Find the argument, the person who made it and the section it concerns. A state consumer advocate speaks for a different office than a utility commission. Hearing testimony does not establish a vote on a pending filing.
Thirteen commissions backed OPSI’s August comments on the original backstop. West Virginia did not. Eleven backed its September comments on PJM’s registry and curtailment plan, including West Virginia. Kentucky, Ohio and Virginia abstained. Neither tally is a vote on the November filings.
Google, Equinix and Data Center Coalition · Direct response
FERC cites all three commenters as seeking to share the underlying allocation data with states. Those data would let a retail regulator see which wholesale obligations had been assigned before setting the customer’s retail rate.
PDF p. 49, footnote 191, citing Google comments p. 8Illinois Commerce Commission and Joint Consumer Advocates · Related public statement
Illinois regulators and the consumer advocates warned that a single end date for contracts could amplify forecast errors. FERC recorded that concern as it considered freezing load shares at one point in time.
PDF p. 40, footnote 144Illinois Commerce Commission and Joint Consumer Advocates · Direct response
Illinois regulators and the consumer advocates warned that a single end date for contracts could amplify forecast errors. FERC recorded that concern as it considered freezing load shares at one point in time.
PDF p. 40, footnote 144New Jersey Board of Public Utilities · Direct response
FERC records the board’s comparison of one distributor counting projects from 50 MW and another reporting expansions from 20 MW. The board wanted a consistent threshold so that equally sized projects would not pay differently just because of where they connected.
PDF pp. 43–44, NJBPU comments summarized by FERCNew Jersey Board of Public Utilities · Related public statement
In comments on the July proposal, the board showed how different distributor cutoffs could charge comparable projects differently. It sought a uniform threshold before assigning bills. That objection explains why it matters which projects count in the refiling.
PDF pp. 43–44, NJBPU comments summarized by FERCIndependent Market Monitor for PJM · Related public statement
The monitor objected to eligibility rules that could let an existing resource reclassify its capacity. Its test was whether an award actually paid for additional physical supply.
PDF p. 15, responsive pleadingsIndependent Market Monitor for PJM · Direct response
The monitor objected to eligibility rules that could let an existing resource reclassify its capacity. Its test was whether an award actually paid for additional physical supply.
PDF p. 15, responsive pleadingsExelon Corporation · Related public statement
In a separate complaint about PJM, Exelon argued that moving procurement closer to delivery could reduce forecast risk. It invoked ISO New England as a precedent. The complaint sought changes in PJM, not changes to ISO New England’s July report.
PDF pp. 52–53Mary Yang, 804 Advisory, interviewed by Latitude Media · Direct response
Yang, a former PJM regulatory counsel, expected other priorities to delay a rewrite. She said that uncertainty could slow bilateral arrangements between new loads and generators.
Maeve Allsup, October 13, interview with Mary YangElliot Mainzer, CAISO president and CEO, quoted by APPA · Related public statement
After the October board action, Mainzer said CAISO expected its response to improve operational visibility, protect other customers from cost shifts and speed connections for flexible loads. His statement described a plan, not FERC approval.
October 28, comments following board actionConstellation and PJM · Direct response
Constellation questioned the proposed July 2028 start for interim network service. PJM answered that administering interruptions required new automation, but said it expected to take requests from September 2027.
PDF pp. 2–3American Municipal Power and PJM · Direct response
AMP asked that the new service also cover non-retail behind-the-meter generation. PJM agreed to revise the language. On a separate objection from Amtrak and industrial customers, PJM said its changes did not impose the netting restriction they feared.
PDF pp. 6–7PJM and Constellation · Direct response
PJM sought an extension to align its co-location and large-load work. Constellation wanted full interim network-service terms on the original schedule. FERC kept the August partial filing while granting additional time for other requirements.
Requests and ruling on extension of time (unpaginated)Constellation Energy Generation · Direct response
Constellation supported a partial delay but said PJM’s separate duty to comply with the co-location order could not depend on the outcome of the large-load process.
