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If a large data center is proposed in your area, ask the electric utility and its regulators for evidence in six areas: how much load is actually likely to arrive, when supply and grid upgrades will be ready, how reliability was tested, who pays, what protects customers if the project changes, and where the public can review or challenge the decision. Request forecasts in both megawatts and energy use, the assumptions behind each project, multiple delay or cancellation scenarios, contingency results, a project-by-project cost allocation, and the docket where filings and comments are posted.
There is no national, one-size-fits-all answer. Tariffs, planning rules, regional transmission organizations, confidentiality standards and approval procedures differ by state and utility. Use the questions below as a meeting script, then verify every answer in your utility’s filing and your state commission’s docket.
Start with the right decision-makers
Data-center service decisions can involve several entities. Identify your electric distribution utility, state public-utility commission, regional transmission organization or independent system operator, and any local government reviewing land use. Ask which body controls the issue you care about: a tariff may be decided by a state commission, regional transmission may be reviewed through a regional process, and generation or interconnection work may appear in several dockets.
Before a meeting, obtain the utility’s most recent integrated-resource, load-forecast or large-customer filing. Record the docket number, filing date and deadline for comments. If the utility says an answer is confidential, ask for the legal basis, whether a redacted version exists and which regulator reviews the confidentiality request.
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1. Test whether the load forecast is credible
A headline projection can combine speculative sites, signed contracts and projects already under construction. Ask the utility to separate those categories and show the probability assumptions used for each one.
Ask for a time-phased forecast
- What data-center demand is expected in the next three, seven and ten years, and farther out?
- What is the forecast in both peak megawatts and annual energy (megawatt-hours or gigawatt-hours)?
- Which projects are included, at what application, interconnection, land-use, construction or contractual stage?
- How often will the forecast be updated, and which public filing will contain revisions?
The Minnesota Public Utilities Commission has used a three-, seven- and ten-year framing in questions to utilities. California’s Energy Commission said its 2024 demand forecast began incorporating data-center projections from utility applications, with utilities helping assess the likelihood that applications will be completed. Those are jurisdiction-specific examples, not a universal forecasting rule.
Require alternative scenarios
Ask for at least a base case, a high-growth case and a low-growth case. Each should show what happens if a project is delayed, built at a smaller capacity, canceled or duplicates a load counted elsewhere. The U.S. Department of Energy’s integrated-resource-planning guidance recommends methods for judging whether proposed large customers will materialize and modeling multiple scenarios. Ask whether the utility has a written probability or milestone test rather than simply adding every announcement to its peak forecast.
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Have the utility define terms such as “pipeline,” “reserved,” “contracted,” “under construction” and “in service.” Ask what financial security, minimum bill, construction milestone or cancellation payment makes a project count as committed. Request a project list that identifies the stage and the load amount used in the forecast; customer names may be redacted, but the assumptions should still be auditable.
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2. Ask how supply and reserves will keep pace
More load requires dependable capacity, energy, reserves and a schedule for bringing resources online. A forecast is not a reliability plan unless the utility explains which resources will serve it and what happens when a project is late.
Questions about generation and capacity
- Which existing plants, new generators, contracts, storage resources or demand-response programs are expected to serve the data-center load?
- When will each resource be available, and what is its status in the interconnection queue, permitting process or construction schedule?
- What reserve margin or other resource-adequacy standard was applied at the relevant peak?
- What is the plan if a generator, fuel supply, transmission project or import is delayed or retires early?
At a Federal Energy Regulatory Commission technical conference on resource adequacy, large commercial and industrial loads such as data centers, slower-than-expected resource interconnection and transmission constraints were identified as planning concerns. Ask whether the regional operator agrees with the utility’s assumptions about timing, deliverability and peak contribution.
