EL26-70-000 · 2026-08-03 · Midcontinent Independent System Operator Inc.MISO Transmission Owners

MISO requests more time to answer the June 18 show cause order

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
Midcontinent Independent System Operator, Inc., et al. 
 
 
) 
) 
) 
 
Docket No. EL26-70-000 
 
MOTION OF THE MIDCONTINENT INDEPENDENT SYSTEM OPERATOR, INC.  
AND THE MISO TRANSMISSION OWNERS  
TO HOLD PROCEEDING IN ABEYANCE AND REQUEST FOR SHORTENED 
COMMENT PERIOD AND EXPEDITED TREATMENT 
 
 
Pursuant to Rules 212 and 20081 of the Federal Energy Regulatory Commission’s (“FERC” 
or “Commission”) Rules of Practice and Procedure, and as invited by the Commission’s June 18, 
2026 “Order Instituting Proceeding under Section 206 of the Federal Power Act,”2 the 
Midcontinent Independent System Operator, Inc. (“MISO”) and the MISO Transmission Owners3 
 
1  
18 C.F.R. §§ 385.212, 385.2008 (2026). 
2  
Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212, at P 37 (2026) (“The Commission will consider requests by MISO and/or the 
Transmission Owners to hold, for up to 90 days, all or certain aspects of this [Federal Power Act (“FPA”)] 
section 206 proceeding in abeyance, including the deadline to respond to this order… to work through the 
stakeholder processes to develop FPA section 205 filings to revise the Tariff to address the issues raised in this 
order.”) (“Show Cause Order” or “SCO”). 
3  
The MISO Transmission Owners for this filing include: AEP Indiana Michigan Transmission Company; 
Ameren Services Company, as agent for Union Electric Company d/b/a Ameren Missouri, Ameren Illinois 
Company d/b/a Ameren Illinois and Ameren Transmission Company of Illinois; American Transmission 
Company LLC (“ATC”); Big Rivers Electric Corporation; Central Minnesota Municipal Power Agency; 
Citizens Electric Corporation; City Water, Light & Power (Springfield, IL); Cleco Power LLC; Cooperative 
Energy; Dairyland Power Cooperative; Duke Energy Business Services, LLC for Duke Energy Indiana, LLC; 
East Texas Electric Cooperative, Inc.; Entergy Arkansas, LLC; Entergy Louisiana, LLC; Entergy Mississippi, 
LLC; Entergy New Orleans, LLC; Entergy Texas, Inc.; Great River Energy; GridLiance Heartland LLC; 
Hoosier Energy Rural Electric Cooperative, Inc.; Indiana Municipal Power Agency; Indianapolis Power & Light 
Company d/b/a AES Indiana; International Transmission Company d/b/a ITCTransmission; ITC Midwest LLC; 
Lafayette Utilities System; Michigan Electric Transmission Company, LLC; MidAmerican Energy Company; 
Minnesota Power (and its subsidiary Superior Water, L&P)(ALLETE, Inc.); Missouri River Energy Services; 
Montana-Dakota Utilities Co.; Northern Indiana Public Service Company LLC; Northern States Power 
Company, a Minnesota corporation, and Northern States Power Company, a Wisconsin corporation, subsidiaries 
of Xcel Energy Inc.; Northwestern Wisconsin Electric Company; Otter Tail Power Company; Prairie Power, 
Inc.; Republic Transmission, LLC; Southern Illinois Power Cooperative; Southern Indiana Gas & Electric 
Company (d/b/a CenterPoint Energy Indiana South); Southern Minnesota Municipal Power Agency; Wabash 
Valley Power Association, Inc.; and Wolverine Power Supply Cooperative, Inc.

