ER27-25-000 · 2026-10-23 · ACP and SREA

Protest and Request for Clarification of the American Clean Power Association and Southern Renewable Energy Association

1 
UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
Midcontinent Independent System 
) 
 
Operator, Inc. 
) 
Docket No. ER27-25-000 
 
) 
 
PROTEST AND REQUEST FOR CLARIFICATION OF THE 
AMERICAN CLEAN POWER ASSOCIATION AND  
SOUTHERN RENEWABLE ENERGY ASSOCIATION 
 
Pursuant to Rules 211 and 212 of the Federal Energy Regulatory Commission’s 
(“Commission”) Rules of Practice and Procedure,1 the American Clean Power Association 
(“ACP”) and Southern Renewable Energy Association (“SREA”) (together, “Clean Energy 
Trades”) submit this protest and request for clarification regarding the Large Load Addition 
Resource Study (“LARS”) proposal filed by the Midcontinent Independent System Operator, Inc. 
(“MISO”) on October 2, 2026 (“Filing”).2 
ACP is the leading national trade association representing companies across the clean 
power industry, including developers, owners, and operators of wind, solar, and energy storage 
facilities, many of which hold or are pursuing generator interconnection requests in MISO’s 
Definitive Planning Phase (“DPP”) queue. SREA is a non-profit regional trade association that 
works to promote the responsible development and use of utility-scale wind energy, solar energy, 
energy storage, and transmission solutions throughout the South. The Clean Energy Trades’ 
 
1  
18 C.F.R. §§ 385.211, 385.212. 
2  
Midcontinent Independent System Operator, Inc., Large Load Addition Resource Study Process, Docket No. 
ER27-25-000 (Oct. 2, 2026) (“Transmittal Letter”). The Filing includes redlined Tariff sheets (Tab A) and 
the Prepared Direct Testimony of Christina Drake (Tab C) (“Drake Testimony”). Capitalized terms not 
otherwise defined herein have the meanings given in the Transmittal Letter or the MISO Tariff. ACP and 
SREA previously submitted to the Commission timely doc-less motions to intervene on October 21,2026 and 
October 7, 2026, respectively. See Doc-Less Motion to Intervene of the American Clean Power Association, 
Docket No. ER27-25-000 (Oct. 21, 2026); Doc-Less Motion to Intervene of the Southern Renewable Energy 
Association, Docket No. ER27-25-000 (Oct. 7, 2026).

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. 
MISO describes LARS as a proposal that “leverages the existing success in the MISO’s 
Expedited Project Review (‘EPR’) process on the load side and lessons learned from Expedited 
Resource Additions Study (‘ERAS’) process on the generation side.”3 The structure of LARS is 
indeed similar to that of ERAS and it raises the same open access, undue discrimination, and queue 
integrity concerns that the Clean Energy Trades raised in the ERAS proceedings, which remain 
pending before the U.S. Court of Appeals for the District of Columbia Circuit.4 But LARS goes 
further than ERAS in ways the Commission has never accepted. It is permanent and uncapped. It 
is untethered to any identified resource adequacy need. It hands the application and the pairing 
decision to the load-serving entity (“LSE”) rather than to MISO. And it is not what the 
Commission’s Show Cause Order described. Most fundamentally, LARS unduly discriminates 
against IPPs by failing to provide comparable access to a Commission-jurisdictional generator 
interconnection process. LARS is also an attempt to convert what was a temporary, extraordinary 
measure into a permanent feature of MISO’s operations. Further, MISO fails to justify LARS as 
an independent entity variation from the Commission’s pro forma Large Generator 
Interconnection Procedures (“LGIP”). For the reasons set forth below, the Commission should 
reject the Filing. 
 
3  
Transmittal Letter at 2. 
4  
See Midcontinent Indep. Sys. Operator, Inc., 192 FERC ¶ 61,064 (2025) (“ERAS Acceptance Order”), order 
addressing arguments raised on reh’g, 194 FERC ¶ 61,050, at P 1 & n.4 (2026) (“ERAS Rehearing Order”) 
(noting rehearing request of the Clean Energy Associations, including ACP).

3 
I. 
BACKGROUND 
A. MISO’s Initial and Revised ERAS Proposals 
On May 16, 2025, the Commission rejected MISO’s initial ERAS proposal, finding that 
MISO had “not demonstrated that its ERAS proposal is a just and reasonable and not unduly 
discriminatory or preferential approach for addressing MISO’s stated resource adequacy and 
reliability needs.”5 The Commission identified two defects. First, the proposed Tariff placed “no 
limit on the number of projects that could be entered in the ERAS process,” which could produce 
an ERAS queue with processing times “similar to the challenges with the current DPP queue” and 
“a volume of ERAS interconnection requests untethered to reliability or resource adequacy 
needs.”6 Second, MISO had not shown “how the ERAS process is sufficiently targeted to study 
only interconnection requests needed to meet the anticipated shortfall in generating capacity 
described by MISO.”7 Commissioners Rosner and See each concurred separately.8 
MISO refiled a revised ERAS proposal that the Commission accepted on July 21, 2025. 
The accepted ERAS process is capped at 68 interconnection requests, with ten reserved for IPPs 
that have agreements with entities other than LSEs and eight reserved for requests serving retail-
choice load; it requires verification by a Relevant Electric Retail Regulatory Authority (“RERRA”) 
of a specific resource adequacy need; and it sunsets on the earlier of August 31, 2027 or completion 
of the sixty-eighth study.9 The Commission explained that these changes “ensure the ERAS 
process is sufficiently limited in scope to swiftly address discrete, demonstrated resource adequacy 
 
5  
Midcontinent Indep. Sys. Operator, Inc., 191 FERC ¶ 61,131, at P 197 (2025) (“ERAS Rejection Order”). 
6  
Id. P 199. 
7  
Id. P 201. 
8  
Id. (Rosner, Comm’r, concurring); id. (See, Comm’r, concurring). 
9  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at PP 16-17, 203.

4 
needs in a narrowly tailored fashion, and on a temporary, time-limited basis,” and that “the limited, 
one-time design of the process weighed significantly on our decision here.”10 MISO’s own witness 
in this proceeding describes ERAS as the “temporary Expedited Resource Addition Study 
(‘ERAS’) process.”11 
B. The Show Cause Order 
On June 18, 2026, the Commission instituted a proceeding under section 206 of the Federal 
Power Act (“FPA”) in Docket No. EL26-70-000.12 As relevant here, the Commission preliminarily 
found that MISO’s Tariff “appears to be unjust and unreasonable because it lacks a generator 
interconnection study process and/or generator interconnection service to reflect an 
interconnection customer’s commitment in an interconnection agreement to limit the generating 
facility’s output to minimize the impact on the transmission system while serving an electrically 
proximate large load or large co-located load.”13 The Commission defined “electrically proximate 
large load” as a large load sufficiently close to the generator’s requested point of interconnection 
(“POI”) “such that the impact on the transmission system of the combination of the generating 
facility and the load, with the exception of the transmission facilities between the two, will be 
effectively the same as if they were located at the same substation (e.g., large load that is located 
no more than two substations away from the generating facility).”14 The Commission further stated 
that, where the generating facility serves an electrically proximate large load, “we believe that the 
generator interconnection service should be of an interim nature until the interconnection customer 
 
10  
Id. P 195; see also ERAS Rehearing Order, 194 FERC ¶ 61,050 at P 12 (quoting same). 
11  
Drake Testimony at 2. 
12  
Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 (2026) (“Show Cause Order”). 
13  
Id. P 113. 
14  
Id. P 112.

