Case intelligence reportCASE-08-02

PJM co-location and Susquehanna/AWS contractual cluster

PJM implementation remains open and the revised Talen–AWS arrangement is C10.

Executive summary

Read the conclusion before the archive.

  1. PJM implementation remains open and the revised Talen–AWS arrangement is C10.
  2. The verified path stops at C10; the next transition remains bounded by the public record.
  3. No claim of 1,920 MW delivered, energized or economically utilized.

01 · Case brief

Why this mechanism belongs in the portfolio.

Federal/RTO co-location rules plus named contractual adaptation. The cluster is retained for its evidentiary function, not as a representative sample or ranking.

01

Observed mechanism

PJM implementation remains open and the revised Talen–AWS arrangement is C10.

02

Unverified transition

Firm/deliverable service; energization; commissioning; operating load; utilization; C20

03

Quantitative basis

Up to 1,920 MW contractual maximum; not load

Figures remain attached to their stated unit and state basis.

Decision boundary

The evidence ceiling

Permitted conclusion

Revised front-of-meter PPA exists and PJM rules remain in implementation.

Prohibited stronger claim

No claim of 1,920 MW delivered, energized or economically utilized.

Quantitative ceiling
Contractual maximum only
Causal ceiling
No delay or outcome attribution

02 · Institutional control

The outcome depends on a distributed permission stack.

No actor, filing or contract is allowed to stand in for the entire conversion chain.

01

FERC order

02

PJM compliance

03

generation/customer contract

04

transmission service

Controlling actors

Institutions with decision rights

  • FERC
  • PJM
  • Talen
  • AWS

Controlling instruments

Documents and mechanisms

  • FERC orders/compliance
  • PPA disclosure

03 · Event sequence

The verified path and the point where proof stops.

The sequence records documentary transitions. It does not imply a standard duration, inevitability or linear progression.

  1. 01

    Co-location proposal/order

  2. 02

    PJM compliance

  3. 03

    partial FERC acceptance/further compliance

  4. 04

    revised PPA

  5. —
    Blocked or unverified next transition

    Firm/deliverable service; energization; commissioning; operating load; utilization; C20

04 · Rival tests

Alternative explanations that materially narrow the claim.

A rival “win” does not reverse the record. It defines the strongest inference that survives the contrary evidence.

01

RW-0002 · MATERIAL WIN

Policy/implementation uncertainty

Tested against
Assumption that PJM compliance completed co-location pathway
Evidence result
Partial acceptance and further compliance remain
Ceiling effect
C10 maximum
Prohibited inference
No deliverable service or operating campus inference
02

RW-0003 · MATERIAL WIN

Contract ≠ physical delivery

Tested against
Assumption that 1,920 MW PPA equals delivered load
Evidence result
Filing states contractual maximum and transition, not delivery
Ceiling effect
C10 maximum
Prohibited inference
No 1,920 MW energized/average/IT load

Documented adaptation

The mechanism changed; the outcome remains bounded.

ADAPT-0001 · Contractual restructuring

Revised front-of-the-meter PPA up to 1,920 MW through 2042

Trigger or constraint
Co-location/regulatory pathway change
Evidence / implementation
C10 contractual disclosure · TRANSITIONED APRIL 2026
Observed outcome
Contract state observed; physical delivery not observed
Claim ceiling
Contract adaptation only

05 · Claim register and evidence file

Load-bearing claims and the record that resists them.

20 linked claims, 4 primary source references and explicit contrary or negative evidence are retained under stable IDs.

CLM-0014 · legal status

FERC’s co-location record spans distinct procedural stages and dockets, including AD24-11, ER24-2172, EL25-49, and PJM compliance in ER26-1088.

Claim ceiling
Proceeding map; no assumption that filed terms are effective or that a site is operating.
Evidence
Tier A · HIGH
Locator
Named dockets and accession 20260223-5181

CLM-0021 · legal status

PJM co-location compliance remains an implementation and tariff-status question after the December 2025 FERC order; the filing itself is not the final effective rule.

Claim ceiling
Pending compliance status only.
Evidence
Tier A · HIGH
Locator
EL25-49 order summary; ER26-1088 accession
Linked sources
SRC-0010SRC-0011

CLM-0053 · interpretation

No single U.S. “grid interconnection” state applies to all large loads: retail load service/interconnection, transmission service, generator interconnection, co-location, and behind-the-meter arrangements use different actors, instruments, studies, and jurisdictional pathways.

