ER26-3650-000 · 2026-09-18 · Data Center Coalition

Motion to Intervene and Comments of the Data Center Coalition re Midcontinent Independent System Operator, Inc.'s 08/28/2026 filing

UNITED STATES OF AMERICA  
BEFORE THE  
FEDERAL ENERGY REGULATORY COMMISSION 
) 
Midcontinent Independent System 
Operator, Inc. 
 ) 
 Docket No. ER26-3650-000
) 
MOTION TO INTERVENE  
AND COMMENTS OF THE DATA CENTER COALITION 
Pursuant to Rules 212 and 214 of the Rules of Practice and Procedure of the Federal Energy 
Regulatory Commission (“FERC” or the “Commission”)1 and the Commission’s August 31, 2026 
Combined Notice of Filings #1,2 the Data Center Coalition (“DCC”) hereby moves to intervene 
and submits these comments on Midcontinent Independent System Operator, Inc.’s (“MISO”) 
proposal to establish certain Interconnection Reliability Requirements (“IRR”) for large loads.3 
I.
OVERVIEW OF THE DATA CENTER COALITION
DCC is the membership organization for the U.S. data center industry, representing leading
data center owners and operators that develop, operate, and maintain data center infrastructure and 
teams across the country.4  DCC members operate data centers that constitute significant loads 
within the MISO region and DCC has been an active stakeholder in regional efforts to ensure 
reliability, enable new generation, and discipline load forecasts.  DCC and its members have been 
at the forefront of efforts to advance reforms in MISO and at the state level to accommodate the 
1 18 C.F.R. §§ 385.212 and 385.214. 
2 Midcontinent Independent System Operator, Inc., et al., Docket No. ER26-3650-000, et al., Combined 
Notice of Filings #1 (Aug. 31, 2026). 
3 Midcontinent Independent System Operator, Inc., Docket No. ER26-3650-000, Proposal of Midcontinent 
Independent System Operator, Inc. to Establish Certain Interconnection Reliability Requirements for Large Loads 
(Aug. 28, 2026) (“Filing”).  
4 The DCC is a membership organization of leading data center owners and operators. Public testimony and 
written comments submitted by DCC do not necessarily reflect the views of each individual DCC member. A list of 
current DCC members is accessible at https://www.datacentercoalition.org/members.

- 2 - 
growth of large loads within the MISO region while maintaining reliability and protecting existing 
retail customers.   
II. 
INTRODUCTION 
DCC appreciates MISO’s continued proactive engagement with the data center industry, 
and its efforts to develop reliability requirements that facilitate the integration of large loads while 
preserving the reliable operation of the transmission system.  DCC member facilities depend upon 
reliable electricity service, and DCC shares MISO’s objective of ensuring that the interconnection 
and operation of large load customers does not adversely affect reliability, system operations, or 
other customers.  DCC recognizes that large loads may present operational characteristics that 
warrant distinct reliability requirements and standards to maintain transmission system reliability.  
DCC is committed to working collaboratively with MISO, the North American Electric Reliability 
Corporation (“NERC”), and stakeholders to establish requirements that maintain reliability, 
protect customers, and avoid creating barriers to large load growth.  
The issue presented by MISO’s Filing is not whether transmission customers taking service 
for large loads should be subject to distinct visibility and operational requirements.  The 
Commission already resolved this issue in its June 2026 show cause order finding the MISO tariff 
unjust and unreasonable because it does not include provisions establishing ride-through, ramping, 
and other operational requirements to address the challenges of large load integration.5  Instead, 
the issue is whether the framework that MISO has proposed in this proceeding represents a just 
and reasonable means of mitigating these reliability risks.  While DCC appreciates MISO’s efforts 
to develop a compliance framework and recognizes the difficulty of the task, DCC respectfully 
 
5 Midcontinent Indep. Sys. Operator, Inc., et al., 195 FERC ¶ 61,212, at PP 43, 64 (2026) (“Show Cause 
Order”).

- 3 - 
submits that MISO’s proposal, as filed, falls short of the clear and consistent framework that the 
Show Cause Order contemplated.   
One of the primary objectives of the Show Cause Order is to ensure that the MISO tariff 
includes clear rules governing the provision of transmission service to customers serving large 
loads “to ensure regulatory and process certainty, fairness and consistency, and efficiency as large 
and co-located loads are added to the transmission system[.]”6  Indeed, MISO has acknowledged 
the need for reform, stating that its “existing Tariff provisions ‘do not provide a consistent or 
transparent framework to evaluate’ large loads and that interested parties ‘face uncertainty 
regarding applicable criteria, study assumptions, data requirements, and post-interconnection 
obligations.’”7  DCC agrees with that assessment—and it is precisely because DCC shares MISO’s 
diagnosis of the problem—that it believes that MISO’s tariff revisions must go farther to establish 
the types of “clear and consistent” tariff provisions contemplated by the Commission.8   
MISO has not demonstrated that the framework that MISO has proposed would resolve the 
uncertainty, consistency, or transparency issues identified in the Show Cause Order.  MISO 
proposes to revise its tariff to provide itself with new authority to impose new visibility and 
reliability requirements on Large Loads and Computational Loads.  But the proposed tariff 
revisions do not clearly define the customers that will be subject to those requirements and the 
obligations that will apply.  Instead, MISO proposes to include the substance of the reliability 
requirements in a future Business Practices Manual (“BPM”).  The result is a tariff framework that 
 
6 Id. at P 12.  
7 Id. at P 29 (quoting MISO, Issue Submission Report (Apr. 15, 2026), available at: 
https://cdn.misoenergy.org/New%20Issue%20-
%20Large%20Load%20Interconnection%20Reliability%20Requirements748710.pdf). 
8 Id. at PP 12, 61, 64, 126.

- 4 - 
fails to deliver the regulatory certainty, consistency, and notice required by the Show Cause Order 
and the Federal Power Act (“FPA”). 
MISO’s proposed grandfathering framework suffers from similar issues.  Although the 
Commission directed MISO to minimize disruption to existing commercial arrangements, MISO 
ties grandfathered treatment primarily to whether an associated transmission project has reached 
specified milestones in the MISO Transmission Expansion Plan (“MTEP”) or Expedited Project 
Review (“EPR”) rather than to whether the Large Load customer has entered into binding 
agreements or made material investments in reliance on the existing regulatory framework.  The 
result is a grandfathering framework that is disconnected from the commercial arrangements that 
the Commission sought to preserve in the Show Cause Order.9  Additionally, MISO has proposed 
to grant itself broad discretion to subject customers that otherwise qualify for an exemption to its 
reliability standards without including any objective standards or procedures in the tariff, creating 
uncertainty about whether customers will be exempt from these requirements or whether MISO 
may later withdraw that protection.  
DCC is not opposed to efforts by MISO or other transmission providers to impose 
reliability requirements necessary to account for the operational characteristics of large loads.  
Maintaining grid reliability is a top priority for DCC and its members.  If MISO demonstrates that 
new reliability requirements are necessary to mitigate reliability risks, then the MISO tariff should 
be modified to include the necessary safeguards to ensure that transmission customers install 
equipment and abide by operational limitations needed to maintain reliability.   
However, any reliability framework that is implemented should be objective, transparent, 
and provide clear notice to customers of the scope of their obligations and the steps needed to 
 
