ER26-1479-002 · 2026-08-17 · PJM

PJM partial compliance filing in response to the June 18, 2026 order on rehearing in EL25-49-002 et al.

1200 G Street, N.W., Suite 600 
Washington, D.C.  20005-3898 
Phone: 202.393.1200 
Fax: 202.393.1240 
wrightlaw.com 
 
August 17, 2026 
 
Honorable Debbie-Anne A. Reese 
Secretary  
Federal Energy Regulatory Commission  
888 First Street, NE, Room 1A 
Washington, DC 20426 
 
Re: 
PJM Interconnection, L.L.C., Docket Nos. ER26-1479-001 
Compliance Filing of PJM Interconnection, L.L.C. in Response to Order on 
Rehearing, Clarification, Compliance Filing, and Paper Hearing in Docket 
Nos. EL25-49-002, et al. 
 
Dear Secretary Reese: 
Pursuant to section 206 of the Federal Power Act,1 PJM Interconnection, L.L.C. 
(“PJM”) hereby submits proposed revisions to the PJM Open Access Transmission Tariff 
(“Tariff”)2 in accordance with the Federal Energy Regulatory Commission’s 
(“Commission”) directives in its June 18, 2026, Order on Rehearing, Clarification, 
Compliance Filing, and Paper Hearing (“June Order”) 3 in Docket No. EL25-49-002, et al.4  
As discussed below, PJM proposes an effective date for the Tariff revisions in Parts I, III, 
 
1 16 U.S.C. § 824e. 
2 Capitalized terms not otherwise defined herein have the meaning set forth in PJM’s Open Access 
Transmission Tariff (“Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, 
L.L.C.  
3 PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026). 
4 PJM’s submission of this partial compliance filing overlaps with a broader reform framework that the 
Commission’s Large Load Order (as defined below) invites.  PJM is identifying, with stakeholder 
engagement, what changes to its Tariff may be needed on a holistic basis to develop a Federal Power Act 
section 205 filing to fully respond to the Large Load Order.  PJM intends to submit that filing by mid-
November 2026.  Today’s partial compliance filing should not be construed to, and is in no way intended to, 
limit the reforms PJM will pursue to meet the challenges of the moment and resolve the Commission’s 
preliminary findings in the Large Load Order.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 2 
 
VI, VII, VIII, and IX of October 17, 2026, 61 days after the date of this filing.5  For the 
new Interim Network Integration Transmission Service (“Interim NITS”) provisions in 
Part XI of the Tariff, PJM proposes an effective date of July 1, 2028, to provide time for 
operational changes and implementation of additional operational tools that will be needed 
to curtail non-firm Interim NITS. 
Consistent with the directives of the June Order, PJM proposes compliance changes 
to: 
• Modify the definitions of Co-Located Load, Behind the Meter Generation 
(“BTMG”), and Necessary Study, as directed;6 
• Modify the definition of Retail BTMG to eliminate the 50 megawatts (“MW”) 
nameplate limit for netting;7  
• Add a definition of Eligible Load and Eligible Generating Facility to Tariff, 
Part I, section 1 (Definitions) to make Interim NITS available to Eligible 
Customers serving Co-Located Load or load connected to BTMG and make 
conforming changes to incorporate these new terms in Parts III, VI, VII, VIII, 
IX, and XI;8 
• Remove the requirement for existing customers to enter into a new Generation 
Interconnection Agreement (“GIA”) to serve Co-Located Load, make 
corresponding changes to Parts VI and VII to allow existing service agreements 
 
5 This requested effective date applies to the Tariff revisions proposed herein (except for new Tariff, Part 
XI), as well as to the Tariff revisions proposed without effective dates in the Thirty-Day Compliance Filing, 
the Sixty-Day Compliance Filing, and the May 18 Compliance Filing and accepted in the April 16 Order and 
the June Order.  See PJM Interconnection, L.L.C., Thirty-Day Compliance Filing with Order on Show Cause 
of PJM Interconnection, L.L.C., Docket No. ER26-1088-000 (Jan. 20, 2026) (“Thirty-Day Compliance 
Filing”); PJM Interconnection, L.L.C., 60-day Compliance Filing for Co-Located Load Related Revisions to 
Open Access Transmission Tariff to Comply with Commission Order in Docket No. EL25-49, et al. of PJM 
Interconnection, L.L.C., Docket No. ER26-1479-000 (Feb. 23, 2026) (“Sixty-Day Compliance Filing”); PJM 
Interconnection, L.L.C., Compliance Filing to the Commission’s April 16 Order on PJM’s Thirty-Day 
Compliance Filing with the Order to Show Cause of PJM Interconnection, L.L.C., Docket No. ER26-1088-
001 (May 18, 2026) (“May 18 Compliance Filing”); PJM Interconnection, L.L.C., 195 FERC ¶ 61,030 (2026) 
(“April 16 Order”).  All these changes are shown in redline in Attachment A. 
6 June Order at P 207 & n.519 (Behind the Meter Generation); id. at P 280 n.670 (Necessary Studies); id. at 
PP 307 & n.717, 308 (Co-Located Load). 
7 Id. at PP 207, 220. 
8 Id. at P 91.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 3 
 
to be modified to serve Eligible Load via the Necessary Study process, and 
clarify how the Necessary Study requirements and prohibition on service before 
needed upgrades are complete will apply to existing projects that may already 
have Necessary Studies Agreements;9 
• Provide live records for the illustrative Tariff language for Interim NITS in Part 
XI, incorporating certain changes directed by the June Order,10 and additional 
edits to clarify the nature of the service.11 
To improve clarity and consistency in the Tariff and make the Tariff easier to 
understand, PJM also proposes minor revisions to Parts I, III, VI, VII, VIII, IX and X to 
cross-reference Part VIII as needed; make clear that the Provisional Interconnection 
Service and Necessary Study process provided in Part VIII is available to Interconnection 
Customers under Part VI, as well as to Expedited Interconnection Track Project Developers 
under Part X; applies to those entities and to Eligible Customers under Part III; and clarify 
that the use of the terms “Project Developer,” “Generation Project Developer,” and 
“Generation Interconnection Agreement” under Tariff, Part VIII shall be understood to 
reference Interconnection Customers and Interconnection Service Agreements (“ISA”) 
under Part VI, as appropriate. 
 
