This blog is a follow-up to the FERC Order dated August 17, 2020, in Docket No. ER20-1068, where FERC accepted a request by The Dayton Power and Light (DP&L) for an RTO Adder, yet suspended it for a five month period, subject to refund and the outcome of a paper hearing to explore whether DP&L has shown that its participation in PJM or another RTO is voluntary or if such participation is mandated by Ohio law.   On September 16, in this docket, PJM requested clarification of the FERC August 17, 2020 Order that the Order should not be construed as a holding that “voluntariness” is the sole criterion by which to judge the appropriateness of DP&L’s RTO Adder request.  PJM states that although voluntariness is relevant to the analysis, FERC should clarify that its investigation of this singular issued is not dispositive of the question of the appropriateness of the RTO Adder for DP&L going forward - that FERC should make it clear that it is keeping its options open pending receipt of a more fulsome record and is not substituting a sole criterion analysis in the place of the “case-by-case” RTO Adder eligibility analysis required by Order 679.