Digital Power Network Urges FERC to Refine PJM Co-Located Load Framework to Preserve Flexible Load Participation and Speed-to-Power
FOR IMMEDIATE RELEASE
Digital Power Network Urges FERC to Refine PJM Co-Located Load Framework to Preserve Flexible Load Participation and Speed-to-Power
Washington, D.C. — March 16, 2026 — The Digital Power Network (“DPN”) has filed comments with the Federal Energy Regulatory Commission (“FERC”) in PJM Interconnection, L.L.C., Docket No. ER26-1479-000, urging the Commission to ensure that PJM’s proposed compliance revisions do not inadvertently undermine the economic viability and operational flexibility of large flexible loads, including Bitcoin mining and other digital infrastructure projects.
In its filing, DPN recognizes that PJM’s proposal represents an important step toward providing greater tariff clarity for co-located load arrangements and establishing more defined service pathways. At the same time, DPN argues that the Commission should not allow the new framework to come at the expense of the very flexibility that makes many emerging large loads valuable to the grid. Flexible loads can rapidly curtail, respond to system conditions, and support demand response and related reliability services when market structures preserve the right incentives.
DPN’s comments raise several key concerns with PJM’s proposed compliance filing.
First, DPN argues that the Commission should ensure PJM’s new co-located load transmission service framework preserves the operational flexibility of flexible loads. The filing explains that many digital infrastructure projects, including Bitcoin mining facilities, are designed to operate dynamically and can provide meaningful reliability value when they retain the ability to curtail and participate in demand response. DPN cautions that service constructs that reduce the economic incentives for non-firm or flexible operation could reduce, rather than enhance, those grid benefits.
Second, DPN urges FERC to ensure that the final framework continues to economically support demand response and other reliability-enhancing behavior. The filing explains that flexible loads do not simply consume electricity; they can also function as highly responsive demand-side resources during periods of stress or congestion. DPN emphasizes that preserving the financial logic of curtailment is critical if these projects are to continue delivering those system benefits in practice.
Third, DPN calls on the Commission to take a closer look at PJM’s proposed 50 MW threshold for new Retail Behind-the-Meter Generation (“Retail BTMG”). DPN argues that behind-the-meter configurations can provide a viable speed-to-power pathway, particularly at existing industrial sites, brownfields, and other locations with legacy infrastructure, and that a categorical 50 MW cap risks foreclosing those opportunities for a substantial segment of new computing infrastructure in the PJM region.
DPN also urges the Commission to consider whether a higher interim threshold would be more appropriate while the region continues to evaluate the scale and impacts of large-load growth. The filing notes that PJM itself acknowledged that parties in the underlying proceeding proposed higher thresholds, such as 200 MW, as a way to preserve existing investments and account for current uncertainty.
Finally, DPN warns against forcing projects into frameworks that may compound PJM’s already significant queue and study delays without stronger justification. The filing explains that if projects above the 50 MW threshold are pushed into additional study and interconnection pathways, the result could be further delays for fast-moving digital infrastructure developments. DPN argues that where load forecasting for emerging sectors remains uncertain, PJM and FERC should avoid prematurely eliminating viable behind-the-meter options that may allow projects to move more quickly.
In conclusion, DPN supports the efforts to meaningfully reform large load colocation frameworks but asks the Commission to require further refinement of PJM’s compliance filing and, at minimum, to ensure that the final framework preserves meaningful opportunities for flexible loads to participate in adequately incentivized demand response and related reliability-supporting arrangements, revisits or further justifies the proposed 50 MW threshold for new Retail BTMG, and avoids unnecessarily exacerbating queue-related delays for large flexible loads and data centers seeking timely deployment in PJM.
View the full letter here.
About the Digital Power Network
The Digital Power Network, an affiliate of the Digital Chamber, is the largest coalition of Bitcoin miners and digital infrastructure providers, advocating for policies that support innovation, grid reliability, and commercially viable pathways for digital infrastructure deployment across the United States.