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Chatterjee summarizes the PJM order - it builds on MOPR-Ex proposal that PJM filed in April 2018 and FERC rejected in June 2018.
Expanded MOPR includes the following exemptions: existing RE "participating in" RPS programs; existing DR, EE, storage; existing self-supply and competitive resources that do not receive state subsidies (I think I got them all)
It sounds like there is no carve out.
FERC will give PJM 90 days to file ANOTHER proposal - so no final resolution today. ANOTHER proceeding to come.
Chatterjee emphasizes that MOPR will only apply to STATE subsidies. That sounds like there will be a distinction between compliance RECs and voluntary RECs. Not sure how PJM/FERC will police that.
Chatterjee began with "PJM RPM is mechanism for assuring resource adequacy at JR rates." If there's no carve-out, then the RPM ceases to be a resource adequacy mechanism. No reasonable RA mechanism can ignore gigawatts of nuclear capacity (and GWs of wind+solar+etc).
If you want to brush up on MOPR-ex, see paragraphs 73-106 of its June 2018 order ferc.gov/CalendarFiles/…

FERC rejected it in June 2018 bc it exempted RPS resources from the MOPR. Today, FERC seems to reverse that (based on N-Chat's remarks)...
Glick is 30 days off but his point is valid!
Glick warns that FERC's definition of state subsidy is too broad - something to look for in the text. Says it blows up muni/co-op business model, captures RGGI (which leads to higher market prices), and generators participating in NJ's BGS auction.
Looks like this from my initial comment in the docket will hold up - eelp.law.harvard.edu/wp-content/upl… If the Commission approves<br /> one of PJM’s proposals, it should expect a steady stream of §206 complaints about laws and<br /> regulations ensnared or uncaptured by PJM’s arbitrary rules. The Commission should<br /> decline PJM’s invitation for interminable conflict with state policies
Glick confirms - there is no resource-carve out. The PJM RPM is now divorced from resource adequacy.
Glick: Order shows a clear preference for existing resources. Order will slow the clean energy transition. 5,000 MW of existing RE gets exempted, but 38,000 in the pipeline will be affected. Vast majority of PJM states are pursuing clean energy programs.
Glick goes into the "deep-state theory." Un-elected Commissioners seek to overturn actions of other branches of government. Cites today's MOPR as overturning states, PURPA NOPR ignoring Congress, and pipeline decisions ignoring DC Circuit on GHGs.
Glick closes by calling for another PURPA technical conference!
Oh no. McNamee says out-of-market support distorts the "regulatory compact." That phrase has absolutely no meaning in connection with wholesale auction markets. We wrote about it here - eelp.law.harvard.edu/wp-content/upl…
McNamee incorrectly suggests that the capacity construct pre-dates state subsidies. No, RPSs and other programs came long before the PJM capacity auction. See page 5 eelp.law.harvard.edu/wp-content/upl…
McNamee doubles down why they are not MOPR-izing federal subsidies. FERC will "honor" Congress's decision. The implication is that FERC will not honor states' decisions.
McNamee says benefits of market will not continue in the long-run if prices are suppressed by state subsidies...This ignores the double-payment problem that FERC recognized last year. Customers will pay PJM capacity rates and for state subsidies. How is that better for customers?
|￣￣￣￣￣ |
| RELEASE |
| THE |
| ORDER |
| ＿＿＿＿___|
(\__/) ||
(•ㅅ•) ||
/ 　 づ
Will it be awkward when clean energy advocates and FirstEnergy are on the same side of this case?

Exelon and PSE&G will almost certainly oppose today's order.

What about Dominion? Glick said self-supplying munis/co-ops will oppose. Presumably self-supplying non-FRR IOUs too?
The press release is out! ferc.gov/media/news-rel…
The release include the precise definition of a "subsidy." Looks to me like it captures state economic development incentives and Dominion. So I guess:

-Natural gas plants no longer want state incentives
-Dominion switches to FRR?
You get MOPR-ized! You get MOPR-ized! You get MOPR-ized!
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Ari Peskoe
@AriPeskoe
A non-exhaustive list of the most arbitrary, capricious, and outrageous determinations in FERC’s PJM MOPR order:

In no particular order . . .
(and making no predictions about litigation)
1 – Choosing not to mitigate federal subsidies (i.e. tax credits) because it finds FERC “may not disregard or nullify the effects of federal legislation,” while ignoring whether it has authority to “disregard or nullify” state clean energy programs.
2 – Isolating econ development incentives as the only state payment that doesn’t subject a resource to the MOPR because such payments are not related to generation while also finding that payments of any amount distort the market, regardless of the state’s purpose.
Read 14 tweets
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Ari Peskoe
@AriPeskoe
The PJM Order - elibrary-backup.ferc.gov/idmws/file_lis…

