INGAA Reply Comments on Grid Resilience in RTOs/ISOs

INGAA supports the Commission’s continued examination of grid reliability and resilience in regional transmission organizations (“RTOs”) and independent system operators (“ISOs”).  Every RTO and ISO, including PJM, plays a crucial role in ensuring a reliable and resilient electric grid within its footprint.  INGAA members appreciate this role and share the goal of ensuring reliability and resilience with regard to the interstate pipeline grid.  INGAA members have worked collaboratively with the RTOs/ISOs towards the shared goal of electric and gas reliability and resilience, and we believe this relationship has worked well.  There is no need for additional, formalized processes or pipeline-specific proceedings, as PJM suggests in its comments.  Even the other RTOs/ISOs have requested the Commission reject PJM’s proposals, because “the record in this proceeding does not support any universal resilience standard or tariff change requirements”.