P3 Filings

P3 Files Comments At FERC Supporting PJM’s Proposal to Create a New CONE Area 5 in Response to the Illinois CEJA Law, ER24-462-000
December 19, 2023 | Federal
P3 Offers Further Comment on Capacity Market Offer Caps
November 27, 2023 | Federal
P3 and EPSA file Comments Requesting that FERC Decline to Take Action on IMM Complaint until after resolution of PJM Capacity Filings, in Docket No. EL24-12-000.
November 27, 2023 | Federal
P3 Offers Comments on PJM Capacity Market Reform Filings
November 9, 2023 | Federal
P3 Submits Comments to the PA PUC Regarding Proposed Storage Policy
October 23, 2023 | State
P3 Files Comments at FERC Supporting PJM’s IROL Revisions
September 8, 2023 | Federal
P3 Offers FERC Path Forward for Capacity Market Reforms
August 4, 2023 | Federal
P3 Reminds NJ BPU of the Unnecessary Costs of its ZEC Program
July 6, 2023 | State
P3 Files Comments at FERC Supporting PJM’s Proposed Tariff Provisions Regarding Performance Assessment Interval (“PAIs”), ER23-1996
June 9, 2023 | Federal
P3 Files Comments at FERC Regarding PJMs Auction Delay Request
May 2, 2023 | Federal
P3 Files Comments at FERC Supporting PJM Motion for Establishment of Settlement Judge Procedures Related to Winter Storm Elliott Complaints
April 24, 2023 | Federal
P3 Comments at FERC Regarding Motion to Stay on PJM Issuance of Penalties and Bonuses Related to Winter Storm Elliott
April 20, 2023 | Federal
P3 Joins Diverse National Associations in Protesting PJM’s Independent Market Monitor’s Complaint Against PJM in FERC Docket No. EL23-50
April 17, 2023 | Federal
P3 Files Comments At FERC Opposing The PSC WV’s Complaint Against PJM, EL23-45-000
March 28, 2023 | Federal
P3 Requests Rehearing of FERC’s Approval of PJM’s Change to December 2022 BRA Rules
March 23, 2023 | Federal
P3 Joins EPSA and NEPGA Requesting Rehearing at FERC on Cost Recovery Concerns for New Extreme Cold Weather Standards
March 20, 2023 | Federal
P3 Files Comments At FERC Supporting PJM’s Tariff Changes for Capacity Interconnection Rights For Certain Resources
March 1, 2023 | Federal
P3 Files Opening Brief at U.S. Court of Appeals for the Sixth Circuit along with EPSA in ORDC Appeal
February 23, 2023 | Federal
P3 Comments at FERC Regarding PJM’s Proposed Revisions to Billing of Non-Performance Charges
February 23, 2023 | Federal
P3 Further Responds to PJM’s Call to Change Rules During BRA
February 9, 2023 | Federal
P3 Opposes PJM Proposal to Amend Tariff During Auction
January 20, 2023 | Federal
P3 Issues Press Release on Opposing PJM’s Proposal to Amend Tariff During Auction
January 20, 2023 | Federal
P3 Offers FERC Steps Necessary to Modernize the Grid
January 18, 2023 | Federal
P3 Responds to Capacity Accreditation Complaint
January 17, 2023 | Federal
P3 Files Comments in Support of PJM’s Proposed Tariff Changes To Better Reflect Generation Resources’ Market Costs and Credits
December 23, 2022 | Federal
P3 Joins NEPGA and EPSA Answering ISO/RTO Council Comments to FERC on NERC Proposed Cold Weather Reliability Standards
December 20, 2022 | Federal
P3 and EPSA File Comments at FERC Regarding NERC Proposed Cold Weather Reliability Standards
December 8, 2022 | Federal
P3 Answers PJM and Public Interest Entities Regarding PJM’s VRR Reset Filing
November 14, 2022 | Federal
P3 to FERC: PJM’s VRR Rest Filing will Further Damage Beleaguered PJM Capacity Market
October 21, 2022 | Federal
P3 Comments at FERC on PJM’s MSOC Compliance Filing
October 11, 2022 | Federal
P3 Submits Comments on the 2022 Virginia Energy Plan supporting the Governor’s all-inclusive energy policy.
