Date filed: August 26, 2022
Docket No.: RM22-10
On August 26, 2022, the Electric Power Supply Association (“EPSA”) filed comments in response to the Federal Energy Regulatory Commission’s (“Commission”) June 16, 2022 Notice of Proposed Rulemaking (“NOPR”) which proposes to direct NERC to submit to the Commission modifications to Reliability Standard TPL-001-5.1 within one year of the effective date of a Final Rule in this proceeding to address reliability concerns pertaining to transmission system planning for extreme heat and cold weather events that impact the reliable operations of the Bulk-Power System (“BPS”). While the NOPR contemplates redefining transmission-related benchmark events, EPSA urges a holistic approach to mitigating the effects of extreme weather on the grid is needed to fully prepare the system for unexpected events. EPSA supports the NOPR and recommends that the Commission also consider directing NERC to examine how it defines and measures its resource adequacy benchmarks, including the impacts of non-dispatchable resources increasingly present on the system and the availability of dispatchable, flexible resources which are increasingly being replaced by new, less flexible resources or technologies. Further, in order to address tangible, reality-based reliability threats, the Commission must focus on market issues that impact system readiness – including the resources and services needed to maintain delivery of reliable, cost-effective power to consumers in all events and conditions.