United States of America Before the Federal Energy Regulatory Commission
Indicated Generation Owners } Docket No. EL19-70-000
Initial Brief on Capital Structure and Cost of Capital of Indicated Generation Owners, Electric Power Supply Association, and PJM Power Providers Group
EPSA joined Indicated Generators and P3 in an Initial Brief to address the FERC paper hearing to consider whether PJM’s Cone Study is a reasonable proxy for a merchant generator in establishing its capital structure and cost of capital in its reactive revenue requirement (EL19-70-000). The generators’ group urges FERC to declare that the capital cost and capital structure reflected in PJM’s Commission-approved CONE Study is a reasonable proxy to use to determine a merchant generator’s capital structure and cost of capital, as requested by Indicated Generation Owners in the original Petition for Declaratory Order. This Initial Brief demonstrates that the CONE Study is not only a just and reasonable proxy for a merchant generator’s capital structure and capital costs, but it is also the best existing proxy for that purpose.