Plain-English framing. The 'Public Staff' in North Carolina is a permanent state agency that represents residential and small-business customers in utility rate cases — separate from the elected Attorney General, separate from the Utilities Commission. When the Public Staff files testimony, it's the closest thing to a 'consumer advocate verdict' on what the utility should be allowed to charge. Duke Carolinas (the territory covering most of NC and parts of SC) is in an ongoing rate case asking for a 14% rate increase effective January 1, 2027. The Public Staff's counterproposal: before that rate increase touches residential customers, every data center load above 50 MW that also commits to using at least 80% of its requested capacity should be moved into a separate mandatory tariff with minimum monthly bills, exit fees for early termination, and operational curtailment requirements during specified hours. The 80% load factor trigger is the interesting variable. AI training workloads run very high load factor (close to 100%). Inference workloads and mixed-use sites run lower (60-80%). At 80%, the tariff would catch hyperscale training campuses but might miss mixed-workload inference sites — which could become a structural siting incentive for variable-workload AI in NC. Duke disclosed 6 GW of data center pipeline across the Carolinas, with 16 signed contracts totaling 4,337 MW already in place. The 6 GW figure is the relevant denominator for the tariff's reach.
Primary source · WFAE / Duke Energy testimony filings (NC Utilities Commission) ↗
Why it matters
NC is the third tariff template Cliff needs to model alongside AEP Ohio and Dominion GS-5 — but the 80% load factor cutoff is sharper than either, which makes it the first US tariff that meaningfully differentiates AI training from inference at the rate-class level. For Cliff's siting tool, that creates a real product surface: 'show me states where a 60% load factor inference site escapes the mandatory tariff but a 90% training site doesn't.' That's exactly the kind of routing question the regulatory knowledge graph should answer without consultants.
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