On October 2, 2007, FERC held a public hearing and technical conference on a proposed expedited process for pilot projects. Carolyn Elefant, legislative and regulatory counsel for OREC, delivered an abbreviated version of these comments which will be filed with the Commission. In addition, you can view the full transcript of the FERC conference at this link.
We’ve quickly reviewed the dozen or so comments filed. Many commenters have asked FERC to undertake a formal rulemaking and issue regulations to govern the pilot process. Indeed, some commenters have even suggested that FERC must issue a formal rulemaking to comply with the requirements of laws such as the Administrative Procedure Act. Other commenters do not believe that a rulemaking is required, but have asked FERC to clarify certain matters, such as whether a pilot license would have priority over a permit or whether developers could seek sequential pilot license.
Here at OREC, we support FERC’s initiative. We hope that the other agencies involved in the licensing process will come on board with the effort so that we begin to test these new technologies which offer so much promise.