Read topic-matched comments in EL26-67
Topics in the text: Cost allocation · Connecting load and generation · Filing procedure
Commissioner David LaCerte · Related public statement
Answering Senator Cotton, LaCerte said beneficiaries should pay for the new infrastructure and states should hold hyperscalers to their commitments in retail rates. He did not specify a PJM cost formula.
PDF pp. 79–80, printed pp. 75–76Pennsylvania Office of Consumer Advocate · Direct response
The office asked FERC to clarify that a customer agreement is only one protection. It wanted parties to be able to show that existing regional allocation methods themselves charge other customers for network upgrades needed by a large load.
PDF pp. 2–5Maryland Office of People’s Counsel, Ohio Consumers’ Counsel, Delaware Division of the Public Advocate and Illinois Attorney General · Direct response
The four offices backed FERC’s transparency directives but said disclosure alone leaves existing cost shifts intact. They asked that agreements require full payment for the necessary upgrades and that other customers receive the corresponding revenue credits promptly.
PDF pp. 1–4, section III.B challengeRep. Victoria Spartz (Indiana’s 5th Congressional District) · Direct response
Spartz asked FERC and DOE to scrutinize potentially duplicate load forecasts and to require developers to pay attributable generation and transmission costs. Her November letter represents a member of Congress, not Indiana’s utility commission.
PDF pp. 1–4Commissioner David Rosner · Direct response
Rosner argued that a cost recovery agreement should prevent households from paying for a network upgrade if the data center never opens. He invited alternative regional mechanisms if they offered comparable protection.
PDF p. 91, Rosner concurrencePrinted headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Cost allocation
195 FERC ¶ 61,211 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Laura V.Read this passage Filed comments: Cost allocation
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C.Read this passage
printed heading · Topic match: Connecting load and generation
EL26-67-000 - 4 - Over the past year, the Commission has taken action in numerous dockets1 to address issues related to (a) unprecedented increases in requests for transmission service to serve large loads2 and (b) growing interest in the co-location of loads with generating facilities (co-location…Read this passage Filed comments: Connecting load and generation
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I.Read this passage
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BackgroundRead this passage
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Dep’t of Energy, Resource Adequacy Report: Evaluating the Reliability & Security of the United States Electric Grid (July 2025), www.energy.gov/sites/default/files/2025- 07/DOE%20Final%20EO%20Report%20%28FINAL%20JULY%207%29.pdf). 18 Id. (citing NERC, 2024 Long- Term Reliability Assessment 8 (Dec.…Read this passage Filed comments: Cost allocation
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Recent Proceedings Addressing Large and Co-Located Loads Over the past year, the Commission has begun to address, both sua sponte and in response to complaints and FPA section 20539 filings, the growing use of co-location arrangements.40 The Commission’s orders in those proceedings have addressed…Read this passage
PDF bookmark · Topic match: Connecting load and generation
EL26-67-000 - 14 - to co-location arrangements.41 The Commission explained when initiating that proceeding that the absence of such provisions may leave entities unable to determine what steps they can or must take to effectuate co-location arrangements of various configurations and how to do so in…Read this passage Filed comments: Connecting load and generation
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P 32 (explaining that SPP will grant HILLGA customers a new type of interconnection service, load limited resource interconnection service, which grants limited interconnection service solely to serve the associated HILL).Read this passage Filed comments: Connecting load and generation
PDF bookmark · Topic match: Reliability and curtailment
SPP Conditional High Impact Large Load Service On June 5, 2026, the Commission accepted revisions to SPP’s tariff to add a new type of non-firm transmission service, conditional high impact large load service 57 Id.Read this passage Filed comments: Reliability and curtailment
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II.Read this passage
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EL26-67-000 - 22 - Tariff provides that each “Eligible Customer shall be obligated to pay for 100% of the costs of the minimum amount of Network Upgrades necessary to accommodate its New Service Request and that would not have been incurred under the Regional Transmission Expansion Plan [(RTEP)]…Read this passage Filed comments: Cost allocation
printed heading · Topic match: Cost allocation
The company also proposed implementing an application process and specific requirements for potential customers with a projected load of at least 50 MW.”); id. (“Exelon subsidiary Commonwealth Edison Company (ComEd) has proposed revisions to Rider DE that clarify requirements and procedures for…Read this passage Filed comments: Cost allocation
PDF bookmark · Topic match: Reliability and curtailment
As such, and as the Commission explained in the April Order Regarding Intent to Act, we find that the Commission must now take further action to ensure that PJM promptly proposes revisions to ensure that its Tariff remains just and reasonable.Read this passage Filed comments: Reliability and curtailment
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III.Read this passage
printed heading · Topic match: Filing procedure
We emphasize that we will not grant such abeyances reflexively, that any abeyance will be limited to 90 days, and that we will look with great disfavor toward requests to extend the abeyance period.Read this passage Filed comments: Cost allocation
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It also includes instances where an Eligible Customer requests a new or modified point of remaining directives, we expect a response to this order within the 60-day deadline set forth herein. 112 See, e.g., Idaho Power Co., 145 FERC ¶ 61,122 (2013); Canal Elec.Read this passage
PDF bookmark · Topic match: Retail and wholesale authority
