EL26-68-000 · 2026-08-03 · Southwest Power Pool, Inc.AMERICAN ELECTRIC POWER SERVICE CORPORATIONEVERGY, INC. ,GRIDLIANCE HIGH PLAINS LLC ,ITC GREAT PLAINS LLC ,

Amended Joint Motion of Southwest Power Pool, Inc. et al. to Hold Section 206 Proceeding in Abeyance

1 
 
UNITED STATES OF AMERICA 
BEFORE THE  
FEDERAL ENERGY REGULATORY COMMISSION 
Southwest Power Pool, Inc.  
 
 ) 
  
Docket No. EL26-68-000 
 
 
 
 
 
 
 
JOINT MOVANTS’ AMENDED MOTION  
TO HOLD SECTION 206 PROCEEDING IN ABEYANCE 
 
Southwest Power Pool, Inc. (“SPP”), American Electric Power Service 
Corporation, Evergy, Inc., GridLiance High Plains LLC, ITC Great Plains, LLC, 
Mountrail-Williams Electric Cooperative, NextEra Energy Transmission Southwest, LLC, 
Northwestern Energy, Upper Missouri G. & T. Electric Cooperative, Inc. d/b/a Upper 
Missouri Power Cooperative, Oklahoma Gas and Electric Company, Tri-State Generation 
and Transmission Association, Inc., and Xcel Energy Services Inc.  (collectively known as 
“Joint Movants”), pursuant to Rule 212 of the Rules of Practice and Procedure of the 
Federal Energy Regulatory Commission (“Commission”), respectfully move the 
Commission to (i) hold this proceeding, including the deadline for responding to the 
briefing questions, in abeyance for ninety-five (95) days, up to and including November 
20, 2026; and (ii) establish a five (5) day answer period and act on this Motion as 
expeditiously as practicable thereafter. 1  
I. 
INTRODUCTION 
 
On June 18, 2026, the Commission issued an order instituting a proceeding under 
Section 206 of the Federal Power Act (“FPA”) concerning large loads (“Show Cause 
Order”).2  In the Show Cause Order, the Commission preliminarily found that the existing 
 
1  
Deseret Generation & Transmission Co-operative, Inc. (“Deseret”) is not joining as a Joint 
Movant, but Deseret has informed SPP that it does not object to this Motion. 
2  
Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026).

2 
 
SPP Open Access Transmission Tariff (“Tariff”)3 governing service to large loads appeared 
to be unjust, unreasonable, or unduly discriminatory or preferential.4 The Commission 
directed SPP and the jurisdictional Transmission Owners, within sixty (60) days of the 
issuance of the Show Cause Order, to either: 
1. Show cause why the Tariff remains just and reasonable and not unduly 
discriminatory or preferential notwithstanding the absence of provisions that: 
a. require the evaluation of alternative transmission technologies and 
memorialize ongoing operational requirements in a transmission service 
agreement between SPP and the Transmission Customer taking 
transmission service on behalf of a large load; 
b. provide additional transparency regarding Network Upgrade costs, establish 
a pro forma cost recovery agreement to mitigate the risk of cost shifting, 
and ensure appropriate crediting of such payments toward Transmission 
Owners' transmission revenue requirements; 
c. address the rates, terms, and conditions applicable to interconnection 
customers serving co-located loads; and 
d. address transmission service for co-located loads, load served by Behind-
The-Meter Generation, and flexible large loads willing and able to limit 
their use of the transmission system under certain conditions; or 
 
3  
Southwest Power Pool, Inc., Open Access Transmission Tariff, Sixth Revised Volume No. 
1. 
4  
Show Cause Order at P 3.

3 
 
2. explain what revisions to the Tariff would remedy the Commission's identified 
concerns should the Commission determine that the Tariff has become unjust and 
unreasonable or unduly discriminatory or preferential and therefore establish 
replacement Tariff provisions.5 
The Show Cause Order expressly contemplates an abeyance to permit SPP and its 
stakeholders to develop proposed Tariff revisions to address the identified concerns. 
Specifically, the Commission states that it: 
will consider requests from SPP and/or the Transmission 
Owners to hold, for up to 90 days, all or certain aspects of this 
FPA section 206 proceeding in abeyance, including the 
deadline to respond to this order. Any such abeyance, which 
will begin as of the deadline to respond to this order, would 
be considered to provide SPP and the Transmission Owners 
time while they work through the stakeholder processes to 
develop FPA section 205 filings to revise the Tariff to address 
the issues raised in this order.6 
 