PDF pp. 2–3FirstEnergy Service Company · Related public statement
FirstEnergy compared supplier security of $1.5 million per MW under the earlier design with the much smaller security required of sellers. That objection is a benchmark for the revised calculation, not an objection to the new $686,000 figure.
PDF p. 14Joint Consumer Advocates, including Delaware, D.C., Illinois, Maryland and New Jersey offices · Related public statement
The advocates estimated that buying 15 years rather than five could add $13 billion. They also warned that without a location requirement, customers could pay for capacity built far from the shortfall. These were their estimates and objections to the September order.
PDF pp. 2, 4, 6–7Pennsylvania Office of Consumer Advocate · Direct response
The office asked FERC to clarify that a customer agreement is only one protection. It wanted parties to be able to show that existing regional allocation methods themselves charge other customers for network upgrades needed by a large load.
PDF pp. 2–5Maryland Office of People’s Counsel, Ohio Consumers’ Counsel, Delaware Division of the Public Advocate and Illinois Attorney General · Direct response
The four offices backed FERC’s transparency directives but said disclosure alone leaves existing cost shifts intact. They asked that agreements require full payment for the necessary upgrades and that other customers receive the corresponding revenue credits promptly.
PDF pp. 1–4, section III.B challengeMissouri Public Service Commission · Direct response
Missouri backed the 95-day request because SPP’s November 17 board vote fell just beyond the 90-day window. It said the extra days allowed meaningful state input without materially delaying the case.
PDF pp. 1, 3–5Commissioner Judy Chang · Related public statement
In the separate Duke case, Chang dissented because Duke had not shown that its security requirements backed the full 15-year payment promise. The comparison bears on PJM’s proposed collateral; Chang was not evaluating PJM’s dollar amount.
Chang dissent, section on security requirementsCommissioner Judy Chang · Direct response
Chang said Duke had not demonstrated that a promise to pay for 75% of forecast demand would protect existing customers if the responsible utility defaulted. She wanted security commensurate with the 15-year commitment.
Chang dissent, section on security requirements (unpaginated DOCX)Commissioner Lindsay See · Direct response
See saw the minimum revenue commitment as an improvement over charging for use alone. She said 75% might be near the low end of an acceptable range and urged Duke to consider incremental charges where appropriate.
See concurrence, discussion of committed revenue contribution (unpaginated DOCX)Commissioner David Rosner · Related public statement
Rosner wanted voluntary demand response called first, followed by noncritical large loads before homes and other ordinary customers. He objected to keeping demand out of the capacity market forecast. His October concurrence predates the November compliance filing.
PDF pp. 55–57, Rosner concurrenceCommissioner Judy Chang · Related public statement
Chang asked why a data center would voluntarily disconnect once connected if each interrupted megawatt-hour was very costly. She invited utilities and operators to explain what would make a flexibility commitment credible.
October 21 reliability conference, 01:36:23Commissioner David Rosner · Direct response
Rosner wanted voluntary demand response called first, followed by noncritical large loads before homes and other ordinary customers. He objected to keeping demand out of the capacity market forecast. His October concurrence predates the November compliance filing.
PDF pp. 55–57, Rosner concurrenceCommissioner David Rosner · Related public statement
PJM’s July report considered shortage service. Reviewing a subsequent tariff proposal in October, Rosner objected to mandatory curtailment before paid, voluntary demand response and warned about masking demand in capacity prices.
PDF pp. 55–57, Rosner concurrenceData Center Coalition · Direct response
The coalition supported letting customers bring their own generation but opposed the proposed interim service. It argued that PJM’s region-wide mandatory curtailment rule would displace state retail decisions.
PDF pp. 2–4Joint Consumer Advocates · Direct response
The advocates saw value in a choice between contributing new capacity and curtailing with appropriate state action. With suitable eligibility rules, they argued, this mechanism would make a separate backstop procurement redundant.
PDF pp. 2–3, 40Iowa Office of Consumer Advocate, Illinois and Michigan attorneys general, Minnesota Department of Commerce and co-protesters · Direct response
The joint protesters asked how the study would prevent costs shifting to other customers. They warned that related MISO proposals could exempt about 30 GW of existing load from some reliability requirements; 30 GW was not the size of the proposed LARS study queue.
