ER26-3380-001 · 2026-10-13 · American Municipal Power

Request for Clarification and Alternative Request for Rehearing of American Municipal Power, Inc.

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C. 
 
) 
) 
Docket Nos. ER26-3380-000 
                            EL26-108-000 
REQUEST FOR CLARIFICATION AND ALTERNATIVE  
REQUEST FOR REHEARING OF 
AMERICAN MUNICIPAL POWER, INC. 
 
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 Reliability Backstop Procurement 
(“RBP”) for the PJM region.2 Clarification of the September 29 Order is warranted to help 
ensure that any method for allocating RBP costs (whether developed in this proceeding 
or proposed by PJM in a future filing) comports with the Commission’s goal of allocating 
RBP costs to regions experiencing load growth driven by new large loads, consistent with 
cost causation principles.  
First, the Commission should clarify its suggestion in the September 29 Order that 
it may be just and reasonable for PJM to “base the RBP allocation on the difference 
between the actual load for 2026/2027 delivery year in each Electric Distributor zone/area 
with the most recent 2028/2029 delivery year load forecast for each Electric Distributor 
zone/area.”3 The Commission should make clear that it would not be just and reasonable 
to implement this cost allocation method if (as is likely) it would result in RBP costs being 
 
1  PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“September 29 Order”). 
2  PJM, Reliability Backstop Procurement to Address Resource Adequacy Concerns Stemming from Large 
Loads, Docket No. ER26-3380-000 (July 31, 2026) (“PJM Filing”). 
3  September 29 Order at P 159.

2 
allocated to Electric Distributor zone/areas that are not experiencing load growth 
attributable to data centers or other large loads, as such an allocation would be 
inconsistent with the cost causation principle.  
Second, the Commission should clarify that it did not make a final determination in 
the September 29 Order that PJM’s proposed cost allocation method is not just and 
reasonable.4 The Commission should also clarify that parties will have the opportunity in 
the paper hearing to argue that PJM’s as-filed proposal to allocate RBP cost responsibility 
is just and reasonable and not unduly discriminatory or unduly preferential.5 In the 
alternative, AMP requests rehearing. 
I. 
BACKGROUND 
PJM proposed the RBP as “a one-time time procurement of new capacity to 
address resource adequacy challenges in the PJM Region.”6 The mechanism was 
designed to procure a targeted quantity of capacity under fixed agreements with terms up 
to fifteen years beginning with the 2028/2029 Delivery Year and ending with the 
2042/2043 Delivery Year.7 PJM set the Initial RBP Target at 6,831.3 MW.8  
PJM proposed to allocate the Initial RBP Target “to each Electric Distributor’s 
zone/area using that zone/area’s pro-rata share of the difference between the forecasted 
 
4  See id. at PP 153-57. 
5  See id. at P 158. 
6  PJM Filing, Transmittal Letter at 1. 
7  Id. at 8. 
8  Id. at 31. This quantity (in megawatts (“MW”) of Unforced Capacity (“UCAP”)) is the amount that PJM’s 
Base Residual Auction for the 2028/2029 Delivery Year cleared short of PJM’s RTO-wide reliability 
requirement at the price cap of $325/MW-day. Id. at 7. PJM proposed that the Initial RBP Target could 
be decremented to account for certain new offsetting capacity (Qualifying RBP Offset UCAP MW), as 
well as for any qualifying Electric Distributor zone/areas that opt out of procuring capacity through the 
RBP. See id. at 8-9.

3 
Load Adjustments for the 2026/2027 Delivery Year and the 2028/2029 Delivery Year.”9 
Thus, the Initial RBP Target of 6,831.3 MW would be allocated to those Electric Distributor 
zone/areas that provided PJM projections of large load growth between 2026 and 2028.10 
Although there would be several more steps in determining ultimate liability for RBP 
Charges under PJM’s proposal, zone/areas that did not receive any allocation at this first 
step would be effectively excluded from responsibility for RBP Charges. 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 
discriminatory or preferential.12 The Commission established paper hearing procedures 
to address three aspects of the PJM Filing – cost allocation, Transmission Owner exit 
rules, and collateral requirements for Load Serving Entities (“LSEs”).13 The paper hearing, 
the Commission explained, “should address the Commission’s potential modifications 
 
