EL26-68-000 · 2026-08-03 · Southwest Power Pool, Inc.AMERICAN ELECTRIC POWER SERVICE CORPORATIONEVERGY, INC. ,GRIDLIANCE HIGH PLAINS LLC ,ITC GREAT PLAINS LLC ,
Amended Joint Motion of Southwest Power Pool, Inc. et al. to Hold Section 206 Proceeding in Abeyance
Back to sections and commentaryPDF page 1
1
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Southwest Power Pool, Inc.
)
Docket No. EL26-68-000
JOINT MOVANTS’ AMENDED MOTION
TO HOLD SECTION 206 PROCEEDING IN ABEYANCE
Southwest Power Pool, Inc. (“SPP”), American Electric Power Service
Corporation, Evergy, Inc., GridLiance High Plains LLC, ITC Great Plains, LLC,
Mountrail-Williams Electric Cooperative, NextEra Energy Transmission Southwest, LLC,
Northwestern Energy, Upper Missouri G. & T. Electric Cooperative, Inc. d/b/a Upper
Missouri Power Cooperative, Oklahoma Gas and Electric Company, Tri-State Generation
and Transmission Association, Inc., and Xcel Energy Services Inc. (collectively known as
“Joint Movants”), pursuant to Rule 212 of the Rules of Practice and Procedure of the
Federal Energy Regulatory Commission (“Commission”), respectfully move the
Commission to (i) hold this proceeding, including the deadline for responding to the
briefing questions, in abeyance for ninety-five (95) days, up to and including November
20, 2026; and (ii) establish a five (5) day answer period and act on this Motion as
expeditiously as practicable thereafter. 1
I.
INTRODUCTION
On June 18, 2026, the Commission issued an order instituting a proceeding under
Section 206 of the Federal Power Act (“FPA”) concerning large loads (“Show Cause
Order”).2 In the Show Cause Order, the Commission preliminarily found that the existing
1
Deseret Generation & Transmission Co-operative, Inc. (“Deseret”) is not joining as a Joint
Movant, but Deseret has informed SPP that it does not object to this Motion.
2
Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026).
PDF page 2
2
SPP Open Access Transmission Tariff (“Tariff”)3 governing service to large loads appeared
to be unjust, unreasonable, or unduly discriminatory or preferential.4 The Commission
directed SPP and the jurisdictional Transmission Owners, within sixty (60) days of the
issuance of the Show Cause Order, to either:
1. Show cause why the Tariff remains just and reasonable and not unduly
discriminatory or preferential notwithstanding the absence of provisions that:
a. require the evaluation of alternative transmission technologies and
memorialize ongoing operational requirements in a transmission service
agreement between SPP and the Transmission Customer taking
transmission service on behalf of a large load;
b. provide additional transparency regarding Network Upgrade costs, establish
a pro forma cost recovery agreement to mitigate the risk of cost shifting,
and ensure appropriate crediting of such payments toward Transmission
Owners' transmission revenue requirements;
c. address the rates, terms, and conditions applicable to interconnection
customers serving co-located loads; and
d. address transmission service for co-located loads, load served by Behind-
The-Meter Generation, and flexible large loads willing and able to limit
their use of the transmission system under certain conditions; or
3
Southwest Power Pool, Inc., Open Access Transmission Tariff, Sixth Revised Volume No.
1.
4
Show Cause Order at P 3.
PDF page 3
3
2. explain what revisions to the Tariff would remedy the Commission's identified
concerns should the Commission determine that the Tariff has become unjust and
unreasonable or unduly discriminatory or preferential and therefore establish
replacement Tariff provisions.5
The Show Cause Order expressly contemplates an abeyance to permit SPP and its
stakeholders to develop proposed Tariff revisions to address the identified concerns.
Specifically, the Commission states that it:
will consider requests from SPP and/or the Transmission
Owners to hold, for up to 90 days, all or certain aspects of this
FPA section 206 proceeding in abeyance, including the
deadline to respond to this order. Any such abeyance, which
will begin as of the deadline to respond to this order, would
be considered to provide SPP and the Transmission Owners
time while they work through the stakeholder processes to
develop FPA section 205 filings to revise the Tariff to address
the issues raised in this order.6
Joint Movants respectfully request that the Commission hold this proceeding in
abeyance for ninety-five (95) days, up to and including November 20, 2026. Joint Movants
acknowledge that the requested abeyance exceeds the ninety (90) days contemplated by
the Show Cause Order. The additional five (5) days is necessary to accommodate SPP’s
full stakeholder process, which culminates in a scheduled Board of Directors (“Board”)
meeting,7 as further discussed in Sections III and V of this Motion. This Motion is timely
5
Id.
