Venue: Federal Energy Regulatory Commission Date: September 20, 2023 Proceeding: August 10, 2023 FERC/NERC Physical Security Technical Conference (RD23-2-000) Summary: These comments support continued examination of the effectiveness of CIP-014-3 and highlight that any additional NERC action should be performance-based in nature. Given the site and terrain specific challenges that are associated with individual substations, it is critical […]
Read MoreEPSA Comments on CAISO Proposals for Day-Ahead Market Extension and Enhancements
Date: September 21, 2023 Venue: Federal Energy Regulatory Commission Docket: ER23-2686-000 Proceeding: California Independent System Operator Corp. Summary: EPSA highlights the importance of improvements to the California ISO’s day-ahead market to address system changes and better align the day-ahead market with real time conditions, and particularly the proposal to extend participation in CAISO’s day-ahead market to neighboring balancing authorities in […]
Read MoreJoint Brief of Petitioners on Review of FERC Order Accepting PJM Revisions to Capacity Auction LDA Requirements
Date: September 18 Venue: U.S. Court of Appeals for the Third Circuit Case: No. 23-1778, et al. Case: PJM Power Providers Group v. FERC Summary: The Joint Petitioners in this case – EPSA, PJM Power Providers Group (P3), NRG Business Marketing, and Constellation Energy Generation – submitted an opening brief in this case outlining the […]
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EPSA Comments on CEQ Phase 2 Proposal to Revise National Environmental Policy Act Infrastructure Permitting Reforms
The Electric Power Supply Association submitted comments to the White House Council on Environmental Quality (CEQ) “Phase 2” proposal to reform energy infrastructure permitting processes under the Natonal Environmental Policy Act.
Read MoreEPSA Comments on PJM IROL Critical Resources Cost Recovery Filing
Venue: FERC Date: September 8, 2023 Proceeding: PJM CIP Critical Resources Cost Recovery Filing (ER23-2649-000) Summary: EPSA filed comments in support of PJM’s IROL Critical Resources Cost Recovery Filing. EPSA argues that as the costs outlined in PJM’s filing would be imposed on only a subset of generators – those designated as IROL Critical Resources – the cost recovery mechanism […]
Read MoreEPSA Comments on Second New England Winter Gas Electric Forum
Date Filed: August 24, 2023 Docket No.: AD22-9-000 Venue: Federal Energy Regulatory Commission Summary: These comments highlight the importance of gas electric coordination in New England and point to EPSA’s extensive work on this topic. These comments also outline EPSA’s market reform concepts and how they might be beneficial to the future of New England’s […]
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