9 See id. at PP 5, 36.

- 5 - 
comply with such requirements, with appropriate measures to minimize disruption to existing 
commercial arrangements and reasonable implementation periods.  Customers must have clarity 
on their compliance obligations so they can make the design decisions necessary to meet these 
obligations.  At the same time, it is important to recognize that customers with facilities that are 
under development or that have commenced operation may not be able to easily revisit investment 
and design decisions without incurring significant delays and costs.  Reliability requirements 
should be implemented in a manner that respects settled expectations and avoids unnecessary 
disruption to existing investment decisions to the extent consistent with the objective of 
maintaining reliability.  
Thus, while DCC supports the critically important reliability imperatives underlying 
MISO’s Filing, DCC respectfully requests that the Commission decline to accept MISO’s 
proposed tariff revisions as filed, without prejudice to a future filing that proposes implementation 
of new reliability requirements in a manner that is objective, transparent, and consistent with the 
objectives of the Show Cause Order.  Although DCC believes that the Filing should be rejected, 
DCC encourages MISO to work with the region to further refine and clarify its proposals and 
identify a path forward that provides the certainty and durability needed to effectively ensure that 
large loads take the steps and make the investments necessary to meet the reliability imperatives 
that MISO rightly aims to safeguard.

- 6 - 
III. 
COMMENTS 
A. 
MISO’s Filing Is Inconsistent With The Show Cause Order, The FPA, And 
The Rule Of Reason    
1. 
MISO’s Proposal To Relegate The Substance Of Its Requirements To 
Its BPMs Is Inconsistent With The FPA 
Section 205 of the FPA requires public utilities to file the rates, terms, and conditions of 
FERC-jurisdictional service with the Commission.10  This obligation includes “classifications, 
practices, and regulations affecting such rates and charges[.]”11  Additionally, “no change shall be 
made” in any rate, term, condition, or practice without a Section 205 filing providing notice of the 
change to the Commission and the public, and only after the Commission determines that the 
change is just and reasonable, and not unduly discriminatory or preferential.12  These basic 
statutory requirements are reflected in the Filed Rate Doctrine, which prohibits public utilities from 
imposing any rates, terms, and conditions other than those that have been filed with and approved 
by the Commission.13   
Section 205 and the Filed Rate Doctrine are designed to ensure that customers receive 
advance notice of the rates, terms, and conditions of service and the Commission can exercise its 
authority necessary to maintain just and reasonable rates.14  As the courts have recognized, the 
 
10 16 U.S.C. § 824d. 
11 Id.; see also 18 C.F.R. § 35.1(a) (requiring that any “rates and charges . . . classifications, practices, rules 
and regulations affecting such rates, charges, classifications, services, rules, regulations or practices,” be filed). 
12 16 U.S.C. § 824d(d).  
13 See Ark. La. Gas Co. v. Hall, 453 U.S. 571, 577 (1981) (stating that the filed rate doctrine “forbids a 
regulated entity to charge rates for its services other than those properly filed with the appropriate federal regulatory 
authority”) (“Arkansas Louisiana Gas”). 
14 Cogentrix Energy Power Mgmt., LLC v. FERC, 24 F.4th 677, 683 (D.C. Cir. 2022); see also Town of 
Concord v. FERC, 955 F.2d 67, 71 (D.C. Cir. 1992) (explaining that purpose of filed rate doctrine is “preservation of 
the agency’s primary jurisdiction over reasonableness of rates and the need to insure that regulated companies charge 
only those rates of which the agency has been made cognizant”) (quoting Arkansas Louisiana Gas  at 577-578).

- 7 - 
requirement “of transparent, public filing of rates ensures evenhandedness, fairness, stability, and 
predictability” in the rates charged for FERC-jurisdictional service.15   
But the FPA and Filed Rate Doctrine are not satisfied merely because a public utility has 
filed a tariff with FERC.  The FPA, FERC’s regulations, and the Filed Rate Doctrine require that 
the tariff “clearly and specifically” set forth the rates, terms, and conditions, and practices affecting 
such rates, terms, and conditions, of FERC-jurisdictional service.16  A tariff that omits key terms 
and conditions of service in favor of vague or open-ended references to a public utility’s 
procedures and practices is inconsistent with the FPA and the Filed Rate Doctrine, and ultimately 
unjust and unreasonable.17   
MISO’s proposed tariff revisions do not satisfy these requirements.  While DCC recognizes 
that not every ministerial implementation detail must be included in the tariff, MISO’s tariff 
revisions do not include the substantive standards that MISO proposes to apply, leave key aspects 
of MISO’s proposed framework unaddressed, and grant MISO broad discretion to apply the 
standards to customers as it deems appropriate without any objective requirements to constrain 
this discretion.  Instead, the tariff repeatedly defers the substance of these standards and key aspects 
of how these standards will be applied to a new Large Load BPM that remains under development 
by MISO, including the performance standards and limits that customers will be held to,18 testing 
requirements and other procedures for demonstrating compliance with MISO’s standards, and the 
timelines for providing required information to MISO.19  The result is a tariff framework that 
 
15 See, e.g., West Deptford Energy, LLC v. FERC, 766 F.3d 10, 12 (D.C. Cir. 2014).  
16 Sw. Power Pool, Inc., 182 FERC ¶ 61,100, at P 34 (2023) (“SPP Order”).  See also 18 C.F.R. § 35.1(a) 
(stating that tariffs must “clearly and specifically” set out rates, charges, and practices for FERC-jurisdictional 
service). 
17 Keyspan-Ravenswood, LLC v. FERC, 474 F.3d 804, 810-11 (D.C. Cir. 2006) (“Keyspan-Ravenswood”). 
18 Filing, Tab A, Proposed §§ 37A.6, 37A.7. 
19 Id., Proposed § 37A.1.

