Read topic-matched comments in ER27-25
Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment
PDF p. 14
LARS, therefore, takes a category of costs usually assigned to generators and assigns them to existing load. PDF p. 14Filed comments: Connecting load and generation
PDF p. 18
A process that assigns upgrade costs to zonal load now, on the strength of an agreement whose terms are not before the Commission, has not been shown to be just and reasonable. PDF p. 18
PDF p. 18
These differing approaches risk MISO allocating transmission headroom twice. PDF p. 18
PDF p. 18
Failing to coordinate DPP and LARS shifts costs onto DPP customers. PDF p. 18Filed comments: Connecting load and generation
PDF p. 30
In other words, the LSE is the gatekeeper for participation in LARS, because without it PDF p. 30Filed comments: Connecting load and generation
PDF p. 32
LARS is not time-limited, as MISO's most recent queue-jumping proposal ERAS was. PDF p. 32Filed comments: Connecting load and generation
PDF p. 33
Instead, LARS generators and load are merely required to be in the same general Local Resource Zone. PDF p. 33Filed comments: Connecting load and generation
PDF p. 24
MISO's proposal is unduly discriminatory because it grants generators associated with qualifying large loads an accelerated pathway to obtain access to MISO's Planning Resource Auction market PDF p. 24
PDF p. 21
After fifteen years, the generator keeps full NRIS of up to 150 percent of the departed load's peak demand with no further study and no cost at all. PDF p. 21
PDF p. 39
LARS would be at least the fifth separate path onto the MISO transmission system PDF p. 39Filed comments: Connecting load and generation
PDF p. 40
By excluding the DPP, LARS does the opposite of NERC's procedures. PDF p. 40Filed comments: Connecting load and generation
PDF p. 45
the Commission should reject all portions of MISO's LARS proposal and direct MISO to engage with stakeholders to advance a different proposal. PDF p. 45Filed comments: Connecting load and generation
Midcontinent Independent System Operator · Direct response
MISO said the study should go ahead before related cost-recovery reforms were complete. It promised to incorporate those protections once FERC accepted them and cited other existing tariff mechanisms.
PDF pp. 5–6Printed 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 PROTEST OF CLEAN ENERGY ADVOCATES AND COMMUNITY ORGANIZATIONS Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”)1, Clean Energy Advocates2 and Community Organizations3 respectfully submit this protest in…Read this passage Filed comments: Connecting load and generation
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TABLE OF CONTENTS I.Read this passage Filed comments: Connecting load and generation
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C.Read this passage Filed comments: Connecting load and generation
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D.Read this passage Filed comments: Connecting load and generation
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I.Read this passage
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The Commission should reject LARS because it is not just and reasonable and is unduly discriminatory or, in the alternative, issue a deficiency letter requiring MISO to demonstrate how LARS can be made just and reasonable.Read this passage Filed comments: Connecting load and generation
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II.Read this passage
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BackgroundRead this passage
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MISO acknowledges that “large loads have overtaken the EPR process.”7 The 89 EPR requests approved in MTEP26 accounted for roughly 54 percent of the approximately $14.7 billion of transmission investment approved in that cycle.8 A generator may be treated as an alternative to a transmission…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Cost allocation
These include: (1) A definition of large load. (2) A rolling application process with non-refundable fees, escalating readiness requirements, and disclosure of duplicative requests. (3) Study procedures that account for large-load behavior and flexibility. (4) Evaluations of alternative…Read this passage Filed comments: Cost allocation
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MISO retained this structure over stakeholder objections, citing “mixed feedback.” MISO Large Load Working Group, MISO Response to Feedback, at 7 (Sept. 28, 2026), available at 9 Second, the Interconnection Customer develops a generating facility, demonstrates that it will provide energy to the…Read this passage Filed comments: Connecting load and generation
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The Stakeholder Process MISO developed LARS in eleven weeks.Read this passage Filed comments: Connecting load and generation
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III.Read this passage
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ER25-1674-000 (Apr. 7, 2025), Accession No. 20250407-5242 (explaining that excluding late-stage DPP projects from an expedited interconnection study produces reliability gaps, and that resolving the resulting overallocation of transmission headroom through the annual MTEP process does not cure them…Read this passage Filed comments: Connecting load and generation
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This is particularly true for the types of large loads that MISO anticipates connecting, which have disproportionately high load factors and therefore should not have the excess capacity to bid into the PRA. 102 Id. at 15. 103 Transmittal Letter at 2. 104 See id. at 9 (“The agreement must…Read this passage Filed comments: Connecting load and generation
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While LARS might fast track a limited set of privileged interconnection requests, the creation of a new interconnection queue will put competing pressures on MISO’s staff and compute time to process standard DPP requests.Read this passage Filed comments: Connecting load and generation
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Additionally, MISO justifies this choice by arguing that tying LARS Associated Load to Local Resource Zones “avoids price separation between the paired generation and LARS Associated Load.”148 However, Local Resource Zones do not always align with transmission pricing zones and cost allocation…Read this passage Filed comments: Connecting load and generation
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Due to the permanent nature of MISO’s LARS proposal, there is a risk that non-LARS transmission customers could be permanently disadvantaged by the process and bear the costs of transmission investments needed to resolve issues caused, at least in part, by a LARS request, or series of…Read this passage Filed comments: Connecting load and generation
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IV.Read this passage
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Conclusion For the foregoing reasons, the Commission should reject all portions of MISO’s LARS proposal and direct MISO to engage with stakeholders to advance a different proposal.Read this passage Filed comments: Connecting load and generation
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Dated: October 23, 2026. /s/ Justin Vickers Justin Vickers Senior Attorney, Sierra Club 2101 Webster St., 13th Floor Oakland, CA 94612 (224) 420-0614 justin.vickers@sierraclub.org Counsel for Sierra ClubRead this passage