New FERC Chairman Christie's priority is dispatchable resources.

Greater role for States in generator interconnection and transmission project costs allocation, priority for dispatchable resources, and possible capacity market overhaul.

President Trump has appointed current Federal Energy Regulatory Commission (FERC) Commissioner Mark Christie as Chairman. Naturally, I am curious what would be Chairman Christie’s priorities.

His priority can be summed up in his own words on X:

“In both PJM and MISO, dispatchable generation kept the lights on and heat pumps running during this freezing weather. We need to stop the premature retirements of dispatchable generation and build more, otherwise we freeze in the dark. That is reality.”

Right off the bat, we know that Chairman Christie has background as a state regulator. He was the Chairman at Virginia State Corporation Commission. You can read more about his background here.

Source: FERC

Reading his opening comments at an Interconnection Workshop that FERC had last year, it is quite clear that he would give preference to state regulator ideas. For example, he states,

“That proposal is to enable state utility regulators to designate those generation resources in their states awaiting interconnection that are critical to reliability. Such state designations would move those resources to the front of the queue. State regulators know which resources are needed to keep the lights on in their states; that expertise should justify prioritization. I see no problem with this form of prioritization in terms of Order No. 888’s open access requirements, but if necessary, we should be prepared to amend 888 to allow such prioritization, given its critical importance to reliable power service.”

Chairman Christie is referring to a proposal from the Chairman of the Colorado Public Utilities Commission to speed up interconnection of renewable projects.

Current FERC Commissioners. Source: X

Chairman Christie also thinks we are headed to a reliability crisis due to the following 3 issues:

• “First, the far too rapid loss of existing dispatchable resources;

• Second, rapidly rising demand largely driven by data centers and other hyperscale users;

• Third, the inability to bring online those new generation resources that can give us a lot more capacity and quickly. So we need to identify and prioritize those generation resources for interconnection as quickly as possible.”

It is interesting to note that on the co-location issue, then Commissioner Christie was in majority rejecting the PJM’s Susquehanna Co-Location Proposal. Then Chairman Phillips was the lone dissenting vote.

It is also worth noting that then Commissioner Christie dissented on Order 1920, which is the transmission planning order that then Chairman Glick spearheaded. Commissioner Christie voted in favor of Order 1920 A, which expanded state provisions. You can read his long dissent on Order 1920 here.

He has also written an article pushing for a review of capacity markets. It is reported in this Utility Dive article. As a Chairman, will he push for reforming capacity markets at the Independent System Operators?

He has strong opinions on transmission project costs - “Don’t count on FERC as the ‘big sugar daddy’ for new transmission, generation: Commissioner Christie” and also “FERC transmission incentives ‘way out of whack,’ drive up consumer costs: Commissioner Christie”

It might be worthwhile to read his past opinions but start with “FERC affirms generator interconnection rule, but ‘it’s not a silver bullet,’ Christie says”, “States shouldn’t have to pay for transmission driven by other states’ policies: FERC’s Christie” and “Extreme weather shows need for dispatchable resources, new transmission: FERC commissioners”

Reading then Commissioner Christie’s concurrence on March 1, 2023 in FERC’s decision on PJM’s Order 2222 filing (ER22-962-001), here are my key takeaways:

1. Commissioner Christie would have voted against Order 2222. [Source: “I would have voted against Order No. 2222 had I been a member of the Commission at that time and I did vote against Order No. 2222-A.”]

2. He says “encouraging the development of DERs is a good thing.” But he doesn’t think Order 2222 as the right vehicle. [Source: “I just don’t think Order No. 2222, which “eviscerat[es] the states’ historic authority in the name of encouraging DER development,” was the right vehicle.”]

3. He believes “that the complexities that Order No. 2222 creates will haunt the RTOs and RERRAs — let alone the reliability of the grid and the pocketbooks of consumers — for a very long time.”

4. He urged “PJM to give the concerns of the OPSI states the highest priority.” OPSI is Organization of PJM States.

5. He stated “States may even require new legislation to implement Order No. 2222’s requirements and, at a minimum, these practical challenges facing the individual states will take time to resolve”.

6. He stated “Among its many examples of fundamentally flawed reasoning, Order No. 2222 and its progeny blithely ignore the fact that resources on the distribution grid are matters first and foremost of state jurisdiction, state responsibility and state rate regulation. So Order No. 2222 was and remains fundamentally in conflict with state regulations and policies in an area — retail rate and distribution grid regulation — that has always been dedicated to state authority.”

7. He believes, “the costs associated with Order No. 2222 compliance will be enormous and paid by the consumer cannot be denied.”

8. He believes, “A rapid concentration of behind-the-meter aggregated DERs at various locations on the local grid will inevitably require costly upgrades to a distribution grid that has largely been engineered to deliver power from the substation to end-user retail customers.”

9. Feds (FERC) cannot push States on implementing Order 2222. [Source: “given all of the complexities of Order No. 2222, and the state’s own processes and jurisdictional charges, the states may not be on the same timeline as the one approved by the Commission today, nor are they required to be.”]

Couple of last points, Chairman Christie served as an Officer in the U.S. Marine Corps. And he loves Greyhounds.

Source: X