FERC Charts a New Path for Large Load Co-Location in PJM

At the December 18 Open Meeting of the Federal Energy Regulatory Commission (“FERC”), FERC took action to provide guidance on how large loads and generators may co-locate in the PJM Interconnection, L.L.C. (“PJM”). FERC’s decision in the PJM large load co-location proceeding comes amid a national debate over how best to meet surging electricity demand—spurred in large part by the buildout of artificial intelligence and other digital infrastructure—and how to overcome regulatory roadblocks to building new grid infrastructure. FERC underscored its priority in this debate: “if a new large load wants to connect directly to a power plant and operate in a way that lowers grid costs, we should let it.”[1] The Order charts a new path for the co-location of large loads in PJM and sheds light on FERC’s potential next steps.

Sidley European Private Equity Infrastructure Update

Sidley’s European Private Equity Infrastructure Team has released its 2025 end-of-year update, featuring insights on geothermal energy considerations in the UK, UK real estate diligence, EU digital regulatory updates, employment rights bill updates, and changes to the verification of your identities via Companies House.

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FERC’s First Meeting Under New Leadership: Key Takeaways and Signals for 2026

On November 20, 2025, the U.S. Federal Energy Regulatory Commission (FERC or the Commission) held its first monthly open meeting since the confirmation and swearing-in of Chairman Laura Swett and Commissioner David LaCerte.[1] It marks the first time FERC has had a full five-member commission since the departures of Commissioner Mark Christie and Chairman Willie Phillips earlier this year. FERC’s first meeting under new leadership coincided with an agenda that underscored urgency and a new strategic direction. The summary below outlines the Commission’s discussion and key actions.

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Bringing Data Centers to the Grid: FERC’s Emerging Large Load Framework

On October 23, 2025, Secretary of Energy Chris Wright directed the Federal Energy Regulatory Commission (FERC) to consider an Advance Notice of Proposed Rulemaking (ANOPR) to initiate rulemaking procedures to “ensure the timely and orderly interconnection of large loads to the transmission systems.” Under the ANOPR, “large loads” are defined as those with a capacity of 20 MW or more, aligning with the definition of “large generation sources” in FERC’s Order No. 2003.

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The Trump Administration’s Pushback Against a Global Shipping Carbon Levy

The International Maritime Organization (IMO), the United Nations agency tasked with regulating global shipping, has proposed an international carbon pricing scheme on shipping. The maritime shipping sector has increasingly faced global scrutiny as the contributor of 3% of global greenhouse gas emissions, and IMO’s proposed mechanism would serve as the first global emissions pricing mechanism affecting the shipping sector.

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Governors of PJM States Intensify Pressure on PJM for Reform

A bipartisan group of governors of PJM Interconnection (PJM) member states has intensified calls for reforming PJM after what they have described as a “crisis of confidence,” citing high electricity prices, interconnection delays, and lack of transparency and state participation in the RTO’s decision-making processes.

Council on Environmental Quality Issues Long Awaited Guidance for Environmental Review Across Agencies

On September 29, 2025, the Council on Environmental Quality (CEQ) issued long-awaited guidance to formalize agencies’ individual efforts to implement the National Environmental Policy Act (NEPA).  After rescinding the CEQ regulations that shaped NEPA for 40+ years and bearing witness to various agencies’ independent efforts to issue their own NEPA rules, CEQ issued new guidance to more systematically guide the agencies’ efforts.  As CEQ notes, “NEPA implementation reform now has been called for, authorized, and directed by all three branches of government at the highest possible level: Congress, the President, and the Supreme Court.”  The guidance reflects direction from each.

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EPA, Departments of Interior and Energy Announce New Coal-Friendly Policy Initiatives

On September 29, 2025, the Trump Administration unveiled a sweeping set of policy initiatives aimed at revitalizing the U.S. coal sector that spans multiple federal agencies and includes measures such as increased funding and financial incentives, relief from environmental regulatory requirements, and increased access to public lands. In the unveiling, the Administration emphasized the importance of American “energy dominance” and the increased demand for electricity to power artificial intelligence (AI) in order to ensure that the United States wins “the AI arms race” — two themes commonly highlighted by the Administration and its top officials.

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Resources

 

Meet the Team

<a target=‘_blank’ href="https://www.sidley.com/en/people/v/vrielink-cliff-w">Cliff W. Vrielink</a>

Cliff W. Vrielink

Houston
<a target=‘_blank’ href="https://www.sidley.com/en/people/i/irvin-kenneth-w">Kenneth W. Irvin</a>

Kenneth W. Irvin

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/higgins-tara">Tara Higgins</a>

Tara Higgins

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/hamner-iii-herschel-t">Herschel T. Hamner III</a>

Herschel T. Hamner III

Houston
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/macarthur-james">James MacArthur</a>

James MacArthur

London
<a target=‘_blank’ href="https://www.sidley.com/en/people/a/atkins-raymond-a">Raymond A. Atkins Ph.D.</a>

Raymond A. Atkins Ph.D.

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/lewis-kevin-p">Kevin P. Lewis</a>

Kevin P. Lewis

Houston
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