THE NEW LARGE-LOAD BARGAIN
Power, Cost, Risk + Responsibility

Economic Infrastructure Group | Intelligence Brief | September 2026

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The Large-Load Economy is entering a new phase.

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The Large-Load Economy is entering a more consequential phase. The question is no longer simply whether power can be delivered fast enough to support data centers, advanced manufacturing, semiconductor facilities and other energy-intensive development. The more important question is on what terms that power can be delivered—and who is responsible for the infrastructure, cost, risk and operating obligations that come with it. As utilities, grid operators and regulators respond to unprecedented load growth, power access is becoming more conditional, capital-intensive and negotiated. The result is a new development equation in which electricity is not just an input, but a core part of site strategy, underwriting and regional competitiveness.

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This is The New Large-Load Bargain: Power, Cost, Risk + Responsibility.

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For much of the market, the dominant question has been:

How quickly can a large load get power?

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That question is becoming incomplete.

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The rapid expansion of data centers, advanced manufacturing, semiconductor production and other power-intensive development is forcing utilities, system operators and regulators to confront a broader set of questions:

• Who brings the power?

• Who pays for the infrastructure?

• Who carries the risk?

• And what responsibilities must the load accept in return for service?

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Together, these questions are creating what EIG calls:

The New Large-Load Bargain.

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The shift matters because large-load development is no longer simply a story about electricity demand.

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At sufficient scale, a new project can affect generation requirements, transmission planning, substations, resource adequacy, infrastructure investment, system operations and customer costs.

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The relationship between development and the grid is changing with it.

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WHY THIS MATTERS NOW

Electricity demand is rising at the same time that the infrastructure required to serve it can take years to plan, permit, finance and construct.

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The International Energy Agency projects that data centers will account for nearly half of U.S. electricity-demand growth through 2030. Globally, data-center electricity consumption is projected to more than double to approximately 945 TWh by 2030.

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The U.S. Energy Information Administration estimates that servers alone accounted for approximately 7% of U.S. commercial-sector electricity consumption in 2025. By 2050, server electricity use could reach 22%–33% of commercial-building electricity consumption, depending on the scenario.

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At the same time, the generation required to support the next wave of electricity demand faces its own execution challenge.

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At the end of 2025, approximately 8,200 generation and storage projects representing more than 2,060 GW were actively seeking U.S. grid interconnection. Only about 13% of capacity entering queues between 2000 and 2020 had reached commercial operation by the end of 2025, while the median development period for projects completed in 2025 exceeded five years.

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That creates a structural mismatch:

Large-load demand can emerge faster than the infrastructure required to serve it.

And that mismatch is beginning to reshape the commercial relationship between large electricity users and the grid.

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THE BIG PICTURE

Different states, utilities and regional grid operators are developing different approaches.

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In June 2026, the Federal Energy Regulatory Commission opened proceedings involving all six regional transmission organizations and independent system operators under its jurisdiction, directing them to justify or reform rules governing the integration of large electricity users such as data centers and manufacturing facilities. FERC's proceedings address issues including consumer protection, reliability, cost recovery, transmission service and large-load integration.

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Texas offers another indication of the scale of the issue.

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As of June 2026, ERCOT reported tracking more than 438,000 MW of large-load requests, with nearly 89% associated with data centers. Texas has responded by moving qualifying projects into a systemwide batch-study process designed to evaluate available grid capability and transmission requirements more systematically.

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The Large-Load Economy is therefore moving beyond the simple question of whether demand exists.

Demand is visible.

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The harder question is:

Under what conditions can that demand become executable?

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POWER

Who supports the incremental load?

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Historically, the large customer approached the utility primarily from the demand side:

We need power. How quickly can you deliver it?

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The emerging conversation increasingly asks another question:

What supports that demand?

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A request for 300 MW, 500 MW or 1 GW does not by itself explain how that electricity will be generated or delivered.

The answer may depend on:

• new generation;

• existing generation;

• transmission capacity;

• new substations;

• energy storage;

• behind-the-meter resources;

• flexible load;

• phased service;

• or combinations of these resources.

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This creates an important distinction between power proximity and power deliverability.

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A transmission line may cross a property without having sufficient capacity to serve the proposed development.

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A utility may be able to provide initial service while requiring major infrastructure before full buildout.

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A project may receive service only if it accepts certain operating limitations.

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Another project may need additional generation before its full electricity demand can be supported.

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The implication for developers is significant:

• Power strategy is becoming part of development strategy.

• Generation procurement, storage, co-location, flexible demand and other energy solutions are moving from supporting considerations toward potential site-enabling infrastructure.

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COST

Who pays for the infrastructure?

The second part of the bargain is financial.

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Large loads can require substantial investments in:

• transmission;

• substations;

• transformers;

• switchyards;

• generation;

• distribution infrastructure;

• and other grid upgrades.

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The regulatory concern is increasingly straightforward:

If infrastructure is constructed for a major load and the project fails to materialize, who absorbs the cost?

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The answer is becoming increasingly important to regulators and existing utility customers.

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FERC's June proceedings specifically contemplate Cost Recovery Agreements intended to address situations in which grid infrastructure is constructed for a large customer that ultimately does not appear as expected.

Individual states and utilities are moving in the same direction.

