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Home / Filings / EPSA Comments to FERC on Cricket Valley & Empire Generating Complaint v. NYISO on Statewide Mitigation, Docket EL21-7-000

November 18, 2020

EPSA Comments to FERC on Cricket Valley & Empire Generating Complaint v. NYISO on Statewide Mitigation, Docket EL21-7-000

By EPSA

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.

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