What Allison Clements thinks about the grid

Volts

In this episode, I sit down with Allison Clements, former FERC commissioner, to discuss her time at the commission and the challenges of grid modernization. We dive into the complexities of integrating clean energy, reforms to interconnection queues, and how the commission can take a more active role in the energy transition.

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David Roberts

All right. Hello, everyone. This is Volts for October 9, 2024, "What Allison Clements thinks about the grid." I'm your host, David Roberts. It has been a pretty exciting term at the Federal Energy Regulatory Commission as these things go.

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FERC has a reputation as a somewhat staid and slow-moving agency, but recent years have seen it begin to take a more active role in the clean energy transition, issuing major new rules on regional transmission planning, grid interconnection queues, and distributed energy, among other things. Allison Clements, a longtime environmental law and regulatory expert, has seen all this recent action up close.

She joined FERC as a commissioner in December 2020 and stepped down when her term ended this summer. In between, she read thousands of public comments, wrote dozens of opinions, argued over numerous pipelines, and consistently pushed for more aggressive grid reform. Since stepping down from the commission, she has mostly been laying low.

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So, I am thrilled that she's come on Volts to chat about her work on the commission, the future of the grid, and what better regulation might look like. With no further ado, Allison Clements, welcome to Volts. Thank you so much for coming. It's a real honor.

Allison Clements

Thanks, David. It's nice to be here.

David Roberts

I hope you've had a chance to lay on some beaches or sleep late.

Allison Clements

A little bit of that. A little bit of that. I've mostly been chasing kids around, but I have had no trouble removing myself, so I've enjoyed it.

David Roberts

Beautiful. I'll start with a general question: Numerous times over the years, you have expressed a worry, I would say, basically, that the grid, the energy system, the US energy system is changing very quickly in some pretty fundamental ways, and the US regulatory apparatus is not keeping up, basically, is not moving fast enough to stay abreast of these changes. In your four years on the commission, now, do you worry about that more or less than when you started?

Allison Clements

That's a great place to start, and I think I worry about the same, which is a pretty high amount, even for a worrier like me. You know, we start with the place in these conversations that the transmission system, the electricity system, is the backbone of the US economy.

David Roberts

Oh, yes.

Allison Clements

You know, it is not just about climate. It is about our national security. It is about our international economic competitiveness. It is about costs for customers. It is about resilience as weather patterns change. And so, when we think about the system we've been running for the last, let's say, 50 to 100 years, it's increasingly old, clunky, and outdated. But in the process of trying to keep costs low for customers, we haven't moved, kind of made that capital investment sufficient to then keep saving customers money over time. So, yeah, absolutely. There's lots to say about that regulatory structure.

The starting point is, we're at this generational moment where the actual infrastructure is not up to the challenge.

David Roberts

Yeah, and I want to get back maybe a little bit later to some, you know, reforms of FERC itself that might help improve that. But let's talk about a few specific areas first. One of the big orders that came out of FERC while you were there, Order 2023, was addressed at these interconnection queues, which I think everyone in clean energy now is at least aware of. Basically, we've got more clean energy waiting to connect to the grid than there is on the grid, and it's just a trickle at best, that is actually getting hooked up.

So, FERC decided to take this on in a rule that mainly sort of urges utilities to, instead of studying each new project in line, one at a time, at a cost of two to three to four or five years each, maybe you could study several new projects in a cluster. You could do these cluster studies and maybe connect several projects at once, which is not nothing. But when you wrote your concurrence on that rule, you mentioned that there are "more fundamental issues" that have been sort of left unaddressed by this ruling. So, what do you mean by that, what are those fundamental issues?

Allison Clements

Sure. And this is the example of your first question, which is that regulations take a lot of time to make at FERC. When the commission decides that there's an issue like this jammed-up interconnection queue that needs to be investigated, we go through legal processes of rulemaking, proposed rulemaking, and comment. That takes a long time. So we started this effort at the beginning of my term, ended the effort at the end of my term, and we're still, you know, we just let the horses out of the gate. We have not crossed the finish line. So what happened was we looked around the country and we said, "Wow, you know, there's 2.6 terawatts of generation waiting to hook up to the grid that can't get on."

90% plus of that is wind, solar storage. That's what's happening in the world. The commission's job is to facilitate what's happening in the world affordably and reliably. But, that interconnection process was never set up for so many projects trying to get online.

David Roberts

Set up for big once every several years, fossil fuel plants, you know.

Allison Clements

Exactly. Closer to load coming on at a much slower pace. Kind of better understood how the operations will affect the system traditionally. And so, what happened was, everybody just got overwhelmed. Fast forward to 2022-23. You look around the grid and you say, "Okay, the utilities aren't waiting for FERC to act." Utilities around the country were trying to fix these logjams themselves. And so, FERC said, "What are the practices these utilities are doing around the country and what's working?" And we saw this cluster study idea. We saw this idea that, you know, some of these projects aren't serious, right.

They're just putting in applications to see how far they can get. How do we weed that stuff out? Well, let's make them pay. Let's make them, you know, show that they are commercially ready to hook up to the grid. Let's make them pay for studies to get onto the grid. Let's make them pay if they drop out of the line; that puts more accountability on the interconnection customer. We also said, "Hey, utilities, get those studies done that the customers are asking for, get them done by deadlines," and created a kind of payment incentive for utilities to speed up as well.

So, what we did was, we made a strong baseline. It's nuts and bolts improvements. It wasn't modernizing the interconnection process. It didn't fix all the problems. But it said, "Hey, as a starting point, we have to get out from underneath this kind of just ill-suited process and let's take it from there." That's where my concurrence comes in.

David Roberts

One thing that's kind of in vogue these days in clean energy circles to talk about is the kind of Texas approach to the interconnection queue, which is known as "connect and manage." Just for listeners who aren't familiar, it's complicated. But the capsule summary is, instead of doing a full study of how the plant would operate and how it would affect the grid and whether the grid could accommodate it, you just go ahead and connect it. And then if the grid needs to shut that power plant down for whatever reason, for safety, reliability, whatever, it just will.

So, in a sense, the power plant is taking a little bit more risk, but it gets hooked up a lot faster. Would you support that kind of connect and manage approach everywhere? And do you think FERC should have a say in whether utilities use that?

Allison Clements

You know, using everywhere is always dangerous, but this idea that — what's happened is, while these resources are waiting to get hooked up, these upgrades to the grid have to be made, these network upgrades, so that the resources have, you know, what's called capacity? Room, network service on the grid. But they don't have to have that. You could hook them up and just say, "Okay, you know, we have congestion today. You're getting curtailed."

David Roberts

Right.

