Dear Secretary Bose: The U.S. Chamber of Commerce and its Global Energy Institute (collectively, “the Chamber”) appreciate the opportunity to respond to the Advance Notice of Proposed Rulemaking (“ANOPR)1 issued by the Federal Energy Regulatory Commission (“FERC” or “Commission”) on July 15, 2021. The ANOPR presents and seeks comments on potential reforms to the electric regional transmission planning, cost allocation, and generator interconnection processes overseen by the Commission. This ANOPR sets forth a significant undertaking, broadly proposing to reassess and potentially restructure many of the most significant policies and procedures within FERC’s jurisdiction. Many of these policies and procedures have been crafted through various rulemakings and numerous case law developments over nearly two decades. As such, the Commission should seriously consider the gravity of this undertaking and its potential significant impacts on both the reliability and the cost of electricity for businesses and consumers across the country. Many of the policies and procedures subject to revaluation in this docket have served their intended purposes. They should not be abruptly jettisoned without a thorough evaluation of the costs and benefits resulting from any significant transmission planning and interconnection policy changes.
The mission of the Chamber’s Global Energy Institute is to unify policymakers, regulators, business leaders, and the American public behind a common-sense energy strategy to help keep America secure, prosperous, and clean. These comments intend to provide the overall business community’s input to the Commission as it considers modifications to the policies and procedures governing the planning and expansion of America’s interstate electric grid.