6
Id. at P 33.
7
This Board of Directors meeting time has already been adjusted to avoid conflicts with
Election Day and Nation Association of Regulatory Utility Commissioners (“NARUC”)
annual meeting dates. Avoiding widespread conflicts to allow meeting participants to more
fully prepare and focus on meetings is important for robust and meaningful participation.
PDF page 4
4
because it is being filed within forty-five (45) days of the issuance of the Show Cause
Order.8
II.
GOOD CAUSE EXISTS TO HOLD THIS PROCEEDING IN ABEYANCE
Good cause exists to grant the Joint Movants' abeyance request. Granting the
requested abeyance will allow SPP to utilize its stakeholder process to develop
comprehensive Tariff revisions responsive to the Show Cause Order. The issues identified
by the Commission involve numerous, interrelated aspects of the Tariff, and developing
proposed Tariff revisions addressing these issues requires careful technical analysis,
coordination among numerous stakeholder groups and membership sectors, and
consideration through SPP's governance process before any proposed revisions can be
presented to the Board for approval and filed with the Commission pursuant to Section 205
of the FPA.
The requested abeyance also will promote administrative efficiency. Absent an
abeyance, SPP, Transmission Owners, stakeholders, and the Commission would be
required to simultaneously litigate the issues raised in this Section 206 proceeding while
SPP conducts the stakeholder process necessary to develop potential Tariff revisions
addressing those same issues. By contrast, the requested abeyance will allow SPP to focus
its efforts on developing a comprehensive Section 205 filing or a package of Section 205
filings that responds to the Commission's concerns through its stakeholder process, thereby
potentially narrowing or resolving issues that otherwise would be litigated in this
proceeding. In addition, feedback received through the stakeholder process has the
8
Show Cause Order at P 33. The Show Cause Order requires any request for abeyance to
be filed within forty-five (45) days of the issuance of the Show Cause Order.
PDF page 5
5
potential to raise and resolve other technical or legal concerns with the language that will
mitigate the risk of needing further Tariff change.
Moreover, the requested abeyance will not prejudice any party. During the limited
abeyance period, the existing Tariff will remain in effect, and no party's substantive rights
will be altered. The requested relief provides the time necessary for SPP to complete the
stakeholder process the Commission expressly contemplated as the vehicle for developing
potential Tariff revisions responsive to the Show Cause Order. In addition, it allows SPP
time to work with stakeholders and vendors to help avoid technical challenges and achieve
orderly implementation of changes to non-Tariff governing documents, software,
procedures, and workflows.
Finally, granting the requested abeyance serves the public interest because, as
discussed further below, it will allow SPP sufficient time to develop comprehensive, well-
vetted Tariff revisions through its established stakeholder process rather than requiring
expedited proposals that have not benefited from the full consideration contemplated and
required by SPP's governance structure. Accordingly, good cause exists to grant this
Motion.
III.
SPP’S STAKEHOLDER PROCESS NECESSITATES ADDITIONAL TIME
TO DEVELOP TARIFF REVISIONS RESPONSIVE TO THE SHOW
CAUSE ORDER
SPP's stakeholder process is the appropriate forum through which potential Tariff
revisions responsive to the Commission's concerns should be developed. Consistent with
the SPP Bylaws, stakeholder input is developed primarily through SPP's Organizational
Groups.9 The Markets and Operations Policy Committee ("MOPC"), through its designated
9
Southwest Power Pool, Inc., Bylaws, First Revised Volume No. 1, Section 1.0, Definitions
of Organizational Group (“A group, other than the Board of Directors and the MembersPDF page 6
6
Organizational Groups, develops and recommends policies and procedures governing the
operation and administration of the Tariff before those recommendations are considered by
the Board.10 Proposed Tariff revisions are developed through SPP's Revision Request
(“RR”) process and proceed through the appropriate working groups and task forces, where
stakeholders evaluate draft language, identify operational and implementation concerns,
recommend refinements, and develop consensus recommendations before proposals are
considered by MOPC and, ultimately, the Board for authorization to file under Section 205
of the FPA. The stakeholder process is particularly important in the context of the Show
Cause Order because it raises issues spanning multiple functional areas of the Tariff and
affects a broad range of stakeholder interests and implicates many aspects of SPP’s
operations. The stakeholder process is more than just a series of public meetings on Tariff
language; it allows for widespread feedback and vetting of process changes whose
implementation details are complex to design and effectuate. The iterative nature of SPP's
stakeholder process ensures that proposed Tariff revisions are informed by the technical,
operational, commercial, legal, and regulatory expertise of the entities that will be
responsible for implementing and operating under those revisions.
The current sixty-day (60) response period does not provide sufficient time to
complete this stakeholder process in a meaningful manner. By contrast, the requested
ninety-five (95) day abeyance will permit, although still on an expedited time frame, SPP
to convene the necessary stakeholder meetings, develop and refine draft revisions to the
Committee, comprising a committee or working group that is charged with specific
responsibilities toward accomplishing SPP’s mission.”).
10
Id. at Section 6.1.
PDF page 7
7
Tariff and other affected governing documents, solicit and incorporate stakeholder
feedback, obtain the approvals required by the SPP Bylaws, and prepare a comprehensive
filing under Section 205 of the FPA. Granting the requested abeyance therefore will
facilitate the development of more complete, thoroughly vetted Tariff revisions and provide
the Commission with a more robust record upon which to evaluate SPP's proposed
response.
The SPP Board was originally scheduled to meet on November 3, 2026. Because
this was scheduled for Election Day, the leadership of the Regional State Committee
(“RSC”), many of whom are elected officials in their state, requested that SPP reschedule
the SPP Board’s quarterly meeting to ensure that all of the members of the RSC are able to
participate. The next week, November 10, 2026, was considered for the SPP Board
meeting, but that date conflicted with the 2026 NARUC Annual Meeting and Education
Conference.11 Most of the members of the RSC will attend the 2026 NARUC Annual
Meeting. To accommodate Election Day and the previously scheduled NARUC annual
meeting, the SPP Board meeting was scheduled for the following week on November 17,
2026. SPP acknowledges that its requested abeyance exceeds the ninety (90) days
contemplated by the Show Cause Order but submits that the additional five (5) days is
necessary to accommodate its full stakeholder process, which culminates in a scheduled
Board meeting, and ensures full participation by members of the RSC.
11
NARUC Annual Meeting: https://www.naruc.org/events/all-events/2026-naruc-annual-
meeting-and-education-conference/.
PDF page 8
8
IV.
ANTICIPATED SECTION 205 FILING
Unlike a typical request to defer a procedural deadline, the Commission expressly
directed respondents seeking abeyance to provide a detailed description of the anticipated
Tariff revisions that would be developed during the requested abeyance period.12
Consistent with that directive, this section summarizes the principal subject areas that SPP
presently anticipates will be developed through its ongoing stakeholder process and
addressed in a filing under Section 205 of the FPA.13
A.
Transmission Service to Eligible Customers on Behalf of Large Loads
In the Show Cause Order, the Commission finds that the Tariff is preliminarily
unjust and unreasonable because it does not require (1) the evaluation of alternative
transmission technologies in transmission service request studies, in all instances, without
the need for a request from the Eligible Customer seeking transmission service on behalf
of a large load; and (2) if traditional Network Upgrades are selected instead of alternative
transmission technologies, inclusion in the study report to the Eligible Customer seeking
transmission service on behalf of a large load of a sufficiently clear demonstration of why
alternative transmission technologies are not feasible or would not result in lower costs or
a faster timeline for accommodating the transmission service request.14
12
Show Cause Order at P 33.
13
These descriptions are necessarily preliminary and are intended to provide the Commission
with a good-faith understanding of the anticipated scope of SPP's efforts during the
requested abeyance period. SPP continues to work internally and with its stakeholders to
determine the full scope of appropriate Tariff revisions. Accordingly, the descriptions
below should not be construed as an exhaustive or final statement of the Tariff changes that
may be included in a future Section 205 filing.
