{"document":{"slug":"protest-er27-25-seia-united","title":"Protest of the Solar Energy Industries Association and Advanced Energy United","issued":"2026-10-23","accession":"20261023-5181","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"SEIA and Advanced Energy United","kind":"protest","file":"sources/originals/20261023-5181_ER27-25 - SEIA and United protest.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261023-5181","sha256":"704992d7f5fc029414e5b57783dfb4e11963b8368a37655dbd378bf08a81e59e","pages":16,"tokens":4337,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":386,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nMidcontinent Independent System Operator, \nInc. \n) \n) \n) \n \nDocket No. ER27-25-000 \n \nPROTEST OF THE SOLAR ENERGY INDUSTRIES ASSOCIATION  \nAND ADVANCED ENERGY UNITED \n \nPursuant to Rule 211 of the Federal Energy Regulatory Commission’s (Commission) \nRules of Practice and Procedure,1 the Solar Energy Industries Association (SEIA)2 and \nAdvanced Energy United (United)3 submit this protest of the Midcontinent Independent System \nOperator, Inc.’s (MISO) LARS filing.4  \nIn the LARS filing, MISO proposes a process that would study load and generation on a \ncoordinated basis. But to enter that process, a load and generation owner must be granted access \nby the Transmission Customer, which in MISO, is also often a vertically integrated Load Serving \nEntity (LSE) and Transmission Owner (TO).5 In this way, a Transmission Customer is also a \ndirect competitor to independent power producers in developing generation in MISO. MISO \nproposes to effectively grant the Transmission Customer, which has an incentive to discriminate \nagainst competitive generation, the ability to discriminate against competitive generation. By \n \n1 18 C.F.R. § 385.211 (2026). \n2 The comments contained in this filing represent the position of SEIA as a trade organization on behalf of the solar \nindustry, but do not necessarily reflect the views of any particular member with respect to any issue. \n3  Advanced Energy United is a national association of businesses that are making the energy we use secure, clean \nand affordable. Advanced Energy United is the only industry association in the United States that represents the full \nrange of advanced energy technologies and services, both grid-scale and distributed. Advanced energy includes \nenergy efficiency, demand response, energy storage, wind, solar, hydro, nuclear, electric vehicles, and more. The \ncomments expressed in this filing represent the position of Advanced Energy United but may not represent the views \nof any particular member with respect to any issue. \n4 Midcontinent Independent System Operator, Inc., LARS, Docket No. ER26-3813-000 (Sept. 21, 2026) (LARS \nProposal). \n5See Midcontinent Indep. Sys. Operator, Inc., 170 FERC ¶ 61,215, P 13 (2020) (“Notably, approximately 90% of the \nload in MISO is served by vertically integrated LSEs…”); see also Midcontinent Indep. Sys. Operator, Inc., 191 \nFERC ¶ 61,131, P 87 (2025) (ERAS 1.0 Order); and Midcontinent Indep. Sys. Operator, Inc., 189 FERC ¶ 61,159, \nPP 6, 27 (2024)."},{"page":2,"startToken":386,"endToken":655,"text":"2 \nvesting the Transmission Customer with the discretion to file the LARS application,6 MISO turns \nwhat could have been a just and reasonable process into one that is unjust, unreasonable, and \nunduly discriminatory.  \nMISO could have filed a proposal that worked for many stakeholders, rather than just a \nfew; MISO still can make such a proposal. SEIA and United respectfully request that the \nCommission reject the LARS proposal, on the grounds that the proposal is unduly \ndiscriminatory, and provide guidance to MISO to refile the proposal with a mechanism that \nwould allow any qualified market participant—including independent power producers, \ndevelopers, and load customers—to initiate a submission, provided the applicable readiness and \nsecuritization requirements are met. However, if the Commission accepts LARS, SEIA and \nUnited request that the Commission expressly clarify that the Associated Transmission \nCustomer’s exclusive application role must be executed in a nondiscriminatory manner. \n \nI. \nPROTEST \nA. The LARS Proposal is unduly discriminatory because it allows LSEs to \ndecide if their competitors may participate in the LARS process. \n \nMISO’s filing is part of its efforts to comply with the Commission’s June 18, 2026, Show \nCause Order.7 As relevant here, the Show Cause Order found that MISO’s tariff may be unjust \nand unreasonable because it does not contain provisions allowing an interconnection customer to \nseek interconnection service that reflects the operational dynamics of serving electrically \nproximate load.8 \n \n6 Transmittal at 6, 24. \n7 Transmittal at 3. \n8 Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,212 at P 113 (2026) (“Show Cause Order”)."