EL26-70-000 · 2026-07-20 · Midcontinent Independent System Operator, Inc.

MISO reports on resource adequacy and large-load proposals

Midcontinent Independent 
System Operator, Inc. 
317.249.5400 
www.misoenergy.org 
720 City Center Drive 
Carmel, IN 46032 
2985 Ames Crossing Road 
Eagan, MN 55121 
1700 Centerview Drive 
Little Rock, AR 72211 
 
Christopher D. Supino 
Managing Senior Corporate Counsel  
Direct Dial:  317-249-5256 
E-mail: csupino@misoenergy.org 
 
July 20, 2026 
VIA ELECTRONIC FILING 
The Honorable Debbie-Anne Reese 
Secretary 
Federal Energy Regulatory Commission 
888 First Street, NE 
Washington, DC  20426 
Re: 
Midcontinent Independent System Operator, Inc. 
 
Informational Report   
 
Docket No. EL26-70-000 
  
Dear Secretary Reese: 
The Midcontinent Independent System Operator, Inc. (“MISO”), through this filing, 
submits this informational report in compliance with the Federal Energy Regulatory Commission’s 
(the “Commission”) Order Instituting Proceeding Under Section 206 of the Federal Power Act 
issued in this proceeding on June 18, 2026 (the “Show Cause Order”).1  MISO respectfully requests 
that the Commission accept this filing in compliance with the Show Cause Order’s requirements. 
I. 
Executive Summary 
MISO appreciates the support of the Commission to ensure efficient, cost-effective and 
reliable integration of large loads.  MISO continues to work diligently with the states both 
individually and through the Organization of MISO States (“OMS”), as well as its member 
utilities, to support resource adequacy for planned load growth in a manner that maintains customer 
affordability, efficiency and regional reliability.  MISO’s current framework is well-suited to meet 
the needs of traditional load growth, and MISO’s existing processes have enabled us to maintain 
resource adequacy.  The unique nature of certain new large loads and the need to help ensure speed 
to power, however, brings new challenges that require MISO to continue to work with its states 
and broader stakeholder community to develop new tools and processes to ensure resource 
adequacy is maintained going forward.  Conventional load forecasting was designed around 
gradual and geographically-dispersed growth.  The new large loads, which include data center 
developments, reflect a new type of load growth.  A single project may require more load than an 
entire city at one location and desire service within a short period.  This concentrated and 
discontinuous load growth requires new processes to most effectively meet this new demand and 
maintain resource adequacy.  Many of these new large loads are difficult to forecast with a high 
 
1  
Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 (2026) (the “Show Cause Order”).

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 2 
degree certainty using traditional forecasting methods, and the flexibility in locational siting does 
not align well with traditional utility planning.  It is not prudent for load serving entities to build 
local transmission, or generation, for speculative loads.  Yet the pace of large load additions and 
early need-by dates nonetheless require acceleration of transmission planning and generator 
interconnection processes, even in the face of this uncertainty.  
While MISO’s existing processes have been sufficient to ensure resource adequacy in the 
short term, the unique operational characteristics of new large loads have prompted MISO to 
consider new processes within the current regulatory framework and Resource Adequacy 
construct.  As discussed below, MISO, the states, and our members have taken a number of steps 
to address resource adequacy in the near term and to plan for resource adequacy needs in the future 
given the shifting resource mix and risk profile in the MISO region. 
In order to meet the unique speed to power needs of these new large loads and provide 
additional tools that support resource adequacy, MISO is developing two new processes to speed 
the delivery of energy to large loads.  First, MISO will file its Zero Injection Generator 
Interconnection Agreement (“ZGIA”) by early August.  MISO began working with stakeholders 
in 2025 to develop a new Interconnection service study type—ZG Interconnection Service, an 
associated study process, and revisions to its pro forma Generator Interconnection Agreement and 
modifications to its pro forma GIA designed to facilitate faster interconnection of generation 
resources that serve only Load connected to the same substation and will not inject energy further 
onto the Transmission System.  As discussed in more detail below, the ZGIA is not restricted to 
use only for large loads.  However, the process is particularly responsive to the challenges faced 
by large loads.  The ZGIA will facilitate the accelerated interconnection of generation needed to 
serve a specific nearby load source where broader injection onto the broader Transmission System 
is not needed and system impacts—and corresponding Network Upgrades—can be limited to 
roughly the substation level.  This provides a valuable option for generation to be co-located with 
large loads without having enter the Definitive Planning Phase of MISO’s generation 
interconnection queue or obtain a form of Interconnection Service that is broader and potentially 
more costly than what is needed.  
In addition, at the July 16, 2026 Large Load Working Group MISO initiated stakeholder 
discussions to develop a new set of processes for concurrently studying large loads and associated 
generation.2  This new framework (provisionally named the “Large Load Parallel Study Process”) 
aligns the study processes used to assess the transmission infrastructure needed to meet new large 
loads and new generation in an efficient framework that can be executed on a shorter timeline 
using shared modelling inputs.  The Large Load Parallel Study Process recognizes the unique 
commercial realities of these new large loads.  This framework is expected to position MISO’s 
members to meet the challenges presented by new large loads on a more immediate timeline.  The 
Large Load Parallel Study Process will support resource adequacy and further supplement the 
opportunities available for members to effectively facilitate new large spot loads, with speed, and 
supports resource adequacy while protecting customers from unnecessary investments relating to 
 
