Request for Rehearing and Clarification or Alternative Request for Rehearing of Northern Virginia Electric Cooperative, Inc.
Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Filing procedure · Reliability and curtailment
What the document says
PDF p. 17
FirstEnergy and NOVEC ask FERC to reject the procurement and replace it.
requests that the Commission grant its request for rehearing and require PJM to adopt the voluntary stakeholder framework. PDF p. 17Filed comments: Filing procedure
PDF p. 5
LSE collateral of $1.5 million per RBP MW is far above seller collateral.
the RBP Proposal is not just and reasonable because it imposes an unreasonable and excessive collateral obligation on RBP buyers PDF p. 5Filed comments: Credit and exit
PDF p. 3
The RBP should be the stakeholders' voluntary subscription model, with interruptible service as the alternative.
The PJM stakeholders proposed a voluntary framework for the RBP that recognized the contribution of load growth to the capacity shortfall without the issues attendant to PJM’s proposed RBP. PDF p. 3
PDF p. 5
The RBP should be the stakeholders' voluntary subscription model, with interruptible service as the alternative.
The Commission neglected to address NOVEC’s arguments that PJM should be required to adopt the voluntary, subscription-based model in lieu of the RBP Proposal. PDF p. 5
PDF p. 11
Charging only LSEs serving large loads is undue discrimination, contrary to the IRAS order.
The RBP constitutes undue discrimination against LSEs that serve large loads. PDF p. 11
PDF p. 12
Charging only LSEs serving large loads is undue discrimination, contrary to the IRAS order.
The Commission cannot simultaneously maintain two opposing, contrary points of view and yet meet its obligation to engage in reasoned decision-making. PDF p. 12
PDF p. 8
Price-taker RBP supply suppresses RPM prices and weakens entry signals for 15 years.
The RBP suppresses the capacity price, which is the result whenever some generation must bid into the market as price-takers. PDF p. 8
PDF p. 10
Price-taker RBP supply suppresses RPM prices and weakens entry signals for 15 years.
the Commission’s RMR precedent actually warrants rejection of the RBP due to the disproportionate, lasting impacts on the RPM’s ability to send accurate price signals. PDF p. 10
PDF p. 9
RMR precedent cannot justify price-taker treatment of 6,831 MW for 15 years.
The RBP is distinct as a matter of duration, exigency, and scale. PDF p. 9
PDF p. 16
NOVEC: the shortfall has other causes, so charging only large-load LSEs breaks cost causation.
Despite that fact, the RBP allocates all costs to LSEs serving large loads, a result inconsistent with the cost-causation principle. PDF p. 16
PDF p. 16
NOVEC: the shortfall has other causes, so charging only large-load LSEs breaks cost causation.
NOVEC and other RBP Buyers would be subsidizing the rest of the capacity market, a result that is not consistent with the cost-causation principle. PDF p. 16
PDF p. 13
Clarification: the cost-allocation paper hearing stays open to all methods, including NOVEC's causation arguments.
NOVEC respectfully requests that the Commission dispel any ambiguity as to the scope of the paper hearing and clarify that the Commission has set all issues concerning cost allocation for further procedures PDF p. 13Filed comments: Cost allocation
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
ER26-3380-000 EL26-108-000 ) REQUEST FOR REHEARING AND CLARIFICATION OR ALTERNATIVE REQUEST FOR REHEARING OF NORTHERN VIRGINIA ELECTRIC COOPERATIVE, INC.Read this passage Filed comments: Filing procedure
I. STATEMENT OF ISSUES AND SPECIFICATIONS OF ERROR
printed heading · Topic match: Cost allocation
If the Commission does not clarify that all aspects of the design for cost allocation of the RBP are within the scope of the paper hearing and that NOVEC is not foreclosed from advocating for alternative designs for cost allocation, the Commission erred by not addressing NOVEC’s arguments with…Read this passage Filed comments: Cost allocation
II. REQUEST FOR REHEARING AND REQUEST FOR CLARIFICATION OR
printed heading · Topic match: Filing procedure
REQUEST FOR REHEARING AND REQUEST FOR CLARIFICATION OR ALTERNATIVE REQUEST FOR REHEARINGRead this passage Filed comments: Filing procedure
A. The Commission should require PJM to adopt the voluntary stakeholder RBP
printed heading · Topic match: Cost allocation
To be just and reasonable, the RBP must include the ability to proactively and preemptively choose interruptible service rather than accept a capacity obligation.Read this passage Filed comments: Cost allocation
B. The RBP distorts the Reliability Pricing Model (“RPM”) price signals and unduly
printed heading · Topic match: Reliability and curtailment
For all other LSEs that are or will be providing retail service to large loads that materialize later than the forecasts on which PJM premised its RBP Proposal, there are no 23 PJM Business Practice Manual No. 18 at § 1.2.1 (“Under RPM, each LSE that serves load in a PJM Zone during the Delivery…Read this passage Filed comments: Reliability and curtailment
C. The Commission should clarify that all aspects of the RBP’s cost allocation are
printed heading · Topic match: Cost allocation
At the outset, the Commission’s order, if final for purposes of rehearing, is deficient under TANC because the Commission stated that it declined to “to further address arguments raised in the protests related to PJM’s proposed cost allocation method at this time.”49 The Commission must set aside…Read this passage Filed comments: Cost allocation
III. CONCLUSION
printed heading
III.Read this passage
CONCLUSION
printed heading · Topic match: Filing procedure
CONCLUSION WHEREFORE, for the foregoing reasons, NOVEC respectfully requests that the Commission grant its request for rehearing and require PJM to adopt the voluntary stakeholder framework.Read this passage Filed comments: Filing procedure
CERTIFICATE OF SERVICE
printed heading
Dated at Washington, D.C. this 29th day of October, 2026. //s// Jessika Dziechciowska Jessika Dziechciowska Energy Practice Analyst Washington Energy Law LLP 900 17th Street, N.W., Suite 500-A Washington, D.C. 20006 Tel: (202) 326-9308 Email: jdziechciowska@washingtonenergylaw.comRead this passage