{"document":{"slug":"compliance-er26-1479-pjm","title":"PJM partial compliance filing in response to the June 18, 2026 order on rehearing in EL25-49-002 et al.","issued":"2026-08-17","accession":"20260817-5195","docket":"ER26-1479-002","group":"PJM co-location compliance","filer":"PJM","kind":"compliance filing (transmittal)","file":"sources/originals/20260817-5195_Transmittal for August Compliance Filing.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20260817-5195","sha256":"8bb53306c1f94f03859a6aaba8125e91e28b7084609244fb5f298fe4a07999a2","pages":27,"tokens":8096,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":317,"text":"1200 G Street, N.W., Suite 600 \nWashington, D.C.  20005-3898 \nPhone: 202.393.1200 \nFax: 202.393.1240 \nwrightlaw.com \n \nAugust 17, 2026 \n \nHonorable Debbie-Anne A. Reese \nSecretary  \nFederal Energy Regulatory Commission  \n888 First Street, NE, Room 1A \nWashington, DC 20426 \n \nRe: \nPJM Interconnection, L.L.C., Docket Nos. ER26-1479-001 \nCompliance Filing of PJM Interconnection, L.L.C. in Response to Order on \nRehearing, Clarification, Compliance Filing, and Paper Hearing in Docket \nNos. EL25-49-002, et al. \n \nDear Secretary Reese: \nPursuant to section 206 of the Federal Power Act,1 PJM Interconnection, L.L.C. \n(“PJM”) hereby submits proposed revisions to the PJM Open Access Transmission Tariff \n(“Tariff”)2 in accordance with the Federal Energy Regulatory Commission’s \n(“Commission”) directives in its June 18, 2026, Order on Rehearing, Clarification, \nCompliance Filing, and Paper Hearing (“June Order”) 3 in Docket No. EL25-49-002, et al.4  \nAs discussed below, PJM proposes an effective date for the Tariff revisions in Parts I, III, \n \n1 16 U.S.C. § 824e. \n2 Capitalized terms not otherwise defined herein have the meaning set forth in PJM’s Open Access \nTransmission Tariff (“Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, \nL.L.C.  \n3 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026). \n4 PJM’s submission of this partial compliance filing overlaps with a broader reform framework that the \nCommission’s Large Load Order (as defined below) invites.  PJM is identifying, with stakeholder \nengagement, what changes to its Tariff may be needed on a holistic basis to develop a Federal Power Act \nsection 205 filing to fully respond to the Large Load Order.  PJM intends to submit that filing by mid-\nNovember 2026.  Today’s partial compliance filing should not be construed to, and is in no way intended to, \nlimit the reforms PJM will pursue to meet the challenges of the moment and resolve the Commission’s \npreliminary findings in the Large Load Order."},{"page":2,"startToken":317,"endToken":754,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 2 \n \nVI, VII, VIII, and IX of October 17, 2026, 61 days after the date of this filing.5  For the \nnew Interim Network Integration Transmission Service (“Interim NITS”) provisions in \nPart XI of the Tariff, PJM proposes an effective date of July 1, 2028, to provide time for \noperational changes and implementation of additional operational tools that will be needed \nto curtail non-firm Interim NITS. \nConsistent with the directives of the June Order, PJM proposes compliance changes \nto: \n• Modify the definitions of Co-Located Load, Behind the Meter Generation \n(“BTMG”), and Necessary Study, as directed;6 \n• Modify the definition of Retail BTMG to eliminate the 50 megawatts (“MW”) \nnameplate limit for netting;7  \n• Add a definition of Eligible Load and Eligible Generating Facility to Tariff, \nPart I, section 1 (Definitions) to make Interim NITS available to Eligible \nCustomers serving Co-Located Load or load connected to BTMG and make \nconforming changes to incorporate these new terms in Parts III, VI, VII, VIII, \nIX, and XI;8 \n• Remove the requirement for existing customers to enter into a new Generation \nInterconnection Agreement (“GIA”) to serve Co-Located Load, make \ncorresponding changes to Parts VI and VII to allow existing service agreements \n \n5 This requested effective date applies to the Tariff revisions proposed herein (except for new Tariff, Part \nXI), as well as to the Tariff revisions proposed without effective dates in the Thirty-Day Compliance Filing, \nthe Sixty-Day Compliance Filing, and the May 18 Compliance Filing and accepted in the April 16 Order and \nthe June Order.  See PJM Interconnection, L.L.C., Thirty-Day Compliance Filing with Order on Show Cause \nof PJM Interconnection, L.L.C., Docket No. ER26-1088-000 (Jan. 20, 2026) (“Thirty-Day Compliance \nFiling”); PJM Interconnection, L.L.C., 60-day Compliance Filing for Co-Located Load Related Revisions to \nOpen Access Transmission Tariff to Comply with Commission Order in Docket No. EL25-49, et al. of PJM \nInterconnection, L.L.C., Docket No. ER26-1479-000 (Feb. 23, 2026) (“Sixty-Day Compliance Filing”); PJM \nInterconnection, L.L.C., Compliance Filing to the Commission’s April 16 Order on PJM’s Thirty-Day \nCompliance Filing with the Order to Show Cause of PJM Interconnection, L.L.C., Docket No. ER26-1088-\n001 (May 18, 2026) (“May 18 Compliance Filing”); PJM Interconnection, L.L.C., 195 FERC ¶ 61,030 (2026) \n(“April 16 Order”).  All these changes are shown in redline in Attachment A. \n6 June Order at P 207 & n.519 (Behind the Meter Generation); id. at P 280 n.670 (Necessary Studies); id. at \nPP 307 & n.717, 308 (Co-Located Load). \n7 Id. at PP 207, 220. \n8 Id. at P 91."},{"page":3,"startToken":754,"endToken":1041,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 3 \n \nto be modified to serve Eligible Load via the Necessary Study process, and \nclarify how the Necessary Study requirements and prohibition on service before \nneeded upgrades are complete will apply to existing projects that may already \nhave Necessary Studies Agreements;9 \n• Provide live records for the illustrative Tariff language for Interim NITS in Part \nXI, incorporating certain changes directed by the June Order,10 and additional \nedits to clarify the nature of the service.11 \nTo improve clarity and consistency in the Tariff and make the Tariff easier to \nunderstand, PJM also proposes minor revisions to Parts I, III, VI, VII, VIII, IX and X to \ncross-reference Part VIII as needed; make clear that the Provisional Interconnection \nService and Necessary Study process provided in Part VIII is available to Interconnection \nCustomers under Part VI, as well as to Expedited Interconnection Track Project Developers \nunder Part X; applies to those entities and to Eligible Customers under Part III; and clarify \nthat the use of the terms “Project Developer,” “Generation Project Developer,” and \n“Generation Interconnection Agreement” under Tariff, Part VIII shall be understood to \nreference Interconnection Customers and Interconnection Service Agreements (“ISA”) \nunder Part VI, as appropriate. \n \nINTRODUCTION  \nA. \nCommission December Order \nOn December 18, 2025, the Commission issued the Order on Show Cause \n(“December Order”) finding the Tariff unjust and unreasonable due to the lack of \n \n9 Id. at P 284. \n10 See, e.g., id. at PP 515, 519 (directing PJM to eliminate provisions disqualifying an Eligible Customer from \ntaking new transmission services after one instance of failure to follow a curtailment or load shedding \ndirective). \n11 See proposed Tariff, Part XI, Subpart A, sections 701, 702, 705."