EL26-67-000 · 2026-08-03 · Constellation Energy Generation, LLC

Answer of Constellation Energy Generation, LLC in support of PJM Interconnection, L.L.C.'s Motion for Abeyance

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
PJM Interconnection, L.L.C.
) 
Docket No. EL26-67-000 
ANSWER OF CONSTELLATION ENERGY GENERATION, LLC  
Constellation1 submits this answer to support PJM’s motion to hold the Large Load Show 
Cause Order2 proceeding in abeyance with one clarification:3 that PJM remains obligated to file 
on August 17, 2026, a complete set of provisions to facilitate Interim Network Integration 
Transmission Service (“NITS”), that will allow for a prompt start of service.4 
Constellation agrees that the implementation of Interim NITS should be prioritized and that 
Contract Demand Services may proceed on a separate track.5 Quickly implementing Interim NITS 
for new and pending large load applicants is the fastest approach to “release the bottleneck of large 
load investments across the PJM footprint”6 and obtain national and economic security. Unlike 
 
1 Constellation Energy Generation, LLC (“Constellation”) files this answer pursuant to Rule 213 of the Commission’s 
Rules of Practice and Procedure. See 18 C.F.R. § 385.213. 
2 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“Large Load Show Cause Order”). 
3 Motion of PJM Interconnection, L.L.C. to Hold Proceeding in Abeyance and Request for Shortened Answer Period 
and Expedited Treatment (July 28, 2026) (“Motion for Abeyance”). 
4 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026) (“June 2026 Co-Location Order”). In the Co-Location 
proceeding, PJM requests an extension to comply with Commission directives other than “certain defined terms in 
Tariff, Part I; certain terms for NITS pursuant to Tariff, Part III; additional details regarding the Necessary Study 
process that will be specified in the manuals; and the provision of interim NITS.” Motion for Extension of Time for 
Specified Compliance Requirements and Request for Expedited Treatment of PJM Interconnection, L.L.C., Docket 
No. EL25-49-000, et al., at 7 (July 28, 2026) (“Motion for Extension of Time”). 
5 See, e.g., Reply Brief of Constellation Energy Generation, LLC, Docket No. EL25-49-000, at 3 (Mar. 25, 2026) 
(“Additional time is not needed for Interim NITS, which is ‘[g]enerally speaking’ the same as NITS.”) (quoting 
Initial Brief of PJM Interconnection, L.L.C. at 67 (Feb. 23, 2026)); id. (“the Commission can allow more time if 
needed, on a separate track, to establish the rates and terms of new Contract Demand Services”). 
6 FERC, FERC Directs Nation’s Largest Grid Operator to Create New Rules to Embrace Innovation and Protect 
Consumers (Dec. 18, 2025), https://www.ferc.gov/news-events/news/ferc-directs-nations-largest-grid-operator-
create-new-rules-embrace-innovation-and?new= (quoting Chairman Swett).

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Interim NITS, which is “basically”7 NITS, developing the terms and conditions for Contract 
Demand Services may require an additional 90 days. 
If the Commission grants PJM’s motion, it should clarify that PJM remains obligated to 
make all directed changes to Interim NITS as applicable to Eligible Customers taking service on 
behalf of Co-Located Loads, including that PJM: 
 Reconsider its proposed June 1, 2029 effective date given that the interconnection 
of large loads is an “urgent” issue that “merit[s] serious consideration” of an 
accelerated timeframe, and explain whether Interim NITS can be “effective at an 
earlier date;”8 
 Explain “what new and existing interconnection requirements and operational 
practices” are “needed for necessary control technologies and/or protection 
systems” for Eligible Customers taking Interim NITS;9 
 Specify “curtailment priorities” for Interim NITS, and detail how PJM will 
“prioritize” Interim NITS customers for curtailment based on “duration of 
service;”10 and 
 Automatically “convert” an Eligible Customer taking Interim NITS to a Network 
Customer when Network Upgrades are completed.11 
The Large Load Show Cause Order does not excuse PJM from including a full set of rates, 
terms, and conditions to facilitate the prompt implementation of service. Furthermore, while the 
Co-Located Load and Large Load proceedings have overlapping concepts,12 they are separate 
proceedings with distinct compliance obligations that PJM must not conflate,13 especially when 
 
