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  • videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Energy
  • schedule 90 minutes

FERC PJM Order: Lessons for Data Centers, Co-Location, and Tariffs

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About the Course

Introduction

This CLE webinar will explain FERC's Dec. 18, 2025, directive ordering PJM to rewrite key tariff provisions governing co-located large loads (including AI/data centers) and behind-the-meter generation, and will translate the order into national, practical guidance for counsel advising large-load projects, generators, utilities, and market participants on interconnection, transmission service options, cost causation, and reliability risk allocation.

Description

The panel will use the PJM proceeding as a blueprint to analyze how similar disputes could play out across other regions and business models, whether front-of-the-meter interconnection, "behind-the-meter" arrangements, or hybrid structures that seek to limit net withdrawals from the grid.

Listen as our panel explores this new landscape and guides project and regulatory counsel on structuring large-load and co-location deals, anticipating tariff and stakeholder changes, documenting load flexibility commitments, and managing enforcement, litigation, and rate impacts.

Presented By

Stephen J. Humes
Partner
Pillsbury Winthrop Shaw Pittman LLP

Mr. Humes advises clients on clean energy project development and finance, including renewables, nuclear facilities, powering data centers, including grid-scale and net-metered solar photovoltaics (PV), offshore wind, battery energy storage systems and geothermal. For decades, he has advised clients on energy transactional, regulatory and environmental issues, including those associated with conventional and renewable power plant development, cogeneration, liquefied natural gas and pipeline facilities, geothermal and other utility infrastructure matters. Mr. Humes energy-related environmental experience includes advising clients on environmental due diligence, permitting, environmental justice and climate change issues. He guides clients through state and federal administrative proceedings, including advancing rate cases in administrative litigation and defending clients in enforcement actions. Mr. Humes also counsels clients on a full range of state and federal environmental compliance and enforcement matters and handles energy and environmental issues effectively in corporate mergers and acquisitions (M&A) transactions, including acquisitions and divestitures of power plants, nuclear facilities and renewable energy portfolios.

Tory Lauterbach
Partner
Gibson, Dunn & Crutcher LLP

Ms. Lauterbach is a partner in Gibson Dunn’s Washington, D.C. office. She has extensive experience providing regulatory and transactional advice to energy companies, large energy users, and their investors. Ms. Lautenbach represents renewable and traditional energy companies, including investor-owned utilities, independent transmission companies, independent power producers, energy investors, natural gas companies, and pipeline shippers in a variety of regulatory, transactional, and litigation matters. She also advises data center developers, investors, and lenders on all aspects of development and administration of data center power supply arrangements. Ms. Lauterbach advises clients regarding the Federal Power Act (FPA), the Natural Gas Act (NGA), the Interstate Commerce Act and related federal and state statutes, as well as requirements under public utility tariffs and agreements.

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, March 12, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. What FERC actually ordered (PJM case study, but universal issues)

II. The "menu" concept: new transmission service pathways for co-located load

III. Reliability plus resource adequacy: Why large load is now a tariff problem

IV. Applying the framework nationwide (beyond PJM)

V. The next wave: FERC's broader large-load interconnection rulemaking

VI. Practitioner takeaways

The panel will discuss these and other key issues:

  • How FERC's PJM order reframes co-located load and behind-the-meter structures
  • Why "tariff clarity" is now a deal risk for data centers, industrial loads, and generation co-location projects
  • How PJM's compliance filing and stakeholder process can become a template for other RTO/ISO tariff revisions
  • Reducing project execution and financing challenges by translating tariff and interconnection uncertainty into actionable risk allocation, schedule protections, and change-in-law/change-in-tariff strategies for term sheets and agreements