Thread by @AriPeskoe

October 2 is the deadline for responses to FERC’s 6/29 order on PJM’s capacity construct. Starting a thread to track the filings. . . .

In that order, FERC “preliminarily” found that excluding resources paid for their environmental benefits (MOPR) and allowing equivalent load to meet capacity needs outside of the construct (FRR-Alternative) “may produce a just and reasonable rate.” elibrary.ferc.gov/idmws/file_lis…

Notoriously litigious Allco Renewables is first to file! Allco develops solar-powered Qualifying Facilities (QF) under PURPA. It has filed these cases in fed ct statepowerproject.org/california/#CA…; statepowerproject.org/connecticut/; statepowerproject.org/massachusetts/…, and initiated numerous proceedings at FERC.

Allco says QFs have an absolute right to sell in the PJM capacity construct and cannot be MOPRd out or forced to participate through an FRR. “Making QFs subject to a MOPR or an FRR Alternative impermissibly interferes with a QF’s right to sell energy and capacity under PURPA.”

Allco attacks non-QF state-supported resources, arguing they should be excluded from the energy market because they harm QFs. There is a near zero chance FERC agrees. elibrary.ferc.gov/idmws/file_lis…

Eastern Generation, owner of 3GW of natural gas in PJM, says "the failure to capture the cost of carbon in power prices is a serious market inefficiency and
creates significant and unproductive tensions with state policy initiatives"
elibrary.ferc.gov/idmws/file_lis…

Eastern supports a broad "Clean MOPR" and a FERC order initiating a stakeholder process to develop a carbon price.

Consumer advocates, enviros, Exelon, others file "shared principles" for a resource-specific FRR - "FRR-RS must be sufficiently flexible to allow states to pursue their valid policy goals and also must allow for a smooth transition..." elibrary.ferc.gov/idmws/file_lis…

American Coalition for "Clean Coal" (quote marks are mine) and National Mining Association advocate for a Fuel Secure Capacity market for resources with on-site fuel supplies. elibrary-backup.ferc.gov/idmws/file_lis…

P3 (generator group): "the unit specific FRR exacerbates the problem and provides an easy path forward for additional subsidization and the resultant price suppression;" wants a "Clean MOPR" p3powergroup.com/siteFiles/News…

P3: under an FRR-RS "the clearing price is the same when the subsidized unit
bids at zero as when the subsidized unit is removed from the auction via FRR-RS. The very result FERC seeks to avoid (price suppression from subsidization)
remains"

P3's proposed Clean MOPR would not include any exception for self-supply, public power or vertically integrated utilities. Also P3: "this proceeding will likely determine whether PJM is going to remain a beacon of hope for competitive markets"

Clean Energy Advocates file a brief on the MOPR includes accessible discussion of why selectively MOPRing state clean energy policies while ignoring other subsidies (such as retail rate recovery of generation) "defies basic economic principles" dropbox.com/s/ztf6d4f8evv5…

Clean Energy Advocates: REC sales are "payments for co-products of electricity whose value has been determined in private transactions" and FERC mitigation would "regulate the terms of the sale of a non-jurisdictional product and grossly overstep its role under the FPA."

Clean Energy Advocates and Consumer Advocates made a separate filing on the FRR-RS that emphasizes flexibility to allow states to shape it to meet their policies and avoid over-procurement dropbox.com/s/o9biotoes1hj…

EPSA supports an expansive MOPR and argues that an FRR for state-supported resources would "exacerbate, not ameliorate, the price suppression problem" and FERC should therefore abandon it epsa.org/wp-content/upl…

"In EPSA’s view, ensuring that states bear the costs of their decisions in this area [by paying twice for capacity - once through state policies and a second time through PJM] should be regarded as a benefit of a MOPR."

Ooof. EPSA has a creative interpretation of its loss at the 7th Circuit. The court did not determine what FERC should do about ZECs. The court understood that FERC has legal authority and discretion to do something about ZECs.

EPSA also argues that FERC cannot mandate an FRR-RS bc it has not found "anything broken" in the tariff "that would be fixed by the FRR." FERC "has no authority to fashion rate remedies in the absence of a demonstrated rate problem."

EPSA goes for an obvious analogy - FERC's "discretion is not so broad as to empower the Commission to perform a nose job when it has diagnosed the ratemaking equivalent of a ruptured spleen."

