UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
LS Power Development, LLC and Doswell Limited Partnership v. PJM Interconnection, L.L.C. } Docket No. EL21-72-000
COMMENTS IN SUPPORT OF COMPLAINT
On May 13, 2021, EPSA filed comments at the FERC in support of the LS Power Complaint against PJM regarding the Dominion FRR Violation in Docket No. EL21-72-000. EPSA urges the Commission to expeditiously approve the Complaint and to do so in a manner that does not further delay the PJM BRA scheduled for May 19. EPSA emphasizes that it is essential for reliability and resource adequacy in the region that PJM strictly adhere to the existing protections currently within its tariff surrounding FRR – and asserts the Commission must act in response to the Complaint to enforce this requirement – and argues these tariff protections should remain stringent so that FRR can offer capacity market exit without impacting that market for all other market participants, states, and consumers. EPSA highlights that it addressed these points in detail in Reply Comments submitted earlier this week in response to the Commission’s Notice Inviting Comments following the technical conference on Resource Adequacy in the Evolving Electricity Sector; accordingly, EPSA incorporated by reference its Reply Comments filed in the Commission’s administrative docket.