ER26-3380-000 · 2026-10-12 · PJM
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
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UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
PJM Interconnection, L.L.C.
)
Docket Nos. ER26-3380-000
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EL26-108-000
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MOTION FOR ABEYANCE OF
PJM INTERCONNECTION, L.L.C.
Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“Commission”)
Rules of Practice and Procedure,1 PJM Interconnection, L.L.C. (“PJM”) respectfully requests that
the Commission hold the paper hearing proceedings, including any additional briefings, in this
docket in abeyance pending resolution of PJM’s forthcoming filing that will be submitted under
section 205 of the Federal Power Act (“FPA”) addressing the issues raised in the Commission’s
September 29 Order.2
In the September 29 Order, the Commission accepted PJM’s proposed reliability backstop
procurement (“RBP”) rules, but suspended those rules for five months to allow time for further
briefing through a paper hearing process to further review three discrete areas of the RBP: cost
allocation, Transmission Owner exit rules, and LSE collateral requirements.3 While the
Commission established additional paper hearing procedures and a separate proceeding under
section 206 of the FPA in its September 29 Order, the Commission “strongly encourage[d] PJM
to address the issues discussed in [the] order by submitting an alternative proposal pursuant to its
FPA section 205 filing rights without delay.”4 The September 29 Order further explained that “the
1 18 C.F.R. § 385.212.
2 PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“September 29 Order”).
3 Id. at P 24.
4 Id. at P 28.
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Commission would grant a motion to hold that briefing in this proceeding in abeyance if PJM
submitted a new section 205 filing within 30 days from the date of this order.”5
In accordance with the Commission’s September 29 Order, and to help expedite a
resolution of the remaining issues identified by the Commission, PJM plans to submit a new FPA
section 205 filing that addresses, inter alia, cost allocation issues, Transmission Owner exit
responsibilities, and LSE collateral requirements as they relate to RBP by October 29, 2026. To
that end, PJM has scheduled a special Members Committee and a special Transmission Owners
Agreement – Administrative Committee meeting on October 22, 2026 to provide the requisite
consultation with the PJM Members Committee and Transmission Owners of the new FPA section
205 filing in accordance with Tariff, section 9.2(b) and the Consolidated Transmission Owners
Agreement, section 7.5.1(ii), respectively.
Filing this motion for abeyance at this time allows the Commission to timely consider this
request and grant the abeyance so that interested parties can focus efforts on the upcoming section
205 filing rather than having to separately prepare for the paper hearing briefing under the current
timelines specified in the September 29 Order. For these reasons, the Commission should
expeditiously grant this motion to hold the paper hearing proceedings in abeyance.
5 Id. at PP 24 and 160.
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Respectfully submitted,
/s/ Chenchao Lu
Craig Glazer
Vice President – Federal Government Policy
PJM Interconnection, L.L.C.
1200 G Street, N.W.
Suite 600
Washington, D.C. 20005
(202) 423-4743
Craig.Glazer@pjm.com
Chenchao Lu
Associate General Counsel
PJM Interconnection, L.L.C.
2750 Monroe Boulevard
Audubon, PA 19403
(610) 666-2255
Chenchao.Lu@pjm.com
On behalf of
PJM Interconnection, L.L.C.
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CERTIFICATE OF SERVICE
I hereby certify that I have on this 12th day of October served a copy of the foregoing
upon all parties on the service list in these proceedings in accordance with the requirements of
Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.2010.
/s/ Chenchao Lu
Chenchao Lu
Associate General Counsel
PJM Interconnection, L.L.C.
2750 Monroe Boulevard
Audubon, PA 19403