Comments Based on Research from the RTO Governance Research Network re the PJM Governance and Stakeholder Reforms under AD26-7.

Summary: Dr. Seth Blumsack, representing the RTO Governance Research Network at Penn State University, submits research-based comments advocating for structural reforms to PJM's governance. He argues for consolidating governing documents, increasing Board independence, empowering states in resource adequacy decisions, and reforming the sector-weighted voting process to improve accountability and decision-making speed.