{"document":{"slug":"errata-er27-330-pjm-backstop-attachment-1","title":"Att A- Corrected Transmittal (Clean).pdf","issued":"2026-10-30","accession":"20261030-5172","docket":"ER27-330-001","group":"PJM filings","filer":"PJM Interconnection, L.L.C.","kind":"attachment","file":"sources/originals/20261030-5172_02.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20261030-5172","parent":"errata-er27-330-pjm-backstop","sha256":"62e0d7cbad4478989cf238f5fab99ca717d50a98e741a4a8a21237438a31467e","pages":67,"tokens":19535,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":6,"text":"Attachment A \nCorrected  \nTransmittal Letter \n(Clean)"},{"page":2,"startToken":6,"endToken":216,"text":"PJM Interconnection, L.L.C. \n2750 Monroe Blvd. \nAudubon, PA 19403 \n \nChenchao Lu \nAssociate General Counsel \n(610) 500-3245  \nchenchao.lu@pjm.com \n \n \n \n \n \n \n \n \nOctober 29, 2026 \n \nThe Honorable Debbie-Anne A. Reese \nSecretary  \nFederal Energy Regulatory Commission \n888 First Street, N.E. \nWashington, D.C. 20426-0001 \n \nRe: \nPJM Interconnection, L.L.C., Docket No. ER27-____-000  \nProposed Amendments to the Reliability Backstop Procurement \nMotion for Extended, 32-Day Comment Period  \nRequest for Waiver of Tariff Attachment DD, Sections 16.2 and 16.3 \n \nDear Secretary Reese: \n \nPursuant to section 205 of the Federal Power Act (“FPA”),1 the Federal Energy \nRegulatory Commission’s (“Commission”) Regulations,2 PJM Interconnection, L.L.C. \n(“PJM”) hereby submits proposed revisions to the PJM Open Access Transmission Tariff \n(“Tariff”) that updates the Reliability Backstop Procurement (“RBP”) rules to address, \ninter alia, issues identified in the Commission’s September 29 Order.3  Specifically, this \nfiling proposes modifications to establish just and reasonable rules to (i) allocate \nresponsibility for RBP Charges to certain Load Serving Entities (“LSE”); (ii) require LSEs \nresponsible for RBP Charges to post an appropriate level of credit; and (iii) provide notice \n \n1 16 U.S.C. § 824d. \n2 18 C.F.R. part 35. \n3 PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“September 29 Order”)."},{"page":3,"startToken":216,"endToken":560,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 2 \n \nto LSEs exiting PJM of their continuing responsibility for RBP Charges allocated to them \nthrough the remainder of the RBP commitment term.4   \nPJM requests that most of the proposed revisions become effective on February 28, \n2027—the same effective date for the RBP rules the Commission accepted in the \nSeptember 29 Order.5  However, because PJM is proposing certain pre-conduct of RBP \nactivities from Electric Distributors, PJM has proposed one Tariff record to be effective \nJanuary 29, 2027, which is 92 days from the date of filing.  PJM is also requesting that the \nCommission issue an order on all aspects of this filing no later than January 29, 2027, to \nfacilitate conduct of the RBP and provide participants the advance notice necessary for the \nefficient administration of the RBP. \nTo afford stakeholders adequate time to evaluate the proposed RBP rules changes, \nPJM moves for the Commission to establish an extended, 32-day comment period, such \nthat comments and interventions would be due November 30, 2026.  Even accounting for \nthe intervening holidays and the requested extended comment period, issuance of an order \nby January 29, 2027, would still leave the Commission with approximately 60 days \nfollowing the close of the comment period to consider the record and act on the filing.  \nHowever, the Commission should not feel constrained to wait until January 29, 2027, to \nissue an order on the proposed RBP rules, but should feel free to issue an order whenever \nit feels appropriate before January 29, 2027. \n \n4 For the purpose of this filing, capitalized terms not defined herein shall have the meaning as contained in \nthe PJM Tariff, Amended and Restated Operating Agreement, the Reliability Assurance Agreement Among \nLoad Serving Entities in the PJM Region (“RAA”), and the PJM RBP filing under Docket No. ER26-3380-\n000.  See PJM Interconnection, L.L.C., Reliability Backstop Procurement to Address Resource Adequacy \nConcerns Stemming from Large Loads, Docket No. ER26-3380-000 (July 31, 2026) (“July 31 Filing”). \n5 September 29 Order, 196 FERC ¶ 61,245 at P 1."},{"page":4,"startToken":560,"endToken":824,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 3 \n \nIn addition, through this filing, PJM also conditionally requests waiver of the \nrequirement in Tariff, Attachment DD, section 16.2 for PJM to “investigate the cause for \nthe shortage, and recommend corrective action”6 in the event the 2029/2030 Base Residual \nAuction clears short of the reliability requirement.  Likewise, should the 2029/2030 \nDelivery Year Base Residual Auction clear short, resulting in three consecutive Delivery \nYears with insufficient capacity procurement, PJM conditionally requests waiver of the \nrequirement in Tariff, Attachment DD, section 16.3 that PJM “declare a capacity shortage \nand make a filing with FERC for approval to conduct a Reliability Backstop Auction” \nfollowing three consecutive Delivery Years in which the Base Residual Auction clears \nshort.  As discussed below in Part IV, the Commission should grant this one-time, \nprospective waiver. \nI. \nBACKGROUND \nOn July 31, 2026, PJM filed a comprehensive proposal to establish the RBP, a \ntargeted, one-time procurement mechanism designed to address emerging resource \nadequacy challenges driven principally by the rapid growth of Large Loads and the \nresulting acceleration of capacity needs across the PJM Region.7  In its September 29 \nOrder, the Commission accepted PJM’s proposed RBP framework, but suspended the \nTariff revisions for a period of five months and established additional procedures to further \nexamine three discrete aspects of the proposal:  cost allocation, Transmission Owner exit \nprovisions, and LSE collateral requirements.8  While the Commission initiated a paper \n \n6 Tariff, Attachment DD, section 16.2. \n7 See July 31 Filing. \n8 September 29 Order, 196 FERC ¶ 61,245 at P 24."},{"page":5,"startToken":824,"endToken":1130,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 4 \n \nhearing and a related proceeding under section 206 of the FPA to develop a more complete \nrecord regarding those issues, it also expressly and strongly encouraged PJM to submit, an \nalternative proposal pursuant to its FPA section 205 filing rights to address the concerns \nidentified in the order.9   \nPJM submits this section 205 filing in accordance with the Commission’s guidance \nfrom the September 29 Order.  The revisions proposed herein are carefully tailored to \naddress the specific issues identified by the Commission while preserving the fundamental \nstructure and policy objectives of the RBP framework that the Commission otherwise \naccepted in the September 29 Order.  Consistent with the Commission’s direction, this \nfiling presents targeted modifications to the RBP’s cost allocation, exit responsibilities, and \ncollateral provisions that are intended to resolve the Commission’s remaining areas of \nconcern, strengthen the overall design of the RBP, and facilitate timely implementation of \na mechanism that is needed to address pressing reliability and resource adequacy risks.  By \nnarrowing the issues in dispute and building upon the framework that the Commission has \nalready found generally just and reasonable, this filing will promote administrative \nefficiency, reduce regulatory uncertainty, and enable PJM to move forward with the RBP \non an expedited basis.10  Through this section 205 filing, PJM has addressed the issues set \nfor paper hearing in the September 29 Order. \nPJM respectfully submits that each aspect of the filing is just and reasonable.  \nNevertheless, to facilitate prompt Commission action and avoid further delay in the \n \n9 September 29 Order, 196 FERC ¶ 61,245 at P 28. \n10 The pieces of the RBP that are not proposed to be modified through this filing are not further discussed in \nthis filing given that the Commission accepted all of the proposed RBP rules in its September 29 Order."},{"page":6,"startToken":1130,"endToken":1504,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 5 \n \nimplementation of the RBP, PJM consents to the Commission’s exercise of its authority, \nto the extent permitted under section 205 of the FPA and NRG Power Marketing, LLC v. \nFERC,11 to modify, reject, or sever discrete elements of the proposed Tariff revisions while \naccepting the remainder of the filing.  Such an approach, if deemed necessary by the \nCommission, would preserve the benefits of the proposed reforms and support the timely \ncommencement of the RBP. \nII. \nPROPOSED UPDATES THAT ADDRESS ISSUES IDENTIFIED IN THE \nCOMMISSION’S SEPTEMBER 29 ORDER \nA. \nPJM Proposes Updates that Directly Address the Commission’s RBP Cost \nAllocation Concerns.  \nUnder FPA section 205, cost allocation must be grounded in the principle that costs \nare assigned to those who cause them or benefit from the facilities and services provided.12  \nAt the same time, courts have long recognized that cost causation is not a standard of \nmathematical precision.  Indeed, courts have long recognized that “it would no doubt be \nimpossible, even if desirable, to formulate a rate scheme with such precision that each \ncustomer—or even customer group—is made to bear the exact cost of the service he \nreceived.”13  Therefore, costs need not be “allocate[d] . . . with exacting precision.”14  \nRather, they need only “be allocated in a manner that is roughly commensurate with the \n \n11 NRG Power Mktg., LLC v. FERC, 862 F.3d 108, 114-15 (D.C. Cir. 2017). \n12 E.g., Pub. Serv. Elec. & Gas Co. v. FERC, 989 F.3d 10, 13 (D.C. Cir. 2021) (The Commission “has long \nviewed the just-and-reasonable requirement” under FPA section 205 “to incorporate a cost-causation \nprinciple.” (internal quotation marks and citation omitted)); Ill. Com. Comm’n v. FERC, 576 F.3d 470, 476 \n(7th Cir. 2009). \n13 Ala. Elec. Coop., Inc. v. FERC, 684 F.2d 20, 28 (D.C. Cir. 1982); see also Sithe/Indep. Power Partners, \nL.P. v. FERC, 285 F.3d 1, 5 (D.C. Cir. 2002) (explaining the Court has consistently upheld rates based on \ncost-causation principles as applied in Alabama Electric Cooperative). \n14 Ill. Com. Comm’n, 576 F.3d at 477 (quoting Midwest ISO Transmission Owners v. FERC, 373 F.3d 1361, \n1369 (D.C. Cir. 2004))."},{"page":7,"startToken":1504,"endToken":1805,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 6 \n \nbenefits received.”15  Consistent with this standard, the Commission possesses broad \ndiscretion to evaluate whether a proposed cost allocation reasonably aligns cost \nresponsibility with causation and benefits.16 \nAs an initial matter, the Commission largely agreed with the foundational premise \nof PJM’s proposed RBP cost allocation methodology: the costs of procuring new capacity \nto address reliability concerns arising from large load growth should be assigned to the \nzone/areas experiencing that growth.  Specifically, the Commission’s September 29 Order \nexplained that: \nallocating RBP costs to Electric Distributor zone/areas based on a \n“snapshot” of load growth between 2026/2027 and 2028/2029, \nadjusted down by qualifying offset capacity, may be just and \nreasonable, because it reasonably assigns costs to those responsible \nfor the near-term capacity shortfall.  Thus, such zone/areas benefit \nfrom procurement of new resources to fill this urgent gap.  We \ngenerally find that PJM’s proposal to initially assign RBP costs to \nElectric Distributor zone/areas, with the ultimate cost allocation to \nthe LSEs as determined by the state and/or [Relevant Electric Retail \nRegulatory Authority (“RERRA”)] and as reported to the Electric \nDistributor by PJM, may be just and reasonable, as it reflects the \nauthority of PJM under the Tariff and respects the authority of the \nstates and/or RERRAs.17 \n \nThe Commission’s concerns were therefore not directed at the underlying cost \nallocation to the zone/area.  Rather, the Commission questioned whether PJM’s use of Load \nAdjustment data provided the most accurate means of identifying the Large Load growth \n \n15 City Util. of Springfield v. FERC, 185 F.4th 1262, 1271 (D.C. Cir. 2026) (internal quotation marks and \nalteration omitted).   \n16 City Util. of Springfield, 185 F.4th at 1273. \n17 September 29 Order, 196 FERC ¶ 61,245 at P 154."},{"page":8,"startToken":1805,"endToken":2127,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 7 \n \nthat is driving the need for the RBP.18  More particularly, the Commission was concerned \nwith “relying on Load Adjustments to measure load growth [because that] may be \ninconsistent or not reasonably capture forecasted load growth or actual large load \ngrowth.”19  That is, some large loads may be reflected in PJM’s underlying load forecast \nrather than in the incremental Load Adjustments used in PJM’s initial proposal.20  \nConsequently, the Commission was concerned that the use of the Load Adjustment delta \n“could lead to the costs imposed on certain entities not being at least roughly commensurate \nwith the benefits they will receive from the procurement.”21 \nThis filing directly addresses the Commission’s concern by allocating the “RBP \ncosts to the Electric Distributor zone/areas with the reported new load that is driving the \nneed for the procurement.”22  Specifically, rather than relying on Load Adjustment data as \na proxy for Large Load growth, PJM is proposing to require Electric Distributors outside \nof a Fixed Resource Requirement (“FRR”) Service Area to report, by no later than seven \ndays prior to the commencement of the RBP, the aggregate incremental peak Large Load \ngrowth between the 2026 actual summer peak and the 2028/2029 Delivery Year expected \nsummer peak to PJM.23  This updated approach will better align cost responsibility with \n \n18 PJM is utilizing the recently accepted definition of Large Load to capture only those loads that are end-use \ncustomer load that has a cumulative peak load of 50 MW or greater at a single electrical site behind one or \nmore points of interconnection. \n19 September 29 Order, 196 FERC ¶ 61,245 at P 154. \n20 September 29 Order, 196 FERC ¶ 61,245 at P 155. \n21 September 29 Order, 196 FERC ¶ 61,245 at P 155. \n22 September 29 Order, 196 FERC ¶ 61,245 at P 159. \n23 Proposed Tariff, Attachment DD, section 18.3A."},{"page":9,"startToken":2127,"endToken":2479,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 8 \n \nthe specific Large Load growth that necessitates the RBP while preserving the cost-\nallocation framework that the Commission otherwise found to be just and reasonable. \n1. \nRequiring Electric Distributors to report the Large Load increase \nbetween 2026 and the expected 2028/2029 Delivery Year will allow \nRBP cost allocation to all incremental Large Loads. \nRequiring each Electric Distributor to report the aggregate incremental Large Load \ngrowth between the 2026 actual summer peak and the 2028/2029 Delivery Year expected \nsummer peak is consistent with Commission precedent.24  Indeed, Electric Distributors \nalready report actual and forecasted peak loads to PJM today.  This proposal merely \nrequires Electric Distributors to provide a more granular subset of information relating \nspecifically to Large Load growth.  Under this proposal, each Electric Distributor outside \nan FRR Service Area will be required to report the aggregate incremental quantity of Large \nLoad, where the Large Load quantity for each load is calculated as the difference between: \n(1) the actual summer peak load associated with the Large Load in 2026; and (2) the \nexpected summer peak load associated with Large Load for the 2028/2029 Delivery Year.25  \nAdditionally, Electric Distributors will be required to report the identity of the Large Load \nthat is supported by an electric service obligation, construction commitment, or equivalent \nagreement.26  Because Electric Distributors maintain the direct distribution and metering \nrelationships associated with these loads and already serve as PJM’s primary source of \n \n24 See PJM Interconnection, L.L.C., 197 FERC ¶ 61,019, at PP 48-50 (2026); see also PJM Interconnection, \nL.L.C., 188 FERC ¶ 61,200, at P 40 & n.65 (2024) (finding that an “Electric Distributor is the party with the \ndistribution and metering facilities defining a zone/area and responsible for reporting load information to \nPJM,” and also noting that, “under the current framework, each LSE already reports their peak load \ncontribution to the Electric Distributor, which is the entity ultimately responsible for reporting that \ninformation to PJM”). \n25 Proposed Tariff, Attachment DD, section 18.3A. \n26 Proposed Tariff, Attachment DD, section 18.3A."