Read topic-matched comments in EL25-49
Topics in the text: Connecting load and generation · Reliability and curtailment · Filing procedure
PJM and Constellation · Direct response
PJM sought an extension to align its co-location and large-load work. Constellation wanted full interim network-service terms on the original schedule. FERC kept the August partial filing while granting additional time for other requirements.
Requests and ruling on extension of time (unpaginated)Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Filing procedure
EL25-49-002, et al. - 3 - Co-Located Load and Eligible Customers taking transmission service on behalf of Co-Located Load.2 The Commission directed PJM to file, within 60 days of the date of issuance of the order, a compliance filing to revise its Tariff to set forth specific terms and conditions…Read this passage Filed comments: Connecting load and generation
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Penalty Charge or Other Remedial Action for New Transmission Services - 218 - 1.Read this passage
printed heading · Topic match: Reliability and curtailment
G.Read this passage Filed comments: Reliability and curtailment
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I.Read this passage
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BackgroundRead this passage
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EL25-49-002, et al. - 11 - conditions of service that apply to Co-Location Arrangements.17 In addition, the Commission preliminarily found that this lack of applicable Tariff provisions raises the potential for undue discrimination or preferential treatment.18 As to specific concerns raised…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 12 - of Co-Located Load.22 The Commission explained that the absence of such provisions leaves entities unable to determine what steps they must take to effectuate Co-Location Arrangements and creates uncertainty that has resulted in disparate treatment in PJM because…Read this passage Filed comments: Connecting load and generation
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II.Read this passage
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PJM’s Compliance Filing Notice of PJM’s compliance filing in Docket No.Read this passage
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EL25-49-002, et al. - 16 - Consumer Advocate filed a motion to intervene out of time in this proceeding.Read this passage
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Pursuant to section 313(a) of the FPA,44 an aggrieved party must file an application for rehearing within 30 days after the issuance of the Commission’s order; in this case, that deadline is 40 Pennsylvania Office of Consumer Advocate is not a party to this proceeding with respect to rehearing or…Read this passage
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Requests for Rehearing and/or Clarification As discussed further below, we sustain our finding that the Tariff is unjust and unreasonable because it does not contain provisions addressing with sufficient clarity or consistency the rates, terms, and conditions of service that apply to…Read this passage Filed comments: Connecting load and generation
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A.Read this passage
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1.Read this passage
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In particular, the Commission affirmed that “states have authority over their generation resource mix, including through their siting authority” and further explained that “[t]his authority means that which generating facilities are sited and allowed to serve Co-Located Load is also a question of…Read this passage Filed comments: Connecting load and generation
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Request for Clarification and/or Rehearing Constellation requests that the Commission clarify that the Commission has jurisdiction over the wholesale sale of energy by a generator to a retail supplier even if the retail supplier then resells that energy to a Co-Located Load.Read this passage Filed comments: Connecting load and generation
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Determination In response to Constellation’s request for clarification or rehearing, we reiterate that, where a generator sells electricity at wholesale in interstate commerce to another entity that then resells that electricity at retail to a Co-Located Load, the generator’s sale for resale is…Read this passage Filed comments: Connecting load and generation
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Retail Allocation of Commission-Jurisdictional RatesRead this passage
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December Order In the December Order, the Commission held that “states have exclusive jurisdiction over how the costs assigned to Eligible Customers on behalf of Co-Located Load taking Commission-jurisdictional transmission services,” including the new transmission services, “are allocated to…Read this passage
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Request for Clarification and/or Rehearing Constellation requests that the Commission clarify that states do not have unlimited authority over how to allocate the costs of all Commission-jurisdictional rates and that they cannot use their authority over retail allocation to indirectly regulate the…Read this passage Filed comments: Connecting load and generation
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We nonetheless reiterate that: (1) Eligible Customers taking transmission service on behalf of Co-Located Load must have the option to take one of three transmission services, i.e., NITS or Interim NITS, FCD transmission service, or NFCD transmission service;66 and (2) while it remains just and…Read this passage Filed comments: Connecting load and generation
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3.Read this passage
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In particular, the Commission found that PJM’s existing retail BTMG netting rules do not limit the amount of qualifying load that a Network Customer may net by using BTMG and do not provide any protections against potential transmission and resource adequacy planning problems or against the costs…Read this passage Filed comments: Reliability and curtailment
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Request for Clarification and/or Rehearing Industrials argue that the Commission failed to explain and justify its assertion of jurisdiction over “retail BTMG that merely offsets retail load.”71 Industrials contend that “retail BTMG [is not within] the Commission’s jurisdiction over the…Read this passage
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The BTMG netting rules instead allow PJM to calculate the charges for 71 Industrials Request for Clarification or Rehearing at 39. 72 Id. at 40 (citing PJM, Intra-PJM Tariffs, OATT, § I.1 (Definitions – A-B) (22.0.0)). 73 Id. 74 Id. at 40-41 (citing Nat’l Ass’n of Regul.Read this passage
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4.Read this passage
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December Order In the December Order, the Commission required that PJM modify its Tariff to require that an Eligible Customer taking transmission service on behalf of a Co-Located Load take one of three transmission services: (1) NITS or Interim NITS; (2) FCD transmission service; or (3) NFCD…Read this passage
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Cir. 2012) (“[T]he regulation of transmission charges is undoubtedly within FERC’s jurisdiction . . . .”). 78 December Order, 193 FERC ¶ 61,217 at P 193. 79 Exelon and FirstEnergy Request for Rehearing at 53. 80 Id.Read this passage
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EPSA, 577 U.S. 260, 275 (2016)). 83 December Order, 193 FERC ¶ 61,217 at P 193. 84 FPA section 313(a) requires that an “application for rehearing shall set forth specifically” its grounds. 16 U.S.C. § 825l(a) (emphasis added).Read this passage Filed comments: Connecting load and generation
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B.Read this passage
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Overview, Transmission Service, Regulation and Black StartRead this passage
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December Order As relevant here, the Commission found in the December Order that the Tariff is unjust and unreasonable because it does not contain provisions addressing with sufficient clarity or consistency the rates, terms, and conditions of service that apply to Interconnection Customers serving…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 27 - situation described in the Constellation Complaint giving rise to the purposed uncertainty revealed that “any delay resulted from a decision made by Constellation in its attempt to bypass retail service requirements and to obtain service in violation of Illinois law.”91…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 32 - In fact, based on our review of the Tariff, the Tariff indeed does not contain provisions specifying the rules governing Co-Location Arrangements.115 For instance, the Tariff lacks provisions specifying: the terms and conditions for Interconnection Customers seeking to…Read this passage Filed comments: Connecting load and generation
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2.Read this passage
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a.Read this passage
