The Electricity Law Initiative rebutted arguments filed by PJM and its member utilities about their proposed amendments to a contract that is foundational to PJM’s existence. The contract allows PJM to operate energy markets and administer transmission rules that govern the use of the utilities’ transmission assets.
In July, the Electricity Law Initiative protested the utilities’ proposed amendments because they would compromise PJM’s decisionmaking processes for the utilities’ benefit. That initial protest argued that the Federal Energy Regulatory Commission (FERC) should reject the utilities’ filing, and that the utilities’ proposed contract amendments are unnecessary for approving PJM’s separate filings about its regional transmission planning protocol.
The Electricity Law Initiative’s September filing rebutted the utilities’ attempt to link the contract amendments with separate filings by PJM about regional transmission planning. In October, the Electricity Law Initiative responded to PJM’s effort to link its filing about regional transmission planning to the separate proposal filed by the utilities about its contract with PJM. The Electricity Law Initiative’s October comment also rebuts the utilities’ claim that a new dispute resolution process outlined in the new contract is consistent with FERC policy.