{"document":{"slug":"protest-er27-25-consumer-advocates","title":"Joint Protest of the Iowa Office of the Consumer Advocate, the Citizens Utility Boards of Michigan, Illinois, Wisconsin and Minnesota, Citizens Action Coalition of Indiana, the Michigan and Illinois Attorneys General, and the Minnesota Department of Commerce","issued":"2026-10-23","accession":"20261023-5197","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"Iowa OCA and 8 consumer advocates","kind":"protest","file":"sources/originals/20261023-5197_Consumer Advocate AG Joint Protest.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261023-5197","sha256":"e20ebc271540db782c81e479ad96ae49969673777f4abeba7c463c5921fe2621","pages":14,"tokens":3961,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":190,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \n \n \n) \nMidcontinent Independent System \n) \n \nDocket ER27-25-000 \n      Operator, Inc. \n) \n \n \n \n \n) \n \n \n \nJOINT PROTEST OF  \nTHE IOWA OFFICE OF THE CONSUMER ADVOCATE, \nTHE CITIZENS UTILITY BOARD OF MICHIGAN,  \nTHE CITIZENS UTILITY BOARD OF ILLINOIS,  \nTHE CITIZENS UTILITY BOARD OF WISCONSIN, \nTHE CITIZENS UTILITY BOARD OF MINNESOTA \nCITIZENS ACTION COALITION OF INDIANA,  \nMICHIGAN ATTORNEY GENERAL,  \nTHE OFFICE OF THE ILLINOIS ATTORNEY GENERAL, AND  \nMINNESOTA DEPARTMENT OF COMMERCE \n \n \n \nPursuant to Rule 211 the Federal Energy Regulatory Commission’s (“Commission”) \nRules of Practice and Procedure, 18 C.F.R. section 385.211 and the August 31, 2026 Combined \nNotice of Filings #1, the Iowa Office of Consumer Advocate, Citizens Utility Board of \nMichigan, Citizens Utility Board of Illinois, Citizens Utility Board of Wisconsin, Citizens Utility \nBoard of Minnesota, Citizens Action Coalition of Indiana, the Michigan Attorney General, the \nOffice of the Illinois Attorney General, and Minnesota Department of Commerce (collectively, \nthe “Joint Protestors”) respectfully submit this Joint Protest in the above-captioned proceeding.   \nJOINT PROTEST \n \n \nThe Joint Protestors submit this Joint Protest regarding the proposed tariff revisions filed \nby the Midcontinent Independent System Operator, Inc. (“MISO”) regarding the Large Load"},{"page":2,"startToken":190,"endToken":515,"text":"2 \nAdditional Resource Study Process (“LARS Process”) with the Commission in the above-\ncaptioned action.1   \n \nOn October 2, 2026, MISO filed proposed revisions to its Open Access Transmission, \nEnergy, and Operating Reserve Markets Tariff (“Tariff”) to establish a LARS Process with \nsupporting direct testimony prepared by Christina Drake, MISO Director, Generation \nInterconnection.  In the Transmittal Letter, MISO asserts the filing is responsive to the \nCommission’s concerns in its Show Cause Order in Docket No. EL26-70-000, including the \nfinding MISO’s existing Tariff may be unjust and unreasonable because it does not provide \ngenerator interconnection study procedures and services that account for the operational \ndynamics of serving electrically proximate large loads.2   \n \nIn the Show Cause Order, the Commission found MISO’s Tariff “appears to be unjust and \nunreasonable because it lacks adequate mechanisms to mitigate the risk of cost shifting among \ntransmission customers, which may result in unjust and unreasonable rates for transmission \nservice.”3  In the ruling, the Commission expressed concern about the lack of transparency \nregarding the assignment of costs, including Network Upgrades, necessary to provide \ntransmission service to Eligible Customers or Large Load Customers on behalf of Large Loads. \nThe Commission sought to ensure Eligible Customers bear the risk and are ultimately \nresponsible for costs incurred to provide transmission service, including the cost of Network \nUpgrades.4   \n \n1  In the Show Cause Order discussed below, the Commission expressly “encourage[d] . . . state consumer advocates \nto submit comments explaining whether this information is sufficient and granular enough or to submit comments \nexplaining precisely which additional information on transmission cost allocation may be needed to inform proper \nstate-jurisdictional cost allocation.”  Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 at P 70 (2026) \n(“Show Cause Order”). \n2  Transmittal Letter at 3. The definition of electrically proximate large loads is in the Show Cause Order and set \nforth in this Protest, below. See footnote 23. \n3  Show Cause Order at P 66.   \n4  Id. at PP 70-77."},{"page":3,"startToken":515,"endToken":831,"text":"3 \nI. \nThe Commission Should Not Allow the Grandfathering of Approximately 30 \nGigawatts of Load   \n \nMISO is proposing to fully exempt or “grandfather” any Large Load with a service \ncommencement date on or prior to December 4, 2026, from all requirements of proposed Section \n37A, or more generally, the Large Load Interconnection Reliability Requirements.5  MISO is \nalso proposing to partially exempt a Large Load or a portion of a Large Load that does not have a \nService Commencement Date prior to December 4, 2026, but that meets the MTEP/EPR \nCondition and the ramp and ride-through requirements set forth in Section 37A.6 through \n37A.7.6  In total, MISO is proposing to fully or partially exempt approximately 30 gigawatts of \nexisting load from the Large Load Interconnection Reliability Requirements.7  The Joint \nProtestors filed a Protest in Docket No. ER26-3650-000 on September 18, 2026, protesting \nMISO’s proposed grandfathering exemptions.8  The Joint Protestors maintain the proposed \ngrandfathering exemptions under MISO’s Section 205 filings, including the LARS Process, are \nnot just and reasonable.  If the grandfathering exemptions are carried forward in this filing and to \nthe series of future Federal Power Act Section 205 filings MISO intends to make in response to \nthe Show Cause Order, the exemptions could deprive electric consumers of the cost-shifting and \nother consumer protections MISO has been directed to address in the Show Cause Order.  \n \n \n5  Midcontinent Indep. Sys. Operator, Inc., Interconnection of Reliability Requirements for Large Loads, Docket No. \nER26-3650 at 13- 14 (Aug. 28, 2026).   \n6  Id. \n7  Midcontinent Indep. Sys. Operator, Large Load Working Group, Large Load Interconnection Reliability \nRequirements (LLWG) at 8 (Aug. 12, 2026), https://www.misoenergy.org/events/2026/large-load-working-group-\nllwg---august-12-2026/ (last visited on Sept. 16, 2026). \n8  Joint Protest of the Iowa Office of Consumer Advocate et al., Midcontinent Indep. Sys. Operator, Inc., Docket No. \nER26-3650-000 at 3 (filed Sept. 18, 2026)."},{"page":4,"startToken":831,"endToken":1206,"text":"4 \nII. \nCost-Shifting Should be Addressed Across MISO’s Section 205 Filings and in the \nSection 206 Filing \n \n \nMISO’s LARS Process does not address the Commission’s concerns regarding cost-\nshifting expressed in the Show Cause Order.  In her direct testimony, MISO Witness Drake notes \n“[t]he cost shifting issues raised in the Commission’s Show Cause Order will be addressed in \nfuture filings that MISO plans to submit by November 16.”9  The Commission’s concerns \nregarding cost-shifting are an integral part of the Show-Cause Order.  If the Commission \napproves MISO’s proposed Tariff changes in MISO’s Section 205 filings without considering \ncost-shifting and the collective impact of all of MISO’s Section 205 filings as a whole, electric \ncustomers may be deprived of the cost-shifting and other consumer protections the Commission \ndirected MISO to address in the Show Cause Order.  The Commission should require MISO to \naddress cost-shifting in all of its Section 205 filings and in all of its direct responses to the \nSection 206 Show Cause Order.  The Joint Protestors should be permitted to address the cost-\nshifting impacts, transparency issues, and other consumer protection issues raised in MISO’s \nSection 205 filings as a whole, collectively, in the Section 206 Show Cause Docket.10 \n \n \n9  Tab C. MISO Witness Drake Direct Testimony at 41:7-8.   \n10 Consumer advocates have demonstrated a need for their offices to have a more meaningful, active, and visible role \nin MISO.  See Docket No. AD25-7, Statement of Jennifer Easler on behalf of Iowa OCA at 7 (May 16, 2025); see \nalso id. at 7-8 (urging “the Commission to consider changes to give Consumer Advocates a stronger voice at MISO \nand its planning process so the interests of those who pay the bills are heard.”).  