- Docket
- EL26-68-000
- Item
- E-9
- Reporter cite
- 195 FERC ¶ 61,213
- Region
- Central U.S., 14+ states
- Respondents
- SPP + 22 named transmission owners
- Length
- 92 pages
Read the order PDF (committed copy) Official source on ferc.gov ↗
What is unique to SPP
SPP is the benchmark, not the laggard. E-9 adopts SPP’s own ‘High Impact Large Load’ (HILL) definition, commends its ‘High Impact Large Load Generation Assessment’ (HILLGA) and Conditional HILL Service, and leaves the Attachment Z1/AQ/AX study stack and Highway/Byway cost split intact. Even in this leading framework FERC finds only two real gaps: no requirement to evaluate alternative transmission technologies, and no pro forma terms to ‘memorialize ongoing operational requirements in a transmission service agreement.’ The remaining ask is a mechanism to credit large-load payments back through transmission owners’ revenue requirements.
What FERC presses SPP on
- A mechanism to credit large-load cost-recovery payments toward transmission owners’ revenue requirements (Ordering (B)(1)(b)).
- Evaluating alternative transmission technologies in all instances without a customer request — and, if conventional upgrades are chosen instead, justifying why (P 46).
Quoted directives, with page cites
Each quotation below is verbatim from the committed order text and links to the page it appears on. A test asserts every one of them against the extracted source.
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Alternative tech + operational terms Ordering (B)(1)(a)
“require the evaluation of alternative transmission technologies, and memorialize ongoing operational requirements in a transmission service agreement”
-
Evaluate alt tech by default P 46
“in all instances, without the need for a request from the Eligible Customer seeking transmission service on behalf of large load”
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Cost-recovery + crediting Ordering (B)(1)(b)
“establish a mechanism to ensure such payments are appropriately credited toward transmission owners’ transmission revenue requirements”
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Co-location service Ordering (B)(1)(c)
“address the rates, terms, and conditions of service that apply to co-location arrangements”
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New services for flexible loads Ordering (B)(1)(d)
“transmission services that reflect Eligible Customers taking transmission service on behalf of co-located loads, load with behind the meter generation, and flexible large loads”
Region-specific findings
The order adopts SPP’s own HILL (High Impact Large Load) definition as its definition of ‘large load,’ and treats ‘flexible’ loads as the HILL subset not co-located with generation and willing to limit withdrawals. PP 4, 6 n.16
“not co-located with generation”
FERC commends SPP’s already-approved HILL study process and HILLGA (High Impact Large Load Generation Assessment, accepted Jan. 14, 2026, 194 FERC ¶ 61,031), which expedites generation serving an electrically proximate HILL. PP 15-18
“High Impact Large Load Generation Assessment”
SPP’s Conditional HILL Service (CHILLS, accepted June 5, 2026) is an as-available, non-firm, 7-year-max service, curtailable until firm service is available. P 17
“Conditional High Impact Large Load Service”
FERC points SPP to its under-development Price Adaptive Load Service (PALS) — a non-firm option for price-sensitive flexible loads — and its Highway/Byway (Attachment J) cost-allocation process as the existing baseline. PP 19-21
“Price Adaptive Load Service”
Even in this leading framework FERC finds only two gaps: no requirement to evaluate alternative transmission technologies, and no pro forma terms memorializing operational requirements in a transmission service agreement. P 27
“memorialize ongoing operational requirements in a transmission service agreement”
SPP’s baseline study is Attachment Z1 (Aggregate Transmission Service Study) plus Attachments AQ (Delivery Point Assessment) and AX (Provisional Load Process); the HILL process layers enhanced study on top of these. pp. 17-19
“Aggregate Transmission Service Study”
Its Highway/Byway cost allocation (Attachment J) splits Network-Upgrade costs by voltage: 300 kV and above region-wide (postage stamp), 100 to 300 kV one-third regional / two-thirds subregional, and 100 kV and below fully local. pp. 17
“for facilities at 300 kV or above”
What the public comment record says about SPP
37 of the RM26-4 record's public comments name-check SPP specifically (14 support · 3 oppose · 2 mixed · 18 neutral). That's a floor, not a full count: only about 40% of the corpus carries a region tag at all, so a comment that discusses SPP without the audit pass catching a region-specific mention won't appear here.
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American Electric Power Service Corporation support
“The Commission should support regional efforts to move towards consolidated, integrated planning, like SPP's CPP.” p. 19
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Arkansas Public Service Commission oppose
“the proposed rule is unnecessarily harmful for Arkansas and risks disrupting well‑functioning regional and state processes.” p. 1
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Antora Energy, Inc. mixed
“Highly flexible large loads face substantial interconnection barriers where, as in SPP, the RTO requires a one-to-one matching of non-coincident peak demand with new Designated Network Resources (DNRs).” p. 3
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Duke Energy Corporation neutral
“Duke Energy recognizes that there may be opportunities to identify 'bridge' solutions for limited, temporary interconnection service rights without eliminating the need for full interconnection service studies that identify the need for long-term infrastructure expansion.” p. 20
See all 37 comments about SPP →
Section IV briefing questions
This order poses its briefing questions at page 51 of the committed PDF: open at § IV. The questions are templated across the six show cause orders; the full set, and what the public record says on each, is in the comment record.
Respondents named in the order
AEP Oklahoma Transmission Company, Inc. · AEP Southwestern Transmission Company, Inc. · Deseret Generation & Transmission Co-operative, Inc. · Empire District Electric Company · Evergy Kansas Central, Inc. · Evergy Kansas South, Inc. · Evergy Metro, Inc. · Evergy Missouri West, Inc. · GridLiance High Plains LLC · ITC Great Plains, LLC · Mountrail-Williams Electric Cooperative · NextEra Energy Transmission Southwest, LLC · NorthWestern Energy Public Service Corporation · Oklahoma Gas and Electric Company · Prairie Wind Transmission, LLC · Public Service Company of Oklahoma · Southwestern Electric Power Company · Southwestern Public Service Company · Transource Missouri, LLC · Transource Oklahoma, LLC · Tri-State Generation and Transmission Association, Inc. · Upper Missouri G. & T. Electric Cooperative, Inc.
The other dockets
E-7 PJM · E-8 MISO · E-10 CAISO · E-11 ISO-NE · E-12 NYISO · E-2 PJM
Return to the full briefing: the timeline, the five reform categories, the procedural clock, and the 273-comment RM26-4 record.