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A NEWSLETTER FROM ADVANCED ENERGY UNITED

November 19, 2025

In a non-binding member vote late today, no proposal received enough votes to pass, leaving the board with difficult decisions as PJM’s Critical Issue Fast Path (CIFP) for Large Load Additions (LLA) comes to a conclusion.

Today, PJM held its final Critical Issue Fast Path (CIFP) for Large Load Additions (LLA) stakeholder meeting. The 7-hour stakeholder meeting, which was closed to the media, featured summary presentations of the 12 final stakeholder proposals (including the PJM proposal). The PJM Board of Managers questioned the presenters -- no other stakeholders were permitted to speak; however, pre-registered stakeholders were given 4 minutes to provide comments. The CIFP meeting was immediately followed by a brief Special Members Committee meeting, which culminated in a member vote on the 12 final proposals.

Members voted on each proposal independently, voting yes, no, or to abstain. No single proposal received enough YES votes to meet PJM's threshold for passing.

The following represent the top four proposals in order of the most YES votes received:

The member vote in this CIFP process is advisory to the PJM Board of Managers, who have the ultimate decision on how to move forward on PJM rules for large load additions - the Board has the option to choose another proposal, a combination of proposals developed by the Board, or to do nothing. The Board offered no specific timeline for its decision. Still, the CIFP process timeline was driven by the Board’s desire to have rules in place in time for a December FERC filing so that new rules can go into effect in advance of the June 2026 capacity market auction. To meet that timeline, the Board will need to reach a decision quickly.

The voting reflects the nearly impossible challenge of trying to ensure resource adequacy and control ratepayer costs, while also allowing data center development in a market that is already short on generation supply and faces a 5-to-7 year timeline to bring on new large-scale generating resources.

Board Chair David Mills, after the vote, indicated that the Board will act, they will review the voting results carefully, and piece together a proposal for filing at FERC.

 NOTE: For reference, we’ve re-included last week’s background explainer and overview of the stakeholder proposals and state engagement below.

Critical Issue Fast Path (CIFP) for Large Load Additions (LLA)

Why it Matters:

PJM Interconnection faces a historic surge in electricity demand, driven largely by data-center growth, further stressing an already stretched PJM grid that is desperately in need of new energy supply.

In response, the PJM Board launched a “Critical Issue Fast Path” process to design new reliability measures. Peak load is expected to climb by 32 gigawatts (GW) by 2030, with 30 GW of that growth expected to come from data centers alone.

The key underlying question is how to manage the new demand so that existing customers don’t suffer cost increases or reliability shortfalls in a region that has already seen price spikes and diminished reserve margins. But given the potentially staggering numbers, it’s not an easy problem to solve. Should massive new power users be required to bring online the generation they require? Should they be brought onto the system on the condition that they be curtailed during emergency events? Or should they be barred from interconnecting to the grid until there is sufficient generation to serve them? 

CIFP Background:

The PJM CIFP for LLA, initiated by the PJM Board of Managers on August 8, is moving rapidly toward conclusion, with a stakeholder vote on the proposals scheduled for November 19.

The PJM board initiated the CIFP process to “explore reliability-focused solutions for integrating large load additions quickly and securely, without compromising resource adequacy across the region.”

The Board is on track to develop a FERC filing by December 2025, with the proposal intended to take effect for the 2028/2029 Base Residual Auction, scheduled for June 2026. (Recall that, absent intervention, this auction will no longer have the “price collar” that capped prices in the last auction and that will still be in effect for the December 2025 auction for the 2027/2028 delivery year.)

Since the August kick-off, PJM has held seven stakeholder meetings, many of them day-long meetings. The Board is not required to accept the outcome of the November 19th stakeholder vote on proposals. It also has full autonomy to decide which, if any, plan for large load additions is ultimately filed at FERC in December. Further complicating matters, on October 23, DOE Secretary of Energy Chris Wright directed FERC to initiate an Advanced Notice of Proposed Rulemaking (ANOPR) “presenting potential reforms to ensure the timely and orderly interconnection of large loads.” DOE provided fourteen principles expected to inform the procedures.

FERC has since docketed the proposal (RM26-4), and comments are due November 21. DOE requested that FERC take final action by April 30, 2026. Doing so will require issuing a Notice of Proposed Rulemaking (NOPR) and a final rule.

CIFP Proposals:

PJM presented its initial proposal under the CIFP process at the September 15 stakeholder meeting and received nearly 200 pages of stakeholder comments. Many stakeholders expressed strong opposition to the proposal’s centerpiece— a provision that would have placed certain large loads under mandatory Non-Capacity Based Load (NCBL) status, subjecting them to involuntary curtailment during periods of resource adequacy constraints. As a result of the negative feedback, PJM’s proposal has shifted a few times, starting with the removal of the NCBL and the addition of an expedited interconnection queue process for “state-sponsored” generation.

PJM’s current CIFP proposal includes three major updates:

PJM withdrew its proposal to mandate certain large loads as NCBL, which would have subjected them to curtailment before demand response resources. The NCBL concept will remain as a voluntary option through existing demand response and price-responsive demand programs.

PJM is proposing a new state commission review step for large load adjustments. Electric distribution companies (EDCs) will also be required to submit information on duplicate load requests to avoid double-counting. PJM is further considering a financial security requirement for large customers based on their capacity obligations.

