Chairman Richard Glick Statement
March 9, 2021
Docket No. ER21-835-000
I support today’s order accepting the unexecuted Facilities Service Agreement (FSA) among Heartland Divide Wind II, LLC as interconnection customer, MidAmerican Energy Company as transmission owner, and Midcontinent Independent System Operator, Inc. (MISO), because it conforms with MISO’s pro forma FSA and reflects the state of the law today. However, I write separately to reiterate my concern that giving transmission owners the discretion to unilaterally choose whether to self-fund network upgrades constructed on behalf of affiliated and non-affiliated interconnection customers may be unjust and unreasonable and unduly discriminatory or preferential.[1] The Commission failed to meaningfully wrestle with these concerns in its orders allowing transmission owners the unilateral right to choose up-front funding.[2]
For these reasons, I respectfully concur.