EPSA
United States of America Before the Federal Energy Regulatory Commission PJM Interconnection, L.L.C. } Docket Nos. EL19-58-003 Comments of the Electric Power Supply Association EPSA submitted comments and an affidavit of Dr. Paul M. Sotkiewicz regarding the August 5, 2020 filing by PJM in compliance with the Commission’s directive to propose a forward-looking energy and […]
Read MoreEPSA joined Indicated Generators and P3 in an Initial Brief to address the FERC paper hearing to consider whether PJM’s Cone Study is a reasonable proxy for a merchant generator in establishing its capital structure and cost of capital in its reactive revenue requirement
Read MoreEEI and EPSA filed joint comments responding to FERC’s Notice of Inquiry (NOI) on Potential Enhancements to the CIP Reliability Standards. The joint organizations point out that several issues raised in the NOI are addressed by existing or soon-to-be implemented CIP standards, and therefore FERC should reconsider additional enhancements until after these standards have been in place for a period of time. This is consistent with NERC’s risk-based focus and FERC’s flexible approach to Reliability Standards.
Read MoreP3/EPSA state support for PJM’s Enhanced Pricing and Dispatch Filing, as it is a significant and necessary step in PJM’s price formation efforts (ER20-2573).
Read MoreEPSA argues the Commission failed to provide a meaningful response to arguments by EPSA and others that allowing states to eliminate the contract option was discriminatory, in violation of the requirements of Section 210 of the Public Utility Regulatory Policies Act of 1978 (PURPA), and was not the product of reasoned decision-making.
Read MoreUnited States of America Before the Federal Energy Regulatory Commission PJM Interconnection, L.L.C. } Docket No. EL19-58-002 Comments of the PJM Power Providers Group and the Electric Power Supply Association In the joint comments, the Electric Power Supply Association (EPSA) and the PJM Power Providers Group (P3) (jointly P3/EPSA) conditionally support PJM’s July 6, 2020, […]
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