Answer and Motion for Leave to Answer of the Independent Market Monitor for PJM Interconnection, L.L.C. to the Answer of PJM Interconnection, L.L.C. filed on 09/10/2026
Read topic-matched comments in ER26-3380
Topics in the text: Credit and exit · Cost allocation · Reliability and curtailment
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Opening text
opening text · Topic match: Reliability and curtailment
PJM states (September 10th Answer at 64): “It is fallacious to suggest that a just and reasonable cost allocation approach must either identify specific loads (which are not FPA- jurisdictional actors) and not the LSEs serving those loads or be limited to one type of load when the resource adequacy…Read this passage Filed comments: Reliability and curtailment
I. ANSWER
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I.Read this passage
A. PJM’s Reliance on “Cooperative Federalism” Is Misguided and Has Resulted in a Flawed and Incomplete Proposal.
PDF bookmark · Topic match: Cost allocation
The September 10th Answer defends (at 56–65) what it alleges is a “cost allocation approach” in the RBP Filing with references to “cooperative federalism.” The RBP Filing does not propose a cost allocation approach, it proposes to procure the 6,831.3 MW shortfall of capacity through a flawed…Read this passage Filed comments: Cost allocation
B. The September 10th Answer Fails to Address the Issues Raised by the Market Monitor and Others.
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The September 10th Answer Fails to Address the Issues Raised by the Market Monitor and Others.Read this passage
1. The Shortfall is Entirely the Result of Data Center Load.
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The Shortfall is Entirely the Result of Data Center Load.Read this passage
2. The Shortfall MW Value Is Not Correct and PJM Refuses to Correct It.
PDF bookmark · Topic match: Cost allocation
The argument that PJM seeks to evade is that PJM must support its 6,831.3 MW target, inherently a precise number, based on accurate and contemporaneous information.Read this passage Filed comments: Cost allocation
3. PJM Incorrectly Allocates Data Center Costs to EDCs/LSEs and Their Customers.
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PJM Incorrectly Allocates Data Center Costs to EDCs/LSEs and Their Customers.Read this passage
4. PJM Allocates Financial Risks Created by Data Centers to EDCs and Their Customers.
PDF bookmark · Topic match: Credit and exit
PJM proposes that RBP sellers provide collateral equal to 20 percent of the first three years of their RBP sell offers.50 Under assumptions consistent with the buyer side obligation derivation, namely that 1 MW is offered at $555 per MW-day, the RBP seller’s credit requirement is $121,545 per MW (3…Read this passage Filed comments: Credit and exit
5. PJM Ignores Fundamental Locational Market Requirements.
PDF bookmark · Topic match: Reliability and curtailment
However, this type of interconnection study cannot and does not 65 RBP Filing, Attachment A (Marked Tariff), Proposed OATT Attachment DD § 18.9(a). 66 See IMM Protest at 11; EKPC Protest at 31–33; JCA Protest at 28–29; AEP Protest at 29. 67 See PJM Answer at 60 n.179. - 27 - replace a local…Read this passage Filed comments: Reliability and curtailment
6. PJM’s Procurement Process is Flawed.
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The September 10th Answer asserts that because some commenters would like a higher number and some would like a lower number, that PJM must be correct.Read this passage
7. PJM’s Definitions of Capacity That Can Satisfy the Requirements to Meet Data Center Load are Inconsistent.
PDF bookmark · Topic match: Reliability and curtailment
The problem is that PJM proposes to treat RBP offset capacity as equivalent to RBP supply for 71 OATT Attachment DD § 16.4(e)(ii). - 30 - purposes of reducing the regional reliability requirement, even though the two have materially different contractual protections and performance obligations.Read this passage Filed comments: Reliability and curtailment
II. MOTION FOR LEAVE TO ANSWER
PDF bookmark · Topic match: Filing procedure
MOTION FOR LEAVE TO ANSWER The Commission’s Rules of Practice and Procedure, 18 CFR § 385.213(a)(2), do not permit answers to protests, answers, or requests for rehearing unless otherwise ordered by the decisional authority.Read this passage Filed comments: Filing procedure
III. CONCLUSION
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CONCLUSION The Market Monitor respectfully requests that the Commission afford due consideration to this answer as the Commission resolves the issues raised in this proceeding.Read this passage
CERTIFICATE OF SERVICE
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Dated at Eagleville, Pennsylvania, this 25th day of September, 2026.Read this passage