ER26-3380-000 · 2026-08-19 · Illinois Commerce Commission

Comments of the Illinois Commerce Commission in support of PJM Interconnection, L.L.C.’s 07/31/2026 filing

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Topics in the text: Cost allocation · Registry access · Reliability and curtailment

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Opening text

opening text · Topic match: Reliability and curtailment

The ICC recommends that the Commission require sufficient mitigation efforts to protect against cost shifts to or any negative impacts on existing ratepayers, impose no new obligations upon the states, and require PJM to provide the clarifications, transparency, and access to data as discussed…
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I. COMMENTS

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I.
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A. The Core Elements of PJM’s Reliability Backstop Procurement Proposal are

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PJM proposes to “empower” states by imposing on them an obligation to “submit RBP RBOs, which PJM would then apply to the allocation of RBP Charges” to load serving entities (“LSEs”).5 Given the timing and the lack of implementation details, particularly for retail access states like Illinois,…
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B. PJM’s Proposal Requires Active Collaboration Between PJM and States

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PJM’s territory covers vastly different market structures and PJM’s proposals must work for all of them.
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II. CONCLUSION

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The ICC further requests any and all other appropriate relief.
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CERTIFICATE OF SERVICE

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Dated at Chicago, Illinois, this 19th day of August, 2026. /s/ Christine F.
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