Calling power grid resilience potentially one of the most important issues to be addressed by the Federal Energy Regulatory Commission "in a generation," Commissioner Neil Chatterjee urged stakeholders from all sectors of the energy industry to weigh in on the matter.
The nation's regional grid operators recently filed their responses to questions FERC posed in January on maintaining the resilience of the power grid, including one that asked them to define resilience and explain how it differs from reliability. They also described the natural and man-made threats potentially impacting system resilience in their regions, outlined the steps they have taken to ensure that resilience, and offered suggestions on action that can be taken going forward.
But now is the time for everyone else who has an interest in the issue to give FERC their views, even if they are members of a trade or other interest group that is submitting comments on behalf of that organization, according to the commissioners.
"My advice to any interested parties who are on the fence about whether or not to submit comments, no matter what side of the spectrum you are on or where your interest lie, is this: Err on the side of caution. Make your voice heard," Chatterjee said during the agency's March 15 regular open meeting. "These submissions are, in part, the foundation upon which my colleagues and I will assess this issue."
FERC Chairman Kevin McIntyre echoed that sentiment.
"The resilience of our bulk power system is a priority at the commission; it's a critical issue for the American people and for our economy and for our national security," McIntyre said. "And it is imperative that we base our next steps on the best available information."
The resilience proceeding stems from a September 2017 U.S. Department of Energy proposal aimed at providing more financial support to struggling nuclear and coal-fired generating units. Worried about the threat to grid resilience potentially posed by the premature retirement of baseload generating units, the DOE directed FERC to establish new market rules that would provide full cost recovery and a return on investment to certain generators that can stockpile a 90-day fuel supply.
The plan was opposed by many stakeholders out of concern that it would distort existing power markets, but coal and nuclear advocates generally viewed it as necessary to fix what they consider to be the faulty market rules spurring the early retirement of baseload power plants.
While FERC on Jan. 8 rejected the DOE's proposal (FERC docket RM18-1), finding it to be legally unsupported, the agency also initiated a new proceeding (FERC docket AD18-7) specifically aimed at examining the resilience risks facing the bulk power system. The six FERC-approved independent system operators and regional transmission operators — the Midcontinent ISO, PJM Interconnection, ISO New England, Southwest Power Pool, New York ISO and California ISO — as well as the Electric Reliability Council of Texas all responded to the commission's request for comments on March 9.
During the March 15 FERC meeting, McIntyre thanked the grid operators for their timely submissions and invited any other interested parties to weigh in before April 9, stressing that he has his colleagues "have an open mind on these issues" and that their work "will benefit from as much good and thoughtful input as possible."
"Although our January order's description of the comments process characterized the next round of comments as reply comments, in my view, interested entities should feel free to submit to us their own views independent of anything put forward by the RTOs and ISOs," McIntyre said.
