{"document":{"slug":"filing-er26-3515-pjm-iras-attachment-3","title":"Attachment C IRAS - Pilong Affifdavit .pdf","issued":"2026-08-13","accession":"20260813-5118","docket":"ER26-3515-000","group":"PJM filings","filer":"PJM Interconnection, L.L.C.","kind":"attachment","file":"sources/originals/20260813-5118_04.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260813-5118","parent":"filing-er26-3515-pjm-iras","sha256":"6bd9e23954ca7a2502f1c60404d418121c7a2544456762fa1aa050ba8e3dfacf","pages":13,"tokens":4169,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":14,"text":"Attachment C \nAffidavit of Christopher Pilong on \nBehalf of PJM Interconnection, L.L.C."},{"page":2,"startToken":14,"endToken":408,"text":"2 \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \n) \nPJM Interconnection, L.L.C. \n) \nDocket No. ER26-____-000 \n \n \n \n) \n \nAFFIDAVIT OF CHRISTOPHER PILONG \nON BEHALF OF PJM INTERCONNECTION, L.L.C. \n \nI. \nIntroduction \n1. \nMy name is Christopher Pilong.  My business address is 2750 Monroe Boulevard, \nAudubon, Pennsylvania, 19403.  I am Senior Director of Operations Planning for PJM \nInterconnection, L.L.C. (“PJM”).  I am submitting this affidavit on behalf of PJM to discuss \nwhen and how PJM would utilize the Interim Resource Adequacy Service (“IRAS”) to \nmanage system reliability.  Specifically, in this affidavit, I explain how PJM will generally \nfollow its existing processes and procedures in calling for IRAS load reductions and \nprovide some examples of how it will work in practice.   \n2. \nI joined PJM in November 2001.  Currently, as Senior Director of Operations Planning, I \nam responsible for the Transmission Operations Department, Generation Department, \nTransmission Service Department, and Outage Analysis Technologies Department.  These \ndepartments perform near-term transmission outage analysis and approvals, generation \noutage analysis and approvals, facilitate annual Black Start Unit commitments, support and \ndevelop operational tools, implement and comply with all North American Energy \nStandards Board business rules regarding Available Flowgate Capability/Available \nTransfer Capability, perform gas-electric coordination activities, as well as many other \ntasks to prepare for, and support, real time operations.  The teams also perform seasonal \nreliability assessments, support the various tools and applications utilized in these \nprocesses, and coordinate directly with the Market Services Division and System Planning \nDivision.   \n3. \nPreviously, as Director, Dispatch, I was responsible for the oversight and operation of the \nValley Forge and Milford Control Centers.  This function included ensuring the reliable \noperation of the power grid, in accordance with all PJM and North American Electric \nReliability Corporation (“NERC”) reliability standards pertaining to the functions of \nReliability Coordinator, Balancing Authority, and Transmission Operator.  In addition, I \nwas responsible for ensuring the efficient economic dispatch of the system under the \nexisting PJM market rules and neighboring Joint Operating Agreements.   \n4. \nPrior to that position, I served as a Reliability Engineer and then Manager – Reliability \nEngineering.  As Manager for the Reliability Engineering Group, I managed the group \nresponsible for coordinating day-ahead and real-time operating plans among PJM staff, \nPJM Transmission Owners, PJM Generation Owners, and our neighboring entities.  I \nperformed these functions directly in my earlier role as a Reliability Engineer.  I hold a"},{"page":3,"startToken":408,"endToken":701,"text":"3 \nBachelor of Science degree in Electrical Engineering from Lehigh University and a Master \nof Business Administration degree from Villanova University. \nII. \nOverview of Practices When Capacity Shortages Give Rise to Emergency Procedures   \n5. \nAs set forth in section 2.1 of PJM Manual 13, “PJM is responsible for determining and \ndeclaring that an Emergency is expected to exist, exists, or has ceased to exist in any part \nof the PJM [regional transmission organization (“RTO”)] or in any other Control Area that \nis interconnected directly or indirectly with the PJM RTO.  1.”2 \n6. \nIn PJM, there are three general levels of Emergency Procedures for capacity shortages, and \nan advisory level.   \n7. \nPrior to the Operating Day, PJM may issue advisories and/or alerts (see Figure 1, below).  \nThe advisory level is general in nature and for elevated awareness “only and may be issued \none or more days in advance of the Operating Day.”3  Emergency Procedure Alerts may \nbe “issued one or more days in advance of the Operating Day for elevated awareness and \nto give time for advanced preparations.”4   \nFigure 1: Advisory and Alerts5 \n \nA. \nSteps in Real-Time Prior to Emergency Actions \n8. \nPJM Dispatchers monitor projected and current reserves and determine whether actions are \nneeded to maintain reserves within the required limits.  In accordance with PJM Manual \n13, before entering into capacity-related emergency actions in real-time, PJM Dispatch will \n \n \n2 Systems Operations Division, PJM Manual 13: Emergency Operations, PJM Interconnection, L.L.C., section 2.1 \n(rev. \n98, \nJune \n24, \n2026), \nhttps://www.pjm.com/-/media/DotCom/documents/manuals/m13.pdf \n[https://perma.cc/HE9Y-BNQK] (“PJM Manual 13”). \n3 PJM Manual 13, section 2.3.  \n4 PJM Manual 13, section 2.3.  \n5 PJM Manual 13, section 2.3."},{"page":4,"startToken":701,"endToken":1195,"text":"4 \nuse available generation and economic demand response, based on economic dispatch, \nwhich ensures that Real-Time Locational Marginal Prices reflect actual system conditions.6   \n9. \nSecond, as set forth in PJM Manual 13, if generation and economic demand resources are \nnot sufficient to maintain reserves, PJM Dispatch will then recall energy from its Capacity \nResources by curtailing non-firm export transactions, i.e., interchange transactions, in \naccordance with Part II of the PJM Open Access Transmission Tariff (“Tariff”).   \n10. \nPJM Dispatch will also have declared a NERC Energy Emergency Alert Level 1 (“EEA1”), \nas required by NERC Standard EOP-011 Attachment 1, via the Reliability Coordinator \nInformation System and Emergency Procedures webpage.7   \n11. \nThere are three levels of NERC Energy Emergency Alert Levels (EEA1 through EEA3), \nwith an EEA3 being the highest alert level.  “EEA1 signals that PJM foresees or is \nexperiencing conditions where all available resources are scheduled to meet firm load, firm \ntransactions, and reserve commitments, and is concerned about sustaining its required \nContingency Reserves.”8  “An EEA3 is issued when [PJM] is unable to meet minimum \nContingency Reserve Requirements.”9 \n12. \nThird, if system conditions remain constrained and reserves are projected to be short of \nrequirements, assuming PJM’s new, yet-to-be-effective transmission service products—\nNon-Firm Contract Demand Service (“CDS”) and Interim Network Integrated \nTransmission Service (“Interim NITS”) are effective, PJM may direct curtailment of Non-\nFirm CDS and/or Interim NITS transmission service.10 \n13. \nFourth, if system conditions remain constrained and reserves are projected to be short of \nrequirements, then PJM will curtail the new IRAS load as outlined in the Examples below. \n14. \nFifth, if a system emergency develops, then PJM will initiate Steps 1 through Step 10 of \nthe Capacity Emergency procedures as necessary to maintain the reliability of the grid.  If \nStep 10 (Manual Load Dump Action) is reached, this may require firm load to shed \npursuant to emergency actions.  PJM members are expected to implement all emergency \nprocedures based on the timeliness associated with each specific procedure.11 \n \n6 PJM Manual 13, section 2.3.2. \n7 PJM Manual 13, section 2.3.2. \n8 PJM Manual 13, section 2.3.1. \n9 PJM Manual 13, section 2.3.2. \n10 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209, at P 551 (2026) (“[W]e find PJM’s proposal to curtail Interim \nNITS and [Non-Firm Contract Demand] transmission service prior to deployment of its Pre-Emergency Load \nResponse Program, or in response to a transfer capability shortage as a result of system reliability conditions, to be \njust and reasonable because it is consistent with how Non-Firm [Point-to-Point Service] is curtailed. . . . [W]e find \nthat PJM’s proposal to curtail Interim NITS during capacity or reserve shortages is just and reasonable and consistent \nwith both the nature of the transmission service as a non-firm transmission service for which Eligible Customers do \nnot pay generation capacity charges, and the need to maintain reliability.” (footnote omitted)).  \n11 PJM Manual 13, section 2.3."},{"page":5,"startToken":1195,"endToken":1423,"text":"5 \nB. \nSteps for Real-Time Emergency Actions Set Forth in PJM Manual 13 \n15. \nImportantly, while there is a sequence of escalating emergency action steps set forth in \nPJM Manual 13, the rapidness of system events influences the timing and order of actions \nnecessary to maintain system reliability.  Therefore, PJM Dispatchers “have the flexibility \nto implement emergency procedures in whatever order is required to ensure system \nreliability.12  Likewise, they have the flexibility to exit emergency procedures in a different \norder than they were implemented.”13 \n16. \nFigure 2, below, excerpted from PJM Manual 13, illustrates the escalating emergency \nactions that PJM may take and/or require of Members under the status quo rules.14  \nFigure 2. \n \n17. \nAs Figure 2, above, demonstrates, under current Emergency Procedures, the first step when \nan emergency action is declared is to require Pre-Emergency Load Management \nReductions, which essentially require a class of Demand Resources and DER Aggregation \nResources to reduce load.   \n18. \nAt the most extreme, PJM will declare an EEA3, in which PJM may call for a Manual Load \nDump (i.e., shedding load taking NITS), a last-resort emergency instruction issued by PJM, \ntriggered during severe capacity deficiencies or critical transmission overloads when all \nother operational steps have failed.   \n \n12 PJM Manual 13, section 2.3. \n13 PJM Manual 13, section 2.3. \n14 PJM Manual 13, section 2.3."},{"page":6,"startToken":1423,"endToken":1901,"text":"6 \nIII. \nAddition of Interim Resource Adequacy Service Emergency Procedures to Existing \nEmergency Procedures in PJM Manual 13 \n19. \nNew Large Loads are developing more quickly than generation and transmission can be \nbuilt.  As a result, this may impact the ability for PJM to maintain a reliable system and \ncontinue to meet the demand for existing customers and maintain reserve requirements \nduring times of peak demand and/or significant generator outages.  Therefore, a new \noperational tool is needed to ensure the current level of reliability for our customers is \nmaintained.   \n20. \nIRAS, as proposed, is an additional load reduction service that PJM may deploy in real-\ntime, starting with the 2027/2028 Delivery Year.  As part of this filing, PJM is proposing \na new term, “Interim Resource Adequacy Service Action,” to mean “an Operating \nInstruction, as defined by NERC, issued from the Office of the Interconnection to reduce \nload prior to calling on Pre-Emergency Load Management Reductions after determining \nthat available economic real-time supply may not be sufficient to maintain reserves to meet \napplicable Reserve Requirements and/or Interconnection Reliability Operating Limits \n(“IROL”) within prescribed limits and prevent cascading outages.”15 \n21. \nThe IRAS framework is intended to operate as both a forward-looking reliability assurance \nmechanism and an operational tool. The identification of an IRAS requirement for each \nElectric Distributor’s zone/area establishes the reliability obligation applicable to affected \nload, while PJM’s real-time operating processes determine when and how that obligation \nis activated based on actual system conditions. \n22. \nThe IRAS framework therefore does not require PJM to reduce affected load whenever an \nIRAS requirement exists. Rather, the IRAS requirement establishes an operational \nreliability resource available to PJM, which can be called upon when actual system \nconditions indicate that the reliability need addressed by the IRAS requirement is \nmaterializing. \n23. \nPJM will incorporate IRAS-designated load, that PJM will determine under the IRAS rules, \ninto its operating models, operating plans, and real-time reliability assessments.  PJM’s \nexisting real-time Energy Management System and contingency-analysis processes \nprovide the platform for evaluating system conditions and identifying potential reliability \nviolations. \n24. \nIf the proposed IRAS framework is accepted by the Commission, PJM Manual 13 will be \nrevised to establish the specific details of how PJM will deploy IRAS through new \nEmergency Procedures, i.e., Emergency Alerts, Actions, Advisories, and/or Warnings.  