Pre-filed Statement of Marjorie Rosenbluth Philips, Senior Vice President of Wholesale Market Policy for LS Power Development, LLC, for the PJM Governance and Stakeholder Reforms Technical Conference under AD26-7.
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Summary: LS Power Development, LLC supports the Commission's efforts to reform PJM governance but argues that current resource adequacy issues are primarily driven by market rules and physical constraints rather than governance alone. The company recommends specific enhancements to PJM's governance, such as requiring the Board to explain its reasoning, relaxing ex parte rules, and expanding state participation through the OPSI.