- 8 - 
informs customers that they will be subject to ride-through requirements, ramp-rate limitations, 
and other requirements, but leaves customers in the dark about the substance of their compliance 
obligations.   
The Commission’s Rule of Reason does not justify MISO’s decision to leave the substance 
of its proposed requirements to the BPMs.  Instead, the Commission’s Rule of Reason requires 
public utilities to file those practices or provisions that “significantly affect rates and services”20 
while permitting only implementation details of “practical insignificance”21 to be included in 
BPMs or other manuals.  The Rule of Reason requires terms and conditions to be included in the 
tariff if they “affect rates and services significantly, . . . are realistically susceptible of specification, 
. . . are not so generally understood . . . as to render recitation superfluous,”22 and are not “clearly 
implied by the tariff’s express terms.”23  Rather than supporting MISO’s proposal, applying the 
Rule of Reason to the tariff provisions that MISO has filed in this proceeding highlights the 
problems with MISO’s approach.   
i. 
The Tariff Must Include The Reliability Standards That 
Customers Will Be Required To Meet 
MISO proposes to require that a transmission customer taking service on behalf of a 
Computational Load comply with ramping limits and ride-through requirements.  Although MISO 
notes in its transmittal letter that it is considering an initial limit of 30 MW/minute, MISO does 
not propose to include the actual limits and requirements in the tariff.24  For instance, MISO’s 
 
20 See, e.g., Boston Energy Trading & Mktg. LLC v. Midcontinent Indep. Sys. Operator, Inc., 153 FERC ¶ 
61,336, at P 39 (2015). 
21 Pub. Serv. Comm’n of N.Y. v. FERC, 813 F.2d 448, 454 (D.C. Cir. 1987) (holding that the Commission 
properly excused utilities from filing policies or practices that dealt with only matters of “practical insignificance” to 
serving customers). 
22 Id. (quoting City of Cleveland v. FERC, 773 F.2d 1368, 1376 (D.C. Cir. 1985)).   
23 Cometa Energia, S.A. de C.V. v. Cal. Indep. Sys. Operator Corp., 191 FERC ¶ 61,089, at PP 10, 19 
(2025), order on reh’g, 193 FERC ¶ 61,011 (2025). 
24 Filing, Tab A, Proposed § 37A.7.

- 9 - 
tariff revisions state that Computational Load will be subject to “up-ramp and down-ramp limits 
established by [MISO]” and must have “an effective up and down ramp rate not exceeding the 
specified limit,” but the tariff does not specify the actual limits that will apply, the procedures that 
will be used to determine the applicable limits, or how MISO will determine a load’s “effective” 
ramp rate.25  Similarly, MISO’s proposed ride-through requirements state that Computational Load 
must remain connected to the transmission system and continue to operate during voltage and 
frequency disturbances within the “performance criteria” established by MISO, but does not 
provide any detail regarding the performance criteria that will be applied.26  The tariff also states 
that the ride-through requirements “may include evaluation, testing, modeling, monitoring, and 
other compliance measures,” but states that these measures will be detailed in MISO’s BPMs.27 
MISO has not demonstrated that excluding the substance of these requirements from the 
tariff is just, reasonable, and consistent with the FPA.  There is little question that the ramp rate 
and ride-through requirements applied to transmission customers serving Large Loads 
significantly affect the rates, terms, and conditions of FERC-jurisdictional service.  The 
Commission recognized as much in the Show Cause Order by directing MISO to include ramp 
rate and ride-through requirements in its tariff.28  Additionally, compliance with MISO’s proposed 
ramp rate and ride-through requirements is a precondition to receiving service, and failure to abide 
by these requirements may lead MISO to delay or limit the availability of service.   
Likewise, there is little question that these requirements are readily susceptible to 
specification.  Indeed, MISO states that it plans to impose an initial limit of 30 MW per minute, 
 
25 Id. 
26 Id. Proposed § 37A.6. 
27 Id. 
28 Show Cause Order at P 64 (stating that absence of tariff provisions addressing ramp and ride-through 
requirements may lead to unjust and unreasonable rates).

- 10 - 
demonstrating that the limit is both known and realistically susceptible to specification.29  Both 
the Commission and the courts have recognized that numerical thresholds, such as the ramp limit, 
are “susceptible of specification” and should be included in the tariff.30  Similarly, MISO already 
has published a technical compendium describing its proposed ride-through requirements, 
including minimum ride-through times,31 and the MISO tariff has long included ride-through 
requirements for generation resources.32  Neither the proposed ramp rate nor the ride-through 
requirements are generally understood or implied by the tariff’s express terms, as there is no set of 
standard “ramp rates” or “ride-through” requirements that are applicable and nothing in the 
proposed terms of the tariff implies a specific ramp limitation or ride-through requirement.   
Also, the procedures and protocols that are used by MISO to verify a transmission 
customer’s compliance with these requirements significantly affect the rates, terms, and conditions 
of service and should be described in the tariff.  The Commission has found that the tariff should 
describe procedures that are used to measure and verify compliance with tariff requirements.33  
Indeed, the MISO tariff includes detailed provisions describing how MISO evaluates compliance 
with operational restrictions for other resource and customer classes, including the frequency of 
testing, the nature of the tests that will be administered, applicable performance standards, 
 
29 Filing, Transmittal Letter at 20. 
30 See City & Cnty. of San Francisco v. FERC, 24 F.4th 652, 661 (D.C. Cir. 2022) (“Even if the 75 kW 
threshold is a guidepost, however, that kind of numerical threshold is the type of requirement that the ‘rule of reason’ 
requires be stated in the [t]ariff, as a numerical threshold is ‘realistically susceptible of specification.’” (quoting 
Keyspan-Ravenswood, 474 F.3d at 811)). 
31 See MISO, Interconnection Reliability Requirements for Large Load Technical Compendium (Aug. 
2026), available at: 
https://cdn.misoenergy.org/20260827%20LLWG%20Item%2002c%20MISO%20Large%20Load%20Interconnectio
n%20Reliability%20Requirements_Technical%20Compendium777982.pdf. 
32 See Midwest Indep. Transmission Sys. Operator, Inc., 114 FERC ¶ 61,270 (2006) (approving addition of 
ride-through standards and other technical requirements to Appendix G of the pro forma generator interconnection 
agreement); Midcontinent Indep. Sys. Operator, Inc., 187 FERC ¶ 61,144 (2024) (approving revisions to Appendix G 
to establish performance standards for inverter-based resources).  
33 Midwest Indep. Transmission Sys. Operator, Inc., 137 FERC ¶ 61,214, at P 79 (2011) (directing MISO to 
revise its tariff to include measurement and verification protocols, including metering standards, in the tariff).

