United States: Energy and Natural Resources

With nuclear power re-emerging as a critical piece of the clean energy transition, Adam Banack shares how small modular reactors are moving from concept to deployable infrastructure.

Every federal development described in the first three alerts of this series – the PJM Interconnection (PJM) co-location orders, the Southwest Power Pool (SPP) High Impact Large Load (HILL) framework, the DOE Rulemaking Proposal’s proposed assertion of jurisdiction over large-load interconnections, and the new transmission service requirements and gross demand billing mandates – reinforces the same observation: the structural advantages of the Electric Reliability Council of Texas (ERCOT) for data center behind-the-meter generation and co-located load arrangements.

The first two alerts in this series traced the Federal Energy Regulatory Commission’s (FERC or the Commission) regulatory trajectory and the political economy now shaping data center power. This alert turns to the structuring question that sits at the center of every behind-the-meter generation and co-located load transaction serving data centers (collectively, BTM): how to design an arrangement that achieves the developer’s commercial objectives while managing, or, where the project configuration permits, avoiding FERC jurisdiction.