PJM recently and rather hastily launched a "fast-track" stakeholder process to develop rules for interconnecting data centers and other large loads across its 13 state + DC footprint. Non-Capacity-Backed Load (NCBL) is a proposed new class of electricity demand in PJM, for new, large loads of 50 megawatts or more, and the NCBL initiative is intended to manage the rapid growth of large electricity consumers, which has strained the grid and caused capacity prices to rise. While NCBL customers would not be required to procure additional capacity or participate in the annual capacity auction, they would also be subject to curtailment before other large customers during grid emergencies.
Released on August 29, the grid operator's first pass at the "Critical Issue Fast Path initiative" took a fast path to nowhere, panned by the Data Center Coalition, a trade organization representing some of the largest players such as Google, Meta and Microsoft because it "exceeds PJM’s jurisdiction" and "undermines the integrity of its market framework."
Pointedly, it was also declared not viable by PJM's own Independent Market Monitor (IMM), Monitoring Analytics, which noted, unsurprisingly, that it's "unlikely data centers that want 99.999% uptime would accept having their load curtailed." In the same vein, power generator Exelon exclaimed “Nothing in the NERC reliability framework permits an RTO to pre-arrange routine load shedding of a designated customer class as a substitute for resource adequacy.”
PJM, after withering criticism from a variety of stakeholders on its initial attempt, released its updated its proposal on September 15, 2025. The changes include:
PJM would calculate the total amount of mandatory NCBL required and allocate it to electric distribution companies (EDCs) and load-serving entities (LSEs). These organizations would then be responsible for further assigning their NCBL allotment to specific customers.
NCBLs would (still) be the first to be curtailed during a grid reliability event, even before paid, capacity-backed demand response resources are called upon to shed or reduce load.
PJM would remove the NCBL from a zone's forecasted peak load when determining cost responsibility.
A customer that procures its own supply through BYOG (Bring Your Own Generation) or participates in demand response would receive a credit, reducing or eliminating their NCBL obligation.
While NCBLs would still not be required to pay for capacity, they would still pay for transmission charges, and PJM would "add back" the curtailed load when calculating Network Service Peak Load (NSPL).
So, we'll see where round two goes! This initiative is expected to culminate in a special member vote, with a goal of an initial filing with the Federal Energy Regulatory Commission (FERC) in December 2025. Ideally, final rules would be promulgated before the capacity auction for the 2028/2029 delivery year.