ER27-25-000 · 2026-10-02 · MISO

Midcontinent Independent System Operator, Inc.'s Large Load Addition Resource Study Process (transmittal letter; requested effective date December 2, 2026)

Midcontinent Independent 
System Operator, Inc. 
317.249-5400 
www.misoenergy.org 
720 City Center Drive 
Carmel, Indiana 46032 
2985 Ames Crossing Road 
Eagan, Minnesota 55121 
1700 Centerview Drive 
Little Rock, AR 72211 
 
Christopher D. Supino 
Managing Senior Corporate Counsel 
Direct Dial:  317-517-2963 
Email:  csupino@misoenergy.org 
 
 
October 2, 2026 
VIA ELECTRONIC FILING 
The Honorable Debbie-Anne Reese  
Secretary 
Federal Energy Regulatory Commission 
888 First Street, NE 
Washington, DC  20426 
Re: 
Midcontinent Independent System Operator, Inc.’s  
Large Load Addition Resource Study Process 
Docket No. ER27-___-000 
 
Dear Secretary Reese: 
The Midcontinent Independent System Operator, Inc. (“MISO”), through this filing,1 
submits proposed revisions to its Open Access Transmission, Energy and Operating Reserve 
Markets Tariff (“Tariff”),2 to establish a Large Load Addition Resource Study (“LARS”) process,3 
associated application and operational requirements to enable load and generation to be studied 
together leveraging existing MISO processes to facilitate the timely availability of the tool to 
customers.4  The LARS proposal will help streamline the MISO generator and load interconnection 
process by providing expedited review of the addition of 200 MW or greater loads together with 
new generation resources that are electrically proximate to those loads.  Through this coordinated 
study framework, LARS is designed to facilitate the timely and reliable interconnection of Large 
Loads and new generation onto the MISO system. 
 
 
1  
This filing is made pursuant to section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d, and Part 35 of 
the regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 35.1, et 
seq. 
2  
Unless otherwise indicated by the text or context of this transmittal letter, all terms used herein have the definitions 
set forth in Module A of the Tariff. 
3  
For the purposes of this filing, references to “LARS” may refer to the Large Load Addition Resource Study or 
may be used as a general reference to the processes and operational requirements that are part of the proposal 
submitted herein. 
4  
MISO uses the uncapitalized term “large load” in this transmittal letter and associated testimony rather than the 
“Large Load” term proposed in MISO’s pending Large Load Interconnection Reliability filing.  This is done to 
avoid confusion because that definition remains pending before the Commission and because, given the 200 MW 
threshold for entry into LARS, not all “Large Loads” will be eligible to be a “LARS Associated Load.”

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 2 
 
 
 
MISO requests that the Tariff revisions submitted herewith be made effective December 2, 
2026, which is not less than sixty (60) days nor more than one-hundred and twenty (120) days 
from the date of this filing.  MISO requests that the Commission issue an order by this date in 
order to allow MISO to commence the first LARS Study Period in Q1 of 2027.  As discussed 
below and in the supporting testimony of Christina Drake,5 action is needed in the near term to 
enhance the available tools to address the reliability impacts associated with the impending 
interconnection of Load, including the anticipated interconnection of significant large loads. 
 
I. 
EXECUTIVE SUMMARY 
 
LARS responds to rapidly evolving reliability and resource adequacy needs in the MISO 
region.  MISO is proposing LARS to facilitate the cost effective, timely and reliable integration of 
new large loads into the system.  LARS supports the Commission’s call to action to meet these 
new challenges in short order.  LARS will provide a path for the interconnection of both large 
loads and supporting generation pairs in a parallel 120-day study process.  The proposal leverages 
the existing success in the MISO’s Expedited Project Review (“EPR”) process on the load side 
and lessons learned from Expedited Resource Additions Study (“ERAS”) process on the 
generation side.  
 
MISO is experiencing significant growth in electricity demand at the same time that 
additional resources are needed to reliably serve that demand.  MISO projects annual load growth 
of approximately 1% to 3% through 2044, driven in part by energy-intensive loads such as data 
centers and manufacturing expansion, and has identified the need to accelerate new resource 
additions as demand grows.6   
 
The need to accelerate the infrastructure necessary to reliably serve growing electricity 
demand is also reflected in the Department of Energy’s (“DOE”) Speed to Power initiative, which 
seeks to accelerate development timelines for large-scale transmission and generation projects to 
meet rising electricity demand.7  LARS advances that objective within the MISO region by 
providing a process through which significant new large loads and generation intended to support 
that load can be studied on an accelerated and coordinated basis. 
 
 
 
5  
Prepared Direct Testimony of Christina Drake, Director—Generation Interconnection, attached hereto as Tab C 
(“Drake Testimony”). 
6  
MISO, 2026 Reliability Imperative Report at 4 (Feb. 2026) (projecting annual load growth of approximately 1% 
to 2% through 2044 and identifying data centers, manufacturing expansion, and electrification as drivers of 
sustained, concentrated load growth); see also, MISO, 2026 Planning Resource Auction Results at 2 (May 22, 
2026) (stating that faster resource additions are needed to support large-load growth and ensure resource 
adequacy). 
7  
DOE, Speed to Power Initiative (Sept. 18, 2025) (describing the initiative as a federal effort to accelerate 
development timelines for large-scale transmission and generation projects and ensure sufficient power to meet 
rising electricity demand).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 3 
 
 
 
LARS is also responsive to the Commission’s June 18, 2026, Order Instituting Proceeding 
Under Section 206 of the Federal Power Act in Docket No. EL26-70-000 (“Show Cause Order”).  
The Commission preliminarily found, among other things, that MISO’s existing Tariff may be 
unjust and unreasonable because it does not provide generator interconnection study procedures 
and services that account for the operational dynamics of serving electrically proximate large 
loads.8  The Commission specifically addressed the potential for a new generating facility and an 
electrically proximate large load to be studied in a manner that accounts for their combined 
transmission system impacts.9  LARS provides a mechanism for MISO to study a large load and 
the generation that will serve it at the same time such that their combined transmission system 
impacts may be considered together.  
 
In addition, the Commission requested a detailed informational report on any proposals 
under consideration to address the issue of resource adequacy to serve new large loads, strongly 
encouraging new proposals to the extent necessary to address these concerns.10  The LARS process 
responds to this concern and serves to provide a critical tool that allows the timely integration of 
resources associated with these new loads supporting regional resource adequacy.  While MISO’s 
existing processes have been sufficient to ensure resource adequacy in the short term, the unique 
commercial and operational characteristics of new large loads and the speed with which they need 
to come online have prompted MISO to develop LARS as an additional tool to further support 
resource adequacy as new large loads are integrated into the MISO region in the future. 
 
This proposal is deliberately tailored to significant new large loads.  MISO initially 
proposed a minimum eligibility threshold of 250 MW and expressly sought stakeholder input 
regarding whether that threshold appropriately captured high-impact loads without unnecessarily 
expanding the scope of the process.11  MISO set the initial threshold at 250 MW as recent EPR 
results showed that large loads of 250 MW and greater created meaningful grid impacts, with 
upgrades becoming increasingly likely between 300–500 MW and consistently necessary at 1,200 
MW and above with multi-element upgrades.  Stakeholders proposed alternative thresholds, 
including 200 MW, which MISO proposes herein as it expands the LARS proposal beyond 
hyperscale load to apply to other kinds of large loads including industrial loads.12  
 
 
8  
Midcontinent Independent System Operator, Inc., Order Instituting Proceeding Under Section 206 of the Federal 
Power Act, 195 FERC ¶ 61,212 at P 113 (2026) (“Show Cause Order” or “SCO”). 
9  
Id. 
10  Id. at P 122.  
11  MISO, Large Load Working Group (“LLWG”), Generation and Large Load Alignment, LLWG-2026-6, 
Stakeholder Feedback (July 30–31, 2026) (soliciting stakeholder feedback on whether 250 MW was the 
appropriate minimum threshold and what alternative threshold would capture high-impact loads without diluting 
the intent of the proposed process), available at https://www.misoenergy.org/engage/stakeholder-
feedback/2026/llwg-large-load-addition-resource-study-llwg-2026-6-20260827/. 
12  Id.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 4 
 
 
 
Importantly, LARS is designed to work in concert with other MISO large load initiatives, 
such as MISO’s proposed Zero Injection Generator Interconnection Agreement (“ZGIA”)13 and 
Interconnection Reliability Requirement (“IRR”)14 frameworks currently pending before the 
Commission and maintains protections for generation already progressing through MISO’s 
generator interconnection queue or more commonly known as the Definitive Planning Phase 
(“DPP”) process.  LARS provides a different tool for large load interconnection arrangements 
involving paired generation that do not fit within the ZGIA framework. 
 
Taken LARS provides MISO with a targeted tool to address the intersection of significant 
large load additions, optimized Network Upgrades with generation and load, generation 
development, and supports resource adequacy.  The proposal allows MISO to study qualifying 
load and associated generation on a coordinated basis, responds to issues identified in the 
Commission’s Show Cause Order, and is designed to preserve the integrity of MISO’s existing 
generator interconnection processes.  LARS is needed now to facilitate the cost-effective and 
reliable interconnection of impending new large loads and generation additions on an accelerated 
timeline. 
 
II. 
OVERVIEW OF THE LARS PROCESS 
 
A. 
BACKGROUND 
 
The MISO region is experiencing a significant change in both the magnitude and pace of 
anticipated electricity demand.  MISO’s 2026 Reliability Imperative explains that, following a 
period in which electricity demand grew at an average annual rate of approximately 0.5% between 
2009 and 2024, MISO now projects annual load growth of approximately 1% to 3% through 
2044.15  MISO identifies energy-intensive loads, including data centers and manufacturing 
expansion, among the sources of this sustained and concentrated growth.16 
 
This growth has corresponding implications for the resources necessary to maintain 
operational reliability and resource adequacy.  MISO has stated that, as demand grows rapidly, 
maintaining existing resources and accelerating new resource additions are critical.17  MISO’s 
2026 Planning Resource Auction results likewise recognize that, although the region has sufficient 
resources to satisfy resource adequacy requirements for the 2026-2027 Planning Year, faster 
 
13  Midcontinent Indep. Sys. Operator, Inc, Docket No. ER26-3552 (Aug. 18, 2026) (“ZGIA Filing”). 
14    Midcontinent Indep. Sys. Operator, Inc, Docket No. ER26-3650 (Aug. 28, 2026) (“IRR Filing”). 
15  MISO, 2026 Reliability Imperative Report at 4 (Feb. 2026) (contrasting historical load growth of approximately 
0.5% annually from 2009 through 2024 with projected annual growth of approximately 1% to 2% through 2044). 
16  Id. 
17  Id.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 5 
 
 
 
resource additions remain necessary to support large-load growth and ensure resource adequacy.18  
MISO has, therefore, identified rapid load growth as a core component of its broader Reliability 
Imperative.  MISO’s Transmission Evolution work specifically identifies the need to “speed up 
timelines for new generation and transmission projects” while managing large-load growth without 
compromising reliability.19   
 
Against this backdrop, the challenge presented by new large load growth is not limited to 
connecting the load itself.  Significant new demand must be accompanied by sufficient resources 
to maintain reliability and resource adequacy.  MISO’s Large Load Working Group (“LLWG”) 
was established to address this broader relationship, with a mission encompassing markets, reliable 
operations, planning, and resource adequacy associated with the integration and enablement of 
large loads.20  LARS is intended to address one aspect of that challenge by establishing a process 
through which qualifying Large Load additions and associated new generation can be studied on 
a coordinated basis.  Studying qualifying load and generation together, with aligned study timeline, 
provides a mechanism for MISO to consider significant new demand and the resources associated 
resulting in optimized network upgrades.  In this manner, LARS is designed to facilitate the reliable 
integration of significant new load and generation on an accelerated timeline. 
 
B. 
STRUCTURE OF LARS AND PARTIES 
 
LARS provides a parallel study process for a proposed large load and generation pair.21  As 
MISO explained in its motion for abeyance, “LARS will assess the transmission infrastructure 
needed to meet new large loads and new generation in an efficient process that can be executed on 
a shorter timeline, further supplementing the opportunities available for members to facilitate new 
large spot loads effectively.”22  The generation and load studies will be completed at the same time 
and will finish within approximately 120 days.  To allow this to happen, LARS brings the 
requirements that are needed for both the generation and load studies under a common application, 
 
18  MISO, 2026 Planning Resource Auction Results at 2 (May 22, 2026) (finding sufficient resources for the 2026-
2027 Planning Year while stating that faster resource additions are needed to support large-load growth and ensure 
resource adequacy). 
19  MISO, Reliability Imperative 2026 (identifying rapid load growth and a changing generation mix as transmission 
challenges and identifying accelerated generation and transmission development as part of MISO’s response). 
20  MISO, Large Load Working Group Charter at 1 (Apr. 20, 2026) (establishing the LLWG to provide input and 
policy guidance concerning markets, reliable operations, planning, and resource adequacy associated with large-
load integration), (“LLWG Charter”), available at: 
https://cdn.misoenergy.org/20260420%20LLWG%20Item%2001c%202026%20LLWG%20Charter_Draft75085
8.pdf. 
21  Attachment X defines Large Load Addition Resource Study (LARS) as “the procedure as set forth in Section 3.12 
of this GIP for studying an Interconnection Customer’s proposed Generating Facility in parallel with the study of 
a LARS Associated Load Customer’s proposed load.” See Section 1 of Attachment X. 
22  Motion of the Midcontinent Independent System Operator, Inc. and the MISO Transmission Owners to Hold 
Proceeding in Abeyance and Request for Shortened Comment Period and Expedited Treatment, Docket No. 
EL26-70-000 (Aug. 3, 2026) (“Abeyance Motion”).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 6 
 
 
 
the LARS Application and provides a framework for participation by the entities involved in the 
existing MISO processes that LARS builds upon.  
 
There are four primary types of entities involved in implementing LARS aside from MISO. 
These are the LARS Associated Transmission Customer, the Interconnection Customer(s) who will 
own or operate the Generating Facility, the applicable Transmission Owner, and the 
owner/controller of the ultimate load (called the “LARS Associated Load”).  To understand how 
LARS will work, a brief explanation of each of these parties’ roles in the process is provided below.   
 
The first of these parties is the LARS Associated Transmission Customer.23  This is the 
entity that procures Transmission Service for load and has a direct relationship with the load.  This 
is often a Load Serving Entity (“LSE”).  Because only the Transmission Customer can procure 
Transmission Service under established Tariff processes, LARS requires the LARS Associated 
Transmission Customer to be the party that initiates the LARS Application and obtains the 
resulting Transmission Service.24  Ultimately, the LARS Associated Transmission Customer acts 
as a coordinator between the other entities involved in the LARS process.  
 
Second, there is the Interconnection Customer.  This is the entity that will complete the 
section of the LARS Application that supports the generation portion of the LARS study, will be 
responsible for meeting the requirements of Attachment X pertaining to the generation study, and 
will receive Interconnection Service under an LLGIA.  The Interconnection Customer can be any 
entity (including an Independent Power Producer (“IPP”)) whose Generating Facility will provide 
Energy for the LARS Associated Load provided it is permitted by applicable laws and regulations 
to do so.25  The Interconnection Customer has the contractual relationships required by LARS to 
show that the Generating Facility is in fact paired with the LARS Associated Load.26   
 
Third, the Transmission Owner owns the facilities the LARS Associated Load will connect 
to the Transmission System.  The Transmission Owner works with the other parties to establish 
the Point of Interconnection (“POI”) for the Generating Facility(ies) and the Point of Withdrawal 
 
23  In GIP Section 1 of Attachment X, a LARS Associated Transmission Customer is defined as “the entity that is 
responsible for submitting the LARS Application and procures Transmission Service in order to serve LARS 
Associated Load and designates such load as formally paired with an Interconnection Customer’s LARS 
Interconnection Request.” 
24  See GIP Section 3.12.1.  
25  Interconnection Customer is defined as “any entity, including Transmission Provider, Transmission Owner or any 
of the Affiliates or subsidiaries of either, that proposes to interconnect its Generating Facility with the 
Transmission System.  For the purposes of Large Load Addition Resource Study (LARS), Interconnection 
Customer shall refer to the entity developing the Generating Facility that will execute the LLGIA, which may be 
a different entity from the LARS Associated Transmission Customer that submitted the LARS Application.” See 
GIP Section 1 of Attachment X. 
26  See GIP Section 3.12.2(i).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 7 
 
 
 
for the LARS Associated Load and has the responsibility to construct Network Upgrades (subject 
to applicable Tariff rules that are not changed by this filing).27  
 
The fourth key participant is the entity that owns or controls the LARS Associated Load, 
which for purpose of LARS must be a large load of at least 200 MW.28  While MISO usually will 
not have a direct relationship with this entity and does not purport through this filing to impose 
obligations directly on them, this entity will have a crucial role in establishing relationships 
between the parties directly involved in LARS, in supplying information necessary to complete 
the LARS Application, and study process, and in enabling the other parties to meet their obligations 
under LARS.   
 
As noted above, the roles of these parties and their specific responsibilities reflect existing 
Tariff requirements and practices.  LARS does not seek to fundamentally change the established 
roles of the entities participating in the load and generation studies but rather seeks to coordinate 
them.  LARS thus provides for faster and more transparent interconnection arrangements for large 
loads with paired generation, while offering customers speed-to-power, optimized transmission 
solutions, and greater certainty to support siting, and financing of large load projects.  The outcome 
of the LARS process is MTEP approval of transmission required to reliably facilitate the 
withdrawal of the load and corresponding injection rights for the proposed generation. The 
component parts of the process are discussed in greater detail below.  
 
