Illinois AG Submitted Comments Urging FERC to Reject PJM’s Discriminatory Market Rule Proposals

OCTOBER 2, 2018

Illinois Attorney General Lisa Madigan submitted comments urging the Federal Energy Regulatory Commission (FERC) to reject two proposals by PJM Interconnection that would remove state-supported clean energy from its capacity market and establish a new Minimum Offer Price Rule (MOPR) for state-supported clean energy. If enacted, PJM’s proposals would counteract state clean energy policies by establishing an artificial price floor designed to benefit fossil-fuel energy sources. AG Madigan’s comments noted that electricity prices in the ComEd Locational Delivery Area serving Northern Illinois continued to rise following the institution the State’s Zero Emission Credit (ZEC) system, demonstrating that Illinois’s clean energy policies were not acting as a mechanism for artificially suppressing prices. The comments also requested that FERC institute a minimum price mechanism in a manner that does not raise capacity market prices to unjust and unreasonable levels, and urged FERC to provide states with sufficient time to adjust state-level policies in response to the finalized capacity market rules.