FERC Section 206 Complaint Filing: April 2026 | Sign on as a supporting party →
Consumer Affordability Initiative

Billions in
Hidden Electricity Costs.
You're paying for it.

Across America's electricity markets, an incomplete system lets billions in unhedged congestion costs flow directly to your electric bill. Driven by renewable energy growth, congestion charges are increasing and the tools to manage them were designed for a different grid. There's a proven fix. We're fighting to implement it.

$30.8B
Total congestion charges across PJM, MISO & SPP since 2018. $15.0B in the last 3 years alone (ISO State of Market reports).
$11.9B
Paid by consumers. The ARR process returns only 61% of all congestion charges.
$5.5B
Renewable RT congestion since 2023 — 37% of recent congestion. ARR paths are limited and no products exist to manage this.
$29.3B
In additional credits unlocked with an RT Congestion Hedge. ARRs provide only $18.9B, while an optimal hedge could achieve upwards of $48.2B.

Understand the problem in 60 seconds

Watch the explainer below to see why congestion costs show up on your electric bill — and what we can do about it.

A 60-second explainer on why congestion costs show up on your electric bill

About the Affordable Grid Coalition

The Affordable Grid Coalition is a cross-sector alliance of energy market participants, consumer advocates, renewable developers, and state officials united by a simple principle: consumers deserve congestion credit tools that reflect today's grid — not yesterday's.

The coalition was founded in 2025 by energy market professionals and consumer advocates who spent over a decade documenting the congestion hedging gap across U.S. wholesale electricity markets. Our quantitative analysis covers PJM, MISO, and SPP to date, with NYISO and CAISO analysis underway. All figures are grounded in publicly available settlement data, validated against Independent Market Monitor findings.

Data & analysis provided by XO Energy, LLC — an energy trading and analytics firm specializing in congestion revenue rights across PJM, MISO, SPP, and ERCOT. Contact: info@xo-energy.com

Our growing coalition includes state utility commissions, consumer advocacy organizations, renewable energy developers, cooperative utilities, and individual market participants who believe consumers deserve the same congestion protections Texas ratepayers already have.

Consumer Benefits

How This Saves You Money

You pay for every dollar of electricity congestion. Right now, billions of those dollars are unmanaged. Here's how a real-time congestion hedge puts money back in your pocket.

Follow the money trail from the power grid to your monthly bill

The Numbers Don't Lie

The math is simple: utilities currently return $18.9 billion through existing congestion credits to offset $30.8 billion in charges. The difference — $11.9 billion — is paid directly by consumers, an average gap of $1.5 billion per year. Additional credits exist to help offset increasingly large congestion charges, however no products exist to capture them.

The Simple Version

Today

Your electric bill includes congestion charges — the cost of moving power through a constrained grid. To offset these charges, credits are allocated through a year-ahead process based on legacy transmission paths. But the grid has changed. Renewable growth, shifting load patterns, and real-time conditions look nothing like what was planned a year ago. The result: credits cover only 61% of actual congestion charges. The rest — $11.9 billion since 2018 — lands on your bill.

With RT Congestion Hedge

An RT Congestion Hedge allows market participants to manage the congestion that's occurring right now — not what was planned a year ago. This active management increases the total credits flowing back to consumers and improves the value of existing ARR and FTR credits. More credits, lower bills — all through the same cost-recovery process already in place.

Think About It Like Your Commute

🗺️

Paper Map vs. GPS

Today's system is like planning a road trip with a paper map months or years in advance. You pick your route, lock it in, and hope for the best. But you couldn't possibly see the traffic jam occurring today. An RT Congestion Hedge is like upgrading to GPS with live traffic data — it manages what's actually happening on the grid right now, not what was predicted a year ago.

How This Saves Consumers Money

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More Credits Return to Consumers

The RT Congestion Hedge generates additional congestion credits that flow back to consumers through existing cost-recovery mechanisms. Today, ARR credits return only 61% of total congestion charges. An RT Congestion Hedge captures value that current tools miss — growing the total credit pool and narrowing the $11.9 billion gap.

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Existing Credits Become More Valuable

When market participants actively manage real-time congestion, day-ahead and real-time prices converge. That convergence makes existing ARR and FTR credits more valuable — they fund more fully, returning more to consumers without any changes to the current allocation process.

