{"document":{"slug":"filing-20261008-5175","title":"Motion for Leave to Answer and Answer of Community Organizations and Clean Energy Advocates to Midcontinent Independent System Operator, Inc.’s 09/23/2026 Answer","issued":"2026-10-08","accession":"20261008-5175","docket":"ER26-3552-000","group":"MISO filings","filer":"Natural Resources Defense CouncilSierra ClubCommunity Collaboration on Climate Change ,Michigan Environmental Justice Coalition ,","kind":"answer","file":"sources/originals/20261008-5175_01.pdf","url":"https://sustainableferc.org/wp-content/uploads/2026/10/ZGIA_Answer.pdf","sha256":"8807355b3cd192b33de3e88f461750ba7f4029cddd3f41f4d5652409139fd372","pages":72,"tokens":19689,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":263,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nMidcontinent Independent \nDocket No. ER26-3552-000 \nSystem Operator, Inc. \nMOTION FOR LEAVE TO ANSWER AND ANSWER \nPursuant to Rule 213(a)(3) of the Federal Energy Regulatory Commission’s (“FERC”) \nRules of Practice and Procedure,1 Community Organizations and Clean Energy Advocates \nrespectfully submit this Motion for Leave to Answer and Answer to MISO’s Answer filed on \nSeptember 23, 2026,2 which directly engages with Community Organizations and Clean Energy \nAdvocates’ protest of MISO’s proposed Zero Generation Interconnection Service (“ZGIS”) and \nZero Generation Interconnection Agreement (“ZGIA”) process.3 This Answer is timely because \nit has been filed within 15 days of MISO’s September 23 filing.4 \nAs described in the Answer below and attached testimony from Mr. Houtan Moaveni, \nVice President at Grid Strategies LLC,5 MISO’s Answer does not redress the deficiencies of its \nproposal. Specifically, the proposed process does not ensure compliance with operational \nrequirements, does not demonstrate that its cost allocation method is just and reasonable, and is \nnot appropriately limited given the foregoing concerns. MISO’s Answer also only partially \n1 See generally 18 C.F.R. §§ 385.212 and 213 (2026). \n2 Motion For Leave to Answer And Answer Of The Midcontinent Independent System Operator, Inc., Accession No. \n20260923-5148 (“MISO Answer”). \n3 Protest of Community Organizations and Clean Energy Advocates, Accession No. 20260908-5341 \n (“Community Organizations and Clean Energy Advocates Protest”). \n4 18 C.F.R. §§ 385.213(d)(1). \n5 Attachment A, Testimony of Houtan Moaveni in Support of the Protest of Community Organizations and Clean \nEnergy Advocates (“Moaveni Testimony”)."},{"page":2,"startToken":263,"endToken":505,"text":"2 \n \nclarifies the functionality of ZGIS for all resources. As a result, the Commission should designate \nthe filing as deficient and direct further revision. \nCONTENTS \nMOTION FOR LEAVE ................................................................................................................ 3 \nANSWER ....................................................................................................................................... 3 \nA. MISO’s Answer Does Not Cure Concerns with ZGIA’s Operational Requirements. ......... 4 \n1. \nNeither Explanations in MISO’s Answer Nor Provisions in the Business Practice \nManual are Adequate Substitutes for Tariff Rules Regarding Key Operational Terms of the \nTransient Tolerance Window. .................................................................................................. 5 \n2. \nMISO’s Required Equipment Testing is Insufficient Verification to Confirm the \nPerformance of Injection-Limiting Plans. ............................................................................... 7 \n3. \nMISO’s Limited Remedies for Injection and Equipment Failures Fails to Properly \nIncentivize Compliance with Performance Standards, Risking Reliability Issues. ................ 9 \nB. \nMISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of Potential \nCost Shifts. ................................................................................................................................ 13 \n1. \nMISO’s Reliance on the Limited Nature of ZGIS Does Not Justify Socialization of \nUpgrades to Address Cumulative Grid Impacts. ................................................................... 14 \n2. \nMISO’s Defense of the 5-Year Contract Terms Misunderstands the Nature of Potential \nTransmission Cost Shifts. ..................................................................................................... 15 \n3. \nMISO Cannot Justify Exempting ZGIS from FERC’s Emphasis on Transparency to \nPrevent Large Load-Related Cost Shifts. .............................................................................. 17 \nC. \nMISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall Limits \non the ZGIA Process. ................................................................................................................ 18 \nD. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource \nParticipation, But the Commission Should Order Broader Confirmation via Compliance \nDirective or Deficiency Notice. ................................................................................................ 20 \nCONCLUSION ........................................................................................................................... 21 \nCERTIFICATE OF SERVICE .................................................................................................. 23 \nATTACHMENT A: TESTIMONY OF HOUTAN MOAVENI, GRID STRATEGIES…….24"},{"page":3,"startToken":505,"endToken":923,"text":"3 \n \nMOTION FOR LEAVE \nAlthough the Commission’s Rule 213(a)(2) does not generally permit answers to \nanswers,6 the Commission permits answers for good cause shown, including when an answer \ncontributes to a more accurate, complete record or provides information helpful to the \nCommission’s decision-making process.7 This Answer will aid the Commission’s decision-\nmaking process by providing additional perspective in support of the Community Organizations \nProtest from an electrical engineer with over a decade of transmission and interconnection policy \nleadership experience with utility and state organizations,8 as well as additional clarification of \nthe Protest. Community Organizations and Clean Energy Advocates therefore ask that FERC \naccept this Answer. \nANSWER \nCommunity Organizations and Clean Energy Advocates note three areas of concern that \nMISO’s Answer does not resolve: the failure of the proposed operational requirements to ensure \nthat generators with ZGIA service (“ZG resources”) are genuinely zero injection such that they \nwarrant expedited processing and do not risk reliability problems; the unjust and unreasonable \n \n6 18 C.F.R. §§ 385.213(a)(2). \n7 See, e.g., 189 FERC ¶ 61,181, at P 20 (2024) (Accepting answers from nine parties “because they have provided \ninformation that assisted us in our decision-making process.”); PJM Interconnection, L.L.C., 182 FERC ¶ 61,073, at \nP 13 (2023) (“We accept the answers of J-Power, P3, PJM, Public Interest Entities, and the Market Monitor because \nthey have provided information that assisted us in our decision-making process.”); N.Y. State Pub. Serv. Comm’n v. \nN.Y. Indep. Sys. Operator, Inc., 158 FERC ¶ 61,137, at P 29 (2017) (“We will accept the Companies’ and the \nComplainants’ answers because they have provided information that assisted us in our decision-making process.”), \nclarified by 170 FERC ¶ 61,120, order on reh’g, 173 FERC ¶ 61,022 (2020), order on reh’g, 174 FERC ¶ 61,110 \n(2021); Colonial Pipeline Co., 157 FERC ¶ 61,173, at P 23 (2016) (“In the instant case, the Commission will accept \nthe Protestors’ Answers and Colonial [Pipeline Co.]’s Answer because they have provided information that assisted \nus in our decision-making process.”).   \n8 As certain of the Community Organizations and Clean Energy Advocates indicated in the August 28, 2026 Motion \nfor Extension of Time in this proceeding, the original response time of 21 days after MISO’s initial filing made it \ndifficult for intervening parties to fully consult with relevant technical personnel.  Mr. Moaveni is previously \nfamiliar with MISO interconnection issues, having provided expert testimony on the ERAS proposal in Docket No. \nER25-1674 last year."},{"page":4,"startToken":923,"endToken":1214,"text":"4 \n \ncost allocation methods that shift certain types of costs from ZG resources by socializing them \nmore broadly; and the lack of system-wide limits on the ZGIA process, of which MISO fails to \nappropriately consider the broader implications. Finally, Community Organizations and Clean \nEnergy Advocates appreciate MISO’s Answer regarding the eligibility for hybrid resources, but \ncontinue to encourage FERC to require that these clarifications be solidified in the tariff. \nA. MISO’s Answer Does Not Cure Concerns with ZGIA’s Operational Requirements.  \nIn their initial protest, Community Organizations and Clean Energy Advocates explained \nthat MISO’s proposal fails to actually limit ZG resources to zero injections due to imprecise and \npermissive operational standards without adequate penalties and other incentives.9 MISO’s \nAnswer attempts to defend this design, noting that its proposal “imposes specific operational \nrequirements” to enforce ZGIS’s zero-injection limitation, including the required installation of \ncommunications and monitoring equipment by the ZG resource enabling it to monitor demand of \nthe ZG Associated Load, as well as equipment to enable the Generating facility to reduce its \ninjections within the Transient Tolerance Window.10 Community Organizations and Clean \nEnergy Advocates do recognize that MISO’s proposal includes several measures facially \ndesigned to ensure that resources with ZGIAs comply with the operating requirements.11 But as \nMr. Moaveni’s testimony further explains, these proposed measures leave several gaps.12 \nBy way of analogy, MISO’s requirements amount to requiring a car to have a \nspeedometer, without imposing appropriate speed limits on the road, using radar detection for \nindependent identification of speeding, or posting clear penalties to de-incentivize speeding. \n \n9 Community Organizations and Clean Energy Advocates Protest at 3-13. \n10 MISO Answer at 7. \n11 See Moaveni Testimony at 7-8 (summarizing operational requirements).  \n12 See generally Moaveni Testimony, Section III (7-25)."},{"page":5,"startToken":1214,"endToken":1491,"text":"5 \n \nCommunity Organizations and Clean Energy Advocates respond below to explain why the \nremaining uncertainty in implementation of the Transient Tolerance Window is akin to lacking \nappropriate speed limits. Further, inadequate verification of compliance testing is akin to not \nconducting independent speed checks, and reliance on solely a contractual remedy without \nintermediate remedies or financial penalties is akin to lacking clear and well-calibrated penalties \nfor road violations other than cancelling a driver’s license. Finally, we explain that MISO’s \nemphasis on the distinction between interconnection and transmission service, though important \nto understand, does not dispel Community Organizations’ concerns. \n1. Neither Explanations in MISO’s Answer Nor Provisions in the Business Practice \nManual are Adequate Substitutes for Tariff Rules Regarding Key Operational \nTerms of the Transient Tolerance Window. \nCommunity Organizations and Clean Energy Advocates’ Protest explained that MISO did \nnot justify the tariff’s use of a twenty-second Transient Tolerance Window,13 and that MISO’s \ninclusion of supplemental terms in the Business Practice Manual violates the Rule of Reason.14 \nMISO’s Answer does not remedy these concerns. First, MISO’s claim that the twenty-second \nmaximum has a “reasonable engineering basis”15 relies on the fact that MISO uses a twenty-\nsecond study period for other transient responses.16 But Community Organizations and Clean \nEnergy Advocates’ concern is not about using twenty seconds as an interval for transient study \ngenerally, but rather, whether the operational consequences of exceeding the zero-injection \nlimitation in this specific context cause reliability violations.17 As Mr. Moaveni puts simply, “the \n \n13 Community Organizations and Clean Energy Advocates Protest at 12. \n14 Id. at 13. \n15 MISO Answer at 10. \n16 Id. at 10-11. \n17 Moaveni Testimony at 17."},{"page":6,"startToken":1491,"endToken":1799,"text":"6 \n \nFiling does not demonstrate that injections lasting up to twenty seconds are operationally \nacceptable.”18 That’s because while the “study horizon establishes the period analyzed, it does \nnot by itself establish the maximum operationally acceptable duration of an unplanned export.”19 \nAs Mr. Moaveni states, “the permitted duration should be derived from what the system can \ntolerate at the location in question.”20 And as Community Organizations and Clean Energy \nAdvocates explained in protest, the ZGIA process is unique in that it is entirely defined and \njustified by virtue of having zero injections.21 \nSecond, MISO defends the twenty seconds as a just a ceiling, with the potential to be \nlowered based on tests to be memorialized within the Business Practice Manual,22 but this is \nirrelevant since (a) as explained above, there are no demonstrated circumstances that the ceiling \nis  proven to be appropriate under, and (b) in circumstances in which the 20-second ceiling \nwould not be appropriate, the applicability, enforceability, and functioning of the Business \nPractice Manual are all unclear and unreliable. It is well-established precedent that key terms \nmust be included in the tariff.23 This precedent is important. A resource’s ability to limit its \ninjections to its permitted tolerance window is a condition of ZGIS.24 MISO offers this service \non the basis that resources can and will adhere to these conditions. Yet MISO proposes to leave \nthe details of these conditions to the Business Practice Manual, a document that is developed \nthrough the stakeholder process and not filed with the Commission. As Mr. Moaveni explains, \n \n18 Moaveni Testimony at 16. \n19 Id. at 17. \n20 Id. \n21 Community Organizations and Clean Energy Advocates Protest at 3. \n22 MISO Answer at 11. \n23 City of Cleveland v. FERC, 773 F.2d 1368, 1376 (D.C. Cir. 1985). \n24 See Moaveni Testimony at 17."},{"page":7,"startToken":1799,"endToken":2089,"text":"7 \n \n“[t]he Tariff is the filed rate, and it should therefore contain sufficient detail for MISO to enforce \nthe operating restrictions applicable to a ZG resource.”25  \nMISO asserts that placing these critical rules in the manual ensures “consistent” treatment \nof ZG Interconnection Customers,26 but this assertion is unsupportable. Only the Tariff both \napplies equally and is enforceable. To be sure, some minor implementing terms can be \nappropriate for manual inclusion only. But in MISO’s proposal, the Tariff does not even \nexplicitly dictate the baseline standard to which ZG resources managed through the Business \nPractice Manual would be held. As Mr. Moaveni explains, “the performance any such solution \n[pursued through the Business Practice Manual] must achieve is not stated in the Tariff.”27 \nWithout at least this much of a baseline standard in the Tariff, MISO’s filing provides insufficient \nevidence for the Commission to conclude that rates established by the proposal would be just and \nreasonable, and the filing is deficient.  \n2. MISO’s Required Equipment Testing is Insufficient Verification to Confirm the \nPerformance of Injection-Limiting Plans.  \nCommunity Organizations and Clean Energy Advocates’ Protest also explained that the \nproposal does not sufficiently verify compliance with injection limits because MISO proposes to \nlet ZG resources propose their own protection equipment systems,28 in tandem with a deferred \nevaluation by MISO of any “proposed control equipment and/or operating procedures.”29 As we \nexplained, this open-ended and discretionary approach does not ensure ZGIS’ defining features \n \n25 Moaveni Testimony at 17. \n26 MISO Answer at 11. \n27 Moaveni Testimony at 20. \n28 Community Organizations and Clean Energy Advocates Protest at 9. \n29 Community Organizations and Clean Energy Advocates Protest at 10 (quoting Proposed Att. X § 3.2.5.2.1 \n(emphasis added))."},{"page":8,"startToken":2089,"endToken":2387,"text":"8 \n \nare met, nor provide adequate reliability safeguards. MISO now characterizes its choice to avoid \nany prescription of ZG resources’ specific technological approaches in favor of requiring only \ncompliance with operational requirements as “performance-based,” which it argues will better \nadapt to the changing nature of technology.30 But this characterization imposes a tradeoff \nbetween baseline requirements and additional, more flexible performance standards that does not \nneed to exist. MISO ultimately fails to demonstrate that stronger baseline requirements are \nunnecessary.  Moreover, the set of requirements proposed by MISO collectively fail to verify that \na ZG resource’s injection-limiting scheme will actually perform according to plan.31 \nMISO’s reliance on specific tariff and contractual provisions in its Answer only further \nhighlights the inadequacies of its proposal.32 As Mr. Moaveni acknowledges, pre-operation \ntesting and certain routine inspections and further testing as required by Articles 6.1, 6.2 and \n9.7.4.6 do indeed operate to ensure that the control equipment operates as it should under the \nAppendix A Interconnection Service level.33 But this is an insufficient scope. First, as Mr. \nMoaveni continues to explain, “none of [the proposal terms] expressly requires  a dynamic \ndemonstration that, following a sudden reduction or loss of associated load, the facility can \nreduce its output to the load’s current withdrawal within the Transient Tolerance Window.”34 In \nother words, MISO’s proposed tariff fails to establish ZG-specific criteria or tests that confirm \nthat a resource’s equipment will actually limit injections in operation.35 Second, while it’s \ngenerally beneficial that some testing is required, there is no requirement to report such results to \n \n30 MISO Answer at 8-9. \n31 See generally Moaveni Testimony at 21-23. \n32 See MISO Answer at 9-10. \n33 Moaveni Testimony at 21. \n34 Id. at 22.  \n35 Moaveni Testimony at 21."},{"page":9,"startToken":2387,"endToken":2643,"text":"9 \nMISO.36 Indeed, as Mr. Moaveni notes, there is similarly no requirement to report actual, non-\ntesting injection events or control failures to MISO.37 This impermissibly leaves verification of \ncompliance with reliability requirements in the hands of ZG resources rather than the grid \noperator. \nIn short, without “the Tariff [] stat[ing] the zero-injection obligation as a measurable \nperformance criteria rather than as a general requirement to install suitable equipment … there is \nno assurance that the required equipment will perform as MISO’s studies assume.”38  \n3. MISO’s Limited Remedies for Injection and Equipment Failures Fails to\nProperly Incentivize Compliance with Performance Standards, Risking\nReliability Issues.\nAs Community Organizations and Clean Energy Advocates explained in Protest, MISO’s \nlack of remedies designed to incentivize ZG resources to ensure that their equipment will \nperform as required raises similar reliability issues as the lax verification measures.39 The \ncontractual remedy that MISO has proposed functions only as a “last-resort backstop,” offering \nno consequence other than termination and nothing that operates on the timescale of an injection \nevent.40 MISO relies on the pro forma generator interconnection agreement’s general default \nand termination framework instead of creating remedies tailored to deter or correct injections by \nZG resources.41 While termination may be an appropriate response to persistent or repeated \nfailures, termination alone is not an adequate option set as a remedy for noncompliance when \n36 Id. \n37 Id. at 22. \n38 Id. at 23.  \n39 Community Organizations and Clean Energy Advocates Protest at 7. \n40 Moaveni Testimony at 9.   \n41 Id."},{"page":10,"startToken":2643,"endToken":2939,"text":"10 \n \nthere are no intermediate remedies provided before that point, including remedies that can be \napplied to protection-scheme misoperations.42 \nAs Mr. Moaveni explains in his testimony, MISO’s proposal only begins to cover \nviolations of certain types of injections that could occur. Specifically, ZG resources may \ninadvertently inject power beyond their interconnection substations in three different situations: \nordinary tracking errors, contingency-driven transient exports, and control or protection \nfailures.43 Out of the three circumstances, control or protection failures involve the largest \ninjections and will continue until the controls recover or corrective action is taken.44 Yetthe \nFiling does not establish a ZG-specific monitoring, testing, or remedial framework for control or \nprotection failures.45 While the ZG Impact Assessment models a loss of load followed by a \nreduction within the Transient Tolerance Window, it does not model a sustained injection beyond \nit.46 Nor does the Filing contain automatic or graduated curtailment, suspension, or financial \nconsequence that would give customers an adequate incentive to maintain and correct injection-\nlimiting controls.47 Article 9.7.4.7(c)’s obligation to cease injection when triggered by the trip of \na transmission facility in the delivery path is also not enough to cure the deficiency in the Filing, \nas it is an operating requirement that responds to a system event, rather than a remedy for non-\ncompliance.48 In light of these serious risks, Community Organizations and Clean Energy \n \n42 Moaveni Testimony at 12. The article 17 cure period is not a substitute for intermediate remedies. Article 17 does \nnot impose a ZGIA-specific operating restriction while a cure is pending, nor does it provide an intermediate ZGIA-\nspecific remedy between cure and termination. \n43 Id. at 10.  \n44 Id. \n45 Id. \n46 Id. \n47 Id. \n48 Id. at 10-11."},{"page":11,"startToken":2939,"endToken":3278,"text":"11 \n \nAdvocates urge the Commission to direct MISO to include graduated penalties to incentivize \nbetter compliance with operational requirements. \nMISO answers that this docket is “not the appropriate vehicle” for considering penalty \nproposals, and states that it does not want to explore penalties here for certain types of generating \nfacilities and service types.49 But neither FERC nor stakeholders like Community Organizations \nand Clean Energy Advocates can rely on such vague intentions about future filings. And as it \nstands, the proposed new ZGIS put forth for FERC’s approval lacks proper incentives and \nrequirements for compliance that penalties could help remedy. As Mr. Moaveni explains, the \npenalties need not be limited to just penalizing exceedance of fixed interconnection service. 50 \nInstead, Mr. Moaveni recommends that MISO should tie penalties to the zero-injection \nprotection schemes on which the ZG interconnection service depends.51 In other words, MISO \ncan, within this proposal, establish penalties for control equipment failure that need not pre-judge \npenalty scheme consistency with future products yet to come.52 We note that MISO’s avoidance \nof penalties in this context is newfound. MISO’s own previous ZGIA proposal to its stakeholders \nin June 2026 demonstrated that penalties would be appropriate for ZG resources and ZGIS. In a \nproposal to its Large Load Working Group in June 2026, MISO stated that it would “monitor \neach ZGIA for injections and will consider substantive charges for any injections.”53  \n \n49 MISO Answer at 8. \n50 Moaveni Testimony at 15. \n51 Id. \n52 To the extent that specifically penalizing “unreserved use of the transmission system” would require a broader \nproceeding as MISO suggests in its Answer at 8, then Community Organizations and Clean Energy Advocates \nsuggest that a different solution is appropriate. It does not, however, mean that there is not a deficiency in the current \nproposal.  \n53 Moaveni Testimony at 12.. See also Consideration of Zero-Injection GIA, MISO Large Load Working Group (Jun. \n10, 2026), \nhttps://cdn.misoenergy.org/20260610%20LLWG%20Item%2005%20Market%20Participation%20and%20Registrati\non%20of%20Co-Located%20Load%20and%20Generation763097.pdf."},{"page":12,"startToken":3278,"endToken":3569,"text":"12 \n \nMISO’s Answer also relies heavily on the distinction between interconnection and \ntransmission service in order to minimize its proposal’s general permissiveness of violations of \nzero-injection requirements.54 For example, MISO states that the “ZGIS provides no general \nright to inject energy onto the Transmission System and does not convey Transmission \nService.”55 MISO also quibbles that the twenty-second limit is not an authorization to inject for \ntwenty seconds, but rather, the maximum interval “within which a project must satisfy the \napplicable study and operating requirements,” or potentially a shorter interval if determined by \nthe Business Practice manual.56 But this is still accurately—and perhaps more tellingly—\ndescribed as a potential twenty-second period in which there are not clear consequences to the \nZG resource for injecting, without adequate guarantee that there will not be reliability impacts as \na result.  The issue is not that ZGIS or the Transient Tolerance Window provides a right to inject \nonto the Transmission System, but that ZGIS does not adequately penalize ZG resources when \nthey do inject outside of or beyond the Transient Tolerance Window or adequately prevent them \nfrom doing so. The question is whether the Tariff attaches any operational consequence to \ninjections, outside of or beyond the Transient Tolerance Window, onto the Transmission System \nbeyond the substation.57 It does not. \nFinally, MISO invokes Order No. 845 in justifying its lack of penalties for unauthorized \ninjections here.58 But as Mr. Moaveni explains, the potential exceedance of interconnection \nservice level in other contexts that MISO discusses in its Answer is different than the ZG control \n \n54 See MISO Answer at 4, 6, 8. \n55 MISO Answer at 6. \n56 Id. at 12. \n57 See Moaveni Testimony at 14. \n58 MISO Answer at 8."},{"page":13,"startToken":3569,"endToken":3835,"text":"13 \n \nfailures that are at issue here.59 A conventional generating facility has a fixed interconnection \nservice level and went through an interconnection study where necessary Network Upgrades \nwere identified.60 A conventional generator’s exceedance of that level would be a departure from \na quantity that the system was studied to carry.61 In contrast, a ZG resource has no general right \nto export beyond the interconnecting substation and its permissible output is limited by the \nassociated load’s current withdrawal, which can change abruptly.62 As Mr. Moaveni explains, \n“[t]he loss of the associated load does not itself change the [ZG] resource’s dispatch instruction \non the seconds-scale of the Transient Tolerance Window, and the Filing caps the resource’s \nregistered operating limits at the load’s peak Demand rather than its current withdrawal.”63  \nCompliance depends on the injection-limiting scheme preventing a sustained export onto a \nsystem that was neither studied nor upgraded for it.64 Additionally, Order No. 845 “rested on the \nadequacy of existing interconnection agreement mechanisms for the exceedance it addressed,” \nbut those mechanisms—monitoring, testing, and verification—are what the ZGIA now leaves \nincomplete for a control failure.65  \nB. MISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of \nPotential Cost Shifts. \nCommunity Organizations and Clean Energy Advocates’ Protest explained two pathways \nthat the ZGIS process allows for costs associated with ZG resources and large loads to be \nsocialized more broadly: via the modeling overlaps between ZG and Definitive Planning Process \n \n59 Moaveni Testimony at 14. \n60 Id. \n61 Id. \n62 Id. \n63 Id. \n64 Id. at 15 \n65 Id."},{"page":14,"startToken":3835,"endToken":4134,"text":"14 \n \n(“DPP”) resources, and via the risk that ZG resources relied on as transmission alternatives to \nsupport new load might not materialize, and thus the transmission need would have to be met \nthrough MISO’s Transmission Expansion Process (“MTEP”). MISO’s Answer continues to \nimproperly assume that the definitional limits of ZGIS will prevent such cost issues—which Mr. \nMoaveni’s testimony explains in detail is not the case from an engineering perspective—and \nseems to misunderstand the concern related to crediting ZG resources as transmission \nalternatives. Despite these concerns, MISO also argues it should not yet be forced to provide \nenough transparency to detect potential cost shifts. The Commission should redirect MISO on \nthese points. \n1. MISO’s Reliance on the Limited Nature of ZGIS Does Not Justify Socialization \nof Upgrades to Address Cumulative Grid Impacts. \nAs Community Organizations and Clean Energy Advocates explained in Protest, the \ndifference in assumptions built into the baseline of the study models for ZGIA resources and the \nDPP force upgrades arising from cumulative impacts between the two processes to be resolved \nthrough MTEP, where costs are broadly socialized.66 MISO does not contest the differences \nbetween the models, nor how conflicts would be resolved.67 Instead, MISO suggests that that the \nlimits inherent to ZG service – namely peak load limits and the requirement to be at the same \nsubstation and voltage level – should generally serve to limit cumulative upgrade needs.68 But \nMISO’s assumption about ZG resources is not supported by evidence, and fails to otherwise \njustify socialization of costs that may nevertheless arise to cover upgrades to cover cumulative \nimpacts on the  grid resulting from the addition of ZGIA resources. \n \n66 Community Organizations and Clean Energy Advocates Protest at 24-26. \n67 Compare MISO Answer at 14, Moaveni Testimony at 29-30. \n68 MISO Answer at 14-15."},{"page":15,"startToken":4134,"endToken":4411,"text":"15 \n \nMISO’s assertion that the defining limits of ZG resources will prevent grid strain from \nthese resources does not withstand scrutiny. As Mr. Moaveni explains, “a generating facility \naffects the transmission system in ways that do not depend on whether it is exporting real \npower.”69 For example, “[a]n energized generator can contribute fault current to nearby buses \neven when it is not exporting real power.”70 This matters because the technology and grid \nfunctions that would address such issues – breaker interrupting capability and protection \ncoordination margins at nearby substations – are “a finite and shared capacity on which pending \nDPP projects also rely.”71 As a result, the double allocation of access to such resources between \nZGIA and DPP resources is not resolved by injection, substation or voltage requirements. And \nthis is just one example of potential cumulative impacts. As Mr. Moaveni’s testimony further \nexplains, merely “[p]reserving transfer capability therefore does not establish that ZG resources \nomitted from a DPP model, or DPP projects omitted from a ZGIA model, have no short-circuit, \nprotection, voltage, or dynamic interaction with one another.”72 \nThe Commission should reject the filing as deficient because both MISO’s filing and \nMISO’s Answer fail to either refute such cumulative impacts or justify their resolution in MTEP, \nwhich socializes costs to load more broadly. \n2. MISO’s Defense of the 5-Year Contract Terms Misunderstands the Nature of \nPotential Transmission Cost Shifts. \nMISO’s filing allows for ZG generating facilities to be credited as non-transmission \nalternatives, which recognizes that the proximate nature of the facilities and intent for the load to \n \n69 Moaveni Testimony at 30. \n70 Id. \n71 Id. at 31. \n72 Id. at 31-32."},{"page":16,"startToken":4411,"endToken":4773,"text":"16 \n \nbe served by the ZG generate can defer upgrades that would otherwise be needed to serve the ZG \nAssociated Load.73 But as Community Organizations and Clean Energy Advocates flagged in \nProtest, MISO’s filing contains no measures to backstop the cost and reliability issues this \nfavorable treatment would cause in the event that the generating facility fails to materialize or \nretires early.74 As Mr. Moaveni explains, this means that if a ZG resource does not materialize \nand thus causes the underlying transmission need to re-emerge, the resulting transmission \nupgrades that would still be needed to serve the associated load would be broadly socialized via \nMTEP.75 \nMISO’s Answer appears to either misunderstand this concern76 or choose not to address it \nbefore the Commission. Yet as Mr. Moaveni testifies, MISO has previously acknowledged that \n“[i]f ZGIA agreements are not met and upgrades become necessary, those costs are still allocated \nto the load in the Local Pricing Zone,” and that “MISO is not proposing any changes to cost \nallocation of either generation or transmission investments in its ZGIA efforts. Cost allocation \ncould be a component of the broader large load efforts taking place at the Large Load Working \nGroup.”77 While MISO may not be changing cost allocation per se, as Mr. Moaveni explains, the \nassociated large load in this situation would have already received the significant benefit of this \nproposal—namely, expedited connection to the grid.78 Moreover, the rapid emergence of \ntransmission needs in such a scenario might cause further complications and more expensive \n \n73 See Keyser Test. at 19 (explaining Attachment FF). See also Moaveni Testimony at 25-29. \n74 Community Organizations and Clean Energy Advocates Protest at 21-22. \n75 Moaveni Testimony at 26-27. \n76 See MISO Answer at 16, discussing the potential consequences of a ZG-associated load – rather than the \ngenerating resource – failing to become operational. See also MISO Answer at 17-18, which states that “deferred \nupgrades” concerns are mitigated by the limited nature of ZGIA service, but does not account for what happens if \nthe generator with ZGIA service no longer exists. \n77Moaveni Testimony at 26-27 (quoting April 15 Feedback Response at 8). \n78 Id. at 27-29."},{"page":17,"startToken":4773,"endToken":5042,"text":"17 \n \nupgrades that the proposal does not contemplate. As Mr. Moaveni concludes, MISO “provides no \nZGIA-specific means of addressing the timing, reliability, and cost consequences of a need that \nre-emerges when the arrangement on which MISO relied did not perform.”79 \n3. MISO Cannot Justify Exempting ZGIS from FERC’s Emphasis on \nTransparency to Prevent Large Load-Related Cost Shifts. \nCommunity Organizations and Clean Energy Advocates’ Protest explained that MISO’s \nproposal does not provide sufficient information to identify potentially deferred or shifted costs \nof transmission upgrades as a result of the large load associated with the ZG resource, and noted \nthis conflicts with FERC’s Show Cause Orders on large loads.80 MISO answers that its ZGIS \nproposal need not address all of the issues raised in the Show Cause Orders.81 While we do not \ndispute this assertion in its entirety, it is misplaced here. The Commission should not allow \nMISO to add new processes to the tariff that suffer from the same flaws that the Commission has \nalready found to be unjust and unreasonable—namely, lack of transparency surrounding cost \ncausation.  \nMISO further avers that the transparency measures requested by Community \nOrganizations and Clean Energy Advocates are not required of requests in the Definitive \nPlanning Phase, and that MISO does not propose to reduce any generally applicable transparency \nrequirement.82 As Mr. Moaveni explains, comparisons to other processes are not relevant. “The \nquestion is whether existing procedures allow anyone to trace the linkage this service creates \n \n79 Moaveni Testimony at 28. \n80 Community Organizations and Clean Energy Advocates Protest at 14-15. \n81 MISO Answer at 18. \n82 Id. at 17."