EL26-67-000 · 2026-08-04 · Constellation Energy Generation, LLC

Answer of Constellation Energy Generation, LLC in response to Transmission Owner's 07/20/2026 Request for Clarification

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 
Constellation submits this answer1 to respond to the Transmission Owners’ Request for 
Clarification2 of the Large Load Show Cause Order.3 The Transmission Owners also request 
rehearing in the above-captioned proceeding, and although Constellation disagrees with the 
Transmission Owners’ rehearing arguments, including those in Exelon and FirstEnergy’s joint 
rehearing request,4 Constellation does not respond here because Exelon and FirstEnergy’s 
arguments are premature and barred by Rule 713 of the Commission’s Rules of Practice and 
Procedure.5 
The Transmission Owners request that with respect to the obligation to define “rates, terms, 
and conditions applicable to interconnection customers serving ‘electrically proximate large load’ 
 
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. The Commission should accept Constellation’s answer 
to the Indicated PJM Transmission Owners’ requests for clarification because “[a]nswers to requests for 
clarifications are not barred by Rule 713 of the Commission’s Rules of Practice and Procedure.” Savion, LLC v. 
PJM Interconnection, L.L.C., 194 FERC ¶ 61,240, at P 16 n.40 (2026). 
2 Request for Clarification, or in the Alternative, Rehearing of the Indicated PJM Transmission Owners (July 20, 2026) 
(“Transmission Owners’ Request for Clarification”). The Indicated Transmission Owners that filed the Transmission 
Owners’ Request for Clarification are a subset of Transmission Owners in PJM, excluding Old Dominion Electric 
Cooperative, Public Service Electric and Gas Company and Southern Maryland Electric Cooperative, for example. 
3 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“Large Load Show Cause Order”). 
4 Request for Rehearing of Exelon Corporation and FirstEnergy Service Company (July 20, 2026).  
5 18 C.F.R. § 385.713(a)(1) (stating rehearing may be requested “of a final Commission decision or other final order”); 
id. § 385.713(a)(2) (“a final decision in any proceeding … includes … any other action designated as a final decision 
by the Commission for purposes of rehearing”); Midcontinent Indep. Sys. Operator, Inc., 188 FERC ¶ 61,211, at 
P 12 (2024) (denying request for rehearing where “Commission did not make any final decision or determination in 
the Show Cause Order on whether the OATTs of the Responding RTOs/ISOs are unjust, unreasonable, or unduly 
discriminatory or preferential”); see also id. (“Where, as here, Commission action is not final and is to be succeeded 
by further Commission action, a request for rehearing may be dismissed”) (citation omitted); La. PSC v. Sys. Energy 
Res., Inc., 182 FERC ¶ 61,080, at P 6 (2023) (same); NorthWestern Corporation, 166 FERC ¶ 61,193, at P 7 (2019) 
(same).

2 
or co-located load”6 the Commission clarify that they will be permitted to propose and support a 
definition that is not based on the location of facilities relative to the Point of Interconnection, such 
as the Point of Change in Ownership.7 The Commission should not grant this clarification with 
respect to Co-Located Loads, as it has already ruled twice that the Point of Interconnection and 
not the Point of Change in Ownership is the appropriate point.8 This request for clarification is a 
thinly-veiled collateral attack on the Commission’s previous rulings in Docket Numbers ER26-
1088-000 and ER26-1479-000. 
In addition, the Commission should clarify that any eligibility requirements PJM and the 
Transmission Owners propose in their initial filings must not be so prescriptive as to improperly 
disqualify large loads, foreclosing any benefits that help avoid unnecessary transmission upgrades 
and reduce strain on the grid. The Commission should also clarify that Transmission Owners may 
not use the Point of Change in Ownership, or any other point of reference, to define “electrically 
proximate large load” in a manner that likewise undermines speedy interconnection or avoidance 
of unnecessary transmission upgrades. As the Co-Located Load proceeding demonstrates,9 clear 
direction from the Commission is necessary to ensure that PJM and Transmission Owners propose 
terms and conditions that facilitate, rather than frustrate, large load interconnections. 
 
6 Transmission Owners’ Request for Clarification at 2. 
7 Id. at 6-8. 
8 See June 2026 Co-Location Order, 195 FERC ¶ 61,209 at P 307 (denying PJM’s proposal to replace “Point of 
Interconnection” with “Point of Change in Ownership,” stating “[w]e note that no party, including PJM, sought 
rehearing or clarification of this directive, let alone the definition, in response to the December Order.”); PJM 
Interconnection, L.L.C., 195 FERC ¶ 61,030, at P 27 (2026) (same). 
9 See generally Reply Brief of Constellation Energy Generation, LLC, Docket No. EL25-49-000, et al., at 13 (Mar. 25, 
2026) (“PJM and Indicated Transmission Owners propose provisions that would restrict, delay or otherwise 
discourage the use of Interim NITS and Contract Demand Services.”); Response Brief of Constellation Energy 
Generation, Docket No. EL25-49-000, et al., at 2 (“Without delay, the Commission should reject and direct further 
compliance on PJM’s and the Transmission Owners’ proposals that restrict, discriminate, eliminate, or otherwise 
discourage the new transmission services.”).

3 
CONCLUSION 
For the reasons stated above, Constellation respectfully requests that the Commission deny 
the Transmission Owners’ Request for Clarification, but if the Commission nonetheless grants the 
request, it should make clear that PJM and the Transmission Owners should propose terms that 
encourage the use of new transmission services and the speedy interconnection of large loads. 
 
 
 
 
 
 
 
    Respectfully submitted, 
 
 
 
 
 
 
 
    /s/ Paul F. Wight 
 
 
August 4, 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 4th 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