ER26-3515-000 · 2026-08-13 · PJM Interconnection, L.L.C.

Attachment C IRAS - Pilong Affifdavit .pdf

Attachment C 
Affidavit of Christopher Pilong on 
Behalf of PJM Interconnection, L.L.C.

2 
UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
) 
PJM Interconnection, L.L.C. 
) 
Docket No. ER26-____-000 
 
 
 
) 
 
AFFIDAVIT OF CHRISTOPHER PILONG 
ON BEHALF OF PJM INTERCONNECTION, L.L.C. 
 
I. 
Introduction 
1. 
My name is Christopher Pilong.  My business address is 2750 Monroe Boulevard, 
Audubon, Pennsylvania, 19403.  I am Senior Director of Operations Planning for PJM 
Interconnection, L.L.C. (“PJM”).  I am submitting this affidavit on behalf of PJM to discuss 
when and how PJM would utilize the Interim Resource Adequacy Service (“IRAS”) to 
manage system reliability.  Specifically, in this affidavit, I explain how PJM will generally 
follow its existing processes and procedures in calling for IRAS load reductions and 
provide some examples of how it will work in practice.   
2. 
I joined PJM in November 2001.  Currently, as Senior Director of Operations Planning, I 
am responsible for the Transmission Operations Department, Generation Department, 
Transmission Service Department, and Outage Analysis Technologies Department.  These 
departments perform near-term transmission outage analysis and approvals, generation 
outage analysis and approvals, facilitate annual Black Start Unit commitments, support and 
develop operational tools, implement and comply with all North American Energy 
Standards Board business rules regarding Available Flowgate Capability/Available 
Transfer Capability, perform gas-electric coordination activities, as well as many other 
tasks to prepare for, and support, real time operations.  The teams also perform seasonal 
reliability assessments, support the various tools and applications utilized in these 
processes, and coordinate directly with the Market Services Division and System Planning 
Division.   
3. 
Previously, as Director, Dispatch, I was responsible for the oversight and operation of the 
Valley Forge and Milford Control Centers.  This function included ensuring the reliable 
operation of the power grid, in accordance with all PJM and North American Electric 
Reliability Corporation (“NERC”) reliability standards pertaining to the functions of 
Reliability Coordinator, Balancing Authority, and Transmission Operator.  In addition, I 
was responsible for ensuring the efficient economic dispatch of the system under the 
existing PJM market rules and neighboring Joint Operating Agreements.   
4. 
Prior to that position, I served as a Reliability Engineer and then Manager – Reliability 
Engineering.  As Manager for the Reliability Engineering Group, I managed the group 
responsible for coordinating day-ahead and real-time operating plans among PJM staff, 
PJM Transmission Owners, PJM Generation Owners, and our neighboring entities.  I 
performed these functions directly in my earlier role as a Reliability Engineer.  I hold a

3 
Bachelor of Science degree in Electrical Engineering from Lehigh University and a Master 
of Business Administration degree from Villanova University. 
II. 
Overview of Practices When Capacity Shortages Give Rise to Emergency Procedures   
5. 
As set forth in section 2.1 of PJM Manual 13, “PJM is responsible for determining and 
declaring that an Emergency is expected to exist, exists, or has ceased to exist in any part 
of the PJM [regional transmission organization (“RTO”)] or in any other Control Area that 
is interconnected directly or indirectly with the PJM RTO.  1.”2 
6. 
In PJM, there are three general levels of Emergency Procedures for capacity shortages, and 
an advisory level.   
7. 
Prior to the Operating Day, PJM may issue advisories and/or alerts (see Figure 1, below).  
The advisory level is general in nature and for elevated awareness “only and may be issued 
one or more days in advance of the Operating Day.”3  Emergency Procedure Alerts may 
be “issued one or more days in advance of the Operating Day for elevated awareness and 
to give time for advanced preparations.”4   
Figure 1: Advisory and Alerts5 
 
A. 
Steps in Real-Time Prior to Emergency Actions 
8. 
PJM Dispatchers monitor projected and current reserves and determine whether actions are 
needed to maintain reserves within the required limits.  In accordance with PJM Manual 
13, before entering into capacity-related emergency actions in real-time, PJM Dispatch will 
 
 
2 Systems Operations Division, PJM Manual 13: Emergency Operations, PJM Interconnection, L.L.C., section 2.1 
(rev. 
98, 
June 
24, 
2026), 
https://www.pjm.com/-/media/DotCom/documents/manuals/m13.pdf 
[https://perma.cc/HE9Y-BNQK] (“PJM Manual 13”). 
3 PJM Manual 13, section 2.3.  
4 PJM Manual 13, section 2.3.  
5 PJM Manual 13, section 2.3.