MISO’s failure to address the cost-\nimpact components of the Show Cause Order serves as  an acute example that corroborates that need.  In a future \nsubmission, Joint Protestors may  ask FERC to take action under Section 206 to address that need by (i) finding that \nthe lack of funding provisions for consumer advocate offices renders MISO’s Tariff unjust and unreasonable and \nunduly discriminatory, and (ii) establishing a mechanism in MISO’s Tariff to fund a consumer advocate organization \n(similar to the CAPS organization in PJM Interconnection, L.L.C.)."},{"page":5,"startToken":1206,"endToken":1604,"text":"5 \nIII. \nThe LARS Process Lacks Transparency on Costs and Allows Cost-Shifting of \nNetwork Upgrades \n \n \nMISO proposes to add a new GIP Section 3.12.4 to describe the studies that will take \nplace for LARS generation projects.11  With respect to mitigations or network upgrades to \naddress violations observed during the studies, MISO proposes the following language: \nMitigations developed to address violations observed in only the transmission \nstudies shall be assigned Baseline Reliability Projects (BRP) or Other project \ntypes.  Mitigations developed to address common violations observed in both the \ntransmission study and the generation study shall be assigned Baseline Reliability \nProjects (BRP) or Other project types.  Mitigations developed to address \nviolations observed only in the generation study shall be assigned to the LARS \nInterconnection Customer under the Generator Interconnection Project (GIP) \nproject type.12 \n \nIn the Transmittal Letter, MISO explains the above language: \naddresses how mitigations developed to address violations will be assigned \ndepending on where they were observed.  If they were only observed in the load \nside study of LARS, then they will be assigned BRPs and Other project types.  If \nmitigations were developed to address violations observed in both the generation \nand load studies, then they will be assigned BRPs and Other project types.  And \nfinally, any mitigations developed to address violations observed that were caused \nonly in the generation study will be assigned to the Interconnection Customer \nunder the Generator Interconnection Project (“GIP”) project type.13 \n \nIn her direct testimony, MISO Witness Drake further explains the proposed Tariff change: \nQ. \nBECAUSE LARS INVOLVES GENERATION/LOAD PAIRS, HOW \nARE VIOLATIONS AND THEIR ASSOCIATED MITIGATION \nCOSTS ASSIGNED? \n \nA. \nThe generator will be responsible for any constraints unique to the \ngeneration study and the load will be responsible for any constraints \nunique to the load study.  In the event there is an overlap in violations, \nthen the costs will be assigned to the load.  Thus, projects developed to \nmitigate violations observed only in the LARS generator study will be \nassigned to the LARS Interconnection Customer under the Generator \nInterconnection Project (depicted as GIP below) project type.  In the event \nthat any Planning Criteria violations, such as thermal or voltage overloads, \n \n11  Transmittal Letter at 31-32; Tab A, ATTACHMENT X, Generator Interconnection Procedures (GIP) 193.0.0. \n12  Transmittal Letter at 31-32; Tab A, ATTACHMENT X, Generator Interconnection Procedures (GIP) 193.0.0. \n13  Transmittal Letter at 32."},{"page":6,"startToken":1604,"endToken":1837,"text":"6 \nare observed during the load-side study process including any common \nviolations identified between the generation and load studies, mitigations \nwill be developed and assigned BRP or Other project types as defined in \nAttachment FF. \n \n \n \n \n \nAs the diagram demonstrates above, in the event that there is a common \nissue between the load and generation, then the cost will be allocated for \nthe BRP or Other project type.  If a GIP defers or displaces a BRP, then the \ncosts of the GIP up to the costs of the deferred or displaced BRP shall be \nallocated consistent with the cost allocation for the BRP.14 \n \n \nThe LARS Process does not assign the cost of all network upgrades to the cost-causer.  \nThe LARS Process assigns the Interconnection Customer, the cost-causer, the cost of network \nupgrades to address violations observed in the generation study under the GIP project type.  \nUnlike the violations observed only in the generation study, the LARS Process assigns the cost of \nnetwork upgrades to address violations observed in the transmission studies and observed in both \nthe transmission study and the generation study to Baseline Reliability (“BRP”) or Other project \ntypes, which are allocated zonally.  The LARS proposal does not adequately assign costs to the \ncost causers, and MISO has not yet fully developed a cost allocation proposal for LARS load and \n \n14  Tab C, MISO Witness Drake Direct Testimony at 27:14-28:7."},{"page":7,"startToken":1837,"endToken":2174,"text":"7 \ngeneration pairs. MISO indicates in its Transmittal Letter that any overallocation of upgrade \ncosts will be “formalized in a future MTEP project,” and will likely be allocated zonally across \nMISO’s Transmission Pricing Zone.15 This does not address whether costs are properly allocated \nto large loads. MISO’s Tariff does not contain a transparent, cost-causation tracking framework \nto track the cost of the network upgrades, allowing the cost of the network upgrades to shift from \ndirect assignment to the cost-causer to other ratepayers under zonal rates.  Consistent with the \nShow Cause Order, the cost-causer, not other ratepayers, should be responsible for all network \nupgrades resulting from the Large Load. Proposals that allocate Large Load network upgrade \ncosts to other customers zonally under the premise of the alleged benefits those customers \nreceive are therefore irrelevant.   \nIV.  \nThe LARS Process Fails to Address the Commission’s Show Cause Order’s \nRequirement to be “Electrically Proximate” \n \nMISO proposes LARS as load and generation pairs, interconnecting within the same \nLocal Resource Zone (LRZ).16 MISO LRZ’s are physically large, with LRZ 1 spanning from \nMontana to Illinois.17  In the Transmittal Letter, MISO explains that they chose the load and \ngeneration interconnection pair threshold at the LRZ to align with MISO’s Resource Adequacy \nconstruct.18 MISO Witness Christina Drake further details the choice around LRZ: \nQ.  \nHOW DOES LARS ADDRESS THE ELECTRICALLY \nPROXIMATE REQUIREMENT IN THE SHOW CAUSE ORDER?  \n \nA.  \nMISO’s LARS proposal provides the Tariff structure necessary to enable \nan Interconnection Customer to serve an electrically proximate load as the \nLARS Associated Load must be located within the same LRZ.  MISO did \nnot want to limit the pairing of generation with associated load to a \n \n15 Transmittal Letter at 13. \n16 Transmittal Letter at 10. \n17 Midcontinent Indep. Sys. Operator, FERC Electric Tariff, Attachment VV, Map of Local Resource Zone \nBoundaries (40.0.0) at 1 (effective Oct. 26, 2025), https://www.misoenergy.org/legal/tariff/ (last visited on Oct. 18, \n2026). \n18 Tab C. MISO Witness Drake Direct Testimony at 40."},{"page":8,"startToken":2174,"endToken":2550,"text":"8 \nspecific number of substations because that would limit how MISO may \noptimize common solutions.19 \n \nMISO discusses how it could have structured its LARS proposal, by either “requiring the \ngeneration and LARS Associated Load to be located in the same Local Balancing Authority area \nor through requiring that the location of the Generating Facilities be within a specific number of \nsubstations of the LARS Associated Load.”20 MISO indicates that it chose neither of these \nstructures, favoring LRZ as a boundary, due to its existing relationship with the Resource \nAdequacy metric, as well as “avoiding capacity import/capacity export limitations for the \nindividual LRZ,” and avoiding “price separation between the paired generation and LARS \nAssociated Load.”21 \n \nThe Commission indicated preference for faster interconnection between large load and \nassociated generation facilities in the Large Load ANOPR, as well as in the Commission’s Show \nCause Order. The Commission’s Show Cause Order considers the benefits of studying new load \nand new generation together. Physical proximity between new load and new generation “when \nphysically or electrically proximate, present system benefits and can help address the challenges \nposed by large load.