INTRODUCTION  
A. 
Commission December Order 
On December 18, 2025, the Commission issued the Order on Show Cause 
(“December Order”) finding the Tariff unjust and unreasonable due to the lack of 
 
9 Id. at P 284. 
10 See, e.g., id. at PP 515, 519 (directing PJM to eliminate provisions disqualifying an Eligible Customer from 
taking new transmission services after one instance of failure to follow a curtailment or load shedding 
directive). 
11 See proposed Tariff, Part XI, Subpart A, sections 701, 702, 705.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 4 
 
specificity for the rates, terms, and conditions that apply to Co-Located Load and directing 
PJM to make a number of compliance and informational filings.12   
First, the December Order directed PJM to make a compliance filing within 30 days 
to clarify the rates, terms, and conditions that apply to an Interconnection Customer13 
seeking to serve Co-Located Load with new generation, including with Surplus 
Interconnection Service and Provisional Interconnection Service.14 
Second, the December Order directed PJM to make a compliance filing within 60 days 
to, inter alia, modify the Retail BTMG netting rules to limit netting over a certain 
threshold;15 add certain requirements for Eligible Customers taking transmission service 
on behalf of Co-Located Loads;16 and clarify that existing customers seeking to modify 
ISAs/GIAs to accommodate Generating Facilities serving Co-Located Load must follow 
Necessary Study processes.17    
Third, the December Order ordered a paper hearing to determine the appropriate rates, 
terms, and conditions for the three new transmission service.18  Among other things, the 
Commission asked PJM to address (1) the appropriate rates, terms and conditions for the 
new services; (2) the appropriate rates for customers taking new transmission services for 
 
12 PJM Interconnection, L.L.C., 193 FERC ¶ 61,217, at PP 1-2, 161, 231-36 (2025) (“December Order”). 
13 Under PJM’s current interconnection rules in Tariff, Parts VII, VIII, and IX, Interconnection Customers 
are referred to as “Project Developers.”  PJM uses in this filing the term used in its current interconnection 
rules but it should be understood as consistent with the Commission’s references to Interconnection 
Customers.  
14 December Order at PP 232-35. 
15 Id. at P 221. 
16 Id. at PP 193, 200.  
17 Id. at P 226.  
18 Id. at P 219.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 5 
 
regulation and black start services; (3) the appropriate penalty charge or remedial action 
for unauthorized use of the Transmission System; (4) eligibility requirements and 
anti-toggling mechanisms for Firm Contract Demand Transmission service; (5) 
interconnection requirements and operational practices needed to maintain system 
reliability in the event Co-Located Load or its associated generator trips offline; (6) 
communications, alarm, and Supervisory Control and Data Acquisition requirements for 
Co-Located Load; and (7) appropriate procedures for curtailment and load shed.19 
B. 
PJM Compliance Filings 
1. 
Thirty-Day Compliance Filing 
On January 20, 2026, PJM made its 30-day compliance filing in Docket No. ER26-
1088-000 pursuant to the December Order (“Thirty-Day Compliance Filing”).20  The 
Thirty-Day Compliance Filing proposed to clarify certain aspects of the Tariff for those 
seeking to serve Co-Located Load with new Generating Facilities.21  Among other changes, 
the Thirty-Day Compliance Filing proposed to clarify that existing services in the Tariff 
could be used to serve Project Developers serving Co-Located Load, including Provisional 
Interconnection Service and Surplus Interconnection Service.22  The Thirty-Day 
Compliance Filing also clarified the ability of Project Developers serving Co-Located Load 
to request interconnection service below nameplate capacity and the potential to accelerate 
the interconnection process under certain circumstances.23 
 
19 See id. at P 219. 
20 See generally Thirty-Day Compliance Filing. 
21 Id. at 4-7. 
22 Id. at 5-7. 
23 Id. at 4-5.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 6 
 
On April 16, 2026, the Commission accepted in part and rejected in part PJM’s 
compliance filing.24  The Commission rejected PJM’s revisions to the proposed definition 
of Co-Located Load because PJM’s proposal to deviate from this definition by replacing 
the term “Point of Interconnection” with “Point of Change in Ownership” did not provide 
sufficient explanation as to how this proposed deviation complies with the Commission’s 
directive in the December Order.25  The Commission also rejected proposed Tariff 
revisions relating to BTMG as constituting changes that were outside the scope of the 
original proceeding, and directed PJM to remove revisions that incorporated the term Co-
Located Load into Tariff sections related to BTMG Application Requirements.26  On 
May 18, 2026, PJM submitted a compliance filing to comply with the directives set forth 
in the April 16 Order.27 
2. 
Sixty-Day Compliance Filing 
On February 23, 2026, PJM submitted its 60-day compliance filing in response to 
the December Order (“Sixty-Day Compliance Filing”).28  The Sixty-Day Compliance 
Filing proposed Tariff revisions to:  (1) revise its BTMG Tariff provisions; (2) establish 
three new transmission services for Eligible Customers seeking to take service on behalf 
of Co-Located Load; and (3) revise its necessary studies processes, among other changes.29  
 
24 See generally April 16 Order.  
25 April 16 Order at P 27. 
26 See generally May 18 Compliance Filing; see April 16 Order at P 30. 
27 See generally May 18 Compliance Filing.  Neither the Thirty-Day Compliance Filing nor the Sixty-Day 
Compliance Filing initially proposed an effective date for the Tariff revisions to Parts I, III, VII, VIII, and 
IX. The May 18 Compliance Filing established an effective date of April 16, 2026 in accordance with the 
April 16 Order.  April 16 Order at ordering para. (A). 
28 See generally Sixty-Day Compliance Filing. 
29 Id. at 1.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 7 
 