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obtains Energy Resource Interconnection Service (ERIS) or Network Resource Interconnection 
Service (NRIS).”15 Separately, the Commission directed MISO to file an informational report on 
proposals under consideration to address resource adequacy for new large loads.16 
C. The LARS Proposal 
MISO proposes LARS as a new, permanent study process under which a large load of at 
least 200 megawatts (“MW”) and one or more new Generating Facilities are studied in parallel, 
with the generator receiving a Large Load Generator Interconnection Agreement (“LLGIA”) for 
NRIS in approximately 120 days.17 MISO will run three LARS study periods per year, each with 
up to ten LARS Applications studied serially on a first-come, first-served basis.18 The LARS 
Application may be initiated and submitted only by the “LARS Associated Transmission 
Customer”—the entity that procures Transmission Service for the load, which MISO 
acknowledges “is often” an LSE.19 The LARS Associated Transmission Customer also pays the 
$250,000 non-refundable application deposit.20 A LARS Generating Facility need only be located 
in the same Local Resource Zone (“LRZ”) as the load, may request NRIS up to 150% of the load’s 
peak demand, and must remain paired with the load for fifteen years, after which its 
Interconnection Service continues regardless of whether the load remains.21 LARS studies will 
 
15  
Id. P 115. 
16  
Id. P 122. 
17  
Transmittal Letter at 7, 11; Drake Testimony at 5, 28. 
18  
Transmittal Letter at 9; Drake Testimony at 22; Tab A, Attachment X, § 3.12.3. 
19  
Transmittal Letter at 6, 8; Tab A, Attachment X, §§ 1, 3.12.1. 
20  
Transmittal Letter at 8. 
21  
Id. at 10, 16-18; Tab A, Attachment X, §§ 3.12.2, 3.12.7.4.

6 
exclude DPP Interconnection Requests that lack an executed Generator Interconnection 
Agreement (“GIA”).22 
II. 
PROTEST 
Because MISO filed LARS under FPA section 205, MISO bears the burden of 
demonstrating that its proposal is just and reasonable and not unduly discriminatory or 
preferential.23 MISO has not carried that burden. LARS is unduly discriminatory because it makes 
the LSE the gatekeeper of a Commission-jurisdictional generator interconnection process and 
gives LSEs contracting options that IPPs do not have. It is also unjust and unreasonable on its own 
terms.  It is a permanent, uncapped priority queue untethered to any demonstrated need, it does not 
reflect the electrically proximate configuration the Show Cause Order described, and it shifts 
transmission capacity and costs away from DPP customers.  These are the same defects the 
Commission identified when it rejected MISO’s initial ERAS proposal. Finally, MISO has not 
shown that LARS satisfies the independent entity variation standard. 
A. LARS Would Unduly Discriminate Against Independent Power Producers and 
Create Opportunities for LSE Self-Dealing. 
i. Open access requires that all interconnection customers have comparable 
access to Commission-jurisdictional interconnection service. 
The Commission’s open access framework rests on the premise that a transmission 
provider must offer service to third parties on the same or comparable basis that it provides service 
to itself. In Order No. 888, the Commission required “that all public utilities must offer . . . services 
on a non-discriminatory open access basis” and explained that “[a]n open access tariff that is not 
unduly discriminatory or anticompetitive should offer third parties access on the same or 
 
22  
Transmittal Letter at 12; Drake Testimony at 14, 28-29. 
23  
16 U.S.C. § 824d; see ERAS Rejection Order, 191 FERC ¶ 61,131 at P 197.

7 
comparable basis, and under the same or comparable terms and conditions, as the transmission 
provider’s uses of the system.”24 The Commission adopted that rule because it found that 
transmission owners with generation interests have the incentive to use their control of the grid to 
favor their own resources.25 
In Order No. 2003, the Commission extended those requirements to generator 
interconnection, recognizing that interconnection is a “critical component of open access 
transmission service and thus is subject to the requirement that utilities offer comparable service 
under the [pro forma open access transmission tariff].”26 The Commission adopted standard 
procedures to “minimize opportunities for undue discrimination and expedite the development of 
new generation, while protecting reliability and ensuring that rates are just and reasonable.”27 
Central to that framework is a single, non-discriminatory generator interconnection queue 
administered by the transmission provider, to which any interconnection customer may submit a 
request on equal terms. The Commission has consistently found the comparable ability of all 
 
24  
Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Servs. by Pub. 
Utils.; Recovery of Stranded Costs by Pub. Utils. & Transmitting Utils., Order No. 888, FERC Stats. & Regs. 
¶ 31,036, at 31,647 (1996) (cross-referenced at 75 FERC ¶ 61,080) (“Order No. 888”), order on reh’g, Order 
No. 888-A, FERC Stats. & Regs. ¶ 31,048, order on reh’g, Order No. 888-B, 81 FERC ¶ 61,248 (1997), 
order on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d in relevant part sub nom. Transmission 
Access Pol’y Study Grp. v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 
U.S. 1 (2002); see also ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 193 & n.483. 
25  
See Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,682 (“It is in the economic self-interest of 
transmission monopolies, particularly those with high-cost generation assets, to deny transmission or to offer 
transmission on a basis that is inferior to that which they provide themselves.”).  
26  
Standardization of Generator Interconnection Agreements & Procs., Order No. 2003, 104 FERC ¶ 61,103, 
at PP 9, 12 (2003) (“Order No. 2003”), order on reh’g, Order No. 2003-A, 106 FERC ¶ 61,220, order on 
reh’g, Order No. 2003-B, 109 FERC ¶ 61,287 (2004), order on reh’g, Order No. 2003-C, 111 FERC ¶ 61,401 
(2005), aff’d sub nom. Nat’l Ass’n of Regul. Util. Comm’rs v. FERC, 475 F.3d 1277 (D.C. Cir. 2007); see 
ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 194. 
27  
Order No. 2003, 104 FERC ¶ 61,103 at P 11.