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December Order The Commission found that PJM’s retail BTMG netting rules are no longer just and reasonable and clarified that this finding applies to all Network Load.162Read this passage
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Request for Clarification and/or Rehearing Citing the Administrative Procedure Act (APA) and Commission Rule 209, Industrials argue that changes to retail BTMG netting rules are outside the scope of the February Order.163 Industrials assert that the February Order set the scope of the proceeding…Read this passage Filed comments: Connecting load and generation
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Under the APA, an agency setting a matter for hearing must provide parties with adequate notice of the issues that would be considered, and ultimately resolved, at that hearing.165 Under Commission Rule 209(b), “an order to show cause will contain a statement of the matters about which the…Read this passage Filed comments: Connecting load and generation
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Whether PJM’s Retail BTMG Rules Are Unjust and UnreasonableRead this passage
PDF bookmark · Topic match: Reliability and curtailment
The Commission found that PJM’s existing BTMG netting rules may lead to both reliability and resource adequacy risks because PJM, per its Tariff, is obligated to serve transmission customers using BTMG but does not consider such customers in transmission and resource adequacy planning.Read this passage Filed comments: Reliability and curtailment
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Request for Clarification and/or Rehearing Industrials argue that the Commission erred by failing to address prior precedent on cost causation and failing to demonstrate that the existing BTMG netting rules were 181 Id. (quoting PJM March 24, 2025 Response at 13). 182 Id. (citing Docket No.Read this passage
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EL25-49-002, et al. - 49 - and the Commission may not have fully recognized the cost causation implications of the removal of all netting rules.204 We find these concerns unpersuasive for several reasons.Read this passage Filed comments: Reliability and curtailment
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3.Read this passage
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EL25-49-002, et al. - 51 - using BTMG but does not consider such customers in transmission and resource adequacy planning.212Read this passage
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Request for Clarification and/or Rehearing Industrials request clarification that the new transmission services must be made available to Eligible Customers taking transmission service on behalf of load-only customers with BTMG.213 Industrials argue that Eligible Customers taking transmission…Read this passage
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In addition to the finding in the December Order that the Tariff is unjust and unreasonable as to Eligible Customers taking transmission service on behalf of Co-Located Load, we also find that the Tariff is unjust and unreasonable because it does not include transmission services that reflect that…Read this passage Filed comments: Connecting load and generation
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C.Read this passage
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1.Read this passage
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a.Read this passage
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December Order As relevant here, the Commission found that NITS must be taken on a gross basis.218Read this passage
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PIOs argue that, given the unprecedented volume and scale of large load requests, the Commission should evaluate whether existing transmission rate designs remain just and reasonable.Read this passage
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Determination We deny the request for clarification.221 In the December Order, the Commission found that NITS must be taken on a gross basis.222 The Commission did not address cost allocation for Network Upgrades needed to accommodate NITS (or related reporting requirements) and we decline to do so…Read this passage
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New Transmission Services In the December Order, the Commission—having found the Tariff unjust and unreasonable because it lacked relevant provisions with sufficient clarity and transmission services that reflect Eligible Customers taking service on behalf of Co-Located Loads that are willing and…Read this passage Filed comments: Connecting load and generation
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i.Read this passage
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(a) Requests for Clarification and/or Rehearing As to a replacement rate covering Eligible Customers taking transmission service on behalf of load-only customers with BTMG, Industrials request clarification that the new transmission services must be made available to those customers.230 Industrials…Read this passage
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EL25-49-002, et al. - 56 - system; however, they must choose at least one of the required transmission services, and may take a combination of the FCD and NFCD transmission services.Read this passage
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ii.Read this passage
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(a) Requests for Clarification and/or Rehearing Exelon and FirstEnergy argue that the Commission granted an undue preference to Co-Located Loads in requiring new forms for transmission services.235 Exelon and FirstEnergy charge that the Commission failed “to explain why system protection schemes…Read this passage Filed comments: Connecting load and generation
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Rule 713(b) of the Commission’s Rules of Practice and Procedure permits requests for rehearing “of any final decision or other final order in a proceeding.”242 A final decision is one that imposes an obligation, denies a right, or fixes some legal relationship as a consummation of the…Read this passage
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iii.Read this passage
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Industrials Request for Clarification or Rehearing at 13-14. 263 Exelon and FirstEnergy Request for Rehearing at 22-26 (citing Nat’l R.R.Read this passage
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Even if the cited cases were controlling here, we find these new circumstances would warrant the Commission’s decision to charge for FCD and NFCD transmission services based on the contract demand.Read this passage Filed comments: Connecting load and generation
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Alleged Alternatives to FCD and NFCD Transmission ServicesRead this passage
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(a) Request for Rehearing Exelon and FirstEnergy contend that the Commission “fail[ed] to demonstrate that [the new transmission services] are just and reasonable” because there are already existing mechanisms for customers to reduce load or use other generation in order to reduce withdrawals.295…Read this passage
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And demand response presents a different set of benefits and burdens—NFCD transmission service would be curtailed earlier than demand response resources would be called on and can be instructed to curtail without any notification (unlike most demand response resources).296 FCD transmission service,…Read this passage Filed comments: Connecting load and generation
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v.Read this passage
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(a) Request for Rehearing Exelon and FirstEnergy argue that the Commission’s emphasis on protection systems is arbitrary and capricious because it is in tension with the Commission’s open access policies.Read this passage
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The December Order does not mandate that any Co-Located Load or Co-Located Generator enter into a Co-Location Arrangement.Read this passage Filed comments: Connecting load and generation
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vi.Read this passage
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(a) Request for Rehearing Exelon and FirstEnergy allege that the Commission is wrong to suggest that FCD and NFCD transmission services will promote efficiency or change siting.307 Exelon and FirstEnergy argue that planning and siting depend on physics and engineering of the grid, not whether…Read this passage Filed comments: Reliability and curtailment
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EL25-49-002, et al. - 72 - The Commission’s findings related to retail BTMG netting are not inconsistent with the findings related to the new FCD and NFCD transmission services.320 The Commission stated that “the existing BTMG netting rules in the PJM Tariff [are] unjust and unreasonable” because,…Read this passage Filed comments: Connecting load and generation
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vii.Read this passage
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(a) Request for Rehearing Exelon and FirstEnergy argue that the Commission overlooked important reliability concerns in establishing new transmission services, including that loads impact the system even when there is no net power draw on the system.325 Exelon and FirstEnergy assert that gross load…Read this passage Filed comments: Reliability and curtailment
