Data center power verification: the five rungs of evidence that a site can be powered

Proximity to a substation is the weakest evidence

The usual site pitch starts with a parcel and a line on a map: 200 acres, two miles from a 345 kV substation. That tells you where the wires are. It says nothing about whether the station or the lines behind it can carry another few hundred megawatts without overloading something under contingency. A buyer who searches by distance to a substation is screening for the cheapest attribute to check and the least predictive one.

Paces put numbers on this for Texas in a November 2025 white paper. Its team screened every Texas parcel against common developer criteria (at least 100 acres, slope under 15 degrees, favorable zoning, within 3 miles of a 345 kV substation or 1 mile of a 345 kV line, plus fiber and gas). It then added load bus by bus in ERCOT's 2028 summer-peak planning case, with full AC N-1 contingency analysis, until the first element overloaded. Only about 230 substations had suitable land within 3 miles, and only about 17% of the substations near those sites showed positive withdrawal capacity. The rest of the land was, in the paper's word, stranded.Paces ↗

The same paper found that five overloaded elements limited headroom for roughly 250,000 acres, about 30% of the viable land. So a single transmission constraint can disqualify dozens of parcels that look identical on a map. Land data vendors now say the same thing in their own marketing. LandGate, for one, argues that power availability has to be confirmed with current numbers before any other site factor is seriously evaluated, and that a cheap, well located parcel with no grid capacity nearby is not a viable site.Paces ↗LandGate ↗

The practical conclusion is to search from power evidence first and only then look for land. Start with places where a utility, a planning record or an existing connection already shows megawatts. Parcels come second.

The five rungs of power evidence

We sort every power claim into one of five rungs, numbered 0 to 4. The rung is set by the strongest document in hand, not by what the seller says the document would show. A site can only be graded as high as its paperwork.

Two points about the middle rungs. Rung 2 includes existing connections, and these are often the best leads in a market. A retired or retiring generator had an export path sized to its nameplate, and EIA-860 lists generators by status, including retired and proposed units. EIA notes that the annual file's retired list covers only the current cycle, so use the monthly 860M inventory for a complete retirement history back to 2002. A retired plant's export path does not convert to load service automatically, but it does tell you where the transmission was built.U.S. Energy Information Administration ↗

Rung 3 is where most real projects stall. Dominion Energy's Virginia process is a clear example of the steps. A customer files a site plan, a load letter and a load ramp through Dominion's data center portal. Dominion's team can then prepare an infrastructure evaluation and preliminary power plan, and a will-serve letter if needed. Dominion says projects over 50 MW will likely need a transmission extension and a new substation, and it often phases service with a bridging solution while the final plan is built. A preliminary power plan for your load is rung 3. A generic statement that the area has capacity is rung 2 at best.Dominion Energy ↗

Queues and pipelines overstate available power

Headline demand numbers are useful for understanding how crowded a grid is. They are useless as evidence that any one site has power. Requests are cheap to file, and the same project often files at several utilities. The gap between requested load and studied or signed load is the clearest measure of how much of the market is speculative.

ERCOT's numbers show the pattern at scale. The grid operator told the Texas Senate in July 2026 that it was tracking about 474 GW of large loads seeking interconnection. For comparison, its own September 2026 board deck listed conditional Batch Zero classifications of 66.4 GW as base load and 127.9 GW as studied load, and it excluded 302.2 GW. Those classifications were themselves conditional on an eligibility audit, with ERCOT asking for evidence such as purchase orders for long-lead equipment, real estate agreements, land use approvals and end-user agreements.ERCOT ↗ERCOT ↗

Utility disclosures tell the same story from the other end. Oncor reported 298 GW of service requests in its second quarter 2026 results, while 44 GW of its large load projects qualified for Batch Zero. Duke Energy separates executed agreements (7.6 GW) from a broader 15.4 GW pipeline that includes prospective load. PJM said its January 2026 forecast reflected improved vetting of requested data center adjustments and that it would derate longer-term projects without firm commitments. When a seller cites a utility's pipeline as proof that power is coming to their area, they are quoting the soft number.Utility Dive ↗Utility Dive ↗PJM Inside Lines ↗

Texas also shows how policy can freeze a rung. In August 2026 Governor Abbott directed the PUC and ERCOT to audit data centers in the interconnection process. ERCOT paused energization of new large-load data centers and crypto mining facilities pending that audit and a community impact review, with both reports due to the PUC by December 10, 2026. A September directive extended the pause to TCEQ permits. As of November 2026 we have not seen a public notice lifting it, so any Texas claim of a near-term energization date needs to say how it clears the audit.ERCOT ↗DLA Piper ↗

How to grade a broker's power claim

Take a common pitch: "450 MW available, utility confirmed." Grade it by asking for the document, then reading the document for five things. Until a current utility letter is in hand, the claim is rung 2 at most, and if the MW figure has no named station behind it, it is rung 1.

Then ask whether the seller has filed or paid for anything. A load letter on file, a study fee paid or security posted moves a claim toward rung 3, because it means the utility has a record of this load. In ERCOT, loads in the Batch Zero process had to bring financial security to $50,000 per MW. A seller who cannot show any of this is selling land and a hope.ERCOT ↗

Watch for borrowed evidence. A will-serve letter issued to a previous owner for a different load, a slide from a utility investor presentation, or a county's statement that a new substation is planned are all real documents. None of them is a study of your load.

How to move a site up a rung

Going from rung 1 to rung 2 takes a phone call. Going from rung 2 to rung 3 takes a filing, a fee and usually months. Before you spend money on the second step, make sure the first step held up.

Start with the utility's economic development or large load team, not the local customer service line. Investor-owned utilities and many cooperatives have staff whose job is to answer site questions for large loads. Ask them for a short list of facts in writing:

Going to rung 3 means filing. In Dominion's territory that is the load letter, site plan and ramp through its portal. In Texas, the PUC adopted large load interconnection standards in September 2026 that set a flat $100,000 study fee regardless of load size and dropped a proposed $50,000 per MW non-refundable fee. The final rule also gives 24 months of notice on missed energization milestones, applied to the schedule as a whole. Other utilities set their own fees and security through tariffs filed at their state commission, so read the current large load tariff in the PUC docket before budgeting.Dominion Energy ↗Utility Dive ↗

Going to rung 4 means signing. An electric service agreement or interconnection agreement with an in-service date, minimum demand terms and security is the strongest evidence short of a meter. Read the conditions. A signed agreement that depends on a transmission project that has not cleared its own approvals carries that project's schedule risk.

Sites from our inventory that show the point

We grade every site we screen on this ladder and keep the result in one inventory, now more than 140 US sites. Three of them show how far apart two sites that both claim power can be.

The first and third sites would both appear on a map as land near high-voltage lines. Only the documents separate them. Locations, owners and documents are shared on a call.

Kill disqualifiers first, then assign a tier

Power evidence decides where to look. A kill sheet decides which of those places to drop before anyone pays for title work or a survey. We check these at the station level, then at the parcel level:

What survives gets a tier. Tier A is documented power: rung 3 or 4 evidence for this load at this site. Tier B is a named power path with a date: rung 2 evidence, a named station, the upgrades identified and a utility estimate of when they finish. Tier C is land near capacity: rung 1, a good parcel near the right voltage with no figure from anyone who would have to deliver it. Each tier comes with the next document that would move the site up, so a buyer knows what to ask for and who should produce it.

This is how Invariant screens sites before any introduction. We work from power records outward, run the kill sheet, and send a buyer the tier and the supporting documents together. If you have a requirement in MW, a state and an energize-by date, we can tell you what evidence exists in that market and what it would take to get a site from C to A.