Answer of American Municipal Power, Inc. in Response to the Motion to Hold Abeyance filed by Midcontinent Independent System Operator, Inc. et al
Read topic-matched comments in EL26-70
Topics in the text: Filing procedure · Cost allocation · Registry access
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Opening text
opening text · Topic match: Filing procedure
Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”)1 and the Commission’s notice,2 American Municipal Power, Inc. (“AMP”) respectfully submits this Answer in response to the abeyance motion filed by Midcontinent…Read this passage
I. ANSWER
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I.Read this passage
A. The Show Cause Order identified critical issues for MISO to address
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The Show Cause Order identified critical issues for MISO to address in Tariff revisions to be proposed through a compliance filing that remains due on August 17, 2026.Read this passage
B. The Show Cause Order adopted reasonable standards for evaluating
printed heading · Topic match: Filing procedure
The Commission anticipated that MISO and the MISO Transmission Owners may need additional “time while they work through the stakeholder processes to develop FPA section 205 filings to revise the Tariff to address the issues raised in [the Show Cause Order].”5 The Show Cause Order indicated “that…Read this passage
C. MISO’s Motion fails to meet the standards for abeyance established in
printed heading · Topic match: Cost allocation
P 37. 7 Id. 8 See id. 9 16 U.S.C. § 824d. 4 feedback requests as they are developed in anticipation of a November FPA section 205 filing to address any Commission directives not addressed in a prior FPA section 205 filing.10 Whereas the Commission has thoughtfully outlined its expectations in terms…Read this passage Filed comments: Cost allocation
D. To expedite resolution of this matter, the Commission should
printed heading · Topic match: Cost allocation
There is a clear gap between the existing broad cost allocation methodologies applied to transmission projects in MISO generally, and a targeted allocation that is necessary to protect against cost shifting due to the addition of large loads.Read this passage Filed comments: Cost allocation
II. CONCLUSION
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II.Read this passage
CONCLUSION
printed heading · Topic match: Reliability and curtailment
CONCLUSION WHEREFORE, for the foregoing reasons, American Municipal Power, Inc. respectfully requests that the Commission issue an order containing the three directives described herein, and that the Commission grant such further relief as the Commission may deem appropriate.Read this passage Filed comments: Reliability and curtailment
CERTIFICATE OF SERVICE
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Hull Deputy General Counsel for Regulatory Affairs American Municipal Power, Inc. 1111 Schrock Road, Suite 100 Columbus, OH 43229 (614) 540-1111 Dated at Columbus, Ohio, this 7th day of August, 2026.Read this passage