Today we approve Southwest Power Pool, Inc.’s (SPP) Markets+ proposal and we concur in that approval, because Markets+ has the potential to bring significant benefits to Western electricity consumers through greater competition and more efficient operation of the transmission system. We write separately, however, to raise an important issue of governance that we urge be addressed expeditiously by SPP.
Markets+ will expand SPP’s geographic footprint into the Rocky Mountain West with its great diversity of states, along with their shared and respective interests. While the Markets+ proposal is not a full regional transmission organization (RTO) at this time, it is nonetheless timely to raise an important issue of governance that is pertinent not only to the Markets+ proposal with its proposed Markets+ State Committee, but also to SPP – which obviously is a full RTO – and specifically its Regional State Committee (RSC) as well. That issue is the absence of dedicated stafffor either the Markets+ State Committee or the RSC, staff who are hired by and work exclusively for the state organizations, with adequate funding to support these staffthrough a tariff provision, and whose sole responsibility would be to support the work of the states’ organizations, not any other organization, including SPP itself.
Along with PJM Interconnection, L.L.C. (PJM) and the Midcontinent Independent System Operator, Inc. (MISO), SPP is one of the three largest multi-state RTOs in the country. Unlike SPP’s RSC, however, both PJM and MISO have successfully established state organizations with dedicated staff and funding who work directly for those state organizations, not for the RTO nor for other organizations. This structure is not unique: PJM has the Organization of PJM States, Inc. (OPSI), and MISO has the Organization of MISO States (OMS). Both OPSI and OMS have long played critically important roles in representing the states and, importantly, their millions of consumers and the public interest, in those large RTOs. The full-time staffs of OPSI and OMS, who work exclusively for those organizations, are essential to the vital roles played by those organizations of state regulators.
Here, however, staff support for the Markets+ State Committee (which will provide advice to the Markets+ Independent Panel, the Markets+ Participants Executive Committee, and any working group or task force on all matters pertinent to Markets+) will be facilitated by SPPitself. In its comments, the Markets+ State Committee provides clarification that it will be staffed by the Western Interstate Energy Board (WIEB), which also provides staff support and technical expertise to several other established Western committees, including the Committee on Regional Electric Power Cooperation (CREPC), the Western Interconnection Regional Advisory Body (WIRAB), the Western Energy Imbalance Market Body of State Regulators (BOSR), and the Western Resource Adequacy Program (WRAP) Committee of State Representatives(CSR). As valuable as WIEB staff are, we believe RTOstate regulator organizations must have their own dedicated staff to be effective in evaluating and advising on RTO matters, especially when it comes to the impact of those matters on individual states and their consumers.
The absence of a dedicated staff for the RSC and for theMarkets+ State Committee prevents states in SPP and those in Markets+ from participating more meaningfully. Knowledge is power, and state organizations must have dedicated staff to obtain the requisite knowledge to act effectively. We believe it is imperative for states to be active participants in RTO matters. If not, states and the consumers they represent may not realize the full benefits of RTO participation, and states may be saddled with costs that their consumers will be forced to pay, a concern the Markets+ State Committee highlights in its comments on this proceeding. Simply put, the Markets+ State Committee’s position is clear: states need resources to do the jobs with which they have been tasked consistent with its public interest mandates.
As it launches Markets+, now is the right time for SPP to take action to remedy the flaws in its governance, for both the Markets+ State Committee and the RSC. OPSI and OMS have demonstrated that dedicating staff and resources to support state participation can be done cost-effectively. For example, OPSI has annual expenses of roughly $1 million, which represents just .002% of PJM’s total annual billings in 2023. As the energy industry becomes increasingly more complex, it is critical that states have the resources and staff they need to participate fully. The promotion and defense of the public interest in each member state demands no less.
For these reasons we respectfully concur.
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Mark C. Christie
Commissioner
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David Rosner
Commissioner