{"document":{"slug":"answer-er27-25-miso","title":"MISO Answer to Comments and Protests on the Large Load Addition Resource Study","issued":"2026-11-09","accession":"20261109-5205","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"MISO","kind":"motion for leave to answer and answer","file":"sources/originals/20261109-5205_FINAL AnswerER27-25-000.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261109-5205","sha256":"8cf8065935fae99e4f035e6bf7512455a3721c9f4b2fcd6dc2166845fe46ae1f","pages":30,"tokens":8990,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":240,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nMidcontinent Independent \n) \nDocket No.  ER27-25-000 \nSystem Operator, Inc. \n) \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nMOTION FOR LEAVE TO ANSWER AND ANSWER OF \nTHE MIDCONTINENT INDEPENDENT SYSTEM  \nOPERATOR, INC. TO COMMENTS AND PROTESTS \n \n \n \n \n \n \n \n \n \n \n \n \nThe Midcontinent Independent System Operator, Inc. (“MISO”) submits1 this Motion for \nLeave to Answer and Answer to the comments and protests filed in the above-captioned docket.  \nThis proceeding involves a filing made under section 205 of the Federal Power Act (“FPA”)2 to \nimplement the proposed Large Load Addition Resource Study (“LARS”) process.  In Docket No. \nER27-25-000, MISO proposed to amend its Attachment X, Generator Interconnection Procedures \n(“GIP”), and Attachment FF to provide a framework for the accelerated study of the addition of \n200 MW or greater loads together with new generation resources that are electrically proximate to \nthose loads.3   \nMISO seeks leave to respond to the submitted comments and protests due to the importance \nof the LARS process in addressing the integration of large loads onto MISO’s Transmission \n \n1  \nSee Rules 212 and 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission \n(“FERC” or “Commission”), 18 C.F.R. §§ 385.212 and 213 (2026). \n2  \n16 U.S.C. § 824d. \n3  \nSee Midcontinent Indep. Sys. Operator, Inc., “Large Load Addition Resource Study Process,” Docket No. ER27-\n25-000 \n(Oct. \n2, \n2026) \n(“LARS \nFiling”); \nthe \nGIP \nand \nAttachment \nFF \nare \navailable \nat: \nhttps://www.misoenergy.org/legal/rules-manuals-and-agreements/tariff/."},{"page":2,"startToken":240,"endToken":579,"text":"2 \nSystem.4  Also, because a number of commenters misstate the intent and background of LARS, \nraise extraneous issues, seek clarifications, and/or propose changes, MISO requests permission to \nrespond to the intervenors’ arguments to clarify the record and assist the Commission with its \ndecision-making. \nI. \nMOTION FOR LEAVE TO FILE ANSWER \nUnder the Commission’s rules, answers to protests generally are not permitted.5  \nNonetheless, the Commission waives this requirement where an otherwise prohibited answer \nwould clarify the issues under consideration, ensure completeness of the record or assist the \nCommission in its decision-making.6  Consistent with this precedent, MISO asks for leave to \nsubmit this Answer to the protests filed in the above-captioned docket7 to provide additional \ninformation related to certain issues raised by the intervenors and assist the Commission in its \ndecision-making.  MISO’s response is particularly warranted given how LARS fits in with MISO’s \nbroader large load framework.  Accordingly, MISO respectfully requests that Rule 213(a)(2)8 be \nwaived and that the Commission accept this Answer for good cause shown. \n \n4  \nMISO uses the uncapitalized term “large load” in this answer rather than the “Large Load” term proposed in \nMISO’s pending Large Load Interconnection Reliability Requirements filing.  This is done to avoid confusion \nbecause that definition remains pending before the Commission and because, given the 200 MW threshold for \nentry into LARS, not all “Large Loads” will be eligible to be a “LARS Associated Load.” \n5  \nSee 18 C.F.R. § 385.213(a)(2)(2026). \n6  \nSee, e.g., Midcontinent Indep. Sys. Operator, Inc., 169 FERC ¶ 61,173, at P 24 (2019) (accepting MISO’s answer \nto protests that assisted in the decision-making process); Texas Eastern Transmission, LP, 122 FERC ¶ 61,205, \nat P 8 (2008) (accepting answer that completed the record); California Independent System Operator Corp., \n105 FERC ¶ 61,284, at P 10 (2003) (accepting answer that clarified the issues under consideration). \n7  \nThere is no prohibition under the Commission’s rules for submitting answers to comments. \n8  \n18 C.F.R. § 385.213(a)(2)(2026)."},{"page":3,"startToken":579,"endToken":925,"text":"3 \nII. \nEXECUTIVE SUMMARY \nMISO proposed LARS as part of its response to the Commission’s Show Cause Order,9 \nand as a standalone procedure that will immediately improve the study process for large loads \nlooking to connect to MISO’s system and create significant opportunities for lowering the costs of \nmitigating the impacts of integrating the largest of large loads onto the MISO Transmission \nSystem.  As highlighted in many of the comments filed in this docket, the energy industry is \nchanging quickly, and many states are experiencing significant new load additions in the near-\nterm.10  LARS is one of MISO’s proposed solutions to more effectively address this problem.  It \nis a standalone process that enables the optimization of transmission solutions by allowing MISO \nto study both the large load and the generation that will serve it at the same time, promoting process \nefficiency, cost responsibility, and affordability.  The tool offers a vast improvement over the status \nquo leveraging available efficiencies in other MISO processes.  \nMISO appreciates the opportunity to respond to the protests and comments in support it \nreceived in response to its LARS filing.  In particular, MISO appreciates the opportunity to clarify \nmisconceptions and concerns surrounding cost impacts.  LARS, in fact, provides an opportunity \nto better mitigate cost impacts of new Large Load integration over the status quo for LSEs that \nchoose to leverage the tool.  While LARS was well-received by a wide variety of stakeholders, \n \n9  \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”). \n10  All LARS Comment citations in this Answer are from Midcontinent Indep. Sys. Operator, Inc., “Large Load \nAddition Resource Study Process,” Docket No. ER27-25-000 (Oct. 2, 2026). See Data Center Coalition LARS \nComments at 2-3; NIPSCO LARS Comments at 2-4; MISO Transmission Owners LARS Comments at 6-9; \nEntergy and Cleco LARS Comments at 10-11; Mississippi Public Service Commission and the Louisiana Public \nService Commission (the “Southern Regulators”) LARS Comments at 1-2; and Alliant Energy Corporation and \nConsumers Energy LARS Comments at 15-16."},{"page":4,"startToken":925,"endToken":1228,"text":"4 \nthere are certain aspects of the LARS process that warrant additional explanation given the \ncomments received.   \n \nLARS Responds to the Commission’s Show Cause Order \nFirst and foremost, LARS responds to several of the concerns raised in the Commission’s \nShow Cause Order.11  LARS addresses the Commission’s concern regarding the speed at which \nlarge loads are seeking to interconnect,12 by enabling the generation associated with the most \nresource intensive (i.e., the largest) large loads to be aligned and studied on a similar timeline to \nthat currently experienced for Expedited Project Reviews (“EPRs”) of local transmission projects \nassociated with large load additions.  