EL26-70-000 · 2026-07-28 · Wabash Valley Power Association, Inc.

Motion of Wabash Valley Power Association, Inc. for Request for Issuance of an Errata of the 06/18/2026 Order Instituting Proceedings Under Section 206 of the Federal Power Act

7607303 
UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
Midcontinent Independent System Operator, Inc. 
 
AEP Indiana Michigan Transmission Company, Inc. 
ALLETE, Inc. 
Ameren Illinois Company 
Ameren Transmission Company of Illinois 
American Transmission Company, LLC 
Cleco Power LLC 
Duke Energy Indiana, LLC 
Entergy Arkansas, LLC 
Entergy Louisiana, LLC 
Entergy Mississippi, LLC 
Entergy New Orleans, LLC 
Entergy Texas, Inc. 
GridLiance Heartland LLC 
Indianapolis Power & Light Company 
International Transmission Company 
ITC Midwest LLC 
Michigan Electric Transmission Company, LLC 
MidAmerican Energy Company 
Montana-Dakota Utilities Company 
Northern Indiana Public Service Company LLC 
Northern States Power Company, a Minnesota 
Corporation 
Northern States Power Company, a Wisconsin 
Corporation 
Northwestern Wisconsin Electric Company 
Otter Tail Power Company 
Pioneer Transmission, LLC 
Republic Transmission, LLC 
Southern Indiana Gas & Electric Company 
Union Electric Company 
Wabash Valley Power Association, Inc. 
Wolverine Power Supply Cooperative, Inc. 
 
       Docket No. EL26-70-000

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7607303 
 
WABASH VALLEY POWER ASSOCIATION, INC. 
REQUEST FOR ISSUANCE OF AN ERRATA 
 
 
To the Commission: 
 
On June 18, 2026, the Commission issued its “Order Instituting Proceeding Under 
Section 206 of the Federal Power Act” in this above captioned proceeding.1  In its Order, 
the Commission found that Midcontinent Independent System Operator Inc.’s (“MISO”) 
existing Open Access Transmission, Energy, and Operating Reserve Markets Tariff 
(“Tariff”) appears to be unjust, unreasonable, or unduly discriminatory or preferential and 
thereafter directed MISO and thirty (30) Participating Transmission Owners (“PTOs”) 
within MISO to show cause with respect to a variety of concerns related to large load or 
co-located load transmission and interconnection within sixty (60) days of the date of its 
Order.2 Wabash Valley Power Association, Inc. (“WVPA”) has identified a procedural 
issue with the Order and respectfully requests that the Commission issue an errata as soon 
as practicable. 
Before addressing the procedural issue presented below, WVPA desires to clarify 
that it does not dispute the need for the Commission to address issues surrounding service 
to large load and co-located load within organized markets and elsewhere.  Further, WVPA 
acknowledges the Commission’s existing precedent regarding non-jurisdictional entities 
 
1 Midcontinent Independent System Operator, Inc., et al, 195 FERC ¶ 61,212 (June 18, 2026) (the 
“Order”). 
 
2 Id. at P 3.

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with certain rate schedules within a jurisdictional RTO or ISO.   
The Commission included WVPA as one of the PTOs in the caption of the Order.  
However, at footnote 11 of the Order, the Commission described which PTOs it intended 
to include in the caption and made clear: 
Transmission Owners refers to the entities listed in the caption 
of this order. We recognize that MISO’s transmission owners 
include entities that are not subject to the Commission’s 
jurisdiction because they are not public utilities pursuant to 
section 201(f) of the FPA. See 16 U.S.C. § 824(f); Sw. Power 
Pool, Inc., 180 FERC ¶ 61,022, at PP 44-45 (2022). 
Accordingly, the Commission has not included 1803 Electric 
Cooperative, Inc.; Ames Municipal Electric System; Arkansas 
Electric Cooperative Corporation; Big Rivers Electric 
Corporation; Board of Water, Electric and Communications 
Trustees of the City of Muscatine, Iowa; Central Minnesota 
Municipal Power Agency; Citizens Electric Corporation; City 
of Alexandria, Louisiana; City of Columbia, Missouri, Water 
& Light Department; City of Henderson, Kentucky, Utility 
Commission; City Water, Light and Power - City of 
Springfield, Illinois City Water and Light Plant of the City of 
Jonesboro; 
Cooperative 
Energy; 
Dairyland 
Power 
Cooperative; East Texas Electric Cooperative, Inc.; Great 
River Energy; Hoosier Energy Rural Electric Cooperative, 
Inc.; Indiana Municipal Power Agency; Lafayette City-Parish 
Consolidated Government; Michigan Public Power Agency; 
Michigan South Central Power Agency; Minnesota Municipal 
Power Agency; Missouri Joint Municipal Electric Utility 
Commission; Missouri River Energy Services; Municipal 
Electric Utility of the City of Cedar Falls, Iowa; Municipal 
Energy Agency of Nebraska; Prairie Power, Inc.; Rochester 
Public Utilities; Sam Houston Electric Cooperative, Inc.; 
Southern Illinois Power Cooperative; Southern Minnesota 
Municipal Power Agency; Willmar Municipal Utilities; and 
WPPI Energy here as Transmission Owners that must respond 
to this order to show cause. Nonetheless, the Commission 
retains the authority to review each entity’s formula rates as a 
component of MISO’s Tariff in an order to show cause directed 
towards MISO, and MISO must respond to this order regarding 
the non-public utilities’ MISO Tariff provisions on file with

