{"document":{"slug":"report-el26-68-spp","title":"SPP reports on resource adequacy and large-load proposals","issued":"2026-07-20","accession":"20260720-5205","docket":"EL26-68-000","group":"SPP filings","filer":"Southwest Power Pool, Inc.","kind":"informational report","file":"sources/originals/20260720-5205_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260720-5205","sha256":"0081403cc87eb228bdea8473b113039d217a2d248311497c489665f65e33d677","pages":29,"tokens":7097,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":216,"text":"UNITED STATES OF AMERICA \nBEFORE THE  \nFEDERAL ENERGY REGULATORY COMMISSION \nSouthwest Power Pool, Inc.  \n \n ) \n  \nDocket No. EL26-68-000 \n \n \n \n \n \n \n \nINFORMATIONAL REPORT OF  \nSOUTHWEST POWER POOL, INC. \n \nSouthwest Power Pool, Inc. (“SPP”) respectfully submits this Informational Report \nin response to the directive issued by the Federal Energy Regulatory Commission \n(“Commission”) in its June 18, 2026, Order Instituting Proceeding Under Section 206 of \nthe Federal Power Act in Docket No. EL26-68-0001 (“Show Cause Order”). In the Show \nCause Order, the Commission directed SPP to provide, within thirty days, a detailed \ninformational report describing: (1) any proposals under consideration in SPP's stakeholder \nprocess to address resource adequacy associated with new large loads, or, to the extent no \nsuch proposals are under consideration, information regarding how SPP's existing \nprocesses are operating to ensure resource adequacy; and (2) for any new proposals under \ndevelopment, a detailed schedule identifying key stakeholder milestones, including \nanticipated stakeholder and Board actions and the expected date for any future filing with \nthe Commission.2  \nI. \nEXECUTIVE SUMMARY \nSPP appreciates the Commission's recognition that unprecedented growth in \nelectric demand from data centers, advanced manufacturing, industrial electrification, and \nother large load customers presents both opportunities and challenges for the electric \n \n1   \nSw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026) (“Show Cause Order”). \n \n2   \nShow Cause Order at P 91."},{"page":2,"startToken":216,"endToken":449,"text":"2 \nindustry. SPP likewise recognizes the importance of integrating these new loads in a \nmanner that preserves reliability, maintains resource adequacy, and protects existing \ncustomers from unreasonable costs. \nAs large load requests have increased in both number and size, SPP has worked \nwith stakeholders to develop processes that not only evaluate the transmission impacts \nassociated with these customers but also facilitate the timely addition of new generating \nresources capable of serving that demand. Rather than relying on a single solution, SPP has \ndeveloped complementary initiatives that improve planning certainty, accelerate the \naddition of new resources, enhance operational flexibility, strengthen resource adequacy \naccountability, and better align transmission and interconnection processes with the unique \ncharacteristics of emerging large loads. \nAs discussed in greater detail below, these efforts include: \n• \nthe Expedited Resource Adequacy Study (\"ERAS\"), which accelerates evaluation \nof new generating resources intended to support resource adequacy;3  \n• \nthe Provisional Load Process, which allows SPP to study proposed delivery point \nadditions using both existing Designated Resources and identified planned \ngeneration that is expected to serve the new load;4  \n \n3   \nSubmission of Tariff Revisions to Implement the Expedited Resource Adequacy Study of \nSouthwest Power Pool, Inc., Docket No. ER25-2296-000 (May 22, 2025) (“ERAS Filing”). \nTariff, Attachment AW. \n \n4   \nSubmission of Tariff Revisions to Implement a Provisional Load Process of Southwest \nPower Pool, Inc., Docket No. ER26-2430-000 (June 4, 2025) (“Provisional Load Process \nFiling”). Tariff, Attachment AX."},{"page":3,"startToken":449,"endToken":724,"text":"3 \n• \nenhanced study procedures for High Impact Large Loads (“HILLs”) to enable SPP \nto assess the load’s reliability impacts on the Transmission System;5 \n• \nthe High Impact Large Load Generation Assessment (\"HILLGA\") process, which \nconsists of a new generator interconnection service and related interconnection \nprocess to allow the limited connection of supporting generation for HILLs on an \nexpedited basis;6 \n• \nthe Conditional High Impact Large Load Service (\"CHILLS\"), which allows a \nHILL (or a portion of a HILL) to receive the transfer of energy on a long-term, non-\nfirm basis in instances where transmission service is unavailable due to the lack of \nexisting Designated Resources or completion of Network Upgrades necessary to \nprovide firm transmission service;7 \n• \nthe Peak Demand Assessment (“PDA”) and Demand Response reforms, which \nstrengthen resource adequacy through enhanced load forecasting accountability and \nexpanded integration of Demand Response Resources, including the Reliability-\nRegistered Demand Response Program (“RRDRP”);8  \n \n5   \nSubmission of Tariff Revisions to Add the High Impact Large Load Processes and High \nImpact Large Load Generation Assessment of Southwest Power Pool, Inc., Docket No. \nER26-247-000, at 11 (Oct. 24, 2025) (“HILL Filing”). Tariff, Attachment BA, Section 2. \n \n6   \nHILL Filing at 11. Tariff, Attachment BB. \n \n7   \nSubmission of Tariff Revisions to Add Conditional High Impact Large Load Service of \nSouthwest Power Pool, Inc., Docket No. ER26-1323-000, at 10 (Feb. 10, 2026) (“CHILLS \nFiling”). Tariff, Part VII and Attachment BC. \n \n8   \nSubmission of Tariff Revisions Regarding the Peak Demand Assessment and Demand \nResponse of Southwest Power Pool, Inc., Docket No. ER26-2249-000 (April 17, 2026) \n(“PDA Filing”). This proceeding is pending before the Commission with a requested \neffective date of January 1, 2027."},{"page":4,"startToken":724,"endToken":981,"text":"4 \n• \nthe Consolidated Planning Process (“CPP”), which modernizes SPP's regional \ntransmission planning framework by evaluating transmission needs using \ncoordinated assumptions and integrated studies that better account for significant \nload growth, including emerging large loads;9 and \n• \ncontinued stakeholder development of the Price Adaptive Load (“PAL”) product \nand Price Adaptive Load Service (\"PALS\"), intended to address the evolving needs \nand desire for flexibility of large load customers while preserving system \nreliability.10 \nAlthough several of these initiatives have only recently become effective, they \nrepresent significant changes to SPP's transmission service, markets, operations, resource \nadequacy and interconnection frameworks and provide important tools for ensuring that \nintegration of large loads into the SPP Region is done in a way that facilitates the continued \nsafe and reliable operation of the Transmission System. The Commission has repeatedly \nrecognized SPP's proactive approach to addressing large load growth, emphasizing the \ninnovative and forward-looking nature of these reforms. \nThis report provides details regarding the evolution of these existing processes, \nexplains how they collectively contribute to resource adequacy, and describes ongoing \nstakeholder efforts to implement additional enhancements. As with prior large load \ninitiatives, any future Tariff revisions will be developed and approved through SPP's \n \n9  \nSubmission of Revisions to the SPP Open Access Transmission Tariff to Implement the  \nConsolidated Planning Process of Southwest Power Pool, Inc., Docket No. ER26-414- \n000 (Nov. 3, 2025) (“CPP Filing”). Tariff, Attachment AY. \n \n10  \nSee Price Adaptive Load Service Revision Request posted at: https://www.spp.org/spp- \ndocuments-filings/?id=21069 (see zip file “RR791 SIR796 Price Adaptive Load”) (“RR \n791”)."