{"document":{"slug":"filing-20260803-5234","title":"Answer of Constellation Energy Generation, LLC in support of PJM Interconnection, L.L.C.'s Motion for Abeyance","issued":"2026-08-03","accession":"20260803-5234","docket":"EL26-67-000","group":"PJM filings","filer":"Constellation Energy Generation, LLC","kind":"answer","file":"sources/originals/20260803-5234_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5234","sha256":"76b892a0ee562c62f7342673f8c400f34cb9ff2d585e7dd1c2990ece97709c53","pages":5,"tokens":1174,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":418,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nPJM Interconnection, L.L.C.\n) \nDocket No. EL26-67-000 \nANSWER OF CONSTELLATION ENERGY GENERATION, LLC  \nConstellation1 submits this answer to support PJM’s motion to hold the Large Load Show \nCause Order2 proceeding in abeyance with one clarification:3 that PJM remains obligated to file \non August 17, 2026, a complete set of provisions to facilitate Interim Network Integration \nTransmission Service (“NITS”), that will allow for a prompt start of service.4 \nConstellation agrees that the implementation of Interim NITS should be prioritized and that \nContract Demand Services may proceed on a separate track.5 Quickly implementing Interim NITS \nfor new and pending large load applicants is the fastest approach to “release the bottleneck of large \nload investments across the PJM footprint”6 and obtain national and economic security. Unlike \n \n1 Constellation Energy Generation, LLC (“Constellation”) files this answer pursuant to Rule 213 of the Commission’s \nRules of Practice and Procedure. See 18 C.F.R. § 385.213. \n2 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“Large Load Show Cause Order”). \n3 Motion of PJM Interconnection, L.L.C. to Hold Proceeding in Abeyance and Request for Shortened Answer Period \nand Expedited Treatment (July 28, 2026) (“Motion for Abeyance”). \n4 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026) (“June 2026 Co-Location Order”). In the Co-Location \nproceeding, PJM requests an extension to comply with Commission directives other than “certain defined terms in \nTariff, Part I; certain terms for NITS pursuant to Tariff, Part III; additional details regarding the Necessary Study \nprocess that will be specified in the manuals; and the provision of interim NITS.” Motion for Extension of Time for \nSpecified Compliance Requirements and Request for Expedited Treatment of PJM Interconnection, L.L.C., Docket \nNo. EL25-49-000, et al., at 7 (July 28, 2026) (“Motion for Extension of Time”). \n5 See, e.g., Reply Brief of Constellation Energy Generation, LLC, Docket No. EL25-49-000, at 3 (Mar. 25, 2026) \n(“Additional time is not needed for Interim NITS, which is ‘[g]enerally speaking’ the same as NITS.”) (quoting \nInitial Brief of PJM Interconnection, L.L.C. at 67 (Feb. 23, 2026)); id. (“the Commission can allow more time if \nneeded, on a separate track, to establish the rates and terms of new Contract Demand Services”). \n6 FERC, FERC Directs Nation’s Largest Grid Operator to Create New Rules to Embrace Innovation and Protect \nConsumers (Dec. 18, 2025), https://www.ferc.gov/news-events/news/ferc-directs-nations-largest-grid-operator-\ncreate-new-rules-embrace-innovation-and?new= (quoting Chairman Swett)."},{"page":2,"startToken":418,"endToken":752,"text":"2 \nInterim NITS, which is “basically”7 NITS, developing the terms and conditions for Contract \nDemand Services may require an additional 90 days. \nIf the Commission grants PJM’s motion, it should clarify that PJM remains obligated to \nmake all directed changes to Interim NITS as applicable to Eligible Customers taking service on \nbehalf of Co-Located Loads, including that PJM: \n Reconsider its proposed June 1, 2029 effective date given that the interconnection \nof large loads is an “urgent” issue that “merit[s] serious consideration” of an \naccelerated timeframe, and explain whether Interim NITS can be “effective at an \nearlier date;”8 \n Explain “what new and existing interconnection requirements and operational \npractices” are “needed for necessary control technologies and/or protection \nsystems” for Eligible Customers taking Interim NITS;9 \n Specify “curtailment priorities” for Interim NITS, and detail how PJM will \n“prioritize” Interim NITS customers for curtailment based on “duration of \nservice;”10 and \n Automatically “convert” an Eligible Customer taking Interim NITS to a Network \nCustomer when Network Upgrades are completed.11 \nThe Large Load Show Cause