},{"page":10,"startToken":2479,"endToken":2766,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 9 \n \nzonal load information, they are uniquely and aptly positioned to provide the most accurate \nand comprehensive information regarding incremental Large Load growth. \nConsistent with PJM’s load forecasting process, the expected quantity of Large \nLoad for the 2028/2029 Delivery Year reported under this proposal should largely align \nwith the information the Electric Distributor previously provided to PJM for development \nof the applicable load forecast.  However, because Large Load development is dynamic, \ncircumstances may change after submission of forecast data and before the reporting of \nLarge Load values for purposes of establishing the Reliability Pricing Model (“RPM”) \nprocurement targets.  This could potentially include new Large Loads that are now \nexpected to be online by the 2028/2029 Delivery Year that may not have previously been \nexpected at the time PJM developed the load forecast.  Conversely, there could be electric \nservice agreements with Large Loads that are canceled between the time Electric \nDistributors initially reported the data as part of PJM’s load forecast process and when the \nElectric Distributors report expected Large Loads for RBP purposes.  In either case, the \nproposal requires an Electric Distributor to “provide an explanation for any deviation \nbetween the expected quantity of Large Loads for the 2028/2029 Delivery Year and the \nvalues provided by the Electric Distributor to [PJM] as part of the development for the load \nforecast.”27  As always, PJM maintains the ability to refer Electric Distributors to the \nCommission’s Office of Enforcement in the event the reported information is significantly \ndifferent from what the Electric Distributor reported as part of PJM’s load forecast \ndevelopment process and such deviations are not sufficiently explained.  This requirement \n \n27 Proposed Tariff, Attachment DD, section 18.3A."},{"page":11,"startToken":2766,"endToken":3176,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 10 \n \nsafeguards against potential incorrect submissions while allowing PJM to rely on the most \ncurrent available information. \nThe proposed approach also satisfies the Commission’s cost-causation standards \nbecause it assigns costs in a manner that is roughly commensurate with the benefits \nreceived.28  Cost causation requires that “all approved rates reflect to some degree the costs \nactually caused by the customer who must pay them.”29  Indeed, as the courts have held, \n“nothing requires the Commission to ensure full or perfect cost causation,”30 and the \nCommission “is not bound to reject any rate mechanism that tracks the cost causation \nprinciple less than perfectly.”31   \nHere, the data reported by Electric Distributors represent the most practical and \nadministratively feasible measure of incremental Large Load growth for purposes of \nestablishing a cost allocation approach that will assign costs to the zone/areas where the \nincremental Large Loads will be located.  While no cost allocation methodology can \nachieve perfect precision, the Commission has repeatedly recognized that feasibility \nconsiderations are relevant and that cost-causation principles need only be applied in a \nreasonably accurate and practical manner.32  By relying on Electric Distributor’s reported \n \n28 Ill. Com. Comm’n, 576 F.3d at 477 (requiring “an articulable and plausible reason to believe that the \nbenefits are at least roughly commensurate with [the costs]”); Transmission Planning and Cost Allocation by \nTransmission Owning and Operating Public Utilities, Order No. 1000, 136 FERC ¶ 61,051, at PP 622, 639 \n(2011) (requiring costs of regional transmission facilities to be allocated in a manner that is at least roughly \ncommensurate with estimated benefits), order on reh’g & clarification, Order No. 1000-A, 139 FERC \n¶ 61,132, order on reh’g & clarification, Order No. 1000-B, 141 FERC ¶ 61,044 (2012), aff’d sub nom., S.C. \nPub. Serv. Auth. v. FERC, 762 F.3d 41 (D.C. Cir. 2014) (“South Carolina PSA”).   \n29 K N Energy v. FERC, 968 F.2d 1295, 1300 (D.C. Cir. 1992) (emphasis added); see also Midwest ISO \nTransmission Owners, 373 F.3d at 1368 (quoting K N Energy, 968 F.2d at 1300)). \n30 South Carolina PSA, 762 F.3d at 88.    \n31 Sithe/Indep. Power Partners, 285 F.3d at 5.  \n32 South Carolina PSA, 762 F.3d at 88; Midwest ISO Transmission Owners, 373 F.3d at 1368-69; Pub. Serv. \nComm’n of Wis. v. FERC, 545 F.3d 1058, 1066-67 (D.C. Cir. 2008); Carnegie Nat. Gas Co. v. FERC, 968"},{"page":12,"startToken":3176,"endToken":3541,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 11 \n \nincremental Large Load growth at the zonal or area level, the proposal tracks the costs \nassociated with emerging Large Load demand to the most granular level that is reasonably \nfeasible and therefore satisfies the Commission’s cost-causation requirements. \nTo be clear, the information required under this proposal will initially be reported \nseparately from the Large Load Registry that the Commission recently accepted because \nthe information required from the Electric Distributors serves a different purpose.  \nSpecifically, the reporting requirement here is targeted to quantify incremental Large Load \ngrowth between 2026 and the 2028/2029 Delivery Year for purposes of establishing the \nInitial RBP Target.  Nonetheless, to the extent appropriate, certain information submitted \nthrough this process may ultimately be incorporated into the Large Load Registry. \n2. \nRBP costs will be allocated to the zone/areas associated with \nincremental Large Loads. \nBased on information provided by Electric Distributors, PJM will allocate the \nInitial RBP Target among Electric Distributor zone/areas in proportion to each zone/area’s \nshare of the total incremental Large Load growth.  PJM will then reduce a zone/area’s \nallocated share to the extent PJM receives the requisite evidence, as detailed in Tariff, \nAttachment DD, section 18.2(c),33 of new capacity in the form of Qualifying RBP Offset \nUCAP MW that is the subject of a bilateral agreement with a Large Load.34  In addition, \nto the extent an Electric Distributor requests, with the required accompanying support \n \nF.2d 1291, 1293-94 (D.C. Cir. 1992) (noting that, in the section of the Natural Gas Act likened to FPA section \n205, there is “no requirement in the Act itself that rates precisely match cost causation and responsibility” \nand that instead “the Commission may rationally emphasize other, competing policies and approve measures \nthat do not best match cost responsibility and causation”).  \n33 Specifically, evidence of Qualifying RBP Offset UCAP MW must include signed bilateral contracts with \nLarge Loads for at least five Delivery Years with a commercial operation date prior to the start of the \n2032/2033 Delivery Year as further detailed in Tariff, Attachment DD, section 18.2(c). \n34 Proposed Tariff, Attachment DD, section 18.2(c)."},{"page":13,"startToken":3541,"endToken":3851,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 12 \n \npursuant to Tariff, Attachment DD, section 18.1(d), that the Initial RBP Target be \ndecremented to reflect the associated MW quantity of load participating in a qualifying \nPeak Shaving Adjustment program, the Initial RBP Target may be further reduced.35  After \naccounting for all Qualifying RBP Offset UCAP MW and any applicable Peak Shaving \nAdjustment opt-out, PJM will determine each zone/area’s adjusted incremental Large Load \nquantity.  That quantity, floored at zero, will serve as the basis for calculating the \nzone/area’s pro rata share of the Final RBP Target MW.  Ms. Danielle Croop, PJM’s senior \nmanager of market design, provides a detailed example that demonstrates how the RBP \nobligations will be allocated to each Electric Distributor’s zone/area.36 \nThis approach is consistent with the Commission’s determination that “[a]llocating \nRBP costs based on a snapshot of this shortfall over the term of the RBP commitment \nperiod may provide greater certainty to the LSEs in the Electric Distributor zone/areas \nultimately bearing responsibility for those costs.”37  Accordingly, PJM proposes to \ncontinue using a snapshot of incremental Large Load growth between the 2026 summer \npeak and the forecasted summer peak for the 2028/2029 Delivery Year to establish each \nzone/area’s share of the Final RBP Target MW.  That allocation to the zone/area will \nremain fixed throughout the 15-year RBP commitment period.  Maintaining a fixed \nallocation to the zone/area promotes certainty, provides transparent cost responsibility at \nthe outset of the commitment period, and avoids repeated reallocation of costs to different \nzone/areas during the term of the RBP Resource commitment. \n \n35 Proposed Tariff, Attachment DD, section 18.1(d). \n36 Affidavit of Danielle Croop on Behalf of PJM Interconnection, L.L.C. (Attachment D) ¶¶ 19-27 (“Croop \nAff.”). \n37 September 29 Order, 196 FERC ¶ 61,245 at P 156."},{"page":14,"startToken":3851,"endToken":4151,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 13 \n \n3. \nPJM will further allocate RBP Charges to relevant LSEs in the \nzone/areas with incremental Large Loads. \nPJM is retaining the mechanism through which RBP Charges may be more \ngranularly allocated to LSEs within an Electric Distributor’s zone/area.  As noted, above, \nthe September 29 Order held that “the ultimate cost allocation to the LSEs as determined \nby the state and/or RERRA and as reported to the Electric Distributor . . . may be just and \nreasonable[.]”38  Specifically, RBP Charges may be allocated based on “the state and/or \nRERRA-determined allocation of cleared RBP UCAP MW to LSEs within each Electric \nDistributor’s zone/area, as reported by each Electric Distributor to [PJM].”39  Likewise, \nPJM is maintaining the term, “RBP Obligation” or “RBO” to provide flexibility for states \nand/or RERRAs to further determine which retail customers should be allocated RBP \nCharges.40 \nThe RBO framework provides states and RERRAs, through the relevant Electric \nDistributors, with flexibility to determine how cost responsibility for RBP Resources \nshould be allocated among LSEs serving load within a zone/area.  To facilitate more \ntargeted cost allocation, an Electric Distributor may report to PJM an RBO allocation \nidentifying the RBP UCAP MW assigned to individual LSEs in the zone/area.  Where an \nRBO is reported, PJM will allocate the daily RBP Charges to each LSE based on its \nproportionate share of the reported RBO MW.  In this way, states and RERRAs may direct \n \n38 September 29 Order, 196 FERC ¶ 61,245 at P 154. \n39 Tariff, Attachment DD, section 18.3(b)(iii). \n40 Tariff, Part 1, Definitions – R-S, RBP Obligation (‘“RBP Obligation’ or ‘RBO’ shall mean the state and/or \nRERRA-determined allocation of RBP UCAP MW to Load Serving Entities within each Electric \nDistributor’s zone/area.”)."},{"page":15,"startToken":4151,"endToken":4500,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 14 \n \nrelevant Electric Distributors to report RBO so that RBP costs can more precisely be \nallocated to the LSEs serving the Large Loads that drive the need for the RBP Resources. \nElectric Distributors electing to provide RBO allocations must submit the initial \nallocation no later than 120 days before the start of the 2028/2029 Delivery Year.41  PJM \nproposes this deadline to allow sufficient time for the calculation and communication of \neach affected LSE’s credit requirements before collateral must be posted.  PJM has \nadvanced this deadline from the 60-day period proposed in the July 31 Filing to provide \nLSEs with additional notice regarding their potential credit obligations and adequate time \nto arrange and post collateral.  Importantly, the 120-day reporting deadline serves solely to \nestablish the initial allocation sufficiently in advance of the commencement of the \n2028/2029 Delivery Year.  That is, Electric Distributors do not have a continuing obligation \nto report RBO to PJM by a certain deadline prior to the commencement of a subsequent \nDelivery Year after the 2028/2029 Delivery Year.  Rather, Electric Distributors may report \nupdates to the RBO any time after the start of the 2028/2029 Delivery Year to reflect \nchanges to the initial allocation.  This may occur, as an example, if a Large Load switches \nLSEs after the initial RBO is reported to PJM.  \nPJM must be able to settle RBP Charges regardless of whether an Electric \nDistributor submits an RBO allocation.  Accordingly, if no RBO MW are reported for a \nzone/area, PJM will apply a backstop allocation methodology based on the existing \nmethodology for allocating capacity costs pursuant to RAA, Schedule 8.42  Under this \n \n41 Proposed Tariff, Attachment DD, section 18.3(b)(iii). \n42 Proposed Tariff, Attachment DD, section 18.3(b)(iii) (“If no RBO MW are reported to the Office of the \nInterconnection for an Electric Distributor zone/area, PJM will allocate the RBP Charges for that zone/area \nto all load in the zone/area using each LSE’s ratio share of the Daily Unforced Capacity Obligation for the"},{"page":16,"startToken":4500,"endToken":4785,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 15 \n \napproach, if no allocation is reported by the relevant Electric Distributors with allocated \nRBP UCAP MW, PJM will allocate RBP Charges among LSEs in the relevant zone/area \nusing each LSE’s proportional Daily Unforced Capacity Obligation.  This fallback \nmethodology allows PJM to calculate and settle wholesale charges among its jurisdictional \ncustomers even in the absence of state- or RERRA-directed RBO allocations. \n4. \nThe proposed allocation methodology respects the federal-state \njurisdictional boundary; cost allocation to retail customers, \nincluding data centers, is within the states’ and/or RERRAs’ \npurview.  \nThe proposed methodology also appropriately respects the longstanding division of \njurisdiction between PJM and the states.  As the Commission recognized, “states determine \nhow Commission-approved rates are collected among the relevant retail consumers along \nwith the rates for state-jurisdictional matters.”43  Consistent with that principle, PJM’s \nproposal governs only the allocation of RBP Charges among wholesale market \nparticipants, specifically the LSEs responsible for paying those charges. \nPJM does not propose, and lacks authority, to dictate how any LSE subsequently \nallocates or recovers those costs from retail customers.  Thus, even where PJM applies its \ndefault LSE-level allocation methodology because no RBO has been reported, PJM would \nnot determine how costs are ultimately assigned among retail customers served by those \nLSEs.  In this way, the proposed approach appropriately allocates wholesale cost \nresponsibility while preserving the ability of states and RERRAs to determine how those \n \nzone/area as determined in RAA, Schedule 8.  PJMSettlement shall be the Counterparty to each LSE’s \nobligation to pay, and payments of, RBP Charges.”).    \n43 September 29 Order, 196 FERC ¶ 61,245 at P 161 (quoting PJM Interconnection, L.L.C., 195 FERC \n¶ 61,211, at P 69 (2026))."},{"page":17,"startToken":4785,"endToken":5063,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 16 \n \ncosts should be reflected at the retail level.  In short, the proposal maintains a framework \nthrough which states and RERRAs may, if they choose, direct RBP costs more precisely \nto the specific Large Load retail customers whose load growth drives the need for the \nunderlying RBP Resources. \nB. \nCredit Requirements of LSEs Commensurate with Risks (Proposed Tariff, \nAttachment DD, Section 18.8). \nPJM is proposing revisions to the LSE credit rules in Tariff, Attachment DD, \nsection 18.8(b) that the Commission accepted, subject to refund and further procedures, in \nthe September 29 Order.   \nIn the July 31 Filing, and as accepted subject to the outcome of a paper hearing, \nPJM proposed to establish an initial RBP Credit Rate of $1.5 million per committed RBP \nUCAP MW, which would collateralize approximately 50% of the (up to) 15-year \ncontractual payment obligation to the committed RBP Resources.  