Background
According to the FERC news release, the 2020 global supply chain attack involving the SolarWinds Orion software demonstrated how attackers can "bypass all network perimeter-based security controls traditionally used to identify malicious activity and compromise the networks of public and private organizations." Thus, FERC determined that current CIP Reliability Standards focus on prevention of unauthorized access at the electronic security perimeter and that CIP-networked environments are thus vulnerable to attacks that bypass perimeter-based security controls. The new or modified Reliability Standards ("INSM Standards") are intended to address this gap by requiring responsible entities to employ INSM in certain BES Cyber Systems. INSM is a subset of network security monitoring that enables continuing visibility over communications between networked devices that are in the so-called "trust zone," a term which generally describes a discrete and secure computing environment. For purposes of the rule, the trust zone is any CIP-networked environment. In addition to continuous visibility, INSM facilitates the detection of malicious and anomalous network activity to identify and prevent attacks in progress. Examples provided by FERC of tools that may support INSM include anti-malware, intrusion detection systems, intrusion prevention systems, and firewalls.
New or Modified Reliability Standards
The INSM Standards will apply to all high-impact BES Cyber Systems and medium-impact BES Cyber Systems with external routable connectivity, defined as the ability to access a BES Cyber System from outside of its associated electronic security perimeter.FERC拒绝为即将实现的标准设定执行时间框架,代之以指令NERC提交建议书时推荐执行期,因此责任实体实施INSM的最后期限可能是未来数年 。
规则下INSM标准必须:
- (1)解决责任实体开发CIP网络环境网络流量基线的需要;
- (c) Implementing measures to minimize the likelihood of an attacker removing evidence of their tactics, techniques, and procedures from compromised devices.
Feasibility Study
Within 12 months of the final rule, NERC must also submit a report that studies the feasibility of implementing INSM within medium-impact BES Cyber Systems without external routable connectivity and all low-impact BES Cyber Systems, which are not subject to the INSM Standards.
FERC has emphasized that the commissioned feasibility study should include a determination of:
(1) The ongoing risk to the reliability and security of the Bulk-Power System posed by low and medium-impact BES Cyber Systems that will not be subject to the INSM Standards!并
类表示's样式缩放'>(2)As we have described in prior posts, the social cost of carbon is a tool that expresses in dollar amounts the estimated cost to society of a one metric ton increase in CO2 emissions. Developed by a federal interagency working group (IWG) originally to aid cost benefit analysis in rulemaking context, the tool also has potential use in the project approval, by informing agency assessments of environmental impacts under the NEPA. By and large, however, courts have accepted agency decisions not to utilize the SCC in their analysis, often relying on the well-established rule that NEPA generally does not mandate cost-benefit analysis. See 40 C.F.R.1502.22.
Enter Vecinos, the most recent decision in an evolving area of law. The case concerned FERC approval of liquefied natural gas export terminals and pipelines in Texas. As it has in past projects, FERC quantified the greenhouse gas emissions associated with construction and operation of the facilities, but declined to consider the significance of those effects on the project's contribution to climate change. The Commission justified this position on the grounds that there is no "universally accepted methodology to attribute discrete, quantifiable, physical effects on the environment to" an individual source's greenhouse gas emissions. Local residents, environmental groups, and a nearby city challenged, arguing, inter alia, that the Commission was obligated to use the social cost of carbon in light of 40 C.F.R.§1502.21,CEQ执行NEPA规范要求机构评估基于理论方法或研究方法的影响,即“科学界普遍接受”,即“无法获得可合理预见重大不利影响相关信息”。
d.C电路判定委NEP分析不充分。它关于碳 < ahrf='##ftn1命名s'#ftnref1>>>[1]社会成本的决定完全取决于FERC未考虑§1502.21的潜在效果,而FERC命令或简介中则未讨论或引用该作用。Circuit decision which had upheld FERC's decision not to use the social cost of carbon in other projects, which also did not discuss the regulation.[2]
Accordingly, on remand and in the future, FERC and other agencies will have to more directly evaluate the tool and the rigor of the science behind it. Proponents will argue that the social cost of carbon is the kind of "generally accepted" theoretical approach § 1502.21 requires be incorporated into NEPA: The IWG's SCC framework is at this point over a decade old, and was designed from the start to reflect scientific consensus, incorporating the three most widely cited climate economic impact models, each of which have been extensively peer reviewed. The National Academy of Sciences has recognized the tool and provided recommendations on how to strengthen it, which the Biden Administration is actively working to incorporate through an inclusive public process with stakeholders and experts to ensure that projections are based on the "best available science."
