APPA Urges FERC to Respect Jurisdictional Limits in Large Load Interconnection Rules

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On November 21, 2025, the American Public Power Association (APPA) submitted comments to the Federal Energy Regulatory Commission (FERC) regarding the Secretary of Energy’s advance notice of proposed rulemaking (ANOPR) on interconnecting large loads to the interstate transmission system.

APPA emphasized that FERC should respect the Federal Power Act’s jurisdictional boundaries by:

  • Allowing retail regulatory authorities to continue governing retail service terms for large loads.
  • Avoiding mandates for transmission providers to offer retail wheeling service.
  • Maintaining its disclaimer of authority over bundled transmission sales.

Additionally, APPA urged FERC to protect existing customers from increased costs or risks resulting from new interconnection rules. Any principles adopted must include clear provisions for allocating stranded cost risks to large load customers if they fail to meet forecasted electricity demand.

This guidance aims to ensure fairness and stability as FERC considers new policies for large load interconnections.

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