As \nis the norm, PJM will work with stakeholders to revise PJM Manual 13 to establish specific \nlanguage for IRAS Emergency Procedures after the IRAS proposal has been filed with the \n \n15 Tariff, Definitions – Interconnection Reliability Operating Limits; Glossary Terms, North American Electric \nReliability Corporation, https://www.nerc.com/glossary-of-terms?alpha=I [https://perma.cc/TZ9W-MZ4K] (last \nvisited Aug. 11, 2026) (defining Interconnection Reliability Operating Limit as “[a] System Operating Limit that, if \nviolated, could lead to instability, uncontrolled separation, or Cascading outages that adversely impact the reliability \nof the Bulk Electric System.”)."},{"page":7,"startToken":1901,"endToken":2390,"text":"7 \nCommission.  Any revisions to PJM Manual 13 to reflect IRAS will not become effective \nunless the Commission accepts the IRAS framework.   \n25. \nThat said, I will provide, below, a general overview of how IRAS, as a new operational \ntool, will be deployed.  PJM expects that existing Emergency Procedures set forth in PJM \nManual 13 will not change except to add IRAS as another potential tool at PJM’s disposal \nthat PJM may deploy in efforts to address a potential emergency prior to Pre-Emergency \nLoad Management Reduction Action.   \n26. \nIn day-ahead, Interim Resource Adequacy Service Alerts may precede a Maximum \nGeneration Alert (“Max Gen Alert”).  Thus, IRAS provides a new, lower-level Emergency \nProcedure Alert that PJM Dispatch may issue prior to a Max Gen Alert.  In real-time, PJM \nDispatch will deploy Interim Resource Adequacy Service Actions before Pre-Emergency \nLoad Management Reduction Actions.  Thus, in real-time, IRAS provides a new step, at \nPJM’s disposal, prior to impacting existing customers.  If the Interim Resource Adequacy \nService Actions do not address the emergency, PJM Dispatchers would then take necessary \nPre-Emergency Load Management Reduction Actions and declare escalating Emergency \nProcedures as necessary. \n27. \nIn the next subsections of my affidavit, I explain how a PJM Dispatcher may deploy IRAS.  \nIn Example 1, below, I describe how PJM issues an Interim Resource Adequacy Service \nAlert in the day-ahead.  In Example 2, I describe a scenario when, in real-time, PJM \nexperiences an RTO-wide reliability and/or capacity shortfall event and responds by \ndeploying IRAS.  In Example 3, in real-time, PJM experiences an IROL and responds by \ndeploying IRAS.   \n28. \nIt is important to note that prior to the start of each Delivery Year, the megawatts (“MW”) \nquantity of IRAS that will be required to respond to an Interim Resource Adequacy Service \nAlert will be determined by PJM for each Electric Distributor zone/area.  This value will \nbe utilized by PJM Dispatch in their system projections, alerts and actions in the examples \nbelow (e.g., PJM may determine, for example, that prior to the Delivery Year, there may \nbe 4 gigawatts of IRAS available across the RTO, with smaller amounts assigned to an \nElectric Distributor zone/area for real-time curtailment if an Interim Resource Adequacy \nService Action is issued).   \nA. \nExample 1—Day-Ahead Interim Resource Adequacy Service Alert \n29. \nAs PJM operators look ahead to the next Operating Day, they periodically evaluate \nforecasted demand and scheduled supply.  They also evaluate, among many other things, \nexpected weather conditions to determine, e.g., wind and solar resource availability, \ntemperature, etc. PJM schedules reserves on a day-ahead basis to address such \ncontingencies and variabilities.   \n30. \nIn this example, in day-ahead, PJM operators reasonably expect that insufficient supply \nwill be available to meet expected real-time demand and reserves for the next Operating \nDay.  PJM’s operators will have available to them, on a daily basis, the expected aggregate \namount of Interim Resource Adequacy Service MW that can be reduced at the Electric"},{"page":8,"startToken":2390,"endToken":2839,"text":"8 \nDistributor level.  If reduction of some/all of the IRAS load may be necessary to meet  real-\ntime demand and reserve requirements, PJM Dispatchers may elect to issue an Interim \nResource Adequacy Service Alert in day-ahead.   \n31. \nPJM issues an Interim Resource Adequacy Service Alert before and/or concurrently with \na Max Gen Alert/Load Management Alert.  