Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Credit and exit · Reliability and curtailment
PDF p. 1
we accept the proposed RBP for filing, suspend it for five months, effective February 28, 2027, subject to refund, and establish a paper hearing PDF p. 1
PDF p. 9
Aside from the three issues discussed directly below, we find that the other aspects of PJM’s RBP proposal are just and reasonable PDF p. 9
PDF p. 7
the RBP aims to procure capacity equal to the 6,831 MW shortfall in the 2028/2029 BRA (Initial RBP Target) PDF p. 7
PDF p. 7
for a fixed term of up to 15 years, starting with the 2028/2029 delivery year at the earliest and ending no later than the 2042/2043 delivery year PDF p. 7
PDF p. 31
we disagree with JCA that PJM unreasonably requires commitment terms ending no earlier than 2042/2043 PDF p. 31
PDF p. 29
we find that PJM has shown that its proposed $555/MW-day maximum willingness to pay and process for selecting RBP Resources in the RBP auction are just and reasonable PDF p. 29
PDF p. 30
We agree with PJM that the proposed pay-as-bid structure for the RBP auction is reasonable. PDF p. 30
PDF p. 20
We agree with PJM that the proposed cap represents a reasonable balance between providing sellers with flexibility and managing UCAP risk for load. PDF p. 20
PDF p. 33
RBP shortfall charges are equal to the product of the RBP Resource’s committed RBP UCAP MW shortfall and 20% of the RBP price. PDF p. 33
PDF p. 63
we agree with concerns in the record that relying on Load Adjustments to measure load growth may be inconsistent or not reasonably capture forecasted load growth or actual large load growth PDF p. 63
PDF p. 63
it appears some large loads may never have been accounted for as Load Adjustments because PJM accounted for them when calculating the initial load forecast PDF p. 63
PDF p. 64
PJM could base the RBP allocation on the difference between the actual load for 2026/2027 delivery year in each Electric Distributor zone/area with the most recent 2028/2029 delivery year load forecast PDF p. 64
PDF p. 62
We find that PJM’s proposed opt-out for qualifying cooperatives and municipal utilities may be unjust, unreasonable, and unduly discriminatory. PDF p. 62
PDF p. 62
Because cooperatives and municipal utilities serve large loads that are similarly situated to large loads served by other LSEs PDF p. 62
PDF p. 62
we find that FRR Entities have not contributed towards the resource adequacy gap that the RBP will address PDF p. 62Filed comments: Reliability and curtailment
PDF p. 65
states determine how Commission-approved rates are collected among the relevant retail consumers along with the rates for state-jurisdictional matters PDF p. 65
PDF p. 65
Our partners in the states are more than capable of ensuring that these promises reach fruition. PDF p. 65
PDF p. 73
we find that PJM’s proposed exit provisions may be unjust and unreasonable because they would assess RBP Charges to exiting Transmission Owners, rather than the LSEs in the relevant Transmission Owner’s zone PDF p. 73Filed comments: Cost allocation
PDF p. 82
PJM does not support its 50% estimate with any quantitative measures, including an expected probability of default PDF p. 82
PDF p. 81
we find PJM’s proposed collateral requirements for RBP Sellers just and reasonable PDF p. 81Filed comments: Credit and exit
PDF p. 12
We therefore conclude on a preliminary basis that the existing Reliability Backstop Auction Tariff provisions may be unjust and unreasonable. PDF p. 12
PDF p. 9
we anticipate that the 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 PDF p. 9Filed comments: Filing procedure
PDF p. 10
We anticipate that, following the paper hearing, the Commission may need to direct significant modifications to certain aspects of PJM’s proposal PDF p. 10
PDF p. 3
The 2027/2028 BRA, which cleared at the temporary price cap of $333.44/MW-day, was the third BRA in a row to clear at historically high prices. PDF p. 3
Chairman Laura Swett · Direct response
Swett said the original procurement arrived too late for a deficiency letter or further evidence. She urged a prompt section 205 filing to repair the rejected terms. Her September concurrence did not address the later timetable.
PDF p. 92, Swett concurrenceCommissioner David Rosner · Direct response
Rosner supported directing costs to zones whose data center growth drove the shortfall. He called on states to set retail tariffs, enforce collateral and decide curtailment priorities. He wanted a return to ordinary hedging and capacity procurement after the backstop.
PDF p. 93, Rosner concurrenceCommissioner Lindsay See · Direct response
See wanted dependable generation quickly but said the first proposal left existing customers exposed. Better evidence about which projects will actually connect should guide who pays for the resulting capacity.
PDF p. 94, See concurrenceCommissioner David LaCerte · Direct response
LaCerte urged PJM to refile promptly rather than wait for more briefs. He said new loads should pay for the capacity they require and cited the commitment to build, bring or buy that capacity.
PDF pp. 96–97, LaCerte concurrencePrinted headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Reliability and curtailment
The RBP is a one-time procurement of new capacity to address significant resource adequacy challenges primarily driven by an influx of large loads.3 As discussed below, we accept the proposed RBP for filing, suspend it for five months, effective February 28, 2027, subject to refund, and establish a…Read this passage Filed comments: Reliability and curtailment
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I.Read this passage
printed heading · Topic match: Cost allocation
Despite these differences, many of the core components of the two proposals were the same, including resource commitments up to the 2042/2043 delivery year, requiring a resource in-service date by the 2032/2033 delivery year, a must-offer RPM requirement with contracts for differences, and similar…Read this passage Filed comments: Cost allocation
printed heading · Topic match: Cost allocation
Pursuant to the proposed Tariff provisions, new load is load that has an executed electric service agreement or transmission service agreement indicating that the load will come online during the 2027/2028 or 2028/2029 delivery year.28 To avoid double procurement, PJM proposes to require all…Read this passage Filed comments: Cost allocation
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Notice of Filing and Responsive Pleadings Notice of PJM’s filing was published in the Federal Register, 91 Fed.Read this passage
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IV.Read this passage
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DiscussionRead this passage
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We accept the answers filed by AEP, the Kentucky Attorney General, EKPC, the Market Monitor, NJBPU, NOVEC, Voltus, PJM, P3, Constellation, PPL, Indicated PJM TOs, and FirstEnergy because they have provided information that assisted us in our decision-making process.Read this passage
printed heading · Topic match: Cost allocation
In response, NOVEC maintains PJM’s proposal does require suppliers to provide duplicative collateral because PJM proposes to determine RBP collateral obligations as if suppliers were paying the entire RBP Charge—which means suppliers are providing collateral for the cost of capacity of their RBP MW…Read this passage Filed comments: Cost allocation