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For example, when PJM or the transmission owners consider factors unrelated to the contract demand of the Co-Located Load, the December Order did not preclude use of the complete dynamic or EMT model of the Co-Located Load, regardless of what level or type of transmission service the Eligible…Read this passage Filed comments: Connecting load and generation
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viii.Read this passage
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(a) Request for Rehearing Exelon and FirstEnergy assert that the Commission’s replacement rate violates the major questions doctrine.334 Exelon and FirstEnergy argue that the Commission has no authority under FPA section 206 to provide unduly preferential treatment to a certain category of…Read this passage Filed comments: Connecting load and generation
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P 200. 334 Exelon and FirstEnergy Request for Rehearing at 52. 335 W.Read this passage
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c.Read this passage
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i.Read this passage
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EPA, 597 U.S. at 721. 344 Exelon and FirstEnergy Request for Rehearing at 52. 345 December Order, 193 FERC ¶ 61,217 at P 221. 346 Id.Read this passage
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For these reasons, Industrials request that the Commission clarify that cogeneration QFs are exempt from the “gross load” approach or that PJM must include a reasonable “Back-up Power” transmission option that retail BTMG customers, including QFs, can purchase.351Read this passage
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The replacement rate applies only to Network Customers’ usage of NITS under the Tariff, and nothing in the replacement rate undoes the requirement in 18 C.F.R. § 292.305(b)(1) that, as to QFs, “each electric utility shall provide . . .Read this passage Filed comments: Reliability and curtailment
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ii.Read this passage
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(a) December Order The Commission found that PJM’s existing retail BTMG netting rules may lead to both reliability and resource adequacy risks because PJM is obligated to serve transmission customers using BTMG but does not consider such customers in transmission and resource adequacy planning.358…Read this passage Filed comments: Reliability and curtailment
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(b) Request for Clarification and/or Rehearing Industrials seek clarification that the removal of BTMG netting rules will only be applicable to transmission and specified ancillary services, not to capacity obligations.Read this passage
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(c) Determination We deny Industrials’ clarification request and sustain the December Order.Read this passage Filed comments: Reliability and curtailment
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iii.Read this passage
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(a) December Order In the December Order, the Commission directed PJM to revise the retail BTMG netting rules in the Tariff.369Read this passage
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(b) Request for Clarification and/or Rehearing Industrials argue that the Commission’s BTMG findings effectuate an unlawful taking of private property without providing just compensation, in violation of the Fifth Amendment of the United States Constitution.Read this passage
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As the Commission found in the December Order, circumstances have changed since the Commission approved PJM’s retail BTMG netting rules such that these rules are no longer just and reasonable.379 The Commission therefore is establishing a just and reasonable replacement rate.Read this passage
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iv.Read this passage
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(a) December Order The Commission directed PJM to propose a new MW threshold for the amount of load at a particular electrical location that Network Customers may net by using BTMG.382 The Commission stated that parties would have an opportunity to comment on PJM’s proposed threshold before we…Read this passage
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(b) Request for Clarification and/or Rehearing Industrials seek clarification that any retail BTMG materiality threshold implemented will be sufficiently high to permit traditional manufacturers and institutional customers to continue to net generation, consistent with actual use of the…Read this passage Filed comments: Reliability and curtailment
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P 194 (stating that “Eligible Customers, on behalf of the Co-Located Loads that they represent, may choose the transmission services that match their preferred use of the transmission system”). 403 Industrials Request for Clarification or Rehearing at 43. 404 FPA section 313(a) requires that an…Read this passage Filed comments: Reliability and curtailment
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Necessary Study Process for Existing Interconnection CustomersRead this passage
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Treatment of Capacity Interconnection Rights (CIRs) for Co-Located GeneratorsRead this passage
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December Order The Commission found that an existing generator may not begin serving Co-Located Load that is not Network Load until it has de-listed its CIRs for the portion of the generator to be designated to serve any Co-Located Load that is not receiving NITS.405 A capacity resource’s CIRs are…Read this passage Filed comments: Connecting load and generation
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Request for Clarification and/or Rehearing Constellation argues that the December Order appears to require a capacity resource to delist its CIRs even when the capacity resource remains fully capable of serving the grid during capacity emergencies.407 Constellation explains that generators and…Read this passage Filed comments: Connecting load and generation
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Determination We deny Constellation’s request for clarification and sustain the December Order’s finding that an existing generator may not begin serving Co-Located Load that is not Network Load until it has delisted its CIRs for the portion of the generator to be designated to serve any Co-Located…Read this passage Filed comments: Connecting load and generation
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b.Read this passage
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December Order In the December Order, the Commission required PJM to revise its Tariff to expressly indicate that the Interconnection Customer will be responsible for the costs of any modifications or Network Upgrades that are needed as a result of PJM’s study of the change to the Interconnection…Read this passage Filed comments: Connecting load and generation
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Request for Rehearing Exelon and FirstEnergy challenge the Commission’s directive that an Interconnection Customer seeking to serve Co-Located Load using an existing generator must bear the costs of all Network Upgrades.417 Exelon and FirstEnergy contend that the Commission has departed, without…Read this passage Filed comments: Connecting load and generation
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The Commission specifically stated that the requirement to self-fund any needed Network Upgrades was appropriate because when “an Interconnection Customer seek[s] to serve Co-Located Load using an existing generating facility” “existing transmission customers” must be “protect[ed]” “from bearing…Read this passage Filed comments: Connecting load and generation
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New Generators Serving Co-Located LoadRead this passage Filed comments: Connecting load and generation
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December Order In the December Order, the Commission found that the Tariff is unjust and unreasonable because it does not contain provisions addressing with sufficient clarity or consistency the rates, terms, and conditions of service that apply to Interconnection Customers serving Co-Located Load…Read this passage Filed comments: Connecting load and generation
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Joint Parties explain that, to the extent PJM performs interconnection service study steps involving withdrawal assumptions from both the storage facility and the Co-Located Load, those steps “must allow the interconnection customer to provide for limits to the injection and withdrawal rights for…Read this passage Filed comments: Connecting load and generation
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Determination We deny Joint Parties’ request for clarification.Read this passage Filed comments: Connecting load and generation
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D.Read this passage
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December Order In the December Order, the Commission directed PJM to submit in Docket No.Read this passage
