{"document":{"slug":"comments-er27-25-entergy-cleco","title":"Supporting Comments of the Entergy Operating Companies and Cleco Power LLC","issued":"2026-10-23","accession":"20261023-5035","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"Entergy and Cleco","kind":"comments in support","file":"sources/originals/20261023-5035_Entergy Comments in Support MISO LARS Filing FINAL1.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261023-5035","sha256":"ff7d1cd1c0d996887155de1c866fb865485dea9b200af641e0f47fd3aa310ef5","pages":6,"tokens":1485,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":220,"text":"1\nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \n \n \n \n \n) \nMidcontinent Independent System  \n) \nDocket No. ER27-25-000 \nOperator, Inc.    \n \n \n) \n  \n \nSUPPORTING COMMENTS OF \nTHE ENTERGY OPERATING COMPANIES AND CLECO POWER LLC \n \nPursuant to Rule 212 of the Commission’s Rules of Practice and Procedure1, and \nthe Commission’s October 2, 2026, notice in the above-captioned docket, Entergy \nServices, LLC, on behalf of the Entergy Operating Companies (“Entergy”)2 and Cleco \nPower, LLC hereby submit comments in support of the Midcontinent Independent \nSystem Operator, Inc.’s (“MISO’s”) filing to establish the Large Load Addition Resource \nStudy (LARS).   \nEntergy and Cleco Power LLC support MISO’s October 2, 2026, filing to \nestablish the LARS process, and respectfully urges the Commission to accept it, as it will \nenable MISO to expeditiously review the interconnection needs of large loads over 200 \nMW that have identified new generation resources to support their needs.  As a general \nprinciple, the LARS process should reduce overall interconnection-related costs to \nconsumers.   \nLarge loads, including computational data centers, advanced manufacturing, and \nother energy-intensive industries, are arriving in MISO’s footprint at an increasing pace, \n \n1 18 C.F.R. § 385.212. \n2 The Entergy Operating Companies are Entergy Arkansas, LLC (“Entergy Arkansas”), Entergy Louisiana, \nLLC (“Entergy Louisiana”), Entergy Mississippi, LLC (“Entergy Mississippi”), Entergy New Orleans, \nLLC (“Entergy New Orleans”), and Entergy Texas, Inc. (“Entergy Texas”)."},{"page":2,"startToken":220,"endToken":494,"text":"2\nand their addition to the bulk electric system can create unique study needs. Pairing these \nloads with generation that is developed to support them can be one way to reduce the \nneed for significant transmission upgrades that might be otherwise needed if only the \ngeneration or only the load were interconnecting; however, to date, MISO has not always \nstudied such generation-load pairs in a manner that recognizes these synergies.  LARS \noffers a coordinated, 120-day parallel study of eligible large loads and their paired \ngeneration resources.  It is a measured and thoughtful response to the Commission’s call \nfor tariff provisions concerning electrically proximate large loads and generation, and it \nshould be accepted as just and reasonable.3 \nI. \nBackground \nBoth Entergy and Cleco Power LLC are load-serving entities with an obligation to \nserve the electricity needs of their customers.  The Entergy Operating Companies are \ngeneration and transmission-owning members of MISO and serve approximately 3.1 \nmillion retail customers, 70% of which are large industrial or commercial businesses. As \nload serving entities, the Entergy Operating Companies procure both generation and \ntransmission service for their retail customers, including large loads. The Entergy \nOperating Companies own or lease over 24,000 MW of generation assets producing \nelectricity that is carried across more than 16,000 miles of high voltage transmission \nlines.  \nCleco Power LLC is an electric utility engaged principally in the generation, \ntransmission, distribution, and sale of electricity within Louisiana.  Cleco Power LLC is a \n \n3 Midcontinent Independent System Operator, Inc., 195 FERC ¶ 61,212, (issued June 18, 2026) (Docket \nNo. EL26-70-000) (“Show Cause Order”); Prepared Direct Testimony of Christina Drake (“Drake \nTestimony”) at 7, 41."},{"page":3,"startToken":494,"endToken":765,"text":"3\nLouisiana limited liability company and a wholly owned subsidiary of Cleco Corporate \nHoldings LLC, a privately held holding company.  Cleco Power currently owns eight (8) \ngenerating units with a capacity of over 2,600 MW and maintains approximately 1,380 \nmiles of transmission lines.  When the Entergy Operating Companies and Cleco Power \nidentify needs for new generation resources to support load growth, the decision about \nwhere to construct the new generator is based in part on where new loads are likely to be \nlocated. This is done to try to reduce the need for additional transmission upgrades if \npossible.  \nFor the Entergy Operating Companies and Cleco Power, the inclusion of LARS as \nan option to plan for the future needs of its growing customer base is vital. In recent \nyears, both companies have seen first-hand why a coordinated, expedited study pathway \nis needed for new large loads that are paired with generation.  MISO’s DPP cycles have \ntaken four years or longer to reach completion, leaving load-serving entities without a \ntimely path to interconnect associated generation that is being built to benefit customers \nthat are hoping to be served within a much shorter timeframe. That timing mismatch, \nbetween the pace of large-load arrivals and when an associated generator can obtain a \nsigned GIA, is what LARS helps to resolve by aligning the load and generation on \nparallel studies and on a single 120-day track.4  And, the ability to identify combined \ntransmission solutions and avoid the introduction of duplicative and expensive upgrades \nwill certainly result in far faster and clearer interconnection timelines.   \n \n \n \n4 Id.; see also MISO Transmittal Letter at 19."