EL26-67-000 · 2026-08-03 · Silver Run Electric, LLC

Motion for Abeyance and Request for Shortened Answer Period and Expedited Treatment of Silver Run Electric, LLC

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
PJM Interconnection, L.L.C., et al. 
 
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) 
) 
) 
Docket No. EL26-67-000 
MOTION FOR ABEYANCE AND REQUEST FOR SHORTENED ANSWER PERIOD 
AND EXPEDITED TREATMENT OF  
SILVER RUN ELECTRIC, LLC 
I. 
INTRODUCTION 
Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“FERC” or 
“Commission”) Rules of Practice and Procedure,1 Silver Run Electric, LLC (“Silver Run”) 
respectfully submits this Motion for Abeyance in response to the Order Instituting Proceeding 
Under Section 206 of the Federal Power Act, issued in the above-captioned proceeding on June 
18, 2026.2  Silver Run seeks a 90-day full abeyance of the current 60-day deadline to respond to 
all issues raised in the Show Cause Order so that Silver Run may have the additional time 
coordinate with PJM Interconnection, L.L.C. (“PJM”) and relevant stakeholders to prepare an 
FPA section 205 filing.  Silver Run further requests that the Commission shorten the answer 
period for this Motion to five days and issue an order on this Motion by August 13, 2026, so that 
Silver Run will have certainty regarding its obligations in advance of the August 17, 2026 
deadline to respond to the Show Cause Order. 
 
1 
18 C.F.R. § 385.212 (2025). 
2  PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026) (“Show Cause Order”).

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Silver Run appreciates the Commission’s attention and guidance on issues relating to the 
interconnection of large loads, including data centers, to the FERC-jurisdictional transmission 
system.  Silver Run believes the potential tariff changes discussed in the Show Cause Order may 
provide opportunities for PJM and the transmission owning members of PJM (“PJM TOs”) to 
integrate large loads efficiently and further protect ratepayers across the PJM region from 
transmission-related costs associated with speculative requests or large-load additions that do not 
materialize as planned.  Silver Run also agrees that speed to interconnection should be a priority 
as the stakeholders work through this process.  Silver Run respectfully moves to hold the 
obligation to respond to the Show Cause Order in abeyance in order to allow PJM and the PJM 
TOs sufficient time to ensure the proposed tariff revisions are workable, transparent, and 
responsive to the Commission’s identified areas of concern. 
II. 
ARGUMENT 
In the Show Cause Order, the Commission states that it will consider requests for 
abeyances of up to 90 days, which should include both (1) a robust description of the content of a 
potential future filing under FPA section 205 and (2) a reasoned and specific explanation of 
when such a filing is expected to be made.3 
Silver Run seeks additional time to ensure it can develop comprehensive, coordinated 
tariff amendments in accordance with the Commission’s directives.  The issues the Commission 
has raised are complex and substantial.  Addressing the Show Cause Order will require 
substantial revisions to the PJM Open Access Transmission Tariff (“Tariff”)—potentially 
including new pro forma contract(s)—and the incorporation of study and application processes 
tailored to the provision of transmission service to Eligible Customers on behalf of large loads.  
Silver Run must therefore closely coordinate with PJM and other PJM TOs as the parties draft 
new provisions and, as applicable, revise existing provisions.  PJM is separately seeking an 
abeyance to engage in its stakeholder process, which requires a corresponding motion for 
 
3  Id. P 39.

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abeyance for the PJM TOs.  Accordingly, Silver Run seeks an abeyance until November 16, 
2026,4 for it to submit its response to the Show Cause Order.5 
A. 
Proposed Tariff Revisions 
The Show Cause Order sets out four preliminary findings.  Because the Commission is 
addressing its concerns related to co-located load in the separate and ongoing FPA section 206 
proceeding in Docket No. EL25-49-000, the Show Cause Order is limited to the integration of 
large loads that are not co-located with generation, and it accordingly makes no preliminary 
finding regarding the rates, terms, and conditions of service that apply to co-location 
arrangements.6  First, the Commission preliminarily found that the PJM Tariff appears to be 
unjust and unreasonable because it lacks provisions that address, with sufficient clarity and 
consistency, how PJM and/or the Transmission Owners will timely study — that is, within 60 to 
90 days of receiving the request — the provision of transmission service to Eligible Customers 
on behalf of large loads.7  The Show Cause Order directs PJM and the Transmission Owners, to 
the extent the matters addressed implicate aspects of the Tariff over which they hold the filing 
rights, either to explain whether the Tariff remains just and reasonable without an application 
process, study procedures, and ongoing operational requirements that address the unique 
 
4  Ninety (90) days from the response deadline is Sunday, November 15, 2026, and, therefore, such time 
period should end on November 16, 2026.  See 18 C.F.R. § 385.2007(a)(2) (stating that the last day of 
any time period is included in the time period, unless it is a Saturday or Sunday). 
5  At this time, Silver Run anticipates a single filing by PJM, in coordination with the other PJM TOs, 
will be submitted in response to the Show Cause Order.  It may be necessary, however, for each 
FERC-jurisdictional transmission owner to submit supplemental filings in response to some of the 
briefing questions included in the Show Cause Order. 
6 
Show Cause Order, 195 FERC ¶ 61,211 at P 2; see also id. PP 3, 35 (directing PJM and the 
Transmission Owners to address four enumerated subject areas). 
7 
Id. P 41. The Commission identified four component deficiencies: the absence of a definition of large 
load, of an application process and study procedures, of ongoing operational requirements, and of pro 
forma provisions in a transmission service agreement memorializing those requirements. Id. PP 57-
65.