Joint Movants respectfully request that the Commission hold this proceeding in 
abeyance for ninety-five (95) days, up to and including November 20, 2026. Joint Movants 
acknowledge that the requested abeyance exceeds the ninety (90) days contemplated by 
the Show Cause Order. The additional five (5) days is necessary to accommodate SPP’s 
full stakeholder process, which culminates in a scheduled Board of Directors (“Board”) 
meeting,7 as further discussed in Sections III and V of this Motion. This Motion is timely 
 
5  
Id.  
6  
Id. at P 33.  
7  
This Board of Directors meeting time has already been adjusted to avoid conflicts with 
Election Day and Nation Association of Regulatory Utility Commissioners (“NARUC”) 
annual meeting dates. Avoiding widespread conflicts to allow meeting participants to more 
fully prepare and focus on meetings is important for robust and meaningful participation.

4 
 
because it is being filed within forty-five (45) days of the issuance of the Show Cause 
Order.8 
II. 
GOOD CAUSE EXISTS TO HOLD THIS PROCEEDING IN ABEYANCE  
Good cause exists to grant the Joint Movants' abeyance request. Granting the 
requested abeyance will allow SPP to utilize its stakeholder process to develop 
comprehensive Tariff revisions responsive to the Show Cause Order. The issues identified 
by the Commission involve numerous, interrelated aspects of the Tariff, and developing 
proposed Tariff revisions addressing these issues requires careful technical analysis, 
coordination among numerous stakeholder groups and membership sectors, and 
consideration through SPP's governance process before any proposed revisions can be 
presented to the Board for approval and filed with the Commission pursuant to Section 205 
of the FPA. 
The requested abeyance also will promote administrative efficiency. Absent an 
abeyance, SPP, Transmission Owners, stakeholders, and the Commission would be 
required to simultaneously litigate the issues raised in this Section 206 proceeding while 
SPP conducts the stakeholder process necessary to develop potential Tariff revisions 
addressing those same issues. By contrast, the requested abeyance will allow SPP to focus 
its efforts on developing a comprehensive Section 205 filing or a package of Section 205 
filings that responds to the Commission's concerns through its stakeholder process, thereby 
potentially narrowing or resolving issues that otherwise would be litigated in this 
proceeding. In addition, feedback received through the stakeholder process has the 
 
8  
Show Cause Order at P 33. The Show Cause Order requires any request for abeyance to 
be filed within forty-five (45) days of the issuance of the Show Cause Order.

5 
 
potential to raise and resolve other technical or legal concerns with the language that will 
mitigate the risk of needing further Tariff change. 
Moreover, the requested abeyance will not prejudice any party. During the limited 
abeyance period, the existing Tariff will remain in effect, and no party's substantive rights 
will be altered. The requested relief provides the time necessary for SPP to complete the 
stakeholder process the Commission expressly contemplated as the vehicle for developing 
potential Tariff revisions responsive to the Show Cause Order. In addition, it allows SPP 
time to work with stakeholders and vendors to help avoid technical challenges and achieve 
orderly implementation of changes to non-Tariff governing documents, software, 
procedures, and workflows. 
Finally, granting the requested abeyance serves the public interest because, as 
discussed further below, it will allow SPP sufficient time to develop comprehensive, well-
vetted Tariff revisions through its established stakeholder process rather than requiring 
expedited proposals that have not benefited from the full consideration contemplated and 
required by SPP's governance structure. Accordingly, good cause exists to grant this 
Motion.  
III. 
SPP’S STAKEHOLDER PROCESS NECESSITATES ADDITIONAL TIME 
TO DEVELOP TARIFF REVISIONS RESPONSIVE TO THE SHOW 
CAUSE ORDER  
 
SPP's stakeholder process is the appropriate forum through which potential Tariff 
revisions responsive to the Commission's concerns should be developed. Consistent with 
the SPP Bylaws, stakeholder input is developed primarily through SPP's Organizational 
Groups.9 The Markets and Operations Policy Committee ("MOPC"), through its designated 
 
9  
Southwest Power Pool, Inc., Bylaws, First Revised Volume No. 1, Section 1.0, Definitions 
of Organizational Group (“A group, other than the Board of Directors and the Members

