Reference

References#

Update sources (v1.1, July 13–17, 2026)#

• FERC, Reliability Standard(s) Pertaining to Computational Load Integration, Docket No. RD26-7-000, 196 FERC ¶ 61,031 (July 16, 2026); FERC July 2026 open-meeting agenda, Item E-1. Coverage: Power Magazine; National Law Review; Daily Energy Insider.
• PJM Interconnection, Base Residual Auction reports for the 2025/2026 (July 30, 2024), 2026/2027 (July 22, 2025), 2027/2028 (December 17, 2025) and 2028/2029 (July 14, 2026) delivery years — the RTO clearing-price series $28.92, $269.92, $329.17, $333.44 and $325/MW-day, and the compressed auction calendar that placed two auctions in 2025 as PJM returned to a three-year-forward cycle. PJM Interconnection, 2028/2029 Base Residual Auction Report and news release, July 14, 2026 (138,318 MW UCAP; $325/MW-day; ~6.8 GW shortfall; ~525 MW new generation). Coverage: Utility Dive; PJM Inside Lines.
• Office of Governor Kathy Hochul, executive order establishing the first statewide hyperscale data-center moratorium, July 14, 2026; NY DPS Energize NY proceeding and GEIS. Coverage: Reuters; The Washington Post; CNBC.
• Ratepayer Protection Pledge, Presidential Proclamation 11014 (March 4, 2026); mid-July 2026 White House convening reported by Reuters and the Associated Press.
• Trump v. Slaughter, No. 25-332 (U.S. June 29, 2026), overruling Humphrey's Executor; Trump v. Cook (Federal Reserve carve-out). Analysis: Akin; Troutman Pepper Washington Energy Report; Congressional Research Service LSB11448.

Update sources (v1.2, July 20–21, 2026)#

• FERC, six §206 show-cause orders, June 18, 2026 (EL26-67 PJM; EL26-68 SPP; EL26-69 NYISO; EL26-70 MISO; EL26-71 CAISO; EL26-72 ISO-NE), 195 FERC ¶ 61,211–61,216, for the procedural calendar: interventions July 9; generation-adequacy informational reports July 20; abeyance requests August 3; responses and briefs August 17; stakeholder comments on or about September 16. FERC fact sheet and staff presentation, June 18, 2026. Coverage: Day Pitney; McGuireWoods; Baker Botts; Willkie; RMI.
• ISO New England, compliance notice on the FERC large-load show-cause order, June 29, 2026, stating that the ISO and the New England transmission owners intend to request a 90-day abeyance by the August 3 deadline. ISO Newswire.
• Ratepayer Protection Pledge, The White House, March 4, 2026 (seven signatories; commitments to fund new generation, pay for all new power delivery infrastructure upgrades, negotiate separate rate structures, and pay for contracted capacity whether used or not; no enforcement or audit provisions). Google, “Supporting the White House Ratepayer Protection Pledge” (March 4, 2026) and the Capacity Commitment Framework as applied in the Ameren Missouri / New Florence announcement (May 20, 2026). On the limits: Ari Peskoe, Harvard Electricity Law Initiative, on the 1994 transmission pricing policy and embedded-cost recovery of data-center-driven upgrades (April 2026); Brookings, on the absence of enforcement (July 2026); reporting that colocation operators were not signatories and that a wider pledge including utilities and developers is being convened.
• California ISO, Informational Report, Docket No. EL26-71-000, July 20, 2026 — integrated CEC/CPUC/CAISO planning framework and the 2022 memorandum of understanding; ~36 GW of generation and storage added January 2020–March 2026 (>16 GW storage); 6.8 GW added in 2025; CPUC procurement obligation of 24.8 GW (2021–2032) with >20 GW under contract to 2029; 2026 summer assessment surplus above 2.5 GW against a 1-in-10 LOLE standard; CEC data-center forecast of 1.8 GW by 2030 and 4.9 GW by 2040; 2025 WEIM peak of 130.1 GW, down 3.8% year on year, per the CAISO Department of Market Monitoring annual report; expedited Large Loads stakeholder calendar ending in a November 16, 2026 filing that assumes an abeyance. caiso.com
• PJM Interconnection, news release on the 2028/2029 Base Residual Auction, July 14, 2026 (138,318 MW UCAP; 10,864 MW FRR; 149,182 MW total; 6,831 MW short; 14.7% reserve margin; special backstop procurement to be sought for September); PJM CIFP Reliability Backstop Procurement proposal paper, June 30, 2026 (procurement window September 10 – October 9, 2026; cost allocated by forecast load additions). pjm.com
• FERC, 2025 State of the Markets (staff report, March 19, 2026) — source for the data-center growth figures used throughout: more than 50 GW of data-center capacity operating in the United States at the end of 2025, 24% compound annual growth nationally since 2020, and 43% in MISO, the fastest of any region. Every occurrence of the 43% figure in this report draws on this dataset. MISO large-load additions programme materials (three-part framework; 120-day approval target; ERAS, EPR and zero-injection interconnection agreements; new study process in development), misoenergy.org. MISO's July 20 filing in EL26-70 is reported by RTO Insider, “MISO to Design Dedicated Queue Process for Large Loads and Devoted Generation” (July 20, 2026) — new expedited study process outside the queue and a non-firm transmission service option; the filing itself had not been retrieved when this revision closed.

