ER27-25-000 · 2026-10-23 · Alliant and Consumers Energy

Comments of Alliant Energy Corporate Services, Inc. and Consumers Energy Company in Support of MISO's Proposed Tariff Revisions

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
Midcontinent Independent System Operator, Inc.                )                      Docket No. ER27-25
COMMENTS OF ALLIANT ENERGY CORPORATE SERVICES, INC. AND 
CONSUMERS ENERGY COMPANY IN SUPPORT OF MISO’S PROPOSED TARIFF 
REVISIONS 
Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“FERC” or 
“Commission”) Rules of Practice and Procedure,1 18 C.F.R. § 385.212, Alliant Energy Corporate 
Services, Inc (“AECS”) and Consumers Energy Company (“Consumers Energy”)2 respectfully 
submit these comments in support of the Midcontinent Independent System Operator, Inc.’s 
(“MISO”) Large Load Addition Resource Study (LARS) Proposal (“Proposal”) in the above-
captioned docket. AECS and its affiliates, 3 and Consumers Energy, as load-serving entities 
(“LSEs”) support the need for an interconnection process that facilitates the timely study of 
generation paired with an associated large load(s) to arrive at optimized transmission solutions. 
Large loads increasingly seek service on accelerated timelines, creating a need for study processes 
capable of evaluating load, generation, and associated transmission requirements on a more 
coordinated basis. The LARS Proposal offers a practical approach to meeting load growth while 
helping to maintain resource adequacy and supporting a cost-effective mix of generating resources. 
 
1 18 C.F.R. § 385.212 (2025).   
2 Consumers Energy is a Load Serving Entity (LSE) and active participant in the MISO generation interconnection 
queue process. Consumers Energy is a public utility serving over 1.9 million residential, commercial, and industrial 
electric customers in the Michigan Joint Zone of the MISO footprint.  
3 AECS affiliates include Wisconsin Power & Light Company and Interstate Power & Light Company (collectively, 
the “Alliant Energy Operating Companies”). The Alliant Energy Operating Companies are LSEs and active 
participants in the MISO generation interconnection queue process. The companies have and continue to support 
MISO improvements to interconnection processes and believe that while queue process enhancements are needed 
and helpful, the benefits will take years to realize given the current status of queue cycles.

2 
AECS and Consumers Energy respectfully request that the Commission accept the LARS 
Proposal.  
Support for LARS as a Just and Reasonable Study Pathway 
LARS offers an opportunity to plan transmission around the combined needs of new large 
loads and paired generation, rather than evaluating each through separate processes. This 
integrated approach will enable MISO to identify optimized transmission solutions, eliminate 
duplicative or unnecessarily expensive upgrades, and help deliver lower-cost outcomes for 
customers. The LARS Proposal provides a path to avoid studying qualifying large loads and 
associated generation through separate processes using different assumptions and on different 
schedules that may produce different transmission solutions. MISO has proposed using consistent 
assumptions and rigorous methodologies to study the load and generation in parallel, with the 
objective of completing the process within approximately 120 days. 4 This approach has the 
potential to provide greater certainty regarding generation interconnection requirements, 
transmission service, and the network upgrades necessary to support reliable service.  MISO’s 
filing further explains that LARS responds directly to the Commission’s Show Cause Order by 
allowing MISO to account for the operational dynamics of serving electrically proximate large 
loads.5 These benefits support acceptance of LARS as just and reasonable. 
The Commission should support reforms that allow credible, commercially mature large 
load projects to move forward efficiently while maintaining appropriate reliability protections. 
MISO’s broader framework for integrating large loads onto its system appropriately recognizes 
that acceleration must be coupled with operational capabilities such as telemetry, coordination, 
curtailment capability, ride-through, stability controls, resilience, and security. 
 
4 LARS Proposal at 11-12, 18. 
5 Id. at 3.

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An expedited process should be available to projects demonstrating a high degree of 
commercial and development certainty. MISO has emphasized that LARS is intended for specific 
load-generation pairings with contractual arrangements and shovel-ready conditions, rather than 
as an alternative fast-track interconnection queue for generators serving general system load.6 
Strong readiness requirements are therefore an appropriate safeguard against speculative projects 
consuming scarce study resources or affecting transmission solutions for projects that are prepared 
to proceed. 
AECS and Consumers Energy therefore support LARS as a practical response to the 
planning challenges presented by new large-load development. Its value extends beyond a shorter 
study schedule: evaluating load and generation together creates an opportunity to optimize 
transmission investments and achieve lower-cost solutions for customers. By combining that 
opportunity with reliable study practices and clear participation safeguards, LARS provides a 
disciplined framework suited to the needs of the MISO footprint. 
Continued Stakeholder Collaboration on Implementation 
AECS and Consumers Energy expect MISO will continue working with stakeholders to 
refine LARS implementation details, including providing greater certainty regarding the 
conditions under which projects may retain interconnection rights over time. Large load 
development is evolving rapidly, and the industry is still gaining experience with the operating 
characteristics, development timelines, and transmission implications of these facilities. 
Accordingly, AECS and Consumers Energy support implementation of LARS with sufficient 
transparency and stakeholder engagement to allow MISO to refine the framework as practical 
experience identifies opportunities for improvement.  Continued stakeholder engagement will be 
 
6 Id. at 11, 25, and 28.

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important to realizing the benefits of LARS while maintaining reliable service and the integrity of 
the interconnection process. 
For these reasons, AECS and Consumers Energy respectfully request that the Commission 
find MISO’s LARS Proposal is a just and reasonable approach to coordinating the study of large 
loads and paired generation, optimizing transmission solutions, and facilitating timely, reliable 
service at lower costs for customers, and accept the LARS Proposal. 
 
 
 
        Respectfully submitted, 
 
        /s/ Mitchel Myhre 
   Mitchel Myhre 
    Director of Grid Planning and RTO Relations 
       Alliant Energy Corporate Services, Inc. 
       4902 N. Biltmore Lane 
       Madison, WI 54718 
                               Tel.: (608) 458-6273 
          Email: MitchellMyhre@alliantenergy.com 
 
       /s/ Rachael Moore 
       Rachael H. Moore  
       Principal Attorney  
       Consumers Energy Company  
       One Energy Plaza  
       Jackson, MI 49201  
       Phone: (517) 788-1147  
       Email: rachael.moore@cmsenergy.com

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CERTIFICATE OF SERVICE 
 
I hereby certify I have this day served the foregoing document upon each person designated 
on the official service list compiled by the Secretary in these proceedings. 
Dated at Cedar Rapids, Iowa, this 23 day of October 2026. 
 
/s/ Dezirae Fisher 
Dezirae Fisher 
Senior Paralegal  
Alliant Energy Corporate Services, Inc. 
200 1st St SE 
Cedar Rapids, IA 52401 
Tel: (319) 786-4113 
Email: deziraefisher@alliantenergy.com