Update: American Municipal Power (AMP) has petitioned FERC for permission to file a limited response to the comments filed by the Independent Market Monitor for PJM (IMM). In its comments, IMM argued that the FERC should rescind the waivers on affiliate power sales restrictions previously granted to AEP, FirstEnergy, and their unregulated generating affiliates. MM’s comments also included, as attachments, the testimony it filed in the AEP PPA Expansion Case and the FirstEnergy ESP IV Case. Part of that testimony includes a discussion about potential reforms that could be made to PJM’s minimum offer price rule (MOPR). AMP asserts that PJM’s MOPR is beyond the scope of the complaints and not relevant to FERC’s consideration of whether the waivers should be rescinded.