Motion for Leave to Answer and Answer of PJM Interconnection, L.L.C. to the limited protests of its August 17, 2026 compliance filing (EL25-49 and ER26-1479)
Read topic-matched comments in EL25-49
Topics in the text: Reliability and curtailment · Connecting load and generation · Filing procedure
What the document says
PDF p. 2
Constellation called July 2028 unsupported; PJM answers that Interim NITS needs new automation.
in the August Filing is unsupported and neglects to give “serious consideration” to more expedited implementation. PDF p. 2
PDF p. 3
Constellation called July 2028 unsupported; PJM answers that Interim NITS needs new automation.
IRAS was proposed to be implemented on an aggregate, zonal basis using largely existing tools, whereas Interim NITS curtailment will occur on an individual transmission service request basis and requires entirely new tools and automation. PDF p. 3Filed comments: Reliability and curtailment
PDF p. 3
PJM now expects to accept Interim NITS requests from September 2027.
Currently, PJM anticipates modifying the systems needed to begin accepting requests for the new transmission services in September of 2027. PDF p. 3
PDF p. 3
PJM now expects to accept Interim NITS requests from September 2027.
PJM is developing a proposal for a new a study process that would evaluate large loads and generation interconnection requests together in a unified cluster study that would take roughly a year to complete PDF p. 3
PDF p. 4
PJM rejects Constellation's other asks: studies repeat only on scope change; service stays interruptible.
While PJM will not repeat studies already performed, project scope or other technical changes may trigger the need for additional study. PDF p. 4
PDF p. 5
PJM rejects Constellation's other asks: studies repeat only on scope change; service stays interruptible.
Interim NITS is such a service, as customers must be able to limit their withdrawals from the system consistent with the existing system limits PDF p. 5
PDF p. 5
PJM rejects Constellation's other asks: studies repeat only on scope change; service stays interruptible.
the August Filing specified that Interim NITS will be interruptible and curtailed before firm services like Firm Contract Demand Service or NITS that are capacity-backed services PDF p. 5
PDF p. 6
PJM rejects Constellation's other asks: studies repeat only on scope change; service stays interruptible.
PJM clarifies that this is existing NITS under Part III of the Tariff. PDF p. 6
PDF p. 6
PJM says Amtrak and industrial customers fear losing netting, but PJM proposed no such restriction.
National Railroad Passenger Corporation (“Amtrak”) and various industrial customers express concern that the definitions PJM proposed may somehow disqualify industrial customers that sell surplus energy to the grid from netting their load PDF p. 6
PDF p. 6
PJM says Amtrak and industrial customers fear losing netting, but PJM proposed no such restriction.
PJM has proposed no such restriction nor does it intend to include such a restriction in its upcoming compliance filing. PDF p. 6
PDF p. 7
PJM says Amtrak and industrial customers fear losing netting, but PJM proposed no such restriction.
PJM intends to propose clarifications to the definition of BTMG in the November compliance filing to specify that load with BTMG is excluded from the definition of Co-Located Load. PDF p. 7Filed comments: Connecting load and generation
PDF p. 7
PJM accepts AMP's fix so non-retail behind-the-meter generation can use the services.
American Municipal Power, Inc.’s (“AMP”) limited protest avers that the proposed definition of an “Eligible Generating Facility” may disqualify Non-Retail BTMG from qualifying for use of the new transmission services. PDF p. 7
PDF p. 7
PJM accepts AMP's fix so non-retail behind-the-meter generation can use the services.
Accordingly, PJM, does not object to AMP’s proposed revision to Eligible Generating Facility definition set forth in its pleading PDF p. 7
PDF p. 2
PJM asks FERC to accept the answer and consider deferring October 17 changes.
it may be appropriate for the Commission to defer consideration of these issues until it has the benefit of a complete record following next month’s compliance filing. PDF p. 2
PDF p. 8
PJM asks FERC to accept the answer and consider deferring October 17 changes.