},{"page":3,"startToken":655,"endToken":1008,"text":"3 \nUnder the LARS Proposal, MISO would study load and generation pairs in parallel, with \nboth study processes brought under a common application.9 To be eligible for LARS, an \nInterconnection Customer and the LARS Associated Load must provide an agreement \ndemonstrating that the output of the LARS Generating Facility will serve the LARS Associated \nLoad.10 This agreement, along with the other LARS requirements, would be part of the LARS \nApplication submitted by the LARS Associated Transmission Customer,11 which is the “entity \nthat procures Transmission Service for load and has a direct relationship with the load,” and \n“often a Load Serving Entity (“LSE”).”12 The LARS Associated Transmission Customer is the \nonly party that may initiate the LARS Application.13 \nAs MISO states, the LARS Associated Transmission Customer is often a Load Serving \nEntity,14 and in the MISO region, LSE are often vertically integrated utilities that have a \ngeneration affiliate and/or build their own generation.15 These entities have a competitive motive \nto discriminate in favor of their own facilities.16 Utility-owned generators are competing with \nindependent power producers for the ability to be the power procurement solution for new large \nloads in MISO. MISO’s proposed LARS creates a process wherein that competition to serve a \nnew LARS Associated Load is organized and refereed by one of the competitors – the \nTransmission Customer utility. The Transmission Customer is the utility party with an interest in \n \n9 Transmittal at 5. \n10 Transmittal at 9. \n11 Transmittal at 7. \n12 Transmittal at 6. \n13 Transmittal at 6. \n14 Transmittal at 6. \n15 See Midcontinent Indep. Sys. Operator, Inc., 170 FERC ¶ 61,215, P 13 (2020) (“Notably, approximately 90% of \nthe load in MISO is served by vertically integrated LSEs…”); see also Midcontinent Indep. Sys. Operator, Inc., 191 \nFERC ¶ 61,131, P 87 (2025) (ERAS 1.0 Order); and Midcontinent Indep. Sys. Operator, Inc., 189 FERC ¶ 61,159, \nPP 6, 27 (2024). \n16 Am. Clean Power Ass'n v. FERC, 54 F.4th 722, 728 (D.C. Cir. 2022) (discussing Ameren Servs. Co. v. FERC, 880 \nF.3d 571, 578 (D.C. Cir. 2018))."},{"page":4,"startToken":1008,"endToken":1281,"text":"4 \nprioritizing its own generation development and limiting competition from independently \ndeveloped generation within its service territory. Moreover, the Transmission Customer is often \nthe same utility that owns the existing transmission infrastructure and is responsible for \nconstructing the additional transmission facilities needed to accommodate the interconnection \ncustomer’s generation and associated load. This is antithetical to the very purpose of Order No. \n2003. \nIn Order No. 2003, the Commission found that “public utilities owning or controlling \njurisdictional transmission facilities had the incentive to engage in, and had engaged in, unduly \ndiscriminatory transmission practices.”17 Because interconnection is an element of transmission \nservice, the Commission established standard terms and procedures to “remedy undue \ndiscrimination and preferences under Sections 205 and 206 of the Federal Power Act.”18 The \nCommission did state that it would allow Regional Transmission Organizations and Independent \nSystem Operators (RTOs/ISOs), such as MISO, to propose independent entity variations for \npricing and non-pricing provisions.19 The Commission granted RTOs this flexibility because an \nRTO “is less likely to act in an unduly discriminatory manner than a Transmission Provider that \nis a market participant.”20 Despite this being a process under the MISO Tariff, MISO designed \nLARS to ensure it is the Transmission Customer—who has the incentive to discriminate against \ncompetitors—that controls access to the LARS process. \nCritical to any decision on MISO’s proposed LARS process is the understanding that \nMISO’s use of the Transmission Customer, while sensible because the Transmission Customer \n \n17 Standardization of Generator Interconnection Agreements & Procs., Order No. 2003, 104 FERC ¶ 61,103, P 13 \n(2003). \n18 Id. at P 19. \n19 Id. at P 827. \n20 Id."