Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance

two-reviewer order approved mo-ameren-llrp-et-2025-0184

cappednotice-based

Record created 2026-08-16, last updated 2026-08-16. Snapshot built September 14, 2026. JSON

State

MO

Kind

order

Status

approved

Agency

Missouri Public Service Commission

Utility

Union Electric Company d/b/a Ameren Missouri

Citation

In re Union Electric Co. d/b/a Ameren Missouri, File No. ET-2025-0184 (Mo. P.S.C. Nov. 24, 2025)

Docket

ET-2025-0184

Effective

2025-12-04

Threshold MW

75

Contract term (years)

12

Ramp (years)

5

Minimum take %

80

Summary

The Missouri PSC approved a non-unanimous stipulation and agreement authorizing Ameren Missouri to implement a Large Load Customer Rate Plan (LLRP/LLCS) applicable to new or expanding facilities with a monthly maximum demand of 75 MW or more -- a lower threshold than the 100 MW set in SB4. Approved terms include a 12-year minimum service term plus an optional 5-year transitional ramp period, 36-month exit notice with Exit Fee/Early Termination Fee, collateral equal to two years of minimum monthly bills, a minimum monthly bill with demand charge set at 80 percent of Contract Capacity, and treatment under Ameren's existing Emergency Energy Conservation Plan for curtailment.

Exit terms

Two distinct notice provisions per the Stipulation and Agreement, Case ET-2025-0184: Sec. 8 requires 36 months' notice to avoid automatic renewal into a 5-year Extension Term; Sec. 12 requires 24 months' notice to terminate service. Exit Fee = the applicable Minimum Monthly Bill multiplied by the LESSER of 60 calendar months or the months remaining in the Term/Extension Term (during the ramp period: the remaining ramp months PLUS 60 calendar months). Early Termination Fee = two times the Minimum Monthly Bill times the number of months by which notice falls short of 24 months. The 60-month cap is the material difference from Evergy's LLPS, whose Exit Fee runs the full remaining Term with a 12-month floor and no cap.

Collateral terms

Large Load Customers must provide collateral equal to two years of minimum monthly bills. A customer with a Guarantor rated at least A- (S&P) / A3 (Moody's), not on credit watch at that floor, and with liquidity greater than ten times the collateral requirement, qualifies under the Agreement's credit provisions (Stipulation ¶24).

Curtailment terms

The Emergency Energy Conservation Plan tariff applies to LLCS customers, and these customers may be interrupted during grid emergencies under the same circumstances as any other customer.

Cost allocation

Order implements Sec. 393.130.7's directive that large-load customer rates reflect their share of costs and not burden other customer classes; includes a Revenue Sharing / Earnings Review Surveillance mechanism under which 65% of any positive ERS amount is deferred to a regulatory liability returned to retail customers in a future rate case, with any share above 50% reserved for low-income customers (Stipulation ¶46).

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “Issue Date: November 24, 2025 Effective Date: December 4, 2025 ... Section 393.130.7 requires that electrical corporations providing electric service to more than 250,000 customers shall develop and submit to the Commission schedules applicable to customers who are reasonably projected to have above an annual peak demand of 100 megawatts (MW) or more.”

  p.1-2 (Issue Date/Effective Date; Relevant Law)
  https://efis.psc.mo.gov/Document/Display/858399
  Extracted from the PDF text layer via PyMuPDF after WebFetch could not parse the PDF binary directly.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “The LLRP Plan applies to any new facility beginning service with a peak load forecast reasonably expected to be equal to or in excess of a monthly maximum demand of 75 MW ... Large Load Customers must take service for a minimum term of twelve years, and may take service for an additional transitional load ramp period of five years. ... Large Load Customers will be required to provide collateral in an amount equal to two years of minimum monthly bills.”