4 
use available generation and economic demand response, based on economic dispatch, 
which ensures that Real-Time Locational Marginal Prices reflect actual system conditions.6   
9. 
Second, as set forth in PJM Manual 13, if generation and economic demand resources are 
not sufficient to maintain reserves, PJM Dispatch will then recall energy from its Capacity 
Resources by curtailing non-firm export transactions, i.e., interchange transactions, in 
accordance with Part II of the PJM Open Access Transmission Tariff (“Tariff”).   
10. 
PJM Dispatch will also have declared a NERC Energy Emergency Alert Level 1 (“EEA1”), 
as required by NERC Standard EOP-011 Attachment 1, via the Reliability Coordinator 
Information System and Emergency Procedures webpage.7   
11. 
There are three levels of NERC Energy Emergency Alert Levels (EEA1 through EEA3), 
with an EEA3 being the highest alert level.  “EEA1 signals that PJM foresees or is 
experiencing conditions where all available resources are scheduled to meet firm load, firm 
transactions, and reserve commitments, and is concerned about sustaining its required 
Contingency Reserves.”8  “An EEA3 is issued when [PJM] is unable to meet minimum 
Contingency Reserve Requirements.”9 
12. 
Third, if system conditions remain constrained and reserves are projected to be short of 
requirements, assuming PJM’s new, yet-to-be-effective transmission service products—
Non-Firm Contract Demand Service (“CDS”) and Interim Network Integrated 
Transmission Service (“Interim NITS”) are effective, PJM may direct curtailment of Non-
Firm CDS and/or Interim NITS transmission service.10 
13. 
Fourth, if system conditions remain constrained and reserves are projected to be short of 
requirements, then PJM will curtail the new IRAS load as outlined in the Examples below. 
14. 
Fifth, if a system emergency develops, then PJM will initiate Steps 1 through Step 10 of 
the Capacity Emergency procedures as necessary to maintain the reliability of the grid.  If 
Step 10 (Manual Load Dump Action) is reached, this may require firm load to shed 
pursuant to emergency actions.  PJM members are expected to implement all emergency 
procedures based on the timeliness associated with each specific procedure.11 
 
6 PJM Manual 13, section 2.3.2. 
7 PJM Manual 13, section 2.3.2. 
8 PJM Manual 13, section 2.3.1. 
9 PJM Manual 13, section 2.3.2. 
10 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209, at P 551 (2026) (“[W]e find PJM’s proposal to curtail Interim 
NITS and [Non-Firm Contract Demand] transmission service prior to deployment of its Pre-Emergency Load 
Response Program, or in response to a transfer capability shortage as a result of system reliability conditions, to be 
just and reasonable because it is consistent with how Non-Firm [Point-to-Point Service] is curtailed. . . . [W]e find 
that PJM’s proposal to curtail Interim NITS during capacity or reserve shortages is just and reasonable and consistent 
with both the nature of the transmission service as a non-firm transmission service for which Eligible Customers do 
not pay generation capacity charges, and the need to maintain reliability.” (footnote omitted)).  
11 PJM Manual 13, section 2.3.

5 
B. 
Steps for Real-Time Emergency Actions Set Forth in PJM Manual 13 
15. 
Importantly, while there is a sequence of escalating emergency action steps set forth in 
PJM Manual 13, the rapidness of system events influences the timing and order of actions 
necessary to maintain system reliability.  Therefore, PJM Dispatchers “have the flexibility 
to implement emergency procedures in whatever order is required to ensure system 
reliability.12  Likewise, they have the flexibility to exit emergency procedures in a different 
order than they were implemented.”13 
16. 
Figure 2, below, excerpted from PJM Manual 13, illustrates the escalating emergency 
actions that PJM may take and/or require of Members under the status quo rules.14  
Figure 2. 
 
