for an “other agreement” under proposed Section 
3.11(viii)(d), provide sufficient flexibility to account for a wide array of commercial arrangements 
while still acting as a process safeguard.  
Seventh, MISO proposes to include a requirement that a ZG Interconnection Request not 
include a request for any other type of Interconnection Service.75  This requirement is needed 
because the underlying non-injection assumptions behind ZG Interconnection Service would 
conflict with pairing this with other kinds of Interconnection Service, which authorize injections.76  
This requirement also facilitates MISO’S study of ZG Interconnection Service as a more limited 
product in an accelerated timeframe. This language does not prevent an Interconnection Customer 
from submitting a separate Interconnection Request for another type of Interconnection Service 
for the same Generating Facility using the process specified by these Generator Interconnection 
Procedures for such request type.  In the event that an Interconnection Customer obtains another 
form of Interconnection Service for the same Generating Facility, such service shall be deemed to 
supersede any previously-granted ZG Interconnection Service upon its effective date. MISO does 
not intend this requirement to preclude an Interconnection Customer from separately or later 
seeking another form of Interconnection Service and includes language in the second and third 
sentence of this subsection that expressly allows the Interconnection Customer to separately obtain 
such service and have it supplant the more limited ZG Interconnection Service upon its effective 
date.  This would allow, for example, an Interconnection Customer to obtain ZG Interconnection 
Service rapidly to address an urgent need-by date for its associated load while separately pursuing 
NRIS through the DPP. 
 
73  Should the Generating Facility ceased to be used by the ZG Associated Load, MISO likely would need to restudy 
the impacts of transmission service for that Load and either delay the service date or suspend service for that load 
while an alternative mitigation is found in order to prevent adverse reliability impacts to the Transmission System. 
74  Attachment X at Proposed Section 3.11(viii)(e). 
75  Attachment X at proposed Section 3.11(ix).  
76  Keyser at 15.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 34 
 
 
8. Sections 3.11.1 and 4.4—Modification of Interconnection Requests for ZG 
Interconnection Service 
MISO proposes new Section 1.11.1 to prohibit modifications to ZG Interconnection 
Requests after submission.  This prohibition is necessary and reasonable given the 90-day 
timeframe for studies of Interconnection Requests for ZG Interconnection Service. To make this 
timeframe workable and avoid delays that would impact other Interconnection Customers, it is 
necessary to require that these Interconnection Services be well-considered and provide certainty 
with respect to the details to be studied at the time they are submitted.  This readiness requirement 
is mitigated by the fact that MISO will study ZG Interconnection Requests on a quarterly basis.  
Therefore, an Interconnection Customer that is not certain of the details to be included in its 
Interconnection Request would only need to wait until the following quarter for another 
opportunity to be studied.   
 
Section 3.11.1 includes one exception made necessary by process sequencing.  MISO 
proposes to require, and therefore allow, the ZG Interconnection Customer to move its Point of 
Interconnection to the Transmission System if the ZG Associated Load subsequently moves the 
Point of Withdrawal to not be at the same substation and voltage level as the Point of 
Interconnection.  In such circumstance, the Interconnection Customer would need to move its 
proposed Point of Interconnection to match the move made by the ZG Associated Load. MISO 
proposes to permit this move for several reasons.  First, because the premise of ZG Interconnection 
Service is based on the relative location of the ZG Associated Load and the ZG Resource, it is 
more important from a system impact study perspective to prevent the Point of Interconnection 
and Point of withdrawal from separating than it is to prevent the Point of Interconnection from 
moving if the load’s location moves.77  Second, MISO expects that Interconnection Requests for 
ZG Interconnection Service often will be submitted to MISO before transmission service is 
requested by or on behalf of the ZG Associated Loads.  This sequencing allows MISO to consider 
the executed ZGIA in the transmission service study. Because the Interconnection Request for ZG 
Interconnection Service likely will precede the transmission service study process, it is not 
practical to hold the load to a proposed Point of Withdrawal before it has even submitted its own 
application; doing so would undermine the scoping discussions between the load, its Load Serving 
Entity, and the applicable Transmission Owner that occur during the load study process. This is 
true under MISO’s current Tariff and business practices surrounding load integration studies and 
MISO expects this sequencing to continue under other study processes currently being developed 
to address the concerns raised in the Show Cause Order.  MISO therefore submits that both the 
general prohibition on modifications and the Point of Withdrawal move exception are reasonable.  
 
 
Consistent with proposed Section 3.11.1, MISO proposed to add a new paragraph at the 
end of Section 4.4 (Modifications) to implement the move of a POI to correspond to a POW move.  
The proposed new language reiterates the requirement to move the POI when the POW moves and 
requires that this be done prior to the change taking effect, which is necessary to allow MISO to 
study the impact of the move.  When such a change is submitted, MISO would revalidate the 
 
77  Keyser at 28-29.

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Page 35 
 
 
Interconnection Request and determine whether it has material adverse impacts. If such impacts 
are identified, the Interconnection Request will be assigned a new queue position.  This is 
consistent with existing tariff rules on material impacts applicable to Interconnection Requests.  
The final proposed sentence addresses the situation in which such a modification occurs after the 
ZGIA has become effective, requiring a restudy and an amendment to document such restudy and 
any associated costs, or terminate the ZGIA within 60 Calendar Days after the restudy is 
completed.  This language recognizes that an Interconnection Customer may not have any ability 
to control the timing of the Load’s transmission service study process and that such changes may 
need to be made even after the ZGIA is completed.  The proposed language prevents negative 
impacts to other Interconnection Customers from post-ZGIA changes and facilitates timely 
coordination between the ZG Interconnection Service Customer and its ZG Associated Load. 
 