9  PJM Filing, Attach. A, proposed Tariff, Attachment DD, section 18.3(a). 
10  See, e.g., id., Attach. C, Croop Aff. at ¶¶ 41-43; Transmittal Letter at 96-97. 
11  See id., Transmittal Letter at 100-108. PJM effectively confirmed that neither AMP, nor any AMP 
member, would be allocated any of the costs of procuring the Initial RBP Target (i.e., RBP Charges) 
under PJM’s as-filed proposal, as all AMP members were within zone/areas that would not receive any 
allocation of the Initial RBP Target. See AMP, Comments, Docket No. ER26-3380-000, at 2 (Aug. 21, 
2026) (“AMP Comments”). 
12  See September 29 Order at P 23. FERC also concluded that the existing PJM Open Access 
Transmission Tariff (“Tariff”) “may be unjust and unreasonable because the existing reliability backstop 
provisions appear to be insufficient to prevent the grave resource adequacy concerns that led PJM to 
file the instant proposal in the first place.” Id. at P 29. 
13  See id. at PP 23-24. The Commission also established a new proceeding in Docket No. EL26-108-000 
pursuant to section 206 of the Federal Power Act (“FPA”) “in anticipation of the Commission directing 
significant modifications to certain aspects of PJM’s RBP proposal following the paper hearing.” Id. at P 
27.

4 
with respect to the portions of PJM’s existing RBP proposal” that FERC found may be 
unjust and unreasonable.14  
While establishing a paper hearing, the Commission “strongly encourage[d] PJM 
to address the issues discussed in this order by submitting an alternative proposal 
pursuant to its FPA section 205 filing rights without delay.”15 The Commission observed 
that such a filing could “obviate the need for the paper hearing procedures,”16 and the 
Commission indicated that it would likely hold the paper hearing in abeyance if PJM files 
a new FPA section 205 filing within thirty days of the September 29 Order.17 
II. 
REQUEST FOR CLARIFICATION 
A. 
The Commission should clarify that it would not be just and 
reasonable to implement its potential modification to PJM’s proposed 
RBP cost allocation if that approach would result in the allocation of 
RBP costs to zone/areas that are not experiencing load growth 
attributable to large loads. 
In finding that PJM’s proposed RBP cost allocation may be unjust and 
unreasonable, the Commission’s principal concern was that PJM’s reliance on Load 
Adjustments could “potentially leav[e] out some new large loads,”18 because Load 
Adjustments “account[] for net load growth associated with any size or type of load, while 
excluding any new large loads that PJM knew of and accounted for when calculating the 
initial load forecast.”19 Excluding new large loads from the Load Adjustments used to 
 
14  Id. at P 23.  
15  Id. at P 28; see also id. at PP 3, 158, 160. 
16  Id. at P 3. 
17  Id. at P 24. 
18  Id. at P 155. 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 load growth may be inconsistent or not reasonably capture forecasted load growth or actual

5 
allocate the Initial RBP Target, the Commission reasoned, “could lead to the costs 
imposed on certain entities not being at least roughly commensurate with the benefits 
they will receive from the procurement.”20 In other words, the Commission was not 
persuaded that the load growth data upon which PJM proposed to rely would accurately 
identify, and allocate costs to, zone/areas with the new large loads that drove the region’s 
current capacity shortfall, as required by the cost causation principle.21  
In response to this perceived deficiency in PJM’s proposal, the Commission 
remarked that it may be just and reasonable for PJM to “base the RBP allocation on the 
difference between the actual load for 2026/2027 delivery year in each Electric Distributor 
zone/area with the most recent 2028/2029 delivery year load forecast for each Electric 
Distributor zone/area.”22 This approach, the Commission suggested, “may be consistent 
with the cost causation principle because it would appropriately assign RBP costs to the 
Electric Distributor zone/areas with the reported new load that is driving the need for the 
procurement.”23 The Commission indicated that parties should address this potential 
modification to PJM’s cost allocation proposal in the paper hearing procedures.24 
The cost causation principle dictates that “all Commission-jurisdictional rates and 
charges must reflect to some degree the costs actually caused by the customer who must 
 
large load growth.”). As explained, infra, in section III.B.1, the Commission appears to have 
misunderstood how PJM calculated the Load Adjustment data on which PJM relied to set the Initial RBP 
Target. 
20  Id. at P 155. 
21  See, e.g., id., Comm’r See, concurring, at P 3 (observing that “PJM missed the mark on an important 
element of its proposal: it did not adequately ensure that the procurement’s costs will be allocated to the 
customers who drive its need.”). 
22  Id. at P 159. 
23  Id. 
24  Id. at PP 158, 160.

