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December 16, 2025

Common Charge Wants to Grow Distributed Resources to Meet Spiking Demand

With rising demand putting pressure on the system, a new group has launched to encourage distributed solutions such as virtual power plants that can be deployed quickly and cheaply.

“Right now, those are two of the biggest issues that we have on hand: affordability and reliability,” Katherine Hamilton — acting executive director of the new group, Common Charge — said in an interview. “And, so, the way we want to do that is to maximize distributed assets that are already being developed and can be plugged into the grid, and to ensure everybody has access to those technologies and those applications.”

Common Charge is a coalition, not a trade group. While it includes companies in the distributed energy resource industry, it also includes nonprofits and consumers, Hamilton said. Founding members include Advanced Energy United, Charge Ahead Partnership, Coalition for Community Solar Access, Eco Capital, Institute for Local Self-Reliance, Pivot Energy, Solar United Neighbors, Sunrun and Vote Solar.

“Distributed solutions often are not even considered in the mix as part of the solution set for mitigating for rate increases and prices going up,” Hamilton said. “So, we want to unlock that and make sure everybody has access to those solutions.”

The distribution system is state regulated, and how much distributed resources are used varies by jurisdiction, so part of the group’s efforts is to figure out best practices and ensure they are adopted as widely as possible.

“If you try to follow the distributed energy resource ecosystem, it is very diverse and very disaggregated,” Hamilton said. “And what we’re trying to do is bring a little more organization to that and then drive a lot more impact.”

Distributed resources are at work in different regions, with Common Charge pointing to PJM’s dispatch of thousands of megawatts of demand response during heat waves this year. New York delivered 6 GW of distributed solar early and under budget in 2024. New England benefited from behind-the-meter solar this summer as it helped meet high demand reliably.

ERCOT has a pilot program providing the grid with nearly 60 MW of power from customer-sited assets, and microgrids in Texas have helped keep hospitals running. In a recent test in California, 100,000 distributed assets simultaneously discharged to the grid for two hours, functioning like a power plant and helping to cut peak demand.

“From a small business improving operations through an energy management system, to a community leveraging solar to save on energy bills, to homeowners enjoying the comfort of smart thermostats, millions of distributed assets already exist, and more are waiting to be leveraged in a modern, coordinated energy grid,” Hamilton said. “These assets are proven to increase reliability, lower utility costs and grow local economies.”

Some of the distributed technologies like solar panels are tied to climate change and the divisive politics surrounding it, with skeptics dominating the federal government now, but Hamilton said Common Charge was focused on more bipartisan issues.

“We’re trying to address two of the big issues that [exist] regardless of whether people are talking about climate change or not, and we’ve just seen as demand rises and more strain is put on the grid — from data centers, from increased manufacturing, from electrification — that affordability and rates are going up,” she added. “Affordability is huge, and that’s regardless of what’s happening on the climate side, regardless of what’s happening on the federal side; it’s really just about affordability on a very day-to-day, kitchen table issue.”

The other major issue implicated by demand growth is reliability, which has been a focus of the Trump administration, and distributed resources can help there, Hamilton said.

Former FERC Chair Pat Wood — now CEO of Hunt Energy Network, which is deploying distributed assets across ERCOT — endorsed Common Charge’s mission. He is working on a parallel effort by the Pew Charitable Trusts with former New York Public Service Commission Chair and PJM COO Audrey Zibelman to expand the use of DERs around the country.

The Pew effort is to give decision-makers, which include utilities, state regulators, governors’ offices and even federal officials, a detailed plan for maximizing the benefits of DERs. Wood said he benefited from similar resources while working to restructure Texas’ electricity market in the 1990s when he chaired the Texas Public Utility Commission.

“What we’re trying to do with this group is put out, not just the principles, but how do you do it?” Wood said. “What do you need to address, for interconnection costs, for timetables, for standardization of equipment, for rates, for customer engagement or other customer protection aspects to it, which we’ve learned from all the other industries that just because they’re a competitor, it doesn’t mean they’re nice.”

The rules need to be balanced so that customers’ privacy is protected without being so onerous they hold back the deployment of DERs to benefit the broader grid, he added.

“We’re in the mode of no megawatt left behind, because with all this kind of electrification of everything, and then, of course, the data tsunami that’s kind of sweeping over everywhere, we’re going to need power coming off every corner of the grid,” Wood said.

The distribution grid has been used to ship power one way historically, but recently that has changed, with advances in computing enabling appliances from smart thermostats to water heaters, pool pumps and plug-in cars to help balance the power system.

“There’s just so much more on the grid than when we opened up the Texas market, or when I was at FERC and we were getting the final rules done on the transmission grid,” Wood said. “That same zeal and effort need to continue all the way to the meter.”

FERC has issued major orders on tapping the demand side to benefit wholesale markets in the past, and numerous states have held “grid of the future” proceedings, but both Common Charge and Wood think now is the time that the technologies will really take off.

It is twice as expensive to build a natural gas plant as it was five years ago, and while renewables have helped keep wholesale prices in check, that has not flowed through to the distributed grid, with the rates rising.

“The regulated rates are going up way faster, and the competitive rates coming down, [and they] kind of net each other out,” Wood said.

