This en banc hearing, approved by a unanimous vote of the Commission on March 27, 2025, examined how to ensure a fair, transparent, and forward-looking approach to connecting high-energy users to the grid while protecting existing utility customers.
Hearing Witnesses/Testimony
The agenda for the proceeding included three expert panels, representing the following perspectives related to large-load energy demand and growth--
Large Load Customers
-- Amazon Data Services Inc. - Michael Fradette, Principal, Energy Services
“The rapid growth of electricity demand presents both challenges and opportunities for the US energy infrastructure. We understand the Commission's mandate to establish just and
reasonable tariffs that provide open and non-discriminatory access to public utility systems while protecting existing customers from undue burdens and costs.
“At AWS, we share these concerns and are committed to being responsible partners in grid development and energy consumption.
“We've demonstrated this commitment through our Climate Pledge goal of reaching net-zero carbon emissions by 2040.
“Additionally, all of the electricity consumed across our operations – including our data centers, corporate buildings, grocery stores, and fulfillment centers – is matched with 100% renewable energy, seven years ahead of schedule.
“We recognize that bringing on new sources of baseload, carbon-free energy is critical to
meeting society's growing electricity needs and meeting our customers' demands.
“It is one of the reasons we are investing in a diverse portfolio of energy sources, including solar, wind, and advanced nuclear technologies.
“For instance, we've recently invested over $1 billion dollars in carbon free nuclear initiatives, including projects like the Susquehanna Nuclear Facility, and our equity investment in X-Energy to bring about 5 GW of new nuclear capacity by 2039.
“Amazon also supports expanding and modernizing the U.S. power grid, including
upgrading the physical infrastructure with advanced technologies (e.g., smart meters, grid enhancing technologies, battery storage), and implementing policies that enable rapid modernization, so that we can realize the benefits of a modernized power grid built on low or carbon-free power sources more quickly.
“We are taking tangible steps to support these efforts. We are innovating across the energy sector to bring new carbon-free power sources forward, encouraging investment in grid modernization technologies, and urging policymakers across the country to implement policies to accelerate grid modernization efforts.
“That said, speed to market, coupled with ensuring we pay for our fair allocation of the costs to serve the electricity we consume, continues to be a priority as we work to meet growing demand from our customers, which directly influences how and where we make investments in both data center growth and energy development.”
-- Google LLC - Brendon Baatz, Energy Market Development
“Google is proud to be a national leader on clean energy procurement. In 2007, Google committed to carbon neutrality in its operations.
“A decade later, with new tools at our disposal, we took another leap forward by becoming the first major company to match 100% of our annual electricity consumption with renewable sources. And we have done so since 2017 even as we have continued to grow.
“In 2020, Google announced its intention to power its data centers with 24/7 carbon-free energy by 2030.
“That means we seek to match carbon-free generation with our consumption on an hourly basis, drawn from generating resources in the same market as our load.
“For our existing sites in PJM, this means that we are working to bring on a portfolio of new, round-the-clock carbon-free generation resources that can produce as much or more energy each hour than we consume.
“As one example, in 2021, we partnered with AES Clean Energy to develop a portfolio of carbon-free energy resources to power our data center facilities in Virginia.
“We expect the partnership to add 500 MW of new carbon free generation and provide our data centers with 90% carbon free energy measured on an hourly basis by 2030.
“Google is focused across our footprint on developing new models that can help bring new, carbon-free resources to market while fully covering all costs associated with these developments.
“In Nevada, Google partnered with Fervo Energy to support development of a
first-of-its-kind enhanced geothermal project. Fervo's project came online in the fall of 2023 and is currently generating about 15 MW of clean firm power on Nevada's grid.
“Building on the pilot's success, we partnered with the local utility, NV Energy, to introduce an innovative rate structure, the Clean Transition Tariff ("CTT"), that enables us to quickly bring enhanced geothermal from pilot to scale, supporting 115 MW enhanced geothermal to power our operations in Northern Nevada.
“In addition, Google recently announced a deal with Kairos Power to directly fund and deploy 500 MW of advanced nuclear generation.
“And in the Carolinas, Google is partnering with Duke Energy to develop a CTT to bring new clean resources onto the grid. We view these innovative partnerships as critical to meeting the challenge before us.
