Request for Rehearing of the Indicated PJM Transmission Owners of the September 29, 2026 backstop order (TO exit amendment)
Read topic-matched comments in ER26-3380
Topics in the text: Filing procedure · Cost allocation · Credit and exit
What the document says
PDF p. 5
FERC should have finally rejected the TO Exit Amendment on cost-causation grounds.
The Order’s preliminary conclusion that the Exit Amendment may violate cost-causation principles should have been stated finally and definitively, instead of being left open for decision after a paper hearing. PDF p. 5
PDF p. 6
FERC should have finally rejected the TO Exit Amendment on cost-causation grounds.
the Commission has found it just and reasonable to impose generation capacity costs on LSEs located within an exiting TO’s zone, not on the TO as such. PDF p. 6
PDF p. 7
PJM lacked section 205 authority to file the Exit Amendment over the TOs' CTOA rights.
PJM cannot avoid the CTOA’s amendment procedures by casting a change to the core terms of the CTOA as an amendment to the OATT, rather than to the CTOA. PDF p. 7
PDF p. 8
PJM lacked section 205 authority to file the Exit Amendment over the TOs' CTOA rights.
Because PJM failed to fulfill any of these procedural prerequisites, PJM exceeded its authority in unilaterally submitting the Exit Amendment as a section 205 filing. PDF p. 8
PDF p. 2
TOs and FirstEnergy seek rehearing mainly to preserve issues while PJM prepares a replacement filing.
The Indicated PJM Transmission Owners submit this rehearing request out of an abundance of caution to preserve their rights in this fast-moving and dynamic proceeding. PDF p. 2Filed comments: Filing procedure
Responses and related views
No section-specific public response is linked for this document.
Source sections
Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
Opening text
opening text · Topic match: Filing procedure
The FirstEnergy Transmission Companies are separately filing a rehearing request raising other issues. 5 See PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“Order”). 2 The Indicated PJM Transmission Owners are hopeful that PJM6 will submit a revised section 205 filing that supersedes its…Read this passage Filed comments: Filing procedure
I. Background
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I.Read this passage
BACKGROUND
printed heading · Topic match: Cost allocation
On September 29, 2026, the Commission issued its Order, accepting PJM’s RBP proposal for filing, “suspended for five months, effective February 28, 2027, subject to refund and the outcome of the further procedures ordered in this proceeding.”7 The Commission identified three aspects of PJM’s…Read this passage Filed comments: Cost allocation
II. Request for rehearing
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REQUEST FOR REHEARINGRead this passage Filed comments: Filing procedure
A. Statement of Issues and Specification of Errors
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Statement of Issues and Specification of Errors The Indicated PJM Transmission Owners submit the following Statement of Issues and Specification of Errors pursuant to Rule 713(c)(1)-(2) of the Commission’s Rules of Practice and Procedure.14 • The Order is erroneous, arbitrary and capricious, fails…Read this passage
B. Argument
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B.Read this passage
1. The Exit Amendment Violates Cost-Causation Principles
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Under cost-causation principles, rates must “reflect to some degree the costs actually caused by the customer who must pay for them,” and costs must be 6 allocated in a manner at least roughly commensurate with benefits.15 As the Order recognized, PJM proposes to procure RBP capacity “on behalf of…Read this passage Filed comments: Cost allocation
2. PJM Lacked Authority To File The Exit Amendment
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The Order did not adopt that modification; rather, it accepted the Exit Amendment as filed, anticipated that modifications may be directed after the paper hearing, and encouraged PJM to submit a new filing.29 The Commission should grant rehearing and hold that PJM lacked authority under section 205…Read this passage Filed comments: Filing procedure
III. CONCLUSION
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CONCLUSION
printed heading · Topic match: Filing procedure
CONCLUSION For the foregoing reasons, the Indicated PJM Transmission Owners respectfully request that the Commission grant rehearing of the Order and definitively reject PJM’s proposed Exit Amendment.Read this passage Filed comments: Filing procedure
CERTIFICATE OF SERVICE
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Dated at New York, N.Y., this 29th day of October, 2026. /s/ Sanford I.Read this passage