{"document":{"slug":"filing-20260708-5011","title":"Comments of Maven Solutions on the Commission's Show Cause Order regarding large-load interconnection tariff provisions","issued":"2026-07-08","accession":"20260708-5011","docket":"EL26-67-000","group":"PJM filings","filer":"MAVEN SOLUTIONS","kind":"comments","file":"sources/originals/20260708-5011_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260708-5011","sha256":"19d1d3a444195fc4bac958ec025b3dc691b37a72f2dc1fb4057bf9859bbd9419","pages":16,"tokens":4986,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":82,"text":"1 of 16 \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nPJM Interconnection, L.L.C. \n  \nShow Cause Order regarding \nlarge-load interconnection \ntariff provisions \nDocket No. EL26-67-000 \n \nCOMMENTS OF MAVEN SOLUTIONS \nON THE COMMISSION'S SHOW CAUSE ORDER \nApplying the Civic Bankability Rating Standard \nto FERC's Five Reform Categories \nFiled by: \nMaven Solutions \nJayne Algermissen, Founder \nSeattle, Washington \nmavensolutions.xyz  ·  jalgermissen@gmail.com \nDated: July 9, 2026 \nOne of six coordinated comments filed by Maven Solutions \nacross Dockets EL26-67 through EL26-72"},{"page":2,"startToken":82,"endToken":144,"text":"2 of 16 \nTABLE OF CONTENTS \nI.  Introduction and Statement of Interest \nII.  Executive Summary \nIII.  Record Background: The PJM System in Documented Distress \nIV.  Methodology: The Civic Bankability Rating Standard \nV.  Analysis Against FERC's Five Reform Categories \nVI.  CBRS Findings for PJM \nVII.  Recommendations to the Commission \nVIII.  Companion Filings and Stage 2 Supplement Notice \nIX.  Conclusion \nX.  Sources and Notes"},{"page":3,"startToken":144,"endToken":510,"text":"3 of 16 \nI.  INTRODUCTION AND STATEMENT OF INTEREST \nMaven Solutions is a Seattle-based decision-intelligence practice specializing in AI \ninfrastructure, large-load interconnection, and grid governance. Founded in 2014, Maven has \ndeveloped the Civic Bankability Rating Standard (“CBRS”), a statute-grounded scoring \nmethodology for evaluating large-load and data-center projects against the ratepayer, reliability, \ncommunity-cost, and financial-surety exposures they generate. Maven introduces the CBRS \nmethodology to the Commission's record through these Comments. \nMaven Solutions is a named party of record in Docket No. RM26-4-000 (Large Loads Co-\nLocated at Generating Facilities and Other Considerations for the Efficient Use of the \nTransmission System). Maven's May 20, 2026 supplemental comment (Submission ID \n1755084) and June 8, 2026 filings (Accession Nos. 20260608-5025 and 20260608-5026) are on \nthe federal record. On June 15, 2026, the Joint Consumer Advocates of Pennsylvania, \nDelaware, and New Jersey addressed Maven's filings alongside those of the Harvard \nEnvironmental & Energy Law Program, the Working Group for Investment in Reliable and \nEconomic Electric Systems (WIRES), and the Transmission Access Policy Study Group (TAPS) \nin Accession No. 20260615-5141. Maven files these Comments in Docket No. EL26-67-000 in \ncontinuation of that record. \nMaven's interest in this proceeding is direct and specific. The Commission's June 18, 2026 \nShow Cause Order in this docket directs PJM Interconnection, L.L.C. (“PJM”) to demonstrate \nwhy its existing tariff provisions governing large-load interconnection are just and reasonable, or \nto propose reforms consistent with the five reform categories specified in that Order.1 The CBRS \ninstrument was developed to score precisely the class of tariff and interconnection questions the \nCommission has placed before PJM. \nII.  EXECUTIVE SUMMARY \nHEADLINE FINDING \nPJM's current tariff posture on large-load interconnection scores CONDITIONAL under the Civic \nBankability Rating Standard with two active keystone flags — Ratepayer Protection (FERC \nCategory 2) and Financial Surety (FERC Category 4). Under CBRS scoring architecture, \nconcurrent activation of two keystone flags warrants Commission-level intervention on the specific \nreform categories to which those flags attach. \n \nThe PJM system is under greater documented ratepayer and reliability stress than any regional \ngrid in the modern capacity-market era. The evidentiary record supporting the Commission's \nShow Cause Order has intensified in the twenty-one days between issuance and the \nintervention deadline for these Comments."},{"page":4,"startToken":510,"endToken":989,"text":"4 of 16 \nOn May 18, 2026, the U.S. Department of Energy issued Emergency Order No. 202-26-23 \nunder Federal Power Act Section 202(c), effective May 18 through May 20, 2026, authorizing \nPJM to deploy backup generation resources at data centers and other major facilities as an \nemergency measure.2 This order followed an earlier DOE Section 202(c) order issued on \nJanuary 26, 2026 addressing PJM and backup generation resources at large-load customers.3 \nPJM's 2027/28 Base Residual Auction cleared 134,478.1 MW UCAP. Including 11,299.0 MW \nUCAP committed through Fixed Resource Requirement, total procured capacity was 145,777.1 \nMW UCAP, which PJM reported as 6,516.6 MW UCAP below the RTO Reliability Requirement. \nPJM further reported that the