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Comment Filed Electricity Law

Electricity Law Initiative Suggests New FERC Office Monitor RTOs


The Electricity Law Initiative filed a comment about FERC’s Office of Public Participation. Congress created the Office in 1978, charging it with “coordinating assistance to the public with respect to authorities exercised” by FERC. FERC has never hired a Director for the Office or provided any funding to the Office. In December 2020, Congress instructed FERC to finally establish the Office. Shortly thereafter, FERC convened several public sessions to solicit ideas about the Office’s potential functions and opened a docket for written comments.

The Electricity Law Initiative’s comment suggests that FERC include monitoring of Regional Transmission Organizations (RTOs) in the Office’s portfolio. The Office could coordinate assistance to the public by documenting RTO processes and proceedings. Providing visibility into RTO decisionmaking could assist state regulators and officials, non-public utilities, companies providing advanced energy technologies, landowners affected by transmission development, and numerous other RTO-adjacent parties. The Initiative’s comment also explains how RTO monitoring would be consistent with FERC’s orders about RTO decisionmaking processes and would build on FERC’s long-standing efforts to enhance transparency of transmission operations and planning. You can read the full comment here.