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the Commission. See Sw. Power Pool, Inc., 180 FERC ¶ 
61,022 at P 40.[3] 
 
 
Like each of the PTO entities listed in footnote 11, WVPA is not a public utility 
pursuant to section 201(f) of the FPA.  In January 2025 WVPA informed the Commission 
that as a result of the termination of one of its members, it ceased to be a public utility on 
January 1, 2025 because it became exempt from the Federal Power Act as a result of being 
wholly owned by exempt entities.  As of January 1, 2025, WVPA has been wholly owned 
by twenty-one electric cooperatives that receive financing under the Rural Electrification 
Act of 1936 or sell less than four (4) million megawatt hours annually and by one additional 
member which is wholly owned by WVPA.  The Commission subsequently acknowledged 
WVPA’s acceptance of its withdrawal of jurisdictional rate schedules based on the change 
in status.4   
 
As of today, WVPA is still wholly owned by electric cooperatives that receive 
financing under the Rural Electrification Act of 1936 or sell less than four (4) million 
megawatt hours annually and by the additional member it wholly owns.  In fact, WVPA is 
itself in the process of receiving financing under the Rural Electrification Act of 1936.  
WVPA is a PTO within MISO, however, it is a PTO that is similarly situated to all of the 
other non-jurisdictional entities listed in footnote 11 of the Order.  WVPA respectfully 
submits that it is unaware of any basis, stated within the Order or any facts external to the 
 
3 Id. at fn. 11. 
4 Wabash Valley Power Ass’n, Inc., Docket No. ER25-838-000, (Feb. 12, 2025) (delegated order); 
Wabash Valley Power Ass’n, Inc., Docket No. ER25-842-000, (Feb. 12, 2025) (delegated order).

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Order, to treat WVPA any different. WVPA believes that the Order inadvertently identified 
it based on its prior status as a public utility. 
 
In addition, WVPA believes the Commission did not intend to include it as a named 
respondent. In the Show Cause Order issued to the California Independent System Operator 
(“CAISO”) and its transmission owners in Docket No. EL26-71-000, non-jurisdictional 
utilities were purposefully included as respondents “because their Transmission Owner 
Tariffs on file with the Commission detail the wholesale load interconnection process in 
CAISO.”5  The Commission explained that “[i]f a non-public utility wishes to be removed 
from this proceeding, we will rescind the show cause order against them at their request, 
and we expect CAISO to respond to this order regarding the non-public utility’s CAISO 
Tariff provisions on file with the Commission.”6  The Commission did not express a similar 
concern with respect to MISO’s non-jurisdictional transmission owners. 
 
As the Commission’s interests are in modifying the terms and conditions of the 
MISO Tariff, an errata to the Order affecting MISO would not impact or diminish the 
Commission’s stated show cause goals.  Further, an errata to the Order would be consistent 
with the Commission’s treatment of a request from a similarly situated non-jurisdictional 
entity in Docket No. EL26-72-000 regarding the Show Cause Order issued to ISO New 
England Inc.7  Based on these facts, WVPA respectfully requests that the Commission 
 
5 Cal. Indep. Sys. Op, Inc., et al, 195 FERC ¶ 61,214 at fn. 9 (2026) (“CAISO Order”). 
6 Id., citing Sw. Power Pool, Inc., 180 FERC ¶ 61,022 at P 40 (2022). 
7 ISO New England Inc., 195 FERC ¶ 61,215 (2026), errata notice, FERC Docket No. EL26-72-000 (July 
9, 2026).

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issue an errata to the Order that:  
(1) removes WVPA from the caption of Docket No. EL26-70-000, which intended 
to identify only MISO and jurisdictional PTOs; and 
 
(2) adds WVPA in the list of non-jurisdictional PTO entities in footnote 11. 
 
 
If the Commission determines that the requested corrections exceed the scope of 
an errata, WVPA respectfully requests in the alternative that the Commission rescind the 
Order with respect to WVPA as described in the CAISO Order precedent, as set forth 
above. 
  
 
 
 
 
 
       Respectfully submitted, 
 
  
/s/ Jeremy L. Fetty  
 
 
Jeremy L. Fetty 
L. Robyn Zoccola 
Parr Richey Frandsen Patterson Kruse LLP 
c/o Wabash Valley Power Association 
6702 Intech Boulevard 
Indianapolis, IN 46278 
Telephone: (317) 481-2815 
Email: jfetty@parrlaw.com 
rzoccola@parrlaw.com 
 
Counsel 
for 
Wabash 
Valley 
Power 
Association, Inc. 
 
 
Dated: July 28, 2026

7607303 
CERTIFICATE OF SERVICE 
 
 
I hereby certify that on this 28th day of July 2026, I have served a copy of the 
foregoing document on the official service list compiled by the Office of the Secretary for 
the above-referenced proceeding.  
 
 
 
 
 
 
 
/s/ Jeremy L. Fetty