PJM requests that the Commission grant PJM’s motion for leave to answer and accept the foregoing answer and affidavit. PDF p. 8
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
PJM respectfully requests that the Commission grant its Motion because the Answer will help clarify the record and contribute to an understanding of the issues. 3 PJM Interconnection, L.L.C., Compliance Filing of PJM Interconnection, L.L.C. in Response to Order on Rehearing, Clarification,…Read this passage
I. ANSWER
printed heading
I.Read this passage
A. PJM’s Proposed Effective Date for Interim NITS
printed heading · Topic match: Reliability and curtailment
As more fully explained in the Affidavit of Christopher Pilong provided herewith as Attachment A, providing Interim NITS with the assistance of automation will require PJM to make significant modifications to its forecasts, operations, markets, and settlement systems.8 PJM anticipates significant…Read this passage Filed comments: Reliability and curtailment
B. Necessary Study Process
printed heading · Topic match: Connecting load and generation
Necessary Study Process Constellation asks the Commission to order PJM to clarify that Necessary Studies need not be repeated where the scope of the previously conducted study has not changed.17 As Constellation notes, however, the Commission clarified in the June Hearing Order that the scope of…Read this passage Filed comments: Connecting load and generation
C. Transmission Owner Technical Requirements
printed heading
The June Hearing Order clarified that the provision of any new transmission service must be compliant with 15 See id. 16 Pilong Aff. at ¶¶ 5, 9. 17 Constellation Limited Protest at 5. 18 Id. (citing PJM Interconnection, L.L.C., 195 FERC ¶ 61,209, at P 283 (2026) (“June Hearing Order”)). 19…Read this passage
D. Interim NITS And Resource Adequacy
printed heading · Topic match: Reliability and curtailment
Interim NITS And Resource Adequacy Constellation expresses concern that PJM will limit the provision of Interim NITS due to resource adequacy considerations.22 That is not the case.Read this passage Filed comments: Reliability and curtailment
E. Partial NITS
printed heading
Partial NITS Constellation seeks clarification regarding the statement in the August Filing concerning the provision of partial NITS (i.e., NITS in an amount less than requested or for a term shorter than requested).27 PJM clarifies that this is existing NITS under Part III of the Tariff.Read this passage
F. Behind The Meter Generation (“BTMG”) Issues
printed heading · Topic match: Connecting load and generation
An Interconnection Service Agreement does not disqualify from netting.Read this passage Filed comments: Connecting load and generation
II. CONCLUSION
printed heading
II.Read this passage
CONCLUSION
printed heading
CONCLUSION Based on the foregoing, PJM requests that the Commission grant PJM’s motion for leave to answer and accept the foregoing answer and affidavit.Read this passage
CERTIFICATE OF SERVICE
printed heading
Dated at Washington, DC on this 14th day of October 2026. /s/ Ruth M.Read this passage
Attachment A
printed heading · Topic match: Reliability and curtailment
Providing Interim NITS on an automated basis involves introducing a new operational status that must remain consistent across planning, market, scheduling, outage, reliability, dispatch, settlement, and customer-facing processes.Read this passage Filed comments: Reliability and curtailment
I. OPERATIONAL DESIGN AND PROCEDURE CHANGES
printed heading · Topic match: Reliability and curtailment
Procedures must work during normal operations, constrained operations, emergencies, restoration, and periods when communications or applications are degraded. 8.Read this passage Filed comments: Reliability and curtailment
II. COORDINATION WITH TRANSMISSION OWNERS, GENERATION
printed heading · Topic match: Reliability and curtailment
Where a curtailment is intended to relieve a local or regional constraint, PJM and the affected Transmission Owner must agree on the relevant monitored facilities, contingencies, expected distribution factors, validation method, and restoration criteria. 11.Read this passage Filed comments: Reliability and curtailment
III. TOOL AND SYSTEM IMPACTS
printed heading · Topic match: Reliability and curtailment
For each relevant interval, PJM should be able to reconstruct the authorized service level, transmission conditions, applicable curtailment priority, notices sent, operator actions, customer response, market results, and settlement treatment.Read this passage Filed comments: Reliability and curtailment
IV. MARKET CLEARING, RELIABILITY AND SETTLEMENT IMPACTS
printed heading · Topic match: Reliability and curtailment
The treatment must be internally consistent and understandable to market participants.Read this passage Filed comments: Reliability and curtailment
V. IMPLEMENTATION SCHEDULE
printed heading · Topic match: Reliability and curtailment
Interpret the order; identify affected tariff, manual, agreement, and reliability provisions; resolve ambiguities; define eligibility, priority, curtailment, restoration, data, and settlement rules; establish governance and implementation scope. ii.Read this passage Filed comments: Reliability and curtailment
VI. DIFFERENCES FROM IRAS IMPLEMENTATION
printed heading · Topic match: Reliability and curtailment
Moreover, to do so, PJM must determine a range of implementation details including how Interim NITS will be represented in the Day-Ahead load forecast, whether curtailment limitations affect demand bid treatment, and how transmission service restrictions impact commitment decisions.Read this passage Filed comments: Reliability and curtailment
VII. CONCLUSION
printed heading
VII.Read this passage
CONCLUSION
printed heading · Topic match: Reliability and curtailment
The work must proceed from a stable service definition and must include integrated testing under normal, constrained, emergency, and degraded-tool conditions. 42.Read this passage Filed comments: Reliability and curtailment