ER26-3515-000 · 2026-09-03 · Delaware Division of the Public AdvocateDistrict of Columbia Office of People's CounselIllinois Citizens Utility Board ,Maryland Office of People's Counsel ,New Jersey Division of Rate Counsel ,Office of the Illinois Attorney General ,

Protest and Comments of Joint Consumer Advocates on the 08/13/2026 filing by PJM Interconnection, L.L.C

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Topics in the text: Reliability and curtailment · Registry access · Cost allocation

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Opening text

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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION PJM Interconnection, L.L.C.
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protest and comments OF JOINT CONSUMER ADVOCATES

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We note that the Commission’s June 2026 Show Cause Order6 found PJM’s Open Access Transmission Tariff (Tariff) “appears to be unjust, unreasonable, or unduly discriminatory or preferential,” in part because of its treatment of large load customers.7 The Commission should reject PJM’s treatment of…
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SUMMARY

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But in making its filing initiating this proceeding, PJM has presented IRAS as a supply-side measure akin to demand response.13 Thus, PJM proposes that new large loads that are curtailed pursuant to IRAS should be entitled to compensation, but leaves to the states resolution of the question of who…
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PROTEST AND COMMENTS

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PROTEST AND COMMENTS
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I. IF properly implemented, IRAS could Insulate Ratepayers from the Capacity Costs OF Serving Projected New Large Loads by removing those loads from the Bra.

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The Commission’s “first and foremost duty” under the FPA is to “protect consumers from unjust and unreasonable rates.”40 Here, that means that FERC must act to protect ratepayers against the risk of “a protracted [AI] investment bust,” including the risk of the 39 Ganesh Sitaraman and Asad…
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II. IRAS Should Help ease the Demand Pressures Plaguing the BRA.

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IRAS SHOULD HELP EASE THE DEMAND PRESSURES PLAGUING THE BRA.
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Summary

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Summary (May 27, 2026), https://www.pjm.com/- /media/DotCom/committees-groups/cifp-rbp/2026/20260527/20260527-informational-only---reliability- backstop-rfi-summary---charles-river-associates.pdf. 51 Motion to Intervene and Protest of Nicholas Max Neal and David Neal, Delaware Standard Offer…
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III. while potentially beneficial, iras as proposed is flawed.

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The White Paper explains that “[t]oday, due to compounding frictions in siting, permitting, supply chains and interconnection, it can take two or three times as long to build a gas resource as it does to build a hyperscale data center.”57 Other resources, such as renewables combined with battery…
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IV. The Commission Should Exercise either Its FPA Section 205 or section 206 authority to Direct PJM to make IRAS a Non-Firm Transmission Service.

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PJM proposes it as a compensable resource adequacy measure.
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V. PJM’S PROPOSAL IS FLAWED BECAUSE IT IMPROPERLY TREATS AS “NEW” CAPACITY THAT previously cleared a base residual auction.

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IRAS is intended to enable PJM to address auction shortfalls and ensure system reliability.97 Because new large loads are driving BRA shortfalls, PJM proposes through IRAS to require these loads either to bring their own new capacity or be subject to curtailment (depending upon state load shed…
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VI. The commission should condition acceptance upon revisions to the Large Load Registry.

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The duty to populate the Registry falls on “[e]ach Party,” which must “submit, or cause to be submitted,” the required information “related to each Large Load served by the Party.”107 Electric Distributors, in turn, are required to provide “any information or data the Electric Distributor believes…
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VII. The Acceptance of IRAS Is Further Reason to Reject RBP.

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There is every reason to believe that IRAS— a resource adequacy measure that will be available to PJM before the availability of any RBP resources—will provide a source of new resource adequacy roughly equivalent to PJM’s final RBP target.
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CONCLUSION

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CONCLUSION WHEREFORE, for the foregoing reasons, the Commission should direct PJM to revise its IRAS proposal consistent with the recommendations herein.
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CERTIFICATE OF SERVICE

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Dated on this 3rd day of September, 2026. /s/ Lauren L.
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