The promise of competition was lower prices overall, not just shifting costs from the competitive side of the industry to the regulated side, Wood said, and enhancing DERs can make that promise come true. Now with the pressure of rising demand helping push prices even higher, it has attracted more attention from politicians, with governors and legislators around the country focused on ensuring affordability. Wood said that is not a bad thing.

“They can help create the investments and certainty for generators to come in to help push the monopoly utilities to open up their grid and embrace new technology to incentivize customers to get smart and to use their power in the market to discipline price and service,” Wood said. “I mean, who better than the governor or even a president to do that?”

MISO 2025 Tx Expansion Estimate Drops Slightly to $12.4B

The cost estimate for MISO’s 2025 Transmission Expansion Plan (MTEP 25) has fallen slightly from previous estimates to $12.36 billion.  

MISO previously clocked MTEP 25 at $13.1 billion and 444 projects, driven by growing load. (See MISO 2025 Transmission Planning Cycle Rises to $13B.) The newest version includes 10 fewer projects.  

The RTO said MTEP 25 “is shaping up to be another significant year driven by load growth and reliability.” According to the grid operator, MTEP 25 includes 1,930 miles of transmission lines (44% of which are new) that would accommodate nearly 11.6 GW of spot load additions.  

The 2024 MTEP included $6.7 billion worth of projects. That figure does not include the $22 billion second long-range transmission portfolio that technically was included under the annual planning cycle.  

MTEP 25 contains $3.44 billion in baseline reliability projects as dictated by NERC standards, $673 million in projects necessary for generator interconnections, nearly $5 billion in projects for load growth, $1.38 billion in projects to address the age and condition of existing facilities, $1.3 billion in projects to satisfy locally defined reliability criteria and $489 million to address more general local needs.  

Louisiana is set to receive the most investment this year, at more than $3.4 billion. The amount is split between baseline reliability projects and those needed to meet load growth.  

MTEP 25’s 10 most expensive projects account for 44% of the portfolio’s total cost, with four of the 10 in Louisiana. Entergy Louisiana’s Cargas 500-kV station and Smalling 500/230-kV station project in the northern part of the state is the year’s most expensive, at $1.2 billion. Entergy Louisiana said the project is necessary to support new customer load. The work would be located near a proposed Meta data center slated for Richland Parish. 

MTEP 25 spending by category | MISO

Entergy Louisiana’s Babel-to-Webre 500-kV baseline reliability project takes the second-most expensive slot at almost $1.1 billion.  

This year, 49 projects went through MISO’s expedited project review and were cleared to begin construction before MISO’s Board of Directors votes on approving this year’s transmission package in December.  

At a Sept. 5 West Subregional Planning Meeting, Joseph Dunn, MISO director of transmission planning, said the “tremendous” number of expedited review requests were brought on by load growth.  

MISO’s modeling for MTEP 25 assumes projects from the second long-range transmission portfolio enter the scene on schedule in 2035. Five MISO states — the majority of which won’t contain a project — are trying to revoke the cost-sharing of the $22 billion portfolio, which would put the projects in jeopardy. (See MISO States Split on FERC Complaint to Unwind $22B Long-range Tx Plan.)  

This year’s transmission expansion package also contains a blast from the past, as Northern States Power has entered a $92 million maintenance project for a 345-kV line that was part of MISO’s 2011 Multi-Value Project portfolio.  

According to MISO, any maintenance on Multi-Value Projects must be classified under the multi-value category.

MISO plans to publicly post its MTEP 25 report Sept. 29, kicking off a two-week comment period for stakeholders. The grid operator will preview a more final MTEP 25 report at the Oct. 8 Planning Advisory Committee meeting.  

Aging, Expensive N.Y. Nuclear Plants a Bargain, Report Finds

A new report estimates keeping New York’s aging commercial nuclear reactors running through 2050 would save $50 billion in energy. 

Other economic and environmental benefits would accrue from continued operation of the four reactors, which now account for nearly half of New York’s emissions-free electricity, the authors point out. 

The state’s energy planners have concluded the same — they included nuclear energy in the state’s updated energy plan and have recommended the state continue subsidizing the reactors until 2049. 

The Carbon Free NY Coalition, a nuclear power advocacy group, announced the new report by the Brattle Group on Sept. 4. 

Along with the $50 billion in savings, the Brattle analysis concluded that extended operation would contribute $38 billion to the state’s economy; support 2,020 direct jobs and 12,380 other jobs; and preserve $10 billion in tax revenue, $4 billion of it going to the state. 

The four reactors also are increasingly important to New York’s decarbonization goals, as efforts to develop solar and wind generation within the state’s borders are proceeding more slowly than hoped. 

Fossil generation equivalent to the reactors’ 27.5 TWh output in 2024 would have emitted 16.4 million tons of CO2, the coalition noted. The state has paid the reactors’ operator $3.69 billion in subsidies since 2017, in recognition of the reactors’ high cost of operation as well as their high value to the state’s grid and environment. 

“Keeping the upstate nuclear plants operating until midcentury will contribute substantially to New York’s clean energy goals and keep costs lower for ratepayers. It will also support the New York economy, contributing substantially to GDP and jobs — particularly in the upstate region,” said Dean Murphy, lead author of the report and a principal of The Brattle Group. 