PJM also proposed Tariff placeholders for the new transmission services being proposed 
concurrently in the paper hearing.30  Due to the uncertainty regarding the timing of 
Commission action on the proposed changes and the non-rate terms and conditions being 
proposed in the paper hearing, PJM did not propose a specific effective date for the 
proposed new transmission services changes.31 
3. 
Paper hearing on new transmission services 
PJM submitted its initial brief in Docket Nos. EL25-49-000 and EL25-49-001 to 
address the Commission’s finding in the December Order that additional record evidence 
was needed to set the appropriate replacement rates, terms, and conditions for new 
transmission services for Eligible Customers serving Co-Located Load, including for 
Interim NITS, Firm Contract Demand Transmission Service, and Non-Firm Contract 
Demand Transmission Service.32  PJM’s initial brief set forth the non-rate terms and 
conditions for these new transmission services along with illustrative Tariff language.  
Various parties protested aspects of PJM’s illustrative Tariff language.33  In its reply brief, 
PJM proposed certain refinements to the illustrative language.34 
 
30 Id. at 19. 
31 Id. at 35. 
32 See generally PJM Interconnection, L.L.C., Initial Brief of PJM Interconnection, L.L.C., Docket Nos. 
EL25-49-000, et al. (Feb. 23, 2026). 
33 See, e.g., PJM Interconnection, L.L.C., Reply Brief of Joint Co-Location Developers and Motion to 
Intervene Out-of-Time of Calibrant, Convergent, U.S. Energy Storage Coalition, and Verrus, Docket Nos. 
EL25-49-000, et al., at 2 (Mar. 25, 2026); PJM Interconnection, L.L.C., Reply Brief and Protest of Enchanted 
Rock, Docket Nos. EL25-49-000, et al., at 7-9 (Mar. 25, 2026) (arguing that PJM’s proposal “renders Interim 
NITS entirely unworkable”); PJM Interconnection, L.L.C., Reply Brief of Advanced Energy United and 
Solar Energy Industries Association, Docket Nos. EL25-49-000, et al., at 6-10 (Mar. 25, 2026). 
34 PJM Interconnection, L.L.C., Reply Brief of PJM Interconnection, L.L.C., Docket Nos. EL25-49-000, et 
al., Attachment A (Redlines on Reply Brief to Illustrative Language for New Tariff, Part XI; Attachments F-
3A and F-4; and Other Illustrative Tariff Revisions), Illustrative Tariff, Part XI, Subpart A, section 701.1 
(Apr. 24, 2026).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 8 
 
C. 
The Commission’s June Order 
On June 18, 2026, the Commission issued the June Order, addressing the Sixty-
Day Compliance Filing, the paper hearing submissions, and requests for rehearing and 
clarification of the December Order.35  
The June Order found that PJM’s Sixty-Day Compliance Filing partially complies 
with the directives of the December Order, and the Commission accepted in part and 
rejected in part PJM’s proposed Tariff revisions and ordered PJM to submit a further 
compliance filing within 60 days.36  Additionally, the June Order found that in response to 
the record developed in the paper hearing, certain rates, terms, and conditions for the new 
transmission services as directed in the December Order (i.e., Interim NITS, Firm Contract 
Demand transmission service, and Non-Firm Contract Demand transmission service) are 
just and reasonable and directed PJM to make a compliance filing to revise its Tariff.37  
D. 
Large Load Order 
The same day it issued the June Order, the Commission also issued a new show 
cause order to PJM concerning Large Loads (“Large Load Order”).38  The Large Load 
Order found that several aspects of PJM’s Tariff appeared unjust and unreasonable due to 
the lack of specific procedures for integrating large loads, including a lack of procedures 
for interconnection studies, processing transmission service requests, and constructing 
network upgrades without cost shifting.39  The Large Load Order also found PJM’s Tariff 
 
35 See June Order at PP 1-2, 4-7.  
36 Id. at P 8. 
37 Id. at P 9. 
38 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211, at P 1 (2026). 
39 Large Load Order at PP 60, 65, 77.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 9 
 
appeared to be unjust and unreasonable due to a lack of transmission service options for 
customers serving large loads that are willing and able to limit their withdrawals from the 
Transmission System.40  The Large Load Order further found that PJM’s Tariff appeared 
to be unjust and unreasonable due to a lack of mechanisms to ensure that costs are not 
shifted between transmission customers.41 
To address these issues, the Large Load Order directed PJM to make two 
compliance filings.42  First, the Large Load Order directed PJM to submit an informational 
filing within 30 days to explain how PJM intends to ensure that it has adequate generation 
to serve existing and new large loads.43  Second, the Large Load Order directed PJM to 
submit within 60 days a compliance filing to explain whether its Tariff remains just and 
reasonable in light of the issues identified in the order, or to propose Tariff changes that 
would remedy the identified concerns.44  The Commission noted that it would entertain 
requests to hold the show cause proceedings in abeyance if PJM demonstrated a plan to 
file changes pursuant to Federal Power Act section 205 to address the identified concerns.45 
E. 
Partial Extension 
On July 28, 2026, PJM filed a motion for extension of time to meet certain 
compliance requirements in the June Order.46  PJM explained that due to the significant 
 
40 Id. at P 86.  
41 Id. at P 77. 
42 Id. at ordering paras. (A) & (B). 
43 Id. at P 4. 
44 Id. at ordering para. (B). 
45 Id. at P 39. 
46 PJM Interconnection, L.L.C., Motion for Extension of Time for Specified Compliance Requirements and 
Request for Expedited Treatment of PJM Interconnection, L.L.C., Docket Nos. EL25-49-002, et al. (July 28, 
2026) (“PJM Extension Motion”).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 10 
 
overlap in the subject matter, additional time is needed to ensure that certain compliance 
changes for Co-Located Load from the June Order align with the directives in the Large 
Load Order.47  PJM explained that a partial extension would allow time for stakeholder 
engagement and feedback on the changes PJM plans to make to respond to the Large Load 
Order.48  PJM sought a 90-day extension of certain directives in the June Order.49  In 
particular, PJM proposed to defer implementation of the new contract demand transmission 
services and some aspects of the BTMG netting.50  At the same time, PJM pledged to 
submit a partial compliance filing on August 17, 2026 to reflect PJM’s continuous and 
ongoing efforts to implement the Commission’s reforms.51   
The Commission issued a notice on August 14, 2026 granting PJM’s requested 
extension and abeyance.52  This filing represents PJM’s partial compliance filing with the 
June Order, as outlined in the July 28, 2026 motion for extension of time. 
 
