{"document":{"slug":"attachment-er27-454-d","title":"Attachment D - Danielle Croop Affidavit","issued":"2026-11-09","accession":"20261109-5216","docket":"ER27-454-000","group":"PJM Reliability Backstop Procurement","filer":"PJM","kind":"attachment","file":"sources/originals/attachment-er27-454-d.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261109-5216","parent":"refiling-er27-454-pjm-backstop","sha256":"3d744c78710f0acc1a361f4b9b26a4e3cbe066ae215db72da6016d2aa88395fd","pages":8,"tokens":2564,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":6,"text":"Attachment D \n \n \nAffidavit of Danielle Croop"},{"page":2,"startToken":6,"endToken":376,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nPJM Interconnection, L.L.C. \n \n) \n \nDocket No. ER27-____-000 \n \nAFFIDAVIT OF DANIELLE CROOP \nON BEHALF OF PJM INTERCONNECTION, L.L.C. \n1. \nMy name is Danielle Croop, Senior Manager in the Market Design group for PJM \nInterconnection, L.L.C. (“PJM”).  My business address is 2750 Monroe Blvd., \nAudubon, Pennsylvania, 19403.  I am submitting this affidavit on behalf of PJM to \nsupport the proposed reforms to PJM’s Open Access Transmission Tariff (“Tariff”) \nand PJM’s Reliability Assurance Agreement Among Load Serving Entities \n(“RAA”) to implement the Reliability Backstop Procurement (“RBP”) framework \nby providing support for PJM’s proposal to: \na. Update the Initial RBP Target; and \nb. Update Cost Allocation Methodology to Electric Distributor zone/areas. \nQualifications \n2. \nIn my role as Senior Manager for PJM, I lead a team of Market Design Specialists \nand Economists on the development of PJM’s market design across all of PJM’s \nmarkets including the energy, ancillary services, and capacity markets.  My \nresponsibilities include leading the development of wholesale market rules and \nparticipation frameworks that advance market efficiency and grid reliability.  I \njoined PJM in 2014 as an Engineer, and since then, I have held numerous other \nroles, including as a Senior Engineer, Senior Lead Engineer, Senior Lead Market \nDesign Specialist, and Market Design Manager, providing technical support and \nleading cross-divisional teams on market design, market evolution initiatives \nrelated to energy storage and distributed energy technologies participating in the \nPJM markets, and balancing operations at PJM, including involvement in a number \nof North American Electric Reliability Corporation subcommittees and initiatives.   \n3. \nPrior to joining PJM, I was employed by the SI Organization, Inc. as a System \nEngineer supporting large system integrations.  I received a Bachelor of \nEngineering Degree and a Master of Engineering (Electrical Engineering) from \nDrexel University in Philadelphia, Pennsylvania, and have obtained a Certificate in \nEngineering Management. \nInitial RBP Target  \n4. \nPJM proposes to update the Initial RBP Target using the lesser of the projected \nshortfall established from the latest load forecast and planning parameters for the \n2028/2029 Delivery Year that will be available at the time the RBP is conducted, \nand the aggregate quantity of Large Load growth reported to PJM, rather than"},{"page":3,"startToken":376,"endToken":862,"text":"3 \nrelying solely on the shortfall quantity established through the Base Residual \nAuction for the 2028/2029 Delivery Year, held in July 2026.    \n5. \nFirst, utilizing the latest information allows PJM to identify the most accurate \nestimate of the reliability need for the 2028/2029 Delivery Year based on the latest \nload forecast of demand that will need to be served and the expected supply.  \nSpecifically, because this updated information will be available prior to conducting \nthe RBP, it is appropriate to use the most up-to-date information to produce an \nInitial RBP Target that represents the latest expected reliability shortfall and avoid \neither under-procurement or over-procurement of resources. \n6. \nSecond, applying the “lesser of” calculation using the aggregate quantity of Large \nLoad growth reported to PJM for the RBP will mitigate the potential over-allocation \nof RBP Charges to a zone/area relative to the forecasted Large Load growth.  PJM \nbelieves this scenario is unlikely based on currently available information.  \nSpecifically, PJM’s 2026 Load Forecast indicates approximately 9,000 MW of large \nload growth, while the projected Regional Transmission Organization (“RTO”) \nshortfall for the 2028/2029 Base Residual Auction is approximately 6,800 MW.  \nAlthough these values may change as updated forecasts become available in 2027, \nPJM expects the relationship between Large Load growth and the projected \nshortfall to remain generally consistent.  Nevertheless, including the “lesser of” \ncalculation in the Initial Target provides an important safeguard by accounting for \nthe possibility that previously reported Large Load agreements may be canceled \nbetween the collection of data for the 2027 Load Forecast and the establishment of \nthe RBP.  By ensuring that RBP cost allocations do not exceed 100% of the Large \nLoad growth reported for the applicable zone/area, the proposed procurement target \nand cost allocation framework better align cost responsibility with the principles of \ncost causation and beneficiary pays. \n7. \nFurther, since PJM plans to run the RBP in March 2027, by that time PJM will have \nconducted the 2029/2030 Base Residual Auction, scheduled for December 2026.  \nThat auction may produce a shortfall, and of different quantity than for the \n2028/2029 Delivery Year.  Nevertheless, PJM proposes to maintain the 2028/2029 \nDelivery Year shortfall as the basis for the RBP.  This approach is consistent with \nthe underlying intent of the RBP to address the nearer-term reliability need while \nallowing market fundamentals to address the longer-term resource adequacy.  \n8. \nAdditionally, adopting a different procurement target timeframe would necessitate \nbroader revisions to the overall design, including resource eligibility requirements \nand commitment terms.  Because market participants have already planned and \nmade business decisions based on PJM conducting the RBP for the 2028/2029 \nDelivery Year, maintaining the existing design is prudent.  Doing so promotes \ncertainty, preserves stakeholder expectations, and avoids unnecessary disruption to \nthe market. \n9. \nThe RBP is intended to serve as a bridge mechanism to address immediate \nreliability concerns while PJM and stakeholders continue to pursue longer-term"},{"page":4,"startToken":862,"endToken":1270,"text":"4 \nmarket design reforms aimed at improving investment and retention signals to \nsupport resource adequacy.  In support of those efforts, PJM has initiated its \nPowering Reliability Through Market Design initiative with stakeholders and \ncontinues to work with the Charles River Associates to facilitate bilateral matching \nefforts. \n10. \nThe shortfall MW calculation that will set the Initial RBP Target will be calculated \nusing the updated information from the 2027 Load Forecast and associated updated \nplanning parameters and submitted Large Load MW values from the Electric \nDistributors.  More specifically, PJM will calculate the Initial RBP Target MW as:  \nThe lesser of: \n(1) the PJM Region Reliability Requirement for the 2028/2029 Delivery Year \nminus the UCAP-equivalent of the ICAP quantity of Capacity Resources that \ncleared in the 2028/2029 Base Residual Auction \nWhere the PJM Region Reliability Requirement for the 2028/2029 Delivery \nYear will be calculated as the RTO Region Peak Load Forecast for the \n2028/2029 Delivery Year from the 2027 Load Forecast times the 2028/2029 \nForecast Pool Requirement from the updated planning parameters published \nin 2027 prior to the commencement of the RBP, less the sum of all updated \nUnforced Capacity Obligations of FRR Entities in the PJM Region.  \nAnd where the UCAP-equivalent of the ICAP quantity of Capacity \nResources that cleared in the 2028/2029 Base Residual Auction, where the \nUCAP-equivalent values will be determined by the Capacity Resources’ \nupdated capacity accreditation factors for the 2028/2029 Delivery Year that \nwill be available in the updated planning parameters available just prior to \nthe commencement of the RBP. \nAnd  \n(2) the UCAP equivalent of the aggregate region-wide Large Load MW quantity \nreported by the Electric Distributor \nWhere the UCAP equivalent of the aggregate region-wide Large Load MW \nis the aggregate region-wide Large Load MW times the most recent \n2028/2029 Forecast Pool Requirement. \n11. \nThe RBP will function as a safety net to address the shortfall MW for the 2028/2029 \nDelivery Year that has not been addressed by new Large Load bringing their own \nnew capacity through bilateral agreements or otherwise.  