Topics in the text: Connecting load and generation · Cost allocation · Filing procedure
Eolian · Direct response
Eolian sought clarification that generation located electrically close to a large load could qualify for permanent limited service if it could constrain grid withdrawals over the long term. FERC dismissed the request because the preliminary order was not final.
Eolian request and FERC discussion (unpaginated)Commissioner Judy Chang · Direct response
Chang supported developing a regional record. She welcomed evidence from state regulators on possible jurisdictional problems and distinguished the narrower preliminary findings from the broader federal authority contemplated in the national rulemaking.
PDF pp. 109–110, Chang concurrenceNew York Independent System Operator · Direct response
NYISO explained that if the market and transmission proposals cannot cover a reliability need, it may refer a non-transmission solution to the New York Public Service Commission. The state commission then considers the project and cost recovery. This is NYISO’s description of the process, not a state endorsement of a project.
PDF pp. 7–8Printed headings where available; page ranges otherwise. Excerpts below are selected from the text by keyword.
opening text · Topic match: Cost allocation
195 FERC ¶ 61,216 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Laura V.Read this passage
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D.Read this passage
printed heading · Topic match: Connecting load and generation
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 1 See, e.g., PJM Interconnection, L.L.C., 190 FERC ¶ 61,115 (2025) (PJM Show Cause Order); PJM Interconnection, L.L.C., 193 FERC ¶…Read this passage
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I.Read this passage
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BackgroundRead this passage
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EL26-69-000 - 10 - notes that there are several challenges with its existing load interconnection process, such as: (1) the large volume of requests may delay the completion of the Load System Impact Study (Load SIS), which already requires approximately nine months to complete;28 (2) resource…Read this passage
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Representatives November 21 ANOPR Comments at 1. 36 See, e.g., AI Supply Chain Alliance November 21 ANOPR Comments at 2; DCC November 21 ANOPR Comments at 3; ECA November 21 ANOPR Comments at 6; Geronimo November 21 ANOPR Comments at 1-2; Google November 21 ANOPR Comments at 2-3; Verrus December 5…Read this passage
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On February 20, 2025, the Commission initiated a show cause proceeding against PJM and the PJM transmission owners regarding the lack of tariff provisions addressing with sufficient clarity or consistency the rates, terms, and conditions of service that apply to co-location arrangements.39 The…Read this passage
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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). 55 Id.Read this passage
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SPP Conditional High Impact Large Load Service 18.Read this passage
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II.Read this passage
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Eligible Customers may request Firm Point-To-Point Transmission Service68 or NITS.69 Firm Point-To-Point Transmission Service and NITS are available to an Eligible Customer that is willing to pay Congestion Rent associated with its service.70 The charges for transmission services in NYISO (either…Read this passage
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NYISO offers a standard Firm Point-to-Point Service Agreement to an Eligible Customer when it submits a completed application for Firm Point-to-Point Service.75 Firm Point-To-Point Transmission Service does not require NYISO to conduct a System Impact Study (SIS) or Transmission Service Study…Read this passage
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NITS requests do not require a NITS Study unless the Eligible Customer specifically requests that NYISO conduct such a study.92 In the event that the Eligible Customer requests a NITS Study, NYISO will coordinate with all affected transmission owners in performing the NITS Study, which will…Read this passage
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EL26-69-000 - 24 - data.100 After the Eligible Customer executes a System Impact Study Agreement with the transmission owner whose system the Eligible Customer proposes to interconnect (Connecting Transmission Owner) and submits a $150,000 study deposit, NYISO, in cooperation with the Connecting…Read this passage
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4.Read this passage
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Pursuant to the Tariff, an interconnection customer may request, and NYISO may provide, provisional interconnection service for limited operation prior to the completion of the cluster study and prior to completion of requisite attachment facilities, distribution upgrades, system upgrade…Read this passage
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NYISO does not have a process in place to evaluate large load co-located with generating facilities.118 Generator interconnection requests proceed through NYISO’s 113 Id. attach.Read this passage
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EL26-69-000 - 28 - and Behind-the-Meter Net Generation programs.123 NYISO explains that its current Behind-the-Meter Net Generation Resource participation is premised on a firm Host Load that does not participate in wholesale markets and is not easily controllable or responsive to market signals,…Read this passage
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III.Read this passage
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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
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It also includes instances where an Eligible Customer requests a new or modified point of delivery to serve a large load, where a large load seeks a new or modified delivery point as an unbundled retail transmission service customer, or where large loads are otherwise included in an Eligible…Read this passage
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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
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Lastly, we are concerned that NYISO’s existing Tariff fails to deter speculative or duplicative requests for transmission service by Eligible Customers on behalf of large loads.Read this passage
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Cost Shifting Risk Among Transmission Customers 72.Read this passage
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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
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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
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Several commenters discuss the risk of cost shifting among transmission customers that could result from transmission service requests by Eligible Customers on behalf of large loads.190 Commenters also argue that retail-level large load tariffs do not protect wholesale transmission customers from…Read this passage
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See infra P 98. 201 PJM Co-Location Order, 193 FERC ¶ 61,217 at P 2; PJM Co-Location Rehearing Order, 195 FERC ¶ 61,209 at PP 91, 102.Read this passage
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The Generator of the BTM:NG Resource must be electrically located in the NYCA, have a minimum nameplate rating of 2 MW and a minimum net injection to the NYS Transmission System or distribution system of 1 MW.Read this passage
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As we explained in the PJM Co- Location Order, states retain exclusive authority over the specific terms of retail sales and retail rate design, including retail cost allocation to the co-located load; which entities are legally permitted to provide electricity to retail customers in co-location…Read this passage
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We preliminarily find that NYISO’s Tariff appears to be unjust and unreasonable because it lacks sufficient clarity and consistency as to the rates, terms, and conditions of service that apply to interconnection customers serving co-located load, including the scope of the analyses NYISO performs…Read this passage
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Finally, we note that the Commission has found it just and reasonable that, in order for an Eligible Customer to 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…Read this passage
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Interconnection Customers Serving Electrically Proximate Large Load and Co-Located Load 114.Read this passage
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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,262 and has approved…Read this passage
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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,264 that is sufficiently electrically close to the interconnection customer’s requested point of interconnection, such that the impact on the…Read this passage
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EL26-69-000 - 77 - what type of transmission service an Eligible Customer will need to take on behalf of the electrically proximate large load or large co-located load.281 We note that, in the PJM Co-Location Order, the Commission found that the Eligible Customer must take transmission service on…Read this passage
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The informational report must include a detailed schedule of such initiatives, including timing of the stakeholder process and dates of any anticipated filings with the Commission.Read this passage
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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
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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 those issues if the…Read this passage
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The Commission Needs Good Records to Ensure Reasoned Decision-Making 4.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
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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
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The Orders Recognize the Importance of Evaluating Advanced Transmission Technologies 12.Read this passage
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VI.Read this passage
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While this is a long journey, even so, we must continue to move at breakneck pace to win the AI race.Read this passage