9. Section 3.11.2 Evaluation Process and Study Limits  
 
MISO proposes a quarterly study cadence for ZG Interconnection Service Interconnection 
Requests as well as a limit of ten such Interconnection Requests per quarter.  The quarterly cadence 
aligns with the expected duration of the ZG Impact Assessment in order to avoid overlapping 
studies.  MISO determined that 10 such Interconnection Requests is an appropriate quarterly limit 
because it balances opportunities for prompt study with avoiding the reduction of personnel and 
resources needed to process the DPP, which will remain the primary focus of MISO’s 
interconnection process.  ZG Interconnection Service, while valuable, is a niche tool.  MISO does 
not expect to receive more than ten such Interconnection Requests a quarter as the process matures.  
The proposed limit thus is a safeguard in case ZGIAs prove more popular than expected. 
 
In order to avoid undue disruption to the DPP, MISO proposes to allow Interconnection 
Requests in the DPP to withdraw and commence the ZG Interconnection Service study process 
only if they have not yet reached Decision Point II of their DPP cycle. This avoids the risk of 
unscheduled restudy to other DPP Interconnection Requests because Interconnection Customers 
currently can withdraw from the DPP at Decision Point II with such withdrawals being accounted 
for in Phase 3 of the DPP.  For the same reason, MISO does not propose to excuse withdrawing 
Interconnection Requests from the currently-applicable penalty provisions of Section 7.6.2.1.1 and 
7.8 of the DPP.  The prohibition withdrawals after Decision Point II will be enforced through a one 
year waiting period before an Interconnection Request for the same project can be processed for 
ZG Interconnection Service.  MISO believes that this is a sufficient deterrent against late stage 
transfers.   
 
10. Section 3.11.3—ZG Interconnection Service-Notice to Proceed  
 
Proposed Section 3.11.3 provides that the Interconnection Customer shall inform MISO 
whether it intends to proceed to a ZGIA within 5 Business Days after having received the results 
of the ZG Impact Analysis.  As noted above, MISO has designed the process to allow for the 
simultaneous commenced of the portion of the ZG Facilities Study focusing on Interconnection 
Facilities at the same time as the ZG Impact assessment commences.  Given the same 90 Calendar

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Page 36 
 
 
Day timeline, the Interconnection Customer therefore should have results from both of those 
studies at the time it elects to proceed to ZGIA.  
 
MISO’s proposed process also allows for the commencement of ZG Facilities Studies as 
the needs driving them become identified.  While this admittedly does not guarantee that the 
portion of the ZG Facilities Study focused on Network Upgrades will be completed at the time an 
election to proceed must be made, MISO believes that this tradeoff is reasonable to allow for a 
quarterly study process and facilitate the rapid interconnection of co-location arrangements with 
short need-by dates.  In reaching this conclusion, MISO considered the fact that the planning-level 
costs for addressing system impacts will be provided in the ZG Impact Assessment, with the ZG 
Facilities Study focusing more on the specific design details of the Network Upgrade.  Thus, an 
Interconnection Customer will have this cost information at the time it must elect to proceed.  
Second, given the limited scope of potential Network Upgrades that can be required in a process 
that does not allow for Network Upgrades other than system protection facilities beyond the 
interconnecting substation, both the risk and uncertainty of potential Network Upgrade costs is far 
more limited in the ZG Interconnection Service process than under other processes where 
significant Network Upgrades on other parts of the Transmission System may be required.  For 
similar reasons, and as noted above, MISO also will not delay the election to proceed until the 
receipt of any affected systems analysis.  
 
11. Section 3.11.4—ZGIA for ZG Generating Facility  
 
Proposed section 3.11.4 provides that MISO will tender a draft pro forma ZGIA or 
amendments within 5 Business Days after receiving the Interconnection Customer’s Notice to 
Proceed.  This accelerated timeframe reflects a shortening of the DPP’s deadline to tender a ZGIA 
from 30 Calendar Days to 5 Business Days and is consistent with the equivalent shortening of the 
Interconnection Customer’s time to elect whether to proceed from 30 Calendar Days to 5 Business 
Days in Section 3.11.3.  This section further reinforces MISO’s obligation to complete all portions 
of the ZG Facilities study by the specified deadline.78   
 
12.  Section 11.1-11.3—Tender, Negotiation, Execution, and Filing Processes 
MISO proposed revisions to Sections 11.1 (Tender), 11.2 (Negotiation), and 11.3 
(Execution and Filing) to list ZGIAs along with the currently referenced GIAs and EGIAs as forms 
of agreements subject to the tender, negotiation, and execution processes.79  In designing the ZG 
Interconnection Service process, MISO determined to align the tender, negotiation, and execution 
 
78  As a practical matter, this will refer only to the portion of the ZG Facilities Study examining Network Upgrades 
because the portion focusing on Interconnection Facilities must be completed on the same timeframe as the ZG 
Impact Analysis whereas the portion of the ZG Facilities Study addressing Network Upgrades cannot begin until 
the impact requiring such Network Upgrade to address is identified through the ZG Impact Assessment.  However, 
as previously noted, this need not delay the tender of a draft ZGIA because the costs of needed Network Upgrades 
would be identified in the ZG Impact Analysis.  
79  Attachment X at Sections 11.1—11.3.

