{"document":{"slug":"filing-20260911-5203","title":"Motion for Acceptance of Late-Filed Comments and Comments in Conditional Support of the Organization of MISO States, Inc. re Midcontinent Independent System Operator, Inc.’s proposed tariff revisions","issued":"2026-09-11","accession":"20260911-5203","docket":"ER26-3552-000","group":"MISO filings","filer":"Organization of MISO States, Inc.","kind":"comments","file":"sources/originals/20260911-5203_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260911-5203","sha256":"7b670e5cab16dd60ac2aa432d9d65334d46fc86eb1b4e5ecdf08fa4dc31ab6bf","pages":15,"tokens":3579,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":221,"text":"1 \n \nUNITED STATES OF AMERICA  \n BEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n  \n \n \n) \nMidcontinent Independent System \n) \nDocket No. ER26-3552-000 \nOperator, Inc. \n) \n \n \n) \n \n \nMOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS AND  \nCOMMENTS IN CONDITIONAL SUPPORT OF  \nTHE ORGANIZATION OF MISO STATES, INC. \n \nThe Organization of MISO States, Inc. (“OMS”) submits this Notice of Intervention and \nConditional Comments in Support in response to proposed tariff revisions filed by the \nMidcontinent Independent System Operator, Inc. (“MISO”) with the Federal Energy Regulatory \nCommission (“Commission”) in the above-captioned proceeding.1 On August 18, 2026, MISO \nfiled proposed revisions to its Open Access Transmission, Energy, and Operating Reserves \nMarkets Tariff (“Tariff”) to establish a Zero Injection Generator Interconnection Agreement \n(“ZGIA”), associated study process and operational requirements, and market and resource \nadequacy rules to accommodate Zero-Injection Generation Resources (“ZG Resource”) that intend \nto serve load interconnecting at the same substation as the Generating Facility. OMS cautiously \nsupports the ZGIA proposal but highlights several critical reliability and resource adequacy \nconcerns for the Commission’s consideration.  \nI. \nMOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS \nPursuant to Rule 212 of the Commission’s Rules of Practice and Procedure, OMS \nrespectfully requests that the Commission accept these late-filed comments.2 On September 8, \n \n1 Midcontinent Indep. System Operator, Inc., Zero Injection Generator Interconnection Agreement, Docket No. \nER26-3552 (August 18, 2026) (“ZGIA Filing”). \n2 18 C.F.R § 385.212."},{"page":2,"startToken":221,"endToken":521,"text":"2 \n \n2026, OMS timely filed a doc-less Notice of Intervention in this proceeding.3 Due to the need to \ncoordinate the perspectives of several OMS members and allow for sufficient review, it was \ndetermined that additional time was necessary to conduct a vote on the comments. \nOMS offers the following comments to aid the Commission in its decision-making process. \nThe Commission may allow an untimely response when there is no showing of undue prejudice or \ndelay. Through these brief comments, OMS does not seek to disrupt or delay the proceeding. OMS \nbelieves these comments will assist the Commission in its deliberations and improve overall \nunderstanding by offering the important perspectives of state regulators. Therefore, good cause \nexists to grant this Motion. OMS respectfully requests that the Commission grant this Motion and \naccept OMS’s comments. \nII. COMMENTS \nOver the course of the year, MISO and its stakeholders have worked to develop an \ninterconnection and study process that facilitates the expedited integration of large loads and \nproximately located generation while maintaining system reliability and protecting customers from \nunnecessary costs. As recognized by the Commission in its Show Cause Order, rapidly increasing \ndemand from data centers and other large loads presents new challenges for transmission planning, \ngenerator interconnection, resource adequacy, and reliable system operations.4  \nOMS conditionally supports MISO’s Zero Injection Generator Interconnection Agreement \n(“ZGIA”) framework as a potential tool for addressing these challenges. However, MISO’s ZGIA \nframework should be implemented only with appropriate safeguards to ensure that expedited \ninterconnection does not create increased reliability risks, preferential treatment, or costs shifted \n \n3 Notice of Intervention of the Organization of MISO States, Inc., Docket No. ER26-3552 (Sept. 8, 2026). \n4 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order”)."