{"document":{"slug":"report-el26-70-miso","title":"MISO reports on resource adequacy and large-load proposals","issued":"2026-07-20","accession":"20260720-5204","docket":"EL26-70-000","group":"MISO filings","filer":"Midcontinent Independent System Operator, Inc.","kind":"informational report","file":"sources/originals/20260720-5204_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260720-5204","sha256":"bd3f20e9a427bfa913991fb1ea3a2356285ccea734bad275ad7efb9a8a692dbe","pages":14,"tokens":5560,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":378,"text":"Midcontinent Independent \nSystem Operator, Inc. \n317.249.5400 \nwww.misoenergy.org \n720 City Center Drive \nCarmel, IN 46032 \n2985 Ames Crossing Road \nEagan, MN 55121 \n1700 Centerview Drive \nLittle Rock, AR 72211 \n \nChristopher D. Supino \nManaging Senior Corporate Counsel  \nDirect Dial:  317-249-5256 \nE-mail: csupino@misoenergy.org \n \nJuly 20, 2026 \nVIA ELECTRONIC FILING \nThe Honorable Debbie-Anne Reese \nSecretary \nFederal Energy Regulatory Commission \n888 First Street, NE \nWashington, DC  20426 \nRe: \nMidcontinent Independent System Operator, Inc. \n \nInformational Report   \n \nDocket No. EL26-70-000 \n  \nDear Secretary Reese: \nThe Midcontinent Independent System Operator, Inc. (“MISO”), through this filing, \nsubmits this informational report in compliance with the Federal Energy Regulatory Commission’s \n(the “Commission”) Order Instituting Proceeding Under Section 206 of the Federal Power Act \nissued in this proceeding on June 18, 2026 (the “Show Cause Order”).1  MISO respectfully requests \nthat the Commission accept this filing in compliance with the Show Cause Order’s requirements. \nI. \nExecutive Summary \nMISO appreciates the support of the Commission to ensure efficient, cost-effective and \nreliable integration of large loads.  MISO continues to work diligently with the states both \nindividually and through the Organization of MISO States (“OMS”), as well as its member \nutilities, to support resource adequacy for planned load growth in a manner that maintains customer \naffordability, efficiency and regional reliability.  MISO’s current framework is well-suited to meet \nthe needs of traditional load growth, and MISO’s existing processes have enabled us to maintain \nresource adequacy.  The unique nature of certain new large loads and the need to help ensure speed \nto power, however, brings new challenges that require MISO to continue to work with its states \nand broader stakeholder community to develop new tools and processes to ensure resource \nadequacy is maintained going forward.  Conventional load forecasting was designed around \ngradual and geographically-dispersed growth.  The new large loads, which include data center \ndevelopments, reflect a new type of load growth.  A single project may require more load than an \nentire city at one location and desire service within a short period.  This concentrated and \ndiscontinuous load growth requires new processes to most effectively meet this new demand and \nmaintain resource adequacy.  Many of these new large loads are difficult to forecast with a high \n \n1  \nMidcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 (2026) (the “Show Cause Order”)."},{"page":2,"startToken":378,"endToken":940,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 2 \ndegree certainty using traditional forecasting methods, and the flexibility in locational siting does \nnot align well with traditional utility planning.  It is not prudent for load serving entities to build \nlocal transmission, or generation, for speculative loads.  Yet the pace of large load additions and \nearly need-by dates nonetheless require acceleration of transmission planning and generator \ninterconnection processes, even in the face of this uncertainty.  \nWhile MISO’s existing processes have been sufficient to ensure resource adequacy in the \nshort term, the unique operational characteristics of new large loads have prompted MISO to \nconsider new processes within the current regulatory framework and Resource Adequacy \nconstruct.  As discussed below, MISO, the states, and our members have taken a number of steps \nto address resource adequacy in the near term and to plan for resource adequacy needs in the future \ngiven the shifting resource mix and risk profile in the MISO region. \nIn order to meet the unique speed to power needs of these new large loads and provide \nadditional tools that support resource adequacy, MISO is developing two new processes to speed \nthe delivery of energy to large loads.  First, MISO will file its Zero Injection Generator \nInterconnection Agreement (“ZGIA”) by early August.  MISO began working with stakeholders \nin 2025 to develop a new Interconnection service study type—ZG Interconnection Service, an \nassociated study process, and revisions to its pro forma Generator Interconnection Agreement and \nmodifications to its pro forma GIA designed to facilitate faster interconnection of generation \nresources that serve only Load connected to the same substation and will not inject energy further \nonto the Transmission System.  