EL26-68-000 · 2026-07-20 · Southwest Power Pool, Inc.

SPP reports on resource adequacy and large-load proposals

UNITED STATES OF AMERICA 
BEFORE THE  
FEDERAL ENERGY REGULATORY COMMISSION 
Southwest Power Pool, Inc.  
 
 ) 
  
Docket No. EL26-68-000 
 
 
 
 
 
 
 
INFORMATIONAL REPORT OF  
SOUTHWEST POWER POOL, INC. 
 
Southwest Power Pool, Inc. (“SPP”) respectfully submits this Informational Report 
in response to the directive issued by the Federal Energy Regulatory Commission 
(“Commission”) in its June 18, 2026, Order Instituting Proceeding Under Section 206 of 
the Federal Power Act in Docket No. EL26-68-0001 (“Show Cause Order”). In the Show 
Cause Order, the Commission directed SPP to provide, within thirty days, a detailed 
informational report describing: (1) any proposals under consideration in SPP's stakeholder 
process to address resource adequacy associated with new large loads, or, to the extent no 
such proposals are under consideration, information regarding how SPP's existing 
processes are operating to ensure resource adequacy; and (2) for any new proposals under 
development, a detailed schedule identifying key stakeholder milestones, including 
anticipated stakeholder and Board actions and the expected date for any future filing with 
the Commission.2  
I. 
EXECUTIVE SUMMARY 
SPP appreciates the Commission's recognition that unprecedented growth in 
electric demand from data centers, advanced manufacturing, industrial electrification, and 
other large load customers presents both opportunities and challenges for the electric 
 
1   
Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026) (“Show Cause Order”). 
 
2   
Show Cause Order at P 91.

2 
industry. SPP likewise recognizes the importance of integrating these new loads in a 
manner that preserves reliability, maintains resource adequacy, and protects existing 
customers from unreasonable costs. 
As large load requests have increased in both number and size, SPP has worked 
with stakeholders to develop processes that not only evaluate the transmission impacts 
associated with these customers but also facilitate the timely addition of new generating 
resources capable of serving that demand. Rather than relying on a single solution, SPP has 
developed complementary initiatives that improve planning certainty, accelerate the 
addition of new resources, enhance operational flexibility, strengthen resource adequacy 
accountability, and better align transmission and interconnection processes with the unique 
characteristics of emerging large loads. 
As discussed in greater detail below, these efforts include: 
• 
the Expedited Resource Adequacy Study ("ERAS"), which accelerates evaluation 
of new generating resources intended to support resource adequacy;3  
• 
the Provisional Load Process, which allows SPP to study proposed delivery point 
additions using both existing Designated Resources and identified planned 
generation that is expected to serve the new load;4  
 
3   
Submission of Tariff Revisions to Implement the Expedited Resource Adequacy Study of 
Southwest Power Pool, Inc., Docket No. ER25-2296-000 (May 22, 2025) (“ERAS Filing”). 
Tariff, Attachment AW. 
 
4   
Submission of Tariff Revisions to Implement a Provisional Load Process of Southwest 
Power Pool, Inc., Docket No. ER26-2430-000 (June 4, 2025) (“Provisional Load Process 
Filing”). Tariff, Attachment AX.

3 
• 
enhanced study procedures for High Impact Large Loads (“HILLs”) to enable SPP 
to assess the load’s reliability impacts on the Transmission System;5 
• 
the High Impact Large Load Generation Assessment ("HILLGA") process, which 
consists of a new generator interconnection service and related interconnection 
process to allow the limited connection of supporting generation for HILLs on an 
expedited basis;6 
• 
the Conditional High Impact Large Load Service ("CHILLS"), which allows a 
HILL (or a portion of a HILL) to receive the transfer of energy on a long-term, non-
firm basis in instances where transmission service is unavailable due to the lack of 
existing Designated Resources or completion of Network Upgrades necessary to 
provide firm transmission service;7 
• 
the Peak Demand Assessment (“PDA”) and Demand Response reforms, which 
strengthen resource adequacy through enhanced load forecasting accountability and 
expanded integration of Demand Response Resources, including the Reliability-
Registered Demand Response Program (“RRDRP”);8  
 
5   
Submission of Tariff Revisions to Add the High Impact Large Load Processes and High 
Impact Large Load Generation Assessment of Southwest Power Pool, Inc., Docket No. 
ER26-247-000, at 11 (Oct. 24, 2025) (“HILL Filing”). Tariff, Attachment BA, Section 2. 
 
6   
HILL Filing at 11. Tariff, Attachment BB. 
 
7   
Submission of Tariff Revisions to Add Conditional High Impact Large Load Service of 
Southwest Power Pool, Inc., Docket No. ER26-1323-000, at 10 (Feb. 10, 2026) (“CHILLS 
Filing”). Tariff, Part VII and Attachment BC. 
 
8   
Submission of Tariff Revisions Regarding the Peak Demand Assessment and Demand 
Response of Southwest Power Pool, Inc., Docket No. ER26-2249-000 (April 17, 2026) 
(“PDA Filing”). This proceeding is pending before the Commission with a requested 
effective date of January 1, 2027.