2  
See 
https://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20and%20Load%20Align
ment%20Presentation768740.pdf

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 3 
the uncertainty of spot large load siting.  MISO will work with stakeholders to further develop the 
Large Load Parallel Study Process and intends to submit a Section 205 filing to the Commission 
codifying the Large Load Parallel Study Process in the Tariff as part of the suite of solutions 
responsive to the Commission’s Show Cause Order.   
II. 
BACKGROUND 
On June 18, 2026, the Commission issued the Show Cause Order.  The Show Cause Order 
directed the following compliance requirements:   
122. Accordingly, we direct MISO to submit in Docket No. EL26-
70-000, within 30 days of the date of issuance of this order, a 
detailed informational report on any proposals under consideration 
in its stakeholder process to address the issue of resource adequacy 
to serve new large loads.  We also strongly encourage new proposals 
to the extent necessary to address these concerns.  The informational 
report must include a detailed schedule of key milestones, such as 
stakeholder or MISO Board votes, that includes the estimated date 
on which MISO expects to file any such proposals with the 
Commission.  Additionally, as part of this informational report, we 
direct MISO to identify any ongoing stakeholder processes that aim 
to increase the pace of adding generating capacity in the MISO 
region.  The informational report must include a detailed schedule 
of such initiatives, including timing of the stakeholder process and 
dates of any anticipated filings with the Commission.3   
III. 
INFORMATIONAL FILING 
To respond to the Show Cause Order’s requirements, MISO has divided its informational 
report into three sections.  Sections A and B discuss MISO’s role in promoting Resource Adequacy 
in the MISO Region and the ability of the Transmission System to meet projected large load 
demands under current Tariff processes and expected generation additions.  Section C discusses 
new initiatives that MISO is developing with its stakeholders to further buttress resource adequacy 
and accelerate the pace of adding generation to meet the emerging needs of large loads.   
A. 
The MISO Region Is Resource Adequate. 
1. 
The role of the States in ensuring resource adequacy.  
Within the MISO region, States are primarily responsible for resource adequacy, which 
involves overseeing Load Serving Entities (“LSEs”) and ensuring LSEs plan for and secure enough 
power to meet their customers’ demand.  MISO supports resource adequacy by determining 
Planning Reserve Margin, administering the Planning Resource Auction and providing data for 
planning, but it is the responsibility of the States and LSEs to ensure sufficient  capacity is available 
 
