APPA recently submitted comments to the Federal Energy Regulatory Commission on the Secretary of Energy’s advance notice of rulemaking (ANOPR) on the interconnection of large loads to the interstate transmission system.
The comments submitted on Nov. 21 were in response to FERC’s October 27, 2025, notice inviting comment on the Secretary of Energy’s proposed ANOPR.
APPA urged FERC to respect the Federal Power Act’s jurisdictional limits, by: (a) explicitly allowing relevant retail regulatory authorities to continue regulating terms of retail service for large loads, (b) not ordering any transmission provider to provide retail wheeling service, and (c) continuing to disclaim authority over the bundled transmission sales.
APPA also urged FERC to ensure that existing customers do not bear increased cost or increased risk as a result of FERC-jurisdictional interconnection rules for large loads.
Any principles that FERC adopts for large load interconnections must include explicit provisions that will allocate risks of stranded costs to the large load interconnection customers, in the event that they fail to achieve or maintain the electricity demand that is forecasted.