},{"page":5,"startToken":981,"endToken":1215,"text":"5 \nestablished stakeholder process before being submitted to the Commission for review. \nConsistent with the Commission's directive, this report also provides the anticipated \nschedule for stakeholder consideration of the PAL/PALS proposal currently under \ndevelopment. \nII. \nBACKGROUND  \n \nA. \nSPP \n \nSPP is a Commission-approved Regional Transmission Organization (“RTO”).11 It \nis an Arkansas non-profit corporation with its principal place of business in Little Rock, \nArkansas. SPP currently has 154 members, including 16 investor-owned utilities, 16 \nmunicipal systems, 26 generation and transmission cooperatives, 6 state agencies, 28 \nindependent power producers, 11 power marketers, 18 independent transmission \ncompanies, 3 federal agencies, 18 large retail customers, 4 alternative power entities, and \n8 public interest entities. As an RTO, SPP: (1) administers, across the facilities of SPP’s \nTransmission Owners, open access transmission service over approximately 85,000 miles \nof transmission lines in the Eastern and Western Interconnections covering portions of \nArizona, Arkansas, Colorado, Iowa, Kansas, Louisiana, Minnesota, Missouri, Montana, \nNebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, and \nWyoming; and (2) administers the Integrated Marketplace, a centralized day-ahead and \nreal-time Energy and Operating Reserve market with locational marginal pricing and \nmarket-based congestion management.12 SPP also implements a resource adequacy \n \n11  \nSw. Power Pool, Inc., 109 FERC ¶ 61,009 (2004), order on reh’g, 110 FERC ¶ 61,137 \n(2005). \n12  \nSw. Power Pool, Inc., 146 FERC ¶ 61,130 (2014) (approving the start-up and operation of \nthe Integrated Marketplace)."},{"page":6,"startToken":1215,"endToken":1448,"text":"6 \nprogram under Attachment AA of the Tariff, under which Load Responsible Entities \n(“LRE”) must demonstrate sufficient accredited resource capacity to satisfy their load and \nan SPP-established Planning Reserve Margin (“PRM”) for the Summer Season and Winter \nSeason, or else face significant charges for failure to meet their Resource Adequacy \nRequirement (“RAR”). \nB. \nRole of Stakeholders and States in SPP  \nSPP operates under a stakeholder-driven governance model in which proposed \nrevisions to the Tariff, Bylaws, Membership Agreement, and business practices are \ndeveloped through an open, collaborative process involving market participants, \ntransmission owners, state regulators, and other stakeholders before being considered by \nthe SPP Board of Directors (the \"Board\") and, where applicable, filed with the \nCommission. This Commission-approved governance framework, established in SPP's \nBylaws, Membership Agreement, and organizational governance documents, provides \nmultiple opportunities for stakeholder discussion, refinement, and voting as proposals \nprogress through technical working groups, policy committees, and ultimately to the \nBoard. \nThis collaborative governance structure has been central to SPP's response to \nunprecedented large load growth. The stakeholder initiatives discussed throughout this \nreport were each developed through this established process with significant stakeholder \nparticipation. Of particular importance are the SPP Regional State Committee (\"RSC\") and \nthe Resource and Energy Adequacy Leadership Team (\"REAL Team\"), both of which have \nplayed key roles in shaping SPP's evolving resource adequacy framework. Under the SPP \nBylaws, the RSC possesses defined authority over regional cost allocation methodology"},{"page":7,"startToken":1448,"endToken":1784,"text":"7 \nand resource adequacy matters.13 Complementing that role, the REAL Team was \nestablished in January 2023 to evaluate SPP’s long-term resource adequacy construct and \nto develop recommendations addressing emerging reliability challenges associated with \nchanges in the resource mix, extreme weather events, and rapidly increasing electric \ndemand.14  \nIII. \nCURRENT STATE OF RESOURCE ADEQUACY  \n \nSince adopting Attachment AA of the Tariff in 2018, SPP has continued to \nstrengthen its Resource Adequacy framework to address fundamental changes in the \nresource mix and unprecedented demand growth across the SPP Region. Historically, the \nResource Adequacy program focused primarily on ensuring that each LRE procured \nsufficient generating capacity to meet its forecasted seasonal peak demand plus an \nestablished PRM.15 In recent years, however, accelerating growth in large commercial and \nindustrial loads together with generator retirements and an evolving resource mix have \n \n13  \nSouthwest Power Pool, Inc., Bylaws, First Revised Volume No. 4, Section 7.2. The RSC \nhas primary responsibility for determining regional proposals and the transition process in \nthe following areas: (1) whether and to what extent participant funding will be used for \ntransmission enhancements; (2) whether license plate or postage-stamp rates will be used \nfor the regional access charge; (3) determination of financial transmission rights (“FTRs”) \nallocations where a locational price methodology is used; and (4) determination of the \ntransition mechanism to be used to assure that existing firm customers receive FTRs \nequivalent to the customers’ existing firm rights; and (5) determination of the approach for \nresource adequacy across the entire region. \n14  \nResource and Energy Adequacy Leadership Team, Organizational Group Scope Statement, \nSouthwest \nPower \nPool, \nInc. \n(Jan. \n2023) \nhttps://spp.org/documents/68934/real_scope_statement%20final.pdf. The REAL Team is \ncomposed of members from the RSC, the Board, the Members Committee, the Strategic \nPlanning Committee, the Cost Allocation Working Group (“CAWG”), and the Supply \nAdequacy Working Group (“SAWG”). \n15   \nSee Summer Resource Adequacy Report posted at: \nhttps://spp.org/documents/76932/2026%20spp%20summer%20resource%20adequacy%2\n0report.pdf (“Summer 2026 Resource Adequacy Report”)."