PJM's flex interconnection year: BYONG, Non-Firm Contract Demand, and the federal 60-day rule
Raymond Xu
April 27, 2026 · 6 min read
Three things happened between October 2025 and January 2026 that combined to set up PJM’s flex-interconnection year. The governors of Pennsylvania, New Jersey, Maryland, and Virginia issued a joint letter on Oct 30 pushing data centers toward bringing their own generation. FERC issued EL25-49 on Dec 18, directing PJM to create three new transmission services for large and co-located loads. PJM’s Board issued a letter on Jan 16 committing to a voluntary BYONG path paired with an Expedited Interconnection Track. Each of these is a separate mechanism with separate mechanics; they’re complementary, not substitutes.
FERC EL25-49 and the three new transmission services
The Dec 18, 2025 order (5–0 vote) directs PJM to create three new transmission services for co-located and large loads:
- An interim non-firm bridge service.
- Firm Contract Demand Transmission Service.
- Non-Firm Contract Demand Transmission Service — the “interruptible for faster access” vehicle.
Non-Firm Contract Demand customers pay no generation-capacity charges and are first in line to be curtailed during emergencies. PJM’s compliance filing was due Feb 16, 2026 and is currently in tariff hearing. As of this writing the products exist on order but are not yet tariffed.
PJM Board letter on BYONG
The Jan 16, 2026 Board letter on the CIFP large-load process commits PJM to a voluntary BYONG (Bring Your Own New Generation) path paired with an Expedited Interconnection Track. The mechanics: a large load brings dedicated generation sized to its hourly forecast, pays 100% of any required network upgrade costs, and skips the firm queue. Connect-and-manage exists as a parallel curtailment-instead-of-generation track. Expedited Track target: August 2026.
Federal umbrella: FERC RM26-4-000
The ANOPR on Interconnection of Large Loads (over 20 MW) has a DOE-directed final-action deadline of April 30, 2026 — three days from this post. The headline ask is whether large loads and co-located facilities that agree to be curtailable can complete interconnection studies in as short as 60 days versus the current 3 years. If finalized on schedule, RM26-4 is the federal cover that legitimizes every ISO-level curtailment-for-speed mechanism in this post. A slip past April 30 would reset the timing on all four ISO frameworks below it.
The mechanisms, side by side
| Jurisdiction | Vehicle | The bargain | Status |
|---|---|---|---|
| FERC (federal) | RM26-4-000 ANOPR | Large loads (>20 MW) that agree to be curtailable, or hybrid facilities that agree to be dispatchable, can complete interconnection studies in as short as 60 days vs. the current 3 years. | Final-action deadline Apr 30, 2026 (DOE-directed). Federal umbrella for every ISO mechanism below. |
| SPP | HILLGA / LLRIS (FERC Docket ER26-247) | Co-located generation must be sized to the load's hourly forecast, output capped to the load's demand, and located within two substations of the load. | Effective Jan 15, 2026. The only fully-effective FERC-approved curtailment-for-speed mechanism today. |
| ERCOT | PGRR145 / NPRR1325 (Batch Zero PCLR) | Provisional Controllable Load Resource accepts binding SCED dispatch on a flexible MW slice in exchange for earlier energization. | ERCOT Board approval target Jun 1, 2026; PCLR declaration deadline Jul 24, 2026. |
| PJM | Jan 16, 2026 Board letter (CIFP large-load additions) | Voluntary BYONG (Bring Your Own New Generation) paired with Expedited Interconnection Track. Large loads pay 100% of required network upgrade costs. | Expedited Track target Aug 2026. |
| PJM | FERC EL25-49 transmission services | Three new services for large / co-located loads: interim non-firm bridge, Firm Contract Demand, and Non-Firm Contract Demand. NCD pays no generation-capacity charges and is curtailed first during emergencies. | FERC ordered Dec 18, 2025 (5-0). PJM compliance filing due Feb 16, 2026; tariff in hearing. |
The bargain across every mechanism is the same: load accepts a constraint (curtailability, co-located generation, 100% upgrade cost), gets interconnection faster than firm-queue physics would allow. What varies is which constraint, at what financial-security threshold, under whose tariff.
Political alignment
The four-state governor letter on Oct 30, 2025 is unusual. State energy policy in PJM territory has historically been fragmented — Maryland’s climate goals don’t align cleanly with West Virginia’s coal economics or Ohio’s utility politics — and four governors (two Democratic, two Republican) issuing a joint letter on energy policy is a rare alignment. The Maryland Office of People’s Counsel filed FERC support for BYOG with expedited interconnection in July 2025; even the consumer-advocate side wants this exchange to exist. New York’s PSC opened Case 26-E-0045 in February explicitly naming BYOG as a tool, with reply comments due May 13, 2026 and a DPS Staff white paper due Feb 12, 2027.
The portfolio implication
A developer with sites in PJM, ERCOT, and SPP territory now runs three different feasibility calculations, three different filing workflows, and three different financial-security postures. Cliff is being built to render that as a single-pane portfolio view rather than three separate analyses. See the companion post on ERCOT PCLR for the Texas leg, and the original de-rate calculator post for the air-permit math that interacts with PJM’s non-firm products. Talk to us if you’re staring down both queues.
Primary sources
- PJM Board letter on CIFP large-load additions (Jan 16, 2026)
- FERC fact sheet on EL25-49 co-located load final rule
- FERC order approving SPP HILLGA / LLRIS (Docket ER26-247, Jan 14, 2026)
- FERC RM26-4-000 docket page (DOE-directed ANOPR on Interconnection of Large Loads)
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