NRECA filed comments with the U.S. Federal Energy Regulatory Commission (FERC) in its proceeding to evaluate the resilience of the bulk power system in the regions operated by RTOs and ISOs. Electric cooperatives support maintaining an "all of the above," diverse portfolio of power-supply resources to maintain safe, affordable, and reliable power for their consumer-members. NRECA believes that FERC's development of wholesale market design policies to address bulk power system resilience in RTO and ISO regions should be guided by the following principles:
- RTOs and ISOs should have flexibility in determining resilience needs and devising regional solutions;
- Resource compensation for bulk power sytem resilience services should be based on the technical ability of the resource to provide such services;
- Resource compensation for bulk power system resilience services should be market-based where feasible;
- Load-serving entities should be allowed to self-supply bulk power system resilience services and should not be required to pay twice for such services;
- Costs for compensating resources for bulk power system resilience services should be just and reasonable and should be allocated on a cost-causation basis; and
- FERC actions to ensure bulk power system resilience should preserve the ability of local utilities and their state and local regulators to ensure safe, affordable, reliable, and resilient electric service.