Commissioner Rosner's Concurrence to Order Accepting Tariff Revisions, Subject to Condition re Southwest Power Pool, Inc. under ER26-247

Today’s order accepts SPP’s proposal to establish new study processes for new High Impact Large Loads (HILLs) and associated generation through the High Impact Large Load Generation Assessment (HILLGA).  Together, these processes will enable SPP to efficiently identify new large loads, expedite the interconnection of new generation needed to serve them, and protect the reliability of the bulk power system.  The proposal also encourages “bring-your-own-new-generation” solutions in SPP, which will enable rapid interconnection of new large loads without raising costs or threatening electric reliability for other customers.  I concur to highlight SPP’s pragmatic steps to support economic growth in its footprint and call on other transmission providers across the country to consider similar proposals through FPA section 205 filings.  

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.  Because the generator’s output is matched to the large load’s demand, the impacts of adding load and generation to the transmission system effectively cancel each other out, which minimizes the need for time-consuming transmission upgrades.  SPP’s proposal is grounded in physics, takes a harder look at reliability impacts of large loads on the grid than current practice requires, and unlocks large load opportunities while protecting other customers from rising bills. 

There are also clear parallels between SPP’s approach in its HILLs and HILLGA processes and the new transmission services the Commission recently directed PJM to create for load co-located with generation.[1]  While the mechanics of these approaches are distinct between the different regions, the practical outcome is similar: they both enable new generation needed to serve new large loads to connect to the grid faster and at lower cost. The common thread is a recognition that when generation is paired with load that is physically proximate, the impacts on the transmission system are lower than they are in the status quo, in which large loads and generation are planned separately.   

I also note that SPP’s proposal is another step towards realizing the goals of Secretary Wright’s Large Load ANOPR proposal in three important ways: first, it pairs new large loads and new generation to connect them to the grid rapidly and reliably;[2] second, it minimizes costs borne by other customers;[3] and third, it does so through an FPA section 205 filing, rather than waiting on the Commission to require such action.[4]

Today’s order is a productive step toward facilitating the energy needed to win the AI race, bring back American manufacturing, and deliver the reliable and affordable energy on which families and small businesses depend.  I encourage other transmission providers to take note of the innovative approach SPP proposed in this filing, and to consider proposing similar solutions tailored to meet the needs within their own footprints.

For these reasons, I respectfully concur.