As discussed in more detail below, the ZGIA is not restricted to \nuse only for large loads.  However, the process is particularly responsive to the challenges faced \nby large loads.  The ZGIA will facilitate the accelerated interconnection of generation needed to \nserve a specific nearby load source where broader injection onto the broader Transmission System \nis not needed and system impacts—and corresponding Network Upgrades—can be limited to \nroughly the substation level.  This provides a valuable option for generation to be co-located with \nlarge loads without having enter the Definitive Planning Phase of MISO’s generation \ninterconnection queue or obtain a form of Interconnection Service that is broader and potentially \nmore costly than what is needed.  \nIn addition, at the July 16, 2026 Large Load Working Group MISO initiated stakeholder \ndiscussions to develop a new set of processes for concurrently studying large loads and associated \ngeneration.2  This new framework (provisionally named the “Large Load Parallel Study Process”) \naligns the study processes used to assess the transmission infrastructure needed to meet new large \nloads and new generation in an efficient framework that can be executed on a shorter timeline \nusing shared modelling inputs.  The Large Load Parallel Study Process recognizes the unique \ncommercial realities of these new large loads.  This framework is expected to position MISO’s \nmembers to meet the challenges presented by new large loads on a more immediate timeline.  The \nLarge Load Parallel Study Process will support resource adequacy and further supplement the \nopportunities available for members to effectively facilitate new large spot loads, with speed, and \nsupports resource adequacy while protecting customers from unnecessary investments relating to \n \n2  \nSee \nhttps://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20and%20Load%20Align\nment%20Presentation768740.pdf"},{"page":3,"startToken":940,"endToken":1358,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 3 \nthe uncertainty of spot large load siting.  MISO will work with stakeholders to further develop the \nLarge Load Parallel Study Process and intends to submit a Section 205 filing to the Commission \ncodifying the Large Load Parallel Study Process in the Tariff as part of the suite of solutions \nresponsive to the Commission’s Show Cause Order.   \nII. \nBACKGROUND \nOn June 18, 2026, the Commission issued the Show Cause Order.  The Show Cause Order \ndirected the following compliance requirements:   \n122. Accordingly, we direct MISO to submit in Docket No. EL26-\n70-000, within 30 days of the date of issuance of this order, a \ndetailed informational report on any proposals under consideration \nin its stakeholder process to address the issue of resource adequacy \nto serve new large loads.  We also strongly encourage new proposals \nto the extent necessary to address these concerns.  The informational \nreport must include a detailed schedule of key milestones, such as \nstakeholder or MISO Board votes, that includes the estimated date \non which MISO expects to file any such proposals with the \nCommission.  Additionally, as part of this informational report, we \ndirect MISO to identify any ongoing stakeholder processes that aim \nto increase the pace of adding generating capacity in the MISO \nregion.  The informational report must include a detailed schedule \nof such initiatives, including timing of the stakeholder process and \ndates of any anticipated filings with the Commission.3   \nIII. \nINFORMATIONAL FILING \nTo respond to the Show Cause Order’s requirements, MISO has divided its informational \nreport into three sections.  Sections A and B discuss MISO’s role in promoting Resource Adequacy \nin the MISO Region and the ability of the Transmission System to meet projected large load \ndemands under current Tariff processes and expected generation additions.  Section C discusses \nnew initiatives that MISO is developing with its stakeholders to further buttress resource adequacy \nand accelerate the pace of adding generation to meet the emerging needs of large loads.   \nA. \nThe MISO Region Is Resource Adequate. \n1. \nThe role of the States in ensuring resource adequacy.  \nWithin the MISO region, States are primarily responsible for resource adequacy, which \ninvolves overseeing Load Serving Entities (“LSEs”) and ensuring LSEs plan for and secure enough \npower to meet their customers’ demand.  MISO supports resource adequacy by determining \nPlanning Reserve Margin, administering the Planning Resource Auction and providing data for \nplanning, but it is the responsibility of the States and LSEs to ensure sufficient  capacity is available \n \n3  \nId. at P 122."},{"page":4,"startToken":1358,"endToken":1787,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 4 \nto meet Load and reserve requirements.  