Every quarter, the NC Clean Energy Technology Center counts what the states did. The Q3 2026 edition of its 50 States of Power Decarbonization report, released November 5, tallies 497 actions across 49 states and Puerto Rico — regulatory dockets, passed legislation, executive orders, filed resource plans, and generation capacity changes. This quarter’s edition has an unusually clear throughline: the large-load wave has stopped being a tariff problem and become a planning problem.
That shift matters because of where planning decisions live: a tariff sets the price of serving a data center, while a resource plan decides what gets built to serve it, what retires, and who bears the risk if the load never arrives. When load growth migrates from one docket to the other, the questions change from “what should this customer pay?” to “what kind of system are we building, and for whom?”
The quarter in numbers
The composition tells the story. Electric generation capacity changes — utilities seeking to build, acquire, convert, or retire plants — led with 151 actions across 40 states and Puerto Rico. Large-load customer treatment followed with 138 actions in 40 states: new tariffs, interconnection rules, contract terms, and on-site generation options for data centers and other big customers. Studies and investigations accounted for 63, planning and procurement rules for 60, integrated resource plans for 45, clean energy targets for 26, and emissions targets and carbon policies for 14.
Two things stand out. First, large-load treatment is no longer a niche docket. At 28 percent of all actions, it is effectively tied with generation capacity changes as the most active category — and it was the single most common category in the prior quarter, with 155 actions in Q2. Second, the planning categories are growing around it: 60 actions rewrote the rules governing how utilities plan and procure, and 45 tracked integrated resource plans filed or under review. The most active states were California, North Carolina, and Texas, then Louisiana, Maryland, New Jersey, Oregon, and Wisconsin; the total fell from 564 in Q2, but the planning and large-load concentration held. The total counts motion in both directions: Arizona repealed its efficiency standard, its second clean-energy pullback of the year.
What the plans say: gas first, solar close behind
The report’s most consequential numbers are the planned capacity additions in resource plans filed or under review. Across those plans, utilities propose adding 74,937 MW of natural gas, 69,670 MW of solar, 44,068 MW of storage, 17,946 MW of wind, and 12,291 MW of nuclear — while planning 28,238 MW of coal retirements. Gas leads, but only just; solar is within 5,000 MW of it, and storage now exceeds wind by a wide margin.
The prior quarter was similar: 77,810 MW of gas, 72,193 MW of solar, 43,017 MW of storage, 12,615 MW of nuclear, and 12,327 MW of wind, with 26,752 MW of coal retirements. The headline is continuity: utilities planning for large-load growth reach for gas and solar in roughly equal measure. Two caveats matter: these are planned additions in IRPs, not approved projects, and commissions routinely modify or reject a utility’s proposal. And the authors note that large-load demand is already pressuring the retirement side of the ledger — fossil retirements that looked straightforward when load was flat now face the question of what serves the load in the interim.
Trend one: load growth written into the planning process
The report’s first named trend is states considering large-load growth within planning processes. New Mexico regulators created a working group to revise the state’s resource planning rules for large-load growth. West Virginia regulators ordered utilities to submit their next IRPs two years early, citing load growth. The Illinois Power Agency held a stakeholder meeting on data center load for its upcoming Resource Adequacy Mitigation Plan. New Jersey regulators released a resource adequacy report finding data centers the primary driver of adequacy risk in the state, and calling for the cost of serving them to be properly allocated.
Indiana produced the quarter’s most complete statement of the new approach. The Strategic Energy Growth Task Force, established by Governor Mike Braun in 2025, released its final report in July 2026 with ten recommendations. Among them: an expedited approval pathway for large loads committed to paying 100 percent of project costs, a standing principle that large-load customers pay 100 percent of their costs, and a requirement that they cover at least 80 percent of an expedited project’s costs regardless of tenure. The task force’s framing is that current processes do not account for large loads at all — and that the fix is to integrate load growth into planning and resource adequacy, not bolt it on afterward. That is the right diagnosis, and it is harder than it sounds: resource plans were designed for slow, predictable load growth, while a single data center campus can add hundreds of megawatts in a few years — a step change, not a trend.
Trend two: FERC and the regions coordinate on large loads
The second trend runs through Washington. FERC, which has jurisdiction over interstate transmission and facilities connecting at the transmission level, opened reviews into every regional transmission organization’s Open Access Transmission Tariff last quarter, and the Q3 report tracks the regions’ responses. The June 18 show-cause orders directed the six RTOs and ISOs to justify their existing tariffs or propose reforms for large-load interconnection — defining large load as peak demand above 50 MW interconnecting at voltages above 69 kV — with responses flowing in through the summer and fall.
The regional answers are diverging in instructive ways. ISO-New England proposed a Bring Your Own New Generation policy, similar to the Southwest Power Pool’s Conditional High Impact Large Load policy, approved earlier this year. PJM’s governing board approved a new framework for reliability backstop procurement, including a large-load registry that FERC accepted in October while rejecting the curtailment and bring-your-own-capacity elements. The pattern is worth naming: FERC is not writing a single national large-load tariff. It is running six regional proceedings and letting each region’s answer differ. The “bring your own generation” idea — a large load that wants fast interconnection must bring new supply with it — is the most consequential of these experiments, because it converts a transmission problem into a resource problem and puts the obligation on the customer creating the need.
The pause states: New York and Texas
Two of the quarter’s top five developments are governors hitting the brakes. In New York, Governor Kathy Hochul signed an executive order establishing a temporary moratorium on new hyperscale data centers pending a Department of Public Service environmental study. In Texas, Governor Greg Abbott ordered the Public Utility Commission of Texas and ERCOT to audit all data centers in ERCOT’s interconnection queue, with no project moving forward until the audit is complete.