Allison Clements

And then, as they're already hooked up and producing electrons, the network upgrade process can continue. So, yeah, it's a really good idea. It's worked in Texas. People have opinions on the specific nuances of one approach versus the other. But this connect and manage, or this focus interconnection, is a really important and promising idea, and it's one of the many ways we can start to make progress.

David Roberts

Now that you're not on the commission and you're just sort of free to let your imagination run, what else do you think FERC should do on interconnection? Like, if you were queen of FERC for a day, what do you think would get at a more fundamental fix?

Allison Clements

Yeah, I'm unburdened by what has come before.

David Roberts

Exactly. You just fell right out of the coconut tree.

Allison Clements

You know, there's so much talk about the power used by advanced computing and by artificial intelligence, but what can those things do for the grid? There are opportunities to use these kinds of advanced computing cloud platforms to automate processes, to be able to study scenarios and impacts on the grid that any given solar project or solar plus storage or gas plant, whatever, you name it, the impacts that might have. Can you imagine a world where you could enter a sort of standardized interconnection agreement and you'd use modern technology software to study what might happen on the grid, and then you can hook up in a month, because we figured it out? That is technologically possible, but operationally, we're not there.

Right. There are conversations in the Great Plains region and SPP about how we might get more certainty upfront for generators and say, "It costs x dollars per megawatt to hook up to the grid." So, if you're 100, it's this. If you're 250, it's this. Pay it and let's go.

David Roberts

Yeah, give them something to plan around. Because right now, it's really like — it's just like throwing dice. It's like a lottery. When you get in that queue, you have no idea what you're going to run into.

Allison Clements

That's right. You just know that's not going to turn out how you think it's going to turn out. And there's lots of other things we can get into. We can talk about how to make more room on the existing system, how to take advantage of co-location, how to use surplus interconnection rights. There's a whole lot of opportunity. But again, the regular process grinds slowly and it's keeping those things moving that's important.

David Roberts

To your knowledge, is FERC, are they some intern in a basement somewhere chugging away, thinking about further interconnection stuff? Or did you just cross this off the list for a while?

Allison Clements

Absolutely. FERC has such great interns, but also really strong experts, and they just held a workshop, a two-day workshop on what comes next. I think the regions aren't waiting for the commission right now, and they're taking next steps into their own hands. It would be nice to see this commission take next steps and do it quickly. To kind of, you know, everywhere you go right now, people are talking about interconnection. There's all these companies who didn't understand they were computing companies, they're advanced manufacturing companies. They didn't understand they were energy companies or power companies. And now they're learning about what are kind of these irrational barriers to entry that make it just really urgent to get going on this stuff soon.

David Roberts

Yeah, well, let's talk about the other big grid issue — I guess there are multiple — but one of the other big grid issues that everyone is also talking about, namely transmission. So, you know, the basic situation, which I'm sure you're deeply familiar with at this point, I guess almost everybody now, at least in our world, is familiar with this, which is just, if you have more renewables, location matters more and you need more transmission. You need more long-distance transmission to carry the power from wherever it's going to be generated to where it's going to be used.

And we are, in this country, incredibly slow and not particularly rational about where we build transmission. We don't, you know, it's sort of catch-as-catch-can based on individual utilities. And there's very little in the way of broad planning; even though this is a system and a big system, you'd want some planning. So FERC jumped into this, also took a long time, also a lot of arguments, a lot of public comments. But you issued this rule, 1920, big rule on transmission planning. And so the main thrust of that rule was a) utilities have to do these 20-year plans, so they have to plan, which is like, as I've said on this pod before, it's a little remarkable that a regulator has to force a utility to plan its utility area.

It's a little crazy, but nevertheless, there it is. They have to plan now and they have to take certain benefits of transmission into account when planning. Just like on its face, how sufficient is that rule to the need? Or do you think that also is just kind of cracking the door?

Allison Clements

I think it's a lot more than just the starting point. So, the idea that utilities should be working together with their neighboring utilities, looking forward 20 years, using scenario planning with the best available data to say, "What will the interconnection queues look like in 20 years? What do electrification trends mean in industry and buildings and cars? What might gas prices and commodity prices look like?" We don't know the answer to any of those questions. But if you take scenarios and start to harness that uncertainty, there's a lot, a lot, a lot of low regrets, big regional transmission that needs to get built, and that is regardless of what types of resources hook up on the other end.

Right. You know, LBL put out a study; they did an analysis from 2012 to 2021. They updated it again in 2022. But they looked at the locational, marginal, no price values of transmission. And 2011 to 2021 wasn't the time of massive renewal integration. And their analysis demonstrated that for every gigawatt of transmission investment, it's about a million dollars a mile for transmission. As a rule of thumb, every gigawatt of transmission will pay for itself somewhere between five and ten years over. And that is simply by lowering bulk system costs, right?

David Roberts

Yeah.

Allison Clements

That's savings. That has nothing to do with the type of resources that are hooking onto the grid. So, let's look forward 20 years and build this stuff. Let's not build too much. Let's not build it cost ineffectively. Let's optimize across costs, and let's optimize across impact. The only way you can do that is to do these forward-looking planning. And it is kind of shocking that this hasn't been happening for the last decade. It's just like every household plans, they plan their budget for Christmas, they plan their budget for spring break vacation. We weren't requiring that as a regulator of the utilities.

David Roberts

What do you think about the idea that utilities, investor-owned utilities, make money by spending money? So, if they get together in groups and plan and build a transmission system that maximally sort of shares power across the region and lowers costs, that's great for customers, but it's not necessarily great for utilities. It lowers the need to invest more in the grid, thereby lowering the amount they can spend, thereby lowering their returns. In other words, this, as in many areas, it kind of seems like what's best for customers is counter to the utility's financial interests. Do you think that's at play here?

Allison Clements

I think that's a play in a lot of the aspects of utility planning. When it comes to transmission, this actually is a win-win in terms of the ability of utilities to spend money on transmission, which can lower costs of new generation, can provide access to other lower-cost generation and other regions. And so in this case, of course, there are questions in any given situation, but the opportunity is there for everybody to be on the same side. The question that our rule did not answer, and it's one of these existential questions about why transmission hasn't gotten built over the last decade, is the question of competition and whether or not utilities should have to compete with non-utilities or other utilities to build this stuff.

And that's a question that this rule didn't answer, and it's certainly an important one relative to if, when, and how this stuff gets built.

David Roberts

Yeah, well, I wanted to ask about that because you and Commissioner Phillips, in your concurrence, said that you were willing to give utilities back their, what's called, "right of first refusal", ROFR, right of first refusal, which basically just means that they get first cut at any transmission line, and that if they have that right of first refusal, that basically kills competition because it just puts them permanently at the front of the line. So, I'm wondering why you thought it would be a good thing to give them that right of first refusal back.

