The Quiet Rewrite

DOE Secretary Wright invoked Section 403 of the DOE Organization Act on October 23, 2025, directing FERC to initiate rulemaking on standardized large-load interconnection; accompanied by 14 principles including joint co-located generation+load interconnection requests.

FERC opened corresponding rulemaking docket RM26-4-000 on October 28, 2025.

FERC committed to act on the Section 403 proposal by end of June 2026.

FERC December 18, 2025 order in Docket EL25-49-000 found PJM’s tariff “unjust and unreasonable” and ordered PJM to implement transparent rules for large loads co-located with generation resources.

DOE issued 202(c) emergency orders during Winter Storm Fern (Jan 24–26, 2026) directing PJM, Duke Energy, and ERCOT to keep diesel generators ready and dispatchable.

NERC Standards Committee accepted SAR for new Reliability Standard targeting computational load on March 18, 2026 (Project 2026-02 — Computational Load Alignment Phase 1).

NERC RSTC approved Large Loads Working Group whitepaper #2, “Assessment of Gaps in Existing Practices, Requirements, and Reliability Standards for Emerging Large Loads,” on March 12, 2026.

NERC Reliability Standard FAC-002-4 (Facility Interconnection Studies) in force as the foundational standard for interconnection studies.

NOGRR 282 + NPRR 1308 filed November 14, 2025. Creates Large Electronic Load (LEL) class — ≥75 MW where ≥50% of demand is power-electronic.

Full voltage ride-through curve, §2.14 Table A: continuous 0.9–1.1 pu; 2.0 s at 0.8–0.9 pu; 0.5 s at 0.5–0.8 pu; 0.25 s at 0.2–0.5 pu; 0.15 s below 0.2 pu. Per-unit measured at the Service Delivery Point (138 kV / 345 kV).

Strict ride-through band effective January 1, 2028. Interim band before that date allows proportional reduction; strict band requires continued active power consumption.

ERCOT contracted McKinsey to support improvement of the Large Load Interconnection process; deliverables expected to feed next round of NOGRR filings.

PJM Board Critical Issue Fast Path (CIFP) decision on large-load interconnection, finalized January 16, 2026.

Expedited Interconnection Track operational by August 2026. Connect-and-Manage framework subordinates large-load growth to curtailment ahead of pre-emergency Demand Response.

Verbatim from PJM Board letter: “the incremental demand associated with such load growth would be subject to curtailment prior to the deployment of pre-emergency Demand Response.”

Large Load Considerations Issue Paper published January 30, 2026; information session February 5, 2026.

CAISO does not study load interconnections — those are retail-tariff functions under the connecting utility (PG&E, SCE, SDG&E). CAISO is developing parallel technical requirements (ride-through, ramp, telemetry, dynamic modeling).

4.5 GW of data center demand under study in 2025–2026 transmission planning cycle. CEC forecast: +1.8 GW by 2030, +4.9 GW by 2040.

High Impact Large Load (HILL) Integration unanimously approved by FERC on January 14, 2026 (effective January 15, 2026).

CHILLS revisions refiled February 10, 2026, Docket ER26-1323-000; target effective date July 1, 2026. Maximum 7-year bridge term, non-firm service, lower priority than firm NITS.

Price Adaptive Load (PAL), Schedule 16: non-firm service indexed to LMP. Customers pay LMP for withdrawals; receive no compensation when curtailing.

Large Load framework triggers September 1, 2026. Defines Large Load as >50 MW total capacity at a single site, or +25 MW expansion of an existing >50 MW load.

Five reliability requirement categories: performance & ride-through behavior; flexibility limits; operational readiness (telemetry & metering); system stability impacts; security & resilience.

48 large-load proposals totaling ~12 GW in queue as of December 31, 2025 (up from 6 projects in 2022). Current interconnection studies trigger at ≥10 MW at ≥115 kV or ≥80 MW <115 kV.

Reform timeline: Feb–May 2026 concepts; June–July 2026 straw proposal; August 2026 detailed proposal; December 2026 Board approval and FERC filing.

New York PSC opened Case 26-E-0045 (“Energize NY Development”) on February 12, 2026, modernizing interconnection policy for load-intensive facilities under the Climate Leadership and Community Protection Act (CLCPA).

Next cluster interconnection request window: October 5 – November 19, 2026.

Senate Bill 6 signed by Governor Abbott on June 20, 2025. Mandates remote-disconnect equipment and curtailment participation for new ≥75 MW loads after December 31, 2025.

PURA § 37.0561 narrows ERCOT’s operational authority over co-located generation+load arrangements (≥50% serve-from-self threshold, non-exporting).

PURA § 39.169 governs net-metering arrangements between large loads and co-located standalone generators.

