ER27-25-000 · 2026-10-23 · Entergy and Cleco

Supporting Comments of the Entergy Operating Companies and Cleco Power LLC

1
UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
 
 
 
 
) 
Midcontinent Independent System  
) 
Docket No. ER27-25-000 
Operator, Inc.    
 
 
) 
  
 
SUPPORTING COMMENTS OF 
THE ENTERGY OPERATING COMPANIES AND CLECO POWER LLC 
 
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure1, and 
the Commission’s October 2, 2026, notice in the above-captioned docket, Entergy 
Services, LLC, on behalf of the Entergy Operating Companies (“Entergy”)2 and Cleco 
Power, LLC hereby submit comments in support of the Midcontinent Independent 
System Operator, Inc.’s (“MISO’s”) filing to establish the Large Load Addition Resource 
Study (LARS).   
Entergy and Cleco Power LLC support MISO’s October 2, 2026, filing to 
establish the LARS process, and respectfully urges the Commission to accept it, as it will 
enable MISO to expeditiously review the interconnection needs of large loads over 200 
MW that have identified new generation resources to support their needs.  As a general 
principle, the LARS process should reduce overall interconnection-related costs to 
consumers.   
Large loads, including computational data centers, advanced manufacturing, and 
other energy-intensive industries, are arriving in MISO’s footprint at an increasing pace, 
 
1 18 C.F.R. § 385.212. 
2 The Entergy Operating Companies are Entergy Arkansas, LLC (“Entergy Arkansas”), Entergy Louisiana, 
LLC (“Entergy Louisiana”), Entergy Mississippi, LLC (“Entergy Mississippi”), Entergy New Orleans, 
LLC (“Entergy New Orleans”), and Entergy Texas, Inc. (“Entergy Texas”).

2
and their addition to the bulk electric system can create unique study needs. Pairing these 
loads with generation that is developed to support them can be one way to reduce the 
need for significant transmission upgrades that might be otherwise needed if only the 
generation or only the load were interconnecting; however, to date, MISO has not always 
studied such generation-load pairs in a manner that recognizes these synergies.  LARS 
offers a coordinated, 120-day parallel study of eligible large loads and their paired 
generation resources.  It is a measured and thoughtful response to the Commission’s call 
for tariff provisions concerning electrically proximate large loads and generation, and it 
should be accepted as just and reasonable.3 
I. 
Background 
Both Entergy and Cleco Power LLC are load-serving entities with an obligation to 
serve the electricity needs of their customers.  The Entergy Operating Companies are 
generation and transmission-owning members of MISO and serve approximately 3.1 
million retail customers, 70% of which are large industrial or commercial businesses. As 
load serving entities, the Entergy Operating Companies procure both generation and 
transmission service for their retail customers, including large loads. The Entergy 
Operating Companies own or lease over 24,000 MW of generation assets producing 
electricity that is carried across more than 16,000 miles of high voltage transmission 
lines.  
Cleco Power LLC is an electric utility engaged principally in the generation, 
transmission, distribution, and sale of electricity within Louisiana.  Cleco Power LLC is a 
 
3 Midcontinent Independent System Operator, Inc., 195 FERC ¶ 61,212, (issued June 18, 2026) (Docket 
No. EL26-70-000) (“Show Cause Order”); Prepared Direct Testimony of Christina Drake (“Drake 
Testimony”) at 7, 41.

3
Louisiana limited liability company and a wholly owned subsidiary of Cleco Corporate 
Holdings LLC, a privately held holding company.  Cleco Power currently owns eight (8) 
generating units with a capacity of over 2,600 MW and maintains approximately 1,380 
miles of transmission lines.  When the Entergy Operating Companies and Cleco Power 
identify needs for new generation resources to support load growth, the decision about 
where to construct the new generator is based in part on where new loads are likely to be 
located. This is done to try to reduce the need for additional transmission upgrades if 
possible.  
For the Entergy Operating Companies and Cleco Power, the inclusion of LARS as 
an option to plan for the future needs of its growing customer base is vital. In recent 
years, both companies have seen first-hand why a coordinated, expedited study pathway 
is needed for new large loads that are paired with generation.  MISO’s DPP cycles have 
taken four years or longer to reach completion, leaving load-serving entities without a 
timely path to interconnect associated generation that is being built to benefit customers 
that are hoping to be served within a much shorter timeframe. That timing mismatch, 
between the pace of large-load arrivals and when an associated generator can obtain a 
signed GIA, is what LARS helps to resolve by aligning the load and generation on 
parallel studies and on a single 120-day track.4  And, the ability to identify combined 
transmission solutions and avoid the introduction of duplicative and expensive upgrades 
will certainly result in far faster and clearer interconnection timelines.   
 