3  
Id. at P 122.

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 4 
to meet Load and reserve requirements.  MISO’s Resource Adequacy construct complements the 
jurisdiction that State commissions and Relevant Electric Retail Rate Authorities (“RERRA”) have 
in determining the necessary level of Resource Adequacy and works in concert with LSEs, as LSEs 
are the entities responsible for providing demand forecasts that help drive the development of local 
and regional requirements by MISO.  Additionally, MISO partners with the Organization of MISO 
States, Inc. (“OMS”) to conduct a survey (“OMS-MISO Survey”) of resource owners within MISO 
footprint on an annual basis to assess anticipated generating capacity over a five-year planning 
horizon.  The OMS-MISO Survey results, along with MISO’s Planning Resource Auction 
(“PRA”) and other forward-looking analyses (e.g., Futures), provide a comprehensive view of 
system risks and resource needs, supporting states in their resource adequacy responsibilities and 
members in their resource planning.   
2. 
The MISO region is expected to experience capacity surpluses in the 
near term.  
a. 
OMS-MISO Survey 
The OMS-MISO Survey provides transparency in expectations of future resource adequacy 
plans, among other vehicles.4  Overall, the OMS–MISO Survey provides a five-year view of 
resource adequacy, indicating if expected capacity based on member plans will meet planning 
reserve margins and yield a surplus or deficit. 
The 2026 OMS-MISO Survey results, published on June 4, 2026, show an adaptive 
response to increasing demand through generation additions that sustain near-term resource 
adequacy.5  As provided in the 2026 OMS-MISO Survey results, the MISO region is projected to 
maintain sufficient capacity to meet demand across the next five years, based upon current load 
forecasts and anticipated load growth.6  MISO examines the survey results in tandem with forecast 
data submitted by LSEs. The forecast data indicates that Load growth as submitted by LSEs 
continues to accelerate, with a Compound Annual Growth Rate (“CAGR”) projected between 
3.1% and 5.1% over five years.7  The study results also indicates that, to support rising demand, 
the MISO Region needs to maintain the increased pace of capacity additions, noting that timely 
generation builds, generator interconnection queue improvements, as well as the Expedited 
Resource Adequacy Study (“ERAS”), will help meet this need.8  The study results further confirm 
that seasonal reliability risk is changing in a way that contributes to shifting hours of reliability 
 
4  
“OMS” refers to the Organization of MISO States, which encompasses state utility regulators in the MISO 
footprint.  
5  
2026 OMS-MISO Survey Results available at: https://cdn.misoenergy.org/20260604%20OMS-
MISO%20Survey%20Results%20Workshop%20Presentation761711.pdf 
6  
Id. at 2. 
7  
Id. 
8  
Id.

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 5 
risk and the seasonal distribution of risk.  For example, MISO is seeing a shift in risk away from 
summer and towards winter as the resource mix evolves.9 
b. 
MISO’s Regional Resource Assessment 
MISO is confident that the MISO Region will continue to be resource adequate in both the 
near and longer term.  In addition to the OMS-MISO Survey, MISO had also developed Regional 
Resource Assessment (“RRA”) to assess the state of resource adequacy in its footprint in the past.  
The RRA10 was one of the periodic studies MISO used to forecast how the mix of electricity-
generating resources in the MISO Region could evolve going forward.  
While the RRA and the OMS-MISO Survey are similar in some ways, there are some key 
differences.  The RRA is a 20-year outlook based on publicly announced resource plans and state 
and policy goals, whereas the OMS-MISO Survey is a more near-term (5-year outlook) resource 
adequacy assessment based on member plans and resource addition trends.  Separately but related, 
MISO also develops MISO Futures which typically entails two or more scenarios, with 20-year 
outlook, and is used for transmission planning purposes.   
B. 
MISO’s Efforts to Support Resource Adequacy 
MISO works diligently to develop, implement, and refine programs to give states and our 
members the support needed to ensure resource adequacy in the MISO Region.  MISO’s ongoing 
resource adequacy efforts involve a holistic, stakeholder-driven approach that has culminated in 
numerous Tariff enhancements, some of which are under development and some of which have 
recently taken effect.  This filing discusses the subset of those initiatives that specifically address 
the market reforms to send transparent price signals that provide all parties with the information 
necessary to make informed decisions in their resource planning efforts.  These initiatives are 
discussed in greater detail in the remainder of this section.  MISO anticipates that it will provide 
more detail on additional initiatives addressing other aspects of the large load integration challenge 
in a forthcoming abeyance request. 
1. 
Seasonal Construct and Reliability Based Demand Curve  
MISO’s recent shift to a seasonal capacity market with seasonal accredited capacity better 
reflects extreme weather conditions that have become more prevalent.  These weather conditions 
affect both the seasonal peak demand and the available seasonal supply.  In addition, the seasonal 
construct better reflects the seasonal planned & forced outage patterns of supply.  The recent 
implementation of the Reliability Based Demand Curve (“RBDC”) reflects the contributions to 
reliability incremental MWs can add to the system.  The RBDC helps with price signals by 
indicating if the MISO Region has sufficient capacity for the prompt Planning Year.  On the supply 
 
9  
Id. 
10  More information on MISO’s 2024 Regional Resource Assessment can be found here: 
https://cdn.misoenergy.org/2024%20RRA%20Report_Final676241.pdf.

