ER26-3552-000 · 2026-09-08 · Community Collaboration on Climate ChangeMichigan Environmental Justice CoalitionMidwest Tribal Energy Resources Association ,Sierra Club ,Natural Resources Defense Council ,Clean Grid Alliance ,

Protest of Community Collaboration on Climate Change, et al. re the Midcontinent Independent System Operator, Inc.’s filing proposing revisions to establish the Zero Injection Generator Interconnection Agreement

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
Midcontinent Independent System Operator, Inc. 
Docket No. ER26-3552-000 
 
 
 
PROTEST OF COMMUNITY ORGANIZATIONS AND  
CLEAN ENERGY ADVOCATES 
 
I. 
INTRODUCTION 
Community Organizations1 and Clean Energy Advocates2 and their respective members reside 
throughout the Midcontinent Independent System Operator Inc.’s (“MISO”) footprint.  They rely 
on MISO to provide affordable and reliable wholesale service to power many aspects of their lives, 
including their residences, businesses, hospitals, places of worship, and schools.  Their members 
also rely on MISO’s adherence to non-discriminatory practices that enable a diverse set of energy 
generation technologies, namely distributed energy resources, to provide low-cost energy options 
that will help lower their energy bills without increasing pollution in their communities.  
Additionally, one of Clean Energy Advocates is an organization including energy project 
developers that regularly use MISO’s interconnection services. 
 
1 Community Organizations are Community Collaboration on Climate Change and Michigan Environmental Justice 
Coalition, which are nonprofit organizations chartered under the laws of Michigan; and Midwest Tribal Energy 
Resources Association, a nonstock corporation chartered under the laws of Wisconsin. 
2 Clean Energy Advocates consist of Sierra Club and Natural Resources Defense Council, which are nonprofit 
environmental organizations with members throughout MISO territory; and Clean Grid Alliance, a nonprofit 
corporation chartered under the laws of Minnesota.

2 
On June 18, 2026, the Commission issued an order to show cause (“OSC” or “Show Cause 
Order”) to MISO and its transmission owners (“TOs”) directing them to either provide more 
options to fast track the grid interconnection of large load customers, which at the moment are 
primarily data centers, or explain why MISO’s tariff is sufficient.  MISO submitted its Zero 
Injection Generator Interconnection Agreement (“ZGIA”) proposal (the “Proposal”) to respond to 
the co-location requirements in the Commission’s OSC.3   Our organizations do not oppose the 
intended design of MISO’s ZGIA Proposal—a co-location arrangement that results in no injections 
or withdrawals of electrons to MISO’s transmission system and, therefore, does not require 
network upgrades nor cause negative impacts to the Definitive Planning Phase (“DPP”) process.  
Rather, we oppose the lack of processes and tariff provisions to make those design elements a 
reality.  
Without proper tariff provisions, this process could have the opposite of MISO’s intended 
effect by instead operationalizing ongoing cost shifts that will be difficult, if not impossible, for 
states to untangle, triggering otherwise preventable reliability shortalls, and allowing generators 
with ZGIA service (“ZG Resource”) to perpetually gain an unfair advantage over projects in DPP, 
frustrating the implementation of Order 2023’s queue reforms to the detriment of market 
participants and consumers, like our members.  As discussed below, we urge the Commission to 
direct MISO to address these tariff and procedural defects through either a deficiency letter or 
direct further compliance via the show cause proceeding.  
 
 
 
3 Midcontinent Indep. Sys. Op., Inc.’s Transmittal Letter for Zero Injection Generator Interconnection Agreement 
Filing, Docket No. ER26-3552-000 (Aug. 18, 2026), Accession No. 20260818-5152 (“MISO Transmittal” or 
“Transmittal Letter”).

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TABLE OF CONTENTS 
I. 
INTRODUCTION .................................................................................................................. 1 
II. 
ARGUMENT .......................................................................................................................... 3 
A. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators. .......................... 3 
1. ZG Generating Facilities that Make Unauthorized Injections Should Be Penalized. ...... 3 
2. ZGIA’s Requirement for System Protection Facilities is Poorly Defined. ...................... 9 
3. Length of the Transient Tolerance Window Should be Set According to Clear 
Standards. ....................................................................................................................... 12 
B. The Proposal Lacks Required Transparency...................................................................... 14 
C. The ZGIA Program’s Scope Should Have a Defined Limitation. ..................................... 16 
D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will Be Paid 
by Other than the Cost Causers. ........................................................................................ 18 
1. Overview of MISO’s Cost-Shifting Safeguards ............................................................ 19 
2. MISO’s Safeguards are Inadequate to Prevent Cost-Shifting of Network Upgrades to 
Interconnection Customers and Load. ........................................................................... 21 
E. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources. .............. 26 
F. 
Drafting Errors ................................................................................................................... 27 
1. Limitation on Injections ................................................................................................. 27 
2. Reference to Interconnection Study ............................................................................... 29 
III. 
CONCLUSION ................................................................................................................. 29 
 
 
II. 
ARGUMENT 
A. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators. 
1. 
ZG Generating Facilities that Make Unauthorized Injections Should Be 
Penalized.  
Zero injection is an extremely clear program design element in this Proposal,4 but MISO fails 
to ensure that zero means zero.  The Transmittal Letter, testimony, and proposed tariff language 
are silent about what happens when a ZG Generator exports power to the grid outside the Point of 
 
4 Transmittal Letter at 8 (MISO stating that the “new generator with ZGIA Interconnection Service cannot inject past 
the interconnecting substation…”); id at 13 (MISO stating that the “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.”

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Interconnection (“POI”) and the Transient Tolerance Window.  Yet the Commission clearly stated 
in the Show Cause Order that it is concerned with the lack of tariff provisions that “specify 
requirements for necessary control technologies and protections systems” needed to limit 
withdrawals consistent with study arrangements and related agreements.5  The Commission should 
require MISO to modify its ZGIA proposal to include robust operational penalties for ZGIA 
Generating Facilities that make unauthorized injections into the MISO transmission system 
notwithstanding the use of control technologies and/or protection systems.6  MISO cannot be silent 
on its enforcement procedures in light of the serious reliability risks to the grid that may arise if a 
ZGIA Generating Facility fails to limit its injections as promised. The Commission should require 
MISO to impose strict operational penalties to give ZG Generating Facilities adequate incentives 
to limit their injections as expected or risk termination of their transmission service if they fail to 
perform. 
i. Unauthorized injections are likely to increase reliability risks in MISO. 
Unauthorized injections on the transmission system can lead to increased reliability risks, 
making it imperative that generators are properly incentivized to follow zero-injection 
requirements.  MISO has acknowledged the reliability risks associated with large loads, including 
the risk associated with frequency and voltage instability, system balancing, and Area Control 
Error volatility.7 MISO’s Board previously made a commitment to address the operational risks 
associated with large loads, particularly with respect to ramping, adequacy, and stability.8  Yet, in 
 
5 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212, P 64 (2026). 
6 See generally, PJM Interconnection LLC, 193 FERC ¶ 61,217 at P 212 (2025) (“PJM Co-location Order”). 
7 Interconnection of Large Loads to the Interstate Transmission System, Comments of the Midcontinent Independent 
System Operator, Inc., Docket No. RM26-4-000, Accession No. 20251121-5472 at 30 (Nov. 21, 2025).  
8 Id. at 29, n.29.

