Hearings, Meetings, Proceedings, etc.: PJM Governance and Stakeholder Reforms; Third Supplemental Notice of Commission-Led Technical Conference

The Organization of PJM States, Inc. (OPSI) supports the Commission's convening of a technical conference to reform PJM's governance and stakeholder processes. They advocate for giving PJM the authority to independently propose changes to its Operating Agreement and for establishing formal mechanisms that allow states to have a meaningful role in resource adequacy and transmission cost allocation decisions.

Joseph Bowring, representing Monitoring Analytics, LLC (the Independent Market Monitor for PJM), supports the proposed governance and stakeholder reforms. He argues for strengthening the independence of the PJM Board and staff from PJM members, increasing transparency in meetings, and enhancing the role of state representatives in the decision-making process.

Jameson Tweedie, representing the Delaware Division of the Public Advocate, supports reforms to PJM governance to prioritize affordability, transparency, and state input. He proposes embedding affordability into governing documents, updating voting structures to be sector-weighted, formalizing the role of states, and increasing public accountability.

The National Caucus of Environmental Legislators, a group of state lawmakers, supports the PJM governance and stakeholder reforms. They urge FERC to establish a formal governance role for state interests, increase transparency, and codify a public interest mandate within PJM's operating agreement.

Joseph Bowring, representing Monitoring Analytics, LLC (the Independent Market Monitor for PJM), supports the proposed governance and stakeholder reforms. He argues for strengthening the independence of the PJM Board and staff from PJM members, increasing transparency in meetings, and enhancing the role of state representatives in the decision-making process.

LS Power Development, LLC supports the Commission's efforts to reform PJM governance but argues that current resource adequacy issues are primarily driven by market rules and physical constraints rather than governance alone. The company recommends specific enhancements to PJM's governance, such as requiring the Board to explain its reasoning, relaxing ex parte rules, and expanding state participation through the OPSI.

Mason Emnett, representing Constellation Energy Generation, LLC, supports the Commission's efforts to identify actionable reforms to PJM's stakeholder process and governance. The commenter argues for improved state participation and leadership-driven decision-making while emphasizing the need to preserve PJM's independence and existing authority.

Pamela Quinlan, a consultant and former FERC official, argues that PJM's governance reform should focus on strengthening the regional compact and empowering the Board to exercise independent leadership rather than just redistributing stakeholder influence. She emphasizes the need for a more strategic partnership with states and a better alignment of responsibility for resource adequacy with the actual infrastructure requirements.

Pat Wood III, writing as Executive Chairman of Hunt Energy Network, supports the proposed governance and stakeholder reforms for PJM. He provides specific recommendations to improve transparency, clarify state engagement channels, and simplify decision-making processes based on best practices from other RTOs and ISOs.

PJM Interconnection, L.L.C. supports the Commission's examination of governance and stakeholder reforms to improve the speed and efficiency of addressing regional electricity market needs. They specifically advocate for unconditioned Federal Power Act section 205 filing rights over core functions and the implementation of time gates and expedited processes to prevent stalemates on high-impact issues.