ESA Comments to FERC on DOE NOPR
ESA filed comments to FERC following the Secretary of Energy’s September 28, 2017 proposal, recommending that FERC not adopt the proposed rule.
Instead, ESA recommends that FERC work with the North American Electric Reliability Corporation (“NERC”) and other stakeholders to first establish a framework for defining and measuring the grid’s resilience. ESA recommends that, subsequent to that effort, FERC initiate a proceeding to identify and value the full range of electric system resilience attributes that are inadequately compensated or uncompensated, as well as technology-neutral approaches to compensating any desired resilience attributes.