AD26-8-000 · 2026-10-21 · PJM

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. (Christopher Pilong, Panel 1)

For Public Use 
 
 
 
 
 
 
 
 
 
 
Reliability Technical Conference 
Comments from PJM Interconnection, 
L.L.C. 
FERC Reliability Technical Conference, Docket No. AD26-8-000

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
PJM © 2026 
www.pjm.com | For Public Use 
i | P a g e  
Contents 
Summary ....................................................................................................................................................................... 1 
RTOs Need Detailed Site Information About Large Loads Seeking to Interconnect ............................................. 2 
How PJM Is Responding to the Rapid Interconnection of Large Loads and Technologies like Inverter Based 
Resources ..................................................................................................................................................................... 3 
Physical And Cybersecurity Risks Posed by Large Load Integration .................................................................... 3 
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 ..................................................................................... 4

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
PJM © 2026 
www.pjm.com | For Public Use 
1 | P a g e  
Summary  
On behalf of PJM Interconnection, L.L.C. (“PJM”), I, Christopher Pilong, Senior Director of Operations Planning, 
appreciate the opportunity to provide this written statement for the Commission’s October 21, 2026 reliability technical 
conference.  
PJM welcomes the opportunity to participate in a public discussion about the state of reliability in our changing energy 
landscape and, in particular, the operational challenges involved with integrating large loads and addressing evolving 
system dynamics. 
The pace of load growth and emergence and adoption of technologies such as inverter-based resources are presenting 
novel challenges. PJM is working with stakeholders to respond to those reliability challenges. Both state and federal 
action will be critical to continuing to ensure system reliability. 
My statement addresses four reliability priorities: the detailed and continuously updated information PJM needs from 
Large Load operators; PJM’s response to the rapid interconnection of Large Loads and the growing penetration of 
inverter-based resources; the physical and cybersecurity risks associated with concentrated Large Loads; and the fuel-
security and infrastructure implications of behind-the-meter and front-of-the-meter gas-fired generation that relies on 
shared natural gas pipelines. 
Going forward, PJM supports a reliability framework that: requires timely, accurate, and continuously updated technical 
information from Large Load operators; establishes enforceable voltage and frequency ride-through requirements for 
both new and existing Large Loads; ensures that interconnection and energization decisions reflect the time required to 
develop sufficient generation and transmission; and advances coordinated electric-gas planning, cybersecurity 
protections, and accountability for facility performance. 
Large Loads are seeking interconnection in PJM faster than the generation and transmission needed to serve them can 
be placed in service. 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. This timing mismatch 
creates a reliability risk. 
Large Loads also exhibit very high and relatively constant power utilization, unlike traditional residential, industrial, and 
commercial load, which generally declines overnight, on weekends, and during the spring and fall shoulder seasons. 
Large Loads therefore raise the system’s base demand across nearly all hours, producing not only higher summer and 
winter peaks but also higher demand during spring, fall, and other historically off-peak periods. This change makes it 
more difficult to maintain reliability during planned transmission and generation outages needed for construction, 
equipment overhauls, and major maintenance. 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. Without those safeguards, reliability for existing customers may 
be placed at risk. The urgency is illustrated by PJM’s increasing need to seek Department of Energy authorization 
under section 202(c) of the Federal Power Act to operate generation beyond otherwise applicable limits and potentially 
use backup generation at data centers and other sites during anticipated emergencies, including over the October 12–
14, 2026 period. PJM historically has not needed to seek such relief under comparable temperatures and seasonal 
conditions.

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
PJM © 2026 
www.pjm.com | For Public Use 
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RTOs Need Detailed Site Information About Large Loads Seeking to 
Interconnect 
Because Large Loads present with various configurations that can affect reliable electric service, it is essential that 
RTOs receive detailed site information about Large Loads seeking to interconnect, including the specific system 
conditions that may trigger a load to switch ‘off grid power’ and move to its UPS or backup generator. Such information 
is necessary for PJM to understand and validate how the Large Load facilities will respond to system events before 
Large Loads interconnect with the grid, as opposed to having an unexpected response to system conditions in real time 
operations.  
Ongoing participation of the Large Loads in furnishing detailed information to appropriate entities and either directly or 
ultimately to the RTOs is critical. 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.).  
Given wholesale and transmission system impacts, PJM is exploring pathways to ensure Large Loads are required to 
participate in commissioning tests, periodic validation of models and settings, prompt notice of material facility changes, 
event-data retention, and post-event performance reporting. 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 proportionate to the reliability risk. 
Large Load operators should be subject to consistent performance requirements and standards. PJM has already 
experienced multiple instances in which Large Loads unexpectedly disconnected from the grid. In July 2024, 
approximately 1,500 MW of load transferred off grid in response to a system fault in Northern Virginia. Two additional 
major events have since occurred, including the sudden transfer of approximately 3,900 MW of load off grid on July 22, 
2026. PJM has also observed multiple events outside its footprint. These events demonstrate the need to implement 
voltage ride-through requirements without delay. 
As part of its response to the June 18, 2026 Large Load show-cause order, PJM is developing voltage and frequency 
ride-through requirements informed by the July 22, 2026 event. Those requirements could have mitigated the event if 
they had applied to the affected facilities. To reduce the risk of recurrence, the requirements should apply, as legally 
and technically appropriate, to both new and existing Large Loads. The expected magnitude and reliability 
consequences of future events will increase as concentrated Large Loads continue to grow, making timely action 
essential. 
The modeling and adherence to voltage/frequency ride through requirements also allows RTOs to direct reinforcements 
to the system that will support the new Large Loads while maintaining the current high level of reliability for existing 
customers.  
PJM has actively participated in the NERC efforts to draft standards pertaining to Large Computational Loads, which 
will also assist in these efforts and are critical to have in place as soon as possible.

