Multi-Trade Electricity Consumer Letter to FERC

By at 12 June, 2019, 2:08 pm

Chairman Neil Chatterjee
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Commissioner Richard Glick
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Commissioner Cheryl A. LaFleur
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Commissioner Bernard L. McNamee
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426


Dear Chairman Chatterjee, Commissioner LaFleur, Commissioner Glick, and Commissioner

As associations representing the commercial and industrial sectors, as well as, residential
ratepayers and public interest groups, we are writing to urge the Federal Energy Regulatory
Commission (FERC) to continue its leadership role in encouraging the evolution of competitive
wholesale electricity markets and to consider several critical issues as part of your agenda and
activities going forward.

Two decades ago, consistent with the principles and requirements of the Federal Power Act,
FERC encouraged the formation of regional transmission organizations (RTOs) and
independent system operators (ISOs), with the goals of promoting economic efficiency,
reliability, and non-discriminatory access to the transmission grid.
Since that time, multiple studies have found that competitive wholesale electricity markets can
deliver significant benefits to electricity customers, including greater efficiency, lower electricity
prices, and robust reliability. Competitive wholesale electricity markets can also encourage
investment in innovations that are transforming the grid and delivering significant value to
customers, such as clean energy generation as well as energy storage, distributed energy
resources, and demand response technologies.

However, as you are quite aware, RTO and ISO decision-making processes do not always
adequately consider the voices of customers, innovators, and other new entrants to wholesale
electricity markets. The processes often favor incumbents, which have resulted in problems with
transparency, accountability, and market performance. Customers are also concerned about
growing tensions among states, market operators, and Federal policymakers related to the
evolution and operation of wholesale electricity markets. In some regions, state preferences and
mandates for energy generation do not always align with market outcomes. In some markets,
choices in market design create unintended barriers to adoption of emerging technologies.

These issues are complex, and solutions will necessarily involve rigorous analysis and diverse
stakeholder input. As FERC continues its mission and mandate to ensure open access,reliability, and just and reasonable electricity rates, we urge you to consider the following:

• FERC should ensure that RTOs and ISOs adhere to key principles necessary for the
efficient and effective operation of wholesale electricity markets, namely: transparency in
decision-making, independence from undue influence, and fair representation of all
stakeholders consistent with Order No. 719.
• FERC should continue to fulfill its role in providing strong oversight to ensure RTO and
ISO accountability not only to these principles in concept, but also in practice. RTO and
ISO decision-making processes—and which stakeholders are empowered to shape
them—will impact the success of each and every priority of the Commission, including
resiliency, cybersecurity, and the transition to a modern grid.
• FERC should ensure wholesale electricity markets continue to enable access to
advanced technologies, which benefit consumers by lowering costs and improving
service quality. Innovation in generation, transmission, communications technologies,
and consumer-centric business models are already creating value for electricity
customers and the grid as a whole. FERC should be a leader in this transformation.
• FERC should ensure the independence and effectiveness of the RTO and ISO
Independent Market Monitors (IMMs) and the IMMs’ right to file complaints regarding
market deficiencies.
• FERC should consider mechanisms for ensuring all U.S. electricity customers can
realize the benefits of wholesale market competition.

More than ever before, competitive wholesale electricity markets are poised to unleash the costeffective, clean, reliable, and resilient solutions that electricity customers demand and deserve.

With FERC’s continued leadership and oversight, we can accelerate the transition to a modern
grid while empowering consumers and protecting the public good.

We look forward to continuing a dialogue with you on these critical issues.

American Chemistry Council
American Forest and Paper Association
Business and Institutional Furniture Manufacturers Association
Electricity Consumers Resource Council
Heritage Action for America
National Association of State Utility Consumer Advocates
National Retail Federation
Portland Cement Association
Public Citizen
R Street Institute
Retail Industry Leaders Association
Small Business & Entrepreneurship Council

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