DESCRIPTION OF CHANGES  
A. 
Prohibition on Serving Co-Located Load from Existing Generators 
The June Order directed PJM to explain in its compliance filing how its changes 
will prohibit Interconnection Customers from serving Co-Located Loads from new and 
existing generators until all necessary Network Upgrades, control technologies and/or 
 
47 Id. at 4-6. 
48 Id. at 6.  PJM also moved to hold the Large Load proceeding in abeyance for 90 days.  PJM Interconnection, 
L.L.C., Motion of PJM Interconnection, L.L.C. to Hold Proceeding in Abeyance and Request for Shortened 
Answer Period and Expedited Treatment, Docket No. EL26-67-000 (July 28, 2026). 
49 PJM Extension Motion at 4-5. 
50 Id. 
51 Id. at 5-7. 
52 PJM Interconnection, L.L.C., Notice of Extension of Time, Docket Nos. EL25-49-002, et al. (Aug. 14, 
2026).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
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protection systems, and metering are complete and in service.53  This compliance filing 
proposes to add Necessary Study references and provisions to Parts I, III, VI, and VII, and 
to direct Generation Project Developers seeking to serve Co-Located Load with an existing 
Co-Located Generating Facility to the Necessary Study process in Part VIII, Subpart A, 
section 401(H)(3).54  In its Sixty-Day Compliance Filing, PJM proposed to add language 
to Part VIII for the Necessary Study process to preclude a Project Developer from 
implementing any planned modifications to its facilities until the Necessary Studies are 
completed and the amended GIA reflecting the results of such studies is fully executed and 
effective; the Sixty-Day Compliance Filing also provided that service to the Co-Located 
Load could not begin until “all required Network Upgrades, necessary control technologies 
and protection systems, and metering identified as necessary are complete and in 
service.”55  Thus, the Tariff would now require that all Interconnection Customers and 
Generation Project Developers seeking to serve Co-Located Load, whether with existing 
or new Generating Facilities:  (1) provide advance written notice to PJM and the relevant 
Transmission Owner; (2) go through the Necessary Study process in Part VIII of the Tariff; 
and (3) not begin serving Eligible Load until the entire scope of the work under their GIA 
as amended after the Necessary Study process is complete.  These combined revisions 
 
53 June Order at P 285. 
54 See proposed Tariff, Part I, section 1 (Definitions L-M-N) (adding the definitions of “Necessary Study” 
and “Necessary Studies Agreement”); id., Part III (General) (addition of notice requirement); id., Part VI, 
Subpart B, section 212 (same); id., Part VII, Subpart A, section 301(A)(7)(c) (same).   
55 Sixty-Day Compliance Filing, proposed Tariff Revisions (Attachments A & B), Part VIII, Subpart A, 
sections 401(H)(3)(a), 401(H)(3)(b)(iii).  In this compliance filing, PJM proposes to further clarify in 
Proposed Tariff, Part VIII, the Necessary Study process by amending the listing of required and necessary 
equipment changes to instead reference “the entire scope of work required under that amended Generation 
Interconnection Agreement.”  Proposed Tariff, Part VIII, Subpart A, section 401(H)(3)(d).  This ensures that 
all items determined to be necessary and therefore captured in the amended GIA are complete before the 
Project Developer may begin serving Eligible Load.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 12 
 
ensure that all these entities are treated comparably and the prohibition on serving Co-
Located Loads before all the necessary upgrades and equipment changes are complete is 
enforced across the board.56   
B. 
Revisions to Retail Behind the Meter Generation Definition 
In the Sixty-Day Compliance Filing, PJM had proposed to define Retail BTMG as 
load being served by a generation facility with a nameplate capacity of 50 MW or less.57  
PJM also proposed to implement various exemptions from the netting limit for a transition 
period, contractual rights, and qualifying facilities under Public Utility Regulatory Policies 
Act via the Retail BTMG definition.58  The June Order, however, rejected PJM’s proposed 
50 MW limit and instead directed PJM to permit Retail BTMG netting up to a 50 MW 
materiality threshold.59  Consistent with the extension motion, PJM is continuing to work 
with stakeholders to develop Tariff language to implement the 50 MW netting provisions 
for Retail BTMG.  However, for purposes of allowing Eligible Customers with load served 
by Retail BTMG to take Interim NITS,60 PJM is proposing a revised definition of Retail 
 
56 PJM also proposes herein formatting and language changes to the Necessary Study provisions in Part VIII, 
Subpart A, section 401(H)(3), to make clear that the Necessary Study process applies to all Project 
Developers that plan to make modifications to their facilities, “including but not limited to a Project 
Developer whose planned modifications include an Eligible Load configuration.”  Proposed Tariff, Part VIII, 
Subpart A, section 401 (H)(3)(a).  PJM further proposes minor, ministerial changes to Tariff, Part VIII to 
spell out the term “Generation Interconnection Agreement” and replace “PJM” with “Transmission 
Provider,” as appropriate.  See, e.g., proposed Tariff, Part VIII, Subpart C, section 408 (A)(2)(e)(i)(j)(iv); id., 
Part VIII, Subpart E, sections 414(B)(2), 414(B)(4)(c). 
57 Sixty-Day Compliance Filing at 4-16. 
58 Id. 
59 June Order at PP 207, 220. 
60 Id. at P 91.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
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BTMG that eliminates the rejected 50 MW nameplate limit and other netting exemptions 
that will be added elsewhere in a future compliance filing.61  
C. 
Expansion of Service to “Eligible Load” for Load with BTMG 
The June Order directed PJM to expand the availability of the December Order’s 
new transmission services to Network Customers serving load with BTMG that are willing 
and able to limit their withdrawals from the Transmission System under certain 
circumstances.62  The Commission directed PJM to either add a definition of “Eligible 
Load” or propose other changes to implement this directive.63  Consistent with this 
directive, PJM is proposing to add the term Eligible Load to the Tariff to encompass both 
Co-Located Load and Load with BTMG.64  To that end, PJM is proposing to add to the 
Tariff, Part I, section 1, Definitions the term “Eligible Load” defined as “Co-Located Load 
or load connected to Behind the Meter Generation.”65  Further consistent with the 
Commission’s directive to propose other Tariff changes necessary to expand the 
availability of these new services, PJM is proposing to add to the term “Eligible Generating 
Facility” to the Tariff to encompass both a Co-Located Generating Facility or Retail 
BTMG.66  In addition, PJM is proposing conforming changes to replace “Co-Located 
 