C. 
THE LARS APPLICATION 
MISO is establishing a single application process for the participants in the LARS process.  
The LARS Application will be a single submission consisting of materials required by Attachment 
FF for the load and Attachment X for the generation.29  Because LARS involves two separate study 
processes being completed concurrently and in parallel, all the relevant parties to the load and 
generation pairing must apply together.30  While the LARS Application process may only be 
initiated by the LARS Associated Transmission Customer, the Interconnection Customer, the 
Transmission Owner, and the LARS Associated Load customer must all complete the required 
information as part of the application before it will be reviewed by MISO.  Independent Power 
Producers and other kinds of Interconnection Customers are not prohibited from participating in 
 
27  See GIP Section 3.12.1. 
28  The LARS Associated Load is defined as the “source of electrical load that is at least 200 MW and that is formally 
paired with one or more Interconnection Customer(s) that have submitted an Interconnection Request to LARS 
proposing one or more new Generating Facility(ies) to provide energy to such load.” See GIP Section 1 of 
Attachment X.  
29  The LARS Application is defined as “a single submission consisting of the materials required for LARS 
processing as required by Section I.D.1.b.ii of Attachment FF to the Tariff as well as the information required for 
studying the Generating Facilities under this Attachment X (in the form of Appendix 1) to these generator 
interconnection procedures. For purposes of this GIP, a LARS Application shall be a form of Interconnection 
Request.” 
30  See Drake Testimony at 17-18.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 8 
 
 
 
the LARS process.31  The LARS Application will also serve as a repository for all information 
required by the load and generation study processes.  A non-refundable fee of $250,000 must 
accompany the LARS Application and be paid by the LARS Associated Transmission Customer.32   
 
Notably, MISO is establishing a “pre-submission coordination process” that LARS 
applicants must participate in prior to submitting a LARS Application.33  This coordination process 
requires the potential LARS Interconnection Customer and the Transmission Owner to meet and 
agree on a definitive Point of Interconnection for the proposed LARS Generating Facility.  Forty-
five days prior to a LARS Application deadline, a potential LARS Interconnection Customer must 
notify the Transmission Owner to whose Transmission Facilities the potential LARS 
Interconnection Customer proposes to Interconnect of its plans to participate in LARS.  After 
receiving a request to meet from any potential LARS Interconnection Customer, the Transmission 
Owner must meet with them and any other impacted parties necessary to determine a definitive 
POI within ten business days after receiving a request for the meeting.  The parties must jointly 
agree on a feasible POI no later than ten business days prior to the next LARS Application deadline 
as published on MISO’s website.  An attestation from the Transmission Owner stating that it has 
an agreed POI with the LARS Interconnection Customer(s) must be included in the LARS 
Application.34  
 
MISO is proposing these pre-submission coordination activities for several reasons.  First, 
while the LARS Associated Transmission Customer is the only party that may submit the LARS 
Application, MISO is requiring that they actively participate in the LARS process with the 
potential LARS Interconnection Customers prior to LARS Application deadline.  Second, 
requiring pre-submission coordination activities will increase the efficiency of reviewing the 
LARS Application with all the relevant parties identified, the agreed upon POI identified, and other 
necessary details have already been determined by the time the LARS Application is submitted to 
MISO.  Having the LARS Application parties agree on many of these necessary details in advance 
of submission will also help avoid future disagreements or changes, which can lead to unnecessary 
or late withdrawals from the study process.  MISO has heard from stakeholders and learned from 
experience that an accelerated study process requires that the relevant participants have 
coordinated and agreed upon key details (such as the location of the POI) up front and not after 
they have submitted their application. Third, requiring coordination meetings between these parties 
will assist them with identifying any other relevant parties who may need to participate in the 
LARS process.  Ms. Drake explains that to effectively facilitate the speed of the LARS study 
process, MISO needs all relevant parties to the load and generation pair to not only be identified 
at the outset but committed to working together.35  
 
31  Id. at 18-19.  
32  See GIP Section 3.3.1 (“A LARS Application for the Large Load Addition Resource Study shall be accompanied 
by a Non-Refundable Deposit 1 (D1) of $250,000 submitted by the LARS Associated Transmission Customer.”). 
33  See GIP Section 3.12.1 and Section I.D.1.b.ii(a) of Attachment FF.  
34  See Drake Testimony at 20; GIP Section 3.12.1. 
35  Drake Testimony at 19-20.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 9 
 
 
 
 
MISO will accept LARS Applications on a rolling basis, and the applications will be 
queued on a serial, time-stamped basis based on time of submission to the LARS process.  There 
will be three LARS study periods each year and each study period will be completed in 
approximately 120 days, as explained by Ms. Drake.36  MISO will accept ten LARS Applications 
per study period and the LARS Applications will be assigned to study periods in order of 
submission.  Customers interested in joining the next LARS study period must submit their LARS 
Application to MISO no later than 20 business days prior to the scheduled kick-off of the LARS 
study period as published on the MISO public website.  MISO will keep an open queue of LARS 
Applications and will replace any LARS Application that withdraw prior to study kick off with the 
next submitted generation/load pair not included in the current study period.  Once the LARS study 
process has kicked off for a specific LARS generation/load pair, then that spot is lost for the LARS 
study period it is part of even if the pair later withdraws during the study process.37   
 
An Interconnection Request included in a LARS Application must be accompanied by an 
executed agreement between the Interconnection Customer and either the LARS Associated 
Tranmission Customer or the entity that owns or controls the LARS Associated Load.  The 
agreement must demonstrate that the output of the LARS Generating Facility will serve the LARS 
Associated Load.  The agreement must be legally binding and must state a minimum term of five 
years so that if any transmission solutions need to be developed, there is sufficient time to work 
through the processes for development.  As described in Section 3.12.2(i) of Attachment X, the 
agreement must be in the form of a power purchase agreement (“PPA”) or similar off-take 
agreement, a Build-Own-Transfer Agreement, or any other kind of agreement used by Load 
Serving Entities including a special contract, a large load tariff agreement, or a retail service 
agreement.  Ms. Drake explains that in response to stakeholder feedback, MISO revised the Tariff 
redlines to explicitly state the agreement can be executed between the generator and large load. 38 
This does not supersede the role of the LARS Associated Transmission Customer to determine 
whether to submit a LARS Application but does allow flexibility for different types of agreements 
that are consistent with state law and supported by the parties.39  MISO also added the third 
agreement option to incorporate specific utility arrangements with large loads that are not 
traditional PPAs to link the generation and load.40   
 
 
36  See id. at 13. 
37  For example, if MISO holds the LARS study kick-off calls for all ten generation/load pairs and one of the pairs 
withdraws the following week, MISO will not move up another pair into that study cycle since the study process 
had already commenced.  If the generation/load pair withdraws shortly before the LARS study kick-off call, then 
MISO would move the next LARS generation/load pair into that study cycle.  
38  MISO, Large Load Working Group (“LLWG”), Generation and Large Load Alignment, LLWG-2026-6, MISO 
Response to Feedback at 8, (Sep. 28, 2026), available at: 
https://cdn.misoenergy.org/LLWG%20Large%20Load%20Addition%20Resource%20Study%20Response%20(
LLWG-2026-6)%20(20260827)784877.pdf 
39  Drake Testimony at 31-32. 
40  See id.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 10 
 
 
 
Other requirements of the LARS Application include limiting the Interconnection Requests 
to NRIS, limiting the amount of requested Interconnection Service to no more than 150% of the 
peak demand of the LARS Associated Load, and demonstration of 100% site control for the POI 
including a one-line diagram demonstrating the Generating Facilities and any associated electrical 
equipment required.41  Based on stakeholder feedback MISO established the 150% of 
Interconnection Service limitation to ensure the generation is required to reliably serve the load 
within the same LRZ.  As Ms. Drake states, MISO sought to establish a closer connection between 
what is needed by the LARS Associated Load and what is being proposed by the LARS 
Interconnection Customer.42  Thus, MISO implemented this requirement to directly connect the 
Generating Facility with the LARS Associated Load and to allow for different generator fuel types 
and accreditation.  Ms. Drake explains that “this requirement establishes a clear connection 
between the output of the Generating Facility and the load without being overly prescriptive on 
generation fuel type, dispatch requirements, or other operational considerations.”43 
 
Another important condition of the LARS process is the requirement that the load and 
generation pair be located in the same Local Resource Zone (“LRZ”).44  The Point of 
Interconnection(s) specified in a LARS Application must be located in the same LRZ as the Point 
of Withdrawal (“POW”) of the LARS Associated Load.  As discussed by Ms. Drake, the intent of 
the LARS process is to identify an optimized Network Upgrade solution for both the load and 
generation, and MISO retains that flexibility in the LRZ because it aligns with MISO’s Resource 
Adequacy construct.45  Specifically, MISO does not have a requirement that loads bring generation, 
but through the proposed LARS process, by restricting the Point of Interconnection(s) specified in 
a LARS Application to be located in the same LRZ as the Point of Withdrawal, MISO providing 
an incentive for Load to bring Generation in a manner that maximizes the positive impact this 
Generation has on Resource Adequacy.  MISO recognizes there are other ways it could have 
limited the pairing such as requiring the generation and LARS Associated Load to be located in 
the same Local Balancing Authority area or through requiring that the location of the Generating 
Facilities be within a specific number of substations of the LARS Associated Load.  However, 
limiting the pairing of Generating Facilities and LARS Associated Load to the same LRZ strikes 
an appropriate balance between accommodating large, landlocked LARS Associated Loads that 
may need additional POIs to propose sufficient Generating Facilities needed to serve that load.  
Limiting the proximity of the Generating Facilities and LARS Associated Load provides a solution 
 
41  See GIP Section 3.12.2.  
42  See Drake Testimony at 29. 
43  Id.  
44  Attachment X defines Local Resource Zone (LRZ) as the “geographic area within the Transmission Provider 
Region that is prescribed by the Transmission Provider, based upon the criteria in Section 68A.3, to address 
congestion that limits Planning Resource deliverability.” An LRZ is the smallest geographic area defined by 
MISO for planning and market purposes and it is used to allocate resource adequacy requirements, capacity 
benefits, and reliability needs based on transmission constraints, electrical boundaries, and local reliability 
requirements. LRZs are used in the Planning Resource Auction (“PRA”) as well as for allocating the Planning 
Reserve Margin (“PRM”) requirement.  
45  See Drake Testimony at 40.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 11 
 
 
 
that is not overly restrictive and is consistent with MISO’s resource adequacy construct by ensuring 
deliverability of the Generating Facilities to LARS Associated Load within the same LRZ.   
 
MISO is proposing to increase flexibility in the LARS process by allowing a LARS 
Associated Load to be served by multiple Generating Facilities under specific circumstances.  
First, all Generating Facilities serving a LARS Associated Load must be included and identified 
in the same LARS Application and must request a minimum of 200 MW of Generator 
Interconnection Service in aggregate.  Second, a LARS Associated Load may be served by more 
than one group of Generating Facilities located at different POIs, but a separate LARS Application 
must be submitted for each POI group of Generating Facilities.  Stated differently, each group of 
aggregated LARS Generating Facilities at a single POI must submit a separate LARS Application.  
Each LARS Application must identify the total amount of load requested by the LARS Associated 
Load and must identify every Generating Facility providing power to that load.46  While MISO is 
allowing aggregation for LARS Generating Facilities, MISO is not allowing aggregated load to 
participate in LARS.  As explained earlier, MISO developed LARS in the context of dramatic large 
load growth and created the LARS process to help address that growth.  Ms. Drake explains that 
limiting LARS load participants to at least 200 MW at one POW ensures that the load coming 
online is sufficiently large to warrant inclusion in LARS and is not a large group of small loads 
banded together.47   
 
While the LARS Application requirements are expected to reduce the number of 
speculative projects submitting applications, they provide enough flexibility to enable these large 
loads to connect to the system.  As Ms. Drake explains in her testimony, ensuring that only 
commercially viable and shovel ready projects enter LARS is a necessary prerequisite to running 
these extremely fast serial studies because each LARS study must be able to rely on the Network 
Upgrades resulting from previously completed LARS study actually being developed.48  Thus, the 
strict entry requirements for LARS both support its intended benefits while also underscoring that 
LARS is not, and should not be, a replacement for the DPP.49  Rather, it is intended to be a narrowly 
scoped but powerful process.   
 
D. 
THE LARS STUDY PROCESS 
The requirements of the LARS generator interconnection study process are outlined in 
Section 3.12.2 of Attachment X.  Based on principles established in ERAS, the LARS generation-
side study will provide a Large Load Generator Interconnection Agreement (“LLGIA”) in 
approximately 120 days and will be a permanent MISO study process.  Similarly, the load process 
will start the approval process after a 90-day study process.  While the LARS generation and load 
studies are completed separately and in parallel, they both start with the same overall base 
 
46  See id. at 23, 30.   
47  See id. at 24-25. 
48  See id. at 9-11. 
49  See id. at 12.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 12 
 
 
 
configuration system including both MTEP and GIA projects in their models.50  On top of that 
common base model, MISO then adds the LARS generation, load, and the proposed transmission 
solutions to study all three components together.  Ms. Drake explains how this allows for both the 
generation and load studies to have a fuller picture of system impacts than would be possible if 
each was studied in isolation, enabling greater efficiency in Network Upgrade identification.51  The 
load and generation studies will be completed at approximately the same time.52  MISO designed 
the LARS process to ensure the proposed load and generation pair is evaluated to the same 
standards as those submitted separately through MISO’s other existing processes (i.e., MTEP/EPR 
and ERAS).   
 
1. THE GENERATION STUDY 
For each LARS study period, the individual generation/load pairs will be studied in one 
model, and MISO will have ten models that represent those ten generation/load pairs.  MISO will 
complete these studies individually and in a serial fashion based on their submission date.  This 
allows MISO to look at any generation or load violations individually and together with the results 
from the load side study as explained by Ms. Drake.53  Then any common violations that show up 
in the generation and load studies are assigned to BRP and Other project types.  Only the violations 
but for the generator are assigned GIP project types.54  
 
As MISO explained to stakeholders in the LLWG, all studies begin with the MTEP models 
as a base to contain consistent topology, generation, and load assumptions.55  The LARS model 
build will include all Existing Generating Facilities, including those from completed DPP cycles, 
the ERAS process, and the latest MTEP base case with all approved MTEP projects as well as any 
recently approved EPR projects.  This is the same process utilized for the DPP process except the 
DPP models include all higher queued Interconnection Requests from earlier cycles and all 
Interconnection Requests within that DPP cycle.  As Ms. Drake explained, “LARS studies will not 
include Interconnection Requests currently in the generator interconnection queue that do not have 
an executed GIA.”56  MISO has designed the LARS study this way to reduce the number of 
speculative projects in the modeling process.  Thus, on the generation study side, MISO is 
analyzing whether there are enough pathways and requested Network Service to allow the 
generator to integrate into the system.  On the load study side, MISO is analyzing the cumulative 
 
50  Id. at 13-14. 
51  Id. at 14-15. 
52  Id. at 26. 
53  Id. at 14-16. 
54  See id. at 15-16. 
55  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Large Load Addition Resource 
Study (LARS) presentation at 5 (Sep. 23, 2026), available at: 
https://cdn.misoenergy.org/20260923%20LLWG%20Item%2006%20Large%20Load%20Addition%20Resourc
e%20Study%20(LLWG-2026-6)782864.pdf. 
56  Drake Testimony at 29.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 13 
 
 
 
impacts of adding the large loads to the system and identifying common issues solutions.  Notably, 
MISO will not limit the study process to the specific LRZ the generation/load pair will be located 
in – this requirement is solely for the pairing of the load and generation.57  MISO will look at the 
full impacts of the generation/load pair on MISO’s Transmission System using the same study 
criteria and processes applicable to NRIS evaluations of other Interconnection Requests.   
 
As a result of the way MISO’s study models are structured, LARS projects will not impact 
existing projects in the DPP process.58  LARS Interconnection Requests will not be included in 
ongoing DPP studies and therefore will not utilize any available transmission capacity in those 
studies.  Any Network Upgrades approved through the LARS process will be reflected in later 
cycles and may mitigate constraints that would otherwise be identified there.  Thus, LARS cannot 
impact ongoing DPP cycles and, to the extent that LARS projects could impact future cycles, such 
impacts would only be positive.59  In the event that overallocation does occur, any constraints that 
are identified as needing mitigation in the MTEP process will be formalized in a future MTEP 
project.60  The cost of the MTEP project will be allocated based on existing Tariff rules, which is 
likely to be the load within the transmission pricing zone where the transmission upgrade is 
required.  This cost shift is consistent with MISO’s existing processes.  The Interconnection 
Customer will be responsible for all Network Upgrades identified in the LLGIA as GIP project 
types even if it later withdraws from LARS.61  Ms. Drake explains that this is necessary both to 
ensure commitment from those entering the LARS process and provide certainty to the other 
processes (including later LARS and DPP studies) that will include facilities identified through 
LARS in their starting models.62  
 
At the end of the LARS process, the generator will receive a LLGIA to generate up to 150% 
of identified MW need of the LARS Associated Load.  
 
