Regulatory Blog
Transmission Interconnection Costs: Unpacking the Growing Network Burden
October 17, 2025Grid Interconnection is a Critical Problem
Electricity demand is increasing across the U.S. due to factors like electric vehicles, building electrification, and the rise of energy-intensive technologies such as AI and data centers. At the same time, there is growing momentum to meet this demand with clean energy — which has led to a surge in proposed renewable projects, many from small and independent developers. But to deliver power to the grid, these projects must go through the interconnection process, a complex and time-consuming system that can take multiple years to complete.
Currently, there are hundreds of projects waiting in the interconnection queue. Each must undergo a series of technical studies to ensure the grid remains stable and secure if the project is added. These studies determine whether grid upgrades — like transformer expansions or network reinforcements — are needed, and the project developers are expected to pay for these costs. Depending on system conditions, outcomes can range from minor fees to multimillion-dollar upgrade bills.
One of the biggest problems is uncertainty: developers typically have no clear estimate of how much interconnection will cost them until after they’ve already invested significant time and money into the process. This lack of transparency is partially by design — meant to protect critical energy infrastructure information (CEII) and prevent market manipulation. But as a result, many projects ultimately drop out before reaching completion, because the final upgrade costs turn out to be too high. This in turn clogs the system and delays viable clean energy from coming online.
Interconnection Costs are Increasing Due to Higher Network Charges
Berkely notes that interconnection costs have grown substantially over time. These interconnection costs comprise both point-of-interconnection (POI) costs and network upgrade costs. The POI costs are not a problem. Adjusted for inflation these have been stable and are relatively small. However, the network upgrade costs have sharply risen after Covid. DOE notes that transmission investment peaked in the 2012 to 2015 period and has been declining ever since. This decline in transmission investment is exactly when network interconnection costs increased.

Different Technologies Face Different Economies of Scale
There are different network interconnection cost characteristics with each type of generation:
- Gas generation has low network costs and relatively consistent (or slightly improving) with project size.
- Wind generation has moderate costs, but faces higher costs as the project size increases
- Solar generation has less discernable trends. It has higher network costs. At larger project sizes the interconnection cost is highly variable and can be quite high.
- Storage has high costs that increase with size.
Overall sizes of 200-300 MW appeared to show the optimum size for network interconnection costs.
Different Regoins Face Different Economies of Scale
Conclusion
Submetering Across the U.S.: Regulatory Trends, Compliance Structures, and Conservation Impacts
July 17, 2025The Legal Challenge of Submetering
Varying Responses Across the U.S.
Conclusion
- Accurate measurement
- Fair tenant treatment
- Administrative feasibility
- Conservation and decarbonization goals
| Jurisdiction | Submetering Status | Oversight/Standards | Notes |
|---|---|---|---|
| California | Mandatory | Title 24, PUC §739.5, CTEP | Required for all new MF housing (post-2018) |
| New York | Allowed with petition | 16 NYCRR Part 96, HEFPA | PSC approval required; full utility obligations |