September 16, 2022 | State
P3 Issues Press Release Regarding Motion to Strike FERC’s MOPR Brief
September 7, 2022 | Federal
P3 Files Motion to Strike FERC MOPR Brief
September 7, 2022 | Federal
P3 Offers Comments at FERC Regarding PJM’s Interconnection Reform Proposal
July 14, 2022 | Federal
P3 Comments in Support of PJM’s FTR Credit Requirement Filing
June 24, 2022 | Federal
P3 Statement on 2023/24 PJM Capacity Auction
June 22, 2022 | Federal
P3 Issues Press Release on Filing MSOC Petitioner Appeal at the DC Circuit U.S. Court of Appeals
June 14, 2022 | Federal
P3 and Joint Petitioners File Brief in MSOC Appeal at the U.S. Court of Appeals for the D.C. Circuit
June 13, 2022 | Federal
P3 Issues Press Release on Filing MOPR Petitioner Appeal at the Third Circuit U.S. Court of Appeals
May 10, 2022 | Federal
P3 Files Petitioner Appeal Brief of MOPR at Third Circuit U.S. Court of Appeals
May 9, 2022 | Federal
P3 Files Comments At FERC Regarding Reactive Power Compensation In PJM – Supporting EPSA’s Comments And Requesting Continuation of PJM’s Reactive Power Compensation Task Force, Docket No. RM22-2-000
February 22, 2022 | Federal
P3 Files Rehearing Request of FERC’s Order of 10% Adder
February 18, 2022 | Federal
P3 Warns Maryland on the Pitfalls of Mandated Long Term Contracts
February 2, 2022 | State
P3 Issues Press Release On the Cumulative Impact of Recent FERC Orders: Lack of Clarity and Stability in PJM Markets Will Increase Costs for Consumers
February 1, 2022 | Federal
P3 Reminds FERC that Modern Electricity Grid Requires Functional Energy and Capacity Markets
February 1, 2022 | Federal
P3 Files Comments at FERC regarding PJM Base Residual Auction Dates Extension
January 31, 2022 | Federal
P3 Requests Rehearing of FERC Order on PJM Reserve Market Reforms
January 21, 2022 | Federal
P3 Files Answer at FERC in Support of Clean Energy Trades Answer Regarding Market Seller Offer Cap Process
December 16, 2021 | Federal
P3 Files Additional Comments at the PA PUC Regarding the Utilization of Storage Resources as Electric Distribution Assets
November 29, 2021 | State
P3 Files Answer Agreeing With PJM And The IMM In Opposing SOO Green Complaint Regarding External Capacity Requirements – EL21-103
October 29, 2021 | Federal
P3 Files Response to FERC Commissioners’ Supporting Statement in Expanded MOPR Proceeding
October 28, 2021 | Federal
P3 Files Comments Requesting That FERC Reaffirm The Use of the 10% Adder for the VRR Curve.
October 22, 2021 | Federal
P3 Along With Others File for Rehearing Request at FERC of Market Seller Offer Cap Order
October 4, 2021 | Federal
P3 Supports Ohio HB 351 That Repeals HB 6 OVEC Subsidies
September 29, 2021 | Federal
P3 Replies to PJM’s Answer in the Expanded MOPR Filing
September 20, 2021 | Federal
P3 Replies to Comments Filed in the PJM’s Expanded MOPR Filing
September 3, 2021 | Federal
P3 Files Supplemental Protest in PJM’s Expanded MOPR Filing
September 2, 2021 | Federal
P3 Protests PJM’s Expanded MOPR Filing
August 20, 2021 | Federal
P3 Files Comments in Support of PJM’s Waiver Request of Specified Market Seller Offer Cap Deadlines, ER21-2444-000
July 30, 2021 | Federal
P3 Files FERC Motion for Expedited Relief Seeking Continuity in Market Seller Offer Cap Rules Pending Final FERC Action, EL19-47; EL19-63
July 23, 2021 | Federal
P3 Requests FERC Approve PJM’s Updated ELCC Construct, ER21-2073
June 22, 2021 | Federal
P3 urges FERC to either adopt a lower PAH for its default Market Seller Offer Cap, or Support PJM’s proposal, but in either case, not to delay the upcoming Base Residual Auction. EL19-47; EL19-63
June 9, 2021 | Federal
P3 Supports Ohio SB 117 That Eliminates Subsidies for OVEC
May 11, 2021 | Federal
P3 Files Comments in Support of PJM Black Start Revisions and Urges FERC Timely Acceptance
April 28, 2021 | Federal
P3 Requests FERC to Dismiss IMM Answer to P3 Motion for Clarification of FERC’s Market Seller Offer Cap Order, EL19-47-001; EL19-63-001
April 23, 2021 | Federal
P3 Requests FERC Clarification or a Rehearing regarding the Market Seller Offer Cap Order
April 9, 2021 | Federal
P3 Files Proponet Testimony in Ohio Senate Energy Committee – HB 128 – Repeal HB 6 Nuclear Subsidies.
March 22, 2021 | Federal
P3 Files Comments At FERC Continuing To Request That PJM Refine Its ELCC Proposal Before Implementation.
March 22, 2021 | Federal
P3 Submits Proponent Testimony for Ohio House Public Utilities Committee on HB 128 – Repeal HB 6 Nuclear Subsidies.
February 22, 2021 | State
P3 Files Comments at the PA PUC Regarding Utilization of Storage Resources as Electric Distribution Assets
February 18, 2021 | State
P3 Urges the Ohio Legislature to Support HB 798 With An Understanding that Significant Work Still Needs to Be Done.
