What's Happening in Energy highlights the most interesting findings from public utility commission filings.
One year. 38,000 emails opened. One very full and caffeinated newsletter.
What's Happening in Energy (WHiE) is officially 1 year old!
If you have been following along these past 365 days, you may have noticed that energy regulation hasn't exactly mellowed with age — it's gotten louder. So we’re using this week to look back at twelve months of proceedings, utility filings, procedural steps, and curveballs that actually moved the needle (and occasionally, the eyebrows). In a world drowning in endless dockets and comment periods, signal is everything, including:Read through at your own pace – skim for the highlights, dive deeper through the linked filings and/or Halcyon’s suggested queries. Here is a Halcyon query to start your journey:
What's Happening in Energy — May 1
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An update on the acronym we still do not know how to pronounce – ZGIA (“Ziggy-Ahh” or “Zzzz-Ghia”):
In MISO, the Large Load Working Group discussed how a Zero-Injection Generator Interconnection Agreement (ZGIA) can offset the capacity contribution of large loads. The working group presentation included an example for a 1,000 MW load with a 10% Initial Planning Reserve Margin Requirement (IPRMR) (presentation). In this case, with no ZGIA, the load-serving entity would be required to procure 1,100 MW of accredited capacity.
If this load has a ZGIA with an accredited generation capacity of 1,170 MW, then the load-serving entity would have its capacity contribution requirement reduced by the 1,100 MW IPRMR requirement. This means that the generation capacity is slightly overbuilt since the agreement does not allow injection back onto the grid (i.e. netting).
On the other hand, if the associated generator had an accredited capacity of 600 MW, then the load-serving entity would be required to procure 800 MW to meet its IPRMR.
The Large Load Working Group has its work cut out for it the rest of the year. ZGIA is expected to become effective in October ‘26, and two other options (the Firm and Non-firm Service Option) for large load interconnection will be proposed and filed with the FERC. Here’s the schedule.
Previous WHiE coverage: Jan 23, '26 and Feb 27, '26
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A strong to very strong candidate for Halcyon’s next slogan T-shirt from MISO:
In MISO, a group of generators moved to answer and answer MISO’s motion to leave for answer and answer to the motion for leave to answer and answer. The proceeding concerns MISO’s attempt to require generators to pay back their proceeds from the Planning Reserve Auction after the system operator identified an issue with the software used to clear it. Here’s a key excerpt from their response:
“Given the sweeping authority that MISO claims for itself under Section 12A, one would expect that the scope of MISO’s authority would be clearly and unambiguously expressed in the tariff. But there is nothing in the tariff that supports the conclusion that the requirements of Module E-1 can be set aside if MISO determines that a Continuing Error has occurred.”
Tune in next year for the next few rounds of answering and answering.
Previous WHiE coverage: Mar 6, '26
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The filed large load tariff for a very ambitious electric cooperative in Virginia:
In Virginia, Rappahannock Electric Cooperative (REC) filed its final Schedule Large Power-Dedicated Facilities (Schedule LP-DF) tariff this April with the State Corporation Commission. Devoted WHiE readers will know that we have been covering REC’s progress in achieving the noble goal of meeting 16,700 MW of large load growth. That’s roughly 16 times REC’s current peak demand of 1,100 MW. Here’s the list of Customer Service Charges per MVA from the filed rate.
Read Halcyon’s summary of the revisions to the large load tariff.
Previous WHiE coverage: Oct 10, '25 and Nov 7, '25
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LA County’s planned monster battery energy storage system (BESS) draws public comment:
In California, the public has been submitting comments for the past few months on the giant 1,150 MW Prairie Song Reliability Project in Los Angeles County. WHiE readers may remember our excitement when we picked this needle from the haystack of California Energy Commission filings last summer. At the time, there was hardly any coverage of the project. Halcyon made it easier to spot.
One of Halcyon’s strengths is quickly grasping cross-cutting themes that arise in requests for information (RFI) and in comments, so we asked for a RFI summary and comment summary. Fire risk is top of mind for most commenters.
Previous WHiE coverage: July 25, '25 and Feb 27, '26
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Updates on the pair of large load tariffs in Wisconsin:
In Wisconsin, the Public Service Commission Staff released the Final Decision Matrix this April for Wisconsin Electric Power Company’s (WE Energies) two large load tariffs: the Very Large Customer (VLC) tariff (originally proposed at 500 MW, later scaled back to 250 MW by WE Energies) and the Bespoke Resources tariff. We can expect a final order from the Commission soon. Check out Halcyon’s summary of the key issues raised by stakeholders.
Previous WHiE coverage: Jan 30, '26
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Another rate case from one of our most frequently covered utilities (even for rate case standards):
In Michigan, DTE Electric requested a rate increase for $474.3 million (Rate Case Summary). Follow along here by clicking the “Create Alert” icon in the top right. Check out the components of the revenue requirement increase.
