Read topic-matched comments in ER27-25
Topics in the text: Connecting load and generation · Reliability and curtailment · Cost allocation
PDF p. 2
LARS will provide a path for the interconnection of both large loads and supporting generation pairs in a parallel 120-day study process. PDF p. 2
Mississippi and Louisiana Public Service Commissions · Direct response
The commissions backed a 120-day joint study. They said studying the load and its generator together could avoid duplicating network upgrades; the limit of ten pairs per period made it manageable. They wanted a permanent process so projects could plan and finance construction.
PDF pp. 2–3Arkansas Public Service Commission · Direct response
Arkansas expressly agreed with the Mississippi and Louisiana commissions’ comments and asked FERC to accept MISO’s tariff changes. It did not offer its own numerical estimate of costs or queue delays.
Comments of the Arkansas PSC, concluding paragraph (unpaginated)Entergy and Cleco · Direct response
The utilities said some ordinary MISO study cycles had taken four years or more. They supported the 120-day path and argued that its cap of ten load-generator pairs per study period would keep it workable.
PDF pp. 2–3, 5PDF p. 15
The goal of LARS is not necessarily to find the lowest cost solution for either the load or generation but to identify the solution that best fits both PDF p. 15Filed comments: Connecting load and generation
PDF p. 18
LARS meets the urgent need for an accelerated evaluation process that accounts for both load and generation PDF p. 18Filed comments: Connecting load and generation
PDF p. 3
LARS provides a mechanism for MISO to study a large load and the generation that will serve it at the same time PDF p. 3Filed comments: Connecting load and generation
PDF p. 13
As a result of the way MISO's study models are structured, LARS projects will not impact existing projects in the DPP process. PDF p. 13Filed comments: Connecting load and generation
PDF p. 9
There will be three LARS study periods each year and each study period will be completed in approximately 120 days PDF p. 9Filed comments: Connecting load and generation
PDF p. 9
MISO will accept ten LARS Applications per study period and the LARS Applications will be assigned to study periods in order of submission. PDF p. 9Filed comments: Connecting load and generation
PDF p. 8
A non-refundable fee of $250,000 must accompany the LARS Application and be paid by the LARS Associated Transmission Customer. PDF p. 8
Alliant Energy and Consumers Energy · Direct response
The utilities backed the readiness requirements because a speculative project could occupy one of a limited number of study slots. They argued the joint model could identify cheaper combined upgrades.
PDF pp. 2–3DTE Electric · Direct response
DTE supported the pairing rules and minimum commitment as evidence of a lasting commercial relationship. It also said the tariff allowed the interconnection customer to participate even though the transmission customer submits the application.
PDF pp. 2–3PDF p. 9
The agreement must be legally binding and must state a minimum term of five years PDF p. 9
Alliant Energy and Consumers Energy · Direct response
The utilities backed the readiness requirements because a speculative project could occupy one of a limited number of study slots. They argued the joint model could identify cheaper combined upgrades.
PDF pp. 2–3DTE Electric · Direct response
DTE supported the pairing rules and minimum commitment as evidence of a lasting commercial relationship. It also said the tariff allowed the interconnection customer to participate even though the transmission customer submits the application.
PDF pp. 2–3PDF p. 10
limiting the amount of requested Interconnection Service to no more than 150% of the peak demand of the LARS Associated Load, and demonstration of 100% site control PDF p. 10
Alliant Energy and Consumers Energy · Direct response
The utilities backed the readiness requirements because a speculative project could occupy one of a limited number of study slots. They argued the joint model could identify cheaper combined upgrades.
PDF pp. 2–3DTE Electric · Direct response
DTE supported the pairing rules and minimum commitment as evidence of a lasting commercial relationship. It also said the tariff allowed the interconnection customer to participate even though the transmission customer submits the application.
PDF pp. 2–3PDF p. 7
must be a large load of at least 200 MW PDF p. 7
Bloom Energy · Direct response
Bloom backed the study but challenged its 200 MW entry threshold. It proposed letting transmission-connected loads of at least 50 MW participate and asked FERC not to delay the requested start date.
PDF pp. 1, 4–5PDF p. 11
While MISO is allowing aggregation for LARS Generating Facilities, MISO is not allowing aggregated load to participate in LARS. PDF p. 11
Bloom Energy · Direct response
Bloom backed the study but challenged its 200 MW entry threshold. It proposed letting transmission-connected loads of at least 50 MW participate and asked FERC not to delay the requested start date.
