PJM answers comments and protests about interim resource adequacy service
Read topic-matched comments in ER26-3515
Topics in the text: Registry access · Reliability and curtailment · Cost allocation
Responses and related views
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Source sections
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Opening text
opening text · Topic match: Cost allocation
Except for in reference to the “NEDC/PJM Governors’ Principles,” reference herein to the PJM states shall include the 13 state signatories and the District of Columbia. 4 Ratepayer Protection Pledge, The White House (Mar. 4, 2026), https://www.whitehouse.gov/releases/…Read this passage Filed comments: Cost allocation
I. ANSWER
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I.Read this passage
A. There Is Overwhelming Support for PJM’s Proposed Large Load
printed heading · Topic match: Registry access
Regardless, PJM disputes EKPC’s characterization as there was indeed broad support for a registry as evidenced in the August 13 Filing. 28 PA PUC Comments at 7; OPSI Comments and Request for Clarification or to Sever at 7. 29 August 13 Filing, Transmittal Letter at 28 (citing proposed RAA, Schedule…Read this passage Filed comments: Registry access
B. PJM’s Proposed Definition of Large Load Is Consistent with Commission
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Given the reliability and operational purposes of the Large Load Registry, PJM must have visibility into all Large Loads for registry purposes to ensure reliability and facilitate proper planning for the region, and existing Large Loads should be treated no differently. 50 IMM Comments at 29-31. 51…Read this passage Filed comments: Registry access
C. There Is Widespread Support to Establish a Policy that New Large Loads
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See August 13 Filing, Affidavit of Christopher Pilong on Behalf of PJM Interconnection, L.L.C. (Attachment C) ¶ 12 (“Pilong Aff.”). 59 See August 13 Filing, Transmittal Letter at 4-5. 60 Ratepayer Protection Pledge. 61 See Ratepayer Protection Pledge Announcement; July 2026 Ratepayer Protection…Read this passage Filed comments: Cost allocation
D. IRAS Divides Authority over Responses to an Interim Resource Adequacy
printed heading · Topic match: Reliability and curtailment
PJM will not direct reductions to specific New Large Loads pursuant to IRAS.”92 However, it is worth noting that, following PJM’s August 13 Filing, the Commission, in Tri-State Generation and Transmission Association, Inc. (“Tri-State”), shed to areas with concentrations of non-capacity backed new…Read this passage Filed comments: Reliability and curtailment
E. Calling for IRAS Load Reductions Before Pre-Emergency Load
printed heading · Topic match: Reliability and curtailment
OPSI, NJ BPU, the Pennsylvania Governor’s Office, Ohio FEA, and Ohio ELC each express strong support for PJM’s proposed placement of IRAS within the sequence of PJM’s operational tools for addressing emergency conditions.122 These entities recognize that PJM’s proposal: • “appropriately places the…Read this passage Filed comments: Reliability and curtailment
F. PJM’s BYONC Rules Appropriately Incent the Development of New
printed heading · Topic match: Reliability and curtailment
Electric Power Supply Association (“EPSA”) and others representing the interests of existing generators contend that the rule that New Large Loads must contract with new capacity to address their resource adequacy needs is unduly discriminatory against existing Capacity Resources.163 In other…Read this passage Filed comments: Reliability and curtailment
G. Excluding New Large Loads from the VRR Curve Until They Bring New
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The DCC claims that PJM “cannot expect new supply resources to appear if the price signals sent by the market do not reflect—as will be the case under PJM’s IRAS proposal--the actual load that must be served in the region.”182 The DCC completely ignores that the New Large Loads (many of which may…Read this passage Filed comments: Cost allocation
H. The IRAS Compensation Mechanism Benefits Ratepayers, Adheres to
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The IRAS Compensation Mechanism Benefits Ratepayers, Adheres to Cost Causation Principles, and Reflects a Division of Labor that Respects States’ Jurisdictional Authority over Retail Customers and Rates.Read this passage Filed comments: Cost allocation
I. IRAS Does Not Unduly Discriminate Against New Large Loads.
printed heading · Topic match: Reliability and curtailment
By definition, FRR Entities must bring new capacity for all new loads within their territory.226 If an FRR Entity does not include sufficient capacity in its FRR Capacity Plan, the FRR Entity is subject to “an FRR Commitment Insufficiency Charge, in an amount equal to two times the Cost of New…Read this passage Filed comments: Reliability and curtailment
II. CONCLUSION
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II.Read this passage
CONCLUSION
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CONCLUSION PJM asks that the Commission consider this answer and accept the Tariff and RAA revisions proposed in this proceeding, effective October 12, 2026, as requested.Read this passage Filed comments: Registry access
CERTIFICATE OF SERVICE
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Dated at Washington, D.C., this 23rd day of September 2026. /s/ Ryan J.Read this passage