By Tyson Slocum
The Commission seeks suggestions on how the North American Electric Reliability Corporation (NERC) can better “receive and respond to recommendations by the users, owners, and operators of the Bulk-Power System, and other interested parties for improvement of the Electric Reliability Organization’s operations, activities, oversight and procedures.” Public Citizen offers the following comments:
- We strongly endorse the Commission’s proposal requiring NERC to submit assessments of its performance every three years instead of the current period of every five years.
- The Commission should compel changes to NERC’s Board of Trustees to diversify representation of stakeholders, including allocating at least one seat for an individual with professional experience as a bona fide consumer advocate.
- FERC’s new Office of Public Participation should coordinate assistance to the public to participate in NERC stakeholder proceedings and public comment opportunities.
- Notices of NERC public comment opportunities should be posted in the Federal Register.
- NERC stakeholder committees should expand the number of allocated seats for consumer advocates, as in some cases there are no consumer advocates present in key stakeholder proceedings. Spaces for small end-use customers should be reserved for bona fide consumer advocates—not utility executives who happen to pay a utility bill.
Read our full, 4 page filing in Docket No. RM21-12 here: NERC