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 6 
side, resources are being accredited based on availability during all times of need, across all 
seasons (Schedule 53, seasonal accredited capacity resources). 
Data from the 2025-2026 PRA confirm the reliability benefits of the RBDC construct.  At 
a system level, MISO cleared more capacity beyond the seasonal PRM.  The auction cleared above 
seasonal final reliability target, representing additional reliability value at cost competitive prices.  
For all seasons, Subregional RBDCs set the requirement for both subregions.  The efficiency of 
the RBDC enabled MISO to secure more capacity at a significantly lower price. 
2. 
Transition to the Direct Loss-of-Load Accreditation Methodology 
MISO is currently transitioning to a two-step accreditation approach (the “Direct Loss-of-
Load” or “DLOL”-based methodology) that accredits capacity based on marginal contribution to 
reliability during periods of highest system risk (“marginal effective load carrying capability” or 
“marginal ELCC”) on a Resource Class basis.  MISO’s DLOL-based methodology combines both 
probabilistic and deterministic elements into a single resource accreditation process.  Simply 
described, the DLOL-based methodology takes two steps by first determining the size of the pie, 
and second, divvying up the pie.  The DLOL-based accreditation methodology will provide both 
MISO members and regulators engaged in integrated resource planning the right investment and 
retirement signals to help ensure the availability of resources with the attributes necessary to 
maintain reliability into the future. 
3. 
Expedited Resource Addition Study 
In June of 2025, consistent with the Commission’s direction, MISO filed its revised 
Expedited Resource Addition Study (“ERAS”) proposal (“Revised ERAS Proposal”).  As noted 
in its filing, the ERAS proposal was driven by the fact that MISO was facing urgent near-term 
resource adequacy and reliability concerns due to load growth, generation retirement, and delays 
in the interconnection process11 and that it would experience a 4.7 gigawatt (GW) shortfall by 2028 
if currently planned generation facility retirements were to occur.12   
In support of the ERAS proposal MISO asserted that, while it has undertaken reforms to 
improve queue processing, the current processing presents a barrier to developing generation that 
can address these near-term needs.  As such, MISO proposed revisions to its Generator 
Interconnection Procedures (“GIP”) and pro forma Generator Interconnection Agreement (“GIA”) 
to establish a ERAS process, which provides for accelerated study of interconnection requests that 
will address urgent resource adequacy and reliability needs in the near term (i.e., within the next 
five years).13  Specifically, under the Revised ERAS Proposal, MISO proposed to create a quarterly 
 
11  Ltr. to the Hon. Debbie Ann Reese, Secretary, Docket No. ER25-1674-000, at p. 5 (Mar. 17, 2025). 
12  Id. at 6 (citing NERC’s 2024 Long-Term Reliability Assessment (published December 2024), 
https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_Long%20Term%20Reliability
%20Assessment_2024.pdf). 
13  Id. at 1.  See MISO, Proposed Tariff, Attach. X (GIP) (175.0.0), §§ 1 (Definitions), 2.1 (Application of Generator 
Interconnection Procedures), 3.3.1 (Initiating an Interconnection Request), 3.4 (OASIS Posting), 3.9 (Expedited

