Protest, Motion to Reject, and Alternative Request for the Imposition of Conditions of Delaware Division of the Public Advocate et al
Read topic-matched comments in ER26-3380
Topics in the text: Cost allocation · Reliability and curtailment · Registry access
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Opening text
opening text · Topic match: Registry access
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION PJM Interconnection, L.L.C.Read this passage Filed comments: Registry access
SUMMARY
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This allocation to be developed by state commission or RERRA is given a name by PJM, the “RBP Obligation” (RBO).15 In the “unexpected event”16 that “RBOs are ultimately not reported to PJM,” PJM proposes that the costs for up to 15 years of capacity payments to zones/areas to which RBP cost…Read this passage Filed comments: Cost allocation
I. Protest
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RBP will saddle ratepayers with fifteen years of payments, even as PJM admits that the proposed commitment period is as much as a decade longer than the five-year bilateral procurements that will meet PJM’s reliability needs.Read this passage Filed comments: Cost allocation
A. RBP’s design is contrary to PJM’s assertion that the proposal is needed to address a reliability risk associated with a 6.8 GW capacity shortfall.
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Proposed Tariff Attachment DD, section 18.1(d) provides in part:35 The Initial RBP Target shall be further decremented, if requested by an Electric Distributor, by up to the associated MW quantity of load that participates in a peak shaving adjustment program where such Electric Distributor’s…Read this passage Filed comments: Cost allocation
B. PJM fails to demonstrate that 15-year resource commitments are needed to meet the capacity shortfall.
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Cir. 2023). 58 Id. 59 Id. at 857. - 17 - Although the foregoing demonstrates that the fifteen-year period is unjust and unreasonable, we note that it is also unduly discriminatory to require some ratepayers to pay for fifteen-year procurements when other ratepayers are insulated from RBP charges…Read this passage Filed comments: Cost allocation
C. The RBP fosters the exercise of seller-side market power and is unlikely to secure the least-cost combination of resources.
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It must be emphasized that Joint Consumer Advocates do not concede that the Reliability Pricing Model (RPM) is at present competitive or just and reasonable.Read this passage Filed comments: Registry access
D. The proposed $555/MW-Day cap price is excessive.
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But as used in the RBP, the $555/MW-day price is a soft price cap, meaning that ratepayers are subject to paying a selected resource’s “as bid” offer price—and are not protected by a fixed, $555/MW-day cap.Read this passage Filed comments: Cost allocation
E. The absence of locational criteria for RBP resource procurements poses unjustified cost risks for ratepayers.
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The absence of locational criteria for RBP resource procurements poses unjustified cost risks for ratepayers.Read this passage Filed comments: Cost allocation
II. Request for issuance of directive to pjm to implement one of two just and reasonable alternatives
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PJM proposes no counterpart provision to adjust the target forecast for known reductions in projected new large loads even as those forecasts have been rapidly and continuously plummeting. 107 Id. ¶ 8. 108 “The initial allocation of RBP UCAP MW to each Electric Distributor zone/area will be based…Read this passage Filed comments: Cost allocation
III. If the Commission declines to reject RBP, it should condition acceptance to address evident and substantial concerns.
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PJM’s assertions demonstrate that it is unjust and unreasonable to require ratepayers to bear procurement costs over a fifteen-year period.Read this passage Filed comments: Cost allocation
CONCLUSION
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It is self-contradictory, deeply flawed, and likely to result in significant and excessive costs to ratepayers that are “all pain and no gain.” As the stakeholder process made clear, the purported capacity shortfall and whatever reliability concerns it engenders can be addressed through far less…Read this passage Filed comments: Cost allocation
CERTIFICATE OF SERVICE
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Dated on this 21st day of August, 2026. /s/ Lauren L.Read this passage