Tab C - Testimony of BeiBei Li.pdf
Read topic-matched comments in ER26-3650
Topics in the text: Cost allocation · Registry access
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Opening text
opening text
Tab C Tab C UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Midcontinent Independent ) Docket No.Read this passage
I. PROFESSIONAL BACKGROUND AND QUALIFICATIONS
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PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND RELATIONSHIP TO 2 THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC. 3Read this passage
A. My name is Beibei Li. I am the Senior Manager of Strategic Assessment for the
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I am the Senior Manager of Strategic Assessment for the 4 Midcontinent Independent System Operator, Inc. (“MISO”).Read this passage
A. As Senior Manager of Strategic Assessment, I lead MISO’s evaluation and framing of
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As Senior Manager of Strategic Assessment, I lead MISO’s evaluation and framing of 17 emerging reliability risks and the development of practical, implementable solutions, 18 including the ongoing operational requirements for Large Load. 19 Q.Read this passage
II. PURPOSE OF TESTIMONY
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II.Read this passage
A. The purpose of my testimony is to support MISO’s proposal to apply a defined set of
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The purpose of my testimony is to support MISO’s proposal to apply a defined set of 3 reliability requirements to certain loads, defined as Large Loads.1 4 Q.Read this passage
A. As discussed below in greater detail, the IRR proposal defines “Large Load” and is
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Matters involving new transmission 17 service products, study processes and potential cost shifting for Large Loads will be 18 1 As discussed below, MISO proposes to defined Large Load as Load with Demand of 50 MW or more associated with any facility or aggregation of facilities located at a single…Read this passage Filed comments: Cost allocation
III. THE RISE OF LARGE LOADS AND
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THE RISE OF LARGE LOADS AND 3 RELATED INTERCONNECTION REQUESTS 4 5 Q.Read this passage
A. The MISO region is experiencing a significant increase in both the scale and pace of Large
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This combination of increased 14 volume and accelerated development is changing the manner in which MISO must plan for 15 and reliably integrate new load. 16 Q.Read this passage
A. Accommodating the accelerated interconnection of Large Loads requires MISO to ensure
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Accommodating the accelerated interconnection of Large Loads requires MISO to ensure 20 that the Transmission System can reliably plan for and operate these facilities as they come 21 online.Read this passage
A. The North American Electric Reliability Corporation (“NERC”), through the Large Loads
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The North American Electric Reliability Corporation (“NERC”), through the Large Loads 18 Working Group, has identified emerging large loads as an increasing reliability 19 consideration for the Bulk Power System.Read this passage
A. MISO is experiencing increasing levels of Large Load development being evaluated
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Existing MISO planning and operational processes 4 provide a strong foundation for evaluating reliability impacts; however, the increasing size, 5 concentration, and changing characteristics of Large Loads create a need for greater 6 consistency in the information, visibility, and performance…Read this passage
A. Yes. In recent years, MISO established the Expedited Resource Addition Study (“ERAS”)
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In recent years, MISO established the Expedited Resource Addition Study (“ERAS”) 17 as a targeted, temporary process to issue a Generator Interconnection Agreement in three 18 months.Read this passage
A. While these initiatives provide important benefits, they do not fully address the reliability
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While these initiatives provide important benefits, they do not fully address the reliability 2 and operational challenges associated with accelerating large load growth.Read this passage
A. MISO is proposing to implement a reliability-based framework to support the
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MISO is proposing to implement a reliability-based framework to support the 12 interconnection and ongoing operational challenges of Large Loads within the MISO 13 region.Read this passage
IV. MISO’S LARGE LOAD INTERCONNECTION RELIABILITY
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MISO’S LARGE LOAD INTERCONNECTION RELIABILITY 1 REQUIREMENTS PROPOSAL 2 Q.Read this passage
A. MISO’s IRR proposal establishes a reliability framework surrounding Large Load
