Comments of PJM Industrial Customer Coalition on PJM Interconnection, L.L.C.’s Reliability Backstop Procurement Proposal
Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Reliability and curtailment · Connecting load and generation
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Opening text
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ER26-3380-000 : COMMENTS ON PJM’S RELIABILITY BACKSTOP PROCUREMENT PROPOSAL ON BEHALF OF PJM INDUSTRIAL CUSTOMER COALITION Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) August 3, 2026, Combined Notice of Filings #1, the PJM Industrial Customer Coalition (“PJMICC”…Read this passage
I. INTRODUCTION
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I.Read this passage
INTRODUCTION
printed heading · Topic match: Reliability and curtailment
INTRODUCTION As described by PJM, the Reliability Backstop Procurement (“RBP”) is a “one-time procurement of new capacity to address resource adequacy challenges in the PJM Region arising from insufficient commitments of capacity in the 2027/2028 and 2028/2029 Reliability Pricing Model (‘RPM’)…Read this passage Filed comments: Reliability and curtailment
II. BACKGROUND
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II.Read this passage
BACKGROUND
printed heading · Topic match: Cost allocation
See also id. at 29 (“the proposed RBP is intended to occur concurrently, on a parallel path, with an ongoing bilateral matching process that credits new capacity being brought by new large loads and therefore guards against double procurement in the RBP”). 3 ultimate retail cost allocation…Read this passage Filed comments: Cost allocation
III. PJMICC COMMENTS
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III.Read this passage
A. The RBP, as proposed, is incomplete because it lacks key protections and components to enable alignment of wholesale and retail cost allocation.
PDF bookmark · Topic match: Cost allocation
The RBP, as proposed, is incomplete because it lacks key protections and components to enable alignment of wholesale and retail cost allocation.Read this passage Filed comments: Cost allocation
B. Gap #1: Cost Allocation Alignment: Effective cooperative federalism must position states and retail customers for success by providing appropriate alignment between wholesale and retail costs.
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Gap #1: Cost Allocation Alignment: Effective cooperative federalism must position states and retail customers for success by providing appropriate alignment between wholesale and retail costs.Read this passage Filed comments: Cost allocation
C. Gap #2: Regulatory Accountability: Assignment of costs to retail customers by utilities must be on file before a state commission or FERC.
PDF bookmark · Topic match: Cost allocation
Gap #2: Regulatory Accountability: Assignment of costs to retail customers by utilities must be on file before a state commission or FERC.Read this passage Filed comments: Cost allocation
Attachment M-2s stand at the border between state and federal regulatory responsibility.
printed heading · Topic match: Cost allocation
While the FERC may not direct retail cost allocation, it has jurisdiction over rules and regulations “affecting or pertaining to [jurisdictional] rates and charges”10 Utilities must be required to set 9 PJM keeps an inventory of methodologies on its website.Read this passage Filed comments: Cost allocation
D. Gap #3: Information-Sharing: Clear tagging of RBP participation and relevant carveouts.
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Additionally, states must know well in advance what information they will have access to as they design cost allocation at the retail level.Read this passage Filed comments: Cost allocation
IV. CONCLUSION
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IV.Read this passage
CONCLUSION
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CONCLUSION WHEREFORE, the PJM Industrial Customer Coalition respectfully requests the Commission to consider these Comments when evaluating PJM’s Reliability Backstop Procurement proposal.Read this passage
CERTIFICATE OF SERVICE
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Dated this 21st day of August, 2026. /s/ Matthew L.Read this passage