MISO’s Resource Adequacy construct complements the \njurisdiction that State commissions and Relevant Electric Retail Rate Authorities (“RERRA”) have \nin determining the necessary level of Resource Adequacy and works in concert with LSEs, as LSEs \nare the entities responsible for providing demand forecasts that help drive the development of local \nand regional requirements by MISO.  Additionally, MISO partners with the Organization of MISO \nStates, Inc. (“OMS”) to conduct a survey (“OMS-MISO Survey”) of resource owners within MISO \nfootprint on an annual basis to assess anticipated generating capacity over a five-year planning \nhorizon.  The OMS-MISO Survey results, along with MISO’s Planning Resource Auction \n(“PRA”) and other forward-looking analyses (e.g., Futures), provide a comprehensive view of \nsystem risks and resource needs, supporting states in their resource adequacy responsibilities and \nmembers in their resource planning.   \n2. \nThe MISO region is expected to experience capacity surpluses in the \nnear term.  \na. \nOMS-MISO Survey \nThe OMS-MISO Survey provides transparency in expectations of future resource adequacy \nplans, among other vehicles.4  Overall, the OMS–MISO Survey provides a five-year view of \nresource adequacy, indicating if expected capacity based on member plans will meet planning \nreserve margins and yield a surplus or deficit. \nThe 2026 OMS-MISO Survey results, published on June 4, 2026, show an adaptive \nresponse to increasing demand through generation additions that sustain near-term resource \nadequacy.5  As provided in the 2026 OMS-MISO Survey results, the MISO region is projected to \nmaintain sufficient capacity to meet demand across the next five years, based upon current load \nforecasts and anticipated load growth.6  MISO examines the survey results in tandem with forecast \ndata submitted by LSEs. The forecast data indicates that Load growth as submitted by LSEs \ncontinues to accelerate, with a Compound Annual Growth Rate (“CAGR”) projected between \n3.1% and 5.1% over five years.7  The study results also indicates that, to support rising demand, \nthe MISO Region needs to maintain the increased pace of capacity additions, noting that timely \ngeneration builds, generator interconnection queue improvements, as well as the Expedited \nResource Adequacy Study (“ERAS”), will help meet this need.8  The study results further confirm \nthat seasonal reliability risk is changing in a way that contributes to shifting hours of reliability \n \n4  \n“OMS” refers to the Organization of MISO States, which encompasses state utility regulators in the MISO \nfootprint.  \n5  \n2026 OMS-MISO Survey Results available at: https://cdn.misoenergy.org/20260604%20OMS-\nMISO%20Survey%20Results%20Workshop%20Presentation761711.pdf \n6  \nId. at 2. \n7  \nId. \n8  \nId."},{"page":5,"startToken":1787,"endToken":2249,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 5 \nrisk and the seasonal distribution of risk.  For example, MISO is seeing a shift in risk away from \nsummer and towards winter as the resource mix evolves.9 \nb. \nMISO’s Regional Resource Assessment \nMISO is confident that the MISO Region will continue to be resource adequate in both the \nnear and longer term.  In addition to the OMS-MISO Survey, MISO had also developed Regional \nResource Assessment (“RRA”) to assess the state of resource adequacy in its footprint in the past.  \nThe RRA10 was one of the periodic studies MISO used to forecast how the mix of electricity-\ngenerating resources in the MISO Region could evolve going forward.  \nWhile the RRA and the OMS-MISO Survey are similar in some ways, there are some key \ndifferences.  The RRA is a 20-year outlook based on publicly announced resource plans and state \nand policy goals, whereas the OMS-MISO Survey is a more near-term (5-year outlook) resource \nadequacy assessment based on member plans and resource addition trends.  Separately but related, \nMISO also develops MISO Futures which typically entails two or more scenarios, with 20-year \noutlook, and is used for transmission planning purposes.   \nB. \nMISO’s Efforts to Support Resource Adequacy \nMISO works diligently to develop, implement, and refine programs to give states and our \nmembers the support needed to ensure resource adequacy in the MISO Region.  MISO’s ongoing \nresource adequacy efforts involve a holistic, stakeholder-driven approach that has culminated in \nnumerous Tariff enhancements, some of which are under development and some of which have \nrecently taken effect.  This filing discusses the subset of those initiatives that specifically address \nthe market reforms to send transparent price signals that provide all parties with the information \nnecessary to make informed decisions in their resource planning efforts.  These initiatives are \ndiscussed in greater detail in the remainder of this section.  MISO anticipates that it will provide \nmore detail on additional initiatives addressing other aspects of the large load integration challenge \nin a forthcoming abeyance request. \n1. \nSeasonal Construct and Reliability Based Demand Curve  \nMISO’s recent shift to a seasonal capacity market with seasonal accredited capacity better \nreflects extreme weather conditions that have become more prevalent.  