{"document":{"slug":"filing-er26-3650-miso-irr-attachment-3","title":"Tab C - Testimony of BeiBei Li.pdf","issued":"2026-08-28","accession":"20260828-5278","docket":"ER26-3650-000","group":"MISO filings","filer":"Midcontinent Independent System Operator, Inc.","kind":"attachment","file":"sources/originals/20260828-5278_04.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260828-5278","parent":"filing-er26-3650-miso-irr","sha256":"642d42621fce69e0a804ef3a455019644f3a09984b8788d0441c27ed72c7a585","pages":45,"tokens":10398,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":2,"text":"Tab C"},{"page":2,"startToken":2,"endToken":34,"text":"Tab C \n \n \n \n \n \n \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \nMidcontinent Independent   \n \n \n) \n \nDocket No. ER26-___-000 \n  System Operator, Inc. \n  \n \n \n) \n \n \n \nPREPARED DIRECT TESTIMONY OF \nBEIBEI LI \nSENIOR MANAGER OF STRATEGIC ASSESSMENT"},{"page":3,"startToken":34,"endToken":259,"text":"Tab C \nPage 1 \n \nI. \nPROFESSIONAL BACKGROUND AND QUALIFICATIONS \n1 \nQ. \nPLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND RELATIONSHIP TO \n2 \nTHE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC.  \n3 \nA. \nMy name is Beibei Li.  I am the Senior Manager of Strategic Assessment for the \n4 \nMidcontinent Independent System Operator, Inc. (“MISO”).  My business address is 720 \n5 \nCity Center Drive, Carmel, Indiana 46032. \n6 \nQ. \nPLEASE \nDESCRIBE \nYOUR \nEDUCATION \nAND \nPROFESSIONAL \n7 \nBACKGROUND. \n8 \nA. \nI hold Bachelor’s degrees in both Electrical and Computer Engineering and Political \n9 \nScience from Purdue University.  I also hold a Master’s Degree in Electrical and Computer \n10 \nEngineering from Purdue University and an Executive MBA from the University of \n11 \nChicago Booth School of Business.  I began my career with MISO in 2008 as an Outage \n12 \nCoordination Engineer before progressing to Operations Engineer, Market Design \n13 \nAdvisory, and Manager of Economic and Policy Planning, before assuming my current \n14 \nrole of Senior Manager of Strategic Assessment.   \n15 \nQ. \nPLEASE DESCRIBE YOUR CURRENT ROLE AND JOB RESPONSIBILITIES. \n16 \nA. \nAs Senior Manager of Strategic Assessment, I lead MISO’s evaluation and framing of \n17 \nemerging reliability risks and the development of practical, implementable solutions, \n18 \nincluding the ongoing operational requirements for Large Load.    \n19 \nQ. \nHAVE YOU PREVIOUSLY SUBMITTED TESTIMONY IN A REGULATORY \n20 \nPROCEEDING? \n21 \nA. \nNo.   \n22 \n \n23"},{"page":4,"startToken":259,"endToken":596,"text":"Tab C \nPage 2 \n \nII. \nPURPOSE OF TESTIMONY \n1 \nQ. \nWHAT IS THE PURPOSE OF YOUR TESTIMONY? \n2 \nA. \nThe purpose of my testimony is to support MISO’s proposal to apply a defined set of \n3 \nreliability requirements to certain loads, defined as Large Loads.1  \n4 \nQ. \nHOW DOES THE IRR FILING ADDRESS THE CONCERNS RAISED IN THE \n5 \nCOMMISSION’S SHOW CAUSE ORDER RELATED TO LARGE LOADS IN THE \n6 \nMISO REGION? \n7 \nA. \nAs discussed below in greater detail, the IRR proposal defines “Large Load” and is \n8 \nresponsive to several of the concerns raised by the Commission in the Order Instituting \n9 \nProceeding Under Section 206 of the Federal Power Act2 in Docket No. EL26-70-000 by \n10 \nproposing Tariff revisions that are responsive to the concerns raised in the Show Cause \n11 \nOrder regarding ongoing operational requirements for Large Loads.  More specifically, the \n12 \nIRR proposal includes Tariff revisions to include visibility, ramp rate, and disturbance ride-\n13 \nthrough requirements applicable to Large Loads, along with transition provisions to \n14 \nminimize disruption to commercial arrangements.  The IRR proposal does not introduce \n15 \nnew transmission service products, pro forma service agreements, or address potential cost \n16 \nshifting contemplated by the Show Cause Order.  Matters involving new transmission \n17 \nservice products, study processes and potential cost shifting for Large Loads will be \n18 \n \n1  \nAs discussed below, MISO proposes to defined Large Load as Load with Demand of 50 MW or more associated \nwith any facility or aggregation of facilities located at a single substation behind one or more Point(s) of \nWithdrawal from the Transmission System that is owned, operated, or controlled by: (a) a single entity or (b) a \ngroup of entities that will coordinate with respect to the profile of the Load.  Large Load does not include Load \nused exclusively for charging an Electric Storage Resource. \n2  \nMidcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order” or “SCO”)."},{"page":5,"startToken":596,"endToken":855,"text":"Tab C \nPage 3 \n \naddressed in future Federal Power Act Section 205 filings expected to be submitted prior \n1 \nto November 16, 2026. \n2 \nIII. \nTHE RISE OF LARGE LOADS AND  \n3 \nRELATED INTERCONNECTION REQUESTS \n4 \n \n5 \nQ. \nPLEASE DESCRIBE THE EMERGENCE OF LARGE LOADS IN THE MISO \n6 \nREGION.  \n7 \nA. \nThe MISO region is experiencing a significant increase in both the scale and pace of Large \n8 \nLoad development.  MISO’s 2026 Long-Term Load Forecast3 indicates that the region is \n9 \nexperiencing load growth at levels not seen in decades, driven in large part by \n10 \nunprecedented large load activity and accelerating project announcements.  Data centers \n11 \nand advanced manufacturing are among the primary drivers of this growth, with some \n12 \nprojects seeking to develop on timelines significantly shorter than those traditionally \n13 \nassociated with generation and transmission infrastructure.  This combination of increased \n14 \nvolume and accelerated development is changing the manner in which MISO must plan for \n15 \nand reliably integrate new load.  \n16 \nQ. \nPLEASE DESCRIBE THE RELIABILITY CONSIDERATIONS NECESSARY TO \n17 \nACCOMMODATE THE ACCELERATED INTERCONNECTION OF LARGE \n18 \nLOADS IN THE MISO REGION.  \n19 \nA. \nAccommodating the accelerated interconnection of Large Loads requires MISO to ensure \n20 \nthat the Transmission System can reliably plan for and operate these facilities as they come \n21 \nonline.  Key reliability considerations include sufficient visibility into Large Load \n22 \n \n3  \nSee MISO’s 2026 Long-Term Load Forecasting (LTLF) Results Summary (April 13, 2026), available at : \nhttps://cdn.misoenergy.org/20260413%20LTLF%20Workshop%202026%20Long%20Term%20Load%20Forec\nast%20Summary_UPDATED750524.pdf"},{"page":6,"startToken":855,"endToken":1099,"text":"Tab C \nPage 4 \n \ncharacteristics and operating behavior, accurate forecasting and modeling, and \n1 \nrequirements that address operational risks such as rapid change in demand, disturbance \n2 \nresponse, including ride-through capability.  \n3 \nCertain Large Load characteristics—including rapid changes in demand, sudden loss of \n4 \nsignificant load, or dynamic interactions between power-electronic equipment and the \n5 \nTransmission System—may affect system performance during normal operations and \n6 \ncontingency conditions.  Under certain system conditions, these behaviors may increase \n7 \noperational uncertainty, contribute to system stability concerns, affect post-disturbance \n8 \nrecovery, stress transmission facilities, or create additional challenges in maintaining the \n9 \nreal-time balance of supply and demand.  \n10 \nThese considerations do not imply that all large loads create the same reliability risk.  \n11 \nReliability impacts may vary depending on facility type, operating characteristics, \n12 \nelectrical design, system strength, and local transmission conditions.  Accordingly, MISO’s \n13 \napproach is intended to be scalable and risk-informed to ensure reliability requirements \n14 \nremain proportional to demonstrated system risk.   \n15 \nQ. \nPLEASE DESCRIBE THE NERC GUIDANCE AND INDUSTRY DIRECTION \n16 \nINFORMING THIS FILING. \n17 \nA. \nThe North American Electric Reliability Corporation (“NERC”), through the Large Loads \n18 \nWorking Group, has identified emerging large loads as an increasing reliability \n19 \nconsideration for the Bulk Power System.  NERC has identified reliability risks associated \n20 \nwith the rapid growth and changing characteristics of large loads and has issued \n21 \nwhitepapers, incident reviews, a Reliability Guideline, and a Level 3 Alert addressing those \n22"},{"page":7,"startToken":1099,"endToken":1392,"text":"Tab C \nPage 5 \n \nrisks.4  Across these efforts, NERC has emphasized the need for improved load data and \n1 \nmodeling, real-time telemetry and high-resolution monitoring, more accurate near-term \n2 \nforecasting, information regarding ramping and operating characteristics, and better \n3 \nunderstanding of how large loads perform during grid disturbances. \n4 \nThe industry’s direction is also moving beyond voluntary guidance toward formal \n5 \nreliability requirements.  In 2026, NERC initiated Project 2026-02 to develop definitions, \n6 \nregistration criteria, and Reliability Standards for computational load integrations.5  On \n7 \nJuly 16, 2026, the Commission directed NERC to file by December 31, 2026, one or more \n8 \nnew or modified Reliability Standards addressing Bulk-Power System reliability risks \n9 \nassociated with the integration of computational loads and associated definitions.  The \n10 \nCommission also directed NERC to develop revisions to its Rules of Procedure, including \n11 \nregistry criteria necessary for the registration of computational load entities, and stated that \n12 \nit expects NERC to submit those proposed revisions by December 31, 2026.6  Consistent \n13 \nwith that directive, in August 2026, NERC opened 30-day comment periods on proposed \n14 \nRules of Procedure revisions establishing registration criteria for computational load \n15 \n \n4  \nEssential Action to Industry – Computational Load Modeling, Studies, Instrumentation, Commissioning, \nOperations, Protection, and Control, NERC (May 4, 2026), available at \nhttps://www.nerc.com/globalassets/programs/bpsa/alerts/level-3-computational-load-alert.pdf; See Draft large \nLoad Disturbance Performance, NERC (Dec. 10, 2026), available at https://www.nerc.com/globalassets/who-\nwe-are/standing-\ncommittees/rstc/llwg/draft_llwg_white_paper_large_load_disturbance_performance_tosubmit.pdf. \n5  \nProject 2026-02 Computational Load, NERC, https://www.nerc.com/standards/reliability-standards-under-\ndevelopment/2026-02-computational-loads (last visited Aug. 27, 2026). \n6  \nReliability Standard(s) Pertaining to Computational Load Integration, 196 FERC ¶ 61,031 (July 16, 2026)."},{"page":8,"startToken":1392,"endToken":1659,"text":"Tab C \nPage 6 \n \nentities and on proposed Reliability Standards CLO-001, CLO-002, and CLO-003 under \n1 \nProject 2026-02, with comments due September 18, 2026.7 \n2 \nMISO’s IRR proposal is also consistent with the direction being taken by other ISOs and \n3 \nRTOs.  