Dr. Mark McNees
Working press resource. Facts verified against primary sources. Last verified August 24, 2026. On deadline: 850.973.7687
National ratepayer tracker, fourteen states with cost-allocation action

Who pays for the grid capacity that data centers trigger

This is the deep reference: state-by-state stakeholder maps, money-flow diagrams, key facts, and the gaps, all with numbered citations. For story angles, quotes cleared for use, and verified stats on one page, start at the press desk.

Texas, Florida, New Jersey, and Oklahoma passed binding statutes. Ten other states are answering the same question through tariffs, rate cases, studies, investigations, and merger reviews. The organizing principle is simple. The load creator should pay for the load it creates. Everything else is mechanism.

Status verified on August 7, 2026. Every checkable fact is numbered and cited in Sources and citations, and each reference is marked primary or secondary. Dockets move quickly; re-check before republishing.
FloridaBinding statute TexasBinding statute New JerseyBinding statute PennsylvaniaPUC tariff VirginiaRate class WisconsinRewritten tariff ArizonaRate case CaliforniaStudy law North CarolinaMerger review South CarolinaMerger review OregonRates in effect GeorgiaInvestigation OhioTariff and bills OklahomaBinding statute
Next to the fourteen, not among them

New York has the only statewide data center moratorium in the country, Executive Order No. 62. It is a pause on permits, not a cost-allocation rule, so it sits beside the fourteen states rather than inside the count. See New York and the national moratorium picture.

The core idea. A data center that triggers hundreds of millions of dollars in grid upgrades should carry that cost itself. When the cost lands on the residential rate class instead, that is cost externalization: a private profit paid for with a public bill. Every framework below is a different attempt to stop that shift.

"The question is not whether we build the grid for AI. It is who pays for it. A data center that triggers a billion dollars in upgrades should carry that cost, not hand it to a retiree three counties away who never asked for the load."
Dr. Mark McNees, Florida State University

Florida

Binding statute

The first state to put a binding statute behind the load-creator-pays principle. SB 484 became law on May 7, 2026 and takes effect July 1, 2026. The real test is the tariff filings that follow.

"Florida did something rare. It put a binding statute behind a simple rule: the load creator pays for the load. The law is written. The real test is whether the tariff filings this fall have teeth."
Dr. Mark McNees, Florida State University
Stakeholder map
Florida Legislature SB 484, unanimous Senate Florida PSC Approves the tariff filings FPL and other IOUs File compliant tariffs Large load customer 50 MW+. Pays full cost of service Residential ratepayers Protected from cost shift directs sets tariff rules bills shields

The statute names the PSC as the firewall. Utilities file, the Commission approves against the statute, and the large load customer carries its own cost of service.

How the money flows
1 GENERATION AND GRID Utility builds capacity Transmission, generation upgrades 2 COST ALLOCATION (SB 484) PSC tariff assigns cost to the load creator Minimum charges, contract terms, financial guarantees Data center pays Full cost of service Households Not charged for the trigger cost of the buildout protected

Key facts

  • Law: CS/CS/SB 484, Chapter 2026-65, effective July 1, 2026 except as otherwise provided.12
  • Threshold: Large load customers with anticipated monthly peak load of 50 MW or more.1
  • Mechanism: Utilities must file tariffs for PSC approval so large loads pay their own cost of service, and the risk of nonpayment may not be borne by the general body of ratepayers. Load splitting to dodge the threshold is barred.1
  • Filing deadline: October 1, 2026 is the deadline for public utilities to file compliant large load tariffs for Commission approval under s. 366.043(8), Florida Statutes.1
  • The rate-design question is separate: The October 1 deadline governs when a compliant tariff must be filed. It does not settle what a large load customer is charged. Rate design is resolved in the Commission proceedings that follow, on their own schedule, as the Duke docket below shows.
Live proceeding: Duke Energy Florida large-load tariff

FPSC Docket 20260064-EI, "Petition for a limited proceeding to approve large load tariff," Duke Energy Florida, LLC. Docketed April 22, 2026. Open, with 142 filings as of July 19, 2026. This is the first tariff filing that follows SB 484, and it is being litigated now.

Docket at a glance

  • Status: Tariff suspended by Commission order June 19, 2026. The docket remains open pending decision. Hearing set for August 25 and 26, 2026, and briefs due September 15. The prehearing conference was held August 5, 2026.
  • Procedural history: Duke first petitioned for the same policy September 5, 2025 in Docket 20250113-EI. That proceeding was litigated through intervention, OPC testimony, depositions, and Duke rebuttal, with a hearing set for April 8, 2026. Duke moved for abatement March 16, 2026, three days after the Legislature passed SB 484 on March 13, then refiled in the current docket.
  • Parties of record: Duke Energy Florida; Office of Public Counsel; Florida Rising, represented by Earthjustice; Florida Industrial Power Users Group; PCS Phosphate White Springs. Nucor Steel Florida petitioned to intervene July 14, 2026.
  • Proposed terms as filed: 20-year contract term; take-or-pay minimum demand at 75 to 85 percent of annual contract capacity; minimum billing energy volume at no less than 60 percent load factor; two-year termination notice; 100 percent of estimated extension costs paid in advance as CIAC, refundable over up to five years.
  • What Duke changed to comply with SB 484: Paragraph 11 of the petition lists the changes Duke made to comply with the new legislation. Applicability was lowered from 100 MW to 50 MW. Rate schedule LLC-1 was withdrawn from consideration, with stated intent to propose a new large load rate schedule in the next rate case. CIAC flexibility was removed, so all customers pay upfront subject to a five-year refund. The minimum term was raised from 15 to 20 years, with a two-year notice requirement.27
  • The price is deferred to a later schedule: Section 13.08 of the proposed Large Load Customer Policy provides that until a new large load rate schedule is presented and approved, large load customers take service under existing GSD-1 or GSDT-1 rates. The petition establishes the framework; the rate that a 50 MW customer actually pays is set in a separate later proceeding.27
  • Hearing: Scheduled for August 25 and 26, 2026.27

Docket source: FPSC Docket 20260064. Petition: Document No. 02327-2026, filed April 22, 2026 [27].

Approved instrument: Florida Power & Light Incremental Generation Charge

Florida Power & Light, Incremental Generation Charge. Approved as part of a contested, non-unanimous settlement in FPL's 2025 base rate case, effective January 1, 2026.22

Charge at a glance

  • Scope: Rate schedules LLCS-1 and LLCS-2 apply to new or incremental load of 50 MW or more at a load factor of 85% or higher.
  • Mechanism: The Incremental Generation Charge recovers incremental generation costs and is charged in addition to embedded cost-based rates.
  • Transmission: Transmission interconnection is handled separately under FPL's contribution in aid of construction tariff, refundable through monthly bill credits for a maximum of five years.

Order source: Order No. PSC-2026-0022-S-EI, Docket No. 20250011-EI. Back to top

Where the gaps are

The affiliate transfer price

SB 484 audits the price the utility charges the customer. It does not audit the price a regulated utility pays a generator owned by the same parent company. That transfer price sits between the two and no one reviews it directly.

Load durability is not addressed

The statute assigns cost at the point of connection. It does not require regulators to stress-test whether the projected demand is real and lasting before the buildout is approved. If demand shrinks, the stranded asset risk remains.

Sources: [1] [2] [22]. Back to top

Texas

Law

Texas moved a year before Florida and asked a different first question: not who pays for the grid, but whether the load asking to connect is real. SB 6, signed June 20, 2025 and effective immediately, rebuilt how large loads interconnect in ERCOT, with financial commitments up front and a mandatory

curtailmentCutting electricity demand instead of adding supply. It is the fast, cheap tool a grid uses when demand outruns generation. Whether a large load can be curtailed, and who gets curtailed first, is one of the central fights in data center policy. Why curtailment matters more than price caps →
switch for grid emergencies.

"Texas answered a different question first. Before asking who pays, SB 6 asks whether the load is real. A six-figure study fee and full interconnection cost responsibility is how you clear phantom projects out of the queue."
Dr. Mark McNees, Florida State University
Stakeholder map
PUCT SB 6 rules, Project 58317 ERCOT Studies, curtailment authority Large loads, 75 MW+ Data centers, crypto, manufacturers Transmission providers Collect fees, security, CIAC ERCOT ratepayers 4CP cost allocation under review directs studies sets standards costs allocated

SB 6 gave the PUCT and ERCOT new authority over how loads of 75 MW or more connect: study fees, site control, financial security, disclosure of duplicate requests, and a remote-curtailment requirement for anything interconnecting after December 31, 2025.