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Request for Clarification PIOs request clarification as to how the Commission intends to respond to or otherwise use information provided in the record regarding PJM’s load forecasting practices.Read this passage
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Determination We deny the request for clarification.Read this passage
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V.Read this passage
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A.Read this passage
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1.Read this passage
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P 221 (citing PJM Manual 14G: Generation Interconnection Requests, Rev. 8 (eff.Read this passage Filed comments: Reliability and curtailment
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PJM Compliance Filing PJM proposes to modify the existing Tariff definition of BTMG and add a new definition for Retail BTMG to establish a materiality threshold for Retail BTMG.471 PJM explains that the current Tariff definition of BTMG includes both Retail and Non-Retail BTMG, but the Tariff only…Read this passage Filed comments: Connecting load and generation
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c.Read this passage
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Moreover, Industrials/Amtrak argue, a low threshold would remove the incentive to operate efficiently and during stressed system conditions, as well as create additional work for PJM staff to study BTMG that must either go through the interconnection queue or deactivate.Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 106 - arguing that this proposal is inconsistent with the December Order.498 BTMG Parties argue that the scale of the reduction in load (i.e., what PJM considers and plans for versus what PJM may actually need to serve) determines whether the potential for resource adequacy…Read this passage Filed comments: Reliability and curtailment
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EL25-49-002, et al. - 108 - netting eligibility.509 Industrials/Amtrak contend that PJM’s proposal would distort investment decisions, produce outcomes disconnected from actual system needs, harm resource adequacy, and harm economic development opportunities in PJM.510 Energy Artisans contend that…Read this passage Filed comments: Reliability and curtailment
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Answers Indicated TOs argue that PJM’s proposed 50 MW materiality threshold strikes the appropriate balance between allowing continued use of retail BTMG and limitations to ensure reliability.Read this passage Filed comments: Reliability and curtailment
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P 186 (“We find that PJM’s existing BTMG rules may lead to both reliability and resource adequacy risks because PJM, per its Tariff, is obligated to serve transmission customers using BTMG but does not consider such customers in transmission and resource adequacy planning.”). 522 See Vonage…Read this passage Filed comments: Reliability and curtailment
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2.Read this passage
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December Order The Commission directed PJM to establish a transition period of three years for Network Customers currently using PJM’s existing retail BTMG netting rules.551 The Commission also directed PJM to include in its compliance filing revisions to grandfather entities with existing…Read this passage
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EL25-49-002, et al. - 117 - further proposes that this exemption would encompass existing renewal or extension rights recognized under any existing contracts to “avoid interference with such reliance expectations upon which investment decisions likely have been made . . . .”557 PJM states that if…Read this passage
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c.Read this passage
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AEU/SEIA contend that many existing customers have neither the desire nor the economic incentive to pursue co-location and that, for smaller projects, PJM’s full interconnection process will be too costly and complex.563 Eastman similarly requests that the Commission require PJM’s grandfathering…Read this passage Filed comments: Reliability and curtailment
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Answers Indicated TOs argue that PJM’s materiality threshold should be paired with grandfathering provisions that appropriately recognize that customers have relied on retail BTMG netting rules and eliminating such rules could cause financial harm.Read this passage
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Inc., 132 FERC ¶ 61,098, at P 12 (2010) (“The Commission has held that requests to alter a compliance filing in a manner that differs from the order requiring the compliance filing constitute a collateral attack on the order requiring the compliance filing.”). 575 See BTMG Parties Joint Protest of…Read this passage
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3.Read this passage
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PJM Compliance Filing PJM proposes that the new materiality threshold should not apply to any QF over 50 MW serving as Retail BTMG as of the date of the December Order.Read this passage
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Industrials/Amtrak argue that for cogeneration QFs, “the BTMG netting construct aligns with their efficient, reliable energy production configurations, matching the intent of Congress and the [Commission].”584 Industrials/Amtrak argue that QFs have stronger operational and financial incentives to…Read this passage Filed comments: Connecting load and generation
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Answer Industrials/Amtrak note that many of the customers impacted by the change in BTMG netting rules are QFs under PURPA, subject to efficiency standards (and for non-cogeneration QFs, size limits).591Read this passage
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Determination Consistent with our determination on rehearing,592 PJM must submit a further compliance filing that includes a process to exempt certain cogeneration QFs from the new retail BTMG netting rules if they demonstrate that they are integrated with load such that, when their generating…Read this passage Filed comments: Reliability and curtailment
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B.Read this passage
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December Order The Commission directed PJM to modify its Tariff to require that the Eligible Customer taking transmission service on behalf of a Co-Located Load takes one of three transmission services: (1) NITS or Interim NITS, (2) a new FCD transmission service, or (3) a new NFCD transmission…Read this passage Filed comments: Connecting load and generation
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PJM Compliance Filing PJM clarifies that the compliance filing only includes the organizational Tariff changes needed to implement the Commission’s compliance directives regarding creating new transmission services and that the majority of the changes will be determined through the paper…Read this passage Filed comments: Connecting load and generation
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DCC also requests that PJM define the trigger, scope, and sequence of Interim NITS curtailment with respect to the operational limits identified in 622 PJM, Proposed Tariff, Part III (NITS) (4.0.0). 623 EDFps Comments on Compliance Filing at 8. 624 Constellation Protest and Comments on Compliance…Read this passage Filed comments: Reliability and curtailment
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Answers Indicated TOs argue that the Commission should reject requests to reject or defer action on PJM’s proposal to limit the new transmission services to Co-Located Load, because, Indicated TOs contend, the December Order limited such services to Eligible Customers taking transmission service on…Read this passage Filed comments: Connecting load and generation
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However, we reject the Tariff provisions proposing that Co-Located Load that is not served by an Eligible Customer taking transmission service on its behalf “must take all necessary steps to disconnect from the Transmission System.”637 We find this provision duplicative of PJM’s proposed changes to…Read this passage Filed comments: Connecting load and generation
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C.Read this passage
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The Commission found that PJM must include a description of the information that the Interconnection Customer must provide about the Co-Located Load for the purposes of the Necessary Study, and that the Necessary Study process must assess any special protection scheme that is part of a Co-Location…Read this passage Filed comments: Connecting load and generation
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PJM Compliance Filing PJM states that it proposes changes to Parts III and VIII of the Tariff to comply with the Commission’s directives regarding the Necessary Study process for existing Interconnection Customers, including clarifying that customers must enter into a Necessary Study Agreement with…Read this passage Filed comments: Connecting load and generation