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MISO’s IRR proposal establishes a reliability framework surrounding Large Load 5 interconnection that is focused on visibility of Large Loads and management of the ongoing 6 operational impacts Large Loads present.Read this passage
A. DEFINITIONS
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PLEASE IDENTIFY THE NEW DEFINITIONS MISO PROPOSES TO 4 IMPLEMENT THROUGH THIS FILING. 5Read this passage
A. The following definitions are provided to support consistent interpretation of the reliability
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The following definitions are provided to support consistent interpretation of the reliability 6 framework described in this filing: 7 • Computational Load: Large Load comprised of 25 MW or more of Demand from 8 information technology equipment, such as servers, storage, and networking 9 hardware.…Read this passage
A. MISO developed the proposed Large Load definition through review of emerging industry
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MISO developed the proposed Large Load definition through review of emerging industry 3 practices, consideration of the reliability needs within the MISO region, and stakeholder 4 feedback.Read this passage
A. MISO determined that 50 MW is a reasonable threshold based on industry precedent,
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MISO determined that 50 MW is a reasonable threshold based on industry precedent, 20 including from PJM and SPP, and the need for a clear and administratively workable means 21 of identifying significant, concentrated loads that warrant additional reliability visibility. 22 Tab C Page 13 A load of…Read this passage
A. MISO defines Computational Load to distinguish a subset of Large Loads that may exhibit
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MISO defines Computational Load to distinguish a subset of Large Loads that may exhibit 11 operational characteristics different from more traditional loads, including rapid changes 12 in demand, highly coordinated control behavior, and power-electronic responses during 13 system disturbances.Read this passage
A. MISO’s proposed definition of Computational Load is closely aligned with NERC’s
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MISO’s proposed definition of Computational Load is closely aligned with NERC’s 9 developing definition of computational load.Read this passage
B. SCOPE AND APPLICABILITY
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B.Read this passage
A. This filing proposes reliability requirements and a reliability-based framework applicable
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This filing proposes reliability requirements and a reliability-based framework applicable 3 to Transmission Customers taking Transmission Service on behalf of Large Load 4 interconnected to the MISO Transmission System.Read this passage
A. No. This IRR proposal focuses specifically on reliability requirements applicable to Large
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This IRR proposal focuses specifically on reliability requirements applicable to Large 15 Loads in the MISO region.Read this passage
A. The proposed requirements in this filing apply to the Large Load as set forth in the Tariff
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The proposed requirements in this filing apply to the Large Load as set forth in the Tariff 19 and the Business Practices Manual for Large Load, and as discussed further below. 20 Subject to the transition provisions discussed below, all Large Loads will be subject to the 21 applicable visibility…Read this passage
A. The IRR proposal establishes that the Transmission Customer taking Transmission Service
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The term “Transmission 14 Customer” is currently defined in the MISO Tariff as: “Any Eligible Customer (or its 15 Designated Agent) that (i) executes a Service Agreement, or (ii) requests in writing that the 16 Transmission Provider file with the Commission, a proposed unexecuted Service 17…Read this passage
A. Requiring the Transmission Customer to prove compliance with the requirements
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Requiring the Transmission Customer to prove compliance with the requirements 4 established in the IRR proposal is consistent with the Show Cause Order’s discussion of 5 imposing requirements on an “Eligible Customer” and recognizes that the ultimate owner 6 of a Large Load may not participate…Read this passage
C. TRANSITION PROVISIONS
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HOW DOES THE IRR FILING RECOGNIZE EXISTING COMMERCIAL 18 ARRANGEMENTS, AND COMMERCIAL ARRANGEMENTS NEAR 19 COMPLETION, AS CONTEMPLATED BY THE SHOW CAUSE ORDER? 20Read this passage
A. The IRR Filing includes transition provisions that are intended to provide certainty to
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The IRR Filing includes transition provisions that are intended to provide certainty to 21 existing commercial arrangements and commercial arrangements that were near 22 completion at the time of this filing.Read this passage
A. For purposes of the transition provisions, Load will satisfy the “MTEP/EPR Condition” if
