{"document":{"slug":"filing-er26-3515-pjm-iras","title":"PJM proposes a large-load registry, interim service and bring-your-own capacity","issued":"2026-08-13","accession":"20260813-5118","docket":"ER26-3515-000","group":"PJM filings","filer":"PJM Interconnection, L.L.C.","kind":"filing","file":"sources/originals/20260813-5118_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260813-5118","sha256":"c8e685cd114c739dbd879674f3e913b77f16f18ef2d6d3ff0ab14db8b5322f3a","pages":132,"tokens":42328,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":130,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n  \n  \nPJM Interconnection, L.L.C. \n  )  \nDocket No. ER26-____-000  \n  \n  \n  \n \n \n \nPROPOSAL OF PJM INTERCONNECTION, L.L.C. \nTO ESTABLISH INTERIM RESOURCE ADEQUACY SERVICE AND A LARGE \nLOAD REGISTRY TO ADDRESS SYSTEM RELIABILITY    \n \n \n \n \n \nCraig Glazer \nVice President–Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, D.C.  20005 \n(202) 423-4743  \ncraig.glazer@pjm.com \n \nRyan J. Collins \nVivian W. Chum \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, D.C.  20005 \n(202) 393-1200  \ncollins@wrightlaw.com \nchum@wrightlaw.com \n \nMark J. Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd. \nAudubon, PA  19403 \n(610) 666-8800 \nmark.stanisz@pjm.com  \n \n \nAttorneys for PJM Interconnection, L.L.C. \n \n \nAugust 13, 2026"},{"page":2,"startToken":130,"endToken":353,"text":"TABLE OF CONTENTS \n \nI. \nBACKGROUND .................................................................................................. 13 \nA. \nThe Senior Task Force and Critical Issue Fast Path Stakeholder \nProcesses ................................................................................................... 15 \nB. \nPJM Board Determination ........................................................................ 16 \nC. \nRelated PJM Large Load Filings .............................................................. 18 \nII. \nTHE PROPOSED REFORMS TO THE TARIFF AND THE RAA ARE \nJUST AND REASONABLE AND NOT UNDULY DISCRIMINATORY \nOR PREFERENTIAL ........................................................................................... 21 \nA. \nOverview of Interim Resource Adequacy Service Framework and \nResponsibilities of PJM and Electric Distributors to Implement \nIRAS ......................................................................................................... 21 \n1. \nThe Interim Resource Adequacy Service framework ................... 21 \n2. \nResponsibilities of PJM and Electric Distributors ........................ 25 \nB. \nThe Large Load Registry (RAA, Schedule 11, Section B) ....................... 28 \n1. \nOverwhelming support from PJM stakeholders for a New \nLarge Load Registry to be established and maintained by \nPJM ............................................................................................... 30 \n2. \nThe proposed definition of Large Load is just and \nreasonable ..................................................................................... 31 \n3. \nInformation reported in the Large Load Registry ......................... 36 \na. \nInformation in the Large Load Registry will help \nPJM distinguish Large Loads from New Large \nLoads and identify New Large Loads eligible for \nIRAS ................................................................................. 38 \nb. \nInformation in the Large Load Registry will assist \nin identifying Eligible New Large Loads that may \nbe called on to reduce their load or switch to on-site \nback-up resources pursuant to IRAS ................................. 40 \nc. \nInformation in the Large Load Registry will assist \nPJM operators in determining how best to support \nreliability during periods of insufficient capacity ............. 41"},{"page":3,"startToken":353,"endToken":600,"text":"ii \nd. \nConfidentiality pursuant to Operating Agreement, \nsection 18.17 ..................................................................... 42 \ne. \nReliance on Large Load Registry must reflect \naccurate and complete information on which PJM \nmay determine a baseline .................................................. 43 \n4. \nPJM’s exercise of authority to require information from \nLSEs and Electric Distributors, and to obtain information \nfrom Large Loads and other entities ............................................. 45 \nC. \nNew Large Loads Can Avoid Being Subject to Interim Resource \nAdequacy Service by Bringing New Capacity to Offset Their \nCapacity Needs.  This Is Consistent with the Ratepayer Protection \nPledge and Is a Just and Reasonable Condition to Maintaining \nSystem Reliability ..................................................................................... 49 \n1. \nRequirement for New Large Loads to bring capacity or be \nsubject to load reductions.............................................................. 49 \n2. \nBring Your Own New Capacity arrangements with New \nLarge Load .................................................................................... 50 \na. \nPJM proposes to define BYONC as new megawatts \nof Unforced Capacity ........................................................ 50 \nb. \nPJM is proposing reasonable gating criteria \ndesigned to stimulate development of new capacity ......... 53 \n3. \nTo ensure the capacity benefits of BYONC are real and \nlasting, PJM is proposing certain RPM participation \nrequirements .................................................................................. 55 \n4. \nReporting arrangements between BYONC and New Large \nLoads, and obligations on BYONC of an arrangement ................ 59 \na. \nThe clear two-step process for PJM to recognize \narrangements between New Large Loads and \nBYONC............................................................................. 59 \nb. \nArrangements must be reported to PJM in a timely \nmanner to allow for them to be reflected in the RPM \nAuctions, because an arrangement will not be \neffective for Delivery Years before the BYONC \nclears an RPM Auction ..................................................... 60"},{"page":4,"startToken":600,"endToken":862,"text":"iii \ni. \nReporting BYONC-New Large Load \narrangements for the 2027/2028 and \n2028/2029 Delivery Years ..................................... 61 \nii. \nReporting BYONC-New Large Load \narrangements for the 2029/2030 Delivery \nYear ....................................................................... 62 \niii. \nReporting BYONC-New Large Load \narrangements for the 2030/2031 Delivery \nYear and subsequent Delivery Years ..................... 63 \nc. \nRules for BYONC arrangements ...................................... 63 \nd. \nThe Accredited UCAP value for BYONC subject to \nan arrangement is set in the first Delivery Year the \narrangement is in effect ..................................................... 65 \n5. \nAllocated RBP UCAP MW .......................................................... 67 \n6. \nOnly Eligible New Large Loads will be considered \navailable to provide Interim Resource Adequacy Service, \nand then only to the extent they do not have sufficient \nBYONC to meet their capacity needs ........................................... 69 \n7. \nDetermination of the maximum amount of Interim \nResource Adequacy Service available for a Delivery Year \nfor the PJM Region and each Electric Distributor zone/area ........ 70 \n8. \nPJM is not proposing to extend IRAS to New Large Loads \nlocated in FRR Service Areas ....................................................... 73 \nD. \nLoad Reduction Under Interim Resource Adequacy Service ................... 74 \n1. \nInterim Resource Adequacy Service will be needed only to \naddress potential capacity emergencies or IROL violations ......... 74 \n2. \nHow PJM will call an Interim Resource Adequacy Service \nAction ............................................................................................ 81 \n3. \nElectric Distributors must follow PJM directives to reduce \nmegawatts of load in response to an Interim Resource \nAdequacy Service Action ............................................................. 83 \n4. \nThe IRAS load reduction framework is, at its core, a \nproduct of cooperative federalism that recognizes the \nsignificant role of the states in requiring New Large Loads \nto reduce their load to support reliability pursuant to IRAS ......... 85"},{"page":5,"startToken":862,"endToken":1112,"text":"iv \na. \nDuring an Interim Resource Adequacy Event, PJM \nwill direct a MW quantity of load reduction to the \nrelevant Electric Distributor zone(s)/area(s) ..................... 86 \nb. \nState efforts to develop load reduction programs \nreflect a cooperative federalism framework that is \nsimilar to that embedded in PJM’s proposal ..................... 87 \nc. \nThe division of authority between PJM and the \nstates and/or RERRAs is supported by relevant \nprecedent ........................................................................... 89 \nd. \nThe division of authority preserves the \nCommission’s FPA sections 205 and 206 rights \nover the IRAS framework ................................................. 92 \n5. \nReducing New Large Loads before Pre-Emergency Load \nManagement Reductions (EEA1) is not unduly \ndiscriminatory or preferential ....................................................... 94 \na. \nNew Large Loads are not similarly situated to other \nloads in the PJM Region, constitute a separate, new \nclass of load, and are therefore appropriately subject \nto different treatment......................................................... 95 \nb. \nIRAS is only applicable in Delivery Years when \nNew Large Loads without arrangements with new \ncapacity give rise to a PJM Region Reliability \nRequirement shortfall and provides opportunities \nfor New Large Loads to avoid being subject to load \nreduction under IRAS ....................................................... 97 \nc. \nLoad reduction under Interim Resource Adequacy \nService appropriately treats New Large Loads as \nNITS customers .............................................................. 100 \nE. \nCompensation for Load Reduction Under Interim Resource \nAdequacy Service ................................................................................... 101 \n1. \nThe proposed IRAS compensation approach respects and \nreflects the federal and state division of authority and \nresponsibilities ............................................................................ 101 \na. \nThe proposed IRAS rate is just and reasonable .............. 102 \nb. \nElectric Distributors bear the responsibility, in \nconjunction with applicable state authorities and"},{"page":6,"startToken":1112,"endToken":1301,"text":"v \nNew Large Loads, to implement the compensation \nscheme............................................................................. 104 \n2. \nThe proposed billing indemnification language is just and \nreasonable ................................................................................... 108 \nF. \nConsistent with the Ratepayer Protection Pledge, PJM Is Proposing \nto Exclude New Large Loads from the VRR Curve Until They \nBring New Capacity ................................................................................ 109 \n1. \nExcluding incremental New Large Load Amounts from the \ndemand curve beginning with the 2029/2030 Delivery Year ..... 112 \n2. \nNew Large Loads with BYONC arrangements or Allocated \nRPB UCAP MW will be reflected in the demand curve ............ 115 \n3. \nEach of the three points on the VRR Curve would be \nreduced by the Quantities of New Large Loads for the \nrelevant Base Residual Auction .................................................. 117 \n4. \nThe Incremental Auctions will reflect adjustments of \ncapacity previously committed, including any updated \nadjustments to the Excluded RTO New Large Load \nAmounts and/or Excluded LDA New Large Load Amounts...... 118 \n5. \nPJM will maintain transparency by posting the Variable \nResource Requirement Curve in advance of the RPM \nAuctions ...................................................................................... 119 \nIII. \nCORRESPONDENCE ........................................................................................ 121 \nIV. \nREQUESTED EFFECTIVE DATE AND CONSENT TO \nMODIFICATION OR SEVERANCE OF ISSUES ............................................ 121 \nV. \nDOCUMENTS ENCLOSED .............................................................................. 125 \nVI. \nSERVICE ............................................................................................................ 125 \nVII. \nCONCLUSION ................................................................................................... 126"},{"page":7,"startToken":1301,"endToken":1703,"text":"1200 G Street, N.W., Suite 600 \nWashington, D.C.  20005-3898 \nPhone: 202.393.1200 \nFax: 202.393.1240 \nwrightlaw.com \nAugust 13, 2026 \n \nThe Honorable Debbie-Anne A. Reese \nSecretary \nFederal Energy Regulatory Commission \n888 First Street, N.E., Room 1A \nWashington, D.C.  20426 \n \nRe: \nPJM Interconnection, L.L.C., Docket No. ER26-___-000 \nProposal to Establish Interim Resource Adequacy Service and a Large Load \nRegistry to Address System Reliability  \n \nDear Ms. Reese: \n \nPJM Interconnection, L.L.C. (“PJM”), pursuant to section 205 of the Federal Power \nAct (“FPA”), 16 U.S.C. § 824d, hereby submits revisions to the Reliability Assurance \nAgreement Among Load Serving Entities (“RAA”) and the PJM Open Access \nTransmission Tariff (“Tariff”)1 to establish Interim Resource Adequacy Service \n(“IRAS”)—a service to be implemented by PJM solely during periods when there are \ninsufficient resources to reliably meet demand in real time operations.  When triggered by \nsystem conditions, IRAS will enable PJM to prioritize load reduction in zones/areas where \nNew Large Loads2 have not brought their own new capacity or had their capacity needs \n \n1 In the context of revisions proposed in this filing, the Tariff will be referred to as “proposed Tariff,” and the \nRAA will be referred to as “proposed RAA.”  Capitalized terms not otherwise defined herein shall have the \nmeaning as defined in the Tariff, Amended and Restated Operating Agreement of PJM (“Operating \nAgreement”), RAA, and Consolidated Transmission Owners Agreement.   \n2 Proposed Tariff, Definitions – New Large Load (“‘New Large Load’ shall mean end-use customer load that \nis either (a) a Large Load that goes into service after June 1, 2027, or (b) incremental load in-service after \nJune 1, 2027, that increases the existing end-use customer load at a single electrical site that, prior to such \nincremental load, did not previously meet the definition of Large Load.  However, to the extent three \nconsecutive Delivery Years meet the requirements of Tariff, Attachment DD-4, section IV(b)(iii), then New \nLarge Load shall mean end-use customer load that is either (a) a Large Load that goes into service after June \n1 of the first Delivery Year for which the requirements of Tariff, Attachment DD-4, section IV(b)(iii) are not \nmet or (b) incremental load in-service after June 1 of the first Delivery Year for which the requirements of \nTariff, Attachment DD-4, section IV(b)(iii) are not met that increases the existing end-use customer load at"},{"page":8,"startToken":1703,"endToken":2081,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 2 \n \n \n \ncovered through the Reliability Backstop Procurement (“RBP”).3  New Large Loads can \navoid this condition on taking transmission service by bringing new capacity to the system, \nas described below.  The authority sought herein would only be invoked in those situations \nwhere PJM determines that the available economic real-time supply may be insufficient to \nmaintain reserves to meet applicable Reserve Requirements and/or Interconnection \nReliability Operating Limits (“IROL”) within prescribed limits and prevent cascading \noutages.4   \nThe proposed IRAS framework and the other enclosed revisions fall squarely \nwithin the Federal Energy Regulatory Commission’s (“Commission”) established \ntransmission jurisdiction and wholesale jurisdiction and has been carefully designed to \nrespect the cooperative federalism approach established under the FPA and animating \nseveral other recent landmark Commission determinations, including the large load show \ncause proceedings.5  As such, IRAS respects existing bright-line divisions between retail \n \na single electrical site that, prior to such incremental load, did not previously meet the definition of Large \nLoad.”). \n3 Although the proposed IRAS framework and other revisions proposed herein may refer to the RBP, the two \nfilings are independent of each other.  In short, , IRAS can and should be accepted and made effective as \nrequested.   \n4 The North American Electric Reliability Corporation (“NERC”) defines an Interconnection Reliability \nOperating Limit as “[a] System Operating Limit that, if violated, could lead to instability, uncontrolled \nseparation, or Cascading outages that adversely impact the reliability of the Bulk Electric System.”  Glossary \nTerms, North American Electric Reliability Corporation, https://www.nerc.com/glossary-of-terms?alpha=I \n[https://perma.cc/TZ9W-MZ4K] (last visited Aug. 11, 2026) (defining Interconnection Reliability Operating \nLimit); IRO-009-2 – Reliability Coordinator Actions to Operate Within IROLs, North American Electric \nReliability Corporation, https://www.nerc.com/globalassets/standards/reliability-standards/iro/iro-009-2.pdf \n[https://perma.cc/6MLX-HBHM] (last visited Aug. 11, 2026) (The appropriate NERC Standard: \nIRO-009-2’s purpose is “[t]o prevent instability, uncontrolled separation, or cascading outages that adversely \nimpact the reliability of the interconnection by ensuring prompt action to prevent or mitigate instances of \nexceeding Interconnection Reliability Operating Limits (IROLs).”). \n5 See PJM Interconnection, L.L.C., 193 FERC ¶ 61,217 (2025) (“December 2025 Show Cause Order”); PJM \nInterconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“June 2026 Order to Show Cause”)."},{"page":9,"startToken":2081,"endToken":2372,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 3 \n \n \n \nand wholesale jurisdiction over transmission and distribution.  It is an example of a federal \nregime encouraging (but not mandating) states to re-evaluate load reduction plans, which \nare traditionally in the state jurisdictional bailiwick, while providing PJM the necessary \ntools to address situations where regional resource adequacy shortfalls would jeopardize \nreliability.6  In this regard, it is an example of the federal regime helping to effectuate state \ndecisions associated with the rates, terms, and conditions of retail service.  Moreover, the \nIRAS framework, as proposed here, was developed following consultations and \ndiscussions with states and stakeholders (through the Critical Issue Fast Path (“CIFP”) \nprocess), and the proposal is intentionally designed to avoid conflicts with state authority \nand regimes by leaving retail load reduction plans and retail cost allocation to state-level \nentities, while offering non-mandatory options under the federal tariff to aid collection and \nsettlement of compensation for IRAS. \nAs further evidence of this federal-state division of labor, PJM anticipates \nparticipating in efforts to develop standardized regulatory tools and model retail tariff \nstructures that individual state commissions may consider as they address the integration \nof new large loads and otherwise decide whether and how to act in response to the evolving \nfederal wholesale landscape, inclusive of the IRAS filing. \nTo support the IRAS framework, PJM is also proposing three foundational \nrevisions in this filing.  First, PJM is proposing revisions to the RAA7 to clarify a Load \nServing Entity’s (“LSE”) obligation to bring new capacity in an amount that equals or \n \n6 Under PJM’s existing authority, it may receive load reduction plans from Electric Distributors and other \nMembers.  See, e.g., Operating Agreement, sections 10.4, 11.3.1(e).   \n7 Proposed RAA, section 7.8."},{"page":10,"startToken":2372,"endToken":2798,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 4 \n \n \n \nexceeds its New Large Loads’ peak load or be subject to load reduction requests during \nEmergencies prior to Pre-Emergency Load Management Response.  This principle lays the \nfoundation for the IRAS paradigm in PJM that facilitates large load interconnections in a \nmanner similar to the Southwest Power Pool’s (“SPP”) Conditional High Impact Large \nLoad Service (“CHILLS”) construct, which “allows transmission customers serving [a \ncertain category of load called High Impact Large Loads] to reliably receive transfers of \nenergy [subject to curtailment and interruption] until sufficient designated resources and/or \nnetwork upgrades are in place to support long-term, firm transmission service[,]” where \nterms and conditions of service are “intended to incentivize transmission customers . . . to \nobtain the designated resources and/or complete the network upgrades needed to procure \nlong-term firm transmission service through existing tariff processes.”8  In addition, this \nprinciple is consistent with the Ratepayer Protection Pledge introduced in March 20269 and \nrecently expanded in July 2026,10 which assures that New Large Loads will, at a minimum, \n \n8 June 2026 Order to Show Cause, 195 FERC ¶ 61,211.   \n9 \nRatepayer \nProtection \nPledge, \nThe \nWhite \nHouse \n(Mar. \n4, \n2026), \nhttps://www.whitehouse.gov/releases/2026/03/ ratepayer-protection-pledge/ [https://perma.cc/N8PH-K82T] \n(“Ratepayer Protection Pledge”).  \n10 President Trump’s Ratepayer Protection Pledge Secures American AI Dominance, Protects Consumers, \nThe White House (July 23, 2026), https://www.whitehouse.gov/releases/2026/07/president-trumps-\nratepayer-protection-pledge-secures-american-ai-dominance-protects-consumers/ [https://perma.cc/9VDB-\nB4EH] (“Ratepayer Protection Pledge Announcement”); Data centers pay their way. Ratepayers pay theirs., \nThe White House, https://www.whitehouse.gov/ratepayer-protection-pledge/ [https://perma.cc/3WBQ-\nRXW4] (last visited on Aug. 12, 2026) (“July 2026 Ratepayer Protection Pledge Update”) (identifying 282 \nutilities, cooperatives, data centers, and 23 governors that joined the Ratepayer Protection Pledge, including \n38 data centers: Aligned Data Centers, LLC; Amazon.com, Inc.; Beale Infrastructure Group, LLC; \nCleanSpark LLC; Cloud HQ LLC; Cologix, Inc.; Compass Datacenters, LLC; Core Scientific, Inc.; \nCoreWeave, Inc.; Corscale, LLC; Crusoe Technologies LLC; CyrusOne, Inc.; DataBank Holdings, Ltd.; \nDigital Realty Trust, Inc.; EdgeConnex Inc.; EdgeCore Digital Infrastructure (d/b/a EdgeCore Internet Real \nEstate, LLC); Equinix, Inc.; Google (d/b/a Alphabet Inc.); Iron Mountain Incorporated; Meta Platforms, Inc.; \nMicrosoft Corporation; Nebius Group N.V.; NTT Global Data Centers (d/b/a NTT DATA, Inc.); OpenAI, \nL.L.C.; Oracle Corporation; Oppidan Connect Data Centers (d/b/a Oppidan Investment Company); Prologis, \nInc.; Quality Technology Services, LLC; Rowan Digital Infrastructure Pty. Ltd.; Skybox Datacenters, LLC; \nSTACK Infrastructure, Inc.; Starwood Digital Ventures (d/b/a Starwood Capital Operations, LLC); Stream"},{"page":11,"startToken":2798,"endToken":3179,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 5 \n \n \n \n“build, bring, or buy the new generation resources and electricity needed to satisfy their \nnew energy demands, paying the full cost of those resources whether by building, or buying \nfrom, new or otherwise additive power plants” because it “advances self-sufficiency and \nprotects Americans from higher prices.”11   \nSecond, PJM is proposing revisions to the RAA to establish a Large Load \nRegistry—a database of information pertaining to Large Loads that will be established and \nmaintained by PJM.  The Large Load Registry, while reliant on information provided by \nothers, will aid PJM in administering recent resource adequacy initiatives, including IRAS, \nas well as likely useful in the implementation of other Large Load-related initiatives.12  \nThird, PJM is proposing to revise its Tariff and the RAA to include definitions of Large \nLoad and New Large Load.13   \nIn addition to those revisions, PJM is proposing, beginning with the 2029/2030 \nDelivery Year, to exclude certain New Large Loads from the Variable Resource \nRequirement (“VRR”) Curve to protect residential customers from capacity price \n \nData Centers, L.P.; Switch, Inc.; T5Data Centers, LLC; TA Realty LLC; Vantage Data Centers Management \nCompany, LLC; and x.AI LLC). \n11 Ratepayer Protection Pledge. \n12 In response to the Commission’s show cause directives related to Large Loads, PJM is evaluating how to \nefficiently and cost effectively integrate Large Loads, including Large Load-specific procedures for \ninterconnection studies, processing transmission service requests, and providing transmission service without \ncost shifting.  PJM Interconnection, L.L.C., Motion of PJM Interconnection, L.L.C. to Hold Proceeding in \nAbeyance and Request For Shortened Answer Period and Expedited Treatment, Docket No. EL26-67-000, \nat 5-7 (July 28, 2026).  As part of that evaluation, PJM is assessing the usefulness of a Large Load Registry \nto support such efforts. \n13 Proposed RAA, Definitions – Large Load (“‘Large Load’ shall mean end-use customer(s) load that has a \ncumulative peak load of 50 megawatts [(“MW”)] or greater at a single electrical site behind one or more \npoints of interconnection, where for configurations involving multiple affiliated load facilities or multiple \npoints of interconnection with affiliated load facilities behind them, all affiliated load facilities within a one-\nmile radius will be considered a single electrical site as further described in the PJM Manuals.”)."},{"page":12,"startToken":3179,"endToken":3425,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 6 \n \n \n \nincreases, consistent with the Statement of Principles Regarding PJM issued on January 16, \n2026, by the National Energy Dominance Council (“NEDC”) and the 13 governors of the \nPJM states, and the Ratepayer Protection Pledge introduced in March 2026,14 and as \nrecently expanded in July 2026.15  \nThe IRAS and the related revisions proposed herein support system reliability in \nthe PJM Region.  Insufficient commitments of capacity in the 2027/2028 and 2028/2029 \nReliability Pricing Model (“RPM”) Auctions, primarily driven by the unprecedented \naddition of large loads, most notably data centers, have given rise to resource adequacy \nshortfalls—and associated real-time operational issues that IRAS is intended to address.  \nMore specifically, in Delivery Years when RPM Auctions have failed to secure sufficient \ncapacity, under the proposed IRAS framework, PJM will have the ability to manage \nreal-time operational issues resulting from such shortages through Interim Resource \nAdequacy Service Action.   \nPursuant to IRAS, each Electric Distributor zone/area may be directed by PJM \ndispatchers to reduce load up to the MW quantity of capacity attributable to Eligible New \nLarge Loads in that zone/area.  Each Electric Distributor zone/area, in turn—based upon \nappropriate, documented state-sanctioned load reduction plans that are either already in \nplace or will be developed and refined in conjunction—will determine which load to reduce \nin response to a PJM IRAS directive.   \n \n14 See generally Ratepayer Protection Pledge.  \n15 See generally Ratepayer Protection Pledge Announcement."},{"page":13,"startToken":3425,"endToken":3705,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 7 \n \n \n \nSuch actions by PJM at the regional level and Electrical Distributors at the local \nlevel will be informed and supported by the Large Load Registry established through this \nproposal.  Indeed, the proposed registry will give Electric Distributors and state entities \naccess to critical information they may elect to rely upon when fashioning such load \nreduction protocols (including through recently-announced VA SCC and DCC state-led \nworkshops).  By way of example, IRAS would facilitate a decision by an Electric \nDistributor in conjunction with relevant state entities, as applicable, to decide that specific \nEligible New Large Loads may be reduced during a Delivery Year when IRAS applies, \nbecause such loads are not arranged with sufficient new capacity.  Such new capacity \nwould have either been brought by the New Large Load themselves (“Bring Your Own \nNew Capacity” or “BYONC”) or Allocated RBP Unforced Capacity (“UCAP”) MW.  This \naspect of the IRAS framework is consistent with the Ratepayer Protection Pledge \nintroduced in March 202616 and recently expanded in July 2026,17 which recognizes that \nNew Large Loads “will voluntarily negotiate new, separate rate structures with their \nutilities and relevant State governments wherever they build data centers.”18  The \navailability to PJM of IRAS provides PJM with a new critical operational tool in those \nhours when PJM is projecting its inability to maintain reliability for the region based on \nsystem conditions. \nWhile the enclosed Tariff revisions make clear that IRAS will be available starting \nwith the 2027/2028 Delivery Year, i.e., June 1, 2027, PJM requests that the Commission \n \n16 See generally Ratepayer Protection Pledge. \n17 See generally Ratepayer Protection Pledge Announcement. \n18 Ratepayer Protection Pledge."},{"page":14,"startToken":3705,"endToken":4045,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 8 \n \n \n \naccept the enclosed proposed Tariff and RAA revisions effective October 12, 2026, which \nis 60 days from the date of filing.  First, the requested effective date will allow PJM to start \nbuilding the Large Load Registry and begin accepting information about New Large Loads \nand arrangements with BYONC in time to expeditiously develop and post a new VRR \nCurve with the New Load Loads removed to the extent they do not have arrangements with \nBYONC (which is another aspect of this submission).  \nSecond, Commission action by such date, with the requested effective date, will \nprovide regulatory certainty to parties seeking to enter into bilateral agreements for new \ncapacity and will support the ongoing efforts of the states to establish state-level tariffs to \naddress reduction priorities, as needed.  PJM heard from data center representatives and \nothers on this need for clarity of the IRAS rules as a condition precedent to their finalizing \ncontracts for BYONC generation to offset their New Large Load additions.  Approval of \nthe proposed IRAS framework will provide regulatory certainty to parties seeking to enter \ninto bilateral arrangements for new capacity, including through the ongoing, PJM-\nadministered bilateral matching process aimed at bringing new capacity to PJM. \nThird, in its recent RBP Proposal Filing,19 PJM committed, subject to Commission \napproval, to conduct the RBP as soon as practicable, with a target start of September 30, \n2026, in accordance with the Statement of Principles Regarding PJM by the NEDC and the \n13 governors of the PJM states.20  A zone/area in which New Large Loads have brought \n \n19 PJM Interconnection, L.L.C., Reliability Backstop Procurement to Address Resource Adequacy Concerns \nStemming from Large Loads of PJM Interconnection, L.L.C., Docket No. ER26-3380-000 (July 31, 2026) \n(“RBP Proposal Filing”). \n20 Statement of Principles Regarding PJM, National Energy Dominance Council, 1 (Jan. 16, 2026), \nhttps://www.energy.gov/documents/statement-principles-regarding-pjm \n[https://perma.cc/35HJ-W56E] \n(“NEDC/PJM Governors’ Principles”).  The 13 state signatories are the governors of Delaware, Illinois,"},{"page":15,"startToken":4045,"endToken":4444,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 9 \n \n \n \ntheir own new capacity or have had capacity allocated to it through the RBP will be at \nlower risk of load reduction through the IRAS structure.   \nFourth, approval of IRAS will support ongoing state efforts to establish retail-level, \noperational procedures through which New Large Loads that have not brought their own \nnew capacity may be reduced ahead of residential and traditional industrial customers.   \nEach element of this proposal is just and reasonable.  Nevertheless, in the event the \nCommission deems it necessary, and to help facilitate the Commission’s acceptance of this \nfiling without delay, PJM provides notice that it consents to the Commission’s exercise of \nauthority to modify and/or sever any element of the proposed Tariff and RAA language to \nthe extent necessary and permitted under FPA section 205 and NRG Power Marketing, \nLLC v. FERC,21 where such modification and/or severance is consistent with PJM’s \noverarching objectives in this filing.  While the each of the reforms proposed in this filing \nis just and reasonable and act together to advance important resource adequacy objectives, \nthey may also be considered discretely. \nWhile consenting to each issue being severable, PJM notes that some elements \nbuild on each other, and therefore, Commission modification/severance of an issue may \nrequire a corresponding/conforming modification to another element in order for the \n \nIndiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, \nVirginia, and West Virginia.  Except for in reference to the “NEDC/PJM Governors’ Principles,” reference \nherein to the PJM states shall include the 13 state signatories and the District of Columbia. \n21 NRG Power Mktg., LLC v. FERC, 862 F.3d 108 (D.C. Cir. 2017).  As the Commission has repeatedly \nstated, “[t]he United States Court of Appeals for the District of Columbia Circuit has held that, in certain \ncircumstances, the Commission has ‘authority to propose modifications to a utility’s [FPA section 205] \nproposal if the utility consents to the modifications.’”  N.Y. Indep. Sys. Operator, Inc., 188 FERC ¶ 61,051, \nat P 22 n.36 (2024) (second alteration in original) (citing NRG Power Mktg., 862 F.3d at 114-15); see \nMidcontinent Indep. Sys. Operator, Inc., 180 FERC ¶ 61,141, at P 26 n.29 (2022) (same), order on reh’g, \n182 FERC ¶ 61,096 (2023); ISO New Eng. Inc., 175 FERC ¶ 61,172, at P 16 n.20 (2021) (same)."},{"page":16,"startToken":4444,"endToken":4762,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 10 \n \n \n \noverall framework to function.  For example, PJM’s proposal to shift the VRR Curve based \non the amount of New Large Load with capacity coverage is dependent on the BYONC \nrules being in place.  However, the Large Load Registry, the general obligation that Load \nServing Entities bring new capacity in an amount that equals or exceeds its New Large \nLoads’ peak load, and other elements are discrete and may be severed and addressed \nthrough separate procedures without interlocking concerns.22  For example, the proposed \nrequirement that LSEs designate new capacity in a cumulative amount that equals or \nexceeds its New Large Loads’ peak load or be subject to interim and conditional \ntransmission service in emergency conditions has already been accepted in other regions \nand should be accepted here.23 \nFurther, PJM has been and continues to be in an ongoing dialogue with states and \nother stakeholders regarding the important issues addressed by this filing, including the \ninteraction of federal/state responsibilities.  PJM may, at the behest of the states, host \nworkshops and other fora to advance these discussions.  