PDF pp. 1, 4–5PDF p. 10
Another important condition of the LARS process is the requirement that the load and generation pair be located in the same Local Resource Zone PDF p. 10Filed comments: Connecting load and generation
PDF p. 17
MISO will provide the Generating Facility up to one year after the LARS Associated Load withdraws to continue to operate under the LLGIA PDF p. 17Filed comments: Connecting load and generation
PDF p. 16
this requirement ensures that the LARS study process accurately reflects the expected impacts of the Generating Facility and LARS Associated Load on the Transmission System for a significant period of time. PDF p. 16Filed comments: Connecting load and generation
PDF p. 12
Then any common violations that show up in the generation and load studies are assigned to BRP and Other project types. Only the violations but for the generator are assigned GIP project types. PDF p. 12
PDF p. 13
In the event that overallocation does occur, any constraints that are identified as needing mitigation in the MTEP process will be formalized in a future MTEP project. PDF p. 13
American Clean Power Association and Southern Renewable Energy Association · Direct response
The trade associations said studying accelerated projects without other generators already waiting could leave later studies with fewer feasible connections and higher costs. They objected to a permanent parallel route without a cap on total capacity.
PDF pp. 2, 21, 27Solar Energy Industries Association and Advanced Energy United · Direct response
The protesters asked FERC to reject the proposal or clarify that an applicant meeting all published requirements could not lose access at the transmission customer’s discretion.
PDF pp. 1–2, 13Organization of MISO States, quoted by Utility Dive · Direct response
OMS warned that a rapid route must not turn into a general substitute for the queue. It asked for safeguards before qualifying pairs could claim transmission capacity ahead of projects already waiting.
October 26, reporting on October 23 ER27-25 commentsPDF p. 13
The cost of the MTEP project will be allocated based on existing Tariff rules, which is likely to be the load within the transmission pricing zone where the transmission upgrade is required. PDF p. 13
American Clean Power Association and Southern Renewable Energy Association · Direct response
The trade associations said studying accelerated projects without other generators already waiting could leave later studies with fewer feasible connections and higher costs. They objected to a permanent parallel route without a cap on total capacity.
PDF pp. 2, 21, 27Solar Energy Industries Association and Advanced Energy United · Direct response
The protesters asked FERC to reject the proposal or clarify that an applicant meeting all published requirements could not lose access at the transmission customer’s discretion.
PDF pp. 1–2, 13Organization of MISO States, quoted by Utility Dive · Direct response
OMS warned that a rapid route must not turn into a general substitute for the queue. It asked for safeguards before qualifying pairs could claim transmission capacity ahead of projects already waiting.
October 26, reporting on October 23 ER27-25 commentsPDF p. 14
all of which will be submitted to the Commission in a FPA section 205 filing by November 16, 2026. PDF p. 14
Iowa Office of Consumer Advocate, Illinois and Michigan attorneys general, Minnesota Department of Commerce and co-protesters · Direct response
The joint protesters asked how the study would prevent costs shifting to other customers. They warned that related MISO proposals could exempt about 30 GW of existing load from some reliability requirements; 30 GW was not the size of the proposed LARS study queue.
PDF pp. 1, 3–4, 6PDF p. 14
LARS can be implemented based on the Tariff revisions filed herein and need not await these future filings. PDF p. 14
Iowa Office of Consumer Advocate, Illinois and Michigan attorneys general, Minnesota Department of Commerce and co-protesters · Direct response
The joint protesters asked how the study would prevent costs shifting to other customers. They warned that related MISO proposals could exempt about 30 GW of existing load from some reliability requirements; 30 GW was not the size of the proposed LARS study queue.
PDF pp. 1, 3–4, 6PDF p. 6
Because only the Transmission Customer can procure Transmission Service under established Tariff processes, LARS requires the LARS Associated Transmission Customer to be the party that initiates the LARS Application PDF p. 6
Google · Direct response
Google supported studying loads and generators together but questioned the separate assumptions used in the ordinary queue. It wanted cost protections and a way for independent generators to participate without discrimination by the serving utility.
PDF pp. 2–3, 6–9PDF p. 9
This does not supersede the role of the LARS Associated Transmission Customer to determine whether to submit a LARS Application PDF p. 9
Google · Direct response
Google supported studying loads and generators together but questioned the separate assumptions used in the ordinary queue. It wanted cost protections and a way for independent generators to participate without discrimination by the serving utility.
PDF pp. 2–3, 6–9Clean Energy Advocates · Direct response
The advocates warned that two study tracks using different assumptions could count the same unused transmission capacity twice. They challenged assigning upgrade costs to existing customers based on agreements whose terms FERC had not seen.
