In comments on PJM’s position regarding provisions addressing co-located load and generation, EPSA and P3 highlight the insufficiency of PJM’s answer to FERC and urge the Commission to convene a 90-day settlement process to develop the revisions needed to remove barriers to co-location arrangements
Date: April 23, 2025
Venue: Federal Energy Regulatory Commission
Proceeding: Show Cause Proceeding on PJM Co-Location Tariff Provisions, Docket EL25-49-000 et al.
On April 23, EPSA and the PJM Power Providers Group (P3) filed joint comments responding to the PJM and PJM Transmission Owners answers to a Show Cause Order from FERC asking them whether existing tariff provisions accommodate co-located load arrangements.
EPSA and P3 refute PJM’s stance that its Tariff is sufficient and explain why the RTO must undertake revisions necessary to remove barriers to co-location arrangements on an expedited, time-limited basis.
Noting that there is some novelty and innovation to the array of co-location configurations that may emerge and highlighting issues that need to be addressed, EPSA and P3 recommend that the Commission convene an expedited time-limited settlement process so that PJM can work with its states and members to identify and develop the improvements and clarifications needed to accommodate co-location arrangements.
