A common approach to reliable load-following is to "slave" fuel cell response to the reactants supply subsystem (e.g. fuel processor). A change-in-power demand may be time-sensitive, however, and slaving the fuel cell response to that of the slower balance-of-plant components may not be practical. A model has been constructed to simulate the unrestrained load-following characteristics of a commercial-grade fuel cell. Analyses have shown that initial conditions exist which facilitate timely responses to increases in load demand, among them lower fuel utilization, larger operating voltage and optimized cell potential reduction.