ER26-3515-000 · 2026-09-03 · Data Center Coalition

Motion to Intervene and Protest of the Data Center Coalition to PJM Interconnection, L.L.C.’s proposal to establish Interim Resource Adequacy Service and a Large Load Registry

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Topics in the text: Reliability and curtailment · Cost allocation · Retail and wholesale authority

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Opening text

opening text · Topic match: Registry access

ER26-3515-000 ) MOTION TO INTERVENE AND PROTEST OF THE DATA CENTER COALITION Pursuant to Rules 211, 212, and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”)1 and the Commission’s August 13, 2026 Combined Notice of Filings #2,2 the…
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I. INTRODUCTION

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I.
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INTRODUCTION

printed heading · Topic match: Reliability and curtailment

But Congress’s decision to reserve to the states authority over retail service means that it is the states that must take the lead in developing the retail service frameworks through which new large loads are integrated into the electric system, including the rules governing the priority of…
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II. PROTEST

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II.
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A. IRAS Unlawfully Intrudes On State Authority Over Retail Sales

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Learjet, Inc., 575 U.S. 373, 385 (2015). - 9 - Commission must examine what IRAS actually does in practice.
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B. IRAS Is Unjust, Unreasonable, Unduly Discriminatory, And Inconsistent

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Curtailing Load That Pays For Demand Response Before Calling Upon Demand Response Is Inconsistent With Cost Causation Requirements The Commission and the courts have recognized that the FPA’s “just and reasonable” standard incorporates a cost causation principle.56 The cost causation principle…
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C. IRAS Fails To Account For Existing Contractual Arrangements And Reliance

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While long overdue, PJM’s transition away from a legacy serial process includes the unfortunate feature of pausing study of all new interconnection requests while PJM implements its new, faster process.”). - 33 - demonstrate,92 this timeline does not provide a realistic opportunity for New Large…
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D. The Commission Should Reject IRAS Or Impose A Meaningful Transition

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Alternatively, if the Commission determines based on the record in this proceeding that PJM’s emergency procedures must be reformed immediately, then it should initiate a Section 206 proceeding to determine how PJM’s emergency procedures can be modified to mitigate reliability risks without…
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III. MOTION TO INTERVENE

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DCC advocates for grid reforms that minimize unnecessary cost burdens, align with cost causation principles, facilitate responsible load growth, support the development of new generation, and enhance grid resilience system-wide without imposing undue costs on existing ratepayers.
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IV. CORRESPONDENCE AND COMMUNICATIONS

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CORRESPONDENCE AND COMMUNICATIONS DCC requests that the following names be placed on the official service list for this proceeding by the Commission and that all correspondence and communications with respect to this proceeding be addressed to the following:96 Morgan A.
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V. CONCLUSION

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V.
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CONCLUSION

printed heading · Topic match: Reliability and curtailment

These model tariffs would: ● Establish standardized retail tariff provisions under which large customers may receive interruptible service, whether through voluntary election or pursuant to state regulatory requirements; ● Define the operational expectations, customer obligations, and utility…
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Conclusion

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Cost causation rationale is weak. 9 Arbitrary Outcomes Created by Vintage Cutoff dates create arbitrary results that are not based on load magnitude or system impact. 10 Protection is Not Assured The Claimed Benefit of BYONC Is Outside PJM’s Control Protection Must Be Real • PJM cannot dictate…
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CERTIFICATE OF SERVICE

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Dated at Washington, D.C., this 3rd day of September 2026. /s/ Stephen J.
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