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Virginia has approved a separate rate class for certain large Dominion Energy Virginia customers. Beginning in 2027, qualifying new customers face a minimum 14-year service obligation, minimum payments covering at least 85% of transmission and distribution costs, and, for customers without sufficient credit, collateral requirements that can cover up to 60% of minimum contract charges.

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Ohio provides another example.

AEP Ohio's approved data-center tariff includes a 12-year commitment period, minimum-demand requirements reaching as high as 85% of contracted capacity, financial-viability requirements, collateral provisions and exit obligations.

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By February 2026, developers had signed binding contracts under the tariff covering 5,642 MW of additional data-center load, on top of more than 12,000 MW contracted before the tariff took effect.

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This changes the development equation.

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Grid-access obligations are becoming development capital.

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The relevant question is no longer simply:

What will electricity cost?

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It increasingly becomes:

What must the project commit, guarantee or finance before electricity can be delivered?

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That distinction can materially affect project economics.

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THE RISK

Who carries the consequences when assumptions fail?

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Cost asks who pays.

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Risk asks who absorbs the consequences when the development does not proceed according to plan.

Large-load development can create several forms of exposure.

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Development risk:
The project is delayed or never built.

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Ramp risk:
Electricity consumption grows more slowly than forecast.

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Infrastructure risk:
Transmission, generation or substations arrive later than the development.

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Resource-adequacy risk:
Electricity demand arrives faster than supporting generation.

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Curtailment risk:
Power may be available, but only under service terms that permit electricity consumption to be reduced under certain conditions.

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Operational risk:

• The facility behaves differently than expected during a disturbance.

• These risks increasingly matter because infrastructure investments can be substantial and long-lived.

• Utilities must decide how much infrastructure to build.

• Regulators must determine who should pay.

• Developers must determine what commitments they can realistically make.

• Investors must decide whether those commitments can be financed.

• And existing customers increasingly want assurance that they will not inherit the cost of projects that fail to materialize.

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This is turning project credibility into an infrastructure issue.

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RESPONSIBILITY

What happens after the project connects?

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One of the most important developments in 2026 illustrates why the New Large-Load Bargain extends beyond obtaining electricity.

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On July 22, nearly 4,000 MW of data-center load unexpectedly disconnected from the PJM grid in Northern Virginia during a system disturbance and switched to backup generation.

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PJM and Dominion operators had to manage the resulting imbalance between electricity generation and demand, along with voltage and frequency effects.

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PJM said the event was the third measurable large-load disconnection event in two years and subsequently proposed additional reliability requirements for computational loads.

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The event exposes a second side of the large-load problem.

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The grid must plan for:

• What happens when enormous amounts of load arrive?

• But increasingly also:

• What happens when enormous amounts of load suddenly disappear?

• This changes the nature of responsibility.

• Utilities and grid operators increasingly need information concerning:

• project phasing;

• load ramps;

• backup generation;

• transformer configurations;

• protection systems;

• voltage behavior;

• facility operating characteristics;

• and other technical conditions.

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The underlying principle is becoming increasingly important:

If a project is large enough to materially affect the grid, the grid may increasingly expect the project to behave like part of the grid.

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Large loads are therefore becoming something more than electricity customers.

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They are becoming infrastructure participants.

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SPEED-TO-POWER IS BECOMING AN INCOMPLETE QUESTION

Speed still matters.

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The ability to energize a project faster than competing markets can create substantial value.

But speed without certainty can also create risk.

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A market that promises power quickly but depends on unresolved infrastructure, uncertain cost allocation or undefined service conditions may ultimately offer a weaker proposition than a market with a slightly longer timeline but a clearly defined pathway.

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The competitive question therefore needs to evolve.

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Not simply:

How fast can we get power?

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But:

How quickly can we establish a credible, financeable and durable pathway to power?

That distinction will increasingly matter to both developers and capital providers.

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THE SIGNAL

The Large-Load Economy is not running out of demand.

It is entering a more disciplined phase.

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The first phase of the market focused on:

• Who wants power?

• The second focused on:

• Where is power available?

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The next phase increasingly asks:

On what terms will the infrastructure system agree to serve that demand?

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Those terms increasingly reconcile four competing priorities:

• Growth with reliability.

• Speed with infrastructure.

• Private investment with customer protection.

• Development opportunity with long-term responsibility.

• That is the emerging bargain.

• And it changes the meaning of competitive advantage.

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The premium may no longer belong simply to the land with the biggest advertised power number.

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It may increasingly belong to the places capable of assembling:

POWER + COST + RISK + RESPONSIBILITY

into a credible development proposition.

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That is the New Large-Load Bargain.

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CONTINUE THE INTELLIGENCE

This public brief introduces the market forces reshaping large-load development.

The full EIG Intelligence Brief: The New Large-Load Bargain — Power, Cost, Risk + Responsibility examines the emerging structures in greater depth for:

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• U.S. Markets

• Service Structures

• Nominal and Executable Power

• Infrastructure Dependency

• Capital Requirements

• Developers

• Regions

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ECONOMIC INFRASTRUCTURE GROUP

Infrastructure | Energy | Capital | Policy | Place-Based Investment

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EIG produces intelligence on the infrastructure, policy, capital and market conditions shaping economic development and place-based investment.

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This material is provided for informational and educational purposes only and does not constitute investment, financial, engineering, legal or regulatory advice.

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Access the full EIG Intelligence Brief for the deeper analysis. 

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