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and filing periods with the timeframes applicable to EGIAs rather than standard GIAs in order to 
expedite the agreement process.  Building on MISO’s previous experience with ERAS, these  
accelerated timeframes represent the amount of time MISO believes is practical to reduce 
timeframes while maintaining a robust, detail-oriented process.  Like EGIAs, ZGIAs are intended 
for ready projects where the load and generator already have an agreement.  Under the ZG 
Interconnection Service process, specific configuration details as between generation and load 
must be planned in advance in order to be included in the Interconnection Request for ZG 
Interconnection Service, and the potential Network Upgrades as more limited than either under 
ERAS or the DPP.  Thus, MISO submits that it is reasonable to accelerate the tender, negotiation, 
execution, and filing processes for ZGIAs to match other expedited process timeframes. 
13. Miscellaneous Revisions to Attachment X  
In addition to the foregoing, MISO also proposes conforming revisions to other portions 
of Attachment X to list the ZGIA or ZG Interconnection Service in Tariff Sections listing other 
types of service or agreements.  Specifically, MISO proposes the following revisions: 
• Section 2.1 (Application of Generator Interconnection Procedures: MISO proposes new 
subsection (j) providing that a Request for ZG Interconnection Service is within the scope 
of the GIP. 
• Section 3.2 (Identification of Types of Services): MISO proposes to add ZG 
Interconnection Service to the list of service types. 
• Section 11.4 (Commencement of Interconnection Activities): MISO proposes to add 
“ZGIAs” where GIAs are listed to clarify that these provisions also apply to ZGIAs. 
• Sections 13 (Confidentiality) including subsections 13.1, 13.4, 13.5.1, 13.5.2, 13.6: MISO 
proposes to add “ZGIAs” where GIAs are listed to clarify that these provisions also apply 
to ZGIAs. 
• List of Appendices to GIP:  MISO proposes to add the JTIQ Commitment Agreement an 
ZG Interconnection Agreement to the list of Appendices.  This is a ministerial change.  The 
JTIQ Commitment Agreement is accepted by the Commission and not in any way changed 
by this filing.  MISO here is simply adding it to the list.  
 
E. 
Attachment X – Appendix 1 (Interconnection Request for a Generating 
Facility). 
 
MISO is proposing to revise this Appendix to integrate the ZGIA framework into the 
interconnection request form.  These revisions include adding new options for interconnection 
requests and interconnection service to accommodate the new ZG Interconnection Service, 
confirm that the amount of ZG Interconnection Service cannot exceed the total amount of its ZG 
Associated Load, requirements to describe the ZG Associated Load and facilities to connect to the 
Transmission System, along with System Protection Facilities or operating procedures to prevent 
injections onto the Transmission System beyond the substation and voltage level where the 
Resource is located, and requirements for the disclosure of additional information for MISO to 
evaluate the request.  The specific changes are:

The Honorable Debbie-Anne Reese 
August 18, 2026 
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• Section 2: MISO has added a new checklist item for a Generating Facility to indicate the 
request is for processing through the ZG Interconnection Service study process. 
 
• Section 3: MISO has added a new checklist item to select ZG Interconnection Service as 
the requested service type.  
 
• Section 4: MISO has added a new row for ZG Interconnection Service to the table of 
required information by type of service requested. This row requires the Interconnection 
Customer to indicate the MW/MVAR of the request and states that the amount of ZG 
Interconnection Service cannot exceed the total Demand of the ZG Associated Load.  
 
• Section 9:  MISO has added new Section 9 requiring the Interconnection Customer to 
provide a description of the ZG Associated Load, including its need by date, and 
connecting facilities, system protection facilities, and any proposed operating 
requirements necessary to prevent injections beyond the interconnecting substation.  This 
information is critically important in evaluating the potential impacts of the Generating 
Facility. 
 
• Attachment A-5: MISO has added a new paragraph below the dynamic modelling 
information required for other types of Interconnection Requests to require 
Interconnection Customers seeking ZG Interconnection Service to provide a detailed 
power flow model that includes all ZG Associated Loads, their Point(s) of Withdrawal and 
the POI for the Interconnection Request, as well as system protection facilities.  This 
provides necessary information for MISO to study the Interconnection Request.  
 