| Texas | Permitted | PUC Rule 25.141, NEC | Utility-like billing, tenant protections required |
| Maryland | Regulated | PSC, ANSI/NEC standards | Meter certification & housing authority approval |
| Massachusetts | Prohibited | Only utility-installed meters allowed | No landlord-managed electric submetering |
| North Carolina | Permitted with rules | NCUC, NEC | Strict billing & estimation caps |
| Seattle (local) | Mandatory (sized base) | NEC, Seattle Energy Code | Applies to commercial and large residential buildings |
| Arizona, Georgia | Freely allowed | NEC, ANSI | No utility designation if billing is cost-based |
On Q1 investor calls, 40% of utilities see expansion opportunities driven by connecting data center load
May 7, 2025
| Stock Ticker | Petitioner | State | Docket Number | Docket Description |
|---|---|---|---|---|
| AEE | Ameren Corp | MO | ER-2024-0184 | Pending modified tariff filing for large-load customers |
| MO | ER-2024-0319 | Pending electric rate review | ||
| MO | GR-2024-0369 | Pending gas rate review filing | ||
| MO | EA-2024-0237 | Order approving CCN for Castle Bluff Energy Center | ||
| MO | EA-2023-0286 | Order approving multi-project CCN for Solar Projects | ||
| MO | EO-2019-0044 | Smart Energy Plan filing | ||
| MO | EO-2024-0020 | 2025 Preferred Plan change to 2023 IRP | ||
| IL | 25-0084 | Pending natural gas rate review filing | ||
| IL | 25-0382 | Pending performance-based ratemaking reconciliation filing | ||
| IL | 24-0288 | Order approving electric distribution performance-based rate update filing | ||
| IL | 23-0082 | Order approving revised Multi-Year Rate Plan filing | ||
| IL | 24-0238 | Order approving revised Multi-Year Rate Plan filing | ||
| FERC | EL14-12 | Order in complaint proceedings regarding MISO base ROE (2nd complaint) | ||
| FERC | EL15-45 | Order in complaint proceedings regarding MISO base ROE (1st complaint) | ||
| FERC | RM20-10-000 | FERC Notice of Proposed Rulemaking regarding policies for incentives | ||
| AEP | American Electric Power | VA | PUR-2024-00024 | Rate case |
| WV | 24-0854-E-42T | Rate case | ||
| OK | PUD 2023-000086 | Rate case | ||
| AES | AES Corporation | OH | 24-0960-EL-MER | Sold a 30% stake in AES Ohio to CDPQ |
| IN | 45911 | Rate case, AES Indiana filed June 28, 2023, order April 17, 2024 | ||
| AQN | Algonquin Power & Utilities Corp | MO | ER-2024-0261 | Rate case |
| CA | A24-09-010 | Rate case | ||
| NH | DG 23-067 | Rate case | ||
| NH | DE 23-039 | Rate case | ||
| CA | A24-01-002 | Rate case | ||
| AZ | W-02074A-23-0337, W-02465A-23-0338,W-02060A-23-0339, WS-02676A-23-0340 | Rate cases | ||
| CA | 24-01-003 | Rate case | ||
| NY | 24-G-0668 | Rate case | ||
| ATO | Atmos Energy Corporation | CO | 22AL-0348G | General rate case, rates Q2 2026 |
| KS | 25-ATMG-278-TAR | System Integrity program filed Jan 2025, new rates Q3 2025 | ||
| KY | 2024-00276 | $ 33.7MM – Kentucky Gas Rate Case filed Sept 27, 2024 | ||
| AVA | Avista Corp | WA | UE-240006,UG-240007 | Completed gas and electric rate case |
| ID | AVU-E-25-01,AVU-G--01 | General rate case for gas and electric filed January 2025 for effect Sept 2025 | ||
| OR | UG519 | General rate case filed November 2024 for new rates to be effective Sept 2025 | ||
| AWR | American States Water Company | MO | WR-2024-0320 | Rate case filed 7/1/24, settlement March 17, 2025, rates effective May 31 2025 |
| HI | 2024-0038 | Rate case filed 8/2/24, partial settlement, rates effective mid 2025 | ||
| IA | RPU-2024-0002 | Rate case filed 5/1/24, interim rates effective 5/11/24 | ||
| AWK | American Water Works Company, Inc | CA | A23-08-010 | GSWC’s general rate case application, settlement July 12, 2024 |
