Docket No. ER24-1583-001
As I did in the underlying order, I concur only in the result, which herein is to sustain the acceptance of SPP’s proposal.
The petitions for rehearing make compelling arguments, many of which I naturally agree with because they quote from my earlier concurrence. At the end of the day, however, I will continue to defer to the SPP Regional State Committee (RSC), which has historically had a unique and authoritative role representing the states in SPP. I will note, however, that I find the failure of the RSC to file any separate comments or to better seek to explain its support of this extraordinary exception to the Highway/Byway method, to be disappointing. A mere reference to an RSC vote in the Minutes of a meeting, with no articulated rationale from the RSC itself filed in this record, is weak support[1] and may not be persuasive in the future, especially if the RSC vote is divided.
For these reasons I respectfully concur in the result.
[1] My understanding is that the RSC, in contrast to the Organization of PJM States, Inc. and the Organization of MISO States, Inc., does not have its own independent staff that could prepare comments and filings on behalf of the states in the RSC.