A former board member of PJM Interconnection is calling on federal regulators to accelerate the integration of grid flexibility resources — demand response, virtual power plants, and behind-the-meter batteries — arguing they can be deployed in months rather than the years or decades required for new generation and transmission infrastructure. Jeanine Johnson, co-founder of cybersecurity platform Immutaverse, wrote that the power industry faces a "mismatch of speed" as data centers add gigawatts of demand within two years while infrastructure projects remain stuck in permitting, supply-chain constraints, and capital requirements. The analysis was published ahead of a July 23 Federal Energy Regulatory Commission technical conference on PJM governance.
Johnson points to flexible interconnection agreements as evidence that flexibility is becoming a resource class in its own right. FERC's December order directed PJM to establish non-firm transmission service options for co-located loads, allowing customers to take part of their load as interruptible capacity in exchange for connecting faster. The Southwest Power Pool has introduced conditional large-load service, ERCOT has changed interconnection rules, and Google has reportedly contracted flexible capacity at gigawatt scale across multiple utility territories in exchange for tolerating limited curtailment. But PJM's market monitor has warned that flexibility commitments without binding curtailment authority can amount to a "regulatory fiction," Johnson notes.
According to Johnson, the binding constraint is no longer primarily technological but institutional. She writes that FERC issued Order 2222 in 2020 to open wholesale markets to aggregated distributed resources, yet PJM's stakeholder process took more than five years to bring distributed energy resource aggregation participation to market. "Six years from federal order to market entry is not a technology problem; it is a governance problem," she states. The report proposes three reforms: decision shot clocks for reliability-critical rule changes, realignment of voting incentives so incumbent resources don't control rules governing their potential displacement, and a durable seat for the thirteen states and District of Columbia within PJM's footprint, which currently bear political accountability for reliability and affordability but hold no formal governance role.
Johnson argues the industry's conventional response to load growth — build more infrastructure — overlooks resources already connected to the grid. She cites electric vehicles as an illustration: while EVs add load, vehicle-to-home, vehicle-to-building, and ultimately vehicle-to-grid technologies could let millions of distributed batteries support reliability during peak periods. Though full vehicle-to-grid remains in early development with standards and business models still maturing, utilities are increasingly planning around EVs becoming grid resources. The report draws on governance models from other sectors, including Australia's legislated "national electricity objective" that makes the long-term interests of consumers with respect to price and reliability the standard every market institution must serve, and interstate compacts like the Port Authority of New York and New Jersey, which has managed billions in infrastructure for over a century.
Johnson concludes that the most valuable near-term resources may not be power plants yet to be built, but "the millions of devices, batteries, buildings, and vehicles already connected to the grid, waiting on institutions capable of saying yes at the speed the moment demands." She frames the July 23 FERC conference as a test of whether institutions that govern the grid can adapt as fast as the grid itself. The technology is there, she writes. The clock is ticking.