{"document":{"slug":"motion-el26-70-miso-abeyance","title":"MISO requests more time to answer the June 18 show cause order","issued":"2026-08-03","accession":"20260803-5249","docket":"EL26-70-000","group":"MISO filings","filer":"Midcontinent Independent System Operator Inc.MISO Transmission Owners","kind":"motion for abeyance","file":"sources/originals/20260803-5249_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5249","sha256":"5e7d429cddb597a84a9e9cb546d03fe276df88de49b0587262bbca63cf33075d","pages":16,"tokens":4874,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":446,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nMidcontinent Independent System Operator, Inc., et al. \n \n \n) \n) \n) \n \nDocket No. EL26-70-000 \n \nMOTION OF THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC.  \nAND THE MISO TRANSMISSION OWNERS  \nTO HOLD PROCEEDING IN ABEYANCE AND REQUEST FOR SHORTENED \nCOMMENT PERIOD AND EXPEDITED TREATMENT \n \n \nPursuant to Rules 212 and 20081 of the Federal Energy Regulatory Commission’s (“FERC” \nor “Commission”) Rules of Practice and Procedure, and as invited by the Commission’s June 18, \n2026 “Order Instituting Proceeding under Section 206 of the Federal Power Act,”2 the \nMidcontinent Independent System Operator, Inc. (“MISO”) and the MISO Transmission Owners3 \n \n1  \n18 C.F.R. §§ 385.212, 385.2008 (2026). \n2  \nMidcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212, at P 37 (2026) (“The Commission will consider requests by MISO and/or the \nTransmission Owners to hold, for up to 90 days, all or certain aspects of this [Federal Power Act (“FPA”)] \nsection 206 proceeding in abeyance, including the deadline to respond to this order… to work through the \nstakeholder processes to develop FPA section 205 filings to revise the Tariff to address the issues raised in this \norder.”) (“Show Cause Order” or “SCO”). \n3  \nThe MISO Transmission Owners for this filing include: AEP Indiana Michigan Transmission Company; \nAmeren Services Company, as agent for Union Electric Company d/b/a Ameren Missouri, Ameren Illinois \nCompany d/b/a Ameren Illinois and Ameren Transmission Company of Illinois; American Transmission \nCompany LLC (“ATC”); Big Rivers Electric Corporation; Central Minnesota Municipal Power Agency; \nCitizens Electric Corporation; City Water, Light & Power (Springfield, IL); Cleco Power LLC; Cooperative \nEnergy; Dairyland Power Cooperative; Duke Energy Business Services, LLC for Duke Energy Indiana, LLC; \nEast Texas Electric Cooperative, Inc.; Entergy Arkansas, LLC; Entergy Louisiana, LLC; Entergy Mississippi, \nLLC; Entergy New Orleans, LLC; Entergy Texas, Inc.; Great River Energy; GridLiance Heartland LLC; \nHoosier Energy Rural Electric Cooperative, Inc.; Indiana Municipal Power Agency; Indianapolis Power & Light \nCompany d/b/a AES Indiana; International Transmission Company d/b/a ITCTransmission; ITC Midwest LLC; \nLafayette Utilities System; Michigan Electric Transmission Company, LLC; MidAmerican Energy Company; \nMinnesota Power (and its subsidiary Superior Water, L&P)(ALLETE, Inc.); Missouri River Energy Services; \nMontana-Dakota Utilities Co.; Northern Indiana Public Service Company LLC; Northern States Power \nCompany, a Minnesota corporation, and Northern States Power Company, a Wisconsin corporation, subsidiaries \nof Xcel Energy Inc.; Northwestern Wisconsin Electric Company; Otter Tail Power Company; Prairie Power, \nInc.; Republic Transmission, LLC; Southern Illinois Power Cooperative; Southern Indiana Gas & Electric \nCompany (d/b/a CenterPoint Energy Indiana South); Southern Minnesota Municipal Power Agency; Wabash \nValley Power Association, Inc.; and Wolverine Power Supply Cooperative, Inc."},{"page":2,"startToken":446,"endToken":778,"text":"2 \n(“MISO Transmission Owners”) respectfully submit this Motion to Hold this Proceeding in \nAbeyance for 90 days, up to and including November 16, 2026 (“Motion”).  The Motion is \nnecessary to permit MISO and the MISO Transmission Owners to continue the MISO stakeholder \nprocess to develop and submit FPA section 2054 filings that address the concerns expressed in the \nShow Cause Order.5  The Show Cause Order raises a number of concerns regarding the apparent \nabsence from MISO’s Open Access Transmission, Energy and Operating Reserve Markets Tariff \n(“Tariff”) of provisions specific to the reliable interconnection, operation, and service to large loads \nin the MISO region.  