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characteristics and challenges of providing transmission service to Eligible Customers on behalf 
of large loads, or to propose appropriate Tariff revisions.8 
Second, the Commission preliminarily found that the Tariff appears to be unjust and 
unreasonable because it lacks adequate mechanisms to mitigate the risk of cost shifting among 
transmission customers, specifically (1) transparency regarding the assignment of Network 
Upgrades, and their associated costs, that are needed to provide transmission service to Eligible 
Customers on behalf of large loads, and (2) a pro forma cost recovery agreement among PJM, 
the relevant transmission owner, and the Eligible Customer taking transmission service on behalf 
of large loads that helps ensure that Eligible Customers bear the risk of, and are ultimately 
responsible for, the costs incurred to provide that service.9  The Commission further stated that it 
appears reasonable for filers of formula rates to provide a separate workpaper in the annual 
informational filing describing how payments made pursuant to such an agreement are reflected 
in the transmission owner’s transmission formula rate.10 
Third, the Commission preliminarily found that the Tariff appears to be unjust and 
unreasonable because it does not include transmission services that reflect Eligible Customers 
taking transmission service on behalf of flexible large loads that are willing and able to limit 
their use of the transmission system under certain conditions, and identified non-firm interim 
network integration transmission service and permanent firm and non-firm contract demand 
transmission service as the services whose absence PJM must address.11 
Fourth, the Commission preliminarily found that the Tariff appears to be unjust and 
unreasonable because it does not contain provisions allowing an interconnection customer to 
seek the generator interconnection service or services that reflect the operational dynamics of 
serving either an electrically proximate large load or a co-located load, as defined in the PJM Co-
 
8  Id. P 43. 
9  Id. P 66; see also id. PP 71, 76-77, 81. 
10  Id. P 84. 
11  Id. PP 85-87.

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Location Order,12 with a high peak load, meaning a co-located load of 50 MW or greater.13  The 
Show Cause Order separately directs PJM alone, and not the Transmission Owners, to submit an 
informational report addressing resource adequacy to serve new large loads.14 
The issues for PJM and PJM TOs to address are interconnected; therefore, successful 
FPA section 205 filings will require significant coordination among PJM, the PJM TOs, and 
other stakeholders, such as state regulators.  Silver Run understands that PJM plans to file 
responsive tariff amendments in November (assuming its abeyance request is granted), and PJM 
TOs’ cooperation in developing this proposal is vital.  For example, the roles, responsibilities, 
and processes to interconnect and serve large loads taking new types of transmission services 
will likely be dependent on modifications to existing services under the PJM Tariff.  PJM-
specific regional differences must also be considered. 
Through the stakeholder process, Silver Run expects to propose revisions to the Tariff 
and related agreements addressing the application process, study procedures, and ongoing 
operational requirements applicable to Eligible Customers seeking transmission service on behalf 
of large loads.  Those revisions are expected to concern, among other matters, the definition of a 
large load; readiness and information requirements; the evaluation of alternative transmission 
technologies; a pro forma service agreement memorializing operational terms; transparency; cost 
recovery, associated financial security, and rate treatment provisions intended to mitigate cost 
shifting among transmission customers; and a reasonable implementation period and effective 
date designed to minimize disruption to existing commercial arrangements.  These matters 
remain under development and may evolve through coordination with PJM and stakeholders.  
Silver Run will coordinate with PJM and complete internal approvals that may be necessary in 
time to comply with the Commission’s directives by November 16, 2026. 
 
12  See PJM Interconnection, L.L.C., 193 FERC ¶ 61,217 (2025) (“PJM Co-Location Order”). 
13  Show Cause Order, 195 FERC ¶ 61,211 at P 95. 
14  Id. PP 4, 36, 102, 104.

