Request for Clarification and Alternative Request for Rehearing of American Municipal Power, 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. 15
AMP: PJM's allocation holds, because Table B9b counts the large loads FERC feared missed.
Because the Load Adjustments in Table B9b are intended to count new large load quantities, including those that might have otherwise been embedded in the initial PJM load forecast data, use of Table B9b addresses the Commission’s principal concern PDF p. 15
PDF p. 9
AMP: PJM's allocation holds, because Table B9b counts the large loads FERC feared missed.
The Commission should clarify that it has not made a final decision regarding the justness and reasonableness of PJM’s as-filed RBP cost allocation approach PDF p. 9Filed comments: Cost allocation
PDF p. 7
AMP: FERC's suggested load-difference method must not charge zones without large-load growth.
implementing its potential modification to RBP cost allocation would likely violate cost causation principles, as it could result in the allocation of RBP costs to zone/areas that have not experienced load growth attributable to data centers or other large loads. PDF p. 7Filed comments: Cost allocation
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Source sections
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Opening text
opening text · Topic match: Cost allocation
American Municipal Power, Inc. (“AMP”) hereby requests clarification of certain aspects of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) September 29, 2026 order in the above-captioned docket,1 which addressed the proposal by PJM Interconnection, L.L.C. (“PJM”) to establish a…Read this passage Filed comments: Cost allocation
I. BACKGROUND
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I.Read this passage
BACKGROUND
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PJM asserted that this allocation framework would be consistent with cost causation principles and the Ratepayer Protection Pledge.11 In the September 29 Order, the Commission preliminarily found that aspects of PJM’s RBP proposal – including cost allocation – may be unjust, unreasonable, unduly…Read this passage Filed comments: Cost allocation
II. REQUEST FOR CLARIFICATION
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II.Read this passage
A. The Commission should clarify that it would not be just and
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The Commission also found that “PJM’s proposed opt-out for qualifying cooperatives and municipal utilities may be unjust, unreasonable, and unduly discriminatory.” Id. at P 152. 19 Id. at P 155; see also id. at P 154 (agreeing “with concerns in the record that relying on Load Adjustments to measure…Read this passage Filed comments: Cost allocation
B. The Commission should clarify that it has not made a final decision
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Granting the requested clarification would be consistent with the general proposition that, when the Commission makes preliminary findings on an issue and establishes further procedures, it has not made a final determination that is subject to rehearing requests.36 The Commission should also…Read this passage Filed comments: Cost allocation
III. ALTERNATIVE REQUEST FOR REHEARING
printed heading · Topic match: Filing procedure
ALTERNATIVE REQUEST FOR REHEARING If the Commission denies the clarification requested in section II.B above, AMP seeks rehearing of the September 29 Order pursuant to FPA section 31338 and Commission Rule 713.39 The Commission should grant rehearing of its determination that PJM’s proposed RBP…Read this passage Filed comments: Filing procedure
A. Statement of Issues
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The Commission’s conclusion that PJM’s proposed RBP cost allocation method was not just and reasonable was arbitrary and capricious.41 2.Read this passage Filed comments: Cost allocation
B. Request for Rehearing
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Thus, PJM removes large loads from the underlying forecast data and adds large loads back into the forecast through the Load Adjustments.52 Table B9b is intended to capture the difference between the final forecast and what the final forecast would be without any large load, not just without Load…Read this passage Filed comments: Cost allocation
IV. CONCLUSION
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IV.Read this passage
CONCLUSION
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In the alternative, AMP requests rehearing of the Commission’s rejection of PJM’s RBP cost allocation methodology.Read this passage Filed comments: Filing procedure
CERTIFICATE OF SERVICE
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Dated at Washington, D.C., this 13th day of October, 2026. /s/ John McCaffrey John McCaffrey Stinson LLP 1775 Pennsylvania Avenue NW Suite 800 Washington, DC 20006 (202) 728-3026 john.mccaffrey@stinson.comRead this passage