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Articles by Emily Starobin
RTOs and ISOs Answer: A National Preview of How All Six Grid Operators Plan to Respond to the Large Load Surge
The nation’s six regional grid operators recently told FERC how they plan to keep the lights on as large loads reshape the grid. Their July 20, 2026 Informational Reports offer a rare, coast-to-coast snapshot of the regulatory landscape for data centers, AI campuses, and other large loads. They also signal what to expect when each grid operator files its Show Cause Response on August 17, 2026.
FERC Issues Show Cause Orders to All Six RTOs/ISOs on Large Load Interconnection
On June 18, 2026, the Federal Energy Regulatory Commission (FERC or the Commission) took long-awaited action on the Advance Notice of Proposed Rulemaking (ANOPR) proceeding for large loads. The Commission issued unique show cause orders to each of the six Regional Transmission Organizations (RTOs)/Independent System Organizations (ISOs) under its jurisdiction: PJM (EL26-67), SPP (EL26-68), NYISO (EL26-69), MISO (EL26-70), CAISO (EL26-71), and ISO-NE (EL26-72).
FERC Order May Alter PJM's Framework, Spur $1B In Refunds
By Richard Bonnifield and Emily Starobin ( May 28, 2026, 5:53 PM EDT) -- A recent order from the Federal Energy Regulatory Commission fundamentally restructures how transmission upgrade charges are assigned across the PJM Interconnection LLC region.[1]... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
NERC Computational Load Updates
Proposed “Computational Load Entity” Criteria Posted for Comments Since North American Electric Reliability Corporation (NERC) launched Project 2026-02 to address reliability risks from computational loads, as discussed in our previous post, NERC has continued to manage the concerns raised by the emerging presence of large loads on the Bulk‑Power System (BPS).
FERC Eliminates PJM’s De Minimis Rule and Orders Retroactive Transmission Cost Reallocations
In a March 6, 2026 order (the Order), the Federal Energy Regulatory Commission (FERC or the Commission) reshaped how PJM Interconnection, L.L.C. (PJM) allocates transmission project costs. Consol. Edison Co. of New York, Inc. et al., 194 FERC ¶ 61,179 (2026) (Docket Nos. EL15-18-005, EL 15-67-005, EL 17-68-003, ER 17-950-006, EL21-39, ER22-1606, and ER22-1606).
NERC Launches Project 2026‑02 to Address Reliability Risks from Computational Loads
The North American Electric Reliability Corporation (NERC) has determined that large computational loads connecting to the Bulk‑Power System (BPS) at an unprecedented speed and scale are reshaping demand profiles and exposing reliability gaps in both planning and operations.
NERC Launches Project 2026‑02 to Address Reliability Risks from Computational Loads
The North American Electric Reliability Corporation (NERC) has determined that large computational loads connecting to the Bulk‑Power System (BPS) at an unprecedented speed and scale are reshaping demand profiles and exposing reliability gaps in both planning and operations.
FERC Reaffirms Go-Ahead of Natural Gas Construction During Appeals | JD Supra
At the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) monthly open meeting on February 19, 2026, the Commission reaffirmed that it will not reinstate its ban on gas pipeline work during appeals. As discussed in our previous post, FERC issued a final rule on October 7, 2025, “Removal of Regulations Limiting Authorizations to Proceed with Construction Activities Pending Rehearing” (Docket No. RM25-9-000, 193 FERC ¶61,014 (2025)).
OSHA Authority to Cite Healthcare Employers for Workplace Violence Is Upheld
The Tenth Circuit U.S. Court of Appeals has reaffirmed the authority of Occupational Health and Safety Administration’s (OSHA) to cite healthcare employers for workplace violence under its General Duty Clause. In a February 13, 2026 decision, Cedar Springs Hospital v. Occupational Safety and Health Review Commission (OSHRC), No. 24-9519 (10th Cir.