FirstEnergy supports FERC's order and surprisingly wants the MOPR to include ratebased generation (its parent company owns vertically integrated utilities) and generally supports the FRR "shared principles" from clean energy groups and nukes (see above) elibrary.ferc.gov/idmws/file_lis…

Buckeye Power wants out of the PJM capacity construct: "The goal of the capacity market should be to serve the needs of LSEs (and indirectly their retail consumers), not for LSEs to serve the needs of the market or merchant generators." elibrary.ferc.gov/idmws/file_lis…

Buckeye goes farther than PJM's order, requesting that LSEs "be permitted to participate in the PJM capacity markets on a voluntary, residual basis" and that the new FRR option be available to all resources, not just those receiving "actionable subsidies."

NRECA (cooperatives' trade group) similarly seeks self-supply options and urges FERC to "reverse course and return the RPM capacity construct to its original function as a residual, “last resort” mechanism elibrary.ferc.gov/idmws/file_lis…

NRECA: "there is nothing magic about revenues received from the centralized capacity construct which makes them more legitimate than revenues received through bilateral contracts for resources procured outside of those constructs."

NRECA: "prices yielded by RPM do not fully reflect the complete set of [buyer] preferences and RPM thus is incapable of signaling for the types of resources that optimally satisfy all buyers’ references, particularly the desire for diversity, environmental and health benefits..."

API supports the Clean MOPR + FRR and while endorsing FERC's 6/29 order says that FERC "must ensure that it has a full understanding of the out-of-market payments...and their impact on the PJM wholesale market." FERC's 6/29 order lacks that info. Confusing elibrary.ferc.gov/idmws/file_lis…

API includes this confusing comparison

AMP: FERC's order calls for "a sweeping and fundamental change [to the PJM capacity construct] whose magnitude eclipses the 28 prior major rule changes." Great to see that someone is keeping score! elibrary.ferc.gov/idmws/file_lis…

AMP: "Public Power entities with capacity resources, including bilateral contracts or generating assets, for the purpose of self-supply do not receive material subsidies that the Commission may or should mitigate by application of the MOPR."

AMP tries to argue that Public Power is special.

AMP more relevantly argues that "the Public Power business model precludes the opportunity to economically benefit from artificially lowering the clearing price."

APPA makes similar arguments - elibrary.ferc.gov/idmws/file_lis…

Avangrid explains why PJM's proposal does not align with how REC markets actually function and recommends that FERC "allow an exemption for, or define Actionable Subsidy in a way to exclude, any competitively procured out-of-market resources" - elibrary.ferc.gov/idmws/file_lis…

Tesla argues that energy limited resources (aka batteries) cannot sell in the capacity construct due to capacity performance rules and explains how FRR can accommodate state storage policies (maybe outside the scope of this docket, but doesnt hurt to try) elibrary.ferc.gov/idmws/file_lis…

ELCON: Not all subsidies are equal. "Investors adjust their expectations to predictable, long-term programmatic subsidies that give eligible resources an opportunity to compete to receive program payments (e.g., renewable portfolio standards)...."

ELCON (cont) "These permit political preferences to distort efficient market outcomes but keep competitive forces as the ultimate determinants of resource entry and exit."

ELCON: Actionable subsidies should be limited to "government-backed contractual guarantee for the operation of specific resources...which fundamentally contradicts the ability of competitive forces to determine resource entry and exit." elibrary.ferc.gov/idmws/file_lis…

ELCON: "the legitimate market for capacity is bigger than PJM...private capital that pursues voluntary capacity contracts in bilateral markets should not face administrative corrections."

ELCON - soon to be under new leadership elcon.org/devin-hartman-… - very critical of a Clean MOPR; interesting filing

Exelon: Until FERC "is ready to approve carbon pricing so that state clean energy policies are integrated into wholesale energy market prices, FERC must at the very least adopt market rules with the flexibility to accommodate state policy initiatives." elibrary.ferc.gov/idmws/file_lis…

Exelon: FERC "should express its willingness to entertain a Section 205 filing from PJM incorporating carbon pricing."

Exelon actually includes red-lines to the PJM Tariff to implement its proposed FRR option. If you're interested in a deep dive on the FRR...