The RBP is a stop-gap, \none-time measure aimed specifically at addressing the resource adequacy shortfall \nin the PJM Region, an effort designed to work in part with the load that has \nvoluntarily brought supply to the PJM Region—independently or with support of \nongoing PJM bilateral matching efforts—and a return to market fundamentals to \nsupport the expected load growth over the next decade."},{"page":5,"startToken":1270,"endToken":1744,"text":"5 \nRBP Cost Allocation Methodology \n12. \nThe cost allocation structure begins with the Initial RBP Target based on the Large \nLoad growth between the 2026 summer peak load and the forecasted Large Load \nMW in each Electric Distributor’s zone/area for the 2028/2029 Delivery Year.  The \nInitial RBP Target is then adjusted by the quantity of Qualifying RBP Offset UCAP \nMW and Peak Shaving Adjustment opt-out to reach the Final RBP Target.  Each \nElectric Distributor’s zones/areas with resulting forecasted Large Load growth \nbetween 2026 and the 2028/2029 Deliver Year will be allocated a pro rata share of \nthe Final RBP Target.1  The MW quantity assigned to each Electric Distributor’s \nzone/area will be further allocated to Load Serving Entities (“LSE”) based on the \nRBP Obligation (“RBO”), which permits states to determine the appropriate cost \nallocation to specific LSEs.  Should the Relevant Electric Retail Regulatory \nAuthority(s), through the relevant Electric Distributors, decline to provide an RBO \nMW, PJM has proposed to apply a backup default cost allocation where costs would \nbe allocated to all of the LSEs in the zone/area based on their percent share of the \nzone/area’s Daily Unforced Capacity Obligation.  \nStep 1: \nCollecting the Forecasted Large Load Growth Between 2026 \nThrough the 2028/2029 Delivery Year Subject to RBP Cost \nAllocation  \n13. \nSeven days prior to the commencement of the RBP, PJM will receive all Large \nLoad growth in the Electric Distributor zone/area from the 2026/2027 Delivery \nYear through the 2028/2029 Delivery Year.  The Large Load growth will be \nsubmitted based on firm commitments, as supported by electric service obligation, \nconstruction commitment, or equivalent agreements, and measured based on \nsummer peak values.  These submissions are required to align with the Large Loads \nsubmitted to PJM for the 2027 load forecast.  Any discrepancies between the \nElectric Distributors’ submissions for RBP and data submitted to PJM for the 2027 \nload forecast must be accompanied by written documentation of the change from \nthe Electric Distributor.  \n14. \nThe aggregate Large Loads growth will be submitted within a zone/area, along with \nidentification of the underlying Large Loads.  This will result in PJM having the \naggregate value to determine the total Large Load MW for the zone/area and the \nsummation of all zone/areas to determine the total Large Load MW for the RTO \nRegion.  The underlying Large Loads will be used to facilitate the Qualifying RBP \nOffset UCAP MW process.  \nStep 2: \nAllocating to Electric Distributor Zone/Area \n15. \nTo allocate costs, i.e., RBP Charges, PJM is proposing to determine cost \nresponsibility by the Electric Distributor zone/area and their pro rata share of Large \nLoad MW subject to RBP in comparison to the total Large Load MW subject to \n \n1 This cost allocation structure in detailed in the example below starting in paragraph 17."},{"page":6,"startToken":1744,"endToken":2109,"text":"6 \nRBP across the RTO.  The final pro rata share determination will be fixed for the \nterm of the RBP and be applied to the committed RBP UCAP MW and associated \nRBP Charges throughout the term of the RBP.  \n16. \nAn illustrative example of Step 1 and Step 2 is detailed in the following section.   \nExample of Allocation to Electric Distributor Zone/Area \n17. \nFor this example, the Initial RBP Target MW will be assumed to be 4,000 MW.  \nThis value is purely illustrative for this example and not indicative of the Initial \nRBP Target for the RBP.  \n18. \nThe initial pro rata allocation to each Electric Distributor zone/area will be based \non the submitted data from the Electric Distributors representing the forecasted \nLarge Load growth between the 2026/2027 Delivery Year and 2028/2029 Delivery \nYear.  The initial share is calculated as: [Zone/Areas Large Load Growth MW/ \nRTO Large Load Growth MW], which can be represented as the initial RBP UCAP \nMW allocation based on that pro rata share of the Initial RBP Target.  \n \n19. \nSecond, as Qualifying RBP Offset UCAP MW are submitted, both the Final RBP \nTarget and the pro rata allocation to each Electric Distributor zone/area will be \nupdated.  In this example, I will assume the following Qualifying RBP Offset \nUCAP MW were submitted and will decrement the Initial RBP Target: \n \nNote: The Qualifying RBP Offset UCAP MW is represented by Load*FPR. FPR is represented as 0.9401 int this \nexample.  \n20. \nIn my illustrative example, for purposes of simplicity, I assume there are no \nadditional decrements to the Initial RBP Target for opt outs.  Thus, the Final RBP \nTarget would be calculated as Initial RBP Target – Qualifying RBP Offset UCAP \nZone/Area \nSubmitted Large \nLoad Growth (MW)\nInitial Share of \nRBP (%) \nShare of Initial Target \nMW (4000MW)\nZone/Area 1\n1000\n24%\n975.6\nZone/Area 2\n500\n12%\n487.8\nZone/Area 3\n100\n2%\n97.6\nZone/Area 4\n1000\n24%\n975.6\nZone/Area 5\n1500\n37%\n1463.4\nTotal\n4100\n100%\n4000\nZone/Area \nLoad (MW)\nQualifying RBP \nOffset UCAP \nMW\nZone/Area 1\n500\n470\nZone/Area 2\n100\n94"},{"page":7,"startToken":2109,"endToken":2452,"text":"7 \nMW.  In this example, this would be: 4,000 MW – [470 MW + 94 MW ] = 3,436 \nMW.   \n21. \nSubsequently, the Large Load that submitted the Qualifying RBP UCAP MW will \nbe removed from the Large Load growth for cost allocation purposes.  The updated \npro rata allocation and RBP UCAP share of the Final RBP Target is demonstrated \nin the table below.  In Zone/Area 1 the Large Load Growth (MW) will be reduced \nfrom 1000 MW to 500 MW to account for the 500 MW of load with demonstrated \nQualifying RBP Offset UCAP MW.  Similarly, Zone/Area 2 will be updated to 400 \nMW to account for the Qualifying RBP Offset UCAP MW.   \n22. \nBased on adjustments to each Electric Distributor zone/area’s Large Load Growth \nMW, the final pro rata shares are recalculated. \n \nThe Bounds of Qualifying Offsets \n23. \nLarge Load can be removed from the Large Load MW used to determine RBP cost \nallocation by bringing Qualifying RBP Offset UCAP MW.  A Large Load can bring \nup to their capacity obligation (in UCAP), determined as peak MW times the \nForecast Pool Requirement.  MW from supply resources in excess of that value will \nnot be considered to decrement the Large Load growth in a zone/area or decrement \nthe Initial RBP Target value.   \n24. \nA zone/area cannot reduce its zone/area share of the Initial RBP Target beyond the \ncapacity obligation of the total Large Load MW in that zone/area (floored at zero).  \nFurther, a zone/area must provide Qualifying RBP Offset UCAP MW equal to \ncapacity obligation of the total Large Load MW in that zone/area to be fully \nremoved from the RBP cost allocation. \n25. \nThis concludes my affidavit. \n \nZone/Area \nSubmitted Large \nLoad Growth \n(MW)\nFinal Share of \nRBP (%) \nShare of Final Target \nMW (3436 MW)\nZone/Area 1\n500\n14%\n490.9\nZone/Area 2\n400\n11%\n392.7\nZone/Area 3\n100\n3%\n98.2\nZone/Area 4\n1000\n29%\n981.7\nZone/Area 5\n1500\n43%\n1472.6\nTotal\n3500\n100%\n3436"},{"page":8,"startToken":2452,"endToken":2564,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nPJM Interconnection, L.L.C. \n \n) \n \nDocket No. ER27-____-000 \n \nVERIFICATION \nI, Danielle Croop, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that \nI am the Danielle Croop referred to in the foregoing document entitled “Affidavit of \nDanielle Croop, Senior Manager in the Market Design group for PJM Interconnection, \nL.L.C.,” that I have read the same and am familiar with the contents thereof, and that the \nfacts set forth therein are true and correct to the best of my knowledge, information, and \nbelief. \n \n/s/ Danielle Croop  \n \nDanielle Croop  \nSr. Manager, Market Design \nPJM Interconnection, L.L.C."}],"sections":[{"p":1,"at":0,"title":"Attachment D","method":"printed heading","endPage":8,"endAt":704,"startToken":0,"endToken":2564}]}