LARS also enables the potentially-significant cost saving \nefficiencies that the Show Cause Order sought for electrically proximate large loads and associated \ngeneration by allowing for a more complete picture of the localized Transmission System and the \nidentification of an optimized set of Network Upgrades to address the impacts of both the load and \nthe generation, creating opportunities for more efficient, and potentially less costly Network \nUpgrades that could be identified in the separate load and generation studies that occur today.13   \n \nLARS Helps Mitigate Cost Shifting, Supports Cost Causation Principles, and Addresses \nUrgent Needs Now Without Prejudicing Subsequent Large Load Reforms \n \nSecond, MISO recognizes the importance of developing a cost allocation framework that \nwill prevent cost shifting and align with the Commission’s cost causation principles.  As MISO \nexplained in its transmittal letter, aspects of the broader cost allocation framework for large loads \n \n11  Show Cause Order at P 113. \n12  Show Cause Order at P 120 (expressing concern that “the relative speed and concentration at which large loads \nare seeking to interconnect appears to be outpacing the addition of new generation, which in turn heightens \nreliability risks and drives up costs to ratepayers.”). \n13  Show Cause Order at P 106-109."},{"page":5,"startToken":1228,"endToken":1589,"text":"5 \nand implementing agreements are still being developed by MISO, the Transmission Owners, and \nother stakeholders but will ultimately be part of MISO’s response to the Show Cause Order to be \nfiled on November 16.  MISO has committed to incorporating the large load reforms being \ndeveloped in response to the Show Cause Order with LARS as they become accepted by the \nCommission.14  Even without these, the LARS proposal includes a Tariff mechanism for \nidentifying and assigning any necessary transmission Network Upgrades associated with the \ngeneration/load pair to the Transmission Customer or the Interconnection Customer.   \nMISO understands the desire of some protestors to delay LARS until all of MISO’s \nproposed large load reforms can be considered together.  However, such a delay would frustrate \nthe goals of the Show Cause Order and needlessly sacrifice the benefits of critical reforms for \nratepayers and stakeholders without corresponding benefit.  Acceptance by the requested effective \ndate is needed to give MISO and its stakeholders the time to establish internal processes and \nimplement LARS by the first quarter of 2027.  Rejecting or delaying LARS implementation will \nnot slow down the pace of Large Load integration.  MISO has processed more than 32,734 MW \nof large load additions through its EPR process anticipates that it will be required to process \nanywhere from an additional 5,000 MW to 15,000 MW in Q1 of 2027.  If LARS is not available, \nthe result would not be that large load studies will stop until all elements of Large Load reform \nhave been accepted by the Commission.  Rather, large loads will continue to be studied through \nthe EPR process, which does not allow MISO to identify optimized transmission solutions or \nutilize a non-GIA generator as a mitigation option.  The cost, timing, and efficiency benefits of \n \n14   Many of these additional elements will become applicable to LARS automatically because all loads included in \nLARS are “Large Loads” and thus requirements applicable to Large Loads such as the transparency dashboard, \nwill apply.  Where reconciliation of Tariff versions is required in order to apply forthcoming reforms to LARS, \nMISO has committed to make such filings promptly.  See, LARS Transmittal Letter at n 66."},{"page":6,"startToken":1589,"endToken":1872,"text":"6 \nLARS should not be delayed pending the approval of other reforms, especially since MISO has \ncommitted to integrating those reforms into LARS upon their acceptance.  \n \nLARS Does Not Adversely Impact Projects in the Existing Interconnection Queue \nThird, MISO has structured the LARS process to not harm projects in the existing \ngeneration interconnection queue.  LARS projects are not displacing current projects in the \nDefinitive Planning Phase (“DPP”) queue and claims that LARS projects will take the transmission \nheadroom capacity of projects in future queue cycles are speculative.  LARS projects will identify \noptimized transmission solutions that could ultimately create more headroom on the transmission \nsystem with their potentially larger Network Upgrades, and any LARS projects and their \nassociated upgrades may be used to help alleviate constraints observed in queue cycle studies.  \nMoreover, maintaining LARS as a process separate from the DPP better insulates Interconnection \nCustomers from bearing the cost of Network Upgrades needed to accommodate generation serving \na LARS Associated Load.   \n \nLARS Is Appropriately Scoped to Address the Unique Challenges and Opportunities \nAssociated with the Largest Large Loads and Generation Pairs  \nFourth, the LARS Application and strict eligibility requirements are designed to ensure \nthat only genuinely shovel-ready generation-and-load pairs participate in LARS.  MISO structured \nLARS to permit participation by all developers and resource types.  The process requires \nTransmission Customers to collaborate with other parties before submitting a LARS Application. \nRather than making Transmission Customers (commonly LSEs) gatekeepers of the LARS process, \nthis requirement recognizes the essential role Transmission Customers play in integrating large \nloads onto the grid.  Limiting loads to a minimum of 200 MW and requiring commercial \nagreements will act as a natural barrier to speculative projects and will result in only truly"},{"page":7,"startToken":1872,"endToken":2176,"text":"7 \ncommitted generation and load pairs applying.  Following MISO’s experience with loads \nparticipating in its EPR process, MISO’s 200 MW threshold for large loads participating in LARS \nis reasonable and will serve to ensure that LARS is only used by the largest load participants, \nwhich enables MISO to identify optimized transmission solutions.  MISO does not believe that \nimplementing a sunset on LARS is appropriate at this juncture but is committed to reviewing the \nprocess on a regular basis to determine whether there continues to be sufficient demand for it.  \n \nLARS Meets the Independent Entity Variation Standard; It is An Innovative Solution \nTailored to Specific Needs and is Consistent with the Goals of Commission Orders. \n \nFinally, MISO has met the standard for independent entity variation as serial studies of the \ngeneration side of LARS projects are necessary to facilitate the quick addition of these projects to \nthe grid and LARS will not change DPP rules.  LARS is limited in scope both by its strict eligibility \nrequirements and because only thirty generation and load pairs may be studied each year.  Thus, \nthe LARS proposal meets the goals of Order Nos. 2003 and 2023 by expediting the development \nof new generation, while protecting reliability and ensuring that rates are just and reasonable,15 as \nwell as by establishing strict eligibility requirements to meet readiness principles of the Orders and \nensuring only truly commercially viable projects participate.16  \n \nIII. \nANSWER \nTwenty-one entities filed substantive Protests or Comments in response to the LARS filing.  \nOf that number, ten parties supported LARS, recognizing and confirming the need to act \nexpeditiously to address the dramatic growth in large load development.  Many of these supporters \nrecognize in their comments that LARS provides a path to avoid studying large loads and \n \n15  Order No. 2003 at 11.  \n16  Order No. 2023 at 454-455."},{"page":8,"startToken":2176,"endToken":2456,"text":"8 \nassociated generation through separate processes on different schedules and would produce a more \nrealistic picture of the grid, which could create opportunities for MISO to potentially optimize \nNetwork Upgrades.17  The commenters recognized that pairing large loads with generation to \nsupport them is one way to reduce the need for significant transmission upgrades that may be \nneeded if only the generation or load were interconnecting to MISO’s system.18  Eleven parties \nsubmitted either protests or requests for clarification on certain details of the LARS proposal.  \nIn this answer, MISO seeks to clarify certain aspects of the LARS proposal including that: \n(1) it is responsive to the concerns underlying Commission’s electrically proximate arrangements \ndiscussion described in the Show Cause Order;  (2) it provides an effective vehicle to help support \nresource adequacy in the face of impending Large Load additions; (3) it provides an efficient and \nreasonable parallel study process that will address urgent needs now while will also working with \nMISO’s forthcoming Large Load reforms; (4) it will help address affordability and identify \noptimized transmission solutions; (5) it will not negatively impact projects in the existing \ninterconnection queue; (6) its eligibility requirements are appropriate and will limit the number of \napplicants to those that are commercially ready; and (7) it is consistent with the goals of the Show \nCause Order and Commission principles established in other relevant Commission Orders.  \nMISO’s LARS proposal is just and reasonable and not unduly discriminatory.  As such, MISO \n \n17  Consumers Energy and Alliant LARS Comments at 2; Data Center Coalition LARS Comments at 4; DTE \nLARS Comments at 2; Electricity Customer Alliance (“ECA”) LARS Comments at 1.  \n18  Entergy and Cleco LARS Comments at 2."},{"page":9,"startToken":2456,"endToken":2787,"text":"9 \nrespectfully asks that the Commission accept its proposal to enable MISO to implement this \nneeded study process by the first quarter of 2027.  \nA. \nLARS is Responsive to the Commission’s Show Cause Order  \nThe Electrically Proximate Requirement \nMany of the protesters suggested that how MISO defined “electrically proximate” is not \nresponsive to the Commission’s Show Cause Order.19  The protesters emphasize that the \nCommission defined “electrically proximate” as a “large load that is located no more than two \nsubstations away from the generating facility.”20  The protestors argued that MISO’s proposal of \nallowing the generation and load pair to be located in the same Local Resource Zone (“LRZ”) to \nmeet the electrically proximate requirement fails to meet the Commission’s expectations.21  But \nthe Commission expressly stated that it would “consider proposed revisions to this definition that \nensure it is appropriately tailored to MISO’s transmission system.”22  MISO is expanding upon the \nCommission’s definition to fit its needs and resource adequacy construct.  LARS does not limit \nthe electrical or physical distance between the load and generator within the same LRZ to provide \nmaximum flexibility for the generation/load pairs.  MISO determined that requiring the generation \nand load to be located within the same LRZ enabled flexibility while still allowing it to identify \noptimized Network Upgrade solutions. In developing LARS, MISO concluded that defining a \nmaximum distance based on substations would impede the flexibility of large loads and \n \n19  Clean Energy Trades LARS Comments at 18; the Community Organizations and Clean Energy Advocates (the \n“Advocates”) LARS Comments at 37-38; Consumer Advocates LARS Comments at 9; OMS LARS Comments \nat 8; and the Southern Minnesota Municipal Power Agency and WPPI Energy (the “Midwest TDUs”) LARS \nComments at 5-6.  \n20  Show Cause Order at P 112.  \n21  MISO clarifies that both the large load’s point of withdrawal (“POW”) and the generator’s point of \ninterconnection (“POI”) as well as the facilities must be located in the same LRZ.  \n22  Show Cause Order at P 112."},{"page":10,"startToken":2787,"endToken":3176,"text":"10 \nInterconnection Customers to site their projects in a way that made the most sense for the parties.  \nMoreover, in the context of MISO’s Transmission System, such a limit would be arbitrary.  MISO \nnotes that depending on a transmission line’s voltage level, two substations could still be hundreds \nof miles apart and does not necessarily result in generation and load being geographically near \neach other.23  On other parts of MISO’s Transmission System, several substations can be fairly \nclose together such that a geographically proximate Generating Facility and large load may have \nvery limited options for interconnection.   \n \nUnder the LARS construct, there is no requirement that the Generating Facility limit its \noutput in real time to fluctuations in the demand of the large load.24  This is not the mechanism \nLARS uses to create value and potential savings.  Thus, a bus or other electrical distance limit is \nnot a necessary component of the LARS construct.  The opportunities for lowering the Network \nUpgrade costs of interconnecting and providing generation to the large load come from the LARS \nprocess’s ability to include generation that does not yet have a Generation Interconnection \nAgreement (“GIA”) in the load study and to model the proposed large load in the generation study.  \nLARS enables this to be done with confidence because LARS places requirements on both the \nLARS Associated Transmission Customer and the Interconnection Customer that are not otherwise \nrequired of loads and generators that greatly reduce both the opportunities for speculative \n \n23  MISO, Transferred Transmission Facilities, available at: https://www.misoenergy.org/legal/transferred-\ntransmission-facilities/#t=10&p=0&s=FileName&sd=asc. See for example, ITC Midwest: Lehigh to Raun \n345kV 116 miles, available at: \nhttps://cdn.misoenergy.org/ITC%20Midwest%20Transmission%20Owner%20Transferred%20Facilities%2020\n26390628.xlsx; ATC: Briggs Road to North Madison 345kV 161 miles, available at: \nhttps://cdn.misoenergy.org/American%20Transmission%20Company%20Transferred%20Facilities%20202639\n0603.xls; ALLETE MP/MHEB: Iron Range to Dorsey 500kV 357 miles (224 to the border), available at: \nhttps://cdn.misoenergy.org/ALLETE%20MP%20SWLPC%20Transferred%20Facilities%202026390599.xlsx.  \n24  MISO has proposed a process to accommodate such arrangements, through its ZG Interconnection Service \nprocess, which currently is pending before the Commission in Docket No. ER26-3552-000.  LARS does not seek \nto duplicate ZG Interconnection Service but instead provide a different tool for different situations."},{"page":11,"startToken":3176,"endToken":3526,"text":"11 \nsubmissions and the potential for cost shifts due to the load or generation not being built.25  With \nboth the load and Generating Facility accounted for in the same study process, their impacts at \npeak operation (i.e. maximum injection of the Generating Facility and full amount of Transmission \nService requested for the large load) can be accounted for in the modeling stage, thereby avoiding \nthe potential for requiring Network Upgrades in one study that are more expensive or different \nfrom what would be identified if both were studied in isolation.  This delivers the value of \noptimized Network Upgrades but using a different, innovative approach, one which is tailored to \nthe needs of the MISO region and the other MISO processes.  \nWhile some protestors complain that a Local Resource Zone is too large to address the \nCommission’s “electrically proximate” discussion, none have provided evidence to suggest that \nMISO’s LRZ-based requirements will not allow for a more optimized set of Network Upgrades \nthan is possible to identify under current processes.  