• Attachment A-6: MISO has added a paragraph requiring the one line diagram submitted 
with a ZG Interconnection Request to include all ZG Associated Loads and their Point(s) 
of Withdrawal in order to facilitate accurate study of the Generating Facility and ZG 
Associated Load. 
MISO submits that these requirements are just, reasonable, and necessary to the performance of 
ZG Interconnection Service given the centrality of the configuration of the Generating Facility and 
ZG Associated Load to this new type of service.  
F. 
Attachment X – Appendix 19 (ZG Interconnection Agreement (“ZGIA”)).   
MISO is proposing to add a new Appendix 19 to Attachment X, titled “ZG Interconnection 
Agreement” (“ZGIA”).  This new appendix contains the ZGIA to be executed between the 
Interconnection Customer, the Transmission Owner, and MISO, and contains the material 
provisions relating to ZG Interconnection Service.  At the outset, MISO notes that it developed the 
revisions to its pro forma Generator Interconnection Agreement needed to accommodate ZG 
Interconnection Service to fit as an option within the same pro forma agreement currently used for

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 39 
 
 
all other types of Interconnection Service—Attachment X, Appendix 6.80  MISO proposes the 
ZGIA a new Appendix 19 to the GIP in this filing as a pragmatic means of avoiding potential 
administrative impacts to the rest of the queue.  MISO currently anticipates that DPP cycles 
scheduled to proceed to GIA in the next 6 months to result in hundreds of GIAs being negotiated, 
executed, and submitted to the Commission for existing service types.  Introducing new revisions 
to the pro forma GIA at this time would complicate this process considerably and risk processing 
delays81  Incorporating these revisions temporarily into a new Appendix 19 avoids these 
complications.  MISO intends to make a subsequent 205 filing, following the acceptance of the 
revisions proposed in this docket to incorporate the provisions of Appendix 19 into Appendix 6 
and remove Appendix 19 from the Tariff82 with a proposed effective date timed to avoid agreement 
execution processing disruptions.   
MISO includes the foregoing discussion because it is necessary to explain the structure of 
the revisions proposed herein.  MISO views the proposed ZGIA as part of its GIA construct rather 
than as a separate agreement. MISO therefore has not proposed to eliminate accepted language 
contained in Appendix 6 or develop a customized agreement tailored only to ZG interconnection 
Service.  MISO therefore discusses the Tariff language herein as revisions to the existing pro forma 
GIA (Attachment X Appendix 6) that ultimately will be housed therein and requests the 
Commission review them in that light.83  To facilitate discussion, revisions to the pro forma GIA 
are grouped by article and appendix below: 
1. Revisions to Recitals  
MISO proposes a new third recital for use in the ZGIA that explains that the output of the 
Generating Facility will be used to serve the ZG Associated Load. Including this recital provides 
clarity about what the ZGIA does at the front of the document.84  MISO also proposes to revise the 
final recital to remove the reference to a Provisional Generator Agreement because MISO has not 
proposed to develop a provisional ZGIA.85 
 
80  Attachment X—Appendix 6 is used for ERIS, NRIS, Generating Facility Replacement, Surplus Interconnection 
Service, etc.  
81  The group nature of DPP studies means that studies complete and GIA processing deadlines become due in waves. 
Putting this version of the pro forma GIA in a new appendix avoids versioning issues that could otherwise impact 
interconnection Customers, especially if compliance is required.   
82  Because Appendix 19 is built on the current version of the pro forma GIA, the subsequent filing would largely be 
ministerial.  MISO would select an effective date that avoids disruption to Interconnection Customers. 
83  Consistent with this approach, MISO has included as Tab D to this filing a redline comparing Attachment X—
Appendix 19 to Attachment X—Appendix 6. 
84  When merged with Appendix 6, MISO would include this recital in brackets indicating it is to be used only for 
ZGIAs. 
85  MISO has not proposed a provisional ZGIA in part because the ZG Interconnection Process is rapid and in part 
because the ZG Impact assessment is necessary to verify non-injection.  MISO will address how this recital would

The Honorable Debbie-Anne Reese 
August 18, 2026 
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2. Revisions to Article 1—Definitions 
MISO proposes to include the same new and revised definitions in the ZGIA that are 
proposed for inclusion in the GIP.   The proposed  terms and definition language is identical to that 
described above for GIP revisions except for non-substantive edits needed to reflect the location 
of the definition in the ZGIA rather than the GIP.86  MISO refers to its discussion above and asks 
that the Commission accept the definition changes as just and reasonable for the reasons explained 
in the discussion of these changes.  
3. Revisions to Article 2—Effective Date, Term, and Termination  
MISO proposes to include a sentence after the second sentence of Article 2.3.1 clarifying 
that for the purposes of the ZGIA, Commercial Operation refers to supplying Energy to the ZG 
Associated Load and excludes commercial arrangements with other parties.  This provision 
ensures consistency with the limited nature of ZG Interconnection Service and avoids potential 
confusion about what constitutes “Commercial Operation” for a ZG Resource.  
In addition, MISO also proposes to revise Article 2.4.1 regarding cancellation of Network 
Upgrades and Interconnection Facilities in the event of termination to provide that the financial 
impact analysis performed under Section 7.8 of the GIP and the Automatic Withdrawal Penalty 
under Section 7.8.1 are not applicable to ZGIAs.  These revisions are appropriate because ZG 
Interconnection Service does not proceed through the Definitive Planning Phase and thus do not 
pay DPP milestones, DPP Decision Points, or have other Interconnection Requests in their study 
group.  Thus, these GIP provisions would not apply to ZG Interconnection Requests. The revisions 
to Article 2.4.1 thus avoid potential confusion about the applicability of DPP provisions to ZG 
Interconnection Service Requests being terminated after a ZGIA has been issued.  The non-
applicability of GIP Sections 7.8 and 7.8.1 is reasonable for the additional reason that ZG 
Interconnection Service Requests cannot trigger the need for Network Upgrades beyond the 
interconnecting substation except for system protection facilities at the adjacent substation and 
their Interconnection Requests are not expected to have material impacts on Interconnection 
Customers in the DPP. 
4. Article 4—Revisions to Scope of Service 
MISO also proposes to include new sections 4.1.4 through 4.1.4.2 into the ZGIA and add 
a sentence to the end of Article 4.3 describing ZG Interconnection Service and its Transmission 
Service implications.  The language of these sections is functionally identical to its counterpart in 
GIP Section 3.2.5.1 and is just and reasonable for the same reasons discussed with respect to that 
section.  MISO again notes that the ZGIA does not alter existing requirements, obligations, or 
processes with respect to obtaining Transmission Service.  MISO intends to address Transmission 
 
