EL26-67-000 · 2026-07-22 · Allegheny Electric Cooperative, Inc.

Motion to Rescind Show Cause Order of Allegheny Electric Cooperative, Inc

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C.  
 
 
 
Docket No. EL26-67-000 
AEP Appalachian Transmission Company, Inc. 
AEP Indiana Michigan Transmission Company, Inc. 
AEP Kentucky Transmission Company, Inc. 
AEP Ohio Transmission Company, Inc. 
AEP West Virginia Transmission Company, Inc. 
Allegheny Electric Cooperative, Inc. 
American Transmission Systems, Incorporated 
Appalachian Power Company 
Atlantic City Electric Company 
Baltimore Gas and Electric Company 
Commonwealth Edison Company 
Commonwealth Edison Company of Indiana, Inc. 
Dayton Power and Light Company 
Delmarva Power & Light Company 
Duke Energy Kentucky, Inc. 
Duke Energy Ohio, Inc. 
Duquesne Light Company 
Essential Power Rock Springs, LLC 
Hudson Transmission Partners, LLC 
Indiana Michigan Power Company 
Jersey Central Power & Light Company 
Kentucky Power Company 
Keystone Appalachian Transmission Company 
Kingsport Power Company 
Linden VFT, LLC 
Mid-Atlantic Interstate Transmission, LLC 
Monongahela Power Company 
Neptune Regional Transmission System, LLC 
NextEra Energy Transmission MidAtlantic Indiana, Inc. 
Ohio Power Company 
Ohio Valley Electric Corporation 
Old Dominion Electric Cooperative 
PECO Energy Company 
PPL Electric Utilities Corporation 
The Potomac Edison Company 
Potomac Electric Power Company 
Public Service Electric and Gas Company 
Rockland Electric Company

2 
 
Silver Run Electric, LLC 
Trans-Allegheny Interstate Line Company 
Transource West Virginia, LLC 
UGI Utilities, Inc. 
Virginia Electric and Power Company 
Wabash Valley Power Association, Inc. 
Wheeling Power Company 
 
 
MOTION TO RESCIND SHOW CAUSE ORDER AS TO 
ALLEGHENY ELECTRIC COOPERATIVE, INC. 
 
Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure,1 Allegheny 
Electric Cooperative, Inc. (“Allegheny”) hereby submits this motion to the Federal Energy 
Regulatory Commission (“FERC” or “Commission”) to rescind the show cause order (“PJM 
Show Cause Order”)2 directed to Allegheny and issued on June 18, 2026, in the above captioned 
proceeding.   
I. 
DESCRIPTION OF ALLEGHENY 
Allegheny, the owner of transmission facilities turned over to the operational control of 
PJM Interconnection, L.L.C. (“PJM”) and thus a PJM transmission owner (“PJM TO”), is a 
non-profit electric generation and transmission cooperative (“G&T Cooperative”) corporation, 
incorporated under the Electric Cooperative Law of the Commonwealth of Pennsylvania.  It is 
the exclusive wholesale supplier of its 14 electric distribution cooperative members located in 
Pennsylvania and New Jersey.  Like other G&T Cooperatives, Allegheny is owned entirely by 
its members.  Each of Allegheny’s members either receives financing under the Rural 
Electrification Act of 1936 or sells less than 4 million megawatt hours of electricity per year.  
 
1  
18 C.F.R. § 385.212 (2026). 
2  
PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“PJM Show Cause Order”).