Claim ceiling
Pathway distinction only; no single source establishes a nationally uniform process.
Evidence
Tier A-minus · HIGH
Locator
FERC RM26-4 overview; FERC PJM order summary; MISO current-rules page; CAISO issue paper pp. 3-8; PJM pathway presentations

CLM-0055 · legal status

FERC’s December 2025 PJM co-location order required transmission-service pathways for eligible customers serving co-located load, including interim non-firm service while upgrades needed for requested network service are incomplete.

Claim ceiling
Establishes a Commission directive, not a project-specific service award, deliverable MW, or energization.
Evidence
Tier A · HIGH
Locator
Fact sheet and order summary for 193 FERC ¶ 61,217
Linked sources
SRC-0010

CLM-0056 · legal status

On April 16, 2026, FERC accepted in part and rejected in part PJM’s ER26-1088 compliance filing and directed a further compliance filing within 30 days, superseding the prior “pending review” status.

Claim ceiling
Current procedural status only; tariff details and subsequent compliance remain subject to further action.
Evidence
Tier A · HIGH
Locator
April 2026 Commission Meeting Summary, Item E-1
Linked sources
SRC-0083

CLM-0057 · interpretation

A FERC or RTO service framework, compliance order, study pathway, or queue entry does not establish that any named project has approved load, contracted power, deliverable power, completed upgrades, energization, or operating compute.

Claim ceiling
Applies only as an evidence ceiling; project states require project-specific records.
Evidence
Tier A-minus · HIGH
Locator
Procedural records and aggregate process pages
Show 14 additional linked claim IDs

CLM-0074CLM-0076CLM-0155CLM-0173CLM-0174CLM-0179CLM-0187CLM-0188CLM-0191CLM-0192CLM-0193CLM-0206CLM-0207CLM-0208

Contrary evidence and competing mechanisms

CTR-0017 · Policy and data uncertainty

A single national “interconnection queue” model does not describe current large-load pathways.

Evidence result:CAISO, MISO, ERCOT, PJM, SPP, NYISO and ISO-NE assign different roles to utilities, RTO/ISOs, transmission service, forecasting and generator interconnection.

Ceiling effect:Prohibits uniform national process claims.

CTR-0019 · Flexible-load response

Non-firm or curtailable service may permit limited/interim service before all firm-service upgrades are complete.

Evidence result:FERC’s PJM directive and regional proposals recognize service designs tied to limited withdrawals or curtailment.

Ceiling effect:Mitigation mechanism only; does not establish firm reliability or universal feasibility.

CTR-0020 · Supply response

Regional processes can study large loads together with associated new generation rather than treating supply as fixed.

Evidence result:SPP’s effective HILL/HILLGA framework studies load and associated generation; other regions are evaluating co-location and bring-your-own-generation.

Ceiling effect:Shows an adaptation pathway, not timely generation completion or physical delivery.

CTR-0047 · Capex realization gap

Large capex does not establish completed, ready-for-use or utilized infrastructure.

Evidence result:Alphabet explicitly separates assets not yet in service and multi-year construction; Meta and Amazon combine multiple asset/business categories.

Ceiling effect:Capex supports financial exposure only.

CTR-0049 · Metric-boundary mismatch

Active power and cabinet utilization do not measure average consumption, MW-IT, accelerator utilization or economic output.

Evidence result:CoreWeave and Equinix use different portfolio metrics and exclusions.

Ceiling effect:No cross-company utilization ranking.

CTR-0051 · Contract performance risk

A long-term PPA does not prove delivered energy, customer load or revenue realization.

Evidence result:Talen filing establishes contractual maximum and transition date, not delivery profile or campus operation.

Ceiling effect:C10 contractual ceiling.

Public-record gaps

NEG-0005

Question checked:Are all customer-specific obligations in large-load contracts public?

No; redactions and framework-only public records remain.

Implication:Framework-level claim ceiling; REDACTION GAP.

NEG-0020

Question checked:Was a controlling public disposition of SPP ER26-1323 CHILL located?

UNKNOWN — PUBLIC EVIDENCE NOT LOCATED. Filing located; controlling disposition not established by cutoff.

Implication:Keep CHILL at proposed/pending verification.

NEG-0022

Question checked:Can ERCOT aggregate large-load interest be reconciled to project-level approved, deliverable and energized MW?

SOURCE GAP. Aggregate interest/process evidence does not provide a complete public project-level C7–C17 crosswalk.

Implication:No project realization ratio or operating total from aggregate request figures.

NEG-0024

Question checked:Do ISO-NE forecast records identify construction or operating status for the included large loads?

