EL26-67-000 · 2026-07-08 · MAVEN SOLUTIONS

Comments of Maven Solutions on the Commission's Show Cause Order regarding large-load interconnection tariff provisions

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
PJM Interconnection, L.L.C. 
  
Show Cause Order regarding 
large-load interconnection 
tariff provisions 
Docket No. EL26-67-000 
 
COMMENTS OF MAVEN SOLUTIONS 
ON THE COMMISSION'S SHOW CAUSE ORDER 
Applying the Civic Bankability Rating Standard 
to FERC's Five Reform Categories 
Filed by: 
Maven Solutions 
Jayne Algermissen, Founder 
Seattle, Washington 
mavensolutions.xyz  ·  jalgermissen@gmail.com 
Dated: July 9, 2026 
One of six coordinated comments filed by Maven Solutions 
across Dockets EL26-67 through EL26-72

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TABLE OF CONTENTS 
I.  Introduction and Statement of Interest 
II.  Executive Summary 
III.  Record Background: The PJM System in Documented Distress 
IV.  Methodology: The Civic Bankability Rating Standard 
V.  Analysis Against FERC's Five Reform Categories 
VI.  CBRS Findings for PJM 
VII.  Recommendations to the Commission 
VIII.  Companion Filings and Stage 2 Supplement Notice 
IX.  Conclusion 
X.  Sources and Notes

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I.  INTRODUCTION AND STATEMENT OF INTEREST 
Maven Solutions is a Seattle-based decision-intelligence practice specializing in AI 
infrastructure, large-load interconnection, and grid governance. Founded in 2014, Maven has 
developed the Civic Bankability Rating Standard (“CBRS”), a statute-grounded scoring 
methodology for evaluating large-load and data-center projects against the ratepayer, reliability, 
community-cost, and financial-surety exposures they generate. Maven introduces the CBRS 
methodology to the Commission's record through these Comments. 
Maven Solutions is a named party of record in Docket No. RM26-4-000 (Large Loads Co-
Located at Generating Facilities and Other Considerations for the Efficient Use of the 
Transmission System). Maven's May 20, 2026 supplemental comment (Submission ID 
1755084) and June 8, 2026 filings (Accession Nos. 20260608-5025 and 20260608-5026) are on 
the federal record. On June 15, 2026, the Joint Consumer Advocates of Pennsylvania, 
Delaware, and New Jersey addressed Maven's filings alongside those of the Harvard 
Environmental & Energy Law Program, the Working Group for Investment in Reliable and 
Economic Electric Systems (WIRES), and the Transmission Access Policy Study Group (TAPS) 
in Accession No. 20260615-5141. Maven files these Comments in Docket No. EL26-67-000 in 
continuation of that record. 
Maven's interest in this proceeding is direct and specific. The Commission's June 18, 2026 
Show Cause Order in this docket directs PJM Interconnection, L.L.C. (“PJM”) to demonstrate 
why its existing tariff provisions governing large-load interconnection are just and reasonable, or 
to propose reforms consistent with the five reform categories specified in that Order.1 The CBRS 
instrument was developed to score precisely the class of tariff and interconnection questions the 
Commission has placed before PJM. 
II.  EXECUTIVE SUMMARY 
HEADLINE FINDING 
PJM's current tariff posture on large-load interconnection scores CONDITIONAL under the Civic 
Bankability Rating Standard with two active keystone flags — Ratepayer Protection (FERC 
Category 2) and Financial Surety (FERC Category 4). Under CBRS scoring architecture, 
concurrent activation of two keystone flags warrants Commission-level intervention on the specific 
reform categories to which those flags attach. 
 
The PJM system is under greater documented ratepayer and reliability stress than any regional 
grid in the modern capacity-market era. The evidentiary record supporting the Commission's 
Show Cause Order has intensified in the twenty-one days between issuance and the 
intervention deadline for these Comments.

