As a follow up to testimony before FERC in early May, ACCCE submitted post-Technical Conference comments on wholesale electricity markets. As we indicated at the Technical Conference, re-regulation by the states could be the most straightforward, long-term way to address many of the concerns about baseload sources of electricity.
Alternatively, FERC could lead the way in addressing these concerns. Here are some of the suggestions we offered to FERC:
- Establish criteria for grid resilience.
- Require analysis by all ISO/RTOs to determine the most resilient resource portfolios.
- Better define the respective roles of FERC, the grid operators, state regulators, utilities, NERC, and DOE in ensuring resilience and reliability.
- Adopt changes to electricity markets to properly value and compensate reliability and resilience attributes (on-site fuel, primary frequency response, inertia, etc.).
- Ensure that electricity market policies do not put the coal fleet at a disadvantage because of out-of-market subsidies for other resources.
In the meantime, we urge FERC to take steps to avoid more coal retirements until their potential impacts on grid reliability and resilience can be assessed.