PJM in three charts: 13 states, three deals, the next 13 weeks

Raymond Xu

April 28, 2026 · 4 min read

PJM’s 2026 flex-interconnection year is mostly being lived inside three regulatory venues at once: the PJM Board, FERC EL25-49, and FERC RM26-4-000. The parts that actually matter for whether a specific large load should pursue one of these mechanisms come down to three things: which states are politically aligned to make any of this work, what each of the three deals actually trades, and how short the window is before they all finalize. Three charts, in that order. The deeper companion with primary-source citations is PJM’s flex interconnection year.

1. The political alignment is the precondition

PJM is 13 states plus DC, serving 65 million people. State politics across that footprint have historically been fragmented — Maryland’s climate goals don’t align cleanly with West Virginia’s coal economics or Ohio’s utility politics. The Oct 30, 2025 joint letter from the governors of Pennsylvania (Shapiro), New Jersey (Murphy), Maryland (Moore), and Virginia (Youngkin) is the rare bipartisan alignment that made the next nine months tractable. Two Democrats and one Republican jointly endorsed BYONG with Expedited Interconnection, partnered with the Data Center Coalition and Exelon. Without that alignment, neither the PJM Board action nor FERC’s companion order would have moved in the same window.

The four-governor states are also where the load is. Loudoun County alone has 199 operational data centers and 148 more applications under review. Dominion’s contracted data center capacity jumped from 21 GW in July 2024 to roughly 40 GW by December 2024 — an 88 percent increase in five months. Northern Virginia is where the regulatory mechanisms are strongest because it is also where the demand-side political pressure is strongest.

2. Three deals on the table, one underlying bargain

A PJM developer in 2026 is choosing between three distinct mechanisms, each offered by a different authority, each with a different shape. The bargain underneath is identical in all three: accept some constraint — bring your own generation, accept curtailability, accept being over 20 MW and dispatchable — and get interconnection faster than firm-queue physics allows. What varies is which constraint, under whose tariff, on what timeline.

BYONG is the most aggressive: it skips the queue entirely in exchange for the developer building dedicated generation sized to their hourly forecast and absorbing 100 percent of any required network upgrade costs. Non-Firm Contract Demand is the cheapest on paper — no generation-capacity charges — but settles transmission service on net withdrawals after self-supply and accepts being curtailed first when the system is stressed. The federal 60-day path is the most flexible mechanism but the least concrete: it would apply broadly to any large load that agrees to be curtailable, but the rule itself is still pending FERC final action.

3. The decision window is 13 weeks, not 13 months

FERC’s original final-action deadline on RM26-4-000 was April 30, 2026, set by the Department of Energy on Oct 23, 2025. On April 16, 2026, FERC issued an Order Regarding Intent to Act extending the deadline to the end of June 2026. PJM’s Expedited Interconnection Track target is August 2026. Between now and August, all three mechanisms either go live or get a substantial first form. After August, the choice between them collapses into whichever ones FERC and PJM actually land on schedule.

The portfolio implication for a developer with sites in PJM, ERCOT, and SPP territory is that the three queues are now running on parallel but not synchronized clocks. ERCOT’s PCLR declaration is due July 24, 2026. SPP’s HILLGA / LLRIS went effective Jan 15, 2026. PJM’s mechanisms finalize in August. A site that misses one window often still has another jurisdiction’s window open — which is exactly the cross-ISO portfolio view a single-state consultant can’t give you.

What’s next

If you’re evaluating a PJM site — especially in Loudoun, Prince William, Columbus, or any of the four-governor states — send us the location and the MW. We’ll tell you which of the three vehicles is feasible against the actual transmission, air-permit, and BYONG-generation economics at that node, and what the math looks like against staying in the firm queue.

For the technical breakdown — FERC EL25-49 paper hearing schedule, PJM CIFP eligibility specifics, and the four-state governor letter mechanics — see the companion post on PJM’s flex interconnection year. For the Texas leg, see PCLR in three charts and ERCOT PCLR and Batch Zero. For the air-permit math that interacts with PJM’s non-firm products, see the de-rate calculator.

Primary sources

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1. The political alignment is the precondition

2. Three deals on the table, one underlying bargain

3. The decision window is 13 weeks, not 13 months

What’s next