The four reactors at three plants in two locations along the south shore of Lake Ontario all are owned by Constellation Energy, which is part of the coalition that commissioned the Brattle report. 

Nine Mile Point Unit 1 is the oldest operating commercial reactor in the nation, and the Ginna reactor is the second-oldest. The FitzPatrick reactor entered commercial operation in 1975; Nine Mile Point Unit 2 is a relative youngster, entering commercial operation in 1988. 

Constellation needs signals of support to take the step of updating and relicensing the geriatric plants, and New York is moving to provide those signals. (See N.Y. Makes Case for Extending Nuclear Subsidies to 2049.) 

Given that renewables are developing slowly in New York, and given that the state is pinning its energy strategy on the hope that new technologies will be perfected, affordable and scalable, nuclear power takes on considerable importance for the Empire State if it is to meet its decarbonization targets. (See N.Y. Considers New Fossil Generation as Renewables Lag.) 

The report analyzes the impact of FitzPatrick, Ginna and Nine Mile Point 1 retiring in 2029, due to expiration of New York’s ZEC subsidy program, and Nine Mile Point 2 retiring in 2032, due to expiration of the federal 45U tax credit. 

They have a combined nameplate rating of 3,537 MW and run at a five-year average 94% capacity factor, and their retirement would lead to an average 3.36% annual increase in retail prices from 2030 to 2050, the report states. 

Retirement of the four reactors likely also would increase the amount of fossil generation the state needs — the report points out that this is exactly what happened when the Indian Point nuclear plant was shut down. 

Earlier in 2025, Gov. Kathy Hochul (D) directed the New York Power Authority to develop new nuclear generation. (See N.Y. Pursuing Development of 1-GW Advanced Nuclear Facility.) 

MISO Selects 10 Gen Proposals at 5.3 GW in 1st Expedited Queue Class

MISO has assembled 10 generation finalists to enter its first interconnection queue fast track, and the list includes five natural gas proposals, three solar farms, one wind farm and a battery storage facility.  

About 4.3 GW of the projects’ combined installed maximum capacity of nearly 5.3 GW would come from natural gas generation. The projects under evaluation span six states and have in-service dates ranging from January 2027 to August 2028. MISO whittled the list down from 47 applications. (See 26.5 GW of Mostly Gas Gen Compete for MISO’s Sped-up Grid Treatment.)  

The RTO said it continues to evaluate the remaining 37 proposals for inclusion in upcoming study cycles. MISO plans to study up to 10 generation projects per quarter, with a maximum of 68 projects, before it retires the temporary express lane process Aug. 31, 2027. The fast track aims to get necessary generation interconnected sooner than MISO’s regular queue currently allows.  

MISO said the first cycle of generation projects to enter the expedited study process were selected by a combination of the timestamp of their application submission and application withdrawals, a review of common constraints near the project and developers’ ability to rectify shortcomings in their applications prior to the study kickoff.  

“The first 10 projects cover all three regions of MISO, stretching from Louisiana to Minnesota,” MISO Senior Vice President of Planning and Operations Jennifer Curran said in a press release.  

Curran said each project “must meet rigorous standards to make sure only necessary and feasible proposals move forward.” 

Applicants had to identify a specific resource adequacy need their projects would address and secure a blessing from their relevant regulatory authority to be considered.   

Entergy La.’s Gas Plants for Meta Make the List

Entergy Louisiana’s proposed 1.64-GW gas plant, intended to meet the upward of 2 to 2.3 GW Meta will need to operate its $10 billion, hyperscale data center, is the largest on the list. (See Louisiana PSC Approves 3 Controversial Gas Plants Ahead of Schedule for Meta Data Center.) The Franklin Farms units are two of the three Entergy Louisiana would need to build to keep Meta’s facility powered.  

Invenergy’s proposed 1.2-GW gas plant in Kenosha County, Wis., to address a 1.75- to 2-GW need among Wisconsin Electric customers is the second-biggest project.  

Otter Tail Power is the sole battery facility to make the cut. The 75-MW Hoot Lake Battery Energy Storage System is proposed to serve a need highlighted in Minnesota’s Integrated Resource Plan.  

MISO also agreed to study Interstate Power and Light Co.’s separate requests for a 750-MW combustion turbine and 350-MW wind farm in central Iowa to help serve a 3.2 to 3.5-GW projected need in MISO’s Local Resource Zone 3.  

Other contenders in the fast lane include: MidAmerican Energy’s 263-MW natural gas combustion turbine in Adair County, Iowa; Lincoln Capital Land’s 125-MW solar farm to serve City Water Light & Power’s unmet needs from generation retirements in downstate Illinois; Ameren Missouri’s 300-MW solar farm in the northern portion of the state; Minnesota Power’s 85-MW Boswell Solar Project in Itasca County, Minn.; and an upgrade of the gas turbine at Minnesota Municipal Power Agency’s Faribault Energy Park in southern Minnesota that requires 60 MW of additional interconnect capacity.  

Curran called the queue fast track a “critical tool we can use to support reliability as we work toward long-term improvements in the interconnection process.”  

MISO plans to accept another round of applications for expedited study in early November and begin studying them at the beginning of December.  

