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Board Decision on Reliability Backstop Procurement & Connect and Manage (Now IRAS)

The PJM Board of Managers has issued its decisional letter closing out the combined Critical Issue Fast Path on the Reliability Backstop Procurement and Connect and Manage — five months of accelerated stakeholder process, now headed to FERC as two separate Section 205 filings.

Board Decision on Reliability Backstop Procurement & Connect and Manage (Now IRAS)

(Link to Board Letter)

The real story with this is the governance signal. On June 30, PJM’s membership voted decisively, 3.778 against a 3.335 passing threshold, for a subscription-based backstop where load-serving entities affirmatively opt in to the megawatts they want PJM to procure on their behalf. The Board acknowledged that the proposal had real merit but rejected it anyway, concluding that a voluntary framework couldn’t guarantee the shortfall would actually be filled. That’s the Board using its Manual 34 authority exactly as designed, and it’s a reminder for anyone tracking a CIFP process in PJM that a supermajority vote is a strong signal but not a guaranteed outcome.

What survives instead is closer to PJM staff’s own proposal of a forecast-based procurement target sized to the 2028/2029 BRA shortfall that can be reduced by new supply showings including signed contracts for new supply, approved new IRP supply, or large loads that commit to demand-side participation, although it seems unlikely there will be many signed bilateral deals made in time to decrement that target given the looming target procurement adjustment timeline. The other major piece of this is cost allocation, in which RBP costs will first be allocated to zones based on their share of the procurement target, then to LSEs based on a new Reliability Backstop Obligation (RBO). The most contentious part about this is if the states have not established frameworks for allocating those RBO costs to specific new data centers, the fallback is that PJM will allocate to all load in that zone using existing PLC assignments. So, they are essentially shifting one of the most consequential near-term actions to the states to develop large-load flexibility and interruptible-service tariff rules.

Connect & Manage tells the opposite story. The Board built its own mandatory curtailment construct that none of the CIFP Stage 4 proposals included—and renamed it Interim Resource Adequacy Service (IRAS), since the program now reflects a new Emergency Procedure that governs load reduction rather than the physical connection of load to the grid. IRAS presumably will run through Electric Distributors and a new Large Load Registry rather than direct PJM control over any individual customer, reflecting the jurisdictional line between PJM’s wholesale role and the states’ authority over retail service. Large Loads that haven’t brought BYONC or are not offset by RBP-credited UCAP are the ones assigned IRAS responsibility, with curtailment triggering ahead of Pre-Emergency Load Management. It’s a real operational tool, but one PJM had to design largely on its own once the stakeholder process couldn’t converge on how or when these loads would be curtailed. This creates a strong incentive for data centers to contract for new supply and get out of this emergency procedure bucket, because it makes curtailability a real threat given the frequency with which PJM has been deploying Pre-Emergency DR.

Both filings are due to FERC by the end of July to preserve the September 30 procurement. The near-term takeaway for market participants is that BYONC status is the single lever that moves both RBP cost exposure and IRAS curtailment priority, and it’s worth considering which path between the central procurement and bilateral matchmaking will be the more advantageous route ahead of the October bid window.

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Sam Selick, MBA is a Senior Consultant at Customized Energy Solutions (CES), a global energy services and technology company.