Commissioner James Danly Statement
October 21, 2021
Docket No. ER10-3230-011
I concur with the result and holding of this order. 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 to adopt a unit-specific review of all offers in the capacity market.[1] I opposed unit-specific review of all offers because doing so will likely result in over-mitigation.[2] In this order, the Commission notes its adoption of unit-specific review as a recent mitigation change in PJM.[3] 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.