UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
PJM Interconnection L.L.C. } Docket No. ER19-1486-000
PJM Interconnection L.L.C. } Docket No. EL19-58-000
ANSWER TO JOINT MOVANTS’ MOTION
Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (the “Commission”), the Electric Power Supply Association (“EPSA”), and The PJM Power Providers Group (“P3,” and together with EPSA, the “Indicated Parties”) hereby answer the motion filed by the Joint Movants on December 7, 2021, renewing their prior protests to the modifications to the reserve market rules of PJM at issue in these proceedings, requesting that the Commission issue an order on remand granting rehearing of or vacating the orders accepting such modifications, and further requesting that the Commission “reopen the record in these proceedings” and permit the Joint Movants to lodge a variety of materials relating to Winter Storm Uri.
As P3 previously pointed out, the modifications to the reserve market rules and Operating Reserve Demand Curve (“ORDC”) that were approved by the Commission in these proceedings reflected a multi-year effort by PJM and its stakeholders to reform PJM’s reserve market rules. PJM fully explained and supported the need for those modifications in its underlying filings, and concerns regarding the proposed modifications were examined and addressed in the ORDC Orders.
There is no reason for the Commission to now reverse course. This is particularly true because market participants have made business decisions, and other market rules have been designed, based on the expectation that the ORDC rules would be implemented. While the Indicated Parties urge the Commission to reaffirm its findings in the ORDC Orders, the Indicated Parties understand that the Commission’s request for voluntary remand before the United States Court of Appeals for the District of Columbia Circuit could indicate a desire on the part of the Commission to revisit the issues raised in these proceedings. In the event that the Commission does intend to do so, the Indicated Parties urge the Commission to establish additional procedures in order to permit all interested parties to supplement the record and fully brief any issues of concern, as it has done in past cases where it has requested voluntary remand. Such an approach would be more efficient than having parties haphazardly submit individual pleadings and motions to lodge, as the Joint Movants have done. Moreover, established briefing procedures would ensure that all parties have the opportunity to respond to issues raised by others. Indeed, the December 7 Motion demonstrates the importance of full briefing, because the Joint Movants have presented a skewed and incomplete view of actions taken by the Public Utility Commission of Texas (“PUCT”) in the wake of Winter Storm Uri, which occurred earlier this year.