},{"page":18,"startToken":5042,"endToken":5322,"text":"18 \n \nbetween a particular ZG resource, the load-serving transmission assumption made in reliance on \nit, and a later MTEP reconciliation.”83 \nNotably, MISO does not appear to contest the feasibility of requiring these greater \ntransparency requirements, nor their effectiveness in potentially elucidating cost allocation \nissues. In contrast, Mr. Moaveni confirms Community Organizations and Clean Energy \nAdvocates’ concerns, finding that “[t]o determine whether an upgrade identified in a later MTEP \ncycle resulted from assumptions made in the ZGIA process, a party would need the ZG study \nresults, the models and base-case vintage used, the upgrades deferred in reliance on the resource, \nand the operating history of that resource.”84 In the current proposal, none of that is required to \nbe public. In order to rectify this issue and align with the Commission’s concerns in the Show \nCause Order, Mr. Moaveni instead recommends that the Commission direct MISO to publish: the \nZG requests received in each quarterly study period, with megawatt quantity, technology, \nlocation, and status; the study reports and the base case used; the Network Upgrades identified \nand, separately, the upgrades deferred in reliance on each ZG resource; affected-system results; \nrequests rejected for requiring upgrades beyond the interconnecting substation; and an annual \nreport of injection events, control failures, and any enforcement actions.85  \nC. MISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall \nLimits on the ZGIA Process. \nAs Community Organizations and Clean Energy Advocates noted in Protest, MISO’s \nproposed ZGIA process differs from other Commission-approved interconnection fast tracks in \nlacking any program-wide limitations, such as a limited duration or aggregate megawatt or \n \n83 Moaveni Testimony at 39. \n84 Id. at 38-39. \n85 Id. at 39."},{"page":19,"startToken":5322,"endToken":5633,"text":"19 \n \nproject number cap.86 MISO’s Answer suggests that the quarterly study limit and the defining \nterms of ZGIS are sufficient limitations.87  \nHowever, MISO’s Answer fails to engage with the cumulative impacts that would grow \nin magnitude alongside ZGIS uptake. As Mr. Moaveni explains, “the Filing does not examine \nhow a growing share of generation dedicated to specific loads affects resource adequacy for the \nrest of the system.”88 Moreover, at a time in which the high cost of new entry continues to be \nprohibitively expensive and capacity prices continue to increase, this potential diversion of new \nentry, which is not examined in the filing, raises key questions for both resource adequacy and \njust and reasonable electricity and capacity rates. MISO’s answer, which dismisses an aggregate \ncap as unnecessary because the amount of ZGIS for each ZG resource is limited to the peak \ndemand of its associated load,89 fails to grapple with either of these critical considerations. \nWith regard to the lack of a temporal limit on the ZGIA process – which MISO’s Answer \nseems to ignore, considering only the suggestion for term-limited individual ZGIS rights —any \nreliability issues that do arise will be harder to address if the program is put into place \npermanently, as a follow-up Section 205 or 206 proceeding would be required. As Mr. Moaveni \nexplains, approving ZGIA as a time-limited process, much like MISO ERAS, “would permit the \nCommission and stakeholders to observe how many resources actually use the pathway, whether \nthe injection limits hold in operation, and whether upgrades are later identified in transmission \nplanning that were not anticipated in the interconnection studies, before the service becomes a \npermanent feature of the Tariff.”90 \n \n86 Community Organizations and Clean Energy Advocates Protest at 16-18. \n87 MISO Answer at 19. \n88 Moaveni Testimony at 44. \n89 MISO Answer at 19. \n90 Moaveni Testimony at 44."},{"page":20,"startToken":5633,"endToken":5876,"text":"20 \n \nCommunity Organizations and Clean Energy Advocates therefore reiterate their request \nthat the Commission find the filing is deficient absent program-wide limits to appropriately \nnarrowly tailor this process.91 \nD. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource \nParticipation, But the Commission Should Order Broader Confirmation via \nCompliance Directive or Deficiency Notice. \nIn our initial Protest, Community Organizations and Clean Energy Advocates sought \nclarification on the rules governing participation of hybrid resources as ZG resources.92 We \nappreciate the clarifications in MISO’s Answer,93 and particular MISO’s openness to a \ncompliance directive to clarify that the term “firm interconnection service” is intended to refer to \ndeliverability.94 However, the Commission should issue a broader directive to confirm the other \npoints under discussion in the tariff as well. \nSuch further action is necessary because although though MISO’s Answer states that \ncharging behavior would be studied as part of the ZG Impact Assessment “consistent with \nMISO’s treatment of charging in the DPP study process,”95 as Mr. Moaveni explains, the current \nexplanation differs from MISO’s stakeholder explanation that storage charging “is not considered \nduring the interconnection queue process.”96 Moreover, even if MISO’s current statement were \ntaken at face value, Mr. Moaveni notes four areas of uncertainty that such a framework would \n \n91 Community Organizations and Clean Energy Advocates Protest at 16-18. \n92 Id. at 26-27. \n93 MISO Answer at 20-21. \n94 Id. at 21. \n95 Id. at 20. \n96 Moaveni Testimony at 41."},{"page":21,"startToken":5876,"endToken":6093,"text":"21 \n \ncreate for hybrid resources, “where the defining constraint is the relationship between generation \noutput and a specific load.”97 These include: \n“ (1) whether energy used to charge the storage component from the co-located generation \nconstitutes a withdrawal requiring transmission service;  \n(2) whether charging from the Transmission System increases the Demand of the ZG \nAssociated Load and therefore the permissible level of ZG Interconnection Service under \nSection 3.11(v);  \n(3) how a charging storage component is represented in the load-trip stability case required \nby Section 3.2.5.2.1, given that a charging battery is itself a load that can be lost; and  \n(4) how charging energy is metered and settled where the resource and the load must be \nmetered separately.”98  \nAs Mr. Moaveni concludes, “these questions are material to project design, study \ntreatment, and commercial evaluation.”99 As such, FERC should require MISO to provide this \nfurther clarity on critical hybrid resource eligibility in the tariff. \nCONCLUSION  \nTo effectuate MISO’s zero injection concept without raising the risk of adverse reliability \nevents and cost shifts, Community Organizations and Clean Energy Advocates respectfully ask \nthe Commission to use its authority to direct MISO to cure the deficiencies with filing before \naccepting it. \n \n \n \n \n \n \n \n \n \n97 Moaveni Testimony at 40. \n98 Id.at 40-41. \n99 Id. at 41."},{"page":22,"startToken":6093,"endToken":6233,"text":"22 \n \nDATED: October 8, 2026 \n \n \n \nRespectfully submitted, \n \n \n/s/ Sameer H. Doshi \n \nSameer H. Doshi \nAda Statler \nChristine Powell \nAaliyah Adkins \nEarthjustice \n311 S. Wacker Dr., 14th Floor \nChicago, IL 60606 \nsdoshi@earthjustice.org \nastatler@earthjustice.org \ncpowell@earthjustice.org \naadkins@earthjustice.org \n \nAttorneys for Michigan Environmental \nJustice \nCoalition and Community Collaboration on \nClimate Change \n \nKareem Scales \nCo-Chair \nCommunity Collaboration on Climate \nChange \nGrand Rapids, MI \nkareem@c4gr.org \n \nWesley Watson \nPolicy Associate \nMichigan Environmental Justice Coalition \n1401 W. Fort St., P.O. Box 44080 \nDetroit, MI 48233 \nwesley@michiganej.org\n \n/s/ Jonah Baskin. \n \nJonah Baskin \nAssociate Attorney \nSierra Club Environmental Law Program \n50 F Street NW, Eighth Floor \nWashington, DC 20001 \njonah.baskin@sierraclub.org \n \n   \n/s/ Natalie McIntire \n \nNatalie McIntire \nSenior Advocate \nNatural Resources Defense Council \n20 North Wacker Drive, Suite 1600 \nChicago, IL 60606 \nnmcintire@nrdc.org \n(312) 995-5907"},{"page":23,"startToken":6233,"endToken":6290,"text":"23 \n \nCERTIFICATE OF SERVICE \nI hereby certify that the foregoing has been served in accordance with 18 C.F.R. § \n385.2010 upon each party designated on the official service list in this proceeding by email. \n \n \nDATED: October 8, 2026 \n \n \n \n \n/s/ Ada Statler  \nAda Statler \nEarthjustice \n180 Steuart St. #194330  \nSan Francisco, CA 94105 \nastatler@earthjustice.org"},{"page":24,"startToken":6290,"endToken":6307,"text":"ATTACHMENT A \n \n \nTestimony of Houtan Moaveni in Support of the Protest of  \nCommunity Organizations & Clean Energy Advocates"},{"page":25,"startToken":6307,"endToken":6348,"text":"ATTACHMENT A CONTENTS: \n \nTestimony………………………………………………………………………...……………….1 \nIntroduction……………………………………………………………...………………………1 \nSummary of Findings……………………………………………………………………………3 \nEnforceability of the Operating Requirements………………………………………………….7 \nModeling Assumptions and Cost Allocation……………………………………………..……25 \nEligibility and Limitations on the ZGIA Process……………………………………………...40 \nConclusion……………………………………………………………………………………..45 \n \nCurriculum Vitae of Houtan Moaveni………………………………………………………...46 \nVerification……………………………………………………………………………………...47"},{"page":26,"startToken":6348,"endToken":6572,"text":"1 \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n) \n \nMidcontinent Independent System \nOperator, Inc. \n) \nDocket No. ER26-3552-000 \n \n) \n \n \nTestimony of Houtan Moaveni in Support of the Protest of Community Organizations and \nClean Energy Advocates \nI.  Introduction \nQ. Please briefly summarize your qualifications. \nA. My name is Houtan Moaveni. I am a Vice President at Grid Strategies LLC, where I advise on \nenergy policy, siting and permitting, transmission planning, and generation interconnection. I am \nan electrical engineer by training, with a Bachelor of Science in Electrical Engineering from the \nUniversity of Tehran and a Master of Science in Energy Management and Policy from École \nNationale Supérieure des Mines de Paris. \nI have nearly 19 years of experience in the energy sector. I was the founding Executive Director \nof the New York State Office of Renewable Energy Siting (ORES) and, before that, Director of \nFacility Certification and Compliance at the New York State Department of Public Service (DPS), \nwhere I worked with the transmission owners and the New York Independent System Operator on \ntransmission planning and major transmission projects. At the New York State Energy Research \nand Development Authority (NYSERDA), I served as the state’s interconnection ombudsman and \nco-chaired its interconnection policy working group. Earlier, at the New York Power Authority \n(NYPA) and the Florida Solar Energy Center (FSEC), I worked on transmission system operations,"},{"page":27,"startToken":6572,"endToken":6883,"text":"2\ngrid impact modeling, and generation interconnection, including the integration of inverter-based \nresources on distribution and transmission networks. \nMy curriculum vitae is attached to this testimony as Attachment HM-1. I submit this testimony in \nsupport of the Protest of Community Organizations and Clean Energy Advocates. Unless \notherwise noted, the statements in this testimony are based on my personal knowledge. \nQ. What is the purpose of your testimony? \nA. The purpose of my testimony is to evaluate the Zero Injection Generator Interconnection \nAgreement (“ZGIA”) construct that the Midcontinent Independent System Operator, Inc. \n(“MISO”) filed on August 18, 2026, from the perspective of interconnection process design, \ntransmission planning, and queue management.1 I address five questions: whether the zero-\ninjection obligation that justifies expedited treatment is enforceable; whether the proposal \nestablishes cost responsibility when MISO relies on a ZG resource in transmission planning, and \nwhether its study assumptions are adequate to capture cumulative effects and appropriately assign \nresponsibility for later-identified upgrades; whether it provides sufficient transparency to identify \nlater-arising costs; whether it resolves how storage paired with generation will be treated; and \nwhether it contains limiting principles appropriate to a permanent expedited service. My testimony \ntakes into account MISO’s September 23, 2026 Answer to the protests and comments.2 \n \n1Midcontinent Independent System Operator, Inc., Zero Injection Generator Interconnection Agreement, Docket No. \nER26-3552-000 (Aug. 18, 2026) (“Filing”). Citations to the transmittal letter are to its internal pagination and appear \nas “Transmittal at __.” Citations to the Prepared Direct Testimony of Marc Keyser, submitted as Tab C to the Filing, \nappear as “Keyser at __.” Citations to proposed Tariff provisions are to the clean Tariff sheets submitted as Tab B. \n2 Motion for Leave to Answer and Answer of the Midcontinent Independent System Operator, Inc., Docket No. \nER26-3552-000 (Sept. 23, 2026) (“MISO Answer”). Page citations to the MISO Answer are to the pages of the filed \nPDF."},{"page":28,"startToken":6883,"endToken":7152,"text":"3\nA properly designed zero-injection interconnection service could facilitate generation dedicated to \nserving new load and avoid unnecessary transmission construction, and MISO narrowed the \nproduct in several respects during its stakeholder process. The question is whether the Filing, as \nsubmitted, contains the enforceable operating requirements, cost protections, study safeguards, and \nlimiting principles that a permanent expedited service requires. In several material respects, it does \nnot. \nII.  Summary of Findings \nQ. Please summarize MISO’s proposed new form of interconnection service. \nA. MISO proposes a new form of interconnection service, ZG Interconnection Service, for a \ngenerating facility that connects at the same voltage level of the same substation as a Point of \nWithdrawal of an identified load, and that serves only that load.3 The amount of interconnection \nservice is capped at the total Demand of the associated load, although installed nameplate capacity \nis not capped.4 ZG Interconnection Service provides no general right to inject onto the \nTransmission System beyond the interconnecting substation, and the resource cannot require \nNetwork Upgrades beyond that substation other than System Protection Facilities. Following a \nreduction or loss of associated load, however, the Tariff permits a Transient Tolerance Window (a \nspecified length of time) within which the resource must reduce its output to the applicable level.5 \nRequests are studied serially, on a first-come, first-served basis, in quarterly study periods limited \nto ten Interconnection Requests each, with an impact assessment that MISO expects to complete \n \n3Proposed Generator Interconnection Procedures (“GIP”) § 3.2.5.1; § 3.11(ii). \n4GIP § 3.11(v); Keyser at 9–10. \n5GIP § 3.2.5.1(1)–(2); § 3.11(iii)."},{"page":29,"startToken":7152,"endToken":7420,"text":"4\nwithin ninety days, leading to an executed agreement.6 The service is permanent. Netting is \nprohibited, and the associated load remains firm network load that pays for transmission and \nancillary services on a gross basis.7  \nQ. Please summarize your findings regarding MISO’s proposed ZG Interconnection Service. \nA. Based on my review of the Filing, I have identified the following issues: \n1. The Filing does not establish a complete, graduated enforcement regime specific to the zero-\ninjection obligation that justifies expedited treatment. The ZGIA provisions establish no \ninjection-specific penalty, no ZGIA-specific telemetry performance standard, no required \nload-rejection test or acceptance criterion for the obligation to reduce output within the \nTransient Tolerance Window, no ZGIA-specific retesting interval, and no reporting \nrequirement for injection events or control failures, and they do not address repeated \nexcursions within the permitted tolerance window. The agreement instead relies on its general \nbreach, cure, and termination provisions and does not establish intermediate consequences \ncalibrated to the severity or recurrence of injection events. As a result, the Filing does not \nprovide the tools needed to detect, correct, and deter a failure of the injection-limiting controls. \nSuch a failure would allow exports beyond the permitted tolerance, which could create \nreliability problems for other customers on the system. \n2. The operative injection tolerance is delegated in material part to the Business Practices Manual \nfor Large Load, which is not filed with the Commission. The Filing ties the twenty-second \nceiling to the length of MISO’s transient stability study and to commercial practicality, but \n \n6 GIP § 3.11.2; Keyser at 18; Transmittal at 15. \n7Transmittal at 8, 18."