ER27-25-000 · 2026-10-23 · DTE Electric

Comments of DTE Electric Company

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
Midcontinent Independent System  
 
)  
 
Docket No. ER27-25-000 
Operator, Inc  
 
 
 
 
) 
 
 
 
COMMENTS OF DTE ELECTRIC COMPANY 
 
Pursuant to Rules 212 and 214 of the Federal Energy Regulatory Commission’s 
(“Commission”) Rules of Practice and Procedure, 18 CFR §§ 385.212 and 385.214 (2013), DTE 
Electric Company (“DTE Electric”, “DTE”, or the “Company”) hereby submits its comments 
regarding the filing submitted by Midcontinent Independent System Operator, Inc. ("MISO") on 
October 2, 2026, in the above-captioned docket proposing to establish a Large Load Addition 
Resource Study ("LARS") process.1 DTE Electric supports MISO's proposal and believes the 
LARS framework represents a reasonable approach to evaluating the transmission, operational, 
and resource adequacy impacts associated with significant new load additions and associated 
generation resources within the MISO footprint. 
I. 
Background 
In this proceeding, MISO proposes revisions to its Tariff to establish the LARS framework. 
MISO states that the proposal is intended to facilitate the timely and reliable integration of 
significant new load additions and associated generation resources through a coordinated study 
process that evaluates transmission, operational, and resource adequacy impacts. Under the 
 
1 Midcontinent Independent System Operator, Inc., Large Load Addition Resource Study (“LARS”) Process, 
Docket No. ER27-25-000 (October 2, 2026). (“LARS Filing.”)

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proposal, eligible load-generation pairings may request a LARS evaluation, allowing MISO and 
stakeholders to assess the combined impacts of associated load and generation resources, improve 
planning certainty, and support more efficient use of the transmission system. MISO requests that 
the Commission accept the proposed tariff revisions and permit the LARS framework to become 
effective as proposed. 
II. 
COMMENTS  
DTE Electric supports the LARS filing and respectfully requests that the Commission 
accept the filing as proposed. As the load-serving entity responsible for serving approximately two 
million customers in Michigan, DTE Electric has a direct interest in ensuring that significant new 
load additions are integrated through processes that appropriately account for associated 
generation, transmission needs, and effects on other customers. 
A. The LARS filing is a just and reasonable solution to integrate new large loads 
while maintaining resource adequacy and reliability and supports MISO's 
compliance with the Commission's Show Cause Order. 
The LARS Filing directly responds to the Commission’s directive to create “a just and 
reasonable framework for addressing these concerns and ensuring the timely, efficient, and reliable 
integration of large and co-located loads onto the transmission system.”2 By allowing large loads 
and associated generation resources to be studied together, the proposal recognizes that jointly 
planned and electrically proximate resources may produce materially different system impacts than 
traditional stand-alone studies. This coordinated approach provides MISO with a more complete 
assessment of the net impacts of load and generation pairings and supports more informed planning 
and operational decision-making. 
 
2 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212 (2026) (“Show Cause Order”) at P 2.

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The proposal also contains meaningful safeguards designed to ensure participation is 
limited to qualifying projects and to discourage speculative requests. Participating projects must 
satisfy applicable deposit, minimum size, site control, and commercial operation requirements. In 
addition, load and generation pairings must demonstrate a qualifying contractual relationship, 
remain within the same Local Resource Zone, and maintain a long-term commitment to remain 
paired. These requirements provide reasonable assurance that participating projects represent 
durable load-generation relationships and help mitigate potential impacts to the transmission 
system and other customers. 
The LARS filing also preserves an open and non-discriminatory framework by permitting 
the interconnection customer responsible for the generation component to be any eligible entity. 
This approach maintains flexibility for loads, generators, and load-serving entities while 
preserving the technical, financial, and operational safeguards necessary to protect reliability and 
other customers. 
Taken together, these provisions establish a targeted and balanced framework that 
facilitates the efficient integration of significant new loads while preserving appropriate customer 
and reliability protections. Accordingly, DTE Electric respectfully requests that the Commission 
approve the LARS Filing as proposed. 
III. 
COMMUNICATIONS 
DTE Electric requests that all communications, correspondence, documents, and other 
materials related to this proceeding be addressed to the following persons:

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Tristin Rojeck  
Regulatory Affairs  
DTE Electric Company       
One Energy Plaza 
Detroit, Michigan 48226 
(313) 235-1041 
tristin.rojeck@dteenergy.com 
Andrea E. Hayden 
Office of the General Counsel  
DTE Electric Company       
One Energy Plaza 
Detroit, Michigan 48226 
(313) 235-6205 
andrea.hayden@dteenergy.com 
IV. 
CONCLUSION 
DTE Electric believes the LARS Filing constitutes a reasonable and targeted response to 
the concerns identified by the Commission in the Show Cause Order. The proposal establishes an 
appropriately tailored framework for the coordinated study of large loads and associated 
generation resources while maintaining important reliability safeguards. Accordingly, DTE 
Electric respectfully requests that the Commission accept the LARS Filing as proposed. 
Respectfully submitted, 
 
 
 
/s/Andrea E. Hayden  
Andrea E. Hayden 
Office of the General Counsel 
DTE Electric Company 
One Energy Plaza  
Detroit, Michigan 48226-1279 
(734)546-0179 
andrea.hayden@dteenergy.com 
Counsel for DTE Electric Company 
Filed: October 23, 2026

CERTIFICATE OF SERVICE 
 
In accordance with 18 C.F.R. § 385.2010, I hereby certify that I have, on this 23rd day of 
October 2026, caused a copy of the foregoing Comments of DTE Electric Company to be served 
on each person designated on the official service list compiled by the Secretary of the Commission 
in Docket No. ER27-25. 
 
/s/ Andrea Hayden