The Commission \nidentified several issues that, “[t]aken together,” led the Commission to find that PJM’s \ninitial RBP LSE credit rules may be unjust and unreasonable.44  Specifically, the \nCommission indicated that PJM did not adequately support the level of RBP Charges that \nPJM asserted needed to be collateralized “with any quantitative measures, including an \nexpected probability of default, a loss-given-default assumption, a historical LSE default \nexperience, a liquidation or replacement period, or any other quantitative measure.”45  The \nCommission also found that PJM’s proposed LSE credit rules provided LSEs “little \nflexibility . . . to manage their collateral requirements, including a short timeline for \n \n44 September 29 Order, 196 FERC ¶ 61,245 at P 205. \n45 September 29 Order, 196 FERC ¶ 61,245 at P 205."},{"page":18,"startToken":5063,"endToken":5386,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 17 \n \n[learning of] and posting collateral and limited, acceptable forms of collateral.”46  Thus, \nthe Commission held that PJM did not demonstrate that its proposed approach struck “a \nreasonable balance . . . against the risk of default and ensuring market participants have \nadequate flexibility to manage their collateral requirements.”47 \nPJM has re-evaluated its initial proposal in light of the Commission’s guidance and \ndeveloped a new RBP Credit Rate along with revisions to other aspects of the LSE credit \nrules to provide LSEs greater flexibility.  PJM proposes five broad changes to the RBP \nLSE credit rules: \n(1) establish, using objective data, a revised uniform credit rate, based on \nquantitative analyses, for LSEs allocated responsibility for RBP Charges to post \ncollateral;48  \n(2) lengthen the timeframe from when an LSE is assigned responsibility for RBP \nCharges before a Delivery Year to the time by which collateral must be \nposted;49  \n(3) broaden the instruments that may be used to provide collateral to include surety \nbonds in addition to Letters of Credit and cash;50   \n(4) memorialize a commitment to review the RBP Credit Rate used to determine \nthe credit requirement for LSEs assigned responsibility for RBP Charges;51 and  \n(5) clarify that an LSE’s payment obligations for committed RBP Resources, i.e., \nboth RBP Charges and associated RPM capacity payments will not be \nconsidered in determining such LSE’s Peak Market Activity.52   \n \n46 September 29 Order, 196 FERC ¶ 61,245 at P 205. \n47 September 29 Order, 196 FERC ¶ 61,245 at P 205. \n48 See proposed Tariff, Attachment DD, section 18.8(b)(i)(B). \n49 See proposed Tariff, Attachment DD, section 18.3(b)(iii) and proposed Tariff, Attachment DD, \nsection 18.8(b)(i)(B). \n50 See proposed Tariff, Part 1, Definitions – R-S, RBP Collateral.  \n51 See proposed Tariff, Attachment DD, section 18.8(b)(i)(A). \n52 See proposed Tariff, Attachment DD, section 18.8."},{"page":19,"startToken":5386,"endToken":5686,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 18 \n \nAs discussed below, these revisions offer an approach that strikes “a reasonable balance \nbetween protecting PJM’s markets and its members against the risk of default and ensuring \nthat market participants have adequate flexibility to manage their collateral \nrequirements.”53   \n1. \nPJM is proposing a revised RBP Credit Rate, determined using \nobjective, quantitative analyses, for LSEs allocated responsibility \nfor RBP Charges.  \na. \nPJM derived the revised RBP Credit Rate based on an \neconomic analysis of quantitative and qualitative inputs. \nThe 15-year term of RBP commitments is markedly different from all other forward \npayment obligations contemplated by PJM’s credit rules today.  To address this credit risk \nin a just and reasonable manner, PJM considered a number of different approaches with an \neye toward approaches that would minimize costs to LSEs and appropriately mitigate cost \nof socialized default on PJM Members.  Specifically, PJM considered credit approaches \nthat would provide more fluid and constant assessments of credit risk and vary the \ncollateral required, based on either new data as it becomes known (e.g., RPM Auction \nclearing prices) or forecasts of variable data (e.g., RPM Auction clearing prices).  But, as \nMs. Gwen Kelly explains, an approach based on forecasts would fail to adequately mitigate \nrisk to Members as “PJM could be left with insufficient collateral to secure the LSE’s \npayment obligations”54 because their efficacy would be dependent on the accuracy of \n“forecasts of RPM clearing prices extending many years into the future.”55  Ultimately, as \nproposed in this filing, PJM selected an approach that collateralizes the entire payment \n \n53 PJM Interconnection, L.L.C., 186 FERC ¶ 61,055, at P 27 (2024).   \n54 Affidavit of Gwen Kelly on Behalf of PJM Interconnection, L.L.C. (Attachment C) ¶ 13 (“Kelly Aff.”). \n55 Kelly Aff. ¶ 11."},{"page":20,"startToken":5686,"endToken":5950,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 19 \n \nobligation to an RBP Resource, i.e., both the BRP Charge (which is a contract for \ndifference) and the resource’s RPM capacity payment.  As Ms. Kelly testifies, “PJM favors \na methodology that establishes meaningful credit protection based on long-term RBP \ncommitments rather than making that protection substantially dependent on forecasts of \nfuture RPM clearing prices or on the ability to obtain additional collateral over time.”56  \nThat is, PJM’s approach does not require forecasting of future RPM clearing prices or \nannual adjustments based on the applicable RPM capacity payment for a given Delivery \nYear.  Rather, PJM is maintaining its initial approach of establishing a single credit \nobligation applicable to the entire RBP payment obligation through application of a \nuniform RBP Credit Rate for each RBP UCAP MW for which an LSE is assigned cost \nresponsibility.   \nHowever, PJM determined that its approach to determining the RBP Credit Rate \nshould be revisited.  Ms. Kelly testifies that “PJM sought to identify the collateral \npercentage at which the combined expected costs of posting collateral and socialized \ndefault amounts are minimized.”57  Given that “[t]hese costs generally move in opposite \ndirections,”58 PJM “performed an economic analysis evaluating the cost of posting \ncollateral and the expected cost of socialized default amounts at different collateral levels, \nexpressed as percentages of the net present value of the total RBP payment obligation” to \ndetermine the appropriate collateral percentage, i.e., the RBP Credit Rate.59  In performing \n \n56 Kelly Aff. ¶ 14. \n57 Kelly Aff. ¶ 19. \n58 Kelly Aff. ¶ 18. \n59 Kelly Aff. ¶ 22."},{"page":21,"startToken":5950,"endToken":6249,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 20 \n \nthis economic analysis, PJM considered the following inputs:  the weighted-average RBP \nclearing price, the credit quality of the portfolio of LSEs active in PJM, the probability of \ndefault, the loss given default, and the cost of posting collateral.60   \nMs. Kelly details in her affidavit how PJM developed and considered these \nquantitative and qualitative inputs.61  The results of PJM’s economic analysis is presented \nin Table 1 below. \nTable 1: Cost of Socialized Default Amount \n \nPJM then took these inputs to evaluate “the combined expected costs of posting collateral \nand socialized default amounts at different collateral levels, expressed as percentages of \nthe discounted total RBP payment obligation.”62  Ms. Kelly explains that “the combined \ncost of posting collateral and expected socialized default amounts is minimized at a \n \n60 Kelly Aff. ¶ 23.  Ms. Kelly also testifies that “PJM has used a discount rate of 9.5%, based on the capacity \nmarket Weighted Average Cost of Capital developed by The Brattle Group as part of PJM’s 2025 periodic \nreview of the Cost of New Entry of Capacity Resources into the PJM Region.  PJM considers this rate \nappropriate for purposes of calculating the net present value of the total RBP payment obligation.”  Kelly \nAff. ¶ 24.   \n61 See Kelly Aff. ¶¶ 25-38. \n62 Kelly Aff. ¶ 39. \na) LSE Credit Ratings (weighted average)\nBBB\nb) Probability of Default\n4.05%\nc) Loss Given Default\n100%\nd) expected default %\n2.4%\nadjusted by the amount \nposted to PJM\ne) Defaulted Amount\n$73,839 =$555 x 1 x 365 x 15 x 2.4%\nf) Collateral Held\n$29,535 =$73,839 x 40%\ng) Socialized Amount (=Defaulted Amount- Collateral Held)\n$44,303 =$73,839 - $29,535\nh) Socialized Cost to Non Default LSEs\n$45,407 =$44,303 / (1-2.4%)"},{"page":22,"startToken":6249,"endToken":6423,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 21 \n \ncollateral level equal to 40% of the net present value of the total RBP payment \nobligation,”63 as shown in Figure 1 below. \nFigure 1: Optimal Collateralization  \n \nAs Ms. Kelly explains, this 40% rate “does not represent the percentage of gross RBP \npayments that PJM expects LSEs to pay through contract-for-differences settlements,” \nrather, it represents the rate at which “the combined cost of posting collateral and expected \nsocialized default amounts” are minimized.64  Or stated another way, it is an economically \noptimal rate.   \nIn sum, following the Commission’s guidance in the September 29 Order,65 PJM \nperformed an economic analysis, that considered the qualitative measure of the credit \n \n63 Kelly Aff. ¶ 40. \n64 Kelly Aff. ¶ 42.  \n65 See September 29 Order, 196 FERC ¶ 61,245 at P 205 (finding that PJM did not support the initial RBP \nCredit Rate “with any quantitative measures, including an expected probably of default, a loss-given-default \nassumption, a historical LSE default experience, a liquidation or replacement period, or any qualitative \nmeasure”)."},{"page":23,"startToken":6423,"endToken":6764,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 22 \n \nquality of the portfolio of LSEs active in PJM and the quantitative measure of probability \nof default, the loss given default, and the cost of posting collateral.  Based on such analysis, \nPJM proposes to set the RBP Credit Rate at 40% of the net present value of the total RBP \npayment obligation.66  \nApplying the proposed new RBP Credit Rate at an assumed weighted-average RBP \nclearing price of $555/MW-day, Ms. Kelly finds that “the proposed methodology produces \nan illustrative RBP Credit Rate of approximately $686,000 per MW.  This amount is \nequivalent to approximately 3.4 years of undiscounted RBP payments per MW.”67  This \nrepresents a significant reduction from the $1.5 million/MW RBP Credit Rate PJM initially \nproposed—a reduction in cost to post to affected LSEs which naturally results in a tradeoff \nreduction in the collateral coverage that protects PJM Members against socialized default \namounts.  Given that for the purposes of this example PJM assumed the weighted-average \nRBP clearing price would be at maximum allowable value of $555/MW-day,68 the \nillustrative RBP Credit Rate of approximately $686,000 per MW is the highest possible \nRBP Credit Rate and would be lower to the extent the MW-weighted average of the \nlevelized procurement cost of all committed RBP Resources is less than $555/MW-day. \nb. \nClarifying revisions for determining cumulative LSE RBP \nCredit Requirement \nAs noted, PJM is retaining its initial structure of first determining the overall credit \nrequirement needed to address this risk at an aggregate level before then determining an \n \n66 See proposed Tariff, Attachment DD, section 18.8(b)(i)(A).  Ms. Kelly explains how PJM will determine \nthe net present value of the total RBP payment obligation.  See Kelly Aff. ¶ 24. \n67 Kelly Aff. ¶ 48. \n68 See September 29 Order, 196 FERC ¶ 61,245, at P 74 (“[W]e find that using the $555/MW-day price cap \nfor the 2028/2029 BRA . . . is a reasonable proxy of load’s maximum willingness to pay for RBP capacity.”)"},{"page":24,"startToken":6764,"endToken":7070,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 23 \n \nindividual LSE’s RBP credit requirement.  PJM will determine the cumulative LSE RBP \ncredit requirement equal to “the RBP Credit Rate (as determined in accordance with Tariff, \nAttachment DD, section 18.8(b)(i)(B)) multiplied by the committed RBP UCAP MW \namount.”69  That is, one uniform RBP Credit Rate will be applicable to all committed RBP \nUCAP MW, and the cumulative RBP credit requirement for LSEs shall be met through \nRBP Collateral posted by those LSEs with responsibility for RBP Charges pursuant to \nTariff, Attachment DD, section 18.3. \nHowever, PJM is proposing revisions to clarify that the committed RBP UCAP \nMW for such purpose will be the “total amount of RBP UCAP MW that receives a \ncommitment through the Reliability Backstop Procurement and is supported by an RBP \nResource that has reached commercial operation by the start of the applicable Delivery \nYear.”70  And, the committed RBP UCAP MW “shall exclude” any RBP UCAP MW that \nis rescinded pursuant to Tariff, Attachment DD, section 18.6(e).71  In other words, no \ncollateral would be required for RBP Resources not in service for that Delivery Year. \nc. \nClarifying revisions regarding PJM’s return of excess \ncollateral \nWhile the accepted Tariff provides that PJM will reduce the RBP Credit Rate “when \ntotal posted RBP Collateral is greater than the total remaining RBP Charges obligations \nover time by the Office of the Interconnection to an amount sufficient to cover the total \nexisting RBP Charges obligations,”72 PJM proposes to not change the RBP Credit Rate in \n \n69 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A).  \n70 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A). \n71 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A). \n72 Tariff, Attachment DD, section 18.8(b)(i)(A)."},{"page":25,"startToken":7070,"endToken":7373,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 24 \n \nsuch instance.  Rather, PJM proposes that “[w]hen total posted RBP Collateral is greater \nthan the total remaining RBP payment of obligations, the Office of the Interconnection will \nmake available excess collateral, upon request by an applicable Load Serving Entity.”73  \nThat is, PJM will only be holding collateral sufficient to cover about 3.4 years of remaining \nRBP payment obligations (the sum of RBP Charges and RPM payments).  Thus, as the \nRBP commitment period carries on, the new approach affords PJM flexibility to release \nexcess collateral while maintaining sufficient collateral to mitigate against default risk.   \nd. \nClarifying revisions for the determination of the RBP LSE \ncredit requirement \nPJM proposes to maintain its approach that the RBP credit requirement will follow \ncost allocation for RBP Resources.  Thus, only those LSEs allocated cost responsibility \nwill be assigned an RBP credit requirement and be required to post RBP Collateral, and \nthe RPM credit requirement will be based on the level of RBP UCAP MW for which an \nLSE is allocated cost responsibility.  In this manner, the RBP credit requirement is aligned \nwith cost allocation. \nPJM is proposing new Tariff language to clarify the determination of an LSE’s RBP \ncredit requirement, which will still equal the product of (1) the uniform RBP Credit Rate; \nand (2) the LSE’s allocated RBP UCAP MW amount, i.e., its Allocated RBP Credit MW.  \nFirst, reflective of PJM’s movement from a stated RBP Credit Rate to one based on a \npercentage of the payment obligation, PJM is proposing to define RBP Credit Rate as “an \namount per MW equal to 40% of the discounted total RBP payment obligation per MW \nover the applicable RBP commitment term, calculated using the weighted-average RBP \n \n73 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A)."},{"page":26,"startToken":7373,"endToken":7681,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 25 \n \nclearing price of all RBP UCAP MW committed through the RBP.”74  Second, for clarity \nand ease of understanding and application, PJM is defining “Allocated RBP Credit MW” \nas “the amount of RBP UCAP MW, expressed in MW, for which the LSE has been \nallocated responsibility for RBP Charges in accordance with Tariff, Attachment DD, \nsection 18.3 and as determined in accordance with this Tariff, Attachment DD, \nsection 18.8(b)(i)(B)(1) or (2), as appropriate.”75   \nAccepted sections 18.8(b)(i)(B)(1) and (2) detail how an LSE allocated cost \nresponsibility determine the amount of collateral they need to post.  While PJM is not \nproposing to change this structure, PJM is proposing some revisions to reflect the new RBP \nCredit Rate and clarify the determination of an LSE’s Allocated RBP Credit MW.  