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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

The math is simple: utilities currently return $20.1 billion through existing congestion credits to offset $30.8 billion in charges. The difference — $10.7 billion — is paid directly by consumers, an average gap of $1.3 billion per year. Additional credits exist to help offset increasingly large congestion charges, however no products exist to capture them.

The Simple Version

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 65% of total congestion charges. An RT Congestion Hedge captures value that current tools miss — growing the total credit pool and narrowing the $10.7 billion gap.

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.

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:

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.

Congestion Credits by the Numbers

Credit tiers: XO Energy ARR credit analysis, planning years 2018-19 through 2025-26 (complete). Charges: ISO State of Market reports, calendar years 2018–2025. Maximum Available Value is a ceiling — the most an optimal hedge could capture, not a damages figure.

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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

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.

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.

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 2012. MISO's IMM has recommended a virtual spread product in fourteen consecutive State of the Market reports. 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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

$31.9 Billion in Additional Credits

Today's ARR auctions return $20.1B against $30.8B in total congestion charges. An RT Congestion Hedge captures value at every settlement tier — up to the Maximum Available Value ceiling of $52.0B. Up to $31.9B in additional credits could flow back to consumers through the same cost-recovery process already in place.

Texas Utilities Already Vote With Their Money

This isn't a theoretical product. ERCOT runs the complete chain today — annual CRR auction → monthly auction → day-ahead PTP → real-time settlement — with zero fees, no bid caps, and ~full funding. And it's not financial traders driving it: Texas's own utilities, municipals, and co-ops are the heaviest users, running one hedge program from years-ahead auctions all the way to real-time delivery.

The instrument held up when it mattered most: through Winter Storm Uri — the worst power crisis in modern U.S. history — ERCOT's congestion hedges paid the full real-time spread, uncapped, and the CRR market stayed fully funded (its last short payment was November 2020; deration since runs ~1%). PJM's product, by contrast, can't even be submitted when expected congestion exceeds its $50/MWh bid cap — the hedge is amputated at exactly the moments it's needed most.

The jurisdictional irony: ERCOT is the one U.S. market outside FERC's Federal Power Act jurisdiction — and it's the one that got congestion hedging right. FERC doesn't need to invent anything. It needs to direct the markets it does regulate to match what Texas already proves works.

Source: XO Energy analysis of ERCOT CRR auction results, 60-day DAM disclosure, and settlement prices, Jan 2018 – Apr 2026; ERCOT and PJM State of Market reports; ERCOT Nodal Protocols; FERC dockets EL14-37 and ER18-88.

Markets Affected

Lead filings in September 2026 against PJM, MISO, and SPP. The NYISO follow-on complaint is drafted; CAISO follows once data analysis is complete.

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 left up to $31.9 billion in congestion credits unrealized across PJM, MISO, and SPP over 8 planning years — including at least $8.2 billion of settled real-time value no election available today can reach — and New York's numbers are now in too, with another $4.0 billion unrealized there — beyond the reach of any TCC election.

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, whose congestion-hedge market has run near-fully funded for years. We're asking for the same protection in every U.S. electricity market.

Congestion costs are embedded in every retail electric bill through automatic cost-recovery riders. Utilities have zero financial exposure. The cost of not having real-time hedging: at least $8.2 billion of settled real-time value beyond today's credits across PJM, MISO, and SPP over 8 planning years — plus $4.0 billion unrealized in NYISO, with CAISO analysis underway. When measured against what optimal real-time hedging tools could have captured, the total value left on the table reaches $31.9 billion.

We are filing Section 206 complaints at FERC. Consumer advocates can amplify this by filing supporting comments, issuing public statements, and educating state regulators about how these hidden costs affect their communities.

Every state provides utilities with automatic cost-tracking riders that guarantee full recovery of wholesale market charges. OPSI's Resolution FTR-2016-4 found only 45% of PJM congestion was returned to consumers — a $983 million shortfall in one year.

The utilities subject to your oversight bear zero financial risk from congestion. State commissions can take action by filing comments supporting the Section 206 complaints, examining whether cost-tracking riders should credit customers for hedging savings, and directing utilities to report on congestion cost exposure.

Electricity congestion charges are buried in complex wholesale settlements and passed to retail customers via automatic mechanisms. No consumer-facing disclosure, no opt-out, no recourse. The cost of not having real-time hedging tools reaches at least $8.2 billion of settled real-time value across PJM, MISO, and SPP over 8 planning years (plus $4.0 billion unrealized in NYISO; CAISO forthcoming), with up to $31.9 billion in total value left on the table.

AGs can support consumer protection by investigating whether utilities meet prudent cost management obligations, filing amicus briefs at FERC, and advocating for transparency in how congestion costs are passed through.

