Miles Farmer

Making flexibility work: A concrete framework for the DOE large load proposal The proposal for interconnecting data centers to the grid calls for load flexibility but gives few details. Former FERC Commissioner Allison Clements and Miles Farmer and Sam Walsh of Roselle LLP fill...

Notable op-ed today by @allisonclements.bsky.social @mfarmer.bsky.social & Sam Walsh: "bottom line is that enabling load flexibility is critical to achieving speed-to-power for large customers while keeping the grid reliable and affordable for the rest of us." 🔌💡 www.utilitydive.com/news/data-ce...

To get from the high-level principles announced in the ANOPR to real-world implementation would take a lot of work from
@ferc.gov, utilities and developers. We discuss these issues in the Policy Brief.

Verrus successfully demos its flexible data center technology The Sidewalk Infrastructure Partners’ venture used an NREL testing software platform to validate its tech under real-world grid conditions.

As we discuss in the Policy Brief, "flexibility" can mean a lot of things: it includes demand response capabilities, utility-scale batteries paired with the load, and other strategies discussed in our Brief. Here's an example, from
@verrusdata.bsky.social: www.latitudemedia.com/news/verrus-...

Opinion | A Simple Fix to America’s Soaring Electricity Prices

@tnorris.bsky.social discusses the benefits of load flexibility in his @nytimes.com op ed. It can provide speed-to-power for the large customer, while keeping electricity affordable and reliable for everyone else. www.nytimes.com/2025/11/04/o...

How DOE’s Proposed Large Load Interconnection Process Could Unlock the Benefits of Load Flexibility In the United States, the current system for interconnecting large electric loads, like data centers, to the grid has left all sides frustrated. Data center developers are mired in slow interconnectio...

DOE's ANOPR could change the way large energy users connect to the grid. This Policy Brief, by Roselle, @allisonclements.bsky.social and Nicholas Institute, unpacks a promising principle in the ANOPR: interconnection for flexible loads should be expedited. nicholasinstitute.duke.edu/publications...

Saw from @nickguidi.bsky.social that DOE actually used its section 403 authority more recently with gas certification policy: www.utilitydive.com/news/in-unus...

Wright directs FERC to fast track large load interconnection In a notice of proposed rulemaking, the Energy Secretary endorsed accelerating interconnection for flexible loads like data centers.

Late night filing from Chris Wright that could greatly expand federal authority over interconnection -- and fast track the process for flexible large loads. By me for @latitudemedia.bsky.social ⤵️

www.latitudemedia.com/news/wright-... #energysky

Roselle partner @mfarmer.bsky.social outlines thoughts on DOE's start of a rulemaking process at FERC on large load interconnection.

This is MUCH better than the last time the Trump Admin kicked off a rule making process at FERC (in 2017 aimed at keeping piles of coal around)

There is a provision of the Department of Energy Organization Act (section 403) that provides DOE with authority to propose rulemakings to FERC. It is not commonly used. The last time it was done was DOE's ill-conceived bailout of "baseload" resources.

This proposal is not intended in any way to discourage public utilities from making filings to address these and similar issues under FPA section 205

10 - clarifies that it does not discourage filings from utilities to implement similar reforms while the ANOPR proposal is pending:

Thirteenth, there must be a plan to implement these proposed reforms. We seek comment on appropriate transition plans, including the treatment of large load interconnections that are already being studied for interconnection.

9 - calls for transition plans in adopting new rules

Ninth, to the extent the interconnection customer is not the transmission owner, the interconnection customer shall be afforded the same (or equivalent) option to build as currently provided to generator interconnection customers.

8 - gives the large load customer the option to build:

Eighth, load and hybrid facilities should be responsible for 100% of the network upgrades that they are assigned through the interconnection studies. We seek comment on whether such costs should be offset through a crediting mechanism and, if so, over how many years.

7 - proposes to assign 100% of network upgrade costs to the large loads. Calls for comment on whether such costs should be offset through a crediting mechanism and, if so, over
how many years.

Seventh, the interconnection study of large loads that agree to be curtailable and hybrid facilities that agree to be curtailable and dispatchable should be expedited. The system operator's ability to control such facilities through curtailment and/or dispatch must be sufficient for the system operator to integrate the facility into both operations and system planning. This ensures the timely and orderly addition of large loads to the transmission system in a safe, reliable, and non-discriminatory manner. We seek comment on whether this should be accomplished through a serial interconnection study process or by some other means. We also seek comment on appropriate deadlines for such an expedited study process, including whether such studies can be completed in 60 days.

