Item E-3: Commissioner Neil Chatterjee Dissent Regarding Grid Resilience in Regional Transmission Organizations and Independent System Operators

Commissioner Neil Chatterjee Statement
February 18, 2021
Docket No. AD18-7-000
Order:  E-3

I oppose today’s order terminating the Commission’s proceeding to evaluate the resilience of the bulk power system. 

I acknowledge that the issues teed-up in this proceeding are multi-layered and complex.  I also acknowledge that this proceeding has politically charged origins beginning with the Department of Energy’s (DOE) initial proposed rulemaking to compensate certain categories of generators with on-site fuel.  However, a unanimous,
bi-partisan Commission rejected DOE’s proposal and, in its stead, posed fuel-neutral, critical questions about what it means to have a resilient grid and what steps the Commission can take to foster it.[1]  Those questions and their answers remain as critical today as they were three years ago.

Despite thorough examinations of previous cold weather events,[2] we find ourselves wondering what went wrong this week when much of the nation encountered extreme cold weather that led to load shed in ERCOT, MISO, and SPP.  Initial reports suggest that, as with previous cold weather events, these regions experienced unusually high demands, inadequate natural gas supplies, frozen infrastructure, correlated generation resource outages, and varying levels of load shed.

The severity of this week’s event – measured in duration, geographic scope, amount of load shed, customers affected, and amount of unplanned generation outage – suggests that, despite the lessons learned and actions taken in the past to improve winterization and gas-electric coordination, the bulk power system may not be able to adequately withstand extreme cold weather events. 

I am concerned that extreme weather events will continue to increase in frequency and severity, and present serious risks to the resilience of the bulk power system.  The majority casts resilience as a question best addressed on a region-by-region basis by emphasizing that wildfires, hurricanes and cold snaps are threats that “present stark, but different challenges to the reliability of the electric grid.”[3]  That goes without saying, but the majority ignores the fact that these threats – as illustrated by this week’s event – do not respect regional boundaries.  As such, I believe that terminating this resilience proceeding, in the face of clear and continuing weather-related resilience concerns that affect multiple regions, is ill advised. 

I would prefer that the Commission grapple with the resilience concerns raised in this proceeding in a more comprehensive way.  The Commission is well positioned to, for instance, adopt a definition of resilience that could be implemented in all regions, describe categories of resilience concerns that would include extreme weather events and common-mode failures, and then take additional steps to ensure that the Commission, RTOs/ISOs, and stakeholders can understand how each RTO/ISO assesses the resilience of its region.  Such assessments would enable a comparative, cross-market view of how each RTO/ISO identifies and addresses resilience needs and would enhance coordination across regions.  Such a holistic review would not only assist RTOs/ISOs and their stakeholders in considering different approaches to these efforts, but also help the Commission understand how to best assess and address bulk power system resilience.

I emphatically support accelerating our nation’s transition to a cleaner, more flexible grid.  That is why I am not satisfied with a piecemeal, passive approach to ensuring its resilience, especially in the face of anticipated load increases due to economy-wide electrification goals.  Rather, I have long supported pressing forward with the fuel-neutral, bi-partisan review that the Commission began three years ago.

For these reasons, I respectfully dissent.