New Release: Defense Energy Resilience Engagement Framework for Utility Regulators - Converge Strategies

New Release: Defense Energy Resilience Engagement Framework for Utility Regulators

Click to Download Framework

The Defense Energy Resilience Engagement Framework for Utility Regulators (“Framework”) was prepared for the National Association of Regulatory Utility Commissioners (NARUC) by Converge Strategies, LLC (CSL). The Framework is a flexible guide for the electricity industry and national security enterprise to collect, examine, and document regulatory considerations for defense energy resilience.

Electricity Industry. The Framework provides public utility commissions with best practices to facilitate engagement with in-state military stakeholders and support consideration of defense-related utility applications.

National Security Enterprise. The Framework equips U.S. Department of Defense’s (DoD) stakeholders with questions to consider as they prepare for future engagements and regulatory proceedings with commissions and utilities.

The Big Picture

In recognition of the grid’s role in national defense, DoD issued guidance in 2024 for engagement with regulated utilities around energy resilience. This guidance builds on DoD’s extensive energy resilience policies, as well as on Congress’s focus on defense critical electric infrastructure (DCEI). Congress defined DCEI in 2015 to include civilian electric infrastructure that provides power to critical defense facilities.

The emerging focus on defense energy resilience sheds light on the evolving relationship between the DoD and its utility partners, which in turn has implications for state utility regulatory commissions.

By The Numbers. 98% of DoD installations depend on electricity from the civilian electric grid. Power outages represent a significant threat to DoD’s missions and national defense.

Click to Download Framework Overview

The Opportunity

NARUC’s Defense Community Partnerships Program, funded by DOE, supports public utilities commissions engagement with military and national security stakeholders through publications, webinars, convenings, and resource guides on military engagement.

The Framework was created in response to regulators increasingly being asked to consider ratepayer investments in infrastructure related to national defense because of DCEI and similar policy initiatives. Commissions expressed interest in understanding DoD’s presence in their states to better inform their decision making related to defense energy resilience. DoD offices have likewise expressed interest in understanding the utility regulatory process as they evaluate pathways to achieve their resilience objectives.

Section 1. Defense Energy Landscape Analysis. Supports commissioners and their staff in engaging with national defense issues. Provides questions to help regulators characterize the DoD’s in-state presence, review their interactions with DoD stakeholders, understand the (non-ratepayer) funding that may be available, and map ongoing military-civilian coordination.

Section 2. Utility Commission Overview. Focuses on the information regulators can provide to DoD stakeholders on the Commission’s process for reviewing projects for potential ratepayer investment and the information required to support decision making.

Section 3. Applying the Framework: A Case Study of Florida. The Project Team partnered with the Florida Public Service Commission and other stakeholders to pilot the Framework, in support of energy resilience at Eglin Air Force Base (Eglin AFB). The experience gathering the data for the case study led to refinements in Sections 1 and 2.

Appendix 1. Eglin AFB Workshop. Outlines how to put the framework and module into practice with a workshop hosted by Eglin AFB and the Project Team to connect and align military and utility stakeholders, gather information, and validate the Framework. This workshop delivery and template could be adapted for use in other states.

Our Appreciation

In addition to NARUC, Converge Strategies would like to thank Eglin AFB, Eglin’s supporting utilities (CHELCO, Power South, FP&L, NextEra Energy, and Okaloosa Gas), the Florida Public Service Commission, and the Emerald Coast Regional Planning Council for their participation in the workshop and contributions to the Framework.

About Converge Strategies, LLC

Converge Strategies, LLC is a consulting company focused on the intersection of clean energy, resilience, and national security. We build partnerships with the military, civilians, and all levels of government to accelerate resilience and security in the clean energy transformation.

Media Contact Adair Douglas | adouglas@convergestrategies.com | 202.934.3856

About the National Association of Regulatory Utility Commissioners

NARUC is a non-profit organization founded in 1889 whose members include the governmental agencies that are engaged in the regulation of utilities and carriers in the fifty states, the District of Columbia, Puerto Rico and the Virgin Islands. NARUC’s member agencies regulate telecommunications, energy, and water utilities. NARUC represents the interests of state public utility commissions before the three branches of the Federal government.