United States of America Before the Federal Energy Regulatory Commission
PJM Interconnection, L.L.C. } Docket Nos. ER18-1314-006
Comments of the Electric Power Supply Association
The Electric Power Supply Association submits comments before the Federal Energy Regulatory Commission (FERC) in response to PJM Interconnection’s second compliance filing addressing FERC’s December 19 Order and related directives to expand the Minimum Offer Price Rule (MOPR) in PJM’s capacity market, the Reliability Pricing Model.
EPSA respectfully requests, as outlined by PJM, that the Commission expeditiously act on the June 1 Compliance Filing, as well as the March 18 Compliance Filing, and provide clear guidance to allow PJM to conduct the delayed 2022/2023 Base Residual Auction (BRA) and resume the long-delayed BRA Auction process.
EPSA notes that it greatly appreciates the steps taken by the Commission in the December 2019 Order and related orders to expand the MOPR in order to prevent further harm to the RPM market from out-of-market subsidies, including moving swiftly to provide further guidance to PJM and stakeholders.
EPSA refrains from wading into the details of PJM’s June 1 Compliance Filing, but says the filing is generally consistent with the requirements of the April 16 Order on Rehearing and should be accepted. EPSA agrees with PJM that the 2022/2023 BRA is s “long overdue,” and strongly supports PJM’s request for expeditious action by the Commission on both compliance filings in order to allow the delayed auction process to re-commence as soon as possible.
