On December 19, 2025, the Federal Energy Regulatory Commission
(FERC or the Commission) issued its much-anticipated order on show
cause proceeding concerning the co-location of generation and load
within the PJM Interconnection, L.L.C. (PJM)
market.1 In the order, the Commission finds that
PJM's tariff is unjust and unreasonable because it does not
provide sufficient clarity on the rates, terms, and conditions of
service applicable to generators serving Co-Located Load and does
not include transmission services appropriate for customers that
are willing and able to limit their use of the transmission system
in certain conditions.
The Commission's order is animated by the perspective that
co-location is an important tool to meet the growing demand for
energy to power data centers critical to achieving the United
States' long-term strategic and economic objectives while
minimizing the impact on the grid and consumers. This view is
perhaps best summarized in