2. THE LOAD STUDY 
The requirements of the LARS load interconnection study process are outlined in Section 
I.D.1.b.ii of Attachment FF.  For each LARS study period, all ten generation/load pairs will be 
represented in one model, and MISO will complete ten separate studies in that one model.63  The 
LARS load study process is built upon MISO’s existing EPR process and requires similar 
 
57  Id. at 4 (“Completing the generation and load studies in parallel allows MISO to see the full impacts on the system 
with each different configuration, which enables MISO to identify solutions for both the generation and load 
sides.”). 
58  See Drake Testimony at 32-33.  
59  Id. at 33. 
60  Id.  
61  Id. at 37-38. 
62  Id. at 15-16. 
63  Id. at 14 (“All ten generation/load pairs will be represented in one model, and MISO will complete ten separate 
studies in that one model.”).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 14 
 
 
 
information.  MISO’s load study process focuses on accounting for cumulative impacts of the 
proposed loads and the coordination with affected systems.  The transmission reliability studies 
will employ a format including all other submitted EPRs and LARS projects to ensure the 
cumulative impacts of the load and transmission are observed.  The Transmission Owner’s initial 
set of transmission solutions are identified and submitted to MTEP.  This allows MISO to view 
and analyze the full spectrum of contingencies across timeframes and processes.64   
 
First, MISO will complete a load model build with the proposed LARS generators.  Then 
MISO will review the proposed LARS projects with reliability assumptions and determine if any 
constraints are identified. This process includes reviewing the outage of the generator in the study. 
After completing a load and generation constraint review, MISO will determine whether there are 
any common issues solutions. A planning level solution is established at the end of the load study 
process.  While completing the study, MISO is looking to determine whether the available 
generation and transmission pathways can reliably serve the LARS Associated Load without 
negatively impacting the rest of the transmission system.  As Ms. Drake explains, MISO is looking 
at different scenarios and conditions within the load model to ensure that the load can be reliably 
served under a variety of circumstances.65  By including every load for that LARS study period in 
one model, MISO is able to look at the cumulative impacts and reduce the risk that multiple 
transmission projects will need to be developed.  Any cost impacts from the study outcomes will 
be assigned to Baseline Reliability Projects and Other type projects.66  In addition, a pro forma 
cost shifting agreement will need to be executed and any new terms in transmission services 
agreements will need to be met.  MISO notes that it is continuing to work with stakeholders through 
the LLWG to develop the pro forma cost shifting agreement and any necessary terms for 
transmission service for large loads, all of which will be submitted to the Commission in a FPA 
section 205 filing by November 16, 2026.  
 
The proposed Attachment FF updates reinforce the core requirement of generator 
commitment to LARS, other MISO processes require that a GIA must be executed before a 
resource can be included in the load study models as it provides the necessary certainty for the 
load planning process.  In the LARS study process, MISO includes the paired generator in the 
LARS load study even though it will not have an executed GIA at the time of study.  This pairing 
of load and generation for a parallel process supports or facilitates identification of a more efficient 
and potentially more cost-effective set of Network Upgrades than would be possible if the 
generation and load were studied in isolation and acknowledges the increasing number of projects 
that require coordinated evaluation.  In addition, the cost allocation hierarchy—transitioning from 
GIP to BRP when appropriate—supports procedural alignment and simplifies outcomes when 
common constraints lead either to BRP designation or another path.  
 
64  Id. at 14-15, 25. 
65  Id. at 25. 
66  Id. at 27-28. MISO’s proposed Tariff language is sufficient to categorize these costs as BRPs or Other project 
types, with cost responsibility flowing from such designation under existing rules.  The LARS structure is 
compatible with these agreements and MISO will incorporate them into LARS once they are accepted. However, 
LARS can be implemented based on the Tariff revisions filed herein and need not await these future filings.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 15 
 
 
 
 
E. 
COORDINATED LARS STUDY PROCESS 
The LARS process builds off the existing EPR and ERAS processes but improves upon 
them by integrating planned load with the generation, which enables the identification of more 
optimal Network Upgrades.  If MISO knows a large load is coming, which it will in the LARS 
process, then MISO can study the load’s impacts with greater certainty and reduce the risk of 
speculative generation or load.  By running the generation and load studies in parallel, MISO is 
able to review constraints identified on both the load and generation sides and can see the impacts 
to the system with each different configuration.  This information can then inform the transmission 
network upgrades that are solutions for the transmission needs identified in the load and generation 
studies.  MISO can also bring Sugar-developed solutions to the Transmission Owner and 
Interconnection Customer for coordination.67   
 
The goal of LARS is not necessarily to find the lowest cost solution for either the load or 
generation but to identify the solution that best fits both the generation and load needs at the lowest 
cost.  MISO expects LARS to produce more cost-effective solutions that are more efficient for the 
grid overall.68  This allows MISO to combine solutions between the load and generation side for 
more optimal, efficient, and effective responses.  MISO can then come up with more effective 
solutions to help integrate load and generation into the system, which maximizes the benefits of 
both study processes and reduces integration costs.  Thus, as Ms. Drake explains, the LARS 
process enables MISO to optimize solutions for the transmission grid to reduce costs overall while 
also maintaining reliability.69   
 
The LARS Application must identify a Commercial Operation Date for the Generating 
Facility and a Load In-Service Date for the LARS Associated Load that is no later than three (3) 
years from the date the LARS Application is submitted.70  The load can start receiving service for 
less than the full amount of transmission service requested (start receiving service in phases), but 
must commence service for the full amount of transmission service requested in LARS Application 
no later than the Generating Facility’s COD.  While the load is operating at less than the full amount 
of service, the Generating Facility must remain subject to the Annual ERIS (“AERIS”) and the 
Quarterly Operating Limit (“QOL”).  Thus, once the LLGIA is executed, some amount of the 
LARS Associated Load must be in-service before the Generator can come online.  The Generator 
may not come online prior to the LARS Associated Load coming in service.   
 
 
67  MISO uses an integrated modeling software Suite of Unified Grid Analyses with Renewables (“SUGAR”), for 
Phase 1 and Phase 2 DPP studies with plans to integrate it in Phase 3.  The SUGAR software leverages powerful 
circuit simulation methods developed to study billion-transistor electronic systems. SUGAR reduced DPP phase 
1 cycle time significantly from the status quo as evidenced in the DPP 2022, 2023 and 2025 cycles. 
68  See Drake Testimony at 4. 
69  Id. at 10-12. 
70  See GIP Section 3.12.9.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 16 
 
 
 
To encourage certainty and facilitate optimized transmission solutions, MISO is requiring 
that the generation and load commit to remain contractually paired for a minimum of five years at 
application, which coincides with MISO’s planning horizon.71  This requirement thus enables 
MISO to rely on the pairing of the Generating Facility and LARS Associated Load in conducting 
its planning.  This application and study processing requirement is separate from the obligation to 
remain paired for a fifteen-year period.  As described below, LARS requires that the generation 
and load remain paired for a minimum of fifteen years.  However, MISO acknowledges that it may 
be difficult to obtain a commercial agreement for such a period at time of LARS Application 
submission.  Requiring that the commercial agreement specify at least a 5-year term at application 
allows some flexibility to renew the contract between the paired load and generation during the 
operational life of the generation and load while still ensuring a significant, upfront commitment 
to even be studied in the LARS process.  
 
If either the load or generation portion withdraws after the LARS study is completed, the 
LLGIA is void and non-refundable deposits are forfeited.  There will be no restudy with the LARS 
process.  Notably, if either of the parties terminate a LLGIA, withdraw the load after MTEP 
approval, cease use of the Transmission Service granted through LARS, or terminate their 
commercial agreement after notice to proceed, the parties will be responsible for all assigned 
Network Upgrades costs. The Interconnection Customer remains responsible for any identified 
GIP Network Upgrades and the LARS Associated Transmission Customer remains responsible for 
any identified BRPs or Other assigned Network Upgrades.  Moreover, the LARS Associated Load 
would then need to be studied through the applicable MTEP process to maintain service.72  
 
If the LARS Associated Load is withdrawn, ceases use of the Transmission Service granted 
through LARS, or the commercial agreement between the generation and the load terminates 
during the first fifteen years after the date that the LARS Associated load commences use of the 
Transmission Service granted through LARS, then MISO will terminate the LLGIA after a limited 
operations transition period and Interconnection Customer would need to obtain new 
Interconnection Service through the DPP to continue making injections onto the MISO 
Transmission System.73  Both the 15-year commitment period and the limited operations transition 
process are important design features that warrant further discussion. 
 
With respect to the requirement to remain paired and in service for fifteen years, MISO 
determined that requiring both the Generating Facility and LARS Associated Load to remain in 
service and retain their relationship provided important safeguards.  This requirement ensures that 
the LARS study process accurately reflects the expected impacts of the Generating Facility and 
LARS Associated Load on the Transmission System for a significant period of time.  It also serves 
to prevent customers from gaming or otherwise misusing the LARS process to obtain 
Interconnection Service not intended for long-term service to a specific large load.  Along with 
 
71  See Drake Testimony at 35. 
72  Id. at 36-37. 
73  Id.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 17 
 
 
 
these considerations, MISO also weighed stakeholders’ legitimate concerns that Generating 
Facilities submitted to LARS in good faith and which in fact served LARS Associated Loads for 
long periods of time could should not be forced to go offline or undergo a second study process 
with potentially significant new costs if the LARS Associated Load unexpectedly ceased 
operations more than a decade into the relationship.  Several stakeholders also expressed concerns 
that a permanent pairing requirement would strand a Generating Facility that had a remaining 
useful service life even if such Generating Facility could be used—or was needed—to address 
resource adequacy needs following the departure of the LARS Associated Load.  These discussions 
convinced MISO that that a permanent pairing requirement would not only create significant long-
term commercial risk to the LARS Interconnection Customer but that such a risk could create 
challenges to funding LARS projects that would otherwise be beneficial.   
 
Based on these discussions, MISO considered the implications of several potential time 
durations for the pairing requirement before determining that a fifteen-year pairing requirement 
for the generation and load struck the best balance between ensuring LARS was used as intended 
and enabling long term commercial certainty for Interconnection Customers.   MISO reached this 
conclusion for several reasons.  First, fifteen years is a standard duration for large load contracts 
and thus a fifteen-year commitment aligns with contracting timeframes.  Second, fifteen years is a 
sufficiently extensive period to deter entities from invoking the needs of a specific large load as a 
pretext to bypass the DPP queue and receive unrestricted Interconnection Service on an accelerated 
timeline.  This positions the DPP as the more flexible and lower risk option for Generating 
Facilities with all but the firmest long-term relationships with a large load. Finally, the fifteen-year 
period provides an outer limit on Interconnection Service risk that increases the commercial 
viability of LARS and avoids the potentially negative resource adequacy implications of imposing 
a permanent limitation with effects that would become known only beyond the reasonable 
commercial and planning horizon visible at the time LARS commercial arrangements are made.  
 
With respect to the transition period, MISO will provide the Generating Facility up to one 
year after the LARS Associated Load withdraws to continue to operate under the LLGIA in order 
to provide time for the Interconnection Customer to enter the DPP and obtain new NR 
Interconnection Service.74  MISO further proposes that this period would be extended for the 
duration of a DPP cycle if the Interconnection Customer submits an Interconnection Request for 
DPP processing and remains in such DPP cycle through to GIA.  Operations during this transition 
period would be subject to MISO’s Quarterly Operating Limits (“QOL”) and Annual ERIS 
(“AERIS”) processes to ensure reliability.75  MISO developed this transition period to mitigate the 
impacts to a Generating Facility whose LLGIA must be terminated within the first fifteen Calendar 
Years after the LARS Associated Load commences use of the Transmission Service granted 
through LARS.  The limited transition period also prevents adverse reliability impacts from 
operating the Generating Facility without the LARS Associated Load online and is consistent with 
 
74  Id.  
75  Id.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 18 
 
 
 
the requirement to obtain new Interconnection Service because it provides only a temporary bridge 
to avoid immediately taking the Generating Facility offline.  While MISO fully expects that future 
DPP cycles will be completed within one year, MISO added the automatic extension as a safeguard 
against DPP delays. Because the automatic extension only lasts for as long as the Interconnection 
Customer maintains its Interconnection Request in the DPP and meets the progressively increasing 
commitments required by that process, this extension would not provide a useful stalling 
mechanism for Interconnection Customers that is not actively seeking new Interconnection 
Service. 
 
After 15 years, it is reasonable to allow the Interconnection Service granted through the 
LLGIA to remain even if the LARS Associated Load subsequently leaves service.  This allowance 
addresses the need for commercial certainty for the Generating Facilities participating in LARS 
and helps reduce any reliability impacts that may be associated with immediately terminating the 
LLGIA if the load were to go offline.  This also reflects the purpose of LARS as providing a process 
for formally paired generation and load to be studied together and connect to MISO’s Transmission 
System efficiently and effectively.  Ultimately, the outcome of the LARS process is MTEP-
approved transmission for reliable load integration into the system, the allocation of LLGIA 
generation interconnection service, a more optimized set of Network Upgrades within 
approximately 120-days, and generation/load pair that has agreed to remain paired within same 
LRZ for a minimum of fifteen years.  
III. 
THE PROPOSED REVISIONS ARE JUST AND REASONABLE 
 
The LARS proposal and its corresponding Tariff changes are just and reasonable.  LARS 
provides a valuable tool to enable the study of LARS Associated Loads that are brought to MISO 
with a paired generation solution.  LARS meets the urgent need for an accelerated evaluation 
process that accounts for both load and generation, responds to concerns identified in the Show 
Cause order regarding proximity between large loads and their associated generation, and does not 
disturb existing DPP processes.  The LARS process is not unduly discriminatory to any potential 
market participant and respects existing roles and responsibilities.  LARS brings together several 
independent MISO processes needed to integrate a new large load.  Through the LARS 
Application, MISO has established a framework that allows different stakeholders to proactively 
coordinate the addition of these generation/load pairs onto the system.  The result is an accelerated 
process that allows for the integration of generation/load pairs and optimized transmission 
solutions.  
 
A. 
LARS COMPLEMENTS OTHER COMPONENTS OF MISO’S LARGE LOAD 
FRAMEWORK  
The need to accelerate reliable power infrastructure is reflected in the DOE’s Speed to 
Power initiative.  DOE launched Speed to Power in September 2025 as an effort to accelerate 
development timelines for large-scale transmission and generation projects and ensure sufficient

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 19 
 
 
 
power to meet rising electricity demand.76  On June 18, 2026, the Commission issued the Show 
Cause Order addressing MISO’s Tariff provisions governing the interconnection of large loads.77  
The Commission preliminarily found that aspects of MISO’s existing Tariff may be unjust and 
unreasonable and identified potential reforms concerning the integration of large loads and 
associated generation.78  Of particular relevance to LARS, the Commission addressed the absence 
of generator interconnection procedures and services designed to facilitate the interconnection of 
generation brought onto the transmission system to serve electrically proximate large loads.79  The 
Commission also addressed the electrical relationship between a large load and generation 
intended to serve that load.80 
 
LARS is responsive to the Commission’s focus on the coordinated consideration of 
significant new load and generation.  At the July 16, 2026 LLWG meeting, MISO first introduced 
a new proposal designed to align the study processes for new large loads and generation intended 
to serve those loads.81  Certain stakeholders described MISO’s proposal as allowing load and 
generation to be studied in parallel using consistent assumptions, thereby addressing timing 
mismatches between existing study processes.82  MISO subsequently developed that concept into 
LARS and has included it within its broader large load framework.  While LARS is an independent, 
standalone process and does not need the other parts of the framework to proceed as explained by 
Ms. Drake, it is complementary to other proposals in MISO’s large load framework.83  While the 
ZGIA process addresses the generator interconnection service and study framework for generation 
serving co-located load, LARS will address the distinct study issues presented by new generation 
and large load that are electrically proximate but are not eligible for ZG Interconnection Service.  
 
LARS is intended to work in concert with MISO’s broad large load framework by 
facilitating the coordinated study of qualifying large load additions and associated generation while 
 
76  DOE, Speed to Power Initiative (Sept. 18, 2025) (describing Speed to Power as an initiative to accelerate 
development timelines for large-scale transmission and generation projects to meet rising demand for reliable and 
secure energy). 
77  Midcontinent Indep. Sys.  Operator, Inc., 195 FERC ¶ 61,212 (2026) (“Show Cause Order”). 
78  Id. 
79  Id. at P 117 (expressing concern that the absence of such procedures and services could result in MISO’s generator 
interconnection process failing to keep pace with new large loads seeking to integrate onto the MISO transmission 
system). 
80  Id. at P 113-119. 
81  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6 (Jul. 16, 2026), available at: 
https://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20and%20Load%20Alignm
ent%20Presentation768740.pdf. 
82  See MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Stakeholder Feedback (July 30–31, 
2026) (including stakeholder feedback supporting an integrated process for studying load and generation in 
parallel 
and 
addressing 
timing 
mismatches 
between 
existing 
processes), 
available 
at: 
https://www.misoenergy.org/engage/stakeholder-feedback/2026/llwg-generation-and-large-load-alignment-
llwg-2026-6-20260716/.  
83  See Drake Testimony at 8.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 20 
 
 
 
maintaining appropriate limitations on the rights available to generation that has not completed 
MISO’s ordinary Generator Interconnection Queue process.84  The preservation and protection of 
the DPP process was an express consideration in the LARS stakeholder process.  Stakeholders 
have raised questions regarding how LARS generation will interact with generation already 
progressing through the ordinary Generator Interconnection Queue and the protections necessary 
to avoid adversely affecting existing Interconnection Customers.85  The transmission capacity 
headroom available at the beginning of the DPP cycle is still available the end of the cycle and is 
not impacted by the LARS Applications.86  Similarly, the transmission capacity headroom for the 
LARS models are separate and distinct as they start with different MTEP base models and the 
LARS models are not inclusive of generation without executed GIAs.  The models from LARS 
and the DPP process will be reconciled through MTEP.87   
 
In addition to ZGIA and LARS, MISO is working with stakeholders through the LLWG on 
additional initiatives that will address the other concerns raised by the Show Cause Order.  MISO 
has introduced several of these initiatives at the LLWG meetings and many have specific details 
that are still being worked out with stakeholders.  These additional initiatives and proposals will 
be evaluated through the LLWG through the fall and will ultimately be presented to the 
Commission in separate FPA section 205 filings by November 16, 2026.   
 
