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December 7, 2025

WRAP ‘Binding’ Phase Set for Winter 2027/28 After Utilities Affirm Commitment

The Western Power Pool’s Western Resource Adequacy Program (WRAP) has secured enough participants for the program to enter the first binding phase after 11 utilities reaffirmed their commitment in a Sept. 29 letter.

The utilities’ assurance that they will remain in the program comes shortly before the two-year opt-out deadline. The recommitment means WRAP has secured a “critical mass” of participants to move forward with the first binding season in winter 2027/28, WPP said in a statement on its website.

The letter is signed by Arizona Public Service, Avista, Bonneville Power Administration, Chelan Public Utility District, Clatskanie Public Utility District, NorthWestern Energy, Powerex, Puget Sound Energy, Salt River Project, Tacoma Power and Tucson Electric Power.

“As utilities that have actively participated in WRAP since its inception in 2019, we reaffirm our commitment to the program and to continue building on its strong foundation,” the letter stated. “The signatories to this letter will remain in WRAP and participate in binding operations starting in winter 2027/28.”

“The participants who have voiced their commitment to the program represent a broad and diverse group of organizations,” WPP said in its statement. “In addition to those who signed the letter, there are more participants we expect to remain in WRAP, some that recently joined and even more joining in upcoming years.”

WPP launched the WRAP in response to industry concerns about resource adequacy in the West. (See WRAP Participants Find Value in Program’s Nonbinding Phase.)

Under the program’s forward-showing requirement, participants must demonstrate they have secured their share of regional capacity needed for the upcoming season. Once WRAP enters its binding phase, participants with surplus capacity must help those with a deficit in the hours of highest need.

The binding phase also includes penalties for participants that enter a binding season with capacity deficiencies compared with their forward showing of resources promised for that season.

In 2024, the binding phase was postponed by one year at the request of participants, who said they were facing challenges including supply chain issues, faster-than-expected load growth and extreme weather events that would make it difficult for them to secure enough resources and avoid penalties. WRAP members voted in September 2024 to delay the binding phase until summer 2027, but that date was pushed forward. (See WRAP Members Vote to Delay ‘Binding’ Phase to Summer 2027.)

WRAP has also become a focal point in the competition between SPP and CAISO. Both are developing separate day-ahead markets and are trying to attract as many participants as possible. Supporters of SPP’s Markets+ have highlighted that participants in the market must join WRAP, while arguing that CAISO’s Extended Day-Ahead Market (EDAM) contains no RA framework. Most of the signatories to the letter have committed to Markets+.

The organizations wrote in the Sept. 29 letter that WRAP continues to evolve, highlighting the “multiple task forces” involved in developing the program. One such task force is the WRAP Day-Ahead Market (DAM) Task Force that is working to make the program compatible with Markets+ and EDAM. (See WRAP Day-Ahead Market Task Force Moves Forward on Concept Paper.)

“We are confident the program will continue to grow and adapt,” the organizations said. “The program’s design will evolve alongside emerging day-ahead markets, while its broad participation ensures the collective savings and reliability benefits are delivered for customers.”

The utilities noted also that some current signatories to the program may still exit, but added that “the participants signing this statement represent only a portion of the utilities committed to WRAP’s long-term success.”

“By stepping forward now, we intend to demonstrate early momentum, provide confidence to those still weighing their options and signal that WRAP will continue to deliver value as it enters its binding phase,” the organizations wrote.

“We remain confident in the fundamental premise of WRAP and the value it brings,” WPP said. “Over the next two years, in addition to onboarding new members, we will focus on changes and updates to optimize the program and respond to concerns raised by participants and stakeholders. This will allow WRAP to maximize the benefits it delivers when binding operations begin and help address the growing challenge of resource adequacy.”

PJM MRC/MC Briefs: Sept. 25, 2025

Stakeholders Endorse Widened Provisional Interconnection Service

PJM’s Markets and Reliability Committee endorsed by acclamation a set of manual revisions to expand when a new resource could be granted provisional interconnection service to allow for early operation when it becomes capable of injecting a portion of its output while its network upgrades still are under way. 

PJM Director of Interconnection Planning Donnie Bielak said the RTO brought the changes against a backdrop of an increasing number of emergency procedures with the objective of making as many resources as possible available to dispatchers in the coming years.  

The Planning Committee endorsed the quick fix proposal Sept. 9, including an issue charge to explore creating a process for PJM to proactively identify resources that could take advantage of provisional service. (See PJM Stakeholders Endorse Expansion of Provisional Interconnection Service.) 

Donnie Bielak, PJM | © RTO Insider LLC

Interim deliverability studies are conducted to determine if resources that have been completed, but are awaiting completion of assigned network upgrades, can operate without triggering transmission violations.  

Under current rules, if a unit cannot reliably inject its full output, it is denied provisional service. The proposal would create a second round of analysis to determine if a resource not capable of full operations could provide output at a fraction of its nameplate. If so, an operational guide would be produced to inform dispatchers how the unit could be operated. Project developers must request, and pay, for PJM to conduct the studies, which would not be changed by the proposal. 

Bielak said PJM is processing studies for the 2026/27 delivery year and is planning to present the results in the next few weeks. If the change is approved, it will be applied to the results and no further action is needed from developers who already have sought provisional service for that year. 

Stakeholders debated an amendment PJM proposed to add the phrase “consistent with PJM’s governing documents” to language outlining the information the RTO would publish about individual requests for interim deliverability studies, including the location and provisional output desired. After a discussion with stakeholders, PJM revised the amendment to instead state that applicants “agree to waive their rights to confidential treatment of such requests” and agree to the publishing of that information. 

Proponents of requiring the disclosures argued transparency is needed around the requests to ensure applicants would not have insider information about the resources likely to be in operation months before other market participants become aware. 

Independent Market Monitor Joe Bowring said the proposal is a great step forward on PJM’s part but contended that the resource owner should be obligated to perform when dispatched by PJM. Without such a requirement, the RTO could not rely on any possible reliability benefit from provisional resources. 

Committee Approves Changes to DR Participation in Regulation Market

Stakeholders endorsed a proposal to allow demand response resources to enroll to provide regulation-only service when there are energy injections at the point of interconnection. (See “PJM Reviews Proposal on Regulation Resources at NEM Sites,” PJM MRC/MC Briefs: Aug. 20, 2025.) 

The changes would allow a DR resource to participate in the regulation market when there is no load or a net injection at its POI with the consent of its relevant electric distribution company memorialized in a net energy metering agreement. 

Intelligent Generation CEO Jay Marhoefer said the proposal would restore a mode of DR participation that was lost in previous FERC orders on the regulation market. 

During the July 9 Market Implementation Committee meeting, he said some EDCs changed their tariffs in a manner that inadvertently prevented behind-the-meter storage from participating in the regulation market while injecting. (See “Stakeholders Endorse Changes to Storage Participation in Regulation Market,” PJM MIC Briefs: July 9, 2025.) 