“As a result of our efforts, we are one of the world's largest corporate purchasers of clean energy and we have brought nearly 14 GW of new, clean generation online worldwide. We estimate that we will spend approximately $16 billion by 2040 on clean energy purchases.”
-- Vantage Data Centers - Shawn Smith, Vice President, Utility & Regulatory
“Vantage is interested in developing hyperscale data center campuses in Pennsylvania to meet the growing demand for digital infrastructure.
“By one estimate, data center capacity in the United States will grow from 25GW in 2024 to 80GW in 2030.1
“To continue to develop this infrastructure, it is critically important that the regulatory environment facilitates appropriate cost allocation for electricity generation and transmission, and the necessary approvals on a timescale that allows us and Pennsylvania to meet this unique moment in our nation’s history.
“We appreciate the Commission’s leadership in opening this dialogue on how interconnection and tariffs can be modernized to better serve large load customers—while protecting the interests of all ratepayers and ensuring system reliability.
“Today, I’d like to offer four recommendations for your consideration, based on our real-world experience navigating large load interconnections and co-located generation in Pennsylvania and across North America.
“These ideas focus on encouraging generation co-location, aligning financial requirements with project risk, applying consistent credit standards, specific contract terms that align with risk utilities and large load customers are taking, and tariff provisions that balance the needs of all parties.
[Note: Vantage Data Centers has a goal of reaching net zero carbon emissions for scopes 1 and 2 by 2030. Vantage Data Centers now has 10 locations across North America and EMEA powered in part by renewable energy, from hydro to tidal and wind.]
-- Data Center Coalition - Lucas Fykes, Director of Energy Policy
“The importance of data centers is difficult to overstate, in part because nearly every sector of the modern American economy relies on cloud computing—a service facilitated by data centers—in some way.
“The importance of data centers can be measured financially, however. DCC commissioned a PwC 2025 impact study that shows the data-center sector is a major economic force.4 In 2023, it supported 4.7 million U.S. jobs, including 603,900 direct jobs—up 51% since 2017.
“Those roles generated 404 billion in wages, a 93% jump over the same period. Direct contributions added 231 billion to GDP. Total annual contributions to U.S. GDP in 2023, including direct, indirect, and induced effects totaled 727 billion.
“Each data-center job now underpins more than six additional jobs across the economy. The industry also delivered 162.7 billion in federal, state, and local tax revenue in 2023, 146 % above 2017, highlighting its growing fiscal value.
“After nearly two decades of relatively flat electricity consumption, the U.S. is experiencing a significant increase in power demand driven by several economic growth trends, including the onshoring of new manufacturing, widespread electrification of buildings, industry and electrification, hydrogen fuel production, and growth in demand for data center services.
“As noted by Lawrence Berkeley National Laboratory in the 2024 U.S. Data Center Energy Usage Report, “This surge in data center electricity demand…should be understood in the context of the much larger electricity demand that is expected to occur over the next few decades from a combination of electric vehicle adoption, onshoring of manufacturing, hydrogen utilization, and the electrification of industry and buildings.”
“Supporting growing electricity demand through timely and prudent investments in new generation, transmission, and distribution infrastructure – along with investments in energy efficiency, grid enhancing technologies, and other innovative strategies – is essential to the nation’s economic growth, global competitiveness, and national security.”
Electric Distribution Companies
-- Duquesne Light Co. - C. James Davis, Director, Rate, Energy Procurement and Federal/RTO Affairs
“As the region has transformed and continues to evolve, Duquesne Light stands ready to reliably and safely meet the needs of the community it serves.
“Data centers and specifically artificial intelligence, or AI, is transforming how we all live and work.
“But the extreme energy demands of data centers, if not managed correctly, could result in grid impacts and unintended shifting of costs to other customers.
“To put this energy demand into perspective, consider that in 2024, DLC’s Network Service Peak Load was nearly 2,700 MW.
“A hyperscale data center will commonly range from 60 MW to several hundred megawatts.
“There are a few examples within Pennsylvania where hyperscale data center have the potential to scale up to 900 to 1,000 MWs.
“ A single data center could account for as much as 30% of the current peak load in our entire service area in Allegheny and Beaver counties.”
