Large Load Interconnection

Large Load Interconnection: what this is

What did PJM file on Nov 9?

PJM filed its 50 MW Large Load registry rules (ER26-3515-002) without the rejected curtailment service. It also refiled its backstop proposal under the correct §205 code (ER27-454-000). Comments on both are due Nov 30 at 5 p.m. ET. The separate show cause deadline is Nov 16.

Registry filing · Backstop refiling

Questions in the filings

• Who can see the registry? PJM would publish totals by distributor area where possible. Site-level filings stay subject to confidentiality rules. Ohio’s consumer advocate wants access under those same protections.
• Who pays if a supplier leaves? PJM proposes that the departing load-serving entity keep its backstop obligation. A later rate filing would set what it owes. The liability can outlast membership.
• What counts as one site? PJM’s 50 MW test uses cumulative peak demand. The clean tariff covers affiliated facilities within one mile under the configurations specified in the agreement.

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On October 23, 2025, the Department of Energy invoked its rarely used § 403 authority to direct FERC to open a rulemaking on connecting large loads (data centers, AI, advanced manufacturing) to the interstate grid (Docket RM26-4-000), and asked for final action by April 30, 2026.

Rather than run a multi-year rulemaking, FERC answered on June 18, 2026 with six tailored § 206 show cause orders, one to each RTO/ISO. Each makes a threshold finding that the region’s tariff may be unjust and unreasonable for lack of clear, consistent large-load rules, then puts the market on a 30/60-day clock to defend the status quo or file a fix across the same five reform categories.

The through-line is cost causation made visible: the large load that triggers a network upgrade should bear its cost and spare ordinary ratepayers, with new transparency into how those costs are identified and allocated. The same morning, FERC issued Item E-2 (EL25-49-002), the order on rehearing that finalizes the rates and terms for the three new transmission services its PJM co-location proceeding created, the same services the six orders extend to every other region.

Where it stands on November 10, 2026: the Nov 9–10 sweep found no new respondent answer on the six main sheets. Morongo Transmission, a CAISO transmission owner, had already answered on Aug 12. The Nov 16 deadline (Nov 20 for SPP) remains separate from PJM’s Nov 9 registry filing in ER26-3515-002. The respondents' plans are in writing: the PJM Transmission Owners and ISO New England have each committed to a §205 filing by November 16; CAISO's Board advanced its large-load proposal on October 28 for a filing by the same date; PJM scheduled a November 5 special Members Committee to consult on a suite of §205 filings answering the show cause order, posted no outcome from it, and its chief executive wrote to four buyer and clean-energy trade groups that day that PJM's proposal was still under development; MISO is filing its reforms under §205 in separate dockets; and NYISO's stated target is December. FERC's one ruling on large-load tariff text since June came on October 9, in PJM's own §205 docket: it accepted a 50 MW Large Load definition and a Large Load Registry and rejected the curtail-first Interim Resource Adequacy Service built around them as an intrusion on state retail jurisdiction. PJM refiled its suspended backstop procurement on October 29 in a new docket, ER27-330, after FERC on October 23 moved the paper-hearing briefs to January rather than ruling on PJM's abeyance motion; seven parties have asked for rehearing or clarification of the September 29 backstop order, and FERC's November 2 notice set comments on the refiling for November 30. Vistra, and Exelon with others, have petitioned the Third Circuit for review of four orders in the PJM co-location proceeding (EL25-49). PJM governance is at the redline stage after the Members' September 30 vote, with the states opposed and the Board's filing decision unannounced. On November 3 Exelon filed a fast-track complaint (EL27-11) asking FERC to replace PJM's three-year-forward capacity auction with a prompt auction from 2030/31. The Filings tab quotes the key positions in each of these proceedings, page by page. Each of these threads has its own line under Where things stand, and the Timeline carries every earlier sweep's findings by date.

The Timeline tab holds the dated record: the August 3 and August 9 answer periods, the August 14 abeyance orders, the August 17 partial co-location compliance, the August 21 governance comments and backstop protests, and everything since. Each entry cites the document it was read from.

Where things stand

Four proceedings and one context lane run beside each other, each on its own clock. Status as of 2026-11-10.

