Comments

APPA and NRECA filed a protest in the Petition for Declaratory Order of Advanced Energy Economy in Docket No. EL17-75-000 (7-19-17)

APPA filed post-technical conference comments and post-technical conference reply comments on State Policies and Wholesale Markets Operated by ISO New England Inc., New York Independent System Operator, Inc., and PJM Interconnection, L.L.C. in Docket No. AD17-11-000 (6-22-17; 7-14-17)

APPA, LPPC, and NRECA filed joint comments on the Review of Generator Interconnection Agreements and Procedures in Docket No. RM17-8-000. In addition, APPA and LPPC also filed joint comments in Docket No. RM17-8-000 objecting to one of the Commission's specific proposals which would expand interconnection customers' option to build their own interconneciton facilities and stand-alone network upgrades (4-13-17)

APPA and NRECA filed comments on the Uplift Cost Allocation and Transparency in Markets Operated by Regional Transmission Organizations and Independent System Operators in Docket No. RM17-2-000 (4-10-17)

APPA and NRECA filed comments on the Fast-Start Resource Pricing NOPR in Docket No. RM17-3-000 (2-28-17)

APPA, EEI, ELCON, EPSA, LPPC, NRECA, and TAPS filed comments on FERC's Notice of Petition for Rulemaking in Docket No. AD17-9 (2-17-17)

APPA and NRECA filed comments on the Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators NOPR in Docket No. RM16-23-000 (2-13-17)

APPA, Dominion Resources Services, Inc., American Municipal Power, Inc., Old Dominion Electric Cooperative, PJM Industrial Customer Coalition, NRECA, and Public Power Association of New Jersey filed a protest in Docket No. EL16-49-000 (1-30-17)

APPA, the PJM Industrial Customer Coalition, the Public Power Association of New Jersey, the NRECA, Rockland Electric Company, the Union of the Concerned Scientists, the Sierra Club, and the Natural Resources Defense Council filed comments in Docket Nos. EL17-32 and EL17-36 in support of two complaints filed at FERC regarding the pending implementation of full Capacity Performance in PJM (1-25-17)

APPA, TAPS, and LPPC filed comments on the Essential Reliability Services and the Evolving Bulk-Power System —Primary Frequency Response NOPR in Docket No. RM16-6-000 (1-24-17)

APPA and AMP filed a request for rehearing of the Final Rule (Order No. 831) on Offer Caps in Markets Operated by RTos and ISOs in Docket No. RM16-5-001 (12-19-16)

APPA filed comments on the MISO proposal to estabish a Forward Resource Auction for the Competitve Retail Areas, also known as the Competitive Retail Solution in Docket ER17-284 (11-14-16)

APPA and TAPS filed comments on the FERC Staff Retrospective Analysis of Existing Rules memo in Docket No. AD12-6-002 (12-5-16)

APPA and TAPS filed comments in FERC Docket No. RM 16-21-000 on the Commission's NOI on Modifications to Commission Requirements for Review of Transactions under Section 203 of the FPA and Market-Based Rate Applications under SEction 205 of the FPA (11-28-16)

APPA submitted an initial brief to address FERC's proceedings under section 206 of the Federal Power Act, 16 U.S.C. §824e, to investigate the tariffs of the SPP and MISO in Docket Nos. EL16-91-00 and EL16-99-00 (10-21-16)

APPA and NRECA filed comments in response to FERC’s Competitive Transmission Development Technical Conference in Docket No. AD16-18-000. (10-3-16)

APPA filled comments in FERC Docket No. RM16-17 on the Commission's NOPR on Data Collection for Analytics and Surveillance and Market-Based Rate Purposes. (09-19-19)

APPA filed comments in FERC Docket No. RM16-15 on the Commission's proposed "Regulations Implementing FAST Act Section 61003- Critical Electric Infrastructure Security and Amending Critical Energy Infrastructure Information" (8-19-16)

APPA, LPPC, and NRECA filed comments in FERC Docket Nos. RM16-12 and RM15-21 in response to a technical conference on generation interconnection issues (6-30-16) 

APPA filed comments in FERC Docket AD16-20 on possible barriers to participation by electric storage resources in the wholesale electric markets of RTOs and ISOs (6-6-16)

