Digital Power Network Submits Comments to FERC on DOE’s Large-Load Interconnection Proposal
FOR IMMEDIATE RELEASE
Washington, D.C. — The Digital Power Network (DPN), the nation’s largest coalition of Bitcoin miners and digital infrastructure operators representing over 85% of U.S. public Bitcoin mining hashrate, submitted formal comments to the Federal Energy Regulatory Commission (FERC) in response to the Department of Energy’s (DOE) Advance Notice of Proposed Rulemaking on large-load interconnection (Docket No. RM26-4-000).
In its filing, DPN underscores the urgent need for a modernized, efficient interconnection framework as large flexible loads, including data centers, AI compute, hybrid facilities, and Bitcoin mining, face growing delays across the nation’s transmission system. DPN’s comments respond to each of DOE’s fourteen proposed reform principles, offering detailed recommendations to accelerate permitting, reduce speculative queue backlogs, strengthen grid reliability, and establish clear pathways for flexible load participation.
Read the full filing here.
DPN’s submission emphasizes that DOE’s proposed use of Section 403 authority may face significant jurisdictional challenges. The organization highlights the recent National Association of Regulatory Utility Commissioners (NARUC) resolution opposing federal preemption in large-load interconnection, noting that extended legal disputes could complicate or delay implementation.
The comments support a 20 MW applicability threshold while calling for targeted flexibility for certain smaller facilities, including hydro-based projects. DPN strongly urges FERC to study hybrid facilities holistically, evaluating injection and withdrawal rights together, to unlock efficiencies that reduce the need for costly network upgrades.
DPN also recommends meaningful, standardized study deposits to deter speculative activity and align load treatment with generator interconnection processes. The filing points to Texas’s 2025 reforms as a workable model and notes that deposit credits can balance developer cost burdens.
A major focus of DPN’s comments is the need to expedite interconnection for proven flexible and curtailable loads. DPN supports a 60-day study timeline for such facilities and recommends even higher prioritization for loads with demonstrated curtailment history.
The filing further stresses the importance of crediting mechanisms for upgrade costs, parity in “option to build” rights, and stronger accountability measures for transmission owners whose delays often drive bottlenecks. DPN urges FERC to create clear implementation timelines to avoid multi-year compliance cycles that have hindered past reforms.
Finally, DPN calls on NERC to establish a dedicated flexible-load category and urges FERC to exempt non-firm flexible loads from deliverability studies, which are unnecessary for resources that do not require firm service and substantially slow the interconnection process.
“Flexible large load is not a threat to grid reliability, it is a resource,” said Hailey Miller, Director of Government Relations & Public Policy for the Digital Power Network. “A modern interconnection framework that recognizes the unique capabilities of flexible digital infrastructure will strengthen resilience, support system planning, and accelerate nationwide energy development. Our filing provides a roadmap for achieving those goals while avoiding lengthy jurisdictional disputes and unnecessary regulatory burdens.”
DPN’s full comments outline additional considerations related to implementation timelines, state-level regulatory risks, transmission owner resistance, and opportunities to integrate flexible load into broader resource planning efforts.
The Digital Power Network remains committed to working with DOE, FERC, NERC, and state regulators to build an interconnection system that is efficient, reliable, and reflective of the changing dynamics of the nation’s energy and digital infrastructure landscape.
About the Digital Power Network (DPN):
The Digital Power Network (DPN) is the largest coalition of Bitcoin miners and digital infrastructure leaders in the United States, representing over 85% of the Bitcoin hash rate among publicly traded U.S. mining companies. DPN advocates for policies that promote energy innovation, grid resilience, economic development, and the strategic role of digital assets in the 21st-century economy.