PJM may, pursuant to FPA \nsection 205, amend aspects of the proposals submitted herein based on the product of those \ndiscussions, and request that the Commission afford additional time for comments and \nconsideration as may be necessary or appropriate. \nAs further discussed below in Part IV, to the extent the Commission exercises such \nauthority to modify the proposed Tariff or RAA language herein pursuant to the FPA and \n \n22 For example, given that IRAS will not be available until June 1, 2027, the compensation program, among \nother proposed rules, may be resolved later without affecting the overall efficacy of this filing. \n23 See, e.g., Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026); Sw. Power Pool, Inc., 195 FERC ¶ 61,196 \n(2026); Sw. Power Pool, Inc., 194 FERC ¶ 61,031 (2026)."},{"page":17,"startToken":4762,"endToken":5204,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 11 \n \n \n \nNRG Power Marketing, PJM respectfully requests that the Commission expressly prescribe \nspecific revised language to provide the “necessary predictability” for PJM to implement \nsuch change(s) even before issuance of an order on compliance.24  PJM’s submittal of any \ncompliance filing implementing such modifications would further constitute PJM’s \nconsent and acceptance of the Commission’s modifications.  PJM has the authority to \nconsent to modifications to PJM’s proposal by the Commission, pursuant to the FPA and \nNRG Power Marketing.  In contrast to the underlying facts in NRG Power Marketing, the \nproposal submitted in this filing was authorized by the PJM Board of Managers (“PJM \nBoard”) and was not the result of a stakeholder-endorsed proposal.25 \nAt bottom, IRAS is a just and reasonable means of addressing the influx of New \nLarge Loads into the PJM Region while maintaining resource adequacy, reliability, and \naffordability in a manner that respects the divide between state and federal authorities and \navoids disrupting existing commercial arrangements.  As the PJM Board recognized in a \n \n24 PJM Interconnection, L.L.C., 175 FERC ¶ 61,137, at P 110 (2021) (first quoting Aera Energy LLC v. \nFERC, 789 F.3d 184, 190-92 (D.C. Cir. 2015) (“[A]ffirming the Commission, finding ‘FERC’s conditional \nacceptance . . . simply required Kern River to substitute one number for another when allocating costs to the \nrolled-in shippers. . . . Because this mechanical change gave Kern River no discretion to adjust its rate models, \nFERC provided sufficient notice to ratepayers.’”); and then quoting Elec. Dist. No. 1 v. FERC, 774 F.2d 490, \n493 (D.C. Cir. 1985) (“[V]acating when the ‘effective date of an order set[] forth no more than the basic \nprinciples pursuant to which the new rates are to be calculated.’” (second alteration in original))).  As the \nCommission elaborated further in PJM Interconnection, mere “direction” without “sufficient detail on each \nelement [of the replacement rate] that [customers/market participants] could determine when their \ntransactions would be subject to [the new rule],” would mean that implementation of the compliance directive \nprior Commission approval would violate the filed rate doctrine.  Id. (quoting Elec. Dist. No. 1, 774 F.2d at \n493 (“[P]urchasers of electricity cannot plan their activities unless they know the cost of what they are \nreceiving, ‘providing the necessary predictability is the whole purpose of the well-established filed rate \ndoctrine.’” (citing Ark. La. Gas Co. v. Hall, 453 U.S. 571, 577 (1981)))). \n25 NRG Power Mktg., 862 F.3d at 112 (noting that PJM developed proposed revisions filed with the \nCommission through its stakeholder process and that the proposed revisions “received overwhelming support \nfrom PJM’s stakeholders”)."},{"page":18,"startToken":5204,"endToken":5598,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 12 \n \n \n \nJanuary 16, 2026 letter,26 IRAS—which, in its earlier iteration, was referred to as “Connect \n& Manage”—is just one part of a multi-pronged, ongoing effort by PJM to respond to the \nchallenges stemming from the influx of Large Loads into the PJM Region.27  Indeed, PJM \ncontinues to make progress on a broader, holistic review of its capacity market, the RPM, \nto identify durable, more holistic solutions to concerns stemming from large load \nadditions.28  More specifically, on May 6, 2026, PJM issued a white paper, Powering \nReliability Through Market Design: Addressing Rising Demand and Constrained Supply, \nand Stimulating Investment to Support Durable Reliability, which inter alia, posed \nfoundational questions facing PJM’s capacity market today and proffered three distinct, \nalbeit not mutually exclusive, paths forward.29  These foundational questions and proposed \npaths forward are a starting point towards more holistic solutions to PJM’s resource \nadequacy concerns.30  This ongoing review is in line with the NEDC/PJM Governors’ \nPrinciples, which urged PJM to “embark on a stakeholder process to reform the capacity \n \n26 Letter of David E. Mills, PJM Board Chair, Board Decisional Letter on Critical Issue Fast Path - Large \nLoad Additions, PJM Board (Jan. 16, 2026), https://www.pjm.com/-/media/DotCom/about-pjm/who-we-\nare/public-disclosures/2026/20260116-pjm-board-letter-re-results-of-the-cifp-process-large-load-\nadditions.pdf [https://perma.cc/P57T-ZXYJ] (“January 2026 Board Letter”). \n27 PJM is proposing Interim Resource Adequacy Service, as opposed to Connect & Manage,” to reflect that \nthe proposal is for a new load reduction service provided by New Large Load that does not bring sufficient \nnew capacity to meet the loads’ resource adequacy needs, and to avoid confusion and conflation between \n“Connect & Manage” and the ongoing efforts to interconnect Large Loads in the Commission’s show cause \nproceeding in Docket No. EL26-67 and PJM’s development (and future filing of) of an FPA section 205 \nproposal to address the Commission-identified issues. \n28 See Powering Reliability Through Market Design: Addressing Rising Demand and Constrained Supply, \nand Stimulating Investment to Support Durable Reliability (May 6, 2026), https://www.pjm.com/-\n/media/DotCom/library/reports-notices/special-reports/2026/20260506-powering-reliability-through-\nmarket-design.pdf [https://perma.cc/3W8Z-M4TQ]. \n29 Id. \n30 PJM Interconnection, L.L.C., PJM to Lead Market Reform Effort to Support Generation Investment and \nReliability, PJM Inside Lines (May 6, 2026), https://insidelines.pjm.com/pjm-to-lead-market-reform-effort-\nto-support-generation-investment-and-reliability/ [https://perma.cc/J2KW-LRW2]."},{"page":19,"startToken":5598,"endToken":6025,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 13 \n \n \n \nmarket to ensure long-term viability and prevent consumers from bearing excessive \nongoing costs,” with an ultimate goal of returning PJM to market fundamentals.31   \nI. \nBACKGROUND \nPJM hosts the largest concentration of data center load in the world.32  “PJM’s load \nforecast predicts peak load growth of 32 gigawatts [(“GW”)] from 2024 to 2030, 30 GW \nof which is projected to be from data centers.”33  Year-over-year, the shortfall of capacity \nsupply needed to meet demand (plus a reasonable reserve margin) has grown despite a net \nincrease of 1,294.4 MW Installed Capacity (“ICAP”) of supply between the 2027/2028 and \n2028/2029 Base Residual Auction (“BRA”).34  In other words, the addition of new supply \nhas not kept pace with rapid large load demand growth, thus giving rise to the significant \ntightening of the capacity market in recent years and subsequent resource adequacy \nshortfalls.  To mitigate the potential reliability risks associated with resource adequacy \n \n31 NEDC/PJM Governors’ Principles at 1; see also PJM Interconnection, L.L.C., CIFP Reliability Backstop \nProcurement – PJM Proposal, 1 (June 11, 2026), https://www.pjm.com/-/media/DotCom/committees-\ngroups/cifp-rbp/2026/20260611/20260611-item-04a---pjm-reliability-backstop-proposal---post-meeting-\nmaterials.pdf [https://perma.cc/X7T7-5RPB] (providing background on stakeholder engagement). \n32 See, e.g., Laila Kearney, Biggest US power grid operator moving forward with plan to manage data \ncenters, Reuters (Nov. 20, 2025), https://www.reuters.com/business/energy/biggest-us-power-grid-operator-\nmoving-forward-with-plan-manage-data-centers-2025-11-19/ [https://perma.cc/7M34-52V4]. \n33 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 8 & n.24 (citing Letter of David E. Mills, PJM \nBoard Chair, PJM Board Letter Implementing CIFP for Large Load Additions,  (Aug. 8, 2025), \nhttps://www.pjm.com/-/media/DotCom/about-pjm/who-we-are/public-disclosures/2025/20250808-pjm-\nboard-letter-re-implementation-of-critical-issue-fast-path-process-for-large-load-additions.pdf \n[https://perma.cc/F9KV-B7HK] (“August 2025 Board Letter”)).  Since the issuance of the August 2025 \nBoard Letter, PJM has published its 2026 Long-Term Load Forecast Report, which anticipates lower peak \ndemand in the near term due to forecasting improvements, revising the peak load forecast for 2030 downward \nby 875 MW, but confirms significant growth in the next 20 years.  PJM Interconnection, L.L.C., PJM’s \nUpdated 20-Year Forecast Continues to See Significant Long-Term Load Growth, PJM Inside Lines (Jan. 14, \n2026), \nhttps://insidelines.pjm.com/pjms-updated-20-year-forecast-continues-to-see-significant-long-term-\nload-growth/ [https://perma.cc/W3UY-F9HE]. \n34 2028/2029 Base Residual Auction Report, PJM Interconnection, L.L.C., 8 (July 14, 2026), \nhttps://www.pjm.com/-/media/DotCom/markets-ops/rpm/rpm-auction-info/2028-2029/2028-2029-bra-\nresults-report.pdf [https://perma.cc/A53K-TXXY] (“2028/2029 BRA Report”)."},{"page":20,"startToken":6025,"endToken":6409,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 14 \n \n \n \nshortfalls, PJM is proposing the IRAS as a mechanism to support reliability while allowing \nNew Large Loads to connect even when new capacity supply lags behind load growth. \nThe 2028/2029 BRA Report, dated July 14, 2026, indicates PJM’s BRA cleared \nshort of the PJM Region Reliability Requirement35 for a second consecutive year.36  \nSpecifically, PJM’s BRA for the 2028/2029 Delivery Year, which ran from June 30, 2026, \nto July 7, 2026, cleared 6,831.3 MW (in UCAP) short of PJM’s Regional Transmission \nOrganization (“RTO”)-wide reliability requirement at the market price cap of \n$325/MW-day.37 \nLast year, PJM’s BRA for the 2027/2028 Delivery Year, which ran from \nDecember 4, 2025, through December, 10, 2025, likewise cleared 6,623 MW short of the \nPJM Region Reliability Requirement, at the market price cap of $333.44/MW-day \n(UCAP).38  As both the Commission and the Department of Energy (“DOE”) have recently \nhighlighted, the pace of “growth [in electricity demand] is now higher than at any point in \nthe past two decades, driven in part by increasing quantities of large commercial and \nindustrial load, most notably data centers, connecting rapidly to the transmission system.”39   \n \n35 Tariff, Part I, section 1, Definitions – O – P - Q – PJM Region Reliability Requirement (“‘PJM Region \nReliability Requirement’ shall mean, for purposes of the Base Residual Auction, the Forecast Pool \nRequirement multiplied by the Preliminary PJM Region Peak Load Forecast, less the sum of all Preliminary \nUnforced Capacity Obligations of [Fixed Resource Requirement (“FRR”)] Entities in the PJM Region; and, \nfor purposes of the Incremental Auctions, the Forecast Pool Requirement multiplied by the updated PJM \nRegion Peak Load Forecast, less the sum of all updated Unforced Capacity Obligations of FRR Entities in \nthe PJM Region.”). \n36 2028/2029 BRA Report at 3. \n37 2028/2029 BRA Report at 3. \n38 PJM Auction Procures 134,479 MW of Generation Resources, PJM Interconnection, L.L.C., 1 (Dec. 17, \n2025), https://www.pjm.com/-/media/DotCom/about-pjm/newsroom/2025-releases/20251217-pjm-auction-\nprocures-134479-mw-of-generation-resources.pdf [https://perma.cc/A89W-W99B]. \n39 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 6 & n.18 (citing Interconnection of Large Loads \nto the Interstate Transmission System, Advance Notice of Proposed Rulemaking, Docket No. RM26-4-000,"},{"page":21,"startToken":6409,"endToken":6688,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 15 \n \n \n \nA. \nThe Senior Task Force and Critical Issue Fast Path Stakeholder \nProcesses  \nOn January 16, 2026, the PJM Board issued a letter announcing its decision on the \nCIFP process addressing large load issues in PJM, which set forth the roadmap for a multi-\npronged approach to addressing resource adequacy challenges, including “accelerat[ing] \nand execute[ing]” a backstop capacity procurement and “address[ing] cost allocation for \nany such procurement, including consideration of mechanisms that assign costs to those \nLSEs that are short as a result of incremental load growth within their service areas.”40  The \nNEDC/PJM Governors’ Principles were issued on the same day.   \nOn March 25, 2026, the PJM Board issued a Problem/Opportunity Statement \ndirecting that PJM implement a “framework that allows qualifying large loads to connect \nto the PJM system subject to defined operational controls, including curtailment during \nspecified system conditions to protect residential customers from potential power \noutages.”41  Subsequently, the Connect and Manage Senior Task Force (“Senior Task \nForce”) was established to address such a framework.  The Senior Task Force met five \ntimes between March and May 2026. \n \nat 2 (Oct. 23, 2025) (“DOE ANOPR”) (citing 2024 Long- Term Reliability Assessment, North American \nElectric \nReliability \nCorporation, \n8 \n(Dec. \n2024, \ncorrected \nJuly \n11, \n2025), \nhttps://www.nerc.com/globalassets/our-work/assessments/2024-ltra_corrected_july_2025.pdf \n[https://perma.cc/Z4D4-AMQT])).  \n40 January 2026 Board Letter at 6. \n41 Problem/Opportunity Statement: Board Directed ‘Connect and Manage’, PJM Interconnection, L.L.C. \n(Mar. \n25, \n2026), \nhttps://www.pjm.com/-/media/DotCom/committees-\ngroups/committees/mrc/2026/20260325/20260325-item-01---2-connect-and-manage---problem-\nstatement.pdf [https://perma.cc/45CR-8Z4S]."},{"page":22,"startToken":6688,"endToken":7067,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 16 \n \n \n \nDuring that period, on April 8, 2026, the PJM Board issued a letter initiating the \nCIFP to engage stakeholders in the development of an RBP proposal (“RBP CIFP”).42  \nSubsequently, on May 19, 2026, the PJM Board issued a second related letter, directing \nthat the scope of the RBP CIFP be expanded to incorporate a separate stakeholder process \nto identify and reduce large load in the PJM Region, when necessary, to maintain sufficient \nreserves to meet applicable Reserve Requirements and IROLs within limits, and avoid \ncascading outages, if available economic generation is not sufficient.  The PJM Board \ndetermined that it would be appropriate to address both the RBP and IRAS in a single CIFP \nprocess in light of the substantive link between these two proposals.   \nThe expanded scope RBP and IRAS CIFP concluded on June 30, 2026, following \neight days of stakeholder meetings over the course of three months.  On June 30, 2026, \nstakeholders submitted advisory votes on 11 different proposals.  All 11 proposals \nregarding the concepts addressed by IRAS failed to achieve two-thirds stakeholder \nsupport.43   \nB. \nPJM Board Determination \nThe PJM Board reviewed the results of the June 30, 2026 stakeholder advisory \nvotes.44  Ultimately, the PJM Board concluded that “[i]n light of the deteriorating resource \n \n42 Letter of David E. Mills, Interim President and CEO, PJM Interconnection, L.L.C. (Apr. 8, 2026), \nhttps://www.pjm.com/-/media/DotCom/about-pjm/who-we-are/public-disclosures/2026/20260408-cifp-\nrbp-initiation-letter.pdf [https://perma.cc/8LM5-9VX3] (stating the intent of the letter was to addresses the \ninitiation of the CIFP – RBP accelerated stakeholder process by the PJM Board).  \n43 PJM Members Committee, MC Voting Results for RBP Proposals Agenda Items 3L through 3X, PJM \nInterconnection, \nL.L.C., \nhttps://www.pjm.com/committees-and-groups/committees/mc \n[https://perma.cc/5CSQ-DP4K] (last visited Aug. 12, 2026) (Scroll to “Meeting Materials” and search for \n2026, click on link for “6.30.2026 Special MC,” scroll to MC Voting Results – Agenda Items 3L to 3X and \nclick on each to view the PDF). \n44 As PJM reported in a recent July 20, 2026 informational filing to the Commission, PJM sought additional \nfeedback on the RBP proposal from stakeholders on specific topics through further polling, which concluded"},{"page":23,"startToken":7067,"endToken":7444,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 17 \n \n \n \nadequacy outlook, and consistent with [the PJM Board] letter issued to the stakeholders on \nMay 19, 2026, . . . PJM must take timely action within its control to begin restoring resource \nadequacy.”45  Thus, the PJM Board directed PJM to file a proposal that includes the \nfollowing elements: \n• IRAS, which will be applicable to “[N]ew Large Loads that, as of \nJune 1, 2027, do not bring sufficient capacity to serve their resource \nadequacy needs and cannot otherwise be served at the 1-in-10 reliability \nstandard[,]” with load reductions under the service occurring before \ndeployment of Pre-Emergency Load Management;46 \n• A Large Load Registry, which will require Electric Distributors “to \nprovide the information necessary for PJM to improve the accuracy and \ntransparency of load forecasts and to administer the [RBP] and \n[IRAS];”47 \n• Compensation for reduced load under IRAS “for Large Load customers \nthat are directed to reduce their consumption” with “[d]eterminations as \nto which retail customers may fund such a program or whether specific \nLarge Loads would be entitled to such compensation (or may waive \nsuch compensation consistent with the Ratepayer Protection Pledge) \nwill be determined by state authorities under state law or [Relevant \nElectric Retail Regulatory Authorities (“RERRA”)] as may be \napplicable[,]” and administered by the relevant “Electric Distributor in \ncoordination with the relevant state authorities or RERRA[.]”48 and \n \non July 10, 2026.  PJM Interconnection, L.L.C., PJM Informational Report on Stakeholder Processes \nAddressing Resource Adequacy for Large Loads, Docket No. EL26-67-000, at 4 (July 20, 2026) (citing PJM \nInterconnection, L.L.C., CIFP – Reliability Backstop Procurement / Connect & Manage, Summarized Poll \nResults \n(2026), \nhttps://www.pjm.com/-/media/DotCom/committees-groups/cifp-rbp/postings/cifp-poll-\nresults-with-comments.pdf [https://perma.cc/T2X8-NKGD] (“CIFP - RBP/Connect & Manage Poll \nResults”)).   \n45 Letter from Paula Conboy, Chair, PJM Board of Managers, Board Decisional Letter on Critical Issue Fast \nPath – Reliability Backstop Procurement and Connect and Manage, 1 (July 27, 2026), \nhttps://www.pjm.com/-/media/DotCom/about-pjm/who-we-are/public-disclosures/2026/20260727-board-\ndecisional-letter-on-cifp-reliability-backstop-procurement-and-connect-and-manage.pdf \n[https://perma.cc/V9Z7-83AH] (“PJM Board July 2026 Decisional Letter”). \n46 PJM Board July 2026 Decisional Letter at 2 (emphasis omitted). \n47 PJM Board July 2026 Decisional Letter at 1. \n48 PJM Board July 2026 Decisional Letter at 2."},{"page":24,"startToken":7444,"endToken":7779,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 18 \n \n \n \n• Exclusion of “[i]ncremental [N]ew Large Loads relative to the forecast \nutilized for the 2028/2029 BRA . . . from the forecast used in future \nRPM auctions for the 2029/2030 Delivery Year and beyond unless and \nuntil there are new supply resources offered into an RPM auction in \nsufficient quantity to cover the [individual] [N]ew Large Load.”49 \nOn July 27, 2026, following a period of intense deliberation, during which the PJM \nBoard considered the merits of the 11 proposals, as well as various letters to the PJM Board, \nthe PJM Board issued a decisional letter directing PJM to submit the IRAS and the other \nenclosed revisions, and to also submit the RBP proposal set forth in this filing.50  In a \nseparate FPA section 205 filing on July 31, 2026, PJM submitted the RBP Proposal \nFiling.51  The proposal in this FPA section 205 filing reflects the IRAS framework, \nincluding the Large Load Registry and compensation for reduced load under IRAS, which \nwas ultimately approved by the PJM Board on July 27, 2026. \nC. \nRelated PJM Large Load Filings  \nThe Interim Resource Adequacy Service proposal is just one of numerous filings \nthat PJM has submitted or will shortly be submitting to the Commission, pursuant to FPA \nsection 205, to address the region’s resource adequacy issues.   \nAs of today’s filing, the following matters have already been filed with the \nCommission: \n• An RBP proposal to establish a one-time procurement of new capacity \nto procure for an RBP target based on the observed capacity shortfall in \nthe 2028/2029 Delivery Year BRA, as adjusted to reflect qualifying new \n \n49 CIFP Framework for Service During Periods of Insufficient Resource Adequacy – PJM Proposal, PJM \nInterconnection, L.L.C., 5 (July 27, 2026), https://www.pjm.com/-/media/DotCom/about-pjm/who-we-\nare/public-disclosures/2026/20260727-cifp-framework-for-service-during-periods-of-insufficient-resource-\nadequacy-executive-summary.pdf [https://perma.cc/GX7A-W3Q6] (“CIFP Framework for Service”). \n50 See generally PJM Board July 2026 Decisional Letter. \n51 See generally RBP Proposal Filing."},{"page":25,"startToken":7779,"endToken":8186,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 19 \n \n \n \ncapacity serving new load and certain qualifying Electric Distributors \nthat elect and meet requirements to opt-out of the RBP;52   \n• An Expedited Interconnection Track temporary pathway for advanced \nprojects of significant size interconnected more quickly to address \nPJM’s urgent need for additional Capacity Resources by facilitating the \ninterconnection of those new generation resources—outside of PJM’s \nCycle Process—that commit to firm commercial-in-service dates and \nhave a commitment from the Primary Siting Authority (or a state \nexecutive officer in certain circumstances) to expedite consideration of \napplicable siting, which was accepted by the Commission on June 9, \n2026;53 \n• An extension of a price collar on RPM Auction outcomes through the \n2029/2030 Delivery Year, which was accepted by the Commission on \nApril 8, 2026;54 \n• A one-time, reliability-based expansion, known as the Reliability \nResource Initiative, of the eligibility criteria for PJM’s Transition Cycle \n#2 of PJM’s existing interconnection queue, which the Commission \naccepted55 and resulted in PJM selecting 51 projects that can come \nonline quickly and provide more than 9,300 MW of reliable capacity;56 \n• An extension of the capacity must-offer requirement to all available \nExisting Capacity Resources so as to allow RPM Auction outcomes to \nmore accurately reflect the actual quantity of Existing Generation \nCapacity Resources, while continuing to safeguard against the potential \nexercise of market power that may be exerted by the withholding of such \nresources, which was accepted by the Commission;57 and \n• A compliance filing and illustrative Tariff revisions to provide that the \nEligible Customer taking transmission service on behalf of a co-located \nload may take a transmission service that reflects the co-located load’s \n \n52 Since this spring, PJM has been concurrently facilitating a bilateral matching process to encourage \nvoluntary, bilateral agreements between supply and demand for new capacity.   \n53 See PJM Interconnection, L.L.C., 195 FERC ¶ 61,197, at PP 1, 7, 44-45 (2026). \n54 See PJM Interconnection, L.L.C., 195 FERC ¶ 61,076, at P 51 (2026).   \n55 See PJM Interconnection, L.L.C., 190 FERC ¶ 61,084, reh’g denied, 192 FERC ¶ 61,085 (2025). \n56 See PJM Interconnection, L.L.C., PJM Chooses 51 Generation Resource Projects To Address Near-Term \nElectricity Demand Growth, PJM Inside Lines (May 2, 2025), https://insidelines.pjm.com/pjm-chooses-51-\ngeneration-resource-projects-to-address-near-term-electricity-demand-growth/ \n[https://perma.cc/4BBH-\nYR3F]. \n57 PJM Interconnection, L.L.C., 190 FERC ¶ 61,117, order on reh’g, 191 FERC ¶ 61,221 (2025)."},{"page":26,"startToken":8186,"endToken":8588,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 20 \n \n \n \nability and willingness to limit its use of the transmission system, which, \nif utilized, would reduce the amount of capacity required to meet the \nregion’s resource adequacy needs.  The Commission ruled on PJM’s \nTariff revisions and directed a future compliance filing to implement \nthese new transmission services that PJM will soon submit.58 \nThe following filings aimed at addressing the impacts of new large loads on the \nPJM Region are forthcoming: \n• A fulsome FPA section 205 filing addressing the issues the Commission \nraised in its June 2026 Order to Show Cause that will set forth the non-\nrate terms and conditions for Eligible Customers to take transmission \nservice on behalf of large loads that are willing and able to limit their \nenergy withdrawals from the transmission system, which, if utilized, \nwill reduce the amount of capacity required to meet the region’s \nresource adequacy needs; and \n• Future enhancements to reserve products and updated reserve demand \ncurves to better account for ramping and uncertainty and better align \nreserve pricing with operational practice.59  \n• In addition, PJM has undertaken the following initiatives: \no Improved load forecasts that include state review of large load \nadditions, addressing duplicative requests, the use of additional \nthird-party review and increased transparency;60 and \no Facilitating bilateral contracting by providing a voluntary matching \nservice that helps connect potential buyers with sellers of capacity, \nas described at length in the RBP proposal filed July 31, 2026. \n \n58 See PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026).  On July 28, 2026, PJM submitted a motion \nto extend its compliance filing with respect to, among other things, the Tariff revisions implementing these \nnew transmission services to allow for the concurrent development of the compliance language with the \ndevelopment of a new FPA section 205 filing to propose new transmission services for Eligible Customers \ntaking transmission services on behalf of large loads that are not part of a co-location arrangement.  PJM \nInterconnection, L.L.C., Motion for Extension of Time for Specified Compliance Requirements and Request \nfor Expedited Treatment of PJM Interconnection, L.L.C., Docket Nos. EL25-49-000, et al. (July 28, 2026). \n59 See PJM Interconnection, L.L.C., Informational Report on Stakeholder Process Addressing Resource \nAdequacy for New Large Loads of PJM Interconnection, L.L.C., Docket No. EL26-67-000, at 8 (July 20, \n2026). \n60 See January 2026 Board Letter at 2."},{"page":27,"startToken":8588,"endToken":8873,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 21 \n \n \n \nII. \nTHE PROPOSED REFORMS TO THE TARIFF AND THE RAA ARE JUST \nAND REASONABLE AND NOT UNDULY DISCRIMINATORY OR \nPREFERENTIAL \nA. \nOverview of Interim Resource Adequacy Service Framework and \nResponsibilities of PJM and Electric Distributors to Implement IRAS \n1. \nThe Interim Resource Adequacy Service framework \nAs of right now, PJM will enter the 2027/2028 Delivery Year short of sufficient \ncapacity to meet the PJM Region Reliability Requirement.  As PJM has explained, this \nshortfall is due to a confluence of various factors, particularly the “unprecedented surge in \ndata center load” at a faster pace than new supply can come online,61 and the “speed of \nconnecting these large loads creates a fundamental misalignment between demand and \nsupply cycles,”62 resulting in “resource adequacy in the PJM service area [being] under \nsignificant stress.”63  Through this FPA section 205 filing, PJM seeks to build on its prior \nefforts to ameliorate the resource adequacy stress.  PJM’s proposal in this filing can be \nbroadly thought of as consisting of five parts.   \nOne, PJM proposes to clarify an LSE’s obligation to bring new capacity in an \namount that equals or exceeds its New Large Loads’ peak load or be subject to load \nreduction requests during Emergencies prior to Pre-Emergency Load Management \nResponse.  In codifying this principle, which is similar to one already inherent in SPP’s \n \n61 See 2027/2028 Base Residual Auction Reserve Target Shortfall Report, PJM Interconnection, L.L.C., 1 \n(Feb. 9, 2026), https://www.pjm.com/-/media/DotCom/markets-ops/rpm/rpm-auction-info/2027-2028/2027-\n2028-bra-reserve-target-shortfall-report.pdf [https://perma.cc/TA3Y-95AX] (“2027/2028 BRA Report”). \n62 2027/2028 BRA Report at 4. \n63 2027/2028 BRA Report at 2."},{"page":28,"startToken":8873,"endToken":9169,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 22 \n \n \n \nlarge load integration construct,64 PJM is incentivizing resource adequacy and investing in \ngeneration and related infrastructure to meet the projected demand growth. \nTwo, PJM proposes to administer and maintain a new Large Load Registry.  \nThrough this centralized registry, PJM will be able to gain a better understanding of all the \nLarge Loads currently on its system and the New Large Loads that will interconnect in the \nfuture.  The registry will enable PJM to better forecast load growth, plan and manage the \ntransmission system, and study and provide the anticipated new transmission services for \nco-located loads and Large Loads.  PJM will not be the only beneficiary of the registry, as \nthe proposed RAA language explicitly contemplates that the registry will be available to \nstates, Transmission Owners, Electric Distributors, LSEs, the Independent Market Monitor \nfor PJM, and the Commission, subject to appropriate confidentiality and data protection \nsafeguards. \nThree, PJM is proposing Interim Resource Adequacy Service, a new supplemental \ncapacity product through which New Large Loads provide a load reduction service that is \na tool available to PJM to manage resource adequacy shortfalls that would otherwise drive \nshedding of native loads.  Interim Resource Adequacy Service Action will be issued prior \nto calling on Pre-Emergency Load Management, placing IRAS appropriately at the \nbeginning of PJM’s actions in the event of NERC Energy Emergency Alert Level 1 \n(“EEA1”), and PJM will update the Emergency Procedures in its PJM Manuals to detail \nhow and when it may call on IRAS.   \n \n64 See, e.g., Sw. Power Pool, 195 FERC ¶ 61,213, concur op. (Commissioner Rosner) at P 13; Sw. Power \nPool, 195 FERC ¶ 61,196 at P 15; Sw. Power Pool, 194 FERC ¶ 61,031, concur op. (Commissioner Rosner) \nat P 1."},{"page":29,"startToken":9169,"endToken":9503,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 23 \n \n \n \nFour, PJM is proposing Bring Your Own New Capacity or “BYONC” as the \ncategory of new capacity eligible to address New Large Load capacity needs and through \nwhich a New Large Load can reduce the amount of Interim Resource Adequacy Service it \nmay be asked to provide, consistent with the Electric Distributor’s approved load reduction \nrules.  The amount of IRAS a New Large Load will be eligible to make available is \ninversely proportional to the amount of new capacity the New Large Load has brought to \nthe PJM system.  New Large Loads have a number of “self-sufficiency” avenues (in the \nlanguage of the Ratepayer Protection Pledge) to avoid facing potential load reduction under \nstate curtailment priorities implementing IRAS at the retail level.  Specifically, to the extent \na New Large Load does not want to provide IRAS, it needs to contract with new capacity \nthat meets the BYONC gating criteria, which are designed to ensure the capacity is actually \nnew and not repackaged and will provide capacity over at least 10 years.  Many New Large \nLoads have already committed through their recently executed Ratepayer Protection \nPledge to fund the electricity generation and infrastructure their projects require.  IRAS \nprovides a tool available to PJM to manage resource adequacy issues through calling for \nload reductions from those New Large Loads that do not adhere to the Ratepayer Protection \nPledge or have otherwise not brought new eligible capacity to offset their load additions. \nFive, in future RPM Auctions, PJM is proposing to exclude from the VRR Curve \nNew Large Loads, to the extent they do not have arrangements with sufficient BYONC, \nbeginning with the 2029/2030 Delivery Year.  To the extent New Large Loads do not \nprocure BYONC to meet their capacity needs, the rest of PJM’s load should not be exposed \nto the price impacts caused by those New Large Loads’ procurement of their capacity needs \nthrough the RPM Auctions.  PJM’s proposal is designed to protect residential customers"},{"page":30,"startToken":9503,"endToken":9846,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 24 \n \n \n \nfrom capacity price increases resulting from the effects of New Large Loads and is \ntherefore consistent with the Statement of Principles Regarding PJM issued on January 16, \n2026, by the NEDC and the 13 governors of the PJM states and the Ratepayer Protection \nPledge.65   \nAs discussed below, to implement these concepts, PJM proposes to establish a new \nAttachment DD-4 to its Tariff to house the rules for Interim Resource Adequacy Service;66 \nrevisions to the RAA to establish the Large Load Registry and the resource adequacy \nobligations associated with interconnecting New Large Loads; and revisions to Tariff, \nAttachment DD to adjust the VRR Curve.  While each of these provisions is detailed later \nin this transmittal letter, PJM takes this opportunity to describe the introductory section of \nproposed Tariff, Attachment DD-4.  Specifically, section I provides that the rules in \nAttachment DD-4 are supplemented by the PJM Manuals and should be read “in \nconjunction with the Reliability Assurance Agreement.”67  From there, the basic concepts \nare introduced:   \n(1) “Interim Resource Adequacy Service is a load reduction service, effective \nstarting with the 2027/2028 Delivery Year . . . for the purpose of supporting the \n \n65 PJM’s proposal in this respect is based on the forecasted resource adequacy shortfalls and uncertainty today \nas to how much capacity will be procured through either the RBP or future BRAs.  Nothing in this proposal \nis intended to bind PJM or the Commission in the future if and when the supply/demand balance becomes \nbetter aligned.  \n66 At proposed Tariff, Attachment DD-4, the IRAS rules fit well alongside the other resource \nadequacy-related rules in the Tariff:  Tariff, Attachment DD provides the Reliability Pricing Model rules, \nTariff, Attachment DD-1 provides a copy of the RAA rules on Demand Resource participation in RPM, \nTariff, Attachment DD-2 provides the rules for Peak Shaving Adjustments, and Tariff, Attachment DD-3 is \nthe list of state policies or programs accepted as Conditioned State Support and subject to the Minimum Offer \nPrice Rule. \n67 Proposed Tariff, Attachment DD-4, section I."},{"page":31,"startToken":9846,"endToken":10123,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 25 \n \n \n \nintegration of New Large Loads to the PJM Region that are not in arrangements \nwith new capacity additions to the PJM Region;”68  \n(2) PJM can call on IRAS load reductions prior to calling on Pre-Emergency Load \nManagement Reductions Actions when needed to avoid a capacity shortage on \na regional or sub-regional basis;69  \n(3) PJM will maintain the Large Load Registry “pursuant to the Reliability \nAssurance Agreement . . . [to] inform which New Large Loads are eligible to \nbe called on to provide Interim Resource Adequacy Service;”70 and  \n(4) PJM will “coordinate with Electric Distributors, and other Members as \nappropriate, on the provision of Interim Resource Adequacy Service” and any \nresulting compensation.”71 \nEach of these concepts is borne out in the proposed IRAS rules described in this transmittal \nletter.  \n2. \nResponsibilities of PJM and Electric Distributors  \nBecause successful implementation of Interim Resource Adequacy Service will \nrequire actions from PJM and Electric Distributors, PJM’s proposal delineates broadly the \nresponsibilities of PJM and Electric Distributors at the outset of proposed Tariff, \nAttachment DD-4.  Section II of proposed Tariff, Attachment DD-4 provides that PJM \nshall be responsible for:  maintaining the Large Load Registry; identifying Eligible New \nLarge Loads and the MW quantity of IRAS needed for each Electric Distributor zone/area \nfor a given Delivery Year, starting with the 2027/2028 Delivery Year; and issuing an \nInterim Resource Adequacy Service Action based on system conditions and Eligible New \n \n68 Proposed Tariff, Attachment DD-4, section I(a). \n69 Proposed Tariff, Attachment DD-4, section I(b). \n70 Proposed Tariff, Attachment DD-4, section I(c). \n71 Proposed Tariff, Attachment DD-4, section I(d)."},{"page":32,"startToken":10123,"endToken":10456,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 26 \n \n \n \nLarge Load Amounts directing Electric Distributors to reduce load in accordance with such \nInterim Resource Adequacy Service Action.72 \nWith regard to Electric Distributors, PJM proposes that they “shall” fulfill four \ntasks.  One, Electric Distributors must execute PJM’s load reduction directives when PJM \nissues an Interim Resource Adequacy Alert.73  As discussed below in Part II.D.4.c, this \ndoes not mean that PJM will identify specific New Large Loads for the Electric Distributor \nto reduce; PJM will identify only aggregate MW values that need to be reduced, but such \nvalues will be based on the maximum IRAS value PJM determined for the Electric \nDistributor’s zone/area prior to the Delivery Year.  The Electric Distributors, in \ncoordination with the appropriate states and/or RERRAs, LSEs, and LSE customers will \ndetermine which loads should ultimately reduce subject to IRAS.  PJM here is simply \nmemorializing current practice under which Electric Distributors, consistent with their \nstate programs, determine how to implement load reduction directives.  \nTwo, Electric Distributors must coordinate with PJM on the development and \nmaintenance of the Large Load Registry.  Specifically, PJM proposes that the Electric \nDistributors must provide PJM with “any information or data the Electric Distributor \nbelieves appropriate to facilitate an accurate Large Load Registry, including applicable \nstate or RERRA retail tariff or contractual obligations.”74  This coordination is just and \n \n72 Proposed Tariff, Attachment DD-4, sections II(a)-(e). \n73 Proposed Tariff, Attachment DD-4, section III(a).  In full, this provision states:  The Electric Distributor \nshall “execute the Office of the Interconnection’s directives to implement Interim Resource Adequacy \nService Actions among the Eligible New Large Loads in the Electric Distributor’s zone/area, which is an \narea within a Zone for which the relevant Electric Distributor specifies a separate Obligation Peak Load MW \nvalue and is a service area of an Electric Distributor that is a separately identifiable, geographic area bounded \nby wholesale metering.”  Id. \n74 Proposed Tariff, Attachment DD-4, section III(b)."},{"page":33,"startToken":10456,"endToken":10725,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 27 \n \n \n \nreasonable, as the Electric Distributor is privy to much of the information the proposed \nLarge Load Registry seeks to maintain.  As discussed below in Part II.B, the initial \nobligation to submit data to PJM is on the LSE serving the Large Load, but in order to \nincrease the accuracy of the registry, PJM finds valuable—and needed—the information \navailable to the Electric Distributors. \nThree, Electric Distributors must “coordinate, as appropriate, with the relevant \nstate(s) or RERRA(s), individual Load Serving Entities, and customers served by the Load \nServing Entities in its zone/area to support transparent, effective, and orderly deployment \nof Interim Resource Adequacy Service.”75  Through this coordination requirement, PJM is \nnot dictating how or on which terms the Electric Distributor must effectuate such \ncoordination.  Rather, as with the first responsibility discussed above, PJM is \nmemorializing existing practices.  And, here, PJM is merely articulating the expectation \nthat the Electric Distributor will be the entity to identify, consistent with applicable state \nprograms, the load to be reduced in response to an Interim Resource Adequacy Service \nAction. \nFinally, the Electric Distributor shall “implement compensation program consistent \nwith Tariff, Attachment DD-4, section X.”76  As discussed below in Part II.E, PJM is not \nmandating how IRAS-directed load reductions are to be compensated.  PJM is proposing \na just and reasonable maximum rate for such service.  However, given that the Electric \nDistributors, in accordance with state programs, will have identified the loads to be \n \n75 Proposed Tariff, Attachment DD-4, section III(c). \n76 Proposed Tariff, Attachment DD-4, section III(d)."},{"page":34,"startToken":10725,"endToken":11029,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 28 \n \n \n \nreduced, it is the responsibility of the Electric Distributor and its applicable state regulator \nto determine the appropriate compensation scheme.  PJM’s proposal offers the Electric \nDistributor and their state regulator much flexibility in this regard.  \nB. \nThe Large Load Registry (RAA, Schedule 11, Section B) \nPJM is proposing to establish a registry of Large Loads in the PJM Region to be \nmaintained by PJM and updated periodically, and which may be “available to Authorized \nCommissions, Transmission Owners, Electric Distributors, [LSEs], the Market Monitoring \nUnit, and [the Commission]” and other entities pursuant to the Operating Agreement, \nsection 18.17, “subject to appropriate data protection safeguards required by Operating \nAgreement, section 18.17.”77  To the extent consistent with existing confidentiality \nprotections in PJM’s Governing Agreements, PJM is also proposing that aggregated data \nfrom the Large Load Registry be posted on the PJM website.78   \nThe Large Load Registry will contain information about Large Loads in the PJM \nRegion that will, inter alia, facilitate the transparent implementation of IRAS and assist \nthe Commission and states in monitoring whether loads are, in fact adhering to the \nRatepayer Protection Pledge commitment to “build, bring, or buy the new generation \nresources and electricity needed to satisfy their new energy demands” and “add[ing] more \ncapacity that serves the broader public by increasing supply” in order to protect “Americans \nfrom higher prices.”79  PJM will use the registry to determine the quantity of New Large \n \n77 Proposed RAA, Schedule 11, section B.1(d). \n78 Proposed RAA, Schedule 11, section B.1(e).   \n79 Ratepayer Protection Pledge; Ratepayer Protection Pledge Announcement; see also Fact Sheet: President \nDonald J. Trump Advances Energy Affordability with the Ratepayer Protection Pledge, The White House \n(Mar. 4, 2026), https://www.whitehouse.gov/fact-sheets/2026/03/fact-sheet-president-donald-j-trump-"},{"page":35,"startToken":11029,"endToken":11329,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 29 \n \n \n \nLoads by zone/area and allocate IRAS responsibility to each zone/area accordingly, \nstarting with the 2027/2028 Delivery Year.  States may leverage the Large Load Registry \nto inform the implementation of retail constructs including load reduction priorities and \ncost allocation at the retail level to appropriate end-use customers.  The Large Load \nRegistry will assist states in administering their respective programs at the retail level while \nallowing each state to retain the flexibility to administer those programs, including the \nflexibility to determine when and whether Large Loads and Existing Large Loads have \ndemonstrated that their loads are matched with new capacity that they have procured to \nserve their needs.  PJM also anticipates that the proposed Large Load Registry may also \nsupport recent efforts by NERC to “aggressively work[] toward revised registry criteria \nand standards”80 in accordance with the Commission’s recent order, pursuant to section \n215(d)(5) of the FPA,81 directing NERC to “develop changes to NERC’s Rules of \nProcedure, including registry criteria, necessary for the registration of computational load \nentities.”82   \n \nadvances-energy-affordability-with-the-ratepayer-protection-pledge/ [https://perma.cc/N366-NGF4] (listing \nthe companies who joined the Ratepayer Protection Pledge). \n80 Large Loads Action Plan: Understanding and addressing the reliability risks of emerging large loads, \nNorth American Electric Reliability Corporation, https://www.nerc.com/initiatives/large-loads-action-plan \n[https://perma.cc/87WF-F4LV] (last visited Aug. 13, 2026); \n81 16 U.S.C. § 824o(d)(5). \n82Reliability Standard(s) Pertaining to Computational Load Integration, 196 FERC ¶ 61,031, at P 10 (2026).  \nNERC has announced that it will be issuing its second draft of the registry criteria for public review on \nAugust 19, 2026.  NERC, (@NERC_Official), X (Aug. 5, 2026, at 4:34 PM), https://x.com/NERC_Official \n/status/2085102044054953996 [https://perma.cc/4EWU-2E83]."},{"page":36,"startToken":11329,"endToken":11737,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 30 \n \n \n \n1. \nOverwhelming support from PJM stakeholders for a New Large \nLoad Registry to be established and maintained by PJM \n \nPJM’s proposal to establish a Large Load Registry received overwhelming support \nfrom PJM stakeholders.  Indeed, in response to a poll of stakeholders posted on July 16, \n2026, 82% of the 66 stakeholder respondents agreed that a Large Load registration \nrequirement is necessary to “ensur[e] that costs of new capacity required to serve new large \nload should be allocated to data centers.”83  Furthermore, seven of the 10 proposals put \nforward by PJM’s stakeholders similarly include a Large Load Registry.84  In addition, in \nresponse to the July 16, 2026 poll of stakeholders, at least seven stakeholder respondents \nnoted that the Large Load Registry is likely to provide the necessary transparency to \nidentify Large Loads while supporting the overall success of the IRAS framework.85  One \nstakeholder respondent noted that “[a] registry provides the transparency needed to identify \nnew large loads, their locations, and whether they have secured qualifying BYONC or other \n \n83 CIFP - RBP/Connect & Manage Poll Results at 4. \n84 See Connection and Manage Senior Task Force, Implementation of Connect and Manage Framework for \nLarge Load Interconnections Package/Proposal Matrix, PJM Interconnection, L.L.C., Sheet 6 (3. Package \nMatrix) \n(June \n30, \n2026), \nhttps://www.pjm.com/-/media/DotCom/committees-groups/cifp-\nrbp/2026/20260630/20260630-cifp---connect-and-manage---options-and-packages-matrix.xls \n[https://perma.cc/59X5-P7WG] (The following stakeholder proposals also included the concept of a Large \nLoad Registry: (1) Joint Electric Distribution Companies (Joint EDCs); (2) Glatz-Silverman; (3) Calibrant; \n(4) Joint Consumer Advocates; (5) Natural Resources Defense Council (NRDC); (6) E-Cubed Policy \nAssociates; and (7) Voltus.).  \n85 CIFP - RBP/Connect & Manage Poll Results at 33 (Stakeholder respondents noted that “[a] registry is \nnecessary for both the Reliability Backstop Procurement and for the Connect & Manage framework to ensure \ncosts and curtailments are assigned appropriately.  Consistent with the Statement of Principles, a registry will \nensure that new Large Load customers (cost causers), through the LSEs that serve them, are appropriately \nassigned the cost of capacity procured through the Reliability Backstop Procurement (RBP) mechanism.  \nAbsent a registry, it is unclear how other end-use consumers could be insulated from these costs. . . . \nAdditionally, it is unclear how, absent a registry, a Connect & Manage framework could be implemented in \na way that protects other end-use consumers from being curtailed in response to a PJM Connect & Manage \nevent.”)."},{"page":37,"startToken":11737,"endToken":12076,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 31 \n \n \n \nreliability arrangements.”86  Another noted that “[a] registry is one means of satisfy[ing] \nthe principle of ensuring that costs of new capacity required to serve new large load (i.e., \ndata centers) should be allocated to data centers.”87  Overall, there was broad support across \nthe stakeholder sectors for a registry registration requirement.88 \n2. \nThe proposed definition of Large Load is just and reasonable  \nPJM’s proposed Large Load Registry, which will provide the critical data \ntransparency needed to establish load reduction priorities for retail customers through \nIRAS, begins with a definition of Large Load.  PJM proposes to define Large Load as \n“end-use customer(s) load that has a cumulative peak load of 50 megawatts or greater at a \nsingle electrical site behind one or more points of interconnection, where for configurations \ninvolving multiple affiliated load facilities or multiple points of interconnection with \naffiliated load facilities behind them, all affiliated load facilities within a one-mile radius \nwill be considered a single electrical site as further described in the PJM Manuals.”89   \nPJM’s proposed definition of Large Load is in line with the Commission’s June \n2026 Order to Show Cause regarding Large Loads, wherein the Commission expressly \nfound that “PJM’s Tariff appears to be unjust and unreasonable because it lacks a definition \nof large load, as a new category of load.”90  More specifically, the Commission held that \n \n86 CIFP - RBP/Connect & Manage Poll Results at 32. \n87 CIFP - RBP/Connect & Manage Poll Results at 32. \n88 CIFP - RBP/Connect & Manage Poll Results at 5-6 (Of the 82% of stakeholder respondents that agreed \nthat a large load registration requirement is necessary to ensure that costs of new capacity required to serve \nnew load should be allocated to data centers, 18 were Electric Distributors, 16 were End-Use Customers, \n6 were Generation Owners, 7 were Other Suppliers, and 7 were Transmission Owners). \n89 Proposed RAA, Definitions – Large Load. \n90 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58."},{"page":38,"startToken":12076,"endToken":12379,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 32 \n \n \n \n“an appropriate definition, including a load size and interconnection voltage threshold, \nshould be based on the characteristics of PJM’s transmission system.”91  The Commission \nthus requested that PJM “explain whether the Tariff remains just and reasonable without \nsuch a definition, or propose Tariff revisions establishing its own definition of large \nload.”92 \nThe Commission, in its June 2026 Order to Show Cause, preliminarily found that, \nbased on the record in the DOE ANOPR proceeding, “it appears that it would be reasonable \nto define a large load as a new, commercial or industrial customer, located at a single site \nbehind one or more points of interconnection, and that has a peak load of 50 MW or greater, \ninterconnects to the transmission system at a voltage level of greater than 69 [kilovolts \n(“kV”)], and is not part of a co-location arrangement.”93  However, while the Commission \nstated that its proposed definition “appears . . . [to] be reasonable,” the Commission \nfurthermore acknowledged that PJM may establish “its own definition of large load.”94   \nPJM proposes to define Large Load in terms that are substantially similar to the \nCommission’s preliminary proposal.  Specifically, like the Commission’s preliminary \ndefinition, PJM is proposing that Large Load, as defined in the Tariff:  (1) has a peak load \nof 50 MW or greater; (2) be located at a single site; and (3) be behind one or more points \nof interconnection.  Nevertheless, PJM’s proposed definition of Large Load differs from \n \n91 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58. \n92 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58. \n93 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58. \n94 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58."},{"page":39,"startToken":12379,"endToken":12694,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 33 \n \n \n \nthe Commission’s in several ways to reflect the characteristics and realities of Large Loads \nin the PJM Region.    \nFirst, the 50 MW or greater threshold, as proposed by PJM, is a cumulative peak \nload of 50 MW.  During the stakeholder process, PJM was informed that a single entity \nthat is an end-use customer in PJM may actually consist of a number of smaller loads with \na cumulative have a peak load of 50 MW or greater.  Thus, to capture the smaller loads of \na single entity—e.g., disparate, closely located data centers owned by a single company—\nand to avoid any gamesmanship from splitting up a Large Load into smaller loads, but all \nwithin the same area, PJM is proposing that the cumulative peak load be equal to or greater \nthan a 50 MW threshold. \nSecond, Large Load is located at a single electrical site behind one or more points \nof interconnection within a one-mile radius.  The one-mile radius requirement is intended \nto avoid a scenario where, for example, a data center owner is not categorized as Large \nLoad simply because the owner has elected to site a number of smaller data centers, each \nwith peak loads below 50 MW, close together.95  The Commission has explicitly adopted \na one-mile test in other situations to determine whether facilities are “at the same site” to \nbe a Qualifying Facility  There, the Commission has set and applied an irrebuttable \npresumption that they are a single facility at a single site when the distance between \n \n95 Qualifying Facility Rates and Requirements Implementation Issues Under the Public Utility Regulatory \nPolicies Act of 1978, Order No. 872, 172 FERC ¶ 61,041 (revising one-mile rule for small power production \nfacilities seeking Qualifying Facility status as an analog), order on reh’g & clarifying in part, Order No. \n872-A, 173 FERC ¶ 61,158 (2020)."},{"page":40,"startToken":12694,"endToken":12991,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 34 \n \n \n \nequipment at two facilities is one mile or less.96  Adoption of a similar criterion for \ndetermining Large Loads is also just and reasonable.  \nSimilarly, the reference to a single “electrical” site is similarly intended to avoid a \nscenario where data centers and other Large Loads avoid the 50 MW threshold by \nconfiguring themselves into smaller loads.  Data centers and other Large Loads that are \nphysically located together or act as a single facility are a single “electrical” site.  In the \nsame vein, companies may site many affiliated facilities in the same general areas but could \nsite them in a manner that could allow the facilities to individually avoid falling within a \ndefinition of Large Load.  Therefore, PJM is proposing to extrapolate in the definition that \nthere are many different configurations that may constitute a single electrical site, \nparticularly where there are multiple facilities that are affiliated in the same general area.  \nThese criteria are logical and helpful for purposes of defining Large Load and minimizing \nrisks of gamesmanship.  \nGiven the multitude of possible configurations and the other possible variations, \nPJM intends to detail in the PJM Manuals the method of calculating the one-mile distance \nand for examining different configurations to determine whether they may constitute a \nsingle electrical site.  Such implementation details are needed, and explicitly called for in \nthe proposed definition of Large Load.   \nThird, Large Load, as proposed by PJM, is defined as “end-use customer(s) load” \nrather than the Commission’s proposed “new, commercial or industrial customer.”  PJM \nproposes to define Large Load to refer specifically to the MW quantity of the demand \n \n96 Order No. 872, 172 FERC ¶ 61,041 at PP 17, 62, 466; see 18 C.F.R. § 292.204(a)(2)."},{"page":41,"startToken":12991,"endToken":13333,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 35 \n \n \n \ncreated by the customer rather than the customer itself.  In other words, as reflected below, \nduring emergency conditions IRAS will not be used in real-time operations to require the \nreduction of specific end-use customers but, rather, will be focused on directing that a \ncertain MW quantity be reduced by the Electric Distributor in order to maintain system \nreliability in the face of resource adequacy challenges.  PJM is also proposing that Large \nLoad encompass all end-use customer(s) load that meet the other requirements, thus \navoiding singling out commercial or industrial customers specifically.  That said, PJM does \nnot contemplate that residential customers or smaller industrial customers would have peak \nloads anywhere near 50 MW, which represents, roughly, the electricity consumption of \nbetween 25,000 and 50,000 homes.97   \nFourth, PJM’s proposed definition of Large Load also excludes several provisions \nreflected in the Commission’s definition.  Namely, PJM is not proposing that Large Load \nbe limited to connecting to the system at a voltage of 69 kV or greater, is not excluding \nco-location arrangements from the definition, and is not limiting the definition to new load.  \nPJM understands that other regions have identified a need for specifying a voltage criterion \nin a Large Load definition because “different-size loads may have different impacts on the \ntransmission system depending on the voltage level at which they interconnect,” the \nprevalence of 69 kV transmission lines on their system, and the existence of transmission \nthat is less than 69 kV.98  While PJM’s transmission system has some transmission that is \n \n97 PJM is not using the Tariff defined term, “End-Use Customer,” as not all relevant customers may \nnecessarily fit under that term.  End-Use Customer, as defined in the RAA, “shall mean a Member that is a \nretail end-user of electricity within the PJM Region.”  RAA, Article 1, Definitions (defining End-Use \nCustomer).  For purposes of this proposal, not all relevant customers of LSEs may be Members of PJM. \n98 See Sw. Power Pool, 194 FERC ¶ 61,031 at P 61."},{"page":42,"startToken":13333,"endToken":13680,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 36 \n \n \n \nless than 69 kV in certain zones, to date, PJM’s processes and stakeholder engagement \nhave not identified any need to draw a distinction between Large Loads connecting at \ndifferent voltage levels given the specific purpose of IRAS as outlined herein.  As such, \nPJM’s proposed definition does not include the Large Load connecting to the system “at a \nvoltage level of greater than 69 kV” criterion.  PJM is also not proposing that the definition \nof Large Load exclude load that is “part of a co-location arrangement.”  Rather, PJM’s \nproposed definition of Large Load is focused on the MW quantity threshold of load located \nclose in distance at a single electrical site.  Rather than entirely excluding such load from \nthe definition of Large Load by virtue of its co-location with generation, PJM has proposed \nrules that specifically address situations in which Large Load is co-located with their own \ngeneration.  Also, Large Load, as defined, is not limited to “new” load.  Instead, PJM is \nproposing a separate definition, “New Large Load,” to capture the temporal aspect of such \nload with greater specificity.  In addition, PJM is proposing to define those New Large \nLoads that are eligible to provide IRAS as Eligible New Large Load.  The definitions of \nNew Large Load and Eligible New Large Load are described below in Parts II.B.3.a and \nII.C.6, respectively.99 \n3. \nInformation reported in the Large Load Registry \nPJM is proposing that LSEs submit information to PJM about the Large Loads they \nserve,100 and also that PJM may obtain information, as needed, from the Electric \n \n99 While PJM is proposing a just and reasonable definition of Large Load, as part of the ongoing NERC and \nlarge load show cause response efforts, PJM will continue to engage with the industry and stakeholders to \nconsider operational impacts and requirements necessary to address situations where multiple unaffiliated \nloads aggregate up to or in excess of 50 MW in relatively close proximity to each other. \n100 Proposed RAA, Schedule 11, section B.1(a)."},{"page":43,"startToken":13680,"endToken":13980,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 37 \n \n \n \nDistributors whose zone(s)/area(s) the LSEs are located and the Transmission Owner.101  \nFurthermore, PJM may also consult with the Large Load.102   \nThe Large Load Registry will contain the following information about each Large \nLoad in the PJM Region: \n• Eligible Customer/Network Customer for Large Load; \n• Description of Large Load; \n• Location(s) (Control Zone, Electric Distributor zone/area, where a \nzone/area is an area within a Zone for which the relevant Electric \nDistributor specifies a separate Obligation Peak Load MW value.  A \nzone/area is a service area of an Electric Distributor that is a separately \nidentifiable, geographic area bounded by wholesale metering); \n• In-service date for each increment of load; \n• Peak shaving adjustment value pursuant to a state program codified in \nstate law and whether and how it meets the requirements of Tariff, \nAttachment DD-2; \n• Delivery point / Point(s) of interconnection (include all if more than \none); \n• Peak load quantity (MW) and ramp schedule, if applicable; \n• Telemetry specifications; \n• BYONC quantity (MW) and ramp schedule, if applicable; \n• Allocated RBP UCAP MW quantity (MW), if applicable; \n• Backup generation (MW), including fuel type and relevant permitting \nlimitations; \n• Contracts or service agreements between the Large Load and the LSE; \n• Points of contact at the applicable Transmission Owner, Electric \nDistributor, and Load Serving Entity; \n• EMS B1/B2/B3 name (for the applicable Transmission Owner, Electric \nDistributor); and  \n• Additional details and contents as necessary, in accordance with the \nPJM Manuals.103 \n \nEach piece of information is a necessary component to the Large Load Registry and \nprovides key information to PJM, as well as Authorized Commissions, Transmission \n \n101 Proposed RAA, Schedule 11, section B.1(b). \n102 Proposed RAA, Schedule 11, section B.1(c). \n103 Proposed RAA, Schedule 11, section B.1(a)."},{"page":44,"startToken":13980,"endToken":14276,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 38 \n \n \n \nOwners, Electric Distributors, LSEs, the Market Monitoring Unit, and the Commission, \nsubject to data protection safeguards pursuant to the Operating Agreement, section 18.17, \nas discussed below in Part II.B.3.d.  The information in the Large Load Registry will be \nused, as needed, for purposes that include implementation of IRAS, effective starting with \nthe 2027/2028 Delivery Year.104  Below, PJM describes how the information required to \nbe reported in the Large Load Registry will support IRAS and allow PJM to determine the \nMW value of load that is required to be made available for IRAS in each Electric \nDistributor zone/area. \na. \nInformation in the Large Load Registry will help PJM \ndistinguish Large Loads from New Large Loads and identify \nNew Large Loads eligible for IRAS. \nThe information submitted to or obtained by PJM for inclusion in the registry will \nallow PJM to distinguish Large Loads from New Large Loads.  As noted above, PJM’s \nproposed definition of Large Loads, unlike the Commission’s, does not require that the \nLarge Load is new.  Rather, PJM is proposing a separate definition of New Large Load, \nwhich will mean “an end-use customer load that is either (a) a Large Load that goes into \nservice after June 1, 2027, or (b) incremental load in-service after June 1, 2027, that \nincreases the existing end-use customer load at a single electrical site that, prior to such \nincremental load, did not previously meet the definition of Large Load.”105   \nThe in-service date for the Large Load, including each increment of Large Load \ncoming online, is a critical piece of information, because only New Large Load may be \n \n104 Proposed RAA, Schedule 11, section B.3. \n105 Proposed Tariff, Definitions – New Large Load."},{"page":45,"startToken":14276,"endToken":14641,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 39 \n \n \n \ndesignated “Eligible New Large Load”—i.e., New Large Load that is eligible to provide \nIRAS.  The reason for this is straightforward.  Namely, IRAS applies in Delivery Years \nwhen the amount of Capacity Resources committed falls short of the PJM Region \nReliability Requirement.106  As described below in Part II.C.7, such a shortfall arises when \nnew load comes onto the PJM system without bringing their own capacity.  IRAS, as \nproposed, is a service that specifically allows for Large Loads to interconnect without \nbringing their own capacity, on the condition that “they must reduce their load or switch to \non-site backup resources under specific, limited” emergency conditions.107  Furthermore, \nin recent years, the majority of the new load that has come onto the PJM system has been \nLarge Load.108  PJM is therefore limiting the MW quantity of Large Load that may be \nsubject to reduction pursuant to IRAS to the MW value of New Large Load that has not \nbrought their own capacity.  \nAt the beginning of IRAS, New Large Load will be Large Load that is in-service \nafter June 1, 2027.109  In subsequent years, the relevant in-service date for a Large Load to \nqualify as New Large Load will fluctuate based on whether or not IRAS is needed in the \nmanner set forth below.  Thus, the in-service date will continue to be relevant to IRAS in \nfuture years.  More specifically, pursuant to PJM’s proposed definition of New Large Load, \n \n106 Proposed Tariff, Attachment DD-4, sections IV(b)(i)-(ii). \n107 CIFP Framework for Service at 1. \n108 August 2025 Board Letter at 1 (“Recent increases in large load additions, mainly from data centers, present \nboth opportunities and challenges for the regional grid. PJM's location, size, market opportunities and system \nreliability make it an attractive area for large load customers to locate, and we continue to see significant load \ninterconnection activity at several of our utilities.  Indeed, PJM’s 2025 long-term load forecast shows a peak \nload growth of 32 GW from 2024 to 2030.  Of this, approximately 30 GW is projected to be from data \ncenters.”). \n109 Proposed Tariff, Definitions – New Large Load."},{"page":46,"startToken":14641,"endToken":14949,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 40 \n \n \n \n“to the extent three consecutive Delivery Years meet the requirements of Tariff, \nAttachment DD-4, section IV(b)(iii), then New Large Load shall mean end-use customer \nload that is either (a) a Large Load that goes into service after June 1 of the first Delivery \nYear for which the requirements of Tariff, Attachment DD-4, section IV(b)(iii) are not met \nor (b) incremental load in-service after June 1 of the first Delivery Year for which the \nrequirements of Tariff, Attachment DD-4, section IV(b)(iii) are not met that increases the \nexisting end-use customer load at a single electrical site that, prior to such incremental load, \ndid not previously meet the definition of Large Load.”110   \nb. \nInformation in the Large Load Registry will assist in \nidentifying Eligible New Large Loads that may be called on \nto reduce their load or switch to on-site back-up resources \npursuant to IRAS. \nIn a Delivery Year where IRAS applies, the MW subject to IRAS that PJM will \nallocate to an Electric Distributor zone/area will be limited to the MW quantity of New \nLarge Loads in that zone/area without arrangements for BYONC or RBP UCAP MW \nallocated to them.  PJM is therefore proposing that the Large Load Registry include \ninformation needed to distinguish between New Large Load with and without \narrangements for capacity including, for example, the BYONC quantity and schedule for \nincremental build out of the New Large Load’s energy demands (i.e., ramp schedule), and \nthe quantity of Allocated RBP UCAP MW associated with each Large Load.  Information \nin the registry will assist PJM in determining the quantity of New Large Loads by zone/area \nthat did not BYONC (or have RBP UCAP MW) and allocate an appropriate MW value of \n \n110 Proposed Tariff, Definitions – New Large Load."},{"page":47,"startToken":14949,"endToken":15282,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 41 \n \n \n \nIRAS responsibility to each zone/area starting with the 2027/2028 Delivery Year.  Using \nthe registry information, and subject to real-time needs of the system, New Large Loads \nthat have not arranged for BYONC or been assigned Allocated RBP UCAP MW may, in \naccordance with arrangements involving the Electric Distributor and relevant state \nauthorities, be subject to load reduction prior to the MW quantity associated with other, \nin-service New Large Loads that have arrangements with BYONC and/or Allocated RBP \nUCAP MW in the registry.  \nc. \nInformation in the Large Load Registry will assist PJM \noperators in determining how best to support reliability \nduring periods of insufficient capacity. \nMuch of the information that PJM is proposing to require in the Large Load \nRegistry is needed by the Electric Distributor and state authorities to make decisions that \nwill, in turn, also inform determinations by PJM operators about how best to manage the \nsystem and avoid a Manual Load Dump Action.111  For example, the peak load MW value \nassociated with a Large Load in a particular Electric Distributor zone/area will help inform \nPJM operators of the potential capacity needs in that particular zone/area.  The peak \nshaving adjustment value pursuant to a state program codified in state law and meeting the \nrequirements of Tariff, Attachment DD-2 will inform PJM operators of Large Loads that \nare managing their resource needs through peak shaving adjustments under a state program.  \n \n111 Systems Operations Division, PJM Manual 13: Emergency Operations, PJM Interconnection, L.L.C., \nsection 2.3.2 (rev. 98, June 24, 2026), https://www.pjm.com/-/media/DotCom/documents/manuals/m13.pdf \n[https://perma.cc/HE9Y-BNQK] (“PJM Manual 13”) (defining a Manual Load Dump Action as “an \nOperating Instruction from PJM to shed firm load when the PJM RTO cannot provide adequate capacity to \nmeet the PJM RTO’s load and tie schedules, or critically overloaded transmission lines or equipment cannot \nbe relieved in any other way”)."},{"page":48,"startToken":15282,"endToken":15547,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 42 \n \n \n \nThe locations, including the service zone/area of an Electric Distributor, of each Large \nLoad will assist PJM operators in managing capacity needs across the PJM Region.    \nFurthermore, as noted above, PJM is not excluding co-located load or load with \nbackup generation from the definitions of Large Load and New Large Load.  To the extent \nthat Large Load is co-located or has backup generation, PJM is proposing that this be \nidentified in the Large Load Registry.   \nd. \nConfidentiality \npursuant \nto \nOperating \nAgreement, \nsection 18.17 \nPJM is proposing to maintain the confidentiality of the information in the Large \nLoad Registry “[t]o the extent such documents, data, or other information provided to the \nOffice of the Interconnection has been designated as confidential by a Party, Electric \nDistributor, or other entity supplying the information,” pursuant PJM’s existing \nconfidentiality obligations under Operating Agreement, section 18.17.112  Furthermore, \nsubject to the appropriate data protection safeguards required by Operating Agreement, \nsection 18.17, information maintained in the Large Load Registry may be available to \nAuthorized Commissions, Transmission Owners, Electric Distributors, LSEs, the Market \nMonitoring Unit, the Commission.113   \nIn addition, to aid transparency to the public, PJM will post aggregated data from \nthe Large Load Registry, which will be aggregated by Electric Distributor zone/area, where \npossible and in a manner consistent with existing confidentiality protections.  Aggregating \nthe data by zone/area supports transparency by putting stakeholders on notice of the \n \n112 Proposed RAA, Schedule 11, section B.1(d). \n113 Proposed RAA, Schedule 11, section B.1(d)."},{"page":49,"startToken":15547,"endToken":15814,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 43 \n \n \n \nzones/areas that have been assigned IRAS in a given Delivery Year, that may be potentially \nrequired to reduce load under certain emergency conditions pursuant to IRAS, while \nmaintaining the confidentiality of the data. \nFurthermore, PJM intends to develop provisions in its Manuals to implement the \nLarge Load Registry, as needed, including details about who may access the information \nand specific safeguards in place to maintain the confidentiality of certain data.  PJM \nintends, for example, to propose revisions to its Manuals that would permit Electric \nDistributors to access their specific information in the registry.  PJM anticipates that each \nLarge Load will have a specific randomized identifier in the registry, and that Electric \nDistributors will inform customers who have been included in the Large Load Registry and \neach customer’s Large Load identifier.  To link Large Load to a BYONC resource, a \nCapacity Market Seller may input the relevant BYONC resource into their account and \nassociate it with the Large Load identifier.  By relying on randomized identifiers, PJM \neffectively allows for some transparency while also maintaining confidentiality of Large \nLoads with BYONC.   \ne. \nReliance on Large Load Registry must reflect accurate and \ncomplete information on which PJM may determine a \nbaseline.  \nPJM will review the information provided and coordinate with the applicable \nTransmission Owner and Electric Distributor to check the validity of the information \nprovided, request additional information if needed, and consult with the Large Load.114  \nThe information provided in the Large Load Registry will form the foundation for an \n \n114 Proposed RAA, Schedule 11, section B.1(c)."},{"page":50,"startToken":15814,"endToken":16172,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 44 \n \n \n \naccurate, complete, and reliable database that will inform, inter alia, decisions about the \nMW quantity of New Large Loads that is available to provide IRAS in a Delivery Year.   \nPJM is aware that false or misleading statements about, for example, Peak Load \nContributions could give rise to inaccurate baselines on which PJM would rely in the \ncourse of determining Eligible New Large Load Amounts, i.e., the MW value of load that \nan Eligible New Large Load in a given zone/area may be required to be made available for \nIRAS.115   \nThe longstanding provisions against intentionally false statements or omissions of \nmaterial fact extend to the reporting of information to the Large Load Registry.  \nSpecifically, pursuant to FPA section 222116 and 18 C.F.R. § 1c.2, “it shall be unlawful for \nany entity, directly or indirectly, in connection with the purchase or sale of electric energy \nor the purchase or sale of transmission services subject to the jurisdiction of the \nCommission, . . .  [t]o make any untrue statement of a material fact or to omit to state a \nmaterial fact necessary in order to make the statements made, in the light of the \ncircumstances under which they were made, not misleading.”117  Furthermore, to the extent \nthat Electric Distributors, LSEs, and Large Loads are “Sellers,”118 they are required, \npursuant to the Commission’s Rules and Regulations, to “provide accurate and factual \n \n115 Indeed, falsifying or artificially lowering Peak Load Contributions for purposes of increasing profits for \nthe provision of demand response has given rise to significant scrutiny by the Commission’s enforcement \noffice.  See Lincoln Paper & Tissue, LLC, 140 FERC ¶ 61,031 (2012); Competitive Energy Servs. LLC, 144 \nFERC ¶ 61,163 (2013). \n116 16 U.S.C. § 824v. \n117 18 C.F.R. §§ 1c.1(a), 1c.2(a); 16 U.S.C. § 824v. \n118 A “Seller” is “any person that has authorization to or seeks authorization to engage in sales for resale of \nelectric energy, capacity or ancillary services at market-based rates under section 205 of the Federal Power \nAct.”  18 C.F.R. § 35.36(a)(1)."},{"page":51,"startToken":16172,"endToken":16456,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 45 \n \n \n \ninformation and not submit false or misleading information, or omit material information, \nin any communication with the Commission,” as well as with PJM, “unless Seller exercises \ndue diligence to prevent such occurrences.”119   \nFalse or misleading statements or material omissions may give rise to a referral to \nthe Commission’s Office of Enforcement and Regulatory Accounting.  Violators, including \nindividuals, of the duty of candor and the prohibition against false or misleading statements \nmay be subject to significant penalties, including civil penalties of over $1.5 million per \nviolation per day.120  The authority of PJM to validate the information submitted into the \ndatabase and consult with the Large Load supports PJM’s efforts to make the Large Load \nRegistry an accurate and reliable dataset.  Furthermore, the underlying prohibition against \nfalse or misleading statements or material omissions provides PJM with reasonable \nconfidence that the information provided will be a reliable basis for establishing a baseline \nfor purposes of IRAS. \n4. \nPJM’s exercise of authority to require information from LSEs and \nElectric Distributors, and to obtain information from Large Loads \nand other entities  \nPJM is proposing to require that the information used to develop and maintain a \nLarge Load Registry be “submit[ted] or cause to be submitted” to PJM by LSEs, pursuant \nto proposed RAA, Schedule 11, section B.1(a).121  In addition, PJM proposes to obtain \ninformation from Electric Distributors,122 to coordinate with applicable Transmission \n \n119 18 C.F.R. § 35.41(b). \n120 Civil Monetary Penalty Inflation Adjustments, Order No. 906, 190 FERC ¶ 61,006 (2025). \n121 Proposed RAA, Schedule 11, section B.1(a). \n122 Proposed RAA, Schedule 11, section B.1(b)."},{"page":52,"startToken":16456,"endToken":16820,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 46 \n \n \n \nOwners and Electric Distributors, as needed, to validate the information provided in the \nLarge Load Registry, and/or to consult with relevant Large Loads.123   \nThe data PJM is requesting for the Large Load Registry in this proposal builds upon \nPJM’s existing authority and Commission precedent.  Authority exists today in the \nOperating Agreement to require Electric Distributors to provide to PJM “all System, \naccounting, customer tracking, load forecasting (including all load to be served from its \nSystem) and other data necessary or appropriate to implement or administer [the Operating \nAgreement], and the Reliability Assurance Agreement[.]”124  The Commission has also \npreviously accepted proposals by PJM to require and obtain information from jurisdictional \nentities such as Electric Distributors and LSEs.  For example, in 2024, the Commission \naccepted PJM’s proposed revisions to the RAA to incorporate, into its forecast, Load \nAdjustments, which would be reported by Electric Distributors and/or their LSEs.125   \nFurthermore, PJM’s information-gathering authority is wide, and the Commission \nhas permitted PJM to seek information from non-jurisdictional entities such as retail \ncustomers to the extent that the information is relevant to Commission-jurisdictional \nservices and rates.126  Indeed, an analogous practice can be found in longstanding \n \n123 Proposed RAA, Schedule 11, section B.1(c). \n124 Operating Agreement, section 11.3.3(h). \n125 PJM Interconnection, L.L.C., 188 FERC ¶ 61,200, at P 40 & n.65 (2024) (finding that an “Electric \nDistributor is the party with the distribution and metering facilities defining a zone/area and responsible for \nreporting load information to PJM[,]” and also noting that, “‘under the current framework, each LSE already \nreports their peak load contribution to the Electric Distributor, which is the entity ultimately responsible for \nreporting that information to PJM.’” (quoting PJM Interconnection, L.L.C., Response to Deficiency Letter, \nRequest for Commission Action by September 23, 2024, Request for Waiver of the 60-Day Notice \nRequirement, and Request for a Shortened Seven Business Day Comment Period, Docket No. \nER24-2447-001, at 9-10 (Aug. 9, 2024))).   \n126 FERC v. Elec. Power Supply Ass’n, 577 U.S. 260, 278-79 (2016) (“EPSA”); FPA section 201(b), 16 U.S.C. \n§ 824(b)."},{"page":53,"startToken":16820,"endToken":17123,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 47 \n \n \n \nrequirements applicable to Demand Resources, as set forth in Order No. 719-A.127  In that \norder, the Commission prohibited PJM and other RTOs/Independent System Operators \n(“ISO”) from accepting bids from Curtailment Service Providers that aggregated demand \nresponse of customers of utilities distributing below a MW per hour threshold unless \notherwise permitted by an appropriate retail authority.128  To comply with Order No. \n719-A, the Commission required that PJM and other RTOs/ISOs review evidence and \ninformation concerning end-use customer participation in load response programs.  In \nPJM’s case, PJM explained that, “when an LSE or Electric Distribution Company does not \npresent evidence that the Retail Authority permits or conditionally permits demand \nresponse activity, the registration will not be processed until evidence of Retail Authority \nauthorization for the resource’s participation in PJM’s load response programs is provided \nto PJM within the established deadlines.”129  \nFurthermore, PJM’s authority to obtain “data and details concerning large load \nadditions” finds support in the Commission’s June 2026 Order to Show Cause, which \nexpressly required PJM and the PJM Transmission Owners to post and regularly update \ndata and details concerning large load additions.130   \n \n127 Wholesale Competition in Regions with Organized Electric Markets, Order No. 719-A, 128 FERC \n¶ 61,059, order on clarification, Order No. 719-B, 129 FERC ¶ 61,252 (2009). \n128 Order No. 719-A, 128 FERC ¶ 61,059 at P 60; PJM Interconnection, L.L.C., 135 FERC ¶ 61,211, at P 3 \n(2011).  \n129 PJM Interconnection, 135 FERC ¶ 61,211 at P 3 (citing PJM Interconnection, L.L.C., Request for Limited \nTariff Waiver, and Request for Fast Track Processing of PJM Interconnection, L.L.C., Docket No. \nER11-3386-000, at 4-5 (Apr. 19, 2011)). \n130 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 74."},{"page":54,"startToken":17123,"endToken":17340,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 48 \n \n \n \nIn fact, the Commission found, therein, that PJM’s Tariff appeared to be unjust and \nunreasonable because it lacked, inter alia, “provisions that would require PJM and the \nTransmission Owners to publicly post and regularly update data that details:  (1) the \naggregate amounts of proposed large load additions in PJM’s footprint, including the \naggregate amounts in each transmission pricing zone.”131  In particular, the Commission \nexpressed concern that “without sufficient transparency . . . stakeholders may lack \ninformation and visibility regarding the costs driven by large load additions.”132  Likewise, \nthe Large Load Registry provides transparency to PJM, states, the Independent Market \nMonitor for PJM, and other entities with the ability to obtain such information and—\nthrough aggregated data posted on PJM’s website—transparency to stakeholders, \nregarding the zones/areas with the greatest concentrations of Large Loads that may be \neligible to provide IRAS during a particular Delivery Year.  As such, PJM’s proposal to \ngather the data, materials, and other inputs into the Large Load Registry is in line with the \nCommission’s overall interest in supporting transparency with respect to information about \nLarge Loads.   \n \n131 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 76. \n132 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 74."},{"page":55,"startToken":17340,"endToken":17631,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 49 \n \n \n \nC. \nNew Large Loads Can Avoid Being Subject to Interim Resource \nAdequacy Service by Bringing New Capacity to Offset Their Capacity \nNeeds.  This Is Consistent with the Ratepayer Protection Pledge and Is a \nJust and Reasonable Condition to Maintaining System Reliability.  \n1. \nRequirement for New Large Loads to bring capacity or be subject \nto load reductions  \nTo make clear an LSE’s obligations associated with bringing a New Large Load to \nthe transmission system, PJM is proposing a new section 7.8 to the RAA.  Article 7 of the \nRAA is for detailing LSEs Reserve Requirements and Obligations, and PJM proposes to \nexpand those obligations, effective June 1, 2027, to include a requirement that the LSE \nserving each New Large Load “designate one or more Generation Capacity Resources or \nCapacity Storage Resources that had not cleared an RPM Auction as Network Resource(s) \nin a cumulative amount that equals or exceeds the LSE’s New Large Load’s peak load (in \nMW) as reported in the Large Load Registry pursuant to RAA, Schedule 11.”133  To the \nextent, the LSE does not designate a sufficient amount of Network Resources, then “such \nNew Large Load may be subject to load reduction requests during Emergencies prior to \nPre-Emergency Load Management Response.”134  This provision of the proposed section, \nwhile it includes the concepts that underlie the IRAS framework, is not dependent on \nCommission acceptance of the IRAS rules in proposed Tariff, Attachment DD-4 to be \neffective.  \nTo tie this concept with the IRAS program, PJM further proposes a second sentence \nthat joins this provision with the IRAS program.  Specifically, it provides that to the extent \n \n133 Proposed RAA, section 7.8. \n134 Proposed RAA, section 7.8."},{"page":56,"startToken":17631,"endToken":17919,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 50 \n \n \n \nan LSE service a New Large Load has not “designated such Network Resource(s) as \nBYONC with which it has entered into an arrangement in accordance with this requirement \nand Tariff, Attachment DD-4,” the New Large Load will need to provide IRAS “subject to \nthe rates, terms, and conditions of Interim Resource Adequacy Service, as set forth in \nTariff, Attachment DD-4.”135  These IRAS rates, terms, and conditions are discussed in the \nfollowing sections of this transmittal letter. \n2. \nBring Your Own New Capacity arrangements with New Large Load  \nTo incentivize Large Loads to address the capacity shortfall caused by their rapid \ngrowth, in both speed to interconnection and volume of capacity needed, PJM is proposing \nto allow New Large Loads to remove themselves—in whole or in part—from the MW \neligible for IRAS where such loads bring new capacity to the PJM Region.  As discussed \nbelow, to ensure such capacity is in fact “new” and not simply existing generation capacity \nthat is repackaged, and to ensure the benefits of the new capacity are not ephemeral and \nwill not dissipate quickly, PJM is proposing for such new capacity certain gating criteria \nand imposing capacity market participation requirements. \na. \nPJM proposes to define BYONC as new megawatts of \nUnforced Capacity.  \nBefore turning to the gating criteria and market participation requirements, it is \nimportant to understand what this new capacity is definitionally.  First, PJM is calling this \nnew capacity “Bring Your Own New Capacity,” or “BYONC” for short, to convey that the \nNew Large Load should bear some responsibility for bringing this new capacity to \ncorrespond with the addition of the New Large Load.   \n \n135 Proposed RAA, section 7.8."},{"page":57,"startToken":17919,"endToken":18228,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 51 \n \n \n \nSecond, at a basic level, BYONC is “megawatts of Unforced Capacity.”136  This is \nconsistent with how Capacity Resources under PJM’s capacity market design are also MW \nand not the underlying physical resource that supports a Capacity Resource.137  RPM \nAuctions clear MW of UCAP; that is the traded product.  Thus, in the same vein, BYONC \nis designed to offset the capacity need presented by the New Large Load.  Further, as \ndiscussed below, BYONC will also be Capacity Resources, but will be a subset of Capacity \nResources that have arrangements with New Large Loads, must meet the BYONC RPM \nparticipation requirements discussed below, and also must meet all applicable requirements \nfor Capacity Resources.138 \nIn addition, defining BYONC as simply MW provides significant flexibility in how \nNew Large Loads meet their capacity requirements and how resources can provide \nBYONC to New Large Loads, and provide a more liquid marketplace for matching New \nLarge Loads with BYONC.  For example, a New Large Load can enter into BYONC \narrangements with multiple qualifying resources to cover its peak load, and likewise, a \nresource can provide MW for purposes of entering into BYONC arrangements with \nmultiple New Large Loads so long as these arrangements are clearly identified and \nconsistent with the Large Load Registry.  Through this approach of commoditizing the \ncapacity attributes of a physical resource, the lumpiness inherent in matching New Large \n \n136 See proposed Tariff, Definitions – Bring Your Own New Capacity. \n137 See RAA, Article 1, Definitions (“‘Capacity Resources’ shall mean megawatts . . . .”); see also Energy \nHarbor, LLC v. FERC, 143 F.4th 388, 394 (D.C. Cir. 2025) (“The [PJM] Tariff defines a Capacity Resource \nas the amount of net megawatts committed from one or many generating units, not a physical facility.” \n(citation omitted)).     \n138 See proposed Tariff, Attachment DD-4, section VI."},{"page":58,"startToken":18228,"endToken":18577,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 52 \n \n \n \nLoads with physical resources is smoothed, allowing for a more efficient and timely means \nof addressing the capacity shortfall otherwise caused by the addition of New Large Loads. \nThird, the capacity must be “new.”  Given that PJM is currently short of capacity \nand looking to reestablish a healthy capacity reserve margin, PJM is proposing that any \ncapacity added to the system starting with the 2027/2028 BRA will qualify as new—subject \nto the gating criteria discussed below, while capacity already on the system would not fall \nwithin the definition of BYONC.   \nFor the same reason, PJM is proposing that “[m]egawatts of Unforced Capacity that \nhave been previously included in an FRR Capacity Plan prior to the 2027/2028 Delivery \nYear do not qualify as BYONC.”139  The capacity must be new to the PJM system, not just \nnew to the capacity market.140  As such, New Large Loads should only be exempted from \nIRAS if it has arrangements with capacity not already on the system as of May 31, 2027, \nthe day before IRAS becomes available as a tool for PJM operators. \nHowever, in the event the PJM Region has sufficient capacity to meet the PJM \nRegion Reliability Requirement for three consecutive Delivery Years, the IRAS rules will \nnot apply—no IRAS will be required, and BYONC will not be needed to address New \nLarge Loads’ capacity needs.  In such circumstance, all existing BYONC would be relieved \nof their BYONC market participation requirements and can be just regular Capacity \nResources.141  But, to the extent the PJM Region again falls short of securing sufficient \n \n139 See proposed Tariff, Definitions – Bring Your Own New Capacity. \n140 See proposed RAA, Schedule 8.1, section D 1.1 (“An FRR Entity may not include in its FRR Capacity \nPlan any MW quantity of Existing Generation Capacity Resource in excess of what such FRR Entity owned \nor contracted by such FRR Entity prior to June 1, 2027, to serve New Large Load.”).  \n141 See proposed Tariff, Attachment DD-4, section IV(b)(iii)."},{"page":59,"startToken":18577,"endToken":18848,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 53 \n \n \n \ncapacity to meet the PJM Regional Reliability Requirement and the need for IRAS arises, \nthen the “new” capacity needed will no longer be measured against the capacity in the \nsystem prior to the 2027/2028 Delivery Year.  Rather, it will be measured against the \ncapacity supply existing at that time, such that BYONC would be any new capacity that \nhas “not cleared in an RPM Auction conducted for a Delivery Year prior to the first \nDelivery Year” in which the PJM Region is short of capacity, while still meeting the gating \ncriteria.142  \nb. \nPJM is proposing reasonable gating criteria designed to \nstimulate development of new capacity. \nSuch new capacity may be supported by generation, storage, or demand-side \nresources that meet certain gating criteria.  The gating criteria are designed to ensure that \nthe capacity is “new” and not a repackaging of existing capacity or capability.   \nThus, for generation and storage resources, PJM proposes that the BYONC must \nbe supported by:  “(1) a new-build generation resource including new resources that obtain \nCapacity Interconnection Rights [(“CIR”)] transferred from deactivated resources or \nresources that have announced deactivation as of April 10, 2026; (2) the incremental \ncapacity created by an uprate of Existing Generation Capacity Resources, but only to the \nextent such incremental capacity is created through an increase in such Generation \nCapacity Resource’s installed capacity and increase in [CIRs] associated with that \nGeneration Capacity Resource; (3) the incremental capacity created by the utilization of \nSurplus Interconnection Service; (4) repowering of a deactivated generation resource that \n \n142 See proposed Tariff, Attachment DD-4, section VI(a)(ii)."},{"page":60,"startToken":18848,"endToken":19153,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 54 \n \n \n \ndeactivated prior to April 10, 2026; or (5) incremental capacity, whether due to greater \nUnforced Capacity or a higher level of [CIRs], created by an Existing Generation Capacity \nResource’s changing fuel type to a more efficient fuel type.”143  Each of these gating criteria \nensures that the BYONC will be capacity that was not on the transmission system or \notherwise available to meet the PJM Region’s needs as of June 1, 2027.  \nBecause capacity may also be supplied by demand-side resources, PJM proposes \nthat BYONC may be supported by Planned Demand Resource or Planned Distributed \nEnergy Resources (“DER”) Capacity Aggregation Resources, as described in RAA, \nSchedule 6 and Schedule 6.2.  Such resources would need to be composed of registered \nlocations that did not previously support a capacity commitment or reduce the amount of \ncapacity needed to meet the PJM Region Reliability Requirement through a Peak Shaving \nAdjustment or Price Responsive Demand for or prior to the 2026/2027 Delivery Year.144  \nThus, just as for BYONC supported by generation and storage resources, demand-side \nBYONC would need to be “new” starting June 1, 2027.  However, this date would need to \nbe reset in the event the PJM Region has sufficient capacity to meet the PJM Region \nReliability Requirement for three consecutive Delivery Years—meaning the IRAS rules \nwould not apply and BYONC will not be needed—and then the PJM Region again falls \nshort of securing sufficient capacity to meet the PJM Regional Reliability Requirement.  \nAs discussed, such capacity shortage would trigger the need for IRAS again.  In such \ncircumstance, because the “new” capacity would need to be measured against the capacity \n \n143 See proposed Tariff, Attachment DD-4, sections VI(b)(i)(1)-(5). \n144 See proposed Tariff, Attachment DD-4, sections VI(b)(ii)(1)-(2)."},{"page":61,"startToken":19153,"endToken":19441,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 55 \n \n \n \nsupply existing at that time, any demand-supported capacity would need to be “composed \nof, or reliant on, any location registered in the Delivery Year prior to the first Delivery \nYear” the PJM Region experienced the capacity shortage.145 \n3. \nTo ensure the capacity benefits of BYONC are real and lasting, PJM \nis proposing certain RPM participation requirements. \nFor BYONC to address the capacity needs of New Large Loads, BYONC must be \nCapacity Resources, with all attendant rights and obligations, and obtain capacity \ncommitments.  PJM is proposing a number of RPM participation requirements designed to \nobtain the maximum capacity benefit from the BYONC.   \nFirst, all BYONC must be Capacity Resources,146 and when committed through an \nRPM Auction to provide capacity, the BYONC “will be subject to all capacity market rules, \nas set forth in Tariff, Attachments DD and DD-1.”147  While these requirements may seem \nobvious, they make clear to all entities the rules and obligations that accompany \narrangements between the UCAP of their resource and New Large Loads.  Thus, if the \nresource supporting BYONC fails to appear or is otherwise unavailable for a Delivery Year, \nthe seller will be subject to “all relevant deficiency charges under Tariff, \nAttachment DD.”148 \nSecond, to ensure that BYONC clear the auction and obtain a capacity commitment, \nPJM proposes a general requirement that each BYONC must participate, as a price taker \n(i.e., $0/MW offer) in RPM Auctions for 10 consecutive Delivery Years, starting with the \n \n145 Proposed Tariff, Attachment DD-4, section VI(b)(ii)(1). \n146 See proposed Tariff, Attachment DD-4, section VIII(a). \n147 Proposed Tariff, Attachment DD-4, section VIII(c). \n148 Proposed Tariff, Attachment DD-4, section VIII(d)."},{"page":62,"startToken":19441,"endToken":19754,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 56 \n \n \n \nfirst Delivery Year of the arrangement with New Large Load.149  As part of this 10-year \nparticipation requirement, PJM is proposing that the BYONC would be subject to the \n“capacity must-offer requirements and exceptions set forth in Tariff, Attachment DD, \nsections 6.6 and 6.6A,” and that the BYONC would be prohibited from “seek[ing] an \nexception to the capacity must-offer requirement to provide an external sale” during this \n10-year period.150  \nThe 10-year participation requirement for generation and storage resources, \nincluding the no-external-sale rule, is just and reasonable.  It is designed to ensure that this \nBYONC is real and lasting.  New capacity brought to address a New Large Load’s \nsignificant capacity demands should not be allowed to sell its capacity attributes outside of \nPJM.  Such would undermine the purpose of BYONC, particularly given that New Large \nLoads with BYONC arrangements are included in the demand curve.  If the new capacity \nwas able to withdraw from serving as a PJM Capacity Resource, but the load continued to \nbe considered in the VRR Curve, then the New Large Load would no longer be the entity \nresponsible for procuring its capacity.  Rather, that obligation would have been transferred \nto PJM and shared with other PJM loads, contrary to the purpose of the IRAS scheme. \nBYONC supported by a Demand Resource or DER Capacity Aggregation Resource \nlikewise has a 10-year commitment.151  However, the seller of the BYONC may replace its \n \n149 See proposed Tariff, Attachment DD-4, section VIII(e). \n150 Proposed Tariff, Attachment DD-4, section VIII(b). \n151 See proposed Tariff, Attachment DD-4, section VIII(e) (“To the extent the resource is a Demand Resource \nor DER Capacity Aggregation Resource, the BYONC shall participate in RPM Auctions for ten (10) \nconsecutive Delivery Years as an Annual Demand Resource or DER Capacity Aggregation Resource, as \napplicable.”)."},{"page":63,"startToken":19754,"endToken":20014,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 57 \n \n \n \nBYONC obligation with a different BYONC subject to certain conditions.  First, the initial \nBYONC seller (i.e., the releasing BYONC) must report—or cause to be reported—the new \narrangement with the replacement BYONC in accordance with the reporting rules, and the \nreplacement BYONC seller will need to provide the certification attesting to the \narrangement.  Second, the replacement BYONC must be for the remainder of the releasing \nBYONC’s 10-year commitment.  And, third, the releasing BYONC (and its supporting \nregistrations) may no longer provide BYONC going forward.152   \nThis exception to the 10-year commitment for demand-supported BYONC is just \nand reasonable, as it increases commercial opportunities for BYONC without adversely \naffecting the region’s ability to address its capacity needs.  PJM understands that this \nexception provides New Large Loads a “bridge to power” of near-term demand-supported \ncapacity that is eventually replaced with new generation as that supply comes online.  As \nsuch, it increases opportunities for New Large Loads to spur the development of additional \ncapacity in a few years, while relying on existing (or their own) demand-side capacity \ncapability. \nThe requirement to offer BYONC MW as price takers ($0/MW) is both just and \nreasonable.  To realize the capacity benefits of a BYONC arrangement, the resource must \nsuccessfully clear an RPM Auction and secure a capacity commitment.  The BYONC \narrangement itself serves as the commitment to provide this capacity.  Because the resource \nis already obligated to provide the capacity, its incremental, going-forward avoidable costs \n \n152 See proposed Tariff, Attachment DD-4, section VIII(e)."},{"page":64,"startToken":20014,"endToken":20353,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 58 \n \n \n \nto secure the RPM commitment are zero.  Offering as a price taker directly reflects this \nzero-cost profile and guarantees the resource clears the auction.  \nThis treatment also preserves market balance.  Matching the inclusion of New \nLarge Loads in the VRR Curve (demand side) with the corresponding BYONC MW in the \nsupply stack at $0/MW creates a symmetrical, one-for-one addition.  This structure \nprevents artificial price shifts, resulting in an effectively price-neutral outcome for the rest \nof the market.  This mechanism is consistent with existing Commission-approved rules for \nother resources retained for reliability purposes, which are also treated as price takers.153 \nFinally, however, BYONC RPM participation requirements are extinguished if \nIRAS is not needed for three consecutive Delivery Years.154  This means that the BYONC \nwould no longer be required to offer as price takers for the remainder of their 10-year term.  \nBecause they are Capacity Resources BYONC would still be subject to the capacity \nmust-offer requirement (to the extent they are not supported by Demand Resources or DER \nCapacity Aggregation Resources).  But, they would be free to meet the requirements for an \nexception based on an external sale.  \n \n153 See, e.g., PJM Interconnection, L.L.C., 190 FERC ¶ 61,088, at P 50, reh’g denied, 192 FERC ¶ 61,135, \nat PP 31-34 (2025); Indep. Power Producers of N.Y. v. N.Y. Indep. Sys. Operator, Inc., 150 FERC ¶ 61,214 \n(2015), order granting in part & denying in part clarification & reh’g, 170 FERC ¶ 61,118 (2020); N.Y. \nIndep. Sys. Operator, Inc., 150 FERC ¶ 61,116 (2015), order on reh'g & compliance, 155 FERC ¶ 61,076 \n(2016), order on reh'g & compliance, 161 FERC ¶ 61,189 (2017), order on clarification & reh’g, 163 FERC \n¶ 61,047 (2018); see also ISO New Eng. Inc., 165 FERC ¶ 61,202, at PP 82-88 (2018) (approving price taker \ntreatment for resource retained for fuel security purposes), order addressing arguments raised on reh’g, 173 \nFERC ¶ 61,204 (2020). \n154 See proposed Tariff, Attachment DD-4, section VIII(f)."},{"page":65,"startToken":20353,"endToken":20675,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 59 \n \n \n \n4. \nReporting arrangements between BYONC and New Large Loads, \nand obligatons on BYONC of an arrangement  \nThe purpose of the BYONC construct is to incent New Large Loads to facilitate the \ndevelopment of new capacity so that the PJM Region has sufficient capacity to maintain \nreliability without entering into a capacity shortage and/or having to shed existing native \nload customers.  To do so, the New Large Loads need to be able to get credit for any \nBYONC they facilitate.155  PJM proposes to give them credit by allowing New Large Loads \nto report to PJM an arrangement the New Large Load enters into with BYONC, and such \narrangement will result in a reduction in the New Large Loads MW available to provide \nInterim Resource Adequacy Service. \na. \nThe clear two-step process for PJM to recognize \narrangements between New Large Loads and BYONC \nObtaining recognition for arrangements between BYONC with a New Large Load \nis a relatively basic process, with only two steps.  One, an entity needs to report the \narrangement to PJM by identifying both the New Large Load and the BYONC.  While PJM \nexpects the LSE serving the New Large Load or the applicable Electric Distributor to make \nsuch report, the proposed rules contemplate that PJM “may also accept information to the \nextent interconnection customers, Large Loads, Transmission Owners, or other entities \nvoluntarily report any BYONC that may be in an arrangement with a New Large Load.”156 \nTwo, “the resource owner or entity with contractual authority to enter into a \nBYONC arrangement must certify” to PJM that the BYONC has an arrangement with that \n \n155 See proposed Tariff, Attachment DD-4, section V(c) (“For purposes of removing its eligibility to provide \nInterim Resource Adequacy Service, a New Large Load may enter into arrangements with BYONC supported \nby one or more resources.”). \n156 Proposed Tariff, Attachment DD-4, section VII(a)(i)."},{"page":66,"startToken":20675,"endToken":20968,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 60 \n \n \n \nNew Large Load and that the BYONC will follow the RPM participation requirements in \nproposed Tariff, Attachment DD-4, section VIII.157  Both elements of this certification are \ncrucial.  The BYONC representative attesting to the arrangement confirms the reported \narrangement in the other step, providing certainty that the New Large Load’s capacity needs \nwill be addressed (at least in part) through this BYONC.  Certification that the BYONC is \naware of and intends to abide by the RPM participation requirements, which as discussed \nabove, include a 10-year must-offer at $0/MW, provides a level of certainty that the \nBYONC will be real and lasting.  Together, these certifications provide confidence that the \ncapacity needs of the New Large Load will be addressed (at least in part as discussed below \nin Part II.C.6) by this BYONC, allowing PJM to include such loads in the demand curve \nused to clear RPM Auctions.   \nb. \nArrangements must be reported to PJM in a timely manner \nto allow for them to be reflected in the RPM Auctions, \nbecause an arrangement will not be effective for Delivery \nYears before the BYONC clears an RPM Auction. \nBecause New Large Loads in arrangements with BYONC will be included in the \nVRR Curve used to clear RPM Auctions—and the BYONC in the arrangement will be \nrequired to participate in RPM Auctions as price takers, it is important that any BYONC \narrangements expected to start in a future Delivery Year are timely reported to PJM to \nallow such load to be reflected in the VRR Curve.  Without timely reporting, the BYONC \ncould clear the auction without associated load being included in the demand curve, which \n \n157 Proposed Tariff, Attachment DD-4, section VII(a)(ii)."},{"page":67,"startToken":20968,"endToken":21249,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 61 \n \n \n \nwould artificially show more capacity available to serve the PJM Region generally than \nwould be appropriate.   \nTo be clear, arrangements between New Large Loads and new resources need to be \nreported prior to the first Delivery Year they will be in place.  PJM will validate the \narrangement as discussed, and update the Large Load Registry to reflect any PJM-validated \narrangements between New Large Loads and BYONC.  That is, PJM will validate the \nBYONC to make sure it meets the BYONC rules and is capable of providing the level of \ncapacity, and to avoid duplicate arrangements between BYONC and New Large Loads, \nand PJM will, as necessary, validate the data regarding the New Large Load with the \nElectric Distributor that interconnected the Large Load for retail service.158   \nThe above timing concerns are most present where the arrangement is known or \nhas otherwise been consummated.  Thus, PJM proposes rules requiring timely reporting of \nBYONC-New Large Load arrangements prior to the next RPM Auction for the first \nDelivery Year of each arrangement.   \ni. \nReporting BYONC-New Large Load arrangements \nfor the 2027/2028 and 2028/2029 Delivery Years \nFor the 2027/2028 and 2028/2029 Delivery Years, because (1) the BRAs have \nalready run; (2) IRAS is not intended to commence until June 1, 2027; and (3) parties need \ntime to develop appropriate contractual arrangements, PJM proposes that, for an \narrangement to be considered in determining a New Large Load’s availability to provide \nIRAS, as measured by its Eligible New Large Load Amount, any arrangement for these \n \n158 Once an arrangement is reported to PJM, there are no ongoing reporting requirements for subsequent \nDelivery Years."},{"page":68,"startToken":21249,"endToken":21543,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 62 \n \n \n \nDelivery Years must be reported to PJM by April 1 before the first applicable Delivery \nYear.159  Reporting arrangements between BYONC and New Large Loads by such date \nwill afford PJM sufficient time to review and validate, and then update the Large Load \nRegistry by April 15 before the Delivery Year.160  PJM will use such data to determine the \namount of IRAS available to PJM for the upcoming Delivery Year, and assign each Electric \nDistributor the amount of IRAS available in their zone/area for the Delivery Year. \nii. \nReporting BYONC-New Large Load arrangements \nfor the 2029/2030 Delivery Year \nThe timing considerations for Delivery Year 2029/2030 are idiosyncratic given that \nthe BRA is scheduled to commence on December 9, 2026, i.e., within 60 days from the \nrequested effective date of this filing.  Accordingly, PJM is proposing that any known \narrangements be reported to PJM “no later than by 50 days prior to the commencement of \nthe 2029/2030 Base Residual Auction,”161 so that PJM may adjust the VRR Curve for that \nauction, as discussed below in Part II.F.  In the event, an arrangement is entered into after \nthat deadline, in order for the “BYONC arrangement to be considered” for the 2029/2030 \nDelivery Year, and the New Large Load’s Interim Resource Adequacy Service availability \nto be reduced, the arrangement must be reported “by 30 days prior to the posting of the \nplanning parameters for the Incremental Auctions arrangement with the 2029/2030 \nDelivery Year.”162   \n \n159 See proposed Tariff, Attachment DD-4, section VII(b). \n160 See proposed Tariff, Attachment DD-4, section VII(b). \n161 Proposed Tariff, Attachment DD-4, section VII(c). \n162 Proposed Tariff, Attachment DD-4, section VII(c)."},{"page":69,"startToken":21543,"endToken":21798,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 63 \n \n \n \niii. \nReporting BYONC-New Large Load arrangements \nfor the 2030/2031 Delivery Year and subsequent \nDelivery Years \nStarting with the 2030/2031 Delivery Year and for all future Delivery Years, for any \nBYONC arrangement to be considered for a given Delivery Year, the arrangement must be \nreported to PJM “no later than by 30 days prior to the posting of the planning parameters \nfor the relevant RPM Auction for the initial Delivery Year the BYONC enters into an \narrangement with the New Large Load.”163  Reporting associations 30 days before PJM \nmust post the planning parameters for an RPM Auction provides sufficient time for PJM \nto validate the information provided and reflect such arrangement in the VRR Curve for \nthat auction.  It also reasonably balances providing entities the maximum time possible to \nagree on the arrangements.   \nc. \nRules for BYONC arrangements \nPJM is also proposing certain rules around BYONC-New Large Load arrangements  \nto ensure no capacity is double counted and to facilitate efficient matchmaking between \nNew Large Loads and new capacity.  As discussed above, BYONC is composed of MW, \nnot a physical resource.  This allows for efficient sizing of BYONC to meet the exact \ncapacity needs of New Large Loads, and allows for liquidity in the market for matching \nthe two.   \nIn this regard, PJM proposes that “[a] physical resource may support multiple \nBYONC, each of which may be in an arrangement with different New Large Loads, as long \n \n163 Proposed Tariff, Attachment DD-4, section VII(d)."},{"page":70,"startToken":21798,"endToken":22107,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 64 \n \n \n \nas no BYONC is in an arrangement with more than one New Large Load,”164 and that “[a] \nNew Large Load may enter into an arrangement with discrete BYONC supported by \ndifferent physical resources.”165  In other words, New Large Load may reduce or eliminate \nits IRAS availability by mixing and matching BYONC supported by many different \nphysical resource, with the caveat that no MW of BYONC may sold twice.  This approach \nbest allows resources to price each MW of BYONC capability and derive an alternative \nrevenue stream that will facilitate the development of new capacity in PJM.   \nTo provide further flexibility, PJM is proposing that “[a] New Large Load may enter \ninto an arrangement with BYONC in excess of its current Eligible Large Load Amount, \ne.g., to allow for expected growth in the New Large Load.”166  Thus, a New Large Load \nthat has plans for expanding in the future may go ahead and lock in BYONC for such \nplanned growth before the growth occurs.  This type of arrangement would occur where \nthe new capacity enters commercial operation at its maximum facility output level while \nthe New Large Load has not achieved its maximum expected demand level.  Offering this \nflexibility to the New Large Load and BYONC arrangements is reasonable, as it allows the \nparties to fashion their arrangements however they see fit. \nWhile PJM is proposing significant flexibility in reaching BYONC-New Large \nLoad arrangements, PJM is proposing that once the subject of an arrangement BYONC \ncannot change to a different New Large Load—i.e., BYONC is non-transferable.  \nSpecifically, PJM is proposing that “BYONC that is in an arrangement with a New Large \n \n164 Proposed Tariff, Attachment DD-4, section VII(f). \n165 Proposed Tariff, Attachment DD-4, section VII(g). \n166 Proposed Tariff, Attachment DD-4, section VII(h)."},{"page":71,"startToken":22107,"endToken":22434,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 65 \n \n \n \nLoad must remain in such arrangement with that New Large Load unless and until the New \nLarge Load is permanently out-of-service.”167  This limitation is necessary and consistent \nwith PJM’s overall scheme.  Specifically, PJM is proposing that once BYONC is in an \narrangement with a New Large Load, such arrangement is permanent,168 and the New Large \nLoad gets the benefit of “bringing” this new capacity to the system and permanently \nreduces its availability to provide Interim Resource Adequacy Service by the ICAP \nequivalent of the BYONC.169  Allowing BYONC to leave or be traded after entering into \nan arrangement with a New Large Load would dramatically increase the complexity of the \nprogram without commensurate benefit.  New Large Loads would be susceptible to \nfluctuations in their Interim Resource Adequacy Service availability, and could be left \nscrambling for additional BYONC.  PJM would need to expend extra resources ensuring \nno BYONC enters into an arrangement with New Large Load more than once.  \nd. \nThe Accredited UCAP value for BYONC subject to an \narrangement is set in the first Delivery Year the arrangement \nis in effect. \nThe timing of the arrangement is central to the determination of the BYONC’s \nAccredited UCAP value—the ICAP equivalent of this Accredited UCAP value is used to \n \n167 Proposed Tariff, Attachment DD-4, section VII(e). \n168 As discussed, PJM is proposing that BYONC based on Demand Resources or DER Capacity Aggregation \nResources may be replaced within the 10-year RPM Auction commitment.  This does not affect the \nrequirement the BYONC is permanent, as the Demand Resources or DER Capacity Aggregation Resources \nbeing replaced must be retired and their registered locations can never support future BYONC.  See proposed \nTariff, Attachment DD-4, section VIII(e) (“[T]he replaced BYONC (and its supporting registrations) may no \nlonger provide BYONC.”). \n169 See proposed Tariff, Attachment DD-4, section V(b) (determination of a New Large Load’s Eligible New \nLarge Load Amount)."},{"page":72,"startToken":22434,"endToken":22806,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 66 \n \n \n \nreduce a New Large Load’s potential IRAS availability as discussed below in Part II.C.7.170  \nFor BYONC supported by any resource type (generation, storage, and demand-side), the \nAccredited UCAP of the BYONC “shall be the Accredited UCAP for the RPM Auction in \nwhich the BYONC cleared for the initial Delivery Year the BYONC is in an arrangement \nwith the New Large Load.”171  For BYONC supported by Demand Resources or DER \nCapacity Aggregation Resources, such Accredited UCAP value “must be demonstrated \neach year for a 10-year period using the Demand Response or DER Capacity Aggregation \nResources installed capacity for the first Delivery Year after the BYONC is in an \narrangement with the New Large Load.”172  This requirement is derived from PJM’s \nexisting Demand Resource rules, which require sellers to the “demonstrate, to PJM’s \nsatisfaction, that such resource shall have the capability to provide a reduction in demand, \nor otherwise control load, on or before the start of the Delivery Year for which such \nresource is committed.”173  However, given the 10-year commitment for BYONC, the usual \none-year demonstration must extend to cover all 10 years.  This is reasonable, as it provides \na level of assurance that the capacity to be provided by such demand-side resource is \ncommensurate with that offered by a generation or storage resource.  \n \n170 See proposed Tariff, Attachment DD-4, section V(b) (“A New Large Load’s Eligible New Large Load \nAmount shall be determined as follows: (New Large Load’s registered peak load (in MW), as provided in the \nLarge Load Registry) minus (the sum of all BYONC arrangements with the New Large Load in accordance \nwith Tariff, Attachment DD-4, section VII divided by the Forecast Pool Requirement for the first Delivery \nYear in which the BYONC cleared an RPM Auction, plus Allocated RBP UCAP MW assigned to the New \nLarge Load, in accordance with Tariff, Attachment DD-4, section IX divided by the Forecast Pool \nRequirement for the first Delivery Year in which the Allocated RBP UCAP MW cleared an RPM Auction).”). \n171 Proposed Tariff, Attachment DD-4, sections VII(i)(i)-(ii). \n172 Proposed Tariff, Attachment DD-4, section VII(i)(ii). \n173 RAA, Schedule 6, section A.5."},{"page":73,"startToken":22806,"endToken":23187,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 67 \n \n \n \n5. \nAllocated RBP UCAP MW    \nIn addition to BYONC, a New Large Load may have its IRAS availability reduced \nby being allocated a share of the RBP UCAP MW174 obtained through the Reliability \nBackstop Procurement that PJM has proposed in Docket No. ER26-3380.175   \nUnder the proposed RBP rules, the costs for committed RBP UCAP MW are, as a \ngeneral matter, allocated to each Electric Distributor’s zones/areas based on its pro-rata \nshare of forecasted load growth in the PJM Region from the 2026/2027 Delivery Year to \nthe 2028/2029 Delivery Year.176  To do so, PJM used the total load growth, in part to \ndetermine the target quantity to be committed through the Reliability Backstop \nProcurement, called the “Final RBP Target,” and provided that costs for such resources will \nbe allocated “an Electric Distributor’s zone/area on a pro-rata basis using the zone/area’s \nassigned share of the total Final RBP Target MW across all zone/areas.”177  In other words, \nthose areas that have forecasted load growth—which is generally due to Large Loads, \nincluding New Large Loads—will be allocated the costs for the RBP UCAP MW.   \nFor purposes of IRAS availability, PJM proposes that the allocation of RBP UCAP \nMW following the RBP cost allocation at the Electric Distributor zone/area level, such that \neach Electric Distributor zone/area “shall be allocated RBP UCAP MW on a pro-rata basis \n \n174 RBP UCAP MW is the unforced capacity product committed through the RBP. \n175 RBP Proposal Filing, Transmittal Letter at 46. \n176 See RBP Proposal Filing, proposed Tariff (Attachments A & B), Attachment DD, section 18.3(a) (“The \nOffice of the Interconnection shall allocate the Initial RBP Target MW to each Electric Distributor’s \nzone/area using that zone/area’s pro-rata share of the difference between the forecasted Load Adjustments \nfor the 2026/2027 Delivery Year and the 2028/2029 Delivery Year. . . . The resulting reduced MW, floored \nat zero, is used to calculate the zone/area’s assigned pro-rata share of the Final RBP Target MW.  The \nzone/area’s assigned share of the Final RBP Target MW shall remain constant throughout the fixed, 15-year \nterm.”). \n177 RBP Proposal Filing, proposed Tariff (Attachments A & B), Attachment DD, section 18.3(a)."},{"page":74,"startToken":23187,"endToken":23455,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 68 \n \n \n \nusing the Electric Distributor zone/area’s assigned share of the total Final RBP Target MW \nacross all zone/areas.”178  From there, to allocate that quantity among New Large Load’s \nin the Electric Distributor’s zone/area, PJM proposes that the Electric Distributor “shall \ninform [PJM] how such RBP UCAP MW should be further allocated among the New Large \nLoads located in the Electric Distributor’s zone/area.”179  But, in the event the Electric \nDistributor has not informed PJM how to allocated its share of RBP UCAP MW among its \nNew Large Loads by April 1 before a given Delivery Year, PJM will allocate that quantity \npro rata among the New Large Loads in the zone/area.180  Since RBP commitments can \nvary each Delivery Year as RBP Resources enter commercial operation, the allocation of \nRBP UCAP MW will be done for each Delivery Year throughout the 15-year RBP \ncommitment term, i.e., from 2028/2029 through 2042/2043.   \nPJM’s proposed approach is just and reasonable.  The “benefit” of RBP UCAP MW \nin the context of IRAS should flow to the entities with cost responsibility for the RBP \nUCAP MW.  Thus, New Large Loads should get an offset credit to their capacity needs for \nRBP UCAP MW. \n \n178 Proposed Tariff, Attachment DD-4, section IX(a). \n179 Proposed Tariff, Attachment DD-4, section IX(b)(i).  Each New Large Load’s allocated share of its \nzone/area’s RBP UCAP MW is called “Allocated RBP UCAP MW.”  See proposed Tariff, Definitions – \nAllocated RBP UCAP MW. \n180 Proposed Tariff, Attachment DD-4, section IX(b)(ii)."},{"page":75,"startToken":23455,"endToken":23918,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 69 \n \n \n \n6. \nOnly Eligible New Large Loads will be considered available to \nprovide Interim Resource Adequacy Service, and then only to the \nextent they do not have sufficient BYONC to meet their capacity \nneeds. \nAll New Large Loads shall be eligible to provide IRAS and considered Eligible \nNew Large Loads181 to the extent the combination of their BYONC arrangements and \nAllocated RBP UCAP MW does not meet their capacity needs.182  To determine whether a \nNew Large Load is an Eligible New Large Load, PJM will determine its Eligible New \nLarge Load Amount—a measurement of the difference between the New Large Load’s \npeak load (in MW) as reported in the New Large Load Registry and the ICAP equivalent \nof its (1) BYONC arrangements and (2) Allocated RBP UCAP MW.183  If the Eligible New \nLarge Load Amount is greater than zero MW, the New Large Load is an Eligible New \nLarge Load.184   \n \n181 See proposed Tariff, Definitions – Eligible New Large Load (‘“Eligible New Large Loads’ shall mean a \nNew Large Load eligible to provide Interim Resource Adequacy Service in accordance with Tariff, \nAttachment DD-4, section V.”). \n182 See proposed Tariff, Attachment DD-4, section V(a); see also proposed Tariff, Attachment DD-4, section \nIV(a) (“All Eligible New Large Loads shall be available to be requested to provide Interim Resource \nAdequacy Service by [PJM].”). \n183 See proposed Tariff, Attachment DD-4, section V(b) (“A New Large Load’s Eligible New Large Load \nAmount shall be determined as follows: (New Large Load’s registered peak load (in MW), as provided in the \nLarge Load Registry) minus (the sum of all BYONC arrangements with the New Large Load in accordance \nwith Tariff, Attachment DD-4, section VII divided by the Forecast Pool Requirement for the first Delivery \nYear in which the BYONC cleared an RPM Auction, plus Allocated RBP UCAP MW assigned to the New \nLarge Load, in accordance with Tariff, Attachment DD-4, section IX divided by the Forecast Pool \nRequirement for the first Delivery Year in which the Allocated RBP UCAP MW cleared an RPM Auction).”). \n184 See proposed Tariff, Attachment DD-4, section V(a) (“New Large Loads with a cumulative installed \ncapacity equivalent of their BYONC arrangements and assigned Allocated RBP UCAP MW that equals or \nexceeds the New Large Load’s registered peak load, as provided in the Large Load Registry, shall not be \nEligible New Large Loads.  New Large Loads that are located within an FRR Service Area cannot be Eligible \nNew Large Loads.”). \n184  See proposed Tariff, Attachment DD-4, section V(a).  This is reasonable given that FRR Entities are \nindividually responsible for securing sufficient capacity for all loads within their FRR Service Area, and are \ntherefore not reliant on RPM to secure capacity commitments."},{"page":76,"startToken":23918,"endToken":24295,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 70 \n \n \n \n7. \nDetermination of the maximum amount of Interim Resource \nAdequacy Service available for a Delivery Year for the PJM Region \nand each Electric Distributor zone/area. \nThe amount of Interim Resource Adequacy Service PJM may need to be available \nwill be determined each Delivery Year for the PJM Region and each Electric Distributor \nzone/area.  The amount of Interim Resource Adequacy Service needed to be available \ndepends on the level of capacity shortfall for the PJM Region and the Eligible New Large \nLoad Amounts.   \nThere are three possible scenarios.  One, the capacity shortfall185 exceeds the \ncumulative sum of all Eligible New Large Load Amounts across the PJM Region.  In this \nevent, then PJM will need all Eligible New Large Load Amounts to be available to provide \nInterim Resource Adequacy Service for that Delivery Year.186   \nTwo, the capacity shortfall is less than the cumulative sum of all Eligible New \nLarge Load Amounts across the PJM Region.  In this event, then PJM only needs Eligible \nNew Large Loads to make available Interim Resource Adequacy Service in a cumulative \namount equal to the capacity shortfall.187 \n \n185 To use the most precise figure, the capacity shortfall shall be determined after the Third Incremental \nAuction and equal:  “([amount of Capacity Resources committed for a given Delivery Year (as determined \nafter the Third Incremental Auction) is less than the PJM Region Reliability Requirement determined prior \nto the Third Incremental Auction] divided by the Pool-wide Accredited UCAP Factor).”  Proposed Tariff, \nAttachment DD-4, section IV(b)(i). \n186 See proposed Tariff, Attachment DD-4, section IV(b)(i). \n187 See proposed Tariff, Attachment DD-4, section IV(b)(ii) (“In the event ([the amount of Capacity \nResources committed for a given Delivery Year (as determined after the Third Incremental Auction) is less \nthan the PJM Region Reliability Requirement determined prior to the Third Incremental Auction] divided by \nthe Pool-wide Accredited UCAP Factor) by an amount less than the sum (in MW) of all Eligible New Large \nLoad Amounts, then the difference (in MW) shall be the cumulative amount (in MW) of Eligible New Large \nLoad Amounts that the Office of the Interconnection needs to be available to provide Interim Resource \nAdequacy Service for that Delivery Year.”)."},{"page":77,"startToken":24295,"endToken":24611,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 71 \n \n \n \nThird, there is no capacity shortfall, i.e., “([the amount of Capacity Resources \ncommitted for a given Delivery Year (as determined after the Third Incremental Auction) \nequals or exceeds the PJM Region Reliability Requirement determined prior to the Third \nIncremental Auction] divided by the Pool-wide Accredited UCAP Factor)” and PJM “does \nnot need any Eligible New Large Loads to be available to provide Interim Resource \nAdequacy Service for that Delivery Year.”188   \nIf the first or second scenarios occur, PJM will need to determine for the Delivery \nYear the total amount of IRAS needed to be available on a daily basis across the PJM \nRegion and for each Electric Distributor zone/area.189  The regional amount will be the \nlesser of:  the cumulative sum of all Eligible New Large Load Amounts across the PJM \nRegion or the capacity shortfall.190  In either instance, the maximum amount of IRAS PJM \nneeds from an Electric Distributor zone/area will be determined in accordance with the \nfollowing formula: \nthe product of the sum of all Eligible New Large Load Amounts \nneeded in the PJM Region pursuant to Attachment DD-4, \nsection IV(b) multiplied by the quotient of [(the sum of all Eligible \nNew Large Load Amounts in the Electric Distributor’s zone/area) \ndivided by (the sum of all Eligible New Large Load Amounts in the \nPJM Region)].191 \nIn other words, each Electric Distributor zone/area will be required to provide a \nproportional share of the IRAS needed based on the sum of the Eligible New Large Load \nAmounts in its zone/area.  Thought of conversely, each Electric Distributor zone/area will \n \n188 Proposed Tariff, Attachment DD-4, section IV(b)(iii). \n189 See proposed Tariff, Attachment DD-4, section IV(c). \n190 See proposed Tariff, Attachment DD-4, section IV(c)(i). \n191 See proposed Tariff, Attachment DD-4, section IV(c)(ii)."},{"page":78,"startToken":24611,"endToken":24907,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 72 \n \n \n \nneed to be available to provide IRAS consistent with the amount of capacity the Eligible \nNew Large Loads in the zone/area need to meet the zone/area’s capacity needs.  \nAs discussed above in Parts II.C.2.a and II.C.3, to the extent the third scenario (i.e., \nPJM does not have a capacity shortfall) occurs for three consecutive Delivery Years, then \nthe IRAS program effectively goes to sleep, with any existing BYONC relieved of their \nRPM participation obligations192 and all New Large Loads effectively becoming Large \nLoads.  The New Large Loads become Large Loads because the definition of New Large \nLoad is initially tied to an in-service date of June 1, 2027, or later.193 \nPJM is not proposing an end date to the IRAS program.  Regardless of whether the \nPJM Region has maintained capacity sufficient to meet the PJM Region Reliability \nRequirement for three or more years, PJM will continue to maintain the Large Load \nRegistry.  However, if the region re-enters capacity shortfall conditions, then the need for \nNew Large Loads to provide IRAS will re-emerge.  The definition of New Large Load \nallows for this and explicitly provides that New Large Loads will then be defined as \nentering service “after June 1 of the first Delivery Year” the PJM Region is short of \ncapacity.194   \n \n192 Proposed Tariff, Attachment DD-4, section VIII(f).   \n193 Proposed Tariff, Definitions – New Large Load.   \n194 Proposed Tariff, Definitions – New Large Load.  For example, to the extent PJM meets the regional \ncapacity requirement for Delivery Years 2033/2034, 2034/2035, and 2035/2036, but then enters shortage \nconditions for the 2036/2037 Delivery Year, then New Large Loads must have an in-service date after June 1, \n2036."},{"page":79,"startToken":24907,"endToken":25239,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 73 \n \n \n \n8. \nPJM is not proposing to extend IRAS to New Large Loads located \nin FRR Service Areas. \nA general purpose of IRAS is for New Large Loads to bring new capacity to address \ntheir capacity needs instead of relying on PJM’s capacity market.  Given that FRR Entities \nhave elected to be responsible for providing capacity for all loads in their FRR Service \nAreas, there is no reason to extend IRAS to New Large Loads in FRR Service Areas.  For \nthis reason, as noted above, PJM is proposing that “New Large Loads that are located \nwithin an FRR Service Area cannot be Eligible New Large Loads.”195  While New Large \nLoads in FRR Service Areas may not be eligible for IRAS, they will still fall within the \ndefinition of Large Load and, as such, the LSEs serving such load—or another entity—\nwill need to register such loads in the Large Load Registry. \nHowever, FRR Entities must procure sufficient capacity for all their New Large \nLoads and include such in their FRR Capacity Plans.  And, the PJM Region, as a whole, \ndoes not have excess capacity right now, so the FRR Entity must add new capacity for any \nNew Large Load in its territory.  Given the current levels of existing capacity, PJM is \nproposing a similar “bring your own new capacity” requirement for FRR Service Areas.  \nWhile PJM will not set gating criteria for an FRR Entity’s new capacity to serve New Large \nLoads, PJM is proposing a requirement that “[a]n FRR Entity may not include in its FRR \nCapacity Plan any MW quantity of Existing Generation Capacity Resource in excess of \nwhat such FRR Entity owned or contracted by such FRR Entity prior to June 1, 2027, to \nserve New Large Load” to meet its capacity requirements.196  This rule ensures that FRR \n \n195 Proposed Tariff, Attachment DD-4, section V(a). \n196 See proposed RAA, Schedule 8.1, section D.1.1."},{"page":80,"startToken":25239,"endToken":25550,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 74 \n \n \n \nEntities (or their New Large Loads) bring new capacity to the system to meet the New \nLarge Loads’ resource adequacy needs, and precludes FRR Entities from satisfying load \ngrowth from New Large Loads with existing Capacity Resources that could potentially be \nlured from the RPM Auctions (and further exacerbating the shortage conditions in the \ncapacity market).  The growth of Large Loads is an issue facing the entire PJM Region, \nand new capacity should arrive to serve their needs, regardless of whether the New Large \nLoad is to be located in an FRR Service Area or the region served by RPM.  At the same \ntime, this measured approach provides FRR Entities with the necessary flexibility to \nreplace contracts for capacity from one set of resources with a different set of resources \nthat may be existing so long as the total MW quantity of Existing Generation Capacity \nResource in the FRR Capacity Plan does not exceed the amount that such FRR Entity \nowned or contracted prior to June 1, 2027, to serve New Large Loads. \nD. \nLoad Reduction Under Interim Resource Adequacy Service  \n1. \nInterim Resource Adequacy Service will be needed only to address \npotential capacity emergencies or IROL violations. \nIRAS is a supplemental capacity product through which Eligible New Large Loads \nmay be directed by the Electric Distributor to reduce their load in response to an Interim \nResource Adequacy Service Action called by PJM.  Indeed, proposed Tariff, \nAttachment DD-4, section I(a) accurately describes Interim Resource Adequacy Service as \n“a load reduction service, effective starting with the 2027/2028 Delivery Year, through \nwhich Eligible New Large Loads may be compensated for providing load reductions \nrequested by [PJM] to maintain system reliability for the purpose of supporting the \nintegration of New Large Loads to the PJM Region that are not in arrangements with new"},{"page":81,"startToken":25550,"endToken":25829,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 75 \n \n \n \ncapacity additions to the PJM Region.”  In other words, IRAS is needed to manage the \ncapacity needs of New Large Loads that have not satisfied their capacity needs on their \nown.  \nThus, “[s]tarting with the 2027/2028 Delivery Year, [PJM] may, in accordance with \nthe Manuals, instruct the implementation of an Interim Resource Adequacy Service Action \nprior to calling on Pre-Emergency Load Management Reductions Actions after \ndetermining that available economic real-time supply may not be sufficient to maintain \nreserves to meet applicable Reserve Requirements and/or Interconnection Reliability \nOperating Limits within prescribed limits and prevent cascading outages.”197  In other \nwords, PJM anticipates the need to implement IRAS when (1) it is no longer able to \nmaintain reserves in the RTO or a zone; or (2) there are insufficient resources to keep \nIROLs within defined operating limits in order to prevent instability, uncontrolled \nseparation, or cascading outages that adversely impact the reliability of the interconnection.   \nAs detailed in the proposed Tariff language, PJM may initiate an Interim Resource \nAdequacy Service Action, which is an “Operating Instruction, as defined by NERC,”198 in \naccordance with the procedures and conditions to be detailed in the Manuals, and “prior to \ncalling on Pre-Emergency Load Management Reduction Actions after determining that \navailable economic real-time supply may not be sufficient to maintain reserves to meet \napplicable Reserve Requirements and/or Interconnection Reliability Operating Limits \nwithin prescribed limits and prevent cascading outages.”199  The details as to how and when \n \n197 Proposed Tariff, Attachment DD-4, section I(b). \n198 Proposed Tariff, Definitions – Interim Resource Adequacy Service Action. \n199 Proposed Tariff, Attachment DD-4, section I(b)."},{"page":82,"startToken":25829,"endToken":26112,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 76 \n \n \n \nPJM may call an Interim Resource Adequacy Service Action will be set forth in PJM \nManual 13.200   \nThe affidavit of Mr. Christopher Pilong, Senior Director of Operations Planning for \nPJM, provides an overview of the steps taken by PJM Dispatchers, in accordance with PJM \nManual 13, “to manage, allocate, or alleviate an emergency” in the course of Emergency \nProcedure Advisories, Alerts, Warnings, and Actions.201   \nInterim Resource Adequacy Service may be called on, as necessary, to maintain \nrequired RTO/Zonal Reserves, IROLs within limits, and/or prevent cascading outages if \navailable economic generation is not sufficient.  To implement IRAS Emergency \nProcedures, PJM intends to revise PJM Manual 13 to include IRAS Alerts and IRAS \nActions.  Mr. Pilong further explains, in his affidavit, how Interim Resource Adequacy \nService Alerts and Interim Resource Adequacy Service Actions will be added to the steps \ntaken in the event of an emergency, and thus provide an additional tool that PJM \nDispatchers may use when responding to an emergency.202   \nImportantly, however, while Interim Resource Adequacy Service Alerts and Interim \nResource Adequacy Service Actions will be incorporated into a general sequence of \nescalating Emergency Procedures, Mr. Pilong notes that it remains the case that “PJM \n \n200 CIFP Framework for Service at 4 (“New and/or existing Emergency Procedures (Alerts and Warnings) \nneed to be adjusted as appropriate to provide advanced notice that Interim Resource Adequacy Service may \nneed to be reduced.  This will be documented in [PJM] Manual 13.”). \n201 Affidavit of Mr. Christopher Pilong on Behalf of PJM Interconnection, L.L.C. (Attachment C) ¶ 5 (“Pilong \nAff.”) (quoting PJM Manual 13, section 2.1). \n202 Pilong Aff. ¶¶ 29-55."},{"page":83,"startToken":26112,"endToken":26392,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 77 \n \n \n \nDispatchers ‘have the flexibility to implement emergency procedures in whatever order is \nrequired to ensure system reliability.”203   \nThat said, PJM anticipates that the general sequence of Emergency Procedures will \nbe revised, as follows:  Prior to the Operating Day, PJM may issue Interim Resource \nAdequacy Service Alerts, which would put all Eligible New Large Loads on notice that \nPJM may “request reductions in load in quantities equal to or lesser than each Electric \nDistributor zone/area’s assigned IRAS amounts during the next Operating Day.”204  Interim \nResource Adequacy Service Alerts would be available before and/or concurrently with a \nMax Gen Alert/Load Management Alert.205  Mr. Pilong describes a scenario (Example 1), \nin which PJM operators look ahead to the next Operating Day and determine that it is \nnecessary to issue an Interim Resource Adequacy Service Alert.206  As Mr. Pilong explains, \n“All 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.”207 \nIn real-time, as Mr. Pilong explains, Interim Resource Adequacy Service Actions \nwould become a new step available to PJM Dispatchers, prior to Pre-Emergency Load \nManagement Reductions.208  Mr. Pilong describes a scenario (Example 2) in which PJM \n \n203 Pilong Aff. ¶ 15 (quoting PJM Manual 13, section 2.3) (footnotes omitted). \n204 Pilong Aff. ¶ 31. \n205 Pilong Aff. ¶ 31. \n206 Pilong Aff. ¶¶ 29-34. \n207 Pilong Aff. ¶ 33 (quoting PJM Manual 13, section 2.3.1). \n208 Pilong Aff. ¶ 45."