EL26-68-000 · 2026-08-07 · Missouri Public Service Commission

Comments of the Public Service Commission of the State of Missouri in support of Southwest Power Pool, Inc.'s et al. request for abeyance filed 08/03/2026

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
 
 
 
 
) 
Southwest Power Pool, Inc.  
 
) 
Docket No. EL26-68-000 
 
 
 
 
 
 
) 
 
COMMENTS OF THE PUBLIC SERVICE COMMISSION OF THE STATE OF 
MISSOURI IN SUPPORT OF THE JOINT MOVANTS’ REQUEST FOR ABEYANCE 
 
 
Pursuant to Rule 20081 and the Notice Establishing Answer Period issued in this docket 
on August 4, 2026, by the Federal Energy Regulatory Commission (Commission or FERC), the 
Public Service Commission of the State of Missouri (Missouri PSC) hereby submits these 
comments in support of the request for abeyance filed by the Southwest Power Pool, Inc. (SPP) 
and various transmission owners (collectively, Joint Movants) on August 3, 2026. 
I.  Summary of Comments 
 
The Commission should grant the Joint Movants’ request for a 95-day abeyance in order 
to accommodate SPP’s stakeholder process.  Although the Commission said it will disfavor a 
request for an abeyance exceeding 90 days, SPP’s Board of Directors meeting is scheduled for 
November 17, 2026—one day outside the 90-day window.  The Joint Movants’ requested 95-day 
abeyance will allow SPP to complete its stakeholder and approval process for its compliance 
filing in this docket, including input from state regulators.  The requested abeyance will allow 
SPP’s stakeholder community adequate time to address important issues highlighted by the 
Commission and represents only a de minimus extension beyond the Commission’s 90-day 
timeline.  Therefore, the Joint Movants demonstrated good cause for the requested abeyance and 
it should be granted. 
 
1 18 C.F.R. § 385.2008.

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II.  Service and Communication 
 
All pleadings, correspondence and other communications related to this proceeding  
 
should be directed to: 
 
Rodney Massman 
John D. Borgmeyer 
General Counsel 
Asst. General Counsel-Regulation 
Public Service Commission of the                 Public Service Commission of the 
State of Missouri 
 
 
              State of Missouri 
P.O. Box 360  
P.O. Box 360  
 
  
 
Jefferson City, MO 65102 
Jefferson City, MO 65102 
(573) 751-7510 
(573) 751-7504 
              rodney.massman@psc.mo.gov 
john.borgmeyer@psc.mo.gov 
 
 
III.  Background 
 
The Missouri PSC is a “state commission” as defined in Section 1.101(k) of the 
Commission’s Rules of General Applicability.2  Missouri law authorizes the Missouri PSC to 
regulate rates, charges and terms of service for the sale and distribution of electricity by public 
utilities to consumers in the state.3  The Missouri PSC is an active member of the SPP Regional 
State Committee (RSC). 
 
The Commission issued its Order Instituting Proceeding Under Section 206 of the 
Federal Power Act (Show Cause Order) in this docket on June 18, 2026.4  The Commission 
made a preliminary finding that SPP’s existing tariff appears to be unjust, unreasonable, or 
unduly discriminatory or preferential in that it lacks certain provisions.5  The Commission 
recognized and applauded the steps SPP and its stakeholders have already taken to address the 
addition of large and co-located loads to the transmission system.6  The Commission also noted, 
 
2 18 C.F.R. 1.101(k). 
3 Section 386.250 Revised Statutes of Missouri (RSMo)(2016). 
4 195 FERC ¶ 61,213 (June 18, 2026). 
5 Show Cause Order at P. 3. 
6 Id. at P. 2.

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however, that SPP had not yet proposed tariff revisions to address all the challenges associated 
with integrating these loads into its system. 
 