In particular, FERC has accepted Southwest Power Pool’s (“SPP”) High Impact \n4 \nLarge Load (“HILL”) framework, which establishes enhanced study and ongoing \n5 \nreliability requirements for qualifying large loads.8  Like MISO’s IRR proposal, SPP’s \n6 \nframework includes requirements addressing load forecasting, real-time telemetry, phasor \n7 \nmeasurement data, ride-through performance, and limitations on rapid changes in load \n8 \ndemand.  SPP specifically requires HILLs to provide real-time telemetry, comply with \n9 \nramp limits, and meet ride-through requirements, and requires PMU or similar high-\n10 \nresolution measurement equipment to support model validation, dynamic performance \n11 \nmonitoring, and post-event analysis. \n12 \nMISO’s proposed framework addresses many of these same reliability needs, while \n13 \ntailoring the applicability of individual requirements to the characteristics and risks \n14 \nobserved within the MISO footprint.  As described more fully below, MISO applies \n15 \nfoundational data, modeling, telemetry, forecasting, and audit requirements to all Large \n16 \nLoads, while applying additional PMU, ride-through, and ramp requirements specifically \n17 \nto Computational Loads. \n \n18 \n \n7  \nProposed Computational Load ROP Revisions, NERC, https://www.nerc.com/who-we-are/rules-of-\nprocedure/proposed-changes-to-rules-of-procedure (last visited Aug. 27, 2026). See also, Project 2026-02 \nComputational Loads, NERC, https://www.nerc.com/standards/reliability-standards-under-development/2026-\n02-computational-loads (last visited Aug. 27, 2026). \n8  \nThe Commission approved SPP’s proposal on January 14, 2026. See Southwest Power Pool, Inc., 194 FERC ¶ \n61,031 (Jan. 14, 2026)."},{"page":9,"startToken":1659,"endToken":1920,"text":"Tab C \nPage 7 \n \nQ. \nPLEASE DESCRIBE THE RELIABILITY NEEDS DRIVING THIS FILING.  \n1 \nA. \nMISO is experiencing increasing levels of Large Load development being evaluated \n2 \nthrough transmission planning, Expedited Project Review (“EPR”), and other \n3 \ninterconnection-related processes.  Existing MISO planning and operational processes \n4 \nprovide a strong foundation for evaluating reliability impacts; however, the increasing size, \n5 \nconcentration, and changing characteristics of Large Loads create a need for greater \n6 \nconsistency in the information, visibility, and performance expectation necessary to \n7 \nreliably plan and operate the Transmission System.    \n8 \nAccordingly, MISO proposes a reliability-based framework for Large Loads that \n9 \ncomplements existing MISO planning, interconnection, and operational processes.  The \n10 \nframework is intended to improve visibility into Large Load characteristics and behavior, \n11 \nsupport accurate representation of these facilities in planning and operational analyses, and \n12 \nestablish scalable and technically justified requirements that reflect demonstrated \n13 \nreliability risks. \n14 \nQ. \nHAS MISO TAKEN ANY STEPS TO ADDRESS LARGE LOAD INTEGRATION \n15 \nIN THE PAST? \n16 \nA. \nYes.  In recent years, MISO established the Expedited Resource Addition Study (“ERAS”) \n17 \nas a targeted, temporary process to issue a Generator Interconnection Agreement in three \n18 \nmonths.  MISO has also improved its Transmission Expansion Plan’s EPR process to \n19 \nquickly approve transmission upgrades necessary to address urgent needs associated with \n20 \nthe addition of large loads.  As discussed further below, MISO’s large load initiatives are \n21 \ndesigned to support reliability at interconnection, speed to reliable power, and reliable \n22 \nsystem operations as large load additions continue to accelerate across the footprint.   \n23"},{"page":10,"startToken":1920,"endToken":2144,"text":"Tab C \nPage 8 \n \nQ. \nPLEASE EXPLAIN WHY THESE EXISTING EFFORTS ARE INSUFFICIENT.  \n1 \nA. \nWhile these initiatives provide important benefits, they do not fully address the reliability \n2 \nand operational challenges associated with accelerating large load growth.  Existing \n3 \nplanning reforms primarily focus on generation additions and transmission development \n4 \ntimelines.  Likewise, broader reliability initiatives were not specifically designed to address \n5 \nthe unique characteristics and operational challenges presented by large load and \n6 \ncomputational load additions.  Accordingly, additional Tariff-based solutions are necessary \n7 \nto establish clear reliability expectations, improve operational visibility, and facilitate \n8 \ntimely integration of large loads in a manner that is both reliable and non-discriminatory. \n9 \nQ. \nHOW \nIS \nMISO \nPROPOSING \nTO \nACCELERATE \nTHE \nRELIABLE \n10 \nINTEGRATION OF LARGE LOADS IN THE MISO REGION? \n11 \nA. \nMISO is proposing to implement a reliability-based framework to support the \n12 \ninterconnection and ongoing operational challenges of Large Loads within the MISO \n13 \nregion.  The objective is to establish scalable, technically justified, and risk-informed \n14 \nexpectations that improve visibility into large load behavior, support planning and \n15 \noperational readiness, and preserve reliable operation of the Transmission System and Bulk \n16 \nElectric System.  The proposed framework is intended to complement existing MISO \n17 \nplanning, interconnection, and operational processes and align, to the extent practical, with \n18 \nemerging NERC guidance and industry practices. \n \n19"},{"page":11,"startToken":2144,"endToken":2372,"text":"Tab C \nPage 9 \n \nIV. \nMISO’S LARGE LOAD INTERCONNECTION RELIABILITY \n1 \nREQUIREMENTS PROPOSAL \n2 \nQ. \nPLEASE PROVIDE AN OVERVIEW OF MISO’S PROPOSED RELIABILITY \n3 \nREQUIREMENTS FOR LARGE LOADS.  \n4 \nA. \nMISO’s IRR proposal establishes a reliability framework surrounding Large Load \n5 \ninterconnection that is focused on visibility of Large Loads and management of the ongoing \n6 \noperational impacts Large Loads present.  In addition to the specific reliability \n7 \nrequirements codified in the Tariff, the IRR proposal also provides key transition \n8 \nprovisions related to the application of specific requirements that seek to minimize \n9 \ndisruption to existing commercial arrangements for Large Loads, including those \n10 \ncommercial arrangements that were nearing completion at the time of this filing.  The \n11 \ndistinct categories of requirements are:  \n12 \n1. \nVisibility Requirements - Data, Modeling, Telemetry, and Forecasting \n13 \nRequirements: These requirements establish expectations for facility information, \n14 \nelectrical models, real-time telemetry, monitoring, short-term and forecasting, and \n15 \nother operational visibility requirements necessary to support planning studies, \n16 \noperational assessments, and accurate representation of Large Load behavior and \n17 \nsystem impacts.   \n18 \n2  \nPhasor Measurement Unit (PMU) Requirements: In addition to the broader \n19 \nvisibility requirements above, the PMU requirements establish enhanced \n20 \nmonitoring expectations for Computation Loads through high-resolution, time-\n21 \nsynchronized measurements.  PMU data provides MISO with greater visibility into \n22 \nfacility behavior during system disturbances and rapid operating changes, \n23"},{"page":12,"startToken":2372,"endToken":2623,"text":"Tab C \nPage 10 \n \nsupporting model validation, performance verification, disturbance analysis, and \n1 \nidentification of potential dynamic interactions with the Transmission System. \n2 \n3. \nRamp Requirements: These requirements \naddress the rate at which \n3 \nComputational Loads may increase or decrease consumption during stable-state \n4 \ntransitions.  Managing rapid changes in demand helps reduce real-time supply-\n5 \ndemand imbalances, sudden change in transmission power flows, and associated \n6 \noperational impacts, while supporting more reliable system operation.  Ramp-rate \n7 \nlimits do not apply during fault or disturbance conditions when necessary for \n8 \nequipment protection or to satisfy ride-through performance requirements. \n9 \n4. \nRide-Through \nRequirements: These \nrequirements \nestablish \nminimum \n10 \ndisturbance performance expectations during voltage and frequency disturbances \n11 \nto reduce the risk of unnecessary disconnection or customer-initiated rapid \n12 \nreductions in Demand during credible system events.   \n13 \nMISO recognizes that the Commission also included a study process that evaluates and \n14 \nmanages the unique reliability and operational challenges Large Loads create when \n15 \nreceiving Transmission Service  in its discussion of ongoing operational requirements in \n16 \nthe Show Cause Order.  The IRR proposal addresses requirements applicable to Large Load \n17 \nfacilities themselves.  MISO evaluates and manages unique reliability and operational \n18 \nchallenges through studies, including a stability assessment, as part of its MTEP and EPR \n19 \nprocesses.  MISO intends to address enhancements to stability assessment study processes \n20 \nin a future Federal Power Act Section 205 filing.  Those future study processes will focus \n21 \non identifying system-level reliability impacts associated with load additions and \n22"},{"page":13,"startToken":2623,"endToken":2861,"text":"Tab C \nPage 11 \n \ndetermining whether transmission or other system-level solutions are necessary, as part of \n1 \na broader set of load addition and transmission service study requirements. \n2 \nA. \nDEFINITIONS \n3 \nQ. \nPLEASE IDENTIFY THE NEW DEFINITIONS MISO PROPOSES TO \n4 \nIMPLEMENT THROUGH THIS FILING.  \n5 \nA. \nThe following definitions are provided to support consistent interpretation of the reliability \n6 \nframework described in this filing:   \n7 \n• \nComputational Load: Large Load comprised of 25 MW or more of Demand from \n8 \ninformation technology equipment, such as servers, storage, and networking \n9 \nhardware. \n10 \n• \nLarge Load: Load with Demand of 50 MW or more associated with any facility \n11 \nor aggregation of facilities located at a single substation behind one or more Point(s) \n12 \nof Withdrawal from the Transmission System that is owned, operated, or controlled \n13 \nby: (a) a single entity or (b) a group of entities that will coordinate with respect to \n14 \nthe profile of the Load.  Large Load does not include Load used exclusively for \n15 \ncharging an Electric Storage Resource. \n16 \n• \nLarge Load Equipment: Any of the facilities, devices, or equipment that \n17 \nconstitutes a part of a Large Load, or are used to interconnect the Large Loads to \n18 \nthe Transmission System.   \n19 \n• \nPoint(s) of Withdrawal: The point where a non-transmission facility used to \n20 \nwithdraw Energy from the Transmission System to serve Load connects to the \n21 \nTransmission System.   \n \n22"},{"page":14,"startToken":2861,"endToken":3124,"text":"Tab C \nPage 12 \n \nQ. \nHOW DID MISO ARRIVE AT THE PROPOSED DEFINITION OF LARGE \n1 \nLOAD? \n2 \nA. \nMISO developed the proposed Large Load definition through review of emerging industry \n3 \npractices, consideration of the reliability needs within the MISO region, and stakeholder \n4 \nfeedback.  