auction cleared at a 14.4% installed reserve margin, 5.6 \npercentage points below the 20% target.4 PJM has described the 2027/28 BRA as the first RPM \nauction since the Reliability Pricing Model was created in 2007 that did not meet the reliability \nrequirement.4 \nCapacity clearing prices rose from $28.92/MW-day in the 2024/25 delivery year to $333.44/MW-\nday in the 2027/28 delivery year, an approximately 11.5-fold increase across three delivery-year \nauctions, held below unconstrained clearing levels only by the settlement price cap agreed \nbetween the Commonwealth of Pennsylvania and PJM.4 FERC-approved planning parameters \nfor the 2028/29 BRA establish a $325/MW-day UCAP price cap and $175/MW-day UCAP price \nfloor for that auction.5 \nDuring the July 1–3, 2026 heat event, PJM forecast a July 2 peak of 166,147 MW, above the \nprior all-time summer hourly integrated peak of 165,563 MW set in 2006.6 PJM later reported \npreliminary July 2 instantaneous load of approximately 162,700 MW, suppressed by demand-\nresponse activation. PJM also warned utilities to prepare for possible curtailment of data centers \nand other large loads to backup generation, but stated that the action was ultimately not \nrequired.7 \nMaven's principal recommendations, developed in Section VII, are structured against each of \nthe five reform categories established in the Show Cause Order. In summary, the Commission \nshould require PJM to submit tariff revisions or, in the alternative, a detailed evidentiary showing \naddressing: (1) time-bounded transmission-service application and study commitments with \npublic reporting; (2) a cost-causation methodology allocating transmission-upgrade costs \ncaused by large-load interconnection to the responsible load class; (3) co-location and behind-\nthe-meter generation tariff provisions consistent with the Commission's parallel PJM co-location \nproceedings and including measurable reliability-hold-harmless mechanisms and financial \nsurety instruments; (4) a new tariff class for flexible or curtailable large loads with contribution-\nto-reliability compensation and coordination with state Virtual Power Plant and FERC Order \n2222 DER aggregation pathways; and (5) study-process reforms for generation serving \nelectrically proximate or co-located loads that mirror the transparency and cost-causation \nprovisions recommended for Category (2)."},{"page":5,"startToken":989,"endToken":1320,"text":"5 of 16 \nThese Comments are one of six substantive Comments Maven files this cycle across the six \nShow Cause dockets initiated on June 18, 2026 (EL26-67 through EL26-72). Each applies the \nCBRS instrument to the corresponding RTO. Together the six are one coordinated Comment \nacross the federal RTO surface. \nIII.  RECORD BACKGROUND: THE PJM SYSTEM IN \nDOCUMENTED DISTRESS \nA.  Emergency Authorities in Force \nOn May 18, 2026, the U.S. Department of Energy issued Emergency Order No. 202-26-23 \nunder Federal Power Act Section 202(c), effective May 18 through May 20, 2026, authorizing \nPJM to deploy backup generation resources at data centers and other major facilities. PJM's \nrequest sought authority to direct data-center customers and other large-load customers with \nbackup generation capability to use those resources instead of grid power during emergency \nconditions.2 \nThe May 18 order followed a January 26, 2026 DOE Section 202(c) order involving PJM and \nbackup generation resources at data centers and other large-load customers. Together, the two \n2026 orders establish an emerging pattern of federal emergency backup-generation authorities \ndirected to PJM's data-center and large-load footprint.3 \nB.  Capacity Market Trajectory \nPJM Base Residual Auction (“BRA”) clearing prices have followed the trajectory shown below.4 \nDelivery Year \nClearing Price ($/MW-day) \nNotes \n2024/25 \n$28.92 \nBaseline \n2025/26 \n$269.92 \nSingle-auction increase \n2026/27 \n$329.17 \nConstrained by PA/PJM \nsettlement cap \n2027/28 \n$333.44 \nConstrained by cap; footprint \nshortfall auction \n2028/29 \nPending \nAuction ran June 30–July 4, 2026; \nFERC-approved $325 cap / $175 \nfloor \n \nThe aggregate increase from 2024/25 to 2027/28 is approximately 11.5-fold across three \ndelivery-year auctions. The 2026/27 and 2027/28 clearing prices were constrained by the \nsettlement reached between the Commonwealth of Pennsylvania and PJM, which established a \ntemporary price cap.4 \nThe 2028/29 BRA ran from June 30 through July 4, 2026 — during the concurrent heat event \ndescribed in Section III.D. Contrary to some public commentary, that auction was not uncapped:"},{"page":6,"startToken":1320,"endToken":1768,"text":"6 of 16 \nFERC-approved planning parameters establish a $325/MW-day UCAP price cap and a \n$175/MW-day UCAP price floor for the 2028/29 BRA.5 Results were not yet public at the time of \nthese Comments; Maven expressly reserves the right to file supplemental comment on \npublication of those results, as noted in Section VIII. \nC.  