Bowring said advancing one element of PJM’s Order 2222 compliance filing would provide special treatment for one class of market participants and open the door for others to ask for expedited treatment for their preferred components. 

“Clearly the FERC thought it was reasonable to do this, but in 2029,” he said. 

Stakeholders Vote for Cost Allocation for DOE Emergency Orders

The MRC and Members Committee endorsed a proposal to define how PJM would determine how to allocate the costs associated with operating generators under a DOE emergency order. (See PJM Stakeholders to Examine Rules for Future DOE Emergency Orders.) 

For orders addressing an RTO-wide resource adequacy issue, PJM would use a pro forma cost allocation that splits the costs a resource owner incurs under the emergency order across all RTO load based on each entity’s share of the monthly unforced capacity obligation. The pro forma approach would be used only when resource owners and PJM agree to use the deactivation avoidable cost credit (DACC) compensation model.  

If the RA concern affects specific regions, PJM would initiate an “abbreviated stakeholder consultation” with the goal of drafting Reliability Assurance Agreement revisions addressing cost allocation. The process would pick up where the PJM DOE 202(c) Cost Allocation Senior Task Force left off on identifying recommended approaches for the RTO’s Board of Managers to consider.  

If there is an emergency order unrelated to RA, PJM would initiate a Critical Issue Fast Path (CIFP) process, similar to how it proceeded after the U.S. Department of Energy ordered Constellation Energy and PJM to keep the Eddystone Generation Station outside Philadelphia online past its scheduled deactivation at the end of May. (See FERC Approves Cost Allocation for Eddystone Emergency Order.) 

The abbreviated stakeholder consultation would be considered a workshop under a new section to be added to Manual 34: PJM Stakeholder Process, with voting at the MC. The pro forma cost allocation would be added to the RAA under Section 7.2A Responsibility to Pay 202(c) Charge. 

Denise Foster Cronin, EKPC’s vice president of federal and RTO regulatory affairs, said she is glad PJM adopted a wider perspective on how it could proceed under different scenarios, but argued the proposal remains flawed without any way for PJM to determine the cause of an RA emergency order without direction from DOE. She said the department is unlikely to delve into the drivers of RA needs. 

Sophia Dossin, of Middle River Power, said the RTO should think about how to proceed if there is disagreement between PJM and stakeholders about whether to move ahead with the pro forma. 

Phil Sussler, of the Maryland Office of People’s Counsel, argued stakeholders should have an opportunity to gain more insight into what costs can be recovered under the DACC methodology. He said units whose deactivations are being deferred are more likely to be older and run into unexpected problems that substantially increase costs. Consumer advocates protested PJM’s cost allocation filing for Eddystone, arguing that the compensation should be subject to FERC oversight rather than a bilateral agreement between PJM and the resource owner. 

Responding to a stakeholder question, PJM’s Lisa Morelli said the costs to keep Eddystone online in June were covered by the revenues it received in PJM’s markets. 

Regulation Market Manual Revisions Approved

The committee endorsed by acclamation a revision to Manual 11: Energy & Ancillary Services Market Operations to reflect the adoption of a tracking metric for the amount of regulation a resource should be providing. The change was included in the first phase of PJM’s redesign of the regulation market; however, language detailing the calculation of lost opportunity cost credits did not reflect the tracking regulation set point. PJM’s Brian Chmielewski said the changes are to be rolled out at the beginning of October. (See “Update on Regulation Market Design,” PJM OC Briefs: April 3, 2025.) 

Members Committee

Stakeholders Endorse Revisions to CIR Transfer Filing

PJM’s Members Committee endorsed a set of revisions to a proposal to rework how capacity interconnection rights (CIRs) can be transferred from a deactivating resource to a replacement following FERC’s rejection of the original tariff changes (ER25-1128). (See PJM Preparing Alterations to Rejected CIR Transfer Proposal.) 

The changes to the proposal center on two exemptions from the commercial operational date requirements for the replacement resource — one for resource types known for long development timelines and a one-time allowance for an indefinite COD delay. In its Aug. 8 denial, the commission found that allowing developers deferrals that could last years could open the door for owners to withhold CIRs by tying them up in theoretical planned resources. 

The new COD requirement would mandate the replacement unit be in service by the greater of four years from the submission of the replacement generation application or three years from the deactivation date of the original resource. An amendment offered by Vistra added a requirement that the resource be online within three years of its planned in-service date and reserves the right for a developer to seek a FERC waiver from the COD requirements. 

Vistra’s Erik Heinle said the change provides room for PJM and developers to negotiate the milestones. 

PJM’s Jason Shoemaker said staff designed the revisions around the Reliability Resource Initiative (RRI), a one-time window PJM opened to allow 51 resources to have their interconnection studies processed under Transition Cycle 2. Like the CIR transfer proposal, RRI was intended to allow resources likely able to come quickly into service to have their interconnection process expedited. 

The larger proposal aims to speed the process for studying whether a replacement resource requires network upgrades and offer an interconnection agreement within nine months of a request to transfer CIRs. A resource would be permitted to pursue the expedited process even if minor network upgrades are identified, and a categorical prohibition on storage resources would be eliminated. (See PJM Stakeholders Endorse Coalition Proposal on CIR Transfers.) 

Discussion with Board Members on Large Load Growth

The Board of Managers discussed with stakeholders an ongoing CIFP process addressing large load growth, continuing a standing item on the MC agenda that board Chair David Mills sought in an effort to improve the transparency and accessibility of the body. 

Opening the conversation, Mills said much of the CIFP meetings thus far have focused on the RTO’s non-capacity backed load (NCBL) and bring-your-own generation proposals, but many of the comments submitted at the onset of the process focused on the load forecast and the need to ensure understanding of the scale of the problem. He questioned how the membership prioritizes improving the load forecast relative to solutions focused on serving large loads. 

Asthana said PJM has removed NCBL from its CIFP proposal based on opposition from much of the membership. Materials for the Oct. 1 CIFP meeting say PJM is shifting the focus to a price-responsive demand model similar to a voluntary NCBL model and a parallel expedited interconnection queue. 

Heinle said the load forecast will dictate the range of solutions stakeholders should focus on, scaling to the size of the problem, and recommended that PJM integrate a “ground-up” perspective on the amount of data center load expected in the region. He said there seems to be an assumption that every data center load is coming to PJM, even while that industry sees many of the same supply chain issues plaguing the electric industry. 

Greg Poulos, executive director of the Consumer Advocates of the PJM States, said this is one of the biggest discussion points stakeholders face, with load growth expected in the next five to seven years exceeding the total load served by CAISO. If those estimates are accurate, he said he’s not aware of any changes PJM can make to bring on sufficient generation in time. 