MISO reviewed approaches being developed or used by NERC and other RTOs, \n5 \nincluding PJM, SPP, and ERCOT.  While those approaches vary, they generally recognize \n6 \nthat sufficiently large, concentrated load additions warrant additional visibility and \n7 \nreliability consideration. \n8 \nBased on that review, MISO selected a 50 MW threshold as a reasonable and \n9 \nadministratively clear starting point, consistent with industry precedent and sufficiently \n10 \nsignificant to warrant application of MISO’s Large Load requirements.  The definition is \n11 \nbased on gross load rather than net load so that MISO has visibility into the full electrical \n12 \ndemand and characteristics of the facility. \n13 \nFinally, MISO also defined Large Load at the facility or site level rather than solely at an \n14 \nindividual point of interconnection.  This allows loads under common ownership or \n15 \ncoordinated operational control at a single site to be considered together, including where \n16 \nthe site is served through multiple points of interconnection. \n17 \nQ. \nWHY IS 50 MW A REASONABLE THRESHOLD FOR LARGE LOAD IN THE \n18 \nMISO REGION? \n19 \nA. \nMISO determined that 50 MW is a reasonable threshold based on industry precedent, \n20 \nincluding from PJM and SPP, and the need for a clear and administratively workable means \n21 \nof identifying significant, concentrated loads that warrant additional reliability visibility.  \n22"},{"page":15,"startToken":3124,"endToken":3394,"text":"Tab C \nPage 13 \n \nA load of this magnitude is sufficiently large that its characteristics and behavior can be \n1 \nrelevant to transmission planning and system operations.  \n2 \nImportantly, the 50 MW threshold serves as an applicability threshold; it does not mean \n3 \nthat every Large Load at or above 50 MW presents the same reliability risk.  MISO’s \n4 \nproposed requirements recognize differences in facility characteristics by establishing \n5 \nbaseline visibility requirements for Large Loads while applying certain additional \n6 \nperformance requirements to Computational Loads where their operating characteristics \n7 \nwarrant additional consideration.  This approach provides a clear threshold while allowing \n8 \nthe requirements to remain proportional to the reliability needs being addressed. \n9 \nQ. \nWHY DOES MISO DEFINE “COMPUTATIONAL LOAD”? \n10 \nA. \nMISO defines Computational Load to distinguish a subset of Large Loads that may exhibit \n11 \noperational characteristics different from more traditional loads, including rapid changes \n12 \nin demand, highly coordinated control behavior, and power-electronic responses during \n13 \nsystem disturbances.  This distinction allows MISO to apply certain incremental \n14 \nrequirements—such as ramp, PMU, and ride-through requirements—only where those \n15 \ncharacteristics warrant additional reliability consideration.  Defining Computational Load \n16 \ntherefore supports a more targeted and risk-informed approach, rather than applying the \n17 \nsame requirements to all Large Loads regardless of facility type or operating behavior. \n18 \nQ. \nWHY IS A DEFINITION OF COMPUTATIONAL LOAD NECESSARY FOR THIS \n19 \nFILING? \n20 \nA. \nA definition of Computational Load is necessary because certain proposed requirements \n21 \nare intended to apply only to Large Loads with operating characteristics that warrant \n22 \nadditional reliability consideration.  Computational Loads may exhibit rapid and \n23"},{"page":16,"startToken":3394,"endToken":3653,"text":"Tab C \nPage 14 \n \ncoordinated changes in demand, significant power-electronic behavior, and distinct \n1 \nresponses to Transmission System disturbances.  Defining this subset allows MISO to \n2 \napply incremental requirements—such as ramp, PMU, and ride-through requirements—in \n3 \na targeted manner rather than applying them to all Large Loads.  As noted above, this \n4 \nsupports a scalable and risk-informed approach in which requirements are aligned with the \n5 \ncharacteristics and reliability risks they are intended to address. \n6 \nQ. \nHOW DOES MISO’S PROPOSED DEFINITION OF COMPUTATIONAL LOAD \n7 \nALIGN WITH NERC’S PROPOSED DEFINITION? \n8 \nA. \nMISO’s proposed definition of Computational Load is closely aligned with NERC’s \n9 \ndeveloping definition of computational load.  Both approaches identify computational load \n10 \nbased on electric demand associated with information technology equipment, such as \n11 \nservers, storage, and networking hardware.  This common approach focuses on the \n12 \nunderlying electrical equipment and characteristics of the load rather than on a particular \n13 \nindustry or customer type. \n14 \nMISO has tailored the applicability of its requirements to the needs of the MISO \n15 \nTransmission System, while NERC is separately developing registration criteria and \n16 \nReliability Standards to determine which Computational Load Owners and Operators will \n17 \nbe subject to mandatory NERC requirements.  Accordingly, differences in applicable \n18 \nthresholds or scope do not represent a fundamental difference in the definition of \n19 \nComputational Load; rather, they reflect the different purposes and responsibilities of \n20 \nMISO and NERC. \n21 \nMISO will continue to monitor NERC’s ongoing standards development and seek \n22 \nalignment as those requirements are finalized. \n23"},{"page":17,"startToken":3653,"endToken":3875,"text":"Tab C \nPage 15 \n \n \nB. \nSCOPE AND APPLICABILITY \n1 \nQ. \nPLEASE DESCRIBE THE SCOPE OF THIS FILING. \n2 \nA. \nThis filing proposes reliability requirements and a reliability-based framework applicable \n3 \nto Transmission Customers taking Transmission Service on behalf of Large Load \n4 \ninterconnected to the MISO Transmission System.  These requirements are needed to allow \n5 \nMISO to plan for and ensure the reliable operations of Large Loads that may materially \n6 \naffect the Transmission System or Bulk Electric System due to their size, operating \n7 \nbehavior, electrical characteristics, or dynamic performance.  The filing includes the \n8 \nfollowing principal requirements: \n9 \n• \nDefinitions and Applicability: Establishes which facilities qualify as Large Loads and \n10 \nComputational Loads and identifies when the requirements apply. \n11 \n• \nData Requirements: Establishes the facility and operational information MISO needs \n12 \nto understand Large Load characteristics and expected behavior. \n13 \n• \nModel Requirements: Requires appropriate electrical models so Large Loads can be \n14 \naccurately represented in MISO planning and operational analyses. \n15 \n• \nTelemetry Requirements: Provides real-time visibility into Large Load demand and \n16 \noperating conditions to support reliable system operations. \n17 \n• \nForecasting Requirements: Establishes short-term and other forecast information \n18 \nneeded to anticipate Large Load demand and operating changes. \n19 \n• \nPMU Requirements for Computational Loads: Provides high-resolution, time-\n20 \nsynchronized measurements to support disturbance analysis, model validation, and \n21 \nperformance verification. \n22"},{"page":18,"startToken":3875,"endToken":4134,"text":"Tab C \nPage 16 \n \n• \nRamp Requirements for Computational Loads: Establishes limits on rapid increases \n1 \nor decreases in demand during stable-state transitions to help manage operational \n2 \nimpacts. \n3 \n• \nRide-Through Requirements for Computational Loads: Establishes minimum \n4 \nvoltage and frequency disturbance-performance expectations to reduce unnecessary \n5 \ndisconnection and sudden load loss. \n6 \n• \nImplementation and Transitional Provisions: Establishes compliance timing, \n7 \nresponsibilities, and transition mechanisms for existing and developing facilities. \n8 \nTaken together, these provisions address reliability needs at the facility and information \n9 \nlevels by establishing clearer expectations for how Large Loads are represented, monitored, \n10 \nforecasted, and expected to perform.  MISO intends to address additional enhancements to \n11 \nits study processes in a subsequent filing, including analyses used to identify broader \n12 \nsystem-level reliability impacts and, where necessary, appropriate system-level solutions. \n13 \nQ. \nDOES THE IRR FILING PROPOSE NEW TRANSMISSION PRODUCTS? \n14 \nA. \nNo.  This IRR proposal focuses specifically on reliability requirements applicable to Large \n15 \nLoads in the MISO region.  MISO will address new transmission products in a separate \n16 \nFederal Power Act Section 205 filing. \n17 \nQ. \nTO WHOM WILL THE PROPOSED REQUIREMENTS APPLY?   \n18 \nA. \nThe proposed requirements in this filing apply to the Large Load as set forth in the Tariff \n19 \nand the Business Practices Manual for Large Load, and as discussed further below.   \n20 \nSubject to the transition provisions discussed below, all Large Loads will be subject to the \n21 \napplicable visibility requirements including: Basic Facility Data, Modeling, Telemetry, \n22 \nForecast Data, and Audit requirements.  In addition, the Computational Load component \n23"},{"page":19,"startToken":4134,"endToken":4396,"text":"Tab C \nPage 17 \n \nof a Large Load, as defined in the Tariff, is additionally subject to the Phasor Measurement \n1 \nUnit, Ride-Through, and Ramp requirements.   \n2 \nAs previously discussed, MISO recognizes that not all Large Loads present the same \n3 \nreliability risks.  Accordingly, MISO has limited the application of PMU, Ramp and Ride-\n4 \nThrough requirements to the Computational Load component of a Large Load, which \n5 \nreflects the increased operational risk Computational Loads place on the Transmission \n6 \nSystem.  As previously stated, the IRR proposal is intended to provide a scalable and risk-\n7 \ninformed framework that may be applied in a manner proportional to demonstrated \n8 \nreliability need, system conditions, and facility characteristics.   \n9 \nQ. \nWHICH ENTITIES ARE RESPONSIBLE FOR COMPLIANCE WITH THE \n10 \nREQUIREMENTS PROPOSED IN THIS FILING? \n11 \nA. \nThe IRR proposal establishes that the Transmission Customer taking Transmission Service \n12 \non behalf of a Large Load is responsible for ensuring compliance with each of the \n13 \napplicable requirements set forth in the new Tariff section 37A.  The term “Transmission \n14 \nCustomer” is currently defined in the MISO Tariff as: “Any Eligible Customer (or its \n15 \nDesignated Agent) that (i) executes a Service Agreement, or (ii) requests in writing that the \n16 \nTransmission Provider file with the Commission, a proposed unexecuted Service \n17 \nAgreement to receive Transmission Service under Module B of this Tariff.” This term is \n18 \nused in the Module A, Common Tariff Provisions, to include customers receiving \n19 \nTransmission Service under Module B of this Tariff, including any customer receiving \n20 \nHVDC Service.    \n21"},{"page":20,"startToken":4396,"endToken":4661,"text":"Tab C \nPage 18 \n \nQ. \nWHY IS IT JUST AND REASONABLE TO APPLY THE INTERCONNECTION \n1 \nRELIABILITY REQUIREMENTS TO A TRANSMISSION CUSTOMER TAKING \n2 \nTRANSMISSION SERVICE ON BEHALF OF A LARGE LOAD? \n3 \nA. \nRequiring the Transmission Customer to prove compliance with the requirements \n4 \nestablished in the IRR proposal is consistent with the Show Cause Order’s discussion of \n5 \nimposing requirements on an “Eligible Customer” and recognizes that the ultimate owner \n6 \nof a Large Load may not participate directly in MISO’s markets or otherwise have \n7 \ncontractual privity to MISO.  All Large Loads interconnected to the Transmission System, \n8 \nhowever, will be required to procure Transmission Service through a Transmission \n9 \nCustomer pursuant to the Tariff.  As a result, the Transmission Customer will be required \n10 \nto enter into a transmission service agreement, which incorporates by reference, the terms \n11 \nof the Tariff, including the requirements proposed herein.  As such, applying the \n12 \nrequirements established in the IRR proposal to a Transmission Customer taking \n13 \nTransmission Service on behalf of a Large Load establishes a legally enforceable \n14 \nframework though which all reliability requirements imposed on a Large Load may be \n15 \nenforced.    \n16 \n \nC. \nTRANSITION PROVISIONS \n17 \nQ. \nHOW DOES THE IRR FILING RECOGNIZE EXISTING COMMERCIAL \n18 \nARRANGEMENTS, \nAND \nCOMMERCIAL \nARRANGEMENTS \nNEAR \n19 \nCOMPLETION, AS CONTEMPLATED BY THE SHOW CAUSE ORDER? \n20 \nA. \nThe IRR Filing includes transition provisions that are intended to provide certainty to \n21 \nexisting commercial arrangements and commercial arrangements that were near \n22 \ncompletion at the time of this filing.  The requirements, which I discuss further below, \n23"},{"page":21,"startToken":4661,"endToken":4965,"text":"Tab C \nPage 19 \n \nconsider the Service Commencement Date of the Transmission Service to serve a Large \n1 \nLoad, whether transmission projects or upgrades associated with the Large Load have been \n2 \napproved by the MISO Board in MTEP 2026, or a prior MTEP, and when transmission \n3 \nprojects or upgrades associated with the Large Load has been submitted to the MISO EPR \n4 \nprocess.  The “Service Commencement Date” is the date MISO or an Independent \n5 \nTransmission Company (“ITC”) begins to provide service pursuant to the terms of an \n6 \nexecuted Service Agreement, or the date MISO or an ITC begins to provide Transmission \n7 \nService under the MISO Tariff. \n8 \nQ. \nWHAT IS THE MTEP / EPR CONDITION? \n9 \nA. \nFor purposes of the transition provisions, Load will satisfy the “MTEP/EPR Condition” if \n10 \nit is associated with a transmission project that either: (a) has been approved by the MISO \n11 \nBoard in MTEP 2026, or a prior MTEP; or, (b) has been submitted to MISO for EPR on or \n12 \nprior to June 18, 2026, in accordance with Attachment FF of the Tariff. \n13 \nQ. \nWHAT IS THE SIGNIFICANCE OF LINKING APPROVAL OF TRANSMISSION \n14 \nPROJECTS FOR LARGE LOAD INTERCONNECTIONS TO MTEP 2026, OR A \n15 \nPRIOR MTEP? \n16 \nA. \nUnder current processes, MISO does not have a Load interconnection process.  As such, \n17 \nspecific Load additions are not submitted to MISO for individual study in MISO’s planning \n18 \nprocesses; however, the need for transmission upgrades or related projects to support a new \n19 \nLoad can be identified through MISO’s MTEP or EPR processes.  Linking the transition \n20 \nprovisions discussed below to approvals received in MTEP 2026, or prior, recognizes the \n21 \nexisting commercial arrangements and more immediate, non-speculative, nature of the \n22 \nLoad additions and associated Transmission System upgrades. \n23"},{"page":22,"startToken":4965,"endToken":5254,"text":"Tab C \nPage 20 \n \nQ. \nWHY DO THE PROPOSED TRANSITION PROVISIONS ALLOW FOR \n1 \nSUBMISSIONS OF LOAD OR TRANSMISSION UPGRADES THROUGH EPR \n2 \nON OR BEFORE JUNE 18, 2026? \n3 \nA. \nThe June 18, 2026, date coincides with the Commission’s issuance of the Show Cause \n4 \nOrder and establishes a date on which all parties were on notice that significant changes to \n5 \nMISO’s Tariff, and requirements for Large Loads in particular, should be expected in the \n6 \nnear future.  In addition, application of this date in the terms of the transition provision \n7 \nrecognizes projects that had been previously submitted to MISO for study in the EPR \n8 \nprocess on, or prior to, the date of the Show Cause Order without opening a window during \n9 \nwhich parties could submit speculative EPR or MTEP projects. \n10 \nQ. \nPLEASE DESCRIBE THE TRANSITION PROVISIONS PROPOSED IN THIS \n11 \nFILING. \n12 \nA. \nMISO proposes to implement the following transition provisions:  \n13 \nFirst, MISO proposes to fully exempt, or “grandfather,” any Large Load that has a Service \n14 \nCommencement Date on or prior to December 4, 2026, from all requirements of the \n15 \nproposed Section 37A, with respect to the portion of the Large Load that has procured \n16 \nTransmission Service as of the Service Commencement Date.  Any modification or series \n17 \nof modifications to a Load that meets the MTEP/EPR Condition, which results in a \n18 \ncumulative increase of 25 MW or more in Transmission Service for such Load and with a \n19 \nService Commencement Date after December 4, 2026, may subject the additional Load to \n20 \ncertain requirements, depending on MTEP / EPR approval date and the Service \n21 \nCommencement Date of the Transmission Service for the additional Load. \n22"},{"page":23,"startToken":5254,"endToken":5570,"text":"Tab C \nPage 21 \n \nSecond, MISO proposes that a Large Load, or a portion of a Large Load, that does not have \n1 \na Service Commencement Date prior to December 4, 2026, but that meets the MTEP/EPR \n2 \nCondition shall be subject to the visibility requirements set forth in Sections 37A.1 through \n3 \n37A.5 and Section 37A.8, and shall be exempt from the ramp and ride-through \n4 \nrequirements set forth in Sections 37A.6 through 37A.7.   \n5 \nThird, MISO proposes that a Large Load, or a portion of Large Load, that does not have a \n6 \nService Commencement Date prior to December 4, 2026, and that has not met the \n7 \nMTEP/EPR Condition, but has submitted Load associated with a transmission project to \n8 \nthe Transmission Provider for EPR on or after June 19, 2026, but on or before October 31, \n9 \n2026, shall be subject to all requirements set forth in this Section 37A, provided that \n10 \nTransmission Provider may waive the ride-through requirements set forth in Section 37A.6 \n11 \nbased upon a determination that: a) exemption from such requirements would not have an \n12 \nadverse reliability impact; and, b) compliance with such requirements would result in \n13 \nsignificant costs. \n14 \nQ. \nWHY DOES MISO PROVIDE A POTENTIAL EXEMPTION FROM RIDE-\n15 \nTHROUGH REQUIREMENTS FOR PROJECTS SUBMITTED BETWEEN JUNE \n16 \n19, 2026, AND OCTOBER 31, 2026? \n17 \nA. \nMISO provides a potential exemption from the ride-through requirements for certain \n18 \nprojects submitted between June 19, 2026, and October 31, 2026, to provide a reasonable \n19 \ntransition for projects that were nearing completion at the time of this filing. \n20 \nThe June 19, 2026, date immediately follows the Commission’s June 18, 2026 Show Cause \n21 \nOrder, which recognized that Large Loads were at different stages of development and \n22 \ndirected that prospective reforms minimize disruption to existing commercial \n23"},{"page":24,"startToken":5570,"endToken":5838,"text":"Tab C \nPage 22 \n \narrangements and provide reasonable time for arrangements nearing completion.  The \n1 \nOctober 31, 2026, cutoff date establishes a finite transition period, after which prospective \n2 \nprojects are expected to account for MISO’s ride-through requirements as part of their \n3 \ndevelopment and design. \n4 \nImportantly, the provision does not provide an automatic exemption from ride-through \n5 \nrequirements.  Rather, it provides a pathway for eligible projects to demonstrate, through \n6 \nthe applicable reliability assessment, that operation without full ride-through capability \n7 \nwould not result in an adverse reliability impact.  Where such a determination cannot be \n8 \nmade, appropriate ride-through capability or mitigation would still be required. \n9 \nThis approach balances the need to recognize projects that may have made material design, \n10 \nprocurement, or commercial commitments before the new requirements were fully \n11 \nestablished with MISO’s responsibility to maintain reliable operation of the Transmission \n12 \nSystem. \n13 \nQ. \nARE LARGE LOADS THAT DO NOT MEET THE MTEP/EPR CONDITION \n14 \nEXEMPT? \n15 \nA. \nNo.  A Large Load, or a portion of a Large Load, that does not meet the MTEP/EPR \n16 \nCondition shall be subject to all applicable requirements set forth in proposed Section 37A. \n17 \nQ. \nHOW DID MISO DEVELOP THESE TRANSITION PROVISIONS? \n18 \nA. \nMISO developed the transition provisions through a deliberate process that considered both \n19 \nidentified reliability needs and practical implementation considerations for Large Loads at \n20 \ndifferent stages of development.  MISO evaluated the reliability objectives of the proposed \n21 \nrequirements, presented and discussed potential transition approaches through the MISO \n22 \nstakeholder process, and considered stakeholder feedback regarding project status, \n23"},{"page":25,"startToken":5838,"endToken":6079,"text":"Tab C \nPage 23 \n \nimplementation readiness, and the potential economic and other impacts of applying new \n1 \nrequirements to existing and late-stage projects.  Based on that process, MISO refined the \n2 \ntransition framework to provide appropriate treatment for existing and previously approved \n3 \nprojects while applying the new requirements prospectively and preserving MISO’s ability \n4 \nto address demonstrated material adverse impacts to Transmission System reliability. \n5 \n \nD. \nLARGE LOAD RELIABILITY REQUIREMENTS \n6 \nQ. \nPLEASE SUMMARIZE THE PROPOSED RELIABILITY REQUIREMENTS. \n7 \nA. \nThe proposed framework consists of the following categories of reliability requirements \n8 \nintended to address planning, operational, disturbance performance, and system stability \n9 \nconsiderations associated with Large Loads:   \n10 \nRequirement Category \nGeneral Applicability \nData, Modeling, \nTelemetry, and \nForecasting, \nRequirements \nGenerally applicable to all Large Loads to provide MISO \nwith the information, models, operational visibility, and \nforecasts necessary to support transmission planning and \nreliable system operations. \nPhasor Measurement \nUnit (PMU) \nRequirements \nApplicable to Computational Loads to provide high-\nresolution, time-synchronized measurement capability \nsupporting monitoring, model validation, post-event \nanalysis, and reliability assessment. \nRamp Requirements \nApplicable to Computational Loads. Ramp limits address \nup- and down-ramp behavior during stable-state transitions \nand are measured in aggregate across the applicable Point(s) \nof Withdrawal. \nRide-Through \nRequirements \nApplicable to Computational Loads. Computational Loads \nmust remain connected and continue operation during \nvoltage and frequency disturbances within the performance \ncriteria established by MISO. \nThe applicability of individual requirements, implementation details, exemptions, and \n11 \ncompliance approaches are discussed below.   \n12"},{"page":26,"startToken":6079,"endToken":6313,"text":"Tab C \nPage 24 \n \n1. \nBasic Facility Data and Modeling \n1 \nQ. \nPLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED \n2 \nDATA AND MODELING REQUIREMENTS.  \n3 \nA. \nThe objective of the proposed data and modeling requirements is to ensure sufficient \n4 \nvisibility into the characteristics, operating behavior, and electrical performance of Large \n5 \nLoads necessary to support reliable planning, interconnection, commissioning, operations, \n6 \nand post-event analysis.  As emerging Large Loads increasingly exhibit dynamic operating \n7 \ncharacteristics and concentrated demand, and utilize sophisticated power-electronic \n8 \nequipment and controls, additional facility information, telemetry, and modeling detail \n9 \nmay be necessary to evaluate reliability impacts under both normal and contingency \n10 \nconditions.  Data and modeling requirements are intended to support reliable operation of \n11 \nthe Transmission System by improving the accuracy of planning assumptions, \n12 \nstrengthening operational awareness, supporting disturbance analysis and model \n13 \nvalidation, and enabling more consistent evaluation of system performance associated with \n14 \nLarge Load integration.  These requirements provide a framework for obtaining facility \n15 \ninformation, electrical models, telemetry, monitoring data, and operational visibility \n16 \nnecessary to support planning studies, operational assessments, commissioning activities, \n17 \nand reliability evaluations.   \n18 \nQ. \nPLEASE DESCRIBE THE PROPOSED DATA REQUIREMENTS.  \n19 \nA. \nThe proposed data requirements are intended to ensure that MISO has sufficient \n20 \ninformation to understand the configuration and electrical characteristics of each Large \n21 \nLoad.  Transmission Customers must provide basic facility information, one-line diagrams, \n22"},{"page":27,"startToken":6313,"endToken":6567,"text":"Tab C \nPage 25 \n \nand information describing the electrical characteristics of the Large Load and associated \n1 \nLarge Load Equipment. \n2 \nThe requirements also establish an ongoing obligation to provide timely updates when the \n3 \ncharacteristics of the Large Load change.  Those updates may include changes in Load \n4 \nMW amounts, firm and non-firm demand, dispatchable Load, power factor, metering, \n5 \ntelemetry, breaker configuration, staged load additions, and annual energy.  The \n6 \nTransmission Customer must also coordinate with the applicable Transmission Owner in \n7 \naccordance with MISO’s load interconnection guidance and applicable NERC standards. \n8 \nTogether, these requirements help ensure that MISO has current and accurate facility \n9 \ninformation to support planning and reliable operation of the Transmission System. \n10 \nQ. \nPLEASE DESCRIBE THE PROPOSED MODELING REQUIREMENTS.  \n11 \nA. \nThe proposed modeling requirements are intended to ensure that MISO has accurate and \n12 \nsufficiently detailed representations of Large Loads for transmission planning and \n13 \nreliability analysis.  Transmission Customers must provide verified electrical models and \n14 \ndetailed load profiles with enough information for MISO to evaluate system performance \n15 \nunder normal and contingency conditions. \n16 \nBefore service begins, the Transmission Customer must submit final verified models \n17 \nreflecting the facility’s as-built configuration and actual operating characteristics.  The \n18 \nmodels must also be maintained and updated over time, and material modifications must \n19 \nbe submitted to MISO for study and approval before implementation. \n20 \nTogether, these requirements help ensure that MISO’s planning and reliability studies are \n21 \nbased on current and representative Large Load models. \n22"},{"page":28,"startToken":6567,"endToken":6789,"text":"Tab C \nPage 26 \n \n2. \nLoad Forecasting Requirements \n1 \nQ. \nPLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED \n2 \nLOAD FORECASTING REQUIREMENTS.  \n3 \nA. \nLarge Loads can change system conditions rapidly, and unlike traditional demand, their \n4 \nbehavior cannot be forecasted accurately using historical load patterns, even when modeled \n5 \nwith weather and calendar data in MISO’s short-term forecasting system.   \n6 \nQ. \nPLEASE \nDESCRIBE \nTHE \nPROPOSED \nLOAD \nFORECASTING \n7 \nREQUIREMENTS.  \n8 \nA. \nThe proposed short and medium-term forecasting requirements are intended to provide \n9 \nMISO with timely and accurate visibility of expected Large Load demand.  Transmission \n10 \nCustomers must provide Day-Ahead and Real-Time Load Forecasts directly to MISO to \n11 \nsupport the Reliability Assessment Commitment, Security Constrained Economic \n12 \nDispatch, and other reliability studies.  The forecasts must be updated to reflect the most \n13 \ncurrent information regarding expected demand. \n14 \nMISO also provided an extended implementation period for these requirements.  \n15 \nCompliance is required by the latter of the Large Load’s Service Commencement Date or \n16 \nSeptember 1, 2027, providing Transmission Customers with additional time to establish \n17 \nthe forecasting capabilities, data processes, and related procedures necessary to provide \n18 \nreliable day-ahead and real-time Load Forecasts to MISO. \n19 \n3. \nTelemetry and PMU Requirements \n20 \nQ. \nPLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED \n21 \nTELEMETRY AND PHASOR MEASUREMENT UNIT REQUIREMENTS.  \n22"},{"page":29,"startToken":6789,"endToken":7050,"text":"Tab C \nPage 27 \n \nA. \nThe objective of the proposed Telemetry and PMU requirements is to provide MISO with \n1 \nthe real-time visibility and high-resolution measurement capabilities necessary to reliably \n2 \nintegrate Large Loads.  Continuous, high-resolution visibility into the behavior of Large \n3 \nLoads is needed because the size, rapid changes in consumption, and dynamic behavior of \n4 \nLarge Loads can create or exacerbate reliability risks. \n5 \nTelemetry provides the foundational real-time visibility into Large Load operation.  The \n6 \nproposed Telemetry requirements apply to all applicable Large Loads and provide MISO \n7 \nand Transmission Owners with real-time information regarding Large Load electrical \n8 \nconditions and operating behavior through SCADA/ICCP data.  This information supports \n9 \nreal-time monitoring, balancing of supply and demand, contingency analysis, and \n10 \nidentification of abnormal operating conditions. \n11 \nFor Computational Loads, the proposed PMU requirements provide additional high-\n12 \nresolution, time-synchronized measurements needed to monitor and verify dynamic \n13 \nperformance that may not be adequately captured by conventional telemetry.  \n14 \nComputational Loads can exhibit rapid changes in real and reactive power and can respond \n15 \nrapidly to voltage and frequency disturbances, including through partial reductions in \n16 \nconsumption or disconnection.  PMUs, or comparable high-resolution measurements, \n17 \nenable MISO to: monitor and verify disturbance performance, including ride-through and \n18 \nactive-power recovery behavior; characterize rapid changes in consumption and oscillatory \n19 \nbehavior; validate and refine models used in reliability studies; and, support post-event \n20 \nanalysis. \n21 \nThe PMU requirements therefore complement, rather than duplicate, conventional \n22 \ntelemetry by providing the measurement resolution necessary to observe and evaluate the \n23"},{"page":30,"startToken":7050,"endToken":7224,"text":"Tab C \nPage 28 \n \nfast dynamic behavior of Computational Loads.  Figure 1 illustrates the difference in \n1 \nmeasurement resolution between conventional SCADA telemetry and PMU data.   \n2 \n \n \n3 \n \n4 \nFigure 1: Differences between SCADA and PMU \n5 \nQ. \nPLEASE DESCRIBE THE PROPOSED TELEMETRY REQUIREMENTS.  \n6 \nA. \nThe telemetry requirements are intended to provide MISO with reliable, real-time visibility \n7 \ninto Large Load operations.  The Transmission Customer must provide real-time telemetry \n8 \nthrough an approved communication path using Inter-Control Center Communications \n9 \nProtocol (“ICCP”), maintain commercially reasonable levels of data availability and \n10 \naccuracy, and promptly correct data or modeling issues.  This also requires individual \n11 \nmetering for Large Loads and, where applicable, generation located behind the same Point \n12 \nof Withdrawal so that MISO can accurately distinguish and assess the relevant load and \n13 \nrelated generation behavior. \n14 \nMISO also provides an extended implementation period for these requirements.  \n15 \nCompliance is required by the latter of the Large Load’s Service Commencement Date or \n16 \nSeptember 1, 2027, providing Transmission Customers and Transmission Owners \n17"},{"page":31,"startToken":7224,"endToken":7473,"text":"Tab C \nPage 29 \n \nadditional time to establish the necessary metering, ICCP communications, data mappings, \n1 \nand related processes needed to provide reliable and accurate telemetry to MISO.  \n2 \nQ. \nDOES THE PROPOSAL IDENTIFY SPECIFIC PHASOR MEASUREMENT \n3 \nREQUIREMENTS FOR COMPUTATIONAL LOADS? \n4 \nA. \nYes.  The PMU requirements apply specifically to Computational Loads and are intended \n5 \nto provide MISO with high-resolution, time-synchronized visibility into their electrical \n6 \nbehavior to support disturbance analysis, model validation, performance verification, and \n7 \nbroader reliability assessments.  Prior to the applicable Service Commencement Date, \n8 \nphasor measurement recording and communications equipment must be installed on the \n9 \nTransmission Owner’s side of the Point of Withdrawal and become part of the \n10 \nTransmission Owner’s interconnection facilities. \n11 \nThe proposal also provides flexibility regarding the equipment used to satisfy the \n12 \nrequirement.  Existing or newly installed equipment, such as protective relays or digital \n13 \nfault recorders, may be used in place of a stand-alone PMU where they provide equivalent \n14 \nmeasurement quality, resolution, and time synchronization. \n15 \nQ. \nDOES \nTHE \nPROPOSAL \nPROVIDE \nGUIDANCE \nREGARDING \nTHE \n16 \nINSTALLATION OF PHASOR MEASUREMENT CAPABILITY FOR A LARGE \n17 \nLOAD? \n18 \nA. \nYes.  For Computational Loads subject to the phasor measurement requirements, the \n19 \nproposal provides guidance regarding both the location of the measurement capability and \n20 \nthe entity responsible for its installation. \n21 \nThe phasor measurement capability is generally required on the Transmission Owner’s side \n22 \nof the Point of Withdrawal so that MISO can obtain high-resolution, time-synchronized \n23"},{"page":32,"startToken":7473,"endToken":7729,"text":"Tab C \nPage 30 \n \nmeasurements of the facility’s interaction with the Transmission System.  