The 2027/28 Footprint Shortfall \nPJM has reported that the 2027/28 BRA was the first RPM auction since the Reliability Pricing \nModel was created in 2007 that did not meet the reliability requirement. Cleared capacity was \n134,478.1 MW UCAP; including 11,299.0 MW UCAP committed through Fixed Resource \nRequirement, total procured capacity was 145,777.1 MW UCAP, which PJM reported as \n6,516.6 MW UCAP below the RTO Reliability Requirement. The auction cleared at a 14.4% \ninstalled reserve margin, 5.6 percentage points below the 20% target.4 \nOn load-driver attribution, PJM identified a 5,249.9 MW increase in forecasted load, largely due \nto additional Large Loads.4 The Independent Market Monitor has separately reported that recent \nactual and forecast load increases were almost entirely due to existing and projected large data-\ncenter additions, and that the inclusion of 17,071 MW of existing and forecast data-center load \nincreased 2027/28 RPM revenues by $6.498 billion, or 65.5%.8 \nD.  July 1–3, 2026 Emergency Event \nPJM forecast a July 2, 2026 peak of 166,147 MW, above the prior all-time summer hourly \nintegrated peak of 165,563 MW set on August 2, 2006.6 PJM subsequently reported preliminary \nJuly 2 instantaneous load of approximately 162,700 MW, suppressed by demand-response \nactivation. PJM also warned utilities to prepare for possible curtailment of data centers and \nother large loads to backup generation, but reported that the action was ultimately not required.7 \nThe event was contemporaneous with the intervention window for these Show Cause \nComments. It is direct evidence, current as of the filing date, of the operational reality against \nwhich the Commission is evaluating PJM's tariff posture. \nE.  Estimated Ratepayer Impact \nThe Natural Resources Defense Council has estimated that data-center-driven load growth \ncould impose up to $163 billion in additional PJM consumer costs through 2033, with average \nhousehold impacts reaching approximately $70 per month by 2028.9 \nMonitoring Analytics has reported that the total cost of wholesale power in PJM increased from \n$77.78/MWh in Q1 2025 to $136.53/MWh in Q1 2026, a 75.5% increase.10 \nF.  Companion Proceedings \nThe Commission's Show Cause Order in this docket is one of six issued on June 18, 2026, \nsplitting the underlying rulemaking record from Docket No. RM26-4-000 into RTO-specific"},{"page":7,"startToken":1768,"endToken":2118,"text":"7 of 16 \nproceedings: PJM (EL26-67), SPP (EL26-68), NYISO (EL26-69), MISO (EL26-70), CAISO \n(EL26-71), and ISO-NE (EL26-72).1 As Commissioner Chang's concurrence in EL26-67 notes, \nthe co-location clarity issue is somewhat different for PJM because PJM already has a separate \nco-location-related proceeding before the Commission, in addition to a behind-the-meter \ngeneration compliance docket, both with compliance filings pending. Reform packages adopted \nin Category (3) of this docket should be tested for consistency with dispositions in those parallel \nproceedings.1 \nIV.  METHODOLOGY: THE CIVIC BANKABILITY RATING \nSTANDARD \nA.  Overview of CBRS \nThe Civic Bankability Rating Standard is a statute-grounded scoring methodology Maven \nSolutions has developed for evaluating large-load and data-center projects against ratepayer, \nreliability, community-cost, and financial-surety exposures. Maven introduces the methodology \nto the Commission's record through these Comments. The methodology consists of ten \ndimensions, each anchored to a specific enacted statutory or regulatory framework in United \nStates federal or state law. Each dimension is scored on a 0-to-5 evidence-weighted scale. \nAggregate scores map to four bands: Below Threshold (0–12), Conditional (13–25), Acceptable \n(26–37), and Community Asset (38–50). \nThree of the ten dimensions are designated Keystone dimensions: Ratepayer Protection, Water, \nand Financial Surety. Any keystone dimension scoring below the Acceptable threshold caps the \naggregate band at Conditional regardless of raw score total. Two or more concurrent keystone \nflags warrant elevated scrutiny of the specific reform categories to which they attach. \nB.  Jurisdictional Application to Commission Proceedings \nNot all CBRS dimensions map to matters within the Commission's Section 205 and Section 206 \njurisdiction. Maven applies to Commission proceedings a jurisdiction-relevant subset consisting \nof four dimensions: Ratepayer Protection, Transparency, Co-Location and Interconnection \nGovernance, and Financial Surety. The full ten-dimension methodology is maintained by Maven \nSolutions and available on request. Maven's application of the jurisdictional subset in \nCommission dockets does not waive the applicability of the full methodology in state-utility-\ncommission, county-ordinance, permit, or corporate-decision contexts. \nC.  Mapping the Jurisdictional Subset to FERC's Five Reform Categories \nFERC Cat. \nReform Focus \nPrimary CBRS Dimension \n1 \nEfficient transmission service application and \nstudy processes \nTransparency \n2 \nPreventing cost shifting; requiring transparency \nRatepayer Protection  —"},{"page":8,"startToken":2118,"endToken":2439,"text":"8 of 16 \nKEYSTONE \n3 \nCo-location and behind-the-meter generation \nCo-Location & Interconnection \nGovernance \n4 \nNew transmission services for flexible large \nloads \nFinancial Surety  — KEYSTONE \n5 \nStudy process for generation serving \nproximate/co-located loads \nTransparency (secondary axis) \n \nBecause CBRS has four jurisdictional dimensions and the Show Cause Order has five reform \ncategories, one CBRS dimension (Transparency) is applied to two categories where \ntransparency and process design are the operative concerns. Each dimension is scored once \nagainst its primary category and, where relevant, discussed as a secondary axis under other \ncategories. \nV.  