PJM is \nalso taking the opportunity to make some wordsmithing revisions for ease of \nunderstanding.76  Specifically, PJM is clarifying that, in the event the LSE’s cost allocation \nis determined through an RBO, PJM will determine its Allocated RBP Credit MW “based \non the relevant Load Serving Entity’s percent share of the zone/area’s RBP Obligation MW \nassigned by the Electric Distributor,”77 instead of scaling the RBP Obligation MW “in the \nevent the total the RBP Obligation MW values uploaded by the Electric Distributor do not \nsum to the fixed, Final RBP Target MW for the zone/area.”78 \n \n74 Proposed Tariff, Attachment DD, section 18.8(b)(i)(B). \n75 Proposed Tariff, Attachment DD, section 18.8(b)(i)(B). \n76 See proposed Tariff, Attachment DD, section 18.8(b)(i)(B)(1) and (2) (wordsmithing revisions). \n77 Proposed Tariff, Attachment DD, section 18.8(b)(i)(B)(1). \n78 Tariff, Attachment DD, section 18.8(b)(i)(B)(1)."},{"page":27,"startToken":7681,"endToken":8017,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 26 \n \n2. \nPJM is proposing to lengthen the timeframe from when an LSE is \nassigned responsibility for RBP Charges to the time by which \ncollateral must be posted from 15 days to 75 days.  \nPJM is proposing that LSEs be provided at least 75 days’ notice of their collateral \nobligation prior to a given Delivery Year before the LSE must have the requisite RBP \nCollateral posted.  That is, PJM is not changing the rule that LSEs must post RBP Collateral \nat least 45 days before the start of a Delivery Year in which the LSE is allocated \nresponsibility for RBP Charges.79  Rather, as discussed above in Part II.A, PJM is \nproposing that Electric Distributors report their initial RBP Obligation values to PJM at \nleast 120 days prior to the start of the 2028/2029 Delivery Year.  PJM is not proposing to \nchange the rule that if no RBP Obligation is reported for an Electric Distributor zone/area, \nthen RBP Charges allocated to that zone/area will be assign to each LSE “using each LSE’s \nratio share of the Daily Unforced Capacity Obligation for the zone/area as determined in \nRAA, Schedule 8.”80   \nThus, each LSE will know no later than 120 days before the 2028/2029 Delivery \nYear whether it will be assigned RBP Charges and if so, how much.  Correspondingly, by \napplying the uniform RBP Credit Rate to the MW underlying its assigned RBP Charges, \neach LSE will also be able to easily determine its RBP Collateral requirement 120 days \nbefore the start of the 2028/2029 Delivery Year.  As such, LSEs will be afforded at least \n75 days to post their RBP Collateral, providing LSEs greater flexibility to manage their \ncollateral requirements. \n \n79 Compare July 31 Filing, Attachment B at proposed Tariff, Attachment DD, sections 18.8(b)(i)(B)(1), (2), \nwith proposed Tariff, Attachment DD, sections 18.8(b)(i)(B)(1), (2). \n80 Tariff, Attachment DD, section 18.3(b)(iii)."},{"page":28,"startToken":8017,"endToken":8366,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 27 \n \n3. \nPJM is proposing to broaden the forms of acceptable collateral to \ninclude surety bonds.  \nIn response to the Commission’s assertion that PJM’s initial LSE credit rules \nerrantly “limited . . . acceptable forms of collateral”81 to Letters of Credit and cash, PJM \nre-assessed whether it could accept other forms of collateral, and determined that it also \ncould accept surety bonds.  Accordingly, PJM is proposing to revise the definition of RBP \nCollateral to include surety bonds,82 providing LSEs additional flexibility to manage their \ncollateral requirements.  As Ms. Kelly testifies, all three of these acceptable forms of \ncollateral “provide [PJM] reliable financial protection that PJM can access promptly when \nnecessary, without conditions that could delay or impair its ability to obtain payment.”83   \nFrom the start, PJM considered the unsecured credit available from existing Market \nParticipants.  But, as PJM explained in the initial RBP proceeding, there are two primary \nreasons that unsecured credit is not an appropriate form of collateral for RBP payment \nobligations.  One, PJM’s experience “has shown that, generally speaking, Market \nParticipants used their full amount of unsecured credit to cover their Peak Market Activity \ncredit obligations associated with those periods.”84  Two, the ability of the entity proffering \nthe unsecured credit to “access to liquidity may . . . evaporate [during the up to 15-year \nterm of the RBP contract], making it functionally unable to post additional collateral \n \n81 September 29 Order, 196 FERC ¶ 61,245 at P 205. \n82 Proposed Tariff, Part 1, Definitions – R-S, RBP Collateral (“‘RBP Collateral’ shall mean any one of: (1) a \ncash deposit, including any interest thereon, (2) a surety bond with a provider, amount and form determined \nby and acceptable to PJM or PJMSettlement, or (3) a letter of credit issued for the benefit of PJM or \nPJMSettlement, with a provider, amount and form determined by and acceptable to PJM or \nPJMSettlement.”). \n83 Kelly Aff. ¶ 57. \n84 PJM Interconnection, L.L.C., Motion for Leave to Answer and Answer of PJM Interconnection, L.L.C., \nDocket No. ER26-3380-000, at 85 (Sep. 10, 2026) (“PJM RBP Answer”)."},{"page":29,"startToken":8366,"endToken":8678,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 28 \n \nprecisely when default risk rises.”85  In short, Market Participants already use all their \nunsecured credit available today so none is available to cover a 15-year payment obligation.  \nAnd, even if some were available, it is not a form of collateral you can draw down on, and \nit is not convertible to cash.  In addition, RBP’s long-term payment obligation precludes \nPJM having the requisite confidence in the ability to draw on an unsecured credit to \nmeaningfully cover the payment obligation.  Therefore, allowing an LSE’s credit \nrequirement to be met through unsecured credit would inappropriately shift the default risk \nto PJM’s Members. \n4. \nUpon garnering sufficient experience, PJM will review the RBP \nCredit Rate and will present any recommendations to stakeholders. \nThings change over time; PJM recognizes that.  The quantitative and qualitative \nanalysis that support the proposed RBP Credit Rate could change over time such that a \nreview of the RBP Credit Rate may be warranted in order for the LSE credit requirement \nto continue to “strike a reasonable balance . . . against the risk of default and ensuring \nmarket participants have adequate flexibility to manage their collateral requirements.”86  \nAccordingly, PJM is proposing to memorialize in its Tariff a requirement for PJM to review \nthe RBP Credit Rate “[f]ollowing the commencement of commercial operation of all \nCapacity Resources with RBP commitments.”87  This review will look at the inputs used \nto the determine the RBP Credit Rate, allowing PJM to identify whether and to what degree \nchanges in the inputs over time may affect the RBP Credit Rate.  In other words, PJM \nwould evaluate the inputs discussed in Part II.B.1 above, including, for example, changes \n \n85 PJM RBP Answer at 85. \n86 September 29 Order, 196 FERC ¶ 61,245 at P 205. \n87 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A)."},{"page":30,"startToken":8678,"endToken":8996,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 29 \n \nin the weighted-average credit rating of the portfolio of LSEs operating in PJM and the \ncost incurred by LSEs in providing collateral (e.g., the five-year historical trend in the 30-\nday average Secured Overnight Financing Rate).  As Ms. Kelly explains, “[i]f PJM \nidentifies material changes that would affect the RBP Credit Rate, PJM will reassess the \nRBP Credit Rate.”88  To the extent PJM identifies the need for any changes, the proposed \nTariff revisions require PJM to “present any recommendations to stakeholders through the \nMembers Committee.”89   \nPJM is proposing to conduct this review once all committed RBP Resources reach \ncommercial operation,90 which will be a point in time in which there will be certainty as to \nthe entire set of RBP Resources as well as afford PJM and Market Participants a few \nDelivery Years’ worth of experience under the proposed RBP Credit Rate before \nevaluating whether it needs to be revised.  PJM would conduct such review no later than \nthe 2035/2036 Delivery Year, given that all RBP Resources should achieve commercial \noperation by June 1, 2032, or face RBP Shortfall Charges and RBP commitments will be \nrescinded for RBP Resources that fail to achieve commercial operation within three \nDelivery Years of the first Delivery Year for which the RBP Resource is committed.   \n5. \nPJM is clarifying that Credit Requirements for RBP Charges shall \nnot be included in existing PJM credit tools. \nThe proposed LSE credit requirement should require the provision of adequate \ncredit to mitigate the risk of paying for the RBP commitments over their term.  To be clear, \n \n88 Kelly Aff. ¶ 62. \n89 Proposed Tariff, Attachment DD, section 18.8(b)(i)(A). \n90 To the extent any RBP commitment is rescinded pursuant to Tariff, Attachment DD, section 18.6(e), PJM \nwould ignore such RBP Resource in determining when to commence the review."},{"page":31,"startToken":8996,"endToken":9302,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 30 \n \nthe LSE credit requirement is designed to cover both parts of the forward payment \nobligation due to a committed RBP Resource—the RBP Charges (i.e., the contract for \ndifferences) and the Locational Reliability Charges (i.e., RPM capacity payments).91  \nTherefore, to avoid double counting the RPM capacity payment obligation, PJM is \nproposing revisions to Tariff, Attachment DD, section 18.8 to remove language that could \nallow PJM to consider RBP Charges and RPM capacity payments owed such RBP \nResource through its other credit tools in Tariff, Attachment Q, including the Peak Market \nActivity.  In fact, PJM is proposing revisions to make explicit that such payment \nobligations “shall not be included in Peak Market Activity” and is deleting the language \nthat “[n]othing in this Tariff, Attachment DD, section 18.8 supersedes the provisions of \nTariff, Attachment Q.”92  These revisions resolve in the negative any doubt as to whether \nPJM’s proposed RBP credit requirement is duplicative of any existing PJM credit rule. \nC. \nTreatment of RBP Commitment in Event of Transmission Owner Exit \nDuring Term of the Commitment (Proposed Tariff, Attachment DD, \nSection 18.7) \nThe September 29 Order states that “the proposed Transmission Owner exit \nprovisions [from PJM’s July 31 Filing] may be inconsistent with the cost causation \nprinciple because they do not assign costs to the entities that cause the costs and benefit \nfrom the capacity procurement under the RBP, i.e. LSEs.”93  In response, PJM is proposing \nto modify Tariff, Attachment DD, section 18.7 to put LSEs on notice that, in the event of a \nwithdrawal from PJM, LSEs will continue to be responsible for any remaining RBP \n \n91 See Kelly Aff. ¶ 59. \n92 Tariff, Attachment DD, section 18.8. \n93 September 29 Order, 196 FERC ¶ 61,245 at P 179."},{"page":32,"startToken":9302,"endToken":9632,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 31 \n \nCharges that are allocated to them during the term of the RBP commitment.  To be clear, \nthis provision is designed to address the limited scenario where an LSE assigned \nresponsibility for RBP Charges is electrically separated from PJM as a result of another \nentity that physically withdraws from PJM.  It does not apply to scenarios where a Large \nLoad may switch LSEs during the term of the RBP commitment as those changes would \nordinarily be reflected in the Daily Unforced Capacity Obligation or Reliability Backstop \nObligation that is used to charge for the RBP obligations. \nSpecifically, PJM proposes to modify the exit provision in proposed Tariff, \nAttachment DD, section 18.7 as follows:  \nIn the event a Load Serving Entity that is allocated RBP Charges \nwithdraws from PJM (whether or not caused by the physical \nwithdrawal of another entity from the PJM Region), such Load \nServing Entity shall be responsible for the remainder of the RBP \nCharges allocated to it, subject to a rate filing with the Federal \nEnergy Regulatory Commission that details the specific terms and \namounts owed. Nothing in this provision shall limit such Load \nServing Entity’s ability to seek redress from another entity to the \nextent the Load Serving Entity’s withdrawal is caused by that other \nentity’s physical withdrawal from the PJM Region. \nTo date, no LSEs have indicated an intention to withdraw from PJM.  Nevertheless, the \nproposed Tariff provision is needed to: (1) put LSEs on notice of how RBP commitments \nwill be honored; (2) recognize that a primary incentive for developers to participate in the \nRBP is the cost certainty afforded by a 15-year commitment; (3) aid in the financing of \nRBP Resources that can be developed and placed in service quickly; and (4) protect \nremaining customers in PJM from stranded costs arising from RBP Charges.  As proposed, \nthe Tariff language may be divided into the following three distinct subparts, which PJM \nwill address, in turn, below:"},{"page":33,"startToken":9632,"endToken":9931,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 32 \n \n1) broad notice to LSEs of their responsibility for allocated RBP Charges in \nthe event of withdrawal;  \n2) recognition that, in the event of withdrawal, details about specific terms and \namounts owed will be subject to subsequent filings with the Commission; \nand  \n3) express preservation of an LSE’s ability to seek redress under certain \ncircumstances.   \n1. \nLSEs are on notice that, in the event of withdrawal, LSEs will \ncontinue to be responsible for RBP Charges allocated to them.   \nThe September 29 Order suggests that “a just and reasonable approach could \nrequire LSEs in an exiting Transmission Owner’s zone to pay RBP exit fees commensurate \nwith their cost allocation under the RBP, to prevent cost shifts to other LSEs in the PJM \nRegion.”94  Accordingly, PJM proposes to require that LSEs, rather than exiting \nTransmission Owners, cover costs commensurate with the RBP Charges allocated to them.  \nThe modified Tariff language follows the guidance provided in the September 29 Order \nand finds support in Commission precedent, and is therefore just and reasonable. \nFirst, the September 29 Order suggests that a more legally durable approach to \nguarding against stranded RBP costs in the event of a withdrawal from PJM would be to \nrequire RBP Charges to follow an exiting LSE, rather than the exiting Transmission Owner.  \nAs the Commission observed in the September 29 Order, in Duquesne, the LSE \n“understood that PJM was procuring capacity on its behalf,” and “PJM’s obligation to pay \ngenerators is fixed at the time of the auction.”95  It follows that, in Duquesne, LSEs located \n \n94 September 29 Order, 196 FERC ¶ 61,245 at P 181. \n95 September 29 Order, 196 FERC ¶ 61,245 at P 178 (quoting Duquesne Light Co., 122 FERC ¶ 61,039, at P \n89 (2008))."},{"page":34,"startToken":9931,"endToken":10234,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 33 \n \nin an exiting Transmission Owner’s zone continued to be obligated to pay for capacity \nprocured through the RPM.96   \nAccording to the September 29 Order, RBP Charges are analogous to the cost of \ncapacity procured through the RPM in Duquesne, because:  \nUnder its RBP proposal, PJM similarly proposes to procure capacity \nthrough the RBP on behalf of LSEs, establish obligations to pay \nRBP Resources at the time of the procurement, and later allocate \nthose costs to LSEs.  PJM fails to explain why Transmission \nOwners—who are not the buyers for which PJM procures capacity \nunder the RBP—should be responsible for RBP Charges.97  \nBecause LSEs, not exiting Transmission Owners, are the buyers for which PJM procures \ncapacity under the RBP, LSEs are the beneficiaries of the RBP Resources procured by PJM.  \nThus, as the September 29 Order suggests, even where an exiting Transmission Owner \nultimately causes an LSE to withdraw involuntarily from PJM, LSEs nevertheless remain \nthe underlying cause for the RBP Resources and associated RBP Charges established at the \ntime of procurement.  Thus, as the Commission suggests, it is reasonable to continue \nrequiring LSEs to cover RBP Charges allocated to them, even after they have withdrawn \nfrom PJM.  Thus, PJM is revising its proposed Tariff, Attachment DD, section 18.7 to \nrequire that LSEs, rather than exiting Transmission Owners, continue to cover the costs of \nRBP Charges allocated to them.   \nSecond, PJM’s proposed Tariff language is drafted broadly to put exiting LSEs on \nnotice of ongoing cost responsibility for RBP Charges allocated to them, without regard to \nwhether those LSEs have exited PJM involuntarily based on their location in an exiting \n \n96 September 29 Order, 196 FERC ¶ 61,245 at P 178. \n97 September 29 Order, 196 FERC ¶ 61,245 at P 178."},{"page":35,"startToken":10234,"endToken":10489,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 34 \n \nTransmission Owner’s zone.  In PJM, an LSE is defined by its role as an entity serving \nend-use customers within the PJM Region with the authority or obligation to sell electric \nenergy to such end-users.98  LSEs without physical assets would generally withdraw from \nPJM when the end-users they serve are located in an exiting Transmission Owner’s zone.  \nThus, the September 29 Order suggests that a just and reasonable approach could require \n“LSEs in an exiting Transmission Owner’s zone” to continue paying RBP Charges \nallocated to them.99   \nPJM’s proposed Tariff provision recognizes that, in light of the numerous different \nconfigurations found in PJM, it is possible that LSEs may withdraw from PJM for reasons \nother than a Transmission Owner’s physical withdrawal from the PJM Region.  Thus, \nPJM’s proposed Tariff provision puts LSEs on notice that they will be responsible for the \nremainder of RBP Charges allocated to them whether or not their exit was caused by the \nphysical withdrawal of another entity from the PJM Region.  Likewise, the revised Tariff \nprovision puts LSEs on notice that their ongoing cost responsibility for RBP Charges will \ncontinue to follow them even if an LSE’s withdrawal is the result of the physical \nwithdrawal of entities other than an exiting Transmission Owner.  Thus, the proposed Tariff \nprovision is drafted broadly to provide assurances against stranded RBP Charges and cost \nshifts. \n \n98 RAA, Article 1, Definitions; Tariff, Part 1, Definitions – L-M-N. \n99 September 29 Order, 196 FERC ¶ 61,245 at PP 181-82."},{"page":36,"startToken":10489,"endToken":10782,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 35 \n \n2. \nThe modified proposal expressly recognizes that the specific terms \nand amounts owed in RBP Charges are subject to future filings with \nthe Commission.   \nIn response to PJM’s July 31 Filing, a number of protestors raised concerns that \nPJM’s previously proposed exit provisions were unnecessarily constraining.  The \nCommission, “disagree[d] with protesters that establishing exit provisions in the Tariff \nwould unnecessarily constrain the parties involved in effectuating a Transmission Owner’s \nwithdrawal from PJM.  As PJM states, the cost obligations will be ‘appropriately decided \nat the time of Transmission Owner’s exit and subject to Commission approval.’”100  As the \nCommission has previously recognized, “there are a number of steps involved in \nproceeding with an orderly withdrawal from [a Regional Transmission Organization \n(“RTO”)]” through “an orderly, phased-in sequence.”101 \nPJM is proposing to modify its Tariff provision to expressly state that RBP Charges \nassociated with a withdrawing LSE will be “subject to a rate filing with the Federal Energy \nRegulatory Commission that details the specific terms and amounts owed.”102  The \nmodified proposal clarifies an important point and adheres to the September 29 Order and \nCommission precedent and is therefore just and reasonable. \nFirst, like other exit provisions that the Commission has previously found to be just \nand reasonable, PJM’s proposal does not establish specific cost obligations arising from \nspecific circumstances surrounding a particular LSE’s withdrawal or prejudge any potential \n \n100 September 29 Order, 196 FERC ¶ 61,245 at P 180 (quoting PJM RBP Answer at 98). \n101 Duke Energy Ohio, Inc., 133 FERC ¶ 61,058, at P 133 (2010) (quoting Am. Transmission Sys., Inc. v. \nPJM Interconnection, L.L.C., 129 FERC ¶ 61,249, at P 29 (2009)). \n102 Proposed Tariff, Attachment DD, section 18.7."},{"page":37,"startToken":10782,"endToken":11066,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 36 \n \nsettlement agreements pertaining to cost responsibility.103  Under the proposed Tariff \nlanguage, LSEs will only be responsible for the remainder of RBP Charges allocated to it.  \nDepending on the specific circumstance of an LSE’s withdrawal, RBP Obligation MW and \nassociated RBP Charges may be subsequently allocated to other LSEs that have not \nwithdrawn from the PJM Region, in accordance with Tariff, Attachment DD, section \n18.3(b).     \nSecond, in accordance with the September 29 Order, PJM is proposing a Tariff \nprovision that “still leave[s] flexibility for LSEs”104 that have been allocated responsibility \nfor RBP Charges.  PJM agrees with the Commission that LSEs withdrawing from PJM \nshould retain the flexibility to enter into appropriate business arrangements to cover its \nallocated RBP Charges.  As the September 29 Order suggests, exiting LSEs may still have \nthe flexibility “to enter into agreements with RBP Resources (which they may need to serve \ntheir load) or pay to pseudo-tie RBP Resources located within the exiting Transmission \nOwner’s zone back into PJM.”105   \n3. \nThe modified proposal expressly preserves an LSE’s ability to seek \nredress under certain circumstances.   \nWhile the modified proposal requires exiting LSEs—rather than exiting \nTransmission Owners—to continue covering their allocated RBP Charges, PJM \nnevertheless recognizes that LSEs retain the flexibility to seek redress when another \nentity’s physical withdrawal from the PJM Region, such as a Transmission Owner’s, causes \n \n103 See, e.g., Midwest Indep. Transmission Sys. Operator, Inc., 133 FERC ¶ 61,221, at P 471 (2010), order \non reh’g, 137 FERC ¶ 61,074 (2011). \n104 September 29 Order, 196 FERC ¶ 61,245 at P 181. \n105 September 29 Order, 196 FERC ¶ 61,245 at P 181."},{"page":38,"startToken":11066,"endToken":11361,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 37 \n \nan LSE to also be withdrawn from PJM.  Therefore, PJM’s modified Tariff provision \nexpressly states that “[n]othing in this provision shall limit such Load Serving Entity’s \nability to seek redress from another entity to the extent the Load Serving Entity’s \nwithdrawal is caused by that other entity’s physical withdrawal from the PJM Region.”106  \nThe proposed language is just and reasonable and supported by Commission precedent.    \nFirst, as noted above, the proposed exit provision is drafted broadly to include, but \nnot be limited to, instances where a Transmission Owner’s physical withdrawal from the \nPJM Region causes LSEs to involuntarily withdraw from PJM.  The Commission has \nexpressly recognized that LSEs “may be required to associate with the same RTO as the \ntransmission owner” and thus could require the “involuntary withdrawal by other LSEs in \nthe [withdrawing transmission owner’s] zone.”107   \nWhen Transmission Owners have exited an RTO/Independent System Operator \n(“ISO”), LSEs that must involuntarily withdraw in order to associate with the same \nRTO/ISO as the exiting Transmission Owners have invariably challenged costs associated \nwith the Transmission Owners’ withdrawal from the RTO/ISO.108  The Commission has \npreviously found an exiting transmission owner’s proposal to recover costs from its \ncustomers to be unjust and unreasonable where the transmission owner has “not \nsufficiently shown that wholesale transmission customers would realize net benefits from \n \n106 Proposed Tariff, Attachment DD, section 18.7. \n107 Duquesne Light Co., 122 FERC ¶ 61,039 at P 130. \n108 See, e.g., PJM Interconnection, L.L.C., 151 FERC ¶ 61,029 (2015) (approving settlement between exiting \ntransmission owner and wholesale transmission customers excluding 100% of certain exit and integration \ncosts following Commission’s denial, without prejudice, of transmission owner’s request to recover such \ncosts)."},{"page":39,"startToken":11361,"endToken":11656,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 38 \n \nthe RTO realignment.”109  The proposed Tariff provision recognizes that LSEs retain the \nright to file for cost recovery or intervene, challenge, and protest cost assignments \nfollowing their involuntary withdrawal, including, but not limited to, by challenging the \nsubsequent rate filings before the Commission.   \nSecond, the proposed Tariff provision recognizes that the Commission has \npreviously upheld Tariff provisions that shift cost responsibility from transmission \ncustomers to their exiting transmission owners.  In FirstEnergy Service Co. v. Midwest \nIndependent Transmission System Operator, Inc., for example, the Commission upheld \nSchedule 39 of the Midwest Independent Transmission System Operator, Inc. (“MISO”) \nTariff, which held Transmission Owners exiting from MISO responsible for the costs of \nMulti-Value Project Charges, even though such charges are typically borne transmission \ncustomers.  Therein, the Commission “disagree[d] with parties’ assertions that Schedule 39 \nimproperly shifts responsibility from the transmission customers to the Withdrawing \nTransmission Owner.”110  As the Commission explained: \nThe transmission owner, not its transmission customers, makes the \ndecision to withdraw from MISO and, therefore, Attachment FF [of \nthe MISO Tariff] neither contemplates nor prescribes any financial \nobligations for transmission customers in the Withdrawing \nTransmission Owner’s zone.  Moreover, we disagree that MVP \ncharges cannot be part of a transmission owner’s exit fee obligation \nbecause, prior to a transmission owner’s withdrawal, MVP charges \nare assessed to transmission customers.  Attachment FF states . . . \nthat transmission owners, upon withdrawal, become responsible \nfor costs contemplated in Attachment FF.111 \n \n109 PJM Interconnection, L.L.C., 144 FERC ¶ 61,217, at P 22 (2013). \n110 FirstEnergy Serv. Co. v. Midwest Indep. Transmission Sys. Operator, Inc., 138 FERC ¶ 61,140, at P 65 \n(2012), order on initial decision & reh’g, 153 FERC ¶ 61,101 (2015). \n111 FirstEnergy, 138 FERC ¶ 61,140 at P 65."},{"page":40,"startToken":11656,"endToken":11972,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 39 \n \nSubsequently, the Commission expressly distinguished FirstEnergy from Duquesne, \nreasoning:   \nAlthough the Commission agreed that the allocation and usage-\nbased rate design of MISO’s MVPs are similar to the allocation and \nusage-based rate design of PJM’s 500 kV facilities at issue in \nDuquesne, which the Commission rejected as part of a PJM exit \nfee, the Commission found that MISO’s Tariff language is different \nthan PJM’s.  The Commission stated that Section III.A.2.j of \nAttachment FF of MISO’s Tariff explicitly obligates transmission \nowners withdrawing from MISO to pay costs incurred under \nAttachment FF, including MVP costs, whereas, in Duquesne, the \nCommission found that Schedule 12 of the PJM tariff lacked any \nlanguage to obligate transmission owners that withdraw from PJM \nto continue to pay for transmission facility additions rated 500 kV \nand above.  Because Attachment FF specified that transmission \nowners withdrawing from MISO are obligated to honor financial \nobligations associated with transmission facility additions incurred \nunder Attachment FF prior to withdrawal, the Commission found \nthat the Duquesne precedent was distinguishable.112 \nWhile PJM’s revised Tariff provision recognizes that a more legally durable solution \nfollows Commission precedent in Duquesne, PJM nevertheless proposes that its Tariff \nexpressly reserves the right of an LSE to seek redress from other entities whose decision \nto withdraw from PJM results in the withdrawal of the LSE.        \nIn recognition of the fact that, depending on the specific circumstances of the \nwithdrawal, LSEs may argue that costs typically borne by LSEs should become the \nresponsibility of the entity that initiated the physical withdrawal from the PJM Region, \nPJM is proposing revised Tariff language that expressly contemplates that LSEs may seek \nredress from the other such entity whose physical withdrawal from the PJM Region caused \nthe LSEs’ withdrawal from PJM.  While the provision is drafted broadly, PJM contemplates \n \n112 FirstEnergy, 153 FERC ¶ 61,101 at P 142."},{"page":41,"startToken":11972,"endToken":12247,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 40 \n \nthat the forms of redress that an LSE may seek may include recouperation of costs resulting \ndirectly from a Transmission Owner’s business decision to exit PJM.   \nIII. \nPROPOSED ADDITIONAL UPDATES TO THE ACCEPTED RBP RULES \nBeyond the proposed updates discussed above, PJM proposes additional limited \namendments to the Tariff that serves to further refine, clarify, and/or update the set of RBP \nrules as detailed below.   \nA. \nPJM Proposes to Amend the Opt-Out for LSEs that Are Not Regulated by \nStates. \nIn the July 31 Filing, PJM proposed a limited RBP opt-out applicable to certain \nElectric Distributors whose zone/area rates are not subject to state regulation.  The purpose \nof that provision was to address a narrow regulatory circumstance facing certain \ncooperative and municipal utility systems whose rates are not regulated by a state authority.  \nHowever, in the September 29 Order, the Commission found that the proposed opt-out for \nqualifying cooperatives and municipal utilities may be unjust, unreasonable, and unduly \ndiscriminatory because those entities may serve Large Loads that are similarly situated to \nLarge Loads served by other LSEs that would remain responsible for RBP Charges.113   \nTo address this concern, PJM proposes to revise Tariff, Attachment DD, section \n18.1(d) to eliminate the provision that permits an Electric Distributor that is not regulated \nby a RERRA to specify a quantity of load that will be opted out of the Initial RBP Target.  \nAs revised, the RBP framework will no longer provide an opt-out based on the regulatory \nstatus of an Electric Distributor’s zone/area. \n \n113 September 29 Order, 196 FERC ¶ 61,245 at P 152."},{"page":42,"startToken":12247,"endToken":12520,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 41 \n \nThis revision ensures that responsibility for RBP Charges is applied on a \ncomparable basis across all LSEs that serve Large Loads.  Accordingly, LSEs serving \nLarge Loads will remain responsible for RBP Charges regardless of whether the relevant \nElectric Distributor’s zone/area is regulated by a state.  By removing the previously \nproposed opt-out, the potential for disparate treatment among similarly situated Large \nLoads is eliminated and directly addresses the concern identified by the Commission in the \nSeptember 29 Order. \nB. \nPJM Proposes Updates to Modify the Opt-Out for a Peak Shaving \nAdjustment Program to Align with the RBP Offset. \nWhile PJM is maintaining the remaining opt-out for Electric Distributors that \naddress resource adequacy needs through Peak Shaving Adjustment programs established \npursuant to state law, PJM proposes a targeted modification to better align that opt-out with \nthe requirements applicable to Qualifying RBP Offset UCAP MW.  Specifically, PJM \nproposes to require that any MW quantity used to reduce the Initial RBP Target through \nthe Peak Shaving Adjustment opt-out be committed to participate in the applicable Peak \nShaving Adjustment program for a minimum term of five years.114  This requirement is \nconsistent with the existing requirement that Qualifying RBP Offset UCAP MW be \nsupported by a signed bilateral contract with a minimum term of five years in order to offset \nthe Initial RBP Target.115 \nThis proposed revision recognizes that Peak Shaving Adjustment MW and \nQualifying RBP Offset UCAP MW serve a similar function within the RBP framework. In \n \n114 See proposed Tariff, Attachment DD, section 18.1(d). \n115 See Tariff, Attachment DD, section 18.2(c)(i)."