{"document":{"slug":"filing-20260828-5287","title":"Motion for Extension of Time of the Organization of PJM States, Inc. to submit comments in response to PJM Interconnection, L.L.C.'s 08/13/2026 proposal","issued":"2026-08-28","accession":"20260828-5287","docket":"ER26-3515-000","group":"PJM filings","filer":"Organization of PJM States, Inc.","kind":"comments","file":"sources/originals/20260828-5287_01.pdf","url":"https://opsi.us/wp-content/uploads/2026/09/ER26-3515-000-IRAS-Extension-Request.pdf","sha256":"d4a2cb8b10279706c0ebe0b8586f25630a51e2b939c247b2a21790a216b11346","pages":4,"tokens":820,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":353,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nPJM Interconnection, L.L.C. \n) \nDocket No. ER26-3515-000 \n \nMOTION FOR EXTENSION OF TIME  \nOF THE ORGANIZATION OF PJM STATES, INC. \n \nPursuant to Rules 212 and 2008 of the Rules of Practice and Procedure of the Federal \nEnergy Regulatory Commission (“FERC” or the “Commission”),1 the Organization of PJM States, \nInc. (“OPSI”) submits this Motion for an Extension of Time to submit comments in response to \nPJM’s August 13, 2026, filing proposing revisions to the Open Access Transmission Tariff \n(“Tariff”) and the Reliability Assurance Agreement Among Load Serving Entities (“RAA”) to \nestablish Interim Resource Adequacy Service (“IRAS”), among other things.2 OPSI requests that \nthe Commission extend the time for comments in this docket from September 3, 2026 to September \n14, 2026. OPSI requests that the Commission act on this motion by September 1, 2026.3 PJM has \nauthorized OPSI to represent that PJM does not oppose this Motion for Extension of Time. \nI. \nBACKGROUND \nOn August 13, 2026, PJM filed a proposal to create “a new supplemental capacity product \nthrough which New Large Loads [(“NLL”)] provide a load reduction service that is a tool available \nto PJM to manage resource adequacy shortfalls that would otherwise drive shedding of native \nloads.”4 PJM also proposed to create a new large load registry and meaningful changes to the \nposition of the region’s Variable Resource Requirement (“VRR”) curve, depending on the amount \n \n1 18 C.F.R. §§ 385.212 and 385.2008 (“Except as otherwise provided by law, the time by which any person is required \nor allowed to act under any statute, rule, or order may be extended by the decisional authority for good cause, upon a \nmotion made before the expiration of the period prescribed or previously extended.”). \n2 PJM Interconnection L.L.C., Proposal to Establish Interim Resource Adequacy Service and a Large Load \nRegistry to Address System Reliability, Docket No. ER26-3515-000 (August 13, 2026) (“IRAS Filing”). \n3 The OPSI Board of Directors approved this Motion for Extension of Time pursuant to its Bylaws on August 28, \n2026. \n4 IRAS Filing at 22."},{"page":2,"startToken":353,"endToken":663,"text":"of NLL that has not brought its own new capacity in a delivery year, among other things.5 \nImportantly, PJM proposes a compensation mechanism for loads that provide this new service, \nwhich creates new obligations for Electric Distributors. There is also an opportunity for NLLs to \nwaive this compensation, and discussion of ways that states may be able to modify this \ncompensation at the retail level.  \nII. \nMOTION FOR EXTENSION OF TIME \nPursuant to the combined notice of filings issued on August 13, 2026, comments on PJM's \nproposal are due on September 3, 2026.6 Good cause exists to extend the comment deadline in this \nproceeding from September 3, 2026 to September 14, 2026 to allow the retail regulators in the \nPJM region additional time to consider the complex interaction between the rights and \nresponsibilities of PJM, Electric Distributors, and retail regulators related to the implementation \nof IRAS and the associated compensation mechanism. OPSI asserts that no party will be prejudiced \nshould FERC grant this motion, nor is this motion made solely for the purpose of delay. \nPJM proposes meaningful state-federal interactions in the implementation of the IRAS \nproduct itself and the compensation rate for the service. In order to ensure that the retail electric \nregulators in the PJM region have the opportunity to provide substantive comments, OPSI \nrespectfully requests a limited extension of time to file comments in this docket. Failing to grant \nthe motion would result in rushed reactions to PJM’s proposal, which has materially evolved since \nPJM presented it to stakeholders at the end of June. Granting the extension would, therefore, \nsupport the Commission in its decision-making. The issues in this docket are not insignificant. The \nproposal raises significant questions related to the interaction between wholesale and retail \nratemaking. \n \n5 Id. at 109–119. \n6 Combined Notice of Filings #2, Accession No. 20260813-5118 (FERC Aug. 13, 2026)."},{"page":3,"startToken":663,"endToken":748,"text":"III. \nCONCLUSION \nAccordingly, OPSI respectfully requests that the Commission grant this Motion for \nExtension of Time to respond to PJM’s IRAS filing by the close of business on September 14, \n2026. \n   \nRespectfully Submitted,  \nBenjamin B. Sloan \nExecutive Director  \nOrganization of PJM States, Inc.  \n700 Barksdale Road, Suite 1 \nNewark, DE 19711  \n601-214-8481  \nben@opsi.us  \nEllen B. Egen \nDirector of Legal and Regulatory Affairs  \nOrganization of PJM States, Inc.  \n700 Barksdale Road, Suite 1 \nNewark, DE 19711  \n336-254-4915 \nellen@opsi.us  \nDated: August 28, 2026"},{"page":4,"startToken":748,"endToken":820,"text":"CERTIFICATE OF SERVICE \n \nI hereby certify that the foregoing has been served in accordance with 18 C.F.R. §385.2010 \nupon each person designated on the official service list compiled by the Secretary in this \nproceeding.  \n \n/s/ Ellen B. Egen_______ \nDirector of Legal and Regulatory Affairs  \nOrganization of PJM States, Inc.  \n700 Barksdale Road, Suite 1 \nNewark, DE 19711  \n336-254-4915 \nellen@opsi.us  \n \n \nDated at Newark, Delaware this August 28, 2026."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1042,"startToken":0,"endToken":162},{"p":1,"at":1042,"title":"I. BACKGROUND","method":"PDF bookmark","endPage":1,"endAt":1046,"startToken":162,"endToken":163},{"p":1,"at":1046,"title":"BACKGROUND","method":"printed heading","endPage":2,"endAt":407,"startToken":163,"endToken":419},{"p":2,"at":407,"title":"II. MOTION FOR EXTENSION OF TIME","method":"PDF bookmark","endPage":3,"endAt":0,"startToken":419,"endToken":663},{"p":3,"at":0,"title":"III. CONCLUSION","method":"PDF bookmark","endPage":3,"endAt":6,"startToken":663,"endToken":664},{"p":3,"at":6,"title":"CONCLUSION","method":"printed heading","endPage":4,"endAt":0,"startToken":664,"endToken":748},{"p":4,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":4,"endAt":459,"startToken":748,"endToken":820}]}