Read topic-matched comments in ER26-3515
Topics in the text: Registry access · Reliability and curtailment · Retail and wholesale authority
PDF p. 11
establishing the threshold to qualify as a Large Load at a cumulative peak of 50 MW strikes a just and reasonable balance between capturing the larger loads into which PJM needs visibility to ensure the reliability of its system PDF p. 11
PDF p. 20
We find that PJM’s proposed Large Load Registry is just and reasonable and not unduly discriminatory or preferential because it will require LSEs to provide information about the Large Loads that they serve to PJM PDF p. 20Filed comments: Registry access
PDF p. 6
the only elements of its proposal that are severable are the proposed definition of Large Load and the proposed Large Load Registry, which can be implemented independent of the IRAS and BYONC frameworks. PDF p. 6Filed comments: Registry access
PDF p. 34
certain aspects of PJM’s proposal appear to present an impermissible intrusion on retail rate regulation and are not subject to the Commission’s authority pursuant to section 205 PDF p. 34Filed comments: Retail and wholesale authority
PDF p. 36
the plain language of the Tariff, as proposed, appears to place obligations directly on the Eligible New Large Loads and requires Electric Distributors to curtail the Eligible New Large Loads. PDF p. 36
PDF p. 36
the proposed Tariff appears to be setting a retail rate because it establishes a compensation rate for IRAS payable to the Eligible New Large Load. PDF p. 36Filed comments: Retail and wholesale authority
PDF p. 42
PJM’s proposal imposes capacity procurement and curtailment obligations on Electric Distributors and LSEs taking NITS to serve certain loads based on retail customer characteristics PDF p. 42Filed comments: Reliability and curtailment
PDF p. 42
PJM’s generic references to these retail customer characteristics without more detail are insufficient evidence PDF p. 42
PDF p. 45
PJM has not sufficiently justified its proposal to lock in the accreditation of BYONC resources over the lifetime of the BYONC arrangement PDF p. 45
PDF p. 47
the risk that a BYONC resource’s locked-in accreditation value be higher than the capacity that it can actually provide has the potential to create a new resource adequacy risk for the entire PJM Region PDF p. 47Filed comments: Reliability and curtailment
PDF p. 6
the proposed rules for BYONC arrangements and the exclusion of Eligible New Large Loads from the VRR curve, are not simply complementary, but instead are inextricably linked. PDF p. 6
PDF p. 6
we recognize the imminent capacity shortfall in PJM, we find that two key aspects of PJM’s proposal—IRAS and BYONC—are either outside of the Commission’s authority or have not been sufficiently demonstrated PDF p. 6
PDF p. 1
beginning in the 2027/2028 Delivery Year, it will be short of sufficient capacity to meet the PJM Region Reliability Requirement, particularly due to data center load growth PDF p. 1
PDF p. 48
PJM’s proposal would shed firm load on an involuntary basis. PDF p. 48
PDF p. 48
It appears that PJM’s proposal ignores the plain language of mandatory Reliability Standard EOP-011-4 PDF p. 48
PDF p. 48
Eligible Customers taking non-firm transmission service on behalf of co-located load should not be charged for capacity because PJM does not procure capacity on their behalf. PDF p. 48
PDF p. 12
we find reasonable PJM’s proposal to include all types of large loads in the Large Load definition. PDF p. 12
PDF p. 12
the one-mile radius paired with the single electrical site requirement is necessary to ensure that loads that are physically located together and affiliated are considered as a single facility PDF p. 12
PDF p. 12
any cutoff criterion would inevitably exclude loads sized just below the threshold, and that alone does not render the definition unjust or unreasonable. PDF p. 12
PDF p. 21
PJM proposes to follow its existing, Commission-approved rules, rules that currently do not allow state consumer advocates or similar entities to have access to this type of information. PDF p. 21Filed comments: Registry access
PDF p. 21
the LSE serving a Large Load is obligated to provide PJM with the information for the Large Load Registry, and the Electric Distributor may provide information when the LSE does not have all the information required readily available. PDF p. 21Filed comments: Registry access
PDF p. 13
we also sever and reject the definition of New Large Load without prejudice. PDF p. 13
PDF p. 49
a 49 MW existing load that increased its consumption by 1 MW would become a 50 MW New Large Load and impose new requirements on the existing NITS customer for the entire 50 MW. PDF p. 49
PDF p. 50
a non-firm transmission service similar to Non-Firm Contract Demand transmission service, with appropriate adjustments, might be considered as a potential avenue to achieve some of the aims of PJM’s proposed IRAS framework. PDF p. 50
PDF p. 43
States have a crucial role to play in this challenge by designating which retail customers must be curtailed when the system is stressed PDF p. 43
PDF p. 56
if PJM chooses to refile its proposal, it must justify its proposal to curtail IRAS load on a mandatory basis before load that has voluntarily enrolled in a demand response program. PDF p. 56
PDF p. 56
The result could be a capacity market signaling that PJM has more than enough capacity while the region sheds thousands of megawatts of demand on an involuntary basis. PDF p. 56
PDF p. 57
data centers not serving critical functions should be shut off before ordinary customers PDF p. 57
PDF p. 1
we accept PJM’s proposed Tariff revisions to establish a definition of Large Load and a Large Load Registry, effective October 12, 2026, as requested, and require PJM to submit a compliance filing within 30 days PDF p. 1Filed comments: Registry access
Office of the Ohio Consumers’ Counsel · Direct response
OCC sought rehearing of the October 9 order. It asked FERC to reject the registry unless PJM grants consumer advocates access under confidentiality agreements.
