The nation’s six regional grid operators recently told FERC how they plan to keep the lights on as large loads reshape the grid. Their July 20, 2026 Informational Reports offer a rare, coast-to-coast snapshot of the regulatory landscape for data centers, AI campuses, and other large loads. They also signal what to expect when each grid operator files its Show Cause Response on August 17, 2026.
The U.S. Department of Energy has released a $293 million funding opportunity (DE-FOA-0003612) under its Genesis Mission to accelerate AI deployment across 26+ national challenges in energy systems, grid infrastructure, data centers, advanced manufacturing, microelectronics, and biotechnology. The focus is on creating deployment-ready solutions, not exploratory research. Unlike traditional DOE research grants, Genesis Mission prioritizes speed, integration, and measurable performance gains in complex systems through cross-sector collaboration.
On September 4, 2025, the Board of Directors of Southwest Power Pool (SPP), the regional transmission organization (RTO) responsible for much of the central United States, passed Revision Request 696 (RR 696), paving the way for SPP to propose that the Federal Energy Regulatory Commission (FERC) modify SPP’s Open Access Transmission Tariff (Tariff) to create a 90-day path to interconnection for large loads and supporting generation. SPP is expected to file this Tariff change proposal with FERC in the coming weeks. Pending FERC’s decision, SPP aims to administer one of the fastest interconnection study processes in the nation and allow expedited processing of new large loads on the SPP transmission system.
On December 19, 2024, FERC issued a Notice of Proposed Rulemaking (NOPR) to approve the addition of the newly defined term “Ride-through” to the North American Electric Reliability Corporation (NERC) Glossary of Terms and to approve the proposed Protection and Control (PRC) Reliability Standards PRC-024-4 (Frequency and Voltage Protection Settings for Synchronous Generators, Type 1 and 2 Wind Resources, and Synchronous Condensers) and PRC-029-1 (Frequency and Voltage Ride-through Requirements for Inverter-Based Resources (IBR)). According to FERC, these reliability standards are intended to address reliability gaps associated with IBRs tripping or entering momentary cessation in aggregate. The new rules will ensure that IBRs are able to “ride through” frequency and voltage excursions, such as faults on the transmission or sub-transmission system. In the NOPR, FERC seeks comments on the proposed rules and the need for informational filings that would help FERC analyze the impact of proposed exemptions in the rules for certain IBRs.
On June 13, 2024, the Federal Energy Regulatory Commission (FERC) issued an “Order to Show Cause”[1] (Order) under Section 206 of the Federal Power Act to four regional transmission organizations (RTOs) and independent system operators (ISOs). FERC is concerned that the RTOs/ISOs’ open access transmission tariffs (OATT) are unjust, unreasonable, and discriminatory because they allow transmission owners (TOs) to unilaterally elect “TO Initial Funding” (a funding mechanism that allows TOs to fund network upgrade capital costs upfront and then recover those costs from interconnection customers) which FERC believes may create barriers to interconnection and result in discrimination.
FERC is directing the Regional Transmission Operators (RTOs) and Independent System Operators (ISOs) to either show cause as to why their OATTs are just and reasonable or explain what changes they would make to remedy the concerns. The Order acknowledges and discusses the background of the issue, including FERC’s Order No. 2003, which established an interconnection pricing policy that allows RTOs/ISOs to propose alternative pricing mechanisms.
However, FERC is concerned about the potential for discrimination when the transmission provider is not independent. The Order further discusses the different ways that network upgrade costs can be funded in the Midcontinent Independent System Operator (MISO) region, recent case history related to TO Initial Funding, and a number of proceedings related to the issue. The Order also raises concerns about potential discrimination by transmission owners in PJM, Southwest Power Pool (SPP), and ISO New England, as well as questions about whether transmission owners face any uncompensated risks associated with owning, operating, and maintaining network upgrades.
FERC requests the RTOs/ISOs to address these concerns and answer a number of questions related to increased costs and potential discrimination. Under its Section 206 authority, FERC directs each of the four RTOs/ISOs, within 90 days of the date of the Order (i.e., Wednesday, September 11, 2024), either: (1) to show cause as to why its OATT remains just and reasonable and not unduly discriminatory or preferential and provide responses to the questions set forth in the Order; or (2) to explain what changes to its OATT it believes would remedy the identified concerns if the commission does determine the self funding to be unjust and unreasonable.
The impact of “TO self funding” on generation developers can be substantial. Here is a breakdown of the potential impacts on generation developers:
The FERC directive for RTO/ISOs to either justify the fairness of these practices or propose changes is therefore very significant for generation developers, who stand to benefit if the costs and risks associated with network upgrades are distributed more equitably and transparently.
For more information about the Order’s potential impact on your specific situation or to explore the next steps in light of the Order, please contact Michael Blackwell or a member of Husch Blackwell’s Energy Regulation team.
[1] Midcontinent Indep. Sys. Operator, Inc., et al., 187 FERC ¶ 61,170 (2024) (FERC Docket Nos. EL24-80-000, EL24-81-000, EL24-82-000, EL24-83-000).
Last month, Husch Blackwell published its seventh-annual report on public-private partnerships (P3s) and alternative project delivery strategies. This year’s report features an interesting article by Michael Blackwell, an attorney on the firm’s Energy & Natural Resources team, that explores how P3s and P3-like agreements might be deployed to hasten the transition from fossil fuels
At its May 13, 2024 open meeting the Federal Energy Regulatory Commission (FERC) unanimously approved Order No. 1977,[1] which updates the process FERC uses when exercising its transmission siting authority under Section 216 of the Federal Power Act, as amended by the Infrastructure Investment and Jobs Act of 2021 (IIJA).
At its May 13, 2024 open meeting, the Federal Energy Regulatory Commission (FERC) approved a groundbreaking final rule—Order No. 1920[1] —requiring public utilities to undertake new long-term regional transmission planning over a 20-year horizon and allocate the cost of selected transmission projects in a manner that corresponds to the benefits they provide.
The Texas Legislature, primarily responding to the unprecedented ERCOT system load shed event during 2021’s Winter Storm Uri, enacted far-reaching system and wholesale market reforms during its 2021 and 2023 legislative sessions. These reforms broadly seek to bolster electric system resilience and reliability while incentivizing, through wholesale market reforms and other out of market actions
Earlier this summer, the Federal Energy Regulatory Commission (FERC) introduced a groundbreaking order—Order No. 2023—aimed at reforming the generator interconnection process in response to the evolving landscape of energy resources, market dynamics, and emerging technologies across the nation.
Industry reaction to the substance of the new rules has been mixed, but it is