1) Grid operator and market structure
- RTO/ISO / balancing authority footprint: South Dakota load and generation sit across the Southwest Power Pool (SPP) and MISO footprints; SPP identifies South Dakota in its regional footprint, and MISO identifies South Dakota among the states it serves. SPP, accessed 2026-07-17; MISO, accessed 2026-07-17.
- Retail market structure: South Dakota remains a regulated retail electricity market; EIA’s state profile shows retail sales through full-service providers and no energy-only provider sales, which is consistent with no broad retail-choice market. EIA South Dakota State Profile, accessed 2026-07-17.
2) Interconnection queue (status, wait times, data center requests, reforms)
- Queue timing benchmark: Berkeley Lab’s 2025 Queued Up materials report that the median duration from interconnection request to commercial operation exceeded four years for projects built in 2018-2024, providing the best public national benchmark for queue timing rather than a South Dakota-specific data-center queue metric. Berkeley Lab Queued Up, 2025-12-15.
- SPP HILL/HILLGA reform: FERC accepted SPP’s High Impact Large Load (HILL) and High Impact Large Load Generation Assessment (HILLGA) processes in January 2026; Commissioner Rosner’s concurrence described them as pairing large loads and associated generation to reduce reliability and customer-cost risks. FERC, 2026-01-14.
- SPP CHILLS reform: FERC approved SPP tariff revisions for Conditional High Impact Large Load Service (CHILLS) on June 5, 2026, allowing non-firm, as-available transmission service for qualifying high-impact large loads while needed resources or network upgrades are put in place; the order states CHILLS has a one-year minimum term, seven-year maximum term, and is subject to curtailment during constraints or emergencies. FERC order hosted by SPP, 2026-06-05.
- FERC show-cause proceedings for both South Dakota RTOs: On June 18, FERC opened separate Federal Power Act section 206 proceedings for SPP (EL26-68-000) and MISO (EL26-70-000), directing each RTO and its transmission owners within 60 days to justify existing large-load tariff provisions or propose reforms. The orders address application and study procedures, operational requirements, network-upgrade cost transparency and cost-shift protection, co-location, flexible transmission service, and expedited study of generation serving nearby large loads. FERC SPP show-cause order, 2026-06-18; FERC MISO show-cause order, 2026-06-18.
- MISO large-load framework remains under development: FERC’s MISO order records that MISO lacks a consistent, transparent large-load evaluation framework and is developing large-load definitions and reliability requirements, a zero-injection generator interconnection agreement pathway for generation serving co-located load, and possible incremental or non-firm transmission service. MISO’s current public materials describe large-load projects seeking connection in 18-36 months and a three-part framework responding to the June 18 order. FERC MISO show-cause order, 2026-06-18; MISO Large Load Additions, accessed 2026-07-17.
- Computational-load reliability standards ordered: On July 16, FERC directed NERC to file new or modified reliability standards for computational-load integration and associated registration criteria by December 31, 2026. This national reliability action applies to the bulk-power reliability risks posed by data centers and other computational loads, including those connecting in MISO and SPP. FERC July meeting summary, 2026-07-16.
- MISO-SPP seam: SPP’s JTIQ page says the five-project MISO-SPP Joint Targeted Interconnection Queue portfolio was approved by SPP’s board on December 9, 2024, and by MISO’s board as part of MTEP24 on December 12, 2024; SPP says the portfolio is intended to address seam barriers and enable about 28.6 GW of generation interconnection. SPP-MISO JTIQ, accessed 2026-07-17.
- Data center-specific public queue evidence: Public queue and transmission-planning materials identify large-load reforms that include data centers, but they generally do not disclose named South Dakota data-center load requests by customer; South Dakota-specific public evidence is instead concentrated in PUC electric-service dockets and local project records. FERC SPP show-cause order, 2026-06-18; South Dakota PUC EL24-027 docket page, accessed 2026-07-17; South Dakota PUC EL26-008 docket page, accessed 2026-07-17.
3) Ratepayer protection (PUC/PSC tariffs, cost allocation, dockets)
- Legislative cost protection is now codified: SDCL 49-50-2 requires electricity providers to maintain separate data-center service terms and conditions requiring data centers of 10 MW or greater to reimburse providers for all costs fairly attributed to their service demand and utility consumption, including costs incurred if the customer leaves the system or materially reduces load. South Dakota Legislature SDCL 49-50-2, accessed 2026-07-17.