6 
 
Organizational Groups, develops and recommends policies and procedures governing the 
operation and administration of the Tariff before those recommendations are considered by 
the Board.10 Proposed Tariff revisions are developed through SPP's Revision Request 
(“RR”) process and proceed through the appropriate working groups and task forces, where 
stakeholders evaluate draft language, identify operational and implementation concerns, 
recommend refinements, and develop consensus recommendations before proposals are 
considered by MOPC and, ultimately, the Board for authorization to file under Section 205 
of the FPA. The stakeholder process is particularly important in the context of the Show 
Cause Order because it raises issues spanning multiple functional areas of the Tariff and 
affects a broad range of stakeholder interests and implicates many aspects of SPP’s 
operations. The stakeholder process is more than just a series of public meetings on Tariff 
language; it allows for widespread feedback and vetting of process changes whose 
implementation details are complex to design and effectuate. The iterative nature of SPP's 
stakeholder process ensures that proposed Tariff revisions are informed by the technical, 
operational, commercial, legal, and regulatory expertise of the entities that will be 
responsible for implementing and operating under those revisions.  
The current sixty-day (60) response period does not provide sufficient time to 
complete this stakeholder process in a meaningful manner. By contrast, the requested 
ninety-five (95) day abeyance will permit, although still on an expedited time frame, SPP 
to convene the necessary stakeholder meetings, develop and refine draft revisions to the 
 
Committee, comprising a committee or working group that is charged with specific 
responsibilities toward accomplishing SPP’s mission.”). 
10  
Id. at Section 6.1.

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Tariff and other affected governing documents, solicit and incorporate stakeholder 
feedback, obtain the approvals required by the SPP Bylaws, and prepare a comprehensive 
filing under Section 205 of the FPA. Granting the requested abeyance therefore will 
facilitate the development of more complete, thoroughly vetted Tariff revisions and provide 
the Commission with a more robust record upon which to evaluate SPP's proposed 
response.  
The SPP Board was originally scheduled to meet on November 3, 2026. Because 
this was scheduled for Election Day, the leadership of the Regional State Committee 
(“RSC”), many of whom are elected officials in their state, requested that SPP reschedule 
the SPP Board’s quarterly meeting to ensure that all of the members of the RSC are able to 
participate. The next week, November 10, 2026, was considered for the SPP Board 
meeting, but that date conflicted with the 2026 NARUC Annual Meeting and Education 
Conference.11 Most of the members of the RSC will attend the 2026 NARUC Annual 
Meeting. To accommodate Election Day and the previously scheduled NARUC annual 
meeting, the SPP Board meeting was scheduled for the following week on November 17, 
2026. SPP acknowledges that its requested abeyance exceeds the ninety (90) days 
contemplated by the Show Cause Order but submits that the additional five (5) days is 
necessary to accommodate its full stakeholder process, which culminates in a scheduled 
Board meeting, and ensures full participation by members of the RSC. 
 
 
 
11  
NARUC Annual Meeting: https://www.naruc.org/events/all-events/2026-naruc-annual-
meeting-and-education-conference/.

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IV. 
ANTICIPATED SECTION 205 FILING 
Unlike a typical request to defer a procedural deadline, the Commission expressly 
directed respondents seeking abeyance to provide a detailed description of the anticipated 
Tariff revisions that would be developed during the requested abeyance period.12 
Consistent with that directive, this section summarizes the principal subject areas that SPP 
presently anticipates will be developed through its ongoing stakeholder process and 
addressed in a filing under Section 205 of the FPA.13 
A. 
Transmission Service to Eligible Customers on Behalf of Large Loads 
In the Show Cause Order, the Commission finds that the Tariff is preliminarily 
unjust and unreasonable because it does not require (1) the evaluation of alternative 
transmission technologies in transmission service request studies, in all instances, without 
the need for a request from the Eligible Customer seeking transmission service on behalf 
of a large load; and (2) if traditional Network Upgrades are selected instead of alternative 
transmission technologies, inclusion in the study report to the Eligible Customer seeking 
transmission service on behalf of a large load of a sufficiently clear demonstration of why 
alternative transmission technologies are not feasible or would not result in lower costs or 
a faster timeline for accommodating the transmission service request.14  
 
12  
Show Cause Order at P 33. 
13  
These descriptions are necessarily preliminary and are intended to provide the Commission 
with a good-faith understanding of the anticipated scope of SPP's efforts during the 
requested abeyance period. SPP continues to work internally and with its stakeholders to 
determine the full scope of appropriate Tariff revisions. Accordingly, the descriptions 
below should not be construed as an exhaustive or final statement of the Tariff changes that 
may be included in a future Section 205 filing. 
14  
Show Cause Order at P 45.