Organized by the section each source principally supports, following a consolidated list of the primary regulatory documents that anchor the report. This report uses a grouped-citation model rather than inline footnotes: to trace any quote, fact, or figure, find the section it appears in and consult that section's reference block below, plus the consolidated primary-documents list for any order, rule, or standard. Primary instruments are cited by name, docket, or number so a reader can retrieve them from the issuing agency's docket; secondary analyses and reporting include the retrievable link where one was used. Every headline figure in the report — the 438 GW queue, the capacity-cost shares, the 1,500 MW event, the load-growth series, the adequacy metrics — is sourced here to a primary filing or the reporting of one. This chapter is the complete provenance of the report. A note on citation form: dates given are issuance or effective dates as reported at the time of writing (mid-July 2026). Where a figure comes from secondary reporting of a primary filing, or where a number is disputed or metric-dependent (see the 128-vs-67 GW discussion at Figure D3), that is flagged at the point of use. Several proceedings were live as this report was prepared; readers should check the docket for subsequent orders, rehearings, and compliance filings. Primary regulatory documents (consolidated)

• FERC — Order No. 841 (Feb 2018); Order No. 845 (Apr 2018); Order No. 2222 (Sept 2020); Order No. 2023 (Jul 28, 2023) and 2023-A (Mar 21, 2024); Order No. 1920 / 1920-A / 1920-B (May 13, 2024) and Order No. 1977; §206 order on PJM co-located load (Dec 18, 2025), compliance order (Apr 16, 2026), rehearing (Jun 18, 2026); six §206 show-cause orders (Jun 18, 2026, Dockets EL26-67 et seq.; 195 FERC ¶ 61,211–61,216); order rejecting Tri-State's HIL tariff (Docket ER25-3316, Oct 2025); ANOPR (Docket RM26-4000, Oct 2025). FERC explainers and fact sheets at ferc.gov.
• NERC — Long-Term Reliability Assessment (Jan 2026); Level 3 Essential Action Alert (May 4, 2026); Reliability Guideline: Risk Mitigation for Emerging Large Loads (May 2026); gaps white paper (Mar 2026); Project 2026-02 Computational Loads (SAR Apr 1, 2026); Rules of Procedure computational-load registry proposal (comment through May 15, 2026); 2026 State of Reliability report (Jul 2026); Large Loads FAQ and Action Plan. nerc.com.
• ERCOT / PUCT — PGRR145 / NPRR1325 (Batch Zero, eff. Jul 11, 2026); NOGRR282 / NPRR1308; NPRR1180 / PGRR107; Market Notice M-B062326-01; 2024 Regional Transmission Plan (Dec 2024) and Permian Basin Reliability Plan; PUCT Project 58480 (16 TAC §25.370) and Project 58481 (16 TAC §25.194); SB6 / PURA §37.0561. ercot.com; interchange.puc.texas.gov.
• DOE — §403 directive to FERC (Oct 2025); §202(c) emergency backup-generation order for PJM (Jun 30, 2026).
• FERC, six §206 show-cause orders to the RTOs/ISOs, June 18, 2026 — PJM (EL26-67), SPP (EL26-68), NYISO (EL26-69), MISO (EL26-70), with CAISO and ISO-NE issued the same day; reported at 195 FERC ¶ 61,211–61,216. FERC news release, “FERC Launches Aggressive Targeted Action to Speed Large Load Integration.” Analyses: Akin; Vinson & Elkins; Willkie Farr & Gallagher; Day Pitney; McGuireWoods; Troutman Pepper.
• FERC, Docket No. RM26-4-000 — Interconnection of Large Loads to the Interstate Transmission System (DOE §403 ANOPR, October 2025; >3,500 pages of comments).
• Akin, “FERC Issues Landmark Show Cause Orders on Large Load Interconnection.” akingump.com/en/insights/blogs/speaking-energy
• Troutman Pepper, Washington Energy Report, analysis of the June 18 orders. troutmanenergyreport.com
• McGuireWoods, client alert on the six §206 show-cause orders, June 2026. mcguirewoods.com
• ERCOT PGRR145 / NPRR1325 (Batch Zero), effective July 11, 2026; Market Notice M-B062326-01; Preliminary Long-Term Load Forecast 2026–2032.
• PUCT Project 58480 (16 TAC §25.370) and Project 58481 (proposed 16 TAC §25.194), implementing SB6 / PURA §37.0561.
• EUCI, “Utilities adopt large-load tariffs …” (Enverus estimate that gating cut AEP Ohio requests roughly in half). euci.com Primer — demand growth and load categories (Figures D1–D2)
• Grid Strategies, National Load Growth Reports (2023–2025), via Utility Dive (“Five-year US load growth forecast surges … to 128 GW,” Dec 6, 2024): consistent FERC Form 714 five-year peak-growth series 23 → 39 → 67 GW (2022–24); the 128 GW headline adds ~61 GW of further planning-document updates; ~166 GW projected by 2030 in the 2025 report. gridstrategiesllc.com
• EIA, “After more than a decade of little change, U.S. electricity consumption is rising again” (Today in Energy) and “We expect rapid electricity demand growth in Texas and the mid-Atlantic” (July 31, 2025): ~0.1%/yr growth 2005–2020; 0.8%/yr 2020–2024; 2.2% forecast for 2025 and 2026. EIA, Annual Energy Outlook 2026: 2.1%/yr over the last five years after 15 years of nearly flat consumption. eia.gov. ITIF, “The United States Needs Data Centers …” (Nov 2025): ~760 GW July 2024 U.S. peak. itif.org
• Lawrence Berkeley National Laboratory, 2024 United States Data Center Energy Usage Report: 325–580 TWh/yr by 2030 (6.7– 12% of U.S. electricity); Goldman Sachs and S&P Global data-center demand outlooks (2025–26); BofA Global Research US grid transformation note.
• World Resources Institute, “Powering the US Data Center Boom” and “How to Manage Growing Electricity Demand in the US”; Bipartisan Policy Center, “Electricity Demand Growth and Data Centers: A Guide for the Perplexed” (Apr 2026); Belfer Center, “AI, Data Centers, and the U.S. Electric Grid” (Feb 2026). wri.org
• Rabobank/RaboResearch, “The US scrambles to meet surging power demand by 2030” (Jun 2026), citing EIA, ICF, ACP, Grid Strategies. rabobank.com