The decision is the latest in a series of cases assessing the adequacy of FERC's NEPA analysis. The D.C.电路要求FERC更充分地考虑核准项目气候后果, 特别是s/www.sierraclub.org/files/blog/FINAL%20ORDER%202020-22-17.pdf'Circuit made clear that it was stopping short of forcing the social cost of carbon on FERC. Indeed, the Vecinos court remanded the approval without vacating it, concluding it was "reasonably likely" that the Commission would be able to reach the same result even after discussing § 1502.21, and that vacatur could "needlessly disrupt completion of the projects." Construction of the facilities continues after the ruling.
Even if Vecinos does not result in broader adoption of the social cost of carbon in project approval, changes from the executive and legislative branches may, for FERC as well as other agencies. By the end of this month, the interagency working group will submit recommendations on "areas of decision-making, budgeting, and procurement" across the federal government where the SCC should be applied, which could include project approval and NEPA analysis. Regarding FERC specifically, President Biden will soon be expected to announce his replacement for Commissioner Neil Chatterjee, potentially shifting the Commission to a Democratic majority and providing additional support to Chairman Glick, who has vocally supported having the Commission consider the significance of greenhouse gas emissions and the social cost of carbon in NEPA analyses.
[1] Vecinos separately held that the Commission's environmental justice analysis was arbitrarily limited, as it did not discuss potential disproportionate effects more than two miles away from the project site.
[2] See EarthReports, Inc.公元前FERC ,828F3d949956Cir市2016年)appalachian声音vFERC 号17-12712019WL847199Cir市二月192019SierraClub公元前FERC ,672FedAppx3839Cir市2016年)
Driven by the entry of renewable generation resources locating far from load centers and the new demands placed on the grid by their differing characteristics, the Federal Energy Regulatory Commission (FERC) launched a comprehensive review of its policies regarding regional transmission planning, interconnection and cost-allocation. In an Advance Notice of Proposed Rulemaking (ANOPR), the agency requested public comments on its current policies and offered potential areas for reform with a view toward anticipated future generation. According to FERC Chairman Richard Glick, "(a) piecemeal approach to expanding the transmission system is not going to get the job done.We must take steps today to build the transmission that tomorrow's new generation resources will require."
This initiative is likely to result in specific proposals from FERC and ultimately reform of its rules and policies that could substantially change how the electric grid is planned and paid for. Accordingly, the ANOPR should be of interest to any company with a current or anticipated interest in, or use of, grid facilities.
This is the second initiative in as many months that FERC has taken a big step toward addressing the kind of grid needed for renewable generation As discussed in a prior post to the blog, last month FERC established a Joint Federal-State Task Force on Electric Transmission with state and local regulatory agencies to address barriers to transmission planning and development, opportunities for states to coordinate on regional transmission solutions, and barriers to interconnecting new resources.
The ANOPR
After providing a comprehensive discussion of its current policies regarding transmission planning, cost allocation and interconnection, FERC says "it is now appropriate to examine whether the existing regional transmission planning and cost allocation and generator interconnection processes adequately account for the transmission needs of the changing resource mix." Accordingly, the ANOPR identifies the following major aspects as potential areas for reform.关于每一方面,ANOPR请求评论当前政策的适当性并同时建议潜在的改革。
Identifying the benefits, cost and responsibility for grid facilities. One potential reform is to eliminate the current policy that requires interconnecting generators to pay the total cost of grid network upgrades that would not be needed but for the interconnection. FERC observes that a network upgrade may sufficiently benefit grid customers or later-in-time interconnections that it is appropriate to allocate the costs more broadly. Eliminating the policy could increase integration of generation by reducing cost uncertainty to resources in the interconnection queue and by removing a potentially prohibitive cost assignment to the resource first in line in the interconnection queue, which will bear the full brunt of needed grid upgrade costs that may also benefit resources next in line.
