# Large Load Interconnection

> From the DOE §403 ANOPR (Docket RM26-4-000) to FERC’s June 18, 2026 tailored §206 show cause orders

On October 23, 2025, the Department of Energy invoked its rarely used § 403 authority to direct FERC to open a rulemaking on connecting large loads (data centers, AI, advanced manufacturing) to the interstate grid (Docket RM26-4-000), and asked for final action by April 30, 2026.
Rather than run a multi-year rulemaking, FERC answered on June 18, 2026 with six tailored § 206 show cause orders, one to each RTO/ISO. Each makes a threshold finding that the region’s tariff may be unjust and unreasonable for lack of clear, consistent large-load rules, then puts the market on a 30/60-day clock to defend the status quo or file a fix across the same five reform categories.
The through-line is cost causation made visible: the large load that triggers a network upgrade should bear its cost and spare ordinary ratepayers, with new transparency into how those costs are identified and allocated. The same morning, FERC issued Item E-2 (EL25-49-002), the order on rehearing that finalizes the rates and terms for the three new transmission services its PJM co-location proceeding created, the same services the six orders extend to every other region.
As of the August 3, 2026 sweep, all six markets have used the tools the clock gives them. Every RTO/ISO filed its 30-day generation-adequacy report by July 20 (confirmed on eLibrary for all six). Every one of the six proceedings now carries an abeyance motion: PJM and its Transmission Owners filed five days early, on July 28; the other five followed on August 3, the deadline itself. FERC opened an answer period on PJM's motion, and large stakeholders are answering in support rather than opposing it. August 17 still carries the six show-cause filings for any docket that isn't held in abeyance, plus PJM's separate request to extend its co-location compliance deadline. Running beside all of it, FERC opened the post-conference comment period on PJM's own governance on July 30, in Docket AD26-7-000, heading toward a September reform deadline.
The August 23, 2026 sweep finds the clock stopped. On August 14, three days before the deadline everything had been building toward, FERC held all six §206 proceedings in abeyance, in full, including both the show-cause responses and the briefing questions. Responses now come due November 16, 2026, and answers to them December 16; SPP asked for 95 days rather than 90 and got exactly that, so its dates are November 20 and December 21. Every abeyance motion on file was granted, including PJM's, its Transmission Owners' and Silver Run Electric's, and including MISO's over American Municipal Power's opposition, the only opposition in the record. FERC did not adopt AMP's proposed condition but answered it in the order, reminding MISO and its Transmission Owners that if their §205 filings do not address all of the preliminary findings, the Commission will take those issues up through the show cause proceeding. Each order carries the same suspension clause: a respondent that makes its §205 filing by the new date has its obligation to respond suspended, and the proceeding stays in abeyance pending further direction. CAISO's is the only one issued as a full order rather than a letter order, because it also granted the rescission motions of the Six Cities and the Western Area Power Administration, removing them from the proceeding as non-public utilities under FPA §201(f) and amending the caption. FERC made the same cleanup in PJM's and MISO's dockets by errata on August 13.
August 17 did not pass empty. It was also the co-location compliance date, and although FERC granted PJM a 90-day extension to November 16 there too, PJM had promised a partial filing that day and made one: revised definitions, removal of the 50 MW nameplate limit on retail behind-the-meter netting, and the tariff records for Interim Network Integration Transmission Service, whose provisions it proposes not to make effective until July 1, 2028. The PJM Transmission Owners filed the Interim NITS rate the same day, noting in a footnote that the directives they are complying with are under challenge and the sheets may later be withdrawn. The pressure did not pause with the clock. On Jul 27 the entire Maryland congressional delegation, two senators and seven representatives, wrote to Chairman Swett saying they were encouraged by the June 18 orders and asking for something the orders do not reach: relief from the roughly $2 billion of PJM transmission cost already allocated to Maryland ratepayers for data centers built in other states. Two states went further and acted on their own, New Jersey enacting a data-center ratepayer class on Jul 7 and Virginia's commission directing Dominion on Aug 10 to assign transmission costs to large loads directly. Cost causation, the principle the six orders rest on, is being implemented at retail while the federal proceeding waits. Meanwhile the two lanes running beside the main one both filled up: roughly 49 filings landed in the PJM governance docket on the August 21 comment deadline, from PJM itself, the state committee, utilities, generators, consumer advocates and environmental groups, and PJM's backstop auction drew protests from its own Transmission Owners, from consumer advocates in three states and from generators, after a sweep two weeks earlier had found none.
The August 9, 2026 sweep found the answer period producing the record's first real division. American Municipal Power is the lone opponent, arguing MISO's abeyance motion does not meet the show cause order's own abeyance standard, and asking FERC to condition further abeyance on a 20-day stakeholder proposal rather than deny it outright. Every other answer's own filed description states support for its docket's motion, from Constellation, an industrial customer coalition, the Corporate Energy Buyers Association, a state committee and state commissions; the one ambiguously worded exception (a state committee's answer in ISO-NE's docket) was confirmed as support by reading the filing directly. PJM's docket alone gained a third, separate abeyance motion, from a respondent asking FERC to rule by August 13 so it has certainty ahead of the August 17 deadline. Newly confirmed, known only through an Aug 4 Constellation answer that cites and dates them: the Indicated PJM Transmission Owners and, jointly, Exelon and FirstEnergy sought rehearing of both the PJM order and the E-2 order on July 20. Constellation's answer, opposing both, says the Exelon/FirstEnergy E-2 request largely repeats an earlier rehearing request the Commission already rejected. On the governance track, FERC's July 30 notice, once its own text was read directly, sets two concrete dates: post-conference comments are due August 21, and its Alternative Dispute Resolution forum is set to commence September 1. And PJM's capacity backstop moved from a stated intent to a proposed FERC filing on July 31 (Docket ER26-3380, not yet acted on): a one-time reliability auction targeting the same 6,831 MW shortfall, at a $555/MW-day cap and up to $20 billion. No docket has a FERC ruling yet on any pending abeyance motion.