In the first year of WHiE, we covered DTE’s previous rate case, which was one of the most highly contentious rate cases of 2025. Two months after the rate increase for $242.2 million was approved in February ‘26, DTE Electric filed a motion in mid-April for the Public Service Commission to reject the Attorney General’s Concurrence with the Michigan Environmental Council’s petition for rehearing. The formal label? The “Answer Opposing Attorney General’s Concurrence with Michigan Environmental Council’s Petition for Rehearing and to Alter, Amend, or Modify Order.”
According to DTE, “The Commission’s Rules of Practice and Procedure, Mich Admin Code, R 792.10401 et seq., do not provide for a ‘concurrence’ with a petition for rehearing. Therefore, the Commission should simply disregard the AG’s filing, as the Commission has done for similar filings.”
Previous WHiE coverage: Oct 10, '25 and Oct 31, '25
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An update on Texas’s net-metering arrangements as part of the evolving regulatory framework for large load ignited under Senate Bill 6 (SB6):
In Texas, we continue to track the proceedings on the implementation of SB6. WHiE readers know that we like to surface the noteworthy exchanges in this complicated and interconnected (no pun intended) universe of ERCOT technical revisions and PUCT dockets. For those of you who want to stay on top of SB6 – here’s an example of the most recent alert sent to our inbox on Monday (you can receive it too by clicking “copy alert”).
In this curated alert series, we learned that the recently adopted rule for Net Metering Arrangements Involving a Large Load Co-located with an Existing Generation Resource (in project 58479 order pages 0-99, pages 100-141) is meeting reality with data center load net metering arrangements in flight. Staff filed a Proposed Order on the net-metering arrangement between Freestone Power and C1 Freestone. The Proposed Order would approve the arrangement and accept the conditions that ERCOT recommended the PUCT adopt (but that C1 and Freestone took issue with). Here’s a summary of the Proposed Order.
Previous WHiE coverage: Nov 7, '25, Mar 27, '26, and Apr 10, '26
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An update on the permitting of the generation resources for Amazon’s “megaload” in Indiana:
In Indiana, Northern Indiana Public Service Company (NIPSCO) filed a draft order with the Utility Regulatory Commission that, if approved by the Commission, would remove the Certificate of Public Convenience and Necessity (CPCN) requirement for the generation company (“GenCo”) NIPSCO spun up to serve Amazon. GenCo would sell the output of 400 MW of BESS and two 1,300 MW gas plants to NIPSCO under a PPA so that the utility can serve Amazon’s 2,400 MW “megaload” as the utility calls it (or 2.4 million kiloload – enough power for 700k to 2m homes).
According to GenCo,
“The CPCN Statute was not intended to apply in the absence of any obligation to serve, and GenCo is explicitly prohibited from providing retail electric service. Because NIPSCO will be the only customer of GenCo and GenCo’s costs will not be recovered from NIPSCO’s current, traditional retail customers, it is appropriate for the Commission to decline such jurisdiction.”
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Last but not least for our Halcyon one-year anniversary items,
An ending in sight for FERC’s Advance Notice of Proposed Rulemaking (ANOPR) on large load interconnection:
The FERC declared in mid-April its intent to issue an Order Regarding Intent to Act by the end of June 2026, targeting surging power demand and large load interconnection to the interstate transmission system — among WHiE’s most-covered topics.
“As requested, the Commission and its dedicated staff have been implementing and “build[ing] upon [the ANOPR] principles” in our recent work, and our view is that the Commission and regulated parties have made meaningful progress toward addressing the urgent and important problems identified by the Secretary. But it is clear to us that further action is warranted to support further progress where it is needed.”
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Also, here is one more development we came across in the past week to round out to 10 items.
In Mississippi, Entergy and Mississippi Power are pushing back against a request from Prado AI, a data center developer, with the Public Service Commission. Prado AI is requesting that the Commission issue a declaratory opinion that it is not a “public utility.” This designation would allow Prado AI to move forward with developing generation for its data center without having to request a Certificate of Public Convenience and Necessity under the jurisdiction of the Commission. Read Halcyon’s summary of the opposing legal arguments. In the latest exchange, Prado AI requested that the Commission strike Entergy’s brief because it was filed after the deadline (Prado AI Motion to Strike).
“Pursuant to Commission Rules…all briefs were to be filed by April 13, 2026…EML submitted its brief at 7:16 p.m. on April 13, 2026.”
Entergy promptly responded: “EML is confident that the Mississippi Public Service Commission (“Commission”) will focus its attention and limited time on the substance…rather than a punitive reading of the Mississippi Public Service Commission’s Public Utilities Rules…The Commission routinely accepts electronic filings past 5:00pm as a matter of practice.”
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Halcyon Team Query of the Week
New Docket of the Week
In New Mexico, El Paso Electric Company is requesting approval for a demand response and distributed energy resource pilot projects designed to enhance grid modernization and meet capacity needs.
Public Comment Excerpt(s) of the Week
Previous WHiE coverage: Feb 20, '26 and Mar 13, '26
Most clicked item from last week’s WHiE