EL26-67-000 · 2026-07-28 · PJM Interconnection, L.L.C.

PJM requests more time to answer the June 18 show cause order

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
PJM Interconnection, L.L.C., et al. 
) 
) 
) 
 
Docket No. EL26-67-000 
 
MOTION OF PJM INTERCONNECTION, L.L.C.  
TO HOLD PROCEEDING IN ABEYANCE AND REQUEST FOR SHORTENED 
ANSWER PERIOD AND EXPEDITED TREATMENT 
 
Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy 
Regulatory Commission (“Commission”),1 PJM Interconnection, L.L.C. (“PJM”) moves to 
hold the above-captioned proceeding in abeyance for ninety days to allow PJM to pursue a 
Federal Power Act (“FPA”) section 205 filing,2 to address the issues identified in the large 
load show cause order issued June 18, 2026 (“Large Load Order”).3  PJM is already working 
to develop a section 205 filing to respond to the Large Load Order on an expedited basis.  
This development, however, must be done in conjunction with PJM’s already ongoing 
efforts to implement changes directed by the Order on Rehearing, Clarification, 
Compliance Filing, and Paper Hearing (“Compliance Order”) in the PJM Co-Located Load 
proceeding. 4  Many of the changes contemplated in the Large Load Order will build upon 
compliance changes recently ordered for Co-Located Load in Docket Nos. EL25-49-000, 
et al. 5  Given the complexity and interrelated nature of these issues, an abeyance is 
appropriate to allow time for PJM to identify what changes to the Open Access 
Transmission Tariff (“Tariff”) may be needed on a holistic basis, engage with stakeholders, 
 
1 18 C.F.R. § 385.212. 
2 16 U.S.C. § 824d. 
3 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026). 
4 See PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026). 
5 See id.

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and develop the resulting FPA section 205 filing.  PJM anticipates submitting that filing 
by early to mid-November.  Accordingly, PJM respectfully requests that the Commission 
grant a ninety-day abeyance starting on the current compliance deadline, August 17, 2026.6  
In the interest of regulatory certainty, PJM also requests that the Commission shorten the 
answer period to five days and grant expedited consideration to rule on this motion within 
ten days of filing (i.e., by August 6, 2026). 
I. 
BACKGROUND 
A. 
Large Load Order 
The Large Load Order is an important component of the Commission’s ongoing 
efforts to efficiently and cost effectively integrate large loads with the transmission 
system.7  The Large Load Order found that several aspects of PJM’s Tariff appeared unjust 
and unreasonable due to the lack of specific procedures for integrating large loads, 
including a lack of large load-specific procedures for interconnection studies, processing 
transmission service requests, and providing transmission service without cost shifting.8  
The Large Load Order also found PJM’s Tariff appeared to be unjust and unreasonable due 
to a lack of transmission service options for customers taking service on behalf of large 
loads that are willing and able to limit their withdrawals from the transmission system.9  
Additionally, the Large Load Order found that PJM’s Tariff appeared to be unjust and 
unreasonable due to a lack of mechanisms to ensure that costs are not shifted between 
transmission customers.10 
 
6 See Large Load Order at P 3. 
7 Id. at P 1. 
8 Id. at PP 60, 65, 77. 
9 Id. at P 86.  
10 Id. at P 77.

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To address these issues, the Large Load Order directed PJM to make two 
compliance filings.11  First, the Large Load Order directed PJM to submit an informational 
filing within thirty days to explain how PJM intends to ensure that it has adequate 
generation to serve existing and new large loads.12  Second, the Large Load Order directed 
PJM to submit within sixty days a response to explain whether its Tariff remains just and 
reasonable in light of the issues identified in the order or to propose changes that would 
remedy the identified concerns.13  The Commission noted that it would entertain requests 
to hold the show cause proceedings in abeyance if PJM demonstrated a plan to propose 
changes pursuant to section 205 of the FPA.14 
B. 
Co-Located Load Proceeding 
Also on June 18, 2026, the Commission issued the Compliance Order in the PJM 
Co-Located Load proceeding.15  The Compliance Order accepted most of PJM’s proposed 
Tariff changes, but directed that PJM make a number of additional changes within sixty 
days.16  Among other things, the Compliance Order directed PJM to propose changes to 
clarify the study process for interconnecting Co-Located Loads,17 make new transmission 
services available to customers with behind the meter generation (“BTMG”) that are 
 
11 Id. at ordering paras. (A) & (B). 
12 Id. at P 4 & ordering para. (C). 
13 Id. at ordering para. (B). 
14 Id. at P 39. 
15 See generally Compliance Order. 
16 See, e.g., Compliance Order at P 280 (directing PJM to revise Tariff to specify what information about 
necessary studies will be available in the manuals). 
17 Id. at PP 370-75.

