Energy Decision # 27 - Behind the Meter Versus Front of Meter: The Billion Dollar Question

Co-location of load with generation — specifically the choice between behind-the-meter and front-of-meter configuration — is now one of the highest-stakes interconnection decisions facing large C&I operators, data center developers, and industrial load owners in PJM and beyond.This is Energy Decision #27 in the complete C&I energy management series from Tactical Energy Group. 100 decisions. Every one that matters.In this episode, Daniel Burke covers:What co-location actually means under FERC's December 2025 PJM Co-Location Order — and why it is not the same as a behind-the-meter arrangement. Why behind-the-meter generation worked for three decades and why it no longer works at data center scale. The Talen-Amazon Susquehanna nuclear case: a 1,920 MW BTM deal rejected by FERC and restructured into a front-of-meter PPA. The four approved PJM interconnection mechanics: sub-full-capacity service, queue acceleration, Provisional Interconnection Service, and Surplus Interconnection Service. Which host generator profiles benefit most from Surplus Interconnection Service — retiring coal plants, nuclear assets near concentrated load, and storage-paired generators. What FERC's order actually directs on tariff service: why co-located loads that can limit energy withdrawals should not be required to take full NITS, and what that means for your project. Reliability enforcement provisions under discussion in PJM's compliance process and why compound outage risk modeling matters before you commit. Ancillary service cost obligations: why FERC's cost-causation ruling means co-located loads pay for regulation and black start services even when net energy withdrawal is minimal. And where BTM still works: C&I industrial parks, manufacturing, and smaller facilities operating below FERC's emerging thresholds.Who this is for: data center developers, industrial park operators, large manufacturers with onsite generation, and any C&I executive evaluating whether to configure load behind a generator's meter or interconnect front-of-meter for grid backup.If you're trying to figure out whether your large load should go behind the meter to avoid transmission charges or connect front-of-meter for regulatory certainty and reliability backing, this episode is built for you.Read the full breakdown on co-location of load with generation at tac-nrg.comIf you're an Indiana C&I operator actively evaluating this decision, get your free Energy Decision Blueprint at blueprint.tac-nrg.com.Visit tac-nrg.com for more practical tools and the Energy Decision Blueprint for qualified Indiana C&I operators.0:00 – What is co-location of load with generation?1:00 – Why BTM and co-location are not the same thing2:30 – Why behind-the-meter stopped working at data center scale4:00 – The Talen-Amazon case: a BTM deal forced front-of-meter5:00 – The four approved PJM interconnection mechanics6:30 – Tariff service and why co-located loads don't have to take full NITS7:30 – Reliability enforcement provisions and compound outage risk