Allison Clements

We did not actually give them that right of first refusal back. We left that question open. There's another docket at the commission where that question may or may not get answered by this new set of group of five commissioners. And you're thinking about an industry that's heavily regulated. There are a few industries, telecom and others, that are similarly regulated. And you've introduced competition. In 2011, the commission introduced this rule called Order 1000, and it said, "Regional transmission has to be subject to competition." And so what happened was — and this is an oversimplification, and I readily admit that — but what happened was utilities lean towards building the needs of their own systems within their own footprints that weren't subject to competition or that were needed for specific reliability purposes, and therefore not an exception from this competition rule.

That's not to say they're not willing to compete, but there had been a de-emphasis on the competition part.

David Roberts

It sure seems like they're avoiding it. It sure seems like they're doing everything they can to not let competition happen.

Allison Clements

You know, I'll be honest. It's hard to go halfway into, it's like jumping halfway into the water. Right? We've said, "Okay, have competition, but not in all cases." And the commission has the choice to double down and say, and eliminate more opportunities for competition or to say, "Hey, can't beat 'em, join them. Let's provide the right incentives to the utilities to get the good stuff done." We live somewhere in the middle right now. And to me, you know, it's like, "Hey, these are the rules." You know, we took four years to get this rule out. We took on as much as we could as a commission.

There was a lot of compromise involved in getting it done. Go try and win by playing around these rules. You know, there's one thing I learned when I was in project finance is that the developers will live with whatever the rules are, as long as they have certainty around the rules. Right?

David Roberts

Yeah.

Allison Clements

And I think the utilities that want to ensure this right of first refusal, you know, fair enough, they keep fighting for that interest and they have a responsibility to their shareholders to do so. But at the same time, go compete, figure out a way. They've got the right of ways. You know, they have lots of advantages, perhaps not all in the capital markets, but they certainly have some. And so let's go see what we could do now that we have this rule out there.

David Roberts

What do you make of the argument of your Republican colleague that this requirement that a state's utilities sort of get together in a group and do this shared planning? Basically, the argument is this forces states that don't have clean energy policies and don't want clean energy policies to basically participate in and help pay for the clean energy policies of states that do have them. Basically, like socializing these costs, you're dragooning these unwilling states into this process. What do you make of that argument?

Allison Clements

You know, this is not just my Republican colleague. It's a perspective shared by states who look around and say, "Hey, transmission's getting expensive." But as I started, the reality is new transmission brings benefits to customers, to everybody on the grid. From a reliability and economic perspective, period. We are very far from the point where we're going to start worrying that a penny spent is a penny lost related to all customers getting benefits from transmission. So to me, what we did in this role was give states an unprecedented seat at the table to say, "Hey, we don't think that that particular line is going to help our customers because it's serving that other state's policies."

Great, stipulated, you shouldn't have to pay for that line. But if that line is the most cost-effective way to bring the economic benefits to your state, that will reduce, you know, the transmission component of your customers' bills. Why wouldn't you get on board with that? No transmission line provides only one kind of benefit to customers. And I think if we strip out the politics and say we have a generational need for transmission investment, our grid is not supporting our economy, it's not supporting our communities. I mean, we haven't talked about Hurricane Helene yet, but the reality of these terrible, terrible incidents that are taking place, it seems to me that if I was a regulator whose governor had my cell phone number, I'd want to be sure I was doing everything I could to make sure that my communities were safe in the face of these storms, that their bills continued to be manageable relative to this reality of the need for new investment, and that advanced manufacturing facilities were choosing my state and not the state next door because there wasn't any room for them on the grid.

David Roberts

Yeah, well, ideology can make people stupid. One of the real hot-button issues here, one of the things that people struggle with, I think even in good faith, struggle with trying to find the right answer, is just the best way to share costs of these things. It's difficult to pin down with precision, sort of exactly who benefits. There's some fuzziness there. So, aside from the constraints of the rule and the commission that you were in, what do you think is the best way to think about cost sharing for these big cross-utility, sometimes cross-state, transmission projects?

Allison Clements

Yeah. The reality is, you know, if you think about how the national highway system got built — there's lots not to emulate there, right — but the federal government, because this development of his highway system was in the national interest —

David Roberts

Right.

Allison Clements

used federal government funds to pay for the development of the highways. Right. Oklahoma couldn't come in and say, "Yeah, I don't want that going through my state." Illinois couldn't say, "Yeah, like, I-90 is not for me." That highway system formed the basis for the US economy. Now we're at the next technical revolution, and the electricity grid is that highway system. But in this case, the customers, you, me, and companies and businesses pay for this new investment on our utility bills. So the concern is fair, it's understood. But the best example that I always come back to is the multi-value project lines in MISO, the Midwest regional grid operator.

Those lines got started because a bunch of governors of very different political stripes got together and said, "Wow, there's a lot of wind coming into the Midwest, and we think we could all take advantage of this low-cost resource. There's also a lot of need for economic savings on our transmission system. So, let's figure out a way to develop this backbone set of lines and do some rough justice. We will all try and figure out roughly how much we benefit and everybody will be allocated the cost of those lines based on that rough justice." And those lines are the gift that keep on giving.

When you look at what happened in Winter Storm Yuri, in Winter Storm Elliot, those lines probably paid for themselves each time over by being able to interconnect regions, provide redundancy, and keep the lights on. So, I don't know of a case where analysis of the benefits over-evaluated the benefit of new regional transactions.

David Roberts

We always underestimate the value of these things. Always, always.

Allison Clements

And that's why I think there is an opportunity for everybody to sit at the table together and get away from this question of whose policy caused which electron to flow.

David Roberts

If transmission, especially long-distance transmission, is sort of a natural monopoly, why do we have profit-making companies involved in it at all? Why don't we just approach it the way we approached the national highway system, that is, do some national planning, build it out with federal tax money, and tell states what we told them when we were running I-90 through them, which is like, "Tough. This is happening, we're doing this." Why not? Why are we still mucking around with profit-making companies at all?

Allison Clements

David, I know you like the West Coast better than the East Coast, but you've spent time in Washington DC. We operate under a divided government. It's where we are.

David Roberts

But if you were to queen like, if you were in charge, does that make sense to you?

Allison Clements

Yes, absolutely. Is the electricity system the critical component of this nation's prosperity in the next century? Yes, I think about the military bases in North Carolina and Tennessee, whether they lost power, what operations they were running. And I think about the amount of investment that China's making in its grid. It has, you know, it plans for 700 to 800 billion dollars over the next. I forget if it's five to ten years. If we want to maintain our role in the world, we have to be doing this. That, to me, is the pinnacle of national interest.

