{"document":{"slug":"filing-er27-25-miso-lars","title":"Midcontinent Independent System Operator, Inc.'s Large Load Addition Resource Study Process (transmittal letter; requested effective date December 2, 2026)","issued":"2026-10-02","accession":"20261002-5074","docket":"ER27-25-000","group":"MISO Large Load Addition Resource Study (LARS)","filer":"MISO","kind":"section 205 filing (transmittal letter)","file":"sources/originals/20261002-5074_Transmittal Letter_LARS.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261002-5074","sha256":"e43c8b54877ecc55b90d9f02a5574062d7321cdda7386187b782a8847326d8d5","pages":54,"tokens":25989,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":397,"text":"Midcontinent Independent \nSystem Operator, Inc. \n317.249-5400 \nwww.misoenergy.org \n720 City Center Drive \nCarmel, Indiana 46032 \n2985 Ames Crossing Road \nEagan, Minnesota 55121 \n1700 Centerview Drive \nLittle Rock, AR 72211 \n \nChristopher D. Supino \nManaging Senior Corporate Counsel \nDirect Dial:  317-517-2963 \nEmail:  csupino@misoenergy.org \n \n \nOctober 2, 2026 \nVIA ELECTRONIC FILING \nThe Honorable Debbie-Anne Reese  \nSecretary \nFederal Energy Regulatory Commission \n888 First Street, NE \nWashington, DC  20426 \nRe: \nMidcontinent Independent System Operator, Inc.’s  \nLarge Load Addition Resource Study Process \nDocket No. ER27-___-000 \n \nDear Secretary Reese: \nThe Midcontinent Independent System Operator, Inc. (“MISO”), through this filing,1 \nsubmits proposed revisions to its Open Access Transmission, Energy and Operating Reserve \nMarkets Tariff (“Tariff”),2 to establish a Large Load Addition Resource Study (“LARS”) process,3 \nassociated application and operational requirements to enable load and generation to be studied \ntogether leveraging existing MISO processes to facilitate the timely availability of the tool to \ncustomers.4  The LARS proposal will help streamline the MISO generator and load interconnection \nprocess by providing expedited review of the addition of 200 MW or greater loads together with \nnew generation resources that are electrically proximate to those loads.  Through this coordinated \nstudy framework, LARS is designed to facilitate the timely and reliable interconnection of Large \nLoads and new generation onto the MISO system. \n \n \n1  \nThis filing is made pursuant to section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d, and Part 35 of \nthe regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 35.1, et \nseq. \n2  \nUnless otherwise indicated by the text or context of this transmittal letter, all terms used herein have the definitions \nset forth in Module A of the Tariff. \n3  \nFor the purposes of this filing, references to “LARS” may refer to the Large Load Addition Resource Study or \nmay be used as a general reference to the processes and operational requirements that are part of the proposal \nsubmitted herein. \n4  \nMISO uses the uncapitalized term “large load” in this transmittal letter and associated testimony rather than the \n“Large Load” term proposed in MISO’s pending Large Load Interconnection Reliability filing.  This is done to \navoid confusion because that definition remains pending before the Commission and because, given the 200 MW \nthreshold for entry into LARS, not all “Large Loads” will be eligible to be a “LARS Associated Load.”"},{"page":2,"startToken":397,"endToken":874,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 2 \n \n \n \nMISO requests that the Tariff revisions submitted herewith be made effective December 2, \n2026, which is not less than sixty (60) days nor more than one-hundred and twenty (120) days \nfrom the date of this filing.  MISO requests that the Commission issue an order by this date in \norder to allow MISO to commence the first LARS Study Period in Q1 of 2027.  As discussed \nbelow and in the supporting testimony of Christina Drake,5 action is needed in the near term to \nenhance the available tools to address the reliability impacts associated with the impending \ninterconnection of Load, including the anticipated interconnection of significant large loads. \n \nI. \nEXECUTIVE SUMMARY \n \nLARS responds to rapidly evolving reliability and resource adequacy needs in the MISO \nregion.  MISO is proposing LARS to facilitate the cost effective, timely and reliable integration of \nnew large loads into the system.  LARS supports the Commission’s call to action to meet these \nnew challenges in short order.  LARS will provide a path for the interconnection of both large \nloads and supporting generation pairs in a parallel 120-day study process.  The proposal leverages \nthe existing success in the MISO’s Expedited Project Review (“EPR”) process on the load side \nand lessons learned from Expedited Resource Additions Study (“ERAS”) process on the \ngeneration side.  \n \nMISO is experiencing significant growth in electricity demand at the same time that \nadditional resources are needed to reliably serve that demand.  MISO projects annual load growth \nof approximately 1% to 3% through 2044, driven in part by energy-intensive loads such as data \ncenters and manufacturing expansion, and has identified the need to accelerate new resource \nadditions as demand grows.6   \n \nThe need to accelerate the infrastructure necessary to reliably serve growing electricity \ndemand is also reflected in the Department of Energy’s (“DOE”) Speed to Power initiative, which \nseeks to accelerate development timelines for large-scale transmission and generation projects to \nmeet rising electricity demand.7  LARS advances that objective within the MISO region by \nproviding a process through which significant new large loads and generation intended to support \nthat load can be studied on an accelerated and coordinated basis. \n \n \n \n5  \nPrepared Direct Testimony of Christina Drake, Director—Generation Interconnection, attached hereto as Tab C \n(“Drake Testimony”). \n6  \nMISO, 2026 Reliability Imperative Report at 4 (Feb. 2026) (projecting annual load growth of approximately 1% \nto 2% through 2044 and identifying data centers, manufacturing expansion, and electrification as drivers of \nsustained, concentrated load growth); see also, MISO, 2026 Planning Resource Auction Results at 2 (May 22, \n2026) (stating that faster resource additions are needed to support large-load growth and ensure resource \nadequacy). \n7  \nDOE, Speed to Power Initiative (Sept. 18, 2025) (describing the initiative as a federal effort to accelerate \ndevelopment timelines for large-scale transmission and generation projects and ensure sufficient power to meet \nrising electricity demand)."},{"page":3,"startToken":874,"endToken":1365,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 3 \n \n \n \nLARS is also responsive to the Commission’s June 18, 2026, Order Instituting Proceeding \nUnder Section 206 of the Federal Power Act in Docket No. EL26-70-000 (“Show Cause Order”).  \nThe Commission preliminarily found, among other things, that MISO’s existing Tariff may be \nunjust and unreasonable because it does not provide generator interconnection study procedures \nand services that account for the operational dynamics of serving electrically proximate large \nloads.8  The Commission specifically addressed the potential for a new generating facility and an \nelectrically proximate large load to be studied in a manner that accounts for their combined \ntransmission system impacts.9  LARS provides a mechanism for MISO to study a large load and \nthe generation that will serve it at the same time such that their combined transmission system \nimpacts may be considered together.  \n \nIn addition, the Commission requested a detailed informational report on any proposals \nunder consideration to address the issue of resource adequacy to serve new large loads, strongly \nencouraging new proposals to the extent necessary to address these concerns.10  The LARS process \nresponds to this concern and serves to provide a critical tool that allows the timely integration of \nresources associated with these new loads supporting regional resource adequacy.  While MISO’s \nexisting processes have been sufficient to ensure resource adequacy in the short term, the unique \ncommercial and operational characteristics of new large loads and the speed with which they need \nto come online have prompted MISO to develop LARS as an additional tool to further support \nresource adequacy as new large loads are integrated into the MISO region in the future. \n \nThis proposal is deliberately tailored to significant new large loads.  MISO initially \nproposed a minimum eligibility threshold of 250 MW and expressly sought stakeholder input \nregarding whether that threshold appropriately captured high-impact loads without unnecessarily \nexpanding the scope of the process.11  MISO set the initial threshold at 250 MW as recent EPR \nresults showed that large loads of 250 MW and greater created meaningful grid impacts, with \nupgrades becoming increasingly likely between 300–500 MW and consistently necessary at 1,200 \nMW and above with multi-element upgrades.  Stakeholders proposed alternative thresholds, \nincluding 200 MW, which MISO proposes herein as it expands the LARS proposal beyond \nhyperscale load to apply to other kinds of large loads including industrial loads.12  \n \n \n8  \nMidcontinent 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” or “SCO”). \n9  \nId. \n10  Id. at P 122.  \n11  MISO, Large Load Working Group (“LLWG”), Generation and Large Load Alignment, LLWG-2026-6, \nStakeholder Feedback (July 30–31, 2026) (soliciting stakeholder feedback on whether 250 MW was the \nappropriate minimum threshold and what alternative threshold would capture high-impact loads without diluting \nthe intent of the proposed process), available at https://www.misoenergy.org/engage/stakeholder-\nfeedback/2026/llwg-large-load-addition-resource-study-llwg-2026-6-20260827/. \n12  Id."},{"page":4,"startToken":1365,"endToken":1760,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 4 \n \n \n \nImportantly, LARS is designed to work in concert with other MISO large load initiatives, \nsuch as MISO’s proposed Zero Injection Generator Interconnection Agreement (“ZGIA”)13 and \nInterconnection Reliability Requirement (“IRR”)14 frameworks currently pending before the \nCommission and maintains protections for generation already progressing through MISO’s \ngenerator interconnection queue or more commonly known as the Definitive Planning Phase \n(“DPP”) process.  LARS provides a different tool for large load interconnection arrangements \ninvolving paired generation that do not fit within the ZGIA framework. \n \nTaken LARS provides MISO with a targeted tool to address the intersection of significant \nlarge load additions, optimized Network Upgrades with generation and load, generation \ndevelopment, and supports resource adequacy.  The proposal allows MISO to study qualifying \nload and associated generation on a coordinated basis, responds to issues identified in the \nCommission’s Show Cause Order, and is designed to preserve the integrity of MISO’s existing \ngenerator interconnection processes.  LARS is needed now to facilitate the cost-effective and \nreliable interconnection of impending new large loads and generation additions on an accelerated \ntimeline. \n \nII. \nOVERVIEW OF THE LARS PROCESS \n \nA. \nBACKGROUND \n \nThe MISO region is experiencing a significant change in both the magnitude and pace of \nanticipated electricity demand.  MISO’s 2026 Reliability Imperative explains that, following a \nperiod in which electricity demand grew at an average annual rate of approximately 0.5% between \n2009 and 2024, MISO now projects annual load growth of approximately 1% to 3% through \n2044.15  MISO identifies energy-intensive loads, including data centers and manufacturing \nexpansion, among the sources of this sustained and concentrated growth.16 \n \nThis growth has corresponding implications for the resources necessary to maintain \noperational reliability and resource adequacy.  MISO has stated that, as demand grows rapidly, \nmaintaining existing resources and accelerating new resource additions are critical.17  MISO’s \n2026 Planning Resource Auction results likewise recognize that, although the region has sufficient \nresources to satisfy resource adequacy requirements for the 2026-2027 Planning Year, faster \n \n13  Midcontinent Indep. Sys. Operator, Inc, Docket No. ER26-3552 (Aug. 18, 2026) (“ZGIA Filing”). \n14    Midcontinent Indep. Sys. Operator, Inc, Docket No. ER26-3650 (Aug. 28, 2026) (“IRR Filing”). \n15  MISO, 2026 Reliability Imperative Report at 4 (Feb. 2026) (contrasting historical load growth of approximately \n0.5% annually from 2009 through 2024 with projected annual growth of approximately 1% to 2% through 2044). \n16  Id. \n17  Id."},{"page":5,"startToken":1760,"endToken":2290,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 5 \n \n \n \nresource additions remain necessary to support large-load growth and ensure resource adequacy.18  \nMISO has, therefore, identified rapid load growth as a core component of its broader Reliability \nImperative.  MISO’s Transmission Evolution work specifically identifies the need to “speed up \ntimelines for new generation and transmission projects” while managing large-load growth without \ncompromising reliability.19   \n \nAgainst this backdrop, the challenge presented by new large load growth is not limited to \nconnecting the load itself.  Significant new demand must be accompanied by sufficient resources \nto maintain reliability and resource adequacy.  MISO’s Large Load Working Group (“LLWG”) \nwas established to address this broader relationship, with a mission encompassing markets, reliable \noperations, planning, and resource adequacy associated with the integration and enablement of \nlarge loads.20  LARS is intended to address one aspect of that challenge by establishing a process \nthrough which qualifying Large Load additions and associated new generation can be studied on \na coordinated basis.  Studying qualifying load and generation together, with aligned study timeline, \nprovides a mechanism for MISO to consider significant new demand and the resources associated \nresulting in optimized network upgrades.  In this manner, LARS is designed to facilitate the reliable \nintegration of significant new load and generation on an accelerated timeline. \n \nB. \nSTRUCTURE OF LARS AND PARTIES \n \nLARS provides a parallel study process for a proposed large load and generation pair.21  As \nMISO explained in its motion for abeyance, “LARS will assess the transmission infrastructure \nneeded to meet new large loads and new generation in an efficient process that can be executed on \na shorter timeline, further supplementing the opportunities available for members to facilitate new \nlarge spot loads effectively.”22  The generation and load studies will be completed at the same time \nand will finish within approximately 120 days.  To allow this to happen, LARS brings the \nrequirements that are needed for both the generation and load studies under a common application, \n \n18  MISO, 2026 Planning Resource Auction Results at 2 (May 22, 2026) (finding sufficient resources for the 2026-\n2027 Planning Year while stating that faster resource additions are needed to support large-load growth and ensure \nresource adequacy). \n19  MISO, Reliability Imperative 2026 (identifying rapid load growth and a changing generation mix as transmission \nchallenges and identifying accelerated generation and transmission development as part of MISO’s response). \n20  MISO, Large Load Working Group Charter at 1 (Apr. 20, 2026) (establishing the LLWG to provide input and \npolicy guidance concerning markets, reliable operations, planning, and resource adequacy associated with large-\nload integration), (“LLWG Charter”), available at: \nhttps://cdn.misoenergy.org/20260420%20LLWG%20Item%2001c%202026%20LLWG%20Charter_Draft75085\n8.pdf. \n21  Attachment X defines Large Load Addition Resource Study (LARS) as “the procedure as set forth in Section 3.12 \nof this GIP for studying an Interconnection Customer’s proposed Generating Facility in parallel with the study of \na LARS Associated Load Customer’s proposed load.” See Section 1 of Attachment X. \n22  Motion of the Midcontinent Independent System Operator, Inc. and the MISO Transmission Owners to Hold \nProceeding in Abeyance and Request for Shortened Comment Period and Expedited Treatment, Docket No. \nEL26-70-000 (Aug. 3, 2026) (“Abeyance Motion”)."},{"page":6,"startToken":2290,"endToken":2790,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 6 \n \n \n \nthe LARS Application and provides a framework for participation by the entities involved in the \nexisting MISO processes that LARS builds upon.  \n \nThere are four primary types of entities involved in implementing LARS aside from MISO. \nThese are the LARS Associated Transmission Customer, the Interconnection Customer(s) who will \nown or operate the Generating Facility, the applicable Transmission Owner, and the \nowner/controller of the ultimate load (called the “LARS Associated Load”).  To understand how \nLARS will work, a brief explanation of each of these parties’ roles in the process is provided below.   \n \nThe first of these parties is the LARS Associated Transmission Customer.23  This is the \nentity that procures Transmission Service for load and has a direct relationship with the load.  This \nis often a Load Serving Entity (“LSE”).  Because only the Transmission Customer can procure \nTransmission Service under established Tariff processes, LARS requires the LARS Associated \nTransmission Customer to be the party that initiates the LARS Application and obtains the \nresulting Transmission Service.24  Ultimately, the LARS Associated Transmission Customer acts \nas a coordinator between the other entities involved in the LARS process.  \n \nSecond, there is the Interconnection Customer.  This is the entity that will complete the \nsection of the LARS Application that supports the generation portion of the LARS study, will be \nresponsible for meeting the requirements of Attachment X pertaining to the generation study, and \nwill receive Interconnection Service under an LLGIA.  The Interconnection Customer can be any \nentity (including an Independent Power Producer (“IPP”)) whose Generating Facility will provide \nEnergy for the LARS Associated Load provided it is permitted by applicable laws and regulations \nto do so.25  The Interconnection Customer has the contractual relationships required by LARS to \nshow that the Generating Facility is in fact paired with the LARS Associated Load.26   \n \nThird, the Transmission Owner owns the facilities the LARS Associated Load will connect \nto the Transmission System.  The Transmission Owner works with the other parties to establish \nthe Point of Interconnection (“POI”) for the Generating Facility(ies) and the Point of Withdrawal \n \n23  In GIP Section 1 of Attachment X, a LARS Associated Transmission Customer is defined as “the entity that is \nresponsible for submitting the LARS Application and procures Transmission Service in order to serve LARS \nAssociated Load and designates such load as formally paired with an Interconnection Customer’s LARS \nInterconnection Request.” \n24  See GIP Section 3.12.1.  \n25  Interconnection Customer is defined as “any entity, including Transmission Provider, Transmission Owner or any \nof the Affiliates or subsidiaries of either, that proposes to interconnect its Generating Facility with the \nTransmission System.  For the purposes of Large Load Addition Resource Study (LARS), Interconnection \nCustomer shall refer to the entity developing the Generating Facility that will execute the LLGIA, which may be \na different entity from the LARS Associated Transmission Customer that submitted the LARS Application.” See \nGIP Section 1 of Attachment X. \n26  See GIP Section 3.12.2(i)."},{"page":7,"startToken":2790,"endToken":3318,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 7 \n \n \n \nfor the LARS Associated Load and has the responsibility to construct Network Upgrades (subject \nto applicable Tariff rules that are not changed by this filing).27  \n \nThe fourth key participant is the entity that owns or controls the LARS Associated Load, \nwhich for purpose of LARS must be a large load of at least 200 MW.28  While MISO usually will \nnot have a direct relationship with this entity and does not purport through this filing to impose \nobligations directly on them, this entity will have a crucial role in establishing relationships \nbetween the parties directly involved in LARS, in supplying information necessary to complete \nthe LARS Application, and study process, and in enabling the other parties to meet their obligations \nunder LARS.   \n \nAs noted above, the roles of these parties and their specific responsibilities reflect existing \nTariff requirements and practices.  LARS does not seek to fundamentally change the established \nroles of the entities participating in the load and generation studies but rather seeks to coordinate \nthem.  LARS thus provides for faster and more transparent interconnection arrangements for large \nloads with paired generation, while offering customers speed-to-power, optimized transmission \nsolutions, and greater certainty to support siting, and financing of large load projects.  The outcome \nof the LARS process is MTEP approval of transmission required to reliably facilitate the \nwithdrawal of the load and corresponding injection rights for the proposed generation. The \ncomponent parts of the process are discussed in greater detail below.  \n \nC. \nTHE LARS APPLICATION \nMISO is establishing a single application process for the participants in the LARS process.  \nThe LARS Application will be a single submission consisting of materials required by Attachment \nFF for the load and Attachment X for the generation.29  Because LARS involves two separate study \nprocesses being completed concurrently and in parallel, all the relevant parties to the load and \ngeneration pairing must apply together.30  While the LARS Application process may only be \ninitiated by the LARS Associated Transmission Customer, the Interconnection Customer, the \nTransmission Owner, and the LARS Associated Load customer must all complete the required \ninformation as part of the application before it will be reviewed by MISO.  