PDF pp. 1, 3–4, 6Commissioner David Rosner · Direct response
Rosner said Duke’s previous tariff contained no comparable protection for households or small businesses. He accepted the added protection and said FERC should consider more if action by the states proved insufficient.
Rosner concurrence, first and second points (unpaginated DOCX)Commissioner David LaCerte · Related public statement
Answering Senator Cotton, LaCerte said beneficiaries should pay for the new infrastructure and states should hold hyperscalers to their commitments in retail rates. He did not specify a PJM cost formula.
PDF pp. 79–80, printed pp. 75–76Rep. Victoria Spartz (Indiana’s 5th Congressional District) · Direct response
Spartz asked FERC and DOE to scrutinize potentially duplicate load forecasts and to require developers to pay attributable generation and transmission costs. Her November letter represents a member of Congress, not Indiana’s utility commission.
PDF pp. 1–4SPP Regional State Committee · Direct response
The committee endorsed a November 20 deadline while its cost-allocation team studied who should secure network costs if promised demand fails to arrive or leaves early. The filing endorsed the schedule, not a final cost-allocation formula.
PDF pp. 1–2Midcontinent Independent System Operator · Direct response
MISO said the study should go ahead before related cost-recovery reforms were complete. It promised to incorporate those protections once FERC accepted them and cited other existing tariff mechanisms.
PDF pp. 5–6Commissioner David Rosner · Direct response
Rosner argued that a cost recovery agreement should prevent households from paying for a network upgrade if the data center never opens. He invited alternative regional mechanisms if they offered comparable protection.
PDF p. 91, Rosner concurrenceCommissioner Judy Chang · Direct response
Answering Senator Hirono, Chang linked the June section 206 proceedings to tracking which data center triggered a network upgrade and identifying who would otherwise pay. She described the information needed to limit cost shifting, not the outcome of a regional case.
PDF p. 75, printed p. 71SPP Regional State Committee · Related public statement
In its later comments on the filing schedule, the committee said its cost team was examining security for upgrades if a large customer never arrives or leaves early. It did not approve a particular conditional-service charge.
PDF pp. 1–2Iowa Office of Consumer Advocate, Illinois and Michigan attorneys general, Minnesota Department of Commerce and co-protesters · Direct response
The coalition challenged MISO’s grandfathering provisions. It said existing loads can also trip or ramp suddenly and that utilities and other customers could inherit the cost of local reliability projects if those loads were exempt.
Protest and concluding request on proposed section 37A (unpaginated)Commissioner David LaCerte · Direct response
Answering Senator Cotton, LaCerte said beneficiaries should pay for the new infrastructure and states should hold hyperscalers to their commitments in retail rates. He did not specify a PJM cost formula.
PDF pp. 79–80, printed pp. 75–76Equinix and PJM industrial customers · Related public statement
Equinix wanted customers notified and allowed to verify or correct the information PJM would use. Industrial customers also requested an appeal and safeguards for commercial data.
PDF p. 17, ¶38Equinix and PJM industrial customers · Direct response
Equinix wanted customers notified and allowed to verify or correct the information PJM would use. Industrial customers also requested an appeal and safeguards for commercial data.
PDF p. 17, ¶38Indicated PJM Transmission Owners · Related public statement
The owners argued that FERC should reject the original exit amendment on cost-causation grounds and that their agreement reserved the relevant filing right to them. Their rehearing request concerned the earlier wording.
PDF pp. 5–8Constellation Energy Generation · Related public statement
Constellation asked FERC to clarify that it had not assigned the departing owner’s share to suppliers by default. In its view an exiting owner, rather than captive customers, should bear exit costs it causes.
PDF pp. 16–17Commissioner Lindsay See · Direct response
See said the federal changes should give states better information about wholesale costs so they could carry out their own affordability duties. She cautioned against using federal tariff reform to override state decisions.
PDF pp. 77–79, See concurrenceCommissioner Judy Chang · Direct response
Chang supported developing a regional record. She welcomed evidence from state regulators on possible jurisdictional problems and distinguished the narrower preliminary findings from the broader federal authority contemplated in the national rulemaking.