4 
• 
the Consolidated Planning Process (“CPP”), which modernizes SPP's regional 
transmission planning framework by evaluating transmission needs using 
coordinated assumptions and integrated studies that better account for significant 
load growth, including emerging large loads;9 and 
• 
continued stakeholder development of the Price Adaptive Load (“PAL”) product 
and Price Adaptive Load Service ("PALS"), intended to address the evolving needs 
and desire for flexibility of large load customers while preserving system 
reliability.10 
Although several of these initiatives have only recently become effective, they 
represent significant changes to SPP's transmission service, markets, operations, resource 
adequacy and interconnection frameworks and provide important tools for ensuring that 
integration of large loads into the SPP Region is done in a way that facilitates the continued 
safe and reliable operation of the Transmission System. The Commission has repeatedly 
recognized SPP's proactive approach to addressing large load growth, emphasizing the 
innovative and forward-looking nature of these reforms. 
This report provides details regarding the evolution of these existing processes, 
explains how they collectively contribute to resource adequacy, and describes ongoing 
stakeholder efforts to implement additional enhancements. As with prior large load 
initiatives, any future Tariff revisions will be developed and approved through SPP's 
 
9  
Submission of Revisions to the SPP Open Access Transmission Tariff to Implement the  
Consolidated Planning Process of Southwest Power Pool, Inc., Docket No. ER26-414- 
000 (Nov. 3, 2025) (“CPP Filing”). Tariff, Attachment AY. 
 
10  
See Price Adaptive Load Service Revision Request posted at: https://www.spp.org/spp- 
documents-filings/?id=21069 (see zip file “RR791 SIR796 Price Adaptive Load”) (“RR 
791”).

5 
established stakeholder process before being submitted to the Commission for review. 
Consistent with the Commission's directive, this report also provides the anticipated 
schedule for stakeholder consideration of the PAL/PALS proposal currently under 
development. 
II. 
BACKGROUND  
 
A. 
SPP 
 
SPP is a Commission-approved Regional Transmission Organization (“RTO”).11 It 
is an Arkansas non-profit corporation with its principal place of business in Little Rock, 
Arkansas. SPP currently has 154 members, including 16 investor-owned utilities, 16 
municipal systems, 26 generation and transmission cooperatives, 6 state agencies, 28 
independent power producers, 11 power marketers, 18 independent transmission 
companies, 3 federal agencies, 18 large retail customers, 4 alternative power entities, and 
8 public interest entities. As an RTO, SPP: (1) administers, across the facilities of SPP’s 
Transmission Owners, open access transmission service over approximately 85,000 miles 
of transmission lines in the Eastern and Western Interconnections covering portions of 
Arizona, Arkansas, Colorado, Iowa, Kansas, Louisiana, Minnesota, Missouri, Montana, 
Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, and 
Wyoming; and (2) administers the Integrated Marketplace, a centralized day-ahead and 
real-time Energy and Operating Reserve market with locational marginal pricing and 
market-based congestion management.12 SPP also implements a resource adequacy 
 
11  
Sw. Power Pool, Inc., 109 FERC ¶ 61,009 (2004), order on reh’g, 110 FERC ¶ 61,137 
(2005). 
12  
Sw. Power Pool, Inc., 146 FERC ¶ 61,130 (2014) (approving the start-up and operation of 
the Integrated Marketplace).

6 
program under Attachment AA of the Tariff, under which Load Responsible Entities 
(“LRE”) must demonstrate sufficient accredited resource capacity to satisfy their load and 
an SPP-established Planning Reserve Margin (“PRM”) for the Summer Season and Winter 
Season, or else face significant charges for failure to meet their Resource Adequacy 
Requirement (“RAR”). 
B. 
Role of Stakeholders and States in SPP  
SPP operates under a stakeholder-driven governance model in which proposed 
revisions to the Tariff, Bylaws, Membership Agreement, and business practices are 
developed through an open, collaborative process involving market participants, 
transmission owners, state regulators, and other stakeholders before being considered by 
the SPP Board of Directors (the "Board") and, where applicable, filed with the 
Commission. This Commission-approved governance framework, established in SPP's 
Bylaws, Membership Agreement, and organizational governance documents, provides 
multiple opportunities for stakeholder discussion, refinement, and voting as proposals 
progress through technical working groups, policy committees, and ultimately to the 
Board. 
This collaborative governance structure has been central to SPP's response to 
unprecedented large load growth. The stakeholder initiatives discussed throughout this 
report were each developed through this established process with significant stakeholder 
participation. Of particular importance are the SPP Regional State Committee ("RSC") and 
the Resource and Energy Adequacy Leadership Team ("REAL Team"), both of which have 
played key roles in shaping SPP's evolving resource adequacy framework. Under the SPP 
Bylaws, the RSC possesses defined authority over regional cost allocation methodology

7 
and resource adequacy matters.13 Complementing that role, the REAL Team was 
established in January 2023 to evaluate SPP’s long-term resource adequacy construct and 
to develop recommendations addressing emerging reliability challenges associated with 
changes in the resource mix, extreme weather events, and rapidly increasing electric 
demand.14  
III. 
CURRENT STATE OF RESOURCE ADEQUACY  
 
Since adopting Attachment AA of the Tariff in 2018, SPP has continued to 
strengthen its Resource Adequacy framework to address fundamental changes in the 
resource mix and unprecedented demand growth across the SPP Region. Historically, the 
Resource Adequacy program focused primarily on ensuring that each LRE procured 
sufficient generating capacity to meet its forecasted seasonal peak demand plus an 
established PRM.15 In recent years, however, accelerating growth in large commercial and 
industrial loads together with generator retirements and an evolving resource mix have 
 
13  
Southwest Power Pool, Inc., Bylaws, First Revised Volume No. 4, Section 7.2. The RSC 
has primary responsibility for determining regional proposals and the transition process in 
the following areas: (1) whether and to what extent participant funding will be used for 
transmission enhancements; (2) whether license plate or postage-stamp rates will be used 
for the regional access charge; (3) determination of financial transmission rights (“FTRs”) 
allocations where a locational price methodology is used; and (4) determination of the 
transition mechanism to be used to assure that existing firm customers receive FTRs 
equivalent to the customers’ existing firm rights; and (5) determination of the approach for 
resource adequacy across the entire region. 
14  
Resource and Energy Adequacy Leadership Team, Organizational Group Scope Statement, 
Southwest 
Power 
Pool, 
Inc. 
(Jan. 
2023) 
https://spp.org/documents/68934/real_scope_statement%20final.pdf. The REAL Team is 
composed of members from the RSC, the Board, the Members Committee, the Strategic 
Planning Committee, the Cost Allocation Working Group (“CAWG”), and the Supply 
Adequacy Working Group (“SAWG”). 
15   
See Summer Resource Adequacy Report posted at: 
https://spp.org/documents/76932/2026%20spp%20summer%20resource%20adequacy%2
0report.pdf (“Summer 2026 Resource Adequacy Report”).

