Case Study: Inside The Safest School In America

CIP-014-4 strengthens the physical-security framework for transmission stations, substations and associated primary control centers whose loss through physical attack could cause instability, uncontrolled separation or cascading within an Interconnection. The revised standard tightens risk-assessment timelines, clarifies applicability and strengthens independent verification and oversight.

University cogeneration: Large campus cogenerating plants do not become subject to CIP-014-4 simply because it operates in parallel with the utility grid. The standard is directed principally at qualifying Transmission Owners and Transmission Operators and the critical transmission facilities identified through the prescribed risk assessment.  When the plant gets to about 75 MVA and is connected at greater than 100 kV ( a fairly common “service” interconnect voltage, the NERC registration, the ownership boundary and the topology of the high-voltage interconnection all become consequential.  The University of Michigan and MIT plants — the largest in the USA — lie on the boundary

Practical implication: Large research universities with interconnected cogeneration should nevertheless examine the physical security of the campus–utility interface: high-voltage substations, switchyards, protection and control systems, communications, black-start capability and operating arrangements with the serving utility. A campus facility outside CIP-014-4 may still affect — or depend upon — a transmission facility that is inside it. Resilience therefore becomes a shared engineering problem even where regulatory responsibility does not.

University district energy systems are significant stakeholders in bulk electrical transmission reliability because large educational settlements behave much like small cities. Hospitals, laboratories, data centers, residence halls, athletic facilities and central utility plants create substantial, concentrated electrical loads whose interruption may have consequences extending beyond ordinary commercial outages.

Many universities also operate combined heat and power plants, generators, thermal storage, microgrids and other distributed energy resources. These assets can reduce transmission demand, support local resilience and, where market and interconnection arrangements permit, participate in demand response or other grid-support activities. Conversely, disturbances on the bulk transmission system can disrupt campus generation, utility distribution and critical research or clinical operations.

Universities therefore occupy both sides of the reliability equation: they are dependent loads and potential reliability resources.  Transmission planning, protection, restoration priorities, interconnection requirements and emergency operating procedures can directly affect the continuity, cost and resilience of university district energy systems.

For universities, research campuses, hospitals, semiconductor manufacturers, and data center developers, the June 2026 meeting represents a significant shift in federal policy. Rather than treating large-load requests as exceptional cases, FERC is moving toward standardized, faster interconnection procedures coupled with clearer cost-allocation rules. Institutions planning major campus expansions or new energy-intensive facilities should monitor the forthcoming tariff revisions from their regional transmission organizations, as these changes could substantially affect project schedules, interconnection costs, and opportunities to incorporate on-site generation or microgrids.

March 19, 2026

Key Reliability & Cybersecurity Actions. FERC approved important updates to Critical Infrastructure Protection (CIP) Reliability Standards. These included modernized rules for virtualization (allowing secure use of virtual machines), enhanced security management controls for low-impact cyber systems (CIP-003-11), and refinements to the definition of “control center” to better protect high-risk assets. The changes aim to strengthen the bulk-power system against rising cyber threats and extreme weather while reducing unnecessary administrative burdens.

Electric Rate and Complaint Resolutions. The Commission resolved several long-running rate complaints, including setting a base return on equity (ROE) of 9.57% for New England Transmission Owners. It addressed complaints involving spot market sales exceeding price caps in the WECC region and cost allocation issues in MISO related to DOE emergency orders. Several tariff revisions and generator interconnection filings were also accepted.

Other Actions. FERC modernized Electric Quarterly Report (EQR) filing requirements, authorized multiple asset transactions and dispositions, and approved several natural gas pipeline, storage, and abandonment projects. A presentation on the 2025 State of the Markets Report was also delivered.

FERC’s involvement in CHP plants at universities and hospitals depends on and how the facility interacts with the bulk electric power system and wholesale markets. In many cases, FERC’s role is indirect—but it can become significant under certain conditions.  We cover this topic separately in our periodic US Department of Energy Combined Heat & Power eCATALOG

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