ER26-3552-000 · 2026-09-11 · Organization of MISO States, Inc.

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

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UNITED STATES OF AMERICA  
 BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
  
 
 
) 
Midcontinent Independent System 
) 
Docket No. ER26-3552-000 
Operator, Inc. 
) 
 
 
) 
 
 
MOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS AND  
COMMENTS IN CONDITIONAL SUPPORT OF  
THE ORGANIZATION OF MISO STATES, INC. 
 
The Organization of MISO States, Inc. (“OMS”) submits this Notice of Intervention and 
Conditional Comments in Support in response to proposed tariff revisions filed by the 
Midcontinent Independent System Operator, Inc. (“MISO”) with the Federal Energy Regulatory 
Commission (“Commission”) in the above-captioned proceeding.1 On August 18, 2026, MISO 
filed proposed revisions to its Open Access Transmission, Energy, and Operating Reserves 
Markets Tariff (“Tariff”) to establish a Zero Injection Generator Interconnection Agreement 
(“ZGIA”), associated study process and operational requirements, and market and resource 
adequacy rules to accommodate Zero-Injection Generation Resources (“ZG Resource”) that intend 
to serve load interconnecting at the same substation as the Generating Facility. OMS cautiously 
supports the ZGIA proposal but highlights several critical reliability and resource adequacy 
concerns for the Commission’s consideration.  
I. 
MOTION FOR ACCEPTANCE OF LATE-FILED COMMENTS 
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure, OMS 
respectfully requests that the Commission accept these late-filed comments.2 On September 8, 
 
1 Midcontinent Indep. System Operator, Inc., Zero Injection Generator Interconnection Agreement, Docket No. 
ER26-3552 (August 18, 2026) (“ZGIA Filing”). 
2 18 C.F.R § 385.212.

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2026, OMS timely filed a doc-less Notice of Intervention in this proceeding.3 Due to the need to 
coordinate the perspectives of several OMS members and allow for sufficient review, it was 
determined that additional time was necessary to conduct a vote on the comments. 
OMS offers the following comments to aid the Commission in its decision-making process. 
The Commission may allow an untimely response when there is no showing of undue prejudice or 
delay. Through these brief comments, OMS does not seek to disrupt or delay the proceeding. OMS 
believes these comments will assist the Commission in its deliberations and improve overall 
understanding by offering the important perspectives of state regulators. Therefore, good cause 
exists to grant this Motion. OMS respectfully requests that the Commission grant this Motion and 
accept OMS’s comments. 
II. COMMENTS 
Over the course of the year, MISO and its stakeholders have worked to develop an 
interconnection and study process that facilitates the expedited integration of large loads and 
proximately located generation while maintaining system reliability and protecting customers from 
unnecessary costs. As recognized by the Commission in its Show Cause Order, rapidly increasing 
demand from data centers and other large loads presents new challenges for transmission planning, 
generator interconnection, resource adequacy, and reliable system operations.4  
OMS conditionally supports MISO’s Zero Injection Generator Interconnection Agreement 
(“ZGIA”) framework as a potential tool for addressing these challenges. However, MISO’s ZGIA 
framework should be implemented only with appropriate safeguards to ensure that expedited 
interconnection does not create increased reliability risks, preferential treatment, or costs shifted 
 
3 Notice of Intervention of the Organization of MISO States, Inc., Docket No. ER26-3552 (Sept. 8, 2026). 
4 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order”).

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to existing customers. Furthermore, nothing in the ZGIA Filing shall supplant state and local rules 
regarding generation and load application, approval, and interconnection processes. 
OMS’s position has evolved through substantial review of MISO’s ZGIA proposal and 
draft tariff provisions. In March 2026, OMS identified significant questions concerning reliability, 
multiple points of interconnection, cost allocation, resource adequacy, market participation, and 
circumstances in which associated generation does not materialize. In June, OMS recommended 
that additional time was needed to resolve outstanding issues before MISO filed its proposal. In 
July, after MISO delayed its filing, OMS continued to identify unresolved resource adequacy 
issues described in subsection E. below. 
OMS appreciates MISO’s subsequent efforts to further develop the proposal. Nevertheless, 
the Commission should evaluate ZGIA as a comprehensive package involving both generation and 
load, rather than as a generator interconnection mechanism considered in isolation. The 
Commission should also direct MISO to work with stakeholders on the development of Business 
Practice Manual rules to remedy the remaining reliability and resource adequacy issues presented 
by ZGIA. 
A. OMS Supports ZGIA as a Potential Tool to Interconnect Large Loads, Subject to 
Appropriate Safeguards. 
 
