Energy Associations File Comments Opposing Proposed Electric Grid Resiliency Pricing Rule

12 associations representing oil, natural gas, wind, solar, efficiency, and other energy technologies today submitted comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) proposed rulemaking on grid resiliency pricing. In joint comments, the associations urged FERC to not adopt DOE’s proposed rule to provide out-of-market financial support to uneconomic coal and nuclear power plants in the wholesale electricity markets overseen by the commission.

Specifically, the associations’ comments state that:

• DOE’s request for a rule that provides discriminatory compensation to certain coal and nuclear resources is based on a “justification for the proposed payments – resiliency – [which] is not well defined, nor is it demonstrated to be lacking” in the regions that would be affected by the rule
• The DOE request “fails to provide substantial evidence” for its claim that “RTO/ISO markets do not adequately value fuel security,” and fails to justify its conclusion that “full cost of service payments are therefore needed to prevent ‘early retirement’ of resources with 90 days of on-site fuel supply”
• Rather, “there is substantial evidence showing that electric systems that lack, or are transitioning to lesser reliance on, coal and nuclear resources are nonetheless operated in a manner that is both reliable and resilient,” and that “outages caused by disruptions of fuel supply to generators appear to be virtually nonexistent.”
• Therefore, the proposed DOE rule would “prop up uneconomic generation that is unable to compete … and that is not otherwise needed for reliability.”
• “Accordingly, the proposed rule has not been shown to be just and reasonable and cannot be adopted by the Commission.”

The comments were submitted by the following associations:

• Advanced Energy Economy
• American Biogas Council
• American Council on Renewable Energy
• American Petroleum Institute
• American Wind Energy Association
• Electric Power Supply Association
• Electricity Consumers Resource Council
• Energy Storage Association
• Independent Petroleum Association of America
• Interstate Natural Gas Association of America
• Natural Gas Supply Association
• Solar Energy Industries Association

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