North American Power & Utilities: Watt’s Happening in Transmission ROEs?

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North American Power & Utilities: Watt’s Happening in Transmission ROEs?

BofAS Analyst

The MISO ROE decision appears to create limited incremental financial exposure for the +1david.rold@bofa.com646 556 1118

named utilities, with any impact largely tied to previously ordered refund mechanics

rather than a new prospective earnings reset. The court left FERC’s existing 9.98% ROE

and refund framework in place but did not quantify company-by-company liabilities; FERC: Federal Energy Regulatory

initial company feedback has generally been consistent with that view, indicating that Commission

reviews are ongoing but that any financial impact is expected to be limited, with refund

MISO: Midwest Independent Systemexposure either already contemplated or likely modest relative to the broader utility rate

Operatorbase.

ROE: Return on Equity

NETO case had a similar outcome, heading to court next

This decision is relevant for the NETO case because it supports FERC’s ability to order LPSC: Louisiana Public Service

ROE refunds beyond the ordinary 15-month S.206 refund window when the agency is Commission

correcting its own prior legal error after a court remand. While the D.C. Circuit did not

NETO: New England Transmissionaddress the New England Transmission Owners proceeding directly, its reasoning in the

OwnersMISO ROE case is potentially important to NETO because FERC’s March 2026 NETO

order similarly set a lower base ROE, at 9.57%, and ordered refunds with interest,

including a backdated period tied to the long-running remand posture of that case.

NETO refund argument may have different legal basis

NETO may present a different fact pattern, because FERC’s Oct. 2014 order setting the

prior ROE was later vacated. That could give parties room to argue that FERC’s roughly