},{"page":30,"startToken":7420,"endToken":7730,"text":"5\ndoes not demonstrate that injections lasting that long are acceptable under the relevant \noperating conditions. While the Tariff establishes twenty seconds only as an outer ceiling, the \ncriteria determining when a shorter operative window applies are left to that manual, which \nleaves unresolved how those criteria will be applied. \n3. The Filing leaves cost responsibility unresolved when MISO relies on a ZG resource in \ntransmission planning. A ZG resource may be credited as a Non-Transmission Alternative that \ndefers upgrades otherwise needed to serve the associated load. If the resource fails to \nmaterialize, retires early, or becomes permanently unavailable, the deferred need may re-\nemerge in a later transmission expansion planning cycle, and MISO has stated that the resulting \ncosts would be allocated to load in the Local Pricing Zone. Depending on how the project is \nclassified under MISO’s planning and cost-allocation rules, the same or substantially the same \ncustomers may have borne those costs had the load entered service without a ZG resource, so \nthe ZGIA does not necessarily change who pays. What it changes is when, and on what terms, \nthe need is addressed. If the resource is lost after the load is in service, the need re-emerges \nwhen the Filing’s principal express remedy for pre-service non-performance, a discretionary \ndelay of the load’s in-service date, no longer applies. The Filing contains no mechanism to \nrecord the deferred need, tie it to the ZG arrangement, or address the reliability and cost \nconsequences if the planning assumption fails. \n4. The study process does not capture certain cumulative effects of ZG resources and projects in \nthe standard interconnection queue. ZGIA studies exclude pending Interconnection Requests \nwithout executed agreements, and the Definitive Planning Phase (DPP) base case is not \nupdated for ZGIAs approved mid-cycle. Because an energized generator can affect short-\ncircuit duty, protection coordination, voltage performance, and dynamic behavior whether or"},{"page":31,"startToken":7730,"endToken":8002,"text":"6\nnot it exports real power, projects in each track may be found acceptable against models that \nomit the other. In effect, a ZG resource can contribute to short-circuit duty and reduce the \nbreaker interrupting and protection-coordination margin at nearby substations on which \npending DPP projects, including requests submitted before the ZG request, may also rely. As \na result, problems such as overdutied breakers or miscoordinated protection may be identified \nonly through a later reconciliation or planning study, after the ZGIA has been executed. The \nFiling provides no ZGIA-specific mechanism for determining and assigning responsibility for \nan interconnection-related upgrade identified later because of the combined effects of the ZG \nresource and pending DPP projects. An executed agreement from MISO’s Expedited Resource \nAddition Study (ERAS) process, which the Filing uses as its model, shows how this study \narchitecture operates. Its prior-queue accounting is defined to reach only other requests within \nthe same expedited pathway, and in that agreement it is empty. \n5. The proposal does not require MISO to publish the study results, base-case information, and \nupgrade information needed to trace whether a later transmission need is related to assumptions \nmade in the ZGIA process. Without that information, the cost consequences described above \nwould be difficult for the Commission or stakeholders to detect. \n6. Although paired generation-and-storage configurations are facially eligible for ZG \nInterconnection Service, the Tariff does not state how storage charging is treated for \ninterconnection study, service-cap, metering, and transmission service purposes. These \nunresolved issues create practical uncertainty for paired generation-and-storage projects and \nmay complicate or discourage use of the ZGIA pathway by resources that are otherwise well \nsuited to it."},{"page":32,"startToken":8002,"endToken":8231,"text":"7\n7. The proposal establishes a permanent parallel interconnection process whose only cumulative \nlimit is a quarterly study-throughput cap. There is no sunset, no aggregate project cap, no \naggregate megawatt cap, no locational concentration limit, and no required transition into the \nstandard process. As a result, the reliability and cost effects described in this testimony can \naccumulate over time without any required point at which the Commission reviews operating \nexperience and revisits the construct. \nEach of these issues can be addressed. I recommend that the Commission require MISO to cure \nthe deficiencies in its proposal by placing the essential operating standards and graduated remedies \nfor injection events in the Tariff; addressing the consequences if a resource relied on to defer \nupgrades is lost; requiring cumulative study models and defined restudy triggers; publishing the \ninformation a reconciliation would require; clarifying the treatment of storage charging in the \nTariff and explaining how resource adequacy accounts for ZG resources; and adopting an initial \nsunset or aggregate cap. \nIII.  Enforceability of the Operating Requirements \nQ. What measures does MISO propose to ensure that resources with ZGIAs comply with the \noperating requirements? \nA. MISO proposes the following: \n1. A study requirement: The ZG Impact Assessment reviews the proposed configuration, the \nelectrical connection between the generating facility, the associated load, and the Transmission \nSystem, and “the proposed control equipment and/or operating procedures” to determine"},{"page":33,"startToken":8231,"endToken":8588,"text":"8\nwhether these are sufficient to prevent injections beyond the interconnecting substation. The \nstability and steady-state analyses include a case in which the associated load trips offline.8 \n2. Equipment obligations in the agreement: The interconnection customer must install \ncommunications and monitoring equipment enabling it to monitor the demand of the associated \nload; install equipment enabling it to reduce injections to a level not exceeding that demand \nwithin the Transient Tolerance Window; and cease all injection within that window if any \ntransmission facility over which energy must flow to reach the associated load trips offline. \nThe equipment is identified in Appendix A to the agreement.9 MISO has agreed that this \nobligation is intended to be measured against the “amount of Energy currently being withdrawn \nby the ZG Associated Load,” rather than the load’s peak Demand, and has offered to revise \nArticle 9.7.4.7 and the definition of the Transient Tolerance Window accordingly on \ncompliance.10 \n3. A tolerance window: The Transient Tolerance Window “shall be no greater than 20 seconds, \nand is further described by the Business Practices Manual for Large Load,” and is subject to \nTransmission Owner local planning criteria.11 \n4. Metering and registration: The resource must be metered separately from the associated load, \nand a resource larger than 5 MW must register and participate in MISO’s markets as a \nGeneration Resource, Electric Storage Resource, or Dispatchable Intermittent Resource before \ncommercial operation.12 \n5. Market offer limits: Seven Module A limit definitions are revised to provide that a ZG \nresource’s maximum operating level shall be less than the Demand of its associated loads.13 \n6. Testing provisions: The agreement carries forward the pro forma testing articles. Article 6.1 \nrequires pre-operation testing of the Interconnection Customer’s System Protection Facilities, \nincluding control equipment used to limit injection to the service level stated in Appendix A, \n \n8GIP § 3.2.5.2.1. \n9Proposed Attachment X, Appendix 19 (“ZGIA”), art. 9.7.4.7. \n10 MISO Answer at 22. \n11Proposed Module A, definition of “Transient Tolerance Window.” \n12ZGIA arts. 7.1, 7.1.1; proposed Module C § 38.2.2. \n13 Transmittal at 17–18."},{"page":34,"startToken":8588,"endToken":8919,"text":"9\nand provides that similar testing may be required after initial operation; Article 6.2 requires \nroutine inspection and testing in accordance with Good Utility Practice; and Article 9.7.4.6 \nrequires calibration and functional trip tests of System Protection Facilities before the In-\nService Date and Commercial Operation Date, at intervals suggested by Good Utility Practice, \nand following any apparent malfunction.14 \n7. A contractual remedy: The agreement incorporates the breach, cure, and termination provisions \nof MISO’s pro forma Generator Interconnection Agreement. Under Article 17, a non-\nbreaching Party gives notice of a breach; the breaching Party has thirty days to cure, or up to \nninety days if the cure cannot be completed sooner; and if the breach is not cured, the non-\nbreaching Party terminates the agreement, subject to any required notice filing with the \nCommission.15 The agreement adds no injection-specific or graduated consequence of its own. \nQ. What is the likely effectiveness of these measures, and what risks remain? \nA. The proposed measures do not provide adequate assurance that the zero-injection obligation \nwill be met, in three respects. First, the only express remedy for an injection-limiting scheme that \nfails to perform is the agreement’s general breach, cure, and termination framework, which \noperates on a timescale of weeks to months and offers nothing between a cure demand and \ntermination. Second, the criteria that determine whether a given transient injection is permitted or \nis a violation are left to a Business Practices Manual rather than stated in the Tariff, and the Tariff \ndoes not specify the control performance, or the coordination with ride-through requirements, \nneeded to meet them. Third, although the Filing requires equipment testing, it does not require the \ndynamic load-rejection demonstration, ZG-specific ongoing performance criteria, or event \nreporting needed to confirm that the injection-limiting scheme performs as assumed. I address each \nin turn. \n \n14 ZGIA arts. 6.1, 6.2, 9.7.4.6. \n15 ZGIA arts. 17.1.1, 17.1.2, 2.3.3."},{"page":35,"startToken":8919,"endToken":9206,"text":"10 \nQ. How does the proposed contractual remedy, without additional measures, function to \nensure compliance with the operating requirements? \nA. The proposed contractual remedy functions only as a last-resort backstop. It offers no \nconsequence short of termination, and nothing that operates on the timescale of an injection event. \nThe Filing relies on the pro forma generator interconnection agreement’s general default and \ntermination framework rather than on a remedy designed to deter or correct injections by ZG \nresources. To see why that matters, it helps to distinguish the ways in which a ZG resource can \ninject power beyond its interconnecting substation. \nMISO refers generally to “inadvertent” or “unintended” injections, but those terms cover three \ndifferent situations: ordinary tracking error, contingency-driven transient export, and control or \nprotection failure. In an ordinary tracking error, generation briefly exceeds contemporaneous load \nby a small margin during normal operation. In a contingency-driven transient export, the associated \nload trips or drops sharply and the generating facility has not yet reduced its output. In a control \nor protection failure, the injection-limiting scheme does not arrest the export within the permitted \nwindow. These situations differ in likelihood and consequence, as well as in how they are detected \nand in the appropriate response. MISO’s proposed Transient Tolerance Window addresses \ncontingency-driven transient export, and the proposed offer administration process addresses, at \nmost, part of ordinary tracking error. No ZGIA-specific provision directly addresses the third \nsituation, in which the facility continues exporting beyond the permitted tolerance because the \nmechanism intended to limit that export did not perform as expected. \nThe situation in which exports continue beyond the tolerance window because a control \nmechanism fails is the situation in which a remedy matters most, for three reasons. First, it involves"},{"page":36,"startToken":9206,"endToken":9525,"text":"11 \nthe largest injection, because absent a working scheme the facility’s full output can flow onto the \nTransmission System rather than the small margin of a tracking error. Second, it is not necessarily \nself-limiting; a transient export ends when the controls act, while a control failure can persist \nbeyond the permitted window until the controls recover or corrective action is taken. Third, it is \nthe situation the studies did not evaluate, since the ZG Impact Assessment models a loss of load \nfollowed by a reduction within the Transient Tolerance Window, not a sustained injection beyond \nit. \nYet the Filing does not establish a ZG-specific monitoring, testing, or remedial framework for \ncontrol failures. The ZGIA provisions contain no automatic or graduated curtailment, suspension, \nor financial consequence tied to an unauthorized injection that would give ZG customers a \ncontinuing incentive to maintain and correct their injection-limiting controls. The only contractual \nbackstop is the agreement’s general breach-and-cure framework, which operates on a thirty- to \nninety-day timescale suited to contractual defaults and, if the breach is not cured, leads to \ntermination. Nor does Article 9.7.4.7(c) fill that gap. Its obligation to cease injection is triggered \nby the trip of a transmission facility in the delivery path; it is an operating requirement that \nresponds to a system event, not a remedy for non-compliance. \nTermination, standing alone, is not a workable remedy for operating non-compliance. A ZG \nresource is by design dedicated to serving its associated load, and the Filing requires the associated \narrangement to state an expected term of at least five years. Terminating the interconnection \nagreement would eliminate the generator’s interconnection rights and leave the associated load’s \nfull demand dependent on network service. Without intermediate measures, termination provides \nno means of correcting an isolated or remediable control failure, and its consequences fall on the \nassociated load as well as on the party whose equipment failed to perform. The injection-limiting"},{"page":37,"startToken":9525,"endToken":9804,"text":"12 \nscheme must act whenever the load’s withdrawal falls, not only when the load trips entirely, and \ntermination removes the load’s dedicated supply for the remainder of the term, long after the event \nthat triggered it. \nTermination can also create an immediate planning and operating challenge. Because the \nassociated load remains firm network load, termination requires its full demand to be supplied \nfrom the Transmission System; where facilities have been deferred in reliance on the ZG resource \nand are not yet in service, MISO may need interim operating measures or accelerated construction, \nas discussed in Section IV. Termination may well be the appropriate response to persistent or \nrepeated failure, but the Filing offers nothing before that point. Intermediate remedies should be \navailable and applied proportionately to an isolated protection-scheme misoperation, repeated non-\ncompliance, and persistent failure. Those intermediate measures could include a ZGIA-specific \ncure period during which operating restrictions apply, mandatory load-rejection retesting after an \ninjection event, temporary suspension pending correction, financial consequences for \nunauthorized injections, and escalation for repeated events, with termination reserved for the end \nof that sequence. \nThe Article 17 cure period is not a substitute. It is not clear that a single injection event, once it \nhas ended, is a Breach that can be cured in the Article 17 sense. If it is treated as cured once the \nscheme is restored, Article 17 itself imposes no injection-specific consequence for the completed \nevent; if it is treated as a Breach that is not capable of being cured, Article 17 provides that the \nnon-breaching Party “shall terminate” the agreement.16 Either way, Article 17 does not impose a \n \n16 ZGIA arts. 17.1.1, 17.1.2."},{"page":38,"startToken":9804,"endToken":10067,"text":"13 \nZGIA-specific operating restriction while a cure is pending or provide an intermediate remedy \nbetween cure and termination. \nExisting reliability standards do not fill this gap either. Protection-system misoperation reporting \nasks whether a protection scheme operated as it was designed to operate. It does not ask whether \nthe scheme achieved the zero-injection obligation on which ZG Interconnection Service is \npremised. A protection system can perform exactly as engineered and still permit injections \ninconsistent with the terms of the interconnection service. \nIntermediate compliance measures of this kind are feasible. Indeed, MISO described a more \ncomplete compliance regime to stakeholders than the one in the Filing. When previewing the \nproposal to the Large Load Working Group in June 2026, MISO stated that “MISO will monitor \neach ZGIA for injections and will consider substantive charges for any injections; injecting more \nenergy than the resource interconnection service limit can be cause for termination of the \ninterconnection agreement.”17 Of the three elements in that sentence, only the last appears in the \nproposed Tariff. The ZGIA provisions impose no express obligation on MISO to monitor ZG \nresources for injections and establish no injection-specific charge. Narrowing a proposal after \nstakeholder review is not unusual. The point is that MISO itself identified monitoring, and a \nconsequence short of termination, as appropriate components of this construct. The Tariff should \nestablish that compliance framework rather than relying solely on the agreement’s general default \nprovisions. \n \n17MISO, Consideration of Zero-Injection GIA: Market Participation and Registration of Co-Located Load and \nGeneration (PAC-2024-4B), Large Load Working Group, at 8 (June 10, 2026) (“June 10 LLWG Presentation”)."