},{"page":8,"startToken":1784,"endToken":2046,"text":"8 \nrequired SPP to modernize both its resource accreditation methodology and its load \nforecasting processes.16  \nThe most significant recent enhancement is SPP's transition to a planning margin \nbased on accredited capacity (Accredited Capacity Planning Reserve Margin, “Accredited \nCapacity PRM”) framework beginning with the Summer 2026 Resource Adequacy \nseason.17 Under this framework, resource capability is no longer measured solely by \ninstalled or nameplate capability. Instead, SPP utilizes Performance-Based Accreditation \n(“PBA”) for conventional generation and Effective Load Carrying Capability (“ELCC”) \nmethodologies for wind, solar, and battery Resources to more accurately reflect each \nresource's expected reliability contribution during periods of system stress.18 For Summer \n2026, LREs were required to satisfy their RAR using accredited capacity and a system-\nwide Accredited Capacity PRM of 7.06 percent.19  \nThe transition to accredited capacity represents a significant advancement in SPP's \nresource adequacy framework by aligning resource accreditation with actual performance \nrather than simply relying on installed capability with limited testing to ensure capacity \nadequacy in SPP. This provides a more accurate assessment of regional reliability while \n \n16  \nKeeping the Lights On: Examining the State of Regional Grid Reliability (Testimony of \nLanny Nickell, Executive Vice President, Chief Operating Officer, Southwest Power Pool, \nInc. Before the House Energy & Commerce Subcommittee on Energy), 119th Cong., 3-4 \n(Mar. 25, 2025), available at: \n \nhttps://www.congress.gov/119/meeting/house/118040/witnesses/HHRG-119-IF03-\nWstate-NickellL-20250325.pdf. \n \n17  \nSee Summer 2026 Resource Adequacy Report. \n \n18  \nId. \n \n19  \nId.; see also Conventional Resources Class Averages – Summer 2026 posted at: \nhttps://spp.org/documents/74895/conventional%20unit%20class%20averages%20-\n%20summer%202026.pdf."},{"page":9,"startToken":2046,"endToken":2282,"text":"9 \ncreating technology-neutral incentives for resource performance during critical system \nconditions.  \nA. \nCurrent Resource Adequacy Outlook  \nSPP's most recent Summer 2026 Resource Adequacy Report concludes that the SPP \nRegion is adequately positioned to meet expected Summer 2026 demand while also \nproviding an outlook through the Summer 2031 planning horizon.20 The report evaluates \nexisting accredited Resources, anticipated retirements, planned generation additions, and \nprojected demand growth across the SPP East Balancing Authority Area. For the 2026 \nSummer Season, all sixty-five LREs satisfied their RAR.21 Based on data submitted in the \n2026 Summer Season Workbook, the East BAA maintains a reserve margin of 17.1%, \nrepresenting approximately 5,752 MW of excess accredited capacity above the total RAR. \nThis is an increase of approximately 2,500 MW of excess capacity compared to the 2025 \nSummer Season. More than half of all LREs maintain reserve margins exceeding 16%, \nrepresenting capacity in excess of approximately one-third of LRE forecasted Net Peak \nDemand.22 The 2026 Summer Season Workbook does not address the West BAA because \nthe West BAA is not required to meet SPP’s resource adequacy processes and procedures \nuntil summer 2027. \nB. \nIntegration With Recent Large Load Initiatives \nWhile current resource adequacy projections indicate that the East BAA is well \npositioned to meet near-term demand, SPP recognizes that rapidly increasing load forecasts \n \n20  \nSee Summer 2026 Resource Adequacy Report. \n \n21  \nId. \n \n22  \nSee Summer 2026 Resource Adequacy Report."},{"page":10,"startToken":2282,"endToken":2576,"text":"10 \nrepresent one of the greatest sources of uncertainty in future resource adequacy planning. \nMuch of this uncertainty stems from unprecedented load interconnection requests \nassociated with data centers and other large commercial and industrial customers, many of \nwhich have historically been incorporated into utility load forecasts before development \nplans were sufficiently mature. Traditional planning processes were designed to \naccommodate incremental load growth rather than the addition of individual customers \nwith demand measured in hundreds of megawatts. Recognizing that accurate demand \nforecasts are fundamental to effective resource adequacy planning, SPP also filed Tariff \nrevisions in April 2026 to implement the Peak Demand Assessment,23 establishing a more \nstructured process for validating forecasted peak demand and strengthening accountability \nby ensuring that all loads (including projected large loads) for the upcoming season are \nsupported by sufficient amounts of Accredited Capacity.   \nIV. \nSPP’S EXISTING FRAMEWORK FOR EVALUATING AND SERVING \nNEW LARGE LOADS24  \n \nSPP has developed a coordinated framework of planning, interconnection, \ntransmission service, and resource adequacy processes to address growing demand and \nsupport the reliable integration of new large loads. Rather than addressing large load \n \n23  \nThe PDA Filing is pending before the Commission. \n \n24  \nWhile this Informational Report primarily focuses on the evolution of SPP policies directly \n targeted at large load interconnections, SPP has implemented several complementary  \n initiatives that strengthen resource adequacy. These include annual updates to the Cost of  \n New Entry (“CONE”), which preserve appropriate incentives for LREs to procure \n sufficient Accredited Capacity; implementation of the Consolidated Planning Process  \n (“CPP”), which integrates long-term transmission planning and generator interconnection \n into a single, cohesive framework to better accommodate evolving resource and load needs  \n and speed up interconnection processing; and development of the Surplus Plus  \n interconnection reforms, which facilitate more timely additions of incremental generation \n using existing transmission capability."},{"page":11,"startToken":2576,"endToken":2849,"text":"11 \nrequests as isolated transmission issues, SPP evaluates them through an integrated \nframework designed to accommodate significant load growth while preserving the reliable \noperation of the Transmission System. \nA. \nERAS \nOn May 22, 2025, SPP submitted Tariff revisions to add the ERAS process \nestablishing a one-time, accelerated pathway for new generating resources to help address \nurgent reliability needs through 2030.25 The Commission accepted the ERAS Filing on July \n21, 2025, with an effective date of July 22, 2025.26 SPP developed ERAS in collaboration \nwith the RSC, REAL, and other stakeholders in response to the growing need to bring new \ngeneration resources online on an accelerated timeline. ERAS enables LREs to identify \nand secure the generating resources needed to maintain reliability across the SPP footprint, \ncomply with the resource adequacy requirements set forth in Attachment AA of the Tariff, \nand satisfy their obligation to serve under applicable state or other governing law. To \nqualify for ERAS, a project was required to address an LRE's projected resource adequacy \ndeficit, commit to achieving commercial operation within five years, and satisfy additional \ncriteria demonstrating that the project was sufficiently developed and reasonably likely to \nachieve commercial operation in time to address identified resource adequacy needs.27 \nERAS operates separately from, but in parallel with, SPP's standard Generator \nInterconnection Procedures under Attachment V of the Tariff. \n \n25  \nERAS Filing at 25. Tariff, Attachment AW. At the time of the ERAS Filing, SPP predicted \nthat the SPP Region could face a 2-3 GW accredited capacity shortfall by 2030. \n26  \nSw. Power Pool, Inc., 192 FERC ¶ 61,062 (2025) (“ERAS Order”). \n27  \nTariff, Attachment AW, Section 8.2."