- 11 - 
procedures for seeking waivers, and other pertinent details.34  DCC is not arguing that every 
ministerial detail of MISO’s proposed compliance procedures need to be included in the tariff.  But 
transmission customers serving Large Load customers should be given a level of certainty and 
transparency that is comparable to that regularly afforded to other customers and market 
participants. 
ii. 
The Terms And Conditions Of “Ramp Smoothing” Must Be In 
The Tariff 
MISO proposes to allow customers to comply with the ramp requirements using 
“reduction/ramp smoothing provided by generation or other resources that meet[] the eligibility 
requirements specified in” the BPM for Large Load.35  Absent from the proposed tariff, however, 
is any description of how ramp smoothing would affect ramp limits, what resources would be 
eligible to provide this service, or how resource contributions would be measured and accounted 
for in the effective ramp rate.  In fact, neither the transmittal letter nor the testimony submitted in 
support of MISO’s filing provides any detail about this ramp smoothing “service” or how it would 
figure into a customer’s ramp limitations.   
The terms and conditions of ramp smoothing must be included in the tariff.  The eligibility 
requirements to provide ramp smoothing, the methodology used to measure a resource’s 
contribution, and the extent to which these contributions may offset a customer’s ramp limitations 
significantly affect rates, as these requirements will dictate the ability of resources to provide ramp 
smoothing and whether a customer will be deemed to have met applicable compliance 
 
34 MISO Tariff, § 69.A.3.5(j) (stating that market participant must demonstrate demand reduction capability 
by performing annual test, testing conditions, procedures for obtaining waiver from these requirements, and the 
performance standards that must be demonstrated during the test); id. §§ 1F, 40.2.5 (describing testing requirements 
for fast ramping resources, including applicable performance standards and consequences of non-compliance).  
35 Filing, Tab A, Proposed § 37A.7.

- 12 - 
obligations.36  Additionally, the requirements governing ramp smoothing are readily susceptible 
to specification, as MISO could easily identify the categories of eligible resources, the performance 
criteria applicable to these resources, and the methodology used to calculate the contribution of 
these resources to meeting ramping requirements, as MISO already does for other services and 
products that are traded within the MISO markets.37  Nor are the requirements associated with 
ramp smoothing reasonably implied by, or otherwise apparent from, the tariff itself.   
iii. 
The Tariff Must Include Objective Standards And Procedures 
For Revoking Exemptions 
The problems with MISO’s approach are not limited to the substance of the reliability 
requirements that MISO proposes to apply to customers.  While MISO proposes to include 
grandfathering criteria in its tariff, MISO also proposes to grant itself authority to require an 
otherwise exempt customer to comply with its proposed reliability requirements whenever it 
“determines that operation of a Large Load results in a material adverse effect on Transmission 
System reliability.”38  MISO’s proposed tariff language does not describe the criteria that it would 
apply to revoke a customer’s exemption, any rights to appeal or challenge this determination, the 
process that it would use to require compliance with these standards, or the transition period that 
would be provided for a customer to bring itself into compliance.  Instead, the tariff states that 
 
36 See, e.g., Sw. Power Pool, Inc., 169 FERC ¶ 61,048, at P 62 (2019) (finding that four-hour minimum-run-
time requirement significantly affects rates because it determined eligibility of resources to satisfy resource adequacy 
requirements).  
37 See, e.g., MISO Tariff, §§ 39.2.1A(f)(i)-(ii), 39.2.1B(D), 40.2.4(d). 
38 Filing, Tab A, Proposed § 37A(II)(3).

- 13 - 
“[t]he process by which [MISO] will make such a determination and which, if any, of the 
requirements of . . . Section 37A are to be applied” will be included in the BPM for Large Load.39  
The criteria and process used by MISO to make the extraordinary decision to revoke an 
exemption conferred by the express terms of the tariff will have a significant effect on the 
transmission service provided to customers serving Large Loads.  A determination by MISO to 
revoke a customer’s exemption would fundamentally change the operational requirements that 
would apply to a transmission customer and the associated Large Load.  Additionally, the criteria 
MISO applies when evaluating whether to revoke an exemption will determine whether revocation 
is reserved for extraordinary circumstances or may occur as a matter of course.  Equally important, 
the timing of any such evaluation and the compliance timeline afforded to an affected customer 
will determine whether revocation is a manageable transition or a significant disruption to the 
customer’s operations.  
Additionally, without tariff provisions that clearly set out the standards and procedures 
governing revocation, the Commission cannot meaningfully evaluate whether MISO’s proposed 
grandfathering framework will achieve the objective of minimizing disruption to existing 
commercial arrangements.  The practical effect is that the Commission is being asked to approve 
a framework for protecting settled expectations without knowing the criteria under which those 
protections may be withdrawn.  
There is no reason that MISO cannot describe the standards and processes that it would use 
to revoke an exemption in the tariff—just as it has described the criteria that customers would be 
required to meet to qualify for an exemption in the first place.  And nothing about MISO’s 
 
39 Id.

- 14 - 
process—from the standards applied to how MISO would implement this authority—is generally 
understood or implied by the limited description that MISO has proposed to include in the tariff.  
iv. 
MISO Has Not Justified The Omission Of Metering Standards 
And Other Requirements 
MISO’s proposed tariff language also omits other significant requirements related to the 
standards and procedures that will be applied to transmission customers and the Large Loads that 
they serve.  For instance, while the Commission has recognized that the Rule of Reason requires 
metering standards to be described in the tariff and the existing tariff already includes detailed 
metering requirements for market participants,40 MISO’s proposed tariff revisions in this 
proceeding do not provide any detail about the metering standards that will be applied to Large 
Load or any generation resources serving these customers.41  The Commission also has found that 
procedural deadlines, such as deadlines for submitting data and information to a transmission 
provider, should be specified in the tariff, particularly where the failure to abide by these 
requirements could have adverse consequences for entities taking service under the tariff.42  Yet, 
MISO again proposes to leave such deadlines to its BPMs even though failure to comply with 
these requirements may adversely affect a customer’s ability to receive transmission service.43 
The matters described above may not be as consequential as the criteria used to determine 
whether to revoke an exemption from tariff requirements or the substance of the reliability 
 
40 See, e.g., Midcontinent Indep. Sys. Operator, Inc., 169 FERC ¶ 61,137 at P 252 (2019) (finding that MISO’s 
tariff should include a “description of MISO’s proposed metering methodology and accounting practices for Electric 
Storage Resources”); MISO Tariff § 38.2.5(e) (describing metering standards applicable to market participants, 
including applicable minimum standards, accuracy standards, and testing requirements). 
41 Filing, Tab A, Proposed § 37A.3. 
42 See, e.g., PJM Interconnection, L.L.C., 182 FERC ¶ 61,143 at P 249 (2023), order on compliance, 188 
FERC ¶ 61,076 at P 101 (2025) (finding tariff incomplete because it omitted deadline for meter submissions). 
43 See, e.g., Filing, Tab A, Proposed § 37A.1 (stating that transmission customer will provide basic 
information, one-line diagrams, and description of electrical characteristics consistent with timelines specified in the 
BPMs); Id., § 37A.2 (stating that transmission customer must provide modeling information in format and consistent 
with timelines specified in BPMs).

