Given that (1) within the PJM footprint there is a continuous increase in large load applications; (2) Congress, FERC,
state legislators and policymakers are championing establishment of load rates and programs to accelerate load & gen
interconnections while mitigating cost and resource adequacy impacts from these large loads; (3) the PJM Board in its
January 16, 2026 correspondence specifically directed PJM staff to develop a framework in which the incremental
demand associated with such load growth that does not bring its own new generation would be subject to curtailment
prior to the deployment of pre-emergency Demand Response while acknowledging that future developments will be
relevant to the design of longer-term approaches to large load integration; and (4) planning analysis has often identified
significant transmission upgrades required to reliably interconnect large customers on a standard basis that will impact
speed to market for many large loads; there is a critical need to explore customer flexibility solutions that would allow
certain large load customers to connect to the grid prior to completion of necessary transmission upgrades.