6 
pay for them, and costs must be allocated in a manner that is at least roughly 
commensurate with benefits.”25 Adherence to this principle in allocating RBP costs, as 
the Commission properly recognized, requires that RBP costs are borne by the 
zone/areas experiencing growth in large loads.26 The United States Department of Energy 
(“DOE”) underscored this point in its recent Statement of Position, “emphasiz[ing] the 
need to protect ratepayers from the costs associated with rising demand caused by other 
large load customers.”27 
To help ensure that the method for allocating RBP costs (whether developed 
through the paper hearing or proposed by PJM in an FPA section 205 filing) comports 
with the Commission’s goal of allocating RBP costs to zone/areas experiencing load 
growth driven by new large loads, the Commission should clarify that it would not be just 
and reasonable to apply the Commission’s potential modification to PJM’s cost allocation 
method if it would result in RBP costs being allocated to Electric Distributor zone/areas 
that are not experiencing load growth attributable to data centers or other large loads, as 
such an allocation would be inconsistent with the cost causation principle.  
The requested clarification would avoid any potential misinterpretation of the 
Commission’s statement that its potential modification to the PJM proposal “would 
appropriately assign RBP costs to the Electric Distributor zone/areas with the reported 
new load that is driving the need for the procurement.”28 Specifically, clarification would 
 
25  Id. at P 150 (citation modified). 
26  Id. at PP 154-55; see also id., Comm’r Rosner, concurring, at P 2 (opining that the Commission’s 
guidance “will enable PJM to assign costs to those responsible (i.e. to the zones with data center growth) 
for the resource adequacy shortfall, consistent with cost causation principles”). 
27  DOE, Notice of Intervention and Statement of Position of the United States Department of Energy, 
Docket Nos. ER26-3380-000, et al., at 6 (Oct. 7, 2026). 
28  September 29 Order at P 159.

7 
indicate that the Commission’s reference to “new load that is driving the need for the 
procurement” means new data center and other large load. 
Clarification is also appropriate to resolve the incongruity between, on the one 
hand, the Commission’s aim of ensuring that RBP costs are allocated to zone/areas with 
large load growth driving resource adequacy deficiencies, and, on the other hand, the 
likelihood that its proposed cost allocation method would allocate RBP costs to 
zone/areas without new large loads. Contrary to the Commission’s goals in suggesting 
its revised cost allocation approach, 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. The Commission’s proposed modification apparently calls 
for PJM to allocate RBP costs to each Electric Distributor zone/area based on its load 
ratio share of forecasted load growth between the 2026/2027 and 2028/2029 delivery 
years. Such a load ratio share approach to allocating costs would not comport with cost 
causation. As the Commission recognized, “[t]he RBP is a one-time procurement of 
capacity resources to address a shortfall attributable to load growth in certain Electric 
Distributor zone/areas.”29 Simply assigning RBP costs based on each zone/area’s share 
of the difference between the actual load for the 2026/2027 delivery year and the load 
forecast for 2028/2029 would not ensure that costs are appropriately allocated to those 
“certain Electric Distributor zone/areas”30 driving the capacity shortfall. The Commission’s 
 
29  Id. at P 156 (emphasis added).  
30  Id.

8 
modified approach is instead likely also to capture zone/areas where load growth is 
attributable to ordinary, organic load growth, not new large loads.  
B. 
The Commission should clarify that it has not made a final decision 
regarding the justness and reasonableness of PJM’s proposed cost 
allocation method. 
AMP generally supported the RBP cost allocation method proposed in the PJM 
Filing, observing that it would appropriately allocate the Initial RBP Target to zone/areas 
with large load growth documented in forecast Load Adjustments.31 As noted above, 
however, the Commission concluded “that PJM’s proposed RBP cost allocation method 
may be unjust and unreasonable,”32 finding that, “based on the current record, PJM has 
not adequately demonstrated that its proposal is just and reasonable and consistent with 
the cost causation principle.”33 
The September 29 Order, however, is ambiguous as to whether the Commission 
intended to make a final decision as to the justness and reasonableness of PJM’s as-filed 
cost allocation method that would be subject to a request for rehearing. While certain 
statements in the September 29 Order indicate that the Commission made no final 
determination on the merits of PJM’s proposal,34 other statements in the Order suggest 
 
