Docket Nos. ER26-191-000 & ER26-191-001
We join today’s order because we agree that PSCo needs to provide further details to demonstrate that the revisions to sections 8.0 and 11 of its proposed pro forma NOA are consistent with or superior to the Commission’s pro forma OATT and otherwise just and reasonable.[1]
We write separately to encourage PSCo, if it chooses to make a future filing, to explain the alternative transmission service options available to current or prospective NITS customers that are unable to timely designate sufficient Network Resources to serve new or increasing Network Load. Specifically, PSCo should explain how network customers have ready access to firm and non-firm point-to-point transmission services to access alternative sources of generation or rely on their own behind-the-meter generation or load flexibility if those customers are unable to timely designate sufficient Network Resources.[2] This explanation will help the Commission understand whether the existing PSCo Tariff provides sufficient transmission service options for network customers to rapidly and efficiently serve new load.
As we have previously noted, it is imperative that the industry embrace innovative ways to maintain reliable and affordable service,[3] rather than resorting to the draconian steps of denying requests for new service, terminating existing service, or manually shedding load. PSCo should evaluate whether its tariff allows for practical pathways to pair new loads with new generation and to operate large loads flexibly—if not, programs being implemented in PJM,[4] SPP,[5] and elsewhere may be models for alternative transmission service options that PSCo could consider.
For these reasons, we respectfully concur.
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David Rosner
Commissioner
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Judy W. Chang
Commissioner
[1] Pub. Serv. Co. Colo., 194 FERC ¶ 61,135, at PP 28, 56 (2026).
[2] See Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,736 (“[I]f a customer wishes to exclude a particular load at discrete points of delivery from its load ratio share of the allocated cost of the transmission provider’s integrated system, it may do so. Customers that elect to do so, however, must seek alternative transmission service for any such load that has not been designated as network load for network service. This option is also available to customers with load served by ‘behind the meter’ generation that seek to eliminate the load from their network load ratio calculation.” (footnotes omitted)).
[3] PJM Interconnection, L.L.C., 193 FERC ¶ 61,217 (2025) (Rosner, Comm’r, concurring) at P 4 (“Today’s order . . . directs PJM to establish new pathways for co-location . . . and load flexibility that enable large co-located loads to reduce how much they lean on the grid, while ensuring that they pay their fair share. As a result, PJM can avoid constructing unnecessary transmission upgrades for large loads, reduce strain on the grid, and make power bills cheaper for everyone—including for families and small businesses.”); id. (Chang, Comm’r, concurring) at P 2 (“With today’s action, the Commission is providing guidance on how loads and generators may co-locate, including the development of new transmission services...”); see also Sw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026) (Rosner, Comm’r, concurring) (“The HILLs and HILLGA processes work together to pair shovel-ready generation with large loads and allow them to interconnect to the grid in less than half the time typically required for generators to clear SPP’s generator interconnection queue. The secret sauce behind SPP’s proposal is Load Limited Resource Interconnection Service (LLRIS), a new interconnection service that limits the amount of power a generator can put on the SPP grid to the forecasted hourly load of the nearby large load it serves.”).
[4] PJM Interconnection, L.L.C., 193 FERC ¶ 61,217 (2025).
[5] Sw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026).