},{"page":12,"startToken":2849,"endToken":3131,"text":"12 \nAs a one-time study, ERAS accepted requests during a limited application \nwindow28 and is no longer accepting new requests as a one-time process. Participation by \nLREs during the application window was strong. As of the date of this Informational \nReport, there are 36 active ERAS requests representing approximately 13.3 GW of \ngenerating capacity and no requests have withdrawn.29 These requests remain on schedule \nin the study process.  ERAS Generator Interconnection Agreements (GIA) are currently in \nthe negotiation phase and SPP expects to advance to the execution phase in September \n2026. The process is on track to achieve its primary objective of accelerating the \ninterconnection of generating resources needed to address near-term resource adequacy \nconcerns. Although ERAS was designed as a one-time initiative, it demonstrated SPP's \nability to accelerate the development of reliability-critical generation through a targeted \nstakeholder-driven process and established an important foundation for subsequent large \nload and resource adequacy reforms. \nB. \nProvisional Load Process  \nOn June 4, 2025, SPP submitted Tariff revisions to add a Provisional Load Process, \ndocumented in Attachment AX of the Tariff.30 The Commission accepted the Provisional \nLoad Process Filing on October 10, 2025, with an effective date of August 4, 2025.31 While \n \n28  \nFollowing Commission approval of the ERAS process on July 21, 2025, SPP opened the \none-time ERAS application window on September 2, 2025, and closed the window on \nOctober 2, 2025. \n29  \nSee SPP Operations Portal of GI Active Requests posted at:  \nhttps://opsportal.spp.org/Studies/GIActive and \nhttps://app.powerbigov.us/view?r=eyJrIjoiNTFhODQ5MjEtMTQ1My00ZjI5LWFjNWIt\nZmQ3NGQxNzM1ZDZiIiwidCI6IjMyMzA5MjZhLTcxYjctNDM3MC1hMTM3LTE5N2\nJhZGMwNjZhMiJ9. \n30  \nProvision Load Process Filing. Tariff, Attachment AX. \n31  \nSw. Power Pool, Inc., 193 FERC ¶ 61,018 (2025) (“Provision Load Process Order”)."},{"page":13,"startToken":3131,"endToken":3388,"text":"13 \nthe HILL process described below is designed for large, high-impact loads, the Provisional \nLoad Process addresses a different challenge: the ability for SPP to study new proposed \nload additions prior to the Transmission Customers having existing resources online to \nsupport the new load. Under Attachment AQ, SPP may only study requests for new or \nmodified delivery points when the Transmission Customer demonstrates that its existing \nDesignated Resources are sufficient to serve both its existing forecasted load and the \nproposed new load over a ten-year horizon.32 As requests associated with large loads \nincreased significantly, many Transmission Customers were unable to satisfy this \nprerequisite because the generation intended to serve the load had not yet completed the \ninterconnection process or otherwise become an existing Designated Resource. As a result, \nSPP was unable to evaluate numerous otherwise viable load requests under its then-existing \nTariff provisions. \nThe Provisional Load Process was developed to address this gap. Using the same \nstudy methodologies used for other load connection studies, the Provisional Load Process \nallows SPP to study proposed delivery point additions using both existing Designated \nResources and identified planned generation that is expected to serve the new load.33 \nImportantly, the Provisional Load Process, alone, does not provide transmission service \nbut instead serves as a planning mechanism that enables Transmission Customers to \nidentify the transmission upgrades necessary to accommodate future load while their \nplanned generation progresses through the applicable interconnection and transmission \n \n32  \nTariff, Part II, Section 17.9; Part III, Section 31.2; and Attachment AQ. \n33  \nTariff, Attachment AX."},{"page":14,"startToken":3388,"endToken":3688,"text":"14 \nservice processes.34 Because the generation relied upon in the study has not yet completed \nthe interconnection process and may ultimately change or fail to materialize, the revenue \nrequirements for Network Upgrades identified through the Provisional Load Process are \ntreated as Directly Assigned Upgrade Costs and are allocated 100% to the Transmission \nCustomer until the Transmission Customer acquires firm transmission service for the \nplanned generation.35 Once the planned generation obtains Long-Term Service and \nbecomes a Designated Resource, the remaining costs of those Network Upgrades transition \nto Base Plan funding consistent with Attachment J of the Tariff36 and the Transmission \nCustomer’s Network Integration Transmission Service Agreement or Point-to-Point \nTransmission Service Agreement is updated to reflect the requested changes.37 This \napproach protects other loads within SPP from bearing the costs of upgrades associated \nwith speculative or uncertain generation while still allowing transmission planning to move \nforward in support of anticipated load growth.  \nAs described in more detail in the following sections, SPP modified Attachment \nAX in the HILL and CHILLS Filings to integrate those frameworks into the existing \nAttachment AX process by requiring additional studies and information for qualifying \n \n34  \nThe Transmission Customer must  complete either the Aggregate Transmission Service \nStudy assessing the planned Designated Resource or the expedited process for resource \ndesignation as described in Section 30.2.2 of the Tariff before the Transmission Customer’s \nNetwork Integration Transmission Service Agreement or Point-to-Point Transmission \nService Agreement will be updated to reflect the requested changes. Tariff, Attachment AX, \nAddenda 2 and 3. \n35  \nTariff at Attachment J, Section V; Tariff at Attachment AX, Addendum 2 at Sections 6.0 \nand 7.0; Tariff, Attachment AX, Addendum 3 at Sections 6.0 and 7.0 \n36  \nTariff, Attachment J, Section III.A. \n37  \nTariff, Attachment AX, Addenda 2 and 3."