31  See AMP Comments at 2. 
32  September 29 Order at P 153. 
33  Id. 
34  See, e.g., id. at P 23 (“[o]ur preliminary analysis indicates that . . . aspects of PJM’s proposal have not 
been shown to be just and reasonable and may be unjust, unreasonable, unduly discriminatory or 
preferential, or otherwise unlawful.”); id. (“PJM’s filing raises issues of material fact that cannot be 
resolved based on the record before us and that are more appropriately addressed in the paper hearing 
procedures established below.”); id at P 153 (“PJM’s proposed RBP cost allocation method may be 
unjust and unreasonable”).

9 
that the Commission conclusively found that PJM’s proposed cost allocation method is 
not just and reasonable.35 
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, and that 
the September 29 Order is not a final order as to that issue. 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 clarify that parties may address PJM’s as-filed cost 
allocation proposal in the paper hearing procedures. Those procedures would provide an 
appropriate forum for parties to clarify aspects of PJM’s proposal that are subject to 
misinterpretation, and address other details related to the merits of PJM’s as-filed cost 
allocation method. The hearing process would allow the Commission to make a final 
determination on the proposal’s justness and reasonableness based on a more complete 
record.37 The opportunity to further evaluate PJM’s original proposal could be particularly 
valuable given the concerns discussed above regarding the Commission’s proposed 
modification to PJM’s cost allocation approach. 
 
35  See, e.g., id. at P 156 (“PJM has not demonstrated that reliance on the Load Adjustment process is just 
and reasonable.”); id. at P 158 (“we now conclude that additional record evidence is needed to determine 
whether PJM’s proposed RBP cost allocation method could be just and reasonable if modified.”); id., 
Comm’r See, concurring, at P 3 (“PJM missed the mark on an important element of its proposal: it did 
not adequately ensure that the procurement’s costs will be allocated to the customers who drive its 
need.”). 
36  See, e.g., PJM Interconnection, L.L.C., 196 FERC ¶ 61,214, at P 19 (2026); DCR Transmission, L.L.C., 
195 FERC ¶ 61,181, at P 19 (2026). 
37  See September 29 Order at P 153 (concluding “based on the current record” that PJM did not adequately 
demonstrate that its cost allocation proposal is just and reasonable).

10 
III. 
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 cost allocation method – particularly its reliance on Load 
Adjustments – is not just and reasonable. The Commission’s rejection of PJM’s proposal 
was arbitrary and capricious, as it was based on an apparent misunderstanding of PJM’s 
approach. 
A. 
Statement of Issues 
In accordance with Rule 713(c)(2),40 AMP provides the following enumerated 
statement of issues, including citations to representative Commission and court 
precedent on which it relies: 
1. 
The Commission’s conclusion that PJM’s proposed RBP cost allocation 
method was not just and reasonable was arbitrary and capricious.41 
2. 
The Commission’s conclusion that PJM’s proposed RBP cost allocation 
method was not just and reasonable was arbitrary and capricious, as it was based upon 
an apparent misunderstanding of the record evidence.42 
 
38  16 U.S.C. § 825l. 
39  18 C.F.R. § 385.713. 
40  18 C.F.R. § 385.713(c)(2).  
41  5 U.S.C. § 706(2); Motor Vehicle Mfrs. Ass’n of the United States, Inc. v. State Farm Mut. Auto. Ins. Co., 
463 U.S. 29, 43 (1983); New England Power Generators Ass’n v. FERC, 881 F.3d 202 (D.C. Cir. 2018); 
KeySpan-Ravenswood, LLC v. FERC, 348 F.3d 1053 (D.C. Cir. 2003). 
42  5 U.S.C. § 706(2); Motor Vehicle Mfrs. Ass’n., 463 U.S. at 43.