Exelon argues that all state subsidies, including ratebasing generation and economic development incentives, should be considered Actionable Subsidies and therefore subject a resource to the MOPR

OPSI: "the relative magnitude of the price impacts show that a MOPR without accommodation would create outcomes substantially more unjust and unreasonable than any alleged price suppression." elibrary.ferc.gov/idmws/file_lis…

OPSI critical of PJM's calculation of Net CONE: "Notwithstanding CC’s place as the actual competitive entrant in PJM, only one stakeholder has brought forth a proposal using the CC as the reference unit for purposes of calculating Net CONE."

OPSI therefore concludes that "any use of Net CONE as the MOPR level does not provide an accurate measure of a competitive price in PJM’s markets, and would therefore fail to produce a just and reasonable rate."

Ohio Consumers' Counsel argues that FRR should apply to the energy market too. elibrary.ferc.gov/idmws/file_lis…

OCC: FERC should at least require PJM to call first on all energy offers available from power plants participating in the RPM capacity auctions before calling on energy produced from the subsidized power plants." 🤔

Ironically, CPV - the company that would have benefited from the Maryland program preempted by Hughes - supports a Clean MOPR and no FRR elibrary.ferc.gov/idmws/file_lis…

PUCO: Resource electing to use FRR should be required to get state approval due to "far-reaching impacts that such a decision will have on the retail electricity market" elibrary.ferc.gov/idmws/file_lis…

PUCO notes "heavy administrative burden" of matching load to resources; warns that default customers may be further incented to shop when faced with a bypassable surcharge to support an FRR Alternative unit, leaving fewer customers to subsidize that resource."

RESA: Removing load from RPM "w/o customer consent is akin to 'slamming' these customers back to the incumbent utility and denying their ability to choose the electric product and supplier that best meets their individual needs." elibrary.ferc.gov/idmws/file_lis…

Phew. FirstEnergy Utilities (distinct from FE Solutions above) is very on-brand, arguing that PJM markets "continue to inadequately compensate fuel-secure baseload generators." elibrary-backup.ferc.gov/idmws/file_lis…

MD PSC says FRR is "unworkable;" argues that there is no alignment between environmental attributes sought by states (ie RECs) and specific resources elibrary-backup.ferc.gov/idmws/file_lis…

MD PSC proposes a "competitive carve-out auction" for REC-generating resources as an alternative to the FRR that would precede PJM's capacity auction.

PJM Industrials define Actionable Subsidy as government-mandated payments to resources; REC-generating resources would not be covered bc RPSs "do not involve state requirements for dollar transfers from electricity consumers to certain generators." elibrary-backup.ferc.gov/idmws/file_lis…

PJM Industrials are among the few commenters that engage with FRR design issues

AEE provides a primer on REC sales and numerous reasons why RECs should not be considered "Actionable Subsidies" elibrary.ferc.gov/idmws/file_lis…

I'd really like to wrap up this thread...but eLibrary appears to still not be fully up-to-date...

Direct Energy - In case you're curious how a competitive retailer thinks PJM should allocate RPM credits associted with FRR (or RCO) resources elibrary.ferc.gov/idmws/file_lis…

AES visits the MOPR Upside Down elibrary.ferc.gov/idmws/file_lis…

AES advocates for a "Proportional MOPR tailored to ensure that mitigation occurs in an economically rational fashion that distinguishes between resources that are fully subsidized versus resources that have access to limited out-of-market support and receive small subsidies"

"a Proportional MOPR that adjusts for each resource that receives out-of-market revenues to a level equal to the $/MW-day equivalent of the out-of-market revenues received." i.e. resource generating RECs that sell at $6, equals a $72/MW-day MOPR value

🚨🚨🚨
Citation to 19th Century Law Alert!
Calpine dangles the possibility that generators will ask FERC for stranded cost recovery if it doesn't ensure a competitive market by MOPRing everyone. Footnotes Smyth v. Ames! elibrary.ferc.gov/idmws/file_lis…

Dominion argues vertically integrated utilities should not be MOPRd. One of its two arguments applies to all state-sponsored resources:

NRG also raises stranded costs: "To the extent FERC elects to move away from competitive markets and towards a residual market that relies on state subsidies to drive new investment,FERC must, at a minimum...address the expectation interests of investors." elibrary.ferc.gov/idmws/file_lis…

Clean Energy Industries (AWEA+SEIA, others) go deep into an interesting legal argument - "MOPR should not apply to an exercise of Congress’s Taxing and Spending Power, including the PTC and ITC" elibrary.ferc.gov/idmws/file_lis…

Policy Integrity notes that coal ash sales could be considered "out-of-market" revenue but is ignored by MOPR advocates policyintegrity.org/documents/Poli…

Policy Integrity also argues that "well-designed state externality payment policies enhance market efficiency; mitigating them will detract from market efficiency"

Market Monitor (IMM) proposes the Sustainable Market Rule (see below). A "competitive offer in the capacity market is the marginal cost of capacity, or net ACR, regardless of whether the resource is planned or existing."