Exelon’s Alex Stern said the load forecast is an important data point but is one of many the states and utilities use to guide their decisions around ensuring load is served. He said there has been a great deal of work done already at the Load Analysis Subcommittee to improve the transparency of the data presented there, as well as on the large load adjustment submission process. 

BOEM Seeks to Pull Back Atlantic Shores OSW Approval

The Bureau of Ocean Energy Management is seeking to remand its earlier approval of the construction and operations plan for Atlantic Shores Offshore Wind.

The New Jersey project already is on at least a temporary pause. Neither construction nor operation will happen anytime soon, because it terminated its financial agreement with New Jersey, half of the partnership quit the joint venture and the Environmental Protection Agency has remanded its air permit for further review. (See Developer Shelves Atlantic Shores, Seeks to Cancel ORECs.)

The Sept. 26 court filing further clouds the future.

The Jersey Shore anti-wind group Save Long Island Beach Inc. applauded the court filing Sept. 27: “It’s a rare and important moment. It confirms the seriousness of the technical and scientific concerns we’ve raised, for many years now — especially regarding the impacts to endangered North Atlantic right whales and cumulative construction and operation harms to the North Atlantic right whale migration corridor.”

An Atlantic Shores spokesperson said Sept. 29: “Atlantic Shores is disappointed by this course of action and has no further comment.”

All 11 of the offshore wind projects approved by BOEM received their approvals during the Biden administration.

Hours after the start of his second term, President Donald Trump set about undoing his predecessor’s work. He or his agencies have canceled future development, halted the progress of existing early-stage projects and moved to block construction of approved middle-stage projects.

One of the 11 projects is complete, one was canceled by the developer in 2023 and five are under construction. The Trump administration has motioned in court to remand the approvals of the other four: Atlantic Shores, New England Wind, SouthCoast Wind and US Wind.

Save Long Beach Island Inc. sued the federal government July 25 in U.S. District Court for D.C. (1:25-cv-02211) seeking to overturn approval of Atlantic Shores project.

The Sept. 26 federal filing is similar to the three other motions to remand: It indicates that BOEM wants to re-examine its earlier approval because it might not have fully accounted for all of the impacts of Atlantic Shores in its initial review.

BOEM intends to conduct a full review and then approve, disapprove or approve with conditions the Atlantic Shores construction and operations plan it approved Oct. 1, 2024, during the waning days of the Biden administration.  As such, the wind opponents’ lawsuit should be stayed until conclusion of the review, the federal government asserts, because their case may well become moot.

The Trump administration has shown a sustained antipathy toward offshore wind development. However, the Sept. 26 federal motion asserts Atlantic Shores would merely be speculating if it is worried that BOEM might not reapprove the project.

And if Atlantic Shores did not like the outcome of the review, the Department of Justice wrote in its motion, it is free to file a challenge, assuming all jurisprudential requirements are met.

The Department of Justice further asked the court not to impose any artificial deadline for the remand process, as it might affect BOEM’s ability to conduct a proper and thorough analysis.

PJM Members Confirm 2 Board Nominees; States Call for Governance Overhaul

The PJM Members Committee overwhelmingly voted to appoint Robert Ethier, a former ISO-NE executive, and Le Xie, faculty co-director of the Power and AI Initiative at the Harvard School of Engineering and Applied Sciences, to fill two vacant positions on the RTO’s Board of Managers.

Both nominees were elected with 97% sector-weighted support during the MC’s Sept. 25 meeting. (See Robert Ethier, Le Xie Nominated for PJM Board.)

Their ascension brings the board back to its full 10-member roster after the membership declined to re-elect Chair Mark Takahashi and Terry Blackwell during the 2025 Annual Meeting in May, citing transparency concerns and frustration with the capacity market design. (See PJM Stakeholders Reaffirm Board Election Results.)

In the weeks leading up to the election, several governors of PJM member states requested that PJM’s Nominating Committee consider naming former FERC Commissioners Mark Christie and Allison Clements to be considered for the board. During a multistate technical conference on Sept. 22, Virginia Gov. Glenn Youngkin called for PJM to reopen the nomination process. (See Governors Call for More State Authority in PJM.)

Le Xie | Harvard John A. Paulson School Of Engineering And Applied Sciences

Prior to the MC vote, Philip Sussler, of the Maryland Office of People’s Counsel, said PJM needs deep governance reform, and holding an election on board candidates without accompanying statements from the RTO about how it will change its path is disappointing.

Following the election, Xie told stakeholders that he aims to begin his tenure with a comprehensive listening tour across the region. He said PJM is facing complex, urgent challenges that will require the membership to think about what unites them.

Xie began teaching at Harvard in 2024, before which he was a professor at Texas A&M University starting in 2010. He previously held roles at the Massachusetts Institute of Technology and the University of California, Berkeley. He also is a fellow and distinguished lecturer at the Institute of Electrical and Electronics Engineers and has served as an editor for the group’s Transactions on Power Systems journal.

During his more than 24 years at ISO-NE, Ethier filled three vice president positions — system planning, market operations and market development — between 2008 and 2024. He now is a principal at Stickney Brook Consulting, based in Florence, Mass.

Technical Conference Calls for Overhaul of PJM Governance

Headlined by governors calling for a greater role for the states in PJM decision-making, panelists participating in the multistate technical conference debated the future of the RTO’s governance structure and whether it is prepared to rise to the challenge of accelerating data center load.

Former FERC Chair Mark Christie said a crisis of confidence should be apparent when both the governors of Pennsylvania and Virginia speak about the need to either reimagine PJM or a future outside of it. The issue is not economic or technical, he said, nor does it lie with the experts at Valley Forge, but a problem of governance.

PJM started as a power pool, then morphed into a system operator focused on coordinating power flows. Over time it has been empowered to take a more proactive role in planning resource adequacy as well. Christie said that has put it in the position of becoming a policymaking body when it determines how to allocate transmission costs and how it integrates the load forecast into the variable resource requirement curve that sets capacity prices.

Legislation over the Transource Independence Energy Connection transmission project underscores that point, Christie said, with the courts finding that the Pennsylvania Public Utility Commission violated the Constitution’s Supremacy Clause in denying permits for the project. If states cannot make their own determinations on the need for transmission within their borders, he said, it underlines the governors’ message that the states need more of a role in PJM decision-making.

“The states in PJM simply do not have a substantive role in PJM governance,” he said.

Christie cautioned that his message isn’t that state legislatures should be running PJM; it is to recognize that the question of how to address the interconnection of large loads and the associated costs is a technical and policy question. At a minimum, PJM states should have the same Federal Power Act Section 205 filing rights as member states of SPP and MISO, he said.

Joshua Macey, associate professor at Yale Law School, said granting Section 205 filing rights to the states is one of the most powerful governance changes that could be made. He said FERC defers to the entity filing a tariff change under Section 205 so long as it falls within a zone of reasonableness, while the bar for making changes under FPA Section 206 is much higher.

