Electric Power Supply Association

Electric Power Supply Association
Name	Electric Power Supply Association
Abbreviation	EPSA
Formation	2002
Type	Trade association
Headquarters	Washington, D.C.
Region served	United States
Membership	Independent power producers, merchant generators
Leader title	President and CEO
Leader name	Thomas J. Kuhn

Electric Power Supply Association is a U.S.-based trade association representing competitive power producers and merchant generators. The association has engaged with regulatory agencies, Congress, and industry stakeholders on matters involving wholesale markets, transmission policy, and environmental compliance. EPSA has participated in litigation, rulemaking, and research initiatives alongside utilities, independent power producers, and market operators.

History

Founded in 2002, the association emerged amid restructuring debates following regulatory developments shaped by the Federal Power Act, the Energy Policy Act of 1992, and orders from the Federal Energy Regulatory Commission. Early members included companies active during reforms associated with the North American Electric Reliability Corporation formation and market evolution precipitated by incidents like the Northeast blackout of 2003. Over the 2000s and 2010s EPSA engaged with entities involved in debates around Regional Transmission Organizations, the expansion of Independent System Operator footprints, and the integration challenges signaled by Hurricane Katrina and other extreme events. Its activities paralleled industry trends tied to technologies promoted by manufacturers such as General Electric and Siemens and financiers including Goldman Sachs and BlackRock that invested in merchant generation portfolios.

Organization and Membership

EPSA's governance has included representatives from major independent generators, merchant owners, and corporate legal teams. Member companies have included firms formerly or currently associated with Dynegy, Calpine Corporation, NRG Energy, Exelon, and Vistra Energy, as well as smaller participants linked to AES Corporation and NextEra Energy spin-offs. The association has worked closely with trade counterparts such as the American Petroleum Institute, the American Wind Energy Association, the Solar Energy Industries Association, and the National Rural Electric Cooperative Association when interests aligned on market design and transmission. EPSA maintains relationships with market operators like PJM Interconnection, Midcontinent Independent System Operator, California Independent System Operator, and New York Independent System Operator, and with policy entities including the U.S. Department of Energy and state public utility commissions such as the California Public Utilities Commission.

Policy and Advocacy

EPSA has advocated for policies favoring competitive wholesale market structures under frameworks developed by the Federal Energy Regulatory Commission and statutes like the Public Utility Regulatory Policies Act of 1978. It has filed comments and petitions concerning capacity markets operated by ISO New England, PJM, and NYISO, and submitted positions on transmission cost allocation issues that intersect with projects such as MISO regional planning and approvals involving TransWest Express. The association has engaged in debates around emissions regulations implemented under the Clean Air Act and has participated in stakeholder processes related to the Clean Power Plan and subsequent rulemakings. EPSA has also weighed in on tax and finance matters influenced by rulings of the United States Court of Appeals for the District of Columbia Circuit and legislation debated in the United States Congress.

Research and Publications

EPSA produced reports and technical analyses addressing market performance, reliability metrics, and generator retirement impacts on reserve margins used by PJM Interconnection and MISO. Publications examined interactions among fuel supply chains including references to the Alaska Natural Gas Pipeline debates, grid resilience considerations raised after the 2012 Derecho, and the role of thermal, nuclear, hydroelectric, wind, and solar resources sited near corridors used by projects like TransWest Express and Rock Island Clean Line. EPSA disseminated white papers on capacity market design influenced by academic work from scholars affiliated with Massachusetts Institute of Technology and Stanford University, and collaborated with consulting firms such as The Brattle Group and NERA Economic Consulting.

Legal and Regulatory Activities

The association has been an active party in litigation before the Federal Energy Regulatory Commission and federal courts, filing appeals and interventions in cases adjudicated by the United States Court of Appeals for the District of Columbia Circuit and the United States Supreme Court on matters of market rules, jurisdictional boundaries under the Federal Power Act, and preemption issues implicating state measures such as those arising from the Illinois Commerce Commission or the Massachusetts Department of Public Utilities. EPSA submitted amici curiae briefs in high-profile cases concerning the Clean Air Act implementation and state procurement programs that affected wholesale market participation. It has also participated in rulemakings related to interconnection standards administered by entities like North American Electric Reliability Corporation and regional planning overseen by Federal Energy Regulatory Commission staff.

Criticism and Controversies

EPSA has faced criticism from environmental groups such as Sierra Club and Natural Resources Defense Council for positions opposing certain state-level clean energy procurement efforts and for defending market structures perceived as favoring fossil-fuel generation. Consumer advocacy organizations including Public Citizen and Consumer Federation of America criticized some EPSA filings as prioritizing merchant revenue over ratepayer protections. Labor organizations like the International Brotherhood of Electrical Workers have sometimes disputed EPSA stances on plant retirements and workforce transitions. Legal commentators pointed to EPSA litigation strategies in cases involving capacity markets and state clean energy mandates debated in forums linked to the Supreme Court of the United States and the United States Court of Appeals for the D.C. Circuit.

Category:Trade associations based in the United States Category:Energy industry organizations