🌱

Renewable Congestion Costs Come Down

Renewable energy is the fastest-growing driver of congestion charges — $5.5 billion since 2023 across PJM, MISO, and SPP. This congestion is largely unhedged because ARR allocations are built on legacy paths that predate today's renewable fleet. With an RT Congestion Hedge, these costs can be managed and credited back to consumers.

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Growing Load, Growing Costs

Data centers and electrification are driving unprecedented load growth. More load means more congestion, and more congestion means higher charges for everyone. An RT Congestion Hedge ensures these costs can be actively managed rather than passed through to all consumers.

Why are bills going up but nothing's changing?

Utilities recover congestion costs through state-regulated mechanisms — charges flow directly to consumers. Because utilities are made whole through this process, the incentives that would typically drive action — increasing costs and higher bills — don't apply. That's why federal action through FERC is needed to bring an RT Congestion Hedge to market, and why consumer support matters.

It Already Works in Texas

ERCOT's Point-to-Point Obligation product lets participants manage real-time congestion at every node on the grid, every day. It's been running for years with proven results:

Full
Congestion revenue consistently returned to consumers
Full Nodal
Available at all resources including renewables — wind, solar, and batteries
Open
Available to all participants, increasing competition

Your voice matters in this fight.

Join thousands of consumers, advocates, and regulators demanding that FERC bring real-time congestion hedging tools to every U.S. electricity market.

The Congestion Problem

The data from ISO State of Market reports and ARR credit analysis — market by market, dollar by dollar. Here's what consumers are paying and what's being left on the table.

The Evidence Is Overwhelming

Congestion Credits by the Numbers

$30.8B
Total congestion charges across PJM, MISO & SPP since 2018 (ISO State of Market reports)
$18.9B
ARR auction credits returned to consumers — $1.31/MWh (61% of charges)
$22.4B
If all utilities self-scheduled FTRs to capture DA value — $1.55/MWh (73% of charges)
$26.0B
RT settlement value — $1.80/MWh (84% of charges). No product exists to capture this today.
$48.2B
LOC: higher of DA or RT each hour — $3.34/MWh. The ceiling an RT Congestion Hedge achieves.
$29.3B
Additional credits beyond today's ARR auctions — the value an RT Congestion Hedge unlocks.

A walkthrough of total congestion charges and credit performance across PJM, MISO, and SPP

Market Deep Dive

Each market has different credit dynamics — but the pattern is the same: current tools leave significant value on the table, and an RT Congestion Hedge closes the gap.

Issue 1: Credit Gap

How much congestion is charged vs. how much is returned through existing credit tools.

Congestion Charges
$11.9B
2025: $3.2B — record year
ARR Auction Credits
$8.0B
$1.16/MWh — 67% of charges
Self-Schedule Rate
26%
DA value is 34% higher than auction — most value left on table of any market
LOC Value
$21.5B
$3.10/MWh — 2.7× auction rate
Issue 2: Renewable Congestion

RT congestion driven by wind and solar generation — largely unhedged because ARR paths don't cover these sources.

PJM — Solar Driven
$257MSolar RT congestion (Jan 2023 – Jan 2026)

PJM's renewable congestion story is solar — the Virginia and North Carolina buildout is creating RT congestion at $10–13/MWh across hundreds of generators. No ARR paths exist for these sources. This congestion is largely unhedged and flows directly to consumers.

Sources: Congestion charges from ISO State of Market reports. Credit and renewable data from XO Energy ARR analysis platform, 8 planning years (Jun 2018 – Jan 2026).

This Problem Is Accelerating — Renewables Are the Driver

The ISOs' own Independent Market Monitors and FERC's infrastructure data tell the same story: renewable generation is the fastest-growing source of congestion, and the existing credit framework wasn't designed for it. As the generation mix continues to shift, these patterns will only intensify — and without real-time hedging tools, consumers absorb the growing cost.

MISO — Potomac Economics (IMM)

2024 State of the Market

Wind output now contributes approximately 40% of MISO's real-time congestion — up from 35% in 2019. Wind forecast errors averaged 14% on a 2-hour-ahead basis (up from 8% in 2023), widening the gap between day-ahead and real-time prices. This forecast divergence is exactly what an RT Congestion Hedge addresses.

Avg Hourly Curtailment
242 MW → 607 MW
+150%
Peak Curtailment
2.5 GW → 6.2 GW
+148%
Wind % of RT Congestion
35% → 40–44%

Source: Potomac Economics, 2024 MISO State of the Market Report (2019–2024 data).