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Energy Artisans allege that these requirements will force many industrial facilities to cease operations, which will lead to higher Network Loads and exacerbate resource adequacy issues in PJM.658 Vistra and Constellation request that PJM clarify how the proposed Tariff revisions describing the…Read this passage Filed comments: Connecting load and generation
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VIII.A, § 400 (Definitions N) (2.0.0) (definition of Necessary Study). 675 December Order, 193 FERC ¶ 61,217 at P 226 (“[W]e direct PJM to submit, within 60 days of the date of issuance of this order, a compliance filing to revise the Tariff to clarify that an existing Interconnection Customer…Read this passage Filed comments: Connecting load and generation
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D.Read this passage
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1.Read this passage
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Definition of Co-Located Load In the December Order, the Commission directed PJM to adopt the definition of Co-Located Load specified in the order: “a configuration that refers to end-use customer load that is physically connected to the facilities of an existing or planned Customer Facility on the…Read this passage Filed comments: Connecting load and generation
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The Commission clarified that, should an Interconnection Customer wish to serve Co-Located Load using its generator but not identify an Eligible Customer, then the Interconnection Customer may take steps to terminate its generator’s interconnection to the PJM transmission system and serve the…Read this passage Filed comments: Connecting load and generation
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2.Read this passage
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Definition of Co-Located Load On April 16, 2026, the Commission issued an order rejecting the portion of PJM’s first compliance filing proposing to define Co-Located Load in a manner that deviated 683 Id.Read this passage Filed comments: Connecting load and generation
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PJM explains that the proposed Tariff revisions comply by: (1) adding to the list of requirements for a New Service Request that an Interconnection Customer who will use its generating facility to serve Co-Located Load must specify an Eligible Customer who will take transmission service on behalf…Read this passage Filed comments: Connecting load and generation
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Definition of Non-Retail BTMG PJM states that it is also seeking to avoid any inadvertent changes to the substantive rules pertaining to Non-Retail BTMG.701 For this reason, PJM proposes to add clarifying language in Tariff, Part III, section 34.3 providing that “The daily load of a Network…Read this passage
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3.Read this passage
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Vistra requests that the Commission reject PJM’s use of “Point of Change in Ownership” in its proposed definition of Co-Located Load.707 Vistra argues that PJM’s proposed revision to the definition of Co-Located Load creates uncertainty and an opportunity for transmission owners to unduly…Read this passage Filed comments: Connecting load and generation
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Invenergy requests that the Commission and PJM clarify how the definition of Eligible Customer applies to co-located generators and co-located loads.711 Constellation urges the Commission to direct PJM to revise its proposed definition of Co-Located Generating Facility to clarify that the…Read this passage Filed comments: Connecting load and generation
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Definition of Non-Retail BTMG AMP argues that PJM’s proposed revision to the definition of Non-Retail BTMG could be construed as preventing generating units that are merely eligible for application of the Non-Retail BTMG rules from participating in Co-Located Load configurations.Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 150 - The Maryland OPC argues that the proposed Tariff revisions fail to explain how increased capacity costs of allowing existing generators to serve Co-Located Load, as opposed to new generators, will be paid by Co-Located Load and not by existing ratepayers.714Read this passage Filed comments: Connecting load and generation
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Answers In response to Invenergy, Indicated TOs argue that the Commission should not mandate a combined interconnection and transmission study process for Co-Located Loads and Co-Located Generators.Read this passage
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5.Read this passage
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Rather, PJM proposes to deviate from this definition by replacing the term “Point of Interconnection” with “Point of Change in Ownership” 714 Maryland OPC Protest of Compliance Filing at 10-11. 715 Indicated TOs April 24 Answer at 4-5. 716 Exelon Answer at 1, 5-6. 717 PJM Interconnection, L.L.C.,…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 152 - transmission system;722 and (5) revising the pro forma GIA to specify that an Interconnection Customer that will use its generator to serve Co-Located Load must specify an Eligible Customer that will take transmission service on behalf of the Co-Located Load.723 However,…Read this passage Filed comments: Connecting load and generation
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Definition of Non-Retail BTMG We agree with AMP that PJM’s proposed revisions to the definition of Non-Retail BTMG may inadvertently prevent generators that could merely qualify as Non-Retail BTMG from participating in Co-Location Arrangements, regardless of whether the generator is being used to…Read this passage
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Timing with Planned Reliability Backstop Auction As discussed below, we decline Maryland OPC’s request that the Commission defer action.730 We find that Maryland OPC’s concerns about PJM’s capacity market are beyond the scope of this compliance proceeding, which pertains solely to PJM’s compliance…Read this passage
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E.Read this passage
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PJM Compliance Filing PJM requests a placeholder effective date of 12/31/9998 because PJM cannot implement the Tariff changes until the Commission sets the terms and conditions of the new transmission services in the paper hearing.731 PJM states that it will submit a clean-up filing proposing an…Read this passage
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Vistra also argues that PJM has not explained why it will take until 2029 to update its software to accommodate the new curtailment logic.Read this passage Filed comments: Reliability and curtailment
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Determination As discussed below in Part VI.J, we direct PJM to submit, within 60 days of the date of issuance of this order, a further compliance filing providing additional information on the effective date.Read this passage
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Paper Hearing The Commission directed PJM to modify its Tariff to require that the Eligible Customer taking transmission service on behalf of a Co-Located Load takes one of three transmission services: (1) NITS or Interim NITS, (2) FCD transmission service, or (3) NFCD transmission service.735 With…Read this passage Filed comments: Connecting load and generation
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Rates, Terms, and Conditions for Firm and Non-Firm Contract Demand Transmission ServiceRead this passage
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December Order With respect to FCD transmission service and NFCD transmission service, the Commission found in the December Order that these transmission services should be permanent transmission services available to Eligible Customers taking transmission service on behalf of Co-Located Load.737…Read this passage Filed comments: Connecting load and generation
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2.Read this passage
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PJM further states that an Eligible Customer taking service on behalf of a Co-Located Load must request NFCD transmission service equal to the MW level of the Co-Located Generating Facility dedicated to serving the Co-Located Load, so that the customer is eligible to obtain NFCD transmission…Read this passage Filed comments: Connecting load and generation
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Response Briefs Indicated TOs support PJM’s proposal to require Eligible Customers taking service on behalf of Co-Located Load to take a combination of FCD and NFCD transmission services equivalent to the entire gross demand of the Co-Located Load.753 However, a number of parties protest PJM’s…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 164 - ramping.776 PJM argues that the obvious path for Co-Located Load that increases over time is NITS, a transmission service designed to accommodate load growth.Read this passage Filed comments: Connecting load and generation
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d.Read this passage
