New Capacity, or Reduce When Called: PJM Answers the Protests

On September 23, 2026, PJM, the grid operator, filed an answer before the Federal Energy Regulatory Commission in Docket No. ER26-3515-000. It answers the comments and protests filed in response to a proposal PJM made on August 13: an Interim Resource Adequacy Service, which it shortens to IRAS, and a Large Load Registry.

This is PJM arguing for its own proposal. It is not a ruling. The filing is also a motion. The Commission's rules do not generally permit answers to protests, it says, though the Commission "permits answers for good cause shown," and PJM "respectfully moves for leave to file this answer."

Insufficient Capacity

The answer opens on an auction. The Base Residual Auction for the 2027/2028 Delivery Year, it says, "procured insufficient capacity to meet the PJM Region Reliability Requirement."

Its next sentence: "Thus, it is unclear whether, as of June 1, 2027, the PJM Region will have enough capacity to meet the longstanding reliability metric of one event in 10 years loss of load expectation."

A footnote adds that PJM is still developing the 2027 Load Forecast and has yet to conduct the Third Incremental Auction for that Delivery Year. "Thus, it is still unknown whether the PJM Region will be short of capacity heading into the Delivery Year."

Another footnote turns to operations. It quotes a page of PJM's own, dated August 11, 2026: "a July 22 event saw nearly 4,000 MW of data center load trip offline unexpectedly in Virginia. It was the largest such event in PJM history."

Bring New Capacity, or Reduce

The answer quotes the sentence PJM proposes to put first in section 7.8 of its Reliability Assurance Agreement. An LSE is a load serving entity.

Effective June 1, 2027, each LSE that desires to provide Network Transmission Service to support New Large Loads must designate one or more Generation Capacity Resources or Capacity Storage Resources that had not cleared an RPM Auction as Network Resource(s) in a cumulative amount that equals or exceeds the LSE's New Large Load's peak load (in MW) as reported in the Large Load Registry pursuant to RAA, Schedule 11 or such New Large Load may be subject to load reduction requests during Emergencies prior to Pre-Emergency Load Management Response.

PJM then says what it intends: "to establish the policy that New Large Loads must bring new capacity or PJM may request that they reduce their energy consumption to alleviate emergency conditions."

A footnote to that sentence reads: "To be clear, this is designed as a condition of New Large Loads interconnecting and taking Network Transmission Service. To the extent the New Large Load takes one of the alternative transmission services being addressed through other proceedings, this policy would not immediately apply."

Which loads? The proposed definition of a Large Load is end-use customer load with a cumulative peak load of 50 MW or greater at a single electrical site. Where affiliated facilities are involved, "all affiliated load facilities within a one-mile radius will be considered a single electrical site."

A New Large Load, under the proposed definition, goes into service after June 1, 2027, "including incremental load." That date holds "at the beginning of IRAS." The answer goes on: "In subsequent years, if the need for IRAS re-emerges, New Large Load will be designated as Large Load entering service after June 1 of the first Delivery Year that the PJM Region is short capacity."

Before Pre-Emergency Load Management

The answer gives a section to where the request falls in an emergency.

IRAS, it says, "will be an operational tool available for PJM's operators to maintain system reliability when the system has exhausted all available economic resources (i.e., all available generation, storage, and Economic Load Response Participant resources), and before PJM calls upon Pre-Emergency Load Management."

Its reason is that the loads in question "have not satisfied their respective capacity needs through BYONC, and therefore, should not obtain the capacity benefit of Demand Resources." BYONC is the answer's short form. A commenter it quotes spells it out as "Bring Your Own New Capacity."

Quoting its August 13 filing, PJM says it "may issue directives to Electric Distributors to reduce load by a certain MW quantity during certain, limited emergency conditions." And: "PJM will not direct reductions to specific New Large Loads pursuant to IRAS."

The answer also reports the other side. It names intervenors who argue against PJM being able to call on IRAS before Pre-Emergency Load Management, the Independent Market Monitor among them, and it quotes an objection: "PJM has not provided a supportable reason to justify giving IRAS priority over existing compensated Demand Resources."

PJM's reply to their arguments: "None of these has merit."

No Locational Requirement

What counts as bringing capacity? "BYONC are simply MW of Unforced Capacity," the answer says. "A New Large Load with a resource adequacy need of 75 MW should contract with 75 MW of BYONC."

Then: "There is no hint of a requirement that the BYONC must physically serve the New Large Load. The issue is that the PJM Region is short of capacity."

And on place: "Because as part of the transmission planning and interconnection processes all new capacity must ultimately be deliverable to the entire PJM Region (subject to transmission constraints), there does not need to be any locational requirement for BYONC."

Once an arrangement is reported, "the two are paired, unless the New Large Load goes out of business." And "for each MW of BYONC associated with a New Large Load, that New Large Load's exposure to IRAS is permanently reduced."

October 12, 2026

PJM asks for a date. The proposed changes "should be accepted, and made effective, no later than October 12, 2026, as requested." The key operational tools, it says elsewhere, "must be in place by June 1, 2027."

These are dates PJM asks for. The answer does not say what the Commission will do.

PJM also says "it is not proposing a package to be accepted or rejected as a whole." Each element "is modifiable and severable so long as consistent with PJM's overarching objectives." If the Commission rejects any element, PJM asks that it "either direct prescriptive changes to be implemented on compliance or provide guidance to aid PJM and stakeholders to develop a just and reasonable approach."

The next sentence: "The issues outlined herein are simply too important, and the timing too critical, for PJM and its stakeholders to have to guess in such a case as to what the Commission would find acceptable."