FL moratorium wave / Clay final + Hernando, Lake first reading Jun 23 / Santa Rosa 3-1 to draft / Zephyrhills final / 5-8 FL jurisdictions in 5 weeks / SB 484 backdrop / water-first concern

Why it matters

Three implications for Cliff. (1) Florida is the fourth distinct non-RTO moratorium cluster, after Duke Energy Carolinas (NC + SC), TVA (TN), and MISO Wisconsin (technically RTO but rural cooperative). The Florida Reliability Coordinating Council (FRCC) is the non-RTO reliability region that covers peninsular Florida; FPL and Duke Energy Florida are the dominant utilities; neither is a FERC-jurisdiction RTO for retail purposes. That means FERC's June 18 show-cause orders against the six RTOs (PJM, MISO, SPP, CAISO, ISO-NE, NYISO) do not reach Florida at all — the federal tariff fight that is currently consuming PJM and MISO simply does not apply to Florida sites, and the only available pressure mechanisms are state legislation (SB 484, now law) and local moratoriums (this week's wave). This makes the underwriting analysis for a Florida hyperscale site structurally different from a Pennsylvania or Virginia one — Cliff's corpus should tag FRCC territory as a distinct regulatory regime, not lump it with adjacent SERC RTO members. (2) SB 484's July 1 effective date is now a hard deadline that everyone underwriting Florida is racing against. Once the law is in effect, it prohibits utilities from passing data center electricity costs to residential or small-business customers and explicitly preserves local government veto authority. So between now and July 1, every Florida developer with a pending project is either trying to finalize permitting under the pre-SB-484 regime or trying to time a behind-the-meter / dedicated-PPA structure that compliant under the new law. Combined with the Jun 22 Microsoft + Chevron Kilby precedent (yesterday's pull), the structural arbitrage is now: behind-the-meter campuses in low-density Florida counties (parts of DeSoto, Hernando, Santa Rosa) become structurally easier to underwrite than grid-connected campuses in higher-density coastal counties. (3) Water is the binding constraint in Florida in a way it is not in NC or TN. Hyperscale evaporative cooling, paired with Florida's hot-humid climate (high wet-bulb temperatures) and Floridian counties relying heavily on the Floridan Aquifer for residential well water, makes water-use the first thing every commissioner brings up at every hearing this week. Cliff's diligence product should treat Florida site readiness as having water-use review on a par with air-permit review (PJM/VA) or interconnection-queue dedup (ERCOT) — a distinct, citable, structured-data axis that can be productized against South Florida Water Management District + St. Johns River Water Management District consumptive-use permitting.