SPP — Market Monitoring Unit

2024 State of the Market

Wind now accounts for 38% of total SPP generation. Congestion drives 92% of all price variation — the highest since the market launched in 2014. Wind curtailments have increased 10× in five years (137 MW/hr in 2019 to 1,483 MW/hr in 2024). The MMU describes the dominant congestion pattern as running along the boundary between renewable generation and load.

Source: SPP MMU, 2024 State of the Market Report (May 2025).

FERC — Renewable Capacity Pipeline

2025 Energy Infrastructure Update

Renewables accounted for 88% of all new generating capacity added in 2025. Solar alone was 73% of new additions — leading for 28 consecutive months. The 2026–2028 pipeline projects 35 GW/year of new wind and solar. Every megawatt of new renewable capacity creates congestion at nodes the existing ARR framework doesn't cover.

Source: FERC Energy Infrastructure Update, 2025 full year (April 2026).

This Problem Has Been Documented for Over a Decade

Independent market monitors, state commissions, and academic experts have identified this gap — and proposed solutions — since 2013. MISO's IMM has recommended a virtual spread product in every State of the Market report. SPP approved a product (SIR34) through its stakeholder process but implementation stalled. PJM once had a functioning product — Up-To Congestion transactions — that has since been scaled back dramatically through limited trading nodes and fees which create a significant hurdle rate.

How PJM's real-time congestion product was scaled back — and what it cost consumers

NYISO — New York

Data Coming Soon

~20 million consumers. NYISO's own Market Issues Working Group proposed a Locational Virtual Transaction (LVT) product in April 2016. An IEEE academic study validated the design in 2017. Despite proven need and a validated design, NYISO abandoned the product with no current initiative to revisit.

What we know:
• TCC (Transmission Congestion Contract) funding analysis underway
• RT congestion from offshore wind and downstate load patterns being compiled
• Section 206 complaint to follow PJM/MISO/SPP lead filing
📊 TCC funding data, RT congestion charges, and renewable exposure analysis will be published here when complete.

CAISO — California

Data Coming Soon

~40 million consumers. Three companies filed formal Point-to-Point Convergence Bid comments over three consecutive years (2015–2017). CAISO's LAP-level design structurally precludes nodal congestion hedging. The DMM documented $900M in CRR auction ratepayer losses from 2012 to 2018.

What we know:
• CRR funding analysis and LAP-level hedging gap quantification underway
• Solar curtailment and RT congestion from behind-the-meter growth being compiled
• Section 206 complaint to follow PJM/MISO/SPP lead filing
📊 CRR funding data, RT congestion charges, and renewable exposure analysis will be published here when complete.

A Proven Solution

This isn't theoretical. One U.S. market already does this — and it works. We're asking FERC to bring that same protection to every electricity consumer in America.

Texas proves the two-layer congestion hedging model works — we're asking FERC to bring it everywhere

Why It Works

The Core Benefit

$29.3 Billion in Additional Credits

Today's ARR auctions return $18.9B against $30.8B in total congestion charges. An RT Congestion Hedge captures value at every settlement tier — DA, RT, and LOC — unlocking up to $48.2B in total credits. The additional $29.3B flows back to consumers through the same cost-recovery process already in place.

Price Formation

DA-RT Convergence

When participants can trade the DA-RT spread, it incentivizes better price formation in both markets. Day-ahead prices converge toward real-time, which makes existing ARR and FTR credits more valuable — even without changing the ARR framework itself. Everyone wins when prices are more accurate.

Renewables

Renewable Congestion Management

$5.5B in renewable RT congestion since 2023 — and no product exists to manage it. Wind and solar generators underbid in DA due to forecast uncertainty, creating RT congestion that legacy ARR paths can't cover. An RT Congestion Hedge at full nodal granularity gives the market the first tool to manage this growing exposure.

Track Record

Proven in ERCOT

Texas already operates this model. ERCOT's Point-to-Point Obligation product settles at full nodal granularity in real-time, is open to all market participants, supports legitimate hedging across all market sectors, and has a fee structure that incentivizes convergence.

What We're Asking FERC To Do

Existing congestion revenue crediting mechanisms are unjust and unreasonable because they systematically fail to return real-time congestion value to the consumers who fund the transmission grid. The Affordable Grid Coalition is filing Section 206 complaints at FERC against each ISO/RTO to direct implementation of an RT congestion settlement tier — modeled on ERCOT's proven design.