14
Show Cause Order at P 45.
PDF page 9
9
SPP recently implemented its High Impact Large Load ("HILL")15 process to
provide an expedited framework for evaluating transmission service requests associated
with large loads.16 Although the HILL Delivery Point Study (“HDPS”) process includes
enhanced study analyses to ensure that the unique operational characteristics of HILLs are
considered when evaluating the addition of a HILL to the Transmission System, and that
SPP has mechanisms in place to maintain reliable operation of the Transmission System,17
it does not currently require SPP to evaluate alternative transmission technologies when
studying HILLs.18 Accordingly, SPP currently anticipates working through its stakeholder
process to develop revisions to incorporate such an evaluation into the study process.
SPP currently anticipates that this effort will include consideration of the point
during the study process in which alternative transmission technologies should be
evaluated, the technologies that should be considered, and the information that should be
documented in study reports regarding those evaluations. Development of these revisions
will require coordinated review and technical analysis by multiple stakeholder groups and
15
Tariff at Part I, Section 1, defines a HILL as “A new commercial or industrial load, or
increase in commercial or industrial load, at a single site connected through one or more
shared Points of Interconnection (POIs) or delivery points, where such load is either (1) 10
MW or more if connected to the Transmission System at a voltage level less than or equal
to 69 kV; or (2) 50 MW or more if connected to the Transmission System at a voltage level
greater than 69 kV. An Electric Storage Resource is not considered a HILL. A load may be
categorized as a HILL after the initial effective date of Attachment BA of the Tariff. High
Impact Large Loads must register as such in accordance with Attachment AE of the Tariff
and follow the processes specified in Attachment BA of the Tariff.”.
16
Tariff, Attachment BA.
17
Tariff, Attachment BA, Section 2.1.3.4. The HDPS is a supplemental assessment, in
addition to the studies required pursuant to Attachment AQ, Attachment AX, and/or
Attachment BC of the Tariff, of the impact of a requested HILL delivery point
configuration change on the Transmission System.
18
Id.PDF page 10
10
subject matter experts and ensure that any proposed revisions do not cause unintended
impacts to Commission approved processes addressing interconnection of large loads.
Second, the Commission found that the HILL process does not include pro forma
provisions in transmission service agreements between SPP and the Transmission
Customer taking transmission service on behalf of a HILL that memorialize ongoing
operational requirements.19 The Commission recognized that these operational
requirements do exist in the Tariff but expressed concern that without pro forma provisions
in the transmission service agreement between SPP and the Transmission Customer, SPP
may be unable to enforce the ongoing operational requirements of HILLs.20
Accordingly, SPP currently anticipates working through its stakeholder process to
develop revisions to the Tariff's pro forma transmission service agreements, namely the
Network Integration Transmission Service Agreement21 and the Form of Service
Agreement for Firm Point-To-Point Transmission Service,22 that would incorporate the
applicable operational requirements for HILLs. Because revisions to the pro forma service
agreements affect the contractual rights and obligations of Transmission Customers and
SPP, their development requires stakeholder review and collaboration.
B.
Cost Shifting Risk Among Transmission Customers
The Commission preliminarily found that the Tariff is unjust and unreasonable
because it does not require the public posting, of information regarding transmission
19
Show Cause Order at P 46.
20
Id.
21
Tariff, Attachment F.
22
Tariff, Attachment A.
PDF page 11
11
service requests associated with large loads and the Network Upgrades necessary to
provide such service.23 Specifically, the Commission identified the absence of Tariff
provisions governing the disclosure of information regarding Network Upgrades driven by
large loads, associated cost estimates, the requesting entity, project status within SPP's
planning process, aggregate large load additions, and related transmission planning
information. The Commission acknowledges that SPP provides some information to
stakeholders regarding the cost of Network Upgrades but that the Tariff does not explicitly
contain provisions that require SPP to publicly post estimates for Network Upgrades
necessary to provide transmission service to Eligible Customers on behalf of large loads.24
SPP anticipates that stakeholders will evaluate development of new Tariff
provisions governing the public reporting of transmission planning and transmission
service information associated with large loads including (1) the categories of information
that should be publicly reported with respect to HILLs; (2) the identification of Network
Upgrades associated with HILLs; (3) the disclosure of estimated Network Upgrade costs
associated with HILLs; (4) reporting regarding aggregate large load additions throughout
the SPP footprint and within individual transmission pricing zones; (5) identification of
project status within SPP's transmission planning process; (6) the frequency with which
information should be updated; (7) the format in which information should be made
publicly available; and (8) any necessary confidentiality limitations. Although the
Commission identified the categories of information it preliminarily believes should be
23
Show Cause Order at PP 52-54.