PDF pp. 109–110, Chang concurrenceAmerican Municipal Power · Related public statement
AMP opposed an unconditional delay and asked FERC to require a compliance filing. The order says FERC would return to the section 206 case for any preliminary finding MISO’s tariff filings did not address.
Discussion of AMP’s protest and Commission determination (unpaginated)Southwest Power Pool · Related public statement
SPP told FERC its board meeting had moved because of the elections. The revised November 17 vote made a November 16 filing impractical; FERC granted a November 20 response date.
SPP motion and Commission determination (unpaginated)Organization of PJM States · Related public statement
OPSI asked PJM to remove withdrawn large projects when setting the procurement target. Otherwise existing customers could pay for generation to meet demand that no longer exists.
PDF pp. 3–4, original August 21 commentsAmazon and Northern Virginia Electric Cooperative · Related public statement
Amazon argued that immutable shares would diverge from actual demand as projects changed. NOVEC asked why PJM considered a single snapshot appropriate.
PDF p. 40, responsive pleadingsOrganization of PJM States · Direct response
OPSI asked PJM to remove withdrawn large projects when setting the procurement target. Otherwise existing customers could pay for generation to meet demand that no longer exists.
PDF pp. 3–4, original August 21 commentsAmazon and Northern Virginia Electric Cooperative · Direct response
Amazon argued that immutable shares would diverge from actual demand as projects changed. NOVEC asked why PJM considered a single snapshot appropriate.
PDF p. 40, responsive pleadingsIllinois Commerce Commission · Direct response
The ICC supported a one-time supplemental purchase but wanted protection against forecast error, data for state regulators and no new obligations on states. It warned that a modest percentage error in a larger forecast could mean paying for substantial unneeded capacity.
PDF pp. 1–2, 4, 6–7Google · Direct response
Google supported studying loads and generators together but questioned the separate assumptions used in the ordinary queue. It wanted cost protections and a way for independent generators to participate without discrimination by the serving utility.
PDF pp. 2–3, 6–9Midcontinent Independent System Operator · Direct response
MISO said the transmission customer submits an application for an already matched pair. It argued that an independent generator remains free to bring a proposal to that customer before the application, and that the eligibility rules are nondiscretionary.
PDF pp. 20–22Eolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Eolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Eolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Eolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Organization of MISO States · Direct response
OMS conditionally supported the zero-injection agreement. It wanted enforceable limits on a generator exporting power and asked MISO to explain how paired loads and generators would count in capacity and reliability calculations during outages.
PDF pp. 3–5, 9Commissioner David LaCerte · Related public statement
At WIRES on July 9, LaCerte said PJM’s stakeholder process too often protected individual business interests and prevented agreement. He was discussing governance months before the members voted, not evaluating their final term sheet.
July 9 WIRES keynote, 00:40:00Chairman Laura Swett · Related public statement
Swett asked the October reliability panel how to model the scale and operating patterns of large loads. She pointed out that the forecast determines how much generation is procured and therefore influences market prices.
October 21 reliability conference, 00:45:35Jefferies analysts, quoted by Utility Dive · Direct response
Jefferies saw the rejection of interim service as favorable to existing independent generators. That was an analyst assessment of market effects, separate from the commission’s reasons for its decision.
Ethan Howland, October 12, analyst reactionAmerican Municipal Power · Related public statement
AMP asked FERC to protect systems that did not cause the new demand. It also disputed the suggestion that the forecast table excluded projects PJM had actually counted.
PDF pp. 7, 15Public Service Commission of West Virginia · Related public statement
The West Virginia commission warned that complex rules could discourage participants from reporting qualifying capacity. That would make the final purchase larger than necessary.
PDF pp. 2–4, bilateral matching and offsetsU.S. Department of Energy · Related public statement
DOE wanted a mandatory way to identify the large load driving additional procurement and give it a chance to build, bring or buy capacity. It questioned whether the proposed two-year lookback would capture the relevant projects.
