ER26-3380-000 · 2026-08-14 · PJM Interconnection, L.L.C.

PJM Interconnection, L.L.C. submits tariff filing per : Supplemental Filing of Croop Affidavit in ER26-3380 to be effective N/A

PJM Interconnection, L.L.C. 
2750 Monroe Blvd. 
Audubon, PA 19403-2497 
 
Chenchao Lu 
Associate General Counsel  
T:  (610)-500-3245  
Chenchao.Lu@pjm.com 
 
 
 
 
August 14, 2026 
 
Honorable Debbie-Anne A. Reese, Secretary 
Federal Energy Regulatory Commission 
888 First Street, N.E.,  
Washington, D.C. 20426 
 
Re: 
Supplemental Filing in PJM Interconnection, L.L.C., Docket No. ER26-3380-000 
 
Dear Secretary Reese: 
 
PJM Interconnection, L.L.C. (“PJM”) submits this supplemental affidavit of Danielle 
Croop to provide a more complete example of the selection process detailed in the June 30, 2026 
affidavit.  Specifically, it has come to PJM’s attention that the example provided in Exhibit 1 of 
Mrs. Croop’s June 30, 2026 affidavit did not accurately demonstrate the least cost selection by 
Delivery Year for offers submitted in the proposed Reliability Backstop Procurement.  Therefore, 
to provide the Commission and any interested parties with a more fulsome example, PJM submits 
the attached supplemental affidavit that further demonstrates how PJM would select resource 
offers based on least costs while prioritizing in service dates during the selection process.   
Notably, the supplemental affidavit merely updates the examples, also shown in redline, 
that were included in Mrs. Croop’s June 30, 2026 affidavit and does not revise or amend a proposed 
rate schedule, term, or condition.  Indeed, the Commission has previously explained that 
“supplements d[o] not constitute an amendment because the supplements d[o] not change the 
proposed rates. . . .”1  As a result, this supplemental affidavit does not reset the clock for the 
 
1 Union Elec. Co., 181 FERC ¶ 61,064, at P 40 (2022) (finding that MISO’s supplements did not constitute an 
amendment because the supplements did not change the proposed rates that MISO filed).

Honorable Debbie-Anne A. Reese, Secretary 
August 14, 2025 
Page 2 
 
Commission to act on PJM’s June 30, 2026 filing as all parties were on notice of the proposed 
rates, terms and conditions based on the June 30, 2026 filing.2  Accordingly, the Commission 
should continue to issue an order by the requested action date of September 29, 2026. 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
  /s/ Chenchao Lu 
 
 
Craig Glazer 
Vice President – Federal Government Policy 
PJM Interconnection, L.L.C. 
1200 G Street, N.W., Suite 600 
Washington, D.C.  20005 
(202) 423-4743 (phone) 
(202) 393-7741 (fax) 
Craig.Glazer@pjm.com  
 
Chenchao Lu 
Associate General Counsel 
PJM Interconnection, L.L.C. 
2750 Monroe Blvd. 
Audubon, PA  19403 
(610) 666-2255 (phone) 
(610) 666-8211 (fax) 
Chenchao.Lu@pjm.com    
 
 
 
Counsel for 
 
PJM Interconnection, L.L.C. 
 
2 Sierra Pacific Power Co., 141 FERC ¶ 61,266, at P 39 (2012) (“Filings ... that do not revise a rate schedule, tariff, 
or service agreement, but instead only add or revise supplemental materials submitted as part of the application are 
considered on an individual basis to determine whether such changes are so significant that they would constitute an 
amendment ....”); Miss. Power Co., 137 FERC ¶ 61,241, at P 23 (2011).

CERTIFICATE OF SERVICE 
 
 
I hereby certify that I have this day served the foregoing document upon each 
person designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Audubon, PA, this 14th day of August 2026. 
 