},{"page":4,"startToken":1041,"endToken":1336,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 4 \n \nspecificity for the rates, terms, and conditions that apply to Co-Located Load and directing \nPJM to make a number of compliance and informational filings.12   \nFirst, the December Order directed PJM to make a compliance filing within 30 days \nto clarify the rates, terms, and conditions that apply to an Interconnection Customer13 \nseeking to serve Co-Located Load with new generation, including with Surplus \nInterconnection Service and Provisional Interconnection Service.14 \nSecond, the December Order directed PJM to make a compliance filing within 60 days \nto, inter alia, modify the Retail BTMG netting rules to limit netting over a certain \nthreshold;15 add certain requirements for Eligible Customers taking transmission service \non behalf of Co-Located Loads;16 and clarify that existing customers seeking to modify \nISAs/GIAs to accommodate Generating Facilities serving Co-Located Load must follow \nNecessary Study processes.17    \nThird, the December Order ordered a paper hearing to determine the appropriate rates, \nterms, and conditions for the three new transmission service.18  Among other things, the \nCommission asked PJM to address (1) the appropriate rates, terms and conditions for the \nnew services; (2) the appropriate rates for customers taking new transmission services for \n \n12 PJM Interconnection, L.L.C., 193 FERC ¶ 61,217, at PP 1-2, 161, 231-36 (2025) (“December Order”). \n13 Under PJM’s current interconnection rules in Tariff, Parts VII, VIII, and IX, Interconnection Customers \nare referred to as “Project Developers.”  PJM uses in this filing the term used in its current interconnection \nrules but it should be understood as consistent with the Commission’s references to Interconnection \nCustomers.  \n14 December Order at PP 232-35. \n15 Id. at P 221. \n16 Id. at PP 193, 200.  \n17 Id. at P 226.  \n18 Id. at P 219."},{"page":5,"startToken":1336,"endToken":1570,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 5 \n \nregulation and black start services; (3) the appropriate penalty charge or remedial action \nfor unauthorized use of the Transmission System; (4) eligibility requirements and \nanti-toggling mechanisms for Firm Contract Demand Transmission service; (5) \ninterconnection requirements and operational practices needed to maintain system \nreliability in the event Co-Located Load or its associated generator trips offline; (6) \ncommunications, alarm, and Supervisory Control and Data Acquisition requirements for \nCo-Located Load; and (7) appropriate procedures for curtailment and load shed.19 \nB. \nPJM Compliance Filings \n1. \nThirty-Day Compliance Filing \nOn January 20, 2026, PJM made its 30-day compliance filing in Docket No. ER26-\n1088-000 pursuant to the December Order (“Thirty-Day Compliance Filing”).20  The \nThirty-Day Compliance Filing proposed to clarify certain aspects of the Tariff for those \nseeking to serve Co-Located Load with new Generating Facilities.21  Among other changes, \nthe Thirty-Day Compliance Filing proposed to clarify that existing services in the Tariff \ncould be used to serve Project Developers serving Co-Located Load, including Provisional \nInterconnection Service and Surplus Interconnection Service.22  The Thirty-Day \nCompliance Filing also clarified the ability of Project Developers serving Co-Located Load \nto request interconnection service below nameplate capacity and the potential to accelerate \nthe interconnection process under certain circumstances.23 \n \n19 See id. at P 219. \n20 See generally Thirty-Day Compliance Filing. \n21 Id. at 4-7. \n22 Id. at 5-7. \n23 Id. at 4-5."},{"page":6,"startToken":1570,"endToken":1881,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 6 \n \nOn April 16, 2026, the Commission accepted in part and rejected in part PJM’s \ncompliance filing.24  The Commission rejected PJM’s revisions to the proposed definition \nof Co-Located Load because PJM’s proposal to deviate from this definition by replacing \nthe term “Point of Interconnection” with “Point of Change in Ownership” did not provide \nsufficient explanation as to how this proposed deviation complies with the Commission’s \ndirective in the December Order.25  The Commission also rejected proposed Tariff \nrevisions relating to BTMG as constituting changes that were outside the scope of the \noriginal proceeding, and directed PJM to remove revisions that incorporated the term Co-\nLocated Load into Tariff sections related to BTMG Application Requirements.26  On \nMay 18, 2026, PJM submitted a compliance filing to comply with the directives set forth \nin the April 16 Order.27 \n2. \nSixty-Day Compliance Filing \nOn February 23, 2026, PJM submitted its 60-day compliance filing in response to \nthe December Order (“Sixty-Day Compliance Filing”).28  The Sixty-Day Compliance \nFiling proposed Tariff revisions to:  (1) revise its BTMG Tariff provisions; (2) establish \nthree new transmission services for Eligible Customers seeking to take service on behalf \nof Co-Located Load; and (3) revise its necessary studies processes, among other changes.29  \n \n24 See generally April 16 Order.  \n25 April 16 Order at P 27. \n26 See generally May 18 Compliance Filing; see April 16 Order at P 30. \n27 See generally May 18 Compliance Filing.  Neither the Thirty-Day Compliance Filing nor the Sixty-Day \nCompliance Filing initially proposed an effective date for the Tariff revisions to Parts I, III, VII, VIII, and \nIX. The May 18 Compliance Filing established an effective date of April 16, 2026 in accordance with the \nApril 16 Order.  April 16 Order at ordering para. (A). \n28 See generally Sixty-Day Compliance Filing. \n29 Id. at 1."},{"page":7,"startToken":1881,"endToken":2245,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 7 \n \nPJM also proposed Tariff placeholders for the new transmission services being proposed \nconcurrently in the paper hearing.30  Due to the uncertainty regarding the timing of \nCommission action on the proposed changes and the non-rate terms and conditions being \nproposed in the paper hearing, PJM did not propose a specific effective date for the \nproposed new transmission services changes.31 \n3. \nPaper hearing on new transmission services \nPJM submitted its initial brief in Docket Nos. EL25-49-000 and EL25-49-001 to \naddress the Commission’s finding in the December Order that additional record evidence \nwas needed to set the appropriate replacement rates, terms, and conditions for new \ntransmission services for Eligible Customers serving Co-Located Load, including for \nInterim NITS, Firm Contract Demand Transmission Service, and Non-Firm Contract \nDemand Transmission Service.32  PJM’s initial brief set forth the non-rate terms and \nconditions for these new transmission services along with illustrative Tariff language.  \nVarious parties protested aspects of PJM’s illustrative Tariff language.33  In its reply brief, \nPJM proposed certain refinements to the illustrative language.34 \n \n30 Id. at 19. \n31 Id. at 35. \n32 See generally PJM Interconnection, L.L.C., Initial Brief of PJM Interconnection, L.L.C., Docket Nos. \nEL25-49-000, et al. (Feb. 23, 2026). \n33 See, e.g., PJM Interconnection, L.L.C., Reply Brief of Joint Co-Location Developers and Motion to \nIntervene Out-of-Time of Calibrant, Convergent, U.S. Energy Storage Coalition, and Verrus, Docket Nos. \nEL25-49-000, et al., at 2 (Mar. 25, 2026); PJM Interconnection, L.L.C., Reply Brief and Protest of Enchanted \nRock, Docket Nos. EL25-49-000, et al., at 7-9 (Mar. 25, 2026) (arguing that PJM’s proposal “renders Interim \nNITS entirely unworkable”); PJM Interconnection, L.L.C., Reply Brief of Advanced Energy United and \nSolar Energy Industries Association, Docket Nos. EL25-49-000, et al., at 6-10 (Mar. 25, 2026). \n34 PJM Interconnection, L.L.C., Reply Brief of PJM Interconnection, L.L.C., Docket Nos. EL25-49-000, et \nal., Attachment A (Redlines on Reply Brief to Illustrative Language for New Tariff, Part XI; Attachments F-\n3A and F-4; and Other Illustrative Tariff Revisions), Illustrative Tariff, Part XI, Subpart A, section 701.1 \n(Apr. 24, 2026)."},{"page":8,"startToken":2245,"endToken":2524,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 8 \n \nC. \nThe Commission’s June Order \nOn June 18, 2026, the Commission issued the June Order, addressing the Sixty-\nDay Compliance Filing, the paper hearing submissions, and requests for rehearing and \nclarification of the December Order.35  \nThe June Order found that PJM’s Sixty-Day Compliance Filing partially complies \nwith the directives of the December Order, and the Commission accepted in part and \nrejected in part PJM’s proposed Tariff revisions and ordered PJM to submit a further \ncompliance filing within 60 days.36  Additionally, the June Order found that in response to \nthe record developed in the paper hearing, certain rates, terms, and conditions for the new \ntransmission services as directed in the December Order (i.e., Interim NITS, Firm Contract \nDemand transmission service, and Non-Firm Contract Demand transmission service) are \njust and reasonable and directed PJM to make a compliance filing to revise its Tariff.37  \nD. \nLarge Load Order \nThe same day it issued the June Order, the Commission also issued a new show \ncause order to PJM concerning Large Loads (“Large Load Order”).38  The Large Load \nOrder found that several aspects of PJM’s Tariff appeared unjust and unreasonable due to \nthe lack of specific procedures for integrating large loads, including a lack of procedures \nfor interconnection studies, processing transmission service requests, and constructing \nnetwork upgrades without cost shifting.39  The Large Load Order also found PJM’s Tariff \n \n35 See June Order at PP 1-2, 4-7.  \n36 Id. at P 8. \n37 Id. at P 9. \n38 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211, at P 1 (2026). \n39 Large Load Order at PP 60, 65, 77."},{"page":9,"startToken":2524,"endToken":2833,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 9 \n \nappeared to be unjust and unreasonable due to a lack of transmission service options for \ncustomers serving large loads that are willing and able to limit their withdrawals from the \nTransmission System.40  The Large Load Order further found that PJM’s Tariff appeared \nto be unjust and unreasonable due to a lack of mechanisms to ensure that costs are not \nshifted between transmission customers.41 \nTo address these issues, the Large Load Order directed PJM to make two \ncompliance filings.42  First, the Large Load Order directed PJM to submit an informational \nfiling within 30 days to explain how PJM intends to ensure that it has adequate generation \nto serve existing and new large loads.43  Second, the Large Load Order directed PJM to \nsubmit within 60 days a compliance filing to explain whether its Tariff remains just and \nreasonable in light of the issues identified in the order, or to propose Tariff changes that \nwould remedy the identified concerns.44  The Commission noted that it would entertain \nrequests to hold the show cause proceedings in abeyance if PJM demonstrated a plan to \nfile changes pursuant to Federal Power Act section 205 to address the identified concerns.45 \nE. \nPartial Extension \nOn July 28, 2026, PJM filed a motion for extension of time to meet certain \ncompliance requirements in the June Order.46  PJM explained that due to the significant \n \n40 Id. at P 86.  \n41 Id. at P 77. \n42 Id. at ordering paras. (A) & (B). \n43 Id. at P 4. \n44 Id. at ordering para. (B). \n45 Id. at P 39. \n46 PJM Interconnection, L.L.C., Motion for Extension of Time for Specified Compliance Requirements and \nRequest for Expedited Treatment of PJM Interconnection, L.L.C., Docket Nos. EL25-49-002, et al. (July 28, \n2026) (“PJM Extension Motion”)."},{"page":10,"startToken":2833,"endToken":3139,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 10 \n \noverlap in the subject matter, additional time is needed to ensure that certain compliance \nchanges for Co-Located Load from the June Order align with the directives in the Large \nLoad Order.47  PJM explained that a partial extension would allow time for stakeholder \nengagement and feedback on the changes PJM plans to make to respond to the Large Load \nOrder.48  PJM sought a 90-day extension of certain directives in the June Order.49  In \nparticular, PJM proposed to defer implementation of the new contract demand transmission \nservices and some aspects of the BTMG netting.50  At the same time, PJM pledged to \nsubmit a partial compliance filing on August 17, 2026 to reflect PJM’s continuous and \nongoing efforts to implement the Commission’s reforms.51   \nThe Commission issued a notice on August 14, 2026 granting PJM’s requested \nextension and abeyance.52  This filing represents PJM’s partial compliance filing with the \nJune Order, as outlined in the July 28, 2026 motion for extension of time. \n \nDESCRIPTION OF CHANGES  \nA. \nProhibition on Serving Co-Located Load from Existing Generators \nThe June Order directed PJM to explain in its compliance filing how its changes \nwill prohibit Interconnection Customers from serving Co-Located Loads from new and \nexisting generators until all necessary Network Upgrades, control technologies and/or \n \n47 Id. at 4-6. \n48 Id. at 6.  PJM also moved to hold the Large Load proceeding in abeyance for 90 days.  PJM Interconnection, \nL.L.C., Motion of PJM Interconnection, L.L.C. to Hold Proceeding in Abeyance and Request for Shortened \nAnswer Period and Expedited Treatment, Docket No. EL26-67-000 (July 28, 2026). \n49 PJM Extension Motion at 4-5. \n50 Id. \n51 Id. at 5-7. \n52 PJM Interconnection, L.L.C., Notice of Extension of Time, Docket Nos. EL25-49-002, et al. (Aug. 14, \n2026)."