- 15 - 
standards that MISO proposes to apply.  But they nonetheless significantly affect FERC-
jurisdictional service as transmission customers and the Large Loads that they serve must comply 
with these requirements to obtain service.  They also are the types of details that are regularly 
included in transmission provider tariffs.  MISO has not demonstrated that providing transmission 
customers serving Large Loads and their customers with less notice and transparency than other 
customers is just, reasonable, and consistent with the Rule of Reason.     
v. 
MISO’s Approach Undermines Certainty, Predictability, And 
Commission Oversight 
The practical effect of the tariff revisions that have been proposed is that neither the 
Commission nor commenters have the information necessary to determine whether the substance 
of MISO’s proposed framework is just, reasonable, and not unduly discriminatory or preferential.  
This places the Commission and commenters in the impossible position of being asked to evaluate 
a reliability framework without any insight into the substance of the standards or other key terms 
and conditions of service. Without the operative standards and procedures before it, the 
Commission cannot determine whether the proposed requirements are supported by demonstrated 
reliability needs, reasonably tailored to the risks MISO seeks to address, capable of being applied 
consistently to similarly situated customers, or will achieve the objective of minimizing disruption 
to existing commercial arrangements.  
MISO’s proposed framework undermines the certainty that the Show Cause Order sought 
to promote.  The proposed tariff language does not provide customers with notice of the 
requirements that will apply, how compliance will be assessed, or even whether their facilities 
ultimately will be deemed subject to these requirements.  Large Load customers need to understand 
the scope of their obligations when making investment decisions and entering commercial 
arrangements.  And the tariff must provide customers with assurance that exemptions, once

- 16 - 
granted, cannot be summarily revoked based on a subjective MISO assessment without regard to 
the stage of development of their facilities.  
 
MISO’s proposal also creates a risk of inconsistent standards and application.  
Transmission customers serving Large Loads or Computational Loads should be subject to a 
common set of standards and requirements, as applicable.  Yet, since the details of these 
requirements are not provided in the tariff, neither the Commission nor customers have any 
assurance that the requirements that ultimately are adopted will be applied in a manner that ensures 
consistent and non-discriminatory treatment of customers.  
Finally, the proposed framework would allow MISO to create through future BPM 
revisions the very disruption to settled expectations that the Show Cause Order directed MISO to 
avoid.  Placing the substance of MISO’s reliability requirements in the BPMs means that the 
standards, as well as their application to individual customers, can be modified by MISO without 
formal notice to customers or approval by the Commission.  As the Commission recognized in the 
Show Cause Order, the application of new reliability requirements to customers has the potential 
to disrupt the settled expectations of customers that have relied on existing market rules when 
developing their facilities.44  It was precisely for this reason that the Commission directed MISO 
to propose measures to minimize disruption to existing commercial arrangements.45  Yet, MISO’s 
proposal would allow it to revise these same requirements through the BPMs after customers have 
designed their facilities and entered commercial arrangements without making a Section 205 filing 
or seeking Commission approval—and without any obligation to take steps to protect settled 
expectations.       
 
44 Show Cause Order at P 123.  
45 Id.

- 17 - 
B. 
MISO Has Not Demonstrated That Its Proposed Definition Of Large Load Is 
Just, Reasonable, And Not Unduly Discriminatory Or Preferential 
MISO’s proposed definition of Large Load also creates ambiguity regarding the scope and 
application of MISO’s proposed requirements.  Because classification as a “Large Load” carries 
substantial regulatory and commercial consequences, it is critical that any definition of Large Load 
provide clear notice to transmission customers and the loads they serve of whether they will be 
subject to these requirements.  At the same time, the definition of Large Load should be limited to 
customers serving load whose size, location, and operating characteristics present the reliability 
risks that the Commission sought to address in the Show Cause Order.  MISO’s proposed 
definition of Large Load does not meet these standards.   
Indeed, MISO has proposed a definition that departs in material respects from the definition 
identified in the Show Cause Order without adequately explaining those departures, clarifying 
their effect on the scope of the proposed requirements, or demonstrating how they correspond to 
the reliability concerns underlying this proceeding. In the Show Cause Order, the Commission 
stated that it would be reasonable to define a large load as  
a new, commercial or industrial customer, located at a single site behind one or 
more points of interconnection, and that has a peak load of 50 MW or greater, 
interconnects to the transmission system at a voltage level of greater than 69 kV, 
and is not part of a co-location arrangement.46 
In its Filing, however, MISO proposes a definition of Large Load that omits any voltage 
thresholds, is not expressly limited to transmission-connected load, and provides MISO the 
authority to aggregate customers based on vague and subjective standards:   
Load with Demand of 50 MW or more associated with any facility or aggregation 
of facilities located at a single substation behind one or more Point(s) of Withdrawal 
from the Transmission System that is owned, operated, or controlled by: (a) a single 
entity, or (b) a group of entities that will coordinate with respect to the profile of 
 
46 Id. at P 58.

- 18 - 
the Load. Large Load does not include Load used exclusively for charging an 
Electric Storage Resource.47 
 
As discussed further below, MISO’s proposed definition of Large Load appears 
inconsistent with the Show Cause Order and only injects further uncertainty into the scope of 
MISO’s requirements.  The Commission’s definition of Large Load was tailored to capture large, 
transmission-connected loads that the Commission believed present distinct operational and 
reliability risks “given their size, operational behavior, and unique potential to impact the 
transmission system.”48  It is not clear that MISO’s definition is so limited.  Instead, the definition 
appears broad enough to be interpreted as extending to transmission customers that are taking 
transmission service to serve loads that are interconnected solely to the distribution system and has 
the potential to result in the aggregation of facilities that do not exhibit the scale or characteristics 
that were the focus of the Show Cause Order.       
1. 
The Definition Of Large Load Should Be Limited To Transmission-
Interconnected Loads 
The absence of any voltage criteria or requirement that a customer be interconnected to the 
transmission system from the definition of Large Load could be interpreted as extending the term 
to loads that are interconnected solely to the distribution network.  Under MISO’s proposed 
definition, an entity or group of entities with 50 MW or more of load located at a single substation 
behind one or more “Point(s) of Withdrawal” from the transmission system would be classified as 
a Large Load.  Because Point of Withdrawal is defined as the point where a non-transmission 
 
47 Filing, Transmittal Letter at 10.  DCC notes that, in contrast to the Commission’s definition, MISO’s 
proposed definition does not distinguish between Large Loads and loads participating in a co-location arrangement.  
MISO should clarify the application of the Large Load definition to co-located loads consistent with the Commission’s 
recognition of the distinct issues presented by such arrangements in the MISO Show Cause Order.  Show Cause Order 
at P 86.  Additionally, if MISO is going to apply its proposed reliability requirements to co-located load, it should 
demonstrate that the proposed standards are appropriately tailored to account for the characteristics of these 
arrangements. 
48 Show Cause Order at P 58.