24
Id. at P 55.
PDF page 12
12
publicly available, substantial stakeholder input remains necessary to determine how those
reporting requirements should be implemented.
Next, the Commission finds that the Tariff lacks a pro forma cost recovery
agreement between SPP, the relevant Transmission Owner, and the Eligible Customer
serving a large load that requires the Eligible Customer to make a minimum contribution
toward the Transmission Owner’s transmission revenue requirement, if the Eligible
Customer ultimately takes less transmission service than anticipated because the large load
does not materialize as planned or is not developed at all.25 The Commission also found
that the minimum contribution required pursuant to such cost recovery agreement should
be based on the level of jurisdictional transmission service requested by the Eligible
Customer on behalf of the large load and that such cost recovery agreement should include
a credit support or other financial security requirement sufficient to secure the obligations
of the Eligible Customer taking transmission service on behalf of a large load to pay the
amounts owed pursuant to the cost recovery agreement.26
SPP has initiated a comprehensive stakeholder effort through its Cost Control and
Allocation Review & Evaluation Team (“CARE Team”)27 to evaluate potential Tariff
revisions responsive to the Commission's concerns regarding cost mitigation and cost
25
Show Cause Order at PP 61-63.
26
Id. at P 65.
27
The CARE Team was established in November 2025 to serve as a cross-functional
leadership body to review, evaluate, assess, and recommend refinements or alternatives to
the current transmission cost controls and cost allocation methodologies in SPP including
cost allocation challenges associated with large load growth and related infrastructure
needs. See CARE Team Organizational Group Scope Statement (November 2025) located
at: https://www.spp.org/spp-documents-filings/?id=552360.
PDF page 13
13
shifting.28 Stakeholders are presently evaluating multiple alternative approaches to address
this specific concern. Although no specific approach has be determined by the CARE
Team, the following are some of the alternative approaches being considered: (1)
establishment of financial security requirements securing the cost of Base Plan Upgrades
constructed to serve large load delivery points; (2) direct assignment, in whole or in part,
of Network Upgrade costs associated with large load delivery point additions or
modifications; (3) combinations of direct assignment and financial security designed to
satisfy the Commission's minimum contribution expectations while preserving appropriate
Base Plan funding principles; (4) other mechanisms for ensuring a minimum contribution
from Transmission Customers serving large loads; and (5) corresponding revisions
governing the disposition of recovered funds to ensure that any amounts recovered are
applied to reduce costs otherwise borne by Transmission Customers.
With respect to the financial security framework, stakeholders have already begun
consideration of numerous implementation questions including, but not limited to: (1) the
appropriate amount and form of any required financial security; (2) the period of time that
should be allowed for the load to materialize before a claim is made on the financial
security; (3) how long the load should remain in place in order to avoid a claim on the
financial security; (4) whether the financial security should be assessed in part if the load
that materializes is less than predicted; (5) how the delivery point should be quantified for
the purpose of assessing a potential claim on security; and (6) whether projected operating
and maintenance expense of the upgrade should be included in the financial security
28
CARE Meeting Materials, dated July 23, 2026, at Agenda Item 7 posted at:
https://www.spp.org/spp-documents-filings/?id=552361.
PDF page 14
14
requirement. With respect to the potential direct charge framework, stakeholders have also
begun considering: (1) whether to apply full or partial direct assignment of delivery point
upgrade costs; (2) if such direct assignment is partial, how the partial direct assignment
should be implemented and whether the direct assignment should take the form of capital
cost only or revenue requirements over a fixed period; and (3) whether a form of minimum
charge other than, or in addition to, direct assignment of delivery point costs would be
appropriate.
These multiple alternatives present significant policy choices that extend far
beyond drafting of Tariff language, implicating fundamental cost allocation principles that
have governed SPP's transmission planning and funding framework for many years.
