For years I have been warning that rising demand forecasts and the failure to retain existing generators or build adequate new power generation is threatening resource adequacy and the reliability of our power grid. I look forward to addressing this important topic with my colleagues and others who can contribute important information and give their views on how we move forward on this critically important issue.   

FERC Chairman Mark Christie, Feb 20, 2025

In February, the Federal Energy Regulatory Commission initiated a technical conference on the US electricity network’s resource adequacy: in simple terms, the country’s ability to provide enough power generation to meet rapidly-growing electricity demand on an aging grid.  On July 7th, FERC closed its comment window, after receiving almost 70 comments from almost 70 organizations.

Here is Halcyon’s AI-generated summary of FERC AD25-7-000:

The key issues addressed in the docket revolve around resource adequacy challenges across Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs), especially in the context of rapid load growth, generation retirements, and changing resource mixes. The docket examines how both capacity market-based and alternative resource adequacy constructs are coping with these challenges, the role of transmission expansion, the integration of new resource types (like renewables and storage), and the importance of robust planning and forecasting practices.

Stakeholder groups:

• RTO/ISO Operators (e.g., SPP, PJM, MISO): 
• State Regulators (e.g., Pennsylvania PUC): 
• Market Participants (e.g., LS Power): 
• Renewable/Energy Advocacy Groups (e.g., ACORE): 
  
• Utility Advocates

Halcyon has tracked FERC proceedings since early 2024, and this latest proceeding is of sufficient breadth and importance that our data science team decided to approach it as a standalone research project.  To put it another way: a FERC resource adequacy technical conference is sufficiently important to the market that we think it deserves adequate resourcing from us, on behalf of our customers.

That means understanding the arguments made by FERC as well as its many commenters, binning them by type, and creating a landscape of priorities, concerns, and suggested strategies for meeting the US’ resource adequacy challenge. 

Here are some of the topics, and a few of their relevant questions, which our data science team queried to identify themes across stakeholder groups: 

Capacity markets: 

• Does this comment advocate for a resource adequacy mechanism (capacity market, administrative adder, etc)
• Does the comment support or critique capacity markets? Does it endorse a non-capacity market mechanism like energy-only or procurement mandates?

Forecasting: 

• Does this comment discuss uncertainty in load growth? How should ISOs/RTOs treat forecasts of large loads? What level of scrutiny do ISOs/RTOs apply to remove duplicative entries and speculative requests?
• What is the need for commitment-backed forecast adjustments? What recommendations are made for the up-front collateral or minimum demand provisions?

Data centers: 

• Does this comment address data centers and other large loads? Is there discussion about requiring such loads to provide on-site generation or colocation? Does it recommend new tariff structures or incentives?
• Does this comment advocate for data centers to locate in resource-abundant zones? If so, what is the rationale?

 Here’s what stands out to us at Halcyon: this is an important, timely challenge for the US grid writ large, and there’s a reason that almost 70 organizations commented in detail.  There are distinct and numerous challenges to forecasting load growth in the US. Understanding them in the aggregate is useful; being able to examine each challenge specifically is essential.

Halcyon has packaged this data science project into one clear deliverable: every comment (and commenter) measured across a dozen key questions, easily scanned, searched, and linked to source. Want to access it? Drop us a line here. 

This post has been edited to update the number of comments and organizations in the first paragraph.

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