Docket No. ER26-2592-000
I concur with today’s order accepting SPP’s proposed Tariff revisions to implement a process allowing for economic topology reconfigurations. I write separately to highlight the significant cost savings that the SPP region stands to realize and to urge other ISOs and RTOs to consider similar revisions to their own tariffs.
Transmission topology optimization allows grid operators to make smarter, more efficient use of the existing grid by reconfiguring the routes where power flows when the system is congested.1 This allows grid operators to move more energy with less infrastructure, which reduces costs and increases reliability.2 These savings are not theoretical—they are real and substantial. For example, in 2023, MISO began implementing a topology optimization program that resulted in $113 million in congestion savings in 2025.3
There are similar potential benefits in SPP. SPP’s 2018 topology optimization pilot resulted in congestion cost savings between $18 and $44 million annually.4 And with SPP averaging over $1.6 billion in yearly congestion costs,5 the record in this proceeding points to additional untapped consumer savings via topology optimization.
To be sure, topology optimization is no magic wand obviating the grid infrastructure investments essential to powering our economy in the 21st century. But SPP’s proposal—at a time when demand is growing and costs are increasing—is a win for consumers in the region.
For these reasons, I respectfully concur.