Read topic-matched comments in ER27-25
Topics in the text: Connecting load and generation · Reliability and curtailment · Cost allocation
PDF p. 21
LARS projects will therefore be studied as if the only other generation on the system is generation that already holds a GIA. PDF p. 21Filed comments: Connecting load and generation
PDF p. 21
resulting in more constraints and higher Network Upgrade costs for DPP projects when they are finally studied against a system that LARS projects have already used. PDF p. 21Filed comments: Cost allocation
PDF p. 6
LARS is unduly discriminatory because it makes the LSE the gatekeeper of a Commission-jurisdictional generator interconnection process PDF p. 6Filed comments: Connecting load and generation
PDF p. 2
It is permanent and uncapped. It is untethered to any identified resource adequacy need. PDF p. 2Filed comments: Reliability and curtailment
PDF p. 27
LARS contains no scoring criteria, no carve-outs, no regulatory verification, no cap, and no sunset. PDF p. 27Filed comments: Connecting load and generation
PDF p. 14
LARS does the opposite: it grants permanent NRIS through a parallel process PDF p. 14Filed comments: Connecting load and generation
PDF p. 24
MISO has now twice prioritized separate, one-off expedited processes that not all market participants can feasibly access on a comparable, not unduly discriminatory basis PDF p. 24
PDF p. 29
MISO cannot satisfy the independent entity variation standard, and LARS does not accomplish the purposes of Order No. 2003 PDF p. 29Filed comments: Connecting load and generation
PDF p. 30
the Clean Energy Trades respectfully request that the Commission reject MISO's LARS proposal. PDF p. 30Filed comments: Connecting load and generation
PDF p. 30
the relevant location is the applicable POI to the MISO Transmission System rather than the physical location of the Generating Facility PDF p. 30
Midcontinent Independent System Operator · Direct response
MISO said the transmission customer submits an application for an already matched pair. It argued that an independent generator remains free to bring a proposal to that customer before the application, and that the eligibility rules are nondiscretionary.
PDF pp. 20–22Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Connecting load and generation
ER27-25-000 (Oct. 7, 2026). 2 members include independent power producers (“IPPs”) that develop generation to serve large loads and that would be directly affected by both the access rules LARS establishes and the effect of LARS on the transmission capacity and Network Upgrade costs available to…Read this passage Filed comments: Connecting load and generation
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I.Read this passage
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BACKGROUNDRead this passage
printed heading · Topic match: Reliability and curtailment
The accepted ERAS process is capped at 68 interconnection requests, with ten reserved for IPPs that have agreements with entities other than LSEs and eight reserved for requests serving retail- choice load; it requires verification by a Relevant Electric Retail Regulatory Authority (“RERRA”) of a…Read this passage Filed comments: Reliability and curtailment
printed heading · Topic match: Connecting load and generation
P 112. 5 obtains Energy Resource Interconnection Service (ERIS) or Network Resource Interconnection Service (NRIS).”15 Separately, the Commission directed MISO to file an informational report on proposals under consideration to address resource adequacy for new large loads.16Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
The LARS Proposal MISO proposes LARS as a new, permanent study process under which a large load of at least 200 megawatts (“MW”) and one or more new Generating Facilities are studied in parallel, with the generator receiving a Large Load Generator Interconnection Agreement (“LLGIA”) for NRIS in…Read this passage Filed comments: Connecting load and generation
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PROTEST Because MISO filed LARS under FPA section 205, MISO bears the burden of demonstrating that its proposal is just and reasonable and not unduly discriminatory or preferential.23 MISO has not carried that burden.Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
While it is reasonable for LSEs to initiate and oversee LARS requests on the load side, given state jurisdiction over retail service and LSEs’ obligations to serve load, that logic does not 36 See Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,682; Order No. 2003, 104 FERC ¶ 61,103 at P 827. 37…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
LARS studies “will not include Interconnection Requests currently in the generator interconnection queue that do not have an executed GIA.”84 LARS projects will therefore be studied as if the only other generation on the system is generation that already holds a GIA.Read this passage Filed comments: Connecting load and generation
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The Commission found that the initial, rejected MISO ERAS proposal did “not sufficiently describe how the ERAS process is sufficiently targeted to study only interconnection requests needed to meet the anticipated shortfall in generating capacity,” and that it was “difficult to determine whether…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
Operator, Inc., 185 FERC ¶ 61,084, at P 11 (2023)); see also ERAS Acceptance Order, 192 FERC ¶ 61,064 at P 259 (applying standard to ERAS). 114 See pro forma LGIP § 3.1. 115 Tab A, Attachment X, §§ 3.12.1, 3.12.2. 29 the basis of queue position and, following Order No. 2023, in clusters on a…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
Proposed Attachment X, Section 3.12.2 appears to apply the same-LRZ requirement based on the Generating Facility’s POI for an individual LARS Interconnection Customer, providing that “[t]he Point of Interconnection specified in a LARS Application must be located in the same Local Resource Zone as…Read this passage Filed comments: Connecting load and generation
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IV.Read this passage
printed heading · Topic match: Connecting load and generation
CONCLUSION For the reasons stated above, the Clean Energy Trades respectfully request that the Commission reject MISO’s LARS proposal.Read this passage Filed comments: Connecting load and generation
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Dated this 23rd day of October, 2026. /s/ Brett White Brett White Vice President, Markets & Transmission American Clean Power Association 1299 Pennsylvania Ave.Read this passage