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Home / Filings / Reply Brief of Petitioners in PJM Market Seller Offer Cap Appeals

September 13, 2022

Reply Brief of Petitioners in PJM Market Seller Offer Cap Appeals

By EPSA

Date filed: September 9, 2022

Venue: U.S. Court of Appeals for the D.C. Circuit

Case: Vistra et al. v. FERC

Case Nos. 21-1214 et al.

Filers: Joint Petitioners: EPSA, P3, Calpine, LS Power, Talen, Vistra, Constellation

The reply brief from Joint Petitioners finalizes the briefing in this case, which seeks court review of the Federal Energy Regulatory Commission (FERC) orders approving revisions to PJM’s Market Seller Offer Cap (MSOC) because, as approved, the mechanism fails to properly reflect the risks and costs imposed on suppliers and is at odds with PJM’s Capacity Performance structure. Petitioners seek vacatur as the appropriate remedy from the court and focus on three arguments in this brief: FERC failed to justify the exclusion of opportunity costs from capacity offers; FERC failed to justify its categorical exclusion of key risks from capacity offers; and FERC’s determination that capacity sellers lack Section 205 rights is contrary to law. The oral argument has not yet been scheduled.

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