Nor do protestors recognize that that, while \nadjacent large loads and Generating Facilities may produce the most significant Network Upgrade \noptimization, limiting LARS on that basis would—in aggregate leave the efficiency and cost \nsavings LARS promises by making it unusable in the many situations where it could still produce \na more optimized set of Network Upgrades.  In this respect, MISO also notes that LARS is limited \nto large loads and Generating Facilities that seek at least 200 MW of Transmission Service and \n200 MW of Interconnection Service respectively.  Given this scale, the potential efficiency and \ncost savings for Network Upgrade optimization may easily span an LRZ. \n \n25  It is highly unlikely that a Transmission Customer and Interconnection Customer would choose to enter LARS if \nthey did not have a high degree of commitment to each other’s projects being built.  And if one does not \nmaterialize, new service or a new study reflecting the impact of only the facility proposed to remain is required \nfor the Generating Facility or Large load to maintain their service, thus avoiding cost shift risks."},{"page":12,"startToken":3526,"endToken":3785,"text":"12 \nMoreover, while LARS sets the outer boundaries at the borders of a Local Resource Zone, \nit nonetheless creates a strong incentive for the LARS Associated Generating Facilities and LARS \nAssociated Load to site as close together as is practical in order to maximize potential Network \nUpgrade cost savings of a common set of Network Upgrades.  MISO’s LRZ approach thus can be \nconsidered an “electrically proximate plus” construct because it provides benefits both to those \nlarge load and Generating Facility pairs that can site next to each other while also providing \nbenefits to those further apart.  It should not be objectionable that LARS provides efficiency \nbenefits in more situations than the smaller subset contemplated by the Show Cause Order. \nFinally, allowing Generating Facilities participating in LARS to interconnect at multiple \nPOIs furthers the “electrically proximate plus” benefits of LARS.  This provides Interconnection \nCustomers with the necessary flexibility to serve extremely large loads and in way that MISO can \noptimize any necessary transmission solutions.  As Ms. Drake explained in her testimony, \n“[u]ltimately, limiting the generation and LARS Associated Load to locations within the same \nLRZ ensures deliverability of the generation to the LARS Associated Load because it avoids \npotential capacity import / capacity export limitations for the individual LRZ and also avoids price \nseparation between the paired generation and LARS Associated Load.”26  MISO therefore \ncorrectly determined that the LRZ was the appropriate limitation on electrically proximate \ngeneration and load pairs as adequately fitting within its current construct and providing maximum \nflexibility for participants.    \n \n26  Drake LARS Testimony at 40-41."},{"page":13,"startToken":3785,"endToken":4110,"text":"13 \nLARS Heeds the Call for Speed to Power and Supports Resource \nAdequacy  \nThe immensity and rate of large load additions across the United States is requiring unique \nproposals.  While MISO had already considered creating a process to study load with generation \nat the same time, the Commission’s Show Cause Order underscored the need to establish the study \nprocess sooner rather than later.  LARS advances that objective within the MISO region by \nproviding a process through which significant new large loads and generation intended to support \nthat load can be studied on an accelerated and coordinated basis.  LARS is another complementary \ntool that harmonizes with MISO’s large load framework including its recently proposed ZGIA \nprocess for co-located load.  Each of the proposed processes seek to address different challenges \nposed by large load growth and LARS provides a pathway for paired load and generation to be \nstudied and commence service together.  \nThe Commission recognized in its Show Cause Order that “the relative speed and \nconcentration at which large loads are seeking to interconnect appears to be outpacing the addition \nof new generation, which in turn heightens reliability risks and drives up costs to ratepayers” and \nstated it was “concerned that MISO and load serving entities are unable to plan adequate generation \nto serve all load at the pace such load seeks to connect.”27  MISO developed LARS in the context \nof this dramatic large load growth and is proposing the LARS process to help address that growth.  \nThe strict entry requirements for LARS both support its intended benefits and underscore that \nLARS is not, and should not be, a replacement for the DPP.28  Rather, it is intended to be a narrowly \nscoped but powerful process.  LARS speeds up the interconnection process for a select number \nand kind of project where the large load has formally partnered with generation for a period of 15 \n \n27  Show Cause Order at P 120.  \n28  See id. at 12."},{"page":14,"startToken":4110,"endToken":4433,"text":"14 \nyears.  LARS will provide a path for the interconnection of both large loads and supporting \ngeneration pairs in a parallel 120-day study process.  This will enable MISO to optimize \ntransmission solutions for these pairs when studying their impacts at the same time.  \nB. Large Load Cost Allocation Framework  \nSeveral protesters oppose LARS because it fails to address the cost-shifting concerns and \nlacks transparency on costs.29  First, LARS does not create any new cost shift opportunities, but \nLARS does mitigate risks that already exist.  Further, as explained in the transmittal letter, MISO \ncontinues to work with stakeholders to develop pro forma cost recovery agreements as part of its \nLarge Load Project Review (“LLPR”) process, which will be proposed as part of MISO’s response \nto the Commission’s Show Cause Order.  MISO also will address transparency for Large Load-\ndriven Network Upgrade costs.  This work is important and MISO has committed to integrating \nLARS with its other large load reforms as they are accepted by the Commission and become \navailable for use.  However, MISO disagrees that the LARS is incomplete or should not be \naccepted unless and until LLPR and its related reforms have been accepted by the Commission.   \n \nLARS significantly improves upon current processes available to study large loads.  With \nrespect to cost responsibility, accountability, and cost shifting, the LARS filing includes Tariff \nlanguage stating: \nOnce MTEP approval occurs for the LARS Associated Load, the LARS Associated \nTransmission Customer remains responsible for the identified BRPs and Other \nassigned projects even if such LARS Associated Load does not commence service \nor commences service for less than the total amount of the LARS Associated \nLoad….30 \n \n29  Anna Farrar LARS Comments at 3; the Advocates LARS Comments at 13; Consumer Advocates LARS \nComments at 6; OMS LARS Comments at 5; and Google LAR Comments at 3.  \n30  See Tariff Sheets included with LARS Filing at Attachment FF, proposed section I.D.1.b.ii.g."},{"page":15,"startToken":4433,"endToken":4725,"text":"15 \nThis language clearly associates the non-GIP local Transmission Facilities needed to accommodate \nTransmission Service for a large load undergoing the LARS study process with the LARS \nAssociated Transmission Customer and assigns the cost of these facilities to the LARS Associated \nTransmission Customer even if the large load is ultimately not built.  MISO and the MISO \nTransmission Owners will include in their Large Load filing(s) due on November 16, 2026, the \npro forma cost recovery agreements that provide an enforcement mechanism for the obligations \nof Transmission Customers seeking Transmission Service to serve Large Loads.  