- PUC regulatory-review cost recovery is enacted: HB 1038, signed March 24, authorizes the PUC to assess a public-utility data-center customer with peak demand of 10 MW or greater for actual costs of processing a contract-with-deviations or other electric-service agreement review, with collections deposited in the PUC gross receipts tax fund. South Dakota Legislature HB 1038 session law, 2026-03-24.
- Black Hills Power Blockchain Interruptible Service (BCIS) tariff: The PUC approved Black Hills Power’s utility-specific BCIS tariff in EL25-019, effective January 29, 2026, for new blockchain interruptible loads of 10 MW or greater; the tariff requires each BCIS customer to enter a PUC-filed service agreement and identify customer-specific infrastructure costs and interruption terms. South Dakota PUC EL25-019 order, 2026-01-29; Black Hills Power EL25-019 compliance tariff, 2026-03-05.
- Black Hills Power pending general rate case: Black Hills Power’s EL26-003 general rate case remains pending and includes proposed rate-book pages that move the BCIS tariff from section 3B to section 3 while preserving the 10-MW-or-greater interruptible-load framework. On July 17, Black Hills filed notice that it intends to implement a 25.4% interim base-rate increase on August 18 if no final order issues; the filing says commercial and industrial impacts vary by class and usage and that interim collections are subject to refund. The interim filing does not resolve the separate CSRE agreement docket. South Dakota PUC EL26-003 docket page, accessed 2026-07-17; Black Hills Power EL26-003 notice of interim rates, 2026-07-17; Black Hills Power EL26-003 tariff pages, 2026-02-19.
- Black Hills Power/CSRE blockchain interruptible agreement: On March 19, 2026, Black Hills Power filed EL26-008 seeking approval of a confidential BCIS agreement with CSRE Properties South Dakota, LLC in Rapid City, and the docket remained pending with no PUC order on July 17. The public application says the customer reimburses utility-side capital/construction costs, pays energy, transmission, ancillary service, reserve, imbalance, CUS, TFA, and other nondiscretionary costs, and may be interrupted for up to 300 hours per calendar year. South Dakota PUC EL26-008 docket page, accessed 2026-07-17; Black Hills Power EL26-008 application, 2026-03-19.
- MDU transmission rider and Rate 45 credit: In EL26-005, the PUC approved Montana-Dakota Utilities’ 2026 Transmission Cost Recovery Rider rate effective May 1, 2026. The order and staff memorandum identify transmission revenues from a large Rate 45 customer; staff said the High-Density Contracted Demand Rate 45 customer is a North Dakota customer served on MDU’s integrated transmission system, with the South Dakota allocation returning $449,485 to ratepayers and saving a typical residential customer about $2.99 per month. South Dakota PUC EL26-005 order, 2026-04-28; South Dakota PUC EL26-005 staff memorandum, 2026-04-16.
- Leola electric-provider assignment: EL24-027 remains pending. The PUC canceled the June 30 summary-judgment hearing on June 26 after staff reported that all parties were engaged in settlement efforts and wanted additional time; MDU filed additional public and confidential discovery responses on July 6. South Dakota PUC EL24-027 continuance order, 2026-06-26; South Dakota PUC EL24-027 docket page, accessed 2026-07-17.
- Leola Rate 45 service agreement: EL24-028 remains the related public docket for Montana-Dakota Utilities’ requested approval of an electric service agreement under Rate 45 with Leola Data Center LLC; public attachments are substantially redacted, including sensitive service terms. South Dakota PUC EL24-028 docket page, accessed 2026-07-17; South Dakota PUC EL24-028 Attachment A, 2024-08-05.
- Tariff-class status: Through July 17, 2026, no statewide generic PUC rulemaking established a single data-center tariff for all utilities; the public record instead shows statutory cost-reimbursement requirements, Black Hills Power’s utility-specific BCIS tariff and pending CSRE agreement, MDU Rate 45 proceedings, and project-specific Leola dockets. South Dakota Legislature SDCL 49-50-2, accessed 2026-07-17; South Dakota PUC EL25-019 order, 2026-01-29; South Dakota PUC EL26-008 docket page, accessed 2026-07-17; South Dakota PUC EL24-028 docket page, accessed 2026-07-17.