BPA Transmission Pause Questioned During Workshop

The Bonneville Power Administration estimates it would need up to seven years and billions of dollars in upgrades to handle the 65 GW of transmission service requests in the queue, staff said during a Sept. 4 workshop. 

The workshop is part of a series of public meetings the agency is hosting as part of its Grid Access Transformation Project (GAT). 

BPA paused certain planning processes and launched the GAT program to consider changes following a surge of transmission service requests. The federal power agency’s 2025 transmission cluster study includes more than 65 GW of requests, compared with 5.9 GW in 2021. The requests exceed the total regional load predicted for the Pacific Northwest in 2034, according to the agency. (See BPA’s Proposed Tx Access Changes Prompt Questions of Industry Readiness.) 

Conducting an actionable study would require the agency to “model unrealistic load increases or unrealistic generation dispatch patterns to achieve the load reverse balance that’s necessary to perform a power flow study,” said Abbey Nulph, manager of transmission commercial planning at BPA, during the workshop. 

“Our best estimate is that the batches that we believe would not require unrealistic load or generation patterns would have us batching roughly 10 to 20 GW of batches,” Nulph said. “Using our current [Transmission Service Request Study and Expansion Process] timelines, it would take between seven and eight years to process just the existing queue. And while we were undergoing those studies, we would continue to be getting more requested.” 

Alex Swerzbin, vice president of power marketing and transmission at NewSun Energy, asked about the six- to seven-year timeline, saying others in the industry have estimated the process to take between three to four years under a batch framework. 

Nulph replied that even if BPA was able to process 65 GW, the result would be a “massive collection of plans of service.” 

“And the host of plans of service that will come out of study of this size would likely necessitate several billion dollars more in upgrade,” Nulph added. “We do not have that access to capital.” 

Some of the new proposed updates to planning processes include readiness criteria and a new Network Integration Transmission Service initiative where any new forecast increase of 13 MW or more during any year would require participation in commercial planning.  

The agency also is contemplating offering interim service and moving toward proactive planning, meaning building ahead of transmission service requests, according to a July 9 workshop presentation. (See BPA Outlines Proposed Transmission Planning Reforms.) 

‘Slings and Arrows’

NewSun CEO Jake Stephens also weighed in during the Sept. 4 discussion, contending that BPA should have continued processing requests under the current rules instead of issuing the pause. He noted the 2023 TSEP studied 15 GW, triggering “universal upgrades.” 

“We would recommend go ahead and process the first 15 GW of the current queue without waiting and running a whole litigated process, which could take a long time and is probably pretty contentious, because we actually know right now that you can process at least 15 or 20 GW more,” Stephens said. 

Nulph said BPA can process many requests but could run into issues that arose during the 2023 process, where a “large portion of our queue drops away because the plans of service are too expensive.” 

“So, it feels like a waste of our time and our effort,” Nulph said. “Especially when we are relatively resource-constrained in our ability to perform these sorts of studies. We are wanting to spend our slings and arrows on the work that is the most effective for us. And our assessment at this point is that conducting the largest study we think we could will not result in actionable results at the other end.” 

Stephens responded that the market and studies point to the need for more buildouts, while BPA is “sort of saying, ‘Well, we can’t build all this stuff that everybody needs, so we want to adopt policies to shrink everything back to a small-enough set that it doesn’t need all the upgrades that we all need.’ But we do need that.” 

“It’s not what I’m saying,” Nulph said. 

“I’ll clarify,” she added. A “vast portion” of requesters dropped out when BPA offered the Preliminary Engineering Agreements after the 2023 TSEP, Nulph said. 

“And the cited reasons were that those projects were too expensive for them to proceed with,” Nulph said. “So, this isn’t a Bonneville assessment that we can’t afford to build these. It’s that the region is telling us they can’t afford these.” 

Next steps in BPA’s GAT process include a customer-led workshop Sept. 10. Additionally, the agency plans to respond to customer comments from previous workshops in October. 

BPA is also moving from a business practice process to a tariff proceeding process and will publish a webpage and host additional workshops on those proceedings, according to presentation slides. 

RF Presenter Plugs Winterization Assist Visits

Speaking at a NERC-hosted webinar Sept. 4, a presenter from ReliabilityFirst urged attendees to take advantage of the resources available to them ahead of the upcoming winter months.

In his introduction to the webinar, Darrell Moore, NERC’s director of reliability risk management, observed that extreme winter events “have had a very significant impact on … reliability, readiness and security of the” grid over the last 15 years. That period has seen eight major storms, he pointed out, with winter storms Uri in 2021 and Elliott in 2022 causing widespread load shedding in Texas and the Southeast, respectively.

“As we get ready to enter another winter season, we must ensure the processes, equipment, procedures and personnel are prepared for this winter and future winter seasons,” Moore said.

Kellen Phillips, a principal analyst at RF, discussed the regional entity’s winterization assist program. Begun in 2014 after the polar vortex brought record-low temperatures and caused widespread generator failures, the program sees RF staff visit select generators — with the owners’ permission — and review their preparations for extreme cold weather.

Phillips said that while the program has conducted six to 12 visits per year on average since inception, the number of engagements has ramped up in the past few years, with 16 visits in the winter of 2023/24 and 20 in 2024/25.

