Orientation
Upcoming Dates and Events: A 12–18 Month Watchlist#
Everything in this report eventually resolves into a calendar. This section is that calendar — the decisions, filings, and market events that will determine which of the eight problems get answered and which remain open a year and a half from now. It sits before Section 1 by design: a reader who takes nothing else from the report should still know what arrives and when.
Two cautions on reading it. First, the entries mix categories on purpose — compliance deadlines, market outcomes, rulemaking milestones, and the years NERC flags as the onset of elevated reliability risk — because developers and planners navigate that mixture as a single decision environment. Second, the confidence tag distinguishes a date someone must legally meet from a date someone currently intends to meet. Items tagged Emerging in particular signal direction of travel rather than schedule: rulemakings slip, standards get remanded, and a single court decision on the co-location or jurisdiction questions could reorder much of the 2027 column.
The next 90 days — July to September 2026#
The densest stretch on the calendar. Four filings inside a month will show, for the first time, whether the RTOs intend to defend their tariffs or replace them.
| Date | Event | What it decides | Tag |
|---|---|---|---|
| Jul 20, 2026 | RTO/ISO resource-adequacy informational reports due to FERC — deadline passed | First formal statement from each RTO on whether it can actually serve its queue (§2) | SETTLED |
| Jul 24, 2026 | ERCOT TSP/DSP submissions due — Batch Zero eligibility | Fixes the Batch Zero population and the base-load MW allocation (§1, §5) | SETTLED |
| Aug 3, 2026 | NERC Level 3 Essential Action Alert responses due | Reveals the true extent of ride-through non-compliance across the fleet (§4) | SETTLED |
| Aug 3, 2026 | §206 abeyance requests due (45 days) | Whether the common August 17 deadline holds across all six regions (§7) | LIKELY |
| **Aug 17, 2026** | **RTO/ISO §206 show-cause responses and briefs due (60 days)** | One of the year's most consequential filings: defend the existing tariff or propose the replacement (§5, §6, §7) | SETTLED |
| Sep 10 – Oct 9, 2026 | PJM reliability backstop procurement window (per the June 30 design paper) | Whether backstop capacity can be procured outside the auction, and at whose cost (§2, §3) | LIKELY |
| Sep 15–16, 2026 | NERC Data Center Load Modeling Workshop | Sets the modeling conventions the year-end standard will codify (§4, T.4) | SETTLED |
| Sep 16, 2026 | Stakeholder comments on RTO show-cause filings due | Last broad intervention window before FERC acts (§7) | SETTLED |
| Oct 20 / 28, 2026 | CAISO WEM Governing Body and Board of Governors votes on the large-load package | Whether the abeyance route produces a §205 proposal rather than a defence of the tariff (§7) | LIKELY |
Table W1 — The next ninety days. Dates already fixed by an order, a rule, or a filing deadline. Confidence tags refer to the outcome, not the date: the calendar is settled even where what it produces is not.
Sources: FERC; NERC; ERCOT; PUCT; PJM; MISO; SPP; DOE, from the filings and dockets listed in the Catalog of Orders, Rules, and Directives Cited.
Q4 2026 through Q1 2027 — obligations begin to bind#
Here voluntary guidance becomes enforceable. The December 31 date may prove the most consequential entry on the list, because reliability obligations then attach to the load itself rather than to the utilities around it.
| Date | Event | What it decides | Tag |
|---|---|---|---|
| Mid-Nov 2026 | CAISO filing on the show-cause order; §205 filings from any other region granted an abeyance | Whether the regions that take the pause file tariff proposals rather than defend the existing tariff (§7) | EMERGING |
| Q4 2026 | First NERC large-load Reliability Standard (Project 2026-02 “bridge” standard) | Converts voluntary guidance into enforceable obligation (§4) | LIKELY |
| Dec 2026 | PUCT duplicate-request disclosure rule final (16 TAC §25.194) | Determines the honest size of the ERCOT queue (§1) | LIKELY |
| **Dec 31, 2026** | **RD26-7-000 compliance:** NERC files Reliability Standards **and** Rules-of-Procedure registration criteria for computational loads | A central reliability reform lands on a date certain; the registry threshold remains the open question (§4, §8) | SETTLED |
| Dec 2026 – Jan 2027 | NERC Long-Term Reliability Assessment (annual) | Whether the ten-year peak forecast is revised upward again (§1, §9) | LIKELY |
| **Mar 1, 2027** | **RD26-7-000:** NERC Phase II work plan for additional standards due | Sets the trajectory for standards beyond the bridge rule (§4) | SETTLED |
| Mar 2027 | PJM reliability backstop — central pay-as-bid procurement | Price and cost allocation of backstop capacity billed to large loads (§2, §3) | LIKELY |
Table W2 — Late 2026 into 2027, where guidance becomes obligation. These are the dates at which the reforms described throughout the report stop being proposals and start carrying compliance consequences.
Sources: FERC; NERC; ERCOT; PUCT; PJM; MISO; SPP; NYISO; state commissions.
Through 2027 and into 2028 — the rules mature, the risk window opens#
The later entries grow increasingly uncertain because they depend on future rulemakings, and they also make the report's central timing inversion visible: the reliability-risk windows open in 2028 while the remedial standards are still being drafted and the major transmission is still years from energization.
| Date | Event | What it decides | Tag |
|---|---|---|---|
| Across 2027 | FERC RM26-4 matures from ANOPR to NOPR and then final rule | Whether a pro forma national large-load interconnection procedure exists at all (§1, §7) | SPECULATIVE |
| 2027 | NERC Phase II computational-load standards drafted; registry populated | Scope thresholds decide which facilities are actually bound (§4, §8) | SPECULATIVE |
| 2027 | Co-location and flexible-load service terms take effect after the rulemaking | Whether non-firm service is priced attractively enough to be chosen (§5, §6) | SPECULATIVE |
| Mid-2027 | PJM Base Residual Auction for the 2029/30 delivery year | A third consecutive shortfall would confirm scarcity is structural, not cyclical (§2, §3) | LIKELY |
| Jul 2027 | New York moratorium lapses; GEIS and Energize NY framework due | A framework other states may adopt, modify, or decline (§7) | LIKELY |
| 2027–2028 | ERCOT 765 kV backbone and Permian Basin plan construction milestones | The long-lead wires that do not actually arrive until the 2030s (§9) | SPECULATIVE |
| 2028 | MISO enters the NERC elevated/high reliability-risk window | Opening of the gap where risk bites before the fixes are enforceable (§9) | SPECULATIVE |
| Jun 1, 2028 | PJM 2028/29 delivery year begins — the year procured ~6.8 GW short | First delivery year in PJM history to start below the reliability requirement (§2) | SETTLED |
Table W3 — 2027 and beyond. Tagged Speculative where the entry depends on a rulemaking that has not yet been proposed, or on a market outcome three years out. The dates are indicative; the direction is not.
Sources: NERC Long-Term Reliability Assessment; ERCOT; PJM; MISO; FERC.
The near-term entries in this table are the operational watch list; Section 9 carries the full 2018–2035 view, including the long-lead physical builds beyond this horizon.