Commissioner James Danly Statement
November 18, 2021
Docket No. ER17-1609-003, ER19-1215-002
I concur with the result and holding of this order.[1] I write separately to highlight that the Independent Market Monitor’s concerns in this case would properly be rejected even if the Commission had not recently ordered PJM Interconnection, L.L.C. (PJM) to adopt a unit-specific review of all offers in the capacity market.[2] I opposed unit-specific review of all offers because doing so will likely result in over-mitigation.[3] In this order, the Commission notes its adoption of unit-specific review as a recent mitigation change in PJM.[4] Unit-specific review is not required to adequately mitigate market power concerns, and today’s order in no way indicates otherwise.
For these reasons, I respectfully concur.