Request the actual stress tests
Ask to see results for summer and winter peaks where applicable, extreme weather, generator outages, transmission outages, fuel limitations and simultaneous project delays. Find out whether the model treats data centers as constant loads, flexible loads or loads that can be curtailed. A system that passes an average-day study may still fail under a credible contingency.
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Generation somewhere in the region does not prove that electricity can reach a particular campus. Large loads can require high-voltage transmission, substations, transformers, distribution feeders, protection equipment and sometimes new rights of way.
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Infrastructure questions
- Which transmission lines, substations, transformers, breakers and distribution circuits must be built or upgraded?
- What are the in-service dates, permitting dependencies and long-lead equipment risks?
- Which local thermal, voltage, stability or fault-duty constraints were found?
- What contingency cases were studied, and what operating limits apply before every upgrade is complete?
- Does the regional transmission organization or independent system operator confirm that the proposed delivery path is feasible?
The Illinois Commerce Commission’s questions for evaluating large-load proposals specifically address system stress, contingencies, local impacts, infrastructure upgrades, load shape and generation sufficiency. Ask for maps or one-line diagrams that show the affected facilities, not just a regional capacity total.
Examine the load shape
Ask whether the data center runs continuously, how quickly demand can change, and whether cooling systems create seasonal or hourly peaks. Compare the customer’s peak demand with its average demand and ask whether the forecast assumes coincident peak with other customers. A high annual energy use and a high instantaneous peak create different planning problems and different cost drivers.
4. Identify who pays and how customers are protected
Large-load service can create costs for a specific interconnection, shared network facilities and regional transmission. The key question is not simply the project’s total cost, but which customers are assigned each component and under what tariff or commission decision.
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| Cost category | Questions to ask |
|---|---|
| Direct interconnection | Which lines, transformers, protection systems and construction work are assigned directly to the data center? What customer contribution is due before construction? |
| Shared network upgrades | Which facilities benefit other customers or regions? What allocation formula applies, and what estimated benefits support it? |
| Generation and capacity | Who pays for new capacity, reserves, fuel arrangements or market purchases needed for the forecast? |
| Ongoing service | What demand, energy, minimum-bill, standby or other tariff charges apply, and how can they change? |
FERC’s transmission-planning explainer describes benefit-based allocation: regional costs should be roughly commensurate with estimated benefits. The exact formula and legal standard depend on the region and filing, so request the tariff section and the commission’s cost-allocation analysis rather than relying on a general principle.
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Ask what happens if the customer underuses or leaves
- Is there a minimum demand or minimum billing period?
- Must the customer post security, make a construction contribution or pay an exit charge?
- Who bears debt or depreciation if the project is delayed, downsized or canceled?
- Can the utility reassign reserved capacity or facilities to another customer?
- Are there protections against spreading project-specific costs to ordinary customers?
Minnesota regulators have asked how to prevent cross-subsidy. Oregon’s large-customer policy materials identify minimum-load or billing agreements and stranded-asset avoidance as issues to examine. Request the proposed service agreement, tariff language and financial model showing the recovery period.
5. Demand transparency and a meaningful public process
Ask for the docket, filing schedule, public versions of the utility’s analysis, technical appendices and instructions for written comments or hearings. Confirm whether the public can comment before the commission approves a tariff, service agreement or major investment.
Handle confidential information precisely
Minnesota’s PUC describes a process in which a utility files a service agreement, the public receives notice and can comment, and the commission reviews the proposal. It also notes that load estimates, construction estimates, schedules and customer-specific rates may be claimed as trade secret after review. Rules elsewhere may differ. Ask for a redacted record, a description of each withheld category, the governing confidentiality rule and the regulator responsible for deciding the claim.
Build a comment record
- Download the filing and note every forecast, assumption, deadline and proposed condition.
- Separate factual questions from policy objections; cite the page or attachment for each factual point.
- Ask the commission to require scenario analysis, contingency results, cost allocation and customer protections that are missing.
- Submit comments through the official docket before the stated deadline and keep the confirmation.
