
Large-Load Interconnection and NEPA Shifts: FERC’s June Commission Meeting
FERC issued show cause orders on large load interconnection to six RTOs and revised its NEPA cumulative impacts approach.
Originally published for customers June 17, 2026.
What’s the issue?
PJM approved approximately $11.8 billion in new baseline reliability transmission projects as part of its 2025 Regional Transmission Expansion Plan (RTEP), by far the largest amount approved in recent years.
Why does it matter?
Transmission planning provides an early look at where PJM expects future reliability needs, load growth, and infrastructure investment to emerge.
What’s our view?
The size of the investment reflects rapid large-load growth, primarily from data centers. PJM approval does not guarantee construction, but the plan is a useful snapshot as FERC’s large-load interconnection proceeding gets underway—and a strong indicator that natural gas-fired generation will bear a growing share of the reliability burden.
PJM’s 2025 RTEP produced the largest single-year reliability investment in recent memory: approximately $11.8 billion in new baseline reliability projects, nearly double the $5.9 billion approved in 2024. This post explains how the RTEP process works, what is driving the surge, and what the plan signals for natural gas demand as FERC’s large-load interconnection proceeding moves forward.
Reliability is front and center in PJM. In support of its capacity market structure—which aims to ensure sufficient generation is available during periods of grid stress—PJM conducts an annual Regional Transmission Expansion Plan (RTEP), studying expected load growth, generation additions and retirements, and system performance to identify where transmission upgrades may be needed.
Once PJM identifies a transmission need through the RTEP process, it opens a competitive proposal window in which transmission owners and developers can submit solutions. The 2025 Window 1 process attracted 134 proposals from 19 entities. PJM then evaluates those proposals based on cost, performance, constructability, permitting requirements, schedule, and developer capability before recommending projects to its Board of Managers.
The planning process can look as far as 20 years into the future, but the needs driving the 2025 cycle are much closer at hand. The selected projects were primarily aimed at addressing reliability concerns identified in the 2030 and 2032 planning models. Study and recommendation to the board do not guarantee construction; projects still must navigate permitting, land acquisition, and the practical challenges of building major infrastructure.
The headline from the 2025 RTEP cycle is its scale: approximately $11.8 billion in new baseline reliability projects. This is nearly double the $5.9 billion approved in 2024 and well above the $6.6 billion approved in 2023.

The main driver is large-load growth, much of which PJM attributes to data centers. As Arbo has documented, data center geography and power access vary significantly by region—and those regional differences are now showing up in PJM’s planning models. Compared to the 2022 RTEP, load forecasts increased by approximately 10 GW for 2030 and 15 GW for 2032. The impacts are not evenly distributed: PJM highlighted significant load growth in the Dominion zone and broader eastern PJM footprint, resulting in heavier west-to-east power flows across the system. PJM also cited more than 2 GW of generator retirements as a contributing factor.
The likely result is increased reliance on natural gas-fired generation. That pressure has been building in PJM’s capacity market, a dynamic Arbo examined in rising grid stress and the push for new generation as FERC leadership shifted. The chart below shows a 10-year outlook on natural gas generation in PJM, based on data from the Energy Information Administration’s Form EIA-860 (the Annual Electric Generator Report), covering both currently operating and proposed natural gas generation. Not all proposed projects will ultimately be built.

Also worth highlighting is PJM’s Constructability and Cost Analysis for Window 1, in which PJM evaluated a representative sample of 27 projects across five focus areas. As the chart below shows, many projects fall at or above the medium constructability risk level, underscoring the role that post-approval work—permitting in particular—plays in turning a planned project into a completed one. PJM’s most frequently cited reason for rating a project at or above medium constructability risk was land acquisition associated with greenfield development.

PJM’s 2025 RTEP is a practical illustration of why FERC’s large-load interconnection proceeding is moving with urgency. The Secretary of Energy directed FERC to initiate a rulemaking on large-load interconnection on October 23, 2025. FERC responded with an Advance Notice of Proposed Rulemaking (ANOPR) on October 27, 2025, defining large loads as facilities requiring more than 20 MW of capacity. As discussed in Changing of the Guard, Shifting of the Grid, that directive set the federal policy context driving this proceeding.
At its June 18, 2026 open meeting, FERC issued show cause orders to six grid operators—CAISO, ISO-NE, MISO, NYISO, PJM, and SPP—requiring each to either defend its existing interconnection framework for large loads or propose improvements. Responses are due approximately August 17, 2026, with a 90-day extension available if requested within 45 days. As Arbo covered in Large-Load Interconnection and NEPA Shifts: FERC’s June Commission Meeting, the Commissioners were clear that inadequate responses would prompt the Commission to act directly.
Data center growth is no longer a long-term planning assumption. The same large-load growth driving FERC’s proceeding is already influencing transmission investment decisions, and not just in the country’s largest organized power market. As Arbo has tracked in examining grid reliability shifts across the U.S., the reliability pressures are registering simultaneously in capacity markets, generation retirements, and infrastructure planning cycles.
PJM’s RTEP is an annual transmission planning process that studies expected load growth, generation additions and retirements, and system performance to identify where transmission upgrades are needed across PJM’s 13-state footprint. PJM opens competitive proposal windows for developers to submit project proposals, then recommends a set of reliability projects to its Board of Managers.
The 2025 cycle approved approximately $11.8 billion in new baseline reliability projects, nearly double the $5.9 billion approved in 2024. The primary driver is large-load growth—mainly from data centers—which added roughly 10 GW to PJM’s 2030 load forecast and 15 GW to its 2032 forecast compared to 2022 projections.
No. PJM’s recommendation initiates the development process, but approved projects still require permitting, land acquisition, and financing before construction can begin. PJM’s own Constructability and Cost Analysis found that many Window 1 projects carry medium or higher constructability risk, with land acquisition for greenfield development cited most frequently.
Load growth that outpaces current generation capacity makes natural gas-fired generation the most likely near-term reliability backstop in PJM. EIA-860 data shows significant proposed natural gas capacity through the mid-2030s in the region, though not all proposed projects will ultimately be built.
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