Sites are selected based on requests submitted to RF from registered entities, narrowed down with data on cold weather-related losses over the previous two years from NERC’s Generator Availability Data System. RF also prefers to visit newly registered generators of 300 MW gross output or greater “to ensure they have a robust winterization program in place,” Phillips said. PJM, which operates in a large portion of the RE’s footprint, has been participating in the program for the past two years and attended most site visits in the most recent winter season.

Prior to the visit, plants complete an informational survey to provide RF staff with plant-specific information. Visits consist of a morning session, containing presentations from RF and PJM, followed by reviews of winterization procedures, processes and work orders; and an afternoon session, which mainly consists of a tour of the control room and the plant’s exterior examining how those processes are put into place.

“We try and get a lot of the heavy lifting done off-site and just cover the critical components on-site,” Phillips said. “We don’t take up too much of their time. We realize they’re trying to run the plant, which is not an easy task … so we try to get in and out as quick as we can.”

Items often checked by the RF team include heat tracing equipment and monitoring systems; temporary and permanent wind breaks; heating systems for the air inlets; and cooling tower de-icing systems. The visitors also check the winter supply areas to ensure that the equipment they listed in their preparation materials is ready.

A visit typically concludes with a final review and initial recommendations; the RE then prepares a full report on the visit, which usually is shared with the registered entity within two weeks. Phillips emphasized this report is not shared with NERC or FERC; however, RF does keep a file of best practices observed in previous visits that it updates each year, and also prepares a yearly after-action report that is available on its website.

Asked if the RE has decided which sites it will visit this year, Phillips said visits typically occur in December and January, and the team still is working through the data to determine where they will take place. He said RF probably will visit 20 to 30 generator facilities this winter.

ISO-NE Monitor Discusses Market Trends, Energy Transition

BOSTON — The New England wholesale electricity markets performed competitively in 2024, while decreased imports and higher emissions compliance rates increased overall market costs, the ISO-NE Internal Market Monitor told the NEPOOL Participants Committee on Sept. 4. 

David Naughton, executive director of the IMM, discussed the group’s 2024 annual report, which originally was published in May. 

The IMM found that wholesale market costs totaled about $10.2 billion in 2024, up by about $1 billion from 2023. This increase largely stemmed from higher energy market prices, which were caused by greater emissions compliance costs and a significant drop in imports from Quebec, which caused the region to rely more heavily on higher-priced natural gas generation, Naughton said. (See Drought, Climate Drive Uncertainty on New England Imports from Québec.) 

Regional Greenhouse Gas Initiative (RGGI) costs increased by about 55% in 2024 compared to 2023, he noted, adding that this increase was offset partly by a 61% decline in Massachusetts’ cap-and-trade program. Overall, carbon compliance costs totaled $509 million for New England generators, Naughton said. This translated to $910 million in added wholesale market costs, as higher marginal resource costs increased the clearing price paid to all participants. 

He noted that the New England states reinvest most of the RGGI proceeds in energy efficiency programs, which help mitigate the cost impacts of carbon prices. 

“These energy efficiency programs saved approximately 17.5 TWh in energy, or roughly $757 million in wholesale energy market costs based on the 2024 LMP,” the IMM wrote in its annual report. 

In 2025, wholesale costs are on track for a significant year-over-year increase, largely from low winter temperatures and periods of extreme heat in the summer, Naughton said. 

He noted that market revenues in 2024 were lower than the cost of entry for most new resources.  

“Market-based revenues in 2024 were below the going-forward costs of new entrant gas-fired generators,” Naughton said. Market revenues for wind and solar resources also were well below the CONE, and these resources remain heavily reliant on state programs, he added. 

Naughton also noted that, while combined cycle plants generally earn more from the capacity and ancillary service markets than in the capacity market, fossil peaker plants are increasingly reliant on capacity market revenues. 

2024 net market revenues for fossil generators | ISO-NE

“These observations indicate that some older, less efficient units could face exit decisions if current market conditions persist, especially when faced with large capital and fixed operating expenses,” the IMM wrote in its report. 

Naughton said the IMM has seen “gradual” impacts of the clean energy transition so far on supply and demand. Average solar output in the region doubled between 2020 and 2024, but wind output remained stagnant during this period. 

Behind-the-meter solar growth has led to a growing duck curve in the region, with mid-day demand frequently dropping below nighttime levels. This has caused growing morning and evening ramp requirements and is beginning to present increased arbitrage opportunities for energy storage resources, Naughton said. 

While the saturation of the storage market has led to declining regulation revenues, energy market revenues have started to tick up for storage resources, he said. 

Recommendations

Naughton also discusses the IMM’s recommended market changes, which include a proposal to subject exports to pay-for-performance (PFP) penalties during capacity scarcity events. 

PFP payments are intended to incentivize resource performance during capacity shortages. While imports receive the PFP rate and LMP, “exporting-only participants are only charged the LMP,” Naughton said, adding that this “over-incentivizes procuring imports” instead of limiting exports. 

He said participants that both import and export power during a scarcity event are subject to PFP netting rules, but there could be a “gaming opportunity” for related companies to schedule imports and exports during a scarcity event and profit without delivering actual energy. 

To fix this issue, the Monitor has recommended that ISO-NE “apply the PFP rate symmetrically to exports, aligning financial incentives and ensuring that external transactions — whether imports or reduced exports — are valued equally for their contribution to system reliability.” 