},{"page":15,"startToken":3688,"endToken":3941,"text":"15 \nHILLs and to provide Transmission Customers with additional flexibility when requesting \nstudies for new load additions. \nC. \nHILLs and the HILLGA  \n \nOn October 24, 2025, SPP submitted Tariff revisions to add a HILL study process \nand the HILLGA.38 The Commission accepted the HILL Filing on January 14, 2026, with \nan effective date of January 15, 2026.39 The HILL Filing proposed two new mechanisms: \n(1) the HILL study process set forth in Attachment BA; and (2) the HILLGA process set \nforth in Attachment BB. The HILL Filing revisions (1) defined and created a new category \nof load, termed a “HILL”; (2) established enhanced study requirements for HILLs to enable \nSPP to assess the load’s reliability impacts on the Transmission System; and (3) established \nadditional, ongoing operational requirements for HILLs to ensure continued reliability of \nthe Transmission System.40 The HILLGA process consists of a new generator \ninterconnection service and related interconnection process to allow the limited connection \nof supporting generation for HILLs on an expedited basis.41  \nThe HILL Filing revisions built upon the original Attachment AX framework by \npreserving Attachment AX as a vehicle through which HILLs may receive provisional \ntransmission service while layering on the HILL-specific study and operational \nrequirements established in Attachment BA. The revisions clarified that requests for new \nor modified delivery points associated with a HILL remain eligible for study under \n \n38  \nHILL Filing. \n \n39  \nSw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026) (“HILL/HILLGA Order”). \n40  \nHILL Filing at 11-38. \n41  \nTariff, Attachment BB."},{"page":16,"startToken":3941,"endToken":4288,"text":"16 \nAttachment AX but must also satisfy the additional study and operational requirements \nestablished in Attachment BA.  \nThe Tariff defines a HILL as:  \nA new commercial or industrial load, or increase in commercial or industrial \nload, at a single site connected through one or more shared Points of \nInterconnection (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 \nthan or equal to 69 kV; or (2) 50 MW or more if connected to the \nTransmission System at a voltage level greater than 69 kV. An Electric \nStorage Resource is not considered a HILL. A load may be categorized as a \nHILL after the initial effective date of Attachment BA of the Tariff.  High \nImpact Large Loads must register as such in accordance with Attachment \nAE of the Tariff and follow the processes specified in Attachment BA of the \nTariff.42 \n \nSPP processes all load additions and modifications, including HILLs, using its \nexisting Attachment AQ, Attachment AX, and/or Attachment Z1 study processes.43 \nHowever, for HILLs, SPP and the applicable Transmission Owner(s) simultaneously \nconduct additional studies under Attachment BA to ensure that the unique operational \ncharacteristics of HILLs are considered when evaluating the addition of a HILL to the \nTransmission System, and that SPP has mechanisms in place to maintain reliable operation \nof the Transmission System.44 Attachment BA also imposes ongoing operational \nrequirements, including the addition of certain equipment, to ensure that SPP can continue \n \n42  \nTariff, Part I, Section 1, Definition of High Impact Large Load. \n43  \nThrough Attachment AQ, any existing customers may obtain firm transmission service for \nthe modification of an existing delivery point or for the creation of a new delivery point. \nUnder Attachment AX, existing customers may receive provisional study of a new or \nmodified delivery point using planned generation, instead of existing Designated \nResources. Lastly, new customers may receive transmission service for their load and \nResources through Attachment Z1. \n44  \nTariff, Attachment BA, Sections 2.1.3.4 and 2.1.3.5."},{"page":17,"startToken":4288,"endToken":4596,"text":"17 \nto manage the Transmission System while accommodating the unique operational demands \nand characteristics of HILLs.45  \nThe HILLGA process, outlined in Attachment BB, facilitates the prompt \ninterconnection of generating resources that are specifically identified for and limited to \nserving a HILL, at the request of the HILLGA Customer.46 SPP studies HILLGA Requests \noutside of its existing generator interconnection process on a serial basis, but solely for the \nimpact of the Generating Facility47 to serve the identified HILL.48 Unlike traditional \ninterconnection service, HILLGA provides a limited form of interconnection service \nspecifically designed to evaluate generation intended to serve an identified HILL.49  \nD. \nCHILLS  \nOn February 10, 2026, SPP submitted Tariff revisions to add a CHILLS, that allows \nHILLs to be served with non-firm conditional transmission service.50 The Commission \n \n45  \nTariff, Attachment BA, Section 2.2. \n46  \nTariff, Attachment BB, Section 2. \n47  \nTariff, Attachment BB, Section 1, Definition of Generating Facility (“will mean a HILLGA \nCustomer's device(s) for the production and/or storage for later injection of electricity \nidentified in the HILLGA Request, but will not include HILLGA Customer's \nInterconnection Facilities and will not include a Storage as Transmission Only Asset as \ndefined in Section 1 of the Tariff. A Generating Facility consists of one or more generating \nunit(s) and/or storage device(s) which usually can operate independently and be brought \nonline or taken offline individually.”). \n48  \nTariff, Attachment BB, Section 3.1.2. \n49  \nTariff, Attachment BB, Section 3.2. The HILLGA does not grant the Generating Facility \ntraditional generator interconnection service, such as Network Resource Interconnection \nService (“NRIS”) or Energy Resource Interconnection Service (“ERIS”); instead, \nGenerating Facilities studied under the HILLGA process receive much more limited “Load \nLimited Resource Interconnection Service” or “LLRIS,” which only studies the impact of \nthe Generating Facility serving the identified HILL. \n50  \nCHILLS Filing."},{"page":18,"startToken":4596,"endToken":4914,"text":"18 \naccepted the CHILLS Filing on June 5, 2026, with an effective date of July 1, 2026.51 \nCHILLS builds on the HILL and HILLGA processes to help further unlock the \ninterconnection of large loads by facilitating service for HILLs by allowing a HILL (or a \nportion of a HILL) to receive the transfer of energy on a long-term, non-firm basis. \nThe Attachment AQ and AX processes may delay service to otherwise ready HILLs \nand postpone the economic benefits associated with those projects. Delays could be related \nto construction of Network Upgrades or an inability to comply with the need to have \nsufficient Designated Resources to support the HILL. CHILLS mitigates this challenge by \nproviding Transmission Customers with the ability to receive non-firm transmission \nservice to HILL delivery points before (1) completion of any applicable Network Upgrades \nand/or (2) meeting the requirements for establishment of Designated Resources.52  \n \nThe CHILLS Filing further built upon the Attachment AX framework by clarifying \nwhich customers may be eligible for the Provisional Load Process. Specifically, a \nTransmission Customer may request the study of a new load addition pursuant to \nAttachment AX regardless of whether the Eligible Customer has sufficient Designated \nResources to support the study, provided that the Eligible Customer elects not to use its \nexisting Designated Resources for the proposed load addition.53 This framework provides \n \n51  \nSw. Power Pool, Inc., 195 FERC ¶ 61,196 (2026) (“CHILLS Order”). \n52  \nTariff, Part I, Section 1, Definition of Network Resource (“Any designated generating \nresource owned, purchased or leased by a Network Customer under the Network \nIntegration Transmission Service Tariff.  