Reliability Technical Conference Comments from PJM Interconnection, L.L.C. (Christopher Pilong, Panel 1)
Topics in the text: Reliability and curtailment
What the document says
PDF p. 3
PJM says large loads arrive in two years while generation takes three and transmission seven.
A data center may seek interconnection within two years, while new generation can take three years or more to come online and major transmission facilities can take seven years or more. PDF p. 3
PDF p. 3
PJM says large loads must be flexible or curtailable until supply is built.
Large Loads must provide sufficient operational flexibility or be subject to load reductions until the generation and transmission needed to serve them have been studied and placed in service. PDF p. 3
PDF p. 4
PJM wants voltage and frequency ride-through rules for new and existing large loads.
the requirements should apply, as legally and technically appropriate, to both new and existing Large Loads. PDF p. 4
PDF p. 4
PJM cites a 3,900 MW load drop on July 22, 2026 as proof.
including the sudden transfer of approximately 3,900 MW of load off grid on July 22, 2026. PDF p. 4
PDF p. 4
PJM cites a 3,900 MW load drop on July 22, 2026 as proof.
In July 2024, approximately 1,500 MW of load transferred off grid in response to a system fault in Northern Virginia. PDF p. 4
PDF p. 4
PJM wants corrective action when a large load performs differently from its submitted models.
Where a facility’s actual performance differs from its submitted models or approved settings, the applicable framework should provide for corrective action, operating restrictions, or other consequences PDF p. 4
PDF p. 3
PJM says it has needed DOE 202(c) emergency relief it historically did not.
PJM historically has not needed to seek such relief under comparable temperatures and seasonal conditions. PDF p. 3
PDF p. 5
PJM warns a malicious actor could swing data center load through workload-management systems.
A malicious actor, however, could seek access to a data center’s workload-management systems, manipulate computing activity, and create abrupt load increases or losses. PDF p. 5
PDF p. 6
PJM wants NERC standards to cover large computational loads.
NERC reliability standards should address the operational and cybersecurity obligations appropriate to those facilities. PDF p. 6
PDF p. 6
PJM cites reports of 30 GW of gas plants for data centers within five years.
Recent reports indicate that as much as 30 GW of gas-fired generation may be developed to serve data-center load over the next four to five years. PDF p. 6
PDF p. 6
PJM says data centers at 80-90% capacity factors raise base demand all year.
Data centers with capacity factors of 80–90% increase the system’s base demand and therefore the need for resources capable of serving sustained load. PDF p. 6
PDF p. 7
PJM asks FERC to align energization with available infrastructure.
PJM respectfully requests that the Commission use this technical conference to advance a coordinated reliability framework for Large Loads PDF p. 7
Responses and related views
No section-specific public response is linked for this document.
Source sections
Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
Opening text
opening text
For Public Use Reliability Technical Conference Comments from PJM Interconnection, L.L.C.Read this passage
Summary
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Given their potential effect on system reliability, Large Loads must provide sufficient operational flexibility or be subject to load reductions until the generation and transmission needed to serve them have been studied and placed in service.Read this passage
RTOs Need Detailed Site Information About Large Loads Seeking to Interconnect
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They must provide—and be held accountable for providing—accurate information on an ongoing basis and must ensure any changes they make are appropriately coordinated with the entities they affect (e.g., Transmission Owners, Transmission Operators, Balancing Authorities, etc.).Read this passage
How PJM Is Responding to the Rapid Interconnection of Large Loads and Technologies like Inverter Based Resources
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One example is PJM’s Primary Frequency Response review, as the September 10, 2026 PJM Operating Committee presentation shows.2 In addition, PJM must obtain sufficient reserves via markets to address Essential Reliability Services.Read this passage
Physical And Cybersecurity Risks Posed by Large Load Integration
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Physical And Cybersecurity Risks Posed by Large Load Integration The physical and cybersecurity risks presented by Large Load vary.Read this passage
How PJM Is Addressing Fuel Issues and Issues Posed by Behind-the-Meter and Front-of-the-Meter Gas-Fired Generation Resources on the Same Natural Gas Pipelines
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PJM also must retain a portfolio able to meet seasonal and weather-driven demand that varies by hour and time of year.Read this passage