Today’s order approves SPP’s Consolidated Planning Process, a proposal grounded in a recognition of the integrated nature of the transmission planning and generator interconnection processes. I write separately to commend SPP on taking a bold step to address the needs of its system and to encourage other regional transmission operators (RTOs) and independent system operators (ISOs) to explore comparable reforms.
Currently, the adequacy of the nation’s transmission system is being tested. Rapid and accelerating load growth, backlogged interconnection queues, and limited regional and interregional transmission capabilities are among the challenges exacerbating reliability concerns and raising electricity bills for consumers. We cannot meet these challenges without effective and efficient buildout of the transmission system. SPP’s proposal recognizes that transmission planning and generator interconnection processes search for the same solution: ensuring that the transmission system reliably delivers affordable power to consumers.
I have written about the need to integrate the generator interconnection process with transmission planning[1] and am glad to see that SPP is taking the first step down this path with the CPP proposal. The single biggest bottleneck to getting needed new generation online to serve the dramatic increase in load growth is the interconnection process. The Commission and many of the nation’s transmission providers have been working to improve that process[2] but it will take actions like the one that SPP has taken here to redesign how the transmission system is planned and paid for to truly accommodate the needed new generation to serve load.
SPP’s CPP proposal addresses the core issue that has been delaying the interconnection of new generation: transmission upgrade cost uncertainties. Currently, interconnection customers must make difficult financial choices at many points in the interconnection process. They face requirements to submit large, non-refundable deposits, subjecting themselves to significant withdrawal penalties without sufficient confidence regarding their network upgrade cost exposure. As we have seen in multiple examples over the years, generators may not find out that they must pay for expensive network upgrades until late stages in the interconnection process.[3] These cost assignments can significantly reduce the financial viability of some generation projects, resulting in their withdrawal from the queue, which in turn can cause time-consuming restudies of the other generators in the queue, adding even greater uncertainties. We have already witnessed cascading restudies and delays that undermine our ability to get needed generation online.
SPP addresses this issue by redesigning a component of its interconnection process: how cost assignments are provided to interconnecting generators. SPP’s proposal advances its transmission planning process and applies the Commission’s cost causation principle to determine the transmission upgrade costs and make them available to the generators that would like to interconnect at certain pre-identified locations on the SPP system. The cost information is available to generators so that they can make their location and financing decisions before entering the interconnection queue, which should streamline and significantly increase the pace of the buildout of new generation.
SPP’s proposal also addresses another pressing challenge: affordability. The transmission network should be developed with an eye toward the long-term needs of the system, not leaning too heavily on network upgrades triggered by new generation. SPP’s proposal rightfully focuses on planning the backbone system that will be needed to support rapidly growing load and the resources needed to serve it. With a focus on the longer term, the system will cost less for consumers because a well-planned system will require fewer piecemeal network upgrades and meet system needs more efficiently.
With today’s order, SPP can move forward with its innovative proposal and customers can begin receiving the benefits of an integrated transmission and interconnection planning process.[4] As other regions continue to grapple with the same underlying challenges that led SPP to develop CPP, I encourage other RTOs/ISOs to explore similar reforms to break the pernicious cycles that undermine generation development and lead to inefficient transmission system buildout. Facing rapid load growth and the need for new resources, we must meet this moment, and proposals like SPP's put us on the path to do so.
For these reasons, I respectfully concur.[1] Judy Chang, et. al., It’s All One System: Integrate Transmission and Interconnection Planning to Support Load Growth, Utility Dive (Sept. 26, 2025) https://www.utilitydive.com/news/its-all-one-system-integrate-transmission-and-interconnection-planning-Judy-Chang/761240/.
[2] See, e.g., Improvements to Generator Interconnection Procs. & Agreements, Order No. 2023, 184 FERC ¶ 61,054, at P 814, order on reh’g, 185 FERC ¶ 61,063 (2023), order on reh’g, Order No. 2023-A, 186 FERC ¶ 61,199, errata notice, 188 FERC ¶ 61,134 (2024).
[3] See, e.g. Tenaska Clear Creek Wind, LLC v. Southwest Power Pool, Inc., 177 FERC ¶ 61,200 (2021).
[4] While I support SPP’s proposal, I want to highlight one part of the CPP that is extremely important and will warrant continued monitoring. SPP has committed to publish information on the detailed calculations and assumptions that will form the cost new interconnection customers will face to enter the CPP. These are critical to how SPP’s proposal works because they establish how SPP determines what portion of the transmission buildout will be assigned to new generation. I will be watching, with interest, how these numbers turn out and what assumptions SPP makes along the way.