A static, independent analysis microsite (not affiliated with FERC or DOE). Source of truth: docs/js/data.js. Evidence is kept in three visibly distinct tiers: FERC primary, DOE primary, and secondary analysis.

## Key facts

- Authority: Federal Power Act § 206 · DOE Organization Act § 403
- Items and dockets: Items E-7 to E-12 · Dockets EL26-67-000 to EL26-72-000
- Reporter cites: 195 FERC ¶ 61,211 to 61,216
- Commission: Laura V. Swett (Chairman) · David Rosner · Lindsay S. See · Judy W. Chang · David LaCerte
- Order record as of 2026-06-22; Discourse commentary gathered 2026-06-29
- RTOs / ISOs: 6, all FERC-jurisdictional grid operators + their TOs
- Reform categories: 5, teed up in each tailored order
- Informational report: 30 days, resource-adequacy plan to serve large loads
- Justify or file: 60 days, defend tariffs or propose §206 revisions; all six now in abeyance to Nov 16
- “Large load”: > 20 MW, DOE threshold (per Order No. 2003)
- Pages reviewed: 3,500+, public comments in the RM26-4 docket

## The six show cause orders (E-7 to E-12)

Each order PDF is committed and served at the page-precise link below; the official FERC source (Cloudflare-gated) is noted after it.

- [E-7 PJM, EL26-67-000, 195 FERC ¶ 61,211, 114 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-7-pjm-el26-67-000.pdf): Co-location rules already in place. Region: Mid-Atlantic / 13 states + DC. Official: https://www.ferc.gov/media/e-7-el26-67-000
- [E-8 MISO, EL26-70-000, 195 FERC ¶ 61,212, 115 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-8-miso-el26-70-000.pdf): Early-stage large-load rules. Region: 15 states, Midwest + South. Official: https://www.ferc.gov/media/e-8-el26-70-000
- [E-9 SPP, EL26-68-000, 195 FERC ¶ 61,213, 92 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-9-spp-el26-68-000.pdf): Most mature: HILL / HILLGA. Region: Central U.S., 14+ states. Official: https://www.ferc.gov/media/e-9-el26-68-000
- [E-10 CAISO, EL26-71-000, 195 FERC ¶ 61,214, 118 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-10-caiso-el26-71-000.pdf): No Order No. 888 service. Region: California (+ WEIM footprint). Official: https://www.ferc.gov/media/e-10-el26-71-000
- [E-11 ISO-NE, EL26-72-000, 195 FERC ¶ 61,215, 115 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-11-isone-el26-72-000.pdf): Transmission-constrained grid. Region: Six New England states. Official: https://www.ferc.gov/media/e11-el26-72-000
- [E-12 NYISO, EL26-69-000, 195 FERC ¶ 61,216, 119 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-12-nyiso-el26-69-000.pdf): Largely outside the tariff today. Region: New York State. Official: https://www.ferc.gov/media/e12-el26-69-000

