ER27-454-000 · 2026-11-09 · PJM

Attachment D - Danielle Croop Affidavit

Attachment D 
 
 
Affidavit of Danielle Croop

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C. 
 
) 
 
Docket No. ER27-____-000 
 
AFFIDAVIT OF DANIELLE CROOP 
ON BEHALF OF PJM INTERCONNECTION, L.L.C. 
1. 
My name is Danielle Croop, Senior Manager in the Market Design group for PJM 
Interconnection, L.L.C. (“PJM”).  My business address is 2750 Monroe Blvd., 
Audubon, Pennsylvania, 19403.  I am submitting this affidavit on behalf of PJM to 
support the proposed reforms to PJM’s Open Access Transmission Tariff (“Tariff”) 
and PJM’s Reliability Assurance Agreement Among Load Serving Entities 
(“RAA”) to implement the Reliability Backstop Procurement (“RBP”) framework 
by providing support for PJM’s proposal to: 
a. Update the Initial RBP Target; and 
b. Update Cost Allocation Methodology to Electric Distributor zone/areas. 
Qualifications 
2. 
In my role as Senior Manager for PJM, I lead a team of Market Design Specialists 
and Economists on the development of PJM’s market design across all of PJM’s 
markets including the energy, ancillary services, and capacity markets.  My 
responsibilities include leading the development of wholesale market rules and 
participation frameworks that advance market efficiency and grid reliability.  I 
joined PJM in 2014 as an Engineer, and since then, I have held numerous other 
roles, including as a Senior Engineer, Senior Lead Engineer, Senior Lead Market 
Design Specialist, and Market Design Manager, providing technical support and 
leading cross-divisional teams on market design, market evolution initiatives 
related to energy storage and distributed energy technologies participating in the 
PJM markets, and balancing operations at PJM, including involvement in a number 
of North American Electric Reliability Corporation subcommittees and initiatives.   
3. 
Prior to joining PJM, I was employed by the SI Organization, Inc. as a System 
Engineer supporting large system integrations.  I received a Bachelor of 
Engineering Degree and a Master of Engineering (Electrical Engineering) from 
Drexel University in Philadelphia, Pennsylvania, and have obtained a Certificate in 
Engineering Management. 
Initial RBP Target  
4. 
PJM proposes to update the Initial RBP Target using the lesser of the projected 
shortfall established from the latest load forecast and planning parameters for the 
2028/2029 Delivery Year that will be available at the time the RBP is conducted, 
and the aggregate quantity of Large Load growth reported to PJM, rather than

