From House Select Committee on the Climate Crisis:

Stakeholders, such as states, consumer groups, and public interest groups, have expressed concern about the power of incumbent generators and transmission owners because they often have greater resources than new entrants, they tend to have ongoing relationships with RTO and ISO staff, and some market rules limit participation to those with existing assets.156

156 Mark James et al, How the RTO Stakeholder Process Affects Market Efficiency (R Street Institute, 2017)

Incumbent generators and transmission owners also always have the ability to threaten withdrawal.157

157 Travis Kavulla, Problems in Electricity Market Governance: An Assessment (R Street Institute, 2019).

Without ongoing oversight, when existing rules create a power imbalance for incumbents, they may be able to avoid changes to the rules that would disadvantage them.160

160 Mark James et al, How the RTO Stakeholder Process Affects Market Efficiency (R Street Institute, 2017).

Moreover, stakeholders have expressed concerns that RTO and ISO staff are advancing proposals that are not in the public interest because they do not prioritize consumer interests and overall market efficiency, but may be unduly influenced by incumbents.162

162 Mark James et al, How the RTO Stakeholder Process Affects Market Efficiency (R Street Institute, 2017); Travis Kavulla, Problems in Electricity Market Governance: An Assessment (R Street Institute, 2019).

They have also expressed concerns that FERC is too deferential to proposals from RTOs and ISOs.163

163 Mark James et al, How the RTO Stakeholder Process Affects Market Efficiency (R Street Institute, 2017).