Comments of Travis Fisher of the Cato Institute on the Advanced Notice of Proposed Rulemaking under RM26-4.
Travis Fisher of the Cato Institute submitted comments in support of "Consumer Regulated Electricity" (CRE) in FERC's "Interconnection of Large Loads" ANOPR. His key points were:
- Clarify that any physically islanded network—with no connection whatsoever to the broader grid—is exempt from Commission oversight and NERC standards.
- Commission oversight over CRE utilities would be unnecessary and represent a departure from the intent of Section 215 of the Federal Power Act, which was to prevent wide-scale, cascading outages on the bulk power system like the one experienced in August 2003 in the Northeast United States.
- Physically islanded networks as envisioned in the CRE concept should be excluded from FERC and NERC oversight.
https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20251124-5131