EL26-67-000 · 2026-08-07 · Corporate Energy Buyers Association

Answer of Corporate Energy Buyers Association in support of PJM Interconnection, L.L.C.'s et al. 07/28/2026 Motion for Abeyance

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
PJM Interconnection, L.L.C., et al. 
) 
Docket No. EL26-67-000 
 
ANSWER OF CORPORATE ENERGY BUYERS ASSOCIATION  
IN SUPPORT OF THE MOTIONS FOR ABEYANCE 
 
Pursuant to Rule 213 of the Federal Energy Regulatory Commission’s (Commission) 
Rules of Practice and Procedure,1 Corporate Energy Buyers Association (CEBA) respectfully 
submits this Answer in support of the motions for abeyance submitted separately by PJM 
Interconnection, L.L.C. (PJM),2 Indicated PJM Transmission Owners,3 and Silver Run Electric, 
LLC4 (collectively, Movants). Movants ask the Commission to hold this proceeding in abeyance 
by 90 days and, in so doing, extend certain deadlines for responding to the June 18, 2026 Order 
to Show Cause (Show Cause Order).5 
The issues raised in the Show Cause Order raise complex and substantial issues that 
require due consideration to craft solutions that are appropriately tailored to the region. Granting 
the requested abeyance will promote administrative efficiencies by allowing time for PJM and 
stakeholders—including CEBA and its members—to work collaboratively, as opposed to a 
rushed proposal that would unnecessarily shift stakeholder debate to the Commission docket. 
Lastly, the requested abeyance also strikes an appropriate balance: a 90-day extension would not 
materially impede the Commission’s objectives for advancing reforms quickly yet offers 
 
1 18 C.F.R. § 385.213. 
2 PJM July 28, 2026 Motion for Abeyance. 
3 Indicated PJM Transmission Owners July 28, 2026 Motion for Abeyance. 
4 Silver Run Electric, LLC August 3, 2026 Motion for Abeyance. 
5 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026).

2 
 
significant benefits in terms of enabling proposals to receive sufficient stakeholder feedback to 
promote both commercial viability and legal durability of the proposals that PJM and the PJM 
transmission owners will file in mid-November. 
For these reasons, CEBA respectfully requests that the Commission grant these motions 
in an expedited manner. 
 
Respectfully submitted, 
 
 
/s/ John Miller___________________ 
John Miller 
Director, Transmission Policy 
CEBA 
1501 M Street, N.W., Suite 900 
Washington, D.C. 20005 
(240) 630-2201 
jmiller@ceba.org 
 
Bryn Baker 
Senior Director, Organized Markets Policy 
CEBA 
1501 M Street, N.W., Suite 900 
Washington, D.C. 20005 
bbaker@ceba.org  
 
August 7, 2026

CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary of the Commission in this 
proceeding. 
Dated at Washington, D.C., this 7th day of August 2026. 
/s/ John Miller___________________ 
John Miller 
Director, Transmission Policy 
CEBA 
1501 M Street, N.W., Suite 900 
Washington, D.C. 20005 
(240) 630-2201 
jmiller@ceba.org