Macey said filing rights are not the end of the conversation between PJM and the states, which hold their own negotiating power through their ability to liquidate and restructure utilities to no longer be part of an RTO. He said there is a risk in taking too much autonomy away from PJM, which does hold deep expertise on technical issues. He said there often are actuarily correct cost allocation methodologies that have not been adopted because of political fighting.

During a “fireside chat” with Clements during the conference, PJM CEO Manu Asthana said the RTO does not hold the unilateral power to grant the states Section 205 filing rights; that would have to be endorsed by the MC and approved by FERC. He said governance reform is a conversation worth having, but there should be a parallel focus on the actual rule changes that are needed to address the resource adequacy problem in front of PJM.

Manu Asthana, PJM CEO | © RTO Insider 

Panelists also debated whether states should be granted voting rights in PJM’s stakeholder process, with some arguing it would grant them both a voice and skin in the game.

Macey argued that PJM’s stakeholder process favors incumbent asset owners, through dominance of the five membership sectors at the MC and holding even more power in the lower committees where votes also are allowed for affiliates.

Stacey Burbure, vice president of FERC and RTO strategy and policy for American Electric Power, said her company owns more than a quarter of the transmission in PJM, but holds only 2% of the votes.

Vincent Duane, principal at Copper Monarch and former general counsel for PJM, said the RTO already is ungovernable, and adding more votes to an already crowded body likely would leave the states disappointed. Instead, he said the focus should be on developing strong executive decision-making. He said transmission owners should have a substantial role because of their place at the intersection of private capital and accountability to their states.

During his time at PJM, Duane said he regularly received questions from board members about who they owed their fiduciary duties to, and he found it difficult to give a specific answer. Until that can clearly be determined, along with the question of who manages the stakeholder process, he argued governance should take a back seat.

Dan Scripps, chair of the Michigan Public Service Commission, said MISO’s requirement that one seat on its Nominating Committee be appointed by its member states allows them to have a seat at the table, rather than criticize the results from the sidelines.

“If you’re locked out, you end up throwing rocks from outside,” he said.

Maryland Del. Lorig Charkoudian said legislators and public utility commissions are charged with managing the resource mix in each state, but their efforts can be undermined by PJM decisions, which are made through an opaque stakeholder process. She said the primary cause of instability in PJM’s market has been an interconnection queue unable to keep up with the pace of new requests. Now that PJM has put reforms in place to speed processing those requests, she argued the blame should not be shifted to state clean energy efforts, but to federal policies creating barriers to developing wind and solar generation.

Without more confidence that the transmission projects planned by PJM are truly necessary for reliability, she said it will be a hard sell to convince elected representatives to advocate to skeptical voters.

Duane said PJM is one of the most transparent organizations he has been a part of, with a deluge of information published. He said the complexity of those postings should not be mistaken for a lack of transparency.

PJM Stakeholders Discuss Governance

The MC and board discussed the issues raised during the technical conference during the Sept. 25 meeting — a standing agenda item recently established by board Chair David Mills in response to the calls for more transparency and accessibility to board members.

John Horstmann, senior director of RTO affairs at AES Ohio, said he heard a lot of criticism and finger-pointing at PJM’s leadership, but little in the way of solutions to the issues the states and RTO face together. He said there seems to be little interest in being involved in the stakeholder process to advance their causes.

“The real issue is load is growing faster than we can make supply … and they don’t like it, but I didn’t hear how they would fix it if you handed them the keys today,” he said.

He said he did not see how creating a governors’ organization is going to be any different from the deference PJM and its membership already provide to the Organization of PJM States Inc. (OPSI).

Manager Matt Nelson said the governors want to bring load growth to their states and see it interconnected at the least cost.

“There’s a real goal of making sure we can show the value of PJM, and that isn’t just PJM itself but this whole process. And when I hear governance, I hear them say they want a way to engage in this process,” he said.

Sophia Dossin, manager of regulatory affairs for Middle River Power, said the growth of large load customers felt like a hot potato at the technical conference, and while PJM will have a role to play in how to manage that growth, it is limited by its jurisdiction.

“Everybody wants the benefits; nobody wants the cost,” she said.

Dossin also said the membership should consider what Christie said at the conference: that individuals the PJM membership might call “consumers” are referred to as “voters” by elected officials. Communications between PJM and state leadership would be well served by approaching those conversations as speaking to voters, she said.

OPSI Executive Director Gregory Carmean said PJM should provide easily understandable information about rule changes being considered. Pointing to the slate of Quadrennial Review proposals voted on during the Sept. 25 meeting, he said a short description could have been provided on each, along with a statement on how it would benefit the public.

Asthana told the MC that his interpretation of what states are requesting from PJM is a measure of control over the RTO and lower prices, which he said the membership should keep in mind and consider how those goals can be addressed. That control is not PJM’s to give, he said, and instead is under the purview of the membership, with management considering how to facilitate that conversation.

To address the need for a 10-fold increase in the amount of capacity coming online, he said solutions spanning the state and federal jurisdictional boundary will be needed, creating an opportunity for PJM to partner with the states in a different way than it has in the past.

Latest N.Y. Renewables Solicitation a Race Against Time

New York has launched a renewable energy solicitation enlisting multiple agencies to expedite the process and get projects approved while they still can qualify for federal tax credits. 

Developers with shovel-ready projects are the target audience in the new request for proposals. Gov. Kathy Hochul announced Sept. 26 that she is directing state agencies to work together to advance as many of them as possible as quickly as possible. The whole-of-government approach is intended to streamline permitting, interconnection, financing and contracting processes. 

Applications are due Oct. 21, and final proposals are due Dec. 4. Initial award notifications are expected in February 2026. 

This time frame leaves a narrow margin before a key Trump-era deadline for solar and wind projects: They must begin construction by July 3, 2026, to qualify for 45Y and 48E production and investment credits. 

The New York State Energy Research and Development Authority, which manages the state’s renewables solicitations, said this ninth large-scale, land-based RFP is expected to result in a $5 billion investment in projects with a combined capacity of at least 2 GW. 

A NYSERDA spokesperson could not estimate how many projects are in so advanced a stage of planning that they could begin construction within a few months of a contract award. But many New York projects were paused during the financial turmoil that hit the renewable energy sector in 2023. 

A state database of large-scale renewable projects over the past two decades provides the tally: Of the 311 projects listed through Aug. 28, 112 are completed or operational, and their combined rating is only 2.78 GW. The 65 projects under development would have a capacity of 8.21 GW. The 134 projects listed as canceled could have produced 17.52 GW. 

The disparity is not as great as it seems: Some of the projects listed as “canceled” were not canceled at all; their contracts were. The projects themselves were rebid in later solicitations, won new contracts and are now “under development.” 

Meanwhile, NYSERDA cites yet another number: 102 projects totaling 9.7 GW in operation or under development. 

