ET-2025-0184

Key events and scheduled submissions in this proceeding include:

- May 14, 2025: Ameren Missouri filed its large load customer rate plan application with the Missouri Public Service Commission 1, 1.
- May 27, 2025: Ameren Missouri requested the Commission to hold a procedural conference on June 13, 2025 2, 2.
- June 3, 2025: The Commission issued an order scheduling a procedural conference for June 13, 2025, to discuss interventions and the procedural schedule 2, 2.
- June 12, 2025: Last day to submit applications to intervene in the case 1, 1.
- June 13, 2025: The Commission held the procedural conference to discuss intervention applications, the proposed procedural schedule, and Ameren Missouri’s request for a protective order. Intervention applications from Missouri Industrial Energy Consumers, Google LLC, Renew Missouri Advocates, Sierra Club, and Amazon Data Services, Inc. were granted 3, 3.
- June 17, 2025: Deadline for parties to respond to Ameren Missouri’s request for a protective order 3, 3.
- June 23, 2025: Deadline for Ameren Missouri to respond to Evergy Missouri Metro and West’s intervention application; also, deadline for parties to file a proposed procedural schedule 3.
- June 27, 2025: Deadline for Evergy Missouri Metro and West to reply to any Ameren Missouri response regarding their intervention application 3.
- December 31, 2025: Ameren Missouri seeks an order approving the large load customer rate plan by this date to allow customers to begin operations in their service territory 1, 1.

These dates reflect both actions already taken and near-term deadlines established by the Commission.

This docket concerns Ameren Missouri's proposed large load rate plan, which seeks approval from the Missouri Public Service Commission to establish a new subclass within the Large Power Service (LPS) tariff for customers with an actual or expected demand of at least 100 MW, served at transmission voltages above 115 kV. The plan requires these large load customers to enter into long-term electric service agreements (ESAs) and participate in up to three new revenue-generating programs beyond base retail charges: Renewable Solutions – Large Load Customers (Rider RSP-LLC), Clean Capacity Advancement Program (Rider CCAP), Nuclear Energy Credits (Rider NEC), and Clean Energy Choice (Rider CEC). The framework aims to attract major manufacturers and data centers to Missouri by providing clean, reliable, and affordable energy while ensuring these customers pay their fair share of costs, preventing unjust or unreasonable rate impacts on existing customers. The plan includes provisions for tracking program revenues, requests a variance from certain renewable energy standard rules, and aligns with recent legislative requirements (SB 4) calling for utility tariffs that fairly allocate costs to large load customers. Ameren Missouri has already signed construction agreements with entities representing up to 2,270 MW of new potential load, contingent on the approval of this rate plan 1, 2, 3, 1, 2.

The docket discusses several financial and timeline risks and concerns related to serving large load customers, especially data centers and similar high-demand prospects, under Ameren Missouri's proposed large load rate plan.

Financial Risks:
- Stranded cost risk if large load customers terminate their electric service agreements (ESAs) early, which could leave the utility with investments in generation or infrastructure not fully paid for by the departing customer. However, the plan includes termination payments and financial security requirements explicitly designed to mitigate this risk. For instance, the plan requires a minimum term of 15-17 years and significant termination payments, and includes a minimum monthly demand payment for 70% of contracted capacity 1, 1.
- The risk of negative financial impacts on existing customers if large loads leave the system. Risk analysis shows that with mitigation actions (such as deferring generation investments), even extreme scenarios (e.g., all large load customers terminating early) would result in most or all of the residual risk being addressed. For example, in the worst-case scenario modeled, a $1.9 billion residual revenue requirement impact could largely be mitigated by deferring over $2 billion in planned generation investments 2.
- Concerns about whether large load customers will pay their fair share of system costs. The analysis concludes that with the plan’s structure—including long-term contracts, termination fees, and additional revenue-generating clean energy programs—these customers are expected to cover the incremental costs they create, reducing risk for existing customers 1, 1.

Timeline Risks:
- Uncertainty around the timing and ramp-up of large load additions. While the company expects between 500 MW and 2 GW of new demand by 2032, the timing of these additions (and their ramp-up schedules) is not fully predictable, adding uncertainty to resource planning and capital investment scheduling 3.
- The need to rapidly scale up generation and transmission infrastructure to meet these loads, with risks associated with potential delays or mismatches between customer demand and the completion of new resources. Delays or mismatches could create short-term reliability or cost pressures 1, 1.
- Potential for rapid changes in large load customer demand (either up or down), which could make it challenging to align infrastructure investments with actual needs. The plan attempts to address this by allowing for deferral of generation investments if loads do not materialize as expected or if customers terminate early 1.

Overall, the docket emphasizes that these financial and timeline risks are being proactively managed through contract structures, risk analysis, and resource planning strategies designed to protect both Ameren Missouri and its existing customers 2, 1, 1.

The stakeholders formally recognized as intervenors in this docket (File No. ET-2025-0184) are:

- Missouri Industrial Energy Consumers
- Google LLC
- Renew Missouri Advocates
- Sierra Club
- Amazon Data Services, Inc.
- Evergy Missouri Metro and West (pending response and reply on intervention as of June 13, 2025)

As of the procedural conference held on June 13, 2025, the applications for intervention from the first five entities were granted without objection. Evergy Missouri Metro and West's intervention was still under consideration, with deadlines set for responses and replies.

The provided excerpts do not specify which stakeholders support or oppose particular proposals within the docket. The excerpts only confirm their intervention status and participation in the procedural schedule negotiations, not their positions on Ameren Missouri's large load rate plan or related proposals 1, 1.

The docket identifies two main areas of growth:

1. Technology Sector Growth (especially Data Centers)
2. Manufacturing Sector Growth (including Advanced and Re-shoring Manufacturing)

Key considerations for each area:

Technology Sector (Data Centers and AI):
- Data centers and AI-related facilities are driving unprecedented increases in electric demand. Individual economic development prospects are now requesting over 1,000 MW each, compared to just over 3 MW in 2019. By the end of 2024, the average requested demand was nearly 190 MW. Projected large load additions, primarily from data centers, are expected to add 500 MW to 2 GW by 2032, with potential for 2.5–3.5 GW by 2040 1, 2.
- Key considerations:
- Access to large amounts of clean, reliable, and affordable energy is critical.
- Energy availability and infrastructure capacity are now primary site selection factors for these businesses.
- The rapid growth in power demand is accelerating the need for new generating resources and grid investments.
- The ability to offer clean energy sources is increasingly important due to customer sustainability goals 1, 1.

Manufacturing Sector (Traditional and Advanced/Re-shoring):
- There is significant growth in traditional manufacturing (such as aerospace and defense) and advanced manufacturing, driven by trends like automation and re-shoring. For example, Boeing’s $1.8 billion expansion in Missouri has added thousands of jobs 1, 1.
- Key considerations:
- Like technology, manufacturing growth is heavily dependent on energy supply—businesses require clean, reliable, and affordable power.
- Manufacturing automation and AI adoption are increasing electricity needs.
- The state’s competitiveness in attracting these facilities depends on how quickly and flexibly utilities can meet new load requirements, and on the terms of electric supply agreements 1, 1.

In both sectors, the ability to provide sufficient, reliable, and clean energy supply is a top site-selection factor, often determining whether Missouri will be chosen for new investments. The state must adapt its energy policies, infrastructure, and rate structures to support these large load customers and remain competitive in economic development 1, 1.