{"document":{"slug":"statement-ad26-8-pjm-pilong","title":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. (Christopher Pilong, Panel 1)","issued":"2026-10-21","accession":"20261021-4003","docket":"AD26-8-000","group":"2026 FERC reliability technical conference: integrating large loads","filer":"PJM","kind":"pre-conference statement","file":"sources/originals/20261021-4003_Panel 1-PJM -Chris Pilong Testimony.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_number=20261021-4003","sha256":"9a23360b830f7f9a47fb3449cfa2819521c88d53d54ad310d0f3482478ab3616","pages":7,"tokens":2204,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":20,"text":"For Public Use \n \n \n \n \n \n \n \n \n \n \nReliability Technical Conference \nComments from PJM Interconnection, \nL.L.C. \nFERC Reliability Technical Conference, Docket No. AD26-8-000"},{"page":2,"startToken":20,"endToken":109,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \ni | P a g e  \nContents \nSummary ....................................................................................................................................................................... 1 \nRTOs Need Detailed Site Information About Large Loads Seeking to Interconnect ............................................. 2 \nHow PJM Is Responding to the Rapid Interconnection of Large Loads and Technologies like Inverter Based \nResources ..................................................................................................................................................................... 3 \nPhysical And Cybersecurity Risks Posed by Large Load Integration .................................................................... 3 \nHow PJM Is Addressing Fuel Issues and Issues Posed by Behind-the-Meter and Front-of-the-Meter Gas-Fired \nGeneration Resources on the Same Natural Gas Pipelines ..................................................................................... 4"},{"page":3,"startToken":109,"endToken":635,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \n1 | P a g e  \nSummary  \nOn behalf of PJM Interconnection, L.L.C. (“PJM”), I, Christopher Pilong, Senior Director of Operations Planning, \nappreciate the opportunity to provide this written statement for the Commission’s October 21, 2026 reliability technical \nconference.  \nPJM welcomes the opportunity to participate in a public discussion about the state of reliability in our changing energy \nlandscape and, in particular, the operational challenges involved with integrating large loads and addressing evolving \nsystem dynamics. \nThe pace of load growth and emergence and adoption of technologies such as inverter-based resources are presenting \nnovel challenges. PJM is working with stakeholders to respond to those reliability challenges. Both state and federal \naction will be critical to continuing to ensure system reliability. \nMy statement addresses four reliability priorities: the detailed and continuously updated information PJM needs from \nLarge Load operators; PJM’s response to the rapid interconnection of Large Loads and the growing penetration of \ninverter-based resources; the physical and cybersecurity risks associated with concentrated Large Loads; and the fuel-\nsecurity and infrastructure implications of behind-the-meter and front-of-the-meter gas-fired generation that relies on \nshared natural gas pipelines. \nGoing forward, PJM supports a reliability framework that: requires timely, accurate, and continuously updated technical \ninformation from Large Load operators; establishes enforceable voltage and frequency ride-through requirements for \nboth new and existing Large Loads; ensures that interconnection and energization decisions reflect the time required to \ndevelop sufficient generation and transmission; and advances coordinated electric-gas planning, cybersecurity \nprotections, and accountability for facility performance. \nLarge Loads are seeking interconnection in PJM faster than the generation and transmission needed to serve them can \nbe placed in service. A data center may seek interconnection within two years, while new generation can take three \nyears or more to come online and major transmission facilities can take seven years or more. This timing mismatch \ncreates a reliability risk. \nLarge Loads also exhibit very high and relatively constant power utilization, unlike traditional residential, industrial, and \ncommercial load, which generally declines overnight, on weekends, and during the spring and fall shoulder seasons. \nLarge Loads therefore raise the system’s base demand across nearly all hours, producing not only higher summer and \nwinter peaks but also higher demand during spring, fall, and other historically off-peak periods. This change makes it \nmore difficult to maintain reliability during planned transmission and generation outages needed for construction, \nequipment overhauls, and major maintenance. Given their potential effect on system reliability, Large Loads must \nprovide sufficient operational flexibility or be subject to load reductions until the generation and transmission needed to \nserve them have been studied and placed in service. Without those safeguards, reliability for existing customers may \nbe placed at risk. The urgency is illustrated by PJM’s increasing need to seek Department of Energy authorization \nunder section 202(c) of the Federal Power Act to operate generation beyond otherwise applicable limits and potentially \nuse backup generation at data centers and other sites during anticipated emergencies, including over the October 12–\n14, 2026 period. PJM historically has not needed to seek such relief under comparable temperatures and seasonal \nconditions."