Read topic-matched comments in ER27-25
Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment
PDF p. 2
Under current rules, the costs of those project types are recovered from all network customers in a Transmission Pricing Zone. PDF p. 2
PDF p. 8
the Commission cannot determine that LARS is just and reasonable because the record lacks such a key piece of the puzzle. PDF p. 8Filed comments: Connecting load and generation
PDF p. 3
the Commission should either reject LARS with guidance indicating that it needs to be filed concurrently with procedures to prevent cross-subsidization or, in the alternative, accept and suspend the proposal PDF p. 3Filed comments: Connecting load and generation
PDF p. 2
Google supports the intent and conceptual direction of LARS. PDF p. 2Filed comments: Connecting load and generation
PDF p. 6
each process is based on an incomplete snapshot of the transmission system and how it will operate in practice, which increases the likelihood that the LARS and DPP processes will produce incompatible results. PDF p. 6Filed comments: Connecting load and generation
PDF p. 7
LARS could be modified to use more conservative assumptions PDF p. 7Filed comments: Connecting load and generation
PDF p. 9
making load-serving entities ("LSEs") the gatekeepers of the LARS process PDF p. 9Filed comments: Connecting load and generation
PDF p. 9
protections providing that all forms of generation, including independent generation, have nondiscriminatory, direct access to the expedited generation interconnection study process under LARS. PDF p. 9Filed comments: Connecting load and generation
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
In addition, MISO must also continue to refine and improve its principal interconnection process, the Definitive Planning Phase (“DPP”), so that all generation resources in MISO—not 8 Id. at 14. -4- just those paired with large loads—can interconnect on a reasonable timeline.Read this passage Filed comments: Connecting load and generation
PDF bookmark · Topic match: Connecting load and generation
That is particularly so given that LARS’s design creates the very real risk of overallocation because ongoing DPP cycles do not include LARS requests and the LARS studies do not include DPP projects before they have signed Generator Interconnection Agreements.19 As a result, each process is based…Read this passage Filed comments: Connecting load and generation
PDF bookmark · Topic match: Connecting load and generation
It could reject the LARS proposal outright with direction to MISO that if it refiles LARS it must contain adequate protections against cost shifting, including any pro forma agreement.Read this passage Filed comments: Connecting load and generation
PDF bookmark · Topic match: Connecting load and generation
Under MISO’s proposal, LARS applications must be submitted through a designated LARS Associated Transmission Customer, which MISO indicates is typically the LSE.Read this passage Filed comments: Connecting load and generation
printed heading
Dated: October 23, 2026 Washington, D.C. /s/ Bryan Shpall Bryan Shpall Wilson Sonsini Goodrich & Rosati 1700 K Street NW Fifth Floor Washington, DC 20006Read this passage