PJM’s independent market monitor is doubling down on its hotly debated assertion that data center flexibility is little more than an expensive and unproven reliability gamble.
In a complaint filed to the Federal Energy Regulatory Commission late yesterday, Monitoring Analytics asked the commission to block new large load interconnections unless those projects come with matching new generation, or can be “served reliably as defined by both transmission and capacity adequacy.”
FERC should weigh in, the complaint said, on whether PJM even has the authority to rely on load curtailment as the basis for serving new data center demand. “Interconnecting large new data center loads when adequate capacity is not available is not providing reliable service,” the monitor wrote.
The filing comes in response to PJM’s Critical Issue Fast Path process, a stakeholder initiative the RTO’s board of managers kicked off over the summer to help address issues related to large loads. Just last week, stakeholders rejected all of the proposals that had been submitted as part of the initiative — including the market monitor’s own proposal, which would require data centers to bring their own matching generation capacity.
But the proposals and the vote revealed a foundational problem in the way PJM and other stakeholders are considering new data center load, the market monitor told FERC.
“PJM is not required to add large new data center loads when the loads cannot be served reliably consistent with the standards defined in the PJM Market Rules,” the complaint said. “However, the positions presented in the CIFP stakeholder process have clarified that PJM and many stakeholders are not willing to state that PJM has such authority.”
None of the proposals, the monitor said, “addressed the fact that PJM does not have the authority or the capability to order or enforce curtailments,” it added. “Under all these proposals, PJM will be in the position of recommending the allocation of load curtailments rather than ensuring reliable service for all customers.”
It’s a critical disconnect, the monitor told FERC, that must be decided before the CIFP process can move forward; IMM called for “more explicit rules” to both protect resource adequacy and to keep capacity prices down — as well as to ultimately “ensure that there is a clear path to provide for the reliable interconnection of large new data center loads.”
The complaint comes alongside a parallel discussion on how to interconnect large loads on a federal level — spurred by the Department of Energy’s advanced notice of proposed rulemaking back in October. Initial comments in that process were due last week, and hundreds of filings revealed a similar disconnect over whether data centers can be reliable flexible assets.
Monitoring Analytics filed a notice of its complaint against PJM in the ANOPR docket, explaining that it was specific to PJM market rules, and “not intended as an alternative” to the ongoing federal rulemaking process. That said, the monitor added, PJM can’t afford to wait for the federal process to play out.
“The complaint is consistent with the objectives of the ANOPR but recognizes that PJM markets face an urgent need for immediate clarification of PJM’s authority over the interconnection of large new data center loads,” the monitor said.