},{"page":3,"startToken":521,"endToken":796,"text":"3 \n \nto existing customers. Furthermore, nothing in the ZGIA Filing shall supplant state and local rules \nregarding generation and load application, approval, and interconnection processes. \nOMS’s position has evolved through substantial review of MISO’s ZGIA proposal and \ndraft tariff provisions. In March 2026, OMS identified significant questions concerning reliability, \nmultiple points of interconnection, cost allocation, resource adequacy, market participation, and \ncircumstances in which associated generation does not materialize. In June, OMS recommended \nthat additional time was needed to resolve outstanding issues before MISO filed its proposal. In \nJuly, after MISO delayed its filing, OMS continued to identify unresolved resource adequacy \nissues described in subsection E. below. \nOMS appreciates MISO’s subsequent efforts to further develop the proposal. Nevertheless, \nthe Commission should evaluate ZGIA as a comprehensive package involving both generation and \nload, rather than as a generator interconnection mechanism considered in isolation. The \nCommission should also direct MISO to work with stakeholders on the development of Business \nPractice Manual rules to remedy the remaining reliability and resource adequacy issues presented \nby ZGIA. \nA. OMS Supports ZGIA as a Potential Tool to Interconnect Large Loads, Subject to \nAppropriate Safeguards. \n \nMISO began developing the ZGIA framework with the recognition that co-located \narrangements were necessary to quickly integrate large loads and their associated generation while \nshielding existing customers from any resulting costs.5 The ZGIA framework is further premised \non the understanding that a generator that serves a co-located load and is prohibited from injecting \nbeyond the interconnecting substation may not present the same transmission impacts as a \n \n5 Interconnection of Large Loads to the Interstate Transmission Sys., Advanced Notice of Proposed Rulemaking, \nDocket No. RM26-4-000 (Oct. 27, 2025)."},{"page":4,"startToken":796,"endToken":1048,"text":"4 \n \nconventional generating facility seeking firm interconnection service. As such, a properly designed \nZGIA process could reduce unnecessary network upgrades, improve utilization of existing \ninfrastructure, and facilitate timely development of generation and large loads. \nOMS recognizes the potential value of ZGIA and the importance of practical pathways for \nlarge load integration. The Commission’s Show Cause Order demonstrates that existing processes \nmay need to evolve to accommodate rapidly changing demand. MISO’s ZGIA Filing likewise \nexplains that ZGIA is intended to provide a defined interconnection and study process for \ngeneration serving load at the same substation and voltage level while prohibiting injection onto \nthe broader transmission system. Therefore, OMS does not oppose the ZGIA Filing.  \nWhile OMS does not oppose the ZGIA Filing, the Commission should determine whether \nthe proposed ZGIA framework adequately protects the reliability and economic interests of \nexisting customers and whether the treatment of ZGIA resources is consistent with MISO’s \nbroader resource adequacy, market, transmission planning, and transmission service constructs. \nOMS recommends that the Commission approve ZGIA only if those protections are clear and \nenforceable. \nB. Reliability Protections Must Be Fundamental to the ZGIA Framework. \nThe defining characteristic of ZGIA is the prohibition on injection beyond the \ninterconnecting substation. That limitation must be treated as a reliability requirement, not merely \na contractual condition. OMS remains concerned that financial penalties alone may not adequately \nprotect against inadvertent injection, no matter how momentary or transitory. Relevant \ntransmission system conditions should be studied prior to ZGIA execution rather than relying \nsolely on post-event penalties."},{"page":5,"startToken":1048,"endToken":1373,"text":"5 \n \nMISO appears to appreciate the importance of this distinction as its ZGIA Filing requires \ndetailed modeling of the generator, associated load, and protection facilities as well as proposed \noperating requirements necessary to prevent injections beyond the interconnecting substation. \nOMS remains concerned, however, that MISO has deferred establishing an explicit definition of \nthe appropriate Transient Tolerance Window to the development of its Business Practice Manual.6 \nIt is paramount that the studies and the Transient Tolerance Window be developed and conducted \nwith sufficient rigor to ensure that ZG Resources do not cause adverse impacts to system reliability. \nOMS recommends that the Commission ensure those operating requirements are \nsufficiently specific, enforceable, and capable of physically or operationally preventing prohibited \ninjection. Depending on the facility, such mechanisms could include physical controls, generator \ndrawback controls, remedial action schemes, or other technologies and operating requirements \nMISO determines are necessary. OMS also recommends that the ZGIA study process evaluate \nboth sides of the generation-load relationship, including but not limited to: \n• the ZGIA generator tripping offline; \n• the associated load tripping offline; \n• the associated load rapidly reducing and increasing output; \n• the