The "Statement of Principles Regarding PJM", reflecting the agreement between ALL of the PJM Governors and the Energy Dominance Council, is now on live on DOE's website. Details largely consistent with @JarrettRenshaw's excellent reporting last night. 1/ energy.gov/documents/stat…
@JarrettRenshaw The agreement urges PJM to conduct an emergency backstop auction to procure *new* generation capacity with an offer of 15 year contracts, with all costs of the auction allocated to utility zones with data centers that haven't self-procured or agreed to curtail. 2/
@JarrettRenshaw It also urges a two-year extension of the price cap in the existing capacity auction; improved load forecasting; accelerated interconnection for new gens procured in the backstop auction; and a new stakeholder process to fundamentally reform the capacity market. 3/
@JarrettRenshaw The governors agree to "use their authorities to allocate costs to data centers and protect residential customers" by ensuring their commissions design "rate class structures" to allocate the backstop auction costs to new data centers. 4/
@JarrettRenshaw Much of this was proposed by the Governors and data center interests in the recently concluded PJM CIFP process, with the exception of the backstop auction and the cost allocation specification for data centers who have not self procured. That proposal "failed" like the others.5/
@JarrettRenshaw There could potentially be a lot of good aspects to this, but this is not a risk free endeavor for customers. The agreement tacitly acknowledges this, noting that there could be additional costs from the 15 year contracts to allocate to utility zones that are "short". 6/
@JarrettRenshaw Also, that last paragraph with the commitments of the govs is doing A LOT of work. The cost allocation rubber meets the road there. Will the commissions go along? Do they have the tools to achieve this? Will what they get from PJM be transparent enough? 7/
@JarrettRenshaw In addition, I do wonder how they will decide whether a data center has "self-procured". Does it have to be a certain kind of contract or arrangement? Yet to be seen. 8/8
@JarrettRenshaw Some data centers will probably see this as another tool to get some certainty and address the looming social license problem they have around utility costs. Others may retreat behind the meter (hard to do completely) or to other regions.
Did I mention never a dull moment? 9/9
@JarrettRenshaw Putting out a proposal different than the one all your Governors and the President of the United State just sprung on you unannounced is . . .a choice?
One final domino to fall today: the PJM Board of Managers has released its own proposal to address large load growth and cost allocation. It contains a lot of similarities to the plan urged by the Energy Dominance Council and PJM Govs today, but has a couple of important diffs 1/
On a quick comparison, there are a few differences. The most notable is that the Board is not proposing to extend the price collar to two more auctions, at least not yet. Instead, it's asking for stakeholder feedback. EDC/Govs would extend two more auctions. 3/
Next week, @FERC will address several long-running dockets on co-location of generation with large loads in PJM. FERC doesn't appear to be acting on DOE's ANOPR proposal on this subject yet, but what it does here will have obvious implications for that. 1/
@FERC Just before Thanksgiving, @FERC also received a complaint from the PJM Independent Market Monitor (EL26-30), asking that it declare that PJM has authority to refuse to interconnect data centers if there is insufficient generation to serve them. 2/elibrary.ferc.gov/eLibrary/filel…
@FERC So, needless to say, LOTS happening here. The IMM complaint is, to be charitable, poorly timed and not particularly well-plead. Several parties have already urged @FERC to dismiss it, which the Commission should absolutely do for two reasons. 3/
So, FERC got a lot of comments on large load interconnection. @AriPeskoe and others have great summaries. At the risk of being immodest, though, I'm going to tout Electricity Customer Alliance's comments as one of the few that provide a practical path forward for FERC. 🧵1/
@AriPeskoe What do our comments say? First, we explain why the lack of clarity in large load interconnection procedures and lack of clear paths for bringing your own generation, among other things, is creating acute risks of unjust and unreasonable rates. 3/
The results here illustrate a couple of things: (1) treating these proposals as 12 separate proposals was destined for failure when success is defined as a stakeholder-weighted vote in support of 1, and (2) the disagreements here are really around just a few issues. 1/
If you spend even just a little time with all the proposals, you find that there was good unanimity around (1) improving load forecasting, (2) making DR more workable in the short term, and (3) accelerating generator interconnection to facilitate "bring your own power". 2/
Several of the "separate proposals" mostly included variations on these things, or additions to this list, not full on new proposals or disagreement around these items. 3/
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/
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