\"22 The Commission’s Show Cause Order defines “electrically proximate \nlarge load” as “no more than two substations away from the generating facility” to govern the \nelectrical distance in between related generation interconnection and large load.23 The \n \n19 Tab C MISO Witness Drake Direct Testimony at 10. \n20 Transmittal Letter at 10. \n21 Tab C MISO Witness Drake Direct Testimony at 40:15-16, Transmittal Letter at 22. \n22 Show Cause Order at P 106. \n23 “[T]he term “electrically proximate large load” to mean a large load, as defined in this order,  that is sufficiently \nelectrically close to the interconnection customer’s requested point of interconnection, such that the impact on the \ntransmission system of the combination of the generating facility and the load, with the exception of the \ntransmission facilities between the two, will be effectively the same as if they were located at the same substation \n(e.g., large load that is located no more than two substations away from the generating facility).  We will consider \nproposed revisions to this definition that ensure it is appropriately tailored to MISO’s transmission system.” Show \nCause Order at P 112."},{"page":9,"startToken":2550,"endToken":2834,"text":"9 \nCommission established this definition because electrical efficiencies created by narrow co-\nlocation of generation interconnection and new large load customers would harmonize siting of \nload and generation and minimize the need for Network Upgrades. 24 \n \nMISO does not accomplish optimizing solutions between a LARS Associated Load and \nan Interconnection Customer’s generation facility in accordance with the Commission’s guidance \nin the Show Cause Order. Instead of proposing a compatible definition of “electrically \nproximate,” MISO eschewed the lower network upgrade cost benefits of defining new large load \nand generation facilities in a constrained area in favor of the LRZ boundary for the LARS \nproposal. \nNeither MISO Witness Drake nor the Transmittal Letter explain how the LARS proposal \nmitigates the electrical impact of LARS Associated Load and generation facilities being spaced \npotentially hundreds of miles apart, with load and generation being linked, despite being located \npotentially many states away. Furthering the logical challenge presented by MISO’s use of LRZ \nas a boundary, MISO has Zones that range in size from LRZ 1, which spans from eastern \nMontana to northwest Illinois, to LRZ 5 which comprises less than half of the state of Missouri. \nMISO’s LRZ proposal does not meaningfully engage with the Show Cause Order. MISO neither \nevaluates whether its LRZ boundaries are appropriate under the Order’s terms nor supports its \nconclusion that they are. \nThe Joint Protestors respectfully urge the Commission to require MISO to establish a \nreasonable distance of “electrically proximate” that fully considers the factors laid out in the \nCommission’s Show Cause Order. For example, MISO could allow for project-specific \nsubstations to not count against the “no more than two substations” count, such that a step-up \n \n24 Show Cause Order at P 113."},{"page":10,"startToken":2834,"endToken":3128,"text":"10 \nsubstation to transmission voltage and a step-down to distribution voltage are not part of the \nelectrical distance or electrical impact.25 However, as the proposal stands, MISO’s LARS filing \nappears to be a departure from the defined electrical distance contemplated in the Show Cause \nOrder.  \nV.  \nMISO Fails to Explain How LARS is Not a Queue-Jumping Proposal \n \nThe Joint Protestors also take issue with MISO’s classification of the LARS proposal and \nits intent to build off the success of the Expedited Resource Addition Study (“ERAS”) and the \nZero-Injection Generator Interconnection Agreement (“ZGIA”) process, the latter of which is \nstill pending at the Commission. The ERAS pathway allowed Generator Interconnection \ncustomers who have approval from their Retail Electric Rate Regulatory Authority (“RERRA”) \nto seek an expedited pathway to a Generator Interconnection Agreement (“GIA”), circumventing \nthe traditional DPP queue. The Joint Protestors are concerned that LARS, similar to ERAS, will \nenable queue jumping. MISO Witness Drake indicates that “MISO understands the concerns that \nLARS is enabling queue jumping,” but does not believe that the LARS proposal contemplates \nqueue jumping and maintains a size cap that prevents misuse of the process.26  \nMISO Witness Drake discusses the likely success of the LARS process from a planning \nstandpoint, and how there could be strategic efficiencies between generator interconnection and \nload interconnection processes, “If MISO can identify a common solution that \nhelps integrate both the load and generation into the system, then MISO can maximize the \nbenefits of both processes and reduce integration costs.”27 The LARS study process only \nevaluates generator projects with executed GIAs. Any projects currently moving through the \n \n25 Show Cause Order at 67. \n26 Tab C, MISO Witness Drake Direct Testimony at 10. \n27 Tab C, MISO Witness Drake Direct Testimony at 6."},{"page":11,"startToken":3128,"endToken":3433,"text":"11 \nDPP Cycle will not be modeled into the LARS study models.28 In effect, any LARS project will \nbe studied before the DPP projects that have waited through multiple phases of study. The \nomission of DPP projects combined with an electrically proximate definition that can be up to \nnearly a thousand miles creates a process that enables queue jumping for LARS Associated \nGenerators.  \nMISO’s testimony supposes that queue jumping only becomes a problem when the \njumping is unrestricted and constant. Under FPA Section 205, MISO bears the burden of proof \nthat LARS is just and reasonable, and not unduly preferential. MISO has not adequately \nexplained how LARS generation projects are not receiving undue preference over other \ngeneration projects in the DPP cycles ahead of them. The Show Cause Order explicitly asks \nMISO to show, in their FPA Section 205 filing, how they will “avoid disrupting existing \ncommercial arrangements.”29 MISO has not shown how the LARS filing will avoid such \ndisruptions to the existing DPP queue, and will avoid being unjust and unreasonable, or unduly \ndiscriminatory to Generator Interconnection Customers currently in the queue. \nCONCLUSION \nWHEREFORE, the Joint Protestors pray the Commission reject MISO’s proposed Tariff \ngrandfathering exemptions to ensure Large Load customers bear the cost and risk of all costs \ncaused by the Large Load customer, direct MISO to address cost-shifting in its Section 205 \nfilings and in its direct response to the Section 206 filing, allow the Joint Protestors to address \nthe cost-shifting impacts, transparency issues, and other consumer protection issues raised in \nMISO’s Section 205 filings as a whole, collectively, in the Section 206 Show Cause Docket, \nreject MISO’s proposed Tariff provisions under GIP Section 3.12.4 that shift the cost of network \n \n28 Tab C, MISO Witness Drake Direct Testimony at 28. \n29 Show Cause Order at P 36."},{"page":12,"startToken":3433,"endToken":3725,"text":"12 \nupgrades to address violations observed in the transmission studies and observed in both the \ntransmission study and the generation study to Baseline Reliability or Other project types, reject \nMISO’s LARS definition for “electrically proximate” to mean across an LRZ, reject MISO’s \nprovisions that allow queue jumping around the standard DPP process, and require MISO to \nensure Large Load customers bear the cost and risk of all costs caused by the Large Load \ncustomer, and for any additional relief Commission deems appropriate under the circumstances. \n \n \n \n \nRespectfully submitted, \n \n/s/ Anthony A. Alvarez \n \nAnthony A. Alvarez \nUtilities Regulation Engineer 2 \nIowa Attorney General \nOffice of the Consumer Advocate \n1375 East Court Avenue \nDes Moines, IA  50319 \nAnthony.Alvarez@oca.iowa.gov\n/s/ Jennifer C. Easler \n \nJennifer C. Easler \nAttorney \nIowa Attorney General \nOffice of the Consumer Advocate \n1375 East Court Avenue \nDes Moines, IA  50319 \njennifer.easler@oca.iowa.gov\n \nFor the