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Commissioner Cheryl A. LaFleur Statement
November 4, 2015
Docket Nos. RR15-2-001, RR15-2-002
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Statement of Commissioner Cheryl A. LaFleur on Reliability Assurance Initiative

“As the Commission reviews the Reliability Assurance Initiative (RAI), it is essential to strike a balance between ensuring appropriate Commission oversight and providing the North American Electric Reliability Corporation (NERC) and the Regional Entities sufficient flexibility to implement the RAI program to achieve its intended efficiencies and benefits. On the whole, I believe today’s order strikes an acceptable balance of those two objectives.

“The RAI program grew out of a well-documented concern – discussed for years on the record in reliability technical conferences and Commission dockets – that NERC and the Regional Entities’ reliability work was unsustainably bogged down in paperwork on relatively minor issues, which detracted from our collective ability to focus on more significant reliability matters. Going forward, I believe we must be careful not to require, as part of our ongoing oversight, the type of overly prescriptive and time-consuming analysis that the RAI program was designed to avoid, which would “unduly hamstring the intended flexibility and streamlined processes that are the hallmark of RAI.” FERC and NERC should focus our attention on significant issues before us like cybersecurity, geomagnetic disturbances, and adapting the electric grid to changes in the resource mix. We should also stay focused on the risk-based prioritization that led us to approve RAI, and not require NERC to repeatedly justify that program.

“Accordingly, we respectfully concur.”