EL26-70-000 · 2026-08-14 · Organization of MISO States, Inc.

Comments of the Organization of MISO States, Inc. on the Informational Report of the Midcontinent Independent System Operator, Inc. filed on 07/20/2026

UNITED STATES OF AMERICA  
 BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
 
) 
Midcontinent Independent System 
) 
Docket No. EL26-70-000 
      Operator, Inc., et al. 
) 
 
) 
 
 
COMMENTS OF  
THE ORGANIZATION OF MISO STATES, INC. ON 
THE INFORMATIONAL REPORT OF  
THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC. 
 
The Organization of MISO States, Inc. (“OMS”)1 submits the following comments in 
response to the Midcontinent Independent System Operator, Inc.’s (“MISO”) July 20, 2026 
Informational Report2 filed with the Federal Energy Regulatory Commission (“Commission”) in 
the above-captioned proceeding.3 OMS submits these comments regarding MISO’s Informational 
Report to underscore the role of state and local regulators regarding resource adequacy and the 
interconnection of large loads – the subject of MISO’s Informational Report. These comments are 
intended to aid the Commission in its decision-making process by offering the perspective of retail 
regulatory authorities responsible for overseeing resource adequacy in the MISO region.  
I. 
COMMENTS 
OMS submits this response to ensure that the perspectives of state and local regulators are 
reflected in the Commission’s consideration of resource adequacy. As the entities responsible for 
overseeing retail customers, resource planning, generation procurement cost decisions, and siting, 
 
1 OMS filed a Motion to Intervene Out-of-Time on July 15, 2026. OMS is a non-profit, self-governing organization 
comprised of representatives from the seventeen regulatory bodies with jurisdiction over entities participating in 
MISO and serves as the regional state committee for the MISO region. OMS coordinates regulatory oversight among 
its members, makes recommendations to MISO, the MISO Board of Directors, the Commission, and other relevant 
government entities, and intervenes in proceedings before the Commission to express the positions of OMS members. 
2  Ltr. to Secretary Reese re: Informational Report, Docket No. EL26-70 (July 20, 2026) (“Informational Report”). 
3  Midcontinent Indep. System Operator, Inc., 195 FERC ¶ 61,212 (2026) (the “Show Cause Order”).

state and local regulators play a central role in ensuring reliable, affordable electric service and 
should remain active participants in discussions regarding resource adequacy. 
OMS remains committed to working constructively with MISO and stakeholders to 
strengthen the existing framework while preserving state authority over resource adequacy and 
ensuring that reforms continue to support reliable service, efficient markets, and reasonable 
customer costs. At the same time, unprecedented large load growth presents new planning, 
coordination, and implementation challenges that warrant continued collaboration among MISO, 
states, market participants, and other stakeholders.  
A central purpose of OMS’s comments here is to highlight that many important resource 
adequacy and affordability policy and implementation issues are being addressed through state 
proceedings and utility-specific processes that are not fully reflected in MISO's informational 
report as those actions are not FERC-jurisdictional, and MISO is not a party to those actions or 
proceedings. 
A. 
MISO and the States’ Existing Resource Adequacy Construct Provides a 
Strong Foundation to Integrate New Loads. 
 
MISO and the states’ resource adequacy framework provides a durable foundation for 
maintaining reliability while appropriately recognizing the complementary roles of states and the 
regional market. States remain primarily responsible for determining resource adequacy needs 
through utility oversight, resource planning, and retail regulatory processes, while MISO provides 
the regional planning, market rules, and capacity auction framework necessary to support those 
state decisions.  
The recent emergence of unprecedented large load growth presents new planning, 
operational, and coordination challenges, but these challenges do not indicate a failure of the states 
and their collaboration with MISO’s underlying resource adequacy framework nor does it shift

who is responsible for establishing needs or determining how those needs are met. Rather, the 
unique characteristics and uncertainty associated with very large loads warrant enhanced 
coordination between MISO, load-serving entities, transmission owners, and state regulators, with 
planning processes that evaluate load additions using a level of rigor comparable to that applied to 
new generation resources.  
B. 
States Remain Key in Ensuring Affordability through Resource Adequacy 
Constructs.  
 
As MISO, states, and stakeholders continue to evolve the resource adequacy framework to 
address unprecedented large load growth, OMS believes that future reforms should continue to 
build upon the complementary roles established under the Federal Power Act, recognizing the 
central role states play in ensuring resource adequacy by protecting customers from unnecessary 
costs while ensuring reliable electric service.4 
States are responsible for protecting customer affordability – States are uniquely 
positioned to evaluate how wholesale market outcomes translate into retail customer bills and to 
ensure that new investments are appropriately assigned to those who cause them. Across the MISO 
footprint, state commissions are implementing retail tariffs, approving special contracts, requiring 
resource adequacy demonstrations, establishing interruptible service requirements, and adopting 
 
4  See OMS Pre-Filed Technical Conference Statement of Commissioner Marcus Hawkins, Docket No. AD25-7 (filed 
May 28, 2025) available at: https://www.misostates.org/images/stories/Filings/FERC/2025/AD25-7_-
_OMS_Hawkins_Pre-Filed_Tech_Conference_Statement.pdf; and Post-Technical Conference Comments of OMS, 
Docket No. AD25-7 (filed July 7, 2025) available at: https://www.misostates.org/images/stories/Filings/FERC/ 
2025/AD25-7_-_OMS_Post-Tech_Conference_Comments.pdf.