## The PJM co-location rehearing order the six extend (Item E-2)

- [E-2 PJM Interconnection, L.L.C., EL25-49-002, 195 FERC ¶ 61,209, 278 pp](https://pranava0x0.github.io/FERC-Orders-June-2026/orders/e-2-pjm-el25-49-002.pdf): Order on rehearing, clarification, compliance & paper hearing on the December 18, 2025 PJM Co-Location Order (193 FERC ¶ 61,217), issued June 18, 2026. Finalizes PJM’s co-location services (Interim NITS, FCD, NFCD) — the services the six §206 orders extend. Official: https://www.ferc.gov/media/e-2-el25-49-002

## The five reform categories

- 1. Application & study processes (incl. alternative transmission technologies): Developing efficient transmission-service application and study processes, including consideration of alternative transmission technologies.
- 2. Cost-shifting prevention & transmission-cost transparency: Preventing cost shifting and requiring transparency into transmission costs.
- 3. Co-location arrangements & behind-the-meter (BTM) generation: Accommodating co-location agreements and behind-the-meter generation.
- 4. New transmission services for flexible large loads: Providing new transmission services for flexible large loads.
- 5. Studying generation serving electrically proximate / co-located loads: Developing a process to study generating facilities that serve electrically proximate large loads and co-located loads.

## Primary sources

- [DOE §403 Letter & enclosed ANOPR](https://www.energy.gov/sites/default/files/2025-10/403%20Large%20Loads%20Letter.pdf): U.S. Dept. of Energy (Sec. Chris Wright), captured 2026-06-22
- [News Release: “FERC Launches Aggressive Targeted Action to Speed Large Load Integration”](http://web.archive.org/web/20260618211730/https://www.ferc.gov/news-events/news/ferc-launches-aggressive-targeted-action-speed-large-load-integration): FERC, Office of External Affairs, captured 2026-06-18 (Internet Archive)
- [Fact Sheet: “FERC Takes Action to Supercharge America’s Grid…”](http://web.archive.org/web/20260620020229/https://www.ferc.gov/news-events/news/fact-sheet-ferc-takes-action-supercharge-americas-grid-efficiency-reliability-and): FERC, captured 2026-06-20 (Internet Archive)
- [Summaries: June 2026 Commission Meeting](http://web.archive.org/web/20260618204955/https://www.ferc.gov/news-events/news/summaries-june-2026-commission-meeting): FERC, Office of External Affairs, captured 2026-06-18 (Internet Archive)
- [Docket RM26-4-000 landing page: “Interconnection of Large Loads…”](http://web.archive.org/web/20260619085932/https://www.ferc.gov/rm26-4): FERC, captured 2026-06-19 (Internet Archive)

## Parallel proceedings (as of the 2026-08-23 news sweep)

### The six-market §206 clock (`sc6`)
- Venue: FERC Dockets EL26-67-000 to EL26-72-000
- What: Six show cause orders on one 60-day clock. Each RTO or ISO must defend its tariff or file a fix.
- Why it is tracked separately: This is the main proceeding the site tracks. The other lanes run beside it, each on its own clock.
- Status (2026-08-23): All six proceedings are held in abeyance. FERC granted every pending abeyance motion on Aug 14, three days before the 60-day deadline, in full, including responses to the show cause order and the briefing questions. Responses are now due Nov 16, 2026 and answers Dec 16, except SPP, which asked for 95 days instead of 90 and got them: Nov 20 and Dec 21. MISO's was granted over American Municipal Power's opposition; FERC declined AMP's proposed 20-day condition but told MISO and its Transmission Owners in the order that any preliminary finding their §205 filings leave unaddressed will be taken up through the show cause proceeding. In every docket, a respondent that makes its §205 filing by the new date has its obligation to respond suspended, and the proceeding stays in abeyance pending further direction. CAISO's order also granted the Six Cities' and WAPA's motions to rescind the order as against them, as non-public utilities under FPA §201(f); errata on Aug 13 made the same correction in the PJM and MISO orders. One actual show-cause answer was filed before the pause: Morongo Transmission, a CAISO participating TO owned by the Morongo Band of Mission Indians, answered on Aug 12 that its tariff needs no amendment because it serves no end-use customers.
- Next: 2026-11-16, Show-cause responses due after the 90-day abeyance (SPP: Nov 20)
  - Dec 16, 2026: Answers due 30 days after the rescheduled responses
  - After the response records close: FERC decides whether to accept, modify, or impose a §206 remedy
  - Parallel lane: Rehearing and court-review risk runs alongside implementation

