Infrastructure Intelligence No. 06: Power Responsibility Is Becoming Development Credibility

Energy. Power. Development. Capital. | October 6, 2026 | Issue No. 06

THE WEEK IN INFRASTRUCTURE

For much of the past year, the infrastructure market has focused on one question:

Where will the power come from?

This week, the answer became more sophisticated.

In Texas, Related Companies, NextEra Energy Resources and Lewis Energy Group were selected to develop Project Star, a $22.3 billion energy-infrastructure campus built around 6.47 GW of natural-gas generation supporting an adjacent 5 GW digital-infrastructure campus. South Korea has now confirmed Project Star as the first Korea-U.S. strategic investment project.

In Kentucky, TeraWulf and Kentucky Power finalized an amended agreement that would increase contracted electric demand at the Muskie Data Campus from 500 MW to 1 GW. If approved by the Kentucky Public Service Commission, the agreement is expected to provide $100 million in TeraWulf-funded winter bill credits to Kentucky Power's residential customers over its first ten years. The amended contract has not yet been filed with the Commission.

In Texas, meanwhile, ERCOT's Batch Zero process remains constrained by a verification and audit ordered before data-center projects are permitted to advance, while a separate community-impact review is examining water, cooling, grid dependence and other effects of major new loads.

And nationally, FERC's large-load proceedings continue to examine whether existing regional tariffs adequately address the extraordinary growth of data centers and other large loads.

The pattern is becoming difficult to miss:

Large-load development is moving from power acquisition toward power responsibility.

The most executable projects increasingly arrive with more than a utility application.

They arrive with generation, transmission strategy, equipment, capital, customer protections and a credible path to energization.

01 | THE LEAD

Project Star: When the Power Campus Becomes the Development

The U.S. Department of Commerce and the Republic of Korea selected Related Companies and NextEra Energy Resources, in partnership with Lewis Energy Group, to develop Project Star, a $22.3 billion energy-infrastructure campus in Encinal, Texas.

At full scale, the announced development calls for 6.47 GW of natural-gas generation directly supporting an adjacent 5 GW digital-infrastructure campus, with excess generation intended to be available to the grid. NextEra describes first power as targeted as early as 2029, subject to required permitting and approvals.

NextEra's announcement describes the 5 GW data-center campus as privately funded and under development by Related Digital.

The Korean government has since confirmed Project Star as the first project under the Korea-U.S. strategic investment framework, saying the required domestic procedures, including deliberation, resolution and reporting to the National Assembly, have been completed. Initial commercial operation is targeted for 2029, with full operation targeted for 2032.

On October 6, Korea's finance minister confirmed that $2.4 billion was transferred to Washington on October 1 as part of Korea's funding for the project.

Those steps move Project Star beyond announcement: it now has government sponsorship on both sides and an initial tranche of Korean funding transferred.

But a project of this scale still faces the permitting, approvals and execution work inherent in moving 6.47 GW of generation and 5 GW of digital infrastructure from announcement through commercial operation.

That distinction matters.

So does the scale of what is being attempted.

Project Star is not simply a data center with onsite generation.

It represents an integrated energy and digital-infrastructure development in which generation, natural-gas supply, water, electrical infrastructure, transmission, equipment procurement and compute must advance on coordinated schedules.

The historical sequence:

Site → Utility → Interconnection → Data Center

is increasingly giving way to:

Energy Platform → Infrastructure → Compute

Developer Takeaway

The most power-intensive developments increasingly require developers to think more like energy companies.

A large parcel with favorable zoning is not enough.

The development team must understand:

Fuel + Generation + Transmission + Interconnection + Water + Equipment + Capital + Community

as one integrated development program.

The opportunity is substantial for firms capable of working across those boundaries.

The power strategy is becoming the development strategy.

02 | POLICY & GRID SECURITY

EO 14421: The Comment Window Closes October 9

Executive Order 14421, covered in Issues No. 01 through No. 04, reaches its first implementation deadline this week.

Comments on DOE's formal Request for Information, published in the Federal Register on September 9, close Thursday, October 9.

EO 14421, Declaring a National Emergency to Secure the United States Bulk-Power System, was issued August 26 and addresses national-security risks associated with certain foreign-produced bulk-power-system electrical equipment.

The RFI shows just how broadly DOE is examining implementation.

It seeks input on covered equipment and transactions; covered foreign entities and supply-chain risk; existing equipment and mitigation; licensing and vendor prequalification; domestic manufacturing and federal procurement; and economic and reliability impacts. It invites responses not only from equipment manufacturers but from software and firmware developers and remote-access service providers.

