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 ancillary services offset (“EAS Offset”). As discussed in the comments and affidavit, EPSA believes that the tariff language proposed in the Compliance Filing complies with the Commission’s directives and articulates conceptually sound principles for calculating the EAS Offset on a forward-looking basis. That tariff language should, therefore, be accepted, as filed. EPSA does ask, however, that the Commission condition its acceptance of the Compliance Filing on PJM’s submitting an informational filing after conducting its first Base Residual Auction (“BRA”) with the forward-looking EAS Offset, and, more broadly, that the Commission make clear that future challenges to PJM’s implementation of the principles proposed in the Compliance Filing will not be deemed to be collateral attacks on its order accepting that filing. EPSA urges the Commission to act expeditiously on the Compliance Filing in order to minimize any further delay in conducting the BRA for the 2022/2023 Delivery Year (the “2022/2023 BRA”).