ER26-3650-000 · 2026-08-28 · Midcontinent Independent System Operator, Inc.
Tab C - Testimony of BeiBei Li.pdf
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Tab C
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Midcontinent Independent
)
Docket No. ER26-___-000
System Operator, Inc.
)
PREPARED DIRECT TESTIMONY OF
BEIBEI LI
SENIOR MANAGER OF STRATEGIC ASSESSMENT
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I.
PROFESSIONAL BACKGROUND AND QUALIFICATIONS
1
Q.
PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND RELATIONSHIP TO
2
THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC.
3
A.
My name is Beibei Li. I am the Senior Manager of Strategic Assessment for the
4
Midcontinent Independent System Operator, Inc. (“MISO”). My business address is 720
5
City Center Drive, Carmel, Indiana 46032.
6
Q.
PLEASE
DESCRIBE
YOUR
EDUCATION
AND
PROFESSIONAL
7
BACKGROUND.
8
A.
I hold Bachelor’s degrees in both Electrical and Computer Engineering and Political
9
Science from Purdue University. I also hold a Master’s Degree in Electrical and Computer
10
Engineering from Purdue University and an Executive MBA from the University of
11
Chicago Booth School of Business. I began my career with MISO in 2008 as an Outage
12
Coordination Engineer before progressing to Operations Engineer, Market Design
13
Advisory, and Manager of Economic and Policy Planning, before assuming my current
14
role of Senior Manager of Strategic Assessment.
15
Q.
PLEASE DESCRIBE YOUR CURRENT ROLE AND JOB RESPONSIBILITIES.
16
A.
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.
HAVE YOU PREVIOUSLY SUBMITTED TESTIMONY IN A REGULATORY
20
PROCEEDING?
21
A.
No.
22
23
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II.
PURPOSE OF TESTIMONY
1
Q.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
2
A.
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.
HOW DOES THE IRR FILING ADDRESS THE CONCERNS RAISED IN THE
5
COMMISSION’S SHOW CAUSE ORDER RELATED TO LARGE LOADS IN THE
6
MISO REGION?
7
A.
As discussed below in greater detail, the IRR proposal defines “Large Load” and is
8
responsive to several of the concerns raised by the Commission in the Order Instituting
9
Proceeding Under Section 206 of the Federal Power Act2 in Docket No. EL26-70-000 by
10
proposing Tariff revisions that are responsive to the concerns raised in the Show Cause
11
Order regarding ongoing operational requirements for Large Loads. More specifically, the
12
IRR proposal includes Tariff revisions to include visibility, ramp rate, and disturbance ride-
13
through requirements applicable to Large Loads, along with transition provisions to
14
minimize disruption to commercial arrangements. The IRR proposal does not introduce
15
new transmission service products, pro forma service agreements, or address potential cost
16
shifting contemplated by the Show Cause Order. 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 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 the Load. Large Load does not include Load
used exclusively for charging an Electric Storage Resource.
2
Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal
Power Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order” or “SCO”).
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addressed in future Federal Power Act Section 205 filings expected to be submitted prior
1
to November 16, 2026.
2
III.
THE RISE OF LARGE LOADS AND
3
RELATED INTERCONNECTION REQUESTS
4
5
Q.
PLEASE DESCRIBE THE EMERGENCE OF LARGE LOADS IN THE MISO
6
REGION.
7
A.
The MISO region is experiencing a significant increase in both the scale and pace of Large
8
Load development. MISO’s 2026 Long-Term Load Forecast3 indicates that the region is
9
experiencing load growth at levels not seen in decades, driven in large part by
10
unprecedented large load activity and accelerating project announcements. Data centers
11
and advanced manufacturing are among the primary drivers of this growth, with some
12
projects seeking to develop on timelines significantly shorter than those traditionally
13
associated with generation and transmission infrastructure. 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.
PLEASE DESCRIBE THE RELIABILITY CONSIDERATIONS NECESSARY TO
17
ACCOMMODATE THE ACCELERATED INTERCONNECTION OF LARGE
18
LOADS IN THE MISO REGION.
19
A.
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. Key reliability considerations include sufficient visibility into Large Load
22
3
See MISO’s 2026 Long-Term Load Forecasting (LTLF) Results Summary (April 13, 2026), available at :
https://cdn.misoenergy.org/20260413%20LTLF%20Workshop%202026%20Long%20Term%20Load%20Forec
ast%20Summary_UPDATED750524.pdf
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characteristics and operating behavior, accurate forecasting and modeling, and
1
requirements that address operational risks such as rapid change in demand, disturbance
2
response, including ride-through capability.
3
Certain Large Load characteristics—including rapid changes in demand, sudden loss of
4
significant load, or dynamic interactions between power-electronic equipment and the
5
Transmission System—may affect system performance during normal operations and
6
contingency conditions. Under certain system conditions, these behaviors may increase
7
operational uncertainty, contribute to system stability concerns, affect post-disturbance
8
recovery, stress transmission facilities, or create additional challenges in maintaining the
9
real-time balance of supply and demand.
10
These considerations do not imply that all large loads create the same reliability risk.
11
Reliability impacts may vary depending on facility type, operating characteristics,
12
electrical design, system strength, and local transmission conditions. Accordingly, MISO’s
13
approach is intended to be scalable and risk-informed to ensure reliability requirements
14
remain proportional to demonstrated system risk.
15
Q.
PLEASE DESCRIBE THE NERC GUIDANCE AND INDUSTRY DIRECTION
16
INFORMING THIS FILING.
17
A.
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. NERC has identified reliability risks associated
20
with the rapid growth and changing characteristics of large loads and has issued
21
whitepapers, incident reviews, a Reliability Guideline, and a Level 3 Alert addressing those
22
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risks.4 Across these efforts, NERC has emphasized the need for improved load data and
1
modeling, real-time telemetry and high-resolution monitoring, more accurate near-term
2
forecasting, information regarding ramping and operating characteristics, and better
3
understanding of how large loads perform during grid disturbances.
4
The industry’s direction is also moving beyond voluntary guidance toward formal
5
reliability requirements. In 2026, NERC initiated Project 2026-02 to develop definitions,
6
registration criteria, and Reliability Standards for computational load integrations.5 On
7
July 16, 2026, the Commission directed NERC to file by December 31, 2026, one or more
8
new or modified Reliability Standards addressing Bulk-Power System reliability risks
9
associated with the integration of computational loads and associated definitions. The
10
Commission also directed NERC to develop revisions to its Rules of Procedure, including
11
registry criteria necessary for the registration of computational load entities, and stated that
12
it expects NERC to submit those proposed revisions by December 31, 2026.6 Consistent
13
with that directive, in August 2026, NERC opened 30-day comment periods on proposed
14
Rules of Procedure revisions establishing registration criteria for computational load
15
4
Essential Action to Industry – Computational Load Modeling, Studies, Instrumentation, Commissioning,
Operations, Protection, and Control, NERC (May 4, 2026), available at
https://www.nerc.com/globalassets/programs/bpsa/alerts/level-3-computational-load-alert.pdf; See Draft large
Load Disturbance Performance, NERC (Dec. 10, 2026), available at https://www.nerc.com/globalassets/who-
we-are/standing-
committees/rstc/llwg/draft_llwg_white_paper_large_load_disturbance_performance_tosubmit.pdf.
