{"document":{"slug":"filing-20260803-5106","title":"Answer in Support of the PJM Industrial Customer Coalition to the Motions for Extension and Abeyance by PJM Interconnection, L.L.C","issued":"2026-08-03","accession":"20260803-5106","docket":"EL26-67-000","group":"PJM filings","filer":"PJM Industrial Customer Coalition","kind":"answer","file":"sources/originals/20260803-5106_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5106","sha256":"1e8d58dfe0def165db82242d46dfae8049a4326edeba64213ad6aca08149bd2c","pages":5,"tokens":958,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":201,"text":"UNITED STATES OF AMERICA \nBEFORE THE  \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nPJM Interconnection, L.L.C.  \n \n \n) \n \nDocket No. EL25-49-002 \n) \n \nDocket No. EL25-49-000 \n \n \n \n \n \n \n \n) \nLarge Loads Co-Located at Generating Facilities \n)  \n \nDocket No. AD24-11-001 \n \n \n \n \n \n \n \n) \nConstellation Energy Generation, LLC \n \n) \n \nv. \n \n \n \n \n \n) \n \nDocket No. EL25-20-001 \nPJM Interconnection, L.L.C.  \n \n \n) \n \n(Consolidated) \n \n \n \n \n \n \n \n) \nPJM Interconnection, L.L.C.  \n \n \n) \n \nDocket No. ER26-1479-000 \n \n \n \n \n \n \n \n) \nPJM Interconnection, L.L.C.  \n \n \n) \n \nDocket No. EL26-67-000 \n \n \nANSWER IN SUPPORT OF \nTHE PJM INDUSTRIAL CUSTOMER COALITION \nTO THE MOTIONS FOR EXTENSION AND ABEYANCE \nBY PJM INTERCONNECTION, L.L.C. \n \nPursuant to Rule 213 of the Federal Energy Regulatory Commission (“Commission”) \nRules of Practice and Procedure and the requests for a shortened answer period of PJM \nInterconnection, L.L.C. (“PJM”),1 PJM Industrial Customer Coalition (“PJMICC”) hereby files \nthis Answer in support of PJM’s Motion for Extension of Time for Specified Compliance \nRequirements and Request for Expedited Treatment of PJM Interconnection, L.L.C. in Docket No. \nEL25-49, et al. (“Co-Located Load Extension Motion”) and Motion of PJM Interconnection, \nL.L.C. to Hold Proceeding in Abeyance and Request For Shortened Answer Period and Expedited \nTreatment in Docket No. EL26-67 (“Large Load Abeyance Motion”), both of which were filed on \n \n1 See 18 C.F.R. § 385.213."},{"page":2,"startToken":201,"endToken":594,"text":"- 2 - \nJuly 28, 2026.2 These Motions both request that the Commission extend certain PJM filing \ndeadlines by 90 days.  \nIn its Co-Located Load Extension Motion, PJM explains: “The compliance changes \ndirected in this proceeding significantly relate to or overlap with the directives in the Large \nLoad Order in three major areas: expansion of new transmission services, study procedures, and \noperational requirements.”3 To facilitate the stakeholder process and to allow for coordination on \nthe Co-Located Load docket and the Large Load docket, PJM seeks a parallel ninety-day extension \nfor both proceedings, which will result in filings by mid-November.4 \nPJM further states: \nGiven the interrelated nature of a number of the other requirements in the \nCompliance Order and Large Load Order, a coordinated approach on the \nremaining compliance matters is appropriate for consistency and efficiency.  \nAs noted above, both orders require PJM to propose Tariff changes to address the \nstudy procedures to interconnect Co-Located/Large Loads, make new transmission \nservices available for customers that are willing and able to limit their withdrawals, \nand specify operational requirements for Co-Located/Large Loads. PJM proposes \nto address these interrelated requirements in a suite of filings to be submitted by \nearly to mid-November following a period of intensive stakeholder engagement and \nfeedback.5  \n \nPJMICC agrees with PJM’s proposed approach, which facilitates administrative \nefficiencies and helps consolidate stakeholder and party resources and work efforts.6 PJMICC \n \n2 Also on July 28, 2026, certain PJM Transmission Owners (“Indicated Transmission Owners”) filed parallel \npleadings: (1) Motion for Extension of Compliance Deadline of the Indicated PJM Transmission Owners and Request \nfor Expedited Action and Shortened Comment Period in Docket No. EL25-49, et al.; and (2) Motion for Abeyance of \nthe Indicated PJM Transmission Owners and Request for Expedited Action and Shortened Comment Period in Docket \nNo. EL26-67. PJMICC also supports the requests of the Indicated Transmission Owners for extension and abeyance, \nrespectively, until November 16, 2026. \n3 Co-Located Load Extension Motion at 4 (emphasis added). \n4 Id. at 6. PJM also pledges to complete a partial compliance filing by August 17, 2026. Id. \n5 Id. at 7-8 (emphasis added). \n6 See Motion for Extension of Compliance Deadline of the Indicated PJM Transmission Owners, Docket No. EL25-\n49 et al., at 7 (emphasizing the importance of coordination to ensure Commission review of proposed reforms “in a \ncoherent and administratively efficient fashion.”)."},{"page":3,"startToken":594,"endToken":802,"text":"- 3 - \nbelieves that such a 90-day time frame is proportionate to the reforms the Commission is pursuing. \nThe Commission, PJM, and many stakeholders have been working hard to ensure all stakeholder \nvoices and perspectives are considered. Many of these participants have raised nuanced but \nimportant issues that include significant downstream effects of the Commission’s major orders in \nthese dockets. To execute on the Commission’s reforms in a logical, coherent, and durable manner, \nthese nuanced issues must be addressed thoroughly and carefully in a coordinated fashion.  \nIn summary, PJMICC agrees with PJM that the above-captioned proceedings raise \ncomplex issues that are necessarily interrelated and that require significant analysis. In pursuit of \ndurable final orders that provide the industry with regulatory stability and clear direction toward \ninvestment, growth, and resource adequacy, PJM’s plan to ensure robust discussion within the \nPJM stakeholder process—and adequate time to ensure both proceedings are complementing and \nnot contradicting one another—is reasonable. Even a 90-day extension is still potentially an \naggressive timeline, but it better strikes the balance between the FERC’s urgent call for reforms \nand the need for time to create a durable compliance filing. PJMICC therefore respectfully requests \nthat the Commission grant PJM’s Co-Located Load Extension Motion and Large Load Abeyance \nMotion."},{"page":4,"startToken":802,"endToken":891,"text":"- 4 - \nWHEREFORE, the PJM Industrial Customer Coalition supports PJM Interconnection, \nL.L.C.’s Co-Located Load Extension Motion and Large Load Abeyance Motion and respectfully \nrequests that the Commission grant those Motions in an expedited fashion. \n \n \n \n \n \n \nRespectfully submitted, \nMcNEES WALLACE & NURICK LLC \n/s/  Matthew L. Garber \nBy______________________________ \nSusan E. Bruce \nKenneth R. Stark \nMatthew Garber \nMcNees Wallace & Nurick LLC \n100 Pine Street \nHarrisburg, PA 17101 \nPhone/Fax:  (717) 237-5254 \nE-mail:  sbruce@mcneeslaw.com \n              kstark@mcneeslaw.com  \n              mgarber@mcneeslaw.com  \n \nCounsel to PJM Industrial Customer Coalition \n \nDated:  August 3, 2026"},{"page":5,"startToken":891,"endToken":958,"text":"CERTIFICATE OF SERVICE \n \n \nI hereby certify that I have this day served, via first-class mail, electronic transmission, or \nhand-delivery, the foregoing upon each person designated on the official service list compiled by \nthe Secretary in this proceeding.  Dated this 3rd day of August 2026. \n \n/s/ Matthew Garber \n \n \n  \nMatthew Garber \nMcNees Wallace & Nurick LLC  \n100 Pine Street \nHarrisburg, PA 17101 \nPhone/Fax: (717) 237-5433  \nE-mail:  mgarber@mcneeslaw.com"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":5,"endAt":0,"startToken":0,"endToken":891},{"p":5,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":5,"endAt":467,"startToken":891,"endToken":958}]}