United States of America Before the Federal Energy Regulatory Commission
PJM Interconnection, L.L.C. } Docket No. ER20-2573-000
Comments of the PJM Power Providers Group and the Electric Power Supply Association
P3/EPSA state support for PJM’s Enhanced Pricing and Dispatch Filing, as it is a significant and necessary step in PJM’s price formation efforts (ER20-2573). P3/EPSA has long stressed the importance of PJM’s continued efforts to ensure proper price formation for all resources in the PJM markets, and believes that the proposed changes will ensure more accurate pricing and dispatch of resources within the PJM footprint. P3/EPSA appreciate that PJM’s Filing begins with these “short-term reforms” that will lay the groundwork for additional reforms in the “intermediate-term” and the “long-term.” Importantly, these proposed modifications appropriately resolve the pricing and dispatch misalignment problem that the Commission identified in PJM’s Fast-Start Order on January 23, 2020. P3/EPSA agree with PJM that the proposed changes herein “will better align dispatch and pricing intervals by ensuring that prices appropriately reflect the costs of the marginal resources consistent with the future timing of the dispatch instructions they receive.” P3/EPSA note that these short-term pricing alignment changes were overwhelmingly approved by the PJM stakeholders. P3/EPSA respectfully request that the Commission expeditiously accept PJM’s Filing at the requested date of no later than October 12, 2020.