The proposal \n1 \nalso provides flexibility in how this capability is provided.  Existing or newly installed \n2 \nequipment, including protective relays or other recording devices, may be used where they \n3 \nprovide measurement capability equivalent to a dedicated PMU. \n4 \nThe responsibility for installing and maintaining this capability is assigned to the \n5 \nTransmission Owner, at the expense of the Transmission Customer.  This differs from \n6 \nrequirements for data, models, forecasts, and other facility information, which rely on \n7 \ninformation within the knowledge or control of the Transmission Customer.  The phasor \n8 \nmeasurement requirement involves physical monitoring capability located on \n9 \ntransmission-side facilities that are owned and maintained by the Transmission Owner.  \n10 \nAssigning this responsibility to the Transmission Owner therefore aligns the obligation \n11 \nwith the entity that controls the facilities necessary to install, maintain, and integrate the \n12 \nmeasurement equipment with the applicable communications and monitoring \n13 \ninfrastructure. \n14 \n4. \nRamp Requirements \n15 \nQ. \nPLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED \n16 \nRAMP REQUIREMENTS.  \n17 \nA. \nThe reliability objective of ramp requirements is to manage the operational impacts that \n18 \ncan result when a Computational Load increases or decreases its demand rapidly during \n19 \nstable-state transitions. \n20 \nComputational Loads may have the capability to change significant amounts of demand \n21 \nover a relatively short period of time and, in some cases, to do so in a highly coordinated \n22 \nmanner.  Rapid changes of this magnitude can create short-term supply-demand \n23"},{"page":33,"startToken":7729,"endToken":7884,"text":"Tab C \nPage 31 \n \nimbalances, cause sudden changes in transmission power flows, and increase the \n1 \noperational actions needed to maintain reliable system conditions. \n2 \nEstablishing reasonable limits on the rate at which a Computational Load may increase or \n3 \ndecrease its demand provides an established operating envelope within which the \n4 \nTransmission Provider can maintain generation-load balance and ensure the coincident risk \n5 \nof multiple Computational Loads does not result in broader reliability impacts.  \n6 \n \n7 \nFigure 2: Ramp Rate Risk Profile \n8 \nQ. \nPLEASE DESCRIBE THE PROPOSED RAMP REQUIREMENTS.  \n9 \nA. \nThe proposed ramp requirements are intended to ensure that changes in Computational \n10 \nLoad demand occur at a rate that can be reliably accommodated by the Transmission \n11 \nSystem.  The requirements establish up- and down-ramp limits during stable-state \n12 \ntransitions, measured in aggregate across the applicable Points of Withdrawal, while \n13 \nallowing eligible generation or other resources to provide ramp smoothing.   \n14"},{"page":34,"startToken":7884,"endToken":8117,"text":"Tab C \nPage 32 \n \n5. \nRide-Through Requirements \n1 \nQ. \nPLEASE DESCRIBE THE RELIABILITY OBJECTIVE FOR THE PROPOSED \n2 \nRIDE-THROUGH REQUIREMENTS.  \n3 \nA. \nThe proposed ride-through requirements reduce the risk of unnecessary Computational \n4 \nLoad disconnection or rapid changes in Demand during voltage and frequency disturbances \n5 \nand to support predictable disturbance performance during credible Transmission System \n6 \nevents.  Computational Loads may include fast-acting power-electronic equipment and \n7 \ncontrols with dynamic operating behavior, and their response to Transmission System \n8 \ndisturbances may materially affect system performance, operational reliability, and post-\n9 \ncontingency recovery.  Establishing minimum ride-through performance expectations is \n10 \ntherefore intended to reduce the risk of significant or simultaneous changes in Demand and \n11 \nsupport overall system stability and post-disturbance recovery. \n12 \nConsistent with emerging industry practices and NERC guidance, the proposed ride-\n13 \nthrough requirements address three fundamental aspects of Computational Load \n14 \nperformance: continued connection and stable operation during disturbances within the \n15 \napplicable ride-through criteria, appropriate active power response while riding through \n16 \nvoltage and frequency disturbances, and active power recovery following disturbance \n17 \nclearance.  The technical basis and detailed performance criteria supporting these \n18 \nrequirements are described in MISO’s published Large Load Technical Compendium.9   \n19 \n \n9  \nSee MISO’s Interconnection Reliability Requirements for Large Load Technical Compendium, August 2026; \navailable at: \nhttps://cdn.misoenergy.org/20260827%20LLWG%20Item%2002c%20MISO%20Large%20Load%20Interconn\nection%20Reliability%20Requirements_Technical%20Compendium777982.pdf."},{"page":35,"startToken":8117,"endToken":8354,"text":"Tab C \nPage 33 \n \nQ. \nPLEASE DESCRIBE THE GENERAL PRINCIPLES UNDERLYING THE \n1 \nPROPOSED RIDE-THROUGH REQUIREMENTS.  \n2 \nA. \nThe proposed ride-through requirements apply at the applicable Point(s) of Withdrawal \n3 \nand establish the voltage and frequency conditions under which Computational Loads are \n4 \nrequired to remain connected to the Transmission System and continue operation.  When \n5 \nsystem conditions remain within the applicable ride-through criteria, Computational Loads \n6 \nare required to remain connected without unnecessary disconnection. \n7 \nThe requirements further establish expectations for Computational Load performance \n8 \nwhile riding through disturbances and following disturbance recovery.  During voltage \n9 \ndisturbances, the appropriate active power response may vary depending on the severity of \n10 \nthe disturbance, with greater flexibility in active power response during more severe \n11 \nvoltage depressions to support continued connection and stable operation.  Following \n12 \ndisturbance clearance, active power is expected to recover in a controlled and predictable \n13 \nmanner consistent with Transmission System reliability needs.  During frequency \n14 \ndisturbances, Computational Loads are expected to maintain predictable active power \n15 \nconsumption while riding through the disturbance in accordance with the applicable \n16 \nperformance requirements. \n17 \nThe proposed Tariff establishes the core ride-through obligation, while the technical basis \n18 \nand detailed performance criteria supporting MISO's proposal are described in MISO's \n19 \npublished Large Load Technical Compendium.  Detailed implementation, evaluation, and \n20 \ncompliance requirements will be established through MISO's applicable Business Practices \n21 \nand address the following:   \n22"},{"page":36,"startToken":8354,"endToken":8594,"text":"Tab C \nPage 34 \n \n• Applicability: Applies to Computational Loads subject to MISO’s ride-through \n1 \nrequirements. \n2 \n• Stay connected: Requires the facility to remain connected during qualifying voltage \n3 \nand frequency disturbances. \n4 \n• Stable operation: Requires the facility to maintain stable behavior during the \n5 \ndisturbance and avoid unnecessary tripping. \n6 \n• Post-disturbance recovery: Requires active power to recover in a controlled manner \n7 \nthat supports reliable Transmission System operation. \n8 \n• Demonstration of capability: Requires the Transmission Customer to provide models, \n9 \nstudies, equipment information, testing, or other evidence demonstrating compliance. \n10 \nAdditional detail can be found in the Large Load Technical Compendium.  \n11 \nV. \nSTAKEHOLDER ENGAGEMENT AND EFFECTIVE DATE \n12 \nQ. \nPLEASE DESCRIBE HOW THE STAKEHOLDER PROCESS INFORMED \n13 \nMISO’S IRR PROPOSAL. \n14 \nA. \nMISO has engaged in detailed discussions with stakeholders on Large Load issues since \n15 \n2024 in various stakeholder entities and workshops.  MISO first discussed Large Loads \n16 \nwith stakeholders in the context of EPR process improvements at the Planning Advisory \n17 \nCommittee (“PAC”) and Planning Subcommittee (“PSC”) in 2024 and 2025.  Moreover, \n18 \nsince 2024, MISO has discussed coordinating the MTEP and Definitive Planning Phases \n19 \n(“DPP”) processes to accommodate Large Loads at the PSC.  MISO additionally discussed \n20 \nLarge Load citing methodology at the November 18, 2025, Futures Redesign Workshop. \n21 \nMISO introduced the Large Load Interconnection Reliability Requirements at the Large \n22 \nLoads Workshop on January 30, 2026.  The workshop addressed the challenges associated \n23"},{"page":37,"startToken":8594,"endToken":8869,"text":"Tab C \nPage 35 \n \nwith reliably interconnecting large loads, focusing on defining reliability requirements and \n1 \nimproving the speed of integration while maintaining reliability to support member plans \n2 \nand goals.  Following the January 30th workshop, MISO discussed the Large Load \n3 \nInterconnection Reliability Requirements at the PAC and the Large Load Working Group \n4 \n(“LLWG”).10  \n5 \nAt the February 25, 2026, PAC, MISO proposed a definition of Large Load and provided \n6 \na high-level overview of the Large Load Interconnection Reliability Requirements.  MISO \n7 \nrequested stakeholder feedback on the Large Load definition.  At the April 20, 2026, \n8 \nLLWG, MISO provided a revised large load definition based on stakeholder feedback and \n9 \npresented the Large Load Interconnection Reliability Requirements.  MISO requested \n10 \nfeedback on the Large Load Interconnection Reliability Requirements.  At the April 22, \n11 \n2026, PAC, MISO shared the revised Large Load definition that had been shared \n12 \npreviously at the LLWG.  MISO additionally presented transition provisions it developed \n13 \nto address pending but unbuilt Large Load.  \n14 \nAt the May 14, 2026, LLWG, MISO responded to stakeholder feedback from the April 20 \n15 \nLLWG meeting, provided proposed Tariff language for the Large Load Interconnection \n16 \nReliability Requirements, and provided an updated Large Load definition.  In response to \n17 \nstakeholder feedback MISO revised the applicability language to provide additional clarity, \n18 \nincluded transitional provisions that offer flexibility during implementation, and \n19 \nincorporated a phased-in implementation to support readiness across customers and \n20 \nutilities.  MISO additionally updated its Large Load definition based on stakeholder \n21 \n \n10  A table listing the stakeholder meetings, including links to the presentations, is provided as Attachment A \nhereto."},{"page":38,"startToken":8869,"endToken":9148,"text":"Tab C \nPage 36 \n \nfeedback.  Specifically, in response to stakeholder feedback regarding MISO’s initial \n1 \nproposal allowing multiple Points of Interconnection (“POI”), MISO proposed only \n2 \nallowing multiple POIs if the ZGIA is located at one of the stations, i.e. Points of \n3 \nWithdrawal of a Large Load Campus.  