Plain-English framing. 'Co-located load' is the structure where a generator (a power plant) and a load (a data center) sit on the same site, behind the same point of interconnection, so the data center is electrically 'hidden' from the rest of the grid. Microsoft + Three Mile Island and Amazon + Talen's Susquehanna are the marquee examples. The unsettled question for two years has been: does that data center pay grid charges (like every other customer), or does it pay nothing (because it's not 'really' using the grid)? FERC's December 2025 order forced PJM to write a rule. The February 23 compliance filing is that rule. Three services worth understanding separately. (1) Interim non-firm transmission service. Before a customer can get full Network Integration Transmission Service — the gold standard, with guaranteed grid backup — they can take a lower-tier non-firm service that lets them connect faster but can be curtailed during grid stress. This is the 'connect now, formalize later' option. (2) Firm Contract Demand Transmission Service. Customer specifies a megawatt level they want guaranteed, signs a contract, and pays for it. The grid commits to deliver that MW regardless of what their on-site generator is doing. (3) Non-Firm Contract Demand Transmission Service. Same as firm but curtailable, much cheaper, used when the data center's primary supply is its co-located generator and grid is purely backup. What ties this to ERCOT Batch Zero: PJM and ERCOT are converging on the same structural answer for the same problem — give large loads an early-connect option in exchange for accepting curtailment when transmission is constrained. ERCOT calls its version PCLR (Provisional Controllable Load Resource). PJM calls its version Non-Firm Contract Demand. Same concept, different acronyms, same July effective dates. Sources: White & Case 'PJM proposes to carve out new services for co-located data centers'; FERC 'FERC Directs Nation's Largest Grid Operator to Create New Rules' fact sheet; Mayer Brown 'FERC Directs PJM to Facilitate Co-Location Arrangements'; PJM Inside Lines auction releases.
Primary source · White & Case / FERC / Mayer Brown / PJM ↗
Why it matters
Two product-level implications. (1) The July 31 effective date in PJM lines up almost exactly with the ERCOT July 24 Declaration of Intent deadline and the (likely) ERCOT July 10 Batch Zero effective date. So July 2026 is the month where both PJM and ERCOT — the two largest data-center grids in the country — formally codify their large-load interconnection rules. A developer with a PJM project and a Texas project will have to file structured forms in both markets within a two-week window. That's exactly the cross-jurisdictional workflow Cliff's filing-drafting wedge is designed for. (2) The convergence of PCLR and Non-Firm Contract Demand into the same structural product — 'cheaper grid service in exchange for curtailment when transmission is tight' — turns the 'interruptible load economics' analysis Cliff has been building into a portable tool. The math is the same in both markets; only the curtailment-frequency inputs change. That's the first piece of Cliff's product surface where one analytical engine covers PJM and ERCOT without a market-specific rewrite.
Related filings
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