The curtailment hierarchy and cost-allocation rules for large loads are the tariff's business consequence — the mechanism that determines who absorbs the bill when PJM's grid cannot serve every connected facility simultaneously [1]. Data centers sit at the top of the hierarchy, meaning they face curtailment first during supply crunches.

The filing establishes a two-tier structure: a one-time reliability backstop auction for capacity procurement, and a "connect and manage" operational registry that assigns load-reduction priorities [1]. The board letter's assertion that "state action is essential" frames the cost question as a political problem, not just a market one. It signals that PJM expects state regulators to play a role in determining how costs are distributed.

For data-center operators, the tariff's terms translate into concrete financial exposure. PJM's monitoring analytics has attributed $21.3 billion of the last three auctions' $47.2 billion total to forecast data center load [2]. The new regime asks those facilities to bear the cost of the capacity they require, rather than spreading it across all ratepayers.

Maryland's Office of People's Counsel has already challenged roughly $2 billion in data-center-driven transmission cost allocation to Maryland ratepayers, and Pennsylvania's governor filed a FERC complaint tying record PJM prices to data center load growth [2]. The tariff enters that fight with a concrete framework.

The curtailment hierarchy itself is the sharpest instrument. Under stressed conditions, large loads without behind-the-meter generation face the deepest cuts before residential and commercial customers are affected. For data centers that depend on grid power for cooling and critical operations, the hierarchy translates into reliability risk during peak demand periods.

-- THEO KAPLAN, San Francisco