• The six-market §206 clock (FERC Dockets EL26-67-000 to EL26-72-000). All six proceedings remain in abeyance and the clock has not moved since Aug 14: responses are due Nov 16, 2026 and answers Dec 16, except SPP (Nov 20 and Dec 21). The Nov 9–10 window added no respondent answer. Morongo Transmission answered in CAISO’s docket on Aug 12. Four regions have reported plans for Nov 16. The PJM Transmission Owners (Oct 9) and ISO-NE with its transmission owners (Oct 9) committed in writing to §205 filings by that date. CAISO's Board of Governors advanced the Large Loads proposal on Oct 28, and CAISO says it will file at FERC by Nov 16. PJM did not hold the advisory Members Committee vote on its own proposal that the Aug 14 abeyance order recorded for Oct 28: the Oct 28 agenda carried no large-load item. Instead PJM posted a Nov 5 special Members Committee to consult, under Tariff section 9.2(b), on “a suite of section 205 filings” answering the show cause order. For the backstop PJM consulted on Oct 22 and filed Oct 29, “seven days prior to submitting this filing”; the same spacing would put its show cause filings no earlier than Nov 12. MISO keeps filing pieces under §205 in separate ER dockets: FERC found its August zero-injection agreement filing deficient on Oct 9, and its Oct 2 LARS proposal (ER27-25) drew support from the Arkansas and Mississippi commissions and from utilities, and protests from clean-energy groups, consumer advocates and Google on Oct 23. NYISO told FERC in June it aims to file by December, after the Nov 16 date. The six docket sheets, read row by row through Nov 9, show only the National Congress of American Indians' comments urging a moratorium on hyperscale data centers, filed in all six on Oct 26 and not read, and a service-list update. The large customers PJM's filing would govern are on record against its shape: an Oct 2 letter from the Corporate Energy Buyers Association and the Data Center Coalition, first found this sweep, asks PJM's Board either to explain why it is not directly complying with the order's 60-to-90-day study directive or to pursue a narrower response. On Nov 5 ITI wrote the Board that interconnection requirements “should not be one size fits all”, and PJM's chief executive told all four groups that day that its proposal was “still under development”. Next: 2026-11-16, Show-cause responses due after the 90-day abeyance (SPP: Nov 20).
• PJM co-location: EL25-49 (FERC Docket EL25-49 (Item E-2, order on rehearing)). Unchanged on the clock: PJM's and the PJM Transmission Owners' full co-location compliance filing is due Nov 16, 2026, the same date as the §206 clock, and the transmission owners' Oct 9 consultation notice folds it into the single §205 filing they have committed to make on or before Nov 16. PJM's Oct 15 answer to the protests of its Aug 17 partial compliance filing asked FERC to defer ruling until the November filing completes the record. New since Oct 20, and moving the fight to court: Vistra Corp. (Oct 22, Case No. 26-3635) and Exelon Corp. and others (Oct 27) petitioned the U.S. Court of Appeals for the Third Circuit for review of four orders in this proceeding, issued Dec 18, 2025, Feb 20, 2026, June 18, 2026 and Aug 20, 2026. That is known from the docket-sheet descriptions; the petitions were not read. No Commission order since the Aug 14 extension; the sheet was read through Oct 30. Next: 2026-11-16, PJM and PJM TOs full co-location compliance filing.
• PJM governance: AD26-7 (FERC Docket AD26-7-000 (Commission-led technical conference)). PJM is drafting the Members' term sheet into tariff language. On Oct 13 it posted Operating Agreement and Tariff redlines implementing the sheet the Members endorsed Sept 30 (§205 rights over the energy-market schedules with a jump-ball rule for competing Member filings, 30 days' notice of market-design filings, a permanent planning committee in the Operating Agreement, an independence clause), and walked stakeholders through them at an Oct 16 page-turn workshop. The redlines are a stakeholder draft, not a filing, and nothing says yet whether the Board will file the Members' package, its own, or neither. The record so far: FERC's Dispute Resolution Service opened confidential talks on Sept 1; on Sept 30 a special Members Committee approved the Members' sheet by the required sector-weighted two-thirds vote, ahead of PJM's and the Consumer Advocates' versions, neither of which won a majority; PJM told FERC so on Oct 1 and noted that the Organization of PJM States and the PJM Governors' Collaborative do not find the result satisfactory. The states had written to the Board on Sept 29 that if the Members' sheet passed they would “forcefully oppose it before the Commission and beyond.” FERC has not acted on the vote, its Oct 15 open meeting carried no governance item, and the AD26-7 docket sheet, read through Oct 30, has nothing new since Oct 8. The regular Members Committee met Oct 28 with no governance vote on its agenda; the afternoon was a Board discussion with stakeholders on short-term priorities. Next: 2026-11-18, Next regular Members Committee; the Board's decision on what to file at FERC is still unannounced.
• The RM26-4 record (FERC Docket RM26-4-000 (the DOE §403 rulemaking)). Open with no dated next step, and nothing new on it since the June 18 orders. FERC answered the directive with the six §206 orders rather than a rule, and its Oct 15 open meeting agenda carried no RM26-4 item. The record's substance now moves through the regional §205 filings the orders invited; the crosswalk on the Comments tab tracks which of the record's issues each order reached.
• Market context. PJM filed the Large Load definition and registry on Nov 9 (ER26-3515-002), removing the capacity fields tied to its rejected curtailment proposal. Ohio’s Consumers’ Counsel separately sought rehearing on access to confidential registry data (ER26-3515-001). PJM also refiled its Oct 29 backstop proposal in ER27-454-000 to correct the filing code. Comments on the registry and backstop filings are both due Nov 30. The backstop paper-hearing briefs are due Jan 11 and Jan 26, 2027. Next: 2026-11-30, Comments on PJM’s registry compliance filing and separate backstop refiling.