- 19 - 
facility that is used to withdraw energy to serve load connects with the transmission system, the 
definition of Large Load could be interpreted as extending to distribution-connected loads merely 
because they are located downstream of the transmission-distribution interface.  
 
The potential issues created by MISO’s proposed definition can be illustrated by 
considering the position of a 75 MW industrial or commercial customer interconnected to a 
distribution substation within the MISO region as reflected in Figure 1 below.  Although the 
customer’s facility is not connected to the MISO transmission system, the customer’s facility 
would appear to meet the definition of Large Load because (1) its facility has a load of 50 MW or 
more interconnected at a single substation; (2) the facility is located behind the point at which the 
distribution system interconnects with the MISO transmission system; and (3) the facility is owned 
by a single entity.   
Figure 1: Single Distribution-Connected Facility 
 
 
Defining Large Load to include distribution-interconnected loads would extend the tariff’s 
requirements beyond the category of customers that the Commission identified in the Show Cause 
Order as giving rise to the reliability concerns underlying this proceeding.  The Commission 
initiated this proceeding because it recognized that the integration of large loads into the 
transmission system has the potential to materially affect transmission planning, system 
operations, and resource adequacy.  Loads that are interconnected solely to the distribution

- 20 - 
network lack the same nexus that justified the Commission’s intervention in the Show Cause 
Order.  Absent revision and clarification, MISO’s proposed definition could be interpreted as 
sweeping in customers whose relationship to the transmission network may be indistinguishable 
from any other retail customer served through bundled retail service. 
Extending the definition of Large Load to customers that are interconnected to distribution 
facilities also presents jurisdictional concerns.  In the Show Cause Order, the Commission 
recognized that the FPA reserves to the states the authority to regulate retail sales and facilities for 
the distribution of electricity and that nothing in the order was intended to intrude upon state 
jurisdiction.49  To respect the jurisdictional boundaries established by Congress, the Commission 
made clear that it was exercising its authority solely to address the rules governing the “provision 
of jurisdictional transmission service to Eligible Customers on behalf of large loads 
interconnecting to the transmission system[.]”50   
 
Classifying distribution-connected loads as Large Loads would be particularly problematic 
in MISO where most retail customers continue to receive service under traditional bundled retail 
rates.51  The Commission has long drawn, and the courts have upheld, a jurisdictional line under 
which transmission that remains bundled with the sale and delivery of electric energy to an ultimate 
consumer is treated as part of a state-regulated retail sale.52  Yet, MISO’s proposed definition could 
 
49 Id. at P 46.  
50 Id. at P 47 (emphasis added).   
51 Midcontinent Indep. Sys. Operator, Inc., 192 FERC ¶ 61,064 at PP 35-36 (2025), order on reh’g, 194 
FERC ¶ 61,050 (2026) (noting that MISO region is largely comprised of vertically integrated utilities).  
52 Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Services by 
Public Utilities; Recovery of Stranded Costs by Public Utilities and Transmitting Utilities, Order No. 888, 61 Fed. 
Reg. 21,540, 21,625 (May 10, 1996). (“[W]hen transmission is sold at retail as part and parcel of the delivered product 
called electric energy, the transaction is a sale of electric energy at retail.”), clarified, 76 FERC ¶ 61,009 (1996), order 
on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 31,048, at 30272 (1997), order on reh’g, Order No. 888-B, 81 
FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d in part and remanded in 
part sub nom. Transmission Access Policy Study Grp. v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New 
York v. FERC, 535 U.S. 1 (2002).

- 21 - 
result in customers interconnected solely to state-jurisdictional distribution facilities and receiving 
service through bundled retail rates being required to comply with operational requirements 
developed for large transmission-interconnected load.  
 
DCC notes that it is not entirely clear that MISO intends for the definition of Large Load 
to extend to transmission customers that are serving loads that are interconnected solely to the 
distribution network, as certain tariff revisions proposed by MISO appear to contemplate 
transmission-interconnected loads.53  But this same limitation is not reflected in the definition of 
Large Load.  If MISO intends to limit the definition of Large Load to customers directly 
interconnected to transmission facilities, the tariff language should explicitly include that 
limitation consistent with the definition included in the Show Cause Order.  Because classification 
as a Large Load carries significant regulatory consequences, affected customers should not be 
required to infer from context whether a definition applies to transmission-interconnected 
facilities, distribution-interconnected facilities, or both. 
2. 
MISO Has Not Demonstrated That Its Proposal To Aggregate 
Customer Facilities Is Just And Reasonable 
MISO also does not demonstrate that its proposal to aggregate facilities and customers is 
just, reasonable, and not unduly discriminatory.  As a starting point, MISO’s proposal to define 
Large Load based on the load of facilities sharing a substation—rather than on the load of 
individual customers—risks sweeping in relatively small commercial and industrial loads that do 
not present the reliability concerns that the Commission sought to address in the Show Cause 
Order.  Consider the example in Figure 2 of the load associated with two 20 MW industrial 
facilities and a 10 MW commercial facility located within a single industrial park that is owned by 
 
53 See, e.g., Filing, Transmittal Letter at 22 (stating that “Large Load Equipment” is defined as the “facilities, 
devices, or equipment that . . . are used to interconnect the Large Load to the Transmission System”) (emphasis added).

- 22 - 
a single commercial landlord and that share a single substation.  Although the tenants leasing these 
facilities may operate separate businesses, with different load profiles, MISO’s proposed definition 
could be interpreted as requiring them to be treated as a single large load because (1) the aggregate 
load of the facilities meets the 50 MW threshold; (2) the facilities are owned by a single entity 
(i.e., the same landlord); and (3) the facilities share a single substation.  
Figure 2: Aggregation Of Customers 
 
MISO’s aggregation proposal also could result in the application of MISO’s proposed 
Computational Load standards to customers whose primary business is unrelated to computing.  
For instance, if the example described in Figure 2 were modified such that one of the facilities 
were a 30 MW data center or cryptocurrency miner, it could result in the aggregation of facilities 
being deemed a Computational Load because it contains 25 MW or more of demand from 
information technology equipment, as reflected in Figure 3 below.

