Item E-8: Commissioner James Danly Concurrence Regarding Midcontinent Independent System Operator, Inc.

Commissioner James Danly Statement
December 16, 2022
ER22-995-001

I concur with today’s order addressing the arguments raised on rehearing.[1]  In light of the concerns raised, I write separately to express my misgivings regarding the use of the postage stamp cost allocation mechanism established by Midcontinent Independent System Operator, Inc.’s (MISO) tariff revisions.  Nonetheless, given the record before us and the design of MISO’s allocation system, I have not concluded that MISO’s proposed cost allocation method is unjust and unreasonable.

For these reasons, I respectfully concur.

[1] Midcontinent Indep. Sys. Operator, Inc., 181 FERC ¶ 61,219 (2022).