Comments on FERC's "Mega-NOPR"

RMI provides comments to the Federal Energy Regulatory Commission (FERC) regarding its March 1995 Notice of Proposed Rulemaking (NOPR) on open-access transmission. The document argues for symmetrical economic rewards for demand-side resources and warns that rapid technological advances in distributed generation could render central thermal power plants and the traditional utility model obsolete.

• The author argues that demand-side resources, such as end-use efficiency and load management, should receive the same economic credit for grid decongestion as supply-side resources. Without a transactional mechanism to reward 'negative loads' for relieving grid burdens, cheaper demand-side investments will be artificially disadvantaged, leading to societal capital misallocations.
• Technological advancements in distributed generation may make central thermal power plants, including new combined-cycle plants, uncompetitive. Specifically, trigeneration with gas turbines can provide electricity at costs of 0.5-2.0¢/kWh with efficiencies over 90%, and proton-exchange-membrane fuel cells show promise of yielding electricity at 1-2¢/kWh.
• The emergence of the 'distributed utility'—characterized by onsite power storage like superflywheels and decentralized generation—could disintermediate the traditional utility model. This shift could reduce the necessity of the electric grid and retail meters, potentially leaving only a gas grid for energy delivery.
• The author cautions that FERC's focus on the conventional context of bulk transmission and large central stations may create conditions that inhibit the next stage of electric system evolution. The Commission is urged to ensure its framework is consistent with a future of radically decentralizing and 'supercompetitive' technical conditions.

APA

Lovins, A. B. (1995). Comments on FERC's "Mega-NOPR". RMI. https://rmi.org/app/uploads/2017/05/RMI_Document_Repository_Public-Reprts_U95-37_CommentsOnFERC.pdf

Chicago

Lovins, Amory B. Comments on FERC's "Mega-NOPR". RMI, 1995. https://rmi.org/app/uploads/2017/05/RMI_Document_Repository_Public-Reprts_U95-37_CommentsOnFERC.pdf.

Wikipedia

{{cite press release |last1=Lovins |first1=Amory B. |title=Comments on FERC's "Mega-NOPR" |publisher=RMI |date=24 July 1995 |url=https://rmi.org/app/uploads/2017/05/RMI_Document_Repository_Public-Reprts_U95-37_CommentsOnFERC.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{lovins1995comments, author = {Lovins, Amory B.}, title = {{Comments on FERC's "Mega-NOPR"}}, publisher = {RMI}, year = {1995}, month = jul, url = {https://rmi.org/app/uploads/2017/05/RMI_Document_Repository_Public-Reprts_U95-37_CommentsOnFERC.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }