Rural America is served by about 2000 public electric companies serving about 57 million people. Working together at APPA, they are worth including in the analysis. This is how public power argued cost causation should work, filed three weeks before the PJM Board picked a different mechanism. The controversial RBP is technologically obsolete, which is why I looked at other proposals.
Important facts
American Municipal Power submitted this executive summary on June 23, 2026, as agenda item 02d for PJM’s Critical Issue Fast Path — Reliability Backstop Procurement (CIFP-RBP) stakeholder committee meeting on June 30, 2026. The proposal, called FRR-LL, adapts PJM’s existing Fixed Resource Requirement (FRR) product: incremental large-load growth would have to show matching capacity commitments for delivery years 2030/2031 through 2037/2038, an eight-year span cut down from AMP’s original ten-year design after Stage 2 and Stage 3 stakeholder feedback.
Under FRR-LL, a large load or its load-serving entity would file capacity plans annually. The first four years’ plans would be due immediately; years five through eight would be filed one year at a time. A Plan Inaccuracy Charge applies to the first four years to discourage inflated or padded forecasts, then sunsets. A deficiency charge, set equal to PJM’s existing FRR deficiency charge, applies across the full eight years if committed capacity comes up short of the load served — unless the load instead elects PJM’s Connect and Manage service.
Eligible new capacity: any new incremental UCAP megawatt not already carrying a must-offer obligation, of any resource type, in front of or behind the meter. Committed capacity has to equal the load’s requirement and sit in the same PJM zone, but the plan’s contents are fully tradable among FRR-LL entities, and any surplus can be sold into the Base Residual Auction under existing FRR rules.
AMP ties the design to principles it attributes to the National Energy Dominance Council and to PJM-region governors — immediate commitment of new generation to serve large loads, and cost allocation confined to those loads. On PJM’s separately-developed centralized procurement (which the document describes as starting in September), AMP proposes one change: let LSEs bid demand quantities directly into the auction instead of PJM setting the procurement quantity administratively, with PJM keeping authority to add parameters to shape the outcome.
AMP lists four changes made after Stage 2 and 3 feedback: a safe harbor for load growth by smaller large loads, so the requirement doesn’t chill local economic development; sunsetting the Plan Inaccuracy Charge after year four; cutting the applicability window from ten years to eight; and broadening the definition of “New Capacity” to include prior prospective large-load contracts that would have counted as new when signed — and, in the same sentence, to include Demand Response. That last point sits oddly next to an earlier passage in the same document that excludes Demand Response from new-capacity eligibility “due to the difficulty of verifying that new Demand Response is in fact new.” The document doesn’t reconcile the two.
What the proposal does
AMP frames FRR-LL as an addition to, not a replacement for, whatever centralized procurement the Board runs. Because it’s built on the FRR product PJM already administers, AMP argues it needs no large body of new rules — the accounting mechanism at its core, AMP says, could be adopted whole or layered onto another Board-selected design as an add-on.
The closing section is explicitly a menu, not a demand: AMP invites the Board to take pieces from competing proposals rather than pick one wholesale, and offers FRR-LL’s load-forecasting and cost-allocation features as components available either way.
Author and credits
American Municipal Power, Inc. describes itself as a nonprofit wholesale power and services provider for more than 130 municipally owned electric systems across nine states. The document carries no named individual author; AMP submits it institutionally as agenda item 02d for PJM’s CIFP-RBP stakeholder committee, dated June 23, 2026, presented June 30, 2026.
Link
Summary
AMP’s core claim is that routing large-load capacity costs through the FRR product — rather than through a centrally administered backstop auction — ties costs more directly to the load causing them, and gives PJM better forecasting information, because the utilities serving those loads know earliest and most precisely where and when load will materialize.
That argument cuts against the design PJM staff was building in parallel: a single centralized auction run by PJM to fill a shortfall administratively, rather than a bilateral, entity-by-entity accounting exercise. AMP doesn’t argue against the centralized design outright. It proposes one amendment (LSE-submitted buy bids) and positions FRR-LL as a companion mechanism the Board could add on top, not a replacement it’s fighting for.
The one place the document doesn’t hang together cleanly is Demand Response eligibility, excluded on verification grounds in one section and folded into a broadened “New Capacity” definition in another. Anyone using this document as a clean statement of AMP’s position on DR participation should flag that tension rather than pick whichever line supports their read.
Conclusions
AMP wrote this before PJM’s actual shortfall target was public. The PJM Board’s July 27, 2026 decisional letter — three weeks after this filing — set the Reliability Backstop Procurement’s initial target at the shortfall from the 2028/2029 Base Residual Auction (reported elsewhere as roughly 6,831 MW UCAP) and explicitly proposed excluding Fixed Resource Requirement load and supply from that procurement and its cost allocation. FRR-LL, built on adapting FRR, is therefore not the mechanism PJM’s Board chose. Nor was the proposal that actually won a stakeholder supermajority vote in the CIFP process (the Joint EDCs & Data Center Coalition’s Reliability Backstop Procurement package) — the Board’s letter says that one didn’t provide sufficient assurance the shortfall capacity would actually get procured. PJM’s own centralized-procurement design went to FERC instead, under docket ER26-3380.
edited and authored by Dave with close collaboration by Claude