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B. 
Briefing Questions 
The Commission also identifies several issues for further briefing.15  Silver Run 
understands that, if the Commission grants the requested full abeyance, the deadline to respond 
to the briefing questions will likewise be held in abeyance.16  Silver Run believes an abeyance is 
appropriate as to the briefing questions as they are wholly interrelated with the issues to be 
addressed in the forthcoming FPA section 205 filing, as described above. 
III. 
REQUEST FOR SHORTENED ANSWER PERIOD AND EXPEDITED 
TREATMENT 
Silver Run respectfully requests that the Commission shorten the answer period for this 
Motion to five days and grant expedited treatment so that it may issue an order on this Motion by 
August 13, 2026.  Rule 213(d)(1) of the Commission’s Rules of Practice and Procedure provides 
that an answer to a motion must be made within 15 days after the motion is filed unless the 
Commission orders otherwise.17  The Commission should order otherwise here, for three 
reasons. 
First, a shortened answer period and expedited action will provide regulatory certainty in 
advance of a deadline that is now imminent.  The Show Cause Order directs PJM and the PJM 
TOs to respond within 60 days of issuance, which is August 17, 2026—14 days from the date of 
this filing.18  If the ordinary 15-day answer period applies, the Commission will not be in a 
position to rule on this Motion until after Silver Run’s response is already due.  Silver Run would 
then be required to divert resources to preparing a merits response to the Show Cause Order 
rather than to the coordinated work with PJM and stakeholders that is necessary to produce the 
 
15  Id. Section IV. 
16  Id. P 39 (stating that “the deadline to respond to this order” for “all or certain aspects of this FPA 
section 206 proceeding” will be held in abeyance for up to 90 days upon a successful petition by a 
transmission owner). 
17  18 C.F.R. § 385.213(d)(1). 
18  Show Cause Order, 195 FERC ¶ 61,211 at P 35 & Ordering Para. (B).  Sixty days from the June 18, 
2026 issuance date is Monday, August 17, 2026.

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contemplated FPA section 205 filing.  The need for certainty is heightened here, because the 
Commission has emphasized that it will not grant abeyances reflexively.19 
Second, interested entities have been on notice of the need to respond to abeyance 
requests promptly.  The Commission expressly contemplated such requests in the Show Cause 
Order and directed that they be submitted within 45 days of issuance so as to allow the 
Commission time to act on them.20  Because the Commission itself contemplated that an 
abeyance request could be filed as late as 15 days before the response deadline, any entity with 
an interest in this proceeding has been on notice since June 18, 2026, that it would need to 
respond to such a request on an expedited basis.  A five-day answer period is therefore consistent 
with the schedule the Commission established and will not prejudice any participant.21 
Third, expedited action will promote administrative efficiency.  PJM has separately 
requested that the Commission hold this proceeding in abeyance.22  The two requests are 
interrelated.  Silver Run’s ability to develop and submit an FPA section 205 filing depends on 
the outcome of the PJM stakeholder process that PJM’s request is designed to accommodate, and 
Silver Run does not administer a stakeholder process of its own through which the issues raised 
in the Show Cause Order could be resolved independently.  Ruling on both requests together as 
closely as practicable, and in advance of the August 17, 2026 deadline, will avoid the prospect 
that Silver Run is held to a merits deadline while the regional process on which its FPA section 
205 filing depends remains underway. 
 
19  Id. P 39. 
20  Id.  The Commission directed that requests for a full or partial abeyance be submitted “within 45 days 
of issuance of this order, to allow time for the Commission to act on the abeyance request.”  Id.  45 
days from June 18, 2026 was Sunday, August 2, so under Rule 2007 of the Commission’s regulations, 
this Motion, filed August 3, is timely.  18 C.F.R. § 385.2007(a)(1)-(2). 
21  Five days from the August 3, 2026 filing date is Saturday, August 8, 2026, which Rule 2007 moves to 
Monday, August 10, 2026.  Id. § 385.2007(a)(1)-(2). 
22    Motion of PJM Interconnection, L.L.C. to Hold Proceeding in Abeyance and Request for Shortened 
Answer Period and Expedited Treatment, Docket No. EL26-67-000, at 8-10 (July 28, 2026) 
(requesting a five-day answer period and an order by August 6, 2026).

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IV. 
CONCLUSION 
For the reasons described above, Silver Run respectfully requests that the Commission (i) 
grant this Motion and hold this proceeding in abeyance for 90 days beginning August 17, 2026, 
and extend Silver Run’s deadline to respond in full to the Show Cause Order to November 16, 
2026; (ii) shorten the answer period for this Motion to five days; and (iii) grant expedited 
treatment and issue an order on this Motion by August 13, 2026.   
 
Respectfully submitted, 
 
/s/ Blake R. Urban 
Blake R. Urban 
Senior Regulatory Counsel 
16150 Main Circle Drive, Suite 310 
Chesterfield, MO 63017 
Telephone: 
(636) 231-0475 
Email:  
burban@lspower.com 
Attorney for 
Silver Run Electric, LLC 
 
 
Dated: August 3, 2026

CERTIFICATE OF SERVICE 
Under Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 
385.2010 (2025), I hereby certify that I have this day served the foregoing MOTION FOR 
ABEYANCE AND REQUEST FOR SHORTENED ANSWER PERIOD AND 
EXPEDITED TREATMENT OF SILVER RUN ELECTRIC, LLC upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
Dated at Silver Spring, Maryland, this 3rd day of August 2026. 
 
/s/ Seth Yeazel 
Seth Yeazel 
Associate Regulatory Counsel 
LS Power Development, LLC 
16150 Main Circle Drive, Suite 310 
Chesterfield, MO 63017 
Tel: (240) 904-5109 
syeazel@lspower.com