Implementation of the alternatives presently under consideration will require coordinated
revisions across multiple components of the Tariff, introducing interrelated policy and
implementation issues that underscore the importance of meaningful stakeholder
development.
C.
Co-Location Arrangements and Load with Behind-The-Meter
Generation
The Commission preliminarily found that the Tariff should provide greater clarity
regarding the treatment of co-located29 resources and behind-the-meter generation,
including the circumstances under which such resources are subject to the Tariff's
29
The Show Cause Order defines co-located load as a configuration that refers to end-use
customer load that is physically connected to the facilities of an existing or planned
generating facility on the interconnection customer’s side of the point of interconnection
to the RTO/ISO’s transmission system. In the Show Cause Order, the Commission uses the
term co-location arrangement when referring to both the co-located load and the associated
generating facility.
PDF page 15
15
transmission service, interconnection, and market participation requirements.30 The
Commission expressed concern regarding the absence of Tariff provisions addressing
transmission and ancillary service rates for Eligible Customers taking transmission service
on behalf of Eligible Load.31
Stakeholder development is necessary to determine, among other things, (1) the
appropriate terminology and definition used to describe generators interconnected to
facilities that are not connected to the Transmission System; (2) the study process
applicable to such generators; and (3) the overlap between transmission service,
interconnection, and market registration requirements. Stakeholder coordination is
essential to development of a comprehensive framework that provides the clarity sought
by the Commission.
D.
Extending New Transmission Services to Eligible Customers Taking
Service on Behalf of Flexible Large Loads
The Commission preliminarily found the Tariff unjust and unreasonable because it
does not include transmission services that reflect Eligible Customers taking transmission
service on behalf of flexible large loads32 that are willing and able to limit their use of the
Transmission System under certain conditions.33 The Commission required SPP to explain
30
Show Cause Order at PP 75-80.
31
Id. at PP 77, 80-82.
32
The Show Cause Order clarifies that, for purposes of the Show Cause Order, “flexible”
large loads are a subset of HILLs that are not co-located with generation but are willing
and able to limit their energy withdrawals from the Transmission System under certain
conditions. See Show Cause Order at n.163.
33
Show Cause Order at P 86.
PDF page 16
16
whether the Tariff remains just and reasonable without (1) an interim non-firm network
transmission service while Network Upgrades are being constructed (i.e., interim NITS)
and (2) permanent firm and non-firm contract demand transmission services.34
The Commission expressly noted SPP’s Price Adaptative Load (“PAL”) and Price
Adaptive Load Service (“PALS”) proposal (collectively “PAL/PALS”), which is currently
under stakeholder development, and urged SPP to consider whether PALS would address
the Commission’s concern that the Tariff may be unjust and unreasonable because it does
not include transmission services that reflect the use of the Transmission System by
Eligible Customers on behalf of flexible large load.35 Unlike traditional transmission
service, the PAL/PALS framework would establish both a new market participation model
and a new non-firm transmission service designed specifically for dispatchable, price-
responsive large loads. Under the current proposal, participating loads would submit price-
sensitive bids into SPP's Integrated Marketplace and would be required to respond to Day-
Ahead Market commitments and Real-Time Balancing Market dispatch instructions.
Correspondingly, PALS would establish a new transmission service under which
participating loads would receive transmission service subject to usage-based pricing,
mandatory dispatchability requirements, and Curtailment during transmission constraints,
Emergency Conditions, or local reliability events. As explained in SPP’s Informational
Report,36 the PAL/PALS initiative has already progressed through extensive stakeholder
34
Id. at P 87.
35
Id. at P 88.
36
Informational Report of Southwest Power Pool, Inc., Docket No. EL26-68-000, at 25
(July 20, 2026).
PDF page 17
17
education and preliminary design. SPP anticipates continued stakeholder review over the
next several months with formal, with final approval anticipated on November 17, 2026.
Continued stakeholder review and collaboration is needed before approval of the
PAL/PALS framework.
In addition to PALS, SPP anticipates stakeholder consideration of revisions to
existing transmission service product(s), such as the Conditional High Impact Large Load
Service (CHILLS), to include control technologies and/or protection systems designed to
limit energy withdrawals from the Transmission System. Continued stakeholder
collaboration is necessary because incorporating control technologies and/or protection
systems into existing transmission service products implicates technical, operational, and
policy considerations extending well beyond the development of Tariff language.
