Former FERC Commissioner Philip Moeller on Dec. 1 said that he hopes that the commission takes an overall look soon at where FERC Order 1000 compliance matters now stand.
“I lived the Order 1000 development and its evolution to where it is today and from the very beginning, I was kind of a lukewarm supporter of Order 1000,” Moeller said during his keynote address at TransForum East, which was held in Washington, D.C., and presented by PennWell’s TransmissionHub. “I thought it had a lot of potential. I also thought there were parts of Order 1000 that perhaps went too far and might result in more litigation …, particularly how we handle reliability projects. I think that in the end, that hasn’t played out yet, and there are positive elements to all of that.”
Moeller discussed “Order 1000 fatigue,” saying: “[A]t least when I left the [FERC] building about a month ago, there is a fair amount of Order 1000 fatigue because it’s been a multi-year effort. Many of the compliance filings took on a third or a fourth iteration [and it is] very time-consuming, not only for the staff at FERC, but for those of you who have actually worked on compliance filings and [have gotten] to know some of your neighboring utilities, if that’s the field that you’re in, and so it was an extensive effort to come to where the commission is.”
Despite the Order 1000 fatigue, he said that FERC “needs to kind of step back a second and say, ‘Okay, what’s working in various Order 1000 situations … and what’s not, and not necessarily a standard market design approach, but let’s see what the best practices are, RTO by RTO, so that as we move forward, we don’t rush down a certain path that will be less efficient in terms of the process and getting more transmission done.’”
He continued, “So, I am hoping that the commission, at some point relatively soon, will take kind of an overall look, now that we’re here, we’re roughly five to six years into it, [and see] where is Order 1000 compliance and where can it be improved, again, to improve the process, and ultimately, from that perspective, get more transmission built.”
Among other things, Moeller said that there should be a focus on the value of transmission.
“I believe we’ve spent way, way, way too much time talking about the cost of transmission and way, way, way too little time talking about the value of transmission,” he said. “The debate really focuses on cost, whereas I think the debate really should focus on value.”
Transmission is the ultimate enabler of other public policies, he said, adding, “Not only is it necessary for reliable service, it can reduce cost through reducing congestion, [and] it can enable us to have more flexibility and redundancy as our nation’s fuel supply changes.”