Date: January 24, 2023 Venue: Federal Energy Regulatory Commission Docket No.: AD22-10-000 Summary: These comments urge the Commission to ensure that markets are sending adequate price signals and procuring the products and services that best equip them to address both current and future reliability needs. These comments also address the possible need to examine existing […]
Read MoreEPSA Protest & Affidavit Regarding PJM LDA Revisions Filings
Docket Nos.: ER23-729 and EL23-19 Date filed: January 20, 2023 Agency: FERC Summary: On January 20, 2023, EPSA filed at the FERC a protest and expert affidavit of Dr. Paul Sotkiewicz in response to the December 23, 2022, PJM section 205 and section 206 filings to revise its RPM Locational Deliverability Area (LDA) Reliability Requirements […]
Read MoreEPSA Comments on ISO/RTO Reports Addressing Market Design Modernization And System Changes
Date: January 18, 2023 Venue: FERC Proceeding: Modernizing Electricity Market Design Docket: AD21-10-000 Summary: EPSA highlights issues addressed across all six reports submitted by the FERC-jurisdictional ISOs and RTOs to draw attention to how competitive electricity markets can meet changing system needs reliably and cost effectively. In part, new state and federal policies and mandates […]
Read MoreEPSA Protest to the MISO Transmission Owners Filing to Eliminate Schedule 2 Reactive Power Compensation
Venue: FERC Proceeding: MISO Transmission Owners Elimination of Schedule 2 Reactive Power Compensation Docket: ER23-523-000 EPSA opposes this filing and asks that the Commission reject it without prejudice. In light of the acknowledged role that reactive power plays in maintaining system operation and reliability, EPSA urges the Commission to initiate a generic proceeding to broadly […]
Read MoreJoint Answer of the Competitive Generators (NEPGA, EPSA, P3) to ISO/RTO Council Comments on Proposed NERC Extreme Cold Weather Standards
Venue: FERC Proceeding: NERC Proposed Freeze Protection Reliability Standards Docket: RD23-1-000 Competitive generator associations EPSA, New England Power Generators Association (NEPGA), and The PJM Power Providers (P3) filed an answer to respond to the ISO/RTO Council (IRC) comments in the FERC proceeding concerning generator freeze protection standards proposed by the North American Electric Reliability Organization […]
Read MoreEPSA and P3 File Comments on NERC Extreme Cold Weather Standard (RD23-1)
EPSA and P3 filed the attached comments at FERC on NERC’s Proposed Extreme Cold Weather Standards (RD23-1). While generally supportive of NERC’s efforts, these comments outline the legal and operational issues with Requirements R1 and R2 of the proposed standard. EPSA and P3 request the standard be remanded back to NERC and revised to remove […]
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