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FERC Approves SPP “System Support Resource” Program to Manage Generator Retirements

By Sahara Shrestha & Alexander Kaplen on March 25, 2026
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On March 19, 2026, FERC approved Southwest Power Pool, Inc.’s (SPP) System Support Resource (SSR) program to allow SPP, under specified conditions, to keep certain generating units that plan to retire temporarily online when they are needed to maintain reliability of the bulk electric system in the SPP region.  In doing so, FERC found that SPP’s proposal appropriately balanced the need to maintain reliability with generator owners’ ability to implement their business plans.

SPP’s proposal builds on its existing generator retirement study process set out in Attachment AB of its tariff. Under SPP’s Tariff Attachment AB, a generator owner must request a retirement study at least one year before the planned retirement date using the specified form. SPP first performs a preliminary screening of the retirement’s impact on the transmission system and provides results within 30 days. If the screening shows no need for further analysis, the owner may proceed to submit its retirement notice. If the screening indicates potential reliability concerns, SPP conducts a detailed Resource Retirement Study using power flow, transient stability, and short-circuit analyses. If no reliability issues are found, the resource may retire; if SPP identifies reliability issues, SPP may require network upgrades to address the reliability impact before retirement can occur. The generator owner may withdraw its retirement request at any point during this process.

In its filing, SPP explained that an SSR mechanism is needed as a last‑resort, short‑term backstop to address reliability issues caused by generator retirements when no timely alternative solution is available. SPP described the program as voluntary and modeled on the Midcontinent Independent System Operator’s SSR construct and other “Reliability Must Run” (RMR)‑type programs, with SSR Agreements generally limited to 12‑month terms and subject to at least annual review. SPP further proposed that compensation is capped at the cost‑of‑service for extended SSR operation, focused on “Eligible Costs” associated with continued operation and excluding sunk costs and other expenses the owner would incur even if the unit retired, and that SSR costs should be allocated to “Asset Owners” in proportion to the reliability benefits they receive.

FERC concluded that SPP’s SSR program is just and reasonable and not unduly discriminatory or preferential, finding it to be a reasonable, limited backstop that appropriately balances SPP’s reliability obligations with generator owners’ ability to implement their business plans. The Commission determined that the proposed compensation framework, which provides for a FERC‑approved Monthly SSR Payment net of market revenues and limited to going‑forward costs, is consistent with Commission precedent on voluntary backstop and RMR arrangements, and that SPP’s proposed cost allocation to benefiting Asset Owners accords with cost‑causation principles. FERC granted SPP’s request for waiver of the 120‑day prior‑notice requirement, accepted the tariff records with a placeholder effective date of December 31, 9998, and directed SPP to submit a subsequent compliance filing at least seven days before implementation to specify the actual effective date expected in late 2026.

A copy of FERC’s order, filed in Docket No. ER25-177, is available here.

Photo of Sahara Shrestha Sahara Shrestha

Sahara represents clients in the hydropower, natural gas, and electric utility sector before the Federal Energy Regulatory Commission (FERC) and the D.C. Circuit. She advises hydropower clients on all aspects of FERC licensing and compliance under the Federal Power Act, as well as…

Sahara represents clients in the hydropower, natural gas, and electric utility sector before the Federal Energy Regulatory Commission (FERC) and the D.C. Circuit. She advises hydropower clients on all aspects of FERC licensing and compliance under the Federal Power Act, as well as issues arising under other federal statutes, including the Clean Water Act, National Environmental Policy Act, National Historic Preservation Act, and Endangered Species Act. Sahara also advises natural gas clients in certificate proceedings and compliance matters, and advises electric utility clients on transmission, interconnection, and market design issues.

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Photo of Alexander Kaplen Alexander Kaplen

Alexander advises clients on all aspects of regulatory issues. With experiences in both the public and private sectors, he applies a deep understanding of the legal, regulatory, and strategic challenges facing stakeholders in the energy sector.

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  • Posted in:
    Energy and Utilities
  • Blog:
    Washington Energy Report
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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