},{"page":5,"startToken":1281,"endToken":1570,"text":"5 \nprocures transmission service for load interconnecting to MISO’s system, is in practical effect \nthe same as MISO saying the vertically integrated LSE/TO utility; when a LARS Interconnection \nRequest is in that utility’s footprint, is in charge of whether to move a LARS project forward. \nThat result presents the very instance the Commission adopted Order No. 2003 to address: \n“when the Transmission Provider is not independent and has an interest in frustrating rival \ngenerators.”21 MISO’s flexibility to depart from the pro forma LGIP under the independent entity \nvariation standard rests on the Commission’s premise that an RTO or ISO is “less likely to act in \nan unduly discriminatory manner than a Transmission Provider that is a market participant.”22 \nThat premise does not support LARS when the decision whether any generator enters the process \nis handed to the market participant whose own generation the interconnection customer would be \ncompeting against. \nMISO claims that independent power producers are not prohibited from participating in \nthe LARS process.23 MISO is right. There is nothing in the Tariff language that expressly \nprohibits independent power producers from participating in the LARS process. However, \nsimply stating that the process is open does not actually make the process meaningfully open. \nYes, independent power producers can participate in the LARS process—if their competitors \nwill let them.  \nJust as there is no express prohibition on independent power producer participation in \nLARS, there is no express requirement that a LARS Associated Transmission Customer must \nsubmit a request. Under the proposed tariff, it is possible for the LARS Associated Transmission \nCustomer to hold up an otherwise viable arrangement between an independent Interconnection \n \n21 Id. at P 696. \n22 Id. at P 827. \n23 Transmittal at 7-8."},{"page":6,"startToken":1570,"endToken":1859,"text":"6 \nCustomer and a LARS Associated Load. An independent power producer may have an executed \nagreement with the large-load customer, substantial site control, and a commercially mature \nproject, but will remain unable to submit into the LARS process without signoff from the \nTransmission Customer.  \nThe proposal requires the Transmission Owner—which again in MISO is likely to also be \nthe LARS Associated Transmission Customer—to meet with the LARS Interconnection \nCustomer and any other impacted parties.24 However, there is enough ambiguity in the tariff to \nallow the Transmission Owner/ LARS Associated Transmission Customer to slow down a \nrequest. The tariff states that the parties “shall jointly agree upon a feasible Point of \nInterconnection” no later than 10 days before the LARS Application deadline.25 But, there is no \nprovisions for situations in which the parties cannot agree on the Point of Interconnection, and \nthere is no mechanism by which the LARS Interconnection Customer can seek recourse if the \nparties do not agree on a Point of Interconnection. Nor are there any provisions that require the \nLARS Associated Transmission Customer to submit an application, effectively granting them the \nability to prevent independent power producers from entering the LARS process. \nThis undue discrimination can be fixed. SEIA and United request that the Commission \nreject MISO’s LARS proposal, because it is unduly discriminatory. SEIA and United also \nrequest that the Commission provide guidance to MISO to refile the proposal with a mechanism \nthat would allow any qualified market participant—including independent power producers, \ndevelopers, and load customers—to initiate a submission directly to MISO, provided the \napplicable readiness and securitization requirements are met. \n \n24 Proposed Tariff, Attach. X, Sec. 3.12.1. \n25 Proposed Tariff, Attach. X, Sec. 3.12.1."},{"page":7,"startToken":1859,"endToken":2142,"text":"7 \nB. The LARS proposal is unjust and unreasonable because it conditions \ngenerators’ interconnection rights on specific large loads while risking double-\ncounted transmission headroom, harm to earlier-queued projects, and \nimproper cost shifts. \ni. LARS makes a generator’s rights depend on a specific large load, \nexposing viable projects to operational and financial uncertainty if \nthat load departs. \nMISO’s proposed LARS framework provides expedited Interconnection Service based on \na generator’s relationship with a particular large load,26 but fails to address the very real \npossibility that the relationship may be altered over time due to business decisions of the large \nload, creating significant uncertainty regarding the long-term durability of a generator’s \ninterconnection rights.27 Without any kind of transition mechanism, this uncertainty may force \notherwise viable generating resources into an uncertain and potentially disruptive transition \nprocess. By transferring the risk of the load customer’s future business decisions to the generator, \nthe proposal could penalize generators for circumstances they cannot control and thereby deter \notherwise viable projects from