PDF pp. 6–7Public Service Commission of West Virginia · Direct response
The West Virginia commission warned that complex rules could discourage participants from reporting qualifying capacity. That would make the final purchase larger than necessary.
PDF pp. 2–4, bilateral matching and offsetsPublic Service Commission of West Virginia · Direct response
The commission opposed the original filing in its proposed form and on its proposed timetable. It wanted PJM to learn how much demand would be covered by bilateral contracts before setting a central procurement target.
PDF pp. 1–4Data Center Coalition · Direct response
The coalition supported offsetting a new load’s own capacity purchases and procurement through bilateral deals. It also wanted backstop costs charged to loads driving the need rather than customers elsewhere.
PDF pp. 3–4New Jersey Board of Public Utilities · Related public statement
The New Jersey board sought more flexible terms for demand resources and distributed resource aggregations in the original procurement. This concerned auction eligibility; it did not endorse the later peak-shaving formula.
PDF p. 15, footnote 54New Jersey Board of Public Utilities · Direct response
The New Jersey board sought more flexible terms for demand resources and distributed resource aggregations in the original procurement. This concerned auction eligibility; it did not endorse the later peak-shaving formula.
PDF p. 15, footnote 54Elliot Mainzer, CAISO president and CEO, quoted by APPA · Related public statement
The July report scheduled a response for the fall. After the October board action, Mainzer said CAISO expected the proposed rules to improve operational awareness and reduce cost shifts. The board action did not itself change a FERC tariff.
October 28, board actionAlliant Energy and Consumers Energy · Direct response
The utilities backed the readiness requirements because a speculative project could occupy one of a limited number of study slots. They argued the joint model could identify cheaper combined upgrades.
PDF pp. 2–3DTE Electric · Direct response
DTE supported the pairing rules and minimum commitment as evidence of a lasting commercial relationship. It also said the tariff allowed the interconnection customer to participate even though the transmission customer submits the application.
PDF pp. 2–3Rep. Frank Pallone Jr. (New Jersey) · Related public statement
Pallone wanted as much of the registry made public as possible to improve demand forecasts. FERC records his request separately from the states’ requests for protected access. He spoke as a member of Congress.
PDF p. 18, ¶39Rep. Frank Pallone Jr. (New Jersey) · Direct response
Pallone wanted as much of the registry made public as possible to improve demand forecasts. FERC records his request separately from the states’ requests for protected access. He spoke as a member of Congress.
PDF p. 18, ¶39American Clean Power Association and Southern Renewable Energy Association · Direct response
The trade associations said studying accelerated projects without other generators already waiting could leave later studies with fewer feasible connections and higher costs. They objected to a permanent parallel route without a cap on total capacity.
PDF pp. 2, 21, 27Solar Energy Industries Association and Advanced Energy United · Direct response
The protesters asked FERC to reject the proposal or clarify that an applicant meeting all published requirements could not lose access at the transmission customer’s discretion.
PDF pp. 1–2, 13Organization of MISO States, quoted by Utility Dive · Direct response
OMS warned that a rapid route must not turn into a general substitute for the queue. It asked for safeguards before qualifying pairs could claim transmission capacity ahead of projects already waiting.
October 26, reporting on October 23 ER27-25 commentsSouthwest Power Pool · Direct response
SPP’s November 10 amendment says the November 6 filing inadvertently omitted Schedule 14 and Incremental Market Efficiency Use revenues on the Upper Missouri rate sheet. It corrected that sheet while retaining the conditional-service proposal.
PDF p. 2Commissioner David LaCerte · Direct response
LaCerte supported the order as a way to identify gaps in large-load tariffs. He expected a timely response with evidence about the region’s own rules, not a final nationwide tariff imposed in June.
PDF pp. 112–114, LaCerte concurrenceOffice of the Ohio Consumers’ Counsel · Related public statement
Ohio’s consumer advocate asked FERC to give state consumer offices the same confidential access available to commissions. Customers need an advocate who can test costs and curtailment decisions, it argued. Its November 9 request challenges the October order. It does not ask PJM to publish customer records.
