Seven Best NOPR 'Micro-Comments'

These are the seven winners! The best of the “micro-comments” you all submitted to us, on the controversial consequential FERC NOPR.

FERC’s decision is due December 11. FERC would save a whole lot of time if it simply used these rather than reading through the thousands of pages of comments it has received.

Recharge the Economy with Renewable Energy Tax Credits

1. NARUC: The Federal Power Act requires that FERC give full deference to the States’ longstanding authority over electric generation facilities and the manner in which each State has exercised such authority to choose for itself the appropriate form of rate regulation and generation resources. This proposal contravenes the States’ authority.

2. Exelon: Exelon encourages FERC to first correct long-standing flaws in the way energy prices are set in PJM that disadvantage resilient power sources, and then to evaluate how to strengthen the nation's power supply against major disruptions and place a value on the uninterrupted emissions-free energy provided by nuclear plants.

3. Ed Smeloff, Vote Solar, in a poem: Darkness crawls across the grid/Piles of coal freeze with the snow/Winds fall poles, an errant balloon/Trips the switches, while frightened squirrels/Ground pointless threats about freedom's price. To understand resiliency you need to know/There is no sense in the NOPR.

4. Paul Stockton, former Assistant Secretary of Defense: At DOD, I helped lead the Department's response to Superstorm Sandy, Deepwater Horizon and other disasters. Ensuring resiliency in preparation for emergencies is crucial, and DOE is right to identify the increased dependence of power generation on natural gas as a potential risk to U.S. natural security. Current initiatives to identify and mitigate risks of gas-electric system interdependencies are simply not adequate.

5. Massachusetts Attorney General Office: DOE’s NOPR violates the Commission’s legal rulemaking obligations and, if finalized, would violate the Federal Power Act. It would do nothing for electric reliability, do sweeping damage to competitive wholesale electricity markets, undermine state energy and environmental laws and policies, and lock in excessive customer costs. Just say no.

6. Metin Celebi, Judy Chang, Marc Chupka, Sam Newell, Hannes Pfeifenberger, Ira Shavel, The Brattle Group: DOE’s proposal would cost $3.7–$11.2 billion/year and undermine competitive markets without providing any demonstrated or measurable resilience benefits. Even if coal and nuclear generation were critical for resilience, the proposal’s focus on a region with plentiful coal and nuclear generation (PJM) would appear misplaced. 

Recharge the Economy with Renewable Energy Tax Credits

7. Anonymous, in classic rock titles: The Pleadings can be summarized – FERC to Stakeholders: There's something happening here; what it is ain't exactly clear (Buffalo Springfield). NOPR Responses: Money for nothing (Dire Straits)/Let the sun shine (Fifth Dimension)/The answer is blowin’ in the wind (Dylan)/Take the money and run (Steve Miller)/Would I lie to you? (Eurythmics)/I can't get no satisfaction (Stones)/You can get it if you really want it (Jimmy Cliff)/Whatever it is you're looking for, don't come around here no more (Tom Petty)/If I had a [b]illion dollars (Bare Naked Ladies)/It's a legal matter (The Who). What We Want from FERC: Tell me something good (Rufus).


Is your organization impacting the debate as a member of the PUF community? Nearly two hundred utilities, commissions, consumer advocates, associations, agencies, professional firms and vendors are members. How about yours?

Steve Mitnick, Editor-in-Chief, Public Utilities Fortnightly
E-mail me: