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Independent regulatory commissions

PJM Interconnection's Motion for Leave to Answer and Rebuttal to Rehearing Requests

Strategic Insights

— 2 min read

The Federal Energy Regulatory Commission (FERC) has received a motion for leave to answer and answer from PJM Interconnection, L.L.C. in response to rehearing requests from Clean Energy Associations and Public Interest Organizations regarding PJM's proposal to comply with the requirements of Order Nos. 2023 and 2023-A. PJM argues that the Commission's acceptance of its proposed independent entity variation to maintain its current cluster study timeframe was just and reasonable, and that the fact that the Commission's pro forma Large Generator Interconnection Procedures (LGIP) reflect a different timeframe does not render PJM's Tariff unjust or unreasonable.

Key Takeaways:

  • PJM requests leave to answer rehearing requests from Clean Energy Associations and Public Interest Organizations regarding its proposal to comply with Order Nos. 2023 and 2023-A.
  • PJM argues that its cluster study timeframe, including restudies, is just and reasonable, and that a comparison to the pro forma LGIP cluster study timeframe is overly simplistic and unrealistic.
  • The Commission previously accepted PJM's request for an independent entity variation to forego application of a materiality test for its withdrawal penalty provisions.
  • CJean Energy Associations and Public Interest Organizations repeat an argument explicitly rejected in the July 24 Order without providing any demonstration of why the rejection was in error.
  • PJM's Tariff does not contain a withdrawal penalty provision that triggers a materiality test, and PJM's independent entity variation does not affect its Tariff's compliance with Order No. 2023-A.
  • The Commission should uphold the July 24 Order with respect to these independent entity variations.
  • The Commission should deny the CEA Rehearing Request and the PIO Rehearing Request.

Statistics:

  • PJM's cluster study timeframe, including restudies, is 540-day timeline.
  • The pro forma LGIP cluster study timeframe, without restudies, is 150-day timeline.
  • The side-by-side comparison in Figure 1 shows that PJM's cluster study timeframe, including restudies, is not "three times" the length of the pro forma LGIP cluster study timeframe without restudies.
  • The Commission has permitted answers to requests for rehearing when they clarify the disputed issues and provide the Commission with information to assist in its decision-making.

Sources:

  • PJM Interconnection, L.L.C., Mot. for Leave to Answer and Answer of PJM Interconnection, L.L.C., Docket No. ER24-2045-003 (Sept. 9, 2025) ("Motion for Leave to Answer").
  • PJM Interconnection, L.L.C., Partial Request for Rehearing of the Clean Energy Associations, Docket No. ER24-2045-003 (Aug. 21, 2025) ("CEA Rehearing Request").
  • PJM Interconnection, L.L.C., Limited Request for Rehearing of Public Interest Organizations, Docket No. ER24-2045-003 (Aug. 22, 2025) ("PIO Rehearing Request").
  • PJM Interconnection, L.L.C., 192 FERC P 61,077 (2025) ("July 24 Order").
  • Improvements to Generator Interconnection Procedures and Agreements, Order No. 2023, 184 FERC P 61,054, limited order on reh'g, 185 FERC P 61,063 (2023), order on reh'g & clarification, Order No. 2023-A, 186 FERC P 61,199 ("Order No. 2023-A").

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