FERC on Thursday rejected SPP’s proposed Tariff revision to develop uniform local transmission planning criteria, siding with stakeholders who argued they would be unduly discriminatory or preferential (ER20-2334).
GridLiance High Plains, Tri-County Electric Cooperative, Kansas Power Pool and a group of eight cooperatives and municipalities protested the filing, which proposed to use zonal planning criteria to evaluate the need for zonal reliability upgrades in SPP’s regional transmission planning process.
The RTO proposed that the network customer with the zone’s largest total network load would designate each year a transmission owner within the zone as the facilitating TO. That TO would develop a single set of zonal planning criteria, conducting open meetings with the zone’s other TOs and transmission customers taking long-term service within that zone.
All TOs within the zone would apply the zonal planning criteria “comparably” to all the zone’s load.
SPP has 18 transmission pricing zones, 10 of which comprise multiple TOs. Currently, each TO submits its own local planning criteria to the RTO, which then uses its regional transmission planning process to determine whether a reliability violation requiring new reliability upgrades should be considered.
Those objecting to SPP’s proposal charged it would give facilitating TOs “unilateral power” and “unduly” benefit them and the zone’s largest network load customer by allowing a single customer, based on the size of its load, to dictate planning criteria for everyone else in the zone.
In a joint protest, GridLiance and Tri-County said “this puts every other entity within the zone at a disadvantage and unduly discriminates against smaller loads in the zone and non-facilitating” TOs. KPP and the cooperatives contended the facilitating TOs are not obligated to take stakeholder input into account when establishing the planning criteria.
The comments echoed their concerns over transparency and equality when the revision request was discussed and approved during SPP’s April governance meetings. Four representatives on the 21-person Members Committee, which advises the Board of Directors with a show of hands, voted against the measure and a fifth abstained. (See “Directors Approve Zonal Planning Criteria, Z2 Elimination,” SPP MOPC Briefs: April 14, 2020.)
FERC agreed with the protests, finding that in zones with multiple TOs, SPP’s proposal would give an undue preference to the network customer with the zone’s largest total network load and to the facilitating TO.
In an email to RTO Insider, GridLiance High Plains President Brett Hooton said, “FERC’s important ruling recognizes that the proposal would have given large incumbent transmission owners complete control over transmission upgrade criteria.”
“Under SPP’s proposal, the network customer with the largest total network load in the zone would have sole authority to designate a single transmission owner in the zone as the facilitating transmission owner, which could be the network customer itself (if it is also a transmission owner) or a transmission-owning affiliate,” the commission said.
“This raises concerns that the facilitating transmission owner could potentially select zonal planning criteria that address its own local reliability needs … or could potentially foreclose SPP’s consideration of local reliability needs of other transmission owners in the zone when identifying the need for zonal reliability upgrades,” FERC wrote. In that case, it noted, the resulting reliability upgrades’ costs would be allocated to all customers in the zone.
The commission said SPP’s proposal would be unduly discriminatory toward the zone’s other transmission customers that do not serve the largest share of load and toward non-facilitating TOs. Aside from attending open meetings, FERC said the zone’s other customers and TOs would have “no formal process rights” or the ability to influence the facilitating TO’s decisions in establishing the planning criteria.
“Facilitating transmission owners could potentially prevent the local reliability needs of other transmission owners in the zone from being considered and thus prevent zonal reliability upgrades from being constructed in response to those needs,” FERC said.
The Tariff proposal was one of 21 recommendations from the Holistic Integrated Tariff Team, which spent 15 months in an effort to help SPP adapt to the evolving grid and electricity markets.