  p.4 (key provisions summary: Large Load Customers; Service Agreement; Collateral)
  https://efis.psc.mo.gov/Document/Display/858399
  Confirms 75 MW threshold is lower than SB4's statutory 100 MW floor, consistent with the statute allowing but not requiring exactly 100 MW as the tariff line.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “Service Term: LLCS customers shall take service for a minimum term that includes up to five (5) years of an optional transitional load ramp period plus twelve (12) years ... Unless otherwise mutually agreed in the LLCS Service Agreement, the LLCS Service Agreement will automatically extend for periods of five years (“Extension Term”) at the end of the Term or any Extension Term, unless either party to the LLCS Service Agreement provides at least thirty-six (36) months’ written notice to the other party prior to the end of the Term or any Extension Term of its intent not to renew the LLCS Service Agreement”

  Stipulation and Agreement Exhibit, Sec. 8 (Service Term), PDF pp.10-11 of 113
  https://efis.psc.mo.gov/Document/Display/858399
  MO GATE 2026-08-20: ALTERED QUOTE FIXED. The row read 'the Term shall automatically extend for periods of five years (“Extension Term”)'; Sec. 8 reads 'the LLCS Service Agreement will automatically extend for periods of five years (“Extension Term”)'. Subject and modal were both changed, so the string reproduced nowhere in the order. Re-cut from the document's own contiguous text.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “The parties agree the Emergency Energy Conservation Plan tariff applies to LLCS customers and these customers may be interrupted during grid emergencies under the same circumstances as any other customer.”

  para. 54 (Emergency Energy Conservation Plan)
  https://efis.psc.mo.gov/Document/Display/858399

• Order Approving Non-Unanimous Stipulation and Agreement, Case No. ET-2025-0184 (Ameren Missouri LLCS) -- Exhibit, Sec. 8 & Sec. 12 order two-reviewer

  “Sec. 8: "...unless either party to the LLCS Service Agreement provides at least thirty-six (36) months’ written notice to the other party prior to the end of the Term or any Extension Term of its intent not to renew the LLCS Service Agreement, or of its intent to renew the LLCS Service Agreement for the Extension Term at a reduced Contract Capacity." Sec. 12: "In order to terminate before the end of the Term or any Extension Term, the customer must deliver a written notice (a ‘Termination Notice’) to Ameren Missouri not less than twenty-four (24) months prior to the effective date of the termination specified in the Termination Notice ... An additional fee shall apply if the customer seeks to terminate with less than twenty-four (24)-months’ notice (the ‘Early Termination Fee’). In such case, the Early Termination Fee shall be equal to two (2) times the nominal value of the applicable Minimum Monthly Bill times the number of months less than the twenty-four (24)-months’ notice required for termination."”

  Stipulation and Agreement Exhibit, PDF pp. 11 & 14 of 113 (internal Exhibit pages 4 & 7): Sec. 8 "Service Term" and Sec. 12 "Termination of LLCS Service Agreement"
  https://efis.psc.mo.gov/Document/Display/858399
  Resolves the prior 36-vs-24-month exit-notice dispute by re-reading the primary Stipulation and Agreement exhibit attached to the order. Sec. 8 sets a 36-month notice to avoid automatic renewal into a 5-year Extension Term; Sec. 12 sets a separate 24-month notice to actually terminate service before the end of the Term/Extension Term. MO GATE 2026-08-20: WRITE-BACK. This row existed ONLY in the DB (atlas_sources id 86, reviewer 'atlas-steward', 2026-08-18) and in no collector file, so a rebuild from files would have lost it -- the mirror image of the partial-write orphan class. Re-fetched and re-verified this gate: both halves reproduce verbatim in the 113-page order (Sec. 8 at PDF p.11, Sec. 12 at PDF p.14), and the two-provisions reading is CONFIRMED, not merely asserted.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “• Revenue Sharing – The Agreement provides that Ameren Missouri shall file a yearly Earnings Review Surveillance report. If that report shows that the revenues from large load customers exceed the amount of large load customers base rate revenues, such excess revenue shall be returned to customers in an amortization to be determined in a future rate case. Such revenue shall be used to benefit all customers of the electric utility, and excess revenue amounts above a fixed percentage shall be set aside exclusively for the benefit of low-income customers. • Collateral - Large Load Customers will be required to provide collateral in an amount equal to two years of minimum monthly bills. There are also specific provisions relating to required credit ratings.”