 /s/ Chenchao Lu 
 
 
Chenchao Lu 
Associate General Counsel 
PJM Interconnection, L.L.C. 
2750 Monroe Blvd. 
Audubon, PA  19403 
Chenchao.Lu@pjm.com

Attachment A 
 
 
 
 
 
 
 
Supplemental Affidavit of Ms. Danielle Croop, 
Senior Manager in the Market Design group of 
PJM Interconnection, L.L.C.

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
 
 
 
 
) 
PJM Interconnection, L.L.C. 
 
) 
 
Docket No. ER26-3380-000 
 
 
 
 
 
 
) 
 
SUPPLEMENTAL AFFIDAVIT OF DANIELLE CROOP 
ON BEHALF OF PJM INTERCONNECTION, L.L.C. 
1. 
My name is Danielle Croop, Senior Manager in the Market Design group for PJM 
Interconnection, L.L.C. (“PJM”).  My business address is 2750 Monroe Blvd., 
Audubon, Pennsylvania, 19403.  I am submitting this supplemental affidavit on 
behalf of PJM to provide a clarifying example that better illustrates all components 
of the commitment process which is:  clearing in least-cost order while prioritizing 
earlier Delivery Years and constraining the commitment by the maximum 
willingness to pay. 
 
2. 
The example submitted under Exhibit No 1 from my June 30, 2026 affidavit was 
focused on documenting the procurement approach of applying the maximum 
willingness to pay and demonstrating how that constraint can impact the 
procurement.  However, in that example, the least cost selection by delivery year 
was not demonstrated. 
 
3. 
This supplemental affidavit sponsors an updated exhibit, appended to my affidavit 
as Exhibit 1 to illustrate three simplified examples that help demonstrate how the 
Reliability Backstop Procurement selection process works.  Separately, Exhibit 2 
shows the redlines against the example that was originally included in my June 30, 
2026 affidavit. 
 
4. 
In addition, the explanation in Step 2 of the example submitted under Exhibit No 1 
from my June 30, 2026 affidavit regarding the calculation of the MW-weighted 
average levelized cost incorrectly inverted the numerator and denominator. The 
explanation has been revised in this supplemental affidavit to accurately reflect the 
MW-weighted average levelized cost calculation set forth in the filing letter and 
proposed tariff revisions.

Exhibit 1 
 
 
 
 
 
 
Appendix to Affidavit of Ms. Danielle Croop 
 
Examples Demonstrating RBP Resource Procurement 
Process 
 
(Clean Version)

EXHIBIT 1 
Examples Demonstrating RBP Resource Procurement Process 
In this example, each RBP Resource Sell Offer will include an offer price and MW quantity pair 
for each Delivery Year beginning with the first year the resource is expected to reach 
commercial operation.  PJM will then determine the “levelized procurement cost” for this 
resource to use in the selection process.1  This will be done with the Levelized Cost equation, 
with a discount rate equal to 9.5% after-tax average weighted average cost of capital 
(“ATWACC”).  
Levelized Cost ($/MW-day) = Net Present Value (RBP Sell Offer price x UCAP offered)/Net 
Present Value (UCAP offered)  
 
Example 1 
In the example below, Unit A offers at a price and a quantity for each Delivery Year of the 15-
year fixed term, beginning in Year 1 and ending in Year 15.  This Offer has a levelized 
procurement cost of $101.05/MW-day UCAP and a levelized MW value of 69.3 MW. 
Example 1: Unit A, $/MW Offer per Year 
 
Unit A 
Price ($) 
MW 
Year 1 
91 
10 
Year 2 
91 
10 
Year 3 
100 
9 
Year 4 
100 
9 
Year 5 
100 
9 
Year 6 
100 
9 
Year 7 
100 
9 
Year 8 
110 
8 
Year 9 
110 
8 
Year 
10 
110 
8 
 