2 
(“MISO Transmission Owners”) respectfully submit this Motion to Hold this Proceeding in 
Abeyance for 90 days, up to and including November 16, 2026 (“Motion”).  The Motion is 
necessary to permit MISO and the MISO Transmission Owners to continue the MISO stakeholder 
process to develop and submit FPA section 2054 filings that address the concerns expressed in the 
Show Cause Order.5  The Show Cause Order raises a number of concerns regarding the apparent 
absence from MISO’s Open Access Transmission, Energy and Operating Reserve Markets Tariff 
(“Tariff”) of provisions specific to the reliable interconnection, operation, and service to large loads 
in the MISO region.  MISO, the MISO Transmission Owners, and the MISO stakeholder 
community have already undertaken significant efforts to promote the efficient integration and 
reliable interconnection of large loads. These efforts address a number of the Commission’s 
concerns expressed in the Show Cause Order.  While the timeline would remain tight, granting this 
Motion would allow MISO and the MISO Transmission Owners to respond to the remaining 
concerns in a manner that recognizes the unique characteristics of the MISO region, with additional 
coordination between MISO, the MISO Transmission Owners, the Organization of MISO States, 
Inc. (“OMS”), and the MISO stakeholder community.   
I. 
EXECUTIVE SUMMARY 
As MISO and its member utilities have seen, and as the Show Cause Order affirms, the 
MISO region (and much of the country) is experiencing a significant influx of large load additions, 
which present both significant opportunities and challenges for the region.  MISO and the MISO 
Transmission Owners appreciate the direction and regional flexibility the Commission provided 
 
4  
16 U.S.C. § 824d.   
5  
ATC joins the MISO Transmission Owners and MISO in this motion in part.  ATC intends to file a separate, 
individual filing pursuant to section 205 of the Federal Power Act that will be responsive to some of the 
Commission’s directives in the Show Cause Order.  ATC will clearly indicate whether it joins the MISO 
Transmission Owners and MISO in each future section 205 filing.

3 
in the Show Cause Order to facilitate the timely and reliable addition of large loads to the MISO 
transmission system without unfair cost shifts.  Developing new tools and processes to 
accommodate the challenges of large load integration has been, and continues to be, a primary goal 
of MISO and the MISO Transmission Owners.   
Prior to the issuance of the Show Cause Order, MISO, in collaboration with the MISO 
Transmission Owners, OMS, and other stakeholders, identified and implemented multiple 
solutions to facilitate speed to reliable power.  Two already-implemented solutions are the 
Expedited Resource Addition Study (“ERAS”) process to accelerate generator interconnection for 
near-term resource adequacy needs, and improving the MISO Transmission Expansion Plan’s 
(“MTEP”) Expedited Project Review (“EPR”) process to enable the quick study and approval of 
transmission upgrades necessary for the addition of large loads.   
MISO also created the Large Load Working Group (“LLWG”) in March 2026 to provide a 
dedicated and consolidated stakeholder forum to prioritize and focus efforts to both identify critical 
issues and develop corresponding solutions to integrate large loads reliably and cost effectively.6  
The LLWG, like other MISO stakeholder processes, allows for the consideration of issues and 
solutions developed not only by MISO staff but also by stakeholders.  The stakeholder issue 
submission process in the LLWG is an important element for MISO’s development of solutions 
for effectively serving large loads because, as the Commission is aware,7 stakeholders are well 
 
6  
The MISO Steering Committee approved creation of the LLWG in a special meeting on March 16, 2026. 
7  
See, e.g., Champion Energy Marketing LLC v. PJM Interconnection, L.L.C., 153 FERC ¶ 61,059 at P 31 (2015) 
(dismissing a complaint against certain cost allocation provisions of PJM Interconnection L.L.C’s (“PJM”) 
tariff, ruling that the complainant “should first raise its concerns and potential resolution through the PJM 
stakeholder process or in the Commission’s ongoing price formation proceeding.” ); CSOLAR IV South LLC v. 
Cal.  Indep. Sys. Operator, Corp., 142 FERC ¶ 61,250, at P 45 (2013) (“While we understand the business risk 
articulated by CSOLAR Entities and CalWEA regarding the uncertainty that phased generation projects may 
encounter is a genuine concern, we nevertheless agree with [California Independent System Operator, Corp.] 
that addressing these issues in the stakeholder process is superior to attempting to resolve them in a contested 
proceeding at the Commission.”); N.Y. Indep. Sys. Operator, Inc., 126 FERC ¶ 61,046, at P 54 (2009) (a 
stakeholder’s proposal submitted in a FERC proceeding “should be presented to and discussed among