The six show cause orders

Each order has its own page below, with the quoted directives, the region-specific findings and the full respondent roster. Every PDF is a committed copy of the ferc.gov original, served with this site so page-precise citations open inline.

• E-7 PJM, Docket EL26-67-000: 195 FERC ¶ 61,211, 114 pp. Co-location rules already in place. Region: Mid-Atlantic / 13 states + DC. PJM is the control case, the one region that does not start from a blank page. FERC built PJM’s co-location rules in the parallel EL25-49 proceeding (finalized the same morning in Item E-2), so E-7 asks PJM to carry those new services (Interim NITS and Firm/Non-Firm Contract Demand) into a general large-load framework. The catch: every request still runs through one ‘first-ready, first-served’ clustered New Services Queue with no large-load-specific study, even though an Eligible Customer already pays ‘100% of the costs of the minimum amount of Network Upgrades’ its request triggers. So the order presses how to add flexible-load service and protect deals nearing completion without breaking that queue.
• E-8 MISO, Docket EL26-70-000: 195 FERC ¶ 61,212, 115 pp. Early-stage large-load rules. Region: 15 states, Midwest + South. MISO is the cost-allocation stress test. Its tariff still studies new load at its maximum demand ‘regardless of the load’s operational capabilities or willingness to be curtailed,’ and the resulting network upgrades are ‘rolled into the relevant transmission owner’s base zonal rates,’ spread across that utility’s wholesale customers. MISO itself told its Large Load Working Group the tariff does ‘not provide a consistent or transparent framework’ for large loads. E-8 presses whether flexible service and a pro forma cost-recovery agreement can keep those upgrade costs on the load that caused them.
• E-9 SPP, Docket EL26-68-000: 195 FERC ¶ 61,213, 92 pp. Most mature: HILL / HILLGA. Region: Central U.S., 14+ states. SPP is the benchmark, not the laggard. E-9 adopts SPP’s own ‘High Impact Large Load’ (HILL) definition, commends its ‘High Impact Large Load Generation Assessment’ (HILLGA) and Conditional HILL Service, and leaves the Attachment Z1/AQ/AX study stack and Highway/Byway cost split intact. Even in this leading framework FERC finds only two real gaps: no requirement to evaluate alternative transmission technologies, and no pro forma terms to ‘memorialize ongoing operational requirements in a transmission service agreement.’ The remaining ask is a mechanism to credit large-load payments back through transmission owners’ revenue requirements.
• E-10 CAISO, Docket EL26-71-000: 195 FERC ¶ 61,214, 118 pp. No Order No. 888 service. Region: California (+ WEIM footprint). CAISO is the translation problem. It ‘does not offer traditional Order No. 888 network and point-to-point transmission services, offers no firm, long-term transmission reservations of capacity,’ and its Participating TOs (not CAISO itself) ‘play the lead role in managing the interconnection of load’ inside California’s state planning and forecasting processes. So E-10 gives CAISO an alternative no other order offers: either build equivalent large-load protections, or explain why its single daily service and Transmission Access Charge (TAC/RAC) framework already solves the same cost and reliability problems.
• E-11 ISO-NE, Docket EL26-72-000: 195 FERC ¶ 61,215, 115 pp. Transmission-constrained grid. Region: Six New England states. ISO-NE is the small-system, big-load case. FERC flags a system peaking at only ‘30,000 MW’ with significant transmission constraints, and a ‘CELT load forecast’ that generally excludes proposed data centers, so a single large customer can move the regional needle. E-11 turns that into concrete planning questions: how Schedule 22/23 cluster studies, Pool Transmission Facilities at ‘69 kV’ and above, and the Monthly Regional Network Load behind-the-meter-netting rules should change, and whether to import PJM’s MW-threshold remedy for that netting.
• E-12 NYISO, Docket EL26-69-000: 195 FERC ¶ 61,216, 119 pp. Largely outside the tariff today. Region: New York State. NYISO is the tariff-gap case. It runs load interconnection for projects over 10 MW at ‘115 kV’ and above largely off-tariff: the study details, deposits, and assumptions sit in non-tariff documents, and its tariff ‘lacks a definition of large load’ as a category. With co-location reforms not expected until ‘2027,’ E-12 converts that off-tariff practice into show-cause issues: a 60-to-90-day study expectation, a new large-load definition with readiness requirements to deter speculation, and the only order’s express path to request a 90-day abeyance.