MISO requested feedback on the Large Load \n4 \nInterconnection Reliability Requirements Tariff draft.  At the May 27, 2026, PAC, MISO \n5 \npresented the updated Large Load definition, including the revisions to applicability and \n6 \ntransitional provisions, to ensure clarity on implementation of Interconnection Reliability \n7 \nRequirements.  \n8 \nAt the June 10, 2026, LLWG, MISO responded to stakeholder feedback and presented the \n9 \nTariff redlines for the Large Load Interconnection Reliability Requirements based on \n10 \nstakeholder feedback.  Stakeholder feedback significantly influenced the revised Tariff \n11 \nlanguage, particularly around applicability, transition provisions, and requirement specific \n12 \nlanguage.  Namely, MISO: (1) updated Tariff and BPM language to clarify treatment of \n13 \nexisting loads, any expansions, and the applicability date; (2) updated the transitional \n14 \nprovision to allow more flexibility; (3) updated the Applicability section to distinguish \n15 \nbetween Computational and Non-Computational Loads, and applied only ramp, PMU, \n16 \nride-through, and advanced modeling requirements to Computational Loads; (4) updated \n17 \nthe Transmission Customer definition to clearly define roles and responsibilities; (5) \n18 \nexpanded process detail across several Tariff sections, including applicability screening, \n19 \npre-MTEP/EPR timing, and transitional provisions for inflight projects; and (6) clarified \n20 \nthat Tariff applicability for the ramp, PMU, and ride-through requirements align with \n21 \nNERC’s emerging definition of Computational Loads and NERC’s Load Modeling Task \n22 \nForce technical discussions.  MISO additionally revised the Large Load definition by \n23"},{"page":39,"startToken":9148,"endToken":9428,"text":"Tab C \nPage 37 \n \nremoving the Large Load Campus construct in response to stakeholder feedback.  In \n1 \naddition, MISO published a technical compendium outlining the technical details of the \n2 \nproposal that will be included in the Business Practice Manual. \n3 \nAt the June 29, 2026, LLWG, MISO reviewed Tariff redlines for the Large Load definition \n4 \nand Large Load Interconnection Reliability Requirements based on stakeholder feedback.  \n5 \nStakeholder feedback significantly influenced the revised Tariff language, specifically \n6 \naround applicability, transition provisions, and requirement specific language.  MISO \n7 \nadditionally described how its proposed framework is consistent with the Commission’s \n8 \nShow Cause Order and noted that the framework is also in line with the emerging NERC \n9 \nguidance and broader industry practices.  Furthermore, MISO described how its \n10 \ninterconnection framework relies on the Tariff to set requirements and its BPM to guide \n11 \nconsistent implementation, noting that it is targeting Large Load BPM development to take \n12 \nplace from June to September 2026.  MISO requested stakeholder feedback on the Tariff \n13 \nupdates.  \n14 \nMISO separately presented on Large Load Telemetry and PMU Requirements, with the \n15 \npurpose of establishing SCADA telemetry requirements for Large Loads, and PMU \n16 \nrequirements for Computational Loads to provide situational awareness and support system \n17 \nreliability across the MISO footprint.  Specifically, MISO will require real-time SCADA \n18 \ntelemetry from large loads via ICCP to support real-time monitoring and analysis, and real-\n19 \ntime SCADA telemetry from generation behind same POI as Large Load will also be \n20 \nrequired for real-time monitoring and optimal market dispatch; generator telemetry shall \n21 \nnot be netted with load.  Furthermore, MISO will require PMU or similar device at the \n22"},{"page":40,"startToken":9428,"endToken":9738,"text":"Tab C \nPage 38 \n \nLarge Load with computational load to support dynamic monitoring in real-time.  MISO \n1 \nrequested stakeholder feedback on The Large Load Telemetry and PMU Requirements.  \n2 \nMISO also presented on Large Load Operation Forecast Requirements, proposing that \n3 \nLarge Loads submit short-term forecasts to reliably manage their variability.  In particular, \n4 \nMISO proposed Large Load forecast submission at the CP node level, on hourly and 5-\n5 \nminute cadences aligned with commitment and dispatch and defined forecast error \n6 \nmeasurement and submission monitoring, noting that it is considering mechanisms to \n7 \nincentivize accurate submissions.  MISO highlighted that NERC has called for short-term \n8 \nforecast submissions from Large Loads, that SPP requires them today, and that CAISO has \n9 \nidentified the same visibility gap.  MISO requested stakeholder feedback on this topic.   \n10 \nAt the July 15, 2026, PAC, MISO informed stakeholders that the Steering Committee \n11 \napproved reassignment of the Large Load definition to the LLWG.  At the July 16, 2026, \n12 \nLLWG, MISO noted in its liaison report that there is a transition plan to manage active \n13 \nprojects, explaining that a key consideration has been ensuring reliability while avoiding \n14 \ndisruption to loads at a late stage of development.  MISO noted that this consideration is \n15 \nreflected in the Commission’s Show Cause Order and that it has received stakeholder \n16 \nfeedback indicating that its current proposal does not achieve this directive.  Therefore, \n17 \nMISO revised its approach to apply full requirements only to loads that MISO has not yet \n18 \napproved through its planning processes, and to apply visibility requirements to a broader \n19 \nset of large loads.   \n20 \nMISO also discussed the Large Load BPM framework and development, focusing on \n21 \nchanges for interconnection and operational reliability requirements.  MISO proposed a \n22 \n“hub-and-spoke” BPM framework consisting of a new Large Load BPM, the “hub,” \n23"},{"page":41,"startToken":9738,"endToken":10016,"text":"Tab C \nPage 39 \n \nsupported by updates to existing BPMs and manuals, the “spokes.”  MISO requested \n1 \nstakeholder feedback on the Large Load BPM framework.  \n2 \nAt the July 27, 2026, LLWG, MISO reviewed Tariff redlines for the Large Load definition \n3 \nand Large Load Interconnection Reliability Requirements based on stakeholder feedback.  \n4 \nMISO noted that its BPM development timeline has been extended to December 2026.  \n5 \nMISO also provided updates to its Technical Compendium.  MISO requested stakeholder \n6 \nfeedback on its Tariff updates.  \n7 \nAt the August 12, 2026, LLWG, MISO reviewed the informal stakeholder feedback on the \n8 \nreliability requirement updates provided at the July 27, 2026, LLWG.  MISO discussed the \n9 \nadditional refinements it made to its proposal based on informal stakeholder feedback.  \n10 \nAs described above, throughout the stakeholder engagement period, MSO has solicited \n11 \nfeedback from stakeholders and provided written and verbal responses to that feedback.  \n12 \nMISO’s stakeholder process has contributed to substantive design changes in MISO’s \n13 \nfiling and the collaborative process with stakeholders resulted in a comprehensive proposal \n14 \nfor addressing Large Loads in the MISO footprint.  MISO appreciates the willingness of \n15 \nall its stakeholders and state regulators to review and comment on this final proposal, which \n16 \nMISO believes reasonably accommodates concerns raised by stakeholders. \n17 \nIn addition to the stakeholder meetings, MISO’s external affairs and large load teams have \n18 \nmet with individual stakeholders and RERRAs to inform them about MISO’s proposal and \n19 \nanswer questions.  MISO is aware that this is a pressing topic in the MISO footprint and \n20 \ncommits to working with stakeholders and RERRAs to address any questions that may \n21 \narise. \n22"},{"page":42,"startToken":10016,"endToken":10090,"text":"Tab C \nPage 40 \n \nQ. \nWHAT EFFECTIVE DATE HAS MISO REQUESTED FOR THE LARGE LOAD \n1 \nINTERCONNECTION REFORM PROPOSAL?  \n2 \nA. \nMISO has requested a proposed effective date of December 4, 2026.  This is the day after \n3 \nwhich the MISO Board is expected to approve the MTEP 2026 projects and aligns with the \n4 \nIRR transition provisions described above.    \n5 \nVI. \nCONCLUSION \n6 \nQ. \nDOES THIS CONCLUDE YOUR TESTIMONY? \n7 \nA. \nYes. \n8"},{"page":43,"startToken":10090,"endToken":10208,"text":"Affidavit of Beibei Li \n  \nCOUNTY OF HAMILTON \n) \n) \nSTATE OF INDIANA \n) \nBeibei Li, being duly sworn, deposes and states that she prepared the Prepared Direct \nTestimony of Beibei Li, and the statements contained therein are true and correct to the best of \nher knowledge and belief. \nae) \nBeibei Li   \nSUBSCRIBED AND SWORN BEFORE ME, this WU day of August, 2026. \n4’ \nbw Le AA AVuL- { \n    \noiedy, \nJENNIFER L MILLER \nA \nSos\" \nLE \n; \nE \n(Notary Phblic Signature) \naN A Notary Public, State of Indiana \nPSEALI DE \n° \nA \nNUTT \nzy \nBoane County \noe \nae xs Commission Number NPO697079 \n“afMriers \nMy Commission Expires \nAw \nFebruary 22, 2033 \n  \n  \n  \nCommissioned in \nDoare \n  \ncounty. \nCommission Number; \nNP O97 0'79 \n  \nCommission Expires: \nKerman, 2, 0D D"},{"page":44,"startToken":10208,"endToken":10359,"text":"1 \nAttachment A – Table of Stakeholder Meetings and Materials \nMEETING DATE \nMATERIALS \nJanuary 30, 2026 Large Load Workshop \nLarge Load Additions Workshop \nFebruary 25, 2026 PAC \nLarge Load Interconnection Reliability \nRequirements (PAC-2024-1) \nApril 20, 2026 LLWG \nLarge Load Overview \n \nNew Large Load Issue Submissions \n \nLarge Load Interconnection Reliability \nRequirements (LLWG) \nApril 22, 2026 PAC \nPAC April 2026: PAC: Large Load Definition \n(PAC-2024-1) \nMay 14, 2026 LLWG \nLarge Load Interconnection Reliability \nRequirements (LLWG) \nMay 27, 2026 PAC \nLarge Load Definition Update \nJune 10, 2026 LLWG \nLarge Load Interconnection Reliability \nRequirements (LLWG) \n \nInterconnection Reliability Requirements \nTechnical Compendium  \nJune 29, 2026 LLWG  \nLarge Load Interconnection Reliability \nRequirements \n(LLWG) \n \nLarge Load Telemetry and PMU \nRequirements \n \nLarge Load Operational Forecast \nRequirements \n \nInterconnection Reliability \nRequirements for Large Load Technical \nCompendium  \nJuly 15, 2026 PAC  \nLiaison Report \nJuly 16, 2026 LLWG \nLiaison Report \n \nLarge Load BPM Development \n(LLWG) \nJuly 27, 2026 LLWG \nLarge Load Interconnection Reliability \nRequirements \n(LLWG)"},{"page":45,"startToken":10359,"endToken":10398,"text":"2 \nAugust 12, 2026 LLWG  \nLarge Load Interconnection Reliability \nRequirements \n(LLWG) \nAugust 27, 2026 LLWG \nLarge Load Interconnection Reliability \nRequirements Clean Tariff (LLWG) \n \nLarge Load Interconnection Reliability \nRequirements Redline Tariff (LLWG) \n \nLarge Load Interconnection Reliability \nRequirements Redline comparison (LLWG)"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":17,"startToken":0,"endToken":38},{"p":3,"at":17,"title":"I. PROFESSIONAL