Section 1 — Load-forecasting methodology and forecast trend (Figures 10, D3)#

• PJM, 2026 Long-Term Load Forecast, issued January 14, 2026; Load Adjustment Request Implementation document (July 2025); PJM Inside Lines, “PJM's Updated 20-Year Forecast …” insidelines.pjm.com
• Utility Dive, “PJM trims near-term load forecast on stricter data center vetting” (Jan 15, 2026); Power Magazine coverage of the 2026 forecast. utilitydive.com
• PSE&G 2026 Load Forecast documentation (100% / 50% confidence tiers by request stage); NOVEC bottom-up forecast documentation, via PJM. pjm.com
• ERCOT, “Long-Term Load Forecast Update (2025–2031) and Methodology Changes” (Apr 2025); NPRR1180 / PGRR107; PUC Subst. Rule 25.101. ercot.com
• NERC, Long-Term Reliability Assessment (January 2026; +224 GW / ~69% ten-year summer-peak revision vs. 2024 LTRA).
• Grid Strategies National Load Growth Reports (2023–2025) and Utility Dive coverage for the FERC-714 five-year forecast-trend series (23/39/67 GW) in Figure D3. gridstrategiesllc.com
• EIA, Electric Power Annual — Table 2.5 (retail sales to ultimate customers, 2014–2024) for Table D1 and Figure D1; Tables 4.2.A and 4.2.B (existing net summer capacity by energy source, 2014–2024) for the capacity series in Figure D1; Table 4.6 (capacity additions and retirements, 2024). EIA, Short-Term Energy Outlook for the 2.2%/yr forecast and the 2025 capacity factors used in Table 2A. eia.gov