},{"page":11,"startToken":3139,"endToken":3535,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 11 \n \nprotection systems, and metering are complete and in service.53  This compliance filing \nproposes to add Necessary Study references and provisions to Parts I, III, VI, and VII, and \nto direct Generation Project Developers seeking to serve Co-Located Load with an existing \nCo-Located Generating Facility to the Necessary Study process in Part VIII, Subpart A, \nsection 401(H)(3).54  In its Sixty-Day Compliance Filing, PJM proposed to add language \nto Part VIII for the Necessary Study process to preclude a Project Developer from \nimplementing any planned modifications to its facilities until the Necessary Studies are \ncompleted and the amended GIA reflecting the results of such studies is fully executed and \neffective; the Sixty-Day Compliance Filing also provided that service to the Co-Located \nLoad could not begin until “all required Network Upgrades, necessary control technologies \nand protection systems, and metering identified as necessary are complete and in \nservice.”55  Thus, the Tariff would now require that all Interconnection Customers and \nGeneration Project Developers seeking to serve Co-Located Load, whether with existing \nor new Generating Facilities:  (1) provide advance written notice to PJM and the relevant \nTransmission Owner; (2) go through the Necessary Study process in Part VIII of the Tariff; \nand (3) not begin serving Eligible Load until the entire scope of the work under their GIA \nas amended after the Necessary Study process is complete.  These combined revisions \n \n53 June Order at P 285. \n54 See proposed Tariff, Part I, section 1 (Definitions L-M-N) (adding the definitions of “Necessary Study” \nand “Necessary Studies Agreement”); id., Part III (General) (addition of notice requirement); id., Part VI, \nSubpart B, section 212 (same); id., Part VII, Subpart A, section 301(A)(7)(c) (same).   \n55 Sixty-Day Compliance Filing, proposed Tariff Revisions (Attachments A & B), Part VIII, Subpart A, \nsections 401(H)(3)(a), 401(H)(3)(b)(iii).  In this compliance filing, PJM proposes to further clarify in \nProposed Tariff, Part VIII, the Necessary Study process by amending the listing of required and necessary \nequipment changes to instead reference “the entire scope of work required under that amended Generation \nInterconnection Agreement.”  Proposed Tariff, Part VIII, Subpart A, section 401(H)(3)(d).  This ensures that \nall items determined to be necessary and therefore captured in the amended GIA are complete before the \nProject Developer may begin serving Eligible Load."},{"page":12,"startToken":3535,"endToken":3873,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 12 \n \nensure that all these entities are treated comparably and the prohibition on serving Co-\nLocated Loads before all the necessary upgrades and equipment changes are complete is \nenforced across the board.56   \nB. \nRevisions to Retail Behind the Meter Generation Definition \nIn the Sixty-Day Compliance Filing, PJM had proposed to define Retail BTMG as \nload being served by a generation facility with a nameplate capacity of 50 MW or less.57  \nPJM also proposed to implement various exemptions from the netting limit for a transition \nperiod, contractual rights, and qualifying facilities under Public Utility Regulatory Policies \nAct via the Retail BTMG definition.58  The June Order, however, rejected PJM’s proposed \n50 MW limit and instead directed PJM to permit Retail BTMG netting up to a 50 MW \nmateriality threshold.59  Consistent with the extension motion, PJM is continuing to work \nwith stakeholders to develop Tariff language to implement the 50 MW netting provisions \nfor Retail BTMG.  However, for purposes of allowing Eligible Customers with load served \nby Retail BTMG to take Interim NITS,60 PJM is proposing a revised definition of Retail \n \n56 PJM also proposes herein formatting and language changes to the Necessary Study provisions in Part VIII, \nSubpart A, section 401(H)(3), to make clear that the Necessary Study process applies to all Project \nDevelopers that plan to make modifications to their facilities, “including but not limited to a Project \nDeveloper whose planned modifications include an Eligible Load configuration.”  Proposed Tariff, Part VIII, \nSubpart A, section 401 (H)(3)(a).  PJM further proposes minor, ministerial changes to Tariff, Part VIII to \nspell out the term “Generation Interconnection Agreement” and replace “PJM” with “Transmission \nProvider,” as appropriate.  See, e.g., proposed Tariff, Part VIII, Subpart C, section 408 (A)(2)(e)(i)(j)(iv); id., \nPart VIII, Subpart E, sections 414(B)(2), 414(B)(4)(c). \n57 Sixty-Day Compliance Filing at 4-16. \n58 Id. \n59 June Order at PP 207, 220. \n60 Id. at P 91."},{"page":13,"startToken":3873,"endToken":4192,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 13 \n \nBTMG that eliminates the rejected 50 MW nameplate limit and other netting exemptions \nthat will be added elsewhere in a future compliance filing.61  \nC. \nExpansion of Service to “Eligible Load” for Load with BTMG \nThe June Order directed PJM to expand the availability of the December Order’s \nnew transmission services to Network Customers serving load with BTMG that are willing \nand able to limit their withdrawals from the Transmission System under certain \ncircumstances.62  The Commission directed PJM to either add a definition of “Eligible \nLoad” or propose other changes to implement this directive.63  Consistent with this \ndirective, PJM is proposing to add the term Eligible Load to the Tariff to encompass both \nCo-Located Load and Load with BTMG.64  To that end, PJM is proposing to add to the \nTariff, Part I, section 1, Definitions the term “Eligible Load” defined as “Co-Located Load \nor load connected to Behind the Meter Generation.”65  Further consistent with the \nCommission’s directive to propose other Tariff changes necessary to expand the \navailability of these new services, PJM is proposing to add to the term “Eligible Generating \nFacility” to the Tariff to encompass both a Co-Located Generating Facility or Retail \nBTMG.66  In addition, PJM is proposing conforming changes to replace “Co-Located \n \n61 Proposed Tariff, Part I, section 1 (Definitions R - S) (adding the definition of “Retail Behind The Meter \nGeneration”); id., Part VIII, Subpart A, section 400, Definitions R. \n62 June Order at P 91. \n63 Id. \n64 Proposed Tariff, Part I, section 1 (Definitions E - F) (adding the definition of “Eligible Load”). \n65 Id. \n66 “‘Eligible Load’ shall mean Co-Located Load or load connected to Behind the Meter Generation. ‘Eligible \nGenerating Facility’ shall mean a Co-Located Generating Facility or Retail Behind the Meter Generation.”  \nProposed Tariff, Part I, section 1 (Definitions E – F) (defining “Eligible Load” and “Eligible Generating \nFacility”)."