Network Resources do not include any resource, \nor any portion thereof, that is committed for sale to third parties or otherwise cannot be \ncalled upon to meet the Network Customer's Network Load on a non-interruptible \nbasis, except for purposes of fulfilling obligations under a reserve sharing program.”). \n53  \nTariff, Attachment AX, Section 1."},{"page":19,"startToken":4914,"endToken":5170,"text":"19 \nflexibility to Transmission Customers in determining which Designated Resources will be \nassociated with new load additions when studied for firm transmission service under the \nTariff. \nCHILLS includes numerous reliability protections, including supporting generation \nrequirements, enhanced engineering and operational studies, dedicated operating \nagreements, separate metering requirements, and SPP's authority to curtail or interrupt \nservice during transmission constraints or Emergency Conditions. CHILLS are limited to \na maximum seven-year term and requires customers to pursue permanent firm transmission \nservice through existing Tariff processes, reinforcing that the service is intended as a \ntemporary bridge rather than a substitute for long-term transmission solutions.  \nAlthough CHILLS only recently became effective, SPP and its stakeholders \ncontinue to evaluate potential enhancements to improve its implementation and operation. \nSPP anticipates filing Tariff changes to clarify the sequencing of Resource commitments \nand Reliability-Resource Demand Response Program (RRDRP) deployments relative to \nCHILLs and establish a minimum Curtailment ramp rate for CHILLS.54 SPP also intends \nto propose Tariff revisions permitting limited outages for Resources supporting certain \nCHILLs.55 As a first-of-its-kind transmission service, CHILLS will continue to evolve. SPP \nand its stakeholders will continue refining the service where appropriate to improve its \neffectiveness while maintaining system reliability.  \nE. \nPDA and Enhancements to the Participation of Demand Response \nResources \n \n \n54  \nSee CHILL Clarification Revision Request posted at: https://www.spp.org/spp- \ndocuments-filings/?id=21069 (see zip file “RR767(SIR833) CHILL Clarification). \n55  \nSee CHILL Outage Criteria Revision Request posted at: https://www.spp.org/spp- \ndocuments-filings/?id=21069 (see zip file “RR768(SIR823) CHILL Outage Criteria)."},{"page":20,"startToken":5170,"endToken":5414,"text":"20 \n \nOn April 17, 2026, SPP submitted Tariff revisions to strengthen its Resource \nAdequacy framework through implementation of a PDA and enhancements to the \nparticipation of Demand Response Resources.56 The PDA Filing is pending before the \nCommission with a requested effective date of January 1, 2027. The filing was developed \nin response to accelerating load growth, including the emergence of large data center \ndemand, increasing uncertainty in load forecasting, and the continued evolution of the \nresource mix across the SPP Region, including the anticipated increased reliance on \nDemand Response Programs by LREs to meet the RAR while dealing with the \naforementioned load growth. \nJust as SPP recently modernized how resource capability is measured through the \nAccredited Capacity PRM framework, the PDA modernizes how demand is forecasted and \nmeasured for resource adequacy purposes. Together, these reforms strengthen both sides \nof SPP's resource adequacy framework by improving the accuracy of the capacity available \nto serve load and the forecasted demand against which that capacity is evaluated. The PDA \nshifts resource adequacy accountability from a solely forecast-based, pre-season \nevaluation57 to a financially binding post-season assessment based on actual, weather-\nnormalized peak demand.  \nUnder the revised framework, SPP would continue to validate each LRE’s qualified \ncapacity before each season through a new Pre-Season Requirement, while determining \ncompliance with the RAR after the season using verified demand data.58 This approach \n \n56  \nPDA Filing. \n57  \nTariff, Attachment AA, Section 12 entitled, “Post-Season Analysis.” \n58  \nPDA Filing at 6."},{"page":21,"startToken":5414,"endToken":5632,"text":"21 \naddresses a key limitation of the existing framework by establishing accountability for \nmaterial under-forecasting of load while preserving the operational benefits of pre-season \nresource qualification. By relying on actual metered data and weather-normalized peak \ndemand, the PDA better aligns resource adequacy obligations with actual system \nconditions, particularly as large loads introduce greater variability and uncertainty into \nforecasting.59 \nThe PDA Filing also modernizes SPP's treatment of Demand Response Resources \nby integrating qualifying Demand Response Resources more fully into the Resource \nAdequacy framework.60 The revisions permit market-registered Demand Response \nResources to serve as capacity Resources, establish a new RRDRP that may receive \naccredited capacity, implement performance-based accreditation using historical \nperformance, and enhance operational and deployment requirements to ensure dependable \nperformance during system stress and emergency conditions.61 These revisions provide \ngreater operational visibility into available Resources while creating incentives for both \naccurate load forecasting and reliable Demand Response performance.  Additionally, the \nPDA filing permits LREs to implement non-registered load-modifying Demand Response \nprograms that are not registered in the Integrated Marketplace and do not qualify as \nRRDRP. This flexibility allows LREs to actively manage their peak demand in real time, \nsupporting compliance with their load forecasts while ensuring their demand remains \nconsistent with the capacity they qualified for under the Pre-Season Requirement. \n \n59  \nId. \n60  \nId. \n61  \nId."