using the LARS pathway. \nUnder the LARS Proposal, a generator’s eligibility for LARS Interconnection Service is \ntied to the continued existence of a specific associated large load for a substantial portion of the \ngenerator’s operating life.28 LARS provides off-ramps when an associated load departs.29 If the \nLARS Associated Load withdraws, ceases taking transmission service, or the required \ncommercial agreement terminates during the first fifteen years, the generator’s LLGIA ultimately \nwill be terminated and the generator must obtain new Interconnection Service through the \nDefinitive Planning Process (DPP) to continue operating.30 This proposed structure creates a \n \n26 Transmittal at 7. \n27 Transmittal at 16. \n28 Transmittal at 5. \n29 Transmittal at 34. \n30 Transmittal at 16-18."},{"page":8,"startToken":2142,"endToken":2429,"text":"8 \nmaterial risk that a generator could lose the benefit of its expedited interconnection path through \nno fault of its own. Large-load facilities may cease operations, relocate, reduce demand, change \nsuppliers, or otherwise alter their commercial arrangements for reasons unrelated to the \ngenerator’s performance. When this occurs, the generator faces uncertainty regarding its future \noperating rights and potential migration into the DPP process.31  \nMISO acknowledges that the proposed process could “strand a Generating Facility” with \nremaining useful life and create “significant long-term commercial risk” affecting project \nfinancing,32 yet its proposed structure does not resolve those concerns. The risk of stranding a \ngenerator is particularly acute given the long development timelines and financing horizons of \ngeneration projects. Developers, lenders, and investors require predictable, durable \ninterconnection rights. Conditioning those rights on the continuation of a particular customer \nrelationship introduces uncertainty that may undermine financing and increase project costs. In \neffect, the proposal requires developers to evaluate not only the viability of the generation \nproject, but also the associated load’s long-term business prospects. \nThe proposed transition mechanism is woefully inadequate to address this stranded asset \nrisk. If an associated load departs during the period in which the generator remains subject to the \nfifteen-year pairing requirement, the generator’s LLGIA ultimately may be terminated and the \ngenerator must obtain new Interconnection Service through the DPP to continue operations.33 \nMISO proposes only a temporary transition period of up to one year, during which the generating \nfacility would remain subject to Quarterly Operating Limits (QOL) and Annual ERIS (AERIS) \nrestrictions while seeking new Interconnection Service through the DPP.34 Although MISO states \n \n31 Transmittal at 16-18; 34-35; 41-42. \n32 Transmittal at 17. \n33 Transmittal at 34. \n34 Transmittal at 17, 35."},{"page":9,"startToken":2429,"endToken":2702,"text":"9 \nthat it expects future DPP cycles will be completed within one year and provides for an extension \nif DPP processing is delayed beyond the generator's control,35 MISO provides little support for \nthat assumption and does not demonstrate that a generator can transition to the DPP without \nadverse operational or commercial impacts.36 Given the current backlogged status of the DPP, \nthe possibility of being put through that process means exposure to potentially years of delay, \neven after a facility has already entered commercial operation. \nMISO’s limited transition stands in stark contrast to the approach taken by the Southwest \nPower Pool (SPP) in its High Impact Large Load Generation Assessment (HILLGA) proposal, \nwhich the Commission specifically referenced as an example when directing other regions to \nensure adequate pathways for studying electrically proximate load and generation together.37 In \nHILLGA, SPP establishes upfront that generators using the pathway are granted only Load \nLimited Resource Interconnection Service (LLRIS), and provides five years for the \ninterconnecting generator to obtain full interconnection rights.38 While LARS differs from \nHILLGA in other important ways, the necessity of a clear pathway for the interconnecting \ngenerator to become a system resource applies equally here. \nAbsent additional protections, MISO’s proposal creates the possibility of an arbitrary \ninterconnection-service cliff in which a resource that was properly interconnected, financed, and \noperating becomes subject to substantial uncertainty because of events occurring outside the \ngenerator's control. Such outcomes would undermine investment certainty and could discourage \nparticipation in the very framework MISO seeks to establish. \n \n35 Transmittal at 18. \n36 Transmittal at 17-18, 35, 41-42. \n37 EL.26-70-000 at 14.  \n38 ER26-247-000 Transmittal at 5."},{"page":10,"startToken":2702,"endToken":2970,"text":"10 \nAccordingly, the Commission should reject the LARS filing, and direct MISO to provide \nadditional clarity in a subsequent proposal regarding the treatment of generators when associated \nloads cease operations or otherwise terminate the relationship underlying a LARS request. MISO \nshould establish transparent transition procedures, clearly define the rights and obligations of \naffected generators, and ensure that generators are not exposed to unreasonable operational or \ncommercial risks due solely to changes in a customer’s circumstances. \nii. MISO has not demonstrated how transmission capability will be \ntransparently managed across parallel LARS and DPP study \nprocesses to protect earlier-queued projects from double-counted \nheadroom, cost shifts, and diminished available capability. \nMISO has not adequately demonstrated that the proposed LARS framework will preserve \ntransparency and certainty for customers currently progressing through the Generator \nInterconnection Queue. While MISO states that protecting the DPP process was an express \nconsideration during development of the proposal,39 there is limited detail regarding how \ntransmission capability assumptions will be coordinated between LARS and DPP studies or how \npotential conflicts will be identified and resolved before stakeholders make significant \ncommercial and development decisions.40  \nUnder the proposal, LARS and DPP requests will be studied separately and using \ndifferent assumptions.41 MISO specifically states that LARS studies will not include \ninterconnection requests currently in the generator interconnection queue that have not executed \nGIAs.42 As a result, projects advancing through the two processes may be evaluated based on \ndifferent assumptions regarding future system conditions and available transmission capability.43 \n \n39 Transmittal at 20. \n40 Transmittal at 51. \n41 Transmittal at 23. \n42 Transmittal at 12. \n43 Transmittal at 12-13."},{"page":11,"startToken":2970,"endToken":3212,"text":"11 \n \nMISO contends that the separate study frameworks ultimately will be reconciled through \nthe MISO Transmission Expansion Plan (MTEP) process, and argues that LARS projects will \nnot affect DPP studies because the projects are evaluated independently.44 Although LARS \ncustomers remain responsible for applicable Network Upgrade costs, cost responsibility is not \nthe central concern. The filing does not adequately explain how MISO will coordinate \ntransmission-capability assumptions across parallel interconnection processes. Nor does it \nexplain how existing queue customers will receive timely visibility into contemporaneous LARS \nstudies before making significant commercial and development decisions. These uncertainties \ncould create unjust and unreasonable results for interconnection customers and must be clarified.  \nSpecifically, the filing does not sufficiently explain how reconciliation between the \nLARS and DPP processes will occur relative to key interconnection milestones, including \ncompletion of studies, execution of GIAs, commencement of construction activities, and major \nfinancing commitments. Although MISO states that reconciliation will occur through MTEP, the \nproposal provides little information regarding when potential conflicts between LARS and DPP \nassumptions will be identified or how affected customers will be informed.45  \nThis lack of transparency raises concerns irrespective of ultimate cost responsibility. \nInterconnection customers routinely make substantial commercial commitments based on study \nresults and anticipated interconnection outcomes. Developers rely on those results when \nnegotiating financing arrangements, equipment procurement contracts, power purchase \nagreements, and other project milestones. Yet the filing provides little explanation regarding how \n \n44 Transmittal at 13, 20. \n45 Transmittal at 13, 20."},{"page":12,"startToken":3212,"endToken":3452,"text":"12 \ninterconnection customers will be notified if assumptions underlying those commitments are \nlater modified as a result of reconciliation between LARS and DPP studies.46  \nNor does MISO identify a clear mechanism for addressing circumstances in which \ntransmission capability assumptions used in one process ultimately prove inconsistent with \nassumptions used in the other process. While MISO generally states that resulting transmission \nneeds would be addressed through existing planning processes and cost-allocation mechanisms,47 \nMISO does not explain when such inconsistencies would be identified, whether customers would \nreceive advance notice of potential impacts, or how MISO would ensure that existing queue \ncustomers retain reasonable certainty regarding their interconnection expectations as the two \nprocesses operate concurrently.  