PJM’s electricity markets have always demanded close attention. But the last three years represent something different in kind, not just degree. Where previous periods of market stress tended to concentrate around a single issue — a capacity market reform, a difficult year for fuel prices, a congestion problem — what PJM is working through right now spans capacity, transmission, reserves, and load integration simultaneously. Every segment of the market has something material at stake.
For organizations operating in PJM, that means the cost of falling behind the stakeholder process has never been higher. What looks like a regulatory proceeding in one corner of the market can turn out to be an existential threat or a significant commercial opportunity, depending on how well-positioned an organization is when the rules settle.
The Issues in Play
Reliability Backstop
The most time-sensitive proceeding underway is the reliability backstop, ordered jointly by NERC and PJM’s governing bodies in January and expected to conclude as early as this month. The mechanism would authorize a special capacity auction allowing multi-year commitments of up to 15 years for large load entities — a structure PJM’s existing capacity market does not currently accommodate.
The intent is to assign dedicated capacity procurement responsibility to large loads, separating their cost obligations from those of other customer classes. This directly addresses a concern that has become increasingly visible in PJM’s stakeholder process: end-use customers have been showing up to planning meetings in growing numbers, and their concerns about rising costs have become a real input to market design decisions. The reliability backstop is, in part, PJM’s structural response to that pressure — an attempt to ensure that the costs associated with large load growth are borne by large loads rather than distributed across all ratepayers.
Connect and Manage
Running in parallel, PJM is developing a new reliability approach called Connect and Manage. It would make qualifying large loads interruptible in grid stress scenarios, before curtailment affects residential or other standard load classes. The mechanism is structured to encourage large load entities to secure their own generation resources rather than relying entirely on the shared grid — whether through grid-connected generation that can operate around the clock, or through on-site backup resources that can function as demand response during curtailment events.
The proceeding is still in early stages. The meetings have not yet produced a clear solution framework, but a deadline approximately eight weeks out means the pace of development will need to accelerate significantly.
Co-located Load
A related and less publicly discussed issue involves co-located load — the question of how generation and large load operating on the same site interact with PJM’s market rules. As large load entities explore on-site generation arrangements, PJM is working through the operational and market implications of loads and generation that share a physical interconnection but may have complex relationships with the broader grid. This proceeding, still pending at FERC, has material implications for how co-location arrangements are structured and what obligations they carry.
Transmission Investment
The transmission picture is substantial and shows no sign of slowing. Each of the last three Regional Transmission Expansion Plans has authorized investment levels larger than the prior three decades of transmission spending combined within the region. That reflects three converging pressures: load growth concentrated in specific geographic areas, a generation fleet whose location on the grid has shifted materially over the past decade, and aging infrastructure reaching end-of-life in large cohorts simultaneously. Supply chain constraints and post-pandemic cost increases have made rebuilding and expanding that infrastructure significantly more expensive than it would have been even five years ago. Organizations with generation assets or load-serving obligations need to understand how transmission cost allocation is evolving.
Reserve Market Reform
PJM has been working since 2023 to overhaul its reserve markets through the Reserve Certainty Senior Task Force. The initiative aims to roughly triple available reserve megawatts and create a new category of ramping reserve products designed to manage wider frequency swings caused by increasing solar penetration. PJM began seeing early signs of a duck curve dynamic in 2023, particularly on hot summer days with high solar output. The reserve overhaul is PJM’s effort to build the market structures needed to manage that challenge as it becomes more pronounced.
Why This Moment Matters for Large Load Entities in Particular
The reliability backstop and Connect and Manage proceedings are not background issues for large load entities — they will directly determine capacity procurement obligations, interruptibility requirements, and the resource arrangements large loads may need to put in place. These proceedings are moving quickly, and the time between a rule being finalized and its commercial implications becoming visible is shrinking.
The honest read on where things stand is that PJM is threading a needle with no obvious solution that satisfies all objectives simultaneously: bringing on sufficient new generation, expanding transmission to deliver it, accommodating large load growth, and keeping costs manageable across all customer classes. That tension is real, and it is what makes independent, expert guidance critical rather than optional.
How CES Fits In
The challenge most organizations face is not a lack of information. It is having the bandwidth and expertise to stay current across interconnected proceedings that move quickly and do not always telegraph their commercial implications clearly.
CES’s Market IQ team attends every PJM stakeholder meeting — lower and senior committees, task forces, working groups — and translates that engagement into guidance tailored to each client’s specific market position. For organizations with internal regulatory staff, CES functions as a ground-truth resource and sounding board, a monthly check on whether their read of a fast-moving process is complete. For organizations covering multiple markets with limited bandwidth for any single one, CES provides the consistent, expert presence the PJM process now demands.
The link CES provides is between what is happening at the ISO level and what it means for a specific organization’s commercial interests. Those two things are not always obvious to connect, particularly for clients whose businesses span multiple markets and multiple asset types. Understanding what happened in a stakeholder meeting last week matters a great deal less than understanding what it means for your capacity position, your transmission exposure, or your resource planning decisions going forward.
If you are active in PJM markets and want to ensure your organization has the coverage it needs, we would welcome the conversation.
By: Christina Corcoran, Senior Marketing Manager, Customized Energy Solutions
