FERC Calls NJ Rate Counsel for Advice

Today, FERC disclosed a conversation between an internal FERC energy Analyst named John Collins and the NJ Rate Counsel.  I’ve uploaded a complete copy below:


What this appears to be is an admission from FERC that a junior staffer broke ex parte rules and reached out directly to the NJ Rate Counsel to try out some information.  Per those rules, they are now required to disclose the substance of that discussion.

Mr. Collins asked a series of questions around affiliate relationships, who exactly is regulated by the BPU, how “need” is determined by the BPU, and – here’s the kicker – “Why are New Jersey Local Distribution Companies signing up for PennEast capacity“?

Along the way Mr. Collins specifically asked about South Jersey Gas and New Jersey Resources, and in conjunction with that asked “How are affiliate relationships evaluated in the sense that there is a potential for self-dealing abuse?”.

He asked “How is the need for additional gas capacity determined by the NJ BPU“?

And finally:

Is there expected gas demand growth in the service territories of these entities“.

NJ Rate Counsel Stefanie Brand more or less replied that all of the answers to these questions could be found in her lovely “Comments of the New Jersey Division of Rate Counsel” to FERC on September 12th on the PennEast docket, and further educated Mr. Collins on how the NJ markets work.


I wouldn’t read too much into this – this isn’t an official FERC line of inquiry on the PennEast application, it’s a curious FERC economist trying to understand PennEast in more detail.

Mr. Collins himself is firmly embedded in the energy industry.  Here’s his linkedin page:



He has a Bachelors in Civil Engineering, a Masters from the Colorado School of Mines, and a second Masters in Petroleum Economics and Management.  He is still pretty young but has a very impressive educational pedigree, and is currently an analyst and Economist for FERC.

Here’s the important part – someone with that background inside of FERC is asking the same comments that we are.  If nothing else, this once again serves as a validation that our analysis of total lack of public purpose and need for this project is correct, and that the whole PennEast proposal has a number of suspicious and troubling aspects to it.

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Mike Spille

I'm a thinker, an analyzer, a synthesizer. Maybe not in that order. I live in West Amwell NJ with my wife Kristina, our two kids Day and Z, our two dogs Fern and Cinna, and three cats Ponce de Leon, Oliver, and Doolittle.

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