7 Reply Brief of PJM Interconnection, L.L.C., Docket No. EL25-49-000, et al., at 1 (Apr. 24, 2026). 
8 June 2026 Co-Location Order, 195 FERC ¶ 61,209 at P 597. 
9 Id. P 482. 
10 Id. P 555. 
11 Id. P 571. 
12 See Motion for Abeyance at 1 (calling the Large Load Show Cause Order and the June 2026 Co-Location Order 
“interrelated”); Motion for Extension of Time at 7 (same). 
13 See June 2026 Co-Location Order, 195 FERC ¶ 61,209 at P 107 (“In an order issued concurrently, the Commission 
is initiating a separate show cause proceeding in Docket No. EL26-67-000 to address, among other things, whether

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PJM did not seek rehearing.14 In other words, while Constellation supports PJM’s motion to 
partially delay its obligation to comply with the June 2026 Co-Location Order, that obligation is 
not dependent on any PJM stakeholder or other outcome in the Large Load Show Cause 
proceeding. 
CONCLUSION 
For the reasons stated above, Constellation respectfully requests that the Commission grant 
PJM’s Motion for Abeyance with the clarification that PJM’s obligation in the Co-Location 
proceeding to file complete provisions on Interim NITS by August 17, 2026, is unchanged. 
 
the Tariff remains just and reasonable and not unduly discriminatory or preferential without provisions addressing 
transmission services that reflect flexible large loads that are willing and able to limit their energy withdrawals from 
the transmission system under certain conditions. Accordingly, it is beyond the scope of this proceeding—and within 
the scope of the separate proceeding—to argue that the new transmission services should be extended to Eligible 
Customers taking transmission service on behalf of flexible large loads.”) (citation omitted). 
14 PJM Interconnection, L.L.C., 195 FERC ¶ 61,030 (2026) (rejecting in part PJM’s compliance filing for 
impermissibly changing the definition of Co-Located Load adopted in the Commission’s underlying order, noting 
that “no party, including PJM, sought rehearing or clarification” of that definition).

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    Respectfully submitted, 
 
 
 
 
 
 
 
    /s/ Paul F. Wight 
 
 
August 3, 2026 
Carrie Hill Allen 
Sr. Vice President & Deputy General Counsel 
Seth T. Lucia 
Assistant General Counsel 
Constellation Energy Generation, LLC 
250 Massachusetts Ave. NW, Suite 760 
Washington, D.C. 20001 
carrie.allen@constellation.com 
seth.lucia@constellation.com 
  
Christopher A. Wilson 
Vice President, Federal Regulatory Affairs 
Constellation Energy Generation, LLC 
250 Massachusetts Ave. NW, Suite 760 
Washington, D.C. 20001 
202-347-7500 
FERCe-filings1@constellation.com 
 
Paul F. Wight 
Carolyn E. Clarkin 
DLA Piper LLP (US) 
500 Eighth Street NW 
Washington, D.C. 20004 
703-773-4058 
paul.wight@us.dlapiper.com  
carolyn.clarkin@us.dlapiper.com  
 
Sophia Browning 
DLA Piper LLP (US) 
4365 Executive Drive 
Suite 1100 
San Diego, CA 92121 
858-677-1455 
sophia.browning@us.dlapiper.com 
 
Counsel for Constellation Energy 
Generation, LLC

CERTIFICATE OF SERVICE 
I hereby certify that I have on this 3rd day of August, 2026, caused to be served a copy of 
the foregoing upon all parties on the service lists in these proceedings in accordance with the 
requirement of Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. 
§ 385.2010 (2026). 
/s/ Sophia Browning 
 
 
Sophia Browning 
DLA Piper LLP (US) 
4365 Executive Drive 
Suite 1100 
San Diego, CA 92121 
858-677-1455 
sophia.browning@us.dlapiper.com