ER27-25-000 · 2026-10-23 · Iowa OCA and 8 consumer advocates

Joint Protest of the Iowa Office of the Consumer Advocate, the Citizens Utility Boards of Michigan, Illinois, Wisconsin and Minnesota, Citizens Action Coalition of Indiana, the Michigan and Illinois Attorneys General, and the Minnesota Department of Commerce

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
 
 
) 
Midcontinent Independent System 
) 
 
Docket ER27-25-000 
      Operator, Inc. 
) 
 
 
 
 
) 
 
 
 
JOINT PROTEST OF  
THE IOWA OFFICE OF THE CONSUMER ADVOCATE, 
THE CITIZENS UTILITY BOARD OF MICHIGAN,  
THE CITIZENS UTILITY BOARD OF ILLINOIS,  
THE CITIZENS UTILITY BOARD OF WISCONSIN, 
THE CITIZENS UTILITY BOARD OF MINNESOTA 
CITIZENS ACTION COALITION OF INDIANA,  
MICHIGAN ATTORNEY GENERAL,  
THE OFFICE OF THE ILLINOIS ATTORNEY GENERAL, AND  
MINNESOTA DEPARTMENT OF COMMERCE 
 
 
 
Pursuant to Rule 211 the Federal Energy Regulatory Commission’s (“Commission”) 
Rules of Practice and Procedure, 18 C.F.R. section 385.211 and the August 31, 2026 Combined 
Notice of Filings #1, the Iowa Office of Consumer Advocate, Citizens Utility Board of 
Michigan, Citizens Utility Board of Illinois, Citizens Utility Board of Wisconsin, Citizens Utility 
Board of Minnesota, Citizens Action Coalition of Indiana, the Michigan Attorney General, the 
Office of the Illinois Attorney General, and Minnesota Department of Commerce (collectively, 
the “Joint Protestors”) respectfully submit this Joint Protest in the above-captioned proceeding.   
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

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Additional Resource Study Process (“LARS Process”) with the Commission in the above-
captioned action.1   
 
On October 2, 2026, MISO filed proposed revisions to its Open Access Transmission, 
Energy, and Operating Reserve Markets Tariff (“Tariff”) to establish a LARS Process with 
supporting direct testimony prepared by Christina Drake, MISO Director, Generation 
Interconnection.  In the Transmittal Letter, MISO asserts the filing is responsive to the 
Commission’s concerns in its Show Cause Order in Docket No. EL26-70-000, including the 
finding 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.2   
 
In the Show Cause Order, the Commission found MISO’s Tariff “appears to be unjust and 
unreasonable because it lacks adequate mechanisms to mitigate the risk of cost shifting among 
transmission customers, which may result in unjust and unreasonable rates for transmission 
service.”3  In the ruling, the Commission expressed concern about the lack of transparency 
regarding the assignment of costs, including Network Upgrades, necessary to provide 
transmission service to Eligible Customers or Large Load Customers on behalf of Large Loads. 
The Commission sought to ensure Eligible Customers bear the risk and are ultimately 
responsible for costs incurred to provide transmission service, including the cost of Network 
Upgrades.4   
 
1  In the Show Cause Order discussed below, the Commission expressly “encourage[d] . . . state consumer advocates 
to submit comments explaining whether this information is sufficient and granular enough or to submit comments 
explaining precisely which additional information on transmission cost allocation may be needed to inform proper 
state-jurisdictional cost allocation.”  Midcontinent Indep. Sys. Operator, Inc., 195 FERC ¶ 61,212 at P 70 (2026) 
(“Show Cause Order”). 
2  Transmittal Letter at 3. The definition of electrically proximate large loads is in the Show Cause Order and set 
forth in this Protest, below. See footnote 23. 
3  Show Cause Order at P 66.   
4  Id. at PP 70-77.