MISO began developing the ZGIA framework with the recognition that co-located 
arrangements were necessary to quickly integrate large loads and their associated generation while 
shielding existing customers from any resulting costs.5 The ZGIA framework is further premised 
on the understanding that a generator that serves a co-located load and is prohibited from injecting 
beyond the interconnecting substation may not present the same transmission impacts as a 
 
5 Interconnection of Large Loads to the Interstate Transmission Sys., Advanced Notice of Proposed Rulemaking, 
Docket No. RM26-4-000 (Oct. 27, 2025).

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conventional generating facility seeking firm interconnection service. As such, a properly designed 
ZGIA process could reduce unnecessary network upgrades, improve utilization of existing 
infrastructure, and facilitate timely development of generation and large loads. 
OMS recognizes the potential value of ZGIA and the importance of practical pathways for 
large load integration. The Commission’s Show Cause Order demonstrates that existing processes 
may need to evolve to accommodate rapidly changing demand. MISO’s ZGIA Filing likewise 
explains that ZGIA is intended to provide a defined interconnection and study process for 
generation serving load at the same substation and voltage level while prohibiting injection onto 
the broader transmission system. Therefore, OMS does not oppose the ZGIA Filing.  
While OMS does not oppose the ZGIA Filing, the Commission should determine whether 
the proposed ZGIA framework adequately protects the reliability and economic interests of 
existing customers and whether the treatment of ZGIA resources is consistent with MISO’s 
broader resource adequacy, market, transmission planning, and transmission service constructs. 
OMS recommends that the Commission approve ZGIA only if those protections are clear and 
enforceable. 
B. Reliability Protections Must Be Fundamental to the ZGIA Framework. 
The defining characteristic of ZGIA is the prohibition on injection beyond the 
interconnecting substation. That limitation must be treated as a reliability requirement, not merely 
a contractual condition. OMS remains concerned that financial penalties alone may not adequately 
protect against inadvertent injection, no matter how momentary or transitory. Relevant 
transmission system conditions should be studied prior to ZGIA execution rather than relying 
solely on post-event penalties.

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MISO appears to appreciate the importance of this distinction as its ZGIA Filing requires 
detailed modeling of the generator, associated load, and protection facilities as well as proposed 
operating requirements necessary to prevent injections beyond the interconnecting substation. 
OMS remains concerned, however, that MISO has deferred establishing an explicit definition of 
the appropriate Transient Tolerance Window to the development of its Business Practice Manual.6 
It is paramount that the studies and the Transient Tolerance Window be developed and conducted 
with sufficient rigor to ensure that ZG Resources do not cause adverse impacts to system reliability. 
OMS recommends that the Commission ensure those operating requirements are 
sufficiently specific, enforceable, and capable of physically or operationally preventing prohibited 
injection. Depending on the facility, such mechanisms could include physical controls, generator 
drawback controls, remedial action schemes, or other technologies and operating requirements 
MISO determines are necessary. OMS also recommends that the ZGIA study process evaluate 
both sides of the generation-load relationship, including but not limited to: 
• the ZGIA generator tripping offline; 
• the associated load tripping offline; 
• the associated load rapidly reducing and increasing output; 
• the generator being required to rapidly reduce output following a load reduction; 
• simultaneous or correlated outages of the generator and load; and 
• circumstances in which the generator and load do not behave as assumed in the 
interconnection study. 
 
6 ZGIA Filing, Prepared Direct Testimony of Marc Keyser, at 25-26; Per MISO’s proposed Tariff revision, 
Transient Tolerance Window shall mean the period of time after a reduction or loss of load by the ZG Associated 
Load by the end of which window the Generating Facility with ZG Interconnection Service must have reduced its 
injections to an amount not greater than the Load of the ZG Associated Load. The Transient Tolerance Window 
shall be no greater than 20 seconds, and is further described by the Business Practices Manual for Large Load. The 
Transient Tolerance Window will be subject to Transmission Owner local planning criteria.

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These scenarios are important because a large load that suddenly disappears can leave generation 
temporarily without its expected sink. Conversely, a generator outage can cause a large load to 
rely immediately on the broader network for support. 
OMS therefore recommends that the Commission consider whether MISO’s ZGIA study 
procedures adequately evaluate these operating conditions, including dynamic and stability 
considerations where appropriate. MISO’s ZGIA Filing should also establish detailed metering, 
telemetry, modeling, communications, and operating requirements to ensure that MISO and the 
applicable Transmission Owner have adequate visibility into both the ZGIA generator and 
associated load. 
C. The Initial ZGIA Framework Should Be Limited to Generation and Load at the 
Same Substation and Voltage Level. 
 