Key facts

  • Law: SB 6 was signed June 20, 2025 and took effect immediately, enacting PURA section 37.0561 and amending PURA section 35.004, the transmission cost provision that Project 58484 implements.31 Default threshold: 75 MW at a single site, adjustable by the PUCT. It requires site control, proof of financial commitment, disclosure of duplicate interconnection requests, and transmission screening study fees reported in the range of $100,000 to $300,000 depending on project size.10
  • Kill switch: Large loads interconnecting after December 31, 2025 must install equipment allowing remote disconnection during firm load-shed events. ERCOT can order curtailment or backup-generation deployment only after market options are exhausted.10
  • Proposed rule, not yet adopted: On March 12, 2026 the PUCT voted to publish draft rule 16 TAC 25.194 under Project No. 58481: a non-refundable interconnection fee of $50,000 per MW of contracted demand, 100 percent of direct interconnection costs paid by the customer, and security for system upgrades. If a customer withdraws, 80 percent of remaining security goes to the transmission provider's rate base. Comments closed April 17, 2026 and the Commission signaled final adoption around mid-2026. Terms below are as proposed and may change on adoption.11
  • The demand behind it: ERCOT's large-load interconnection queue was reported at more than 438 GW in June 2026, which ERCOT says is almost 90 percent data centers.25 At a December 9, 2025 board meeting the figure was more than 233 GW at over 70 percent, an increase of almost 300 percent over the 2024 year-end total.26 A queue is requested capacity, not confirmed load, and ERCOT treats it as planning pressure rather than a forecast. It is the scale the interconnection standards are being written against.
  • Co-location review, adopted: Pairing a new large load with an existing grid-connected generator requires an ERCOT study and PUCT approval under 16 TAC 25.205, adopted March 26, 2026 in Project No. 58479. ERCOT may direct curtailment or dispatch of a co-located facility only where the arrangement involves a new or expanded large load and the co-located generation can serve at least 50 percent of on-site demand without exporting to the grid. This closes the path where a data center removes a power plant from the shared grid.10
  • Batch review replaces one-at-a-time: On June 18, 2026 the PUCT approved ERCOT's Batch Zero process, moving evaluation of 75 MW-plus interconnection requests from individual review to a single grouped study, which ERCOT describes as assessing the full picture of future demand at once and replacing a project-by-project process that had become lengthy and repetitive. ERCOT is to notify Batch Zero applicants of project classifications by August 2026. Batch 1 applications are expected to open in summer 2027, with a transmission plan for the batch expected in fall 2027.25 As of the August 3, 2026 directive below, ERCOT has postponed this Batch Zero transmission planning study. The first scheduled deliverable of that process, the notice telling each interconnecting distribution or transmission service provider how a large load was classified, was due August 7, 2026 and was not sent.3239
  • Governor's directive on residential transmission costs: Governor Abbott's June 10, 2026 directive required the PUC and ERCOT to submit a joint memorandum to the Governor's office by July 17, 2026, and directed the PUC to initiate action to reduce residential ratepayers' transmission costs by July 31, 2026.28 The PUCT and ERCOT response was released in July 2026 and includes requiring data centers to pay for transmission infrastructure built to serve them and to contribute toward reducing residential electric bills, rules preventing large data centers from diverting existing power away from the ERCOT grid, and a mandate that new data centers reduce load promptly on ERCOT instruction. The PUCT has also opened a rulemaking requiring large loads to post financial security for interconnection, apply forfeited security to offset transmission rates, and begin paying transmission charges once capacity is available.29
  • Audit and connection pause: On August 3, 2026 Governor Abbott directed the PUCT and ERCOT to conduct a comprehensive verification and audit of every data center advancing through ERCOT's interconnection process, and to complete that audit before any project moves forward. A project that fails to comply is to be denied grid connection. Building on the June 10 directive, the order requires each project to disclose the extent to which it is paying its own way or depending on public financial assistance, including tax incentives, grants, and abatements; whether it will generate its own power or rely on the ERCOT grid, with projected annual and peak demand; its water use and cooling method; and steps to reduce community impacts. ERCOT said it would implement the directive, including postponing the Batch Zero transmission planning study. The governor's office put the queue at more than 474 GW, over five times the state's record peak demand.32 ERCOT acted the same day, issuing Market Notice M-A080326-01, which stated that ERCOT would not deliver the Batch Zero large load classification notices by the scheduled August 7, 2026 deadline and would instead seek a good cause exception to the Batch Zero timelines and process in Planning Guide Sections 5 and 9, ahead of the PUCT open meeting on August 20, 2026.39 The pause was therefore not open-ended by design. The Commission took the matter up at its August 20, 2026 open meeting. The outcome of that meeting is not yet reflected on this page.
  • Five dockets, one of them the allocation question: SB 6 implementation runs through five PUCT projects: interconnection standards (58481), co-located net metering (58479), load forecasting criteria (58480), voluntary demand reduction (58482), and transmission cost allocation (58484). The first four govern how a large load connects and behaves. The fifth is where who-pays is decided.12
Where the gaps are

Interconnection is covered. Retail cost of service is not.

SB 6 polices how large loads connect and what they pay to connect. It is not a Florida-style retail cost-of-service statute; most of ERCOT is a deregulated retail market. Whether ongoing transmission costs land fairly depends on the separate transmission cost allocation proceeding, PUCT Project No. 58484, which the Commission must finish by December 31, 2026.30 Connection rules and allocation rules are different instruments, and Texas has moved faster on the first than the second.

Exemption engineering

Law firms are already publishing structures to preserve co-location exemptions through entity acquisitions, leases, and tolling agreements. The rule is only as strong as the review that polices the workarounds.

Sources: [10] [11] [12] [25] [26]. Back to top

New Jersey

Law

New Jersey put the load-creator-pays principle into a signed statute. The Data Center Fair Share Act, S731 / A796, became law on July 7, 2026 under Governor Mikie Sherrill. It creates a separate ratepayer class and rate structure for data centers, and it backs that class with financial guarantees rather than leaving the commitment to a later tariff proceeding.

"New Jersey did what a rate class alone cannot. It wrote the terms of the guarantee into the statute and left the regulator only the job of implementing them. Take at least 85 percent of the service you asked for, hold it for ten years, and post security for the transmission built to serve you. That is the load creator carrying the load it creates."
Dr. Mark McNees, Florida State University

Key facts

  • Law: The Data Center Fair Share Act, S731 / A796, was signed July 7, 2026 by Governor Mikie Sherrill. It creates a separate ratepayer class and rate structure for data centers.2324
  • Take-or-pay guarantee: Large-load data center customers must commit to taking at least 85 percent of their requested service for a minimum of ten years, so the utility is not left recovering the cost of capacity built for demand that never arrives.2324
  • Upfront security: The Act requires upfront deposits or financial security covering the cost of new transmission built to serve the data center load.2324
  • Threshold and aggregation: The Board of Public Utilities sets the qualifying threshold, which may not exceed 50 MW of peak demand, and related facilities under common ownership or control, or sharing infrastructure, are aggregated toward that threshold.2324
Where the gaps are

A guarantee audits the bill, not the affiliate

The 85 percent commitment and the transmission security move real risk onto the data center, which is exactly the point. What a rate class and a take-or-pay guarantee still do not reach is the transfer price a regulated utility pays a generator owned by the same parent company. The Fair Share Act audits what the data center pays the utility. It does not audit what the utility pays an affiliated generator, the gap this page tracks across every state.

Sources: [23] [24]. Back to top

Pennsylvania

Model tariff

Pennsylvania acted through its utility commission, not a signed statute. On April 30, 2026 the PUC voted 5-0 to adopt a model

large-load tariffA separate rate class for very large electricity customers, usually data centers. It sets what they pay, what infrastructure costs they cover, and what happens if they leave early. Fourteen states have active state-level action on how these costs are allocated. How spreading a cost changes who pays →
. A legislative version passed the House and stalled in the Senate. PJM capacity costs sit on top of all of it, and have now cleared at the FERC cap in three consecutive auctions.

"Pennsylvania shows the cost most people never see. The capacity charge reaches sixty-seven million people across PJM's thirteen states, and data center demand is driving it. A model tariff helps at the connection point, but the auction cost still lands on everyone."
Dr. Mark McNees, Florida State University
Stakeholder map
PJM Interconnection Capacity auction, FERC cap Pennsylvania PUC Model tariff, April 30 2026 PA House (HB 1834) Passed House, Senate stall Distribution utilities e.g. PPL, incorporate model Large load, 50 MW+ Pays interconnection upgrades Residential ratepayers Bills up 10-20% on capacity Consumer advocates PULP, intervene in filings cost pressure recommends bills capacity pass-through

Two forces stack in Pennsylvania. The PUC model tariff pushes interconnection cost onto large loads, while PJM capacity auction costs still flow through to every bill.

How the money flows
1 PJM CAPACITY AUCTION Capacity price hit the FERC cap $333.44 per MW-day, cleared short of need 2 STATE TARIFF LAYER PUC model tariff, interconnection Large load pays upgrades, deposits, collateral Everyone's bill rises Capacity cost is socialized across 67M PJM customers Large load pays Its own interconnection socialized assigned

Key facts

  • Regulatory action: The PA PUC adopted a model large-load tariff framework on April 30, 2026. Utility interconnection upgrade costs are recovered directly from the large-load customer. It is guidance that utilities incorporate into their own filings.4
  • Legislation: HB 1834, the Data Center Act (Rep. Matzie), passed the House and moved to the Senate. It directs the PUC to create data center regulations. Related bills include HB 2150, HB 2151, and SB 939.3
  • PJM pressure, 2027/2028: PJM's December 17, 2025 auction, for the 2027/2028 delivery year, cleared at the $333.44 per MW-day FERC cap. It was the first auction in which the entire RTO, including Fixed Resource Requirement areas, fell short of the reliability requirement, by 6,516.6 MW. PJM attributed over 95 percent of the more than 5 GW increase in the reliability requirement to data center demand.5
  • PJM pressure, 2028/2029: The next auction, announced July 14, 2026, cleared at the $325 per MW-day cap, down 2.5 percent, securing 138,318 MW of unforced capacity. The shortfall against the reliability requirement widened to about 6,821 MW, with roughly 525 MW of new generation clearing. PJM cited a roughly 2 GW increase in forecast demand driven largely by data center development, and said it is preparing market reforms including a backstop capacity procurement and a "connect and manage" framework for large new loads.5
  • The price collar: PJM, FERC, and the governors of all 13 PJM states established a capacity price cap and floor across four auctions to limit volatility. The 2028/2029 auction was the third consecutive auction under the collar. Pennsylvania Governor Josh Shapiro led the advocacy for it. PJM has estimated the collar reduced capacity costs by billions of dollars per auction, though it does not address the underlying supply and demand imbalance.5
Where the gaps are

The model tariff is not binding

The PUC framework is a recommendation. Protection depends on each utility filing a tariff that follows the model, and on advocates intervening if a filing falls short. A binding statute would close that discretion.