},{"page":4,"startToken":635,"endToken":1145,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \n2 | P a g e  \nRTOs Need Detailed Site Information About Large Loads Seeking to \nInterconnect \nBecause Large Loads present with various configurations that can affect reliable electric service, it is essential that \nRTOs receive detailed site information about Large Loads seeking to interconnect, including the specific system \nconditions that may trigger a load to switch ‘off grid power’ and move to its UPS or backup generator. Such information \nis necessary for PJM to understand and validate how the Large Load facilities will respond to system events before \nLarge Loads interconnect with the grid, as opposed to having an unexpected response to system conditions in real time \noperations.  \nOngoing participation of the Large Loads in furnishing detailed information to appropriate entities and either directly or \nultimately to the RTOs is critical. They must provide—and be held accountable for providing—accurate information on \nan ongoing basis and must ensure any changes they make are appropriately coordinated with the entities they affect \n(e.g., Transmission Owners, Transmission Operators, Balancing Authorities, etc.).  \nGiven wholesale and transmission system impacts, PJM is exploring pathways to ensure Large Loads are required to \nparticipate in commissioning tests, periodic validation of models and settings, prompt notice of material facility changes, \nevent-data retention, and post-event performance reporting. Where a facility’s actual performance differs from its \nsubmitted models or approved settings, the applicable framework should provide for corrective action, operating \nrestrictions, or other consequences proportionate to the reliability risk. \nLarge Load operators should be subject to consistent performance requirements and standards. PJM has already \nexperienced multiple instances in which Large Loads unexpectedly disconnected from the grid. In July 2024, \napproximately 1,500 MW of load transferred off grid in response to a system fault in Northern Virginia. Two additional \nmajor events have since occurred, including the sudden transfer of approximately 3,900 MW of load off grid on July 22, \n2026. PJM has also observed multiple events outside its footprint. These events demonstrate the need to implement \nvoltage ride-through requirements without delay. \nAs part of its response to the June 18, 2026 Large Load show-cause order, PJM is developing voltage and frequency \nride-through requirements informed by the July 22, 2026 event. Those requirements could have mitigated the event if \nthey had applied to the affected facilities. To reduce the risk of recurrence, the requirements should apply, as legally \nand technically appropriate, to both new and existing Large Loads. The expected magnitude and reliability \nconsequences of future events will increase as concentrated Large Loads continue to grow, making timely action \nessential. \nThe modeling and adherence to voltage/frequency ride through requirements also allows RTOs to direct reinforcements \nto the system that will support the new Large Loads while maintaining the current high level of reliability for existing \ncustomers.  \nPJM has actively participated in the NERC efforts to draft standards pertaining to Large Computational Loads, which \nwill also assist in these efforts and are critical to have in place as soon as possible."},{"page":5,"startToken":1145,"endToken":1609,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \n3 | P a g e  \nHow PJM Is Responding to the Rapid Interconnection of Large Loads and \nTechnologies like Inverter Based Resources \nThere are essential reliability attributes that all generators produce at varying levels that are critical to maintaining grid \nreliability. PJM is considering system reliability needs via markets products, and the development of enhanced \nEssential Reliability Services,1 which are the building blocks of grid reliability. \n PJM and other regions will need to continue to track and value Essential Reliability Services, potentially implementing \nmarket solutions. One example is PJM’s Primary Frequency Response review, as the September 10, 2026 PJM \nOperating Committee presentation shows.2  \nIn addition, PJM must obtain sufficient reserves via markets to address Essential Reliability Services. In this regard, \nPJM’s Reserve Certainty Senior Task Force (“RCSTF”) effort will help achieve sufficient reserves to address \nuncertainty and ramping. The RCSTF proposal was presented at PJM’s September 24, 2026 Markets and Reliability \nCommittee meeting.3 Stakeholders will vote on the proposal at the November Members Committee meeting, and, \nassuming a passing vote, PJM expects to file the proposal at the Commission in December. \nPhysical And Cybersecurity Risks Posed by Large Load Integration  \nThe physical and cybersecurity risks presented by Large Load vary.  \nThe principal physical and cybersecurity risks associated with Large Loads arise from the amount of demand \nconcentrated at individual facilities and within geographic areas. Erratic operation, simultaneous disconnection, or \nmalicious manipulation of multiple facilities could produce sudden load changes that affect grid frequency, voltage, and \nsystem stability. \nThe disruptive Large Load events observed to date appear to have been inadvertent, including the July 22 event \ninvolving the sudden disconnection of nearly 3.9 GW in Virginia. A malicious actor, however, could seek access to a \ndata center’s workload-management systems, manipulate computing activity, and create abrupt load increases or \nlosses. Coordinated manipulation across multiple facilities could activate protection systems and compound the system \neffects observed during an inadvertent event. These scenarios support development of security controls, incident-\nreporting obligations, operational coordination protocols, and recovery requirements proportionate to the grid \nconsequences of concentrated computational load. \n \n1 As described by NERC, Essential Reliability Services include frequency support, voltage support, and ramping capability on the \nBulk Electric System. See NERC Essential Reliability Services Abstract Report, available at \nhttps://www.nerc.com/globalassets/programs/rapa/ra/ers-abstract-report-final.pdf. \n2 The September 10, 2026 Operating Committee presentation addressing the Primary Frequency Response Review is available at \nhttps://www.pjm.com/-/media/DotCom/committees-groups/committees/oc/2026/20260910/20260910-item-06---primary-frequency-\nresponse-update---presentation.pdf. \n3 Reserve Certainty Senior Task Force Overview and Proposal, available at https://www.pjm.com/-/media/DotCom/committees-\ngroups/committees/mrc/2026/20260924/20260924-item-02a---1-pjm-rcstf-proposal-summary---presentation.pdf."