OMS continues to support a narrowly defined ZGIA framework. MISO’s ZGIA Filing 
limits ZG Interconnection Service to generation and associated load located at the same substation 
and voltage level. MISO explains that this can include configurations in which the generation and 
load have separate points of interconnection or withdrawal at a common substation, provided the 
required limitations on injection are maintained. 7  OMS supports this narrow approach and 
recommends that the Commission retain the common-substation limitation. 
OMS recognizes that MISO considered both a strict same-POI approach and broader 
electrically proximate configurations (e.g., campus approach). MISO rejected the latter for this 
proposal because of unresolved reliability, transmission service, and jurisdictional issues but 
intends to address electrically proximate configurations through its forthcoming Large Load 
Addition Resource Study (“LARS”) process. OMS agrees that those broader configurations should 
 
7 ZGIA Filing at 7.

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not be incorporated into ZGIA. Expanding the framework beyond a common substation could 
introduce additional reliability, transmission service, cost allocation, market, and jurisdictional 
questions. As such, OMS recommends that the Commission accept the common-substation and 
voltage-level limitation as the appropriate scope of ZGIA. 
D. MISO Must Prevent Cost Shifting When the Associated Generation or Load Does 
Not Materialize. 
 
A central benefit of ZGIA is the ability to avoid or reduce network upgrades that otherwise 
could be required if associated load were evaluated without the ZG generation. That benefit 
depends upon the continued existence and operation of the generation relied upon in the load study. 
OMS supports MISO’s requirements for an agreement between the generator and associated load 
demonstrating that the full output of the generating facility is intended to serve the associated load, 
with an expected period of at least five years.8 MISO explains that this requirement is intended to 
prevent speculative requests and provide sufficient certainty for MISO to rely on the generation as 
an alternative mitigation in transmission-service studies.9  
MISO also recognizes that if the generating facility ceases to serve the associated load, 
MISO may need to restudy the load’s transmission impacts and potentially delay or suspend 
service while an alternative mitigation is identified. Those provisions are important, but MISO’s 
Tariff should go further by establishing clear responsibility for resulting costs. If network upgrades 
subsequently become necessary because generation that supported the original study assumptions 
does not materialize or ceases to operate, the costs of that incremental need should not 
automatically shift to existing transmission customers. 
 
 
8 Id. at 32.  
9 Id.

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To prevent such occurrences, the Commission should require MISO to establish in its 
Tariff or BPMs: 
• 
clear notification requirements; 
• 
defined triggers for restudy; 
• 
procedures for identifying previously avoided or deferred upgrades; 
• 
mechanisms for tracing subsequent upgrades to assumptions underlying the original ZGIA 
approval; 
• 
appropriate cost responsibility for the customer or customers whose circumstances caused 
the additional need; and 
• 
protections against socializing costs that would not otherwise have been incurred. 
These provisions are particularly important because MISO’s proposal relies on the ZG Resource 
as an alternative mitigation in studying the associated load. 
E. Resource Adequacy Treatment Must Be Complete, Transparent, and Consistent 
with Physical Capability. 
 
OMS continues to have significant concerns regarding the treatment of ZGIA resources in 
MISO’s Resource Adequacy (“RA”) construct. The fact that a ZG Resource cannot inject beyond 
the interconnecting substation does not mean that it has no relevance to regional reliability. 
Similarly, associated load cannot be treated as though it has disappeared simply because it is served 
in part or in whole by on-site generation. 
OMS recognizes that MISO’s filing proposes specific RA treatment. In particular, MISO 
proposes to cap Seasonal Accredited Capacity (“SAC”) for a ZG Resource based on the applicable 
portion of the Coincident Peak Demand forecast attributable to the ZG Associated Load, less SAC 
assigned to that load, with an adjustment for avoided transmission losses.10 MISO also proposes 
 
10 Id., Proposed Tariff Redlines, Seasonal Accredited Capacity of Capacity Resources, 43.0.0, i., 1.

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limits on ZG Resource participation in the Planning Resource Auction and would not permit 
uncleared Zonal Resource Credits to be used for replacement. 
The Commission should ensure that MISO has demonstrated these provisions operate 
consistently across the entire RA construct and accurately reflect the physical reliability 
contribution of the paired generation and load. To that end, OMS requests that MISO explain in a 
compliance filing, subsequent BPM rules, or a workshop how ZGIA resources and associated loads 
will be represented in: 
• 
the LOLE model, including CIL, CEL, LCR calculations; 
• 
UCAP calculations; 
• 
SAC calculations; 
• 
PRM requirements; 
• 
the Planning Resource Auction; 
• 
must-offer requirements; 
• 
transmission outage scenarios; 
• 
generator outage scenarios; 
• 
load outage and load-reduction scenarios; and 
• 
PRMR allocation framework(s). 
 