  p.4, key-provisions summary: Revenue Sharing; Collateral
  https://efis.psc.mo.gov/Document/Display/858399
  MO GATE 2026-08-20: D7 (VA D5 class). The instrument's cost_allocation asserted the Revenue Sharing / Earnings Review Surveillance mechanism and the low-income set-aside, and its collateral_terms asserted 'subject to specific credit-rating provisions' -- the strings 'Revenue Sharing', 'Earnings Review' and 'low-income' appeared in ZERO of the 90 MO source quotes. Both fields are now sourced from the order's own summary of the approved Agreement.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “Any positive amount shall be multiplied by sixty-five (65%) and the resulting product shall be deferred to a regulatory liability to be returned to retail electric customers through an amortization established by the Commission in a future rate case, over a reasonable period of years established by the Commission in that case. Any percentage of the share above 50% will be for the benefit of low-income customers.”

  Stipulation and Agreement Exhibit ¶46(c) (Revenue Sharing Mechanism), PDF p.30 of 113
  https://efis.psc.mo.gov/Document/Display/858399
  MO GATE 2026-08-20: Supplies the number the order's own p.4 summary leaves as 'a fixed percentage': the ERS share is 65%, and the portion above 50% goes to low-income customers. Sourced this gate; the corpus had neither figure.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “If a customer terminates its service under its LLCS Service Agreement pursuant to this Paragraph 12 during the ramp period, the Customer shall pay to Ameren Missouri an Exit Fee in an amount equal to the applicable Minimum Monthly Bill multiplied by the number of months in the remaining term of the load ramp period plus sixty (60) calendar months. If the customer terminates its service under its LLCS Service Agreement pursuant to this Paragraph 12 after the ramp period, the customer shall pay to Ameren Missouri an “Exit Fee” in an amount equal to the applicable Minimum Monthly Bill multiplied by the lesser of (x) a period of sixty (60) calendar months or (y) the number of months in remaining Term or Extension Term (such lesser period, the “Termination Fee Period”).”

  Stipulation and Agreement Exhibit ¶12 (Termination of LLCS Service Agreement), PDF p.14 of 113
  https://efis.psc.mo.gov/Document/Display/858399
  MO GATE 2026-08-20: The Ameren Exit Fee FORMULA, which the instrument row did not carry at all - it recorded only that a fee is 'keyed to the 24-month threshold.' This is the single most commercially material difference between the two approved Missouri tariffs: Ameren's exit fee is CAPPED at 60 minimum monthly bills (or the remaining term, whichever is less), while Evergy's runs the full remaining Term with a 12-month floor and no cap. exit_terms updated to carry it.

• Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance, File No. ET-2025-0184 order two-reviewer

  “24. A customer together with a Guarantor, which can include its ultimate parent, corporate affiliate, a tenant, or any other entity with a financial interest in the customer (“Guarantor”) that guarantees the Collateral Requirement under the LLCS tariff provisions and the LLCS Service Agreement that (i) has a credit rating of at least A- from Standard & Poor’s (“S&P”) and A3 from Moody’s, (ii) and if rated A- or A3 has not been placed on credit watch by either such rating agency if either the customer’s credit rating by such agency is equal (and not greater to) to the foregoing rating, and (iii) has liquidity greater than ten (10) times the collateral requirement as of the end of applicable period”

  Stipulation and Agreement Exhibit ¶24 (Guarantor credit tests), PDF p.21 of 113
  https://efis.psc.mo.gov/Document/Display/858399
  MO GATE 2026-08-20: The actual credit-rating provisions behind collateral_terms' 'subject to specific credit-rating provisions': A- / A3 floor, no credit watch at the floor, and liquidity greater than ten times the collateral requirement.