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On May 18, 2026, the U.S. Department of Energy issued Emergency Order No. 202-26-23 
under Federal Power Act Section 202(c), effective May 18 through May 20, 2026, authorizing 
PJM to deploy backup generation resources at data centers and other major facilities as an 
emergency measure.2 This order followed an earlier DOE Section 202(c) order issued on 
January 26, 2026 addressing PJM and backup generation resources at large-load customers.3 
PJM's 2027/28 Base Residual Auction cleared 134,478.1 MW UCAP. Including 11,299.0 MW 
UCAP committed through Fixed Resource Requirement, total procured capacity was 145,777.1 
MW UCAP, which PJM reported as 6,516.6 MW UCAP below the RTO Reliability Requirement. 
PJM further reported that the auction cleared at a 14.4% installed reserve margin, 5.6 
percentage points below the 20% target.4 PJM has described the 2027/28 BRA as the first RPM 
auction since the Reliability Pricing Model was created in 2007 that did not meet the reliability 
requirement.4 
Capacity clearing prices rose from $28.92/MW-day in the 2024/25 delivery year to $333.44/MW-
day in the 2027/28 delivery year, an approximately 11.5-fold increase across three delivery-year 
auctions, held below unconstrained clearing levels only by the settlement price cap agreed 
between the Commonwealth of Pennsylvania and PJM.4 FERC-approved planning parameters 
for the 2028/29 BRA establish a $325/MW-day UCAP price cap and $175/MW-day UCAP price 
floor for that auction.5 
During the July 1–3, 2026 heat event, PJM forecast a July 2 peak of 166,147 MW, above the 
prior all-time summer hourly integrated peak of 165,563 MW set in 2006.6 PJM later reported 
preliminary July 2 instantaneous load of approximately 162,700 MW, suppressed by demand-
response activation. PJM also warned utilities to prepare for possible curtailment of data centers 
and other large loads to backup generation, but stated that the action was ultimately not 
required.7 
Maven's principal recommendations, developed in Section VII, are structured against each of 
the five reform categories established in the Show Cause Order. In summary, the Commission 
should require PJM to submit tariff revisions or, in the alternative, a detailed evidentiary showing 
addressing: (1) time-bounded transmission-service application and study commitments with 
public reporting; (2) a cost-causation methodology allocating transmission-upgrade costs 
caused by large-load interconnection to the responsible load class; (3) co-location and behind-
the-meter generation tariff provisions consistent with the Commission's parallel PJM co-location 
proceedings and including measurable reliability-hold-harmless mechanisms and financial 
surety instruments; (4) a new tariff class for flexible or curtailable large loads with contribution-
to-reliability compensation and coordination with state Virtual Power Plant and FERC Order 
2222 DER aggregation pathways; and (5) study-process reforms for generation serving 
electrically proximate or co-located loads that mirror the transparency and cost-causation 
provisions recommended for Category (2).

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These Comments are one of six substantive Comments Maven files this cycle across the six 
Show Cause dockets initiated on June 18, 2026 (EL26-67 through EL26-72). Each applies the 
CBRS instrument to the corresponding RTO. Together the six are one coordinated Comment 
across the federal RTO surface. 
III.  RECORD BACKGROUND: THE PJM SYSTEM IN 
DOCUMENTED DISTRESS 
A.  Emergency Authorities in Force 
On May 18, 2026, the U.S. Department of Energy issued Emergency Order No. 202-26-23 
under Federal Power Act Section 202(c), effective May 18 through May 20, 2026, authorizing 
PJM to deploy backup generation resources at data centers and other major facilities. PJM's 
request sought authority to direct data-center customers and other large-load customers with 
backup generation capability to use those resources instead of grid power during emergency 
conditions.2 
The May 18 order followed a January 26, 2026 DOE Section 202(c) order involving PJM and 
backup generation resources at data centers and other large-load customers. Together, the two 
2026 orders establish an emerging pattern of federal emergency backup-generation authorities 
directed to PJM's data-center and large-load footprint.3 
B.  Capacity Market Trajectory 
PJM Base Residual Auction (“BRA”) clearing prices have followed the trajectory shown below.4 
Delivery Year 
Clearing Price ($/MW-day) 
Notes 
2024/25 
$28.92 
Baseline 
2025/26 
$269.92 
Single-auction increase 
2026/27 
$329.17 
Constrained by PA/PJM 
settlement cap 
2027/28 
$333.44 
Constrained by cap; footprint 
shortfall auction 
2028/29 
Pending 
Auction ran June 30–July 4, 2026; 
FERC-approved $325 cap / $175 
floor 
 