4) Generation adequacy (major projects, storage, shortfall concerns)
- No new South Dakota data-center-driven IRP decision found for February 1-July 17, 2026: The major energy-regulation changes during the update window were enacted cost-allocation statutes, utility-specific tariff/service-agreement proceedings, MDU’s transmission-rider treatment of a high-density Rate 45 customer, and federal/regional large-load proceedings rather than a South Dakota PUC order approving a new utility resource plan for data-center load. South Dakota Legislature SDCL 49-50-2, accessed 2026-07-17; South Dakota PUC EL26-008 docket page, accessed 2026-07-17; South Dakota PUC EL26-005 staff memorandum, 2026-04-16; FERC large-load news release, 2026-06-18.
- Regional adequacy relevance: SPP’s CHILLS and HILL/HILLGA reforms, FERC’s June 18 show-cause orders to SPP and MISO, and FERC’s July 16 computational-load reliability directive are directly relevant to South Dakota’s two-RTO footprint and to high-impact large loads including data centers. FERC SPP show-cause order, 2026-06-18; FERC MISO show-cause order, 2026-06-18; FERC July meeting summary, 2026-07-16.
- MDU ten-year plan: Montana-Dakota Utilities’ July 1 South Dakota plan says its latest IRPs were filed in North Dakota and Montana in 2024 and its next IRP is due in July 2027. It reports no currently proposed South Dakota transmission facilities and projects only modest growth in its South Dakota peak demand, from 27.4 MW summer/26.3 MW winter in 2026 to 27.7 MW/26.8 MW in 2035. Montana-Dakota Utilities ten-year South Dakota plan, 2026-07-01.
5) Utility load forecasts (data center demand, IRP filings)
- Public load visibility remains limited: South Dakota’s enacted 2026 data-center laws require cost-reimbursement terms and water reporting, but they do not create a general public utility load-forecast reporting requirement for all data-center prospects. South Dakota Legislature SB 135 session law, 2026-03-24; South Dakota Legislature HB 1038 session law, 2026-03-24.
- Failed utility-reporting proposal: HB 1301 would have required annual public utility reporting on large data-center costs and risks, but it was deferred to the 41st legislative day on February 18, 2026. South Dakota Legislature HB 1301 text, 2026-02-04; South Dakota Legislature HB 1301 action log, 2026-02-18.
- Utility-rate filings expose partial large-load information: Black Hills Power’s BCIS tariff applies to new interruptible blockchain loads of at least 10 MW, while MDU’s EL26-005 Attachment B defines Rate 45 customer revenue as revenue from data-center-type facilities with expected demand of at least 10 MW per month and at least an 85% minimum load factor and projects $16.31 million of 2026 Rate 45 customer revenue before South Dakota allocation. Black Hills Power EL25-019 compliance tariff, 2026-03-05; MDU EL26-005 Attachment B, 2026-02-27.
- MDU forecast treatment illustrates cross-state visibility limits: MDU’s July 1 plan separately identifies a 180-MW operating data-center load near Ellendale, North Dakota and a second campus with a signed 350-MW service agreement that was then using 50 MW, but expressly excludes both from its tabulated South Dakota and integrated-system peak forecast. The same plan projects essentially flat South Dakota peak demand through 2035, so it does not present a public forecast for the pending Leola proposal as a committed South Dakota load. Montana-Dakota Utilities ten-year South Dakota plan, 2026-07-01.
- Project-level load points now public: Applied Digital’s Deuel County proposal was publicly described as 430 MW before becoming unlikely/stalled; Gemini’s Sioux Falls proposal was described in April 2026 as 500-MW-capable; July reporting revised Sequitor Edge’s planned Rapid City facility to 15 MW; Leola and CSRE/Black Hills have public dockets but confidential/redacted terms. Data Center Dynamics, 2026-03-17; News From The States/South Dakota Searchlight, 2026-04-02; KOTA, 2026-07-02; South Dakota PUC EL24-028 docket page, accessed 2026-07-17; Black Hills Power EL26-008 application, 2026-03-19.
