Electricity Markets Filings and Reports
The Association proposes that the mandatory capacity market constructs be reformed to serve as voluntary, residual capacity procurement mechanisms.
The American Public Power Association, American Municipal Power, Inc., and the Public Power Association of New Jersey on January 21, 2020 requested rehearing of the Federal Energy Regulatory Commission’s December 19, 2019 order which implemented a sweeping expansion of the Minimum Offer Price Rule used in PJM’s capacity construct, the Reliability Pricing Model.
The American Public Power Association and a diverse group of energy industry stakeholders on March 5, 2019 sent a letter to FERC detailing principles to maximize the benefits of organized wholesale electricity markets.
The Association filed comments urging FERC to reject the U.S. Department of Energy’s proposed rule requiring organized electricity markets to adopt tariff changes that would ensure full cost recovery for certain “fuel-secure” resources. We indicated that RTO-operated markets are not designed to achieve fuel diversity.
The Association supports FERC efforts to reduce or remove undue barriers to electric storage resource participation in organized wholesale markets through distributed energy resource aggregators.
In May 2017 post technical conference comments, the Association urges FERC to encourage implementation of alternatives to the mandatory capacity markets outside of the five pathways.
In May 2017 technical conference reply comments, the Association recommends a path forward for FERC to avoid wholesale market design by litigation and unintended adverse consequences.
A 2016 Association report on retail electric prices shows that between 1997 and 2016, price icreases in states with deregulated electric markets and regulated states were about the same.
PJM’s Reliability Pricing Model was designed to be a residual, as-needed market intervention. But over time, market factors have led generators to seek more revenue from RPM, as shown in Missing Money Revisited.
In a May 2016 open letter to the GAO, the Brattle Group responded to Senate questions on electricity capacity markets. Many of the responses are misleading or unsupported.