-- FirstEnergy Pennsylvania - Kelly Gower, Vice President, State Finance & Regulatory
-- PECO Energy Company - Richard Webster, Vice President, Regulatory Policy & Strategy
“To aid in the Commission’s consideration of designing a proposed model tariff, my testimony is focused on some of the most significant challenges PECO has experienced in connection with large load customers.
“First, many contemplated large load projects are substantially larger than customer projects we have served in the past. PECO is working with a number of large load projects that are considering connecting to PECO’s distribution system.
“Four of these projects, which have reached an advanced stage, would potentially increase PECO’s overall peak demand by 3.8 gigawatts, resulting in an almost 40% increase in the demand on PECO’s distribution system.
“PECO is also studying an additional 24 proposed large load projects that, if implemented, would add another 8 gigawatts of demand to our system.
“This potential demand growth is unlike anything we have dealt with before and is a major departure from almost two decades of relatively flat growth.
“Second, the number and size of these projects makes it challenging to evaluate their potential effects on the distribution system.
“Large load projects have the potential to impact multiple EDC service territories as well as regional transmission systems, resulting in an extremely dynamic modelling and analysis environment.
“This means that it may be necessary to study proposed projects in groupings or clusters, and impact analysis completed one day can be altered the next day by interconnection requests filed in other regional transmission systems, even in other states.
“In addition, the number and type of required interconnection studies and agreements can vary situationally based on site-specific and customer-specific parameters, which may limit the degree of short-term certainty that EDCs can provide to these customers on the time and cost of new interconnections.
“ Load profiles for data centers can also be quite different from those of other types of large load, such as industrial customers, and even the load profiles among data center
customers can vary depending upon a customer’s potential to hyperscale or provide increasingly mobile service over time.
“Third, the advent of large load customers is occurring in the context of a rapidly evolving external environment.
“The Federal Energy Regulatory Commission, regional transmission organizations, independent system operators, and state utility commissions across the country are evaluating issues associated with the proliferation of data centers.
“Some states are competing for data center- and artificial intelligence-related development, while others are or may be considering imposing barriers to or guard rails around such development.
“Large load development is also susceptible to the persistent supply chain and workforce challenges impacting large infrastructure development more broadly in our nation, and economic uncertainty has the potential to alter the speed and trajectory of demand growth.
“Data center and artificial intelligence technology are also rapidly evolving, adding uncertainty to projected energy demand forecasts.
“In short, change can occur quickly in this space, and the future is uncertain.”
-- PPL Electric - Joe Lookup, Vice President, T&D Planning & Asset Management
“PPL Electric is directly seeing the growth of data center development in Pennsylvania, with requests in advanced stages in excess of 9 GW of new load as reported during PPL Corporation’s year-end earnings call.
“To put this into perspective, PPL Electric's current summer peak is 7.5 GW, and the new data center requests are poised to more than double PPL Electric's system peak within the next 5-6 years.
“PPL Electric has invested in the reliability and resiliency of its transmission system to better serve its customers.
“An additional benefit of this investment is that PPL Electric now stands ready to serve this influx of load with large load customers only having to cover the incremental cost of interconnecting their facilities."
"When interacting with prospective large load customers, perhaps the biggest question that we hear is not about transmission capacity, but whether generation capacity will be sufficient to serve this increased load.
“While not directly the subject of this hearing, any PUC policies that arise from this docket should also consider the impact that data centers will have on resource adequacy, particularly the effects on capacity costs and system reliability.
“To that end, I’d refer you to PPL’s comments on resource adequacy and EDC investment in generation related to the PUC’s November technical conference at Docket No. M-2024-3051988."
Statutory Consumer And Public Advocates
-- Office of Consumer Advocate - Darryl Lawrence, Acting Consumer Advocate
“I will first highlight three contextual issues that the Commission and Staff should consider when developing the proposed model tariff and then discuss three critical elements that the tariff should contain.
“First, these large loads have many similarities to generators.
“Of course, large load customers consume electricity instead of generating it. However, their size, transmission and distribution-related costs, potential for stranded investment, and interconnection safety and reliability issues are more similar to those of generators than the typical industrial customer.
“Furthermore, many large load customers will have primary or backup generation of commensurate size to its load, making them both a large load and a large generator.
“Thus, large load customers may need specialized studies and additional transmission and distribution infrastructure that typical industrial customers do not require.
“Second, the companies behind developing these large load customers are generally highly sophisticated and well-financed.