},{"page":14,"startToken":4192,"endToken":4637,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 14 \n \nLoad” with “Eligible Load” and “Co-Located Generator” with “Eligible Generator” and \nother clarifying changes in Tariff Part I, section 1 (Definitions),67 Part III (Network \nIntegration Transmission Service),68 Part VI (Administration and Study of New Service \nRequests),69 Part VII (Transition Cycle Generation Interconnection Procedure),70 Part VIII \n(New Rules Generation Interconnection Procedure),71 Part IX (Forms of Interconnection-\n \n67 Proposed Tariff, Part I, section 1 (Definitions O – P – Q) (updating the definition of “Provisional \nInterconnection Service” to reference “Eligible Load” instead of just “Co-Located Load”). \n68 Proposed Tariff, Part III, sections 28.1 (replacing “Co-Located Load” with “Eligible Load”); section 29.1 \n(allowing customers to take NITS on behalf of “Eligible Load” instead of “Co-Located Load”); id., Part III, \nsection 29.2 (replacing “Co-Located Load” with “Eligible Load” in application procedures); id., Part III, \nsection 31.6 (replacing “Co-Located Load” with “Eligible Load” in annual load and resource information \nupdate). \n69 Proposed Tariff, Part VI, Subpart B, section 212 (adding language in Part VI, Subpart B, section 212 \nregarding the Necessary Study process in Part VIII for Generating Facilities to reference service to Eligible \nLoads). \n70 Proposed Tariff, Part VII, Subpart A, section 300, Definitions P (adding the definitions for “Eligible Load” \nand “Eligible Generating Facility”); id., Part VII, Subpart A, section 300, Definitions P (revising the \ndefinition of “Provisional Interconnection Service” to reference “Eligible Generating Facility” and “Eligible \nLoad”). \n71 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions E (adding the definitions for “Eligible Load” \nand “Eligible Generating Facility”); id., Part VIII, Subpart A, section 400, Definitions P (updating the \ndefinition of “Provisional Interconnection Service” to reference “Eligible Generating Facility” and “Eligible \nLoad”); id., Part VIII, Subpart A, section 401 (revising the application requirements to allow Eligible \nGenerating Facilities serving Eligible Load and clarifying the Necessary Studies process applies to Eligible \nLoad); id., Part VIII, Subpart B, section 403 (revising the application rules to allow Eligible Generating \nFacilities serving Eligible Load); id., Part VIII, Subpart C, section 404 (updating the System Impact Studies \nto contemplate service to Eligible Load); id., Part VIII, Subpart C, section 406 (updating the acceleration \nlanguage to allow acceleration of new service requests for new facilities or increases the generation capability \nin existing facilities to serve Eligible Load); id., Part VIII, Subpart C, section 408 (same); id., Part VIII, \nSubpart E, section 413 (updating the language permitting service requests below the maximum facility output \nfor new facilities or increases the generation capability in existing facilities that will serve Eligible Load); \nid., Part VIII, Subpart E, section 414 (updating the language to permit Surplus Interconnection Service for \nEligible Load)."},{"page":15,"startToken":4637,"endToken":5104,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 15 \n \nRelated Agreements),72 and Part XI, Subpart A (Interim Network Integration Transmission \nService).73 \nD. \nElimination of New GIA Requirement \nPJM previously proposed to require all Eligible Customers that intend to serve Co-\nLocated Load with a new or existing Co-Located Generating Facility to enter into a new \nGIA pursuant to Part VIII of the Tariff, which was revised to include additional details \nregarding the Necessary Studies process.74  The June Order rejected this proposal for \ncustomers with existing service agreements and directed PJM to add language concerning \nthe Necessary Study process to Tariff, Parts VI and VII to allow customers with existing \nservice agreements to modify those agreements.75  Accordingly, PJM is proposing changes \nto allow customers that obtained service agreements pursuant to Parts VI and VII to modify \nthose agreements pursuant to the Necessary Study process in Part VIII.76  \n \n72 Proposed Tariff, Part IX, Subpart A (Form of Application and Studies Agreement), section 1 (revising \nsection 1 of the Application and Studies Agreement to collect applicant information for an Eligible \nGenerating Facility serving Eligible Load); id., Part IX, Subpart A (Form of Application and Studies \nAgreement), section 3.17 (changing “PJM” to “Transmission Provider” and clarifying all transmission \nservice requests in the PJM Region are subject to the same deliverability tests); id., Part IX, Subpart B, GIA \nAppendices and Schedules, Schedule O (updating Schedule O to replace “Eligible Load” with “Eligible \nGenerating Facility”); id., Part XI, Subpart G, Necessary Studies Agreement (updating the Necessary Studies \nAgreement to reference “Eligible Load” and “Eligible Generating Facility”).  \n73 Proposed Tariff, Part XI, Subpart A, section 700 (updating references to “Co-Located Load” to “Eligible \nLoad”); id., Part XI, Subpart A, section 701.1 (same); id., Part XI, Subpart A, section 701.2 (same); id., Part \nXI, Subpart A, section 701.3 (same); id., Part XI, Subpart A, section 702.1 (same); id., Part XI, Subpart A, \nsection 702.4 (same); id., Part XI, Subpart A, section 703 (same). \n74 See June Order at P 284; proposed Tariff, Part VIII, Subpart A, section 401(H)(3). \n75 June Order at P 311. \n76 See supra note 54 concerning addition of Necessary Study language to Parts I, III, VI, and VII; proposed \nTariff, Part VIII, Subpart A, section 401(I).  PJM also proposes to cross-reference Tariff, Part VIII, Subpart \nL, section 439, Provisional Interconnection Service, added in the Thirty-Day Compliance Filing, in Parts VI \nand VII to clarify that Provisional Interconnection Service is available to entities that obtained \nInterconnection Service under those Parts.  See proposed Tariff, Part I, section 1 (Definitions O – P – Q) \n(updating the definition of “Provisional Interconnection Service”); id., Part VII, Subpart A, section 300, \nDefinitions P (same); id., Part VIII, Subpart A, section 400, Definitions P (same)."