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SPP recently implemented its High Impact Large Load ("HILL")15 process to 
provide an expedited framework for evaluating transmission service requests associated 
with large loads.16 Although the HILL Delivery Point Study (“HDPS”) process includes 
enhanced study analyses to ensure that the unique operational characteristics of HILLs are 
considered when evaluating the addition of a HILL to the Transmission System, and that 
SPP has mechanisms in place to maintain reliable operation of the Transmission System,17 
it does not currently require SPP to evaluate alternative transmission technologies when 
studying HILLs.18 Accordingly, SPP currently anticipates working through its stakeholder 
process to develop revisions to incorporate such an evaluation into the study process. 
SPP currently anticipates that this effort will include consideration of the point 
during the study process in which alternative transmission technologies should be 
evaluated, the technologies that should be considered, and the information that should be 
documented in study reports regarding those evaluations. Development of these revisions 
will require coordinated review and technical analysis by multiple stakeholder groups and 
 
15  
Tariff at Part I, Section 1, defines a HILL as “A new commercial or industrial load, or 
increase in commercial or industrial load, at a single site connected through one or more 
shared Points of Interconnection (POIs) or delivery points, where such load is either (1) 10 
MW or more if connected to the Transmission System at a voltage level less than or equal 
to 69 kV; or (2) 50 MW or more if connected to the Transmission System at a voltage level 
greater than 69 kV. An Electric Storage Resource is not considered a HILL. A load may be 
categorized as a HILL after the initial effective date of Attachment BA of the Tariff.  High 
Impact Large Loads must register as such in accordance with Attachment AE of the Tariff 
and follow the processes specified in Attachment BA of the Tariff.”. 
16  
Tariff, Attachment BA. 
17  
Tariff, Attachment BA, Section 2.1.3.4. The HDPS is a supplemental assessment, in 
addition to the studies required pursuant to Attachment AQ, Attachment AX, and/or 
Attachment BC of the Tariff, of the impact of a requested HILL delivery point 
configuration change on the Transmission System.  
18  
Id.

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subject matter experts and ensure that any proposed revisions do not cause unintended 
impacts to Commission approved processes addressing interconnection of large loads. 
Second, the Commission found that the HILL process does not include pro forma 
provisions in transmission service agreements between SPP and the Transmission 
Customer taking transmission service on behalf of a HILL that memorialize ongoing 
operational requirements.19 The Commission recognized that these operational 
requirements do exist in the Tariff but expressed concern that without pro forma provisions 
in the transmission service agreement between SPP and the Transmission Customer, SPP 
may be unable to enforce the ongoing operational requirements of HILLs.20 
Accordingly, SPP currently anticipates working through its stakeholder process to 
develop revisions to the Tariff's pro forma transmission service agreements, namely the 
Network Integration Transmission Service Agreement21 and the Form of Service 
Agreement for Firm Point-To-Point Transmission Service,22 that would incorporate the 
applicable operational requirements for HILLs. Because revisions to the pro forma service 
agreements affect the contractual rights and obligations of Transmission Customers and 
SPP, their development requires stakeholder review and collaboration. 
B. 
Cost Shifting Risk Among Transmission Customers 
The Commission preliminarily found that the Tariff is unjust and unreasonable 
because it does not require the public posting, of information regarding transmission 
 
19  
Show Cause Order at P 46. 
20  
Id. 
21  
Tariff, Attachment F.  
22  
Tariff, Attachment A.

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service requests associated with large loads and the Network Upgrades necessary to 
provide such service.23 Specifically, the Commission identified the absence of Tariff 
provisions governing the disclosure of information regarding Network Upgrades driven by 
large loads, associated cost estimates, the requesting entity, project status within SPP's 
planning process, aggregate large load additions, and related transmission planning 
information. The Commission acknowledges that SPP provides some information to 
stakeholders regarding the cost of Network Upgrades but that the Tariff does not explicitly 
contain provisions that require SPP to publicly post estimates for Network Upgrades 
necessary to provide transmission service to Eligible Customers on behalf of large loads.24 
SPP anticipates that stakeholders will evaluate development of new Tariff 
provisions governing the public reporting of transmission planning and transmission 
service information associated with large loads including (1) the categories of information 
that should be publicly reported with respect to HILLs; (2) the identification of Network 
Upgrades associated with HILLs; (3) the disclosure of estimated Network Upgrade costs 
associated with HILLs; (4) reporting regarding aggregate large load additions throughout 
the SPP footprint and within individual transmission pricing zones; (5) identification of 
project status within SPP's transmission planning process; (6) the frequency with which 
information should be updated; (7) the format in which information should be made 
publicly available; and (8) any necessary confidentiality limitations. Although the 
Commission identified the categories of information it preliminarily believes should be 
 
