United States of America Before the Federal Energy Regulatory Commission
Waiver of Tariff Requirements } Docket Nos. PL20-7-000
Reply Comments of the Joint Associations
EPSA joins seven other major energy industry trade associations to urge the Commission not to adopt as proposed a policy statement on tariff waivers, highlighting comments submitted to the agency raising concerns that the proposed changes to the waiver policy are unnecessary, would set up an inflexible approach to waivers, and unnecessarily limit the Commission’s ability to protect the public interest. Importantly, the Commission currently holds extensive and adequate flexibility to assess waiver requests on a case-by-case basis, and can therefore ensure that any such necessary relief is granted in a manner fully compatible with the filed rate doctrine and rule against retroactive ratemaking.