Docket No. ER20-2054-000
I vote to approve today’s order because it correctly applies both ISO-NE’s Formula Rate Protocols and the Commission’s prudence standard. I write separately to reiterate here what I have said in other contexts about the importance of transparency.1
It has become clear that many state regulators and consumer advocates lack confidence regarding the need for these utility-planned projects. In my view, utilities should work harder to demonstrate the need for their projects. Simply put, when customers are concerned about whether a project is needed, utilities’ response should always be: “Let us show you why it is.” In the context of growing demand and an aging electric grid, building trust and confidence in the need for infrastructure will only serve to expedite permitting and improve the likelihood that projects are ultimately constructed.
On separate tracks, there are efforts by states2 and regions3 to oversee these projects. I encourage others to consider doing the same and stand ready to work with my colleagues as we consider similar proposals.
For these reasons, I respectfully concur.
- 1See, e.g., Kammer Juniata Transmission, LLC, 196 FERC ¶ 61,015 (2026), (Rosner, Comm’r, concurring, at P 2) (“Transparency as to how the Commission will consider requests for incentive rate treatments is essential to increasing certainty that needed infrastructure is ultimately constructed.”); ISO New England Inc., 195 FERC ¶ 61,215 (2026) (Rosner, Comm’r, concurring, at P 8) (“Transparency is important because ‘who pays?’ has been and continues to be a fraught and contentious question for large load interconnection.”).
- 2See, e.g., Advanced Grid Technologies Act, A.B. 5188, 222d Leg., 2026-2027 Sess. (N.J. 2026), https://www.njleg.state.nj.us/bill-search/2026/A5188.
- 3See, e.g., ISO New England Inc., Revision to Establish ISO New England Inc. as the Asset Condition Reviewer, Docket No. ER26-3533-000 (Aug. 17, 2026); see also https://www.iso-ne.com/committees/key-projects/asset-condition-reviewer.