The order directs DOE to publish implementing rules or regulations, as needed, within 120 days of August 26, a window that runs to late December. No implementing rules have yet been issued.

Developer Takeaway

For major electrical equipment, the traditional questions have been:

How much does it cost?

When can it be delivered?

A third question is becoming increasingly important:

Can we demonstrate where it came from and who controls it?

For developers procuring critical power equipment, diligence may increasingly extend beyond manufacturer and country of assembly into critical components, software, firmware, maintenance services and remote-access capabilities.

That changes when supply-chain diligence should occur.

Not after procurement.

During development.

Supply-chain security is moving upstream into infrastructure diligence.

03 | POWER & GRID

PJM's Backstop Procurement Hits the Cost-Allocation Question

PJM's Reliability Backstop Procurement, a proposed tariff change filed July 31 and first covered in Issue No. 02, has been accepted by FERC but suspended.

In a September 29 order in Dockets ER26-3380-000 and EL26-108-000, FERC accepted the proposal and suspended it for five months, establishing an effective date of February 28, 2027, subject to refund. FERC also set a paper hearing on cost allocation, transmission-owner exit provisions and load-serving-entity collateral, and opened a separate Section 206 proceeding that could lead to further modifications.

PJM said it will not proceed with the procurement on September 30 as originally planned, and will review its timeline at a later date.

But the larger issue extends beyond one PJM proceeding:

Who should pay for the infrastructure required by rapid load growth?

Across major power markets, regulators are increasingly confronting generation adequacy, transmission expansion, substations, customer collateral and the risk that infrastructure constructed for very large new customers could ultimately become a cost borne by existing ratepayers.

That debate is rapidly becoming part of data-center development itself.

Developer Takeaway

Large-load customers should increasingly expect commercial scrutiny around:

Capacity responsibility + Infrastructure contributions + Collateral + Load-ramp commitments + Generation support + Curtailment rights + Ratepayer protection

Power availability is only part of the equation.

The commercial structure behind the megawatt is becoming as important as the megawatt itself.

04 | DATA CENTER / MISSION CRITICAL

TeraWulf Doubles Its Kentucky Power Position to 1 GW

TeraWulf announced October 5 that it had executed amended agreements with Kentucky Power increasing contracted capacity at its Muskie Data Campus in eastern Kentucky from 500 MW to 1 GW.

The first 500 MW remains targeted to begin ramping in 2028.

The amendment advances planned delivery of the second 500 MW from 2030 to 2029, subject to Kentucky Public Service Commission approval and Kentucky Power's construction schedule. TeraWulf is also evaluating whether the campus could eventually support as much as 2 GW.

Kentucky Power is developing a 765-kV/345-kV substation connected to the regional transmission network to serve the site.

But the commercial structure may be even more interesting.

Kentucky Power says that, if approved by the Commission, the amended agreement is expected to provide $100 million in TeraWulf-funded winter bill credits for its residential customers over the first ten years of the contract.

The utility also says TeraWulf has agreed to pay the estimated financing costs associated with Kentucky Power's planned 760 MW combined-cycle generation facility at Big Sandy, helping prevent costs associated with the increased demand from being shifted to existing customers.

None of this is yet approved. Kentucky Power says it plans to file the amended contract and seek the related regulatory approvals later this year.

That is an important development model.

The project is simultaneously addressing power, transmission infrastructure, new generation, regulatory approval and protection of existing utility customers.

Developer Takeaway

The next generation of large-load agreements may increasingly involve three parallel negotiations:

How much power can be delivered?

What infrastructure is required to deliver it?

Who pays for that infrastructure?

Ratepayer protection is therefore moving upstream into development strategy.

For developers, community and customer economics may need to be addressed before the project reaches the utility commission.

05 | ENERGY INFRASTRUCTURE

Amazon Backs Additional Nuclear Capacity at Calvert Cliffs

Amazon and Constellation announced a 20-year agreement on September 30 supporting continued investment and expansion at Maryland's Calvert Cliffs nuclear facility.

The agreement includes 690 MW of power, including approximately 190 MW of additional generating capacity expected through uprates between 2030 and 2032.

Constellation says the agreement will enable more than $3 billion of infrastructure investment across the 1,790 MW plant.

The arrangement also provides Constellation with long-term revenue certainty supporting relicensing of the plant for another 20 years and potential development of additional clean-energy generation at the site. The uprates and relicensing will still require Nuclear Regulatory Commission approval.

This represents another model for large-load energy procurement:

A major customer provides long-term revenue certainty that enables additional generation from existing infrastructure.

Developer Takeaway

Not every new megawatt requires an entirely new power plant.