23  
Show Cause Order at PP 52-54. 
24  
Id. at P 55.

12 
 
publicly available, substantial stakeholder input remains necessary to determine how those 
reporting requirements should be implemented. 
Next, the Commission finds that the Tariff lacks a pro forma cost recovery 
agreement between SPP, the relevant Transmission Owner, and the Eligible Customer 
serving a large load that requires the Eligible Customer to make a minimum contribution 
toward the Transmission Owner’s transmission revenue requirement, if the Eligible 
Customer ultimately takes less transmission service than anticipated because the large load 
does not materialize as planned or is not developed at all.25 The Commission also found 
that the minimum contribution required pursuant to such cost recovery agreement should 
be based on the level of jurisdictional transmission service requested by the Eligible 
Customer on behalf of the large load and that such cost recovery agreement should include 
a credit support or other financial security requirement sufficient to secure the obligations 
of the Eligible Customer taking transmission service on behalf of a large load to pay the 
amounts owed pursuant to the cost recovery agreement.26 
SPP has initiated a comprehensive stakeholder effort through its Cost Control and 
Allocation Review & Evaluation Team (“CARE Team”)27 to evaluate potential Tariff 
revisions responsive to the Commission's concerns regarding cost mitigation and cost 
 
25  
Show Cause Order at PP 61-63. 
26  
Id. at P 65. 
27  
The CARE Team was established in November 2025 to serve as a cross-functional 
leadership body to review, evaluate, assess, and recommend refinements or alternatives to 
the current transmission cost controls and cost allocation methodologies in SPP including 
cost allocation challenges associated with large load growth and related infrastructure 
needs. See CARE Team Organizational Group Scope Statement (November 2025) located 
at: https://www.spp.org/spp-documents-filings/?id=552360.

13 
 
shifting.28 Stakeholders are presently evaluating multiple alternative approaches to address 
this specific concern. Although no specific approach has be determined by the CARE 
Team, the following are some of the alternative approaches being considered: (1) 
establishment of financial security requirements securing the cost of Base Plan Upgrades 
constructed to serve large load delivery points; (2) direct assignment, in whole or in part, 
of Network Upgrade costs associated with large load delivery point additions or 
modifications; (3) combinations of direct assignment and financial security designed to 
satisfy the Commission's minimum contribution expectations while preserving appropriate 
Base Plan funding principles; (4) other  mechanisms for ensuring a minimum contribution 
from Transmission Customers serving large loads; and (5) corresponding revisions 
governing the disposition of recovered funds to ensure that any amounts recovered are 
applied to reduce costs otherwise borne by Transmission Customers.  
With respect to the financial security framework, stakeholders have already begun 
consideration of numerous implementation questions including, but not limited to: (1) the 
appropriate amount and form of any required financial security; (2) the period of time that 
should be allowed for the load to materialize before a claim is made on the financial 
security; (3) how long the load should remain in place in order to avoid a claim on the 
financial security; (4) whether the financial security should be assessed in part if the load 
that materializes is less than predicted; (5) how the delivery point should be quantified for 
the purpose of assessing a potential claim on security; and (6) whether projected operating 
and maintenance expense of the upgrade should be included in the financial security 
 
28  
CARE Meeting Materials, dated July 23, 2026, at Agenda Item 7 posted at: 
https://www.spp.org/spp-documents-filings/?id=552361.

14 
 
requirement. With respect to the potential direct charge framework, stakeholders have also 
begun considering: (1) whether to apply full or partial direct assignment of delivery point 
upgrade costs; (2) if such direct assignment is partial, how the partial direct assignment 
should be implemented and whether the direct assignment should take the form of capital 
cost only or revenue requirements over a fixed period; and (3) whether a form of minimum 
charge other than, or in addition to, direct assignment of delivery point costs would be 
appropriate.  
These multiple alternatives present significant policy choices that extend far 
beyond drafting of Tariff language, implicating fundamental cost allocation principles that 
have governed SPP's transmission planning and funding framework for many years. 
Implementation of the alternatives presently under consideration will require coordinated 
revisions across multiple components of the Tariff, introducing interrelated policy and 
implementation issues that underscore the importance of meaningful stakeholder 
development. 
C. 
Co-Location Arrangements and Load with Behind-The-Meter 
Generation 
 
The Commission preliminarily found that the Tariff should provide greater clarity 
regarding the treatment of co-located29 resources and behind-the-meter generation, 
including the circumstances under which such resources are subject to the Tariff's 
 
29  
The Show Cause Order defines co-located load as a configuration that refers to end-use 
customer load that is physically connected to the facilities of an existing or planned 
generating facility on the interconnection customer’s side of the point of interconnection 
to the RTO/ISO’s transmission system. In the Show Cause Order, the Commission uses the 
term co-location arrangement when referring to both the co-located load and the associated 
generating facility.

