UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
PJM Interconnection, L.L.C. } Docket Nos. ER21-2582-000
PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION
Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (the “Commission” or “FERC”) and in accordance with the Commission’s July 30, 2021, notice in the proceeding, the Electric Power Supply Association (“EPSA”) protests the July 30, 2021, filing by PJM Interconnection, L.L.C. (“PJM”) of revisions to its minimum offer price rule (“MOPR”). For the reasons set forth in the comments, the revisions proposed in the July 30 PJM Filing are unjust, unreasonable, and unduly discriminatory, and the July 30 PJM Filing should be rejected.
EPSA recognizes that various parties, including members of the Commission, have concerns about the currently effective MOPR, and EPSA is certainly open to the development and implementation of just and reasonable refinements to, or even a replacement for, that mechanism. But, as discussed in more detail in the comments and in the affidavit of Collin Cain, M.SC., provided in Attachment A (the “Cain Affidavit”), the Reliability Pricing Model (“RPM”) market cannot produce just and reasonable results if the MOPR is just gutted as PJM proposes. The July 30 PJM Filing ignores entirely the constitutional and statutory rights of investors and suppliers to compensatory rates and likewise ignores the reliance interests that the Commission’s longstanding policy of protecting the integrity of the RPM market have engendered. Moreover, while some will point to the July 30 PJM Filing’s accommodation of state policies providing subsidies for preferred resources as a positive, that same accommodation would run roughshod over the rights of other states. These and other fundamental flaws compel rejection of the July 30 PJM Filing.
