Request for Rehearing and Clarification of Constellation Energy Generation, LLC
Read topic-matched comments in ER26-3380
Topics in the text: Filing procedure · Credit and exit · Reliability and curtailment
What the document says
PDF p. 17
Clarification: an exiting TO should bear exit costs, and FERC has not presumed LSEs must pay.
Constellation seeks clarification that the Order neither established a presumption that LSEs in an exiting Transmission Owner’s zone must bear RBP exit charges nor predetermined the allocation of such charges. PDF p. 17
PDF p. 17
Clarification: an exiting TO should bear exit costs, and FERC has not presumed LSEs must pay.
An exiting Transmission Owner should bear its appropriate cost burden of generation and load investments made under the assumption that the Transmission Owner would remain in PJM. PDF p. 17
PDF p. 14
Price-taker RBP supply suppresses RPM prices and weakens entry signals for 15 years.
The resulting signal can reduce retention and entry incentives, accelerate resource exit, and defer new investment in the region. PDF p. 14
PDF p. 12
RMR precedent cannot justify price-taker treatment of 6,831 MW for 15 years.
Characterizing the arrangements at that level of generality does not explain why their material differences are irrelevant, or why, in this instance, the price-taker requirement is just and reasonable. PDF p. 12
PDF p. 14
FERC ignored Constellation's isolation mechanism, which avoids double procurement without zero-price offers.
The mechanism therefore prevents duplicate procurement for the matched quantity by adjusting both supply and demand, while avoiding the one-sided price-forming effect of mandatory zero offers. PDF p. 14
PDF p. 2
Energy-only plants like Eddystone should qualify as RBP Resources after obtaining new CIRs.
paragraph 51 rejected—without reasoned analysis—Constellation’s request to permit energy-only resources obtaining new capacity rights PDF p. 2
PDF p. 10
Energy-only plants like Eddystone should qualify as RBP Resources after obtaining new CIRs.
The Order expressly recited Constellation’s request that Energy Resources obtaining new CIRs be eligible to provide Qualifying RBP Offset UCAP MW, but never decided it. PDF p. 10
PDF p. 18
Constellation agrees Load Adjustments may miss large loads and wants current, validated forecasts used.
The Order correctly found that reliance on PJM’s Load Adjustment process may fail to capture actual or forecast large-load growth PDF p. 18
PDF p. 19
Constellation agrees Load Adjustments may miss large loads and wants current, validated forecasts used.
Any replacement methodology must use current, project-specific, PJM-validated and auditable information; identify and eliminate double counting associated with duplicate or alternative-site requests PDF p. 19
PDF p. 16
Clarification: the collateral paper hearing should cover credit rate size, overlapping collateral and release standards.
Constellation requests clarification that the paper-hearing inquiry into “appropriate collateral requirements for RBP buyers” encompasses: (1) the size and methodology of the RBP Credit Rate; PDF p. 16Filed comments: Credit and exit
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Opening text
opening text · Topic match: Filing procedure
ER26-3380-000 EL26-108-000 REQUEST FOR REHEARING AND CLARIFICATION OF CONSTELLATION ENERGY GENERATION, LLC Pursuant to Section 313 of the Federal Power Act (“FPA”)1 and Rule 713 of the Federal Energy Regulatory Commission (“Commission”) Rules of Practice and Procedure,2 Constellation Energy…Read this passage Filed comments: Filing procedure
BACKGROUND
printed heading · Topic match: Filing procedure
Shanker’s expert affidavit,9 or (ii) engaging in a reasoned balancing analysis, instead pointing to certain reliability-must-run resource arrangements to justify imposing zero- Answer”); PJM Interconnection, L.L.C., Motion for Leave to Answer and Answer of Constellation Energy Generation, LLC,…Read this passage Filed comments: Filing procedure
A. The Commission Erred in Rejecting Constellation’s Proposed Eligibility Revisions for RBP Resources and Resources Eligible to Supply Qualifying RBP Offset UCAP MW
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The Commission Erred in Rejecting Constellation’s Proposed Eligibility Revisions for RBP Resources and Resources Eligible to Supply Qualifying RBP Offset UCAP MW Constellation requested12 that the Commission require PJM to modify the criteria set forth in the RBP Proposal so that resources like…Read this passage
(i) Composed of new Installed Capacity and new Maximum Facility Output;
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(i) Composed of new Installed Capacity and new Maximum Facility Output;Read this passage
(ii) Supported by new Capacity Interconnection Rights (if located in the PJM Region) or Capacity Interconnection Rights transferred from a deactivated resource or a resource that announced deactivation as of April 10, 2026; and
PDF bookmark · Topic match: Cost allocation
Eddystone is now an Energy Resource with no capacity rights.17 To return as a Capacity Resource, Eddystone must reenter the interconnection queue, obtain new CIRs, and bear any required Network Upgrade costs.Read this passage Filed comments: Cost allocation
B. The Commission Did Not Justify Mandatory Price-Taker Treatment
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The Commission Did Not Justify Mandatory Price-Taker TreatmentRead this passage
1. The Commission Failed to Engage in a Reasoned Balancing Analysis
PDF bookmark · Topic match: Reliability and curtailment
Those distinctions concern the very factors the Commission has considered when balancing the reliability rationale for out-of-market support against its effect on market price formation and the potential impacts on resource adequacy in the long-term: purpose, magnitude, duration, and certainty of…Read this passage Filed comments: Reliability and curtailment
2. The Order Did Not Address the Matched Isolation Mechanism, Which Was Supported by Expert Testimony
PDF bookmark · Topic match: Reliability and curtailment
PJM suggested that RBP resources must be offered into RPM as a price-taker to ensure load does not “double pay” for capacity.Read this passage Filed comments: Reliability and curtailment
C. In an Abundance of Caution, the Commission Should Clarify the Scope of the Paper Hearings
PDF bookmark · Topic match: Filing procedure
Because paragraphs 159, 181, and 206 identify potential replacement approaches without finally adopting them, Constellation requests clarification that the full scope of the issues described below remains open.Read this passage Filed comments: Filing procedure
1. Scope of the LSE Collateral Paper Hearing
PDF bookmark · Topic match: Credit and exit
Scope of the LSE Collateral Paper Hearing In its Order, the Commission found that the proposed RBP collateral requirements for LSEs may be unjust and unreasonable, and set the issue for paper hearing.44 Constellation requests clarification that the paper-hearing inquiry into “appropriate collateral…Read this passage Filed comments: Credit and exit
2. Scope of the Transmission Owner Exit Rules Paper Hearing
PDF bookmark · Topic match: Filing procedure
Constellation seeks clarification that the Order neither established a presumption that LSEs in an exiting Transmission Owner’s zone must bear RBP exit charges nor predetermined the allocation of such charges.Read this passage Filed comments: Filing procedure
3. Scope of Cost Allocation Paper Hearing
PDF bookmark · Topic match: Cost allocation
The forecast used to establish the procurement target and the data used to allocate costs must be consistent or expressly reconciled.Read this passage Filed comments: Cost allocation
CONCLUSION
printed heading · Topic match: Filing procedure
Clarify that paragraphs 181–182 establish no presumption that LSEs must bear Transmission Owner exit charges and that incremental exit-caused costs require a separate cost- causation analysis; and 5.Read this passage Filed comments: Filing procedure
CERTIFICATE OF SERVICE
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Dated at Washington, D.C. this 29 day of October 2026. /s/ Alexandra K.Read this passage