5
Project 2026-02 Computational Load, NERC, https://www.nerc.com/standards/reliability-standards-under-
development/2026-02-computational-loads (last visited Aug. 27, 2026).
6
Reliability Standard(s) Pertaining to Computational Load Integration, 196 FERC ¶ 61,031 (July 16, 2026).
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entities and on proposed Reliability Standards CLO-001, CLO-002, and CLO-003 under
1
Project 2026-02, with comments due September 18, 2026.7
2
MISO’s IRR proposal is also consistent with the direction being taken by other ISOs and
3
RTOs. In particular, FERC has accepted Southwest Power Pool’s (“SPP”) High Impact
4
Large Load (“HILL”) framework, which establishes enhanced study and ongoing
5
reliability requirements for qualifying large loads.8 Like MISO’s IRR proposal, SPP’s
6
framework includes requirements addressing load forecasting, real-time telemetry, phasor
7
measurement data, ride-through performance, and limitations on rapid changes in load
8
demand. SPP specifically requires HILLs to provide real-time telemetry, comply with
9
ramp limits, and meet ride-through requirements, and requires PMU or similar high-
10
resolution measurement equipment to support model validation, dynamic performance
11
monitoring, and post-event analysis.
12
MISO’s proposed framework addresses many of these same reliability needs, while
13
tailoring the applicability of individual requirements to the characteristics and risks
14
observed within the MISO footprint. As described more fully below, MISO applies
15
foundational data, modeling, telemetry, forecasting, and audit requirements to all Large
16
Loads, while applying additional PMU, ride-through, and ramp requirements specifically
17
to Computational Loads.
18
7
Proposed Computational Load ROP Revisions, NERC, https://www.nerc.com/who-we-are/rules-of-
procedure/proposed-changes-to-rules-of-procedure (last visited Aug. 27, 2026). See also, Project 2026-02
Computational Loads, NERC, https://www.nerc.com/standards/reliability-standards-under-development/2026-
02-computational-loads (last visited Aug. 27, 2026).
8
The Commission approved SPP’s proposal on January 14, 2026. See Southwest Power Pool, Inc., 194 FERC ¶
61,031 (Jan. 14, 2026).
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Q.
PLEASE DESCRIBE THE RELIABILITY NEEDS DRIVING THIS FILING.
1
A.
MISO is experiencing increasing levels of Large Load development being evaluated
2
through transmission planning, Expedited Project Review (“EPR”), and other
3
interconnection-related processes. 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 expectation necessary to
7
reliably plan and operate the Transmission System.
8
Accordingly, MISO proposes a reliability-based framework for Large Loads that
9
complements existing MISO planning, interconnection, and operational processes. The
10
framework is intended to improve visibility into Large Load characteristics and behavior,
11
support accurate representation of these facilities in planning and operational analyses, and
12
establish scalable and technically justified requirements that reflect demonstrated
13
reliability risks.
14
Q.
HAS MISO TAKEN ANY STEPS TO ADDRESS LARGE LOAD INTEGRATION
15
IN THE PAST?
16
A.
Yes. 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. MISO has also improved its Transmission Expansion Plan’s EPR process to
19
quickly approve transmission upgrades necessary to address urgent needs associated with
20
the addition of large loads. As discussed further below, MISO’s large load initiatives are
21
designed to support reliability at interconnection, speed to reliable power, and reliable
22
system operations as large load additions continue to accelerate across the footprint.
23
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Q.
PLEASE EXPLAIN WHY THESE EXISTING EFFORTS ARE INSUFFICIENT.
1
A.
While these initiatives provide important benefits, they do not fully address the reliability
2
and operational challenges associated with accelerating large load growth. Existing
3
planning reforms primarily focus on generation additions and transmission development
4
timelines. Likewise, broader reliability initiatives were not specifically designed to address
5
the unique characteristics and operational challenges presented by large load and
6
computational load additions. Accordingly, additional Tariff-based solutions are necessary
7
to establish clear reliability expectations, improve operational visibility, and facilitate
8
timely integration of large loads in a manner that is both reliable and non-discriminatory.
9
Q.
HOW
IS
MISO
PROPOSING
TO
ACCELERATE
THE
RELIABLE
10
INTEGRATION OF LARGE LOADS IN THE MISO REGION?
11
A.
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. The objective is to establish scalable, technically justified, and risk-informed
14
expectations that improve visibility into large load behavior, support planning and
15
operational readiness, and preserve reliable operation of the Transmission System and Bulk
16
Electric System. The proposed framework is intended to complement existing MISO
17
planning, interconnection, and operational processes and align, to the extent practical, with
18
emerging NERC guidance and industry practices.
19
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IV.
MISO’S LARGE LOAD INTERCONNECTION RELIABILITY
1
REQUIREMENTS PROPOSAL
2
Q.
PLEASE PROVIDE AN OVERVIEW OF MISO’S PROPOSED RELIABILITY
3
REQUIREMENTS FOR LARGE LOADS.
4
A.
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. In addition to the specific reliability
7
requirements codified in the Tariff, the IRR proposal also provides key transition
8
provisions related to the application of specific requirements that seek to minimize
9
disruption to existing commercial arrangements for Large Loads, including those
10
commercial arrangements that were nearing completion at the time of this filing. The
11
distinct categories of requirements are:
12
1.
Visibility Requirements - Data, Modeling, Telemetry, and Forecasting
13
Requirements: These requirements establish expectations for facility information,
14
electrical models, real-time telemetry, monitoring, short-term and forecasting, and
15
other operational visibility requirements necessary to support planning studies,
16
operational assessments, and accurate representation of Large Load behavior and
17
system impacts.
18
2
Phasor Measurement Unit (PMU) Requirements: In addition to the broader
19
visibility requirements above, the PMU requirements establish enhanced
20
monitoring expectations for Computation Loads through high-resolution, time-
21
synchronized measurements. PMU data provides MISO with greater visibility into
22
facility behavior during system disturbances and rapid operating changes,
23
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supporting model validation, performance verification, disturbance analysis, and
1
identification of potential dynamic interactions with the Transmission System.
2
3.
Ramp Requirements: These requirements
address the rate at which
3
Computational Loads may increase or decrease consumption during stable-state
4
transitions. Managing rapid changes in demand helps reduce real-time supply-
5
demand imbalances, sudden change in transmission power flows, and associated
6
operational impacts, while supporting more reliable system operation. Ramp-rate
7
limits do not apply during fault or disturbance conditions when necessary for
8
equipment protection or to satisfy ride-through performance requirements.