},{"page":84,"startToken":26392,"endToken":26708,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 78 \n \n \n \nDispatchers respond to an RTO-wide emergency in real-time by deploying an Interim \nResource Adequacy Service Action under an EEA1.209   \nAs Mr. Pilong explains, prior to deploying Interim Resource Adequacy Service \nActions, PJM Dispatchers may first “deploy available generation and economic demand \nresources, in economic dispatch order while maintaining required reserves.”210  Second, \nPJM Dispatchers may “require non-firm interchange transaction curtailment, as \nneeded.”211  Third, assuming that “PJM’s new, yet-to-be-effective transmission service \nproducts—Non-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.”212 \nIn accordance with the proposed sequence, “after all non-firm transmission services \nare curtailed” PJM may “then issue the new Interim Resource Adequacy Service Action \nprior to deployment of a Pre-Emergency Load Management Reduction Action.”213  PJM \nintends to communicate Emergency Procedures under IRAS using the status quo \nnotification processes set forth in PJM Manual 13.214  Figure 1, below, demonstrates how \n \n209 Pilong Aff. ¶¶ 35-47. \n210 Pilong Aff. ¶ 36. \n211 Pilong Aff. ¶ 37. \n212 Pilong Aff. ¶ 12 (citing PJM Interconnection, 195 FERC ¶ 61,209 at P 551 (“[W]e find PJM’s proposal \nto curtail Interim NITS and [Non-Firm Contract Demand] transmission service prior to deployment of its \nPre-Emergency Load Response Program, or in response to a transfer capability shortage as a result of system \nreliability conditions, to be just and reasonable because it is consistent with how Non-Firm [Point-to-Point \nService] is curtailed. . . . [W]e find that PJM’s proposal to curtail Interim NITS during capacity or reserve \nshortages is just and reasonable and consistent with both the nature of the transmission service as a non-firm \ntransmission service for which Eligible Customers do not pay generation capacity charges, and the need to \nmaintain reliability.” (footnote omitted))); id. ¶ 39.  \n213 Pilong Aff. ¶ 40. \n214 Pilong Aff. ¶ 41."},{"page":85,"startToken":26708,"endToken":26880,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 79 \n \n \n \nNew Interim Resource Adequacy Service Actions may precede Pre-Emergency Load \nManagement Reductions in an EEA1.   \nFigure 1: PJM Emergency Procedures with Interim Resource Adequacy Service (IRAS) \n \nAs explained in PJM Manual 13, “EEA1 signals that PJM foresees or is experiencing \nconditions where all available resources are scheduled to meet firm load, firm transactions, \nand reserve commitments, and is concerned about sustaining its required Contingency \nReserves.”215  In other words, the region is approaching a capacity event.  Thus, it is \nappropriate for PJM to direct Electric Distributors to reduce those New Large Loads that \nhave failed to cover their capacity obligations before relying on Demand Resources, \nthrough Pre-Emergency Load Management Reductions Actions, to maintain reliability.     \nTo further illustrate how PJM plans to integrate IRAS into its Emergency \nProcedures, PJM prepared Figure 2, which shows how IRAS will affect PJM’s Emergency \nProcedures, relative to the status quo, and when there is an order from the Secretary of \n \n215 PJM Manual 13, section 2.3.1."},{"page":86,"startToken":26880,"endToken":27094,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 80 \n \n \n \nEnergy under FPA section 202(c) authorizing backup generation to run in excess of their \npermits.216 \nFigure 2: Comparison of PJM Emergency Procedures \n  \nAlerts and \nWarnings \nEEA1 \nEEA2 \nLast step \nbefore \nEEA3 \nEEA3 \nToday \n(Status \nquo) \nSchedule \nAll \nAvailable \nResources; \nissue Max \nGen Alert \nPre-Emergency DR \nEmergency \nDR \n \nShed Non-\ncritical load \nwith backup \ngeneration \n(remaining \nload) \nfirm load \nshed \nStatus \nquo \nplus \nDOE \n202c \nOrder \nSchedule \nAll \nAvailable \nResources; \nissue Max \nGen Alert \nPre-Emergency DR \nEmergency \nDR \nEnergency \nUse of \nBack-up \nGenerators \n(pre \n6/1/2027 \nload) \nShed Non-\ncritical load \nwith backup \ngeneration \n(remaining \nload) \nfirm load \nshed \nWith \nIRAS \nSchedule \nAll \nAvailable \nResources; \nissue IRAS \nand/or Max \nGen Alerts \nIRAS Large \nLoad \nreduction \n(post 6/1/27 \nload) without \nBYONC \nPre-\nEmergency \nDR \nEmergency \nDR \nEnergency \nUse of \nBack-up \nGenerators \n(pre \n6/1/2027 \nload) \nShed Non-\ncritical load \nwith backup \ngeneration \n(remaining \nload) \nfirm load \nshed \nFinally, Figures 1 and 2 illustrate that changing the Emergency Procedures \nsequence to call on IRAS after Pre-emergency Load Management would reduce the \nincentive for New Large Loads to bring new capacity to the system, as they would be \ninsulated by the Demand Resource capacity products.  \n \n216 16 U.S.C. § 824a(c)."},{"page":87,"startToken":27094,"endToken":27363,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 81 \n \n \n \n2. \nHow PJM will call an Interim Resource Adequacy Service Action \nUnder the terms of the Operating Agreement and as the Reliability Coordinator, \nTransmission Operator, and Balancing Authority, PJM has the authority and flexibility to \ninitiate Emergency Procedures as it sees fit to maintain the reliability of the PJM Region.  \nIndeed, the Operating Agreement explicitly authorizes PJM to “[c]oordinate the \ncurtailment or shedding of load, or other measures appropriate to alleviate an Emergency, \nin order to preserve reliability in accordance with NERC, or Applicable Regional Entity \nprinciples, guidelines and standards, and to ensure the operation of the PJM Region in \naccordance with Good Utility Practice and this Agreement[,]”217 where an “Emergency” is \ndefined as mean “a condition that requires implementation of emergency procedures as \ndefined in the PJM Manuals.”218   \nTherefore, while the addition of IRAS Emergency Procedures will add to the \nsequence of escalating steps that PJM may take to respond to an emergency and prevent \nManual Load Dump, Mr. Pilong also adds that, as set forth in PJM Manual 13, “the \nrapidness of system events influences the timing and order of actions necessary to maintain \nsystem reliability.  PJM Dispatchers ‘have the flexibility to implement emergency \nprocedures in whatever order is required to ensure system reliability.  Likewise, they have \nthe flexibility to exit emergency procedures in a different order than they were \nimplemented.’”219   \n \n217 Operating Agreement, Schedule 1, section 1.6.2(vii). \n218 Operating Agreement, section 1, Definitions E – F (defining Emergency).   \n219 Pilong Aff. ¶ 15 (quoting PJM Manual 13, section 2.3) (footnotes omitted)."},{"page":88,"startToken":27363,"endToken":27630,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 82 \n \n \n \nThus, while IRAS and Pre-Emergency Load Management Reductions would both \nbe categorized as EEA1 actions, the sequence of actions is such that PJM will generally \ncall on IRAS before Pre-Emergency Load Management Reductions to address an \nEmergency, to the extent the zone/area has any IRAS available.   \nFurthermore, as Mr. Pilong explains in his affidavit, PJM will issue MW load \nreduction directives to “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.  PJM will only direct load reduction of an aggregate MW IRAS within the zone \nor area.”220 \nIn addition, PJM may deploy broader or more targeted IRAS Actions, as needed.  \nIn response to an RTO-wide emergency, for example, as Mr. Pilong explains in Example 2, \n“based on the maximum IRAS amounts assigned to each Electric Distributor zone/area, \nPJM Dispatchers [may] call for some or all Electric Distributors to reduce load across the \nPJM RTO Region in the manner they see fit to address the system conditions.”221   \nBy comparison, in response to a potential Interconnection Reliability Operating \nLimit Violation, as described in Mr. Pilong’s Example 3, the deployment of an Interim \nResource Adequacy Service Action in real-time may be more targeted.  In Mr. Pilong’s \n \n220 Pilong Aff. ¶ 52; see id. ¶¶ 48-55. \n221 Pilong Aff. ¶ 43."},{"page":89,"startToken":27630,"endToken":27923,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 83 \n \n \n \nExample 3, “the Dominion Zone is experiencing a transmission capacity scarcity event \nresulting from a potential IROL violation due to overloading of an IROL facility in West \nVirginia, e.g., AP South.  In response, it makes little sense for PJM Dispatchers to curtail \nnon-firm exports to the West or North of the PJM system.  However, PJM may require \ncurtailment of non-firm exports between PJM and areas to the South that are flowing power \nacross the AP South IROL Reactive Interface to mediate the potential IROL violation.”222  \nTo the extent PJM Dispatchers determine it is necessary to issue an Interim Resource \nAdequacy Service Action in response to the potential IROL violation, it would likely be a \nmore targeted Interim Resource Adequacy Service Action than the pro rata load reductions \nacross multiple Electric Distributor zones/areas issued in Example 2.  As Mr. Pilong \ntestifies, “[i]f load in a particular Electric Distributor zone/area is not negatively impacting \ntransmission flows into the Dominion Zone, load reduction in that zone/area may not have \nany effect on the Dominion Zone.”223   \n3. \nElectric Distributors must follow PJM directives to reduce \nmegawatts of load in response to an Interim Resource Adequacy \nService Action. \nWhen PJM issues an Interim Resource Adequacy Service Action, the applicable \nElectric Distributor will be sent an IRAS reduction MW quantity, which will be based on \nthe IRAS quantity PJM determined for the Delivery Year, as described above in Part II.C.7.  \nThat is, an Interim Resource Adequacy Service Action will not be specific as to which New \nLarge Loads would need to be reduced; rather, it will be based on the aggregate MW of \n \n222 Pilong Aff. ¶¶ 48-55. \n223 Pilong Aff. ¶ 53."},{"page":90,"startToken":27923,"endToken":28349,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 84 \n \n \n \nreduction available from the Eligible New Large Loads in the zone/area.  The entities sent \nsuch directive will be expected, and required, to implement it.  PJM proposes that Interim \nResource Adequacy Service Action be defined as “an Operating Instruction, as defined by \nNERC.”224  As such, Electric Distributors and LSEs would need to follow it:   \n• Given that PJM is the Reliability Coordinator, NERC Reliability Standard \nIRO-001-4 R2 would require compliance with an Interim Resource Adequacy \nService Action, as that standard provides that “[e]ach Transmission Operator, \nBalancing Authority, Generator Operator, and Distribution Provider shall \ncomply with its Reliability Coordinator’s Operating Instructions unless \ncompliance with the Operating Instructions cannot be physically implemented \nor unless such actions would violate safety, equipment, regulatory, or statutory \nrequirements.”225   \n• Similarly, given that PJM is the Transmission Operator, NERC Standard \nTOP-001-6 R1 would require compliance with an Interim Resource Adequacy \nService Action, as that standard, provides that “[e]ach Transmission Operator \nshall act to maintain the reliability of its Transmission Operator Area via its own \nactions or by issuing Operating Instructions,” and R3 requires “[e]ach \nBalancing Authority, Generator Operator, and Distribution Provider shall \ncomply with each Operating Instruction issued by its Transmission Operator(s), \nunless such action cannot be physically implemented.”226 \n• Finally, the Operating Agreement requires all Members and Market \nParticipants, including Electric Distributors subject to unique obligations, to \nfollow PJM Emergency procedures.227 \n \n224 In full, the proposed definition is:  “‘Interim Resource Adequacy Service Action’ shall mean an Operating \nInstruction, as defined by NERC, issued from the Office of the Interconnection to reduce load prior to calling \non Pre-Emergency Load Management Reductions after determining that available economic real-time supply \nmay not be sufficient to maintain reserves to meet applicable Reserve Requirements and/or Interconnection \nReliability Operating Limits within prescribed limits and prevent cascading outages.”  Proposed Tariff, \nDefinitions – Interim Resource Adequacy Service Action. \n225 Standard IRO-001-4 Reliability Coordination - Responsibilities, North American Electric Reliability \nCorporation (June 12, 2025), https://www.nerc.com/globalassets/standards/reliability-standards/iro/iro-001-\n4.pdf [https://perma.cc/72GK-YZG3]. \n226 TOP-001-6 - Transmission Operations, North American Electric Reliability Corporation (June 12, 2025), \nhttps://www.nerc.com/globalassets/standards/reliability-standards/top/top-001-6.pdf \n[https://perma.cc/L3FQ-QBRN]. \n227 See Operating Agreement, section 11.3.1(e) (Members shall “[c]omply with the requirements of the PJM \nManuals and all directives of the Office of the Interconnection to take any action for the purpose of managing, \nalleviating or ending an Emergency.”); Operating Agreement, section 11.3.3(c) (Electric Distributors shall"},{"page":91,"startToken":28349,"endToken":28864,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 85 \n \n \n \nAccordingly, while PJM might not be able to directly reduce the loads of Eligible New \nLarge Loads to the extent they are available to provide IRAS, PJM can direct others to do \nso with a high degree of confidence that such directives will be followed.   \nGiven these requirements, it can be no surprise that today Electric Distributors \nselect, consistent with their state programs, which loads to reduce in response to a PJM \nload reduction directive.  Stated another way, PJM is not looking to change any existing \napproach.  Currently, the manner in which an Electric Distributor reduces load is a function \nof their state-approved contracts and state-approved curtailment and load reduction plans.  \n4. \nThe IRAS load reduction framework is, at its core, a product of \ncooperative federalism that recognizes the significant role of the \nstates in requiring New Large Loads to reduce their load to support \nreliability pursuant to IRAS.  \nThe proposed IRAS framework assigns an Eligible New Large Load Amount, \nwhich is measured in MW, to Electric Distributor zones/areas in a manner that respects the \nbalance of authority between states, the Commission, and PJM.228  The framework \n \n“[m]aintain or arrange for a portion of its connected load to be subject to control by . . . load-shedding devices \nat least equal to the levels established pursuant to the Reliability Assurance Agreement.”); Operating \nAgreement, section 11.3.3(e) (Electric Distributors shall “[s]hed connected load, share Generation Capacity \nResources and take such other coordination actions as may be necessary in accordance with the directions of \nthe Office of the Interconnection in Emergencies.”); Operating Agreement, Schedule 1, section 1.7.4(b) \n(“Market Participants shall undertake all operations in or affecting the PJM Interchange Energy Market and \nthe PJM Region including but not limited to compliance with all Emergency procedures, in accordance with \nthe power and authority of the Office of the Interconnection with respect to the operation of the PJM \nInterchange Energy Market and the PJM Region as established in this Agreement, and as specified in the \nSchedules to this Agreement and the PJM Manuals.”); Operating Agreement, Schedule 1, section 1.7.4(g) \n(“Each Market Participant shall follow the directions of the Office of the Interconnection to take actions to \nprevent, manage, alleviate or end an Emergency in a manner consistent with this Agreement and the \nprocedures of the PJM Region as specified in the PJM Manuals.”); Operating Agreement, Schedule 1, \nsection 1.7.11(a) (“The standards, policies and procedures of the Office of the Interconnection for declaring \nthe existence of an Emergency, including but not limited to a Minimum Generation Emergency, and for \nmanaging, alleviating or ending an Emergency, shall apply to all Members on a non-discriminatory basis.”). \n228 See, e.g., New PJM Cos., 107 FERC ¶ 61,272, at P 22 (2004) (“In the event of a transmission emergency, \nPJM is only responsible for determining the location, quantity, and timing of any curtailment.  PJM is not \nresponsible for determining or directing the manner in which load is to be curtailed during an emergency.”)."},{"page":92,"startToken":28864,"endToken":29184,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 86 \n \n \n \nrecognizes the role that states and/or RERRAs play in integrating New Large Loads and \nmanaging load reductions when necessary.229   \na. \nDuring an Interim Resource Adequacy Event, PJM will \ndirect a MW quantity of load reduction to the relevant \nElectric Distributor zone(s)/area(s).  \nIn a Delivery Year in which IRAS applies, PJM will identify, for each zone/area, \nthe Eligible New Large Load Amounts, i.e., MW quantities that are eligible to be called \nupon to reduce load under IRAS.  Directing an Electric Distributor, rather than a specific \nend-use customer, to reduce a quantity of load is in keeping with PJM’s longstanding \npractice and reflects and respects the allocation of jurisdiction between the federal and state \nlevels.230   \nMore specifically, the Eligible New Large Load Amount assigned to each Electric \nDistributor will be derived from information and BYONC arrangements reported to PJM \nand recorded in the Large Load Registry.  However, should PJM experience system \nconditions that require an Interim Resource Adequacy Service Action during a Delivery \nYear in which IRAS is in effect, PJM will instruct Electric Distributors to reduce load by \na MW quantity equal to or less than the Electric Distributor’s Eligible New Large Load \nAmount for that Delivery Year.  PJM will not direct specific LSEs and/or specific \ncustomers of LSEs—including specific Large Loads—to reduce their load and/or switch \n \n229 See, e.g., 52 Pa. Code § 57.52 (2026) (“Emergency load control and energy conservation by electric \nutilities.”); 20 Va. Admin. Code § 5-300-20 (2026) (“Virginia electric energy emergency conservation \nplan.”).  \n230 See, e.g., New PJM Cos., 107 FERC ¶ 61,272 at P 21 (“When such emergency circumstances arise, PJM \nwill inform the electric distribution company serving load of the quantity and location of load that must be \nshed, and the distributor, which directly serves the affected load, will effectuate the load-shedding.”)."},{"page":93,"startToken":29184,"endToken":29472,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 87 \n \n \n \nto on-site backup resources.  Those decisions would be worked out through revised state \nretail tariffs.  PJM stands ready to assist states in developing those tariffs if they so desire. \nPursuant to the proposed framework, Electric Distributors will be responsible for \n“coordinat[ing] as appropriate, with the relevant state(s) or RERRA(s), individual Load \nServing Entities, and customers served by the Load Serving Entities in its zone/area to \nsupport transparent, effective, and orderly deployment of Interim Resource Adequacy \nService.”231  Thus, under the IRAS framework, the specific retail customers that must \nreduce load consumption or switch to backup resources will be determined by the Electric \nDistributor and relevant LSEs in the zone/area, in coordination with the appropriate state \nand/or RERRA.  Indeed, while PJM has proposed definitions of Large Load, New Large \nLoad, and Eligible New Large Load that may be subject to IRAS, PJM simultaneously \nrecognizes that states may each define “large loads” differently for purposes of their retail \ntariffs, particularly those governing load reduction protocols.  Thus, while PJM will \ndetermine the quantity of MW that load in a zone/area will need to be reduced by to \nmaintain system reliability in the PJM Region, states may determine—under their own \nlaws, policies, and definition of what constitutes “large load”—which resources will be \ncalled on to reduce load.   \nb. \nState efforts to develop load reduction programs reflect a \ncooperative federalism framework that is similar to that \nembedded in PJM’s proposal. \nThe division of authority and responsibility between states and PJM with respect to \nload reduction that is embedded in PJM’s proposed IRAS framework, is also reflected in \n \n231 Proposed Tariff, Attachment DD-4, section III(c)."},{"page":94,"startToken":29472,"endToken":29781,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 88 \n \n \n \nthe ongoing efforts of the VA SCC and DCC, with other interested states, to jointly develop \nmodel state commission tariff language “establishing emergency load reduction programs \ndesigned to protect residential customers during the most severe reliability emergencies \nwhile preserving reliable system operations[,]” by no later than February 1, 2027, prior to \nthe applicability of the IRAS framework.232  According to the VA SCC, the model state \ncommission tariff language would, inter alia: \n(1) Establish retail mechanisms authorizing utilities to curtail designated large \ncommercial and industrial customers, or require the use of available on-site \nbackup generation, once PJM has exhausted all other available reliability \nresources, including demand response, but before implementation of broad \nmanual load shed; [and] \n(2) Define \noperational \nexpectations, \ncustomer \nobligations, \nand \nutility \nimplementation procedures associated with load reduction programs[.]233 \nThe efforts of the VA SCC and DCC recognize the significant role of the states in \ndetermining which “designated large commercial and industrial customers” will be subject \nto load reduction programs, and the operational expectations and customer obligations \nassociated with such programs.  The efforts of the VA SCC and DCC also recognize the \nneed to establish retail mechanisms authorizing utilities to curtail designated large \ncommercial and industrial customers or require the use of available on-site backup \ngeneration.  These mechanisms must allow PJM and utilities sufficient time to avoid the \n \n232 Letter of Chair of Virginia State Corporation Commission, Kelsey Bagot and President and CEO of Data \nCenter Coalition, Josh Levi to Ms. Paula Conboy, Chair of PJM Board of Managers, and Mr. David Mills, \nPresident and CEO of PJM Interconnection, L.L.C., 2 (June 30, 2026), https://www.pjm.com/-\n/media/DotCom/committees-groups/cifp-rbp/2026/20260630/20260630-written-comments---va-scc-and-\ndata-center-coalition.pdf [https://perma.cc/S7C6-C86H] (“VA SCC and DCC Letter”). \n233 VA SCC and DCC Letter at 2."},{"page":95,"startToken":29781,"endToken":30153,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 89 \n \n \n \nstart of manual load shed well before declaration of EEA3.  PJM stands ready to assist in \nthose efforts and other related efforts and engagement. \nc. \nThe division of authority between PJM and the states and/or \nRERRAs is supported by relevant precedent. \nPJM’s proposed revisions are in line with recent Commission precedent.  On \nOctober 23, 2025, the DOE ANOPR, which called on the Commission to consider \n“potential reforms to ensure the timely and orderly interconnection of large loads to the \ntransmission system.”234  The ANOPR further stated that “[e]ven if the large load seeking \nto interconnect to the transmission system is an end-use customer, the [ANOPR] does not \nexert jurisdiction over any retail sales to the large load.”235  The Commission’s subsequent \nOrder Regarding Intent to Act on the ANOPR (Order on DOE ANOPR),236 found, inter \nalia, that large loads present an urgent need for reforms to ensure their timely, orderly, and \nnon-discriminatory connection to the transmission system.237  Nevertheless, “the addition \nof and service to large loads” and the associated rates, terms, and conditions “implicate \nboth federal and state interests.”238  Accordingly, the Commission observed, “resolution of \nissues related to large load additions will require the involvement of both federal and state \n \n234 DOE ANOPR at P 1 (citations omitted). \n235 DOE ANOPR at P 15. \n236 Interconnection of Large Loads to the Interstate Transmission System, 195 FERC ¶ 61,045 (2026) (“Order \non DOE ANOPR”). \n237 Order on DOE ANOPR, 195 FERC ¶ 61,045 at P 2. \n238 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 44; see also December 2025 Show Cause Order, \n193 FERC ¶ 61,217 (Issues pertaining to large loads “implicate both federal and state interests, and their \nresolution will require the involvement of both federal and state actors, including the Commission, state \npublic utility commissions, and other state and local entities.”); PJM Interconnection, 195 FERC ¶ 61,197, \nconcur op. (Commissioner Rosner) at P 2 (“[P]ublic utility commissioners, governors’ offices, and state \nlegislatures are all necessary partners in ensuring that energy infrastructure is built at the pace needed to stay \nahead of demand and keep energy affordable and reliable for PJM customers.”)."},{"page":96,"startToken":30153,"endToken":30569,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 90 \n \n \n \nactors, including the Commission, state public utility commissions, and other state and \nlocal entities.”239  Indeed, as the Commission’s Order on DOE ANOPR points out, in the \nlast several years, the Commission has accepted proposed tariffs and agreements “related \nto large loads connecting to the transmission system . . . while rejecting those that exceeded \nthe Commission’s jurisdiction or failed to reasonably allocate costs.”240  Likewise, an order \nto show cause issued by the Commission on February 20, 2025, on aspects of the \nco-location of large loads held that:  \nstates retain exclusive jurisdiction over the terms of retail sales . . . \nincluding . . . how the costs of the wholesale sale and transmission \nof electricity assigned to a wholesale customer are allocated among \nthat wholesale customer’s retail customers.  Thus, while a State may \nnot conclude in setting retail rates that the FERC-approved \nwholesale rates are unreasonable, it is within a state’s exclusive \njurisdiction to determine how those FERC-approved rates are \ncollected among the relevant retail customers.241   \nAt bottom, “exclusive jurisdiction”242 rests with the states to ensure that the appropriate \nretail customers, i.e., New Large Loads, including data centers—and not residential \n \n239 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 44; see also id. at P 48 (Notably, the Commission \nhas expressly “recognize[d] that states will continue to regulate:  (1) the specific terms of retail sales to large \nload; (2) which entities may make retail sales within their borders; . . . and (3) any siting decisions and \nconstruction associated with the large load project.” (citations omitted)); December 2025 Show Cause Order, \n193 FERC ¶ 61,217 at P 165 (Issues pertaining to large loads “implicate both federal and state interests, and \ntheir resolution will require the involvement of both federal and state actors, including the Commission, state \npublic utility commissions, and other state and local entities.”); PJM Interconnection, 195 FERC ¶ 61,197, \nconcur op. (Commissioner Rosner) at P 1 (“[P]ublic utility commissioners, governors’ offices, and state \nlegislatures are all necessary partners in ensuring that energy infrastructure is built at the pace needed to stay \nahead of demand and keep energy affordable and reliable for PJM customers.”). \n240 Order on DOE ANOPR, 195 FERC ¶ 61,045 at P 2 (footnotes omitted). \n241 PJM Interconnection, L.L.C., 190 FERC ¶ 61,115, at P 68, order directing compliance, December 2025 \nShow Cause Order, 193 FERC ¶ 61,217 (2025). \n242 PJM Interconnection, 190 FERC ¶ 61,115 at P 68 (emphasis added)."},{"page":97,"startToken":30569,"endToken":30839,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 91 \n \n \n \ncustomers or small industrial customers—are reduced when system conditions call for PJM \nto require load reductions according to IRAS.   \nThe division of authority and responsibility between PJM and the PJM states is \nfirmly rooted in the Supreme Court of the United States’ (“Supreme Court”) holding in \nEPSA.243  There, the Supreme Court held that the Commission’s regulation of demand \nresponse “addresses—and addresses only—transactions occurring on the wholesale \nmarket” and takes aim at “enhanc[ing] the wholesale, not retail, electricity market.”244  The \nSupreme Court accordingly held that the Commission’s rules for demand response \nwithstood Electric Power Supply Association’s jurisdictional challenge by respecting the \ndivision of federal/state authority set forth in the FPA.245  Even though the FPA’s drafters \ncould not have anticipated demand response, its regulation was nevertheless consistent \nwith the division of jurisdictional authority contemplated by the FPA—in which the \nCommission, and thereby RTOs/ISOs, retain authority over wholesale transactions, while \nstates regulate retail transactions.246  Likewise, the reforms in this filing address issues that \nthe FPA’s drafters would have certainly considered science fiction—the resource adequacy \nimpacts of New Large Loads, including data centers, driven primarily by exponential \ntechnological advancements in artificial intelligence.   \n \n243 EPSA, 577 U.S. at 260. \n244 EPSA, 577 U.S. at 282, 287. \n245 EPSA, 577 U.S. at 288-91. \n246 See Matthew R. Christiansen, FERC v. EPSA: Functionalism and the Electricity Industry of the Future, \n68 \nStan. \nL. \nRev. \n(Apr. \n2016), \nhttps://www.stanfordlawreview.org/online/ferc-v-epsa/ \n[https://perma.cc/6QRP-KXET] (citing EPSA, 577 U.S. at 265-68)."},{"page":98,"startToken":30839,"endToken":31156,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 92 \n \n \n \nIn this case, PJM may issue directives to Electric Distributors to reduce load by a \ncertain MW quantity during certain, limited emergency conditions.  The Eligible New \nLarge Load Amount attributable to each Electric Distributor zone/area will be guided by \nthe Large Load Registry.  Nevertheless, in recognition of the jurisdictional divide between \nPJM and the states and/or RERRAs, PJM will not direct reductions to specific New Large \nLoads pursuant to IRAS.  Rather, PJM is leaving it to Electric Distributors, in coordination \nwith the appropriate states and/or RERRAs, LSEs, and LSE customers to determine which \nloads should ultimately reduce subject to IRAS.  Thus, the IRAS framework divides \nauthority between PJM and the states in a manner consistent with the FPA’s basic division \nof authority.   \nd. \nThe division of authority preserves the Commission’s FPA \nsections 205 and 206 rights over the IRAS framework.  \nPJM’s approach also finds support in the Commission’s 2025 order accepting \nMidcontinent Independent System Operator, Inc.’s (“MISO”) Revised Expedited Resource \nAddition Study (“ERAS”) Proposal.247  In the ERAS order, the Commission found that \nRERRA participation in the ERAS process was permissible and not an improper delegation \nof federal authority to the states, as the participation of RERRA:  \nwould be wholly pursuant to a Commission-jurisdictional \nprocess . . . proposed by MISO and approved by the Commission—\nnot by state authorities—and under which a [Generator \nInterconnection Procedure] is on file with the Commission and any \nfuture revisions would be subject to Commission approval.  Further, \nthe ERAS process would remain subject to the Commission’s \nauthority pursuant to FPA sections 205 and 206.  In contrast, in \nTalen, the Maryland Commission established a state program that \n \n247 Midcontinent Indep. Sys. Operator, Inc., Revisions to the Open Access Transmission, Energy and \nOperating Reserve Tariff Expedited Resource Addition Study Filing of Midcontinent Independent System \nOperator, Inc., Docket No. ER25-2454-000 (June 6, 2025)."},{"page":99,"startToken":31156,"endToken":31491,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 93 \n \n \n \noperated outside a Commission-jurisdictional process and \n“interfered” with the Commission’s authority to establish interstate \nwholesale rates.248 \nSimilarly, PJM’s Tariff states that PJM will identify the MW quantity in a zone/area \nthat will be eligible for load reduction under IRAS, but expressly places the responsibility \non Electric Distributors to coordinate with relevant states and/or RERRAs, as well as LSEs \nand LSE customers, including Large Loads, to determine which retail customers will \nrespond to PJM’s directive to reduce load.249  If approved by the Commission, the division \nof responsibility reflected in the Tariff would be on file and remain subject to the \nCommission’s authority pursuant to FPA sections 205 and 206.   \nAs the Commission has previously observed, PJM’s resource adequacy framework \nrequires that the Commission “recognize the traditional role of state and local entities in \nregulating resource adequacy” while also remaining “aware of [its] responsibilities under \nthe FPA to ensure that adequate service is provided, and that wholesale rates are just and \nreasonable.”250  Thus, the Commission found that the appropriate course of action has been \nto “defer to state and local entities’ decisions when possible on resource adequacy matters, \nbut in doing so . . . not shirk our congressionally-mandated responsibilities.”251  The \ndivision of responsibilities embedded in the proposed IRAS framework is a balanced \n \n248 Midcontinent Indep. Sys. Operator, Inc., 192 FERC ¶ 61,064, at P 99 (2025) (distinguishing Hughes v. \nTalen Energy Mktg., LLC, 578 U.S. 150, 163 (2016)), order addressing arguments raised on reh’g, 194 \nFERC ¶ 61,050 (2026).  \n249 Proposed Tariff, Attachment DD-4, section III(c). \n250 PJM Interconnection, L.L.C., 119 FERC ¶ 61,318, at P 40 (2007) (requiring PJM to “allocate costs to data \ncenters” in a manner similar to that as urged in the NEDC/PJM Governors’ Principles at 1), aff’d sub nom. \nPub. Serv. Elec. & Gas Co. v. FERC, 324 F.App’x 1 (D.C. Cir. 2009). \n251 PJM Interconnection, 119 FERC ¶ 61,318 at P 40."},{"page":100,"startToken":31491,"endToken":31772,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 94 \n \n \n \napproach that reflects the well-considered divide between PJM and state/RERRA \nauthorities over load reduction programs. \n5. \nReducing New Large Loads before Pre-Emergency Load \nManagement Reductions (EEA1) is not unduly discriminatory or \npreferential. \nThe IRAS framework strikes a straightforward bargain.  In Delivery Years when \nthe influx of Eligible New Large Loads gives rise to a PJM Region-wide Reliability \nRequirement shortfall, New Large Loads without arrangements with new capacity will \nnevertheless be permitted to interconnect, and thus achieve “speed to power,” on the \ncondition that their MW quantity of load is counted toward the MW potentially reduced \nduring certain emergency conditions pursuant to IRAS.  These Eligible New Large Load \ncustomers will be compensated under the IRAS framework to the extent that they reduce \nload pursuant to IRAS and do not waive compensation.  The bargain is limited in scope \nand applies only to Eligible New Large Loads in years where their addition to the PJM \nsystem gives rise to an observed shortfall.252  The LSEs serving these Eligible New Large \nLoad customers, which receive NITS, will—like other NITS customers—have their \ntransmission service curtailed after non-firm customers, but they may be asked to reduce \nload prior to other NITS customers in accordance with the Interim Resource Adequacy \nService they may be asked to provide.  At bottom, the IRAS framework recognizes that \nNew Large Loads are not similarly situated to other loads, and reducing New Large Loads \nbefore Pre-Emergency Load Management Reductions (EEA1) is not unduly discriminatory \nor preferential.  To that end, Members of Congress have expressed to PJM that “[i]t is not \n \n252 Proposed Tariff, Attachment DD-4, sections IV(b)(i)-(ii)."},{"page":101,"startToken":31772,"endToken":32122,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 95 \n \n \n \nunduly discriminatory to identify and manage demand from new data centers given their \nincomparably large energy demands, how quickly data centers can come online, and their \nunique potential to impact the reliability of the electric grid as a collective class and to \nincrease rates for all other customers.”253   \na. \nNew Large Loads are not similarly situated to other loads in \nthe PJM Region, constitute a separate, new class of load, and \nare therefore appropriately subject to different treatment. \nRequiring New Large Loads to reduce load before other NITS customers is not \nunduly discriminatory or preferential.  