PDF p. 19Jefferies analysts, quoted by Utility Dive · Direct response
Jefferies saw the rejection of interim service as favorable to existing independent generators. That was an analyst assessment of market effects, separate from the commission’s reasons for its decision.
Ethan Howland, October 12, analyst reactionMary Yang, 804 Advisory, interviewed by Latitude Media · Direct response
Yang, a former PJM regulatory counsel, expected other priorities to delay a rewrite. She said that uncertainty could slow bilateral arrangements between new loads and generators.
Maeve Allsup, October 13, interview with Mary YangCommissioner David Rosner · Direct response
Rosner wanted voluntary demand response called first, followed by noncritical large loads before homes and other ordinary customers. He objected to keeping demand out of the capacity market forecast. His October concurrence predates the November compliance filing.
PDF pp. 55–57, Rosner concurrencePrinted headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Registry access
In this order, we accept PJM’s proposed Tariff revisions to establish a definition of Large Load and a Large Load Registry, effective October 12, 2026, as requested, and require PJM to submit a compliance filing within 30 days of the date of issuance of this order.Read this passage Filed comments: Registry access
PDF bookmark · Topic match: Registry access
ER26-3515-000 - 2 - PJM proposes to establish and maintain; (3) IRAS, which PJM states will involve curtailments during periods when there are insufficient resources to reliably meet demand in real-time operations; (4) a requirement for LSEs serving New Large Load to designate new capacity…Read this passage Filed comments: Registry access
PDF bookmark · Topic match: Filing procedure
On August 28, 2026, OPSI filed a motion requesting an extension of time to submit comments in response to PJM’s filing.Read this passage Filed comments: Filing procedure
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III.Read this passage
printed heading
DiscussionRead this passage
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Pursuant to Rule 214(d) of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.214(d), we grant CyrusOne and Governor Shapiro’s late-filed motions to intervene given their interest in the proceeding, the early stage of the proceeding, and the absence of undue prejudice or delay.Read this passage
PDF bookmark · Topic match: Registry access
Next, PJM proposes to develop a Large Load Registry to foster transparency regarding Large Load additions.Read this passage Filed comments: Registry access
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Large Load Definition and RegistryRead this passage Filed comments: Registry access
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a.Read this passage
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PJM proposes to define Large Load as: end-use customer(s) load that has a cumulative peak load of 50 [MW] or greater at a single electrical site behind one or more points of interconnection, where for configurations involving multiple affiliated load facilities or multiple points of interconnection…Read this passage
PDF bookmark · Topic match: Reliability and curtailment
EKPC argues that PJM does not justify the 50 MW threshold and requests that the Commission should either require PJM to narrow the definitions or to establish objective criteria demonstrating that non-computational load presents the same IRAS-relevant risks.47 The IMM argues that the 50 MW…Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Reliability and curtailment
PJM explains that the term New Large Load is needed to describe the subset of Large Loads that PJM proposes may be subject to curtailment where the LSE does not designate capacity to offset the load.55 Given that we are rejecting these aspects of PJM’s proposal, as discussed below, we also sever…Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Registry access
Large Load RegistryRead this passage Filed comments: Registry access
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PJM proposes to require LSEs to submit information to PJM about the Large Loads they serve, which PJM will maintain in a Large Load Registry.57 Specifically, PJM proposes revisions to Schedule 11 of the RAA to establish a registry of Large Loads in the PJM Region capturing existing Large Loads and…Read this passage Filed comments: Registry access
PDF bookmark · Topic match: Registry access
ER26-3515-000 - 18 - arguing entities with access are subject to onerous and insurmountable confidentiality restrictions.81 Joint Consumer Advocates and Ohio Consumers’ Counsel argue that PJM should allow state consumer advocates access to the Large Load Registry because the information will play a…Read this passage Filed comments: Registry access
PDF bookmark · Topic match: Registry access
PJM explains that the Large Load Registry will be available only to entities that already have access to this sort of information and consistent with existing confidentiality rules, i.e., PJM proposes to follow its existing, Commission-approved rules, rules that currently do not allow state…Read this passage Filed comments: Registry access
PDF bookmark · Topic match: Reliability and curtailment