MISO also has \ncommitted to integrate the Large Load reforms into the LARS process through an appropriate \nfiling once those reforms are accepted, and MISO is willing to accept a compliance directive \nrequiring such a filing should the Commission deem this necessary. However, MISO cannot \npredict how long it will take for these further reforms to be accepted by the Commission and \nbecome effective.  What MISO can predict is that large loads will continue to move forward and \nrequire expedited study of Network Upgrades to interconnect them. Delaying or denying LARS \nwill not address the concerns raised by protests.  Rather, it will simply mean that MISO will be \nrequired to use current processes, such as EPR, to study these large loads.   \nLARS significantly improves upon current study processes, addresses numerous concerns \nexpressed in the Show Cause Order, and can be applied to the next group of large load integrations \neven if other reforms are not yet accepted.  MISO does not claim that LARS is a panacea or that it \nwill obviate the need for forthcoming additional reforms such as pro forma agreements and \ntransparency mechanisms.  But the fact that all reforms may not be available when LARS"},{"page":16,"startToken":4725,"endToken":5045,"text":"16 \ncommences would be a poor reason to deny the MISO footprint the clear benefits that LARS can \nprovide for processing large loads and their associated generation integrations in the near term. \n \nLARS is not creating a new cost-allocation problem. MISO has historically applied \ndistribution factor (“DFAX”) thresholds for cost assignment of GIPs.  In situations where a \ngenerator has an impact but is below the DFAX threshold, the cumulative impact of all \nInterconnection Requests may create a transmission need that must be resolved in MTEP or a \nfuture DPP cycle.  LARS is no different.   \nThe EPR process was historically facilitated by MISO to study projects out of the regular \nMTEP cycle when there was an urgent system need that would be jeopardized unless an expedited \nsystem impact study was conducted.31  EPRs allow for the incremental addition of transmission \nand load to the electric grid.  The recent and dramatic acceleration of these EPR submittals drives \nthe need for more generation to meet that increased spot load growth.  An example of this is \ndemonstrated in the figure below, which shows that individual EPR requests continue to increase \nin load size and transmission investment.32   \n \n31  MISO, MTEP25 Report 36 at 6(2025), https://cdn.misoenergy.org/MTEP25%20Report731648.pdf (“MISO \nMTEP 25 Report”) (“MISO has worked with stakeholders to refine the Expedited Project Review (EPR) process \nto advance urgent transmission projects outside the standard MTEP cycle — with the increased use of this process \nbeing a good indication of how quickly system needs are emerging.”).  \n32  MISO, EPR Statistic Update, Expedited Project Review Technical Studies Task Force (EPR-TSTF), Slide 9, \nNov. 3, 2026, available at: https://cdn.misoenergy.org/20261103%20EPR-\nTSTF%20Item%2003%20MISO%20EPR%20Statistics UPDATED792865.pdf? t id=5OVCdhOREsRw7Ezo\nAr-xAA%3d%3d& t uuid=Toha-\ns9SSzWtdq2zatRW5g&_t_q=EPR&_t_tags=language%3aen%2csiteid%3a11c11b3a-39b8-4096-a233-\nc7daca09d9bf%2candquerymatch&_t_hit.id=Optics_Models_Find_RemoteHostedContentItem/792865&_t_hit.\npos=4."},{"page":17,"startToken":5045,"endToken":5252,"text":"17 \n \nThis EPR data supports MISO’s assertion that load growth is increasing dramatically in the MISO \nfootprint and will likely continue to do so in 2027 and beyond.  Moreover, based on internal \nanalysis, with this increase in EPR submittals, MISO has also seen an increase in the average \nNetwork Upgrade cost in 2026.33  As the load margins grow tighter, larger investments are needed \nto mitigate constraints as MISO is relying on more generation transfers to cover the load.   \nLARS is one component of MISO’s answer to this problem.  And it is needed urgently.  By \nenabling large loads (≥200 MW) to pair with generation, MISO can study the pair in the LARS \nprocess and potentially identify optimized transmission solutions.  The EPR process only studies \nload and cannot incorporate a generator as a potential mitigation solution unless it has a GIA, \nwhich can delay getting the load interconnected as it is waiting for generation to be studied and \ncompleted.  LARS improves upon this status quo, provides speed to power for the largest of large \n \n33  Fifty-six Load Requests were approved as part of MTEP26 with an average cost of $145,000,000 per project. For \nlarge loads greater than 200 MW, the average cost was $201,000,000."},{"page":18,"startToken":5252,"endToken":5561,"text":"18 \nloads, and significantly decreases the opportunities for cost shifting even while other reforms \nremain pending.    \nLARS is a solid building block in MISO’s large load framework and can be implemented \nindependently from the forthcoming LLPR filing.  The LARS process does not create new \nopportunities for cost shifting and, even without the LLPR process, imposes more accountability \non the Transmission Customer than MISO’s current processes do.  Finally, there is nothing in the \nLARS proposal that would prevent a state regulator from allocating costs of a BRP or Other project \nmore granularly to a specific retail customer.34 \nC. LARS Will Not Harm the Existing Queue \nMISO understands that many stakeholders are concerned that LARS projects will take \navailable transmission capacity or headroom from other projects currently in the DPP queue.35  \nThe argument is that since LARS and DPP interconnection customers are vying for the same \ncapacity, adding LARS projects to the transmission system before DPP projects will necessarily \nreduce the transmission headroom available for DPP projects.36  The assertion is that because \nLARS projects will be studied first, they will have priority on MTEP upgrades that could have \notherwise been utilized to mitigate constraints for a previously queued DPP project that is subject \nto a longer study process.37   \n \n34  Nor does LARS intrude on the authority of RERRAs to establish rules and policies for their Load Serving Entities. \n35  See Advanced Energy United and Solar Energy Industries Association (“SEIA”) at 10; the American Clean Power \nAssociation and the Southern Renewable Energy Association (“Clean Energy Trades”) at 15; Ms. Farrar at 2; the \nAdvocates at 19; and the Consumer Advocates at 11. \n36  See Clean Energy Trades at 20 (“LARS projects would gain priority access to transmission capacity and avoid \nNetwork Upgrades they would otherwise trigger, shifting costs to DPP customers and other transmission \ncustomers.”).  \n37  See id."},{"page":19,"startToken":5561,"endToken":5904,"text":"19 \nMISO has taken numerous steps to protect current DPP queue projects from losing \navailable transmission capacity.  First, each LARS study cycle model will be built based on the \nexisting MTEP model, which would not remove any available headroom from active DPP queue \nprojects using previous MTEP models.38  All approved projects which have gone through the \nMTEP, EPR, ERAS, or DPP processes are included in the base LARS model.  All load studies \nfollow the same concepts outlined in MTEP but in a more expedited manner.  Second, MISO \nalready has several processes in place to address these kinds of situations.  MISO’s Business \nPractice Manual 015 for generation interconnection states that in order to mitigate a constraint, \nMISO will check the MTEP appendices and discuss the issue with the impacted transmission \nowners to determine if there already exists a planned project that will alleviate the constraint.39  \nThe base case for each DPP cycle is not updated once the study process starts except for generation \nchanges due to withdrawals or generator retirements.  