9
4.
Ride-Through
Requirements: These
requirements
establish
minimum
10
disturbance performance expectations during voltage and frequency disturbances
11
to reduce the risk of unnecessary disconnection or customer-initiated rapid
12
reductions in Demand during credible system events.
13
MISO recognizes that the Commission also included a study process that evaluates and
14
manages the unique reliability and operational challenges Large Loads create when
15
receiving Transmission Service in its discussion of ongoing operational requirements in
16
the Show Cause Order. The IRR proposal addresses requirements applicable to Large Load
17
facilities themselves. MISO evaluates and manages unique reliability and operational
18
challenges through studies, including a stability assessment, as part of its MTEP and EPR
19
processes. MISO intends to address enhancements to stability assessment study processes
20
in a future Federal Power Act Section 205 filing. Those future study processes will focus
21
on identifying system-level reliability impacts associated with load additions and
22
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determining whether transmission or other system-level solutions are necessary, as part of
1
a broader set of load addition and transmission service study requirements.
2
A.
DEFINITIONS
3
Q.
PLEASE IDENTIFY THE NEW DEFINITIONS MISO PROPOSES TO
4
IMPLEMENT THROUGH THIS FILING.
5
A.
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.
10
•
Large Load: Load with Demand of 50 MW or more associated with any facility
11
or aggregation of facilities located at a single substation behind one or more Point(s)
12
of Withdrawal from the Transmission System that is owned, operated, or controlled
13
by: (a) a single entity or (b) a group of entities that will coordinate with respect to
14
the profile of the Load. Large Load does not include Load used exclusively for
15
charging an Electric Storage Resource.
16
•
Large Load Equipment: Any of the facilities, devices, or equipment that
17
constitutes a part of a Large Load, or are used to interconnect the Large Loads to
18
the Transmission System.
19
•
Point(s) of Withdrawal: The point where a non-transmission facility used to
20
withdraw Energy from the Transmission System to serve Load connects to the
21
Transmission System.
22
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Q.
HOW DID MISO ARRIVE AT THE PROPOSED DEFINITION OF LARGE
1
LOAD?
2
A.
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. MISO reviewed approaches being developed or used by NERC and other RTOs,
5
including PJM, SPP, and ERCOT. While those approaches vary, they generally recognize
6
that sufficiently large, concentrated load additions warrant additional visibility and
7
reliability consideration.
8
Based on that review, MISO selected a 50 MW threshold as a reasonable and
9
administratively clear starting point, consistent with industry precedent and sufficiently
10
significant to warrant application of MISO’s Large Load requirements. The definition is
11
based on gross load rather than net load so that MISO has visibility into the full electrical
12
demand and characteristics of the facility.
13
Finally, MISO also defined Large Load at the facility or site level rather than solely at an
14
individual point of interconnection. This allows loads under common ownership or
15
coordinated operational control at a single site to be considered together, including where
16
the site is served through multiple points of interconnection.
17
Q.
WHY IS 50 MW A REASONABLE THRESHOLD FOR LARGE LOAD IN THE
18
MISO REGION?
19
A.
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
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A load of this magnitude is sufficiently large that its characteristics and behavior can be
1
relevant to transmission planning and system operations.
2
Importantly, the 50 MW threshold serves as an applicability threshold; it does not mean
3
that every Large Load at or above 50 MW presents the same reliability risk. MISO’s
4
proposed requirements recognize differences in facility characteristics by establishing
5
baseline visibility requirements for Large Loads while applying certain additional
6
performance requirements to Computational Loads where their operating characteristics
7
warrant additional consideration. This approach provides a clear threshold while allowing
8
the requirements to remain proportional to the reliability needs being addressed.
9
Q.
WHY DOES MISO DEFINE “COMPUTATIONAL LOAD”?
10
A.
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. This distinction allows MISO to apply certain incremental
14
requirements—such as ramp, PMU, and ride-through requirements—only where those
15
characteristics warrant additional reliability consideration. Defining Computational Load
16
therefore supports a more targeted and risk-informed approach, rather than applying the
17
same requirements to all Large Loads regardless of facility type or operating behavior.
18
Q.
WHY IS A DEFINITION OF COMPUTATIONAL LOAD NECESSARY FOR THIS
19
FILING?
20
A.
A definition of Computational Load is necessary because certain proposed requirements
21
are intended to apply only to Large Loads with operating characteristics that warrant
22
additional reliability consideration. Computational Loads may exhibit rapid and
23
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coordinated changes in demand, significant power-electronic behavior, and distinct
1
responses to Transmission System disturbances. Defining this subset allows MISO to
2
apply incremental requirements—such as ramp, PMU, and ride-through requirements—in
3
a targeted manner rather than applying them to all Large Loads. As noted above, this
4
supports a scalable and risk-informed approach in which requirements are aligned with the
5
characteristics and reliability risks they are intended to address.
6
Q.
HOW DOES MISO’S PROPOSED DEFINITION OF COMPUTATIONAL LOAD
7
ALIGN WITH NERC’S PROPOSED DEFINITION?
8
A.
MISO’s proposed definition of Computational Load is closely aligned with NERC’s
9
developing definition of computational load. Both approaches identify computational load
10
based on electric demand associated with information technology equipment, such as
11
servers, storage, and networking hardware. This common approach focuses on the
12
underlying electrical equipment and characteristics of the load rather than on a particular
13
industry or customer type.
14
MISO has tailored the applicability of its requirements to the needs of the MISO
15
Transmission System, while NERC is separately developing registration criteria and
16
Reliability Standards to determine which Computational Load Owners and Operators will
17
be subject to mandatory NERC requirements. Accordingly, differences in applicable
18
thresholds or scope do not represent a fundamental difference in the definition of
19
Computational Load; rather, they reflect the different purposes and responsibilities of
20
MISO and NERC.
21
MISO will continue to monitor NERC’s ongoing standards development and seek
22
alignment as those requirements are finalized.
23
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B.
SCOPE AND APPLICABILITY
1
Q.
PLEASE DESCRIBE THE SCOPE OF THIS FILING.
2
A.
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. These requirements are needed to allow
5
MISO to plan for and ensure the reliable operations of Large Loads that may materially
6
affect the Transmission System or Bulk Electric System due to their size, operating
7
behavior, electrical characteristics, or dynamic performance. The filing includes the
8
following principal requirements:
9
•
Definitions and Applicability: Establishes which facilities qualify as Large Loads and
10
Computational Loads and identifies when the requirements apply.
11
•
Data Requirements: Establishes the facility and operational information MISO needs
12
to understand Large Load characteristics and expected behavior.
13
•
Model Requirements: Requires appropriate electrical models so Large Loads can be
14
accurately represented in MISO planning and operational analyses.