MISO, the MISO Transmission Owners, and the MISO stakeholder \ncommunity have already undertaken significant efforts to promote the efficient integration and \nreliable interconnection of large loads. These efforts address a number of the Commission’s \nconcerns expressed in the Show Cause Order.  While the timeline would remain tight, granting this \nMotion would allow MISO and the MISO Transmission Owners to respond to the remaining \nconcerns in a manner that recognizes the unique characteristics of the MISO region, with additional \ncoordination between MISO, the MISO Transmission Owners, the Organization of MISO States, \nInc. (“OMS”), and the MISO stakeholder community.   \nI. \nEXECUTIVE SUMMARY \nAs MISO and its member utilities have seen, and as the Show Cause Order affirms, the \nMISO region (and much of the country) is experiencing a significant influx of large load additions, \nwhich present both significant opportunities and challenges for the region.  MISO and the MISO \nTransmission Owners appreciate the direction and regional flexibility the Commission provided \n \n4  \n16 U.S.C. § 824d.   \n5  \nATC joins the MISO Transmission Owners and MISO in this motion in part.  ATC intends to file a separate, \nindividual filing pursuant to section 205 of the Federal Power Act that will be responsive to some of the \nCommission’s directives in the Show Cause Order.  ATC will clearly indicate whether it joins the MISO \nTransmission Owners and MISO in each future section 205 filing."},{"page":3,"startToken":778,"endToken":1198,"text":"3 \nin the Show Cause Order to facilitate the timely and reliable addition of large loads to the MISO \ntransmission system without unfair cost shifts.  Developing new tools and processes to \naccommodate the challenges of large load integration has been, and continues to be, a primary goal \nof MISO and the MISO Transmission Owners.   \nPrior to the issuance of the Show Cause Order, MISO, in collaboration with the MISO \nTransmission Owners, OMS, and other stakeholders, identified and implemented multiple \nsolutions to facilitate speed to reliable power.  Two already-implemented solutions are the \nExpedited Resource Addition Study (“ERAS”) process to accelerate generator interconnection for \nnear-term resource adequacy needs, and improving the MISO Transmission Expansion Plan’s \n(“MTEP”) Expedited Project Review (“EPR”) process to enable the quick study and approval of \ntransmission upgrades necessary for the addition of large loads.   \nMISO also created the Large Load Working Group (“LLWG”) in March 2026 to provide a \ndedicated and consolidated stakeholder forum to prioritize and focus efforts to both identify critical \nissues and develop corresponding solutions to integrate large loads reliably and cost effectively.6  \nThe LLWG, like other MISO stakeholder processes, allows for the consideration of issues and \nsolutions developed not only by MISO staff but also by stakeholders.  The stakeholder issue \nsubmission process in the LLWG is an important element for MISO’s development of solutions \nfor effectively serving large loads because, as the Commission is aware,7 stakeholders are well \n \n6  \nThe MISO Steering Committee approved creation of the LLWG in a special meeting on March 16, 2026. \n7  \nSee, e.g., Champion Energy Marketing LLC v. PJM Interconnection, L.L.C., 153 FERC ¶ 61,059 at P 31 (2015) \n(dismissing a complaint against certain cost allocation provisions of PJM Interconnection L.L.C’s (“PJM”) \ntariff, ruling that the complainant “should first raise its concerns and potential resolution through the PJM \nstakeholder process or in the Commission’s ongoing price formation proceeding.” ); CSOLAR IV South LLC v. \nCal.  Indep. Sys. Operator, Corp., 142 FERC ¶ 61,250, at P 45 (2013) (“While we understand the business risk \narticulated by CSOLAR Entities and CalWEA regarding the uncertainty that phased generation projects may \nencounter is a genuine concern, we nevertheless agree with [California Independent System Operator, Corp.] \nthat addressing these issues in the stakeholder process is superior to attempting to resolve them in a contested \nproceeding at the Commission.”); N.Y. Indep. Sys. Operator, Inc., 126 FERC ¶ 61,046, at P 54 (2009) (a \nstakeholder’s proposal submitted in a FERC proceeding “should be presented to and discussed among"},{"page":4,"startToken":1198,"endToken":1573,"text":"4 \nsituated to identify solutions to some of the current challenges for large load integration.  