},{"page":16,"startToken":5104,"endToken":5450,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 16 \n \nFor Interconnection Customers that utilized the Part VI process, because Part VI \ndoes not contain discrete definitions, PJM is revising the proposed definition of Co-Located \nGenerating Facility in Part I to include an existing Customer Facility that is physically \nconnected to Co-Located Load to incorporate the relevant terms from Part VI.77  As \nexplained above, to ensure that existing Interconnection Customers with effective ISAs do \nnot serve Co-Located Load until all necessary upgrades and equipment are in place,78 PJM \nis also adding to the Co-Located Generating Facility definition a requirement to provide \nadvance written notice to the Transmission Provider and Transmission Owner to initiate \nthe Necessary Study process pursuant to Part VIII, Subpart A, section 401(H)(3)(b) to use \na Customer Facility to serve Co-Located Load.79  In addition, PJM is adding language to \nmirror this Necessary Study process requirement in Part VI, Subpart B, section 212.80  \nFinally, PJM has updated the pro forma Necessary Studies Agreement to include language \nfor Queue No., reference Part VI for ISAs, incorporate references to Interconnection \nCustomers throughout, and reference Tariff, Attachment O, Appendix 2, section 3 in \nparagraph 5 concerning the purpose of the Necessary Studies.81 \nFor Generation Project Developers that utilized the Part VII Transition Cycle \nInterconnection Process, PJM is proposing to modify the definition of Co-Located \n \n77 Proposed Tariff, Part I, section 1 (Definitions C - D) (revising the definition of “Co-Located Generating \nFacility”). \n78 June Order at P 285. \n79 Proposed Tariff, Part I, section 1 (Definitions C - D) (adding to the definition of “Co-Located Generating \nFacility”). \n80 Proposed Tariff, Part VI, Subpart B, section 212.  PJM also proposes to add new Tariff, Part VIII, Subpart \nA, section 401(I) to clarify that Interconnection Customers with ISAs under Tariff, Part VI may utilize the \nPart VIII Necessary Study process and will be referred to as Project Developers or Generation Project \nDevelopers and their agreements referred to as Generation Interconnection Agreements when doing so. \n81 Proposed Tariff, Part IX, Subpart G, Necessary Studies Agreement."},{"page":17,"startToken":5450,"endToken":5770,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 17 \n \nGenerating Facility to include both an existing and planned Generating Facility.82  \nConsistent with the proposed changes in Part VI, PJM is adding a requirement to provide \nTransmission Provider and Transmission Owner with advance written notice to initiate the \nNecessary Study process pursuant to Part VIII, Subpart A, section 401(H)(3)(b) in the event \na Generation Project Developer with an effective GIA intends to use a Generation Facility \nto serve Co-Located Load.83  PJM is also adding this advance notice requirement for the \nNecessary Study process to Tariff, Part VII, Subpart A, section 301(A)(7)(c).84  Finally, \nPJM is proposing a definition of Co-Located Load that references the relevant terms for \nPart VII of the Tariff (i.e., Generating Facility and Project Developer).85  \nE. \nInterim NITS \nPJM is proposing the terms and conditions for Interim NITS in new Part XI of the \nTariff.86  The Part XI largely adopts the terms and conditions proposed during the paper \nhearing subject to certain changes directed in the June Order and other clarifications.   \nFirst, consistent with the June Order,87 PJM clarified in section 701.1 that an \nInterim NITS customer will be converted automatically to a NITS customer upon \ncompletion of the relevant Network Upgrades and once the Transmission Provider updates \nits system to reflect those upgrades.88  The language concerning the internal system updates \n \n82 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C (definition of Co-Located Generating \nFacility). \n83 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C (definition of Co-Located Generating \nFacility). \n84 Proposed Tariff, Part VII, Subpart A, section 301(A)(7)(c); id., Subpart A, section 300, Definitions N. \n85 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C. \n86 Proposed Tariff, Part XI. \n87 June Order at P 571. \n88 Proposed Tariff, Part XI, Subpart A, section 701.1."},{"page":18,"startToken":5770,"endToken":6069,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 18 \n \nwas added to clarify that the conversion does not happen automatically the moment the \nconstruction of the Network Upgrades is complete but must first be reflected in PJM’s \ninternal systems. \nSecond, consistent with the June Order,89 PJM revised the language in section 705.2 \nto clarify the curtailment priority for Interim NITS relative to Non-Firm Point to Point \nService and that it will prioritize customers for curtailment based on duration of service as \nspecified in the PJM Manuals.90  As the Commission directed,91 PJM also added language \nto specify that Eligible Customers subject to curtailment may use a Co-Located Generating \nFacility to serve Co-Located Load provided the facility either has not obtained \ninterconnection service yet or the facility is not a capacity resource.92 \nThird, consistent with the June Order,93 PJM revised the operational penalties for \nfailure to follow dispatch instructions or misoperation of control technologies to suspend \nservice for up to 120 days after the first instance and terminate service after the second.94  \nFourth, consistent with the June Order,95 PJM added language in section 705.1 and \nto the Part I definition of Curtailment to clarify that with respect to Tariff, Part XI, its \nCurtailment authority includes the authority to curtail Interim NITS for capacity or reserve \nshortages.96 \n \n89 June Order at P 555. \n90 Proposed Tariff, Part XI, Subpart A, section 705.2. \n91 June Order at P 576. \n92 Proposed Tariff, Part XI, Subpart A, section 705.2. \n93 June Order at PP 516, 523-24, 527. \n94 Proposed Tariff, Part XI, Subpart A, section 705.6. \n95 June Order at P 551. \n96 Proposed Tariff, Part I, section 1 (Definitions C - D); proposed Tariff, Part XI, Subpart A, section 705.1."},{"page":19,"startToken":6069,"endToken":6339,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 19 \n \nFifth, consistent with the June Order,97 PJM added language in section 705.5 on \nNecessary Control Technologies and Protection Systems to specify that such technologies \ninclude telemetry, data exchange, and metering for the Transmission Provider to monitor \nthe Eligible Customer’s use of the Transmission System, limit withdrawals, and ensure \nrelay settings are consistent with necessary control technologies and/or protection \nsystems.98    \nFinally, PJM made the following additional clarifying edits: \n• Section 701.1:  PJM added a cross-reference to Part XI, Subpart A, section \n702.3 to clarify that Eligible Customers may receive Interim NITS consistent \nwith the Transmission Provider’s determination as to the amount of service that \ncan be reliably provided.99  PJM also omitted language referencing Firm \nContract Demand Service and Non-Firm Contract Demand Service, as those \nservices will be implemented in a later compliance filing.100 \n• Section 701.2:  PJM struck the term “capacity” from this section because \nInterim NITS is an energy-only service.101 \n• Section 701.3:  PJM struck the term “capacity” from this section because \nInterim NITS is an energy-only service.102 \n• Section 702.3:  PJM clarified that the Transmission Provider will determine the \namount of Interim NITS that can be reliably provided to an Eligible \nCustomer.103 \n \n97 June Order at P 541. \n98 Proposed Tariff, Part XI, Subpart A, section 705.5. \n99 Proposed Tariff, Part XI, Subpart A, section 701.1. \n100 Id. \n101 Proposed Tariff, Part XI, Subpart A, section 701.2. \n102 Proposed Tariff, Part XI, Subpart A, section 701.3. \n103 Proposed Tariff, Part XI, Subpart A, section 702.3."