Docket Nos. ER24-2797-000, ER24-2871-000, ER24-2798-000, ER24-2825-000
I concur with today’s order, which largely accepts Midcontinent Independent System Operator, Inc.’s (MISO) and Southwest Power Pool, Inc.’s (SPP) (together, RTOs) Joint Targeted Interconnection Queue (JTIQ) proposal. It is worth writing separately, however, to emphasize that the projects that make up JTIQ Portfolio #1, the first projects identified in the study undertaken by the RTOs, would not have been selected in the RTOs’ regional transmission plans for purposes of cost allocation.[1] These projects are not designed to serve load, i.e., consumers, with optimal solutions to identified reliability concerns or economic drivers. Rather, the primary purpose of these projects is to provide interconnection customers—generation developers, primarily wind and solar—with more interconnection opportunities. Accordingly, it is appropriate that the primary funding for these projects is from the generation developers themselves as they are the primary beneficiaries.[2]
A key component of the JTIQ proposal involves load providing backstop funding for JTIQ Portfolio #1, and to justify this backstop funding, today’s order establishes that benefits to load are sufficient for purposes of the cost causation principle.[3] This is only true, and the backstop funding mechanism is only just and reasonable, however, with the U.S. Department of Energy Grid Resilience and Innovating Partnerships funding, covering approximately 25% of the total JTIQ Portfolio #1 capital costs.[4] Without this funding, it would be unjust and unreasonable to allocate to load any of the costs of JTIQ Portfolio #1. These projects were not designed to serve load, plain and simple, and if there were no funding, the JTIQ proposal would not be acceptable.
For these reasons, I respectfully concur.