ER27-25-000 · 2026-10-23 · Mississippi and Louisiana PSCs

Comments on Behalf of the Southern Regulators (Mississippi and Louisiana PSCs) in Support of MISO Application

1 
UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
Midcontinent Independent System 
Operator, Inc 
) 
) 
Docket No. ER27-25-000 
 
 
COMMENTS ON BEHALF OF THE SOUTHERN REGULATORS IN SUPPORT OF 
MISO APPLICATION 
 
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, the Mississippi Public 
Service Commission and the Louisiana Public Service Commission  (together, the Southern 
Regulators) 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”).  The LARS proposal seeks to revise MISO’s Open Access Transmission, Energy, and 
Operating Reserves Markets Tariff to establish a process to enable load and generation to be 
studied together. The LARS proposal also is intended to address the Commission’s June 18, 2026 
Show Cause Order finding that MISO’s Tariff may be unjust and unreasonable because it does 
not provide generator interconnection study procedures and services that account for serving 
electrically proximate Large Loads. 
The Southern Regulators support MISO’s filing to establish the LARS process and 
respectfully request that the Commission accept it.  It is designed to coordinate and expedite the 
analyses needed to interconnect large loads above 200 MW and the new generation resources 
identified to support that new load.  The LARS process may also reduce overall interconnection 
costs and provide more certainty for interconnection customers.   
 
1 18 C.F.R. § 385.212.

2 
Large Loads are seeking interconnection with the MISO system in ever increasing 
numbers.  Studying these loads along with the generation that is planned to serve those loads 
may reduce the need for and the costs of transmission upgrades that might otherwise needed if 
only the generation or only the load were interconnecting.  LARS provides for a 120-day parallel 
study of eligible large loads and their paired generation resources.   
LARS should be accepted by the Commission because it is just and reasonable.  By 
studying load and its paired generation together, MISO can identify combined transmission 
solutions, avoid duplicative and costly upgrades, and produce an outcome in approximately 120 
days.  This is not currently possible across the separate MISO transmission interconnection 
transmission study processes. Making LARS a permanent process is reasonable because it 
provides certainty needed to site and finance large load-and-generation pairings.  LARS is a 
reasonable response to and aligns with the requirements of the Commission’s Show Cause 
Order.2   
LARS limits the total number of projects studied in a year to ensure that MISO can 
administratively support the new process; it allows no more than ten generation/load pairs per 
study period to be evaluated, and allows for only three study periods per year.3   MISO’s tariff 
revisions propose eligibility requirements that deter speculative interconnection requests and not 
interfere with the normal  DPP process, including a 150% generation to load ceiling, a $250,000 
deposit, a three-year commercial operation date, and a same-Local-Resource-Zone requirement.4  
 
2  Show Cause Midcontinent Independent System Operator, Inc., 195 FERC ¶ 61,212, (issued June 18, 2026) 
(Docket No. EL26-70-000) (“Show Cause Order”) at P 113. 
3 MISO Transmittal at 9. 
4 Id. at 10, 28.

3 
MISO’s proposal is transparent, competitive, fuel agnostic, and it does not adversely affect DPP 
participants.5  It is non-discriminatory and serves a legitimate public purpose.  
Therefore, the Southern Regulators respectfully request that the Commission accept 
MISO’s LARS filing.  
 
 
 
 
 
Barton Norfleet 
Special Counsel; Federal Energy Affairs  
Mississippi Public Service Commission  
501 N. West Street, Suite 201-A  
P.O. Box 1174  
Jackson, MS 39215-1174  
Phone: (601) 961-5821  
barton.norfleet@psc.ms.gov  
 
 
 
 
 
 
 
Respectfully submitted, 
 
/s/ William D. Booth  
 
William D. Booth 
Orrie A. Walsvik 
Michael Best & Friedrich LLP 
1000 Maine Avenue, S.W. 
Suite 400  
Washington, D.C. 20024 
Phone: (202) 747-9560 
wdbooth@michaelbest.com 
orrie.walsvik@michaelbest.com 
 
Attorneys for the Mississippi Public Service 
Commission 
 
 
5 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.

4 
 
Kathryn Bowman 
Executive Counsel 
Lauren Evans 
Deputy General Counsel  
Louisiana Public Service Commission  
602 North Fifth Street, Baton Rouge, 
Louisiana 70802 
Phone: (225) 342-9888  
Kathryn.bowman@la.gov 
Lauren.evans@la.gov 
/s/ Noel J. Darce 
Noel J. Darce 
Dana M. Shelton 
Justin A. Swaim 
Fishman Haygood LLP 
601 St. Charles Ave. Suite 4600 
New Orleans LA 70170 
Phone: (504) 586-5252 
ndarce@fishmanhaygood.com 
dshelton@fishmanhaygood.com 
jswaim@fishmanhaygood.com 
 
Attorneys for the Louisiana Public Service 
Commission

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CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon the parties designated 
on the official service list for the above-captioned docket in accordance with the requirements of 
Rule 2010 of the Commission’s Rules of Practice and Procedure. 
Dated at New Orleans, Louisiana on this 23rd day of October, 2026. 
 
 
 
 
 
 
/s/ Noel J. Darce