APPA submitted comments in FERC Docket ER16-1404 on the compliance filing by the NYISO in response to the Commission's order requiring a self-supply exemption and renewable energy exemption to the buyer-side mitigation rules in the NYISO capacity market (5-31-16)

American Municipal Power, Inc., APPA, Old Dominion Electric Cooperative, PJM Industrial Customer Coalition, and Public Power Association of New Jersey filed a Motion to Dismiss of Dominion Resources Services, Inc. in Docket No. EL16-49 (5-6-16)

American Municipal Power, Inc., APPA, Old Dominion Electric Cooperative, PJM Industrial Customer Coalition, and Public Power Association of New Jersey filed a Motion for Leave to Answer and Answer of Dominion Resources Services, Inc. in Docket No. EL16-49 (4-25-16)

APPA, LPPC, and TAPS filed joint comments in FERC Docket RM16-6 in response to the NOI on primary frequency reponse (4-25-16)

APPA joined comments filed by the "Load Group" an ad hoc coalition of parties in FERC Docket EL16-49-000 (4-11-2016)

APPA, NRECA and AMP filed joint comments in FERC Docket RM16-5 on offer caps in markets operated by RTOs and ISOs (4-4-2016)

Trade associations, including APPA, reply supporting customers in the BPA v. PacifiCorp (3-16-2016)

APPA, LPPC, NRECA, PPC, NRU and PNGC filed an answer in support of BPA's Partial Motion for Summary Disposition in the subject FERC docket (3-7-2016)

APPA, NRECA filed rulemaking comments in FERC Docket No. RM16-3, Ownership Information in Market-Based Rate Filings (2-22-2016)

APPA, NRECA filed comments on notice of proposed rulemaking on "connected entities" in RTOs and ISOs (1-22-2016)

APPA joined motion for leave to answer and answer by the PJM Load Group and Interested State Commissions supporting the PJM Independent Market Monitor's protest and counterproposal to PJM’s request for tariff changes to allow generators to submit day-ahead energy offers that vary by hour and to update their offers in real-time on an hourly basis in Dockets EL15-73 and ER16-372 (12-28-2015)

APPA, LPPC, and TAPS filed joint comments on the FERC NOPR regarding access to NERC databases (12-15-2015)

APPA joined a protest by the PJM Load Group and Interested State Commissions to PJM’s request for tariff changes to allow generators to submit day-ahead energy offers that vary by hour and to update their offers in real-time on an hourly basis in Docket ER16-372 (12-11-2015)

APPA, NRECA filed comments on settlement intervals and shortage pricing in markets operated by regional transmission organizations and independent system operators (11-30-2015)

APPA, NRECA, Northwest Requirements Utilities, Pacific Northwest Generating Cooperative, and the Public Power Council filed comments in FERC Docket No. EL15-100-000 in support of the petition for declaratory order filed by the Northwest Power Pool Members’ Market Assessment and Coordination Committee (10-7-2015)

APPA, EEI, ELCON, EPSA, LPPC, NRECA and TAPS filed comments on the CIP Version 5 Reliability Standards Revisions NOPR Docket RM15-14 (9-21-2015)

APPA, LPPC and NRECA filed comments on the AWEA petition docket RM15-21-000 (9-18-2015)

APPA, NRECA, and the Kansas Corporation Commission filed joint pleadings with FERC regarding ITC Grid Development’s petition for declaratory order (8-27-2015)

  • Request for petition to be dismissed without prejudice because the relief it sought was so far-reaching it should be the subject of a rulemaking proceeding, not a simple declaratory order
  • Protest on the substance of the petition

APPA, EEI, NRECA, and others filed comments in response to FERC’s NOPR proposing to approve the NERC stage 2 GMD standard (7-27-2015)

APPA, TAPS filed comments raising concern about NERC not fully asserting its authority to oversee implementation of regional delegation agreements (7-27-2015)

APPA, NRECA filed a request for rehearing of FERC’s June 9, 2015 Order approving the core of PJM's Capacity Performance proposal  (7-9-2015)

