UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
PJM Interconnection, L.L.C. } Docket Nos. ER21-2582-000
MOTION FOR LEAVE TO ANSWER AND LIMITED ANSWER OF THE ELECTRIC POWER SUPPLY ASSOCIATION
EPSA filed this limited answer in response to the comments of the Natural Resources Defense Council, the Sustainable FERC Project, the Sierra Club, and the Union of Concerns Scientists (the “PIOs”), the answer of PJM Interconnection, L.L.C. (“PJM”), and certain other pleadings filed in support of PJM’s July 30, 2021, filing of proposed revisions to its minimum offer price rule (“ Focused MOPR”).
As discussed in more detail in the EPSA answer and in the supplemental affidavit of Collin Cain, M.SC., (the “Cain Supplemental Affidavit”), nothing in these or any other pleadings in this proceeding remedies the fatal flaws in the July 30 Filing, and supporting commenters’ various requests for modifications or clarifications of the July 30 Filing only serve to underscore why that filing must be rejected.