V.
OVERALL SCHEDULE AND ANTICIPATED SECTION 205 FILING
TIMELINE
Draft RRs addressing several of the Commission's preliminary findings are
expected to be posted for stakeholder review in early August 2026. Throughout the
requested abeyance period, the proposals will proceed through technical development,
stakeholder education, policy discussions, and formal review by the applicable working
groups, culminating in working group votes during September and October, MOPC in
October, the RSC where applicable in November, and final Board consideration on
November 17, 2026. SPP anticipates the same timeline for approval and filing of the
PAL/PALS RR.
Accordingly, Joint Movants respectfully request that the Commission hold this
proceeding in abeyance until November 20, 2026, and establish that date as the deadline
for SPP to respond to the Show Cause Order through a comprehensive filing under Section
PDF page 18
18
205 of the FPA. A ninety-five (95) day abeyance is necessary because the Board must
provide final authorization for the Section 205 filing described herein and is not scheduled
to meet until November 17, 2026.37 Following Board authorization, SPP requires a brief
period to finalize and submit the resulting Section 205 filing(s) to comply with the Show
Cause Order.
VI.
REQUEST
FOR
SHORTENED ANSWER
PERIOD,
EXPEDITED
COMMISSION ACTION, AND REQUEST FOR ABEYANCE OF THE
DEADLINE TO RESPOND TO THE BRIEFING QUESTIONS
Joint Movants respectfully request that the Commission establish a five (5) day
period for answers to this Motion38 and act as expeditiously as practicable thereafter. As
the Commission recognized in the Show Cause Order, requests for abeyance must be filed
sufficiently in advance of the August 17, 2026, response deadline to allow the Commission
adequate time to act before that deadline expires. Prompt action on this Motion will provide
SPP and its stakeholders with certainty regarding the applicable timeline and avoid the
need to simultaneously prepare both a response to the Show Cause Order and the
anticipated Section 205 filing. Absent timely action, SPP would be required to devote
substantial resources to preparing filings that may ultimately prove unnecessary if the
requested abeyance is granted. Expedited consideration therefore will promote
37
The Board’s regularly scheduled meetings occur quarterly and are scheduled many months
in advance. This Board of Directors meeting time has already been adjusted to avoid
conflicts with Election Day and NARUC meeting dates. Avoiding widespread conflicts to
allow meeting participants to more fully prepare and focus on meetings is important for
robust and meaningful participation.
38
To the extent necessary, SPP requests waiver of Rule 213 of the Commission’s Rules of
Practice and Procedure, 18 C.F.R.§ 385.213, which provides that an answer to a motion
must be filed within 15 days, unless otherwise ordered. The Show Cause Order requires
abeyance requests to be filed by August 3, 2026, and expressly contemplates that the
Commission will issue an order on any such request prior to the response deadline of
August 17, 2026 (14 days after the abeyance request deadline).
PDF page 19
19
administrative efficiency and further the purpose for which the Commission authorized
parties to seek an abeyance.
In addition, because the Show Cause Order establishes a single deadline for both
Joint Movants' response and their responses to the accompanying briefing questions, Joint
Movants respectfully request that any order granting this Motion also apply to and defer
the deadline to submit responses to the briefing questions proposed in the Show Cause
Order. The briefing questions seek Joint Movants' views regarding the very Tariff revisions
and policy determinations currently under stakeholder development. Accordingly,
responses submitted following completion of that process will provide the Commission
with a more complete and useful record than preliminary responses prepared before
stakeholders have developed the comprehensive Tariff revisions contemplated in this
Motion.
VII.
CONCLUSION
For the reasons stated herein, Joint Movants respectfully request the Commission:
(1) Grant this Motion and hold the above-captioned proceeding in abeyance for
ninety-five (95) days, up to and including November 20, 2026, to permit SPP to complete
its stakeholder process and submit a comprehensive filing under Section 205 of the FPA
addressing the Commission's preliminary findings in the Show Cause Order;
(2) Find that, if the requested abeyance is granted, the deadline for Joint Movants’
responses to the briefing questions accompanying the Show Cause Order likewise are held
in abeyance and deferred to November 20, 2026;
(3) Establish a five (5) day period for answers to this Motion; and
PDF page 20
20
(4) Act on this Motion as expeditiously as practicable following the close of the
answer period.
