Date: November 7, 2022 Venue: Federal Energy Regulatory Commission Proceeding: Cybersecurity Incentives Notice of Proposed Rulemaking Docket: RM22-19-000 EPSA supports an incentive-based approach to encourage utilities to make investments above and beyond existing standards to keep the Bulk-Power System protected against emerging threats not yet reflected in standards or regulations. As directed by Congress in […]
Read MoreEPSA Comments on Proposed Guidance for the DOE Civil Nuclear Credit Program Second Award Cycle
DOE’s updated guidance would allow for a nuclear facility to apply for CNC Program funding through the offer of a narrative explanation on the “likelihood” that the facility will retire within four years. As the CNC Program eligibility criteria becomes broader, EPSA continues to call on DOE to develop an efficient process (consistent with the intent of Congress) that relies on the best available expertise to determine the most appropriate use of Program funding.
Read MoreEPSA Comments on Certain Energy Generation Incentives (relative to the Inflation Reduction Act) Treasury and IRS Request for Comments
EPSA filed in response to the Treasury/Internal Revenue Service Request for Comments on Certain Energy Generation Incentives regarding key provisions in the Inflation Reduction Act (IRA), specifically the IRA’s Addition of the Zero-Emission Nuclear Power Production Credit (§ 45U). EPSA recommend that Treasury/IRS sharpen and solidify guidance on the definition of gross receipts, take full account of programs providing governmental (out-of-market) support, and rely on a neutral, independent entity to certify § 45U credits for the purposes of payment reduction.
Read MoreEPSA Answer in Support of IPPNY’s Motion for Expedited Action on Remand in NYISO DCR proceeding
Docket No.: ER21-502-000 Filed at: Federal Energy Regulatory Commission (FERC) Date: October 20, 2022 EPSA supports the Independent Power Producers of New York (“IPPNY”) request that the Commission issue an order expeditiously on remand in this proceeding consistent with the judgement of the United States Court of Appeals for the District of Columbia Circuit (“DC […]
Read MoreComments on Proposed Rule to Reform Interconnection Procedures and Agreements
Date: Oct 13, 2022 Venue: FERC Docket: RM22-14-000 EPSA strongly supports the Commission’s effort to reform the interconnection process and offers several recommendations for clarifications or modifications that will ensure the resulting process is fair, just and reasonable, and not unduly discriminatory to any class of interconnection customers or project developers. Fundamentally, it is critical […]
Read MoreComments on FERC Proposed Rule for Credit-Related Information Sharing in Organized Wholesale Electric Markets
Date filed: Oct 7, 2022 Venue: Federal Energy Regulatory Commission (FERC) Proceeding : Credit-related Information Sharing in Organized Wholesale Electric Markets Docket: RM22-13-000 Summary: EPSA largely supports FERC’s NOPR proposing to revise ISO/RTO tariffs to permit the sharing of market participants’ credit-related information with other ISOs/RTOs to enhance credit risk assessment efforts. EPSA proposes certain modifications […]
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