UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Carbon Pricing in Organized Wholesale Electricity Markets } Docket No. AD20-14-000
REPLY COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
The Electric Power Supply Association respectfully submits these reply comments in response to the Notice of Proposed Policy Statement issued on October 15, 2020, by the Federal Energy Regulatory Commission in the above-referenced docket. EPSA commends the Commission for continuing the dialogue on this critical issue and offers additional information to supplement the record in the docket.
EPSA argues that FERC has an obligation to review the impact of any submitted policy proposal on wholesale rates, and further adds that a market-based program to address state environmental goals, such as a carbon price, is entirely reasonable given FERC’s longstanding approach to market-based regulation.