ANALYSIS AGAINST FERC'S FIVE REFORM CATEGORIES \nA.  Category (1) — Efficient Transmission Service Application and Study \nProcesses \nPrimary CBRS Dimension: Transparency     Score: 2 of 5 — Conditional. \nPJM's current transmission service application and study processes for large loads (>50 MW) \nproceed without a bounded time-to-service commitment, without public reporting on median or \n90th-percentile completion timelines, and without a customer-facing remedy mechanism for \ndelayed studies. The Commission's Show Cause Order requires that reform in this category \naddress efficiency of application and study processes. Efficiency without measurable customer-\nfacing commitments is not reform. \nPJM's current serial and cluster study procedures produce study timelines that vary materially \nacross cluster cycles and across similarly situated interconnection customers. Aggregate \noutputs are reported in general terms but not disaggregated by service size, load class, or \nregion. Under CBRS Transparency, this posture scores 2/5: partial disclosure of aggregate \noutcomes with no time-bounded customer commitment and no disaggregated public reporting. \nB.  Category (2) — Preventing Cost Shifting and Requiring Transparency \nPrimary CBRS Dimension: Ratepayer Protection  —  KEYSTONE FLAG ACTIVE     Score: 1 \nof 5 — below the CBRS Acceptable threshold. \nKEYSTONE FLAG — RATEPAYER PROTECTION \nUnder CBRS scoring architecture, Ratepayer Protection is a pass/fail keystone dimension. A \nfailing score caps the aggregate scoring band at Conditional regardless of other dimension \nperformance. This is the first of two active keystone flags in Maven's assessment of PJM's current \ntariff posture. It warrants Commission-level intervention on Category (2)."},{"page":9,"startToken":2439,"endToken":2853,"text":"9 of 16 \n \nPJM identified a 5,249.9 MW increase in forecasted load for the 2027/28 delivery year, largely \ndue to additional Large Loads.4 The Independent Market Monitor has separately reported that \nrecent actual and forecast load increases were almost entirely due to existing and projected \nlarge data-center additions, and that the inclusion of 17,071 MW of existing and forecast data-\ncenter load increased 2027/28 RPM revenues by $6.498 billion, or 65.5%.8 NRDC has \nestimated that data-center-driven load growth could impose up to $163 billion in additional PJM \nconsumer costs through 2033, with average household impacts reaching approximately $70 per \nmonth by 2028.9 \nThe mismatch between cost causation and cost allocation in this category is not incidental. It is \nthe direct product of a tariff structure that treats new large loads as if their marginal system \nimpact is proportionate to their share of aggregate load, rather than proportionate to the \ntransmission upgrades and capacity procurement they specifically require. Under CBRS \nRatepayer Protection, the current PJM tariff posture fails to allocate the costs of transmission \nupgrades and capacity procurement attributable to large-load interconnection to the responsible \nload class. Score: 1/5 — below the CBRS Acceptable threshold, with KEYSTONE FLAG active. \nC.  Category (3) — Accommodating Co-Location and Behind-the-Meter \nGeneration \nPrimary CBRS Dimension: Co-Location & Interconnection Governance     Score: 2 of 5 — \nConditional. \nAs Commissioner Chang's concurrence in this docket notes, the co-location clarity issue is \nsomewhat different for PJM than for the other RTOs addressed in the June 18 Show Cause \nOrders, because PJM already has a separate co-location-related proceeding before the \nCommission, in addition to a behind-the-meter generation (“BTMG”) compliance docket. Both \nparallel proceedings have compliance filings pending. Reform in Category (3) of this Show \nCause docket should be tested for consistency with dispositions in those parallel proceedings \nbefore final Commission action.1 \nSubstantively, co-location and BTMG arrangements create the specific reliability risk illustrated \nby the July 10, 2024 Dominion Energy event, in which a failed lightning arrestor on a 230 kV \nfacility produced voltage disturbances that led data-center-type load to transfer to backup power \nsystems, resulting in an approximately 1,500 MW reduction of voltage-sensitive load on the \ntransmission system.11 \nUnder CBRS Co-Location & Interconnection Governance, the current PJM posture scores 2/5. \nThe posture recognizes co-location as a service class but does not yet include measurable \nreliability-hold-harmless mechanisms, financial surety instruments backing switching-event \nratepayer exposure, or reciprocity provisions between co-located generation and the load it \nserves."},{"page":10,"startToken":2853,"endToken":3263,"text":"10 of 16 \nD.  