Comments of RTOGov Researchers to the U.S. Federal Energy Regulatory Commission

These written comments were filed with the U.S. Federal Energy Regulatory Commission by 10 researchers from RTOGov, to help inform the creation of an Office of Public Participation at FERC. The researchers suggested that the new Office of Public Participation could help the public – which might include new market entrants but also individuals, civil society organizations, and public sector representatives impacted by market decisions – in understanding the significance of RTOs and the opportunities to engage in their decision-making processes. This is especially important for public interests that have been historically under-represented in formal regulatory proceedings and underrepresented in RTO stakeholder engagement processes. They also proposed the creation of an RTO ombudsman position in the Office of Public Participation, and suggested that the new office could develop best practices for improving public involvement in RTO decision-making.

The RTOGov researchers who are cited within include: Dr. Seth Blumsack, Professor of Energy and Environmental Economics and International Affairs, College of Earth and Mineral Sciences, Pennsylvania State University; Michael H. Dworkin, JD., Professor Emeritus, Vermont Law School; Dalten Fox, Graduate Student, Boise State University; Mark James, JD., Senior Research Associate and Kevin Jones, Director, Institute for Energy and the Environment, Vermont Law School; Dr. Stephanie Lenhart, Senior Research Associate, Energy Policy Institute, School of Public Service, Boise State University; Christina Simeone, Senior Fellow, Kleinman Center for Energy Policy, University of Pennsylvania; Zachary F. Teti, Graduate Student, Pennsylvania State University; and Elizabeth J. Wilson, Professor of Environmental Studies and Director, Arthur L. Irving Institute for Energy and Society, Dartmouth College.