B. 
ADDRESSING FERC’S SHOW CAUSE ORDER: ELECTRICALLY PROXIMATE 
REQUIREMENT 
MISO continues to advance a coordinated set of solutions designed to balance speed to 
power, fairness, and, most importantly, reliability.  In particular, MISO has developed solutions 
that are responsive to the Commission’s concerns noted in the Show Cause Order surrounding the 
interconnection and study processes for co-location arrangements, large load reliability 
requirements, and now is addressing the need for service of proximate large loads.  MISO has 
developed LARS against this backdrop of its broader efforts to address the reliable integration of 
large loads and associated generation.  MISO developed the ZGIA process through the LLWG with 
express consideration of resource adequacy, markets, and reliable operations.88  The LARS offers 
more flexibility in the siting of the load/generation pair to maximize the effectiveness of any 
transmission solutions developed.  Thus, the ZGIA process will be utilized to meet the co-located 
 
84  See id. at 7-8.  
85  See MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6, Stakeholder Feedback (Sept. 9, 2026) 
(reflecting stakeholder comments concerning the relationship between LARS and the existing Generator 
Interconnection Queue). 
86  See Drake Testimony at 32-33. 
87  See id. 
88  ZGIA Filing at 5-6.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 21 
 
 
 
portion of the Order and LARS will address the electrically proximate large load portion of the 
Order, by pairing generation with large load in the same LRZ.   
In its Show Cause Order, the Commission found that MISO’s Tariff “appears to be unjust 
and unreasonable” because it did not contain provisions allowing an interconnection customer to 
serve “an electrically proximate large load.”89  The Commission defined electrically proximate 
large load to mean a large load “that is sufficiently electrically close to the interconnection 
customer’s requested point of interconnection, such that the impact on the transmission system of 
the combination of the generating facility and the load, with the exception of the transmission 
facilities between the two, will be effectively the same as if they were located at the same 
substation (e.g., large load that is located no more than two substations away from the generating 
facility).”90  The Commission then stated that it would consider proposed revisions to this 
definition to “ensure it is appropriately tailored to MISO’s transmission system.”91  Per this 
invitation, MISO is now proposing revisions that address the Commission’s concerns related 
electrically proximate generation and load pairs as part of a broader regionally-tailored framework.   
 
LARS establishes the Tariff structures necessary to enable an Interconnection Customer to 
serve an electrically proximate load under study processes that reflect the interaction between 
generation and load.  In MISO, anchoring the proximate requirement with the LRZ is more 
efficient and effective because it aligns with MISO’s existing resource adequacy construct and 
enables more generation to serve a single load across a broader area but in a manner that still 
addresses resource adequacy and reliability of the system.  MISO did not want to limit the pairing 
of generation with associated load to a specific number of substations because that is likely too 
geographically narrow and could limit how MISO may optimize common transmission solutions.  
Moreover, allowing Generating Facilities participating in LARS to interconnect at multiple POIs 
provides a “proximate plus” solution for the pairing of load with generation.  This provides 
Interconnection Customers with the necessary flexibility to serve extremely large loads and in way 
that MISO can optimize any necessary transmission solutions.  As Ms. Drake explained in her 
testimony, “[u]ltimately, limiting the generation and LARS Associated Load to locations within 
the same LRZ ensures deliverability of the generation to the LARS Associated Load because it 
avoids potential capacity import / capacity export limitations for the individual LRZ and also 
avoids price separation between the paired generation and LARS Associated Load.”92  This 
structure also reflects stakeholder feedback regarding the need to accommodate the 
interconnection of large, landlocked loads that may need additional POIs.  
 
The LARS process was designed to produce optimized load-and-generation Network 
Upgrades, which aligns with the intent of the Show Cause Order and the proximate generation 
requirement.  Requiring the load and the generation to be located in the same LRZ provides the 
necessary proximity while also providing sufficient flexibility to enable LARS to be a successful 
 
89  Show Cause Order at P 113.  
90  Id. at P 112.  
91  Id.  
92  Drake Testimony at 40-41.

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October 2, 2026 
Page 22 
 
 
 
process.93  MISO is confident that LARS is a beneficial addition to its large load framework, 
differentiated from the co-location requirements of the ZGIA process, and provides another just 
and reasonable way for large loads to connect to the grid.  Accordingly, LARS intends to provide 
a resource solution associated with significant new demand without establishing an unrestricted 
alternative to MISO’s ordinary generator interconnection process.  Together with the ZGIA 
framework, LARS provides MISO with an additional mechanism to facilitate the development of 
resources needed to support significant new load growth while maintaining reliability and 
appropriate protections for existing Interconnection Customers. 
 
IV. 
DESCRIPTION OF PROPOSED TARIFF REVISIONS 
 
To implement the LARS process proposed herein, MISO is requesting approval of new 
Tariff provisions, as well as revisions to several existing provisions.94  
A. 
Attachment X (Generator Interconnection Procedures).  
The proposed Tariff revisions implement the LARS process and are necessary to 
distinguish the key differences in how the LARS study process and the resulting LLGIA will 
operate in comparison to MISO’s standard three-phase generator interconnection queue.  For 
convenience, MISO discusses the revisions to the GIP by section, below.  
 
1. Section 1: Definitions 
 
Section 1 contains definitions that are used throughout the GIP and its supporting 
attachments. MISO is proposing both to add several new terms and definitions to Attachment X, 
as well as to revise the definition of several existing terms.  The proposed new definitions are 
necessary to implement the LARS process and to provide clarity and consistency throughout the 
GIP. MISO proposes the following revisions to existing definitions in Attachment X: 
Interconnection Customer shall mean any entity, including Transmission Provider, 
Transmission Owner or any of the Affiliates or subsidiaries of either, that proposes to 
interconnect its Generating Facility with the Transmission System.  For the purposes of 
Large Load Addition Resource Study (LARS), Interconnection Customer shall refer to the 
entity developing the Generating Facility that will execute the LLGIA, which may be a 
different entity from the LARS Associated Transmission Customer that submitted the 
LARS Application.  
Interconnection Request shall mean (1) an Interconnection Customer’s request, in the 
form of Appendix 1 to the Generator Interconnection Procedures, to interconnect a new 
 
93  Id. at 39-40. 
94  This transmittal letter frequently quotes proposed Tariff revisions to facilitate its explanation.  In the event of a 
conflict between the Tariff language as discussed in this letter and that reflected in the attached Tariff sheets, 
MISO intends that the language in the attached Tariff sheets control.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 23 
 
 
 
Generating Facility, or a request for the Expedited Resource Addition Study for a new 
generation capacity, or a request for the processing of a proposed Generating Facility as 
part of a Large Load Addition Resource Study, or to increase the capacity of, or make a 
Material Modification to the operating characteristics of, an Existing Generating Facility 
that is interconnected with the Transmission System, or to interconnect an Existing 
Generating Facility that is external to the Transmission System, or to change Energy 
Resource Interconnection Service to Network Resource Interconnection Service for an 
Existing Generating Facility; or (2) an MHVDC Connection Customer’s request, in the 
form of Appendix 1 to the Generator Interconnection Procedures, to obtain Injection 
Rights. 
Party or Parties shall mean Transmission Provider, Transmission Owner, Interconnection 
Customer, LARS Associated Transmission Customer, or any combination of the above.   
These changes are necessary to properly document that LARS projects will be studied separately 
from MISO’s generator interconnection queue and will require a separate election in Appendix 1 
to the GIP (“Interconnection Request for a Generating Facility”) to be studied as a LARS project.  
MISO proposes these revisions to ensure that the LARS process is included in the Interconnection 
Request procedures and to clarify that the Interconnection Customer in the LARS process may not 
be the same entity that is the Transmission Customer or Transmission Owner.  
MISO also proposes the following new definitions for addition to the GIP (and LLGIA): 
Large Load Addition Resource Study (LARS) shall mean the procedure as set forth in 
Section 3.12 of this GIP for studying a Interconnection Customer’s proposed Generating 
Facility in parallel with the study of a LARS Associated Load Customer’s proposed load.    
Large Load Addition Resource Study (LARS) Period shall mean the period of time in 
which Interconnection Requests for proposed Generating Facility are studied in parallel 
with the study of a LARS Associated Load Customer’s proposed load. There are three 
LARS study periods in one year and each study period will run for approximately 120 days. 
All Interconnection Customers requesting to join the next Large Load Addition Resource 
Study (LARS) shall submit their Interconnection Request to the Transmission Provider no 
later than the LARS application deadline as published on the MISO public website, which 
shall be at least twenty (20) Business Days prior to the scheduled kick-off of the LARS 
cycle published on the MISO public website.   
These definitions are necessary to describe the study that MISO will conduct for a 
generation/load pair in the same process.  These definitions also establish that LARS will be 
conducted three times per year and provides the timing requirements of when the LARS 
Applications must be submitted to MISO to be included in the LARS process.  
Large Load Generator Interconnection Agreement (LLGIA) shall mean the form of 
interconnection agreement governing the terms and conditions of Large Load 
Interconnection Service, set forth in Appendix 6 to the GIP.  This agreement shall follow

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 24 
 
 
 
the form of the Transmission Provider’s pro forma Generator Interconnection Agreement 
with modifications to reflect the Large Load Addition Resource Study process.  Unless 
otherwise provided in the GIP, all requirements applicable to the pro forma Generator 
Interconnection Agreement shall apply to the LLGIA.  A LLGIA is a form of GIA and, 
where used in the Tariff, references to Generator Interconnection Agreements or GIAs 
encompasses LLGIAs.  
MISO proposes the above definition for the pro forma agreement that would be tendered 
to an Interconnection Customer at the conclusion of the LARS process.  MISO notes that the 
LLGIA is closely based on the MISO’s pro forma GIA in Tariff Attachment X, Appendix 6 with 
modifications as described below.  MISO includes the last sentence of this definition to avoid any 
confusion and clarify that the numerous references in other sections of the Tariff to GIAs include 
LLGIAs by default.95  
LARS Application shall be a single submission consisting of the materials required for 
LARS processing as required by Section I.D.1.b.ii of Attachment FF to the Tariff as well 
as the information required for studying the Generating Facilities under this Attachment X 
(in the form of Appendix 1) to these generator interconnection procedures. For purposes of 
this GIP, a LARS Application shall be a form of Interconnection Request.   
MISO is adding this defined term to the Tariff provides the vocabulary needed for discussing all 
of the pieces of information that must be supplied to MISO in a single submission prior to 
participating in the LARS process.  
LARS Associated Load shall mean a source of electrical load that is at least 200 MW and 
that is formally paired with one or more Interconnection Customer(s) that have submitted 
an Interconnection Request to LARS proposing one or more new Generating Facility(ies) 
to provide energy to such load.    
LARS Associated Transmission Customer shall mean the entity that is responsible for 
submitting the LARS Application and procures Transmission Service in order to serve 
LARS Associated Load and designates such load as formally paired with an 
Interconnection Customer’s LARS Interconnection Request.  
Adding these defined terms to the Tariff provides the vocabulary needed for discussing the specific 
load that a Generating Facility with a LLGIA is limited to serving and to identify the entity 
responsible for submitting the LARS Application.  
 
95  MISO has built its LLGIA Tariff sheets using the latest effective version of Appendix 6 to Attachment X of the 
Tariff.  This does not include the ZGIA revisions currently housed in Appendix 19, which are pending before the 
Commission in Docket No. ER26-3552-000 or MISO’s revisions submitted in compliance with Order No. 2023, 
which remains pending before the Commission in Docket No. ER24-2046-003.  MISO has used this approach for 
version control and administrative reasons.  MISO commits to reconcile these versions as appropriate once they 
are accepted.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 25 
 
 
 
2. Section 2.1—Application of Generator Interconnection Procedures 
MISO proposes to add a subsection k to GIP Section 2.1 that governs the application of 
interconnection procedures.  This subsection explains that a request for LARS should be evaluated 
according to the procedure in GIP Section 3.12, which is a new Section MISO proposes to add for 
the implementation of the LARS process.  This addition is necessary to distinguish the process for 
evaluating requests for LARS from other projects entering MISO’s generator interconnection 
queue. 
3. Section 3.3.1—Valid Interconnection Request  
MISO proposes to revise Section 3.3.1, which encompasses the procedures for submitting 
an Interconnection Request.  The revisions include clarifying language surrounding the timeline 
for submitting LARS Applications to MISO and where the application timeline will be posted on 
the MISO website.  MISO also proposes to increase the Non-Refundable Deposit 1 (D1) to 
$250,000 for LARS projects and to require an entry milestone (M2) of $30,000 per Megawatt for 
new Interconnection Service requested to ensure only projects that are “shovel ready” and 
commercially viable apply to LARS.  
To further demonstrate that a project is “shovel ready,” all documentation, milestone 
payments, deposits and any necessary data is required at the time of LARS Application submission. 
These up-front requirements will allow MISO to complete the study process within its estimated 
120-day timeframe.  MISO also proposes to require that LARS projects have a Commercial 
Operation Date within three calendar years from the date of the Interconnection Request and the 
LARS Associated Load will have an identical anticipated Service Commencement Date.  All 
LARS projects are eligible to use the grace period of up to three years as documented in GIA 
Article 2.3.1.  
4. Section 3.5.1.1—Inclusion in a JTIQ Screening Group, JTIQ Participation 
Group, and JTIQ Commitment Group  
MISO proposes to revise GIP Section 3.5.1.1 subsection (1) to clarify that LARS projects 
shall be included in a JTIQ Screening Group, along with projects in the generator interconnection 
queue.  As discussed in prior stakeholder meetings, MISO intends to consider LARS projects for 
JTIQ. This revision is necessary to ensure that LARS projects are properly included in JTIQ 
Screening Groups along with projects from MISO’s DPP interconnection queue.  
5. Section 
3.5.4—Affected 
Systems 
Coordination 
Procedures 
to 
Interconnection Requests Included in a Large Load Addition Resource 
Study 
MISO proposes new Section 3.5.4 governing coordination with affected systems in the 
evaluation of Interconnection Requests participating in LARS.  Proposed Section 3.5.4 closely 
follows the affected systems coordination procedure accepted for ERAS Interconnection Requests.  
Specifically, proposed Section 3.5.4 provides that MISO will apply the same coordination

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 26 
 
 
 
procedures and screening criteria as that used for Interconnection Requests in the DPP.  MISO 
submits that these rules are appropriate because they provide a structure for processing 
Interconnection Requests for LARS rapidly and in a manner that recognizes the serial nature of 
such studies.  Requiring LARS Interconnection Customers to execute LLGIAs where affected 
systems information has not yet been provided is necessary to maintain the accelerated speed of 
the LARS process and to provide certainty to LARS Interconnection Requests in subsequent LARS 
study periods whose models will be built from the prior completed study.  MISO will work with 
its AFS partners to accelerate the AFS study process of any projects participating in LARS.  
6. Section 3.12—Large Load Addition Resource Study 
MISO proposes to add new GIP Section 3.12 to encompass the necessary processes and 
implementation details for the LARS process.  LARS provides a single application and study 
process that produces an optimized set of Network Upgrades in 120 days for any large load and 
generation pair that meet the requirements set out in this section.  
7. Section 3.12.1 – Pre-Submission Coordination Process  
Proposed Section 3.12.1 explains the pre-coordination procedures required for parties to a 
LARS Application. The purpose of this new section is to build in a coordination and collaboration 
process into the LARS timeline.  Since a LARS Application requires information from a wide 
variety of parties, a viable application requires that the parties have met and agreed on key details 
before submitting the required materials to the LARS process.  These agreements will ensure that 
all the parties agree on the POI for the Generating Facility(ies), avoiding post-submission 
withdrawals and enabling MISO to complete the LARS studies on an accelerated basis.  
First, the revisions state that the LARS Associated Transmission Customer initiates and 
submits the LARS Applications with support from the Interconnection Customer on the generation 
side and the Transmission Owner on the load side.  
Second, the proposed language explains the timeline for when Interconnection Customers 
looking to participate in LARS must contact the Transmission Owner to request a meeting to 
determine the POI for the Generating Facility.  Interconnection Customers must request this 
meeting at least 45 calendar days prior to a LARS Application deadline.  The Transmission Owner 
is then required to meet with the Interconnection Customer and any other impacted parties within 
10 business days.  Following the meeting to discuss an agreed-upon POI for the Generating 
Facility, the Tranmission Owner will have at least 15 business days to provide an attestation for 
the LARS Application, which will state that the parties have agreed upon a definitive POI. This 
last provision is needed to avoid leaving the Transmission Owner with too little time to make the 
attestation. 
8. Section 3.12.2 
MISO proposes to add new GIP Section 3.12.2 to explain the requirements for participating 
in the LARS process.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 27 
 
 
 
First, MISO proposes to require the LARS Associated Transmission Customer and the 
potential LARS Interconnection Customer to provide an executed agreement evidencing that the 
output of the Generating Facility for which LARS processing is sought is intended to be used to 
provide energy to the LARS Associated Load.   The proposed language is as follows: 
A LARS Application for processing through the Large Load Addition Resource 
Study must meet the requirements listed in Section 3.3.1 above, plus the following 
requirements: 
 
i. 
The Interconnection Request shall be accompanied by an agreement executed 
by the Interconnection Customer and either the LARS Associated Transmission 
Customer or the entity that owns or controls the LARS Associated 
Load evidencing that the output of the Generating Facility for which LARS 
processing is sought shall be used to provide energy to the LARS Associated 
Load.  Such agreement shall take one of the following forms and state a 
minimum term of at least five (5) years to align with MISO’s transmission 
planning horizon as described in Section I.D.1.b.ii of Attachment FF to the 
Tariff:  
 
a. A power purchase agreement (PPA) or similar off-take agreement between 
the Interconnection Customer submitting the Interconnection Request for 
LARS processing and the entity with the LARS Associated Load to be 
served (including, but not limited to, an Alternative Retail Electric Supplier 
or its Load Serving Entity); or 
b.  An agreement that calls for the Interconnection Customer to develop the 
Generating Facility described in the Interconnection Request and 
subsequently transfer ownership or control of such Generating Facility 
(Build-Own-Transfer Agreement) to the entity with the LARS Associated 
Load to be served (including, but not limited to, an Alternative Retail 
Electric Supplier or its Load Serving Entity); or 
c. For Load Serving Entities (or an Alternative Retail Electric Supplier or 
equivalent in a retail choice state), evidence of other types of agreements 
that provide that the generation is intended to serve the LARS Associated 
Load customer. These agreements include, but are not limited to, a special 
contract, a large load tariff agreement, or retail service agreement.  
 
