An analysis by [[page-3191983|Philip Herold]] of the [[ferc|FERC]] proceeding where ISO-NE transmission owners (TOs) seek a higher base return on equity (ROE), opposed by NESCOE and consumer advocates.

Key Dynamics

• Structural ROE: Long treated as a fixed input, authorized ROE is a dynamic variable that moves the delivered cost of power.
• Geometric Compounding: A higher ROE multiplier applies to a rapidly expanding transmission rate base driven by offshore wind, HVDC interties, and onshore reinforcement.
• The Delivery Stack: Unbundles the PPA "delivery" line (Regional Network Service, or RNS) from a pass-through assumption into an active sensitivity.

Parallel Regulatory Movements

• [[aneel|ANEEL]] Mirror Trade: Unlike Brazil's downward pressure on infrastructure returns, ISO-NE TOs are pushing returns up. Both show regulated returns as volatile.
• Cost Allocation Shifts: PJM Schedule 12 challenges, Oregon's data-center rate class, and Travis Kavulla's "segregated queue" framework signal shifting cost burdens onto large loads.
• Affordability Politics: State pushback mirrors generation-side battles, such as Ohio bills for utility-owned nuclear plants.