},{"page":39,"startToken":10067,"endToken":10398,"text":"14 \nMISO has itself considered a graduated regime for a closely analogous large-load obligation. In \nits August 12 presentation on non-firm transmission service, MISO stated that it “is evaluating \nappropriate consequences for failure(s) to curtail including forced remote disconnect, financial \npenalties, or suspension/revocation of service.”18 That is substantially the escalation structure I \nrecommend here. \nThe Commission has required analogous graduated measures in PJM for co-located load. The \nCommission directed PJM to establish penalty charges and other remedial action for unreserved \nuse of the transmission system and later found that both operational and financial consequences \nwere necessary. Under the framework the Commission accepted with modifications, a first \nmisoperation of the required control technology results in suspension of service for up to 120 days, \na second results in termination of the transmission service agreement, and unreserved use is subject \nto financial penalties.19 A graduated structure reflects that a control scheme that misoperates once, \na scheme that misoperates repeatedly, and a customer that declines to follow a directive present \ndifferent problems. The Filing does not establish comparable graduated ZGIA-specific remedies. \nMISO’s Answer responds that the Commission declined in Order No. 845 to adopt generic \nfinancial penalties for exceeding the interconnection service limits established in interconnection \nagreements, and that any future penalty framework should apply to all interconnection agreements \nrather than to ZG resources alone.20 MISO also objects to characterizing unauthorized ZG \ninjections as “unreserved use,” on the ground that the unreserved-use provisions of Module B \n \n18 MISO, Non-Firm Large Load (LLWG-2026-5), Large Load Working Group, at 12 (Aug. 12, 2026) (“August 12 \nNon-Firm Presentation”). \n19PJM Interconnection, L.L.C., 193 FERC ¶ 61,217, at P 212 (2025); PJM Interconnection, L.L.C., Order on \nRehearing, Clarification, Compliance Filing, and Paper Hearing, 195 FERC ¶ 61,209, at PP 515–516, 523, 529 (2026).   \n20 MISO Answer at 8 & n.44 (quoting Reform of Generator Interconnection Procedures and Agreements, Order No. \n845, 163 FERC ¶ 61,043, at PP 416–417 (2018))."},{"page":40,"startToken":10398,"endToken":10723,"text":"15 \nconcern Transmission Service rather than Interconnection Service.21 However, the label is not \nwhat matters. Whether an unauthorized injection is called unreserved use or something else, the \nquestion is whether the Tariff attaches any operational consequence to the failure of the premise \non which the service was granted, and it does not. MISO’s own proposal defines the service by \nthat premise. ZG Interconnection Service is available only if the study determines that the \ninterconnection “will not result in any injections of Energy onto the Transmission System beyond \nthe substation,” and the resource is studied outside the Definitive Planning Phase, without Network \nUpgrades beyond the substation other than System Protection Facilities, on that basis.22 \nFrom an engineering perspective, the exceedance MISO invokes from Order No. 845 differs from \na ZG control failure in an important respect. A conventional generating facility has a fixed \ninterconnection service level, stated in megawatts in Appendix A, for which the interconnection \nwas studied and any necessary Network Upgrades were identified. An exceedance of that level is \na departure from a quantity the system was studied to carry. A ZG resource, by contrast, has no \ngeneral right to export beyond the interconnecting substation; its permissible output is dynamically \nlimited by the associated load’s current withdrawal, subject to the Transient Tolerance Window, \nand that limit can change abruptly when the load trips or reduces consumption. The loss of the \nassociated load does not itself change the resource’s dispatch instruction on the seconds-scale of \nthe Transient Tolerance Window, and the Filing caps the resource’s registered operating limits at \nthe load’s peak Demand rather than its current withdrawal.  \nCompliance with the obligation therefore depends on the injection-limiting scheme acting within \nseconds; the ordinary market process is not the mechanism that prevents a transient from becoming \n \n21 MISO Answer at 8 & n.42 (citing Tariff, Module B, §§ 13.7, 14.5, 27A.1.6, 27A.2.4). \n22 Proposed GIP § 3.2.5.1."},{"page":41,"startToken":10723,"endToken":11026,"text":"16 \na sustained export onto a system that was neither studied nor upgraded for it. That is why the Filing \nrequires equipment rather than offers to enforce the limit, and why the failure of that equipment is \na failure of the assumption on which the service was granted rather than an incremental exceedance \nof a studied level. \nThat distinction also answers MISO’s consistency argument. The measures I recommend are not \npenalties for exceeding a fixed interconnection service level. They are consequences tied to failure \nof the control scheme on which ZG Interconnection Service depends: retesting after an event, \ntemporary operating restrictions or suspension while the scheme is corrected, and escalation for \nrepeated failure. A conventional generator may also use plant controls to remain within a fixed \ninterconnection limit, but that is not the same event-driven obligation to respond within seconds \nto the loss or reduction of a specific associated load, and nothing in my recommendation would \napply to it.  \nThe framework the Commission accepted for co-located load in PJM is keyed the same way, to \nthe misoperation of required control technology rather than to the existence of capacity above a \nservice level. Order No. 845, moreover, rested on the adequacy of existing interconnection-\nagreement mechanisms for the exceedance it addressed. For the reasons described above and in \nthe discussion of verification below, those mechanisms are what the ZGIA leaves incomplete for \na control failure, and termination alone is an impractical response when it would leave the \nassociated load’s full demand dependent on network service. My recommendation is also not \nsolely a financial penalty. It is a graduated response to failure of the operating premise — \ncorrective action, retesting, operating restrictions or suspension, and escalation for repeated failure \n— of the kind MISO itself described to stakeholders for ZGIAs and for its companion non-firm \nservice proposal."},{"page":42,"startToken":11026,"endToken":11322,"text":"17 \nQ. To what extent are the provisions governing the operative standard for the Transient \nTolerance Window effective? \nA. Only in part. The standard that determines whether an injection is permitted is not in the Tariff, \nand the Tariff does not specify what a resource must do to stay within it. The Module A definition \nestablishes twenty seconds as a ceiling. The operative provision is broader, because GIP § \n3.2.5.1(1) exempts transient injections that “remain within any Transient Tolerance Window \nestablished in the Business Practices Manual for Large Load.” The load-trip stability case is \nlikewise run against the window “established in the Business Practices Manual,” as is the \nprotection carve-out in the agreement.23 MISO states that the manual may only shorten the twenty-\nsecond ceiling, and that the manual “will identify the circumstances in which a shorter interval \napplies.”24 Those criteria determine whether a transient injection remains within the permitted \noperating tolerance at a particular location, and they were not filed with the Commission. \nThere are two separate questions about the Transient Tolerance Window: what the twenty-second \ninterval establishes operationally, and where the criteria governing that interval are stated. On the \nfirst, the Filing does not demonstrate that injections lasting up to twenty seconds are operationally \nacceptable. MISO’s witness explains that the window is limited to twenty seconds “in order to \nalign with the MTEP modeling interval of 20 seconds for transient stability analysis,”25 and \nMISO’s transmittal letter describes the figure as “the best system-wide balance between what is \ntechnically feasible and commercially practical on the one hand, and minimizing even transient \n \n23GIP §§ 3.2.5.1(1), 3.2.5.2.1; ZGIA art. 9.7.5. \n24 MISO Answer at 11. \n25 Keyser at 25:18–26:2."},{"page":43,"startToken":11322,"endToken":11592,"text":"18 \ninjections on the other hand.”26 The study interval is an appropriate duration for a transient stability \nstudy.  \nHowever, neither stated reason is a finding that an injection of that duration is operationally \nacceptable. A stability case evaluates synchronism and voltage recovery for the modeled \nconditions; it does not establish acceptable frequency or balancing performance for every injection \nmagnitude and recurrence pattern, or the result after additional nearby resources are \ninterconnected. MISO’s Answer confirms that rationale, stating that the ceiling “permits MISO to \nevaluate the ZG Resource’s response during the same period in which transient stability impacts \nare analyzed.”27 A study horizon establishes the period analyzed; it does not by itself establish the \nmaximum operationally acceptable duration of an unplanned export. The permitted duration \nshould be derived from what the system can tolerate at the location in question. \nOn the second, the criteria that decide whether an injection is within the permitted tolerance or is \na violation of the interconnection agreement are a substantive condition of service. Business \nPractices Manuals are developed through the stakeholder process and are not filed with the \nCommission. The Tariff is the filed rate, and it should therefore contain sufficient detail for MISO \nto enforce the operating restrictions applicable to a ZG resource. MISO’s Answer states that \nplacing these rules in the manual “ensures ZG Interconnection Customers are treated \nconsistently.”28 Consistent treatment is better assured by stating those criteria in the filed Tariff, \nwhere they apply equally to every ZG Interconnection Customer and can be enforced. \n \n26 Transmittal at 21 & n.52. \n27 MISO Answer at 11. \n28 MISO Answer at 11."},{"page":44,"startToken":11592,"endToken":11923,"text":"19 \nPlacing these criteria in the Tariff would make compliance a measurable question rather than a \nmatter of interpretation. In practice, the Tariff would state the maximum export permitted at the \nPoint of Interconnection and the period within which it must end, or the objective criteria for \nsetting a shorter period at a given location; the time within which the injection-limiting action must \nbegin; and the required behavior on loss of communications between the load and the generating \nfacility. The resource would be required to record the generating facility’s injection and the \nassociated load’s contemporaneous withdrawal, or the other metered quantities necessary to \ndetermine export beyond the interconnecting substation, at a resolution sufficient to observe a \nseconds-scale event, and to retain those records.  \nAfter any loss or reduction of associated load, those records could be compared directly with the \nstated criteria. An event within the criteria would require nothing further. An event outside them \nwould trigger defined consequences: an event report and root-cause analysis, retesting of the \ninjection-limiting scheme, and operating restrictions until the scheme is corrected, with escalation \nfor repeated events. Because the criteria and consequences would be part of the filed rate, MISO \nwould apply them uniformly to every ZG resource, could not change them without a filing with \nthe Commission, and could rely on them if a customer disputed whether an event was a violation. \nUnder the Filing as proposed, the criterion that determines whether an event was permitted is left \nto a manual that can change without Commission review, and no consequence short of the general \nbreach provisions attaches to an event outside it. \nThe Tariff further leaves undefined how a resource is to stay within whatever window applies, \nwhich compounds the delegation just described. The first gap concerns the type of control. The \nstudy standard for the ZG Impact Assessment, GIP § 3.2.5.2.1, permits MISO to accept “control \nequipment and/or operating procedures.” The “and/or” matters because the filed language does not"},{"page":45,"startToken":11923,"endToken":12195,"text":"20 \nrequire every configuration to use an automatic physical export-limiting device. The ZGIA \nprovisions do not expressly require an automatic interlock, directional relay, remedial action \nscheme, or other automatic export-limiting control capable of acting on the timescale of the \nunderlying event. \nThe second gap concerns the coordination of the injection-limiting scheme with ride-through \nrequirements, which also explains why some transient tolerance is unavoidable. The ZGIA places \ntwo obligations on the generating facility that must both be satisfied during the governing event. \nArticle 9.7.3 requires the Interconnection Customer to implement under- and over-frequency and \nunder- and over-voltage relay settings, or equivalent electronic controls, as required by the Electric \nReliability Organization, so that the facility has the ability to “stay connected to and synchronized \nwith the Transmission System during system disturbances.”29 Article 9.7.4.7(c), in turn, requires \nthe generating facility to “[c]ease all injection of Energy onto the Transmission System within the \ntime permitted by the Transient Tolerance Window” in the event a Transmission Facility over \nwhich energy must flow to reach the associated load trips offline.30 \nArticle 9.7.3 goes further for a non-synchronous Generating Facility. For frequency and voltage \nconditions within the “no trip zone” of Reliability Standard PRC-024-3, the facility’s control and \nprotection settings must be configured, within any physical limitations, to “continue active power \nproduction during disturbance and post disturbance periods at pre-disturbance levels” and to \n“return to pre-disturbance active power levels without artificial ramp rate limits if active power is \nreduced,” unless the facility is providing frequency response. \n \n29ZGIA art. 9.7.3. \n30ZGIA art. 9.7.4.7(c)."},{"page":46,"startToken":12195,"endToken":12458,"text":"21 \nConsider a fault that causes the associated load to disconnect while the generating facility is subject \nto applicable ride-through requirements. Those requirements are intended to avoid unnecessary \ngenerator tripping during disturbances, which can exacerbate system conditions, while \ncomputational loads can disconnect during voltage excursions. In a disturbance for which the \napplicable ride-through criteria require continued connection, the generator may therefore be \nrequired to remain connected at the moment its associated load has disconnected. That is a real \nengineering tension, it is not of MISO’s making, and it explains why some transient allowance is \nunavoidable.  \nThat tension does not, however, justify leaving the required performance undefined. During \ndisturbances for which applicable ride-through requirements call for the generating facility to \nremain connected, compliance with the zero-injection limitation must be achieved through \nsufficiently rapid reduction, redirection, or other control of real-power output rather than simply \ntripping the generating facility. Where a configuration relies on operator action or offer \nadministration rather than automatic control, the Filing does not demonstrate that either can act on \nthe timescale the event requires. The agreement does not specify how the ride-through settings and \ninjection-limiting controls must be coordinated so that both requirements are satisfied during the \nsame disturbance.  \nMISO has instead “built flexibility into [the] framework for the Interconnection Customer to select \nthe equipment that it believes is most appropriate for its configuration.”31 MISO’s Answer \ndescribes its approach as performance-based and argues against mandating a single technical \nconfiguration.32 Because these requirements must operate together during the very disturbance the \n \n31Transmittal at 42. \n32 MISO Answer at 9–10."},{"page":47,"startToken":12458,"endToken":12751,"text":"22 \nproduct is designed to address, their coordination should be specified in the Tariff rather than left \nentirely to an applicant’s equipment election and a manual that has not been filed. \nProject-specific technical solutions can be appropriate. The gap is that the performance any such \nsolution must achieve is not stated in the Tariff. This is a further reason the Commission should \nrequire measurable response requirements that any selected configuration must meet, defined \ncoordination between the ride-through settings and the injection-limiting scheme, and \ncommissioning verification that the two operate together as represented. A configuration relying \non operator action should not be accepted where the required response time cannot reliably be \nachieved manually. In short, the manual would have to supply not only the length of the window \nat a given location but also the control performance and the coordination needed to meet it, and \nnone of that is in the filed Tariff. \nQ. To what extent are the verification requirements effective? \nA. Only in part. The requirements to verify compliance with the proposal’s operational provisions \nare incomplete. The ZGIA requires equipment and carries forward general pre- and post-operation \ntesting, but it does not establish the ZG-specific performance criteria, tests, or reporting needed to \nconfirm that the injection-limiting scheme performs in operation. The ZGIA provisions establish \nno ZGIA-specific telemetry performance standard — such as scan rate, latency, accuracy, \navailability, or data-retention requirements — despite requiring the customer to install monitoring \nequipment. Specifically, Article 6.1 requires pre-operation testing of the Interconnection \nCustomer’s System Protection Facilities, “including control equipment to limit injection at the POI \nto the level of Interconnection Service set forth in Appendix A,” provides that “[s]imilar testing \nmay be required after initial operation,” and Article 6.2 requires routine inspection and testing in"},{"page":48,"startToken":12751,"endToken":13036,"text":"23 \naccordance with Good Utility Practice and allows a Party to require reasonable additional testing; \nMISO’s Answer relies on both.33 Further, Article 9.7.4.6 requires calibration and functional trip \ntests of System Protection Facilities before the In-Service Date and Commercial Operation Date, \n“[a]t intervals suggested by Good Utility Practice,” and “following any apparent malfunction” of \nthose facilities; by its terms, those tests “do not require the tripping of any in-service generating \nunit.”34 These provisions test control equipment against the Appendix A Interconnection Service \nlevel and verify that protective relays and lockouts operate. However, none of them expressly \nrequires a dynamic demonstration that, following a sudden reduction or loss of associated load, \nthe facility can reduce its output to the load’s current withdrawal within the Transient Tolerance \nWindow. \nBeyond those provisions, I have not identified a ZGIA-specific pass/fail criterion, a required load-\nrejection test, a requirement to report the results of such testing to MISO, a retest obligation \ntriggered by an injection event rather than by an apparent malfunction of protection facilities, or a \ndefined retesting interval, and MISO explicitly acknowledges the “absence of a separate ZGIS-\nspecific inspection interval.”35 Nor have I identified a requirement to report an injection event or \ncontrol failure to MISO. The filed provisions also do not establish a frequency threshold for \nrepeated excursions within the tolerance window, nor a cumulative event threshold that would \ntrigger restudy or mandatory corrective action. Those omissions make it more difficult to verify \nsystematically whether the operating premise of the service is holding in practice. \n \n33 ZGIA arts. 6.1, 6.2; MISO Answer at 10. \n34 ZGIA art. 9.7.4.6. \n35 MISO Answer at 10."