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 a flex-interconnection year on PJM (the regional grid operator covering 13 states from New Jersey through Ohio and Virginia). Interconnection is the process of getting permission and physical infrastructure to plug a new load or generator into the public grid; for a multi-hundred-megawatt data center in this region, that wait can run three to seven years. On Oct 30, the governors of Pennsylvania, New Jersey, Maryland, and Virginia issued a joint letter pushing data centers toward bringing their own onsite power instead of waiting for the grid. On Dec 18, federal energy regulators (FERC) ordered PJM to create three new categories of grid service for large and co-located data center loads. On Jan 16, PJM’s Board committed to a voluntary path letting large loads bring their own new generation in exchange for skipping the regular queue. Each of these is a separate lever with separate mechanics; they stack rather than replace each other.
The Dec 2025 federal order: three new ways to plug into PJM
On Dec 18, 2025 federal energy regulators voted 5–0 to require PJM to create three new grid-connection products for data centers and other very large loads:
- An interim “non-firm bridge” product — you get connected now, but the grid can cut you off if the wires it shares get congested.
- A traditional firm product where you pay for guaranteed delivery up to a contracted demand.
- A non-firm contract product — the “accept being interruptible in exchange for faster access” vehicle.
Customers on the non-firm contract pay no generation-capacity charges (the share of grid bills that goes to keeping power plants on standby) and are first in line to be curtailed when there’s an emergency. PJM’s plan for actually implementing these products was due to FERC on Feb 16, 2026 and is currently in a tariff hearing (the formal proceeding where the new rate language gets reviewed). As of this writing the products exist on the order but the actual rate book has not been updated yet.
The Jan 2026 PJM Board letter: bring your own power plant
The Jan 16, 2026 Board letter on the 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 data center brings dedicated onsite generation sized to its hourly forecast, pays 100% of any required upgrades to nearby transmission lines, and is allowed to skip ahead of the regular multi-year queue. A parallel option called connect-and-manage lets the load skip ahead instead by agreeing to be curtailed when the grid is constrained — same destination, different toll. The target for the expedited track being live is August 2026.
The federal umbrella over all of this: FERC RM26-4-000
FERC opened a federal rulemaking (an ANOPR, the earliest formal stage of writing a new rule) on how to interconnect large loads above 20 MW. The Department of Energy directed FERC on October 23, 2025 to finish the rule by April 30, 2026. On April 16, 2026 FERC issued an Order Regarding Intent to Act in RM26-4-000 extending the deadline to the end of June 2026. The headline question the rulemaking asks is whether large loads and co-located facilities that agree to be curtailable can complete the studies needed to plug in within 60 daysversus today’s 3 years. If finalized as proposed, RM26-4 is the federal cover that legitimizes every regional “accept being interruptible in exchange for faster access” mechanism described in this post. The two-month extension reset timing on all four regional frameworks downstream of it.
The mechanisms, side by side
| Jurisdiction | Vehicle | The bargain (what you give up to get in faster) | 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 trade across every mechanism is the same shape: a large load accepts a constraint (the grid can curtail you, you bring your own generation, you pay 100% of upgrade costs), and in return gets connected faster than the physics of the regular firm queue would allow. What varies between regions is which constraint applies, how much money has to be posted up front, and which regulator’s rulebook governs the deal.
Why four governors signing one letter is unusual
The four-state governor letter on Oct 30, 2025 is a rare alignment. State energy policy across the PJM region has historically been fragmented — Maryland’s climate goals don’t line up cleanly with West Virginia’s coal economics or Ohio’s utility politics — and four governors (two Democrats, two Republicans) jointly signing an energy-policy letter is the kind of signal that almost never happens. Maryland’s Office of People’s Counsel (the state office that represents residential ratepayers) filed federal support for the bring-your-own-generation plus expedited interconnection idea in July 2025; even the consumer-advocate side wants this exchange to exist. New York’s Public Service Commission opened Case 26-E-0045 in February explicitly naming bring-your-own-generation as a tool, with reply comments due May 13, 2026 and a Department of Public Service Staff white paper due Feb 12, 2027.
Why this matters across a developer’s site portfolio
A data center developer with sites in PJM (mid-Atlantic), ERCOT (Texas), and SPP (the central plains, from Oklahoma up through the Dakotas) now runs three different feasibility calculations, three different filing workflows, and three different up-front cash requirements. Cliff is being built to render that as a single portfolio view rather than three separate analyses. See the companion post on ERCOT PCLR for the Texas equivalent, and the original de-rate calculator post for the air-permit math that interacts with PJM’s interruptible products. Talk to us if you’re looking at sites in more than one region.
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)
Glossary
- PJM
- The regional grid operator (an ISO/RTO) for 13 states from New Jersey through Ohio and Virginia. Runs the wholesale electricity market and queues new generators and large loads.
- FERC
- Federal Energy Regulatory Commission. The federal agency that approves interstate transmission tariffs and oversees PJM and other grid operators.
- Interconnection
- The process of getting permission and physical infrastructure to plug a new load or generator into the public grid. Today it routinely takes 3-7 years for a hyperscale data center.
- Flex / non-firm / energy-only
- Interconnection products where the grid is allowed to curtail you when the wires are constrained, instead of building enough wire for full firm delivery. You clear the queue faster and accept some downtime.
- Curtail
- Order a load or generator to reduce or stop output because of a physical constraint or emergency on the grid.
- Co-located load
- A large load (often a data center) sited on the same parcel as a power plant and configured to take some or all of its electricity directly from that plant.
- BYONG / BYOG (Bring Your Own New Generation)
- An arrangement where a large load brings its own dedicated generation source rather than relying on grid capacity, in exchange for faster interconnection.
- ANOPR / rulemaking
- Advance Notice of Proposed Rulemaking. The earliest formal stage at which a federal agency proposes a new rule and asks for industry input.
- Tariff
- The official rate book a grid operator files with FERC. New products like the three EL25-49 services only become real once the tariff language is approved.
- Capacity charge
- The portion of an electricity bill that pays for keeping enough power plants on standby to meet peak demand. Non-firm interruptible customers can be exempted from these.
- ERCOT / SPP
- ERCOT is the grid operator for most of Texas. SPP is the grid operator for the central plains (Oklahoma, Kansas, Nebraska, the Dakotas, parts of Arkansas and New Mexico).
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