Section 2 — Resource adequacy and the development-timeline gap#

• MISO, Expedited Resource Addition Study (ERAS) and MTEP Expedited Project Review; Large Load Additions Workshop, January 30, 2026; IPWG materials, 2026.
• FERC Order No. 845, Reform of Generator Interconnection Procedures and Agreements, 163 FERC ¶ 61,043, Docket No. RM17-8-000 (April 19, 2018), and Order No. 845-A on rehearing — surplus interconnection service, defined as the unneeded portion of interconnection service established in an LGIA, such that total interconnection service at the point of interconnection would remain the same if the surplus service were used. Available only to the extent it requires no new network upgrades; the original interconnection customer and its affiliates hold priority; the surplus agreement terminates with the original. ferc.gov
• PJM Board CIFP-LLA Decisional Letter, January 16, 2026; PJM stakeholder approval of the reliability backstop procurement, June 30, 2026.
• Capacity accounting (Table 2A): PJM, ELCC Class Ratings for the 2026/2027 Base Residual Auction and the 2025 PJM Effective Load Carrying Capability and Reserve Requirement Study — assumed resource portfolio, effective nameplate against installed capacity by class. pjm.com
• Transmission build-out and usable capacity: ERCOT, Permian Basin Reliability Plan (PUCT-approved 2024–25) and the 765 kV Strategic Transmission Expansion Plan (ERCOT board, December 2025); ERCOT, 2024 Regional Transmission Plan — 345-kV Plan and Texas 765-kV Strategic Transmission Expansion (Jan 2025); Texas Public Policy Foundation, An Economic Assessment of the 765-kV Strategic Transmission Expansion Plan (2026) for the ~$33B capital total and the near-term zonal-flow finding; Burns & McDonnell BenchMark on MISO Tranche 2.1 ($21.8B, in service 2032–34); Utility Dive and Oncor/LCRA filings on route and mileage. FERC Order No. 881 (ambient-adjusted ratings, compliance July 12, 2025), Order No. 1920 (consideration of grid-enhancing technologies in regional planning), and the FERC explainer on dynamic line ratings; NYPA and PJM/AEP demonstrations for the reported 25% class of capacity gain. ercot.com; ferc.gov

Section 3 — Cost allocation and cost-shifting#

• Monitoring Analytics (PJM Independent Market Monitor), 2025 State of the Market Report for PJM (Mar 2026) and capacity-auction cost analyses: data-center load = $6.5B (40%) of the $16.4B December 2025 auction, ~$6.2B of it unbuilt. Two distinct totals circulate for the three auctions (2025/26–2027/28, $47.2B cleared): $21.3B (45%) for forecast data-center load above existing data-center load, and $23.1B (~49%) including existing data-center load. This report uses the former throughout. monitoringanalytics.com
• Utility Dive, “Data centers were 40% of PJM capacity costs in last auction” (Jan 7, 2026) and “‘Clear warning signs’ as PJM wholesale power costs jump 54%” (Mar 14, 2026). utilitydive.com
• IEEFA, “Projected data center growth spurs PJM capacity prices by factor of 10” (capacity-price series $28.92 → $329.17/MW-day). ieefa.org
• NRDC (Tom Rutigliano), “Building Data Centers Without Breaking PJM” (Sept 2025) — origin of the $163B-through-2033 and ~$70/month figures, on the assumption that the capacity price collar lapses after 2027/28; Synapse Energy Economics, ~$100B through 2033 assuming mitigation continues. nrdc.org
• FERC, Docket ER26-1556-000, order accepting PJM’s extension of the $325/$175 per MW-day price collar to the 2028/2029 and 2029/2030 Delivery Years (April 28, 2026); PJM, 2028/2029 Base Residual Auction results, July 14, 2026 ($16.4B cleared). Measured zonal bill impacts: IEEFA (~$18/mo western Maryland, ~$16/mo Ohio) and the D.C. Office of the People’s Counsel (~$10 of a $21/mo Pepco increase).
• Bloomberg, “Data Centers Added $6.5 Billion to Big US Grid's Power Cost” (Jan 5, 2026); Canary Media, “PJM's capacity costs hit record as grid falls short on supply” (Dec 18, 2025).
• Sierra Club, “Data Center State Policies, 2026” (stranded-asset and cross-subsidization framing); Union of Concerned Scientists on ~$4.4B of data-center-related transmission cost. sierraclub.org