PJM has proposed a 10-month expedited interconnection queue pathway for state-sponsored, shovel-ready resources that meet high eligibility criteria. This expedited path would complement PJM’s existing State Agreement Approach (SAA).

PJM is currently considering an additional 20 unique stakeholder proposals and has encouraged stakeholders to consolidate proposals in advance of the November 19th stakeholder vote.

State Engagement in CIFP:

Recent PJM processes, and the CIFP process in particular, have motivated an unprecedented level of state engagement at PJM, which has been building since the June 2025 electric price increases stemming from the 2024 BRA Capacity Market Auction. Representatives from the governors' offices, legislatures, public service commissions, and consumer advocates in PJM states have been active, vocal participants in the many recent CIFP stakeholder meetings.

Noteworthy recent examples of new, organized PJM advocacy coalitions include the PJM Governors Collaborative, announced on September 24, and the PJM State Legislators Collaborative, a bipartisan group of lawmakers from all 13 PJM states, announced on October 23. Other recent examples include a November 5, US Congressional coalition letter to PJM expressing concern about cost and reliability, and an Illinois legislator's letter urging the PJM Board to select a consumer protection-focused proposal in the CIFP process. 

Maryland State Senator Katie Fry Hester, referencing the CIFP process in a whitepaper issued on October 14, reflected the urgency that many state officials appear to feel, stating: "We must act NOW to avoid a massive transfer of wealth from the average ratepayer to the large energy generators and users before December 2025."

Next Steps in CIFP Process:

A Selected Sampling of Noteworthy Proposals

PJM Updated CIFP Proposal

Key Themes Include:

Independent Market Monitor (IMM) Proposal

Key Themes Include:

Governors’ & Data Center Coalition (PA, VA, NJ, MD)

Key Themes Include:

Amazon–Google–Microsoft–Constellation–Calpine–Talen Joint Proposal

Key Themes Include:

Bipartisan State Legislators + NRDC Proposal

Key Themes Include:

PA Office of Consumer Advocate

Key Themes Include:

Maryland OPC + PA OCC Joint Consumer Proposal

Key Themes Include:

Key PJM Updates & Policy Developments

PJM Announces Internal Executive Promotions While It Continues Its Search for a New CEO

PJM is still searching for a replacement for outgoing CEO Manu Asthana. Asthana announced his resignation on April 14, with the intention for it to be effective at the end of 2025. If a new CEO is not in place by January 1, 2026, PJM Board Chair David Mills will take over as interim president and CEO while the search continues.

“The board is committed to finding the best candidate to lead PJM through the numerous challenges facing the industry, and that meticulous process continues,” Mills also stated: “This new structure will strengthen our executive team and allow the incoming CEO to focus early on the external work of building strong relationships with stakeholders, regulators and state leaders, and navigating the evolving energy landscape.”

In the meantime:

• Executive Vice President of Market Services and Strategy, Stu Bresler, has been promoted to Chief Operating Officer (a new role at PJM), putting him in charge of core departments such as operations, markets, and planning. He has been with the Regional Transmission Organization (RTO) for more than 30 years.
• Executive Vice President of Operations, Planning, and Security, Aftab Khan, was promoted to Chief Strategy Officer, setting him up to “lead cross-functional initiatives and drive organizational transformation to ensure sustainable success and alignment,” according to the PJM announcement. He served as Senior Vice President of Engineering for Eversource Energy before joining PJM in 2024 and previously worked at General Electric and ABB.
• Vice President of Market Design and Economics Adam Keech was promoted to Senior Vice President of Market Services. He has been with PJM since 2003, having held roles overseeing compliance and real-time market operations, NERC compliance, and other areas.

PJM spokesperson Jeff Shields said the new titles redefine the three executives’ duties, and the prior positions will not be backfilled.

FERC Filings & Decisions

The Federal Energy Regulatory Commission (FERC) is an important independent agency that regulates interstate transmission of electricity, natural gas, and oil. As the agency that oversees regional transmission authorities such as PJM, it is important to know what FERC is working on and how this may impact consumers in your state. Read more FERC PJM Insights below:

FERC Chairmanship Change and New General Counsel 

• On October 24, following her appointment, Laura Swett was officially named Chair at FERC. As Chair, Swett has the ability to set the calendar and dockets for voting at the Commission. Chairwoman Swett has released the names of her staffers, many of whom come from FERC.
  • Notably, however, the Chief of Staff for the Chairwoman, McKenna Skeeters, has served as the Special Assistant to the President for Presidential Personnel since January. Commissioner LaCerte has not yet finalized his staff.  
• A new General Counsel, James Dawson, was also appointed. Dawson comes to FERC from Vinson & Elkins. Before this, Dawson held an associate position at another DC-based firm and served as a clerk at the US Court of Appeals.

RM21-17-000 - Order 1920 Extension 

On October 17, FERC issued notice granting an extension of time for PJM-related entities to comply with Order No. 1920 transmission planning and cost allocation requirements in response to a joint filing by PARSEC (PJM Area Relevant State Entities Committee) and PJM Transmission Owners on September 12, 2025. PARSEC's Engagement Period is extended to April 7, 2026, and PJM Transmission Owners' compliance filing deadline is extended to June 12, 2026. 

Advanced Energy United

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