Commissioner Allison Clements Statement
April 19, 2022
Docket No. EC16-77-002

I vote to support this extension of BlackRock’s blanket authorization because the request is consistent with BlackRock’s previous authorization and extensions, existing Commission rules and recent precedent.  I write separately, however, to express my growing concern that the Commission’s tools to evaluate the effects of such authorizations may be insufficient. 

I acknowledge Public Citizen’s concerns about the lack of analysis on the effects on competition, just and reasonable rates, and regulation related to the accumulation of acquired interests in public utilities.  In line with these concerns, I encourage further generic consideration of the analysis required by the Commission when evaluating blanket authorizations under FPA section 203(a)(2) to ensure that transactions entered thereunder do not have an adverse effect on competition and that entities granted such blanket authorizations lack control over the utilities whose interest they acquire.

As these types of entities increasingly emerge as material investors across public utilities, it is important for the Commission to consider whether its analysis in considering these blanket authorizations remains sufficient to ensure that transactions made under the blanket authorizations are within the public interest, including that they do not have an adverse effect on wholesale rates.

For these reasons, I respectfully concur.


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