Docket No. ER26-1556-000
I write separately to underscore the urgent need for PJM and its states to pursue consensus-driven solutions that can bring supply and demand back into balance as soon as possible.
A functional capacity market requires both a solid economic foundation and buy-in from the people that finance, build, permit, and pay for generation. PJM market price signals cannot do the job alone, and it will take partnership with states given their authority over resource procurement and generation and transmission siting.[1] To that end, PJM’s proposal here is one part of broader vision shared by the PJM Board,[2] many of its members,[3] and the Governors of all 13 PJM states.[4] While I understand, and am sympathetic to, protesters’ concerns, I believe that we must recognize the confluence of events that have been unfolding over the past decade[5] and embrace an opportunity to chart a new path for the PJM region.
I do not cast my vote in this docket lightly. Extending the price collar without near-term and long-term changes to both PJM’s market rules and state-level permitting and procurement rules will only make the situation in PJM more challenging. On that score, PJM is pursuing a reliability backstop auction[6] to get needed generation financed in the near-term. In parallel, PJM has indicated its intention to pursue market reforms that will send durable price signals that support investment in new generation.[7] And for their part, the PJM states have signaled support for these initiatives,[8] and have started to make some changes to their permitting regimes[9] and procurement rules.[10]
Now, PJM, its members, and its states must come together to turn good intentions into durable market design and state policies that support needed investment in new energy infrastructure. It won’t be easy. But if all parties come willing to seek consensus in pursuit of a larger victory, I am optimistic that we can achieve a more reliable and affordable grid for the 67 million PJM customers who rely on that grid every day.
For these reasons, I respectfully concur.
[1] See PJM Interconnection, L.L.C., 194 FERC ¶ 61,049 (2026) (Rosner, Comm’r, concurring).
[2] PJM, Board Decisional Letter on Critical Issue Fast Path - Large Load Additions (Jan. 16, 2026), 20260116-pjm-board-letter-re-results-of-the-cifp-process-large-load-additions.pdf.
[3] Id. (noting the PJM members and stakeholders that proposed or supported each of the Board’s decisions, including generation companies, load-serving entities, regulated utilities, state governments, environmental advocates, consumer advocates, and technology companies).
[4] Statement of Principles Regarding PJM, https://www.energy.gov/documents/statement-principles-regarding-pjm.
[5] The complaint that prompted the Commission to order PJM to delay its capacity auctions was filed over ten years ago. See Calpine Corporation, et al., Complaint, Docket No. EL16-49-000 (filed Mar. 21, 2016); see also Calpine Corp. v. PJM Interconnection, L.L.C., 163 FERC ¶ 61,236, at PP 1-2 (2018). Since then, PJM has been in a constant state of triage, running back-to-back capacity auctions to return to its standard three-year-forward cadence while doing its best to design and implement the rules needed to confront a changing grid. The events that have unfolded since the Commission directed PJM to pause its capacity auctions play no small part in my views on PJM’s current path forward.
[6] PJM, Critical Issue Fast Path – Reliability Backstop Procurement PJM Proposal (Apr. 16, 2026), https://www.pjm.com/-/media/DotCom/committees-groups/cifp-rbp/2026/20260416/20260416-item-05---pjm-reliability-backstop-procurement-proposal---paper.pdf.
[7] PJM, Board Decisional Letter on Critical Issue Fast Path - Large Load Additions, at 6-7 (Jan. 16, 2026), 20260116-pjm-board-letter-re-results-of-the-cifp-process-large-load-additions.pdf (directing PJM staff to analyze how the energy, reserve, and capacity markets can evolve in a coordinated manner to provide appropriate incentives for both investment and performance).
[8] See Statement of Principles Regarding PJM, https://www.energy.gov/documents/statement-principles-regarding-pjm (“PJM should immediately embark on a stakeholder process to reform the capacity market to ensure long-term viability and prevent consumers from bearing excessive ongoing costs . . .”).
[9] See, e.g., Office of Delaware Governor Matt Meyer, Governor Matt Meyer Signs Executive Order Streamlining State Permitting Regulations (Feb. 26, 2026), https://news.delaware.gov/2026/02/26/governor-matt-meyer-signs-executive-order-streamlining-state-permitting-regulations/; Mark Lucas, Ohio Revamps its Energy Regulatory Framework (May 28, 2025), https://alec.org/article/ohio-revamps-its-energy-regulatory-framework/.
[10] See, e.g., Christine Guhl-Sadovy, President, NJ BPU, In New Jersey, We’re Leading by Example, Tackling Energy Affordability Head-On (Apr. 23, 2026), https://www.utilitydive.com/news/new-jerseys-approach-to-rising-electricity-prices-bpu-president-guhl-sadovy/817889/ (“[T]he most visible acceleration is occurring in energy storage. . . . The Garden State Energy Storage Program Tranche 1 recently awarded 355 MW across three transmission-scale projects, and Tranche 2 launched simultaneously for the remaining 645 MW of the 1,000 MW statutory mandate. [New Jersey Commission] staff projects more than $169 million in ratepayer savings through increased capacity market competition from the three Tranche 1 projects.”); Jamie DeMarco, Every Single Thing in the Utility RELIEF Act (Apr. 14, 2026), https://demarcoadvocacy.substack.com/p/every-single-thing-in-the-utility (“The Utility RELIEF Act clarifies that the [Marlyand Commission] can procure more than 800 megawatts of battery storage in 2026 and in 2027 if it determines the battery storage to be cost-effective and in the interest of ratepayers”).