On Thursday, Oct. 23, U.S. Secretary of Energy Chris Wright sent a communication to the Federal Energy Regulatory Commission (FERC or the Commission), directing that FERC take action no later than April 30, 2026 to issue rules to facilitate the “timely and orderly interconnection of large loads.” Included in the communication was a proposed ANOPR (Advanced Notice of Proposed Rulemaking), which FERC immediately issued for a public comment period through November 14, 2025 in docket number RM26-4. Reply comments are due November 28, 2025.
The ANOPR provides a justification of the need for new rules, a legal analysis arguing that establishing new rules for interconnection of large loads is within FERC’s jurisdiction, and provides a set of principles for guiding FERC’s rulemaking on interconnection of large loads. Briefly, those principles are:
Applicability
FERC’s rules should only apply to new loads greater than 20MW interconnecting to transmission facilities.
Avoid Unnecessary Network Upgrades by Bundling Studies:
Interconnection studies should bundle together load and hybrid facilities with generating facilities to avoid the need for costly upgrades identified by studying only the load or the generating facility; but any network upgrades identified in studies should be 100% the responsibility of the interconnecting load.
Deter Speculative Projects So Demand Forecasting Can Be Accurately Account for Large Loads:
Load and hybrid facilities should be subject to standardized study deposits, readiness requirements, and withdrawal penalties to deter speculative projects and provide transmission providers the ability to more accurately forecast demand.
Withdrawal and/or Injection Rights for Hybrid Facilities:
Hybrid facilities should be studied based on the amount of withdrawal and/or injection rights required and should be required to install system protection facilities as needed to prevent exceeding those withdrawal or injection rights.
Expedite Studies of Large and Hybrid Loads that Agree to be Curtailed:
The interconnection studies of large and hybrid loads that agree to be curtailable should be expedited, and the system operator’s ability to control these facilities must be sufficient to integrate these loads into operations and system planning.
Treat Large Load and Generation Interconnection Customers on Equal Footing:
Large load interconnection customers should be afforded the same or equivalent option to build as is currently provided to generation interconnection customers.
Existing Generation Seeking Partial Suspension in order to Serve New Co-located Load Must Bear The Costs to Ensure System Reliability:
Existing generation facilities that seek partial suspension to serve a new co-located load must go through a system support resource (SSR) or reliability must run (RMR) type study that evaluates system conditions and forecasted load growth for at least three years after the proposed partial suspension, and the partial suspension may only proceed after any network upgrades needed to ensure reliability are in place. Any network upgrades would be the responsibility of the generating facility.
Allocation of Responsibility for Transmission Service and Ancillary Services:
Utilities serving large loads should be responsible for transmission service based on withdrawal rights and ancillary services based on peak demand, without considering co-located generation. Co-located generation should be fully compensated for provision of ancillary services.
The ANOPR seeks comment on various aspects of these principles, as well as on an appropriate transition plan to implement the reforms.
The topic of reliable integration of large loads into the grid continues to be an active discussion across the industry. GDS experts are available to advise customers on all aspects of large load integration. Reach out to the GDS Energy Reliability & Security Team and let us know how we can help.
Laura Hussey
Senior Consultant - Energy, Reliability and Security
GDS Associates
laura.hussey@gdsassociates.com