UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Reactive Power Capability Compensation } Docket No. RM22-2-000
REPLY COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
On March 23, 2022, the Electric Power Supply Association (“EPSA”) filed reply comments responding to certain initial comments regarding the November 18, 2021 Notice of Inquiry (“NOI”) issued by the Federal Energy Regulatory Commission ( the “Commission) with respect to reactive power compensation and market design. EPSA highlights that the initial comments filed in response to the NOI reflect a broad consensus, across parties representing different types of resources, regarding the continuing need to ensure that resources are properly compensated for the costs they must incur to ensure that they are capable of providing reactive power. The reply testimony of Adrian J. Kimbrough (“Kimbrough Reply Testimony”) also explains that suggestions by certain commenters that the Commission should make reactive power compensation dependent on some type of “needs” based analysis is not only practically infeasible, but would jeopardize reliability. Mr. Kimbrough further states that the AEP methodology remains the best way to compensate all resources for their reactive power capability. Accordingly, in acting on the NOI, the Commission should make clear that all resources have the right to seek compensation to fully recover their reactive power costs under the AEP methodology.
