EL26-67-000 · 2026-07-28 · Wabash Valley Power Association, Inc.

Wabash Valley Power Association, Inc. submits Request for Issuance of an Errata to the 06/18/2026 Order Instituting Proceedings Under Section 206 of the Federal Power Act

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
PJM Interconnection, L.L.C. 
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 
       Docket No. EL26-67-000

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Public Service Electric and Gas Company 
Rockland Electric Company 
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  
WABASH VALLEY POWER ASSOCIATION, INC. 
REQUEST FOR ISSUANCE OF AN ERRATA 
To the Commission: 
On June 18, 2026, the Commission issued its “Order Instituting Proceeding Under 
Section 206 of the Federal Power Act” in this above captioned proceeding.1  In its Order, 
the Commission found that PJM Interconnection, L.L.C.’s (“PJM”) existing Open Access 
Transmission Tariff (“Tariff”) appears to be unjust, unreasonable, or unduly discriminatory 
or preferential and thereafter directed PJM and forty-five (45) Participating Transmission 
Owners (“PTOs”) within PJM to show cause with respect to a variety of concerns related 
to large load or co-located load transmission and interconnection within sixty (60) days of 
the date of its Order.2 Wabash Valley Power Association, Inc. (“WVPA”) has identified a 
procedural issue with the Order and respectfully requests that the Commission issue an 
errata as soon as practicable. 
1 PJM Interconnection, L.L.C., et al, 195 FERC ¶ 61,211 (June 18, 2026) (the “Order”). 
2 Id. at P 3.

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Before addressing the procedural issue presented below, WVPA desires to clarify 
that it does not dispute the need for the Commission to address issues surrounding service 
to large load and co-located load within organized markets and elsewhere.  Further, WVPA 
acknowledges the Commission’s existing precedent regarding non-jurisdictional entities 
with certain rate schedules within a jurisdictional RTO or ISO.   
The Commission included WVPA as one of the PTOs in the caption of the Order. 
However, at footnote 13 of the Order, the Commission described which PTOs it intended 
to include in the caption and made clear: 
Transmission Owners refers to the entities listed in the caption 
of this order. We recognize that PJM’s transmission owners 
include entities that are not subject to the Commission’s 
jurisdiction because they are not public utilities pursuant to 
section 201(f) of the FPA. See 16 U.S.C. § 824(f); Sw. Power 
Pool, Inc., 180 FERC ¶ 61,022, at PP 44-45 (2022). 
Accordingly, the Commission has not included AMP 
Transmission, LLC; City of Hamilton, OH; East Kentucky 
Power Cooperative, Inc.; and Southern Maryland Electric 
Cooperative, Inc. here as Transmission Owners that must 
respond to this order to show cause. Nonetheless, the 
Commission retains the authority to review each entity’s 
formula rates as a component of PJM’s Tariff in an order to 
show cause directed towards PJM, and PJM must respond to 
this order regarding the non-public utilities’ PJM Tariff 
provisions on file with the Commission. See Sw. Power Pool, 
Inc., 180 FERC ¶ 61,022 at P 40.[3] 
Like each of the PTO entities listed in footnote 13, WVPA is not a public utility 
pursuant to section 201(f) of the FPA.  In January 2025 WVPA informed the Commission 
that as a result of the termination of one of its members, it ceased to be a public utility on 
3 Id. at fn. 13.

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January 1, 2025 because it became exempt from the Federal Power Act as a result of being 
wholly owned by exempt entities.  As of January 1, 2025, WVPA has been wholly owned 
by twenty-one electric cooperatives that receive financing under the Rural Electrification 
Act of 1936 or sell less than four (4) million megawatt hours annually and by one additional 
member, which is wholly owned by WVPA.  The Commission subsequently acknowledged 
WVPA’s acceptance of its withdrawal of jurisdictional rate schedules based on the change 
in status.4   
 
As of today, WVPA is still wholly owned by electric cooperatives that receive 
financing under the Rural Electrification Act of 1936 or sell less than four (4) million 
megawatt hours annually and by the additional member it wholly owns.  In fact, WVPA is 
itself in the process of receiving financing under the Rural Electrification Act of 1936.  
WVPA is a PTO within PJM, however, it is a PTO that is similarly situated to all of the 
other non-jurisdictional entities listed in footnote 13 of the Order.  WVPA respectfully 
submits that it is unaware of any basis, stated within the Order or any facts external to the 
Order, to treat WVPA any different.  WVPA believes that the Order inadvertently 
identified it based on its prior status as a public utility. 
 
In addition, WVPA believes the Commission did not intend to include it as a named 
respondent. In the Show Cause Order issued to the California Independent System Operator 
(“CAISO”) and its transmission owners in Docket No. EL26-71-000, non-jurisdictional 
 
4 Wabash Valley Power Ass’n, Inc., Docket No. ER25-838-000, (Feb. 12, 2025) (delegated order); 
Wabash Valley Power Ass’n, Inc., Docket No. ER25-842-000, (Feb. 12, 2025) (delegated order).

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utilities were purposefully included as respondents “because their Transmission Owner 
Tariffs on file with the Commission detail the wholesale load interconnection process in 
CAISO.”5  The Commission explained 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, 
and we expect CAISO to respond to this order regarding the non-public utility’s CAISO 
Tariff provisions on file with the Commission.”6  The Commission did not express a similar 
concern with respect to PJM’s non-jurisdictional transmission owners. 
As the Commission’s interests are in modifying the terms and conditions of the PJM 
Tariff, an errata to the Order affecting PJM would not impact or diminish the Commission’s 
stated show cause goals. Further, an errata to the Order would be consistent with the 
Commission’s treatment of a request from a similarly situated non-jurisdictional entity in 
Docket No. EL26-72-000 regarding the Show Cause Order issued to ISO New England 
Inc.7  Based on these facts, WVPA respectfully requests that the Commission issue an 
errata to the Order that:  
(1) removes WVPA from the caption of Docket No. EL26-67-000, which
intended to identify only PJM and jurisdictional PTOs; and
(2) adds WVPA in the list of non-jurisdictional PTO entities in footnote 13.
If the Commission determines that the requested corrections exceed the scope of 
5 Cal. Indep. Sys. Op, Inc., et al, 195 FERC ¶ 61,214 at fn. 9 (2026) (“CAISO Order”). 
6 Id., citing Sw. Power Pool, Inc., 180 FERC ¶ 61,022 at P 40 (2022).  
7 ISO New England Inc., 195 FERC ¶ 61,215 (2026), errata notice, FERC Docket No. EL26-72-000 (July 
9, 2026).

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an errata, WVPA respectfully requests in the alternative that the Commission rescind the 
Order with respect to WVPA as described in the CAISO Order precedent, as set forth 
above. 
       Respectfully submitted, 
/s/ Jeremy L. Fetty  
Jeremy L. Fetty 
L. Robyn Zoccola
Parr Richey Frandsen Patterson Kruse LLP
c/o Wabash Valley Power Association
6702 Intech Boulevard
Indianapolis, IN 46278
Telephone: (317) 481-2815
Email: jfetty@parrlaw.com
rzoccola@parrlaw.com 
Counsel 
for 
Wabash 
Valley 
Power 
Association, Inc. 
Dated: July 28, 2026

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CERTIFICATE OF SERVICE 
I hereby certify that on this 28th day of July 2026, I have served a copy of the 
foregoing document on the official service list compiled by the Office of the Secretary for 
the above-referenced proceeding.  
 
/s/ Jeremy L. Fetty