Illinois: "a net-ACR FRR Alternative cap that includes all revenues available to cover avoidable costs...assures that the [FRR] achieves both the goal of retaining state preferred resources and the requirement that rates are just and reasonable" elibrary.ferc.gov/idmws/file_lis…

AE Buyers Group: voluntary REC purchases "driven by the private market and private consumer decisions, and therefore do not fit FERC’s theory of harm in this Order, which states that out-of-market support provided by state policies ... suppress prices" elibrary.ferc.gov/idmws/file_lis…

PSE&G calls an expanded MOPR and FRR-RS "symbiotic structures," warning that a MOPR only would "shift reliance of all resources to capacity revenues and discourage, or at least undervalue efficiency in the energy market" elibrary.ferc.gov/idmws/file_lis…

PSE&G sketches out how the market should clear and says that "states need the flexibility to direct the credit back to load that comes from removing the policy resource from the auction clearing results"

Vistra proposes Capacity Performance with Sponsored Supply aka CAPSS, which they say "is based in part on," "builds off of," includes "the primary elements of," and is "similar to" ISO-NE's CASPR. elibrary.ferc.gov/idmws/file_lis…

PJM: "The first step to reconcile the challenge raised by a bifurcated market is to accept that a trade-off is inescapable," suggesting that PJM has already gone through the previous 4 stages of grief in prior filings and stakeholder processes. elibrary.ferc.gov/idmws/file_lis…

PJM: "The principal legal question here is: what terms and conditions must apply to a Resource Carve-Out option in order to assure, not merely that participation (market seller offers in the residual market) is competitive, but also that the outcome of that market remains J&R."

Here is how PJM defines Material Subsidy for MOPR/RCO purposes, but if the resource is owned or contracted by a self-supply entity and meets the net short and net long criteria MOPR/RCO does not apply:

PJM addresses how a federal bailout for coal and nukes would fit into the MOPR/RCO scheme. Resources would be subject to the MOPR but not be allowed to elect the RCO (PJM's term for the FRR-RS)

PJM proposes that seasonable resources would not be eligible for RCO bc "it would be challenging to determine an associated load" for a seasonal resources. A seasonal pair (winter-summer) could use the RCO.

PJM says "Extended RCO" should "ensure a reasonable connection bt clearing prices and resource compensation." RCO-X pays resources that are "crowded out" by RCO resources the difference between their offer and the clearing price. Here's PJM's explanation -

Duke+AEP: "some parties may try to argue" that retail riders in Ohio to support OVEC should be MOPRable, but the OVEC riders "do not have the effect of preventing the retirement of the OVEC units" and are "unrelated to wholesale market issues." elibrary.ferc.gov/idmws/file_lis…

Duke+AEP: Under the OVEC riders, "the PUCO simply allowed retail pass through of costs paid by the buyers under that agreement (or credits if applicable)....Such downstream retail rate mechanisms have no bearing on the generator’s continued operation."

A few observations after reading through most of the filings in the PJM capacity market docket. I’ll focus here on the two key aspects of FERC’s order – the MOPR and the FRR – and end with a list of new proposals I spotted...

1) The scope of the MOPR: fossil generators remain united in advocating for a broad MOPR that eliminates ZEC/REC generating resources from the market and would apply to vertically integrated utilities, public power and coops (self-supply). They call it a "Clean MOPR."

A handful of others are OK w a Clean MOPR but there's wide opposition. Clean energy/nukes remain opposed to any MOPR expansion but say that if FERC is going to do that it must include self-supply, basically daring FERC to go there. Munis+coops argue self-supply must be MOPR-free.

