IPAA and Cooperating Associations Comments to the Federal Energy Regulatory Commission on its Notice of Proposed Rulemaking on Grid Reliability and Resiliency Pricing

IPAA and Cooperating Associations Comments to the Federal Energy Regulatory Commission on its Notice of Proposed Rulemaking on Grid Reliability and Resiliency Pricing

Pursuant to the October 2, 2017, Notice Inviting Comment, issued by the Federal Energy Regulatory Commission (FERC or “the Commission”) in the above-referenced docket, the Independent Petroleum Association of America and the following organizations (collectively, “Independent Producers”) hereby respectfully submit the following comments on the Notice of Proposed Rulemaking in this docket. The Independent Producers urge the Commission to reject the recommendations as set forth by the Secretary of Energy in its September 28, 2017, proposal of a rule for final action by the Commission.