{"document":{"slug":"motion-el26-67-pjm-abeyance","title":"PJM requests more time to answer the June 18 show cause order","issued":"2026-07-28","accession":"20260728-5084","docket":"EL26-67-000","group":"PJM filings","filer":"PJM Interconnection, L.L.C.","kind":"motion for abeyance","file":"sources/originals/20260728-5084_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260728-5084","sha256":"2510bf46b2aa7f3c83adbdd11ecbde3a583f59c56fc34c33dbf61596b1cce1b3","pages":12,"tokens":3079,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":274,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \nPJM Interconnection, L.L.C., et al. \n) \n) \n) \n \nDocket No. EL26-67-000 \n \nMOTION OF PJM INTERCONNECTION, L.L.C.  \nTO HOLD PROCEEDING IN ABEYANCE AND REQUEST FOR SHORTENED \nANSWER PERIOD AND EXPEDITED TREATMENT \n \nPursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy \nRegulatory Commission (“Commission”),1 PJM Interconnection, L.L.C. (“PJM”) moves to \nhold the above-captioned proceeding in abeyance for ninety days to allow PJM to pursue a \nFederal Power Act (“FPA”) section 205 filing,2 to address the issues identified in the large \nload show cause order issued June 18, 2026 (“Large Load Order”).3  PJM is already working \nto develop a section 205 filing to respond to the Large Load Order on an expedited basis.  \nThis development, however, must be done in conjunction with PJM’s already ongoing \nefforts to implement changes directed by the Order on Rehearing, Clarification, \nCompliance Filing, and Paper Hearing (“Compliance Order”) in the PJM Co-Located Load \nproceeding. 4  Many of the changes contemplated in the Large Load Order will build upon \ncompliance changes recently ordered for Co-Located Load in Docket Nos. EL25-49-000, \net al. 5  Given the complexity and interrelated nature of these issues, an abeyance is \nappropriate to allow time for PJM to identify what changes to the Open Access \nTransmission Tariff (“Tariff”) may be needed on a holistic basis, engage with stakeholders, \n \n1 18 C.F.R. § 385.212. \n2 16 U.S.C. § 824d. \n3 PJM Interconnection, L.L.C., 195 FERC ¶ 61,211 (2026). \n4 See PJM Interconnection, L.L.C., 195 FERC ¶ 61,209 (2026). \n5 See id."},{"page":2,"startToken":274,"endToken":539,"text":"2 \nand develop the resulting FPA section 205 filing.  PJM anticipates submitting that filing \nby early to mid-November.  Accordingly, PJM respectfully requests that the Commission \ngrant a ninety-day abeyance starting on the current compliance deadline, August 17, 2026.6  \nIn the interest of regulatory certainty, PJM also requests that the Commission shorten the \nanswer period to five days and grant expedited consideration to rule on this motion within \nten days of filing (i.e., by August 6, 2026). \nI. \nBACKGROUND \nA. \nLarge Load Order \nThe Large Load Order is an important component of the Commission’s ongoing \nefforts to efficiently and cost effectively integrate large loads with the transmission \nsystem.7  The Large Load Order found that several aspects of PJM’s Tariff appeared unjust \nand unreasonable due to the lack of specific procedures for integrating large loads, \nincluding a lack of large load-specific procedures for interconnection studies, processing \ntransmission service requests, and providing transmission service without cost shifting.8  \nThe Large Load Order also found PJM’s Tariff appeared to be unjust and unreasonable due \nto a lack of transmission service options for customers taking service on behalf of large \nloads that are willing and able to limit their withdrawals from the transmission system.9  \nAdditionally, the Large Load Order found that PJM’s Tariff appeared to be unjust and \nunreasonable due to a lack of mechanisms to ensure that costs are not shifted between \ntransmission customers.10 \n \n6 See Large Load Order at P 3. \n7 Id. at P 1. \n8 Id. at PP 60, 65, 77. \n9 Id. at P 86.  \n10 Id. at P 77."