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relying solely on the shortfall quantity established through the Base Residual 
Auction for the 2028/2029 Delivery Year, held in July 2026.    
5. 
First, utilizing the latest information allows PJM to identify the most accurate 
estimate of the reliability need for the 2028/2029 Delivery Year based on the latest 
load forecast of demand that will need to be served and the expected supply.  
Specifically, because this updated information will be available prior to conducting 
the RBP, it is appropriate to use the most up-to-date information to produce an 
Initial RBP Target that represents the latest expected reliability shortfall and avoid 
either under-procurement or over-procurement of resources. 
6. 
Second, applying the “lesser of” calculation using the aggregate quantity of Large 
Load growth reported to PJM for the RBP will mitigate the potential over-allocation 
of RBP Charges to a zone/area relative to the forecasted Large Load growth.  PJM 
believes this scenario is unlikely based on currently available information.  
Specifically, PJM’s 2026 Load Forecast indicates approximately 9,000 MW of large 
load growth, while the projected Regional Transmission Organization (“RTO”) 
shortfall for the 2028/2029 Base Residual Auction is approximately 6,800 MW.  
Although these values may change as updated forecasts become available in 2027, 
PJM expects the relationship between Large Load growth and the projected 
shortfall to remain generally consistent.  Nevertheless, including the “lesser of” 
calculation in the Initial Target provides an important safeguard by accounting for 
the possibility that previously reported Large Load agreements may be canceled 
between the collection of data for the 2027 Load Forecast and the establishment of 
the RBP.  By ensuring that RBP cost allocations do not exceed 100% of the Large 
Load growth reported for the applicable zone/area, the proposed procurement target 
and cost allocation framework better align cost responsibility with the principles of 
cost causation and beneficiary pays. 
7. 
Further, since PJM plans to run the RBP in March 2027, by that time PJM will have 
conducted the 2029/2030 Base Residual Auction, scheduled for December 2026.  
That auction may produce a shortfall, and of different quantity than for the 
2028/2029 Delivery Year.  Nevertheless, PJM proposes to maintain the 2028/2029 
Delivery Year shortfall as the basis for the RBP.  This approach is consistent with 
the underlying intent of the RBP to address the nearer-term reliability need while 
allowing market fundamentals to address the longer-term resource adequacy.  
8. 
Additionally, adopting a different procurement target timeframe would necessitate 
broader revisions to the overall design, including resource eligibility requirements 
and commitment terms.  Because market participants have already planned and 
made business decisions based on PJM conducting the RBP for the 2028/2029 
Delivery Year, maintaining the existing design is prudent.  Doing so promotes 
certainty, preserves stakeholder expectations, and avoids unnecessary disruption to 
the market. 
9. 
The RBP is intended to serve as a bridge mechanism to address immediate 
reliability concerns while PJM and stakeholders continue to pursue longer-term

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market design reforms aimed at improving investment and retention signals to 
support resource adequacy.  In support of those efforts, PJM has initiated its 
Powering Reliability Through Market Design initiative with stakeholders and 
continues to work with the Charles River Associates to facilitate bilateral matching 
efforts. 
10. 
The shortfall MW calculation that will set the Initial RBP Target will be calculated 
using the updated information from the 2027 Load Forecast and associated updated 
planning parameters and submitted Large Load MW values from the Electric 
Distributors.  More specifically, PJM will calculate the Initial RBP Target MW as:  
The lesser of: 
(1) the PJM Region Reliability Requirement for the 2028/2029 Delivery Year 
minus the UCAP-equivalent of the ICAP quantity of Capacity Resources that 
cleared in the 2028/2029 Base Residual Auction 
Where the PJM Region Reliability Requirement for the 2028/2029 Delivery 
Year will be calculated as the RTO Region Peak Load Forecast for the 
2028/2029 Delivery Year from the 2027 Load Forecast times the 2028/2029 
Forecast Pool Requirement from the updated planning parameters published 
in 2027 prior to the commencement of the RBP, less the sum of all updated 
Unforced Capacity Obligations of FRR Entities in the PJM Region.  
And where the UCAP-equivalent of the ICAP quantity of Capacity 
Resources that cleared in the 2028/2029 Base Residual Auction, where the 
UCAP-equivalent values will be determined by the Capacity Resources’ 
updated capacity accreditation factors for the 2028/2029 Delivery Year that 
will be available in the updated planning parameters available just prior to 
the commencement of the RBP. 
And  
(2) the UCAP equivalent of the aggregate region-wide Large Load MW quantity 
reported by the Electric Distributor 
Where the UCAP equivalent of the aggregate region-wide Large Load MW 
is the aggregate region-wide Large Load MW times the most recent 
2028/2029 Forecast Pool Requirement. 
11. 
The RBP will function as a safety net to address the shortfall MW for the 2028/2029 
Delivery Year that has not been addressed by new Large Load bringing their own 
new capacity through bilateral agreements or otherwise.  The RBP is a stop-gap, 
one-time measure aimed specifically at addressing the resource adequacy shortfall 
in the PJM Region, an effort designed to work in part with the load that has 
voluntarily brought supply to the PJM Region—independently or with support of 
ongoing PJM bilateral matching efforts—and a return to market fundamentals to 
support the expected load growth over the next decade.

