HOUSTON — SPP stakeholders debated a contentious tariff revision request that creates a one-time study outside the grid operator’s normal planning process during their quarterly Markets and Operations Policy Committee meeting. They took a break and then continued the debate. 

Eventually, MOPC passed a series of votes April 15 that sends the expedited resource adequacy study (ERAS) proposal (RR668) to the SPP board and its Regional State Committee, composed of state regulators in the RTO’s footprint, for final approval.  

“I think for most of us there, we had some fun elements and getting some clarity around motions,” MOPC Chair Joe Lang, with Omaha Public Power District, told the Strategic Planning Committee on April 16. 

SPP says the tariff change is necessary because large loads have increased load forecasts significantly. However, load-responsible entities could fall short by 17 GW by 2030, according to their submissions, and “large uncertainties” still exist with the backlogged generator interconnection queue.  

The Resource and Energy Adequacy Leadership (REAL) Team worked with staff to develop the ERAS. It added modifications to attestation and LRE-ceiling capacity suggested by Evergy and Xcel/Southwestern Public Service (SPS) and Empire District Electric, respectively, before endorsing it April 2. 

MOPC approved the provisional process policy in October 2024, and the RSC subsequently endorsed its cost-allocation concept. The current process is base-plan funded; under the new methodology, upgrade costs will be assigned directly to the customer, with base-plan funding covering the remaining cost. 

During MOPC’s hourslong discussion, staff accepted Oklahoma Gas & Electric’s suggestion to extend the deadline for ERAS projects’ commercial operations date from five to seven years, allowing for supply chain issues. 

“Let’s allow for some of [the] things that an LRE can control to happen and still get resources on to meet the [planning reserve margin] as quick as possible,” OG&E’s Brad Cochran said. 

Evergy also modified its own comments to add a second LRE ceiling provision: the projected deficiency multiplied by the ceiling multiplier or the projected deficiency plus the less of either 419 MW or 50% of the LRE’s highest summer season or winter season net peak demand. 

The final measure passed with 81.15% approval and five abstentions. All 18 transmission-owning members voted for RR668, but only 38 of 61 transmission-using members voted for the revision. 

Not everyone was happy. 

NextEra Energy’s Jeff Wells said SPP’s time, resources and efforts would be better supported clearing the existing GI queues. 

“SPP has made substantial efforts … my estimates are rough, but there are approximately 180 GW currently in the queue,” he said. “I would imagine that most of that could meet resource adequacy, so I think it would be important for SPP to focus on those current queues and unlocking those with [GI agreements] instead of creating a new queue exclusive to LREs. It’s unduly discriminatory.” 

Christy Walsh, with Natural Resources Defense Council-Sustainable FERC, suggested waiting until the commission responds to MISO’s ERAS filing, which is opposed by independent power producers, environmental organizations and several state regulatory bodies. MISO’s proposal also drew pushbacks from eight former FERC commissioners, who said it threatens the open-access principle. (See MISO Fast Lane Proposal Disadvantages IPPs, Retail Choice States, Critics Tell FERC.) 

“I think that should be concerning to all of us, and I, at the very least, think we need to wait,” Walsh said, noting MISO asked for action by May 17. “At least wait to see what FERC does there, to see if this proposal even has legs. I think SPP hasn’t really adequately justified the need and we haven’t done enough to ensure that the resources that are going to be in ERAS will actually come online in time. We’re doing a lot here that violates fundamental tenets for FERC rules and isn’t actually going to fix any problem that’s been identified.” 

“The biggest problem that exists with this proposal … is the challenge, the danger it poses to open access. The idea that one set of entities [has] the ability to unilaterally make a decision about who gets access to the grid runs directly contrary … to what has been established by FERC over the last two-and-a-half decades in multiple orders,” echoed Steve Gaw, with the Advanced Power Alliance. 

SPP’s Steve Purdy, technical director of engineering policy, responded to concerns that the proposal helps some entities by allowing them to jump ahead of projects stalled in SPP’s queue. 

“I don’t know that a restudy constitutes queue-jumping, but all along, we’ve said that the ERAS requests are going to get higher priority than anything that’s already been [studied] and that hasn’t had a GIA,” he said. “If you want to characterize that as queue-jumping, you can.” 

Purdy agreed with stakeholders that the ERAS process could lead to costs being shifted to SPP’s transmission planning process, but said he didn’t think it would be “dramatic.” 

“That’s been a recognition all along, with the understanding that the purpose of ERAS is resource adequacy to benefit the entire footprint,” he said. “The rationale, if you will, is for those costs to be borne by the larger footprint in order to reinforce our resource adequacy.” 

LREs will be able to determine which projects go to ERAS, Purdy added, but said they will be limited by the planning reserve margin (PRM). Perhaps worn down by the ERAS discussion, committee members quickly approved without further feedback an increase to the 2029 PRM (RR664). The summer PRM will go from 16 to 17% and the 2029/30 winter PRM will go from 36 to 38%. 

The tariff change passed with 82.54 approval. Four of 18 TOs voted against the measure and eight of 63 transmission users. 

‘Chicken & Egg’ Issue

MOPC unanimously approved a provisional load process (RR672) that allows transmission customers to add load to the system when they don’t have enough designated resources to cover their 10-year load forecast (including losses). The measure is subject to secondary stakeholder groups’ approval. 

“If ERAS is the chicken, this is the egg,” said Evergy’s Derek Brown, chair of the Transmission Working Group. “So, resources versus load. We need a way to bring loads online faster that don’t have resources procured for them yet.” 

The new planning process replaces a tariff attachment that required costly studies when customers didn’t have enough firm resources. 

MOPC approved the provisional process policy in October 2024, and the RSC subsequently endorsed its cost-allocation concept. The current process is base-plan funded; under the new methodology, upgrade costs will be assigned directly to the customer, with base-plan funding covering the remaining cost. 

SPP plans to file the tariff revision with FERC in June, assuming it secures board and RSC approval. 

“We have loads that are waiting to connect that would rely on this process,” Brown said.