On December 21, 2017, FERC accepted the Southwest Power Pool, Inc.’s (“SPP”) proposed tariff revisions related to its Integrated Transmission Planning (“ITP”) process contained in SPP’s Open Access Transmission Tariff (“Tariff”). In 2015, SPP created the Transmission Planning Improvement Task Force (“Task Force”) to review its transmission planning process to determine if improvements were needed. Based on the Task Force’s recommendations, SPP proposed to revise certain language in its Tariff, including moving from a three-year transmission planning cycle to a one-year cycle.
In its filing, SPP stated that the Task Force determined that there were identifiable solutions to improve the ITP process. Specifically, the Task Force concluded that SPP should replace the current three-year ITP cycle in Attachment O of SPP’s Tariff with a one-year transmission planning cycle by combining SPP’s Near Term and 10-Year Assessments into a single, annual ITP Assessment. SPP stated that the current three-year transmission planning cycle is too long and reduces opportunities for synergy in addressing the reliability, public policy, compliance, and economic needs of the SPP transmission system. SPP also proposed revisions to Attachment O of its Tariff that require the 20-Year Assessment to take place every five years, rather than every three years under the prior provisions in Attachment O of SPP’s Tariff. In addition, SPP stated that it would put those recommendations from the Task Force not requiring Tariff revisions into the ITP Manual.
Protestors argued that SPP did not provide sufficient detail to ensure a transparent, just, and reasonable transmission planning process and that FERC should condition its approval of the proposed Tariff revisions on SPP making a compliance filing to provide additional details and on SPP making an annual informational filing to update FERC on any changes to the ITP Manual. Protestors specifically contended that SPP had not adequately described how it would implement the Task Force’s recommendations, and, although the ITP Manual would address some of those details, it would not be filed with the Commission. In addition, protestors claimed that to ensure the process would be as transparent as possible, SPP should offer two planning summits each transmission planning cycle.
FERC disagreed with these contentions. First, FERC reiterated that SPP’s Tariff provisions on transmission planning had previously been found just and reasonable. According to FERC, SPP was not seeking to change the structure of the planning process, but merely sought to implement the Task Force’s recommendations for changing the frequency of planning cycles. As a result, the proposed Tariff revisions did not alter FERC’s prior determination that the ITP provisions are just and reasonable. Similarly, because the concerns raised by protestors related to elements of the ITP process that were not at issue in this proceeding, FERC concluded these concerns were beyond the scope of this proceeding.
FERC further disputed the contentions that SPP should have to file its ITP Manual with the Commission, or include the information from the ITP Manual in its Tariff. In doing so, FERC stated, “[T]ransmission providers can use a combination of tariff language in their Tariffs and references to planning manuals to implement their transmission planning processes.” Lastly, FERC concluded that it did not prescribe a minimum number of planning meetings in Order No. 890; rather, Order No. 890 instead focused on opening lines of communication with stakeholders. FERC concluded that SPP’s Tariff satisfies this principle through its requirement to hold a single, annual planning summit.
FERC’s order can be found here.