• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to footer

Electric Power Supply Association

  • Podcast
  • About EPSA
    • Our Policy Principles
    • EPSA Members
    • Our Staff
    • Careers
  • Contact
  • FAQ
EPSA

EPSA

  • Filings
    • Federal Energy Regulatory Commission
    • Federal
    • Judiciary
    • State
    • ISOs/RTOs
  • Newsroom
    • Press Releases
    • Media Contacts
    • Power Moves Newsletter
    • Factsheets and White Papers
    • Opinion and Commentary
    • Social Media
    • Podcast
  • Competitive Solutions
    • Reliable Power
    • Cost Savings
    • Environmental Progress
      • Competitive Emissions Policy Primers
    • Energy Innovation
    • In Your State
  • For Members
    • EPSA Membership
    • Committees
  • PowerFacts Blog
Home / Filings / Joint Comments of Energy Trade Associations on FERC Duty of Candor NOPR

November 10, 2022

Joint Comments of Energy Trade Associations on FERC Duty of Candor NOPR

By EPSA

Proceeding: Duty of Candor Notice of Proposed Rulemaking

Docket No.: RM22-20

Summary:

EPSA joined seven energy trade associations on joint comments responding to the Federal Energy Regulatory Commission’s Duty of Candor NOPR (RM22-20). While underscoring support for truthfulness and accuracy in communications and information exchanges with the Commission and organizations, the Trades outline the significant policy and legal flaws with the broad and ill-defined application of the proposed rule that will tend to suppress communications.

Specifically, the joint comments highlight the potential impacts on a wide range of necessary communications that occur, including with RTOs and in RTO stakeholder processes. Additionally, there are legal issues surrounding the proposed rule given the lack of factual support and explanation, First Amendment violations, lack of intent and materiality provisions, and ambiguity regarding the FERC’s interpretation of its statutory authority to implement the proposed rule, among other concerns. For these reasons, the Energy Trade Associations argue the Commission should rescind the proposal.

In addition to EPSA, the other signatories include six national energy trades associations: the American Petroleum Institute, Edison Electric Institute, Energy Trading Institute, INGAA, the Natural Gas Supply Association, and the National Hydropower Association, as well as EPSA’s state and regional partner, the PJM Power Providers Group (“P3”).

Primary Sidebar

Download PDF

Share

Home Page Help Area

Sign up for EPSA’s Power Moves newsletter – a monthly update on the road to a cleaner, affordable and reliable energy future that works for all Americans.

LEARN MORE

Footer

1401 New York Ave. NW
Suite 950
Washington, DC 20005

p 202.628.8200
f 202.628.8260

  • Facebook
  • LinkedIn
  • Twitter
  • Home
  • About EPSA
  • Filings
  • Newsroom
  • For Members
  • Contact
  • PowerFacts Blog
  • FAQ

Copyright © 2023 | Electric Power Supply Association. All rights reserved. | Privacy Policy >