ER27-25-000 · 2026-10-23 · SEIA and Advanced Energy United

Protest of the Solar Energy Industries Association and Advanced Energy United

Read topic-matched comments in ER27-25

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

What the document says

PDF p. 10

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

Under the proposal, LARS and DPP requests will be studied separately and using different assumptions. PDF p. 10
Filed comments: Connecting load and generation

PDF p. 11

Queued generators say overallocation raises their upgrade costs and curtails their output.

The filing does not adequately explain how MISO will coordinate transmission-capability assumptions across parallel interconnection processes. PDF p. 11

PDF p. 1

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

MISO proposes to effectively grant the Transmission Customer, which has an incentive to discriminate against competitive generation, the ability to discriminate against competitive generation. PDF p. 1

PDF p. 2

SEIA and United: reject LARS and let any qualified party file; or require nondiscriminatory handling.

reject the LARS proposal, on the grounds that the proposal is unduly discriminatory, and provide guidance to MISO to refile the proposal with a mechanism that would allow any qualified market participant PDF p. 2
Filed comments: Connecting load and generation

PDF p. 13

SEIA and United: reject LARS and let any qualified party file; or require nondiscriminatory handling.

the Commission should clarify that once an applicant meets all applicable LARS eligibility, readiness, financial security, and application requirements, the Commission expects the LARS Associated Transmission Customer to apply the same submission standards PDF p. 13
Filed comments: Connecting load and generation

PDF p. 8

If the paired load leaves, the generator faces a one-year bridge into a backlogged queue.

The proposed transition mechanism is woefully inadequate to address this stranded asset risk. PDF p. 8

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

ER27-25-000 PROTEST OF THE SOLAR ENERGY INDUSTRIES ASSOCIATION AND ADVANCED ENERGY UNITED Pursuant to Rule 211 of the Federal Energy Regulatory Commission’s (Commission) Rules of Practice and Procedure,1 the Solar Energy Industries Association (SEIA)2 and Advanced Energy United (United)3 submit…
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I. Protest

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I.
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A. The LARS Proposal is unduly discriminatory because it allows LSEs to decide if their competitors may participate in the LARS process.

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MISO’s filing is part of its efforts to comply with the Commission’s June 18, 2026, Show Cause Order.7 As relevant here, the Show Cause Order found that MISO’s tariff may be unjust and unreasonable because it does not contain provisions allowing an interconnection customer to seek interconnection…
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B. The LARS proposal is unjust and unreasonable because it conditions

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The LARS proposal is unjust and unreasonable because it conditions generators’ interconnection rights on specific large loads while risking double- counted transmission headroom, harm to earlier-queued projects, and improper cost shifts.
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i. LARS makes a generator’s rights depend on a specific large load, exposing viable projects to operational and financial uncertainty if that load departs.

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Under the LARS Proposal, a generator’s eligibility for LARS Interconnection Service is tied to the continued existence of a specific associated large load for a substantial portion of the generator’s operating life.28 LARS provides off-ramps when an associated load departs.29 If the LARS Associated…
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ii. MISO has not demonstrated how transmission capability will be transparently managed across parallel LARS and DPP study processes to protect earlier-queued projects from double-counted headroom, cost shifts, and diminished available capability.

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While MISO states that protecting the DPP process was an express consideration during development of the proposal,39 there is limited detail regarding how transmission capability assumptions will be coordinated between LARS and DPP studies or how potential conflicts will be identified and resolved…
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III. Alternative Recommendation

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III.
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A. Alternatively, the Commission should clarify that the LARS application process must be administered on a nondiscriminatory basis.

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Alternatively, the Commission should clarify that the LARS application process must be administered on a nondiscriminatory basis.
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IV. Conclusion

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IV.
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CONCLUSION

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In a region such as MISO’s where many utilities are vertically integrated, that role grants these initiated by the LARS Associated Transmission Customer, the Interconnection Customer, Transmission Owner, and LARS Associated Transmission Customer must all complete the required information as part of…
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CERTIFICATE OF SERVICE

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Dated at Washington, DC, this 23rd day of October, 2026. /s/ Caitlin Marquis Caitlin Marquis
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