August 26, 2026 | Source: FERC Docket Nos. EL26-67 through EL26-72 (RTO/ISO Large Load Show-Cause Orders, issued June 18, 2026); NERC Large Loads Action Plan Q2 2026 Update; CAISO Informational Report on Large Loads and Co-located Loads (July 20, 2026, EL26-71-000)
RTO Show-Cause Response Window Closes on Large Loads; Ball Is Now in FERC's Court
The 60-day clock FERC set on June 18 under Section 206 of the Federal Power Act has now run out. PJM, MISO, SPP, CAISO, ISO-NE, and NYISO were each directed to either justify why their current tariffs remain just and reasonable without provisions tailored to large loads — or file changes that address five specific reform categories the Commission laid out.
Those five categories: efficient transmission service study processes (including alternative transmission technologies), cost-shift protections and cost transparency, co-location and behind-the-meter generation, new transmission services for flexible large loads, and a study process for generation electrically proximate to large or co-located loads.
CAISO's July 20 informational report in EL26-71 is a preview of the shape these responses are taking — a formal on-the-record filing acknowledging the co-location and proximate-generation questions the Commission put in front of every RTO. The other five operators have now filed their own answers into their respective dockets.
What This Means for the Control Room and the Compliance Desk
This is not another data-center panel discussion. It is a live Section 206 proceeding across every FERC-jurisdictional RTO simultaneously, and it lands on top of NERC's accelerated Large Loads Action Plan under RM26-4 — where NERC has committed to updated registry criteria and an initial Reliability Standard by year-end, following the Level 3 Essential Action Alert whose registered-entity responses were due August 3.
For operators and reliability coordinators: expect changes to the study assumptions you use for large-load interconnection requests, including ramping behavior, trip settings on IBRs feeding co-located loads, and how behind-the-meter generation is modeled in your case builds. For transmission planners: the cost-allocation question is now on the record, which means the assumptions in your active queue studies could shift before the next cluster window closes.
For compliance teams: start tracking which of your customers or interconnection requests meet the 20 MW threshold NERC is using to scope large loads. Whatever registry criteria land at the end of 2026 will pull entities under NERC's jurisdiction that were never registered before — and the evidence you need to demonstrate compliance starts accumulating now, not on the effective date.
EPG Solutions Can Help
EPG's Benchmark Intelligence Reports track how peer utilities and RTO members are scoping large-load interconnection processes, co-location tariffs, and the compliance posture behind NERC's accelerated timeline — the same primary-source docket work summarized above, extended to your specific market and peer set. Visit EPG Solutions → epgsolutions.services