The Interim Resource Adequacy Service Alert \nputs all Eligible New Large Loads on notice that PJM could request reductions in load in \nquantities equal to or lesser than each Electric Distributor zone/area’s assigned IRAS \namounts during the next Operating Day.  However, under an alert, no IRAS reduction is \nactually requested or implemented.  This is simply a notice to prepare and will be issued to \nprovide maximum notice possible. \n32. \nIn this example, PJM also elects to issue a Max Gen Alert/Load Management Alert in day-\nahead.  \n33. \nAs explained in section 2.3.1 of PJM Manual 13, “The intent of the alert(s) is to keep all \naffected system personnel aware of the forecasted and/or actual status of the PJM RTO.  \nAll alerts and cancellation thereof are broadcast on the ALLCALL system and posted to \nselected PJM websites to assure that all members receive the same information.  Alerts are \nissued in advance of a scheduled load period to allow sufficient time for members to \nprepare for anticipated initial capacity shortages.”16   \n34. \nFor Examples 2-3, where PJM issues an Interim Resource Adequacy Service Action in \nreal-time, it can be assumed that PJM Dispatch would have already issued an Interim \nResource Adequacy Service Alert.  Thus, in real-time, PJM’s members are already aware \nthat potential Emergency Procedure actions may take place in real-time.  However, it \nshould be noted that not all conditions can be forecasted, and it is not a requirement that an \nInterim Resource Adequacy Service Alert be issued prior to an Interim Resource Adequacy \nService Action.  Therefore, it is possible to have no day-ahead alerts, but nevertheless have \nan Interim Resource Adequacy Service Action or other Actions issued during the Operating \nDay. \nB. \nExample 2—Real-Time Interim Resource Adequacy Service Action, RTO-\nWide Emergency \n35. \nIn real-time, PJM faces an RTO-wide system emergency.  Prior to directing an Interim \nResource Adequacy Service Action, however, PJM has several other ways to address RTO-\nwide reliability concerns.   \n36. \nFirst, in keeping with the practice in place today and set forth in PJM Manual 13, PJM \nDispatchers deploy available generation and economic demand resources, in economic \ndispatch order while maintaining required reserves.  Even with all available economic \nresources dispatched, PJM’s operators may still face a potential reliability issue and \ncapacity shortfall in real-time. \n \n16 PJM Manual 13, section 2.3.1."},{"page":9,"startToken":2839,"endToken":3323,"text":"9 \n37. \nSecond, in keeping with the practice in place today and as set forth in PJM Manual 13, if \nissues persist or are projected to deteriorate, PJM operators may require non-firm \ninterchange transaction curtailment, as needed.   \n38. \nPJM Dispatchers will have already issued an EEA1.  After the first and second steps taken \nby PJM Dispatchers, PJM remains under an EEA1.   \n39. \nThird, assuming for purposes of this example that the yet-to-be-effective Interim NITS and \nNon-Firm CDS transmission services are now in place, PJM may curtail Non-Firm CDS, \nfollowed by Interim NITS.   \n40. \nFourth, after all non-firm transmission services are curtailed, PJM Dispatchers would then \nissue the new Interim Resource Adequacy Service Action prior to deployment of a Pre-\nEmergency Load Management Reduction Action. \n41. \nPJM intends to issue an Interim Resource Adequacy Service Action through the status quo \nnotification processes set forth in PJM Manual 13.17  Pursuant to the Interim Resource \nAdequacy Service Action, PJM prioritizes load reduction from those Electric Distributor \nzones/areas where New Large Loads have not brought their own new capacity and do not \nhave Allocated Reliability Backstop Procurement Unforced Capacity Megawatts (“RBP \nUCAP MW”) sufficient to cover their capacity needs.  PJM’s operators will direct the IRAS \nreduction to Electric Distributor zones/areas as needed based on system conditions.   \n42. \nMore specifically, through an Interim Resource Adequacy Service Action, PJM \nDispatchers will direct Electric Distributors to implement reductions in load up to, and \ncapped at, the pre-Delivery Year IRAS obligations they were assigned.  