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this filing, MISO fails to adequately address the severity of potential reliability issues that could 
be caused by unauthorized injections on the system.  
Recent grid fluctuation events illustrate the serious reliability risks that could result from 
unplanned injections on the system.  In July 2026, over three GW of data centers on the PJM grid 
suddenly disconnected, causing voltage and frequency fluctuations that could be detected from 
Virginia to Illinois.9  While operators can typically correct grid disturbances within milliseconds, 
this event took almost 10 minutes to stabilize.10  A similar event occurred two years prior, also in 
PJM, where 1.5 GW of data center load suddenly dropped in Northern Virginia, forcing operators 
to make emergency adjustments to prevent cascading outages.11  There is growing concern from 
the North American Electric Reliability Corporation (“NERC”) about the increased amount of 
customer initiated load reduction events as large, extended fluctuations can lead to cascading 
fluctuations and system blackouts.12  
The Commission should require MISO to impose strict operational penalties to prevent similar 
grid fluctuation events from occurring in MISO’s territory.  MISO anticipates that ZG Associated 
Loads may, at some point, suddenly decrease their load.13  The ZGIA proposal establishes a 
Transient Tolerance Window during which the ZGIA Generating Facility will ramp down to match 
 
9 Lee Shaver, Data Centers are Already Stressing the Grid. Regulators are Playing Catch-up, Union of Concerned 
Scientists (Aug. 6, 2026), https://blog.ucs.org/lee-shaver/data-centers-are-already-stressing-the-grid-regulators-are-
playing-catch-up.  
10 Tim McLaughlin, Massive Disconnect of Power Roils Largest US Electric Grid, Reuters (Jul. 22, 2026), 
https://www.reuters.com/business/energy/massive-disconnect-power-roiled-largest-us-electric-grid-2026-07-22.  
11 Rachel Mural, et. al, AI, Data Centers, and the U.S. Electric Grid: A Watershed Moment, Belfer Center for 
Science and International Affairs (Feb. 10, 2026), https://www.belfercenter.org/research-analysis/ai-data-centers-us-
electric-grid.  
12 NERC, Characteristics and Risks of Emerging Large Loads: Large Loads Task Force White Paper (July 2025), 
https://www.nerc.com/globalassets/who-we-are/standing-committees/rstc/whitepaper-characteristics-and-risks-of-
emerging-large-loads.pdf, at 21-36; NERC, Level 3 Alert: Computational Load Modeling, Studies, Instrumentation, 
Commissioning, Operations, Protection, and Control (May 4, 2026), 
https://www.nerc.com/globalassets/programs/bpsa/alerts/level-3-computational-load-alert.pdf, at 8.  
13 Transmittal Letter at 21.

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the reduced load level.14  MISO’s filing acknowledges that ZG Generating Facilities cannot 
instantaneously ramp down to meet the associated load loss, which presents increased risks of grid 
fluctuations as ZGIA arrangements attempt to stabilize.  If multiple ZG Generating Facilities fail 
to ramp down as expected, either by choice or by misoperation of control technology, the MISO 
grid could experience cascading fluctuations across its system. As demonstrated in PJM, as more 
GWs of load drop from the system, fluctuations are harder to manage.  If MISO anticipates that 
large loads will use the ZGIA service to connect to the grid, it must ensure that ZG Generating 
Facilities will limit their injections when necessary.  The control equipment and management 
measures contemplated in the Proposal, even if optimally chosen,15 are not sufficient. 
ii. Strong Operational Penalties Are Needed to Ensure That ZG Resources 
Will Not Make Unauthorized Injections That Could Lead to Greater 
Reliability Risks. 
The Commission must require MISO to implement strong penalties to prevent ZG Resources 
from making unauthorized injections into MISO’s transmission system above their authorized 
level of service (namely, zero), consistent with the Commission’s prior finding that transmission 
customers should be subject to penalties for unreserved use of the transmission system.16  Absent 
such penalties, the Proposal cannot be found just and reasonable. 
MISO’s ZGIA proposal fails to discuss any penalties to be levied on ZGIA Generating 
Facilities that violate the rule against unauthorized injections outside the Transient Tolerance 
Window.17  Similarly, MISO’s proposal states that the ZG Interconnection Service Study must 
 
14 Id.  
15 As discussed infra in section II.A.2, MISO has not optimally or adequately structured its requirements for control 
equipment and measures. 
16  PJM Co-location Order at P 212 (2025) (directing PJM to brief appropriate penalty charges for transmission 
customers’ unreserved use of the PJM transmission system).  
17 Transmittal Letter at 43.

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confirm that a generator’s proposed equipment can sufficiently limit injections, but is silent as to 
any consequences if the equipment malfunctions and allows the generator to inject into the 
transmission system outside the Transient Tolerance Window.18 
The Proposal contains no specific penalty schedule or mandatory reporting of injection events 
and control failures.  There seems to be no consequence for an unauthorized injection—no charge, 
curtailment, suspension, mandatory retesting, or graduated penalty.  This lackadaisical approach 
to enforcement is inconsistent with the serious reliability risks that would occur if ZG Generating 
Facilities made unauthorized injections into the system.  When faced with potential consequences 
as serious as widespread outages, MISO must implement operational penalties that are just as 
serious. 
The Commission has already found that operational and financial penalties are just and 
reasonable to ensure that customers follow curtailment directives, especially where there are 
significant reliability risks if customers fail to curtail.19  In its recent proceeding on co-location 
arrangements in PJM, the Commission directed PJM to establish an appropriate penalty charge 
and “any other remedial action” that PJM should take to address a customer’s unreserved use of 
the transmission system or excess energy withdrawals.20   PJM established three separate penalties 
that escalated in severity based on the potential harm to the transmission system—a pause in 
service, disqualification, and financial penalties—where customers rely on control technologies 
that fail more than once, fail to follow Load Shedding and Curtailment directives, or make 
 
18 Transmittal Letter at 13, 14.  
19 PJM Interconnection, L.L.C., Order on Rehearing, Clarification, Compliance Filing, and Paper Hearing, 195 
FERC ¶ 61,209, at P 515 (2026) (“PJM Co-Location Rehearing Order”). 
20 PJM Co-location Order at P 212.

