ER27-25-000 · 2026-10-23 · Google

Limited Protest of Google LLC

Read topic-matched comments in ER27-25

Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment

What the document says

PDF p. 2

LARS puts upgrade costs of load-caused violations on zonal ratepayers instead of the pair.

Under current rules, the costs of those project types are recovered from all network customers in a Transmission Pricing Zone. PDF p. 2

PDF p. 8

FERC cannot find LARS just and reasonable without MISO's unfiled cost-shifting agreement.

the Commission cannot determine that LARS is just and reasonable because the record lacks such a key piece of the puzzle. PDF p. 8
Filed comments: Connecting load and generation

PDF p. 3

Google: reject LARS with guidance, or accept and suspend it until the cost agreement arrives.

the Commission should either reject LARS with guidance indicating that it needs to be filed concurrently with procedures to prevent cross-subsidization or, in the alternative, accept and suspend the proposal PDF p. 3
Filed comments: Connecting load and generation

PDF p. 2

Google: reject LARS with guidance, or accept and suspend it until the cost agreement arrives.

Google supports the intent and conceptual direction of LARS. PDF p. 2
Filed comments: Connecting load and generation

PDF p. 6

LARS and the queue use different assumptions, so both can claim the same headroom.

each process is based on an incomplete snapshot of the transmission system and how it will operate in practice, which increases the likelihood that the LARS and DPP processes will produce incompatible results. PDF p. 6
Filed comments: Connecting load and generation

PDF p. 7

Google would model advanced-stage queue projects in LARS so large loads absorb study error.

LARS could be modified to use more conservative assumptions PDF p. 7
Filed comments: Connecting load and generation

PDF p. 9

Utility gatekeeping of LARS applications is undue discrimination against independent generators.

making load-serving entities ("LSEs") the gatekeepers of the LARS process PDF p. 9
Filed comments: Connecting load and generation

PDF p. 9

Google wants independent generators to have direct access, with FERC resolving disputes with the utility.

protections providing that all forms of generation, including independent generation, have nondiscriminatory, direct access to the expedited generation interconnection study process under LARS. PDF p. 9
Filed comments: Connecting load and generation

Responses and related views

MISO says independent generators can negotiate before applying

Midcontinent Independent System Operator · Direct response

MISO said the transmission customer submits an application for an already matched pair. It argued that an independent generator remains free to bring a proposal to that customer before the application, and that the eligibility rules are nondiscretionary.

PDF pp. 20–22

Source sections

Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.

Opening text

opening text · Topic match: Connecting load and generation

In addition, MISO must also continue to refine and improve its principal interconnection process, the Definitive Planning Phase (“DPP”), so that all generation resources in MISO—not 8 Id. at 14. -4- just those paired with large loads—can interconnect on a reasonable timeline.
Read this passage Filed comments: Connecting load and generation

A. The LARS Proposal Opens the Door to Shifting the Costs of Serving LARS Pairs onto Other Customers and Future MTEP Cycles

PDF bookmark · Topic match: Connecting load and generation

That is particularly so given that LARS’s design creates the very real risk of overallocation because ongoing DPP cycles do not include LARS requests and the LARS studies do not include DPP projects before they have signed Generator Interconnection Agreements.19 As a result, each process is based…
Read this passage Filed comments: Connecting load and generation

B. Without the Pro Forma Cost Shifting Agreement, the Commission Cannot Find LARS Just and Reasonable

PDF bookmark · Topic match: Connecting load and generation

It could reject the LARS proposal outright with direction to MISO that if it refiles LARS it must contain adequate protections against cost shifting, including any pro forma agreement.
Read this passage Filed comments: Connecting load and generation

C. LARS Opens the Door to Undue Discrimination

PDF bookmark · Topic match: Connecting load and generation

Under MISO’s proposal, LARS applications must be submitted through a designated LARS Associated Transmission Customer, which MISO indicates is typically the LSE.
Read this passage Filed comments: Connecting load and generation

CERTIFICATE OF SERVICE

printed heading

Dated: October 23, 2026 Washington, D.C. /s/ Bryan Shpall Bryan Shpall Wilson Sonsini Goodrich & Rosati 1700 K Street NW Fifth Floor Washington, DC 20006
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