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For purposes of the transition provisions, Load will satisfy the “MTEP/EPR Condition” if 10 it is associated with a transmission project that either: (a) has been approved by the MISO 11 Board in MTEP 2026, or a prior MTEP; or, (b) has been submitted to MISO for EPR on or 12 prior to June 18, 2026,…Read this passage
A. Under current processes, MISO does not have a Load interconnection process. As such,
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Under current processes, MISO does not have a Load interconnection process.Read this passage
A. The June 18, 2026, date coincides with the Commission’s issuance of the Show Cause
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The June 18, 2026, date coincides with the Commission’s issuance of the Show Cause 4 Order and establishes a date on which all parties were on notice that significant changes to 5 MISO’s Tariff, and requirements for Large Loads in particular, should be expected in the 6 near future.Read this passage
A. MISO proposes to implement the following transition provisions:
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MISO proposes to implement the following transition provisions: 13 First, MISO proposes to fully exempt, or “grandfather,” any Large Load that has a Service 14 Commencement Date on or prior to December 4, 2026, from all requirements of the 15 proposed Section 37A, with respect to the portion of the…Read this passage
A. MISO provides a potential exemption from the ride-through requirements for certain
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MISO provides a potential exemption from the ride-through requirements for certain 18 projects submitted between June 19, 2026, and October 31, 2026, to provide a reasonable 19 transition for projects that were nearing completion at the time of this filing. 20 The June 19, 2026, date immediately…Read this passage
A. No. A Large Load, or a portion of a Large Load, that does not meet the MTEP/EPR
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A Large Load, or a portion of a Large Load, that does not meet the MTEP/EPR 16 Condition shall be subject to all applicable requirements set forth in proposed Section 37A. 17 Q.Read this passage
A. MISO developed the transition provisions through a deliberate process that considered both
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MISO developed the transition provisions through a deliberate process that considered both 19 identified reliability needs and practical implementation considerations for Large Loads at 20 different stages of development.Read this passage
D. LARGE LOAD RELIABILITY REQUIREMENTS
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PLEASE SUMMARIZE THE PROPOSED RELIABILITY REQUIREMENTS. 7Read this passage
A. The proposed framework consists of the following categories of reliability requirements
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Computational Loads must remain connected and continue operation during voltage and frequency disturbances within the performance criteria established by MISO.Read this passage
A. The objective of the proposed data and modeling requirements is to ensure sufficient
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The objective of the proposed data and modeling requirements is to ensure sufficient 4 visibility into the characteristics, operating behavior, and electrical performance of Large 5 Loads necessary to support reliable planning, interconnection, commissioning, operations, 6 and post-event analysis.Read this passage
A. The proposed data requirements are intended to ensure that MISO has sufficient
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Transmission Customers must provide basic facility information, one-line diagrams, 22 Tab C Page 25 and information describing the electrical characteristics of the Large Load and associated 1 Large Load Equipment. 2 The requirements also establish an ongoing obligation to provide timely updates…Read this passage
A. The proposed modeling requirements are intended to ensure that MISO has accurate and
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Transmission Customers must provide verified electrical models and 14 detailed load profiles with enough information for MISO to evaluate system performance 15 under normal and contingency conditions. 16 Before service begins, the Transmission Customer must submit final verified models 17…Read this passage
A. Large Loads can change system conditions rapidly, and unlike traditional demand, their
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Large Loads can change system conditions rapidly, and unlike traditional demand, their 4 behavior cannot be forecasted accurately using historical load patterns, even when modeled 5 with weather and calendar data in MISO’s short-term forecasting system. 6 Q.Read this passage
A. The proposed short and medium-term forecasting requirements are intended to provide
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Transmission 10 Customers must provide Day-Ahead and Real-Time Load Forecasts directly to MISO to 11 support the Reliability Assessment Commitment, Security Constrained Economic 12 Dispatch, and other reliability studies.Read this passage