Section 4 — Ride-through and dynamic performance#

• NERC, Level 3 Essential Action Alert (May 4, 2026); Reliability Guideline: Risk Mitigation for Emerging Large Loads (May 2026); gaps assessment (March 2026); large-load registration criteria (comment through May 15, 2026); Project 2026-02 SAR; incident reviews of the July 10, 2024 and January 2026 events.
• ERCOT NOGRR282 / NPRR1308 (large-load ride-through and dynamic modeling); NERC Data Center Load Modeling Workshop, September 15–16, 2026.
• ERCOT, “Inverter-Based Resource and Large Load Ride-Through Events: Background and Mitigation,” Reliability and Markets Committee, June 19, 2023. Primary source for two distinct events. The June 4, 2022 Odessa IBR disturbance cost 2,555 MW of generation and took frequency to 59.7 Hz. The December 7, 2022 west Texas large-load event removed about 1,600 MW, took frequency to 60.235 Hz, and needed 12 min 30 sec to recover; the same deck records it as a three-phase fault caused by a breaker failure, affecting a mix of data centers, oil and gas, and other industrial load. The deck also records ERCOT’s 2008 generator ride-through requirement and the five smaller west Texas events of October 2022. ercot.com
• NERC, Incident Review: Voltage-Sensitive Crypto Load Reductions (January 9, 2026) — 26 events of indirect load loss above 100 MW between January 2023 and September 2025, reductions of 17% to 95% of pre-disturbance consumption, sensitivity below roughly 0.7 per unit single-phase, and the four mechanisms behind the trips: neutral overcurrent protection, wye-wye rather than delta-wye transformation, constant-power overcurrent, and cooling-drive undervoltage settings as high as 0.96 per unit. NERC defines indirect load loss as loss not attributable to the outage of the connecting line. Also: ERCOT Large Flexible Load Task Force, March 4, 2025, for the delayed-clearing character of the December 2022 west Texas event and the substantial oil and gas share of it.
• Voltage-sensitivity mechanism: NERC, Incident Review — Considering Voltage-Sensitive Crypto Load Reductions and the July 2024 Eastern Interconnection incident review, for the switched-mode power supply front end, the ITIC (formerly CBEMA) tolerance curve and its 20-millisecond allowance at 0.7 per unit, the behaviour of static and diesel-rotary uninterruptible supplies, and the finding on neutral overcurrent protection and transformer winding configuration. IEC 62040-3 for the 0.7–0.8 per unit transfer threshold within one to three cycles. nerc.com
• Event record (Table 4A): ERCOT, Large Load Loss/Reduction Events 2020–2024 (Performance, Disturbance and Compliance Working Group, November 19, 2024) — dated events, magnitudes, fault types and clearing times for October 12 and 31, 2022, December 7, 2022 and January 23, 2023. NERC, Incident Review: Considering Simultaneous Voltage-Sensitive Load Reductions (Jan 2025) for the July 10, 2024 event, and the two January 2026 incident reviews of crypto-mining load reductions. ERCOT Large Load Working Group, September 19, 2025 — the ~2,600 MW instantaneous load-loss threshold from the 2030/31 study case. ESIG, “Engaging with Large Loads” (Nov 2025) — ERCOT’s reduction of System Operating Limits and its characterisation of event impacts to date as minimal. nerc.com; ercot.com; esig.energy

Section 5 — Co-location, BTM, and electrically proximate load#

• FERC, §206 order on PJM co-located load, PJM Interconnection, L.L.C., 193 FERC ¶ 61,217, Docket Nos. EL25-49-000 et al. (December 18, 2025); April 16, 2026 compliance order; order on rehearing (June 18, 2026). Show Cause Order, 190 FERC ¶ 61,115 (February 20, 2025), which consolidated the AD24-11-000 technical conference of November 1, 2024 and Constellation's complaint in EL25-20-000. Paper-hearing schedule: PJM initial brief February 16, 2026; responses March 18; replies April 17.
• ERCOT NPRR1325 (WLPUN / PCLR; Form X / Form W); SPP HILL process, approved by FERC January 2026.
• American Bar Association, Infrastructure & Regulated Industries Section, “The Jurisdictional Collision over Large Loads and Data Center Interconnection” (Spring 2026). americanbar.org
• FERC fact sheet and order, PJM Interconnection, L.L.C., 193 FERC ¶ 61,217, Docket Nos. EL25-49-000 et al. (December 18, 2025), for two points relied on here. The order requires the Eligible Customer serving co-located load to choose among four transmission service options: NITS; a new interim non-firm service open only to customers seeking NITS, running until the network upgrades behind that request are complete; a new Firm Contract Demand service; and a new Non-Firm Contract Demand service. And the order expressly declines to address jurisdictional matters regarding the interconnection of retail loads served through a co-location arrangement (Section 7). A separate reliability informational report from PJM fell due January 19, 2026. ferc.gov
• FERC, PJM Interconnection, L.L.C., 189 FERC ¶ 61,078, Docket Nos. ER24-2172-000 and ER24-2172-001 (November 1, 2024) — order rejecting the Susquehanna amended ISA, with the Phillips dissent and Christie concurrence attached; rehearing denied, ER24-2172-002 (April 2025). The order supplies the 300 MW / 480 MW / 960 MW figures, the 2023 ISA history, the November 2023 fallback event, and the Exelon/AEP cost-shift estimate of up to $140 million a year — which Susquehanna answered as forgone retail revenue under the PPL LP-5 tariff rather than a shift of incurred cost. ferc.gov
• FERC, 195 FERC ¶ 61,162 (June 1, 2026) — one-time limited waiver transferring 760 MW of Capacity Interconnection Rights from Eddystone Units 3 and 4 to the Crane Clean Energy Center, granted over the protest of the PJM Independent Market Monitor on all four waiver criteria. Constellation's waiver request of March 31, 2026 states the December 2030 upgrade date and the second-half-2027 restart target. Related: DOE section 202(c) orders keeping Eddystone online as an energy-only resource from May 2025.
• Talen Energy Corporation, Form 8-K and press release, “Talen Energy Expands Nuclear Energy Relationship with Amazon” (June 11, 2025) — 1,920 MW at full contract quantity through 2042, full volume no later than 2032, transition to front-of-the-meter service at the spring 2026 refuelling outage, with PPL Electric Utilities responsible for transmission and delivery. Constellation Energy, “Constellation to Launch Crane Clean Energy Center” (September 20, 2024) for the twenty-year Microsoft agreement and the absence of any co-located data center. sec.gov
• Behind-the-meter generation (Table 5A): unit size ranges are the standard class ratings for reciprocating gas engines, aeroderivative and frame turbines, fuel cells, storage and standby diesel as deployed at data-center scale, and are given as indicative engineering ranges rather than as a survey of installed projects. Proximity: FERC’s June 18, 2026 orders introducing “electrically proximate” large load and the two-substation working example.