Enhanced transmission oversight. Given the potentially significant investment in transmission facilities to come, FERC is considering enhanced oversight of transmission planning and spending to ensure that transmission rates remain just and reasonable. For example, FERC could require that transmission providers establish an independent entity to monitor the planning and cost of transmission facilities in a region and to possibly provide advice on the design and implementation of the regional transmission planning and cost allocation processes.FERC also requests comment on involving state commissions in transmission planning and cost allocation processes and in limiting the costs that can be recovered for regional transmission facilities that are abandoned prior to going into service.
Commissioner statements
While the ANOPR was approved unanimously, all four commissioners issued concurring statements.[1]
Chairman Glick and Commissioner Clements issued a joint concurrence that provides a deeper discussion of certain topics than appears in the ANOPR, such as the extent of the shift toward renewable resources and the reasons for it. The concurrence is also more conclusory regarding how and why the current regional transmission planning, cost allocation and generator interconnection processes may no longer ensure just and reasonable rates for transmission service. Finally, the concurrence offers the following:
We anticipate that this effort will be the Commission's principal focus in the months to come.In addition to reviewing the record assembled in response to today's order, we intend to explore technical conferences and other avenues for augmenting that record—including through the joint federal-state task force (footnote omitted)—before proceeding to reform our rules and regulations.
Commissioner Danly's concurrence observes that many of the proposals would "exceed or cede our jurisdictional authority, violate cost causation principles, create stifling layers of oversight and ‘coordination,' trample transmission owners' rights, force neighboring states' ratepayers to shoulder the costs of other states' public policy choices, treat renewables as a new favored class of generation with line-jumping privileges, and perhaps inadvertently lead to much less transmission being built and at much greater all-in cost to ratepayers." Accordingly, Commissioner Danly requests that comments address whether each proposal is a proper exercise of the Commission's authority and the ultimate effect on ratepayers.
Commissioner Christie's concurrence notes that "(t)his consideration of potential reforms is especially timely as the transmission system faces the challenge of maintaining reliability through the changing generation mix and efforts to reduce carbon emissions" but notes that he does not endorse any of the proposals included in the order.
Comment deadlines
Initial and reply comments on the ANOPR are due 75 days, and 105 days, respectively, after publication in the Federal Register.
[1] Commissioner Chatterjee, whose term has expired, did not participate in this matter.
2017 Spire项目证书应用Louis大都市区输油管交付点项目主办人则称管道会提高可靠性和获取天然气新源,消除高需求期间对丙烷“峰值分层”的依赖SpireSTL主要依赖它与Spire密苏里公司达成的先例协议("Spire Missouri"), an affiliate, for approximately 87.5 percent of the Spire Project's capacity as evidence of need for the project.