Developers should increasingly evaluate:

Nuclear uprates + Repowering + Existing-plant expansion + Transmission upgrades + Storage + Other improvements to existing energy assets

The fastest capacity may sometimes come from expanding infrastructure that is already operating.

Maryland Creates a Revenue Bridge for Storage

On October 1, the Maryland Public Service Commission announced its first-round Energy Storage Capacity Credit awards, conditionally selecting the 400 MW Chalk Point project and the 40 MW Jade Meadow III project.

The awards are subject to the Commission's approval conditions, and both projects must still apply for construction approval, which will require additional public and evidentiary hearings.

The larger significance is financial.

Long-duration revenue support can reduce one of the central challenges facing grid-scale storage: uncertainty over the revenue stack.

Developer Takeaway

Storage financeability increasingly depends on more than battery economics.

Bankable storage requires bankable revenue.

For developers, the critical diligence is not simply installed cost per kilowatt-hour.

It is understanding which combination of capacity value, energy-market revenue, ancillary services, tax attributes and contracted revenue can support financing.

06 | EQUIPMENT & SUPPLY CHAIN

Equipment Provenance Moves Into the Development Schedule

This week's equipment story is less about a new product announcement and more about a changing development requirement.

DOE's EO 14421 RFI explicitly seeks input from equipment manufacturers, component and sub-tier suppliers, software and firmware developers, maintenance and remote-access service providers, distributors and integrators throughout the electrical-equipment supply chain.

That matters because power-intensive projects are already procuring equipment earlier.

Transformers, switchgear, controls and other long-lead electrical systems can influence schedules years before energization.

Now another layer of diligence is emerging alongside availability:

Provenance.

Developer Takeaway

Early-stage procurement increasingly needs to answer:

Can we get it?

When can we get it?

Where was it made?

Who supplied the critical components?

Who controls its software, firmware and remote access?

For developers, that means procurement records may become part of the project's regulatory and security record.

Procurement strategy is schedule strategy.

Increasingly, it may also be compliance strategy.

08 | THE INTERCONNECTION DESK

ERCOT

Batch Zero Remains Paused at a Critical Point

Texas' Batch Zero process, followed since Issue No. 01, remains subject to the verification and audit ordered before affected data-center projects are permitted to advance.

ERCOT's September 9 notice recalls that Governor Greg Abbott directed the PUCT and ERCOT on August 3 to conduct a verification and audit of data-center projects advancing through ERCOT's interconnection process before those projects are permitted to advance.

ERCOT issued provisional Batch Zero classifications on September 3, and on September 9 began issuing verification RFIs to a majority of the large-load entities conditionally included in the batch, with the remainder to follow through the end of September.

Successful completion of verification is a condition of inclusion. ERCOT states that failure to provide a timely and complete response will result in exclusion from Batch Zero.

The pause is broader than the verification itself. ERCOT's September Board update states that it paused the Batch Zero study process and final classification on August 3, and has paused energization of new large-load data centers and crypto-mining facilities of 75 MW or more until the verification, audit and community-impact review are complete. Final decisions are expected in December.

That creates a different kind of schedule risk.

A project can hold a provisional classification without yet having certainty around when it will be permitted to move through the complete interconnection process.

State and Community Impact Review

ERCOT's separate State and Community Impact RFI, introduced in Issue No. 03 and followed in Issues No. 04 and No. 05, applies to data centers of 25 MW or more and examines much more than electricity demand.

It asks about grid dependence, onsite generation, water sources and consumption, cooling technology, noise, light, traffic, public financial assistance and ownership and controlling interests.

Responses are due October 12.

ERCOT says it will coordinate with the PUCT and expects to publish a report no later than December 10.

This is an important evolution.

Large-load diligence is expanding beyond the electrical meter.

PJM

PJM's proposed Large Load Registry and Interim Resource Adequacy Service, last covered in Issue No. 05, remain pending before FERC in Docket ER26-3515-000.

One date has moved. PJM now expects the new tool supporting its Existing and Future Large Load Registry and Bring Your Own New Capacity framework to be ready February 1, 2027, a month later than the January 1 date reported in Issue No. 05. Aggregated public registry information is still expected beginning in March 2027.

IRAS would provide a framework for new large-load customers bringing their own new power supply. For customers without new supply, PJM describes an alternative level of service intended to avoid sacrificing reliability or adding costs for existing customers.

The critical status point is straightforward:

These structures have been proposed. They have not yet been approved by FERC.

FERC

FERC's six Section 206 large-load proceedings, first covered in Issue No. 02, remain one of the most consequential national regulatory developments for data-center and industrial-load development.

