Commissioner James Danly Statement
December 16, 2022
ER22-477-002
I dissent from the Commission’s order addressing the arguments raised on rehearing[1] and direct the reader to my dissent to the underlying order.[2] In the underlying order, the Commission rejected Midcontinent Independent System Operator, Inc.’s (MISO) tariff revisions, thereby denying MISO’s request to allow transmission owners to unilaterally elect to fund Merchant High Voltage Direct Current (MHVDC) transmission connection requests with and without Injection Rights and denying the transmission owners’ right to receive a return on and of the capital costs of network upgrades, necessary upgrades, and transmission owner system protection facilities, identified in the MHVDC Transmission Connection Procedures.[3] Today’s order sustains that result—a result that I disagree with. For the reasons stated in my separate statement to the underlying order, I would have found MISO’s tariff revisions to be just and reasonable.
For these reasons, I respectfully dissent.