These weather conditions \naffect both the seasonal peak demand and the available seasonal supply.  In addition, the seasonal \nconstruct better reflects the seasonal planned & forced outage patterns of supply.  The recent \nimplementation of the Reliability Based Demand Curve (“RBDC”) reflects the contributions to \nreliability incremental MWs can add to the system.  The RBDC helps with price signals by \nindicating if the MISO Region has sufficient capacity for the prompt Planning Year.  On the supply \n \n9  \nId. \n10  More information on MISO’s 2024 Regional Resource Assessment can be found here: \nhttps://cdn.misoenergy.org/2024%20RRA%20Report_Final676241.pdf."},{"page":6,"startToken":2249,"endToken":2745,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 6 \nside, resources are being accredited based on availability during all times of need, across all \nseasons (Schedule 53, seasonal accredited capacity resources). \nData from the 2025-2026 PRA confirm the reliability benefits of the RBDC construct.  At \na system level, MISO cleared more capacity beyond the seasonal PRM.  The auction cleared above \nseasonal final reliability target, representing additional reliability value at cost competitive prices.  \nFor all seasons, Subregional RBDCs set the requirement for both subregions.  The efficiency of \nthe RBDC enabled MISO to secure more capacity at a significantly lower price. \n2. \nTransition to the Direct Loss-of-Load Accreditation Methodology \nMISO is currently transitioning to a two-step accreditation approach (the “Direct Loss-of-\nLoad” or “DLOL”-based methodology) that accredits capacity based on marginal contribution to \nreliability during periods of highest system risk (“marginal effective load carrying capability” or \n“marginal ELCC”) on a Resource Class basis.  MISO’s DLOL-based methodology combines both \nprobabilistic and deterministic elements into a single resource accreditation process.  Simply \ndescribed, the DLOL-based methodology takes two steps by first determining the size of the pie, \nand second, divvying up the pie.  The DLOL-based accreditation methodology will provide both \nMISO members and regulators engaged in integrated resource planning the right investment and \nretirement signals to help ensure the availability of resources with the attributes necessary to \nmaintain reliability into the future. \n3. \nExpedited Resource Addition Study \nIn June of 2025, consistent with the Commission’s direction, MISO filed its revised \nExpedited Resource Addition Study (“ERAS”) proposal (“Revised ERAS Proposal”).  As noted \nin its filing, the ERAS proposal was driven by the fact that MISO was facing urgent near-term \nresource adequacy and reliability concerns due to load growth, generation retirement, and delays \nin the interconnection process11 and that it would experience a 4.7 gigawatt (GW) shortfall by 2028 \nif currently planned generation facility retirements were to occur.12   \nIn support of the ERAS proposal MISO asserted that, while it has undertaken reforms to \nimprove queue processing, the current processing presents a barrier to developing generation that \ncan address these near-term needs.  As such, MISO proposed revisions to its Generator \nInterconnection Procedures (“GIP”) and pro forma Generator Interconnection Agreement (“GIA”) \nto establish a ERAS process, which provides for accelerated study of interconnection requests that \nwill address urgent resource adequacy and reliability needs in the near term (i.e., within the next \nfive years).13  Specifically, under the Revised ERAS Proposal, MISO proposed to create a quarterly \n \n11  Ltr. to the Hon. Debbie Ann Reese, Secretary, Docket No. ER25-1674-000, at p. 5 (Mar. 17, 2025). \n12  Id. at 6 (citing NERC’s 2024 Long-Term Reliability Assessment (published December 2024), \nhttps://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_Long%20Term%20Reliability\n%20Assessment_2024.pdf). \n13  Id. at 1.  See MISO, Proposed Tariff, Attach. X (GIP) (175.0.0), §§ 1 (Definitions), 2.1 (Application of Generator \nInterconnection Procedures), 3.3.1 (Initiating an Interconnection Request), 3.4 (OASIS Posting), 3.9 (Expedited"},{"page":7,"startToken":2745,"endToken":3279,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 7 \n“first-come, first-served” serial study process to facilitate the rapid study of interconnection \nrequests for generating resources that are committed to addressing specific, identified resource \nadequacy and/or reliability needs with RERRA verification,14 resulting in an ERAS Generator \nInterconnection Agreement (“EGIA”) within approximately 90 days of study kickoff.  \nThe Commission accepted MISO’s ERAS proposal on July 21, 2025, finding that MISO’s \nproposed Tariff revisions accomplish the purposes of the Commission’s final rules on generator \ninterconnection, including Order Nos. 2003 and 2023, by helping to ensure that interconnection \ncustomers are able to interconnect to the transmission system in a reliable, efficient, transparent, \nand timely manner.15   \nERAS was filed as short term, limited-use, ‘bridge’ process to enable generators needed to \nrespond to specifically identified and urgent resource adequacy and reliability needs, thus giving \nMISO’s broader queue reforms time to take effect.  