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Home / Regulatory & Policy / EPSA, EEI, and ACORE Reply Comments on FERC’s NOI regarding Section 203 Blanket Authorizations

April 25, 2024

EPSA, EEI, and ACORE Reply Comments on FERC’s NOI regarding Section 203 Blanket Authorizations

By EPSA

Date filed:    April 25, 2024

Venue:         Federal Energy Regulatory Commission (FERC)

Docket No.: AD24-6-000

Summary: The Electric Power Supply Association (EPSA) filed reply comments at the Federal Energy Regulatory Commission (“FERC”) responding to parties’ initial comments on the Notice of Inquiry (NOI) regarding blanket authorizations for investment companies (AD24-6). The reply comments were filed jointly with the Electric Edison Institute (EEI) and the American Council on Renewable Energy (ACORE). The joint reply comments reiterate EPSA’s and other commenters’ requests that the Commission retain its existing policies with respect to blanket authorizations under FPA Section 203(a)(2) for investment companies. The joint reply comments emphasize that, critically, none of the commenters urging radical changes to the blanket policies offers any example, much less concrete evidence, of cognizable harm or abuse under these policies. At the same time, the record contains substantial evidence showing how such policy changes could deter much-needed investment in the electric sector. The comments underscore that this is the very opposite of what is required at a time when new investment is critically needed to meet demand and maintain reliability.  Accordingly, the joint reply comments request that the Commission determine that no changes are needed to the existing policies at this time. The reply comments also ask the Commission to reject requests for a reduction in the affiliation threshold requirement.

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