Net market revenues for battery storage resources | ISO-NE

Responding to the proposal, some stakeholders expressed a concern about applying the PFP to capacity-backed exports and asked ISO-NE to exempt them from performance penalties. 

The Monitor has recommended that ISO-NE update its bidding software “to allow low-cost resources to more easily submit real-time specific offers” and change the external interface clearing rules “to reduce incentives for strategic virtual bidding and incentivize participants to submit more accurate, cost-reflective offers closer to the operating day.” 

Asset-condition Review

During the MC meeting, ISO-NE COO Vamsi Chadalavada discussed the RTO’s work to establish an asset-condition reviewer role.  

The RTO has agreed to pursue this role at the urging of states and consumer advocates and with the agreement of the transmission owners. It has stressed it will not take on a regulatory function investigating the prudence of investments. Instead, its role would be aimed at increasing transparency into projects and could, hypothetically, provide information that would aid stakeholders in prudence challenges with FERC. (See ISO-NE Open to Asset Condition Review Role amid Rising Costs.) 

Chadalavada said ISO-NE’s work is complicated by the fact that no similar role exists elsewhere in the U.S., requiring the RTO to develop these capabilities from scratch. Once developed, the role could serve as an example for the rest of the country, he added. 

He noted that ISO-NE has hired Electrical Consultants Inc. to “help develop a framework for a new asset-condition reviewer role,” as well as to “review selected asset-condition projects in the interim review cycle, through the end of 2026.” 

ISO-NE stillis working to determine which projects it will include in this interim review process generally but will focus on high-cost or abnormal projects, he said. 

Tri-State Seeks FERC Approval for Data Center Load Tariff

Tri-State Generation and Transmission is seeking FERC’s approval for a new tariff designed to manage the heavy volume of data center load expected to materialize in its member utilities’ service territories over the next decade (ER25-3316). 

The filing is part of a growing trend among utilities and states in crafting policies to protect ratepayers from the financial — and reliability — risks stemming from the voracious energy demands of new artificial intelligence data centers. (See related story, Large-Load Tariffs Touted as Alternative to ‘Side Deals’.) 

The proposal is the product of “months of collaboration with members and stakeholders,” the Colorado-based cooperative said in an Aug. 29 press release. 

“The proposed tariff is designed to establish a repeatable and fair process for incorporating high-impact loads onto the Tri-State system without adverse impacts to reliability or affordability,” Tri-State said. “The process would allow Tri-State members to respond in a consistent manner to requests for services from heavy energy users, such as data centers.” 

“We’re in the business of providing electricity, and we are committed to doing it in a way that can meet the needs both of new loads and Tri-State members,” said Lisa Tiffin, Tri-State’s senior vice president of energy management. “This approach allows us to grow responsibly and limits the potential for stranded assets that could result in financial risk to Tri-State and our members.” 

Tri-State is a power supply cooperative that serves electric distribution cooperatives and public power districts across four states. It said in its filing with FERC that new load requests from data centers among its members would, over the next 10 years, more than double its current system peak demand of 2.5 GW. 

In the filing, Tri-State noted that data centers “support local economic development, improve the efficient utilization of utility resources and provide steady revenue streams when fully integrated into a service provider’s system.”  

But it also warned that integrating such large loads also “carries risks,” including the need to build new transmission lines and generation, and the potential for increasing interconnection queue backlogs and delays in procuring needed resources. 

“Large load interconnections also present serious reliability and cost-shifting risks for a utility’s customers,” Tri-State added. 

Tri-State’s existing Electric Resource Planning (ERP) process, designed for a more measured rate of native load growth, is not equipped to handle those risks and the expected pace of new demand from what the co-op calls high-impact load (HIL) projects, it explained in the filing. 

“HIL projects are more speculative than utility members’ prior requests for new or modified delivery points, or native load growth in general. HILs also require accelerated and significant transmission upgrades that do not fall neatly into the existing ERP process,” Tri-State said. 

‘Avoid Socializing the Risk’

Tri-State’s proposed High Impact Load Tariff (HILT) would provide an alternative planning approach for integrating those loads into its system. 

According to the filing, the “guiding principles” for the HILT are: “(1) facilitating economic development across Tri-State’s utility members’ systems at an unprecedented level and pace; (2) limiting the risk of stranded assets resulting from high-impact load integration, which could create financial risk for Tri-State and its utility members; and (3) continuing to meet all resource planning and associated regulatory requirements.” 

Modeled on similar tariffs filed by other U.S. utilities, the Tri-State HILT would establish a biennial planning cycle for customer loads rated at 45 MW or higher. 

“This separate HIL planning cycle process is necessary because HILs are of a size that require significant generation capacity additions or procurement of long-term [power purchase agreements], which necessitates proper planning. Ratepayers may suffer financial consequences if capacity additions are completed only for a HIL to not materialize,” Tri-State wrote. 

Each planning cycle would begin with a “kickoff” meeting among Tri-State, co-op members and potential HIL customers, where participants will “set forth the requirements and timing for a HIL participation package [prepared by the utility member], a process for verifying the participation package components are met and a HIL evaluation process.” 