That's not where we are today. And so, to my mind, we need political will at all levels, right? We need governors, we need county commissions, we need Congress, we need everybody saying, "This country has to want to start building stuff and we need to do it well." And we need to be cognizant of the communities that are going to have to take in this infrastructure. But yesterday was too late. And so, absolutely in a perfect world, we'd be doling out money for this stuff.

David Roberts

What do you think needs to happen next on regional transmission? There was some stuff about grid enhancing technologies which we've done a couple of pods on here at Volts. I think the Order said basically just that utilities need to be cognizant of them and calculate their value. Do you think that's enough on grid enhancing technologies, or do you think more is needed there?

Allison Clements

It's a start, it's a compromise, and I'm proud that we got something done related to that in the regional planning rule and also in our interconnection rule. But there's a lot more to do there. One thing we haven't talked about is we talked about the general inability for regulation to keep up with where the markets wanna go. We haven't talked about the fact that these particular rules, 1920, which is the transmission rule, and 2023, which is the interconnection rule, they will take time to bear fruit. So if you think about Order 1920, regions comply — well, first it's gonna get litigated — then regions are complying with the rule, and then they start planning together.

We're talking about 2029, when lines start getting chosen. What do we do between now and then? We have a whole lot of opportunity to create new room on the existing system. And that happens in lots of different ways. Using hardware and software, which we call grid enhancing technologies, reconductoring or other advanced transmission technologies that can double the amount of renewables we could integrate on the grid today without material new transmission. Right. Right now, if you are a chips manufacturing facility, who just got a grant from DOE trying to move into a state, but there isn't room on the grid according to the rules, even if physically, by the laws of physics, there is indeed room to be on the system.

These are the kinds of things that we need to be solving now, so that we have the opportunity, while the suite of solutions that are regulatory, take time to take effect.

David Roberts

Yeah, it seems like it would be cheaper for Microsoft. Rather than spending $1.4 billion on a nuclear plant, you could probably spend like a third that much on grid-enhancing technologies and just boost the capacity of the grid you're on. I bet these AI companies would help pay for that, even if it was available as an option.

Allison Clements

I think there's competition in the ability to own and procure generation with the largely still monopoly state of the transmission lines. It's the utilities themselves that need to deploy them on their systems.

David Roberts

Yeah. Yeah. So, this is all about regional transmission planning, which is a big deal, but then there's also the even maybe stickier question of interregional transmission planning, or I guess you'd just call it kind of national transmission planning. I wonder what you think FERC can do on that without Congress with its existing powers, or do you think Congress is going to have to step in and sort of change that situation? What's your take on interregional transmission?

Allison Clements

Sure. As you know, right now there is slim to none when it comes to interregional planning.

David Roberts

Yeah, there is none now. Creating some at all would be a good step.

Allison Clements

That's right. The Department of Energy puts out good studies. The labs put out good studies on the seams, but there is no required interregional planning. FERC has the jurisdiction, from my perspective, quite clearly, to require interregional planning in the same way we have required long-term regional planning. But the question is both structurally and politically, can the commission do that and do it in a way that is strong without congressional direction? So, of course, we now have the Manchin-Barrasso permitting package, which is being batted around Capitol Hill, and that legislation contains really the requirement that the commission establish a really strong interregional planning rule.

David Roberts

Oh does it?

Allison Clements

It sure does.

David Roberts

Interesting. So, that would trigger basically a rulemaking at FERC, you think, or something along those lines?

Allison Clements

That's right.

David Roberts

And this would be RTOs basically coordinating with other RTOs. I mean, is that how it would work? Or would FERC itself, like, do you need a national governmental agency, you know, sort of in the room there with that planning?

Allison Clements

As is envisioned by, I think, most stakeholders at the commission who've been thinking through this question, and also by Congress, FERC would issue a rule that required each utility, and in the case of FERC's planning rules, the RTOs themselves are a utility on behalf of their member utilities. So, it doesn't matter if you're in an RTO or not. There would be some requirement to establish joint planning, either resulting in one plan or compatible plans, separate compatible plans with neighboring regions, which could be another RTO, or it could be a non-RTO utility region, which also exists outside of the RTOs in both the west and the southeast.

David Roberts

Yeah. Yeah. Well, who knows if that will ever pass. But it would be interesting. I want to touch on distributed energy. I think you'd call it like the other side of the coin from transmission. We need a lot more regional and interregional transmission to move things long distances, but we also need, I think, by common agreement, lots more coordination and just making sense of the profusion of local energy, basically local generation, storage, distribution, things like that. So, FERC has taken a couple of swings on this. Order 841 was about integrating storage into these regional markets and then Order 2222.

Is that how you say it?

Allison Clements

That's how I say it.

David Roberts

2-2-2-2? Two by four, 22-22. This was a pretty sweeping order that basically mandates the overseers of these regional markets, the RTOs and ISOs, to allow aggregated distributed energy resources into wholesale energy markets.

Allison Clements

That's right.

David Roberts

So, I guess two questions. One is, do you think — because Order 1000 before this was kind of about a similar thing and I think the general view is it didn't really work like it is not really working like you wanted. So, what do you see as kind of the efficacy of 2222? Do you think it's going to work? And just generally, I'm curious on your take on distributed energy resources and whether integrating them in wholesale markets is the only, the best way of supporting them?

Allison Clements

Absolutely. Well, I want to get back to the way you set up that question, which is the question of: yes, we need new transmission and these distributed energy resources. Princeton is projecting 2.4 to 3.8% a year load growth over the next ten years. We need to be firing on all cylinders. We need everything from the cheap, easy near-term stuff like harnessing demand side, which isn't easy, but it's easier, like using grid-enhancing technologies all the way up to building the big, more difficult transmission. But when it comes to distributed energy resources, one of the kind of bummers of my term was that this rule was in the compliance process for the entire time I was there.

I issued an order, I think it was on NISO, right before the end of my term. And so, from 2020 to 2024, we were still in compliance, which meant that we couldn't talk to stakeholders about anything that came close to touching on the participation of distributed energy resources in FERC jurisdictional processes because that would have been ex parte. So, there's been kind of a lack of communication around whether or not this is working and what the next steps are, except through the paper filings and the comments that we've got from stakeholders. Now, did Order 2222 do, has it done, or is it going to prove out all it had hoped to do?

