Policy Gradients went quiet for several weeks this holiday season.1 PJM did not. This is the final post in the Standby, or Stand Firm series. When we left off, PJM’s Critical Issue Fast Path on Large Load Additions (CIFP-LLA) was in full swing as billion-dollar stakeholders argued over what to do about very large new loads—namely data centers—arriving faster than transmission upgrades and generation additions could accommodate. By late November, the CIFP’s window for deliberation timed out without producing a consensus package, even as the grid’s resource inadequacy—and constituents’ discontent—intensified.
After PJM’s process wound down, FERC stepped in with a related but separate decision that caught many by surprise. On December 18, 2025, the Commission issued an order directing PJM to rewrite its tariff treatment of “co-located load,” and it did so with unusual specificity. Today’s edition explains what exactly FERC deemed so unworkable, what FERC is requiring PJM to adopt instead, and whether that solves the region’s broader large-load challenge.