In FERC's August 2018 order granting Spire STL's certificate application, the 3-2 Commission majority found that Spire Missouri's willingness to sign a binding contract to pay for pipeline service showed need or demand for the Spire Project. The majority rejected protestors' arguments that the precedent agreement was not a sufficient showing of need and that a market study must be undertaken. The majority noted that, since the issuance of the Certificate Policy Statement, FERC has relied on precedent agreements for a substantial amount of a proposed project's capacity as adequate evidence of need, even when the agreements are between affiliates, in the absence of anticompetitive or discriminatory behavior. According to the majority, Spire Missouri's affiliation with Spire STL did not require the Commission to look behind the precedent agreement to evaluate project need, principally relying upon the D.C.电路2014决策Envtl预科安全 v.FERC ,762F3d 97,114Cir市委前委Cheryl LaFleur和RichardGlick对2018证书令表示异议,发现记录没有显示Spire项目的必要性。 双方都认为,鉴于SpireSTL和SpireMeGlick专员(现主席)指出,当各方提出了相当多的可信关切,即先例协议是否可靠显示需要时,推理决策要求委员会做更多工作,而不仅仅是重申其接受表面价值先例协议的政策。2019年11月FERC2-1表决拒绝重审证书令请求Glick专员再次表示异议,辩称证书顺序表示“不合理应用...证书策略语句.电路判定
FERC证书和重听命令提交法院,法院依据SpireSTL申请抗诉者Environment Defe Fund(“EDF's”)提交审查申请,EDF断言FERC授予Spire项目证书的决定是任意和易变的,因为委员会完全依赖SpireSTL-SpireMeroi创举协议查找项目需求,未能充分证明它的结论,即项目福利大于不良效果。EDF认为,先例协议在FERCSireSTL证书应用评估中应只有有限证明价值,因为SpireSTL和SpireMeroy法院指出,FERC得到了有力的论据,说明SpireSTL和SpireMeroi法院补充道,委员会似乎认为单一先例协议是结论性协议,而不是参与这些论点。The court found that nothing in the Certificate Policy Statement endorses this approach.
The court distinguished this case from its opinions upholding prior certificate orders by noting that none of those cases involved precedent agreements with one affiliated shipper, and that FERC can put precedent agreements with affiliates on the same footing as non-affiliate precedent agreements only so long as FERC finds "no evidence of self-dealing." The court found that the Commission ignored record evidence of self-dealing by Spire STL, including that the pipeline was not being built to serve increasing load demand and that there was no indication the new pipeline would lead to cost savings.If it was unnecessary for the Commission to look behind the precedent agreement under these circumstances, the court added, "it is hard to imagine a set of facts for which it would ever be required." In summary, the court said that it found no judicial authority upholding a FERC certificate order when the proposed pipeline was not meant to serve any new load demand, there was no finding that the pipeline would reduce costs, the application was supported by only a single precedent agreement, and the counterparty to such precedent agreement was a corporate affiliate.
On the day the court issued its decision, FERC issued a statement saying that the Commission is considering what action may be appropriate in light of the court's vacatur.FERC发言中引用Glick主席的一段话,即他想重审委员会评估州际天然气管道需求的方法,作为其2月18日
FERC established the Task Force pursuant to Section 209(b) of the Federal Power Act, a rarely-invoked provision that authorizes FERC to confer with state commissions "regarding the relationship between rate structures, costs, accounts, charges, practices, classifications, and regulations of public utilities subject to the jurisdiction" of such state commissions and FERC. The June 17 order noted that transmission-related issues were ripe for federal-state coordination and cooperation given the respective authority of federal and state regulators and the resulting processes that transmission developers must successfully navigate.