15
•
Telemetry Requirements: Provides real-time visibility into Large Load demand and
16
operating conditions to support reliable system operations.
17
•
Forecasting Requirements: Establishes short-term and other forecast information
18
needed to anticipate Large Load demand and operating changes.
19
•
PMU Requirements for Computational Loads: Provides high-resolution, time-
20
synchronized measurements to support disturbance analysis, model validation, and
21
performance verification.
22
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•
Ramp Requirements for Computational Loads: Establishes limits on rapid increases
1
or decreases in demand during stable-state transitions to help manage operational
2
impacts.
3
•
Ride-Through Requirements for Computational Loads: Establishes minimum
4
voltage and frequency disturbance-performance expectations to reduce unnecessary
5
disconnection and sudden load loss.
6
•
Implementation and Transitional Provisions: Establishes compliance timing,
7
responsibilities, and transition mechanisms for existing and developing facilities.
8
Taken together, these provisions address reliability needs at the facility and information
9
levels by establishing clearer expectations for how Large Loads are represented, monitored,
10
forecasted, and expected to perform. MISO intends to address additional enhancements to
11
its study processes in a subsequent filing, including analyses used to identify broader
12
system-level reliability impacts and, where necessary, appropriate system-level solutions.
13
Q.
DOES THE IRR FILING PROPOSE NEW TRANSMISSION PRODUCTS?
14
A.
No. This IRR proposal focuses specifically on reliability requirements applicable to Large
15
Loads in the MISO region. MISO will address new transmission products in a separate
16
Federal Power Act Section 205 filing.
17
Q.
TO WHOM WILL THE PROPOSED REQUIREMENTS APPLY?
18
A.
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 requirements including: Basic Facility Data, Modeling, Telemetry,
22
Forecast Data, and Audit requirements. In addition, the Computational Load component
23
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of a Large Load, as defined in the Tariff, is additionally subject to the Phasor Measurement
1
Unit, Ride-Through, and Ramp requirements.
2
As previously discussed, MISO recognizes that not all Large Loads present the same
3
reliability risks. Accordingly, MISO has limited the application of PMU, Ramp and Ride-
4
Through requirements to the Computational Load component of a Large Load, which
5
reflects the increased operational risk Computational Loads place on the Transmission
6
System. As previously stated, the IRR proposal is intended to provide a scalable and risk-
7
informed framework that may be applied in a manner proportional to demonstrated
8
reliability need, system conditions, and facility characteristics.
9
Q.
WHICH ENTITIES ARE RESPONSIBLE FOR COMPLIANCE WITH THE
10
REQUIREMENTS PROPOSED IN THIS FILING?
11
A.
The IRR proposal establishes that the Transmission Customer taking Transmission Service
12
on behalf of a Large Load is responsible for ensuring compliance with each of the
13
applicable requirements set forth in the new Tariff section 37A. 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
Agreement to receive Transmission Service under Module B of this Tariff.” This term is
18
used in the Module A, Common Tariff Provisions, to include customers receiving
19
Transmission Service under Module B of this Tariff, including any customer receiving
20
HVDC Service.
21
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Q.
WHY IS IT JUST AND REASONABLE TO APPLY THE INTERCONNECTION
1
RELIABILITY REQUIREMENTS TO A TRANSMISSION CUSTOMER TAKING
2
TRANSMISSION SERVICE ON BEHALF OF A LARGE LOAD?
3
A.
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 directly in MISO’s markets or otherwise have
7
contractual privity to MISO. All Large Loads interconnected to the Transmission System,
8
however, will be required to procure Transmission Service through a Transmission
9
Customer pursuant to the Tariff. As a result, the Transmission Customer will be required
10
to enter into a transmission service agreement, which incorporates by reference, the terms
11
of the Tariff, including the requirements proposed herein. As such, applying the
12
requirements established in the IRR proposal to a Transmission Customer taking
13
Transmission Service on behalf of a Large Load establishes a legally enforceable
14
framework though which all reliability requirements imposed on a Large Load may be
15
enforced.
16
C.
TRANSITION PROVISIONS
17
Q.
HOW DOES THE IRR FILING RECOGNIZE EXISTING COMMERCIAL
18
ARRANGEMENTS,
AND
COMMERCIAL
ARRANGEMENTS
NEAR
19
COMPLETION, AS CONTEMPLATED BY THE SHOW CAUSE ORDER?
20
A.
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. The requirements, which I discuss further below,
23
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consider the Service Commencement Date of the Transmission Service to serve a Large
1
Load, whether transmission projects or upgrades associated with the Large Load have been
2
approved by the MISO Board in MTEP 2026, or a prior MTEP, and when transmission
3
projects or upgrades associated with the Large Load has been submitted to the MISO EPR
4
process. The “Service Commencement Date” is the date MISO or an Independent
5
Transmission Company (“ITC”) begins to provide service pursuant to the terms of an
6
executed Service Agreement, or the date MISO or an ITC begins to provide Transmission
7
Service under the MISO Tariff.
8
Q.
WHAT IS THE MTEP / EPR CONDITION?
9
A.
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, in accordance with Attachment FF of the Tariff.
13
Q.
WHAT IS THE SIGNIFICANCE OF LINKING APPROVAL OF TRANSMISSION
14
PROJECTS FOR LARGE LOAD INTERCONNECTIONS TO MTEP 2026, OR A
15
PRIOR MTEP?
16
A.
Under current processes, MISO does not have a Load interconnection process. As such,
17
specific Load additions are not submitted to MISO for individual study in MISO’s planning
18
processes; however, the need for transmission upgrades or related projects to support a new
19
Load can be identified through MISO’s MTEP or EPR processes. Linking the transition
20
provisions discussed below to approvals received in MTEP 2026, or prior, recognizes the
21
existing commercial arrangements and more immediate, non-speculative, nature of the
22
Load additions and associated Transmission System upgrades.
23
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Q.
WHY DO THE PROPOSED TRANSITION PROVISIONS ALLOW FOR
1
SUBMISSIONS OF LOAD OR TRANSMISSION UPGRADES THROUGH EPR
2
ON OR BEFORE JUNE 18, 2026?
3
A.
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. In addition, application of this date in the terms of the transition provision
7
recognizes projects that had been previously submitted to MISO for study in the EPR
8
process on, or prior to, the date of the Show Cause Order without opening a window during
9
which parties could submit speculative EPR or MTEP projects.
10
Q.
PLEASE DESCRIBE THE TRANSITION PROVISIONS PROPOSED IN THIS
11
FILING.
12
A.
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 Large Load that has procured
16
Transmission Service as of the Service Commencement Date. Any modification or series
17
of modifications to a Load that meets the MTEP/EPR Condition, which results in a
18
cumulative increase of 25 MW or more in Transmission Service for such Load and with a
19
Service Commencement Date after December 4, 2026, may subject the additional Load to
20
certain requirements, depending on MTEP / EPR approval date and the Service
21
Commencement Date of the Transmission Service for the additional Load.
