Venue: FERC
Proceeding: NERC Proposed Freeze Protection Reliability Standards
Docket: RD23-1-000
Competitive generator associations EPSA, New England Power Generators Association (NEPGA), and The PJM Power Providers (P3) filed an answer to respond to the ISO/RTO Council (IRC) comments in the FERC proceeding concerning generator freeze protection standards proposed by the North American Electric Reliability Organization (NERC). The Competitive Generators point out that the IRC suggests changes to the proposed standards without sufficient evidence that such changes are just and reasonable or not unduly discriminatory, and may in fact delay the realization of reliability benefits. If FERC believes any changes have merit then it should direct NERC to make a subsequent filing reflecting further deliberations on the standards. Additionally, FERC should direct each jurisdictional ISO/RTO to begin developing a cost recovery design or mechanism which can go into effect before Generation Owners begin to incur compliance costs.
