The ANOPR does not specify detailed terms and conditions for large load interconnections, leaving those to the FERC rulemaking process.

On October 23, 2025, U.S. Energy Secretary Chris Wright issued an advance notice of proposed rulemaking (ANOPR) directing the Federal Energy Regulatory Commission (FERC) to develop rules for interconnecting large electric customers, such as data centers and hybrid facilities (i.e., combining a generator and a large load) that have peak demand of 20 megawatts (MW) or higher. Large load interconnections, especially those involving data centers and their colocation with generating resources, currently are a hot topic in several pending FERC proceedings involving proposals by individual utilities and regional transmission organizations (RTOs), as well as various generic inquiries. Due to their size and rapid growth, these facilities strain the interstate electric grid, resulting in reliability issues and requiring expensive transmission system upgrades. To respond to these challenges, the ANOPR initiates a rulemaking to develop a standardized set of procedures that would be applicable across the board, on a more or less uniform basis, to all “public utilities” and RTOs with FERC open access tariffs.

Traditionally, FERC has not exercised jurisdiction over end-user interconnections, including to the FERC-regulated interstate electric transmission grid. Instead, individual utilities are responsible for such interconnections, usually under the oversight of state utility regulators. The ANOPR, however, asserts FERC jurisdiction over large load interconnections under the Federal Power Act (FPA) because: (1) like generator interconnections, large load interconnections are a critical component of open access transmission service requiring minimum terms and conditions to ensure nondiscriminatory transmission service; (2) the interconnection of large loads to the transmission system falls under a practice “directly affecting” FERC-jurisdictional wholesale electricity rates under the FPA; (3) the proposal will not impinge on states’ authority over retail electricity sales; and (4) according to the ANOPR, any contrary view of the proposed reforms conflicts with the FPA’s core purposes.

The ANOPR does not specify detailed terms and conditions for large load interconnections, leaving those to the FERC rulemaking process. Instead, it sets forth 14 principles for the FERC rulemaking as follows:

1. To comply with the FPA’s division between state and federal authority, FERC’s jurisdiction will be limited solely to interconnections directly to transmission facilities, consistent with FERC’s technical “seven-factor test” that distinguishes between transmission and distribution facilities.
2. The reforms will apply to new loads greater than 20 MW; however, alternative thresholds could be proposed in the rulemaking process.
3. Load and hybrid facilities should be studied together with generating facilities “to the extent practicable.” This principle suggests that the new rules could be integrated with the existing generator interconnection procedures rather than having to be a set of separate procedures.
4. Under the rules, load and hybrid facilities should be subject to standardized study deposits, readiness requirements and withdrawal penalties similar to generating facilities, but alternative requirements could be proposed.
5. Hybrid facilities should be studied based on the amount of injection and/or withdrawal rights requested.
6. Any hybrid interconnection will be required to install the system protection facilities necessary to prevent unauthorized injections or withdrawals that exceed the respective rights.
7. The interconnection study of large loads that agree to be curtailable and hybrid facilities that agree to be curtailable and dispatchable should be expedited. The ANOPR invites comments on whether this should be accomplished through a serial interconnection study process or by some other means and on other specifics, such as deadlines and any expedited process.
8. Load and hybrid facilities should be responsible for 100 percent of the network upgrades that they are assigned through the interconnection studies. Comments are invited on whether such costs should be offset through a crediting mechanism and, if so, over how many years.
9. To the extent the interconnection customer is not the transmission owner, the interconnection customer will be afforded the same (or equivalent) option to build as currently provided to generator interconnection customers.
10. An existing generating facility that seeks to enter a partial suspension to serve a new load at the same location must go through a system support resource/“reliability must run” type study, which must consider system conditions, including forecasted load growth, at least three years after the proposed suspension date. The partial suspension can only proceed after any network upgrades needed to ensure reliability are placed into service. Any such network upgrades would be the responsibility of the generating facility.
11. Utilities serving large loads, including those at hybrid facilities, should be responsible for transmission service based on their withdrawal rights, as that value amount reflects the quantity of capacity and energy that is being transmitted across the transmission system to the load.
12. Utilities serving large loads, including those at hybrid facilities, should be responsible for ancillary services based on peak demand, without consideration of any colocated generation. Any colocated generating facilities will similarly be fully compensated for the provision of ancillary services.
13. There must be a plan to implement these proposed reforms, including with respect to transition.
14. Utilities serving large loads must meet all applicable North American Energy Reliability Corporation reliability standards and open access tariff provisions.

While the 14 principles outlined above provide some key parameters, they do not specify detailed rules or pro forma interconnection agreements. Those will be developed as part of the FERC rulemaking process. Some of the key issues in that process will be: how to address reliability and cost allocation challenges associated with large load interconnection; how to integrate the proposed large load interconnection rules with the existing generator interconnection procedures; and how much flexibility to grant to individual RTO regions and utility systems in developing their own large load rules. Notably, the ANOPR states that it is not intended in any way to discourage public utilities from making filings with FERC to address these and similar issues.

Given the complexity of the issues, participating in the ANOPR and subsequent rulemaking process will be critical for all interested parties as it will determine the shape and content of the final rule. FERC has established the following comment due dates: November 14, 2025, for initial comments and November 28, 2025, for reply comments.

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