Capacity cost is still socialized

The state tariff addresses interconnection upgrades. It does not touch the PJM capacity charge, which is spread across all 67 million customers in the region. The independent market monitor tied a majority of one auction's price jump to data center demand, yet the cost lands on every bill.

Sources: [3] [4] [5]. Back to top

Virginia

Rate class in place

Home to the world's largest data center market. The SCC created the GS-5 large-load rate class in its November 2025 Dominion order, and the 2026 Legislature passed SB 253 on top of it. Transmission allocation is the live question. The SCC issued its Rider T-1 final order on July 31, 2026, directing Dominion to file proposed line extension amendments requiring a mandatory contribution in aid of construction on direct connect facilities, and deferring the broader question of higher-order transmission cost. The pending NextEra merger reshapes the whole picture.

"Virginia built the rate class inside a rate case, not a new law. It moved real cost onto the largest users. But run the math past the contract term and a big share still falls back on households. A start, not a finish."
Dr. Mark McNees, Florida State University
Stakeholder map
Virginia SCC Created GS-5 rate class Dominion Energy Proposed the rate class VA General Assembly SB 253 (Lucas) Data centers, 25 MW+ 14-year contracts, 85/85/60 minimum demand charges Residential ratepayers Bill up ~$16/mo, partial shield SELC, PEC, advocates Argue cost split still unfair proposed SB 253 adds approved partial shield

The SCC built the mechanism inside a rate case rather than through new legislation. SB 253 then gave the SCC authority to shift more capacity and distribution cost onto data centers.

How the money flows
1 GRID INVESTMENT Dominion builds for demand 183% projected demand rise by 2040 2 GS-5 COST ALLOCATION Minimum demand charges lock in cost 85% transmission, 85% distribution, 60% generation Data center pays Even if it uses less Households Still carry residual share residual

Key facts

  • Rate class: The SCC created the GS-5 large-load rate class in its final order of November 25, 2025 in Dominion's biennial review, Case No. PUR-2025-00058. Minimum demand charges are 85 percent of contracted distribution and transmission demand and 60 percent of generation demand.6
  • Contract term and threshold: GS-5 covers customers demanding 25 MW or more at a monthly load factor above 75 percent. The contract term is 14 years, applying to customers taking initial service on or after January 1, 2027. A customer that ceases operations or defaults during the term owes an exit fee covering outstanding minimum charges for the remaining duration. Customers must post collateral and give three years' notice before reducing contracted demand.6
  • Legislation: SB 253 (Lucas), paired with HB 1393, passed the 2026 session. As amended it extends Dominion and Appalachian Power weatherization programs and requires the SCC, in Dominion's next biennial rate case, to take all measures to reasonably ensure that high-load customers including data centers pay their own costs and are not subsidized by other ratepayers.
  • Active transmission case: Rider T-1, Case No. PUR-2026-00056. The SCC heard argument July 14, 2026 on Dominion's proposal to recover about $1.58 billion in transmission cost. Rider T-1 currently runs $11.79 a month for a typical residential customer; Dominion first estimated an increase of $2.90 a month, then refined it to about $0.94 in rebuttal testimony filed June 30, 2026. That reduction came from the amended 12-CP allocation methodology, including the 85 percent minimum transmission demand charge for large loads that begins January 1, 2027, not from any contribution in aid of construction. The governor's office urged a "but for" cost-causation standard, assigning to data centers the transmission that would not be built but for them. Rider T-1 takes effect September 1, 2026.19
  • What the July 31 order actually did: The final order does not itself direct direct assignment. It directs Dominion to file, within 90 days and in a separate new docket, proposed amendments to its line extension policy requiring a mandatory contribution in aid of construction. That requirement applies prospectively and only to "direct connect" transmission facilities, meaning the substations and the lines connecting a large load to the bulk system where that customer is the but-for cause. On higher-order transmission cost, the Commission expressly found the record supports a more deliberate approach and deferred the question.19
  • What comes next and when: Amended line extension policy due October 29, 2026. Cross-utility status update due November 28, 2026.19
Where the gaps are

The residual still lands on households

Advocates calculated that after the 14-year contract term, a majority of the grid-upgrade cost can still fall on individual ratepayers. The rate class narrows the shift, it does not eliminate it.

The merger changes who owns the generator

If NextEra acquires Dominion, the same parent could own both the regulated Virginia utility and unregulated generation. That raises the affiliate transfer-price question the rate class was not designed to police.

In Henrico County, government and school electricity rates rose nearly 25 percent on July 1, 2026, adding about $5 million a year across county and school facilities. The same increase applies to roughly 170 member entities of the Virginia Energy Purchasing Governmental Association statewide. County and utility officials attribute it to fuel and grid costs, not data centers. The open question is allocation: the SCC has ordered Dominion to shift generation cost allocation toward large loads like data centers, and whether any part of this increase reflects that shift has not been addressed publicly. Wholesale power costs across the PJM region rose 62.7 percent in the first five months of 2026 against the same period in 2025, per PJM's independent market monitor.16

Transmission allocation is the next layer, not a first move

The November 2025 rate class already set minimum demand charges and exit fees for large loads that leave before their contract term ends.20 The Rider T-1 case is Virginia refining transmission cost allocation on top of that base. The governor's office argued that data centers should pay for transmission lines that would not be built but for the data centers, a "but for" standard. Dominion asked the Commission to let the GS-5 mechanism operate before making further allocation changes. The July 31, 2026 final order went narrower than direct assignment. It directs Dominion to file, within 90 days and in a separate new docket, proposed amendments to its line extension policy requiring a mandatory contribution in aid of construction, applying prospectively and only to direct connect facilities, the substations and lines connecting a large load to the bulk system where that customer is the but-for cause. On higher-order transmission cost, the shared backbone that carries power to everyone, the Commission found the record supports a more deliberate approach and deferred the question. That deferral is the gap: the direct connect piece is the easy half of cost causation, and the harder half is still open.19

Sources: [6], [16], [19], [20]. Back to top

Wisconsin

Tariff approved

A commission-led outcome with unusually strong customer protections. On April 24, 2026 the PSC unanimously approved a rewritten "very large customer" tariff for We Energies. The utility asked the Commission to reopen the credit-rating piece in June; the Commission declined, and the question moved to state court.

"Wisconsin is the version other states should study. The commission did not rubber-stamp the utility's filing. It rewrote it, lowered the threshold, and made the very large customers pay the full cost of the plants built to serve them."
Dr. Mark McNees, Florida State University
Stakeholder map
Wisconsin PSC Rewrote and approved tariff We Energies (WEC) Filed, later moved to reopen Very large customers 100 MW+, 15-year minimum, pay 100% of their costs Microsoft, Vantage Named large loads Existing customers "Not a single cent" to subsidize Citizens Utility Board Backed credit protections rewrote filing full shield

The PSC did not simply approve the utility's filing. It removed a capacity-only option that would have left ordinary customers paying a quarter of new plant costs, and required full-cost recovery from the large loads.

How the money flows
1 BESPOKE GENERATION New plants built for the load $19.3B generation plan over 5 years 2 FULL-COST TARIFF VLC pays 100%, plus credit collateral Below A- credit rating means posted guarantees Data center pays Generation and fuel, full Existing customers Transmission risk remains transmission gap

Key facts

  • Order: The PSC unanimously approved a rewritten We Energies very large customer tariff on April 24, 2026, Docket 6630-TE-113, with the written order dated May 21, 2026. The structure requires We Energies to bill data center customers alone for new generation built to serve them.7
  • Threshold lowered: The Commission dropped the eligibility floor from 500 MW to 100 MW and extended the minimum term to 15 years.7
  • Full cost: The PSC removed the capacity-only option and required very large customers to pay the full cost of the generation serving them.7
  • The credit-rating guardrail: Developers rated below A- must post financial guarantees in cash or letters of credit, so that a developer's financial trouble does not shift cost to other customers. For the Oracle subsidiary co-developing the Port Washington campus, which carries a BBB rating, that requirement has been reported at more than $100 million a year.7
  • The utility asked, the Commission declined: We Energies petitioned the PSC on June 10, 2026 to reconsider the credit-rating rules and exempt investment-grade ratings including BBB, arguing default risk is very low and the requirement could deter investment in Wisconsin. The PSC declined to loosen the rules. Oracle sued the Commission in Ozaukee County Circuit Court, and the PSC is defending the requirement there.7
Where the gaps are

Transmission cost timing

Under federal law, utilities cannot bill data centers for transmission until they draw power. The PSC used a minimum billing demand charge as a stopgap, but existing customers can still front some upfront transmission cost during construction.

No statewide statute

This is a single-utility docket, not a law. Advocates note Wisconsin lacks statewide legislative guardrails, so the next utility's rate case starts the argument over again.

A credit rating is a snapshot, not a guarantee

The guardrail turns on a rating at the moment of interconnection, while the generation built to serve the load is recovered over decades. In January testimony to the PSC, Wisconsin Citizens Utility Board chief economist Steve Kihm noted that Enron held a BBB rating a year before its 2001 bankruptcy. That is the allocation question in one line: if the counterparty fails partway through the recovery period, the plant remains and someone pays for it.7

Sources: [7]. Back to top

Arizona

Rate case

Arizona is the live test of who pays. APS filed a rate case asking over 45 percent more from extra-large users like data centers in a new separate customer class, alongside about $20 a month more from households. The evidentiary hearing ran May 18 through June 30, 2026, opening to packed rooms and protest. A Commission vote is anticipated in December 2026, with new rates, if approved, taking effect in early 2027.