17. 
As Figure 2, above, demonstrates, under current Emergency Procedures, the first step when 
an emergency action is declared is to require Pre-Emergency Load Management 
Reductions, which essentially require a class of Demand Resources and DER Aggregation 
Resources to reduce load.   
18. 
At the most extreme, PJM will declare an EEA3, in which PJM may call for a Manual Load 
Dump (i.e., shedding load taking NITS), a last-resort emergency instruction issued by PJM, 
triggered during severe capacity deficiencies or critical transmission overloads when all 
other operational steps have failed.   
 
12 PJM Manual 13, section 2.3. 
13 PJM Manual 13, section 2.3. 
14 PJM Manual 13, section 2.3.

6 
III. 
Addition of Interim Resource Adequacy Service Emergency Procedures to Existing 
Emergency Procedures in PJM Manual 13 
19. 
New Large Loads are developing more quickly than generation and transmission can be 
built.  As a result, this may impact the ability for PJM to maintain a reliable system and 
continue to meet the demand for existing customers and maintain reserve requirements 
during times of peak demand and/or significant generator outages.  Therefore, a new 
operational tool is needed to ensure the current level of reliability for our customers is 
maintained.   
20. 
IRAS, as proposed, is an additional load reduction service that PJM may deploy in real-
time, starting with the 2027/2028 Delivery Year.  As part of this filing, PJM is proposing 
a new term, “Interim Resource Adequacy Service Action,” to mean “an Operating 
Instruction, as defined by NERC, issued from the Office of the Interconnection to reduce 
load prior to calling on Pre-Emergency Load Management Reductions after determining 
that available economic real-time supply may not be sufficient to maintain reserves to meet 
applicable Reserve Requirements and/or Interconnection Reliability Operating Limits 
(“IROL”) within prescribed limits and prevent cascading outages.”15 
21. 
The IRAS framework is intended to operate as both a forward-looking reliability assurance 
mechanism and an operational tool. The identification of an IRAS requirement for each 
Electric Distributor’s zone/area establishes the reliability obligation applicable to affected 
load, while PJM’s real-time operating processes determine when and how that obligation 
is activated based on actual system conditions. 
22. 
The IRAS framework therefore does not require PJM to reduce affected load whenever an 
IRAS requirement exists. Rather, the IRAS requirement establishes an operational 
reliability resource available to PJM, which can be called upon when actual system 
conditions indicate that the reliability need addressed by the IRAS requirement is 
materializing. 
23. 
PJM will incorporate IRAS-designated load, that PJM will determine under the IRAS rules, 
into its operating models, operating plans, and real-time reliability assessments.  PJM’s 
existing real-time Energy Management System and contingency-analysis processes 
provide the platform for evaluating system conditions and identifying potential reliability 
violations. 
24. 
If the proposed IRAS framework is accepted by the Commission, PJM Manual 13 will be 
revised to establish the specific details of how PJM will deploy IRAS through new 
Emergency Procedures, i.e., Emergency Alerts, Actions, Advisories, and/or Warnings.  As 
is the norm, PJM will work with stakeholders to revise PJM Manual 13 to establish specific 
language for IRAS Emergency Procedures after the IRAS proposal has been filed with the 
 
15 Tariff, Definitions – Interconnection Reliability Operating Limits; Glossary Terms, North American Electric 
Reliability Corporation, https://www.nerc.com/glossary-of-terms?alpha=I [https://perma.cc/TZ9W-MZ4K] (last 
visited Aug. 11, 2026) (defining Interconnection Reliability Operating Limit as “[a] System Operating Limit that, if 
violated, could lead to instability, uncontrolled separation, or Cascading outages that adversely impact the reliability 
of the Bulk Electric System.”).