Independent Power \nProducers and other kinds of Interconnection Customers are not prohibited from participating in \n \n27  See GIP Section 3.12.1. \n28  The LARS Associated Load is defined as the “source of electrical load that is at least 200 MW and that is formally \npaired with one or more Interconnection Customer(s) that have submitted an Interconnection Request to LARS \nproposing one or more new Generating Facility(ies) to provide energy to such load.” See GIP Section 1 of \nAttachment X.  \n29  The LARS Application is defined as “a single submission consisting of the materials required for LARS \nprocessing as required by Section I.D.1.b.ii of Attachment FF to the Tariff as well as the information required for \nstudying the Generating Facilities under this Attachment X (in the form of Appendix 1) to these generator \ninterconnection procedures. For purposes of this GIP, a LARS Application shall be a form of Interconnection \nRequest.” \n30  See Drake Testimony at 17-18."},{"page":8,"startToken":3318,"endToken":3864,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 8 \n \n \n \nthe LARS process.31  The LARS Application will also serve as a repository for all information \nrequired by the load and generation study processes.  A non-refundable fee of $250,000 must \naccompany the LARS Application and be paid by the LARS Associated Transmission Customer.32   \n \nNotably, MISO is establishing a “pre-submission coordination process” that LARS \napplicants must participate in prior to submitting a LARS Application.33  This coordination process \nrequires the potential LARS Interconnection Customer and the Transmission Owner to meet and \nagree on a definitive Point of Interconnection for the proposed LARS Generating Facility.  Forty-\nfive days prior to a LARS Application deadline, a potential LARS Interconnection Customer must \nnotify the Transmission Owner to whose Transmission Facilities the potential LARS \nInterconnection Customer proposes to Interconnect of its plans to participate in LARS.  After \nreceiving a request to meet from any potential LARS Interconnection Customer, the Transmission \nOwner must meet with them and any other impacted parties necessary to determine a definitive \nPOI within ten business days after receiving a request for the meeting.  The parties must jointly \nagree on a feasible POI no later than ten business days prior to the next LARS Application deadline \nas published on MISO’s website.  An attestation from the Transmission Owner stating that it has \nan agreed POI with the LARS Interconnection Customer(s) must be included in the LARS \nApplication.34  \n \nMISO is proposing these pre-submission coordination activities for several reasons.  First, \nwhile the LARS Associated Transmission Customer is the only party that may submit the LARS \nApplication, MISO is requiring that they actively participate in the LARS process with the \npotential LARS Interconnection Customers prior to LARS Application deadline.  Second, \nrequiring pre-submission coordination activities will increase the efficiency of reviewing the \nLARS Application with all the relevant parties identified, the agreed upon POI identified, and other \nnecessary details have already been determined by the time the LARS Application is submitted to \nMISO.  Having the LARS Application parties agree on many of these necessary details in advance \nof submission will also help avoid future disagreements or changes, which can lead to unnecessary \nor late withdrawals from the study process.  MISO has heard from stakeholders and learned from \nexperience that an accelerated study process requires that the relevant participants have \ncoordinated and agreed upon key details (such as the location of the POI) up front and not after \nthey have submitted their application. Third, requiring coordination meetings between these parties \nwill assist them with identifying any other relevant parties who may need to participate in the \nLARS process.  Ms. Drake explains that to effectively facilitate the speed of the LARS study \nprocess, MISO needs all relevant parties to the load and generation pair to not only be identified \nat the outset but committed to working together.35  \n \n31  Id. at 18-19.  \n32  See GIP Section 3.3.1 (“A LARS Application for the Large Load Addition Resource Study shall be accompanied \nby a Non-Refundable Deposit 1 (D1) of $250,000 submitted by the LARS Associated Transmission Customer.”). \n33  See GIP Section 3.12.1 and Section I.D.1.b.ii(a) of Attachment FF.  \n34  See Drake Testimony at 20; GIP Section 3.12.1. \n35  Drake Testimony at 19-20."},{"page":9,"startToken":3864,"endToken":4435,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 9 \n \n \n \n \nMISO will accept LARS Applications on a rolling basis, and the applications will be \nqueued on a serial, time-stamped basis based on time of submission to the LARS process.  There \nwill be three LARS study periods each year and each study period will be completed in \napproximately 120 days, as explained by Ms. Drake.36  MISO will accept ten LARS Applications \nper study period and the LARS Applications will be assigned to study periods in order of \nsubmission.  Customers interested in joining the next LARS study period must submit their LARS \nApplication to MISO no later than 20 business days prior to the scheduled kick-off of the LARS \nstudy period as published on the MISO public website.  MISO will keep an open queue of LARS \nApplications and will replace any LARS Application that withdraw prior to study kick off with the \nnext submitted generation/load pair not included in the current study period.  Once the LARS study \nprocess has kicked off for a specific LARS generation/load pair, then that spot is lost for the LARS \nstudy period it is part of even if the pair later withdraws during the study process.37   \n \nAn Interconnection Request included in a LARS Application must be accompanied by an \nexecuted agreement between the Interconnection Customer and either the LARS Associated \nTranmission Customer or the entity that owns or controls the LARS Associated Load.  The \nagreement must demonstrate that the output of the LARS Generating Facility will serve the LARS \nAssociated Load.  The agreement must be legally binding and must state a minimum term of five \nyears so that if any transmission solutions need to be developed, there is sufficient time to work \nthrough the processes for development.  As described in Section 3.12.2(i) of Attachment X, the \nagreement must be in the form of a power purchase agreement (“PPA”) or similar off-take \nagreement, a Build-Own-Transfer Agreement, or any other kind of agreement used by Load \nServing Entities including a special contract, a large load tariff agreement, or a retail service \nagreement.  Ms. Drake explains that in response to stakeholder feedback, MISO revised the Tariff \nredlines to explicitly state the agreement can be executed between the generator and large load. 38 \nThis does not supersede the role of the LARS Associated Transmission Customer to determine \nwhether to submit a LARS Application but does allow flexibility for different types of agreements \nthat are consistent with state law and supported by the parties.39  MISO also added the third \nagreement option to incorporate specific utility arrangements with large loads that are not \ntraditional PPAs to link the generation and load.40   \n \n \n36  See id. at 13. \n37  For example, if MISO holds the LARS study kick-off calls for all ten generation/load pairs and one of the pairs \nwithdraws the following week, MISO will not move up another pair into that study cycle since the study process \nhad already commenced.  If the generation/load pair withdraws shortly before the LARS study kick-off call, then \nMISO would move the next LARS generation/load pair into that study cycle.  \n38  MISO, Large Load Working Group (“LLWG”), Generation and Large Load Alignment, LLWG-2026-6, MISO \nResponse to Feedback at 8, (Sep. 28, 2026), available at: \nhttps://cdn.misoenergy.org/LLWG%20Large%20Load%20Addition%20Resource%20Study%20Response%20(\nLLWG-2026-6)%20(20260827)784877.pdf \n39  Drake Testimony at 31-32. \n40  See id."},{"page":10,"startToken":4435,"endToken":5009,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 10 \n \n \n \nOther requirements of the LARS Application include limiting the Interconnection Requests \nto NRIS, limiting the amount of requested Interconnection Service to no more than 150% of the \npeak demand of the LARS Associated Load, and demonstration of 100% site control for the POI \nincluding a one-line diagram demonstrating the Generating Facilities and any associated electrical \nequipment required.41  Based on stakeholder feedback MISO established the 150% of \nInterconnection Service limitation to ensure the generation is required to reliably serve the load \nwithin the same LRZ.  As Ms. Drake states, MISO sought to establish a closer connection between \nwhat is needed by the LARS Associated Load and what is being proposed by the LARS \nInterconnection Customer.42  Thus, MISO implemented this requirement to directly connect the \nGenerating Facility with the LARS Associated Load and to allow for different generator fuel types \nand accreditation.  Ms. Drake explains that “this requirement establishes a clear connection \nbetween the output of the Generating Facility and the load without being overly prescriptive on \ngeneration fuel type, dispatch requirements, or other operational considerations.”43 \n \nAnother important condition of the LARS process is the requirement that the load and \ngeneration pair be located in the same Local Resource Zone (“LRZ”).44  The Point of \nInterconnection(s) specified in a LARS Application must be located in the same LRZ as the Point \nof Withdrawal (“POW”) of the LARS Associated Load.  As discussed by Ms. Drake, the intent of \nthe LARS process is to identify an optimized Network Upgrade solution for both the load and \ngeneration, and MISO retains that flexibility in the LRZ because it aligns with MISO’s Resource \nAdequacy construct.45  Specifically, MISO does not have a requirement that loads bring generation, \nbut through the proposed LARS process, by restricting the Point of Interconnection(s) specified in \na LARS Application to be located in the same LRZ as the Point of Withdrawal, MISO providing \nan incentive for Load to bring Generation in a manner that maximizes the positive impact this \nGeneration has on Resource Adequacy.  MISO recognizes there are other ways it could have \nlimited the pairing such as requiring the generation and LARS Associated Load to be located in \nthe same Local Balancing Authority area or through requiring that the location of the Generating \nFacilities be within a specific number of substations of the LARS Associated Load.  However, \nlimiting the pairing of Generating Facilities and LARS Associated Load to the same LRZ strikes \nan appropriate balance between accommodating large, landlocked LARS Associated Loads that \nmay need additional POIs to propose sufficient Generating Facilities needed to serve that load.  \nLimiting the proximity of the Generating Facilities and LARS Associated Load provides a solution \n \n41  See GIP Section 3.12.2.  \n42  See Drake Testimony at 29. \n43  Id.  \n44  Attachment X defines Local Resource Zone (LRZ) as the “geographic area within the Transmission Provider \nRegion that is prescribed by the Transmission Provider, based upon the criteria in Section 68A.3, to address \ncongestion that limits Planning Resource deliverability.” An LRZ is the smallest geographic area defined by \nMISO for planning and market purposes and it is used to allocate resource adequacy requirements, capacity \nbenefits, and reliability needs based on transmission constraints, electrical boundaries, and local reliability \nrequirements. LRZs are used in the Planning Resource Auction (“PRA”) as well as for allocating the Planning \nReserve Margin (“PRM”) requirement.  \n45  See Drake Testimony at 40."},{"page":11,"startToken":5009,"endToken":5507,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 11 \n \n \n \nthat is not overly restrictive and is consistent with MISO’s resource adequacy construct by ensuring \ndeliverability of the Generating Facilities to LARS Associated Load within the same LRZ.   \n \nMISO is proposing to increase flexibility in the LARS process by allowing a LARS \nAssociated Load to be served by multiple Generating Facilities under specific circumstances.  \nFirst, all Generating Facilities serving a LARS Associated Load must be included and identified \nin the same LARS Application and must request a minimum of 200 MW of Generator \nInterconnection Service in aggregate.  Second, a LARS Associated Load may be served by more \nthan one group of Generating Facilities located at different POIs, but a separate LARS Application \nmust be submitted for each POI group of Generating Facilities.  Stated differently, each group of \naggregated LARS Generating Facilities at a single POI must submit a separate LARS Application.  \nEach LARS Application must identify the total amount of load requested by the LARS Associated \nLoad and must identify every Generating Facility providing power to that load.46  While MISO is \nallowing aggregation for LARS Generating Facilities, MISO is not allowing aggregated load to \nparticipate in LARS.  As explained earlier, MISO developed LARS in the context of dramatic large \nload growth and created the LARS process to help address that growth.  Ms. Drake explains that \nlimiting LARS load participants to at least 200 MW at one POW ensures that the load coming \nonline is sufficiently large to warrant inclusion in LARS and is not a large group of small loads \nbanded together.47   \n \nWhile the LARS Application requirements are expected to reduce the number of \nspeculative projects submitting applications, they provide enough flexibility to enable these large \nloads to connect to the system.  As Ms. Drake explains in her testimony, ensuring that only \ncommercially viable and shovel ready projects enter LARS is a necessary prerequisite to running \nthese extremely fast serial studies because each LARS study must be able to rely on the Network \nUpgrades resulting from previously completed LARS study actually being developed.48  Thus, the \nstrict entry requirements for LARS both support its intended benefits while also underscoring that \nLARS is not, and should not be, a replacement for the DPP.49  Rather, it is intended to be a narrowly \nscoped but powerful process.   \n \nD. \nTHE LARS STUDY PROCESS \nThe requirements of the LARS generator interconnection study process are outlined in \nSection 3.12.2 of Attachment X.  Based on principles established in ERAS, the LARS generation-\nside study will provide a Large Load Generator Interconnection Agreement (“LLGIA”) in \napproximately 120 days and will be a permanent MISO study process.  Similarly, the load process \nwill start the approval process after a 90-day study process.  While the LARS generation and load \nstudies are completed separately and in parallel, they both start with the same overall base \n \n46  See id. at 23, 30.   \n47  See id. at 24-25. \n48  See id. at 9-11. \n49  See id. at 12."},{"page":12,"startToken":5507,"endToken":5996,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 12 \n \n \n \nconfiguration system including both MTEP and GIA projects in their models.50  On top of that \ncommon base model, MISO then adds the LARS generation, load, and the proposed transmission \nsolutions to study all three components together.  Ms. Drake explains how this allows for both the \ngeneration and load studies to have a fuller picture of system impacts than would be possible if \neach was studied in isolation, enabling greater efficiency in Network Upgrade identification.51  The \nload and generation studies will be completed at approximately the same time.52  MISO designed \nthe LARS process to ensure the proposed load and generation pair is evaluated to the same \nstandards as those submitted separately through MISO’s other existing processes (i.e., MTEP/EPR \nand ERAS).   \n \n1. THE GENERATION STUDY \nFor each LARS study period, the individual generation/load pairs will be studied in one \nmodel, and MISO will have ten models that represent those ten generation/load pairs.  MISO will \ncomplete these studies individually and in a serial fashion based on their submission date.  This \nallows MISO to look at any generation or load violations individually and together with the results \nfrom the load side study as explained by Ms. Drake.53  Then any common violations that show up \nin the generation and load studies are assigned to BRP and Other project types.  Only the violations \nbut for the generator are assigned GIP project types.54  \n \nAs MISO explained to stakeholders in the LLWG, all studies begin with the MTEP models \nas a base to contain consistent topology, generation, and load assumptions.55  The LARS model \nbuild will include all Existing Generating Facilities, including those from completed DPP cycles, \nthe ERAS process, and the latest MTEP base case with all approved MTEP projects as well as any \nrecently approved EPR projects.  This is the same process utilized for the DPP process except the \nDPP models include all higher queued Interconnection Requests from earlier cycles and all \nInterconnection Requests within that DPP cycle.  As Ms. Drake explained, “LARS studies will not \ninclude Interconnection Requests currently in the generator interconnection queue that do not have \nan executed GIA.”56  MISO has designed the LARS study this way to reduce the number of \nspeculative projects in the modeling process.  Thus, on the generation study side, MISO is \nanalyzing whether there are enough pathways and requested Network Service to allow the \ngenerator to integrate into the system.  On the load study side, MISO is analyzing the cumulative \n \n50  Id. at 13-14. \n51  Id. at 14-15. \n52  Id. at 26. \n53  Id. at 14-16. \n54  See id. at 15-16. \n55  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Large Load Addition Resource \nStudy (LARS) presentation at 5 (Sep. 23, 2026), available at: \nhttps://cdn.misoenergy.org/20260923%20LLWG%20Item%2006%20Large%20Load%20Addition%20Resourc\ne%20Study%20(LLWG-2026-6)782864.pdf. \n56  Drake Testimony at 29."},{"page":13,"startToken":5996,"endToken":6495,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 13 \n \n \n \nimpacts of adding the large loads to the system and identifying common issues solutions.  Notably, \nMISO will not limit the study process to the specific LRZ the generation/load pair will be located \nin – this requirement is solely for the pairing of the load and generation.57  MISO will look at the \nfull impacts of the generation/load pair on MISO’s Transmission System using the same study \ncriteria and processes applicable to NRIS evaluations of other Interconnection Requests.   \n \nAs a result of the way MISO’s study models are structured, LARS projects will not impact \nexisting projects in the DPP process.58  LARS Interconnection Requests will not be included in \nongoing DPP studies and therefore will not utilize any available transmission capacity in those \nstudies.  Any Network Upgrades approved through the LARS process will be reflected in later \ncycles and may mitigate constraints that would otherwise be identified there.  Thus, LARS cannot \nimpact ongoing DPP cycles and, to the extent that LARS projects could impact future cycles, such \nimpacts would only be positive.59  In the event that overallocation does occur, any constraints that \nare identified as needing mitigation in the MTEP process will be formalized in a future MTEP \nproject.60  The cost of the MTEP project will be allocated based on existing Tariff rules, which is \nlikely to be the load within the transmission pricing zone where the transmission upgrade is \nrequired.  This cost shift is consistent with MISO’s existing processes.  The Interconnection \nCustomer will be responsible for all Network Upgrades identified in the LLGIA as GIP project \ntypes even if it later withdraws from LARS.61  Ms. Drake explains that this is necessary both to \nensure commitment from those entering the LARS process and provide certainty to the other \nprocesses (including later LARS and DPP studies) that will include facilities identified through \nLARS in their starting models.62  \n \nAt the end of the LARS process, the generator will receive a LLGIA to generate up to 150% \nof identified MW need of the LARS Associated Load.  \n \n2. THE LOAD STUDY \nThe requirements of the LARS load interconnection study process are outlined in Section \nI.D.1.b.ii of Attachment FF.  For each LARS study period, all ten generation/load pairs will be \nrepresented in one model, and MISO will complete ten separate studies in that one model.63  The \nLARS load study process is built upon MISO’s existing EPR process and requires similar \n \n57  Id. at 4 (“Completing the generation and load studies in parallel allows MISO to see the full impacts on the system \nwith each different configuration, which enables MISO to identify solutions for both the generation and load \nsides.”). \n58  See Drake Testimony at 32-33.  \n59  Id. at 33. \n60  Id.  \n61  Id. at 37-38. \n62  Id. at 15-16. \n63  Id. at 14 (“All ten generation/load pairs will be represented in one model, and MISO will complete ten separate \nstudies in that one model.”)."},{"page":14,"startToken":6495,"endToken":7083,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 14 \n \n \n \ninformation.  MISO’s load study process focuses on accounting for cumulative impacts of the \nproposed loads and the coordination with affected systems.  The transmission reliability studies \nwill employ a format including all other submitted EPRs and LARS projects to ensure the \ncumulative impacts of the load and transmission are observed.  The Transmission Owner’s initial \nset of transmission solutions are identified and submitted to MTEP.  