8 
required SPP to modernize both its resource accreditation methodology and its load 
forecasting processes.16  
The most significant recent enhancement is SPP's transition to a planning margin 
based on accredited capacity (Accredited Capacity Planning Reserve Margin, “Accredited 
Capacity PRM”) framework beginning with the Summer 2026 Resource Adequacy 
season.17 Under this framework, resource capability is no longer measured solely by 
installed or nameplate capability. Instead, SPP utilizes Performance-Based Accreditation 
(“PBA”) for conventional generation and Effective Load Carrying Capability (“ELCC”) 
methodologies for wind, solar, and battery Resources to more accurately reflect each 
resource's expected reliability contribution during periods of system stress.18 For Summer 
2026, LREs were required to satisfy their RAR using accredited capacity and a system-
wide Accredited Capacity PRM of 7.06 percent.19  
The transition to accredited capacity represents a significant advancement in SPP's 
resource adequacy framework by aligning resource accreditation with actual performance 
rather than simply relying on installed capability with limited testing to ensure capacity 
adequacy in SPP. This provides a more accurate assessment of regional reliability while 
 
16  
Keeping the Lights On: Examining the State of Regional Grid Reliability (Testimony of 
Lanny Nickell, Executive Vice President, Chief Operating Officer, Southwest Power Pool, 
Inc. Before the House Energy & Commerce Subcommittee on Energy), 119th Cong., 3-4 
(Mar. 25, 2025), available at: 
 
https://www.congress.gov/119/meeting/house/118040/witnesses/HHRG-119-IF03-
Wstate-NickellL-20250325.pdf. 
 
17  
See Summer 2026 Resource Adequacy Report. 
 
18  
Id. 
 
19  
Id.; see also Conventional Resources Class Averages – Summer 2026 posted at: 
https://spp.org/documents/74895/conventional%20unit%20class%20averages%20-
%20summer%202026.pdf.

9 
creating technology-neutral incentives for resource performance during critical system 
conditions.  
A. 
Current Resource Adequacy Outlook  
SPP's most recent Summer 2026 Resource Adequacy Report concludes that the SPP 
Region is adequately positioned to meet expected Summer 2026 demand while also 
providing an outlook through the Summer 2031 planning horizon.20 The report evaluates 
existing accredited Resources, anticipated retirements, planned generation additions, and 
projected demand growth across the SPP East Balancing Authority Area. For the 2026 
Summer Season, all sixty-five LREs satisfied their RAR.21 Based on data submitted in the 
2026 Summer Season Workbook, the East BAA maintains a reserve margin of 17.1%, 
representing approximately 5,752 MW of excess accredited capacity above the total RAR. 
This is an increase of approximately 2,500 MW of excess capacity compared to the 2025 
Summer Season. More than half of all LREs maintain reserve margins exceeding 16%, 
representing capacity in excess of approximately one-third of LRE forecasted Net Peak 
Demand.22 The 2026 Summer Season Workbook does not address the West BAA because 
the West BAA is not required to meet SPP’s resource adequacy processes and procedures 
until summer 2027. 
B. 
Integration With Recent Large Load Initiatives 
While current resource adequacy projections indicate that the East BAA is well 
positioned to meet near-term demand, SPP recognizes that rapidly increasing load forecasts 
 
20  
See Summer 2026 Resource Adequacy Report. 
 
21  
Id. 
 
22  
See Summer 2026 Resource Adequacy Report.

10 
represent one of the greatest sources of uncertainty in future resource adequacy planning. 
Much of this uncertainty stems from unprecedented load interconnection requests 
associated with data centers and other large commercial and industrial customers, many of 
which have historically been incorporated into utility load forecasts before development 
plans were sufficiently mature. Traditional planning processes were designed to 
accommodate incremental load growth rather than the addition of individual customers 
with demand measured in hundreds of megawatts. Recognizing that accurate demand 
forecasts are fundamental to effective resource adequacy planning, SPP also filed Tariff 
revisions in April 2026 to implement the Peak Demand Assessment,23 establishing a more 
structured process for validating forecasted peak demand and strengthening accountability 
by ensuring that all loads (including projected large loads) for the upcoming season are 
supported by sufficient amounts of Accredited Capacity.   
IV. 
SPP’S EXISTING FRAMEWORK FOR EVALUATING AND SERVING 
NEW LARGE LOADS24  
 
SPP has developed a coordinated framework of planning, interconnection, 
transmission service, and resource adequacy processes to address growing demand and 
support the reliable integration of new large loads. Rather than addressing large load 
 
23  
The PDA Filing is pending before the Commission. 
 
24  
While this Informational Report primarily focuses on the evolution of SPP policies directly 
 targeted at large load interconnections, SPP has implemented several complementary  
 initiatives that strengthen resource adequacy. These include annual updates to the Cost of  
 New Entry (“CONE”), which preserve appropriate incentives for LREs to procure 
 sufficient Accredited Capacity; implementation of the Consolidated Planning Process  
 (“CPP”), which integrates long-term transmission planning and generator interconnection 
 into a single, cohesive framework to better accommodate evolving resource and load needs  
 and speed up interconnection processing; and development of the Surplus Plus  
 interconnection reforms, which facilitate more timely additions of incremental generation 
 using existing transmission capability.