1 Proposed TariƯ, Attachment DD, section 18.5(f)(ii); Croop AƯ. ¶ 29.

4 
Year 
11 
110 
8 
Year 
12 
110 
8 
Year 
13 
110 
8 
Year 
14 
110 
8 
Year 
15 
110 
8 
 
 
Example 2 
Example 2 walks through how a set of offers are evaluated based on ranked Delivery Year and 
levelized cost for selection. The selection process is also constrained to the maximum 
willingness to pay of the procurement.  For illustrative purposes, rather than a maximum 
willingness to pay of $555/MW-day as PJM is proposing to use for the RBP, we assume that the 
maximum willingness to pay is $100/MW-day, and the Final RBP Target for procurement is 
6,800 MW.   
Table 1 illustrates the UCAP MW offered through the first four Delivery Years and a represented 
levelized cost offer for this resource.  Table 1, below, tracks the MW that are procured to 
determine when PJM satisfies the procurement target of 6,800 MW.  
Table 1: Table updates include switch Offer 1 and 2 to reflect offers in rank-order for 
selection and Offer 3 was updated to offer starting in the 2028/29 DY.

5 
Table 2 shows the offers in greater detail in determining the present value and levelized cost of 
the offers.  For each RBP Resource offer (Offers 1-8), there are three procurement values in the 
NPV column.  The first value for each RBP Resource offer is the levelized MW UCAP.  The 
second value is the levelized cost, expressed as $/MW-day.  And the third value is the total 
revenue cost stream based on the RBP Resource’s levelized MW and cost.  
Table 2 
 
The procurement process will prioritize earlier Delivery Years, while being constrained to the 
fixed-budget maximum willingness to pay.  This can result in: (1) an earlier Delivery Year 
resource being skipped if it will violate the maximum willingness to pay constraint; (2) a 
procurement of that resource later in the process, even if the resource was previously skipped, if 
procurement of a lower-priced resource creates additional cost headroom in the budget; and/or 
(3) a possibility that PJM will not procure the exact Final RBP Target quantity if doing so 
violates the maximum willingness to pay constraint.  These features are demonstrated below in 
the selection sequencing example: 
Step 1: Procure Offer 1. Offer 1 would be procured first in the commitment, given it has the 
cheapest levelized cost in the delivery year.  This will add the below MW value to the target for 
each Delivery Year, with a MW-weighted average levelized costs of  $50.

6 
 
Step 2: Procure Offer 2. This will increase our procurement by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.26.  
 
The MW-weighted average levelized cost of $93.26 can be calculated from the PV column in 
Table 2 as the  sum of Revenue cost stream / sum of levelized MW.  [932,200 + 72,645]/ 
[9,322+1,453]. 
 
Step 3: Skip Offer 3. If Offer 3 was selected the MW-weighted average levelized cost would rise 
to $105.75, above the maximum willingness to pay of $100 MW/day. 
Step 4: Procure Offer 4. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $80.50. 
 
Step 5: Procure Offer 3.  Offer 3 may now be procured while keeping the MW-weighted average 
levelized cost under the maximum willingness to pay.  Thus, the procurement will prioritize and 
commit this resource with an earlier first Delivery Year.  This will increase the procured MW by 
the offered MW for each applicable Delivery Year, and result in a MW-weighted average 
levelized cost of $90.71.

7 
Step 6: Procure Offer 5. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $90.63.  
 
Step 7: Procure Offer 6. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.02.  
 
At this point, the final target MW of 6,800 has been committed and the procurement is complete.  
Offer 7 and 8 would not be procured through the RBP.  
Example 3 
In Example 3, the selection clears short of the Final RBP Target to maintain the maximum 
willingness to pay.  This example relies on the same example as above, except that offer prices 
for Offers 6, 7, and 8 are dramatically increased.

8 
Table 3 
 
The procurement process runs through Steps 1 through 6, as described in Example 2, above.  
Then, following Step 6, the process begins to differ:  
Step 6: Procure Offer 5, as in Example 2. This will increase the procured MW by the offered 
MW for each applicable Delivery Year, and result in a MW-weighted average levelized cost of 
$90.63. 
 
