EL26-70-000 · 2026-08-07 · American Municipal Power, Inc.

Answer of American Municipal Power, Inc. in Response to the Motion to Hold Abeyance filed by Midcontinent Independent System Operator, Inc. et al

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
Midcontinent Independent System 
 Operator, Inc.
) 
)
Docket No. EL26-70-000
 
ANSWER OF 
AMERICAN MUNICIPAL POWER, INC. 
 
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 Independent System Operator, Inc. (“MISO”) 
and the MISO Transmission Owners on August 3, 2026, in the above-captioned 
proceedings (“Motion”). The Motion fails to provide the information required by the 
Commission’s June 18 Show Cause Order in the event abeyance is sought,3 and 
therefore the Commission has grounds to deny the Motion.  
However, in the interest of expediting resolution of this matter, the Commission 
should instead direct MISO to present within twenty days to its stakeholders a proposal 
for their consideration that addresses in substantial detail the critical cost-transparency 
and cost-shifting issues identified in the Show Cause Order, and immediately file that 
proposal with the Commission on an informational basis, along with an update describing 
MISO’s detailed plan for consideration of its proposal within the stakeholder process, to 
demonstrate progress in support of further abeyance. The Commission should also 
impose a deadline of November 16, 2026 for MISO and the MISO Transmission Owners 
 
1  18 C.F.R. § 385.213. 
2  Notice Establishing Answer Period, Docket No. EL26-70, at 2 (August 4, 2026). 
3  Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212, at P 37 (2026) (“Show Cause Order”).

2 
to file responsive revisions to the MISO Open Access Transmission, Energy and 
Operating Reserves Markets Tariff (“Tariff”). 
I. 
ANSWER 
A. 
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. 
The Show Cause Order identified cost transparency and cost-shifting protections 
as central deficiencies, among others, in MISO's Tariff. Missing protections include, inter 
alia, public disclosure of large-load-driven network upgrades and their costs, cost 
recovery agreements, financial security requirements, and protection of existing 
transmission customers from stranded costs caused by speculative large-load projects.4 
The Show Cause Order discusses each of these problem areas in support of the 
Commission’s decision to require submittal of proposed revisions to the Tariff by August 
17, in the absence of a demonstration that the existing Tariff is just and reasonable. 
B. 
The Show Cause Order adopted reasonable standards for evaluating 
the abeyance request presented in the Motion. 
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 successful abeyance requests, if any, 
will include both (1) a robust description of the content of a potential future filing under 
FPA section 205 and (2) a reasoned and specific explanation of when such a filing is 
 
4  See Show Cause Order at PP 3, 23-25, 33, 66, 71-85. 
5  Id. P 37.

3 
expected to be made.”6 The Commission expressly stated that it would not grant 
abeyances reflexively.7 
C. 
MISO’s Motion fails to meet the standards for abeyance established in 
the Show Cause Order. 
MISO's response consists largely of a few lines of text indicating that concepts and 
Tariff revisions will be developed in the future through collaboration between MISO and 
the MISO Transmission Owners, and eventually presented to MISO’s Large Load 
Working Group (“LLWG”), with a potential filing in November anticipated. This falls well 
short of the detailed roadmap to compliance that the Commission required to justify 
abeyance.8 
The Motion only superficially describes a potential future filing under Federal 
Power Act (“FPA”) section 205.9 The “anticipated” filing may take place sometime in 
November. The only explanation for the vague filing timeline is that MISO will engage with 
stakeholders prior to the filing, but no detail is provided regarding that engagement other 
than that it will involve presentations, discussions, and feedback: 
Finally, MISO and the MISO Transmission Owners are 
working together to develop additional solutions, processes, 
and services to address the balance of the Commission’s 
concerns identified in the Show Cause Order. These include, 
among other things, (a) the application process, study 
procedures (including evaluating alternative transmission 
technologies), and ongoing operational requirements that 
apply to Eligible Customers seeking transmission service on 
behalf of large loads; and (b) additional transparency 
concerning the Network Upgrade costs and cost shift 
concerns.  MISO will present concepts and proposed Tariff 
revisions to the LLWG for discussion and formal stakeholder 
 
6  Id. 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 of cost 
transparency and preventing cost shifting, MISO and the MISO Transmission Owners 
have scarcely provided a conceptual response to the Commission’s detailed and specific 
concerns, much less a reasoned and specific explanation of when a filing will be made or 
how it will address those concerns. Yet MISO has vigorously pursued other initiatives with 
respect to large loads for months as detailed in the balance of its abeyance request.11  
The Motion asserts that there will be six meetings of MISO’s LLWG between now 
and November, and that “[a] detailed management plan outlining the specific agenda for 
these meetings is located on MISO’s website and will be updated regularly.”12 But the 
referenced “plan” merely contains high level bullets listing a few general topics to be 
discussed at each meeting. For example, the listing for the August 27, 2026 meeting 
states in part: “Introduce New Issue(s) – Cost Transparency . . . .”13 
Costs associated with transmission upgrades to serve large loads are likely to be 
in the billions of dollars. Solutions to ensure proper cost allocation that will avoid cost 
shifting cannot be solely developed by MISO and the MISO Transmission Owners through 
proposals that are presented to the rest of the stakeholder community with almost no time 
for meaningful input. This is especially true when the Show Cause Order’s directives have 
 
10  Motion at 12-13 (footnotes omitted). 
11  See, e.g., Motion at 9-12. 
12  Id. at 13 (citing MISO, LLWG Management Plan, (July 31, 2026), 
https://cdn.misoenergy.org/20260812%20LLWG%20Item%2001d%20Management%20Plan772569.p
df (“LLWG Management Plan”) (attached hereto as Exhibit A)). 
13  LLWG Management Plan.

