On March 9, each of the FERC-jurisdictional Independent System Operators (ISOs)/Regional Transmission Organizations (RTOs) filed comments in FERC’s resilience proceeding, Docket No. AD18-7. FERC had requested that each jurisdictional ISO/RTO respond to a series of questions concerning: (1) the definition and understanding of the term “resilience,” (2) current methods for evaluating resilience, and (3) methods for evaluating options to mitigate risks to grid resilience. Comments were filed by:
- the California Independent System Operator Corporation (CAISO),
- ISO New England (ISO-NE),
- the Midcontinent Independent System Operator (MISO),
- the New York Independent System Operator (NYISO),
- PJM Interconnection (PJM), and
- Southwest Power Pool (SPP).
Notwithstanding that Electric Reliability Council of Texas, Inc. (ERCOT)’s grid does not fall under FERC’s Federal Power Act jurisdiction, ERCOT also filed comments in conjunction with the Public Utility Commission of Texas (PUCT).
Additionally, earlier in the week, the American Council on Renewable Energy, American Public Power Association, American Wind Energy Association, Electricity Consumers Resource Council, Large Public Power Council, National Association of Statute Utility Consumer Advocates, National Rural Electric Cooperative Association, Natural Resources Defense Council, Solar Energy Industries Association, and the Transmission Access Policy Study Group* submitted to Chairman McIntyre and the other FERC Commissioners a joint statement on “principles necessary to maximize the benefits of organized wholesale electricity markets.” FERC has docketed this letter in its resilience proceeding.
*The Transmission Access Policy Study Group is represented by Spiegel & McDiarmid LLP attorneys Cindy Bogorad and William Huang.