MISO \naffords equal consideration and deliberation in the LLWG to recommended solutions identified by \nall stakeholders.  \nThrough this collaborative stakeholder forum, MISO has developed a prioritized work plan \nto accelerate consideration of the challenges presented by the rapid growth of large load in the \nMISO region.  The Show Cause Order referenced many of the items in the MISO workplan, which \nhelps reinforce those efforts and provides further guidance that will help drive timely solutions.    \nAs part of this work plan, and as described in more detail below, MISO and stakeholders \nhave developed designs and/or draft Tariff language for several additional solutions, including: (1) \nthe Zero Injection Generator Interconnection Agreement (“ZGIA”) and related study process, \nwhich will provide a Tariff-defined process for co-location of generation and load; (2) a new \ndefinition of large load; (3) interconnection reliability requirements to facilitate the reliable \ninterconnection and operation of large loads; (4) a firm step up service to provide a pathway to \nenergize a portion of a large load prior to full interconnection and upgrade completion; and (5) a \nparallel study process for large load and generation resources (i.e., Load Addition and Resource \nStudy process or “LARS”), which was discussed in MISO’s Informational Report on Resource \nAdequacy filed in this docket.8   \n \nstakeholders and filed as a section 205 proposal, not unilaterally presented to the Commission.”); New England \nPower Pool, 107 FERC ¶ 61,135, at P 24 (2004) (“We find persuasive [New England Power Pool] and [ISO \nNew England, Inc.’s (‘ISO-NE’)] argument that NRG’s suggested revisions have not been vetted through the \nstakeholder process and could impact various participants.  NRG should use ISO-NE’s internal stakeholder \nmechanisms, such as one of the standing Technical Committees, to debate and consider the impact of its \nsuggested changes on the energy markets.”); Consolidated Edison Company of New York, Inc., 95 FERC ¶ \n61,216, at 61,719 (2001) (“We strongly encourage market participants to use the stakeholder process, especially \nin this type of situation, i.e., where a market participant seeks to modify market measures that impact all market \nparticipants.”) (emphasis added). \n8  \nLtr. to Secretary Reese re: Informational Report, Docket No. EL26-70-000 (July 20, 2026)."},{"page":5,"startToken":1573,"endToken":1863,"text":"5 \nMISO and the MISO Transmission Owners acknowledge that several issues identified in \nthe Show Cause Order were not in MISO’s original workplan, as the initial workplan reflected the \nmore pressing and needed solutions, and therefore, respectfully request a 90-day abeyance to \nrecalibrate the workplan and work through the stakeholder processes to develop regionally tailored \nFPA section 205 filings to revise the Tariff to address the issues identified in the Show Cause Order.  \nThe current, imminent compliance deadline in the Show Cause Order effectively prohibits the full \ndevelopment and robust consideration of any potential stakeholder solutions to integrating large \nloads.  The requested abeyance will afford stakeholders the necessary time to identify and discuss \ncreative solutions and will then afford MISO and the MISO Transmission Owners the time \nnecessary to formalize any Tariff and business practice revisions necessary to implement such \nsolutions consistent with the guidance provided in the Show Cause Order. \nAs stated above, the guidance from the Commission in the Show Cause Order provides an \nopportunity for MISO and the MISO Transmission Owners to move these new initiatives forward \nquickly with solutions leveraging MISO and the MISO Transmission Owners section 205 filings \nrights.  MISO and the MISO Transmission Owners are committed to bringing FPA section 205 \nsolutions to the Commission as contemplated in the Show Cause Order in a timely, pragmatic, and \nresponsible manner consistent with the needs of the region.  \nII. \nMISO SHOW CAUSE PROCEEDING  \nThe Show Cause Order identifies an unprecedented increase in requests for transmission \nservice to serve large load, as well as the growing interest in the co-location of loads with \ngeneration facilities (i.e., co-location arrangements), while acknowledging the challenges \nassociated with providing the transmission service to reliably serve the ongoing influx of large"},{"page":6,"startToken":1863,"endToken":2141,"text":"6 \nloads.9  The Show Cause Order states that there is a lack of clarity and consistency in Regional \nTransmission Organization or Independent System Operators’ tariffs regarding the rates, terms, \nand conditions of service that apply to flexible large loads, co-location arrangements, load with \nbehind the meter generation, and generating facilities with electrically proximate large load or co-\nlocated load.10  Ultimately, the Show Cause Order directs MISO and the MISO Transmission \nOwners to: \n(1) show cause as to why the Tariff remains just and reasonable and not \nunduly discriminatory or preferential without provisions addressing: \n \n(a) the application process, study procedures, and ongoing \noperational requirements that apply to Eligible Customers seeking \ntransmission service on behalf of large loads; \n \n(b) additional transparency concerning the Network Upgrade costs \nto provide transmission service to Eligible Customers on behalf of \nlarge loads, a pro forma cost recovery agreement between MISO, \nthe relevant transmission owner, and Eligible Customer taking \ntransmission service on behalf of the large load to mitigate the risk \nof cost shifting among transmission customers, and a mechanism to \nensure such payments are appropriately credited toward \ntransmission owners’ transmission revenue requirements consistent \nwith the Commission's cost-of-service regulations; \n \n(c) the rates, terms, and conditions of service that apply to co-\nlocation arrangements; \n \n(d) transmission services that reflect Eligible Customers taking \ntransmission service on behalf of co-located loads, load with \nbehind the meter generation, and flexible large loads that are \nwilling and able to limit their use of the transmission system under \ncertain conditions; and \n \n(e) the rates, terms, and conditions of service applicable to \ninterconnection customers serving electrically proximate large load \nor co-located load; or \n \n \n9  \nSCO at P 1.  \n10  Id."},{"page":7,"startToken":2141,"endToken":2447,"text":"7 \n(2) explain what changes to the Tariff would remedy the identified concerns \nif the Commission were to determine that the Tariff has in fact become \nunjust and unreasonable or unduly discriminatory or preferential and, \ntherefore, proceeds to establish a replacement Tariff.11 \n   \n \nThe Commission ordered that MISO and the MISO Transmission Owners address these \nissues in a filing due within 60 days; however, the Commission stated that it would consider \nrequests from MISO and the MISO Transmission Owners to hold the proceeding in abeyance, for \nup to 90 days, to provide MISO and the MISO Transmission Owners time while they work through \nthe stakeholder processes to develop FPA section 205 filings to revise the Tariff to address the \nissues raised in the Show Cause Order.12    \nIII. \nREQUEST FOR ABEYANCE \nThe Show Cause Order demonstrates the high priority the Commission has placed on \nensuring that jurisdictional regional grid operators work quickly to meet the challenge of \nintegrating large loads to support the artificial intelligence and manufacturing related national \nsecurity and economic opportunity goals.  Notwithstanding the need for speed, the Commission \ninvited MISO and the MISO Transmission Owners to seek to hold the show cause proceeding in \nabeyance, for up to 90 days, to provide MISO and the MISO Transmission Owners time while they \nwork through the stakeholder process to develop FPA section 205 filings to revise the Tariff to \naddress the issues raised in the Show Cause Order.13  MISO and the MISO Transmission Owners \nagree that an aggressive timeline is needed to address these issues, and that the breadth and \ncomplexity of the concerns raised in the Show Cause Order will require a more expedited \nstakeholder process and feedback loop than is typical before filing solutions with the Commission.  \n \n11  Id. at P 3.  \n12  Id. at P 37. \n13  Id. at P 37."},{"page":8,"startToken":2447,"endToken":2763,"text":"8 \nMISO and the MISO Transmission Owners are committed to undertaking that process in good \nfaith with the expectation that the Commission will be presented with a comprehensive set of \nsection 205 filings addressing the issues identified in the Show Cause Order.   \nMISO and the MISO Transmission Owners appreciate the important role that states play in \nthe MISO region, especially in managing the ultimate retail costs to customers and affordability.  \nIt is also because of the MISO states’ continued focus on resource adequacy that the MISO region \nis not facing an immediate crisis related to large load integration as has been experienced in other \nparts of the nation.  MISO and the MISO Transmission Owners are committed to continued \ncollaboration with the states as solutions are finalized and brought before the Commission. \nGiven the volume of work to be accomplished and the need to engage stakeholders, MISO \nand the MISO Transmission Owners respectfully request that the Commission grant a 90-day \nabeyance to allow MISO and the MISO Transmission Owners to bring regionally tailored solutions \nto the Commission to address the issues identified in the Show Cause Order.   The abeyance will \nallow MISO and the MISO Transmission Owners the opportunity to leverage the LLWG further \nto collaborate with the states and stakeholders to develop robust, durable solutions to meet the \nneeds in the MISO region.  Importantly, MISO is not starting from scratch—the current MISO \nstakeholder process has already developed several prioritized proposals to address large load \nintegration, as further described below.  MISO and the MISO Transmission Owners are confident \nthat the abeyance approach will provide the most successful path forward to achieve the \nCommission’s desired outcomes to ensure the integration of large loads in an efficient, reliable, \nand affordable manner. \nAlthough MISO, the MISO Transmission Owners, the OMS, and stakeholders have been \nworking on several speed to power initiatives, the 90-day abeyance requested herein is essential to"},{"page":9,"startToken":2763,"endToken":3057,"text":"9 \npermit MISO and the MISO Transmission Owners, in collaboration with member states and other \nstakeholders, to adjust planned solutions to fully address the Commission’s directions and, where \nnecessary, to develop additional Tariff revisions responsive to the Show Cause Order. The \nchallenges and opportunities presented by large loads are multi-faceted and implicate numerous \nparts of MISO’s Tariff.  Therefore, while speed is important, it also is critical to ensure that \nindividual solutions align properly with each other and with existing MISO procedures.  This is a \ncomplex task. \nGood cause exists to hold the show cause proceeding in abeyance.  MISO has established \na dedicated stakeholder forum to address the issues identified in the Show Cause Order associated \nwith the reliable integration of large loads.  Holding the show cause proceeding in abeyance will \npromote administrative efficiency, allow for more carefully-crafted solutions, and avoid \nunnecessary litigation of matters that would be more appropriately addressed through the ongoing \nMISO stakeholder process.  Ultimately, granting the abeyance will not prejudice any party, as all \nparties will have an opportunity to participate in MISO’s public stakeholder process and intervene \nin future FPA section 205 filings.   \nIV. \nCOMPLIANCE PLAN \n \nA. \nOverview of Compliance Approach and FPA Section 205 Filings \nMISO and the MISO Transmission Owners will address the issues raised in the Show \nCause Order through a series of FPA section 205 filings to be submitted during the abeyance \nperiod.14  Below is a description of the FPA section 205 filings that MISO and the MISO \nTransmission Owners are currently contemplating.  As shown below, some proposals have already \n \n14  As stated above, ATC will clarify in each section 205 filing submitted during the abeyance period whether it \njoins in that filing.  This will be determined as each subsequent section 205 filing is developed."},{"page":10,"startToken":3057,"endToken":3397,"text":"10 \nundergone significant stakeholder vetting and as such, will be filed prior to the end of the 90-day \nabeyance.  Other proposals are still in their infancy and may require the entire 90-day abeyance.     \nFirst, MISO expects to submit tariff changes establishing a new Zero Injection Generator \nInterconnection Agreement (“ZGIA”) and related study process to facilitate faster resource \nadditions when those resources are designated to serve load at the same substation, thereby \naccelerating the addition of generation resources that have little or no impact on the Transmission \nSystem.  