Importantly, PJM \nwill not direct specific New Large Loads to reduce load, even though Electric \nDistributors—in coordination, where applicable, with relevant states, Load Serving \nEntities, and New Large Loads—may issue more specific directives to specific retail \ncustomers.18  PJM will only direct load reduction of an aggregate MW IRAS within the \nzone or area. \n43. \nIn this example, the Interim Resource Adequacy Service Action is deployed in response to \na Region-wide emergency.  As such, based on the maximum IRAS amounts assigned to \neach Electric Distributor zone/area, PJM Dispatchers call for some or all Electric \nDistributors to reduce load across the PJM RTO Region in the manner they see fit to \n \n17 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2 \n(rev. \n23 \nApr. \n22, \n2026), \nhttps://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf \n[https://perma.cc/FY3P-8SCM]. \n18 As PJM Manual 13 notes, PJM members have Member Load shed plans, which, among other things, “recognize \npriority and critical load including: Essential health and public safety facilities such as hospitals, police, fire facilities, \n911 facilities, wastewater treatment facilities; Facilities providing electric service to facilities associated with Bulk \nElectric System including off-site power to generating stations, substation light and power; Critical natural gas \ninfrastructure used to supply gas pipeline pumping plants, processing and production facilities; and \nTelecommunication facilities.”  PJM Manual 13, section 2.3.2."},{"page":10,"startToken":3323,"endToken":3564,"text":"10 \naddress the system conditions.  As directed by PJM, those Electric Distributors then reduce \nload in accordance with PJM’s emergency action.       \n44. \nFigure 3, below, shows how an Interim Resource Adequacy Service Action fits into PJM’s \nexisting Emergency Procedures framework. \nFigure 3: PJM Emergency Procedures with Interim Resource Adequacy Service (IRAS) \n \n \n \n  \n \n45. \nAs shown in Figure 3, the Interim Resource Adequacy Service Action precedes Pre-\nEmergency Load Management Reductions in PJM’s order of operations to maintain \nreliability.   \n46. \nIn this example, the EEA1 continues, and PJM Dispatchers then proceed to Pre-Emergency \nLoad Management Reductions, in keeping with the status quo steps set forth in PJM \nManual 13.19   \n47. \nThe Pre-Emergency Load Management Reductions address the RTO-wide emergency.  \nPJM Dispatch cancels the Pre-Emergency Load Management Reductions and Interim \nResource Adequacy Service Actions, when appropriate. \nC. \nExample 3—Real-Time Interim Resource Adequacy Service Action, Potential \nInterconnection Reliability Operating Limit Violation \n48. \nIn my next real-time example, there is a potential IROL violation.  Certain facilities, known \nas IROL facilities, can significantly impact system reliability if loaded above a designated \nlimit.20  If an IROL facility’s designated limits are exceeded, this has the potential to result \n \n19 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2, \n(rev. \n23 \nApr. \n22, \n2026), \nhttps://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf \n[https://perma.cc/FY3P-8SCM]. \n20 PJM Manual 13, section 5.5 (including identification of IROL facilities)."},{"page":11,"startToken":3564,"endToken":4045,"text":"11 \nin wide-area voltage collapse.21  Therefore, PJM Dispatch must quickly act to mitigate \nIROL violations.   \n49. \nAn IROL violation, unlike a PJM RTO-wide emergency, occurs when one or more IROL \nfacilities between zones become overloaded or is otherwise experiencing zonal capacity \nshortages.  In my example, PJM’s response to a potential IROL violation includes issuance \nof an Interim Resource Adequacy Service Action. \n50. \nPJM monitors potential IROL violations via PJM Energy Management System, which \nautomatically identifies zones and loads that are at risk of triggering IROL facilities to \nexceed their limits.     \n51. \nIn the event of a potential IROL violation, PJM engages in similar steps and notifications \nin real-time described in Example 2, above, but does so in a more targeted manner.  For \nexample, the response to the potential IROL violation may not require curtailment of all \nnon-firm exports to the extent the exports do not exacerbate the potential IROL violation. \n52. \nIn this case, for example, let’s say the Dominion Zone is experiencing a transmission \ncapacity scarcity event resulting from a potential IROL violation due to overloading of an \nIROL facility in West Virginia, e.g., AP South.  