5 
been in place since mid-June and MISO has not presented any proposals on cost 
transparency or cost shifting in the stakeholder process to date.  
D. 
To expedite resolution of this matter, the Commission should 
condition abeyance on a further compliance filing by MISO. 
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. Transmission 
dependent utilities such as municipalities and cooperatives are not protected by state 
utility commissions and retail tariffs because the allocation of costs between individual 
load serving entities within MISO transmission pricing zones is performed at the 
wholesale level. Transmission service rates are, of course, FERC-jurisdictional and 
protections for these wholesale customers (and by implication, their associated retail 
customers) cannot be ignored or given short shrift.  
Accordingly, the Commission should direct MISO to: (1) bring forward a specific 
proposal to meet its obligations under the Show Cause Order to address cost 
transparency and cost shifting within the next twenty days in the MISO stakeholder 
process and provide the Commission with a detailed report regarding that proposal; (2) 
thoroughly vet its proposal with state regulators, consumer advocates, and other 
representatives of customers and load serving entities that might bear the costs of 
upgrades required to serve large loads; and (3) work collaboratively with these parties to 
develop just and reasonable revisions to the MISO Tariff in compliance with the Show 
Cause Order, to be submitted for the Commission’s approval by the revised deadline, 
which should be no later than the maximum ninety-day abeyance period contemplated in 
that order (i.e., no later than November 16, 2026).

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II. 
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. 
Respectfully submitted, 
 
/s/ Gerit F. Hull 
Lisa G. McAlister  
 
 
 
 
Senior Vice President & General  
 
 
  Counsel  
 
Gerit F. Hull  
 
 
 
 
 
Deputy General Counsel for   
 
  Regulatory Affairs  
 
 
  
American Municipal Power, Inc.  
 
 
1111 Schrock Road, Suite 100  
Columbus, OH 43229   
 
 
(614) 540-1111 
lmcalister@amppartners.org 
ghull@amppartners.org 
 
Counsel for American Municipal Power, Inc. 
 
Dated: August 7, 2026

EXHIBIT A 
 
Midcontinent Independent System Operator, Inc. 
Large Load Working Group Management Plan 
July 31, 2026

LLWG Management Plan 
 
 
Last Update: July 31, 2026 
 
√ Potential Voting Item  
      ^ Feedback Requested 
* Verbal Report 
 
 Informational / Post Only 
 
Entity: Large Load Working Group (LLWG) 
Reports to: Advisory Committee (AC)  
Officers:  
Chris Plante, Chair 
Werner Roth, Vice Chair  
Marc Keyser, MISO Liaison  
Amanda Jones and Eileen King, Stakeholder Relations  
 
Rationale for Existence:  
The objective of the Large Load Working Group (LLWG) is to provide input and policy guidance to MISO Management and the Steering Committee on 
processes and policies pertaining to markets, reliable operations, planning, and resource adequacy that facilitate integration and enablement of 
large loads in the MISO footprint.     
 
The LLWG will coordinate its efforts with other MISO stakeholder groups, including all entities reporting to the Advisory Committee and any other 
related stakeholder forums that are organized during the term of this Working Group.   
 
How many meetings were held in 2025?  N/A 
What was the average number of total participants in 2025?  N/A 
 
Recurring Tasks 
Annual Administrative Tasks 
Status Reports from Subordinate Entities 
• 
New issues assigned by Steering 
Committee (as needed) or FERC (e.g., 
Rulemaking, NOPR) 
• 
Leadership nominations (April) 
• 
Leadership elections (May)  
• 
Next year meeting schedule (Q3/Q4) 
• 
Annual charter and management plan 
review and approval (Q1)  
N/A 
 
 
 
A-1

LLWG Management Plan 
 
 
Last Update: July 31, 2026 
 
√ Potential Voting Item  
      ^ Feedback Requested 
* Verbal Report 
 
 Informational / Post Only 
 
 
 
 
Q3 2026 
• 
Operational Reliability 
Requirements Issues 
(TBD)  
 
Stakeholder Panel: 
Perspective and 
Experience with Large 
Loads  
• 
BPM Updates:  
o 
Large Load BPM-
032 
o 
Large Load Firm 
Service Step Up 
(LLWG-2026-1) 
•o  ZGIA (PAC-
2024-4) ZGIA 
BPM (PAC-2024-
4)  
July 16 
• 
Large Load Firm Service Step Up (LLWG-2026-1) ^ 
• 
Creation of Large Load BPM 032/ Other BPM Updates 
• 
Alliant Large Load Non-Firm Transmission Service (BITS) Proposal  
• 
Discuss FERC June Large Load Action  
• 
New Issue/Discussion: Conditional/Non-firm Transmission Service √ 
• 
New Issue/Discussion: Load Addition Resource Study √ 
• 
 