generator being required to rapidly reduce output following a load reduction; \n• simultaneous or correlated outages of the generator and load; and \n• circumstances in which the generator and load do not behave as assumed in the \ninterconnection study. \n \n6 ZGIA Filing, Prepared Direct Testimony of Marc Keyser, at 25-26; Per MISO’s proposed Tariff revision, \nTransient Tolerance Window shall mean the period of time after a reduction or loss of load by the ZG Associated \nLoad by the end of which window the Generating Facility with ZG Interconnection Service must have reduced its \ninjections to an amount not greater than the Load of the ZG Associated Load. The Transient Tolerance Window \nshall be no greater than 20 seconds, and is further described by the Business Practices Manual for Large Load. The \nTransient Tolerance Window will be subject to Transmission Owner local planning criteria."},{"page":6,"startToken":1373,"endToken":1628,"text":"6 \n \nThese scenarios are important because a large load that suddenly disappears can leave generation \ntemporarily without its expected sink. Conversely, a generator outage can cause a large load to \nrely immediately on the broader network for support. \nOMS therefore recommends that the Commission consider whether MISO’s ZGIA study \nprocedures adequately evaluate these operating conditions, including dynamic and stability \nconsiderations where appropriate. MISO’s ZGIA Filing should also establish detailed metering, \ntelemetry, modeling, communications, and operating requirements to ensure that MISO and the \napplicable Transmission Owner have adequate visibility into both the ZGIA generator and \nassociated load. \nC. The Initial ZGIA Framework Should Be Limited to Generation and Load at the \nSame Substation and Voltage Level. \n \nOMS continues to support a narrowly defined ZGIA framework. MISO’s ZGIA Filing \nlimits ZG Interconnection Service to generation and associated load located at the same substation \nand voltage level. MISO explains that this can include configurations in which the generation and \nload have separate points of interconnection or withdrawal at a common substation, provided the \nrequired limitations on injection are maintained. 7  OMS supports this narrow approach and \nrecommends that the Commission retain the common-substation limitation. \nOMS recognizes that MISO considered both a strict same-POI approach and broader \nelectrically proximate configurations (e.g., campus approach). MISO rejected the latter for this \nproposal because of unresolved reliability, transmission service, and jurisdictional issues but \nintends to address electrically proximate configurations through its forthcoming Large Load \nAddition Resource Study (“LARS”) process. OMS agrees that those broader configurations should \n \n7 ZGIA Filing at 7."},{"page":7,"startToken":1628,"endToken":1895,"text":"7 \n \nnot be incorporated into ZGIA. Expanding the framework beyond a common substation could \nintroduce additional reliability, transmission service, cost allocation, market, and jurisdictional \nquestions. As such, OMS recommends that the Commission accept the common-substation and \nvoltage-level limitation as the appropriate scope of ZGIA. \nD. MISO Must Prevent Cost Shifting When the Associated Generation or Load Does \nNot Materialize. \n \nA central benefit of ZGIA is the ability to avoid or reduce network upgrades that otherwise \ncould be required if associated load were evaluated without the ZG generation. That benefit \ndepends upon the continued existence and operation of the generation relied upon in the load study. \nOMS supports MISO’s requirements for an agreement between the generator and associated load \ndemonstrating that the full output of the generating facility is intended to serve the associated load, \nwith an expected period of at least five years.8 MISO explains that this requirement is intended to \nprevent speculative requests and provide sufficient certainty for MISO to rely on the generation as \nan alternative mitigation in transmission-service studies.9  \nMISO also recognizes that if the generating facility ceases to serve the associated load, \nMISO may need to restudy the load’s transmission impacts and potentially delay or suspend \nservice while an alternative mitigation is identified. Those provisions are important, but MISO’s \nTariff should go further by establishing clear responsibility for resulting costs. If network upgrades \nsubsequently become necessary because generation that supported the original study assumptions \ndoes not materialize or ceases to operate, the costs of that incremental need should not \nautomatically shift to existing transmission customers. \n \n \n8 Id. at 32.  \n9 Id."