The aggregate increase from 2024/25 to 2027/28 is approximately 11.5-fold across three 
delivery-year auctions. The 2026/27 and 2027/28 clearing prices were constrained by the 
settlement reached between the Commonwealth of Pennsylvania and PJM, which established a 
temporary price cap.4 
The 2028/29 BRA ran from June 30 through July 4, 2026 — during the concurrent heat event 
described in Section III.D. Contrary to some public commentary, that auction was not uncapped:

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FERC-approved planning parameters establish a $325/MW-day UCAP price cap and a 
$175/MW-day UCAP price floor for the 2028/29 BRA.5 Results were not yet public at the time of 
these Comments; Maven expressly reserves the right to file supplemental comment on 
publication of those results, as noted in Section VIII. 
C.  The 2027/28 Footprint Shortfall 
PJM has reported that the 2027/28 BRA was the first RPM auction since the Reliability Pricing 
Model was created in 2007 that did not meet the reliability requirement. Cleared capacity was 
134,478.1 MW UCAP; including 11,299.0 MW UCAP committed through Fixed Resource 
Requirement, total procured capacity was 145,777.1 MW UCAP, which PJM reported as 
6,516.6 MW UCAP below the RTO Reliability Requirement. The auction cleared at a 14.4% 
installed reserve margin, 5.6 percentage points below the 20% target.4 
On load-driver attribution, PJM identified a 5,249.9 MW increase in forecasted load, largely due 
to additional Large Loads.4 The Independent Market Monitor has separately reported that recent 
actual and forecast load increases were almost entirely due to existing and projected large data-
center additions, and that the inclusion of 17,071 MW of existing and forecast data-center load 
increased 2027/28 RPM revenues by $6.498 billion, or 65.5%.8 
D.  July 1–3, 2026 Emergency Event 
PJM forecast a July 2, 2026 peak of 166,147 MW, above the prior all-time summer hourly 
integrated peak of 165,563 MW set on August 2, 2006.6 PJM subsequently reported preliminary 
July 2 instantaneous load of approximately 162,700 MW, suppressed by demand-response 
activation. PJM also warned utilities to prepare for possible curtailment of data centers and 
other large loads to backup generation, but reported that the action was ultimately not required.7 
The event was contemporaneous with the intervention window for these Show Cause 
Comments. It is direct evidence, current as of the filing date, of the operational reality against 
which the Commission is evaluating PJM's tariff posture. 
E.  Estimated Ratepayer Impact 
The Natural Resources Defense Council has estimated that data-center-driven load growth 
could impose up to $163 billion in additional PJM consumer costs through 2033, with average 
household impacts reaching approximately $70 per month by 2028.9 
Monitoring Analytics has reported that the total cost of wholesale power in PJM increased from 
$77.78/MWh in Q1 2025 to $136.53/MWh in Q1 2026, a 75.5% increase.10 
F.  Companion Proceedings 
The Commission's Show Cause Order in this docket is one of six issued on June 18, 2026, 
splitting the underlying rulemaking record from Docket No. RM26-4-000 into RTO-specific