The Task Force will be comprised of all five FERC commissioners as well as representatives from 10 state commissions, who will serve one-year terms, not to exceed three consecutively, in an advisory capacity.FERC请求NARUC向FERC提交10国委代表提名表(NERUC区域有2名代表)至7月17日收到NARUC提名后,FERC将发布后续命令,列出工作队成员及其作用,并确定第一次公开会议的时间和地点。
617命令中还包含问题说明,列出工作队可能考虑的专题,包括:(1) 识别阻碍规划和开发实现联邦和州政策目标所必要的最优传播的障碍以及潜在解决方案探索国家自愿协调的机会以确定、规划并开发区域传输解决方案并(3)审查通过FERC辖区互连进程高效快捷地连接新资源的障碍,以及解决这些障碍的潜在方法特别工作组就这些题目开展工作后,可向FERC建议可能修改其条例并开发记录供FERC和/或国家委员会程序使用。
还发布
A例,政策说明突出新泽西公共事业局和PJMInternectiveL.L.C.之间的协议方法研究协议,由FERC2月16日批准并前题 政策声明规定,只要州或传输提供方相信委员会司法收费协议或其他协议中存在自愿协议障碍,FERC鼓励他们考虑归档消除这些障碍政策说明进一步规定,委员会工作人员可以作为州、传输提供方和其他利益攸关方考虑消除这些屏障时一般咨询。
sp>FERC命令应引起广大电市场参与者的兴趣,包括水电公司、发电公司、存储和其他电源投资商和电客。
BackgroundFEREC标志性命令2222区域传输组织(“RTO”)和独立系统操作符(“ISO”)收费中包括专为允许DER聚合器参加有组织批发市场的条款As discussed in a prior post to this blog, a March 2021 rehearing order largely upheld Order No.2222但缩放允许零售监管者禁止DER聚合物批发市场。 FERC撤销对聚合物的这项“选出式”规定,其中包括DR组合资源和其他类型资源(“异式聚合物 ”),但允许选择退出继续应用单需求响应资源聚合物ferc.gov/sites/default/files/2021-03/E-2.pdf719要求RTOs/ISOs允许聚合商直接向批发市场竞价客户需求响应。FERC批发分布系统上或零售客户表后的资源提出了敏感联邦管辖范围问题。FERC允许零售监管局禁止零售客户需求响应由聚合商向RTO/ISO市场投标。
排除异类聚合法中包括选择退出条款中需求响应,2021年3月命令发现它们“不完全属于命令范围”。719选择退出.. 因为它们不单是零售客户聚合值.. 并利用资源的不同操作属性和辅助能力. 对比之下,只有需求响应资源汇总值与批量允许的零售客户聚合值“实质上互不相容 ” 。719选择出局. .strong> 最近重听顺序响应重听2021年3月命令的请求,FERC撤销其不扩展选择出局范围的决定,即不扩展DR资源参加多维DER聚合719通过广泛禁止DR参与RTO/ISO市场可能无法预期在这一聚合过程中会质疑这些广义禁止因此,汇总过程选择退出规定问题将在正在探索是否删除第20/2002号命令的NOI中充分审议719完全选出规定FERC将NOI初始评论日期延长到2021年7月23日。719或此进程中。
s719选择退出,表示它阻止许多州DR资源参与批发市场,无法与FERC法定职责相容,即确保公平合理率。With respect to limiting the ROE premium, all three Republican commissioners issued separate statements. Commissioner Christie voted in favor of the proposal but issued a concurrence basically taking aim at any premium added to a utility's allowed ROE. Commissioners Chatterjee and Danly both dissented from the proposal, arguing that it is inconsistent with the relevant statutory provision and cuts against FERC's policy objectives.
FERC's actions should be of interest to utilities, transmission-only companies, market participants who pay transmission rates, customers and investors interested in developing transmission projects.
Background
In 2005, Congress added section 219 to the Federal Power Act (FPA) directing FERC to provide by rule incentive-based rates (1) for new electric transmission facilities that either ensure reliability or reduce the cost of delivered power by reducing transmission congestion, and (2) for utilities and other transmission providers that join a Transmission Organization (TO), such as a Regional Transmission Organization (RTO).[1] FERC generally approves rate incentives for investments in transmission projects that present special risks or challenges, not routine investments. FERC also awards a 50-basis point adder to the ROE in the rates of transmission owners that join a TO in recognition of the benefits, risks, and associated obligations of such membership (the TO Incentive).
As discussed in a prior post to this blog, in March, 2020, FERC issued a Notice of Proposed Rulemaking (2020 NOPR) that proposed, among other things, to (1) discard the risks and challenges approach for evaluating incentive requests and instead focus on the benefits of new transmission investment, and (2) increase the TO Incentive from 50 to 100 basis points. FERC observed that planning, operating, and maintaining transmission infrastructure had changed considerably and that the types of needed transmission projects, and the rate treatments to incent them, must evolve to reflect the changes.