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generator interconnection customers to submit an interconnection request to be a critical element 
of a just and reasonable and not unduly discriminatory process.28 
Priority interconnection processes are, by their nature, in tension with these principles. As 
Commissioner See explained in concurring in the rejection of MISO’s initial ERAS proposal, 
“where a proposal’s goal is to get some interconnection requests through the study process faster 
than others, the Commission is by definition asked to greenlight discrimination,” and “[t]o justify 
that step under our statutory mandate, priority processes should be tailored enough to accomplish 
the identified ends.”29 The Commission likewise held that MISO “must ensure that this proposal 
is aligned with the Commission’s open access principles in an objective and transparent manner 
in order to meet the FPA’s requirements that rates be just and reasonable and not unduly 
discriminatory or preferential.”30 LARS does not meet that standard. 
ii. LARS makes the LSE the gatekeeper of a Commission-jurisdictional generator 
interconnection process. 
Unlike any generator interconnection process the Commission has accepted, an 
interconnection customer seeking LARS treatment cannot submit its request to MISO. Under 
proposed Section 3.12.1, “[t]he LARS Associated Transmission Customer initiates the submission 
of the LARS Application for the proposed load and associated generation,” and MISO confirms 
that the LARS Associated Transmission Customer “is the only party that may submit the LARS 
 
28  
See ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 204 & n.510 (citing PJM Interconnection, L.L.C., 190 
FERC ¶ 61,084, at P 123 (2025) (“PJM RRI Order”) (comparable ability to submit an interconnection 
request); Cal. Indep. Sys. Operator Corp., 188 FERC ¶ 61,225, at P 94 (2024) (“CAISO IPE Order”) 
(comparable ability to join the cluster)); Protest of the Clean Energy Associations, Docket No. ER25-1674-
000, at 43 (Apr. 7, 2025) (“CEA Protest”). 
29  
ERAS Rejection Order, 191 FERC ¶ 61,131 (See, Comm’r, concurring at P 2) (citing PJM RRI Order, 190 
FERC ¶ 61,084 at P 248). 
30  
Id. P 203.

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Application.”31 In practice, the LARS Associated Transmission Customer will be the LSE that 
procures transmission service on behalf of the large load (hereinafter, the “LSE”). The LSE pays 
the non-refundable application deposit, designates which load is “formally paired” with which 
Interconnection Request, and decides whether any application is submitted at all.32 MISO states 
that allowing the generator and load to contract directly “does not supersede the role of the LARS 
Associated Transmission Customer to determine whether to submit a LARS Application.”33 The 
POI, in turn, must be negotiated by the Interconnection Customer with and attested to by the 
Transmission Owner before the application may be filed.34 Because MISO is primarily a vertically 
integrated region, in which the LSE and the Transmission Owner are frequently the same utility 
or affiliates, the LSE thus controls the generator-side application process entirely. 
Even an IPP with a direct offtake agreement with the large load must be sponsored by the 
LSE’s application; there is no path for an IPP to deal directly with MISO for purposes of accessing 
the generator interconnection queue. And in most MISO states, retail service laws prohibit an IPP 
from contracting to serve the load directly—a point MISO itself acknowledges by adding Tariff 
language providing that LARS does not authorize a generator that is not an LSE to serve load 
where state law does not allow it.35 In those states, the IPP’s only possible counterparty is the same 
utility that controls the application and that may compete to self-build the generation. To be clear, 
the Clean Energy Trades’ concern is with ensuring that access to a Commission-jurisdictional 
generator interconnection process is not unduly discriminatory, consistent with the Commission’s 
 
31  
Tab A, Attachment X, § 3.12.1; Transmittal Letter at 8; see also Drake Testimony at 18. 
32  
Transmittal Letter at 8-9; Tab A, Attachment X, § 1 (definition of LARS Associated Transmission Customer). 
33  
Transmittal Letter at 9. 
34  
Tab A, Attachment X, § 3.12.1. 
35  
Tab A, Attachment X, § 3.12.2; Transmittal Letter at 30.

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open access principles. The Clean Energy Trades fully acknowledge that certain state laws in 
MISO restrict third-party competitive generation from serving retail load and the Clean Energy 
Trades do not seek to change those laws or to expand retail competition through this proceeding. 
The Commission has recognized that utilities with generation interests have the incentive 
to discriminate when given the opportunity. Indeed, that is the premise of Order Nos. 888 and 
2003, and of the independent entity variation itself.36 The concern is particularly acute in MISO, 
which, as Commissioner See observed, “is largely comprised of vertically integrated States.” 
Illinois and part of Michigan are the only retail choice jurisdictions in MISO.37 The Commission 
addressed this very risk in ERAS, where MISO reserved ten slots for IPPs with agreements with 
entities other than LSEs specifically “to address claims that LSEs could block independent power 
producers from participating in the ERAS process,” and eight slots for retail-choice load.38 The 
Commission relied on those carve-outs to find that “all interconnection customers will have 
comparable ability to seek to participate in the ERAS process, regardless of location and ownership 
type.”39 ERAS also required a RERRA to verify the need for each project, including LSE self-
supply projects.40 LARS has no carve-out, no RERRA or other regulatory check, and no scoring 
criteria. 
While it is reasonable for LSEs to initiate and oversee LARS requests on the load side, 
given state jurisdiction over retail service and LSEs’ obligations to serve load, that logic does not 
 
36  
See Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,682; Order No. 2003, 104 FERC ¶ 61,103 at P 827. 
37  
ERAS Rejection Order, 191 FERC ¶ 61,131 (See, Comm’r, concurring at P 4 & n.6); see also id. (Rosner, 
Comm’r, concurring at P 5) (“[I]n MISO, . . . most states are vertically integrated.”).  
 38  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at PP 203-205. 
39  
Id. P 204. 
40  
Id. PP 198-201, 207.

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extend to the generation side, where generator interconnection procedures fall within the 
Commission’s exclusive jurisdiction and are subject to open access requirements.41 Nothing 
prevents MISO from allowing an interconnection customer to initiate the generator portion of a 
LARS Application directly with MISO, with an obligation on the LSE and Transmission Owner 
to respond. Stakeholders asked MISO to do exactly that and MISO declined without explanation.42 
Allowing incumbent LSEs to gain complete control of the entry point to a new, expedited generator 
interconnection process is inconsistent with the Commission’s exclusive jurisdiction over 
generator interconnection and with its open access rules. 
iii. LARS does not offer interconnection service on a comparable and non-
discriminatory basis to similarly situated interconnection customers. 
The designation of the LSE as the sole entity that may submit an application is not the only 
obstacle to open access. LARS’ eligibility requirements also discriminate against third-party 
competitive generation. Every LARS application requires an executed, binding agreement between 
the Interconnection Customer and either the LSE or the entity that owns or controls the load.43 
Even in the hypothetical scenario in which an LSE agrees to incorporate a third party’s 
Interconnection Request into its LARS application, the third party must produce either a power 
purchase agreement (“PPA”) or similar offtake agreement with the load, or a Build-Own-Transfer 
 
41  
See Show Cause Order, 195 FERC ¶ 61,212 at P 110 (“The Commission also has exclusive jurisdiction to 
regulate the procedures and agreements applicable to generating facilities seeking to interconnect to a 
Commission-jurisdictional distribution facility or transmission facility.” . . . “[T]he Commission retains 
jurisdiction over a generator’s interconnection even where the generator plans to serve an electrically 
proximate large load.”). 
42  
See American Clean Power Association Comments on Generation and Large Load Alignment, MISO Large 
Load Working Group (July 30, 2026), available at: LLWG: Generation and Large Load Alignment (LLWG-
2026-6) (20260716).  
43  
Tab A, Attachment X, § 3.12.2(i).

