{"document":{"slug":"pjm-20261005-ceba-dcc-letter-to-pjm-board","filename":"pjm-20261005-ceba-dcc-letter-to-pjm-board.pdf","title":"Letter to the PJM Board of Managers on PJM's large-load show cause response","url":"https://www.pjm.com/-/media/DotCom/about-pjm/who-we-are/public-disclosures/2026/20261005-ceba-dcc-letter-to-pjm-board-re-ll-show-cause-response.pdf","issued":"2026-10-02","group":"PJM stakeholder record","docket":"PJM stakeholder record","file":"sources/originals/pjm-20261005-ceba-dcc-letter-to-pjm-board.pdf","kind":"stakeholder document","sha256":"10d514c418e1fee320fb00820ee8e60564de364347372d90fdc94dfc9d589c82","pages":2,"tokens":653,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":356,"text":"October 2, 2026 \nPaula Conboy, Chair, Board of Managers \nDavid Mills, President and CEO \nPJM Interconnection, L.L.C. \n2750 Monroe Blvd. \nAudubon, PA 19403 \nVia E-mail to: \nJennifer Tribulski, Members Committee Secretary \nDavid Mills, President and CEO \n \nDear Chair Conboy, Mr. Mills, and the PJM Board of Managers: \nWe write on behalf of a coalition of large energy customers committed to PJM's \nlong-term success. \nAt the outset, we want to be clear about our shared objectives. We support efforts to \naccelerate interconnection timelines, lower costs for consumers, maintain reliability, \nimprove planning outcomes, and ensure transparent and equitable cost allocation. \nWe also support automation and innovation of planning processes that enable PJM \nto meet unprecedented load growth and the urgent need for new generation. \nSpecifically, we are concerned that PJM is pursuing an unprecedented approach to \nstudying generation and load as its proposed response to FERC’s Large Load \nIntegration Show Cause Order. While the Order calls for improvements to large load \nintegration, it does not require PJM to overhaul its entire generation interconnection \nqueue. \nPJM has suggested that bringing load and generation into a unified process will \nincrease efficiency, speed, and transparency. However, we remain deeply concerned \nthat the proposed approach could have the opposite effect. Under PJM's proposal, \nlarge loads must first progress through the Transmission Owner study process for \nthe Transmission Owner to approve entry into PJM’s proposed new queue. A \ncustomer that obtains that approval just after the annual cutoff could wait nearly a \nyear for the next cycle, followed by another year in PJM’s proposed study process. \nEven if PJM meets its proposed annual schedule, that could mean nearly two years \nbetween Transmission Owner approval and completion of the PJM process. If paired \ngeneration must enter the process with the load, the generator could be held out of \nthe queue during that wait, delaying new supply that PJM urgently needs. \nThe proposal also raises significant questions regarding cost allocation, interim \ndeliverability, and the interaction with regional transmission planning. The result is \nsignificant uncertainty regarding interconnection costs and energization timelines \nfor new loads, even when those customers have committed to bringing new \ncapacity."},{"page":2,"startToken":356,"endToken":653,"text":"2 \n \nAcross the industry, there is growing interest to integrate system planning to yield \noptimized transmission solutions to diverse needs. Yet other regions pursuing these \ngoals, including in MISO and SPP, generally use parallel but coordinated planning \nprocesses before bringing them together into an integrated system plan, rather \nthan PJM’s proposed approach to combine load and generation interconnection \nrequests into a single cluster. \nMost importantly, PJM has not demonstrated that this proposal will deliver the \nspeed, certainty, or transparency envisioned by the Show Cause Order. Instead, there \nis substantial risk that it could increase queue complexity, delay project \ndevelopment, perpetuate cost uncertainty, and divert attention from meaningful \nconsideration of a truly integrated system planning approach.  \nWe therefore respectfully request that the Board direct PJM staff to either: \n1. \nExplain why it is not directly complying with the Show Cause Order \ndirectives to establish an application and study process for the provision of \ntransmission service for large loads that is 60–90 days or less; or  \n2. \nPursue a more targeted response to the Show Cause Order while \nproviding additional time to develop a comprehensive and durable \nframework for integrated planning. \nImportantly, we are not suggesting that PJM abandon innovation or automation. We \nstrongly support accelerating the deployment of next-generation planning \nprocesses. We also support PJM beginning to pilot and validate study automation, \nwhich can be done today within the Cycle process. \nWe appreciate the Board's consideration of these concerns. We support the \nobjectives of the Show Cause Order and stand ready to work constructively with PJM \non solutions that collectively advance speed, affordability, reliability, and planning \ntransparency. \nSincerely, \nJohn Miller \nDirector, Transmission Policy \nCorporate Energy Buyers Association \n(CEBA) \njmiller@ceba.org \nMorgan A. Sipple \nDirector, Energy Policy—FERC and RTOs \nData Center Coalition (DCC) \nmorgan@datacentercoalition.org"}],"sections":[{"p":1,"at":0,"title":"Pages 1 to 2","method":"page range","endPage":2,"endAt":2089,"startToken":0,"endToken":653}]}