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I. 
The Commission Should Not Allow the Grandfathering of Approximately 30 
Gigawatts of Load   
 
MISO is proposing to fully exempt or “grandfather” any Large Load with a service 
commencement date on or prior to December 4, 2026, from all requirements of proposed Section 
37A, or more generally, the Large Load Interconnection Reliability Requirements.5  MISO is 
also proposing to partially exempt a Large Load or a portion of a Large Load that does not have a 
Service Commencement Date prior to December 4, 2026, but that meets the MTEP/EPR 
Condition and the ramp and ride-through requirements set forth in Section 37A.6 through 
37A.7.6  In total, MISO is proposing to fully or partially exempt approximately 30 gigawatts of 
existing load from the Large Load Interconnection Reliability Requirements.7  The Joint 
Protestors filed a Protest in Docket No. ER26-3650-000 on September 18, 2026, protesting 
MISO’s proposed grandfathering exemptions.8  The Joint Protestors maintain the proposed 
grandfathering exemptions under MISO’s Section 205 filings, including the LARS Process, are 
not just and reasonable.  If the grandfathering exemptions are carried forward in this filing and to 
the series of future Federal Power Act Section 205 filings MISO intends to make in response to 
the Show Cause Order, the exemptions could deprive electric consumers of the cost-shifting and 
other consumer protections MISO has been directed to address in the Show Cause Order.  
 
 
5  Midcontinent Indep. Sys. Operator, Inc., Interconnection of Reliability Requirements for Large Loads, Docket No. 
ER26-3650 at 13- 14 (Aug. 28, 2026).   
6  Id. 
7  Midcontinent Indep. Sys. Operator, Large Load Working Group, Large Load Interconnection Reliability 
Requirements (LLWG) at 8 (Aug. 12, 2026), https://www.misoenergy.org/events/2026/large-load-working-group-
llwg---august-12-2026/ (last visited on Sept. 16, 2026). 
8  Joint Protest of the Iowa Office of Consumer Advocate et al., Midcontinent Indep. Sys. Operator, Inc., Docket No. 
ER26-3650-000 at 3 (filed Sept. 18, 2026).

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II. 
Cost-Shifting Should be Addressed Across MISO’s Section 205 Filings and in the 
Section 206 Filing 
 
 
MISO’s LARS Process does not address the Commission’s concerns regarding cost-
shifting expressed in the Show Cause Order.  In her direct testimony, MISO Witness Drake notes 
“[t]he cost shifting issues raised in the Commission’s Show Cause Order will be addressed in 
future filings that MISO plans to submit by November 16.”9  The Commission’s concerns 
regarding cost-shifting are an integral part of the Show-Cause Order.  If the Commission 
approves MISO’s proposed Tariff changes in MISO’s Section 205 filings without considering 
cost-shifting and the collective impact of all of MISO’s Section 205 filings as a whole, electric 
customers may be deprived of the cost-shifting and other consumer protections the Commission 
directed MISO to address in the Show Cause Order.  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.  The Joint Protestors should be permitted to address the cost-
shifting impacts, transparency issues, and other consumer protection issues raised in MISO’s 
Section 205 filings as a whole, collectively, in the Section 206 Show Cause Docket.10 
 
 
9  Tab C. MISO Witness Drake Direct Testimony at 41:7-8.   
10 Consumer advocates have demonstrated a need for their offices to have a more meaningful, active, and visible role 
in MISO.  See Docket No. AD25-7, Statement of Jennifer Easler on behalf of Iowa OCA at 7 (May 16, 2025); see 
also id. at 7-8 (urging “the Commission to consider changes to give Consumer Advocates a stronger voice at MISO 
and its planning process so the interests of those who pay the bills are heard.”).  MISO’s failure to address the cost-
impact components of the Show Cause Order serves as  an acute example that corroborates that need.  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 MISO’s Tariff to fund a consumer advocate organization 
(similar to the CAPS organization in PJM Interconnection, L.L.C.).

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III. 
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 the studies, MISO proposes the following language: 
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 
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.12 
 
In the Transmittal Letter, MISO explains the above language: 
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.13 
 
In her direct testimony, MISO Witness Drake further explains the proposed Tariff change: 
Q. 
BECAUSE LARS INVOLVES GENERATION/LOAD PAIRS, HOW 
ARE VIOLATIONS AND THEIR ASSOCIATED MITIGATION 
COSTS ASSIGNED? 
 
A. 
The generator will be responsible for any constraints unique to the 
generation study and the load will be responsible for any constraints 
unique to the load study.  In the event there is an overlap in violations, 
then the costs will be assigned to the load.  Thus, projects developed to 
mitigate violations observed only in the LARS generator study will be 
assigned to the LARS Interconnection Customer under the Generator 
Interconnection Project (depicted as GIP below) project type.  In the event 
that any Planning Criteria violations, such as thermal or voltage overloads, 
 
11  Transmittal Letter at 31-32; Tab A, ATTACHMENT X, Generator Interconnection Procedures (GIP) 193.0.0. 
12  Transmittal Letter at 31-32; Tab A, ATTACHMENT X, Generator Interconnection Procedures (GIP) 193.0.0. 
13  Transmittal Letter at 32.

