FERC Filings
EPSA's Motion For Leave To Intervene and Comment In Support of PJM
MOTION TO INTERVENE
EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.
Many of EPSA’s members are authorized to sell energy and ancillary services at market-based rates. EPSA members have been active participants in PJM, and EPSA has participated in many of the Commission’s ongoing proceedings on PJM issues. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
Several EPSA members with facilities in PJM could provide black start service pursuant to Schedule 6A of the PJM Tariff, which sets out a formula for payments to generators for black start service and includes allocation factors for fixed and variable generation costs. Under Schedule 6A, deviations from these allocation factors may be approved by the Commission, based on a demonstration that costs incurred by a generator may be above the current caps used under the Tariff. PJM has filed for FERC approval of such revenue requirements for six generating units pursuant to Section 205 of the Federal Power Act (FPQ), 16 U.S.C. § 824d. PJM’s request is consistent with its tariff, as contemplated, and achieves the goal of encouraging existing and new generation to provide black start service thus enhancing reliability. The Commission should approve PJM’s request.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:
John K. Hawks, Acting Vice President of Policy
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200