},{"page":3,"startToken":539,"endToken":811,"text":"3 \nTo address these issues, the Large Load Order directed PJM to make two \ncompliance filings.11  First, the Large Load Order directed PJM to submit an informational \nfiling within thirty days to explain how PJM intends to ensure that it has adequate \ngeneration to serve existing and new large loads.12  Second, the Large Load Order directed \nPJM to submit within sixty days a response to explain whether its Tariff remains just and \nreasonable in light of the issues identified in the order or to propose changes that would \nremedy the identified concerns.13  The Commission noted that it would entertain requests \nto hold the show cause proceedings in abeyance if PJM demonstrated a plan to propose \nchanges pursuant to section 205 of the FPA.14 \nB. \nCo-Located Load Proceeding \nAlso on June 18, 2026, the Commission issued the Compliance Order in the PJM \nCo-Located Load proceeding.15  The Compliance Order accepted most of PJM’s proposed \nTariff changes, but directed that PJM make a number of additional changes within sixty \ndays.16  Among other things, the Compliance Order directed PJM to propose changes to \nclarify the study process for interconnecting Co-Located Loads,17 make new transmission \nservices available to customers with behind the meter generation (“BTMG”) that are \n \n11 Id. at ordering paras. (A) & (B). \n12 Id. at P 4 & ordering para. (C). \n13 Id. at ordering para. (B). \n14 Id. at P 39. \n15 See generally Compliance Order. \n16 See, e.g., Compliance Order at P 280 (directing PJM to revise Tariff to specify what information about \nnecessary studies will be available in the manuals). \n17 Id. at PP 370-75."},{"page":4,"startToken":811,"endToken":1109,"text":"4 \nwilling and able to limit their withdrawals from the transmission system,18 and clarify the \noperational requirements for customers taking service on behalf of large loads.19 \nC. \nOverlap Between Proceedings \nThe compliance changes directed in the Large Load Order significantly relate to or \noverlap with the directives in the Compliance Order in three major areas:  (1) expansion of \nnew transmission services; (2) study procedures; and (3) operational requirements.   \nFirst, the Compliance Order and the Large Load Order both directed PJM to expand \nthe availability of new transmission services.  The Compliance Order directed PJM to make \nthe new transmission services available to customers taking service on behalf of load with \nBTMG that are willing and able to limit their withdrawals from the transmission system.20  \nTo accomplish this, the Commission directed PJM to either add a definition of “Eligible \nLoad” that encompasses both customers serving both Co-Located Load and load with \nBTMG or to propose comparable Tariff revisions.21  At the same time, the Large Load \nOrder directed PJM to propose Tariff changes to make those same new transmission \nservices available to flexible large loads or explain why it need not do so.22  Thus, PJM \nwill consider the potential impacts on flexible large loads in crafting Tariff revisions to \nexpand the new transmission services to customers serving load with BTMG. \nSecond, the Compliance Order and the Large Load Order both directed PJM to \nenhance its study procedures.  The Compliance Order directed PJM to revise the Tariff to \n \n18 Id. at P 91. \n19 Id. at P 65. \n20 Id. at P 91 (directing PJM to expand new transmission services to customers serving those with BTMG \nthat are willing and able to limit withdrawals from the transmission system). \n21 Id.  \n22 Large Load Order at P 87."},{"page":5,"startToken":1109,"endToken":1421,"text":"5 \nadopt more detailed study procedures for firm contract demand transmission service and \nnon-firm contract demand transmission service that mirror existing cluster study \nprocedures.23  Similarly, in the Large Load Order, the Commission directed PJM to either \npropose study procedures for customers requesting service on behalf of large loads that can \nidentify necessary network upgrades within 60-90 days or explain why it need not do so.24  \nThus, PJM will determine how to integrate these large loads into its study processes.  \nThird,  the Compliance Order directed PJM to revise the Tariff to provide additional \ndetail regarding the operational requirements and necessary control technologies to be \nemployed for customers taking new transmission services on behalf of Eligible Load.25  \nSimilarly, the Large Load Order directed PJM to evaluate what operational requirements \nare appropriate for customers taking service on behalf of large loads.26  Thus, PJM must \neither set operational requirements that encompass the various categories of co-located and \nlarge loads or determine what operational requirements are appropriate for large loads \nspecifically to ensure treatment that is not unduly discriminatory. \nD. \nCompliance Plan \nGiven the significant overlap in subject matter,27 it is important for PJM to consider \na number of the related Compliance Order’s directives in responding to the Large Load \nOrder.  