UNITED STATES OF AMERICA
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Notice of Proposed Rulemaking – Grid Reliability and Resilience Pricing – Docket No. RM18-1-000
INITIAL COMMENTS OF THE R STREET INSTITUTE
Pursuant to the Secretary of Energy’s Notice of Proposed Rulemaking (“NOPR”) for final action by the Federal Energy Regulatory Commission (the “Commission” or “FERC”) issued on September 28, 2017, the R Street Institute (“RSI”) respectfully submits these comments in response to the NOPR’s proposal to impose rules on Commission-approved regional transmission organizations (RTOs) and independent system operators (ISOs) to provide immediate cost recovery for generation resources with 90-day on-site fuel supplies. RSI also submits comments in response to Commission staff’s request for commenters to address specified questions.
 Department of Energy, Grid Resiliency Pricing Rule, Notice of Proposed Rulemaking, Docket No. RM17-3-000, Sept. 28, 2017, pp. 1-11. https://www.energy.gov/sites/prod/files/2017/09/f37/Notice%20of%20Proposed%20Rulemaking%20.pdf
 Federal Energy Regulatory Commission, Grid Reliability and Resilience Pricing, Docket No. RM18-1-000, Oct. 4, 2017, p. 1. https://www.ferc.gov/media/headlines/2017/2017-3/10-04-17.pdf