But even if the aggregate totals of the numbers are mismatched, the numbers themselves paint a picture of a renewable energy campaign that has had more than its share of setbacks. 

The latest setback is the re-election of President Donald Trump, with his embrace of fossil fuels and his active efforts to thwart renewables. 

New York is not onboard with this, Hochul said in a news release: “While the federal government takes us backward on energy policy, New York will not be thwarted in its commitment to clean energy.” 

But the loss of 45Y and 48E may have a greater impact than the rhetoric on either side of the fossil/renewable debate, as it will make an already expensive state more costly for renewables development. So the state is racing to beat the clock and take advantage of the credits. 

Marguerite Wells, executive director of the Alliance for Clean Energy New York, told RTO Insider the organization is happy with the solicitation and the details of it. Her members have been racing to buy equipment and looking for ways to start work, both in hopes of beating the July 3 cutoff date for tax credits. 

Wells said it was a bold move by Hochul to order a whole-of-government effort to fill the state’s renewable energy pipeline, as it might raise the Trump administration’s ire with her and the state. 

But it was a necessary move, Wells said, because while the state agencies central to energy development have been working as a team to expedite renewables, some of the adjoining agencies have been focusing on their own core responsibilities rather than their limited role with renewables, which has slowed down the regulatory process. 

“And having it be not just something that agencies are quietly doing but something she is exhorting them to do,” Wells said, “actually really helps the private sector also encourage their funders to keep investing, because there’s a lot of people who are skittish about the U.S. market broadly and New York specifically.” 

Wells confirmed that there has been a significant attrition rate for developers recently: Roughly a third of projects in the NYISO interconnection queue have dropped out in the past six months. 

But this is not entirely from the chilling effect the Trump administration’s policy changes have had on the industry, she said. It is more from the changes NYISO implemented for FERC Order 2023 and its own parallel reforms, Wells said, which penalize developers for parking immature projects in the queue before they are ready to commit to construction. 

Many have dropped out for that reason, she said, although the reason some are not ready to commit is Trump’s anti-renewables stance. 

“Some of the withdrawals are delays, deferments if you will, and some of the withdrawals are genuine cancellations,” Wells said. “I couldn’t say what percentage are which, because I truly don’t know, but I think it’s some of each.” 

Vistra to Build 2 Gas Units in Oil-rich Permian Basin

Vistra says it will build two new advanced natural gas power units at its Permian Basin Power Plant in West Texas, adding 860 MW of capacity to a petroleum-rich region that is rapidly undergoing an electrification transformation. 

The two units will triple the Permian Basin facility’s current capacity from 325 MW to 1,185 MW. The site currently has five combustion turbines, each about 65 MW.  

The new gas units are part of Vistra’s plan to add up to 2,000 additional MW of gas-fueled dispatchable power in ERCOT by 2028.  

“Given Vistra’s fleet, interconnections and experience in improving, redeveloping and building power plants, we are uniquely positioned to deliver solutions that provide reliable, affordable power to our residential customers, as well as industries across Texas and the United States,” Vistra CEO Jim Burke said in a Sept. 29 press release. 

The Irving, Texas-based company said that in 2024, it identified more than $1 billion worth of potential capital additions in generation capacity within the ERCOT market, if market conditions were “supportive.” It added about 1 GW of new generation capacity between 2020 and 2023 by increasing the gas fleet’s output and bringing three new projects into commercial operation. 

“Vistra’s bold investment in the Permian Basin will reinforce our state’s electric grid, spur jobs and drive regional economic growth for years to come,” Texas Gov. Greg Abbott said in the release. 

Vistra said it has made “significant progress” on other projects announced since the summer of 2024, including:  

    • Completing upgrades at gas plants that have added more than 400 MW of capacity across its Texas fleet.
    • Plans to repower its Coleto Creek Power Plant — a coal plant scheduled for retirement in 2027 — as a 630-MW gas-fired unit.
    • Nearly completing a 200-MW solar project on the site of a retired and reclaimed lignite mine, with commercial operations expected by year’s end. 

When the projects are completed, Vistra will have invested nearly $2 billion to add about 3,100 MW of new generation capacity in the state since 2020.

Nuclear Power PPA Signed

Vistra also said in an 8K filed Sept. 29 with the Securities and Exchange Commission that it has entered into a 20-year power purchase agreement with a “large, investment-grade” company for 1,200 MW of power from its Comanche Peak nuclear plant. 

The company expects power delivery to begin in the fourth quarter of 2027 and ramp to full capacity by 2032. 

Vistra declined further comment on the counterparty or the PPA. A spokesperson said the counterparty is finalizing its plans and it will share further details when they are available. 

Bank of America Securities said in a research report that it estimates the PPA will price around $105 to $120/MWh, with a midpoint of about $112/MWh. 

Trump Administration Takes Actions to Grow Coal’s Role on the Grid

The Trump administration has announced coordinated actions across three cabinet-level agencies to help boost the role of coal in the country’s energy system.

The Department of Energy announced a $625 million investment to reinvigorate the coal industry by boosting production and supporting coal communities, which is in line with executive orders President Donald Trump signed earlier in 2025. (See Trump Seeks to Keep Coal Plants Open, Attacks State Climate Policies.)

“Beautiful, clean coal will be essential to powering America’s reindustrialization and winning the AI race,” Energy Secretary Chris Wright said Sept. 29 in prepared remarks. “These funds will help keep our nation’s coal plants operating and will be vital to keeping electricity prices low and the lights on without interruption. Coal built the greatest industrial engine the world has ever known, and with President Trump’s leadership, it will help do so again.”

The funds include $350 million for coal plant recommissioning and retrofits that the department said will help modernize power plants and provide near-term reliability and capacity. Another $175 million is going to rural capacity and energy affordability projects that burn coal.

DOE also is putting $50 million toward the development and implementation of advanced wastewater management systems that demonstrate scalable, cost-effective systems that can extend coal plant life and cut operational costs. Another $25 million is going to help coal plants implement dual-fuel capability, and $25 million will go toward developing and testing natural gas co-firing systems.

Meanwhile, EPA is providing steam electric power generation more time to comply with existing effluent limitations guidelines under the Clean Water Act to help meet growing demand. The action is expected to save $200 million annually in electricity costs, the agency said.

EPA Administrator Lee Zeldin also announced an Advance Notice of Proposed Rulemaking looking into changes to the Clean Air Act’s Regional Haze Rule. EPA said that after years of feedback, “it is clear that the regional haze program is broken and needs significant revisions.”

And the Department of the Interior announced it is opening 13.1 million acres of federal lands to lease for coal mining, lowering the royalty rates for mining and fast-tracking projects around the country.