11 
requests as isolated transmission issues, SPP evaluates them through an integrated 
framework designed to accommodate significant load growth while preserving the reliable 
operation of the Transmission System. 
A. 
ERAS 
On May 22, 2025, SPP submitted Tariff revisions to add the ERAS process 
establishing a one-time, accelerated pathway for new generating resources to help address 
urgent reliability needs through 2030.25 The Commission accepted the ERAS Filing on July 
21, 2025, with an effective date of July 22, 2025.26 SPP developed ERAS in collaboration 
with the RSC, REAL, and other stakeholders in response to the growing need to bring new 
generation resources online on an accelerated timeline. ERAS enables LREs to identify 
and secure the generating resources needed to maintain reliability across the SPP footprint, 
comply with the resource adequacy requirements set forth in Attachment AA of the Tariff, 
and satisfy their obligation to serve under applicable state or other governing law. To 
qualify for ERAS, a project was required to address an LRE's projected resource adequacy 
deficit, commit to achieving commercial operation within five years, and satisfy additional 
criteria demonstrating that the project was sufficiently developed and reasonably likely to 
achieve commercial operation in time to address identified resource adequacy needs.27 
ERAS operates separately from, but in parallel with, SPP's standard Generator 
Interconnection Procedures under Attachment V of the Tariff. 
 
25  
ERAS Filing at 25. Tariff, Attachment AW. At the time of the ERAS Filing, SPP predicted 
that the SPP Region could face a 2-3 GW accredited capacity shortfall by 2030. 
26  
Sw. Power Pool, Inc., 192 FERC ¶ 61,062 (2025) (“ERAS Order”). 
27  
Tariff, Attachment AW, Section 8.2.

12 
As a one-time study, ERAS accepted requests during a limited application 
window28 and is no longer accepting new requests as a one-time process. Participation by 
LREs during the application window was strong. As of the date of this Informational 
Report, there are 36 active ERAS requests representing approximately 13.3 GW of 
generating capacity and no requests have withdrawn.29 These requests remain on schedule 
in the study process.  ERAS Generator Interconnection Agreements (GIA) are currently in 
the negotiation phase and SPP expects to advance to the execution phase in September 
2026. The process is on track to achieve its primary objective of accelerating the 
interconnection of generating resources needed to address near-term resource adequacy 
concerns. Although ERAS was designed as a one-time initiative, it demonstrated SPP's 
ability to accelerate the development of reliability-critical generation through a targeted 
stakeholder-driven process and established an important foundation for subsequent large 
load and resource adequacy reforms. 
B. 
Provisional Load Process  
On June 4, 2025, SPP submitted Tariff revisions to add a Provisional Load Process, 
documented in Attachment AX of the Tariff.30 The Commission accepted the Provisional 
Load Process Filing on October 10, 2025, with an effective date of August 4, 2025.31 While 
 
28  
Following Commission approval of the ERAS process on July 21, 2025, SPP opened the 
one-time ERAS application window on September 2, 2025, and closed the window on 
October 2, 2025. 
29  
See SPP Operations Portal of GI Active Requests posted at:  
https://opsportal.spp.org/Studies/GIActive and 
https://app.powerbigov.us/view?r=eyJrIjoiNTFhODQ5MjEtMTQ1My00ZjI5LWFjNWIt
ZmQ3NGQxNzM1ZDZiIiwidCI6IjMyMzA5MjZhLTcxYjctNDM3MC1hMTM3LTE5N2
JhZGMwNjZhMiJ9. 
30  
Provision Load Process Filing. Tariff, Attachment AX. 
31  
Sw. Power Pool, Inc., 193 FERC ¶ 61,018 (2025) (“Provision Load Process Order”).

13 
the HILL process described below is designed for large, high-impact loads, the Provisional 
Load Process addresses a different challenge: the ability for SPP to study new proposed 
load additions prior to the Transmission Customers having existing resources online to 
support the new load. Under Attachment AQ, SPP may only study requests for new or 
modified delivery points when the Transmission Customer demonstrates that its existing 
Designated Resources are sufficient to serve both its existing forecasted load and the 
proposed new load over a ten-year horizon.32 As requests associated with large loads 
increased significantly, many Transmission Customers were unable to satisfy this 
prerequisite because the generation intended to serve the load had not yet completed the 
interconnection process or otherwise become an existing Designated Resource. As a result, 
SPP was unable to evaluate numerous otherwise viable load requests under its then-existing 
Tariff provisions. 
The Provisional Load Process was developed to address this gap. Using the same 
study methodologies used for other load connection studies, the Provisional Load Process 
allows SPP to study proposed delivery point additions using both existing Designated 
Resources and identified planned generation that is expected to serve the new load.33 
Importantly, the Provisional Load Process, alone, does not provide transmission service 
but instead serves as a planning mechanism that enables Transmission Customers to 
identify the transmission upgrades necessary to accommodate future load while their 
planned generation progresses through the applicable interconnection and transmission 
 
