Comments Due 5 pm on Friday, January 30!
Urgent Action Requested for Energy Affordability
EEA encourages you to submit comments to PJM by this Friday on whether to reinstate the price collar on the next two capacity market auctions. The price collar put an upper limit on wholesale electricity sales during the last PJM auction—and had it not been there, the impact on electricity bills in the PJM (including PA & NJ) would have been much worse.
The deadline to submit is 5 p.m. January 30. All feedback will be posted publicly, with attribution, on the CIFP-LLA webpage.
Why Do Comments Matter Right Now?
The price cap in place for the past two auctions has expired, and PJM is asking whether it should reinstate it for the next two auctions. All 13 PJM state governors and the White House also included extending the price cap in their Statement of Principles. EEA applauds the efforts of PA Governor Shapiro and his staff to urge PJM to extend the price cap, which was secured through a settlement in January of 2025 but expired in December.
The more responses defending the price cap received by PJM, the more effectively we can counter those who will oppose the cap and stand to profit off of higher capacity market prices. Removing the cap will likely result in windfall payouts to the current load suppliers, mainly traditional fuel generation.
It’s important to note that one of PJM’s proposals in its Critical Issues Fast Path plan (just filed to FERC) is to extend the price cap, but we expect the usual load generation business members of PJM to deliver extensive negative feedback, giving PJM cover to not extend the cap.
Your voice in support of the price cap matters.
How Do I Submit Comments?
Submit your comments to PJM here.
Any organization, business, or association based in or doing business in PJM territory can submit comments, even if they are not a PJM member. Only one response is accepted per firm. If you represent multiple firms, you may submit one set of comments on behalf of multiple firms or one set of comments for each firm.
EEA Collaborators who support extending the price cap have created a template guide for answering PJM’s survey in favor of energy affordability. This guide includes suggested talking points—your comments will be more effective if they’re in your own words!
You’ll be asked to include this information:
- Your first name, last name, phone, and email.
- Whether your response is on behalf of a PJM member company (membership is not required to comment).
- The name of your organization(s).
- Responses to the following questions (you can skip any question by responding “n/a”).
- The existing price collar includes a price cap of $325 and a price floor of $175 adjusted for ELCC changes before each auction. Do you support any extension of the existing price collar? If so, at what level and for what period?
- If you support an extension of the price collar, please provide the justification that you believe should be presented to FERC that supports your proposed level and time period being just and reasonable.
- If you do not support any extension of the price collar, please provide the justification that you believe should be presented to FERC to support the argument that a short-term extension of the price collar is not just and reasonable.
- Not applicable: EEA, KEEA, & EEA-NJ support extending the price collar.
- To the extent you support an extension of the price collar, please explain how you believe such an extension would not adversely impact reliability or investment and when you believe the price collar could be lifted.
- To the extent you oppose an extension of the price collar as inhibiting needed investment in the short term, please indicate the type of projects you believe could come into service during the delivery years covered by these auctions and the potential impact of a collar extension on those project types.
- Not applicable: EEA, KEEA, & EEA-NJ support extending the price collar.
- The Quadrennial Review, cosponsored by the Pennsylvania Public Utility Commission, was overwhelmingly approved by the stakeholders. Should the Board consider a transition mechanism to move from the existing collar to Point A on the demand curve? Please provide your views on whether such a transition would be appropriate and the length and stages of such a transition and its consistency with the stakeholder support of the Quadrennial Review.
What do we actually need PJM to do to protect ratepayers and put clean energy on a level playing field?
As captured in our template feedback, some reforms include: more accurate load forecasting; equitable cost allocation so residential and other business customers are not paying for big data center electricity needs; clearing the PJM Interconnection Queue and quickly processing new interconnection applications to get more cheap energy online more quickly; and adopting market reforms to better value the capacity of renewables and battery storage. See also our advocate letter to PJM.
Some additional context
PJM issued this Board Decisional Letter on Critical Issue Fast Path – Large Load Additions (summary blog can also be found here) on January 16 after its multi-month engagement on incorporating large load additions (mostly data centers) to the grid. In the Decisional Letter, PJM describes some important first steps towards managing the affordability impacts of these data center loads, but does not implement a price collar or similar binding affordability provisions.
IN SUMMARY:
- Submit your comments to PJM by 5 pm on Friday, January 30th.
- You can use this template to help write comment responses.
- If you submit comments, let us know! Use this form.
Questions? Contact Jeaneen Zappa (jzappa@energyefficiencyalliance.org) for more information.