6 - Calls for flexible loads to get priority!

Fourth, like generating facilities, load and hybrid facilities should be subject to standardized study deposits, readiness requirements, and withdrawal penalties. These provisions deter speculative projects and provide transmission providers with more useful information to more accurately forecast demand on their systems. We seek comment on the extent to which the existing study deposits, readiness requirements, and withdrawal penalties can be adopted. We also seek comment on whether additional commitments or financial penalties would be appropriate.

5 - DOE calls for standardized study deposits, readiness requirements, and withdrawal penalties.

Third, to the extent practicable, load and hybrid facilities should be studied together with generating facilities. Such an approach will allow for efficient siting of loads and generating facilities and thereby minimize the need for costly network upgrades.

4 - DOE calls for load and generation to be studied together wherever practicable:

Second, consistent with the Commission's pro forma LGIP and LGIA, the reforms should only apply to new loads greater than 20 MW and, for hybrid facilities

3 - DOE sets a threshold of 20 MW for the reforms' applicability:

There are at least four legaljustifications for the Commission's jurisdiction over such interconnections. First, like generator interconnections, large load interconnections are a "critical component of open access transmission servicc'v? that require minimum terms and conditions to ensure non-discriminatory transmission service.

2 - DOE claims that @ferc.gov has jurisdiction over the interconnection of large loads TO THE TRANMISSION SYSTEM. Makes a robust argument for this jurisdiction but states that it is not regulating interconnection to the distribution system.

On behalf of the American people, and given the urgency of this issue, I look forward to your consideration and final action (no later than April 30, 2026).

1 - The Secretary is asking for a fast response:

Major development!: Department of Energy directs @ferc.gov
to consider an Advanced Notice of Proposed Rulemaking on large load interconnection. THREAD with some key highlights:

Federal appeals court shakes up transmission line siting. 3rd Circuit holds PA PUC's permit denial based on lack of need is preempted by PJM's regional planning process.

Opinion is on PACER but not yet posted by 3rd Circuit on its site

I think we're at the tip of the iceberg for permissionless DERs. Imagine a 1200 W plug in solar, with a few kWh of storage on the same circuit acting as a UPS for your fridge or room AC. Could get interesting.

The cryptocurrency sector has responded enthusiastically to our study. The constructive engagement is appreciated, and at the same time, it's important to clarify a few key points made in this latest media coverage. 🧵 🔌💡

The ability to quickly build new resources, even those with "lower" capacity accreditation, will support power system reliability in the near term better than overwrought deliverability studies that try to account for each resource's contribution and slow everything to a crawl

Trump officials allow massive New York offshore wind project to restart The administration reversed course and will allow the Empire Wind project to proceed after lobbying by New York Gov. Kathy Hochul and Norwegian energy firm Equinor.

Best news I’ve read in a while. The stop work order on Empire Wind has been lifted! 🔌💡#offshorewind www.washingtonpost.com/climate-envi...

I've read through the text from House Energy and Commerce and now Ways and Means. I'm here to tell you this is as bad as it gets for clean energy. We are working to analyze the impact of the actual bill language, but it will be pretty close to our assessment of full repeal we did about a month ago.

FERC Issues Order on Compliance and Tariff Revisions in Docket Nos. ER24-2009 & ER24-2007

🌙 Now Posted: @ferc.gov Issues Order on Compliance & Tariff Revisions in @iso-ne.com.
This stems from #FERC Order 2023.

ferc.gov/news-events/...
🔌💡 #EnergySky

Today I testified to the US House Energy & Commerce Energy Subcommittee for its hearing on "Scaling for Growth," alongside PJM, Southern Company & the Electric Coops - a few things that stood out to me 🧵(1/6) 🔌💡

After groundbreaking bills on jobs and solar, Illinois tackles the… State lawmakers are pushing for more grid-enhancing tech, gigawatts of new energy storage, and the creation of a virtual-power-plant program.

Illinois lawmakers are pushing for more grid-enhancing tech, gigawatts of new energy storage, and the creation of a virtual-power-plant program.

Reporting by Kari Lydersen:

Connecting infrastructure to the grid has been a passion since I worked on FERC's original Order 2003. Surplus interconnection is fast and provides states a tool to accelerate policy achievement even in the face of long queues. Great to work with ‪@mfarmer.bsky.social & the GridLab team!