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A good portion of Load Modifying Resources (LMR) are currently dually registering as an Emergency Demand Response (EDR). Since EDRs are called very late in MISO's Emergency Operating Procedures, one step after when LMRs are called upon, the dual registration provides them an effective strategy to receive capacity payments with virtually no chance of having to perform. This particular issue and potential solution were previously included as a part of MISO's broader LMR Reforms (RASC-2019-9) which had a target implementation date of September 1, 2027, for the Planning Year 2028-2029. With the recent concerns and recommendation provided by MISO's Independent Market Monitor (IMM) and some stakeholders, MISO has decided to split this issue out as a separate issue to implement the associated changes earlier than 2027/2028.