A. The objective of the proposed Telemetry and PMU requirements is to provide MISO with
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The objective of the proposed Telemetry and PMU requirements is to provide MISO with 1 the real-time visibility and high-resolution measurement capabilities necessary to reliably 2 integrate Large Loads.Read this passage
A. The telemetry requirements are intended to provide MISO with reliable, real-time visibility
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The Transmission Customer must provide real-time telemetry 8 through an approved communication path using Inter-Control Center Communications 9 Protocol (“ICCP”), maintain commercially reasonable levels of data availability and 10 accuracy, and promptly correct data or modeling issues.Read this passage
A. Yes. The PMU requirements apply specifically to Computational Loads and are intended
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Prior to the applicable Service Commencement Date, 8 phasor measurement recording and communications equipment must be installed on the 9 Transmission Owner’s side of the Point of Withdrawal and become part of the 10 Transmission Owner’s interconnection facilities. 11 The proposal also provides…Read this passage
A. Yes. For Computational Loads subject to the phasor measurement requirements, the
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For Computational Loads subject to the phasor measurement requirements, the 19 proposal provides guidance regarding both the location of the measurement capability and 20 the entity responsible for its installation. 21 The phasor measurement capability is generally required on the Transmission…Read this passage
A. The reliability objective of ramp requirements is to manage the operational impacts that
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The reliability objective of ramp requirements is to manage the operational impacts that 18 can result when a Computational Load increases or decreases its demand rapidly during 19 stable-state transitions. 20 Computational Loads may have the capability to change significant amounts of demand 21…Read this passage
A. The proposed ramp requirements are intended to ensure that changes in Computational
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The proposed ramp requirements are intended to ensure that changes in Computational 10 Load demand occur at a rate that can be reliably accommodated by the Transmission 11 System.Read this passage
A. The proposed ride-through requirements reduce the risk of unnecessary Computational
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The proposed ride-through requirements reduce the risk of unnecessary Computational 4 Load disconnection or rapid changes in Demand during voltage and frequency disturbances 5 and to support predictable disturbance performance during credible Transmission System 6 events.Read this passage
A. The proposed ride-through requirements apply at the applicable Point(s) of Withdrawal
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The proposed ride-through requirements apply at the applicable Point(s) of Withdrawal 3 and establish the voltage and frequency conditions under which Computational Loads are 4 required to remain connected to the Transmission System and continue operation.Read this passage
V. STAKEHOLDER ENGAGEMENT AND EFFECTIVE DATE
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PLEASE DESCRIBE HOW THE STAKEHOLDER PROCESS INFORMED 13 MISO’S IRR PROPOSAL. 14Read this passage
A. MISO has engaged in detailed discussions with stakeholders on Large Load issues since
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Specifically, MISO will require real-time SCADA 18 telemetry from large loads via ICCP to support real-time monitoring and analysis, and real- 19 time SCADA telemetry from generation behind same POI as Large Load will also be 20 required for real-time monitoring and optimal market dispatch;…Read this passage
A. MISO has requested a proposed effective date of December 4, 2026. This is the day after
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MISO has requested a proposed effective date of December 4, 2026.Read this passage
VI. CONCLUSION
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VI.Read this passage
CONCLUSION
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CONCLUSION 6 Q.Read this passage
A. Yes.
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Yes. 8 Affidavit of Beibei Li COUNTY OF HAMILTON ) ) STATE OF INDIANA ) Beibei Li, being duly sworn, deposes and states that she prepared the Prepared Direct Testimony of Beibei Li, and the statements contained therein are true and correct to the best of her knowledge and belief. ae) Beibei Li…Read this passage
Attachment A – Table of Stakeholder Meetings and Materials
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Attachment A – Table of Stakeholder Meetings and Materials MEETING DATE MATERIALS January 30, 2026 Large Load Workshop Large Load Additions Workshop February 25, 2026 PAC Large Load Interconnection Reliability Requirements (PAC-2024-1) April 20, 2026 LLWG Large Load Overview New Large Load Issue…Read this passage