Case intelligence reportCASE-08-05

Georgia >100 MW large-load contract and planning cluster

Georgia has a current >100 MW framework and documented dispute over pipeline maturity.

Executive summary

Read the conclusion before the archive.

  1. Georgia has a current >100 MW framework and documented dispute over pipeline maturity.
  2. The verified path stops at C9–C10 where a public filing verifies pathway/agreement; the next transition remains bounded by the public record.
  3. No claim that framework fully protects customers or that disputed forecast is correct.

01 · Case brief

Why this mechanism belongs in the portfolio.

Contract review/risk allocation plus disputed pipeline maturity. The cluster is retained for its evidentiary function, not as a representative sample or ranking.

01

Observed mechanism

Georgia has a current >100 MW framework and documented dispute over pipeline maturity.

02

Unverified transition

Named customer identities/terms; mature-project states; realized load; rate effects

03

Quantitative basis

>100 MW threshold; forecast/pipeline quantities remain separate

Figures remain attached to their stated unit and state basis.

Decision boundary

The evidence ceiling

Permitted conclusion

Georgia has enforceable framework and a documented dispute over pipeline quality.

Prohibited stronger claim

No claim that framework fully protects customers or that disputed forecast is correct.

Quantitative ceiling
Threshold and separately vintaged pipeline data only
Causal ceiling
No rate or project outcome causation

02 · Institutional control

The outcome depends on a distributed permission stack.

No actor, filing or contract is allowed to stand in for the entire conversion chain.

01

Tariff/contract

02

cost allocation

03

resource planning

04

confidential customer records

Controlling actors

Institutions with decision rights

  • Georgia PSC
  • Georgia Power
  • customers
  • intervenors

Controlling instruments

Documents and mechanisms

  • Order, rules, contract dockets, IRP/large-load reports

03 · Event sequence

The verified path and the point where proof stops.

The sequence records documentary transitions. It does not imply a standard duration, inevitability or linear progression.

  1. 01

    PSC rule/order

  2. 02

    utility contract filing/review

  3. 03

    planning reports

  4. —
    Blocked or unverified next transition

    Named customer identities/terms; mature-project states; realized load; rate effects

04 · Rival tests

Alternative explanations that materially narrow the claim.

A rival “win” does not reverse the record. It defines the strongest inference that survives the contrary evidence.

01

RW-0008 · BOUNDED WIN WITH ATTRIBUTION

Forecast screening

Tested against
Assumption that pipeline quantities are fixed realized need
Evidence result
Party docket evidence identifies removals/maturity uncertainty; official framework requires review
Ceiling effect
Uncertainty claim strengthened
Prohibited inference
No adoption of party forecast as fact
02

RW-0009 · PARTIAL MATERIAL WIN

Private-risk allocation

Tested against
Assumption that all large-load risk remains socialized
Evidence result
Georgia framework imposes longer terms, minimum billing and cost responsibility
Ceiling effect
Mechanism claim strengthened
Prohibited inference
No claim of full protection or observed rates

Documented adaptation

The mechanism changed; the outcome remains bounded.

ADAPT-0005 · Customer risk security

Longer contracts, minimum billing, upstream/site cost assignment and contract filing

Trigger or constraint
Cost shifting and departure risk
Evidence / implementation
Approved framework · CURRENT FRAMEWORK
Observed outcome
Framework observed; complete rate effect unobserved
Claim ceiling
Partial risk allocation

ADAPT-0006 · Pipeline screening

Maturity rules and periodic large-load reports can remove or downgrade projects

Trigger or constraint
Forecast uncertainty and noncompliance
Evidence / implementation
Party evidence plus official reporting framework · DISPUTED / ONGOING
Observed outcome
Removals alleged/documented in party filing; Commission finding not inferred
Claim ceiling
Attributed uncertainty only

05 · Claim register and evidence file

Load-bearing claims and the record that resists them.

10 linked claims, 6 primary source references and explicit contrary or negative evidence are retained under stable IDs.

CLM-0020 · legal status

Ohio, Georgia, and Virginia have public regulatory records creating or approving large-load/data-center-specific rate or contract pathways, but their terms, procedural finality, and risk allocation differ and cannot be collapsed into one regime.