July 27 
• 
Interconnection Reliability Requirements (LLWG-2026-3) 
August 12 
 
Review Conditional Non-firm Transmission Service (LLWG-2026-5)  
• 
Large Load Show Cause Abeyance Request/Filing Plans 
• 
Interconnection Reliability Requirements (LLWG-2026-3) 
• 
Conditional Non-firm Transmission Service (LLWG-2026-5) ^ 
August 27 
• 
Large Load Firm Service Step Up (RASC-2026-1) Final Tariff Redlines  
• 
Large Load Reserve Product Enhancements (LLWG-2026-2) Evaluation results and initial 
recommendation(s) 
• 
Creation of Large Load BPM 032/ Other BPM Updates 
• 
Large Load Filing Plans (August) 
• 
Interconnection Reliability Requirements: Stability Assessment Requirements 
• 
Load Addition Resource Study (LLWG-2026-6) Draft Tariff Redlines 
 
Large Load Reserve Product Enhancements (LLWG-2026-2)  initial evaluation results, cost 
allocation recommendation 
• 
Introduce New Issue(s) – Cost Transparency, Tariff Defined Application Process, Large Load Study 
Process√ 
• 
Large Load BPM 032/ Other BPM Updates 
• 
 
September 23no meeting 
 
Load Addition Resource Study (LLWG-2026 6) 
 
BPM Updates:  
 
LL BPM-032 
A-2

LLWG Management Plan 
 
 
Last Update: July 31, 2026 
 
√ Potential Voting Item  
      ^ Feedback Requested 
* Verbal Report 
 
 Informational / Post Only 
 
Large Load Firm Service Step Up (LLWG-2026-1) 
 
 ZGIA (PAC-2024-4)  
• 
Interconnection Reliability Requirements: (LLWG-2026-3) Stability Assessment Requirements 
• 
Conditional Non-firm Transmission Service (LLWG-2026-5)  
• 
Load Addition Resource Study (LLWG-2026-6) 
• 
Cost Transparency/Allocation (LLWG-2026-TBD) 
• 
Tariff Defined Application Process (LLWG-2026-TBD) 
• 
Large Load Study Process (LLWG-2026-TBD) 
• 
New Issue/Discussion: Large Load Remote Disconnect √ 
• 
Large Load Remote Disconnect Proposal (LLWG-2026-TBD)^ 
• 
BPM Updates 
 
Q4 2026 
• 
Operational Reliability 
Requirements Issues 
(TBD) 
• 
Large Load Reserve 
Product Enhancements 
(LLWG-2026-2)  reserve 
enhancement 
recommendation and 
evaluation summary 
• 
BPM Updates:  
o 
Large Load BPM-
032 
o 
Large Load Firm 
Service Step Up 
(LLWG-2026-1) 
o 
Conditional Non-
firm Transmission 
Service (LLWG-
2026-5) 
October 8 
• 
Tariff for Conditional/Non-firm Transmission Service (LLWG-2026-5) Draft Tariff Redlines ^ 
 
October 29 
• 
Large Load Firm Service Step Up (LLWG-2026-1) BPM  
• 
Tariff for Conditional/Non-firm Transmission Service (LLWG-2026-5) Final Tariff Redlines  
 
Firm Step Up BPM (add issue #)  
• 
Large Load Remote Disconnect (LLWG-2026-TBD) Tariff Redlines ^ 
November 16 (afternoon tentative to change) 
• 
Review response to Large Load show cause order 
 
A-3

LLWG Management Plan 
 
 
Last Update: July 31, 2026 
 
√ Potential Voting Item  
      ^ Feedback Requested 
* Verbal Report 
 
 Informational / Post Only 
o 
Load Addition 
Resource Study 
(LLWG-2026-6) 
• 
Creation of Large Load 
BPM 032/ Other BPM 
Updates 
 
Load Addition Resource 
Study 
• 
Cost 
Transparency/Allocation 
(LLWG-2026-TBD) 
• 
Tariff Defined Application 
Process (LLWG-2026-
TBD) 
• 
Large Load Study Process 
(LLWG-2026-TBD) 
December 15 
 
Q1 2027 
• 
Leadership Nominations 
and Election √ 
• 
Administrative Items 
Annual Review √ 
 
Meeting TBD 
 
Meeting TBD 
 
 
Q2 2027 
• 
Leadership Nominations 
and Election √ 
• 
 
Meeting TBD 
 
A-4

LLWG Management Plan 
 
 
Last Update: July 31, 2026 
 
√ Potential Voting Item  
      ^ Feedback Requested 
* Verbal Report 
 
 Informational / Post Only 
Meeting TBD 
 
 
Q3 2027 
• 
 
Meeting TBD 
 
Meeting TBD 
 
 
A-5

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. 
/s/ Gerit F. Hull 
Gerit F. 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.