"Arizona is running the experiment in public. A 45-plus percent data center rate and a separate customer class in the same filing as a 20 dollar household increase. If the commission approves both, watch which one shows up on bills first."
Dr. Mark McNees, Florida State University
Stakeholder map
Corporation Commission Decides the rate case in 2026 APS $662M request, formula rates Data center class Proposed: roughly 45% higher rates Attorney General Intervened against the request Residential customers About $20 a month more proposed files rate case challenges approved costs flow

The commission decides three things at once: the revenue increase, the separate data center class, and a formula-rate mechanism that would let APS adjust rates annually without a full rate case. Consumer advocates oppose the formula rates as a risk shift to customers.

Key facts

  • The filing: APS's rate case, Docket E-01345A-25-0105, requests a base-rate revenue increase of $662.44 million, or 15.99 percent system-wide, with a net increase to customers of $579.52 million, or 13.99 percent, on a test year ending December 31, 2024. Average residential bills would rise about 14.6 percent. APS proposes over a 45 percent increase for extra-large energy users like data centers. The evidentiary hearing ran May 18 through June 30, 2026, with more than 30 intervenors.13
  • The formula rate: APS also proposes a Formula Rate Adjustment Mechanism allowing annual rate adjustments tied to load growth, without filing a full rate case each time demand rises. Supporters describe it as assigning growth costs to the classes driving them; opponents describe it as an automatic escalator.13
  • The opposition: Attorney General Kris Mayes intervened, arguing the increase could be cut to about 3 percent by reducing the return on equity, which her office calls a $524 million wealth transfer from ratepayers to shareholders. Her office filed testimony recommending a 6 percent return on equity; RUCO and Commission staff recommended closer to 9 percent. RUCO also urged a fully separate customer class for data centers and other large loads, and cautioned the Commission about broad non-disclosure agreements in data center proposals that reduce transparency.13
  • Commission posture: The Corporation Commission held a large-load workshop on April 16, 2026 and reported consensus that the cost causer pays, with existing tariffs and energy supply agreements as the current tools and a universal large-load tariff under discussion.14
  • The demand: APS expects peak load to grow up to 40 percent by 2031 with data centers the primary driver; it serves 400 to 500 MW of data center load today and plans about 4,000 MW over the next decade.13, 14
  • Second utility: Tucson Electric Power is seeking about $172 million more in retail revenue, roughly 13 percent overall, with typical residential bills up about 14 percent, or about $16 a month at median usage. TEP asked for rates effective September 1, 2026 and its hearing opened April 22, 2026. TEP is not proposing a data center tariff at this time, pending the outcome of its Energy Supply Agreement proceeding.15
Where the gaps are

Formula rates shift risk to customers

The same filing that separates data center costs also asks for annual formula-based adjustments in place of full rate cases. The state consumer office opposes it. If approved, cost review happens faster and with less scrutiny, in a state where demand forecasts are driven by loads that may not materialize.

No binding statute

Arizona has no SB 484 or SB 6. Protection runs utility by utility through tariffs and negotiated energy supply agreements. Shared infrastructure still blends into general rates, which is how a 45 percent data center rate and a $20 household increase arrive in the same filing.

Sources: [13] [14] [15]. Back to top

California

Study, tariff pending

California is the clearest case of the stranded-asset question. SB 57 is a study law, signed in 2025, that directs the CPUC to measure cost shifts and stranded-asset risk. Newer bills would turn that into an actual tariff.

"California is asking the harder question: what happens when a utility builds for demand that never shows up. If the projection is wrong, the stranded asset does not disappear. It goes on someone's bill. Measuring that risk is the first step to pricing it."
Dr. Mark McNees, Florida State University
Stakeholder map
CPUC Study due Jan 1, 2027 CA Legislature SB 57 (law), SB 886/887 PG&E, CAISO $2B+ upgrades for load Large-load customers Speculative interconnection requests inflate forecasts Residential ratepayers Exposed to stranded assets Public Advocates, TURN Push for binding safeguards speculative load study only stranded risk

California has named the problem but not yet built the binding mechanism. SB 57 measures the risk. SB 886 would create the tariff. The April 2026 CPUC rulemaking is where stranded-asset policy will actually be written.

How the money flows
1 SPECULATIVE DEMAND Developers file duplicate requests One site built, many applications submitted 2 CURRENT STATE: STUDY CPUC assesses cost shift, no tariff yet Stranded-asset accounting due Jan 2027 Utility builds ahead $2B+ CAISO upgrades for forecast load If load vanishes Ratepayers hold the asset unresolved

Key facts

  • Law: SB 57 (Padilla), chaptered October 11, 2025 (Chapter 647, Statutes of 2025). It authorizes the CPUC to assess data center cost shifts, including stranded-asset risk, with an assessment due on or before January 1, 2027.8
  • Pending, not enacted: SB 886 and SB 887 (Padilla) both passed the Senate on May 26, 2026, by 27-8 and 29-9, and moved to the Assembly. SB 886, the California Technology Innovation and Ratepayer Protection Act, would require the CPUC to establish a tariff covering transmission, distribution, and generation costs for new large transmission-level customers. As analyzed in committee it caps refunds of a customer's interconnection contributions at 75 percent of annual net revenue and requires an early termination fee for a customer that leaves within 15 years of interconnection or never reaches full load ramp-up. SB 887 pairs an accelerated environmental review with conditions including storage and full infrastructure cost responsibility. A coalition of technology, manufacturing, and business associations opposes SB 886.8
  • Rulemaking already underway: PG&E applied in November 2024 for a new electric rule for data centers. In July 2025 the CPUC issued an initial decision, D.25-07-039, approving an interim rule for data centers that pre-pay interconnection cost. In February 2026 the Commission set a schedule for the next phase, taking up transmission interconnection requirements and mechanisms for covering utility costs. Committee analysis of SB 886 notes the bill overlaps this proceeding.8
Where the gaps are

Study, not yet a rule

SB 57 measures the problem. It does not by itself assign the cost. Until the tariff bills pass or the CPUC rulemaking lands, the binding protection other states already have is not in place.

The stranded-asset question is the whole point

Speculative and duplicate interconnection requests inflate forecasts. If a utility builds against demand that never arrives, the cost of the idle asset falls on existing ratepayers. California is the state where this failure mode is most explicitly on the table.

Sources: [8]. Back to top

North Carolina

Merger review

North Carolina enters this map through the Dominion side of the proposed NextEra merger. The North Carolina Utilities Commission is one of three state regulators that must approve the deal, and it has recent experience conditioning a merger on customer savings. Applications were filed July 15, 2026, starting the review.

"A merger review is a rare moment of leverage. Two questions decide whether it gets used: who pays when this company builds for data centers, and who is protected if that demand moves."
Dr. Mark McNees, Florida State University
Stakeholder map
NextEra + Dominion $67B proposed merger NC Utilities Commission Must approve the deal FERC, NRC, others Federal approval track NextEra generation arm Merchant + rate-based mix under one parent NC retail customers Share of $2.25B bill credits files for approval serves

The North Carolina question is not a data center tariff yet. It is whether the merger review conditions the deal to protect customers, as the NCUC did in the recent Duke subsidiary merger.

Key facts

  • Merger: NextEra announced an all-stock combination with Dominion on May 18, 2026, valued at roughly $67 billion. The combined company would be more than 80 percent regulated across four states, with about 110 GW of generation and roughly 10 million customer accounts in Florida, Virginia, North Carolina, and South Carolina.9
  • Regulatory review began July 15: NextEra filed its Form S-4 registration statement with the SEC on July 9, 2026. State and federal review began July 15, 2026, when the companies filed applications with the Virginia SCC, the North Carolina Utilities Commission, the Public Service Commission of South Carolina, FERC, and the NRC.9
  • NC role: The North Carolina Utilities Commission is one of three state regulators that must approve the deal, alongside FERC and the NRC.9
  • Bill credits: The companies propose approximately $2.25 billion in shareholder-funded bill credits for Dominion customers in Virginia, North Carolina, and South Carolina, allocated over the first two years after closing. Virginia is allocated roughly $1.78 billion, about 79 percent. The companies also committed that merger transaction, financing, and restructuring costs would not be passed to customers. These are proposed commitments in a pending review, not approved terms.9
  • Status: Pending, not closed. The companies expect to close in the second half of 2027. Senator Angus King of Maine filed comments urging FERC to reject the deal, arguing it would concentrate merchant generation, rate-based generation, and transmission in one company, and citing NextEra's 2021 campaign against the New England Clean Energy Connect transmission project as evidence of harm to ratepayers.9
Where the gaps are

Data center cost allocation is not the review's main event

The merger docket centers on market power and customer savings. The specific question of how future data center load is priced can slip past a merger proceeding unless intervenors raise it directly.

One parent, generation and utility together

A combined company that owns both regulated utilities and merchant generation concentrates the affiliate transfer-price question. A U.S. senator has already urged FERC to reject the deal on market-power grounds.

Sources: [9]. Back to top

South Carolina

Merger review

South Carolina is the third merger-review state, and the announced operational headquarters of the combined company. The Public Service Commission of South Carolina must approve the deal. NextEra has pursued utility combinations in Texas, Hawaii, and South Carolina before, and none closed.