The forecast states neither included project was under construction; no energization or operating evidence was located.

Implication:Raw 285 MW remains formal-study nameplate, subject to derating, not project capacity.

NEG-0025

Question checked:Did Pass 03 locate project-specific evidence upgrading bounded projects to C14–C20?

NO. Process, queue, forecast and reliability records do not establish those transitions for a named bounded project.

Implication:Project states from Pass 02 remain unchanged except PS-0009 process status clarification.

Show the complete linked control-ID index
Contrary evidence
CTR-0017CTR-0019CTR-0020CTR-0047CTR-0049CTR-0051CTR-0056CTR-0058CTR-0059CTR-0061CTR-0062CTR-0065
Negative findings
NEG-0005NEG-0020NEG-0022NEG-0024NEG-0025
Reopen controls
OIR-0002OIR-0009OIR-0019OIR-0020OIR-0022OIR-0023OIR-0046OIR-0047OIR-0049OIR-0051OIR-0056

06 · Record maintenance

What would justify reopening this report.

Updates require a documented evidence delta. Passage of time, repetition of an announcement or a portfolio-level disclosure is not enough.

What could change this record

  • OIR-0002 · FERC or PJM files or acts on further ER26-1088 compliance, rehearing, EL25-49 implementation, or related co-location matters.

    Required update: Inspect further compliance and FERC disposition; update tariff options/effective status without inferring project outcomes.

  • OIR-0009 · A public field demonstration or binding service agreement provides measured AI/computational-load flexibility evidence.

    Required update: Capture workload, baseline, response speed/duration, customer constraints, sample, and transferability limits.

  • OIR-0019 · Any bounded project receives a material cancellation, downsizing, land/permit decision, construction milestone, service agreement, energization, commissioning, phase redefinition, or portfolio-capacity reconciliation.

    Required update: Create dated state observation; preserve prior state; record supersession/overlap; update affected capacity fields without borrowing later-state language.

  • OIR-0020 · Public evidence provides measured operating load, commissioned IT capacity, customer-use, utilization, revenue/economic incidence, or independent verification for a C17 project.

    Required update: Verify unit, period, site boundary and source function; upgrade only the supported state; preserve contrary evidence and C18–C20 distinctions.

  • OIR-0022 · An RTO/ISO, transmission owner, state regulator, or FERC adopts, modifies, stays, or withdraws a large-load interconnection, co-location, transmission-service, or technical-requirement framework.

    Required update: Record legal instrument, procedural/effective status, exact locator, supersession and limits; do not borrow project states.

  • OIR-0023 · A public, project-level large-load dataset or executed agreement resolves request, study, upgrade, contract, deliverability, energization, or commissioning states for an aggregate regional cohort.

    Required update: Create dated project state observations, preserve units and confidentiality, and upgrade only directly supported transitions.

  • OIR-0046 · A later periodic filing materially changes company capex, backlog, financing, power, project timing or utilization disclosures used in Pass 07.

    Required update: Inspect new 10-Q/10-K and record only material evidence deltas; do not refresh unchanged metrics each pass.

  • OIR-0047 · Standardized AI-specific capex, named-site energy cost or comparable operating-load disclosure becomes public.

    Required update: Record definitions, reporting boundary and period; revise only matched company metrics.

Record navigation

These records share claims or sources with this report. The linkage supports navigation, not a causal inference.

Sources — bibliography and exact locators

  1. SRC-0010 — FERC Directs PJM to Create New Rules for Co-Located Large Loads

    Federal Energy Regulatory Commission · 2025-12-18 · Tier A-minus

    Locator: Docket EL25-49-000; official order summary

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  2. SRC-0011 — PJM Compliance Filing in Response to Co-Location Order

    PJM Interconnection / FERC eLibrary · 2026-02-23 · Tier A

    Locator: Accession 20260223-5181; Docket ER26-1088-000

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  3. SRC-0083 — Summaries — April 2026 Commission Meeting, Item E-1 ER26-1088-000

    Federal Energy Regulatory Commission · 2026-04-16 · Tier A

    Locator: Item E-1, ER26-1088-000; order on compliance and directing further compliance

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  4. SRC-0161 — Talen Energy Corporation — Quarterly Report on Form 10-Q for quarter ended March 31, 2026

    Talen Energy Corporation · 2026-05-05 · Tier A

    Locator: Glossary lines 2053–2056; revised AWS PPA up to 1,920 MW through 2042; transition in April 2026

    PUBLIC COMPANY/SEC RECORD — CITE/SUMMARIZE