At this point, Offers 6, 7 and 8 cannot be procured without violating the maximum willingness to 
pay constraint.  If Offer 6 were selected, the MW-weighted average levelized cost would rise to 
$106.73 , which is above the maximum willingness to pay of $100 MW/day.  Similar violations 
of the maximum willingness to pay for Offers 7, and 8 would occur.  Given that, in this example, 
there are no additional offers to consider, the procurement would clear 100 MW short the target, 
with the maximum UCAP MW procured equal to 6,700 MW for the 2031/32 Delivery Year.

Exhibit 2 
 
 
 
 
 
 
Appendix to Affidavit of Ms. Danielle Croop 
 
Examples Demonstrating RBP Resource Procurement 
Process 
 
(Redlined Version)

Croop, Exhibit No. 2 
Page 1 
 
Examples Demonstrating RBP Resource Procurement Process 
The following examples are intended to demonstrate how RBP Resources will be procured 
based on a maximum willingness to pay, defined as a “MW-weighted average of the levelized 
procurement cost” for the RBP, and selected through a “budget approach.”1  
In this example, Eeach RBP Resource Sell Offer will include an offer price and MW 
quantity pair for each Delivery Year beginning with the first year the resource is expected to reach 
commercial operation.  PJM will then determine the “levelized procurement cost” for this resource 
to use in the selection process.2  This will be done with the Levelized Cost equation, with a discount 
rate equal to 9.5% after-tax average weighted average cost of capital (“ATWACC”).  
Levelized Cost ($/MW-day) = Net Present Value (RBP Sell Offer price x UCAP 
offered)/Net Present Value (UCAP offered)  
 
Example 1 
In the example below, Unit A offers at a price and a quantity for each Delivery Year of the 
15-year fixed term, beginning in Year 1 and ending in Year 15.  This Offer has a levelized 
procurement cost of $101.0550/MW-day UCAP and a levelized MW value of 69.3 MW. 
 
1 Proposed Tariff, Attachment DD, section 18.5(f)(ii); Croop Aff. ¶ 29. 
2 Proposed Tariff, Attachment DD, section 18.5(f)(ii); Croop Aff. ¶ 29.

Croop, Exhibit No. 2 
Page 2 
 
Example 1: Unit A, $/MW Offer per Year 
 
Unit A 
Price ($) 
MW 
Year 1 
91 
10 
Year 2 
91 
10 
Year 3 
100 
9 
Year 4 
100 
9 
Year 5 
100 
9 
Year 6 
100 
9 
Year 7 
100 
9 
Year 8 
110 
8 
Year 9 
110 
8 
Year 10 
110 
8 
Year 11 
110 
8 
Year 12 
110 
8 
Year 13 
110 
8 
Year 14 
110 
8 
Year 15 
110 
8 
 
 
Example 2 
Example 2 walks through how a set of offers are evaluated based on ranked Delivery Year 
and levelized cost for selection. The selection process is also constrained to the maximum 
willingness to pay of the procurement.  For illustrative purposes, rather than a maximum 
willingness to pay of $555/MW-day as PJM is proposing to use for the RBP, we assume that the 
maximum willingness to pay is $100/MW-day, and the Final RBP Target for procurement is 
6,800 MW.   
Table 1 illustrates the UCAP MW offered through the first four Delivery Years and a 
represented levelized cost offer for this resource.  Table 1, below, tracks the MW that are procured 
to determine when PJM satisfies the procurement target of 6,800 MW.

Croop, Exhibit No. 2 
Page 3 
 
Table 1: Table updates include switch Offer 1 and 2 to reflect offers in rank-order for selection and Offer 3 was updated to offer 
starting in the 2028/29 DY.  
 
 
 
Table 2 shows the offers in greater detail in determining the present value and levelized cost of the 
offers.  For each RBP Resource offer (Offers 1-8), there are three procurement values in the NPV 
column.  The first value for each RBP Resource offer is the levelized MW UCAP.  The second 
value is the levelized cost, expressed as $/MW-day.  And the third value is the total revenue cost 
stream based on the RBP Resource’s levelized MW and cost.