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proceedings: PJM (EL26-67), SPP (EL26-68), NYISO (EL26-69), MISO (EL26-70), CAISO 
(EL26-71), and ISO-NE (EL26-72).1 As Commissioner Chang's concurrence in EL26-67 notes, 
the co-location clarity issue is somewhat different for PJM because PJM already has a separate 
co-location-related proceeding before the Commission, in addition to a behind-the-meter 
generation compliance docket, both with compliance filings pending. Reform packages adopted 
in Category (3) of this docket should be tested for consistency with dispositions in those parallel 
proceedings.1 
IV.  METHODOLOGY: THE CIVIC BANKABILITY RATING 
STANDARD 
A.  Overview of CBRS 
The Civic Bankability Rating Standard is a statute-grounded scoring methodology Maven 
Solutions has developed for evaluating large-load and data-center projects against ratepayer, 
reliability, community-cost, and financial-surety exposures. Maven introduces the methodology 
to the Commission's record through these Comments. The methodology consists of ten 
dimensions, each anchored to a specific enacted statutory or regulatory framework in United 
States federal or state law. Each dimension is scored on a 0-to-5 evidence-weighted scale. 
Aggregate scores map to four bands: Below Threshold (0–12), Conditional (13–25), Acceptable 
(26–37), and Community Asset (38–50). 
Three of the ten dimensions are designated Keystone dimensions: Ratepayer Protection, Water, 
and Financial Surety. Any keystone dimension scoring below the Acceptable threshold caps the 
aggregate band at Conditional regardless of raw score total. Two or more concurrent keystone 
flags warrant elevated scrutiny of the specific reform categories to which they attach. 
B.  Jurisdictional Application to Commission Proceedings 
Not all CBRS dimensions map to matters within the Commission's Section 205 and Section 206 
jurisdiction. Maven applies to Commission proceedings a jurisdiction-relevant subset consisting 
of four dimensions: Ratepayer Protection, Transparency, Co-Location and Interconnection 
Governance, and Financial Surety. The full ten-dimension methodology is maintained by Maven 
Solutions and available on request. Maven's application of the jurisdictional subset in 
Commission dockets does not waive the applicability of the full methodology in state-utility-
commission, county-ordinance, permit, or corporate-decision contexts. 
C.  Mapping the Jurisdictional Subset to FERC's Five Reform Categories 
FERC Cat. 
Reform Focus 
Primary CBRS Dimension 
1 
Efficient transmission service application and 
study processes 
Transparency 
2 
Preventing cost shifting; requiring transparency 
Ratepayer Protection  —

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KEYSTONE 
3 
Co-location and behind-the-meter generation 
Co-Location & Interconnection 
Governance 
4 
New transmission services for flexible large 
loads 
Financial Surety  — KEYSTONE 
5 
Study process for generation serving 
proximate/co-located loads 
Transparency (secondary axis) 
 
Because CBRS has four jurisdictional dimensions and the Show Cause Order has five reform 
categories, one CBRS dimension (Transparency) is applied to two categories where 
transparency and process design are the operative concerns. Each dimension is scored once 
against its primary category and, where relevant, discussed as a secondary axis under other 
categories. 
V.  ANALYSIS AGAINST FERC'S FIVE REFORM CATEGORIES 
A.  Category (1) — Efficient Transmission Service Application and Study 
Processes 
Primary CBRS Dimension: Transparency     Score: 2 of 5 — Conditional. 
PJM's current transmission service application and study processes for large loads (>50 MW) 
proceed without a bounded time-to-service commitment, without public reporting on median or 
90th-percentile completion timelines, and without a customer-facing remedy mechanism for 
delayed studies. The Commission's Show Cause Order requires that reform in this category 
address efficiency of application and study processes. Efficiency without measurable customer-
facing commitments is not reform. 
PJM's current serial and cluster study procedures produce study timelines that vary materially 
across cluster cycles and across similarly situated interconnection customers. Aggregate 
outputs are reported in general terms but not disaggregated by service size, load class, or 
region. Under CBRS Transparency, this posture scores 2/5: partial disclosure of aggregate 
outcomes with no time-bounded customer commitment and no disaggregated public reporting. 
B.  Category (2) — Preventing Cost Shifting and Requiring Transparency 
Primary CBRS Dimension: Ratepayer Protection  —  KEYSTONE FLAG ACTIVE     Score: 1 
of 5 — below the CBRS Acceptable threshold. 
KEYSTONE FLAG — RATEPAYER PROTECTION 
Under CBRS scoring architecture, Ratepayer Protection is a pass/fail keystone dimension. A 
failing score caps the aggregate scoring band at Conditional regardless of other dimension 
performance. This is the first of two active keystone flags in Maven's assessment of PJM's current 
tariff posture. It warrants Commission-level intervention on Category (2).