I'd say results are looking moderate. There are still questions about barriers from distributed energy resource providers in various regions to participating in any RTO's market, but it's possible. Again, we're taught — it's not a technology question as much as it is a coordination and an operational question as well as the political will question. In Australia, where we learned a lot about distributed energy resources, they're going to have 30% of the entire country's capacity —

David Roberts

Yeah, it's wild.

Allison Clements

from rooftop solar by 2030, effectively rooftop solar.

David Roberts

It's cheap as hell there, right?

Allison Clements

And it's not political there, right? It's like it's becoming — but it was like, you know, I cut coupons before I go to the grocery store. I wait till the day that the gas goes on sale and I put solar on my roof, all because those things make the money that I spend lower. Right. But that's not where we sit in the United States. And so the demand side opportunity is tremendous. And I, you know, I feel like I have been advocating for the same thing for the last decade, which is to take advantage of it. And I'm not sure how much progress we have made.

But again, this new era of load growth hopefully opens up an opportunity to say, "We can do all of this stuff." We can do this stuff that is capital intensive and creates a new rate base. And we can, because there is so much of that to do, and because there's an obligation to protect customers, we can also take the next steps on deploying these distributed energy resources into the markets.

David Roberts

The cynical take on it is that utilities are fighting this because they don't own the distributed energy resources. Insofar as distributed energy resources are well coordinated and used effectively, they reduce the need for additional grid infrastructure, which again hurts the financial returns of the utilities. So, the cynical take on this is just utilities don't want competition from local energy, and they're therefore fighting it and dragging their feet in every way they know how. Is there a non-cynical take on why utilities are going so slow on this?

Allison Clements

Well, Allison's rose-colored glasses take on this is that this is a new opportunity, for sure. There are financial incentive misalignments, and that is something that the state regulators and FERC can work to improve. In fact, we have the opportunity under section 219 of the Federal Power Act to provide incentives for advanced transmission technologies. Now, what falls into that bucket, we can talk about, but from my perspective, I think we're not wholly satisfying that obligation today. I keep saying we. It's they now. Which is lovely, but there is an opportunity there, right? But there are concerns about reliability and about operational transparency and the ability to understand from the grid operator's perspective whether or not those resources are going to show up.

I think those are all solvable problems. Sometimes, it's hard to get all of the right people in the same room because of the different jurisdictional pots that are pulled from. The opportunity for the rose-colored piece is that utilities are feeling a fear of this load growth as much as they are excitement. This is a huge challenge.

David Roberts

Yeah, it really is forcing — like doing nothing is no longer an option for any utility anymore. This is a little speculative. I keep asking you to be speculative, but sort of on the DER front, on the distributed energy resources front. I just personally have trouble believing that aggregating them and allowing them to play in wholesale energy markets is the best and final way of encouraging them. And I wonder if you think something more fundamental is needed. So, a lot of people these days talk about a kind of layered grid where you have local energy markets, local trade, and distributed energy, which then sort of aggregates up into wholesale markets.

So, you have distribution, you have DSOs, basically the local equivalent of ISOs and RTOs. What do you think about that? Do you think we're moving in that direction? Or do you think just playing in wholesale markets is going to be enough?

Allison Clements

I don't know the right answer to that question. I don't know —

David Roberts

What a refreshing answer.

Allison Clements

There's a lot of things I don't know on a daily basis, and that's maybe Lorenzo Kristov's kind of perspective, someone who taught me a lot about what I know about the grid and is so visionary. I'm in a moment of coming off a term where we had people with different political perspectives on the commission. There was a lot of compromise involved. And so, perhaps the realist side of me has become stronger in terms of the amount of resources and cultural shift and change that would be required to turn this super tanker of the energy regulatory system in time to face the challenge that we have in the next five years.

That feels very hard. So, if I was starting from whole cloth, I think that is a very efficient, smart, and technologically possible way to run the electricity system and energy systems going forward. Are we there today? In restructured states that have been more open to this idea, let's lean in. But we also should understand that the battle will be long, hardened, and I don't know if it's winnable in some other parts of the country.

David Roberts

Well said. So, speaking of different regions with different politics and different energy mixes, I just wonder, on a big picture scale, which regions do you think are doing best and worst here in terms of managing the energy transition? Who are the leaders and laggards here? You're allowed to call them out now since you're not on the commission anymore.

Allison Clements

Throwing tomatoes is not my specialty. I have very bad aim. You know, I'll talk about a region that I think is doing so well relative to the challenge. And I lived out in Utah for five, just over five years, and kind of adopted, my heart, adopted the west as my home. And the regulators in the west are trying really hard. They organically have been coming together, you know, for decades. There's been conversations out there about the development of markets and what that might look like, and there's a lot of blood, sweat, and tears left behind relative to those fights.

But we've had a couple of states in the West require their utilities to consider joining RTO's. We've had state regulators across all of the states really engaged on the question of, "What does an RTO that serves my state's customers well look like, and how do I get engaged?" And so now there's a bit of a competition, if you — that's the wrong word. But there are two big RTO's that want to play in the west, right? CAISO in California and SPP in Little Rock, and we're seeing utilities start to commit one way or the other. So to me, the dominoes are starting to fall in terms of what that's going to look like.

And I don't know how we meet the challenge of the energy transition without the development of markets. Not necessarily yesterday's markets, markets that have evolved to both provide the services that a grid needs with a new set of changing resources as well as protect customers along the way.

David Roberts

I mean, the Southeastern Power Pool or whatever half-ass thing they set up down there is not anything to celebrate. Do you think the Southeast, do you think in some sense it's inevitable that they're going to have to do a market down there, that they're going to have to have an RTO down there? Or do you think they're just going to hold out forever? They're just going to be old school, vertically integrated monopolies forever and ever amen?

Allison Clements

Let's note for the record that you made that description, not me.

David Roberts

I like throwing tomatoes.

Allison Clements

I have been a vocal critic of the Southeastern energy market. I think that's the SEAM exchange.

David Roberts

Yeah, SEAM, sorry, that it is.

Allison Clements

And I don't think that it has to be the case that the Southeast establishes an RTO tomorrow. But I think whatever market mechanism, any region, and this has happened in the West, in the Western Energy Imbalance Market out of CAISO, which has saved customers over, I think, $5 billion since its inception in 2014, whatever market mechanism gets created needs to be non-discriminatory at whatever phase of the market development it's at. So it doesn't mean you have to have a full-blown RTO tomorrow. But if you're going to start trying to save customers money, and by the way, if you're going to satisfy your responsibilities under the Federal Power Act, there's a lot of money on the table.

