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4 Also, because a number of commenters misstate the intent and background of LARS, raise extraneous issues, seek clarifications, and/or propose changes, MISO requests permission to respond to the intervenors’ arguments to clarify the record and assist the Commission with its decision-making. PDF p. 2
2 AECS and Consumers Energy respectfully request that the Commission accept the LARS Proposal. PDF p. 2
The APSC supports MISO’s filing to establish the LARS process, and agrees with the comments made by the Mississippi Public Service Commission and the Louisiana Public Service Commission. Source text
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. PDF p. 1
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. PDF p. 1
The Southern Regulators support MISO’s filing to establish the LARS process and respectfully request that the Commission accept it. PDF p. 1
2 members include independent power producers (“IPPs”) that develop generation to serve large loads and that would be directly affected by both the access rules LARS establishes and the effect of LARS on the transmission capacity and Network Upgrade costs available to projects in the DPP. PDF p. 2
Bloom supports LARS and urges the Commission to accept it by MISO's requested December 2, 2026 effective date. PDF p. 1
4 For the reasons explained below, the Commission should reject the LARS proposal. PDF p. 1
Cost-Shifting Should be Addressed Across MISO’s Section 205 Filings and in the Section 206 Filing MISO’s LARS Process does not address the Commission’s concerns regarding cost- shifting expressed in the Show Cause Order. PDF p. 4
3 The concept underlying LARS is a particularly important one that is worth prioritizing, and it is a concept that Google continues to strongly support. PDF p. 1
4 In the LARS filing, MISO proposes a process that would study load and generation on a coordinated basis. PDF p. 1
13 LARS Helps Mitigate Cost Shifting, Supports Cost Causation Principles, and Addresses Urgent Needs Now Without Prejudicing Subsequent Large Load Reforms Second, MISO recognizes the importance of developing a cost allocation framework that will prevent cost shifting and align with the Commission’s cost causation principles. PDF p. 4
2 members include independent power producers (“IPPs”) that develop generation to serve large loads and that would be directly affected by both the access rules LARS establishes and the effect of LARS on the transmission capacity and Network Upgrade costs available to projects in the DPP. PDF p. 2
Consistent with the Show Cause Order, the cost-causer, not other ratepayers, should be responsible for all network upgrades resulting from the Large Load. PDF p. 7
To be clear, Google supports both the concept underlying LARS, which will improve speed to power and transmission planning, and provisions that protect other network customers against cost shifting. PDF p. 3
4 (2026) (“ERAS Rehearing Order”) (noting rehearing request of the Clean Energy Associations, including ACP). PDF p. 2
In developing LARS, MISO concluded that defining a maximum distance based on substations would impede the flexibility of large loads and 19 Clean Energy Trades LARS Comments at 18; the Community Organizations and Clean Energy Advocates (the “Advocates”) LARS Comments at 37-38; Consumer Advocates LARS Comments at 9; OMS LARS Comments at 8; and the Southern Minnesota Municipal Power Agency and WPPI Energy (the “Midwest TDUs”) LARS Comments at 5-6. PDF p. 9
13 LARS Heeds the Call for Speed to Power and Supports Resource Adequacy The immensity and rate of large load additions across the United States is requiring unique proposals. PDF p. 13
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. PDF p. 1