Specifically, we find that it is within the Commission’s exclusive authority to ensure that transmission provider and/or transmission owner tariffs include sufficiently clear and consistent provisions governing how transmission service to Eligible Customers on behalf of large loads interconnecting…Read this passage Filed comments: Cost allocation
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Lastly, we are concerned that PJM’s existing Tariff fails to deter speculative or duplicative requests for transmission service by Eligible Customers on behalf of large loads.Read this passage Filed comments: Cost allocation
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Cost Shifting Risk Among Transmission Customers We next preliminarily find that PJM’s Tariff appears to be unjust and unreasonable because it lacks adequate mechanisms to mitigate the risk of cost shifting among transmission customers, which may result in unjust and unreasonable rates for…Read this passage Filed comments: Cost allocation
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To fulfill its responsibility to ensure that transmission rates are just and reasonable, the Commission must act to address the risk of cost shifting among transmission customers due to (1) the process transmission providers and/or transmission owners use to evaluate the facilities needed, and the…Read this passage Filed comments: Cost allocation
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The speed and scale with which Eligible Customers are seeking transmission service on behalf of large loads makes it difficult for interested parties, including transmission customers and state regulators, to accurately assess which transmission costs are driven by requests for transmission service…Read this passage Filed comments: Cost allocation
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EL26-67-000 - 52 - protect wholesale transmission customers from cost shifting.169 Specifically, commenters in the record contend that, while a retail-level large load tariff protects the load serving entity taking wholesale transmission service and its retail customers, it fails “to provide any…Read this passage Filed comments: Cost allocation
PDF bookmark · Topic match: Filing procedure
EL26-67-000 - 58 - take interim NITS, firm contract demand transmission service, and non-firm contract demand transmission service, an Eligible Customer must have necessary control technologies and/or protection systems, which may include a special protection scheme, to limit its energy withdrawals…Read this passage
PDF bookmark · Topic match: Connecting load and generation
Interconnection Customers Serving Electrically Proximate Large Load and Co-Located Load In response to the ANOPR, a number of commenters agree that the ability to study new load and new generation together, when physically or electrically proximate, presents system benefits and can help address the…Read this passage Filed comments: Connecting load and generation
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The Commission has exercised this jurisdiction previously in requiring generator interconnection services that allow certain generating facilities to interconnect more quickly through the use of provisional interconnection service and surplus interconnection service,212 and has approved…Read this passage Filed comments: Connecting load and generation
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Definitions For purposes of this order, it appears to be reasonable to use the term “electrically proximate large load” to mean a large load, as defined in this order,214 that is sufficiently electrically close to the interconnection customer’s requested point of interconnection, such that the…Read this passage
PDF bookmark · Topic match: Connecting load and generation
Given that generator interconnection service in and of itself does not convey transmission service, we encourage PJM to consider, in responding to these concerns, what type of transmission service an Eligible Customer will need to take on behalf of the electrically proximate large load or large…Read this passage Filed comments: Connecting load and generation
PDF bookmark · Topic match: Reliability and curtailment
The informational report must include a detailed schedule of key milestones, such as stakeholder or PJM Board votes, that includes the estimated date on which PJM expects to file any such proposals with the Commission.Read this passage Filed comments: Reliability and curtailment
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We find that there may be a variety of possible approaches to protect customers from significant cost shifts associated with Network Upgrades triggered by large loads.Read this passage Filed comments: Cost allocation
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Overview of Today’s Orders In each of today’s orders to show cause, the Commission identifies a series of issues raised by the ongoing growth of large loads, directs briefing on whether existing tariffs remain just and reasonable in light of those developments, and describes possible solutions to…Read this passage Filed comments: Cost allocation
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The Commission Needs Good Records to Ensure Reasoned Decision-Making I first want to emphasize that the Commission needs active participation from interested stakeholders to develop thorough records in each region.Read this passage
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As we develop the new infrastructure, many have raised concerns about whether these costs are being fairly assigned to new and existing customers, whose benefits must be commensurate with the costs they pay.Read this passage Filed comments: Cost allocation
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While it is important to identify innovative solutions that can adapt to the needs of the system, the Commission and grid operators must also be careful not to implement changes that create unforeseen reliability risks.Read this passage Filed comments: Cost allocation
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The Orders Recognize the Importance of Evaluating Advanced Transmission Technologies Lastly, today we preliminarily find that each RTO/ISO’s tariff is unjust and unreasonable because the tariff lacks clear and consistent provisions requiring the evaluation of alternative transmission technologies…Read this passage
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VI.Read this passage
printed heading · Topic match: Cost allocation
While this is a long journey, even so, we must continue to move at breakneck pace to win the AI race.Read this passage Filed comments: Cost allocation