ER26-3380-000 · 2026-08-14 · PJM Interconnection, L.L.C.
PJM Interconnection, L.L.C. submits tariff filing per : Supplemental Filing of Croop Affidavit in ER26-3380 to be effective N/A
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PJM Interconnection, L.L.C.
2750 Monroe Blvd.
Audubon, PA 19403-2497
Chenchao Lu
Associate General Counsel
T: (610)-500-3245
Chenchao.Lu@pjm.com
August 14, 2026
Honorable Debbie-Anne A. Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.,
Washington, D.C. 20426
Re:
Supplemental Filing in PJM Interconnection, L.L.C., Docket No. ER26-3380-000
Dear Secretary Reese:
PJM Interconnection, L.L.C. (“PJM”) submits this supplemental affidavit of Danielle
Croop to provide a more complete example of the selection process detailed in the June 30, 2026
affidavit. Specifically, it has come to PJM’s attention that the example provided in Exhibit 1 of
Mrs. Croop’s June 30, 2026 affidavit did not accurately demonstrate the least cost selection by
Delivery Year for offers submitted in the proposed Reliability Backstop Procurement. Therefore,
to provide the Commission and any interested parties with a more fulsome example, PJM submits
the attached supplemental affidavit that further demonstrates how PJM would select resource
offers based on least costs while prioritizing in service dates during the selection process.
Notably, the supplemental affidavit merely updates the examples, also shown in redline,
that were included in Mrs. Croop’s June 30, 2026 affidavit and does not revise or amend a proposed
rate schedule, term, or condition. Indeed, the Commission has previously explained that
“supplements d[o] not constitute an amendment because the supplements d[o] not change the
proposed rates. . . .”1 As a result, this supplemental affidavit does not reset the clock for the
1 Union Elec. Co., 181 FERC ¶ 61,064, at P 40 (2022) (finding that MISO’s supplements did not constitute an
amendment because the supplements did not change the proposed rates that MISO filed).
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Honorable Debbie-Anne A. Reese, Secretary
August 14, 2025
Page 2
Commission to act on PJM’s June 30, 2026 filing as all parties were on notice of the proposed
rates, terms and conditions based on the June 30, 2026 filing.2 Accordingly, the Commission
should continue to issue an order by the requested action date of September 29, 2026.
Respectfully submitted,
/s/ Chenchao Lu
Craig Glazer
Vice President – Federal Government Policy
PJM Interconnection, L.L.C.
1200 G Street, N.W., Suite 600
Washington, D.C. 20005
(202) 423-4743 (phone)
(202) 393-7741 (fax)
Craig.Glazer@pjm.com
Chenchao Lu
Associate General Counsel
PJM Interconnection, L.L.C.
2750 Monroe Blvd.
Audubon, PA 19403
(610) 666-2255 (phone)
(610) 666-8211 (fax)
Chenchao.Lu@pjm.com
Counsel for
PJM Interconnection, L.L.C.
2 Sierra Pacific Power Co., 141 FERC ¶ 61,266, at P 39 (2012) (“Filings ... that do not revise a rate schedule, tariff,
or service agreement, but instead only add or revise supplemental materials submitted as part of the application are
considered on an individual basis to determine whether such changes are so significant that they would constitute an
amendment ....”); Miss. Power Co., 137 FERC ¶ 61,241, at P 23 (2011).
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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 in this proceeding.
Dated at Audubon, PA, this 14th day of August 2026.
/s/ Chenchao Lu
Chenchao Lu
Associate General Counsel
PJM Interconnection, L.L.C.
2750 Monroe Blvd.
Audubon, PA 19403
Chenchao.Lu@pjm.com
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Attachment A
Supplemental Affidavit of Ms. Danielle Croop,
Senior Manager in the Market Design group of
PJM Interconnection, L.L.C.
PDF page 5
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
PJM Interconnection, L.L.C.
)
Docket No. ER26-3380-000
)
SUPPLEMENTAL AFFIDAVIT OF DANIELLE CROOP
ON BEHALF OF PJM INTERCONNECTION, L.L.C.
1.
My name is Danielle Croop, Senior Manager in the Market Design group for PJM
Interconnection, L.L.C. (“PJM”). My business address is 2750 Monroe Blvd.,
Audubon, Pennsylvania, 19403. I am submitting this supplemental affidavit on
behalf of PJM to provide a clarifying example that better illustrates all components
of the commitment process which is: clearing in least-cost order while prioritizing
earlier Delivery Years and constraining the commitment by the maximum
willingness to pay.
2.
The example submitted under Exhibit No 1 from my June 30, 2026 affidavit was
focused on documenting the procurement approach of applying the maximum
willingness to pay and demonstrating how that constraint can impact the
procurement. However, in that example, the least cost selection by delivery year
was not demonstrated.
