Comments of Institute for Policy Integrity in AD23-10-000
Coherent Identifier 20.500.12592/6w292s

Comments of Institute for Policy Integrity in AD23-10-000

2 October 2023


AD23-10-000 COMMENTS OF THE INSTITUTE FOR POLICY INTEGRITY AT NEW YORK UNIVERSITY SCHOOL OF LAW Pursuant to the Federal Energy Regulatory Commission’s (FERC or the Commission) September 17, 2023 notice,1 the Institute for Policy Integrity at New York University School of Law (Policy Integrity)2 respectfully submits these comments in support of the American Clean Power Association’s petition for a. [...] FERC should grant the Petition because a technical conference would help the Commission ensure just and reasonable rates and prevent unduly prejudicial practices.5 If accreditation undervalues the reliability contributions of some resources and overvalues the contributions of others, it distorts relative investment/retirement incentives and 1 Capacity Accreditation; Notice of Request for Technical. [...] 3 Petition of the American Clean Power Association for Technical Conference on Capacity Accreditation, Petition of the American Clean Power Association for a Technical Conference on Capacity Accreditation under AD23-10, Docket No. [...] 9 MONITORING ANALYTICS, LLC, STATE OF THE MARKET REPORT FOR PJM: VOLUME 1: INTRODUCTION 54 (“In 2022, capacity market revenue accounted for 28 percent of total net revenues for a new [combustion turbine plant], 21 percent for a new [combined cycle plant], 44 percent for a new [coal plant], 7 percent for a new nuclear plant, 51 percent for a new [diesel plant], 3 percent for a new onshore wind inst. [...] The topics that would benefit from robust discussion during a technical conference include: • What are the latest technical developments for modeling the reliability benefits of renewable and energy-limited resources? • In light of the recent experiences with thermal outages during extreme weather,10 how can accreditation appropriately reflect current thermal resource reliability and how can accre.

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