EPSA raises concerns that PJM’s proposed IRAS framework would unduly discriminate between new and existing capacity resources, distort capacity market signals, and undermine reliability and competition.
Date: September 3, 2026 | Venue: Federal Energy Regulatory Commission | Docket: ER26-3515-000
On September 3, 2026, the Electric Power Supply Association filed a protest at FERC in response to PJM’s proposal to establish an Interim Resource Adequacy Service (IRAS) and Large Load Registry to address resource adequacy concerns and growing large load demand in the region. While EPSA supports efforts to address PJM’s capacity shortfall and reliability challenges and does not oppose the proposed Large Load Registry, the protest explains that the IRAS proposal would undermine reliability and competition by creating unduly discriminatory and preferential treatment between new and existing capacity resources.
EPSA raises particular concerns with PJM’s proposed “Bring Your Own New Capacity” (BYONC) requirement, which would require New Large Loads to contract with new capacity to avoid IRAS and potential curtailment, effectively preventing existing capacity resources from competing to serve New Large Loads. EPSA explains that the proposal would distort capacity market price signals, disadvantage existing resources, increase costs to consumers over time, and undermine investor confidence in PJM’s market design. As an alternative, EPSA identifies an approach that would require capacity-deficient load-serving entities to designate load, or contracted demand response, for curtailment during load-shed events, incenting sufficient capacity procurement while preserving the integrity of PJM’s Reliability Pricing Model and avoiding discrimination against existing resources.
