Motion to Intervene and Protest of the Data Center Coalition to PJM Interconnection, L.L.C.’s proposal to establish Interim Resource Adequacy Service and a Large Load Registry
Read topic-matched comments in ER26-3515
Topics in the text: Reliability and curtailment · Cost allocation · Retail and wholesale authority
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Source sections
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Opening text
opening text · Topic match: Registry access
ER26-3515-000 ) MOTION TO INTERVENE AND PROTEST OF THE DATA CENTER COALITION Pursuant to Rules 211, 212, and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”)1 and the Commission’s August 13, 2026 Combined Notice of Filings #2,2 the…Read this passage Filed comments: Registry access
I. INTRODUCTION
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I.Read this passage
INTRODUCTION
printed heading · Topic match: Reliability and curtailment
But Congress’s decision to reserve to the states authority over retail service means that it is the states that must take the lead in developing the retail service frameworks through which new large loads are integrated into the electric system, including the rules governing the priority of…Read this passage Filed comments: Reliability and curtailment
II. PROTEST
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II.Read this passage
A. IRAS Unlawfully Intrudes On State Authority Over Retail Sales
printed heading · Topic match: Reliability and curtailment
Learjet, Inc., 575 U.S. 373, 385 (2015). - 9 - Commission must examine what IRAS actually does in practice.Read this passage Filed comments: Reliability and curtailment
B. IRAS Is Unjust, Unreasonable, Unduly Discriminatory, And Inconsistent
printed heading · Topic match: Reliability and curtailment
Curtailing Load That Pays For Demand Response Before Calling Upon Demand Response Is Inconsistent With Cost Causation Requirements The Commission and the courts have recognized that the FPA’s “just and reasonable” standard incorporates a cost causation principle.56 The cost causation principle…Read this passage Filed comments: Reliability and curtailment
C. IRAS Fails To Account For Existing Contractual Arrangements And Reliance
printed heading · Topic match: Reliability and curtailment
While long overdue, PJM’s transition away from a legacy serial process includes the unfortunate feature of pausing study of all new interconnection requests while PJM implements its new, faster process.”). - 33 - demonstrate,92 this timeline does not provide a realistic opportunity for New Large…Read this passage Filed comments: Reliability and curtailment
D. The Commission Should Reject IRAS Or Impose A Meaningful Transition
printed heading · Topic match: Retail and wholesale authority
Alternatively, if the Commission determines based on the record in this proceeding that PJM’s emergency procedures must be reformed immediately, then it should initiate a Section 206 proceeding to determine how PJM’s emergency procedures can be modified to mitigate reliability risks without…Read this passage Filed comments: Retail and wholesale authority
III. MOTION TO INTERVENE
printed heading · Topic match: Cost allocation
DCC advocates for grid reforms that minimize unnecessary cost burdens, align with cost causation principles, facilitate responsible load growth, support the development of new generation, and enhance grid resilience system-wide without imposing undue costs on existing ratepayers.Read this passage Filed comments: Cost allocation
IV. CORRESPONDENCE AND COMMUNICATIONS
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CORRESPONDENCE AND COMMUNICATIONS DCC requests that the following names be placed on the official service list for this proceeding by the Commission and that all correspondence and communications with respect to this proceeding be addressed to the following:96 Morgan A.Read this passage
V. CONCLUSION
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CONCLUSION
printed heading · Topic match: Reliability and curtailment
These model tariffs would: ● Establish standardized retail tariff provisions under which large customers may receive interruptible service, whether through voluntary election or pursuant to state regulatory requirements; ● Define the operational expectations, customer obligations, and utility…Read this passage Filed comments: Reliability and curtailment
Conclusion
printed heading · Topic match: Reliability and curtailment
Cost causation rationale is weak. 9 Arbitrary Outcomes Created by Vintage Cutoff dates create arbitrary results that are not based on load magnitude or system impact. 10 Protection is Not Assured The Claimed Benefit of BYONC Is Outside PJM’s Control Protection Must Be Real • PJM cannot dictate…Read this passage Filed comments: Reliability and curtailment
CERTIFICATE OF SERVICE
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Dated at Washington, D.C., this 3rd day of September 2026. /s/ Stephen J.Read this passage