3 
 
For this reason, Allegheny is not a public utility subject to FERC jurisdiction, pursuant to 
Section 201(f) of the Federal Power Act.3   
II. 
RELEVANT BACKGROUND 
On June 18, 2026, the Commission issued the PJM Show Cause Order, thereby initiating 
a proceeding under Section 206 of the Federal Power Act.  The PJM Show Cause Order found 
that PJM’s Open Access Transmission Tariff (“Tariff”) appears to be unjust, unreasonable, or 
unduly discriminatory or preferential for failure to include specific provisions addressing the 
interconnection of data centers, manufacturing facilities, and other large energy users.4  The 
PJM Show Cause Order directed PJM and certain of the PJM TOs either to explain how the 
Tariff remains just and reasonable without specific provisions for the interconnection of large 
load or to develop such provisions.5     
On the same day, the Commission initiated similar Federal Power Act Section 206 show 
cause proceedings against five other regional transmission organizations/independent system 
operators (“RTOs/ISOs”) and their transmission owners.6   
III. 
JUSTIFICATION FOR RESCISSION 
The Commission directed the PJM Show Cause Order to PJM and to those PJM TOs that 
are public utilities, and it expressed an intention to exempt those PJM TOs that are not subject to 
FERC jurisdiction.7  The Commission specifically indicated that it did not address the PJM 
Show Cause Order to the following PJM TOs because they are not public utilities pursuant to 
Section 201(f) of the Federal Power Act:  AMP Transmission, LLC; City of Cleveland, 
 
3  
16 U.S.C. § 824(f) (2026).   
4  
195 FERC ¶ 61,211 at P 3.    
5  
Id. 
6  
See, e.g., Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (“CAISO Show Cause Order”).   
7  
195 FERC ¶ 61,211 at P 3, n.13.

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Department of Public Utilities, Division of Cleveland Public Power; City of Hamilton, Ohio; 
East Kentucky Power Cooperative, Inc.; and Southern Maryland Electric Cooperative, Inc.8  
The Commission, however, noted that it retains the authority to review each of these entities’ 
tariff provisions as a component of PJM’s Tariff in an order to show cause directed towards 
PJM, and it also noted that PJM is obliged to respond regarding these entities’ tariff provisions.9    
As demonstrated above, Allegheny is not a public utility pursuant to Section 201(f) of 
the Federal Power Act.  Accordingly, like each of the PJM TOs that the Commission identified 
as non-public utilities, Allegheny should have been exempted from the PJM Show Cause Order.  
Allegheny believes that the Show Cause Order directed to it was issued in error.  In requesting 
rescission of the Show Cause Order as to it, Allegheny acknowledges the Commission’s 
authority to review the Allegheny-specific provisions of the Tariff and pledges to cooperate with 
PJM, to the extent that PJM requests assistance from Allegheny, in crafting its response. 
Allegheny submits this request for recission consistent with the Commission’s guidance 
to transmission owners that are not subject to its jurisdiction located in other ISO/RTO regions.  
For instance, the Commission directed the CAISO Show Cause Order to CAISO transmission 
owners that are not public utilities despite their non-jurisdictional status “because their 
Transmission Owner Tariffs on file with the Commission detail the wholesale load 
interconnection process in CAISO.”10  The Commission advised that, “[i]f a non-public utility 
wishes to be removed from this proceeding, we will rescind the show cause order against them 
at their request . . ..”11  Allegheny’s motion for rescission is thus consistent with this guidance. 
 
8  
Id.   
9  
Id. (citing Sw. Power Pool, Inc., 180 FERC ¶ 61,022 at P 40 (2022)). 
10  CAISO Show Cause Order, 195 FERC ¶ 61,214 at P 2, n.9.  For the record, the Allegheny-specific 
portions of the PJM Tariff do not include interconnection processes or policies.   
11  Id.

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IV. 
CONCLUSION 
For the reasons indicated above, Allegheny respectfully requests that the Commission 
rescind the PJM Show Cause Order against it, as a non-public utility, and asks that the 
Commission waive any notice and comment periods that might be applicable to this motion. 
Dated:  July 22, 2026  
 
 
Respectfully Submitted, 
/s/ Joshua E. Adrian  
Joshua E. Adrian 
Thompson Coburn, LLP 
1909 K Street, NW 
Suite 600 
Washington, D.C.  20006 
(202) 585-6922 
 
Attorney for Allegheny Electric Cooperative, Inc.

CERTIFICATE OF SERVICE  
I hereby certify that I have this day caused the foregoing document to be served on the 
official service list compiled by the Secretary in this proceeding. 
Dated at Washington, DC, this 22nd day of July, 2026. 
/s/ Joshua E. Adrian  
Joshua E. Adrian 
Thompson Coburn, LLP  
1909 K Street, NW  
Suite 600 
Washington, DC 20426  
(202) 525-6922