ER26-3650-000 · 2026-10-13 · Midcontinent Independent System Operator Inc.

Motion for Leave to Answer and Answer of Midcontinent Independent System Operator Inc. to the Comments and Protests re the proposal to establish Interconnection Reliability Requirements for Large Loads

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Topics in the text: Registry access · Cost allocation

Responses and related views

Municipal utilities seek a clear limit on regulated loads

Midwest Transmission Dependent Utilities · Direct response

The utilities said MISO’s answer disclaimed applying the rules to distribution-connected loads but the tariff still did not say so unambiguously. They wanted the tariff to explain how a utility could assign a compliance task to the large load.

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Source sections

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Opening text

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Several parties expressly support the proposal or its core reliability framework, while other parties seek clarification or additional detail regarding implementation.7 Notably, only one protest requests the revisions to be rejected and MISO directed to file revised requirements by the end of…
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I. BACKGROUND

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I.
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BACKGROUND

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BACKGROUND The IRR Proposal is an important near-term component of MISO’s broader response to rapidly accelerating Large Load development.
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II. MOTION FOR LEAVE TO FILE ANSWER

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MISO therefore respectfully requests waiver of Rule 213(a)(2) and acceptance of this Answer.
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III. ANSWER

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III.
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A. MISO’S LARGE LOAD AND COMPUTATIONAL LOAD DEFINITIONS ARE JUST AND

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Within MISO’s 50 MW Large Load applicability threshold, a 25 MW computational component provides an objective quantitative indicator that the facility contains material computational content and is therefore 44 Proposed Tariff § 37A.I; IRR Proposal at 11-12, 22-26. 45 IRR Proposal at 11-12; Li…
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B. THE TRANSITION PROVISIONS REASONABLY PROTECTS EXISTING COMMERCIAL

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The process for making that determination and identifying which requirements must apply will be set forth in the Large Load BPM.71 This targeted reliability backstop preserves commercial certainty while allowing MISO to apply otherwise-exempt requirements where the Tariff’s reliability criterion is…
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C. THE IRR PROPOSAL PROPERLY PLACES CORE REQUIREMENTS IN THE TARIFF

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Because Large Loads rely on fast-acting controls, power-electronic interfaces, and increasingly sophisticated uninterruptible power supply systems, the detailed technical parameters that govern telemetry, PMU configuration, forecasting formats, ride-through curves, testing protocols, and ramp-rate…
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D. MISCELLANEOUS COMMENTS AND PROTESTS.

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MISO must be able to obtain, through the Transmission Customer, all information and operational access necessary to evaluate, monitor, and verify Large Load behavior under Section 37A, including the facility data, electrical models, telemetry, PMU measurements, and forecasting inputs required to…
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E. CONCLUDING ARGUMENTS

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CONCLUDING ARGUMENTS The IRR Proposal should be accepted as filed.
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IV. NOTICE AND SERVICE

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NOTICE AND SERVICE MISO has served a copy of this filing electronically, including attachments, upon each person designated on the official service list compiled by the Secretary as well as on all Tariff customers, MISO Members, Member representatives of transmission owners and non- transmission…
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V. CONCLUSION

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V.
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CONCLUSION

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CONCLUSION MISO respectfully requests that the Commission (i) accept this Answer and (ii) accept the IRR Proposal without modification or condition.
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CERTIFICATE OF SERVICE

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Dated this 13th day of October 2026, in Carmel, Indiana. /s/ Julie Bunn Julie Bunn Midcontinent Independent System Operator, Inc. 720 City Center Drive Carmel, IN 46032 317-249-5400
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