With these proposed Tariff changes, the ZGIA will partly address several of the issues \nraised by the Commission related to co-location of generation and large loads by proposing a \npermanent solution for generation resources seeking to interconnect to the Transmission System \nat the same substation as an associated load.15  MISO expects to submit the ZGIA filing by the end \nof August. \n \nSecond, MISO anticipates submitting Tariff changes establishing new large load \nInterconnection Reliability Requirements (“IRR”).  The proposed IRR Tariff changes will establish \noperational requirements for transmission customers serving large loads to ensure visibility and \nreliable operation of the Transmission System.16  Specifically, the IRR filing will include \nrequirements for large loads to provide basic facility data, modeling, telemetry, and forecasting \ninformation.17  In addition, the proposed IRR Tariff changes will provide detail regarding Phasor \nMeasurement Unit (“PMU”) requirements, as well as requirements for ramp and ride-though for \ncertain types of large loads.  \n \n15  See SCO at PP 58, 94, 113, 115, 117 and 118. \n16  See SCO at P 57; id. at P 64 (preliminarily finding that MISO’s Tariff appears to be unjust and unreasonable \nbecause it lacks provisions addressing ongoing operational requirements for transmission customers taking \ntransmission service on behalf of large loads). \n17  See SCO at P 64 (stating that MISO’s Tariff does not require transmission customers to provide MISO hourly \nforecasts, telemetry data, and other data to ensure sufficient visibility or specify requirements for maintaining \ncommunication channels between MISO and the transmission customer on behalf of the large load)."},{"page":11,"startToken":3397,"endToken":3753,"text":"11 \n \nThird, at the July 16, 2026, LLWG meeting, MISO presented and stakeholders accepted a \nformal issue submission and conceptual design for a load addition and resource study (“LARS”) \nprocess.18  LARS will assess the transmission infrastructure needed to meet new large loads and \nnew generation in an efficient process that can be executed on a shorter timeline, further \nsupplementing the opportunities available for members to facilitate new large spot loads \neffectively.  This process is expected to position MISO and its members to ensure resource \nadequacy and protect customers from unnecessary investments relating to the uncertainty of spot \nlarge load siting. \nMore specifically, LARS will analyze generation and transmission using the same study \nassumptions applied in the standard generator interconnection process and MISO’s MTEP.  The \nstudies will be run in parallel, and will finish at approximately the same time—within 120 days—\nwith the load/transmission model incorporating both the planned generation and planned load.19  \nLARS, as currently conceived, will address similar issues to those the Show Cause Order identified \nrelated to interconnection customers serving electrically proximate large load or co-located load.20  \nMISO will continue to develop the LARS process through the LLWG and expects to submit the \nLARS filing by November 16, 2026, or earlier, if feasible. \nFourth, MISO has presented to the LLWG initial concepts to accommodate flexible large \nloads including a firm transmission service step-up option.  A firm step-up option was initially \n \n18  The concepts discussed herein as the LARS process were referred to as the “Generation and Large Load \nAlignment” process at the July 16, 2026, LLWG. \n19  MISO included a description of this Joint Study Process in its Informational Report submitted in this docket on \nJuly 20, 2026. \n20  SCO at P 113 (preliminarily finding that MISO’s Tariff may be unjust and unreasonable because it does not \ncontain provisions that will allow an interconnection customer to seek the generator interconnection service(s) \nthat reflects the operational dynamics of serving either: (1) an electrically proximate large load; or (2) a co-\nlocated load, that has a high peak load (i.e., large co-located loads that are 50 MW or greater))."},{"page":12,"startToken":3753,"endToken":4094,"text":"12 \ndiscussed with stakeholders at the April 20, 2026, LLWG and again at the June 10 and July 16 \nLLWG meetings, including a request for stakeholder feedback on proposed Tariff revisions \npresented at the LLWG on July 16, 2026.  