61 Proposed Tariff, Part I, section 1 (Definitions R - S) (adding the definition of “Retail Behind The Meter 
Generation”); id., Part VIII, Subpart A, section 400, Definitions R. 
62 June Order at P 91. 
63 Id. 
64 Proposed Tariff, Part I, section 1 (Definitions E - F) (adding the definition of “Eligible Load”). 
65 Id. 
66 “‘Eligible Load’ shall mean Co-Located Load or load connected to Behind the Meter Generation. ‘Eligible 
Generating Facility’ shall mean a Co-Located Generating Facility or Retail Behind the Meter Generation.”  
Proposed Tariff, Part I, section 1 (Definitions E – F) (defining “Eligible Load” and “Eligible Generating 
Facility”).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 14 
 
Load” with “Eligible Load” and “Co-Located Generator” with “Eligible Generator” and 
other clarifying changes in Tariff Part I, section 1 (Definitions),67 Part III (Network 
Integration Transmission Service),68 Part VI (Administration and Study of New Service 
Requests),69 Part VII (Transition Cycle Generation Interconnection Procedure),70 Part VIII 
(New Rules Generation Interconnection Procedure),71 Part IX (Forms of Interconnection-
 
67 Proposed Tariff, Part I, section 1 (Definitions O – P – Q) (updating the definition of “Provisional 
Interconnection Service” to reference “Eligible Load” instead of just “Co-Located Load”). 
68 Proposed Tariff, Part III, sections 28.1 (replacing “Co-Located Load” with “Eligible Load”); section 29.1 
(allowing customers to take NITS on behalf of “Eligible Load” instead of “Co-Located Load”); id., Part III, 
section 29.2 (replacing “Co-Located Load” with “Eligible Load” in application procedures); id., Part III, 
section 31.6 (replacing “Co-Located Load” with “Eligible Load” in annual load and resource information 
update). 
69 Proposed Tariff, Part VI, Subpart B, section 212 (adding language in Part VI, Subpart B, section 212 
regarding the Necessary Study process in Part VIII for Generating Facilities to reference service to Eligible 
Loads). 
70 Proposed Tariff, Part VII, Subpart A, section 300, Definitions P (adding the definitions for “Eligible Load” 
and “Eligible Generating Facility”); id., Part VII, Subpart A, section 300, Definitions P (revising the 
definition of “Provisional Interconnection Service” to reference “Eligible Generating Facility” and “Eligible 
Load”). 
71 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions E (adding the definitions for “Eligible Load” 
and “Eligible Generating Facility”); id., Part VIII, Subpart A, section 400, Definitions P (updating the 
definition of “Provisional Interconnection Service” to reference “Eligible Generating Facility” and “Eligible 
Load”); id., Part VIII, Subpart A, section 401 (revising the application requirements to allow Eligible 
Generating Facilities serving Eligible Load and clarifying the Necessary Studies process applies to Eligible 
Load); id., Part VIII, Subpart B, section 403 (revising the application rules to allow Eligible Generating 
Facilities serving Eligible Load); id., Part VIII, Subpart C, section 404 (updating the System Impact Studies 
to contemplate service to Eligible Load); id., Part VIII, Subpart C, section 406 (updating the acceleration 
language to allow acceleration of new service requests for new facilities or increases the generation capability 
in existing facilities to serve Eligible Load); id., Part VIII, Subpart C, section 408 (same); id., Part VIII, 
Subpart E, section 413 (updating the language permitting service requests below the maximum facility output 
for new facilities or increases the generation capability in existing facilities that will serve Eligible Load); 
id., Part VIII, Subpart E, section 414 (updating the language to permit Surplus Interconnection Service for 
Eligible Load).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
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Related Agreements),72 and Part XI, Subpart A (Interim Network Integration Transmission 
Service).73 
D. 
Elimination of New GIA Requirement 
PJM previously proposed to require all Eligible Customers that intend to serve Co-
Located Load with a new or existing Co-Located Generating Facility to enter into a new 
GIA pursuant to Part VIII of the Tariff, which was revised to include additional details 
regarding the Necessary Studies process.74  The June Order rejected this proposal for 
customers with existing service agreements and directed PJM to add language concerning 
the Necessary Study process to Tariff, Parts VI and VII to allow customers with existing 
service agreements to modify those agreements.75  Accordingly, PJM is proposing changes 
to allow customers that obtained service agreements pursuant to Parts VI and VII to modify 
those agreements pursuant to the Necessary Study process in Part VIII.76  
 
72 Proposed Tariff, Part IX, Subpart A (Form of Application and Studies Agreement), section 1 (revising 
section 1 of the Application and Studies Agreement to collect applicant information for an Eligible 
Generating Facility serving Eligible Load); id., Part IX, Subpart A (Form of Application and Studies 
Agreement), section 3.17 (changing “PJM” to “Transmission Provider” and clarifying all transmission 
service requests in the PJM Region are subject to the same deliverability tests); id., Part IX, Subpart B, GIA 
Appendices and Schedules, Schedule O (updating Schedule O to replace “Eligible Load” with “Eligible 
Generating Facility”); id., Part XI, Subpart G, Necessary Studies Agreement (updating the Necessary Studies 
Agreement to reference “Eligible Load” and “Eligible Generating Facility”).  
73 Proposed Tariff, Part XI, Subpart A, section 700 (updating references to “Co-Located Load” to “Eligible 
Load”); id., Part XI, Subpart A, section 701.1 (same); id., Part XI, Subpart A, section 701.2 (same); id., Part 
XI, Subpart A, section 701.3 (same); id., Part XI, Subpart A, section 702.1 (same); id., Part XI, Subpart A, 
section 702.4 (same); id., Part XI, Subpart A, section 703 (same). 
74 See June Order at P 284; proposed Tariff, Part VIII, Subpart A, section 401(H)(3). 
75 June Order at P 311. 
76 See supra note 54 concerning addition of Necessary Study language to Parts I, III, VI, and VII; proposed 
Tariff, Part VIII, Subpart A, section 401(I).  PJM also proposes to cross-reference Tariff, Part VIII, Subpart 
L, section 439, Provisional Interconnection Service, added in the Thirty-Day Compliance Filing, in Parts VI 
and VII to clarify that Provisional Interconnection Service is available to entities that obtained 
Interconnection Service under those Parts.  See proposed Tariff, Part I, section 1 (Definitions O – P – Q) 
(updating the definition of “Provisional Interconnection Service”); id., Part VII, Subpart A, section 300, 
Definitions P (same); id., Part VIII, Subpart A, section 400, Definitions P (same).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 16 
 