APPA filed comments in FERC Docket EL15-64 in support of the reforms to the NYISO capacity market proposed by NYPA, NYSERDA, and NYPSC (6-29-2015)

APPA comments on FERC's NOPR that approves the Disturbance Monitoring and Reporting Requirements Reliability Standard, PRC-002-2, submitted by NERC (6-22-2015)

APPA filed supplemental comments for the Technical Conference on Environmental Regulations and Electric Reliability, Wholesale Electricity Markets, and Energy Infrastructure (5-14-2015)

APPA, NRECA, and others filed a request for rehearing on FERC's conclusion that the transfer of transmission facilities by one or more public utilities to another person is outside the scope of FERC's jurisdiction (5-1-2015)

APPA, NRECA, and TAPS filed comments on FERC's proposed rulemaking to allow sellers with market-based rate authority for energy and capacity to also sell primary frequency response service at market-based rates to public utility transmission providers (4-27-2015)

APPA and TAPS filed a request for rehearing or classification of Order No. 807, FERC's final rule on open access and priority rights on interconnection customer's interconnection facilities (4-20-2015)

APPA and NRECA filed comments on FERC's proposed statement of policy on hold-harmless commitments under section 203 of the Federal Power Act (3-30-2015)

APPA and NRECA filed post-technical workshop comments in the FERC docket on Price Formation in Energy and Ancillary Services Markets urging that costs to consumers be minimized in any reforms to price formation (3-6-2015)

APPA and NRECA jointly filed a short protest to PJM’s Capacity Performance Product arguing that PJM has made multiple recent filings changing its capacity market auctions, and it has not shown that these changes are needed (1-20-2015)

APPA, NRECA, and TAPS filed a motion to intervene and comments in support of NERC's risk-based registration initiative (1-12-2015)

APPA, NRECA, and EEI filed comments on due process issues in FERC review of a NERC Notice of Penalty (12-18-2014)

APPA filed comments on the Department of Energy SNPOR for fossil fuel-generated energy consumption reduction for new federal buildings and major renovations of federal buildings (EERE–2010–BT–STD–0031) (12-15-2014)

APPA, NRECA, LPPC, and others filed a motion to intervene regarding NERC reliability assurance initiative (12-3-2014)

APPA filed a petitioners' initial brief with the DC Circuit in Western Minnesota Municipal, et al. v. FERC (11-24-2014)

APPA filed comments on FERC’s proposed performance metrics for both RTOs and non-RTO regions (11-3-2014)

APPA filed a motion to intervene and protest under FERC Docket EL14-97-000 (10-1-2014)

APPA and NRECA joint comments on FERC market-based rate rulemaking - Docket No. RM14-14-000 (9-23-2014)

APPA and NRECA filed an answer in opposition to the Indicated Capacity Suppliers’ motion seeking a mandatory capacity auction in MISO, ER11-4081-001 (9-9-2014)

APPA, NRECA, and LPPC comments on the FERC NOPR on the NERC Physical Security Standard, CIP-0014-001 (9-8-2014)

APPA, Western Minnesota Municipal Power Agency, and Public Power Council petition for review in WMMPA v. FERC, 14-1153, filed in DC Circuit Court (8-15-2014)

APPA and NRECA’s reply to New England Transmission Owners’ opposition to our intervention in the ROE docket in which FERC adopted its new policy (8-13-2014)

APPA, NRECA, and New Hampshire Electric Cooperative answer and oppose the New England Transmission Owners' motion seeking clarification of aspects of FERC Opinion No. 531 (Coakley v. Bangor Hydro-Electric Co.) (8-5-2014)

APPA, NRECA, EPSA, and ODEC response to FERC's rehearing petition (8-4-2014)

APPA and TAPS comments to FERC on Open Access and Priority Rights on Interconnection Customer's Interconnection Facilities (7-30-2014)

APPA, NRECA, et al, petition for rehearing of complainants in FERC docket EL11-66-001 on return on equity used to calculate transmission service rates under ISO-New England tarriff (7-21-2014)

APPA and NRECA motion to intervene out-of-time under FERC docket EL11-66, New England ROE proceeding (7-21-14)