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RBP Cost Allocation Methodology 
12. 
The cost allocation structure begins with the Initial RBP Target based on the Large 
Load growth between the 2026 summer peak load and the forecasted Large Load 
MW in each Electric Distributor’s zone/area for the 2028/2029 Delivery Year.  The 
Initial RBP Target is then adjusted by the quantity of Qualifying RBP Offset UCAP 
MW and Peak Shaving Adjustment opt-out to reach the Final RBP Target.  Each 
Electric Distributor’s zones/areas with resulting forecasted Large Load growth 
between 2026 and the 2028/2029 Deliver Year will be allocated a pro rata share of 
the Final RBP Target.1  The MW quantity assigned to each Electric Distributor’s 
zone/area will be further allocated to Load Serving Entities (“LSE”) based on the 
RBP Obligation (“RBO”), which permits states to determine the appropriate cost 
allocation to specific LSEs.  Should the Relevant Electric Retail Regulatory 
Authority(s), through the relevant Electric Distributors, decline to provide an RBO 
MW, PJM has proposed to apply a backup default cost allocation where costs would 
be allocated to all of the LSEs in the zone/area based on their percent share of the 
zone/area’s Daily Unforced Capacity Obligation.  
Step 1: 
Collecting the Forecasted Large Load Growth Between 2026 
Through the 2028/2029 Delivery Year Subject to RBP Cost 
Allocation  
13. 
Seven days prior to the commencement of the RBP, PJM will receive all Large 
Load growth in the Electric Distributor zone/area from the 2026/2027 Delivery 
Year through the 2028/2029 Delivery Year.  The Large Load growth will be 
submitted based on firm commitments, as supported by electric service obligation, 
construction commitment, or equivalent agreements, and measured based on 
summer peak values.  These submissions are required to align with the Large Loads 
submitted to PJM for the 2027 load forecast.  Any discrepancies between the 
Electric Distributors’ submissions for RBP and data submitted to PJM for the 2027 
load forecast must be accompanied by written documentation of the change from 
the Electric Distributor.  
14. 
The aggregate Large Loads growth will be submitted within a zone/area, along with 
identification of the underlying Large Loads.  This will result in PJM having the 
aggregate value to determine the total Large Load MW for the zone/area and the 
summation of all zone/areas to determine the total Large Load MW for the RTO 
Region.  The underlying Large Loads will be used to facilitate the Qualifying RBP 
Offset UCAP MW process.  
Step 2: 
Allocating to Electric Distributor Zone/Area 
15. 
To allocate costs, i.e., RBP Charges, PJM is proposing to determine cost 
responsibility by the Electric Distributor zone/area and their pro rata share of Large 
Load MW subject to RBP in comparison to the total Large Load MW subject to 
 
1 This cost allocation structure in detailed in the example below starting in paragraph 17.

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RBP across the RTO.  The final pro rata share determination will be fixed for the 
term of the RBP and be applied to the committed RBP UCAP MW and associated 
RBP Charges throughout the term of the RBP.  
16. 
An illustrative example of Step 1 and Step 2 is detailed in the following section.   
Example of Allocation to Electric Distributor Zone/Area 
17. 
For this example, the Initial RBP Target MW will be assumed to be 4,000 MW.  
This value is purely illustrative for this example and not indicative of the Initial 
RBP Target for the RBP.  
18. 
The initial pro rata allocation to each Electric Distributor zone/area will be based 
on the submitted data from the Electric Distributors representing the forecasted 
Large Load growth between the 2026/2027 Delivery Year and 2028/2029 Delivery 
Year.  The initial share is calculated as: [Zone/Areas Large Load Growth MW/ 
RTO Large Load Growth MW], which can be represented as the initial RBP UCAP 
MW allocation based on that pro rata share of the Initial RBP Target.  
 
