FERC Seeks Input on Electric Reliability Issues From Climate Change and Extreme Weather Events

Holland & Knight LLP

Holland & Knight LLP

The Federal Energy Regulatory Commission (FERC) has invited public comment by April 15, 2021, on its recently opened proceeding (Docket No. AD21-13-000), which FERC has stated "will examine how grid operators prepare for and respond to extreme weather events, including, but not limited to droughts, extreme cold, wildfires, hurricanes, and prolonged heat waves."

The March 15, 2021, supplemental notice provides interested persons an opportunity to comment on 17 questions in advance of the public technical conference that FERC staff will convene on June 1-2. FERC intends to utilize the technical conference to address various "issues surrounding the threat to electric system reliability posed by climate change and extreme weather events."

The questions frame the discussion for the technical conference and include the following topics:

  • near-, medium- and long-term challenges posed to electric system reliability due to climate change and extreme weather events
  • frequency and intensity of extreme weather events
  • accounting for the long-term impacts of climate change in the way generation, transmission, substation or other facilities are designed, built, sited and operated
  • electric system reliability challenges associated with "common mode failures" and the steps different energy systems can take to improve coordinated operations and planning to help reduce such common mode failures
  • current and future role of relevant regulatory authorities, individual utilities and regional planning authorities, and additional measures they should consider implementing (e.g., changing modeling and planning assumptions)
  • effectiveness of seasonal resource adequacy assessments
  • changes to the current resource outage planning process
  • using mass public notification systems to solicit voluntary reductions in the demand for electricity during an extreme weather-related emergency
  • improvements to recovery times following outages caused by extreme weather events
  • identifying potential changes to FERC ratemaking practices and market design, North American Electric Reliability Corporation (NERC) Reliability Standards and areas where FERC can collaborate with the states

Following comment submissions, FERC staff will issue an additional supplemental notice with further details regarding the technical conference agenda.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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