15 
 
transmission service, interconnection, and market participation requirements.30 The 
Commission expressed concern regarding the absence of Tariff provisions addressing 
transmission and ancillary service rates for Eligible Customers taking transmission service 
on behalf of Eligible Load.31  
Stakeholder development is necessary to determine, among other things, (1) the 
appropriate terminology and definition used to describe generators interconnected to 
facilities that are not connected to the Transmission System; (2) the study process 
applicable to such generators; and (3) the overlap between transmission service, 
interconnection, and market registration requirements. Stakeholder coordination is 
essential to development of a comprehensive framework that provides the clarity sought 
by the Commission.  
D. 
Extending New Transmission Services to Eligible Customers Taking 
Service on Behalf of Flexible Large Loads  
 
The Commission preliminarily found  the Tariff unjust and unreasonable because it 
does not include transmission services that reflect Eligible Customers taking transmission 
service on behalf of flexible large loads32 that are willing and able to limit their use of the 
Transmission System under certain conditions.33 The Commission required SPP to explain 
 
30  
Show Cause Order at PP 75-80. 
31  
Id. at PP 77, 80-82. 
32  
The Show Cause Order clarifies that, for purposes of the Show Cause Order, “flexible” 
large loads are a subset of HILLs that are not co-located with generation but are willing 
and able to limit their energy withdrawals from the Transmission System under certain 
conditions. See Show Cause Order at n.163. 
33  
Show Cause Order at P 86.

16 
 
whether the Tariff remains just and reasonable without (1) an interim non-firm network 
transmission service while Network Upgrades are being constructed (i.e., interim NITS) 
and (2) permanent firm and non-firm contract demand transmission services.34  
The Commission expressly noted SPP’s Price Adaptative Load (“PAL”) and Price 
Adaptive Load Service (“PALS”) proposal (collectively “PAL/PALS”), which is currently 
under stakeholder development, and urged SPP to consider whether PALS would address 
the Commission’s concern that the Tariff may be unjust and unreasonable because it does 
not include transmission services that reflect the use of the Transmission System by 
Eligible Customers on behalf of flexible large load.35 Unlike traditional transmission 
service, the PAL/PALS framework would establish both a new market participation model 
and a new non-firm transmission service designed specifically for dispatchable, price-
responsive large loads. Under the current proposal, participating loads would submit price-
sensitive bids into SPP's Integrated Marketplace and would be required to respond to Day-
Ahead Market commitments and Real-Time Balancing Market dispatch instructions. 
Correspondingly, PALS would establish a new transmission service under which 
participating loads would receive transmission service subject to usage-based pricing, 
mandatory dispatchability requirements, and Curtailment during transmission constraints, 
Emergency Conditions, or local reliability events. As explained in SPP’s Informational 
Report,36 the PAL/PALS initiative has already progressed through extensive stakeholder 
 
34  
Id. at P 87. 
35  
Id. at P 88. 
36  
Informational Report of Southwest Power Pool, Inc., Docket No. EL26-68-000, at 25 
(July 20, 2026).

17 
 
education and preliminary design. SPP anticipates continued stakeholder review over the 
next several months with formal, with final approval anticipated on November 17, 2026. 
Continued stakeholder review and collaboration is needed before approval of the 
PAL/PALS framework.  
In addition to PALS, SPP anticipates stakeholder consideration of revisions to 
existing transmission service product(s), such as the Conditional High Impact Large Load 
Service (CHILLS), to include control technologies and/or protection systems designed to 
limit energy withdrawals from the Transmission System. Continued stakeholder 
collaboration is necessary because incorporating control technologies and/or protection 
systems into existing transmission service products implicates technical, operational, and 
policy considerations extending well beyond the development of Tariff language.  
V. 
OVERALL SCHEDULE AND ANTICIPATED SECTION 205 FILING 
TIMELINE 
 