11 
B. 
Request for Rehearing 
1. 
The Commission’s rejection of PJM’s RBP cost allocation 
method was based on an apparent misunderstanding of that 
method. 
As discussed above, the Commission’s principal rationale for rejecting PJM’s 
proposed cost allocation method was that PJM’s reliance “on Load Adjustments to 
measure load growth may be inconsistent or not reasonably capture forecasted load 
growth or actual large load growth.”43 While the Commission reasonably determined that 
the cost causation principle requires RBP costs to be allocated based on “large load 
growth,” the Commission erred in concluding that PJM’s as-filed proposal would not 
accomplish this aim. The Commission’s conclusion appears to have been based, in 
significant part, on a misunderstanding of the PJM methodology. As a consequence, the 
Commission’s decision is not the product of reasoned decision making.44 
The Commission expressed concern that, based on PJM’s discussion of its load 
forecasting process in a prior proceeding, “it appears some large loads may never have 
been accounted for as Load Adjustments because PJM accounted for them when 
calculating the initial load forecast.”45 This observation misapprehends the PJM Load 
Adjustment methodology used in allocating the Initial RBP Target. PJM’s proposed RBP 
cost allocation method was based on the Load Adjustments in Table B9b in the 2026 PJM 
 
43  September 29 Order at P 154. 
44  Motor Vehicle Mfrs. Ass’n., 463 U.S. at 43 (an agency decision is arbitrary and capricious where the 
agency offers “an explanation for its decision that runs counter to the evidence before the agency”). 
45  September 29 Order at P 155 (citing PJM Interconnection, L.L.C., 188 FERC ¶ 61,200, at P 21 (2024)); 
see also id. (“the delta accounts for net load growth associated with any size or type of load, while 
excluding any new large loads that PJM knew of and accounted for when calculating the initial load 
forecast.”).

12 
Load Forecast,46 and those adjustments incorporate large loads that might otherwise be 
captured in the initial load forecast, thus avoiding the concern identified by the 
Commission.  
As the Commission notes, PJM stated in Docket No. ER24-2447 that, to avoid 
double counting of forecast load, PJM will not generally make a Load Adjustment if, based 
on its review process, it concludes that a potential Load Adjustment is already captured 
in the underlying load forecast model.47 The actual process is more complex. Relevant 
here, PJM’s review of Load Adjustments includes a sensitivity analysis, reflected in Table 
B9 of the PJM Load Forecast,48 that seeks to identify the extent to which a proposed Load 
Adjustment includes large load already embedded in PJM’s initial econometric forecast.49 
Table B9 presents the results of this sensitivity analysis, quantifying the Load Adjustment 
amounts included in the final forecast that are over and above what is already embedded 
in PJM’s initial forecast.50 Reliance on Load Adjustment quantities in Table B9 to allocate 
RBP costs would indeed present a concern of undercounting new large loads. 
PJM, however, did not rely on the Load Adjustments shown in Table B9 to allocate 
RBP costs, it proposed to use the Load Adjustments in Table B9b of the Load Forecast. 
 
46  PJM Filing, Attach. C, Croop Aff. at ¶ 43 (citing 2026 PJM Load Forecast Report Data Tables, PJM 
Interconnection, 
L.L.C., 
Tab 
Table 
B9b 
(Feb. 
2026), 
https://www.pjm.com/-
/media/DotCom/planning/res-adeq/load-forecast/2026-load-report-tables.xlsx [https://perma.cc/SST2-
EGUZ]; 2026 PJM Load Forecast Report, PJM Interconnection, L.L.C., 5-6 (Jan. 14, 2026), 
https://www.pjm.com/-/media/DotCom/library/reports-notices/load-forecast/2026-load-report.pdf 
[https://perma.cc/J24E-7CV7] (describing Table B9b results)). 
47  See September 29 Order at P 155; see also PJM Interconnection, L.L.C., 188 FERC ¶ 61,200 at P 21. 
48  See footnote 46, supra. 
49  See, e.g., PJM, 2026 PJM Long-Term Load Forecast, Load Analysis Subcommittee presentation, at p. 
28 
(Jan. 
23, 
2026), 
https://www.pjm.com/-/media/DotCom/committees-
groups/subcommittees/las/2026/20260123/20260123-item-03---pjm-2026-long-term-load-forecast---
presentation.pdf. 
50  See id.