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PJM identified a 5,249.9 MW increase in forecasted load for the 2027/28 delivery year, largely 
due to additional Large Loads.4 The Independent Market Monitor has separately reported that 
recent actual and forecast load increases were almost entirely due to existing and projected 
large data-center additions, and that the inclusion of 17,071 MW of existing and forecast data-
center load increased 2027/28 RPM revenues by $6.498 billion, or 65.5%.8 NRDC has 
estimated that data-center-driven load growth could impose up to $163 billion in additional PJM 
consumer costs through 2033, with average household impacts reaching approximately $70 per 
month by 2028.9 
The mismatch between cost causation and cost allocation in this category is not incidental. It is 
the direct product of a tariff structure that treats new large loads as if their marginal system 
impact is proportionate to their share of aggregate load, rather than proportionate to the 
transmission upgrades and capacity procurement they specifically require. Under CBRS 
Ratepayer Protection, the current PJM tariff posture fails to allocate the costs of transmission 
upgrades and capacity procurement attributable to large-load interconnection to the responsible 
load class. Score: 1/5 — below the CBRS Acceptable threshold, with KEYSTONE FLAG active. 
C.  Category (3) — Accommodating Co-Location and Behind-the-Meter 
Generation 
Primary CBRS Dimension: Co-Location & Interconnection Governance     Score: 2 of 5 — 
Conditional. 
As Commissioner Chang's concurrence in this docket notes, the co-location clarity issue is 
somewhat different for PJM than for the other RTOs addressed in the June 18 Show Cause 
Orders, because PJM already has a separate co-location-related proceeding before the 
Commission, in addition to a behind-the-meter generation (“BTMG”) compliance docket. Both 
parallel proceedings have compliance filings pending. Reform in Category (3) of this Show 
Cause docket should be tested for consistency with dispositions in those parallel proceedings 
before final Commission action.1 
Substantively, co-location and BTMG arrangements create the specific reliability risk illustrated 
by the July 10, 2024 Dominion Energy event, in which a failed lightning arrestor on a 230 kV 
facility produced voltage disturbances that led data-center-type load to transfer to backup power 
systems, resulting in an approximately 1,500 MW reduction of voltage-sensitive load on the 
transmission system.11 
Under CBRS Co-Location & Interconnection Governance, the current PJM posture scores 2/5. 
The posture recognizes co-location as a service class but does not yet include measurable 
reliability-hold-harmless mechanisms, financial surety instruments backing switching-event 
ratepayer exposure, or reciprocity provisions between co-located generation and the load it 
serves.

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D.  Category (4) — New Transmission Services for Flexible Large Loads 
Primary CBRS Dimension: Financial Surety  —  KEYSTONE FLAG ACTIVE     Score: 2 of 5 
— Conditional. 
KEYSTONE FLAG — FINANCIAL SURETY 
Under CBRS scoring architecture, Financial Surety is a pass/fail keystone dimension. This is the 
second of two active keystone flags in Maven's assessment of PJM's current tariff posture. 
Concurrent activation of two keystone flags on Categories (2) and (4) warrants coordinated 
Commission-level intervention on both categories. 
 
The Commission's identification of Category (4) as a reform lane recognizes that current firm-
service transmission tariffs are not the only option for large-load service. Curtailable, 
interruptible, or flexible-load tariff classes could reduce the cost-causation impact of large-load 
interconnection on the capacity market and on transmission upgrade needs. 
The state-level policy environment reinforces this reform lane. New Jersey Executive Order No. 
2, signed January 20, 2026, directs the New Jersey Board of Public Utilities to commence 
development of a Virtual Power Plant (“VPP”) program within 180 days of the order. The order 
directs that the VPP program aggregate behind-the-meter distributed energy resources and 
enable participation in PJM markets to the fullest extent possible.12 The 180-day mandate falls 
on or around July 19, 2026, thirteen days after the intervention deadline for these Comments. 
PJM has enabled DER aggregation participation in the capacity market beginning with the 
2028/29 Delivery Year BRA. Under PJM's implementation schedule, DER aggregations required 
notice of intent by June 12, 2026 for inclusion in the 2029/30 BRA, or by December 1, 2026 for 
inclusion in the 2030/31 BRA.13 This creates a structural timing gap between state VPP program 
launch and RTO capacity-market participation eligibility for aggregators in the PJM footprint. 
Under CBRS Financial Surety, the current PJM tariff posture does not provide financial surety 
instruments backing large-load commitments to their contracted service level, does not include 
compensation for contribution to reliability from flexible or curtailable loads, and does not yet 
coordinate operationally with state VPP or FERC Order 2222 pathways. Score: 2/5 — 
Conditional, with KEYSTONE FLAG active. 
E.  Category (5) — Process to Study Generation Serving Electrically 
Proximate or Co-Located Loads 
Primary CBRS Dimension: Transparency (applied to study process)     Score: 2 of 5 — 
Conditional. 
The Commission's identification of Category (5) as a reform lane reflects the fact that generation 
dedicated to serving co-located or electrically proximate large loads has become a significant 
subset of new generation interconnection in the PJM footprint. The study process for such

