PJM states request clarification or separate consideration of the interim service proposal
Read topic-matched comments in ER26-3515
Topics in the text: Reliability and curtailment · Registry access · Cost allocation
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Opening text
opening text · Topic match: Registry access
The Organization of PJM States, Inc. (“OPSI”) files these comments and request for clarification in response to PJM’s August 13, 2026, filing proposing revisions to the Open Access Transmission Tariff (“Tariff”) and the Reliability Assurance Agreement Among Load Serving Entities (“RAA”) to…Read this passage Filed comments: Registry access
I. Comments
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COMMENTS Recognizing the 2027/2028 Base Residual Auction (“BRA”) cleared short of the PJM Region Reliability Requirement, PJM now proposes several measures intended to improve regional resource adequacy, including the creation and maintenance of an NLL Registry, establishment of IRAS, requiring new…Read this passage Filed comments: Cost allocation
a. OPSI Supports the BYONC Incentive, but PJM Should Further explain whether it is expected to exacerbate volatility of supply
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One of the very purposes of IRAS is “for New Large Loads to bring new capacity to address their capacity needs instead of relying on PJM’s capacity market” and eliminate resource adequacy shortfalls.8 OPSI is supportive of the primary objectives of this proposal.Read this passage Filed comments: Cost allocation
b. OPSI Supports Curtailing New Large Loads Without Sufficient Capacity Before Pre-Emergency Load Management
PDF bookmark · Topic match: Reliability and curtailment
More importantly, the proposal functionally eliminates the incentive for NLL to bring new capacity.”11 PJM now proposes to implement an IRAS Action before calling on Pre-Emergency Load Management when available economic real-time supply may be insufficient to maintain required reserves or…Read this passage Filed comments: Reliability and curtailment
c. OPSI Supports Excluding New Large Loads Without BYONC from the VRR Curve Until They Bring Their Own Capacity
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OPSI SUPPORTS EXCLUDING NEW LARGE LOADS WITHOUT BYONC FROM THE VRR CURVE UNTIL THEY BRING THEIR OWN CAPACITY Beginning with the 2029/2030 BRA, PJM proposes to exclude NLLs without sufficient BYONC or Allocated RBP Unforced Capacity (“UCAP”) MW from the Variable Resource Requirement (“VRR”) Curve.14…Read this passage
d. OPSI Supports the Large Load Registry to Inform Retail Curtailment and Cost Allocation
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The Registry will include information such as location, in- service date, peak load, backup generation, peak-shaving adjustments, BYONC, and other relevant characteristics, and PJM will use that information to identify and allocate IRAS obligations by zone/area.21 PJM also recognizes that this…Read this passage Filed comments: Registry access
II. PJM should clarify the proposed IRAS compensation rate and the mechanism used to determine it
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PJM describes the IRAS framework as squarely within the Commission’s established transmission jurisdiction and proposes that “[t]he rate for the provision of Interim Resource Adequacy Service shall be 50% of the Non-Performance Charge Rate” unless an Eligible NLL elects to accept less in its retail…Read this passage Filed comments: Registry access
III. If the Commission reaches the merits on the existing record, it should sever the compensation provisions and find them to be unjust and unreasonable
PDF bookmark · Topic match: Reliability and curtailment
By PJM’s own account, rapid large-load growth has outpaced new supply, tightened the capacity market, and produced resource-adequacy shortfalls.28 PJM attributes the current shortfall particularly to the “unprecedented surge in data center load” occurring faster than new supply can come online,…Read this passage Filed comments: Reliability and curtailment
IV. Conclusion
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IV.Read this passage
CONCLUSION
printed heading · Topic match: Reliability and curtailment
CONCLUSION The rapid influx of NLLs appearing in the PJM region presents a real threat to regional resource adequacy and reliability, and the status quo is not an option.Read this passage Filed comments: Reliability and curtailment
CERTIFICATE OF SERVICE
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Dated at Newark, Delaware this September 3, 2026.Read this passage