22 years ago, FERC issued Order 2003, establishing the first standardized process for generator interconnection. Last month, the Department of Energy asked the Commission to take the next step, by doing the same for large loads.

On October 23, U.S. Secretary of Energy Chris Wright referenced Section 403 of the Department of Energy Organization Act to formally direct FERC to consider an advance notice of proposed rulemaking (ANOPR) on load interconnection reform. If FERC moves forward, this could reshape how utilities manage interconnection for large loads -- from datacenters to industrial facilities -- and bring long-overdue consistency to a process that is currently fragmented and opaque.

What the Proposed Rule Could Do

If issued, the ANOPR would:

• Extend FERC oversight to portions of the load interconnection process in vertically integrated states.

• Standardize study procedures across utilities to create a common analytical framework.

• Require colocated generation and load to be studied together, recognizing how behind-the-meter generation can offset system stress and avoid unnecessary upgrades.

• Explore an expedited study path for curtailable loads, including seeking comment on whether such studies could be completed in 60 days.

Together, these steps could form the foundation for a more consistent, data-driven process that capitalizes on the opportunity of colocated resources and fast-growing load.

The Jurisdiction Question

The legal debate centers on who has the authority to oversee load interconnection.

Under the Federal Power Act, FERC regulates transmission and wholesale sales of electricity, as well as “practices affecting transmission rates.” States, meanwhile, regulate generation, distribution, and retail sales.

In vertically integrated states, utilities have traditionally handled load interconnections under state commission oversight. FERC has never asserted jurisdiction in this area. But as large-load requests increasingly drive new transmission investments, there’s a growing argument that FERC should have authority over this part of the process.

In non-vertically integrated regions where ISOs and RTOs already manage the grid, FERC’s authority is well established, so this rule would mainly formalize or harmonize existing practice.

What It Means for the Industry

For utilities:

• A standardized framework could reduce case-by-case interpretation, improve defensibility, and streamline study coordination.

For large-load customers:

• More predictable timelines and potential fast-track options would lower cost uncertainty and open doors for colocated or flexible-load projects.

For ratepayers:

• Costs of any network upgrades identified in the interconnection study process are proposed to be assigned 100% to the interconnecting large-load or hybrid customer

For developers:

• Unified generation-load studies would make it easier to identify where colocated projects can balance system stress instead of exacerbating it.

What It Means Going Forward

If FERC accepts DOE’s proposal, the Commission is expected to take final action no later than April 30, 2026. The details are still to come (How prescriptive the rule will be? Which utilities it will cover? How will states respond?) but the overall direction is clear.

The reforms proposed in the DOE's ANOPR will fundamentally change how utilities and ISOs evaluate oncoming loads. For example, the ANOPR proposes that hybrid facilities (co-located generation and load) be studied together, rather than as separate withdrawal and injection points. This will require an entirely different modeling approach from the static power flow studies that ISOs and utilities currently run to study generation and load in separate, siloed processes.

These aren't hypothetical changes on a distant horizon. As utilities adapt their processes, developers who wait for clarity will fall behind. Nira's team of transmission experts is already prepared to model transmission capacity under these evolving frameworks, giving you an independent view of available capacity without waiting months for utility feedback.