This allows MISO to view \nand analyze the full spectrum of contingencies across timeframes and processes.64   \n \nFirst, MISO will complete a load model build with the proposed LARS generators.  Then \nMISO will review the proposed LARS projects with reliability assumptions and determine if any \nconstraints are identified. This process includes reviewing the outage of the generator in the study. \nAfter completing a load and generation constraint review, MISO will determine whether there are \nany common issues solutions. A planning level solution is established at the end of the load study \nprocess.  While completing the study, MISO is looking to determine whether the available \ngeneration and transmission pathways can reliably serve the LARS Associated Load without \nnegatively impacting the rest of the transmission system.  As Ms. Drake explains, MISO is looking \nat different scenarios and conditions within the load model to ensure that the load can be reliably \nserved under a variety of circumstances.65  By including every load for that LARS study period in \none model, MISO is able to look at the cumulative impacts and reduce the risk that multiple \ntransmission projects will need to be developed.  Any cost impacts from the study outcomes will \nbe assigned to Baseline Reliability Projects and Other type projects.66  In addition, a pro forma \ncost shifting agreement will need to be executed and any new terms in transmission services \nagreements will need to be met.  MISO notes that it is continuing to work with stakeholders through \nthe LLWG to develop the pro forma cost shifting agreement and any necessary terms for \ntransmission service for large loads, all of which will be submitted to the Commission in a FPA \nsection 205 filing by November 16, 2026.  \n \nThe proposed Attachment FF updates reinforce the core requirement of generator \ncommitment to LARS, other MISO processes require that a GIA must be executed before a \nresource can be included in the load study models as it provides the necessary certainty for the \nload planning process.  In the LARS study process, MISO includes the paired generator in the \nLARS load study even though it will not have an executed GIA at the time of study.  This pairing \nof load and generation for a parallel process supports or facilitates identification of a more efficient \nand potentially more cost-effective set of Network Upgrades than would be possible if the \ngeneration and load were studied in isolation and acknowledges the increasing number of projects \nthat require coordinated evaluation.  In addition, the cost allocation hierarchy—transitioning from \nGIP to BRP when appropriate—supports procedural alignment and simplifies outcomes when \ncommon constraints lead either to BRP designation or another path.  \n \n64  Id. at 14-15, 25. \n65  Id. at 25. \n66  Id. at 27-28. MISO’s proposed Tariff language is sufficient to categorize these costs as BRPs or Other project \ntypes, with cost responsibility flowing from such designation under existing rules.  The LARS structure is \ncompatible with these agreements and MISO will incorporate them into LARS once they are accepted. However, \nLARS can be implemented based on the Tariff revisions filed herein and need not await these future filings."},{"page":15,"startToken":7083,"endToken":7599,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 15 \n \n \n \n \nE. \nCOORDINATED LARS STUDY PROCESS \nThe LARS process builds off the existing EPR and ERAS processes but improves upon \nthem by integrating planned load with the generation, which enables the identification of more \noptimal Network Upgrades.  If MISO knows a large load is coming, which it will in the LARS \nprocess, then MISO can study the load’s impacts with greater certainty and reduce the risk of \nspeculative generation or load.  By running the generation and load studies in parallel, MISO is \nable to review constraints identified on both the load and generation sides and can see the impacts \nto the system with each different configuration.  This information can then inform the transmission \nnetwork upgrades that are solutions for the transmission needs identified in the load and generation \nstudies.  MISO can also bring Sugar-developed solutions to the Transmission Owner and \nInterconnection Customer for coordination.67   \n \nThe goal of LARS is not necessarily to find the lowest cost solution for either the load or \ngeneration but to identify the solution that best fits both the generation and load needs at the lowest \ncost.  MISO expects LARS to produce more cost-effective solutions that are more efficient for the \ngrid overall.68  This allows MISO to combine solutions between the load and generation side for \nmore optimal, efficient, and effective responses.  MISO can then come up with more effective \nsolutions to help integrate load and generation into the system, which maximizes the benefits of \nboth study processes and reduces integration costs.  Thus, as Ms. Drake explains, the LARS \nprocess enables MISO to optimize solutions for the transmission grid to reduce costs overall while \nalso maintaining reliability.69   \n \nThe LARS Application must identify a Commercial Operation Date for the Generating \nFacility and a Load In-Service Date for the LARS Associated Load that is no later than three (3) \nyears from the date the LARS Application is submitted.70  The load can start receiving service for \nless than the full amount of transmission service requested (start receiving service in phases), but \nmust commence service for the full amount of transmission service requested in LARS Application \nno later than the Generating Facility’s COD.  While the load is operating at less than the full amount \nof service, the Generating Facility must remain subject to the Annual ERIS (“AERIS”) and the \nQuarterly Operating Limit (“QOL”).  Thus, once the LLGIA is executed, some amount of the \nLARS Associated Load must be in-service before the Generator can come online.  The Generator \nmay not come online prior to the LARS Associated Load coming in service.   \n \n \n67  MISO uses an integrated modeling software Suite of Unified Grid Analyses with Renewables (“SUGAR”), for \nPhase 1 and Phase 2 DPP studies with plans to integrate it in Phase 3.  The SUGAR software leverages powerful \ncircuit simulation methods developed to study billion-transistor electronic systems. SUGAR reduced DPP phase \n1 cycle time significantly from the status quo as evidenced in the DPP 2022, 2023 and 2025 cycles. \n68  See Drake Testimony at 4. \n69  Id. at 10-12. \n70  See GIP Section 3.12.9."},{"page":16,"startToken":7599,"endToken":8112,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 16 \n \n \n \nTo encourage certainty and facilitate optimized transmission solutions, MISO is requiring \nthat the generation and load commit to remain contractually paired for a minimum of five years at \napplication, which coincides with MISO’s planning horizon.71  This requirement thus enables \nMISO to rely on the pairing of the Generating Facility and LARS Associated Load in conducting \nits planning.  This application and study processing requirement is separate from the obligation to \nremain paired for a fifteen-year period.  As described below, LARS requires that the generation \nand load remain paired for a minimum of fifteen years.  However, MISO acknowledges that it may \nbe difficult to obtain a commercial agreement for such a period at time of LARS Application \nsubmission.  Requiring that the commercial agreement specify at least a 5-year term at application \nallows some flexibility to renew the contract between the paired load and generation during the \noperational life of the generation and load while still ensuring a significant, upfront commitment \nto even be studied in the LARS process.  \n \nIf either the load or generation portion withdraws after the LARS study is completed, the \nLLGIA is void and non-refundable deposits are forfeited.  There will be no restudy with the LARS \nprocess.  Notably, if either of the parties terminate a LLGIA, withdraw the load after MTEP \napproval, cease use of the Transmission Service granted through LARS, or terminate their \ncommercial agreement after notice to proceed, the parties will be responsible for all assigned \nNetwork Upgrades costs. The Interconnection Customer remains responsible for any identified \nGIP Network Upgrades and the LARS Associated Transmission Customer remains responsible for \nany identified BRPs or Other assigned Network Upgrades.  Moreover, the LARS Associated Load \nwould then need to be studied through the applicable MTEP process to maintain service.72  \n \nIf the LARS Associated Load is withdrawn, ceases use of the Transmission Service granted \nthrough LARS, or the commercial agreement between the generation and the load terminates \nduring the first fifteen years after the date that the LARS Associated load commences use of the \nTransmission Service granted through LARS, then MISO will terminate the LLGIA after a limited \noperations transition period and Interconnection Customer would need to obtain new \nInterconnection Service through the DPP to continue making injections onto the MISO \nTransmission System.73  Both the 15-year commitment period and the limited operations transition \nprocess are important design features that warrant further discussion. \n \nWith respect to the requirement to remain paired and in service for fifteen years, MISO \ndetermined that requiring both the Generating Facility and LARS Associated Load to remain in \nservice and retain their relationship provided important safeguards.  This requirement ensures that \nthe LARS study process accurately reflects the expected impacts of the Generating Facility and \nLARS Associated Load on the Transmission System for a significant period of time.  It also serves \nto prevent customers from gaming or otherwise misusing the LARS process to obtain \nInterconnection Service not intended for long-term service to a specific large load.  Along with \n \n71  See Drake Testimony at 35. \n72  Id. at 36-37. \n73  Id."},{"page":17,"startToken":8112,"endToken":8640,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 17 \n \n \n \nthese considerations, MISO also weighed stakeholders’ legitimate concerns that Generating \nFacilities submitted to LARS in good faith and which in fact served LARS Associated Loads for \nlong periods of time could should not be forced to go offline or undergo a second study process \nwith potentially significant new costs if the LARS Associated Load unexpectedly ceased \noperations more than a decade into the relationship.  Several stakeholders also expressed concerns \nthat a permanent pairing requirement would strand a Generating Facility that had a remaining \nuseful service life even if such Generating Facility could be used—or was needed—to address \nresource adequacy needs following the departure of the LARS Associated Load.  These discussions \nconvinced MISO that that a permanent pairing requirement would not only create significant long-\nterm commercial risk to the LARS Interconnection Customer but that such a risk could create \nchallenges to funding LARS projects that would otherwise be beneficial.   \n \nBased on these discussions, MISO considered the implications of several potential time \ndurations for the pairing requirement before determining that a fifteen-year pairing requirement \nfor the generation and load struck the best balance between ensuring LARS was used as intended \nand enabling long term commercial certainty for Interconnection Customers.   MISO reached this \nconclusion for several reasons.  First, fifteen years is a standard duration for large load contracts \nand thus a fifteen-year commitment aligns with contracting timeframes.  Second, fifteen years is a \nsufficiently extensive period to deter entities from invoking the needs of a specific large load as a \npretext to bypass the DPP queue and receive unrestricted Interconnection Service on an accelerated \ntimeline.  This positions the DPP as the more flexible and lower risk option for Generating \nFacilities with all but the firmest long-term relationships with a large load. Finally, the fifteen-year \nperiod provides an outer limit on Interconnection Service risk that increases the commercial \nviability of LARS and avoids the potentially negative resource adequacy implications of imposing \na permanent limitation with effects that would become known only beyond the reasonable \ncommercial and planning horizon visible at the time LARS commercial arrangements are made.  \n \nWith respect to the transition period, MISO will provide the Generating Facility up to one \nyear after the LARS Associated Load withdraws to continue to operate under the LLGIA in order \nto provide time for the Interconnection Customer to enter the DPP and obtain new NR \nInterconnection Service.74  MISO further proposes that this period would be extended for the \nduration of a DPP cycle if the Interconnection Customer submits an Interconnection Request for \nDPP processing and remains in such DPP cycle through to GIA.  Operations during this transition \nperiod would be subject to MISO’s Quarterly Operating Limits (“QOL”) and Annual ERIS \n(“AERIS”) processes to ensure reliability.75  MISO developed this transition period to mitigate the \nimpacts to a Generating Facility whose LLGIA must be terminated within the first fifteen Calendar \nYears after the LARS Associated Load commences use of the Transmission Service granted \nthrough LARS.  The limited transition period also prevents adverse reliability impacts from \noperating the Generating Facility without the LARS Associated Load online and is consistent with \n \n74  Id.  \n75  Id."},{"page":18,"startToken":8640,"endToken":9105,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 18 \n \n \n \nthe requirement to obtain new Interconnection Service because it provides only a temporary bridge \nto avoid immediately taking the Generating Facility offline.  While MISO fully expects that future \nDPP cycles will be completed within one year, MISO added the automatic extension as a safeguard \nagainst DPP delays. Because the automatic extension only lasts for as long as the Interconnection \nCustomer maintains its Interconnection Request in the DPP and meets the progressively increasing \ncommitments required by that process, this extension would not provide a useful stalling \nmechanism for Interconnection Customers that is not actively seeking new Interconnection \nService. \n \nAfter 15 years, it is reasonable to allow the Interconnection Service granted through the \nLLGIA to remain even if the LARS Associated Load subsequently leaves service.  This allowance \naddresses the need for commercial certainty for the Generating Facilities participating in LARS \nand helps reduce any reliability impacts that may be associated with immediately terminating the \nLLGIA if the load were to go offline.  This also reflects the purpose of LARS as providing a process \nfor formally paired generation and load to be studied together and connect to MISO’s Transmission \nSystem efficiently and effectively.  Ultimately, the outcome of the LARS process is MTEP-\napproved transmission for reliable load integration into the system, the allocation of LLGIA \ngeneration interconnection service, a more optimized set of Network Upgrades within \napproximately 120-days, and generation/load pair that has agreed to remain paired within same \nLRZ for a minimum of fifteen years.  \nIII. \nTHE PROPOSED REVISIONS ARE JUST AND REASONABLE \n \nThe LARS proposal and its corresponding Tariff changes are just and reasonable.  LARS \nprovides a valuable tool to enable the study of LARS Associated Loads that are brought to MISO \nwith a paired generation solution.  LARS meets the urgent need for an accelerated evaluation \nprocess that accounts for both load and generation, responds to concerns identified in the Show \nCause order regarding proximity between large loads and their associated generation, and does not \ndisturb existing DPP processes.  The LARS process is not unduly discriminatory to any potential \nmarket participant and respects existing roles and responsibilities.  LARS brings together several \nindependent MISO processes needed to integrate a new large load.  Through the LARS \nApplication, MISO has established a framework that allows different stakeholders to proactively \ncoordinate the addition of these generation/load pairs onto the system.  The result is an accelerated \nprocess that allows for the integration of generation/load pairs and optimized transmission \nsolutions.  \n \nA. \nLARS COMPLEMENTS OTHER COMPONENTS OF MISO’S LARGE LOAD \nFRAMEWORK  \nThe need to accelerate reliable power infrastructure is reflected in the DOE’s Speed to \nPower initiative.  DOE launched Speed to Power in September 2025 as an effort to accelerate \ndevelopment timelines for large-scale transmission and generation projects and ensure sufficient"},{"page":19,"startToken":9105,"endToken":9602,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 19 \n \n \n \npower to meet rising electricity demand.76  On June 18, 2026, the Commission issued the Show \nCause Order addressing MISO’s Tariff provisions governing the interconnection of large loads.77  \nThe Commission preliminarily found that aspects of MISO’s existing Tariff may be unjust and \nunreasonable and identified potential reforms concerning the integration of large loads and \nassociated generation.78  Of particular relevance to LARS, the Commission addressed the absence \nof generator interconnection procedures and services designed to facilitate the interconnection of \ngeneration brought onto the transmission system to serve electrically proximate large loads.79  The \nCommission also addressed the electrical relationship between a large load and generation \nintended to serve that load.80 \n \nLARS is responsive to the Commission’s focus on the coordinated consideration of \nsignificant new load and generation.  At the July 16, 2026 LLWG meeting, MISO first introduced \na new proposal designed to align the study processes for new large loads and generation intended \nto serve those loads.81  Certain stakeholders described MISO’s proposal as allowing load and \ngeneration to be studied in parallel using consistent assumptions, thereby addressing timing \nmismatches between existing study processes.82  MISO subsequently developed that concept into \nLARS and has included it within its broader large load framework.  While LARS is an independent, \nstandalone process and does not need the other parts of the framework to proceed as explained by \nMs. Drake, it is complementary to other proposals in MISO’s large load framework.83  While the \nZGIA process addresses the generator interconnection service and study framework for generation \nserving co-located load, LARS will address the distinct study issues presented by new generation \nand large load that are electrically proximate but are not eligible for ZG Interconnection Service.  \n \nLARS is intended to work in concert with MISO’s broad large load framework by \nfacilitating the coordinated study of qualifying large load additions and associated generation while \n \n76  DOE, Speed to Power Initiative (Sept. 18, 2025) (describing Speed to Power as an initiative to accelerate \ndevelopment timelines for large-scale transmission and generation projects to meet rising demand for reliable and \nsecure energy). \n77  Midcontinent Indep. Sys.  Operator, Inc., 195 FERC ¶ 61,212 (2026) (“Show Cause Order”). \n78  Id. \n79  Id. at P 117 (expressing concern that the absence of such procedures and services could result in MISO’s generator \ninterconnection process failing to keep pace with new large loads seeking to integrate onto the MISO transmission \nsystem). \n80  Id. at P 113-119. \n81  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6 (Jul. 16, 2026), available at: \nhttps://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20and%20Load%20Alignm\nent%20Presentation768740.pdf. \n82  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Stakeholder Feedback (July 30–31, \n2026) (including stakeholder feedback supporting an integrated process for studying load and generation in \nparallel \nand \naddressing \ntiming \nmismatches \nbetween \nexisting \nprocesses), \navailable \nat: \nhttps://www.misoenergy.org/engage/stakeholder-feedback/2026/llwg-generation-and-large-load-alignment-\nllwg-2026-6-20260716/.  \n83  See Drake Testimony at 8."},{"page":20,"startToken":9602,"endToken":10036,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 20 \n \n \n \nmaintaining appropriate limitations on the rights available to generation that has not completed \nMISO’s ordinary Generator Interconnection Queue process.84  The preservation and protection of \nthe DPP process was an express consideration in the LARS stakeholder process.  Stakeholders \nhave raised questions regarding how LARS generation will interact with generation already \nprogressing through the ordinary Generator Interconnection Queue and the protections necessary \nto avoid adversely affecting existing Interconnection Customers.85  The transmission capacity \nheadroom available at the beginning of the DPP cycle is still available the end of the cycle and is \nnot impacted by the LARS Applications.86  Similarly, the transmission capacity headroom for the \nLARS models are separate and distinct as they start with different MTEP base models and the \nLARS models are not inclusive of generation without executed GIAs.  The models from LARS \nand the DPP process will be reconciled through MTEP.87   \n \nIn addition to ZGIA and LARS, MISO is working with stakeholders through the LLWG on \nadditional initiatives that will address the other concerns raised by the Show Cause Order.  MISO \nhas introduced several of these initiatives at the LLWG meetings and many have specific details \nthat are still being worked out with stakeholders.  These additional initiatives and proposals will \nbe evaluated through the LLWG through the fall and will ultimately be presented to the \nCommission in separate FPA section 205 filings by November 16, 2026.   \n \nB. \nADDRESSING FERC’S SHOW CAUSE ORDER: ELECTRICALLY PROXIMATE \nREQUIREMENT \nMISO continues to advance a coordinated set of solutions designed to balance speed to \npower, fairness, and, most importantly, reliability.  In particular, MISO has developed solutions \nthat are responsive to the Commission’s concerns noted in the Show Cause Order surrounding the \ninterconnection and study processes for co-location arrangements, large load reliability \nrequirements, and now is addressing the need for service of proximate large loads.  MISO has \ndeveloped LARS against this backdrop of its broader efforts to address the reliable integration of \nlarge loads and associated generation.  MISO developed the ZGIA process through the LLWG with \nexpress consideration of resource adequacy, markets, and reliable operations.88  The LARS offers \nmore flexibility in the siting of the load/generation pair to maximize the effectiveness of any \ntransmission solutions developed.  Thus, the ZGIA process will be utilized to meet the co-located \n \n84  See id. at 7-8.  \n85  See MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6, Stakeholder Feedback (Sept. 9, 2026) \n(reflecting stakeholder comments concerning the relationship between LARS and the existing Generator \nInterconnection Queue). \n86  See Drake Testimony at 32-33. \n87  See id. \n88  ZGIA Filing at 5-6."},{"page":21,"startToken":10036,"endToken":10560,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 21 \n \n \n \nportion of the Order and LARS will address the electrically proximate large load portion of the \nOrder, by pairing generation with large load in the same LRZ.   \nIn its Show Cause Order, the Commission found that MISO’s Tariff “appears to be unjust \nand unreasonable” because it did not contain provisions allowing an interconnection customer to \nserve “an electrically proximate large load.”89  The Commission defined electrically proximate \nlarge load to mean a large load “that is sufficiently electrically close to the interconnection \ncustomer’s requested point of interconnection, such that the impact on the transmission system of \nthe combination of the generating facility and the load, with the exception of the transmission \nfacilities between the two, will be effectively the same as if they were located at the same \nsubstation (e.g., large load that is located no more than two substations away from the generating \nfacility).”90  The Commission then stated that it would consider proposed revisions to this \ndefinition to “ensure it is appropriately tailored to MISO’s transmission system.”91  Per this \ninvitation, MISO is now proposing revisions that address the Commission’s concerns related \nelectrically proximate generation and load pairs as part of a broader regionally-tailored framework.   \n \nLARS establishes the Tariff structures necessary to enable an Interconnection Customer to \nserve an electrically proximate load under study processes that reflect the interaction between \ngeneration and load.  In MISO, anchoring the proximate requirement with the LRZ is more \nefficient and effective because it aligns with MISO’s existing resource adequacy construct and \nenables more generation to serve a single load across a broader area but in a manner that still \naddresses resource adequacy and reliability of the system.  MISO did not want to limit the pairing \nof generation with associated load to a specific number of substations because that is likely too \ngeographically narrow and could limit how MISO may optimize common transmission solutions.  \nMoreover, allowing Generating Facilities participating in LARS to interconnect at multiple POIs \nprovides a “proximate plus” solution for the pairing of load with generation.  This provides \nInterconnection Customers with the necessary flexibility to serve extremely large loads and in way \nthat MISO can optimize any necessary transmission solutions.  As Ms. Drake explained in her \ntestimony, “[u]ltimately, limiting the generation and LARS Associated Load to locations within \nthe same LRZ ensures deliverability of the generation to the LARS Associated Load because it \navoids potential capacity import / capacity export limitations for the individual LRZ and also \navoids price separation between the paired generation and LARS Associated Load.”92  This \nstructure also reflects stakeholder feedback regarding the need to accommodate the \ninterconnection of large, landlocked loads that may need additional POIs.  \n \nThe LARS process was designed to produce optimized load-and-generation Network \nUpgrades, which aligns with the intent of the Show Cause Order and the proximate generation \nrequirement.  Requiring the load and the generation to be located in the same LRZ provides the \nnecessary proximity while also providing sufficient flexibility to enable LARS to be a successful \n \n89  Show Cause Order at P 113.  \n90  Id. at P 112.  \n91  Id.  \n92  Drake Testimony at 40-41."},{"page":22,"startToken":10560,"endToken":10976,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 22 \n \n \n \nprocess.93  MISO is confident that LARS is a beneficial addition to its large load framework, \ndifferentiated from the co-location requirements of the ZGIA process, and provides another just \nand reasonable way for large loads to connect to the grid.  Accordingly, LARS intends to provide \na resource solution associated with significant new demand without establishing an unrestricted \nalternative to MISO’s ordinary generator interconnection process.  Together with the ZGIA \nframework, LARS provides MISO with an additional mechanism to facilitate the development of \nresources needed to support significant new load growth while maintaining reliability and \nappropriate protections for existing Interconnection Customers. \n \nIV. \nDESCRIPTION OF PROPOSED TARIFF REVISIONS \n \nTo implement the LARS process proposed herein, MISO is requesting approval of new \nTariff provisions, as well as revisions to several existing provisions.94  \nA. \nAttachment X (Generator Interconnection Procedures).  \nThe proposed Tariff revisions implement the LARS process and are necessary to \ndistinguish the key differences in how the LARS study process and the resulting LLGIA will \noperate in comparison to MISO’s standard three-phase generator interconnection queue.  For \nconvenience, MISO discusses the revisions to the GIP by section, below.  \n \n1. Section 1: Definitions \n \nSection 1 contains definitions that are used throughout the GIP and its supporting \nattachments. MISO is proposing both to add several new terms and definitions to Attachment X, \nas well as to revise the definition of several existing terms.  The proposed new definitions are \nnecessary to implement the LARS process and to provide clarity and consistency throughout the \nGIP. MISO proposes the following revisions to existing definitions in Attachment X: \nInterconnection Customer shall mean any entity, including Transmission Provider, \nTransmission Owner or any of the Affiliates or subsidiaries of either, that proposes to \ninterconnect its Generating Facility with the Transmission System.  For the purposes of \nLarge Load Addition Resource Study (LARS), Interconnection Customer shall refer to the \nentity developing the Generating Facility that will execute the LLGIA, which may be a \ndifferent entity from the LARS Associated Transmission Customer that submitted the \nLARS Application.  \nInterconnection Request shall mean (1) an Interconnection Customer’s request, in the \nform of Appendix 1 to the Generator Interconnection Procedures, to interconnect a new \n \n93  Id. at 39-40. \n94  This transmittal letter frequently quotes proposed Tariff revisions to facilitate its explanation.  In the event of a \nconflict between the Tariff language as discussed in this letter and that reflected in the attached Tariff sheets, \nMISO intends that the language in the attached Tariff sheets control."},{"page":23,"startToken":10976,"endToken":11470,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 23 \n \n \n \nGenerating Facility, or a request for the Expedited Resource Addition Study for a new \ngeneration capacity, or a request for the processing of a proposed Generating Facility as \npart of a Large Load Addition Resource Study, or to increase the capacity of, or make a \nMaterial Modification to the operating characteristics of, an Existing Generating Facility \nthat is interconnected with the Transmission System, or to interconnect an Existing \nGenerating Facility that is external to the Transmission System, or to change Energy \nResource Interconnection Service to Network Resource Interconnection Service for an \nExisting Generating Facility; or (2) an MHVDC Connection Customer’s request, in the \nform of Appendix 1 to the Generator Interconnection Procedures, to obtain Injection \nRights. \nParty or Parties shall mean Transmission Provider, Transmission Owner, Interconnection \nCustomer, LARS Associated Transmission Customer, or any combination of the above.   \nThese changes are necessary to properly document that LARS projects will be studied separately \nfrom MISO’s generator interconnection queue and will require a separate election in Appendix 1 \nto the GIP (“Interconnection Request for a Generating Facility”) to be studied as a LARS project.  \nMISO proposes these revisions to ensure that the LARS process is included in the Interconnection \nRequest procedures and to clarify that the Interconnection Customer in the LARS process may not \nbe the same entity that is the Transmission Customer or Transmission Owner.  \nMISO also proposes the following new definitions for addition to the GIP (and LLGIA): \nLarge Load Addition Resource Study (LARS) shall mean the procedure as set forth in \nSection 3.12 of this GIP for studying a Interconnection Customer’s proposed Generating \nFacility in parallel with the study of a LARS Associated Load Customer’s proposed load.    \nLarge Load Addition Resource Study (LARS) Period shall mean the period of time in \nwhich Interconnection Requests for proposed Generating Facility are studied in parallel \nwith the study of a LARS Associated Load Customer’s proposed load. There are three \nLARS study periods in one year and each study period will run for approximately 120 days. \nAll Interconnection Customers requesting to join the next Large Load Addition Resource \nStudy (LARS) shall submit their Interconnection Request to the Transmission Provider no \nlater than the LARS application deadline as published on the MISO public website, which \nshall be at least twenty (20) Business Days prior to the scheduled kick-off of the LARS \ncycle published on the MISO public website.   \nThese definitions are necessary to describe the study that MISO will conduct for a \ngeneration/load pair in the same process.  These definitions also establish that LARS will be \nconducted three times per year and provides the timing requirements of when the LARS \nApplications must be submitted to MISO to be included in the LARS process.  \nLarge Load Generator Interconnection Agreement (LLGIA) shall mean the form of \ninterconnection agreement governing the terms and conditions of Large Load \nInterconnection Service, set forth in Appendix 6 to the GIP.  This agreement shall follow"},{"page":24,"startToken":11470,"endToken":11950,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 24 \n \n \n \nthe form of the Transmission Provider’s pro forma Generator Interconnection Agreement \nwith modifications to reflect the Large Load Addition Resource Study process.  Unless \notherwise provided in the GIP, all requirements applicable to the pro forma Generator \nInterconnection Agreement shall apply to the LLGIA.  A LLGIA is a form of GIA and, \nwhere used in the Tariff, references to Generator Interconnection Agreements or GIAs \nencompasses LLGIAs.  \nMISO proposes the above definition for the pro forma agreement that would be tendered \nto an Interconnection Customer at the conclusion of the LARS process.  MISO notes that the \nLLGIA is closely based on the MISO’s pro forma GIA in Tariff Attachment X, Appendix 6 with \nmodifications as described below.  MISO includes the last sentence of this definition to avoid any \nconfusion and clarify that the numerous references in other sections of the Tariff to GIAs include \nLLGIAs by default.95  \nLARS Application shall be a single submission consisting of the materials required for \nLARS processing as required by Section I.D.1.b.ii of Attachment FF to the Tariff as well \nas the information required for studying the Generating Facilities under this Attachment X \n(in the form of Appendix 1) to these generator interconnection procedures. For purposes of \nthis GIP, a LARS Application shall be a form of Interconnection Request.   \nMISO is adding this defined term to the Tariff provides the vocabulary needed for discussing all \nof the pieces of information that must be supplied to MISO in a single submission prior to \nparticipating in the LARS process.  \nLARS Associated Load shall mean a source of electrical load that is at least 200 MW and \nthat is formally paired with one or more Interconnection Customer(s) that have submitted \nan Interconnection Request to LARS proposing one or more new Generating Facility(ies) \nto provide energy to such load.    \nLARS Associated Transmission Customer shall mean the entity that is responsible for \nsubmitting the LARS Application and procures Transmission Service in order to serve \nLARS Associated Load and designates such load as formally paired with an \nInterconnection Customer’s LARS Interconnection Request.  \nAdding these defined terms to the Tariff provides the vocabulary needed for discussing the specific \nload that a Generating Facility with a LLGIA is limited to serving and to identify the entity \nresponsible for submitting the LARS Application.  \n \n95  MISO has built its LLGIA Tariff sheets using the latest effective version of Appendix 6 to Attachment X of the \nTariff.  This does not include the ZGIA revisions currently housed in Appendix 19, which are pending before the \nCommission in Docket No. ER26-3552-000 or MISO’s revisions submitted in compliance with Order No. 2023, \nwhich remains pending before the Commission in Docket No. ER24-2046-003.  MISO has used this approach for \nversion control and administrative reasons.  MISO commits to reconcile these versions as appropriate once they \nare accepted."},{"page":25,"startToken":11950,"endToken":12407,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 25 \n \n \n \n2. Section 2.1—Application of Generator Interconnection Procedures \nMISO proposes to add a subsection k to GIP Section 2.1 that governs the application of \ninterconnection procedures.  This subsection explains that a request for LARS should be evaluated \naccording to the procedure in GIP Section 3.12, which is a new Section MISO proposes to add for \nthe implementation of the LARS process.  This addition is necessary to distinguish the process for \nevaluating requests for LARS from other projects entering MISO’s generator interconnection \nqueue. \n3. Section 3.3.1—Valid Interconnection Request  \nMISO proposes to revise Section 3.3.1, which encompasses the procedures for submitting \nan Interconnection Request.  The revisions include clarifying language surrounding the timeline \nfor submitting LARS Applications to MISO and where the application timeline will be posted on \nthe MISO website.  MISO also proposes to increase the Non-Refundable Deposit 1 (D1) to \n$250,000 for LARS projects and to require an entry milestone (M2) of $30,000 per Megawatt for \nnew Interconnection Service requested to ensure only projects that are “shovel ready” and \ncommercially viable apply to LARS.  \nTo further demonstrate that a project is “shovel ready,” all documentation, milestone \npayments, deposits and any necessary data is required at the time of LARS Application submission. \nThese up-front requirements will allow MISO to complete the study process within its estimated \n120-day timeframe.  MISO also proposes to require that LARS projects have a Commercial \nOperation Date within three calendar years from the date of the Interconnection Request and the \nLARS Associated Load will have an identical anticipated Service Commencement Date.  All \nLARS projects are eligible to use the grace period of up to three years as documented in GIA \nArticle 2.3.1.  \n4. Section 3.5.1.1—Inclusion in a JTIQ Screening Group, JTIQ Participation \nGroup, and JTIQ Commitment Group  \nMISO proposes to revise GIP Section 3.5.1.1 subsection (1) to clarify that LARS projects \nshall be included in a JTIQ Screening Group, along with projects in the generator interconnection \nqueue.  As discussed in prior stakeholder meetings, MISO intends to consider LARS projects for \nJTIQ. This revision is necessary to ensure that LARS projects are properly included in JTIQ \nScreening Groups along with projects from MISO’s DPP interconnection queue.  \n5. Section \n3.5.4—Affected \nSystems \nCoordination \nProcedures \nto \nInterconnection Requests Included in a Large Load Addition Resource \nStudy \nMISO proposes new Section 3.5.4 governing coordination with affected systems in the \nevaluation of Interconnection Requests participating in LARS.  Proposed Section 3.5.4 closely \nfollows the affected systems coordination procedure accepted for ERAS Interconnection Requests.  \nSpecifically, proposed Section 3.5.4 provides that MISO will apply the same coordination"},{"page":26,"startToken":12407,"endToken":12895,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 26 \n \n \n \nprocedures and screening criteria as that used for Interconnection Requests in the DPP.  MISO \nsubmits that these rules are appropriate because they provide a structure for processing \nInterconnection Requests for LARS rapidly and in a manner that recognizes the serial nature of \nsuch studies.  Requiring LARS Interconnection Customers to execute LLGIAs where affected \nsystems information has not yet been provided is necessary to maintain the accelerated speed of \nthe LARS process and to provide certainty to LARS Interconnection Requests in subsequent LARS \nstudy periods whose models will be built from the prior completed study.  MISO will work with \nits AFS partners to accelerate the AFS study process of any projects participating in LARS.  \n6. Section 3.12—Large Load Addition Resource Study \nMISO proposes to add new GIP Section 3.12 to encompass the necessary processes and \nimplementation details for the LARS process.  LARS provides a single application and study \nprocess that produces an optimized set of Network Upgrades in 120 days for any large load and \ngeneration pair that meet the requirements set out in this section.  \n7. Section 3.12.1 – Pre-Submission Coordination Process  \nProposed Section 3.12.1 explains the pre-coordination procedures required for parties to a \nLARS Application. The purpose of this new section is to build in a coordination and collaboration \nprocess into the LARS timeline.  Since a LARS Application requires information from a wide \nvariety of parties, a viable application requires that the parties have met and agreed on key details \nbefore submitting the required materials to the LARS process.  These agreements will ensure that \nall the parties agree on the POI for the Generating Facility(ies), avoiding post-submission \nwithdrawals and enabling MISO to complete the LARS studies on an accelerated basis.  \nFirst, the revisions state that the LARS Associated Transmission Customer initiates and \nsubmits the LARS Applications with support from the Interconnection Customer on the generation \nside and the Transmission Owner on the load side.  \nSecond, the proposed language explains the timeline for when Interconnection Customers \nlooking to participate in LARS must contact the Transmission Owner to request a meeting to \ndetermine the POI for the Generating Facility.  Interconnection Customers must request this \nmeeting at least 45 calendar days prior to a LARS Application deadline.  The Transmission Owner \nis then required to meet with the Interconnection Customer and any other impacted parties within \n10 business days.  Following the meeting to discuss an agreed-upon POI for the Generating \nFacility, the Tranmission Owner will have at least 15 business days to provide an attestation for \nthe LARS Application, which will state that the parties have agreed upon a definitive POI. This \nlast provision is needed to avoid leaving the Transmission Owner with too little time to make the \nattestation. \n8. Section 3.12.2 \nMISO proposes to add new GIP Section 3.12.2 to explain the requirements for participating \nin the LARS process."},{"page":27,"startToken":12895,"endToken":13330,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 27 \n \n \n \nFirst, MISO proposes to require the LARS Associated Transmission Customer and the \npotential LARS Interconnection Customer to provide an executed agreement evidencing that the \noutput of the Generating Facility for which LARS processing is sought is intended to be used to \nprovide energy to the LARS Associated Load.   The proposed language is as follows: \nA LARS Application for processing through the Large Load Addition Resource \nStudy must meet the requirements listed in Section 3.3.1 above, plus the following \nrequirements: \n \ni. \nThe Interconnection Request shall be accompanied by an agreement executed \nby the Interconnection Customer and either the LARS Associated Transmission \nCustomer or the entity that owns or controls the LARS Associated \nLoad evidencing that the output of the Generating Facility for which LARS \nprocessing is sought shall be used to provide energy to the LARS Associated \nLoad.  Such agreement shall take one of the following forms and state a \nminimum term of at least five (5) years to align with MISO’s transmission \nplanning horizon as described in Section I.D.1.b.ii of Attachment FF to the \nTariff:  \n \na. A power purchase agreement (PPA) or similar off-take agreement between \nthe Interconnection Customer submitting the Interconnection Request for \nLARS processing and the entity with the LARS Associated Load to be \nserved (including, but not limited to, an Alternative Retail Electric Supplier \nor its Load Serving Entity); or \nb.  