},{"page":49,"startToken":13036,"endToken":13394,"text":"24 \nI recommend that the Commission require the Tariff to state the zero-injection obligation as \nmeasurable performance criteria rather than as a general requirement to install suitable equipment. \nWithout such criteria, there is no assurance that the required equipment will perform as MISO’s \nstudies assume. At a minimum, those criteria should specify the maximum permitted export and \nits duration; the time within which the limiting action must begin and the rate at which output must \nthen be reduced; the required behavior on loss of communications between the load and the \ngenerating facility, or loss of control power, given that Article 9.7.4.7(a) makes the scheme \ndependent on that communication; telemetry sampling and data-retention requirements; the \ncommissioning test that must be passed before commercial operation; and the number or frequency \nof events that triggers corrective action or restudy. The North American Electric Reliability \nCorporation’s (NERC’s) May 2026 alert on computational load addresses modeling, studies, \ninstrumentation, commissioning, operations, protection, and control, underscoring the importance \nof clear requirements in those areas.36 \nOne further comparison connects these operating requirements to the planning issues discussed in \nthe next section. Under the Southwest Power Pool’s (SPP’s) Conditional High Impact Large Load \nService (CHILLS), a large load may qualify for service on the strength of supporting generation, \nand where it does, “Transmission Customers will be required to have supporting generation in-\nservice prior to receiving CHILLS,” and “SPP will curtail the CHILLS if the supporting Resource \nis not available to support the [load].”37 That is an operative linkage between resource availability \n \n36 NERC, Level 3 Alert: Computational Load Modeling, Studies, Instrumentation, Commissioning, Operations, \nProtection, and Control (May 4, 2026); ZGIA art. 9.7.4.7(a). \n37 Southwest Power Pool, Inc., Submission of Tariff Revisions to Add Conditional High Impact Large Load Service, \nTransmittal Letter, Docket No. ER26-1323-000, at 9 (Feb. 10, 2026) (“SPP CHILLS Transmittal”); see id. at 20–21 \n(describing qualification based on existing Designated Resource capacity or on supporting generation); see also A. \nLevitt et al., The Brattle Group, Solutions for Timely Interconnection of Large Loads: Enabling Non-Firm \nTransmission Service, at 63–64 & n.99 (Sept. 2026)."},{"page":50,"startToken":13394,"endToken":13642,"text":"25 \nand load service. The Filing contains no comparable linkage. If a ZG resource becomes \nunavailable, its associated load continues to receive network service, with the planning \nconsequences I describe in Section IV. \nIV.  Modeling Assumptions and Cost Allocation \nQ. How could MISO’s proposal affect responsibility for transmission costs? \nA. Two features of MISO’s proposal bear on who bears transmission costs and when. The first is \nreliance on a ZG resource as a substitute for transmission. This does not necessarily change which \ncustomers pay for load-serving upgrades, but it changes when those upgrades are identified and \nleaves responsibility for them unresolved if the resource is lost. The second is the set of study \nassumptions used to approve ZG resources, which can cause interconnection-related issues to be \naddressed under planning cost-allocation rules rather than generator-interconnection cost-\nallocation rules. I address each in turn. \nQ. What cost-responsibility issue arises when MISO relies on a ZG resource as a substitute \nfor transmission? \nA. MISO attributes much of the value of a ZGIA to transmission planning. MISO’s witness states \nthat only resources with an accepted interconnection agreement are eligible for inclusion in MISO \nTransmission Expansion Plan (“MTEP”) studies. MISO identifies this as a principal source of the \nZGIA’s value. According to MISO’s witness, the ZGIA process will provide an agreement within \nninety days, which permits the resource to be modeled as an input to the subsequent MTEP or \nExpedited Project Review load study for its associated load, creating “the potential for reduced"},{"page":51,"startToken":13642,"endToken":13923,"text":"26 \ntotal cost of transmission network upgrades needed to integrate the new load.”38 Attachment FF \npermits the resource to serve as a Non-Transmission Alternative that offsets upgrades that would \notherwise be required to serve the load. Transmission upgrades that would otherwise be identified \nfor the associated load may therefore be deferred or avoided in the planning case that includes the \nZG resource. \nNow consider what happens if the ZG resource fails to materialize, retires early, or becomes \npermanently unavailable. The associated load is firm network load taking Network Integration \nTransmission Service on a gross basis, so a transmission need that had been reduced, deferred, or \navoided in reliance on the ZG resource may re-emerge and be identified in a later MTEP cycle. \nAny resulting transmission solution would be classified and allocated under the applicable MTEP \ncost-allocation rules. The Filing does not assign that cost to the ZG interconnection customer, \nestablishes no ZGIA-specific true-up, and does not trace later planning costs back to the \narrangement on which the earlier planning assumption depended. \nThis conclusion does not rest solely on my reading of the Tariff language. MISO stated the \noutcome directly when stakeholders raised the concern. Responding to what it characterized as \n“[w]idespread concern from multiple stakeholders” that “loads may avoid upgrades initially using \nZGIAs but later cause upgrades that are then socialized,” MISO answered that “[i]f ZGIA \nagreements are not met and upgrades become necessary, those costs are still allocated to the load \nin the Local Pricing Zone,” and that “MISO is not proposing any changes to cost allocation of \neither generation or transmission investments in its ZGIA efforts. Cost allocation could be a \n \n38 Keyser at 18–19."},{"page":52,"startToken":13923,"endToken":14231,"text":"27 \ncomponent of the broader large load efforts taking place at the Large Load Working Group.”39 In \nshort, MISO acknowledged that the cost of a later-arising upgrade would be allocated to load in \nthe Local Pricing Zone generally, as it may be for other load-serving upgrades, rather than to the \ninterconnection customer or specifically to the associated load whose arrangement failed. MISO \nalso indicated that any ZGIA-specific cost-allocation treatment could come, if at all, through its \nseparate and later large-load efforts. \nThe significance of that allocation lies principally in timing and in the terms on which the load \ntakes service. Had no ZG resource been involved, upgrades needed to serve the associated load \nwould have been identified in the load study and, depending on how the project is classified under \nMISO’s planning and cost-allocation rules, may have been borne by the same or substantially the \nsame customers. Without a ZG resource, the need is identified before the load is placed in service, \nwhen the transmission owner, the Load Serving Entity, and any applicable state process can take \nit into account in setting the timing and terms of that service. With a ZG resource credited as a \nNon-Transmission Alternative, the load can be placed in service without those upgrades. If the \nresource is later lost, the need re-emerges after service has begun. At that point the Filing’s \nprincipal express remedy for pre-service non-performance, a discretionary delay of the load’s in-\nservice date, no longer applies; the terms of service for the load may already have been set on the \nassumption that the resource would be available; and MISO may need interim operating measures, \naccelerated construction, or other measures until an alternative transmission solution can be placed \nin service. \n \n39MISO, Response to Feedback, Planning Advisory Committee, ZGIA Proposal Framework (PAC-2024-4), at 8 \n(Apr. 15, 2026) (“April 15 Feedback Response”)."},{"page":53,"startToken":14231,"endToken":14523,"text":"28 \nThis is not a claim that MISO ignores the reliability consequences of an unavailable ZG resource. \nMISO has explained that generator outages are “accounted for in the MTEP process as P11 or P31 \nplanning events used in the MTEP Reliability Analysis,” and that the MTEP load study “will \ninclude the outage events of the generator.”40 The MTEP process can therefore identify the \nresulting need. The issue is what happens next, because the Filing provides no ZGIA-specific \nmeans of addressing the timing, reliability, and cost consequences of a need that re-emerges when \nthe arrangement on which MISO relied does not perform. \nMISO’s Answer does not respond to this cost-responsibility issue; it addresses only a different \ncategory of upgrade. Specifically, the Answer explains that the ZG Interconnection Study must \nfind that a project requires no Network Upgrades beyond the interconnecting substation, and \nconcludes that “the ZGIA process does not permit MISO simply to defer broader Network \nUpgrades and their associated costs.”41 MISO also states that model reconciliation “insulates \nexisting DPP projects from negative impacts or cost shifts due to the existence of the ZGIA \nprocess.”42 Both statements concern the interconnection of the ZG resource and the interests of \nother interconnection customers. The cost-responsibility issue described above concerns \ntransmission needed to serve the associated firm load. After a ZGIA is executed, Attachment FF \npermits MISO to rely on the ZG resource as a Non-Transmission Alternative in determining those \nload-serving needs. If that planning assumption later changes, the resulting need is addressed \nthrough MTEP under its generally applicable cost-allocation rules. The Answer does not identify \n \n40April 15 Feedback Response at 3; June 10 LLWG Presentation at 6. \n41 MISO Answer at 17–18. \n42 MISO Answer at 14 (quoting Transmittal at 15)."},{"page":54,"startToken":14523,"endToken":14874,"text":"29 \nany ZGIA-specific means of addressing the consequences if the arrangement on which the earlier \nplanning determination relied does not perform. \nThe timing of MISO’s related reforms compounds this gap. At the request of MISO and the MISO \nTransmission Owners, the Commission has held the show cause proceeding in abeyance, and \nMISO plans to proceed through milestone-based filings scheduled through 2027, including a filing \ncommitted for no later than November 16, 2026. MISO’s response to the Commission’s cost-\nshifting and transparency directives is to follow.43 At the August 12 working group meeting, MISO \nstated that it “does not have a proposed design at this time” for its companion non-firm service \nproposal.44 The Filing nonetheless requests an October 18, 2026 effective date for a permanent \npathway. That sequencing matters because the ZGIA could become effective before those cost-\nallocation and transparency protections are developed. The Commission should either require the \nprotections now or condition acceptance on their timely filing. MISO’s Answer also emphasizes \nthat ZG Interconnection Service “is not restricted to Generating Facilities serving Large loads,”45 \nwhile deferring cost-allocation and transparency questions to its broader large-load reforms. MISO \nshould therefore explain whether the later cost-allocation and transparency reforms cited in its \nAnswer will apply to ZG arrangements outside any applicable Large Load definition. \nQ. How could the study models used in the ZGIA process shift costs? \n \n43 MISO, Minutes of the August 12, 2026 Large Load Working Group meeting, item 4 (Abeyance Request Review) \n(posted Sept. 9, 2026) (“August 12 LLWG Minutes”) (describing the abeyance motion and a workplan of \n“milestone-based filings and proposals scheduled through 2027”); August 12 Non-Firm Presentation at 3 (MISO and \nthe Transmission Owners “committed to a filing no later than November 16”); see also Transmittal at 5–6 & n.24 \n(noting that the Commission granted the requested 90-day abeyance on August 14, 2026). \n44 August 12 LLWG Minutes, item 6 (Conditional Non-Firm Transmission Service); see August 12 Non-Firm \nPresentation (https://cdn.misoenergy.org/20260812%20LLWG%20Item%2006%20Conditional%20Non-\nFirm%20Transmission%20Service%20(LLWG-2026-5)774185.pdf) at 2–3. \n45 MISO Answer at 18."},{"page":55,"startToken":14874,"endToken":15174,"text":"30 \nA. The models used to study ZG requests exclude the pending interconnection queue. MISO states \nplainly that “ZGIA studies will not include Interconnection Requests currently in the generator \ninterconnection queue that do not have a GIA.”46 As of July 2026, MISO’s queue contained 802 \nactive Interconnection Requests representing approximately 167 GW; requests in that queue that \nhave not reached an executed agreement are excluded from ZGIA studies.47 The exclusion runs in \nboth directions, because the base case for each Definitive Planning Phase cycle is also frozen when \nthe cycle begins and is not updated for ZGIAs approved during that cycle.48 Successive ZGIA \ncycles do account for one another, because MISO adds each agreement approved since the last \nbase case to the following ZGIA cycle. The resulting modeling gap is between ZG resources and \npending DPP requests. \nThis matters because a generating facility affects the transmission system in ways that do not \ndepend on whether it is exporting real power. An energized generator can contribute fault current \nto nearby buses even when it is not exporting real power. The filed Tariff permits System \nProtection Facilities at adjacent substations as the sole Network Upgrade beyond the \ninterconnecting substation,49 and MISO explains that this exception “acknowledges that short \ncircuit and other transient study results could require facilities to be upgraded beyond the \nsubstation, even though injections will be limited.”50 However, the screen for those effects is run \nagainst a model that omits the pending queue. Two or more projects — a ZG resource and a DPP \nproject at an electrically adjacent bus — may each be found to require no upgrade when studied \n \n46Transmittal at 15; Keyser at 30. \n47Keyser at 5. \n48Transmittal at 15. \n49GIP § 3.2.5.1(2); § 3.11(iii). \n50 Transmittal at 26–27."},{"page":56,"startToken":15174,"endToken":15444,"text":"31 \nagainst models that do not contain the other, while their combined contribution exceeds the \ninterrupting capability of existing breakers or the coordination margins of existing protection \nschemes. Breaker interrupting capability and protection coordination margins at nearby \nsubstations are, in this sense, a finite and shared capacity on which pending DPP projects also rely; \na ZG resource studied outside the DPP model can use part of that capacity without the DPP study \naccounting for it.  \nThe magnitude of that contribution depends on technology. A synchronous machine can contribute \nseveral multiples of rated current to a nearby fault, subject to machine and system characteristics, \nwhile inverter-based resources typically limit current through their controls to a much smaller \nmultiple of rating. The short-circuit effect can be more pronounced for synchronous generation, \nincluding combustion turbines or reciprocating engines, than for current-limited inverter-based \nresources. Inverter-based resources present different protection-coordination issues because their \nfault-current magnitude and waveform are control-dependent and may be substantially lower than \nthose of synchronous machines.  \nMISO’s Answer states that ZGIA projects “do not use available transmission capacity reflected in \nthe DPP and ERAS studies.”51 That statement addresses transfer capability, the capacity of the \ntransmission system to deliver power, which a resource that does not export beyond its substation \nshould not consume. Short-circuit duty and protection coordination are different. They depend on \nthe fault current that energized equipment can contribute, whether or not it is exporting power, and \nthey are evaluated against the breakers and protection schemes at nearby substations. Preserving \ntransfer capability therefore does not establish that ZG resources omitted from a DPP model, or \n \n51 MISO Answer at 14."