MISO will address stakeholder feedback on the firm \ntransmission service step-up Tariff revisions at the August 2026 LLWG meetings.  MISO expects \nto make a section 205 filing proposing Tariff revisions incorporating the firm service step-up \noption by November 16, 2026, or earlier, if feasible.   \nFifth, at the July 16, 2026, LLWG, MISO presented a formal issue submission and concepts \nfor a non-firm large load service option intended to address the issues the Commission identified \nin the Show Cause Order relating to the unique operational characteristics of large loads that are \nwilling and able to limit their energy withdrawals under certain conditions and the effect on the \nneed for certain Network Upgrades.21  The LLWG voted to accept the issue submission and \ncontinue discussions related to the development of non-firm large load service options.  MISO will \ncontinue to develop these service options through discussions at the August 2026 LLWG meetings. \n \nFinally, MISO and the MISO Transmission Owners are working together22 to develop \nadditional solutions, processes, and services to address the balance of the Commission’s concerns \nidentified in the Show Cause Order.  These include, among other things, (a) the application process, \nstudy procedures (including evaluating alternative transmission technologies), and ongoing \noperational requirements that apply to Eligible Customers seeking transmission service on behalf \nof large loads; and (b) additional transparency concerning the Network Upgrade costs and cost \nshift concerns.23  MISO will present concepts and proposed Tariff revisions to the LLWG for \n \n21  SCO at P 60, see also, SCO at PP 102, 104. \n22  To the extent the Commission’s concerns address the rates, terms and conditions of Transmission Service and \nmay implicate rate design and Transmission Owner revenue requirements, the FPA section 205 filings \naddressing these issues are expected to be joint filings with the MISO Transmission Owners.   \n23  See SCO at P 33."},{"page":13,"startToken":4094,"endToken":4327,"text":"13 \ndiscussion and formal stakeholder feedback requests as they are developed in anticipation of a \nNovember FPA section 205 filing to address any Commission directives not addressed in a prior \nFPA section 205 filing.  \nB. \nProcess and Schedule for Stakeholder Input \n \n \nTo facilitate further stakeholder discussion and formal feedback cycles on proposals to \naddress the Commission’s concerns expressed in the Show Cause Order, MISO has scheduled a \nseries of LLWG meetings during the requested abeyance period.  While the following LLWG dates \nhave been established, MISO is committed to working with stakeholders to address the issues in \nthe Show Cause Order and will call special meetings of the LLWG if necessary.  Currently, the \nLLWG is scheduled to meet six times between the date of this filing and the end of the requested \nabeyance period including:  \nWednesday, August 12, 2026 \nThursday, August 27, 2026  \nWednesday, September 23, 2026  \nThursday, October 8, 2026 \nThursday, October 29, 2026 \nMonday, November 16, 2026 \nA detailed management plan outlining the specific agenda for these meetings is located on MISO’s \nwebsite and will be updated regularly.24  \n \n \n \n24  The following is the July 31, 2026, version of the LLWG management plan:  \nhttps://cdn.misoenergy.org/20260812%20LLWG%20Item%2001d%20Management%20Plan772569.pdf (last \nvisited August 3, 2026).  MISO notes that the LLWG management plan will be revised from time to time and \nupdated versions will be posted on MISO’s website."},{"page":14,"startToken":4327,"endToken":4675,"text":"14 \nV. \nREQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED TREATMENT \nMISO and the MISO Transmission Owners respectfully request that the Commission issue \nan order granting the requested 90-day abeyance on an expedited basis by August 14, 2026.  \nPrompt action on this Motion will provide certainty to MISO and its stakeholders regarding the \nneed to submit a response to the Show Cause Order by August 17, 2026, and avoid the expenditure \nof time and resources on preparing filings that may prove unnecessary.  With such certainty, MISO \nand its stakeholders can confidently spend critical time and resources developing the FPA section \n205 filings discussed herein.    \nTo enable the Commission’s consideration of this Motion on an expedited basis, MISO and \nthe MISO Transmission Owners also request that the Commission establish a 5-day comment \nperiod for this Motion—i.e., by August 10, 2026.  