APPA filed a doc-less motion to intervene under FERC docket EL14-48-000

APPA and American Municipal Power filed post-technical conference comments in docket AD14-8. The topic of the April 1 technical conference, was "Winter 2013-2014 Operations and Market Performance in RTOs and ISOs." (5-15-2014)

APPA filed a joint petitioners’ reply brief in the NRU v. FERC oversupply case with US Court of Appeals for the Ninth Circuit (4-18-2014)

APPA filed a Joint Letter regarding centralized capacity markets in regional transmission organizations and independent system operators, Docket No. AD13-7-000 (2-10-2014)

APPA and NRECA filed a brief with the U.S. Court of Appeals for the Fourth Circuit in PPL Energyplus LLC et al v Douglas R.M. Narazarian et al and CPV Maryland LLC. (2-12-2014)

APPA filed a Motion for Leave to Intervene with the U.S. Court of Appeals for the District of Columbia Circuit related to the FERC orders in Docket No. EL13-52. In this proceeding, Edison Electric Institute seeks review of FERC orders involving FERC’s conditional approval of the Western Electricity Coordinating Council’s proposal to establish an independent reliability coordinator for the Western Interconnection, known as Peak Reliability. FERC approved WECC’s proposal to implement the bifurcation via a sub-delegation structure. FERC denied EEI’s request for rehearing of its initial order. APPA has members, including several within the WECC footprint, that are either subject to or potentially impacted by NERC’s mandatory reliability standards. (2-06-2014)

APPA and NRECA filed a joint brief in PPL Energy Plus LLC, et al v. Lee A. Solomon in his official capacity as president of the New Jersey Board of Public Utilities, et al, in the US Court of Appeals for the Third Circuit (1-27-2014)

APPA and the Public Power Council file a Motion to Intervene and Request for Rehearing in FERC's Dec. 19, 2013 decision to change a longstanding interpretation of the Federal Power Act's tie-breaker preference for state and municipal applicants for preliminary permits and original licenses for hydroelectric development. (1-22-2013)

APPA files Post-Technical Conference Comments in follow-up to the Technical Conference on Centralized Capacity Markets in Regional Transmission Organizations and Independent System Operators held in September (01-08-2014)

APPA and NRECA filed a motion for limited clarification with FERC on Order No. 791. (12-20-2013)

APPA and NRECA filed an initial brief with the FERC on the Minimum Offer Price Rule proposed by the Midwest Independent Transmission System Operator, Inc. The brief supports FERC's rejection of the proposal and urge the Commission to affirm and uphold the determination in its June 11, 2012 Order3 that MISO's proposed MOPR has not been shown to be just and reasonable. (12-9-2013)

APPA, Northwest Requirements Utilities and others filed a joint opening brief in Northwest Requirements Utilities, et. al. v. Federal Energy Regulatory Commission in the US Court of Appeals for the Ninth Circuit. The brief states that the Court “must set aside the Commission’s Orders because the Commission could not properly invoke jurisdiction under section 211A of the Federal Power Act,” and for several other reasons. (12-9-2013)

APPA filed a brief in the US Court of Appeals for the DC Circuit in South Carolina Public Services Authorities, et. al v. Federal Energy Regulatory Commission regarding Order 1000. The brief argues that FERC’s Order No. 1000 mandate contravenes section 217(b)(4) of the Federal Power Act (FPA), which explicitly directs FERC to facilitate the planning of transmission facilities to meet load-serving entities’ reasonable needs.  The reply brief also states that Order No. 1000 contains public policy directives that are too vague, exceed FERC jurisdiction, and undermine wholesale electric markets.  APPA only joined in the section 217(b)(4) section of the reply brief. (12-9-2013)

APPA, along with the LPPC and NRECA, jointly filed a brief for South Carolina Public Service v. FERC, Case No. 12-1232, supporting FERC’s ruling in Order No. 1000 to NOT exercise its FPA Section 211A jurisdiction over non-jurisdictional utilities to require them to participate in regional transmission planning and cost allocation regimes. (10-17-2013)

Initial brief of APPA and NRECA on Minimum Offer Price Rule Issues in MISO, Docket No. ER11-4081-001. (10-14-2013)