PDF pp. 14, 18–19Office of the Ohio Consumers’ Counsel · Direct response
OCC sought rehearing of the October 9 order. It asked FERC to reject the registry unless PJM grants consumer advocates access under confidentiality agreements.
PDF p. 19Pennsylvania Public Utility Commission · Related public statement
Pennsylvania’s commission supported creating a registry but wanted state commissions to have access and wanted PJM to record curtailments. Its comments addressed the proposal before FERC rejected interim curtailment service.
PDF p. 8, section II, Large Load RegistryOrganization of PJM States · Related public statement
OPSI wanted meaningful state access to the registry to set retail curtailment rules and allocate costs. Its September comments distinguish the registry, which it supported, from the compensation mechanism it challenged.
PDF p. 7, section I.DPennsylvania Public Utility Commission · Direct response
Pennsylvania’s commission supported creating a registry but wanted state commissions to have access and wanted PJM to record curtailments. Its comments addressed the proposal before FERC rejected interim curtailment service.
PDF p. 8, section II, Large Load RegistryOrganization of PJM States · Direct response
OPSI wanted meaningful state access to the registry to set retail curtailment rules and allocate costs. Its September comments distinguish the registry, which it supported, from the compensation mechanism it challenged.
PDF p. 7, section I.DOrganization of PJM States · Related public statement
OPSI supported the registry because states need verified data to allocate retail costs and decide how to curtail load. Its separate objection concerned automatically compensating curtailed projects. Three commissions abstained on the combined comments; that is not a vote against the registry.
PDF pp. 1, 7–10, footnote 2 and sections I.D–IIIGoogle · Direct response
FERC records Google’s request to accept the registry on its own. Google argued that getting better large-load data need not depend on approval of PJM’s wider curtailment and compensation design.
PDF p. 16, ¶36, citing Google protest pp. 3, 18Google · Related public statement
In the original proceeding Google argued that FERC could accept the registry without accepting the remaining interim-service terms. This predates PJM’s compliance filing implementing that separation.
PDF p. 16, ¶36, citing Google protest pp. 3, 18Independent Market Monitor for PJM · Related public statement
The market monitor distinguished enrollment data from real-time telemetry. It said PJM had not shown how it would measure an actual reduction in the proposed interim service.
PDF p. 18, ¶40Independent Market Monitor for PJM · Direct response
The market monitor distinguished enrollment data from real-time telemetry. It said PJM had not shown how it would measure an actual reduction in the proposed interim service.
PDF p. 18, ¶40Data Center Coalition · Direct response
The coalition asked FERC to reject the reliability proposal without prejudice and require substantive standards in the tariff itself. It said future changes should be filed with FERC rather than made outside the tariff.
PDF pp. 4–5Midwest Transmission Dependent Utilities · Direct response
The utilities said MISO’s answer disclaimed applying the rules to distribution-connected loads but the tariff still did not say so unambiguously. They wanted the tariff to explain how a utility could assign a compliance task to the large load.
PDF p. 2Mississippi and Arkansas Public Service Commissions · Direct response
The two commissions asked FERC to condition acceptance on putting the specific requirements in the tariff. They said MISO could otherwise change costly requirements through business manuals without comparable review. These are not the same signatories as the LARS comments from Mississippi and Louisiana.
PDF pp. 1–2Southern Maryland Electric Cooperative · Related public statement
The cooperative asked who bears liability when a distributor reports information obtained from another party, how it could recover its compliance costs, and whether the reporting manual would be filed for review.
PDF pp. 16–17, ¶37Southern Maryland Electric Cooperative · Direct response
The cooperative asked who bears liability when a distributor reports information obtained from another party, how it could recover its compliance costs, and whether the reporting manual would be filed for review.
PDF pp. 16–17, ¶37New York Independent System Operator · Direct response
NYISO explained that if the market and transmission proposals cannot cover a reliability need, it may refer a non-transmission solution to the New York Public Service Commission. The state commission then considers the project and cost recovery. This is NYISO’s description of the process, not a state endorsement of a project.