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unreserved use of the transmission system.21  The Commission found that it was just and 
reasonable to establish these operational penalties because (1) PJM’s new services for co-location 
arrangements were designed for Eligible Customers that are willing and able to limit their 
withdrawals from the transmission system; and (2) there are significant reliability risks if Eligible 
Customers fail to curtail.22   
Similarly, MISO’s ZGIA proposal is designed on the assumption that ZGIA Generation 
Facilities can and will limit their injections on the system and that (like in PJM), there are serious 
reliability risks if ZGIA Generating Facilities fail to limit their injections when directed to. MISO’s 
proposal states that “[t]he premise of ZG Interconnection Service is that injections beyond the 
interconnecting substation can be limited.”23  ZG Generating Facilities, and their ZG Associated 
Loads, would be allowed to interconnect quickly on the assumption that they will adhere to strict 
limitations on injections.24  Under the proposed ZG Interconnection Agreement, a Generating 
Facility taking ZG Interconnection Service agrees to the requirements to install equipment to 
reduce its injections at times when the ZG Associated Load reduces its demand and to cease all 
injections onto the transmission system when necessary.25  Allowing ZGIA Generating Facilities 
to connect quickly through ZGIA on the basis that they will limit their injections, but not enforcing 
any penalties against them when they fail to limit those injections would, as PJM said with respect 
to its co-location penalties filing, “implicitly bless such dangerous behavior.”26  
 
21 Initial Brief of PJM Interconnection, L.L.C., Docket No. EL25-49-000, at 50 (Feb. 23, 2026), Accession No. 
20260223-5189 (“PJM Initial Brief”). 
22 PJM Co-Location Rehearing Order at P 515. 
23 Transmittal Letter at 42.  
24 Transmittal Letter at 7.  
25 Proposed Att. X, App’x 19, § 9.7.4.7.  
26 PJM Initial Brief at 42.

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MISO should terminate or pause a ZG Generating Facility’s ability to use the transmission 
system if the generator fails to stay true to its promise to limit its injections.  Otherwise, ZGIA 
Generating Facilities would receive the benefits of connecting to the grid quickly without 
providing a commensurate benefit to the grid, and at worst, would risk endangering the stability 
of the transmission system.  The failure of a ZG Generating Facility to limit its injections could 
cause reliability risks similar to those contemplated in PJM’s Co-Location docket, including a 
higher risk of widespread outages across the bulk power system.27  In order to ensure that the 
severe risks of failing to limit injections are weighed equally to the benefits that ZGIA Generation 
Facilities receive from the ZG Interconnection Service, the Commission should require MISO to 
impose operational penalties on Generating Facilities that fail to limit their injections as directed. 
2. 
ZGIA’s Requirement for System Protection Facilities is Poorly Defined. 
Next, MISO falls short in its unnecessarily weak standard for System Protection Facilities that 
will ensure zero injection.  The applicant ZG Generating Facility is required to identify “any 
proposed system protection facilities”28 in its Interconnection Request.  Although not capitalized 
in that passage, System Protection Facilities is an existing defined term meaning, as relevant, 
“equipment [] required to protect [] the Transmission System or other delivery systems or other 
generating systems from faults or other electrical disturbances occurring at the Generating 
Facility.”29  It is apparent from the filing that “System Protection Facilities” (or system protection 
facilities) in this context is intended to “control injection onto the rest of the Transmission 
 
27 NERC, Characteristics and Risks of Emerging Large Loads: Large Loads Task Force White Paper, supra note 12, 
at 20.  
28 Proposed Att. X § 3.11(ii); Att. X, App’x 1 § 10 and Att. A-5. 
29 Att. X § 1 (definition of System Protection Facilities).

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System,”30 although that is not codified in the proposed tariff.  Following the Interconnection 
Request, the proposed ZG Facilities Study is to identify “any required system protection facilities 
and equipment,”31 with such facilities memorialized in the ZG Interconnection Agreement.32 
MISO’s proposal falls short of what is needed to ensure that zero means zero by missing any 
minimum configuration of System Protection Facilities necessary to block unauthorized power 
injections to the grid beyond the POI.  Outside the proposed tariff, MISO narrates its intentions: 
“MISO anticipates reviewing a variety of configurations, physical equipment, and 
operational requirements that may independently, or in sum, prevent injections on 
the Transmission System beyond the substation where the Point of Interconnection 
is located. For example, the injection limitation may be implemented through 
equipment controls such as export-limiting controls, directional relays, interlocks, 
and fail-safe trip logic. Operational requirements may include generation limits, 
curtailment obligations, outage coordination, and restrictions on operation. These 
operational requirements are in addition to any monitoring, testing, or maintenance 
requirements.”33 
 
The lack of clarity with this choose-your-own-adventure configuration approach is precisely 
why the Commission directed transmission providers to submit tariff proposals or explain why 
they are not needed.34  No export-limiting control device (nor control over such device) is 
required anywhere in the proposed tariff. MISO proposes to give itself discretion to judge 
whether the “proposed control equipment and/or operating procedures […] are sufficient to 
prevent injections”35 (emphasis added), suggesting that a protocol for manual intervention alone 
 
30 Transmittal Letter at 28; see also proposed Att. X, App’x 19 § 9.7.4.7 (requiring the ZG Generating Facility to 
“install equipment” required to comply with the zero-injection requirement outside the Transient Tolerance Window. 
31 Proposed Att. X. § 3.2.5.2.2. 
32 Proposed Att. X, App’x 19, App’x A §§ 2, 5. 
33 Keyser Test. at 33; see also proposed Att. X § 3.2.5.2.1 
34 See generally, Show Cause Order at P 21 (cautioning against stand-alone study agreements); id at P 49 (requiring 
a degree of clarity and specificity in the tariff regarding studies for customers to avoid a variety of issues including 
disputes regarding how studies are conducted). 
35 Proposed Att. X § 3.2.5.2.1.

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by the ZG Generating Facility’s operator might be acceptable to MISO.  The Commission in the 
Show Cause Order called for MISO to develop generator interconnection service that reflects “a 
generating facility with necessary control technologies and/or protection systems, which may 
include a special protection scheme, that ensure that the injection does not exceed the limit in the 
[…] interconnection agreement.”36  “Special protection scheme” was defined there as in the PJM 
Co-Location Rehearing Order,37 which in turn referenced the PJM Co-Location Order: “a plan 
designed to detect abnormal system conditions and to automatically take appropriate corrective 
action, to maintain system stability, acceptable system voltages, and acceptable facility 
loading”38 (emphasis added). But, defying the Commission’s directives, MISO here proposes no 
requirement for automatic corrective action. 
Additionally, the Proposal fails to be just and reasonable in missing any specific requirements 
for testing the protective measures.  The ZG Interconnection Agreement gives MISO a “right to 
inspect” the ZG Generating Facility’s “System Protection Facilities and other protective 
equipment,” including looking at tests, inspections, settings, and maintenance records, but sets 
no requirement for MISO to do so at any particular interval.39  Similarly, the agreement requires 
the ZG Generating Facility to test its System Protection Facilities “[a]t intervals suggested by 
Good Utility Practice” but does not set any interval or require MISO to verify the testing.40  This 
stands in contrast to, for example, the clear requirement for a ZG Generating Facility’s metering 
equipment to be testified at least biennially.41 
 
36 Show Cause Order at P 113. 
37 PJM Co-Location Rehearing Order at P 480. 
38 PJM Co-Location Order at P 204. 
39 Proposed Att. X, App’x 19 § 6.4. 
40 Id. §§ 9.7.4.5, 9.7.4.6. 
41 Proposed Att. X, App’x 19 § 7.4.

