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Confusion Is a Constraint | Large Load Interconnection

Writer: Brian Gould
Brian Gould
6 days ago
3 min read

The rules that decide who gets power, when they get it, and who pays for it are being rewritten right now. Most of that work happens in regulatory filings, stakeholder meetings, and dockets with names only a utility lawyer could love.


If you develop or operate industrial, logistics, cold storage, or data center sites, those rules now shape your schedule as much as zoning or steel. And most people building sites do not have time to read them.


I have spent my career on one idea: find the constraint and remove it. Right now, for a lot of developers, the constraint is not the rules themselves. It is the confusion around them. So this is the first in a series of plain-English reads on the grid. What changed, what it means for a site, and what to watch next. No predictions. Just the information and how we read it.


First, who is PJM?

PJM Interconnection runs the power grid for 13 states and the District of Columbia, including Ohio. It is not your utility, and it has no power plants. Think of it as air traffic control for electricity. It keeps supply and demand in balance minute to minute, and it runs the markets where power plants get paid to be available when demand peaks.


Data centers and new industrial load are asking to land at a busy airport. PJM is deciding how many new planes it can take, in what order, and who pays for the extra runway.


What happened in October

Four things moved in a few weeks, and they point in the same direction.


The federal regulator sent part of the plan back. On October 9, the Federal Energy Regulatory Commission rejected most of PJM's plan for connecting large new loads, while approving its definition of large loads and a registry to track them. FERC said "States have a crucial role to play in this challenge." For anyone with a site in Ohio, that puts the state closer to the center of the decision.


Backup power got called up. From October 13 to 16, a U.S. Department of Energy emergency order let PJM direct backup generation, including battery storage, to run as a last resort before its highest-level grid emergency. Power sitting behind the meter at businesses became part of the plan for keeping the grid reliable, if only for four days.


Ohio already opened the door. Ohio's House Bill 15 "removes barriers for large energy users to self-generate power, either directly or through a third party." It also removed the requirement that self-generation sit on the customer's premises.


A data center paid for capacity on other people's sites. On October 22, Google announced it is funding "a 1-gigawatt (GW) virtual power plant" in PJM with Voltus, pooling "smart thermostats, batteries, and industrial assets" from homes and businesses, who receive "bill savings and cash payments."


What we are watching

On October 29, PJM "filed an amended proposal to FERC with the goal of commencing a Reliability Backstop Procurement on March 1, 2027." Among the updates: "DR/DER requirements for participating as qualifying RBP offsets." The question we asked on LinkedIn earlier this month still stands: does power generated on a customer's own site count?


Nothing is final. FERC still has to review what PJM filed.


What it means for a site

Every one of these stories says the same thing in a different way. Power is no longer just a line on the utility bill. It is a development decision, made at the start, alongside land, entitlements, and the building itself.


The big projects get their own studies and their own power plants. The 5 to 50 MW site down the road asks the same question with fewer resources to answer it: is the power there, on my schedule, at a cost I can underwrite?


That is the question PowerStack Microgrids™ was built to answer. As The Full-Stack Microgrid Company™, we develop, engineer, procure, and build the power infrastructure a site needs, as one accountable team. We have built solar, storage, and electrical systems for over a decade. Now we bring them together.


Talk to us before you commit to the site. One conversation tells you whether the power is there.


Next in the series: what PJM actually filed, in plain English.


Sources

FERC order on PJM large loads, Utility Dive, Oct 12, 2026: https://www.utilitydive.com/news/ferc-pjm-large-load-interconnection-iras-byonc/832716/


DOE Order No. 202-26-50, Oct 12, 2026: https://www.energy.gov/documents/doe-order-no-202-26-50




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