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We therefore direct PJM to submit a compliance filing within 60 days of the issuance of this order proposing Tariff revisions to permit Eligible Customers to elect to take FCD transmission service or NFCD transmission service without the limitations that PJM proposes (i.e., (1) the requirement that…Read this passage Filed comments: Connecting load and generation
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3.Read this passage
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PJM proposes that it notify the affected transmission owner of an application for FCD transmission service to allow for coordination to study the potential impacts of providing this service on the transmission owner’s system.803 PJM states that it will determine any necessary studies to provide the…Read this passage
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Response Briefs Indicated TOs support PJM’s proposed study processes for FCD transmission service and state that it appropriately recognizes the role of transmission owners in evaluating load interconnection requests.805 Indicated TOs argue, however, that the Tariff should specify that load…Read this passage Filed comments: Connecting load and generation
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Indicated TOs reject claims that they will use their role in the study process to delay or deny Co-Location Arrangements or discriminate against Co-Located Load.820 Constellation requests that the Commission deter delays and potential disputes by (1) establishing deadlines for studies and other…Read this passage
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d.Read this passage
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Determination We find that PJM’s proposal regarding study procedures for FCD and NFCD transmission services is not sufficiently detailed to be just and reasonable, and we direct 822 PJM Reply Brief at 35-36. 823 Constellation Reply Brief at 18 (citing December Order, 193 FERC ¶ 61,217 at P 214).…Read this passage Filed comments: Connecting load and generation
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4.Read this passage
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In addition to these charges, PJM proposes to assess, for FCD transmission service: (1) administrative service charges, (2) ancillary service charges, (3) black start service charges based on gross demand, (4) regulation charges based on gross demand, and (5) any redispatch costs.Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 183 - using that transmission owners’ coincident peak methodology, given that different transmission owners use different methods.850 Industrials/Amtrak argue that the Commission must ensure that transmission owners’ calculation of individual customer and zonal transmission…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 186 - transmission service is superior to Non-Firm PTPS because it has a superior curtailment priority.Read this passage Filed comments: Connecting load and generation
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Geronimo Power argues that the mere fact that Commission policy allows PJM transmission owners to charge up to the firm rate in some cases does not mean that doing so here is just and reasonable.870 Geronimo Power avers that there should be little doubt that some form of discount must be applied as…Read this passage
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In the December Order, the Commission was clear that NFCD transmission service would “provide an option for Eligible Customers seeking to use the transmission system on behalf of a Co-Located Load in this more limited manner.”879 Further, NFCD transmission service is non-firm and curtailed prior to…Read this passage Filed comments: Connecting load and generation
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5.Read this passage
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PJM next proposes that the Eligible Customer designate the Co-Located Load and the Co-Located Generator and provide the MW level of energy from the Co-Located Generator dedicated to serving the Co-Located Load.901 For reliability purposes, PJM states, the Eligible Customer must provide PJM with…Read this passage Filed comments: Connecting load and generation
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Response Briefs ODEC requests clarification regarding how PJM’s requirement that an Eligible Customer taking transmission service on behalf of a Co-Located Load provide PJM with an authorization or certification from its RERRA which affirms that the Eligible Customer is authorized to provide energy…Read this passage Filed comments: Connecting load and generation
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PJM further proposes changes to section 713.1 to provide that PJM will notify the applicable transmission owners of any instruction to curtail Co-Located Load.Read this passage Filed comments: Connecting load and generation
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The Commission already made clear that Co-Located Load must be “physically connected to the facilities of an existing or planned Customer Facility on the Interconnection Customer’s side of the Point of Interconnection to the PJM Transmission System.”916 If an Eligible Customer attempts to request…Read this passage Filed comments: Connecting load and generation
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Additional Charge for Eligible Customers Taking FCD and/or NFCD Transmission ServiceRead this passage
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December Order As part of the paper hearing, the Commission asked the parties: Should the rate paid by an Eligible Customer on behalf of a Co-Located Load taking only the new Non-Firm Contract Demand transmission service that elects to not reserve any amount of that service for a period of time…Read this passage Filed comments: Connecting load and generation
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In further justifying the Grid Reliance Charge, Indicated TOs assert that Co-Located Load and its associated Co-Located Generator benefit from the existence and reliable operation of the transmission system because they are electrically connected to the transmission system, and should contribute to…Read this passage Filed comments: Connecting load and generation
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3.Read this passage
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NOVEC argues that without the Grid Reliance Charge, a Co-Located Load that reserved no FCD or NFCD transmission service would be a free rider, as it would benefit from the payments of existing transmission customers to maintain the transmission system without making any contribution towards it.Read this passage Filed comments: Connecting load and generation
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Constellation contends that Indicated TOs’ proposed Grid Reliance Charge rests on an unsound methodology that violates cost causation principles.934 Constellation requests that the charge be recalculated based on the “minimum system” method.Read this passage Filed comments: Connecting load and generation
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4.Read this passage
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Indicated TOs state that they are unaware of any existing or proposed Co-Located Load customers that are choosing to island their load and on-site generation, and they infer from that fact that Co-Located Loads should 933 Id. at 23-25. 934 Constellation Response Brief at 25-28. 935 Indicated TOs…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 206 - owners to adopt the alternate cost calculation framework proposed by Constellation, which follows the Commission’s cost causation principles.941 Industrials/Amtrak argue that the proposed Grid Reliance Charge fails to reflect how different customers actually rely on the…Read this passage Filed comments: Connecting load and generation
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EL25-49-002, et al. - 207 - Charge is not only to recover costs to deliver ancillary services, but to ensure Co-Located Load customers pay their fair share of the transmission system as it exists and the associated benefits that it provides to all interconnected customers, including essential…Read this passage
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Nonetheless, we recognize that the new transmission services created in this proceeding could raise novel questions regarding application of cost causation principles, particularly if, in practice, many Eligible Customers taking the new transmission services on behalf of Eligible Load elect to take…Read this passage Filed comments: Connecting load and generation
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Interconnection Requirements and Operational Practices for Necessary Control Technologies and/or Protection SystemsRead this passage
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Indicated TOs argue that all special protection schemes and remedial action schemes must meet PJM and transmission owner technical criteria.Read this passage Filed comments: Connecting load and generation
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Response Briefs Vistra opposes Indicated TOs’ request to implement and enforce limits on the amount of load that can be covered by special protection schemes, including in certain areas.953 Vistra expresses concern that this limit could lead to undue discrimination, and argues that if the…Read this passage Filed comments: Connecting load and generation