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willing and able to limit their withdrawals from the transmission system,18 and clarify the 
operational requirements for customers taking service on behalf of large loads.19 
C. 
Overlap Between Proceedings 
The compliance changes directed in the Large Load Order significantly relate to or 
overlap with the directives in the Compliance Order in three major areas:  (1) expansion of 
new transmission services; (2) study procedures; and (3) operational requirements.   
First, the Compliance Order and the Large Load Order both directed PJM to expand 
the availability of new transmission services.  The Compliance Order directed PJM to make 
the new transmission services available to customers taking service on behalf of load with 
BTMG that are willing and able to limit their withdrawals from the transmission system.20  
To accomplish this, the Commission directed PJM to either add a definition of “Eligible 
Load” that encompasses both customers serving both Co-Located Load and load with 
BTMG or to propose comparable Tariff revisions.21  At the same time, the Large Load 
Order directed PJM to propose Tariff changes to make those same new transmission 
services available to flexible large loads or explain why it need not do so.22  Thus, PJM 
will consider the potential impacts on flexible large loads in crafting Tariff revisions to 
expand the new transmission services to customers serving load with BTMG. 
Second, the Compliance Order and the Large Load Order both directed PJM to 
enhance its study procedures.  The Compliance Order directed PJM to revise the Tariff to 
 
18 Id. at P 91. 
19 Id. at P 65. 
20 Id. at P 91 (directing PJM to expand new transmission services to customers serving those with BTMG 
that are willing and able to limit withdrawals from the transmission system). 
21 Id.  
22 Large Load Order at P 87.

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adopt more detailed study procedures for firm contract demand transmission service and 
non-firm contract demand transmission service that mirror existing cluster study 
procedures.23  Similarly, in the Large Load Order, the Commission directed PJM to either 
propose study procedures for customers requesting service on behalf of large loads that can 
identify necessary network upgrades within 60-90 days or explain why it need not do so.24  
Thus, PJM will determine how to integrate these large loads into its study processes.  
Third,  the Compliance Order directed PJM to revise the Tariff to provide additional 
detail regarding the operational requirements and necessary control technologies to be 
employed for customers taking new transmission services on behalf of Eligible Load.25  
Similarly, the Large Load Order directed PJM to evaluate what operational requirements 
are appropriate for customers taking service on behalf of large loads.26  Thus, PJM must 
either set operational requirements that encompass the various categories of co-located and 
large loads or determine what operational requirements are appropriate for large loads 
specifically to ensure treatment that is not unduly discriminatory. 
D. 
Compliance Plan 
Given the significant overlap in subject matter,27 it is important for PJM to consider 
a number of the related Compliance Order’s directives in responding to the Large Load 
Order.  PJM has already been working to develop the Tariff changes directed by the 
Compliance Order that will serve, in large part, as the foundation for the FPA section 205 
 
23 Compliance Order at P 370. 
24 Large Load Order at P 63. 
25 Compliance Order at PP 482, 541. 
26 Large Load Order at P 64. 
27 See, e.g., Midcontinent Indep. Sys. Operator, 195 FERC ¶ 61,212 (2026) (issuing show cause order 
regarding co-located load arrangements and large load); Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026) 
(same); Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (same).

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filing PJM intends to develop to respond to the Large Load Order.  PJM intends to make a 
compliance filing on August 17th to address many of the Compliance Order’s directives as 
further discussed in PJM’s simultaneously-filed extension motion in that proceeding.   
Given the interrelated nature of many of these requirements, PJM is proposing to address 
the related remaining aspects of both filings through integrated stakeholder engagement.     
PJM is immediately focusing on the remaining open issues presented by the 
Compliance Order to finalize its tariffed construct for accommodating co-location 
arrangements and load with BTMG, which is the bedrock for many of the other Large Load 
Order reforms.  To avoid any doubt, PJM’s August 17th compliance filing in the Co-
Located Load docket will, for example, make progress on the new transmission service 
products by including Tariff language on Interim Network Integration Transmission 
Service.  At the same time, PJM intends its FPA section 205 filing in the Large Load Order 
docket will address all other categories for reform identified in the Large Load Order.  
Among other things, PJM’s intended FPA section 205 filing will advance a proposal that 
delivers faster and more flexible processes that also:  (1) achieve efficient transmission 
service application and study processes, including through the consideration of alternative 
transmission technologies; (2) prevent cost shifting and enhance transparency into 
transmission costs28 (with consideration given to concerns and issues raised in recently 
submitted requests for clarification and rehearing); (3) provide new transmission services 
for flexible large loads, building upon the work that has already been done and will be 
finalized regarding Co-Located Load; and (4) enhance study processes especially for 
generating facilities that serve electrically proximate large loads.  More details about PJM’s 
 