},{"page":22,"startToken":5632,"endToken":5860,"text":"22 \nTogether, the PDA and Demand Response reforms complete a broader set of \ncoordinated transmission planning, interconnection, and resource adequacy reforms. When \nconsidered alongside the previously approved Provisional Load Process, the HILL and \nHILLGA frameworks, the ERAS reforms, and related stakeholder initiatives, these \nmeasures illustrate SPP's integrated approach to accommodating significant load growth \nwhile preserving reliability and ensuring resource adequacy. \nF. \nCPP \nIn addition to initiatives specifically focused on large loads and resource adequacy, \nSPP has undertaken broader reforms to its regional transmission planning processes that \nwill improve the region's ability to identify and address transmission needs associated with \nevolving load growth, changing resource portfolios, and increasing system complexity. \nOne such initiative is CPP, which streamlines multiple existing transmission planning \nassessments into a single, coordinated planning framework. \nHistorically, SPP conducted several planning studies independently, each with \ndistinct objectives, assumptions, and study horizons. While these planning processes \nprovided valuable information, the separate study cycles could result in duplicative \nanalyses, differing assumptions, and limited opportunities to evaluate transmission needs \nholistically. As the region experiences accelerating load growth—including requests to \nserve large new loads—along with significant generation interconnection activity and \nevolving resource adequacy needs, SPP recognized the value of integrating these planning \nefforts into a unified process. \nThe CPP establishes a coordinated planning cycle that evaluates reliability, \neconomic, operational, and public policy-driven transmission needs using a common set of"},{"page":23,"startToken":5860,"endToken":6087,"text":"23 \nassumptions and coordinated stakeholder input. By consolidating these planning activities, \nSPP is better positioned to evaluate transmission solutions across multiple planning \nobjectives, improve consistency in forecasting future system conditions, and identify \nprojects that provide broad regional benefits. The process also enhances transparency by \nproviding stakeholders with a single planning framework through which assumptions, \nstudy methodologies, and recommended transmission solutions can be reviewed and \nrefined. \nAlthough the CPP is not directed solely at accommodating large loads, it \nstrengthens the planning foundation needed to address significant changes in demand \nacross the SPP footprint. As large industrial facilities, data centers, electrification, and \nother emerging loads increasingly influence long term transmission needs, the CPP \nprovides a more integrated process for evaluating how those loads interact with generation \ndevelopment, resource adequacy requirements, and regional transmission expansion. This \nintegrated planning approach enables SPP to assess transmission needs using consistent \nplanning assumptions while considering the cumulative impacts of multiple drivers \naffecting the Transmission System. \nThe CPP complements SPP's other initiatives discussed in this report, including \nenhancements to the HILL framework, the HILLGA process, resource adequacy reforms, \nand other transmission planning improvements. Together, these efforts are intended to \nimprove SPP's ability to plan for and reliably serve substantial new load growth while \nmaintaining an efficient, transparent, and stakeholder-driven regional planning process. \nV. \nPRICE ADAPTIVE LOADS (PALs) AND PRICE ADAPTIVE LOAD \nSERVICE (PALS) \n \nA. \nOverview"},{"page":24,"startToken":6087,"endToken":6323,"text":"24 \n \nThe Price Adaptive Load (PAL) and Price Adaptive Load Service (PALS) \nframework establishes a new market participation model and transmission service option \nspecifically designed for large, price-responsive loads.62 Unlike the initiatives discussed in \nSection IV, PAL/PALS remains under active stakeholder development and has not yet been \nsubmitted to the Commission. Accordingly, the discussion below summarizes the current \nproposal and anticipated stakeholder schedule. \nThe PAL/PALS framework is intended to accommodate a new class of commercial \nand industrial customers—such as certain data centers and advanced manufacturing \nfacilities—that are capable of adjusting or interrupting electricity consumption in response \nto real-time market conditions while reducing reliance on traditional firm transmission \nservice. Participating PALs would be economically dispatched through SPP's Integrated \nMarketplace based on submitted price-sensitive bids and would be required to respond to \ndispatch instructions in both the Day-Ahead Market and Real-Time Balancing Market. To \nsupport this market participation model, the proposal also creates Price Adaptive Load \nService (PALS), a new non-firm transmission service designed specifically for \ndispatchable, flexible loads. Unlike traditional transmission service, PALS would utilize a \nusage-based billing structure and require participating loads to be fully dispatchable, \ncapable of rapidly reducing consumption, and subject to Curtailment during transmission \nconstraints, Emergency Conditions, or local reliability events.  \nThe PAL/PALS framework represents the next evolution of SPP's large load \nstrategy by providing a market-based option for flexible loads that complements SPP's \n \n62  \nRR 791."},{"page":25,"startToken":6323,"endToken":6578,"text":"25 \nexisting planning, transmission service, interconnection, and resource adequacy reforms. \nWhere SPP's previously approved reforms focused primarily on ensuring that sufficient \ngeneration, transmission capability, and planning processes exist to support unprecedented \nload growth, the PAL/PALS proposal recognizes that some emerging large loads possess \noperational flexibility that can itself become a valuable reliability and market resource. By \ncreating a market participation model and transmission service tailored to those \ncharacteristics, PAL/PALS would complement SPP's existing framework while expanding \nthe range of tools available to integrate large flexible loads reliably and efficiently. \nB. \nStakeholder Schedule and Expected Milestones  \n \nThe PAL/PALS initiative is the product of extensive stakeholder development that \nhas included technical design, stakeholder education, Tariff drafting, and publication of the \nassociated Revision Request (RR). Development began with an internal team of SPP staff \nmeetings during the first quarter of 2026 to establish the framework and refine the \nmodeling approach. Beginning in April 2026, SPP initiated a broad stakeholder education \neffort, presenting the concepts to the Cost Allocation Working Group (“CAWG”), \nOperating Reliability Working Group (“ORWG”), Markets Working Group (“MWG”), \nRegional Tariff Working Group (“RTWG”), and other stakeholder groups to introduce the \nproposal and solicit early feedback. \nDuring May and June, the stakeholder process advanced from conceptual \ndevelopment to preparation of Tariff revisions necessary to implement the PAL/PALS \ndesign framework. SPP also hosted question-and-answer sessions and multiple stakeholder \nforums to discuss the proposal, gather additional feedback, and refine the draft revisions. \nThe PAL/PALS RR was posted for stakeholder review on July 9, 2026."