EL26-67-001 · 2026-07-17 · Maryland Office of People's CounselOHIO CONSUMERS' COUNSELDELAWARE DIVISION OF THE PUBLIC ADVOCATE ,OFFICE OF THE ILLINOIS ATTORNEY GENERAL ,

The Maryland Office of People's Counsel, et al. submit Request for Rehearing of the 06/18/2026 Order

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Topics in the text: Cost allocation · Filing procedure · Retail and wholesale authority

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Opening text

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We respectfully request rehearing on the Commission’s finding that it “must act to address the risk of cost shifting among transmission customers” but not actual cost shifts among transmission customers that are guaranteed by the PJM Tariff.3 We agree with the Commission that, if implemented…
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I. Statement of Issues and Specifications of Error

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To the extent the Order’s findings regarding state authority over retail cost allocation constitute final determinations, the Commission erred by finding that transparency will enable state regulators to sub-allocate Network Upgrade costs to retail customers “as they see fit,” without considering…
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II. Illustration: The PJM transmission tariff spreads Network Upgrade

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Because our requests for rehearing are about the PJM Tariff, we illustrate how the tariff operates with a hypothetical about Network Upgrade costs.
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III. Requests for Rehearing

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Requests for Rehearing
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A. By failing to remedy a transmission tariff that facilitates systemic and

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FERC, 756 F.3d 556, 561, 565 (7th Cir. 2014). 29 Order at P 68 (“The Commission has a duty to address the risk of cost shifting among transmission customers that may result in unjust and unreasonable transmission rates.”); id. (“To fulfill its responsibility to ensure that transmission rates are…
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B. The Commission failed to rationally connect Network Upgrade cost

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Pennsylvania EDCs and their affiliated transmission companies cannot implement cost allocation methodologies that conflict with FERC-approved tariffs and orders.”) (EAP’s members include several PJM Transmission Owners). 23 Under the second model, a transmission owner recovers transmission charges…
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IV. Requests for Clarification

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Requests for Clarification
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A. The Commission should clarify that a just and reasonable

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The Commission should clarify that a just and reasonable cost-recovery agreement requires the Eligible Customer to pay the full incremental cost of Network Upgrades needed to accommodate the large load.
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B. The Commission should clarify that transmission owners must

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The Commission should clarify that transmission owners must immediately credit revenue received under cost-recovery agreements to the other transmission customers in the zone.
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CONCLUSION

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CONCLUSION The Order correctly finds that the PJM Tariff shifts the costs of Network Upgrades for large loads to transmission customers that neither caused nor benefit from them.
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Certificate of Service

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Sussler Philip L.
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