When you're not participating in those markets and achieving those efficiencies, then we're in trouble. So, we'll see how that plays out. The hurricane, again, not to suggest one requires the other, but when you get past the loss of life and damage, when you think about the power system there and how we're going to maintain resilience in these really unexpected weather situations, there's going to need to be an integrated grid that is bigger than those weather patterns. And so, we'll see what happens.

David Roberts

Trey, it's horrific, obviously, what's happening down there, but it is also an opportunity. I mean, Duke basically came out the other day and said, "In a lot of these areas, it's not about repairing the system. We're just going to have to rebuild from the ground up huge chunks of this system." So, it'd be nice if they did it better, build back better, you might say, after this. The one other thing I wanted to ask regionally, because a bunch of people wanted me to ask you about this, maybe you don't have anything to say about it, but is Texas going to be independent of the federal grid forever?

Or do you think the operational and economic advantages of hooking up with the rest of the grid are eventually going to overwhelm the ideological resistance? What's your prediction on Texas?

Allison Clements

My husband's a Texan, and I don't want to upset him over the dinner table after he listens to this, but, you know, obviously there are benefits to interconnection. And when you are able to interconnect a system that is wider than a weather pattern or an extreme event or has variability in the time of day, so wind and solar can balance out peak periods, you're going to be better off. Customers are going to be better off. So, I'm certainly not going to lead the charge myself to break down the barriers to Texas. But, it's hard to deny.

It's hard to deny the benefit of increasing connections.

David Roberts

Yeah, yeah. Okay, well, let's talk about natural gas, then. So, a lot of people in my world are sort of perpetually irritated that when it comes to natural gas pipelines, basically, you just propose them to FERC. FERC says, "Yeah, we're doing that." And the landowners and the states involved don't really have much say in it. FERC can just, you know, sort of eminent domain: "Yes, put that pipeline there." And then obviously, when it comes to high-speed or long-distance transmission, whole different world, every landowner can stop it. Every state can stop it. Every entity involved, and there are dozens, practically can stop it.

And FERC cannot just pound its shoe on the table and say, "You're building that one there, and everybody just get out of the way." One of the main points of contention is whether FERC should be taking climate change impacts into account when it is assessing proposed natural gas pipelines. You think it should, and I think, have argued repeatedly that it should. I think other people on the other side argue that' s not in our remit. That's not something we're obliged to do by law. That's not something we're allowed to do by law. So, I guess, two questions.

One is, do you think under FERC's existing authority, it has the authority to consider environmental impacts and these things? And then if it doesn't, like, should it, should Congress do something like, how do you think FERC's approach to natural gas pipelines ought to change?

Allison Clements

Yeah, that's a big question.

David Roberts

Very big.

Allison Clements

And I do want to come back to this question of the difference between the Federal Power Act and the Natural Gas Act as it relates to this. But to answer your questions, I have spent a long time actually trying to explain to people that FERC is not a climate regulator, that FERC is an economic regulator, that the Federal Power Act is a consumer protection statute at heart, and that our job is to protect customers and reliability. You know, that's an oversimplification, but to protect customers and reliability, whatever is happening in the world.

David Roberts

Right.

Allison Clements

But under the Natural Gas Act, in the determination of whether or not a pipeline is needed, both the commission and courts have said that environmental factors should be balanced in determining whether or not a project is needed. And I believe that both under the determination of need under the Natural Gas Act as well as under our NEPA analysis, because when we approve these applications, they trigger environmental review, we need to consider environmental impacts. What is the biggest environmental impact right now? The release of greenhouse gas emissions. And so, the idea that we wouldn't take that into account is counterintuitive to me.

And there is such an ideological allergy to the reality of climate change, you know, protruding into, leaking into, or sneaking into FERC's decision-making process that we have, I think, lost the middle where I think we were when I started at the commission, which was on a path towards compromise on this question.

David Roberts

So you think it's gotten more polarized over the last few years?

Allison Clements

I do, I do.

David Roberts

Well, there were some updated policy guidelines along these lines announced in February 2022, only to be retracted in March 2022 after what I think can fairly be characterized as a rather heated assault on those guidelines by our old friend, Joe Manchin. What was in those guidelines, and why did they die?

Allison Clements

I remember those months very specifically, as does my family. Looking back at that time, we put out a proposed policy to modernize the commission's natural gas policy. This policy goes back to 1999. It's really old. It may be, if not one of the, or it is, it is one of the longest policies. And that was written before fracking even existed. The state of the economy, the drivers of the economy, the penetration of gas into the electric system was just orders of magnitude different. Right. It needs updating. Did we do everything in the way that made the most sense?

We released it the day before Russia invaded Ukraine, the updated policy. And there were a lot of things that happened around that. Certainly, a lot of lessons learned. But the thing that I thought was important then and think is important now hasn't changed. And that is this question of need. To your point, if an applicant for a new pipeline wants to get it permitted and cited by the Federal Energy Regulatory Commission, what they need to demonstrate is that they have an unaffiliated transporter. Right. So the person, they need a contract, or more than one contract that represents desire for some high percentage of the capacity of that line.

David Roberts

Right. Just to demonstrate that the line is needed, the market wants the line.

Allison Clements

That's the test. Now, some pipeline companies go beyond that, and they produce market studies and submit those with their filings. But FERC does not engage in a rigorous analysis of need. And to me, if they started to engage in a rigorous analysis of need, then we would be closer to satisfying the language of the Natural Gas Act itself. The statute which says, "If the pipeline is in the public interest, it shall be approved. If not, it shall be rejected." And so it anticipated this question, "Do we need this pipeline? And if we need this pipeline, then let's deal with the environmental impacts of it. But if we don't need it, we should be stopping there."

David Roberts

Right. But it's... I mean, has FERC ever, ever rejected a natural gas pipeline?

Allison Clements

I think a couple of times. Not during my term.

David Roberts

I mean, whatever it's decided, the public interest is, it seems pretty automatic that these things get approved now. But, you did vote against several individual pipelines. Was that based on need, or was that based on environmental impact?

Allison Clements

Both, depending on the case. And actually, we've just gotten a couple of court cases. There's one pipeline in the northeast; there's another pipeline being litigated in the west. The one in the Northeast, the states objected to the development of the pipeline, and the courts found that FERC didn't — this is an oversimplification — the courts found that FERC didn't take a strong enough look at need and that there were these states coming in. And so, you know, this question of, do we listen to the states when they come in and they say they don't want to pay for other states' clean energy policies, but then we don't listen to them when they come in and say, "We don't need this gas because our clean energy policies are going to reduce the demand for gas in our state."

So, it's a complicated question, but I do think it remains an important one. And hopefully, the commission will, despite the, you know, the history of the draft policy update that got rescinded, hopefully they'll make progress on this issue.