},{"page":43,"startToken":12520,"endToken":12755,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 42 \n \neach case, the MW quantity is used to reduce the Initial RBP Target and, therefore, reduce \nthe quantity of Capacity Resources that otherwise would be procured through the RBP \nconstruct. Although Peak Shaving Adjustment MW reflects a demand-side reduction rather \nthan the addition of a supply-side resource with an accredited UCAP value, both \nmechanisms reduce the amount of incremental capacity procurement that would otherwise \nbe necessary to address Large Load growth. \nBecause both mechanisms produce a comparable effect on the Initial RBP Target, \nthey should be subject to comparable durability requirements. The proposed five-year \nminimum participation requirement helps ensure that Peak Shaving Adjustment MW used \nto reduce the Initial RBP Target represents a meaningful and sustained contribution to \nresource adequacy rather than a temporary or transitory reduction in load. Absent such a \nrequirement, load could reduce the Initial RBP Target based on short-term participation in \na Peak Shaving Adjustment program without providing a commensurate long-term \ncontribution to meeting the resource adequacy needs that gave rise to the RBP \nprocurement. \nAccordingly, the proposed five-year minimum term promotes consistency across \nthe RBP framework by treating demand-side and supply-side offset mechanisms in a \ncomparable manner.  At the same time, the requirement remains sufficiently flexible to \naccommodate commercially reasonable arrangements while ensuring that any MW used to \nreduce the Initial RBP Target reflects a sustained commitment that supports resource \nadequacy objectives."},{"page":44,"startToken":12755,"endToken":13054,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 43 \n \nC. \nPJM Proposes to Update the Rules Related to the Cure Period for Any \nIdentified Deficiencies Associated with an RBP Sell Offer. \nUnder the RBP rules accepted by the Commission in the September 29 Order, each \nRBP Sell Offer must include the information and evidence necessary to demonstrate that \nthe proposed project qualifies as an RBP Resource.  Specifically, an RBP Sell Offer must \nbe accompanied by the applicable documentation and support required for the relevant \nresource type under Tariff, Attachment DD, section 18.5(f)(i).  Upon receipt of an RBP \nSell Offer, PJM reviews the submission on a pass/fail basis to determine whether the offer \nincludes the required information and supporting evidence.  If PJM identifies missing \ndocumentation or other deficiencies, PJM will notify the RBP Seller and provide an \nopportunity to cure the identified deficiencies before the offer is rejected.116  In the event \nPJM identifies missing documentation or other evidence in an RBP Sell Offer, an RBP \nSeller has five calendar days, or until the close of the RBP offer submission window, \nwhichever occurs first, to cure any deficiencies identified by PJM.117 \nUpon further review, PJM has determined that this provision may not provide all \nRBP Sellers a meaningful and consistent opportunity to cure deficiencies.  In particular, \nshould a significant number of RBP Sell Offers be submitted towards the end of the RBP \noffer submission window, PJM may not be able to complete its review of every offer and \nissue any necessary deficiency notices prior to the expiration of the submission window.  \nAs a result, the amount of time available to cure a deficiency could vary based solely on \n \n116 Tariff, Attachment DD, section 18.5(f)(i). \n117 Tariff, Attachment DD, section 18.5(f)(i)."},{"page":45,"startToken":13054,"endToken":13352,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 44 \n \nthe timing of PJM’s review rather than the nature of the deficiency or the merits of the \nunderlying project. \nTo address this concern, PJM proposes a narrow modification to the cure process.  \nUnder the proposed revision, an RBP Seller will have five calendar days from receipt of a \ndeficiency notice to cure any deficiencies identified by PJM, even if the cure period extends \nbeyond the close of the RBP offer submission window.  This change does not alter the \nsubstantive requirements applicable to RBP Sell Offers, nor does it modify PJM’s \nevaluation criteria.  Rather, it allows all RBP Sellers to receive the same cure opportunity \nonce PJM has identified a deficiency.  In addition, this revision enhances the fairness and \nadministrability of the RBP qualification process by ensuring that an RBP Seller is not \ndenied a cure opportunity solely because PJM’s review occurs near the end of the \nsubmission window.  The proposed revision also improves the likelihood that potentially \nqualifying RBP Resources will be evaluated on their merits rather than excluded due to \ntiming constraints associated with the review process. \nImportantly, PJM does not expect this change to encourage late submissions.  RBP \nSell Offers will continue to be reviewed on a rolling basis throughout the submission \nwindow, and PJM anticipates that sellers submitting offers earlier in the process may have \ngreater opportunities to respond to informal requests for clarification or supplemental \ninformation before PJM issues a formal deficiency notice.  By contrast, sellers submitting \noffers closer to the close of the submission window may have fewer opportunities for \ninformal engagement prior to the commencement of the formal cure process.  Accordingly, \nRBP Sellers will continue to have a strong incentive to submit complete RBP Sell Offers \nas early as practicable during the submission window."},{"page":46,"startToken":13352,"endToken":13616,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 45 \n \nTo effectuate this update, PJM proposes to modify Tariff, Attachment DD, \nsection 18.5(f)(i), as shown in blackline below: \nRBP Sell Offers that do not include the following information shall \nnot proceed to selection assessment, provided, however, that the \nOffice of the Interconnection shall provide the RBP Seller the \nopportunity to cure any identified deficiencies within five (5) \ncalendar days of being notified by PJM. Notwithstanding, such \nopportunity to cure shall not extend past the close of the bid \nsubmission window of the Reliability Backstop Procurement. \nD. \nPJM Proposes Clarifications Related to Qualifying RBP Offset UCAP \nMW. \nIn the July 31 Filing, PJM explained that it is just and reasonable to reduce the \nInitial RBP Target to reflect qualifying new capacity procured outside of the RBP construct \n(“Qualifying RBP Offset UCAP MW”).  Qualifying RBP Offset UCAP MW recognizes \nbilateral arrangements that help address the resource adequacy need associated with Large \nLoad growth while furthering PJM’s preference for encouraging voluntary procurement of \nnew capacity through bilateral contracting rather than through mandatory RBP \nprocurement.  As the Commission previously accepted, the universe of resources eligible \nto qualify as Qualifying RBP Offset UCAP MW includes new generation, Energy Storage \nResources, Planned Demand Resources, and Planned DER Capacity Aggregation \nResources.118 \nIt remains just and reasonable to permit Electric Distributors to report Qualifying \nRBP Offset UCAP MW for purposes of decrementing the Initial RBP Target.  Through \nthis filing, PJM clarifies that any such resource must be physically located within the PJM \n \n118 Tariff, Attachment DD, section 18.2(b)."},{"page":47,"startToken":13616,"endToken":13970,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 46 \n \nRegion.119  Additionally, given that the RBP is now anticipated to commence on March 1, \n2027, PJM is clarifying that capacity that may be committed in the Third Incremental \nAuction associated with the 2027/2028 Delivery Year will remain eligible as Qualifying \nRBP Offset UCAP MW (as well as to maintain eligibility as an RBP Resource).120  This is \nappropriate given that the deadline to submit the binding notice of intent to offer into the \nThird Incremental Auction associated with the 2027/2028 Delivery Year will be before an \norder on this filing is expected.121  This will avoid a scenario where a Planned Generation \nCapacity Resource may not be offered into the 2027/2028 Third Incremental Auction to \npreserve eligibility to be either offered as an RBP Resource or used as a Qualifying RBP \nOffset UCAP MW. \nIn addition, PJM is updating the language in Tariff, Attachment DD, section 18.2(e) \nto conform with the revised approach of requiring Electric Distributors to report the MW \nquantity of Large Load.  Specifically, PJM proposes to amend this section to state that the \ntotal quantity of Qualifying RBP Offset UCAP MW that can be used to decrement the \nInitial RBP Target “will be capped by the aggregate MW quantity of Large Load reported \nby each Electric Distributor, as reported in accordance with Tariff, Attachment DD, section \n18.3(a)(2), and the total MW quantity that is subject to the RBP opt-out, as requested in \naccordance with Tariff, Attachment DD, section 18.1(d), for the relevant zone/area.”122  \nConsistent with this clarification, PJM is also specifying that the Qualifying RBP Offset \n \n119 Proposed Tariff, Attachment DD, section 18.2(a). \n120 Proposed Tariff, Attachment DD, section 18.2(a); proposed Tariff, Attachment DD, section 18.5(a)(ii); \nproposed Tariff, Part 1, Definitions – O-P-Q, Qualifying RBP Offset UCAP MW. \n121 Specifically, the current deadline for the notice of intent to offer into the Third Incremental Auction for \nthe 20287/2028 Delivery Year is November 26, 2026. \n122 Proposed Tariff, Attachment DD, section 18.2(e)."},{"page":48,"startToken":13970,"endToken":14255,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 47 \n \nUCAP MW must be the subject of a bilateral agreement with a Large Load and up to the \ncapacity obligation of such Large Load.123  This way, the Qualifying RBP Offset UCAP \nMW will not be higher than the quantity of Large Load that the RBP is designed to procure \nfor the 2028/2029 Delivery Year. \nFurther, PJM is clarifying through this filing that Planned Demand Resource or \nPlanned DER Capacity Aggregation Resource used as Qualifying RBP Offset UCAP MW \nmust satisfy certain eligibility requirements that also apply to those resource types when \nqualifying as RBP Resources.  Specifically, such resources must “[n]ot be reliant on or \ncomposed of registered location(s) that previously supported a Demand Resource that \nprovided capacity in the 2026/2027 Delivery Year unless such location represents an \nincremental increase in capacity resulting from an investment in new generation or new \nstorage resources at that location.”124  In addition, such resources must be supported by a \nsigned commitment between the Curtailment Service Provider or DER Aggregator \nidentifying the end-use customers that will support such commitment in an amount equal \nto the MW quantity relied upon as the offset.125 \nThese requirements provide reasonable assurances that Planned Demand Resources \nand Planned DER Capacity Aggregation Resources used to reduce the Initial RBP Target \nrepresent genuinely incremental capacity additions rather than the repackaging of existing \ndemand-side capability that has already contributed to PJM’s resource adequacy \nrequirements.  Because the purpose of the Qualifying RBP Offset UCAP MW mechanism \n \n123 Proposed Tariff, Attachment DD, section 18.2(c). \n124 See proposed Tariff, Attachment DD, section 18.5(c)(i). \n125 Tariff, Attachment DD, section 18.2(c)(iii)."},{"page":49,"startToken":14255,"endToken":14525,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 48 \n \nis to recognize new capacity that mitigates the reliability needs otherwise addressed \nthrough the RBP construct, it is appropriate to require evidence demonstrating that the \nspecific end-use customer locations represent new capability and is directly associated with \nthe new loads responsible for the incremental resource adequacy need.  At the same time, \nthese requirements do not need to be so restrictive that any previously registered end-use \nlocation prior to the 2026/2027 Delivery Year would be foreclosed from being eligible to \nbe registered in support of a Demand Resource that is either offered as an RBP Resource \nor reported as Qualifying RBP Offset UCAP MW.  Such locations are not currently \nsupporting Capacity Resources, and therefore any capacity capability they can provide \nshould be deemed new capacity on the system. \nPJM also proposes to clarify that Planned Demand Resources and Planned DER \nCapacity Aggregation Resources used as Qualifying RBP Offset UCAP MW must identify \nthe specific locations that will support the offset.  This requirement is necessary to verify \nthat the claimed MW quantity is associated with identifiable new load and represents \nincremental capacity that did not previously contribute to PJM's resource adequacy needs.  \nThe Commission expressly recognized concerns that Demand Resources and DER \nAggregation Resources may face challenges in identifying customer locations sufficiently \nfar in advance in the context of qualifying as an RBP Resource, but nonetheless found it \nreasonable to require identification of the specific locations supporting such resources.126  \nRequiring location-specific information in the offset context is likewise appropriate and is \n \n126 September 29 Order, 196 FERC ¶ 61,245 at P 50."},{"page":50,"startToken":14525,"endToken":14807,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 49 \n \nconsistent with the comparable identification requirements applicable to generation \nresources proposed as Qualifying RBP Offset UCAP MW.127 \nAt the same time, while Planned Demand Resources and Planned DER Capacity \nAggregation Resources used as Qualifying RBP Offset UCAP MW must satisfy the \neligibility requirements necessary to demonstrate that the resources are new, incremental, \nand directly tied to the underlying Large Load, PJM does not require those resources to \nprovide all of the documentation necessary to qualify as an RBP Resource.  Specifically, \nthe submission of the specific end-use customer contracts that would otherwise be required \nfor participation as an RBP Resource would not be required.  This tailored approach \nappropriately balances the need to ensure that offset MW represent genuine new capacity \nagainst the recognition that Qualifying RBP Offset UCAP MW are not themselves seeking \nRBP commitments or compensation.  As a result, the proposal provides sufficient \nassurance that any MW used to reduce the Final RBP Target reflects real and incremental \ncapacity additions while avoiding unnecessarily burdensome qualification requirements. \nFinally, PJM is proposing to correct a typographical error in proposed Tariff, \nAttachment DD, section 18.5(d).  Specifically, the Tariff provision states: \nTo qualify as a DER Capacity Aggregation Resource that supplies \nRBP UCAP MW eligible to be offered into the Reliability Backstop \nProcurement, a Planned DER Capacity Aggregation Resource must \nmeet \nthe \nrequirements \nof \nTariff, \nAttachment \nDD, \nsections 18.5(b) . . . .128 \nSection 18.5(b) establishes the requirements applicable to “Generation or Energy \nStorage Resources as an RBP Resources” and was not intended to apply to DER Capacity \n \n127 Tariff, Attachment DD, section 18.2(c). \n128 Tariff, Attachment DD, section 18.5(d)."},{"page":51,"startToken":14807,"endToken":15088,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 50 \n \nAggregation Resources.  Rather, PJM intended to reference section 18.5(a), which sets \nforth the general eligibility requirements applicable to all resources supporting RBP UCAP \nMW and is titled “RBP Seller Eligibility to Participate and General Requirements for \nResources Supporting RBP UCAP MW.”  Accordingly, this filing corrects Tariff, \nAttachment DD, section 18.5(d) by replacing the reference to “section 18.5(b)” with \n“section 18.5(a).”129 \nE. \nPJM Proposes to Update Site Control Requirements. \nIn the July 31 Filing, PJM proposed an RBP gating criteria designed to limit \nparticipation to resources with a high likelihood of achieving commercial operation to deter \nspeculative offers.  As relevant here, generation and storage resources seeking to \nparticipate in the RBP must demonstrate, among other things, evidence of 100% Site \nControl “for a term of at least three years from the date of submission of the \nApplication.”130  In Docket No. ER26-3380-000, PJM responded to comments submitted \nby CPV Power Holdings, LP (“CPV”) and acknowledged certain concerns regarding the \nproposed Site Control requirements.131  In the September 29 Order, the Commission \nrecognized “PJM’s openness to adopt CPV’s suggested redlines to proposed Tariff, \nAttachment DD, section 18.5(f)(i)(2)” and stated that PJM could incorporate revisions to \nthat provision through this filing.132 \n \n129 Proposed Tariff, Attachment DD, section 18.5(d). \n130 Tariff, Attachment DD, section 18.5(f)(i)(2). \n131 See PJM RBP Answer at 10, 44-46; PJM Interconnection, L.L.C., Motion to Intervene and Comments of \nCPV Power Holdings, LP, Docket No. ER26-3380-000, at 4-5 (Aug. 21, 2026).  \n132 September 29 Order, 196 FERC ¶ 61,245 at P 78."},{"page":52,"startToken":15088,"endToken":15365,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 51 \n \nIn particular, PJM recognizes that the reference to “Application” in Tariff, \nAttachment DD, section 18.5(f)(i)(2) may create ambiguity in the context of the RBP.  That \nis, the term “Application” is generally associated with the submission of a project into \nPJM’s interconnection queue and does not clearly identify the relevant point in time for \npurposes of the RBP Site Control requirement.  Accordingly, PJM proposes to clarify that \nthe three-year Site Control requirement is measured from the date of submission of the \nRBP Sell Offer. \nPJM also proposes to revise the Site Control requirement to avoid imposing \nduplicative obligations on projects that are already being studied, or have already \ncompleted the relevant studies, as part of PJM’s interconnection process.  Such projects \nare already required to satisfy the applicable Site Control requirements as a condition of \nprogressing through the interconnection queue.  Requiring those projects to separately \ndemonstrate an additional three-year minimum term of Site Control for RBP participation \ncould unnecessarily exclude otherwise viable resources that have a high likelihood of \nreaching commercial operation. \nTherefore, PJM proposes to revise Tariff, Attachment DD, section 18.5(f)(i)(2) so \nthat only projects that are not currently undergoing, and have not previously completed, an \ninterconnection study in PJM’s interconnection process must provide evidence of 100% \nSite Control, consistent with the requirements set forth in Tariff, Part VIII, Subpart A, \nsection 402, for a term of at least three years from the submission of the RBP Sell Offer.  \nFor the same reason, only those projects would be required to provide an officer \ncertification demonstrating compliance with the applicable Site Control requirements."},{"page":53,"startToken":15365,"endToken":15682,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 52 \n \nBased on the foregoing, PJM proposes to amend Tariff, Attachment DD, \nsection 18.5(f)(i)(2), as shown in blackline below: \n(2) For projects that are not the subject of a completed \ninterconnection study or are not currently under study as part of an \nactive New Service Request by the Office of the Interconnection, \nEevidence of 100% Site Control consistent with Tariff, Part VIII, \nSubpart A, section 402 for each of the Generating Facility (including \nthe location of the main step-up transformer), the Interconnection \nFacilities, and the Interconnection Switchyard (as defined in the \nPJM Manuals) for a term of at least three years from the date of \nsubmission of the ApplicationRBP Sell Offer.  \n \nIn addition,Such projects must also be accompanied by a \ncertification, executed by an officer or authorized representative of \nthe Generation Project Developer, verifying that the Site Control \nrequirements have been met.  Further, at Transmission Provider’s \nrequest, Generation Project Developer shall provide copies of \nlandowner attestations or county recordings.  The Site Control \nrequirements include an acreage requirement for the Project, as set \nforth in the PJM Manuals.  \n \nEvidence of site control shall be consistent with Tariff, Part VIII, \nSubpart A, section 402; \n \nF. \nPJM Proposes to Utilize the Most Updated Resource Forecast and \nResource Mix. \nGiven that the September 29 Order suspended the RBP rules for five months to \nbecome effective February 28, 2027, PJM now anticipates commencing the RBP on \nMarch 1, 2027.  As part of the September 29 Order, the Commission indicated that “PJM \nshould employ the most up-to-date load and resource forecasts to inform the Initial RBP \nTarget” when PJM conducts the RBP.133  \nConsistent with the Commission’s guidance, PJM proposes to update the Initial \nRBP Target using the most current data available at the time of the RBP.  As initially \n \n133 September 29 Order, 196 FERC ¶ 61,245 at P 159."},{"page":54,"startToken":15682,"endToken":15972,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 53 \n \nproposed, the Initial RBP Target will continue to be determined as the difference between \nthe PJM Region Reliability Requirement for the 2028/2029 Delivery Year and the total \nquantity of Capacity Resources that cleared the 2028/2029 Base Residual Auction.  \nHowever, rather than relying on the forecasts and accreditation values available at the time \nof the July 31 Filing, PJM will utilize the most recent load forecast and capacity \naccreditation information available immediately prior to the commencement of the RBP. \nSpecifically, PJM will use the latest PJM Region Reliability Requirement for the \n2028/2029 Delivery Year, which will reflect the latest load forecast for the 2028/2029 \nDelivery Year that is scheduled to be finalized and published on or before February 1, \n2027.134  Likewise, PJM will also recalculate the UCAP equivalent of the ICAP quantity \nof Capacity Resources that cleared in the 2028/2029 Base Residual Auction using the \ncapacity accreditation factors for the 2028/2029 Delivery Year that are scheduled to be \nfinalized in February 2027.   \nThese updates will produce an Initial RBP Target that reflects the most current load \nand resource assumptions available when the RBP is conducted and, therefore, more \naccurately measures the UCAP MW capacity shortfall for the 2028/2029 Delivery Year \nthat the RBP is intended to address.   \nFurther, as a preventative measure so that a zone/area is not allocated costs beyond \nits respective Large Load demand, PJM is proposing to update the Initial RBP Target to \nequal the lesser of the calculated value of the 2028/2029 Delivery Year shortage and the \nregion-wide total of Large Load MW reported to PJM by Electric Distributors.  This \n \n134 See Tariff, Attachment DD, section 5.10(d)."},{"page":55,"startToken":15972,"endToken":16325,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 54 \n \napproach prevents zone/areas from being assessed a greater share of the capacity shortfall \nthan its expected Large Load growth.  As PJM’s senior manager of market design, Ms. \nCroop explains, this approach “provides an important safeguard by accounting for the \npossibility that previously reported Large Load agreements may be canceled between the \ncollection of data for the 2027 Load Forecast and the establishment of the RBP.”135  In \nother words, capping the Initial RBP Target at the Large Load MW quantity that is reported \nby Electric Distributors will ensure that RBP costs do not exceed the Large Load growth \nreported for the applicable zone/area to align with the principles of cost causation and \nbeneficiary pays.136  \nTo effectuate this update, PJM proposes discrete updates to Tariff, Attachment DD, \nsection 18.1(a), as shown below: \nThe Initial RBP Target shall be a region-wide value equal to the \nlesser of the (1) most up to date UCAP MW quantity that PJM \ncleared short of the PJM Region Reliability Requirement for the \n2028/2029 Delivery Year Base Residual Auction or (2) the UCAP \nequivalent of the aggregate region-wide Large Load MW quantity \nreported by the Electric Distributor in accordance with Tariff, \nAttachment DD, section 18.3A. Specifically, the Initial RBP Target \nshall equal the lesser of ([the latest estimate of the PJM Region \nReliability Requirement for the 2028/2029 Delivery Year, \ncalculated as the RTO Region Peak Load Forecast for the \n2028/2029 Delivery Year from the 2027 Load Forecast times the \n2028/2029 Forecast Pool Requirement from the updated planning \nparameters available at the commencement of the RBP, less the \nsum of all updated Unforced Capacity Obligations of FRR Entities \nin the PJM Region] minus [the UCAP-equivalent of the ICAP \nquantity of Capacity Resources that cleared in the 2028/2029 Base \nResidual Auction using the latest capacity accreditation factors for \nthe 2028/2029 Delivery Year available at the commencement of the \nRBP], the aggregate region-wide Large Load MW reported by the \nElectric Distributor in accordance with Tariff, Attachment DD, \n \n135 Croop Aff. ¶ 6. \n136 Id."},{"page":56,"startToken":16325,"endToken":16575,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 55 \n \nsection 18.3A times the most recent 2028/2029 Forecast Pool \nRequirement).  \n \nAlthough PJM considered using the 2029/2030 Delivery Year to establish the \nInitial RBP Target, PJM determined that doing so could drive additional market \nuncertainty.  Utilizing the shortfall from the 2028/2029 Base Residual Auction is consistent \nwith the underlying intent of the RBP to address the nearer-term reliability need while \nallowing market fundamentals to address the longer-term resource adequacy.137  Indeed, \nPJM has already initiated its Powering Reliability Through Market Design initiative with \nstakeholders to pursue longer-term market design reforms aimed at improving investment \nand retention signals to support resource adequacy. \nMore fundamentally, the RBP was developed to address the capacity shortfall \nidentified for the 2028/2029 Delivery Year.  The RBP’s procurement target, eligibility \nrequirements, timelines, and other design elements were all established with that shortfall \nin mind.  If PJM were to instead base the Initial RBP Target on the results of the 2029/2030 \nBase Residual Auction, PJM would need to reevaluate and potentially modify numerous \naspects of the RBP construct to align with a different procurement need many of which \nmarket participants have already prepared for or made decisions around.  Moreover, \nmaintaining the existing design promotes certainty, preserves stakeholder expectations, \nand avoids unnecessary disruption to the market.138  Accordingly, PJM proposes to retain \nthe 2028/2029 Delivery Year as the basis for the Initial RBP Target while updating the \n \n137 Croop Aff. ¶ 7. \n138 Croop Aff. ¶ 8."},{"page":57,"startToken":16575,"endToken":16892,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 56 \n \nunderlying load and resource inputs to reflect the most current information available when \nthe RBP is conducted. \nG. \nPJM Proposes to Update Must-Offer and Binding Notice of Intent Rules \nfor Committed RBP Resources. \nAs PJM originally proposed, and the Commission accepted, a committed RBP \nResource must offer its available capacity, up to the total quantity of committed RBP \nUCAP MW, into the RPM Auctions as a price taker, i.e., $0/MW-day UCAP, beginning \nwith the first RPM Auction following the RBP commitment, for the applicable offered \nDelivery Year in which the term of the committed RBP UCAP MW begins and continuing \neach subsequent Delivery Year through the end of the fixed, 15-year term.139  PJM is not \nproposing any changes to the overall framework of this requirement in this filing.  \nHowever, given that the RBP is now anticipated to commence on March 1, 2027, with final \ncommitments awarded in early May 2027, PJM is updating rules pertaining to when a RBP \nResource must first be offered into the RPM Auctions and the associated rules pertaining \nto the binding notice of intent.  Specifically, PJM is making clear that any committed RBP \nResource will be required to be offered into the RPM Auction associated with the first \nDelivery Year that such resource has an RBP commitment and is expected to be in \nservice.140  That must offer obligation, regardless of resource type, will continue through \nthe end of the term of the RBP commitment. \nThe only exception to this general rule is that if an RBP Resource has a commitment \nbeginning with the 2030/2031 Delivery Year and is not the subject of a notice of intent to \n \n139 Tariff, Attachment DD, section 18.6(a). \n140 Proposed Tariff, Attachment DD, section 18.6(a); proposed Tariff, Attachment DD, section 6.6(j); Tariff, \nAttachment DD, section 6.6A(e)."},{"page":58,"startToken":16892,"endToken":17247,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 57 \n \nbe offered into the Base Residual Auction for the 2030/2031 Delivery Year, such \ncommitted RBP Resource would be required to be offered into the next RPM Auction to \nthe extent such resource has an RBP commitment and is expected to be in service for the \nrelevant Delivery Year.141  This limited exception is necessary because a Planned \nGeneration Capacity Resource that is not the subject of a notice of intent to offer would \nnot have been included in the planning parameters for the 2030/2031 Base Residual \nAuction.  For future auctions, committed RBP Resources would not be required to submit \nbinding notices of intent to offer because PJM will know which resources have an RBP \ncommitment and automatically include those resources in the planning models for the \nrelevant Delivery Years.142 \nIV. \nREQUEST \nFOR \nWAIVER \nOF \nTARIFF, \nATTACHMENT \nDD, \nSECTIONS 16.2 AND 16.3 \nUnder the Tariff provisions approved in the September 29 Order, a Reliability \nBackstop Auction is triggered if, for three consecutive Delivery Years, the Base Residual \nAuction “equates to an installed reserve margin that is more than one percentage point \nlower than the approved PJM Region Installed Reserve Margin.”143  The Base Residual \nAuctions for the 2027/2028 and 2028/2029 Delivery Years resulted in an installed reserve \nmargin that was more than one percentage point lower than the approved PJM Region \nInstalled Reserve Margin.144  The Base Residual Auction associated with the 2029/2030 \n \n141 Proposed Tariff, Attachment DD, section 18.6(a); proposed Tariff, Attachment DD, section 6.6(j); \nproposed Tariff, Attachment DD, section 6.6A(e); Tariff, Attachment DD, section 5.5(b). \n142 See proposed Tariff, Attachment DD, section 5.5(b) \n143 Tariff, Attachment DD, section 16.2. \n144 See 2027/2028 Base Residual Auction Reserve Target Shortfall Report, PJM Interconnection, L.L.C., 1 \n(Feb. 9, 2026), https://www.pjm.com/-/media/DotCom/markets-ops/rpm/rpm-auction-info/2027-2028/2027-\n2028-bra-reserve-target-shortfall-report.pdf [https://perma.cc/TA3Y-95AX] (“2027/2028 BRA Report”) \n(“PJM Interconnection cleared the 2027/2028 Base Residual Auction with a reserve margin that is more than"},{"page":59,"startToken":17247,"endToken":17606,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 58 \n \nDelivery Year could potentially clear short as well.  Should that occur, the current Tariff \nwould require PJM to “declare a capacity shortage and make a filing with FERC for \napproval to conduct a Reliability Backstop Auction.”145  Additionally, the Tariff also calls \nfor PJM to “investigate the cause for clearing short of the reliability requirement and to \nrecommend corrective action.”146 \nBecause the RBP effectively fulfills the same purpose as the Reliability Backstop \nAuction called for in Tariff, Attachment DD, section 16, in the July 31 Filing, PJM \nproposed to reset the timeframe for triggering a Reliability Backstop Auction and the \ninvestigation into the triggering shortfalls to the restart “with the 2032/2033 Delivery Year \nand thereafter.”147  The September 29 Order accepted and suspended this change effective \nFebruary 28, 2027.148 \nGiven that these accepted revisions do not become effective until February 28, \n2027, to the extent the 2029/2030 Base Residual Auction, held in December 2026, clears \nshort of the reliability requirement, the currently effective Tariff would require PJM to \n“investigate the cause for the shortage, and recommend corrective action,”149 but such \ninvestigation would then cease once the accepted tariff records become effective.  Because \n \none percentage point below the Installed Reserve Margin target, and with total Unforced Capacity of all Base \nLoad Generation Resources less than the forecasted minimum hourly load.  This confirmed shortfall \nconstitutes a triggering event as defined in the PJM Tariff, mandating an investigation to determine the root \ncauses of the region’s failure to secure sufficient resource adequacy.”); 2028/2029 Base Residual Auction \nReserve Target Shortfall Report, PJM Interconnection, L.L.C., 3 (July 14, 2026), https://www.pjm.com/-\n/media/DotCom/markets-ops/rpm/rpm-auction-info/2028-2029/2028-2029-reliability-backstop-baseload-\ngeneration-check.pdf (“2028/2029 BRA Report”). \n145 Tariff, Attachment DD, sections 16.3(a)(i)-(ii). \n146 Tariff, Attachment DD, section 16.2. \n147 July 31 Filing, Attachment B at proposed Tariff, Attachment DD, sections 16.2, 16.3(a)(i)-(ii). \n148 See September 29 Order, 196 FERC ¶ 61,245 at P 1 n.3 & Appendix A; ordering para. (A). \n149 Tariff, Attachment DD, section 16.2."