ER27-25-000 · 2026-10-23 · Bloom Energy

Limited Protest of Bloom Energy Corporation

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
Midcontinent Independent System Operator, Inc.       )                            Docket No. ER27-25-000 
 
LIMITED PROTEST OF BLOOM ENERGY CORPORATION 
 
Pursuant to Rule 211 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 
385.211, Bloom Energy Corporation ("Bloom") submits this limited protest of the October 2, 
2026 filing by the Midcontinent Independent System Operator, Inc. ("MISO") to establish the 
Large Load Addition Resource Study ("LARS"). 
Bloom supports LARS and urges the Commission to accept it by MISO's requested 
December 2, 2026 effective date. LARS solves a real problem: today, load and generation studies 
run on different timelines, so each must wait on the other. By studying a large load and its paired 
generation in parallel, LARS removes that delay. It does so in a technology-neutral way, tying 
generation to load through a 150% cap. And it protects the Definitive Planning Phase (“DPP”) 
queue from speculative entry through serial ten-pair cycles, deposits, milestone payment, and 15-
year pairing requirement. Bloom protests one element only: the 200 MW minimum load size. 
I. 
Limited Protest 
MISO bears the burden under FPA section 205 to show that each element of its proposal 
is just and reasonable. Its only evidence of transmission system impact does not support a 200 
MW threshold. MISO initially proposed 250 MW, relying on Expedited Project Review (“EPR”) 
results showing that loads of 250 MW and above created "meaningful grid impacts," with 
upgrades "increasingly likely between 300–500 MW."1 MISO then lowered the threshold to 200 
MW, not on the basis of new analysis, but in response to stakeholder feedback that many projects 
 
1 Transmittal Letter at 3.

2 
 
in the 200–250 MW range "can have significant system impacts."2 MISO presents no EPR 
results or other grid impact study for 200 MW, and none for loads below it. The 200 MW 
threshold therefore rests on stakeholder assertion, not on transmission system data. The point is 
not that MISO should have kept 250 MW; it is that MISO set aside the only impact data it 
offered without replacing it. Nothing in the record shows that a 75 MW or 150 MW load paired 
with new generation presents a materially different study problem than a 200 MW load. 
The 200 MW threshold departs from the Commission's framework and MISO's own 
definition of Large Load. The Show Cause Order identified a reasonable large load definition as 
a single-site commercial or industrial customer with peak load of 50 MW or greater.3 MISO's 
pending Interconnection Reliability Requirement filing adopts this 50 MW threshold.4 MISO 
concedes the mismatch, noting that "not all 'Large Loads' will be eligible" for LARS,5 but offers 
no explanation for it. The Commission's concern with generation serving electrically proximate 
large loads is not limited to loads of 200 MW or more.6 
 
2 Id. at 51; Prepared Direct Testimony of Christina Drake, Tab C, at 24:9-15 (“Drake Test.”). 
3 Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 at P 58 (2026) (“Show Cause Order”). 
4 Midcontinent Indep. System Operator, Inc., Docket No. ER26-3650-000 at Att. A (filed Aug. 28, 2026) 
(Large Load is defined as: “Load with Demand of 50 MW or more associated with any facility or 
aggregation of facilities located at a single substation behind one or more Point(s) of Withdrawal from the 
Transmission System that is owned, operated, or controlled by: (a) a single entity, or (b) a group of 
entities that will coordinate with respect to the profile of the Load….”). 
5 Transmittal Letter at 1 n.4. 
6 Show Cause Order at PP 112–117 (“For purposes of this order, it appears to be reasonable to use the 
term ‘electrically proximate large load’ to mean a large load, as defined in this order [50 MW and 
connected at 69 kV and above], 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.” Id. at P 112 (noting that the 
Commission will consider revisions to this definition that ensure it is tailored to MISO’s transmission 
system)).