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
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How PJM Is Responding to the Rapid Interconnection of Large Loads and 
Technologies like Inverter Based Resources 
There are essential reliability attributes that all generators produce at varying levels that are critical to maintaining grid 
reliability. PJM is considering system reliability needs via markets products, and the development of enhanced 
Essential Reliability Services,1 which are the building blocks of grid reliability. 
 PJM and other regions will need to continue to track and value Essential Reliability Services, potentially implementing 
market solutions. 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. In this regard, 
PJM’s Reserve Certainty Senior Task Force (“RCSTF”) effort will help achieve sufficient reserves to address 
uncertainty and ramping. The RCSTF proposal was presented at PJM’s September 24, 2026 Markets and Reliability 
Committee meeting.3 Stakeholders will vote on the proposal at the November Members Committee meeting, and, 
assuming a passing vote, PJM expects to file the proposal at the Commission in December. 
Physical And Cybersecurity Risks Posed by Large Load Integration  
The physical and cybersecurity risks presented by Large Load vary.  
The principal physical and cybersecurity risks associated with Large Loads arise from the amount of demand 
concentrated at individual facilities and within geographic areas. Erratic operation, simultaneous disconnection, or 
malicious manipulation of multiple facilities could produce sudden load changes that affect grid frequency, voltage, and 
system stability. 
The disruptive Large Load events observed to date appear to have been inadvertent, including the July 22 event 
involving the sudden disconnection of nearly 3.9 GW in Virginia. 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. Coordinated manipulation across multiple facilities could activate protection systems and compound the system 
effects observed during an inadvertent event. These scenarios support development of security controls, incident-
reporting obligations, operational coordination protocols, and recovery requirements proportionate to the grid 
consequences of concentrated computational load. 
 
1 As described by NERC, Essential Reliability Services include frequency support, voltage support, and ramping capability on the 
Bulk Electric System. See NERC Essential Reliability Services Abstract Report, available at 
https://www.nerc.com/globalassets/programs/rapa/ra/ers-abstract-report-final.pdf. 
2 The September 10, 2026 Operating Committee presentation addressing the Primary Frequency Response Review is available at 
https://www.pjm.com/-/media/DotCom/committees-groups/committees/oc/2026/20260910/20260910-item-06---primary-frequency-
response-update---presentation.pdf. 
3 Reserve Certainty Senior Task Force Overview and Proposal, available at https://www.pjm.com/-/media/DotCom/committees-
groups/committees/mrc/2026/20260924/20260924-item-02a---1-pjm-rcstf-proposal-summary---presentation.pdf.

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
PJM © 2026 
www.pjm.com | For Public Use 
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Because large computational loads can materially affect real-time grid operations, NERC reliability standards should 
address the operational and cybersecurity obligations appropriate to those facilities. The standards should clarify 
applicability, performance expectations, coordination with Reliability Coordinators and Balancing Authorities, event 
reporting, model validation, and cybersecurity protections commensurate with the facilities’ potential effect on the Bulk-
Power System. 
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 
PJM actively considers the implications of fuel availability for gas-fired generation to meet the additional demands of 
interconnecting Large Loads.  
Gas-fired generation is an important component of PJM’s resource mix. PJM currently has approximately 90 GW of 
installed gas-fired generation, of which 80% is served directly by interstate pipelines and 20% is served by local 
distribution companies. Approximately 29% of gas-fired resources have dual-fuel capability, and 51% have firm gas-
delivery arrangements. 
To minimize reliability threats posed by unavailability of fuel, PJM’s Gas Electric Coordination Team works closely with 
generation owners and pipelines. PJM’s team coordinates with generation owners and conducts surveys to ensure 
adequate fuel is available and secured going into peak periods. In addition, when PJM declares a maximum generation 
emergency, there is a focus on fuel inventory for different generation resources, including instructions to generation 
resources to conserve available fuel for critical periods if there is a shortage.  
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. Whether that generation is co-located behind the meter or interconnected in front of the 
meter, substantial new pipeline capacity and increased gas production may be needed in some areas to support the 
generation while maintaining reliable service for existing customers. The need is particularly significant if the generation 
is expected to operate throughout the year to serve data centers with high capacity factors. Meeting rapid energization 
targets will require early coordination with the natural gas industry and realistic assumptions about siting, permitting, 
construction schedules, materials, labor, and fuel-delivery capability. These considerations reinforce the need for close 
gas-electric coordination. 
Consideration should also be given to account for common-mode fuel risks. Multiple behind-the-meter and front-of-the-
meter generators serving Large Loads may depend on the same pipeline, compressor station, local distribution system, 
or upstream supply path. PJM and the gas industry therefore need sufficient information to identify correlated 
contingencies, evaluate deliverability during peak electric and gas conditions, and determine whether firm 
transportation, dual-fuel capability, on-site fuel, demand flexibility, or other mitigation is needed. 
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. PJM also must retain a portfolio able to meet seasonal and weather-driven demand 
that varies by hour and time of year. PJM’s Commission-accepted Effective Load Carrying Capability analysis (“ELCC”) 
supports that objective by assessing each resource type’s contribution to resource adequacy during the hours when the 
system is most constrained.

Reliability Technical Conference Comments from PJM Interconnection, L.L.C. 
PJM © 2026 
www.pjm.com | For Public Use 
5 | P a g e  
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PJM respectfully requests that the Commission use this technical conference to advance a coordinated reliability 
framework for Large Loads—one that aligns energization with available infrastructure, requires accurate models and 
dependable facility performance, addresses correlated cyber and fuel risks, and preserves reliable service for existing 
customers as the system evolves.