Category (4) — New Transmission Services for Flexible Large Loads \nPrimary CBRS Dimension: Financial Surety  —  KEYSTONE FLAG ACTIVE     Score: 2 of 5 \n— Conditional. \nKEYSTONE FLAG — FINANCIAL SURETY \nUnder CBRS scoring architecture, Financial Surety is a pass/fail keystone dimension. This is the \nsecond of two active keystone flags in Maven's assessment of PJM's current tariff posture. \nConcurrent activation of two keystone flags on Categories (2) and (4) warrants coordinated \nCommission-level intervention on both categories. \n \nThe Commission's identification of Category (4) as a reform lane recognizes that current firm-\nservice transmission tariffs are not the only option for large-load service. Curtailable, \ninterruptible, or flexible-load tariff classes could reduce the cost-causation impact of large-load \ninterconnection on the capacity market and on transmission upgrade needs. \nThe state-level policy environment reinforces this reform lane. New Jersey Executive Order No. \n2, signed January 20, 2026, directs the New Jersey Board of Public Utilities to commence \ndevelopment of a Virtual Power Plant (“VPP”) program within 180 days of the order. The order \ndirects that the VPP program aggregate behind-the-meter distributed energy resources and \nenable participation in PJM markets to the fullest extent possible.12 The 180-day mandate falls \non or around July 19, 2026, thirteen days after the intervention deadline for these Comments. \nPJM has enabled DER aggregation participation in the capacity market beginning with the \n2028/29 Delivery Year BRA. Under PJM's implementation schedule, DER aggregations required \nnotice of intent by June 12, 2026 for inclusion in the 2029/30 BRA, or by December 1, 2026 for \ninclusion in the 2030/31 BRA.13 This creates a structural timing gap between state VPP program \nlaunch and RTO capacity-market participation eligibility for aggregators in the PJM footprint. \nUnder CBRS Financial Surety, the current PJM tariff posture does not provide financial surety \ninstruments backing large-load commitments to their contracted service level, does not include \ncompensation for contribution to reliability from flexible or curtailable loads, and does not yet \ncoordinate operationally with state VPP or FERC Order 2222 pathways. Score: 2/5 — \nConditional, with KEYSTONE FLAG active. \nE.  Category (5) — Process to Study Generation Serving Electrically \nProximate or Co-Located Loads \nPrimary CBRS Dimension: Transparency (applied to study process)     Score: 2 of 5 — \nConditional. \nThe Commission's identification of Category (5) as a reform lane reflects the fact that generation \ndedicated to serving co-located or electrically proximate large loads has become a significant \nsubset of new generation interconnection in the PJM footprint. The study process for such"},{"page":11,"startToken":3263,"endToken":3555,"text":"11 of 16 \ngeneration currently proceeds on the same footing as unconstrained generation interconnection, \nwhich does not account for the specific service-and-cost relationship between the generation \nand the co-located load it primarily serves. \nUnder CBRS Transparency (applied here as a secondary axis to the study process itself), the \ncurrent PJM posture scores 2/5. The posture treats generation-load pairs of this type as \nstructurally independent when they are, functionally and financially, tightly coupled. \nVI.  CBRS FINDINGS FOR PJM \nFERC \nCat. \nCBRS Dimension Applied \nRaw Score \nKeystone? \n1 \nTransparency (primary) \n2 / 5 \n— \n2 \nRatepayer Protection \n1 / 5 \nKEYSTONE FLAG \n3 \nCo-Location & Interconnection \nGovernance \n2 / 5 \n— \n4 \nFinancial Surety \n2 / 5 \nKEYSTONE FLAG \n5 \nTransparency (secondary axis) \n2 / 5 \n— \nTotal \nFour unique dimensions applied \n9 / 20 \nTWO keystone flags \n \nNote on scoring arithmetic: The Transparency dimension is scored once (Category 1 primary \napplication) and discussed as a secondary axis under Category (5). The aggregate raw score of \n9 of 20 counts the four unique CBRS dimensions applied (Transparency, Ratepayer Protection, \nCo-Location & Interconnection Governance, Financial Surety), each scored on a 0–5 scale, for \na maximum of 20. \nCBRS VERDICT: PJM — CURRENT TARIFF POSTURE \nAggregate raw score 9 of 20. Band placement before keystone application: below the CBRS \nAcceptable threshold. Two active keystone flags (Ratepayer Protection and Financial Surety). \nBand placement after keystone application: CONDITIONAL. Concurrent activation of two keystone \nflags warrants Commission-level intervention on Categories (2) and (4) of the Show Cause Order. \n \nVII.  RECOMMENDATIONS TO THE COMMISSION \nMaven Solutions respectfully recommends that the Commission require PJM Interconnection, \nL.L.C. to submit tariff revisions or, in the alternative, a detailed evidentiary showing, addressing \neach of the five reform categories as set out below within the response period established in the \nShow Cause Order."