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Quick take on the PURPA proposal as I understand it so far: the proposal to drop the rebuttable presumption threshold under 210(m) from 20 MW to 1 MW, and the proposal to potentially extend 210(m) relief outside the RTOs, could both significantly harm competition. 1/?
One beef I have is that FERC seems to be progressing from the notion that PURPA was all about addressing dependence on oil and the 1970s oil shortages/embargo. But as I've noted here before, that's only one of the goals PURPA sought to achieve. 2/?
Another key goal of PURPA was to encourage more competition after a period of regulated monopolies making bad investments in power projects and leaving consumers to bear the costs. PURPA birthed non-utility generation as a competitor. 3/?
To be sure, we've come a long way since then. But smaller resources still face numerous barriers to participation in RTOs/ISOs, many of them structural. FERC recognized that in 2006, and little has changed since then. 4/?
I'm interested to see what evidence FERC points to support this change in policy. Similarly, it's unclear to me how 210(m) could be interpreted to extend mandatory purchase obligation relief beyond RTOs/ISOs; the language is relatively specific. 5/?
Another place we've come along way recently is IRPs; many states are using them more effectively to ensure that the most cost-effective options in the market are getting selected. But I'm not aware of any non-RTO state that provides market access comparable to RTOs. 6/7
The staff presentation refers to open access to transmission as a development potentially supporting these changes; but the OATT was around when Congress passed 210(m) in EPAct 2005, and when FERC implemented in 2006. 7/7
