The Southern Renewable Energy Association (SREA) values the opportunity to provide comments regarding the SERTP Sponsors initial request for reforming the Regional Planning Stakeholder Group (RPSG). At its most recent meeting on April 30th, SERTP sponsors requested feedback regarding potential reform to the RPSG. SREA supports the discussion about reforming the RPSG, and we would encourage SERTP to continue these discussions for an eventual FERC filing.

1. Expand Stakeholder Eligibility and Representation

The current RPSG structure limits stakeholder representation to a narrow set of industry sectors and restricts participation to two representatives per sector. This framework unnecessarily constrains inclusive engagement and limits the range of perspectives in regional transmission planning. Alternatively, within MISO’s stakeholder process, there are eleven sectors that allow any number of participants. If items require voting, each sector has designated and self-selected representatives that participate in voting.¹ Critically, the current RPSG structure does not provide a pathway for state regulatory bodies—such as Public Service Commissions (PSCs)—to formally participate in the RPSG.

Recommendation

• Broaden sectoral representation and remove the two-representative per-sector limit
• Create dedicated seats or a structured engagement process for state regulatory bodies

2. Improve Data Access and Transparency

For stakeholders to meaningfully contribute to transmission planning, access to planning models and data is essential. This includes—but is not limited to—capacity expansion models, load forecasts, generation assumptions, and scenario planning data. Currently, access barriers such as background checks or cost prohibitions deter participation.

Recommendation

• Ensure all relevant planning data are made publicly accessible, subject to resonable confidentiality protections (e.g., CEII)
• Remove requirements for background checks and access fees for participation in the RPSG process

3. Establish Robust Governance and Voting Procedures

The RPSG currently lacks sufficient governanace authority and transparency in its operations. It does not have a formal voting structure, nor does it possess the ability to set agendas or initiate substantive discussions independently. MISO' Stakeholder Governance Guide may be helpful in developing a framework for discussion².

Recommendation

• Develop a formal governance structure including voting rights, agenda-setting authority, and rights to initiate presentations and analyses
• Establish a charter that defines the roles and responsibilities of the RPSG independent of, but in coordination with, SERTP sponsors

4. Enable Stakeholder-Led Scenario Development

Stakeholder input into scenario planning is a cornerstone of inclusive and credible transmission planning. Currently, the timeline for RPSG input into scenario modeling is not well-defined.

Recommendation

• Allow the RPSG to propose stakeholder-defined scenarios
• Require SERTP sponsors to provide draft modeling inputs at least 15–30 days in advance of stakeholder review deadlines to ensure adequate time for evaluation and feedback • Establish clear and firm dates far in advance of due dates, milestones, and meetings planned

5. Strengthen Meeting Cadence and Accessibility

The current RPSG meeting schedule is vague and harms timely stakeholder input.

Recommendation

• Schedule meetings on a consistent quarterly basis, with advance notice of at least 30 days
• Empower the RPSG to call ad hoc meetings with SERTP sponsors when necessary
• Record meetings, provide meeting minutes, and post meeting material and minutes publicly in a timely fashion

6. Establish Dispute Resolution and Appeals Mechanisms

Disputes and disagreements on planning assumptions or stakeholder input should be addressed through a formal and impartial mechanism.

Recommendation

• Create an independent dispute resolution process, potentially through a mediator or advisory panel, accessible to all RPSG participants

7. Develop an Educational Curriculum for Stakeholders

To ensure informed participation, stakeholders should be equipped with access to training on transmission planning tools, processes, and data interpretation.

Recommendation

• Task the RPSG, in partnership with SERTP sponsors, with developing an educational curriculum tailored for both new and existing participants

8. Encourage—but Distinguish—State Decision-Maker Involvement

While state regulatory agencies should be encouraged to participate in the RPSG, the RPSG is not an adequate substitute for state-level coordination on policy and regulatory issues.

Recommendation

• Strongly encourage participation of state PSCs in the RPSG
• Concurrently, establish a separate Regional State Committee (RSC), similar to those in MISO and SPP, to coordinate state-level engagement in transmission policy, cost allocation, and regional infrastructure priorities

Conclusion

Reforming the RPSG is critical to meeting the ambitious transmission best practices and to ensuring that the SERTP process is fully compliant with both the letter and spirit of federal planning requirements. These reforms will support more robust, inclusive, and future-ready transmission planning in the Southeast. We urge the SERTP Sponsors to take these recommendations into serious consideration and look forward to continued dialogue to enhance regional transmission planning.

1. MISO Stakeholder Governance Guide. https://cdn.misoenergy.org/Stakeholder%20Governance%20Guide105455.pdf 

2. MISO Stakeholder Governance Guide. https://cdn.misoenergy.org/Stakeholder%20Governance%20Guide105455.pdf