Who Would Be Curtailed First: The Pennsylvania Commission's Proposal for Certain Large New Loads

The Pennsylvania Public Utility Commission has proposed protections that "would prioritize certain large new loads for curtailment during periods of tight electricity supply," in the words of its press release, published on October 1, 2026. "By a vote of 4-0, the Commission approved a Tentative Order seeking public comment on proposed changes to how Pennsylvania electric utilities prepare for and respond to periods of tight electricity supply, including new procedures for electric distribution companies addressing large loads such as data centers." Parts of the release follow, not the Tentative Order itself.

Who would be curtailed first

At the center of the proposal, the release says, is "a key consumer protection principle", that "certain large new loads that have not secured sufficient new electric capacity to support their demand would be subject to curtailment before other customers when additional load reductions are needed to maintain reliability." The commission also proposes that "large loads such as data centers not be classified by electric distribution companies as critical loads that would be exempt from curtailment during pre-emergency or emergency events."

The release does not say what it takes to have "secured sufficient new electric capacity". For a developer, that phrase marks the line between being curtailed first and being treated like other customers, so it is the first thing to look for in the Tentative Order itself.

What utilities would have to do

The signal would come from the regional grid operator. PJM Interconnection, "the regional grid operator serving Pennsylvania and 12 other states and the District of Columbia," has proposed "a new Interim Resource Adequacy Service (IRAS) intended to help manage periods when available electric resources may not be sufficient to reliably meet demand." Under the commission's Tentative Order, the release says, utilities would prepare by "identifying large loads in their service territories and establishing clear procedures for responding when PJM calls for load reductions." The release lists four things utilities "would be required to" do.

• "Identify large loads": "Develop and maintain a registry of large loads within their service territories, giving utilities, PJM and the PUC better information to prepare for rapidly growing electricity demand."
• "Plan for potential curtailments": "Establish clear procedures for identifying and notifying large-load customers that may be required to reduce their electricity use when PJM determines that additional load reductions are needed to maintain reliability."
• "Prioritize large-load reductions": "Establish procedures to reduce eligible new large loads that have not secured sufficient new electric capacity before shedding load from other customers during an IRAS event."
• "Strengthen emergency protections": "Update pre-emergency and emergency procedures so that large loads such as data centers are not classified as critical load exempt from curtailment during those events."

Still a proposal

Publication comes next. "The Tentative Order will be published in the Pennsylvania Bulletin, beginning a formal public comment period." Then "Interested parties will have 30 days following publication to submit comments on the Commission's proposals, followed by an additional 15 days for reply comments." After that, "the Commission anticipates considering a Final Order at its Jan. 28, 2027, public meeting, directing Pennsylvania electric distribution companies to file updated procedures." For "the Commission's specific proposals and questions for public comment", the release points to the Tentative Order.

Being curtailed first is a cost a lender would want priced before a project is financed. The release leaves the terms that set that cost to the Tentative Order's details.