“By reducing the royalty rate for coal, increasing coal acres available for leasing and unlocking critical minerals from mine waste, we are strengthening our economy, protecting national security and ensuring that communities from Montana to Alabama benefit from good-paying jobs,” Interior Secretary Doug Burgum said in a statement. “Washington doesn’t build prosperity; American workers and entrepreneurs do, and we’re giving them the tools to succeed.”

Reactions to the three agencies’ actions were mixed, with those who rely on coal plants praising them for helping to meet rising demand affordably, and others including leading environmentalists saying they would increase pollution and power prices for consumers.

“As electricity demand skyrockets, smart energy policies that help keep the lights on are more important than ever,” NRECA CEO Jim Matheson said in a statement. “Today’s announcements give electric co-ops important flexibility to reliably meet growing energy needs at a cost local families and businesses can afford. In recent years, misguided energy policies have forced essential power plants off the grid, while electricity demand surged. We thank the administration for moving swiftly to respond to growing energy needs with an emphasis on new tools, flexibility and a pro-energy policy agenda.”

Environmental Defense Fund Director and Lead Counsel Ted Kelly said that subsidizing coal would saddle families with the cost of old power plants from the last century.

“This is not how you lower household costs, promote healthy communities, win the AI race or stay competitive in the 21st century,” he said in a statement. “Today, solar, wind and battery storage are the cheapest and fastest ways to bring new power to communities and businesses. It makes no sense to cut off your best, most affordable options while doubling down on the most expensive ones.”

BPA Provides More Details on 2028 Residential Exchange Program

The Bonneville Power Administration is developing the next phase of its Residential Exchange Program (REP) and presented proposed provisions during a Sept. 24 workshop. 

The REP helps residential and farm customers of higher-cost Pacific Northwest utilities — mainly investor-owned utilities — access lower-cost federal power reserved for public power customers. The REP is managed under a settlement that expires Sept. 30, 2028, and the agency is developing the next phase of the post-2028 REP agreement. 

The Sept. 24 workshop focused in part on the REP’s in-lieu provision, which means that “instead of purchasing any amount of power offered by a utility, BPA may acquire power from other sources and sell that power to the utility if the cost of such power is less than the utility’s [average system cost],” according to BPA’s presentation. 

Under the proposed post-2028 REP in-lieu provision, BPA must provide notice to the utility 10 months prior to implementing or scheduling the in-lieu power. Also, once BPA issues the notice, the IOU has 30 days to opt out of the in-lieu power.

The notice would include the amount of in-lieu power expressed in monthly increments in MW and MWh, how much BPA paid to acquire the in-lieu power, duration of the in-lieu power sale, source of the power and the customer’s point of delivery, according to the presentation. 

The Northwest Power Act established the REP, which is structured as a power exchange where utilities with high-cost resources sell power to BPA at their average system cost (ASC) of resources, and BPA, in turn, sells the same power quantity back to the utilities at BPA’s cost of power. No actual power is transmitted; the deal is instead treated as a financial transaction, according to BPA documents. 

Specifically, the agency pays the IOU the net difference between the two sales, multiplied by the utility’s qualifying residential and farm load. The cost benefits of the exchange are passed on to the utility’s retail residential and farm consumers as a credit on their power bill. 

Public Power’s Input

In a Sept. 17 letter, a group of public power organizations and utilities said BPA’s proposal to implement the post-2028 REP through a financial settlement rather than physical delivery of power “is consistent with BPA’s statutory obligations and authorities.” 

“Also, the practical constraints with implementing the REP through physical deliveries appear daunting, if not impossible to overcome,” the authors said. 

The organizations also wrote that consumer-owned utilities have “first right to federally generated power.” 

“BPA’s proposal to implement REP through a financial settlement ensures that the statutory preference rights of the COU’s are preserved notwithstanding the purchase and exchange sales authorized under Section 5(c) of the Northwest Power Planning and Conservation Act, as intended by Congress when the act was passed in 1980,” the authors said. 

The organizations also said they are unable to take a stance on duration, activation, termination and suspension issues discussed during a Sept. 11 workshop. The letter stated that “consideration of these issues hinges on their alignment with rate periods and ASC submittals.” 

“Accordingly, at this time, public power is unable to take a position without a better understanding of how important aspects of BPA’s financial policies will be implicated, as well as potential linkages to the ‘in-lieu’ provisions in the Residential Purchase and Sale Agreement (RPSA),” the letter stated. 

“In particular, if the Cost Recovery Adjustment Clause, Financial Reserve Policy Surcharge or Reserves Distribution Clause are triggered, a significant shift in benefits could occur,” public power argued. “We would like to better understand the impact of these tools on the REP as it relates to duration, activation, termination and suspension issues, including whether investor-owned utilities will share in the costs and benefits of BPA’s risk mitigation tools for power services.” 

BPA will release a draft of the RPSA on Oct. 29 for comment and input. The agency will hold the next workshop Oct. 9. 

Power Play: Pragmatism, Adaptation and a Touch of Wishful Thinking at Climate Week NYC

New York, frenetic at the best of times, bordered on frantic when Climate Week coincided with the U.N. General Assembly meeting in September.

While the U.N. addressed climate in its hushed halls, experts and pundits at hundreds of Climate Week events scattered across dozens of locations analyzed every aspect of it. Like a subway running beneath this melee of meetings, there were common themes that connected the many panels and events I attended: Old goals were quietly dropped, new challenges accepted and an AI-led future imagined.

Note: Many panels were under the Chatham House Rule or on background only, so some ideas and quotes below are not attributed. Just know that all the speakers had lengthy titles, impressive biographies and well-known employers.

Hello ChatGPT, Goodbye 1.5 Degrees

This was my first climate event where there was little mention of the Paris Accord goal of limiting the global average temperature increase to 1.5 degrees Celsius above pre-industrial levels. “One-point-five” used to be a term so common it was rarely explained. IYKYK — and Climate Week attendees know. This year, the few times it was used, it was in a casual aside about the target there was no chance of meeting, or the limit that already may have been exceeded.

Only two years ago, many in the climate space called for radical emissions cuts to reach the goal. Today, the consensus among the business end of the climate community — asset managers, developers, business leaders and consulting giants — is that the goal is about to be in our rearview mirror, courtesy of the rise of AI. U.S. political headwinds and two more years of too little action? Just speed bumps on the way.

“The net-zero, 1.5-degree scenario is now a mathematical exercise. We could not get there from a policy perspective,” the leader of an energy analytics organization said. “We retain it because it’s important to look at it, but it’s not something that we were able to achieve other than [through] a mathematical formula.”

Move over Mitigation, the Age of Adaptation has Arrived

The other common climate term noticeably absent was mitigation. It used to be that mitigation was king and adaptation was a quitter’s word, one for those who didn’t believe we had the skills and will to pull humankind out of its climate nosedive.

Today, adaptation is a necessary evil needed to cope with the damage being done to the planet. It is not that everyone won’t do their best to mitigate, but it’s no longer enough.

