On September 13, 2024, in Docket Nos. ER21-1635-009 and EL21-91-003, PJM submitted a joint Rule 710(d) motion for waiver of the initial decision concurrent with the filing of reply comments in support of the August 14, 2024 Settlement that resolves pending proceedings relating to whether the CRF rates for Black Start Units selected prior to June 6, 2021 remain just and reasonable in light of the reduction in the federal corporate tax rate from the Tax Cuts and Jobs Act of 2017.

On September 13, 2024, in Docket Nos. ER21-1635-009 and EL21-91-003, PJM submitted reply comments in support of the August 14, 2024 Settlement that resolves pending proceedings relating to whether the CRF rates for Black Start Units selected prior to June 6, 2021 remain just and reasonable in light of the reduction in the federal corporate tax rate from the Tax Cuts and Jobs Act of 2017.

On September 13, 2024, in DC Circuit Case No. 24-1120, regarding the United States Environmental Protection Agency’s Final Rule on the regulation of greenhouse gas emissions, PJM, MISO, SPP and ERCOT (together, the “RTOs”) filed an Amicus Curiae Brief. The brief urges the Court to remand the Rule back to the EPA for consideration of the reliability concerns raised by the RTOs consistent with EPA’s legal obligations under Section 111 of the Clean Air Act, more specifically to address the “reliability safety valve” proposals, which the RTOs previously advanced in the EPA’s docket prior to issuing its Final Rule. In those earlier filings of Aug. 8, 2023, and Dec. 20, 2023, the four RTOs outlined their reliability concerns with the compliance deadlines in the then-proposed Rule and further outlined specific mechanisms that would help mitigate reliability and resource adequacy issues the Rule could trigger. In its Final Rule published on May 9, 2024, the EPA made some helpful modifications from the proposed Rule in response to the RTOs’ feedback. However, the Final Rule did not address, let alone adopt, any of the RTOs’ “reliability safety valve” recommendations meant to ensure the development of compliance plans that meet grid reliability needs.