Section 6 — Flexible and curtailable load#

• Nicholas Institute, Duke University, “Rethinking Load Growth” (Norris et al., Feb 2025) — curtailment-enabled headroom across the 22 largest balancing authorities, which serve 95% of US load: 76 GW at 0.25% of maximum uptime, ~100 GW at 0.5%, 126 GW at 1%, i.e. roughly 22, 44 and 88 hours a year, with an average curtailment event near two hours.
• Berkeley Lab data-center demand range; Goldman Sachs demand outlook (May 2026); ICF load-flexibility analysis (June 2026); GridLab/Telos NV Energy case study.
• Norris et al., Rethinking Load Growth, and the Nicholas Institute webinar deck of February 19, 2025, for the basis of the figures used here. The study defines the curtailment rate as annual curtailed MWh divided by the new load’s maximum potential annual consumption. Headroom on that basis: 76 GW at 0.25%, 98 GW at 0.5%, 126 GW at 1%, 215 GW at 5%. Hours in which any curtailment occurs: 85, 177 and 366. Average event duration: 1.7, 2.1 and 2.5 hours. Retention: at least half the new load in 88% of curtailment hours, three-quarters in 60%, nine-tenths in 29%. The study adds a constant new load in all hours against each balancing authority’s maximum observed seasonal peak, and its stated limitations list network constraints first among the factors that would reduce the estimate, with unused reserve capacity among those that would raise it. The authors describe the result as a first-order estimate and set out a research plan to recompute it with the transmission network represented. nicholasinstitute.duke.edu
• EPRI, DCFlex initiative — pilot finding that 10–40% load modulation is achievable without breaching service-level agreements, reported in ITIF, “The United States Needs Data Centers, and Data Centers Need Energy” (Nov 24, 2025); EPRI DCFlex Regulatory, Policy and Technology Trends Digest (Sept 8, 2025) for the filed structure of the I&M–Google demand-response product (unlimited curtailments, 12-hour summer and 15-hour winter duration caps). epri.com; itif.org
• Indiana Michigan Power and Google, special contract, IURC Cause No. 46276 (filed July 30, 2025; approved 2026) — Clean Capacity Arrangement plus custom demand response, with credit amounts and contract capacity redacted; Citizens Action Coalition Exhibit 1 (Oct 23, 2025) objecting to the scope of confidential treatment and the absence of a public ratepayer-impact analysis. Google, “Signed 1 GW of data center demand response” (Mar 2026) and “How we’re making data centers more flexible” for the I&M, TVA, Entergy Arkansas, Minnesota Power and DTE agreements and the earlier Omaha Public Power District demonstration. iurc.portal.in.gov; blog.google
• Demand response in the capacity market: PJM, “PJM Auction Procures 134,479 MW of Generation Resources” (Dec 17, 2025) — demand response at about 5% of the cleared supply mix, and cleared DR rising from 5,531 MW to 7,299 MW between the 2026/27 and 2027/28 auctions following the ELCC accreditation reform approved by FERC in May 2025, with offered megawatts essentially unchanged. pjm.com

Section 7 — Jurisdiction and the non-RTO grid#

• FPA §201(b); FERC order rejecting Tri-State Generation & Transmission's High Impact Load tariff, 3–0 (Docket ER25-3316, October 2025).
• Utility Dive, “FERC rejects Tri-State's large load tariff over retail jurisdiction issues”; and coverage of NARUC / NCSL comments in RM26-4-000. utilitydive.com
• Mintz, “FERC Decision Highlights Jurisdictional Limits on Large Load Tariffs.” mintz.com
• Balch & Bingham, “FERC's Regional Path for Large-Load Integration.” balch.com/insights
• Womble Bond Dickinson, “Federal–State Jurisdictional Issues Raised by Data Centers and Large Load Interconnections.” womblebonddickinson.com
• Snell & Wilmer, “FERC Sets June Action on DOE's Large Load Interconnection Plan.” swlaw.com
• RTO Insider, “FERC Rejects Tri-State's High Impact Load Tariff.” rtoinsider.com
• PUCO approval of the AEP Ohio data-center tariff (≥25 MW; 85% minimum take; 12-year term), 2025.
• Virginia SCC, Case PUR-2025-00058 (Dominion GS-5 rate class); Georgia Power PLL-18; Pennsylvania PUC model tariff (2026).
• Latitude Media, “The unsettled landscape of large-load tariffs.” latitudemedia.com
• Columbia Climate Law Blog, “What Local Governments Should Know about Large-Load Tariffs” (EEI count: 23 states approved, 7 pending as of May 2026). blogs.law.columbia.edu/climatechange
• Smart Electric Power Alliance tariff survey (65 tariffs across 34 states, 2025), via Latitude Media.
• Buckeye Institute, “Undermining Ohio's Competitive Edge”; Ohio Statehouse News Bureau coverage of the AEP Ohio tariff. buckeyeinstitute.org
• electroneconomics, “The Tariff Lottery” (Georgia Power 11 GW under contract; developer-side ramp-risk analysis). electroneconomics.substack.com

