{"document":{"slug":"filing-20260807-5186","title":"Answer of the Organization of MISO States, Inc. in Support of Midcontinent Independent System Operator, Inc.'s et al. 08/03/2026 Motion to Hold Proceeding in Abeyance","issued":"2026-08-07","accession":"20260807-5186","docket":"EL26-70-000","group":"MISO filings","filer":"Organization of MISO States, Inc.","kind":"answer","file":"sources/originals/20260807-5186_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260807-5186","sha256":"3ecd2aa2dbce42fa4c45eb0656a79b150c053a737a5fefb6e1f166e67a15bfbf","pages":8,"tokens":1990,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":320,"text":"1 \n \nUNITED STATES OF AMERICA  \n BEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n  \n \n \n) \nMidcontinent Independent System \n) \nDocket No. EL26-70-000 \n      Operator, Inc., et al. \n) \n \n) \n \n \nANSWER IN SUPPORT OF  \nTHE MOTION TO HOLD PROCEEDING IN ABEYANCE OF  \nTHE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC. AND  \nTHE MISO TRANSMISSION OWNERS BY \nTHE ORGANIZATION OF MISO STATES, INC. \n \nPursuant to Rule 2131 of the Federal Energy Regulatory Commission’s (“Commission”) \nRules of Practice and Procedure and the Commission’s Notice Establishing Answer Period, the \nOrganization of MISO States, Inc.2 (“OMS”) respectfully submits this Answer in Support of the \nMotion to Hold Proceeding in Abeyance3 of the Midcontinent Independent System Operator, Inc. \n(“MISO”) and the MISO Transmission Owners (“MISO TOs”) in the above-caption proceeding.4  \nOMS supports the Abeyance Request because the issues identified by the Commission’s \nShow Cause Order are significant, highly interconnected, and best addressed through a coordinated \nstakeholder process followed by comprehensive filings under section 205 of the Federal Power \nAct. An abeyance period will provide the necessary opportunity for MISO, MISO TOs, states, \n \n1 18 C.F.R. § 385.213. \n2 OMS filed a Motion to Intervene Out-of-Time on July 15, 2026. OMS is a non-profit, self-governing organization \ncomprised of representatives from the seventeen regulatory bodies with jurisdiction over entities participating in MISO \nand serves as the regional state committee for the MISO region. OMS coordinates regulatory oversight among its \nmembers, makes recommendations to MISO, the MISO Board of Directors, the Commission, and other government \nentities, and intervenes in proceedings before the Commission to express the positions of OMS members. \n3 Motion of the Midcontinent Independent System Operator, Inc. and the MISO Transmission Owners to Hold \nProceeding in Abeyance and Request for Shortened Answer Period and Expedited Treatment, Docket No. EL26-70-\n000 (Aug. 3, 2026) (“Abeyance Request”). \n4 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212, at P 37 (2026) (“Show Cause Order”)."},{"page":2,"startToken":320,"endToken":586,"text":"2 \n \nload-serving entities, consumer advocates, and other stakeholders to develop durable reforms that \naddress the Commission’s concerns in a holistic manner. \nAt the same time, OMS’s support for the Abeyance Request is conditioned on the \nexpectation that the stakeholder process and resulting filings will fully address the issues identified \nby the Commission. Granting abeyance should not narrow the scope of the Commission’s inquiry \nor prejudge whether any particular issue has been adequately resolved when the Commission \nevaluates MISO’s compliance filing in this proceeding made on or before November 16, 2026. \nI. \nANSWER \nA. OMS Supports the Request to Hold this Proceeding in Abeyance. \nOMS supports MISO’s and the MISO TOs’ Abeyance Request because the Commission \nhas identified a broad set of complex and interrelated issues that require robust participation from \nall MISO stakeholders to develop durable, regionally tailored solutions. The Commission’s Show \nCause Order recognizes that the process for serving new large loads raises significant questions \nconcerning transmission planning including increased transparency, meaningful consideration of \nalternative solutions, and the equitable assignment of costs and risks. MISO has made considerable \nprogress on several of these issues to date, but more time is needed. \nOMS’s support is premised on the understanding that the abeyance period will be used to \ndevelop comprehensive reforms addressing all issues identified by the Commission. The purpose \nof the abeyance should not be simply to delay the proceeding, but rather to facilitate the \ndevelopment of a complete record and meaningful reforms that can be evaluated as an integrated \npackage. To that end, OMS appreciates MISO and the MISO TOs’ recognition of the critical role"},{"page":3,"startToken":586,"endToken":848,"text":"3 \n \nstates play in managing affordability and their commitment to continued collaboration with the \nstates to develop and finalize solutions to the Show Cause Orders’ directives.5  \nA coordinated stakeholder process, followed by successive section 205 filings, provides \nthe best opportunity to produce reforms that are durable, regionally appropriate, and supported by \na broad set of stakeholders. Such an approach also provides stakeholders with a meaningful \nopportunity to evaluate how proposed changes interact with one another before the Commission \nis asked to determine whether the overall package satisfies the concerns identified in this \nproceeding. \nOMS also recognizes that the MISO region presents unique circumstances. While the \nCommission’s inquiry was informed by developments occurring across multiple regions, including \nPJM, the MISO region has distinct planning processes, regulatory structures, and load growth \npatterns. Accordingly, reforms should be tailored to the operational and governance characteristics \nof the MISO region while still adhering to the Commission’s objectives regarding the reliable, \nefficient, and equitable interconnection of large loads. \nB. The Show Cause Order Appropriately Identifies the Core Issues Requiring \nReform. \nThe Commission’s Show Cause Order appropriately focuses attention on issues that states \nwithin the MISO region have increasingly observed as requests to interconnect and serve new large \nloads continue to accelerate. States have attempted to properly align the costs and risks presented \nby large loads using the regulatory tools available, but a comprehensive solution requires concerted \ncoordination and partnership between state and federal regulators. These developments have \nsignificant implications not only for customers seeking service, but also for existing customers that \n \n5 Abeyance Request at p. 8."},{"page":4,"startToken":848,"endToken":1130,"text":"4 \n \nmay ultimately bear the costs and reliability risks associated with investments required to \naccommodate new large load customers. \nOMS appreciates the Commission’s focus on large load interconnection issues including: \n• \nimproving transparency regarding transmission costs associated with serving new large \nloads; \n• \naddressing the potential for inappropriate cost shifting when anticipated load does not \nultimately materialize or materializes at a different scale or schedule than expected; \n• \nevaluating circumstances in which costs may shift among load-serving entities within a \ntransmission pricing zone; \n• \nensuring that transmission-related reliability risks associated with delayed or uncertain \nload development are appropriately considered; \n• \nimproving transparency surrounding transmission service studies and study assumptions; \n• \nenhancing transparency throughout the transmission study process generally; \n• \nevaluating flexible transmission service options where appropriate; \n• \nconsidering the role of Grid-Enhancing Technologies and other Alternative Transmission \nTechnologies to efficiently address new load requests; and \n• \naddressing any additional issues identified by the Commission relating to the equitable \nallocation of costs and the efficient integration of new large loads. \n \nSeveral of these issues have been the subject of ongoing stakeholder discussions within \nMISO. OMS appreciates MISO’s proactive leadership to develop workable solutions to these \nissues, but we note that workstreams prioritized by MISO and stakeholders to date have been \nlimited to those issues supported by parties largely interested in developing and serving large loads.  \nThe Commission’s Show Cause Order now provides an important opportunity to evaluate the \nadditional issues necessary to ensure MISO’s large load framework addresses the affordability, \nreliability, transparency, and cost allocation concerns that are important to states, consumers, and \nother stakeholders. OMS agrees that this broader review is both timely and appropriate, and we \nexpect that MISO will work with states on how best to prioritize these issues."},{"page":5,"startToken":1130,"endToken":1397,"text":"5 \n \nAs MISO continues to evaluate reforms intended to facilitate service for new large loads, \nit is equally important that the stakeholder process fully address the corresponding concerns of \nexisting customers, state regulators, and consumer advocates regarding affordability, reliability, \ntransparency, and equitable cost allocation. The Show Cause Order appropriately broadens the \ndiscussion, beyond simply facilitating new service requests, to ensure that the resulting framework \nfairly balances all affected interests. \nC. OMS Intends to Participate in Developing Comprehensive Solutions. \nOMS intends to participate throughout the MISO stakeholder process during the abeyance \nperiod. States have a significant interest in ensuring that reforms promote reliable electric service \nwhile protecting consumers from unreasonable costs and inappropriate cost shifting. \nOMS expects that meaningful, long-term solutions will require a combination of wholesale \nreforms to MISO’s Tariff and complementary actions by state regulators where retail issues or \nstate-jurisdictional cost allocation considerations exist. A collaborative stakeholder process \nprovides the appropriate forum for developing these solutions before they are presented to the \nCommission through section 205 filings. \nOMS likewise intends to participate fully in reviewing and responding to any filings \nsubmitted by MISO and individual MISO TOs during the abeyance period and to assist in \ndeveloping a complete record addressing the Commission’s concerns as detailed in the Show \nCause Order.  \nD. All Issues Identified in the Show Cause Order Should Remain Open Throughout \nthe Abeyance Period. \nWhile OMS supports granting the Abeyance Request, the Commission should make clear \nthat all issues identified in the Show Cause Order remain open throughout the abeyance period. \nThe Commission should evaluate the resulting section 205 filings as a comprehensive package"},{"page":6,"startToken":1397,"endToken":1689,"text":"6 \n \nrather than treating individual issues as resolved based on isolated proposals developed in the \nstakeholder process and interim 205 filings. \nOMS appreciates MISO and the MISO TOs’ acknowledgement that reforms are needed to \nimprove transparency and ensure that the costs of serving new large loads are assigned fairly. OMS \nintends to work constructively within the MISO stakeholder process to help achieve meaningful \nreforms and will remain engaged throughout the proceeding and thereafter. \nAccordingly, the Commission should treat all issues relating to the interconnection of large \nloads including increased transparency in the planning process, equitable cost assignment, \nprotection from cost shifting, and meaningful consideration of alternatives as unresolved until the \nrecord developed during the full abeyance period – including all filings submitted in response to \nMISO and the MISO TOs’ ultimate response to the Show Cause Order – is complete. Only then \nwill the Commission be positioned to determine whether the package of reforms adequately \naddresses the concerns identified in its Show Cause Order. Continued stakeholder engagement \nwith FERC will be imperative at the end of the abeyance period to ensure a final check on the \nholistic set of reforms has been appropriately addressed. \nII. \nCONCLUSION \nFor the foregoing reasons, OMS respectfully requests that the Commission grant MISO \nand the MISO TOs’ Motion to Hold Proceeding in Abeyance. In doing so, the Commission should \nmake clear that the purpose of the abeyance is to facilitate the development of comprehensive \nreforms addressing all issues identified in the Show Cause Order and that no issue should be \ndeemed resolved until the Commission has had the opportunity to review the complete package of \nstakeholder-developed proposals, section 205 filings, MISO and the MISO TOs’ final response to \nthe Show Cause Order, and the responses of interested parties thereto."},{"page":7,"startToken":1689,"endToken":1908,"text":"7 \n \nOMS submits this Answer because a majority of OMS members support this filing.6 This \nshould not be construed to mean that all OMS members agree with all comments herein. Individual \nOMS members reserve the right to file separate comments. In recognition of such, the following \nmembers voted in support of this filing: \nArkansas Public Service Commission  \nIllinois Commerce Commission \nIowa Utilities Commission  \nIndiana Utility Regulatory Commission  \nKentucky Public Service Commission  \nMichigan Public Service Commission \nMinnesota Public Utilities Commission  \nMississippi Public Service Commission \nMissouri Public Service Commission  \nNew Orleans City Council \nNorth Dakota Public Service Commission  \nSouth Dakota Public Utilities Commission  \nPublic Service Commission of Wisconsin  \nPublic Utility Commission of Texas  \nThe Louisiana Public Service Commission abstained from the vote on this filing. The Manitoba \nPublic Utilities Board and the Montana Public Service Commission did not participate in the vote. \n \nRespectfully submitted, \n \n \n /s/ Brad J. Pope  \n \n \n  \n /s/ Tricia DeBleeckere \n \nBrad Pope  \n \n \n \n    \nTricia DeBleeckere \nLegal and Regulatory Director \n \n \nExecutive Director \nOrganization of MISO States \n \n \nOrganization of MISO States \n811 E. Washington Ave., Suite 400 \n \n811 E. Washington Avenue, Ste. 400 \nMadison, WI 53703 \n \n \n \nMadison, WI 53703 \nbrad@misostates.org \n \n \n \ntricia@misostates.org \n \nDated: August 7, 2026 \n \n6 The Iowa Office of Consumer Counselor and the Minnesota Department of Commerce are Associate Members of \nOMS, and they support these Comments."},{"page":8,"startToken":1908,"endToken":1990,"text":"8 \n \n \nCERTIFICATE OF SERVICE \n \n       I certify that I have served the preceding document upon each person designated on the official \nservice list prepared by the Secretary for this proceeding in accordance with the requirements of \nRule 2010 of the Commission’s Rules of Practice and Procedure. 18 C.F.R. § 385.2010. \n \n /s/ Brad J. Pope \n \nBrad Pope \nDirector of Legal & Regulatory Affairs \nOrganization of MISO States \n811 E. Washington Avenue, Suite 400 \nMadison, WI 53703 \nbrad@misostates.org \n \nDated: August 7, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":623,"startToken":0,"endToken":410},{"p":2,"at":623,"title":"I. ANSWER","method":"printed heading","endPage":2,"endAt":635,"startToken":410,"endToken":412},{"p":2,"at":635,"title":"A. OMS Supports the Request to Hold this Proceeding in Abeyance.","method":"printed heading","endPage":3,"endAt":1192,"startToken":412,"endToken":749},{"p":3,"at":1192,"title":"B. The Show Cause Order Appropriately Identifies the Core Issues Requiring","method":"printed heading","endPage":5,"endAt":530,"startToken":749,"endToken":1199},{"p":5,"at":530,"title":"C. OMS Intends to Participate in Developing Comprehensive Solutions.","method":"printed heading","endPage":5,"endAt":1573,"startToken":1199,"endToken":1341},{"p":5,"at":1573,"title":"D. All Issues Identified in the Show Cause Order Should Remain Open Throughout","method":"printed heading","endPage":6,"endAt":1315,"startToken":1341,"endToken":1589},{"p":6,"at":1315,"title":"II. CONCLUSION","method":"printed heading","endPage":6,"endAt":1320,"startToken":1589,"endToken":1590},{"p":6,"at":1320,"title":"CONCLUSION","method":"printed heading","endPage":8,"endAt":7,"startToken":1590,"endToken":1909},{"p":8,"at":7,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":8,"endAt":525,"startToken":1909,"endToken":1990}]}