There's $18.6 billion in requested rate increases sitting in front of state commissions right now. Your 2027 utility budget probably doesn't know that.
Utilities filed for $18.6 billion in electric and gas rate increases in the first half of 2026. The second quarter alone accounted for a record $9.2 billion, up 26% over the same quarter last year. Those filings touch more than 56 million customer accounts.
Here's the number that turns all of that from news into a planning input: over the past two years, 58% of what utilities requested has been approved, with very few requests rejected outright.
So if you're building a 2027 facilities budget off trailing twelve months of actual spend, you're building on a figure that has a known upward revision already in the pipeline. Not a forecast. A filing, with a docket number, in a proceeding you can go read.
The filings aren't evenly distributed, and the regional concentration matters if your portfolio is concentrated too.
Southern states carried the largest regional total in the first half, at $4.5 billion across more than 26 million customers. The largest individual requests included Oncor in Texas at $1.2 billion, and Duke Energy's Carolinas and Progress units at more than $800 million combined. In the Midwest, Consumers Energy, DTE Energy, and Wisconsin Electric Power each filed for roughly $500 million.
If you operate 60 stores across Texas and the Carolinas, two of the three largest rate requests in the country this year land on your portfolio. That's a knowable fact about your 2027 costs, available now, and it's sitting outside the budget process at almost every operator.
None of this is a one-year story either. Investor-owned utilities are expected to spend at least $1.4 trillion over the next five years replacing aging infrastructure, modernizing the grid, and adding capacity for load growth. That spending gets recovered through rates. The filings will keep coming.
Meanwhile the rate has already moved. Commercial electricity averaged 14.19 cents per kilowatt-hour in June 2026, against 13.54 cents in June 2025. Up 4.8% year over year.
Now think about what that does to a facilities budget denominated in dollars.
You budget $4.2 million in utility spend for 2027. The rate case clears in March at 6%. You are now over budget by roughly $250,000 and you did nothing wrong. Your team may have run a genuinely good year on consumption and it won't matter, because the number you committed to was a bet on a rate you don't set.
Worse, the variance is uninterpretable. Nobody looking at that overage can tell whether the facilities team let consumption drift or whether the commission approved a rate increase. Both produce the same red number. And when the next energy project comes up for funding, the CFO remembers that the last budget missed.
A dollar budget makes your team accountable for a regulatory outcome. That's not a stretch goal. It's a category error.
The alternative is to commit to the thing you actually control.
Denominate the budget in kilowatt-hours and peak kilowatts. Consumption and demand are operational outcomes. They're driven by runtime, schedules, setpoints, and equipment condition, all of which belong to your team. Commit to those.
Carry the rate as a separate, explicitly stated assumption. Write it down: "This budget assumes 14.4 cents per kWh blended. A pending rate case in our largest territory could move that to 15.3." Now the rate is visible, sourced, and owned by nobody, which is correct, because nobody in your building controls it.
Report variance in two lines. Load variance and rate variance. When the year closes, you can say plainly: consumption came in 6% under plan, the rate came in 5% over, net spend was roughly flat. That's a defensible sentence. "We missed by $250,000" is not.
The load budget survives the rate case intact. That's the entire point. When the commission rules, your operational commitment is still true and still measurable, and the difference lands on a line that has an explanation attached.
If you've never budgeted this way, the first year takes some work, because consumption data usually arrives tangled up with spend rather than separated from it.
Start by pulling twelve months of interval data, or failing that, twelve months of bills with usage broken out. Split every site into consumption and rate. Then find your controllable share, which for retail and food service sits largely in HVAC runtime, lighting hours, and the equipment that runs when nobody's in the building.
That last category is the largest single opportunity in a retail box and the easiest to commit to, because reducing load during unoccupied hours carries no customer-facing risk. A building that's occupied twelve hours a day and energized twenty-four has twelve hours of load nobody is defending.
Set the 2027 commitment against that. Something like: reduce kWh per site per operating hour by 8% against the 2026 baseline, measured monthly, with the rate carried separately. Then when the rate case clears in March, your budget doesn't break. It just gets a footnote.
Three things, and they take an afternoon.
Look up whether your largest utility territories have a rate case pending. State commission dockets are public and searchable. If you have 40 sites under Oncor, that $1.2 billion filing is your business.
Restate your draft budget in kilowatt-hours with the rate as a named assumption. You don't have to change the process to do this. You can present both.
Decide what you're committing to on load, and make it specific enough that you could miss it. A commitment you can't fail isn't a commitment, and it won't get funded twice.
The $18.6 billion is already filed. History says 58 cents of every dollar of it gets approved. That's not something to react to next spring. It's something to budget against this month.
Want a load baseline before you finalize 2027? Book a demo and we'll walk your interval data.