Venue: Federal Energy Regulatory Commission
Docket Nos: ER24-98 and ER24-99
On November 9, 2023, the Electric Power Supply Association (EPSA) filed comments at the Federal Energy Regulatory Commission (FERC) regarding the PJM Capacity Market Reform Filings in Docket Nos. ER24-98 and ER24-99. The PJM filings propose changes to the rules governing the Market Seller Offer Cap (MSOC), certain capacity performance rules related to penalties and performance payment eligibility during Performance Assessment Intervals (PAIs), and adoption of a forward-looking Energy and Ancillary Services (EAS) offset for purposes of calculating the MSOC and MOPR. Additionally, PJM proposes changes to enhance its resource adequacy risk modeling, implement marginal capacity accreditation, and changes to the Fixed Resource Requirements (FRR) alternative, among other things. EPSA requests that the Commission issue an order on both Capacity Market Reform Filings by December 12, 2023, so that the reforms align and to allow orderly implementation of these changes for the upcoming Base Residual Auction (BRA) for the 2025/2026 Delivery Year. With specific respect to the PJM proposal to limit performance payments to committed capacity resources, EPSA requests that this portion of the PJM Capacity Market Reform Filing in Docket No. ER24-98-000 should be severed (as consented to by PJM) and rejected by the Commission. Additionally, EPSA urges the Commission to encourage PJM to continue to work with stakeholders to file additional, needed capacity market reforms in the near future, and in particular, regarding risk mitigation and MSOC.