Update: OMA Energy Group filed comments before the Federal Energy Regulatory Commission (FERC) in support of a protest made by the Electric Power Supply Association (EPSA) and others that challenges FirstEnergy’s new proposal to replace the affiliate PPA with a virtual PPA. EPSA’s protest and OMA Energy Group’s supporting comments urged the FERC to review the virtual PPA to ensure that customers are not exposed to the same types of affiliate-abuse harms that were embodied in the affiliate PPA. FERC’s decision from April halted the affiliate PPA by requiring that it be submitted for review and approval before any sales could be transacted under it. Unlike the affiliate PPA, the virtual PPA is not backed by a contract between FirstEnergy and its affiliate, FirstEnergy Solutions. By structuring the virtual PPA this way, FirstEnergy appears to be seeking a way to avoid FERC review. Nonetheless, the virtual PPA closely follows the contours of the affiliate PPA by relying on much of the same data that FirstEnergy presented to the PUCO in support of its request to recover the costs of the affiliate PPA through Rider RRS.