{"document":{"slug":"comments-er27-25-southern-regulators","title":"Comments on Behalf of the Southern Regulators (Mississippi and Louisiana PSCs) in Support of MISO Application","issued":"2026-10-23","accession":"20261023-5073","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"Mississippi and Louisiana PSCs","kind":"comments in support","file":"sources/originals/20261023-5073_ER27-25 southern regulator comments.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261023-5073","sha256":"14ad7911b2bb9743f6ecebfbe8e058f2eedc308d994d7b9845f352b9b0114330","pages":5,"tokens":797,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":236,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nMidcontinent Independent System \nOperator, Inc \n) \n) \nDocket No. ER27-25-000 \n \n \nCOMMENTS ON BEHALF OF THE SOUTHERN REGULATORS IN SUPPORT OF \nMISO APPLICATION \n \nPursuant to Rule 212 of the Commission’s Rules of Practice and Procedure1, and the \nCommission’s October 2, 2026, notice in the above-captioned docket, the Mississippi Public \nService Commission and the Louisiana Public Service Commission  (together, the Southern \nRegulators) hereby submit comments in support of the Midcontinent Independent System \nOperator, Inc.’s (“MISO’s”) filing to establish the Large Load Addition Resource Study \n(“LARS”).  The LARS proposal seeks to revise MISO’s Open Access Transmission, Energy, and \nOperating Reserves Markets Tariff to establish a process to enable load and generation to be \nstudied together. The LARS proposal also is intended to address the Commission’s June 18, 2026 \nShow Cause Order finding that MISO’s Tariff may be unjust and unreasonable because it does \nnot provide generator interconnection study procedures and services that account for serving \nelectrically proximate Large Loads. \nThe Southern Regulators support MISO’s filing to establish the LARS process and \nrespectfully request that the Commission accept it.  It is designed to coordinate and expedite the \nanalyses needed to interconnect large loads above 200 MW and the new generation resources \nidentified to support that new load.  The LARS process may also reduce overall interconnection \ncosts and provide more certainty for interconnection customers.   \n \n1 18 C.F.R. § 385.212."},{"page":2,"startToken":236,"endToken":517,"text":"2 \nLarge Loads are seeking interconnection with the MISO system in ever increasing \nnumbers.  Studying these loads along with the generation that is planned to serve those loads \nmay reduce the need for and the costs of transmission upgrades that might otherwise needed if \nonly the generation or only the load were interconnecting.  LARS provides for a 120-day parallel \nstudy of eligible large loads and their paired generation resources.   \nLARS should be accepted by the Commission because it is just and reasonable.  By \nstudying load and its paired generation together, MISO can identify combined transmission \nsolutions, avoid duplicative and costly upgrades, and produce an outcome in approximately 120 \ndays.  This is not currently possible across the separate MISO transmission interconnection \ntransmission study processes. Making LARS a permanent process is reasonable because it \nprovides certainty needed to site and finance large load-and-generation pairings.  LARS is a \nreasonable response to and aligns with the requirements of the Commission’s Show Cause \nOrder.2   \nLARS limits the total number of projects studied in a year to ensure that MISO can \nadministratively support the new process; it allows no more than ten generation/load pairs per \nstudy period to be evaluated, and allows for only three study periods per year.3   MISO’s tariff \nrevisions propose eligibility requirements that deter speculative interconnection requests and not \ninterfere with the normal  DPP process, including a 150% generation to load ceiling, a $250,000 \ndeposit, a three-year commercial operation date, and a same-Local-Resource-Zone requirement.4  \n \n2  Show Cause Midcontinent Independent System Operator, Inc., 195 FERC ¶ 61,212, (issued June 18, 2026) \n(Docket No. EL26-70-000) (“Show Cause Order”) at P 113. \n3 MISO Transmittal at 9. \n4 Id. at 10, 28."},{"page":3,"startToken":517,"endToken":658,"text":"3 \nMISO’s proposal is transparent, competitive, fuel agnostic, and it does not adversely affect DPP \nparticipants.5  It is non-discriminatory and serves a legitimate public purpose.  \nTherefore, the Southern Regulators respectfully request that the Commission accept \nMISO’s LARS filing.  \n \n \n \n \n \nBarton Norfleet \nSpecial Counsel; Federal Energy Affairs  \nMississippi Public Service Commission  \n501 N. West Street, Suite 201-A  \nP.O. Box 1174  \nJackson, MS 39215-1174  \nPhone: (601) 961-5821  \nbarton.norfleet@psc.ms.gov  \n \n \n \n \n \n \n \nRespectfully submitted, \n \n/s/ William D. Booth  \n \nWilliam D. Booth \nOrrie A. Walsvik \nMichael Best & Friedrich LLP \n1000 Maine Avenue, S.W. \nSuite 400  \nWashington, D.C. 20024 \nPhone: (202) 747-9560 \nwdbooth@michaelbest.com \norrie.walsvik@michaelbest.com \n \nAttorneys for the Mississippi Public Service \nCommission \n \n \n5 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 at Para. 2 (July 21, 2025) (Docket No. ER \n25-2454-000); see also MISO Transmittal at 10."},{"page":4,"startToken":658,"endToken":736,"text":"4 \n \nKathryn Bowman \nExecutive Counsel \nLauren Evans \nDeputy General Counsel  \nLouisiana Public Service Commission  \n602 North Fifth Street, Baton Rouge, \nLouisiana 70802 \nPhone: (225) 342-9888  \nKathryn.bowman@la.gov \nLauren.evans@la.gov \n/s/ Noel J. Darce \nNoel J. Darce \nDana M. Shelton \nJustin A. Swaim \nFishman Haygood LLP \n601 St. Charles Ave. Suite 4600 \nNew Orleans LA 70170 \nPhone: (504) 586-5252 \nndarce@fishmanhaygood.com \ndshelton@fishmanhaygood.com \njswaim@fishmanhaygood.com \n \nAttorneys for the Louisiana Public Service \nCommission"},{"page":5,"startToken":736,"endToken":797,"text":"5 \nCERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon the parties designated \non the official service list for the above-captioned docket in accordance with the requirements of \nRule 2010 of the Commission’s Rules of Practice and Procedure. \nDated at New Orleans, Louisiana on this 23rd day of October, 2026. \n \n \n \n \n \n \n/s/ Noel J. Darce"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":5,"endAt":3,"startToken":0,"endToken":737},{"p":5,"at":3,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":5,"endAt":385,"startToken":737,"endToken":797}]}