Patricia Alexander is a senior policy advisor in Crowell & Moring's Washington, D.C. office. Patricia is an economist who participates in cases involving the energy industry with a special emphasis on the regulatory requirements of the Federal Energy Regulatory Commission (FERC) and general electricity matters. She has provided advice to clients on a number of FERC rulemakings dealing with market-based rates, open access transmission tariffs and standardized interconnection procedures, integration of variable resources, streamlined interconnection procedures for small renewable projects, development of price indices and reporting of price data by industry participants, electronic filing of rate schedules and market data, and affiliate conduct rules.
Patricia teams with the attorneys in the firm's Environment, Energy and Resources (EER) Group to assist clients in their negotiations and other dealings with FERC-regulated utilities, ensuring that the legal, regulatory policy, and business aspects are identified and addressed promptly and consistently. She also assists clients in litigation arising at FERC and other judicial forums involving regulatory matters. Her knowledge includes the market rules and practices of regional transmission organizations (RTOs), FERC open access and interconnection rules, the FERC's requirements for market-based rates and other regulatory approvals, generator interconnection procedures and cost allocations, and qualifying facilities rights and obligations. In addition, Patricia provides advice on the FERC's regulatory policies and precedents to clients that are seeking to advocate positions in FERC proceedings on matters dealing with traditional and innovative ratemaking, industry restructuring, market design, and market power. She also provides advice on compliance with FERC regulations, market rules, and reliability standards, and assists clients in developing compliance programs and providing staff training on these matters.
Patricia brings 21 years of experience with the FERC to the firm. From 1999 to 2001, Patricia served as the electric policy advisor to FERC Chairman James J. Hoecker. In this capacity, she counseled the chairman on all electric matters, including all petitions and applications before the FERC, all legislative matters affecting the FERC or the electric industry, and all policy issues involving the electric industry. Patricia also served as the chairman's liaison with the other FERC members with primary responsibility for developing consensus positions on critical policy choices raised in the electric area.
Patricia played a central role in the FERC's initiative to restructure the electric industry into RTOs. Patricia directed the Order No. 2000 rulemaking project which established the FERC's philosophy, policies, and requirements with respect to RTOs. Order No. 2000 identified continuing impediments to the development of competitive bulk power markets that occur when vertically integrated utilities own and operate the transmission grid, developed a framework to ensure independent operation of the transmission grid on a regional basis, and designed a spectrum of innovative transmission pricing options that would support this framework.
Before joining the chairman's personal staff, Patricia served in the FERC's Office of Electric Power Regulation (OEPR) as deputy director in the division responsible for all electric rate and tariff matters filed with the FERC. In this capacity, Patricia was significantly involved in all of the FERC's electric initiatives. Some of those initiatives are described below.
Patricia managed the implementation of the FERC's landmark open access transmission rulemaking (Order No. 888) which required all public utilities to provide comparable open access transmission services. During the implementation stage, more than 100 public utilities tendered new open access tariffs and transmission rates. In ruling on these tariff proceedings, the FERC's open access policies continued to evolve as the principles set forth in Order No. 888 were transformed into real-world transmission rules and pricing. A major part of the Order No. 888 implementation involved the restructuring of several large power pools into Independent System Operators (ISOs) which became the precursors of the RTOs addressed in Order No. 2000.
Patricia counseled the FERC in all areas of innovative transmission pricing, including network transmission pricing rate designs, incremental pricing rules, issuance of the FERC's Transmission Pricing Policy Statement, the implementation of locational marginal pricing in 1996 to allocate constrained transmission capacity, and, as noted above, the development of a spectrum of innovative transmission pricing options for RTOs.
Patricia also advocated and supported the transition from traditional cost-based regulation of generation to competitive market-based regulatory approaches; and managed the implementation of related legislative initiatives, including the Energy Policy Act of 1992. She also played a key role in developing the FERC's involvement in monitoring competitive power markets and developing mitigation strategies to address market power concerns.
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