Always check backup elibrary . . .
Paragraph 7: "The decision by certain states to support less economic or uneconomic resources...cannot be permitted to prevent the new entry or continued operation of more economic generating capacity in the federally-regulated multi-state wholesale capacity market."
In other words, we can't let state clean energy programs block new natural gas plants that are "more economic" under a capacity construct designed to prefer new natural gas plants - see @jacob_mays nature.com/articles/s4156… Asymmetric risk and fuel neutrality in [] capacity markets
Read 40 tweets
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Ari Peskoe
@AriPeskoe
It appears that tomorrow FERC will finally issue its order on the PJM capacity auction (aka Reliability Pricing Model or RPM) and state energy policies. A recap of the key decision points:
BACKGROUND: In 2006, FERC approved the creation of the RPM via a settlement process. Through an annual auction PJM procures sufficient resources (generation, demand response, energy efficiency) to meet its estimate of peak demand 3 years from the auction.
In the 2006 proceeding, parties argued that new entry will “face the possible suppression of prices through buyer actions, such as the decision of states to mandate new reliability projects that could reduce clearing prices to zero.” elibrary.ferc.gov/idmws/common/o…
Read 22 tweets

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Rich Glick
@RichGlickFERC
@FERC @pjminterconnect .@FERC’s PJM MOPR is a direct attack on state electric generation resource decisionmaking. The Federal Power Act is clear, FERC does not have this authority. FERC has the responsibility to attempt to accommodate state decisions not overturn them.
@FERC @pjminterconnect .@FERC’s PJM MOPR is a bailout--costing consumers BILLIONS of dollars every year. Conservatively, $2.4B+ associated w/ higher capacity payments, rising over time per year, & doesn’t even include the costs consumers will pay when states continue to pursue their policy preferences.
@FERC @pjminterconnect The costs imposed by @FERC’s PJM MOPR & the ubiquitous preferences given to existing resources are a transparent attempt to handicap those state actions & slow – or maybe even stop – the clean energy transition.
Read 5 tweets
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Gavin Bade
@GavinBade
We're here at FERC HQ for a pre-filing conference on ISO-NE's upcoming fuel security proposal. Stream: ferc.capitolconnection.org

ISO-NE requested the conference to discuss its proposal, to be filed in October, with FERC staff without ex parte rules.
FERC directed ISO-NE to devise a fuel security framework after it decided to provide cost recovery for a large Exelon gas plant (and adjacent LNG import facility). But it's quite controversial. Background: utilitydive.com/news/iso-ne-ge…
Core of the issue here is that much of ISO-NE's gas fleet — 30% or 4.6 GW, one official just said — may be unable to get fuel during extended cold snaps when gas is diverted for home heating.
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Esther Bartkiw
@soul_whispers
June New Moon Report ➡️ happening Monday the 3rd at 6:02 am eastern time in the sign of Gemini and the energetics support communications, socialization and strong intuitive hits PLUS gives us a foreshadowing of what may be coming up during the July 2nd Solar Eclipse New Moon
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Mr. Skilling (Parody)
@mr_skilling
The first games will tip off in the (Low Return On Invested) Capital Blessings Region.
First match-up is classic blue blood vs new blood. #6 TC PipeLines $TCP has been on the block since 2009 while BP Midstream Partners $BPMP went public in late 2017.

TCP is most known for getting #FERC'd and cutting the distribution immediately before knowing the impacts.
Additionally, $TCP has basically been abandoned by its parent $TRP, which used it as a dropdown vehicle, but has started to rally back as of late.

$BPMP is mostly known for coming public WITH IDRs during a time when everyone hated them. Quite the "fuck you" to investors.
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SeriouslyUS?
@USseriously
Following Judge Emmet Sullivan's order, Special Counsel Robert Mueller has released the redacted 302 report from the Michael Flynn interrogation in January 2017. (1/3)
Following Judge Emmet Sullivan's order, Special Counsel Robert Mueller has released the redacted 302 report from the Michael Flynn interrogation in January 2017. (2/3)
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Rich Glick
@RichGlickFERC
I write tonight to express strong reservations about @FERC’s approach to MOPR and state policies. #FERC is approving #CASPR, for all of the wrong reasons! Follow me below into the #TweetStorm
I disagree strongly with the order’s suggestion that state sponsored resources must either be subject to a Minimum Offer Price Rule (#MOPR) or some alternative mechanism for “accommodating” the effects of state public policies.
That rationale—which is not adopted by a majority of the Commissioners that support the order—is ill-conceived, misguided, and a serious threat to consumers, the environment and, in fact, the long-term viability of the Commission’s capacity market construct.
Read 16 tweets

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