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. A rulemaking that stops is also an entry — RM26-4 appears below without a date, because the Commission has not set one.
The next 90 days — September to November 2026#
The densest stretch on the calendar, and it has shifted. The question this table asked in July — whether the RTOs would defend their tariffs or replace them — was answered in August by six abeyance motions and six replacement designs. What the autumn now decides is which of those designs the Commission will accept, and on what terms. The table ends on November 16 because that is the day the six replacement tariffs arrive. The table ends on November 16 because that is the day the six replacement tariffs arrive.
| Date | Event | What it decides | Tag |
|---|---|---|---|
| Sep 2, 2026 | CAISO large-load straw-proposal comments due | First stakeholder test of the two flexible interconnection services (§2, §6) | ESTABLISHED |
| Sep 3, 2026 | Comments due on PJM's Interim Resource Adequacy Service and Large Load Registry (ER26-3515) | Whether curtailment ahead of pre-emergency load management, and exclusion from procured capacity, survive contest (§2, §3, §6) | ESTABLISHED |
| Sep 8, 2026 | Comments due on PJM's co-location compliance filing (ER26-1479-002) | The operative co-location tariff language, as opposed to the order that directed it (§5) | ESTABLISHED |
| Sep 15–16, 2026 | NERC Data Center Load Modeling Workshop | Sets the modeling conventions the year-end standard will codify (§4, T.4) | ESTABLISHED |
| Sep 21 / 28, 2026 | CAISO draft final proposal and second workshop | Whether the interim and permanent flexible services survive to the Board (§2) | LIKELY |
| End Sep 2026 | MISO large-load parallel study process filing (loads ≥250 MW) | Whether the out-of-queue study route becomes tariff rather than practice (§1, §2) | EMERGING |
| Sep 29, 2026 | Commission action requested on PJM's Reliability Backstop Procurement (ER26-3380) | Whether backstop capacity can be procured outside the auction, and at whose cost (§2, §3) | EMERGING |
| Sep 30 – Oct 21, 2026 | PJM backstop procurement window, if the filing is accepted | Price and allocation of 6,831.3 MW of backstop capacity (§2, §3) | EMERGING |
| Sep 2026 | PUCT decision on the Bell County East – Big Hill 765 kV certificate (Docket 59475) | Whether the landowner-notice objection that the Commission overrode on August 28 changes the outcome on a segment where it is squarely raised (§2, §9) | EMERGING |
| Q4 2026 | First NERC large-load Reliability Standard (Project 2026-02 “bridge” standard) | Converts voluntary guidance into enforceable obligation (§4) | LIKELY |
| Oct 12 / 17, 2026 | Requested effective dates: PJM interim resource adequacy service; PJM co-location compliance | When the two PJM regimes begin to bind, if accepted (§2, §5) | EMERGING |
| Oct 28, 2026 | CAISO Board of Governors vote on the large-load package | Whether the abeyance route produces a §205 proposal rather than a defence of the tariff (§7) | LIKELY |
| Nov 14, 2026 | DOE 202(c) must-run designation for J.H. Campbell expires | Whether the rolling ninety-day emergency designations renew, and how long emergency authority substitutes for planning (§7) | EMERGING |
| **Nov 16, 2026** | **§206 show-cause responses due from all six regions** (Nov 20 in SPP); SPP price-adaptive load service filing | The replacement tariffs themselves, six regions on one day — the filings this report has been anticipating since June (§2, §5, §6, §7) | ESTABLISHED |
| Nov 2026 | FERC RM26-4 — Unified Agenda carries “next action undetermined” | Whether a generic national large-load interconnection rule follows the six §206 dockets, or the dockets are the rule (§1, §7) | SPECULATIVE |
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.
December 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 |
|---|---|---|---|
| Late 2026 | Aurora demonstration targets ~100 MW of power-flexible AI load | Whether second-to-minute flexibility survives three orders of magnitude of scale (§1, §6) | EMERGING |
| Dec 10, 2026 | ERCOT verification filing on the Batch Zero audit | How much of the ERCOT queue survives verification, and whether the April 2027 study deadline holds (§1) | EMERGING |
| Dec 16 / 21, 2026 | Answers and comments in the six §206 dockets | Last broad intervention window before the Commission acts (§7) | ESTABLISHED |
| End 2026 | DCFlex final reference design and incentive-programme designs | Whether the flexibility classes arrive with a compensation structure attached, or only a vocabulary (§3, §6) | EMERGING |
| **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) | ESTABLISHED |
| **Dec 31, 2026** | **PUCT Project 58484** — transmission cost-recovery rule amendments due | Whether minimum demand charges and a share of system upgrade costs attach to large loads in ERCOT by rule rather than case by case (§3) | ESTABLISHED |
| Dec 2026 | PUCT duplicate-request disclosure rule final (16 TAC §25.194) | Determines the honest size of the ERCOT queue (§1) | LIKELY |
| 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) | ESTABLISHED |
| Mar 2027 | PJM reliability backstop — central pay-as-bid procurement | Price and cost allocation of backstop capacity billed to large loads (§2, §3) | LIKELY |
| Mar 2027 | NYISO §205 filing on large loads | Whether mandatory study procedures and the end of behind-the-meter netting reach tariff language (§2, §5) | EMERGING |
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.
Q2 2027 through 2029 — 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, the first 765 kV segments are certificated for 2028 and 2029, and the remedial standards are still being drafted. The horizon now runs to the 2029/30 auction, the first delivery year in which PJM stops procuring capacity for load that brings none.
| Date | Event | What it decides | Tag |
|---|---|---|---|
| 2027–2028 | ERCOT 765 kV backbone construction, on the certificates issued from August 2026 | The long-lead wires: first segments targeted 2028–2029, the rest into the 2030s (§9) | SPECULATIVE |
| 2027 | NERC Phase II computational-load standards drafted; CLE registration begins | Whether the registration threshold (20 MW at 60 kV) and the draft standard threshold (50 MW at 100 kV) converge, or entities register that no standard reaches (§4, §8) | EMERGING |
| 2027 | Co-location and flexible-service terms take effect on the tariffs filed in 2026 | Whether non-firm service is priced attractively enough to be chosen, now that five regions have filed a version of it (§5, §6) | LIKELY |
| Apr 9, 2027 | ERCOT Batch Zero study deadline — ERCOT has said it is at risk | Whether the batch screen delivers a studied queue at all, or a further extension (§1) | SPECULATIVE |
| Jun 1, 2027 | PJM interim resource adequacy service begins to bind on new large loads | First date on which unsupported new load faces curtailment ahead of other customers (§2, §6) | EMERGING |
| Mid-2027 | PJM Base Residual Auction for 2029/30 — the first with unsupported new large load outside the VRR curve | Whether excluding unsupported load from procurement relieves the shortfall or relocates it (§2, §3) | EMERGING |
| Jul 2027 | New York moratorium lapses; GEIS and Energize NY framework due | A framework other states may adopt, modify, or decline; EO 62 exempts applications complete before July 14, 2026 and does not reach projects needing only local permits (§7) | LIKELY |
| 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) | ESTABLISHED |
| 2029/30 auction | Unsupported new large load excluded from PJM's procurement calculation | The end point of bring-your-own-capacity: the market stops buying for load that brings none (§2, §3) | EMERGING |
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.