},{"page":12,"startToken":3555,"endToken":3958,"text":"12 of 16 \nRecommendation 1 — Category (1): Time-Bounded Transmission Service Application and \nStudy Commitments \nPJM should be required to file proposed tariff revisions that include: (i) a bounded time-to-\nservice commitment for large-load interconnection studies, disaggregated by requested service \nsize class; (ii) quarterly public reporting of median and 90th-percentile completion times, \ndisaggregated by service size and by region; and (iii) a customer-remedy mechanism for \ndelayed studies. Compliance with (i) and (iii) should be tested annually against the reported \nmetrics required by (ii). \nRecommendation 2 — Category (2): Cost-Causation Methodology (KEYSTONE) \nPJM should be required to file proposed tariff revisions establishing a cost-causation \nmethodology that: (i) attributes transmission upgrade costs and capacity procurement costs \ncaused by large-load interconnection to the responsible load class, not to Load Serving Entities \nor residential rate classes; (ii) provides for public disclosure of the allocation methodology on a \nper-cluster and per-upgrade basis; (iii) is coordinated with state utility commissions on retail rate \ndesign implications; and (iv) includes a mechanism for retroactive adjustment where actual load \nmaterialization differs from the load presented at interconnection. \nRecommendation 3 — Category (3): Co-Location and BTMG Reliability and Ratepayer-Hold-\nHarmless \nAny co-location or behind-the-meter generation tariff provisions adopted in Category (3) should \nbe consistent with the Commission's dispositions in PJM's parallel co-location and BTMG \ncompliance proceedings, and should include: (i) measurable reliability-hold-harmless \nmechanisms addressing the specific switching-event risk illustrated by the July 10, 2024 \nDominion event; (ii) financial surety instruments backing switching-event ratepayer exposure; \nand (iii) explicit reciprocity provisions between the co-located generation and the load it serves. \nConsistency verification with the parallel proceedings should occur before final Commission \naction in Category (3) of this docket. \nRecommendation 4 — Category (4): Flexible Large-Load Tariff Class (KEYSTONE) \nPJM should be required to file proposed tariff revisions establishing one or more new large-load \ntariff classes that: (i) provide for curtailable or interruptible service with defined compensation; \n(ii) include contribution-to-reliability crediting; (iii) coordinate operationally with state Virtual \nPower Plant programs and with the FERC Order 2222 DER aggregation pathway, including \nscheduling coordination for the current 2029/30 and 2030/31 BRA participation windows; and \n(iv) include financial surety instruments backing service-class commitments. \nRecommendation 5 — Category (5): Study-Process Reciprocity for Proximate Generation \nThe study process for generation serving electrically proximate or co-located loads should \nincorporate: (i) reciprocity with the study process for the load it serves; (ii) cost-transparency \nprovisions matching those recommended for Category (2); and (iii) explicit treatment of the"},{"page":13,"startToken":3958,"endToken":4239,"text":"13 of 16 \nreliability contribution of the generation to the interconnected system, distinct from its \ncontribution to the specific load it primarily serves. \nVIII.  COMPANION FILINGS AND STAGE 2 SUPPLEMENT \nNOTICE \nThese Comments are one of six substantive Comments Maven Solutions files in the six Show \nCause dockets initiated on June 18, 2026 (Dockets EL26-67 through EL26-72). Each of the six \napplies the CBRS instrument to the corresponding RTO and is filed in coordination with the \nother five. Together the six should be read as one coordinated Comment applied six ways \nacross the federal RTO surface. \nMaven expressly reserves the right to file supplemental comment on the record following: \n•  publication of PJM's 2028/29 BRA results (auction concluded July 4, 2026); \n•  RTO informational reports due July 20, 2026; \n•  RTO responses to the Show Cause Order due August 17, 2026; \n•  implementation status of New Jersey Executive Order No. 2 (VPP program) at the 180-\nday mandate deadline of approximately July 19, 2026; and \n•  any other primary-source evidence developed during the response period. \nIX.  CONCLUSION \nFor the reasons stated above, Maven Solutions respectfully submits that PJM's current tariff \nposture on large-load interconnection scores CONDITIONAL with two active keystone flags \nunder the Civic Bankability Rating Standard. The Commission's five reform categories, \naddressed with the specific reforms recommended in Section VII, would materially strengthen \nPJM's tariff posture on cost causation, transparency, co-location governance, transmission \nservice class design, and generation study reciprocity. Maven respectfully requests that the \nCommission require PJM to submit tariff revisions or, in the alternative, a detailed evidentiary \nshowing that addresses each of the five categories consistent with the recommendations set out \nherein. \n \nRespectfully submitted, \n \n/s/ Jayne Algermissen \nJayne Algermissen \nFounder, Maven Solutions"},{"page":14,"startToken":4239,"endToken":4260,"text":"14 of 16 \nSeattle, Washington \nEmail: jalgermissen@gmail.com \nWeb: mavensolutions.xyz \nLinkedIn: linkedin.com/in/jaynealgermissen \n \nDated: July 9, 2026"},{"page":15,"startToken":4260,"endToken":4775,"text":"15 of 16 \nX.  