“They have the technical, managerial, and financial resources to work with utilities, manage the interconnection process, and safely and reliably operate their large load facilities.
“There are many ways to reduce uncertainty in the time and cost of interconnections, which is an important contributor to economic development.
“However, as with the case of hundreds of millions to billions-dollar investments, completely eliminating uncertainty may not be possible.
“The risks of these projects should not lead to stranded investment, not only because of fairness, but because these large load customers are in the best position to manage the risks of their projects.
“Third, the connection between economic development and electricity tariffs is important for large load customers and other ratepayers.
“Any stranded investments from large load customers paid by ratepayers hinders economic development by raising the cost to businesses and reducing spending by residents.
“The impact of a clothing store that reduces its hours for its staff because families tighten their clothing budgets is not visible to the public.
“Its economic impact adds up across families and is just as important as the evident economic activity of building a data center.
“Thus, the pursuit of economic development, in addition to fairness, points to protecting ratepayers from stranded investment.”
-- PAPUC - Allison Kaster, Chief Prosecutor, Bureau of Investigation & Enforcement
“I&E recognizes that Pennsylvania is an attractive location for data center operators due to low-cost rural land and property taxes as well as a currently abundant supply of natural gas and excess electricity; however, such growth also raises some concerns.
“For example, the impact data centers may ultimately have on electric rates is perhaps an unavoidable outcome of the proliferation of data center needs.
“Virginia lawmakers commissioned a study that found that Virginia’s energy usage is expected to increase 183% by 2040, largely driven by data centers.
“Growth of this magnitude is going to require a likely unprecedented increase in generation and transmission capacity in the coming years.
“The capital costs of those necessary expansions will drive up the commodity cost for all electric users in the PJM region, regardless of where the data centers are actually sited.
“Beyond the almost certain impact on electric rates, it is important to remember that data centers can also impact the demand for other resources.
“For example, there is the potential impact to gas costs if a data center’s natural gas backup power source entails capital investments to increase capacity and the natural economic fallout of demand driving the commodity price.
“Moreover, data centers routinely require a large water supply for cooling purposes, which could impact system pressures and water source dependability, especially given the recent history of droughts and usage restrictions in Pennsylvania.
“Therefore, it is important not to lose sight of other potential impacts on Pennsylvania’s utility customers.”
“Finally, establishing protections for ratepayers from stranded costs must be at the forefront.
“For example, any determination of contributions in aid of construction that relies on an anticipated usage level and associated revenue should contain a provision requiring an alteration of assigned rates or an additional construction contribution in the event that anticipated usage levels do not materialize, or the project is terminated before completion.
“In short, all efforts must be taken to ensure that utility ratepayers bear no liability for stranded investments.”
Topics Discussed
The Commission is seeking testimony and input on a range of topics that will help inform future policy, including the development of a model tariff to guide how large load customers connect to the grid.
Topics include:
-- Appropriate MW size designations for large load tariffs.
-- Deposits or financial security from large load customers.
-- Appropriate calculations of contributions in aid of construction.
-- Minimum contract terms.
-- Maximum times for interconnection studies and agreements.
-- Appropriate fees or expenses for interconnection studies.
-- Load ramping schedules for customers that may phase in their usage.
-- Exit or early termination fees.
-- Distinctions in tariff designs for firm service versus interruptible large load customers.
-- Large customers bringing primary or back-up generation to serve their load, and any prudent standby rates.
-- Transparent cost structures for interconnection.
-- Optionality for infrastructure upgrades to be made directly by prospective interconnecting large load customers, and appropriate tariff subcategories to accommodate such option.
-- Expedited interconnection for users willing to construct infrastructure or system upgrades at their own expense.
-- Best practices learned from other jurisdictions.
-- Any other procedures, rules, or tariff designs that can facilitate the efficient and timely interconnection of this unique category of electric customer.
Additional Comments Invited
As outlined in the initial motion by PUC Chairman Stephen M. DeFrank, the Commission will accept comments from interested parties for 30 days following the hearing.
Interested parties may file comments and reply comments to the En Banc hearing and testimony with the Secretary of the Commission at Docket Number M-2025-3054271. All comments are due on or before May 27, 2025.
