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`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
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`PJM Interconnection, L.L.C., et al.
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`PJM Interconnection, L.L.C.
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`Docket No. EL25-49-000
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`Docket No. ER24-2172-000
`(not consolidated)
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`ANSWER OF
`TALEN ENERGY CORPORATION
`IN OPPOSITION TO
`VISTRA CORP.’S MOTION FOR CLARIFICATION
`AND REQUEST FOR EXPEDITED TREATMENT1
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`Talen Energy Corporation (“Talen”) urges the Commission to act as soon as possible to
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`opine on the merits of Talen’s November 20, 2024 Request for Rehearing in Docket No. ER24-
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`2172-000 (the “SSES ISA Docket”).2 The Motion for Clarification and Request for Expedited
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`Treatment filed by Vistra Corp. (“Vistra”) in Docket No. EL25-49-000 (the “Co-Location Show
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`Cause Docket”) requests that the Commission act on a narrow subset of the issues raised in Talen’s
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`Request for Rehearing and closely mirrors the issues Vistra raised in the Motion for Clarification
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`it filed in the SSES ISA Docket.3 With respect, the Commission should not, at Vistra’s request,
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`act in a piecemeal manner. Talen does not seek piecemeal answers and therefore asks that the
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`Commission deny Vistra’s motion. Instead, the Commission should issue an order as
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`expeditiously as possible that substantively addresses all of the issues raised in Talen’s Request
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`for Rehearing.4
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`1 This answer is submitted pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy
`Regulatory Commission (“Commission” or “FERC”).
`2 PJM Interconnection, L.L.C., Docket No. ER24-2172-000, Request for Rehearing of Susquehanna Nuclear, LLC
`(Nov. 20, 2024) (“Request for Rehearing”).
`3 PJM Interconnection, L.L.C., Docket No. ER24-2172-000, Motion for Clarification of Vistra Corp. (Dec. 2, 2024).
`4 Talen filed a Petition for Review with the United States Court of Appeals for the Fifth Circuit that broadly challenges
`the Commission’s Order Rejecting Amendments to Interconnection Service Agreement issued in Docket No. ER24-
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`I.
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`ANSWER
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`Talen filed a Request for Rehearing in response to the Susquehanna ISA Order several
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`months ago and waits for the Commission to take substantive action on its request.5 When it does
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`speak, the Commission should provide more certainty on all the issues raised in Talen’s rehearing
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`request. For instance, Talen avers in its Request for Rehearing that the Commission departed from
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`the “necessity standard” it has historically used to evaluate the need for deviations from the pro
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`forma Interconnection Service Agreement in the Susquehanna ISA Order.6 The Request for
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`Rehearing also asks the Commission to clarify its usage of the new “unique interest” standard
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`which it used to evaluate Susquehanna’s amended Interconnection Service Agreement.7 Without
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`an understanding of the circumstances under which the unique interest standard will be applied
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`and how to meet the standard, Regional Transmission Organizations and Independent System
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`Operators will be unable to detail the rationale for essential modifications with terms acceptable
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`to the Commission.
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`The Commission’s November 1, 2024 order erred in its rulings on these issues and an
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`appeal is pending. Redress on these issues is just as important to Talen as the issues Vistra
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`selectively included in its motion. Talen would welcome a prompt and comprehensive order
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`granting rehearing. Indeed, granting Talen’s Request for Rehearing would be logically consistent
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`with, and inclusive of, the findings Vistra seeks. Talen would welcome these findings as part of a
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`comprehensive order granting Talen’s rehearing request.8
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`2172-000 on November 1, 2024, including issues that go beyond those raised by Vistra in its motion. Susquehanna
`Nuclear, LLC v. Federal Energy Regulatory Commission, No. 25-60019 (5th Cir. 2025).
`5 See generally Request for Rehearing,
`6 Id. at 8-12.
`7 Id.
`8 Vistra requests the Commission to clarify that “the Susquehanna ISO Order should not be read to (1) prejudge the
`permissibility of any particular co-location configuration, (2) indicate that the Commission generally opposes fully
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`2
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`Simply put, the clarifications Vistra seeks should be made in the SSES ISA Docket, where
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`the Commission can address all the issues pending before it. As such, rather than issuing an order
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`responding to Vistra’s selective requests in the Co-Location Show Cause Order docket,9 the
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`Commission should deny Vistra’s motion and promptly issue an order granting Talen’s Request
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`for Rehearing in the SSES ISA Docket.
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`II.
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`CONCLUSION
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`For the aforementioned reasons, we respectfully ask the Commission to deny Vistra’s
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`motion and provide the relief Talen requests.
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`Respectfully submitted,
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`/s/ William S. Scherman
`William S. Scherman
`Melinda J. Warner
`Vinson & Elkins LLP
`2200 Pennsylvania Avenue NW
`Suite 500 West
`Washington, DC 20037
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`Jennifer Mansh
`Talen Energy Corporation
`Senior Vice President, Regulatory and
`External Affairs
`600 Hamilton St.
`Suite 600
`Allentown, PA 18101
`Jennifer.Mansh@TalenEnergy.com
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`Counsel for Talen Energy Corporation
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`April 9, 2025
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`isolated behind the meter co-located load, or (3) prohibit parties form following the currently effective tariff rules and
`negotiating the terms of non-conforming ISAs pursuant to existing tariff provisions.” Motion at 5.
`9 PJM Interconnection, L.L.C., et al., Docket No. EL25-49-000, Order Instituting Proceeding Under Section 206 of
`the Federal Power Act and Consolidating with Other Proceedings (“Show Cause Order”).
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`3
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`CERTIFICATE OF SERVICE
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`I hereby certify that I have this day served the foregoing document upon each person
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`designated on the official service lists compiled by the Secretary in these proceedings.
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`Dated at Washington, DC, this 9th day of April 2025.
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`/s/ Melinda J. Warner
`Melinda J. Warner
`Vinson & Elkins LLP
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`4
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