Orientation
The Federal Frame: Six Regions, One Deadline#
Every reform in the eight sections that follow is now running inside a single federal frame. On June 18, 2026, after reviewing more than 3,500 pages of comments in the large-load docket, FERC issued six simultaneous show-cause orders under section 206 of the Federal Power Act — one to each jurisdictional grid operator and its transmission owners. PJM (EL26-67), SPP (EL26-68), NYISO (EL26-69) and MISO (EL26-70) were joined by CAISO and ISO-NE, covering close to two-thirds of the load served under Commission-jurisdictional rates. The Commission preliminarily found every one of the six tariffs unjust and unreasonable for lacking clear provisions tailored to large and co-located loads.
The orders are tailored region by region but rest on the same five categories. First, clearer application and study processes, including consideration of alternative transmission technologies; protection against cost shifting, paired with new transparency about transmission costs; rules for co-location and behind-the-meter generation; new transmission services for loads that can limit their own use; and a study path for generation sited electrically close to the load it serves. Those five map onto Sections 1, 3, 5, 6 and 2 respectively — which is why this report treats them as one problem in eight parts rather than eight separate ones.
The orders run on one procedural calendar, and it has three exits rather than one. Interventions closed on July 9, 2026. Informational reports on generation adequacy were due thirty days after issuance — July 20, 2026, the nominal thirtieth day falling on a Saturday — and that deadline has now passed. Responses and briefs are due at sixty days, on August 17, with stakeholder comments thirty days after each filing, on or about September 16. The third exit makes the common deadline less common than it looks: within forty-five days, by August 3, an operator and its transmission owners may ask the Commission to hold the proceeding in abeyance for up to ninety days while a stakeholder process develops a section 205 filing instead — moving that region's substantive filing to roughly mid-November. ISO New England and the New England transmission owners announced on June 29 that they intend to make that request. CAISO went further on July 20, publishing an expedited stakeholder calendar in its informational report — straw proposal August 12, draft final proposal September 21, Western Energy Market Governing Body October 20, Board of Governors October 28 — ending in a filing on the show-cause order on November 16, a schedule the report states assumes a motion for abeyance. The Commission has said it will scrutinise such requests rather than grant them as a matter of course, will hold any abeyance to the ninety-day limit, and will look unfavourably on extensions. The practical effect is that a common deadline should be read as a starting position: the orders were simultaneous, but the responses need not be, and the first real test of how uniform this federal frame turns out to be arrives on August 3 rather than August 17.
| Region | Where it stood on June 18, 2026 | What FERC preliminarily found missing |
|---|---|---|
| PJM | Co-location provisions filed under earlier FERC directives; the Board has issued a Critical Issues Fast Path decisional letter setting out large-load initiatives. | No tariff provisions governing large-load interconnection or transmission service. Co-location is handled in a separate concurrent proceeding. |
| MISO | Expedited study routes (ERAS, EPR) but no dedicated large-load framework. | MISO indicated that its tariff gives no consistent or transparent basis for evaluating large loads — against the fastest data-center growth of any region, put by FERC staff at 43% compound annual growth since 2020 against 24% nationally (2025 State of the Markets, March 19, 2026). |
| SPP | HILL and HILLGA study processes live since January 15, 2026; Load Limited Resource Interconnection Service; CHILLS conditional service accepted June 5, 2026. | The narrowest set of deficiencies of the six, because SPP’s reforms had already anticipated most of FERC’s framework. |
| NYISO | Load interconnection procedures above 10 MW at 115 kV or higher, or 80 MW below; a reform initiative of its own running to a December 2026 board filing. | Application, study and operational requirements; cost shifting through the Transmission Service Charge when speculative requests drive local planning; no co-location terms. |
| CAISO | No traditional Order No. 888 transmission service, so the analytical framework differs structurally from the other five. Its July 20 report attributes California's position to an integrated CEC/CPUC/CAISO framework and sets a compliance calendar ending November 16. | Substantially similar deficiencies notwithstanding the different market design. |
| ISO-NE | No express provisions for large-load interconnection or transmission service. | The same gaps, but FERC recorded a less urgent concern in New England. ISO-NE and the New England transmission owners said on June 29 that they intend to seek the 90-day abeyance rather than respond on August 17. |
Table 0 — The six jurisdictional regions on the day FERC acted. Responses and briefs are due August 17, 2026, except where a region obtains the 90-day abeyance the orders permit — ISO-NE has said it will ask and CAISO's published schedule assumes one; informational reports on generation adequacy were due July 20, 2026, and that deadline has now passed. What separates the regions is not whether they face the problem but how far each had travelled before the Commission set a common deadline.
Sources: FERC, six §206 show-cause orders, June 18, 2026 (EL26-67 et seq.; 195 FERC ¶ 61,211–61,216), and the operators’ own tariff filings.
Two features of that table matter more than the individual entries. Acting early produced a measurable regulatory benefit. SPP drew the narrowest findings because it had already built the machinery — the clearest evidence in the record that anticipatory tariff work changes a region’s regulatory exposure. The second is that the severity of FERC’s findings tracks tariff readiness rather than load growth. ISO-NE has almost no large-load provisions and drew a mild order; MISO, whose data-center growth FERC staff measure as the fastest in the country, drew a pointed one. Regions where the load has not yet arrived are untested rather than prepared.