This requirement is necessary both to prevent speculative Interconnection Requests, and to verify 
that the LARS Associated Load intends to use the output of the Generating Facility.  The agreement 
may take several forms, as documented in Section 3.12.2, depending on the type of project and 
associated parties.  This language is intended to limit LARS projects to those that have been 
formally paired together, while also ensuring that certain business models and agreements are not 
excluded from participating in LARS.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 28 
 
 
 
Second, MISO proposes to require any Interconnection Request submitted as part of a 
LARS Application include documentation demonstrating that the Electromagnetic transient 
(“EMT”) modeling requirements have been met for inverter-based resource (“IBR”) generation as 
specified in MISO’s BPM.  Including the specific technical data needed in the BPM is consistent 
with requirements for other types of Interconnection Requests and provides needed flexibility to 
update specific technical details as MISO and its stakeholders gain experience with new kinds of 
Interconnection Service Requests. 
Third, MISO proposes to require that any Interconnection Request submitted as part of a 
LARS Application Demonstrate 100% site control including 100% generator and Interconnection 
Customer Interconnection Facility (“ICIF”) site control.  This is to ensure that truly “shovel-ready” 
projects apply to participate in LARS and reduces the risk of withdrawals later in the process.  
Fourth, MISO proposes to require that any Interconnection Request submitted as part of a 
LARS Application include a one-line diagram showing the Generating Facility and associated 
electrical equipment. MISO also proposes to require a detailed power flow model for the proposed 
Generating Facility that includes the POI and any proposed system protection facilities.  Because 
LARS Generating Facilities are restricted to serving a specified load, the LARS Associated Load, 
submission of detailed and accurate one line diagrams and power flow models showing both the 
Generating Facility, the LARS Associated Load, protection facilities, and their configuration with 
respect to the Transmission System is critical to accurately studying how a proposed LARS 
Generating Facility will interact with the Transmission System and to ensuring limited impacts.  
In addition, it is essential to document this configuration in the resulting LLGIA because the results 
of the LARS study will depend on the proposed configuration remaining as proposed. 
Sixth, MISO proposes to require that any Interconnection Request submitted as part of a 
LARS Application request NRIS in an amount that is at least 200 MW (the minimum threshold for 
a LARS Associated Load) and in an amount that is not more than 150% of the peak Demand of 
the LARS Associated Load. The LARS Application must include the LARS Associated Load’s 
expected peak demand over any one-hour period.  This will allow MISO to know what the total 
amount of MW demand is expected from this load and ensure that the total amount of requested 
Interconnection Service by the Generating Facilities does not exceed 150% of that peak demand 
amount.  These requirements strengthen the connection between the Generating Facility and the 
LARS Associated Load in such a manner as to consider them formally paired.  Allowing a 
Generating Facility to serve up to 150% of the load’s peak demand also allows for more flexibility 
in the kinds of generation that may participate in LARS.  
MISO also proposes to require that the LARS Associated Load and any paired Generating 
Facilities be located in the same LRZ.  In order to address the Commission’s desire for large loads 
to have the option to be located electrically proximate to generation, MISO is proposing to expand 
the concept of “electrically proximate” to the LRZ and not limit it to a pre-determined number of 
substations.  This serves two purposes.  First, this allows load and generation to site near each 
other in a flexible way that will also optimize any common transmission solutions. Second, placing 
the electrically proximate requirement within the LRZ construct aligns LARS with MISO’s 
existing resource adequacy construct.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 29 
 
 
 
Seventh, MISO is establishing three-year deadline for a Generating Facility’s Commercial 
Operation date and requiring that the LARS Associated Load reach its full-service amount in the 
same amount of time.  This provision provides the flexibility needed to enable both the generation 
and load to come online at roughly the same time while also providing a deadline by which they 
both must be fully operating on MISO’s system.  The Commercial Operation Date provisions 
follow those applicable under MISO’s standard process.  The requirement to specify an analogous 
date for the LARS Associated Load preserves and reinforces the linkage between the Generating 
Facility and the LARS Associated Load that underpins the LARS study.  
Eighth, MISO is proposing to include a provision that would allow Interconnection 
Customers participating in LARS to elect the option to build.  Notably, MISO is requiring that the 
Interconnection Customer include that election at the time of submission of the LARS Application 
and MISO will not accept future elections for the option to build after the LARS Application is 
submitted.  This is to ensure certainty for MISO study processes and so that the proper internal 
administrative timelines can be established upon the submission of the LARS Application.  
Ninth, MISO proposes to add provisions to allow a LARS Associated Load to be served 
by multiple Generating Facilities.  The proposed revisions are as follows: 
A LARS Associated Load may be served by multiple Generating Facilities provided that: 
1. All Generating Facilities serving a LARS Associated Load behind the same Point 
of Interconnection must be identified in the LARS Application for the specific 
LARS Associated Load and must request a minimum of 200 MW of 
Interconnection Service in the aggregate; or,   
2. Multiple Generating Facilities serving a LARS Associated Load may be located 
behind different Points of Interconnection provided that they: 
a. Be located in the same LRZ as the LARS Associated Load, 
b. Request a minimum of 200 MW of Interconnection Service for all Generating 
Facility(ies) behind a separate Point of Interconnection; and, 
c. Be submitted as a separate LARS Application for the amount of demand of the 
LARS Associated Load it will serve through that Point of Interconnection.  
 
MISO made this change in response to stakeholder requests to allow multiple POIs for generation 
located within the same LRZ as the LARS Associated Load.  This revision allows multiple 
generators to aggregate behind a single POI to serve one LARS Associated Load.  Due to the size 
of some of the large loads that are looking to connect to the system, allowing Generating Facilities 
to aggregate to supply for the large load is efficient.  Adding the requirement that the Generating 
Facilities contained in a single LARS Application be sited behind a single POI enable MISO to 
adequately study the load with the requested generation.  The requested minimum of requested 
Interconnection Service by the Generating Facilities must be at least 200 MW at each POI and 
generators can aggregate to reach that minimum.  A LARS Associated Load may be served by 
several different groups of Generating Facilities at multiple POIs. To assist MISO with keeping 
track of the LARS Associated Load and its paired Generating Facilities, a LARS Application must

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 30 
 
 
 
be submitted for each POI group of Generating Facilities.  Thus, a LARS Associated Load should 
have a LARS Application for each POI where generators are serving it.  
Tenth, MISO proposes to add language stating that no changes shall be made to the LARS 
Application, including any underlying Interconnect Requests, after submission.  The proposed 
revisions are as follows: 
No changes shall be made to the LARS Application after submission and prior to the 
execution or the unexecuted filing of the LLGIA and MTEP approval for the LARS 
Associated Load except that a LARS Application that is deferred to the next available 
LARS Study Period will be allowed to extend its In-Service Date or Commercial Operation 
Date to be no more than three calendar years from the kickoff of the LARS Study Period 
in which its LARS Application is studied.  
 
Because the timeline from submission to an executed LLGIA is 120 days, this proposed language 
is necessary to ensure that LARS projects are studied expeditiously and can be online as soon as 
possible to meet the stated resource adequacy and/or reliability need.  To make this timeframe 
workable and avoid delays that would impact other Interconnection Customers, it is necessary to 
require that these Interconnection Services be well-considered and provide certainty with respect 
to the details to be studied at the time they are submitted.  This readiness requirement is mitigated 
by the fact that MISO will complete the LARS study process three times per year.  Therefore, an 
Interconnection Customer that is not certain of the details to be included in its Interconnection 
Request for the LARS Application would only need to wait until the following LARS study period 
for another opportunity to participate.  Moreover, MISO has included language that will allow 
LARS applicants to change their COD or In-Service Date if their LARS Application is pushed to 
a later LARS study period.  
 
Eleventh, MISO proposes a paragraph to allay concerns expressed during the stakeholder 
process that LARS could be read as conflicting with state and local laws by allowing the owner of 
a generator that is not a Load Serving Entity to serve load when not authorized to do so by state 
law.  The inclusion of this language neither imposes, nor is intended to impose, any independent 
restrictions on an Interconnection Customer. 
Finally, MISO proposes to limit the period of review to identify deficiencies in LARS 
Applications to a single period for MISO and to limit the period for curing the identified 
deficiencies to a single period for the LARS applicants.  This will ensure that the study process 
remains on track and timely as it avoids multiple review and cure periods for MISO and the LARS 
participants.  If the LARS Application is not cured within the one allotted cure time period, then it 
will be automatically withdrawn from LARS with any associated penalties.   
9. Section 3.12.3 – Evaluation Process for Large Load Addition Resource 
Study Interconnection Request 
MISO proposes to add GIP Section 3.12.3 to facilitate the evaluation process of projects 
seeking to use LARS and limits the number of generation/load pairs to be studied to ten per LARS

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 31 
 
 
 
study cycle.  The proposed language explains that projects will be evaluated in the order in which 
they are submitted.  Proposed language also clarifies that if the project is found to be ineligible for 
LARS, the project will lose its Non-Refundable Deposit D1.  The risk of losing a large deposit if 
determined to be ineligible for LARS will encourage parties to only submit projects that they are 
certain will meet the strict LARS requirements.  This requirement addresses MISO’s need for 
certainty on transmission needs and their associated costs.  
Proposed Section 3.12.3 also documents the process for projects currently in the DPP 
process to transfer to LARS for evaluation.  In the situation where a project in the generator 
interconnection queue is eligible to participate in LARS, proposed language clarifies that the 
project will forfeit its Non-Refundable Deposit D1 and will be subject to withdrawal penalties per 
Sections 7.6.2.1.1 and 7.8.  This proposed addition is necessary to ensure that projects dropping 
out of the generator interconnection queue do not harm remaining projects in their respective 
cycles.  Similarly, proposed language in Section 3.12.3 limits projects from leaving the generator 
interconnection queue to LARS to only those that have not reached Decision Point II.  This 
language is required to ensure that projects remaining in the generator interconnection queue are 
not harmed by restudies that occur after projects drop out after Decision Point II.   
10. Section 3.12.4 – The Study 
MISO proposes to add a new GIP Section 3.12.4 to describe the studies that will take place 
for LARS generation projects. The proposed revisions are as follows: 
The Interconnection Study for LARS will follow the same manner of NR 
Interconnection Study as noted in Sections 3.2.1.2 and 3.2.2.2 needed to integrate 
the Generating Facility in the same manner as for any Generating Facility being 
designated as a Network Resource.  Transmission Provider will use Reasonable 
Efforts to study LARS Interconnection Requests from all Interconnection 
Customers regardless of Generating Facility within sixty (60) Calendar Days after 
the kickoff date for such study.  The study will be performed for each 
Interconnection Request, including the LARS Associated Load, individually in a 
serial fashion based on their submission date per LARS Study Period.  The LARS 
interconnection study will result in a Final LARS System Impact Study and any 
associated LARS Interconnection Facilities Studies. 
 
Transmission Provider shall include in the final study any Affected System Study 
results and information regarding Network Upgrades from Affected Systems 
provided the Affected System Study Reports are available.  If Affected Systems 
analysis is not available for inclusion in the final LARS study, the Transmission 
Provider shall provide such analysis separately when received from the applicable 
Affected System. 
 
Mitigations developed to address violations observed in only the transmission 
studies shall be assigned Baseline Reliability Projects (BRP) or Other project 
types.  Mitigations developed to address common violations observed in both the

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 32 
 
 
 
transmission study and the generation study shall be assigned Baseline Reliability 
Projects (BRP) or Other project types.  Mitigations developed to address violations 
observed only in the generation study shall be assigned to the LARS 
Interconnection Customer under the Generator Interconnection Project (GIP) 
project type.  
 
This proposed section implements the alignment of the load and generation study process and 
describes the generation study side of LARS.  The transmission and generation studies remain 
separate but run in parallel and conclude at approximately the same time.  This language is 
necessary for LARS Applications to be evaluated on a rolling basis during each LARS study 
period.  The studies will be performed serially, based on submission date. Serial studies are ideal 
for LARS projects since there will be a considerably smaller number of proposed LARS 
generation/load pairs per year.  On the generation side of the LARS study process, each 
generation/load pair will be studied individually in a serial fashion in their own model.  
Proposed language in this section also explains that any Affected System Study results, if 
available, will be included at the time of the final LARS study.  If the Affected System Study 
results are unavailable at the time of the final study, those results will be provided separately when 
received from the applicable Affected System. 
 
Finally, the proposed language at the end of Section 3.12.4 addresses how mitigations 
developed to address violations will be assigned depending on where they were observed.  If they 
were only observed in the load side study of LARS, then they will be assigned BRPs and Other 
project types.  If mitigations were developed to address violations observed in both the generation 
and load studies, then they will be assigned BRPs and Other project types.  And finally, any 
mitigations developed to address violations observed that were caused only in the generation study 
will be assigned to the Interconnection Customer under the Generator Interconnection Project 
(“GIP”) project type.  
11. Section 3.12.5 – Notice to Proceed to LLGIA  
MISO proposes to add the following Section 3.12.5, which is titled Notice to Proceed to 
LLGIA.  This proposed language is necessary to distinguish between the shorter timeline for LARS 
and the general timeline for providing a notice to proceed for a DPP interconnection project. The 
shortened five Business Day timeline is necessary to allow Customers to execute their LLGIA 
within approximately 120 days from kickoff of the LARS study period.  
12. Section 3.12.6 – GIA for Large Load Addition Resource Study Projects 
(LLGIA) 
Proposed GIP Section 3.12.6 governs the timeline and necessary requirements regarding 
tender of the draft pro forma LLGIA and JTIQ applicability, and also points to Sections 11.1 
through 11.4 of the GIP governing procedures such as MISO’s tender of the draft LLGIA, 
negotiations, and execution of the LLGIA.  This proposed Section provides a five Business Day

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 33 
 
 
 
timeline for MISO to tender a draft pro forma LLGIA after receiving notification of the 
Interconnection Customer’s intent to proceed to LLGIA.  
Due to the varied nature of MISO’s and SPP’s processes related to JTIQ Service 
Agreements, proposed revisions provide a path forward for JTIQ eligible LARS projects if SPP’s 
JTIQ Service Agreement has not been provided to the Interconnection Customer prior to the tender 
of the draft LLGIA.  If the SPP JTIQ Service Agreement has not been received at the time of 
MISO’s tender of the LLGIA, proposed language requires JTIQ eligible LARS projects to include 
a milestone in GIA Appendix B requiring the parties to execute or request the unexecuted filing of 
an SPP JTIQ Service Agreement within 15 Calendar Days after such agreement has been tendered 
to the Interconnection Customer.  Proposed language also states that LARS Interconnection 
Requests included in a JTIQ Participation Group shall adhere to all JTIQ procedures and execute 
JTIQ Service Agreements as applicable. 
13. Section 3.12.7 – Large Load Addition Resource Study Refunds 
Proposed GIP Section 3.12.7 and its subparts document the process for obtaining refunds 
of study deposits and milestone payments in the LARS process.  
Proposed GIP Section 3.12.7.1 governs applicable refunds of the Study Deposit (D2).  As 
with generator interconnection requests, LARS D2 study deposit amounts are based on Megawatt 
amount of new Interconnection Service of the LARS project as stated in GIP Section 3.3.1.  The 
Interconnection Customer will be charged the actual amount of the Large Load Addition Resource 
Study and will be required to pay any additional costs or will be refunded any overages as 
applicable.  
Proposed GIP Section 3.12.7.2 details the process for receiving a refund of the LARS 
milestone payment M2.  LARS projects are eligible to receive a 100% refund of M2 upon 
withdrawal prior to execution of the LLGIA.  If a LARS project withdraws after execution of the 
LLGIA, the project is only eligible to receive a refund of any remaining M2 milestone after 
meeting the Initial Milestone Payment and/or Network Upgrade costs memorialized in the LLGIA.  
Should a project withdraw after execution of the LLGIA, the proposed Section 3.12.7.3 
documents the process for providing the initial payment to the Transmission Owner, which will 
occur within forty-five Calendar Days from the effective date of the LLGIA.  If the M2 provided 
by the Interconnection Customer exceeds the initial payment amount, MISO will provide a refund 
of any remaining M2 within 45 Calendar Days of the effective date of the LLGIA.  If the 
Interconnection Customer’s M2 is less than the initial payment, the proposed language of 3.12.7.3 
requires the Interconnection Customer to provide the remaining portion of the initial payment to 
the Transmission Owner.  
The proposed language in Section 3.12.7.4 describes what happens when the LLGIA is 
terminated or the large load is withdrawn from the LARS process before or after the minimum 
fifteen-year pairing period has passed.  The proposed language in the first paragraph is as follows:

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October 2, 2026 
Page 34 
 
 
 
In the event that the Interconnection Customer’s LLGIA is terminated after 
execution by all parties or after LLGIA is filed unexecuted, the Interconnection 
Customer will be responsible for the costs of the Network Upgrades that are 
classified as GIPs and documented in the LLGIA and/or corresponding FCAs or 
MPFCAs, including those GIP Network Upgrades arising from the Affected 
System Study process. The Interconnection Customer will be responsible for 
Network Upgrades resulting from a LARS Study that are classified as GIPs under 
Attachment X.  To the extent the generator fails to commence operation or retires, 
the load may go through MTEP and during that transition may be subject to 
similar limitations if the load’s Service Commencement Date is prior to the date 
LARS Generating Facility commences commercial operation. 
 