6) Behind-the-meter / co-location / direct PPA activity
- No South Dakota-specific direct PPA or co-location approval found in the February 1-July 17, 2026 public docket search; the new public South Dakota docket is instead an interruptible blockchain service agreement between Black Hills Power and CSRE Properties South Dakota, LLC. South Dakota PUC EL26-008 docket page, accessed 2026-07-17; Black Hills Power EL26-008 application, 2026-03-19.
- Regional co-location pathways: SPP’s HILL/HILLGA framework creates an expedited study pathway for high-impact large loads and associated generation, while CHILLS creates conditional transmission service for high-impact large loads while firm service requirements are resolved. MISO is developing a zero-injection generator interconnection agreement process that would allow co-located generation to serve load without injecting onto the transmission system, but FERC’s June 18 order describes that work as still under development. FERC SPP show-cause order, 2026-06-18; FERC MISO show-cause order, 2026-06-18.
- Sequitor/Steppe distributed-energy partnership: On May 26, Sequitor Edge announced a national partnership under which Steppe Energy would support natural-gas infrastructure, behind-the-meter generation, solar, battery storage, and microgrid-ready systems for future Sequitor projects, expressly including planned facilities in South Dakota. The announcement says definitive agreements would still be negotiated project by project, so it is not evidence that a specific South Dakota behind-the-meter system or PPA has been approved. Sequitor Edge, 2026-05-26.
- Self-generation reporting did not pass: HB 1301 would have added broader reporting and decommissioning obligations for large data centers, but it failed in committee. South Dakota Legislature HB 1301 text, 2026-02-04; South Dakota Legislature HB 1301 action log, 2026-02-18.
7) Transmission constraints and upgrades
- MISO-SPP seam constraints: The SPP-MISO JTIQ portfolio remains the main identified seam upgrade framework affecting South Dakota-adjacent interconnection economics; SPP says it addresses significant barriers to new generation at the seam and enables about 28.6 GW of generation to interconnect. SPP-MISO JTIQ, accessed 2026-07-17.
- SPP large-load service reform: FERC accepted CHILLS on June 5 with the requested July 1, 2026 effective date, making conditional, non-firm transmission service available to qualifying high-impact large loads while firm service requirements are resolved. FERC then opened EL26-68-000 on June 18 to test whether SPP’s broader tariff still needs additional large-load, co-location, cost-allocation, and transparency reforms. FERC CHILLS order hosted by SPP, 2026-06-05; FERC SPP show-cause order, 2026-06-18.
- No MDU South Dakota build identified in the July plan: MDU says it continues studying transmission options but is not currently proposing new transmission facilities in South Dakota, while its July 2027 IRP will be the next identified integrated-resource update. Montana-Dakota Utilities ten-year South Dakota plan, 2026-07-01.
Notes on scope and evidence gaps
- South Dakota-specific data-center load forecasts remain sparse in public filings; the clearest current evidence is project-level reporting and PUC service-agreement dockets, several of which redact terms or leave demand details confidential. South Dakota PUC EL24-028 docket page, accessed 2026-07-17; South Dakota PUC EL26-008 docket page, accessed 2026-07-17; Montana-Dakota Utilities ten-year South Dakota plan, 2026-07-01.
- The February-July 2026 energy-policy shift is broader than a single PUC rulemaking: it includes codified state cost protection (SB 135/HB 1038), Black Hills Power’s utility-specific BCIS tariff and pending CSRE agreement, MDU’s Rate 45/TCRR treatment, continued Leola settlement and docket activity, MISO and SPP federal show-cause proceedings, and a national computational-load reliability-standard directive. South Dakota Legislature SDCL 49-50-2, accessed 2026-07-17; South Dakota Legislature HB 1038 session law, 2026-03-24; South Dakota PUC EL26-008 docket page, accessed 2026-07-17; South Dakota PUC EL26-005 order, 2026-04-28; South Dakota PUC EL24-027 docket page, accessed 2026-07-17; FERC SPP show-cause order, 2026-06-18; FERC MISO show-cause order, 2026-06-18; FERC July meeting summary, 2026-07-16.