An agreement that calls for the Interconnection Customer to develop the \nGenerating Facility described in the Interconnection Request and \nsubsequently transfer ownership or control of such Generating Facility \n(Build-Own-Transfer Agreement) to the entity with the LARS Associated \nLoad to be served (including, but not limited to, an Alternative Retail \nElectric Supplier or its Load Serving Entity); or \nc. For Load Serving Entities (or an Alternative Retail Electric Supplier or \nequivalent in a retail choice state), evidence of other types of agreements \nthat provide that the generation is intended to serve the LARS Associated \nLoad customer. These agreements include, but are not limited to, a special \ncontract, a large load tariff agreement, or retail service agreement.  \n \nThis requirement is necessary both to prevent speculative Interconnection Requests, and to verify \nthat the LARS Associated Load intends to use the output of the Generating Facility.  The agreement \nmay take several forms, as documented in Section 3.12.2, depending on the type of project and \nassociated parties.  This language is intended to limit LARS projects to those that have been \nformally paired together, while also ensuring that certain business models and agreements are not \nexcluded from participating in LARS."},{"page":28,"startToken":13330,"endToken":13898,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 28 \n \n \n \nSecond, MISO proposes to require any Interconnection Request submitted as part of a \nLARS Application include documentation demonstrating that the Electromagnetic transient \n(“EMT”) modeling requirements have been met for inverter-based resource (“IBR”) generation as \nspecified in MISO’s BPM.  Including the specific technical data needed in the BPM is consistent \nwith requirements for other types of Interconnection Requests and provides needed flexibility to \nupdate specific technical details as MISO and its stakeholders gain experience with new kinds of \nInterconnection Service Requests. \nThird, MISO proposes to require that any Interconnection Request submitted as part of a \nLARS Application Demonstrate 100% site control including 100% generator and Interconnection \nCustomer Interconnection Facility (“ICIF”) site control.  This is to ensure that truly “shovel-ready” \nprojects apply to participate in LARS and reduces the risk of withdrawals later in the process.  \nFourth, MISO proposes to require that any Interconnection Request submitted as part of a \nLARS Application include a one-line diagram showing the Generating Facility and associated \nelectrical equipment. MISO also proposes to require a detailed power flow model for the proposed \nGenerating Facility that includes the POI and any proposed system protection facilities.  Because \nLARS Generating Facilities are restricted to serving a specified load, the LARS Associated Load, \nsubmission of detailed and accurate one line diagrams and power flow models showing both the \nGenerating Facility, the LARS Associated Load, protection facilities, and their configuration with \nrespect to the Transmission System is critical to accurately studying how a proposed LARS \nGenerating Facility will interact with the Transmission System and to ensuring limited impacts.  \nIn addition, it is essential to document this configuration in the resulting LLGIA because the results \nof the LARS study will depend on the proposed configuration remaining as proposed. \nSixth, MISO proposes to require that any Interconnection Request submitted as part of a \nLARS Application request NRIS in an amount that is at least 200 MW (the minimum threshold for \na LARS Associated Load) and in an amount that is not more than 150% of the peak Demand of \nthe LARS Associated Load. The LARS Application must include the LARS Associated Load’s \nexpected peak demand over any one-hour period.  This will allow MISO to know what the total \namount of MW demand is expected from this load and ensure that the total amount of requested \nInterconnection Service by the Generating Facilities does not exceed 150% of that peak demand \namount.  These requirements strengthen the connection between the Generating Facility and the \nLARS Associated Load in such a manner as to consider them formally paired.  Allowing a \nGenerating Facility to serve up to 150% of the load’s peak demand also allows for more flexibility \nin the kinds of generation that may participate in LARS.  \nMISO also proposes to require that the LARS Associated Load and any paired Generating \nFacilities be located in the same LRZ.  In order to address the Commission’s desire for large loads \nto have the option to be located electrically proximate to generation, MISO is proposing to expand \nthe concept of “electrically proximate” to the LRZ and not limit it to a pre-determined number of \nsubstations.  This serves two purposes.  First, this allows load and generation to site near each \nother in a flexible way that will also optimize any common transmission solutions. Second, placing \nthe electrically proximate requirement within the LRZ construct aligns LARS with MISO’s \nexisting resource adequacy construct."},{"page":29,"startToken":13898,"endToken":14433,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 29 \n \n \n \nSeventh, MISO is establishing three-year deadline for a Generating Facility’s Commercial \nOperation date and requiring that the LARS Associated Load reach its full-service amount in the \nsame amount of time.  This provision provides the flexibility needed to enable both the generation \nand load to come online at roughly the same time while also providing a deadline by which they \nboth must be fully operating on MISO’s system.  The Commercial Operation Date provisions \nfollow those applicable under MISO’s standard process.  The requirement to specify an analogous \ndate for the LARS Associated Load preserves and reinforces the linkage between the Generating \nFacility and the LARS Associated Load that underpins the LARS study.  \nEighth, MISO is proposing to include a provision that would allow Interconnection \nCustomers participating in LARS to elect the option to build.  Notably, MISO is requiring that the \nInterconnection Customer include that election at the time of submission of the LARS Application \nand MISO will not accept future elections for the option to build after the LARS Application is \nsubmitted.  This is to ensure certainty for MISO study processes and so that the proper internal \nadministrative timelines can be established upon the submission of the LARS Application.  \nNinth, MISO proposes to add provisions to allow a LARS Associated Load to be served \nby multiple Generating Facilities.  The proposed revisions are as follows: \nA LARS Associated Load may be served by multiple Generating Facilities provided that: \n1. All Generating Facilities serving a LARS Associated Load behind the same Point \nof Interconnection must be identified in the LARS Application for the specific \nLARS Associated Load and must request a minimum of 200 MW of \nInterconnection Service in the aggregate; or,   \n2. Multiple Generating Facilities serving a LARS Associated Load may be located \nbehind different Points of Interconnection provided that they: \na. Be located in the same LRZ as the LARS Associated Load, \nb. Request a minimum of 200 MW of Interconnection Service for all Generating \nFacility(ies) behind a separate Point of Interconnection; and, \nc. Be submitted as a separate LARS Application for the amount of demand of the \nLARS Associated Load it will serve through that Point of Interconnection.  \n \nMISO made this change in response to stakeholder requests to allow multiple POIs for generation \nlocated within the same LRZ as the LARS Associated Load.  This revision allows multiple \ngenerators to aggregate behind a single POI to serve one LARS Associated Load.  Due to the size \nof some of the large loads that are looking to connect to the system, allowing Generating Facilities \nto aggregate to supply for the large load is efficient.  Adding the requirement that the Generating \nFacilities contained in a single LARS Application be sited behind a single POI enable MISO to \nadequately study the load with the requested generation.  The requested minimum of requested \nInterconnection Service by the Generating Facilities must be at least 200 MW at each POI and \ngenerators can aggregate to reach that minimum.  A LARS Associated Load may be served by \nseveral different groups of Generating Facilities at multiple POIs. To assist MISO with keeping \ntrack of the LARS Associated Load and its paired Generating Facilities, a LARS Application must"},{"page":30,"startToken":14433,"endToken":14963,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 30 \n \n \n \nbe submitted for each POI group of Generating Facilities.  Thus, a LARS Associated Load should \nhave a LARS Application for each POI where generators are serving it.  \nTenth, MISO proposes to add language stating that no changes shall be made to the LARS \nApplication, including any underlying Interconnect Requests, after submission.  The proposed \nrevisions are as follows: \nNo changes shall be made to the LARS Application after submission and prior to the \nexecution or the unexecuted filing of the LLGIA and MTEP approval for the LARS \nAssociated Load except that a LARS Application that is deferred to the next available \nLARS Study Period will be allowed to extend its In-Service Date or Commercial Operation \nDate to be no more than three calendar years from the kickoff of the LARS Study Period \nin which its LARS Application is studied.  \n \nBecause the timeline from submission to an executed LLGIA is 120 days, this proposed language \nis necessary to ensure that LARS projects are studied expeditiously and can be online as soon as \npossible to meet the stated resource adequacy and/or reliability need.  To make this timeframe \nworkable and avoid delays that would impact other Interconnection Customers, it is necessary to \nrequire that these Interconnection Services be well-considered and provide certainty with respect \nto the details to be studied at the time they are submitted.  This readiness requirement is mitigated \nby the fact that MISO will complete the LARS study process three times per year.  Therefore, an \nInterconnection Customer that is not certain of the details to be included in its Interconnection \nRequest for the LARS Application would only need to wait until the following LARS study period \nfor another opportunity to participate.  Moreover, MISO has included language that will allow \nLARS applicants to change their COD or In-Service Date if their LARS Application is pushed to \na later LARS study period.  \n \nEleventh, MISO proposes a paragraph to allay concerns expressed during the stakeholder \nprocess that LARS could be read as conflicting with state and local laws by allowing the owner of \na generator that is not a Load Serving Entity to serve load when not authorized to do so by state \nlaw.  The inclusion of this language neither imposes, nor is intended to impose, any independent \nrestrictions on an Interconnection Customer. \nFinally, MISO proposes to limit the period of review to identify deficiencies in LARS \nApplications to a single period for MISO and to limit the period for curing the identified \ndeficiencies to a single period for the LARS applicants.  This will ensure that the study process \nremains on track and timely as it avoids multiple review and cure periods for MISO and the LARS \nparticipants.  If the LARS Application is not cured within the one allotted cure time period, then it \nwill be automatically withdrawn from LARS with any associated penalties.   \n9. Section 3.12.3 – Evaluation Process for Large Load Addition Resource \nStudy Interconnection Request \nMISO proposes to add GIP Section 3.12.3 to facilitate the evaluation process of projects \nseeking to use LARS and limits the number of generation/load pairs to be studied to ten per LARS"},{"page":31,"startToken":14963,"endToken":15462,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 31 \n \n \n \nstudy cycle.  The proposed language explains that projects will be evaluated in the order in which \nthey are submitted.  Proposed language also clarifies that if the project is found to be ineligible for \nLARS, the project will lose its Non-Refundable Deposit D1.  The risk of losing a large deposit if \ndetermined to be ineligible for LARS will encourage parties to only submit projects that they are \ncertain will meet the strict LARS requirements.  This requirement addresses MISO’s need for \ncertainty on transmission needs and their associated costs.  \nProposed Section 3.12.3 also documents the process for projects currently in the DPP \nprocess to transfer to LARS for evaluation.  In the situation where a project in the generator \ninterconnection queue is eligible to participate in LARS, proposed language clarifies that the \nproject will forfeit its Non-Refundable Deposit D1 and will be subject to withdrawal penalties per \nSections 7.6.2.1.1 and 7.8.  This proposed addition is necessary to ensure that projects dropping \nout of the generator interconnection queue do not harm remaining projects in their respective \ncycles.  Similarly, proposed language in Section 3.12.3 limits projects from leaving the generator \ninterconnection queue to LARS to only those that have not reached Decision Point II.  This \nlanguage is required to ensure that projects remaining in the generator interconnection queue are \nnot harmed by restudies that occur after projects drop out after Decision Point II.   \n10. Section 3.12.4 – The Study \nMISO proposes to add a new GIP Section 3.12.4 to describe the studies that will take place \nfor LARS generation projects. The proposed revisions are as follows: \nThe Interconnection Study for LARS will follow the same manner of NR \nInterconnection Study as noted in Sections 3.2.1.2 and 3.2.2.2 needed to integrate \nthe Generating Facility in the same manner as for any Generating Facility being \ndesignated as a Network Resource.  Transmission Provider will use Reasonable \nEfforts to study LARS Interconnection Requests from all Interconnection \nCustomers regardless of Generating Facility within sixty (60) Calendar Days after \nthe kickoff date for such study.  The study will be performed for each \nInterconnection Request, including the LARS Associated Load, individually in a \nserial fashion based on their submission date per LARS Study Period.  The LARS \ninterconnection study will result in a Final LARS System Impact Study and any \nassociated LARS Interconnection Facilities Studies. \n \nTransmission Provider shall include in the final study any Affected System Study \nresults and information regarding Network Upgrades from Affected Systems \nprovided the Affected System Study Reports are available.  If Affected Systems \nanalysis is not available for inclusion in the final LARS study, the Transmission \nProvider shall provide such analysis separately when received from the applicable \nAffected System. \n \nMitigations developed to address violations observed in only the transmission \nstudies shall be assigned Baseline Reliability Projects (BRP) or Other project \ntypes.  Mitigations developed to address common violations observed in both the"},{"page":32,"startToken":15462,"endToken":15948,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 32 \n \n \n \ntransmission study and the generation study shall be assigned Baseline Reliability \nProjects (BRP) or Other project types.  Mitigations developed to address violations \nobserved only in the generation study shall be assigned to the LARS \nInterconnection Customer under the Generator Interconnection Project (GIP) \nproject type.  \n \nThis proposed section implements the alignment of the load and generation study process and \ndescribes the generation study side of LARS.  The transmission and generation studies remain \nseparate but run in parallel and conclude at approximately the same time.  This language is \nnecessary for LARS Applications to be evaluated on a rolling basis during each LARS study \nperiod.  The studies will be performed serially, based on submission date. Serial studies are ideal \nfor LARS projects since there will be a considerably smaller number of proposed LARS \ngeneration/load pairs per year.  On the generation side of the LARS study process, each \ngeneration/load pair will be studied individually in a serial fashion in their own model.  \nProposed language in this section also explains that any Affected System Study results, if \navailable, will be included at the time of the final LARS study.  If the Affected System Study \nresults are unavailable at the time of the final study, those results will be provided separately when \nreceived from the applicable Affected System. \n \nFinally, the proposed language at the end of Section 3.12.4 addresses how mitigations \ndeveloped to address violations will be assigned depending on where they were observed.  If they \nwere only observed in the load side study of LARS, then they will be assigned BRPs and Other \nproject types.  If mitigations were developed to address violations observed in both the generation \nand load studies, then they will be assigned BRPs and Other project types.  And finally, any \nmitigations developed to address violations observed that were caused only in the generation study \nwill be assigned to the Interconnection Customer under the Generator Interconnection Project \n(“GIP”) project type.  \n11. Section 3.12.5 – Notice to Proceed to LLGIA  \nMISO proposes to add the following Section 3.12.5, which is titled Notice to Proceed to \nLLGIA.  This proposed language is necessary to distinguish between the shorter timeline for LARS \nand the general timeline for providing a notice to proceed for a DPP interconnection project. The \nshortened five Business Day timeline is necessary to allow Customers to execute their LLGIA \nwithin approximately 120 days from kickoff of the LARS study period.  \n12. Section 3.12.6 – GIA for Large Load Addition Resource Study Projects \n(LLGIA) \nProposed GIP Section 3.12.6 governs the timeline and necessary requirements regarding \ntender of the draft pro forma LLGIA and JTIQ applicability, and also points to Sections 11.1 \nthrough 11.4 of the GIP governing procedures such as MISO’s tender of the draft LLGIA, \nnegotiations, and execution of the LLGIA.  This proposed Section provides a five Business Day"},{"page":33,"startToken":15948,"endToken":16468,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 33 \n \n \n \ntimeline for MISO to tender a draft pro forma LLGIA after receiving notification of the \nInterconnection Customer’s intent to proceed to LLGIA.  \nDue to the varied nature of MISO’s and SPP’s processes related to JTIQ Service \nAgreements, proposed revisions provide a path forward for JTIQ eligible LARS projects if SPP’s \nJTIQ Service Agreement has not been provided to the Interconnection Customer prior to the tender \nof the draft LLGIA.  If the SPP JTIQ Service Agreement has not been received at the time of \nMISO’s tender of the LLGIA, proposed language requires JTIQ eligible LARS projects to include \na milestone in GIA Appendix B requiring the parties to execute or request the unexecuted filing of \nan SPP JTIQ Service Agreement within 15 Calendar Days after such agreement has been tendered \nto the Interconnection Customer.  Proposed language also states that LARS Interconnection \nRequests included in a JTIQ Participation Group shall adhere to all JTIQ procedures and execute \nJTIQ Service Agreements as applicable. \n13. Section 3.12.7 – Large Load Addition Resource Study Refunds \nProposed GIP Section 3.12.7 and its subparts document the process for obtaining refunds \nof study deposits and milestone payments in the LARS process.  \nProposed GIP Section 3.12.7.1 governs applicable refunds of the Study Deposit (D2).  As \nwith generator interconnection requests, LARS D2 study deposit amounts are based on Megawatt \namount of new Interconnection Service of the LARS project as stated in GIP Section 3.3.1.  The \nInterconnection Customer will be charged the actual amount of the Large Load Addition Resource \nStudy and will be required to pay any additional costs or will be refunded any overages as \napplicable.  \nProposed GIP Section 3.12.7.2 details the process for receiving a refund of the LARS \nmilestone payment M2.  LARS projects are eligible to receive a 100% refund of M2 upon \nwithdrawal prior to execution of the LLGIA.  If a LARS project withdraws after execution of the \nLLGIA, the project is only eligible to receive a refund of any remaining M2 milestone after \nmeeting the Initial Milestone Payment and/or Network Upgrade costs memorialized in the LLGIA.  \nShould a project withdraw after execution of the LLGIA, the proposed Section 3.12.7.3 \ndocuments the process for providing the initial payment to the Transmission Owner, which will \noccur within forty-five Calendar Days from the effective date of the LLGIA.  If the M2 provided \nby the Interconnection Customer exceeds the initial payment amount, MISO will provide a refund \nof any remaining M2 within 45 Calendar Days of the effective date of the LLGIA.  If the \nInterconnection Customer’s M2 is less than the initial payment, the proposed language of 3.12.7.3 \nrequires the Interconnection Customer to provide the remaining portion of the initial payment to \nthe Transmission Owner.  \nThe proposed language in Section 3.12.7.4 describes what happens when the LLGIA is \nterminated or the large load is withdrawn from the LARS process before or after the minimum \nfifteen-year pairing period has passed.  The proposed language in the first paragraph is as follows:"},{"page":34,"startToken":16468,"endToken":16954,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 34 \n \n \n \nIn the event that the Interconnection Customer’s LLGIA is terminated after \nexecution by all parties or after LLGIA is filed unexecuted, the Interconnection \nCustomer will be responsible for the costs of the Network Upgrades that are \nclassified as GIPs and documented in the LLGIA and/or corresponding FCAs or \nMPFCAs, including those GIP Network Upgrades arising from the Affected \nSystem Study process. The Interconnection Customer will be responsible for \nNetwork Upgrades resulting from a LARS Study that are classified as GIPs under \nAttachment X.  