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Preliminary Response of PJM Interconnection, L.L.C. to the Operating Plan of Mirant Potomac River, LLC

Docket No. EO-05-01. In summary, PJM understands the difficulty facing the Department in having to balance the important conflicting interests presented here. However, PJM does not regard Option A as anywhere close to striking the correct balance. The improvement offered by Option B reduces the reliability risks by leaving less potential load uncovered in the event of an emergency and in lessening the call time should it be necessary to dispatch idled units at Potomac River to cover such load. Option B, however, is not an operating state that PJM would accept for any length of time under normal circumstances.

As is true for both the Department and PEPCO, PJM expects Mirant will return with a further refinement of its proposed operating plan that offers greater reliability protection for the District of Columbia. In this event, PJM requests that it be permitted to reserve the right to comment further on any such additional filing that Mirant may make.