{"document":{"slug":"filing-20260901-5028","title":"Answer of the Pennsylvania Public Utility Commission in support of the Organization of PJM States, Inc.’s motion for extension of time to submit comments in response to PJM Interconnection, L.L.C.’s filing","issued":"2026-09-01","accession":"20260901-5028","docket":"ER26-3515-000","group":"PJM filings","filer":"Pennsylvania Public Utility Commission","kind":"comments","file":"sources/originals/20260901-5028_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260901-5028","sha256":"9e70754aba977407925d3346100ad47af31a6f7ea0f7549c73b673329ba529aa","pages":4,"tokens":753,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":166,"text":"1 \n \nCOMMONWEALTH OF PENNSYLVANIA \n \nPENNSYLVANIA PUBLIC UTILITY COMMISSION  \n \nCOMMONWEALTH KEYSTONE BUILDING  \n400 NORTH STREET, THIRD FLOOR \n  \nHARRISBURG, PENNSYLVANIA 17120  \n  \n \nSeptember 1, 2026 \nVia Electronic Filing  \nThe Honorable Debbie-Anne A. Reese, Secretary  \nFederal Energy Regulatory Commission  \n888 First Street, N.E.  \nWashington, D.C.  20426  \n \nRe:  \nPJM Interconnection, L.L.C., Docket No. ER26-3515 \n \nDear Secretary Reese:  \n \nPlease find for e-filing the Answer of the Pennsylvania Public Utility Commission \n(PA PUC) in support of the Organization of PJM States, Inc.’s (OPSI) motion for \nextension of time to submit comments in response to PJM Interconnection, L.L.C.’s filing \nin the above-referenced docket.   \n \nCopies of this document have been served upon all parties designated on the \nCommission’s official service list, in accordance with Rule 2010 of the \nCommission’s Rules of Practice and Procedure. \n \nIf you have any questions, please do not hesitate to contact me.  \n \nRespectfully submitted,  \n  \n/s/ Elizabeth H. Barnes \nElizabeth H. Barnes  \nDeputy Chief Counsel   \nPennsylvania Public Utility Commission  \n(717)772-5408  \nebarnes@pa.gov"},{"page":2,"startToken":166,"endToken":443,"text":"2 \n \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nPJM Interconnection, L.L.C. \nDocket No. ER26-3515-000 \n \n \nANSWER OF THE PENNSYLVANIA PUBLIC UTILITY COMMISSION TO \nMOTION FOR EXTENSION OF TIME \n \n \nPursuant to Rule 213 of the Federal Energy Regulatory Commission’s \n(“Commission”) Rules of Practice and Procedure, 18 C.F.R. § 385.213(a)(3), Intervenor \nPennsylvania Public Utility Commission (PA PUC) submits this Answer in Support of \nthe Motion of the Organization of PJM States (OPSI) for a two-week extension of time to \nsubmit comments in response to PJM’s August 13, 2026 filing proposing revisions to the \nOpen Access Transmission Tariff (“Tariff”) and the Reliability Assurance Agreement \nAmong Load Serving Entities (“RAA”) to establish Interim Resource Adequacy Service \n(“IRAS”), among other things.1  PA PUC supports and joins in OPSI’s request that the \nCommission extend the time for comments in this docket from September 3, 2026 to \nSeptember 14, 2026.   \n \nPJM proposes a compensation mechanism for new large loads (NLLs) that provide \na load reduction service, i.e. curtailment, which creates new obligations for Electric \nDistributors. There is also an opportunity for NLLs to waive this compensation, and ways \nthat states may be able to modify this compensation at the retail level. PA PUC also \nrequests time to examine PJM’s filing and seek clarification regarding the complicated \nissue of how IRAS service may or should be compensated at the retail level.  We find \nsome ambiguity due to discrepancies between PJM’s transmittal letter and the red-lined \n \n1 PJM Interconnection L.L.C., Proposal to Establish Interim Resource Adequacy Service and a Large \nLoad Registry to Address System Reliability, Docket No. ER26-3515-000 (August 13, 2026) (“IRAS \nFiling”)."},{"page":3,"startToken":443,"endToken":671,"text":"3 \n \ntariff amendments proposed on this issue of 0-50% compensation.  PA PUC sees some \npotential jurisdictional conflicts arising from the proposed tariff amendments and may \nfile comments as to what role States should have in controlling the compensation rate via \nstate-level retail tariffs.   The curtailment protocol was not developed with PA PUC’s \ninput, and it may impinge upon our jurisdiction over retail rates.  Specifically, PJM’s \ntariff redlines prescribe compensation obligations for Electric Distribution Companies. \nThe redlines for Tariff section X.b.i. identify EDC compensation obligations and \ncollection thereof from jurisdictional customers (See page 105 of PJM’s filing).  The \ntariff does not expressly recognize state authority to prohibit, approve, or modify such \ncompensation and jurisdictional  recovery.  No party will be prejudiced should FERC \ngrant OPSI’s motion, nor is the motion made solely for the purpose of delay.  It is in the \npublic interest to grant OPSI and the PA PUC an additional two weeks to review the PJM \nfiling and develop comments in response. \n \nCONCLUSION \n \nWHEREFORE, the Pennsylvania Public Utility Commission respectfully requests \nthat the Commission grant OPSI’s motion and extend the deadline for answers to  PJM’s \nIRAS filing to the close of business on Monday, September 14, 2026. \n   \nRespectfully Submitted,  \n/s/ Elizabeth H. Barnes \nElizabeth H. Barnes  \nDeputy Chief Counsel   \nPennsylvania Public Utility Commission  \n400 N. St., 3rd Foor \nHarrisburg, PA 17120 \n(717)772-5408  \nebarnes@pa.gov"},{"page":4,"startToken":671,"endToken":753,"text":"4 \n \n \nCERTIFICATE OF SERVICE  \nI HEREBY CERTIFY that I am on this date serving a copy of the foregoing comments \nupon each person designated on the official service list compiled by the Federal Energy \nRegulatory Commission in accordance with the requirements of Rule 2010 of the \nCommission’s Rules of Practice and Procedure. \n \nRespectfully submitted, \n \n/s/ Elizabeth H. Barnes \nDeputy Chief Counsel \nCounsel for the Pennsylvania \nPublic Utility Commission \nP.O. Box 3265 \nHarrisburg, PA  17105-3265 \nTel: (717) 787-5000 \n \nDated:  September 1, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":1101,"startToken":0,"endToken":607},{"p":3,"at":1101,"title":"CONCLUSION","method":"printed heading","endPage":4,"endAt":7,"startToken":607,"endToken":672},{"p":4,"at":7,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":4,"endAt":553,"startToken":672,"endToken":753}]}