3.
This supplemental affidavit sponsors an updated exhibit, appended to my affidavit
as Exhibit 1 to illustrate three simplified examples that help demonstrate how the
Reliability Backstop Procurement selection process works. Separately, Exhibit 2
shows the redlines against the example that was originally included in my June 30,
2026 affidavit.
4.
In addition, the explanation in Step 2 of the example submitted under Exhibit No 1
from my June 30, 2026 affidavit regarding the calculation of the MW-weighted
average levelized cost incorrectly inverted the numerator and denominator. The
explanation has been revised in this supplemental affidavit to accurately reflect the
MW-weighted average levelized cost calculation set forth in the filing letter and
proposed tariff revisions.
PDF page 6
Exhibit 1
Appendix to Affidavit of Ms. Danielle Croop
Examples Demonstrating RBP Resource Procurement
Process
(Clean Version)
PDF page 7
EXHIBIT 1
Examples Demonstrating RBP Resource Procurement Process
In this example, each RBP Resource Sell Offer will include an offer price and MW quantity pair
for each Delivery Year beginning with the first year the resource is expected to reach
commercial operation. PJM will then determine the “levelized procurement cost” for this
resource to use in the selection process.1 This will be done with the Levelized Cost equation,
with a discount rate equal to 9.5% after-tax average weighted average cost of capital
(“ATWACC”).
Levelized Cost ($/MW-day) = Net Present Value (RBP Sell Offer price x UCAP offered)/Net
Present Value (UCAP offered)
Example 1
In the example below, Unit A offers at a price and a quantity for each Delivery Year of the 15-
year fixed term, beginning in Year 1 and ending in Year 15. This Offer has a levelized
procurement cost of $101.05/MW-day UCAP and a levelized MW value of 69.3 MW.
Example 1: Unit A, $/MW Offer per Year
Unit A
Price ($)
MW
Year 1
91
10
Year 2
91
10
Year 3
100
9
Year 4
100
9
Year 5
100
9
Year 6
100
9
Year 7
100
9
Year 8
110
8
Year 9
110
8
Year
10
110
8
1 Proposed TariƯ, Attachment DD, section 18.5(f)(ii); Croop AƯ. ¶ 29.
PDF page 8
4
Year
11
110
8
Year
12
110
8
Year
13
110
8
Year
14
110
8
Year
15
110
8
Example 2
Example 2 walks through how a set of offers are evaluated based on ranked Delivery Year and
levelized cost for selection. The selection process is also constrained to the maximum
willingness to pay of the procurement. For illustrative purposes, rather than a maximum
willingness to pay of $555/MW-day as PJM is proposing to use for the RBP, we assume that the
maximum willingness to pay is $100/MW-day, and the Final RBP Target for procurement is
6,800 MW.
Table 1 illustrates the UCAP MW offered through the first four Delivery Years and a represented
levelized cost offer for this resource. Table 1, below, tracks the MW that are procured to
determine when PJM satisfies the procurement target of 6,800 MW.
Table 1: Table updates include switch Offer 1 and 2 to reflect offers in rank-order for
selection and Offer 3 was updated to offer starting in the 2028/29 DY.
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5
Table 2 shows the offers in greater detail in determining the present value and levelized cost of
the offers. For each RBP Resource offer (Offers 1-8), there are three procurement values in the
NPV column. The first value for each RBP Resource offer is the levelized MW UCAP. The
second value is the levelized cost, expressed as $/MW-day. And the third value is the total
revenue cost stream based on the RBP Resource’s levelized MW and cost.
Table 2
The procurement process will prioritize earlier Delivery Years, while being constrained to the
fixed-budget maximum willingness to pay. This can result in: (1) an earlier Delivery Year
resource being skipped if it will violate the maximum willingness to pay constraint; (2) a
procurement of that resource later in the process, even if the resource was previously skipped, if
procurement of a lower-priced resource creates additional cost headroom in the budget; and/or
(3) a possibility that PJM will not procure the exact Final RBP Target quantity if doing so
violates the maximum willingness to pay constraint. These features are demonstrated below in
the selection sequencing example:
Step 1: Procure Offer 1. Offer 1 would be procured first in the commitment, given it has the
cheapest levelized cost in the delivery year. This will add the below MW value to the target for
each Delivery Year, with a MW-weighted average levelized costs of $50.
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6
Step 2: Procure Offer 2. This will increase our procurement by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.26.
The MW-weighted average levelized cost of $93.26 can be calculated from the PV column in
Table 2 as the sum of Revenue cost stream / sum of levelized MW. [932,200 + 72,645]/
[9,322+1,453].