There are at least 8 options on the scope of a MOPR: a) A squeaky clean MOPR that includes all subsidies, including state econ dev tax breaks and self-supply; b) exclude state econ development incentives; c) exclude self-supply (munis, coops, vertically integrated utilities)

e) exclude all RECs f) exclude only voluntary RECs g) don’t expand at all.

h) ELCON and PJM Industrials define a limited expansion: MOPR applies only to government-mandated payments w known monetary value to specified resources (no competitive process) above a de minimis level. Under this standard, REC-generating resources are not MOPRd.

Plus, there’s the “Proportional MOPR” concept pushed by AES, Clean Energy Industries – partially subsidized resources should be only partially MOPRd. In other words, a resource receiving a 5% subsidy should be 5% MOPRd while a receive receiving a 50% subsidy should be 50% MOPRd.

There is also some debate about MOPR implementation – i..e, if there are exemptions, should there be a cap? Regardless who is captured by the MOPR, what should the offer floor price be?

2) On the FERC-proposed FRR-RS that would allow resources and equivalent load to exit the PJM capacity construct but still be counted toward regional capacity – there are only a handful of parties that flesh this out.

Fossil generators are united against it and do not generally engage w design details. LS Power is the exception. It is united w its fossil brethren against FRR but it does offer parameters if FERC goes down that path.

Clean energy advocates/nukes emphasize that the FRR must give states and resources flexibility. AES and Clean Energy Industries also offer high-level principles. Kudos to Exelon for drafting tariff language. PJM also provides its own version w a different acronym (RCO).

At least two states (MD+OH) and various competitive retailers raise implementation challenges. OPSI and Illinois urges FERC to provide state with sufficient time (roughly a year) to work it out.

3) New proposals: Eastern and Exelon say FERC should initiate carbon fee docket; Vistra offers the CAPSS and MD PSC floats the Competitive Carve-Out auction; NRG and Calpine threaten to ask for stranded costs; FE and ACCCE+NMA want a fuel-secure auction; IMM’s SMR; PJM’s RCO-X

Replies to these initial filings due in early Nov; FERC also has rehearing requests pending from its 6/29 order and somewhat related rehearing requests from its ISO-NE CASPR order…what does Bernie Mac think of all this? /end

Today is the date for reply comments in the FERC proceeding about PJM's capacity market. I'll post highlights here as they come in, starting with our comment this afternoon. Tesla, MD PSC, MI Energy Agency, and WV PSC have filed early. Nice work.

Of course eLibrary is down...
I can't log in so I can't file...

Hot tip from FERC if you can't log in to eLibrary - use Explorer, not Chrome. I feel like the guy who calls IT because the printer is unplugged.

Harvard Electricity Law Initiative – FERC should discount generators’ threats about “stranded cost” recovery relating to a change in PJM auction rules. statepowerproject.files.wordpress.com/2018/11/electr…

Generators (NRG, Calpine) made vague arguments for stranded cost recovery in initial filings, warning they may ask FERC for payouts if it doesn’t approve a “clean” auction. Their arguments mangle FERC’s restructuring orders and misunderstand FERC’s market-based rate authority.

We argue that generators’ extraordinary stranded cost claims relating to a capacity auction that did not exist a decade ago do not withstand scrutiny.

The Commission’s Open Access Orders limited stranded cost recovery to specific long-term contracts and rejected the amorphous relief that generators threaten to request.

Generators’ “expectation and reliance interests” are irrelevant, as no party has breached any contract. Participation in an RTO capacity auction does not create cognizable claims to profits under the Federal Power Act.

Generators argue that they are entitled to a “competitive” market, but courts have held that the Commission has no obligation to provide a “competitive” market at all. Moreover, our comment argues that generators define competition discriminatorily.

Their “clean” market would relegate historic investors to second-class participants, raise consumer costs, impair state authority, and penalize generators who had themselves relied on past FERC statements that they would not be excluded from the market.

Generators’ disappointment in capacity prices and rules does not entitle generators to a payout. Their complaint about low prices ignores the link between price signals and reliability to rationalize the creation of a walled garden for private equity investors.

It would be unjust and unreasonable and contrary to the long-standing principles for FERC to award stranded cost recovery based on changes to PJM capacity auction rules.