December 3, 2020 | State
P3 Files Comments Generally Supporting PJM’s ELCC Construct; Requests PJM File More Information Before FERC Approval, Docket No. ER19-278
November 20, 2020 | Federal
P3 Joins the Indicated Generation Owners To Request FERC To Approve PJM’s CONE for Reactive Power Service Cost Allocation, EL19-70-000
September 30, 2020 | Federal
P3 Requests That FERC Reject Duquesne Light Company’s FPA 205 Complaint Against PJM, EL20-59-000
September 18, 2020 | Federal
P3 Files Comments Recommending That FERC Reject Dominion’s Waiver Request For Special Treatment During The Pandemic in ER20-2759
September 17, 2020 | Federal
P3/EPSA Support PJM’s Short-Term Pricing And Dispatch Reforms; Request That FERC Expeditiously Accept PJM’s Filing
August 21, 2020 | Federal
P3/EPSA File Comments in Conditional Support of PJM’s Reserve Markets Compliance Filing, EL19-58-002
July 27, 2020 | Federal
P3 Files Comments in Support of PJM’s Second MOPR Compliance Filing, ER18-1314-006.
June 22, 2020 | Federal
P3 Files Comments in Support of PJM’s Revised Fuel Cost Policies, ER20-1764
May 26, 2020 | Federal
P3 Files Comments Supporting PJM’s MOPR Compliance Filing With Suggested Clarifications. ER18-1314, et seq
May 15, 2020 | Federal
P3 and EPSA File Joint Answer Opposing PUCO’s Request For Significant Delay in PJM MOPR Proceeding, ER18-1314-003.
March 30, 2020 | Federal
P3/EPSA Urge FERC To Act Swiftly To Implement Fast-Start Pricing In PJM’s Energy Markets, ER19-2722
October 18, 2019 | Federal
P3 and EPSA Urge FERC To Act Expeditiously In Approving PJM’s Fast-Start Compliance Filing in Docket ER19-2722
September 20, 2019 | Federal
P3 Submits Comments on the New Jersey 2019 Draft Energy Master Plan
September 16, 2019 | State
P3 Urges FERC To Act Expeditiously in PJM Fast-Start Implementation, EL18-34
July 15, 2019 | Federal
P3 and EPSA File Answer Requesting FERC To Accept Petitioners’ Request For A Declaratory Order on Reactive Power Issues, EL19-70
June 18, 2019 | Federal
P3 Opposes Joint Consumer Advocates’ Complaint Regarding PJM’s Market Seller Offer Cap
May 8, 2019 | Federal
P3 Protests IMM’s Complaint Against PJM’s Market Seller Offer Cap in EL19-47
April 18, 2019 | Federal
P3 Urges FERC To Reconsider Denial of PJM’s FTR Waiver Request, ER18-2068
February 8, 2019 | Federal
P3 Urges FERC to Continue Efforts on Price Formation to ensure that PJM’s Energy Storage Resource Rules are Implemented in a Reliable, Nondiscriminatory Manner, ER19-469
February 8, 2019 | Federal
P3 Supports PJM Gas Contingency Cost Proposal to Improve Gas-Electric Coordination
January 11, 2019 | Federal
P3 Urges FERC To Accept Its Requested Modifications To PJM’s Proposed Tariff Amendments Regarding Generation Maintenance Adder Costs in ER19-210; EL19-8.
November 19, 2018 | Federal
P3 Files Comments and Limited Protest with Expert Testimony in PJM Quadrennial Review, ER19-105
November 19, 2018 | Federal
P3 Files Reply Brief with FERC Reinforcing The Need For A Clean MOPR For PJM’s Capacity Market in Docket EL18-178, et al
November 6, 2018 | Federal
P3 Files Initial Brief with supporting Affidavit from Dr. Roy Shanker Urging FERC to Adopt a Clean MOPR For the PJM Capacity Market
October 2, 2018 | Federal
P3 Files Supportive Comments at FERC Regarding PJM’s FTR Credit Policy
August 15, 2018 | Federal
P3 Offers PJM Comments on Proposed Clean MOPR and Unit Specific FRR
July 26, 2018 | Federal
P3 Files Comments Urging FERC to Reform Credit Requirements for Market Participants
June 25, 2018 | Federal
P3 Files Answer in Support of Complaint Urging FERC to Require PJM to File a Clean MOPR
June 20, 2018 | Federal
P3 Files Answer asserting that a Clean MOPR is Necessary to Protect PJM’s Markets from Material Subsidies
June 1, 2018 | Federal
P3 Files Protest with Supporting Affidavit from Dr. Roy Shanker regarding PJM’s Proposed Capacity Repricing/MOPR-Ex Proposals in FERC Docket ER18-1314
May 7, 2018 | Federal
P3 Files Pre-Technical Conference Comments by Dr. Roy Shanker in FERC Seasonal Capacity dockets – EL17-32-000 and EL17-36-000
April 11, 2018 | Federal
P3 Files Reply Brief with supporting expert Robert B. Stoddard Affidavit in FERC Fast Start Proceeding, EL18-34
March 14, 2018 | Federal
P3 Urges PA House to Oppose Anti-Competitive Provisions of HB 1412
March 9, 2018 | State