22
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Second, MISO proposes that a Large Load, or a portion of a Large Load, that does not have
1
a Service Commencement Date prior to December 4, 2026, but that meets the MTEP/EPR
2
Condition shall be subject to the visibility requirements set forth in Sections 37A.1 through
3
37A.5 and Section 37A.8, and shall be exempt from the ramp and ride-through
4
requirements set forth in Sections 37A.6 through 37A.7.
5
Third, MISO proposes that a Large Load, or a portion of Large Load, that does not have a
6
Service Commencement Date prior to December 4, 2026, and that has not met the
7
MTEP/EPR Condition, but has submitted Load associated with a transmission project to
8
the Transmission Provider for EPR on or after June 19, 2026, but on or before October 31,
9
2026, shall be subject to all requirements set forth in this Section 37A, provided that
10
Transmission Provider may waive the ride-through requirements set forth in Section 37A.6
11
based upon a determination that: a) exemption from such requirements would not have an
12
adverse reliability impact; and, b) compliance with such requirements would result in
13
significant costs.
14
Q.
WHY DOES MISO PROVIDE A POTENTIAL EXEMPTION FROM RIDE-
15
THROUGH REQUIREMENTS FOR PROJECTS SUBMITTED BETWEEN JUNE
16
19, 2026, AND OCTOBER 31, 2026?
17
A.
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 follows the Commission’s June 18, 2026 Show Cause
21
Order, which recognized that Large Loads were at different stages of development and
22
directed that prospective reforms minimize disruption to existing commercial
23
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arrangements and provide reasonable time for arrangements nearing completion. The
1
October 31, 2026, cutoff date establishes a finite transition period, after which prospective
2
projects are expected to account for MISO’s ride-through requirements as part of their
3
development and design.
4
Importantly, the provision does not provide an automatic exemption from ride-through
5
requirements. Rather, it provides a pathway for eligible projects to demonstrate, through
6
the applicable reliability assessment, that operation without full ride-through capability
7
would not result in an adverse reliability impact. Where such a determination cannot be
8
made, appropriate ride-through capability or mitigation would still be required.
9
This approach balances the need to recognize projects that may have made material design,
10
procurement, or commercial commitments before the new requirements were fully
11
established with MISO’s responsibility to maintain reliable operation of the Transmission
12
System.
13
Q.
ARE LARGE LOADS THAT DO NOT MEET THE MTEP/EPR CONDITION
14
EXEMPT?
15
A.
No. 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.
HOW DID MISO DEVELOP THESE TRANSITION PROVISIONS?
18
A.
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. MISO evaluated the reliability objectives of the proposed
21
requirements, presented and discussed potential transition approaches through the MISO
22
stakeholder process, and considered stakeholder feedback regarding project status,
23
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implementation readiness, and the potential economic and other impacts of applying new
1
requirements to existing and late-stage projects. Based on that process, MISO refined the
2
transition framework to provide appropriate treatment for existing and previously approved
3
projects while applying the new requirements prospectively and preserving MISO’s ability
4
to address demonstrated material adverse impacts to Transmission System reliability.
5
D.
LARGE LOAD RELIABILITY REQUIREMENTS
6
Q.
PLEASE SUMMARIZE THE PROPOSED RELIABILITY REQUIREMENTS.
7
A.
The proposed framework consists of the following categories of reliability requirements
8
intended to address planning, operational, disturbance performance, and system stability
9
considerations associated with Large Loads:
10
Requirement Category
General Applicability
Data, Modeling,
Telemetry, and
Forecasting,
Requirements
Generally applicable to all Large Loads to provide MISO
with the information, models, operational visibility, and
forecasts necessary to support transmission planning and
reliable system operations.
Phasor Measurement
Unit (PMU)
Requirements
Applicable to Computational Loads to provide high-
resolution, time-synchronized measurement capability
supporting monitoring, model validation, post-event
analysis, and reliability assessment.
Ramp Requirements
Applicable to Computational Loads. Ramp limits address
up- and down-ramp behavior during stable-state transitions
and are measured in aggregate across the applicable Point(s)
of Withdrawal.
Ride-Through
Requirements
Applicable to Computational Loads. Computational Loads
must remain connected and continue operation during
voltage and frequency disturbances within the performance
criteria established by MISO.
The applicability of individual requirements, implementation details, exemptions, and
11
compliance approaches are discussed below.
12
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1.
Basic Facility Data and Modeling
1
Q.
PLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED
2
DATA AND MODELING REQUIREMENTS.
3
A.
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. As emerging Large Loads increasingly exhibit dynamic operating
7
characteristics and concentrated demand, and utilize sophisticated power-electronic
8
equipment and controls, additional facility information, telemetry, and modeling detail
9
may be necessary to evaluate reliability impacts under both normal and contingency
10
conditions. Data and modeling requirements are intended to support reliable operation of
11
the Transmission System by improving the accuracy of planning assumptions,
12
strengthening operational awareness, supporting disturbance analysis and model
13
validation, and enabling more consistent evaluation of system performance associated with
14
Large Load integration. These requirements provide a framework for obtaining facility
15
information, electrical models, telemetry, monitoring data, and operational visibility
16
necessary to support planning studies, operational assessments, commissioning activities,
17
and reliability evaluations.
18
Q.
PLEASE DESCRIBE THE PROPOSED DATA REQUIREMENTS.
19
A.
The proposed data requirements are intended to ensure that MISO has sufficient
20
information to understand the configuration and electrical characteristics of each Large
21
Load. Transmission Customers must provide basic facility information, one-line diagrams,
22
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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 when the
3
characteristics of the Large Load change. Those updates may include changes in Load
4
MW amounts, firm and non-firm demand, dispatchable Load, power factor, metering,
5
telemetry, breaker configuration, staged load additions, and annual energy. The
6
Transmission Customer must also coordinate with the applicable Transmission Owner in
7
accordance with MISO’s load interconnection guidance and applicable NERC standards.
8
Together, these requirements help ensure that MISO has current and accurate facility
9
information to support planning and reliable operation of the Transmission System.
10
Q.
PLEASE DESCRIBE THE PROPOSED MODELING REQUIREMENTS.
11
A.
The proposed modeling requirements are intended to ensure that MISO has accurate and
12
sufficiently detailed representations of Large Loads for transmission planning and
13
reliability analysis. 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
reflecting the facility’s as-built configuration and actual operating characteristics. The
18
models must also be maintained and updated over time, and material modifications must
19
be submitted to MISO for study and approval before implementation.
20
Together, these requirements help ensure that MISO’s planning and reliability studies are
21
based on current and representative Large Load models.
22
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2.
Load Forecasting Requirements
1
Q.
PLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED
2
LOAD FORECASTING REQUIREMENTS.