In accordance with longstanding precedent, \n“[w]hether a rate or practice is unduly discriminatory depends on whether it provides \ndifferent treatment to different classes of entities and turns on whether those classes of \nentities are similarly situated.”254  When differences in treatment “can be explained by \nsome factor deemed acceptable to regulators (and the courts)”255 or “are predicated upon \nfactual differences between customers,”256 they are justified and therefore not unduly \ndiscriminatory nor preferential.   \n \n253 Letter from the Members of Congress to David E. Mills, PJM Board Chair, PJM Interconnection, L.L.C., \n4 \n(Nov. \n5, \n2025), \nhttps://www.pjm.com/-/media/DotCom/about-pjm/who-we-are/public-\ndisclosures/2025/20251106-congressional-letter-re-cifp-lla.pdf [https://perma.cc/ZKA9-Q5LZ]. \n254 Calpine Corp. v. PJM Interconnection, L.L.C., 171 FERC ¶ 61,035, at P 318, order on compliance, \ngranting waiver request, addressing arguments raised on reh’g & setting aside prior order, in part, 173 \nFERC ¶ 61,0061 (2020), order on compliance & clarification, 174 FERC ¶ 61,036, order setting aside prior \norder, in part, 174 FERC ¶ 61,109 (2021). \n255 Town of Norwood v. FERC, 202 F.3d 392, 402 (1st Cir. 2000) (“[D]ifferential treatment does not \nnecessarily amount to undue preference where the difference in treatment can be explained by some factor \ndeemed acceptable by the regulators (and the courts).” (citation omitted)). \n256 Newark v. FERC, 763 F.2d 533, 546 (3d Cir. 1985) (“[D]ifferences in rates are justified where they are \npredicated upon factual differences between customers.”)."},{"page":102,"startToken":32122,"endToken":32474,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 96 \n \n \n \nNew Large Loads are not similarly situated to other loads in the PJM Region.  \nAccording to the Commission, large loads constitute “a separate category of load.”257  In \nthis case, the Commission has justified the differential treatment of New Large Loads, \nwhich is predicated on factual differences between customers.  In fact, in recognition of \nthis distinction, the Commission has required all RTOs/ISOs, including PJM, to define the \nterm “large load” in their respective tariffs.258   \nIn support of large loads being treated as a separate category of load, the \nCommission has highlighted the uniqueness of large loads, noting specifically that their \nintegration “poses specific challenges to transmission system operation given their size, \noperational behavior, and unique potential to impact the transmission system.”259  \nFurthermore, the Commission has found that the records in the recent proceedings \ninvolving large loads “illustrate a host of urgent challenges associated with providing the \ntransmission service needed to serve the ongoing influx of large loads while maintaining \nreliability and affordability.  In particular, stakeholders have expressed concerns that large \nloads are not efficiently and appropriately integrated onto the transmission system; have \nidentified a number of unique challenges that large load integration poses for the reliable \noperation of that system; and have debated how best to ensure that the rates, terms, and \nconditions of transmission service remain just and reasonable as more and more large loads \n \n257 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 50; FPA section 215, 16 U.S.C. § 824o. \n258 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58; Midcontinent Indep. Sys. Operator, Inc., \n195 FERC ¶ 61,212, at P 58 (2026); Sw. Power Pool, 195 FERC ¶ 61,213 at P 15 & n.54; Cal. Indep. Sys. \nOperator Corp.,195 FERC ¶ 61,214, at P 57 (2026); ISO New Eng. Inc., 195 FERC ¶ 61,215, at P 56 (2026); \nN.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,216, at P 64 (2026).   \n259 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 58."},{"page":103,"startToken":32474,"endToken":32780,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 97 \n \n \n \nare onboarded onto that system.”260  Recently, the Commission, in finding SPP’s CHILLS \nproposal for new large loads just and reasonable and not unduly discriminatory or \npreferential, the Commission observed that “SPP has shown that unprecedented growth in \nlarge loads in the SPP region presents significant and unique operational and planning \nchallenges.”261  Likewise, in the last two Delivery Years, since the influx of new large \nloads, consisting primarily of data centers, PJM has cleared short of its PJM Region \nReliability Requirement in the face of exponential load growth.  Challenges that are driven \nby the rapid addition of New Large Loads in PJM have called for PJM to respond \naccordingly with the slate of initiatives discussed above in Part I.C.   \nb. \nIRAS is only applicable in Delivery Years when New Large \nLoads without arrangements with new capacity give rise to \na PJM Region Reliability Requirement shortfall and \nprovides opportunities for New Large Loads to avoid being \nsubject to load reduction under IRAS. \nThe applicability of IRAS is limited and narrowly tailored.  Where the Commission \nhas found the treatment of large loads to be “tailored to the specific and unique nature of” \nof large loads, and “narrowly tailored to reflect the . . . unique characteristics” of such \nloads, the Commission has found that treatment just and reasonable and not unduly \ndiscriminatory or preferential.262   \nFirst, IRAS is limited to years in which the PJM Region experiences a resource \nadequacy shortfall.  IRAS will only apply in Delivery Years where the amount of \ncommitted Capacity Resources is less than the Updated PJM Region Reliability \n \n260 June 2026 Order to Show Cause, 195 FERC ¶ 61,211 at P 1. \n261 Sw. Power Pool, 195 FERC ¶ 61,196 at P 84. \n262 Sw. Power Pool, 195 FERC ¶ 61,196 at PP 85, 87."},{"page":104,"startToken":32780,"endToken":33062,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 98 \n \n \n \nRequirement.  Thus, it is only applicable when New Large Loads that have not brought \ntheir own capacity and have not been allocated sufficient RBP UCAP MW cause a PJM \nRegion Reliability Requirement shortfall.   \nSecond, New Large Loads may significantly mitigate the possibility of being called \non to reduce load pursuant to IRAS by, for example, entering into arrangements with new \ncapacity and working with their states to craft retail curtailment tariffs that may minimize \ndisruption to data centers while protecting remaining native load.263  Thus, New Large \nLoads have the flexibility to engage in self-sufficiency to avoid or, at least, reduce the \npossibility of being called on to reduce load during an Interim Resource Adequacy Service \nAction.   \nThird, IRAS was developed to address the specific and unique issues caused by \nNew Large Loads in the PJM Region, while also enabling New Large Loads to nevertheless \nbe served by PJM.  \nFourth, while PJM uses the Large Load Registry at the outset to establish Eligible \nNew Large Load Amounts attributable to each zone/area in the PJM Region for each \nDelivery Year, PJM’s reliance on the actual identities of those New Large Loads stops \nthere.  In other words, once PJM has determined, for the Delivery Year and based on the \nLarge Load Registry, the MW quantity of resource adequacy shortfall in each zone/area \nbased on New Large Loads in each zone/area that have not entered into arrangements with \nnew capacity, PJM’s operational directives will direct load reduction of certain MW \nquantities in certain zones/areas, not specific New Large Loads in those zones/areas. \n \n263 See VA SCC and DCC Letter at 2."},{"page":105,"startToken":33062,"endToken":33458,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 99 \n \n \n \nDuring real-time operations, PJM will direct Electric Distributors to reduce MW \nquantities of load in specific zones/areas under pre-emergency and emergency conditions, \nPJM will not direct specific New Large Loads to be reduced—albeit, states may, of course, \nestablish and enforce their own retail load reduction programs.  The IRAS framework does \nnot single out New Large Loads for reduction because they are new or large.  Rather, IRAS \nis focused on the reliability shortfall that is the result of the influx of these New Large \nLoads.  IRAS is furthermore focused on responding accordingly with appropriate load \nreductions in the zones/areas with load to reduce.  Under conditions of tightening supply \nand demand, it is a measured and well-considered response to permit the new demand \ncausing the shortfall on the system to interconnect, subject to load reduction under limited \nemergency conditions, but receive compensation for that load reduction.264  While the \nIRAS framework gives rise to differences in the treatment of New Large Loads and other \nloads, the difference is meaningfully grounded in the fact that the current rapid growth in \nLarge Loads are fundamentally different from the historical load growth, in both their \ninherent concentration of demand and the rapidity at which their cumulative demands have \ngrown throughout PJM.  These two factors are the cause of the recent reliability shortfall.265  \n \n264 See, e.g., Tenaska Clear Creek Wind, LLC v. Sw. Power Pool, Inc., 183 FERC ¶ 61,043, at P 24 (2023) \n(finding that an “interconnection customer is differently situated from interconnection customers that have \nnot caused the need for the network upgrades.  This difference may justify that interconnection customer’s \ngenerating facility being subject to curtailment if it operates the generating facility prior to completion of the \nnetwork upgrades when another is not so situated.  Subjecting the interconnection customer that causes the \nneed for upgrades in this manner ensures that the interconnection customer, bears the system-reliability \nburdens that flow from its decision to operate prior to completion of the required network upgrades.” \n(footnote omitted)). \n265 See Independent Market Monitor for PJM, Analysis of the 2027/2028 RPM Base Residual Auction Part \nA, \nMonitoring \nAnalytics, \n2-3 \n(Jan. \n5, \n2026), \nhttps://www.monitoringanalytics.com/reports/Reports/2026/IMM_Analysis_of_the_20272028_RPM_Base\n_Residual_Auction_Part_A_20260105.pdf [https://perma.cc/SM2E-KMTW] (“The capacity shortfall in"},{"page":106,"startToken":33458,"endToken":33816,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 100 \n \n \n \nAs such and, if they do not build, buy, or bring their own capacity, should be reduced, \naccordingly, should emergency conditions require it.  Thus, the IRAS framework is not \nmotivated by any desire to single out New Large Loads for reduction because of their size \nor vintage, but rather for the valid and legitimate reason that New Large Loads have led to \nperiods of insufficient resource adequacy and should, justifiably, play a significant role in \nthe remedy.266 \nc. \nLoad reduction under Interim Resource Adequacy Service \nappropriately treats New Large Loads as NITS customers. \n \nLSEs, which take service under NITS, serve their Eligible New Large Load \ncustomers.  In the event of an Emergency Procedure IRAS Service Alert, Warning, and \nAction, the LSEs serving Eligible New Large Load customers—like other NITS customers \nin PJM—will only be called on to reduce load after non-firm transmission service products.  \nAs described above in Figure 2, PJM intends to amend its Manuals to include a new \ncategory of Emergency Procedure, in which PJM may require that a load reduction up to \nthe quantity of Eligible New Large Load (Potential EEA1) in a zone/area before calling for \nPre-Emergency Load Management Reductions (EEA1).     \n \nboth the 2026/2027 and the 2027/2028 BRAs was a result of new data center load and forecast increases in \nexisting data center load and the already existing demand from large data centers.”). \n266 See, e.g., PJM Interconnection, L.L.C., 167 FERC ¶ 61,114, at P 28 (2019) (finding that limiting \nparticipation in Peak Shaving Adjustment Program to resources governed by tariff or adopted by a RERRA \nnot unduly discriminatory “because [Electric Distribution Companies (“EDCs”)] with RERRA-sponsored \nload curtailment programs are not similarly situated to EDCs without RERRA-sponsored load curtailment \nprograms. . . . PJM has sufficiently demonstrated that the RERRA-sponsorship requirement is just and \nreasonable because it provides PJM with greater confidence in the durability of the peak-shaving program, \nas load reductions provided by RERRA-sponsored resources are more likely to continue over time, creating \nstability in load forecasts, which in turn will ensure efficient transmission planning and resource \ninvestment.”)."},{"page":107,"startToken":33816,"endToken":34107,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 101 \n \n \n \nPJM Manual 13 already requires resource types taking NITS to prevent a Manual \nLoad Dump (at EEA3) by reducing load in a sequential order.  Today, for example, sites \nregistered in the PJM demand response program as a Demand Resource may be called on \nto reduce load in Pre-Emergency and Emergency Load Management Reduction Actions \nbefore firm exports are reduced in a Maximum Generation Emergency (EEA2).  Nor is \nsequential load reduction or dispatch unique to PJM.267  As part of IRAS, PJM is simply \nproposing to add another category of resources that would precede the Demand Resources \nand DER Capacity Aggregation Resources called on to reduce load in Pre-Emergency and \nEmergency Load Management Reduction Actions.    \nE. \nCompensation for Load Reduction Under Interim Resource Adequacy \nService \n1. \nThe proposed IRAS compensation approach respects and reflects \nthe federal and state division of authority and responsibilities. \n \nAs part of the proposed IRAS framework, Electric Distributors bear the \nresponsibility to implement the compensation scheme for New Large Loads that provide \nthe IRAS load reduction service.  A representative class of these New Large Loads are \nsignatories to the Ratepayer Protection Pledge that committed to “[c]ontribut[e] to \n[e]lectric and [c]ommunity [r]esilience” by “coordinat[ing] with grid operators to \ncontribute to a more reliable grid.”268  IRAS reflects such coordination at a just and \nreasonable rate.   \n \n267 Voltus, Inc., 190 FERC ¶ 61,008, at P 17 (2025) (noting that in MISO, “[Emergency Demand Resources] \nare dispatched after [Load Modifying Resources] in times of more acute need”). \n268 Ratepayer Protection Pledge; July 2026 Ratepayer Protection Pledge Update (identifying 282 utilities, \ncooperatives, data centers, and 23 governors that joined the Ratepayer Protection Pledge, including 38 data \ncenters)."},{"page":108,"startToken":34107,"endToken":34457,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 102 \n \n \n \n \nPJM is proposing a rate for IRAS that is equal to 50% of the Non-Performance \nCharge Rate.  However, the wholesale IRAS rate is flexible and can be further reduced to  \nless than 50% of the Non-Performance Charge Rate if the Eligible New Large Load accepts \nin its retail rate a sum less than 50% of the Non-Performance Charge Rate.  As discussed \nbelow, PJM’s proposal provides Electrical Distributors and states flexibility in the \napplicable IRAS rate for its territory, and affords the New Large Load the ability to waive \ncompensation.  Indeed, a rate of zero dollars for IRAS would apply where Eligible New \nLarge Loads waive in their retail rates receipt of compensation for the provision of \nwholesale Interim Resource Adequacy Service—an outcome that would be consistent with \nthe Ratepayer Protection Pledge signatories’ commitment “to protect American consumers \nfrom price hikes due to data center energy and infrastructure requirements, and lower \nelectricity costs for consumers in the long term.”269   \na. \nThe proposed IRAS rate is just and reasonable. \nPJM proposes to extend the rate applicable for Pre-Emergency Load Response non-\nperformance (and conversely for bonus payments)—50% of the Non-Performance Charge \nRate—as the maximum rate for IRAS performance.270  The Commission recently accepted \nthis rate.271  In that proceeding, PJM explained that the rate is appropriate for non-\nperformance or under-performance by Pre-Emergency Load Response Program \n \n269 Ratepayer Protection Pledge. \n270 See proposed Tariff, Attachment DD-4, section X(a) (“The rate for the provision of Interim Resource \nAdequacy Service shall be 50% of the Non-Performance Charge Rate specified in Tariff, Attachment DD, \nsection 10A(e), unless any Eligible New Large Load elects to (i) accept in its retail rates a sum less than 50% \nof the Non-Performance Charge Rate as compensation for the provision of wholesale Interim Resource \nAdequacy Service, or (ii) waive receipt in its retail rates any compensation for the provision of wholesale \nInterim Resource Adequacy Service as contemplated by Tariff, Attachment DD-4, section X(c).”).  \n271 PJM Interconnection, L.L.C., 195 FERC ¶ 61,253 (2026)."},{"page":109,"startToken":34457,"endToken":34794,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 103 \n \n \n \nParticipants as it reflects that the PJM system is at an earlier stage of emergency conditions, \nso the system conditions are not as severe, so the value of the load reduction, while still \nsubstantial, is also not as high as during a Performance Assessment Interval.272  From a \ncustomer perspective, the non-performance rate appropriately reflects that load paid for \ncapacity but did not get the benefit of the Pre-Emergency Load Response Program that \nPJM called upon at a time when the PJM system was in stressed system conditions.273  The \nmonies collected in this instance were, generally speaking, allocated to demand resources \nthat overperformed during such events (i.e., bonus payments), if applicable, with residual \nmonies collected in certain situations reverting to LSEs that did not get the benefit of the \nload response service for which they paid.274   \nThis recently accepted rate is a just and reasonable analog for the wholesale rate \nPJM proposes here for IRAS.  As Mr. Pilong explains, IRAS would be called at the \nemergency conditions similar to when Pre-Emergency Load Response is called today.275  \nIndeed, Mr. Pilong explains that IRAS load reductions would now be introduced just before \nthe Pre-Emergency Load Reduction Actions.276  Thus, similar to the Pre-Emergency Load \nResponse Program, IRAS load is reduced at an earlier stage of emergency conditions and \nthe 50% reduction on the Non-Performance Charge Rate also reflects that the current \n \n272 PJM Interconnection, L.L.C., Proposal to Enhance Performance of Load Management Resources and \nPrice Responsive Demand Providers During Non-Performance Assessment Interval Events of PJM \nInterconnection, L.L.C., Docket No. ER26-2319-000, Transmittal Letter at 11 (Apr. 27, 2026). \n273 PJM Interconnection, L.L.C., 195 FERC ¶ 61,253. \n274 See PJM Interconnection, Proposal to Enhance Performance of Load Management Resources and Price \nResponsive Demand Providers During Non-Performance Assessment Interval Events of PJM \nInterconnection, L.L.C., Docket No. ER26-2319-000, Transmittal Letter at 17. \n275 See Pilong Aff. ¶ 26. \n276 See Pilong Aff. ¶ 26."},{"page":110,"startToken":34794,"endToken":35104,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 104 \n \n \n \nTariff-stated value of load reductions at these system conditions, i.e., where there is not \nsufficient available economic real-time supply “to maintain reserves to meet applicable \nReserve Requirements and/or Interconnection Reliability Operating Limits within \nprescribed limits and prevent cascading outages.”277     \nb. \nElectric Distributors bear the responsibility, in conjunction \nwith applicable state authorities and New Large Loads, to \nimplement the compensation scheme. \nThe IRAS rate is compensation for a wholesale load reduction service, but the \nentities to be paid the rate and the loads to be charged to support such compensation must \nbe determined at the state level consistent with the Electric Distributor’s state-approved \nload reduction plans and other state-approved programs, rates, and rules.  As such, the \nIRAS rate is intended to be conjoined with retail rates and ultimately paid to Eligible New \nLarge Loads that reflects a discount on capacity costs commensurate with the impact of \nInterim Resource Adequacy Service on addressing resource adequacy issues.  The net \nresult is a reduced capacity charge for Eligible New Lage Loads, and thus a “practice . . . \nin which operators of wholesale markets pay electricity consumers for commitments not to \nuse power at certain times” and thus “directly” affects wholesale capacity rates assessed.278   \nThis compensation for load reduction under IRAS is not unduly discriminatory or \npreferential.  As the Commission has recognized in recent landmark decisions (and as \nfurther discussed above), New Large Loads are a separate, unique class of load.279  PJM’s \n \n277 Proposed Tariff, Attachment DD-4, section I(b). \n278 See EPSA, 577 U.S. at 261, 265.   \n279 See, e.g., June 2026 Order to Show Cause, 195 FERC ¶ 61,211; December 2025 Show Cause Order, 193 \nFERC ¶ 61,217; Sw. Power Pool, 195 FERC ¶ 61,213; Sw. Power Pool, 195 FERC ¶ 61,196; Sw. Power \nPool, 194 FERC ¶ 61,031."},{"page":111,"startToken":35104,"endToken":35478,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 105 \n \n \n \nIRAS framework advances the Commission’s policy set forth in those orders that the \nRTO/ISO tariff should be modified to support the integration of this class of load to the \nPJM Region.  As a term of interconnection, for loads that have not brought their own \ncapacity and cause unprecedented strain on the system, PJM is facilitating their \ninterconnection subject to IRAS.  New Large Loads may achieve the “speed to power” they \ndesire and interconnect to the transmission system, but must either bring their own capacity \nor provide IRAS—a service for which there will be a compensation mechanism.  In sum, \nNew Large Loads are eligible to take this new service at a just and reasonable rate to the \nextent they elect to interconnect without BYONC to meet their resource adequacy needs.  \nAlternatively, the proposal does not foreclose Eligible New Large Loads from foregoing \nany available wholesale IRAS compensation through appropriate engagement with Electric \nDistributors.280  This engagement would occur at the state level.281  In these cases where \nIRAS credits in the retail rates are waived, the wholesale IRAS rate will be reduced to zero \ndollars, as allowed under the proposed language.282  This is a just and reasonable rate.  And \nimportantly, including a zero-dollar rate aspect of the proposal is consistent with the \nRatepayer Protection Pledge’s tenet that New Large Loads “will voluntarily negotiate new, \nseparate rate structures with their utilities and relevant State governments wherever they \n \n280 See proposed Tariff, Attachment DD-4, section X(a) (“If any Eligible New Large Load so elects to accept \nless than 50% of the Non-Performance Charge Rate or waives in its entirety receipt of compensation for the \nprovision of wholesale Interim Resource Adequacy Service, the wholesale rate for the provision of Interim \nResource Adequacy Service shall reflect the accepted sum less than 50% of the Non-Performance Charge \nRate or if compensation is waived entirely, the rate shall be zero dollars.”). \n281 PJM understands that in traditional, non-restructured states, the Electric Distributor also doubles as the \nLSE for the New Large Load, while in restructured states, the LSE may be an independent entity, not \naffiliated with the Electric Distributor. \n282 See proposed Tariff, Attachment DD-4, section X(a)."},{"page":112,"startToken":35478,"endToken":35784,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 106 \n \n \n \nbuild data centers.  Importantly, they will pay these rates for the power and related \ninfrastructure that are brought online to service their data centers, whether they use the \nelectricity or not. . . . This will protect the American people from increased utility bills as \na result of the development of these data centers.”283  PJM’s proposal also allows Eligible \nNew Large Loads to agree upon a retail rate between 50% of the Non-Performance Charge \nRate and zero dollars, to further facilitate implementation of the Ratepayer Protection \nPledge and retail level arrangements.284   \nUnder PJM’s proposal, how this wholesale rate is used to compensate for IRAS and \nhow it is used to collect monies for such compensation will be left to the Electric \nDistributors that directed the specific load reductions to implement IRAS, consistent with \ntheir state-approved program, and that can identify the beneficiaries in their zone/area of \nsuch load reduction.  In this way, how the compensation scheme will work in practice relies \non application of state retail law.285  Whether a specific New Large Load may be entitled \nto compensation for provision of IRAS will be determined by state authorities under state \nlaw or RERRA as may be applicable.  The program will be administered by the Electric \nDistributor in coordination with the relevant state authorities or RERRA.  That said, PJM’s \nproposal imposes no obligation on any state to do anything.  States are free to design retail \nrate regimes that facilitate the recovery and allocation of wholesale IRAS rates through \ngenerally applicable retail rate tariffs.  Alternatively, if states decline to act generically, \nthey could negotiate specific retail filed rates with affected entities.  Further still, if states \n \n283 Ratepayer Protection Pledge. \n284 See proposed Tariff, Attachment DD-4, section X(a). \n285 See proposed Tariff, Attachment DD-4, section X(b)(i)."},{"page":113,"startToken":35784,"endToken":36121,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 107 \n \n \n \ndecline to act, Eligible New Large Loads could initiate regulatory proceedings to develop \nretail pathways to recover wholesale IRAS rates.  Or, if states decline to act and Eligible \nNew Large Loads decline to initiate regulatory proceedings to recover through retail rates \nthe wholesale IRAS rate, they would effectively waive a right to compensation.286  Under \nPJM’s proposal, the wholesale rate can flow into retail rates outside the PJM settlements \nrealm.287  Alternatively, Electric Distributors, in consultation with their state regulators, \ncan request PJM’s support in implementing payment of the wholesale rate to Eligible New \nLarge Loads and/or collection of charges to fund such compensation.288  Other potential \nflexibility might exist.  The key takeaway is that PJM is not mandating any action at the \nretail or state level.   \nIn sum, PJM’s proposal imposes responsibilities on individual entities, and not the \nstates themselves.  While it enlists and invites state action through their jurisdictional retail \nprocesses, it does not mandate any state-specific action, nor does it require any specific \nterms and conditions on retail service.  PJM’s proposed federal filed rate facilitates and \nrespects the handoff of responsibilities between federal wholesale rate development and \nstate retail rate implementation.  PJM’s proposed framework avoids the potential for \nconflicts with state policy determinations and jurisdictional domains.  PJM’s proposal \nadvances a framework that is consistent with the Commission’s decision in the demand \n \n286 Indeed, PJM is proposing to include in the compensation rules the following proviso: “Nothing in this \nTariff, Attachment DD-4, section X shall interfere with any Eligible New Large Load’s election to (i) accept \nin its retail rates a sum less than 50% of the Non-Performance Charge Rate as compensation for the provision \nof wholesale Interim Resource Adequacy Service, or (ii) waive receipt in its retail rates any compensation \nfor the provision of wholesale Interim Resource Adequacy Service.”  Proposed Tariff, Attachment DD-4, \nsection X(c).   \n287 Proposed Tariff, Attachment DD-4, section X(b)(i).   \n288 Proposed Tariff, Attachment DD-4, section X(b)(ii)."},{"page":114,"startToken":36121,"endToken":36491,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 108 \n \n \n \nresponse context to respect state law choices about whether and how to facilitate \nimplementation of a wholesale paradigm, even one that indirectly affects retail rates when \nthe wholesale rate flows back into retail rate structures.289  As in the demand response \ncontext, PJM’s proposed framework promotes durability and encourages federal-state \ncommunication and partnership without “plac[ing] an undue burden on state and local retail \nregulatory entities, or . . . rais[ing] new concerns regarding federal and state \njurisdiction.”290 \n2. \nThe proposed billing indemnification language is just and \nreasonable. \nPJM is also proposing indemnification language as part of this compensation \nframework to make clear that neither PJM nor the PJM membership, generally, is \nfinancially responsible for any potential defaults that may arise in association with the \nbilling of this compensation.291  Thus, if a state-approved rate requires collection of the \ncompensation for interruption under an IRAS Event from other LSEs, for example, and a \nLSE does not pay as required (whether billed directly by the Electric Distributor or by PJM \nupon request of the Electric Distributor), the default will not pass to the PJM membership. \nIn the event the Electric Distributor requests that PJM facilitates the billing for an IRAS \n \n289 Wholesale Competition in Regions with Organized Electric Markets, Order No. 719, 125 FERC ¶ 61,071, \nat P 154 (2008) (requiring “RTOs and ISOs to amend their market rules as necessary to permit an [aggregator \nof retail customers] to bid demand response on behalf of retail customers directly into the RTO's or ISO's \norganized markets, unless the laws or regulations of the relevant electric retail regulatory authority do not \npermit a retail customer to participate”); Order No. 719-B, 129 FERC ¶ 61,252 at P 5 (requiring “RTOs and \nISOs to amend their market rules as necessary to permit an aggregator of retail customers (ARC) to bid \ndemand response on behalf of retail customers directly into the RTO’s or ISO’s organized wholesale markets, \nunless the laws or regulations of the relevant electric retail regulatory authority do not permit a retail customer \nto participate”). \n290 Order No. 719, 128 FERC ¶ 61,059 at P 155.   \n291 See proposed Tariff, Attachment DD-4, section X(b)(iii)."},{"page":115,"startToken":36491,"endToken":36831,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 109 \n \n \n \nEvent, such billing will be viewed as a bilateral transaction between the Electric Distributor \nand the other party and any default shall be assessed to the Electric Distributor.  This \nlanguage is just and reasonable because it minimizes risk to PJM and its members, and is \nconsistent with other similar language the Commission has accepted in other parts of PJM’s \nGoverning Agreements.292 \nF. \nConsistent with the Ratepayer Protection Pledge, PJM Is Proposing to \nExclude New Large Loads from the VRR Curve Until They Bring New \nCapacity.  \nPJM is proposing that, beginning with the 2029/2030 Delivery Year, PJM will \nexclude from the demand curve (i.e., the VRR Curve used in RPM Auctions) the MW of \nNew Large Loads that have not entered into BYONC arrangements or do not have \nAllocated RBP UCAP MW, over and above the MW of New Large Loads that were \nincluded in the load forecast for the 2028/2029 Delivery Year.293   \nNew Large Loads have, pursuant to the Ratepayer Protection Pledge, committed to \n“build, bring, or buy the new generation resources and electricity needed to satisfy their \nnew energy demands” and “add more capacity that serves the broader public by increasing \nsupply” in order to “advance[] self-sufficiency and protect[] Americans from higher \n \n292 See, e.g., Tariff, Attachment K-Appendix, section 5.2.2(d)(v) (“The LLC, PJMSettlement, and the \nMembers will not assume financial responsibility for the failure of a party to perform obligations owed to the \nother party under such a bilateral agreement reported to the Office of the Interconnection under this” Tariff \nand Operating Agreement provision.).  \n293 PJM Board directs that “[i]ncremental [N]ew Large Loads relative to the forecast utilized for the \n2028/2029 BRA . . . from the forecast used in future RPM auctions for the 2029/2030 Delivery Year and \nbeyond unless and until there are new supply resources offered into an RPM auction in sufficient quantity to \ncover the [individual] new Large Load.”  CIFP Framework for Service at 5."},{"page":116,"startToken":36831,"endToken":37225,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 110 \n \n \n \nprices.”294  Thus, to the extent that New Large Loads come online, PJM expects that these \nloads will either “build, bring, or buy” new generation and capacity to serve their needs.   \nNew Large Loads that have not entered into BYONC arrangements or do not have \nAllocated RBP UCAP MW will be excluded from the VRR Curve starting with the \n2029/2030 Delivery Year regardless of whether PJM is experiencing a shortfall that \ntriggers IRAS in the relevant Delivery Year.  Including the quantity of New Large Loads \nthat have not entered into BYONC arrangements or do not have Allocated RBP UCAP \nMW in the VRR Curve would fail to recognize that New Large Loads have committed to \n“build, bring, or buy the new generation resources and electricity needed to satisfy their \nnew energy demands” and “add more capacity that serves the broader public by increasing \nsupply.”295  Excluding the quantity of New Large Loads that have not entered into BYONC \narrangements or do not have Allocated RBP UCAP MW from the VRR Curve, on the other \nhand, recognizes the commitment of New Large Loads to cover their own energy and \n \n294 Ratepayer Protection Pledge; Ratepayer Protection Pledge Announcement; July 2026 Ratepayer \nProtection Pledge Update (identifying 282 utilities, cooperatives, data centers, and 23 governors that joined \nthe Ratepayer Protection Pledge, including 38 data centers:  Aligned Data Centers, LLC; Amazon.com, Inc.; \nBeale Infrastructure Group, LLC; CleanSpark LLC; Cloud HQ LLC; Cologix, Inc.; Compass Datacenters, \nLLC; Core Scientific, Inc.; CoreWeave, Inc.; Corscale, LLC; Crusoe Technologies LLC; CyrusOne, Inc.; \nDataBank Holdings, Ltd.; Digital Realty Trust, Inc.; EdgeConnex Inc.; EdgeCore Digital Infrastructure (d/b/a \nEdgeCore Internet Real Estate, LLC); Equinix, Inc.; Google (d/b/a Alphabet Inc.); Iron Mountain \nIncorporated; Meta Platforms, Inc.; Microsoft Corporation; Nebius Group N.V.; NTT Global Data Centers \n(d/b/a NTT DATA, Inc.); OpenAI, L.L.C.; Oracle Corporation; Oppidan Connect Data Centers (d/b/a \nOppidan Investment Company); Prologis, Inc.; Quality Technology Services, LLC; Rowan Digital \nInfrastructure Pty. Ltd.; Skybox Datacenters, LLC; STACK Infrastructure, Inc.; Starwood Digital Ventures \n(d/b/a Starwood Capital Operations, LLC); Stream Data Centers, L.P.; Switch, Inc.; T5Data Centers, LLC; \nTA Realty LLC; Vantage Data Centers Management Company, LLC; and x.AI LLC). \n295 Ratepayer Protection Pledge; Ratepayer Protection Pledge Announcement; July 2026 Ratepayer \nProtection Pledge Update."},{"page":117,"startToken":37225,"endToken":37495,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 111 \n \n \n \ncapacity needs to “advance[] self-sufficiency and protect[] Americans from higher \nprices.”296 \nFurthermore, in Delivery Years when there is a reliability shortfall and IRAS is \ntriggered, to the extent these New Large Loads have not entered into BYONC \narrangements or been Allocated RBP UCAP MW, their demand will be treated as Eligible \nNew Large Load Amounts—that is, MW quantities that are eligible to provide IRAS by \nvirtue of not having either entered into BYONC arrangements or having Allocated RBP \nUCAP MW.  