### PJM co-location: EL25-49 (`e2`)
- Venue: FERC Docket EL25-49 (Item E-2, order on rehearing)
- What: The PJM co-location proceeding that created the three new transmission services the six orders extend to every other region.
- Why it is tracked separately: A different docket with its own compliance clock, which has tracked the §206 clock closely: both were reset to Nov 16, 2026 on the same day, by separate FERC actions.
- Status (2026-08-23): FERC granted the 90-day extension on Aug 14, moving PJM's and the PJM Transmission Owners' co-location compliance deadline to Nov 16, 2026, the same date as the §206 clock. PJM had told FERC it would still make a partial filing on Aug 17 regardless, and it did: revised definitions of Co-Located Load, behind-the-meter generation and Necessary Study, removal of the 50 MW nameplate limit on retail behind-the-meter netting, an end to the requirement that existing customers sign a new interconnection agreement to serve co-located load, and the tariff records for Interim Network Integration Transmission Service. Most of it is proposed effective Oct 17, 2026, but the Interim NITS provisions are proposed for July 1, 2028, which PJM attributes to the operational tools needed to curtail the non-firm service. The PJM Transmission Owners filed the Interim NITS rate the same day and noted that the directives behind it are under challenge, so the sheets may be withdrawn later. Northern Virginia Electric Cooperative's Jul 29 motion for clarification is now on the docket too, answered by Vistra on Aug 18. The Jul 20 rehearing requests, the Third and D.C. Circuit appeals of the predecessor orders, and Constellation's own rehearing request all remain pending.
- Next: 2026-11-16, PJM and PJM TOs full co-location compliance filing
  - Jul 28, 2026: PJM separately seeks more time on its co-location compliance filing
  - Aug 14, 2026: The co-location compliance deadline moves to the same date
  - Aug 17, 2026: PJM files partial co-location compliance anyway, and dates one service to 2028

### PJM governance: AD26-7 (`gov`)
- Venue: FERC Docket AD26-7-000 (Commission-led technical conference)
- What: A July 23 conference on who runs PJM: board independence, the stakeholder process, and the states’ role.
- Why it is tracked separately: Runs outside the §206 clock. Its September deadlines decide who controls PJM’s follow-through filings.
- Also known as: Also referred to in shorthand as the Swett technical conference, after the chairman who convened it.
- Status (2026-08-23): The comment deadline landed and the docket filled: roughly 49 filings on Aug 21 alone, against a handful of mostly individual comments two weeks earlier. PJM filed its own post-conference comments, as did the Organization of PJM States, and the range of filers is the point: utilities and transmission owners (Exelon, FirstEnergy, AEP, Dominion, PSEG, PPL, Duquesne, Duke, Rockland, National Grid Ventures), generators and traders (Constellation, NRG, Vistra, ENGIE, Shell Energy, Capital Power, Tenaska, Vitol, the PJM Power Providers Group, the Financial Marketers Coalition), public power and cooperatives (American Municipal Power, Buckeye Power, three municipal agencies, two co-ops), consumer advocates and state bodies (the Ohio Consumers' Counsel, the Citizens Utility Board of Illinois, the Illinois Commerce Commission), and public-interest and academic filers (the Harvard Electricity Law Initiative, answering Questions 12 and 13 specifically, R Street, the Center for Progressive Reform, Advanced Energy United, SEIA, a joint Sierra Club filing). The Alternative Dispute Resolution forum is next, set to commence Sept 1. The chairman's end-of-September deadline for a PJM reform package, or FERC imposing its own, is still a closing-remarks commitment with no calendar date noticed.
- Next: 2026-09-01, Alternative Dispute Resolution forum commences
  - Jul 23, 2026: FERC holds the PJM governance conference and sets a September deadline
  - Jul 30, 2026: FERC opens the post-conference comment period on PJM governance
  - Aug 21, 2026: The governance docket fills in a single day

