By Christina Hayes, Executive Director of Americans for a Clean Energy Grid
Last week, the Federal Energy Regulatory Commission (FERC) issued an order with a bipartisan separate statement that has the ability to go far beyond its narrow application. In Southwest Power Pool, Inc., Docket No. ER24-1658-000, et al., now-Chairman Christie and Commissioner Rosner wrote about the importance of a strong states’ committee in the developing Southwest Power Pool (SPP) Markets+. While states committees have historically focused on representing state views in dockets related to markets at the federal level, a stronger argument could be made for a states’ committee for transmission planning regions – regardless of market structure – particularly in light of the strengthened state role in FERC Order No. 1920.
SPP’s Regional States Committee has long been held as a model of strength for the role of states, and the separate statement would expand the full scope of the committee to include staff assistance to the Markets+ area. The statement notes that the states’ committees for MISO (Organization of MISO States (OMS)) and PJM (Organization of PJM States (OPSI)) have dedicated funding and staff resources. The experience of OPSI and OMS demonstrates that providing dedicated staff and resources to state organizations is both feasible and impactful. As noted in the concurrence, OPSI’s annual expenses of approximately $1 million amount to just 0.002% of PJM’s total billings, a cost-effective investment in robust governance.
These organizations have shown that empowering states with resources enhances their ability to shape regional transmission planning and protect consumers. Additionally, the New England States Committee on Electricity (NESCOE) provides critical support to New England states by offering technical expertise, facilitating coordinated regional planning, and representing state interests in policy advocacy. Single-state RTOs do not have, and arguably do not need, a separate organization to speak for them, where the state commission already directly engages with market participants.
Outside organized markets, technical assistance for states is more spotty. As the separate statement noted, the states outside SPP proper relies on external staff, such as those from the Western Interstate Energy Board (WIEB), which, though valuable, does not substitute for dedicated personnel who work exclusively for state committees. Without their own staff and sufficient resources, states cannot as effectively participate, potentially undermining the public interest and the full benefits of participation in regional efforts. This lack of support is especially keen for states in regions like WestConnect, Northern Grid, and the Southeastern Regional Transmission Planning (SERTP), where the lack of a unified state organization presents challenges. States must coordinate on an ad hoc basis, which can limit their ability to speak with a cohesive voice or fully evaluate regional proposals.
Several programs have sought to step into the breach and provide assistance to states generally related to transmission planning. The federal government has initiated several programs to enhance state engagement in transmission planning. Notably, the State Technical Assistance (TA) Program, managed by Lawrence Berkeley National Laboratory and other national laboratories, offers public utility commissions and state energy offices access to expert guidance and resources. This program provides assistance at varying levels of depth and duration, including Help Desk support for quick inquiries, Expert Match for more detailed consultations, and Deep Dive engagements for comprehensive analysis.
Additionally, the Department of Energy’s State Energy Program (SEP) delivers funding and technical assistance to states, territories, and the District of Columbia, with a focus on energy security, advance state-led energy initiatives, and increase energy affordability. By utilizing these and other resources, states are better equipped to participate in transmission planning processes, ensuring that state perspectives and consumer interests are adequately represented.
Empowering state committees with resources and dedicated staff is not just a governance improvement—it is an investment in well-functioning federal processes. Robust state participation ensures better cost allocation decisions and equitable outcomes, including cost-effective and forward-looking transmission planning. Enhanced state participation is especially critical for compliance with the Federal Energy Regulatory Commission’s Order No. 1920, which emphasizes the robust involvement of Relevant State Entities (RSEs) throughout the Long-Term Regional Transmission Planning (LTRTP) process. This includes mandatory consultation during the State Engagement Period, facilitation of cost allocation discussions, and the integration of state-proposed cost allocation methodologies into compliance filings. Furthermore, Order No. 1920-A strengthens these requirements by allowing extensions to the State Engagement Period to ensure sufficient time for resolving cost allocation questions and by requiring transmission providers to include all state-endorsed methodologies in their filings for FERC consideration.
As the transmission planning regions around the country embark on more robust planning for the grid of the future, states’ committees should rise to the challenge. Developing robust states’ committees, and potentially adopting funding and staffing mechanisms similar to OPSI and OMS, will create a level playing field for states across the country, ensuring states are well represented and the public interest upheld. Chairman Christie should see to it.