ER26-3515-000 · 2026-08-28 · Organization of PJM States, Inc.

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

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C. 
) 
Docket No. ER26-3515-000 
 
MOTION FOR EXTENSION OF TIME  
OF THE ORGANIZATION OF PJM STATES, INC. 
 
Pursuant to Rules 212 and 2008 of the Rules of Practice and Procedure of the Federal 
Energy Regulatory Commission (“FERC” or the “Commission”),1 the Organization of PJM States, 
Inc. (“OPSI”) submits this Motion for an Extension of Time to submit comments in response to 
PJM’s August 13, 2026, filing proposing revisions to the Open Access Transmission Tariff 
(“Tariff”) and the Reliability Assurance Agreement Among Load Serving Entities (“RAA”) to 
establish Interim Resource Adequacy Service (“IRAS”), among other things.2 OPSI requests that 
the Commission extend the time for comments in this docket from September 3, 2026 to September 
14, 2026. OPSI requests that the Commission act on this motion by September 1, 2026.3 PJM has 
authorized OPSI to represent that PJM does not oppose this Motion for Extension of Time. 
I. 
BACKGROUND 
On August 13, 2026, PJM filed a proposal to create “a new supplemental capacity product 
through which New Large Loads [(“NLL”)] provide a load reduction service that is a tool available 
to PJM to manage resource adequacy shortfalls that would otherwise drive shedding of native 
loads.”4 PJM also proposed to create a new large load registry and meaningful changes to the 
position of the region’s Variable Resource Requirement (“VRR”) curve, depending on the amount 
 
1 18 C.F.R. §§ 385.212 and 385.2008 (“Except as otherwise provided by law, the time by which any person is required 
or allowed to act under any statute, rule, or order may be extended by the decisional authority for good cause, upon a 
motion made before the expiration of the period prescribed or previously extended.”). 
2 PJM Interconnection L.L.C., Proposal to Establish Interim Resource Adequacy Service and a Large Load 
Registry to Address System Reliability, Docket No. ER26-3515-000 (August 13, 2026) (“IRAS Filing”). 
3 The OPSI Board of Directors approved this Motion for Extension of Time pursuant to its Bylaws on August 28, 
2026. 
4 IRAS Filing at 22.

of NLL that has not brought its own new capacity in a delivery year, among other things.5 
Importantly, PJM proposes a compensation mechanism for loads that provide this new service, 
which creates new obligations for Electric Distributors. There is also an opportunity for NLLs to 
waive this compensation, and discussion of ways that states may be able to modify this 
compensation at the retail level.  
II. 
MOTION FOR EXTENSION OF TIME 
Pursuant to the combined notice of filings issued on August 13, 2026, comments on PJM's 
proposal are due on September 3, 2026.6 Good cause exists to extend the comment deadline in this 
proceeding from September 3, 2026 to September 14, 2026 to allow the retail regulators in the 
PJM region additional time to consider the complex interaction between the rights and 
responsibilities of PJM, Electric Distributors, and retail regulators related to the implementation 
of IRAS and the associated compensation mechanism. OPSI asserts that no party will be prejudiced 
should FERC grant this motion, nor is this motion made solely for the purpose of delay. 
PJM proposes meaningful state-federal interactions in the implementation of the IRAS 
product itself and the compensation rate for the service. In order to ensure that the retail electric 
regulators in the PJM region have the opportunity to provide substantive comments, OPSI 
respectfully requests a limited extension of time to file comments in this docket. Failing to grant 
the motion would result in rushed reactions to PJM’s proposal, which has materially evolved since 
PJM presented it to stakeholders at the end of June. Granting the extension would, therefore, 
support the Commission in its decision-making. The issues in this docket are not insignificant. The 
proposal raises significant questions related to the interaction between wholesale and retail 
ratemaking. 
 
5 Id. at 109–119. 
6 Combined Notice of Filings #2, Accession No. 20260813-5118 (FERC Aug. 13, 2026).

III. 
CONCLUSION 
Accordingly, OPSI respectfully requests that the Commission grant this Motion for 
Extension of Time to respond to PJM’s IRAS filing by the close of business on September 14, 
2026. 
   
Respectfully Submitted,  
Benjamin B. Sloan 
Executive Director  
Organization of PJM States, Inc.  
700 Barksdale Road, Suite 1 
Newark, DE 19711  
601-214-8481  
ben@opsi.us  
Ellen B. Egen 
Director of Legal and Regulatory Affairs  
Organization of PJM States, Inc.  
700 Barksdale Road, Suite 1 
Newark, DE 19711  
336-254-4915 
ellen@opsi.us  
Dated: August 28, 2026

CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing has been served in accordance with 18 C.F.R. §385.2010 
upon each person designated on the official service list compiled by the Secretary in this 
proceeding.  
 
/s/ Ellen B. Egen_______ 
Director of Legal and Regulatory Affairs  
Organization of PJM States, Inc.  
700 Barksdale Road, Suite 1 
Newark, DE 19711  
336-254-4915 
ellen@opsi.us  
 
 
Dated at Newark, Delaware this August 28, 2026.