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 7 
“first-come, first-served” serial study process to facilitate the rapid study of interconnection 
requests for generating resources that are committed to addressing specific, identified resource 
adequacy and/or reliability needs with RERRA verification,14 resulting in an ERAS Generator 
Interconnection Agreement (“EGIA”) within approximately 90 days of study kickoff.  
The Commission accepted MISO’s ERAS proposal on July 21, 2025, finding that MISO’s 
proposed Tariff revisions accomplish the purposes of the Commission’s final rules on generator 
interconnection, including Order Nos. 2003 and 2023, by helping to ensure that interconnection 
customers are able to interconnect to the transmission system in a reliable, efficient, transparent, 
and timely manner.15   
ERAS was filed as short term, limited-use, ‘bridge’ process to enable generators needed to 
respond to specifically identified and urgent resource adequacy and reliability needs, thus giving 
MISO’s broader queue reforms time to take effect.  ERAS has succeeded in its goals.  To date, 40 
projects and 19 GWs of generation have completed the accelerated ERAS process and received 
final or near-final generator interconnection agreements allowing them to meet these urgent needs.  
MISO has filled the 50 Load-Serving Entity (“LSE”) slots and 10 Independent Power Producer 
(“IPP”) slots and expects to fill the remaining 8 retail choice spots allowed under the ERAS caps 
prior to the ERAS sunset date.  However, while ERAS has been extremely useful and necessary 
in the short term, MISO acknowledges that it is not permanent and that other new processes or 
enhancements to existing processes must address longer-term needs. 
4. 
Improving Queue Speed 
 
MISO has also made reforms that, taken collectively, enable it to become an industry leader 
in facing the challenges of a swelling interconnection queue while addressing both the current and 
projected needs of Interconnection Customers and load for a more reliable and efficient 
transmission system and Tariff processes tailored to meet emerging needs. 
In January 2017, MISO comprehensively restructured the GIP and instituted a three-phase 
Definitive Planning Phase (“DPP”) process16 to facilitate a structured study and restudy of 
proposed generation projects (“2017 Queue Reform”).17  The key elements of the novel GIP 
 
Resource Addition Study), 5.13 (Transition to ERAS Process), 7.2.1 (Requirements for Demonstrating Site 
Control for Generating Facility), 7.3.1.4 (Interconnection Decision Point I), 7.3.2.3.1 (Additional Analysis 
Applicable to Interconnection Requests in a JTIQ Screening Group), 11.1 (Tender), 11.2 (Negotiation), 11.2.1 
(Optional negotiation period adjustment for Interconnection Facilities Study), and 11.3 (Execution and Filing); 
id. app. 1 (Interconnection Request for a Generating Facility) (56.0.0); id. app. 6 (GIA) (106.0.0), art. 1 
(Definitions), 2.3.3, and 2.4 (Termination Costs).   
14  Transmittal at 4; Filing, Tab C (Testimony of Andrew Witmeier) at 51-52 (Witmeier Testimony). 
15  Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 (2025) at P 31 (“ERAS Order”). 
16  The DPP is the principal part of the GIP where the interconnection study process takes place, as described in 
section 7 of the GIP. See Tariff, Attach. X, GIP § 7. 
17  See Midcontinent Indep. Sys. Operator, Inc., 158 FERC ¶ 61,003 (“2017 Queue Reform Order”), order on reh’g, 
161 FERC ¶ 61,137 (2017).

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 8 
process adopted in 2017 included: sequential System Impact Studies (“SIS”) and Facilities Studies, 
a separate financial milestone at the beginning of each DPP phase,18 and two Interconnection 
Customer Decision Points (“Decision Points”) serving as off-ramps to allow Interconnection 
Customers with projects that are no longer viable to exit the queue with minimal impacts on other 
projects.  This multi-phase model proved to be a significant improvement over the prior one-phase 
process, and it has been adopted in some other large RTOs.19 
After the implementation of the 2017 Queue Reform, MISO and its stakeholders continued 
to evaluate the effectiveness of the new three-phase DPP process, responding to emerging issues 
and refining the initial design with various improvements, both internally and through FERC 
filings.  The following additional main improvements to the three-phase DPP process were 
implemented: (1) reforms to strengthen certain milestone and site control requirements (2019);20 
(2) reforms to the Option to Build, harm test calculation, and provisional GIA requirements 
(2021);21 (3) reforms to classify fuel type change requests made in the DPP process as a Material 
Modification and allow Interconnection Customers to request Surplus Interconnection Service 
earlier in the interconnection study process (2021);22 (4) and an innovative proposal to reduce the 
GIP timeline by offering enhanced flexibility and an optional path for Interconnection Customers 
to execute GIAs in under one year, thereby improving coordination and alignment with MISO’s 
transmission expansion planning process, and to implement various other enhancements to the 
interconnection process (2022).23 
In 2023, during the pendency of the Order No. 2023 process, MISO embarked on yet 
another reform to strengthen its withdrawal penalty regime, including through the adoption of an 
Automatic Withdrawal Penalty, and further refine its site control requirements.  As MISO 
explained in its filing, the reforms were critical to address the ballooning size of MISO’s generator 
interconnection queue and winnow out the speculative interconnection requests that so frequently 
distort price signals and delay cost certainty to the developers of generation.  The Commission 
found these reforms just and reasonable and accepted them effective January 22, 2024,24 to apply 
starting from MISO’s DPP-2024 queue cycle.  
In addition, MISO worked with its RTO neighbors, PJM Interconnection, LLC (“PJM”) 
and Southwest Power Pool, Inc. (“SPP”), to improve affected system studies procedures and 
requirements that are contained in MISO’s Joint Operating Agreements (“JOAs”) with these 
 