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More specifically, Constellation supports, subject to clarification, Indicated TOs’ recommendations that: (1) all special protection schemes and remedial action schemes be fully redundant; (2) customers should pay for PJM and transmission owner-administered studies to ensure any special protection…Read this passage Filed comments: Connecting load and generation
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Indicated TOs also allege that the cost to implement protection systems is extremely low compared to other costs to develop and interconnect Co-Located Load and would not be a deterrent.977Read this passage Filed comments: Connecting load and generation
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We find that PJM’s proposal is inconsistent with the directives in the December Order.Read this passage Filed comments: Reliability and curtailment
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Penalty Charge or Other Remedial Action for New Transmission ServicesRead this passage
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PJM supports its proposal to permit an Eligible Customer disqualified from taking the new transmission services to take NITS by reasoning that NITS, in and of itself, addresses curtailment, load shed, and control technology or protection scheme misoperation risk.994 PJM states that it supports a…Read this passage Filed comments: Reliability and curtailment
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Vistra also points out that, if the Commission accepts transmission owners’ proposal to own special protection schemes, then misoperation of such schemes must attach to the transmission owner, not the Eligible Customer.Read this passage Filed comments: Reliability and curtailment
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However, PJM notes that, in response to protesters’ concerns, PJM proposes revisions to its illustrative tariff language to add discretion to the strict application of non-monetary operational penalties.Read this passage Filed comments: Connecting load and generation
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Answer Constellation alleges that PJM’s reliability arguments are not persuasive, because PJM’s example involves grid-connected load, not Co-Located Load.1026 Constellation argues that PJM fails to explain how resource adequacy concerns justify its proposed penalty scheme, and points out that PJM…Read this passage Filed comments: Connecting load and generation
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We agree with PJM that there are significant reliability risks associated with failing to follow a curtailment or load shedding directive, but we find that PJM’s one strike proposal is unnecessarily strict.Read this passage Filed comments: Reliability and curtailment
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Failure to Follow Curtailment or Load Shedding Directive We find that it is just and reasonable to establish an operational penalty for an Eligible Customer taking any of the new transmission services on behalf of Eligible Load after the second instance of failing to follow a curtailment or load…Read this passage Filed comments: Reliability and curtailment
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However, we reject PJM’s proposal not to apply such a penalty to Eligible Customers taking FCD transmission service on behalf of Co-Located Load, consistent with our findings above that Eligible Customers taking FCD transmission service on behalf of Co-Located Load must also have necessary control…Read this passage Filed comments: Connecting load and generation
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Unreserved Use of the Transmission System We find that it is just and reasonable to impose a financial penalty on an Eligible Customer taking any of the new transmission services on behalf of Eligible Load for unreserved use of the transmission system.Read this passage Filed comments: Connecting load and generation
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Anti-Toggling Mechanisms for Firm Contract Demand Transmission Service In the December Order, the Commission found that FCD transmission service should have a minimum term of one year, but that PJM should propose an anti-toggling mechanism for Eligible Customers switching between FCD and NFCD…Read this passage
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Initial Briefs PJM proposes an anti-toggling mechanism to prevent transmission customers from switching between FCD and NFCD transmission services by providing that the portion of the Co-Located Load served by FCD transmission service is not eligible to be served by NFCD transmission service for…Read this passage Filed comments: Connecting load and generation
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NOVEC asserts that the minimum service commitment sends timely price signals to the capacity market, enhances market stability, and minimizes upgrade‑related risks if a Co-Located Load withdraws.Read this passage Filed comments: Connecting load and generation
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In particular, we find that PJM’s proposal to prohibit, for a period of five years, Eligible Customers taking transmission service on behalf of a Co-Located Load from taking NFCD transmission service for any portion of 1059 Id. at 54-55. 1060 Indicated TOs Initial Brief at 21 (citing December…Read this passage Filed comments: Connecting load and generation
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Communications, Alarm, SCADA, or Other RequirementsRead this passage
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Initial Briefs PJM proposes to develop telemetry requirements for Co-Located Load so that PJM can monitor the status of demand placed on PJM’s transmission system, including unreserved use, to ensure reliability.1068 PJM states that it still determining the scope of the tools and requirements…Read this passage Filed comments: Connecting load and generation
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Response Briefs Indicated TOs support PJM’s proposal in its initial brief to develop telemetry requirements and require Co-Located Load to meet such requirements in order to monitor Co-Located Loads’ use of the transmission system.1070Read this passage Filed comments: Connecting load and generation
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Determination We decline to direct PJM’s proposed telemetry, data exchange, metering, and relay setting requirements as the replacement rate because PJM has not provided 1068 PJM Initial Brief at 59-61. 1069 Id. at 60-61. 1070 Indicated TOs Response Brief at 10-11.Read this passage
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Curtailment Procedures for Interim NITS and Non-Firm Contract Demand Transmission ServiceRead this passage Filed comments: Reliability and curtailment
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PJM proposes that FCD transmission service be treated equal to NITS for purposes of curtailment.1072 PJM states that it reserves the right to curtail the three new transmission services on a non-discriminatory basis for the purpose of making necessary adjustments to, changes in, or repairs on its…Read this passage Filed comments: Connecting load and generation
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Response Briefs Joint Co-Location Developers argue that PJM fails to adequately clarify when and how NFCD transmission service and Interim NITS shall be curtailed, in particular the curtailment trigger.1074 Joint Co-Location Developers maintain that the curtailment trigger significantly affects…Read this passage Filed comments: Reliability and curtailment
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Reply Briefs Earthjustice argues that the Commission should require PJM to clarify how and when PJM will enforce its curtailment procedures, including: (1) how PJM will communicate its curtailment directives; (2) how and when transmission providers will determine that load shed is necessary, which…Read this passage Filed comments: Reliability and curtailment
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Answers Constellation argues that PJM inappropriately attempts in its reply brief to reinstate a curtailment criterion of a capacity/reserve shortage and that the Commission rejected this element of PJM’s proposed Option 7 in the December Order.1082Read this passage Filed comments: Reliability and curtailment
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We disagree with commenters that PJM must provide specific details in its Tariff, such as the trigger and procedures for curtailment of Interim NITS and FCD or NFCD transmission services, or how PJM will enforce its curtailment procedures.Read this passage Filed comments: Reliability and curtailment
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H.Read this passage
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PJM proposes load shedding and curtailment provisions applicable to Interim NITS, including that prior to commencement of service, the Eligible Customer must demonstrate its ability to comply with PJM’s load shedding and curtailment procedures.1094 PJM proposes to require Eligible Customers taking…Read this passage Filed comments: Connecting load and generation