7 
Commission.  Any revisions to PJM Manual 13 to reflect IRAS will not become effective 
unless the Commission accepts the IRAS framework.   
25. 
That said, I will provide, below, a general overview of how IRAS, as a new operational 
tool, will be deployed.  PJM expects that existing Emergency Procedures set forth in PJM 
Manual 13 will not change except to add IRAS as another potential tool at PJM’s disposal 
that PJM may deploy in efforts to address a potential emergency prior to Pre-Emergency 
Load Management Reduction Action.   
26. 
In day-ahead, Interim Resource Adequacy Service Alerts may precede a Maximum 
Generation Alert (“Max Gen Alert”).  Thus, IRAS provides a new, lower-level Emergency 
Procedure Alert that PJM Dispatch may issue prior to a Max Gen Alert.  In real-time, PJM 
Dispatch will deploy Interim Resource Adequacy Service Actions before Pre-Emergency 
Load Management Reduction Actions.  Thus, in real-time, IRAS provides a new step, at 
PJM’s disposal, prior to impacting existing customers.  If the Interim Resource Adequacy 
Service Actions do not address the emergency, PJM Dispatchers would then take necessary 
Pre-Emergency Load Management Reduction Actions and declare escalating Emergency 
Procedures as necessary. 
27. 
In the next subsections of my affidavit, I explain how a PJM Dispatcher may deploy IRAS.  
In Example 1, below, I describe how PJM issues an Interim Resource Adequacy Service 
Alert in the day-ahead.  In Example 2, I describe a scenario when, in real-time, PJM 
experiences an RTO-wide reliability and/or capacity shortfall event and responds by 
deploying IRAS.  In Example 3, in real-time, PJM experiences an IROL and responds by 
deploying IRAS.   
28. 
It is important to note that prior to the start of each Delivery Year, the megawatts (“MW”) 
quantity of IRAS that will be required to respond to an Interim Resource Adequacy Service 
Alert will be determined by PJM for each Electric Distributor zone/area.  This value will 
be utilized by PJM Dispatch in their system projections, alerts and actions in the examples 
below (e.g., PJM may determine, for example, that prior to the Delivery Year, there may 
be 4 gigawatts of IRAS available across the RTO, with smaller amounts assigned to an 
Electric Distributor zone/area for real-time curtailment if an Interim Resource Adequacy 
Service Action is issued).   
A. 
Example 1—Day-Ahead Interim Resource Adequacy Service Alert 
29. 
As PJM operators look ahead to the next Operating Day, they periodically evaluate 
forecasted demand and scheduled supply.  They also evaluate, among many other things, 
expected weather conditions to determine, e.g., wind and solar resource availability, 
temperature, etc. PJM schedules reserves on a day-ahead basis to address such 
contingencies and variabilities.   
30. 
In this example, in day-ahead, PJM operators reasonably expect that insufficient supply 
will be available to meet expected real-time demand and reserves for the next Operating 
Day.  PJM’s operators will have available to them, on a daily basis, the expected aggregate 
amount of Interim Resource Adequacy Service MW that can be reduced at the Electric

8 
Distributor level.  If reduction of some/all of the IRAS load may be necessary to meet  real-
time demand and reserve requirements, PJM Dispatchers may elect to issue an Interim 
Resource Adequacy Service Alert in day-ahead.   
31. 
PJM issues an Interim Resource Adequacy Service Alert before and/or concurrently with 
a Max Gen Alert/Load Management Alert.  The Interim Resource Adequacy Service Alert 
puts all Eligible New Large Loads on notice that PJM could request reductions in load in 
quantities equal to or lesser than each Electric Distributor zone/area’s assigned IRAS 
amounts during the next Operating Day.  However, under an alert, no IRAS reduction is 
actually requested or implemented.  This is simply a notice to prepare and will be issued to 
provide maximum notice possible. 
32. 
In this example, PJM also elects to issue a Max Gen Alert/Load Management Alert in day-
ahead.  
33. 
As explained in section 2.3.1 of PJM Manual 13, “The intent of the alert(s) is to keep all 
affected system personnel aware of the forecasted and/or actual status of the PJM RTO.  
All alerts and cancellation thereof are broadcast on the ALLCALL system and posted to 
selected PJM websites to assure that all members receive the same information.  Alerts are 
issued in advance of a scheduled load period to allow sufficient time for members to 
prepare for anticipated initial capacity shortages.”16   
34. 
For Examples 2-3, where PJM issues an Interim Resource Adequacy Service Action in 
real-time, it can be assumed that PJM Dispatch would have already issued an Interim 
Resource Adequacy Service Alert.  Thus, in real-time, PJM’s members are already aware 
that potential Emergency Procedure actions may take place in real-time.  However, it 
should be noted that not all conditions can be forecasted, and it is not a requirement that an 
Interim Resource Adequacy Service Alert be issued prior to an Interim Resource Adequacy 
Service Action.  Therefore, it is possible to have no day-ahead alerts, but nevertheless have 
an Interim Resource Adequacy Service Action or other Actions issued during the Operating 
Day. 
B. 
Example 2—Real-Time Interim Resource Adequacy Service Action, RTO-
Wide Emergency 
35. 
In real-time, PJM faces an RTO-wide system emergency.  Prior to directing an Interim 
Resource Adequacy Service Action, however, PJM has several other ways to address RTO-
wide reliability concerns.   
36. 
First, in keeping with the practice in place today and set forth in PJM Manual 13, PJM 
Dispatchers deploy available generation and economic demand resources, in economic 
dispatch order while maintaining required reserves.  Even with all available economic 
resources dispatched, PJM’s operators may still face a potential reliability issue and 
capacity shortfall in real-time. 
 