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3. 
Length of the Transient Tolerance Window Should be Set According to 
Clear Standards. 
A third infirmity in ensuring that zero means zero is how MISO proposes to set the “Transient 
Tolerance Window,” which is “the period of time after a reduction or loss of load by the ZG 
Associated Load by the end of which window the [ZG] Generating Facility must have” ceased 
injections to the grid.42  In other words, this time span, defined as no more than 20 seconds,43 is 
the time for a ZG Generating Facility to ramp down production as needed when its co-located load 
drops.  This time window is a fundamental engineering parameter of ZGIA service, but MISO has 
not justified why a maximum period of 20 seconds is either operationally attainable by a generator 
(or if a greater or lesser time window would be more appropriate), or operationally acceptable for 
the transmission grid to remain stably within reliability criteria while receiving unexpected 
injections over that time interval. 
MISO states that it “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”;44 and MISO’s witness Keyser opines that 20 seconds 
was chosen “in order to align with the MTEP modeling interval of 20 seconds for transient stability 
analysis.”45  The physical or even customary basis of 20 seconds remains obscure, as this figure is 
mentioned neither in the existing Attachment FF (Transmission Expansion Planning Protocol) nor 
in Business Practices Manual 20 (Transmission Planning).  MISO should better justify the specific 
time interval chosen with reference to NERC standards, local planning criteria, or some other 
grounding in electrical engineering realities. 
 
42 Proposed Att. X § 1; proposed Att. X, App’x 19, Art. 1 (proposed definition of Transient Tolerance Window). 
43 Id. 
44 Transmittal Letter at 21-22. 
45 Keyser Test. at 25:20-22

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An additional deficiency with MISO’s definition of Transient Tolerance Window is its 
allowance that 20 seconds would be the maximum period allowed, while the time period could be 
“further described by the Business Practices Manual for Large Load.”46  MISO gives more color 
its intentions in its filing letter, offering 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 (“BPM”) rules that narrow the window based on specific circumstances[.]”47  A tariff that 
remained silent about all the standards and intentions in the prior quotation while reserving 
authority for MISO to make discretionary changes outside the Commission’s oversight would 
violate the Rule of Reason, which requires that provisions that (1) significantly affect rates, terms, 
and conditions of service, (2) are realistically susceptible of specification, and are (3) not generally 
understood in a contractual agreement must be included in the tariff.48  While the D.C. Circuit has 
recently recognized that “even specifiable practices that significantly affect rates need not be 
included if they are clearly implied by the tariff’s express terms,”49 the proposed tariff’s passing 
reference to the BPM hardly implies anything as to how MISO will consider varying the 20-second 
rule. 
As a policy matter, users of ZGIA service, not to mention regulators and stakeholders, will 
want to develop reasonable expectations about how the 20-second interval for unauthorized 
injections might evolve; but the placement of untariffed policies in the Business Practices Manual 
 
46 Proposed Att. X § 1. 
47 Transmittal Letter at 21. 
48 City of Cleveland v. FERC, 773 F.2d 1368, 1376 (D.C. Cir. 1985). 
49 Hecate Energy Greene Cnty. 3 LLC v. FERC, 72 F.4th 1307, 1314 (D.C. Cir. 2023)

14 
will complicate that.  A Transient Tolerance Window that MISO can adjust by standardless fiat 
hardly supports orderly market development. 
B. The Proposal Lacks Required Transparency. 
The Commission found in the Show Cause Order that MISO must provide “cost transparency 
measures […] to provide stakeholders with sufficient information and visibility regarding the 
Network Upgrades, and their associated costs, needed to provide transmission service to Eligible 
Customers on behalf of large loads.”50  The Commission further found that MISO’s tariff is not 
just and reasonable to the extent “it does not require the provision of data on MISO’s website in a 
single location, and in an easily accessible format that is searchable and allows users to filter the 
data, that identifies the Network Upgrades that are needed to accommodate requests for 
transmission service by Eligible Customers on behalf of large loads, and the costs of those Network 
Upgrades.”51  Despite this clear command from the Commission for transparency of large load52-
induced costs, and MISO’s stated attempt to respond to the Show Cause Order, MISO has fallen 
well short of the Order’s clear requirements on transparency.  It is simply not correct that the 
“ZGIA proposal is well aligned with the Commission’s goals and objectives of transparency,” as 
MISO avers.53  
 
50 Show Cause Order at P 71. 
51 Id. P 77. 
52 Although the ZGIA proposal is not restricted to serving only large loads, it is reasonable to expect that large loads 
will be a significant share of the end-use customers benefiting from the program. “MISO notes that this description 
[generally outlining ZGIA] explains how ZGIA will serve large loads”; “The ZGIA proposal represents another 
critical tool to help support the timely, reliable, cost-effective integration of new large loads into the MISO system”; 
“the ZGIA is particularly responsive to the needs of a large load[.]” Transmittal Letter at 8 n.33, 9, 11. 
53 Transmittal Letter at 5.

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MISO is  aware of how to design an interconnection program with deliberate transparency, as 
the Commission found last year.54  Yet, no provision within the ZGIA proposal requires MISO to 
post ZGIA study reports, required Network Upgrades identified or deferred, or affected-system 
results.  No provision requires the publication of costs of such upgrades, once known. Without the 
underlying studies and upgrade information, stakeholders and regulators may be unable to quantify 
incremental costs attributable to an expedited project or evaluate whether later MTEP upgrades 
result from assumptions made in the ZGIA process.  The existing generator interconnection tariff 
includes various precedents55 for required publication of data, and there is no reason why MISO 
could not post vital information on Network Upgrades. 
MISO may rest on its requirement that a ZG Generating Facility can qualify for ZG 
Interconnection Service only if the ZG Impact Assessment and ZG Facilities Study find that the 
proposed interconnection “[w]ill not require the construction or modification of any Network 
Upgrades to address impacts to the Transmission System with the exception of Network Upgrades 
located at the same substation as the POI, except for System Protection Facilities at adjacent 
substations.”56  However, to the extent the ZG Generating Facility is owned by a vertically 
integrated, state-regulated utility, the costs of Network Upgrades, even if borne by the generator’s 
utility owner, may be allocated in indeterminate ways at the retail level.  The ZG studies may also 
identify foregone Network Upgrades that would have been required to interconnect the generator 
absent the ZG Associated Load, or Network Upgrades that would have been required to 
accommodate the new load absent the ZG Generating Facility.  It will be important to track these 
 
54 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064, at P 197 (noting “MISO’s commitment to 
publicly post detailed information about each ERAS interconnection request and its corresponding type of load 
served”). 
55 Att. X §§ 3.3.4, 3.4.2.1 – 3.4.2.6. 
56 Proposed Att. X § 3.2.5.1(2); also see §§ 3.2.5.2.1, 3.2.5.2.2, 3.11(iii).

