Founded in 2014, Maven has developed the Civic Bankability Rating Standard (“CBRS”), a statute-grounded scoring methodology for evaluating large-load and data-center projects against the ratepayer, reliability, community-cost, and financial-surety exposures they generate.

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II. EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY HEADLINE FINDING PJM's current tariff posture on large-load interconnection scores CONDITIONAL under the Civic Bankability Rating Standard with two active keystone flags — Ratepayer Protection (FERC Category 2) and Financial Surety (FERC Category 4).

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III. RECORD BACKGROUND: THE PJM SYSTEM IN

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RECORD BACKGROUND: THE PJM SYSTEM IN DOCUMENTED DISTRESS

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A. Emergency Authorities in Force

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Emergency Authorities in Force On May 18, 2026, the U.S.

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B. Capacity Market Trajectory

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Capacity Market Trajectory PJM Base Residual Auction (“BRA”) clearing prices have followed the trajectory shown below.4 Delivery Year Clearing Price ($/MW-day) Notes 2024/25 $28.92 Baseline 2025/26 $269.92 Single-auction increase 2026/27 $329.17 Constrained by PA/PJM settlement cap 2027/28 $333.44…

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C. The 2027/28 Footprint Shortfall

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The 2027/28 Footprint Shortfall PJM has reported that the 2027/28 BRA was the first RPM auction since the Reliability Pricing Model was created in 2007 that did not meet the reliability requirement.

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D. July 1–3, 2026 Emergency Event

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PJM also warned utilities to prepare for possible curtailment of data centers and other large loads to backup generation, but reported that the action was ultimately not required.7 The event was contemporaneous with the intervention window for these Show Cause Comments.

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E. Estimated Ratepayer Impact

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Estimated Ratepayer Impact The Natural Resources Defense Council has estimated that data-center-driven load growth could impose up to $163 billion in additional PJM consumer costs through 2033, with average household impacts reaching approximately $70 per month by 2028.9 Monitoring Analytics has…

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F. Companion Proceedings

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Companion Proceedings The Commission's Show Cause Order in this docket is one of six issued on June 18, 2026, splitting the underlying rulemaking record from Docket No.

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IV. METHODOLOGY: THE CIVIC BANKABILITY RATING

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METHODOLOGY: THE CIVIC BANKABILITY RATING STANDARD

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A. Overview of CBRS

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Overview of CBRS The Civic Bankability Rating Standard is a statute-grounded scoring methodology Maven Solutions has developed for evaluating large-load and data-center projects against ratepayer, reliability, community-cost, and financial-surety exposures.

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B. Jurisdictional Application to Commission Proceedings

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Maven applies to Commission proceedings a jurisdiction-relevant subset consisting of four dimensions: Ratepayer Protection, Transparency, Co-Location and Interconnection Governance, and Financial Surety.

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C. Mapping the Jurisdictional Subset to FERC's Five Reform Categories

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Reform Focus Primary CBRS Dimension 1 Efficient transmission service application and study processes Transparency 2 Preventing cost shifting; requiring transparency Ratepayer Protection — 8 of 16 KEYSTONE 3 Co-location and behind-the-meter generation Co-Location & Interconnection Governance 4 New…

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V. ANALYSIS AGAINST FERC'S FIVE REFORM CATEGORIES

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V.

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A. Category (1) — Efficient Transmission Service Application and Study

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Category (1) — Efficient Transmission Service Application and Study Processes Primary CBRS Dimension: Transparency Score: 2 of 5 — Conditional.

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B. Category (2) — Preventing Cost Shifting and Requiring Transparency

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Category (2) — Preventing Cost Shifting and Requiring Transparency Primary CBRS Dimension: Ratepayer Protection — KEYSTONE FLAG ACTIVE Score: 1 of 5 — below the CBRS Acceptable threshold.

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C. Category (3) — Accommodating Co-Location and Behind-the-Meter

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The posture recognizes co-location as a service class but does not yet include measurable reliability-hold-harmless mechanisms, financial surety instruments backing switching-event ratepayer exposure, or reciprocity provisions between co-located generation and the load it serves. 10 of 16

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D. Category (4) — New Transmission Services for Flexible Large Loads

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Category (4) — New Transmission Services for Flexible Large Loads Primary CBRS Dimension: Financial Surety — KEYSTONE FLAG ACTIVE Score: 2 of 5 — Conditional.

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E. Category (5) — Process to Study Generation Serving Electrically

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The study process for such 11 of 16 generation currently proceeds on the same footing as unconstrained generation interconnection, which does not account for the specific service-and-cost relationship between the generation and the co-located load it primarily serves.

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VI. CBRS FINDINGS FOR PJM

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CBRS Dimension Applied Raw Score Keystone? 1 Transparency (primary) 2 / 5 — 2 Ratepayer Protection 1 / 5 KEYSTONE FLAG 3 Co-Location & Interconnection Governance 2 / 5 — 4 Financial Surety 2 / 5 KEYSTONE FLAG 5 Transparency (secondary axis) 2 / 5 — Total Four unique dimensions applied 9 / 20 TWO…

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VII. RECOMMENDATIONS TO THE COMMISSION

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Recommendation 3 — Category (3): Co-Location and BTMG Reliability and Ratepayer-Hold- Harmless Any co-location or behind-the-meter generation tariff provisions adopted in Category (3) should be consistent with the Commission's dispositions in PJM's parallel co-location and BTMG compliance…

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VIII. COMPANION FILINGS AND STAGE 2 SUPPLEMENT

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COMPANION FILINGS AND STAGE 2 SUPPLEMENT NOTICE These Comments are one of six substantive Comments Maven Solutions files in the six Show Cause dockets initiated on June 18, 2026 (Dockets EL26-67 through EL26-72).

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IX. CONCLUSION

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Maven respectfully requests that the Commission require PJM to submit tariff revisions or, in the alternative, a detailed evidentiary showing that addresses each of the five categories consistent with the recommendations set out herein.

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X. SOURCES AND NOTES

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PJM Interconnection, L.L.C., post-event operations reporting on the July 1–3, 2026 heat event, including preliminary July 2, 2026 instantaneous load of approximately 162,700 MW after demand- response activation and reporting on the utility warning regarding possible curtailment of data centers and…

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