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Fifth, Indicated TOs propose revisions to section 705.5 to require that the necessary control technologies and/or protection systems that must be approved by PJM are also approved by and developed in accordance with the transmission owners’ interconnection standards, guidelines, and practices.Read this passage Filed comments: Connecting load and generation
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Vistra argues that PJM’s study process is flawed because it provides too much discretion to PJM and transmission owners to determine whether studies are required, which studies to conduct, the timeline for doing so, and how to prioritize different requests.1097 Also, Vistra contends that PJM’s…Read this passage Filed comments: Connecting load and generation
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Reply Briefs In consideration of parties’ comments, particularly those of Indicated TOs, PJM proposes certain revisions to the illustrative tariff provisions for Interim NITS and NITS, and the Service Agreement for Interim NITS.1106 PJM articulates several reasons why Interim NITS customers should…Read this passage Filed comments: Connecting load and generation
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Answers Constellation asks the Commission to direct PJM to revise its illustrative tariff to clarify that large loads with pending NITS applications shall be studied for Interim NITS at the request of the load without having to submit a separate application.1114 Enchanted Rock reiterates that PJM’s…Read this passage Filed comments: Connecting load and generation
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We therefore direct PJM to submit, within 60 days, a compliance filing to incorporate the rates, terms, and conditions for Interim NITS that includes clarifications to specify that (1) an Eligible Customer taking Interim NITS on behalf of Co-Located Load may be served by a Co-Located Generator that…Read this passage Filed comments: Connecting load and generation
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MWs of each new transmission service taken by Eligible Customers serving Eligible Loads as a percentage of peak gross load for each transmission owner 4) Frequency and magnitude of curtailment from the reservation of NFCD transmission service and Interim NITS by transmission zone 5) Frequency and…Read this passage Filed comments: Reliability and curtailment
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J.Read this passage
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Initial Briefs PJM proposes an effective date of June 1, 2029, for the three new transmission services.Read this passage Filed comments: Connecting load and generation
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Vistra proposes that, even if the Commission accepts PJM’s software-based justifications, the Commission should require PJM to immediately accommodate Co-Location Arrangements for which software changes are irrelevant, such as where the Eligible Customer does not reserve any amount of NFCD…Read this passage Filed comments: Connecting load and generation
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PJM argues that it must determine how to properly model and reflect NFCD transmission service and Co-Located Load in the different systems given that NFCD transmission service requires the transmission system to operate on reduced contingency margins.Read this passage Filed comments: Connecting load and generation
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Answer Constellation opposes PJM’s requested effective date and points out that PJM seeks to begin Connect and Manage July 1, 2027, to allow the interconnection of non-capacity-backed loads that are potentially interruptible during capacity shortages, unless the load brings its own generation.1150…Read this passage
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Determination We find that PJM has not provided sufficient information for the Commission to find that its proposed June 1, 2029, effective date is just and reasonable.Read this passage Filed comments: Connecting load and generation
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K.Read this passage
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1.Read this passage
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PJM contends that Industrials/Amtrak improperly ask the Commission to examine BTMG.1155Read this passage Filed comments: Connecting load and generation
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Determination Industrials/Amtrak raise issues with respect to PJM’s retail BTMG netting rules that we address in PJM’s second compliance filing above.1156Read this passage
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Maryland OPC requests that the Commission at minimum require PJM demonstrate how its proposal meets ratepayer protection standards set forth in the Statement of Principles and Ratepayer Protection Pledge and defer action on the proposed revisions until after PJM proposes tariff revisions to…Read this passage Filed comments: Connecting load and generation
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We find that Maryland OPC’s concerns about PJM’s capacity market are beyond the scope of this paper hearing, which addresses the rates, terms, and conditions for new transmission services for Eligible Customers to take on behalf of Eligible Loads.1159 1157 Maryland OPC Reply Brief at 9-11. 1158 Id.…Read this passage Filed comments: Connecting load and generation
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3.Read this passage
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Response Briefs Invenergy requests that the Commission and PJM clarify how the definition of Eligible Customer applies to Co-Located Generators and Co-Located Loads.1160 Invenergy explains that, where a state retail choice program results in unbundled retail access, customers may take transmission…Read this passage Filed comments: Connecting load and generation
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Specifically, NOVEC seeks confirmation that it cannot be required to serve as an Eligible Customer serving Co-Located Load unless it agrees to do so.1162 NOVEC argues that the Commission cannot require LSEs to modify their retail rates to accommodate these new services and undertake the…Read this passage Filed comments: Connecting load and generation
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We also clarify that nothing in this order or the December Order requires LSEs to modify their retail rates to accommodate the new transmission services.Read this passage
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4.Read this passage
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Response Briefs Alliance supports converting Options 7 and 8 from PJM’s March 2025 Answer into enforceable tariff language.Read this passage
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Determination Alliance’s comments are essentially an untimely request for rehearing of the December Order.Read this passage Filed comments: Connecting load and generation
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5.Read this passage
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Response Briefs AEU/SEIA claim that PJM proposes to require all co-located generators to undergo full interconnection studies, including those that have no intention of exporting power to the transmission system.1168 AEU/SEIA argue that PJM indisputably requires sufficient information about…Read this passage Filed comments: Connecting load and generation
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Reply Briefs PJM argues that AEU/SEIA improperly assert that PJM should not study all interconnecting generators.1169 1167 December Order, 193 FERC ¶ 61,217 at P 242. 1168 AEU/SEIA Response Brief at 15-16 (citing PJM Initial Brief at 82). 1169 PJM Reply Brief at 58.Read this passage
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However, we note that the Commission has approved PJM’s proposal to comply with the directives of the December Order that, for Interconnection Customers seeking to use new generators to serve Co-Located Load: PJM will consider requests for interconnection service below the full generating…Read this passage Filed comments: Connecting load and generation
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Co-Location Arrangement with Electric Storage ResourceRead this passage
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Joint Co-Location Developers claim that, in the context of PJM’s proposal to limit NFCD transmission service to 100% of the Maximum Facility Output of the Co-Located Generator, PJM appears to allow the relevant Co-Located Load to take service while the co-located electric storage resource charges.Read this passage Filed comments: Connecting load and generation
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Reply Brief PJM argues Joint Co-Location Developers improperly ask the Commission to examine transmission service for charging electric storage resources.1172Read this passage
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AD24-11-001 EL25-20-001 (consolidated) ER26-1479-000 (Issued June 18, 2026) CHANG, Commissioner, concurring: In today’s order, the Commission addresses rehearing requests and the paper hearing and compliance record regarding the rates, terms, and conditions through which Co-Located Loads may take…Read this passage Filed comments: Connecting load and generation