be made applicable only to ZGIAs once Appendix 19 and Appendix 6 are merged in the subsequent 205 filing 
that merges them.  
86  These changes consists of revising “these GIP” to “the GIP” in Appendix 19 in order to avoid confusion.  The 
change is not intended to be substantive.

The Honorable Debbie-Anne Reese 
August 18, 2026 
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Service, including the provision of Transmission Service to co-located loads, in a separate 205 
filing.  
5. Article 7—Revisions to Metering and Market Registration Requirement 
 
MISO proposes to add a sentence to the end of Article 7.1 of the ZGIA a requirement that 
Interconnection Customers granted ZG Interconnection Service must install and meter separately 
from any metering used for the ZG Associated Load.  In addition, MISO proposes new Article 
7.1.1 establishing a market registration requirement for ZGIAs, as follows: 
 
 
7.1.1: Market Registration:  An Interconnection customer with a Generating 
Facility granted ZG Interconnection Service greater than 5 MW shall submit a 
completed Market Participant Application pursuant to Section 38.2 et seq. of the 
Tariff (Module C) not later than thirty (30) Calendar Days after the executing or 
requesting the unexecuted filing of this Agreement  Interconnection Customer with 
ZG Interconnection Service shall take all steps required by the MISO Tariff and 
applicable Business Practices Manual to complete registration as a Generation 
Resource, Energy Storage Resource, or Dispatchable Intermittent Resource based 
on its applicable operating characteristics prior to its Commercial Operation Date 
and shall maintain such registration for the duration of its ZG Interconnection 
Service.87 
 
 
The reason for these requirements is to provide a mechanism for accurately measuring 
flows between the ZG Generator and ZG Associated Load, which facilities charges and credits, 
and serves as a mechanism for verifying compliance with the Interconnection Service limits under 
the ZGIA.  With respect to market registration, Mr. Keyser explains that ZG Resources and their 
ZG Associated Loads are allocated a share of market-distributed costs and that some market 
charges, such as ancillary services for load, and administrative charges, are billed based on gross 
MW volumes in the Day-Ahead and Real-Time markets.88  Requiring ZGIA Resources to register 
as market resources is needed to allow the MW volumes for both load and generation to be captured 
separately, resulting in appropriate billing of these charges.89  Including this requirement also 
allows the ZGIA construct to respond to the concerns the Commission raised in the Show Cause 
Order relating to ensuring that loads participating in co-location arrangements are properly subject 
to transmission service and ancillary service rates.90 
 
6. Revisions to Article 9.7—Outages and Interruptions 
 
 
87  Attachment X, Appendix 19 at proposed Article 7.1.1. 
88  Keyser at 38. 
89  Id.  
90  Show Cause Order at PP 95-96.

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MISO proposes to add new article 9.7.4.7 establishing the obligation of a Generating 
Facility with ZG Interconnection Service to reduce production of energy under certain conditions.  
The new requirement provides, in relevant part: 
 
 
…a Generating Facility with ZG Interconnection Service shall: 
a.  Install communications and monitoring equipment to enable it to monitor the 
demand of the ZG Associated Load. 
b. Install equipment to enable the Generating Facility with ZG Interconnection service 
to reduce its injections to a level that does not exceed the Demand of the ZG 
Associated Load within the Transient Tolerance Window. 
c. Cease all injection of Energy onto the Transmission System within the time permitted 
by the Transient Tolerance Window in the event that any Transmission Facility over 
which Energy must flow in order to reach the point of interconnection or Point of 
Withdrawal of the ZG Associated Load trips offline.  
 
