DOE Grid Resiliency NOPR Comments
Synapse was retained by Earthjustice to draft a whitepaper discussing grid resiliency issues in the context of the United States Department of Energy (DOE)’s “grid resiliency pricing rule” proposal. DOE’s proposal directed the Federal Energy Regulatory Commission (FERC) to design rules that would guarantee full recovery of costs for all generating units operating in competitive wholesale markets with 90 days of fuel supply on-site (conventionally understood to refer to nuclear and coal-fired units). Synapse’s whitepaper discusses several key problems associated with this proposal: first, the authorities in charge of the nation’s wholesale energy markets (including FERC itself as well as ISO/RTOs and state agencies) have devoted substantial efforts to increasing the reliability and resiliency of the grid system and have reasonable, market-based approaches for accomplishing this goal. Second, fuel supply disruptions have not historically been a significant cause of service interruptions. Third, coal units in particular are vulnerable to both fuel supply disruptions and other failures during extreme weather and temperature events, and have demonstrated decreasing reliability over time. Synapse’s whitepaper was filed under FERC docket RM18-1-000 in support of comments submitted by Earthjustice, Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), Sierra Club, Sustainable FERC Project, the Union of Concerned Scientists (UCS), the Center for Biological Diversity, the Environmental Law and Policy Center, the Southern Environmental Law Center (SELC), Conservation Law Foundation (CLF), Environmental Working Group, and Fresh Energy.