In response, it makes little sense for PJM \nDispatchers to curtail non-firm exports to the West or North of the PJM system.  However, \nPJM may require curtailment of non-firm exports between PJM and areas to the South that \nare flowing power across the AP South IROL Reactive Interface to mediate the potential \nIROL violation.      \n53. \nSimilarly, when PJM Dispatchers issue an Interim Resource Adequacy Service Action in \nresponse to the potential IROL violation, it is a more targeted Interim Resource Adequacy \nService Action than the pro-rata load reductions across multiple Electric Distributor \nzones/areas issued in Example 2, above.  If load in a particular Electric Distributor \nzone/area is not negatively impacting transmission flows into the Dominion Zone, load \nreduction in that zone/area may not have any effect on the Dominion Zone.   \n54. \nThe Interim Resource Adequacy Service Action, in the event of an IROL violation, will \nrequire similar steps in real-time as an Interim Resource Adequacy Service Action across \nthe entire PJM RTO Region, except that PJM Dispatchers will only deploy load reductions \nup to the maximum IRAS amounts PJM determined for those affected Electric \nDistributors’ zones/areas needed to alleviate the transmission capacity scarcity event \nwithin that specific zone/area.   \n55. \nThrough distribution factor modeling from its Energy Management System, PJM will \nidentify the Electric Distributors’ zone(s)/area(s) in which an Interim Resource Adequacy \nService Action will have the greatest impact in alleviating the IROL violation.  PJM will \nthen direct those relevant Electric Distributors to reduce load.  The Electric Distributor, in \n \n21 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2, \n(rev. 23Apr. 22, 2026), https://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf [https://perma.cc/FY3P-\n8SCM]."},{"page":12,"startToken":4045,"endToken":4078,"text":"12 \ncoordination with applicable states, Load Serving Entities, and Large Loads, will, in turn, \ndirect specific loads to reduce in response to the Interim Resource Adequacy Service \nAction. \n56. \nThis concludes my affidavit."},{"page":13,"startToken":4078,"endToken":4169,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \n) \nPJM Interconnection, L.L.C. \n) \nDocket No. ER26-____-000 \n \n \n \n) \n \nVERIFICATION \n \n \nI, Christopher Pilong, state, under penalty of perjury, that I am the Christopher Pilong \nreferred to in the foregoing document entitled, “Affidavit of Christopher Pilong on Behalf of PJM \nInterconnection, L.L.C.,” that I have read the same and am familiar with the contents thereof, and \nthat the facts set forth therein are true and correct to the best of my knowledge, information, and \nbelief. \n \n \n/s/ Christopher Pilong \n \nChristopher Pilong"}],"sections":[{"p":1,"at":0,"title":"Attachment C","method":"printed heading","endPage":2,"endAt":234,"startToken":0,"endToken":46},{"p":2,"at":234,"title":"I. Introduction","method":"printed heading","endPage":2,"endAt":238,"startToken":46,"endToken":47},{"p":2,"at":238,"title":"Introduction","method":"printed heading","endPage":3,"endAt":155,"startToken":47,"endToken":429},{"p":3,"at":155,"title":"II. Overview of Practices When Capacity Shortages Give Rise to Emergency Procedures","method":"printed heading","endPage":3,"endAt":1143,"startToken":429,"endToken":595},{"p":3,"at":1143,"title":"A. Steps in Real-Time Prior to Emergency Actions","method":"printed heading","endPage":6,"endAt":3,"startToken":595,"endToken":1424},{"p":6,"at":3,"title":"III. Addition of Interim Resource Adequacy Service Emergency Procedures to Existing","method":"printed heading","endPage":7,"endAt":2384,"startToken":1424,"endToken":2272},{"p":7,"at":2384,"title":"A. Example 1—Day-Ahead Interim Resource Adequacy Service Alert","method":"printed heading","endPage":8,"endAt":2134,"startToken":2272,"endToken":2734},{"p":8,"at":2134,"title":"B. Example 2—Real-Time Interim Resource Adequacy Service Action, RTO-","method":"printed heading","endPage":10,"endAt":970,"startToken":2734,"endToken":3457},{"p":10,"at":970,"title":"C. Example 3—Real-Time Interim Resource Adequacy Service Action, Potential","method":"printed heading","endPage":13,"endAt":619,"startToken":3457,"endToken":4169}]}