"South Carolina has not written a data center rule yet, and a merger review is one of the few moments a commission can set terms it would otherwise negotiate later. Every state circling this question lands in the same place: whether the load creator pays for the load."
Dr. Mark McNees, Florida State University
Stakeholder map
NextEra + Dominion Operational HQ in Cayce, SC PSC of South Carolina Must approve the deal NextEra track record Prior SC bid rejected Combined generation 110 GW, more than 80% regulated SC retail customers Share of $2.25B bill credits files for approval history matters serves

South Carolina holds real leverage. The PSC can approve, condition, or reject. NextEra has failed prior acquisition attempts in South Carolina, Texas, and Hawaii when regulators were skeptical.

Key facts

  • Merger role: The Public Service Commission of South Carolina is one of three state approvers, with applications filed July 15, 2026. The combined company would place its operational headquarters in Cayce, South Carolina, alongside dual corporate headquarters in Richmond, Virginia and Juno Beach, Florida.9
  • Scale: The merged utility would be more than 80% regulated across Florida, Virginia, North Carolina, and South Carolina.9
  • Bill credits: South Carolina customers are included in the proposed $2.25 billion in shareholder-funded bill credits across the three states, spread over the first two years after closing. Virginia is allocated about 79 percent of the total, so the South Carolina share is a minority of it. The companies also propose an additional $10 million a year in shareholder-funded charitable giving across the three states for five years after closing.9
  • Context: NextEra has previously pursued utility combinations in Texas, Hawaii, and South Carolina, none of which was completed. Dominion's leadership has said current management, not prior conduct, will govern how the combined company handles public policy and government affairs.9
Where the gaps are

No dedicated large-load tariff yet

South Carolina has not enacted a Florida-style statute or a Wisconsin-style tariff. Its current lever over data center cost allocation runs through the merger review and future rate cases, not a standing rule.

Concentration risk

The same combined parent would own generation and regulated utilities across the region. Whether the affiliate transfer price gets scrutiny depends on the conditions the PSC attaches at approval.

Sources: [9]. Back to top

Oregon

Rates in effect

Oregon is the first state to move from framework to dollars on the bill. Under the POWER Act, the Public Utility Commission created Schedule 96, a dedicated rate class for large loads. On July 7, 2026 the Commission approved Portland General Electric's implementing rates: about a 29 percent average increase for data center and other large-load customers, with residential rates falling slightly. The changes take effect July 8, 2026.

"Oregon is the first state where cost causation shows up as an actual number on the bill. Large load up about 29 percent, residential down. That is the whole principle made concrete: the users who trigger the buildout carry its cost, and the household three counties away does not."
Dr. Mark McNees, Florida State University
Stakeholder map
Oregon PUC Schedule 96, POWER Act Portland General Electric Files implementing rates Large load customer Data centers. About 29% increase Residential ratepayers Rates fall 1.3% sets rate class bills shields

The Commission sets the Schedule 96 rate class, PGE files the implementing rates, the large load carries the increase, and residential customers are shielded from the buildout cost.

Key facts

  • Framework: Schedule 96, a dedicated large-load rate class required under Oregon's POWER Act (House Bill 3546, 2025).17
  • Approval: The Oregon PUC approved PGE's implementing rates on July 7, 2026, effective July 8, 2026, across roughly 963,000 customers.17
  • Cost split: About a 29 percent average increase for large-load customers; residential rates down about 1.3 percent, commercial down about 2.1 percent, industrial down about 1.4 percent.17
Where the gaps are

Durability of the load

The rate class assigns cost at the point of service. The open question, here as elsewhere, is whether the projected large-load demand is durable enough to justify the capacity built against it, or whether a shrinking load leaves stranded costs behind.

Sources: [17]. Back to top

Georgia

Investigation open

Georgia is testing the same question through a docket rather than a statute. At its administrative session of July 7, 2026 the Public Service Commission took up Staff's proposed procedural and scheduling order in Docket No. 57171, Georgia Power's real time pricing revenue credit and allocation methodology. The same session's administrative affairs agenda carried a request to retain an outside consultant to assist Staff with that methodology review. The Commission has calendared the docket for hearing on September 1, 2026.

"This is not advocacy. It is the regulator that has to decide who pays, deciding the question is worth examining."
Dr. Mark McNees, Florida State University
Stakeholder map
Georgia PSC Cost-shift investigation Georgia Power Rate structure under review Large industrial load Data centers. Cost share in question Residential ratepayers Bill impact under review investigates bills possible cost shift

The Commission is reviewing the methodology by which Georgia Power allocates cost and credits revenue under its real time pricing tariff. The dashed red line is the allocation the docket is built to examine.

Key facts

  • Docket: No. 57171, Georgia Power's real time pricing revenue credit and allocation methodology.18
  • Action: At its administrative session of July 7, 2026 the Commission took up Staff's proposed procedural and scheduling order in the docket. That is a schedule for the review, not a decision on the merits.18
  • Outside review: The same session's administrative affairs agenda sought approval to contract a consultant to assist Staff with the methodology review, at a not-to-exceed amount of $80,250, paid under the May 12, 2026 stipulation in Docket No. 56765 and therefore at no direct cost to the state.18
  • Next step: The Commission has calendared Docket No. 57171 for hearing on September 1, 2026.18
Where the gaps are

Investigation is not yet a remedy

A methodology review examines how cost is allocated. It does not, by itself, reallocate it. Whether the review produces a binding change to the tariff is the open question, and the reason the September 1 hearing is the date to watch.

Sources: [18]. Back to top

Ohio

Tariff in place, bills pending

Ohio has a rate mechanism already running and two bills pushing further. The Public Utilities Commission approved a data center tariff for AEP Ohio that prices large new load separately. A Senate rewrite of House Bill 646 would have gone further, creating a statewide data center rate class and requiring every electric distribution utility to file a data center tariff, and it stalled in June 2026. On July 28, 2026 two House Republicans introduced House Bill 983, which moves the question from rate design to consent, requiring a local vote before a project is built.

"Ohio is the clearest case that this is not a partisan question. The tariff prices the load. The bill in front of the House now asks a different one: whether the community that absorbs the cost gets a say before the cost arrives. Both are cost allocation. One is priced and one is voted."
Dr. Mark McNees, Florida State University
Stakeholder map
PUCO Approved AEP Ohio data center tariff Ohio General Assembly HB 646 stalled, HB 983 introduced AEP Ohio Data center tariff on file Large load Data centers. Priced separately Residential ratepayers Exposure the bills are arguing over approves bills residual cost exposure

Ohio runs a tariff and debates a statute at the same time. The dashed red line is what the tariff prices and what the pending bills are arguing over.

Key facts

  • Bill introduced: HB 983, the Data Center Accountability and Citizen Protection Act, introduced July 28, 2026 by Reps. Jennifer Gross and Michelle Teska in the 136th General Assembly. Amends R.C. 9.66 and enacts R.C. 3744.01 through 3744.12. Declares an emergency.33
  • Consent mechanism: Voter approval in every municipality and township within five miles before construction or expansion of a data center with peak electric load over one megawatt. A permit issued without that approval is void.34
  • Environmental standards: Directs the Ohio EPA to set data center specific wastewater discharge and air emission standards, with ongoing independent testing and public disclosure of results. Discharge standards covering PFAS, glycols, and metals reach existing facilities after eighteen months.3334
  • Water cost responsibility: Owners held financially responsible for water supply and water pressure impacts associated with their facilities.34
Where the gaps are

A vote is not a rate

Requiring local approval decides whether a project happens. It does not decide who pays for the transmission and generation the project triggers once it is approved. Consent and cost allocation are different instruments, and Ohio is currently running one of each.

The bill is introduced, not enacted

HB 983 is at introduction with no committee action recorded as of August 6, 2026, and the earlier rate-class package in HB 646 stalled. Ohio belongs on this tracker for the tariff already in force, not for the bills. Confirm current bill status before citing.

Sources: [33], [34]. Back to top

Oklahoma

Law

Oklahoma answered the question with a statute rather than a docket. House Bill 2992, the Data Center Customer Ratepayer Protection Act of 2026, was signed by Governor Kevin Stitt in May 2026 and took effect July 1, 2026. It is codified at 17 O.S. sections 900 through 906. Two things make it unusual on this page. It reaches every electric supplier in the state under Corporation Commission jurisdiction, cooperatives included, rather than investor-owned utilities alone. And it adds a land notice requirement that fires before a purchase closes, which puts neighbors and county commissioners on notice at the siting stage rather than at the rate stage.

"Oklahoma did two things in one bill. It priced the load, and it told the neighbors before the land changed hands. Most states are still arguing about the first. The second is the part nobody else has written down, and it is the one that decides whether a community finds out early or reads about it later."
Dr. Mark McNees, Florida State University
Stakeholder map
Oklahoma Legislature HB 2992, effective July 1, 2026 Corporation Commission Approves tariffs, receives land notice All electric suppliers Cooperatives included Large load customer 75 MW or more of new demand Residential ratepayers Shielded by cost causation directs separate tariff serves cost stays with the load

Oklahoma is one of the few entries where the line from large load to households is solid rather than dashed. The statute assigns the cost by cost causation, so the residual exposure other states are still arguing over is addressed in the text itself.

Key facts

  • Statute: House Bill 2992, the Data Center Customer Ratepayer Protection Act of 2026, referred to in press coverage as the Consumer Ratepayer Protection Act. Signed by Governor Kevin Stitt in May 2026, effective July 1, 2026, codified at 17 O.S. sections 900 through 906.4041
  • Who it covers: All Oklahoma electric suppliers subject to Corporation Commission jurisdiction, including cooperatives. That is a broader reach than the investor-owned-utility scope common elsewhere on this page.40
  • Large load customer defined: New facilities adding 75 megawatts or more of demand, naming data centers, cryptocurrency mining operations, and artificial intelligence facilities.4041
  • What suppliers must file: Separate tariffs with their own terms and conditions, credit protections, cost allocation on cost causation principles, and a minimum ten-year service commitment from the customer.4041
  • Land notice, sixty days before purchase: Notice to the Corporation Commission, the county commissioners, and every property owner within five miles, filed sixty days before a land purchase for a covered facility.4041
Where the gaps are

The tariffs are still to be written

The statute is in effect, but it directs suppliers to file separate tariffs rather than setting the rate itself. What a 75 MW customer actually pays in Oklahoma is decided in the tariff filings that follow, not in HB 2992. Confirm the status of those filings at the Corporation Commission before citing a price.