16 PJM Manual 13, section 2.3.1.

9 
37. 
Second, in keeping with the practice in place today and as set forth in PJM Manual 13, if 
issues persist or are projected to deteriorate, PJM operators may require non-firm 
interchange transaction curtailment, as needed.   
38. 
PJM Dispatchers will have already issued an EEA1.  After the first and second steps taken 
by PJM Dispatchers, PJM remains under an EEA1.   
39. 
Third, assuming for purposes of this example that the yet-to-be-effective Interim NITS and 
Non-Firm CDS transmission services are now in place, PJM may curtail Non-Firm CDS, 
followed by Interim NITS.   
40. 
Fourth, after all non-firm transmission services are curtailed, PJM Dispatchers would then 
issue the new Interim Resource Adequacy Service Action prior to deployment of a Pre-
Emergency Load Management Reduction Action. 
41. 
PJM intends to issue an Interim Resource Adequacy Service Action through the status quo 
notification processes set forth in PJM Manual 13.17  Pursuant to the Interim Resource 
Adequacy Service Action, PJM prioritizes load reduction from those Electric Distributor 
zones/areas where New Large Loads have not brought their own new capacity and do not 
have Allocated Reliability Backstop Procurement Unforced Capacity Megawatts (“RBP 
UCAP MW”) sufficient to cover their capacity needs.  PJM’s operators will direct the IRAS 
reduction to Electric Distributor zones/areas as needed based on system conditions.   
42. 
More specifically, through an Interim Resource Adequacy Service Action, PJM 
Dispatchers will direct Electric Distributors to implement reductions in load up to, and 
capped at, the pre-Delivery Year IRAS obligations they were assigned.  Importantly, PJM 
will not direct specific New Large Loads to reduce load, even though Electric 
Distributors—in coordination, where applicable, with relevant states, Load Serving 
Entities, and New Large Loads—may issue more specific directives to specific retail 
customers.18  PJM will only direct load reduction of an aggregate MW IRAS within the 
zone or area. 
43. 
In this example, the Interim Resource Adequacy Service Action is deployed in response to 
a Region-wide emergency.  As such, based on the maximum IRAS amounts assigned to 
each Electric Distributor zone/area, PJM Dispatchers call for some or all Electric 
Distributors to reduce load across the PJM RTO Region in the manner they see fit to 
 
17 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2 
(rev. 
23 
Apr. 
22, 
2026), 
https://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf 
[https://perma.cc/FY3P-8SCM]. 
18 As PJM Manual 13 notes, PJM members have Member Load shed plans, which, among other things, “recognize 
priority and critical load including: Essential health and public safety facilities such as hospitals, police, fire facilities, 
911 facilities, wastewater treatment facilities; Facilities providing electric service to facilities associated with Bulk 
Electric System including off-site power to generating stations, substation light and power; Critical natural gas 
infrastructure used to supply gas pipeline pumping plants, processing and production facilities; and 
Telecommunication facilities.”  PJM Manual 13, section 2.3.2.

10 
address the system conditions.  As directed by PJM, those Electric Distributors then reduce 
load in accordance with PJM’s emergency action.       
44. 
Figure 3, below, shows how an Interim Resource Adequacy Service Action fits into PJM’s 
existing Emergency Procedures framework. 
Figure 3: PJM Emergency Procedures with Interim Resource Adequacy Service (IRAS) 
 
 
 
  
 
45. 
As shown in Figure 3, the Interim Resource Adequacy Service Action precedes Pre-
Emergency Load Management Reductions in PJM’s order of operations to maintain 
reliability.   
46. 
In this example, the EEA1 continues, and PJM Dispatchers then proceed to Pre-Emergency 
Load Management Reductions, in keeping with the status quo steps set forth in PJM 
Manual 13.19   
47. 
The Pre-Emergency Load Management Reductions address the RTO-wide emergency.  
PJM Dispatch cancels the Pre-Emergency Load Management Reductions and Interim 
Resource Adequacy Service Actions, when appropriate. 
C. 
Example 3—Real-Time Interim Resource Adequacy Service Action, Potential 
Interconnection Reliability Operating Limit Violation 
48. 
In my next real-time example, there is a potential IROL violation.  Certain facilities, known 
as IROL facilities, can significantly impact system reliability if loaded above a designated 
limit.20  If an IROL facility’s designated limits are exceeded, this has the potential to result 
 
19 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2, 
(rev. 
23 
Apr. 
22, 
2026), 
https://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf 
[https://perma.cc/FY3P-8SCM]. 
20 PJM Manual 13, section 5.5 (including identification of IROL facilities).

