Jeff Dennis Profile picture
Oct 24 6 tweets 2 min read Read on X
Today, @ENERGY sent a directive to @FERC, under Section 403 of the DOE Organization Act, to initiate rulemaking procedures and consider a series of potential reforms to expedite the connection of large loads to the transmission system. 1/ energy.gov/sites/default/…
@ENERGY @FERC Specifically, DOE is asking FERC to consider a series of potential principles in developing new regulations, mostly focused on the development of new procedures for large load interconnections to the transmission system. 2/
@ENERGY @FERC DOE seems very focused here on how those new procedures study and treat so-called "co-location" of new large loads with generation (which DOE calls "hybrid facilities"), including the amount of injection and withdrawal rights that are studied, deposit amounts, etc. 3/
@ENERGY @FERC In addition, DOE says that "the interconnection study of large loads that agree to be curtailable and hybrid facilities that agree to be curtailable and dispatchable [i.e., flexible] should be expedited." 4/
@ENERGY @FERC DOE also sets forth a statement of FERC jurisdiction that, on first read, seems quite broad and expansive. Emphasizes that Justice Thomas, in New York v. FERC, criticized FERC for not extending its jurisdiction further into transmission bundled in retail rates. 5/
@ENERGY @FERC More to come once we all digest, but this proposed set of actions is all but certain to dominate the agenda of FERC under anticipated new leadership. It may also shake loose action on the long-running PJM co-location docket. 6/6

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More from @EnergyLawJeff

Sep 21, 2022
Friendly reminder: Congress was explicit when it enacted Part II of the Federal Power Act that it intended for there to be federal regulation of the interstate transmission grid. The whole point was to fill the gap left by state regulation. 1/ utilitydive.com/news/republica…
"National-scale energy grid regulation is a 'major question' because of the massive economic consequences involved in such regulation," the AGs say. OK, sure. 📣 CONGRESS ADDRESSED THAT QUESTION IN THE FPA 📣 by creating a scheme to, um, regulate the grid on a national scale. 2/
Also, FERC is doing nothing more here than reacting to circumstances not of its own making - a changing resource mix driven by state policies, tax policies enacted by Congress, and consumer choice.

Major questions doctrine, to the extent it's a thing at all, doesn't apply. 3/3
Read 4 tweets
Sep 19, 2022
Lots I disagree with in this piece about RGGI from our Acting Sec. of Natural and Historic Resources, but this admission caught my eye:

"Virginia’s regulated rate structure provides no incentive for utilities to reduce emissions or compliance costs." 1/

washingtonpost.com/opinions/2022/…
As a Virginia resident and ratepayer, I guess my question is - what's the Administration's plan to fix that? 2/2
One more thing: cap and trade works just fine for regulated monopolies if regulators require them to account for compliance costs (i.e, the requirement to pay for the cost of pollution) when considering resource alternatives.
Read 4 tweets
May 28, 2022
@FERC approves ISO-NE proposal to remove MOPR in two years, with a new exemption for a small amount of state-sponsored resources during the next two years MOPR stays in place. All five Commissioners wrote separately, which is incredibly unusual. 1/
The order, which was joined by 4 Commissioners, makes a strong statement (with detailed reasoning) that MOPRing state sponsored resources is not just and reasonable. It also explicitly rejects the idea that MOPR is a reliability tool. Those are both big positives. 2/
3 Commissioners, in separate statements, expressed (like we did) that they did not believe a two-year delay was necessary, but under the FPA could only vote on the proposal before them. 3/
Read 5 tweets
Apr 21, 2022
As expected, @FERC is indeed issuing a Notice of Proposed Rulemaking (NOPR) today on Transmission Planning and Cost Allocation. If I counted right, the vote will be 4-1. Presentation with more details coming soon . . . will try to share some here if I can type fast enough. 1/
@FERC The NOPR is focused on planning and cost allocation, but DOES NOT appear to address generator interconnection. 2/
@FERC Staff says the NOPR would require transmission planning on a "sufficiently" long-term basis, using multiple long-term scenarios including those reflecting impacts of low-frequency high-impact events. Must plan out 20 years in the future(!). 3/
Read 23 tweets
Dec 23, 2021
If all you wanted for Christmas was a FERC order on complex interrelated issues in the energy, reserves, and capacity markets in PJM, well, Merry Christmas to you! Brief 🧵 1/
elibrary.ferc.gov/eLibrary/filel…
What is this acronym soup all about? In short, the Operating Reserve Demand Curve (ORDC) ensures that prices for reserves rise in PJM when system conditions start to get stressed, so that the price of energy and reserves reflect the shortage, just like a "real market". 2/
PJM proposed to make them higher. Quite a bit higher. In 2020 FERC approved that, over the objections of now-Chair Glick, who didn't think PJM made a sufficient record to justify the higher prices. Parties who agreed with him appealed to the courts. 3/
Read 11 tweets
Sep 23, 2021
@FERC and @NERC_Official staff are now providing a report out on their preliminary findings and recommendations stemming from their joint investigation of the February 2021 outages in ERCOT. ferc.capitolconnection.org/#
@FERC @NERC_Official @douglewinenergy asked me to live tweet, and I'm going to try, but I am REALLY bad at it so hold your expectations.
Presentation notes that the Feb. 2021 event is the FOURTH in the past 10 years in which reliability was at risk due to unplanned cold weather-related generation outages. This one was biggest set of outages by a wide margin. Presenter emphasizes these are becoming *common*.
Read 44 tweets

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