3
A.
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.
PLEASE
DESCRIBE
THE
PROPOSED
LOAD
FORECASTING
7
REQUIREMENTS.
8
A.
The proposed short and medium-term forecasting requirements are intended to provide
9
MISO with timely and accurate visibility of expected Large Load demand. 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. The forecasts must be updated to reflect the most
13
current information regarding expected demand.
14
MISO also provided an extended implementation period for these requirements.
15
Compliance is required by the latter of the Large Load’s Service Commencement Date or
16
September 1, 2027, providing Transmission Customers with additional time to establish
17
the forecasting capabilities, data processes, and related procedures necessary to provide
18
reliable day-ahead and real-time Load Forecasts to MISO.
19
3.
Telemetry and PMU Requirements
20
Q.
PLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED
21
TELEMETRY AND PHASOR MEASUREMENT UNIT REQUIREMENTS.
22
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A.
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. Continuous, high-resolution visibility into the behavior of Large
3
Loads is needed because the size, rapid changes in consumption, and dynamic behavior of
4
Large Loads can create or exacerbate reliability risks.
5
Telemetry provides the foundational real-time visibility into Large Load operation. The
6
proposed Telemetry requirements apply to all applicable Large Loads and provide MISO
7
and Transmission Owners with real-time information regarding Large Load electrical
8
conditions and operating behavior through SCADA/ICCP data. This information supports
9
real-time monitoring, balancing of supply and demand, contingency analysis, and
10
identification of abnormal operating conditions.
11
For Computational Loads, the proposed PMU requirements provide additional high-
12
resolution, time-synchronized measurements needed to monitor and verify dynamic
13
performance that may not be adequately captured by conventional telemetry.
14
Computational Loads can exhibit rapid changes in real and reactive power and can respond
15
rapidly to voltage and frequency disturbances, including through partial reductions in
16
consumption or disconnection. PMUs, or comparable high-resolution measurements,
17
enable MISO to: monitor and verify disturbance performance, including ride-through and
18
active-power recovery behavior; characterize rapid changes in consumption and oscillatory
19
behavior; validate and refine models used in reliability studies; and, support post-event
20
analysis.
21
The PMU requirements therefore complement, rather than duplicate, conventional
22
telemetry by providing the measurement resolution necessary to observe and evaluate the
23
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fast dynamic behavior of Computational Loads. Figure 1 illustrates the difference in
1
measurement resolution between conventional SCADA telemetry and PMU data.
2
3
4
Figure 1: Differences between SCADA and PMU
5
Q.
PLEASE DESCRIBE THE PROPOSED TELEMETRY REQUIREMENTS.
6
A.
The telemetry requirements are intended to provide MISO with reliable, real-time visibility
7
into Large Load operations. 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. This also requires individual
11
metering for Large Loads and, where applicable, generation located behind the same Point
12
of Withdrawal so that MISO can accurately distinguish and assess the relevant load and
13
related generation behavior.
14
MISO also provides an extended implementation period for these requirements.
15
Compliance is required by the latter of the Large Load’s Service Commencement Date or
16
September 1, 2027, providing Transmission Customers and Transmission Owners
17
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additional time to establish the necessary metering, ICCP communications, data mappings,
1
and related processes needed to provide reliable and accurate telemetry to MISO.
2
Q.
DOES THE PROPOSAL IDENTIFY SPECIFIC PHASOR MEASUREMENT
3
REQUIREMENTS FOR COMPUTATIONAL LOADS?
4
A.
Yes. The PMU requirements apply specifically to Computational Loads and are intended
5
to provide MISO with high-resolution, time-synchronized visibility into their electrical
6
behavior to support disturbance analysis, model validation, performance verification, and
7
broader reliability assessments. 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 flexibility regarding the equipment used to satisfy the
12
requirement. Existing or newly installed equipment, such as protective relays or digital
13
fault recorders, may be used in place of a stand-alone PMU where they provide equivalent
14
measurement quality, resolution, and time synchronization.
15
Q.
DOES
THE
PROPOSAL
PROVIDE
GUIDANCE
REGARDING
THE
16
INSTALLATION OF PHASOR MEASUREMENT CAPABILITY FOR A LARGE
17
LOAD?
18
A.
Yes. 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 Owner’s side
22
of the Point of Withdrawal so that MISO can obtain high-resolution, time-synchronized
23
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measurements of the facility’s interaction with the Transmission System. The proposal
1
also provides flexibility in how this capability is provided. Existing or newly installed
2
equipment, including protective relays or other recording devices, may be used where they
3
provide measurement capability equivalent to a dedicated PMU.
4
The responsibility for installing and maintaining this capability is assigned to the
5
Transmission Owner, at the expense of the Transmission Customer. This differs from
6
requirements for data, models, forecasts, and other facility information, which rely on
7
information within the knowledge or control of the Transmission Customer. The phasor
8
measurement requirement involves physical monitoring capability located on
9
transmission-side facilities that are owned and maintained by the Transmission Owner.
10
Assigning this responsibility to the Transmission Owner therefore aligns the obligation
11
with the entity that controls the facilities necessary to install, maintain, and integrate the
12
measurement equipment with the applicable communications and monitoring
13
infrastructure.
14
4.
Ramp Requirements
15
Q.
PLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED
16
RAMP REQUIREMENTS.
17
A.
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
over a relatively short period of time and, in some cases, to do so in a highly coordinated
22
manner. Rapid changes of this magnitude can create short-term supply-demand
23
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imbalances, cause sudden changes in transmission power flows, and increase the
1
operational actions needed to maintain reliable system conditions.
2
Establishing reasonable limits on the rate at which a Computational Load may increase or
3
decrease its demand provides an established operating envelope within which the
4
Transmission Provider can maintain generation-load balance and ensure the coincident risk
5
of multiple Computational Loads does not result in broader reliability impacts.
6
7
Figure 2: Ramp Rate Risk Profile
8
Q.
PLEASE DESCRIBE THE PROPOSED RAMP REQUIREMENTS.
9
A.
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. The requirements establish up- and down-ramp limits during stable-state
12
transitions, measured in aggregate across the applicable Points of Withdrawal, while
13
allowing eligible generation or other resources to provide ramp smoothing.
14
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5.
Ride-Through Requirements
1
Q.
PLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED
2
RIDE-THROUGH REQUIREMENTS.
3
A.
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. Computational Loads may include fast-acting power-electronic equipment and
7
controls with dynamic operating behavior, and their response to Transmission System
8
disturbances may materially affect system performance, operational reliability, and post-
9
contingency recovery. Establishing minimum ride-through performance expectations is
10
therefore intended to reduce the risk of significant or simultaneous changes in Demand and
11
support overall system stability and post-disturbance recovery.
