{"document":{"slug":"motion-el26-68-spp-abeyance","title":"SPP requests more time to answer the June 18 show cause order","issued":"2026-08-03","accession":"20260803-5209","docket":"EL26-68-000","group":"SPP filings","filer":"Southwest Power Pool, Inc.","kind":"motion for abeyance","file":"sources/originals/20260803-5209_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5209","sha256":"3d38654a3a352a4dab6dc643698f39a26c667630a216409a926ccae29977a3f8","pages":23,"tokens":5559,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":237,"text":"1 \nUNITED STATES OF AMERICA \nBEFORE THE  \nFEDERAL ENERGY REGULATORY COMMISSION \nSouthwest Power Pool, Inc. \n ) \n  \nDocket No. EL26-68-000 \nJOINT MOVANTS’ MOTION \nTO HOLD SECTION 206 PROCEEDING IN ABEYANCE \nSouthwest Power Pool, Inc. (“SPP”), American Electric Power Service \nCorporation, Evergy, Inc., GridLiance High Plains LLC, ITC Great Plains, LLC, \nMountrail-Williams Electric Cooperative, NextEra Energy Transmission Southwest, LLC, \nNorthwestern Energy, Upper Missouri G. & T. Electric Cooperative, Inc. d/b/a Upper \nMissouri Power Cooperative, Oklahoma Gas and Electric Company, and Tri-State \nGeneration and Transmission Association, Inc.  (collectively known as “Joint Movants”), \npursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy \nRegulatory Commission (“Commission”), respectfully move the Commission to (i) hold \nthis proceeding, including the deadline for responding to the briefing questions, in \nabeyance for ninety-five (95) days, up to and including November 20, 2026; and (ii) \nestablish a five (5) day answer period and act on this Motion as expeditiously as practicable \nthereafter. 1  \nI.\nINTRODUCTION\nOn June 18, 2026, the Commission issued an order instituting a proceeding under\nSection 206 of the Federal Power Act (“FPA”) concerning large loads (“Show Cause \nOrder”).2  In the Show Cause Order, the Commission preliminarily found that the existing \n1\nDeseret Generation & Transmission Co-operative, Inc. (“Deseret”) is not joining as a Joint \nMovant, but Deseret has informed SPP that it does not object to this Motion. \n2\nSw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026)."},{"page":2,"startToken":237,"endToken":442,"text":"2 \n \nSPP Open Access Transmission Tariff (“Tariff”)3 governing service to large loads appeared \nto be unjust, unreasonable, or unduly discriminatory or preferential.4 The Commission \ndirected SPP and the jurisdictional Transmission Owners, within sixty (60) days of the \nissuance of the Show Cause Order, to either: \n1. Show cause why the Tariff remains just and reasonable and not unduly \ndiscriminatory or preferential notwithstanding the absence of provisions that: \na. require the evaluation of alternative transmission technologies and \nmemorialize ongoing operational requirements in a transmission service \nagreement between SPP and the Transmission Customer taking \ntransmission service on behalf of a large load; \nb. provide additional transparency regarding Network Upgrade costs, establish \na pro forma cost recovery agreement to mitigate the risk of cost shifting, \nand ensure appropriate crediting of such payments toward Transmission \nOwners' transmission revenue requirements; \nc. address the rates, terms, and conditions applicable to interconnection \ncustomers serving co-located loads; and \nd. address transmission service for co-located loads, load served by Behind-\nThe-Meter Generation, and flexible large loads willing and able to limit \ntheir use of the transmission system under certain conditions; or \n \n3  \nSouthwest Power Pool, Inc., Open Access Transmission Tariff, Sixth Revised Volume No. \n1. \n4  \nShow Cause Order at P 3."},{"page":3,"startToken":442,"endToken":736,"text":"3 \n2. explain what revisions to the Tariff would remedy the Commission's identified\nconcerns should the Commission determine that the Tariff has become unjust and\nunreasonable or unduly discriminatory or preferential and therefore establish\nreplacement Tariff provisions.5\nThe Show Cause Order expressly contemplates an abeyance to permit SPP and its\nstakeholders to develop proposed Tariff revisions to address the identified concerns. \nSpecifically, the Commission states that it: \nwill consider requests from SPP and/or the Transmission \nOwners to hold, for up to 90 days, all or certain aspects of this \nFPA section 206 proceeding in abeyance, including the \ndeadline to respond to this order. Any such abeyance, which \nwill begin as of the deadline to respond to this order, would \nbe considered to provide SPP and the Transmission Owners \ntime while they work through the stakeholder processes to \ndevelop FPA section 205 filings to revise the Tariff to address \nthe issues raised in this order.6 \nJoint Movants respectfully request that the Commission hold this proceeding in \nabeyance for ninety-five (95) days, up to and including November 20, 2026. Joint Movants \nacknowledge that the requested abeyance exceeds the ninety (90) days contemplated by \nthe Show Cause Order. The additional five (5) days is necessary to accommodate SPP’s \nfull stakeholder process, which culminates in a scheduled Board of Directors (“Board”) \nmeeting,7 as further discussed in Sections III and V of this Motion. This Motion is timely \n5\nId. \n6\nId. at P 33. \n7\nThis Board of Directors meeting time has already been adjusted to avoid conflicts with \nElection Day and Nation Association of Regulatory Utility Commissioners (“NARUC”) \nannual meeting dates. Avoiding widespread conflicts to allow meeting participants to more \nfully prepare and focus on meetings is important for robust and meaningful participation."