16 
foregone upgrades should either the ZG Associated Load or ZG Generating Facility depart the co-
located arrangement in the future, putting upgrade costs back on the table.  Overall, the Proposal 
falls well short of the necessary transparency urged by the Commission. 
C. The ZGIA Program’s Scope Should Have a Defined Limitation. 
The Commission’s two orders last year on the ERAS fast-track interconnection program 
emphasized the Commission’s longstanding policy on open access to the transmission system and 
requirement to limit the scope of departures therefrom.  The first ERAS order denied MISO’s 
initial proposal as not just and reasonable, in part because it lacked a program size cap (in either 
project counts or project megawatts).57  The Commission also found that the proposed program 
end date of December 2028, allowing for three and a half years’ worth of project selections, would 
“exacerbate[] the potential for a volume of ERAS interconnection requests untethered to reliability 
or resource adequacy needs” and would “make[] it difficult to determine […] whether the solution 
is narrowly tailored to fix the problem.”58  MISO altered the time limit on its ERAS proposal when 
it re-filed, setting August 2027 (two years after program commencement) as the sunset date, and 
capping the size of the program at 68 total projects.  The Commission credited these limitations in 
ultimately approving the second ERAS proposal, finding that “the limited, one-time design of the 
[proposed ERAS] process weighed significantly on our decision here.”59 
Despite this precedent, MISO now comes to the Commission with a new fast-track 
interconnection pathway that is similar to the one it rejected.  The program has a structure of 10 
applications processed per quarter,60 but otherwise no limit on the long-term availability of the 
 
57 Midcontinent Independent System Operator, Inc., 191 FERC ¶ 61,131, at PP 199-201. 
58 Id. at P 199. 
59 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064, at PP 84, 195, 203, 265. 
60 Proposed Att. X § 3.11.2.

17 
program for new applicants, the total project number,61 or the total megawatts of capacity.  MISO 
calls it “fundamentally a limited product”62 but offers no limitations on the scope of the program.  
Witness Keyser explains in testimony why ZGIA service is proposed as a “permanent product” for 
a given participating generating plant but ignores why MISO is not capping the number or size of 
participating projects, or the overall lifespan of the program.  This mirrors MISO’s approach to 
stakeholder feedback earlier this year.  While acknowledging stakeholders’ “[r]equests to ensure 
ZGIA is a transitional construct and does not replace the standard GIA process,” MISO wholly 
ignored the point in its response to related comments: 
63 
To achieve the narrow tailoring required by the Commission’s open access precedents, a 
program that bypasses the traditional interconnection queue must have some limitation on how 
large it could get.  Such limitation would be consistent with, for example, the Commission’s 
approval earlier this year of Southwest Power Pool’s HILLGA (“High-Impact Large Load 
Generation Assessment”) interconnection program, which limits the HILLGA service for any 
 
61 MISO expressly acknowledged this point at a stakeholder meeting earlier this year: “there is no limitation on the 
number of ZGIA requests[.]” Minutes of April 22, 2026 Planning Advisory Committee meeting, 
https://cdn.misoenergy.org/20260527%20PAC%20Item%2001c%20Minutes%2020260422754915.pdf, at 6. 
62 Transmittal Letter at 12. 
63 MISO, Consideration of Zero-Injection GIA (Interconnection and Planning Draft Tariff Updates), Presentation to 
Planning Advisory Committee (April 22, 2026), 
https://cdn.misoenergy.org/20260422%20PAC%20Item%2006%20Consideration%20of%20Zero-
Injection%20GIA%20%20(PAC-2024-4)752672.pdf, at 23.

18 
given generator to five years.64  For MISO ZGIA, a pilot program, for example, with a defined 
time limit of availability for new applicants or a defined time limit for each given interconnection 
agreement, followed by Commission review for renewal, could allow the Commission to consider 
whether continued derogation from open access should continue.  Absent those guardrails, ZGIA 
is not just and reasonable.   
D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will 
Be Paid by Other than the Cost Causers. 
MISO’s ZGIA proposal includes two primary mechanisms that together are designed to prevent 
cost-shifting from ZGIA projects to other interconnection customers or load. These mechanisms 
involve: 1) a requirement that, in order to qualify for ZG Interconnection Service to begin with, 
the ZG Generating Facility will not require additional large-scale network upgrades, and 2) that 
MISO can credit the ZG Generating Facility as a “Non-Transmission Alternative” as a result of 
signing five-year commitments with ZGIA load.  However, as further described below, those 
protective measures do not sufficiently insulate Network Upgrade costs from instances when some 
or all the ZG Associated Load is not placed in service.  
Specifically, as discussed in section II.D.2 below, there are at least three principal flaws with 
the Proposal that can result in cost-shifting: 1) the five-year commitment is insufficiently concrete 
to provide the requisite certainty that the load integration study and its assumptions regarding 
needed upgrades are accurate; 2) the structure of the Proposal creates a fast-track ZGIA to GIA 
process whereby ZG Generating Facility could later convert to ERIS or NRIS service and thereby 
 
64 The HILLGA program requires an applicant generator to be within two substations of the large load it serves, such 
that the generator will be “injecting within the local area of the [large load]” similar to the MISO ZGIA Proposal.  
Southwest Power Pool, Inc., 194 FERC ¶ 61,031 (Jan. 14, 2026) at PP 25, 28, 33.

19 
skip ahead of the normal interconnection queue while also potentially avoiding network upgrades; 
and 3) the mismatch in the timing of the various study cycles can result in further cost-shifts. 
1. 
Overview of MISO’s Cost-Shifting Safeguards 
The first mechanism in the Proposal is a condition of obtaining ZG Interconnection Service 
which states that a ZG Generating Facility is eligible for the service only if it does not require 
construction or modification of large-scale Network Upgrades, except for same-substation 
upgrades and certain System Protection Facilities.65  The analysis for this determination is 
performed through the ZG Impact Assessment, which is a screening process used to examine 
whether the project is eligible for ZG Interconnection Service.66  Pursuant to this assessment, the 
proposed tariff states that a project must “not require the construction or modification of any 
Network Upgrades to address impacts to the Transmission System with the exception of Network 
Upgrades located at the same substation as the POI, except for System Protection Facilities at 
adjacent substations.”67  
In other words, the ZG Impact Assessment must find that no broader transmission upgrades 
are needed, reliability can be maintained without Network Upgrades beyond the interconnection 
substation, and only same-substation upgrades or protection facility upgrades may be required.68  
If broader transmission upgrades are needed for the proposed project, it will not qualify for the ZG 
 
65 See Transmittal Letter at 13. 
66 Id. at 28. 
67 See Proposed Att. X, Generator Interconnection Procedures, Section 3.2.5.1(2); see also id. at 3.2.5.2.1 (“For ZG 
Interconnection Service to be granted, these analyses must determine that no Network Upgrades are needed to 
maintain system reliability other than Network Upgrades at the same substation as the Point of Interconnection or 
System Protection Facilities.” 
68 See Transmittal Letter at 28.

