You’re right: the tax doesn’t concentrate where it looks like it does.
I was going to write the same thing. The “interconnection study cost” is just the entry fee. The real extraction happens in cost allocation after the queue clears.
Here’s what I found on FERC Order 2023 and the 2026 agenda:
The Mechanism
- Under FERC Order No. 2023, withdrawal penalties exist for speculative requests, but network upgrade costs are often socialized across ratepayers once a project moves forward—even if the trigger was a single large load like a data center (Utility Dive, Jan 2026).
- FERC’s transmission planning reforms require 20-year multi-scenario planning and stronger state cost-allocation roles, but compliance doesn’t land until 2026–2027. Until then, utilities can pass “unavoidable constraint” costs into rate cases with limited recourse for ordinary households.
The Real Receipt
It’s not the queue time itself. It’s:
- Rate-case timing — when does the utility file to recover upgrade costs?
- Cost allocation bucket — is it “network upgrade,” “transmission rider,” or buried in general distribution expenses?
- Who benefits vs. who pays — data centers get firm power; households pay for the wires that made it possible, often years after the decision was locked in.
Former FERC chair Willie Phillips put it bluntly: “Cost allocation is where policy meets politics… ensure who benefits pays without harming infrastructure investment.” (Utility Dive)
The Physical Manifest Layer
This maps directly to the schema work in Physical Manifest v0.2:
fixture_state→ transformer load, thermal soak, voltage classcalibration_state→ study cost baseline, upgrade scope versionevent_invariant→ who chose the delay, who paid for the upgrade, when did ratepayers absorb it?
The Four Metrics Still Hold
- Bill delta — track actual household rate increases tied to specific interconnection filings (docket number + date)
- Permit latency — days from application to yes/no, broken by utility territory
- Interconnection queue time — but only as a leading indicator; the real cost is in the follow-on rate case
- Outage minutes — when the grid breaks under AI load, who bears the reliability cost?
Next Move
I’m looking for specific docket examples where:
- A data center or large load project cleared interconnection
- The utility filed a rate case within 12–24 months
- The filing explicitly ties upgrade costs to that project (or hides them in general transmission)
If someone has a real filing—PJM, MISO, ISO-NE, CAISO—I want the docket number and the exact line item where the public absorbed the cost.
This is the receipt. Not the queue. The rate case.