},{"page":4,"startToken":765,"endToken":1101,"text":"4\nII. \nThe LARS Process is Just and Reasonable \nLARS should be accepted by the Commission because it is just and reasonable \nand delivers coordinated speed to power without sacrificing study integrity.  By studying \nload and its paired generation together, MISO can identify combined transmission \nsolutions, avoid duplicative and costly upgrades, and produce a reliable outcome in \napproximately 120 days.  This is not currently achievable across the separate EPR, DPP, \nand ERAS processes and timelines that are now in place.5 Making LARS a permanent \nprocess is appropriate because it provides needed, long-term regulatory and financial \ncertainty required to site and finance large load-and-generation pairings, and it includes \nstructural limits that keep the process bounded in every cycle.6  As further highlighted in \nMISO’s filing, LARS aligns with and is directly responsive to the Commission’s Show \nCause Order, as it offers an explicit pathway for MISO to “account for the operational \ndynamics of serving electrically proximate large loads.”7   \nThe Commission should evaluate LARS under the “independent entity variation \nstandard” to determine whether MISO’s variation here is just and reasonable, not unduly \ndiscriminatory or preferential and accomplishes the purposes of Order No. 2003.8  First, \nthe LARS project requirements are appropriately tailored with reasonable limitations to \nprevent unintended uses.  LARS limits the total number of projects to ensure that MISO \n \n5 Drake Testimony at 6. \n6 Id. at 12. \n7 See Show Cause Order at P 113 (noting that the Commission preliminarily found that MISO’s existing \nTariff “may be unjust and unreasonable because it does not provide generator interconnection study \nprocedures and services that account for the operational dynamics of serving electrically proximate large \nloads.”).  \n8 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 at 2 (July 21, 2025) (Docket No. \nER 25-2454-000) (“Under the independent entity variation standard, an RTO/ISO must demonstrate that \nproposed deviations from the Commission’s pro forma LGIP and pro forma LGIA are just and reasonable \nand not unduly discriminatory or preferential and accomplish the purposes of Order No. 2003.”)."},{"page":5,"startToken":1101,"endToken":1364,"text":"5\ncan administratively support the new process, as only ten generation/load pairs per study \nperiod will be evaluated, with three periods per year.9  Second, MISO’s proposed tariff \nrevisions propose stringent eligibility requirements to deter speculative interconnection \nrequests and minimize disruption to the DPP, including a 150% generation to Associated \nLoad ceiling, a $250,000 deposit, a three-year commercial operation date, and a same-\nLocal-Resource-Zone requirement.10 Third, MISO’s proposal is consistent with the \nCommission’s open-access goals because it is transparent, competitive, technology and \nfuel agnostic, applies identical eligibility to all applicants, and does not restrict DPP \naccess or adversely affect DPP applicants.11 These tailored limitations demonstrate that \nLARS is a reasoned approach that anticipates and resolves issues consistent with \npreviously stated Commission guideposts. \nIn short, the Entergy Operating Companies and Cleco Power support LARS \nbecause it is a tailored pathway that reasonably optimizes the nature of coordinated load \nand generation studies, which in turn facilitates more efficient and cost-effective \ntransmission system planning.  It is a significant step to ensure that MISO and its \nstakeholders thoughtfully build the grid to meet its new large load demands.  It is a \nnecessary new product for a new commercial reality.  \nIII. \nConclusion \nLARS is a timely, well-designed, and appropriately limited tool for integrating \nlarge loads and the generation built to serve them, and it responds directly to the \n \n9 MISO Transmittal at 9. \n10 Id. at 10, 28. \n11 Midcontinent Independent System Operator, Inc., 192 FERC ¶ 61,064 at Para. 2 (July 21, 2025) (Docket \nNo. ER 25-2454-000); see also MISO Transmittal at 10."},{"page":6,"startToken":1364,"endToken":1485,"text":"6\nCommission’s Show Cause Order in this regard.  Therefore, the Entergy Operating \nCompanies and Cleco Power respectfully request that the Commission accept MISO’s \nLARS filing.  \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nRespectfully submitted, \n \n/s/ Jeffrey Phillips \nSenior Counsel  \nEntergy Services, LLC \n101 Constitution Ave., Ste. 200-E \nWashington, DC  20001 \n202-530-7312 \nJphil36@entergy.com \n \nAndrea Weinstein \n \n \n \n \nVP& Deputy General Counsel \n \n \nEntergy Services, LLC \n \n \n \n101 Constitution Ave. Ste. 200-E \n \n \nWashington, DC  20001 \n \n \n \n202-503-7342  \n \n \n \n \naweinst@entergy.com \n \n \n \n \nKaris Anne Gong Parnham \nAssistant General Counsel   \nEntergy Services, LLC   \n919 Congress Ave., Suite 700  \nAustin, TX 78701   \n512-487-3986   \nkparnha@entergy.com   \n \nOn behalf of \nEntergy Services, LLC \n \n/s/Jill M. Kelone \nJill M. Kelone \nDirector – Compliance \nCleco Corporate Holdings LLC \n(318) 484-7597 \nJill.Kelone@cleco.com \n \nOn behalf of  \nCleco Power LLC"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":758,"startToken":0,"endToken":337},{"p":2,"at":758,"title":"I. Background","method":"printed heading","endPage":2,"endAt":762,"startToken":337,"endToken":338},{"p":2,"at":762,"title":"Background","method":"printed heading","endPage":4,"endAt":2,"startToken":338,"endToken":766},{"p":4,"at":2,"title":"II. The LARS Process is Just and Reasonable","method":"printed heading","endPage":5,"endAt":1395,"startToken":766,"endToken":1300},{"p":5,"at":1395,"title":"III. Conclusion","method":"printed heading","endPage":5,"endAt":1401,"startToken":1300,"endToken":1301},{"p":5,"at":1401,"title":"Conclusion","method":"printed heading","endPage":6,"endAt":969,"startToken":1301,"endToken":1485}]}