This will ensure that the transmission \ncapacity that is available for DPP projects is not being taken away by LARS projects approved \noutside of the DPP cycle.40   \nSeveral commenters also implied that LARS projects will result in higher network upgrade \ncosts for DPP projects, but there is no evidentiary support for this assertion and the proposed LARS \ntariff redlines require LARS participants to pay all Network Upgrade costs associated with their \nproposed project even if they end up withdrawing it.  Moreover, any LARS projects and their \n \n38  See Drake LARS Testimony at 32-33. \n39  BPM \n15, \nSection \n6.1.1.1. \nMISO’s \nBusiness \nPractices \nManuals \ncan \nbe \nfound \nat: \nhttps://www.misoenergy.org/legal/rules-manuals-and-agreements/business-practice-manuals/. \n40  To the extent that protestors’ argument is that hypothetical future Interconnection Customers may see diminished \nTransmission headroom as a result of MISO adopting the LARS process, such an argument would be entirely \nspeculative.  LARS Applicants will pay for the Network Upgrades their projects require and, like other customers, \nmay create headroom or use it."},{"page":20,"startToken":5904,"endToken":6214,"text":"20 \nassociated Network Upgrades approved as part of the LARS process can be used to mitigate \nconstraints in DPP cycles, which may also benefit DPP projects.41  \nD. LARS Application and Eligibility Requirements  \ni. LARS is Not Preferential to LSEs.  \nA common complaint among protestors was that LARS enables Load Serving Entities \n(“LSEs”) to gatekeep who can participate in the process.42  MISO disagrees with this assessment \nfor several reasons.  First, under MISO’s current processes, only Transmission Owners may submit \nEPR requests – Interconnection Customers have never been allowed to submit these kinds of \nrequests to MISO.  LARS does not change this dynamic.  LARS is a load-driven process, and an \nInterconnection Customer cannot require a Transmission Customer to scope their Transmission \nService request around a generator they have not chosen to pair with.  Thus, it is logical to require \nthe Transmission Customer to act as the applicant.  To the extent that an Interconnection Customer \nhas developed an agreement to work together with a Transmission Customer, the requirement that \nthe Transmission Customer initiate the application provides no barrier to participation.  If no such \nagreement exists, then the pairing of load and generation in a coordinated study process would be \npremature and speculative. LARS does not prevent Independent Power Producers (“IPPs”) from \ncompeting to supply energy to large loads under applicable state and or utility-led RFP processes.  \nHowever, for an accelerated study process to have the level of certainty needed to function, the \npairing must be established prior to submitting a LARS Application.  LARS takes generation and \nTransmission Customer pairings as it finds them.  It is not intended as an avenue for exploring \n \n41  See Clean Energy Trades LARS Comments at 20; the Advocates LARS Comments at 18-19; and OMS LARS \nComments at 4.   \n42  See Clean Energy Trades at 6; the Advocates at 12; Geronimo Power at 5-6; and Google at 9."},{"page":21,"startToken":6214,"endToken":6514,"text":"21 \ncommercial relationships that do not yet exist, and this is not required for the proposal to be just, \nreasonable, and nondiscretionary.  \nSecond, while LARS is not intended to change well-established roles and responsibilities \nfor who can submit projects needed to facilitate new load into MTEP, MISO has carefully \ndeveloped LARS so as to not impede commercial relationships between Interconnection \nCustomers and Transmission Customers.  Specifically, LARS allows arrangements involving \nInterconnection Customers that are separate entities from the Transmission Customer and provides \nthat the Interconnection Customer—and not the LARS Transmission Customer—will receive the \nLLGIA awarding Interconnection Service to LARS Associated Generating Facility and make \ndecisions regarding the generator interconnection portion of the LARS Study.  In other words, \nLARS simply recognizes the entities currently allowed to seek transmission service from MISO, \nand then adds a participation framework to ensure that any Interconnection Customers that pair \nwith the Transmission Customer can participate in LARS and receive an LLGIA. \nSeveral commenters also pointed to SPP’s HILLGA process as a model that MISO should \nemulate with LARS.43  HILLGA is a generator-driven process, while LARS is emphasizing the \npaired generation and load.  The LARS Application requires both sides of the pair to participate \nand provide information for the application.  LARS also has stricter site control requirements such \nthat the Transmission Owner must agree on the POI at the time of application submission.  MISO \nstructured LARS so that it would only encourage truly shovel-ready, commercial projects where \nthe relevant parties had already reached agreement before applying.  MISO does not believe the \nLARS process will work for all projects – it was not designed to – but it will work for generation \n \n43  See Advanced Energy United and SEIA LARS Comments at 9; Clean Energy Trades LARS Comments at 17; \nand Geronimo Power LARS Comments at 10."},{"page":22,"startToken":6514,"endToken":6819,"text":"22 \nand load pairs that have reached an agreement before applying to participate in LARS.  This kind \nof certainty and information will enable MISO to complete these parallel studies on an expedited \nbasis and will assist MISO with identifying any optimized transmission solutions.  \nThe LARS proposal in no way limits who can bring a proposed generation project to a \nTransmission Customer seeking Transmission Service on behalf of a Large Load that.  All of this \noccurs prior to LARS.  If an IPP has a generation project that is better, more cost effective, or \notherwise preferable to alternatives, nothing in the LARS process stops the IPP from bringing this \nproject forward for consideration and entering into a pairing arrangement with a LARS \nTransmission Customer.  To the extent an IPP believes it is disadvantaged in such competition, \nthat is not a result of any feature of the LARS proposal.   \nWhile several commenters also urged the Commission to sunset the LARS process after a \ncertain period of time, MISO does not support an arbitrary end date for LARS and believes that \nallowing more time will help IPPs participate in the process.44  MISO’s internal forecast indicates \nthat large loads will continue to grow in coming years.  MISO’s own recent experience with its \nEPR process demonstrates the dramatic increase in large load development.  MISO does not want \nto propose an arbitrary end date on a beneficial study process that will help MISO identify \noptimized transmission solutions.  Moreover, IPPs and other market participants will have more \ntime to collaborate with Transmission Customers and LSEs when proposing potential \ngeneration/load pairs.  MISO is not opposed to regularly reviewing LARS usage patterns to \nconsider whether changes are needed but does not believe that a specific sunset date is appropriate.  \n \n44  Clean Energy Trades LARS Comments at 17; and OMS LARS Comments at 10."},{"page":23,"startToken":6819,"endToken":7195,"text":"23 \nFinally, the structural design of LARS will systematically limit the number of projects that can be \nstudied in it given the size and certainty requirements.  \nTo facilitate this transparency, MISO commits to publicly post, at the beginning of each \nLARS cycle, information on each LARS generation/load pair’s POI and POW, the MW values for \nlarge load and the generator, the project’s LRZ location, and the number of LARS Applications \nreceived.  