12 
agreement transferring the facility to the LSE or load.44 An LSE, however, may instead rely on 
“evidence of other types of agreements that provide that the generation is intended to serve the 
LARS Associated Load customer,” including “a special contract, a large load tariff agreement, or 
retail service agreement.”45 MISO’s witness explains that this third option was added specifically 
to accommodate “specific utility arrangements with large loads where the LSE business model 
uses one or more agreements that are not traditional PPAs.”46 LSEs are thus afforded far more 
flexible means of qualifying than are IPPs. 
Comparable flexibility for third parties is necessary both to avoid undue discrimination and 
to provide commercially viable options. Requiring an executed PPA as a condition of entry into 
an interconnection process is inconsistent with the project development life cycle. In Order No. 
2023, the Commission declined to adopt the non-financial commercial readiness demonstrations 
proposed in the NOPR—which included executed contracts—recognizing that such 
demonstrations “may be unavailable to interconnection customers with commercially viable 
projects,” for example “as a result of a misalignment of the timing between resource procurement 
decisions and interconnection study processes.”47 Network Upgrade costs were not known at the 
time of an ERAS application and they will not be known at the time of a LARS application; an 
IPP must commit to binding offtake terms without knowing its interconnection costs, while the 
LSE may rely on a retail tariff arrangement whose costs can be passed through to ratepayers. 
 
44  
Id. § 3.12.2(i)(a)-(b). 
45  
Id. § 3.12.2(i)(c). 
46  
Drake Testimony at 31-32; see also Transmittal Letter at 9. 
47  
Improvements to Generator Interconnection Procs. & Agreements, Order No. 2023, 184 FERC ¶ 61,054, at 
PP 694-695 (2023) (“Order No. 2023”), order on reh’g, Order No. 2023-A, 186 FERC ¶ 61,199 (2024).

13 
The Clean Energy Trades recognize that, in ERAS, the Commission found that a similar 
distinction between IPP agreement options and LSE self-supply did not render the proposal unjust 
and unreasonable.48 But the Commission reached that conclusion because LSE self-supply under 
ERAS “must still be verified by a RERRA,” because ERAS reserved slots for IPPs with non-LSE 
agreements, and because the process was limited in duration and size.49 None of those safeguards 
exists in LARS. The ERAS agreement requirement was also more flexible for IPPs than the LARS 
requirement. Under ERAS, any interconnection customer—including an IPP—could satisfy the 
requirement through an “other” executed agreement, an option MISO added to establish “a 
minimum requirement that an arrangement exists between the driver of the need and the project to 
address that need,” and which the Commission found “provides considerable flexibility for 
interconnection customers, including independent power producers.”50 LARS includes a similar 
catch-all—“other types of agreements that provide that the generation is intended to serve the 
LARS Associated Load customer”—but makes it available only to LSEs and Alternative Retail 
Electric Suppliers.51 That IPPs were able to participate in ERAS therefore says little about whether 
they can do so on comparable terms under LARS. 
The practical result of these restrictions on open access will be (1) a reduction in the pool 
of supply options with timely GIAs available to large load offtakers and for state consideration in 
competitive solicitation processes; (2) the ability of LSE self-supply to drive the cost of new 
generation serving large loads; and (3) the general elimination of visibility into the pricing of 
 
48  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 207. 
49  
Id. PP 195, 203-207. 
50  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 208 & n.520 (quoting Witmeier Testimony at 42). 
51  
Tab A, Attachment X, § 3.12.2(i)(c); see Drake Testimony at 31 (describing option (c) as establishing “a 
minimum requirement that an arrangement exists between the LARS Associated Transmission Customer and 
the Interconnection Customer”).

14 
alternative generation that could have obtained timely GIAs on comparable terms. MISO’s 
assurance that LARS is “open to all Interconnection Customers that meet the Tariff’s 
requirements” does not answer these concerns, because the Tariff’s requirements themselves are 
what deny comparable access.52 
B. LARS Is Not Just and Reasonable. 
i. LARS is a permanent, uncapped expedited queue untethered to any identified 
need, unlike every expedited interconnection process the Commission has 
accepted. 
The Show Cause Order did not direct MISO to create a separate, permanent, expedited 
generator interconnection queue. The Commission expressed concern about the absence of “a 
generator interconnection study process and/or generator interconnection service” reflecting a 
generator’s commitment to limit its output while serving an electrically proximate large load.53 
The Commission did not require that such a process operate outside of, or ahead of, the DPP, and 
it stated that service to a generator serving an electrically proximate large load “should be of an 
interim nature until the interconnection customer obtains [ERIS] or [NRIS].”54 LARS does the 
opposite: it grants permanent NRIS through a parallel process that MISO describes as “a 
permanent MISO study process.”55 Moreover, the Filing makes clear that even where the paired 
LARS Associated Load ceases taking service, or the agreement pairing the generator and the load 
terminates, during the fifteen-year pairing period, the LARS generator may continue to operate 
under its LLGIA—subject to MISO’s Annual ERIS and Quarterly Operating Limit processes—
 
52  
Transmittal Letter at 52; see also Drake Testimony at 18-19 (asserting that LARS requirements are “facially 
neutral”). 
53  
Show Cause Order, 195 FERC ¶ 61,212 at P 113. 
54  
Id. P 115. 
55  
Transmittal Letter at 11; see also Drake Testimony at 10-12, 28.

15 
not only for a one-year transition period, but for as long as DPP processing of its new 
Interconnection Request is delayed beyond that year.56 In effect, this work-around creates an 
exclusive pathway for LSE-selected generators to leverage their access to LARS to obtain 
expedited interconnection that persists even after the paired load is gone, undermining the very 
basis for granting those generators priority access in the first place. 
Nor did the Show Cause Order’s invitation for resource adequacy proposals relax the FPA 
section 205 standard. The Commission directed MISO to report on proposals under consideration 
to address resource adequacy for new large loads and “strongly encourage[d] new proposals to the 
extent necessary to address these concerns.”57 An invitation to propose solutions is not a pre-
approval of whatever MISO proposes and it does not displace the Commission’s consistent 
requirement that priority interconnection processes be bounded and tailored to an identified need. 
Every expedited interconnection process the Commission has accepted has been bounded. 
In PJM’s Reliability Resource Initiative (“RRI”), PJM specified that it would study no more than 
50 projects on a one-time basis, “providing clear bounds in its tariff.”58 The revised MISO ERAS 
process is capped at 68 requests and sunsets no later than August 31, 2027—limits that remained 
in place even when the Commission later accepted an increase in the number of requests MISO 
may study each quarter.59 SPP’s ERAS was a one-time process that limited the capacity that may 
participate through a formula tied to each participating load-responsible entity’s resource adequacy 
 
56  
Transmittal Letter at 16-18, 41-42; Tab A, Attachment X, Appendix 6, art. 2.3.1; Drake Testimony at 36-37. 
57  
Show Cause Order, 195 FERC ¶ 61,212 at P 122. 
58  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 200 (citing PJM RRI Order, 190 FERC ¶ 61,084 at P 242). 
59  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at PP 17, 203, 264; see Midcontinent Indep. Sys. Operator, 
Inc., 193 FERC ¶ 61,168, at P 1 (2025) (accepting increase in quarterly ERAS study limit from 10 to 15 
requests); ERAS Rehearing Order, 194 FERC ¶ 61,050 at P 45.