### The RM26-4 record (`rm264`)
- Venue: FERC Docket RM26-4-000 (the DOE §403 rulemaking)
- What: The rulemaking DOE’s §403 directive opened, and the 3,500-plus pages of comment the orders were built on.
- Why it is tracked separately: Still open. Everything the six orders left unaddressed stays live here, which is what the record-to-rule crosswalk tracks.
- Status (2026-07-28): Open with no dated next step. FERC answered the directive with the six §206 orders rather than a rule.
- Next: No dated step on the record
  - Oct 23, 2025: DOE issues a § 403 directive + enclosed ANOPR
  - Oct 23, 2025: Fourteen ANOPR principles define the reform menu
  - Late 2025 to Jan 2026: FERC opens RM26-4-000, takes comment, extends the period

### Market context (`context`)
- Venue: not a docket
- What: Auction results and market events that set the stakes for the filings, from outside any of the dockets.
- Why it is tracked separately: None of these are filings. They are kept in their own lane so the rail never reads an auction result as a docket event.
- Status (2026-08-23): The backstop auction is now contested. PJM's Jul 31 filing (Docket ER26-3380) proposing a one-time reliability auction from Sept 30 to Oct 21 at a $555/MW-day cap, up to $20 billion, drew protests on the Aug 21 comment date from the Indicated PJM Transmission Owners, from consumer advocates in three states (the Pennsylvania Office of Consumer Advocate, the Delaware Division of the Public Advocate, which asked FERC to reject the filing outright, and the Ohio Consumers' Counsel, which asked for rejection or an evidentiary hearing), and from generators including Constellation, NRG, FirstEnergy, AEP and Dominion, most of them limited or partial protests rather than outright opposition. The Illinois Commerce Commission and the Organization of PJM States filed in support. Data center operators are on the docket in their own right: Google, Equinix and CyrusOne all filed. Two weeks earlier this docket had interventions and no protests at all.
- Next: 2026-09-30, PJM's one-time reliability backstop auction opens (Docket ER26-3380)
  - Jul 31, 2026: PJM files its backstop capacity auction plan at FERC
  - Jul 7 to Aug 10, 2026: Two states do the thing the orders are arguing about, while the federal clock runs out
  - Aug 21, 2026: PJM's backstop auction draws protests, including from its own transmission owners