18  There are currently three financial milestones in the GIP: M2, M3, and M4. M2 marks the beginning of DPP 
Phase I, M3 marks the beginning of DPP Phase II, and M4 marks the beginning of DPP Phase III. 
19  See PJM Interconnection, L.L.C., 181 FERC ¶ 61,162 (2022) (adopting a three-phase interconnection process); 
Southwest Power Pool, Inc., 167 FERC ¶ 61,275 (2019) (adopting a three-stage interconnection study process). 
20  See Midcontinent Indep. Sys. Operator, Inc., 169 FERC ¶ 61,173 (2019). 
21  See Midcontinent Indep. Sys. Operator, Inc., letter order, Docket No. ER21-2173-000 (Aug. 10, 2021); 
Midcontinent Indep. Sys. Operator, Inc., 176 FERC ¶ 61,122 (2021). 
22  See Midcontinent Indep. Sys. Operator, Inc., 177 FERC ¶ 61,234 (2021). 
23  See Midcontinent Indep. Sys. Operator, Inc., 178 FERC ¶ 61,141 (2022). 
24  Midcontinent Indep. Sys. Operator, Inc., 186 FERC ¶ 61,054, reh’g denied, 187 FERC ¶ 61,031 (2024).

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 9 
entities.25  These reforms have significantly enhanced MISO’s affected system procedures 
resulting in more expeditious processing of Interconnection Requests involving affected system 
studies with these neighboring RTOs while also allowing Interconnection Customers to move 
forward even where an affected system study is delayed. 
MISO continues to work with its state commissions, stakeholders, and neighbors to 
improve the efficiency, accuracy, and speed of its interconnection queue through developing 
innovative solutions.  For example, MISO integrated modeling software Suite of Unified Grid 
Analyses with Renewables (“SUGAR”), for Phase 1 DPP studies with plans to integrate in Phase 
2 and 3.  SUGAR is designed to perform power flow analyses, identify Network Upgrades, allocate 
costs using MISO’s Transmission Cost Estimation Guide and Transmission Owner upgrade inputs, 
and validate constraint mitigation.  The SUGAR software leverages powerful circuit simulation 
methods developed to study billion-transistor electronic systems; this innovation underlies the 
ability to expedite some of the more time-consuming aspects of running interconnection studies.  
In addition to providing data within MISO’s acceptable tolerances, as benchmarked against current 
software, SUGAR reduced DPP phase 1 cycle time significantly from the status quo as evidenced 
in the DPP 2022, 2023 and 2025 cycles.  The implementation of SUGAR advances MISO’s 
Reliability Imperative by continuing to improve processes for new generator interconnections. 
5. 
Joint Targeted Interconnection Queue Study 
 
The MISO-SPP Joint Targeted Interconnection Queue Study (“JTIQ”) has sped the queue 
up considerably by providing an alternative to the backlogged ordinary affected systems study 
process with SPP while providing both more efficient solutions to the needs of multiple cycles of 
Interconnection Customers as well as greater up-front cost certainty regarding potentially 
significant affected systems costs to generators entering the Definitive Planning Phase or MISO’s 
ERAS processes.  This increased efficiency and cost certainty allows generators to reach GIA 
faster and develop their projects from a starting point of increased cost certainty.  
The JTIQ portfolio directly enables new generation to serve emerging load by proactively 
constructing the transmission backbone needed for interconnection, rather than waiting for 
incremental upgrades triggered by one project at a time.  By identifying and mitigating cross‑seam 
constraints in advance, JTIQ provides large, regionally optimized transmission solutions that 
unlock more than 28 GW of new interconnection capability along the MISO‑SPP seam.  Because 
these upgrades are included upfront in MISO and SPP’s planning and interconnection models 
inclusive of ERAS studies, DPP cycles, and Expedited Project Reviews; projects can interconnect 
faster and with far greater cost certainty.  
 