MISO acknowledges that stakeholders specifically raised issues \nregarding the relationship between LARS and the existing Generator Interconnection Queue \nduring the stakeholder process,48 but does not sufficiently resolve these issues. MISO’s proposal \noffers limited detail regarding the specific procedures that will preserve transparency and \npredictability for customers already progressing through the queue, creating uncertainty and \ndiscouraging participation. \nAccordingly, the Commission should require MISO to provide additional information \nregarding how transmission-capability assumptions will be coordinated between LARS and DPP \nstudies, when reconciliation will occur relative to major interconnection milestones, how \naffected customers will be notified of resulting impacts, and what safeguards will ensure that \nexisting queue customers maintain sufficient visibility into the transmission capability \n \n46 Transmittal at 20. \n47 Transmittal at 13. \n48 Transmittal at 20, 51."},{"page":13,"startToken":3452,"endToken":3746,"text":"13 \nassumptions underlying parallel LARS studies before significant commercial commitments are \nmade.  \n \nIII. \nALTERNATIVE RECOMMENDATION \nA. Alternatively, the Commission should clarify that the LARS application \nprocess must be administered on a nondiscriminatory basis.   \n \nIf the Commission disagrees with SEIA and United that MISO’s LARS proposal is unjust \nand unreasonable, or unduly discriminatory, and accepts the proposal, SEIA and United request, \nin the alternative, that the Commission expressly clarify that the LARS Associated Transmission \nCustomer’s exclusive initial application role does not authorize discriminatory treatment of an \notherwise qualified applicant. As discussed above, the Federal Power Act and Order No. 2003 \nrequire just and reasonable, nondiscriminatory access to jurisdictional transmission and generator \ninterconnection service.49 To preserve those principles, the Commission should expressly require \nnondiscriminatory administration of LARS from the outset. \nSpecifically, the Commission should clarify that once an applicant meets all applicable \nLARS eligibility, readiness, financial security, and application requirements, the Commission \nexpects the LARS Associated Transmission Customer to apply the same submission standards \nand timelines it applies to its own similarly situated projects. During stakeholder engagement, \nMISO responded to concerns about limiting application submission to LSEs by explaining that \nIPPs could participate as Interconnection Customers, even though the Associated Transmission \nCustomer would initiate the application.50 That response, however, does not resolve the concern \n \n49 16 U.S.C. § 824d(a)–(b); Order No. 2003, 104 FERC ¶ 61,103, PP 12, 18–20. \n50 MISO, MISO Response to Feedback: Large Load Addition Resource Study (LARS), at 6 (Aug. 20, 2026), \nhttps://cdn.misoenergy.org/LLWG%20Generation%20and%20Large%20Load%20Alignment%20Response%20%2\n8LLWG-2026-6%29%20%2820260716%29778046.pdf (Feedback: “Why is the submittal limited to Load Serving \nEntities? This is potentially discriminatory to IPPs.” MISO Response: “While the LARS application process will be"},{"page":14,"startToken":3746,"endToken":4025,"text":"14 \nthat the Associated Transmission Customer could use its control over submission to favor its \nown generation. The requested clarification would preserve the Associated Transmission \nCustomer’s service role in the LARS process while ensuring nondiscriminatory access to the \ncoordinated study process.  \nThe Commission should also expressly clarify that acceptance of LARS does not insulate \ndiscriminatory implementation from subsequent challenges. This would be consistent with the \nCommission’s adjudication of Section 206 complaints challenging interconnection study \nprocedures. For example, in EDF Renewable Energy, Inc. v. Midcontinent Indep. Sys. Operator, \nInc., the Commission permitted the RTOs to retain their existing Affected Systems modeling \nstandards “assuming they apply such criteria and procedures consistently and on a not unduly \ndiscriminatory basis among all interconnection requests.”51 The Commission should likewise \nclarify that retaining the Associated Transmission Customer’s application role does not foreclose \nreview of discriminatory administration of LARS upon a future, case-specific complaint. An \nexpress clarification would provide notice of the governing standard and strengthen the