PDF p. 18Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Connecting load and generation
This is done to avoid confusion because that definition remains pending before the Commission and because, given the 200 MW threshold for entry into LARS, not all “Large Loads” will be eligible to be a “LARS Associated Load.” The Honorable Debbie-Anne Reese October 2, 2026 Page 2 MISO requests that…Read this passage Filed comments: Connecting load and generation
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I.Read this passage
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In addition, the Commission requested a detailed informational report on any proposals under consideration to address the issue of resource adequacy to serve new large loads, strongly encouraging new proposals to the extent necessary to address these concerns.10 The LARS process responds to this…Read this passage Filed comments: Connecting load and generation
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OVERVIEW OF THE LARS PROCESSRead this passage Filed comments: Connecting load and generation
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A.Read this passage
printed heading · Topic match: Reliability and curtailment
Significant new demand must be accompanied by sufficient resources to maintain reliability and resource adequacy.Read this passage Filed comments: Reliability and curtailment
printed heading · Topic match: Connecting load and generation
The Honorable Debbie-Anne Reese October 2, 2026 Page 7 for the LARS Associated Load and has the responsibility to construct Network Upgrades (subject to applicable Tariff rules that are not changed by this filing).27 The fourth key participant is the entity that owns or controls the LARS Associated…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
A non-refundable fee of $250,000 must accompany the LARS Application and be paid by the LARS Associated Transmission Customer.32 Notably, MISO is establishing a “pre-submission coordination process” that LARS applicants must participate in prior to submitting a LARS Application.33 This coordination…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
Drake explained, “LARS studies will not include Interconnection Requests currently in the generator interconnection queue that do not have an executed GIA.”56 MISO has designed the LARS study this way to reduce the number of speculative projects in the modeling process.Read this passage Filed comments: Connecting load and generation
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Drake explains, the LARS process enables MISO to optimize solutions for the transmission grid to reduce costs overall while also maintaining reliability.69 The LARS Application must identify a Commercial Operation Date for the Generating Facility and a Load In-Service Date for the LARS Associated…Read this passage Filed comments: Connecting load and generation
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LARS provides a valuable tool to enable the study of LARS Associated Loads that are brought to MISO with a paired generation solution.Read this passage Filed comments: Connecting load and generation
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Stakeholders have raised questions regarding how LARS generation will interact with generation already progressing through the ordinary Generator Interconnection Queue and the protections necessary to avoid adversely affecting existing Interconnection Customers.85 The transmission capacity headroom…Read this passage Filed comments: Connecting load and generation
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Drake explained in her testimony, “[u]ltimately, limiting the generation and LARS Associated Load to locations within the same LRZ ensures deliverability of the generation to the LARS Associated Load because it avoids potential capacity import / capacity export limitations for the individual LRZ…Read this passage Filed comments: Connecting load and generation
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DESCRIPTION OF PROPOSED TARIFF REVISIONS To implement the LARS process proposed herein, MISO is requesting approval of new Tariff provisions, as well as revisions to several existing provisions.94Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
The proposed revisions are as follows: No changes shall be made to the LARS Application after submission and prior to the execution or the unexecuted filing of the LLGIA and MTEP approval for the LARS Associated Load except that a LARS Application that is deferred to the next available LARS Study…Read this passage Filed comments: Connecting load and generation
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B.Read this passage
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These revisions include adding new options for interconnection requests and interconnection service to accommodate LARS, confirm that the amount of Interconnection Service cannot exceed 150% of the total amount of its LARS Associated Load, to describe the requirements for LARS Associated Load and…Read this passage Filed comments: Connecting load and generation
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D.Read this passage
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The proposed revisions are as follows: This LLGIA shall be terminated by Transmission Provider after giving Interconnection Customer ninety (90) Calendar Days advance written notice if: (1) the LARS Associated Load or a portion of the LARS Associated Load fails to achieve a Service Commencement…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
Both the Transmission Owner supporting the LARS Application and requesting to join LARS shall submit the required Large Load information to the MTEP Portal and an Interconnection Customer supporting the LARS Application and requesting to join LARS shall submit their Interconnection Request with the…Read this passage Filed comments: Connecting load and generation
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MISO also clarified several of the requirements of the LARS process including addressing the concerns on representation of the LARS generator/load pair within the parallel study processes.117 The stakeholder process also addressed the relationship between the load and generation, project-readiness…Read this passage Filed comments: Connecting load and generation
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MISO requests that the Commission treat such highlighted language as subject to the outcome of this pending proceeding.Read this passage
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Acceptance of LARS by the requested effective date is necessary to allow LARS to begin on this timeframe because the proposed rules require pre-submission coordination and for MISO to develop software to support the LARS Application prior to opening the first LARS Study Period.Read this passage Filed comments: Connecting load and generation
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COMMUNICATIONS MISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the designation of more than two persons for service on behalf of MISO in this proceeding and requests all…Read this passage
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NOTICE AND SERVICE MISO has served a copy of this filing electronically upon all parties listed on the Commission’s eService list, and upon all Tariff customers, MISO Members, Member representatives of Transmission Owners and non-Transmission Owners, as well as all state commissions within the MISO…Read this passage
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X.Read this passage
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CONCLUSION For all of the foregoing reasons, MISO respectfully requests that the Commission accept this filing and grant waiver of any Commission regulations the Commission deems applicable, but not specifically addressed above in order for the Commission to accept it as proposed.Read this passage