C. 
MISO’s Future Efforts to Bring Resources Online Faster 
1. 
Zero Injection Generator Interconnection Agreement – Expected 
Filing Date – July 31, 2026 
 
25  See Midcontinent Indep. Sys. Operator, Inc., 171 FERC ¶ 61,275 (2020).

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 10 
MISO began working with stakeholders in 2025 to develop a more robust zero injection 
generator interconnection agreement (“ZGIA”) to facilitate faster interconnection of generation 
resources that will be co-located with load and will not inject energy further onto the Transmission 
System.  The ZGIA provides a limited, structured option to support large load integration through: 
 
• A limited service framework supported by associated generation, 
• Defined interconnection study processes tailored to zero-injection configurations, 
and, 
• Clear allocation of operational and planning responsibilities. 
This construct enables a pathway for certain large load configurations to achieve speed to 
reliable power while maintaining system reliability.  A table of MISO’s stakeholder meetings and 
links to respective materials regarding MISO’s ZGIA proposal is provided in Attachment A hereto.  
MISO expects to submit the ZGIA proposal to the Commission in a Federal Power Act Section 
205 filing on, or about July 31, 2026. 
2. 
Large Load Parallel Study Process 
Current load and generation study processes are dependent on each other, requiring one to 
be complete before the next can begin.  Some large load customers are seeking a more integrated, 
predictable experience that reflects the real-world pairing of large loads with the generation needed 
to serve it, without requiring co-location.  MISO is working to address these concerns through the 
proposed Large Load Parallel Study Process.  The Large Load Parallel Study Process will be used 
for studying load greater than or equal to 250MW and will allow MISO to integrate studies for 
planned load and generation to increase speed to approval and optimize network upgrades.   
Through the proposed Large Load Parallel Study Process, an LSE will submit a proposed 
generation and load combination.  The generation and load have separate eligibility requirements 
(e.g., load ≥250 MW, generation nameplate max 150% of identified load need).  The proposed 
Large Load Parallel Study Process will analyze generation and transmission using the same study 
assumptions applied in Generator Interconnection and MTEP.  Both studies will be run 
concurrently and in parallel, with the load/transmission model incorporating the planned 
generation and planned load and finish at approximately the same time—within 120 days.  The 
proposed process is intended to ensure faster and more transparent interconnection arrangements 
for large loads, while offering customers speed-to-power, optimized transmission solutions, and 
greater certainty to support siting, financing, and state coordination.  This solution aligns with the 
spirit of the Commission’s Show Cause Order for interconnection process arrangements to address 
the speed of adding generation to serve large load.  The outcome of the processes is MTEP 
approval of transmission required to reliably facilitate the withdrawal of the load and injection 
rights for the generation. 
MISO initiated the stakeholder process with a presentation of the Large Load Parallel Study 
Process at the July 16, 2026, Large Load Working Group and has requested stakeholder feedback 
on the proposed process.  MISO will continue stakeholder discussions on the Large Load Parallel

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 11 
Study Process at the August 27, 2026 LLWG. Ultimately, MISO expects to file the Large Load 
Parallel Study Process on or about to the end of September. 
IV. 
COMMUNICATIONS 
MISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of 
Practice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the 
designation of more than two persons for service on behalf of MISO in this proceeding and requests 
all communications related to this filing be directed to: 
Christopher D. Supino 
  Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
  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  
 
