Adrienne Thompson

Latest Articles

Nominee for DOE Secretary Dan Brouillette Testifies Before Senate Committee on Energy and Natural Resources

By Katherine O'Konski & Adrienne Thompson

November 21, 2019

On November 14, 2019, the Senate Committee on Energy and Natural Resources (“Committee”) held a hearing to consider the nomination of Dan Brouillette as Secretary of Energy. Mr. Brouillette is currently DOE’s Deputy Secretary, and has been nominated by President Trump to replace outgoing Secretary Rick Perry.…

Washington Energy Report

Calpine Corp. Settles FERC Investigation of Battery Testing and Outage Issues

By Katherine O'Konski & Adrienne Thompson

November 14, 2019

On November 1, 2019 FERC approved a Stipulation and Consent Agreement between its Office of Enforcement (“OE”), the regional reliability entity Texas Reliability Entity, Inc. (“Texas RE”), the North American Electric Reliability Corporation (“NERC”), and Calpine Corporation (“Calpine”), related to Calpine’s alleged violations of NERC reliability standards governing maintenance and testing of batteries and other protection systems, as well as provisions of the California Independent System Operator Corporation (“CAISO”) Tariff requiring entities to report planned…

Washington Energy Report

FERC Denies Complaint Alleging SoCal Edison Improperly Directly Assigned Certain Network Facilities Charges

By Tom Marshall & Adrienne Thompson

November 6, 2019

On October 24, 2019, FERC denied Harbor Cogeneration Company, LLC’s (“Harbor”) complaint alleging that Southern California Edison Company (“SoCal Edison”) misclassified certain interconnection facilities contrary to FERC’s Order No. 2003 and violated SoCal Edison’s Transmission Owner Tariff (“TO Tariff”) in directly assigning the facility costs to Harbor without FERC “approval.” FERC denied the complaint and rejected Harbor’s request for refunds, reasoning that the charges constituted valid filed rates notwithstanding that FERC did not use the…

Washington Energy Report

FERC Directs Additional Briefing in Ongoing Investigation of PJM’s Uplift Cost Allocation

By Katherine O'Konski & Adrienne Thompson

October 30, 2019

On October 17, 2019, FERC directed PJM Interconnection, L.L.C. (“PJM”) and other interested parties to provide information with respect to how uplift costs—i.e., the costs associated with make-whole payments provided by Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”) to market participants whose commitment and dispatch resulted in a shortfall between the generator’s offer and the revenue earned through market-clearing prices—should be allocated to virtual transactions in PJM, and in particular to Up-to-Congestion (“UTC”)…

Washington Energy Report

FERC Staff Offer Recommendations for CIP Reliability Audits and Cybersecurity

By Miriam Archibong & Adrienne Thompson

October 16, 2019

On October 4, 2019, FERC staff issued a report for users, operators, and owners of the bulk-power system to increase compliance with mandatory Critical Infrastructure Protection (“CIP”) standards and improve cybersecurity for the nation’s electric grid. In the report, FERC staff recommended, among other things, that entities: verify employees’ recurring authorizations for using removable media; ensure all employees and third-party contractors complete required trainings and properly maintain training records; consider all generation assets when categorizing…

Washington Energy Report

FERC Allows CAISO to Expand use of RMR Contracts, Drawing Partial Dissent from Commissioner Glick

By Sidney Villanueva & Adrienne Thompson

October 8, 2019

On September 27, 2019, FERC approved CAISO tariff revisions to its voluntary Capacity Procurement Mechanism (“CPM”) and mandatory Reliability-Must-Run (“RMR”) framework such that all backstop procurement from resources that would otherwise retire or mothball will be addressed through CAISO’s RMR provisions. While FERC has traditionally considered RMR contracts as measures of last resort, FERC found it just and reasonable for CAISO to expand its use of such contracts to address evolving operational needs due, in…

Washington Energy Report

Executive Summary of FERC’s Notice of Proposed Rulemaking regarding the Public Utility Regulatory Policies Act of 1978

By Miles Kiger, Katherine O'Konski, Russell Kooistra, Adrienne Thompson, Tom Marshall & Sidney Villanueva

September 20, 2019

Summary of NOPR On September 19, 2019, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) proposing to revise its regulations implementing Sections 201 and 210 of the Public Utility Regulatory Policies Act of 1978 (PURPA) in light of changes in the energy industry since 1978.[1]…

Washington Energy Report

FERC Reaffirms PG&E Transmission Rate Incentive Eligibility

By Meghan Mandel & Adrienne Thompson

July 31, 2019

On July 18, 2019, FERC affirmed on remand its prior approval of Pacific Gas and Electric Company’s (“PG&E”) request for a return-on-equity (“ROE”) incentive adder to its transmission rates (“RTO-Participation Incentive”) for its ongoing membership in the California Independent System Operator Corporation (“CAISO”). In its decision, which followed from a 2018 remand from the U.S. Court of Appeals for the Ninth Circuit (“Ninth Circuit”), FERC reasserted its jurisdiction over such transmission incentive questions and determined…

Washington Energy Report

FERC Eliminates Obligation to Submit Indicative Screens to Obtain Market-Based Rate Authority in Certain Wholesale Markets

By Katherine O'Konski & Adrienne Thompson

July 24, 2019

On July 18, 2019, FERC issued Order No. 861, modifying its regulations regarding the horizontal market power analysis required to obtain authorization to sell energy, capacity, or ancillary services at market-based rates. FERC adopted its proposal (see December 20, 2018 edition of the WER) to relieve electric power sellers of the obligation to submit indicative screens to obtain or retain market-based rate authority in any Regional Transmission Organization (“RTO”)/Independent System Operator (“ISO”) market with…

Washington Energy Report

FERC Rejects PJM’s Changes to Price Responsive Demand Rules

By Miriam Archibong & Adrienne Thompson

July 18, 2019

On June 27, 2019, FERC rejected PJM Interconnection, L.L.C.’s (“PJM”) proposed revisions to its Open Access Transmission Tariff and Reliability Assurance Agreement Among Load Serving Entities in the PJM Region that would have required demand resources to be available year-round. PJM argued that the proposed revisions better aligned its Price Responsive Demand (“PRD”) program with the year-around availability obligation of other supply-side “Capacity Performance Resources” participating in PJM’s capacity market. On review, however, FERC agreed…

Adrienne Thompson

Nominee for DOE Secretary Dan Brouillette Testifies Before Senate Committee on Energy and Natural Resources

Calpine Corp. Settles FERC Investigation of Battery Testing and Outage Issues

FERC Denies Complaint Alleging SoCal Edison Improperly Directly Assigned Certain Network Facilities Charges

FERC Directs Additional Briefing in Ongoing Investigation of PJM’s Uplift Cost Allocation

FERC Staff Offer Recommendations for CIP Reliability Audits and Cybersecurity

FERC Allows CAISO to Expand use of RMR Contracts, Drawing Partial Dissent from Commissioner Glick

Executive Summary of FERC’s Notice of Proposed Rulemaking regarding the Public Utility Regulatory Policies Act of 1978

FERC Reaffirms PG&E Transmission Rate Incentive Eligibility

FERC Eliminates Obligation to Submit Indicative Screens to Obtain Market-Based Rate Authority in Certain Wholesale Markets

FERC Rejects PJM’s Changes to Price Responsive Demand Rules

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