Section 8 — Off-grid and islandable load#

• NERC, 2026 State of Reliability report (released July 2026); documented 2025 customer-initiated load-loss events (~1,800 MW February, ~1,300 MW June; nine ERCOT crypto events >100 MW); Jim Robb “five-alarm fire” remark.
• Wall Street Journal, Jennifer Hiller, coverage of the NERC State of Reliability report (July 3, 2026), as reported.
• Data Center Knowledge, “NERC Flags AI Data Center Grid Risks in Report” (registration category; PERC1 model). datacenterknowledge.com
• Ascend Analytics, “Can US Interconnection Queues Survive Data Center-Driven Load Growth?” (BTM gas as stopgap; LCOE vs. ERCOT forward price), May 5, 2026. ascendanalytics.com
• EUCI, on AEP subsidiaries' ~750 MW of stranded generating capacity acquired for data centers that did not materialize. euci.com
• NERC, Level 3 Essential Action Alert (May 4, 2026) and Reliability Guideline (May 2026) on behind-the-meter resources and coordinated islanding; Carbon Direct and Utility Dive analyses. carbon-direct.com

Section 9 — 2018–2035 timeline#

• FERC, Order No. 841 (Feb 2018), Order No. 845 (Apr 2018), Order No. 2222 (Sept 2020), Order No. 2023 (July 28, 2023) and Order No. 2023-A (Mar 21, 2024), Order No. 1920 and Order No. 1977 (May 13, 2024); FERC explainers and fact sheets. ferc.gov
• ERCOT, Large Flexible Load Task Force (established 2022); 2024 Regional Transmission Plan (Dec 2024) with 345 kV and 765 kV STEP; Permian Basin Reliability Plan (PUCT-approved Oct 2024); Baker Botts, “Bitcoin and Large Loads in ERCOT” (2022 LFLTF origin). ercot.com
• NERC, Project 2026-02 Computational Loads (SAR posted Apr 1, 2026; “bridge” standard targeted year-end 2026; broader standards from 2027); Large Loads FAQ and Rules of Procedure computational-load registry proposal. nerc.com
• NERC, 2025 Long-Term Reliability Assessment (published January 2026): PJM high-risk from ~2029 and ~210 GW summer peak by 2035; MISO elevated/high-risk from 2027–2028 and ~18 GW data-center load by 2035. nerc.com
• DOE, Section 202(c) emergency order directing backup-generation availability in PJM (June 30, 2026). pjm.com
• White & Case, Crowell & Moring, K&L Gates — order-by-order dating of FERC Orders 2023 and 1920. Section 9 — the four clocks: supply chain and political economy (Figure 15)
• GE Vernova, Q1 2026 results (Apr 22–23, 2026): combined gas backlog and slot-reservation agreements grew from 83 to 100 GW (slot reservations 43→56 GW), targeting ≥110 GW by year-end 2026; data-center electrification orders of $2.4B in Q1. SEC Form 8-K; Power Engineering; Industrial Info Resources. sec.gov
• Utility Dive, “GE Vernova expects to end 2025 with an 80-GW gas turbine backlog that stretches into 2029” (Dec 11, 2025); electroneconomics, “Slotting In the Future: Gas Turbine Reservations and the AI Power Land Grab” (Dec 15, 2025) — slots sold out through 2027, delivery conversations at 2029–30; Siemens lead times exceeding 40 months. utilitydive.com
• MultiState, “State Data Center Legislation in 2026” and “Federal AI Data Center Policy Meets Resistance” (Apr 2026): 300+ datacenter bills across 30+ states in 2026; ≥18 states on separate rate classes; 11 states on moratoriums. datacenterbans.com for the New York Responsible Data Center Development Act (passed Jun 4, 2026), New Jersey Data Center Fair Share Act (signed Jul 7, 2026), Virginia $0.011/kWh tax (eff. Jul 1, 2026). multistate.us
• Brookings, “The pledge to protect ratepayers from AI data center costs needs enforcement” (Jul 2026): ≥48 projects (~$156B) blocked or stalled by local opposition in 2025; Ratepayer Protection Pledge (Mar 4, 2026), seven hyperscaler signatories; White House expansion reported by Reuters (Jul 13, 2026). brookings.edu

