PJM Industrial Customer Coalition
For example, such billing line items should include itemized exemptions/credits for Bring Your Own New Capacity (“BYONC”) status (including co-located load additions). PDF p. 8
ER26-3380: the filed comments
These passages match a topic and a request or argument in the same sentence. A filing can quote another party. Read its page before attributing a position.
Connecting load and generation
PJM Interconnection, L.L.C.
Second, other intervenors suggest that capacity provided through Surplus Interconnection Service (“SIS”) should be eligible to qualify as RBP Resources. PDF p. 41
Cost allocation
American Municipal Power
2 allocated to Electric Distributor zone/areas that are not experiencing load growth attributable to data centers or other large loads, as such an allocation would be inconsistent with the cost causation principle. PDF p. 2
Illinois Commerce Commission
The ICC recommends that the Commission require sufficient mitigation efforts to protect against cost shifts to or any negative impacts on existing ratepayers, impose no new obligations upon the states, and require PJM to provide the clarifications, transparency, and access to data as discussed herein. PDF p. 2
PJM Industrial Customer Coalition
” PJM also states that “PJM is not proposing a backup methodology for how RBP Charges should be allocated to non-jurisdictional, retail customers served by each of the LSEs in any Electric Distributor’s zone/area. PDF p. 4
Data Center Coalition
2 facilitate responsible load growth, and support the development of new generation without imposing undue costs on existing ratepayers. PDF p. 2
PJM Interconnection, L.L.C.
”104 To meet their capacity needs, these ratepayers may enter into bilateral arrangements, which are inherently more flexible, including with respect to the length of the term required to support Qualifying RBP Offset UCAP MW, and which can be used to decrement the procurement target of the zone/area in which that ratepayer is located. PDF p. 36
COMMITTEE ON ENERGY AND COMMERCE
4 While I have concerns that the specifics of PJM’s proposals are insufficient to grant ratepayers the protections they need, broadly these core concepts are deeply necessary, and FERC should work to implement and improve them as quickly as possible. PDF p. 2
Constellation Energy Generation
In addition, the paper hearing should distinguish ordinary RBP Charges attributable to load that departs PJM from incremental costs created by the Transmission Owner’s withdrawal, including pseudo-tie, accelerated-payment, contract-preservation, and stranded-obligation costs. PDF p. 18
FirstEnergy Service Company
To do otherwise would be to impose manifestly unjust and unreasonable costs on ratepayers. PDF p. 12
Joint Consumer Advocates (DE, DC, IL CUB, IL AG, MD, NJ)
The amount of RBP charges for PJM’s proposed procurement total of 6,831 MWs at a rate of $555/MW-day x 365 days x 15 years would be $20,756,847,375. PDF p. 24
Northern Virginia Electric Cooperative
Should the Commission’s clarification restrict the scope of the paper hearing, then NOVEC seeks rehearing of any limitations imposed on the scope of the paper hearing insofar as cost allocation associated with RBP is concerned. PDF p. 1
Ohio Consumers' Counsel
The combination of a more stringent shortage penalty with a structure that allocated such costs either to the developers or the load causing the costs to be incurred would be fair, follow cost causation principles and protect all other consumers in Ohio and elsewhere in PJM. PDF p. 21
U.S. Department of Energy
4 PJM should implement the cost allocation and other reforms identified by the Commission to ensure that the costs of serving new data centers or other large electric energy loads are not unfairly shifted to PJM’s existing ratepayers. PDF p. 2
Credit and exit
PJM Interconnection, L.L.C.