The equipment to be used by the Generating Facility with ZG Interconnection Service to 
comply with the requirements of this 9.7.4.7 shall be identified in Appendix A of this 
ZGIA.  Appendix A of this ZGIA shall include a one line diagram showing the Generating 
Facility and associated electrical equipment with appropriate rating and impedance 
information and all the ZG Associated loads including all Point(s) of Withdrawal and the 
Point of Interconnection of the Generating Facility to the Transmission System for the 
Interconnection Request.91 
 
These requirements to install monitoring and communication equipment to monitor the 
demand of the ZG Associated Load, install equipment that enables the Generating Facility to 
reduce injections to a level that does not exceed Deman and to actually reduce its output within 
the Transient Tolerance Window are key features of the ZGIA and necessary to enabling the ZG 
Interconnection Service construct to function as intended.  The premise of ZG Interconnection 
Service is that injections beyond the interconnecting substation can be limited and that energy will 
flow to the ZG Associated Load.  Therefore, if there is a decrease in the ZG Associated Load’s 
demand, it is important to correspondingly reduce the output of the ZG Resource to prevent power 
from flowing out onto the Transmission System.  The requirements of subsection 9.7.4.7(a) ensure 
communications between the ZG Resource and ZG Associated Load.  This works with the 
requirements of 9.7.4.7(b) to install equipment capable of enabling the Generating Facility to 
reduce its Load within the Transient Tolerance Window and the requirements of 9.7.4.7(c) to 
actually cease injections if an element of any Transmission Facility over which energy flows trips 
offline.   
 
 
MISO has built flexibility into framework for the Interconnection Customer to select the 
equipment that it believes is most appropriate for its configuration by listing this in its 
Interconnection Request.  MISO will verify that the ZG Resource can limit injections as proposed 
 
91  Attachment X Appendix 19 at proposed Article 9.7.4.7.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 43 
 
 
and will document the required equipment and configuration in Appendix A of the GIA.  Article 
9.7.4.7 makes this an enforceable term of the ZG Interconnection Service granted. 
 
 
In addition, MISO proposes to add a sentence at the end of Article 9.7.5 (Requirements for 
Protection) clarifying that for ZG Resources, transient injections do not violate the requirements 
of that article as long as they remain within the Transient Tolerance Window.  This language is 
reasonable because it recognizes that the Generating Facility may not be able to switch of 
instantaneously and instead sets its obligation to be consistent with the Transient Tolerance 
Window, which is incorporated into the ZG Impact Analysis.  This sentence references the 
Business Practices Manual for Large Load given the technical nature of the requirement.  This 
appropriately balances the certainty providing the parameters of the Transient Tolerance Window 
established through its definition in the Tariff with needed flexibility to define how the Transient 
Tolerance Window is applied under specific conditions as MISO develops its Business Practices 
Manual revisions through the stakeholder process.  
 
7. Revisions to Article 11.3—Network Upgrades, System Protections 
Facilities, and Distribution Upgrades 
MISO proposes to include two new sentences at the end of section 11.3 stating that the 
Generating Facility with ZG Interconnection Service must connect at the same voltage level and 
substation as the Point(s) of Withdrawal for the ZG Associated Load it serves and not require the 
construction of Network Upgrades beyond the substation where the Point of Interconnection is 
located other than System Protection Facilities.  This language restates the requirements of GIP 
Section 3.11(ii) and (iii) for a proposed Generating Faciltiy, ensuring that these requirements are 
reflected in the resulting ZGIA.  
8. ZGIA Appendices 
MISO proposes several revisions to Appendix A in order to implement ZG Interconnection 
Service.  First, MISO proposes to include a new Section 2 that identifies the MW, Point(s) of 
Withdrawal and need by date of the ZG Associated Load.  This section requires a single line 
diagram illustrating the connections between the Generating Facility, ZG Associated Load, and the 
Transmission System and the identification of the equipment and configurations that prevent 
injections outside of the Transient Tolerance Window.  This section reflects the technical 
requirements applicable to ZG Interconnection Service and makes the studied equipment and 
configuration a part of the ZGIA that can be enforced.  This requirement works with MISO’s 
material modification rules in the same way that section 1 operates to ensure that changes to the 
configuration of the AG Associated Load that could affect the impacts of the ZG Interconnection 
Service as studied are subject to the same modification rules applicable to the Generating Facility 
under Section 1 of Appendix A.  This is necessary and appropriate given the importance of these 
configuration details to the provision of ZG Interconnection Service. 
In appendix B, MISO proposes new milestone 1h requiring the Interconnection Customer 
to submit a completed Marekt Participant Application within 30 Calendar days after execution or 
the request for an unexecuted filing of the ZGIA.  MISO also proposes a milestone 18 requiring