Notice is not consent

The five-mile land notice tells neighbors and county commissioners that a project is coming. It does not give them a vote, and it does not by itself change who pays for the transmission the project triggers. Compare Ohio's pending HB 983, which reaches for consent rather than notice.

Sources: [40], [41]. Back to top

New York

Moratorium plus allocation

New York sits next to the fourteen states above, not among them. It has not enacted a large-load tariff or cost-allocation rule yet. What it has is a pause bolted onto a pending reform. On July 14, 2026 Governor Kathy Hochul signed Executive Order No. 62, the first statewide data center moratorium in the country. It pauses state environmental permits for up to one year for hyperscale facilities at 50 megawatts or more while the reform proceeding runs.

Key facts

  • The moratorium: Executive Order No. 62, signed July 14, 2026, pauses state environmental permits for up to one year for hyperscale data centers at 50 MW or more. It is the first statewide data center moratorium in the country.21
  • The allocation reform underneath: The order runs alongside the Department of Public Service Energize NY proceeding, which requires data centers to pay more for energy or supply their own power. The order states it is New York policy that the cost of electric system upgrades to serve large loads should not be paid for by everyday New Yorkers.21
  • Stranded-asset risk: The order cites the risk of infrastructure investment made in anticipation of loads that may not fully materialize.21
  • The order replaced a stricter bill: The Legislature had already passed the Responsible Data Center Development Act, S10642 and A11560, on June 4, 2026, clearing the Senate 44 to 16 and the Assembly 102 to 39. It set the threshold at 20 MW. The Governor issued Executive Order No. 62 at 50 MW instead of acting on the bill, and said the higher threshold was chosen so facilities serving hospitals, schools, and bank operations would not be captured.35
The national moratorium picture

A moratorium and an allocation rule answer different questions. A pause decides whether a project is built. An allocation rule decides who pays for the grid capacity it triggers once it is. New York is the only state to have enacted a statewide pause, and the pattern below is why the question keeps moving to city and county government.

Where pauses stand

  • Statewide, in effect: New York only, by executive order at 50 MW. No state has enacted a statewide moratorium by statute.21
  • Statewide, failed or pending: Moratorium bills were introduced in at least eleven states during the 2026 sessions and met resistance in nearly all of them. Vermont's S.205 would pause facilities above 10 MW and Oklahoma's SB 1488 would pause new construction, both still pending. Pennsylvania's SB 1359 was offered as an amendment and rejected in committee. Maine's LD 307 passed both chambers and was vetoed; confirm the override outcome before citing it.36
  • Local, where the volume is: Cato counted 116 municipalities with local moratoriums in place as of the end of June 2026. Michigan Public put at least 52 of those in Michigan alone, most running six months to a year.3738
  • Federal: S. 4214, the AI Data Center Moratorium Act, was introduced March 25, 2026 with a House companion. It would pause construction above 20 MW pending federal AI legislation. Introduced only.36
Where the gaps are

A pause is not an allocation rule

The moratorium buys time. It does not, by itself, decide who pays for the grid upgrades a data center triggers. That question sits in the Energize NY proceeding. Until that proceeding sets a rule, the moratorium is a hold, not a remedy, which is why New York belongs next to the fourteen states rather than among them.

A local pause cannot reach the rate

A city or county moratorium controls whether a project is approved inside its own borders. It has no authority over the transmission and generation cost the project would trigger, because that cost is allocated in a state commission rate proceeding the municipality is not a party to. The 116 local pauses Cato counted through June are a measure of how many communities reached for the only instrument they actually hold.

Sources: [21], [35], [36], [37], [38]. Back to top

The gap every state shares

Read across all fourteen states and one gap repeats. The tariffs and rate classes audit what the data center pays the utility. They do not audit what a regulated utility pays a generator owned by the same parent company.

The four price layers
1. Wholesale market (PJM, energy) Market-based, capacity cap approved by FERC 4. Retail rate (customer invoice) State PSC regulates. The tariffs audit this The transfer price Regulated utility pays its own affiliated generator FERC governs the market Layer 1 State PSC audits the bill Layer 4 the seam between state and federal review

FERC governs the wholesale market and maintains its own affiliate-transaction rules. The state commission audits the customer invoice. The open question is whether the state cost-of-service review under these new tariffs reaches the transfer price a regulated utility pays a generator owned by the same parent. The pending NextEra combination makes the question concrete: one parent could own both sides of that transaction across four states. This is the seam worth watching, not a settled claim that no one reviews the price.

Sources: [5] [9]. The affiliate transfer price question in this section is analysis, not a sourced finding. Back to top