This would allow LSEs to make long-term plans for such RBP Charges, including arrangements to post collateral, and avoid scenarios where new load bilaterally contracts for new capacity but subsequently gets allocated RBP Charges. PDF p. 61
Constellation Energy Generation
10 In an abundance of caution, Constellation also requests clarification that the paper-hearing procedures leave fully open the collateral, Transmission Owner exit-charge, and cost-allocation issues identified below. PDF p. 3
Filing procedure
American Municipal Power
ER26-3380-000 EL26-108-000 REQUEST FOR CLARIFICATION AND ALTERNATIVE REQUEST FOR REHEARING OF AMERICAN MUNICIPAL POWER, INC. PDF p. 1
Constellation Energy Generation
23 For the same reasons discussed above regarding RBP Seller eligibility, the Commission should grant rehearing and make such resources eligible to provide Qualifying RBP Offset UCAP MW. PDF p. 10
FirstEnergy Service Company
Each of these determinations is arbitrary and capricious, unsupported by substantial evidence, and contrary to law, and thus rehearing should be granted. PDF p. 3
Indicated PJM Transmission Owners
The FirstEnergy Transmission Companies are separately filing a rehearing request raising other issues. PDF p. 1
Joint Consumer Advocates (DE, DC, IL CUB, IL AG, MD, NJ)
16 For the above reasons, and as explained in greater detail in Part II of this filing, below, Joint Consumer Advocates respectfully request that the Commission (1) grant rehearing of the RBP Order; (2) find unjust and unreasonable the four elements of the RBP framework identified herein by Joint Consumer Advocates; and (3) direct PJM to incorporate changes to those elements in any subsequent FPA section 20517 filing PJM proposes. PDF p. 5
Northern Virginia Electric Cooperative
ER26-3380-000 EL26-108-000 ) REQUEST FOR REHEARING AND CLARIFICATION OR ALTERNATIVE REQUEST FOR REHEARING OF NORTHERN VIRGINIA ELECTRIC COOPERATIVE, INC. PDF p. 1
Ohio Consumers' Counsel
ER26-3380-000 and ) ER26-3380-001 REQUEST FOR REHEARING TO PROTECT CONSUMERS FROM EXCESSIVE TRANSMISSION RATES BY OFFICE OF THE OHIO CONSUMERS’ COUNSEL I. PDF p. 3
Registry access
Illinois Commerce Commission
The registry should collect all necessary data on load size, location, ramp rate, and other relevant features in an easy-to-use format that states can make use when assigning costs. PDF p. 7
PJM Interconnection, L.L.C.
21, 2026) (“NYU Institute Comments”) • Protest, Motion to Reject, and Alternative Request for the Imposition of Conditions of Joint Consumer Advocates (Aug. PDF p. 111
COMMITTEE ON ENERGY AND COMMERCE
9 Making PJM’s registry as public as possible, while still mandating participation from data centers and other large consumers of electricity, would go a long way in providing the transparency around data centers that we desperately need. PDF p. 3
Joint Consumer Advocates (DE, DC, IL CUB, IL AG, MD, NJ)
, Protest, Motion to Reject, and Alternative Request for the Imposition of Conditions of Joint Consumer Advocates at 5-7 (Aug. PDF p. 1
Reliability and curtailment
American Municipal Power
Clarification is also appropriate to resolve the incongruity between, on the one hand, the Commission’s aim of ensuring that RBP costs are allocated to zone/areas with large load growth driving resource adequacy deficiencies, and, on the other hand, the likelihood that its proposed cost allocation method would allocate RBP costs to zone/areas without new large loads. PDF p. 7
Illinois Commerce Commission
The ICC generally supports PJM’s proposal to implement a one-time, supplemental procurement of new capacity to address the identified resource adequacy shortfall that aligns with the National Energy Dominance Council/PJM Governors’ Principles and the Commission’s recognition of the need for action. PDF p. 1
Organization of PJM States, Inc.
5 OPSI hopes that this targeted intervention will bolster regional resource adequacy by addressing the present-day capacity shortfall, which would not have occurred but for large loads, while complementing the ongoing bilateral matching process. PDF p. 2
Data Center Coalition
Given the urgency of PJM’s resource adequacy challenge, DCC supports moving forward with the RBP as a limited, one-time backstop. PDF p. 2
PJM Interconnection, L.L.C.
18 Dominion Partial Protest and Comments at 3 (“Dominion generally supports the RBP as a one-time procurement to bring the PJM region to a more stable state of resource adequacy and pave the way for holistic market design reforms that will support the infrastructure needed to reliably serve load growth in the region. PDF p. 5
COMMITTEE ON ENERGY AND COMMERCE
I support one key idea across both PJM’s Reliability Backstop Procurement (RBP) and Interim Resource Adequacy Service (IRAS) – ensuring that data centers are responsible for bringing new generation capacity to the grid. PDF p. 2
Constellation Energy Generation
Those distinctions concern the very factors the Commission has considered when balancing the reliability rationale for out-of-market support against its effect on market price formation and the potential impacts on resource adequacy in the long-term: purpose, magnitude, duration, and certainty of need. PDF p. 12
FirstEnergy Service Company
39 Nor does the September 29 Order explain how ELCC accreditation—a measure of a resource's contribution to resource adequacy— accounts for the inertia, dynamic reactive support, frequency response, and voltage control that NERC identified as needed for reliability. PDF p. 11
Joint Consumer Advocates (DE, DC, IL CUB, IL AG, MD, NJ)
Allowing capacity and load to be added without accounting for locational resource adequacy would also result in higher energy market prices and increased transmission costs. PDF p. 30