Modifying the TO Incentive
In a recent Supplemental NOPR, a divided FERC seeks comments on an additional proposal that would keep the TO Incentive at 50 basis points and subject it to a three-year term limit.
The Supplemental NOPR notes that although ratepayer benefits and utility risks and responsibilities from Transmission Organization participation have increased, many benefits accrue to transmission owners, such as access to more developed organized markets. Accordingly, the current 50-basis points TO Incentive, not the 100-basis points proposal in the 2020 NOPR, continues to appropriately correspond to the benefits of utilities joining TOs.
FERC also proposes to limit the term of the TO Incentive to a period of three years after a utility turns over operational control of its transmission facilities to the TO.委指出,规约只指向鼓励实体“加入”,因此FERC有权限限制鼓励加入而非保留加入According to the NOPR, an indefinite incentive may not be needed to incentivize a utility to join a TO, and may not appropriately balance utility and ratepayer interests, given the substantial benefits of TO membership to participating utilities and the large impact the incentive has on ratepayers. The proposed 3-year limit would apply to transmission owners whose rates now include the TO Incentive. Those owners would need to remove the incentive from their rates if the proposed term limit is adopted.
The Supplemental NOPR also requests comments on whether the TO Incentive should be limited to utilities that join a TO voluntarily.For example, should the incentive apply where participation in the TO is mandated by the state and/or other relevant electric retail regulatory authority? In addition, FERC wants comments on alternative, non-ROE incentives that are more appropriate for the TO Incentive.
The Supplemental NOPR only addresses the TO Incentive and does not address the other proposals in the 2020 NOPR.
Concurrence
Commissioner Christie says the Supplemental NOPR "moves in the right direction." He takes aim at any premium added to a utility's allowed ROE: "ROE adders needlessly burden consumers with substantial additional costs without demonstrable evidence that they actually incentivize the particular action they are aimed at incentivizing." In addition, Commissioner Christie notes that the public utility cost-of-service model is aimed at preventing the exercise of market power by charging a price higher than the market price, and adding basis points to the allowed ROE "makes the regulator not the guardian against market power, but the facilitator of it." Commissioner Christie agrees with the Supplemental NOPR's request for proposals for alternative, non-ROE incentives.
Dissents
Commissioners Chatterjee and Danly dissented from the Supplemental NOPR.
Commissioner Chatterjee, who was FERC chair when the 2020 NOPR was issued, disagrees with the proposed limits on the TO Incentive. He says that FPA section 219 does not limit incentives to utilities that "newly" or "voluntarily" join a TO and thus the proposal is inconsistent with the statute. In addition, the Supplemental NOPR does not address FERC's prior findings to not limit the incentive to new TO members.Commissioner Chatterjee also argues that the proposal is contrary to the current Administration's federal clean energy goals, which will require "robust organized markets and an enormous amount of investment in transmission." He says RTOs provide a platform for a successful energy transition but can only remain viable if existing utility members remain in RTOs, and lowering overall ROEs "may push investment away from transmission projects and towards other sectors of the economy or to lower risk projects."
Commissioner Danly dissents on somewhat similar grounds. He argues that the Supplemental NOPR is inconsistent with the statute, which directs FERC to provide incentives to a utility "that joins" a TO, not to encourage utilities "to join" a TO or that "voluntarily" joins a TO. In addition, Commissioner Danly argues the proposal "contradicts fourteen years of precedent interpreting unchanged statutory text." He also argues that reducing the benefits to utilities that join TOs "is not the signal we should be sending to utilities that, to date, have resisted RTO participation."
Comments on the Supplemental NOPR are due 30 days after the date of publication in the Federal Register, and reply comments are due 45 days after such publication.
The transmission incentive workshop
FERC also announced a September 10, 2021 workshop "to discuss certain performance-based ratemaking approaches, particularly shared savings, that may foster deployment of transmission technologies" More specifically, the workshop will address how to calculate ex ante and ex post benefit analyses for transmission technologies seeking incentives and issues associated with modeling approaches for various transmission technologies. More details will be provided in a supplemental notice.