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are observed during the load-side study process including any common 
violations identified between the generation and load studies, mitigations 
will be developed and assigned BRP or Other project types as defined in 
Attachment FF. 
 
 
 
 
 
As the diagram demonstrates above, in the event that there is a common 
issue between the load and generation, then the cost will be allocated for 
the BRP or Other project type.  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.  
The LARS Process assigns the Interconnection Customer, the cost-causer, the cost of network 
upgrades to address violations observed in the generation study under the GIP project type.  
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 (“BRP”) or Other project 
types, which are allocated zonally.  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 
 
14  Tab C, MISO Witness Drake Direct Testimony at 27:14-28:7.

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generation pairs. MISO indicates in its Transmittal Letter that any overallocation of upgrade 
costs will be “formalized in a future MTEP project,” and will likely be allocated zonally across 
MISO’s Transmission Pricing Zone.15 This does not address whether costs are properly allocated 
to large loads. MISO’s Tariff does not contain a transparent, cost-causation tracking framework 
to track the cost of the network upgrades, allowing the cost of the network upgrades to shift from 
direct assignment to the cost-causer to other ratepayers under zonal rates.  Consistent with the 
Show Cause Order, the cost-causer, not other ratepayers, should be responsible for all network 
upgrades resulting from the Large Load. Proposals that allocate Large Load network upgrade 
costs to other customers zonally under the premise of the alleged benefits those customers 
receive are therefore irrelevant.   
IV.  
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 Illinois.17  In the Transmittal Letter, MISO explains that they chose the load and 
generation interconnection pair threshold at the LRZ to align with MISO’s Resource Adequacy 
construct.18 MISO Witness Christina Drake further details the choice around LRZ: 
Q.  
HOW DOES LARS ADDRESS THE ELECTRICALLY 
PROXIMATE REQUIREMENT IN THE SHOW CAUSE ORDER?  
 
A.  
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.  MISO did 
not want to limit the pairing of generation with associated load to a 
 
15 Transmittal Letter at 13. 
16 Transmittal Letter at 10. 
17 Midcontinent Indep. Sys. Operator, FERC Electric Tariff, Attachment VV, Map of Local Resource Zone 
Boundaries (40.0.0) at 1 (effective Oct. 26, 2025), https://www.misoenergy.org/legal/tariff/ (last visited on Oct. 18, 
2026). 
18 Tab C. MISO Witness Drake Direct Testimony at 40.

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specific number of substations because that would limit how MISO may 
optimize common solutions.19 
 
MISO discusses how it could have structured its LARS proposal, by either “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.”20 MISO indicates that it chose neither of these 
structures, favoring LRZ as a boundary, due to its existing relationship with the Resource 
Adequacy metric, as well as “avoiding capacity import/capacity export limitations for the 
individual LRZ,” and avoiding “price separation between the paired generation and LARS 
Associated Load.”21 
 
The Commission indicated preference for faster interconnection between large load and 
associated generation facilities in the Large Load ANOPR, as well as in the Commission’s Show 
Cause Order. The Commission’s Show Cause Order considers the benefits of studying new load 
and new generation together. Physical proximity between new load and new generation “when 
physically or electrically proximate, present system benefits and can help address the challenges 
posed by large load."22 The Commission’s Show Cause Order defines “electrically proximate 
large load” as “no more than two substations away from the generating facility” to govern the 
electrical distance in between related generation interconnection and large load.23 The 
 
19 Tab C MISO Witness Drake Direct Testimony at 10. 
20 Transmittal Letter at 10. 
21 Tab C MISO Witness Drake Direct Testimony at 40:15-16, Transmittal Letter at 22. 
22 Show Cause Order at P 106. 
23 “[T]he term “electrically proximate large load” to mean a large load, as defined in this order,  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).  We will consider 
proposed revisions to this definition that ensure it is appropriately tailored to MISO’s transmission system.” Show 
Cause Order at P 112.

