Commissioner Mark C. Christie Statement
June 11, 2021
Docket No. ER21-1676-000

I concur with today’s order, which is appropriately without prejudice.   I write separately to add the following.

SPP’s application provides insufficient detail with respect to the specific roles the Regional State Committee, individual states, and load-serving entities (LSEs) would play in the review of a request to waive the existing cost-allocation formula on an ad hoc basis. [1]  Since approval of a cost-allocation waiver would result in costs being re-allocated to consumers in states and to LSEs that would not otherwise bear those costs under SPP’s existing Highway/Byway methodology, it would be helpful and relevant to know whether any such waiver process ensures that states and LSEs whose consumers would be re-designated as “beneficiaries” have an opportunity to review and consent/dissent affirmatively to the re-designation and to the new costs that go along with it.  Such relevant information on the process was missing from this application.

For these reasons, I respectfully concur.

 

[1] For example, while SPP’s proposal provides a process for the RSC to review and provide a recommendation to the Board with respect to a request for waiver, there is little to no information explaining if and how individual states or other entities, such as LSEs, impacted by a specific waiver request may participate in the process or consent or object.  Additionally, it is not clear whether and to what extent the Board must articulate its consideration of any RSC or other relevant committee recommendation.

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