A facility can be ready to operate long before the grid is ready to serve all of its demand.
For large projects, the question is increasingly whether part of that demand can be reduced when the system is short of capacity. In the PJM region, that question now comes with a filing, a compliance date and a compensation formula. The answer will decide how soon a project connects and what it gives up to get there.
PJM Has Asked FERC to Approve Curtailment-First Service by October 12
PJM's board put the trade-off on the agenda in January. It directed staff to develop a framework in which new large loads that did not bring their own generation would be curtailed early during shortages. On July 27, the board set a date. During capacity shortages, new large loads that have neither brought generation online by June 1, 2027 nor otherwise secured supply would be curtailed before existing pre-emergency load management resources.
PJM then asked FERC on August 13 to approve the framework, now called Interim Resource Adequacy Service. The filing defines a large load as at least 50 MW at a single site and asks for a decision by October 12. It would apply first to new large loads entering service after June 1, 2027. An obligation under the service would not mean routine curtailment. PJM's operations planning director said in an affidavit that reductions would come only when real-time conditions call for them.
A load can shrink that exposure by bringing qualifying new capacity, which PJM calls Bring Your Own New Capacity. Capacity from PJM's separate backstop procurement can also count. Loads directed to reduce would be paid up to half of PJM's non-performance charge rate, and a customer can waive payment. State regulators decide how that compensation is funded, and Pennsylvania's governor has already directed regulators to seek rules that curtail data centers first unless they secure capacity.
FERC's June Orders Direct Grid Operators to Build Services for Flexible Loads
FERC has moved forward on the core issue first put to it by the Department of Energy (DOE) in October 2025, when a proposed Advance Notice of Proposed Rulemaking (ANOPR) sought to expedite grid access for data centers and massive industrial operations. On June 18, 2026, the commission took definitive action by issuing six tailored show-cause orders, one to each jurisdictional regional grid operator, including PJM. The orders name the integration of large energy users as a priority and establish five specific categories of reform. They direct operators to consider flexible transmission approaches—including interim non-firm transmission service while permanent grid upgrades are being built—and give the grid operators a strict 60-day deadline to either justify or completely overhaul their existing large-load interconnection tariffs.
Flexibility Has to Be Measured in Megawatts, Minutes and Hours
For a facilities leader, "flexible" has to mean something more precise than a willingness to help the grid. It means knowing how many megawatts can come off, how quickly, for how long and how often, without breaching production, safety, customer or equipment requirements. A data center might shift computing work. A manufacturer might sequence processes or rely on stored product. Neither can assume every load is interruptible.
Emergency procedures already show how tight those numbers can get. PJM added a procedure in June under which large loads may be asked to bring backup generation online within 15 minutes, as a last resort before firm load shedding. The DOE authorized that use during summer heat waves. PJM issued a warning on July 2 but did not need to exercise it. The procedure is separate from curtailment under the new service. It does show the response times operators are willing to specify.
Rotterdam offers a parallel outside the United States. TenneT and Stedin plan a temporary 500 MW transformer at Europoort, with commissioning no earlier than the end of 2028 and subject to permits and cable connections. The Port of Rotterdam Authority and the business group Deltalinqs welcomed the plan while saying more solutions are needed until permanent expansions are finished. Also involved, the New Energy Taskforce includes all four organizations and is studying flexible capacity with companies. Nothing about the transformer says how quickly a comparable U.S. project could connect. It does show why an interim operating plan matters while infrastructure is built.
The commercial test is whether an earlier energization date is worth the restrictions attached to it. Corporate teams already plan around staged energization and phased conversion, but curtailment adds a different kind of limit. It can create costs that never appear in a connection quote, including backup power and its permits, idle equipment, missed output, staffing changes and contractual penalties. An agreement also has to say who calls an interruption, how much notice the customer gets, whether reductions are measured at the meter or by process, and what happens if the customer cannot respond.
Large-load tariffs already carry collateral and exit terms that behave like long-term debt, and curtailment terms belong in the same diligence file. A customer that secures supply or brings new generation faces a different path from one that accepts curtailment. Project teams should compare those options against the cost and timing of grid upgrades. Flexibility is not automatically the cheapest route.
The Year-End Task Is Defining the Site's Curtailable Load
The year-end decision is to define the site's actual curtailable load before negotiating a connection. Facilities and operations teams should agree on the load blocks, minimum notice, maximum duration, recovery time and consequences of a failed reduction. Finance can then set that operating exposure against the value of opening sooner. Siting teams already ask energy access questions before committing capital, and curtailable load belongs on the same list.
Three decisions matter next. FERC is asked to rule on PJM's filing by October 12. The regional grid operators' responses to the show-cause orders will shape how other markets treat flexible loads. State regulators, Pennsylvania's among them, will set curtailment priority and fund the compensation. None of these currently supports a general claim that accepting curtailment will cut years from every connection schedule.