32  
Tariff, Part II, Section 17.9; Part III, Section 31.2; and Attachment AQ. 
33  
Tariff, Attachment AX.

14 
service processes.34 Because the generation relied upon in the study has not yet completed 
the interconnection process and may ultimately change or fail to materialize, the revenue 
requirements for Network Upgrades identified through the Provisional Load Process are 
treated as Directly Assigned Upgrade Costs and are allocated 100% to the Transmission 
Customer until the Transmission Customer acquires firm transmission service for the 
planned generation.35 Once the planned generation obtains Long-Term Service and 
becomes a Designated Resource, the remaining costs of those Network Upgrades transition 
to Base Plan funding consistent with Attachment J of the Tariff36 and the Transmission 
Customer’s Network Integration Transmission Service Agreement or Point-to-Point 
Transmission Service Agreement is updated to reflect the requested changes.37 This 
approach protects other loads within SPP from bearing the costs of upgrades associated 
with speculative or uncertain generation while still allowing transmission planning to move 
forward in support of anticipated load growth.  
As described in more detail in the following sections, SPP modified Attachment 
AX in the HILL and CHILLS Filings to integrate those frameworks into the existing 
Attachment AX process by requiring additional studies and information for qualifying 
 
34  
The Transmission Customer must  complete either the Aggregate Transmission Service 
Study assessing the planned Designated Resource or the expedited process for resource 
designation as described in Section 30.2.2 of the Tariff before the Transmission Customer’s 
Network Integration Transmission Service Agreement or Point-to-Point Transmission 
Service Agreement will be updated to reflect the requested changes. Tariff, Attachment AX, 
Addenda 2 and 3. 
35  
Tariff at Attachment J, Section V; Tariff at Attachment AX, Addendum 2 at Sections 6.0 
and 7.0; Tariff, Attachment AX, Addendum 3 at Sections 6.0 and 7.0 
36  
Tariff, Attachment J, Section III.A. 
37  
Tariff, Attachment AX, Addenda 2 and 3.

15 
HILLs and to provide Transmission Customers with additional flexibility when requesting 
studies for new load additions. 
C. 
HILLs and the HILLGA  
 
On October 24, 2025, SPP submitted Tariff revisions to add a HILL study process 
and the HILLGA.38 The Commission accepted the HILL Filing on January 14, 2026, with 
an effective date of January 15, 2026.39 The HILL Filing proposed two new mechanisms: 
(1) the HILL study process set forth in Attachment BA; and (2) the HILLGA process set 
forth in Attachment BB. The HILL Filing revisions (1) defined and created a new category 
of load, termed a “HILL”; (2) established enhanced study requirements for HILLs to enable 
SPP to assess the load’s reliability impacts on the Transmission System; and (3) established 
additional, ongoing operational requirements for HILLs to ensure continued reliability of 
the Transmission System.40 The HILLGA process consists of a new generator 
interconnection service and related interconnection process to allow the limited connection 
of supporting generation for HILLs on an expedited basis.41  
The HILL Filing revisions built upon the original Attachment AX framework by 
preserving Attachment AX as a vehicle through which HILLs may receive provisional 
transmission service while layering on the HILL-specific study and operational 
requirements established in Attachment BA. The revisions clarified that requests for new 
or modified delivery points associated with a HILL remain eligible for study under 
 
38  
HILL Filing. 
 
39  
Sw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026) (“HILL/HILLGA Order”). 
40  
HILL Filing at 11-38. 
41  
Tariff, Attachment BB.

16 
Attachment AX but must also satisfy the additional study and operational requirements 
established in Attachment BA.  
The Tariff defines a HILL as:  
A new commercial or industrial load, or increase in commercial or industrial 
load, at a single site connected through one or more shared Points of 
Interconnection (POIs) or delivery points, where such load is either (1) 10 
MW or more if connected to the Transmission System at a voltage level less 
than or equal to 69 kV; or (2) 50 MW or more if connected to the 
Transmission System at a voltage level greater than 69 kV. An Electric 
Storage Resource is not considered a HILL. A load may be categorized as a 
HILL after the initial effective date of Attachment BA of the Tariff.  High 
Impact Large Loads must register as such in accordance with Attachment 
AE of the Tariff and follow the processes specified in Attachment BA of the 
Tariff.42 
 
SPP processes all load additions and modifications, including HILLs, using its 
existing Attachment AQ, Attachment AX, and/or Attachment Z1 study processes.43 
However, for HILLs, SPP and the applicable Transmission Owner(s) simultaneously 
conduct additional studies under Attachment BA to ensure that the unique operational 
characteristics of HILLs are considered when evaluating the addition of a HILL to the 
Transmission System, and that SPP has mechanisms in place to maintain reliable operation 
of the Transmission System.44 Attachment BA also imposes ongoing operational 
requirements, including the addition of certain equipment, to ensure that SPP can continue 
 
42  
Tariff, Part I, Section 1, Definition of High Impact Large Load. 
43  
Through Attachment AQ, any existing customers may obtain firm transmission service for 
the modification of an existing delivery point or for the creation of a new delivery point. 
Under Attachment AX, existing customers may receive provisional study of a new or 
modified delivery point using planned generation, instead of existing Designated 
Resources. Lastly, new customers may receive transmission service for their load and 
Resources through Attachment Z1. 
44  
Tariff, Attachment BA, Sections 2.1.3.4 and 2.1.3.5.