},{"page":26,"startToken":6578,"endToken":6817,"text":"26 \nSPP intends to continue its extensive outreach efforts through additional \nstakeholder forums and educational presentations across numerous working groups, \nincluding the MWG, RTWG, Supply Adequacy Working Group (“SAWG”), Transmission \nWorking Group (“TWG”), Economic Studies Working Group (“ESWG”), ORWG, \nCAWG, RSC, and the Markets and Operations Policy Committee (“MOPC”). The proposal \nis expected to advance through the formal stakeholder approval process from August \nthrough November 2026, with individual working groups considering the revisions before \nfinal votes by MOPC on October 13, 2026, and the RSC on November 16, 2026. Assuming \nstakeholder approval, SPP intends to file the PAL/PALS proposal with the Commission on \nor before November 16, 2026. This timeline reflects SPP's collaborative stakeholder \nprocess, which is designed to provide multiple opportunities for education, technical \ndiscussion, stakeholder input, and formal approval before being filed with the Commission. \nVI. \nONGOING WORK OF THE REAL TEAM \n \nIn 2023, as mentioned above, the SPP Board established the REAL Team to assess \nSPP’s current resource adequacy construct and anticipated challenges resulting from \nresource mix changes, extreme weather impacts, increased demand, and evolving \nconsumer behaviors. REAL provides guidance, prioritization, and policy recommendations \nneeded to increase assurance that sufficient energy to meet load requirements can be \ncontinuously and cost-effectively provided within the SPP Balancing Authority Areas \n(“BAA”). The REAL Team consists of a diverse membership from various SPP \nstakeholder groups, including the SPP Board, transmission owning members, transmission \nusing members, and state commission representatives."},{"page":27,"startToken":6817,"endToken":7028,"text":"27 \nAs seen on the REAL Teams work plan,63 the REAL Team will address a number of \nResource Adequacy issues in 2027, including Seasonal Resource Adequacy Construct, use \nof non-firm imports in the development of the planning reserve margin, non-weather \nrelated load uncertainty, and the use of coincident peak instead of non-coincident peak in \nSPP’s resource adequacy requirements. Through this work, SPP is continuing its steadfast \ncommitment to ensuring that SPP continues to have sufficient resource capacity to meet \ncurrent and projected load growth in both SPP BAAs. \nVII. \nCONCLUSION \nSPP continues to work with stakeholders to refine its planning, transmission, \nmarket, operations, and resource adequacy frameworks as large load development \ncontinues to evolve across the region. The initiatives described in this report reflect SPP's \ncoordinated approach to integrating large loads while preserving reliability, maintaining \nresource adequacy, and protecting existing customers. SPP respectfully requests the \nCommission accept this report as responsive to the Commission’s directive to submit an \ninformational report in the Show Cause Order. \n \nRespectfully submitted, \n/s/ Meredith Powell \n \n \nMeredith Powell \nAttorney \n \n \nSouthwest Power Pool, Inc. \n201 Worthen Drive \n \n \nLittle Rock, AR 72223 \n   \n \n \nmpowell@spp.org \n \n \n63  \nREAL Team meeting materials on the June 17, 2026, item number 5: \n             https://www.spp.org/Documents/76913/REAL%20Meeting%2020260617.zip"},{"page":28,"startToken":7028,"endToken":7038,"text":"28 \nAttorney for \nSouthwest Power Pool, Inc. \n \nJuly 20, 2026"},{"page":29,"startToken":7038,"endToken":7097,"text":"CERTIFICATE 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 20th day of July, 2026. \n \n /s/ Cassie Butler \nCassie Butler \nSouthwest Power Pool, Inc. \n201 Worthen Drive \nLittle Rock, AR 72223-4936 \n(501)"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1182,"startToken":0,"endToken":162},{"p":1,"at":1182,"title":"I. EXECUTIVE SUMMARY","method":"printed heading","endPage":1,"endAt":1186,"startToken":162,"endToken":163},{"p":1,"at":1186,"title":"EXECUTIVE SUMMARY","method":"printed heading","endPage":5,"endAt":271,"startToken":163,"endToken":1016},{"p":5,"at":271,"title":"II. BACKGROUND","method":"printed heading","endPage":5,"endAt":276,"startToken":1016,"endToken":1017},{"p":5,"at":276,"title":"BACKGROUND","method":"printed heading","endPage":6,"endAt":370,"startToken":1017,"endToken":1267},{"p":6,"at":370,"title":"B. Role of Stakeholders and States in SPP","method":"printed heading","endPage":7,"endAt":354,"startToken":1267,"endToken":1496},{"p":7,"at":354,"title":"III. CURRENT STATE OF RESOURCE ADEQUACY","method":"printed heading","endPage":9,"endAt":105,"startToken":1496,"endToken":2057},{"p":9,"at":105,"title":"A. Current Resource Adequacy Outlook","method":"printed heading","endPage":9,"endAt":1269,"startToken":2057,"endToken":2235},{"p":9,"at":1269,"title":"B. Integration With Recent Large Load Initiatives","method":"printed heading","endPage":10,"endAt":1024,"startToken":2235,"endToken":2419},{"p":10,"at":1024,"title":"IV. SPP’S EXISTING FRAMEWORK FOR EVALUATING AND SERVING","method":"printed heading","endPage":11,"endAt":216,"startToken":2419,"endToken":2604},{"p":11,"at":216,"title":"A. ERAS","method":"printed heading","endPage":12,"endAt":1074,"startToken":2604,"endToken":3003},{"p":12,"at":1074,"title":"B. Provisional Load Process","method":"printed heading","endPage":15,"endAt":126,"startToken":3003,"endToken":3705},{"p":15,"at":126,"title":"C. HILLs and the HILLGA","method":"printed heading","endPage":17,"endAt":730,"startToken":3705,"endToken":4392},{"p":17,"at":730,"title":"D. CHILLS","method":"printed heading","endPage":19,"endAt":1537,"startToken":4392,"endToken":5111},{"p":19,"at":1537,"title":"E. PDA and Enhancements to the Participation of Demand Response","method":"printed heading","endPage":23,"endAt":1687,"startToken":5111,"endToken":6074},{"p":23,"at":1687,"title":"V. PRICE ADAPTIVE LOADS (PALs) AND PRICE ADAPTIVE LOAD","method":"printed heading","endPage":23,"endAt":1762,"startToken":6074,"endToken":6085},{"p":23,"at":1762,"title":"A. Overview","method":"printed heading","endPage":25,"endAt":711,"startToken":6085,"endToken":6414},{"p":25,"at":711,"title":"B. Stakeholder Schedule and Expected Milestones","method":"printed heading","endPage":26,"endAt":1003,"startToken":6414,"endToken":6716},{"p":26,"at":1003,"title":"VI. ONGOING WORK OF THE REAL TEAM","method":"printed heading","endPage":27,"endAt":577,"startToken":6716,"endToken":6906},{"p":27,"at":577,"title":"VII. CONCLUSION","method":"printed heading","endPage":27,"endAt":583,"startToken":6906,"endToken":6907},{"p":27,"at":583,"title":"CONCLUSION","method":"printed heading","endPage":29,"endAt":0,"startToken":6907,"endToken":7038},{"p":29,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":29,"endAt":380,"startToken":7038,"endToken":7097}]}