16 
deficiency.60 SPP’s High Impact Large Load Generation Assessment (“HILLGA”)—the model 
the Show Cause Order itself discussed—is an “interim” service that the Commission accepted as 
“a flexible, expedited, and separate serial interconnection process that will facilitate the prompt 
interconnection of generating facilities that are limited to serving a [High Impact Large Load 
(“HILL”)] in the same local area.”61 HILLGA interconnection agreements automatically terminate 
five years after commercial operation, so that generators using the process must ultimately obtain 
continued service through SPP’s standard generator interconnection queue.62 In accepting MISO’s 
revised ERAS proposal, the Commission emphasized that “the limited, one-time design of the 
process weighed significantly on our decision.”63 Commissioner Chang likewise explained that 
limiting the number of participating projects is “a minimum requirement to avoid creating a 
perpetual process under which certain resources can bypass the existing queue,” and that ERAS 
was acceptable only because it is “truly a one-time exception to the traditional interconnection 
process as required by Orders No. 2003 and 2023.”64 
LARS has none of these bounds. It has no overall cap, no sunset, and no limit on the total 
megawatts that may be studied: thirty generation/load pairs may enter every year, indefinitely.65 
The ten-application limit per study period controls only MISO’s workload, not the volume of 
capacity that LARS will ultimately allocate. That is the precise defect the Commission identified 
 
60  
See Sw. Power Pool, Inc., 192 FERC ¶ 61,062, at PP 32, 111 (2025); ERAS Rehearing Order, 194 FERC ¶ 
61,050 at n.205.  
61  
Show Cause Order, 195 FERC ¶ 61,212 at P 115 (quoting Sw. Power Pool, Inc., 194 FERC ¶ 61,031, at P 64 
(2026) (“SPP HILL Order”)). 
62  
SPP HILL Order, 194 FERC ¶ 61,031 at P 34, 69.  
63  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 195. 
64  
Id. (Chang, Comm’r, concurring at PP 7-8). 
65  
Transmittal Letter at 9; Tab A, Attachment X, § 3.12.3.

17 
in the initial ERAS proposal, which it rejected in part because MISO proposed “up to 14 
opportunities to enter the ERAS process through 2028,” exacerbating “the potential for a volume 
of ERAS interconnection requests untethered to reliability or resource adequacy needs.”66 LARS 
offers unlimited opportunities with no end date. Moreover, unlike SPP’s HILLGA agreements, 
LARS LLGIAs have no term limit to ensure that LSE-selected generators are ultimately processed 
through a non-discriminatory generator interconnection queue.67 
Nor is LARS tethered to any identified resource adequacy need. Unlike ERAS, LARS 
requires no RERRA verification of a resource adequacy deficiency, and it does not limit 
participation to resources needed to meet a demonstrated shortfall. To the contrary, MISO 
concedes that “MISO’s existing processes have been sufficient to ensure resource adequacy in the 
short term.”68 MISO’s witness states that “LARS primarily addresses a timing issue”: EPR studies 
for large loads can be completed on a 90-day timeline, while the DPP is designed for a 365-day 
timeline.69 A timing mismatch is a reason to complete the DPP reforms MISO describes, or at most 
to adopt a transitional, bounded tool of the kind the Commission accepted for ERAS—not to create 
a permanent parallel queue controlled by LSEs. MISO itself testifies that its ongoing queue reforms 
“are producing—and will continue to produce—significant process efficiencies.”70 MISO has 
implemented automated interconnection studies through its SUGAR software, a queue cap, and, 
most recently, proposed the Legacy Queue Acceleration framework, which the Clean Energy 
 
66  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 199. 
67  
Compare SPP HILL Order, 194 FERC ¶ 61,031 at PP 34, 69 ], with Tab A, Attachment X, § 3.12.7.4 
(Interconnection Service continues after fifteen years). 
68  
Transmittal Letter at 3. 
69  
Drake Testimony at 12. 
70  
Id. at 6.

18 
Trades support.71 If MISO believed those reforms would fail, it should have said so and supported 
that claim. It says the opposite. 
MISO’s stated reasons for permanence do not cure the problem. MISO argues that a 
temporary process “would create unnecessary costs and uncertainty,” that it would be inefficient 
to “weigh down the DPP” with requests already paired with a large load, and that a permanent 
process “will help MISO avoid a rush of projects like was experienced with ERAS.”72 Each of 
those rationales is an argument for giving a favored class of interconnection customers a 
permanent, faster path to injection rights—not a reason the Commission’s tailoring requirement 
should not apply. The “rush of projects” MISO experienced under ERAS is evidence of the demand 
for priority treatment, which is exactly why the Commission has insisted on firm limits.73 
ii. LARS does not provide the electrically proximate, output-limited service the 
Show Cause Order described, and its same-LRZ pairing grants broad priority 
injection rights to generators that need not be operationally tied to the load. 
The Show Cause Order’s preliminary finding was premised on a specific operational 
configuration: an interconnection customer’s “commitment in an interconnection agreement to 
limit the generating facility’s output to minimize the impact on the transmission system while 
serving an electrically proximate large load.”74 The Commission repeatedly described service that 
reflects “an interconnection customer’s commitment in an interconnection agreement to limit a 
 
71  
Id. at 6; Transmittal Letter at 15 n.67; see Comments of the American Clean Power Association, Docket No. 
ER26-3813-000 (Oct. 5, 2026). MISO asked the Commission to act on that proposal by October 19, 2026, 
ahead of the October 20, 2026 close of Decision Point II for the DPP-2022 cycle. See Motion for Leave to 
Answer and Answer of the Midcontinent Independent System Operator, Inc., Docket No. ER26-3813-000, 
at 1 (Oct. 12, 2026). As of the date of this filing, the Commission has not acted on the proposal. 
72  
Drake Testimony at 10-11. 
73  
See ERAS Rejection Order, 191 FERC ¶ 61,131 (Rosner, Comm’r, concurring at P 3) (“[T]here is no 
guarantee that interest in ERAS will be limited . . . .”). 
74  
Show Cause Order, 195 FERC ¶ 61,212 at P 113.