At the conclusion of the comment period, interested parties may file reply comments with the Secretary of the Commission at Docket Number M-2025-3054271. Reply comments are due on or before June 11, 2025.
All comments and reply comments should include the Docket Number M-2025-3054271 on the first page of your filing and be filed by opening and using an eFiling account through the Commission’s website or mailed to the Secretary by overnight delivery to:
Secretary
Pennsylvania Public Utility Commission
400 North Street
Commonwealth Keystone Building, 2nd Floor
Harrisburg, Pennsylvania 17120
Hearing Background
The April 24 hearing is part of the PUC’s broader effort to assess the growing presence of hyperscale data centers and other energy-intensive operations across Pennsylvania.
These large customers can bring benefits such as economic growth and innovation, but they also raise important questions about grid reliability, cost-sharing for infrastructure upgrades, interconnection procedures, and equitable treatment of existing customers.
For more background, read the initial press release announcing the hearing and Chairman DeFrank’s motion convening the hearing.
More Information
Visit the PUC’s Large Load Customers Hearing webpage for the final agenda, the testimony submitted by the panelists and other information on the hearing.
Documents will be posted at PUC Docket No. M-2025-3054271.
(Photo: Rendering of proposed Homer City data center and power plant complex.)
NewsClips:
-- Post-Gazette: Pittsburgh Electricity Supplier Urges Careful Planning For Data Center ‘Extreme Energy Demands’
-- PA Capital-Star: Data Centers’ Demand For Electricity Brings Unprecedented Opportunity, Challenges
-- TribLive: As Data Centers Spread, Their Leaders Push For Transparency, Consistency In State Regulations [PUC Hearing]
-- AP-Marc Levy: Big Tech’s Soaring Energy Demands Are Making Coal-Fired Power Plant Sites Attractive [Not Necessarily The Plants Themselves]
-- TribLive Editorial: Data Centers’ Power Usage Must Be Monitored And Managed
-- Post-Gazette: PUC Tees Up Hearing On Data Centers As A.I. Critic Says, ‘We Want To Be A Little More Cautious’
Resource Links - PA Data Centers:
-- PUC Launches Review Of Electric Grid Impacts From Data Center Growth, Sets April 24 Hearing [PaEN]
-- PUC Invites Stakeholder Comments On The Issue Of The Adequacy Of Electricity Supplies In Pennsylvania [Background On Issue] [PaEN]
-- 30 Stakeholder Comments Received By PUC On Adequacy Of Electricity Supplies In Pennsylvania; Increasing Natural Gas Power Plant Reliability To 90-95% Would Mean No Imminent Capacity Problem [PaEN]
-- Pennsylvania’s Electric Grid Is Dependent On One Fuel To Generate 59% Of Our Electricity; Market Moving To Renewables + Storage [PaEN]
-- Wall Street Journal: Homer City Coal Power Plant Was Just Imploded To Make Way For An A.I. Data Center, The Country’s Largest Natural Gas Power Plant [PDF of Article]
-- DEP Issues Air Quality Permit For Nova Energy LLC Cryptocurrency Data Center In Venango County [PaEN]
Resource Links - PJM Issues:
-- PA Senate Republican Leader: ‘Every Consumer Of Electricity In This Commonwealth Is Going To Pay More;’ ‘What You’re Going To Face Is Going To Be Really Unpleasant’ [PaEN]
A Oil & Gas Industry Public Notice Dashboards:
-- PA Oil & Gas Weekly Compliance Dashboard - April 12 to 25: Another Abandoned Shale Gas Water Impoundment; 18 More Abandoned Conventional Wells; Exposed Gas Pipeline Crosses Stream [PaEN]
-- DEP: Abandoned Shale Gas Water Impoundment Not Used For 7 Years Cited For Not Being Restored In Clarion County [PaEN]
-- Conventional Oil & Gas Facility Owners Must Now File A Methane Emissions Compliance Report By June 1, 2025 Required By A 2022 DEP Methane Pollution Reduction Rule As A Result Of Court Settlement [PaEN]
-- DEP To Hold May 1 Virtual Update On State Response To Energy Transfer/Sunoco Twin Oaks Pipeline Leak In Bucks County [PaEN]