},{"page":4,"startToken":736,"endToken":1000,"text":"4 \n \nbecause it is being filed within forty-five (45) days of the issuance of the Show Cause \nOrder.8 \nII. \nGOOD CAUSE EXISTS TO HOLD THIS PROCEEDING IN ABEYANCE  \nGood cause exists to grant the Joint Movants' abeyance request. Granting the \nrequested abeyance will allow SPP to utilize its stakeholder process to develop \ncomprehensive Tariff revisions responsive to the Show Cause Order. The issues identified \nby the Commission involve numerous, interrelated aspects of the Tariff, and developing \nproposed Tariff revisions addressing these issues requires careful technical analysis, \ncoordination among numerous stakeholder groups and membership sectors, and \nconsideration through SPP's governance process before any proposed revisions can be \npresented to the Board for approval and filed with the Commission pursuant to Section 205 \nof the FPA. \nThe requested abeyance also will promote administrative efficiency. Absent an \nabeyance, SPP, Transmission Owners, stakeholders, and the Commission would be \nrequired to simultaneously litigate the issues raised in this Section 206 proceeding while \nSPP conducts the stakeholder process necessary to develop potential Tariff revisions \naddressing those same issues. By contrast, the requested abeyance will allow SPP to focus \nits efforts on developing a comprehensive Section 205 filing or a package of Section 205 \nfilings that responds to the Commission's concerns through its stakeholder process, thereby \npotentially narrowing or resolving issues that otherwise would be litigated in this \nproceeding. In addition, feedback received through the stakeholder process has the \n \n8  \nShow Cause Order at P 33. The Show Cause Order requires any request for abeyance to \nbe filed within forty-five (45) days of the issuance of the Show Cause Order."},{"page":5,"startToken":1000,"endToken":1267,"text":"5 \n \npotential to raise and resolve other technical or legal concerns with the language that will \nmitigate the risk of needing further Tariff change. \nMoreover, the requested abeyance will not prejudice any party. During the limited \nabeyance period, the existing Tariff will remain in effect, and no party's substantive rights \nwill be altered. The requested relief provides the time necessary for SPP to complete the \nstakeholder process the Commission expressly contemplated as the vehicle for developing \npotential Tariff revisions responsive to the Show Cause Order. In addition, it allows SPP \ntime to work with stakeholders and vendors to help avoid technical challenges and achieve \norderly implementation of changes to non-Tariff governing documents, software, \nprocedures, and workflows. \nFinally, granting the requested abeyance serves the public interest because, as \ndiscussed further below, it will allow SPP sufficient time to develop comprehensive, well-\nvetted Tariff revisions through its established stakeholder process rather than requiring \nexpedited proposals that have not benefited from the full consideration contemplated and \nrequired by SPP's governance structure. Accordingly, good cause exists to grant this \nMotion.  \nIII. \nSPP’S STAKEHOLDER PROCESS NECESSITATES ADDITIONAL TIME \nTO DEVELOP TARIFF REVISIONS RESPONSIVE TO THE SHOW \nCAUSE ORDER  \n \nSPP's stakeholder process is the appropriate forum through which potential Tariff \nrevisions responsive to the Commission's concerns should be developed. Consistent with \nthe SPP Bylaws, stakeholder input is developed primarily through SPP's Organizational \nGroups.9 The Markets and Operations Policy Committee (\"MOPC\"), through its designated \n \n9  \nSouthwest Power Pool, Inc., Bylaws, First Revised Volume No. 1, Section 1.0, Definitions \nof Organizational Group (“A group, other than the Board of Directors and the Members"},{"page":6,"startToken":1267,"endToken":1535,"text":"6 \n \nOrganizational Groups, develops and recommends policies and procedures governing the \noperation and administration of the Tariff before those recommendations are considered by \nthe Board.10 Proposed Tariff revisions are developed through SPP's Revision Request \n(“RR”) process and proceed through the appropriate working groups and task forces, where \nstakeholders evaluate draft language, identify operational and implementation concerns, \nrecommend refinements, and develop consensus recommendations before proposals are \nconsidered by MOPC and, ultimately, the Board for authorization to file under Section 205 \nof the FPA. The stakeholder process is particularly important in the context of the Show \nCause Order because it raises issues spanning multiple functional areas of the Tariff and \naffects a broad range of stakeholder interests and implicates many aspects of SPP’s \noperations. The stakeholder process is more than just a series of public meetings on Tariff \nlanguage; it allows for widespread feedback and vetting of process changes whose \nimplementation details are complex to design and effectuate. The iterative nature of SPP's \nstakeholder process ensures that proposed Tariff revisions are informed by the technical, \noperational, commercial, legal, and regulatory expertise of the entities that will be \nresponsible for implementing and operating under those revisions.  \nThe current sixty-day (60) response period does not provide sufficient time to \ncomplete this stakeholder process in a meaningful manner. By contrast, the requested \nninety-five (95) day abeyance will permit, although still on an expedited time frame, SPP \nto convene the necessary stakeholder meetings, develop and refine draft revisions to the \n \nCommittee, comprising a committee or working group that is charged with specific \nresponsibilities toward accomplishing SPP’s mission.”). \n10  \nId. at Section 6.1."},{"page":7,"startToken":1535,"endToken":1784,"text":"7 \n \nTariff and other affected governing documents, solicit and incorporate stakeholder \nfeedback, obtain the approvals required by the SPP Bylaws, and prepare a comprehensive \nfiling under Section 205 of the FPA. Granting the requested abeyance therefore will \nfacilitate the development of more complete, thoroughly vetted Tariff revisions and provide \nthe Commission with a more robust record upon which to evaluate SPP's proposed \nresponse.  \nThe SPP Board was originally scheduled to meet on November 3, 2026. Because \nthis was scheduled for Election Day, the leadership of the Regional State Committee \n(“RSC”), many of whom are elected officials in their state, requested that SPP reschedule \nthe SPP Board’s quarterly meeting to ensure that all of the members of the RSC are able to \nparticipate. The next week, November 10, 2026, was considered for the SPP Board \nmeeting, but that date conflicted with the 2026 NARUC Annual Meeting and Education \nConference.11 Most of the members of the RSC will attend the 2026 NARUC Annual \nMeeting. To accommodate Election Day and the previously scheduled NARUC annual \nmeeting, the SPP Board meeting was scheduled for the following week on November 17, \n2026. SPP acknowledges that its requested abeyance exceeds the ninety (90) days \ncontemplated by the Show Cause Order but submits that the additional five (5) days is \nnecessary to accommodate its full stakeholder process, which culminates in a scheduled \nBoard meeting, and ensures full participation by members of the RSC. \n \n \n \n11  \nNARUC Annual Meeting: https://www.naruc.org/events/all-events/2026-naruc-annual-\nmeeting-and-education-conference/."},{"page":8,"startToken":1784,"endToken":2078,"text":"8 \n \nIV. \nANTICIPATED SECTION 205 FILING \nUnlike a typical request to defer a procedural deadline, the Commission expressly \ndirected respondents seeking abeyance to provide a detailed description of the anticipated \nTariff revisions that would be developed during the requested abeyance period.12 \nConsistent with that directive, this section summarizes the principal subject areas that SPP \npresently anticipates will be developed through its ongoing stakeholder process and \naddressed in a filing under Section 205 of the FPA.13 \nA. \nTransmission Service to Eligible Customers on Behalf of Large Loads \nIn the Show Cause Order, the Commission finds that the Tariff is preliminarily \nunjust and unreasonable because it does not require (1) the evaluation of alternative \ntransmission technologies in transmission service request studies, in all instances, without \nthe need for a request from the Eligible Customer seeking transmission service on behalf \nof a large load; and (2) if traditional Network Upgrades are selected instead of alternative \ntransmission technologies, inclusion in the study report to the Eligible Customer seeking \ntransmission service on behalf of a large load of a sufficiently clear demonstration of why \nalternative transmission technologies are not feasible or would not result in lower costs or \na faster timeline for accommodating the transmission service request.14  \n \n12  \nShow Cause Order at P 33. \n13  \nThese descriptions are necessarily preliminary and are intended to provide the Commission \nwith a good-faith understanding of the anticipated scope of SPP's efforts during the \nrequested abeyance period. SPP continues to work internally and with its stakeholders to \ndetermine the full scope of appropriate Tariff revisions. Accordingly, the descriptions \nbelow should not be construed as an exhaustive or final statement of the Tariff changes that \nmay be included in a future Section 205 filing. \n14  \nShow Cause Order at P 45."