},{"page":8,"startToken":1895,"endToken":2138,"text":"8 \n \nTo prevent such occurrences, the Commission should require MISO to establish in its \nTariff or BPMs: \n• \nclear notification requirements; \n• \ndefined triggers for restudy; \n• \nprocedures for identifying previously avoided or deferred upgrades; \n• \nmechanisms for tracing subsequent upgrades to assumptions underlying the original ZGIA \napproval; \n• \nappropriate cost responsibility for the customer or customers whose circumstances caused \nthe additional need; and \n• \nprotections against socializing costs that would not otherwise have been incurred. \nThese provisions are particularly important because MISO’s proposal relies on the ZG Resource \nas an alternative mitigation in studying the associated load. \nE. Resource Adequacy Treatment Must Be Complete, Transparent, and Consistent \nwith Physical Capability. \n \nOMS continues to have significant concerns regarding the treatment of ZGIA resources in \nMISO’s Resource Adequacy (“RA”) construct. The fact that a ZG Resource cannot inject beyond \nthe interconnecting substation does not mean that it has no relevance to regional reliability. \nSimilarly, associated load cannot be treated as though it has disappeared simply because it is served \nin part or in whole by on-site generation. \nOMS recognizes that MISO’s filing proposes specific RA treatment. In particular, MISO \nproposes to cap Seasonal Accredited Capacity (“SAC”) for a ZG Resource based on the applicable \nportion of the Coincident Peak Demand forecast attributable to the ZG Associated Load, less SAC \nassigned to that load, with an adjustment for avoided transmission losses.10 MISO also proposes \n \n10 Id., Proposed Tariff Redlines, Seasonal Accredited Capacity of Capacity Resources, 43.0.0, i., 1."},{"page":9,"startToken":2138,"endToken":2382,"text":"9 \n \nlimits on ZG Resource participation in the Planning Resource Auction and would not permit \nuncleared Zonal Resource Credits to be used for replacement. \nThe Commission should ensure that MISO has demonstrated these provisions operate \nconsistently across the entire RA construct and accurately reflect the physical reliability \ncontribution of the paired generation and load. To that end, OMS requests that MISO explain in a \ncompliance filing, subsequent BPM rules, or a workshop how ZGIA resources and associated loads \nwill be represented in: \n• \nthe LOLE model, including CIL, CEL, LCR calculations; \n• \nUCAP calculations; \n• \nSAC calculations; \n• \nPRM requirements; \n• \nthe Planning Resource Auction; \n• \nmust-offer requirements; \n• \ntransmission outage scenarios; \n• \ngenerator outage scenarios; \n• \nload outage and load-reduction scenarios; and \n• \nPRMR allocation framework(s). \n \nOf particular concern is whether different ZGIA-specific limitations produce inconsistent \noutcomes among the various components of the RA construct. For example, OMS has identified a \npotential mismatch if a ZG Resource’s availability is reduced because its associated load decreases, \nbut there is not a mechanism for such reductions to be accounted for or modeled in the LOLE \nstudy. Consequently, resource class-level results in the LOLE study may over-estimate resource \nperformance. Although ZG Resources would have SAC constrained by the associated load’s \nCoincident Peak Demand forecast, that cap takes place outside of the LOLE study. Without \naddressing limitations, it appears possible that MISO could produce study results that suggest a \nfleet of resources that appears capable of satisfying the PRM in one component of the RA construct"},{"page":10,"startToken":2382,"endToken":2647,"text":"10 \n \nbut is unable to provide the corresponding reliability contribution under other ZGIA-specific \nlimitations. \nMISO should demonstrate that its methodology avoids such inconsistencies. The \nCommission also should require MISO to explain how ZGIA treatment will interact with \nforthcoming changes to DLOL and PRMR allocation. Tariff provisions tied too specifically to the \ncurrent Coincident Peak Demand construct could become inconsistent with MISO’s future RA \nframework. OMS therefore recommends that ZGIA Tariff language or BPM rules provide \nsufficient flexibility to remain consistent with subsequent Commission-approved RA reforms \nwhile preserving the fundamental principle that accreditation must reflect the physical capability \nand reliability contribution of the resource. \nF. ZGIA Should Provide a Clear Transition Path Without Circumventing the DPP. \nOMS recognizes that MISO’s proposal expressly permits a ZG Resource to pursue another \nform of interconnection service separately, including full integration and injection rights through \nNetwork Resource Interconnection Service (“NRIS”) through MISO’s Definitive Planning \nProcess (“DPP”), with the subsequently effective service superseding ZG Interconnection Service. \nOMS supports providing a clear transition path for a ZGIA resource that later seeks injection rights. \nThat transition, however, must not allow a ZGIA resource to circumvent or obtain an advantage \nover interconnection customers already participating in the DPP queue. MISO should clearly \nspecify how such transitions will be sequenced, how queue position and study impacts will be \ndetermined, and how transmission capability reserved or relied upon under ZGIA will be treated \nwhen the resource seeks broader injection rights. \nMISO characterizes ZGIA as a permanent feature in its Tariff rather than a temporary \nprogram. Meanwhile, MISO and stakeholders are also developing separate processes for broader"},{"page":11,"startToken":2647,"endToken":2875,"text":"11 \n \nelectrically proximate configurations (e.g., LARS). The Commission should focus on preventing \nZGIA from becoming a mechanism for indefinite avoidance of the standard DPP interconnection \nprocess and should continue to hold MISO accountable for improving the processing of its \nstandard generator interconnection queue. \nG. OMS Supports Transparency and Meaningful State and Stakeholder Oversight. \nThe rapid development of large-load projects creates significant implications for state \nregulatory commissions, load-serving entities, transmission owners, existing customers, and other \nmarket participants. The ZGIA framework should therefore provide sufficient transparency for \nregulators and stakeholders to understand: \n• \nthe amount and characteristics of load relying on ZG Resources; \n• \nthe amount and characteristics of associated generation; \n• \nthe status of ZGIA projects; \n• \nmaterial changes to ZGIA arrangements; \n• \nwithdrawals or failures to materialize; \n• \nrestudies and resulting network upgrades; \n• \nthe treatment of ZG Resources in RA and markets; and \n• \nthe reliability assumptions underlying ZGIA approvals. \nThis information is important not only for MISO’s operations and planning functions, but also for \nstate regulatory processes, including integrated resource planning, certificates of public \nconvenience and necessity, procurement proceedings, and other state proceedings concerning the \nadequacy, cost, and reliability of electric service. \nOMS is particularly concerned that a framework designed to accelerate large-load \ndevelopment should not impair states’ ability to evaluate the costs and risks associated with serving \nthose loads. In its ZGIA Filing, MISO recognizes that ZGIA does not establish new transmission"},{"page":12,"startToken":2875,"endToken":3122,"text":"12 \n \nservice rules and that additional large-load proposals will address other issues raised by the \nCommission.  \nH. ZGIA Should Complement, Not Displace, Broader Transmission and Large-Load \nReforms. \nOMS supports ZGIA as one tool within MISO’s broader response to large load growth. \nZGIA should not, however, substitute for: cost-effective transmission expansion and regional \nplanning when objective and broadly distributed benefits clearly outweigh costs; improvements to \nMISO’s generator and load interconnection processes; or development of appropriate large-load \ntransmission service. \nMISO describes ZGIA as the first in a series of proposed solutions developed through the \nstakeholder-led Large Load Working Group and identifies LARS as a forthcoming process for \naddressing electrically proximate generation and load that do not satisfy the narrower ZGIA \nrequirements.11 The underlying growth in demand will continue to affect regional transmission \nplanning, resource adequacy, and system operations even when some large loads are paired with \ngeneration behind the meter or at a common substation. \nConsistent with OMS’s support for MISO and the MISO Transmission Owners’ abeyance \nrequest, the Commission should therefore evaluate ZGIA as one component of a broader, \ncomprehensive framework for large load integration rather than as a standalone solution.12 That \nframework should address the broader concerns identified in the Commission’s Show Cause Order, \nincluding reliable and transparent transmission planning, meaningful consideration of alternative \n \n11 Id. at 7.  \n12 Answer in Support of the Motion to Hold Proceeding in Abeyance of MISO and the MISO Transmission Owners \nof OMS, Docket No. EL26-70-000 (August 7, 2026)."},{"page":13,"startToken":3122,"endToken":3373,"text":"13 \n \nsolutions, protection of existing customers from inappropriate cost shifting, and consideration of \nreliability impacts associated with uncertain or delayed load development.  \nThe Commission should also make clear that consideration of the ZGIA Filing does not \nresolve these broader issues or otherwise limit the scope of its inquiry. Since MISO intends its \nstakeholder process and subsequent 205 filings to address the Commission’s concerns regarding \nlarge load interconnection, the Commission should evaluate the ZGIA Filing together with other \nreforms developed during that process only after a complete record is developed whether the \nresulting framework adequately addresses the concerns identified in the Show Cause Order.  \nIII. CONCLUSION \nOMS appreciates MISO’s efforts to develop a practical mechanism for facilitating the \ntimely integration of large loads and associated generation. OMS agrees that a well-designed ZGIA \nframework can provide meaningful benefits by allowing generation that is dedicated to serving an \nassociated load to be evaluated in a manner consistent with its limited transmission-system impact. \nOMS’s support, however, is conditioned on maintaining the fundamental principles of reliability, \ncost causation, transparency, and equitable treatment of customers and market participants as \ndetailed above. \nOMS submits this Answer because a majority of OMS members support this filing. This \nshould not be construed to mean that all OMS members agree with all comments herein. Individual \nOMS members reserve the right to file separate comments. In recognition of such, the following \nmembers voted in support of this filing: \nArkansas Public Service Commission  \nIllinois Commerce Commission \nIowa Utilities Commission  \nIndiana Utility Regulatory Commission"},{"page":14,"startToken":3373,"endToken":3497,"text":"14 \n \nKentucky Public Service Commission  \nLouisiana Public Service Commission \nMichigan Public Service Commission \nMinnesota Public Utilities Commission  \nMississippi Public Service Commission \nMissouri Public Service Commission  \nNew Orleans City Council \nNorth Dakota Public Service Commission  \nSouth Dakota Public Utilities Commission  \nPublic Service Commission of Wisconsin  \nPublic Utility Commission of Texas  \nThe Manitoba Public Utilities Board and the Montana Public Service Commission did not \nparticipate in the vote on this filing. \n \n \n \nRespectfully submitted, \n \n \n \n /s/ Brad J. Pope \n \n \n \n  \n /s/ Tricia DeBleeckere  \nBrad Pope  \n \n \n \n    \nTricia DeBleeckere \nLegal and Regulatory Director \n \n \nExecutive Director \nOrganization of MISO States \n \n \nOrganization of MISO States \n811 E. Washington Ave., Suite 400  \n \n811 E. Washington Avenue, Ste. 400 \nMadison, WI 53703  \n \n \n \nMadison, WI 53703 \nbrad@misostates.org \n \n \n \ntricia@misostates.org \n \nDated: September 11, 2026"},{"page":15,"startToken":3497,"endToken":3579,"text":"15 \n \n \nCERTIFICATE OF SERVICE \n \n       I certify that I have served the preceding document upon each person designated on the official \nservice list prepared by the Secretary for this proceeding in accordance with the requirements of \nRule 2010 of the Commission’s Rules of Practice and Procedure. 18 C.F.R. § 385.2010. \n \n /s/ Brad J. Pope \n \nBrad Pope \nDirector of Legal & Regulatory Affairs \nOrganization of MISO States \n811 E. Washington Avenue, Suite 400 \nMadison, WI 53703 \nbrad@misostates.org \n \nDated: September 11, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1274,"startToken":0,"endToken":162},{"p":1,"at":1274,"title":"I. MOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS","method":"printed heading","endPage":2,"endAt":868,"startToken":162,"endToken":355},{"p":2,"at":868,"title":"II. COMMENTS","method":"printed heading","endPage":3,"endAt":1275,"startToken":355,"endToken":692},{"p":3,"at":1275,"title":"A. OMS Supports ZGIA as a Potential Tool to Interconnect Large Loads, Subject to","method":"printed heading","endPage":4,"endAt":1287,"startToken":692,"endToken":972},{"p":4,"at":1287,"title":"B. Reliability Protections Must Be Fundamental to the ZGIA Framework.","method":"printed heading","endPage":6,"endAt":722,"startToken":972,"endToken":1469},{"p":6,"at":722,"title":"C. The Initial ZGIA Framework Should Be Limited to Generation and Load at the","method":"printed heading","endPage":7,"endAt":344,"startToken":1469,"endToken":1672},{"p":7,"at":344,"title":"D. MISO Must Prevent Cost Shifting When the Associated Generation or Load Does","method":"printed heading","endPage":8,"endAt":716,"startToken":1672,"endToken":1987},{"p":8,"at":716,"title":"E. Resource Adequacy Treatment Must Be Complete, Transparent, and Consistent","method":"printed heading","endPage":10,"endAt":790,"startToken":1987,"endToken":2485},{"p":10,"at":790,"title":"F. ZGIA Should Provide a Clear Transition Path Without Circumventing the DPP.","method":"printed heading","endPage":11,"endAt":327,"startToken":2485,"endToken":2691},{"p":11,"at":327,"title":"G. OMS Supports Transparency and Meaningful State and Stakeholder Oversight.","method":"printed heading","endPage":12,"endAt":116,"startToken":2691,"endToken":2891},{"p":12,"at":116,"title":"H. ZGIA Should Complement, Not Displace, Broader Transmission and Large-Load","method":"printed heading","endPage":13,"endAt":743,"startToken":2891,"endToken":3225},{"p":13,"at":743,"title":"III. CONCLUSION","method":"printed heading","endPage":15,"endAt":8,"startToken":3225,"endToken":3498},{"p":15,"at":8,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":15,"endAt":530,"startToken":3498,"endToken":3579}]}