ER27-25-000 · 2026-11-09 · MISO

MISO Answer to Comments and Protests on the Large Load Addition Resource Study

Read topic-matched comments in ER27-25

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

What the document says

PDF p. 3

MISO defends studying loads and nearby generation together.

study both the large load and the generation that will serve it at the same time PDF p. 3

Responses and related views

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Source sections

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Opening text

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ER27- 25-000 (Oct. 2, 2026) (“LARS Filing”); the GIP and Attachment FF are available at: https://www.misoenergy.org/legal/rules-manuals-and-agreements/tariff/. 2 System.4 Also, because a number of commenters misstate the intent and background of LARS, raise extraneous issues, seek clarifications,…
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I. MOTION FOR LEAVE TO FILE ANSWER

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MOTION FOR LEAVE TO FILE ANSWER Under the Commission’s rules, answers to protests generally are not permitted.5 Nonetheless, the Commission waives this requirement where an otherwise prohibited answer would clarify the issues under consideration, ensure completeness of the record or assist the…
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II. EXECUTIVE SUMMARY

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II.
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EXECUTIVE SUMMARY

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See Data Center Coalition LARS Comments at 2-3; NIPSCO LARS Comments at 2-4; MISO Transmission Owners LARS Comments at 6-9; Entergy and Cleco LARS Comments at 10-11; Mississippi Public Service Commission and the Louisiana Public Service Commission (the “Southern Regulators”) LARS Comments at 1-2;…
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III. ANSWER

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As such, MISO 17 Consumers Energy and Alliant LARS Comments at 2; Data Center Coalition LARS Comments at 4; DTE LARS Comments at 2; Electricity Customer Alliance (“ECA”) LARS Comments at 1. 18 Entergy and Cleco LARS Comments at 2. 9 respectfully asks that the Commission accept its proposal to…
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A. LARS is Responsive to the Commission’s Show Cause Order

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In developing LARS, MISO concluded that defining a maximum distance based on substations would impede the flexibility of large loads and 19 Clean Energy Trades LARS Comments at 18; the Community Organizations and Clean Energy Advocates (the “Advocates”) LARS Comments at 37-38; Consumer Advocates…
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B. Large Load Cost Allocation Framework

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With respect to cost responsibility, accountability, and cost shifting, the LARS filing includes Tariff language stating: Once MTEP approval occurs for the LARS Associated Load, the LARS Associated Transmission Customer remains responsible for the identified BRPs and Other assigned projects even if…
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C. LARS Will Not Harm the Existing Queue

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LARS Will Not Harm the Existing Queue MISO understands that many stakeholders are concerned that LARS projects will take available transmission capacity or headroom from other projects currently in the DPP queue.35 The argument is that since LARS and DPP interconnection customers are vying for the…
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D. LARS Application and Eligibility Requirements

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Specifically, LARS allows arrangements involving Interconnection Customers that are separate entities from the Transmission Customer and provides that the Interconnection Customer—and not the LARS Transmission Customer—will receive the LLGIA awarding Interconnection Service to LARS Associated…
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E. MISO Has Met the Standard for an Independent Entity Variation

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LARS advances Order No. 2003’s goal of expediting new generation while protecting reliability.49 LARS also meets Order No. 2023’s goal of insulating the DPP queue and ensuring that only truly commercially ready projects apply.50 Notably, the LARS process requires an increased non-refundable payment…
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F. Miscellaneous Clarifications and Requests.

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The applicants submitting a LARS Application must identify the LARS Associated Load’s expected peak 49 See Order No. 2003, FERC Stats. & Regs. ¶ 31,146 at PP 822-827; Order No. 2003-A, FERC Stats. & Regs. ¶ 31,160 at P 759. 50 See Improvements to Generator Interconnection Procs. & Agreements, Order…
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IV. CONCLUSION

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IV.
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CONCLUSION

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CONCLUSION WHEREFORE, MISO respectfully requests that the Commission: (1) accept this Answer; and (2) accept the LARS Filing as discussed herein.
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CERTIFICATE OF SERVICE

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Dated at Carmel, Indiana this 9th day of November, 2026. /s/ Dawn Kaminski Dawn Kaminski Midcontinent Independent System Operator, Inc. 720 City Center Drive Carmel, Indiana 46032 Telephone: (317) 249-5400
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