For Interconnection Customers that utilized the Part VI process, because Part VI 
does not contain discrete definitions, PJM is revising the proposed definition of Co-Located 
Generating Facility in Part I to include an existing Customer Facility that is physically 
connected to Co-Located Load to incorporate the relevant terms from Part VI.77  As 
explained above, to ensure that existing Interconnection Customers with effective ISAs do 
not serve Co-Located Load until all necessary upgrades and equipment are in place,78 PJM 
is also adding to the Co-Located Generating Facility definition a requirement to provide 
advance written notice to the Transmission Provider and Transmission Owner to initiate 
the Necessary Study process pursuant to Part VIII, Subpart A, section 401(H)(3)(b) to use 
a Customer Facility to serve Co-Located Load.79  In addition, PJM is adding language to 
mirror this Necessary Study process requirement in Part VI, Subpart B, section 212.80  
Finally, PJM has updated the pro forma Necessary Studies Agreement to include language 
for Queue No., reference Part VI for ISAs, incorporate references to Interconnection 
Customers throughout, and reference Tariff, Attachment O, Appendix 2, section 3 in 
paragraph 5 concerning the purpose of the Necessary Studies.81 
For Generation Project Developers that utilized the Part VII Transition Cycle 
Interconnection Process, PJM is proposing to modify the definition of Co-Located 
 
77 Proposed Tariff, Part I, section 1 (Definitions C - D) (revising the definition of “Co-Located Generating 
Facility”). 
78 June Order at P 285. 
79 Proposed Tariff, Part I, section 1 (Definitions C - D) (adding to the definition of “Co-Located Generating 
Facility”). 
80 Proposed Tariff, Part VI, Subpart B, section 212.  PJM also proposes to add new Tariff, Part VIII, Subpart 
A, section 401(I) to clarify that Interconnection Customers with ISAs under Tariff, Part VI may utilize the 
Part VIII Necessary Study process and will be referred to as Project Developers or Generation Project 
Developers and their agreements referred to as Generation Interconnection Agreements when doing so. 
81 Proposed Tariff, Part IX, Subpart G, Necessary Studies Agreement.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 17 
 
Generating Facility to include both an existing and planned Generating Facility.82  
Consistent with the proposed changes in Part VI, PJM is adding a requirement to provide 
Transmission Provider and Transmission Owner with advance written notice to initiate the 
Necessary Study process pursuant to Part VIII, Subpart A, section 401(H)(3)(b) in the event 
a Generation Project Developer with an effective GIA intends to use a Generation Facility 
to serve Co-Located Load.83  PJM is also adding this advance notice requirement for the 
Necessary Study process to Tariff, Part VII, Subpart A, section 301(A)(7)(c).84  Finally, 
PJM is proposing a definition of Co-Located Load that references the relevant terms for 
Part VII of the Tariff (i.e., Generating Facility and Project Developer).85  
E. 
Interim NITS 
PJM is proposing the terms and conditions for Interim NITS in new Part XI of the 
Tariff.86  The Part XI largely adopts the terms and conditions proposed during the paper 
hearing subject to certain changes directed in the June Order and other clarifications.   
First, consistent with the June Order,87 PJM clarified in section 701.1 that an 
Interim NITS customer will be converted automatically to a NITS customer upon 
completion of the relevant Network Upgrades and once the Transmission Provider updates 
its system to reflect those upgrades.88  The language concerning the internal system updates 
 
82 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C (definition of Co-Located Generating 
Facility). 
83 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C (definition of Co-Located Generating 
Facility). 
84 Proposed Tariff, Part VII, Subpart A, section 301(A)(7)(c); id., Subpart A, section 300, Definitions N. 
85 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C. 
86 Proposed Tariff, Part XI. 
87 June Order at P 571. 
88 Proposed Tariff, Part XI, Subpart A, section 701.1.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 18 
 
was added to clarify that the conversion does not happen automatically the moment the 
construction of the Network Upgrades is complete but must first be reflected in PJM’s 
internal systems. 
Second, consistent with the June Order,89 PJM revised the language in section 705.2 
to clarify the curtailment priority for Interim NITS relative to Non-Firm Point to Point 
Service and that it will prioritize customers for curtailment based on duration of service as 
specified in the PJM Manuals.90  As the Commission directed,91 PJM also added language 
to specify that Eligible Customers subject to curtailment may use a Co-Located Generating 
Facility to serve Co-Located Load provided the facility either has not obtained 
interconnection service yet or the facility is not a capacity resource.92 
Third, consistent with the June Order,93 PJM revised the operational penalties for 
failure to follow dispatch instructions or misoperation of control technologies to suspend 
service for up to 120 days after the first instance and terminate service after the second.94  
Fourth, consistent with the June Order,95 PJM added language in section 705.1 and 
to the Part I definition of Curtailment to clarify that with respect to Tariff, Part XI, its 
Curtailment authority includes the authority to curtail Interim NITS for capacity or reserve 
shortages.96 
 
89 June Order at P 555. 
90 Proposed Tariff, Part XI, Subpart A, section 705.2. 
91 June Order at P 576. 
92 Proposed Tariff, Part XI, Subpart A, section 705.2. 
93 June Order at PP 516, 523-24, 527. 
94 Proposed Tariff, Part XI, Subpart A, section 705.6. 
95 June Order at P 551. 
96 Proposed Tariff, Part I, section 1 (Definitions C - D); proposed Tariff, Part XI, Subpart A, section 705.1.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 19 
 