Sources and citations

Every numbered source below was retrieved and read directly on July 3 and 4, 2026, with sources 19 through 21 retrieved and read July 16, 2026. New Jersey sources 23 and 24 were added and verified July 22, 2026. Sources marked primary are the enacting body itself: the statute record, the commission order or release, or the company filing. Two sources are marked official secondary where the cited item is a regulator's own news release or summary rather than the order it describes, and the full text should be read before quoting exact figures. Claims that could not be traced to a primary source on that date are not stated as fact on this page; they are marked in the panels as needing confirmation. Reference 18 was re-read against the raw bytes of the July 7, 2026 agendas on August 12, 2026 and two quoted strings were restored to the source. Quotation marks in these references are a fidelity claim and are used only where the string has been checked against its own source. Three titles are shown without quotation marks because their sources could not be reached to check them: New York's executive order, which answers 403 behind a bot check, the DLA Piper note, which answers 429 behind a security checkpoint, and the Cato post, which answers with an empty page. The wording is unchanged and the links are unchanged.
How to read the references. Each reference carries a label. Primary means the document itself: a statute, a commission order, a docket filing, an agency notice. Secondary means reporting about that document. Official secondary sits between them: a regulator's own news release or summary rather than the order it describes. Where both exist, the primary source governs and the secondary is listed for context. Where a reference is primary, the dates in it are the dates on the document, not the dates of the coverage. A few entries still rest on reporting alone. Those are labelled secondary, and a date in one of them is the date that report gives, which is the reason the label is there.
  1. The Florida Senate, Regulated Industries Committee. CS/CS/SB 484 Bill Summary (2026). States the October 1, 2026 utility tariff filing requirement, the July 1, 2026 effective date, the cost-of-service and nonpayment provisions, and the final votes. flsenate.gov/Committees/BillSummaries/2026/html/484Primary
  2. The Florida Senate. Senate Bill 484 (2026), Chapter No. 2026-65. Effective 7/1/2026 except as otherwise provided. Signed into law May 7, 2026; 5/8/2026 is the chapter-posting date, not the signing date. flsenate.gov/Session/Bill/2026/484Primary
  3. Citizens for Pennsylvania's Future (PennFuture). Data Center 2026 Legislative Debrief. Identifies HB 1834 (the Data Center Act, Rep. Matzie), HB 2150, HB 2151, and SB 939 as Pennsylvania's data center bills. pennfuture.org/post/DATA-CENTER-2026-LEGISLATION-DEBRIEFPrimary
  4. Pennsylvania Public Utility Commission. Press release, April 30, 2026: PUC adopts a model large-load tariff framework; interconnection upgrade costs recovered directly from large-load customers. puc.pa.govPrimary
  5. PJM Interconnection (PJM Inside Lines). 2027/2028 Base Residual Auction results, December 17, 2025. Cleared at the FERC-approved cap of $333.44/MW-day; first auction in which the entire RTO fell short of the reliability requirement; nearly 5,100 MW of the 5,250 MW load-forecast increase attributable to data center demand. insidelines.pjm.comPrimary
  6. Virginia State Corporation Commission. News release on the final order in the Dominion Energy Virginia 2025 biennial review, November 2025. New large-load rate class with minimum demand charges of 85% (distribution and transmission) and 60% (generation). scc.virginia.govOfficial secondary
  7. Public Service Commission of Wisconsin. Press release, April 24, 2026, Docket 6630-TE-113. Approved a rewritten We Energies very large customer tariff; lowered the eligibility threshold from 500 MW to 100 MW; extended the minimum term to 15 years; removed the capacity-only option in favor of full-cost recovery. psc.wi.govPrimary
  8. California Senate Bill 57 (Padilla), 2025-2026 session. Chaptered October 11, 2025 (Chapter 647, Statutes of 2025). Authorizes the CPUC to assess data center cost shifts, including stranded-asset risk; assessment due on or before January 1, 2027. calmatters.digitaldemocracy.orgPrimary
  9. NextEra Energy. Investor announcement of the NextEra-Dominion combination, May 18, 2026. All-stock transaction; combined company more than 80% regulated across four states; requires FERC, NRC, and the Virginia SCC, North Carolina Utilities Commission, and Public Service Commission of South Carolina approval. Deal terms are announcement-stage and the transaction is pending. newsroom.nexteraenergy.comPrimary
  10. Bracewell LLP. "Texas Senate Bill 6 Ushers in Major Overhaul of Large Load Interconnection and Grid Access Rules." Signed June 20, 2025, effective immediately; 75 MW default threshold; study fees, financial commitments, remote-curtailment requirement for loads interconnecting after December 31, 2025; ERCOT and PUCT review of co-location arrangements. bracewell.comSecondary, law firm analysis
  11. Greenberg Traurig LLP. "Texas Senate Bill 6 Update: What Data Centers and Large Load Customers Should Know About Proposed Interconnection Standards." PUCT draft rule 16 TAC 25.194 published March 12, 2026: $50,000 per MW non-refundable interconnection fee, 100 percent contribution in aid of construction, security for upgrades, 80/20 split of drawn security on withdrawal. Project No. 58481. Comments closed April 17, 2026; final adoption anticipated mid-2026. Status as of last verification: proposed, not adopted. gtlaw.comSecondary, law firm analysis
  12. Public Utility Commission of Texas. SB 6 implementation presentation, October 17, 2025 (hosted by NASEO). ERCOT tracking more than three times as many large-load interconnections as 2024; nearly 69 percent of 189 GW of large-load requests are data centers. naseo.org, PUCT deckOfficial
  13. Arizona Capitol Times. "APS rate case kicks off with hours of protest over 14% rate increase," May 19, 2026. Docket E-01345A-25-0105; roughly $662 million request; separate extra-large customer class with rates about 45 percent higher for data centers; about $20 per month for households; formula-rate proposal opposed by the Residential Utility Consumer Office; Attorney General intervention. azcapitoltimes.comSecondary, news
  14. Arizona Corporation Commission. "ACC Data Center/Large Load Workshop Highlights," April 20, 2026. April 16 workshop; consensus that the cost causer bears its share; existing tariffs and energy supply agreements as current tools; universal large-load tariff under discussion. azcc.govPrimary
  15. Arizona Agenda. "A new formula for the power players," December 2025. Tucson Electric Power 14 percent request, about $172 million annually, targeted for September 2026; no data center tariff at this time pending its energy supply agreement. arizonaagenda.comSecondary, news
  16. Henrico County electricity rate increase and conservation request, June 2026. VEPGA statewide scope and school budget impact. PJM regional wholesale power costs up 62.7 percent in the first five months of 2026 against the same period in 2025, per PJM's independent market monitor. henricocitizen.com; 404media.co; inc.comSecondary, news
  17. Oregon Public Utility Commission, Docket UM 2377. The order: Order No. 26-154, entered May 7, 2026, creates Schedule 96, the dedicated large-load rate class required under Oregon's POWER Act (House Bill 3546, 2025). The order records that its First Partial Stipulation, dated February 4, 2026, is between Portland General Electric Company, Staff of the Public Utility Commission of Oregon, the Alliance of Western Energy Consumers, Amazon Data Services, Inc., Climate Solutions and others together described in the order as the Coalition, the Data Center Coalition, and the Oregon Citizens' Utility Board. The rates: PUC media release PR-202615, July 7, 2026, is the source for the figures on this page: an average 29 percent increase for PGE data center customers, average decreases of 1.3 percent residential, 2.1 percent commercial and 1.4 percent other industrial, about 963,000 customers affected, and rates starting July 8. PGE filed to comply on June 3 with supplemental filings June 30 and July 2. Order No. 26-154; PUC media release PR-202615Primary order + official secondary release
  18. Georgia Public Service Commission, administrative session of July 7, 2026. The amended Utilities Division agenda lists, on the proposed regular agenda, "DOCKET NO. 57171: Real Time Pricing (“RTP”) Revenue Credit and Allocation Methodology: Consideration of Staff's Proposed Procedural and Scheduling Order." The same session's administrative affairs agenda, consent agenda item 2, requests approval "to contract consultant to assist Staff with the RTP Credit Methodology Investigation in Docket No. 57171", at a "not-to-exceed contract amount of $80,250" to "be paid pursuant to the May 12, 2026, Stipulation in Docket No. 56765, therefore leaving no direct cost to the state." The Commission's own use of the word Investigation in that item is the basis for the status shown for Georgia on this page. The Commission calendar lists "Docket No. 57171 RTP Revenue Credit and Allocation Methodology Hearing" for September 1, 2026. amended session agenda; administrative affairs agenda; commission calendarPrimary
  19. Virginia SCC Rider T-1 transmission cost case, Case No. PUR-2026-00056. At the July 14 to 15, 2026 hearing, commission staff testified that a cross-subsidy benefiting new large-load customers remains regardless of the allocation method chosen, and the governor's office argued data centers should pay for transmission that would not be built but for them. Dominion filed the application on May 1, 2026. The Final Order of July 31, 2026 does not itself direct direct assignment. It directs Dominion to file, within 90 days and in a separate new docket, proposed amendments to its line extension policy requiring a mandatory contribution in aid of construction, applying prospectively and only to direct connect transmission facilities, and it expressly found the record supports a more deliberate approach on higher-order transmission cost, deferring that question. Amended line extension policy due October 29, 2026; cross-utility status update due November 28, 2026; Rider T-1 effective September 1, 2026. SCC Case No. PUR-2026-00056, Final Order, July 31, 2026, document 260750228. Final Order (scc.virginia.gov); docket search; utilitydive.com; virginiamercury.comPrimary docket + secondary news
  20. Data Center Dynamics. "Virginia regulators approve new rate class for data centers and other large loads." The November 2025 SCC order established the large-load rate class with an 85 percent minimum demand charge for transmission and distribution and 60 percent for generation, plus exit fees for large loads that leave before their contract term ends. datacenterdynamics.comSecondary, news
  21. New York State. Executive Order No. 62, Establishing a Temporary Moratorium on Data Centers in New York While the State Develops Higher Standards for Data Center Development and Benefits Blueprint to Support Localities, signed July 14, 2026, with the Governor's press release. Pauses state environmental permits for up to one year for hyperscale data centers at 50 MW or more; runs alongside the Department of Public Service Energize NY proceeding requiring data centers to pay more for energy or supply their own power; states that the cost of system upgrades to serve large loads should not be paid for by everyday New Yorkers; cites stranded-asset risk. governor.ny.gov, EO text; governor.ny.gov, press releasePrimary
  22. Order No. PSC-2026-0022-S-EI, Docket No. 20250011-EI, Florida Public Service Commission, issued January 22, 2026. floridapsc.comPrimary
  23. State of New Jersey, Office of the Governor. Press release on the signing of the Data Center Fair Share Act, July 7, 2026. Creates a separate ratepayer class and rate structure for data centers; requires large-load data center customers to commit to taking at least 85 percent of requested service for a minimum of 10 years; requires upfront deposits or financial security covering new transmission costs. nj.gov/governorPrimary
  24. New Jersey Legislature. Senate Bill S731 (companion A796), the Data Center Fair Share Act, full bill text via LegiScan. legiscan.com/NJ/text/S731Primary
  25. Utility Dive. "Texas, facing 438 GW queue, approves initial large-load interconnection process." June 22, 2026. ERCOT large-load interconnection queue reported at more than 438 GW, with ERCOT stating the queue is almost 90 percent data centers; PUCT approval of ERCOT's Batch Zero grouped-study process for loads of 75 MW or greater. utilitydive.comSecondary, trade press
  26. Utility Dive. "ERCOT's large load queue jumped almost 300% last year." January 2026. More than 233 GW of large-load interconnection requests, more than 70 percent from data centers, reported by ERCOT Vice President of System Planning and Weatherization Kristi Hobbs at the December 9, 2025 ERCOT board of directors meeting; total capacity up almost 300 percent over the 2024 year-end total. utilitydive.comSecondary, trade press
  27. Florida Public Service Commission, Docket No. 20260064-EI, Document No. 02327-2026. Duke Energy Florida, LLC, petition for a limited proceeding to approve large load tariff, filed April 22, 2026. Paragraph 11 lists the changes made to comply with SB 484: applicability lowered from 100 MW to 50 MW; LLC-1 withdrawn from consideration with intent to propose a new large load rate schedule in the next rate case; CIAC flexibility removed so all customers pay upfront subject to five-year refund; minimum term raised from 15 to 20 years with a two-year notice requirement. Section 13.08 of the proposed Large Load Customer Policy provides that large load customers take service under existing GSD-1 or GSDT-1 rates until a new large load rate schedule is presented and approved. Hearing scheduled August 25 and 26, 2026. floridapsc.com, Docket 20260064Primary
  28. Office of the Texas Governor. "Governor Abbott Directs PUC And ERCOT To Shield Texans From Data Center Infrastructure Costs." June 10, 2026. Directive requiring the PUC and ERCOT to submit a joint memorandum to the Governor's office by July 17, 2026, and directing the PUC to initiate action to reduce residential ratepayers' transmission costs by July 31, 2026. gov.texas.govPrimary
  29. Office of the Texas Governor. "Governor Abbott Announces PUC And ERCOT Actions Protecting Residential Ratepayers From Data Center Costs." July 2026. PUC and ERCOT response requiring data centers to pay for transmission infrastructure built to serve them and to contribute toward reducing residential electric bills, rules preventing large data centers from diverting existing power away from the ERCOT grid, a mandate that new data centers reduce load promptly on ERCOT instruction, and a rulemaking requiring large loads to post financial security for interconnection, apply forfeited security to offset transmission rates, and begin paying transmission charges once capacity is available. gov.texas.govPrimary
  30. K&L Gates LLP. "Request for Comments on Texas PUCT Draft Report Regarding Transmission Cost Recovery in the ERCOT Region." March 30, 2026. Supports the December 31, 2026 completion date for PUCT Project No. 58484, the transmission cost recovery evaluation in the ERCOT region. klgates.comSecondary, law firm analysis
  31. Texas Legislature Online. Fiscal note, Senate Bill 6, 89th Legislature, Regular Session. Records that SB 6 adds PURA section 37.0561 and amends PURA section 35.004. capitol.texas.gov, SB 6 fiscal notePrimary
  32. Office of the Texas Governor. "Governor Abbott Directs Comprehensive Data Center Audit." August 3, 2026. Directive requiring the PUCT and ERCOT to verify and audit every data center advancing through ERCOT's interconnection process and to complete the audit before any project moves forward, with noncompliant projects denied grid connection. Requires disclosure of reliance on public financial assistance including tax incentives, grants, and abatements; self-generation versus ERCOT grid reliance, with projected annual and peak demand; water use and cooling method; and steps to reduce community impacts. ERCOT stated it would implement the directive, including postponing the Batch Zero transmission planning study. Puts the ERCOT large-load queue at more than 474 GW, over five times the state's record peak demand. gov.texas.govPrimary
  33. Ohio House of Representatives. "Representatives Jennifer Gross and Michelle Teska Introduce Data Center Accountability and Citizen Protection Act." July 2026. Announces HB 983, the Data Center Accountability and Citizen Protection Act, introduced by Reps. Jennifer Gross (R-West Chester) and Michelle Teska (R-Clearcreek Township); directs the Ohio EPA to establish data center specific safety standards for wastewater discharges and air emissions and requires ongoing independent environmental testing with public disclosure of the results. ohiohouse.gov. Bill record: introduced July 28, 2026 in the 136th General Assembly; long title amends section 9.66 and enacts sections 3744.01 through 3744.12 of the Revised Code and declares an emergency. legislature.ohio.gov, HB 983Primary
  34. Rob Moore. "Ohio General Assembly members propose sweeping bill to regulate data center development." Ohio Capital Journal, August 6, 2026. Reports that HB 983 would require voter approval for every new construction or expansion of a data center with peak electric load over one megawatt, in every municipality and township within five miles of the project, and that permits issued without voter approval would be considered void. Reports new air emission and water discharge standards covering PFAS, glycols, metals, and other organic compounds, applying to existing data centers after eighteen months, and that owners would be held financially responsible for water supply and water pressure impacts associated with their centers. ohiocapitaljournal.comSecondary, commentary
  35. DLA Piper. New York State Legislature passes first-in-the-nation data center moratorium: Top points. July 2026. Reports that S10642/A11560 imposes a one-year moratorium on state permits for large data centers at 20 MW or more and cleared the Senate 44 to 16 and the Assembly 102 to 39 on June 4, 2026. dlapiper.com. Governor's stated reason for the 50 MW threshold in Executive Order No. 62 reported by WTEN/News10 Albany, July 2026. news10.comSecondary, legal and news
  36. MultiState. "State Data Center Policy 101: 2026 Legislative Guide." Reports that state-level moratorium bills were introduced in eleven states in 2026 and faced resistance, while local construction pauses moved ahead, shifting the center of gravity to local government. multistate.us. Individual bill status for Vermont S.205, Oklahoma SB 1488, Maine LD 307, and the federal S. 4214 is compiled at ailawsbystate.com; confirm each bill against its own legislative record before citing. Stateline, "Temporarily banning data centers draws more interest from state, local officials," March 6, 2026, by Madyson Fitzgerald, reports at least eleven states citing a Good Jobs First count, and names Georgia, Maryland, Michigan, New Hampshire, New York, Oklahoma, South Carolina, South Dakota, Vermont, Virginia, and Wisconsin. stateline.org. That list does not include Maine or Pennsylvania, both of which are cited in the panel above, and it treats Pennsylvania and Minnesota as announced rather than introduced as of early March. The Stateline count is a March snapshot and the MultiState figure covers the session, so the two are not independent confirmation of each other. Use the phrase at least eleven and confirm any individual state against its own legislative record. Secondary, confirm bill status before citing
  37. Cato Institute. Turning a Local Issue into a Federal Headache: The Problem with Data Center Moratoriums. July 1, 2026. States that 116 municipalities had imposed local moratoriums as of the end of June 2026. cato.orgSecondary, policy research
  38. Michigan Public Radio. "Michigan communities are putting moratoriums on data centers. The clock is ticking." June 29, 2026. Reports at least 52 Michigan communities have enacted data center moratoriums, most initially set for six months to a year. michiganpublic.orgSecondary, news
  39. Electric Reliability Council of Texas. Market Notice M-A080326-01, August 3, 2026. States that, based on the directive in the Governor's letter, ERCOT will not notify each interconnecting distribution service provider and transmission service provider of how any large load is classified in the Batch Zero Interconnection Study by August 7, 2026, and that ERCOT will file a request for a good cause exception related to the timelines and process for Batch Zero set out in ERCOT Planning Guide Sections 5 and 9, in advance of the Public Utility Commission of Texas open meeting on August 20, 2026. Retrieve from the ERCOT market notice archive: ercot.com, market notice archives. Notice text as quoted in Sonal Patel, "Texas Audit Could Delay 49.8 GW of Data Center Load," POWER, August 2026, powermag.com, and in Troutman Pepper Locke, "Texas Hits Pause on Data Center Grid Connections Amid Growing Oversight Push," August 2026, troutman.comPrimary notice, quoted in secondary sources; link the notice directly once retrieved
  40. Oklahoma Corporation Commission, Public Utility Division. "Data Center Customer Ratepayer Protection Act." Commission page describing House Bill 2992, effective July 1, 2026, codified at 17 O.S. sections 900 through 906. Sets the 75 megawatt large load customer threshold covering data centers, cryptocurrency mining, and artificial intelligence facilities; applies to all electric suppliers under Commission jurisdiction, including cooperatives; requires separate tariffs with terms and conditions, credit protections, cost allocation on cost causation principles, and a minimum ten-year service commitment; requires notice to the Commission, county commissioners, and property owners within five miles sixty days before a land purchase. oklahoma.gov, Corporation CommissionPrimary, regulator
  41. Oklahoma Legislature. House Bill 2992, 60th Legislature, 2026 regular session. Enrolled bill text and legislative history, including signature by Governor Kevin Stitt in May 2026 and the July 1, 2026 effective date. Retrieve the enrolled version and the bill status page from the Legislature's bill lookup. oklegislature.govPrimary, enacted statute