Claim ceiling
Existence and heterogeneity only; no conclusion that any regime fully protects ratepayers.
Evidence
Tier A · HIGH for existence; MEDIUM pending full tariff extraction
Locator
Ohio 24-508-EL-ATA and appeal 2025-1458; Georgia >100 MW summary/dockets; Virginia PUR-2025-00058/GS-5

CLM-0081 · legal status

Georgia PSC Docket 44280 approved rule changes for new large customers, requires Georgia Power to use its discretion to protect existing customers, and requires implementation terms before contracting.

Claim ceiling
Order controls; no ex post rate-impact outcome inferred.
Evidence
Tier A · HIGH
Locator
Order pp. 1-3; agency release
Linked sources
SRC-0100SRC-0115

CLM-0082 · contractual state

Georgia Power must file complete contracts and associated materials for new covered contracts within 30 days of execution, but public availability may still be limited by lawful confidentiality treatment.

Claim ceiling
Filing duty does not guarantee an unredacted public contract.
Evidence
Tier A · HIGH
Locator
Order p. 2 ordering paragraphs
Linked sources
SRC-0100

CLM-0083 · interpretation

Georgia’s large-load framework allows customer-specific terms including longer commitments, minimum billing and assignment of site and upstream system costs, while the Commission retained jurisdiction to modify the rules.

Claim ceiling
Framework terms do not establish that every future cost is fully internalized.
Evidence
Tier A · HIGH
Locator
Order and official summaries

CLM-0097 · interpretation

Across the six inspected tariff regimes, thresholds, terms, minimum-billing formulas, deposits/collateral, exit obligations and resource rules vary materially; there is no single U.S. large-load tariff template in the inspected public record.

Claim ceiling
Bounded to inspected regimes and cutoff; not an exhaustive census.
Evidence
Tier A · HIGH
Locator
Pass 04 tariff ledger

CLM-0103 · interpretation

Public special-contract records can establish approval, filing duties and some allocation mechanisms while leaving customer-specific pricing, guaranties or service terms redacted or otherwise unavailable.

Claim ceiling
Preserve SOURCE GAP; do not reconstruct confidential terms.
Evidence
Tier A · HIGH
Locator
Orders/transcript and contract-review provisions
Show 4 additional linked claim IDs

CLM-0107CLM-0198CLM-0199CLM-0205

Contrary evidence and competing mechanisms

CTR-0004 · Private-risk allocation

Tariffs, collateral, minimum bills, contract terms, and exit provisions may shift material risk to large-load customers.

Evidence result:Ohio, Georgia, and Virginia records establish differentiated large-load rate/contract pathways, while consumer/intervenor records contest adequacy and legal status varies.

Ceiling effect:No claim that risk is fully shifted or ratepayers fully protected.

CTR-0025 · Private-risk allocation

Ohio appeal contests sufficiency/finality of approved tariff protections.

Evidence result:OCC current filing registry and Supreme Court appeal record remain active.

Ceiling effect:Prevents claim of uncontested finality or proven full protection.

CTR-0026 · Private-risk allocation

Georgia Commission retained jurisdiction and may revise its framework.

Evidence result:Order expressly retains review and modification authority.

Ceiling effect:Prevents immutable/complete-framework claim.

CTR-0027 · Private-risk allocation

Virginia requires future alternative generation/transmission allocation proposals.

Evidence result:SCC fact sheet states future proposals remain required.

Ceiling effect:Prevents claim GS-5 closes all cost-allocation questions.

CTR-0028 · Private-risk allocation

I&M terms resulted from compromise among materially different proposed thresholds and obligations.

Evidence result:Settlement testimony documents utility, consumer and data-center positions.

Ceiling effect:No single design proven optimal.

CTR-0029 · Policy/data uncertainty

Tariff structures are heterogeneous across states and utilities.

Evidence result:Pass 04 six-regime comparison shows different thresholds, terms, deposits and resource rules.

Ceiling effect:No national-template claim.

Public-record gaps

NEG-0005

Question checked:Are all customer-specific obligations in large-load contracts public?

No; redactions and framework-only public records remain.

Implication:Framework-level claim ceiling; REDACTION GAP.

NEG-0027

Question checked:Is there one uniform U.S. large-load tariff design?

NO. Thresholds, terms, collateral and cost-allocation mechanisms differ materially.

Implication:Use bounded portfolio comparisons only.

NEG-0028

Question checked:Does an effective/approved tariff prove all stranded costs are recovered?

NO comparable ex post dataset was located.

Implication:Outcome/causal ceiling remains low.

NEG-0029

Question checked:Are complete unredacted Georgia large-load contracts publicly available and comparable?

