Report
March 25, 2026
Brattle Experts Assess PJM’s Proposed Transmission Services for Large Loads Co-Located with Generation
Senior Consultant Mr. Andrew Levitt and Energy Associate Dr. Aniruddh Mohan recently assessed PJM’s proposed transmission services for large loads, such as data centers, co-located with generation. Their affidavit and supplemental affidavit note that, while PJM has made an important start, there are several enhancements needed to fully achieve FERC and Administration priorities on large loads:
- Offering non-firm contract demand service (NFCDS) any time it is available improves efficiency, accelerates the connection of new loads, and incentivizes the development of new generation.
- For Interim Network Integration Transmission Service (interruptible non-firm load waiting for full NITS), consumption generally does not need to be curtailed below the level of zero net withdrawals from the grid to the co-located facility. In addition, the curtailments required for transmission security versus for resource adequacy have distinct characteristics and should be treated differently.
- PJM must provide more clarity on how co-located load and supply will be studied together for interconnection processing in order to achieve speed to power.
- Other RTOs are already moving towards non-firm transmission services: SPP’s CHILLS proposal and ERCOT’s Provisional Controllable Load proposal both show that curtailable service for large loads can be workable, reliable, and implemented on timelines much faster than PJM’s proposed 2029 date.
- While both standard Remedial Action Schemes (RAS) and withdrawal-limiting protection systems internal to a co-located facility are helpful, the latter is far simpler, and treating them as interchangeable overstates the complexity of scaling permanent non-firm service.