},{"page":9,"startToken":2078,"endToken":2448,"text":"9 \n \nSPP recently implemented its High Impact Large Load (\"HILL\")15 process to \nprovide an expedited framework for evaluating transmission service requests associated \nwith large loads.16 Although the HILL Delivery Point Study (“HDPS”) process includes \nenhanced study analyses to ensure that the unique operational characteristics of HILLs are \nconsidered when evaluating the addition of a HILL to the Transmission System, and that \nSPP has mechanisms in place to maintain reliable operation of the Transmission System,17 \nit does not currently require SPP to evaluate alternative transmission technologies when \nstudying HILLs.18 Accordingly, SPP currently anticipates working through its stakeholder \nprocess to develop revisions to incorporate such an evaluation into the study process. \nSPP currently anticipates that this effort will include consideration of the point \nduring the study process in which alternative transmission technologies should be \nevaluated, the technologies that should be considered, and the information that should be \ndocumented in study reports regarding those evaluations. Development of these revisions \nwill require coordinated review and technical analysis by multiple stakeholder groups and \n \n15  \nTariff at Part I, Section 1, defines a HILL as “A new commercial or industrial load, or \nincrease in commercial or industrial load, at a single site connected through one or more \nshared Points of Interconnection (POIs) or delivery points, where such load is either (1) 10 \nMW or more if connected to the Transmission System at a voltage level less than or equal \nto 69 kV; or (2) 50 MW or more if connected to the Transmission System at a voltage level \ngreater than 69 kV. An Electric Storage Resource is not considered a HILL. A load may be \ncategorized as a HILL after the initial effective date of Attachment BA of the Tariff.  High \nImpact Large Loads must register as such in accordance with Attachment AE of the Tariff \nand follow the processes specified in Attachment BA of the Tariff.”. \n16  \nTariff, Attachment BA. \n17  \nTariff, Attachment BA, Section 2.1.3.4. The HDPS is a supplemental assessment, in \naddition to the studies required pursuant to Attachment AQ, Attachment AX, and/or \nAttachment BC of the Tariff, of the impact of a requested HILL delivery point \nconfiguration change on the Transmission System.  \n18  \nId."},{"page":10,"startToken":2448,"endToken":2675,"text":"10 \n \nsubject matter experts and ensure that any proposed revisions do not cause unintended \nimpacts to Commission approved processes addressing interconnection of large loads. \nSecond, the Commission found that the HILL process does not include pro forma \nprovisions in transmission service agreements between SPP and the Transmission \nCustomer taking transmission service on behalf of a HILL that memorialize ongoing \noperational requirements.19 The Commission recognized that these operational \nrequirements do exist in the Tariff but expressed concern that without pro forma provisions \nin the transmission service agreement between SPP and the Transmission Customer, SPP \nmay be unable to enforce the ongoing operational requirements of HILLs.20 \nAccordingly, SPP currently anticipates working through its stakeholder process to \ndevelop revisions to the Tariff's pro forma transmission service agreements, namely the \nNetwork Integration Transmission Service Agreement21 and the Form of Service \nAgreement for Firm Point-To-Point Transmission Service,22 that would incorporate the \napplicable operational requirements for HILLs. Because revisions to the pro forma service \nagreements affect the contractual rights and obligations of Transmission Customers and \nSPP, their development requires stakeholder review and collaboration. \nB. \nCost Shifting Risk Among Transmission Customers \nThe Commission preliminarily found that the Tariff is unjust and unreasonable \nbecause it does not require the public posting, of information regarding transmission \n \n19  \nShow Cause Order at P 46. \n20  \nId. \n21  \nTariff, Attachment F.  \n22  \nTariff, Attachment A."},{"page":11,"startToken":2675,"endToken":2922,"text":"11 \n \nservice requests associated with large loads and the Network Upgrades necessary to \nprovide such service.23 Specifically, the Commission identified the absence of Tariff \nprovisions governing the disclosure of information regarding Network Upgrades driven by \nlarge loads, associated cost estimates, the requesting entity, project status within SPP's \nplanning process, aggregate large load additions, and related transmission planning \ninformation. The Commission acknowledges that SPP provides some information to \nstakeholders regarding the cost of Network Upgrades but that the Tariff does not explicitly \ncontain provisions that require SPP to publicly post estimates for Network Upgrades \nnecessary to provide transmission service to Eligible Customers on behalf of large loads.24 \nSPP anticipates that stakeholders will evaluate development of new Tariff \nprovisions governing the public reporting of transmission planning and transmission \nservice information associated with large loads including (1) the categories of information \nthat should be publicly reported with respect to HILLs; (2) the identification of Network \nUpgrades associated with HILLs; (3) the disclosure of estimated Network Upgrade costs \nassociated with HILLs; (4) reporting regarding aggregate large load additions throughout \nthe SPP footprint and within individual transmission pricing zones; (5) identification of \nproject status within SPP's transmission planning process; (6) the frequency with which \ninformation should be updated; (7) the format in which information should be made \npublicly available; and (8) any necessary confidentiality limitations. Although the \nCommission identified the categories of information it preliminarily believes should be \n \n23  \nShow Cause Order at PP 52-54. \n24  \nId. at P 55."