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 44 
 
 
the Interconnection Customer to complete the market registration process before its commercial 
operation date.  These milestones implement the requirements proposed for inclusion in ZGIA 
Article 7.1.1.  MISO proposes an obligation to begin the market registration process as well as a 
required completion date because, in MISO’s experience, market registration can take several 
months from the time a completed application is submitted.  As explained above, market 
registration is needed in order to inform transmissions service and ancillary services rates 
applicable to the ZG Associated Load. Therefore the process must be completed prior to 
Commercial Operation.  Requiring that the application be started early in the process avoids 
surprises to the Interconnection Customer near the end of the development process that could delay 
Commercial Operation because it allows MISO and the Interconnection Customer to work together 
to resolve any deficiencies or other problems with the market registration process early to avoid 
potential delays.  This is consistent with the approach accepted as part of MISO’s Joint Targeted 
Interconnection Queue framework, which imposes similar market application submission and 
completion requirements.92  
9. Miscellaneous  Revisions 
MISO has revised references to the “GIA” to instead refer to the “ZGIA” or “GIA or ZGIA” 
as appropriate in order to correctly identify this agreement is a ZGIA.  These revisions do not have 
a substantive impact but do provide clarity about the agreement being referred to.  
H. 
Attachment FF (Transmission Expansion Planning Protocol).   
MISO is proposing to revise this Attachment to require contractual commitments 
associated with ZG Associated Load to include demonstration that both (1) an executed agreement 
between the entity with the ZG Associated Load and the Generating Facility with the associated 
ZG Interconnection Service is in place and spans at least the five year planning horizon; and (2) 
the Generating Facility associated with the ZG Associated Load has achieved Commercial 
Operation by the time that the transmission solution would otherwise need to be in service.  The 
proposed revisions state that, in the event that the Generating Facility associated with the ZG 
Associated Load fails to achieve Commercial Operation by the date that the transmission solution 
would otherwise need to be in service or the contract between the ZG Associated Load and the 
associated Generating Facility terminates, then the Transmission Provider may require the 
applicable Load Serving Entity to delay the in-service date of ZG Associated Load. 
I. 
Schedule 53 (Seasonal Accredited Capacity Calculation).   
MISO is proposing to revise this Schedule to provide that certain ZG Resources, either (i) 
those that do not have at least 60 days of Real-Time offered availability when designed for RAR 
over the last three (3) years for each Season or (ii) Resources on Catastrophic Generator outage 
during a season they are designated for RAR, will not have a SAC value that exceeds the identified 
Coincident Peak Demand forecast of the ZG Associated Load, if any. 
 
92  See, Tariff Attachment X—Appendix 18 (JTIQ Commitment Agreement) at Article 4.1.

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August 18, 2026 
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IV. 
STAKEHOLDER ENGAGEMENT 
MISO has engaged in detailed discussions with stakeholders on Large Load issues since 
2024 through various stakeholder entities and workshops.  MISO first discussed Large Loads with 
stakeholders in the context of Expedited Project Review process improvements at the Planning 
Advisory Committee (“PAC”) and Planning Subcommittee (“PSC”) in 2024 and 2025.  Moreover, 
since 2024, MISO has discussed coordinating the MISO Transmission Expansion Plan (“MTEP”) 
and Definitive Planning Phases processes to accommodate Large Loads at the PSC.  MISO 
additionally discussed Large Load citing methodology at the November 18, 2025 Futures Redesign 
Workshop. 
MISO first introduced ZGIA to stakeholders at the PSC on December 3, 2025.93  At the 
meeting, MISO provided a high-level overview of the ZGIA concept and solicited feedback from 
stakeholders.  MISO subsequently discussed the proposal at the PAC and the Large Load Working 
Group.  At the January 21, 2026 PAC, MISO described how ZGIA resource configurations may 
lead to reduced transmission network upgrade needs and detailed the stakeholder feedback 
submitted in response to the December 3, 2025 PSC presentation.  At the February 25, 2026 PAC, 
MISO began laying out a proposal for formalizing ZGIA by providing the interconnection and 
planning elements of the proposal, the first two elements of the proposal. MISO requested 
stakeholder feedback on the proposal.  At the first LLWG meeting on April 20, 2026, MISO 
described the elements of the ZGIA proposal relating to resource adequacy and markets and 
reliable operations, the last two elements of the proposal, and requested stakeholder feedback.  
MISO also provided materials outlining MISO’s response to previously submitted stakeholder 
feedback.   
At the April 22, 2026 PAC, MISO shared draft Tariff language with stakeholders reflecting 
the interconnection and planning elements of the ZGIA proposal.  The draft Tariff language 
included specifics that originated from stakeholder feedback, including language ensuring that a 
ZGIA disconnects if the facilities connecting it to its associated load.  MISO also provided 
materials outlining MISO’s response to previously submitted stakeholder feedback.  MISO 
requested stakeholder feedback on the proposed draft Tariff language.  
At the May 14, 2026 LLWG, MISO shared draft Tariff language reflecting the elements 
ZGIA proposal relating to resource adequacy and markets and reliable operations.  The draft Tariff 
language incorporated stakeholder feedback regarding planning studies and multiple Points of 
Injection.  Specifically, in response to stakeholder feedback regarding MISO’s initial proposal 
allowing multiple POIs, MISO proposed only allowing multiple POIs if the ZGIA is located at one 
of the stations, i.e. Points of Withdrawal, of a Large Load Campus.  MISO requested stakeholder 
feedback on the draft Tariff language.  
At the May 27, 2026 PAC, MISO shared updated draft Tariff language with stakeholders 
on the interconnection and planning elements of the ZGIA proposal.  The draft Tariff language 
 