When an Eligible New Large Load interconnects subject to Interim Resource \nAdequacy Service, that New Large Load is, indeed, availing itself to an interim solution—\nwhich permits the Eligible New Large Load to obtain service while simultaneously \npermitting PJM to maintain grid reliability and resource adequacy—even before the New \nLarge Loads’ BYONC arrangements are online and even if the New Large Loads are \nwithout Allocated RBP UCAP MW in that particular Delivery Year.   \nOnce New Large Loads have met their commitment to build, bring, or buy capacity \nto meet their own needs—whether through BYONC or an assignment of RBP UCAP MW \nfor the Delivery Year—the VRR Curve will incorporate the demand from the New Large \nLoad, as well as the supply that it has committed to provide for purposes of meeting the \ndemand it creates on the PJM system.  A New Large Load that was previously eligible for \nIRAS because it previously had not entered into BYONC arrangements will begin to be \n \n296 Ratepayer Protection Pledge; Ratepayer Protection Pledge Announcement; July 2026 Ratepayer \nProtection Pledge Update."},{"page":118,"startToken":37495,"endToken":37864,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 112 \n \n \n \nincluded in the forecast for the same RPM Auction that its BYONC arrangement will be \noffered into the RPM Auction.297   \n1. \nExcluding incremental New Large Load Amounts from the demand \ncurve beginning with the 2029/2030 Delivery Year   \nPJM is proposing two new Tariff definitions, “Excluded RTO New Large Load \nAmounts” and “Excluded Locational Deliverability Area (“LDA”) New Large Load \nAmounts” to mean the UCAP MW quantity of New Large Load that will not be reflected \nin the VRR Curve starting with the 2029/2030 Delivery Year.  The definitions are as \nfollows: \n• “Excluded RTO New Large Load Amounts” shall mean, converted in UCAP \nterms by using the Forecast Pool Requirement and exclusive of any load in an \nFRR Service Area, [the sum of all New Large Loads across the PJM Region in \nthe load forecast for the relevant Delivery Year] minus [New Large Loads \nacross the PJM Region that were included in the load forecast used for the \n2028/2029 Delivery Year] minus [the total MW quantity of New Large Load \nthat is added on or after the 2029/2030 Delivery Year and is (i) in an \narrangement with BYONC in the RTO or (ii) assigned Allocated RBP UCAP \nMW in the RTO].298 \n \n• “Excluded LDA New Large Load Amounts” shall mean, converted in UCAP \nterms by estimating the impact on required imports to a Locational \nDeliverability Area and exclusive of any load in an FRR Service Area, [the sum \nof all New Large Loads in the relevant Locational Deliverability Area that were \nincluded in the load forecast for the relevant Delivery Year] minus [New Large \nLoads in the relevant Locational Deliverability Area that were included in the \nload forecast used for the 2028/2029 Delivery Year] minus [the total MW \nquantity of New Large Load that is added on or after the 2029/2030 Delivery \nYear and is (i) in an arrangement with BYONC in the Locational Deliverability \nArea or (ii) assigned Allocated RBP UCAP MW in Locational Deliverability \nArea].299 \n \n297 Proposed Tariff, Attachment DD, section VII. \n298 Proposed Tariff, Definitions – Excluded RTO New Large Load Amounts. \n299 Proposed Tariff, Definitions – Excluded LDA New Large Load Amounts."},{"page":119,"startToken":37864,"endToken":38212,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 113 \n \n \n \nTo calculate the Excluded RTO New Large Load Amounts and the Excluded LDA \nNew Large Load Amounts, first, begin with the sum of all New Large Loads across the \nPJM Region or in the relevant LDA in the load forecast for the relevant Delivery Year.   \nSecond, subtract out the quantity of New Large Load in the load forecast for the \n2028/2029 Delivery Year for either the RTO or relevant LDA.  It is necessary to subtract \nthis amount because the BRA for the 2028/2029 Delivery Year, which took place in July \n2026, was the last auction conducted prior to this proposal.  Because that auction predates \nthis proposal, it relied on a load forecast that included all loads, including New Large Loads \nthat had not entered into BYONC arrangements or have Allocated RBP UCAP MW, in the \ndemand curve.  As a result, the quantities of New Large Loads incorporated into the load \nforecast for the 2028/2029 Delivery Year are an appropriate reference point for measuring \nthe incremental quantity of New Large Loads in the load forecast, beginning with the \n2029/2030 Delivery Year.300  This results in the incremental MW value of New Large Load \nfor the relevant Delivery Year.  \nThird, subtract the total MW quantity of New Large Load for the RTO or relevant \nLDA that is added on or after the 2029/2030 Delivery Year that has either entered into a \nBYONC arrangement or has Allocated RBP UCAP MW for that Delivery Year. \nFourth, as the above definitions reflect, Excluded RTO New Large Load Amounts \nand Excluded LDA New Large Load Amounts will be represented in UCAP terms.  Thus, \nto determine the Excluded RTO New Large Load Amounts, the resulting value of the above \n \n300 PJM proposes to maintain the inclusion of all New Large Loads in the demand curve for the remaining \nIncremental Auctions associated with the 2027/2028 and 2028/2029 Delivery Years to maintain consistency \nwith those loads being included in the demand curve for the corresponding BRAs that have already been \ncompleted."},{"page":120,"startToken":38212,"endToken":38518,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 114 \n \n \n \nsteps will be converted into UCAP terms by multiplying the calculated amount by the \nForecast Pool Requirement.  Likewise, to determine the Excluded LDA New Large Load \nAmounts, the resulting value of the above steps will be converted into UCAP terms by \nmultiplying the value by an estimated impact factor on required imports to an LDA.   \nLoad in FRR Service Areas will continue to not be included in the VRR Curve, as \nFRR Entities already provide capacity for all load, including New Large Loads, in their \nFRR Service Areas. \nThe Excluded RTO New Large Load Amounts and Excluded LDA New Large \nLoad Amounts, which are the UCAP MW that are not reflected in the RTO-wide VRR \nCurve and the VRR Curve for each LDA, respectively, should only reflect the incremental \nMW value of New Large Loads without BYONC or Allocated RBP UCAP MW in the \nPJM Region or the relevant LDA.  As noted above, the quantity of New Large Loads will \nbe reflected in the VRR Curve beginning with the same RPM Auction that the associated \nBYONC is offered for the first time. \nThe UCAP MW of New Large Loads that are not associated with qualifying \nBYONC or Allocated RBP UCAP MW are expected to build, bring, or buy their own \ngeneration and capacity to support their needs.  During a Delivery Year in which IRAS is \nin effect, these quantities of New Large Loads that have not entered into BYONC \narrangements or does not have Allocated RBP UCAP MW may, in the interim, be subject \nto load reduction pursuant to IRAS.  Nevertheless, as proposed, the UCAP MW of New \nLarge Loads without BYONC or Allocated RBP UCAP MW—whether or not subject to \nIRAS—will be excluded from the VRR Curve starting with the 2029/2030 Delivery Year."},{"page":121,"startToken":38518,"endToken":38847,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 115 \n \n \n \nTherefore, in accordance with the Ratepayer Protection Pledge, New Large Loads would \nultimately “add more capacity that serves the broader public by increasing supply.”301 \n2. \nNew Large Loads with BYONC arrangements or Allocated RPB \nUCAP MW will be reflected in the demand curve.   \nPJM’s proposed Tariff revisions provide that only the UCAP MW of New Large \nLoads without BYONC arrangements or Allocated RBP UCAP MW will be excluded from \nthe demand curve, but New Large Loads are not expected to be indefinitely excluded.  \nRather, where New Large Loads have arrangements for capacity within the same RPM \nAuction, these quantities of New Large Loads will no longer be excluded from the VRR \nCurve.  As explained above in Part II.C.3, BYONC resources with which New Large Load \nhas entered into arrangements would be required to be offered in the RPM Auction as \nsupply and as price takers.   \nFurthermore, the quantities of New Large Load would begin to be included in the \nVRR Curve in the same RPM Auction as the associated BYONC capacity.  In this way, \nthe impact of including such load in the demand curve is counterbalanced by the inclusion \nof a commensurate amount of additional Capacity Resources that are added to the supply \ncurve.  If a BYONC resource is offered into an RPM Auction before the quantity of New \nLarge Load with which it has an arrangement is added to the demand curve, the RPM \nAuction would not reflect actual supply and demand fundamentals.  Thus, to qualify as \nBYONC, the Capacity Resource must not have been offered and cleared in a prior RPM \nAuction where the load was not represented in the demand curve.302  Notably, if a New \n \n301 Ratepayer Protection Pledge.   \n302 Proposed Tariff, Attachment DD-4, section VI(a)(iii).  Given that New Large Loads are included in the \nRPM Auctions through the 2028/2029 Delivery Year and eligible BYONC that previously cleared an RPM"},{"page":122,"startToken":38847,"endToken":39155,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 116 \n \n \n \nLarge Load ramps up over time and arranges for a BYONC that is for the eventual full \nload, such BYONC would be allowed to be offered for the full amount into the first RPM \nAuction that the portion of the New Large Load will be included in the load forecast.  This \nis appropriate because such BYONC is being brought to the system by the New Large Load \nand should not be partially offered when it is available to serve as capacity for the full \naccredited quantity. \nOn the supply side, the LSE that serves the New Large Load would report to PJM \nany BYONC arrangements with the New Large Loads in the zone/area at least 30 days \nprior to the deadline for PJM to post the planning parameters for the relevant RPM \nAuction.303  PJM will therefore have sufficient time to confirm that the reported Capacity \nResources meets all of the BYONC eligibility requirements before including the quantity \nof New Large Load in the VRR Curve that will be posted as part of the planning parameters.   \nFurthermore, on the supply side, the BYONC resource, with which the New Large \nLoad has entered into an arrangement must adhere to existing RPM Auction rules to ensure \nthat the resource can be offered as a price taker in the relevant RPM Auction that the \nquantity of New Large Load would be included in demand curve.  This includes, but is not \nlimited to, meeting all the requirements to be offered as a Capacity Resource, submitting \n \nAuction through the 2028/2029 Delivery Year was not on notice of this limitation, any eligible BYONC that \nis offered in RPM Auctions through the 2028/2029 Delivery Year can be procured by New Large Loads to \navoid IRAS. \n303 Proposed Tariff, Attachment DD-4, section VII(c)."},{"page":123,"startToken":39155,"endToken":39510,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 117 \n \n \n \ntimely binding notice of intent to offer, and certifying that no buyer-side market power will \nbe exercised in accordance with the existing rules and timelines.304  \nIf an LSE does not timely report the New Large Load’s arrangement with eligible \nBYONC to PJM by the specified deadline, then PJM would not include the quantity of \nNew Large Load in the demand curve.  This is because PJM will post the VRR Curve used \nfor the relevant RPM Auction as part of the planning parameters so any submissions \nreceived after the deadline would not be timely incorporated into the demand curve.   \nTo remove potential incentives for LSEs to not timely report New Large Loads in \narrangements with BYONC resources, the quantity of those New Large Loads that have \nnot been timely reported to PJM will continue to be subject to the IRAS in Delivery Years \nwhen IRAS is triggered, until the relevant LSEs have reported New Large Load \narrangement with a BYONC Capacity Resource to PJM at least 30 days prior to the \ndeadline for PJM to post the planning parameters305 for a subsequent RPM Auction.  \n3. \nEach of the three points on the VRR Curve would be reduced by the \nQuantities of New Large Loads for the relevant Base Residual \nAuction.  \nIn addition to the two new definitions described above in Part II.F.1, PJM proposes \nto modify the existing rules in Tariff, Attachment DD, section 5.10(a) to specify that, for \neach of the three points on the VRR Curve, the Excluded RTO New Large Load Amounts \nwould be deducted from the PJM Region Reliability Requirement, and the relevant \n \n304 See generally Tariff, Attachment DD, section 5.3; Tariff, Attachment DD, section 5.14(h-2); RAA, \nSchedule 9.2; RAA, Schedule 10. \n305 Proposed Tariff, Attachment DD-4, section VII(d).  For the 2029/2030 Delivery Year, the arrangement \nmust be reported 50 days prior to the commencement of the BRA or 30 days prior to the posting of the \nplanning parameters for the Scheduled Incremental Auctions.  See Proposed Tariff, Attachment DD-4, \nsection VII(c)."},{"page":124,"startToken":39510,"endToken":39820,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 118 \n \n \n \nExcluded LDA New Large Load Amounts would be deducted from the respective LDA \nReliability Requirements before being multiplied by the relevant existing percentages.306  \nGiven that the Commission accepted the extension of the price collar through the \n2029/2030 Delivery Year, the proposed Tariff revisions maintain the distinctions between \nthe VRR Curve for the 2029/2030 Delivery Year and the VRR Curve associated with the \nsubsequent Delivery Years.  Similarly, the respective points on the LDA VRR Curves \nwould be reduced by the relevant Excluded LDA New Large Load Amounts.307   \n4. \nThe Incremental Auctions will reflect adjustments of capacity \npreviously committed, including any updated adjustments to the \nExcluded RTO New Large Load Amounts and/or Excluded LDA \nNew Large Load Amounts.  \nAs with the BRAs, PJM would similarly exclude Eligible New Large Load \nAmounts from the Demand Curve for Scheduled Incremental Auctions.  To do this, PJM \nproposes to modify the definition of Updated VRR Curve to account for the Excluded RTO \nNew Large Load Amounts and Excluded LDA New Large Load Amounts.308  This \ndefinition will then be incorporated by reference in the existing definitions of Updated \nVRR Curve Increment and Updated VRR Curve Decrement, which are used in the \noptimization algorithm for clearing the Scheduled Incremental Auctions.309 \n \n306 Proposed Tariff, Attachment DD, section 5.10(a)(i). \n307 Proposed Tariff, Attachment DD, section 5.10(a)(ii)(C). \n308 Proposed Tariff, Definitions – Updated VRR Curve (“‘Updated VRR Curve’ shall mean the Variable \nResource Requirement Curve for use in the Base Residual Auction of the relevant Delivery Year, updated to \nreflect any changes in the Reliability Requirement, Excluded RTO New Large Load Amounts, and/or \nExcluded LDA New Large Load Amounts from the Base Residual Auction to the relevant Incremental \nAuction.”). \n309 See Tariff, Attachment DD, section 5.12(b)."},{"page":125,"startToken":39820,"endToken":40146,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 119 \n \n \n \nPJM also proposes to modify the existing rules in Tariff, Attachment DD, \nsection 5.4 to specify that each LDA Reliability Requirement will be updated to reflect \nadjustments to the Excluded LDA New Large Load Amounts.  Similarly, PJM is proposing \nto modify the existing rules in Tariff, Attachment DD, section 5.4 to specify that each LDA \nReliability Requirement will be updated to reflect adjustments to the Excluded LDA New \nLarge Load Amounts.  These revisions conform the treatment of Excluded LDA New \nLarge Load Amounts and Excluded RTO New Large Load Amounts in Incremental \nAuctions to their treatment in BRAs, starting with the 2029/2030 Delivery Year. \n5. \nPJM will maintain transparency by posting the Variable Resource \nRequirement Curve in advance of the RPM Auctions.  \nConsistent with the existing practice of posting VRR Curves as part of the broader \nplanning parameters that are posted as part of the pre-auction process, PJM proposes to \nmemorialize the posting requirement by specifying that the VRR Curves will be “posted \non the same timeline with the PJM Region Reliability Requirement and the Locational \nDeliverability Area Reliability Requirement.”310  Since the VRR Curve for the 2029/2030 \nDelivery Year will be posted as part of the planning parameters under the existing Tariff \nrules by August 31, 2026, PJM makes clear in the proposed Tariff that an Updated VRR \nCurve for the 2029/2030 BRA will be posted one month prior to the commencement of the \nRPM Auction.   \n \n310 Proposed Tariff, Attachment DD, section 5.10(a)(vi)(B).  This deadline would typically be February 1 \nprior to the conduct of a BRA when it is conducted on a normal three-year schedule.  However, until the \n2030/2031 BRA, the RPM Auctions are still on a compressed auction schedule with the deadline for posting \nthe planning parameters subject to a Commission waiver order.  See PJM Interconnection, L.L.C., 189 FERC \n¶ 61,105 (2024)."},{"page":126,"startToken":40146,"endToken":40353,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 120 \n \n \n \nPosting an Updated VRR Curve for the 2029/2030 BRA is entirely distinguishable \nfrom the underlying facts in the United States Court of Appeals for the Third Circuit’s \norder finding that updating the LDA Reliability Requirement after the auction commenced \nwas barred by the filed-rate doctrine.311  Because PJM will post the Updated VRR Curve \nfor the 2029/2030 BRA 30 days before the auction commences and binding offers are \nsubmitted by Capacity Market Sellers, no legal consequences attach after PJM posts the \ninitial VRR Curve on August 31, 2026, especially as this filing provides notice that the yet-\nto-be posted VRR Curve is subject to change in accordance with the proposal set forth in \nthis filing. \nFinally, in addition to specifying that the VRR Curve will be posted prior to the \nauction, PJM also proposes to specify that the Excluded RTO New Large Load Amounts \nand Excluded LDA New Large Load Amounts used in establishing the VRR Curve will be \nincluded in the posting requirement beginning with the 2029/2030 BRA.312 \n \n311 PJM Power Providers Grp. v. FERC, 96 F.4th 390, 400 (3d Cir. 2024). \n312 Proposed Tariff, Attachment DD, section 5.11(a)(iii)."},{"page":127,"startToken":40353,"endToken":40628,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 121 \n \n \n \nIII. \nCORRESPONDENCE \nThe following individuals are designated for inclusion on the official service list in \nthis proceeding and for receipt of any communications regarding this filing: \nCraig Glazer \nVice President–Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, DC 20005 \n(202) 423-4743  \ncraig.glazer@pjm.com \n \nRyan J. Collins \nVivian W. Chum \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, DC 20005 \n(202) 393-1200  \ncollins@wrightlaw.com \nchum@wrightlaw.com \nMark J. Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd. \nAudubon, PA  19403 \n(610) 666-8800 \nmark.stanisz@pjm.com  \n \n \nIV. \nREQUESTED EFFECTIVE DATE AND CONSENT TO MODIFICATION \nOR SEVERANCE OF ISSUES \nPJM requests that the Commission issue an order on this filing and make the \nenclosed proposed Tariff and RAA revisions effective by no later than October 12, 2026, \n2026, which is 60 days after the date of this filing, and to make the Large Load Registry \nrules effective October 12, 2026, which is 60 days from the date of filing.  Such an effective \ndate will allow PJM to start building the Large Load Registry and accept reports of \narrangements between New Large Loads and BYONC in time to expeditiously develop \nand post a new VRR Curve with the New Load Loads removed to the extent they do not \nhave BYONC arrangements.  An October 12, 2026 effective date will not affect when PJM \nwill call an Interim Resource Adequacy Service Action.  As the enclosed revisions make \nclear, IRAS starts being available with the 2027/2028 Delivery Year, i.e., June 1, 2027."},{"page":128,"startToken":40628,"endToken":41088,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 122 \n \n \n \nFurther, allowing the revisions to be effective on the date requested, and allowing IRAS to \ncommence June 1, 2027, would enable the states and other interested entities to put in place \nthe appropriate state-level tools to complement and implement IRAS.  As discussed, PJM \nunderstands that some states have begun proceedings to evaluate how to best facilitate \ncoordination with PJM on implementing IRAS.  PJM welcomes all such efforts.  \nIn addition, as noted above, however, to facilitate Commission approval and \nsmooth implementation of the IRAS on June 1, 2027, PJM consents to the Commission’s \nexercise of authority to modify and/or sever the proposed Tariff and RAA language, as \nneeded and permitted under the FPA and NRG Power Marketing,313 where such \nmodification is consistent with PJM’s overarching objectives in this filing.314  In addition, \nPJM provides the following requests and observations:     \nFirst, should the Commission exercise its authority to modify the proposed Tariff \nlanguage herein pursuant to the FPA and NRG Power Marketing, PJM respectfully requests \nthat the Commission expressly prescribe the revised rate or rule in its order.  Prescriptive \nrevised language from the Commission would provide the “necessary predictability” to \n \n313 NRG Power Mktg., 862 F.3d at 108.  As the Commission has repeatedly stated, “[t]he United States Court \nof Appeals for the District of Columbia Circuit has held that, in certain circumstances, the Commission has \n‘authority to propose modifications to a utility’s [FPA section 205] proposal if the utility consents to the \nmodifications.’”  N.Y. Indep. Sys. Operator, 188 FERC ¶ 61,051 at P 22 n.36 (second alteration in original) \n(citing NRG Power Mktg., 862 F.3d at 114-15); see Midcontinent Indep. Sys. Operator, 180 FERC ¶ 61,141 \nat P 26 n.29 (same); ISO New England, 175 FERC ¶ 61,172 at P 16 n.20 (same). \n314 PJM is not, for example, suggesting that the Commission may modify or sever provisions of its proposal \nto result in an “entirely different rate design.”  NRG Power Mktg., 862 F.3d at 115 (“Our decisions in City of \nWinnfield and Western Resources indicate that Section 205 does not allow FERC to suggest modifications \nthat result in an ‘entirely different rate design’ than the utility’s original proposal or the utility’s prior rate \nscheme.”); see also id. at 116 (holding that the Commission’s modifications resulted in an entirely different \nrate design where Commission’s modifications: (1) replaced PJM’s proposal to permit exemption where \ngenerators demonstrate on a case-by-case basis that their costs fell below the price floor with one in which \ngenerators can claim exemptions even if they cannot demonstrate that their price falls below the floor; (2) \nundid the compromise between LSEs and Generators and thus “eviscerated the terms of the bargain”)."},{"page":129,"startToken":41088,"endToken":41524,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 123 \n \n \n \nallow PJM to implement such changes to elements of the Large Load Registry or IRAS in \na timely manner.315  PJM’s submittal of any compliance filing implementing such \nmodifications would constitute PJM’s consent and acceptance of the Commission’s \nmodifications.   \nSecond, PJM observes that the facts underlying the PJM proposal at issue in NRG \nPower Marketing are distinguishable from the facts here.  In NRG Power Marketing, the \nFPA section 205 filing with the Commission was one in which “PJM asked the \nCommission ‘to view this filing not as a list of discrete Tariff changes, but . . . a hard-\nfought compromise package, and to approve it as such.’”316  By contrast, the proposal put \nforth here is not a stakeholder compromise package.  Unlike NRG Power Marketing, there \nis no danger of undoing the compromise between LSEs and Generators and thus \n“eviscerat[ing] the terms of the bargain.”317  Rather, this filing is the product of an RBP \nproposal that was independently endorsed by the PJM Board following the CIFP \nstakeholder process.  Moreover, through this pre-emptive grant of authority pursuant to \n \n315 PJM Interconnection, L.L.C., 175 FERC ¶ 61,137, at P 110 (2021) (first quoting Aera Energy LLC v. \nFERC, 789 F.3d 184, 190-92 (D.C. Cir. 2015) (“affirming the Commission, finding ‘FERC’s conditional \nacceptance . . . simply required Kern River to substitute one number for another when allocating costs to the \nrolled-in shippers. . . . Because this mechanical change gave Kern River no discretion to adjust its rate models, \nFERC provided sufficient notice to ratepayers’”); and then quoting Elec. Dist. No. 1 v. FERC, 774 F.2d 490, \n493 (D.C. Cir. 1985) (“vacating when the ‘effective date of an order set[] forth no more than the basic \nprinciples pursuant to which the new rates are to be calculated’”) (alteration in original)).  As the Commission \nelaborated further in PJM Interconnection, mere “direction” without “sufficient detail on each element [of \nthe replacement rate] that [customers/market participants] could determine when their transactions would be \nsubject to [the new rule],” would mean that implementation of the compliance directive prior Commission \napproval would violate the filed rate doctrine.  Id. (quoting Elec. Dist. No. 1, 774 F.2d at 493 (“[P]urchasers \nof electricity cannot plan their activities unless they know the cost of what they are receiving, ‘providing the \nnecessary predictability is the whole purpose of the well-established filed rate doctrine.’” (citing Ark. La. \nGas Co. v. Hall, 453 U.S. 571, 577 (1981)))). \n316 NRG Power Mktg., 862 F.3d at 113 (citation omitted). \n317 NRG Power Mktg., 862 F.3d at 116."},{"page":130,"startToken":41524,"endToken":41821,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 124 \n \n \n \nwhich the Commission may sever and modify each element of the proposal, stakeholders \nare on notice of potential changes to the proposal as filed, and will have the opportunity to \ncomment as they feel necessary and appropriate.   \nThird, although PJM consents to make each element of the proposed revisions to \nthe Tariff and RAA severable, PJM has demonstrated that each element of its proposal is \njust and reasonable.  Notwithstanding PJM’s grant of authority to sever, PJM urges the \nCommission to accept all revisions as proposed so that the elements of the Large Load \nRegistry can commence on October 12, 2026; would allow PJM to expeditiously post an \nUpdated VRR Curve for the December 2029/2030 BRA; and IRAS can begin June 1, 2027.   \nTo the extent the Commission does sever and modify any element, the Commission \nshould recognize that, while the RAA and Tariff revisions together advance a means for \naddressing the resource adequacy issues resulting from new large loads interconnecting to \nthe transmission system faster than new capacity is being placed in service.  The elements \nof this proposal were developed together and designed to work in lockstep and provide \ncomplementary pieces to a multi-prong approach to incent New Large Loads to bring their \nown capacity to meet their resource adequacy needs and avoid imposing costs on \nratepayers.  Indeed, the VRR Curve changes are predicated on the BYONC proposed as \npart of the IRAS framework.  Conversely, the general obligation that Load Serving Entities \nbring new capacity in an amount that equals or exceeds its New Large Loads’ peak load \nand Large Load Registry are each discrete from the other elements of this filing and would \nprovide an independent value of informing PJM’s operations, planning, and load \nforecasting activities."},{"page":131,"startToken":41821,"endToken":42117,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 125 \n \n \n \nFinally, PJM continues to discuss with states and other stakeholders how to address \nthese issues, particularly the federal-state handoff of responsibilities.  To that end, PJM \nmay, at the behest of the states, host workshops with states and other stakeholders, which \nmay result in amendments to the proposals submitted herein and, if necessary, additional \ntime for comments and consideration as may be necessary or appropriate. \nV. \nDOCUMENTS ENCLOSED \nThis filing consists of the following: \n1. \nThis transmittal letter;  \n2. \nRevisions to the PJM Tariff and Resource Adequacy Agreement (in redlined \nand non-redlined format (as Attachments A and B, respectively) and in \nelectronic tariff filing format as required by Order No. 714);318 and  \n3. \nAffidavit of Christopher Pilong on Behalf of PJM Interconnection, L.L.C. as \nAttachment C. \nVI. \nSERVICE \nPJM has served a copy of this filing on all PJM members and on all state utility \nregulatory commissions in the PJM Region by posting this filing electronically.  In \naccordance with the Commission’s regulations,319 PJM will post a copy of this filing to the \nCommission filings section of its internet site, located at the following link:  \nhttps://www.pjm.com/library/filing-order.aspx with a specific link to the newly filed \ndocument, and will send an e-mail on the same date as this filing to all PJM members and \nall state utility regulatory commissions in the PJM Region320 alerting them that this filing \n \n318 Electronic Tariff Filings, Order No. 714, 124 FERC ¶ 61,270 (2008), final rule, Order No. 714-A, 147 \nFERC ¶ 61,115 (2014). \n319 See 18 C.F.R. §§ 35.2(e), 385.2010(f)(3). \n320 PJM already maintains, updates, and regularly uses e-mail lists for all PJM members and affected state \ncommissions."},{"page":132,"startToken":42117,"endToken":42328,"text":"Honorable Debbie-Anne A. Reese \nAugust 13, 2026 \nPage 126 \n \n \n \nhas been made by PJM and is available by following such link.  PJM also serves the parties \nlisted on the Commission’s official service list for this docket.  If the document is not \nimmediately available by using the referenced link, the document will be available through \nthe referenced link within 24 hours of the filing.  Also, a copy of this filing will be available \non \nthe \nCommission’s \neLibrary \nwebsite \nlocated \nat \nthe \nfollowing \nlink:  \nhttp://www.ferc.gov/docs-filing/elibrary.asp in accordance with the Commission’s \nregulations and Order No. 714. \nVII. \nCONCLUSION \nBased on the foregoing, PJM requests that the Commission accept the enclosed \nproposed Tariff and RAA revisions by October 12, 2026, effective as requested. \nRespectfully submitted, \n/s/ Ryan J. Collins \n \nCraig Glazer \nVice President–Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 423-4743  \ncraig.glazer@pjm.com \n \nRyan J. Collins \nVivian W. Chum \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 393-1200  \ncollins@wrightlaw.com \nchum@wrightlaw.com \n \nMark J. Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd. \nAudubon, PA  19403 \n(610) 666-8800 \nmark.stanisz@pjm.com  \n \n \n \nAugust 13, 2026"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":0,"startToken":0,"endToken":130},{"p":2,"at":0,"title":"TABLE OF CONTENTS","method":"printed heading","endPage":2,"endAt":139,"startToken":130,"endToken":136},{"p":2,"at":139,"title":"A. The Senior Task Force and Critical Issue Fast Path Stakeholder","method":"printed heading","endPage":2,"endAt":528,"startToken":136,"endToken":161},{"p":2,"at":528,"title":"II. THE PROPOSED REFORMS TO THE TARIFF AND THE RAA ARE","method":"printed heading","endPage":2,"endAt":748,"startToken":161,"endToken":182},{"p":2,"at":748,"title":"A. Overview of Interim Resource Adequacy Service Framework and","method":"printed heading","endPage":3,"endAt":530,"startToken":182,"endToken":408},{"p":3,"at":530,"title":"C. New Large Loads Can Avoid Being Subject to Interim Resource","method":"printed heading","endPage":5,"endAt":1667,"startToken":408,"endToken":1059},{"p":5,"at":1667,"title":"E. Compensation for Load Reduction Under Interim Resource","method":"printed heading","endPage":6,"endAt":303,"startToken":1059,"endToken":1133},{"p":6,"at":303,"title":"F. Consistent with the Ratepayer Protection Pledge, PJM Is Proposing","method":"printed heading","endPage":6,"endAt":1534,"startToken":1133,"endToken":1278},{"p":6,"at":1534,"title":"IV. REQUESTED EFFECTIVE DATE AND CONSENT TO","method":"printed heading","endPage":19,"endAt":231,"startToken":1278,"endToken":5631},{"p":19,"at":231,"title":"I. BACKGROUND","method":"printed heading","endPage":19,"endAt":235,"startToken":5631,"endToken":5632},{"p":19,"at":235,"title":"BACKGROUND","method":"printed heading","endPage":21,"endAt":64,"startToken":5632,"endToken":6418},{"p":21,"at":64,"title":"A. The Senior Task Force and Critical Issue Fast Path Stakeholder","method":"printed heading","endPage":22,"endAt":1184,"startToken":6418,"endToken":6874},{"p":22,"at":1184,"title":"B. PJM Board Determination","method":"printed heading","endPage":24,"endAt":1087,"startToken":6874,"endToken":7628},{"p":24,"at":1087,"title":"C. Related PJM Large Load Filings","method":"printed heading","endPage":27,"endAt":64,"startToken":7628,"endToken":8597},{"p":27,"at":64,"title":"II. THE PROPOSED REFORMS TO THE TARIFF AND THE RAA ARE JUST","method":"printed heading","endPage":27,"endAt":189,"startToken":8597,"endToken":8617},{"p":27,"at":189,"title":"A. Overview of Interim Resource Adequacy Service Framework and","method":"printed heading","endPage":34,"endAt":322,"startToken":8617,"endToken":10769},{"p":34,"at":322,"title":"B. The Large Load Registry (RAA, Schedule 11, Section B)","method":"printed heading","endPage":55,"endAt":64,"startToken":10769,"endToken":17349},{"p":55,"at":64,"title":"C. New Large Loads Can Avoid Being Subject to Interim Resource","method":"printed heading","endPage":80,"endAt":1095,"startToken":17349,"endToken":25421},{"p":80,"at":1095,"title":"D. Load Reduction Under Interim Resource Adequacy Service","method":"printed heading","endPage":107,"endAt":793,"startToken":25421,"endToken":33939},{"p":107,"at":793,"title":"E. Compensation for Load Reduction Under Interim Resource Adequacy","method":"printed heading","endPage":115,"endAt":459,"startToken":33939,"endToken":36562},{"p":115,"at":459,"title":"F. Consistent with the Ratepayer Protection Pledge, PJM Is Proposing to","method":"printed heading","endPage":127,"endAt":65,"startToken":36562,"endToken":40362},{"p":127,"at":65,"title":"III. CORRESPONDENCE","method":"printed heading","endPage":127,"endAt":757,"startToken":40362,"endToken":40465},{"p":127,"at":757,"title":"IV. REQUESTED EFFECTIVE DATE AND CONSENT TO MODIFICATION","method":"printed heading","endPage":131,"endAt":498,"startToken":40465,"endToken":41894},{"p":131,"at":498,"title":"V. DOCUMENTS ENCLOSED","method":"printed heading","endPage":131,"endAt":910,"startToken":41894,"endToken":41958},{"p":131,"at":910,"title":"VI. SERVICE","method":"printed heading","endPage":132,"endAt":632,"startToken":41958,"endToken":42216},{"p":132,"at":632,"title":"VII. CONCLUSION","method":"printed heading","endPage":132,"endAt":638,"startToken":42216,"endToken":42217},{"p":132,"at":638,"title":"CONCLUSION","method":"printed heading","endPage":132,"endAt":1381,"startToken":42217,"endToken":42328}]}