9 
Commission established this definition because electrical efficiencies created by narrow co-
location of generation interconnection and new large load customers would harmonize siting of 
load and generation and minimize the need for Network Upgrades. 24 
 
MISO does not accomplish optimizing solutions between a LARS Associated Load and 
an Interconnection Customer’s generation facility in accordance with the Commission’s guidance 
in the Show Cause Order. Instead of proposing a compatible definition of “electrically 
proximate,” MISO eschewed the lower network upgrade cost benefits of defining new large load 
and generation facilities in a constrained area in favor of the LRZ boundary for the LARS 
proposal. 
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, with load and generation being linked, despite being located 
potentially many states away. Furthering the logical challenge presented by MISO’s use of LRZ 
as a boundary, MISO has Zones that range in size from LRZ 1, which spans from eastern 
Montana to northwest Illinois, to LRZ 5 which comprises less than half of the state of Missouri. 
MISO’s LRZ proposal does not meaningfully engage with the Show Cause Order. MISO neither 
evaluates whether its LRZ boundaries are appropriate under the Order’s terms nor supports its 
conclusion that they are. 
The Joint Protestors respectfully urge the Commission to require MISO to establish a 
reasonable distance of “electrically proximate” that fully considers the factors laid out in the 
Commission’s Show Cause Order. For example, MISO could allow for project-specific 
substations to not count against the “no more than two substations” count, such that a step-up 
 
24 Show Cause Order at P 113.

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substation to transmission voltage and a step-down to distribution voltage are not part of the 
electrical distance or electrical impact.25 However, as the proposal stands, MISO’s LARS filing 
appears to be a departure from the defined electrical distance contemplated in the Show Cause 
Order.  
V.  
MISO Fails to Explain How LARS is Not a Queue-Jumping Proposal 
 
The Joint Protestors also take issue with MISO’s classification of the LARS proposal and 
its intent to build off the success of the Expedited Resource Addition Study (“ERAS”) and the 
Zero-Injection Generator Interconnection Agreement (“ZGIA”) process, the latter of which is 
still pending at the Commission. The ERAS pathway allowed Generator Interconnection 
customers who have approval from their Retail Electric Rate Regulatory Authority (“RERRA”) 
to seek an expedited pathway to a Generator Interconnection Agreement (“GIA”), circumventing 
the traditional DPP queue. The Joint Protestors are concerned that LARS, similar to ERAS, will 
enable queue jumping. MISO Witness Drake indicates that “MISO understands the concerns that 
LARS is enabling queue jumping,” but does not believe that the LARS proposal contemplates 
queue jumping and maintains a size cap that prevents misuse of the process.26  
MISO Witness Drake discusses the likely success of the LARS process from a planning 
standpoint, and how there could be strategic efficiencies between generator interconnection and 
load interconnection processes, “If MISO can identify a common solution that 
helps integrate both the load and generation into the system, then MISO can maximize the 
benefits of both processes and reduce integration costs.”27 The LARS study process only 
evaluates generator projects with executed GIAs. Any projects currently moving through the 
 
25 Show Cause Order at 67. 
26 Tab C, MISO Witness Drake Direct Testimony at 10. 
27 Tab C, MISO Witness Drake Direct Testimony at 6.

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DPP Cycle will not be modeled into the LARS study models.28 In effect, any LARS project will 
be studied before the DPP projects that have waited through multiple phases of study. The 
omission of DPP projects combined with an electrically proximate definition that can be up to 
nearly a thousand miles creates a process that enables queue jumping for LARS Associated 
Generators.  
MISO’s testimony supposes that queue jumping only becomes a problem when the 
jumping is unrestricted and constant. Under FPA Section 205, MISO bears the burden of proof 
that LARS is just and reasonable, and not unduly preferential. MISO has not adequately 
explained how LARS generation projects are not receiving undue preference over other 
generation projects in the DPP cycles ahead of them. 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 unduly 
discriminatory to Generator Interconnection Customers currently in the queue. 
CONCLUSION 
WHEREFORE, the Joint Protestors pray the Commission reject MISO’s proposed Tariff 
grandfathering exemptions to ensure Large Load customers bear the cost and risk of all costs 
caused by the Large Load customer, direct MISO to address cost-shifting in its Section 205 
filings and in its direct response to the Section 206 filing, allow the Joint Protestors to address 
the cost-shifting impacts, transparency issues, and other consumer protection issues raised in 
MISO’s Section 205 filings as a whole, collectively, in the Section 206 Show Cause Docket, 
reject MISO’s proposed Tariff provisions under GIP Section 3.12.4 that shift the cost of network 
 