11 
in wide-area voltage collapse.21  Therefore, PJM Dispatch must quickly act to mitigate 
IROL violations.   
49. 
An IROL violation, unlike a PJM RTO-wide emergency, occurs when one or more IROL 
facilities between zones become overloaded or is otherwise experiencing zonal capacity 
shortages.  In my example, PJM’s response to a potential IROL violation includes issuance 
of an Interim Resource Adequacy Service Action. 
50. 
PJM monitors potential IROL violations via PJM Energy Management System, which 
automatically identifies zones and loads that are at risk of triggering IROL facilities to 
exceed their limits.     
51. 
In the event of a potential IROL violation, PJM engages in similar steps and notifications 
in real-time described in Example 2, above, but does so in a more targeted manner.  For 
example, the response to the potential IROL violation may not require curtailment of all 
non-firm exports to the extent the exports do not exacerbate the potential IROL violation. 
52. 
In this case, for example, let’s say the Dominion Zone is experiencing a transmission 
capacity scarcity event resulting from a potential IROL violation due to overloading of an 
IROL facility in West Virginia, e.g., AP South.  In response, it makes little sense for PJM 
Dispatchers to curtail non-firm exports to the West or North of the PJM system.  However, 
PJM may require curtailment of non-firm exports between PJM and areas to the South that 
are flowing power across the AP South IROL Reactive Interface to mediate the potential 
IROL violation.      
53. 
Similarly, when PJM Dispatchers issue an Interim Resource Adequacy Service Action in 
response to the potential IROL violation, it is a more targeted Interim Resource Adequacy 
Service Action than the pro-rata load reductions across multiple Electric Distributor 
zones/areas issued in Example 2, above.  If load in a particular Electric Distributor 
zone/area is not negatively impacting transmission flows into the Dominion Zone, load 
reduction in that zone/area may not have any effect on the Dominion Zone.   
54. 
The Interim Resource Adequacy Service Action, in the event of an IROL violation, will 
require similar steps in real-time as an Interim Resource Adequacy Service Action across 
the entire PJM RTO Region, except that PJM Dispatchers will only deploy load reductions 
up to the maximum IRAS amounts PJM determined for those affected Electric 
Distributors’ zones/areas needed to alleviate the transmission capacity scarcity event 
within that specific zone/area.   
55. 
Through distribution factor modeling from its Energy Management System, PJM will 
identify the Electric Distributors’ zone(s)/area(s) in which an Interim Resource Adequacy 
Service Action will have the greatest impact in alleviating the IROL violation.  PJM will 
then direct those relevant Electric Distributors to reduce load.  The Electric Distributor, in 
 
21 System Operations Division, PJM Manual 37: Reliability Coordination, PJM Interconnection, L.L.C., section 3.2, 
(rev. 23Apr. 22, 2026), https://www.pjm.com/-/media/DotCom/documents/manuals/m37.pdf [https://perma.cc/FY3P-
8SCM].

12 
coordination with applicable states, Load Serving Entities, and Large Loads, will, in turn, 
direct specific loads to reduce in response to the Interim Resource Adequacy Service 
Action. 
56. 
This concludes my affidavit.

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
) 
PJM Interconnection, L.L.C. 
) 
Docket No. ER26-____-000 
 
 
 
) 
 
VERIFICATION 
 
 
I, Christopher Pilong, state, under penalty of perjury, that I am the Christopher Pilong 
referred to in the foregoing document entitled, “Affidavit of Christopher Pilong on Behalf of PJM 
Interconnection, L.L.C.,” that I have read the same and am familiar with the contents thereof, and 
that the facts set forth therein are true and correct to the best of my knowledge, information, and 
belief. 
 
 
/s/ Christopher Pilong 
 
Christopher Pilong