28 PJM is working on these cost and rate issues with the PJM Transmission Owners, consistent with their 
FPA section 205 filing rights.

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conceptual framework will be previewed with stakeholders on July 30, 2026.  A 
presentation reflecting this framework has been publicly posted to guide the next few 
months of intensive, focused engagement efforts to realize these important reforms.29   
PJM has or will be scheduling stakeholder engagement sessions to both share and 
receive feedback on PJM’s proposal on July 30, 2026, August 18, 2026, and September 16, 
2026,30 with the goal of taking an advisory stakeholder vote on the proposal at the meeting 
of the Members Committee on October 28, 2026, while also satisfying the notice 
requirements pursuant to Tariff, section 9.2(b).31  PJM will also engage with the 
Transmission Owners through appropriate consultation on or about the same date.  Because 
section 9.2(b) of the Tariff requires this consultation to take place at least seven days prior 
to an FPA section 205 filing,32 PJM would then be in a position to make the resulting 
section 205 filing in early to mid-November.  PJM is separately moving for a ninety-day 
extension of time for some aspects of the compliance obligations in the Compliance Order, 
even though PJM will make a compliance filing in that proceeding on August 17, 2026, as 
further discussed in its extension motion.33  
II. 
MOTION TO HOLD PROCEEDING IN ABEYANCE 
PJM respectfully requests the Commission hold this proceeding in abeyance for 
ninety days to allow PJM adequate time to develop a section 205 filing to respond to the 
 
29 Donnie Bielak, Show Cause Order for Large Loads Conceptual Approach: Co-Located Load Order 
Workshop, PJM Interconnection, L.L.C. Interconnection Planning (July 30, 2026), https://www.pjm.com/-
/media/DotCom/committees-groups/workshops/cllsco/2026/20260730/20260730-item-03---show-cause-
for-large-loads-conceptual-approach---presentation.pdf/ [https://perma.cc/QSQ5-FKAU].  
30 These are the currently contemplated dates, but the dates may be subject to change as needed.   
31 Tariff, Part I, section 9.2(b). 
32 See id. 
33 PJM Interconnection, L.L.C., Motion for Extension of Time for Specified Compliance Requirements and 
Request for Expedited Treatment of PJM Interconnection, L.L.C., Docket Nos. EL25-49-000, et al. (July 28, 
2026).

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Large Load Order.  An abeyance is appropriate to allow PJM to identify and develop the 
necessary Tariff changes, engage with stakeholders on an expedited basis, and develop an 
FPA section 205 filing to address the Large Load Order while also finalizing its response 
to certain overlapping aspects of the Compliance Order.  The Commission has previously 
exercised its discretion to hold show cause proceedings in abeyance to allow a Regional 
Transmission Organization to engage with stakeholders to resolve the matter via an FPA 
section 205 filing.34  It should do so again here. 
As discussed above, there is significant overlap in the compliance directives in the 
Large Load Order and the Compliance Order.  Given this overlap, PJM intends to address 
the related requirements of both orders with stakeholders through integrated stakeholder 
engagement to promote efficiency and consistency.  As noted above, PJM has scheduled 
or will be scheduling stakeholder meetings, presentations, and opportunities for 
engagement and feedback with the goal of making its remaining Co-Located Load 
compliance filing and one or more FPA section 205 filings to address the requirements in 
the orders by mid-November. 
III. 
REQUEST FOR SHORTENED ANSWER PERIOD AND EXPEDITED 
TREATMENT 
PJM respectfully requests that the Commission shorten the answer period for this 
motion to five days and grant expedited treatment to issue an order ruling on the abeyance 
motion within ten days, by August 6, 2026.  Although Rule 213(d)(1) generally allows 
 
