On June 18, 2026, the Federal Energy Regulatory Commission (FERC) issued a series of tailored show cause orders under Section 206 of the Federal Power Act, directing the six federally regulated regional grid operators to justify or reform the rules governing the connection of data centers and other large energy users to the electric grid due to the unprecedented and growing demand for electricity. The show cause orders require timely action from the RTOs/ISOs and transmission owners as they must respond to the draft order within 60 days and file an informational report within 30 days. Interested parties must file a notice of intervention or motion to intervene in the show cause dockets by July 9, 2026, in order to be heard during the comment period.
The show cause orders were issued as a result of the Secretary of Energy’s October 2025 Advanced Notice of Proposed Rulemaking (ANOPR), which proposed reforms for timely and orderly interconnection of large loads. In a news release, FERC stated that the series of show cause orders mark “one of the most significant actions the Commission has taken to modernize the nation’s electric markets and push the economy into the future by speeding integration of large energy users onto the grid with additional rigorous consumer safeguards.”
To accommodate how the regional grid operators utilize different procedures and strategies, the orders offer flexibility and variations among different regional operators. However, the general goals of the orders are consistent across the regions. One key requirement is that the six regional grid operators and their transmission owners must provide justification on why their current tariffs remain just and reasonable in the absence of clear and consistent provisions for large load energy users. Another key requirement of the orders is for grid operators to address resource adequacy concerns, demanding they submit informational reports on how they intend to ensure adequate generation will be available to serve new and existing large loads. Informational reports are due within 30 days of the issuance of the orders.
Additionally, the orders propose the following categories of further reforms that grid operators should address:
- Transmission service application and study process, including consideration of alternative transmission technologies.
- Preventing cost shifting and requiring transparency.
- Co-location arrangements and behind the meter generation.
- New transmission services for flexible large loads.
- Generating facilities serving electrically proximate large loads and large co-located loads.
The specific orders for the six regional grid operators can be found here:
- PJM Interconnection, LLC (PJM): EL26-67
- Southwest Power Pool, Inc. (SPP): EL26-68
- New York Independent System Operator (NYISO): EL26-69
- Midcontinent Independent System Operator, Inc. (MISO): EL26-70
- California Independent System Operator Corporation (CAISO): EL26-71
- ISO New England (ISO-NE): EL26-72
The show cause orders do not provide a “one-size-fits-all” solution, and regional grid operators have varying requirements under the orders which will allow them flexibility to decide their best path forward. However, Mark Christie, former Chairman of FERC, highlighted some of the remaining questions after the June 18 orders in his LinkedIn post, including the ongoing questions surrounding jurisdictional issues and whether states still have exclusive jurisdiction over retail customer interconnections. Christie further noted that while the debate over jurisdiction will continue, “the end goal is reliable power at the least cost to consumers” and he praised FERC for its “very smart strategic moves” on the large-load connection issue.
For more information or assistance, please contact Jeffrey C. Genzer, Thomas L. Rudebusch, Michael R. Postar, Lisa S. Gast, Peter J. Scanlon, Sean M. Neal, Bhaveeta K. Mody, and Sylwia Dakowicz.
Article By DWGP Summer Associate Juliette Gaggini – The George Washington University Law School, May 2027