APPA, along with the National Rural Electric Cooperative Association filed a joint amici brief in North Dakota v. Swanson (Case NO. 11-CV-3232) with the United States District Court for the District of Minnesota supporting the plaintiffs’ challenge to Minnesota’s Next Generation Energy Act. The trade associations argued that the statute violates the dormant Commerce Clause of the U.S. Constitution by imposing regulations on generators outside of Minnesota’s borders. (10-10-2013)

APPA and FMPA joint comments with respect to proposed Standard WEQ-001-106.2 (NAESB NOPR Docket RM05-5-022), requesting that it be revised to ensure that it will not inadvertently limit network customers’ ability to modify either their secondary network service reservations or their actual use of the transmission capacity available to them under such reservations (9-24-2013)

APPA and NRECA file Joint Motion to Intervene and Comments in Docket No. RR13-9-00 (9-21-2013)

APPA, EEI, ECRC, EPSA, LPPC, and TAPS files Comments in Docket No. RM13-8 (Electric Reliability Organization Proposal to Retire Requirements in Reliability Standards) (8-27-2013)

APPA files Comments on the Notice of Proposed Rulemaking issued for Docket RM13-17-000 (Communication of Operational Information Between Natural Gas Pipelines and Electric Transmission Operators) (8-26-2013)

Joint Signatories, including APPA, Submit Joint Petition for Review of Order of the Federal Energy Regulatory Commission in Docket EL11-44-004 and EL11-44-005 (Iberdrola Renewables, Inc., et al. v. Bonneville Power Administration) in the United States Court of Appeals for the Ninth Circuit (8-22-2013)

APPA, NRECA, and EEI file Joint Reply Comments on Small Generator Interconnection, FERC Docket RM13-2-00 (8-12-2013)

APPA files Supplemental Comments on the WIRES Petition, FERC Docket RM13-18-000 (7-26-2013)

APPA, NRECA, TAPS, EEI, EPSA, LPPC, and the Electricity Consumers Resource Council Motion for Delay of Action in response to FERC Docket RM11-11-000 (7-18-2013)

Joint Signatories, including APPA, Letter to FERC Commissioners in Response to EEI White Paper on Transmission ROEs and a WIRES Petition in FERC Docket RM13-18 (7-12-2013)

APPA, NRECA, TAPS Motion for Leave to Intervene in People of the State of New York, et al. v. FERC Regarding FERC Docket Nos. RM12-6 and RM12-7 in the U.S. Court of Appeals for the Second Circuit No. 13-2316 (7-8-2013)

APPA Motion to Intervene in Support of the City of Boulder's Petition for Declaratory Order (6-17-2013)

APPA Motion for Leave to Intervene in Midland Power Cooperative, et al. v. FERC Regarding FERC Docket No. ELL11-39 in the U.S. Court of Appeals for the DC Circuit No. 13-1184 (6-10-2013)

APPA, NRECA and EEI Comments on the NOPR to Update the Small Generator Interconnection Procedures and Agreements, Docket No. RM13-2 (6-3-2013)

 APPA and NRECA Joint Motion for Clarification, Or in the Alternative, Request for Rehearing of Order No. 773-A, Docket Nos. RM12-6 and RM12-7, (5-17-2013)

APPA, Massachusetts Municipal Wholesale Electric Co., New Hampshire Electric Cooperative, Inc., NEPPA and NRECA filed a Petition for Rehearing of the Feb. 12, 2013, order in FERC Docket ER12-953-000 (03/14/2013)

APPA, NRECA and the Pacific Northwest Generating Cooperative Submit Joint and Several Petition for Review of Orders of the Federal Energy Regulatory Commission in FERC Docket EL11-44 (Iberdrola Renewables, Inc., et al. v. Bonneville Power Administration) in the United States Court of Appeals for the Ninth Circuit. (02/08/2013)

APPA seeks rehearing of final rule on Definition of Bulk Electric System and Rules of Procedure in FERC Docket RM12-6-000 and RM12-7-000 (1/22/2013)

APPA, NEPPA and NRECA Submit Motion to Intervene and Protest in FERC Docket ER12-953 in ISO New England. (12/28/2012)

