Docket No. ER26-3380-000


I concur in today’s order because, at its core, our responsibility to the 67 million people in PJM is to keep the lights on.  While the record reflects a wide range of views on how best to address the emerging reliability challenges, the downside risk of inaction far outweighs the risk of an imperfect solution.  It is not a close call.

The limited set of guidance we give PJM to revise its proposal will enable PJM to assign costs to those responsible (i.e. to the zones with data center growth) for the resource adequacy shortfall, consistent with cost causation principles, and it is my hope that PJM will act on this guidance swiftly so that needed generation may be procured. 

Many of the issues driving this filing extend beyond PJM’s jurisdiction to solve alone. States and retail authorities must play an active role – particularly in establishing large-load retail tariffs, enforcing collateral requirements, and establishing clear rules for which customers should be curtailed first when circumstances require it (Hint: homes, hospitals, and schools should never be curtailed before data centers).  As the order acknowledges,1 these are decisions that sit squarely with states and their regulators, and meaningful progress requires their continued leadership.

In the longer term PJM and its stakeholders must return to market fundamentals.  Load and supply should have strong incentives to hedge, manage their risks, and procure the capacity they rely upon.  Market discipline – not ad hoc backstops – must again become the primary safeguard for reliability.

For these reasons, while acknowledging the imperfections in the filing, I agree that taking action today is warranted, and I respectfully concur.

For these reasons, I respectfully concur.

  • 1PJM Interconnection, L.L.C., 196 FERC ¶ 61,245, at P 161 (2026).

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This page was last updated on September 30, 2026