• Ameren Missouri Tariff Filing, Schedule No. 6 -- Large Load Customer Service Rate (Service Classification No. 11(M)), effective Jan. 4, 2026 tariff two-reviewer

  “Customers to which this rate applies shall take service for a minimum term that includes up to five (5) years of an optional transitional load ramp period (“Load Ramp” or “Ramp Period”) plus twelve (12) years (the “Term”)... Demand Charge (with minimum monthly demand set at 80 percent of the Contract Capacity (“Minimum Demand”))... The Company will require Schedule LLCS customers to provide collateral in an amount equal to two (2) years of Minimum Monthly Bills, as calculated by the Company (the “Collateral Requirement”)... twenty-four (24)-months’ notice required for termination.”

  Sheet 61.13-61.14 (PDF pp. 9, 12-14): Sections 9 (Service Term), 13 (Termination), 15 (Minimum Monthly Bill), 17 (Customer Creditworthiness)
  https://efis.psc.mo.gov/Document/Display/859644
  Primary tariff-sheet document filed by Ameren Missouri with the PSC; downloaded and text-extracted directly (PDF, 38 pages).

• Docket Sheet, Case No. ET-2025-0184 docket two-reviewer

  “In the Matter of the Application of Union Electric Company d/b/a Ameren Missouri for Approval of New Modified Tariffs for Service to Large Load Customers”

  Docket sheet, filing history table
  https://efis.psc.mo.gov/Case/Display/91941
  Retrieved via WebFetch (AI-processed rendering of the EFIS docket sheet), including filing date 12/12/2024 and a case-closing notice dated 2/4/2026; case caption corroborated verbatim by the order PDF's own text extraction, but the tabular filing-history dates came only from WebFetch's rendering, not a raw-HTML/PDF check, hence medium confidence on those specific dates.

• Docket Sheet - ET-2025-0184 - EFIS docket two-reviewer

  “Status Closed/Archived (6/30/2026) ... Item No. Date Filed Type of Filing Title of Filing Filed on Behalf of Response to Previous Filings 194 2026-06-30 14:53 6/30/2026 2:53 PM Notice Notice of Withdrawal (Stiltner) Sierra Club (Other) 193 2026-02-04 15:06 2/4/2026 3:06 PM Notice Notice Closing Case Commission (Other)”

  Status field; Docket Filings table, Item Nos. 193-194
  https://efis.psc.mo.gov/Case/Display/91941
  MAINTENANCE RE-READ 2026-08-20: raw curl fetch (Chrome UA) of the docket sheet, not WebFetch. UPGRADES the medium-confidence WebFetch-derived source already on file for this instrument (which gave 'a case-closing notice dated 2/4/2026' without the exact filing-history table text) to high confidence with an exact quote and pinpoint. No filings after Item No. 194 (6/30/2026) -- the docket sheet reports 'Returning 194 / 194' -- so NO new order/movement in this docket since the 8/16-8/19 collection window; the case remains Closed/Archived and the last activity (a Sierra Club notice of withdrawal, not a substantive order) predates collection by six weeks. MO GATE 2026-08-20: CONSTRUCTED TABLE QUOTE FIXED. The stored quote interleaved the EFIS filings table's data-label HTML ATTRIBUTE values ("Item No.", "Date Filed", "Filed on Behalf of") between the table's cell values. Those labels are CSS generated content (site.min.css: table.tableCollapse td::before{content:attr(data-label)}), rendered only at narrow viewports; they appear nowhere in the served bytes, so the quote could not reproduce on any raw fetch. Every FACT the row asserted re-confirmed against this gate's own curl fetch; quote re-cut from the page's own contiguous text (the hidden sortText span supplies the ISO datetime that precedes each printed date).

• Utility Tariffs for Large Load Customers | Missouri Public Service Commission government two-reviewer

  “Two of Missouri's three regulated electric utility companies, Ameren Missouri and Evergy, have approved large-load tariffs. Liberty Utilities' large load tariff case is currently in progress.”

  main body text
  https://psc.mo.gov/General/Utility_Tariffs_for_Large_Load_Customers
  Fetched raw HTML via curl and stripped tags to preserve exact page text (typographic apostrophes/dashes normalized during extraction).

