The United States of America Before the Federal Energy Regulatory Commission
Indicated Generation Owners } Docket No. EL19-70-000
Reply Brief on Capital Structure and Cost of Capital of Indicated Generation Owners, Electric Power Supply Association, and PJM Power Providers Group
The group of generators filed a Reply Brief on reactive power cost of capital and capital structure elements, responding initial briefs from parties which focused on the return on common equity (ROE) aspect of a merchant generator’s rate of return or weighted average cost of capital. The generators continue to urge that PJM’s CONE Study is the best existing reasonable proxy to establish the reactive power revenue requirement.