This is an importance piece of MISO’s commitment to transparency as part of the \nintegration of large loads onto the Transmission System.  Since LARS is proposed for such a \nunique and small group of projects, there is no need to place an arbitrary sunset on the study \nprocess.45  \nii. The 200 MW Large Load Size Threshold is Necessary for Optimization \nOver the past several years, MISO has gained experience with large loads through its EPR \nprocess.  Through this experience, MISO has seen loads that are greater than 200 MW having a \nmore significant impact on the Transmission System than smaller projects.  MISO developed \nLARS for a select group of large loads that will have a sizeable impact on the system and that have \nformally paired with generation.  MISO’s design of LARS utilizes a more holistic study process \nfor only the largest loads to try to optimize the best solution for the system.  MISO plans to keep \nthe current EPR process available for smaller load sizes of less than 50 MW or existing loads that \nare adding less than 25 MW and that still require faster processing than the traditional MTEP \nprocess.  Moreover, in its November 16 filing, MISO will be proposing its LLPR process to study \nLarge Loads greater than 50 MW that are not paired with a generator.  LARS is a study process \nfor large loads that are at least 200 MW and that have formally paired with a generator.  MISO has \n \n45  MISO has always intended to provide this information as part of its broader commitment to transparency and \nexpressly commits to making such public posting.  While MISO does not believe that a compliance directive \nrequiring MISO to reflect this commitment in the Tariff is needed, MISO would not object to such a directive if \nthe Commission believes it is necessary."},{"page":24,"startToken":7195,"endToken":7528,"text":"24 \ndeveloped these different study processes for diverse load sizes to increase the efficiency of the \nstudies and identify the best mitigation solutions.  \nThe parallel study process supplied by LARS is especially important for these very large \nload sizes.  Optimized transmission solutions are the most impactful with very large loads.  For \nexample, if there is an extremely large data center being served by multiple generating facilities \nthen it is likely that the associated Network Upgrades will be much larger, and the best opportunity \nfor minimizing the cost of these Network Upgrades is studying the load and generation together.  \nLARS is not aiming to replace other study processes at MISO but rather to ensure that the best \nstudy process for realizing cost efficiencies is utilized for the largest of loads.  This is another \nreason why it is key that the Commission approve the LARS process expeditiously.  In the context \nof the forecasted large load growth that MISO is facing in the near-term, it is critical that LARS is \napproved as soon as possible.  \niii. \nThe 15-Year Pairing Commitment is Necessary for Certainty \nThe 15-year minimum pairing of the generation and load pairs in LARS is a necessary \naspect of ensuring certainty for MISO and ensuring that LARS is not used as a queue-jumping \nprocess by Interconnection Customers.  MISO seeks to prevent either the generator or the load \nfrom using LARS to connect quickly and then operate without their partner.  Requiring a 15-year \nminimum commitment is a key part of ensuring that pairing is a formal, long-term commitment.  \nMISO envisions that LARS pairs will perform concurrently even though MISO is not requiring a \ngenerating facility’s output to be matched to the demand of the electrically proximate large load.  \nThis is another requirement that will reduce speculative generation or load proposals that are not \nready to connect to MISO’s transmission system.  Requiring this commitment to remain in place \nfor a 15-year period is a balanced approach that ensures the pairings remain in place for a long"},{"page":25,"startToken":7528,"endToken":7819,"text":"25 \nenough period of time and that discourages overuse of the process without foreclosing changes in \nthe remote future that would create challenges to attracting project investment/financing.  \nThus, arguments that LARS is flawed because it requires more commitment and \ncommercial certainty than most projects entering the queue can provide entirely miss the point of \nwhat LARS is—and is not—intended to do.  The agreement requirement is flexible enough for \nprojects with commercial certainty to participate in LARS, regardless of the type of entity that is \ndeveloping them.  And the agreement requirement should not be made more flexible to allow in \nprojects that do not meet the high hurdle that LARS is designed to maintain.  LARS is not a broad \nqueue replacement proposal and does not detract from the ability of ordinary generation or load \nprojects to enter the DPP queue or EPR process (or to be submitted in the LLPR process) on the \nsame basis as they have before LARS was proposed.  MISO is simply requiring that the LARS \ngenerator and the LARS Associated Load remain committed for a significant amount of time to \nensure certainty and as a way to avoid the circumvention of the DPP process.  \n \nE. MISO Has Met the Standard for an Independent Entity Variation  \ni. LARS accomplishes the purposes of Order Nos. 2003 and 2023 \nMISO is requesting an independent entity variation for LARS, which is a unique process \nthat will involve a much smaller number of proposed projects that will be studied each year when \ncompared to the traditional DPP queue.  Consistent with Order Nos. 2003 and 2023, MISO may \nseek variations from the pro forma Large Generator Interconnection Procedures (“LGIP”) and \nLarge Generator Interconnection Agreement (“LGIA”) if those variations “are just, reasonable,"},{"page":26,"startToken":7819,"endToken":8171,"text":"26 \nnot unduly discriminatory or preferential, and accomplish the purpose of” the terms proposed in \nOrder Nos. 2003 and Order 2023.46   \nBecause LARS is a standalone process, it should be viewed as one large independent entity \nvariation with a defined rule set rather than individual independent entity variations for the \nnumerous differences between the cluster-based process outlined in Order 2023-2023-A and \nLARS serial-based study approach for the generation side of the pair.47  LARS will not be plagued \nwith the same type of restudies that justified the Commission’s adoption of the cluster study \napproach for the DPP process because a much smaller number of eligible projects will be studied \nannually.  Since the number of projects that qualify for LARS will be significantly smaller than \nthose that can participate in the DPP queue study, MISO can effectively study the proposed LARS \nprojects on a serial basis and, as explained earlier, does not result in priority access for scarce \navailable transmission capacity.  MISO agrees that in most instances cluster studies are the most \nefficient route for an interconnection queue, but due to the unique characteristics of the LARS \nprocess, a serial-based study approach is more appropriate and will facilitate addressing more \noptimized transmission solutions in the MISO footprint.  \nThus, the Commission should find that MISO’s LARS process accomplishes the purposes \nof Order Nos. 2003 and 2023 despite not implementing a cluster process for the study of the \ngenerators.48 A serial study process for the generating facilities participating in LARS is justified \nbecause it will be completed on an extremely small number of projects per year and cluster studies \nexist to manage interdependence among large numbers of unrelated requests, and that problem \ndoes not arise in LARS with such a small number being studied in a geographically dispersed \n \n46  Order No. 2003, 104 FERC ¶ 61,103 at PP 825-826; Order No. 2023, 184 FERC ¶ 61,054 at P 1764. \n47  See Order No. 2023, 184 FERC ¶ 61,054 at P 1764. \n48  See Order No. 2003, 104 FERC ¶ 61,103 at PP 825-826; Order No. 2023, 184 FERC ¶ 61,054 at P 1764."