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generation currently proceeds on the same footing as unconstrained generation interconnection, 
which does not account for the specific service-and-cost relationship between the generation 
and the co-located load it primarily serves. 
Under CBRS Transparency (applied here as a secondary axis to the study process itself), the 
current PJM posture scores 2/5. The posture treats generation-load pairs of this type as 
structurally independent when they are, functionally and financially, tightly coupled. 
VI.  CBRS FINDINGS FOR PJM 
FERC 
Cat. 
CBRS Dimension Applied 
Raw Score 
Keystone? 
1 
Transparency (primary) 
2 / 5 
— 
2 
Ratepayer Protection 
1 / 5 
KEYSTONE FLAG 
3 
Co-Location & Interconnection 
Governance 
2 / 5 
— 
4 
Financial Surety 
2 / 5 
KEYSTONE FLAG 
5 
Transparency (secondary axis) 
2 / 5 
— 
Total 
Four unique dimensions applied 
9 / 20 
TWO keystone flags 
 
Note on scoring arithmetic: The Transparency dimension is scored once (Category 1 primary 
application) and discussed as a secondary axis under Category (5). The aggregate raw score of 
9 of 20 counts the four unique CBRS dimensions applied (Transparency, Ratepayer Protection, 
Co-Location & Interconnection Governance, Financial Surety), each scored on a 0–5 scale, for 
a maximum of 20. 
CBRS VERDICT: PJM — CURRENT TARIFF POSTURE 
Aggregate raw score 9 of 20. Band placement before keystone application: below the CBRS 
Acceptable threshold. Two active keystone flags (Ratepayer Protection and Financial Surety). 
Band placement after keystone application: CONDITIONAL. Concurrent activation of two keystone 
flags warrants Commission-level intervention on Categories (2) and (4) of the Show Cause Order. 
 
VII.  RECOMMENDATIONS TO THE COMMISSION 
Maven Solutions respectfully recommends that the Commission require PJM Interconnection, 
L.L.C. to submit tariff revisions or, in the alternative, a detailed evidentiary showing, addressing 
each of the five reform categories as set out below within the response period established in the 
Show Cause Order.

