PJM in three charts: 13 states, three deals, the next 13 weeks
Raymond Xu
April 28, 2026 · 4 min read
PJM (the regional grid operator covering 13 states from New Jersey through Ohio and Virginia) is in the middle of a one-year window where three different rule changes are being written simultaneously about how large electricity users — mostly data centers — can plug into the grid faster than the normal multi-year queue allows. Three different authorities are writing the rules: PJM’s own board, and two separate dockets at FERC (the Federal Energy Regulatory Commission, the federal agency that sets transmission rules). For anyone trying to decide which of these new pathways to use, only three things really matter: which states have the political alignment to make any of this stick, what each of the three deals actually requires you to give up, and how little time is left 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’s territory is 13 states plus Washington DC, serving 65 million people. State politics across that footprint have historically been fragmented — Maryland’s climate goals don’t line up with West Virginia’s coal-based economy or Ohio’s utility politics. So a joint letter on Oct 30, 2025 from the governors of Pennsylvania (Shapiro), New Jersey (Murphy), Maryland (Moore), and Virginia (Youngkin) was unusual: two Democrats and one Republican collectively endorsing the same approach. They jointly backed BYONG (“bring your own new generation” — the requirement that a new large electricity user build dedicated power plants to cover its own load) paired with Expedited Interconnection (a faster grid-connect track). They partnered with the Data Center Coalition (the data center industry trade group) and Exelon (a regional utility). Without that political alignment, neither the PJM Board action nor the related FERC 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 (Virginia’s main utility) saw its contracted data center capacity jump 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 data center developer in PJM territory 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 being curtailable (the grid can shut you off when stressed), or accept being over 20 MW and dispatchable (large enough and flexible enough that the grid can ramp you up and down) — and get a grid connection faster than the normal firm-queue physics allows. What varies is which constraint, under whose tariff (the legal rate sheet that governs grid service), on what timeline.
BYONG (Bring Your Own New Generation) is the most aggressive: skip the queue entirely in exchange for building dedicated power plants sized to your hourly forecast and absorbing 100 percent of any network upgrade costs the grid demands. Non-Firm Contract Demand is the cheapest on paper — you don’t pay the standard generation-capacity charges — but the grid only meters your net withdrawals after your own onsite generation, and you accept being the first one curtailed 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 user who agrees to be curtailable, but the rule itself is still pending final action by FERC.
3. The decision window is 13 weeks, not 13 months
FERC’s original final-action deadline on the rulemaking docket RM26-4-000 (the federal proceeding writing the rules for connecting large loads to the interstate transmission grid) 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 (the Texas grid operator), and SPP (the central-US grid operator covering the Plains states) territory is that the three queues are now running on parallel but not synchronized clocks. ERCOT’s PCLR (Provisional Capacity Load Resource — the Texas equivalent declaration that lets a large load enter the queue early) is due July 24, 2026. SPP’s HILLGA / LLRIS (the equivalent SPP-region program names for high-impact large-load interconnection) 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 (cross-grid-operator) portfolio view a single-state consultant can’t give you.
What's next
If you’re evaluating a site inside PJM territory — especially in Loudoun or Prince William County (Virginia), Columbus (Ohio), 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 onsite-generation economics at that node, and what the math looks like against staying in the regular firm-grid queue.
For the technical breakdown — the FERC EL25-49 paper hearing schedule, the eligibility specifics for PJM’s CIFP (Critical Issue Fast Path, PJM’s expedited stakeholder process), and the mechanics of the four-state governor letter — 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 (whether your onsite generators can legally run enough hours to make the deal work), see the de-rate calculator.
Glossary
- PJM
- PJM Interconnection. The regional transmission organization that runs the grid for 13 states (NJ, PA, MD, VA, WV, OH, NC, KY, IN, IL, MI, TN, DE) plus DC.
- FERC
- Federal Energy Regulatory Commission. The federal agency that approves interstate transmission rules and tariff changes.
- Capacity auction / RPM / BRA
- PJM's annual auction (Reliability Pricing Model, settled in the Base Residual Auction) where the grid pays generators to commit to being available three years out. Sets a capacity price that flows into customer bills.
- Interconnection queue
- The waiting line for new generators or large loads to connect to the grid. Formal study process that historically takes 4-7 years in PJM.
- ISA
- Interconnection Service Agreement. The signed contract that lets a project actually energize once the queue study is done.
- CIR (Capacity Interconnection Rights)
- The grid right that lets a generator sell capacity into the RPM auction. Without CIRs, a generator can only sell energy.
- Energy-only
- An interconnection that can sell electricity when it runs but cannot bid into the capacity auction. Faster to get than a full capacity-rights interconnection.
- BYONG
- Bring Your Own New Generation. PJM mechanism that lets a large load skip the queue if it builds dedicated generation sized to its own hourly forecast.
- Non-Firm / curtailable
- Grid service that can be cut off first when the system is stressed. Cheaper than firm service because the customer absorbs the reliability risk.
- Tariff
- The FERC-approved legal rate sheet that governs how a grid operator charges for transmission and capacity service.
- EL25-49 / RM26-4-000
- Two specific FERC dockets. EL25-49 is the December 2025 order on co-locating power plants with data centers in PJM. RM26-4-000 is the rulemaking writing federal rules for large-load interconnection.
- ERCOT / SPP
- Other regional grid operators. ERCOT runs the Texas grid; SPP runs the central US (Plains states). Separate from PJM, with separate queues and separate rules.
Primary sources
- PJM Board letter on CIFP large-load additions (Jan 16, 2026)
- FERC fact sheet on EL25-49 (Dec 18, 2025)
- FERC RM26-4-000 docket (Interconnection of Large Loads to the Interstate Transmission System)
- FERC announcement: act on RM26-4 by end of June 2026 (Apr 16, 2026)
- Inside Climate News: “Four Governors Whose States Rely on PJM Want Data Centers to Guarantee Their Own Power” (Oct 30, 2025)
- Baker Botts on FERC EL25-49: three new transmission services and compliance schedule
- PJM Interconnection territory served
- Loudoun County: data center inventory and FY27 budget
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