- 23 - 
Figure 3: Aggregation With Computational Load 
 
Like the application of the definition to distribution-connected load, it is not clear that the 
intent of MISO’s definition is to capture these types of arrangements within the definitions of 
Large Load or Computational Load.  But these examples highlight that the scope of the definition 
of Large Load remains unclear and requires further tailoring to ensure that the definition provides 
customers with adequate notice and captures those loads that present the reliability concerns 
discussed in the Show Cause Order.   
MISO’s proposal to aggregate facilities is even more concerning given its proposal to grant 
itself authority to aggregate facilities owned by entities that MISO deems to be “coordinating” 
with respect to their load profile.  Notably, neither the tariff nor the transmittal letter defines what 
constitutes coordination or provides objective criteria for making that determination.  The Filing 
does not explain, for instance, whether the relevant inquiry turns on common ownership, 
contractual arrangements, operational practices, or some other form of relationship between the 
facilities.   
Nor does MISO explain the degree of coordination necessary to warrant treatment as a 
single Large Load.  For example, it is unclear whether two facilities would be aggregated because

- 24 - 
they coordinate maintenance outages, share common equipment, or simply share a contractual 
relationship with the same service provider.  Instead, MISO’s proposal leaves that determination 
to an undefined and inherently subjective assessment of whether entities are sufficiently 
“coordinated” with respect to their load profile. 
If MISO is going to adopt a standard that would allow it to aggregate facilities owned by 
separate entities into a single “Large Load” under the MISO tariff, then it should be required to 
adopt objective and transparent criteria that are narrowly tailored to capture those loads that present 
the reliability concerns at issue and that provides customers with clear notice of a customer’s 
treatment and regulatory obligations.  Classification as a Large Load should not be left to a 
transmission provider’s subjective determination based on vague and undefined standards.   
The Commission has recognized the importance of ensuring that tariffs contain transparent 
and objective standards that constrain opportunities for the exercise of subjective discretion.54  For 
instance, the Commission previously rejected a proposal by PJM Interconnection, L.L.C. (“PJM”) 
to define Fast-Start Resource as a resource that PJM deemed capable of meeting start-up and 
minimum run-time requirements set out in the tariff on the basis that it provided PJM with “too 
much discretion, and that this process should be more clearly defined in the Tariff.”55  MISO’s 
proposal suffers from a similar defect.  Without objective standards defining when multiple 
facilities will be treated as a Large Load, the application of MISO’s definition would rest on the 
type of case-by-case assessment that the Commission has found insufficient to ensure consistent 
and non-discriminatory treatment.   
 
54 See Sw. Power Pool, Inc., 175 FERC ¶ 61,198, at PP 9, 39–40 (2021) (rejecting provision that would allow 
SPP board to waive zonal allocation of Byway facilities where tariff “contains no objective standards, criteria, or 
thresholds for the SPP’s Board’s decision whether to approve or deny a waiver”); order on reh’g, 184 FERC ¶ 61,028, 
at PP 49–52, order on reh’g, 185 FERC ¶ 61,189 (2023). 
55 PJM Interconnection, L.L.C., 173 FERC ¶ 61,244, at PP 22-26 (2020).

- 25 - 
 
For the foregoing reasons, DCC requests that the Commission reject MISO’s proposed 
definition of Large Load without prejudice to MISO filing a revised proposal that includes 
narrowly tailored, objective, and transparent criteria for the classification of Large Loads.   
C. 
MISO Has Not Demonstrated That Its Grandfathering Proposal Will 
Minimize Disruption To Existing Commercial Arrangements  
In the Show Cause Order, the Commission recognized that while changes to the MISO 
tariff are warranted, large loads already are working with transmission owners and other entities 
to interconnect their projects and obtain transmission service, including that customers are 
“negotiating, entering into, and/or have executed various agreements related to interconnecting to 
the transmission system and/or the provision of transmission service.”56  Accordingly, the 
Commission directed MISO to address in its response to the Show Cause Order how MISO would 
“ensure minimal disruption to such existing commercial arrangements” and allow a “reasonable 
amount of time to finalize ongoing agreements that are nearing completion as of the date such 
Tariff provisions are filed with the Commission.”57 
 
MISO proposes to respond to this directive by exempting certain resources from the 
reliability requirements proposed in its Filing.  Specifically, MISO proposes that:  
• A Large Load, or portion of a Large Load, with a Service Commencement Date on 
or before December 4, 2026 would be fully exempt from Section 37A.  
• A Large Load, or portion of a Large Load, with a Service Commencement Date 
after December 4, 2026 that is associated with a transmission project that either (i) 
has been approved by the MISO Board in MTEP 2026, or a prior MTEP, or (ii) has 
been submitted to MISO for EPR on or prior to June 18, 2026 (the “MTEP/EPR 
Condition”) would be exempt from ride-through and ramp requirements.   
• A Large Load, or portion of a Large Load, that does not have a Service 
Commencement Date prior to December 4, 2026 and does not meet the MTEP/EPR 
Condition but is associated with a transmission project submitted to MISO for EPR 
between June 19, 2026 and October 31, 2026 would be subject to all of the 
 
56 Show Cause Order at P 123.  
57 Id.

- 26 - 
requirements of Section 37A unless MISO waives the ride-through requirements 
after concluding that such waiver would not have an adverse reliability impact and 
compliance with such requirements would result in significant costs.58 
DCC appreciates MISO’s effort to recognize the potential impact that its proposed 
reliability requirements could have on existing large load customers that already have entered 
commercial arrangements based on existing market rules.  In practice, requiring customers that 
have already commenced the development of their facilities to comply with new ride-through, 
ramp limits, and other requirements has the potential to create significant disruption by forcing 
customers to redesign their projects, modify protection and control systems, replace equipment, 
and implement other project-specific engineering modifications.  As a result, it is critically 
important that any new reliability requirements that are adopted include measures to respect the 
settled expectations of customers, including appropriate exemptions and transition periods for 
customers that are required to comply with these requirements.  
DCC believes, however, that MISO has not demonstrated that its proposal is appropriately 
tailored to avoid disruption to existing commercial arrangements that the Commission sought to 
address in the Show Cause Order.  MISO’s proposed grandfathering framework turns entirely on 
the status of an associated transmission project in the MTEP or EPR process rather than on the 
commitments or progress made by Large Load customers.  In practice, whether a transmission 
project satisfies the MTEP/EPR Condition may reflect little more than the timing or nature of a 
transmission upgrade rather than the maturity of the underlying project.  Indeed, a customer may 
execute utility service agreements, secure financing, procure major equipment, commit substantial 
capital, and make irreversible business decisions prior to when an associated transmission project 
reaches the applicable MTEP or EPR milestone.   
 