Iowa Office of the Consumer Advocate\n/s/ Sydnie Lieb   \n \nSydnie Lieb   \nAssistant Commissioner of Regulatory \n  Affairs, Energy Resources Division  \nMinnesota Department of Commerce \n85 7th Place East, Suite 280 \nSaint Paul, MN  55101   \nSydnie.Lieb@state.mn.us \n \nFor the Minnesota Department of Commerce \n \n/s/ Sarah Moskowitz \n \nSarah Moskowitz \n \nExecutive Director \nCitizens Utility Board of Illinois \n309 W. Washington Street \nSuite 800 \nChicago, IL 60606 \nsmoskowitz@citizensutilityboard.org \n \nFor the Citizens Utility Board of Illinois\n/s/ John Liskey \n \nJohn Liskey \nGeneral Counsel \nCitizens Utility Board of Michigan \n921 N. Washington Ave \nLansing, MI 48906 \n(517) 913-5105 \nJohn.liskey@cubofmichigan.org \n \nFor Citizens Utility Board of Michigan \n \n/s/ Jennifer A. Washburn \n \nJennifer A. Washburn \nRegulatory Director \nCitizens Action Coalition of Indiana, Inc. \n1915 W. 18th Street, Suite C \nIndianapolis, IN 46202 \n(317) 735-7764 \njwashburn@citact.org \n \nFor Citizens Action Coalition of Indiana, Inc."},{"page":13,"startToken":3725,"endToken":3893,"text":"13 \n/s/ Daniel Narvey \n \nDaniel Narvey \nGeneral Counsel \n625 North Segoe Rd. Suite 101 \nMadison, WI 53705 \n(608) 251-3322 \nnarvey@cubwi.org \n \nFor the Citizens Utility Board of Wisconsin \n \n/s/ Michael E.  Moody \n \nMichael E.  Moody \n \nSpecial Litigation Division Chief \nAssistant Attorney General \nMichigan Department of Attorney General \nP.O. Box 30212 \nLansing, MI 48909 \nMoodym2@michigan.gov      \n \nFor the Michigan Attorney General \n \n/s/ Brandon Crawford \n \nBrandon Crawford \n \nRegulatory Advocate \nCitizens Utility Board of Minnesota \n332 Minnesota St., Suite W1360 \nSaint Paul, MN 55101 \nbrandonc@cubminnesota.org  \n \nFor the Citizens Utility Board of Minnesota \n/s/ Corey Singletary \n \nCorey Singletary \nDirector of Regulatory Affairs \n625 North Segoe Rd. Suite 101 \nMadison, WI 53705 \n(608) 251-3322 \nsingletary@cubwi.org \n \nFor the Citizens Utility Board of Wisconsin \n \n/s/ Samuel C. Lukens \n \nSamuel C. Lukens \nAssistant Attorney General \nPublic Utilities Bureau \nOffice of the Illinois Attorney General  \n115 South LaSalle Street, 25th Floor \nChicago, IL 60603 \nsamuel.lukens@ilag.gov \n \nFor the Office of the Illinois Attorney General \n \nDated: October 23, 2026"},{"page":14,"startToken":3893,"endToken":3961,"text":"CERTIFICATE OF SERVICE \n \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \n \n \nDated at this 23rd day of October, 2026. \n \n \n/s/ Jennifer C. Easler \n \n \n \nJennifer C. Easler \n \nAttorney \n \nOffice of Consumer Advocate of Iowa \n \n1375 East Court Avenue \n \nDes Moines, IA 50319-0063 \n \n(515) 725-7224 \n \njennifer.easler@oca.iowa.gov"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":4,"endAt":3,"startToken":0,"endToken":832},{"p":4,"at":3,"title":"II. Cost-Shifting Should be Addressed Across MISO’s Section 205 Filings and in the","method":"printed heading","endPage":5,"endAt":3,"startToken":832,"endToken":1207},{"p":5,"at":3,"title":"III. The LARS Process Lacks Transparency on Costs and Allows Cost-Shifting of","method":"printed heading","endPage":5,"endAt":1850,"startToken":1207,"endToken":1475},{"p":5,"at":1850,"title":"A. The generator will be responsible for any constraints unique to the","method":"printed heading","endPage":7,"endAt":904,"startToken":1475,"endToken":1971},{"p":7,"at":904,"title":"IV. The LARS Process Fails to Address the Commission’s Show Cause Order’s","method":"printed heading","endPage":7,"endAt":1563,"startToken":1971,"endToken":2070},{"p":7,"at":1563,"title":"A. MISO’s LARS proposal provides the Tariff structure necessary to enable","method":"printed heading","endPage":10,"endAt":301,"startToken":2070,"endToken":2880},{"p":10,"at":301,"title":"V. MISO Fails to Explain How LARS is Not a Queue-Jumping Proposal","method":"printed heading","endPage":11,"endAt":1172,"startToken":2880,"endToken":3313},{"p":11,"at":1172,"title":"CONCLUSION","method":"printed heading","endPage":14,"endAt":0,"startToken":3313,"endToken":3893},{"p":14,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":14,"endAt":455,"startToken":3893,"endToken":3961}]}