Docket No. ER26-1311-000
Today’s order accepts SPP’s tariff revisions establishing procedures governing interregional transmission coordination for its RTO Expansion, and I commend SPP for their work reaching consensus with their new Western neighbors on these tariff provisions. I write separately, however, to highlight broader deficiencies with the Commission’s current interregional transmission coordination framework.
Since 2011, Order No. 1000’s interregional consultation requirements have resulted in exactly zero interregional transmission projects. Yet, time and time again over those 15 years, we have observed that interregional transmission has made meaningful contributions to grid reliability during periods of extreme stress.[1]
In 2023, Congress directed NERC to study the reliability benefits of interregional transmission. NERC’s study, the Interregional Transfer Capability Study, identified a 35 GW gap that, if left unaddressed, will contribute to a grid that is less reliable.[2] This is a concerning finding that we must address.
While I am encouraged by the modest progress some regions have made on transmission planning along their seams,[3] it is imperative that the Commission and industry advance meaningful action on interregional transmission planning as soon as possible. I stand ready to take swift action on any future filings from industry, which I encourage. Absent such filings, I intend to work with my fellow Commissioners to move this critical ball forward.
For these reasons, I respectfully concur.
[1] See, e.g., FERC, NERC, & Regional Entity Staff, January 2025 Arctic Events: A System Performance Review, at 13-14 (Apr. 17, 2025) https://www.ferc.gov/news-events/news/ferc-nerc-issue-report-system-performance-during-january-2025-arctic-weather; FERC, NERC, & Regional Entity Staff, Winter Storm Elliott Report: Inquiry into Bulk-Power System Operations During December 2022, at 123-25 (Nov. 7, 2023), https://www.ferc.gov/media/winter-storm-elliott-report-inquiry-bulk-power-system-operations-during-december-2022; FERC, NERC, & Regional Entity Staff, The February 2021 Cold Weather Outages in Texas and the South Central United States, at 96-98 (Nov. 16, 2021), https://www.ferc.gov/media/february-2021-cold-weather-outages-texas-and-south-central-united-states-ferc-nerc-and.
[2] See NERC, Interregional Transfer Capability Study, at xii (Nov. 2024), https://www.nerc.com/globalassets/initiatives/itcs/itcs_final_report.pdf.
[3] See Midcontinent Indep. Sys. Operator, Inc., 189 FERC ¶ 61,108 (2024); see also MISO & PJM, MISO-PJM IPSAC Meeting, at 16 (Mar. 13, 2026), https://cdn.misoenergy.org/20260313%20MISO-PJM%20IPSAC%20Item%2001%20AIR%20Presentation_UPDATED%203.16.26745574.pdf.