ER26-3380-000 · 2026-08-21 · Data Center Coalition

Comments of the Data Center Coalition in response to PJM Interconnection, L.L.C.’s 07/31/2026 proposed tariff filing to establish the Reliability Backstop Procurement

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Topics in the text: Cost allocation · Reliability and curtailment · Connecting load and generation

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Opening text

opening text · Topic match: Cost allocation

DCC advocates for grid reforms that minimize unnecessary cost burdens, align with cost causation, 1 The Data Center Coalition is a membership organization of leading data center owners and operators.
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I. The Commission Should Preserve and Facilitate Bilateral Procurement of New Capacity

printed heading · Topic match: Reliability and curtailment

The objective should be straightforward: every MW of qualifying new capacity that a customer brings to PJM should receive appropriate recognition before PJM determines how much additional capacity must be procured through the backstop.
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II. RBP Costs Must Be Allocated to the Large Loads Driving the Need for New Capacity

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RBP Costs Must Be Allocated to the Large Loads Driving the Need for New Capacity DCC supports PJM taking action to address the full resource adequacy shortfall identified through the 2028/2029 Base Residual Auction.
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III. The RBP Can Support Reliability Only If Procured Resources Reach Commercial

printed heading · Topic match: Connecting load and generation

PJM must continue reducing study timelines, processing its interconnection queue, identifying necessary interconnection facilities and transmission upgrades, and providing generation developers sufficient certainty to finance and construct projects.
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IV. Conclusion

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For these reasons, DCC respectfully requests that the Commission accept PJM’s filing consistent with the principles discussed above.
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CERTIFICATE OF SERVICE

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Dated in Washington, D.C., on this 21st day of August, 2026. /s/ Morgan A.
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