Get a Load of This: Regulatory Solutions to Enable Better Forecasting of Large Loads

CIN Admin
CIN Admin
  • Updated
Resource Type Report
Author / Source Jeffrey Sward, Lauren Shwisberg, Katerina Stephan, Jacob Becker (RMI)
Publication Date February 2025
Location United States (case studies from VA, NC, GA)
Initiative Type Policy, Technology
Project Complexity Advanced
Recommended For Staff, Board

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Estimated reading time: 30+ minutes


Why This Matters for Rural Electric Co-ops

This report proposes new regulatory approaches to improve how utilities forecast and plan for large emerging loads like AI-driven data centers and advanced manufacturing. As these facilities increasingly seek rural sites, rural co-ops may find themselves at the center of significant load growth without the tools to manage the risk.

Over-investment driven by loads that never materialize creates stranded asset risk for all members; under-investment risks reliability failures. Co-op staff and G&T partners can use this resource to evaluate whether current planning processes are equipped for large load inquiries and to advocate for tariff and forecasting practices that protect members.


Key Takeaways

Data centers and large industrial loads have unique characteristics, including load shape, flexibility potential, and flight risk, that standard IRP forecasting methods weren't built to capture. Co-ops and G&T partners need updated approaches.
Utilities have historically over-forecast by 8–17%, and cost-of-service incentives reinforce over-investment. Co-ops should scrutinize G&T capital plans tied to large load growth.
Tariffs requiring upfront collateral, contracted demand, and exit fees can protect existing members from stranded infrastructure costs. Several states have already adopted such structures.
Scenario-based forecasting presents load as a range rather than a single value, enabling better distinction between required and imprudent investments. Co-ops should ask whether G&T forecasts reflect this approach.

Implementation Considerations

  • Cost or Funding Requirements: Developing separate large load forecasts and updated tariff structures requires expertise smaller co-ops typically don't have in-house. The most actionable path is advocating through G&T relationships and statewide associations for the practices described in this report.
  • Regulatory or Governance Considerations: Though directed primarily at IOU regulators, this report's recommendations are directly relevant to co-ops operating under G&T contracts or in RTO/ISO markets. Regulatory decisions on large load tariffs and forecasting standards made at the state level directly affect co-op member rates and risk exposure.

Notable Examples

  • Dominion Energy (Virginia): Multi-scenario data center forecast; projected data center load exceeded total ERCOT actual load growth, illustrating scale of risk.
  • Duke Energy (North Carolina): First applied economic development adjustment to IRP in 2023; required by commission to report semiannually on large load pipeline.
  • Georgia Power: Quarterly large load pipeline reporting; 36.5 GW pipeline as of September 2024; commission approved risk-based billing for loads above 100 MW.
  • AEP Ohio: Data centers over 25 MW must pay 85% of expected monthly energy use and exit fees if contracts aren't met.
  • Indiana & Michigan Power: Large load customers must pay collateral equal to 24 months of expected non-fuel bills, shifting stranded asset risk to the customer.

View Full Document Requires name and email to access

Estimated reading time: 30+ minutes

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