{"document":{"slug":"motion-er26-3380-pjm-abeyance","title":"Motion for Abeyance of PJM Interconnection, L.L.C. (ER26-3380-000 and EL26-108-000), holding the backstop paper hearing pending a new section 205 filing","issued":"2026-10-12","accession":"20261013-5141","docket":"ER26-3380-000","group":"PJM Reliability Backstop Procurement","filer":"PJM","kind":"motion for abeyance","file":"sources/originals/20261013-5141_20261012-el26-108-000.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261013-5141","sha256":"0926b57053a561149237e068f356f7e1e9d72e38d63860b7b1ecd730ff391609","pages":4,"tokens":614,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":245,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n  \n \n \n) \nPJM Interconnection, L.L.C. \n) \n \n \nDocket Nos. ER26-3380-000 \n \n \n \n) \n \n \n \n \nEL26-108-000 \n \n \n \n) \n \n \nMOTION FOR ABEYANCE OF  \nPJM INTERCONNECTION, L.L.C.  \n  \nPursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“Commission”) \nRules of Practice and Procedure,1 PJM Interconnection, L.L.C. (“PJM”) respectfully requests that \nthe Commission hold the paper hearing proceedings, including any additional briefings, in this \ndocket in abeyance pending resolution of PJM’s forthcoming filing that will be submitted under \nsection 205 of the Federal Power Act (“FPA”) addressing the issues raised in the Commission’s \nSeptember 29 Order.2   \nIn the September 29 Order, the Commission accepted PJM’s proposed reliability backstop \nprocurement (“RBP”) rules, but suspended those rules for five months to allow time for further \nbriefing through a paper hearing process to further review three discrete areas of the RBP: cost \nallocation, Transmission Owner exit rules, and LSE collateral requirements.3  While the \nCommission established additional paper hearing procedures and a separate proceeding under \nsection 206 of the FPA in its September 29 Order, the Commission “strongly encourage[d] PJM \nto address the issues discussed in [the] order by submitting an alternative proposal pursuant to its \nFPA section 205 filing rights without delay.”4  The September 29 Order further explained that “the \n \n1 18 C.F.R. § 385.212. \n2 PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“September 29 Order”). \n3 Id. at P 24. \n4 Id. at P 28."},{"page":2,"startToken":245,"endToken":476,"text":"2 \nCommission would grant a motion to hold that briefing in this proceeding in abeyance if PJM \nsubmitted a new section 205 filing within 30 days from the date of this order.”5 \nIn accordance with the Commission’s September 29 Order, and to help expedite a \nresolution of the remaining issues identified by the Commission, PJM plans to submit a new FPA \nsection 205 filing that addresses, inter alia, cost allocation issues, Transmission Owner exit \nresponsibilities, and LSE collateral requirements as they relate to RBP by October 29, 2026.  To \nthat end, PJM has scheduled a special Members Committee and a special Transmission Owners \nAgreement – Administrative Committee meeting on October 22, 2026 to provide the requisite \nconsultation with the PJM Members Committee and Transmission Owners of the new FPA section \n205 filing in accordance with Tariff, section 9.2(b) and the Consolidated Transmission Owners \nAgreement, section 7.5.1(ii), respectively.  \nFiling this motion for abeyance at this time allows the Commission to timely consider this \nrequest and grant the abeyance so that interested parties can focus efforts on the upcoming section \n205 filing rather than having to separately prepare for the paper hearing briefing under the current \ntimelines specified in the September 29 Order.  For these reasons, the Commission should \nexpeditiously grant this motion to hold the paper hearing proceedings in abeyance. \n \n \n5 Id. at PP 24 and 160."},{"page":3,"startToken":476,"endToken":541,"text":"3 \n \nRespectfully submitted, \n/s/ Chenchao Lu \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, N.W. \nSuite 600 \nWashington, D.C. 20005 \n(202) 423-4743 \nCraig.Glazer@pjm.com \n \nChenchao Lu \nAssociate General Counsel \nPJM Interconnection, L.L.C. \n2750 Monroe Boulevard \nAudubon, PA 19403 \n(610) 666-2255 \nChenchao.Lu@pjm.com \n \n \n \nOn behalf of \nPJM Interconnection, L.L.C."},{"page":4,"startToken":541,"endToken":614,"text":"4 \nCERTIFICATE OF SERVICE \nI hereby certify that I have on this 12th day of October served a copy of the foregoing \nupon all parties on the service list in these proceedings in accordance with the requirements of \nRule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.2010. \n/s/ Chenchao Lu \nChenchao Lu \nAssociate General Counsel \nPJM Interconnection, L.L.C. \n2750 Monroe Boulevard \nAudubon, PA 19403"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":4,"endAt":3,"startToken":0,"endToken":542},{"p":4,"at":3,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":4,"endAt":426,"startToken":542,"endToken":614}]}