The two pauses are different instruments — a permitting moratorium in one state, an audit precondition in the other — but they share a logic. Both treat the interconnection queue itself as the thing that needs governing — planning actions taken by executive power, for when the planning process cannot keep pace with the queue. Data center opposition has become genuinely bipartisan, with a Democratic governor in New York and a Republican governor in Texas imposing the two broadest statewide restrictions in the country. For planners, load forecasts now carry a new uncertainty: not just whether a customer will arrive, but whether the state will let it.
Trend three: the nuclear turn
The third trend is states promoting the construction of new nuclear generation. Nuclear task forces in Arkansas, Delaware, Iowa, and South Carolina produced final reports on development pathways, California directed its Energy Commission to assess advanced nuclear, and Maryland began a rulemaking for a Nuclear Procurement Program.
New Jersey supplied the quarter’s sharpest example. Governor Mikie Sherrill signed legislation tasking the Board of Public Utilities with developing a program prioritizing affordable, advanced nuclear energy, including a reliable capacity certificate program requiring a proportional share of megawatt-hours sold in the state to come from at least 1,100 MW of qualified nuclear projects. A 1,100 MW target is a meaningful commitment — roughly one large reactor — structured as a market obligation on suppliers rather than a utility build. The nuclear turn should be read alongside the gas numbers, not against them: the IRP data shows utilities planning gas and solar now and nuclear later, while the state actions lay the groundwork for nuclear to be available when the current build cycle matures.
California’s plans: the load-growth test case
California supplied the quarter’s largest single planning event: the state’s investor-owned utilities filed their 2026 resource plans, and the three big utilities — Pacific Gas & Electric, San Diego Gas & Electric, and Southern California Edison — plan in aggregate for 13.7 GW of solar, 5.5 GW of wind, 4.8 GW of energy storage, and 0.7 GW of geothermal by 2035. PacifiCorp’s plan, which runs through 2045 across its multi-state territory, adds 2.2 GW of natural gas and 0.5 GW of nuclear alongside solar, wind, storage, and geothermal. California matters because its planning apparatus is the most developed and its load-growth question the most acute. These plans were written under the state’s 100 percent zero-carbon target, so the gas that dominates other states’ plans is largely absent — and the question is whether 13.7 GW of solar and 4.8 GW of storage, plus imports and existing resources, can serve a load forecast that now includes data centers the planners did not foresee five years ago. If California can absorb large-load growth without reaching for gas, it becomes the model for every other clean-energy state; if it cannot, the gas numbers will keep climbing.
What it means for transmission and adequacy
Here the report’s scope requires a careful reading. The series excludes actions specifically related to transmission and distribution planning, interconnection rules, and permitting and siting — those live in the Center’s companion 50 States of Grid Modernization report, which counted 411 actions in Q3. This report tracks large loads through tariffs, resource plans, and adequacy, not through wires. That boundary is itself informative: large loads interconnect at transmission voltage, so every large-load decision here is, downstream, a transmission decision. When an IRP adds 74,937 MW of gas to serve load growth, the transmission to deliver that power must be planned, permitted, and paid for through processes this report does not track. The FERC OATT review is the one place the two worlds meet. The risk is a seam: generation planned in one docket, transmission in another, neither sized for the other’s assumptions.
The adequacy implications are more direct. New Jersey’s regulators concluded data centers are the primary driver of adequacy risk in the state. The Illinois Power Agency is building data center load into its Resource Adequacy Mitigation Plan. PJM’s new framework includes a large-load registry and interim resource adequacy service — an acknowledgment that the existing capacity construct was not built to register load arriving in hundred-megawatt increments. The technical problem is forecasting: a capacity market or an IRP is only as good as its load forecast, and large loads break methods built on smooth growth.
Who pays
Underneath every trend sits the cost-allocation question. “As demand from new large loads continues to grow, states increasingly factor load growth into long-term resource planning and resource adequacy efforts,” said Justin Lindemann, the Center’s project manager. “From revisiting integrated resource plans to accounting for large loads in resource adequacy, regulators are working to keep pace with data center growth while raising important questions about proper cost allocation.” Indiana’s answer is the bluntest: the large load pays 100 percent. PJM’s answer is procedural: register the load, procure backstop capacity, and sort out the cost later. New Jersey’s answer is analytical: study the adequacy risk first, then allocate. FERC’s answer is structural: rewrite the tariff so the cost of connection and upgrades lands on the customer that triggers them.
What to watch next quarter
Four things will tell us whether Q3 was a turning point or a busy quarter. First, what FERC does with the RTO tariff filings now under review — the bring-your-own and conditional-load models will set the template for every region. Second, the outcome of the Texas audit and whether projects resume moving through ERCOT’s queue, and on what terms. Third, whether Indiana’s recommendations become legislation in the 2027 session, and whether other states copy the 100-percent-cost principle. Fourth, whether the next round of IRPs pushes the gas number higher or bends it down as storage and nuclear options mature.
The deeper signal is not any single number. It is that the planning system is responding to large-load growth in the open — in public dockets, with published reports and named recommendations — rather than behind closed doors in bilateral negotiations between utilities and hyperscalers. That is a healthier way to decide what kind of grid gets built — slower, messier, and more transparent. The 497 actions are the sound of a planning apparatus learning, in real time, to plan for a load it did not expect. The next four quarters will show whether it learned fast enough.