An analysis by John Patrick Herold compares the transmission return on equity (ROE) dispute in [[ferc|ISO-NE]] to [[aneel|ANEEL's]] Âmbar decision (news-3215980), framing it as a structural repricing of power purchase agreements (PPAs) across New England.

Key Dynamics

• The ROE Fight: ISO-NE transmission owners have petitioned [[ferc|FERC]] to raise their base ROE, opposed by NESCOE, state AGs, and consumer advocates.
• PPA Cost Impact: Base ROE acts as a multiplier on regional net plant in service (expanding due to offshore wind, HVDC interties to Canada, and electrification capex). This directly raises the Regional Network Service (RNS) "delivery" rate embedded in PPAs.
• The Allocation Axis: Alongside the ROE fight, battles over cost allocation—such as Maryland's challenge to PJM Schedule 12, Oregon's data-center rate class, and Travis Kavulla's segregated queue framework (news-3216075)—make "transmission as pass-through noise" an untenable modeling assumption.

Strategic Recommendations

1. Unbundle Delivery: Carry RNS as a sensitivity (bracketed by a 50-100 bps ROE shift) rather than a constant.
2. Model Allocation Separately: Account for potential step-changes in transmission cost recovery for large loads.
3. Recognize Variable Returns: Understand that authorized returns are active, contested variables.