Read topic-matched comments in ER27-25
Topics in the text: Connecting load and generation · Registry access · Cost allocation
PDF p. 9
Neither MISO Witness Drake nor the Transmittal Letter explain how the LARS proposal mitigates the electrical impact of LARS Associated Load and generation facilities being spaced potentially hundreds of miles apart PDF p. 9Filed comments: Connecting load and generation
PDF p. 6
Unlike the violations observed only in the generation study, the LARS Process assigns the cost of network upgrades to address violations observed in the transmission studies and observed in both the transmission study and the generation study to Baseline Reliability PDF p. 6Filed comments: Connecting load and generation
PDF p. 6
The LARS proposal does not adequately assign costs to the cost causers, and MISO has not yet fully developed a cost allocation proposal for LARS load and PDF p. 6Filed comments: Connecting load and generation
PDF p. 4
The Commission should require MISO to address cost-shifting in all of its Section 205 filings and in all of its direct responses to the Section 206 Show Cause Order. PDF p. 4
PDF p. 10
The Joint Protestors are concerned that LARS, similar to ERAS, will enable queue jumping. PDF p. 10Filed comments: Connecting load and generation
PDF p. 9
The Joint Protestors respectfully urge the Commission to require MISO to establish a reasonable distance of "electrically proximate" PDF p. 9
PDF p. 3
In total, MISO is proposing to fully or partially exempt approximately 30 gigawatts of existing load from the Large Load Interconnection Reliability Requirements. PDF p. 3
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: Registry access
JOINT PROTEST The Joint Protestors submit this Joint Protest regarding the proposed tariff revisions filed by the Midcontinent Independent System Operator, Inc. (“MISO”) regarding the Large Load 2 Additional Resource Study Process (“LARS Process”) with the Commission in the above- captioned…Read this passage Filed comments: Registry access
printed heading · Topic match: Registry access
In a future submission, Joint Protestors may ask FERC to take action under Section 206 to address that need by (i) finding that the lack of funding provisions for consumer advocate offices renders MISO’s Tariff unjust and unreasonable and unduly discriminatory, and (ii) establishing a mechanism in…Read this passage Filed comments: Registry access
printed heading · Topic match: Connecting load and generation
The LARS Process Lacks Transparency on Costs and Allows Cost-Shifting of Network Upgrades MISO proposes to add a new GIP Section 3.12.4 to describe the studies that will take place for LARS generation projects.11 With respect to mitigations or network upgrades to address violations observed during…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
If a GIP defers or displaces a BRP, then the costs of the GIP up to the costs of the deferred or displaced BRP shall be allocated consistent with the cost allocation for the BRP.14 The LARS Process does not assign the cost of all network upgrades to the cost-causer.Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
The LARS Process Fails to Address the Commission’s Show Cause Order’s Requirement to be “Electrically Proximate” MISO proposes LARS as load and generation pairs, interconnecting within the same Local Resource Zone (LRZ).16 MISO LRZ’s are physically large, with LRZ 1 spanning from Montana to…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
MISO’s LARS proposal provides the Tariff structure necessary to enable an Interconnection Customer to serve an electrically proximate load as the LARS Associated Load must be located within the same LRZ.Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Connecting load and generation
The Show Cause Order explicitly asks MISO to show, in their FPA Section 205 filing, how they will “avoid disrupting existing commercial arrangements.”29 MISO has not shown how the LARS filing will avoid such disruptions to the existing DPP queue, and will avoid being unjust and unreasonable, or…Read this passage Filed comments: Connecting load and generation
printed heading · Topic match: Registry access
Easler Attorney Iowa Attorney General Office of the Consumer Advocate 1375 East Court Avenue Des Moines, IA 50319 jennifer.easler@oca.iowa.gov For the Iowa Office of the Consumer Advocate /s/ Sydnie Lieb Sydnie Lieb Assistant Commissioner of Regulatory Affairs, Energy Resources Division Minnesota…Read this passage Filed comments: Registry access
printed heading · Topic match: Registry access
Easler Attorney Office of Consumer Advocate of Iowa 1375 East Court Avenue Des Moines, IA 50319-0063 (515) 725-7224 jennifer.easler@oca.iowa.govRead this passage Filed comments: Registry access