},{"page":60,"startToken":17606,"endToken":17892,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 59 \n \nthe RBP is designed to address the shortfall and to avoid an unnecessary expense of \nresources, PJM requests waiver of the obligation in Tariff, Attachment DD, section 16.2 to \nperform such investigation.   \nThe Commission will grant waiver of tariff provisions where:  (1) the applicant \nacted in good faith; (2) the waiver is of limited scope; (3) the waiver addresses a concrete \nproblem; and (4) the waiver does not have undesirable consequences, such as harm to third \nparties.150  This one-time prospective waiver satisfies all four of the Commission’s waiver \ncriteria.   \nFirst, the waiver request is being submitted in good faith.  As noted above, such \ninvestigation is unnecessary and would needlessly expend scarce resources.  PJM has \nalready issued two reports detailing the causes of the shortfall from the 2027/2028 and \n2028/2029 Base Residual Auctions.151  Given that many of the same supply constraints and \nload growth remains for the 2029/2030 Delivery Year, it is unlikely that further \ninvestigation will discover different reasons for the current resource adequacy position.  \nAdditionally, this FPA section 205 filing proposes to commence the RBP on March 1, \n2027, which is designed as a stop-gap measure to address the expected resource adequacy \nshortfall that would be duplicative of a Reliability Backstop Auction.  Moreover, PJM is \nalready actively engaged with stakeholders through its “Powering Reliability Through \n \n150 PJM Interconnection, L.L.C., 191 FERC ¶ 61,202, at P 14 (2025) (citing waiver standards and allowing \ntariff waiver to implement equitable relief in light of certain tariff provisions); see Midcontinent Indep. Sys. \nOperator, Inc., 154 FERC ¶ 61,059, at P 13 (2016) (same). \n151 See 2027/2028 BRA Report; 2028/2029 BRA Report."},{"page":61,"startToken":17892,"endToken":18200,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 60 \n \nMarkets” discussions designed to formulate updated market rules that will more efficiently \nand effectively provide resource adequacy for the PJM Region.152   \nSecond, the waiver request is of limited scope.  PJM seeks a one-time waiver of \nTariff, Attachment DD, sections 16.2 and 16.3 upon completion of the 2029/2030 Base \nResidual Auction in the event such auction clears short.  Third, the waiver request \naddresses a concrete problem—the obligation to conduct an investigation into the cause of \nthe shortage and recommend corrective actions.  As noted, this is appropriate given that \nPJM will already be conducting the RBP on March 1, 2027, and conducting a Reliability \nBackstop Auction right after the RBP is not necessary.  Further, another investigation will \nlikely yield the same conclusions as the two recent reports.  Fourth, granting the waiver \nrequest will not have undesirable consequences, such as harm to third parties.  There is no \nneed to conduct such investigation or to recommend corrective measures.  PJM is already \ngoing to hold the RBP to procure new capacity. \nIn short, the waiver request satisfies all four elements for waiver of the Tariff, and \nPJM asks that the Commission grant the waiver request.   \nV. \nSTAKEHOLDER CONSULTATION \nAs required by Tariff, section 9.2(b), PJM consulted the Members Committee and \nthe Transmission Owners on October 22, 2026, seven days prior to submitting this filing.153  \nIn addition, PJM also consulted with the Transmission Owners on October 22, 2026, in \n \n152 Powering Reliability Through Market Design Workshops, PJM Interconnection, L.L.C., \nhttps://www.pjm.com/committees-and-groups/workshops/prtmdw \n[https://perma.cc/6K9W-YRL8] \n(last \nvisited Oct. 28, 2026). \n153 \nSpecial \nMembers \nCommittee, \nAgenda, \nPJM \nInterconnection, \nL.L.C. \n(Oct. \n22, \n2026), \nhttps://www.pjm.com/-/media/DotCom/committees-groups/committees/mc/2026/20261022-\nspecial/agenda.pdf [https://perma.cc/4F23-H5QB]."},{"page":62,"startToken":18200,"endToken":18500,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 61 \n \naccordance with the Consolidated Transmission Owners Agreement, section 7.5.1(ii).154  \nThis filing includes feedback and suggestions from stakeholders during that consultation \nthat PJM found meritorious.   \nVI. \nPROPOSED EFFECTIVE DATES AND UPDATED RBP TIMING \nAs noted above, PJM now anticipates commencing the RBP on March 1, 2027, \nprovided the Commission accepts the Tariff revisions proposed herein.  This \ncommencement date aligns with the Commission’s determination to suspend the RBP rules \nuntil February 28, 2027, as March 1, 2027, is the first business day on which those rules, \nas revised in this filing, would be effective.  PJM considered whether the RBP could \ncommence earlier than March 1, 2027.  However, an earlier commencement would not \nprovide sufficient time to incorporate the most current load forecast and capacity \naccreditation factors, each of which is expected to become available in or around February \n2027 and is necessary to calculate an updated Initial RBP Target.  Commencing the RBP \non March 1, 2027, therefore provides PJM with the opportunity to employ the most current \ndata available while remaining consistent with the Commission’s established effective date \nfor the RBP framework. \nIn addition, PJM is proposing to extend the RBP Sell Offer window by one week \nso that it will be open for a total of four weeks.155  One additional week of the offer window \nwill allow PJM to commence the RBP on March 1, 2027, while providing developers of \nprojects in PJM’s cycle 01 interconnection the opportunity to view the study results from \n \n154 Transmission Owners Agreement-Administrative Committee, PJM TOA-AC Open-Session, Special \nSession \nAgenda, \nPJM \nInterconnection, \nL.L.C. \n(Oct. \n22, \n2026), \nhttps://www.pjm.com/-\n/media/DotCom/committees-groups/committees/toa-ac/2026/20261022/20261022-agenda.pdf \n[https://perma.cc/XEK9-UE59].  \n155 Proposed Tariff, Attachment DD, section 18.4."},{"page":63,"startToken":18500,"endToken":18806,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 62 \n \nphase 1 of the interconnection cycle study, which is currently scheduled to be posted by \nMarch 26, 2027.156  Relatedly, PJM is specifying that if the most current PJM study is \navailable, such study may be used in lieu of an independent consultant report that details \nthe study information and project timeline to support the expected commercial operation \ndate of an RBP Resource.157 \nFurther, given that, as discussed in Part II.A, PJM is proposing a new Tariff, \nAttachment DD, section 18.3A to require for Electric Distributors to report Large Load \nMW quantities to PJM no later than seven days prior to the commencement of the RBP.  \nAn effective date earlier than February 28, 2027, is necessary to afford Electric Distributors \ntime to review the Commission’s order, understand the requirement, gather the requisite \ninformation, and report it to PJM.  Accordingly, PJM is proposing a January 29, 2027 \neffective date for proposed Tariff, Attachment DD, section 18.3A.  However, the \nCommission should not feel constrained to wait until January 29, 2027, to issue an order \non the proposed RBP rules, but should feel free to issue an order whenever it feels \nappropriate before January 29, 2027. \nFinally, PJM respectfully requests that the Commission issue an order on all aspects \nof this filing no later than January 29, 2027.  A Commission order by that date would \nprovide PJM and market participants with sufficient certainty regarding the applicable RBP \nrules and facilitate orderly administration of the RBP beginning on March 1, 2027.  \nAccordingly, while PJM requests an effective date of February 28, 2027, for most of the \n \n156 \nSee \nCycle \nTimeline, \nPJM \nInterconnection, \nL.L.C., \nhttps://www.pjm.com/planning \n[https://perma.cc/AL65-9ALQ] (last visited Oct. 28, 2026). \n157 Proposed Tariff, Attachment DD, section 18.5(f)."},{"page":64,"startToken":18806,"endToken":19005,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 63 \n \nsubstantive Tariff revisions proposed herein, PJM further requests that the Commission act \non this filing no later than January 29, 2027, to provide the advance notice necessary for \nefficient administration of the RBP. \nVII. \nMOTION FOR EXTENDED, 32-DAY COMMENT PERIOD \nTo provide interested parties with a meaningful opportunity to review and comment \non the proposed revisions to the RBP rules, PJM respectfully requests that the Commission \nestablish a 32-day comment period for this filing, i.e., November 30, 2026.  The requested \nextension accounts for the intervening holiday period and will help ensure that stakeholders \nhave adequate time to evaluate and comment on the proposed Tariff changes. \nAs noted above, the extended comment period will not reduce the time available \nfor Commission consideration of comments.  PJM is not requesting Commission action on \nthis filing until January 29, 2027, which would still afford the Commission with 60 days \nfollowing the close of the comment period to consider the record and issue an order.  \nAccordingly, the requested 32-day comment period appropriately balances the interests of \nproviding stakeholders sufficient time to comment while preserving an adequate period for \nCommission review before the requested effective date."},{"page":65,"startToken":19005,"endToken":19199,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 64 \n \nVIII. DESCRIPTION OF SUBMITTAL \nThis filing consists of the following: \n1.  This transmittal letter; \n2.  Attachment A – Revisions to the Tariff, in redline format; \n3.  Attachment B – Revisions to the Tariff, in clean format; \n4.  Attachment C – Affidavit of Gwen Kelly; and \n5.  Attachment D – Affidavit of Danielle Croop. \nIX. \nCORRESPONDENCE \nThe following individuals are designated for inclusion on the official service list in \nthis proceeding and for receipt of any communications regarding this filing: \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, N.W., Suite 600 \nWashington, DC  20005 \n(202) 423-4743 \ncraig.glazer@pjm.com \nChenchao Lu \nAssociate General Counsel \nPJM Interconnection, L.L.C. \n2750 Monroe Boulevard \nAudubon, PA  19403 \n(610) 666-2255 \nchenchao.lu@pjm.com \n \nRyan J. Collins \nVivian W. Chum \nWright & Talisman, P.C. \n1200 G Street, N.W., Suite 600 \nWashington, D.C.  20005 \n(202) 393-1200 (phone) \ncollins@wrightlaw.com \nchum@wrightlaw.com \n \n \nX. \nSERVICE \nPJM has served a copy of this filing on all PJM Members and on all state utility \nregulatory commissions in the PJM Region by posting this filing electronically.  In"},{"page":66,"startToken":19199,"endToken":19410,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 65 \n \naccordance with the Commission’s regulations,158 PJM will post a copy of this filing to the \nCommission filings section of its internet site, located at the following link: \nhttps://www.pjm.com/library/filing-order with a specific link to the newly filed document, \nand will send an e-mail on the same date as this filing to all PJM Members and all state \nutility regulatory commissions in the PJM Region159 alerting them that this filing has been \nmade by 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.  Also, a copy of this filing will be available \non \nthe \nCommission’s \neLibrary \nwebsite \nlocated \nat \nthe \nfollowing \nlink: \nhttp://www.ferc.gov/docsfiling/elibrary.asp in accordance with the Commission’s \nregulations and Order No. 714.160 \n \n158 See 18 C.F.R. §§ 35.2(e), 385.2010(f)(3). \n159 PJM already maintains, updates and regularly uses e-mail lists for all PJM Members and affected state \ncommissions. \n160 Electronic Tariff Filings, Order No. 714, 124 FERC ¶ 61,270 (2008), final rule, Order No. 714-A, 147 \nFERC ¶ 61,115 (2014)."},{"page":67,"startToken":19410,"endToken":19535,"text":"Debbie-Anne Reese, Secretary \nOctober 29, 2026 \nPage 66 \n \nXI. \nCONCLUSION \nBased on the foregoing, PJM respectfully requests that the Commission accept the \nproposed Tariff revisions as discussed herein and effective as proposed. \nRespectfully submitted, \n/s/ Chenchao Lu        \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, N.W., Suite 600 \nWashington, DC  20005 \n(202) 423-4743 \ncraig.glazer@pjm.com \nChenchao Lu \nAssociate General Counsel \nPJM Interconnection, L.L.C. \n2750 Monroe Boulevard \nAudubon, PA  19403 \n(610) 666-2255 \nchenchao.lu@pjm.com \n \nRyan J. Collins \nVivian W. Chum \nWright & Talisman, P.C. \n1200 G Street, N.W., Suite 600 \nWashington, D.C.  20005 \n(202) 393-1200 (phone) \ncollins@wrightlaw.com \nchum@wrightlaw.com \n \n \n \nOn behalf of \nPJM Interconnection, L.L.C."}],"sections":[{"p":1,"at":0,"title":"Attachment A","method":"printed heading","endPage":4,"endAt":948,"startToken":0,"endToken":700},{"p":4,"at":948,"title":"I. BACKGROUND","method":"printed heading","endPage":4,"endAt":952,"startToken":700,"endToken":701},{"p":4,"at":952,"title":"BACKGROUND","method":"printed heading","endPage":6,"endAt":526,"startToken":701,"endToken":1213},{"p":6,"at":526,"title":"II. PROPOSED UPDATES THAT ADDRESS ISSUES IDENTIFIED IN THE","method":"printed heading","endPage":6,"endAt":620,"startToken":1213,"endToken":1226},{"p":6,"at":620,"title":"A. PJM Proposes Updates that Directly Address the Commission’s RBP Cost","method":"printed heading","endPage":17,"endAt":353,"startToken":1226,"endToken":4840},{"p":17,"at":353,"title":"B. Credit Requirements of LSEs Commensurate with Risks (Proposed Tariff,","method":"printed heading","endPage":31,"endAt":1092,"startToken":4840,"endToken":9168},{"p":31,"at":1092,"title":"C. Treatment of RBP Commitment in Event of Transmission Owner Exit","method":"printed heading","endPage":41,"endAt":223,"startToken":9168,"endToken":12006},{"p":41,"at":223,"title":"III. PROPOSED ADDITIONAL UPDATES TO THE ACCEPTED RBP RULES","method":"printed heading","endPage":41,"endAt":485,"startToken":12006,"endToken":12046},{"p":41,"at":485,"title":"A. PJM Proposes to Amend the Opt-Out for LSEs that Are Not Regulated by","method":"printed heading","endPage":42,"endAt":595,"startToken":12046,"endToken":12333},{"p":42,"at":595,"title":"B. PJM Proposes Updates to Modify the Opt-Out for a Peak Shaving","method":"printed heading","endPage":44,"endAt":59,"startToken":12333,"endToken":12763},{"p":44,"at":59,"title":"C. PJM Proposes to Update the Rules Related to the Cure Period for Any","method":"printed heading","endPage":46,"endAt":634,"startToken":12763,"endToken":13448},{"p":46,"at":634,"title":"D. PJM Proposes Clarifications Related to Qualifying RBP Offset UCAP","method":"printed heading","endPage":51,"endAt":511,"startToken":13448,"endToken":14884},{"p":51,"at":511,"title":"E. PJM Proposes to Update Site Control Requirements.","method":"printed heading","endPage":53,"endAt":1348,"startToken":14884,"endToken":15569},{"p":53,"at":1348,"title":"F. PJM Proposes to Utilize the Most Updated Resource Forecast and","method":"printed heading","endPage":57,"endAt":174,"startToken":15569,"endToken":16600},{"p":57,"at":174,"title":"G. PJM Proposes to Update Must-Offer and Binding Notice of Intent Rules","method":"printed heading","endPage":58,"endAt":859,"startToken":16600,"endToken":17032},{"p":58,"at":859,"title":"IV. REQUEST","method":"printed heading","endPage":61,"endAt":1298,"startToken":17032,"endToken":18095},{"p":61,"at":1298,"title":"V. STAKEHOLDER CONSULTATION","method":"printed heading","endPage":62,"endAt":268,"startToken":18095,"endToken":18236},{"p":62,"at":268,"title":"VI. PROPOSED EFFECTIVE DATES AND UPDATED RBP TIMING","method":"printed heading","endPage":64,"endAt":281,"startToken":18236,"endToken":18847},{"p":64,"at":281,"title":"VII. MOTION FOR EXTENDED, 32-DAY COMMENT PERIOD","method":"printed heading","endPage":65,"endAt":59,"startToken":18847,"endToken":19013},{"p":65,"at":59,"title":"VIII. DESCRIPTION OF SUBMITTAL","method":"printed heading","endPage":65,"endAt":385,"startToken":19013,"endToken":19062},{"p":65,"at":385,"title":"IX. CORRESPONDENCE","method":"printed heading","endPage":65,"endAt":1089,"startToken":19062,"endToken":19168},{"p":65,"at":1089,"title":"X. SERVICE","method":"printed heading","endPage":67,"endAt":59,"startToken":19168,"endToken":19418},{"p":67,"at":59,"title":"XI. CONCLUSION","method":"printed heading","endPage":67,"endAt":64,"startToken":19418,"endToken":19419},{"p":67,"at":64,"title":"CONCLUSION","method":"printed heading","endPage":67,"endAt":841,"startToken":19419,"endToken":19535}]}