On June 18, FERC issued separate show-cause orders to all six jurisdictional regional grid operators, directing them to justify or reform the tariffs governing how data centers, manufacturing facilities and other large energy users connect to the transmission system.

The schedule now differs by region. FERC has held PJM's proceeding in abeyance, and PJM's response is now due November 16, 2026. FERC has not issued final determinations in any of the six proceedings.

The proceedings address transmission service, reliability, transparency, infrastructure requirements and protecting existing customers as large loads connect to the system. In the June 18 orders, Commissioner Chang's concurrence emphasized customer protection and cost allocation as central concerns.

The important point for developers is procedural:

These are active regulatory proceedings, not final national large-load rules.

But their direction is already important.

The federal question is no longer simply:

How do we connect large loads faster?

It is increasingly:

How do we connect them faster without compromising reliability or transferring their infrastructure risk to existing customers?

CAISO

Following the October 1 stakeholder meeting on the draft final Large Loads Initiative, covered in Issue No. 05, the next milestone is October 15, when comments are due on both the draft final proposal and the draft tariff language.

A separate tariff-language meeting follows on October 19, after the comment deadline, with Board of Governors consideration currently anticipated for October 28. Neither document has been approved by the Board, and nothing has been filed with FERC.

The proposed flexible interim load interconnection (FILI) service remains particularly important for developers because it could establish a structured pathway toward earlier energization where customers can accept defined operating limitations.

09 | ON OUR RADAR

DOE | October 9

Comments are due on DOE's formal RFI implementing Executive Order 14421, Declaring a National Emergency to Secure the United States Bulk-Power System. The notice seeks input on covered equipment, foreign entities, supply-chain risk, mitigation, vendor prequalification and domestic manufacturing.

ERCOT | October 12

Responses are due for applicable State and Community Impact RFIs. Watch particularly how ERCOT ultimately incorporates information on grid dependence, onsite generation, water, cooling and community impacts into the large-load development process.

CAISO | October 15

Comments are due on the draft final Large Loads Initiative and draft tariff language.

CAISO | October 19

CAISO will hold a separate stakeholder session focused on the draft tariff language.

CAISO | October 28

CAISO currently anticipates presenting the Large Loads Initiative to its Board of Governors for consideration.

ERCOT | December 10

ERCOT expects to publish its State and Community Impact Review Report no later than December 10.

December therefore becomes an important checkpoint for understanding how Texas may incorporate project credibility, water use, community impacts and other non-electrical factors into its evolving large-load framework.

FERC | Large-Load Proceedings

Watch for Commission action in the six Section 206 proceedings, and for PJM's response, due November 16. Any resulting tariff reforms could materially affect interconnection timing, transmission service, cost allocation, financial security and the relationship between new generation and new large loads.

THE INTERFACE VIEW

Over the first six issues of Infrastructure Intelligence, a consistent progression has emerged.

The data-center business is becoming the power business.

Interconnection readiness is becoming development readiness.

Electrical behavior is becoming part of development responsibility.

Flexibility is becoming infrastructure.

Capacity optimization is becoming development strategy.

This week adds another principle:

Power responsibility is becoming part of development credibility.

Project Star proposes generation at extraordinary campus scale, backed by an emerging international investment structure.

TeraWulf is pairing major load growth with new transmission infrastructure, new-generation cost responsibility and proposed benefits for existing utility customers.

Amazon is supporting additional output from an existing nuclear asset.

ERCOT is verifying whether projects seeking scarce grid capacity are sufficiently credible to advance.

FERC is examining whether existing regional rules adequately protect reliability and consumers as enormous new loads seek connection.

And DOE is asking whether critical electrical equipment can be trusted before it becomes part of America's bulk-power system.

These are not separate trends.

They are different parts of the same development equation.

The emerging infrastructure stack increasingly looks like:

Land + Power + Grid + Generation + Equipment + Capital + Community + Security + Execution

That is a very different model from securing acreage and submitting a utility request.

It requires engineering earlier.

Capital earlier.

Utility engagement earlier.

Procurement earlier.

Community strategy earlier.

And increasingly, accountability for the infrastructure consequences created by the project itself.

The next phase of infrastructure development will not simply reward teams that identify demand.

It will reward teams capable of answering a harder question:

Can you turn that demand into infrastructure the grid, the community, the capital markets and the customer can actually support?

That is the distinction between a project that needs power and a project capable of becoming power-ready.

That is where development value is moving.

Interface Holdings and Development Firm

Building the Future of Infrastructure Through Strategy, Capital, and Integration.