ESA Motion of Leave to Answer requesting FERC direct PJM to comply with the Federal Power Act
Through its Complaint, ESA requests that the Commission direct PJM to comply with the filing requirements of the Federal Power Act by submitting revisions to the Tariff or Operating Agreement setting forth the methodology by which PJM calculates the benefits factor used in clearing resources in the Regulation market and the parameters governing the design of the dynamic Regulation (“RegD”) signal. The concerns underlying this request were stated clearly: the various changes to the Regulation market implemented by PJM without Commission review are resulting in limited-energy RegD resources being called upon to operate at full raise or full lower position for extended periods of time. These changes have fundamentally altered the Regulation product for RegD resources, significantly affecting the rates, terms, and conditions of Regulation service.