Docket Nos. ER24-2797-001, et al.
I write separately to re-emphasize the points I made in my prior concurrence to the underlying order,[1] which today’s order properly sustains.
Briefly, these points are: (1) the projects that make up Joint Targeted Interconnection Queue (JTIQ) Portfolio #1, the first projects identified in the study undertaken by Midcontinent Independent System Operator, Inc. (MISO) and Southwest Power Pool, Inc. (SPP), would not have been selected in MISO’s and SPP’s regional transmission plans for purposes of cost allocation, and so it is appropriate for the primary funding for these projects to be borne by the interconnection customers, i.e., the generation developers these projects were primarily designed to serve; and (2) the backstop funding mechanism, a key component of the JTIQ framework and one where load—a/k/a “consumers” —provides backstop funding under certain conditions, is only just and reasonable with the U.S. Department of Energy Grid Resilience and Innovating Partnerships funding, covering approximately 25% of the total JTIQ Portfolio #1 capital costs.
Today’s order, importantly, continues to recognize that consumers are not the primary beneficiaries of JTIQ Portfolio #1. But from my perspective, absent this federal grant funding, it would be unjust and unreasonable to allocate to consumers any of the costs of JTIQ Portfolio #1. Should the federal funding situation change, I question whether JTIQ’s cost allocation, which relies on the backstop funding mechanism, truly comports with the cost causation principle. In other words, if the federal funding is withdrawn, consumers should be held harmless from any costs of JTIQ Portfolio #1, and the backstop funding mechanism should be revisited for future JTIQ portfolios.
For these reasons, I respectfully concur.
[1] Midcontinent Indep. Sys. Operator, Inc., 189 FERC ¶ 61,108 (2024) (Christie, Comm’r, concurring), https://www.ferc.gov/news-events/news/commissioner-christies-concurrence-miso-spp-jtiq-proposal-er24-2797.