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Method

Every checkable fact on this page carries a numbered citation to a primary source that was retrieved and read on July 6, 2026. Where a figure appears in a regulator's summary but the underlying order should be read before it is quoted exactly, the panel says so directly rather than presenting the figure as settled. Where a claim could not be traced to a primary source on that date, it is marked as needing confirmation, not stated as fact. This page carries no speculation. Existing facts re-verified against current sources on July 10, 2026. The Virginia transmission case and the New York moratorium were added and verified on July 16, 2026. Ohio was added and the Texas section was updated to carry Governor Abbott's August 3, 2026 directive on August 6, 2026. Texas sources were re-verified on August 7, 2026. The national moratorium counts were re-verified against their cited sources on August 8, 2026. Oklahoma was added on August 10, 2026 from primary sources: the Oklahoma Corporation Commission page for the Data Center Customer Ratepayer Protection Act and the enrolled text of House Bill 2992 via the Oklahoma Legislature. On August 12, 2026 the date of the Virginia SCC Rider T-1 final order in Case No. PUR-2026-00056 was CORRECTED from August 5, 2026 to July 31, 2026. The earlier date came from news coverage published after the order rather than from the docket. The corrected date is the Final Order date recorded in the Commission's own docket for the case. No state was added or removed by this correction and the state count is unchanged. Also on August 12, 2026 the Georgia quote was CORRECTED to remove a staff estimate of about 11 percent by 2028. That figure came from reporting and could not be traced to the Commission's own record, and the quote had attributed the estimate to the Commission. The quote now makes the allocation point without a figure. The Georgia prose and reference were then rewritten against the Commission's own record on the same date: the July 7, 2026 administrative session agendas for Docket No. 57171. The staff estimate and the end-of-2026 conclusion date were removed from the prose and from the reference entry because neither could be traced to that record, and reference 18 was replaced with the agendas themselves. The state count was not changed by any of this. On August 18, 2026 the Georgia stakeholder diagram was CORRECTED. The August 12 correction removed the staff estimate from the quote and the prose but did not reach the diagram, which continued to display the figure on the residential ratepayer node. That label now reads "Bill impact under review." No state was added or removed and the state count is unchanged. The Oregon reference was also corrected on August 12, 2026. Its figures were right but its sources were not: it cited a news article and a Public Utility Commission release of May 7, 2026 that announced the creation of Schedule 96 and contained none of the July figures attributed to it. The reference now cites Order No. 26-154 in Docket UM 2377 and the Commission's own media release of July 7, 2026, which is where those figures come from. No Oregon number, percentage, customer count or date was changed. On August 12, 2026 two quoted strings in reference 18 were RESTORED to the source after being re-read from the raw bytes of the July 7, 2026 agendas. The agenda writes RTP inside its own quotation marks, which had been dropped, and it ends the consultant clause with a period where this page had put a comma inside the quotation. Nothing in either quotation was reworded. Also on August 12, 2026 every quoted string in the references was checked against its own source, twenty-nine in total. Twenty-five verified against their own sources. One, a phrase this page recommends to reporters rather than a quotation from anyone, was taken out of quotation marks because it was never a source quotation. Three could not be checked because their sources are behind bot protection, and QUOTATION MARKS WERE REMOVED from those three rather than left standing as an unverified claim. No title was reworded, no reference was deleted, and no link was changed.

The framing is deliberately economic, not environmental. The question throughout is cost causation and cost allocation: who triggers the buildout, and who pays for it. Reporters and editors are welcome to use these maps with attribution, or to reach out for a source interview.

Contact: Dr. Mark R. McNees, Florida State University, mmcnees@fsu.edu, 850.973.7687.