ERAS has succeeded in its goals.  To date, 40 \nprojects and 19 GWs of generation have completed the accelerated ERAS process and received \nfinal or near-final generator interconnection agreements allowing them to meet these urgent needs.  \nMISO has filled the 50 Load-Serving Entity (“LSE”) slots and 10 Independent Power Producer \n(“IPP”) slots and expects to fill the remaining 8 retail choice spots allowed under the ERAS caps \nprior to the ERAS sunset date.  However, while ERAS has been extremely useful and necessary \nin the short term, MISO acknowledges that it is not permanent and that other new processes or \nenhancements to existing processes must address longer-term needs. \n4. \nImproving Queue Speed \n \nMISO has also made reforms that, taken collectively, enable it to become an industry leader \nin facing the challenges of a swelling interconnection queue while addressing both the current and \nprojected needs of Interconnection Customers and load for a more reliable and efficient \ntransmission system and Tariff processes tailored to meet emerging needs. \nIn January 2017, MISO comprehensively restructured the GIP and instituted a three-phase \nDefinitive Planning Phase (“DPP”) process16 to facilitate a structured study and restudy of \nproposed generation projects (“2017 Queue Reform”).17  The key elements of the novel GIP \n \nResource Addition Study), 5.13 (Transition to ERAS Process), 7.2.1 (Requirements for Demonstrating Site \nControl for Generating Facility), 7.3.1.4 (Interconnection Decision Point I), 7.3.2.3.1 (Additional Analysis \nApplicable to Interconnection Requests in a JTIQ Screening Group), 11.1 (Tender), 11.2 (Negotiation), 11.2.1 \n(Optional negotiation period adjustment for Interconnection Facilities Study), and 11.3 (Execution and Filing); \nid. app. 1 (Interconnection Request for a Generating Facility) (56.0.0); id. app. 6 (GIA) (106.0.0), art. 1 \n(Definitions), 2.3.3, and 2.4 (Termination Costs).   \n14  Transmittal at 4; Filing, Tab C (Testimony of Andrew Witmeier) at 51-52 (Witmeier Testimony). \n15  Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 (2025) at P 31 (“ERAS Order”). \n16  The DPP is the principal part of the GIP where the interconnection study process takes place, as described in \nsection 7 of the GIP. See Tariff, Attach. X, GIP § 7. \n17  See Midcontinent Indep. Sys. Operator, Inc., 158 FERC ¶ 61,003 (“2017 Queue Reform Order”), order on reh’g, \n161 FERC ¶ 61,137 (2017)."},{"page":8,"startToken":3279,"endToken":3827,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 8 \nprocess adopted in 2017 included: sequential System Impact Studies (“SIS”) and Facilities Studies, \na separate financial milestone at the beginning of each DPP phase,18 and two Interconnection \nCustomer Decision Points (“Decision Points”) serving as off-ramps to allow Interconnection \nCustomers with projects that are no longer viable to exit the queue with minimal impacts on other \nprojects.  This multi-phase model proved to be a significant improvement over the prior one-phase \nprocess, and it has been adopted in some other large RTOs.19 \nAfter the implementation of the 2017 Queue Reform, MISO and its stakeholders continued \nto evaluate the effectiveness of the new three-phase DPP process, responding to emerging issues \nand refining the initial design with various improvements, both internally and through FERC \nfilings.  The following additional main improvements to the three-phase DPP process were \nimplemented: (1) reforms to strengthen certain milestone and site control requirements (2019);20 \n(2) reforms to the Option to Build, harm test calculation, and provisional GIA requirements \n(2021);21 (3) reforms to classify fuel type change requests made in the DPP process as a Material \nModification and allow Interconnection Customers to request Surplus Interconnection Service \nearlier in the interconnection study process (2021);22 (4) and an innovative proposal to reduce the \nGIP timeline by offering enhanced flexibility and an optional path for Interconnection Customers \nto execute GIAs in under one year, thereby improving coordination and alignment with MISO’s \ntransmission expansion planning process, and to implement various other enhancements to the \ninterconnection process (2022).23 \nIn 2023, during the pendency of the Order No. 2023 process, MISO embarked on yet \nanother reform to strengthen its withdrawal penalty regime, including through the adoption of an \nAutomatic Withdrawal Penalty, and further refine its site control requirements.  As MISO \nexplained in its filing, the reforms were critical to address the ballooning size of MISO’s generator \ninterconnection queue and winnow out the speculative interconnection requests that so frequently \ndistort price signals and delay cost certainty to the developers of generation.  The Commission \nfound these reforms just and reasonable and accepted them effective January 22, 2024,24 to apply \nstarting from MISO’s DPP-2024 queue cycle.  \nIn addition, MISO worked with its RTO neighbors, PJM Interconnection, LLC (“PJM”) \nand Southwest Power Pool, Inc. (“SPP”), to improve affected system studies procedures and \nrequirements that are contained in MISO’s Joint Operating Agreements (“JOAs”) with these \n \n18  There are currently three financial milestones in the GIP: M2, M3, and M4. M2 marks the beginning of DPP \nPhase I, M3 marks the beginning of DPP Phase II, and M4 marks the beginning of DPP Phase III. \n19  See PJM Interconnection, L.L.C., 181 FERC ¶ 61,162 (2022) (adopting a three-phase interconnection process); \nSouthwest Power Pool, Inc., 167 FERC ¶ 61,275 (2019) (adopting a three-stage interconnection study process). \n20  See Midcontinent Indep. Sys. Operator, Inc., 169 FERC ¶ 61,173 (2019). \n21  See Midcontinent Indep. Sys. Operator, Inc., letter order, Docket No. ER21-2173-000 (Aug. 10, 2021); \nMidcontinent Indep. Sys. Operator, Inc., 176 FERC ¶ 61,122 (2021). \n22  See Midcontinent Indep. Sys. Operator, Inc., 177 FERC ¶ 61,234 (2021). \n23  See Midcontinent Indep. Sys. Operator, Inc., 178 FERC ¶ 61,141 (2022). \n24  Midcontinent Indep. Sys. Operator, Inc., 186 FERC ¶ 61,054, reh’g denied, 187 FERC ¶ 61,031 (2024)."},{"page":9,"startToken":3827,"endToken":4273,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 9 \nentities.25  These reforms have significantly enhanced MISO’s affected system procedures \nresulting in more expeditious processing of Interconnection Requests involving affected system \nstudies with these neighboring RTOs while also allowing Interconnection Customers to move \nforward even where an affected system study is delayed. \nMISO continues to work with its state commissions, stakeholders, and neighbors to \nimprove the efficiency, accuracy, and speed of its interconnection queue through developing \ninnovative solutions.  For example, MISO integrated modeling software Suite of Unified Grid \nAnalyses with Renewables (“SUGAR”), for Phase 1 DPP studies with plans to integrate in Phase \n2 and 3.  SUGAR is designed to perform power flow analyses, identify Network Upgrades, allocate \ncosts using MISO’s Transmission Cost Estimation Guide and Transmission Owner upgrade inputs, \nand validate constraint mitigation.  The SUGAR software leverages powerful circuit simulation \nmethods developed to study billion-transistor electronic systems; this innovation underlies the \nability to expedite some of the more time-consuming aspects of running interconnection studies.  \nIn addition to providing data within MISO’s acceptable tolerances, as benchmarked against current \nsoftware, SUGAR reduced DPP phase 1 cycle time significantly from the status quo as evidenced \nin the DPP 2022, 2023 and 2025 cycles.  The implementation of SUGAR advances MISO’s \nReliability Imperative by continuing to improve processes for new generator interconnections. \n5. \nJoint Targeted Interconnection Queue Study \n \nThe MISO-SPP Joint Targeted Interconnection Queue Study (“JTIQ”) has sped the queue \nup considerably by providing an alternative to the backlogged ordinary affected systems study \nprocess with SPP while providing both more efficient solutions to the needs of multiple cycles of \nInterconnection Customers as well as greater up-front cost certainty regarding potentially \nsignificant affected systems costs to generators entering the Definitive Planning Phase or MISO’s \nERAS processes.  This increased efficiency and cost certainty allows generators to reach GIA \nfaster and develop their projects from a starting point of increased cost certainty.  \nThe JTIQ portfolio directly enables new generation to serve emerging load by proactively \nconstructing the transmission backbone needed for interconnection, rather than waiting for \nincremental upgrades triggered by one project at a time.  By identifying and mitigating cross‑seam \nconstraints in advance, JTIQ provides large, regionally optimized transmission solutions that \nunlock more than 28 GW of new interconnection capability along the MISO‑SPP seam.  Because \nthese upgrades are included upfront in MISO and SPP’s planning and interconnection models \ninclusive of ERAS studies, DPP cycles, and Expedited Project Reviews; projects can interconnect \nfaster and with far greater cost certainty.  \n \nC. \nMISO’s Future Efforts to Bring Resources Online Faster \n1. \nZero Injection Generator Interconnection Agreement – Expected \nFiling Date – July 31, 2026 \n \n25  See Midcontinent Indep. Sys. Operator, Inc., 171 FERC ¶ 61,275 (2020)."},{"page":10,"startToken":4273,"endToken":4756,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 10 \nMISO began working with stakeholders in 2025 to develop a more robust zero injection \ngenerator interconnection agreement (“ZGIA”) to facilitate faster interconnection of generation \nresources that will be co-located with load and will not inject energy further onto the Transmission \nSystem.  