},{"page":57,"startToken":15444,"endToken":15746,"text":"32 \nDPP projects omitted from a ZGIA model, have no short-circuit, protection, voltage, or dynamic \ninteraction with one another. The Answer does not address those effects. \nMISO’s response to the modeling gap is reconciliation after the fact: “Any transmission issues \nidentified by reconciling the cases will thus be addressed through the existing MTEP process.”52 \nAny issues identified through that reconciliation may arise after the ZGIA has been executed and \nare addressed in a planning process in which cost responsibility is determined by MTEP cost-\nallocation rules rather than generator-interconnection cost-allocation rules. Without the parallel \npathway, the later generator would have been studied in the ordinary interconnection process with \nthe relevant pending projects reflected in the study sequence, and any resulting breaker, protection, \nor other interconnection upgrade responsibility would have been determined through that process.  \nThe order of study also matters. Because ZG studies include only projects with executed \nagreements, a ZG request can be studied and approved against short-circuit and protection margin \nthat earlier-submitted requests still pending in the queue would otherwise have been studied \nagainst. Requests that have not yet entered an active DPP cycle are then studied against a base case \nthat already includes the ZG resource, and are assigned any upgrades that the combined effect \nrequires. MISO’s Answer states that a ZG resource seeking Energy Resource Interconnection \nService (ERIS) or Network Resource Interconnection Service (NRIS) must submit a new \nInterconnection Request and proceed through the DPP on the same footing as other requests,53 \nwhich is correct as to injection rights; it does not address the short-circuit and protection margin \nthe resource has already been permitted to use. In addition, the study provision states that MISO \nwill perform short-circuit, stability, and steady-state analyses “if necessary based on the proposed \n \n52Transmittal at 15. \n53 MISO Answer at 15–16."},{"page":58,"startToken":15746,"endToken":16013,"text":"33 \nconfiguration.”54 Read most narrowly, that qualifier makes the steady-state thermal and voltage \nanalysis discretionary; read more broadly, it qualifies all three. Either reading warrants further \nexplanation given that the governing scenario includes rapid loss of a large associated load. \nThe ERAS experience is relevant here as well, although the analogy is only partial. The ERAS and \nZGIA pathways share several structural features: an expedited pathway operating parallel to the \nstandard process, studied against models that exclude the pending queue, with reconciliation \ndeferred to transmission planning and no mechanism to allocate later-identified costs back to the \nprojects that triggered them. One difference is that ERAS projects receive injection rights and can \ntherefore consume transmission headroom that standard-process customers were relying upon, \nwhile ZG resources receive no such rights and do not consume export headroom in the same way. \nThe shared capacity a ZG resource can consume is instead short-circuit and protection capacity at \nnearby substations. The cumulative effects I am describing include short-circuit duty, protection \ncoordination, voltage performance, and dynamic behavior. Ultimately, a zero-export restriction \ndoes not eliminate those effects, although their magnitude depends on technology, operating \ncondition, controls, and system topology. However, the absence of a cap or sunset means the \npotential cumulative exposure is less bounded under ZGIA. ERAS was capped and time-limited, \nand ZGIA is neither.  \nQ. Is there evidence of how excluding pending requests from expedited-study models \noperates in practice? \nA. Yes. The ERAS process has produced executed interconnection agreements, and one of them \nillustrates the mechanism directly. The public version of the Generator Interconnection Agreement \n \n54GIP § 3.2.5.2.1."},{"page":59,"startToken":16013,"endToken":16307,"text":"34 \nfor Project E0010, executed December 12, 2025, covers a 750 MW net natural gas facility \ninterconnecting at the Twinkle Substation 345 kV bus.55 \nThe agreement’s prior-queue accounting is defined to look only within the expedited pathway. \nAppendix A10 directs higher-queued and similarly queued projects to Tables A10-2 and A10-3, \nwhich are limited by their terms to “ERAS study projects,” and in this agreement both read \n“None.”56 Projects pending in the Definitive Planning Phase are not identified in the agreement, \nbecause the accounting was never defined to reach them. \nThe service granted is also conditional on regionally planned transmission, consisting of 750 MW \nof conditional ERIS and/or NRIS that becomes NRIS upon completion of seven approved MTEP \nand Long Range Transmission Planning facilities listed in Table A10-1, four of which are not \nexpected in service until June 1, 2032.57 The customer’s own network upgrade is two new 345 kV \npositions at the Twinkle substation, estimated at $20,293,813.58 \nI rely on this agreement as evidence that when an expedited pathway defines its prior-queue \naccounting by reference to the pathway itself, that accounting can be empty even while projects \nremain pending in the broader generator interconnection queue. MISO describes the ZGIA process \n \n55Original Service Agreement No. 4627, Project E0010 Generator Interconnection Agreement (Public Version) \n(executed Dec. 12, 2025), Docket No. ER26-811-000 (“E0010 GIA”). The analysis in this testimony is my own, based \non the public version of the agreement and on MISO’s published queue data. \n56E0010 GIA, App. A § A10, tbls. A10-2, A10-3. \n57E0010 GIA, App. A § 1; id. § A10 (providing that if the transmission assumptions “are not completed or significantly \nmodified, the Interconnection Service granted under this GIA may be restricted”). \n58E0010 GIA, App. A §§ A5, A6-1, A6-2."},{"page":60,"startToken":16307,"endToken":16610,"text":"35 \nas resembling the ERAS process in its study aspects, timing, and financial obligations,59 and ZGIA \nstudies likewise exclude pending requests without executed agreements. \nA parallel expedited process need not exclude pending requests from its study models, as a recent \nCommission order shows. On June 9, 2026, the Commission accepted PJM’s Expedited \nInterconnection Track, which studies expedited requests using the models for the currently active \nCycle, the same models used in the standard process.60 The Filing does not explain why that \napproach could not be used here. \nQ. Does MISO’s proposal contain provisions that effectively address these cost-responsibility \nand cost-shift risks? \nA. No. The Filing contains several provisions that bear on the question, but none of them functions \nas a cost-responsibility mechanism for the load-serving upgrades I describe. \nFirst, MISO’s witness states that “[t]he contingent facilities listed in the ZGIA would only be those \nfacilities in the model used for the ZGIA study.”61 This defines the customer’s exposure by \nreference to the model as it stood at execution. It therefore operates as a limitation on the \ncustomer’s responsibility rather than as a protection for others, and anything identified later \nthrough reconciliation falls outside it. \n \n59 June 10 LLWG Presentation \n(https://cdn misoenergy.org/20260610%20LLWG%20Item%2005%20Market%20Participation%20and%20Registra\ntion%20of%20Co-Located%20Load%20and%20Generation763097.pdf) at 5 (elements of the ZGIA process “will \nresemble the surplus, replacement, and ERAS processes in terms of study aspects, timing, and financial/other \nobligations”). \n60 PJM Interconnection, L.L.C., 195 FERC ¶ 61,197 (2026) (accepting PJM’s Expedited Interconnection Track, \nunder which, as PJM stated, EIT Projects “will be studied using the models for the currently active Cycle”), Docket \nNo. ER26-1563-000. I submitted testimony addressing the PJM proposal in that proceeding. \n61Keyser at 30–31; see also Transmittal at 15."},{"page":61,"startToken":16610,"endToken":16941,"text":"36 \nSecond, Attachment FF conditions reliance on a ZG resource on an executed agreement that “is in \nplace and must span at least the five year planning horizon.”62 The corresponding provision in the \ninterconnection procedures requires only that the agreement “state an expected term of at least five \nyears.”63 MISO acknowledges that the weaker formulation was deliberate, stating that, to \naccommodate commercial considerations, MISO “only requires that the agreement specify an \nintent to use the full output of the Generating Facility for at least five years rather than a firm \ncommitment.”64 A stated expectation is not equivalent to a firm commitment, and the two \nprovisions should be reconciled. Separately, the Filing does not explain why a five-year expected \nterm is sufficient or what notice MISO would receive before the resource is lost, when the \ntransmission facilities deferred in reliance on it may take several years to plan and build. \nAttachment FF itself explains that the five-year span is intended “to ensure the ability to provide \nadequate lead time for an alternative transmission solution should the contracts terminate,” which \nconfirms that lead time, not the service life of the deferred facilities, is the relevant measure. \nThird, if the generating facility fails to achieve commercial operation by the date the transmission \nsolution would otherwise need to be in service, or if the contract terminates, “the Transmission \nProvider may require the applicable Load Serving Entity to delay the in-service date of ZG \nAssociated Load until such time as an alternative solution can be placed in service.”65 This is the \nFiling’s principal express response to pre-service non-performance, and it has four limitations. It \nis discretionary and is directed at the Load Serving Entity, which may not be a party to the ZGIA \nand does not control whether the generator is built. It operates only before the load is placed in \n \n62 Attachment FF § I.D.1.b. \n63GIP § 3.11(vii). \n64Transmittal at 33. \n65 Attachment FF § I.D.1.b."},{"page":62,"startToken":16941,"endToken":17232,"text":"37 \nservice, and therefore does nothing about a resource that is lost after service begins. Finally, it is a \ntiming remedy rather than a cost remedy, because it can delay the load but does not address the \ncost or reliability consequences of the changed planning assumption. \nFourth, the requirement that a ZG resource trigger no Network Upgrades beyond the \ninterconnecting substation is a meaningful constraint on the interconnection study, but it does not \naddress the cost-responsibility issue I have described. The upgrades at issue are those needed to \nserve the associated load, which are determined later, in a different process, under different cost \nallocation rules. MISO’s Answer relies on the same limitation and, for the reasons explained \nabove, does not reach those load-serving upgrades. \nFifth, MISO prohibits netting and requires the associated load to take firm Network Integration \nTransmission Service and pay for transmission, ancillary, and administrative services on a gross \nbasis. That addresses the risk of co-located load avoiding its share of system costs. It does not, \nhowever, address responsibility for upgrades deferred in reliance on the ZG resource, which is a \ndifferent question. \nTo address these issues, I recommend that the Commission require MISO to study each \narrangement both with and without the ZG resource so that the deferred-upgrade baseline is \nexplicit; to identify and record every upgrade deferred in reliance on a ZG resource; to require \nfinancial security or a cost-responsibility agreement covering the documented incremental costs \nof interim measures or accelerated construction that would not have been incurred had the deferred \nneed been addressed in the ordinary planning sequence; to conform the interconnection procedures \nto Attachment FF on the five-year term; and to establish defined restudy triggers and cost-\nallocation rules for upgrades identified through model reconciliation."},{"page":63,"startToken":17232,"endToken":17503,"text":"38 \nQ. Does MISO’s proposal contain transparency provisions sufficient to allow later \ntransmission needs and their cost consequences to be traced to the ZGIA process? \nA. No. The Filing’s one meaningful transparency provision is that executed ZGIAs will be filed \nwith the Commission, because MISO has extended the tender, negotiation, and execution \nprovisions of the interconnection procedures to cover them.66 Public availability of particular \ndiagrams or equipment details may remain subject to confidential or Critical Energy/Electric \nInfrastructure Information (CEII) treatment. Filing the executed agreements is useful, but it does \nnot provide the information needed to trace a later transmission need to the ZGIA process or to \nidentify its cost-responsibility consequences. \nNo Tariff provision requires MISO to publish the information that would be needed for that \npurpose. Nothing requires posting of ZG applications or their status. Nothing requires publication \nof the ZG Impact Assessment or ZG Facilities Study reports. Nothing requires disclosure of the \nsize or identity of the associated load, of the Network Upgrades identified or deferred, of affected-\nsystem study results, or of injection events. Mr. Keyser states that applications will be posted on \nMISO’s public website in a timely fashion,67 but that commitment appears in testimony rather than \nin the Tariff. \nThe practical consequence is that the reconciliation and true-up mechanisms I recommend would \nbe difficult for stakeholders to evaluate without additional published information. To determine \nwhether an upgrade identified in a later MTEP cycle resulted from assumptions made in the ZGIA \nprocess, a party would need the ZG study results, the models and base-case vintage used, the \n \n66GIP §§ 11.1–11.3. \n67Keyser at 34."},{"page":64,"startToken":17503,"endToken":17787,"text":"39 \nupgrades deferred in reliance on the resource, and the operating history of that resource. None of \nthat is required to be public. Transparency is therefore integral to evaluating any reconciliation or \ncost-responsibility mechanism adopted for this service. \nMISO’s Answer responds that these disclosures are not required of requests in the Definitive \nPlanning Phase, and that MISO does not propose to reduce any generally applicable transparency \nrequirement.68 MISO is not reducing existing transparency, but the question is whether existing \nprocedures allow anyone to trace the linkage this service creates between a particular ZG resource, \nthe load-serving transmission assumption made in reliance on it, and a later MTEP reconciliation. \nMISO’s statement that other interconnection requests do not receive the same disclosure does not \nestablish that existing transparency is sufficient for that purpose. \nTo provide sufficient information for affected parties to trace later transmission needs and their \ncost-allocation consequences, including any cost shifts, I recommend that the Commission require \nMISO to publish, subject to appropriate protection for genuinely confidential commercial and \ncyber-sensitive information: the ZG requests received in each quarterly study period, with \nmegawatt quantity, technology, location, and status; the study reports and the base case used; the \nNetwork Upgrades identified and, separately, the upgrades deferred in reliance on each ZG \nresource; affected-system results; requests rejected for requiring upgrades beyond the \ninterconnecting substation; and an annual report of injection events, control failures, and any \nenforcement actions. This recommendation is consistent with the transparency concerns the \nCommission identified in its order to show cause in Docket No. EL26-70-000.69 \n \n68 MISO Answer at 17. \n69 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212 (2026)."},{"page":65,"startToken":17787,"endToken":18078,"text":"40 \nV.  Eligibility and Limitations on the ZGIA Process \nQ. Is the ZGIA process equally functional for all resource types? \nA. MISO states that the requirements are facially neutral, fuel-agnostic, and open to any resource \nregardless of technology.70 That is accurate as a matter of eligibility, but it does not follow that the \nZGIA process is equally workable in practice for all resource types. A paired generation-and-\nstorage configuration is eligible to apply for a ZGIA. Because a Generating Facility may consist \nof “one or more generating unit(s) and/or storage device(s),” such a facility can proceed through a \nsingle Interconnection Request, occupy one quarterly study slot, and be subject to a single service \ncap under Section 3.11(v).71 MISO has also confirmed that a resource with ZG Interconnection \nService is considered deliverable to its associated load for accreditation purposes, with the \nreference to “firm interconnection service” in the accreditation provisions referring to \ndeliverability.72  \nHow storage charging would be treated in such a configuration, however, remains unresolved. \nMISO has stated in the stakeholder process that charging by a storage resource with a ZGIA “will \nfollow the same process as other storage resources – storage charging is not considered during the \ninterconnection queue process; instead, it is studied as an obligation to secure transmission service \nas a load.”73 That approach may be workable for a stand-alone storage resource, but it leaves four \nquestions open in a co-located configuration, where the defining constraint is the relationship \nbetween generation output and a specific load: (1) whether energy used to charge the storage \n \n70Keyser at 35. \n71 GIP § 1 (definition of “Generating Facility”); GIP § 3.11(v). \n72 MISO Answer at 21. \n73 April 15 Feedback Response at 13."