United States of America Before the Federal Energy Regulatory Commission
PJM Interconnection, L.L.C. } Docket No. EL19-58-002
Comments of the PJM Power Providers Group and the Electric Power Supply Association
In the joint comments, the Electric Power Supply Association (EPSA) and the PJM Power Providers Group (P3) (jointly P3/EPSA) conditionally support PJM’s July 6, 2020, compliance filing in its Reserve Markets Pricing proceeding (EL18-58-002). P3/EPSA argue that while the substance of the tariff changes proposed in PJM’s Compliance Filing comply with the requirements of the Commission’s May 21 Order in this proceeding, PJM’s proposal to delay the implementation of these changes until June 1, 2022 is inconsistent with the requirements of the May 21 Order and will unnecessarily result in the continued application of market rules that the Commission has expressly found to be unlawful under the Federal Power Act. Accordingly, P3/EPSA urge the Commission to require PJM to implement the substantive changes proposed in PJM’s Compliance Filing by May 21, 2021, or, at latest, October 15, 2021. Even if the Commission is not prepared to impose a firm deadline on PJM, P3/EPSA request it should require PJM to submit a report on its progress towards implementation by May 21, 2021.