58 Filing, Transmittal Letter at 14; Filing, Tab A, Proposed § 37A.II.

- 27 - 
MISO’s proposal also has the potential to result in arbitrary differences in treatment 
between similarly situated transmission customers serving Large Loads.  Because the 
grandfathering proposal is tied to the status of transmission upgrades associated with a particular 
Large Load, a Large Load customer that has not triggered the need for transmission upgrades 
requiring approval through the MTEP or EPR processes would not have any path to achieving 
grandfathered treatment except energizing its project prior to December 2026.  The result is a 
framework under which projects at identical stages of development may receive materially 
different treatment simply because one project requires transmission upgrades subject to the MTEP 
or EPR processes while the other does not.   
Indeed, MISO’s proposal could create barriers to the timely development of projects that 
have a relatively clear path to obtaining service in the near-term while providing grandfathered 
treatment to less advanced customers.  For instance, a Large Load customer with a facility in the 
final stages of development that did not trigger significant transmission upgrades may have to 
delay placing its facility into operation in order to redesign its facility, including procuring and 
installing new equipment and hardware, because it is unable to qualify for an exemption, even 
though existing grid capacity is sufficient to support its load.  At the same time, a Large Load 
customer that may have to wait several years to commence operations while necessary 
transmission facilities are constructed may be exempt from these requirements based solely on the 
timing of when relevant transmission upgrades were submitted to MISO for review and approval. 
Such arbitrary differences in treatment are unduly discriminatory and preferential.59 
MISO argues that it proposed the MTEP/EPR Condition because MISO does not have a 
“Load interconnection process” and the need for transmission upgrades or related projects can be 
 
59 Consol. Edison Co. of N.Y., Inc. v. FERC, 45 F.4th 265, 282 (D.C. Cir. 2022) (“[U]ndue discrimination 
occurs when similarly situated entities are charged different rates for no good reason.”).

- 28 - 
identified through the MTEP or EPR process.60  But MISO need not examine its MTEP and EPR 
processes to try to discern the relative maturity of different customers’ projects.  Instead, MISO 
can address any potential gaps by requiring customers to provide evidence of their commercial 
arrangements as a precondition of obtaining an exemption.   
In short, MISO has not demonstrated that its proposal to tie grandfathered treatment to the 
status of necessary transmission upgrades will further the objective of minimizing disruption to 
existing commercial arrangements or why the status of transmission upgrades in the MTEP or EPR 
processes is a useful proxy for the commercial maturity of Large Load projects.  And while 
MISO’s proposal would result in customers that satisfy the MTEP/EPR Condition receiving 
preferential treatment relative to other customers, MISO has not demonstrated that satisfaction of 
the MTEP/EPR Condition is an appropriate basis for disparate treatment.    
To achieve the objective that the Commission articulated in the Show Cause Order, DCC 
believes that MISO should adopt grandfathering provisions that exempt projects based on 
objective evidence that a customer has entered material commercial arrangements for its project 
prior to the effective date of MISO’s proposed tariff revisions.  This could include, for instance, 
executed interconnection agreements, transmission service agreements, utility service agreements, 
or major equipment orders.  Such an approach would tie the grandfathering provisions to the types 
of commercial arrangements that the Commission sought to respect in the Show Cause Order. 
DCC believes that customers that provide objective evidence that they have entered into 
the types of agreements described above should be exempt from the proposed ride-through and 
ramp-rate requirements while remaining subject to the remaining requirements outlined in MISO’s 
filing.  Complying with new ride-through and ramp requirements may require a customer to 
 
60 Filing, Tab C at 19.

- 29 - 
redesign its facility, replace and procure additional equipment, and modify existing operating and 
contractual requirements.  For instance, a customer subject to new ride-through and ramp 
requirements may need to install new power-electronic conversion equipment, battery energy 
storage systems, and site protection relays/facility control systems.  As a result, it is the application 
of ride-through and ramp limit requirements that are most likely to undermine existing commercial 
arrangements.  Providing an exemption only from ride-through and ramp limit requirements would 
protect objectively verifiable reliance interests while preserving MISO’s access to the information 
necessary to maintain system visibility and address demonstrated reliability risks.     
IV. 
MOTION TO INTERVENE  
DCC respectfully moves to intervene in this proceeding.  DCC is the membership 
organization for the U.S. data center industry, representing leading data center owners and 
operators that develop, operate, and maintain data center infrastructure and teams across the 
country.  DCC members operate data centers that constitute significant loads within the MISO 
region and DCC has been an active stakeholder in regional efforts to ensure reliability, enable new 
generation, and discipline load forecasts.  
DCC’s member companies provide the essential digital infrastructure that underpins the 
modern economy and supports critical public services, including cloud computing, artificial 
intelligence, emergency response systems, and public safety operations.  From 2017 to 2023, the 
data center industry contributed $3.5 trillion to U.S. GDP.  As the industry unlocks unprecedented 
economic opportunities across the country and in the MISO region, supporting affordability is a 
foundational priority for DCC members and the communities they serve.  DCC advocates for grid 
reforms that minimize unnecessary cost burdens, align with cost causation principles, facilitate

- 30 - 
responsible load growth, support the development of new generation, and enhance grid resilience 
system-wide without imposing undue costs on existing ratepayers.   
For the above reasons, DCC has a substantial interest in the outcome of this proceeding 
that cannot be represented adequately by any other participant to this proceeding.  DCC’s 
intervention is in the public interest and its motion for leave to intervene in this proceeding should 
be granted. 
V. 
CORRESPONDENCE AND COMMUNICATIONS 
DCC requests that the following names be placed on the official service list for this 
proceeding by the Commission and that all correspondence and communications with respect to 
this proceeding be addressed to the following:61 
Morgan A. Sipple 
Director, Energy Policy – FERC and RTOs 
DATA CENTER COALITION 
1250 H Street, NW 
Washington, DC  20005 
morgan@datacentercoalition.org  
 
 
Stephen J. Hug 
Christopher Hargett 
AKIN GUMP STRAUSS HAUER & FELD LLP 
2001 K Street, N.W. 
Washington, D.C.  20006 
Tel: (202) 887-4000 
shug@akingump.com  
chargett@akingump.com  
 
 
 
 
 
 
61 DCC respectfully requests waiver of Rule 203(b)(3) of the Commission’s regulations, 18 C.F.R. § 
385.203(b)(3), in order to permit designation of more than two persons for service in this proceeding.

- 31 - 
VI. 
CONCLUSION 
For the reasons set out above, DCC respectfully requests that the Commission issue an 
order consistent with these comments.  
 
Respectfully submitted, 
 
 
 
/s/ Stephen J. Hug 
Morgan A. Sipple 
Director, Energy Policy – FERC and RTOs 
DATA CENTER COALITION 
1250 H Street, NW 
Washington, DC  20005 
morgan@datacentercoalition.org  
 
Data Center Coalition 
Stephen J. Hug 
Christopher Hargett 
AKIN GUMP STRAUSS HAUER & FELD LLP 
2001 K Street, N.W. 
Washington, D.C.  20006 
Tel: (202) 887-4000 
shug@akingump.com 
chargett@akingump.com  
 
 
 
Dated: September 18, 2026 
 
 
Counsel for the Data Center Coalition

CERTIFICATE OF SERVICE 
I hereby certify that I have this day served a copy of the foregoing document on the persons 
designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Washington, D.C., this 18th day of September 2026. 
/s/ Stephen J. Hug 
 
 
 
Stephen J. Hug