David Roberts

Yeah, but do you think it's fair to say, like, I think, sort of, globally speaking, you could say that the commission is moving in basically the right direction on interconnection, on transmission. It kind of doesn't seem like it's moving at all on this particular question. Do you think that's fair, that things are kind of stuck around this issue?

Allison Clements

Yeah, I mean, I've had my head in the sand for the last two months, so we'll see what this new commission does. But I do think it's important to point out that, as you said, the siting and permitting for new gas pipelines and then the related ability to get eminent domain authority all rest at the commission. Right. They are the lead agency for the NEPA review, and they provide the permit. When it comes to transmission infrastructure, there's split jurisdiction. So FERC has jurisdiction over the planning and who pays for transmission, but the states have jurisdiction over the state permitting and the siting, the award of a certificate of public convenience and necessity.

And that, in and of itself with no other consideration, is cumbersome and, you know, difficult at best. And so, in this permitting proposal that's going around, that would give FERC improved, vastly improved, siting authority over electric transmission, that would be really important. It would put the electric transmission not in the same place, but on more of a level playing field with gas infrastructure, and say, okay, what I like to say, which is, let's let the markets decide what is going to get built. And so, I think that would be an important change that would start to help get transmission infrastructure built.

David Roberts

Another kind of general question, which is, there are two perspectives on the question of FERC's power. I think one perspective is, and tell me if I'm wrong, but I feel like maybe you share this perspective, which is that FERC has more authority than it is using. FERC could, under statute, under current law, be more ambitious and maybe more forceful and more whatever. That's one perspective. Then on the other side of that, you have the Supreme Court being the way it is, you have the Chevron ruling, which seems to indicate that the court is going to come down much harder on agencies that exercise their discretion.

So, someone on the other side might say, "Given Chevron, if anything, FERC needs to be more cautious, more timid, more, you know, so as to not get shut down by the court." So, where do you come out on that question?

Allison Clements

Yeah, a couple of thoughts, and I'll start with the court case and then go over to the commission structure. But former Commissioner Norman Bay described FERC's jurisdiction as "unambiguously broad," and I like that term, because FERC has jurisdiction over the rates of wholesale sales of electricity and transmission and the practice affecting those rights. And historically, the framework that has developed has affirmed that broad jurisdiction. The courts have affirmed that broad jurisdiction. And so I think, absolutely, the commission hasn't, you know, kind of extended the bounds of its authority in any inappropriate ways and has the opportunity to do a lot more like what happened in Order 1920 and what might come from Order 2023 on interconnection.

So, I am less concerned, I'll say, about the Loper Bright decision in a post-Chevron world than I would be if I was at the EPA, for example. That's not to say it won't have any impact, but I think we are kind of within our explicit authority that has been affirmed by the courts for a long time. But we have some structural issues at the commission. So, we have, you know, the Federal Power Act isn't that long. We have two main sections, 205 and 206. The way that things get done at FERC is that under 205, the utilities want to change their tariff.

They want to change the way a market rule works. They want to change their interconnection practices. They come in and they file a 205 filing, and FERC says, thumbs up or thumbs down in 60 days. I think in 2017, there was a decision called NRG that basically said when these filings come in from the utilities, FERC can't modify them so much that it changes the nature of the proposal.

David Roberts

Oh, interesting.

Allison Clements

So, it really becomes a thumbs up, thumbs down. So, utilities can come in, make these proposals, and sometimes they have a lot of good in them, but a little bit of bad. But it's not worth rejecting the proposal over the little bit of bad that happens a lot these days. If FERC itself wants to stay under 206 instead, "Hey, we see a problem," like we did with regional transmission planning, like we did with interconnection, "we're going to go investigate that and decide whether or not those rates are unjust and unreasonable or discriminatory, and then we're going to go fix it."

That takes a long time and a lot of resources. Right. And so, it's hard to do that as a commission if you think it took us three years to do those two roles. And that's both by structure and resource constraints. We're staff. Right. People want to go home on the weekends. Like, it's a small agency with a big mandate.

David Roberts

Are we just stuck with that slowness? Or are there structural or funding or whatever changes that you could make to FERC that would make it more nimble? And what would that look like?

Allison Clements

Yeah, I think about that a lot. And people I worked with at FERC think about that a lot. There's a lot of soft power, convening power, appropriate coordination with the other agencies that could be done to get at issues. You know, when I have these conversations with hyperscalers or manufacturing companies or their trade associations or, you know, people who are thinking about how can we fix these problems quickly, or the — to me, it's how much can you do outside of the commission? How much can you do without the commission's help or blessing? You know, bake it and then bring it to us, come in and talk to us about it while it's baking.

But once you file it, we can't talk anymore. And so, I think that's one way to get around this structural barrier. But then, also, FERC can bring together DOE and Interior and the Department of Defense. Importantly, I think there's a huge opportunity for coordination between the Department of Defense and the commission. And, you know, sometimes that gets political and Congress worries about who we're talking to. I think as long as the commission is transparent and clear that it's providing expert advice, there is a lot of ways to drum up ideas and potential pathways forward outside of our, you know, 205, 206 rulemaking and proceeding process.

That's the best I've come up with so far.

David Roberts

What about just my old hobby horse, state capacity? What about just better funding FERC and more staff and more resources? Would that meaningfully help?

Allison Clements

Absolutely. You know, I can't imagine an energy-related agency at the federal or state level today that is sufficiently funded. No utility commission was set up to deal with the extent of change that has been happening for the last decade and will continue to happen for the next two. Right. And so, absolutely, I think all of the senior staff at FERC would appreciate me putting in a plug to whoever may be listening over on Capitol Hill.

David Roberts

Yeah, we love state capacity here at Volts. Speaking of FERC procedures, you took it upon yourself to think a lot about it and make changes to the Office of Public Participation. This is another hot button topic in the energy world and clean energy world. There's a set of people who say, especially, I think, around natural gas rulings, there's a set of people who say, "FERC is ignoring the public. There aren't enough opportunities for people to make themselves heard. It's difficult for people to make themselves heard. You're sort of riding herd over local objections and locals need more of a voice."

Then, there's this other group of people these days, the supposed sort of supply-side Dems, the whatever you want to call them, who say, "In almost every federal agency and every federal rulemaking process, there's too much chance, there's too many opportunities for locals to come in and stop things and slow things down. And it's making everything slow. It's making building anything really slow and more expensive than it needs to be and more uncertain than it needs to be." So, there's this sort of like split brain, I think, in the clean energy world, this ambivalence around public participation and how much is appropriate and what kind.