17 
to manage the Transmission System while accommodating the unique operational demands 
and characteristics of HILLs.45  
The HILLGA process, outlined in Attachment BB, facilitates the prompt 
interconnection of generating resources that are specifically identified for and limited to 
serving a HILL, at the request of the HILLGA Customer.46 SPP studies HILLGA Requests 
outside of its existing generator interconnection process on a serial basis, but solely for the 
impact of the Generating Facility47 to serve the identified HILL.48 Unlike traditional 
interconnection service, HILLGA provides a limited form of interconnection service 
specifically designed to evaluate generation intended to serve an identified HILL.49  
D. 
CHILLS  
On February 10, 2026, SPP submitted Tariff revisions to add a CHILLS, that allows 
HILLs to be served with non-firm conditional transmission service.50 The Commission 
 
45  
Tariff, Attachment BA, Section 2.2. 
46  
Tariff, Attachment BB, Section 2. 
47  
Tariff, Attachment BB, Section 1, Definition of Generating Facility (“will mean a HILLGA 
Customer's device(s) for the production and/or storage for later injection of electricity 
identified in the HILLGA Request, but will not include HILLGA Customer's 
Interconnection Facilities and will not include a Storage as Transmission Only Asset as 
defined in Section 1 of the Tariff. A Generating Facility consists of one or more generating 
unit(s) and/or storage device(s) which usually can operate independently and be brought 
online or taken offline individually.”). 
48  
Tariff, Attachment BB, Section 3.1.2. 
49  
Tariff, Attachment BB, Section 3.2. The HILLGA does not grant the Generating Facility 
traditional generator interconnection service, such as Network Resource Interconnection 
Service (“NRIS”) or Energy Resource Interconnection Service (“ERIS”); instead, 
Generating Facilities studied under the HILLGA process receive much more limited “Load 
Limited Resource Interconnection Service” or “LLRIS,” which only studies the impact of 
the Generating Facility serving the identified HILL. 
50  
CHILLS Filing.

18 
accepted the CHILLS Filing on June 5, 2026, with an effective date of July 1, 2026.51 
CHILLS builds on the HILL and HILLGA processes to help further unlock the 
interconnection of large loads by facilitating service for HILLs by allowing a HILL (or a 
portion of a HILL) to receive the transfer of energy on a long-term, non-firm basis. 
The Attachment AQ and AX processes may delay service to otherwise ready HILLs 
and postpone the economic benefits associated with those projects. Delays could be related 
to construction of Network Upgrades or an inability to comply with the need to have 
sufficient Designated Resources to support the HILL. CHILLS mitigates this challenge by 
providing Transmission Customers with the ability to receive non-firm transmission 
service to HILL delivery points before (1) completion of any applicable Network Upgrades 
and/or (2) meeting the requirements for establishment of Designated Resources.52  
 
The CHILLS Filing further built upon the Attachment AX framework by clarifying 
which customers may be eligible for the Provisional Load Process. Specifically, a 
Transmission Customer may request the study of a new load addition pursuant to 
Attachment AX regardless of whether the Eligible Customer has sufficient Designated 
Resources to support the study, provided that the Eligible Customer elects not to use its 
existing Designated Resources for the proposed load addition.53 This framework provides 
 
51  
Sw. Power Pool, Inc., 195 FERC ¶ 61,196 (2026) (“CHILLS Order”). 
52  
Tariff, Part I, Section 1, Definition of Network Resource (“Any designated generating 
resource owned, purchased or leased by a Network Customer under the Network 
Integration Transmission Service Tariff.  Network Resources do not include any resource, 
or any portion thereof, that is committed for sale to third parties or otherwise cannot be 
called upon to meet the Network Customer's Network Load on a non-interruptible 
basis, except for purposes of fulfilling obligations under a reserve sharing program.”). 
53  
Tariff, Attachment AX, Section 1.

19 
flexibility to Transmission Customers in determining which Designated Resources will be 
associated with new load additions when studied for firm transmission service under the 
Tariff. 
CHILLS includes numerous reliability protections, including supporting generation 
requirements, enhanced engineering and operational studies, dedicated operating 
agreements, separate metering requirements, and SPP's authority to curtail or interrupt 
service during transmission constraints or Emergency Conditions. CHILLS are limited to 
a maximum seven-year term and requires customers to pursue permanent firm transmission 
service through existing Tariff processes, reinforcing that the service is intended as a 
temporary bridge rather than a substitute for long-term transmission solutions.  
Although CHILLS only recently became effective, SPP and its stakeholders 
continue to evaluate potential enhancements to improve its implementation and operation. 
SPP anticipates filing Tariff changes to clarify the sequencing of Resource commitments 
and Reliability-Resource Demand Response Program (RRDRP) deployments relative to 
CHILLs and establish a minimum Curtailment ramp rate for CHILLS.54 SPP also intends 
to propose Tariff revisions permitting limited outages for Resources supporting certain 
CHILLs.55 As a first-of-its-kind transmission service, CHILLS will continue to evolve. SPP 
and its stakeholders will continue refining the service where appropriate to improve its 
effectiveness while maintaining system reliability.  
E. 
PDA and Enhancements to the Participation of Demand Response 
Resources 
 
 
54  
See CHILL Clarification Revision Request posted at: https://www.spp.org/spp- 
documents-filings/?id=21069 (see zip file “RR767(SIR833) CHILL Clarification). 
55  
See CHILL Outage Criteria Revision Request posted at: https://www.spp.org/spp- 
documents-filings/?id=21069 (see zip file “RR768(SIR823) CHILL Outage Criteria).

