Docket No. ER25-943-000
Today’s order denies a waiver request made by MISO and SPP that would have allowed them to plan for interregional transmission projects more efficiently and comprehensively. I understand my colleagues’ perspectives, but I believe that MISO and SPP satisfy the Commission’s waiver criteria. Therefore, I respectfully dissent.
Under their Joint Operating Agreement (JOA), MISO and SPP conduct a Coordinated System Plan (CSP) study at least once every two years to identify interregional transmission solutions benefitting both regions. As MISO and SPP explain, however, the CSP study has not yielded any such projects for more than a decade.[1]
To address this issue, MISO, SPP, and their respective stakeholders developed a proposal to waive, on a one-time basis, two JOA provisions related to technical planning assumptions. As they explain, doing so will better tailor the study to their regional needs, making it more likely to yield useful results. The waiver does not create a new study process; nor does it change project selection criteria or cost allocation provisions. Instead, MISO and SPP merely ask for permission to use more accurate study assumptions. In my view, this request readily satisfies the Commission’s waiver criteria.
The Commission should not stand in the way of simple solutions that give MISO, SPP, and their stakeholders flexibility to improve the accuracy of their study. The alternative compels MISO and SPP to commit resources towards an inefficient study and prevents the regions from identifying needed interregional transmission projects. I commend MISO, SPP, and their stakeholders for collaborating, and I encourage MISO and SPP to submit the changes proposed in this waiver request under FPA section 205.
For these reasons, I respectfully dissent.
[1] Waiver Request at 5.