Step 3: Skip Offer 3. If Offer 3 was selected the MW-weighted average levelized cost would rise
to $105.75, above the maximum willingness to pay of $100 MW/day.
Step 4: Procure Offer 4. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $80.50.
Step 5: Procure Offer 3. Offer 3 may now be procured while keeping the MW-weighted average
levelized cost under the maximum willingness to pay. Thus, the procurement will prioritize and
commit this resource with an earlier first Delivery Year. This will increase the procured MW by
the offered MW for each applicable Delivery Year, and result in a MW-weighted average
levelized cost of $90.71.
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7
Step 6: Procure Offer 5. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $90.63.
Step 7: Procure Offer 6. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.02.
At this point, the final target MW of 6,800 has been committed and the procurement is complete.
Offer 7 and 8 would not be procured through the RBP.
Example 3
In Example 3, the selection clears short of the Final RBP Target to maintain the maximum
willingness to pay. This example relies on the same example as above, except that offer prices
for Offers 6, 7, and 8 are dramatically increased.
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8
Table 3
The procurement process runs through Steps 1 through 6, as described in Example 2, above.
Then, following Step 6, the process begins to differ:
Step 6: Procure Offer 5, as in Example 2. This will increase the procured MW by the offered
MW for each applicable Delivery Year, and result in a MW-weighted average levelized cost of
$90.63.
At this point, Offers 6, 7 and 8 cannot be procured without violating the maximum willingness to
pay constraint. If Offer 6 were selected, the MW-weighted average levelized cost would rise to
$106.73 , which is above the maximum willingness to pay of $100 MW/day. Similar violations
of the maximum willingness to pay for Offers 7, and 8 would occur. Given that, in this example,
there are no additional offers to consider, the procurement would clear 100 MW short the target,
with the maximum UCAP MW procured equal to 6,700 MW for the 2031/32 Delivery Year.
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Exhibit 2
Appendix to Affidavit of Ms. Danielle Croop
Examples Demonstrating RBP Resource Procurement
Process
(Redlined Version)
PDF page 14
Croop, Exhibit No. 2
Page 1
Examples Demonstrating RBP Resource Procurement Process
The following examples are intended to demonstrate how RBP Resources will be procured
based on a maximum willingness to pay, defined as a “MW-weighted average of the levelized
procurement cost” for the RBP, and selected through a “budget approach.”1
In this example, Eeach RBP Resource Sell Offer will include an offer price and MW
quantity pair for each Delivery Year beginning with the first year the resource is expected to reach
commercial operation. PJM will then determine the “levelized procurement cost” for this resource
to use in the selection process.2 This will be done with the Levelized Cost equation, with a discount
rate equal to 9.5% after-tax average weighted average cost of capital (“ATWACC”).
Levelized Cost ($/MW-day) = Net Present Value (RBP Sell Offer price x UCAP
offered)/Net Present Value (UCAP offered)
Example 1
In the example below, Unit A offers at a price and a quantity for each Delivery Year of the
15-year fixed term, beginning in Year 1 and ending in Year 15. This Offer has a levelized
procurement cost of $101.0550/MW-day UCAP and a levelized MW value of 69.3 MW.
1 Proposed Tariff, Attachment DD, section 18.5(f)(ii); Croop Aff. ¶ 29.
2 Proposed Tariff, Attachment DD, section 18.5(f)(ii); Croop Aff. ¶ 29.
PDF page 15
Croop, Exhibit No. 2
Page 2
Example 1: Unit A, $/MW Offer per Year
Unit A
Price ($)
MW
Year 1
91
10
Year 2
91
10
Year 3
100
9
Year 4
100
9
Year 5
100
9
Year 6
100
9
Year 7
100
9
Year 8
110
8
Year 9
110
8
Year 10
110
8
Year 11
110
8
Year 12
110
8
Year 13
110
8
Year 14
110
8
Year 15
110
8
Example 2
Example 2 walks through how a set of offers are evaluated based on ranked Delivery Year
and levelized cost for selection. The selection process is also constrained to the maximum
willingness to pay of the procurement. For illustrative purposes, rather than a maximum
willingness to pay of $555/MW-day as PJM is proposing to use for the RBP, we assume that the
maximum willingness to pay is $100/MW-day, and the Final RBP Target for procurement is
6,800 MW.
Table 1 illustrates the UCAP MW offered through the first four Delivery Years and a
represented levelized cost offer for this resource. Table 1, below, tracks the MW that are procured
to determine when PJM satisfies the procurement target of 6,800 MW.