},{"page":6,"startToken":1609,"endToken":2131,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \n4 | P a g e  \nBecause large computational loads can materially affect real-time grid operations, NERC reliability standards should \naddress the operational and cybersecurity obligations appropriate to those facilities. The standards should clarify \napplicability, performance expectations, coordination with Reliability Coordinators and Balancing Authorities, event \nreporting, model validation, and cybersecurity protections commensurate with the facilities’ potential effect on the Bulk-\nPower System. \nHow PJM Is Addressing Fuel Issues and Issues Posed by Behind-the-Meter \nand Front-of-the-Meter Gas-Fired Generation Resources on the Same \nNatural Gas Pipelines \nPJM actively considers the implications of fuel availability for gas-fired generation to meet the additional demands of \ninterconnecting Large Loads.  \nGas-fired generation is an important component of PJM’s resource mix. PJM currently has approximately 90 GW of \ninstalled gas-fired generation, of which 80% is served directly by interstate pipelines and 20% is served by local \ndistribution companies. Approximately 29% of gas-fired resources have dual-fuel capability, and 51% have firm gas-\ndelivery arrangements. \nTo minimize reliability threats posed by unavailability of fuel, PJM’s Gas Electric Coordination Team works closely with \ngeneration owners and pipelines. PJM’s team coordinates with generation owners and conducts surveys to ensure \nadequate fuel is available and secured going into peak periods. In addition, when PJM declares a maximum generation \nemergency, there is a focus on fuel inventory for different generation resources, including instructions to generation \nresources to conserve available fuel for critical periods if there is a shortage.  \nRecent reports indicate that as much as 30 GW of gas-fired generation may be developed to serve data-center load \nover the next four to five years. Whether that generation is co-located behind the meter or interconnected in front of the \nmeter, substantial new pipeline capacity and increased gas production may be needed in some areas to support the \ngeneration while maintaining reliable service for existing customers. The need is particularly significant if the generation \nis expected to operate throughout the year to serve data centers with high capacity factors. Meeting rapid energization \ntargets will require early coordination with the natural gas industry and realistic assumptions about siting, permitting, \nconstruction schedules, materials, labor, and fuel-delivery capability. These considerations reinforce the need for close \ngas-electric coordination. \nConsideration should also be given to account for common-mode fuel risks. Multiple behind-the-meter and front-of-the-\nmeter generators serving Large Loads may depend on the same pipeline, compressor station, local distribution system, \nor upstream supply path. PJM and the gas industry therefore need sufficient information to identify correlated \ncontingencies, evaluate deliverability during peak electric and gas conditions, and determine whether firm \ntransportation, dual-fuel capability, on-site fuel, demand flexibility, or other mitigation is needed. \nData centers with capacity factors of 80–90% increase the system’s base demand and therefore the need for resources \ncapable of serving sustained load. PJM also must retain a portfolio able to meet seasonal and weather-driven demand \nthat varies by hour and time of year. PJM’s Commission-accepted Effective Load Carrying Capability analysis (“ELCC”) \nsupports that objective by assessing each resource type’s contribution to resource adequacy during the hours when the \nsystem is most constrained."},{"page":7,"startToken":2131,"endToken":2204,"text":"Reliability Technical Conference Comments from PJM Interconnection, L.L.C. \nPJM © 2026 \nwww.pjm.com | For Public Use \n5 | P a g e  \n* \n* \n* \nPJM respectfully requests that the Commission use this technical conference to advance a coordinated reliability \nframework for Large Loads—one that aligns energization with available infrastructure, requires accurate models and \ndependable facility performance, addresses correlated cyber and fuel risks, and preserves reliable service for existing \ncustomers as the system evolves."}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":132,"startToken":0,"endToken":132},{"p":3,"at":132,"title":"Summary","method":"PDF bookmark","endPage":4,"endAt":132,"startToken":132,"endToken":658},{"p":4,"at":132,"title":"RTOs Need Detailed Site Information About Large Loads Seeking to Interconnect","method":"PDF bookmark","endPage":5,"endAt":132,"startToken":658,"endToken":1168},{"p":5,"at":132,"title":"How PJM Is Responding to the Rapid Interconnection of Large Loads and Technologies like Inverter Based Resources","method":"PDF bookmark","endPage":5,"endAt":1381,"startToken":1168,"endToken":1347},{"p":5,"at":1381,"title":"Physical And Cybersecurity Risks Posed by Large Load Integration","method":"PDF bookmark","endPage":6,"endAt":623,"startToken":1347,"endToken":1688},{"p":6,"at":623,"title":"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","method":"PDF bookmark","endPage":7,"endAt":524,"startToken":1688,"endToken":2204}]}