19 
generating facility’s output to match the hourly forecast of an electrically proximate large load,” 
and generating facilities “with necessary control technologies and/or protection systems” that 
ensure injections do not exceed contractual limits.75 The rationale was that, where the generating 
facility and load are so close that their combined impact is “effectively the same as if they were 
located at the same substation,” the transmission provider “would need to study only the local 
impacts,” potentially reducing Network Upgrades.76 The Clean Energy Trades read the Show 
Cause Order to contemplate a study process and service that is predicated on the generator’s ability 
and commitment to minimize its impact on the transmission system while serving the associated 
load, namely through output limits matched to the load’s demand and the control technologies or 
protection systems necessary to enforce them. 
LARS contains no such predicate. A LARS Generating Facility need only have a POI in 
the same LRZ as the load’s Point of Withdrawal.77 MISO’s LRZs are resource adequacy zones 
that can span an entire state or multiple states. MISO acknowledges that it considered—and 
rejected—narrower alternatives such as requiring the generator and load to be in the same Local 
Balancing Authority area “or through requiring that the location of the Generating Facilities be 
within a specific number of substations of the LARS Associated Load,” and instead chose a 
construct that “enables more generation to serve a single load across a broader area.”78 MISO even 
describes the multiple-POI option as a “proximate plus” solution.79 In direct contrast to the Show 
Cause Order’s reasoning, LARS does not require the generator to limit its output to the load’s 
 
75  
Id. PP 113, 116, 118. 
76  
Id. PP 112, 113 & n.256. 
77  
Transmittal Letter at 10; Tab A, Attachment X, § 3.12.2. 
78  
Transmittal Letter at 10, 21; see also Drake Testimony at 40. 
79  
Transmittal Letter at 21.

20 
demand, to operate behind protection schemes, or to forgo injections beyond the load’s needs. To 
the contrary, it grants full NRIS, studied for deliverability “across MISO’s footprint,” with the 
fifteen-year pairing term as the only meaningful limitation.80 MISO confirms that it “will not limit 
the study process to the specific LRZ the generation/load pair will be located in.”81 After fifteen 
years, even the pairing requirement falls away, and the generator retains unrestricted 
Interconnection Service.82 
This design is unjust and unreasonable even apart from the Show Cause Order. The 
justification for studying generation and load together—and for affording that study expedited 
treatment—is that electrically proximate generation and load reduce the burden on the 
transmission system. Where the generator may be located anywhere in a multi-state LRZ, that 
justification disappears. LARS would instead give a subset of generators access to an exclusive, 
expedited queue for full network injection rights without any requirement that they be 
operationally tied to the load they are intended to serve, allowing them to consume transmission 
headroom—potentially in already congested areas—ahead of DPP projects that have waited years 
for study. That is a preference for a class of interconnection customers defined by their contractual 
relationship with an LSE, not by any reduced impact on the grid. 
iii. LARS projects would gain priority access to transmission capacity and avoid 
Network Upgrades they would otherwise trigger, shifting costs to DPP 
customers and other transmission customers. 
MISO asserts that LARS will be conducted in “parallel” with the DPP and is “designed to 
preserve the integrity of MISO’s existing generator interconnection processes,” because LARS 
 
80  
Drake Testimony at 12-13, 29; Transmittal Letter at 10, 16-18. 
81  
Transmittal Letter at 13. 
82  
Id. at 18; Tab A, Attachment X, § 3.12.7.4.

21 
requests “will not be included in ongoing DPP studies and therefore will not utilize any available 
transmission capacity in those studies.”83 On the surface, that appears equitable. The harm is in 
the details. 
LARS studies “will not include Interconnection Requests currently in the generator 
interconnection queue that do not have an executed GIA.”84 LARS projects will therefore be 
studied as if the only other generation on the system is generation that already holds a GIA. That 
excludes every request in the DPP-2022 cycle without an executed GIA and every request in the 
DPP-2023 and DPP-2025 cycles, including projects with Phase III results and GIAs in negotiation. 
Because LARS cycles are designed to move significantly faster than the DPP, and because multiple 
backlogged DPP cycles have not yet reached GIA, LARS projects will claim available headroom 
and will avoid Network Upgrades that would likely be assigned to them if the higher-queued DPP 
projects were modeled. The practical effect is that LARS projects are treated as if they were studied 
first, even though the studies occur in “parallel” on paper, resulting in more constraints and higher 
Network Upgrade costs for DPP projects when they are finally studied against a system that LARS 
projects have already used. 
MISO’s answer to this concern is that “[t]he models from LARS and the DPP process will 
be reconciled through MTEP.”85 That is not a protection. MISO acknowledges that, where 
overallocation occurs, the resulting constraints “would be formalized in a future MTEP project” 
whose cost “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,” and MISO candidly 
 
83  
Transmittal Letter at 4, 13. 
84  
Id. at 12 (quoting Drake Testimony at 29); see also Drake Testimony at 14. 
85  
Transmittal Letter at 20; Drake Testimony at 33.

22 
states: “This cost shift is consistent with MISO’s existing processes.”86 Nothing in the Filing 
ensures that the reconciliation will produce minimal upgrades, or that the resulting costs will not 
be borne by DPP interconnection customers as they move through later studies or by other 
transmission customers through MTEP cost allocation. MISO’s assurance that there is only “a 
minimal risk of overallocation” is unsupported by any analysis in the record.87 The Show Cause 
Order expressly identified the “risk of cost shifting among transmission customers” associated 
with large load additions as a potential source of unjust and unreasonable rates.88 LARS would 
institutionalize that risk. 
The risk is not hypothetical. MISO reports that during the MTEP26 cycle it approved 26 
GW of Spot Loads through the EPR process, along with an additional 40 Corrective Action Plan 
transmission projects, and that another 10 GW of load is under study.89 Eight of the top ten 
MTEP26 projects, totaling roughly $6 billion (approximately 41% of the $14.7 billion MTEP26 
portfolio), are EPR projects. LARS is designed to channel a substantial share of that load growth, 
paired with generation, through a process whose cumulative effects on DPP studies MISO has not 
evaluated. High concentrations of new load and LARS generation in particular areas could create 
constraints that limit import capability, increasing congestion and the need for Network Upgrades 
where they might not otherwise have been needed—costs that DPP generators may become 
responsible for as they move through their own studies. 
The asymmetry in model updates compounds the problem. MISO explains that the DPP 
“uses the most up to date MTEP base case when the study is kicked off and is not modified to 
 
86  
Transmittal Letter at 13; Drake Testimony at 33. 
87  
Drake Testimony at 33. 
88  
Show Cause Order, 195 FERC ¶ 61,212 at PP 66, 68. 
89  
Drake Testimony at 7.

23 
include later approved MTEP projects or LLGIAs.”90 LARS studies, by contrast, begin from the 
latest MTEP base case, including recently approved EPR projects and prior LARS outcomes.91 
DPP customers therefore will not have the benefit of new load-driven MTEP projects in their 
modeling, while LARS customers will—which can produce very different Network Upgrade 
assignments and cost outcomes for DPP interconnection customers that sign GIAs after multiple 
LARS cycles have been processed. 
The Clean Energy Trades recognize that, in accepting the revised ERAS proposal, the 
Commission found similar concerns about modeling exclusions and MTEP reconciliation to be 
speculative.92 But that finding rested on a process capped at 68 requests and scheduled to end in 
2027, and on the Commission’s observation that future DPP customers would have notice of a 
time-limited ERAS process.93 Those premises do not hold for LARS. A permanent process that 
adds up to thirty generation/load pairs per year, with no limit on total MW and no end date, will 
repeatedly and cumulatively claim headroom ahead of the DPP. The question is not whether harm 
to DPP customers is possible in a single bounded cycle, but whether MISO has shown that a 
perpetual priority process will not systematically shift capacity and costs to them. MISO has not 
attempted that showing. 
iv. LARS diverts MISO’s attention and resources from completing the reforms 
required by Order No. 2023. 
In Order No. 2023, the Commission acted to address interconnection queue backlogs, 
reduce delays and uncertainty, and ensure that new resources can interconnect in a reliable, 
 
90  
Drake Testimony at 32. 
91  
Id. at 14, 28-29; Transmittal Letter at 12. 
92  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at PP 259, 261-263. 
93  
Id. PP 258, 262, 264.

