EPSA’s PJM Governance comments outline concerns related to FPA Section 205 Filing Rights
Date filed: August 21, 2026 | Venue: Federal Energy Regulatory Commission | Docket No.: AD26-7-000
On August 21, 2026, the Electric Power Supply Association (EPSA) filed post-conference comments at the Federal Energy Regulatory Commission (FERC) following the Chairman- and Commissioner-led technical conference held on July 23, 2026, to discuss PJM Interconnection, L.L.C. (PJM) governance and stakeholder process reforms (AD26-7). The comments address two questions posed by the FERC about the allocation of filing rights under Federal Power Act (FPA) Section 205 and to underscore the critical importance of ensuring that any attempted reallocation of such rights is fully in accordance with the statutory framework of the FPA. The comments are accompanied by an affidavit from former FERC Chairman Joe Kelliher who addresses issues related to states’ Section 205 filing rights.

