NexPhase Advisory

The Morning Read

Wednesday, July 22, 2026
01  The Bottom Line
The cost-allocation fight over who pays for data-center network upgrades is the defining PJM question this week: FERC's large-load show-cause order acknowledged the risk and left it unresolved, and ratepayer advocates from five states are pressing the point. The pressure to route around the standard queue is spreading west, WIRAB is drafting a large-load interconnection framework for a region that has none. Meanwhile BlackRock's ~$52B week, a $12B debt sale for Meta's ~1 GW El Paso campus plus the close of its $40B Aligned acquisition, shows hyperscaler capital moving faster than power can be contracted, even as El Paso itself tightens data-center zoning. Developers without a firm interconnection position or a credible behind-the-meter power plan are already behind.
02  Signal of the Day
National & Policy
Intertek CEA · 2026-07-21
The FEOC compliance problem for BESS developers is not abstract. Any project beginning construction after December 31, 2025 needs product-level supply chain diligence that most procurement teams are not structured to deliver, and there is no partial remedy if a manufacturer is later designated a Prohibited Foreign Entity. The practical result is that the due diligence burden now sits with the developer, not the manufacturer, and standard contract attestations are no longer adequate protection. Developers financing projects into 2026 and beyond should be treating this as a material deal risk, not a compliance checkbox.
03  Market Intelligence
PJM  · 1 signal
FERC · 2026-07-21
The ratepayer advocates from four PJM states plus Pennsylvania are making a narrow but legally precise argument: FERC's show cause order acknowledged the cost-shift problem and then declined to fix it. That is an administrative law vulnerability, and it is the kind of argument that succeeds on remand. If FERC's eventual order does not resolve regional cost allocation for network upgrades, expect litigation. Developers with large PJM interconnection requests should assume this fight is not over and that the cost-allocation rules they underwrote today may change.
MISO  · 1 signal
Spearmint Energy · 2026-07-21
Spearmint's second permitted project in Minnesota confirms that the state's PUC process, while slower than some markets, is functioning and repeatable. At $457M installed cost for 150MW/600MWh, the capital intensity is in line with current market conditions. Adjacency to the Glenworth Substation is a genuine siting advantage at this scale.
ERCOT  · 3 signals
BlackRock, Aligned Data Centers · 2026-07-21
A $12B debt sale to fund a single near-gigawatt campus in El Paso, layered on top of a $40B acquisition close, makes BlackRock the most consequential single actor in U.S. data center infrastructure right now. The El Paso location matters for ERCOT: a load of this scale at the western edge of the grid is a significant reliability event for a market that already struggles with west Texas transmission constraints. Anyone holding generation or storage interconnection rights in the El Paso load zone should be re-underwriting those positions today.
Intersect Power
Castro County community opposition to Intersect Power's data center is worth tracking. Texas rural communities are increasingly organized around water and land concerns, and Castro County is in the High Plains where groundwater depletion is already a political flashpoint. This does not kill the project, but it will pressure the permitting timeline and could force a water sourcing redesign.
El Paso
El Paso tightening zoning rules for data centers the same week a $12B debt sale lands for a near-gigawatt Meta campus in that city is notable timing. The new rules will govern future developments, not the BlackRock-Meta project, which is presumably already entitled. But any developer looking at El Paso for a second or third campus just got a harder permitting environment.
National & Policy  · 5 signals
Crusoe, ON.energy · 2026-07-21
Five gigawatts of UPS capacity is a supply-chain bet, not an engineering footnote. Crusoe is pre-contracting equipment across its pipeline before the projects are built, which is the right play when transformer and battery lead times are measured in years. A buffered load profile is a materially different grid interaction than a raw GPU ramp, and other large AI developers should be watching this structure closely.
EdgeMode, BlackBerry AIF · 2026-07-21
The DC MALPICA proposal offers a useful European data point: 300MW of on-site generation in a market where grid interconnection timelines are measured in years is not an experiment, it is the only viable path to a near-term in-service date. The developers have not confirmed the generation technology. U.S. developers watching this should note that the same logic applies in constrained domestic markets.
Toyo · 2026-07-20
The DOC investigation into Ethiopian solar cell producers is another iteration of the same circumvention pattern that has run through Southeast Asia for years. If Toyo and Origin lose this, the effective panel supply available to U.S. utility-scale solar developers narrows further. First Solar benefits directly; everyone buying silicon modules should re-examine supply chain exposure now, before any preliminary determination.
Salt River Project · 2026-07-21
SRP's Marigold proposal is a textbook integrated resource move: co-locate solar, storage, and gas on a single site with a new substation and four miles of 230-kV transmission lines, reducing transmission build risk while preserving firm capacity. The board vote in September is the real milestone. At 675MW of gas headroom alongside 600MW solar and 400MW storage, SRP is building to serve growing demand in Maricopa and Pinal counties without pretending that solar alone closes the reliability gap.
Western Interconnection Regional Advisory Body · 2026-07-20
WIRAB targeting a large load interconnection framework by end of 2026 matters because the Western Interconnection has no unified queue structure and each balancing authority handles large load requests differently. A published template does not bind anyone, but it establishes a baseline that state PUCs and utilities will start referencing in tariff proceedings. Developers active in CAISO, NV Energy, or Pacific Northwest markets should engage this process now rather than wait for the final document.
04  Regulatory Watch  · 8 filingsView Filings
EL26-67-000 · PJM · cost allocation · 3 filings
FERC initiates Section 206 proceeding against PJM, all commissioners concurring separately
Filed 2026-06-18   20260618-3105 ›  ·  20260708-5011 ›  ·  20260618-3111 ›
ER26-1323-002 · SPP · large load
SPP compliance filing for conditional high-impact large load service tariff provisions
Filed 2026-07-06   20260706-5174 ›
ER26-2698-000 · NYISO · queue reform
NYISO supplemental filing on interconnection process improvements affecting queue procedures
Filed 2026-07-08   20260708-5191 ›
RM21-17-000 · MISO · cost allocation · 3 filings
FERC extends time on major MISO regional transmission planning and cost allocation rulemaking.
Filed 2026-07-17   20260717-3052 ›  ·  20260717-3053 ›  ·  20260717-3051 ›
ER26-2577-000 · NYISO · queue reform
FERC accepts NYISO interconnection procedure revisions with commissioner concurrence
Filed 2026-07-20   20260720-3065 ›
EL25-49-002 · PJM · large load
FERC issues rehearing/clarification order on PJM proceeding, likely large-load or cost policy matter.
Filed 2026-06-18   20260618-3103 ›
ER26-2514-000 · SPP · queue reform
FERC accepts SPP generator interconnection procedure revisions to Attachment V tariff.
Filed 2026-06-29   20260629-3054 ›
ER26-2771-000 · PJM · queue reform
FERC denied Chestnut Run Energy LLC's waiver request in PJM (ER26-2771), a process-integrity ruling on interconnection queue timing.
Filed 2026-07-02   20260702-3059 ›
The Morning Read is published weekday mornings under the NexPhase Advisory imprint, written by Chris Santiago. Two decades in utility-scale development, from site origination and land control through interconnection, offtake, and delivery to NTP. 5+ GW delivered across major U.S. ISOs and RTOs.
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