WIRES is submitting comments today in response to the Federal Energy Regulatory Commission (FERC) proceeding on Grid Resilience, asserting that a robust transmission grid offers resource diversity and operational flexibility that is critically important to prevent, mitigate, and recover from service disruptions.  In Docket No. AD18-7-000, FERC proposed that independent system operators (ISOs) and regional transmission operators (RTOs) consider how to make the grid more resilient in the face of new threats to it.

WIRES applauds FERC for initiating this review of the challenges confronting America’s electric grid so that families and businesses can maintain access to reliable and affordable electricity that sustains our standard of living.  In the filing, WIRES underscored that, because grid resilience will only increase in importance as the economy continues to become more dependent on electricity, consumers have a large stake in development of a modern and robust transmission system that delivers power for tasks as varied as texting and emailing to life-saving medical procedures and transportation.  At the same time, cyber and physical threats, as well as natural events of unparalleled ferocity and unpredictability, pose new challenges to our increasingly electrified economy.

“Factors that make the grid more resilient must drive the regional and interregional transmission planning processes of the ISOs and RTOs in ways they don’t currently,” said James Hoecker, WIRES executive director and former FERC Chairman. “In order to achieve a truly modern electric system, I believe that the Commission understands that planning for resilience at the transmission level is as prudent and important as planning for the reliability and economic benefits of a more integrated system and for the deployment of new resources and technologies.”

“The Department of Energy and FERC have been focused on generation diversity in the context of resilience. The piece that is missing in the discussion is how those resources are going to be delivered where, and when, they are needed,” adds Nina Plaushin, WIRES president. “Are we planning an integrated transmission system that can deliver and balance generation resources broadly across regions, and over different paths, when faced with major disruptions?  Or are we building “just-in-time” incremental system upgrades to meet local needs?”

WIRES’ comments are supported by a new report, Recognizing the Role of Transmission in Electric System Resilience, issued by The Brattle Group, which analyzes how existing transmission contributes to power system resilience and describes how improved federal policies and new investment in transmission will make our power system more resilient than will subsidies for uneconomic forms of electric generation.

This new research supports that the existing electric transmission system contributes to power system resilience, and evolving policies and new investments in transmission will further enhance power system resilience in several ways:  

  • By providing access to generation resources with diverse geography, technology, and fuel sources, the transmission network buffers customers against extreme weather events that affect a specific geographic location or some external phenomenon (unavailability of fuel and physical or cyber-attacks) that affect only a portion of the generating units.
    • A robust transmission system provides the flexibility that will enable the modern electric system to operate
    • Increased system flexibility provides significant insurance value
  • Additional investment will increase transmission system capacity and connectivity which enhances the overall level of reliability and resilience of the bulk power system.
  • Secure electricity imports enabled by expanded transmission provide cost-effective, resilience benefits even in cases where generation fuel security is identified as the proximate resilience threat.