@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

@ENERGY @FERC P.S. - Should be noted here that FERC’s obligation here is only to consider the potential reforms suggested by DOE. It can finalize something different, or as we saw during Trump 1.0 when DOE directed FERC to consider fuel assurance payments, decline to finalize anything.

@EnergyLawJeff @ENERGY @FERC @threadreaderapp unroll