From FERC:

12. R Street Institute (R Street), Exelon Corporation (Exelon), Clean Energy Entities (CEE), 12 Energy Trading Institute (ETI), FirstEnergy Utility Companies (FirstEnergy),13 Duke Energy Corporation (Duke), Nuclear Energy Institute (NEI), Dominion Energy Services, Inc. (Dominion), Calpine Corporation and LS Power Associates, L.P. (together, Calpine and LS Power), Institute for Policy Integrity at New York University School of Law (IPI), Direct Energy Business Marketing, LLC and Direct Energy Business, LLC (collectively, Direct Energy), Vistra Energy Corporation and Dynegy Marketing and Trade, LLC (collectively, Vistra), and Electric Power Supply Association (EPSA) filed supporting comments in both dockets. The American Petroleum Institute (API) filed supporting comments in Docket No. EL19-58-000. The PJM Power Providers Group (P3) late-filed supporting comments in both dockets.

167. API, Calpine and LS Power, CEE, Direct Energy, Dominion, Duke, EPSA, ETI, Exelon, FirstEnergy, IPI, NEI, P3, PSEG, R Street, and Vistra generally support PJM’s proposal to implement downward-sloping ORDCs to procure reserves beyond the MRR.335

173. R Street warns that there is a risk that PJM’s ORDCs will not actually reflect operational reality, and therefore requests that the Commission require PJM and the IMM to report on whether out-of-market actions by operators diminish as a result of the market-based procurement of operating reserves.357 R Street further suggests that the Commission require periodic re-evaluation of the appropriateness of the slopes of the ORDCs. 358

240. Direct Energy, IPI, PSEG, and R Street argue that PJM should periodically review its ORDCs to ensure the ORDCs are meeting PJM’s stated goals of achieving improved price formation, increasing transparency, and improving system reliability.