},{"page":12,"startToken":2922,"endToken":3207,"text":"12 \n \npublicly available, substantial stakeholder input remains necessary to determine how those \nreporting requirements should be implemented. \nNext, the Commission finds that the Tariff lacks a pro forma cost recovery \nagreement between SPP, the relevant Transmission Owner, and the Eligible Customer \nserving a large load that requires the Eligible Customer to make a minimum contribution \ntoward the Transmission Owner’s transmission revenue requirement, if the Eligible \nCustomer ultimately takes less transmission service than anticipated because the large load \ndoes not materialize as planned or is not developed at all.25 The Commission also found \nthat the minimum contribution required pursuant to such cost recovery agreement should \nbe based on the level of jurisdictional transmission service requested by the Eligible \nCustomer on behalf of the large load and that such cost recovery agreement should include \na credit support or other financial security requirement sufficient to secure the obligations \nof the Eligible Customer taking transmission service on behalf of a large load to pay the \namounts owed pursuant to the cost recovery agreement.26 \nSPP has initiated a comprehensive stakeholder effort through its Cost Control and \nAllocation Review & Evaluation Team (“CARE Team”)27 to evaluate potential Tariff \nrevisions responsive to the Commission's concerns regarding cost mitigation and cost \n \n25  \nShow Cause Order at PP 61-63. \n26  \nId. at P 65. \n27  \nThe CARE Team was established in November 2025 to serve as a cross-functional \nleadership body to review, evaluate, assess, and recommend refinements or alternatives to \nthe current transmission cost controls and cost allocation methodologies in SPP including \ncost allocation challenges associated with large load growth and related infrastructure \nneeds. See CARE Team Organizational Group Scope Statement (November 2025) located \nat: https://www.spp.org/spp-documents-filings/?id=552360."},{"page":13,"startToken":3207,"endToken":3497,"text":"13 \n \nshifting.28 Stakeholders are presently evaluating multiple alternative approaches to address \nthis specific concern. Although no specific approach has be determined by the CARE \nTeam, the following are some of the alternative approaches being considered: (1) \nestablishment of financial security requirements securing the cost of Base Plan Upgrades \nconstructed to serve large load delivery points; (2) direct assignment, in whole or in part, \nof Network Upgrade costs associated with large load delivery point additions or \nmodifications; (3) combinations of direct assignment and financial security designed to \nsatisfy the Commission's minimum contribution expectations while preserving appropriate \nBase Plan funding principles; (4) other  mechanisms for ensuring a minimum contribution \nfrom Transmission Customers serving large loads; and (5) corresponding revisions \ngoverning the disposition of recovered funds to ensure that any amounts recovered are \napplied to reduce costs otherwise borne by Transmission Customers.  \nWith respect to the financial security framework, stakeholders have already begun \nconsideration of numerous implementation questions including, but not limited to: (1) the \nappropriate amount and form of any required financial security; (2) the period of time that \nshould be allowed for the load to materialize before a claim is made on the financial \nsecurity; (3) how long the load should remain in place in order to avoid a claim on the \nfinancial security; (4) whether the financial security should be assessed in part if the load \nthat materializes is less than predicted; (5) how the delivery point should be quantified for \nthe purpose of assessing a potential claim on security; and (6) whether projected operating \nand maintenance expense of the upgrade should be included in the financial security \n \n28  \nCARE Meeting Materials, dated July 23, 2026, at Agenda Item 7 posted at: \nhttps://www.spp.org/spp-documents-filings/?id=552361."},{"page":14,"startToken":3497,"endToken":3758,"text":"14 \n \nrequirement. With respect to the potential direct charge framework, stakeholders have also \nbegun considering: (1) whether to apply full or partial direct assignment of delivery point \nupgrade costs; (2) if such direct assignment is partial, how the partial direct assignment \nshould be implemented and whether the direct assignment should take the form of capital \ncost only or revenue requirements over a fixed period; and (3) whether a form of minimum \ncharge other than, or in addition to, direct assignment of delivery point costs would be \nappropriate.  \nThese multiple alternatives present significant policy choices that extend far \nbeyond drafting of Tariff language, implicating fundamental cost allocation principles that \nhave governed SPP's transmission planning and funding framework for many years. \nImplementation of the alternatives presently under consideration will require coordinated \nrevisions across multiple components of the Tariff, introducing interrelated policy and \nimplementation issues that underscore the importance of meaningful stakeholder \ndevelopment. \nC. \nCo-Location Arrangements and Load with Behind-The-Meter \nGeneration \n \nThe Commission preliminarily found that the Tariff should provide greater clarity \nregarding the treatment of co-located29 resources and behind-the-meter generation, \nincluding the circumstances under which such resources are subject to the Tariff's \n \n29  \nThe Show Cause Order defines co-located load as a configuration that refers to end-use \ncustomer load that is physically connected to the facilities of an existing or planned \ngenerating facility on the interconnection customer’s side of the point of interconnection \nto the RTO/ISO’s transmission system. In the Show Cause Order, the Commission uses the \nterm co-location arrangement when referring to both the co-located load and the associated \ngenerating facility."