On March 10, 2022, Maine Power Link, LLC (MPL) submitted a request for Commission authorization to charge negotiated rates for transmission rights on its proposed transmission project (Project) if the Maine Public Utilities Commission (Maine Commission) selects the Project through a request for proposals (RFP) for both renewable energy projects in northern Maine and a 345 kV transmission line to connect the projects to the ISO New England Inc. (ISO-NE) transmission system in southern Maine (Northern Maine RFP). FERC denied the request for negotiated rate authority because MPL did not shown that it has assumed the full market risk for the Project. In evaluating negotiated rate applications, FERC employs a four-step analysis, as outlined in Chinook, to examine: (1) the justness and reasonableness of the rates; (2) the potential for undue discrimination; (3) the potential for undue preference, including affiliate preference; and (4) regional reliability and operational efficiency requirements. This approach, which was further developed in the 2013 Policy Statement, simultaneously acknowledges the financing realities faced by merchant transmission developers, the mandates of the FPA, and the Commission’s open access requirements. Moreover, this approach allows the Commission to use a consistent framework to evaluate requests for negotiated rate authority from a wide range of merchant transmission projects that can differ from one project to the next.