20 
Interconnection Service.69  If it does qualify, the interconnection customer then generally bears 
those costs of those limited upgrades, if any. 
The second mechanism involves the way in which MISO can credit a ZG Generating Facility 
as a “Non-Transmission Alternative” under the proposal and defer upgrades that would otherwise 
be needed to serve the ZG Associated Load.70  Attachment FF describes the “process of studying 
the Network Upgrades needs to integrate new loads onto the Transmission System,” which 
includes an the “capability of [ZG Resources] to offset the need for Network Upgrades.71 The 
proposal also requires “(1) an executed [five-year] agreement72 between the entity with the ZG 
Associated Load and the [ZGIA] Generating Facility […] and (2) that 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.”73 “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 
 
69 Id. 
70 See Keyser Test. at 19. 
71 Id. 
72 Transmittal Letter at 32-33 (“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. 
[…] The language of the agreement requirement is based on, and largely identical to, the requirements applicable to 
ERAS Interconnection Requests with several differences[:] […] 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 […] [but] MISO [] only requires that the agreement specify an intent [emphasis in original] to use the full 
output of the Generating Facility for at least five years rather than a firm commitment”); see also proposed Att. X § 
3.11(vii). 
73 Att. FF § I.D.1.b (as proposed for amendment).

21 
Provider may require the applicable Load Serving Entity to delay the in-service date of ZG 
Associated Load until such time as an alternative solution can be placed in service.”74 
2. 
MISO’s Safeguards are Inadequate to Prevent Cost-Shifting of Network 
Upgrades to Interconnection Customers and Load. 
The safeguards described above were, in several different ways, inadequately designed to 
prevent cost shifts of Network Upgrades being socialized to non-ZGIA load.  MISO’s proposal is 
unjust and unreasonable until such time that it closes the gaping holes in its proposal that are 
particularly vulnerable to gaming and undue cost shifting. 
i. 
The proposed five-year commitment requirement does not provide 
certainty that the load integration study and its assumptions regarding 
needed upgrades are accurate 
 
First, for new ZG Associated Load, the Proposal does not require adequate financial security, 
cost-recovery agreements, or true-ups for the cost of deferred transmission upgrades if the ZG 
Generating Facility fails to materialize, retires early, or becomes permanently unavailable.  For 
example, if the ZG Generating Facility or its contractual arrangement terminates, and a deferred 
upgrade is identified and becomes necessary through a later MTEP cycle, MISO’s proposal would 
not specifically have those costs assigned to either the ZG Generating Facility or to the associated 
LSE.  Therefore, the upgrade[s] would likely be allocated under ordinary MTEP rules and spread 
to other transmission customers.  MISO itself acknowledges that such reconciliation occurs after-
the-fact: “Any transmission issues identified by reconciling the cases will thus be addressed 
through the existing MTEP process.”75 The ZGIA’s contingent facilities are fixed at execution, and 
 
74 Id. 
75 Transmittal Letter at 15.

22 
the filed ZGIA provides no apparent mechanism for adding cost responsibility later to the 
appropriate ZGIA project.76 
Relatedly, the five-year commitment requirement is insufficient to protect against this cost-
shift pathway.  Here, MISO made a deliberate choice. as described in its submission, to 
accommodate “commercial considerations” at the expense of ensuring just and reasonable rates, 
by “only requir[ing] 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.”77  Specifically, MISO justifies this 
choice by speculating about the “difficult[y]” of “Interconnection Customers and ZG Associated 
Loads to agree to a firm minimum term of at least five years.”78  Beyond this bald statement, MISO 
provides no evidentiary basis for choosing this inadequate formulation and therefore is arbitrary. 
Where MISO allows MTEP to rely on a ZG Generating Facility as a Non-Transmission 
Alternative, but later identifies a needed reliability upgrade under a ZG Resource outage 
contingency, the Proposal does not clearly specify whether that upgrade is treated as a load-driven 
cost of the ZG arrangement or as a generally socialized reliability project.  MISO has stated that 
“Generator outages are accounted for in the MTEP process as P11 or P31 planning events used in 
the MTEP Reliability Analysis. ZGIA generator outages will be accounted for in this manner.”79  
Therefore, to the extent a later MTEP review identifies that a ZGIA generator outage necessitates 
Network Upgrades, there is nothing in the proposal to expressly prevent those upgrades being 
assigned through the normal MTEP process. 
 
76 See proposed Att. X, App’x 19 at passim. 
77 Transmittal Letter at 33 (emphasis original). 
78 Id. 
79 See MISO Response to Feedback, ZGIA Proposal Framework (PAC-2024-4) (April 15, 2026): available at 
https://cdn.misoenergy.org/PAC%20ZGIA%20Proposal%20Framework%20(PAC-2024-
4)%20Feedback%20Response%20(20260225)751481.pdf, slide 3.

23 
Moreover, MISO’s compromised position belies an irreconcilable tension in its filing.  MISO 
states that “[i]n order to ensure that the load integration study is an accurate representation of future 
conditions, there must be certainty that the Non-Transmission Alternative becomes operational 
and remains operational.”80  However, here there is no such certainty, as the contracts merely 
require a statement regarding contractual expectations and intent.  This weak construct has the 
effect of undermining the accuracy and reliability of the assumptions and outputs of the ZG load 
integration study.  MISO should instead study each arrangement both with and without the ZG 
Generating Facility, identify every upgrade deferred in reliance on that resource, and require 
financial security or a cost-responsibility agreement covering nonperformance.  The proposed five-
year “intended” commercial arrangement is not a reasonable basis for deferring transmission 
facilities with much longer planning lives. 
ii. 
The structure of the proposal distorts the normal interconnection 
queue process by providing a fast-track to ZGIA Generating Facilities 
that later convert to ERIS or NRIS service 
 
Next, the structure of the proposal also provides a fast-track pathway for ZGIA resources to 
connect to the gird while also allowing them to avoid needed network upgrades if they later convert 
to ERIS or NRIS service.  In other words, not only can the ZGIA resource energize faster as 
compared to resources in the traditional DPP queue, the ZGIA resource can also avoid the network 
upgrades they would otherwise be responsible for.  This structure presents serious gaming 
opportunities for ZG Resources seeking to energize quickly. 
As described in the filing: “[a]n Interconnection Customer with ZG Interconnection Service is 
free to submit an Interconnection Request into MISO’s queue for ERIS and/or NRIS.  Once the 
Interconnection Customer completes studies and obtains ERIS or NRIS for its ZG Resource, this 
 