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situated to identify solutions to some of the current challenges for large load integration.  MISO 
affords equal consideration and deliberation in the LLWG to recommended solutions identified by 
all stakeholders.  
Through this collaborative stakeholder forum, MISO has developed a prioritized work plan 
to accelerate consideration of the challenges presented by the rapid growth of large load in the 
MISO region.  The Show Cause Order referenced many of the items in the MISO workplan, which 
helps reinforce those efforts and provides further guidance that will help drive timely solutions.    
As part of this work plan, and as described in more detail below, MISO and stakeholders 
have developed designs and/or draft Tariff language for several additional solutions, including: (1) 
the Zero Injection Generator Interconnection Agreement (“ZGIA”) and related study process, 
which will provide a Tariff-defined process for co-location of generation and load; (2) a new 
definition of large load; (3) interconnection reliability requirements to facilitate the reliable 
interconnection and operation of large loads; (4) a firm step up service to provide a pathway to 
energize a portion of a large load prior to full interconnection and upgrade completion; and (5) a 
parallel study process for large load and generation resources (i.e., Load Addition and Resource 
Study process or “LARS”), which was discussed in MISO’s Informational Report on Resource 
Adequacy filed in this docket.8   
 
stakeholders and filed as a section 205 proposal, not unilaterally presented to the Commission.”); New England 
Power Pool, 107 FERC ¶ 61,135, at P 24 (2004) (“We find persuasive [New England Power Pool] and [ISO 
New England, Inc.’s (‘ISO-NE’)] argument that NRG’s suggested revisions have not been vetted through the 
stakeholder process and could impact various participants.  NRG should use ISO-NE’s internal stakeholder 
mechanisms, such as one of the standing Technical Committees, to debate and consider the impact of its 
suggested changes on the energy markets.”); Consolidated Edison Company of New York, Inc., 95 FERC ¶ 
61,216, at 61,719 (2001) (“We strongly encourage market participants to use the stakeholder process, especially 
in this type of situation, i.e., where a market participant seeks to modify market measures that impact all market 
participants.”) (emphasis added). 
8  
Ltr. to Secretary Reese re: Informational Report, Docket No. EL26-70-000 (July 20, 2026).

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MISO and the MISO Transmission Owners acknowledge that several issues identified in 
the Show Cause Order were not in MISO’s original workplan, as the initial workplan reflected the 
more pressing and needed solutions, and therefore, respectfully request a 90-day abeyance to 
recalibrate the workplan and work through the stakeholder processes to develop regionally tailored 
FPA section 205 filings to revise the Tariff to address the issues identified in the Show Cause Order.  
The current, imminent compliance deadline in the Show Cause Order effectively prohibits the full 
development and robust consideration of any potential stakeholder solutions to integrating large 
loads.  The requested abeyance will afford stakeholders the necessary time to identify and discuss 
creative solutions and will then afford MISO and the MISO Transmission Owners the time 
necessary to formalize any Tariff and business practice revisions necessary to implement such 
solutions consistent with the guidance provided in the Show Cause Order. 
As stated above, the guidance from the Commission in the Show Cause Order provides an 
opportunity for MISO and the MISO Transmission Owners to move these new initiatives forward 
quickly with solutions leveraging MISO and the MISO Transmission Owners section 205 filings 
rights.  MISO and the MISO Transmission Owners are committed to bringing FPA section 205 
solutions to the Commission as contemplated in the Show Cause Order in a timely, pragmatic, and 
responsible manner consistent with the needs of the region.  
II. 
MISO SHOW CAUSE PROCEEDING  
The Show Cause Order identifies an unprecedented increase in requests for transmission 
service to serve large load, as well as the growing interest in the co-location of loads with 
generation facilities (i.e., co-location arrangements), while acknowledging the challenges 
associated with providing the transmission service to reliably serve the ongoing influx of large

6 
loads.9  The Show Cause Order states that there is a lack of clarity and consistency in Regional 
Transmission Organization or Independent System Operators’ tariffs regarding the rates, terms, 
and conditions of service that apply to flexible large loads, co-location arrangements, load with 
behind the meter generation, and generating facilities with electrically proximate large load or co-
located load.10  Ultimately, the Show Cause Order directs MISO and the MISO Transmission 
Owners to: 
(1) show cause as to why the Tariff remains just and reasonable and not 
unduly discriminatory or preferential without provisions addressing: 
 
(a) the application process, study procedures, and ongoing 
operational requirements that apply to Eligible Customers seeking 
transmission service on behalf of large loads; 
 