OSHA Authority to Cite Healthcare Employers for Workplace Violence Is Upheld | JD Supra
The Tenth Circuit U.S. Court of Appeals has reaffirmed the authority of Occupational Health and Safety Administration’s (OSHA) to cite healthcare employers for workplace violence under its General Duty Clause. In a February 13, 2026 decision, Cedar Springs Hospital v. Occupational Safety and Health Review Commission (OSHRC), No. 24-9519 (10th Cir.
10th Circuit Backs OSHA on Hospital Workplace Violence Citation | JD Supra
In a February 13, 2026 decision, Cedar Springs Hospital v. Occupational Safety and Health Review Commission (OSHRC), No. 24-9519 (10th Cir. 2026), the Tenth Circuit U.S. Court of Appeals reaffirmed the Occupational Health and Safety Administration’s (OSHA) authority to cite healthcare employers for workplace violence under the OSHA’s General Duty Clause.
How FERC Is Shaping The Future Of Data Center Grid Use
By Linda Walsh and Emily Starobin ( January 28, 2026, 5:03 PM EST) -- Two recent orders from the Federal Energy Regulatory Commission affecting the PJM Interconnection LLC and Southwest Power Pool Inc. regions offer the first glimpse into how FERC will address the challenges currently facing the nation's electricity grid.... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
Restricting Foreign Ownership of U.S. Dairy Land | JD Supra
In recent years, the U.S. government has become increasingly concerned about foreign ownership of agricultural land. According to the most recent U.S. Department of Agriculture (USDA) report, foreign owners (primarily Canadian) hold an interest in nearly 45 million acres of U.S. agricultural land. American Farm Bureau Federation, Foreign Ownership of U.S. Agricultural Land: Trends, Policy and Economic Implications (2023).
FERC Continues Shaping the Future of Data Center Use of the Transmission Grid with Approval of SPP’s HILL and HILLGA | JD Supra
On January 14, 2026, the Federal Energy Regulatory Commission (FERC) accepted new rules proposed by Southwest Power Pool, Inc. (SPP) regarding the interconnection of High Impact Large Loads (HILLs) and the interconnection of new generation facilities that will be used to serve them, called High Impact Large Load Generation Assessment (HILLGA) in Docket No. ER26-247.
MSHA Announces Shift Towards Online Filing of Form 7000-2 | JD Supra
January 21, 2026 To embed, copy and paste the code into your website or blog: On January 8, 2026, the Mine Safety and Health Administration (MSHA) issued a communication encouraging electronic filing of the Quarterly Mine Employment and Coal Production Report (MSHA Form 7000-2). This transition to online submissions is part of MSHA’s broader effort to improve the efficiency of the reporting process.
Federal Climate Disclosure Requirements Wane as State Regulations Grow | JD Supra
Companies’ obligations to identify and disclose climate-related financial risks and climate data have become increasingly complex in recent years, both at the state and federal levels. The fate of federal climate disclosure rules remains unclear, with the Securities and Exchange Commission (SEC), other federal agencies, and the courts deferring action. Meanwhile, some states, such as California, are stepping in with their own robust requirements.
Proposed Bill Would Revive Slashed OBBBA Energy Tax Credit Cuts | JD Supra
On October 29, 2025, Democratic members of the House Ways and Means Committee introduced H.R. 5862, the American Energy Independence and Affordability Act (the Bill). The legislation, introduced by Rep. Mike Thompson (D-Calif.), would restore clean energy tax credits from the Inflation Reduction Act (IRA) that were cut by the One Big Beautiful Bill Act (OBBBA), passed earlier this year.
FERC Begins Shaping the Future of Data Center Co-Location | JD Supra
On December 18, 2025, the Federal Energy Regulatory Commission (FERC) directed PJM Interconnection, L.L.C. (PJM) to create new rules around the co-location of generation and data centers (FERC’s Dec. 18, 2025 Order, Docket Nos. EL25-49, AD24-11, EL25-20).
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