Respectfully submitted,
/s/ Meredith Powell
Meredith Powell
Justin A. Hinton
Emon O. Mahony
Southwest Power Pool, Inc.
201 Worthen Drive
Little Rock, AR 72223
Attorneys for
Southwest Power Pool, Inc.
/s/ Shannon M. Heim
Shannon M. Heim
General Counsel, Vice President – Federal
Government Affairs & FERC Compliance
Officer
NorthWestern Energy
208 N. Montana Ave., Suite 200
Helena, MT 59601
Attorney for NorthWestern Energy
/s/ John C. Crespo
Senior Legal Counsel
American Electric Power Service
Corporation
1 Riverside Plaza, 29th Floor
Columbus, OH 43215
Phone: (614) 716-3727
Email: jccrespo@aep.com
Attorney for American Electric Power
Service Corporation
/s/ C. Patrick Woods
C. Patrick Woods
President
ITC Great Plains, LLC
3500 SW Fairlawn Rd., Ste. 101
Topeka, KS 66614
On Behalf of ITC Great Plains, LLC
/s/ Denise Buffington
Denise Buffington
Senior Director Federal Regulatory Affairs
EVERGY, INC.
1200 Main St.
Kansas City, MO 64105
On Behalf of EVERGY, INC.
PDF page 21
21
/s/ Carly Masenthin
Carly Masenthin
Corporate Counsel
EVERGY, INC.
818 S Kansas Avenue
Topeka, Kansas 66612
Attorney for EVERGY, INC.
/s/ Travis M. Contratto
Travis M. Contratto
Principal Attorney
NextEra Energy, Inc.
801 Pennsylvania Avenue NW
Suite 220
Washington, DC 20004
Attorney for NextEra Energy
Transmission Southwest, LLC and
GridLiance High Plains LLC
/s/ A. Chase Snodgrass
A. Chase Snodgrass, OBA No. 33275
Senior Regulatory Attorney
Oklahoma Gas and Electric Company
321 N. Harvey Ave. M/C 300
Oklahoma City, OK 73102
Attorney for Oklahoma Gas and
Electric Company
/s/ Allison E. S. Salvia
Allison E. S. Salvia
Eversheds Sutherland (US) LLP
700 Sixth St., N.W., Suite 700
Washington, DC 20001-3980
Attorney for Upper Missouri Power
Cooperative
/s/ Michael A. Monson
Michael A. Monson
Billstein, Monson & Small PLLC
1555 Campus Way, Suite 201
Billings, MT 59102
Attorney for Upper Missouri Power
Cooperative
/s/ Jeremy Mahowald
Jeremy Mahowald
General Manager
Upper Missouri Power Cooperative
111 2nd Ave. SW
Sidney, MT 59270
On Behalf of Upper Missouri Power
Cooperative
/s/ Jesse Halpern
Jesse Halpern
Thompson Coburn LLP
1909 K Street, N.W.
Suite 600
Washington, D.C. 20006
Counsel for Montrail-Williams Electric
Cooperative
/s/ Ryan Hubbard
Vice President, Transmission Planning
Policy
Tri-State Generation & Transmission
Association, Inc.
1100 West 116th Avenue
Westminster, CO 80234
On Behalf of Tri-State Generation &
Transmission Association, Inc.
PDF page 22
22
/s/ Tyler Nemkov
Senior Regulatory Attorney
Tri-State Generation & Transmission
Association, Inc.
1100 West 116th Avenue
Westminster, CO 80234
Attorney for Tri-State Generation &
Transmission Association, Inc.
/s/ Timothy T. Mastrogiacomo
Timothy T. Mastrogiacomo
Vice President, Federal Regulatory, Legal,
and Policy
Xcel Energy Services Inc.
701 Pennsylvania Avenue, NW, Ste. 250
Washington, DC 20006
On Behalf of Xcel Energy Services Inc.
August 3, 2026
PDF page 23
23
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
Dated at Little Rock, Arkansas, this 3rd day of August, 2026.
/s/ Cassie Butler
Cassie Butler
Southwest Power Pool, Inc.
201 Worthen Drive
Little Rock, AR 72223-4936
(501) 614-3200