Update: The Ohio Energy Group (OEG) filed comments in opposition to a protest made by the Electric Power Supply Association (EPSA) and others (and supported by OMA Energy Group) that urges the Federal Energy Regulatory Commission (FERC) to review the virtual PPA underlying FirstEnergy’s modified Rider RRS proposal. OEG claims that the matter is beyond FERC’s jurisdiction to regulate because the modified Rider RRS proposal is not backed by a PPA; however, EPSA, OMA Energy Group, and others argue that this argument elevates form over substance because the virtual PPA underlying the modified Rider RRS proposal could damage the wholesale market in much the same way as FirstEnergy’s originally-proposed affiliate PPA.