statutory protections that prevent cost shifting from new large loads to existing customers.5,6,7 
These retail proceedings are an essential component of maintaining affordability and should be 
considered alongside regional reforms. 
States are responsible for resource adequacy decisions and their associated cost – 
Resource adequacy is ultimately defined and achieved through state oversight of utility resource 
planning, procurement, and customer obligations. MISO’s regional markets and reliability 
assessments provide critical support and signals to those decisions, but continued state engagement 
is necessary to ensure regional policies complement and do not displace the resource adequacy 
responsibilities entrusted to state regulators as those decisions are key to ensuring affordability. 
States benefit from efficient regional markets and interconnection processes – OMS 
recognizes that new tools may be appropriate to accommodate imminent large load additions and 
support speed-to-power objectives. However, existing interconnection processes should remain 
the primary pathway for connecting new resources, with expedited or alternative processes 
narrowly tailored to address specific circumstances without creating parallel processes that reduce 
transparency or undermine efficient regional planning. Well-designed regional processes 
ultimately benefit customers by promoting efficient investment, creating robust markets, and 
reducing unnecessary costs. 
 
5  See Minn. Stat. § 216B.1622: “As [the state commission] evaluates a tariff or agreement under this section, the  
commission must consider how to best achieve the following required outcomes: (1) all costs attributable to the 
utility’s very large customers […] are assigned to the very large customer class; [...] (3) the tariff or agreement 
contains protections necessary to ensure that other customers of the public utility are not placed at risk for paying 
stranded costs associated with the utility serving the very large customer.” 
6  See Application of DTE Elec. Co. for approval of special contracts, Case No. U-21990, Order of the Michigan Public 
Service Commission (Dec. 18, 2025); and Application of Consumers Energy Co. for Ex Parte Approval of Certain 
Amendments to Rate GPD, Case No. U-21859, Order of the Michigan Public Service Commission (Feb. 7, 2025). 
7 Smart Electric Power Alliance, Database of Emerging Large Load Tariffs (DELTa) available at: 
https://sepapower.org/large-load-tariffs-database/ (last accessed August 11, 2026).

States need transparency to fulfill their responsibilities – As the Commission has 
recognized, greater transparency regarding planning assumptions, reliability analyses, 
transmission cost allocation, and implementation decisions is essential. Since states are 
accountable for balancing reliability, affordability, and customer protection, they require sufficient 
visibility into wholesale planning and market decisions to evaluate customer impacts and make 
informed regulatory decisions. Continued collaboration among MISO, states, and stakeholders 
will strengthen both regional markets and state oversight while preserving the appropriate balance 
of federal and state responsibilities. 
States will continue to coordinate and work with MISO – Regional collaboration 
remains essential to maintaining reliability across the MISO footprint. Continued partnership 
among MISO, states, and stakeholders, supported by transparent regional and federal processes, 
meaningful state engagement, and ongoing analytical efforts such as the OMS-MISO Survey and 
other informational and collaborative reports with MISO will ensure the resource adequacy 
framework continues to remain successful while preserving reliability, affordability, and the 
appropriate balance of federal and state responsibilities. 
II. 
CONCLUSION 
OMS submits these Comments because a majority of OMS members support this filing. 
This should not be construed to mean that all OMS members agree with all comments herein. 
Individual OMS members reserve the right to file separate comments.  
In recognition of such, the following members voted in support of this filing: 
Arkansas Public Service Commission  
Illinois Commerce Commission 
Iowa Utilities Commission  
Indiana Utility Regulatory Commission

Kentucky Public Service Commission  
Louisiana Public Service Commission  
Michigan Public Service Commission 
Minnesota Public Utilities Commission  
Mississippi Public Service Commission 
Missouri Public Service Commission  
New Orleans City Council 
North Dakota Public Service Commission  
South Dakota Public Utilities Commission  
Public Service Commission of Wisconsin  
Public Utility Commission of Texas  
The Manitoba Public Utilities Board and the Montana Public Service Commission did not 
participate in the vote on this filing. 
 
 
Respectfully submitted, 
 
 
 
/s/ Brad J. Pope 
 
 
 
    /s/ Tricia DeBleeckere 
 
Brad Pope 
 
 
 
 
   Tricia DeBleeckere 
Legal and Regulatory Director 
 
   Executive Director 
Organization of MISO States  
 
   Organization of MISO States 
811 E. Washington Ave., Suite 400 
 
   811 E. Washington Avenue, Suite 400 
Madison, WI 53703  
 
 
   Madison, WI 53703 
brad@misostates.org  
 
 
   tricia@misostates.org 
 
Dated: August 14, 2026

CERTIFICATE OF SERVICE 
 
       I certify that I have served the preceding document upon each person designated on the official 
service list prepared by the Secretary for this proceeding in accordance with the requirements of 
Rule 2010 of the Commission’s Rules of Practice and Procedure. 18 C.F.R. § 385.2010. 
 
 /s/ Brad J. Pope 
 
Brad Pope 
Director of Legal & Regulatory Affairs 
Organization of MISO States 
811 E. Washington Avenue, Suite 400 
Madison, WI 53703 
brad@misostates.org 
 
Dated: August 14, 2026