APPA, NRECA and TAPS Submit Comments in FERC Docket RM12-22 on Reliability Standards for Geomagnetic Disturbances. (12/21/2012)

APPA, EEI, LPPC, NRECA and TAPS Submit Comments in FERC Docket RM12-4 on Commission’s Notice of Proposed Rulemaking (NOPR) to Accept Proposed Reliability Standard FAC-003-2, a Revised Mandatory Reliability Standard for Vegetation Management, submitted by the North American Electric Reliability Corporation (NERC). (12/20/2012)

APPA and NRECA File Motion to Intervene Out-Of-Time and Limited Comments in FERC Docket Nos. EL13-11 and RD13-1 in Tri-State Generation and Transmission Association, Inc. v Western Electric Coordinating Council and North American Electric Reliability Corporation (12/12/2012)

APPA and LPPC Submit Motion for Clarification in FERC Docket No. RM10-12 Electricity Market Transparency Provisions of Section 220 of the Federal Power Act (10/22/2012)

APPA, EPSA, NRECA, EEI and Old Dominion Electric Cooperative Submit Reply Brief of Petitioners in Electric Power Supply Association, et al. v. FERC in the US Court of Appeals for the District of Columbia Circuit (Nos. 11-1486, et al.) (10/11/2012)

APPA and the New York Association of Public Power Submit Request for Rehearing in FERC Docket No. EL11-50 Astoria Generating Company, L.P. and TC Ravenswood, LLC v. New York Independent System Operator (10/10/2012)

APPA Submits Motion to Intervene and Comments in FERC Docket No. RR12-13 North American Electric Reliability Corporation 2013 Business Plan and Budget (09/28/2012)

APPA Submits Comments in  FERC Docket Nos. AD12-9 Allocation of Capacity on New Merchant Transmission Projects and New Cost-Based, Participant-Funded Transmission Projects and AD11-11 Priority Rights to New Participant-Funded Transmission (09/24/2012)

APPA and NRECA File Brief of Amici Curiae in Support of Appellant PJM Interconnection in Marlin Yorty and Nora McCormish v. PJM Interconnection (No. 1210 EDA 2012) in the Superior Court of Pennsylvania Eastern District (09/18/2012)

APPA Submits Comments in the Notice of Proposed Rulemaking (NOPR) FERC Docket Nos. RM11-24 Third-Party Provision of Ancillary Services and AD10-13 Accounting and Financial Reporting for New Electric Storage Technologies (09/07/2012)

APPA et al. File Proof Brief in New Jersey Board of Public Utilities et al., v. FERC (Nos 11-4245, et al.) in the U.S. Court of Appeals for the Third Circuit (09/06/2012)

APPA Files Comments in FERC Docket Nos. RM12-6 and RM12-7 Revisions to Electric Reliability Organization Definition of Bulk Electric System and Rules of Procedure (09/04/2012)

APPA, EEI, ELCON, EPSA, LPPC, TAPS and NRECA File a Joint Brief in FERC Docket FA11-21 Regarding the "Performance Audit of the North American Electric Reliability Corporation for Budget Formulation, Administration, and Execution" (08/20/2012)

APPA Signs Joint Letter to FERC Commissioners in FERC Docket RM11-26 Concerning Current Transmission Incentive Policies (03/05/2012)

APPA et al. File Answer in Opposition to the Motion for Clarification of the Independent Market Monitor for PJM, and Request for Ruling by March 5, 2012 FERC Docket ER11-2875 (03/01/2012)

Comments of the Electric Utility Trade Associations in FERC Docket AD12-1 Commission Role Regarding Environmental Protection Agency's Mercury and Air Toxics Standards (02/29/2012)

APPA et al. File Non-Binding Statement of Issues in New Jersey Board of Public Utilities et al., v. FERC  in the U.S. Court of Appeals for the Third Circuit (02/27/2012)

APPA et al. File Petition for Review in Old Dominion Electric Cooperative et al., v. FERC  in the U.S. Court of Appeals for the District of Columbia Concerning Order 745 (02/10/2012)

 

Contacts

Delia Patterson, APPA Acting Senior Vice President of Advocacy and Communications & General Counsel, 202/467-2993