What's Happening in Energy highlights the most interesting findings from public utility commission filings.
Hey there, it's Nat.
This week:
10 points of interest below.
What's Happening in Energy — Aug 21
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Modeling Large Load Tariff Revenues // Rocky Mountain Institute // Colorado
RMI modeled the split in revenues between energy/demand charges and riders across multiple large load tariffs using a 300 MW test load at a 100% load factor. Across the tariffs, total revenues ranged from $150 to $300 million, and portions of total revenues recovered from demand/energy charges ranged from 35% to 85%. RMI shared the results in a Colorado PUC proceeding evaluating Public Service Company of Colorado’s (Xcel) large load tariff Schedule TL. It turns out that Schedule TL brings in a comparably high portion of revenue from riders compared with other large load tariffs. The fuel cost adjustment alone constitutes 51.7% of revenues.
Here are the exact numbers.
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Cost Shifting // FERC Show Cause Compliance // Southwest Power Pool
SPP’s Cost Control and Allocation Review & Evaluation Team (composed of state commissioners, utilities, and other stakeholders across the RTO footprint) is discussing a proposal to comply with the cost-shifting concerns FERC raised in the Show Cause Orders. One of the team’s recommendations is to establish a “safe harbor” of network upgrade costs for High Impact Large Loads (HILLs) that would cap the costs transmission customers would be responsible for paying through normal Base Plan funding. Beyond this safe harbor, HILLs would directly assign the remaining costs and charge a financial security. Read through the proposal here.
Halcyon angle: Halcyon has SPP’s stakeholder groups organized so that meeting materials are easy to track. If you have ever set an alert on a commission docket, this will feel familiar. Set an alert on key groups like the Market Working Group, the Markets and Operations Policy Committee, and the Cost Control and Allocation Review & Evaluation Team by clicking “Create alert” in the top right.
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Abeyances Granted // FERC Show Cause
6-for-6. That’s how many Motions for Abeyance FERC granted, giving the RTOs 90 more days to respond to the Show Cause Orders with tariff revisions for interconnecting large loads more justly and reasonably. The clock started on August 18th. Responses are due by November 16th, but we expect RTOs to respond at different times depending on the pace of their relevant stakeholder group discussions.
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More on Cost Shifting // Microsoft // Wisconsin // ATC // WEPCO
The Public Service Commission of Wisconsin (PSCW) commented on a filing that American Transmission Company (ATC) submitted with FERC seeking approval of its Large Load Project Commitment Agreements (LLPCAs) with its affiliate Wisconsin Electric Power Company (WEPCO).
The LLPCAs set the terms for recovering the cost of transmission network upgrade projects intended to serve Microsoft’s Racine County data center (a “Very Large Customer,” or VLC, in Wisconsin regulatory speak). While the PSCW was supportive of the revised agreements, they expressed concerns about cost shifting. For example, according to modeling from the Commission, directly assigning costs would recover $441 million more from a large load than “zonal” cost allocation by load ratio share (see table below). ATC’s other wholesale customers would be on the hook for the difference. Note the distinctly non-linear difference in the 4-9 year range (that is, sometime after 2028). It’s the only redacted interval, and it is when the difference in costs spikes the most (585%!).
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Staff Recommendation to Return IRP // NorthWestern Energy // Montana
The Montana Public Service Commission’s staff recommended that the Commissioners return NorthWestern Energy’s 2026 IRP because it failed to satisfy multiple statutory requirements, like assessing resource adequacy and risk under variable conditions, explaining modeling assumptions, and integrating demand response market potential. The Commission had similar concerns about the lack of modeling transparency in the 2023 IRP process. Staff’s memo included comments from this period:
“As the Commission noted in its comments on the 2023 IRP, PowerSIMM’s proprietary nature 'necessitates extraordinary efforts by NorthWestern to ensure statutory requirements designed to promote transparency and trust in the planning process are met.'”
Staff recommended giving NorthWestern 30 days to address the deficiencies. Read the full Staff recommendation here.
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AI Provision in Protective Orders // Evergy // Kansas Corporation Commission
Evergy proposed language for its Protective Orders that would govern how parties can use AI tools when handling confidential information. The utility responded to concerns raised by the Citizens’ Utility Ratepayer Board (CURB) that these provisions would essentially give the utility asymmetric leverage over the use of AI in proceedings:
From Evergy’s perspective, the fact that 314 Evergy proceedings, many of which contained confidential information of Evergy and other parties, have passed since the launch of Chat GPT underscores the need for these protections to be put in place as soon as possible. The Protective Order’s current provisions around confidential information can be sound and still benefit from an express statement of how those provisions apply to AI Tools that invite inadvertent violations.
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Comments on Alabama Large Load Proceeding // Gulf States Renewable Energy Industry Association (GSREIA)
The Gulf States Renewable Energy Industry Association (GSREIA) filed a petition for leave to intervene in the Alabama proceeding to establish a process for the state commission to review contracts between Alabama Power and large loads. The filing included GSREIA’s initial comments, which clearly articulated the threshold to distinguish what information should be protected and information that should be public.
Transparency and legitimate commercial confidentiality can both be served. GSREIA recommends a two-tier approach: a public version of every filing—including the cost-of-service methodology, the categories and magnitudes of incremental cost, the benefit analysis, and the required findings—should be placed on the public docket, while genuinely sensitive, competitively harmful specifics (for example, customer-identifying details or negotiated unit pricing) may be filed under a standard protective order and made available to Staff, the Attorney General, and reviewing parties who execute appropriate confidentiality undertakings.
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More on Data Center Forecasting Assumptions // California Energy Commission
At Halcyon we never tire of parsing the assumptions behind data center load forecasts. The California Energy Commission is back at it: CEC Staff shared one of the more concise representations of data center forecasting math we’ve seen. Loads at different stages of development enter the funnel, are filtered by confidence levels, load factors, and ramp rates, and then exit as megawatts to include in the forecast.
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Data Center Load Forecasting // Resource Planning // Duke Energy Carolinas
Duke Energy Carolinas’ appendices for its 2026 Integrated Resource Plan clarified how the utility integrates large loads based on development pipeline stage: electric service agreements (“ESAs”), letter agreements (“LAs”), and late‑stage pipeline projects. Data center load receives a higher discount than manufacturing load, and even data center load with an ESA gets a 25% trim. Check out the section in the appendix here.
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Our Favorite Acronym // ZGIA // MISO // FERC
It’s happening: our favorite acronym is all grown up! MISO filed its proposed tariff at FERC to implement the Zero-Injection Generation Interconnection Agreement (ZGIA) framework. Set an alert on the docket here. ZGIA has made its way through the MISO stakeholder process and now forms a prominent part of the organization’s response to FERC’s Show Cause Order, which specifically called on ISO/RTOs to revise their study processes for co-located large loads.
Halcyon angle: Halcyon has all of MISO’s stakeholder groups organized in the platform. Follow the Large Load Working Group on Halcyon.
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New Docket of the Week
The PJM proceeding to establish an Interim Resource Adequacy Service (IRAS) and Large Load Registry opened at FERC. IRAS, once known as Connect and Manage, would allow large loads to interconnect prior to receiving firm transmission service. Follow along by clicking “Create alert” in the top right.
Excerpt(s) of the Week
In Texas, a public commenter (Lewis McLain plus a little help from AI) shared a “fact check & analysis” of an article in the Austin American-Statesman on the 765-kV buildout. We’re just leaving the cover page here.
Most clicked item from last week’s WHiE