Read topic-matched comments in EL26-68
Topics in the text: Cost allocation · Connecting load and generation · Filing procedure
Commissioner Lindsay See · Direct response
See said the federal changes should give states better information about wholesale costs so they could carry out their own affordability duties. She cautioned against using federal tariff reform to override state decisions.
PDF pp. 77–79, See concurrencePrinted headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Cost allocation
195 FERC ¶ 61,213 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Laura V.Read this passage
printed heading · Topic match: Connecting load and generation
See infra P 15. 8 We note that SPP’s Tariff does not have a formal definition of “co-located load” or “co-location arrangement.” As discussed below, for the purposes of HILLGA, the generating facility only must be in close electrical proximity.Read this passage
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I.Read this passage
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BackgroundRead this passage
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EL26-68-000 - 9 - that it was clear that additional “action is warranted to support further progress where it is needed.”24 In response to the ANOPR, SPP states that it is facing significant operational, planning, and market challenges in response to unprecedented growth in large and non-…Read this passage
PDF bookmark · Topic match: Filing procedure
It is in this context, and in recognition of SPP’s recent reforms to implement a new process for studying requests for Eligible Customers taking transmission service on behalf of large loads and a new conditional, non-firm transmission service for Eligible Customers taking transmission service on…Read this passage Filed comments: Filing procedure
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PJM Co-Location Proceedings On February 20, 2025, the Commission initiated a show cause proceeding against PJM and the PJM transmission owners regarding the lack of tariff provisions addressing with sufficient clarity or consistency the rates, terms, and conditions of service that apply to…Read this passage Filed comments: Filing procedure
PDF bookmark · Topic match: Connecting load and generation
P 32 (explaining that SPP will grant HILLGA customers a new type of interconnection service, load limited resource interconnection service, which grants limited interconnection service solely to serve the associated HILL). 58 Id.Read this passage
PDF bookmark · Topic match: Reliability and curtailment
P 64. 64 SPP CHILLS Order, 195 FERC ¶ 61,196 at P 1. 65 Id.Read this passage
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II.Read this passage
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Pursuant to the Tariff, an interconnection customer may request, and SPP may provide, interim interconnection service prior to the completion of requisite Interconnection Facilities, Network Upgrades, Distribution Upgrades, or System Protection Facilities.89 The scope of the interim availability…Read this passage
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As such, and as the Commission explained in the April Order Regarding Intent to Act, we find that the Commission must now take further action to ensure that SPP promptly proposes revisions to ensure that its Tariff remains just and reasonable.Read this passage
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III.Read this passage
printed heading · Topic match: Filing procedure
We emphasize that we will not grant such abeyances reflexively, that any abeyance will be limited to 90 days, and that we will look with great disfavor toward requests to extend the abeyance period.Read this passage Filed comments: Filing procedure
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Transmission Service to Eligible Customers on Behalf of Large Loads As noted above, the Commission recently approved revisions to SPP’s Tariff that established an enhanced process for SPP to study the provision of transmission service to Eligible Customers on behalf of HILLs and help to ensure that…Read this passage Filed comments: Filing procedure
PDF bookmark · Topic match: Retail and wholesale authority
Specifically, we find that it is within the Commission’s exclusive authority to ensure that transmission provider and/or transmission owner tariffs include sufficiently clear and consistent provisions governing how transmission service to Eligible Customers on behalf of large loads interconnecting…Read this passage
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This transparency and informational requirement is warranted for the regulatory scheme we are establishing for transmission service requests by Eligible Customers on behalf of large loads given demand from and the expedited development timelines for large load customers.Read this passage
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Cost Shifting Risk Among Transmission Customers We next preliminarily find that SPP’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…Read this passage
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To fulfill its responsibility to ensure that transmission rates are just and reasonable, the Commission must act to address the risk of cost shifting among transmission customers due to (1) the process transmission providers and/or transmission owners use to evaluate the facilities needed, and the…Read this passage
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As an initial matter, we note that SPP has taken numerous steps to connect large loads to the transmission system in a reliable and expeditious manner and to enhance its study and operational requirements related to provision of transmission service to Eligible Customers on behalf of large…Read this passage
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EL26-68-000 - 37 - entity taking wholesale transmission service and its retail customers, it fails “to provide any mechanism to protect other wholesale transmission customers” from stranded transmission costs.130 The Kansas Commission states that while its Large Load Power Services rate plan that…Read this passage
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See infra P 72. 139 PJM Co-Location Order, 193 FERC ¶ 61,217 at P 2; PJM Co-Location Rehearing Order, 195 FERC ¶ 61,209 at PP 91, 102. 140 We note that SPP does not allow Eligible Customers taking transmission service on behalf of loads with behind the meter generation to reduce their transmission…Read this passage Filed comments: Filing procedure
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Definition The PJM Co-Location Order adopted the following definition of co-located load: a “configuration [that] refers to end-use customer load that is physically connected to the facilities of an existing or planned Customer Facility on the Interconnection Customer’s side of the Point of…Read this passage Filed comments: Filing procedure
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As we explained in the PJM Co-Location Order, states retain exclusive authority over the specific terms of retail sales and retail rate design, including retail cost allocation to the co-located load; which entities are legally permitted to provide electricity to retail customers in co-location…Read this passage
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Additionally, in the PJM Co-Location Order, the Commission found that it was necessary to clarify that interconnection customers seeking to use new generating facilities to serve co-located load may (1) request interconnection service at a level below the generating facility’s maximum facility…Read this passage Filed comments: Filing procedure
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Finally, we note that the Commission has found it just and reasonable that, in order for an Eligible Customer to take interim NITS, firm contract demand transmission service, and non-firm contract demand transmission service, an Eligible Customer must have necessary control technologies and/or…Read this passage Filed comments: Filing procedure
PDF bookmark · Topic match: Reliability and curtailment
In particular, SPP’s HILLGA process and Expedited Resource Adequacy Study (ERAS) process provide generator interconnection customers the opportunity to be studied and interconnect to SPP’s transmission system more quickly in order to help ensure load serving entities are able to meet resource…Read this passage Filed comments: Filing procedure
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We find that there may be a variety of possible approaches to protect customers from significant cost shifts associated with Network Upgrades triggered by large loads.Read this passage Filed comments: Filing procedure
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Overview of Today’s Orders In each of today’s orders to show cause, the Commission identifies a series of issues raised by the ongoing growth of large loads, directs briefing on whether existing tariffs remain just and reasonable in light of those developments, and describes possible solutions to…Read this passage
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The Commission Needs Good Records to Ensure Reasoned Decision-Making I first want to emphasize that the Commission needs active participation from interested stakeholders to develop thorough records in each region.Read this passage
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As we develop the new infrastructure, many have raised concerns about whether these costs are being fairly assigned to new and existing customers, whose benefits must be commensurate with the costs they pay.Read this passage
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While it is important to identify innovative solutions that can adapt to the needs of the system, the Commission and grid operators must also be careful not to implement changes that create unforeseen reliability risks.Read this passage
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The Orders Recognize the Importance of Evaluating Advanced Transmission Technologies Lastly, today we preliminarily find that each RTO/ISO’s tariff is unjust and unreasonable because the tariff lacks clear and consistent provisions requiring the evaluation of alternative transmission technologies…Read this passage
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VI.Read this passage
printed heading · Topic match: Cost allocation
While this is a long journey, even so, we must continue to move at breakneck pace to win the AI race.Read this passage