International experience#

• Ireland — CRU Large Energy User Connection Policy Decision Paper (Dec 2025) ending the 2021 de facto moratorium; 100% onsite generation, 80% renewable matching, siting rules for >10 MVA; EirGrid Large Demand Facility Fault-Ride-Through Grid Code recommendation (Apr 1, 2026). Data centers ~22% of 2024 metered demand, ~31% projected by 2034; Dublin ~1,150 MW. William Fry, Arthur Cox, DC Byte, KPMG Ireland; EirGrid Winter Outlook 2025/26. cru.ie
• Netherlands — TenneT congestion declarations (zero large-connection headroom in much of Noord-Holland to ~2036; 5+ GW queues); shift toward flexible/non-firm connections and mandatory congestion management; 9 GW off-peak capacity vs. 70+ GW of applications; battery “congestion mitigator” contracts. RAP, “Gridlock in the Netherlands” (2024); Taylor Wessing; EnergyStorage.news (Apr 2026); Mordor Intelligence. tennet.eu
• Singapore — 2019 moratorium; 2022 pilot allocation; IMDA Green Data Centre Roadmap (May 2024) releasing ≥300 MW gated on PUE < 1.3 and ≥50% green power. DatacenterDynamics; IMDA; Mordor Intelligence. imda.gov.sg

Technical Annex (distribution and planning paradigms, Figure T6)#

• Distribution-system impacts (T.9): EPRI hosting-capacity analysis frameworks; NERC and IEEE guidance on large-load distribution interconnection, service-transformer loading, voltage regulation, harmonics, and reverse power flow; utility distribution interconnection screens.
• Planning paradigms (T.10): deterministic vs. probabilistic planning and production cost modeling (e.g., chronological unit commitment/economic-dispatch tools); NERC ProbA methodology; the deterministic TPL-001 contingency framework alongside probabilistic LOLE/EUE adequacy studies (cross-referenced to T.3, T.6, T.7).

Technical Annex (Figures T1–T5)#

• Schneider Electric, “The new power dynamic: AI data centers begin at the UPS” (Jul 2026); OPAL-RT, “AI workload variability and its impact on data center power stability” (Mar 2026); Oracle Cloud, “GPU Power Smoothing for Large-Scale AI Training” (Mar 2026). blog.se.com
• Peer-reviewed / preprint: “Wide-Area Power System Oscillations from Large-Scale AI Workloads”; “Modal Analysis of Spatial Load Correlation in AI Data Center-Dominated Power Systems”; “EasyRider: Mitigating Power Transients in Datacenter-Scale Training Workloads” (Stanford); “Power for AI Data Centers” (Energies, MDPI, Jan 2026). GPU swing 30–150% in ms; >1,000 MW/s aggregated; 14.7 Hz forced-oscillation observation. arxiv.org
• NERC — Reliability Guideline: Developing Load Model Composition Data (WECC CMPLDW); Level 3 Essential Action Alert: Computational Load Modeling (May 2026, requiring PERC1 or equivalent, EMT at weak-grid POIs; TPL-001 non-consequential load-loss expectations); Data Center Load Modeling Technical Reference and PERC2 specification (in development). TPL-001-5.1 planning standard. nerc.com
• Keentel Engineering, NERC Large Loads Action Plan and SPP HILL process guides (study sequence: load-flow, short-circuit per TPL-001-5.1, RMS dynamic, EMT/SCRCCT screen); ERCOT “Officer Letter Loads” attestation practice. keentelengineering.com
• Resource adequacy (T.6): NERC 2025 Long-Term Reliability Assessment (Jan 2026) and 2026 Summer/2025–26 Winter Reliability Assessments — LOLE 0.1/yr standard, LOLH, EUE, PRM/ARM, ProbA methodology; ERCOT ELCC switch and DR rising to ~53 GW by 2030; MISO PY2026–27 LOLE Study (PRM 7.9% summer / 18.9% winter). NERC “Assessment of Gaps” white paper (Mar 2026). nerc.com
• Capacity accreditation of co-located load-plus-resource systems: “Risk-Based Capacity Accreditation of Resource-Colocated Large Loads in Capacity Markets” (2025); PJM Manual 20A, Resource Adequacy Analysis. arxiv.org
• Scenario analysis & reliability assessment (T.7–T.8): NERC May 2026 Reliability Guideline (probabilistic scenarios across weather/load/outage on a network-aware footprint); Carbon Direct, “Inside NERC's Level 3 Alert on data center loads” (May 2026); Grid Strategies and EPRI growth-scenario framing; TPL-001-5.1 contingency categories P0–P7. carbon-direct.com