United States of America Before the Federal Energy Regulatory Commission
Grid Reliability and Resilience Pricing | Docket No. RM18-1-000
Reply Comments of the New England States Committee on Electricity
The New England States Committee on Electricity (“NESCOE”) submits these reply comments pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) October 2, 2017 Notice in the above-captioned proceeding. For the reasons discussed below, NESCOE respectfully requests that the Commission decline to expand the scope of this proceeding by directing specific actions that commenters have proposed as alternatives to the Proposed Rule. Instead, the Commission should continue its long-standing support for regional flexibility in identifying, and fashioning appropriate solutions to, emerging challenges based on defined needs and the relationship between any proposed reform and its benefit to consumers.