12
Consistent with emerging industry practices and NERC guidance, the proposed ride-
13
through requirements address three fundamental aspects of Computational Load
14
performance: continued connection and stable operation during disturbances within the
15
applicable ride-through criteria, appropriate active power response while riding through
16
voltage and frequency disturbances, and active power recovery following disturbance
17
clearance. The technical basis and detailed performance criteria supporting these
18
requirements are described in MISO’s published Large Load Technical Compendium.9
19
9
See MISO’s Interconnection Reliability Requirements for Large Load Technical Compendium, August 2026;
available at:
https://cdn.misoenergy.org/20260827%20LLWG%20Item%2002c%20MISO%20Large%20Load%20Interconn
ection%20Reliability%20Requirements_Technical%20Compendium777982.pdf.
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Q.
PLEASE DESCRIBE THE GENERAL PRINCIPLES UNDERLYING THE
1
PROPOSED RIDE-THROUGH REQUIREMENTS.
2
A.
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. When
5
system conditions remain within the applicable ride-through criteria, Computational Loads
6
are required to remain connected without unnecessary disconnection.
7
The requirements further establish expectations for Computational Load performance
8
while riding through disturbances and following disturbance recovery. During voltage
9
disturbances, the appropriate active power response may vary depending on the severity of
10
the disturbance, with greater flexibility in active power response during more severe
11
voltage depressions to support continued connection and stable operation. Following
12
disturbance clearance, active power is expected to recover in a controlled and predictable
13
manner consistent with Transmission System reliability needs. During frequency
14
disturbances, Computational Loads are expected to maintain predictable active power
15
consumption while riding through the disturbance in accordance with the applicable
16
performance requirements.
17
The proposed Tariff establishes the core ride-through obligation, while the technical basis
18
and detailed performance criteria supporting MISO's proposal are described in MISO's
19
published Large Load Technical Compendium. Detailed implementation, evaluation, and
20
compliance requirements will be established through MISO's applicable Business Practices
21
and address the following:
22
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• Applicability: Applies to Computational Loads subject to MISO’s ride-through
1
requirements.
2
• Stay connected: Requires the facility to remain connected during qualifying voltage
3
and frequency disturbances.
4
• Stable operation: Requires the facility to maintain stable behavior during the
5
disturbance and avoid unnecessary tripping.
6
• Post-disturbance recovery: Requires active power to recover in a controlled manner
7
that supports reliable Transmission System operation.
8
• Demonstration of capability: Requires the Transmission Customer to provide models,
9
studies, equipment information, testing, or other evidence demonstrating compliance.
10
Additional detail can be found in the Large Load Technical Compendium.
11
V.
STAKEHOLDER ENGAGEMENT AND EFFECTIVE DATE
12
Q.
PLEASE DESCRIBE HOW THE STAKEHOLDER PROCESS INFORMED
13
MISO’S IRR PROPOSAL.
14
A.
MISO has engaged in detailed discussions with stakeholders on Large Load issues since
15
2024 in various stakeholder entities and workshops. MISO first discussed Large Loads
16
with stakeholders in the context of EPR process improvements at the Planning Advisory
17
Committee (“PAC”) and Planning Subcommittee (“PSC”) in 2024 and 2025. Moreover,
18
since 2024, MISO has discussed coordinating the MTEP and Definitive Planning Phases
19
(“DPP”) processes to accommodate Large Loads at the PSC. MISO additionally discussed
20
Large Load citing methodology at the November 18, 2025, Futures Redesign Workshop.
21
MISO introduced the Large Load Interconnection Reliability Requirements at the Large
22
Loads Workshop on January 30, 2026. The workshop addressed the challenges associated
23
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with reliably interconnecting large loads, focusing on defining reliability requirements and
1
improving the speed of integration while maintaining reliability to support member plans
2
and goals. Following the January 30th workshop, MISO discussed the Large Load
3
Interconnection Reliability Requirements at the PAC and the Large Load Working Group
4
(“LLWG”).10
5
At the February 25, 2026, PAC, MISO proposed a definition of Large Load and provided
6
a high-level overview of the Large Load Interconnection Reliability Requirements. MISO
7
requested stakeholder feedback on the Large Load definition. At the April 20, 2026,
8
LLWG, MISO provided a revised large load definition based on stakeholder feedback and
9
presented the Large Load Interconnection Reliability Requirements. MISO requested
10
feedback on the Large Load Interconnection Reliability Requirements. At the April 22,
11
2026, PAC, MISO shared the revised Large Load definition that had been shared
12
previously at the LLWG. MISO additionally presented transition provisions it developed
13
to address pending but unbuilt Large Load.
14
At the May 14, 2026, LLWG, MISO responded to stakeholder feedback from the April 20
15
LLWG meeting, provided proposed Tariff language for the Large Load Interconnection
16
Reliability Requirements, and provided an updated Large Load definition. In response to
17
stakeholder feedback MISO revised the applicability language to provide additional clarity,
18
included transitional provisions that offer flexibility during implementation, and
19
incorporated a phased-in implementation to support readiness across customers and
20
utilities. MISO additionally updated its Large Load definition based on stakeholder
21
10 A table listing the stakeholder meetings, including links to the presentations, is provided as Attachment A
hereto.
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feedback. Specifically, in response to stakeholder feedback regarding MISO’s initial
1
proposal allowing multiple Points of Interconnection (“POI”), MISO proposed only
2
allowing multiple POIs if the ZGIA is located at one of the stations, i.e. Points of
3
Withdrawal of a Large Load Campus. MISO requested feedback on the Large Load
4
Interconnection Reliability Requirements Tariff draft. At the May 27, 2026, PAC, MISO
5
presented the updated Large Load definition, including the revisions to applicability and
6
transitional provisions, to ensure clarity on implementation of Interconnection Reliability
7
Requirements.
8
At the June 10, 2026, LLWG, MISO responded to stakeholder feedback and presented the
9
Tariff redlines for the Large Load Interconnection Reliability Requirements based on
10
stakeholder feedback. Stakeholder feedback significantly influenced the revised Tariff
11
language, particularly around applicability, transition provisions, and requirement specific
12
language. Namely, MISO: (1) updated Tariff and BPM language to clarify treatment of
13
existing loads, any expansions, and the applicability date; (2) updated the transitional
14
provision to allow more flexibility; (3) updated the Applicability section to distinguish
15
between Computational and Non-Computational Loads, and applied only ramp, PMU,
16
ride-through, and advanced modeling requirements to Computational Loads; (4) updated
17
the Transmission Customer definition to clearly define roles and responsibilities; (5)
18
expanded process detail across several Tariff sections, including applicability screening,
19
pre-MTEP/EPR timing, and transitional provisions for inflight projects; and (6) clarified
20
that Tariff applicability for the ramp, PMU, and ride-through requirements align with
21
NERC’s emerging definition of Computational Loads and NERC’s Load Modeling Task
22
Force technical discussions. MISO additionally revised the Large Load definition by
23
PDF page 39
Tab C
Page 37
removing the Large Load Campus construct in response to stakeholder feedback. In
1
addition, MISO published a technical compendium outlining the technical details of the
2
proposal that will be included in the Business Practice Manual.
