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A large number of comments were filed in the Pennsylvania Public Utilities Commission’s inquiry into interconnection related issues for large load customers including the Governor’s office raising serious concern that the model tariff represents a voluntary approach, with significant discretion provided to each jurisdictional electric distribution company (EDC).

See highlights of comments below:

Gov. Shapiro Administration raises concern that the model tariff represents a voluntary approach, with significant discretion provided to each jurisdictional electric distribution company (EDC). The Shapiro Administration commends the Commission for acting quickly to provide guidance to EDCs as large load interconnection requests proliferate. Under different circumstances, this voluntary approach might be sufficient. However, the Shapiro Administration believes that recent dramatic shifts in the electricity sector require stronger action to protect reliability and affordability for consumers. The Administration encourages the Commission to finalize a strengthened model tariff, then move to adopt parallel regulatory measures which to create consistency across Pennsylvania EDCs with respect to 1) ensuring reliability, and 2) protecting consumers from undue costs as large data center-driven loads interconnect to the grid.

Data Center Coalition – “recommends that the final model tariff: (1) remain end-use neutral and rely on objective, system-impact criteria; (2) require EDCs to justify contract term, minimum billing demand, exit provisions, and collateral as an integrated package; (3) avoid stacking every risk tool at the most conservative setting; and (4) pair customer commitments with clear utility-side obligations on study timelines, transparency, and delivery milestones.” 

EAP filed in-depth comments that highlighted “several threshold concerns that fundamentally affect how large load policies can and should be implemented in the Commonwealth. A central challenge in Pennsylvania’s framework is that the PUCO’s authority is limited to distribution service and default service procurement and rate design.”

Vistra filed comments in support the PAPUC’s proposed reporting requirements related to large load customers, supports establishing a maximum time for completion of interconnection studies, and a minimum baseline for contract length, minimum demand charge, collateral requirements, and exit fees.

Walmart – “At a high level, Walmart supports either a new Large Load Customer-specific tariff or the inclusion of additional requirements in existing tariffs. While Walmart supports the Tentative Order at a macro level, in the subsequent sections, it provides comments on some key provisions from its perspective as a large commercial and industrial (“C&I”) customer that is increasing its own power usage, albeit not at the scale of hyperscale data centers. Walmart’s primary concerns center on three key issues. First, the minimum load threshold that triggers application of the additional tariff provisions must be set appropriately. Second, Walmart seeks assurance that each utility’s system will have sufficient capacity to support its own growing energy needs. Third, Walmart emphasizes the importance of protecting non-data center customers from bearing stranded costs associated with infrastructure investments made to serve Large Load Customers that ultimately do not fulfill their financial obligations.”

Duquesne filed comments to (1) split federal and state jurisdiction limits applicability of many tariff provisions; (2) consider the model tariff as guidance only and have flexibility with the timelines; and (3) that the model tariff applies to new interconnections after its effective date and existing customers are grandfathered under current tariff rules and contract provisions. 

PECO supports the comments filed by EAP and requests “clarity on some Model Tariff concepts (e.g., notice periods) and recommended that certain issues (e.g., interruptible rates) be deferred to EDC-specific rate proceedings.” 

FirstEnergy commented in support of many of the tentative guidelines and the asked for further investigation into the megawatt threshold.

PPL commented in support of the comments filed by EAP, specifically focusing on appropriate megawatt size designations for large load tariffs, appropriate calculations of contributions in aid of construction, minimum contract terms, interconnection studies and interconnection agreement, minimum demand charges, exit or early termination fees

Read all filed comments here.

PAPUC Docket No. M-2025-3054271
(Docket Initiated Regarding Interconnection And Tariffs For Large Load Customers Including Data Centers)