-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - April 19 [PaEN]
-- PA Oil & Gas Industrial Facilities: Permit Notices, Opportunities To Comment - April 26 [PaEN]
-- DEP Posted 96 Pages Of Permit-Related Notices In April 19 PA Bulletin [PaEN]
-- DEP Posted 77 Pages Of Permit-Related Notices In April 26 PA Bulletin [PaEN]
Related Articles This Week:
-- PublicSourceNews.org: Setback On Setbacks: PA Environmental Quality Board Tables Consideration Of New Limits On Drilling Near Building, Water Sources
-- Farm & Dairy: PA Environmental Board Delays Vote On Petition To Increase Shale Gas Well Setbacks
-- Post-Gazette Letter: I Applaud Bucks County Commissioners Who Had The Guts To Challenge The Natural Gas Industry For Contributing To Climate Crisis - Cat Lodge, Washington County Resident
-- Susquehanna River Basin Commission: Low Stream Flows Trigger Restrictions On 29 Shale Gas Water Withdrawals [PaEN]
-- Susquehanna River Basin Commission Approved 58 Shale Gas Well Pad Water Use General Permits In March; 142 In 2025 [PaEN]
-- Environmental Health Project Launches AirView Public, New App To Help Communities Protect Residents From Oil & Gas Pollution; Communities Can Join Today [PaEN]
-- PUC Hearing On Data Center Growth Impacts Finds 30-40% Of Utility Demand Could Be From Data Centers; Concerns About Stranded Costs; Major Commitments To Net-Zero Carbon Emissions Energy Use [PaEN]
-- Reuters: FERC Denies Rehearing On Colocated Amazon Data Center Energy Pact In Luzrne County
-- House, Senate Members Introduce Gov. Shapiro's 'Lightning' Energy Plan To Lower Energy Costs, Create Jobs, Protect Pennsylvania From Global Energy Instability [PaEN]
-- Gov. Shapiro: FERC Approves Settlement With PJM To Prevent Unnecessary Prices Hikes, Save Consumers Over $21 Billion On Electric Bills [PaEN]
-- Utility Dive: Ratepayer Advocates: FERC Should Order PJM To Rerun Last Electricity Capacity Auction; Could Lead To $5 Billion In Consumer Savings
-- New Report: Fixing PJM’s Broken Electric Generation Approval Process Can Lower Energy Costs, Create Jobs Across The Mid-Atlantic [PaEN]
-- North American Electric Reliability Corp. Files Proposed Cold Weather Standard To Improve Reliability For Natural Gas-fired, Other Electric Generators [PaEN]
-- DEP Releases 2024 Climate Change Action Plan Update; 2024 Climate Impacts Assessment Report [PaEN]
-- Eleven Coal, Coal-Waste Power Plants In Pennsylvania Now Covered By Presidential Exemption From 2024 Mercury, Hazardous Air Pollutant Regulation For 2 Years [PaEN]
-- AP-Marc Levy: Big Tech’s Soaring Energy Demands Are Making Coal-Fired Power Plant Sites Attractive [Not Necessarily The Plants Themselves]
-- PUC Commissioners Urge Congressional Action To Preserve $19 Million In Remaining LIHEAP Funds For PA This Year [PaEN]
-- Energy Association Of PA [Utilities] Calls For Protection Of LIHEAP Low-Income Home Energy Assistance Program
-- PUC Announces May 6, 7 Hearings On Proposed 15.7% Rate Increase For Philadelphia Gas Works [PaEN]
-- PUC To Investigate Proposed 11.4% Increase In Columbia Gas Natural Gas Rate [PaEN]
-- Warren Times: Instead Of ‘Drill, Baby, Drill,’ US Rig Counts Falling, Layoffs Increasing
-- Financial Times: President’s Tariff Talk Roils US Oil, Gas Industry In Bedrock Republican Territory
-- The Economist: America Won’t Be Able To Bully The World Into Buying More US Natural Gas
-- E&ENews/Politico: President’s Push For More LNG Gas Exports Risks Domestic Price Surge
-- Financial Times: Growth In Oil Demand Expected To Slow Sharply As A Result Of President’s Tariffs
-- Financial Times: China Stopped Buying US LNG Gas Feb. 6 Due To Trade War
-- Marcellus Drilling News: EIA Annual Energy Outlook: Oil And Natural Gas Demand Peaks In 2027 and 2032 [PDF of Article]
[Posted: April 24, 2025] PA Environment Digest
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