20 
 
On April 17, 2026, SPP submitted Tariff revisions to strengthen its Resource 
Adequacy framework through implementation of a PDA and enhancements to the 
participation of Demand Response Resources.56 The PDA Filing is pending before the 
Commission with a requested effective date of January 1, 2027. The filing was developed 
in response to accelerating load growth, including the emergence of large data center 
demand, increasing uncertainty in load forecasting, and the continued evolution of the 
resource mix across the SPP Region, including the anticipated increased reliance on 
Demand Response Programs by LREs to meet the RAR while dealing with the 
aforementioned load growth. 
Just as SPP recently modernized how resource capability is measured through the 
Accredited Capacity PRM framework, the PDA modernizes how demand is forecasted and 
measured for resource adequacy purposes. Together, these reforms strengthen both sides 
of SPP's resource adequacy framework by improving the accuracy of the capacity available 
to serve load and the forecasted demand against which that capacity is evaluated. The PDA 
shifts resource adequacy accountability from a solely forecast-based, pre-season 
evaluation57 to a financially binding post-season assessment based on actual, weather-
normalized peak demand.  
Under the revised framework, SPP would continue to validate each LRE’s qualified 
capacity before each season through a new Pre-Season Requirement, while determining 
compliance with the RAR after the season using verified demand data.58 This approach 
 
56  
PDA Filing. 
57  
Tariff, Attachment AA, Section 12 entitled, “Post-Season Analysis.” 
58  
PDA Filing at 6.

21 
addresses a key limitation of the existing framework by establishing accountability for 
material under-forecasting of load while preserving the operational benefits of pre-season 
resource qualification. By relying on actual metered data and weather-normalized peak 
demand, the PDA better aligns resource adequacy obligations with actual system 
conditions, particularly as large loads introduce greater variability and uncertainty into 
forecasting.59 
The PDA Filing also modernizes SPP's treatment of Demand Response Resources 
by integrating qualifying Demand Response Resources more fully into the Resource 
Adequacy framework.60 The revisions permit market-registered Demand Response 
Resources to serve as capacity Resources, establish a new RRDRP that may receive 
accredited capacity, implement performance-based accreditation using historical 
performance, and enhance operational and deployment requirements to ensure dependable 
performance during system stress and emergency conditions.61 These revisions provide 
greater operational visibility into available Resources while creating incentives for both 
accurate load forecasting and reliable Demand Response performance.  Additionally, the 
PDA filing permits LREs to implement non-registered load-modifying Demand Response 
programs that are not registered in the Integrated Marketplace and do not qualify as 
RRDRP. This flexibility allows LREs to actively manage their peak demand in real time, 
supporting compliance with their load forecasts while ensuring their demand remains 
consistent with the capacity they qualified for under the Pre-Season Requirement. 
 
59  
Id. 
60  
Id. 
61  
Id.

22 
Together, the PDA and Demand Response reforms complete a broader set of 
coordinated transmission planning, interconnection, and resource adequacy reforms. When 
considered alongside the previously approved Provisional Load Process, the HILL and 
HILLGA frameworks, the ERAS reforms, and related stakeholder initiatives, these 
measures illustrate SPP's integrated approach to accommodating significant load growth 
while preserving reliability and ensuring resource adequacy. 
F. 
CPP 
In addition to initiatives specifically focused on large loads and resource adequacy, 
SPP has undertaken broader reforms to its regional transmission planning processes that 
will improve the region's ability to identify and address transmission needs associated with 
evolving load growth, changing resource portfolios, and increasing system complexity. 
One such initiative is CPP, which streamlines multiple existing transmission planning 
assessments into a single, coordinated planning framework. 
Historically, SPP conducted several planning studies independently, each with 
distinct objectives, assumptions, and study horizons. While these planning processes 
provided valuable information, the separate study cycles could result in duplicative 
analyses, differing assumptions, and limited opportunities to evaluate transmission needs 
holistically. As the region experiences accelerating load growth—including requests to 
serve large new loads—along with significant generation interconnection activity and 
evolving resource adequacy needs, SPP recognized the value of integrating these planning 
efforts into a unified process. 
The CPP establishes a coordinated planning cycle that evaluates reliability, 
economic, operational, and public policy-driven transmission needs using a common set of

23 
assumptions and coordinated stakeholder input. By consolidating these planning activities, 
SPP is better positioned to evaluate transmission solutions across multiple planning 
objectives, improve consistency in forecasting future system conditions, and identify 
projects that provide broad regional benefits. The process also enhances transparency by 
providing stakeholders with a single planning framework through which assumptions, 
study methodologies, and recommended transmission solutions can be reviewed and 
refined. 
Although the CPP is not directed solely at accommodating large loads, it 
strengthens the planning foundation needed to address significant changes in demand 
across the SPP footprint. As large industrial facilities, data centers, electrification, and 
other emerging loads increasingly influence long term transmission needs, the CPP 
provides a more integrated process for evaluating how those loads interact with generation 
development, resource adequacy requirements, and regional transmission expansion. This 
integrated planning approach enables SPP to assess transmission needs using consistent 
planning assumptions while considering the cumulative impacts of multiple drivers 
affecting the Transmission System. 
The CPP complements SPP's other initiatives discussed in this report, including 
enhancements to the HILL framework, the HILLGA process, resource adequacy reforms, 
and other transmission planning improvements. Together, these efforts are intended to 
improve SPP's ability to plan for and reliably serve substantial new load growth while 
maintaining an efficient, transparent, and stakeholder-driven regional planning process. 
V. 
PRICE ADAPTIVE LOADS (PALs) AND PRICE ADAPTIVE LOAD 
SERVICE (PALS) 
 
A. 
Overview

24 
 
The Price Adaptive Load (PAL) and Price Adaptive Load Service (PALS) 
framework establishes a new market participation model and transmission service option 
specifically designed for large, price-responsive loads.62 Unlike the initiatives discussed in 
Section IV, PAL/PALS remains under active stakeholder development and has not yet been 
submitted to the Commission. Accordingly, the discussion below summarizes the current 
proposal and anticipated stakeholder schedule. 
The PAL/PALS framework is intended to accommodate a new class of commercial 
and industrial customers—such as certain data centers and advanced manufacturing 
facilities—that are capable of adjusting or interrupting electricity consumption in response 
to real-time market conditions while reducing reliance on traditional firm transmission 
service. Participating PALs would be economically dispatched through SPP's Integrated 
Marketplace based on submitted price-sensitive bids and would be required to respond to 
dispatch instructions in both the Day-Ahead Market and Real-Time Balancing Market. To 
support this market participation model, the proposal also creates Price Adaptive Load 
Service (PALS), a new non-firm transmission service designed specifically for 
dispatchable, flexible loads. Unlike traditional transmission service, PALS would utilize a 
usage-based billing structure and require participating loads to be fully dispatchable, 
capable of rapidly reducing consumption, and subject to Curtailment during transmission 
constraints, Emergency Conditions, or local reliability events.  
The PAL/PALS framework represents the next evolution of SPP's large load 
strategy by providing a market-based option for flexible loads that complements SPP's 
 