The purpose of this language is to clearly establish that the Interconnection Customer is 
responsible for all assigned Network Upgrades that are classified as GIPs identified in the LLGIA.  
MISO is proposing this language to ensure that whether or not the LLGIA is ultimately terminated 
or filed unexecuted, the Interconnection Customer is on the hook for the costs associated with its 
proposed project.  This is necessary to clearly assign responsibility to the Interconnection 
Customer and to protect other market parties from paying for those costs.  The language also 
clarifies what will happen to the LARS Associated Load if the Generating Facility fails to 
commence operations or retires completely.  
 
The next paragraph of Section 3.12.7.4 addresses these permutations in the following language:  
 
In the event that the LARS Associated Load is withdrawn from LARS or ceases use 
of the Transmission Service granted through LARS within the first fifteen (15) 
Calendar Years after the LARS Associated Load commences use of the 
Transmission Service granted through LARS, then operations of the Generating 
Facility shall be subject to the Annual ERIS (“AERIS”) and the Quarterly Operating 
Limit (“QOL”) for a one year period until termination as set forth in Article 2.3.1 
of the Attachment X Appendix 6. An Interconnection Customer that desires to 
continue injections shall be required to obtain Interconnection Service through the 
DPP as described in Attachment X.  The LLGIA will be terminated after the period 
specified in Article 2.3.1.  Following the first fifteen (15) Calendar Years after a 
LARS Associated Load ceases use of its Transmission Service or if the agreement 
required by GIP Section 3.12.2.i is terminated or otherwise ceases to be in effect, 
then Transmission Provider shall not terminate the Generating Facility’s 
Interconnection Service. 
Since the successful operation of LARS is dependent on the formal pairing of both the generation 
and load for fifteen years, MISO has proposed Tariff language to address different permutations 
of what happens if the generation were to stop operating or the load were to stop accepting 
Transmission Service within the first fifteen years.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 35 
 
 
 
If the LARS Associated Load ceases service within the first fifteen years, then the 
Generating Facility will have up to one year to acquire new Interconnection Service.  MISO added 
this provision in response to stakeholder concerns that the termination of the relationship between 
the LARS Associated Load and the Generating Facility (either through termination of their 
agreement or the LARS Associated Load discontinuing operations) could leave an otherwise useful 
Generating Facility suddenly without Interconnection Service and unable to serve other Load 
needs.  If the LARS Associated Load withdraws from LARS in the first fifteen years, then its 
paired Generating Facility will be subject to AERIS and the QOL processes and will have up to 
one year to obtain Interconnection Service through the MISO DPP process.  If the Generating 
Facility is unable to obtain new Interconnection Service within one year, then the LLGIA will be 
terminated.  This is necessary to avoid any resource adequacy concerns that might be implicated 
by immediately terminating the LLGIA and provides flexibility for the Generating Facility to 
continue operating until it can be utilized in a different MISO process.  
 
If the LARS Associated Load ceases service after the first fifteen years of being formally 
paired, then it is reasonable to allow the Generating Facility to continue to utilize the 
Interconnection Service granted through the LLGIA.  Several stakeholders expressed concern that 
a permanent pairing requirement would strand a Generating Facility that had a remaining useful 
service life even if such Generating Facility could be used—or was needed—to address resource 
adequacy needs following the departure of the LARS Associated Load.  MISO added this language 
in response to these stakeholders’ legitimate concerns that Generating Facilities submitted to 
LARS in good faith and that had served LARS Associated Loads for long periods of time should 
not be forced to go offline or undergo a second study process with potentially significant new costs 
if the LARS Associated Load unexpectedly ceased operations.   
 
Thus, MISO is requiring the generation and load to remain paired for fifteen years because 
it provides important safeguards that prevent customers from misusing the LARS process to obtain 
Interconnection Service and only serve the LARS Associated Load for a short period of time. 
Fifteen years is also a reasonable time period as reflected in many standard large load contracts 
and sufficient to deter entities from invoking the needs of a specific large load as a pretext to bypass 
the DPP queue and receive immediate and unrestricted service.  This language clearly allows the 
Generating Facility to continue operating under the terms of the LLGIA after fifteen years have 
passed even if the LARS Associated Load ceases use of its Transmission Service.  This provides 
the Generating Facilities with certainty after the fifteen-year period has passed and allows for these 
facilities to continue assisting with any resource adequacy needs that may be occurring at that time.  
 
The final paragraph of Section 3.12.7.4 addresses what costs the LARS Associated 
Transmission Customer is required to pay for its participation in LARS.  The proposed language 
is as follows:  
 
Once MTEP approval occurs for the LARS Associated Load, the LARS Associated 
Transmission Customer remains responsible for the identified BRPs and Other 
assigned projects even if such LARS Associated Load does not commence 
service.  In addition, if the LLGIA for a LARS Associated Load is terminated, the

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 36 
 
 
 
LARS Associated Transmission Customer remain responsible for the costs thereof.  
If the load portion of the MTEP Project for the LARS Associated Load is 
withdrawn, then the Network Upgrade costs assigned as BRP or Other projects for 
the LARS Associated Load remains the responsibility of the LARS Associated 
Transmission Customer. If the load portion of the MTEP Project for the LARS 
Associated Load is withdrawn, the load may go through the applicable MTEP study 
process. 
 
The language clearly explains in what instances the LARS Associated Transmission Customer is 
required to pay for any assigned Network Upgrades.  Once MTEP approval occurs for the LARS 
Associated Load, then the LARS Associated Transmission Customer is on the hook for any of the 
Network Upgrade costs assigned to the load’s portion of the project.  This language is necessary 
to ensure that Network Upgrades are built as anticipated, even after a Generating Facility can no 
longer operate.  In this instance, the LARS Associated Load may go through the MTEP process.   
 
This section clearly identifies which party is responsible for what mitigation costs.  Once 
the LARS Associated Load receives MTEP approval, then the LARS Associated Transmission 
Customer remains responsible for the identified BRPs and Other type projects assigned even if the 
load does not commence service. Similarly, if the LLGIA is terminated, then the LARS Associated 
Transmission Customer remains responsible for any associated costs identified in the LLGIA.  If 
the LARS Associated Load commences service and then later withdraws the load portion of the 
MTEP Project, then the Network Upgrade costs assigned as BRP or Other projects remain the 
responsibility of the LARS Associated Transmission Customer.  These provisions are necessary to 
ensure that the proper party pays for the associated costs of their portion of the LARS project even 
if they never commence service or later withdraw from LARS.  These provisions can be 
implemented now and will be compatible with the large load study process reforms MISO is 
developing. 
14. Section 3.12.8 – Transfer of Ownership of Large Load Addition Resource 
Study Interconnection Request  
The proposed language in Section 3.12.8 is necessary to prevent transfers of ownership 
prior to LLGIA execution that might slow down the timeline for studying a LARS project and 
ultimately delay the ability for MISO to move LARS projects to LLGIA execution within 120  
days from kickoff.  Prohibiting any changes to a LARS Application prior to LLGIA execution will 
allow MISO to maintain its proposed LARS timeline and enable large loads to connect the system 
faster.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 37 
 
 
 
15. Section 3.12.9 – Modifications of Large Load Addition Resource Study 
Request  
The proposed Section 3.12.9 is necessary to ensure that no details of a LARS Application 
are changed during the study process.  The proposed revisions are as follows: 
After submission of the LARS Application, no modification to the Interconnection 
Request or any of its parameters, including any information provided by the 
Transmission Owner such as the agreed-upon Point of Interconnection, is permitted 
under Section 4.4 or otherwise prior to the execution or unexecuted filing of the 
final LLGIA.  Any modification made by the Interconnection Customer, LARS 
Associated Transmission Customer, or Transmission Owner prior to the execution 
or unexecuted filing of the final LLGIA shall cause the LARS Interconnection 
Request to be deemed withdrawn. 
 
After entering the Large Load Addition Resource Study as defined in Section 
3.12.4, no changes to the In-Service Date or Commercial Operation Date of the 
Generating Facility is permitted via section 4.4.4 except that a LARS Application 
that is deferred to the next available LARS Study Period will be allowed to extend 
its In-Service Date or Commercial Operation Date to be no more than three calendar 
years from the kickoff of the LARS Study Period in which its LARS Application is 
studied.  At the completion of the Large Load Addition Resource Study, the 
Commercial Operation Date and Service Commencement Date for the LARS 
Associated Load shall be set forth in the LLGIA.   
 
Consistent with Article 2.3.1 of the LLGIA, once that LLGIA is executed or filed 
unexecuted, if the Generating Facility fails to reach Commercial Operation by the 
specified Commercial Operation Date set forth in the LLGIA, such specified 
Commercial Operation Date as set forth in the LLGIA may be extended by 
Interconnection Customer for a period up to three (3) consecutive years, after which 
Transmission Provider shall terminate the  LLGIA if the Generating Facility has 
still failed to reach Commercial Operation. 
 
The proposed language is necessary to ensure that LARS Applications are able to be studied on 
both the load and generation side within the timeframe required by LARS. MISO has to have 
certainty to complete these studies in parallel and in 120 days.  Thus, it is not allowing any 
modifications to the information provided in the LARS Application and any modification made 
will result in the withdrawal of the LARS Application.  Similarly, the proposed LARS COD 
requirements set forth in GIP Section 3.3.1 are specifically for generation needed to meet load 
intended to come online while LARS is in place.  Disallowing changes to the In-Service Date or 
COD after entering LARS again provides the certainty necessary to ensure that these projects will 
remain paired during the process and will prevent projects with uncertain timelines from entering 
LARS.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 38 
 
 
 
16. Section 11 – Generator Interconnection Agreement (GIA), Facilities 
Construction Agreement (FCA), and Multi-Party Facilities Construction 
Agreement (MPFCA) 
Proposed revisions to Section 11.1 include the distinction that LARS projects will not 
complete restudies and that the tender of the draft LLGIA will occur after the Interconnection 
Facilities Study is initiated through LARS.  MISO also proposes to revise this Section to clarify 
that LARS Interconnection Requests tender of the LLGIA will occur on a different timeline than 
DPP projects, which timeline for tender is memorialized in new GIP Section 3.12.6.  These edits 
are necessary to properly document the shortened timeline for tender of LARS projects and the 
differences in timing between LARS projects with one study and DPP projects with multiple 
studies. 
MISO proposes to revise Section 11.2 to clarify that LARS projects will have a shorter, 10 
Business Day timeline to return comments on the draft LLGIA.  MISO also proposes to revise this 
Section to clarify that MISO shall tender a revised draft LLGIA after 5 Business Days of receiving 
the comments.  For LARS projects, negotiations of LLGIAS shall be no more than 20 Business 
Days from the notice to proceed in Section 3.9.4. Revisions to 11.2.1 clarify that LARS projects 
are unable to postpone the start of the LLGIA negotiation period.  These edits are needed to shorten 
the negotiations timeframe to keep the LARS process to approximately 120 days from kickoff to 
LLGIA execution.  This shortened timeframe will ensure that LARS projects are able to execute 
the LLGIA quickly and come online within the timeframe allotted to serve the project’s identified 
need. 
MISO proposes to revise Section 11.3 to provide that for LARS projects the Transmission 
Provider shall provide the Interconnection Customer and Transmission Owner a final LLGIA 
within 15 Business Days after completion of the negotiation period in accordance with Section 
11.2.  These revisions also provide that the parties must execute the LLGIA or request to file 
unexecuted within 15 Business Days of tender of the final LLGIA, otherwise the project will be 
deemed to have withdrawn its Interconnection Request.  These revisions are required to properly 
document the shorter timeline for LARS projects as compared to the timeline for DPP GIA 
execution as memorialized in this Section. 
The proposed revisions of Section 11.4 simply expand the requirements related to the 
commencement of interconnection activities to LLGIAs.  
B. 
Attachment X – Appendix 1 (Interconnection Request for a Generating 
Facility) 
 
MISO is proposing to revise this Appendix to integrate the LARS framework into the 
interconnection request form.  These revisions include adding new options for interconnection 
requests and interconnection service to accommodate LARS, confirm that the amount of 
Interconnection Service cannot exceed 150% of the total amount of its LARS Associated Load, to 
describe the requirements for LARS Associated Load and facilities to connect to the Transmission 
System, along with System Protection Facilities or operating procedures to prevent injections onto

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 39 
 
 
 
the Transmission System beyond the substation and voltage level where the Resource is located, 
and to describe requirements for the disclosure of additional information for MISO to evaluate the 
request.  The specific changes are: 
 
• Section 1: MISO has added a new section requiring information for the LARS 
Application.  
 
• Section 2: MISO has added a new check box for a Generating Facility to indicate the 
Interconnection Request is for processing through the Large Load Addition Resource 
Study process. 
 
• Section 4: MISO has added a new address or location section for the LARS Associated 
Load to fill out.  
 
MISO has also added a new row for NRIS Service requested for processing through LARS 
to the table of required information by type of service requested.  This row requires the 
Interconnection Customer to indicate the MW/MVAR of the request and states that the amount of 
NRIS shall not be less than 200 MW and not exceed 150% of the LARS Associated Load’s peak 
demand expected over any one-hour period, including the load MW amount and the percentage.   
 
MISO added a new sub-section (e) for LARS Interconnection Requests anticipated Service 
Commencement for the LARS Associated Load by day, month, and year.  A new contact section 
was added for the LARS Associated Transmission Customer and the LARS Associated Load 
contact.  
 
MISO added a new sub-section (h) requiring an agreement executed by the Interconnection 
Customer and the entity that owns or controls the LARS Associated Load meeting the requirements 
of Section 3.12.2 of the Generator Interconnection Procedures.  
 
In sub-section (i), MISO added new information requirements including the POI MTEP 
substation bus number, the LRZ of the POI, and the attestation required by Section 3.12.1 of the 
Generator Interconnection Procedures.  
 
MISO added a new sub-section (t), requiring the identification of the LARS Associated 
Large Load POW, the LRZ the POW is located in, and amount of Transmission Service Requested 
for the LARS Associated Load.  
 
• Attachment A-5: MISO has added a new paragraph below the dynamic modelling 
information required for other types of Interconnection Requests to require to require 
Interconnection Customers participating LARS to provide a detailed power flow model 
that includes the LARS Associated Load, its Point of Withdrawal, and the POI for the 
Interconnection Request, as well as system protection facilities.  This provides necessary 
information for MISO to study the Interconnection Request.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 40 
 
 
 
• Attachment A-6: MISO has added a paragraph requiring that all inverter-based generators 
must comply with all modeling requirements specified in BPM-015 and that all LARS 
inverter-based generators must comply with the modeling requirements specified in BPM-
015 Appendix I.  
MISO submits that these requirements are just, reasonable, and necessary to the 
performance of LARS process given the formal pairing of the Generating Facility and LARS 
Associated Load to this new type of study process.   
D. 
Attachment X – Appendix 6 (Generator Interconnection Agreement) 
MISO is proposing to revise this Attachment to require contractual commitments 
associated with the LARS Associated Load.  
1. Revisions to Recitals  
MISO proposes a new fifth recital for use in the LLGIA that explains that the output of the 
Generating Facility will be used to serve the LARS Associated Load.  Including this recital 
provides clarity about what the LLGIA does at the front of the document.96   
2. Revisions to Article 1—Definitions 
MISO proposes to include the same new and revised definitions in the LLGIA that are 
proposed for inclusion in the GIP.   The proposed terms and definition language are identical to 
those described above for GIP revisions except for non-substantive edits needed to reflect the 
location of the definition in the LLGIA rather than the GIP.97  MISO refers to its discussion above 
and asks that the Commission accept the definition changes as just and reasonable for the reasons 
explained in the discussion of these changes.  
MISO also added the following definition for the LARS study process to indicate the point 
in the system where the LARS Associated Load is connected: 
Point(s) of Withdrawal (POW) shall mean the point(s) where a non-transmission facility 
that is used to withdraw Energy from the Transmission System to serve Load connects to 
the Transmission System.98 
MISO proposes this definition in order create a load equivalent to the existing defined term, Point 
of Interconnection, which is used to describe the point at which the Interconnection Facilities 
 
96  When merged with Appendix 6, MISO would include this recital in brackets indicating it is to be used only for 
LLGIAs. 
97  These changes consists of revising “these GIP” to “the GIP” in Appendix 19 in order to avoid confusion.  The 
change is not intended to be substantive.  
98  MISO proposed this defined term as part of its ZGIA filing.  While the definition remains pending, MISO proposes 
it again here because LARS utilizes this concept and is being built from Attachment X, Appendix 6 rather than 
Appendix 19 where the pending definition is included.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 41 
 
 
 
connect to the Transmission System.  Because the relative location and configuration of Load with 
respect to the Generating Facility and to the Transmission System is a critical component LARS, 
vocabulary is needed to discuss the point where the LARS Associated Load connects to the 
Transmission System in reference to the Point of Interconnection.  The term “Point(s) of 
Withdrawal” provides a delineation between the two points that facilitates clearer Tariff rules.  
3. Revisions to Article 2.3—Termination Procedures 
MISO proposes revising Article 2.3.1 describing the conditions under which a LLGIA will 
be terminated by the Transmission Provider. The proposed revisions are as follows: 
This LLGIA shall be terminated by Transmission Provider after giving 
Interconnection Customer ninety (90) Calendar Days advance written notice if:   
 
 
(1) the LARS Associated Load or a portion of the LARS Associated Load fails to 
achieve a Service Commencement Date for Transmission Service by the 
Commercial Operation Date for this Generating Facility, including any extension 
provided thereunder; or   
 
(2) within the first fifteen (15) Calendar Years after the LARS Associated Load 
commences use of the Transmission Service granted through LARS, the LARS 
Associated Load or a portion of the LARS Associated Load has ceased use of 
Transmission Service granted through LARS for a period of one year beginning 
with the last date of use of such Transmission Service; or   
 
(3) within the first fifteen (15) Calendar Years after the LARS Associated Load 
commences use of the Transmission Service granted through LARS the agreement 
required by GIP Section 3.12.2.i is terminated or otherwise ceases to be in effect 
except that a replacement agreement that satisfies the requirements of GIP Section 
3.12.2.i involving the same Generating Facility and LARS Associated Load. 
 
