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Filings

March 20, 2023

EPSA, NEPGA and P3 Seek Rehearing on Cost Recovery Concerns for new Extreme Cold Weather Standards

By EPSA

Date: March 20, 2023 Docket: RD23-1-001 Venue: Federal Energy Regulatory Commission Summary: Regional power producer associations New England Power Generators Association (NEPGA) and The PJM Power Providers (P3) joined EPSA in a motion for rehearing of FERC’s dismissal of all three groups’ comments explaining that some cost recovery mechanism needs to be in place to […]

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March 17, 2023

EPSA Joins Comment Letter to Treasury and IRS on Future Guidance Implementing New Corporate Alternative Minimum Tax

By EPSA

Docket: Notice 2023-7 Date Filed: March 14, 2023 Filing Summary: On March 14, EPSA joined a joint Request for Comments letter to the U.S. Treasury Department and Internal Revenue Service on the agencies’ request for future guidance implementing the new corporate alternative minimum tax (CAMT) (Notice 2023-7). The joint letter from a diverse group of energy and […]

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March 1, 2023

EPSA Comments and Response to NAESB Gas Electric Forum Recommendations Survey

By EPSA

Date: Feb 27, 2023 Agency: North American Energy Standards Board Summary: EPSA offers comments to the NAESB Gas-Electric Forum to suggest the most useful approach for the group’s development of recommendations for policymakers to improve the reliability of the natural gas infrastructure system necessary to support the Bulk Electric System. It is important to clearly […]

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February 23, 2023

EPSA and P3 Joint Petitioners’ Brief Appealing PJM Operating Reserve Demand Curve Orders from FERC

By EPSA

February 23, 2023 U.S. Court of Appeals Sixth Circuit Case 22-3176  EPSA and P3 have filed their joint initial brief in the appeals at the U.S. Court of Appeals for the Sixth Circuit of FERC’s orders on PJM’s Operating Reserves Demand Curve (ORDC). The brief argues that then-Chairman Rich Glick’s unilateral directive that FERC’s lawyers […]

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February 9, 2023

EPSA Answers PJM, the PJM IMM, and Other Parties’ Comments in PJM LDA Revisions Proceedings

By EPSA

Docket Nos.: ER23-729 and EL23-19 Date Filed: February 9, 2023 Agency: Federal Energy Regulatory Commission (FERC) Summary: EPSA’s answer filed at the Federal Energy Regulatory Commission responds to the PJM, the PJM Independent Market Monitor (IMM), and the Public Interest Organizations (PIO) answers responding to protests, including EPSA’s protest, in the PJM Section 205 and […]

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January 24, 2023

EPSA Reliability Technical Conference Comments

By EPSA

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 […]

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