| CA | A22-08-010 | BVES’s general rate case application, final decision Jan 16, 2025 | ||
| BKH | Black Hills Corporation | IA | RPU-2024-0001 | Settlement approved, new rates Jan 1, 2025 |
| CO | 24AL-0275E | Rate case rates approved, effective March 22, 2025 | ||
| KS | 25-BHCG-2980RTS | Rate and rider review filed Feb 3, 2025 for effect 2H 2025 | ||
| CMS | CMS Energy Corporation | MI | U-21816 | Renewable Energy Plan 2025-2045 |
| MI | U-21585 | Rate case completed | ||
| MI | U-21806 | Gas rate case filed Dec 16, 2024, expect order Oct 16, 2025 | ||
| CNP | CenterPoint Energy, Inc | IN | 45990 | Rate case completed, rates updated in Feb and also March |
| TX | 56211 | Houston Electric rate case, rates updated April 28 | ||
| MN | 23-174 | MN Gas rate case completed | ||
| TX | 57559 | May 2024 Storm event securitization, PUCT docket, Q2 2025 | ||
| OH | 24-0832-GA-AIR | OH Gas rate case | ||
| CPK | Chesapeake Utilities Corporation | MD | 9711 | Rate Case -Settement, awaiting final order |
| DE | 24-0906 | Rate Case - settlement in principle, final order expected Q2 2025 | ||
| FL | 20240099 | FPU Electric rate case, filed Aug 2024, in progress | ||
| FL | 20250035 | FCG Updated depreciation study | ||
| CWT | California Water Service Group | CA | A2107002 | Escalation increase requests from 2021 general rate case |
| CA | A2407003 | 2024 general rate case | ||
| D | Dominion Energy | VA | 146025 | Biennial review filing |
| DTE | DTE Energy Company | MI | U-21860 | Filed rate case in April |
| DUK | Duke Energy Corporation | FL | 20240025 | 2025-2027 MYRP |
| IN | 46155 | IRP filed Nov 1, 2024 | ||
| ED | Consolidated Edison | NY | 25-E-0072 | Electric Rate Case - filed in Jan, staff testimony expected in May |
| NY | 25-G-0073 | Gas Rate case - filed in Jan | ||
| EIX | Edison International | CA | A.25-03-012 | 2026 cost of capital filed (intervenor june 16, decision Nov 14) |
| CA | A.23-05-010 | General rate case | ||
| CA | A.25-03-009 | Next gen IRP (~$1b, filed in March 2025) | ||
| CA | A.24-10-002 | Wildfire: Woolsey Cost Recovery ($5.4b) | ||
| CA | A.23-10-001 | Wildfire: 2022 Mitigation and Vegetation Mgt ($384m) | ||
| CA | A.24-04-005 | Wildfire: 2023 Mitigation and Vegetation Mgt ($326m) | ||
| ES | Eversource Energy | CT | 24-12-01 | Yankee Gas rate case |
| MA | 24-137 | PBR Ratemaking docket | ||
| NH | 24-070 | PSNH rate case | ||
| ETR | Entergy Corporation | TX | 56865 | Segno Solar 170 MW, Votaw Solar 141 MW |
| TX | 56693 | Legend CCCT 754MW, Lone Star CT 453MW | ||
| LA | U-37425 | Generation and transmission for new customer | ||
| LA | U-37467 | West Bank 500kV transmsission | ||
| TX | 57899 | DCRF filing, $29m rev req | ||
| TX | 57648 | SETEX 500kV transmission ($!.5b) | ||
| EVRG | Evergy, Inc | KS | 25-EKCE-294-RTS | Kansas Central Rate Case |
| KS | 25-EKCE-207-PRE | Natural Gas & Solar Predetermination | ||
| KS | 25-EKME-315-TAR | Large Load Tariff | ||
| MO | EA-2024-0292 | Solar Certificates of Convenience and Necessity (CCN) | ||
| MO | EA-2025-0075 | Natural Gas CCNs | ||
| MO | EO-2025-0154 | Large Load Tariff | ||
| EXC | Exelon Corporation | DE | 24-1044 | Base Rate Case: DPL DE Gas, decision expected Q12026 |
| NJ | ER24110854 | Base Rate Case: ACE Electric, decision expected Dec 2025 | ||
| MD | 9645 | BGE Reconciliation case | ||
| MD | 9655 | Pepco Reconciliation case | ||
| MD | 9618 | Maryland lessons learned | ||
| IL | 25-0383 | ComEd Reconciliation | ||
| HE | Hawaiian Electric Industries (HEI) | HI | 2018-0088 | Performance-based regulation |
| HI | 2027-0352 | Stage 3 RFP | ||
| HI | 2018-0165 | Integrated Grid Planning | ||
