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Comments to FERC on Clean Resources’ Participation in NYISO’s Capacity Market

Complainants in an ongoing proceeding ask that the Federal Energy Regulatory Commission (FERC) make changes to the New York Independent System Operator (NYISO)'s capacity market that would impose offer floors on all capacity market bids by state-supported renewables. We submitted comments and an exhibit showing why the complaint's arguments and evidence fall short of the legal standards required for FERC to make the findings and grant the relief requested. We also responded to an answer filed by the complainants.