Decided the same morning: E-2 (Docket EL25-49-002, 195 FERC ¶ 61,209), the PJM co-location order on rehearing that finalises the three new transmission services the six orders extend.

The five reform categories

• Application & study processes (incl. alternative transmission technologies): Developing efficient transmission-service application and study processes, including consideration of alternative transmission technologies.
• Cost-shifting prevention & transmission-cost transparency: Preventing cost shifting and requiring transparency into transmission costs.
• Co-location arrangements & behind-the-meter (BTM) generation: Accommodating co-location agreements and behind-the-meter generation.
• New transmission services for flexible large loads: Providing new transmission services for flexible large loads.
• Studying generation serving electrically proximate / co-located loads: Developing a process to study generating facilities that serve electrically proximate large loads and co-located loads.

The §206 procedural clock

All six §206 orders run one clock from the June 18, 2026 issuance. The periods are stated in each order’s ordering paragraphs; the calendar dates are derived and business-day-adjusted (National Law Review). Status is computed from today’s date, not from confirmed filings, so it tracks the schedule rather than who has filed.

• 2026-07-09, Motions to intervene (21 days from issuance, Ordering ¶ (D) · Rule 214): Notices of intervention or motions to intervene in the six proceedings are due.
• 2026-07-20, Generation-adequacy report (30 days from issuance, Ordering ¶ (C)): Each RTO/ISO files an informational report on how it will ensure adequate generation to serve existing and new large loads.
• 2026-07-20, Requests for rehearing (30 days from issuance, FPA § 313(a)): Statutory deadline to seek rehearing of the June 18 orders before a court appeal.
• 2026-08-03, Abeyance requests (45 days from issuance, All six orders (e.g., E-12 P 42)): Deadline in each of the six orders to request full or partial abeyance (up to 90 days) of the proceeding. FERC says it will not grant abeyances reflexively and views extension requests with great disfavor.
• 2026-08-17, Show cause or file tariff changes (60 days from issuance, Ordering ¶ (B)): Each RTO/ISO and its Transmission Owners must show cause why the tariff remains just and reasonable, or file remedial tariff changes.
• Not yet dated, Response window opens (filing + 30 days, Ordering ¶ (E)): Interested entities may respond on whether the tariff remains just and reasonable and, if not, what replacement rates to implement. Opens once the show-cause/tariff filing is made.

This is an independent analysis microsite and is not affiliated with FERC or DOE. Order record as of 2026-06-22; commentary 2026-11-02; news and filings swept 2026-11-10. A machine-readable index for agents is at llms.txt.