13 
The Load Adjustments reflected in Table B9b, which was developed after PJM’s filing in 
Docket ER24-2447, are intended to include new large loads that might otherwise have 
been reflected in the underlying econometric forecast. PJM has described51 the basic 
methodology for Table B9b Load Adjustments to be as follows: First, PJM identifies zones 
with existing data center loads. Second, PJM removes monthly data center load from the 
commercial Energy Information Administration data underlying the load forecast. Third, 
PJM removes hourly data center load from historical loads used in PJM’s model 
estimation. Finally, total accepted load is added to the load forecast. 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 Adjustment requests above the embedded value.  
The difference between the B9 and B9b analyses can be seen in a comparison of 
the respective results, with Table B9b generally reflecting larger Load Adjustments, as 
would be expected given the nature of that analysis: 
 
 
 
51  PJM, 2026 PJM Long-Term Load Forecast, Load Analysis Subcommittee presentation, at p. 28, 
https://www.pjm.com/-/media/DotCom/committees-
groups/subcommittees/las/2026/20260123/20260123-item-03---pjm-2026-long-term-load-forecast---
presentation.pdf. 
52  For zones without existing data center loads, total accepted large load gets added into the forecast. See 
id.

14 
2026 Load Forecast – Table B9 
 
2026 Load Forecast – Table B9b

15 
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 with 
PJM’s use of Load Adjustments in the cost allocation methodology. Accordingly, the 
Commission erred in finding that PJM’s approach was not just and reasonable based on 
that concern.  
2. 
The objections raised by the NJBPU did not warrant rejection of 
PJM’s cost allocation methodology. 
In rejecting PJM’s cost allocation methodology, the Commission also pointed to an 
answer filed by the New Jersey Board of Public Utilities (“NJPBU”).53 Although generally 
supporting reliance on Load Adjustments to allocate RBP costs, the NJBPU Answer 
raised concerns about utilities’ potential use of inconsistent criteria in submitting the Load 
Adjustment requests that formed the basis for PJM’s proposed cost allocation.54 While a 
specific MW threshold for Load Adjustments might have been preferable (and has now 
been adopted55), the absence of such a bright line does not undermine a conclusion that 
the Load Adjustments submitted by utilities in connection with the 2026 Load Forecast 
reasonably captured the large loads driving the region’s current capacity shortfall. 
Moreover, once the proposed Load Adjustments were submitted, PJM engaged in a 
robust independent analysis to ensure that the proposals were evaluated based on 
consistent standards, regardless of the criteria used by the respective utilities that 
 
53  September 29 Order at P 155 (citing NJBPU, Motion for Leave to Answer and Answer, at 3-6 (Sept. 24, 
2026) (“NJBPU Answer”)). As noted, the NJBPU filed its answer just five days before the date by which 
PJM asked the Commission to act on its Filing). 
54  See NJBPU Answer at 3-6. 
55  See id. at 4 n.13 (noting that PJM Manual 19 has been updated to specify a 50 MW threshold for future 
Load Adjustments).

16 
submitted the Load Adjustments.56 Accordingly, the NJBPU’s concerns did not warrant 
rejection of PJM’s cost allocation approach. 
Because the Commission’s rationales for rejecting PJM’s proposed RBP cost 
allocation method were based on a mistaken or incomplete understanding of PJM’s 
approach, the Commission should grant rehearing of its rejection of PJM’s approach. 
IV. 
CONCLUSION 
WHEREFORE, for the foregoing reasons, American Municipal Power, Inc. 
requests the Commission to clarify its September 29 Order as explained herein. In the 
alternative, AMP requests rehearing of the Commission’s rejection of PJM’s RBP cost 
allocation methodology.  
Respectfully submitted, 
 
/s/ John McCaffrey            
John McCaffrey 
Stinson LLP  
1775 Pennsylvania Avenue NW  
Suite 800  
Washington, DC 20006  
(202) 728-3026  
john.mccaffrey@stinson.com 
 
 
 
Dated: October 13, 2026
/s/ Gerit F. Hull                
Lisa G. McAlister                               
Senior Vice President & General Counsel  
Gerit F. Hull                                   
Deputy General Counsel for Regulatory Affairs   
American Municipal Power, Inc.                 
1111 Schrock Road, Suite 100  
Columbus, OH 43229                   
(614) 540-1111 
lmcalister@amppartners.org 
ghull@amppartners.org 
 
56  See, e.g., PJM, Load Adjustment Requests Summary for 2026 Load Forecast - Preliminary, Load 
Analysis 
Subcommittee 
presentation 
(Nov. 
24, 
2025), 
https://www.pjm.com/-
/media/DotCom/committees-groups/subcommittees/las/2025/20251124/20251124-item-03---large-
load-adjustment-requests-summary.pdf.

CERTIFICATE OF SERVICE 
 
I hereby certify that I have this day served the foregoing document upon each 
person designated on the official service list compiled by the Secretary in this proceeding. 
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.com