(b) additional transparency concerning the Network Upgrade costs 
to provide transmission service to Eligible Customers on behalf of 
large loads, a pro forma cost recovery agreement between MISO, 
the relevant transmission owner, and Eligible Customer taking 
transmission service on behalf of the large load to mitigate the risk 
of cost shifting among transmission customers, and a mechanism to 
ensure such payments are appropriately credited toward 
transmission owners’ transmission revenue requirements consistent 
with the Commission's cost-of-service regulations; 
 
(c) the rates, terms, and conditions of service that apply to co-
location arrangements; 
 
(d) transmission services that reflect Eligible Customers taking 
transmission service on behalf of co-located loads, load with 
behind the meter generation, and flexible large loads that are 
willing and able to limit their use of the transmission system under 
certain conditions; and 
 
(e) the rates, terms, and conditions of service applicable to 
interconnection customers serving electrically proximate large load 
or co-located load; or 
 
 
9  
SCO at P 1.  
10  Id.

7 
(2) explain what changes to the Tariff would remedy the identified concerns 
if the Commission were to determine that the Tariff has in fact become 
unjust and unreasonable or unduly discriminatory or preferential and, 
therefore, proceeds to establish a replacement Tariff.11 
   
 
The Commission ordered that MISO and the MISO Transmission Owners address these 
issues in a filing due within 60 days; however, the Commission stated that it would consider 
requests from MISO and the MISO Transmission Owners to hold the proceeding in abeyance, for 
up to 90 days, to provide MISO and the MISO Transmission Owners time while they work through 
the stakeholder processes to develop FPA section 205 filings to revise the Tariff to address the 
issues raised in the Show Cause Order.12    
III. 
REQUEST FOR ABEYANCE 
The Show Cause Order demonstrates the high priority the Commission has placed on 
ensuring that jurisdictional regional grid operators work quickly to meet the challenge of 
integrating large loads to support the artificial intelligence and manufacturing related national 
security and economic opportunity goals.  Notwithstanding the need for speed, the Commission 
invited MISO and the MISO Transmission Owners to seek to hold the show cause proceeding in 
abeyance, for up to 90 days, to provide MISO and the MISO Transmission Owners time while they 
work through the stakeholder process to develop FPA section 205 filings to revise the Tariff to 
address the issues raised in the Show Cause Order.13  MISO and the MISO Transmission Owners 
agree that an aggressive timeline is needed to address these issues, and that the breadth and 
complexity of the concerns raised in the Show Cause Order will require a more expedited 
stakeholder process and feedback loop than is typical before filing solutions with the Commission.  
 
11  Id. at P 3.  
12  Id. at P 37. 
13  Id. at P 37.

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MISO and the MISO Transmission Owners are committed to undertaking that process in good 
faith with the expectation that the Commission will be presented with a comprehensive set of 
section 205 filings addressing the issues identified in the Show Cause Order.   
MISO and the MISO Transmission Owners appreciate the important role that states play in 
the MISO region, especially in managing the ultimate retail costs to customers and affordability.  
It is also because of the MISO states’ continued focus on resource adequacy that the MISO region 
is not facing an immediate crisis related to large load integration as has been experienced in other 
parts of the nation.  MISO and the MISO Transmission Owners are committed to continued 
collaboration with the states as solutions are finalized and brought before the Commission. 
Given the volume of work to be accomplished and the need to engage stakeholders, MISO 
and the MISO Transmission Owners respectfully request that the Commission grant a 90-day 
abeyance to allow MISO and the MISO Transmission Owners to bring regionally tailored solutions 
to the Commission to address the issues identified in the Show Cause Order.   The abeyance will 
allow MISO and the MISO Transmission Owners the opportunity to leverage the LLWG further 
to collaborate with the states and stakeholders to develop robust, durable solutions to meet the 
needs in the MISO region.  Importantly, MISO is not starting from scratch—the current MISO 
stakeholder process has already developed several prioritized proposals to address large load 
integration, as further described below.  MISO and the MISO Transmission Owners are confident 
that the abeyance approach will provide the most successful path forward to achieve the 
Commission’s desired outcomes to ensure the integration of large loads in an efficient, reliable, 
and affordable manner. 
Although MISO, the MISO Transmission Owners, the OMS, and stakeholders have been 
working on several speed to power initiatives, the 90-day abeyance requested herein is essential to