## Observed filings (checked 2026-08-23)

- Observed filings only. An empty cell means our checks found nothing, which is not proof nothing was filed. Every report and abeyance cell below is confirmed against its own eLibrary accession. Every abeyance motion was GRANTED on Aug 14, 2026, so the show-cause column is upcoming again, now against Nov 16 (Nov 20 for SPP) rather than Aug 17; each cell's gist carries the granting order's accession and reporter citation.
- Status vocabulary: `filed-verified` (eLibrary accession seen) · `filed-reported` (press or operator channel only) · `signaled` (announced intent). An absent row means our checks observed nothing, which is not proof nothing was filed.
- PJM (EL26-67-000), report, filed-verified, 2026-07-20: PJM's informational filing on regional resource adequacy in compliance with the show-cause order. Accession: 20260720-5203.
- SPP (EL26-68-000), report, filed-verified, 2026-07-20: SPP's informational filing on regional resource adequacy in compliance with the show-cause order. Accession: 20260720-5205.
- NYISO (EL26-69-000), report, filed-verified, 2026-07-20: NYISO's informational filing on regional resource adequacy in compliance with the show-cause order. Accession: 20260720-5217.
- MISO (EL26-70-000), report, filed-verified, 2026-07-20: MISO's informational filing on regional resource adequacy in compliance with the show-cause order. Accession: 20260720-5204.
- CAISO (EL26-71-000), report, filed-verified, 2026-07-20: CAISO's informational filing on regional resource adequacy in compliance with the show-cause order. Accession: 20260720-5202.
- ISO-NE (EL26-72-000), report, filed-verified, 2026-07-20: Informational filing on regional resource adequacy. Outlines requiring new large loads to bring incremental new generation, and not procuring capacity for them through the regional capacity market. Accession: 20260720-5216.
- PJM (EL26-67-000), abeyance, filed-verified, 2026-07-28: PJM Interconnection moves to hold the proceeding in abeyance with a shortened answer period; the Indicated PJM Transmission Owners file a parallel motion the same day. Filed five days ahead of the deadline. FERC sets an answer period Jul 30 (20260730-3026); Constellation and the PJM Industrial Customer Coalition answer in support Aug 3. Granted Aug 14 (letter order 20260814-3059, 196 FERC ¶ 61,129), together with the Indicated PJM TOs' and Silver Run Electric's motions; responses reset to Nov 16, 2026. Accession: 20260728-5084.
- SPP (EL26-68-000), abeyance, filed-verified, 2026-08-03: Joint motion of Southwest Power Pool and other respondents to hold the proceeding in abeyance. Granted Aug 14 (letter order 20260814-3060, 196 FERC ¶ 61,128) for the 95 days the movants asked for rather than 90; responses reset to Nov 20, 2026, the latest of the six. Accession: 20260803-5209.
- NYISO (EL26-69-000), abeyance, filed-verified, 2026-08-03: NYISO moves for abeyance; the New York Transmission Owners (Con Edison, NYSEG, National Grid, O&R, RG&E, Central Hudson) and LS Power Grid New York / New York Transco file two further, separate abeyance motions the same day. All three motions granted Aug 14 (letter order 20260814-3068, 196 FERC ¶ 61,130); responses reset to Nov 16, 2026. Accession: 20260803-5229.
- MISO (EL26-70-000), abeyance, filed-verified, 2026-08-03: Joint motion of MISO and the MISO Transmission Owners to hold the proceeding in abeyance. Granted Aug 14 (letter order 20260814-3058, 196 FERC ¶ 61,133) over American Municipal Power's opposition, without AMP's proposed 20-day condition but with an express reminder that any preliminary finding the §205 filings leave unaddressed returns to the show cause proceeding; responses reset to Nov 16, 2026. Accession: 20260803-5249.
- CAISO (EL26-71-000), abeyance, filed-verified, 2026-08-03: CAISO moves for abeyance; a coalition of California transmission owners (SCE, SDG&E, PG&E and others) files a separate joint abeyance request the same day. The “Six Cities” (Anaheim, Azusa, Banning, Colton, Pasadena, Riverside) file a conditional abeyance motion, having already moved Jul 31 to rescind the order outright; the Western Area Power Administration separately moves to rescind as applied to itself. Granted Aug 14 by full order (20260814-3061, 196 FERC ¶ 61,131), which also granted the Six Cities' and WAPA's motions to rescind the order as against them under FPA §201(f) and amended the caption; responses reset to Nov 16, 2026. Accession: 20260803-5206.
- ISO-NE (EL26-72-000), abeyance, filed-verified, 2026-08-03: Joint motion of ISO New England and the Participating Transmission Owners Administrative Committee to hold the proceeding in abeyance — following through on the intent signaled Jun 29. Granted Aug 14 (letter order 20260814-3056, 196 FERC ¶ 61,132); responses reset to Nov 16, 2026. Accession: 20260803-5083.
- CAISO (EL26-71-000), showcause, filed-verified, 2026-08-12: Morongo Transmission LLC, a CAISO participating transmission owner owned by the Morongo Band of Mission Indians, answers that no amendment to its tariff is required because it is a non-load-serving transmission owner with no end-use customers, while stating it will keep participating in the proceeding. Filed two days before the abeyance and the only substantive answer to any of the six show cause orders observed to date. Accession: 20260812-5158.

