[Take two!] Four events this week may send us once more into the fray of FERC, state policies, and RTO/ISO wholesale markets. A thread on them, starting with a significant announcement from 5 of the New England Governors . . . 1/
1. Today, @NESCOEStates released the "Governors Statement on Electricity Reform 2020", calling for the regional ISO to become "a committed partner in [their] decarbonization efforts." 2/ nescoe.com/resource-cente…
It's a forceful statement noting the misalignment of today's "electricity market and organizational structures" with the State's clean energy mandates, and suggesting these States will seek to be more in the driver's seat going forward. Significant and important! 3/
2. Also today, two large natural gas-fired generators in NYISO filed a complaint at FERC asking FERC to impose a PJM-style broad MOPR on the rest of the state (currently such a MOPR only applies downstate). I don't need to explain why this is controversial . . . 4/
3. Tomorrow, @FERC will rule on PJM's proposal to comply with FERC's orders requiring it to install the broad MOPR. PJM's compliance filing included important flexibility for renewables and other advanced energy resources to reflect their actual costs and clear the market. 5/
PJM would allow these technologies to develop unit specific offer floors based on their actual circumstances, rather than under generic parameters designed for gas-fired power plants. If FERC rejects PJM's filing, we'll be facing major Qs about the future of PJM + the states. 6/
4. FERC has also included in it's Open Meeting agenda for tomorrow an item regarding the recent Carbon Pricing Technical Conference; hoping we'll hear about planned next steps. 7/ ferc.gov/sites/default/…
As I mentioned in this UD story, I thought the conference gave some reason to hope for a policy shift from FERC in how it addresses the interaction of state policies and wholesale markets. So that is definitely something to watch as it moves forward. 8/ utilitydive.com/news/ferc-carb…
So, there's, um, A LOT going on when it comes to FERC-state relationships and the future of RTO/ISO markets this week. Let's hope this isn't me come next week. 9/9

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More from @EnergyLawJeff

31 Oct 19
Thanks again to @EnergyCommerce and @HouseCommerce for inviting us to testify yesterday! You can find all the testimony and a link to the webcast recording here. A couple of takeaways in this brief thread. 1/? energycommerce.house.gov/committee-acti…
@EnergyCommerce @HouseCommerce First, I want to reiterate our overarching message - with wind, solar, energy storage, DER, EE, and all other advanced energy technologies now the least-cost resources, transitioning to a 100% clean power sector is an economic opportunity for America, not an economic burden. 2/?
@EnergyCommerce @HouseCommerce Second, the panel was almost unanimous that we need the federal government to establish a policy objective of reaching net zero carbon emissions by 2050. We strongly support this announced goal of @EnergyCommerce leadership and look forward to working with them. 3/?
Read 9 tweets
19 Sep 19
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/?
Read 7 tweets
1 Apr 19
Here's a good thread on yesterday's NYT article about the La Paloma generating plant in CA, and the complaint they filed that FERC swiftly and unanimously rejected. In addition to @MilesFarmer's excellent analysis, here is my own quick thread. 1/?
The comparison to FERC's order proposing to impose minimum offer prices on renewables and some nuclear in PJM is tenuous at best, because that order's rationale (which I strongly disagree with) is based on PJM's centralized capacity market design. 2/?
The supposed "price suppression" FERC claims occurs in PJM simply can't occur under CAISO's market design. As Miles explains, CAISO doesn't have a centralized capacity market, and FERC has never suggested it will impose one. In fact, La Paloma basically asked FERC to do that. 3/?
Read 6 tweets

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