Draft RRs addressing several of the Commission's preliminary findings are 
expected to be posted for stakeholder review in early August 2026. Throughout the 
requested abeyance period, the proposals will proceed through technical development, 
stakeholder education, policy discussions, and formal review by the applicable working 
groups, culminating in working group votes during September and October, MOPC in 
October, the RSC where applicable in November, and final Board consideration on 
November 17, 2026. SPP anticipates the same timeline for approval and filing of the 
PAL/PALS RR.   
Accordingly, Joint Movants respectfully request that the Commission hold this 
proceeding in abeyance until November 20, 2026, and establish that date as the deadline 
for SPP to respond to the Show Cause Order through a comprehensive filing under Section

18 
 
205 of the FPA. A ninety-five (95) day abeyance is necessary because the Board must 
provide final authorization for the Section 205 filing described herein and is not scheduled 
to meet until November 17, 2026.37 Following Board authorization, SPP requires a brief 
period to finalize and submit the resulting Section 205 filing(s) to comply with the Show 
Cause Order. 
VI. 
REQUEST 
FOR 
SHORTENED ANSWER 
PERIOD, 
EXPEDITED 
COMMISSION ACTION, AND REQUEST FOR ABEYANCE OF THE 
DEADLINE TO RESPOND TO THE BRIEFING QUESTIONS 
 
Joint Movants respectfully request that the Commission establish a five (5) day 
period for answers to this Motion38 and act as expeditiously as practicable thereafter. As 
the Commission recognized in the Show Cause Order, requests for abeyance must be filed 
sufficiently in advance of the August 17, 2026, response deadline to allow the Commission 
adequate time to act before that deadline expires. Prompt action on this Motion will provide 
SPP and its stakeholders with certainty regarding the applicable timeline and avoid the 
need to simultaneously prepare both a response to the Show Cause Order and the 
anticipated Section 205 filing. Absent timely action, SPP would be required to devote 
substantial resources to preparing filings that may ultimately prove unnecessary if the 
requested abeyance is granted. Expedited consideration therefore will promote 
 
37  
The Board’s regularly scheduled meetings occur quarterly and are scheduled many months 
in advance. This Board of Directors meeting time has already been adjusted to avoid 
conflicts with Election Day and NARUC meeting dates. Avoiding widespread conflicts to 
allow meeting participants to more fully prepare and focus on meetings is important for 
robust and meaningful participation. 
38  
To the extent necessary, SPP requests waiver of Rule 213 of the Commission’s Rules of 
Practice and Procedure, 18 C.F.R.§ 385.213, which provides that an answer to a motion 
must be filed within 15 days, unless otherwise ordered. The Show Cause Order requires 
abeyance requests to be filed by August 3, 2026, and expressly contemplates that the 
Commission will issue an order on any such request prior to the response deadline of 
August 17, 2026 (14 days after the abeyance request deadline).

19 
 
administrative efficiency and further the purpose for which the Commission authorized 
parties to seek an abeyance. 
In addition, because the Show Cause Order establishes a single deadline for both 
Joint Movants' response and their responses to the accompanying briefing questions, Joint 
Movants respectfully request that any order granting this Motion also apply to and defer 
the deadline to submit responses to the briefing questions proposed in the Show Cause 
Order. The briefing questions seek Joint Movants' views regarding the very Tariff revisions 
and policy determinations currently under stakeholder development. Accordingly, 
responses submitted following completion of that process will provide the Commission 
with a more complete and useful record than preliminary responses prepared before 
stakeholders have developed the comprehensive Tariff revisions contemplated in this 
Motion. 
VII. 
CONCLUSION 
 
For the reasons stated herein, Joint Movants respectfully request the Commission:  
(1) Grant this Motion and hold the above-captioned proceeding in abeyance for 
ninety-five (95) days, up to and including November 20, 2026, to permit SPP to complete 
its stakeholder process and submit a comprehensive filing under Section 205 of the FPA 
addressing the Commission's preliminary findings in the Show Cause Order; 
(2) Find that, if the requested abeyance is granted, the deadline for Joint Movants’ 
responses to the briefing questions accompanying the Show Cause Order likewise are held 
in abeyance and deferred to November 20, 2026; 
(3) Establish a five (5) day period for answers to this Motion; and

20 
 
(4) Act on this Motion as expeditiously as practicable following the close of the 
answer period. 
 