 
In the event that the LARS Associated Load ceases use of its Transmission Service 
or the agreement required by Section 3.12.2.i terminates within the first fifteen (15) 
Calendar Years after the LARS Associated Load commences use of the 
Transmission Service granted through LARS, this Agreement shall be terminated 
one year after the date of such occurrence.  During such one year period the 
Generating Facility shall be allowed to operate subject to the Annual ERIS 
(“AERIS”) and the Quarterly Operating Limit (“QOL”) processes as specified in 
BPM-015 Section 6.6 in order to allow the Interconnection Customer to obtain new 
Interconnection Service pursuant to the GIP.  If the DPP processing is delayed 
beyond one year due to factors beyond the Interconnection Customer’s control, then 
this LLGIA shall be extended until the relevant DPP studies are completed provided 
Interconnection Customer’ Interconnection Request is not withdrawn. 
 
 
Where: (1) the LARS Associated Load fails to commence service for the full 
amount of Transmission Service requested in the LARS Application by the

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 42 
 
 
 
Commercial Operation Date for this Generating Facility, including any extension 
provided thereunder; (2) ceases use of such full output within the first fifteen (15) 
Calendar Years after the LARS Associated Load commences use of the 
Transmission Service granted through LARS for a period of one year beginning 
with the last date of use of such Transmission Service; or (3) the parties to the 
agreement required by Section 3.12.2.i reduce the MW output from the Generating 
Facility that the LARS Associated Load intends to utilize within the first fifteen 
(15) Calendar Years after the LARS Associated Load commences use of the 
Transmission Service granted through LARS, Transmission Provider shall only 
terminate the portion of the Interconnection Service granted under this LLGIA that 
exceeds 150% of the reduced peak Demand being utilized by the LARS Associated 
Load. 
 
 
Following the first fifteen (15) Calendar Years after a LARS Associated Load 
ceases use of its Transmission Service or if the agreement required by GIP Section 
3.12.2.i is terminated or otherwise ceases to be in effect, then Transmission 
Provider shall not terminate the Generating Facility’s Interconnection Service.  
 
This proposed section lays out the instances where a LLGIA will be terminated, which includes 
when the LARS Associated Load (or some portion thereof) fails to achieve a service commence 
date by the COD of the Generating Facility, when LARS Associated Load has ceased use of the 
transmission service granted through LARS for a period of one year, or when the required executed 
agreement under GIP Section 3.12.2.i is terminated.   
The second paragraph goes into additional detail regarding what happens when the LARS 
Associated Load no longer operates.  The Generating Facility’s LLGIA is not immediately 
terminated but it is granted up to one year to acquire new Interconnection Service.  During that 
year, the Generating Facility must operate subject to MISO’s AERIS and QOL processes as 
specified in the BPM.  
MISO refers the Commission to its discussion of parallel language in GIP Section 3.12.7.4 
as described in this transmittal letter, for additional explanation of why this language is just and 
reasonable.99   
The third paragraph addresses the situation where the LARS Associated Load changes its 
amount of Transmission Service to a lower amount than was originally requested in the LARS 
Application.  In that circumstance, MISO will only terminate (or amend) the portion of the 
Interconnection Service granted by the LLGIA that exceeds 150% of reduced peak demand being 
utilized by the LARS Associated Load.  This will ensure that the generation remains paired with 
the load and results in an amended LLGIA for the Generating Facility.  
 
99  See discussion regarding Attachment X, Section 3.12.7.4, supra at pp. 34-36.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 43 
 
 
 
MISO is also revising Article 2.3.3 to state that LARS projects must provide all security 
required in Section 2.4 prior to any termination request for a LARS project becoming effective.  
The proposed language is as follows: 
For LLGIAs, all security as required by Section 2.4 shall be provided prior to 
termination.   
 
For LLGIAs, any termination or withdrawal of the LARS Application from LARS 
or any cessation of operations or discontinuation of Transmission Service by the 
LARS Associated Load shall be an event of default pursuant to Article 17 of this 
LLGIA.  
 
This language is necessary to ensure that projects are held liable for any Network Upgrades that 
would be memorialized in an LLGIA or related agreement and to prevent harm to other projects 
due to the withdrawal. 
MISO is proposing to revise Article 2.4 to specify that should a LARS project terminate, it 
will be liable for any Network Upgrade costs identified in the LLGIA or that would be 
memorialized in an FCA, MPFCA, or JTIQ Service Agreement.  The proposed language is as 
follows: 
In the event that this LLGIA is terminated by Interconnection Customer, Interconnection 
Customer is responsible for the full cost of all Network Upgrades that are designated as 
GIP projects and are identified in this LLGIA as well as any GIP Network Upgrades 
identified during the LARS process that are to be memorialized in an agreement other than 
this LLGIA, including any applicable FCA, MPFCA, or JTIQ Service Agreements.  If the 
Network Upgrade costs for Network Upgrades subject to an FCA, MPFCA, or JTIQ 
Service Agreement have not been finalized or the Interconnection Customer has not made 
the payment under such agreement as of the date that termination of this LLGIA is sought, 
Interconnection Customer shall provide the payment or security for such Network 
Upgrades in the amount required by the applicable agreement.  If such agreement has not 
been executed and final costs are not available as of a date that termination is sought, 
Interconnection Customer shall provide such payment or security in an amount 
corresponding to the most recent estimate provided by the Transmission Provider during 
the LARS process.  Interconnection Customer shall pay or Transmission Provider shall 
refund, as applicable, to Interconnection Customer the difference between the amount of 
any estimated payment or security made pursuant to this Article and the final cost of such 
Network Upgrade within ninety (90) Calendar Days after such final costs are invoiced to 
the Interconnection Customer. 
 
These additions are necessary to establish that if the final costs have not been determined, the 
Customer must provide security according to the most recent estimate.  Additionally, the 
Transmission Provider will provide any applicable refunds of payments or security within 90 
Calendar Days of providing the final invoice of NUs to the Customer.  As stated above, the

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 44 
 
 
 
proposed language is necessary to ensure that only “shovel ready” projects submit to LARS, 
knowing those projects will assume the risk of paying for any Network Upgrades identified in an 
LLGIA or that would be memorialized in an FCA, MPFCA, or JTIQ Service Agreement.  This 
language will ensure that no other projects are affected by the termination. 
4. Revisions to Article 4.1—Interconnection Product Options 
MISO also proposes adding a check box in Article 4.1 to indicate whether the LLGIA has 
been processed through the LARS Study Process.  The option indicates that ER and NR are the 
only options.  
5. Revisions to Article 9.7.4.7—Operations under an LLGIA prior to Service 
Commencement Date 
 
 
MISO proposes to add new article 9.7.4.7 establishing the obligation of a 
Generating Facility with an LLIGA prior to service commencement date.  The proposed revisions 
are as follows: 
If this GIA is an LLGIA, Interconnection Customer shall not commence Commercial 
Operation or otherwise inject electricity onto the Transmission System prior to the Service 
Commencement Date of the LARS Associated Load except for injections associated with 
testing otherwise allowed by this LLGIA.  In the event that the LARS Associated Load 
commences service for an amount of Transmission Service less than the amount requested 
in the LARS Application, Interconnection Customer’s injections shall be subject to the 
Annual ERIS Evaluation Study and Quarterly Operating Limits processes as described in 
Section 6.6 of the Generator Interconnection Business Practices Manual and may be limited 
to the current Demand of the LARS Associated Load until such time as the LARS 
Associated Load has commenced service. 
These provisions allow the Generating Facility to operate even when the LARS Associated Load 
has commenced service for lower than the total amount identified in the LARS Application.  This 
situation will likely occur when the LARS Associated Load is being phased in over time.  These 
provisions will allow the Generating Facility to begin providing service to the load but subject to 
the Annual ERIS Evaluation Study and Quarterly Operating Limits processes as described in 
Section 6.6 of the Generator Interconnection Business Practices Manual.  The provisions also 
explain that the Generating Facility’s output may be limited to the current Demand of the LARS 
Associated Load until such time as the LARS Associated Load has fully commenced 
service.  These revisions are a just and reasonable approach to addressing timing mismatches that 
can occur in practice between when the Generating Facility and LARS Associated Load enter 
service, which may occur where the LARS Associated Load is delayed or comes online in phases.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 45 
 
 
 
6. Revisions to Appendices  
MISO proposes several revisions to Appendix A in order to implement the LARS process.   
First, MISO proposes to include a new Section 2 that includes a description of the LARS 
Associated Load, identifying the MW, Point(s) of Withdrawal and need by date of the ZG 
Associated Load.  This section requires a single line diagram illustrating the connections between 
the Generating Facility, ZG Associated Load, and the Transmission System and the identification 
of the equipment and configurations that prevent injections outside of the Transient Tolerance 
Window.   
This section reflects the technical requirements applicable to a LARS Associated Load 
participating in LARS and makes the studied equipment and configuration a part of the LLGIA 
that can be enforced.  This requirement works with MISO’s material modification rules in the same 
way that section 1 operates to ensure that changes to the configuration of the AG Associated Load 
that could affect the impacts of the ZG Interconnection Service as studied are subject to the same 
modification rules applicable to the Generating Facility under Section 1 of Appendix A.  This is 
necessary and appropriate given the importance of these configuration details to the completion of 
the LARS process. 
MISO also proposes revisions to Appendix B, the revisions are made to milestone 1f to 
include LARS in the agreement requirement for an Affected System study process pursuant to GIP 
Section 3.5.4.  
E. 
Attachment FF (Transmission Expansion Planning Protocol)   
MISO is proposing to add a new sub-section (ii) to Section I.D.1.b of Attachment FF to 
implement the requirements of the LARS process reflected in Attachment X but for the LARS 
Associated Transmission Customer.  MISO included relevant explanations of the Interconnection 
Customer’s responsibilities in this new proposed section to ensure alignment with new revisions 
to Attachment X to implement LARS.   
The reasoning for the new provisions proposed in Section I.D.1.b.ii.(a) for the LARS Pre-
Submission Coordination Process are the same as the previously described Sections 3.12.1 of 
Attachment X.  
MISO added a new section to address the LARS Application Timing and Deposits for the 
load study.  The proposed revisions are as follows: 
The LARS Associated Transmission Customer is responsible for submitting the 
LARS Application. Both the Transmission Owner supporting the LARS 
Application and requesting to join LARS shall submit the required Large Load 
information to the MTEP Portal and an Interconnection Customer supporting the 
LARS Application and requesting to join LARS shall submit their Interconnection 
Request with the LARS Associated Transmission Customer to the Transmission

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 46 
 
 
 
Provider no later than the LARS Application deadline as published on the MISO 
public website, at least twenty (20) Business Days prior to the scheduled kick-off 
of the LARS study period published on the MISO public website and as described 
in Section 3.12 of Attachment X. A valid LARS Interconnection Request shall be 
included in the next available LARS study period that commences after such 
request is submitted.  
 
A LARS Application shall be accompanied by a Non-Refundable Deposit 1 (D1) 
of $250,000 submitted by the LARS Associated Transmission Customer. Additional 
LARS Study Deposits such as D2 as described in Section 3.3.1 of Attachment X 
apply to the LARS Application and shall be submitted by the Interconnection 
Customer. All applicable deposits, milestone payments and data required to enter 
the Large Load Addition Resource Study must be received at the time the LARS 
Application is submitted. 
 
The purpose of this section is to align the timing of the LARS generation study with the load study. 
The second paragraph also identifies which parties are responsible to pay which deposits.  
Section I.D.1.b.ii.(c) includes the proposed LARS Application requirements for the load 
study and identifies what information must be provided to MISO.  This section closely aligns with 
the existing information requirements of the EPR process.  Otherwise, the remaining proposed 
requirements match those included in Section 3.12.2 of Attachment X and were previously 
explained in the Attachment X section.  
The new provisions of Sections I.D.1.b.ii.(d) describe and implement the same evaluation 
process for LARS Applicants as those previously described in Sections 3.12.3 of Attachment X.   
The new provisions of Sections I.D.1.b.ii.(e) describe and implement the LARS cure and 
deficiency periods as described in Section 3.3.3 of Attachment X.  The proposed revisions to 
Attachment FF are as follows: 
A LARS Application will not be considered valid until all items in Section 3.12 of 
Attachment X and Section I.D.1.b.ii of Attachment FF, have been received by 
Transmission Provider. If the LARS Application fails to meet the requirements, 
Transmission Provider shall notify the Transmission Customer within fifteen (15) 
Business Days of receipt of the LARS Application either that the Transmission 
Provider has accepted the Application as valid or has determined that the 
Application is not valid due to one or more deficiencies. In the event Transmission 
Provider determines that the Application does not meet all the requirements and 
thus is not valid, Transmission Provider shall also provide an explanation of the 
reasons for such determination. The Transmission Customer shall have ten (10) 
Business Days from the date that the Transmission Provider identifies the 
Application as deficient to provide the additional requested information needed to 
constitute a valid request. The requirements of Section 3.3.3 of Attachment X apply 
to LARS Applications. The Transmission Provider will have one period of review

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 47 
 
 
 
to identify deficiencies and the entities identified in the LARS Application shall 
have one cure period to address deficiencies.  
 
This section was necessary to add to Attachment FF because the LARS Application must contain 
the information required by Section I.D.1.b.ii.(c).  MISO clarified in both Attachment X and in 
Attachment FF that it will have one single review period to identify any deficiencies in the LARS 
Application and the applicants will have one single cure period to address those deficiencies.  That 
is necessary to ensure that LARS process only lasts approximately 120 days. MISO cannot be 
delayed by numerous deficiency and cure periods.  
The new provisions of Sections I.D.1.b.ii.(f) describe and implement the refund process 
for the LARS study. Any difference between the study deposit and the actual cost of the study will 
be paid by or refunded to the Interconnection Customer.  
The new provisions of Sections I.D.1.b.ii.(g)-(i) first describe and implement the 
responsibilities of the Interconnection Customer or the LARS Associated Transmission Customer 
depending on whether the load or the generation withdraws from LARS after the LLGIA is 
executed.  The section states that the parties will remain responsible for the costs identified in the 
LLGIA if the project is withdrawn depending on which party caused the withdrawal.  The new 
provisions in sub-section (h) clearly state that no modifications of the LARS Application are 
permitted following its submission.  This is to ensure that MISO may complete the necessary 
studies in order to provide MTEP approval and a LLGIA on the approximate 120-day timeline 
required by LARS.  Finally, the new provisions in sub-section (i) assign the costs of any necessary 
mitigations developed to address violations observed in the following instances: 1) violations 
observed only in the transmission studies to study the impact of the load; 2) violations observed in 
both the load and generation studies; and 3) violations observed in only the generation study.  
Mitigation costs are then assigned to either the Interconnection Customer or the LARS Associated 
Transmission Customer depending on which instance applies.  
The new provisions of Section I.D.1.b.ii.(j) addresses consideration of including generating 
facilities in the LARS study process. The proposed revisions are as follows: 
In accordance with the LARS definitions, Section 3.3.1, and Section 3.12 of 
Attachment X, and notwithstanding the requirements of Section I.D.1.b.ii, a 
generating solution that does not yet have generator interconnection agreement 
filed with the Commission pursuant to Attachment X of this Tariff may be 
considered as an alternative transmission solution if: (1) a valid Interconnection 
Request for such Generating Facility has been submitted for processing under the 
LARS process specified by Attachment X to the Tariff; and (2) the Transmission 
Provider has received an executed agreement between the LARS Interconnection 
Customer, the entity(ies) with the LARS Associated Load with a minimum of 200 
MW, and the LARS Associated Transmission Customer that satisfies the 
requirements of Attachment X, Section 3.12.2(i) with a minimum term of at least 
five years to align with MISO’s transmission planning horizon to ensure the ability 
to provide adequate lead time for an alternative transmission solution should the

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 48 
 
 
 
agreements terminate.  The study will be performed for each LARS Associated 
Load, including the Interconnection Request, capturing the cumulative impact 
based on their submission date per LARS Study Period. The outcome of the LARS 
Associated Load study is MTEP approval of the load and associated optimized 
network upgrades.  
 