The ZGIA provides a limited, structured option to support large load integration through: \n \n• A limited service framework supported by associated generation, \n• Defined interconnection study processes tailored to zero-injection configurations, \nand, \n• Clear allocation of operational and planning responsibilities. \nThis construct enables a pathway for certain large load configurations to achieve speed to \nreliable power while maintaining system reliability.  A table of MISO’s stakeholder meetings and \nlinks to respective materials regarding MISO’s ZGIA proposal is provided in Attachment A hereto.  \nMISO expects to submit the ZGIA proposal to the Commission in a Federal Power Act Section \n205 filing on, or about July 31, 2026. \n2. \nLarge Load Parallel Study Process \nCurrent load and generation study processes are dependent on each other, requiring one to \nbe complete before the next can begin.  Some large load customers are seeking a more integrated, \npredictable experience that reflects the real-world pairing of large loads with the generation needed \nto serve it, without requiring co-location.  MISO is working to address these concerns through the \nproposed Large Load Parallel Study Process.  The Large Load Parallel Study Process will be used \nfor studying load greater than or equal to 250MW and will allow MISO to integrate studies for \nplanned load and generation to increase speed to approval and optimize network upgrades.   \nThrough the proposed Large Load Parallel Study Process, an LSE will submit a proposed \ngeneration and load combination.  The generation and load have separate eligibility requirements \n(e.g., load ≥250 MW, generation nameplate max 150% of identified load need).  The proposed \nLarge Load Parallel Study Process will analyze generation and transmission using the same study \nassumptions applied in Generator Interconnection and MTEP.  Both studies will be run \nconcurrently and in parallel, with the load/transmission model incorporating the planned \ngeneration and planned load and finish at approximately the same time—within 120 days.  The \nproposed process is intended to ensure faster and more transparent interconnection arrangements \nfor large loads, while offering customers speed-to-power, optimized transmission solutions, and \ngreater certainty to support siting, financing, and state coordination.  This solution aligns with the \nspirit of the Commission’s Show Cause Order for interconnection process arrangements to address \nthe speed of adding generation to serve large load.  The outcome of the processes is MTEP \napproval of transmission required to reliably facilitate the withdrawal of the load and injection \nrights for the generation. \nMISO initiated the stakeholder process with a presentation of the Large Load Parallel Study \nProcess at the July 16, 2026, Large Load Working Group and has requested stakeholder feedback \non the proposed process.  MISO will continue stakeholder discussions on the Large Load Parallel"},{"page":11,"startToken":4756,"endToken":5141,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 11 \nStudy Process at the August 27, 2026 LLWG. Ultimately, MISO expects to file the Large Load \nParallel Study Process on or about to the end of September. \nIV. \nCOMMUNICATIONS \nMISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of \nPractice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the \ndesignation of more than two persons for service on behalf of MISO in this proceeding and requests \nall communications related to this filing be directed to: \nChristopher D. Supino \n  Managing Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \n  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 \nV. \nNOTICE AND SERVICE \nMISO has served a copy of this filing electronically upon all parties listed on the \nCommission’s eService list, and upon all Tariff customers, MISO Members, Member \nrepresentatives of Transmission Owners and non-Transmission Owners, as well as all state \ncommissions within the MISO Region and the Organization of MISO States.  The filing has been \nposted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for \nother interested parties in this matter. \nVI. \nCONCLUSION \nFor all of the foregoing reasons, MISO respectfully requests that the Commission accept \nthis filing in compliance with the requirements of the Show Cause Order and grant waiver of any \nCommission regulations the Commission deems applicable to this filing in order for the \nCommission to accept it as proposed.  The MISO region currently is resource adequate and MISO’s \nwork with recent reforms and partnership with OMS, the states and members has provided a firm \nfoundation.  However, with new urgent challenges created by the introduction of new large spot \nloads, additional tools are needed to support this growth and maintain Resource Adequacy going \nforward.  MISO looks forward to bringing new Resource Adequacy tools to LSEs to meet the \nunique challenges associated with the new spot load growth occurring across the footprint.  These \ntools will help support affordability for customers while enabling speed to power in a reliable cost \neffective manner that can meet the new emerging demand."