},{"page":15,"startToken":3758,"endToken":4003,"text":"15 \n \ntransmission service, interconnection, and market participation requirements.30 The \nCommission expressed concern regarding the absence of Tariff provisions addressing \ntransmission and ancillary service rates for Eligible Customers taking transmission service \non behalf of Eligible Load.31  \nStakeholder development is necessary to determine, among other things, (1) the \nappropriate terminology and definition used to describe generators interconnected to \nfacilities that are not connected to the Transmission System; (2) the study process \napplicable to such generators; and (3) the overlap between transmission service, \ninterconnection, and market registration requirements. Stakeholder coordination is \nessential to development of a comprehensive framework that provides the clarity sought \nby the Commission.  \nD. \nExtending New Transmission Services to Eligible Customers Taking \nService on Behalf of Flexible Large Loads  \n \nThe Commission preliminarily found  the Tariff unjust and unreasonable because it \ndoes not include transmission services that reflect Eligible Customers taking transmission \nservice on behalf of flexible large loads32 that are willing and able to limit their use of the \nTransmission System under certain conditions.33 The Commission required SPP to explain \n \n30  \nShow Cause Order at PP 75-80. \n31  \nId. at PP 77, 80-82. \n32  \nThe Show Cause Order clarifies that, for purposes of the Show Cause Order, “flexible” \nlarge loads are a subset of HILLs that are not co-located with generation but are willing \nand able to limit their energy withdrawals from the Transmission System under certain \nconditions. See Show Cause Order at n.163. \n33  \nShow Cause Order at P 86."},{"page":16,"startToken":4003,"endToken":4249,"text":"16 \n \nwhether the Tariff remains just and reasonable without (1) an interim non-firm network \ntransmission service while Network Upgrades are being constructed (i.e., interim NITS) \nand (2) permanent firm and non-firm contract demand transmission services.34  \nThe Commission expressly noted SPP’s Price Adaptative Load (“PAL”) and Price \nAdaptive Load Service (“PALS”) proposal (collectively “PAL/PALS”), which is currently \nunder stakeholder development, and urged SPP to consider whether PALS would address \nthe Commission’s concern that the Tariff may be unjust and unreasonable because it does \nnot include transmission services that reflect the use of the Transmission System by \nEligible Customers on behalf of flexible large load.35 Unlike traditional transmission \nservice, the PAL/PALS framework would establish both a new market participation model \nand a new non-firm transmission service designed specifically for dispatchable, price-\nresponsive large loads. Under the current proposal, participating loads would submit price-\nsensitive bids into SPP's Integrated Marketplace and would be required to respond to Day-\nAhead Market commitments and Real-Time Balancing Market dispatch instructions. \nCorrespondingly, PALS would establish a new transmission service under which \nparticipating loads would receive transmission service subject to usage-based pricing, \nmandatory dispatchability requirements, and Curtailment during transmission constraints, \nEmergency Conditions, or local reliability events. As explained in SPP’s Informational \nReport,36 the PAL/PALS initiative has already progressed through extensive stakeholder \n \n34  \nId. at P 87. \n35  \nId. at P 88. \n36  \nInformational Report of Southwest Power Pool, Inc., Docket No. EL26-68-000, at 25 \n(July 20, 2026)."},{"page":17,"startToken":4249,"endToken":4496,"text":"17 \n \neducation and preliminary design. SPP anticipates continued stakeholder review over the \nnext several months with formal, with final approval anticipated on November 17, 2026. \nContinued stakeholder review and collaboration is needed before approval of the \nPAL/PALS framework.  \nIn addition to PALS, SPP anticipates stakeholder consideration of revisions to \nexisting transmission service product(s), such as the Conditional High Impact Large Load \nService (CHILLS), to include control technologies and/or protection systems designed to \nlimit energy withdrawals from the Transmission System. Continued stakeholder \ncollaboration is necessary because incorporating control technologies and/or protection \nsystems into existing transmission service products implicates technical, operational, and \npolicy considerations extending well beyond the development of Tariff language.  \nV. \nOVERALL SCHEDULE AND ANTICIPATED SECTION 205 FILING \nTIMELINE \n \nDraft RRs addressing several of the Commission's preliminary findings are \nexpected to be posted for stakeholder review in early August 2026. Throughout the \nrequested abeyance period, the proposals will proceed through technical development, \nstakeholder education, policy discussions, and formal review by the applicable working \ngroups, culminating in working group votes during September and October, MOPC in \nOctober, the RSC where applicable in November, and final Board consideration on \nNovember 17, 2026. SPP anticipates the same timeline for approval and filing of the \nPAL/PALS RR.   \nAccordingly, Joint Movants respectfully request that the Commission hold this \nproceeding in abeyance until November 20, 2026, and establish that date as the deadline \nfor SPP to respond to the Show Cause Order through a comprehensive filing under Section"},{"page":18,"startToken":4496,"endToken":4853,"text":"18 \n \n205 of the FPA. A ninety-five (95) day abeyance is necessary because the Board must \nprovide final authorization for the Section 205 filing described herein and is not scheduled \nto meet until November 17, 2026.37 Following Board authorization, SPP requires a brief \nperiod to finalize and submit the resulting Section 205 filing(s) to comply with the Show \nCause Order. \nVI. \nREQUEST \nFOR \nSHORTENED ANSWER \nPERIOD, \nEXPEDITED \nCOMMISSION ACTION, AND REQUEST FOR ABEYANCE OF THE \nDEADLINE TO RESPOND TO THE BRIEFING QUESTIONS \n \nJoint Movants respectfully request that the Commission establish a five (5) day \nperiod for answers to this Motion38 and act as expeditiously as practicable thereafter. As \nthe Commission recognized in the Show Cause Order, requests for abeyance must be filed \nsufficiently in advance of the August 17, 2026, response deadline to allow the Commission \nadequate time to act before that deadline expires. Prompt action on this Motion will provide \nSPP and its stakeholders with certainty regarding the applicable timeline and avoid the \nneed to simultaneously prepare both a response to the Show Cause Order and the \nanticipated Section 205 filing. Absent timely action, SPP would be required to devote \nsubstantial resources to preparing filings that may ultimately prove unnecessary if the \nrequested abeyance is granted. Expedited consideration therefore will promote \n \n37  \nThe Board’s regularly scheduled meetings occur quarterly and are scheduled many months \nin advance. This Board of Directors meeting time has already been adjusted to avoid \nconflicts with Election Day and NARUC meeting dates. Avoiding widespread conflicts to \nallow meeting participants to more fully prepare and focus on meetings is important for \nrobust and meaningful participation. \n38  \nTo the extent necessary, SPP requests waiver of Rule 213 of the Commission’s Rules of \nPractice and Procedure, 18 C.F.R.§ 385.213, which provides that an answer to a motion \nmust be filed within 15 days, unless otherwise ordered. The Show Cause Order requires \nabeyance requests to be filed by August 3, 2026, and expressly contemplates that the \nCommission will issue an order on any such request prior to the response deadline of \nAugust 17, 2026 (14 days after the abeyance request deadline)."},{"page":19,"startToken":4853,"endToken":5090,"text":"19 \nadministrative efficiency and further the purpose for which the Commission authorized \nparties to seek an abeyance. \nIn addition, because the Show Cause Order establishes a single deadline for both \nJoint Movants' response and their responses to the accompanying briefing questions, Joint \nMovants respectfully request that any order granting this Motion also apply to and defer \nthe deadline to submit responses to the briefing questions proposed in the Show Cause \nOrder. The briefing questions seek Joint Movants' views regarding the very Tariff revisions \nand policy determinations currently under stakeholder development. Accordingly, \nresponses submitted following completion of that process will provide the Commission \nwith a more complete and useful record than preliminary responses prepared before \nstakeholders have developed the comprehensive Tariff revisions contemplated in this \nMotion. \nVII.\nCONCLUSION\nFor the reasons stated herein, Joint Movants respectfully request the Commission:\n(1) Grant this Motion and hold the above-captioned proceeding in abeyance for\nninety-five (95) days, up to and including November 20, 2026, to permit SPP to complete \nits stakeholder process and submit a comprehensive filing under Section 205 of the FPA \naddressing the Commission's preliminary findings in the Show Cause Order; \n(2) Find that, if the requested abeyance is granted, the deadline for Joint Movants’\nresponses to the briefing questions accompanying the Show Cause Order likewise are held \nin abeyance and deferred to November 20, 2026; \n(3) Establish a five (5) day period for answers to this Motion; and"},{"page":20,"startToken":5090,"endToken":5248,"text":"20 \n(4) Act on this Motion as expeditiously as practicable following the close of the\nanswer period. \nRespectfully submitted, \n/s/ Meredith Powell  \n/s/ Shannon M. Heim \nShannon M. Heim \nGeneral Counsel, Vice President – Federal \nGovernment Affairs & FERC Compliance \nOfficer \nNorthWestern Energy \n208 N. Montana Ave., Suite 200 \nHelena, MT 59601 \nAttorney for NorthWestern Energy \n/s/ C. Patrick Woods \nC. Patrick Woods\nPresident\nITC Great Plains, LLC\n3500 SW Fairlawn Rd., Ste. 101\nTopeka, KS 66614\nOn Behalf of ITC Great Plains, LLC \nMeredith Powell \nJustin A. Hinton \nEmon O. Mahony \nSouthwest Power Pool, Inc. \n201 Worthen Drive \nLittle Rock, AR 72223 \nAttorneys for \nSouthwest Power Pool, Inc. \n/s/ John C. Crespo \nSenior Legal Counsel \nAmerican Electric Power Service \nCorporation \n1 Riverside Plaza, 29th Floor \nColumbus, OH 43215 \nAttorney for American Electric \nPower Service Corporation \n/s/ Denise Buffington \nDenise Buffington \nSenior Director Federal Regulatory \nAffairs EVERGY, INC. \n1200 Main St. \nKansas City, MO 64105 \nOn Behalf of EVERGY, INC."