9 
permit MISO and the MISO Transmission Owners, in collaboration with member states and other 
stakeholders, to adjust planned solutions to fully address the Commission’s directions and, where 
necessary, to develop additional Tariff revisions responsive to the Show Cause Order. The 
challenges and opportunities presented by large loads are multi-faceted and implicate numerous 
parts of MISO’s Tariff.  Therefore, while speed is important, it also is critical to ensure that 
individual solutions align properly with each other and with existing MISO procedures.  This is a 
complex task. 
Good cause exists to hold the show cause proceeding in abeyance.  MISO has established 
a dedicated stakeholder forum to address the issues identified in the Show Cause Order associated 
with the reliable integration of large loads.  Holding the show cause proceeding in abeyance will 
promote administrative efficiency, allow for more carefully-crafted solutions, and avoid 
unnecessary litigation of matters that would be more appropriately addressed through the ongoing 
MISO stakeholder process.  Ultimately, granting the abeyance will not prejudice any party, as all 
parties will have an opportunity to participate in MISO’s public stakeholder process and intervene 
in future FPA section 205 filings.   
IV. 
COMPLIANCE PLAN 
 
A. 
Overview of Compliance Approach and FPA Section 205 Filings 
MISO and the MISO Transmission Owners will address the issues raised in the Show 
Cause Order through a series of FPA section 205 filings to be submitted during the abeyance 
period.14  Below is a description of the FPA section 205 filings that MISO and the MISO 
Transmission Owners are currently contemplating.  As shown below, some proposals have already 
 
14  As stated above, ATC will clarify in each section 205 filing submitted during the abeyance period whether it 
joins in that filing.  This will be determined as each subsequent section 205 filing is developed.

10 
undergone significant stakeholder vetting and as such, will be filed prior to the end of the 90-day 
abeyance.  Other proposals are still in their infancy and may require the entire 90-day abeyance.     
First, MISO expects to submit tariff changes establishing a new Zero Injection Generator 
Interconnection Agreement (“ZGIA”) and related study process to facilitate faster resource 
additions when those resources are designated to serve load at the same substation, thereby 
accelerating the addition of generation resources that have little or no impact on the Transmission 
System.  With these proposed Tariff changes, the ZGIA will partly address several of the issues 
raised by the Commission related to co-location of generation and large loads by proposing a 
permanent solution for generation resources seeking to interconnect to the Transmission System 
at the same substation as an associated load.15  MISO expects to submit the ZGIA filing by the end 
of August. 
 
Second, MISO anticipates submitting Tariff changes establishing new large load 
Interconnection Reliability Requirements (“IRR”).  The proposed IRR Tariff changes will establish 
operational requirements for transmission customers serving large loads to ensure visibility and 
reliable operation of the Transmission System.16  Specifically, the IRR filing will include 
requirements for large loads to provide basic facility data, modeling, telemetry, and forecasting 
information.17  In addition, the proposed IRR Tariff changes will provide detail regarding Phasor 
Measurement Unit (“PMU”) requirements, as well as requirements for ramp and ride-though for 
certain types of large loads.  
 
15  See SCO at PP 58, 94, 113, 115, 117 and 118. 
16  See SCO at P 57; id. at P 64 (preliminarily finding that MISO’s Tariff appears to be unjust and unreasonable 
because it lacks provisions addressing ongoing operational requirements for transmission customers taking 
transmission service on behalf of large loads). 
17  See SCO at P 64 (stating that MISO’s Tariff does not require transmission customers to provide MISO hourly 
forecasts, telemetry data, and other data to ensure sufficient visibility or specify requirements for maintaining 
communication channels between MISO and the transmission customer on behalf of the large load).