## Commentary themes (secondary, in two dated waves)

- [wave 1, reaction to the June 18 orders, captured 2026-06-29] Cost responsibility is the center of gravity: Across the post-order discussion, the basic question is not whether large loads should connect faster; it is whether the tariff makes the beneficiary carry the cost and risk of the upgrade.
  - "There’s no real quarantining of the cost caused by data centers to those data centers" Source: https://insideclimatenews.org/news/18062026/federal-energy-regulatory-commission-data-center-orders/
  - "those loads bear the costs incurred to serve them" Source: https://www.linkedin.com/posts/jeffdennis77_ecaferclargeloadinterconnectionstatementpdf-activity-7473477334738599936-NWa-
  - "increasing scrutiny on who pays for transmission to connect data centers" Source: https://x.com/aniruddh_mohan/status/2069973894237184457
  - "President Trump's Ratepayer Protection Pledge" Source: https://www.energy.gov/articles/department-energy-applauds-fercs-action-large-load-interconnection-reform
- [wave 1, reaction to the June 18 orders, captured 2026-06-29] The regional route is both substance and litigation strategy: The six-order structure is being read as a deliberate alternative to one national template: faster than a rulemaking, more tailored to each market, and easier to defend on the record.
  - "far more substantively ambitious than the ANOPR" Source: https://www.utilitydive.com/news/ferc-doe-data-center-interconnection/823360/
  - "six regional answers to the same question, decided on six different timelines" Source: https://www.utilitydive.com/news/ferc-doe-data-center-interconnection/823360/
  - "a much more robust and detailed administrative record" Source: https://news.bloomberglaw.com/environment-and-energy/energy-regulator-staves-off-critique-in-new-data-center-orders
  - "reduces future litigation entry points" Source: https://news.bloomberglaw.com/environment-and-energy/energy-regulator-staves-off-critique-in-new-data-center-orders
- [wave 1, reaction to the June 18 orders, captured 2026-06-29] Speed now depends on provable flexibility: The strongest pro-speed argument treats data centers as controllable loads, but the quotes also show the hard edge: flexibility has to be operational, measurable, and worth something in the tariff.
  - "emergency data-center load reduction ripe for deeper industry analysis" Source: https://www.linkedin.com/pulse/demand-hereare-we-ready-build-briggs-white-cixae
  - "flexible AI data centers can adjust demand dynamically and act as grid assets, not only as fixed loads" Source: https://www.latitudemedia.com/news/catalyst-the-rise-of-flexible-data-centers/
  - "asset-backed flexible data centers can operate as grid assets" Source: https://www.volts.wtf/p/can-data-centers-be-good-grid-citizens
  - "paying other customers to shift load can be faster and more cost effective than curtailing expensive data-center chips" Source: https://www.eenews.net/articles/how-big-tech-learned-to-speak-ferc/
- [wave 1, reaction to the June 18 orders, captured 2026-06-29] Reliability and security remain live objections: The order is not landing as a pure acceleration story. Consumer and security voices are treating faster interconnection as acceptable only if modeling, operating standards, and stability protections keep up.
  - "security gaps remain" Source: https://x.com/BenSchifman/article/2067679572431138993
  - "data centers need any more help with interconnection to the grid" Source: https://x.com/Ben_Inskeep/status/2068025625860841880
  - "standards and rules in place that protect ratepayers from any negative stability, reliability and resiliency impacts" Source: https://x.com/Ben_Inskeep/status/2068025625860841880
- [wave 1, reaction to the June 18 orders, captured 2026-06-29] The physical buildout is bigger than the FERC clock: The discourse keeps returning to the same physical constraint: the orders can compress process, but turbines, transformers, generation, local consent, and deliverable capacity still decide which projects energize.
  - "power conversations for individual data centers have moved from megawatts to gigawatts" Source: https://cleanpower.org/blog/american-energy-american-ai-powering-a-secure-future/
  - "gas-turbine, transformer and interconnection lead times" Source: https://www.linkedin.com/pulse/demand-hereare-we-ready-build-briggs-white-cixae
  - "power constraints and political resistance" Source: https://www.shanumathew.com/writing/data-centers-focus-on-energized-gw