Dej Knuckey

“I’d like to avoid being seen as the pessimist in the room,” an in-house climate scientist at an analytics firm said. “We can turn this problem around and talk about the benefits of adaptation, or the benefit-to-cost ratio for adaptation. A recent study by JP Morgan has calculated that the reduced or avoided risk is between $2 and $43 per dollar invested in adaptation. It’s a huge opportunity.”

If you are building infrastructure today, the head of infrastructure at one of the world’s largest asset managers said, you might as well make it strong enough to withstand a future riddled with climate disasters. In the emerging markets, for example, he said it was “significantly cheaper to build something … to an international standard that will withstand the expected impacts of climate change that will come over the next couple of decades. We build to a certain standard that we hope we don’t need, but hurricanes have become stronger, fire risk is greater.”

Electrical transmission and distribution assets should be built with community vulnerability in mind, he said, so they not only could provide service during extreme climate events but also would not cause those disasters.

Business discussions about a post-1.5, adaptation-focused world were positioned as “pragmatic.” The word was used with a touch of guilt: not that they wanted to go gentle into that good night, but it seemed futile to rage, rage against the dying of the light. In an unwinnable war, pragmatists should focus on minimizing the damage … and perhaps even profiting from hardening the infrastructure ahead of the impending crises.

AI: Energy’s Frenemy

The rise of AI and the massive data centers that power it are the culprits behind the surrender of the target. But AI is seen as both a power-hungry enemy and an efficiency friend.

At Deloitte’s three-day Climate Week Horizons conference, data centers were cited as driving demand for electricity.

“There is no doubt that AI is creating the single largest [rise in] energy demand in decades,” said Martin Stansbury, principal and U.S. power, utilities and renewables risk and financial advisory leader at Deloitte. “And the real question is: Can we build it fast enough? Can we build it clean enough, and can it be resilient enough for the market?”

“By our analysis, we see about a five times growth in data center power demand by 2035,” Kate Hardin, executive director at Energy, Resources and Industrials Research, said at the Deloitte event. She said industrial electrification was the other major trend driving demand.

On the flip side, AI was cited as the potential hero for optimizing everything from buildings to ports … as well as the grid itself. While many speakers worried about how quickly generation could be built to service AI data centers or how the related demands on water supply would be met, others believed AI would unlock more energy savings than the data centers themselves would consume. Ultimately, AI will be a self-correcting challenge.

Speaking at Axios House, Tom Steyer, the billionaire co-executive chair of Galvanize Climate Solutions and former Democratic presidential candidate, talked about AI’s ability to make the grid substantially more efficient.

“If you look at renewables in this country, the big pain points are permitting and access to the grid,” he said, citing a discussion with a Californian investor-owned utility who told him it took 12 years to permit and build a new distribution line.

“The grid in California is 32% efficient. The grid in the United States is 42% efficient. We have the ability now, using real-time information and AI protocols, to completely change that number. If we can go from 32 to 64 [percent efficiency], we’ve rebuilt the grid,” Steyer said.

The chair of a major AI developer speaking at a different event had a similarly optimistic take: “The potential for efficiency and productivity of our existing infrastructure, using sensors, using artificial intelligence, is off the charts.” For example, data and sensors enable better use of the existing grid through dynamic load ratings. “When cable lines are cooler, they can get more current through them. Imagine if we could predict the weather, that would predict the temperature of the line, that would allow us to optimize how much current we put through. These are the sorts of things that are possible.”

AI’s potential to optimize generation assets would create further potential for gains, he said, increasing the output from existing renewables capacity. “Imagine that: 10 to 20% for effectively nothing.”

Efficiency Opportunities at Every Turn

It’s not just generation and the grid that could be net beneficiaries of the AI revolution, some argued, but every industry that depends on electricity will gain efficiency.

For example, the real estate sector is unmatched when it comes to climate risks and opportunities, said Lauren Pesa, partner and U.S. real estate sustainability leader at Deloitte. “Real estate is the largest asset class in the world, representing two-thirds of global wealth. First Street Foundation projects up to $1.47 trillion in real estate value in the U.S. could be lost in the next 30 years due to climate risk.”

Yet this massive asset class, a major consumer of the grid’s electricity, is ripe with opportunities to be both more resilient and more efficient. AI and machine learning are key for moving digital building management systems from set-and-forget to active optimization, said Ben Dwyer, SVP of global sales at Kode Labs, at the Deloitte event. “With the evolution of what’s going on with automation, AI and [machine learning], you’re essentially able to, over time, optimize the building to run as efficiently as possible.”

While optimizing energy use will be important, smart buildings’ ability to be more resilient during climate events such as Texas’ freeze and hurricanes will be critical, he said. “What smart buildings allow you to do is get ahead of these large events and ensure that your buildings are prepared for these things to happen, to ensure that not only the asset is protected, but the individuals that inhabit that building are protected,” Dwyer said.

From left: Lauren Pesa, Deloitte; Austin Koch, Hartford Insurance; Caitlyn Raines, Esri; Ben Dwyer, Kode Labs | © RTO Insider

Ports are another example. Beth Rooney, port director at the Port Authority of New York and New Jersey, told a Deloitte panel on aging infrastructure that the port is on the cusp of a transformation.

“Between today and 2050 … we’re going to double, if not triple, our cargo and passenger volume. I don’t have land to expand to, so we have to take the land that we have and use it more efficiently and more productively. And that’s where technology comes into play.”

The Port Authority, whose infrastructure includes aviation infrastructure, tunnels, bridges and rail terminals, was using technology ranging from underwater drones to inspect pilings (fun fact: cleaner water is degrading the port’s pilings faster) to GIS systems for more efficient maintenance. The ports were improving efficiency through four uses of technology, she said: predictive decision making, real-time risk management, enhanced visualization to see what’s going on across 3,000 acres, and hyper-connected logistics.

“We will not be able to handle the volume that is coming our way, not just in New York and New Jersey, but across the United States, if we don’t change the way we do business,” she said.

Wishful Thinking or Wondrous Optimization?

Overall, the consensus was that AI would save more energy than it consumed, leaving the world better off, even if there would be more fossil emissions to cope with during the transition. There was little talk about sequestration, despite the reluctant admission that fossil fuels would supply much of the AI-driven demand for now.

The head of an electrical components manufacturer warned against overestimating the amount of energy required by AI data centers. Last year, data centers consumed 1.3% of global electricity, so doubling by 2030 and doubling again by 2035 still would leave it consuming only about 5% of the world’s energy.

The question of how the markets would meet AI’s power demand brought out the list of usual supply suspects, most notably nuclear, with small modular reactors commercially viable and available within the next five years, and every color of hydrogen. AI still was in its relative infancy, and potential efficiencies, ranging from improved cooling technologies to quantum computing, were expected to lower energy demand as the technology matured. Similarly, value could be extracted from the waste heat by industry or district heating systems, where they exist.

