Federal Energy Regulatory Commission Seeks Comment on Advanced Proposed Rulemaking To Address Interconnection Of Large Loads

On October 23, 2025, Chris Wright, Secretary of Energy (Department of Energy or DOE), transmitted to the Federal Energy Regulatory Commission (FERC) an Advance Notice of Proposed Rulemaking (ANOPR) addressing the topic of interconnection of large loads directly to the bulk electric system. Because FERC has jurisdiction over the transmission of electric energy in interstate commerce, the DOE directed FERC to initiate a rulemaking to ensure large loads (over 20 MW) can “connect to the transmission system in a timely, orderly, and non-discriminatory manner.” The DOE’s proposed ANOPR states that reform is needed due to the “unprecedented current and expected growth of large loads seeking to interconnect to the transmission system, and to provide open access and nondiscriminatory access to the transmission system.” In response to the DOE’s directive, FERC opened a rulemaking proceeding under Docket No. RM26-4-000.

The ANOPR identifies fourteen principles upon which a possible new rule could be based, including, but not limited to:

• Limitation of FERC jurisdiction to interconnections directly to transmission facilities, avoiding state jurisdiction over local distribution.
• Application only to new loads greater than 20 MW and, for hybrid facilities, where the load is greater than 20 MW.
• Allowing for studies of loads and hybrid facilities together with generation for efficient siting and minimized network upgrades.
• Standardization of study deposits, readiness requirements, and withdrawal penalties to deter speculative projects.

FERC’s notice provides that initial comments on the ANOPR should be filed by November 21, 2025, and that reply comments should be filed by December 5, 2025. FERC could use these comments to shape a formal rulemaking to be initiated in early 2026 if it intends to meet the DOE’s request for final action to be taken by April 30, 2026.