The Ohio Consumers' Counsel submits Protest and Request for Rejection of Filing or in the Alternative for Evidentiary Hearings and/or Settlement Proceedings re PJM Interconnection, L.L.C.’s Reliability Backstop Procurement filing
Read topic-matched comments in ER26-3380
Topics in the text: Reliability and curtailment · Cost allocation · Registry access
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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION PJM Interconnection, L.L.C. ) Docket No.Read this passage
I. BACKGROUND
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I.Read this passage
BACKGROUND
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It also asserts that the shortfall in capacity cleared to meet the resource adequacy needs of the region has grown for each of the past three RPM auction Delivery Years, which includes the 2028/2029 Delivery Year auction, run in July of this year.8 PJM proposes to implement a one-time auction along…Read this passage Filed comments: Cost allocation
II. PROTEST
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While there are additional matters pending or contemplated to implement specific data center load tariffs for American Transmission Systems, Inc., Dayton Power and Light Company and Duke Energy Ohio, to date the PUCO has not adopted orders establishing programs for these utilities. 7 generating…Read this passage Filed comments: Cost allocation
A. PJM’s RBP proposal will not ensure just, reasonable rates for consumers;
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Additionally, PJM argues that its proposed “maximum willingness-to-pay cap” will provide “a direct limit on procurement costs even in the absence of offer mitigation.”28 PJM proposes to set the cap at the maximum price for the existing RPM auctions of $555/MW/day, arguing that this mitigates market…Read this passage Filed comments: Cost allocation
B. The RBP proposal will unjustly and unreasonably leave existing consumers
printed heading · Topic match: Reliability and curtailment
Allowing those costs to be transferred to load essentially just shifts the risk that a generating resource will be commercially operational to the parties with no control over those operations, i.e., the loads that must bear the costs of the power to be generated.Read this passage Filed comments: Reliability and curtailment
C. The IMM proposed approach to resource adequacy in PJM will ensure
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This in turn better comports with the Seventh Circuit’s cost allocation mandate that costs must be allocated in a manner roughly commensurate with cost causation and beneficiaries of the proposed new infrastructure.52 Unlike the PJM RBP proposal, the IMM RBP proposal provides no loopholes for new…Read this passage Filed comments: Cost allocation
III. CONCLUSION
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III.Read this passage
CONCLUSION
printed heading · Topic match: Reliability and curtailment
CONCLUSION FERC may accept or reject a utility filing under section 205 of the Federal Power Act, 16 U.S.C. 824d, depending on whether the utility has demonstrated that its proposal is just, reasonable, and not unduly discriminatory or preferential.59 However, as PJM notes in its RBP Application,…Read this passage Filed comments: Reliability and curtailment
CERTIFICATE OF SERVICE
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Dated in Columbus, Ohio this 21st day of August, 2026. /s/ Denise C.Read this passage