United States of America Before the Federal Energy Regulatory Commission
Docket Nos. ER10-2051-010 et al.
Motion to Intervene Out-of-Time, Motion for Leave to Answer, and Answer of the PJM Power Providers Group and the Electric Power Supply Association
P3/EPSA move to intervene out-of-time and answer multiple Limited Protests filed by the PJM IMM in the associations’ member companies’ updated market power analyses proceedings. In these cases the IMM raises grievances with certain PJM market power mitigation rules, but asks FERC to condition individual sellers’ market-based offers in the PJM markets within specific parameters based on those generic concerns over PJM’s rules. P3/EPSA ask FERC to dismiss the protests as misplaced in these proceedings, suggesting that the IMM should raise generic issues through generic means.