The Commission may shorten or eliminate \nanswer periods altogether for good cause shown.25  Good cause exists to establish a 5-day answer \nperiod and grant expedited treatment of this Motion because the Show Cause Order’s compliance \ndeadline is fast approaching and parties need certainty regarding the compliance timeline.  \nVI. \nCONCLUSION \n \nFor the reasons set forth above, MISO and the MISO Transmission Owners respectfully \nrequest that the Commission: (i) grant this Motion to hold this proceeding in abeyance for a period \nof 90 days starting August 17, 2026, to allow time for MISO and the MISO Transmission Owners, \nwhere applicable, to develop and submit FPA section 205 filings to address the issues identified in \n \n25  See, e.g., Sw. Power Pool, Inc., Notice Granting Motion to Hold Proceeding in Abeyance, Docket No. EL22-65-\n000 (Jan. 31, 2024) (holding show cause proceedings in abeyance pending stakeholder process to resolve show \ncause proceedings via a section 205 filing); PJM Interconnection, L.L.C., 171 FERC ¶ 61,015, at P 34 (2020) \n(holding a paper hearing proceeding in abeyance to allow stakeholder discussions to continue); Midcontinent \nIndep. Sys. Operator, Inc., 161 FERC ¶ 61,057, at P 44 (2017) (same); Sw. Power Pool, Inc., 161 FERC ¶ \n61,062, at P 33 (2017) (same)."},{"page":15,"startToken":4675,"endToken":4813,"text":"15 \nthe Show Cause Order; (ii) establish a 5-day answer period; and (iii) grant expedited consideration \nby issuing an order on this Motion by August 14, 2026. \nRespectfully submitted, \n/s/ Christopher D. Supino \nChristopher D. Supino \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System   Operator, Inc. \n720 City Center Drive  \nCarmel, Indiana 46032  \nTelephone: (317) 249-5400 \ncsupino@misoenergy.org \nmkessler@misoenergy.org \n \nJames C. Holsclaw \nCalfee, Halter & Griswold LLP \n3900 Salesforce Tower \n111 Monument Circle \nIndianapolis, Indiana 46204 \nTelephone: (317) 308-4266 \njholsclaw@calfee.com   \n \nAttorneys for \nMidcontinent Independent System Operator, Inc. \n \n/s/ Wendy N. Reed \n \n \nWendy N. Reed \nMatthew J. Binette \nAnna Fernandez \nWRIGHT & TALISMAN, P.C. \n1200 G Street NW, Suite 600 \nWashington, DC 20005-3898 \n(202) 393-1200  \nreed@wrightlaw.com  \nbinette@wrightlaw.com \nfernandez@wrightlaw.com \n \nAttorneys for  \nthe MISO Transmission Owners"},{"page":16,"startToken":4813,"endToken":4874,"text":"CERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \n \nDated at Carmel, Indiana this 3rd day of August, 2026. \n/s/ Dawn Kaminski \nDawn Kaminski \nMidcontinent Independent \nSystem Operator, Inc.  \n720 City Center Drive \nCarmel, Indiana 46032 \nTelephone:  (317) 249-5400"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":1363,"startToken":0,"endToken":647},{"p":2,"at":1363,"title":"I. EXECUTIVE SUMMARY","method":"printed heading","endPage":2,"endAt":1367,"startToken":647,"endToken":648},{"p":2,"at":1367,"title":"EXECUTIVE SUMMARY","method":"printed heading","endPage":5,"endAt":1560,"startToken":648,"endToken":1805},{"p":5,"at":1560,"title":"II. MISO SHOW CAUSE PROCEEDING","method":"printed heading","endPage":7,"endAt":792,"startToken":1805,"endToken":2268},{"p":7,"at":792,"title":"III. REQUEST FOR ABEYANCE","method":"printed heading","endPage":9,"endAt":1305,"startToken":2268,"endToken":2950},{"p":9,"at":1305,"title":"IV. COMPLIANCE PLAN","method":"printed heading","endPage":9,"endAt":1329,"startToken":2950,"endToken":2953},{"p":9,"at":1329,"title":"A. Overview of Compliance Approach and FPA Section 205 Filings","method":"printed heading","endPage":13,"endAt":221,"startToken":2953,"endToken":4128},{"p":13,"at":221,"title":"B. Process and Schedule for Stakeholder Input","method":"printed heading","endPage":14,"endAt":4,"startToken":4128,"endToken":4328},{"p":14,"at":4,"title":"V. REQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED TREATMENT","method":"printed heading","endPage":14,"endAt":1228,"startToken":4328,"endToken":4515},{"p":14,"at":1228,"title":"VI. CONCLUSION","method":"printed heading","endPage":14,"endAt":1233,"startToken":4515,"endToken":4516},{"p":14,"at":1233,"title":"CONCLUSION","method":"printed heading","endPage":16,"endAt":0,"startToken":4516,"endToken":4813},{"p":16,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":16,"endAt":411,"startToken":4813,"endToken":4874}]}