The Waiting Game

Behind the barricades around the United Nations, President Donald Trump was ripping into climate goals when he wasn’t grumbling about halted escalators and broken teleprompters. However, business meetings mere blocks away seemed unconcerned that he labeled climate change a “con job” and wind and solar energy a “scam”. If anything, his comments evoked smirks and assurances that project development operates on timescales that stretch well beyond any single administration.

An industry analyst said, “No matter what the president says, 91% of new additions to the grid in the United States this year have been batteries and renewable energy. So, if you don’t think the transition is happening, you’re burying your head in the sand.”

And regardless of the president’s opinion, fiduciary duty required investment advisers to manage the $16 trillion of U.S. employee retirement funds prudently, a lawyer said. “What does that mean with respect to climate change? When we have all the scientific data, [it] means you have to actually be mindful that these risks are going to have a financial impact on the portfolio,” she said.

The dozens of speakers at events on and off the record agreed: Trump’s comments at the U.N., and his administration’s policies to date, were an annoyance, but not the driving factor for an industry that plans in decades. As the CEO of a major energy generation asset owner said, “There’s nothing I could build today that [will] have a payback period during the Trump administration. There’s nothing I could build today that’s going to have a payback period in the next three administrations.”

Practical Action, not Political Oration, is What Matters

Steyer said the administration’s policies may slow the energy transition, but couldn’t stop it: “Is [Trump] an existential threat to the world’s ability to make this transition and to solve climate change? No. We’re [the U.S.] 11% of emissions. Our emissions may go down slower, but … except for the year of COVID, we have never reduced emissions, and we’re supposed to reduce emissions 40% this decade,” Steyer said.

China’s action would far outweigh any U.S. inaction. “In the first half of 2025, Chinese emissions went down 1%. China is a third of global emissions. Between 2018 and 2024, 95% of new fossil fuel demand came from China. If China’s peaked, the world’s peaked.”

As Deloitte’s principal and sustainability leader, Geoff Tuff, put it: “The headline is, no matter what we hear in different parts of the world, and no matter what reports you may see, the energy transition continues, and it will continue. And it’s just the sheer reality. If you fast forward the clock 30 or 40 years, we will have a fundamentally different energy mix than we do today.”

A Week to End All Climate Weeks

Like the COP28 I attended in Dubai two years ago, it was good to experience Climate Week NYC, if only so I could check it off my list and never go again. I’m too old to shout over a techno beat at a climate-startup-investor schmoozefest, too jaded to hear one more high-octane luxury brand’s CSO congratulate their token coral-growing PR effort, and too tired to negotiate the subway sauna while running from one event to the next.

If I sound like a curmudgeon, I am. There’s no simple way to sort the hundreds of events across dozens of locations, no consistent way to apply for them, and no unifying calendar and map to navigate your choices. And while the coinciding event at the U.N. brings climate experts in from the most-impacted nations, it also drives hotel prices to astronomic heights, even by New York standards. Maybe they could build an AI agent to sort it all out.

But despite the stressors, this curmudgeon left happy to see that pragmatists are running the energy transition, tackling the big, hard challenges as they arise, undeterred by the political distractions happening a few blocks away.

Power Play Columnist Dej Knuckey is a climate and energy writer with decades of industry experience. 

Christie Appointed Director of New William & Mary Energy Law Center

William & Mary Law School announced it has appointed former FERC Chair Mark Christie as the 2025 Lowance Fellow, a visiting professor of the practice of law and the founding director of the school’s new Center for Energy Law & Policy. 

Christie served on FERC for nearly five years and was chair for the last seven months, until this past August. Before that, he was chair of the Virginia State Corporation Commission, on which he served for 17 years. He also previously taught law at the University of Virginia and Virginia Commonwealth University. 

“I love the whole process of teaching,” Christie said in an interview Sept. 29. “First of all, you got to learn before you can teach, and so teaching is very educational.” 

William & Mary said the new energy law center “will serve as a hub for convening policymakers, scholars and students to address critical issues shaping the future of energy regulation.” Christie said the center offers him a chance to continue working on policy, with its first public activity being a conference scheduled for spring 2026 on how Virginia and the rest of the country can meet the needs of data centers and everyday consumers. 

The center also will “host webinars on timely energy issues, sponsor research projects by William & Mary faculty and students, and promote cross-disciplinary collaboration across the university, including opportunities for business and policy students,” the school said. 

“We are ground zero for the planet for the challenges of data center development and the reliability and the consumer cost issues that the whole country is dealing with,” Christie said. “Now, how do we pay for these? How do we keep the reliability? So, it’s a perfect place to do this in Virginia and in William & Mary, which is an outstanding law school.” 

The return of load growth has put pressure on prices and reliability, which has led to calls for major changes at PJM, the largest RTO in the country and one Christie has tracked his entire career as a regulator. He recently spoke at a forum hosted by Pennsylvania Gov. Josh Shapiro (D) where he and other state governors in PJM called for reforms in its governance process. (See related story, PJM Members Confirm 2 Board Nominees; States Call for Governance Overhaul.)

Shapiro and Virginia Gov. Glenn Youngkin (R) had asked that Christie and former FERC Commissioner Allison Clements be named to PJM’s board. The governors raised the issue with Christie shortly after he left FERC, and he said he would have served if asked, but the RTO ended up picking others.

“PJM faces a tremendous political problem, and when I say political, I’m not talking partisan; I’m talking the reality that you’ve got 13 states with obviously very different views about, certainly, what the generation mix ought to be,” Christie said. “So, it’s tough enough to try to come out with something that’s a consensus among the states, but I’m looking to see that the states use the authority we gave them in Order 1920-B, which is to decide on cost allocation, and file that with FERC.” 

PJM is making policy calls around issues without giving the elected representatives of its 67 million consumers enough of a voice, Christie said. 

Another policy issue that has come up lately and periodically over the past 20 years is the role of the Independent Market Monitor. When Christie was president of the Organization of PJM States Inc., his yearlong tenure was taken up by a complaint states filed trying to preserve the independence of Monitor Joseph Bowring, the result of which was universal rules through FERC Order 719. 

But some interests in RTOs do not want IMMs at all. The idea has cropped up occasionally in PJM and just recently at MISO, where Monitor David Patton has clashed with stakeholders and leadership because of his views on transmission expansion. (See MISO Board Orders More Detail into Monitor’s 2026 Budget.) 

“I am not usually at a loss for words,” he said. “People that know me would say that it’s very rare that Mark Christie is at a loss for words. I can hardly even think of the words to describe how essential the market monitor is. … 

“Consumers are absolutely, totally defenseless and regulators are totally in the dark [without a monitor] because I can tell you from my experience in PJM, I don’t know how many times as a state regulator we got critical information from Dr. Bowring that we had to have to make decisions.”