PJM has already been working to develop the Tariff changes directed by the \nCompliance Order that will serve, in large part, as the foundation for the FPA section 205 \n \n23 Compliance Order at P 370. \n24 Large Load Order at P 63. \n25 Compliance Order at PP 482, 541. \n26 Large Load Order at P 64. \n27 See, e.g., Midcontinent Indep. Sys. Operator, 195 FERC ¶ 61,212 (2026) (issuing show cause order \nregarding co-located load arrangements and large load); Sw. Power Pool, Inc., 195 FERC ¶ 61,213 (2026) \n(same); Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 (2026) (same)."},{"page":6,"startToken":1421,"endToken":1726,"text":"6 \nfiling PJM intends to develop to respond to the Large Load Order.  PJM intends to make a \ncompliance filing on August 17th to address many of the Compliance Order’s directives as \nfurther discussed in PJM’s simultaneously-filed extension motion in that proceeding.   \nGiven the interrelated nature of many of these requirements, PJM is proposing to address \nthe related remaining aspects of both filings through integrated stakeholder engagement.     \nPJM is immediately focusing on the remaining open issues presented by the \nCompliance Order to finalize its tariffed construct for accommodating co-location \narrangements and load with BTMG, which is the bedrock for many of the other Large Load \nOrder reforms.  To avoid any doubt, PJM’s August 17th compliance filing in the Co-\nLocated Load docket will, for example, make progress on the new transmission service \nproducts by including Tariff language on Interim Network Integration Transmission \nService.  At the same time, PJM intends its FPA section 205 filing in the Large Load Order \ndocket will address all other categories for reform identified in the Large Load Order.  \nAmong other things, PJM’s intended FPA section 205 filing will advance a proposal that \ndelivers faster and more flexible processes that also:  (1) achieve efficient transmission \nservice application and study processes, including through the consideration of alternative \ntransmission technologies; (2) prevent cost shifting and enhance transparency into \ntransmission costs28 (with consideration given to concerns and issues raised in recently \nsubmitted requests for clarification and rehearing); (3) provide new transmission services \nfor flexible large loads, building upon the work that has already been done and will be \nfinalized regarding Co-Located Load; and (4) enhance study processes especially for \ngenerating facilities that serve electrically proximate large loads.  More details about PJM’s \n \n28 PJM is working on these cost and rate issues with the PJM Transmission Owners, consistent with their \nFPA section 205 filing rights."},{"page":7,"startToken":1726,"endToken":2078,"text":"7 \nconceptual framework will be previewed with stakeholders on July 30, 2026.  A \npresentation reflecting this framework has been publicly posted to guide the next few \nmonths of intensive, focused engagement efforts to realize these important reforms.29   \nPJM has or will be scheduling stakeholder engagement sessions to both share and \nreceive feedback on PJM’s proposal on July 30, 2026, August 18, 2026, and September 16, \n2026,30 with the goal of taking an advisory stakeholder vote on the proposal at the meeting \nof the Members Committee on October 28, 2026, while also satisfying the notice \nrequirements pursuant to Tariff, section 9.2(b).31  PJM will also engage with the \nTransmission Owners through appropriate consultation on or about the same date.  Because \nsection 9.2(b) of the Tariff requires this consultation to take place at least seven days prior \nto an FPA section 205 filing,32 PJM would then be in a position to make the resulting \nsection 205 filing in early to mid-November.  PJM is separately moving for a ninety-day \nextension of time for some aspects of the compliance obligations in the Compliance Order, \neven though PJM will make a compliance filing in that proceeding on August 17, 2026, as \nfurther discussed in its extension motion.33  \nII. \nMOTION TO HOLD PROCEEDING IN ABEYANCE \nPJM respectfully requests the Commission hold this proceeding in abeyance for \nninety days to allow PJM adequate time to develop a section 205 filing to respond to the \n \n29 Donnie Bielak, Show Cause Order for Large Loads Conceptual Approach: Co-Located Load Order \nWorkshop, PJM Interconnection, L.L.C. Interconnection Planning (July 30, 2026), https://www.pjm.com/-\n/media/DotCom/committees-groups/workshops/cllsco/2026/20260730/20260730-item-03---show-cause-\nfor-large-loads-conceptual-approach---presentation.pdf/ [https://perma.cc/QSQ5-FKAU].  \n30 These are the currently contemplated dates, but the dates may be subject to change as needed.   \n31 Tariff, Part I, section 9.2(b). \n32 See id. \n33 PJM Interconnection, L.L.C., Motion for Extension of Time for Specified Compliance Requirements and \nRequest for Expedited Treatment of PJM Interconnection, L.L.C., Docket Nos. EL25-49-000, et al. (July 28, \n2026)."},{"page":8,"startToken":2078,"endToken":2410,"text":"8 \nLarge Load Order.  An abeyance is appropriate to allow PJM to identify and develop the \nnecessary Tariff changes, engage with stakeholders on an expedited basis, and develop an \nFPA section 205 filing to address the Large Load Order while also finalizing its response \nto certain overlapping aspects of the Compliance Order.  The Commission has previously \nexercised its discretion to hold show cause proceedings in abeyance to allow a Regional \nTransmission Organization to engage with stakeholders to resolve the matter via an FPA \nsection 205 filing.34  It should do so again here. \nAs discussed above, there is significant overlap in the compliance directives in the \nLarge Load Order and the Compliance Order.  Given this overlap, PJM intends to address \nthe related requirements of both orders with stakeholders through integrated stakeholder \nengagement to promote efficiency and consistency.  As noted above, PJM has scheduled \nor will be scheduling stakeholder meetings, presentations, and opportunities for \nengagement and feedback with the goal of making its remaining Co-Located Load \ncompliance filing and one or more FPA section 205 filings to address the requirements in \nthe orders by mid-November. \nIII. \nREQUEST FOR SHORTENED ANSWER PERIOD AND EXPEDITED \nTREATMENT \nPJM respectfully requests that the Commission shorten the answer period for this \nmotion to five days and grant expedited treatment to issue an order ruling on the abeyance \nmotion within ten days, by August 6, 2026.  Although Rule 213(d)(1) generally allows \n \n34 See, e.g., Sw. Power Pool, Inc., Notice Granting Motion to Hold Proceeding in Abeyance, Docket No. \nEL22-65-000 (Jan. 31, 2024) (holding show cause proceedings in abeyance pending stakeholder process to \nresolve show cause proceedings via a section 205 filing); see also PJM Interconnection, L.L.C., 171 FERC \n¶ 61,015, at P 34 (2020) (holding a paper hearing proceeding in abeyance to allow stakeholder discussions \nto continue); Midcontinent Indep. Sys. Operator, Inc., 161 FERC ¶ 61,057, at P 44 (2017) (same); Sw. Power \nPool, Inc., 161 FERC ¶ 61,062, at P 33 (2017) (same)."},{"page":9,"startToken":2410,"endToken":2685,"text":"9 \nfifteen days to answer a motion,35 the Commission may shorten the answer period or \neliminate it all together for good cause shown.36  Good cause exists to shorten the answer \nperiod and grant expedited treatment given the Large Load Order’s fast approaching \ncompliance deadline. \nFirst, shortening the answer period will promote regulatory certainty.  The Large \nLoad Order directed PJM to respond to the range of issues identified within sixty days.37  \nAbsent further Commission action, PJM’s response to the Large Load Order is due August \n17, 2026, which is less than twenty-one days from the date of this motion’s filing.  If the \nCommission allows for a full fifteen-day answer period, PJM will not have clarity on \nwhether the deadline applies until shortly before the due date, and PJM will need to devote \nresources towards preparing the responsive filing and not to the FPA section 205 filing.  \nMoreover, there is heightened uncertainty surrounding an abeyance request in this case \ngiven that the Commission emphasized that it will not grant such requests reflexively.38  \nThus, a shortened answer period and expedited treatment is appropriate to give PJM \ncertainty in advance of the deadline. \nSecond, any interested person or entity should be in a position to respond to this \nmotion quickly because the Commission specifically contemplated the potential for such \nrequests in the Large Load Order.39  Indeed, the Commission directed that any such \nrequests be made within forty-five days of the issuance of the order to give the Commission \n \n35 18 C.F.R. § 385.213(d)(1). \n36 See id.  \n37 See supra note 12. \n38 Large Load Order at P 39. \n39 Id."},{"page":10,"startToken":2685,"endToken":2914,"text":"10 \nadequate time to act on the request.40  Given this timing directive (i.e., that abeyance \nrequests could be made up to fifteen days before the deadline), anyone with an interest in \nthis proceeding should have been on notice regarding the need to respond on an expedited \nbasis. \nFinally, as noted above, PJM is also seeking a coincident ninety-day extension of \ncertain overlapping compliance obligations from the Compliance Order.41  Because the \nanswer to that motion and the request to shorten the answer period here will both be due \nwithin five days unless the Commission otherwise orders,42 granting this request for a \nshortened answer period will promote administrative efficiency by allowing the \nCommission to rule on these related requests at the same time. \nIV. \nCONCLUSION \nFor the reasons set forth above, PJM respectfully requests that the Commission \n(i) grant this motion to hold this proceeding in abeyance for a period of ninety days starting \nAugust 17, 2026, to allow PJM time to develop, with stakeholder engagement, and submit \nan FPA section 205 filing to address the issues identified in the Large Load Order; (ii) \nshorten the answer period to five days; and (iii) grant expedited consideration to issue an \norder on this motion within ten days by August 6, 2026. \n \n40 Id. \n41 See supra note 333. \n42 18 C.F.R. § 385.213(d)(1)(i)."},{"page":11,"startToken":2914,"endToken":3012,"text":"11 \n \n \n \n \n \n       Respectfully submitted,  \n \n \n \n \n \n        /s/Ruth M. Porter  \nCraig Glazer \nVice President – Federal Government Policy \nPJM Interconnection, L.L.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 423-4743 \n(202) 393-7741 \ncraig.glazer@pjm.com \nWendy B. Warren \nRuth M. Porter \nWright & Talisman, P.C. \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 393-1200 \n(202) 393-1240 \nwarren@wrightlaw.com \nporter@wrightlaw.com     \n \nMark Stanisz \nAssociate General Counsel \nPJM Interconnection, L.L.C.  \n2750 Monroe Blvd. \nAudubon, PA 19403 \n(610) 666-4707 \nMark.Stanisz@pjm.com \n \n \n \n \n \nCounsel for \nPJM Interconnection, L.L.C.\n \n \nDated: July 28, 2026"},{"page":12,"startToken":3012,"endToken":3079,"text":"CERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon each \nperson designated on the official service list compiled by the Secretary in this proceeding. \n \nDated at Washington, D.C., this 28th day of July 2026. \n/s/ Ruth M. Porter \n \nRuth M. Porter \n1200 G Street, NW, Suite 600 \nWashington, DC  20005 \n(202) 393-1200 \n \nAttorney for PJM Interconnection, L.L.C."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":505,"startToken":0,"endToken":352},{"p":2,"at":505,"title":"I. background","method":"PDF bookmark","endPage":2,"endAt":509,"startToken":352,"endToken":353},{"p":2,"at":509,"title":"BACKGROUND","method":"printed heading","endPage":2,"endAt":521,"startToken":353,"endToken":354},{"p":2,"at":521,"title":"A. Large Load Order","method":"PDF bookmark","endPage":3,"endAt":750,"startToken":354,"endToken":666},{"p":3,"at":750,"title":"B. Co-Located Load Proceeding","method":"PDF bookmark","endPage":4,"endAt":179,"startToken":666,"endToken":839},{"p":4,"at":179,"title":"C. Overlap Between Proceedings","method":"PDF bookmark","endPage":5,"endAt":1226,"startToken":839,"endToken":1287},{"p":5,"at":1226,"title":"D. Compliance Plan","method":"PDF bookmark","endPage":7,"endAt":1274,"startToken":1287,"endToken":1936},{"p":7,"at":1274,"title":"II. motion to hold proceeding in abeyance","method":"PDF bookmark","endPage":8,"endAt":1219,"startToken":1936,"endToken":2262},{"p":8,"at":1219,"title":"III. REQUEST FOR SHORTENED ANSWER PERIOD AND EXPEDITED TREATMENT","method":"PDF bookmark","endPage":10,"endAt":775,"startToken":2262,"endToken":2810},{"p":10,"at":775,"title":"IV. conclusion","method":"PDF bookmark","endPage":10,"endAt":780,"startToken":2810,"endToken":2811},{"p":10,"at":780,"title":"CONCLUSION","method":"printed heading","endPage":12,"endAt":0,"startToken":2811,"endToken":3012},{"p":12,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":12,"endAt":404,"startToken":3012,"endToken":3079}]}