🎯

Real-Time Settlement

Products that settle against actual congestion — not just day-ahead forecasts.

📍

Full Nodal Granularity

Hedging at all available prompt month auction paths — so utilities, generators, and large loads can manage their actual congestion exposure.

🔓

Open Access

Supporting legitimate hedging and convergence activity across all market sectors. Competition increases efficiency.

⚖️

Fee Structure That Works

A fee structure that incentivizes convergence and supports active participation — modeled on ERCOT's proven design.

🛡️

Market Integrity

Rules that protect market integrity while preserving the product's ability to deliver consumer benefits.

📋

FERC Section 206

Directing ISOs to implement real-time congestion hedging tools through FERC's existing authority under the Federal Power Act.

Markets Affected

Lead filings in April 2026 against PJM, MISO, and SPP. Follow-on complaints against NYISO and CAISO once data analysis is complete.

PJM
April 2026
13 states + DC
UTC destroyed; 80% volume collapse
MISO
April 2026
15 states
IMM recommended since 2013
SPP
April 2026
14 states
SIR34 approved but stalled
NYISO
Coming Soon
New York
LVT proposed 2016; abandoned
CAISO
Coming Soon
California
PtP bids requested since 2015

Who's Affected

This issue touches every corner of the electricity system. Select your role below to see how the congestion hedging gap affects you.

🏠
Consumers

You're paying billions for a problem that has a proven fix.

Every time electricity gets congested on the transmission grid, the extra cost shows up in your electric bill. Today, there's no tool to manage the gap between forecast and reality. That gap means consumers across PJM, MISO, and SPP alone missed out on $7.1 billion in congestion revenue over 8 planning years — with NYISO and CAISO data still being compiled.

Think of it this way: imagine if your car insurance only covered accidents predicted the night before. Any accident they didn't forecast? That's on you. That's how electricity congestion works today.

The solution already works in Texas, which consistently achieves full congestion revenue return to consumers. We're asking for the same protection in every U.S. electricity market.

The Section 206 Complaint Is Filing in April 2026. Add Your Voice.

We are filing formal complaints at FERC asking that PJM, MISO, SPP, NYISO, and CAISO implement real-time congestion hedging tools. State commissions, consumer advocates, and market participants can sign on as co-complainants or supporting parties. The filing deadline is imminent.

30 seconds on why your voice matters — sign onto the Section 206 complaint today

📊

See What Your State Could Gain

Select your state to see how much more an RT Congestion Hedge could return to your consumers — and download a customized brief with charts, data, and recommended actions for your state commission.

Pennsylvania
Virginia
West Virginia
Illinois
Ohio
Delaware
Maryland
New Jersey
Michigan
Indiana
North Carolina
Kentucky
Tennessee
District of Columbia
⚖️

Sign Onto the Section 206 Complaint

The Affordable Grid Coalition is filing Section 206 complaints at FERC against PJM, MISO, SPP, NYISO, and CAISO alleging the absence of real-time congestion hedging products is unjust, unreasonable, and unduly discriminatory to consumers.

Organizations that sign on will be named as supporting parties in the complaint filing. This is a stronger level of commitment than the general coalition — your organization is formally supporting the legal action at FERC.

Who should sign on?
Market ParticipantsConsumer Advocacy OrgsState Attorneys GeneralTrade AssociationsMunicipal UtilitiesElectric CooperativesRenewable DevelopersData Centers & Large LoadsState PUC CommissionersAcademic Institutions
Organization Information

Questions about the complaint or what signing on entails? Contact General Counsel at legal@affordablegrid.org

✍️

Join the Coalition

Sign our general support letter to show you stand with the movement for real-time congestion hedging. Open to individuals, organizations, and anyone who believes electricity markets should work for consumers. Organizations wanting to formally sign onto the FERC complaint can do so below.

📧
Email us directly
info@affordablegrid.org
Why contact regulators?

State PUC commissioners oversee the utilities that pass congestion costs to you. Attorneys General can investigate consumer protection failures. Both can file supporting comments at FERC. Use the lookup tools below to find your state contacts.

How the Federal Power Act gives you the right to challenge broken electricity market rules at FERC

Five concrete actions PUC commissioners and Attorneys General can take right now

🏛️

Find Your State PUC Commissioners

Select your state to see commissioners and contact information

🔍

Find Your Attorney General & Consumer Advocates

Select your state to see AG offices and consumer advocacy organizations

📄 Download Educational Materials

Share these resources with colleagues, regulators, and community members.