3
At the June 29, 2026, LLWG, MISO reviewed Tariff redlines for the Large Load definition
4
and Large Load Interconnection Reliability Requirements based on stakeholder feedback.
5
Stakeholder feedback significantly influenced the revised Tariff language, specifically
6
around applicability, transition provisions, and requirement specific language. MISO
7
additionally described how its proposed framework is consistent with the Commission’s
8
Show Cause Order and noted that the framework is also in line with the emerging NERC
9
guidance and broader industry practices. Furthermore, MISO described how its
10
interconnection framework relies on the Tariff to set requirements and its BPM to guide
11
consistent implementation, noting that it is targeting Large Load BPM development to take
12
place from June to September 2026. MISO requested stakeholder feedback on the Tariff
13
updates.
14
MISO separately presented on Large Load Telemetry and PMU Requirements, with the
15
purpose of establishing SCADA telemetry requirements for Large Loads, and PMU
16
requirements for Computational Loads to provide situational awareness and support system
17
reliability across the MISO footprint. 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; generator telemetry shall
21
not be netted with load. Furthermore, MISO will require PMU or similar device at the
22
PDF page 40
Tab C
Page 38
Large Load with computational load to support dynamic monitoring in real-time. MISO
1
requested stakeholder feedback on The Large Load Telemetry and PMU Requirements.
2
MISO also presented on Large Load Operation Forecast Requirements, proposing that
3
Large Loads submit short-term forecasts to reliably manage their variability. In particular,
4
MISO proposed Large Load forecast submission at the CP node level, on hourly and 5-
5
minute cadences aligned with commitment and dispatch and defined forecast error
6
measurement and submission monitoring, noting that it is considering mechanisms to
7
incentivize accurate submissions. MISO highlighted that NERC has called for short-term
8
forecast submissions from Large Loads, that SPP requires them today, and that CAISO has
9
identified the same visibility gap. MISO requested stakeholder feedback on this topic.
10
At the July 15, 2026, PAC, MISO informed stakeholders that the Steering Committee
11
approved reassignment of the Large Load definition to the LLWG. At the July 16, 2026,
12
LLWG, MISO noted in its liaison report that there is a transition plan to manage active
13
projects, explaining that a key consideration has been ensuring reliability while avoiding
14
disruption to loads at a late stage of development. MISO noted that this consideration is
15
reflected in the Commission’s Show Cause Order and that it has received stakeholder
16
feedback indicating that its current proposal does not achieve this directive. Therefore,
17
MISO revised its approach to apply full requirements only to loads that MISO has not yet
18
approved through its planning processes, and to apply visibility requirements to a broader
19
set of large loads.
20
MISO also discussed the Large Load BPM framework and development, focusing on
21
changes for interconnection and operational reliability requirements. MISO proposed a
22
“hub-and-spoke” BPM framework consisting of a new Large Load BPM, the “hub,”
23
PDF page 41
Tab C
Page 39
supported by updates to existing BPMs and manuals, the “spokes.” MISO requested
1
stakeholder feedback on the Large Load BPM framework.
2
At the July 27, 2026, LLWG, MISO reviewed Tariff redlines for the Large Load definition
3
and Large Load Interconnection Reliability Requirements based on stakeholder feedback.
4
MISO noted that its BPM development timeline has been extended to December 2026.
5
MISO also provided updates to its Technical Compendium. MISO requested stakeholder
6
feedback on its Tariff updates.
7
At the August 12, 2026, LLWG, MISO reviewed the informal stakeholder feedback on the
8
reliability requirement updates provided at the July 27, 2026, LLWG. MISO discussed the
9
additional refinements it made to its proposal based on informal stakeholder feedback.
10
As described above, throughout the stakeholder engagement period, MSO has solicited
11
feedback from stakeholders and provided written and verbal responses to that feedback.
12
MISO’s stakeholder process has contributed to substantive design changes in MISO’s
13
filing and the collaborative process with stakeholders resulted in a comprehensive proposal
14
for addressing Large Loads in the MISO footprint. MISO appreciates the willingness of
15
all its stakeholders and state regulators to review and comment on this final proposal, which
16
MISO believes reasonably accommodates concerns raised by stakeholders.
17
In addition to the stakeholder meetings, MISO’s external affairs and large load teams have
18
met with individual stakeholders and RERRAs to inform them about MISO’s proposal and
19
answer questions. MISO is aware that this is a pressing topic in the MISO footprint and
20
commits to working with stakeholders and RERRAs to address any questions that may
21
arise.
22
PDF page 42
Tab C
Page 40
Q.
WHAT EFFECTIVE DATE HAS MISO REQUESTED FOR THE LARGE LOAD
1
INTERCONNECTION REFORM PROPOSAL?
2
A.
MISO has requested a proposed effective date of December 4, 2026. This is the day after
3
which the MISO Board is expected to approve the MTEP 2026 projects and aligns with the
4
IRR transition provisions described above.
5
VI.
CONCLUSION
6
Q.
DOES THIS CONCLUDE YOUR TESTIMONY?
7
A.
Yes.
8
PDF page 43
Affidavit of Beibei Li
COUNTY OF HAMILTON
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STATE OF INDIANA
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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.
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Beibei Li
SUBSCRIBED AND SWORN BEFORE ME, this WU day of August, 2026.
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1
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 Submissions
Large Load Interconnection Reliability
Requirements (LLWG)
April 22, 2026 PAC
PAC April 2026: PAC: Large Load Definition
(PAC-2024-1)
May 14, 2026 LLWG
Large Load Interconnection Reliability
Requirements (LLWG)
May 27, 2026 PAC
Large Load Definition Update
June 10, 2026 LLWG
Large Load Interconnection Reliability
Requirements (LLWG)
Interconnection Reliability Requirements
Technical Compendium
June 29, 2026 LLWG
Large Load Interconnection Reliability
Requirements
(LLWG)
Large Load Telemetry and PMU
Requirements
Large Load Operational Forecast
Requirements
Interconnection Reliability
Requirements for Large Load Technical
Compendium
July 15, 2026 PAC
Liaison Report
July 16, 2026 LLWG
Liaison Report
Large Load BPM Development
(LLWG)
July 27, 2026 LLWG
Large Load Interconnection Reliability
Requirements
(LLWG)
PDF page 45
2
August 12, 2026 LLWG
Large Load Interconnection Reliability
Requirements
(LLWG)
August 27, 2026 LLWG
Large Load Interconnection Reliability
Requirements Clean Tariff (LLWG)
Large Load Interconnection Reliability
Requirements Redline Tariff (LLWG)
Large Load Interconnection Reliability
Requirements Redline comparison (LLWG)