93  See Keyser, Attachment A – Table of Stakeholder Meetings.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 46 
 
 
incorporated stakeholder feedback, including language specifying further detail of the ZGIA 
interconnection studies, language clarifying that ZGIAs do not supersede state jurisdiction, and 
revising the POI rules.  MISO additionally decided not to pursue the campus approach in response 
to stakeholder feedback.  MISO requested stakeholder feedback on the proposed draft Tariff 
language.  At the June 10, 2026 LLWG, MISO reviewed the final ZGIA proposal with stakeholders 
and provided draft Tariff language that incorporated stakeholder feedback.  At the June 29, 2026 
LLWG, MISO continued the dialogue regarding the ZGIA proposal to provide stakeholders an 
opportunity to provide feedback on any remaining concerns and in response to the Show Cause 
Order.  
At the July 15, 2026 PAC, MISO stated in its Liaison Report that the MISO Steering 
Committee approved reassigning the ZIGA issue to the LLWG.  The Liaison Report noted that it 
received feedback in June on ZIGA Tariff redlines and that it posted a feedback response.  For the 
July 16, 2026 LLWG meeting, MISO posted ZGIA redlines for stakeholders to review.  At the July 
27, 2026 LLWG, MISO focused on other large load issues, but it provided a preliminary filing 
timeframe that include the ZGIA filing.  MISO discussed ZGIA at the August 12, 2026 LLWG and 
provided updated Tariff redlines for stakeholders to review.  
V. 
DOCUMENTS SUBMITTED IN THIS FILING 
In addition to this Transmittal Letter, this submission includes: 
Tab A – Redline Tariff;94,95 
Tab B – Clean Tariff;  
Tab C – Prepared Direct Testimony of Marc Keyser; and 
Tab D – Redline ZGIA to pro forma GIA (for informational purposes. 
 
94  Language currently pending before the Commission in the following, unrelated dockets is highlighted in yellow: 
Docket Nos.  ER24-2046-003, ER26-2974-000, and ER26-3267-000.  MISO requests that the Commission treat 
such highlighted language as subject to the outcomes of those pending proceedings.  MISO commits to file any 
revisions to this highlighted language as necessary to comply with any Commission orders in those proceedings.  
In addition, MISO has not included language that has future effective dates of:  6/1/2027 in Docket No. ER26-
1882-001, 6/12/2028 in Docket No. ER26-2825-000, 6/1/2029 in Docket No. ER22-1640-003, 9/1/2027 in 
Docket No. ER26-2974-000, 9/1/2027 in Docket No. ER25-1886-002 and 12/31/9998 in Docket No. ER26-1915-
001.  If needed, MISO commits to file any revisions to comply with any Commission orders in these proceedings 
and MISO commits to make subsequent filings with the Commission to reflect the most up-to-date version of the 
then-current Tariff provisions prior to the effective dates of the language. 
95  In this filing, MISO reconciled both the GIP (GIP Version 187) and ZGIA (GIA Version 111) to reflect the most 
current tariff language, which now incorporates provisions filed in compliance with FERC Order Nos. 2023 and 
2023-A.  MISO requests that the Commission treat such pending language in Docket No. ER24-2406-003 as 
subject to the outcome of the pending proceeding.  Additionally, MISO commits to submit any necessary revisions 
to the pending language to comply with any Commission orders in the proceeding.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 47 
 
 
VI. 
EFFECTIVE DATE 
MISO requests an effective date of October 18, 2026 for the Tariff revisions submitted 
herein, which is not less than 60 days nor more than 120 days, after the filing date.  This effective 
date will allow the revisions proposed herein to be effective expeditiously for stakeholders 
currently seeking a process to facilitate the types of co-location arrangements that this filing 
enables.  
VII. 
COMMUNICATIONS 
MISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of 
Practice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the 
designation of more than two persons for service on behalf of MISO in this proceeding and requests 
all communications related to this filing be directed to: 
Christopher D. Supino 
Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
Midcontinent Independent System 
Operator, Inc. 
720 City Center Drive  
Carmel, Indiana 46032  
Telephone: (317) 249-5400 
csupino@misoenergy.org 
mkessler@misoenergy.org 
 
James C. Holsclaw 
Calfee, Halter & Griswold LLP 
3900 Salesforce Tower 
111 Monument Circle 
Indianapolis, Indiana 46204 
Telephone: (317) 308-4266 
jholsclaw@calfee.com  
 
VIII. 
NOTICE AND SERVICE 
MISO has served a copy of this filing electronically upon all parties listed on the 
Commission’s eService list, and upon all Tariff customers, MISO Members, Member 
representatives of Transmission Owners and non-Transmission Owners, as well as all state 
commissions within the MISO Region and the Organization of MISO States.  The filing has been 
posted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for 
other interested parties in this matter.

The Honorable Debbie-Anne Reese 
August 18, 2026 
Page 48 
 
 
 
IX. 
CONCLUSION 
For all of the foregoing reasons, MISO respectfully requests that the Commission accept 
this filing and grant waiver of any Commission regulations the Commission deems applicable, but 
not specifically addressed above in order for the Commission to accept it as proposed. 
Respectfully submitted, 
 
/s/ Christopher D. Supino 
Christopher D. Supino 
Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
Midcontinent Independent System 
Operator, Inc. 
720 City Center Drive  
Carmel, Indiana 46032  
Telephone: (317) 249-5400 
mkessler@misoenergy.org 
csupino@misoenergy.org 
 
James C. Holsclaw 
Calfee, Halter & Griswold LLP 
3900 Salesforce Tower 
111 Monument Circle 
Indianapolis, Indiana 46204 
Telephone: (317) 308-4266 
jholsclaw@calfee.com   
 
Attorneys for the Midcontinent Independent 
System Operator, Inc.