Exelon calculates that fossil generators' "clean" market would cost PJM ratepayers $900M per yr, $700M of which would be paid by EMAAC (NJ, DE, MD) - elibrary.ferc.gov/idmws/file_lis…

Exelon claims that PJM's "Extended RCO" (see above) would cost PJM ratepayers $2.6 BILLION per yr, $2.2B of which would be paid by EMAAC (NJ, DE, MD)

Good discussion of FERC-state jurisdictional principles. Not surprising since the legal team that wrote these comments also won both ZEC cases.

Exelon points out that the existing FRR retains units that would not clear RPM if subject to the MOPR - most recent FRR plans include three GW of older (1950s-60s), under 400 MW per unit coal burners that resemble the types of units that have largely otherwise retired across PJM.

Exelon brings the 10th Am. into this: "as SCOTUS recently reaffirmed in NFIB v. Sebelius, the federal government cannot induce states to rely on a cooperative federalist scheme and then leverage that reliance to coerce states into giving up control over core sovereign powers"

Exelon: FERC's "core responsibility with respect to the RPM auction is to protect the integrity of the auction process, by ensuring that suppliers are making competitive offers, so that the clearing price reflects robust competition
among suppliers to serve the available load..."

"...By contrast, the Commission does not have the last word on whether states rely on the auction to serve their load. That decision is up to the states."

Exelon says PJM's proposed Extended RCO results in "massively inflated customer costs" bc it sets the price by removing state-supported resources entirely from the supply stack, rather than adding them back in at "competitive" levels.

NRG is one of many that tells a completely opposite story from Exelon - "Let’s call FRR-A what it is: a proposal to re-regulate a substantial portion of the competitive wholesale market" elibrary.ferc.gov/idmws/file_lis…

"From NRG’s perspective, a substantial price decrease threatens the viability of our coal-fired power plants (and the attendant loss of fuel security attributes and jobs)." I had not seen any company being that specific about what precisely is at stake.

NRG's witness finds it "likely" that the cost of ZECs is outweighed by the reduction in capacity prices for Illinois ratepayers - the result is a "transfer of cash from competitive suppliers to Exelon"

NRG actually shares Exelon's concerns that Extended RCO will result in prices that are too high. They suggest adding the state-supported resources back in and changing MW commitments of all resources and payments to the uncleared resources. See p 20-26

Vistra hits back against various MOPR-lite alternatives discussed in the first round - "Alternative MOPR," materiality thresholds, REC exemptions - they've got you covered - elibrary.ferc.gov/idmws/file_lis…

Calpine beings by helpfully summarizing that "The Commission now has the unenviable job of sorting through the filings." Argues that Extended RCO is the best option and agrees with NRG's criticism that subsidized resources should be included elibrary.ferc.gov/idmws/file_lis…

Calpine also supports the IMM's Sustainable Market Rule and Vistra's substitution auction that is similar to ISO-NE's CASPR

Calpine: " the Commission also has a MORAL OBLIGATION to implement rules that allow competitive generators the opportunity to recover their investments in the market." (my emphasis). Calpine doubles down on its stranded cost arguments, which our comment rebuts.

Calpine outrageously claims that there is a "regulatory compact that PJM and the Commission would protect and defend competitive markets" This is so very wrong.

Our comment explains that market-based rates are not premised on the presence of a "competitive" market. FERC must ensure that sellers do not have market power. That's it's legal duty.

To the extent that the "regulatory compact" metaphor has any equitable force, it is premised on the utility having obligations to serve, administratively set ROE, and regulators controlling exit/entry. None of those features are present in FERC's regulation of RTOs.

EPSA continues to argue for a Clean MOPR. Period. They say Extended RCO is not "optimal market design choice and is a choice that would be unnecessary but for an affirmatively bad market design choice, the FRR Alternative." elibrary.ferc.gov/idmws/file_lis…

EPSA: "Leaving aside the fact that it is a bit rich for Exelon to imply that the Illinois legislature spontaneously decided to award Exelon billions of dollars in subsidies..." This is an argumentative, well-cited brief.

"EPSA appreciates that, at times, the care and feeding of RPM and other capacity
markets may induce a certain degree of capacity market fatigue and prompt questions about whether there is some better approach."

Shell: Illustrating the "diminished role played by energy markets in terms of sending efficient price signals for resource entry and exit and as a place for hedging activity;" PJM should "explore methods to allow states to implement carbon pricing" elibrary.ferc.gov/idmws/file_lis…