EL26-67-001 · 2026-07-20 · Eolian, L.P.

Eolian, L.P. submits Limited Request for Clarification or, In the Alternative, Rehearing of the 06/18/2026 Order Instituting Proceedings Under Section 206 of the Federal Power Act

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Topics in the text: Connecting load and generation · Cost allocation · Filing procedure

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Opening text

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OF THE COMMISSION’S ORDERS INSTITUTING PROCEEDINGS UNDER SECTION 206 OF THE FEDERAL POWER ACT Pursuant to section 313(a) of the Federal Power Act (“FPA”), 16 U.S.C. § 825l (2024), and Rule 713 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or…
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I. CONCISE STATEMENT OF ISSUES AND SPECIFICATION OF ERRORS

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CONCISE STATEMENT OF ISSUES AND SPECIFICATION OF ERRORS (1) The Commission’s Orders arbitrarily and capriciously limit RTO/ISOs’ ability to put in place a replacement rate that will ensure just and reasonable and not unduly 4 discriminatory rates by not requiring and/or by limiting their ability to…
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II. ARGUMENT

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II.
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A. The Commission’s Orders Seek to Address Urgent Problems Due to Large

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The Orders specify that while “it may be reasonable for the generator interconnection service to be permanent” “[t]o the extent that the interconnection customer’s generating facility is serving a large co-located load,” where “the interconnection customer’s generating facility is serving an…
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B. Absent modification or clarification, the Commission’s Orders unreasonably

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For permanent LLGIS, it asks the same question about locating new generation at Point A (behind the load’s point of interconnection) or at Point B.
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C. The Orders fail to require broad enough reforms to the generator

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Any flexibility to tailor the generator interconnection reforms to the unique circumstances of the region must be paired with an obligation on the RTO/ISO to show that the set of reforms it proposes will enable a pathway for significant generating capacity to provide load-limited interconnection,…
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III. CONCLUSION

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III.
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CONCLUSION

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CONCLUSION For the foregoing reasons, Eolian respectfully requests that the Commission grant the requested clarifications or, in the alternative, grant rehearing.
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CERTIFICATE OF SERVICE

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Dated: July 20, 2026 /s/ Nathan Lobel Nathan Lobel Roselle LLP 300 New Jersey Ave.
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ATTACHMENT A

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ATTACHMENT A UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION PJM Interconnection, L.L.C., et al.
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I. QUALIFICATIONS

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I am a Senior Consultant at The Brattle Group (Brattle). 2 I am an expert on wholesale market design and reliability implications of changes in the power 3 system.
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II. ASSIGNMENT

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ASSIGNMENT 20 I was asked by Eolian, L.P. to assess the five recent Commission Orders on co-located and 21 electrically proximate generation and load pairings, issued June 18, 2026 in the above-captioned 22 dockets.
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A. Mohan, Accelerating the Integration of New Co-located Generation and Loads, prepared for Bloom Energy

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Mohan, Accelerating the Integration of New Co-located Generation and Loads, prepared for Bloom Energy as part of Docket No.
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III. BACKGROUND

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III.
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BACKGROUND

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Five of the regions (all but SPP) addressed an additional tariff reform need: 4) new 11 resource interconnection service for generation serving electrically proximate large load or co- 12 located load.
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IV. PERMANENT LOAD-LIMITED GENERATOR INTERCONNECTION SERVICE

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Therefore, if the 7 test fails in either case, the generator must go through the standard interconnection queue 8 process.
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