},{"page":20,"startToken":6339,"endToken":6644,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 20 \n \n• Section 705:  PJM eliminated the section on “Load Shedding” as it was no \nlonger needed due to the clarifications regarding the nature of Interim NITS \n(i.e., that the service is non-firm in nature).104 \n• Section 705.4:  PJM added language to clarify that the Transmission Provider \nmay curtail Interim NITS for the purpose of undertaking scheduled system \nupgrades and maintenance.105 \nF. \nOther Commission Ordered Changes \nPJM implemented other compliance changes specified in the June Order as follows: \nJune Order Directive \nPJM Compliance Change \nReject the Tariff provisions proposing \nthat Co-Located Load that is not served \nby \nan \nEligible \nCustomer \ntaking \ntransmission service on its behalf “must \ntake all necessary steps to disconnect \nfrom the Transmission System,” as this \nprovision is duplicative of PJM’s \nproposed changes to Part VIII, Subpart \nB, section 403(A)(1)(r)(iv).106 \nStruck language from Tariff, Part III \n(General).107 \n \nDetail the specific provisions in the PJM \nManuals concerning Necessary Studies \nto which the proposed Tariff language \nrefers.108 \nRevised Tariff, Part VIII, Subpart A, section \n401(H)(3)(c) to reference specific provisions \nof the PJM Manuals. 109 \n \nRevise Tariff to remove the requirement \nfor Interconnection Customers with \nexisting ISAs pursuant to Part VI of the \nTariff and GIAs pursuant to Part VII of \nthe Tariff to enter into a new pro forma \nGIA.110 \nStruck language from Tariff, Part III \n(General).111 \n \n \n104 Proposed Tariff, Part XI, Subpart A, sections 705, 705.3. \n105 Proposed Tariff, Part XI, Subpart A, section 705.4. \n106 June Order at P 264. \n107 See proposed Tariff, Part III (General). \n108 June Order at P 280. \n109 Proposed Tariff, Part VIII, Subpart A, section 401(H)(3)(c). \n110 June Order at P 284. \n111 See proposed Tariff, Part III (General)."},{"page":21,"startToken":6644,"endToken":6935,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 21 \n \nJune Order Directive \nPJM Compliance Change \nReject increase in cost for Necessary \nStudies Agreement.112 \nRemoved proposed cost increase from pro \nforma Necessary Study Agreement.113 \n \nRevise the Tariff’s definition of Co-\nLocated \nLoad \nto \nuse \n“Point \nof \nInterconnection” instead of “Point of \nChange in Ownership.”114 \nRevised Co-Located Load definition in Parts \nI115 and VII.116 \n \nRemove the following requirement from \nthe definition of Co-Located Generating \nFacility:  “If such a Generation Project \nDeveloper \nhas \nan \neffective \nInterconnection \nService \nAgreement \npursuant to Tariff, Part VI or a \nGeneration Interconnection Agreement \npursuant to Tariff, Part VII, such \nagreement must be superseded by a \nGeneration Interconnection Agreement \npursuant to Tariff, Part VIII and the pro \nforma GIA in Part IX, Subpart B,”117 \nStruck language from the definition in Parts \nVII and VIII.118 \n \n \nAdd to Part III a requirement that \nInterconnection Customers with ISAs or \nGIAs executed (or requested to be filed \nunexecuted) prior to the effective date of \nthe revised generation interconnection \nprocedures and pro forma GIA directed \nin December Order that wish to add Co-\nLocated Load or are currently serving \nCo-Located Load publicly notify PJM of \nthat addition and identify the Eligible \nCustomer that will take transmission \nAdded public notice requirement to Part III \n(General).120 \n \n112 June Order at P 288. \n113 See proposed Tariff, Part IX, Subpart G, Necessary Study Agreement. \n114 June Order at P 308. \n115 Proposed Tariff, Part I, section 1, Definitions C-D. \n116 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C. \n117 Id. at P 311. \n118 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C; id., Part VIII, Subpart A, section 400, \nDefinitions C.  \n120 Proposed Tariff, Part III (General)."},{"page":22,"startToken":6935,"endToken":7196,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 22 \n \nJune Order Directive \nPJM Compliance Change \nservice on behalf of that Co-Located \nLoad.119 \nRevise the Tariff to remove PJM’s \nproposed revisions to the definition of \nNon-Retail BTMG consistent with the \nDecember Order’s determination.121  \nRejected changes in Part I, section 1 \n(Definitions L – M – N).122 \n \nRevise Tariff to assess to Eligible \nCustomers taking transmission service \non behalf of Eligible Loads:  (1) \nadministrative \nservice \ncharges; \n(2) \nancillary service charges; (3) black start \nservice charges; (4) regulation charges; \nand (5) any redispatch costs.123 \n \nIncluded in Interim NITS provisions in Part \nXI.124 \nG. \nEffective Date Only \nPJM previously proposed compliance changes in the Sixty-Day Compliance Filing \nthat were accepted in the June Order.125  However, given the uncertainty surrounding \naspects of the Sixty-Day Compliance Filing, PJM had not proposed a specific effective \ndate for those changes.126  Accordingly, PJM is filing the following Tariff records with a \nproposed effective date of October 17, 2026: \n• Part I, section 1, Definitions A-B (Behind the Meter Generation);127  \n \n119 June Order at P 311. \n121 June Order at P 314. \n122 Proposed Tariff, Part I, section 1, Definitions L-M-N (rejecting changes in the definition of “Non-Retail \nBTMG”). \n123 June Order at P 573. \n124 Proposed Tariff, Part XI, Subpart A, section 706. \n125 See, e.g., June Order at P 207 & n.519. \n126 Sixty-Day Compliance Filing at 35. \n127 Proposed Tariff, Part I, section 1 (Definitions A – B) (updating the definition of “Behind the Meter \nGeneration”); June Order at P 207 n.519."},{"page":23,"startToken":7196,"endToken":7500,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 23 \n \n• Part III, section 34.3 (Netting of Non-Retail BTMG);128 \n• Part VII, Subpart A, section 300, Definitions B (BTMG);129 \n• Part VIII, Subpart A, section 400, Definitions B (BTMG);130 and \n• Part VIII, Subpart A, section 400, Definitions N (Necessary Study).131 \n \nEFFECTIVE DATE AND WAIVER REQUEST \nIn accordance with the Commission’s regulations,132 PJM requests an effective date \nfor the compliance changes in Parts I, III, VI, VII, VIII, and IX of the Tariff of \nOctober 17, 2026, which is 61 days after the date of this filing.   \nConsistent with the Commission’s directive to consider whether Interim NITS \ncould be implemented earlier than originally proposed,133 PJM is proposing an effective \ndate of July 1, 2028, for the new Part XI regarding the provision of Interim NITS.  At \npresent, PJM can provide partial NITS, i.e., NITS in an amount less than requested and/or \nfor a term shorter than requested, to Co-Located Load through the Necessary Study process \nand therefore is proposing an October 17, 2026 effective date for the bulk of the revisions \nproposed in this filing.  