By: Rebekah de la Mora, Senior Policy Analyst
With the advancement of large language models, generative chatbots, and other forms of generative artificial intelligence, the hot new question in the energy industry is how are we supposed to power all of this?! What do we do now?! Everyone is attempting to answer it. From preliminary research to dedicated tariffs, states and utilities are employing a myriad of tools to solve the expected rapid increase in load growth and demand.
Across the first half of 2025, the DSIRE Insight team found 33 states took some sort of action on large load customer treatment, with over 85 discrete actions. Tracked actions include the following:
| Customer Requirements | Fees, on-site generation, on-site efficiency, or reporting requirements for large load customers |
|---|---|
| Interconnection | Rules or requirements governing the energization of large load customers to the grid |
| Studies | Studies and investigations into large load customers and their impacts |
| Tariffs | Statutes and regulations for utility tariffs serving large load customers, and applications to establish or amend utility tariffs serving large load customers |
| Utility Requirements | Resource planning and resource procurement targeting (expected) demand from large load customers |
A good majority of actions focused on tariff development -- whether statutory mandates from legislatures, requests and regulations from regulatory commissions, or proposals from utilities. Large load customer tariffs tend to differ from tariffs for smaller commercial customers by requiring a minimum contract length, mandating financial assurances or contributions from the customer, implementing a ramp-up period for customer load, or integrating clean energy provisions -- along with, of course, a higher minimum demand threshold and/or minimum load factor to receive service. Not every large load customer tariff will have every single one of these characteristics, but many have a good mix of them. While these tariffs often use a minimum demand threshold or minimum load factor to determine eligibility, sometimes they call out specific types of eligible customers, like data centers or cryptocurrency customers.
Screenshot of Database of Emerging Large-Load Tariffs, a joint project between the NC Clean Energy Technology Center’s DSIRE Insight Team and the Smart Electric Power Alliance, September 2025
We also saw significant interest in studies or investigations related to large load customers. Legislators passed bills and resolutions requesting research into utility service, interconnection processes, power purchase agreements between customers and third parties, customers' impact on the grid and electricity usage. Regulators also initiated or continued proceedings to investigate the effect of large load customers on the grid, treatment of associated marginal costs, and expected load growth due to these customers.
Policymakers also passed bills regarding requirements for large load customers. These requirements normally covered fees, on-site generation, on-site efficiency, and reporting requirements regarding usage of energy; while not a direct focus of DSIRE Insight, many of these actions also tie in efficiency and reporting of water usage. We consider these "customer" requirements as the responsibility falls to the customers, in comparison to "utility" requirements where the onus is on the utility. Fees cover any additional charges a large load customer must pay to receive electric service or interconnect to the grid. On-site generation can mandate renewable or clean sources of energy, but not always -- some of the bills explicitly call out storage, microgrids, or simply generic backup power. On-site efficiency can include energy efficiency standards for data centers or other large load customers, mandates for waste heat efficiency, or architectural/building optimization. Reporting requirements usually require the customers to either submit annual reports summarizing their energy usage, which is then sometimes aggregated by a regulatory body into a statewide report.
Utility requirements tend to focus on directing utilities to plan and procure capacity specifically in response to large load customers. This can be in the form of states ordering consideration of large load additions in utility capacity planning, or calls to procure generation to specifically serve load from these customers. Like with on-site generation requirements for customers, utility procurement requirements can include generic capacity or specific renewable/clean energy sources. In addition, the DSIRE Insight team has seen multiple utilities over the past few quarters re-file integrated resource plans due to changes in their load forecasts from expected large load additions.
Finally, interconnection focuses on rules, regulations, or other requirements regarding the connecting customers for electric service. Interconnection actions tend to focus on transmission-level interconnection, given the size of the customers, revising the processes and fees associated with customer interconnection. It also includes cost allocation and recovery for transmission upgrades triggered by the interconnection of large load customers, with statutes and regulations ensuring that other customers are not forced to pay for the upgrades.
Major actions over the first half of 2025 include:
West
Nevada regulators approved a new Clean Transition green tariff for NV Energy customers over 5 MW
Utah lawmakers allowed customers over 100 MW to submit service requests to the Public Service Commission, and ordered the Commission to investigate the possibility of large load flexible tariffs; the Commission then opened a rulemaking proceeding in response
Arizona regulators opened a proceeding to review customer classes and the possibility of more transparent rates for data centers
Arizona Public Service proposed new cost allocation to properly rate base high load factor customers
North Dakota lawmakers ordered a study on the impact of large energy consumers on the grid, regulatory structures, and economic development
Midwest
Minnesota lawmakers ordered regulators to review utility-proposed tariffs serving very large load customers and consider proper cost allocation
Wisconsin Electric Power proposed a tariff for customers over 500 MW, along with an associated green tariff
Consumers Energy in Michigan requested changes to an existing tariff to accommodate data centers over 100 MW
Indiana regulators approved changes to Indiana-Michigan Power's industrial tariff to serve individual customers over 70 MW and aggregated customers over 150 MW, and also directed the utility to develop a Clean Transition green tariff similar to NV Energy's
Indiana lawmakers allowed utilities to re-file generation resource plans on an expedited basis to serve expected load growth over 5% of their average three-year peak demand or 150 MW due to large load customers
Missouri lawmakers ordered utilities to develop tariffs for customers over 50 MW or 100 MW, depending on the size of the utility
Evergy filed new tariffs in Kansas and Missouri to serve customers over 100 MW
Kansas lawmakers made data centers ineligible for discounted economic development rates and rider
Mid-Atlantic/South
Maryland regulators formed a working group to investigate regulations regarding large load customers and utility tariffs
Appalachian Power in Virginia requested revisions to an existing tariff to accommodate individual customers over 100 MW and aggregated customers over 150 MW
Duke Energy filed a report on expected large load customers additions in North Carolina; in response, the Utilities Commission began an investigation into large load electric additions
Texas lawmakers enabled net metering for large load retail customers and requiring the Public Utility Commission to promulgate rules on cost recovery for transmission upgrades triggered by the interconnection of large load customers
Interested in more in-depth research on large load customer treatment? Check out the Database of Emerging Large Load Tariffs (DELTa), a joint project between the NC Clean Energy Technology Center and the Smart Electric Power Alliance, for information on existing and pending utility tariffs, and the 50 States of Power Decarbonization Report for information on tariffs, customer requirements, utility requirements, interconnection, studies, and integrated resource plans.