},{"page":21,"startToken":5248,"endToken":5469,"text":"21 \n \n \n \n/s/ Carly Masenthin \nCarly Masenthin \nCorporate Counsel  \nEVERGY, INC. \n818 S Kansas Avenue \nTopeka, Kansas 66612 \n \nAttorney for EVERGY, INC. \n \n/s/ Travis M. Contratto \nTravis M. Contratto \nPrincipal Attorney \nNextEra Energy, Inc. \n801 Pennsylvania Avenue NW \nSuite 220 \nWashington, DC 20004 \n \nAttorney for NextEra Energy \nTransmission Southwest, LLC and \nGridLiance High Plains LLC \n \n/s/ A. Chase Snodgrass \nA. Chase Snodgrass, OBA No. 33275 \nSenior Regulatory Attorney \nOklahoma Gas and Electric Company \n321 N. Harvey Ave. M/C 300 \nOklahoma City, OK 73102 \n \nAttorney for Oklahoma Gas and \nElectric Company \n \n/s/ Allison E. S. Salvia \nAllison E. S. Salvia \nEversheds Sutherland (US) LLP \n700 Sixth St., N.W., Suite 700 \nWashington, DC 20001-3980 \n \nAttorney for Upper Missouri Power \nCooperative \n/s/ Michael A. Monson \nMichael A. Monson \nBillstein, Monson & Small PLLC \n1555 Campus Way, Suite 201 \nBillings, MT 59102 \n \nAttorney for Upper Missouri Power \nCooperative \n \n/s/ Jeremy Mahowald \nJeremy Mahowald \nGeneral Manager \nUpper Missouri Power Cooperative \n111 2nd Ave. SW \nSidney, MT 59270 \n \nOn Behalf of Upper Missouri Power \nCooperative  \n \n/s/ Jesse Halpern \nJesse Halpern \nThompson Coburn LLP \n1909 K Street, N.W. \nSuite 600 \nWashington, D.C. 20006 \n \nCounsel for Montrail-Williams Electric \nCooperative \n \n \n \n/s/ Ryan Hubbard \nVice President, Transmission Planning \nPolicy \nTri-State Generation & Transmission \nAssociation, Inc. \n1100 West 116th Avenue  \nWestminster, CO 80234  \n \nOn Behalf of Tri-State Generation & \nTransmission Association, Inc."},{"page":22,"startToken":5469,"endToken":5498,"text":"22 \n \n \n \n/s/ Tyler Nemkov \nSenior Regulatory Attorney \nTri-State Generation & Transmission \nAssociation, Inc. \n1100 West 116th Avenue  \nWestminster, CO 80234  \n \nAttorney for Tri-State Generation & \nTransmission Association, Inc. \n \n \n \n \n \nAugust 3, 2026"},{"page":23,"startToken":5498,"endToken":5559,"text":"23 \n \nCERTIFICATE OF SERVICE \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \n \nDated at Little Rock, Arkansas, this 3rd day of August, 2026. \n \n /s/ Cassie Butler \nCassie Butler \nSouthwest Power Pool, Inc. \n201 Worthen Drive \nLittle Rock, AR 72223-4936 \n(501) 614-3200"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1140,"startToken":0,"endToken":158},{"p":1,"at":1140,"title":"I. INTRODUCTION","method":"printed heading","endPage":1,"endAt":1143,"startToken":158,"endToken":159},{"p":1,"at":1143,"title":"INTRODUCTION","method":"printed heading","endPage":4,"endAt":103,"startToken":159,"endToken":755},{"p":4,"at":103,"title":"II. GOOD CAUSE EXISTS TO HOLD THIS PROCEEDING IN ABEYANCE","method":"printed heading","endPage":5,"endAt":1249,"startToken":755,"endToken":1176},{"p":5,"at":1249,"title":"III. SPP’S STAKEHOLDER PROCESS NECESSITATES ADDITIONAL TIME","method":"printed heading","endPage":8,"endAt":5,"startToken":1176,"endToken":1785},{"p":8,"at":5,"title":"IV. ANTICIPATED SECTION 205 FILING","method":"printed heading","endPage":8,"endAt":533,"startToken":1785,"endToken":1861},{"p":8,"at":533,"title":"A. Transmission Service to Eligible Customers on Behalf of Large Loads","method":"printed heading","endPage":10,"endAt":1338,"startToken":1861,"endToken":2628},{"p":10,"at":1338,"title":"B. Cost Shifting Risk Among Transmission Customers","method":"printed heading","endPage":14,"endAt":1095,"startToken":2628,"endToken":3647},{"p":14,"at":1095,"title":"C. Co-Location Arrangements and Load with Behind-The-Meter","method":"printed heading","endPage":15,"endAt":826,"startToken":3647,"endToken":3863},{"p":15,"at":826,"title":"D. Extending New Transmission Services to Eligible Customers Taking","method":"printed heading","endPage":17,"endAt":886,"startToken":3863,"endToken":4363},{"p":17,"at":886,"title":"V. OVERALL SCHEDULE AND ANTICIPATED SECTION 205 FILING","method":"printed heading","endPage":18,"endAt":378,"startToken":4363,"endToken":4558},{"p":18,"at":378,"title":"VI. REQUEST","method":"printed heading","endPage":19,"endAt":908,"startToken":4558,"endToken":4978},{"p":19,"at":908,"title":"VII. CONCLUSION","method":"printed heading","endPage":19,"endAt":913,"startToken":4978,"endToken":4979},{"p":19,"at":913,"title":"CONCLUSION","method":"printed heading","endPage":20,"endAt":404,"startToken":4979,"endToken":5148},{"p":20,"at":404,"title":"C. Patrick Woods","method":"printed heading","endPage":23,"endAt":6,"startToken":5148,"endToken":5499},{"p":23,"at":6,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":23,"endAt":396,"startToken":5499,"endToken":5559}]}