Respectfully submitted, 
/s/ Meredith Powell  
 
Meredith Powell 
Justin A. Hinton 
Emon O. Mahony 
Southwest Power Pool, Inc. 
201 Worthen Drive 
Little Rock, AR 72223 
   
Attorneys for 
Southwest Power Pool, Inc. 
 
 
/s/ Shannon M. Heim 
Shannon M. Heim 
General Counsel, Vice President – Federal 
Government Affairs & FERC Compliance 
Officer 
NorthWestern Energy 
208 N. Montana Ave., Suite 200 
Helena, MT 59601 
 
Attorney for NorthWestern Energy 
/s/ John C. Crespo 
Senior Legal Counsel 
American Electric Power Service  
Corporation 
1 Riverside Plaza, 29th Floor 
Columbus, OH 43215 
Phone: (614) 716-3727 
Email: jccrespo@aep.com 
 
Attorney for American Electric Power 
Service Corporation 
 
/s/ C. Patrick Woods 
C. Patrick Woods 
President 
ITC Great Plains, LLC 
3500 SW Fairlawn Rd., Ste. 101 
Topeka, KS 66614 
 
On Behalf of ITC Great Plains, LLC 
/s/ Denise Buffington 
Denise Buffington 
Senior Director Federal Regulatory Affairs 
EVERGY, INC. 
1200 Main St. 
Kansas City, MO 64105 
 
On Behalf of EVERGY, INC.

21 
 
 
 
/s/ Carly Masenthin 
Carly Masenthin 
Corporate Counsel  
EVERGY, INC. 
818 S Kansas Avenue 
Topeka, Kansas 66612 
 
Attorney for EVERGY, INC. 
 
/s/ Travis M. Contratto 
Travis M. Contratto 
Principal Attorney 
NextEra Energy, Inc. 
801 Pennsylvania Avenue NW 
Suite 220 
Washington, DC 20004 
 
Attorney for NextEra Energy 
Transmission Southwest, LLC and 
GridLiance High Plains LLC 
 
/s/ A. Chase Snodgrass 
A. Chase Snodgrass, OBA No. 33275 
Senior Regulatory Attorney 
Oklahoma Gas and Electric Company 
321 N. Harvey Ave. M/C 300 
Oklahoma City, OK 73102 
 
Attorney for Oklahoma Gas and 
Electric Company 
 
/s/ Allison E. S. Salvia 
Allison E. S. Salvia 
Eversheds Sutherland (US) LLP 
700 Sixth St., N.W., Suite 700 
Washington, DC 20001-3980 
 
Attorney for Upper Missouri Power 
Cooperative 
/s/ Michael A. Monson 
Michael A. Monson 
Billstein, Monson & Small PLLC 
1555 Campus Way, Suite 201 
Billings, MT 59102 
 
Attorney for Upper Missouri Power 
Cooperative 
 
/s/ Jeremy Mahowald 
Jeremy Mahowald 
General Manager 
Upper Missouri Power Cooperative 
111 2nd Ave. SW 
Sidney, MT 59270 
 
On Behalf of Upper Missouri Power 
Cooperative  
 
/s/ Jesse Halpern 
Jesse Halpern 
Thompson Coburn LLP 
1909 K Street, N.W. 
Suite 600 
Washington, D.C. 20006 
 
Counsel for Montrail-Williams Electric 
Cooperative 
 
 
 
/s/ Ryan Hubbard 
Vice President, Transmission Planning 
Policy 
Tri-State Generation & Transmission 
Association, Inc. 
1100 West 116th Avenue  
Westminster, CO 80234  
 
On Behalf of Tri-State Generation & 
Transmission Association, Inc.

22 
 
 
 
/s/ Tyler Nemkov 
Senior Regulatory Attorney 
Tri-State Generation & Transmission 
Association, Inc. 
1100 West 116th Avenue  
Westminster, CO 80234  
 
Attorney for Tri-State Generation & 
Transmission Association, Inc. 
 
 
 
/s/ Timothy T. Mastrogiacomo 
Timothy T. Mastrogiacomo 
Vice President, Federal Regulatory, Legal, 
and Policy 
Xcel Energy Services Inc. 
701 Pennsylvania Avenue, NW, Ste. 250 
Washington, DC 20006 
 
On Behalf of Xcel Energy Services Inc. 
 
 
 
 
August 3, 2026

23 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Little Rock, Arkansas, this 3rd day of August, 2026. 
 
 /s/ Cassie Butler 
Cassie Butler 
Southwest Power Pool, Inc. 
201 Worthen Drive 
Little Rock, AR 72223-4936 
(501) 614-3200