},{"page":27,"startToken":8171,"endToken":8494,"text":"27 \nmanner across different LRZs.  LARS advances Order No. 2003’s goal of expediting new \ngeneration while protecting reliability.49  \nLARS also meets Order No. 2023’s goal of insulating the DPP queue and ensuring that \nonly truly commercially ready projects apply.50  Notably, the LARS process requires an increased \nnon-refundable payment (“D1”) of $250,000 that will be applied toward the costs related to \nprocessing the LARS request.  The D1 payment and study deposits are used for study costs and \nother costs associated with processing the LARS request, which includes MISO internal staffing \nhours and contractor staffing hours.  The strict eligibility requirements, including agreeing to \nformally pair for a minimum of fifteen years, also serves as a deterrent to speculative projects and \nenables the expedited study of unique generation/load pairs. Ultimately, LARS will help ensure \ninterconnection to the transmission system in a reliable, efficient, transparent, and timely manner.   \nF.  Miscellaneous Clarifications and Requests.  \n \nMISO first seeks to clarify the allowable Interconnection Service amount requested under \nthe LARS Interconnection Request and whether the LARS Associated Load’s expected peak \ndemand means the load’s demand at the time it first takes service or the expected demand once \nany planned phase build outs are completed.51  MISO wants to clarify that it means that the \nidentified peak demand amount identified in the LARS Application (i.e., amount of Transmission \nService requested), regardless of whether the load comes into service in phases.  The applicants \nsubmitting a LARS Application must identify the LARS Associated Load’s expected peak \n \n49  See Order No. 2003, FERC Stats. & Regs. ¶ 31,146 at PP 822-827; Order No. 2003-A, FERC Stats. & Regs. ¶ \n31,160 at P 759.  \n50  See Improvements to Generator Interconnection Procs. & Agreements, Order No. 2023, 184 FERC ¶ 61,054, \norder on reh’g, 185 FERC ¶ 61,063 (2023), order on reh’g, Order No. 2023-A, 186 FERC ¶ 61,199, errata notice, \n188 FERC ¶ 61,134 (2024).  \n51  Base Electron Power LARS Comments at 3."},{"page":28,"startToken":8494,"endToken":8799,"text":"28 \nDemand once it is fully in service, even if it is developed and built in phases.  But this does not \nmean generation can be sized to account for potential future load size increases not reflected in a \nTransmission Service/LARS application.  \nSecond, MISO recognizes that Invenergy requested that “[t]he Commission should direct \nMISO to revise its proposed Tariff to clarify that MHVDC transmission lines and associated \ninterconnected generation should be eligible to participate in LARS.”52  Invenergy argues that both \nMHVDC transmission lines and the generating facilities connected to those lines are equally \ncapable of serving large load customers.53  MISO appreciates this unique and creative proposal but \ndoes not believe that LARS is the appropriate construct for MHVDC transmission line \nparticipation.  \nFirst, the interconnection of MHVDC facilities is governed by its own process in Attachment \nGGG, which is separate from the GIP process and is much more study intensive.54  Second, \nMHVDC Injection Rights may only be granted through the same study process as Interconnection \nRequests via Attachment X.   If Invenergy is looking to have Injection Rights approved through \nthe LARS process instead of the DPP process, that idea should be proposed in a new proceeding \nas it would require significant changes to Attachment GGG and Attachment X.  As it currently \nstands, MHVDC projects can obtain firm Injection Rights (External NRIS) via the DPP process \nand pursue an off-taker for the generation facilitated by the MHVDC project outside of existing \nMISO processes.  Third, MISO notes that the MHVDC interconnection process and the LARS \nprocess have nearly incompatible timelines as the connection procedures for MHVDC lines can \n \n52  Invenergy LARS Comments at 4.  \n53  Id.   \n54  See MISO, Attachment GGG, Merchant HVDC Transmission Connection Procedures (MHCP), available at: \nhttps://docs.misoenergy.org/miso12-legalcontent/Attachment_GGG_-\n_Merchant_HVDC_Transmission_Connection_Procedures_%28MHCP%29.pdf."},{"page":29,"startToken":8799,"endToken":8928,"text":"29 \ntake considerably longer than 120 days.  LARS is a process for the parallel study of generation \nand load pairs. That said, MISO does not, in concept, oppose considering the addition of MHVDC \nparticipation within the LARS construct through a future filing. However, this is outside the scope \nof the current LARS proposal and would need to be proposed as an issue and then considered \nthrough MISO’s stakeholder process. \nIV. \nCONCLUSION \nWHEREFORE, MISO respectfully requests that the Commission: (1) accept this Answer; \nand (2) accept the LARS Filing as discussed herein. \n \nRespectfully submitted, \n/s/ Christopher Supino  \nChristopher D. Supino \nManaging Senior Corporate Counsel \n720 City Center Dr \nCarmel, IN 46032 \nTelephone: (317) 249-5400 \nEmail: csupino@misoenergy.org \n \n \nAttorneys for the Midcontinent Independent System \nOperator, Inc. \n \n \nDated:  \nNovember 9, 2026"},{"page":30,"startToken":8928,"endToken":8990,"text":"30 \nCERTIFICATE OF SERVICE \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \n \nDated at Carmel, Indiana this 9th day of November, 2026. \n/s/ Dawn Kaminski \nDawn Kaminski \nMidcontinent Independent \nSystem Operator, Inc.  \n720 City Center Drive \nCarmel, Indiana 46032 \nTelephone:  (317) 249-5400"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":308,"startToken":0,"endToken":285},{"p":2,"at":308,"title":"I. MOTION FOR LEAVE TO FILE ANSWER","method":"printed heading","endPage":3,"endAt":3,"startToken":285,"endToken":580},{"p":3,"at":3,"title":"II. EXECUTIVE SUMMARY","method":"printed heading","endPage":3,"endAt":8,"startToken":580,"endToken":581},{"p":3,"at":8,"title":"EXECUTIVE SUMMARY","method":"printed heading","endPage":7,"endAt":1508,"startToken":581,"endToken":2106},{"p":7,"at":1508,"title":"III. ANSWER","method":"printed heading","endPage":9,"endAt":148,"startToken":2106,"endToken":2480},{"p":9,"at":148,"title":"A. LARS is Responsive to the Commission’s Show Cause Order","method":"printed heading","endPage":14,"endAt":274,"startToken":2480,"endToken":4153},{"p":14,"at":274,"title":"B. Large Load Cost Allocation Framework","method":"printed heading","endPage":18,"endAt":639,"startToken":4153,"endToken":5349},{"p":18,"at":639,"title":"C. LARS Will Not Harm the Existing Queue","method":"printed heading","endPage":20,"endAt":162,"startToken":5349,"endToken":5931},{"p":20,"at":162,"title":"D. LARS Application and Eligibility Requirements","method":"printed heading","endPage":25,"endAt":1214,"startToken":5931,"endToken":7728},{"p":25,"at":1214,"title":"E. MISO Has Met the Standard for an Independent Entity Variation","method":"printed heading","endPage":27,"endAt":1000,"startToken":7728,"endToken":8319},{"p":27,"at":1000,"title":"F. Miscellaneous Clarifications and Requests.","method":"printed heading","endPage":29,"endAt":427,"startToken":8319,"endToken":8868},{"p":29,"at":427,"title":"IV. CONCLUSION","method":"printed heading","endPage":29,"endAt":432,"startToken":8868,"endToken":8869},{"p":29,"at":432,"title":"CONCLUSION","method":"printed heading","endPage":30,"endAt":4,"startToken":8869,"endToken":8929},{"p":30,"at":4,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":30,"endAt":419,"startToken":8929,"endToken":8990}]}