Commissioners Mark Christie and Allison Clements Joint Statement
February 18, 2021
Docket No. AD18-7-000
Order: E-3
We write separately to emphasize that our agreement to terminate this specific proceeding is purely procedural, not substantive. The issues attendant to grid resilience and reliability that this particular proceeding raised are compelling and must command this Commission’s future attention. Procedurally, this matter has languished for more than three years with no action, so the unavoidable conclusion is that these issues need to be shifted to other procedural vehicles to make progress. On that basis, we concur.
As the widespread power outages this very week in Texas – as well as the outages in California last summer – graphically demonstrate, the challenges of ensuring a reliable supply of power to American consumers as the generation mix changes, remain as relevant and compelling as ever. Reliability to most Americans means power available 24/7; not just during good weather, but during bad weather, when they need it most to heat or cool their homes, operate their businesses, and to some consumers, even to maintain their very health.
We also agree that while there are general issues attendant to reliability and resilience, each RTO/ISO is different and faces different challenges from its generation mix and weather patterns. FERC’s job is to ensure that each RTO/ISO is meeting its individual operational responsibilities to ensure a 24/7 supply of power.
To meet that reliability challenge, the RTOs and ISOs must be willing to face and speak inconvenient truths about what is – and is not – feasible from an engineering standpoint, given the state of technology. They must also tell the public and the elected political leaders at both the state and federal levels about the realistic impacts on the bills consumers will have to pay for reliability. Politically driven mandates and deadlines may not be grounded in engineering reality and we depend on the leadership of each RTO and ISO to provide forthright information about what is needed to ensure the 24/7 power supply Americans expect.
Decarbonization is a necessary policy goal and preliminary reports from ERCOT, for example, indicate supply problems not only with wind resources, but also with gas and other forms of dispatchable generation as well. We should avoid drawing final conclusions about the events in these various RTOs/ISOs before complete investigations and reports are available. Common sense tells us, however, that as what is called the “energy transition” takes place, it must be grounded in the scientific facts of electrical engineering and physics, if Americans are to receive the reliable supply of power they need at the least cost to them.
Finally, we do not take issue with the sentiments contained in Commissioner Chatterjee’s dissent; indeed, we share them. Resilience and reliability issues remain compelling and unavoidable. Unfortunately this specific proceeding, which began long before we came to this Commission and is rooted in another proposal that was unanimously rejected, no longer appears to be the right vehicle. In that regard, we agree with Commissioner Chatterjee’s statement that he “. . . would prefer that the Commission grapple with the resilience concerns raised in this proceeding in a more comprehensive way.” It is our hope that this Commission will do exactly that – and soon.