Vistra Corp. has submitted the following document to the Federal Energy Regulatory Commission: UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION PJM Interconnection, L.LC))))) Docket No. ER26-1479-000 PROTEST OF VISTRA CORP.

Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (?Commission?), Vistra Corp. (?Vistra?) hereby submits this protest to PJM Interconnection, L.L.C?s (?PJM?) compliance filing filed on February 23, 2026, in the above-captioned docket. On December 18, 2025, this Commission issued a landmark Order on Show Cause Proceedings, which established a clear and principled roadmap for the development of co-located facilities in PJM in a manner that ensures both the reliability and affordability of the PJM system.

The Commission?s order clearly delineated a path for enabling the expeditious development and interconnection of co-located facilities. This action was a critical step toward facilitating the development of digital infrastructure in PJM?the single most important region of the country for data centers and the other infrastructure necessary to develop and maintain our world-leading artificial intelligence capabilities. Accepting PJM?s compliance filing would be a step backward from the progress made in that order.

Where the Commission required clarity, PJM has proposed ambiguity by failing to propose a clear transition mechanism to apply to the facilities that have diligently pursued and, in some cases, completed, the necessary study process. Similarly, where the Commission mandated speed, PJM has chosen delay, by proposing a June 1, 2029 effective date for the new transmission services and a revised necessary study process that would appear to not even begin until 2029?a lifetime when it comes to digital infrastructure. Collectively, these two elements, unless changed, could delay integration of co-location configurations until the early 2030s.

And where the Commission required pragmatism, PJM has responded with a truly byzantine proposal for Capacity Interconnection Rights (?CIRs?) that is clear as mud and appears likely to limit backup resources? ability to support resource adequacy where they can. To realize the potential of the December Order, the Commission should direct PJM to file a further compliance that resolves these fundamental flaws, as discussed further below.