BACKGROUND AND QUALIFICATIONS","method":"printed heading","endPage":3,"endAt":194,"startToken":38,"endToken":62},{"p":3,"at":194,"title":"A. My name is Beibei Li. I am the Senior Manager of Strategic Assessment for the","method":"printed heading","endPage":3,"endAt":1148,"startToken":62,"endToken":208},{"p":3,"at":1148,"title":"A. As Senior Manager of Strategic Assessment, I lead MISO’s evaluation and framing of","method":"printed heading","endPage":4,"endAt":17,"startToken":208,"endToken":263},{"p":4,"at":17,"title":"II. PURPOSE OF TESTIMONY","method":"printed heading","endPage":4,"endAt":94,"startToken":263,"endToken":277},{"p":4,"at":94,"title":"A. The purpose of my testimony is to support MISO’s proposal to apply a defined set of","method":"printed heading","endPage":4,"endAt":407,"startToken":277,"endToken":333},{"p":4,"at":407,"title":"A. As discussed below in greater detail, the IRR proposal defines “Large Load” and is","method":"printed heading","endPage":5,"endAt":136,"startToken":333,"endToken":620},{"p":5,"at":136,"title":"III. THE RISE OF LARGE LOADS AND","method":"printed heading","endPage":5,"endAt":295,"startToken":620,"endToken":647},{"p":5,"at":295,"title":"A. The MISO region is experiencing a significant increase in both the scale and pace of Large","method":"printed heading","endPage":5,"endAt":1227,"startToken":647,"endToken":784},{"p":5,"at":1227,"title":"A. Accommodating the accelerated interconnection of Large Loads requires MISO to ensure","method":"printed heading","endPage":6,"endAt":1356,"startToken":784,"endToken":1033},{"p":6,"at":1356,"title":"A. The North American Electric Reliability Corporation (“NERC”), through the Large Loads","method":"printed heading","endPage":9,"endAt":85,"startToken":1033,"endToken":1673},{"p":9,"at":85,"title":"A. MISO is experiencing increasing levels of Large Load development being evaluated","method":"printed heading","endPage":9,"endAt":1241,"startToken":1673,"endToken":1826},{"p":9,"at":1241,"title":"A. Yes. In recent years, MISO established the Expedited Resource Addition Study (“ERAS”)","method":"printed heading","endPage":10,"endAt":86,"startToken":1826,"endToken":1934},{"p":10,"at":86,"title":"A. While these initiatives provide important benefits, they do not fully address the reliability","method":"printed heading","endPage":10,"endAt":958,"startToken":1934,"endToken":2050},{"p":10,"at":958,"title":"A. MISO is proposing to implement a reliability-based framework to support the","method":"printed heading","endPage":11,"endAt":17,"startToken":2050,"endToken":2148},{"p":11,"at":17,"title":"IV. MISO’S LARGE LOAD INTERCONNECTION RELIABILITY","method":"printed heading","endPage":11,"endAt":199,"startToken":2148,"endToken":2173},{"p":11,"at":199,"title":"A. MISO’s IRR proposal establishes a reliability framework surrounding Large Load","method":"printed heading","endPage":13,"endAt":193,"startToken":2173,"endToken":2652},{"p":13,"at":193,"title":"A. DEFINITIONS","method":"printed heading","endPage":13,"endAt":310,"startToken":2652,"endToken":2670},{"p":13,"at":310,"title":"A. The following definitions are provided to support consistent interpretation of the reliability","method":"printed heading","endPage":14,"endAt":92,"startToken":2670,"endToken":2879},{"p":14,"at":92,"title":"A. MISO developed the proposed Large Load definition through review of emerging industry","method":"printed heading","endPage":14,"endAt":1431,"startToken":2879,"endToken":3082},{"p":14,"at":1431,"title":"A. MISO determined that 50 MW is a reasonable threshold based on industry precedent,","method":"printed heading","endPage":15,"endAt":858,"startToken":3082,"endToken":3246},{"p":15,"at":858,"title":"A. MISO defines Computational Load to distinguish a subset of Large Loads that may exhibit","method":"printed heading","endPage":16,"endAt":645,"startToken":3246,"endToken":3488},{"p":16,"at":645,"title":"A. MISO’s proposed definition of Computational Load is closely aligned with NERC’s","method":"printed heading","endPage":17,"endAt":20,"startToken":3488,"endToken":3657},{"p":17,"at":20,"title":"B. SCOPE AND APPLICABILITY","method":"printed heading","endPage":17,"endAt":102,"startToken":3657,"endToken":3671},{"p":17,"at":102,"title":"A. This filing proposes reliability requirements and a reliability-based framework applicable","method":"printed heading","endPage":18,"endAt":1117,"startToken":3671,"endToken":4018},{"p":18,"at":1117,"title":"A. No. This IRR proposal focuses specifically on reliability requirements applicable to Large","method":"printed heading","endPage":18,"endAt":1408,"startToken":4018,"endToken":4063},{"p":18,"at":1408,"title":"A. The proposed requirements in this filing apply to the Large Load as set forth in the Tariff","method":"printed heading","endPage":19,"endAt":876,"startToken":4063,"endToken":4267},{"p":19,"at":876,"title":"A. The IRR proposal establishes that the Transmission Customer taking Transmission Service","method":"printed heading","endPage":20,"endAt":200,"startToken":4267,"endToken":4429},{"p":20,"at":200,"title":"A. Requiring the Transmission Customer to prove compliance with the requirements","method":"printed heading","endPage":20,"endAt":1288,"startToken":4429,"endToken":4592},{"p":20,"at":1288,"title":"C. TRANSITION PROVISIONS","method":"printed heading","endPage":20,"endAt":1496,"startToken":4592,"endToken":4621},{"p":20,"at":1496,"title":"A. The IRR Filing includes transition provisions that are intended to provide certainty to","method":"printed heading","endPage":21,"endAt":709,"startToken":4621,"endToken":4781},{"p":21,"at":709,"title":"A. For purposes of the transition provisions, Load will satisfy the “MTEP/EPR Condition” if","method":"printed heading","endPage":21,"endAt":1224,"startToken":4781,"endToken":4873},{"p":21,"at":1224,"title":"A. Under current processes, MISO does not have a Load interconnection process. As such,","method":"printed heading","endPage":22,"endAt":171,"startToken":4873,"endToken":4995},{"p":22,"at":171,"title":"A. The June 18, 2026, date coincides with the Commission’s issuance of the Show Cause","method":"printed heading","endPage":22,"endAt":878,"startToken":4995,"endToken":5114},{"p":22,"at":878,"title":"A. MISO proposes to implement the following transition provisions:","method":"printed heading","endPage":23,"endAt":1353,"startToken":5114,"endToken":5489},{"p":23,"at":1353,"title":"A. MISO provides a potential exemption from the ride-through requirements for certain","method":"printed heading","endPage":24,"endAt":1143,"startToken":5489,"endToken":5734},{"p":24,"at":1143,"title":"A. No. A Large Load, or a portion of a Large Load, that does not meet the MTEP/EPR","method":"printed heading","endPage":24,"endAt":1390,"startToken":5734,"endToken":5778},{"p":24,"at":1390,"title":"A. MISO developed the transition provisions through a deliberate process that considered both","method":"printed heading","endPage":25,"endAt":483,"startToken":5778,"endToken":5904},{"p":25,"at":483,"title":"D. LARGE LOAD RELIABILITY REQUIREMENTS","method":"printed heading","endPage":25,"endAt":591,"startToken":5904,"endToken":5918},{"p":25,"at":591,"title":"A. The proposed framework consists of the following categories of reliability requirements","method":"printed heading","endPage":26,"endAt":163,"startToken":5918,"endToken":6105},{"p":26,"at":163,"title":"A. The objective of the proposed data and modeling requirements is to ensure sufficient","method":"printed heading","endPage":26,"endAt":1535,"startToken":6105,"endToken":6276},{"p":26,"at":1535,"title":"A. The proposed data requirements are intended to ensure that MISO has sufficient","method":"printed heading","endPage":27,"endAt":907,"startToken":6276,"endToken":6441},{"p":27,"at":907,"title":"A. The proposed modeling requirements are intended to ensure that MISO has accurate and","method":"printed heading","endPage":28,"endAt":159,"startToken":6441,"endToken":6590},{"p":28,"at":159,"title":"A. Large Loads can change system conditions rapidly, and unlike traditional demand, their","method":"printed heading","endPage":28,"endAt":505,"startToken":6590,"endToken":6638},{"p":28,"at":505,"title":"A. The proposed short and medium-term forecasting requirements are intended to provide","method":"printed heading","endPage":29,"endAt":18,"startToken":6638,"endToken":6793},{"p":29,"at":18,"title":"A. The objective of the proposed Telemetry and PMU requirements is to provide MISO with","method":"printed heading","endPage":30,"endAt":310,"startToken":6793,"endToken":7095},{"p":30,"at":310,"title":"A. The telemetry requirements are intended to provide MISO with reliable, real-time visibility","method":"printed heading","endPage":31,"endAt":302,"startToken":7095,"endToken":7267},{"p":31,"at":302,"title":"A. Yes. The PMU requirements apply specifically to Computational Loads and are intended","method":"printed heading","endPage":31,"endAt":1373,"startToken":7267,"endToken":7414},{"p":31,"at":1373,"title":"A. Yes. For Computational Loads subject to the phasor measurement requirements, the","method":"printed heading","endPage":32,"endAt":1305,"startToken":7414,"endToken":7654},{"p":32,"at":1305,"title":"A. The reliability objective of ramp requirements is to manage the operational impacts that","method":"printed heading","endPage":33,"endAt":627,"startToken":7654,"endToken":7821},{"p":33,"at":627,"title":"A. The proposed ramp requirements are intended to ensure that changes in Computational","method":"printed heading","endPage":34,"endAt":151,"startToken":7821,"endToken":7905},{"p":34,"at":151,"title":"A. The proposed ride-through requirements reduce the risk of unnecessary Computational","method":"printed heading","endPage":35,"endAt":121,"startToken":7905,"endToken":8134},{"p":35,"at":121,"title":"A. The proposed ride-through requirements apply at the applicable Point(s) of Withdrawal","method":"printed heading","endPage":36,"endAt":777,"startToken":8134,"endToken":8456},{"p":36,"at":777,"title":"V. STAKEHOLDER ENGAGEMENT AND EFFECTIVE DATE","method":"printed heading","endPage":36,"endAt":916,"startToken":8456,"endToken":8476},{"p":36,"at":916,"title":"A. MISO has engaged in detailed discussions with stakeholders on Large Load issues since","method":"printed heading","endPage":42,"endAt":122,"startToken":8476,"endToken":10036},{"p":42,"at":122,"title":"A. MISO has requested a proposed effective date of December 4, 2026. This is the day after","method":"printed heading","endPage":42,"endAt":360,"startToken":10036,"endToken":10077},{"p":42,"at":360,"title":"VI. CONCLUSION","method":"printed heading","endPage":42,"endAt":365,"startToken":10077,"endToken":10078},{"p":42,"at":365,"title":"CONCLUSION","method":"printed heading","endPage":42,"endAt":423,"startToken":10078,"endToken":10087},{"p":42,"at":423,"title":"A. Yes.","method":"printed heading","endPage":44,"endAt":3,"startToken":10087,"endToken":10209},{"p":44,"at":3,"title":"Attachment A – Table of Stakeholder Meetings and Materials","method":"printed heading","endPage":45,"endAt":342,"startToken":10209,"endToken":10398}]}