 
 
4 Id.; see also MISO Transmittal Letter at 19.

4
II. 
The LARS Process is Just and Reasonable 
LARS should be accepted by the Commission because it is just and reasonable 
and delivers coordinated speed to power without sacrificing study integrity.  By studying 
load and its paired generation together, MISO can identify combined transmission 
solutions, avoid duplicative and costly upgrades, and produce a reliable outcome in 
approximately 120 days.  This is not currently achievable across the separate EPR, DPP, 
and ERAS processes and timelines that are now in place.5 Making LARS a permanent 
process is appropriate because it provides needed, long-term regulatory and financial 
certainty required to site and finance large load-and-generation pairings, and it includes 
structural limits that keep the process bounded in every cycle.6  As further highlighted in 
MISO’s filing, LARS aligns with and is directly responsive to the Commission’s Show 
Cause Order, as it offers an explicit pathway for MISO to “account for the operational 
dynamics of serving electrically proximate large loads.”7   
The Commission should evaluate LARS under the “independent entity variation 
standard” to determine whether MISO’s variation here is just and reasonable, not unduly 
discriminatory or preferential and accomplishes the purposes of Order No. 2003.8  First, 
the LARS project requirements are appropriately tailored with reasonable limitations to 
prevent unintended uses.  LARS limits the total number of projects to ensure that MISO 
 
5 Drake Testimony at 6. 
6 Id. at 12. 
7 See Show Cause Order at P 113 (noting that the Commission preliminarily found that MISO’s existing 
Tariff “may be unjust and unreasonable because it does not provide generator interconnection study 
procedures and services that account for the operational dynamics of serving electrically proximate large 
loads.”).  
8 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 at 2 (July 21, 2025) (Docket No. 
ER 25-2454-000) (“Under the independent entity variation standard, an RTO/ISO must demonstrate that 
proposed deviations from the Commission’s pro forma LGIP and pro forma LGIA are just and reasonable 
and not unduly discriminatory or preferential and accomplish the purposes of Order No. 2003.”).

5
can administratively support the new process, as only ten generation/load pairs per study 
period will be evaluated, with three periods per year.9  Second, MISO’s proposed tariff 
revisions propose stringent eligibility requirements to deter speculative interconnection 
requests and minimize disruption to the DPP, including a 150% generation to Associated 
Load ceiling, a $250,000 deposit, a three-year commercial operation date, and a same-
Local-Resource-Zone requirement.10 Third, MISO’s proposal is consistent with the 
Commission’s open-access goals because it is transparent, competitive, technology and 
fuel agnostic, applies identical eligibility to all applicants, and does not restrict DPP 
access or adversely affect DPP applicants.11 These tailored limitations demonstrate that 
LARS is a reasoned approach that anticipates and resolves issues consistent with 
previously stated Commission guideposts. 
In short, the Entergy Operating Companies and Cleco Power support LARS 
because it is a tailored pathway that reasonably optimizes the nature of coordinated load 
and generation studies, which in turn facilitates more efficient and cost-effective 
transmission system planning.  It is a significant step to ensure that MISO and its 
stakeholders thoughtfully build the grid to meet its new large load demands.  It is a 
necessary new product for a new commercial reality.  
III. 
Conclusion 
LARS is a timely, well-designed, and appropriately limited tool for integrating 
large loads and the generation built to serve them, and it responds directly to the 
 
9 MISO Transmittal at 9. 
10 Id. at 10, 28. 
11 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 at Para. 2 (July 21, 2025) (Docket 
No. ER 25-2454-000); see also MISO Transmittal at 10.

6
Commission’s Show Cause Order in this regard.  Therefore, the Entergy Operating 
Companies and Cleco Power respectfully request that the Commission accept MISO’s 
LARS filing.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
/s/ Jeffrey Phillips 
Senior Counsel  
Entergy Services, LLC 
101 Constitution Ave., Ste. 200-E 
Washington, DC  20001 
202-530-7312 
Jphil36@entergy.com 
 
Andrea Weinstein 
 
 
 
 
VP& Deputy General Counsel 
 
 
Entergy Services, LLC 
 
 
 
101 Constitution Ave. Ste. 200-E 
 
 
Washington, DC  20001 
 
 
 
202-503-7342  
 
 
 
 
aweinst@entergy.com 
 
 
 
 
Karis Anne Gong Parnham 
Assistant General Counsel   
Entergy Services, LLC   
919 Congress Ave., Suite 700  
Austin, TX 78701   
512-487-3986   
kparnha@entergy.com   
 
On behalf of 
Entergy Services, LLC 
 
/s/Jill M. Kelone 
Jill M. Kelone 
Director – Compliance 
Cleco Corporate Holdings LLC 
(318) 484-7597 
Jill.Kelone@cleco.com 
 
On behalf of  
Cleco Power LLC