Fifth, consistent with the June Order,97 PJM added language in section 705.5 on 
Necessary Control Technologies and Protection Systems to specify that such technologies 
include telemetry, data exchange, and metering for the Transmission Provider to monitor 
the Eligible Customer’s use of the Transmission System, limit withdrawals, and ensure 
relay settings are consistent with necessary control technologies and/or protection 
systems.98    
Finally, PJM made the following additional clarifying edits: 
• Section 701.1:  PJM added a cross-reference to Part XI, Subpart A, section 
702.3 to clarify that Eligible Customers may receive Interim NITS consistent 
with the Transmission Provider’s determination as to the amount of service that 
can be reliably provided.99  PJM also omitted language referencing Firm 
Contract Demand Service and Non-Firm Contract Demand Service, as those 
services will be implemented in a later compliance filing.100 
• Section 701.2:  PJM struck the term “capacity” from this section because 
Interim NITS is an energy-only service.101 
• Section 701.3:  PJM struck the term “capacity” from this section because 
Interim NITS is an energy-only service.102 
• Section 702.3:  PJM clarified that the Transmission Provider will determine the 
amount of Interim NITS that can be reliably provided to an Eligible 
Customer.103 
 
97 June Order at P 541. 
98 Proposed Tariff, Part XI, Subpart A, section 705.5. 
99 Proposed Tariff, Part XI, Subpart A, section 701.1. 
100 Id. 
101 Proposed Tariff, Part XI, Subpart A, section 701.2. 
102 Proposed Tariff, Part XI, Subpart A, section 701.3. 
103 Proposed Tariff, Part XI, Subpart A, section 702.3.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 20 
 
• Section 705:  PJM eliminated the section on “Load Shedding” as it was no 
longer needed due to the clarifications regarding the nature of Interim NITS 
(i.e., that the service is non-firm in nature).104 
• Section 705.4:  PJM added language to clarify that the Transmission Provider 
may curtail Interim NITS for the purpose of undertaking scheduled system 
upgrades and maintenance.105 
F. 
Other Commission Ordered Changes 
PJM implemented other compliance changes specified in the June Order as follows: 
June Order Directive 
PJM Compliance Change 
Reject the Tariff provisions proposing 
that Co-Located Load that is not served 
by 
an 
Eligible 
Customer 
taking 
transmission service on its behalf “must 
take all necessary steps to disconnect 
from the Transmission System,” as this 
provision is duplicative of PJM’s 
proposed changes to Part VIII, Subpart 
B, section 403(A)(1)(r)(iv).106 
Struck language from Tariff, Part III 
(General).107 
 
Detail the specific provisions in the PJM 
Manuals concerning Necessary Studies 
to which the proposed Tariff language 
refers.108 
Revised Tariff, Part VIII, Subpart A, section 
401(H)(3)(c) to reference specific provisions 
of the PJM Manuals. 109 
 
Revise Tariff to remove the requirement 
for Interconnection Customers with 
existing ISAs pursuant to Part VI of the 
Tariff and GIAs pursuant to Part VII of 
the Tariff to enter into a new pro forma 
GIA.110 
Struck language from Tariff, Part III 
(General).111 
 
 
104 Proposed Tariff, Part XI, Subpart A, sections 705, 705.3. 
105 Proposed Tariff, Part XI, Subpart A, section 705.4. 
106 June Order at P 264. 
107 See proposed Tariff, Part III (General). 
108 June Order at P 280. 
109 Proposed Tariff, Part VIII, Subpart A, section 401(H)(3)(c). 
110 June Order at P 284. 
111 See proposed Tariff, Part III (General).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 21 
 
June Order Directive 
PJM Compliance Change 
Reject increase in cost for Necessary 
Studies Agreement.112 
Removed proposed cost increase from pro 
forma Necessary Study Agreement.113 
 
Revise the Tariff’s definition of Co-
Located 
Load 
to 
use 
“Point 
of 
Interconnection” instead of “Point of 
Change in Ownership.”114 
Revised Co-Located Load definition in Parts 
I115 and VII.116 
 
Remove the following requirement from 
the definition of Co-Located Generating 
Facility:  “If such a Generation Project 
Developer 
has 
an 
effective 
Interconnection 
Service 
Agreement 
pursuant to Tariff, Part VI or a 
Generation Interconnection Agreement 
pursuant to Tariff, Part VII, such 
agreement must be superseded by a 
Generation Interconnection Agreement 
pursuant to Tariff, Part VIII and the pro 
forma GIA in Part IX, Subpart B,”117 
Struck language from the definition in Parts 
VII and VIII.118 
 
 
Add to Part III a requirement that 
Interconnection Customers with ISAs or 
GIAs executed (or requested to be filed 
unexecuted) prior to the effective date of 
the revised generation interconnection 
procedures and pro forma GIA directed 
in December Order that wish to add Co-
Located Load or are currently serving 
Co-Located Load publicly notify PJM of 
that addition and identify the Eligible 
Customer that will take transmission 
Added public notice requirement to Part III 
(General).120 
 
112 June Order at P 288. 
113 See proposed Tariff, Part IX, Subpart G, Necessary Study Agreement. 
114 June Order at P 308. 
115 Proposed Tariff, Part I, section 1, Definitions C-D. 
116 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C. 
117 Id. at P 311. 
118 Proposed Tariff, Part VII, Subpart A, section 300, Definitions C; id., Part VIII, Subpart A, section 400, 
Definitions C.  
120 Proposed Tariff, Part III (General).

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 22 
 
June Order Directive 
PJM Compliance Change 
service on behalf of that Co-Located 
Load.119 
Revise the Tariff to remove PJM’s 
proposed revisions to the definition of 
Non-Retail BTMG consistent with the 
December Order’s determination.121  
Rejected changes in Part I, section 1 
(Definitions L – M – N).122 
 
Revise Tariff to assess to Eligible 
Customers taking transmission service 
on behalf of Eligible Loads:  (1) 
administrative 
service 
charges; 
(2) 
ancillary service charges; (3) black start 
service charges; (4) regulation charges; 
and (5) any redispatch costs.123 
 
Included in Interim NITS provisions in Part 
XI.124 
G. 
Effective Date Only 
PJM previously proposed compliance changes in the Sixty-Day Compliance Filing 
that were accepted in the June Order.125  However, given the uncertainty surrounding 
aspects of the Sixty-Day Compliance Filing, PJM had not proposed a specific effective 
date for those changes.126  Accordingly, PJM is filing the following Tariff records with a 
proposed effective date of October 17, 2026: 
• Part I, section 1, Definitions A-B (Behind the Meter Generation);127  
 