},{"page":66,"startToken":18078,"endToken":18368,"text":"41 \ncomponent from the co-located generation constitutes a withdrawal requiring transmission service; \n(2) whether charging from the Transmission System increases the Demand of the ZG Associated \nLoad and therefore the permissible level of ZG Interconnection Service under Section 3.11(v); (3) \nhow a charging storage component is represented in the load-trip stability case required by Section \n3.2.5.2.1, given that a charging battery is itself a load that can be lost; and (4) how charging energy \nis metered and settled where the resource and the load must be metered separately. These questions \nare material to project design, study treatment, and commercial evaluation. Leaving them \nunresolved creates practical uncertainty for paired generation-and-storage projects and may \ncomplicate or discourage their use of the ZGIA pathway, even though those configurations are \nfacially eligible. The questions should be answered in the Tariff rather than left to interpretation at \nthe time an application is filed. \nMISO’s Answer now states that “[c]harging behavior that affects the studied configuration will be \nevaluated as part of the ZG Impact Assessment, consistent with MISO’s treatment of charging in \nthe DPP study process.”74 That statement appears only in a pleading, and it differs from MISO’s \nstakeholder explanation that storage charging “is not considered during the interconnection queue \nprocess.” Moreover, MISO’s new response still does not address the service-cap, metering, and \nsettlement questions above. The charging-study requirement, and the answers to those questions, \nshould be stated in the Tariff. \nQ. In what ways is the magnitude and duration of the proposed ZGIA process limited? \nA. The Filing imposes several project-level eligibility constraints, while the program as a whole \nhas relatively few cumulative limits. The project-level eligibility constraints include that the \n \n74 MISO Answer at 20."},{"page":67,"startToken":18368,"endToken":18653,"text":"42 \ngenerating facility’s Point of Interconnection must be at the same voltage level of the same \nsubstation as a Point of Withdrawal of the associated load; the amount of service may not exceed \nthe total Demand of that load; the resource may serve no other load; the resource may not hold \nERIS or NRIS concurrently; the resource may not require Network Upgrades beyond the \ninterconnecting substation other than System Protection Facilities; and the applicant must submit \nat least 180 days before the earlier of commercial operation or the load’s need-by date, pay a \n$150,000 non-refundable study deposit, demonstrate 100 percent site control, and provide an \nexecuted agreement with the entity owning the associated load. \nThe Filing also includes one express process-wide throughput limit, under which MISO will study \nno more than ten Interconnection Requests in each quarterly study period, with overflow rolling \nforward in submission order.75 That is a throughput constraint governing the rate at which requests \nare processed. It does not govern how many ZGIAs may ultimately exist, how many megawatts \nthey may represent, where they may be located, or how long the program will run. \nQ. In what ways is the magnitude and duration of the proposed ZGIA process unlimited? \nA. The Filing contains no sunset date for the ZGIA process. It contains no aggregate cap on the \nnumber of ZGIAs that may be granted. It contains no fixed aggregate megawatt ceiling; each \nproject’s service level is instead bounded by the associated load’s peak Demand, which may be \nseveral hundred megawatts or more. It contains no locational or electrical concentration limit, so \nten requests in a single quarter may be located at electrically adjacent substations, with the \n \n75GIP § 3.11.2."},{"page":68,"startToken":18653,"endToken":18940,"text":"43 \ncumulative short-circuit and protection effects discussed in Section IV. It contains no requirement \nthat a ZG resource ever transition into the standard interconnection process. \nThe proposal also contains no fixed limit on the duration of an individual agreement. ZG \nInterconnection Service is offered as a permanent product. I further note an inconsistency on this \npoint. The transmittal letter describes the service as available on a permanent basis “subject to 15 \nyear automatically renewing term provisions,” but the filed form of agreement leaves the initial \nterm blank and provides for automatic renewal in successive one-year periods.76 Whichever MISO \nintends, the term should be stated in the filed agreement. \nBecause the quarterly cap governs processing rate rather than cumulative volume, and because \nthere is no aggregate megawatt ceiling, the total quantity of generation interconnected on ZG terms \nis limited only by how long the process operates. At ten requests per quarter, that is up to forty \nrequests studied each year and two hundred over a five-year planning horizon, with no limit on \nhow many may ultimately receive agreements. MISO states that it does not expect to receive more \nthan ten such requests per quarter as the process matures, and describes the cap as a safeguard in \ncase the product proves more popular than expected.77 That statement indicates that actual uptake \nremains uncertain. \nThe ERAS process provides a useful comparison. The Commission accepted ERAS as a parallel, \nexpedited interconnection pathway only with a cap of sixty-eight projects and a sunset of August \n31, 2027, whichever came first.78 ZGIA proposes a permanent parallel pathway with neither. \n \n76Transmittal at 26; ZGIA art. 2.2. \n77 Transmittal at 35. \n78Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 (2025)."},{"page":69,"startToken":18940,"endToken":19259,"text":"44 \nQ. What are the likely adverse consequences of not limiting the ZGIA process beyond the \nten-project quarterly cap? \nA. There are two principal consequences. First, the Filing does not examine how a growing share \nof generation dedicated to specific loads affects resource adequacy for the rest of the system. A \nZG resource may not serve any load other than its associated load, and its capacity credits must be \nused in a Fixed Resource Adequacy Plan or Reliability-Based Demand Curve opt-out rather than \noffered into the Planning Resource Auction.79 Whether that matters depends on whether the \npathway displaces generation that would otherwise have interconnected through the standard \nprocess with the ability to serve other load, or supports generation that would not otherwise have \nbeen built. The Filing does not address that question or explain how MISO’s loss-of-load modeling \nand planning reserve methodology account for ZG resources.80 \nSecond, a permanent construct reduces the opportunity to evaluate actual operating experience \nbefore the pathway becomes an enduring feature of the Tariff. This is a largely new construct, and \nMISO acknowledges having accommodated zero-injection arrangements only in limited \ncircumstances in the past.81 A pilot with an initial term and an aggregate cap would permit the \nCommission and stakeholders to observe how many resources actually use the pathway, whether \nthe injection limits hold in operation, and whether upgrades are later identified in transmission \nplanning that were not anticipated in the interconnection studies, before the service becomes a \npermanent feature of the Tariff. Nothing about a sunset would deny the pathway to projects with \nnear-term needs; it would simply require MISO to return to the Commission with an operating \n \n79Proposed Module E-1 §§ 69A.4.5, 69A.7.3, 69A.7.8, 69A.9, 69A.9.1. \n80 Proposed Module E-1 § 69A.4.1(i); see also id. §§ 69A.4.5, 69A.7.3, 69A.7.8. \n81 Transmittal at 9 n.35."},{"page":70,"startToken":19259,"endToken":19439,"text":"45 \nrecord before the arrangement becomes permanent. The uncertainty about actual uptake that MISO \nitself acknowledges reinforces the case for an initial aggregate cap or sunset, accompanied by \noperational reporting. \nMISO’s Answer does not change this assessment. MISO argues that an aggregate cap or defined \nterm is unnecessary because each ZGIA is limited by its same-substation configuration, its service \ncap, the prohibition on Network Upgrades beyond the interconnecting substation, and the ten-\nrequest quarterly limit.82 Each of those is a limit on an individual project or on the rate of \nprocessing. None constrains how long the parallel pathway operates, how many agreements \naccumulate under it, or the aggregate generating capacity interconnected outside the Definitive \nPlanning Phase. MISO’s Answer also confirms that MISO adopted the quarterly limit “to avoid \ndisruption to the DPP and ensure that sufficient resources are available to process ZGIA \nrequests.”83 That is a processing constraint, not a limit on the scale of the program. \nVI.  Conclusion \nQ. Does this conclude your testimony? \nA. Yes. \n \n82 MISO Answer at 18–20. \n83 MISO Answer at 19."},{"page":71,"startToken":19439,"endToken":19587,"text":"46 \nAttachment HM-1: Curriculum Vitae of Houtan Moaveni \nProfessional Experience \nOctober 2024–Present, Grid Strategies LLC \nTitle: Vice President \nAugust 2021–June 2024, New York State Office of Renewable Energy Siting (ORES) \nTitle: Executive Director \nJanuary 2020–August 2021, New York State Department of Public Service (DPS) \nTitle: Director of Facility Certification & Compliance \nSeptember 2015–January 2020, New York State Energy Research and Development Authority \n(NYSERDA) \nTitle: Senior Advisor to the President & CEO (earlier served as Deputy Director of NY-Sun and \nNew York State Interconnection Ombudsman) \nJune 2014–September 2015, New York Power Authority (NYPA) \nTitle: Program Manager \nJuly 2008–June 2014, Florida Solar Energy Center (FSEC) \nTitle: Program Manager \nJanuary 2008–July 2008, ARMINES \nTitle: Researcher \nEducation \nMaster of Science in “Energy Management and Policy”, École Nationale Supérieure des Mines de \nParis, 2007–2008 \nBachelor of Science in “Power Systems Electrical Engineering”, University of Tehran, 2003–2007"},{"page":72,"startToken":19587,"endToken":19689,"text":"47 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n) \n \nMidcontinent Independent System \nOperator, Inc. \n) \nDocket No. ER26-3552-000 \n \n) \n \n \nVERIFICATION \nI, Houtan Moaveni, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that: I am the \nsame Houtan Moaveni referred to in the foregoing document entitled “Testimony of Houtan \nMoaveni in Support of the Protest of Community Organizations and Clean Energy Advocates;” I \nhave read the same and am familiar with its contents; and the facts set forth therein are true and \ncorrect to the best of my knowledge, information, and belief. \n/s/ Houtan Moaveni \nDated: October 8, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":1232,"startToken":0,"endToken":372},{"p":2,"at":1232,"title":"B. MISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of Potential","method":"printed heading","endPage":2,"endAt":2092,"startToken":372,"endToken":445},{"p":2,"at":2092,"title":"C. MISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall Limits","method":"printed heading","endPage":2,"endAt":2320,"startToken":445,"endToken":465},{"p":2,"at":2320,"title":"D. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource","method":"printed heading","endPage":2,"endAt":2882,"startToken":465,"endToken":496},{"p":2,"at":2882,"title":"ATTACHMENT A: TESTIMONY OF HOUTAN MOAVENI, GRID STRATEGIES…….24","method":"printed heading","endPage":4,"endAt":478,"startToken":496,"endToken":992},{"p":4,"at":478,"title":"A. MISO’s Answer Does Not Cure Concerns with ZGIA’s Operational Requirements.","method":"printed heading","endPage":13,"endAt":1276,"startToken":992,"endToken":3761},{"p":13,"at":1276,"title":"B. MISO’s Answer Fails to Disprove or Justify the ZGIA Process’s Creation of","method":"printed heading","endPage":18,"endAt":1444,"startToken":3761,"endToken":5255},{"p":18,"at":1444,"title":"C. MISO’s Answer is Nonresponsive to Key Concerns Related to the Lack of Overall","method":"printed heading","endPage":20,"endAt":219,"startToken":5255,"endToken":5662},{"p":20,"at":219,"title":"D. MISO’s Answer Provides Some Helpful Clarification Regarding Hybrid Resource","method":"printed heading","endPage":21,"endAt":1038,"startToken":5662,"endToken":6036},{"p":21,"at":1038,"title":"CONCLUSION","method":"printed heading","endPage":23,"endAt":6,"startToken":6036,"endToken":6234},{"p":23,"at":6,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":24,"endAt":0,"startToken":6234,"endToken":6290},{"p":24,"at":0,"title":"ATTACHMENT A","method":"printed heading","endPage":26,"endAt":287,"startToken":6290,"endToken":6383},{"p":26,"at":287,"title":"I. Introduction","method":"printed heading","endPage":26,"endAt":355,"startToken":6383,"endToken":6391},{"p":26,"at":355,"title":"A. My name is Houtan Moaveni. I am a Vice President at Grid Strategies LLC, where I advise on","method":"printed heading","endPage":27,"endAt":469,"startToken":6391,"endToken":6639},{"p":27,"at":469,"title":"A. The purpose of my testimony is to evaluate the Zero Injection Generator Interconnection","method":"printed heading","endPage":28,"endAt":503,"startToken":6639,"endToken":6948},{"p":28,"at":503,"title":"II. Summary of Findings","method":"printed heading","endPage":28,"endAt":603,"startToken":6948,"endToken":6962},{"p":28,"at":603,"title":"A. MISO proposes a new form of interconnection service, ZG Interconnection Service, for a","method":"printed heading","endPage":29,"endAt":318,"startToken":6962,"endToken":7200},{"p":29,"at":318,"title":"A. Based on my review of the Filing, I have identified the following issues:","method":"printed heading","endPage":32,"endAt":1125,"startToken":7200,"endToken":8166},{"p":32,"at":1125,"title":"III. Enforceability of the Operating Requirements","method":"printed heading","endPage":32,"endAt":1290,"startToken":8166,"endToken":8189},{"p":32,"at":1290,"title":"A. MISO proposes the following:","method":"printed heading","endPage":34,"endAt":1056,"startToken":8189,"endToken":8752},{"p":34,"at":1056,"title":"A. The proposed measures do not provide adequate assurance that the zero-injection obligation","method":"printed heading","endPage":35,"endAt":143,"startToken":8752,"endToken":8938},{"p":35,"at":143,"title":"A. The proposed contractual remedy functions only as a last-resort backstop. It offers no","method":"printed heading","endPage":42,"endAt":122,"startToken":8938,"endToken":11044},{"p":42,"at":122,"title":"A. Only in part. The standard that determines whether an injection is permitted is not in the Tariff,","method":"printed heading","endPage":47,"endAt":1059,"startToken":11044,"endToken":12619},{"p":47,"at":1059,"title":"A. Only in part. The requirements to verify compliance with the proposal’s operational provisions","method":"printed heading","endPage":50,"endAt":221,"startToken":12619,"endToken":13427},{"p":50,"at":221,"title":"IV. Modeling Assumptions and Cost Allocation","method":"printed heading","endPage":50,"endAt":344,"startToken":13427,"endToken":13443},{"p":50,"at":344,"title":"A. Two features of MISO’s proposal bear on who bears transmission costs and when. The first is","method":"printed heading","endPage":50,"endAt":1076,"startToken":13443,"endToken":13553},{"p":50,"at":1076,"title":"A. MISO attributes much of the value of a ZGIA to transmission planning. MISO’s witness states","method":"printed heading","endPage":55,"endAt":4,"startToken":13553,"endToken":14875},{"p":55,"at":4,"title":"A. The models used to study ZG requests exclude the pending interconnection queue. MISO states","method":"printed heading","endPage":58,"endAt":1675,"startToken":14875,"endToken":15981},{"p":58,"at":1675,"title":"A. Yes. The ERAS process has produced executed interconnection agreements, and one of them","method":"printed heading","endPage":60,"endAt":701,"startToken":15981,"endToken":16410},{"p":60,"at":701,"title":"A. No. The Filing contains several provisions that bear on the question, but none of them functions","method":"printed heading","endPage":63,"endAt":169,"startToken":16410,"endToken":17257},{"p":63,"at":169,"title":"A. No. The Filing’s one meaningful transparency provision is that executed ZGIAs will be filed","method":"printed heading","endPage":65,"endAt":4,"startToken":17257,"endToken":17788},{"p":65,"at":4,"title":"V. Eligibility and Limitations on the ZGIA Process","method":"printed heading","endPage":65,"endAt":124,"startToken":17788,"endToken":17807},{"p":65,"at":124,"title":"A. MISO states that the requirements are facially neutral, fuel-agnostic, and open to any resource","method":"printed heading","endPage":66,"endAt":1719,"startToken":17807,"endToken":18337},{"p":66,"at":1719,"title":"A. The Filing imposes several project-level eligibility constraints, while the program as a whole","method":"printed heading","endPage":67,"endAt":1284,"startToken":18337,"endToken":18572},{"p":67,"at":1284,"title":"A. The Filing contains no sunset date for the ZGIA process. It contains no aggregate cap on the","method":"printed heading","endPage":69,"endAt":121,"startToken":18572,"endToken":18959},{"p":69,"at":121,"title":"A. There are two principal consequences. First, the Filing does not examine how a growing share","method":"printed heading","endPage":70,"endAt":1059,"startToken":18959,"endToken":19418},{"p":70,"at":1059,"title":"VI. Conclusion","method":"printed heading","endPage":70,"endAt":1115,"startToken":19418,"endToken":19426},{"p":70,"at":1115,"title":"A. Yes.","method":"printed heading","endPage":72,"endAt":675,"startToken":19426,"endToken":19689}]}