| HI | 2020-0132 | Waena BESS | ||
| HI | 2024-0144 | Land sale: Cooke Street Property | ||
| LNT | Alliant Energy Corporation | WI | 6680-UR-125 | Rate case with forward test years 2026 and 2027 |
| IA | RPU-2023-0002 | Electric and Gas Rate Review Settlement | ||
| IA | TF-2025-0007 | Anticipated commission decision on first Individual Customer Rate filing | ||
| IA | GCU-2024-0004 | Anticipated commission decision on Cedar River Generating Station | ||
| WI | 6680-CE-187 | Anticipated commission decision on Riverside Enhancements | ||
| WI | 6680-CE-188 | Anticipated commission decision on Bent Tree Wind Refurbishment (Repower) | ||
| 5-CE-156 | Anticipated commission decision on Energy Dome | |||
| 5-CE-160 | Anticipated commission decision on Forward Wind Refurbishment (Repower) | |||
| WI | 6680-CG-171 | Anticipated commission decision on Liquified Natural Gas (LNG) | ||
| MDU | MDU Resources Group Inc | MT | 2024-05-061 | MTPSC rate case filed July 15, 2024 |
| WY | 30013-415-GR-24 | WYPSC Rate case filed October 31, 2024 | ||
| ND | PU-22-194 | Rate case approved Nov 7, 2024 | ||
| NEE | NextEra Energy Inc. | FL | 2025-0011 | 2025 FPL base rate proceeding |
| NFG | National Fuel Gas Co | NY | 23-G-0627 | Base Rate settlement |
| PA | M-2025-3054126 | DSIC treatment | ||
| NI | NiSource | IN | 45320 | Electric rate case filed 9/12/2024, order expected Aug 2025 |
| IN | 46172 | NIPSCO IRP | ||
| MD | 9754 | CMD gas rate case filed 9/24, 2024, final order expected April 2025 | ||
| VA | PUR-2024-00030 | CVA gas rate case filed 4/29/2024 | ||
| OH | 24-1065-GA-RDR | Infastructure replacement program (IRP), CEP, PHMSA IRP | ||
| KY | 2025-00071 | SMRP | ||
| PA | M-2025-3054108 | Distribution System Improvement | ||
| NJR | NJ | GR24010071 | ||
| NWE | NorthWestern Energy Group | MT | 2022-7-78 | Rate Case |
| NWN | Northwest Natural Holding Company | OR | UG 520 | Gas rate case filed on Dec 30, 2024 for rates effective Nov 1, 2025 |
| ID | Falls Water GRC | |||
| OGS | One Gas, Inc | KS | 24-KGSG-610-RTS | Rate case: approved October 2024, Kansas Gas Service |
| PPL | PPL Corporation | KY | 2025-00113, 2025-00114 | Plan to file base rate case on May 31 (LGE) |
| KY | 2025-00045 | Application in Feb 2025 for 2 new 645 MW NGCC units, 400 MW battery storage system | ||
| KY | 2025-00105? | ECR - regulatory tracker | ||
| SJW | SJW Group | CA | A-24-01-001 | Rate Case 2025-2027 San Jose Water General Rate Case |
| SR | Spire Inc | MO | GR-2025-0107 | Rate Case: Spire Missouri, filed Nov 2024. decision October 2025 |
| SRE | Sempra Energy | TX | 56545 | Oncor system resiliency plan. $3b |
| CA | 4553-E/3369-G | SDGE | ||
| CA | 6404-G | SoCalGas | ||
| TX | 57707 | Capital tracker DCRF filing & TCOS filing filed in Q1 2025, expect another filing in Q3 2025 | ||
| CA | A25-03-011 | Cost of Capital filing, March 2025 | ||
| SWX | Southwest Gas Holdings, Inc | AZ | G-01551A-23-0341 | Rate Case - approval expected Q1 2025, filed Feb 2, 2024 |
| CA | A2409001 | Rate Case - approval expected Q4 2025, filed Setp 5th 2024 | ||
| FERC | RP24-514-000 | GBBTC Rate case approval expected Q2 2025 | ||
| TXNM | TXNM Energy Inc | TX | 56954 | System Resiliency Plan |
| TX | 57578 | Transmission cost of service, 1st 2025 filing | ||
| NM | 24-00089-UT | Rate Case PNM filed in June 2024 for rates effective July 2025, decision expected Q2 2025 | ||
| NM | 24-00271-UT | 2028 Resource Application, filed Nov 22, 2024 | ||
| UGI | UGI Corporation | PA | M-2025-3054115 | Distribution System Improvement Charge (DSIC) filings |
| WV | Infrastucture Replacement and Expansion Program (IREP) | |||