• Utility Tariffs for Large Load Customers | Missouri Public Service Commission government two-reviewer

  “Minimum Service Contracts. Large-load customers must take service for a minimum of 12 years, with the option of taking an additional 5 years as a "ramp up" period until fully using their projected amount of energy, for a potential 17-year commitment. Financial Security and Collateral Requirements. Large load customers must meet creditworthiness and liquidity requirements as well as provide collateral in the amount of two years of minimum monthly bills.”

  main body text, bulleted provisions list
  https://psc.mo.gov/General/Utility_Tariffs_for_Large_Load_Customers
  This page's link labeled 'Ameren Large Load Tariff' points to https://efis.psc.mo.gov/Document/Display/859644 (the approved Ameren tariff document itself, referenced but not separately fetched/quoted here).

• Missouri PSC, File No. ET-2025-0184, Order Regarding Ameren Missouri's Request for Approval of a Large Load Rate Plan and Associated Variance government two-reviewer

  “File No. ET-2025-0184 ... The Commission granted intervention to Amazon Data Services, Google LLC, Evergy Metro, Inc. d/b/a Evergy Missouri Metro and Evergy Missouri West, Inc. d/b/a Evergy Missouri West (collectively “Evergy”), The Empire District Electric Company d/b/a Liberty, Missouri Industrial Energy Consumers, Sierra Club, and Renew Missouri Advocates (Renew). The Staff of the Commission and the Office of the Public Counsel (Public Counsel) were also parties... Public Counsel noted that although it did not join the Agreement filed that morning, it also did not oppose it.”

  p.1 (caption/docket), p.2 (intervenors), p.3 (OPC non-signatory/non-opposition)
  https://efis.psc.mo.gov/Document/Display/858399
  Primary PSC order (113 pages), downloaded and text-extracted directly. Issue Date Nov. 24, 2025; Effective Date Dec. 4, 2025.

• Powering Growth in Missouri to Bolster Communities (Powering Missouri Growth Plan) company two-reviewer

  “a large load user or data center would be required to pay a certain percentage of their maximum demand each month – even if they use less. It also requires the end-use customer to provide collateral or prove financial viability and be able to meet those requirements, as well as to pay an exit fee if they cease operations or otherwise are unable to meet the obligations outlined in the electric service agreement contract.”

  FAQ: 'What are some of the parameters for these new customers to pay their fair share...'
  https://www.ameren.com/page/powering-mo-growth
  Ameren Missouri's own consumer-facing summary of the tariff; corroborated by the actual tariff filing and PSC order cited below.

• Missouri utility regulators approve Ameren rates for data centers journalism two-reviewer

  “The commission voted unanimously to accept Ameren’s tariff proposal for customers using 75MW or more of electricity per month, which is more than double the usage of the largest customer in Ameren’s service area in 2024. The proposal was supported by the Sierra Club, Renew Missouri, staff of the Public Service Commission, Google and Amazon. The Office of Public Counsel, which advocates for customers of investor-owned monopoly utilities in Missouri, did not support the agreement but did not object.”

  paras. 2-3
  https://www.stlpr.org/health-science-environment/2025-11-24/missouri-utility-regulators-approve-ameren-rates-data-centers
  St. Louis Public Radio, by Kate Grumke.

