EL26-67-000 · 2026-08-03 · PJM Industrial Customer Coalition

Answer in Support of the PJM Industrial Customer Coalition to the Motions for Extension and Abeyance by PJM Interconnection, L.L.C

UNITED STATES OF AMERICA 
BEFORE THE  
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
PJM Interconnection, L.L.C.  
 
 
) 
 
Docket No. EL25-49-002 
) 
 
Docket No. EL25-49-000 
 
 
 
 
 
 
 
) 
Large Loads Co-Located at Generating Facilities 
)  
 
Docket No. AD24-11-001 
 
 
 
 
 
 
 
) 
Constellation Energy Generation, LLC 
 
) 
 
v. 
 
 
 
 
 
) 
 
Docket No. EL25-20-001 
PJM Interconnection, L.L.C.  
 
 
) 
 
(Consolidated) 
 
 
 
 
 
 
 
) 
PJM Interconnection, L.L.C.  
 
 
) 
 
Docket No. ER26-1479-000 
 
 
 
 
 
 
 
) 
PJM Interconnection, L.L.C.  
 
 
) 
 
Docket No. EL26-67-000 
 
 
ANSWER IN SUPPORT OF 
THE PJM INDUSTRIAL CUSTOMER COALITION 
TO THE MOTIONS FOR EXTENSION AND ABEYANCE 
BY PJM INTERCONNECTION, L.L.C. 
 
Pursuant to Rule 213 of the Federal Energy Regulatory Commission (“Commission”) 
Rules of Practice and Procedure and the requests for a shortened answer period of PJM 
Interconnection, L.L.C. (“PJM”),1 PJM Industrial Customer Coalition (“PJMICC”) hereby files 
this Answer in support of PJM’s Motion for Extension of Time for Specified Compliance 
Requirements and Request for Expedited Treatment of PJM Interconnection, L.L.C. in Docket No. 
EL25-49, et al. (“Co-Located Load Extension Motion”) and Motion of PJM Interconnection, 
L.L.C. to Hold Proceeding in Abeyance and Request For Shortened Answer Period and Expedited 
Treatment in Docket No. EL26-67 (“Large Load Abeyance Motion”), both of which were filed on 
 
1 See 18 C.F.R. § 385.213.

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July 28, 2026.2 These Motions both request that the Commission extend certain PJM filing 
deadlines by 90 days.  
In its Co-Located Load Extension Motion, PJM explains: “The compliance changes 
directed in this proceeding significantly relate to or overlap with the directives in the Large 
Load Order in three major areas: expansion of new transmission services, study procedures, and 
operational requirements.”3 To facilitate the stakeholder process and to allow for coordination on 
the Co-Located Load docket and the Large Load docket, PJM seeks a parallel ninety-day extension 
for both proceedings, which will result in filings by mid-November.4 
PJM further states: 
Given the interrelated nature of a number of the other requirements in the 
Compliance Order and Large Load Order, a coordinated approach on the 
remaining compliance matters is appropriate for consistency and efficiency.  
As noted above, both orders require PJM to propose Tariff changes to address the 
study procedures to interconnect Co-Located/Large Loads, make new transmission 
services available for customers that are willing and able to limit their withdrawals, 
and specify operational requirements for Co-Located/Large Loads. PJM proposes 
to address these interrelated requirements in a suite of filings to be submitted by 
early to mid-November following a period of intensive stakeholder engagement and 
feedback.5  
 
PJMICC agrees with PJM’s proposed approach, which facilitates administrative 
efficiencies and helps consolidate stakeholder and party resources and work efforts.6 PJMICC 
 
2 Also on July 28, 2026, certain PJM Transmission Owners (“Indicated Transmission Owners”) filed parallel 
pleadings: (1) Motion for Extension of Compliance Deadline of the Indicated PJM Transmission Owners and Request 
for Expedited Action and Shortened Comment Period in Docket No. EL25-49, et al.; and (2) Motion for Abeyance of 
the Indicated PJM Transmission Owners and Request for Expedited Action and Shortened Comment Period in Docket 
No. EL26-67. PJMICC also supports the requests of the Indicated Transmission Owners for extension and abeyance, 
respectively, until November 16, 2026. 
3 Co-Located Load Extension Motion at 4 (emphasis added). 
4 Id. at 6. PJM also pledges to complete a partial compliance filing by August 17, 2026. Id. 
5 Id. at 7-8 (emphasis added). 
6 See Motion for Extension of Compliance Deadline of the Indicated PJM Transmission Owners, Docket No. EL25-
49 et al., at 7 (emphasizing the importance of coordination to ensure Commission review of proposed reforms “in a 
coherent and administratively efficient fashion.”).

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believes that such a 90-day time frame is proportionate to the reforms the Commission is pursuing. 
The Commission, PJM, and many stakeholders have been working hard to ensure all stakeholder 
voices and perspectives are considered. Many of these participants have raised nuanced but 
important issues that include significant downstream effects of the Commission’s major orders in 
these dockets. To execute on the Commission’s reforms in a logical, coherent, and durable manner, 
these nuanced issues must be addressed thoroughly and carefully in a coordinated fashion.  
In summary, PJMICC agrees with PJM that the above-captioned proceedings raise 
complex issues that are necessarily interrelated and that require significant analysis. In pursuit of 
durable final orders that provide the industry with regulatory stability and clear direction toward 
investment, growth, and resource adequacy, PJM’s plan to ensure robust discussion within the 
PJM stakeholder process—and adequate time to ensure both proceedings are complementing and 
not contradicting one another—is reasonable. Even a 90-day extension is still potentially an 
aggressive timeline, but it better strikes the balance between the FERC’s urgent call for reforms 
and the need for time to create a durable compliance filing. PJMICC therefore respectfully requests 
that the Commission grant PJM’s Co-Located Load Extension Motion and Large Load Abeyance 
Motion.

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WHEREFORE, the PJM Industrial Customer Coalition supports PJM Interconnection, 
L.L.C.’s Co-Located Load Extension Motion and Large Load Abeyance Motion and respectfully 
requests that the Commission grant those Motions in an expedited fashion. 
 
 
 
 
 
 
Respectfully submitted, 
McNEES WALLACE & NURICK LLC 
/s/  Matthew L. Garber 
By______________________________ 
Susan E. Bruce 
Kenneth R. Stark 
Matthew Garber 
McNees Wallace & Nurick LLC 
100 Pine Street 
Harrisburg, PA 17101 
Phone/Fax:  (717) 237-5254 
E-mail:  sbruce@mcneeslaw.com 
              kstark@mcneeslaw.com  
              mgarber@mcneeslaw.com  
 
Counsel to PJM Industrial Customer Coalition 
 
Dated:  August 3, 2026

CERTIFICATE OF SERVICE 
 
 
I hereby certify that I have this day served, via first-class mail, electronic transmission, or 
hand-delivery, the foregoing upon each person designated on the official service list compiled by 
the Secretary in this proceeding.  Dated this 3rd day of August 2026. 
 
/s/ Matthew Garber 
 
 
  
Matthew Garber 
McNees Wallace & Nurick LLC  
100 Pine Street 
Harrisburg, PA 17101 
Phone/Fax: (717) 237-5433  
E-mail:  mgarber@mcneeslaw.com