To the extent the generator fails to commence operation or retires, \nthe load may go through MTEP and during that transition may be subject to \nsimilar limitations if the load’s Service Commencement Date is prior to the date \nLARS Generating Facility commences commercial operation. \n \nThe purpose of this language is to clearly establish that the Interconnection Customer is \nresponsible for all assigned Network Upgrades that are classified as GIPs identified in the LLGIA.  \nMISO is proposing this language to ensure that whether or not the LLGIA is ultimately terminated \nor filed unexecuted, the Interconnection Customer is on the hook for the costs associated with its \nproposed project.  This is necessary to clearly assign responsibility to the Interconnection \nCustomer and to protect other market parties from paying for those costs.  The language also \nclarifies what will happen to the LARS Associated Load if the Generating Facility fails to \ncommence operations or retires completely.  \n \nThe next paragraph of Section 3.12.7.4 addresses these permutations in the following language:  \n \nIn the event that the LARS Associated Load is withdrawn from LARS or ceases use \nof the Transmission Service granted through LARS within the first fifteen (15) \nCalendar Years after the LARS Associated Load commences use of the \nTransmission Service granted through LARS, then operations of the Generating \nFacility shall be subject to the Annual ERIS (“AERIS”) and the Quarterly Operating \nLimit (“QOL”) for a one year period until termination as set forth in Article 2.3.1 \nof the Attachment X Appendix 6. An Interconnection Customer that desires to \ncontinue injections shall be required to obtain Interconnection Service through the \nDPP as described in Attachment X.  The LLGIA will be terminated after the period \nspecified in Article 2.3.1.  Following the first fifteen (15) Calendar Years after a \nLARS Associated Load ceases use of its Transmission Service or if the agreement \nrequired by GIP Section 3.12.2.i is terminated or otherwise ceases to be in effect, \nthen Transmission Provider shall not terminate the Generating Facility’s \nInterconnection Service. \nSince the successful operation of LARS is dependent on the formal pairing of both the generation \nand load for fifteen years, MISO has proposed Tariff language to address different permutations \nof what happens if the generation were to stop operating or the load were to stop accepting \nTransmission Service within the first fifteen years."},{"page":35,"startToken":16954,"endToken":17518,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 35 \n \n \n \nIf the LARS Associated Load ceases service within the first fifteen years, then the \nGenerating Facility will have up to one year to acquire new Interconnection Service.  MISO added \nthis provision in response to stakeholder concerns that the termination of the relationship between \nthe LARS Associated Load and the Generating Facility (either through termination of their \nagreement or the LARS Associated Load discontinuing operations) could leave an otherwise useful \nGenerating Facility suddenly without Interconnection Service and unable to serve other Load \nneeds.  If the LARS Associated Load withdraws from LARS in the first fifteen years, then its \npaired Generating Facility will be subject to AERIS and the QOL processes and will have up to \none year to obtain Interconnection Service through the MISO DPP process.  If the Generating \nFacility is unable to obtain new Interconnection Service within one year, then the LLGIA will be \nterminated.  This is necessary to avoid any resource adequacy concerns that might be implicated \nby immediately terminating the LLGIA and provides flexibility for the Generating Facility to \ncontinue operating until it can be utilized in a different MISO process.  \n \nIf the LARS Associated Load ceases service after the first fifteen years of being formally \npaired, then it is reasonable to allow the Generating Facility to continue to utilize the \nInterconnection Service granted through the LLGIA.  Several stakeholders expressed concern that \na permanent pairing requirement would strand a Generating Facility that had a remaining useful \nservice life even if such Generating Facility could be used—or was needed—to address resource \nadequacy needs following the departure of the LARS Associated Load.  MISO added this language \nin response to these stakeholders’ legitimate concerns that Generating Facilities submitted to \nLARS in good faith and that had served LARS Associated Loads for long periods of time should \nnot be forced to go offline or undergo a second study process with potentially significant new costs \nif the LARS Associated Load unexpectedly ceased operations.   \n \nThus, MISO is requiring the generation and load to remain paired for fifteen years because \nit provides important safeguards that prevent customers from misusing the LARS process to obtain \nInterconnection Service and only serve the LARS Associated Load for a short period of time. \nFifteen years is also a reasonable time period as reflected in many standard large load contracts \nand sufficient to deter entities from invoking the needs of a specific large load as a pretext to bypass \nthe DPP queue and receive immediate and unrestricted service.  This language clearly allows the \nGenerating Facility to continue operating under the terms of the LLGIA after fifteen years have \npassed even if the LARS Associated Load ceases use of its Transmission Service.  This provides \nthe Generating Facilities with certainty after the fifteen-year period has passed and allows for these \nfacilities to continue assisting with any resource adequacy needs that may be occurring at that time.  \n \nThe final paragraph of Section 3.12.7.4 addresses what costs the LARS Associated \nTransmission Customer is required to pay for its participation in LARS.  The proposed language \nis as follows:  \n \nOnce MTEP approval occurs for the LARS Associated Load, the LARS Associated \nTransmission Customer remains responsible for the identified BRPs and Other \nassigned projects even if such LARS Associated Load does not commence \nservice.  In addition, if the LLGIA for a LARS Associated Load is terminated, the"},{"page":36,"startToken":17518,"endToken":17944,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 36 \n \n \n \nLARS Associated Transmission Customer remain responsible for the costs thereof.  \nIf the load portion of the MTEP Project for the LARS Associated Load is \nwithdrawn, then the Network Upgrade costs assigned as BRP or Other projects for \nthe LARS Associated Load remains the responsibility of the LARS Associated \nTransmission Customer. If the load portion of the MTEP Project for the LARS \nAssociated Load is withdrawn, the load may go through the applicable MTEP study \nprocess. \n \nThe language clearly explains in what instances the LARS Associated Transmission Customer is \nrequired to pay for any assigned Network Upgrades.  Once MTEP approval occurs for the LARS \nAssociated Load, then the LARS Associated Transmission Customer is on the hook for any of the \nNetwork Upgrade costs assigned to the load’s portion of the project.  This language is necessary \nto ensure that Network Upgrades are built as anticipated, even after a Generating Facility can no \nlonger operate.  In this instance, the LARS Associated Load may go through the MTEP process.   \n \nThis section clearly identifies which party is responsible for what mitigation costs.  Once \nthe LARS Associated Load receives MTEP approval, then the LARS Associated Transmission \nCustomer remains responsible for the identified BRPs and Other type projects assigned even if the \nload does not commence service. Similarly, if the LLGIA is terminated, then the LARS Associated \nTransmission Customer remains responsible for any associated costs identified in the LLGIA.  If \nthe LARS Associated Load commences service and then later withdraws the load portion of the \nMTEP Project, then the Network Upgrade costs assigned as BRP or Other projects remain the \nresponsibility of the LARS Associated Transmission Customer.  These provisions are necessary to \nensure that the proper party pays for the associated costs of their portion of the LARS project even \nif they never commence service or later withdraw from LARS.  These provisions can be \nimplemented now and will be compatible with the large load study process reforms MISO is \ndeveloping. \n14. Section 3.12.8 – Transfer of Ownership of Large Load Addition Resource \nStudy Interconnection Request  \nThe proposed language in Section 3.12.8 is necessary to prevent transfers of ownership \nprior to LLGIA execution that might slow down the timeline for studying a LARS project and \nultimately delay the ability for MISO to move LARS projects to LLGIA execution within 120  \ndays from kickoff.  Prohibiting any changes to a LARS Application prior to LLGIA execution will \nallow MISO to maintain its proposed LARS timeline and enable large loads to connect the system \nfaster."},{"page":37,"startToken":17944,"endToken":18418,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 37 \n \n \n \n15. Section 3.12.9 – Modifications of Large Load Addition Resource Study \nRequest  \nThe proposed Section 3.12.9 is necessary to ensure that no details of a LARS Application \nare changed during the study process.  The proposed revisions are as follows: \nAfter submission of the LARS Application, no modification to the Interconnection \nRequest or any of its parameters, including any information provided by the \nTransmission Owner such as the agreed-upon Point of Interconnection, is permitted \nunder Section 4.4 or otherwise prior to the execution or unexecuted filing of the \nfinal LLGIA.  Any modification made by the Interconnection Customer, LARS \nAssociated Transmission Customer, or Transmission Owner prior to the execution \nor unexecuted filing of the final LLGIA shall cause the LARS Interconnection \nRequest to be deemed withdrawn. \n \nAfter entering the Large Load Addition Resource Study as defined in Section \n3.12.4, no changes to the In-Service Date or Commercial Operation Date of the \nGenerating Facility is permitted via section 4.4.4 except that a LARS Application \nthat is deferred to the next available LARS Study Period will be allowed to extend \nits In-Service Date or Commercial Operation Date to be no more than three calendar \nyears from the kickoff of the LARS Study Period in which its LARS Application is \nstudied.  At the completion of the Large Load Addition Resource Study, the \nCommercial Operation Date and Service Commencement Date for the LARS \nAssociated Load shall be set forth in the LLGIA.   \n \nConsistent with Article 2.3.1 of the LLGIA, once that LLGIA is executed or filed \nunexecuted, if the Generating Facility fails to reach Commercial Operation by the \nspecified Commercial Operation Date set forth in the LLGIA, such specified \nCommercial Operation Date as set forth in the LLGIA may be extended by \nInterconnection Customer for a period up to three (3) consecutive years, after which \nTransmission Provider shall terminate the  LLGIA if the Generating Facility has \nstill failed to reach Commercial Operation. \n \nThe proposed language is necessary to ensure that LARS Applications are able to be studied on \nboth the load and generation side within the timeframe required by LARS. MISO has to have \ncertainty to complete these studies in parallel and in 120 days.  Thus, it is not allowing any \nmodifications to the information provided in the LARS Application and any modification made \nwill result in the withdrawal of the LARS Application.  Similarly, the proposed LARS COD \nrequirements set forth in GIP Section 3.3.1 are specifically for generation needed to meet load \nintended to come online while LARS is in place.  Disallowing changes to the In-Service Date or \nCOD after entering LARS again provides the certainty necessary to ensure that these projects will \nremain paired during the process and will prevent projects with uncertain timelines from entering \nLARS."},{"page":38,"startToken":18418,"endToken":18915,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 38 \n \n \n \n16. Section 11 – Generator Interconnection Agreement (GIA), Facilities \nConstruction Agreement (FCA), and Multi-Party Facilities Construction \nAgreement (MPFCA) \nProposed revisions to Section 11.1 include the distinction that LARS projects will not \ncomplete restudies and that the tender of the draft LLGIA will occur after the Interconnection \nFacilities Study is initiated through LARS.  MISO also proposes to revise this Section to clarify \nthat LARS Interconnection Requests tender of the LLGIA will occur on a different timeline than \nDPP projects, which timeline for tender is memorialized in new GIP Section 3.12.6.  These edits \nare necessary to properly document the shortened timeline for tender of LARS projects and the \ndifferences in timing between LARS projects with one study and DPP projects with multiple \nstudies. \nMISO proposes to revise Section 11.2 to clarify that LARS projects will have a shorter, 10 \nBusiness Day timeline to return comments on the draft LLGIA.  MISO also proposes to revise this \nSection to clarify that MISO shall tender a revised draft LLGIA after 5 Business Days of receiving \nthe comments.  For LARS projects, negotiations of LLGIAS shall be no more than 20 Business \nDays from the notice to proceed in Section 3.9.4. Revisions to 11.2.1 clarify that LARS projects \nare unable to postpone the start of the LLGIA negotiation period.  These edits are needed to shorten \nthe negotiations timeframe to keep the LARS process to approximately 120 days from kickoff to \nLLGIA execution.  This shortened timeframe will ensure that LARS projects are able to execute \nthe LLGIA quickly and come online within the timeframe allotted to serve the project’s identified \nneed. \nMISO proposes to revise Section 11.3 to provide that for LARS projects the Transmission \nProvider shall provide the Interconnection Customer and Transmission Owner a final LLGIA \nwithin 15 Business Days after completion of the negotiation period in accordance with Section \n11.2.  These revisions also provide that the parties must execute the LLGIA or request to file \nunexecuted within 15 Business Days of tender of the final LLGIA, otherwise the project will be \ndeemed to have withdrawn its Interconnection Request.  These revisions are required to properly \ndocument the shorter timeline for LARS projects as compared to the timeline for DPP GIA \nexecution as memorialized in this Section. \nThe proposed revisions of Section 11.4 simply expand the requirements related to the \ncommencement of interconnection activities to LLGIAs.  \nB. \nAttachment X – Appendix 1 (Interconnection Request for a Generating \nFacility) \n \nMISO is proposing to revise this Appendix to integrate the LARS framework into the \ninterconnection request form.  These revisions include adding new options for interconnection \nrequests and interconnection service to accommodate LARS, confirm that the amount of \nInterconnection Service cannot exceed 150% of the total amount of its LARS Associated Load, to \ndescribe the requirements for LARS Associated Load and facilities to connect to the Transmission \nSystem, along with System Protection Facilities or operating procedures to prevent injections onto"},{"page":39,"startToken":18915,"endToken":19314,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 39 \n \n \n \nthe Transmission System beyond the substation and voltage level where the Resource is located, \nand to describe requirements for the disclosure of additional information for MISO to evaluate the \nrequest.  The specific changes are: \n \n• Section 1: MISO has added a new section requiring information for the LARS \nApplication.  \n \n• Section 2: MISO has added a new check box for a Generating Facility to indicate the \nInterconnection Request is for processing through the Large Load Addition Resource \nStudy process. \n \n• Section 4: MISO has added a new address or location section for the LARS Associated \nLoad to fill out.  \n \nMISO has also added a new row for NRIS Service requested for processing through LARS \nto the table of required information by type of service requested.  This row requires the \nInterconnection Customer to indicate the MW/MVAR of the request and states that the amount of \nNRIS shall not be less than 200 MW and not exceed 150% of the LARS Associated Load’s peak \ndemand expected over any one-hour period, including the load MW amount and the percentage.   \n \nMISO added a new sub-section (e) for LARS Interconnection Requests anticipated Service \nCommencement for the LARS Associated Load by day, month, and year.  A new contact section \nwas added for the LARS Associated Transmission Customer and the LARS Associated Load \ncontact.  \n \nMISO added a new sub-section (h) requiring an agreement executed by the Interconnection \nCustomer and the entity that owns or controls the LARS Associated Load meeting the requirements \nof Section 3.12.2 of the Generator Interconnection Procedures.  \n \nIn sub-section (i), MISO added new information requirements including the POI MTEP \nsubstation bus number, the LRZ of the POI, and the attestation required by Section 3.12.1 of the \nGenerator Interconnection Procedures.  \n \nMISO added a new sub-section (t), requiring the identification of the LARS Associated \nLarge Load POW, the LRZ the POW is located in, and amount of Transmission Service Requested \nfor the LARS Associated Load.  \n \n• Attachment A-5: MISO has added a new paragraph below the dynamic modelling \ninformation required for other types of Interconnection Requests to require to require \nInterconnection Customers participating LARS to provide a detailed power flow model \nthat includes the LARS Associated Load, its Point of Withdrawal, and the POI for the \nInterconnection Request, as well as system protection facilities.  This provides necessary \ninformation for MISO to study the Interconnection Request."},{"page":40,"startToken":19314,"endToken":19746,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 40 \n \n \n \n• Attachment A-6: MISO has added a paragraph requiring that all inverter-based generators \nmust comply with all modeling requirements specified in BPM-015 and that all LARS \ninverter-based generators must comply with the modeling requirements specified in BPM-\n015 Appendix I.  \nMISO submits that these requirements are just, reasonable, and necessary to the \nperformance of LARS process given the formal pairing of the Generating Facility and LARS \nAssociated Load to this new type of study process.   \nD. \nAttachment X – Appendix 6 (Generator Interconnection Agreement) \nMISO is proposing to revise this Attachment to require contractual commitments \nassociated with the LARS Associated Load.  \n1. Revisions to Recitals  \nMISO proposes a new fifth recital for use in the LLGIA that explains that the output of the \nGenerating Facility will be used to serve the LARS Associated Load.  Including this recital \nprovides clarity about what the LLGIA does at the front of the document.96   \n2. Revisions to Article 1—Definitions \nMISO proposes to include the same new and revised definitions in the LLGIA that are \nproposed for inclusion in the GIP.   The proposed terms and definition language are identical to \nthose described above for GIP revisions except for non-substantive edits needed to reflect the \nlocation of the definition in the LLGIA rather than the GIP.97  MISO refers to its discussion above \nand asks that the Commission accept the definition changes as just and reasonable for the reasons \nexplained in the discussion of these changes.  \nMISO also added the following definition for the LARS study process to indicate the point \nin the system where the LARS Associated Load is connected: \nPoint(s) of Withdrawal (POW) shall mean the point(s) where a non-transmission facility \nthat is used to withdraw Energy from the Transmission System to serve Load connects to \nthe Transmission System.98 \nMISO proposes this definition in order create a load equivalent to the existing defined term, Point \nof Interconnection, which is used to describe the point at which the Interconnection Facilities \n \n96  When merged with Appendix 6, MISO would include this recital in brackets indicating it is to be used only for \nLLGIAs. \n97  These changes consists of revising “these GIP” to “the GIP” in Appendix 19 in order to avoid confusion.  The \nchange is not intended to be substantive.  \n98  MISO proposed this defined term as part of its ZGIA filing.  While the definition remains pending, MISO proposes \nit again here because LARS utilizes this concept and is being built from Attachment X, Appendix 6 rather than \nAppendix 19 where the pending definition is included."},{"page":41,"startToken":19746,"endToken":20216,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 41 \n \n \n \nconnect to the Transmission System.  Because the relative location and configuration of Load with \nrespect to the Generating Facility and to the Transmission System is a critical component LARS, \nvocabulary is needed to discuss the point where the LARS Associated Load connects to the \nTransmission System in reference to the Point of Interconnection.  The term “Point(s) of \nWithdrawal” provides a delineation between the two points that facilitates clearer Tariff rules.  \n3. Revisions to Article 2.3—Termination Procedures \nMISO proposes revising Article 2.3.1 describing the conditions under which a LLGIA will \nbe terminated by the Transmission Provider. The proposed revisions are as follows: \nThis LLGIA shall be terminated by Transmission Provider after giving \nInterconnection Customer ninety (90) Calendar Days advance written notice if:   \n \n \n(1) the LARS Associated Load or a portion of the LARS Associated Load fails to \nachieve a Service Commencement Date for Transmission Service by the \nCommercial Operation Date for this Generating Facility, including any extension \nprovided thereunder; or   \n \n(2) within the first fifteen (15) Calendar Years after the LARS Associated Load \ncommences use of the Transmission Service granted through LARS, the LARS \nAssociated Load or a portion of the LARS Associated Load has ceased use of \nTransmission Service granted through LARS for a period of one year beginning \nwith the last date of use of such Transmission Service; or   \n \n(3) within the first fifteen (15) Calendar Years after the LARS Associated Load \ncommences use of the Transmission Service granted through LARS the agreement \nrequired by GIP Section 3.12.2.i is terminated or otherwise ceases to be in effect \nexcept that a replacement agreement that satisfies the requirements of GIP Section \n3.12.2.i involving the same Generating Facility and LARS Associated Load. \n \n \nIn the event that the LARS Associated Load ceases use of its Transmission Service \nor the agreement required by Section 3.12.2.i terminates within the first fifteen (15) \nCalendar Years after the LARS Associated Load commences use of the \nTransmission Service granted through LARS, this Agreement shall be terminated \none year after the date of such occurrence.  During such one year period the \nGenerating Facility shall be allowed to operate subject to the Annual ERIS \n(“AERIS”) and the Quarterly Operating Limit (“QOL”) processes as specified in \nBPM-015 Section 6.6 in order to allow the Interconnection Customer to obtain new \nInterconnection Service pursuant to the GIP.  If the DPP processing is delayed \nbeyond one year due to factors beyond the Interconnection Customer’s control, then \nthis LLGIA shall be extended until the relevant DPP studies are completed provided \nInterconnection Customer’ Interconnection Request is not withdrawn. \n \n \nWhere: (1) the LARS Associated Load fails to commence service for the full \namount of Transmission Service requested in the LARS Application by the"},{"page":42,"startToken":20216,"endToken":20678,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 42 \n \n \n \nCommercial Operation Date for this Generating Facility, including any extension \nprovided thereunder; (2) ceases use of such full output within the first fifteen (15) \nCalendar Years after the LARS Associated Load commences use of the \nTransmission Service granted through LARS for a period of one year beginning \nwith the last date of use of such Transmission Service; or (3) the parties to the \nagreement required by Section 3.12.2.i reduce the MW output from the Generating \nFacility that the LARS Associated Load intends to utilize within the first fifteen \n(15) Calendar Years after the LARS Associated Load commences use of the \nTransmission Service granted through LARS, Transmission Provider shall only \nterminate the portion of the Interconnection Service granted under this LLGIA that \nexceeds 150% of the reduced peak Demand being utilized by the LARS Associated \nLoad. \n \n \nFollowing the first fifteen (15) Calendar Years after a LARS Associated Load \nceases use of its Transmission Service or if the agreement required by GIP Section \n3.12.2.i is terminated or otherwise ceases to be in effect, then Transmission \nProvider shall not terminate the Generating Facility’s Interconnection Service.  \n \nThis proposed section lays out the instances where a LLGIA will be terminated, which includes \nwhen the LARS Associated Load (or some portion thereof) fails to achieve a service commence \ndate by the COD of the Generating Facility, when LARS Associated Load has ceased use of the \ntransmission service granted through LARS for a period of one year, or when the required executed \nagreement under GIP Section 3.12.2.i is terminated.   \nThe second paragraph goes into additional detail regarding what happens when the LARS \nAssociated Load no longer operates.  The Generating Facility’s LLGIA is not immediately \nterminated but it is granted up to one year to acquire new Interconnection Service.  During that \nyear, the Generating Facility must operate subject to MISO’s AERIS and QOL processes as \nspecified in the BPM.  \nMISO refers the Commission to its discussion of parallel language in GIP Section 3.12.7.4 \nas described in this transmittal letter, for additional explanation of why this language is just and \nreasonable.99   \nThe third paragraph addresses the situation where the LARS Associated Load changes its \namount of Transmission Service to a lower amount than was originally requested in the LARS \nApplication.  In that circumstance, MISO will only terminate (or amend) the portion of the \nInterconnection Service granted by the LLGIA that exceeds 150% of reduced peak demand being \nutilized by the LARS Associated Load.  This will ensure that the generation remains paired with \nthe load and results in an amended LLGIA for the Generating Facility.  \n \n99  See discussion regarding Attachment X, Section 3.12.7.4, supra at pp. 34-36."},{"page":43,"startToken":20678,"endToken":21155,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 43 \n \n \n \nMISO is also revising Article 2.3.3 to state that LARS projects must provide all security \nrequired in Section 2.4 prior to any termination request for a LARS project becoming effective.  \nThe proposed language is as follows: \nFor LLGIAs, all security as required by Section 2.4 shall be provided prior to \ntermination.   \n \nFor LLGIAs, any termination or withdrawal of the LARS Application from LARS \nor any cessation of operations or discontinuation of Transmission Service by the \nLARS Associated Load shall be an event of default pursuant to Article 17 of this \nLLGIA.  \n \nThis language is necessary to ensure that projects are held liable for any Network Upgrades that \nwould be memorialized in an LLGIA or related agreement and to prevent harm to other projects \ndue to the withdrawal. \nMISO is proposing to revise Article 2.4 to specify that should a LARS project terminate, it \nwill be liable for any Network Upgrade costs identified in the LLGIA or that would be \nmemorialized in an FCA, MPFCA, or JTIQ Service Agreement.  The proposed language is as \nfollows: \nIn the event that this LLGIA is terminated by Interconnection Customer, Interconnection \nCustomer is responsible for the full cost of all Network Upgrades that are designated as \nGIP projects and are identified in this LLGIA as well as any GIP Network Upgrades \nidentified during the LARS process that are to be memorialized in an agreement other than \nthis LLGIA, including any applicable FCA, MPFCA, or JTIQ Service Agreements.  If the \nNetwork Upgrade costs for Network Upgrades subject to an FCA, MPFCA, or JTIQ \nService Agreement have not been finalized or the Interconnection Customer has not made \nthe payment under such agreement as of the date that termination of this LLGIA is sought, \nInterconnection Customer shall provide the payment or security for such Network \nUpgrades in the amount required by the applicable agreement.  If such agreement has not \nbeen executed and final costs are not available as of a date that termination is sought, \nInterconnection Customer shall provide such payment or security in an amount \ncorresponding to the most recent estimate provided by the Transmission Provider during \nthe LARS process.  Interconnection Customer shall pay or Transmission Provider shall \nrefund, as applicable, to Interconnection Customer the difference between the amount of \nany estimated payment or security made pursuant to this Article and the final cost of such \nNetwork Upgrade within ninety (90) Calendar Days after such final costs are invoiced to \nthe Interconnection Customer. \n \nThese additions are necessary to establish that if the final costs have not been determined, the \nCustomer must provide security according to the most recent estimate.  Additionally, the \nTransmission Provider will provide any applicable refunds of payments or security within 90 \nCalendar Days of providing the final invoice of NUs to the Customer.  As stated above, the"},{"page":44,"startToken":21155,"endToken":21595,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 44 \n \n \n \nproposed language is necessary to ensure that only “shovel ready” projects submit to LARS, \nknowing those projects will assume the risk of paying for any Network Upgrades identified in an \nLLGIA or that would be memorialized in an FCA, MPFCA, or JTIQ Service Agreement.  This \nlanguage will ensure that no other projects are affected by the termination. \n4. Revisions to Article 4.1—Interconnection Product Options \nMISO also proposes adding a check box in Article 4.1 to indicate whether the LLGIA has \nbeen processed through the LARS Study Process.  The option indicates that ER and NR are the \nonly options.  \n5. Revisions to Article 9.7.4.7—Operations under an LLGIA prior to Service \nCommencement Date \n \n \nMISO proposes to add new article 9.7.4.7 establishing the obligation of a \nGenerating Facility with an LLIGA prior to service commencement date.  The proposed revisions \nare as follows: \nIf this GIA is an LLGIA, Interconnection Customer shall not commence Commercial \nOperation or otherwise inject electricity onto the Transmission System prior to the Service \nCommencement Date of the LARS Associated Load except for injections associated with \ntesting otherwise allowed by this LLGIA.  In the event that the LARS Associated Load \ncommences service for an amount of Transmission Service less than the amount requested \nin the LARS Application, Interconnection Customer’s injections shall be subject to the \nAnnual ERIS Evaluation Study and Quarterly Operating Limits processes as described in \nSection 6.6 of the Generator Interconnection Business Practices Manual and may be limited \nto the current Demand of the LARS Associated Load until such time as the LARS \nAssociated Load has commenced service. \nThese provisions allow the Generating Facility to operate even when the LARS Associated Load \nhas commenced service for lower than the total amount identified in the LARS Application.  This \nsituation will likely occur when the LARS Associated Load is being phased in over time.  These \nprovisions will allow the Generating Facility to begin providing service to the load but subject to \nthe Annual ERIS Evaluation Study and Quarterly Operating Limits processes as described in \nSection 6.6 of the Generator Interconnection Business Practices Manual.  The provisions also \nexplain that the Generating Facility’s output may be limited to the current Demand of the LARS \nAssociated Load until such time as the LARS Associated Load has fully commenced \nservice.  These revisions are a just and reasonable approach to addressing timing mismatches that \ncan occur in practice between when the Generating Facility and LARS Associated Load enter \nservice, which may occur where the LARS Associated Load is delayed or comes online in phases."},{"page":45,"startToken":21595,"endToken":22028,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 45 \n \n \n \n6. Revisions to Appendices  \nMISO proposes several revisions to Appendix A in order to implement the LARS process.   \nFirst, MISO proposes to include a new Section 2 that includes a description of the LARS \nAssociated Load, identifying the MW, Point(s) of Withdrawal and need by date of the ZG \nAssociated Load.  This section requires a single line diagram illustrating the connections between \nthe Generating Facility, ZG Associated Load, and the Transmission System and the identification \nof the equipment and configurations that prevent injections outside of the Transient Tolerance \nWindow.   \nThis section reflects the technical requirements applicable to a LARS Associated Load \nparticipating in LARS and makes the studied equipment and configuration a part of the LLGIA \nthat can be enforced.  This requirement works with MISO’s material modification rules in the same \nway that section 1 operates to ensure that changes to the configuration of the AG Associated Load \nthat could affect the impacts of the ZG Interconnection Service as studied are subject to the same \nmodification rules applicable to the Generating Facility under Section 1 of Appendix A.  This is \nnecessary and appropriate given the importance of these configuration details to the completion of \nthe LARS process. \nMISO also proposes revisions to Appendix B, the revisions are made to milestone 1f to \ninclude LARS in the agreement requirement for an Affected System study process pursuant to GIP \nSection 3.5.4.  \nE. \nAttachment FF (Transmission Expansion Planning Protocol)   \nMISO is proposing to add a new sub-section (ii) to Section I.D.1.b of Attachment FF to \nimplement the requirements of the LARS process reflected in Attachment X but for the LARS \nAssociated Transmission Customer.  MISO included relevant explanations of the Interconnection \nCustomer’s responsibilities in this new proposed section to ensure alignment with new revisions \nto Attachment X to implement LARS.   \nThe reasoning for the new provisions proposed in Section I.D.1.b.ii.(a) for the LARS Pre-\nSubmission Coordination Process are the same as the previously described Sections 3.12.1 of \nAttachment X.  \nMISO added a new section to address the LARS Application Timing and Deposits for the \nload study.  The proposed revisions are as follows: \nThe LARS Associated Transmission Customer is responsible for submitting the \nLARS Application. Both the Transmission Owner supporting the LARS \nApplication and requesting to join LARS shall submit the required Large Load \ninformation to the MTEP Portal and an Interconnection Customer supporting the \nLARS Application and requesting to join LARS shall submit their Interconnection \nRequest with the LARS Associated Transmission Customer to the Transmission"},{"page":46,"startToken":22028,"endToken":22529,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 46 \n \n \n \nProvider no later than the LARS Application deadline as published on the MISO \npublic website, at least twenty (20) Business Days prior to the scheduled kick-off \nof the LARS study period published on the MISO public website and as described \nin Section 3.12 of Attachment X. A valid LARS Interconnection Request shall be \nincluded in the next available LARS study period that commences after such \nrequest is submitted.  \n \nA LARS Application shall be accompanied by a Non-Refundable Deposit 1 (D1) \nof $250,000 submitted by the LARS Associated Transmission Customer. Additional \nLARS Study Deposits such as D2 as described in Section 3.3.1 of Attachment X \napply to the LARS Application and shall be submitted by the Interconnection \nCustomer. All applicable deposits, milestone payments and data required to enter \nthe Large Load Addition Resource Study must be received at the time the LARS \nApplication is submitted. \n \nThe purpose of this section is to align the timing of the LARS generation study with the load study. \nThe second paragraph also identifies which parties are responsible to pay which deposits.  \nSection I.D.1.b.ii.(c) includes the proposed LARS Application requirements for the load \nstudy and identifies what information must be provided to MISO.  This section closely aligns with \nthe existing information requirements of the EPR process.  Otherwise, the remaining proposed \nrequirements match those included in Section 3.12.2 of Attachment X and were previously \nexplained in the Attachment X section.  \nThe new provisions of Sections I.D.1.b.ii.(d) describe and implement the same evaluation \nprocess for LARS Applicants as those previously described in Sections 3.12.3 of Attachment X.   \nThe new provisions of Sections I.D.1.b.ii.(e) describe and implement the LARS cure and \ndeficiency periods as described in Section 3.3.3 of Attachment X.  The proposed revisions to \nAttachment FF are as follows: \nA LARS Application will not be considered valid until all items in Section 3.12 of \nAttachment X and Section I.D.1.b.ii of Attachment FF, have been received by \nTransmission Provider. If the LARS Application fails to meet the requirements, \nTransmission Provider shall notify the Transmission Customer within fifteen (15) \nBusiness Days of receipt of the LARS Application either that the Transmission \nProvider has accepted the Application as valid or has determined that the \nApplication is not valid due to one or more deficiencies. In the event Transmission \nProvider determines that the Application does not meet all the requirements and \nthus is not valid, Transmission Provider shall also provide an explanation of the \nreasons for such determination. The Transmission Customer shall have ten (10) \nBusiness Days from the date that the Transmission Provider identifies the \nApplication as deficient to provide the additional requested information needed to \nconstitute a valid request. The requirements of Section 3.3.3 of Attachment X apply \nto LARS Applications. The Transmission Provider will have one period of review"},{"page":47,"startToken":22529,"endToken":23078,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 47 \n \n \n \nto identify deficiencies and the entities identified in the LARS Application shall \nhave one cure period to address deficiencies.  \n \nThis section was necessary to add to Attachment FF because the LARS Application must contain \nthe information required by Section I.D.1.b.ii.(c).  MISO clarified in both Attachment X and in \nAttachment FF that it will have one single review period to identify any deficiencies in the LARS \nApplication and the applicants will have one single cure period to address those deficiencies.  That \nis necessary to ensure that LARS process only lasts approximately 120 days. MISO cannot be \ndelayed by numerous deficiency and cure periods.  \nThe new provisions of Sections I.D.1.b.ii.(f) describe and implement the refund process \nfor the LARS study. Any difference between the study deposit and the actual cost of the study will \nbe paid by or refunded to the Interconnection Customer.  \nThe new provisions of Sections I.D.1.b.ii.(g)-(i) first describe and implement the \nresponsibilities of the Interconnection Customer or the LARS Associated Transmission Customer \ndepending on whether the load or the generation withdraws from LARS after the LLGIA is \nexecuted.  The section states that the parties will remain responsible for the costs identified in the \nLLGIA if the project is withdrawn depending on which party caused the withdrawal.  The new \nprovisions in sub-section (h) clearly state that no modifications of the LARS Application are \npermitted following its submission.  This is to ensure that MISO may complete the necessary \nstudies in order to provide MTEP approval and a LLGIA on the approximate 120-day timeline \nrequired by LARS.  Finally, the new provisions in sub-section (i) assign the costs of any necessary \nmitigations developed to address violations observed in the following instances: 1) violations \nobserved only in the transmission studies to study the impact of the load; 2) violations observed in \nboth the load and generation studies; and 3) violations observed in only the generation study.  \nMitigation costs are then assigned to either the Interconnection Customer or the LARS Associated \nTransmission Customer depending on which instance applies.  \nThe new provisions of Section I.D.1.b.ii.(j) addresses consideration of including generating \nfacilities in the LARS study process. The proposed revisions are as follows: \nIn accordance with the LARS definitions, Section 3.3.1, and Section 3.12 of \nAttachment X, and notwithstanding the requirements of Section I.D.1.b.ii, a \ngenerating solution that does not yet have generator interconnection agreement \nfiled with the Commission pursuant to Attachment X of this Tariff may be \nconsidered as an alternative transmission solution if: (1) a valid Interconnection \nRequest for such Generating Facility has been submitted for processing under the \nLARS process specified by Attachment X to the Tariff; and (2) the Transmission \nProvider has received an executed agreement between the LARS Interconnection \nCustomer, the entity(ies) with the LARS Associated Load with a minimum of 200 \nMW, and the LARS Associated Transmission Customer that satisfies the \nrequirements of Attachment X, Section 3.12.2(i) with a minimum term of at least \nfive years to align with MISO’s transmission planning horizon to ensure the ability \nto provide adequate lead time for an alternative transmission solution should the"},{"page":48,"startToken":23078,"endToken":23534,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 48 \n \n \n \nagreements terminate.  The study will be performed for each LARS Associated \nLoad, including the Interconnection Request, capturing the cumulative impact \nbased on their submission date per LARS Study Period. The outcome of the LARS \nAssociated Load study is MTEP approval of the load and associated optimized \nnetwork upgrades.  \n \nIn the event that the Load In-Service Date is prior to the date on which the proposed \nLARS Resource achieves Commercial Operations, the Transmission Provider may \neither; (1) require the applicable Load Serving Entity to delay the in-service date of \nthe LARS Associated Load until such time as an alternative solution can be placed \nin service or the Generating Facilities achieve(s) Commercial Operation in \naccordance with Section I.D.1.b.ii of this Attachment; or (2) impose operational \nlimitations on the LARS Associated Load that the Transmission Provider \ndetermines are reasonably necessary to maintain the reliability of the Transmission \nSystem until such time as the Generating Facility achieves Commercial Operation \nor an alternative solution is placed into service. \n \nThere will be no restudies if a load withdraws from the LARS process.  \n \nThese provisions describe situations where a generating solution does not yet have a GIA on file \nwith the Commission and indicates that it may be considered as an alternative transmission \nsolution in the LARS load study if: (1) a valid Interconnection Request for such Generating Facility \nhas been submitted for processing under the LARS process specified by Attachment X to the Tariff; \nand (2) the Transmission Provider has received an executed agreement between the LARS \nInterconnection Customer, the entity(ies) with the LARS Associated Load with a minimum of 200 \nMW, and the LARS Associated Transmission Customer that satisfies the requirements of \nAttachment X, Section 3.12.2(i). The provisions also explain that if the LARS Associated Load’s \nin-service date is prior to the COD of the Generating Facility, then MISO can: 1) require the LSE \nto delay the in-service date of the LARS Associated Load until such time as an alternative solution \ncan be placed in service or the Generating Facilities achieve(s) COD in accordance with Section \nI.D.1.b.ii of this Attachment; or (2) impose operational limitations on the LARS Associated Load \nthat MISO deems are reasonably necessary to maintain the reliability of the Transmission System \nuntil such time as the Generating Facility achieves Commercial Operation or an alternative \nsolution is placed into service. \nFinally, the new provisions added in Section I.D.1.b.ii.(j) state that MISO will not complete \nany restudies if a LARS Associated Load withdraws from the LARS process. This is to ensure that \nthe integrity and swiftness of the LARS process is maintained."},{"page":49,"startToken":23534,"endToken":24014,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 49 \n \n \n \nV. \nTHE LARS STAKEHOLDER PROCESS \n \nMISO developed LARS through an iterative stakeholder process focused on the \nrelationship between significant new load, associated generation, and the need to maintain system \nreliability.  The LLWG itself is charged with addressing large-load issues across markets, reliable \noperations, planning, and resource adequacy.100  Stakeholders first raised the need to coordinate \nlarge load and generator interconnection studies through MISO’s issue process.101  In early January \n2026, MISO convened a Large Load Additions Workshop where it presented its forecast of large \nload additions, which showed large load additions escalating sharply over the next several years, \ndriven primarily by data centers, and noted that federal policy supporting artificial intelligence was \naccelerating near-term growth.102  \n \nLarge loads continued to be a significant topic of conversation in all of MISO’s stakeholder \nmeetings.  To provide a dedicated forum for large load matters, MISO’s Steering Committee \napproved a charter for the Large Load Working Group.103  The LLWG reports to MISO’s Advisory \nCommittee and is chartered to provide input and policy guidance to MISO Management and the \nAdvisory Committee on market, reliability, planning, and resource adequacy matters related to the \nintegration of large loads within the MISO footprint.  The LLWG held its first meeting on April \n20, 2026.104  In its first several meetings, the LLWG took up the large load interconnection \nreliability requirements (LLWG-2026 3), reserve product enhancements for large load (LLWG-\n2026-2), Firm Service Step Up for large load interconnections (LLWG-2026-1), and the ZGIA \n(PAC-2024-4B), each of which forms part of the broader large load framework within which LARS \nwas developed.105 \n \nOn June 18, 2026, the Commission issued an order directing MISO to show cause why its \nTariff remains just and reasonable without provisions tailored to large loads, or to propose Tariff \n \n100  MISO, LLWG Charter at 1, supra note 20. \n101  On January 29, 2025, Clean Grid Alliance (“CGA”) presented Issue PAC-2024-7, Sharing and Coordinating \nMTEP and DPP to Accommodate Large Load, to the PSC. Coordinating Large Load and Generator \nInterconnection \n(PAC-2024-7), \nPLANNING \nSUBCOMMITTEE \n(Jan. \n29, \n2025), \navailable \nat:   \nhttps://cdn.misoenergy.org/20250129%20PSC%20Item%2007%20Sharing%20and%20C \noordinating%20MTEP%20and%20DPP%20to%20Accomodate%20Large%20Load%20( \nPAC-2024-\n7)674624.pdf.  \n102  Large Load Additions Workshop, MIDCONTINENT INDEP. SYS. OPERATOR (Jan. 30, 2026), available at: \nhttps://cdn.misoenergy.org/20260130%20Large%20Load%20Workshop%20Presentation 738349.pdf.  \n103  See LLWG Charter, supra note 20. \n104  See MISO, LLWG (Apr. 20, 2026available at: https://www.misoenergy.org/events/2026/large-load-working \ngroup-llwg---april-20-2026/; Large Load Working Group (LLWG), MIDCONTINENT INDEP. SYS. \nOPERATOR, available at: https://www.misoenergy.org/engage/committees/large-load-working-group/. \n105  Minutes, \nLARGE \nLOAD \nWORKING \nGROUP \n(June \n10, \n2026), \navailable \nat: \nhttps://cdn.misoenergy.org/20260629%20LLWG%20Item%2001c%20Minutes%202026 \n0610764681.pdf \n(“LLWG June 10 Minutes”); see also Liaison Report, LARGE LOAD WORKING GROUP at 3-10 (Sept. 9,"},{"page":50,"startToken":24014,"endToken":24570,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 50 \n \n \n \nrevisions.106  MISO held a special Steering Committee meeting on July 7, 2026, where it \ndetermined that the LLWG would be the forum for continued discussion of the large load issues \nthat had been proceeding at the PAC, including the ZGIA and the Large Load Definition.107  In its \nliaison report at the July 16, 2026 LLWG meeting, MISO described the three core objectives of its \nlarge load framework: to “[c]onnect within 120 days with all studies completed and GIAs signed,” \nto “[t]ransition and scale with flexible options consistent with timing of network upgrade \nbuildouts,” and to “[s]ustain reliable operations with ability to withdraw or inject energy based on \nconditions and signals.”108 \n \nAt the July 16, 2026, LLWG meeting, MISO first introduced the LARS proposal as a new \nissue and titled it the Generation and Large Load Alignment proposal.  MISO sought stakeholder \ninput concerning the eligibility and design of a process for studying new large loads and their \nassociated generation.109  MISO specifically asked stakeholders whether a minimum threshold of \n250 MW appropriately captured high-impact loads and, if not, what alternative threshold would \nbetter capture those loads without diluting the purpose of the process.110  MISO asked for written \nfeedback by July 30, 2026, asking stakeholders in particular whether 250 MW was the right \nthreshold, what readiness and securitization rules should apply to prevent speculative requests, and \nwhat other improvements were needed, and outlined its next steps as review of draft Tariff \nlanguage at the August 27, 2026 LLWG meeting and a Tariff filing in September 2026.111 \n \nMISO continued to refine the proposal following that feedback.  At the August 27, 2026 \nLLWG meeting, MISO formally presented LARS as a process for concurrently studying Large \nLoads and associated generation and circulated draft Tariff language for stakeholder review.112  \nMISO summarized the outcomes of the process as an allocation of Interconnection Service to the \ngenerator, transmission service for reliable withdrawal by the load, and optimized Network \n \n2026), available at: https://cdn.misoenergy.org/20260909%20LLWG%20Item%2003%20Liaison%20Report \n779834.pdf. \n106   Show Cause Order at P 122 (directing MISO to submit, within 30 days, an informational report on proposals \nunder consideration in its stakeholder process to address resource adequacy for new large loads, with a schedule \nof key milestones and anticipated filing dates). \n107  Liaison \nReport, \nLARGE \nLOAD \nWORKING \nGROUP \nat \n8 \n(July \n16, \n2026), \navailable \nat: \nhttps://cdn.misoenergy.org/20260716%20LLWG%20Item%2004%20Liaison%20Report 768708.pdf (“LLWG \nJuly 2026 Liaison Report”); Minutes, LARGE LOAD WORKING GROUP at 4 (July 16, 2026), available at: \nhttps://cdn.misoenergy.org/20260812%20LLWG%20Item%2001c%20Minutes%202026 0716771087.pdf. \n108  LLWG July 2026 Liaison Report at 4.  \n109  MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6 (July 16, 2026). \n110  MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Stakeholder Feedback (July 30–31, 2026) \n(requesting feedback on whether “≥250 MW” was the appropriate minimum and what alternative threshold would \ncapture high-impact loads without diluting the proposal’s intent). \n111  Generation and Large Load Alignment (LLWG-2026-6), LARGE LOAD WORKING GROUP (July 16, 2026), \navailable \nat: \nhttps://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20an \nd%20Load%20Alignment%20Presentation768740.pdf (“LLWG July 2026 Presentation”). \n112   MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6 (Aug.  27, 2026)."},{"page":51,"startToken":24570,"endToken":25073,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 51 \n \n \n \nUpgrades, and stated that the study process and GIA would together be completed in 120 calendar \ndays.113 MISO also posted draft Tariff language implementing LARS and requested that \nstakeholders provide feedback on the proposed Tariff redlines and identify any additional process \nclarifications needed through the Stakeholder Feedback Tool by September 10, 2026.114 \n \nAs a result of stakeholder feedback, MISO changed the LARS process minimum Large \nLoad value to be 200 MW instead of 250 MW.  Stakeholders proposed a range of approaches to \nthe threshold.  The July LLWG stakeholder record includes a recommendation to reduce the \nminimum threshold from 250 MW to 200 MW to capture projects sufficiently large to warrant \ncoordinated load-generation evaluation while maintaining the proposal’s focus on projects with \nsignificant system impacts.115  Other stakeholders supported retaining a minimum-MW \nmechanism to limit the process to high-impact large loads.116  MISO made this change based on \nsignificant stakeholder feedback that many emerging data center and large industrial projects in \nthe 200-250 MW range can have significant system impacts and would benefit from the \ncoordinated study process. Lowering the threshold also allows access to the LARS framework \nwhile maintaining its focus on large, impactful load additions.  The 200 MW minimum threshold \nstrikes the right balance between different kinds of large load and hyperscalers.  \n \nAt the September 23, 2026, LLWG meeting, MISO presented the final proposed LARS \nprocess and updated tariff language for Attachement FF, Attachment X and associated Appendices \nin response to the September 10th feedback.  MISO explained that it had changed the minimum \nthreshold LARS Associated Load size to 200 MW (from the proposed 250 MW), allowed multiple \nGenerating Facilities to group at different POIs for one LARS Associated Load, and added a new \ncontract agreement option for LSEs.  MISO also clarified several of the requirements of the LARS \nprocess including addressing the concerns on representation of the LARS generator/load pair \nwithin the parallel study processes.117  \n \nThe stakeholder process also addressed the relationship between the load and generation, \nproject-readiness requirements, study assumptions, and the interaction between LARS and the \nexisting Generator Interconnection Queue.118  The resulting LARS proposal reflects MISO’s effort \n \n113  Large Load Addition Resource Study (LLWG-2026-6), LARGE LOAD WORKING GROUP at 7-10 (Aug. 27, \n2026), available at: https://cdn.misoenergy.org/20260827%20LLWG%20Item%2007%20Load%20Addition \n%20Resource%20Study%20(LLWG-2026-6)777236.pdf (“LARS August 2026 Presentation”). \n114  LARS August 2026 Presentation at 16.  \n115  Id. \n116  Id. (including OMS Work Groups feedback supporting a minimum-MW mechanism that limits the proposal to \nhigh-impact large loads). \n117  See MISO, LLWG, Large Load Addition Resource Study (LLWG-2026-6), (Sep. 23, 2026), available at: \nhttps://cdn.misoenergy.org/20260923%20LLWG%20Item%2006%20Large%20Load%20Addition%20Resourc\ne%20Study%20(LLWG-2026-6)782864.pdf.  \n118  MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6, Stakeholder Feedback (Sept.  2026) \n(reflecting stakeholder comments concerning project readiness, the relationship between associated load and \ngeneration, study models, and the interaction between LARS and the existing Generator Interconnection Queue)."},{"page":52,"startToken":25073,"endToken":25543,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 52 \n \n \n \nto establish a targeted process for significant new load additions while coordinating the study of \nassociated generation.  The 200 MW threshold maintains LARS’s focus on substantial load \nadditions while broadening eligibility beyond hyperscale projects exceeding 250 MW to include \nprojects involving larger manufacturing and industrial processes.  MISO worked closely with \nstakeholders to ensure that it considered and incorporated certain elements of feedback.   \n \n \nMISO submits that the Tariff revisions proposed in this filing establish a just, reasonable, \nand not unduly discriminatory mechanism for rapidly integrated large loads with paired generation.  \nThe Tariff revisions are limited in scope and in impact but offer significant benefits in terms of \nimproving the coordination between load and generation studies to reflect the joint impact of both \nthe generation and the load it will serve, and avoiding negative impacts to other MISO processes \nand the stakeholders who participate in them.  As proposed, LARS is both a powerful tool for \nresponding to urgent industry needs as well as a tailored solution with safeguards sufficient to \nguard against overuse of the process.  The benefits of LARS are not free.  Both the Interconnection \nCustomer and LARS Associated Transmission Customer are required to undertake commitments \nthat exceed those imposed on Interconnection Customers in the DPP.  These additional \ncommitments and risk are necessary to provide the certainty that allows LARS to move at an \nexpedited pace without negative impacts to other processes.  The LARS process is open to all \nInterconnection Customers that meet the Tariff’s requirements and that are willing to accept the \ngreater commitments and limitations imposed by LARS. \nVI. \nDOCUMENTS SUBMITTED IN THIS FILING \nIn addition to this Transmittal Letter, this submission includes: \nTab A – Redline Tariff;119 \nTab B – Clean Tariff; and  \nTab C – Prepared Direct Testimony of Christina Drake. \n \n119  Language currently pending before the Commission in the following docket and is highlighted in yellow: ER24-\n2046-003, ER26-3552-000, ER26-3777-000 and ER26-3813-000.  MISO requests that the Commission treat such \nhighlighted language as subject to the outcome of this pending proceeding.  MISO commits to file any revisions \nto this highlighted language as necessary to comply with any Commission orders in this proceeding.  MISO has \nremoved language that has a future effective date of 6/1/2029 and is pending in Docket No. ER22-1640-006.  \nMISO has removed language that has a future effective date of 6/1/2028 and is pending in Docket No. ER26-\n2825-000.  MISO has removed language from Attachment X, Appendix 6 – Generator Interconnection Agreement \nthat has an effective date of 7/28/2025 and is pending in Docket No. ER24-2046-003.  MISO commits to make a \nsubsequent filing with the Commission to reflect the most up-to-date versions of the then-current Tariff provisions \nprior to the effective date of the language accepted in Docket Nos. ER26-2825-000, ER24-2046-003, ER22-1640-\n006."},{"page":53,"startToken":25543,"endToken":25910,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 53 \n \n \n \nVII. \nEFFECTIVE DATE \nMISO requests an effective date of December 2, 2026 for the Tariff revisions submitted \nherein, which is not less than 60 days nor more than 120 days, after the filing date.  MISO intends \nto open the first LARS Study Period in the first quarter of 2027.  Acceptance of LARS by the \nrequested effective date is necessary to allow LARS to begin on this timeframe because the \nproposed rules require pre-submission coordination and for MISO to develop software to support \nthe LARS Application prior to opening the first LARS Study Period.  This effective date will allow \nthe revisions proposed herein to be effective in time for MISO and stakeholders to prepare for \nstudies with certainty regarding the applicable rule set.    \nVIII. \nCOMMUNICATIONS \nMISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of \nPractice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the \ndesignation of more than two persons for service on behalf of MISO in this proceeding and requests \nall communications related to this filing be directed to: \nChristopher D. Supino* \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System \nOperator, Inc. \n720 City Center Drive  \nCarmel, Indiana 46032  \nTelephone: (317) 249-5400 \ncsupino@misoenergy.org \nmkessler@misoenergy.org \n \nJames C. Holsclaw* \nCalfee, Halter & Griswold LLP \n3900 Salesforce Tower \n111 Monument Circle \nIndianapolis, Indiana 46204 \nTelephone: (317) 308-4266 \njholsclaw@calfee.com  \n \nIX. \nNOTICE AND SERVICE \nMISO has served a copy of this filing electronically upon all parties listed on the \nCommission’s eService list, and upon all Tariff customers, MISO Members, Member \nrepresentatives of Transmission Owners and non-Transmission Owners, as well as all state \ncommissions within the MISO Region and the Organization of MISO States.  The filing has been \nposted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for \nother interested parties in this matter. \nX. \nCONCLUSION \nFor all of the foregoing reasons, MISO respectfully requests that the Commission accept \nthis filing and grant waiver of any Commission regulations the Commission deems applicable, but \nnot specifically addressed above in order for the Commission to accept it as proposed."},{"page":54,"startToken":25910,"endToken":25989,"text":"The Honorable Debbie-Anne Reese \nOctober 2, 2026 \nPage 54 \n \n \n \nRespectfully submitted, \n \n/s/ Christopher D. Supino \nChristopher D. Supino \nManaging Senior Corporate Counsel \nMichael Kessler  \nManaging Assistant General Counsel \nMidcontinent Independent System \nOperator, Inc. \n720 City Center Drive  \nCarmel, Indiana 46032  \nTelephone: (317) 249-5400 \ncsupino@misoenergy.org \nmkessler@misoenergy.org \n \nJames C. Holsclaw \nCalfee, Halter & Griswold LLP \n3900 Salesforce Tower \n111 Monument Circle \nIndianapolis, Indiana 46204 \nTelephone: (317) 308-4266 \njholsclaw@calfee.com   \n \nAttorneys for the Midcontinent Independent \nSystem Operator, Inc."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":724,"startToken":0,"endToken":513},{"p":2,"at":724,"title":"I. Executive Summary","method":"PDF bookmark","endPage":2,"endAt":728,"startToken":513,"endToken":514},{"p":2,"at":728,"title":"EXECUTIVE SUMMARY","method":"printed heading","endPage":4,"endAt":1342,"startToken":514,"endToken":1546},{"p":4,"at":1342,"title":"II. Overview of the LARS Process","method":"PDF bookmark","endPage":4,"endAt":1379,"startToken":1546,"endToken":1552},{"p":4,"at":1379,"title":"A. BACKGROUND","method":"printed heading","endPage":4,"endAt":1383,"startToken":1552,"endToken":1553},{"p":4,"at":1383,"title":"BACKGROUND","method":"printed heading","endPage":5,"endAt":1538,"startToken":1553,"endToken":1973},{"p":5,"at":1538,"title":"B. STRUCTURE OF LARS AND PARTIES","method":"printed heading","endPage":7,"endAt":1677,"startToken":1973,"endToken":3041},{"p":7,"at":1677,"title":"C. THE LARS APPLICATION","method":"printed heading","endPage":11,"endAt":2498,"startToken":3041,"endToken":5395},{"p":11,"at":2498,"title":"D. THE LARS STUDY PROCESS","method":"printed heading","endPage":15,"endAt":67,"startToken":5395,"endToken":7092},{"p":15,"at":67,"title":"E. COORDINATED LARS STUDY PROCESS","method":"printed heading","endPage":18,"endAt":1734,"startToken":7092,"endToken":8893},{"p":18,"at":1734,"title":"III. The Proposed Revisions Are Just and Reasonable","method":"PDF bookmark","endPage":18,"endAt":2852,"startToken":8893,"endToken":9055},{"p":18,"at":2852,"title":"A. LARS COMPLEMENTS OTHER COMPONENTS OF MISO’S LARGE LOAD","method":"printed heading","endPage":20,"endAt":1619,"startToken":9055,"endToken":9841},{"p":20,"at":1619,"title":"B. ADDRESSING FERC’S SHOW CAUSE ORDER: ELECTRICALLY PROXIMATE","method":"printed heading","endPage":22,"endAt":794,"startToken":9841,"endToken":10668},{"p":22,"at":794,"title":"IV. Description of Proposed Tariff Revisions","method":"PDF bookmark","endPage":22,"endAt":1002,"startToken":10668,"endToken":10698},{"p":22,"at":1002,"title":"A. Attachment X (Generator Interconnection Procedures).","method":"printed heading","endPage":38,"endAt":2614,"startToken":10698,"endToken":18825},{"p":38,"at":2614,"title":"B. Attachment X – Appendix 1 (Interconnection Request for a Generating","method":"printed heading","endPage":38,"endAt":2618,"startToken":18825,"endToken":18826},{"p":38,"at":2618,"title":"Attachment X – Appendix 1 (Interconnection Request for a Generating","method":"printed heading","endPage":40,"endAt":569,"startToken":18826,"endToken":19397},{"p":40,"at":569,"title":"D. Attachment X – Appendix 6 (Generator Interconnection Agreement)","method":"printed heading","endPage":40,"endAt":573,"startToken":19397,"endToken":19398},{"p":40,"at":573,"title":"Attachment X – Appendix 6 (Generator Interconnection Agreement)","method":"printed heading","endPage":45,"endAt":1559,"startToken":19398,"endToken":21836},{"p":45,"at":1559,"title":"E. Attachment FF (Transmission Expansion Planning Protocol)","method":"printed heading","endPage":49,"endAt":65,"startToken":21836,"endToken":23543},{"p":49,"at":65,"title":"V. The LARS Stakeholder Process","method":"PDF bookmark","endPage":52,"endAt":1838,"startToken":23543,"endToken":25341},{"p":52,"at":1838,"title":"VI. Documents Submitted in this Filing","method":"PDF bookmark","endPage":53,"endAt":65,"startToken":25341,"endToken":25552},{"p":53,"at":65,"title":"VII. Effective Date","method":"PDF bookmark","endPage":53,"endAt":816,"startToken":25552,"endToken":25674},{"p":53,"at":816,"title":"VIII. Communications","method":"PDF bookmark","endPage":53,"endAt":1641,"startToken":25674,"endToken":25791},{"p":53,"at":1641,"title":"IX. Notice and Service","method":"PDF bookmark","endPage":53,"endAt":2153,"startToken":25791,"endToken":25867},{"p":53,"at":2153,"title":"X. Conclusion","method":"PDF bookmark","endPage":53,"endAt":2157,"startToken":25867,"endToken":25868},{"p":53,"at":2157,"title":"CONCLUSION","method":"printed heading","endPage":54,"endAt":647,"startToken":25868,"endToken":25989}]}