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mfarmer.bsky.social
Miles Farmer
@mfarmer.bsky.social
2.5K followers 1K following 180 posts
clean energy policy, strategy, and law
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mfarmer.bsky.social
To get from the high-level principles announced in the ANOPR to real-world implementation would take a lot of work from
@ferc.gov, utilities and developers. We discuss these issues in the Policy Brief.
November 5, 2025 at 7:39 PM
mfarmer.bsky.social
As we discuss in the Policy Brief, "flexibility" can mean a lot of things: it includes demand response capabilities, utility-scale batteries paired with the load, and other strategies discussed in our Brief. Here's an example, from
@verrusdata.bsky.social: www.latitudemedia.com/news/verrus-...
Verrus successfully demos its flexible data center technology
The Sidewalk Infrastructure Partners’ venture used an NREL testing software platform to validate its tech under real-world grid conditions.
www.latitudemedia.com
November 5, 2025 at 7:39 PM
mfarmer.bsky.social
@tnorris.bsky.social discusses the benefits of load flexibility in his @nytimes.com op ed. It can provide speed-to-power for the large customer, while keeping electricity affordable and reliable for everyone else. www.nytimes.com/2025/11/04/o...
Opinion | A Simple Fix to America’s Soaring Electricity Prices
www.nytimes.com
November 5, 2025 at 7:38 PM
mfarmer.bsky.social
Saw from @nickguidi.bsky.social that DOE actually used its section 403 authority more recently with gas certification policy: www.utilitydive.com/news/in-unus...
bsky.app
October 24, 2025 at 6:07 PM
mfarmer.bsky.social
There is a provision of the Department of Energy Organization Act (section 403) that provides DOE with authority to propose rulemakings to FERC. It is not commonly used. The last time it was done was DOE's ill-conceived bailout of "baseload" resources.
October 24, 2025 at 2:11 AM
mfarmer.bsky.social
10 - clarifies that it does not discourage filings from utilities to implement similar reforms while the ANOPR proposal is pending:
This proposal is not intended in any way to discourage public utilities from making filings to address these and similar issues under FPA section 205
October 24, 2025 at 2:07 AM
mfarmer.bsky.social
9 - calls for transition plans in adopting new rules
Thirteenth, there must be a plan to implement these proposed reforms. We seek comment on appropriate transition plans, including the treatment of large load interconnections that are already being studied for interconnection.
October 24, 2025 at 2:05 AM
mfarmer.bsky.social
8 - gives the large load customer the option to build:
Ninth, to the extent the interconnection customer is not the transmission owner, the interconnection customer shall be afforded the same (or equivalent) option to build as currently provided to generator interconnection customers.
October 24, 2025 at 2:04 AM
mfarmer.bsky.social
7 - proposes to assign 100% of network upgrade costs to the large loads. Calls for comment on whether such costs should be offset through a crediting mechanism and, if so, over
how many years.
Eighth, load and hybrid facilities should be responsible for 100% of the network upgrades that they are assigned through the interconnection studies. We seek comment on whether such costs should be offset through a crediting mechanism and, if so, over how many years.
October 24, 2025 at 2:03 AM
mfarmer.bsky.social
6 - Calls for flexible loads to get priority!
Seventh, the interconnection study of large loads that agree to be curtailable and hybrid facilities that agree to be curtailable and dispatchable should be expedited. The system operator's ability to control such facilities through curtailment and/or dispatch must be sufficient for the system operator to integrate the facility into both operations and system planning. This ensures the timely and orderly addition of large loads to the transmission system in a safe, reliable, and non-discriminatory manner. We seek comment on whether this should be accomplished through a serial interconnection study process or by some other means. We also seek comment on appropriate deadlines for such an expedited study process, including whether such studies can be completed in 60 days.
October 24, 2025 at 2:02 AM
mfarmer.bsky.social
5 - DOE calls for standardized study deposits, readiness requirements, and withdrawal penalties.
Fourth, like generating facilities, load and hybrid facilities should be subject to standardized study deposits, readiness requirements, and withdrawal penalties. These provisions deter speculative projects and provide transmission providers with more useful information to more accurately forecast demand on their systems. We seek comment on the extent to which the existing study deposits, readiness requirements, and withdrawal penalties can be adopted. We also seek comment on whether additional commitments or financial penalties would be appropriate.
October 24, 2025 at 2:00 AM
mfarmer.bsky.social
4 - DOE calls for load and generation to be studied together wherever practicable:
Third, to the extent practicable, load and hybrid facilities should be studied together with generating facilities. Such an approach will allow for efficient siting of loads and generating facilities and thereby minimize the need for costly network upgrades.
October 24, 2025 at 1:59 AM
mfarmer.bsky.social
3 - DOE sets a threshold of 20 MW for the reforms' applicability:
Second, consistent with the Commission's pro forma LGIP and LGIA, the reforms should only apply to new loads greater than 20 MW and, for hybrid facilities
October 24, 2025 at 1:58 AM
mfarmer.bsky.social
2 - DOE claims that @ferc.gov has jurisdiction over the interconnection of large loads TO THE TRANMISSION SYSTEM. Makes a robust argument for this jurisdiction but states that it is not regulating interconnection to the distribution system.
There are at least four legaljustifications for the Commission's jurisdiction over such interconnections. First, like generator interconnections, large load interconnections are a "critical component of open access transmission servicc'v? that require minimum terms and conditions to ensure non-discriminatory transmission service.
October 24, 2025 at 1:57 AM
mfarmer.bsky.social
1 - The Secretary is asking for a fast response:
On behalf of the American people, and given the urgency of this issue, I look forward to your consideration and final action (no later than April 30, 2026).
October 24, 2025 at 1:54 AM