62  
RR 791.

25 
existing planning, transmission service, interconnection, and resource adequacy reforms. 
Where SPP's previously approved reforms focused primarily on ensuring that sufficient 
generation, transmission capability, and planning processes exist to support unprecedented 
load growth, the PAL/PALS proposal recognizes that some emerging large loads possess 
operational flexibility that can itself become a valuable reliability and market resource. By 
creating a market participation model and transmission service tailored to those 
characteristics, PAL/PALS would complement SPP's existing framework while expanding 
the range of tools available to integrate large flexible loads reliably and efficiently. 
B. 
Stakeholder Schedule and Expected Milestones  
 
The PAL/PALS initiative is the product of extensive stakeholder development that 
has included technical design, stakeholder education, Tariff drafting, and publication of the 
associated Revision Request (RR). Development began with an internal team of SPP staff 
meetings during the first quarter of 2026 to establish the framework and refine the 
modeling approach. Beginning in April 2026, SPP initiated a broad stakeholder education 
effort, presenting the concepts to the Cost Allocation Working Group (“CAWG”), 
Operating Reliability Working Group (“ORWG”), Markets Working Group (“MWG”), 
Regional Tariff Working Group (“RTWG”), and other stakeholder groups to introduce the 
proposal and solicit early feedback. 
During May and June, the stakeholder process advanced from conceptual 
development to preparation of Tariff revisions necessary to implement the PAL/PALS 
design framework. SPP also hosted question-and-answer sessions and multiple stakeholder 
forums to discuss the proposal, gather additional feedback, and refine the draft revisions. 
The PAL/PALS RR was posted for stakeholder review on July 9, 2026.

26 
SPP intends to continue its extensive outreach efforts through additional 
stakeholder forums and educational presentations across numerous working groups, 
including the MWG, RTWG, Supply Adequacy Working Group (“SAWG”), Transmission 
Working Group (“TWG”), Economic Studies Working Group (“ESWG”), ORWG, 
CAWG, RSC, and the Markets and Operations Policy Committee (“MOPC”). The proposal 
is expected to advance through the formal stakeholder approval process from August 
through November 2026, with individual working groups considering the revisions before 
final votes by MOPC on October 13, 2026, and the RSC on November 16, 2026. Assuming 
stakeholder approval, SPP intends to file the PAL/PALS proposal with the Commission on 
or before November 16, 2026. This timeline reflects SPP's collaborative stakeholder 
process, which is designed to provide multiple opportunities for education, technical 
discussion, stakeholder input, and formal approval before being filed with the Commission. 
VI. 
ONGOING WORK OF THE REAL TEAM 
 
In 2023, as mentioned above, the SPP Board established the REAL Team to assess 
SPP’s current resource adequacy construct and anticipated challenges resulting from 
resource mix changes, extreme weather impacts, increased demand, and evolving 
consumer behaviors. REAL provides guidance, prioritization, and policy recommendations 
needed to increase assurance that sufficient energy to meet load requirements can be 
continuously and cost-effectively provided within the SPP Balancing Authority Areas 
(“BAA”). The REAL Team consists of a diverse membership from various SPP 
stakeholder groups, including the SPP Board, transmission owning members, transmission 
using members, and state commission representatives.

27 
As seen on the REAL Teams work plan,63 the REAL Team will address a number of 
Resource Adequacy issues in 2027, including Seasonal Resource Adequacy Construct, use 
of non-firm imports in the development of the planning reserve margin, non-weather 
related load uncertainty, and the use of coincident peak instead of non-coincident peak in 
SPP’s resource adequacy requirements. Through this work, SPP is continuing its steadfast 
commitment to ensuring that SPP continues to have sufficient resource capacity to meet 
current and projected load growth in both SPP BAAs. 
VII. 
CONCLUSION 
SPP continues to work with stakeholders to refine its planning, transmission, 
market, operations, and resource adequacy frameworks as large load development 
continues to evolve across the region. The initiatives described in this report reflect SPP's 
coordinated approach to integrating large loads while preserving reliability, maintaining 
resource adequacy, and protecting existing customers. SPP respectfully requests the 
Commission accept this report as responsive to the Commission’s directive to submit an 
informational report in the Show Cause Order. 
 
Respectfully submitted, 
/s/ Meredith Powell 
 
 
Meredith Powell 
Attorney 
 
 
Southwest Power Pool, Inc. 
201 Worthen Drive 
 
 
Little Rock, AR 72223 
   
 
 
mpowell@spp.org 
 
 
63  
REAL Team meeting materials on the June 17, 2026, item number 5: 
             https://www.spp.org/Documents/76913/REAL%20Meeting%2020260617.zip

28 
Attorney for 
Southwest Power Pool, Inc. 
 
July 20, 2026

CERTIFICATE OF SERVICE 
 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Little Rock, Arkansas, this 20th day of July, 2026. 
 
 /s/ Cassie Butler 
Cassie Butler 
Southwest Power Pool, Inc. 
201 Worthen Drive 
Little Rock, AR 72223-4936 
(501)