In the Show Cause Order, the Commission said it will consider requests from SPP and/or 
its transmission owners to hold this proceeding in abeyance for up to 90 days.7  The Commission 
said it will not grant such abeyances reflexively, and it “will look with great disfavor” upon 
requests for abeyance beyond the 90-day period.8  Successful requests must include a robust 
description of a future compliance filing and a reasoned and specific explanation of when the 
compliance filing will be made.9 
 
On August 3, 2026, the Joint Movants filed a request for abeyance.10  The Joint Movants 
asked to hold the proceedings in abeyance for 95 days, up to and including November 20, 2026.  
The additional five days is necessary to accommodate SPP’s full stakeholder process, 
culminating in a Board of Directors meeting scheduled for November 17, 2026. 
IV.  Comments of the Missouri PSC 
 
The Joint Movants have demonstrated good cause for the requested 95-day abeyance.  
Commission Rule 2008 provides that “the time by which any person is required… to act under 
any… order may be extended by the decisional authority for good cause, upon a motion made 
before the expiration of the period prescribed… .”  On April 14, 2025, for example, the 
Commission granted SPP a 12-month extension of time to submit filings in compliance with the 
Commission’s Order No. 1920 to accommodate its comprehensive stakeholder process.11  
Similar good cause exists to grant the much more limited 95-day abeyance requested here. 
 
7 Id. at P. 33. 
8 Id. 
9 Id. 
10 Docket No. EL26-68, Joint Movants’ Amended Motion To Hold Section 206 Proceeding in Abeyance, Accession 
No. 20260803-5265 (August 3, 2026) (Joint Motion). 
11 Docket RM21-17, Notice of Extension of Time, Accession No. 20250414-3017 (April 14, 2025).

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The issues identified by the Commission involve numerous interrelated aspects of SPP’s 
tariff.  Developing revisions that meet the Commission’s requirements will need careful technical 
analysis and input from the various members and stakeholder groups affected by these changes.  
The requested 95-day abeyance will allow the stakeholders to refine the proposals and present 
them to the SPP Board for full consideration while maintaining the Commission’s expedited 
timeline. 
Issues related to transparency and the avoidance of cost shifting12 are particularly 
important to the Missouri PSC and other state regulators who bear the responsibility of setting 
retail rates that include FERC-jurisdictional transmission costs.  The Missouri PSC is an active 
participant in the RSC13 and the Cost Control and Allocation Review and Evaluation (CARE) 
Team, both of which will play a role in analyzing and refining SPP’s compliance tariff revisions.  
The CARE Team in particular will evaluate potential responses to the Commission’s concerns 
regarding multiple potential approaches to cost mitigation and cost shifting.14  The requested 
abeyance will allow the CARE Team time to complete this important work and present its 
recommendations to the Board. 
Along with these important benefits, the requested 95-day extension represents only a 
minor extension of the Commission’s preferred 90-day extension timeline.  As the Commission 
noted in its Show Cause Order, SPP and its stakeholders have been national leaders in 
developing new approaches to integrating large loads into the transmission system.  Allowing 
SPP and its stakeholders additional time to fully evaluate and approve the remaining work will 
 
12 Show Cause Order at P. 3. 
13 The RSC holds primary responsibility for cost allocation and the approach to resource adequacy across the entire 
region.  SPP Bylaws Section 7.2. 
14 Joint Motion at pgs. 12-13.

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ultimately save administrative resources, promote durable solutions, and will not unduly delay 
this proceeding. 
V. Conclusion 
 
The Missouri PSC respectfully submits these comments in support of the Joint Movants’ 
request for a 95-day abeyance of this Section 206 proceeding. 
 
Respectfully submitted, 
 
/s/ John D. Borgmeyer 
John D. Borgmeyer 
 
 
 
 
 
 
Asst. General Counsel-Regulation 
 
 
 
 
 
 
Public Service Commission of the  
State of Missouri 
 
 
 
 
 
 
P.O. Box 360 
 
 
 
 
 
 
Jefferson City, MO  65102-0360 
573-751-7504 (telephone) 
 
 
 
 
 
 
573-522-4016 (facsimile)  
John.borgmeyer@psc.mo.gov 
 
 
Certificate of Service 
Pursuant to Rule 2010 of the Commission's Rules of Practice and Procedure, I hereby 
certify that I have this day served a copy of the foregoing document on all persons designated on 
the official service list compiled by the Secretary of the Commission in this proceeding by 
electronic service dated on this 7th day of August, 2026. 
/s/ John D. Borgmeyer 
 
 
Jefferson City, Missouri