SOURCE GAP — filing duty established, but complete comparable public terms were not located.

Implication:Do not reconstruct customer economics.

NEG-0034

Question checked:Are full public U-37425 special-service economics available from the inspected record?

SOURCE GAP — approval and implementation are public, but full terms remain partial/redacted.

Implication:No inference of complete risk transfer.

Show the complete linked control-ID index
Contrary evidence
CTR-0004CTR-0025CTR-0026CTR-0027CTR-0028CTR-0029CTR-0031CTR-0057CTR-0060CTR-0062CTR-0063CTR-0064CTR-0065
Negative findings
NEG-0005NEG-0027NEG-0028NEG-0029NEG-0034
Reopen controls
OIR-0007OIR-0025OIR-0027OIR-0029OIR-0032OIR-0055OIR-0056

06 · Record maintenance

What would justify reopening this report.

Updates require a documented evidence delta. Passage of time, repetition of an announcement or a portfolio-level disclosure is not enough.

What could change this record

  • OIR-0007 · Ohio appeal resolves, or Ohio/Georgia/Virginia tariffs/contracts are modified, stayed, superseded, or implemented through new sheets/orders.

    Required update: Retrieve final holdings/effective sheets; record customer obligations, conditions, supersession, and legal finality.

  • OIR-0025 · Georgia PSC files, approves, modifies or discloses material large-load contract terms or supersedes Docket 44280 rules.

    Required update: Record contract state, public/redacted fields, exact allocation terms and project state without inference.

  • OIR-0027 · Kentucky Power or EKPC tariffs, special contracts, dedicated-resource approvals or compliance sheets are modified or superseded.

    Required update: Inspect approved tariff/special contract and update exact obligations, states and confidentiality.

  • OIR-0029 · Comparable ex post cost, default, stranded-cost or rate-impact data become public for an inspected tariff.

    Required update: Add outcome dataset with denominator, counterfactual/rivals and causal ceiling.

  • OIR-0032 · LPSC U-37425 or related Rider GZ/resource proceedings disclose or change customer obligations, guaranties, generation, transmission or procurement terms.

    Required update: Inspect controlling order/filing, retain redactions, and update only public terms.

  • OIR-0055 · Georgia Commission adjudicates disputed pipeline maturity, publishes updated large-load reports, or discloses contract outcomes.

    Required update: Distinguish Commission finding, utility assertion and party evidence; update pipeline vintage and removals.

  • OIR-0056 · New cross-case evidence materially changes a rival win or adaptation outcome.

    Required update: Update only affected case and preserve mechanism/outcome distinction.

Record navigation

These records share claims or sources with this report. The linkage supports navigation, not a causal inference.

Sources — bibliography and exact locators

  1. SRC-0045 — Georgia PSC Adopts Rules for Data Centers Over 100 MW

    Georgia Public Service Commission · 2025-01-23 · Tier A-minus

    Locator: p. 1; >100 MW threshold; contract/minimum-bill/cost provisions

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  2. SRC-0047 — Georgia PSC Docket 55378

    Georgia Public Service Commission · 2025-01-01 · Tier A

    Locator: Docket index and filings

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  3. SRC-0048 — Georgia PSC Docket 44280

    Georgia Public Service Commission · 2025-01-01 · Tier A

    Locator: Docket index; large-load contracts/filings

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  4. SRC-0100 — Order Approving Georgia Power Rules and Regulations Changes for Large Customers

    Georgia Public Service Commission · 2025-01-28 · Tier A

    Locator: Docket 44280, Document 221165, pp. 1-3; ordering paragraphs on implementation, contract filing, compliance tariff, continuing jurisdiction

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  5. SRC-0168 — Public-interest intervenor filing concerning Georgia Power large-load forecast and pipeline

    Georgia PSC public docket participant filing · 2025-12-16 · Tier A-minus

    Locator: PDF pp. 6–10 and 17; discusses 14,345 MW removal, pipeline screening, contract uncertainty and flexibility assumptions

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE

  6. SRC-0169 — 147th Annual Report — Georgia Public Service Commission

    Georgia Public Service Commission · 2026-05-12 · Tier A-minus

    Locator: Data-center/large-load rule discussion; >100 MW customers; minimum billing, longer terms and pre-execution contract filing; 2025 activity summary

    PUBLIC OFFICIAL RECORD — CITE/SUMMARIZE