PDF page 16
Croop, Exhibit No. 2
Page 3
Table 1: Table updates include switch Offer 1 and 2 to reflect offers in rank-order for selection and Offer 3 was updated to offer
starting in the 2028/29 DY.
Table 2 shows the offers in greater detail in determining the present value and levelized cost of the
offers. For each RBP Resource offer (Offers 1-8), there are three procurement values in the NPV
column. The first value for each RBP Resource offer is the levelized MW UCAP. The second
value is the levelized cost, expressed as $/MW-day. And the third value is the total revenue cost
stream based on the RBP Resource’s levelized MW and cost.
PDF page 17
Croop, Exhibit No. 2
Page 4
Table 2
The procurement process will prioritize earlier Delivery Years, while being constrained to the
fixed-budget maximum willingness to pay. This can result in: (1) an earlier Delivery Year resource
being skipped if it will violate the maximum willingness to pay constraint; (2) a procurement of
that resource later in the process, even if the resource was previously skipped, if procurement of a
lower-priced resource creates additional cost headroom in the budget; and/or (3) a possibility that
PJM will not procure the exact Final RBP Target quantity if doing so violates the maximum
willingness to pay constraint. These features are demonstrated below in the selection sequencing
example:
Step 1: Procure Offer 1. Offer 1 would be procured first in the commitment, given it has
the cheapest levelized cost in the delivery year. This will add the below MW value to the target
for each Delivery Year, with a MW-weighted average levelized costs of $50 $100.
PDF page 18
Croop, Exhibit No. 2
Page 5
Step 2: Procure Offer 2. This will increase our procurement by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.26.
The MW-weighted average levelized cost of $93.26 can be calculated from the PV column in
Table 2 as the sum of levelized MW / sum of Revenue cost stream / sum of levelized MW.
[9,322+1,453]/[932,200 + 72,645]/ [9,322+1,453].
Step 3: Skip Offer 3. If Offer 3 was selected the MW-weighted average levelized cost
would rise to $105.75 $102.84, above the maximum willingness to pay of $100 MW/day.
Step 4: Procure Offer 4. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $80.50.
Step 5: Procure Offer 3. Offer 3 may now be procured while keeping the MW-weighted
average levelized cost under the maximum willingness to pay. Thus, the procurement will
PDF page 19
Croop, Exhibit No. 2
Page 6
prioritize and commit this resource with an earlier first Delivery Year. This will increase the
procured MW by the offered MW for each applicable Delivery Year, and result in a MW-weighted
average levelized cost of $90.71 $88.27.
Step 6: Procure Offer 5. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $90.63. $88.47.
Step 7: Procure Offer 6. This will increase the procured MW by the offered MW for each
applicable Delivery Year, and result in a MW-weighted average levelized cost of $93.02 $90.94
PDF page 20
Croop, Exhibit No. 2
Page 7
At this point, the final target MW of 6,800 has been committed and the procurement is complete.
Offer 7 and 8 would not be procured through the RBP.
Example 3
In Example 3, the selection clears short of the Final RBP Target to maintain the maximum
willingness to pay. This example relies on the same example as above, except that offer prices for
Offers 6, 7, and 8 are dramatically increased.
Table 3
The procurement process runs through Steps 1 through 65, as described in Example 2, above.
Then, starting following in Step 6, the process begins to differ:
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Croop, Exhibit No. 2
Page 8
Step 6: Procure Offer 5, as in Example 2. This will increase the procured MW by the
offered MW for each applicable Delivery Year, and result in a MW-weighted average levelized
cost of $90.63$88.47.
At this point, Offers 6, 7 and 8 cannot be procured without violating the maximum
willingness to pay constraint. If Offer 6 were selected, the MW-weighted average levelized cost
would rise to $106.73 $104.91, which is above the maximum willingness to pay of $100 MW/day.
Similar violations of the maximum willingness to pay for Offers 7, and 8 would occur. Given that,
in this example, there are no additional offers to consider, the procurement would clear 100 MW
short the target, with the maximum UCAP MW procured equal to 6,700 MW for the 2031/32
Delivery Year.
PDF page 22
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
PJM Interconnection, L.L.C.
) Docket No. ER26-3380-000
)
VERIFICATION
I, Danielle Croop, pursuant to 28 U.S.C. § 1746, state, under penalty of perjury, that I am
the Danielle Croop referred to in the foregoing document entitled “Affidavit of Danielle Croop,
on Behalf of PJM Interconnection, L.L.C.,” that I have read the same and am familiar with the
contents thereof, and that the facts set forth therein are true and correct to the best of my
knowledge, information, and belief.
/s/ Danielle Croop
Danielle Croop
Sr. Manager
Market Design
PJM Interconnection, L.L.C.