80 Keyser Test. at 19 (emphasis added).

24 
automatically would supersede any ZG Interconnection Service that such ZG Resource has and 
the parties would replace or amend the ZGIA with a GIA reflecting the new service levels.”81  
Witness Keyser further states, “[i]f [a] project meets the eligibility requirements to enter the ZGIA 
interconnection process, DPP projects in active DPP cycles at or before Decision Point 2 may 
transfer to the ZGIA process.”82  Therefore, if the ZG Associated Load disappears, which is a 
material possibility based on the weak contractual requirements,83 the ZG Generating Facility will 
have skipped interconnection queue line as it can then apply for NRIS/ERIS, while also possibly 
avoiding the Network Upgrades that it may have otherwise been assigned had it completed the 
DPP interconnection process in the first instance.  This structure creates a fast-track ZGIA to GIA 
process where ZG Resources could use the ZG Interconnection Service to get ahead of DPP 
resources.  MISO’s proposal includes no safeguards applicable to the ZG Generating Facilities in 
the form of weighted escrow, securities, or other mechanism to protect against this opportunity for 
gaming and cost-shifting. 
iii. 
MISO’s proposal will result in further cost shifts as a result of  
mismatched study cycle timing 
 
 
Lastly, a study timing mismatch yields yet another opportunity for undue cost-shifting, as 
some deferred upgrades, like missed cumulative fault-duty and other reliability effects,84 that show 
up in MTEP but not the ZGIA study cycle may be charged to load more generally.  An energized 
generator contributes fault current even when it is not exporting real power, which is why the Tariff 
permits, among other things, System Protection Facilities at adjacent substations as the sole extra-
 
81 Id. at 15-16. 
82 Id. at 29. 
83 As describe above, the ZG Associated Load is required to have only an agreement evincing an “intent” to take the 
ZG Generating Facility’s power for five years.  
84 Such as protection coordination, voltage performance, and dynamic stability.

25 
substation upgrade.  However, the system impacts of these effects may be lost because of the timing 
of ZGIA and DPP studies. 
MISO plans to include all interconnection requests with an approved GIA in the base case for 
each ZGIA cycle, but not to the base case for DPP cycles if the DPP studies are ongoing.85  Once 
the DPP cycle is finished, the output from the cycle and the completed ZGIA and the MTEP’s 
Expedited Review Projects will be included in the new MTEP base case.86  MISO plans to 
reconcile any differences caused by the different study assumptions in the ZGIA and the DPP 
through the MTEP process.  The next DPP cycle will then use the latest MTEP base case.87  
However, waiting until the MTEP process to reconcile differences between the ZGIA and DPP 
study assumptions means that the Network Upgrades potentially caused by ZG Resources, but not 
identified until the MTEP process, will be spread to load in MISO through either its regional or 
subregional cost allocation processes.  Unlike in the generator interconnection process, where 
generators pay for Network Upgrades, in the MTEP, Network Upgrade costs are generally 
allocated across load.88  As a result, any transmission upgrades that are not identified in the ZGIA 
and DPP process will be identified in the MTEP process and will be paid for by load.  
In other words, successive ZGIAs do “see” one another because MISO adds each GIA 
approved since the last base case to the following ZGIA cycle.  The gap therefore runs between 
ZG Resources and pending DPP requests in both directions: the DPP base case is likewise frozen 
at kickoff and not updated for ZGIAs approved mid-cycle.  Projects in each track may therefore 
be studied against models that omit the other.  MISO has not adequately explained how their 
 
85 Transmittal Letter at 15. 
86 Id. 
87 Id. 
88 Att. FF § III.A.2.

26 
cumulative short-circuit, protection, voltage, and stability effects will be reconciled before 
approvals become final.  That gap could cause upgrades to be identified later through MTEP, 
without a corresponding ZGIA cost true-up.  The Tariff should identify the required base case; 
require cumulative modeling of prior ZGIAs and relevant pending projects such as projects in DPP 
Phase 2; establish minimum short-circuit, protection, steady-state, and stability analyses; and 
provide clear restudy and cost-allocation rules.  The current provision making thermal and voltage 
analysis discretionary “if necessary” is too open-ended.  Ultimately, this means that residential 
ratepayers and small industrial customers may end up paying for upgrades caused by these 
resources and their associated loads. 
E. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources. 
The Proposal allows for Hybrid Resources to apply for ZG Interconnection Service.89  
However, there are two distinct problems in the Proposal that may hinder Hybrid Resources from 
fully participating on a level playing field with other types of resources.  First, the Proposal sets 
the capacity accreditation of a ZG Generating Facility that is a Hybrid Resource based in part on 
a cap at “the level of firm interconnection service.”90  As ZG Interconnection Service may be 
interpreted as not “firm,” Hybrid Resources in the ZGIA program could receive capacity 
accreditation of zero without clarification.   
Second, the Proposal is silent as to important dimensions of how the battery storage component 
of a Hybrid Resource will be treated within the ZGIA construct.  MISO has stated elsewhere that 
 
89 Under the Proposal, “[a] ZG Resource may participate as a Generation Resource, Dispatchable Intermittent 
Resource, Electric Storage Resource, or Behind the Meter Generation resource”; while Hybrid Resources are 
already defined as a type of Generation Resource.  Proposed Module A § 1 (proposed definition of Zero Injection 
Generation (ZG) Resource); Module A § 1 (definition of Hybrid Resource).  
90 Proposed Module E-1 § 69A.4.1(i); Module E-1 § 69A.4.1(f).

27 
a storage unit’s charging activity will be considered in the DPP interconnection study,91 but MISO’s 
Proposal leaves unclear how, for a Hybrid Resource within ZGIA, the constituent storage unit’s 
charging behavior would be considered in the study.  Relatedly, in the required ZG Impact 
Assessment, “the stability and steady state analyses [will] test[] the impact of injections if the ZG 
Associated Load trips offline for the duration of the Transient Tolerance window,”92 but the 
Proposal leaves unclear whether any such tripping potential by the constituent storage unit would 
be considered in the study.  Additionally, a ZG Generating Facility shall be metered “separate from 
any metering used for the ZG Associated Load,”93 but the Proposal should clarify whether a 
constituent storage unit within a ZGIA Hybrid Resource must be separately metered from the 
constituent generator and whether its charging behavior should be netted from the ZG Generating 
Facility’s “injections” to the extent they must not exceed94 the Load or Demand of the ZG 
Associated Load. 
F. Drafting Errors 
While Community Organizations and Clean Energy Advocates continue to believe the 
Proposal is not just and reasonable as filed, we write here to highlight what may be unintended 
errors in the Proposal as submitted. 
1. 
Limitation on Injections 
 
91 MISO, Removing Storage Charging Limitations in GIAs (PAC-2024-3) (Jun. 10, 2026), 
https://cdn.misoenergy.org/20260610%20PSC%20Item%2005%20Removing%20Storage%20Limitations%20in%20
GIAs%20(PAC-2024-3)762998.pdf, at passim; MISO, Removing Storage Charging Limitations in GIAs (PAC-2024-
3) (Aug. 26, 2026), 
https://cdn.misoenergy.org/20260826%20PAC%20Item%2007a%20Removing%20Storage%20Limitations%20in%
20GIAs%20 (PAC-2024-3)776961.pdf, at passim. 
92 Transmittal Letter at 15, 28 (discussing proposed Att. X § 3.2.5.2.1); Keyser Test. at 11:2-4, 31:6-7. 
93 Proposed Att. X, App’x 19 § 7.1. 
94 See, e.g., proposed Att. X § 1 (definition of Transient Tolerance Window); proposed Att. X § 3.11(v) (limiting the 
ZG Interconnection Service amount to the ZG Associated Load’s Demand); proposed Att. X, App’x 19 § 9.7.4.7 
(requiring a ZG Generating Facility to reduce injections to match the ZG Associated Load’s Demand).