Of particular concern is whether different ZGIA-specific limitations produce inconsistent 
outcomes among the various components of the RA construct. For example, OMS has identified a 
potential mismatch if a ZG Resource’s availability is reduced because its associated load decreases, 
but there is not a mechanism for such reductions to be accounted for or modeled in the LOLE 
study. Consequently, resource class-level results in the LOLE study may over-estimate resource 
performance. Although ZG Resources would have SAC constrained by the associated load’s 
Coincident Peak Demand forecast, that cap takes place outside of the LOLE study. Without 
addressing limitations, it appears possible that MISO could produce study results that suggest a 
fleet of resources that appears capable of satisfying the PRM in one component of the RA construct

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but is unable to provide the corresponding reliability contribution under other ZGIA-specific 
limitations. 
MISO should demonstrate that its methodology avoids such inconsistencies. The 
Commission also should require MISO to explain how ZGIA treatment will interact with 
forthcoming changes to DLOL and PRMR allocation. Tariff provisions tied too specifically to the 
current Coincident Peak Demand construct could become inconsistent with MISO’s future RA 
framework. OMS therefore recommends that ZGIA Tariff language or BPM rules provide 
sufficient flexibility to remain consistent with subsequent Commission-approved RA reforms 
while preserving the fundamental principle that accreditation must reflect the physical capability 
and reliability contribution of the resource. 
F. ZGIA Should Provide a Clear Transition Path Without Circumventing the DPP. 
OMS recognizes that MISO’s proposal expressly permits a ZG Resource to pursue another 
form of interconnection service separately, including full integration and injection rights through 
Network Resource Interconnection Service (“NRIS”) through MISO’s Definitive Planning 
Process (“DPP”), with the subsequently effective service superseding ZG Interconnection Service. 
OMS supports providing a clear transition path for a ZGIA resource that later seeks injection rights. 
That transition, however, must not allow a ZGIA resource to circumvent or obtain an advantage 
over interconnection customers already participating in the DPP queue. MISO should clearly 
specify how such transitions will be sequenced, how queue position and study impacts will be 
determined, and how transmission capability reserved or relied upon under ZGIA will be treated 
when the resource seeks broader injection rights. 
MISO characterizes ZGIA as a permanent feature in its Tariff rather than a temporary 
program. Meanwhile, MISO and stakeholders are also developing separate processes for broader

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electrically proximate configurations (e.g., LARS). The Commission should focus on preventing 
ZGIA from becoming a mechanism for indefinite avoidance of the standard DPP interconnection 
process and should continue to hold MISO accountable for improving the processing of its 
standard generator interconnection queue. 
G. OMS Supports Transparency and Meaningful State and Stakeholder Oversight. 
The rapid development of large-load projects creates significant implications for state 
regulatory commissions, load-serving entities, transmission owners, existing customers, and other 
market participants. The ZGIA framework should therefore provide sufficient transparency for 
regulators and stakeholders to understand: 
• 
the amount and characteristics of load relying on ZG Resources; 
• 
the amount and characteristics of associated generation; 
• 
the status of ZGIA projects; 
• 
material changes to ZGIA arrangements; 
• 
withdrawals or failures to materialize; 
• 
restudies and resulting network upgrades; 
• 
the treatment of ZG Resources in RA and markets; and 
• 
the reliability assumptions underlying ZGIA approvals. 
This information is important not only for MISO’s operations and planning functions, but also for 
state regulatory processes, including integrated resource planning, certificates of public 
convenience and necessity, procurement proceedings, and other state proceedings concerning the 
adequacy, cost, and reliability of electric service. 
OMS is particularly concerned that a framework designed to accelerate large-load 
development should not impair states’ ability to evaluate the costs and risks associated with serving 
those loads. In its ZGIA Filing, MISO recognizes that ZGIA does not establish new transmission

