EPSA generally supports PJM’s Reliability Resource Initiative Filing and continues to underscore the importance of FERC adhering to the NRG Doctrine in assessing proposed changes.
Date: January 8, 2025
Venue: Federal Energy Regulatory Commission
Docket No.: ER25-712-000
Summary: On January 8, 2025, the Electric Power Supply Association (EPSA) filed comments at the Federal Energy Regulatory Commission (FERC) responding to the PJM Resource Reliability Initiative (RRI) section 205 filing. The comments state that while there may be some elements of the proposed RRI that could be improved, overall, EPSA supports PJM’s filing as just and reasonable and urges the Commission to approve the filing by February 11, 2025, as requested by PJM.
The PJM RRI Filing is part of a suite of recent and upcoming filings by PJM and supported by the PJM Board proposing inter-related capacity market and interconnection tariff changes to address escalating, near-term system reliability concerns identified in the PJM region.
The comments also address PJM’s inclusion of the NRG “consent” language that has been in recent PJM filings and the comments underscore the importance of the Commission adhering to the narrow NRG doctrine in assessing the PJM filing.
The comments are accompanied by an expert affidavit from former FERC Chairman Joe Kelliher addressing both policy and legal issues related to the proposal, and in particular, addresses legal issues raised in the November 26, 2024 Norman Bay letter to Chairman Phillips calling for rejection of the RRI proposal.