3 
 
Section 205 prohibits any public utility from maintaining “any unreasonable difference in 
rates, charges, service, facilities, or in any other respect” between classes of service.7 A paired 
load and generation that interconnect to the Transmission System are similarly situated whether 
the load is 75 MW or 200 MW. Each takes transmission service, each faces the study timing 
mismatch LARS cures, and each presents the same coordination problem. MISO must show that 
paired loads and generation below 200 MW affect the Transmission System differently. It has not 
done so. 
MISO responds that the 200 MW minimum preserves LARS’s “focus on large, impactful 
load additions.”8 But MISO has already determined that loads of 50 MW or more are impactful 
enough to warrant its large load reliability requirements.9 MISO cannot treat those loads as large 
and impactful for reliability purposes yet not for the study process designed to integrate them. 
Nor does the load size bear on the problem LARS solves – the timing mismatch between MISO’s 
load study and its generator interconnection queue arises for any paired load awaiting a 
generator’s GIA. And the ten-pair cap, not a size threshold, already preserves the focus of each 
study cycle.10 
MISO's supporting testimony also relies on stakeholder feedback that data center loads 
"come in 200 MW blocks,"11 but cites no data. Industry sources indicate that data center capacity 
is typically built and energized in smaller increments.12 Smaller loads also fall within the 
 
7 16 U.S.C. § 824d(b). 
8 Transmittal Letter at 51. 
9 See supra note 4. 
10 See Transmittal Letter at 9.  
11 Drake Test. at 24:11-13. 
12 See, e.g., Elevate Energy Consulting & GridLab, Practical Guidance and Considerations for Large 
Load Interconnections at 20 and Fig. 2.3 (May 2025) (illustrating a 50 MW data center block within a 200 
MW facility served through four points of connection), available at https://gridlab.org/portfolio-
item/practical-guidance-and-considerations-for-large-load-interconnections/; JLL, 2026 Global Data

4 
 
industrial category that MISO expressly sought to reach by lowering the threshold.13 
Additionally, other RTOs apply materially lower thresholds; Southwest Power Pool's High 
Impact Large Load Generation Assessment framework, for example, applies to loads of greater 
than 10 MW.14  
The proper screen for LARS is interconnection of Large Load to the Transmission 
System, not load size. MISO’s own Large Load definition draws that exact line: it applies to 
loads of 50 MW or more that connect to the Transmission System. That definition implements 
the Commission’s direction to tailor the large load definition to MISO’s system.15 LARS itself 
requires that the paired load’s Point of Withdrawal connect to the Transmission System. The 200 
MW minimum is the only thing separating the two, and MISO offers no transmission-based 
reason for departing from the Show Cause Order. LARS should therefore apply to loads of 50 
MW or more that connect to the Transmission System. A 75 MW load connected to the 115-161 
kV network that must await a paired generator's GIA faces the same delay as a 200 MW load. 
Nor is a 200 MW minimum needed to protect the process. MISO's other safeguards 
already screen out speculative and de minimis requests: the $250,000 non-refundable deposit, the 
milestone payment, full site control, and the bar on aggregating multiple loads.16 And the pairing 
agreement, the same LRZ requirement, and the 15-year commitment – not load size – are what 
keep LARS from becoming a bypass of the competitive DPP queue. A 200 MW minimum load 
size adds no protection beyond what these safeguards already provide. 
 
Center Outlook (Jan. 2026) (reporting an average global build time of 18 months for a new 50 MW data 
center), available at https://www.jll.com/en-us/insights/market-outlook/data-center-outlook. 
13 Transmittal Letter at 3, 51. 
14 See Sw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026). 
15 Show Cause Order at P 58. 
16 Transmittal Letter at 9, 11, 25; Drake Test. at 24–25.

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Finally, if the Commission agrees that the minimum load size should be lowered, it 
should direct a conforming change to Section 3.12.2, which separately requires at least 200 MW 
of Network Resource Interconnection Service at each Point of Interconnection. That generation-
side minimum derives from the load threshold and should scale with it, so that a qualifying load 
can be served by appropriately sized generation. 
II. 
Conclusion 
Bloom does not ask the Commission to delay LARS. Bloom respectfully requests that the 
Commission (1) accept LARS effective December 2, 2026; and (2) direct MISO, in a compliance 
filing within 60 days, either to (a) align LARS eligibility with MISO's Large Load definition, 
with a corresponding generation-side minimum, or (b) provide record evidence that loads below 
200 MW connected to the Transmission System do not warrant coordinated study.  
Respectfully submitted, 
 
/s/ Joel D. Newton 
 
Joel D. Newton 
VP, Regulatory Law 
Bloom Energy Corporation 
4353 North First Street 
San Jose, CA  95134 
joel.newton@bloomenergy.com 
(202) 329-1119 
October 23, 2026 
 
 
Certificate of Service 
I hereby certify that I have served the foregoing document on all persons listed on the 
Commission’s official service list compiled by the Secretary in this proceeding. 
Dated at Falls Church, VA this 23rd day of October, 2026. 
 
 
 
 
/s/ Joel D. Newton