Motion for Leave to Answer and Answer of PJM Interconnection, L.L.C. to Comments and Protests re the 07/31/2026 revised Open Access Transmission Tariff filing et al
Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Credit and exit · Reliability and curtailment
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Opening text
opening text · Topic match: Reliability and curtailment
PJM therefore asks that the Commission accept this Answer.Read this passage Filed comments: Reliability and curtailment
I. ANSWER
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I.Read this passage
A. The RBP Proposal Is a Measured and Timely Response that Received
printed heading · Topic match: Reliability and curtailment
The PJM region must address near-term deficiencies to begin focusing on the long-term solution, which is why Dominion Energy supports the RBP.”). 19 AEU Comments at 1 (“[Advanced Energy] United generally supports PJM’s July 31, 2026, filing as the best available solution to address the pressing…Read this passage Filed comments: Reliability and curtailment
B. The Role of Electric Distributors in the RBP Is Appropriately Tailored.
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The allocation of these inputs impacts cost allocation and credit requirements.”38 These “allocation inputs” are, indeed, inputs to PJM forecasts that Electric Distributors already provide.Read this passage Filed comments: Cost allocation
C. Nothing in Intervenors’ Protests, Comments Call into Question the
printed heading · Topic match: Reliability and curtailment
Furthermore, PJM proposes to procure for the known and measurable shortfall reflected in the 2028/2029 BRA in recognition that the value is not in dispute and that the RBP is not intended to be the one and only solution to the resource adequacy challenges facing the PJM Region today. 3.Read this passage Filed comments: Reliability and curtailment
D. RBP Offsets Should Neither Be Expanded to Include Additional Types of
printed heading · Topic match: Connecting load and generation
It is true that there may be more than one just and reasonable means of accommodating short lead-time resources in PJM's auctions, and in determining whether to accept PJM's filing, the Commission must only determine that PJM’s proposed solution is just and reasonable, not that it is superior to…Read this passage Filed comments: Connecting load and generation
E. PJM Addresses Several Intervenor Requests for Clarification to the
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PJM Addresses Several Intervenor Requests for Clarification to the Proposed Opt-Outs. 1.Read this passage Filed comments: Reliability and curtailment
F. PJM’s Procurement Process Is Just and Reasonable.
printed heading · Topic match: Cost allocation
The JCA asserts, “it is also unduly discriminatory to require some ratepayers to pay for fifteen-year procurements when other ratepayers are insulated from RBP charges due to exemptions or bilateral/self-supply arrangements of only five years.”103 But ratepayers can choose.Read this passage Filed comments: Cost allocation
G. The Requirement for RBP Resources to Offer into the RPM As
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The Commission has consistently rejected the position that requiring resources that are procured outside of a capacity market to offer into the capacity market as price takers would unjustly and unreasonably distort or suppress capacity market clearing prices.136 Indeed, as recently as last year,…Read this passage Filed comments: Cost allocation
H. Arguments That RBP Should Be Extended to FRR Entities Are Baseless.
printed heading · Topic match: Reliability and curtailment
This does not implicate FRR Entities.160 By definition, FRR Entities must bring new capacity for all new loads within their territory.161 If an FRR Entity does not include sufficient capacity in its FRR Capacity Plan, the FRR Entity is subject to “an FRR Commitment Insufficiency Charge, in an…Read this passage Filed comments: Reliability and curtailment
I. PJM’s Proposed Cost Allocation Approach Appropriately Assigns Cost
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Accordingly, “PJM evaluated methodologies for determining the amount of collateral required from LSEs.”248 PJM determined that “a methodology that first determines the aggregate collateral necessary to address the payment exposure associated with the portfolio of committed RBP Resources and then…Read this passage Filed comments: Cost allocation
D. Jaramillo on Behalf of Northern Virginia Electric Cooperative, at 4 (Va. S.C.C. Dec. 16, 2024),
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With respect to collateral requirements, the Virginia State Corporation Commission approved Dominion’s proposed terms, “including: (1) $1.5 million/MW; (2) a reduction up to 70% based on the customer’s established credit; (3) provisions for third-party guarantees and letters of credit; and (4)…Read this passage Filed comments: Credit and exit
II. CONCLUSION
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II.Read this passage
CONCLUSION
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CONCLUSION PJM asks that the Commission consider this Answer and accept the proposed Tariff revisions in this docket, effective September 29, 2026, as requested.Read this passage
CERTIFICATE OF SERVICE
printed heading · Topic match: Registry access
Appendix A Protests, Comments, Requests for Clarification, and Answers Filed to Date Docket No.Read this passage Filed comments: Registry access