SOURCES AND NOTES \nThe following numbered notes correspond to superscript citations throughout these Comments. \nWhere a citation refers to a Commission order, docket accession, or federal agency emergency \norder, Maven has referenced the source by its identifying number, date, and issuing agency to \npermit direct verification by Commission staff and other parties. \n1.  Federal Energy Regulatory Commission, Show Cause Order regarding PJM Interconnection, L.L.C. \nlarge-load interconnection tariff provisions, Docket No. EL26-67-000, issued June 18, 2026, and \nCommissioner Chang's concurrence to the order. \n2.  U.S. Department of Energy, Emergency Order No. 202-26-23 under Federal Power Act Section \n202(c), issued May 18, 2026, effective May 18–20, 2026, authorizing PJM to deploy backup \ngeneration resources at data centers and other major facilities. \n3.  U.S. Department of Energy, Section 202(c) emergency order involving PJM and backup generation \nresources at large-load customers, issued January 26, 2026. \n4.  PJM Interconnection, L.L.C., 2027/28 Base Residual Auction Report (published 2025), including \ncleared UCAP, FRR-committed capacity, total procured capacity, shortfall to RTO Reliability \nRequirement, installed reserve margin, and load-driver commentary. PJM has described the \n2027/28 auction as the first RPM auction since RPM was created in 2007 that did not meet the \nreliability requirement. \n5.  PJM Interconnection, L.L.C., 2028/29 BRA Planning Parameters and associated FERC-accepted tariff \nrevisions establishing a $325/MW-day UCAP price cap and a $175/MW-day UCAP price floor for \nthe 2028/29 Base Residual Auction. \n6.  PJM Interconnection, L.L.C., July 2, 2026 peak-load forecast reporting, including PJM's forecast peak \nof 166,147 MW and reference to the prior all-time summer hourly integrated peak of 165,563 MW \nset on August 2, 2006. \n7.  PJM Interconnection, L.L.C., post-event operations reporting on the July 1–3, 2026 heat event, \nincluding preliminary July 2, 2026 instantaneous load of approximately 162,700 MW after demand-\nresponse activation and reporting on the utility warning regarding possible curtailment of data \ncenters and other large loads to backup generation, which PJM stated was ultimately not required. \n8.  PJM Independent Market Monitor / Monitoring Analytics, 2027/28 RPM auction analysis, including \nfindings that recent actual and forecast load increases were almost entirely due to existing and \nprojected large data-center additions, and that inclusion of 17,071 MW of data-center load \nincreased 2027/28 RPM revenues by $6.498 billion, or 65.5%. \n9.  Natural Resources Defense Council, data-center-driven PJM consumer-cost analysis, estimating up to \n$163 billion in additional PJM consumer costs through 2033 and average household impacts \nreaching approximately $70 per month by 2028. \n10.  Monitoring Analytics, LLC, Q1 2026 State of the Market Report for PJM, reporting that the total cost \nof wholesale power in PJM increased from $77.78/MWh in Q1 2025 to $136.53/MWh in Q1 2026, a \n75.5% increase. \n11.  North American Electric Reliability Corporation and Dominion Energy Virginia event reporting on the \nJuly 10, 2024 Northern Virginia event, describing a failed lightning arrestor associated with a 230 \nkV facility that produced voltage disturbances leading data-center-type load to transfer to backup"},{"page":16,"startToken":4775,"endToken":4986,"text":"16 of 16 \npower systems and an approximately 1,500 MW reduction of voltage-sensitive load on the \ntransmission system. \n12.  State of New Jersey, Executive Order No. 2 (Governor Sherrill), signed January 20, 2026, directing \nthe New Jersey Board of Public Utilities to commence development of a Virtual Power Plant \nprogram within 180 days of the order, with the program intended to aggregate behind-the-meter \ndistributed energy resources and enable participation in PJM markets to the fullest extent possible. \n13.  New Jersey Board of Public Utilities Request for Information on Virtual Power Plants and related PJM \nimplementation materials for FERC Order 2222 DER aggregation, providing PJM's notice-of-intent \nschedule: June 12, 2026 for inclusion in the 2029/30 BRA, and December 1, 2026 for inclusion in \nthe 2030/31 BRA. \n \nNOTE ON SOURCE VERIFICATION \nThis numbered source list identifies each authority relied upon in these Comments. Maven has \ncross-checked each factual assertion against the identified source and welcomes correction on \nthe record where any citation admits of a more precise formulation. In accordance with standard \nCommission practice, primary-source documents (Commission orders, DOE emergency orders, \nPJM auction reports, IMM analyses, NERC event reports, State executive orders, and State utility \ncommission materials) are the controlling authorities in any conflict between these Comments and \nsecondary reporting."