In the event that the Load In-Service Date is prior to the date on which the proposed 
LARS Resource achieves Commercial Operations, the Transmission Provider may 
either; (1) require the applicable Load Serving Entity to delay the in-service date of 
the LARS Associated Load until such time as an alternative solution can be placed 
in service or the Generating Facilities achieve(s) Commercial Operation in 
accordance with Section I.D.1.b.ii of this Attachment; or (2) impose operational 
limitations on the LARS Associated Load that the Transmission Provider 
determines are reasonably necessary to maintain the reliability of the Transmission 
System until such time as the Generating Facility achieves Commercial Operation 
or an alternative solution is placed into service. 
 
There will be no restudies if a load withdraws from the LARS process.  
 
These provisions describe situations where a generating solution does not yet have a GIA on file 
with the Commission and indicates that it may be considered as an alternative transmission 
solution in the LARS load study if: (1) a valid Interconnection Request for such Generating Facility 
has been submitted for processing under the LARS process specified by Attachment X to the Tariff; 
and (2) the Transmission Provider has received an executed agreement between the LARS 
Interconnection Customer, the entity(ies) with the LARS Associated Load with a minimum of 200 
MW, and the LARS Associated Transmission Customer that satisfies the requirements of 
Attachment X, Section 3.12.2(i). The provisions also explain that if the LARS Associated Load’s 
in-service date is prior to the COD of the Generating Facility, then MISO can: 1) require the LSE 
to delay the in-service date of the LARS Associated Load until such time as an alternative solution 
can be placed in service or the Generating Facilities achieve(s) COD in accordance with Section 
I.D.1.b.ii of this Attachment; or (2) impose operational limitations on the LARS Associated Load 
that MISO deems are reasonably necessary to maintain the reliability of the Transmission System 
until such time as the Generating Facility achieves Commercial Operation or an alternative 
solution is placed into service. 
Finally, the new provisions added in Section I.D.1.b.ii.(j) state that MISO will not complete 
any restudies if a LARS Associated Load withdraws from the LARS process. This is to ensure that 
the integrity and swiftness of the LARS process is maintained.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 49 
 
 
 
V. 
THE LARS STAKEHOLDER PROCESS 
 
MISO developed LARS through an iterative stakeholder process focused on the 
relationship between significant new load, associated generation, and the need to maintain system 
reliability.  The LLWG itself is charged with addressing large-load issues across markets, reliable 
operations, planning, and resource adequacy.100  Stakeholders first raised the need to coordinate 
large load and generator interconnection studies through MISO’s issue process.101  In early January 
2026, MISO convened a Large Load Additions Workshop where it presented its forecast of large 
load additions, which showed large load additions escalating sharply over the next several years, 
driven primarily by data centers, and noted that federal policy supporting artificial intelligence was 
accelerating near-term growth.102  
 
Large loads continued to be a significant topic of conversation in all of MISO’s stakeholder 
meetings.  To provide a dedicated forum for large load matters, MISO’s Steering Committee 
approved a charter for the Large Load Working Group.103  The LLWG reports to MISO’s Advisory 
Committee and is chartered to provide input and policy guidance to MISO Management and the 
Advisory Committee on market, reliability, planning, and resource adequacy matters related to the 
integration of large loads within the MISO footprint.  The LLWG held its first meeting on April 
20, 2026.104  In its first several meetings, the LLWG took up the large load interconnection 
reliability requirements (LLWG-2026 3), reserve product enhancements for large load (LLWG-
2026-2), Firm Service Step Up for large load interconnections (LLWG-2026-1), and the ZGIA 
(PAC-2024-4B), each of which forms part of the broader large load framework within which LARS 
was developed.105 
 
On June 18, 2026, the Commission issued an order directing MISO to show cause why its 
Tariff remains just and reasonable without provisions tailored to large loads, or to propose Tariff 
 
100  MISO, LLWG Charter at 1, supra note 20. 
101  On January 29, 2025, Clean Grid Alliance (“CGA”) presented Issue PAC-2024-7, Sharing and Coordinating 
MTEP and DPP to Accommodate Large Load, to the PSC. Coordinating Large Load and Generator 
Interconnection 
(PAC-2024-7), 
PLANNING 
SUBCOMMITTEE 
(Jan. 
29, 
2025), 
available 
at:   
https://cdn.misoenergy.org/20250129%20PSC%20Item%2007%20Sharing%20and%20C 
oordinating%20MTEP%20and%20DPP%20to%20Accomodate%20Large%20Load%20( 
PAC-2024-
7)674624.pdf.  
102  Large Load Additions Workshop, MIDCONTINENT INDEP. SYS. OPERATOR (Jan. 30, 2026), available at: 
https://cdn.misoenergy.org/20260130%20Large%20Load%20Workshop%20Presentation 738349.pdf.  
103  See LLWG Charter, supra note 20. 
104  See MISO, LLWG (Apr. 20, 2026available at: https://www.misoenergy.org/events/2026/large-load-working 
group-llwg---april-20-2026/; Large Load Working Group (LLWG), MIDCONTINENT INDEP. SYS. 
OPERATOR, available at: https://www.misoenergy.org/engage/committees/large-load-working-group/. 
105  Minutes, 
LARGE 
LOAD 
WORKING 
GROUP 
(June 
10, 
2026), 
available 
at: 
https://cdn.misoenergy.org/20260629%20LLWG%20Item%2001c%20Minutes%202026 
0610764681.pdf 
(“LLWG June 10 Minutes”); see also Liaison Report, LARGE LOAD WORKING GROUP at 3-10 (Sept. 9,

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 50 
 
 
 
revisions.106  MISO held a special Steering Committee meeting on July 7, 2026, where it 
determined that the LLWG would be the forum for continued discussion of the large load issues 
that had been proceeding at the PAC, including the ZGIA and the Large Load Definition.107  In its 
liaison report at the July 16, 2026 LLWG meeting, MISO described the three core objectives of its 
large load framework: to “[c]onnect within 120 days with all studies completed and GIAs signed,” 
to “[t]ransition and scale with flexible options consistent with timing of network upgrade 
buildouts,” and to “[s]ustain reliable operations with ability to withdraw or inject energy based on 
conditions and signals.”108 
 
At the July 16, 2026, LLWG meeting, MISO first introduced the LARS proposal as a new 
issue and titled it the Generation and Large Load Alignment proposal.  MISO sought stakeholder 
input concerning the eligibility and design of a process for studying new large loads and their 
associated generation.109  MISO specifically asked stakeholders whether a minimum threshold of 
250 MW appropriately captured high-impact loads and, if not, what alternative threshold would 
better capture those loads without diluting the purpose of the process.110  MISO asked for written 
feedback by July 30, 2026, asking stakeholders in particular whether 250 MW was the right 
threshold, what readiness and securitization rules should apply to prevent speculative requests, and 
what other improvements were needed, and outlined its next steps as review of draft Tariff 
language at the August 27, 2026 LLWG meeting and a Tariff filing in September 2026.111 
 
MISO continued to refine the proposal following that feedback.  At the August 27, 2026 
LLWG meeting, MISO formally presented LARS as a process for concurrently studying Large 
Loads and associated generation and circulated draft Tariff language for stakeholder review.112  
MISO summarized the outcomes of the process as an allocation of Interconnection Service to the 
generator, transmission service for reliable withdrawal by the load, and optimized Network 
 
2026), available at: https://cdn.misoenergy.org/20260909%20LLWG%20Item%2003%20Liaison%20Report 
779834.pdf. 
106   Show Cause Order at P 122 (directing MISO to submit, within 30 days, an informational report on proposals 
under consideration in its stakeholder process to address resource adequacy for new large loads, with a schedule 
of key milestones and anticipated filing dates). 
107  Liaison 
Report, 
LARGE 
LOAD 
WORKING 
GROUP 
at 
8 
(July 
16, 
2026), 
available 
at: 
https://cdn.misoenergy.org/20260716%20LLWG%20Item%2004%20Liaison%20Report 768708.pdf (“LLWG 
July 2026 Liaison Report”); Minutes, LARGE LOAD WORKING GROUP at 4 (July 16, 2026), available at: 
https://cdn.misoenergy.org/20260812%20LLWG%20Item%2001c%20Minutes%202026 0716771087.pdf. 
108  LLWG July 2026 Liaison Report at 4.  
109  MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6 (July 16, 2026). 
110  MISO, LLWG, Generation and Large Load Alignment, LLWG-2026-6, Stakeholder Feedback (July 30–31, 2026) 
(requesting feedback on whether “≥250 MW” was the appropriate minimum and what alternative threshold would 
capture high-impact loads without diluting the proposal’s intent). 
111  Generation and Large Load Alignment (LLWG-2026-6), LARGE LOAD WORKING GROUP (July 16, 2026), 
available 
at: 
https://cdn.misoenergy.org/20260716%20LLWG%20Item%2006b%20Generation%20an 
d%20Load%20Alignment%20Presentation768740.pdf (“LLWG July 2026 Presentation”). 
112   MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6 (Aug.  27, 2026).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 51 
 
 
 
Upgrades, and stated that the study process and GIA would together be completed in 120 calendar 
days.113 MISO also posted draft Tariff language implementing LARS and requested that 
stakeholders provide feedback on the proposed Tariff redlines and identify any additional process 
clarifications needed through the Stakeholder Feedback Tool by September 10, 2026.114 
 
As a result of stakeholder feedback, MISO changed the LARS process minimum Large 
Load value to be 200 MW instead of 250 MW.  Stakeholders proposed a range of approaches to 
the threshold.  The July LLWG stakeholder record includes a recommendation to reduce the 
minimum threshold from 250 MW to 200 MW to capture projects sufficiently large to warrant 
coordinated load-generation evaluation while maintaining the proposal’s focus on projects with 
significant system impacts.115  Other stakeholders supported retaining a minimum-MW 
mechanism to limit the process to high-impact large loads.116  MISO made this change based on 
significant stakeholder feedback that many emerging data center and large industrial projects in 
the 200-250 MW range can have significant system impacts and would benefit from the 
coordinated study process. Lowering the threshold also allows access to the LARS framework 
while maintaining its focus on large, impactful load additions.  The 200 MW minimum threshold 
strikes the right balance between different kinds of large load and hyperscalers.  
 
At the September 23, 2026, LLWG meeting, MISO presented the final proposed LARS 
process and updated tariff language for Attachement FF, Attachment X and associated Appendices 
in response to the September 10th feedback.  MISO explained that it had changed the minimum 
threshold LARS Associated Load size to 200 MW (from the proposed 250 MW), allowed multiple 
Generating Facilities to group at different POIs for one LARS Associated Load, and added a new 
contract agreement option for LSEs.  MISO also clarified several of the requirements of the LARS 
process including addressing the concerns on representation of the LARS generator/load pair 
within the parallel study processes.117  
 
The stakeholder process also addressed the relationship between the load and generation, 
project-readiness requirements, study assumptions, and the interaction between LARS and the 
existing Generator Interconnection Queue.118  The resulting LARS proposal reflects MISO’s effort 
 
113  Large Load Addition Resource Study (LLWG-2026-6), LARGE LOAD WORKING GROUP at 7-10 (Aug. 27, 
2026), available at: https://cdn.misoenergy.org/20260827%20LLWG%20Item%2007%20Load%20Addition 
%20Resource%20Study%20(LLWG-2026-6)777236.pdf (“LARS August 2026 Presentation”). 
114  LARS August 2026 Presentation at 16.  
115  Id. 
116  Id. (including OMS Work Groups feedback supporting a minimum-MW mechanism that limits the proposal to 
high-impact large loads). 
117  See MISO, LLWG, Large Load Addition Resource Study (LLWG-2026-6), (Sep. 23, 2026), available at: 
https://cdn.misoenergy.org/20260923%20LLWG%20Item%2006%20Large%20Load%20Addition%20Resourc
e%20Study%20(LLWG-2026-6)782864.pdf.  
118  MISO, LLWG, Large Load Addition Resource Study, LLWG-2026-6, Stakeholder Feedback (Sept.  2026) 
(reflecting stakeholder comments concerning project readiness, the relationship between associated load and 
generation, study models, and the interaction between LARS and the existing Generator Interconnection Queue).

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 52 
 
 
 
to establish a targeted process for significant new load additions while coordinating the study of 
associated generation.  The 200 MW threshold maintains LARS’s focus on substantial load 
additions while broadening eligibility beyond hyperscale projects exceeding 250 MW to include 
projects involving larger manufacturing and industrial processes.  MISO worked closely with 
stakeholders to ensure that it considered and incorporated certain elements of feedback.   
 
 
MISO submits that the Tariff revisions proposed in this filing establish a just, reasonable, 
and not unduly discriminatory mechanism for rapidly integrated large loads with paired generation.  
The Tariff revisions are limited in scope and in impact but offer significant benefits in terms of 
improving the coordination between load and generation studies to reflect the joint impact of both 
the generation and the load it will serve, and avoiding negative impacts to other MISO processes 
and the stakeholders who participate in them.  As proposed, LARS is both a powerful tool for 
responding to urgent industry needs as well as a tailored solution with safeguards sufficient to 
guard against overuse of the process.  The benefits of LARS are not free.  Both the Interconnection 
Customer and LARS Associated Transmission Customer are required to undertake commitments 
that exceed those imposed on Interconnection Customers in the DPP.  These additional 
commitments and risk are necessary to provide the certainty that allows LARS to move at an 
expedited pace without negative impacts to other processes.  The LARS process is open to all 
Interconnection Customers that meet the Tariff’s requirements and that are willing to accept the 
greater commitments and limitations imposed by LARS. 
VI. 
DOCUMENTS SUBMITTED IN THIS FILING 
In addition to this Transmittal Letter, this submission includes: 
Tab A – Redline Tariff;119 
Tab B – Clean Tariff; and  
Tab C – Prepared Direct Testimony of Christina Drake. 
 
119  Language currently pending before the Commission in the following docket and is highlighted in yellow: ER24-
2046-003, ER26-3552-000, ER26-3777-000 and ER26-3813-000.  MISO requests that the Commission treat such 
highlighted language as subject to the outcome of this pending proceeding.  MISO commits to file any revisions 
to this highlighted language as necessary to comply with any Commission orders in this proceeding.  MISO has 
removed language that has a future effective date of 6/1/2029 and is pending in Docket No. ER22-1640-006.  
MISO has removed language that has a future effective date of 6/1/2028 and is pending in Docket No. ER26-
2825-000.  MISO has removed language from Attachment X, Appendix 6 – Generator Interconnection Agreement 
that has an effective date of 7/28/2025 and is pending in Docket No. ER24-2046-003.  MISO commits to make a 
subsequent filing with the Commission to reflect the most up-to-date versions of the then-current Tariff provisions 
prior to the effective date of the language accepted in Docket Nos. ER26-2825-000, ER24-2046-003, ER22-1640-
006.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 53 
 
 
 
VII. 
EFFECTIVE DATE 
MISO requests an effective date of December 2, 2026 for the Tariff revisions submitted 
herein, which is not less than 60 days nor more than 120 days, after the filing date.  MISO intends 
to open the first LARS Study Period in the first quarter of 2027.  Acceptance of LARS by the 
requested effective date is necessary to allow LARS to begin on this timeframe because the 
proposed rules require pre-submission coordination and for MISO to develop software to support 
the LARS Application prior to opening the first LARS Study Period.  This effective date will allow 
the revisions proposed herein to be effective in time for MISO and stakeholders to prepare for 
studies with certainty regarding the applicable rule set.    
VIII. 
COMMUNICATIONS 
MISO respectfully requests waiver of Rule 203(b)(3) of the Commission’s Rules of 
Practice and Procedure, 18 C.F.R. § 385.203(b)(3) (2026), to the extent necessary to permit the 
designation of more than two persons for service on behalf of MISO in this proceeding and requests 
all communications related to this filing be directed to: 
Christopher D. Supino* 
Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
Midcontinent Independent System 
Operator, Inc. 
720 City Center Drive  
Carmel, Indiana 46032  
Telephone: (317) 249-5400 
csupino@misoenergy.org 
mkessler@misoenergy.org 
 
James C. Holsclaw* 
Calfee, Halter & Griswold LLP 
3900 Salesforce Tower 
111 Monument Circle 
Indianapolis, Indiana 46204 
Telephone: (317) 308-4266 
jholsclaw@calfee.com  
 
IX. 
NOTICE AND SERVICE 
MISO has served a copy of this filing electronically upon all parties listed on the 
Commission’s eService list, and upon all Tariff customers, MISO Members, Member 
representatives of Transmission Owners and non-Transmission Owners, as well as all state 
commissions within the MISO Region and the Organization of MISO States.  The filing has been 
posted electronically on MISO’s website at https://www.misoenergy.org/legal/ferc-filings/ for 
other interested parties in this matter. 
X. 
CONCLUSION 
For all of the foregoing reasons, MISO respectfully requests that the Commission accept 
this filing and grant waiver of any Commission regulations the Commission deems applicable, but 
not specifically addressed above in order for the Commission to accept it as proposed.

The Honorable Debbie-Anne Reese 
October 2, 2026 
Page 54 
 
 
 
Respectfully submitted, 
 
/s/ Christopher D. Supino 
Christopher D. Supino 
Managing Senior Corporate Counsel 
Michael Kessler  
Managing Assistant General Counsel 
Midcontinent Independent System 
Operator, Inc. 
720 City Center Drive  
Carmel, Indiana 46032  
Telephone: (317) 249-5400 
csupino@misoenergy.org 
mkessler@misoenergy.org 
 
James C. Holsclaw 
Calfee, Halter & Griswold LLP 
3900 Salesforce Tower 
111 Monument Circle 
Indianapolis, Indiana 46204 
Telephone: (317) 308-4266 
jholsclaw@calfee.com   
 
Attorneys for the Midcontinent Independent 
System Operator, Inc.