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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
Mr. Fowler provides comprehensive regulatory services to energy sector clients, advising them on regulatory matters and, when necessary, representing clients before regulatory bodies including the NRC, FERC, OMB, EPA and OSHA. He frequently provides due diligence for investments into energy technology developers, ensuring that regulatory aspects are thoroughly evaluated and addressed. Mr. Fowler also partners with clients in developing targeted strategies for engagement on emerging issues, with a holistic view of legislative, agency and political issues, to address and mitigate potential regulatory impacts.
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.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
Date + Time
- event
Thursday, March 12, 2026
- schedule
1:00 p.m. ET./10:00 a.m. 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
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