11 
 
Third, at the July 16, 2026, LLWG meeting, MISO presented and stakeholders accepted a 
formal issue submission and conceptual design for a load addition and resource study (“LARS”) 
process.18  LARS will assess the transmission infrastructure needed to meet new large loads and 
new generation in an efficient process that can be executed on a shorter timeline, further 
supplementing the opportunities available for members to facilitate new large spot loads 
effectively.  This process is expected to position MISO and its members to ensure resource 
adequacy and protect customers from unnecessary investments relating to the uncertainty of spot 
large load siting. 
More specifically, LARS will analyze generation and transmission using the same study 
assumptions applied in the standard generator interconnection process and MISO’s MTEP.  The 
studies will be run in parallel, and will finish at approximately the same time—within 120 days—
with the load/transmission model incorporating both the planned generation and planned load.19  
LARS, as currently conceived, will address similar issues to those the Show Cause Order identified 
related to interconnection customers serving electrically proximate large load or co-located load.20  
MISO will continue to develop the LARS process through the LLWG and expects to submit the 
LARS filing by November 16, 2026, or earlier, if feasible. 
Fourth, MISO has presented to the LLWG initial concepts to accommodate flexible large 
loads including a firm transmission service step-up option.  A firm step-up option was initially 
 
18  The concepts discussed herein as the LARS process were referred to as the “Generation and Large Load 
Alignment” process at the July 16, 2026, LLWG. 
19  MISO included a description of this Joint Study Process in its Informational Report submitted in this docket on 
July 20, 2026. 
20  SCO at P 113 (preliminarily finding that MISO’s Tariff may be unjust and unreasonable because it does not 
contain provisions that will allow an interconnection customer to seek the generator interconnection service(s) 
that reflects the operational dynamics of serving either: (1) an electrically proximate large load; or (2) a co-
located load, that has a high peak load (i.e., large co-located loads that are 50 MW or greater)).

12 
discussed with stakeholders at the April 20, 2026, LLWG and again at the June 10 and July 16 
LLWG meetings, including a request for stakeholder feedback on proposed Tariff revisions 
presented at the LLWG on July 16, 2026.  MISO will address stakeholder feedback on the firm 
transmission service step-up Tariff revisions at the August 2026 LLWG meetings.  MISO expects 
to make a section 205 filing proposing Tariff revisions incorporating the firm service step-up 
option by November 16, 2026, or earlier, if feasible.   
Fifth, at the July 16, 2026, LLWG, MISO presented a formal issue submission and concepts 
for a non-firm large load service option intended to address the issues the Commission identified 
in the Show Cause Order relating to the unique operational characteristics of large loads that are 
willing and able to limit their energy withdrawals under certain conditions and the effect on the 
need for certain Network Upgrades.21  The LLWG voted to accept the issue submission and 
continue discussions related to the development of non-firm large load service options.  MISO will 
continue to develop these service options through discussions at the August 2026 LLWG meetings. 
 
Finally, MISO and the MISO Transmission Owners are working together22 to develop 
additional solutions, processes, and services to address the balance of the Commission’s concerns 
identified in the Show Cause Order.  These include, among other things, (a) the application process, 
study procedures (including evaluating alternative transmission technologies), and ongoing 
operational requirements that apply to Eligible Customers seeking transmission service on behalf 
of large loads; and (b) additional transparency concerning the Network Upgrade costs and cost 
shift concerns.23  MISO will present concepts and proposed Tariff revisions to the LLWG for 
 
21  SCO at P 60, see also, SCO at PP 102, 104. 
22  To the extent the Commission’s concerns address the rates, terms and conditions of Transmission Service and 
may implicate rate design and Transmission Owner revenue requirements, the FPA section 205 filings 
addressing these issues are expected to be joint filings with the MISO Transmission Owners.   
23  See SCO at P 33.

13 
discussion and formal stakeholder feedback requests as they are developed in anticipation of a 
November FPA section 205 filing to address any Commission directives not addressed in a prior 
FPA section 205 filing.  
B. 
Process and Schedule for Stakeholder Input 
 
 
To facilitate further stakeholder discussion and formal feedback cycles on proposals to 
address the Commission’s concerns expressed in the Show Cause Order, MISO has scheduled a 
series of LLWG meetings during the requested abeyance period.  While the following LLWG dates 
have been established, MISO is committed to working with stakeholders to address the issues in 
the Show Cause Order and will call special meetings of the LLWG if necessary.  Currently, the 
LLWG is scheduled to meet six times between the date of this filing and the end of the requested 
abeyance period including:  
Wednesday, August 12, 2026 
Thursday, August 27, 2026  
Wednesday, September 23, 2026  
Thursday, October 8, 2026 
Thursday, October 29, 2026 
Monday, November 16, 2026 
A detailed management plan outlining the specific agenda for these meetings is located on MISO’s 
website and will be updated regularly.24  
 
 
 
24  The following is the July 31, 2026, version of the LLWG management plan:  
https://cdn.misoenergy.org/20260812%20LLWG%20Item%2001d%20Management%20Plan772569.pdf (last 
visited August 3, 2026).  MISO notes that the LLWG management plan will be revised from time to time and 
updated versions will be posted on MISO’s website.