So as someone who has thought quite a bit about the Office of Public Participation at FERC, how do you sort of navigate between those sentiments?

Allison Clements

Yeah, well, I start with, FERC's job is to regulate in the public interest. And what's the public interest without the public as a starting point? That's my philosophy. But when I came to the commission, it was a good moment for public participation in that this requirement that the commission set up this office, which is meant to be a liaison to the public, stems back to the late 1970s. I think I might be wrong about this, but I think it was revisions to PURPA in the late seventies where FERC was told to set up an office.

David Roberts

And you're just now getting around to it.

Allison Clements

You know, funds didn't get appropriated, and then I forget. Then two decades went by and we didn't have an office. When I came into my role, I said to Chairman Rich Glick, "I want to lead on this. This is something I know a lot about, and I will not accept the false choice that you cannot build stuff, but build it well in terms of the impact it has on people and the environment." So, the intuitive starting place for the Office of Public Participation is these natural gas proceedings at FERC. But it's much, much broader than that.

These decisions that we make flow down to customers' bills, and it is hard to engage. It's hard to engage even for resourced advocates and regulated entities. So, what I focused on was ensuring that we had public input on what our Office of Public Participation should look like, which seems pretty straightforward. And then from there, we've had two really excellent directors. Elin Katz was the first director, and now Nicole Sitaraman. And, wow, they have just really brought credibility to the office. They have helped to start explaining this very specific, technocratic, hard-to-penetrate agency to people who care about what's happening at the agencies.

So, it's gone well beyond the borders of scoping sessions for new natural gas pipelines. But it's certainly, that is kind of the intuitive place where it makes a lot of sense that there's a direct impact on people and communities by the commission's decisions.

David Roberts

And have you heard from the public in ways that are, like, meaningful, that changed the way the commission decides a particular question? Like, has public participation been efficacious so far?

Allison Clements

That is the question. I think there is still more work to do. I think it's an ongoing long haul. I don't think we are there all the way yet, but I certainly do think that the way the processes are getting done at FERC, the consideration of comments, the way that we explain to interveners in writing and comments, has improved. And all of that I'll take. There's more to do, and I look forward to watching that happen.

David Roberts

Rule about compensating intervenors, because this is sort of like, one of the complaints is like a lot of the people who might want to give you feedback are poor or unorganized, or don't necessarily have the technical background and just can't afford to take time off work, et cetera. So there's talk about paying them some nominal amount to compensate for their time. Where is that rule now? Is that happening?

Allison Clements

There is no rule. This statutory language suggests that the office may provide intervener funding, and we held a workshop earlier on in my term where we had experts come in from different state commissions who provide intervener funding. So, there's a nice record of information. I'm wholly supportive of the concept. The reality is, it's a knotty issue to think about. Who qualifies? How much do they qualify? Who can they hire to represent them? So, that has not happened. There's a lot of things that got started at the commission that I hope will move forward, including this question of intervener funding.

There's a question about industry dues and whether or not customers should be paying for those. We are expecting guidance on environmental justice, so there are a few things that I'm really excited about that I'm looking forward to seeing what this commission does.

David Roberts

Well that kind of raises another question which I suspect you won't want to comment all that much on, but nonetheless, I would love to hear your thoughts, which is how, what's your, as a worrier, what is your degree of worry about what happens if Republicans win in the November elections and then FERC ends up with a three to two Republican balance? Do you worry about work that's been done getting undone? Do you worry about work just grinding to a halt? Do you have some hope that there's enough bipartisan overlap that things could still happen? What's your level of worry about all that?

Allison Clements

Yeah, less than you might think, to be honest. Will things change? Absolutely. My philosophy on the commission is that it is our job to ensure fair rates and protect reliability no matter what's happening in the world. And what's happening in the world is that, you know, we have 2.6 terawatts of new energy resources trying to get online, and they're all wind, solar, storage. There's advancements being made in geothermal. There's conversations around clean, firm, and we're on our way on the transmission front. The non-energy markets, the real markets, supply and demand, commercial customers, industrial customers, residential customers, they don't want to go back.

Right. The transition is happening, and so might we get a less strong implementation of some of these rules? Maybe. But if I were, you know, I do believe that that brings us back to where we started this conversation, which is that transmission is about a lot more than the color of the electron that's hooking up to the grid. And, you know, the people who serve in these roles of public service should have at the very front of their responsibility, what it takes to maintain this backbone of America's economy. So, I fear less about that piece.

David Roberts

Interesting. Okay, final question. I'm sure working on the commission for four years, you learned all kinds of things about the technical aspects of the grid and how it works and all sorts of questions about utility rules, etcetera. But aside from the technical stuff, I'm just curious, in your four years, this, I think, was your first four years in the belly of the beast, government service in the federal bureaucracy. I'm just sort of curious what you learned about people, bureaucracy, and rulemaking, and sort of just like, did you come away from the experience depressed about the government's ability to do things, or were you inspired, some mix?

Like, what did you learn about federal bureaucracy and your time therein?

Allison Clements

That's a big question. Washington is a very, very interesting place.

David Roberts

Interesting is one word.

Allison Clements

You know, some days it felt like a beast. And some days it felt like, "Wow, these are really important decisions, and I feel really fortunate that I get to sit at the table and try and come up with answers to them." I think I didn't understand — I fancied myself, you know, a sophisticated adult when I came to take this role. And I learned a lot about how politics infiltrates the entire city and our agency not excepted. But I also learned how the city works and that there are so many people here dedicated to getting things done. I learned that it's hard to be a regulated entity, it's hard to be a utility.

There is a lot of work to do. You're balancing a lot of interests. And I was known as someone who liked to be clear on my expectations about what they should do, and I'm proud of that. I think that should be the role of the regulator in this moment. But I also understand more intimately, I think, some of the challenges and difficulties in just getting to yes, and all these long list of items I would have liked to get done at the commission.

David Roberts

So interesting to talk to you. I'm so glad we got to chat. I'm so glad you were on the commission. A lot of exciting things. FERC is not, I think, what a lot of people would point to as the most exciting federal agency. But it's been really fascinating to follow for these last four years, in large part because you were there. So, thanks so much for coming on and talking through it all with us.

Allison Clements

Yeah, thanks for the time. I appreciate it. It was nice to chat.

David Roberts

Thank you for listening to Volts. It takes a village to make this podcast work. Shout out, especially, to my super producer, Kyle McDonald, who makes my guests and I sound smart every week. And it is all supported entirely by listeners like you. So, if you value conversations like this, please consider joining our community of paid subscribers at volts.wtf. Or, leaving a nice review, or telling a friend about Volts. Or all three. Thanks so much, and I'll see you next time.