V. 
NOTICE AND SERVICE 
MISO has served a copy of this filing electronically upon all parties listed on the 
Commission’s eService list, and upon all Tariff customers, MISO Members, Member 
representatives of Transmission Owners and non-Transmission Owners, as well as all state 
commissions within the MISO Region and the Organization of MISO States.  The filing has been 
posted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for 
other interested parties in this matter. 
VI. 
CONCLUSION 
For all of the foregoing reasons, MISO respectfully requests that the Commission accept 
this filing in compliance with the requirements of the Show Cause Order and grant waiver of any 
Commission regulations the Commission deems applicable to this filing in order for the 
Commission to accept it as proposed.  The MISO region currently is resource adequate and MISO’s 
work with recent reforms and partnership with OMS, the states and members has provided a firm 
foundation.  However, with new urgent challenges created by the introduction of new large spot 
loads, additional tools are needed to support this growth and maintain Resource Adequacy going 
forward.  MISO looks forward to bringing new Resource Adequacy tools to LSEs to meet the 
unique challenges associated with the new spot load growth occurring across the footprint.  These 
tools will help support affordability for customers while enabling speed to power in a reliable cost 
effective manner that can meet the new emerging demand.

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 12 
 
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 the Midcontinent Independent 
System Operator, Inc. 
Attachment

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 13 
ATTACHMENT A  
Planning Advisory Committee (PAC) and Large Load Working Group (LLWG) 
MEETING DATE 
MATERIALS 
December 3, 2025 Planning Subcommittee 
(PSC) 
Consideration of Zero-Injection GIA 
January 21, 2026 PAC 
Consideration of Zero-Injection GIA 
January 30, 2026 Large Load Workshop 
 
Large Load Additions Workshop 
February 25, 2026 PAC 
Market Participation and Registration of Co-
Located Load and Generation (PAC-2024-4): 
Consideration of Zero-Injection GIA 
 
Large Load Interconnection Reliability 
Requirements (PAC-2024-1) 
 
April 20, 2026 LLWG 
Large Load Overview 
 
Consideration of Zero-Injection GIA 
Resource: Adequacy Participation and 
Markets and Reliable Operations 
 
New Large Load Issue Submissions 
 
Large Load Interconnection Reliability 
Requirements (LLWG) 
 
 
April 22, 2026 PAC 
Consideration of Zero-Injection GIA 
(Interconnection and Planning Draft Tariff 
Updates): Market Participation and 
Registration of Co-Located Load and 
Generation (PAC-2024-4A) 
 
PAC April 2026: PAC: Large Load Definition 
(PAC-2024-1) 
May 14, 2026 LLWG 
Consideration of Zero-Injection GIA 
(Resource Adequacy, Markets & Reliable 
Operations Draft Tariff): Market Participation 
and Registration of Co-Located Load and 
Generation (PAC-2024-4B) 
 
Large Load Interconnection Reliability 
Requirements (LLWG)

The Honorable Debbie-Anne Reese 
July 20, 2026 
Page 14 
ZGIA Q&A 
May 27, 2026 PAC 
Consideration of Zero-Injection GIA 
(Interconnection and Planning Draft Tariff 
Updates): Market Participation and 
Registration of Co-Located Load and 
Generation (PAC-2024-4A) 
 
Large Load Definition Update (PAC-2024-1) 
 
 Attachment X_ Appendix 19_ZGIA 
Interonnection Agreement_Redlines.docx 
 
June 10, 2026 LLWG 
Consideration of Zero-Injection GIA: Market 
Participation and Registration of Co-Located 
Load and Generation (PAC-2024-4B) 
 
Large Load Interconnection Reliability 
Requirements (LLWG) 
 
Reliability Requirements Technical 
Compendium 
June 29, 2026 LLWG 
Market Participation and Registration of Co-
Located Load and Generation Marc Keyser 
11:30 Consideration of Zero-Injection GIA 
(PAC-2024-4B) 
 
Large Load Operational Reliability 
Requirements 
 
Large Load Reserve Product Enhancements 
(LWLG-2026-2) 
July 16, 2026 LLWG 
Posted meeting materials 
Upcoming Meetings: 
July 27, 2026 LLWG 
August 12, 2026 LLWG 
August 27, 2026 LLWG 
September 23, 2026 LLWG 
October 8, 2026 LLWG 
October 29, 2026 LLWG 
November 16, 2026 LLWG 
Meetings primarily will address the non-
resource adequacy aspects of large load 
integration and compliance with the Show 
Cause Order