14 
V. 
REQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED TREATMENT 
MISO and the MISO Transmission Owners respectfully request that the Commission issue 
an order granting the requested 90-day abeyance on an expedited basis by August 14, 2026.  
Prompt action on this Motion will provide certainty to MISO and its stakeholders regarding the 
need to submit a response to the Show Cause Order by August 17, 2026, and avoid the expenditure 
of time and resources on preparing filings that may prove unnecessary.  With such certainty, MISO 
and its stakeholders can confidently spend critical time and resources developing the FPA section 
205 filings discussed herein.    
To enable the Commission’s consideration of this Motion on an expedited basis, MISO and 
the MISO Transmission Owners also request that the Commission establish a 5-day comment 
period for this Motion—i.e., by August 10, 2026.  The Commission may shorten or eliminate 
answer periods altogether for good cause shown.25  Good cause exists to establish a 5-day answer 
period and grant expedited treatment of this Motion because the Show Cause Order’s compliance 
deadline is fast approaching and parties need certainty regarding the compliance timeline.  
VI. 
CONCLUSION 
 
For the reasons set forth above, MISO and the MISO Transmission Owners respectfully 
request that the Commission: (i) grant this Motion to hold this proceeding in abeyance for a period 
of 90 days starting August 17, 2026, to allow time for MISO and the MISO Transmission Owners, 
where applicable, to develop and submit FPA section 205 filings to address the issues identified in 
 
25  See, e.g., Sw. Power Pool, Inc., Notice Granting Motion to Hold Proceeding in Abeyance, Docket No. EL22-65-
000 (Jan. 31, 2024) (holding show cause proceedings in abeyance pending stakeholder process to resolve show 
cause proceedings via a section 205 filing); PJM Interconnection, L.L.C., 171 FERC ¶ 61,015, at P 34 (2020) 
(holding a paper hearing proceeding in abeyance to allow stakeholder discussions to continue); Midcontinent 
Indep. Sys. Operator, Inc., 161 FERC ¶ 61,057, at P 44 (2017) (same); Sw. Power Pool, Inc., 161 FERC ¶ 
61,062, at P 33 (2017) (same).

15 
the Show Cause Order; (ii) establish a 5-day answer period; and (iii) grant expedited consideration 
by issuing an order on this Motion by August 14, 2026. 
Respectfully submitted, 
/s/ Christopher D. Supino 
Christopher D. Supino 
Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
Midcontinent Independent System   Operator, Inc. 
720 City Center Drive  
Carmel, Indiana 46032  
Telephone: (317) 249-5400 
csupino@misoenergy.org 
mkessler@misoenergy.org 
 
James C. Holsclaw 
Calfee, Halter & Griswold LLP 
3900 Salesforce Tower 
111 Monument Circle 
Indianapolis, Indiana 46204 
Telephone: (317) 308-4266 
jholsclaw@calfee.com   
 
Attorneys for 
Midcontinent Independent System Operator, Inc. 
 
/s/ Wendy N. Reed 
 
 
Wendy N. Reed 
Matthew J. Binette 
Anna Fernandez 
WRIGHT & TALISMAN, P.C. 
1200 G Street NW, Suite 600 
Washington, DC 20005-3898 
(202) 393-1200  
reed@wrightlaw.com  
binette@wrightlaw.com 
fernandez@wrightlaw.com 
 
Attorneys for  
the MISO Transmission Owners

CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Carmel, Indiana this 3rd day of August, 2026. 
/s/ Dawn Kaminski 
Dawn Kaminski 
Midcontinent Independent 
System Operator, Inc.  
720 City Center Drive 
Carmel, Indiana 46032 
Telephone:  (317) 249-5400