UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Independent Market Monitor for PJM v. PJM Interconnection, L.L.C. } Docket No. EL19-47-000
Office of the People’s Counsel for District of Columbia
Delaware Division of the Public Advocate
Citizens Utility Board
Indiana Office of Utility Consumer Counselor
Maryland Office of People’s Counsel
Pennsylvania Office of Consumer Advocaten } Docket No. EL19-63-000 (Not Consolidated)
West Virginia Consumer Advocate Division
PJM Industrial Customer Coalition
PJM Interconnection, LLC.
REQUEST FOR REHEARING
On October 4, 2021, Calpine Corporation (“Calpine”), LS Power Associates, L.P. (“LS Power”), and Talen Energy Marketing, LLC (“Talen”), and together with Calpine and LS Power, the “Indicated Suppliers”), the Electric Power Supply Association (“EPSA”), and the PJM Power Providers Group (“P3″), and together with the Indicated Suppliers and EPSA, the (“Indicated Parties”) respectfully request rehearing of the FERC’s September 2, 2021 order regarding the PJM Interconnection, LLC’s (“PJM”) default Market Seller Offer Cap (“MSOC”) under PJM’s Open Access Transmission Tariff (the “Tariff”).
As discussed in detail in the rehearing request, rehearing of the September 2 Order is required because the Commission failed to properly consider the alternatives set forth by the Indicated Suppliers and others, and instead adopted a Market Seller Offer Cap (MSOC) that fails to properly reflect the risks and costs imposed on suppliers and is at odds with PJM’s Capacity Performance structure.