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 proposed by PJM is necessary and appropriate and should be approved by the Commission. As PJM explains, the mandated costs incurred by IROL Critical Resources occur outside of the market, affect some units but not others, are not discretionary in any way, and may be imposed on very short notice for as brief a period as one year. Allowing these units to recover their IROL-related costs will help preserve both the reliable operation of the grid and competitive outcomes.