| WEC | WEC Energy Group, Inc | WI | 6630-TE-113 | Very large customer tariff, Filed on March 31, 2025 |
| 5BS 276 | High Noon Battery Park, anticipated approval Q12025 | |||
| 5BS 280 | Saratoga Battery Park, anticipated approval Q4 2025 | |||
| 5BS581 | Dawn Harvest Battery Park anticipated approval Q4 2025 | |||
| 5BS282 | Badger Hollow Wind and Whitetail wind, anticipated approval Q4 2025 | |||
| 5CE159 | Good Oak Solar, Gristmill, anticipated approval Q12026 | |||
| WI | 5-UR-111 | General rate case WEOCO and WG | ||
| WI | 6690-UR-128 | General rate case WPS | ||
| WI | 6630-CE-316 | Paris Rice generation filed 4/5/24 | ||
| WI | 6630-CE-317 | Oak Creek CT filed 4/5/24 | ||
| WI | 6630-CG-140 | Oak Creek LNG filed 4/19.24 | ||
| IL | 24-0081 | SMP Investication | ||
| MI | U-21-540 | Decision on proposed settlement - MGU | ||
| MI | U-21541 | Decision on proposed settlement- UMERC | ||
| IL | 24-0158 | Future of Gas | ||
| WTRG | Essential Utilities, Inc | OH | 24-910-WW-SIC | water surcharge |
| OH | 24-911-ST-SIC | wastewater surcharge | ||
| KY | 2024-00332 | gas surcharge | ||
| KY | 2024-00346 | Rate Case - Gas | ||
| XEL | Xcel | MN | E002/RP-24-67 | IRP settlement approved Feb 2025 |
| TX | 54284 | SPS RFP issed in July 2024, portfolio filing summer 2025, decision expected 2026 | ||
| CO | 24A-0442E | Colorado resource plan filed Oct 2025 | ||
| CO | 24A-0442E | Wildfire mitigation plan | ||
| TX | 57463 | System resiliency | ||
| ND | 24-376 | ND Electric rate case decision expected Q4 2025 | ||
| WI | 4220-UR-127 | WI Electric and natural gas rate case decision expected Q4 2025 | ||
| MN | 24-320 | Electric rate case filed November 2024, decision expected July 2026 | ||
| MN | 23-413 | Gas rate case approved Feb 2025 |
Kicking the can down the road
March 27, 2025
As seen on LaReg Corp’s docket tracker Kentucky Power Company (KPC, an AEP company) has filed an application with the Kentucky Public Service Commission, Case #2025-00031, requesting approval to defer approximately $11 million in extraordinary operations and maintenance (O&M) expenses resulting from two major storms on January 5 and February 15, 2025. Without this deferral, KPC would need to expense these costs in the first quarter, potentially impacting its financial metrics and credit ratings, which could lead to higher financing costs and affect customers. Similarly, Southwestern Public Service Company (SPS, an Xcel company) filed a request in Texas to defer accounting treatment of excess liability insurance expanses, docket 57856. These accounting requests were typically uncommon.
Accounting orders, offer a more expedient alternative to traditional base rate cases, which can take up to a year to conclude. For instance, in Massachusetts, NSTAR Electric Company (now part of Eversource) filed for an accounting order on November 28, 2002, in D.T.E. 02-78, to address a potential $200–$300 million write-off related to pension costs influenced by stock market fluctuations and interest rate forecasts. The Massachusetts Department of Telecommunications and Energy approved the order by December 31, 2002, allowing NSTAR to implement a pension tracker mechanism to equitably manage pension expense volatility between the utility and its customers.
AEP and Xcel’s current request aims to mitigate the immediate financial impact of the recent storm-related expenses by deferring them as a regulatory asset, subject to regulatory approval. This approach is intended to preserve the company’s financial stability and maintain favorable credit ratings, ultimately benefiting customers by avoiding potential increases in financing costs.
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