Below, we find that elements of the package are outside of Operating Agreement] shall submit, or cause to be submitted, to [PJM] the following information, as may be further described in the PJM Manuals, related to each Large Load served by [the entity bound by the Operating Agreement].” Proposed…Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Reliability and curtailment
Pilong explains that IRAS Actions would occur after PJM dispatchers have issued a NERC Energy Emergency Alert Level 1 (EEA1).109 PJM states that IRAS would be suspended 105 PJM explains that an IRAS Action is an “Operating Instruction, as defined by NERC.” Transmittal at 75 (citing Proposed OATT,…Read this passage Filed comments: Reliability and curtailment
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b.Read this passage
PDF bookmark · Topic match: Retail and wholesale authority
PJM likewise argues that its compensation framework respects and reflects the federal and state division of authority.126 PJM asserts that the IRAS rate is compensation for a wholesale load reduction service.127 However, PJM also asserts that the rate is intended to be conjoined with retail rates…Read this passage Filed comments: Retail and wholesale authority
PDF bookmark · Topic match: Reliability and curtailment
In its answer, Google asserts that when it comes to determining whether a rate is jurisdictionally permissible under the FPA, the dispositive question is how it works in practice, not the relevant public utility’s transmittal letter.162 Constellation and Data Center Coalition argue that the express…Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Retail and wholesale authority
We find that certain aspects of PJM’s proposal appear to present an impermissible intrusion on retail rate regulation and are not subject to the Commission’s authority pursuant to section 205 of the FPA.174 We find that several provisions of the proposed Tariff appear to place obligations directly…Read this passage Filed comments: Retail and wholesale authority
PDF bookmark · Topic match: Reliability and curtailment
Undue Discrimination – IRAS CurtailmentRead this passage Filed comments: Reliability and curtailment
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Similarly, PJM points to the Southwest Power Pool, Inc. (SPP) Conditional High Impact Large Load Service (CHILLS) order, where the Commission found that the proposal for new large loads was just and reasonable and not unduly discriminatory or preferential.Read this passage
PDF bookmark · Topic match: Reliability and curtailment
Constellation and the Data Center Coalition argue that PJM’s proposal unfairly creates a subclass of NITS customers—those serving Eligible New Large Loads—who pay the same transmission and capacity rates as other NITS customers but receive inferior service and are subject to involuntary curtailment…Read this passage Filed comments: Reliability and curtailment
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We find that PJM has not currently offered sufficiently detailed evidence concerning how its treatment of Electric Distributors and LSEs taking NITS differently in the resource adequacy context based on the characteristics of their retail customers is not unduly discriminatory.221 PJM’s proposal…Read this passage Filed comments: Reliability and curtailment
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d.Read this passage
PDF bookmark · Topic match: Reliability and curtailment
Only BYONC supported by a demand resource or distributed energy resource Capacity Aggregation Resource may be replaced during the 10-year commitment period, and it must be replaced by another eligible resource willing to fulfill the rest of the 10-year requirement.Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Reliability and curtailment
AMP requests that the Commission direct PJM to modify its proposal to set the level of BYONC for a generation or storage resource at the resource’s accredited capacity in the first year it is in arrangement with a New Large Load.229 AMP argues PJM expects the Effective Load Carrying Capability…Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Reliability and curtailment
We find that PJM has not sufficiently justified its proposal to lock in the accreditation of BYONC resources over the lifetime of the BYONC arrangement to be just and reasonable and not unduly discriminatory or preferential.Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Reliability and curtailment
Should PJM choose to refile a modified version of its proposed IRAS framework that does not infringe on retail rate regulation, we encourage PJM to address the concerns discussed below. 107.Read this passage Filed comments: Reliability and curtailment
PDF bookmark · Topic match: Registry access
Office of the Illinois Attorney General* Office of the Ohio Consumers’ Counsel (Ohio Consumers’ Counsel)* Ohio Energy Leadership Council (Ohio ELC)* Old Dominion Electric Cooperative (ODEC)* Organization of PJM States, Inc. (OPSI)^ Pennsylvania Office of Consumer Advocate Pennsylvania Public…Read this passage Filed comments: Registry access
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I write separately to emphasize that, if PJM chooses to refile its proposal, it must justify its proposal to curtail IRAS load on a mandatory basis before load that has voluntarily enrolled in a demand response program.Read this passage