  - "developers are pairing data-center growth with behind-the-meter generation and siting near stranded or underused power" Source: https://www.argusmedia.com/en/news-and-insights/latest-market-news/2804882-us-grid-overhaul-urgently-needed-to-meet-ai-load-ferc
- [wave 1, reaction to the June 18 orders, captured 2026-06-29] The organized-market focus leaves a Southeast gap: The order covers the six RTO/ISO markets, while several reactions flag the regions outside that structure as exactly where transmission planning and interconnection practice may be weakest.
  - "non-RTO areas, which typically suffer from the worst transmission and interconnection practices" Source: https://www.utilitydive.com/news/ferc-doe-data-center-interconnection/823360/
  - "The Southeast needs a modern transmission system" Source: https://ceba.org/southeast-energy-opportunities-require-a-bigger-better-faster-grid-business-leaders-call-for-regional-transmission-planning/
  - "we risk higher energy prices, power shortages, and lost economic opportunities" Source: https://ceba.org/southeast-energy-opportunities-require-a-bigger-better-faster-grid-business-leaders-call-for-regional-transmission-planning/
- [wave 2, the filings and the governance fight, captured 2026-08-23] PJM’s own legitimacy becomes the story: The July 23 technical conference put PJM’s decision-making machinery on the record, and on a September clock. The same commission running the §206 filings is now asking who gets to decide what PJM files, which makes this lane a precondition for the other one rather than a sideshow.
  - "PJM is facing a grave legitimacy crisis" Source: https://www.utilitydive.com/news/ferc-pjm-governance-reforms-data-centers-capacity-market/826140/
  - "Some transmission owners are openly discussing leaving the RTO altogether" Source: https://www.utilitydive.com/news/ferc-pjm-governance-reforms-data-centers-capacity-market/826140/
  - "This is a cultural quagmire" Source: https://www.utilitydive.com/news/ferc-pjm-governance-reforms-data-centers-capacity-market/826140/
- [wave 2, the filings and the governance fight, captured 2026-08-23] Regional divergence: the tailoring thesis meets the record: The first observed answer to the 30-day reports points somewhere different from PJM’s expedited-new-entry posture. ISO-NE looks to new generation and away from its capacity market. That is the regional variation the six tailored orders were built to permit, showing up as substance rather than as a gap.
  - "requiring new large loads to bring incremental new generation" Source: https://isonewswire.com/2026/07/21/update-on-iso-ne-compliance-with-ferc-large-and-co-located-loads-order/
  - "not procuring capacity through the regional capacity market to serve these large loads" Source: https://isonewswire.com/2026/07/21/update-on-iso-ne-compliance-with-ferc-large-and-co-located-loads-order/
  - "intend to request a 90-day abeyance" Source: https://isonewswire.com/2026/06/29/iso-ne-provides-update-on-compliance-with-ferc-large-loads-order/
- [wave 2, the filings and the governance fight, captured 2026-08-23] Capacity scarcity is the arithmetic behind the argument: PJM’s 2028/2029 auction cleared at its cap for the third year running and still landed short of the reserve-margin target. Every claim about who should pay for new load is being made against that number.
  - "The price came in at the FERC-approved cap of $325/MW-day" Source: https://www.pjm.com/-/media/DotCom/about-pjm/newsroom/2026-releases/20260714-pjm-capacity-auction-procures-138318-mw-generation-resources.pdf
  - "short of PJM’s 20% installed reserve margin target by 6,831 MW" Source: https://www.pjm.com/-/media/DotCom/about-pjm/newsroom/2026-releases/20260714-pjm-capacity-auction-procures-138318-mw-generation-resources.pdf

## The RM26-4 public comments (corpus)

- 273 public comments (of 423 total eLibrary filings) on the DOE ANOPR (Docket RM26-4-000) were scraped from FERC eLibrary. Each text-extracted comment carries a quote-centric, auditable summary built the PNNL "CommentNEPA" way: verbatim quotes pulled from the filing, binned to the five reform principles / eight ANOPR questions / six regions (plus emergent topics), each bin with the filer's stance. AI-generated and provisional (not yet human-verified).
- Per-comment summaries: `sources/comments/summaries-v2/<accession>.json`. Compiled for the site: `docs/js/comments-data.js` (`window.FERC_COMMENTS`). Method + schema: `sources/comments/summarization-spec.md`. Explore on the Comments tab (a stance map + per-comment audited analysis).

## Read the site

- [Large Load Interconnection](https://pranava0x0.github.io/FERC-Orders-June-2026/): six tabs (Overview, Timeline, Reforms, Dockets, Comments, Discourse).