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Recommendation 1 — Category (1): Time-Bounded Transmission Service Application and 
Study Commitments 
PJM should be required to file proposed tariff revisions that include: (i) a bounded time-to-
service commitment for large-load interconnection studies, disaggregated by requested service 
size class; (ii) quarterly public reporting of median and 90th-percentile completion times, 
disaggregated by service size and by region; and (iii) a customer-remedy mechanism for 
delayed studies. Compliance with (i) and (iii) should be tested annually against the reported 
metrics required by (ii). 
Recommendation 2 — Category (2): Cost-Causation Methodology (KEYSTONE) 
PJM should be required to file proposed tariff revisions establishing a cost-causation 
methodology that: (i) attributes transmission upgrade costs and capacity procurement costs 
caused by large-load interconnection to the responsible load class, not to Load Serving Entities 
or residential rate classes; (ii) provides for public disclosure of the allocation methodology on a 
per-cluster and per-upgrade basis; (iii) is coordinated with state utility commissions on retail rate 
design implications; and (iv) includes a mechanism for retroactive adjustment where actual load 
materialization differs from the load presented at interconnection. 
Recommendation 3 — Category (3): Co-Location and BTMG Reliability and Ratepayer-Hold-
Harmless 
Any co-location or behind-the-meter generation tariff provisions adopted in Category (3) should 
be consistent with the Commission's dispositions in PJM's parallel co-location and BTMG 
compliance proceedings, and should include: (i) measurable reliability-hold-harmless 
mechanisms addressing the specific switching-event risk illustrated by the July 10, 2024 
Dominion event; (ii) financial surety instruments backing switching-event ratepayer exposure; 
and (iii) explicit reciprocity provisions between the co-located generation and the load it serves. 
Consistency verification with the parallel proceedings should occur before final Commission 
action in Category (3) of this docket. 
Recommendation 4 — Category (4): Flexible Large-Load Tariff Class (KEYSTONE) 
PJM should be required to file proposed tariff revisions establishing one or more new large-load 
tariff classes that: (i) provide for curtailable or interruptible service with defined compensation; 
(ii) include contribution-to-reliability crediting; (iii) coordinate operationally with state Virtual 
Power Plant programs and with the FERC Order 2222 DER aggregation pathway, including 
scheduling coordination for the current 2029/30 and 2030/31 BRA participation windows; and 
(iv) include financial surety instruments backing service-class commitments. 
Recommendation 5 — Category (5): Study-Process Reciprocity for Proximate Generation 
The study process for generation serving electrically proximate or co-located loads should 
incorporate: (i) reciprocity with the study process for the load it serves; (ii) cost-transparency 
provisions matching those recommended for Category (2); and (iii) explicit treatment of the

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reliability contribution of the generation to the interconnected system, distinct from its 
contribution to the specific load it primarily serves. 
VIII.  COMPANION FILINGS AND STAGE 2 SUPPLEMENT 
NOTICE 
These Comments are one of six substantive Comments Maven Solutions files in the six Show 
Cause dockets initiated on June 18, 2026 (Dockets EL26-67 through EL26-72). Each of the six 
applies the CBRS instrument to the corresponding RTO and is filed in coordination with the 
other five. Together the six should be read as one coordinated Comment applied six ways 
across the federal RTO surface. 
Maven expressly reserves the right to file supplemental comment on the record following: 
•  publication of PJM's 2028/29 BRA results (auction concluded July 4, 2026); 
•  RTO informational reports due July 20, 2026; 
•  RTO responses to the Show Cause Order due August 17, 2026; 
•  implementation status of New Jersey Executive Order No. 2 (VPP program) at the 180-
day mandate deadline of approximately July 19, 2026; and 
•  any other primary-source evidence developed during the response period. 
IX.  CONCLUSION 
For the reasons stated above, Maven Solutions respectfully submits that PJM's current tariff 
posture on large-load interconnection scores CONDITIONAL with two active keystone flags 
under the Civic Bankability Rating Standard. The Commission's five reform categories, 
addressed with the specific reforms recommended in Section VII, would materially strengthen 
PJM's tariff posture on cost causation, transparency, co-location governance, transmission 
service class design, and generation study reciprocity. Maven respectfully requests that the 
Commission require PJM to submit tariff revisions or, in the alternative, a detailed evidentiary 
showing that addresses each of the five categories consistent with the recommendations set out 
herein. 
 
Respectfully submitted, 
 
/s/ Jayne Algermissen 
Jayne Algermissen 
Founder, Maven Solutions

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Seattle, Washington 
Email: jalgermissen@gmail.com 
Web: mavensolutions.xyz 
LinkedIn: linkedin.com/in/jaynealgermissen 
 
