The Western Interconnection Regional Advisory Body (“WIRAB”) submitted comments to the U.S. Department of Energy regarding the Staff Report on Electricity Markets and Reliability. WIRAB referenced research indicating that baseload operation of the coal fleet in the West has decreased from 52 percent of coal unit operating days in 2001 to 22 percent in 2016. This confirms a U.S. DOE finding that many coal-fired generating units that were used for baseload generation in the past are no longer operating in that role at this time. WIRAB also noted that current studies of the Western Interconnection do not indicate there is a shortage of primary frequency response at this time. WIRAB continues to believe that more research and analysis is needed to determine how primary frequency response will be provided, including where such response is needed and which technologies can best and most cost effectively provide it, as the composition of the electric grid changes in the West. WIRAB encourages U.S. DOE to continue to work with Western states and provinces to address the reliability implications of the changing electric grid.