24 
efficient, transparent, and timely manner on a non-discriminatory basis.94 The Commission found 
that the serial, first-come, first-served study process is a source of queue delays.95 LARS is a serial, 
first-come, first-served process.96 MISO has now twice prioritized separate, one-off expedited 
processes that not all market participants can feasibly access on a comparable, not unduly 
discriminatory basis, while the DPP remains significantly backlogged. Although MISO asserts that 
LARS fees will fund additional staff and that “no staff time or resources will be shifted between 
the DPP queue and LARS,”97 the time and resources MISO and its stakeholders devote to 
designing, defending, and administering parallel processes are time and resources not spent 
completing the DPP reforms that would benefit all interconnection customers. Commissioner 
Chang has observed that “[o]ne-off short-term fixes can create additional problems and at times 
beget further one-off fixes,” and that “[d]eveloping these types of temporary proposals can detract 
from our collective efforts to address the more fundamental underlying issues.”98 A permanent 
parallel process is that concern made structural. 
C. The Commission’s Orders on MISO’s ERAS Proposals Confirm That LARS Is 
Not Just and Reasonable. 
Although MISO is entitled under FPA section 205 to propose a different approach than the 
Commission has previously accepted, the Commission’s orders on MISO’s ERAS proposals 
identify the elements that rendered an expedited interconnection process unjust and unreasonable, 
as well as the guardrails that ultimately allowed one to be accepted. LARS shares the flaws the 
 
94  
Order No. 2023, 184 FERC ¶ 61,054 at PP 1-3. [Confirm pin cite.] 
95  
Id. P 47. 
96  
Drake Testimony at 10, 22. 
97  
Id. at 32. 
98  
ERAS Acceptance Order, 192 FERC ¶ 61,064 (Chang, Comm’r, concurring at P 3).

25 
Commission identified in the initial ERAS proposal and lacks the guardrails that saved the revised 
one. 
i. No limit on volume. 
The Commission rejected the initial ERAS proposal because “MISO’s proposed Tariff 
places no limit on the number of projects that could be entered in the ERAS process,” which 
threatened processing times “similar to the challenges with the current DPP queue.”99 
Commissioner Rosner explained that he could not find the proposal just and reasonable “because 
the lack of limitations on the volume of interconnection requests threatens to overwhelm the ERAS 
queue with processing delays,” and urged MISO to adopt practical limits such as “a one-time 
ERAS submittal window with a limit on the number of projects.”100 LARS limits the number of 
applications per study period but places no limit on the number of periods, the total number of 
projects, or the total MW that may be studied.101 
ii. No tether to an identified need. 
The Commission found that the initial, rejected MISO ERAS proposal did “not sufficiently 
describe how the ERAS process is sufficiently targeted to study only interconnection requests 
needed to meet the anticipated shortfall in generating capacity,” and that it was “difficult to 
determine whether the volume of resource additions . . . will exceed what is needed to address 
MISO’s near-term resource adequacy needs — in other words, whether the solution is narrowly 
tailored to fix the problem.”102 MISO did not even identify a shortfall here; it states that its existing 
 
99  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 199. 
100  
Id. (Rosner, Comm’r, concurring at PP 3, 6). 
101  
See supra Part II.B.i. 
102  
ERAS Rejection Order, 191 FERC ¶ 61,131 at PP 199, 201.

26 
processes have been sufficient to ensure resource adequacy.103 LARS eligibility turns on the size 
of a load and the existence of a contract, not on any resource adequacy or reliability need. 
iii. Selection outsourced to non-independent entities without objective, 
transparent criteria. 
Commissioner See explained that the initial, rejected MISO ERAS proposal “outsource[d] 
the expedited study selection process altogether,” and that “MISO is the regulated entity, not the 
States, and the Commission’s statutes require us to evaluate its processes.”104 She concluded that 
“the Commission cannot evaluate criteria that do not yet exist, that will vary State-by-State when 
they do, and that MISO does not plan to police.”105 LARS goes further: it outsources selection not 
to state regulators, but solely to LSEs—market participants that may compete with the IPPs 
seeking access. There are no criteria an LSE must apply in deciding which generators to sponsor, 
no transparency into the LSE’s decision-making, and no mechanism for an excluded 
interconnection customer to challenge that decision. 
iv. None of the guardrails that supported prior expedited processes. 
In each instance in which the Commission accepted an expedited process that raised undue 
discrimination concerns, it weighed the proposal against guardrails that protected against undue 
discrimination. In PJM’s RRI and CAISO’s Interconnection Process Enhancements (“IPE”), all 
projects had the comparable ability to submit a request and work directly with the RTO/ISO; they 
were simply subject to objective, published scoring criteria rather than the traditional queue 
 
103  
Transmittal Letter at 3. 
104  
ERAS Rejection Order, 191 FERC ¶ 61,131 (See, Comm’r, concurring at PP 6-7). 
105  
Id. (See, Comm’r, concurring at P 7).

27 
order.106 PJM’s RRI was a one-time process limited to 50 projects.107 The revised ERAS process 
was accepted only after MISO added a cap, IPP and retail-choice carve-outs, strengthened RERRA 
verification, a same-LRZ need requirement, and a sunset date.108 LARS contains no scoring 
criteria, no carve-outs, no regulatory verification, no cap, and no sunset. It is designed to be a 
permanent process in which one subset of market participants controls access to a generator 
interconnection queue. Accepting LARS would be inconsistent with the Commission’s 
determinations in the ERAS proceedings.109 
v. Legal durability. 
Both concurring Commissioners emphasized that an expedited process must be legally 
durable to provide the certainty that customers need. Commissioner Rosner warned that 
“insufficient limitations on the requests that may be studied through ERAS risks a court striking 
down the proposal,” and that if ERAS agreements had to be rescinded, “the upheaval could 
seriously harm MISO’s customers.”110 Commissioner See likewise cautioned that “proposals that 
are not just and reasonable and not unduly preferential or discriminatory are vulnerable to judicial 
scrutiny,” and that “a win today but a loss in court months (or years) later would not help MISO 
address its resource adequacy concerns.”111 Those concerns apply with greater force to a 
 
106  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 202 (discussing PJM RRI location criterion and CAISO IPE 
system need criterion); ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 204 n.510; see also ERAS 
Rejection Order, 191 FERC ¶ 61,131 (See, Comm’r, concurring at P 7 n.13) (comparing PJM RRI “scoring 
criteria that are calibrated to satisfy PJM’s resource adequacy needs”). 
107  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 200. 
108  
ERAS Acceptance Order, 192 FERC ¶ 61,064 at PP 195, 203-205. 
109  
See CEA Protest at 42-45. 
110  
ERAS Rejection Order, 191 FERC ¶ 61,131 (Rosner, Comm’r, concurring at PP 1, 4). 
111  
Id. (See, Comm’r, concurring at P 9).