Croop, Exhibit No. 2 
Page 4 
 
Table 2 
 
The procurement process will prioritize earlier Delivery Years, while being constrained to the 
fixed-budget maximum willingness to pay.  This can result in: (1) an earlier Delivery Year resource 
being skipped if it will violate the maximum willingness to pay constraint; (2) a procurement of 
that resource later in the process, even if the resource was previously skipped, if procurement of a 
lower-priced resource creates additional cost headroom in the budget; and/or (3) a possibility that 
PJM will not procure the exact Final RBP Target quantity if doing so violates the maximum 
willingness to pay constraint.  These features are demonstrated below in the selection sequencing 
example: 
Step 1: Procure Offer 1. Offer 1 would be procured first in the commitment, given it has 
the cheapest levelized cost in the delivery year.  This will add the below MW value to the target 
for each Delivery Year, with a MW-weighted average levelized costs of  $50 $100.

Croop, Exhibit No. 2 
Page 5 
 
 
Step 2: Procure Offer 2. This will increase our procurement by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.26.  
 
The MW-weighted average levelized cost of $93.26 can be calculated from the PV column in 
Table 2 as the sum of levelized MW / sum of Revenue cost stream / sum of levelized MW.  
[9,322+1,453]/[932,200 + 72,645]/ [9,322+1,453]. 
Step 3: Skip Offer 3. If Offer 3 was selected the MW-weighted average levelized cost 
would rise to $105.75 $102.84, above the maximum willingness to pay of $100 MW/day. 
Step 4: Procure Offer 4. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $80.50. 
 
Step 5: Procure Offer 3.  Offer 3 may now be procured while keeping the MW-weighted 
average levelized cost under the maximum willingness to pay.  Thus, the procurement will

Croop, Exhibit No. 2 
Page 6 
 
prioritize and commit this resource with an earlier first Delivery Year.  This will increase the 
procured MW by the offered MW for each applicable Delivery Year, and result in a MW-weighted 
average levelized cost of $90.71 $88.27. 
 
Step 6: Procure Offer 5. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $90.63. $88.47. 
 
Step 7: Procure Offer 6. This will increase the procured MW by the offered MW for each 
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.02 $90.94

Croop, Exhibit No. 2 
Page 7 
 
At this point, the final target MW of 6,800 has been committed and the procurement is complete.  
Offer 7 and 8 would not be procured through the RBP.  
Example 3 
In Example 3, the selection clears short of the Final RBP Target to maintain the maximum 
willingness to pay.  This example relies on the same example as above, except that offer prices for 
Offers 6, 7, and 8 are dramatically increased.   
Table 3 
 
The procurement process runs through Steps 1 through 65, as described in Example 2, above.  
Then, starting following in Step 6, the process begins to differ:

Croop, Exhibit No. 2 
Page 8 
 
Step 6: Procure Offer 5, as in Example 2. This will increase the procured MW by the 
offered MW for each applicable Delivery Year, and result in a MW-weighted average levelized 
cost of $90.63$88.47. 
 
At this point, Offers 6, 7 and 8 cannot be procured without violating the maximum 
willingness to pay constraint.  If Offer 6 were selected, the MW-weighted average levelized cost 
would rise to $106.73 $104.91, which is above the maximum willingness to pay of $100 MW/day.  
Similar violations of the maximum willingness to pay for Offers 7, and 8 would occur.  Given that, 
in this example, there are no additional offers to consider, the procurement would clear 100 MW 
short the target, with the maximum UCAP MW procured equal to 6,700 MW for the 2031/32 
Delivery Year.

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
) 
PJM Interconnection, L.L.C. 
 
)                              Docket No. ER26-3380-000 
                                                                        ) 
 
 
 
VERIFICATION 
 
I, Danielle Croop, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that I am 
the Danielle Croop referred to in the foregoing document entitled “Affidavit of Danielle Croop, 
on Behalf of PJM Interconnection, L.L.C.,” that I have read the same and am familiar with the 
contents thereof, and that the facts set forth therein are true and correct to the best of my 
knowledge, information, and belief. 
 
/s/ Danielle Croop  
 
Danielle Croop 
Sr. Manager 
Market Design 
PJM Interconnection, L.L.C.