• FERC Commissioner Issues Request for Comments
  • February 15, 2012
  • Law Firm: Troutman Sanders LLP - Atlanta Office
  • On February 3, 2012, FERC Commissioner Phillip Moeller (R) released a request seeking comments from natural gas and electricity markets on ways to become more coordinated and ensure reliability.  Commissioner Moeller’s request stems from the increased use of natural gas in electricity generation and the southwestern power outage in February 2011.

    In the request for comments, Commissioner Moeller specifically seeks comments on:

    • What role should FERC have in overseeing better coordination?  What duties, if any, should be delegated to the North American Electricity Reliability Corporation, the North American Energy Standards Board, or other entities?
    • To what extent should FERC defer to various regions of the country in addressing these challenges? Should FERC view organized electricity markets differently from bilateral electricity markets? If regional deference is given, what role should FERC play to assure that regional agreements are adhered to?
    • Whether FERC needs to address the issue that the expanded use of natural gas for electricity generation is likely to change flows on the natural gas pipeline system?
    • How should FREC aide in syncing the electricity and gas trading markets?
    • What will be the impact of the expected retirements of coal and oil-fired generation on the need for gas and electricity coordination?
    • To what extent should FERC consider modifying its existing Standards of Conduct with regulated utilities—either on an emergency basis or in a more fundamental manner—to assure greater coordination of these industries?
    • Will progress on this issue be faster if policies are addressed in several “baskets”, such as communication, operation, contracting, and planning/contingency analysis? If so, what are the appropriate “baskets”?

    Commissioner Moeller has requested comments be submitted by February 29, 2012.  Comments should be emailed to [email protected].