ER26-3380-000 · 2026-10-12 · PJM

Motion for Abeyance of PJM Interconnection, L.L.C. (ER26-3380-000 and EL26-108-000), holding the backstop paper hearing pending a new section 205 filing

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
  
 
 
) 
PJM Interconnection, L.L.C. 
) 
 
 
Docket Nos. ER26-3380-000 
 
 
 
) 
 
 
 
 
EL26-108-000 
 
 
 
) 
 
 
MOTION FOR ABEYANCE OF  
PJM INTERCONNECTION, L.L.C.  
  
Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“Commission”) 
Rules of Practice and Procedure,1 PJM Interconnection, L.L.C. (“PJM”) respectfully requests that 
the Commission hold the paper hearing proceedings, including any additional briefings, in this 
docket in abeyance pending resolution of PJM’s forthcoming filing that will be submitted under 
section 205 of the Federal Power Act (“FPA”) addressing the issues raised in the Commission’s 
September 29 Order.2   
In the September 29 Order, the Commission accepted PJM’s proposed reliability backstop 
procurement (“RBP”) rules, but suspended those rules for five months to allow time for further 
briefing through a paper hearing process to further review three discrete areas of the RBP: cost 
allocation, Transmission Owner exit rules, and LSE collateral requirements.3  While the 
Commission established additional paper hearing procedures and a separate proceeding under 
section 206 of the FPA in its September 29 Order, the Commission “strongly encourage[d] PJM 
to address the issues discussed in [the] order by submitting an alternative proposal pursuant to its 
FPA section 205 filing rights without delay.”4  The September 29 Order further explained that “the 
 
1 18 C.F.R. § 385.212. 
2 PJM Interconnection, L.L.C., 196 FERC ¶ 61,245 (2026) (“September 29 Order”). 
3 Id. at P 24. 
4 Id. at P 28.

2 
Commission would grant a motion to hold that briefing in this proceeding in abeyance if PJM 
submitted a new section 205 filing within 30 days from the date of this order.”5 
In accordance with the Commission’s September 29 Order, and to help expedite a 
resolution of the remaining issues identified by the Commission, PJM plans to submit a new FPA 
section 205 filing that addresses, inter alia, cost allocation issues, Transmission Owner exit 
responsibilities, and LSE collateral requirements as they relate to RBP by October 29, 2026.  To 
that end, PJM has scheduled a special Members Committee and a special Transmission Owners 
Agreement – Administrative Committee meeting on October 22, 2026 to provide the requisite 
consultation with the PJM Members Committee and Transmission Owners of the new FPA section 
205 filing in accordance with Tariff, section 9.2(b) and the Consolidated Transmission Owners 
Agreement, section 7.5.1(ii), respectively.  
Filing this motion for abeyance at this time allows the Commission to timely consider this 
request and grant the abeyance so that interested parties can focus efforts on the upcoming section 
205 filing rather than having to separately prepare for the paper hearing briefing under the current 
timelines specified in the September 29 Order.  For these reasons, the Commission should 
expeditiously grant this motion to hold the paper hearing proceedings in abeyance. 
 
 
5 Id. at PP 24 and 160.

3 
 
Respectfully submitted, 
/s/ Chenchao Lu 
Craig Glazer 
Vice President – Federal Government Policy 
PJM Interconnection, L.L.C. 
1200 G Street, N.W. 
Suite 600 
Washington, D.C. 20005 
(202) 423-4743 
Craig.Glazer@pjm.com 
 
Chenchao Lu 
Associate General Counsel 
PJM Interconnection, L.L.C. 
2750 Monroe Boulevard 
Audubon, PA 19403 
(610) 666-2255 
Chenchao.Lu@pjm.com 
 
 
 
On behalf of 
PJM Interconnection, L.L.C.

4 
CERTIFICATE OF SERVICE 
I hereby certify that I have on this 12th day of October served a copy of the foregoing 
upon all parties on the service list in these proceedings in accordance with the requirements of 
Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.2010. 
/s/ Chenchao Lu 
Chenchao Lu 
Associate General Counsel 
PJM Interconnection, L.L.C. 
2750 Monroe Boulevard 
Audubon, PA 19403