Executive One-Pager
PDF
Single-page brief for decision-makers — the problem, scale, and ask
Download →
Consumer Fact Sheet
PDF
Plain-language overview with key stats and actions
Download →
PUC Commissioner Brief
PDF
Credit side, charge side, riders, and recommended actions
Download →
ISO-by-ISO Data Summary
PDF
Market-by-market funding gaps and renewable exposure
Download →
Section 206 Overview
PDF
Legal framework, four-part argument, and prescriptive remedy
Download →
ERCOT Model Brief
PDF
How Texas achieves consistently full CRR funding
Download →
Coalition Support Letter
DOCX
Editable template letter for organizations
Download →
LEI Report: PJM ARR/FTR Review
EXT
London Economics — $523M–$1.2B/yr consumer benefits from FTR markets
Open External →
LEI Report: MISO ARR/FTR Evaluation
EXT
London Economics — Independent evaluation of MISO's ARR/FTR construct
Open External →

Glossary of Terms

Plain-language definitions of the energy market terms used throughout this site.

Congestion

When too much electricity tries to flow through a bottleneck on the transmission grid, prices increase at that location. The extra cost is called congestion. Think of it like a toll that increases during rush hour.

ARR (Auction Revenue Right)

A financial credit allocated to utilities based on their historical use of the transmission grid. ARRs give utilities the revenue from FTR auctions, which partially offsets congestion costs. Think of it as a rebate check based on last year's toll road usage.

FTR (Financial Transmission Right)

A financial contract that pays the holder based on the difference in day-ahead electricity prices between two points on the grid. Utilities can convert their ARRs into FTRs to potentially earn more, but they take on risk.

Self-Scheduling

When a utility converts its free ARR allocation into an FTR. Instead of receiving the auction clearing price, the utility receives the day-ahead congestion value — which may be higher or lower.

Day-Ahead (DA) Market

The electricity market that runs one day before real-time delivery. Generators and utilities submit bids and offers, and prices are set for each hour of the next day. It's like booking a hotel room in advance.

Real-Time (RT) Market

The electricity market that runs in real-time (every 5 minutes). Prices reflect actual grid conditions. It's like the walk-in rate at a hotel — often different from what you booked.

LOC (Lost Opportunity Cost)

The higher of the day-ahead or real-time congestion value for each hour. This represents what a perfect hedging tool would capture — always picking the best price. It's the theoretical maximum.

Real-Time (RT) Congestion Hedge

A product that allows market participants to manage the difference between day-ahead and real-time congestion. Different markets use different names: Point-to-Point Obligation (ERCOT), Up-To Congestion/UTC (PJM), Spread Bid (MISO proposal), RT Congestion Hedge (SPP proposal), and Linked Virtual Transaction/LVT (NYISO proposal). ERCOT's version is the only one fully operational today.

Fuel Adjustment Clause (FAC)

A state-regulated mechanism that allows utilities to pass through fuel and purchased power costs (including congestion charges) to ratepayers, usually without a full rate case. Different states call it different things: FAC, PSCR, FCA, EAC, Rider HSS.

Section 206 Complaint

A legal mechanism under the Federal Power Act that allows any party to ask FERC to investigate whether existing rates, charges, or practices are unjust, unreasonable, or unduly discriminatory. Our complaint: existing congestion revenue crediting mechanisms systematically fail to return real-time congestion value to the consumers who fund the transmission grid. If FERC agrees, the ISO must implement a remedy.

ISO (Independent System Operator)

The entity that operates the electric grid and runs the wholesale electricity market for a region. PJM, MISO, SPP, ERCOT, NYISO, and CAISO are the major U.S. ISOs.

IMM (Independent Market Monitor)

A third-party watchdog appointed to monitor each ISO's markets for fairness and efficiency. The IMM publishes annual State of the Market reports with findings and recommendations.

Frequently Asked Questions

Common questions about the coalition, the complaint, and real-time congestion hedging.

Who is behind the Affordable Grid Coalition?
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How does an RT Congestion Hedge benefit consumers?
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Why hasn't this been implemented already?
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What happens if I sign on to the Section 206 complaint?
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Does this require new legislation?
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How does this affect renewable energy development?
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What about the $29.3 billion figure — is that real money consumers lost?
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What is ERCOT doing differently?
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How do congestion costs end up on my electric bill?
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What is DA-RT convergence and why does it matter?
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Is this the same as virtual trading?
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