Intended to ensure that only non-speculative projects are presented to Tri-State for study, the participation package would include:  

    • a completed member project request form; 
    • evidence that the HIL customer has at least 90% site control over its project location; 
    • payment of a nonrefundable HIL evaluation fee; 
    • a certified engineering diagram of the project’s expected load and property acreage; 
    • an executed member-customer high-impact load (MCHIL) agreement; and 
    • a high-impact load agreement (HILA) to be executed between the utility member and Tri-State. 

For HIL requests under 80 MW, the evaluation fee would start at $35,000 plus $1,000/MW, increasing to $150,000 for projects between 80 and 200 MW, and $250,000 for projects above 200 MW — levels Tri-State said are consistent with the megawatt deposit thresholds under its large generator interconnection procedures.

Tri-State said the evaluation process would focus on “reliability, economic and environmental criteria, as well as transmission metrics.” 

“The reliability review will ensure the HIL will not have an adverse impact on the reliable operation of Tri-State’s system, including compliance with Level I (base metrics) and Level II (extreme weather events) reliability metrics. The economic criteria focus on whether the HIL project is economically priced so as to minimize Tri-State’s system costs, and reduce or maintain Tri-State’s rate requirements,” the co-op said. 

The proposed HILA would include “minimum billing demand and energy floors” intended to ensure that, regardless of whether a HIL customer’s load grows as forecast, Tri-State is compensated for system upgrades sufficiently enough to avoid shifting costs to other customers. 

The HILA also would stipulate that a HIL customer provide a minimum security deposit of $2.7 million/MW to offset the risk that “the HIL customer begins commercial operations late [or] ceases operations before the expiration of the HILA term or the HIL does not operate at the expected level (or at all). In short, the security requirement enables Tri-State to avoid socializing the risk of the HIL customer’s under- or nonperformance across Tri-State’s entire membership.” 

Large-load Tariffs Touted as Alternative to ‘Side Deals’

As regulators grapple with rate design for large-load electricity customers such as data centers, some experts are pointing out the transparency benefits of tariffs compared to special contracts between the utility and customer.

“We don’t like these side deals,” said Ari Peskoe, director of the Electricity Law Initiative at Harvard Law School. “We think putting in place data center tariffs is better. It’s more transparent. It encourages robust participation in the process in developing these tariffs.”

Peskoe was a speaker during a Sept. 2 New Mexico Public Regulation Commission (PRC) workshop focused on large-load rate design. He gave an overview of a paper released in March on “How Utility Ratepayers Are Paying for Big Tech’s Power.”

Peskoe and co-author Eliza Martin reviewed 40 state utility commission proceedings regarding special contracts with data centers. They found that regulators often “reflexively” grant a utility’s request to keep the proposal confidential, and then “frequently approve special contracts in short and conclusory orders.” That’s in contrast to rate cases, which draw robust stakeholder engagement, according to the researchers.

Utility tariffs typically detail the price, conditions and terms of electricity service to customers and must be approved by regulators. In contrast, special contracts often are a bilateral agreement negotiated by the utility and the large customer, according to Natalie Frick, an energy policy researcher in the Energy Markets and Policy Department at Lawrence Berkeley National Laboratory.

“One of the big complaints about special contracts is that there’s a lack of transparency,” Frick said in a presentation to the PRC. “They’re often confidential, and so there’s less public scrutiny about them.”

Frick cited as an example an approved special agreement between Meta and Duke Energy Indiana.

“You don’t know how much capacity was being procured, you don’t know where it’s being procured [from], you don’t know what the demand fee or energy charge was,” she said. Frick noted that a consumer advocate was able to review the confidential information and found the deal didn’t increase costs for other customers.

Grid Readiness Proceeding

The Sept. 2 workshop was part of the commission’s proceeding on grid readiness and economic development.

“Data centers are a big topic,” said Commissioner Pat O’Connell, noting that the centers create challenges for the electric industry. “On balance, the need for data centers is real, and having them in the United States is valuable. So it’s a problem that’s worth solving.”

The commission is considering whether a large-load tariff could help address some of the issues.

“For me, it’s a lot about a fair allocation of cost to ratepayers, and a fair opportunity for large customers to interconnect and start receiving power from the utility,” said commission Chair Gabriel Aguilera. “A tariff — would it make it easier for a large customer to know what to expect?”

Aguilera said one option would be to form a stakeholder group to work on a proposed large-load tariff and associated agreements, focusing first on minimum requirements.

Frick and other Berkeley Lab researchers released a technical brief in January titled “Electricity Rate Designs for Large Loads: Evolving Practices and Opportunities.” The Brattle Group and U.S. Department of Energy helped with the research.

The report examined 11 large-load tariffs across the U.S. The minimum size to be eligible for the tariff varied, according to Frick’s presentation. In the case of Black Hills Power’s Economic Flexible Load Service, the minimum is 10 MW, while We Energies’ very large customer tariff has a minimum of 500 MW aggregated.

Some tariffs include an exit fee for ending service early. Ohio Power’s data center tariff settlement agreement proposed an exit fee of three years of minimum charges.

Frick said most of the tariffs have a ramping schedule, in which customers consume an increasing amount of their capacity over time.

In some tariffs, large-load customers may resize the load they plan to take, without penalty, if they find out before a certain deadline that they need less than they expected.