Organizations like EPSA and EEI represent companies directly affected by the absence of RT congestion hedging. MISO's IMM has recommended a spread product since 2012 — fourteen consecutive years. SPP approved one but implementation stalled. PJM's UTC has been scaled back significantly. NYISO and CAISO proposals were abandoned.

An RT Congestion Hedge benefits all market sectors — financial and physical participants alike. Trade organizations can support by endorsing the Section 206 filings, mobilizing members to file FERC comments, and educating policymakers on the consumer and market efficiency benefits.

State advocates participate in ISO governance through OPSI, OMS, and the RSC. These bodies have identified congestion hedging shortfalls as priorities — OPSI documented $1.5B over two years; SPP's RSC flagged 83% TCR funding vs 90% target.

Despite these documented concerns, implementation has not followed. State representatives can reaffirm prior resolutions, file coordinated FERC comments supporting the Section 206 complaints, and engage ISO management on prioritizing real-time congestion hedging tools.

Independent Market Monitors have recommended RT congestion hedging products for over a decade. MISO's IMM has recommended a spread product since 2012 — fourteen consecutive years. SPP approved one through its stakeholder process but implementation stalled. PJM's UTC product has been scaled back dramatically through limited trading nodes and fees which create a significant hurdle rate. NYISO and CAISO proposals were abandoned.

ISO State of Market reports document $30.8B in congestion charges against $20.1B in credits returned. The RT value alone — $8.2B beyond current tools — represents documented consumer harm. ERCOT demonstrates the remedy works. The Commission has authority under Section 206 to direct implementation and be prescriptive about settlement, fees, and market rules.

Since January 2023, renewable generators have faced over $6.5 billion in real-time congestion across SPP, MISO, and PJM. This exposure is largely unhedged because legacy ARR paths don't cover these sources. The problem varies dramatically by region and fuel type.

In SPP, wind is the story: Oklahoma wind generators alone face $2.5 billion in RT congestion at ~$18/MWh. SPP does allocate ARRs to wind sources, but only on a fractional portion of output — the credit offset pales in comparison to the actual exposure.

In MISO, wind drives $2.0 billion in RT congestion across Minnesota, Iowa, and the Dakotas, with rates ranging from $5–12/MWh depending on transmission access.

In PJM, solar is the growing story: the Virginia/North Carolina buildout faces $13–17/MWh in RT congestion. As interconnection queues add tens of GW of new solar, this exposure will compound.

An RT Congestion Hedge at full nodal granularity would give renewable developers the ability to manage actual exposure for the first time — improving project economics, reducing financing costs, and supporting the clean energy transition.

Northern Virginia hosts the world's largest data center concentration — and these facilities can't hedge nodal congestion under current rules. PJM's legacy tools are restricted to aggregated load zones.

As AI and cloud computing drive unprecedented load growth, real-time congestion hedging with full nodal settlement would let data centers manage their actual costs instead of socializing them across all ratepayers in their zone.

Unlike IOUs, munis and coops don't have automatic cost-recovery mechanisms. Congestion cost spikes hit your balance sheet and customers directly. ERCOT's municipal and cooperative participants already benefit from these tools.

Munis and coops can support by signing the coalition letter, filing FERC comments describing community impact, and engaging state representatives at ISO governance bodies.

Source: ARR credit analysis, Jun 2018 – May 2026 (8 complete planning years), source-state allocation. "Additional credits" = Maximum Available Value minus what current auctions return. Per-household figures divide the state's total additional credits — all customer classes, since commercial and industrial congestion costs also reach households through the prices of goods and services — by its residential electricity accounts (EIA-861, 2024), cumulative over the 8 planning years. For states only partially inside a market, the per-affected-household figure is higher.

Your state's numbers make the case. Now put them to work.

Send your state's brief to your PUC commissioners, or add your organization's voice to the Section 206 complaint at FERC. The Take Action page has contact lookup for every state and the sign-on form.

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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

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

These explainer videos were produced in spring 2026, before our final figures were confirmed. A few on-screen numbers are early estimates — the current, certified figures are the ones shown on this page.

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.

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.

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.

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.

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.

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.

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, and always a ceiling — never a damages figure. (Earlier materials called this Lost Opportunity Cost, or LOC.)

A product that allows market participants to manage the difference between day-ahead and real-time congestion. The Coalition's FERC complaints formally title it the Day-Ahead Transmission Right (DATR): bid in the day-ahead market, settled against real-time congestion. Different markets have used 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.

The price at which a congestion instrument pays out. Today's credits settle at either the auction clearing price (the default) or day-ahead congestion prices (if converted to an FTR). No tier settles at real-time prices in PJM, MISO, SPP, or NYISO — that missing third tier is what the Coalition's complaints ask FERC to create.

A specific location on the grid where prices are calculated — a generator, substation, or delivery point. There are thousands of nodes in each market. 'Nodal granularity' means being able to hedge congestion at the specific locations where it actually occurs, rather than only at broad zone averages.

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.

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.

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.

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.