PUCT Project 58481 (Large-Load Interconnection Standards) — proposed 16 TAC § 25.194. PUCT staff voted to publish March 12, 2026; comment deadline April 17, 2026.

PUCT Projects 58479 (net-metering / co-location), 58480 (large-load forecasting, ≥10 MW threshold), 58482 (reliability + voluntary demand reduction), 58484 (transmission cost allocation / 4CP review).

SCC approved GS-5 data center rate class November 25, 2025 (Case PUR-2025-00058). Applies to new GS-5 contracts on or after January 1, 2027. Trigger: customer >25 MW with monthly load factor >75%.

85% minimum bill on contracted T&D demand; collateral obligations up to 60% of minimum charges; minimum 14-year contract regardless of buildout.

AEP Ohio data center tariff adopted by PUCO July 9, 2025. 12-year framework (4-year ramp + 8-year fixed). Minimum monthly billing demand ≥85% of customer’s highest previously established monthly billing demand.

Amazon, Google, Meta, Microsoft, and the Ohio Manufacturers’ Association sought rehearing. PUCO denied. (OMA appealed to Ohio Supreme Court.)

In February 2026 PUCO filing, AEP Ohio described the rule as “weeding out uncommitted data center load.”

Ohio HB 706 (introduced March 2026) would extend the framework statewide.

SRP LCIP and E-67 commercial/industrial price plan (2025). Minimum billing = greater of actual demand or 80% of forecasted load.

ACC Large Load Workshop April 16, 2026 (Docket E-00000A-25-0069). 59 SRP large-load customers totaling ~7 GW reported.

TVA review thresholds: >5 MW requires TVA review; >100 MW requires TVA board approval.

TVA board voted February 11, 2026 to add 150 MW to xAI’s Memphis allowance — roughly doubling it. Same decision cycle reversed previously planned closures of the Kingston (2027) and Cumberland (2028) coal plants.

Data centers represent ~18% of TVA industrial load in 2025; projected to double by 2030.

Georgia PSC approved Georgia Power’s ~10 GW gas expansion (9,885 MW). Approximately $16 billion capital plan. Base rate freeze through 2028 (July 31, 2025 PSC order).

Verbatim stipulation: “downward pressure of at least $8.50 per month to the typical residential customer using an average of 1,000 kWh per month for the years 2029, 2030 and 2031.”

~6 GW data center pipeline in Duke Carolinas territory. Duke Energy Progress NC rate case filed October 2025; Duke Energy Carolinas NC rate case filed November 20, 2025.

Clean Transition Tariff announced via MoU with Amazon, Google, Microsoft and Nucor (not yet filed as tariff).

Oregon: amendment to omnibus enterprise-zone legislation (SB/HB 4084, 2026 session) temporarily excluded data centers from expanded 10-year tax exemption.

Washington ESSB 6231 (signed by Gov. Ferguson) repeals sales and use tax exemption on replacement and refurbished data center equipment, effective July 1, 2026.

Washington Clean Energy Transformation Act (CETA) 100% emissions-free electricity mandate by 2045 remains in force (RCW 19.405).

OCP ORv3 HPR (High Power Rack) 5.5 kW PSU shelf — the design used in NVIDIA GB200 NVL72 and Blackwell-class racks — published input voltage window: 180 to 305 VAC.

Earlier ORv3 3 kW PSU runs narrower 200–277 VAC input window. Neither variant brackets the NOGRR 282 ride-through floor.

NVIDIA contributed GB200 NVL72 designs to the Open Compute Project under the ORv3 HPR specification.

OCP Open Rack V3 BBU Module Spec rev 1.4 — battery backup unit shelf providing limited rack-level ride-through mitigation (seconds-scale).

Independent corroboration of the upstream-fix thesis (facility-layer voltage conditioning required, not rack-layer): arXiv 2510.03867, October 2025.

ERCOT interconnection queue >233 GW of large-load requests; >70% from data centers (December 9, 2025 board update).

ERCOT all-time system peak: 85,931 MW, set on August 20, 2024.

PJM 2026/2027 capacity auction: $7,271,197,971 (82.1%) increase in capacity-market revenue attributable to forecast data center load.

PJM 2026/27 BRA cleared at the FERC-approved cap of $329.17/MW-day across the entire footprint (a record at the time of clearing; subsequently exceeded by the 2027/28 BRA).

PJM covers 67 million people across 13 states + DC.

Duke Carolinas data center pipeline: ~6 GW. Data centers ~1% of peak demand today; ~10% by 2030.

APS large-customer load commitments approaching 13.1 GW (against an actual 2025 system peak of ~8.6 GW; system peak forecast ~11.4 GW by 2031 and ~13 GW by 2038).