United States of America Before the Federal Energy Regulatory Commission
Cricket Valley Energy Center LLC and Empire Generating Company LLC, Complainants V. New York Independent System Operator, Inc., Respondent } Docket No. EL21-7-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
EPSA comments on a complaint from NY generators seeking an expansion of mitigation across the ISO to protect against market distortions from state out-of-market subsidies. EPSA agrees that these subsidies create damaging distortions, particularly those as extensive New York’s ZECs. Markets need a more holistic approach to addressing these concerns, and EPSA suggests a better approach would be to establish a market-based mechanism to achieve the state’s emission reduction goals through the competitive wholesale market, likely a carbon pricing program. Without such an approach, however, expanding the MOPR to all resources in the NYCA would be necessary to preserve the market as the grid decarbonizes.