28 Tab C, MISO Witness Drake Direct Testimony at 28. 
29 Show Cause Order at P 36.

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upgrades to address violations observed in the transmission studies and observed in both the 
transmission study and the generation study to Baseline Reliability or Other project types, reject 
MISO’s LARS definition for “electrically proximate” to mean across an LRZ, reject MISO’s 
provisions that allow queue jumping around the standard DPP process, and require MISO to 
ensure Large Load customers bear the cost and risk of all costs caused by the Large Load 
customer, and for any additional relief Commission deems appropriate under the circumstances. 
 
 
 
 
Respectfully submitted, 
 
/s/ Anthony A. Alvarez 
 
Anthony A. Alvarez 
Utilities Regulation Engineer 2 
Iowa Attorney General 
Office of the Consumer Advocate 
1375 East Court Avenue 
Des Moines, IA  50319 
Anthony.Alvarez@oca.iowa.gov
/s/ Jennifer C. Easler 
 
Jennifer C. 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 Department of Commerce 
85 7th Place East, Suite 280 
Saint Paul, MN  55101   
Sydnie.Lieb@state.mn.us 
 
For the Minnesota Department of Commerce 
 
/s/ Sarah Moskowitz 
 
Sarah Moskowitz 
 
Executive Director 
Citizens Utility Board of Illinois 
309 W. Washington Street 
Suite 800 
Chicago, IL 60606 
smoskowitz@citizensutilityboard.org 
 
For the Citizens Utility Board of Illinois
/s/ John Liskey 
 
John Liskey 
General Counsel 
Citizens Utility Board of Michigan 
921 N. Washington Ave 
Lansing, MI 48906 
(517) 913-5105 
John.liskey@cubofmichigan.org 
 
For Citizens Utility Board of Michigan 
 
/s/ Jennifer A. Washburn 
 
Jennifer A. Washburn 
Regulatory Director 
Citizens Action Coalition of Indiana, Inc. 
1915 W. 18th Street, Suite C 
Indianapolis, IN 46202 
(317) 735-7764 
jwashburn@citact.org 
 
For Citizens Action Coalition of Indiana, Inc.

13 
/s/ Daniel Narvey 
 
Daniel Narvey 
General Counsel 
625 North Segoe Rd. Suite 101 
Madison, WI 53705 
(608) 251-3322 
narvey@cubwi.org 
 
For the Citizens Utility Board of Wisconsin 
 
/s/ Michael E.  Moody 
 
Michael E.  Moody 
 
Special Litigation Division Chief 
Assistant Attorney General 
Michigan Department of Attorney General 
P.O. Box 30212 
Lansing, MI 48909 
Moodym2@michigan.gov      
 
For the Michigan Attorney General 
 
/s/ Brandon Crawford 
 
Brandon Crawford 
 
Regulatory Advocate 
Citizens Utility Board of Minnesota 
332 Minnesota St., Suite W1360 
Saint Paul, MN 55101 
brandonc@cubminnesota.org  
 
For the Citizens Utility Board of Minnesota 
/s/ Corey Singletary 
 
Corey Singletary 
Director of Regulatory Affairs 
625 North Segoe Rd. Suite 101 
Madison, WI 53705 
(608) 251-3322 
singletary@cubwi.org 
 
For the Citizens Utility Board of Wisconsin 
 
/s/ Samuel C. Lukens 
 
Samuel C. Lukens 
Assistant Attorney General 
Public Utilities Bureau 
Office of the Illinois Attorney General  
115 South LaSalle Street, 25th Floor 
Chicago, IL 60603 
samuel.lukens@ilag.gov 
 
For the Office of the Illinois Attorney General 
 
Dated: October 23, 2026

CERTIFICATE OF SERVICE 
 
 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
 
 
Dated at this 23rd day of October, 2026. 
 
 
/s/ Jennifer C. Easler 
 
 
 
Jennifer C. Easler 
 
Attorney 
 
Office of Consumer Advocate of Iowa 
 
1375 East Court Avenue 
 
Des Moines, IA 50319-0063 
 
(515) 725-7224 
 
jennifer.easler@oca.iowa.gov