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":9,"startToken":0,"endToken":85},{"p":2,"at":9,"title":"TABLE OF CONTENTS","method":"printed heading","endPage":2,"endAt":28,"startToken":85,"endToken":88},{"p":2,"at":28,"title":"I. Introduction and Statement of Interest","method":"printed heading","endPage":2,"endAt":72,"startToken":88,"endToken":94},{"p":2,"at":72,"title":"II. Executive Summary","method":"printed heading","endPage":2,"endAt":96,"startToken":94,"endToken":97},{"p":2,"at":96,"title":"III. Record Background: The PJM System in Documented Distress","method":"printed heading","endPage":2,"endAt":160,"startToken":97,"endToken":106},{"p":2,"at":160,"title":"IV. Methodology: The Civic Bankability Rating Standard","method":"printed heading","endPage":2,"endAt":217,"startToken":106,"endToken":113},{"p":2,"at":217,"title":"V. Analysis Against FERC's Five Reform Categories","method":"printed heading","endPage":2,"endAt":269,"startToken":113,"endToken":120},{"p":2,"at":269,"title":"VI. CBRS Findings for PJM","method":"printed heading","endPage":2,"endAt":297,"startToken":120,"endToken":125},{"p":2,"at":297,"title":"VII. Recommendations to the Commission","method":"printed heading","endPage":2,"endAt":338,"startToken":125,"endToken":130},{"p":2,"at":338,"title":"VIII. Companion Filings and Stage 2 Supplement Notice","method":"printed heading","endPage":2,"endAt":394,"startToken":130,"endToken":138},{"p":2,"at":394,"title":"IX. Conclusion","method":"printed heading","endPage":2,"endAt":411,"startToken":138,"endToken":140},{"p":2,"at":411,"title":"X. Sources and Notes","method":"printed heading","endPage":3,"endAt":9,"startToken":140,"endToken":147},{"p":3,"at":9,"title":"I. INTRODUCTION AND STATEMENT OF INTEREST","method":"printed heading","endPage":3,"endAt":1895,"startToken":147,"endToken":407},{"p":3,"at":1895,"title":"II. EXECUTIVE SUMMARY","method":"printed heading","endPage":5,"endAt":311,"startToken":407,"endToken":1039},{"p":5,"at":311,"title":"III. RECORD BACKGROUND: THE PJM SYSTEM IN","method":"printed heading","endPage":5,"endAt":376,"startToken":1039,"endToken":1048},{"p":5,"at":376,"title":"A. Emergency Authorities in Force","method":"printed heading","endPage":5,"endAt":1218,"startToken":1048,"endToken":1173},{"p":5,"at":1218,"title":"B. Capacity Market Trajectory","method":"printed heading","endPage":6,"endAt":325,"startToken":1173,"endToken":1376},{"p":6,"at":325,"title":"C. The 2027/28 Footprint Shortfall","method":"printed heading","endPage":6,"endAt":1325,"startToken":1376,"endToken":1546},{"p":6,"at":1325,"title":"D. July 1–3, 2026 Emergency Event","method":"printed heading","endPage":6,"endAt":2062,"startToken":1546,"endToken":1664},{"p":6,"at":2062,"title":"E. Estimated Ratepayer Impact","method":"printed heading","endPage":6,"endAt":2508,"startToken":1664,"endToken":1737},{"p":6,"at":2508,"title":"F. Companion Proceedings","method":"printed heading","endPage":7,"endAt":575,"startToken":1737,"endToken":1847},{"p":7,"at":575,"title":"IV. METHODOLOGY: THE CIVIC BANKABILITY RATING","method":"printed heading","endPage":7,"endAt":633,"startToken":1847,"endToken":1854},{"p":7,"at":633,"title":"A. Overview of CBRS","method":"printed heading","endPage":7,"endAt":1704,"startToken":1854,"endToken":2001},{"p":7,"at":1704,"title":"B. Jurisdictional Application to Commission Proceedings","method":"printed heading","endPage":7,"endAt":2387,"startToken":2001,"endToken":2084},{"p":7,"at":2387,"title":"C. Mapping the Jurisdictional Subset to FERC's Five Reform Categories","method":"printed heading","endPage":8,"endAt":667,"startToken":2084,"endToken":2206},{"p":8,"at":667,"title":"V. ANALYSIS AGAINST FERC'S FIVE REFORM CATEGORIES","method":"printed heading","endPage":8,"endAt":719,"startToken":2206,"endToken":2213},{"p":8,"at":719,"title":"A. Category (1) — Efficient Transmission Service Application and Study","method":"printed heading","endPage":8,"endAt":1830,"startToken":2213,"endToken":2358},{"p":8,"at":1830,"title":"B. Category (2) — Preventing Cost Shifting and Requiring Transparency","method":"printed heading","endPage":9,"endAt":1339,"startToken":2358,"endToken":2647},{"p":9,"at":1339,"title":"C. Category (3) — Accommodating Co-Location and Behind-the-Meter","method":"printed heading","endPage":10,"endAt":10,"startToken":2647,"endToken":2856},{"p":10,"at":10,"title":"D. Category (4) — New Transmission Services for Flexible Large Loads","method":"printed heading","endPage":10,"endAt":2357,"startToken":2856,"endToken":3195},{"p":10,"at":2357,"title":"E. Category (5) — Process to Study Generation Serving Electrically","method":"printed heading","endPage":11,"endAt":517,"startToken":3195,"endToken":3336},{"p":11,"at":517,"title":"VI. CBRS FINDINGS FOR PJM","method":"printed heading","endPage":11,"endAt":1711,"startToken":3336,"endToken":3504},{"p":11,"at":1711,"title":"VII. RECOMMENDATIONS TO THE COMMISSION","method":"printed heading","endPage":13,"endAt":158,"startToken":3504,"endToken":3981},{"p":13,"at":158,"title":"VIII. COMPANION FILINGS AND STAGE 2 SUPPLEMENT","method":"printed heading","endPage":13,"endAt":1114,"startToken":3981,"endToken":4129},{"p":13,"at":1114,"title":"IX. CONCLUSION","method":"printed heading","endPage":15,"endAt":10,"startToken":4129,"endToken":4263},{"p":15,"at":10,"title":"X. SOURCES AND NOTES","method":"printed heading","endPage":16,"endAt":1453,"startToken":4263,"endToken":4986}]}