},{"page":12,"startToken":5141,"endToken":5221,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 12 \n \nRespectfully submitted, \n \n/s/ Christopher D. Supino \nChristopher D. Supino \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System   \nOperator, 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 the Midcontinent Independent \nSystem Operator, Inc. \nAttachment"},{"page":13,"startToken":5221,"endToken":5391,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 13 \nATTACHMENT A  \nPlanning Advisory Committee (PAC) and Large Load Working Group (LLWG) \nMEETING DATE \nMATERIALS \nDecember 3, 2025 Planning Subcommittee \n(PSC) \nConsideration of Zero-Injection GIA \nJanuary 21, 2026 PAC \nConsideration of Zero-Injection GIA \nJanuary 30, 2026 Large Load Workshop \n \nLarge Load Additions Workshop \nFebruary 25, 2026 PAC \nMarket Participation and Registration of Co-\nLocated Load and Generation (PAC-2024-4): \nConsideration of Zero-Injection GIA \n \nLarge Load Interconnection Reliability \nRequirements (PAC-2024-1) \n \nApril 20, 2026 LLWG \nLarge Load Overview \n \nConsideration of Zero-Injection GIA \nResource: Adequacy Participation and \nMarkets and Reliable Operations \n \nNew Large Load Issue Submissions \n \nLarge Load Interconnection Reliability \nRequirements (LLWG) \n \n \nApril 22, 2026 PAC \nConsideration of Zero-Injection GIA \n(Interconnection and Planning Draft Tariff \nUpdates): Market Participation and \nRegistration of Co-Located Load and \nGeneration (PAC-2024-4A) \n \nPAC April 2026: PAC: Large Load Definition \n(PAC-2024-1) \nMay 14, 2026 LLWG \nConsideration of Zero-Injection GIA \n(Resource Adequacy, Markets & Reliable \nOperations Draft Tariff): Market Participation \nand Registration of Co-Located Load and \nGeneration (PAC-2024-4B) \n \nLarge Load Interconnection Reliability \nRequirements (LLWG)"},{"page":14,"startToken":5391,"endToken":5560,"text":"The Honorable Debbie-Anne Reese \nJuly 20, 2026 \nPage 14 \nZGIA Q&A \nMay 27, 2026 PAC \nConsideration of Zero-Injection GIA \n(Interconnection and Planning Draft Tariff \nUpdates): Market Participation and \nRegistration of Co-Located Load and \nGeneration (PAC-2024-4A) \n \nLarge Load Definition Update (PAC-2024-1) \n \n Attachment X_ Appendix 19_ZGIA \nInteronnection Agreement_Redlines.docx \n \nJune 10, 2026 LLWG \nConsideration of Zero-Injection GIA: Market \nParticipation and Registration of Co-Located \nLoad and Generation (PAC-2024-4B) \n \nLarge Load Interconnection Reliability \nRequirements (LLWG) \n \nReliability Requirements Technical \nCompendium \nJune 29, 2026 LLWG \nMarket Participation and Registration of Co-\nLocated Load and Generation Marc Keyser \n11:30 Consideration of Zero-Injection GIA \n(PAC-2024-4B) \n \nLarge Load Operational Reliability \nRequirements \n \nLarge Load Reserve Product Enhancements \n(LWLG-2026-2) \nJuly 16, 2026 LLWG \nPosted meeting materials \nUpcoming Meetings: \nJuly 27, 2026 LLWG \nAugust 12, 2026 LLWG \nAugust 27, 2026 LLWG \nSeptember 23, 2026 LLWG \nOctober 8, 2026 LLWG \nOctober 29, 2026 LLWG \nNovember 16, 2026 LLWG \nMeetings primarily will address the non-\nresource adequacy aspects of large load \nintegration and compliance with the Show \nCause Order"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1098,"startToken":0,"endToken":147},{"p":1,"at":1098,"title":"I. Executive Summary","method":"printed heading","endPage":1,"endAt":1102,"startToken":147,"endToken":148},{"p":1,"at":1102,"title":"Executive Summary","method":"printed heading","endPage":3,"endAt":402,"startToken":148,"endToken":1005},{"p":3,"at":402,"title":"II. BACKGROUND","method":"printed heading","endPage":3,"endAt":407,"startToken":1005,"endToken":1006},{"p":3,"at":407,"title":"BACKGROUND","method":"printed heading","endPage":3,"endAt":1552,"startToken":1006,"endToken":1181},{"p":3,"at":1552,"title":"III. INFORMATIONAL FILING","method":"printed heading","endPage":3,"endAt":2145,"startToken":1181,"endToken":1269},{"p":3,"at":2145,"title":"A. The MISO Region Is Resource Adequate.","method":"printed heading","endPage":5,"endAt":1225,"startToken":1269,"endToken":1983},{"p":5,"at":1225,"title":"B. MISO’s Efforts to Support Resource Adequacy","method":"printed heading","endPage":9,"endAt":3014,"startToken":1983,"endToken":4240},{"p":9,"at":3014,"title":"C. MISO’s Future Efforts to Bring Resources Online Faster","method":"printed heading","endPage":11,"endAt":210,"startToken":4240,"endToken":4792},{"p":11,"at":210,"title":"IV. COMMUNICATIONS","method":"printed heading","endPage":11,"endAt":1009,"startToken":4792,"endToken":4907},{"p":11,"at":1009,"title":"V. NOTICE AND SERVICE","method":"printed heading","endPage":11,"endAt":1520,"startToken":4907,"endToken":4983},{"p":11,"at":1520,"title":"VI. CONCLUSION","method":"printed heading","endPage":11,"endAt":1525,"startToken":4983,"endToken":4984},{"p":11,"at":1525,"title":"CONCLUSION","method":"printed heading","endPage":13,"endAt":57,"startToken":4984,"endToken":5230},{"p":13,"at":57,"title":"ATTACHMENT A","method":"printed heading","endPage":14,"endAt":1279,"startToken":5230,"endToken":5560}]}