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Comments to FERC on Electric Grid Resilience Order

The Federal Energy Regulatory Commission (FERC) requested feedback from regional electricity regulators on the state of resilience in wholesale markets, efforts underway to ensure grid resilience, and opportunities for future improvement. Their responses make clear that while grid resilience is an issue worthy of continued attention, there is not currently evidence to support mandatory, national or even regional action to address acute resilience concerns.

Our comments to FERC argue that it should not seek a “one-size-fits-all” solution for all Regional Transmission Organizations and Independent System Operators (RTOs/ISOs), nor should it consider resilience a “catch-all” concept that opens the door to otherwise unsupported or unnecessary actions. FERC should instead encourage RTOs/ISOs to conduct cost-benefit analyses in order to justify resilience-based policy changes, noting that the Commission’s existing authorities are sufficient to address threats that are identified, if any.

Read our initial and reply comments to FERC on Grid Reliability and Resilience Pricing.