[1] The term Transmission Organization includes an RTO, Independent System Operator, "independent transmission provider, or other organization finally approved by the Commission for the operation of transmission facilities."
FERC's opt-out provision for aggregations of demand response resources is rooted in its established policy allowing retail regulators to prohibit demand response resources from bidding into wholesale markets. In a separate order, FERC opened a proceeding to consider eliminating that opt-out provision as well.
Commissioners Danly and Christie are not on board with trimming the scope of the opt-out provision, and, in separate statements, said they would expand the opt-out provision.
FERC's orders should be of interest to a wide range of electricity market participants, including utilities, generation companies, investors in storage and other electricity resources and electricity customers.
Order No.2222 rehearing
Background
As discussed in a prior post to this blog, Order No.2222市场规则必须容留DER聚合物参与,这些规则必须解决:(1)DERs通过聚合直接参加RTO/ISO市场的资格问题;(2)DER聚合物定位需求在地理上尽可能可行RTO/ISO、DER聚合器、分发工具和相关电商零售监管机构之间的协调。
参与FERC批发市场分配系统或零售客户表后的资源联邦电力法赋予FERC跨州批发电权,而州则拥有发电配电设施以及零售销电权。2222,FERC拒绝质疑其强制实施拟议改革的权力,并拒绝允许零售管理机构授权或禁止DERs和/或DER聚合器参与RTO/ISO市场的请求(即分别选入或选出)。ferc.gov/sites/default/files/2021-03/E-1.pdf2222-A)提供几点澄清,但维护第221-A号命令的规定2222除外允许零售管理机构选择退出规定。响应重听请求,委员会排除选择退出规定DER聚合值i.e/em>,那些由不同类型资源组成,包括需求响应而非完全需求响应。
719号指令要求RTOs/ISOs允许聚合商直接向批发市场竞价客户需求响应。FERC允许零售监管局禁止零售客户需求响应由聚合商竞价进入 RTO/ISO市场 。719选出..................保证需求响应资源可与其他形式的分布式能源资源并发,有可能增强竞争并进一步FERC确保公平合理率的任务。719选出选择退出将继续适用于这些聚合物 。
Separate statements
Commissioner Christie dissented from the NOI order, stating that the "end game is to repeal or severely restrict the ‘opt-out' provisions of Order Nos.719." The dissent notes that eighteen states have chosen to use the opt-out provision, and FERC should respect those state policy decisions.
Commissioner Danly concurred. Although opposed to eliminating the opt-out provision, Commissioner Danly recognizes FERC "has the discretion to issue a Notice of Inquiry (NOI) on any topic within its purview." In the comments to be filed, Commissioner Danly is interested in evidence on whether wholesale demand response aggregation programs are providing reliability benefits commensurate with their costs. He notes that "anecdotal evidence suggests their performance during times of strain may be poor, and perhaps terrible."
Comments in response to the NOI are due 90 days after date of publication in the Federal Register, and reply comments are due 120 days after date of the NOI's publication in the Federal Register.
FERC开通程序说明从非电源向电源转换至最终消费点,如燃料车辆和提供供热和冷却,包括工业设施流程热量To that end, FERC announced an April 29, 2021 conference "to initiate a dialog between Commissioners and stakeholders on how to prepare for an increasingly electrified future."
While discussion at the conference could be fairly wide-ranging, it will likely focus on the impact of electrification on grid investment and operation and on wholesale electricity markets. FERC's notice for the conference lists the following general topics:
- Projections, drivers, and risks of electrification in the United States.
- How electrification may influence or necessitate additional transmission and generation infrastructure.
- Whether and how newly electrified sources of energy demand (e.g., electric vehicles, smart thermostats, etc.) could provide grid services and enhance reliability.
- The role of state and federal coordination as electrification advances.
The conference will be Commissioner-led and held electronically. More information on the conference will be announced by FERC in a supplemental notice.