PDF pp. 7–8Chairman Laura Swett · Related public statement
Swett said the original procurement arrived too late for a deficiency letter or further evidence. She urged a prompt section 205 filing to repair the rejected terms. Her September concurrence did not address the later timetable.
PDF p. 92, Swett concurrenceChairman Laura Swett · Direct response
Swett said the original procurement arrived too late for a deficiency letter or further evidence. She urged a prompt section 205 filing to repair the rejected terms. Her September concurrence did not address the later timetable.
PDF p. 92, Swett concurrenceFirstEnergy Service Company · Related public statement
FirstEnergy said the original shortfall charge stopped once a generator reached commercial operation. It questioned whether a seller then had sufficient incentive to perform throughout its 15-year term.
PDF p. 13Organization of MISO States · Direct response
OMS said the report does not fully reflect state proceedings on resource planning, retail rates and utility approvals because MISO is not a party to those proceedings. It wanted regional planning to complement, rather than displace, state responsibility for adequacy.
PDF pp. 1–3OPSI and PJM Governors’ Collaborative governance negotiating team · Related public statement
Before the vote, the states’ negotiating team opposed the members’ term sheet. The team said the proposed supermajority requirement would let private members decide whether a state proposal received equal consideration at FERC. It preferred a direct route for states to be heard.
PDF p. 1, September 29 letterNew England States Committee on Electricity · Direct response
NESCOE, the committee representing the six New England states, supported the requested delay. It wanted the states and stakeholders to be able to examine proposed tariff changes through the region’s existing process.
PDF pp. 1–4Organization of MISO States · Direct response
OMS supported time for a coordinated sequence of filings but said granting abeyance should neither narrow the inquiry nor prejudge that the coming tariff changes would settle every issue.
PDF pp. 2–3, 5Corporate Energy Buyers Association · Direct response
CEBA backed the California parties’ requests for 90 more days. It argued that testing proposals with stakeholders before filing could improve their commercial viability and legal durability.
PDF pp. 1–2Commissioner David Rosner · Related public statement
At the July hearing Rosner told Senator McCormick that market rules can send investment signals, but those signals lose force if states do not trust how prices are set. He wanted states involved in regional planning.
PDF pp. 69–70, printed pp. 65–66Organization of PJM States, recorded member positions · Direct response
OPSI backed a supplemental purchase. Its filing names support from Delaware, D.C., Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee and Virginia commissions. The West Virginia commission did not support the comments. OPSI also wanted to recalculate the target when projects withdrew.
PDF pp. 1–4, footnote 2 and commentsOrganization of PJM States, recorded member positions · Direct response
Delaware, D.C., Illinois, Indiana, Maryland, Michigan, New Jersey, North Carolina, Pennsylvania, Tennessee and West Virginia commissions supported OPSI’s comments. Kentucky, Ohio and Virginia commissions abstained. The vote covered the whole filing: OPSI supported a registry but wanted clarification or separate treatment of curtailment compensation.
PDF pp. 1, 7–10, footnote 2 and sections I.D–IIIMidcontinent Independent System Operator · Related public statement
MISO proposed LARS in a separate section 205 docket. It argued that modeling a matched pair could identify upgrades for the combination instead of each project separately. This was one proposed response to the June concerns, not a final decision on the full show cause case.
PDF pp. 2–3, 15Mississippi and Louisiana Public Service Commissions · Direct response
The commissions backed a 120-day joint study. They said studying the load and its generator together could avoid duplicating network upgrades; the limit of ten pairs per period made it manageable. They wanted a permanent process so projects could plan and finance construction.
PDF pp. 2–3Arkansas Public Service Commission · Direct response
Arkansas expressly agreed with the Mississippi and Louisiana commissions’ comments and asked FERC to accept MISO’s tariff changes. It did not offer its own numerical estimate of costs or queue delays.
Comments of the Arkansas PSC, concluding paragraph (unpaginated)Entergy and Cleco · Direct response
The utilities said some ordinary MISO study cycles had taken four years or more. They supported the 120-day path and argued that its cap of ten load-generator pairs per study period would keep it workable.
