Docket No. EL22-34-000
I concur in this order, which makes various findings consistent with Commission precedent. I write to add more general comments on ROE adders, as I have frequently done before.
An ROE adder for RTO participation is “by definition, a subsidy, as any ROE adder is — more ‘FERC candy’ taken directly from consumers and redistributed to transmission owners.”[1]
I will state again here what I did in my MISO Concurrence last month:[2] two of my colleagues, including the Chairman, in April 2021 joined me in voting to limit the RTO participation adder to three years after joining.[3] Over a year and a half later, we
have yet to take a final vote to implement that limit. As long as we do not, consumers will continue to pay these adders at a time when consumers are already facing rapidly rising monthly power bills.
For these reasons, I respectfully concur.
[1] Midcontinent Indep. Sys. Operator, Inc., 181 FERC ¶ 61,094 (2022) (Christie, Comm’r, concurring at P 2) (MISO Concurrence) (available at https://www.ferc.gov/news-events/news/commissioner-christies-concurrence-urging-action-re-rto-participation-adder-docket).
[2] Id. P 3.
[3] Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act, Supplemental Notice of Proposed Rulemaking, 175 FERC ¶ 61,035 (2021) (Supplemental NOPR). I note that this Supplemental NOPR modified a March 20, 2020 NOPR issued in that docket. Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act, Notice of Proposed Rulemaking, 170 FERC ¶ 61,204, errata notice, 171 FERC ¶ 61,072 (2020).