“FERC’s purpose and role is to protect reliability. Today’s White Paper, by the Commission’s staff, takes a far too narrow view of reliability by focusing only on Section 215 rules – which effectively involve short-term operational issues, not long-term planning.
 
“FERC staff should recognize that when projecting out 4 to 5 years any reliability analysis must assure there are adequate resources to operate in the event of unforeseen contingencies. This requires considering longer term matters like those in the NERC annual reports.
 
“FERC should be working with states and the planning authorities and not second-guessing them.  Additionally, we are concerned that staff would ignore the reliability studies conducted by the planning authorities by conducting its own separate analysis. A collaborative effort between both would preclude FERC from conducting a reliability analysis from the beginning.
 
“Finally, FERC needs to recognize the states have an important role, as well, especially in long-term planning.”