19. 
Second, as Qualifying RBP Offset UCAP MW are submitted, both the Final RBP 
Target and the pro rata allocation to each Electric Distributor zone/area will be 
updated.  In this example, I will assume the following Qualifying RBP Offset 
UCAP MW were submitted and will decrement the Initial RBP Target: 
 
Note: The Qualifying RBP Offset UCAP MW is represented by Load*FPR. FPR is represented as 0.9401 int this 
example.  
20. 
In my illustrative example, for purposes of simplicity, I assume there are no 
additional decrements to the Initial RBP Target for opt outs.  Thus, the Final RBP 
Target would be calculated as Initial RBP Target – Qualifying RBP Offset UCAP 
Zone/Area 
Submitted Large 
Load Growth (MW)
Initial Share of 
RBP (%) 
Share of Initial Target 
MW (4000MW)
Zone/Area 1
1000
24%
975.6
Zone/Area 2
500
12%
487.8
Zone/Area 3
100
2%
97.6
Zone/Area 4
1000
24%
975.6
Zone/Area 5
1500
37%
1463.4
Total
4100
100%
4000
Zone/Area 
Load (MW)
Qualifying RBP 
Offset UCAP 
MW
Zone/Area 1
500
470
Zone/Area 2
100
94

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MW.  In this example, this would be: 4,000 MW – [470 MW + 94 MW ] = 3,436 
MW.   
21. 
Subsequently, the Large Load that submitted the Qualifying RBP UCAP MW will 
be removed from the Large Load growth for cost allocation purposes.  The updated 
pro rata allocation and RBP UCAP share of the Final RBP Target is demonstrated 
in the table below.  In Zone/Area 1 the Large Load Growth (MW) will be reduced 
from 1000 MW to 500 MW to account for the 500 MW of load with demonstrated 
Qualifying RBP Offset UCAP MW.  Similarly, Zone/Area 2 will be updated to 400 
MW to account for the Qualifying RBP Offset UCAP MW.   
22. 
Based on adjustments to each Electric Distributor zone/area’s Large Load Growth 
MW, the final pro rata shares are recalculated. 
 
The Bounds of Qualifying Offsets 
23. 
Large Load can be removed from the Large Load MW used to determine RBP cost 
allocation by bringing Qualifying RBP Offset UCAP MW.  A Large Load can bring 
up to their capacity obligation (in UCAP), determined as peak MW times the 
Forecast Pool Requirement.  MW from supply resources in excess of that value will 
not be considered to decrement the Large Load growth in a zone/area or decrement 
the Initial RBP Target value.   
24. 
A zone/area cannot reduce its zone/area share of the Initial RBP Target beyond the 
capacity obligation of the total Large Load MW in that zone/area (floored at zero).  
Further, a zone/area must provide Qualifying RBP Offset UCAP MW equal to 
capacity obligation of the total Large Load MW in that zone/area to be fully 
removed from the RBP cost allocation. 
25. 
This concludes my affidavit. 
 
Zone/Area 
Submitted Large 
Load Growth 
(MW)
Final Share of 
RBP (%) 
Share of Final Target 
MW (3436 MW)
Zone/Area 1
500
14%
490.9
Zone/Area 2
400
11%
392.7
Zone/Area 3
100
3%
98.2
Zone/Area 4
1000
29%
981.7
Zone/Area 5
1500
43%
1472.6
Total
3500
100%
3436

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C. 
 
) 
 
Docket No. ER27-____-000 
 
VERIFICATION 
I, Danielle Croop, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that 
I am the Danielle Croop referred to in the foregoing document entitled “Affidavit of 
Danielle Croop, Senior Manager in the Market Design group for PJM Interconnection, 
L.L.C.,” that I have read the same and am familiar with the contents thereof, and that the 
facts set forth therein are true and correct to the best of my knowledge, information, and 
belief. 
 
/s/ Danielle Croop  
 
Danielle Croop  
Sr. Manager, Market Design 
PJM Interconnection, L.L.C.