28 
permanent process under which LLGIAs will be executed three times a year for the indefinite 
future. 
D. MISO Has Not Demonstrated That LARS Satisfies the Independent Entity 
Variation Standard. 
In Order No. 2003, the Commission permitted RTOs and ISOs to propose “independent 
entity variations” from the pro forma LGIP and LGIA, recognizing that an RTO or ISO “has 
different operating characteristics depending on its size and location and is less likely to act in an 
unduly discriminatory manner than a Transmission Provider that is a market participant.”112 Under 
that standard, an RTO/ISO must demonstrate that its proposed variations “are just and reasonable 
and not unduly discriminatory or preferential and accomplish the purposes of Order No. 2003.”113 
The flexibility the standard affords rests on the RTO/ISO’s independence. Although RTOs have 
far less incentive to discriminate, the same cannot be said of the LSEs and Transmission Owners 
to which LARS delegates control. 
LARS deviates from at least three core elements of the pro forma LGIP. First, under the 
pro forma LGIP, an interconnection customer submits its interconnection request directly to the 
transmission provider, and the transmission provider—not a third party—administers access to 
interconnection service.114 LARS instead requires that the request be submitted by the LSE, and it 
requires a POI agreed to and attested by the Transmission Owner before the request may be 
filed.115 Second, the pro forma LGIP establishes a single queue in which requests are studied on 
 
112  
Order No. 2003, 104 FERC ¶ 61,103 at P 827; see also id. P 26. 
113  
ERAS Rejection Order, 191 FERC ¶ 61,131 at P 3 (citing Midcontinent Indep. Sys. Operator, Inc., 185 FERC 
¶ 61,084, at P 11 (2023)); see also ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 259 (applying standard 
to ERAS). 
114  
See pro forma LGIP § 3.1.  
115  
Tab A, Attachment X, §§ 3.12.1, 3.12.2.

29 
the basis of queue position and, following Order No. 2023, in clusters on a first-ready, first-served 
basis.116 LARS creates a separate, permanent queue studied serially on a first-come, first-served 
basis and excludes DPP requests without executed GIAs from its models.117 Third, the pro forma 
LGIP makes interconnection service available on equal terms to any interconnection customer that 
satisfies objective readiness requirements; LARS conditions access on a commercial relationship 
with, and the sponsorship of, the LSE, with qualifying agreements that differ depending on whether 
the customer is an LSE.118 
MISO does not attempt to justify these deviations under the independent entity variation 
standard; it simply asserts that LARS is just and reasonable and not unduly discriminatory.119 
Because MISO itself is not the entity to which the generator submits its LARS application, and 
because working through the LSE is a requirement for IPP participation, MISO has effectively 
installed the LSE as the facilitator of the LARS process. The rationale for the independent entity 
variation—that an independent RTO is less likely to discriminate—cannot justify a variation 
whose effect is to transfer gatekeeping authority from the independent RTO to market participants. 
Because the LSE is the gatekeeper of LARS in a way that goes beyond even the initial ERAS 
proposal, MISO cannot satisfy the independent entity variation standard, and LARS does not 
accomplish the purposes of Order No. 2003: to “minimize opportunities for undue discrimination 
and expedite the development of new generation.”120 
 
116   
See pro forma LGIP §§ 4.1, 7; Order No. 2023, 184 FERC ¶ 61,054 at P 47.  
117  
Drake Testimony at 10, 14, 22. 
118  
Tab A, Attachment X, § 3.12.2(i). 
119  
See Transmittal Letter at 18-22. 
120  
Order No. 2003, 104 FERC ¶ 61,103 at P 11.

30 
III. 
REQUEST FOR CLARIFICATION 
If the Commission does not reject the Filing, it should direct MISO to clarify whether the 
LARS same-LRZ requirement applicable to a LARS Interconnection Customer is determined 
based on a Generating Facility’s physical location or on its POI to the MISO Transmission System. 
Proposed Attachment X, Section 3.12.2 appears to apply the same-LRZ requirement based on the 
Generating Facility’s POI for an individual LARS Interconnection Customer, providing that “[t]he 
Point of Interconnection specified in a LARS Application must be located in the same Local 
Resource Zone as the Point of Withdrawal of the LARS Associated Load.”121 However, where 
multiple Generating Facilities serve a single LARS Associated Load behind different POIs, the 
proposed Tariff states that the Generating Facilities must “[b]e located in the same LRZ as the 
LARS Associated Load,” creating ambiguity as to whether the requirement applies to the physical 
location of the Generating Facilities or to their respective POIs.122 
The Clean Energy Trades request that the Commission direct MISO to clarify that, for 
purposes of the same-LRZ requirement, the relevant location is the applicable POI to the MISO 
Transmission System rather than the physical location of the Generating Facility, including where 
multiple Generating Facilities serve a single LARS Associated Load. 
IV. 
CONCLUSION 
For the reasons stated above, the Clean Energy Trades respectfully request that the 
Commission reject MISO’s LARS proposal. In the event the Commission accepts any portion of 
the Filing, the Clean Energy Trades request that the Commission direct MISO to provide the 
clarification requested in Part III above. 
 
121  
Tab A, Attachment X, § 3.12.2; see also Transmittal Letter at 10. 
122  
Tab A, Attachment X, § 3.12.2 (multiple Generating Facilities provision, item 2(a)); see also Drake 
Testimony at 23, 30.

31 
Respectfully submitted, 
/s/ Brett White 
Brett White 
Vice President, Markets & Transmission 
American Clean Power Association 
1299 Pennsylvania Ave. N.W., Suite 1300 
Washington, D.C. 20004 
(771) 212-6069 
bwhite@cleanpower.org 
 
 
Simon Mahan 
Southern Renewable Energy Association 
11610 Pleasant Ridge Road, Suite 103 #176 
Little Rock, AR 72223 
(337) 303-3723 
simon@southernwind.org 
 
Abby Sherman 
Manager, Electricity Markets 
American Clean Power Association 
1299 Pennsylvania Ave. N.W., Suite 1300 
Washington, D.C. 20004 
(202) 255-4063 
asherman@cleanpower.org 
 
Whit Cox 
Southern Renewable Energy Association 
11610 Pleasant Ridge Road, Suite 103 # 176 
Little Rock, AR 72223 
(501) 701-0874  
whit@southernrenewable.org

32 
CERTIFICATE OF SERVICE 
The undersigned certifies that a copy of this pleading has been served this day upon each 
person designated on the official service list compiled by the Secretary in this proceeding. 
Dated this 23rd day of October, 2026. 
/s/ Brett White 
Brett White 
Vice President, Markets & Transmission 
American Clean Power Association 
1299 Pennsylvania Ave. N.W., Suite 1300 
Washington, D.C. 20004 
(771) 212-6069 
bwhite@cleanpower.org