Order does not excuse PJM from including a full set of rates, \nterms, and conditions to facilitate the prompt implementation of service. Furthermore, while the \nCo-Located Load and Large Load proceedings have overlapping concepts,12 they are separate \nproceedings with distinct compliance obligations that PJM must not conflate,13 especially when \n \n7 Reply Brief of PJM Interconnection, L.L.C., Docket No. EL25-49-000, et al., at 1 (Apr. 24, 2026). \n8 June 2026 Co-Location Order, 195 FERC ¶ 61,209 at P 597. \n9 Id. P 482. \n10 Id. P 555. \n11 Id. P 571. \n12 See Motion for Abeyance at 1 (calling the Large Load Show Cause Order and the June 2026 Co-Location Order \n“interrelated”); Motion for Extension of Time at 7 (same). \n13 See June 2026 Co-Location Order, 195 FERC ¶ 61,209 at P 107 (“In an order issued concurrently, the Commission \nis initiating a separate show cause proceeding in Docket No. EL26-67-000 to address, among other things, whether"},{"page":3,"startToken":752,"endToken":963,"text":"3 \nPJM did not seek rehearing.14 In other words, while Constellation supports PJM’s motion to \npartially delay its obligation to comply with the June 2026 Co-Location Order, that obligation is \nnot dependent on any PJM stakeholder or other outcome in the Large Load Show Cause \nproceeding. \nCONCLUSION \nFor the reasons stated above, Constellation respectfully requests that the Commission grant \nPJM’s Motion for Abeyance with the clarification that PJM’s obligation in the Co-Location \nproceeding to file complete provisions on Interim NITS by August 17, 2026, is unchanged. \n \nthe Tariff remains just and reasonable and not unduly discriminatory or preferential without provisions addressing \ntransmission services that reflect flexible large loads that are willing and able to limit their energy withdrawals from \nthe transmission system under certain conditions. Accordingly, it is beyond the scope of this proceeding—and within \nthe scope of the separate proceeding—to argue that the new transmission services should be extended to Eligible \nCustomers taking transmission service on behalf of flexible large loads.”) (citation omitted). \n14 PJM Interconnection, L.L.C., 195 FERC ¶ 61,030 (2026) (rejecting in part PJM’s compliance filing for \nimpermissibly changing the definition of Co-Located Load adopted in the Commission’s underlying order, noting \nthat “no party, including PJM, sought rehearing or clarification” of that definition)."},{"page":4,"startToken":963,"endToken":1092,"text":"4 \n \n \n \n \n \n \n \n    Respectfully submitted, \n \n \n \n \n \n \n \n    /s/ Paul F. Wight \n \n \nAugust 3, 2026 \nCarrie Hill Allen \nSr. Vice President & Deputy General Counsel \nSeth T. Lucia \nAssistant General Counsel \nConstellation Energy Generation, LLC \n250 Massachusetts Ave. NW, Suite 760 \nWashington, D.C. 20001 \ncarrie.allen@constellation.com \nseth.lucia@constellation.com \n  \nChristopher A. Wilson \nVice President, Federal Regulatory Affairs \nConstellation Energy Generation, LLC \n250 Massachusetts Ave. NW, Suite 760 \nWashington, D.C. 20001 \n202-347-7500 \nFERCe-filings1@constellation.com \n \nPaul F. Wight \nCarolyn E. Clarkin \nDLA Piper LLP (US) \n500 Eighth Street NW \nWashington, D.C. 20004 \n703-773-4058 \npaul.wight@us.dlapiper.com  \ncarolyn.clarkin@us.dlapiper.com  \n \nSophia Browning \nDLA Piper LLP (US) \n4365 Executive Drive \nSuite 1100 \nSan Diego, CA 92121 \n858-677-1455 \nsophia.browning@us.dlapiper.com \n \nCounsel for Constellation Energy \nGeneration, LLC"},{"page":5,"startToken":1092,"endToken":1174,"text":"CERTIFICATE OF SERVICE \nI hereby certify that I have on this 3rd day of August, 2026, caused to be served a copy of \nthe foregoing upon all parties on the service lists in these proceedings in accordance with the \nrequirement of Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. \n§ 385.2010 (2026). \n/s/ Sophia Browning \n \n \nSophia Browning \nDLA Piper LLP (US) \n4365 Executive Drive \nSuite 1100 \nSan Diego, CA 92121 \n858-677-1455 \nsophia.browning@us.dlapiper.com"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":131,"startToken":0,"endToken":18},{"p":1,"at":131,"title":"ANSWER OF CONSTELLATION ENERGY GENERATION, LLC","method":"PDF bookmark","endPage":3,"endAt":291,"startToken":18,"endToken":799},{"p":3,"at":291,"title":"CONCLUSION","method":"PDF bookmark","endPage":5,"endAt":0,"startToken":799,"endToken":1092},{"p":5,"at":0,"title":"CERTIFICATE OF SERVICE","method":"PDF bookmark","endPage":5,"endAt":485,"startToken":1092,"endToken":1174}]}