PDF pp. 2–3, 5Bloom Energy · Direct response
Bloom backed the study but challenged its 200 MW entry threshold. It proposed letting transmission-connected loads of at least 50 MW participate and asked FERC not to delay the requested start date.
PDF pp. 1, 4–5Midcontinent Independent System Operator · Direct response
MISO defended 200 MW based on its experience with large-load studies. It said modeling the load and several associated plants together offered the largest potential savings where loads and upgrades were especially large.
PDF pp. 23–24Morongo Transmission LLC · Direct response
Morongo said it leases transmission capacity and receives revenue through CAISO’s access charge. Because it serves no end-use customers, it argued that its own tariff needed no amendment. It still intended to participate in the proceeding.
PDF pp. 1–3Six Cities and Western Area Power Administration · Related public statement
These public owners committed to coordinate with CAISO and file changes if necessary. FERC rescinded the show cause order as to them; the other California respondents remained in the case.
Commission determination on Six Cities and WAPA (unpaginated)Clean Energy Advocates · Direct response
The advocates warned that two study tracks using different assumptions could count the same unused transmission capacity twice. They challenged assigning upgrade costs to existing customers based on agreements whose terms FERC had not seen.
PDF p. 18Commissioner David Rosner · Related public statement
Rosner supported directing costs to zones whose data center growth drove the shortfall. He called on states to set retail tariffs, enforce collateral and decide curtailment priorities. He wanted a return to ordinary hedging and capacity procurement after the backstop.
PDF p. 93, Rosner concurrenceCommissioner Lindsay See · Related public statement
See wanted dependable generation quickly but said the first proposal left existing customers exposed. Better evidence about which projects will actually connect should guide who pays for the resulting capacity.
PDF p. 94, See concurrenceCommissioner David LaCerte · Related public statement
LaCerte urged PJM to refile promptly rather than wait for more briefs. He said new loads should pay for the capacity they require and cited the commitment to build, bring or buy that capacity.
PDF pp. 96–97, LaCerte concurrenceOffice of the Ohio Consumers’ Counsel · Related public statement
On rehearing of the September order, OCC argued that households should not pay to cover a shortfall caused by data centers. It separately questioned FERC’s decision to allow sellers to receive their own bid prices.
PDF pp. 15, 21–23Northern Virginia Electric Cooperative · Related public statement
NOVEC identified causes of the capacity shortage besides growth in large loads. It preferred voluntary subscription, with interruptible service for a customer that declined. It is a cooperative, not the Virginia regulator.
PDF pp. 3–5, 16Commissioner David Rosner · Direct response
Rosner supported directing costs to zones whose data center growth drove the shortfall. He called on states to set retail tariffs, enforce collateral and decide curtailment priorities. He wanted a return to ordinary hedging and capacity procurement after the backstop.
PDF p. 93, Rosner concurrenceCommissioner Lindsay See · Direct response
See wanted dependable generation quickly but said the first proposal left existing customers exposed. Better evidence about which projects will actually connect should guide who pays for the resulting capacity.
PDF p. 94, See concurrenceCommissioner David LaCerte · Direct response
LaCerte urged PJM to refile promptly rather than wait for more briefs. He said new loads should pay for the capacity they require and cited the commitment to build, bring or buy that capacity.
PDF pp. 96–97, LaCerte concurrencePennsylvania Office of Consumer Advocate · Direct response
The office argued that PJM was asking states to determine the shares suppliers would owe under a wholesale rate. It asked FERC to reject that design or explain how the new allocation would respect the line between state and federal authority.
PDF pp. 3–5Pennsylvania Office of Consumer Advocate · Related public statement
Pennsylvania’s consumer advocate objected to relying on states to determine wholesale obligations in the original July proposal. The distinction between a wholesale supplier’s share and retail cost recovery remained relevant when PJM refiled.
PDF pp. 3–5Office of the Federal Energy Advocate, Public Utilities Commission of Ohio · Direct response
FERC records support from the PUCO office for allowing states to determine the allocation to large loads. This is a different office and a different issue from the Ohio Consumers’ Counsel request for confidential registry access.
PDF p. 47, responsive pleadings, citing Ohio FEA comments p. 4