basis for \ncase-specific relief while preserving MISO’s proposed application structure. \n \nIV. \nCONCLUSION \nMISO’s proposal makes the Transmission Customers—most often vertically integrated \nLSE and TO utility—the gatekeepers of this new competitively advantageous process. In a \nregion such as MISO’s where many utilities are vertically integrated, that role grants these \n \ninitiated by the LARS Associated Transmission Customer, the Interconnection Customer, Transmission Owner, and \nLARS Associated Transmission Customer must all complete the required information as part of the application \nbefore it will be reviewed by MISO. IPPs are not prohibited from participating as the Interconnection Customer as \npart of the process.”).  \n51 EDF Renewable Energy, Inc. v. Midcontinent Indep. Sys. Operator, Inc., 168 FERC ¶ 61,173, P 86 (2019)."},{"page":15,"startToken":4025,"endToken":4291,"text":"15 \nutilities the ability to determine which, if any, of its competitors may participate in the LARS \nprocess. And regardless of which projects go through the LARS process, the impact on earlier-\nqueued projects will be negative. While there are aspects of the filing that would pass muster \nunder the Federal Power Act, its proposal to install the Transmission Customer as the \ngatekeepers to the LARS process and impacts to the existing queue are why it does not meet its \nburden under the Federal Power Act. SEIA and United request that the Commission reject \nMISO’s filing with guidance to MISO to refile the proposal with a mechanism that would allow \nany qualified market participant—including independent power producers, developers, and load \ncustomers—to initiate a submission directly to MISO, provided the applicable readiness and \nsecuritization requirements are met. Allowing LSEs to determine which of its competitors may \nparticipate in the markets would undermine Order No. 2003. However, if the Commission \naccepts MISO’s proposal, SEIA and United request that the Commission expressly clarify that \nthe LARS application process must be administered on a nondiscriminatory basis and that \nacceptance does not foreclose subsequent challenges to discriminatory implementation. \n \nRespectfully submitted, \n \n/s/ Caitlin Marquis \n \nCaitlin Marquis, Managing Director \nConor McKenzie, Senior Principal \nKelsey Koenig, Associate \nAdvanced Energy United \n1801 Pennsylvania Ave NW Ste. 410 \nWashington, DC 20006 \ncmarquis@advancedenergyunited.org   \ncmckenzie@advancedenergyunited.org  \nkkoenig@advancedenergyunited.org  \n/s/ Melissa Alfano \n \nMelissa Alfano  \nSenior Director of Energy Markets and Counsel  \nSolar Energy Industries Association  \n1425 K St NW Ste. 1000  \nWashington, DC 20005  \n(202) 566-2873  \nmalfano@seia.org   \n \n \nDated: October 23, 2026"},{"page":16,"startToken":4291,"endToken":4337,"text":"CERTIFICATE OF SERVICE \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. \nDated at Washington, DC, this 23rd day of October, 2026. \n \n \n \n/s/ Caitlin Marquis \n \nCaitlin Marquis"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":1014,"startToken":0,"endToken":534},{"p":2,"at":1014,"title":"I. Protest","method":"PDF bookmark","endPage":2,"endAt":1027,"startToken":534,"endToken":536},{"p":2,"at":1027,"title":"A. The LARS Proposal is unduly discriminatory because it allows LSEs to decide if their competitors may participate in the LARS process.","method":"PDF bookmark","endPage":7,"endAt":3,"startToken":536,"endToken":1860},{"p":7,"at":3,"title":"B. The LARS proposal is unjust and unreasonable because it conditions","method":"printed heading","endPage":7,"endAt":247,"startToken":1860,"endToken":1892},{"p":7,"at":247,"title":"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.","method":"PDF bookmark","endPage":10,"endAt":551,"startToken":1892,"endToken":2777},{"p":10,"at":551,"title":"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.","method":"PDF bookmark","endPage":13,"endAt":106,"startToken":2777,"endToken":3464},{"p":13,"at":106,"title":"III. Alternative Recommendation","method":"PDF bookmark","endPage":13,"endAt":140,"startToken":3464,"endToken":3467},{"p":13,"at":140,"title":"A. Alternatively, the Commission should clarify that the LARS application process must be administered on a nondiscriminatory basis.","method":"PDF bookmark","endPage":14,"endAt":1317,"startToken":3467,"endToken":3917},{"p":14,"at":1317,"title":"IV. Conclusion","method":"PDF bookmark","endPage":14,"endAt":1322,"startToken":3917,"endToken":3918},{"p":14,"at":1322,"title":"CONCLUSION","method":"printed heading","endPage":16,"endAt":0,"startToken":3918,"endToken":4291},{"p":16,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":16,"endAt":301,"startToken":4291,"endToken":4337}]}