- Monitor supplemental filings, hearing notices and commission orders for changed assumptions.
6. Ask about flexibility and policy requirements
Some proposals may reduce risk through flexible service, curtailment, storage or demand response. Ask whether each option was evaluated, what notice and duration limits apply, and whether it is available under the local tariff. A Federal Energy Regulatory Commission statement dated June 18, 2026, concerning PJM large-load proceedings discusses transmission service and possible flexible-load arrangements under examination; it does not establish that a particular arrangement is approved or offered in your area.
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Also ask how state requirements affect the supply plan. Minnesota planning questions include compliance with state carbon-free requirements. Request the modeled emissions, renewable or clean-energy obligations, and any reliability limits assumed for complying resources. Do not assume that a policy goal replaces the need for capacity, reserves or deliverability analysis.
Use a proposal scorecard
If the utility presents several tariffs, service agreements or supply plans, compare them on the same axes. Record the page supporting each answer and mark “not stated” where the filing provides no evidence.
| Evaluation axis | What a strong filing shows |
|---|---|
| Forecast confidence | Project stages, probability assumptions, high/low scenarios and a revision schedule. |
| Delivery schedule | Resource, transmission, substation and distribution milestones with delay contingencies. |
| Reliability | Peak, seasonal, outage and extreme-weather results, including resource delays. |
| Cost assignment | Direct, shared and regional costs with a stated allocation method. |
| Underuse protection | Minimum bills, security, exit terms and treatment of stranded investment. |
| Transparency | Public assumptions, redacted technical material and a clear comment process. |
| Operational flexibility | Defined curtailment, storage or flexible-service terms and reliability limits. |
| Legal compliance | Evidence that state energy, emissions and commission requirements are included. |
Warning signs that require follow-up
- A forecast counts announced campuses but does not show applications, contracts or construction milestones.
- Peak megawatts are presented without annual energy, load shape or coincident-peak assumptions.
- The plan depends on generation or transmission with no in-service date, permit status or delay case.
- Reliability results cover normal conditions but omit credible outages, extreme weather or equipment failures.
- “Customer-funded” is used without separating direct facilities from shared network upgrades.
- The filing has no minimum bill, security or exit treatment if the load does not materialize.
- Confidentiality claims remove the assumptions needed to test the public-interest case, with no redacted substitute.
- A flexible-load option is described as available even though no approved tariff or operating terms are cited.
For each warning sign, ask the utility or commission to identify the missing document, the responsible decision-maker and the date by which the information will be filed.
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- “Please provide the data-center forecast for three, seven and ten years in peak megawatts and annual energy, with every project’s development stage and probability assumption.”
- “Show base, high and low cases, including delay, downsizing, cancellation and duplicate-counting checks.”
- “List the generation, reserves, transmission, substation and distribution work needed, with dates and contingency results.”
- “Explain which costs are direct, shared or regional, and cite the tariff or allocation rule for each.”
- “What minimum bills, security, exit charges or reassignment rights protect customers if the project underuses or leaves?”
- “Where are the public filings, redacted technical documents, comment instructions and decision schedule?”
- “Were curtailment, storage, demand response or flexible service evaluated, and what reliability limits apply?”
Keep the answers, attachments and docket links together. Recheck the forecast after each major filing because a project’s stage, expected in-service date or requested capacity can change.
How the official examples fit together
California’s Energy Commission illustrates how utility applications can feed a statewide demand forecast. Minnesota’s PUC illustrates detailed questions about forecast horizons, cross-subsidy, service agreements and public input. Oregon’s PUC highlights minimum-load commitments and stranded-cost risks. Illinois’ commission supplies a checklist for contingencies, load shape and local infrastructure. FERC materials address resource adequacy, transmission planning and benefit-based cost allocation, while DOE guidance emphasizes testing whether proposed large customers will actually materialize. These sources make the questions concrete; they do not create a single rule that applies to every utility.
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