28 
To support a ZG Generating Facility’s requirement to avoid grid injections and produce only 
the power its ZG Associated Load demands, MISO proposes to require that, after a reduction or 
loss of load by the ZG Associated Load, the ZG generator shall “reduce its injections to a level 
that does not exceed the Demand of the ZG Associated Load within the Transient Tolerance 
Window [after a load reduction]”95 or “reduce[] its injections to an amount not greater than the 
Load of the ZG Associated Load.”96 
A probable error is in the phrase “reduce its injections” (emphasis added). As the name of the 
interconnection program suggests, grid injections are supposed to be zero, after the Transient 
Tolerance Window elapses. The intent of the referenced phrase may be better captured by MISO’s 
statement: “it is important to correspondingly reduce the output of the ZG Resource to prevent 
power from flowing out onto the Transmission System”97 or statements in the Show Cause Order 
contemplating that under this type of arrangement, “a generating facility’s output is matched to the 
demand of the electrically proximate large load or large co-located load.”98 The Commission 
should, at minimum, clarify whether MISO intended to write “output” rather than “injections” in 
the referenced quotations. If MISO intended the phrasing as written, further clarification may be 
needed to avoid creating a data center-sized loophole: “injections” in the quoted tariff language in 
Attachment X, Section 1 and in Attachment X, Appendix 19, Section 9.7.4.7 can mean only 
injections within the circuit up to the POI, with zero injections beyond that. 
It is also unclear whether the reference to Demand in Section 9.7.4.7 of the ZGIA 
Interconnection Agreement was intended to say Load, as Demand is defined in Module A as a 
 
95 Proposed Att. X, App’x 19 § 9.7.4.7(b). 
96 Proposed Att. X § 1 (definition of “Transient Tolerance Window”). 
97 Transmittal Letter at 42. 
98 Show Cause Order at P 113.

29 
maximum amount of Load over a specified period. If “Demand” was intended, then (i) the 
inconsistency with the use of “Load” in the definition of Transient Tolerance Window is 
unexplained; (ii) it is not clear how the Demand of the ZG Associated Load is to be calculated for 
this purpose; and (iii) it is unclear why the ZG Generating Facility would be allowed to indefinitely 
inject power at the level of some maximum level of Load. 
2. 
Reference to Interconnection Study 
In proposed new Attachment X, Section 3.2.5.1, the tariff language provides that “This [ZGIA] 
service is available only if the study required by Section 3.2.3.2 of these GIP determines that the 
proposed interconnection…” (emphasis added).  This appears to be an error; the reference should 
have been to (proposed new) Section 3.2.5.2 on the next page of Attachment X.  The same 
reference error is also found at proposed new Attachment X, Appendix 19, Section 4.1.4.1. 
 
III. 
CONCLUSION 
To effectuate MISO’s zero injection concept without raising the risk of adverse reliability 
events and cost shifts, Community Organizations and Clean Energy Advocates respectfully ask the 
Commission to use its authority to help MISO course correct.  Given the demonstrated reliability 
concerns interconnecting and serving large load customers, no countervailing reasons justify 
failing to establish operational penalties and transparent baseline requirements for system 
protection mechanisms.   Similarly, as the Commission noted in the OSC, cost transparency is 
paramount given the scale and pace of forecasted load growth.  Without publishing study 
information and reducing instances for mismatching cost responsibility between the multiple 
generator interconnection queue processes, MISO’s ZGIA process could unduly shift cost burdens 
to other ratepayers without giving states and other advocates visibility to identify or resolve the 
issues.

30 
 Since MISO has the structure for a reasonable co-location program, we urge the Commission 
to direct MISO to cure the deficiencies with filing before accepting it.   
DATED: September 8, 2026 
Respectfully submitted, 
/s/ Sameer H. Doshi 
Sameer H. Doshi 
Christine Powell 
Aaron Stemplewicz 
Aaliyah Adkins 
Earthjustice 
311 S. Wacker Dr., 14th Floor 
Chicago, IL 60606 
sdoshi@earthjustice.org 
cpowell@earthjustice.org 
astemplewicz@earthjustice.org 
aadkins@earthjustice.org 
Attorneys for Michigan Environmental Justice 
Coalition and Community Collaboration on 
Climate Change 
Kareem Scales 
Co-Chair 
Community Collaboration on Climate Change 
Grand Rapids, MI 
kareem@c4gr.org 
Wesley Watson 
Policy Associate 
Michigan Environmental Justice Coalition 
1401 W. Fort St., P.O. Box 44080 
Detroit, MI 48233 
wesley@michiganej.org 
/s/ Jonah Baskin 
Jonah Baskin 
Associate Attorney 
Sierra Club Environmental Law Program 
50 F Street NW, Eighth Floor 
Washington, DC 20001 
jonah.baskin@sierraclub.org

31 
 
 
 
/s/ Daniel Wiggins Jr. 
 
 
Daniel Wiggins Jr. 
 
Executive Director 
 
Midwest Tribal Energy Resources Association 
 
3136 W. Kilbourn Ave., Suite 200 
 
Milwaukee, WI 53208 
 
daniel.wiggins@mtera.org  
   
 
/s/ Natalie McIntire 
 
 
Natalie McIntire 
 
Senior Advocate 
 
Natural Resources Defense Council 
 
20 North Wacker Drive, Suite 1600 
 
Chicago, IL 60606 
 
(312) 995-5907 
 
nmcintire@nrdc.org 
 
 
/s/ Beth Soholt 
 
 
Beth Soholt 
 
Executive Director 
 
Clean Grid Alliance 
 
3433 Broadway St. NE, Suite 240 
 
Minneapolis, MN 55413 
 
bsoholt@cleangridalliance.org

32 
CERTIFICATE OF SERVICE 
I hereby certify that the foregoing has been served in accordance with 18 C.F.R. § 
385.2010 upon each party designated on the official service list in this proceeding by email. 
DATED: September 8, 2026 
 
/s/ Sameer H. Doshi 
 
 
Sameer H. Doshi 
 
Earthjustice 
 
311 S. Wacker Dr., 14th Floor 
 
Chicago, IL 60606 
 
sdoshi@earthjustice.org