• Google Pledges Power, Ratepayer Protections in $15B Missouri Data Center Expansion journalism two-reviewer

  “Google will invest $15 billion in Missouri infrastructure, including a new data center in New Florence, Montgomery County... a unanimous settlement—signed by Google, Ameren Missouri, Evergy Metro, Evergy Missouri West, the Sierra Club, Renew Missouri, and Missouri Industrial Energy Consumers—embedding the framework in a PSC-approved tariff that mandates 12-to-17-year minimum service contracts, collateral equal to two years of minimum bills, and an 80% minimum monthly demand charge... “This is the largest economic development project in Ameren Missouri’s service territory, and our new large load rate structure is designed to ensure we continue to deliver safe, reliable electric service for all customers at the lowest cost possible, with robust protections and generational benefits for the communities we serve,” Martin J. Lyons Jr., Chairman, President, and Chief Executive Officer of Ameren Corporation, said on Wednesday.”

  paras. 3, 5, 8-9
  https://www.powermag.com/google-pledges-power-ratepayer-protections-in-15b-missouri-data-center-expansion/
  POWER Magazine (trade journalism); also reports Ameren had signed ESAs for 2.2 GW as of February 2026 'out of a total 3.4 GW of construction agreements,' corroborating the St. Louis Public Radio figures below. MO GATE 2026-08-20: pub_date corrected 2026-05-20 -> 2026-05-21. POWER's own schema gives datePublished 2026-05-21T18:21:57Z (dateModified 2026-05-22); May 20 is the date of Google's announcement, which the article reports, not the date the article ran.

• Ameren Missouri signed confidential contracts with multiple big data centers this week journalism two-reviewer

  “Multiple large data centers have signed binding electric agreements with Ameren Missouri this week, CEO Marty Lyons said during the company’s earnings call Thursday... The agreements total 2.2 gigawatts of new demand for electricity, which is almost the entire capacity of the Labadie coal plant, Ameren’s largest power plant... By signing the agreements, the unnamed companies are committing to paying at least 80% of the amount of electricity they said they need for a minimum of 12 years of service from Ameren — even if they don’t use that much power... Those customers have already paid Ameren $46 million in nonrefundable payments to cover the cost of transmission upgrades.”

  paras. 3-4, 6-7, 11
  https://www.stlpr.org/health-science-environment/2026-02-12/ameren-missouri-signed-confidential-contracts-with-multiple-big-data-centers-this-week
  St. Louis Public Radio, by Kate Grumke; independently corroborates the 80% minimum-take and 12-year term found in the primary tariff document.

• Google Pledges Power, Ratepayer Protections in $15B Missouri Data Center Expansion journalism two-reviewer

  “On Nov. 24, 2025, notably, the Missouri PSC approved a unanimous settlement—signed by Google, Ameren Missouri, Evergy Metro, Evergy Missouri West, the Sierra Club, Renew Missouri, and Missouri Industrial Energy Consumers—embedding the framework in a PSC-approved tariff that mandates 12-to-17-year minimum service contracts, collateral equal to two years of minimum bills, and an 80% minimum monthly demand charge.”

  paragraph on the Nov. 24, 2025 PSC settlement
  https://www.powermag.com/google-pledges-power-ratepayer-protections-in-15b-missouri-data-center-expansion/
  MO GATE 2026-08-20: The evidence for the facility→instrument link now recorded on google-new-florence-datacenter. RECORDED DISCREPANCY, not resolved: POWER calls the settlement 'unanimous'; the Commission's own caption and order call it a NON-unanimous stipulation and agreement, and St. Louis Public Radio reports the Office of the Public Counsel 'did not support the agreement but did not object.' The primary controls; no Atlas field asserts unanimity.

• Google New Florence Data Center

  Montgomery · announced · Missouri dossier

• Missouri Office of the Public Counsel other

  “Public Counsel was not a signatory to the Agreement... Public Counsel noted that although it did not join the Agreement filed that morning, it also did not oppose it.”

• Ameren Missouri (per CEO Marty Lyons, Feb. 2026 earnings call) other

  “The agreements total 2.2 gigawatts of new demand for electricity, which is almost the entire capacity of the Labadie coal plant, Ameren's largest power plant.”

• Martin J. Lyons Jr., Chairman, President and CEO, Ameren Corporation other

  “This is the largest economic development project in Ameren Missouri's service territory, and our new large load rate structure is designed to ensure we continue to deliver safe, reliable electric service for all customers at the lowest cost possible, with robust protections and generational benefits for the communities we serve.”