Interconnection

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On January 14, 2026, FERC accepted the Southwest Power Pool, Inc.’s (SPP) revisions to its Open Access Transmission Tariff (Tariff) to create a High Impact Large Load (HILL) study process and High Impact Large Load Generation Assessment (HILLGA) process. The HILL study process establishes study and operational requirements for HILLs connecting to SPP’s transmission system. The HILLGA is a new interconnection process for interconnection requests of generation resources necessary to serve HILLs. The Tariff revisions are effective as of January 15, 2026.

On December 18, 2025, FERC directed PJM Interconnection, L.L.C. (“PJM”) to revise its Open Access Transmission Tariff (“Tariff”) to:

1) establish terms that an Interconnection Customer seeking to serve co-located load must follow when effectuating a co-location arrangement;
2) clarify the scope and potential of interconnection service when interconnecting new generation to serve co-located load; and
3) require that a customer taking transmission service on behalf of co-located load take one of three new transmission services.

FERC found PJM’s Tariff was unjust and unreasonable because it did not provide the rates, terms, and conditions of service applicable to generators serving co-located load or eligible customers taking transmission service on behalf of such load with sufficient clarity or consistency. FERC separately established a paper hearing to determine just and reasonable rates for new transmission services and ordered PJM to revise the Behind the Meter Generation rules in the PJM Tariff.

On November 25, 2025, FERC accepted the Midcontinent Independent System Operator, Inc.’s (MISO) proposal to expand the number of interconnection requests MISO may study under its temporary, fast-tracked generator interconnection process. FERC concluded that the proposal will help ensure interconnection customers are able to interconnect to the MISO transmission system in a reliable, efficient, and timely manner.

On October 10, 2025, FERC accepted Southwest Power Pool, Inc.’s (“SPP”) proposed revisions to its Open Access Transmission Tariff (“OATT”) to establish a provisional load interconnection process. SPP argued the provisional load interconnection process is driven by an increase in requests for load additions and will improve transmission planning and encourage new generation resources to come online by allowing SPP to study interconnection requests while accounting for planned generation. FERC accepted the tariff revisions subject to further compliance, finding the provisional load interconnection process will allow SPP to better understand the impacts of load requests and identify necessary network upgrades.

On August 25, 2025, the Federal Energy Regulatory Commission (“FERC”) granted NextEra Duane Arnold, LLC (“NEDA”) a waiver of certain sections of the Midcontinent Independent System Operator, Inc.’s (“MISO”) tariff to use MISO’s generating facility replacement process for the recommissioning of the Duane Arnold nuclear power facility (“Project”) in Palo, Iowa. The order also extends the Project’s commercial operation date to December 31, 2029.

On May 27, 2025, FERC addressed arguments raised on rehearing of a January 30, 2025 order, which accepted the Midcontinent Independent System Operator, Inc.’s (“MISO”) proposal to modify its generator interconnection study process by implementing a queue cap and exemptions to that cap (the “Queue Cap Order”). In doing so, FERC reaffirmed that MISO’s proposed queue cap and exemptions align with Order No. 2003’s independent entity variations for regional transmission organizations and independent system operators.

On March 20, 2025, FERC denied Ponderosa Power, LLC’s (“Ponderosa”) complaint alleging that NorthWestern Corporation’s (“NorthWestern”) application of its large generator interconnection procedures (“LGIP”) was unjust and unreasonable or unduly discriminatory or preferential. The dispute centered around NorthWestern’s requirement for Ponderosa to fund approximately $23 million in network upgrades to accommodate the interconnection of its 70 MW wind-powered generation facility located in Musselshell County, Montana (“Project”).

On November 21, 2024, FERC issued an Order partially accepting NorthWestern Energy Corporation’s (“NorthWestern”) compliance filing, effective July 10, 2024.  FERC found that NorthWestern’s filing partially complies with the requirements of Order Nos. 2023 and 2023-A and directed NorthWestern to submit a further compliance filing within 60 days.

On September 10 and 11, 2024, FERC staff held a two-day workshop at its headquarters in Washington, DC on opportunities to further refine the generator interconnection queue process. Panelists and FERC staff discussed potential enhancements to transmission planning and processing interconnection requests over the course of six panels on discrete…

On July 19, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) issued an Order denying Tenaska Clear Creek Wind, LLC’s (“Clear Creek”) challenges to FERC’s orders allowing the allocation of costs for network upgrades.  Southwest Power Pool, Inc. (“SPP”) assigned costs of more than $100 million to Clear Creek to pay for upgrades required on SPP’s system to accommodate the interconnection of Clear Creek’s wind turbine-powered electrical generation project (the “Project”).