34 See, e.g., Sw. Power Pool, Inc., Notice Granting Motion to Hold Proceeding in Abeyance, Docket No. 
EL22-65-000 (Jan. 31, 2024) (holding show cause proceedings in abeyance pending stakeholder process to 
resolve show cause proceedings via a section 205 filing); see also PJM Interconnection, L.L.C., 171 FERC 
¶ 61,015, at P 34 (2020) (holding a paper hearing proceeding in abeyance to allow stakeholder discussions 
to continue); Midcontinent Indep. Sys. Operator, Inc., 161 FERC ¶ 61,057, at P 44 (2017) (same); Sw. Power 
Pool, Inc., 161 FERC ¶ 61,062, at P 33 (2017) (same).

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fifteen days to answer a motion,35 the Commission may shorten the answer period or 
eliminate it all together for good cause shown.36  Good cause exists to shorten the answer 
period and grant expedited treatment given the Large Load Order’s fast approaching 
compliance deadline. 
First, shortening the answer period will promote regulatory certainty.  The Large 
Load Order directed PJM to respond to the range of issues identified within sixty days.37  
Absent further Commission action, PJM’s response to the Large Load Order is due August 
17, 2026, which is less than twenty-one days from the date of this motion’s filing.  If the 
Commission allows for a full fifteen-day answer period, PJM will not have clarity on 
whether the deadline applies until shortly before the due date, and PJM will need to devote 
resources towards preparing the responsive filing and not to the FPA section 205 filing.  
Moreover, there is heightened uncertainty surrounding an abeyance request in this case 
given that the Commission emphasized that it will not grant such requests reflexively.38  
Thus, a shortened answer period and expedited treatment is appropriate to give PJM 
certainty in advance of the deadline. 
Second, any interested person or entity should be in a position to respond to this 
motion quickly because the Commission specifically contemplated the potential for such 
requests in the Large Load Order.39  Indeed, the Commission directed that any such 
requests be made within forty-five days of the issuance of the order to give the Commission 
 
35 18 C.F.R. § 385.213(d)(1). 
36 See id.  
37 See supra note 12. 
38 Large Load Order at P 39. 
39 Id.

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adequate time to act on the request.40  Given this timing directive (i.e., that abeyance 
requests could be made up to fifteen days before the deadline), anyone with an interest in 
this proceeding should have been on notice regarding the need to respond on an expedited 
basis. 
Finally, as noted above, PJM is also seeking a coincident ninety-day extension of 
certain overlapping compliance obligations from the Compliance Order.41  Because the 
answer to that motion and the request to shorten the answer period here will both be due 
within five days unless the Commission otherwise orders,42 granting this request for a 
shortened answer period will promote administrative efficiency by allowing the 
Commission to rule on these related requests at the same time. 
IV. 
CONCLUSION 
For the reasons set forth above, PJM respectfully requests that the Commission 
(i) grant this motion to hold this proceeding in abeyance for a period of ninety days starting 
August 17, 2026, to allow PJM time to develop, with stakeholder engagement, and submit 
an FPA section 205 filing to address the issues identified in the Large Load Order; (ii) 
shorten the answer period to five days; and (iii) grant expedited consideration to issue an 
order on this motion within ten days by August 6, 2026. 
 
40 Id. 
41 See supra note 333. 
42 18 C.F.R. § 385.213(d)(1)(i).

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       Respectfully submitted,  
 
 
 
 
 
        /s/Ruth M. Porter  
Craig Glazer 
Vice President – Federal Government Policy 
PJM Interconnection, L.L.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
(202) 423-4743 
(202) 393-7741 
craig.glazer@pjm.com 
Wendy B. Warren 
Ruth M. Porter 
Wright & Talisman, P.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
(202) 393-1200 
(202) 393-1240 
warren@wrightlaw.com 
porter@wrightlaw.com     
 
Mark Stanisz 
Associate General Counsel 
PJM Interconnection, L.L.C.  
2750 Monroe Blvd. 
Audubon, PA 19403 
(610) 666-4707 
Mark.Stanisz@pjm.com 
 
 
 
 
 
Counsel for 
PJM Interconnection, L.L.C.
 
 
Dated: July 28, 2026

CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each 
person designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Washington, D.C., this 28th day of July 2026. 
/s/ Ruth M. Porter 
 
Ruth M. Porter 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
(202) 393-1200 
 
Attorney for PJM Interconnection, L.L.C.