Dated: July 9, 2026

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X.  SOURCES AND NOTES 
The following numbered notes correspond to superscript citations throughout these Comments. 
Where a citation refers to a Commission order, docket accession, or federal agency emergency 
order, Maven has referenced the source by its identifying number, date, and issuing agency to 
permit direct verification by Commission staff and other parties. 
1.  Federal Energy Regulatory Commission, Show Cause Order regarding PJM Interconnection, L.L.C. 
large-load interconnection tariff provisions, Docket No. EL26-67-000, issued June 18, 2026, and 
Commissioner Chang's concurrence to the order. 
2.  U.S. Department of Energy, Emergency Order No. 202-26-23 under Federal Power Act Section 
202(c), issued May 18, 2026, effective May 18–20, 2026, authorizing PJM to deploy backup 
generation resources at data centers and other major facilities. 
3.  U.S. Department of Energy, Section 202(c) emergency order involving PJM and backup generation 
resources at large-load customers, issued January 26, 2026. 
4.  PJM Interconnection, L.L.C., 2027/28 Base Residual Auction Report (published 2025), including 
cleared UCAP, FRR-committed capacity, total procured capacity, shortfall to RTO Reliability 
Requirement, installed reserve margin, and load-driver commentary. PJM has described the 
2027/28 auction as the first RPM auction since RPM was created in 2007 that did not meet the 
reliability requirement. 
5.  PJM Interconnection, L.L.C., 2028/29 BRA Planning Parameters and associated FERC-accepted tariff 
revisions establishing a $325/MW-day UCAP price cap and a $175/MW-day UCAP price floor for 
the 2028/29 Base Residual Auction. 
6.  PJM Interconnection, L.L.C., July 2, 2026 peak-load forecast reporting, including PJM's forecast peak 
of 166,147 MW and reference to the prior all-time summer hourly integrated peak of 165,563 MW 
set on August 2, 2006. 
7.  PJM Interconnection, L.L.C., post-event operations reporting on the July 1–3, 2026 heat event, 
including preliminary July 2, 2026 instantaneous load of approximately 162,700 MW after demand-
response activation and reporting on the utility warning regarding possible curtailment of data 
centers and other large loads to backup generation, which PJM stated was ultimately not required. 
8.  PJM Independent Market Monitor / Monitoring Analytics, 2027/28 RPM auction analysis, including 
findings that recent actual and forecast load increases were almost entirely due to existing and 
projected large data-center additions, and that inclusion of 17,071 MW of data-center load 
increased 2027/28 RPM revenues by $6.498 billion, or 65.5%. 
9.  Natural Resources Defense Council, data-center-driven PJM consumer-cost analysis, estimating up to 
$163 billion in additional PJM consumer costs through 2033 and average household impacts 
reaching approximately $70 per month by 2028. 
10.  Monitoring Analytics, LLC, Q1 2026 State of the Market Report for PJM, reporting that the total cost 
of wholesale power in PJM increased from $77.78/MWh in Q1 2025 to $136.53/MWh in Q1 2026, a 
75.5% increase. 
11.  North American Electric Reliability Corporation and Dominion Energy Virginia event reporting on the 
July 10, 2024 Northern Virginia event, describing a failed lightning arrestor associated with a 230 
kV facility that produced voltage disturbances leading data-center-type load to transfer to backup

16 of 16 
power systems and an approximately 1,500 MW reduction of voltage-sensitive load on the 
transmission system. 
12.  State of New Jersey, Executive Order No. 2 (Governor Sherrill), signed January 20, 2026, directing 
the New Jersey Board of Public Utilities to commence development of a Virtual Power Plant 
program within 180 days of the order, with the program intended to aggregate behind-the-meter 
distributed energy resources and enable participation in PJM markets to the fullest extent possible. 
13.  New Jersey Board of Public Utilities Request for Information on Virtual Power Plants and related PJM 
implementation materials for FERC Order 2222 DER aggregation, providing PJM's notice-of-intent 
schedule: June 12, 2026 for inclusion in the 2029/30 BRA, and December 1, 2026 for inclusion in 
the 2030/31 BRA. 
 
NOTE ON SOURCE VERIFICATION 
This numbered source list identifies each authority relied upon in these Comments. Maven has 
cross-checked each factual assertion against the identified source and welcomes correction on 
the record where any citation admits of a more precise formulation. In accordance with standard 
Commission practice, primary-source documents (Commission orders, DOE emergency orders, 
PJM auction reports, IMM analyses, NERC event reports, State executive orders, and State utility 
commission materials) are the controlling authorities in any conflict between these Comments and 
secondary reporting.