However, PJM Operations personnel will need to implement \nadditional tools and processes before they will be able to monitor and curtail, as needed, \nthe new non-firm Interim NITS product proposed in Tariff, Part XI.  PJM anticipates it will \nbe able to develop, procure, and implement those tools and processes by mid-2028, and \n \n128 Proposed Tariff, Part III, section 34.3. \n129 Proposed Tariff, Part VII, Subpart A, section 300, Definitions B. \n130 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions B. \n131 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions N; June Order at P 280 n.670. \n132 18 C.F.R. § 35.3(a)(1). \n133 June Order at P 597."},{"page":24,"startToken":7500,"endToken":7582,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 24 \n \ntherefore proposes the July 1, 2028 effective date for the new Interim NITS product.  \nBecause this effective date is more than 120 days after the date of filing, PJM respectfully \nrequests waiver of 18 C.F.R. § 35.3(a)(1) to file the proposed new Tariff, Part XI now. \n \nDOCUMENTS ENCLOSED \nIn addition to this transmittal letter, PJM encloses the following: \n1. \nAttachment A: \nTariff Redline; and \n2. \nAttachment B: \nClean Tariff."},{"page":25,"startToken":7582,"endToken":7870,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 25 \n \n \nCORRESPONDENCE AND COMMUNICATIONS \nCorrespondence and communications with respect to this filing should be sent to, \nand PJM requests the Secretary to include on the official service list, the following:134 \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 423-4743  \ncraig.glazer@pjm.com \n \nWendy B. Warren \nRuth M. Porter \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 393-1200  \nwarren@wrightlaw.com \nporter@wrightlaw.com \n \nMark J. Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd, \nAudubon, PA 19403 \n(610) 666-8800 \nmark.stanisz@pjm.com \n \n \n \nSERVICE \nPJM has served a copy of this filing on all PJM Members and on the affected state \nutility regulatory commissions in the PJM Region by posting this filing electronically.  In \naccordance with the Commission’s regulations,135 \n \nPJM will post a copy of this filing to \nthe Commission filings section on its internet site, https://pjm.com/library/filing-order, and \nwill send an email on the same date as this filing to all PJM Members and all state utility \nregulatory commissions in the PJM Region,136 alerting them that this filing has been made \n \n134 To the extent necessary, PJM requests waiver of Rule 203(b)(3) of the Commission’s Rules of Practice \nand Procedure, 18 C.F.R. § 385.203(b)(3), to permit all of the persons listed to be placed on the official \nservice list for this proceeding. \n135 See 18 C.F.R. §§ 35.2(e) & 385.2010(f)(3). \n136 PJM already maintains, updates, and regularly uses email lists for all PJM Members and affected state \ncommissions."},{"page":26,"startToken":7870,"endToken":8027,"text":"Honorable Debbie-Anne A. Reese  \nAugust 17, 2026 \nPage 26 \n \nby PJM and is available by following such link.  If the document is not immediately \navailable by using the referenced link, the document will be available through the \nreferenced link within 24 hours of the filing. \n \nCONCLUSION \nPJM respectfully requests that the Commission accept this compliance filing as it \ncomplies with the requirements of the June Order. \nRespectfully submitted, \n/s/ Wendy B. Warren \n \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n202-423-4743 \ncraig.glazer@pjm.com \n \nMark J. Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd, \nAudubon, PA 19403 \n(610) 666-8800 \nmark.stanisz@pjm.com \n \n \nAugust 17, 2026 \n \nWendy B. Warren \nRuth M. Porter \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005-3898 \n202-393-1200 \nwarren@wrightlaw.com \nporter@wrightlaw.com \n \n \n \n \n \n \nCounsel for \nPJM Interconnection, L.L.C."},{"page":27,"startToken":8027,"endToken":8096,"text":"CERTIFICATE OF SERVICE \nI hereby certify that I have this 17th day of August 2026 caused a copy of the \nforegoing document to be served upon each person designated on the official service list \ncompiled by the Secretary in this proceeding. \n/s/ Ruth M. Porter \n \nRuth M. Porter \nWright & Talisman, P.C. \n1200 G Street, N.W., Suite 600 \nWashington, D.C.  20005 \n(202) 393-1200 (phone) \nporter@wrightlaw.com"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":1368,"startToken":0,"endToken":958},{"p":3,"at":1368,"title":"INTRODUCTION","method":"printed heading","endPage":3,"endAt":1383,"startToken":958,"endToken":959},{"p":3,"at":1383,"title":"A. Commission December Order","method":"printed heading","endPage":5,"endAt":651,"startToken":959,"endToken":1422},{"p":5,"at":651,"title":"B. PJM Compliance Filings","method":"printed heading","endPage":6,"endAt":1775,"startToken":1422,"endToken":1843},{"p":6,"at":1775,"title":"IX. The May 18 Compliance Filing established an effective date of April 16, 2026 in accordance with the","method":"printed heading","endPage":8,"endAt":60,"startToken":1843,"endToken":2254},{"p":8,"at":60,"title":"C. The Commission’s June Order","method":"printed heading","endPage":8,"endAt":1002,"startToken":2254,"endToken":2399},{"p":8,"at":1002,"title":"D. Large Load Order","method":"printed heading","endPage":9,"endAt":1257,"startToken":2399,"endToken":2731},{"p":9,"at":1257,"title":"E. Partial Extension","method":"printed heading","endPage":10,"endAt":1096,"startToken":2731,"endToken":3009},{"p":10,"at":1096,"title":"A. Prohibition on Serving Co-Located Load from Existing Generators","method":"printed heading","endPage":12,"endAt":269,"startToken":3009,"endToken":3576},{"p":12,"at":269,"title":"B. Revisions to Retail Behind the Meter Generation Definition","method":"printed heading","endPage":13,"endAt":211,"startToken":3576,"endToken":3906},{"p":13,"at":211,"title":"C. Expansion of Service to “Eligible Load” for Load with BTMG","method":"printed heading","endPage":15,"endAt":163,"startToken":3906,"endToken":4660},{"p":15,"at":163,"title":"D. Elimination of New GIA Requirement","method":"printed heading","endPage":17,"endAt":856,"startToken":4660,"endToken":5587},{"p":17,"at":856,"title":"E. Interim NITS","method":"printed heading","endPage":20,"endAt":451,"startToken":5587,"endToken":6410},{"p":20,"at":451,"title":"F. Other Commission Ordered Changes","method":"printed heading","endPage":22,"endAt":700,"startToken":6410,"endToken":7037},{"p":22,"at":700,"title":"G. Effective Date Only","method":"printed heading","endPage":24,"endAt":426,"startToken":7037,"endToken":7572},{"p":24,"at":426,"title":"Attachment A:","method":"printed heading","endPage":24,"endAt":466,"startToken":7572,"endToken":7578},{"p":24,"at":466,"title":"Attachment B:","method":"printed heading","endPage":26,"endAt":280,"startToken":7578,"endToken":7915},{"p":26,"at":280,"title":"CONCLUSION","method":"printed heading","endPage":27,"endAt":0,"startToken":7915,"endToken":8027},{"p":27,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":27,"endAt":405,"startToken":8027,"endToken":8096}]}