And sometimes tariffs and special contracts are used together, she said.

What’s the Goal?

In Nevada, when a large customer wants to take service under one of NV Energy’s large-load tariffs, the utility files an energy supply agreement (ESA) with the Public Utilities Commission of Nevada, said Karen Olesky, an economist with the PUCN’s regulatory operations staff.

The tariff states what should be in the ESA and in the ESA application, while providing some flexibility, Olesky said. Customers might have different energy needs — such as a data center versus a sports stadium — or different renewable energy goals, she said.

NV Energy’s large customer tariffs include the clean transition tariff, which the PUCN approved in March. It’s a framework developed in partnership with Google that will allow the utility’s existing large-load customers to receive power from new clean energy resources. (See Nevada Regulators Give Nod to NV Energy Clean Transition Tariff.)

The clean transition tariff was modeled on NV Energy’s Large Customer Market Price Energy tariff, which is available only to new customers.

Olesky said regulators should start by considering what they want to accomplish with a large-load customer tariff. That might be attracting new load to the system, lowering rates for large customers or helping a large customer meet renewable energy goals that are beyond renewable portfolio standard requirements.

Determining the tariff’s purpose will help regulators decide the acceptable level of subsidy from other customers, she said. “Is it zero?” Olesky said. “Or is the ultimate goal to bring new load at all costs, so having non-participating customers pay something for this is OK?”

MISO: Market Platform Replacement will be Overbudget, Stretch into 2028

MISO said its nine-year effort to replace its market platform will exceed original budget contingencies and will not be completed until 2028, three years later than it previously predicted.

Chief Digital and Information Officer Nirav Shah said at a Sept. 4 meetup of the MISO Board of Directors’ Technology Committee that the RTO now expects the full integration of a new, real-time market clearing engine to extend into 2028.

In early 2024, MISO expected to have all projects associated with its new, modular market platform fully operational in late 2025. When MISO announced the project in 2017, it estimated it could migrate to the new modular computer system by 2023. (See New MISO Day-ahead Market Engine to Emerge Soon After Delay and MISO Sets Sights on 2025 Completion for New Market Platform.)

Shah said the overall cost of the platform overhaul has increased to about $175 million “due to the complexity of completing the real-time market clearing engine.” He said he would have more details on the higher costs of the project later in 2025. MISO originally allotted $130 million for the platform swap with a 25% contingency.

“I look back to 2017, and we’re in a very different place. A lot has changed,” Shah explained. He said technology functions differently now than when MISO announced the replacement project nine years ago. He also said FERC has released several orders with new requirements in that time frame, such as real-time ambient-adjusted line ratings under Order 881.

Shah said that overall, requirements on the market platform replacement are 11% higher than when MISO first gauged them.

“It’s a pretty disappointing miss this late in the project,” said Director Todd Raba, who added that “one of these days,” he’d like to see an IT project end on time and on budget.

Director Theresa Wise said the market platform replacement can be thought of as “a series of projects over time,” with the final projects having vastly different parameters than MISO originally anticipated. Wise said the last two projects are significantly larger with more requirements.

“I think we’re clouding things together,” Wise said in defense of the project’s progress.

Shah said vendors originally estimated the look-ahead commitment component of the project to be about $7 million in 2017. The effort now is predicted to cost about $16 million. He also said the new unit dispatch system has gone from an $8 million estimate to more than $18 million.

MISO CEO John Bear said the RTO probably should have “recast” and repriced the remaining elements of the platform replacement around 2021 to capture rising technological complexities and inflation.

“We didn’t do that, and I want to apologize for that. … Time is not your friend on these projects,” Bear said.

Bear, however, stood by the project even with the late-stage additional costs.

“If you step back from this … the value from the project is still there, even with the increases. The benefits overall are going to be enormous,” Bear said.

For nearly a decade, MISO leadership has said that the current, monolithic market platform — built using technology from the 1990s — is poised to become so obsolete that it won’t be able to clear the day-ahead market or accommodate the more scattered, numerous generation assets that the fleet transition has introduced. (See MISO Makes Case for $130M Market Platform Upgrade.)

Director Erik Takayesu asked if the vendors on the market platform replacement are taking responsibility for some overages. The replacement is being completed with vendors General Electric and Siemens.

“We absolutely are pushing back on the vendors,” Shah said. He said that, for instance, MISO refused to take on additional costs of “poor architecture decisions” that necessitated a redesign on some of the look-ahead commitment components.

“It absolutely is making them uncomfortable, but that’s the right thing for our stakeholders,” Shah said.

MISO estimated it will take until 2026 for the look-ahead commitment software to enter final testing and parallel operations. By 2027, the RTO estimates it would be able to test its new unit dispatch system and enter it into parallel operations.

Through the remainder of 2025, MISO plans to begin testing the look-ahead commitment software and launch its new one-stop model manager so it can cease operations of its old, siloed modeling systems. Shah said MISO had to work through some data quality issues as it migrated data to the new management system. The RTO’s model manager project aims for one system of record for all planning and operations models to eliminate redundant data entry and review.

MISO also said the technology to use real-time AARs is in the testing stages for the remainder of 2025, with production still on track for 2026.

Over 2024, the RTO entered its new day-ahead market clearing engine into standalone production and retired its legacy day-ahead market.