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service rules and that additional large-load proposals will address other issues raised by the 
Commission.  
H. ZGIA Should Complement, Not Displace, Broader Transmission and Large-Load 
Reforms. 
OMS supports ZGIA as one tool within MISO’s broader response to large load growth. 
ZGIA should not, however, substitute for: cost-effective transmission expansion and regional 
planning when objective and broadly distributed benefits clearly outweigh costs; improvements to 
MISO’s generator and load interconnection processes; or development of appropriate large-load 
transmission service. 
MISO describes ZGIA as the first in a series of proposed solutions developed through the 
stakeholder-led Large Load Working Group and identifies LARS as a forthcoming process for 
addressing electrically proximate generation and load that do not satisfy the narrower ZGIA 
requirements.11 The underlying growth in demand will continue to affect regional transmission 
planning, resource adequacy, and system operations even when some large loads are paired with 
generation behind the meter or at a common substation. 
Consistent with OMS’s support for MISO and the MISO Transmission Owners’ abeyance 
request, the Commission should therefore evaluate ZGIA as one component of a broader, 
comprehensive framework for large load integration rather than as a standalone solution.12 That 
framework should address the broader concerns identified in the Commission’s Show Cause Order, 
including reliable and transparent transmission planning, meaningful consideration of alternative 
 
11 Id. at 7.  
12 Answer in Support of the Motion to Hold Proceeding in Abeyance of MISO and the MISO Transmission Owners 
of OMS, Docket No. EL26-70-000 (August 7, 2026).

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solutions, protection of existing customers from inappropriate cost shifting, and consideration of 
reliability impacts associated with uncertain or delayed load development.  
The Commission should also make clear that consideration of the ZGIA Filing does not 
resolve these broader issues or otherwise limit the scope of its inquiry. Since MISO intends its 
stakeholder process and subsequent 205 filings to address the Commission’s concerns regarding 
large load interconnection, the Commission should evaluate the ZGIA Filing together with other 
reforms developed during that process only after a complete record is developed whether the 
resulting framework adequately addresses the concerns identified in the Show Cause Order.  
III. CONCLUSION 
OMS appreciates MISO’s efforts to develop a practical mechanism for facilitating the 
timely integration of large loads and associated generation. OMS agrees that a well-designed ZGIA 
framework can provide meaningful benefits by allowing generation that is dedicated to serving an 
associated load to be evaluated in a manner consistent with its limited transmission-system impact. 
OMS’s support, however, is conditioned on maintaining the fundamental principles of reliability, 
cost causation, transparency, and equitable treatment of customers and market participants as 
detailed above. 
OMS submits this Answer because a majority of OMS members support this filing. This 
should not be construed to mean that all OMS members agree with all comments herein. Individual 
OMS members reserve the right to file separate comments. In recognition of such, the following 
members voted in support of this filing: 
Arkansas Public Service Commission  
Illinois Commerce Commission 
Iowa Utilities Commission  
Indiana Utility Regulatory Commission

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Kentucky Public Service Commission  
Louisiana Public Service Commission 
Michigan Public Service Commission 
Minnesota Public Utilities Commission  
Mississippi Public Service Commission 
Missouri Public Service Commission  
New Orleans City Council 
North Dakota Public Service Commission  
South Dakota Public Utilities Commission  
Public Service Commission of Wisconsin  
Public Utility Commission of Texas  
The Manitoba Public Utilities Board and the Montana Public Service Commission did not 
participate in the vote on this filing. 
 
 
 
Respectfully submitted, 
 
 
 
 /s/ Brad J. Pope 
 
 
 
  
 /s/ Tricia DeBleeckere  
Brad Pope  
 
 
 
    
Tricia DeBleeckere 
Legal and Regulatory Director 
 
 
Executive Director 
Organization of MISO States 
 
 
Organization of MISO States 
811 E. Washington Ave., Suite 400  
 
811 E. Washington Avenue, Ste. 400 
Madison, WI 53703  
 
 
 
Madison, WI 53703 
brad@misostates.org 
 
 
 
tricia@misostates.org 
 
Dated: September 11, 2026

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CERTIFICATE OF SERVICE 
 
       I certify that I have served the preceding document upon each person designated on the official 
service list prepared by the Secretary for this proceeding in accordance with the requirements of 
Rule 2010 of the Commission’s Rules of Practice and Procedure. 18 C.F.R. § 385.2010. 
 
 /s/ Brad J. Pope 
 
Brad Pope 
Director of Legal & Regulatory Affairs 
Organization of MISO States 
811 E. Washington Avenue, Suite 400 
Madison, WI 53703 
brad@misostates.org 
 
Dated: September 11, 2026