119 June Order at P 311. 
121 June Order at P 314. 
122 Proposed Tariff, Part I, section 1, Definitions L-M-N (rejecting changes in the definition of “Non-Retail 
BTMG”). 
123 June Order at P 573. 
124 Proposed Tariff, Part XI, Subpart A, section 706. 
125 See, e.g., June Order at P 207 & n.519. 
126 Sixty-Day Compliance Filing at 35. 
127 Proposed Tariff, Part I, section 1 (Definitions A – B) (updating the definition of “Behind the Meter 
Generation”); June Order at P 207 n.519.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 23 
 
• Part III, section 34.3 (Netting of Non-Retail BTMG);128 
• Part VII, Subpart A, section 300, Definitions B (BTMG);129 
• Part VIII, Subpart A, section 400, Definitions B (BTMG);130 and 
• Part VIII, Subpart A, section 400, Definitions N (Necessary Study).131 
 
EFFECTIVE DATE AND WAIVER REQUEST 
In accordance with the Commission’s regulations,132 PJM requests an effective date 
for the compliance changes in Parts I, III, VI, VII, VIII, and IX of the Tariff of 
October 17, 2026, which is 61 days after the date of this filing.   
Consistent with the Commission’s directive to consider whether Interim NITS 
could be implemented earlier than originally proposed,133 PJM is proposing an effective 
date of July 1, 2028, for the new Part XI regarding the provision of Interim NITS.  At 
present, PJM can provide partial NITS, i.e., NITS in an amount less than requested and/or 
for a term shorter than requested, to Co-Located Load through the Necessary Study process 
and therefore is proposing an October 17, 2026 effective date for the bulk of the revisions 
proposed in this filing.  However, PJM Operations personnel will need to implement 
additional tools and processes before they will be able to monitor and curtail, as needed, 
the new non-firm Interim NITS product proposed in Tariff, Part XI.  PJM anticipates it will 
be able to develop, procure, and implement those tools and processes by mid-2028, and 
 
128 Proposed Tariff, Part III, section 34.3. 
129 Proposed Tariff, Part VII, Subpart A, section 300, Definitions B. 
130 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions B. 
131 Proposed Tariff, Part VIII, Subpart A, section 400, Definitions N; June Order at P 280 n.670. 
132 18 C.F.R. § 35.3(a)(1). 
133 June Order at P 597.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 24 
 
therefore proposes the July 1, 2028 effective date for the new Interim NITS product.  
Because this effective date is more than 120 days after the date of filing, PJM respectfully 
requests waiver of 18 C.F.R. § 35.3(a)(1) to file the proposed new Tariff, Part XI now. 
 
DOCUMENTS ENCLOSED 
In addition to this transmittal letter, PJM encloses the following: 
1. 
Attachment A: 
Tariff Redline; and 
2. 
Attachment B: 
Clean Tariff.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 25 
 
 
CORRESPONDENCE AND COMMUNICATIONS 
Correspondence and communications with respect to this filing should be sent to, 
and PJM requests the Secretary to include on the official service list, the following:134 
Craig Glazer 
Vice President – Federal Government Policy 
PJM Interconnection, L.L.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
(202) 423-4743  
craig.glazer@pjm.com 
 
Wendy B. Warren 
Ruth M. Porter 
Wright & Talisman, P.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
(202) 393-1200  
warren@wrightlaw.com 
porter@wrightlaw.com 
 
Mark J. Stanisz 
Associate General Counsel 
PJM Interconnection, L.L.C.  
2750 Monroe Blvd, 
Audubon, PA 19403 
(610) 666-8800 
mark.stanisz@pjm.com 
 
 
 
SERVICE 
PJM has served a copy of this filing on all PJM Members and on the affected state 
utility regulatory commissions in the PJM Region by posting this filing electronically.  In 
accordance with the Commission’s regulations,135 
 
PJM will post a copy of this filing to 
the Commission filings section on its internet site, https://pjm.com/library/filing-order, and 
will send an email on the same date as this filing to all PJM Members and all state utility 
regulatory commissions in the PJM Region,136 alerting them that this filing has been made 
 
134 To the extent necessary, PJM requests waiver of Rule 203(b)(3) of the Commission’s Rules of Practice 
and Procedure, 18 C.F.R. § 385.203(b)(3), to permit all of the persons listed to be placed on the official 
service list for this proceeding. 
135 See 18 C.F.R. §§ 35.2(e) & 385.2010(f)(3). 
136 PJM already maintains, updates, and regularly uses email lists for all PJM Members and affected state 
commissions.

Honorable Debbie-Anne A. Reese  
August 17, 2026 
Page 26 
 
by PJM and is available by following such link.  If the document is not immediately 
available by using the referenced link, the document will be available through the 
referenced link within 24 hours of the filing. 
 
CONCLUSION 
PJM respectfully requests that the Commission accept this compliance filing as it 
complies with the requirements of the June Order. 
Respectfully submitted, 
/s/ Wendy B. Warren 
 
Craig Glazer 
Vice President – Federal Government Policy 
PJM Interconnection, L.L.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005 
202-423-4743 
craig.glazer@pjm.com 
 
Mark J. Stanisz 
Associate General Counsel 
PJM Interconnection, L.L.C.  
2750 Monroe Blvd, 
Audubon, PA 19403 
(610) 666-8800 
mark.stanisz@pjm.com 
 
 
August 17, 2026 
 
Wendy B. Warren 
Ruth M. Porter 
Wright & Talisman, P.C. 
1200 G Street, NW, Suite 600 
Washington, DC  20005-3898 
202-393-1200 
warren@wrightlaw.com 
porter@wrightlaw.com 
 
 
 
 
 
 
Counsel for 
PJM Interconnection, L.L.C.

CERTIFICATE OF SERVICE 
I hereby certify that I have this 17th day of August 2026 caused a copy of the 
foregoing document to be served upon each person designated on the official service list 
compiled by the Secretary in this proceeding. 
/s/ Ruth M. Porter 
 
Ruth M. Porter 
Wright & Talisman, P.C. 
1200 G Street, N.W., Suite 600 
Washington, D.C.  20005 
(202) 393-1200 (phone) 
porter@wrightlaw.com