Joint reply comments on FERC�s grid reliability and resilience pricing notice of proposed rulemaking

Pursuant to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) October 2, 2017 Notice Inviting Comments, the following entities (collectively, “Joint Industry
Commenters”) submit reply comments:

  • Advanced Energy Economy
  • Alliant Energy Corporate Services, Inc.
  • American Biogas Council
  • American Council on Renewable Energy
  • American Forest & Paper Association
  • American Petroleum Institute
  • American Wind Energy Association
  • Conservation Law Foundation
  • EDP Renewables North America LLC
  • Electric Power Supply Association3
  • Electricity Consumers Resource Council
  • Energy Storage Association
  • E.ON Climate & Renewables North America, LLC
  • Independent Petroleum Association of America
  • Interstate Natural Gas Association of America
  • Invenergy Thermal Development LLC
  • Natural Gas Supply Association
  • NextEra Energy Resources, LLC
  • Solar Energy Industries Association
  • Vestas-American Wind Technology, Inc.

Each of the entities supporting this joint filing urged the Commission in initial comments to reject the proposal by the Secretary of Energy (“Secretary”) for discriminatory payments to certain merchant coal- fired and nuclear generators made in the Notice of Proposed Rulemaking (“DOE NOPR”).4 For the reasons described herein, the entities joining these reply comments continue to urge the Commission not to adopt the DOE NOPR.

Download the full comments here.