A4CRE's Comments to FERC on Resource Adequacy
We submitted comments following FERC's recent technical conference on resource adequacy. Our key points for purposes of this docket were:
(1) "Consumer Regulated Electricity" (CRE) utilities offer economic and reliability benefits to the RTOs and ISOs by reducing the resource adequacy strain and protecting existing ratepayers from the financial risks of overspending on infrastructure upgrades. Every data center or large facility served by a CRE utility represents a reduction in stress on the existing grid and a potential decrease in costs for ratepayers.
(2) The Commission should clarify that any network that is truly isolated—indeed, physically islanded—with no synchronous or asynchronous connection to the broader grid is exempt from Commission oversight.
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