Plain-English version. On June 18, 2026, the Federal Energy Regulatory Commission (FERC, the federal regulator with jurisdiction over the interstate transmission grid) used Section 206 of the Federal Power Act to issue what are called 'show-cause orders' against all six US-jurisdictional RTOs/ISOs. Section 206 is the legal mechanism FERC uses when it has preliminarily concluded that an existing tariff is unjust and unreasonable — instead of opening a years-long rulemaking, FERC puts the burden on the tariff-holder to either justify the status quo or fix it. The six entities under the show-cause orders are the six RTO/ISO markets: - **PJM Interconnection** — covers PA, NJ, MD, DE, VA, WV, OH, KY, IN, IL, MI, NC, DC. Largest by load. Most exposed to data-center politics (Virginia Northern, Ohio AEP territory, Maryland Frederick County). 67 million people. - **MISO (Midcontinent ISO)** — covers MN, IA, WI, MI lower peninsula, IL portions, IN, MO, KY portions, AR, MS, LA, plus the Manitoba border. Already seeing data-center activity in Wisconsin (Mount Pleasant/Microsoft) and the MN-MISO/Northern grid. - **SPP (Southwest Power Pool)** — covers NE, KS, OK, the TX Panhandle, parts of NM/AR/MO. Where the Oklahoma Data Center Ratepayer Protection Act of 2026 lands; SPP is also where Project Stargate's pipeline implications get studied. - **CAISO (California ISO)** — California plus a slice of Nevada. Lower data-center exposure than the others, but the most active state-policy environment (CA SB 540 series). - **ISO-NE (New England ISO)** — all six New England states. Lowest data-center exposure historically; capacity market has its own dysfunctions. - **NYISO (New York ISO)** — New York State. Just had the NY S.10642 moratorium passed by the legislature (now on Hochul's desk per yesterday's edition). NYISO is the RTO that would have to operationally implement whatever comes out of the Hochul desk + the FERC show-cause order simultaneously. What each RTO has to do, and when: - **30 days (deadline: July 20, 2026):** File an informational report describing how the RTO intends to ensure adequate generation will be available to serve existing AND new large loads. This is essentially 'show us the capacity-adequacy plan that gets us from today's queue to a reliability margin you can stand behind.' - **60 days (deadline: August 17, 2026):** Either (a) show cause why the current tariff is still just and reasonable WITHOUT the specific reforms FERC identified, OR (b) file tariff changes addressing those reforms. - **45 days for abeyance request (deadline: August 3, 2026):** RTOs can ask FERC to hold all or part of the order in abeyance for up to 90 additional days to allow stakeholder processes to develop responsive filings. This is the safety-valve mechanism if the 60-day window is genuinely too short. The five FERC-identified reform categories. The show-cause orders give each RTO a specific set of issues to address. These are: (1) develop efficient transmission-service application and study processes, including alternative transmission technologies (i.e., grid-enhancing technologies, dynamic line ratings); (2) prevent cost-shifting and require transparency into transmission costs (the big one — this is where 'who pays' is litigated); (3) accommodate co-location agreements and behind-the-meter generation (the data-center-plus-power-plant pattern); (4) provide new transmission services for flexible large loads (services tailored to loads that can curtail when the grid is tight); (5) develop processes to study generating facilities that serve electrically proximate large loads and co-located loads (essentially, the colocation-rules pattern PJM has been litigating since the Talen-AWS/Susquehanna case).
Why it matters
Four implications. (1) For Cliff's docket-intelligence corpus, the period from now through August 17 will produce the densest concentration of large-load tariff filings in US RTO history. Six RTOs, five reform categories each, with mandatory filings — that's at minimum 30 filing instances, plus stakeholder comment cycles, plus the August 17 responses themselves. This is the regulatory window the corpus has to be ready to ingest at high cadence. (2) The 'cost-shift prevention' reform category (#2) is the connective tissue between the federal-regulator track (FERC) and the state-legislative track (NY S.10642, FL SB 484, OK Data Center Consumer Ratepayer Protection Act). All three levels of government are now demanding the same thing — data centers pay their attributable share of grid-upgrade costs — and the August 17 RTO tariff filings will be the first formal articulation of HOW that gets implemented in market design. Watch PJM specifically: it has the most data-center exposure and the most political pressure. (3) Co-location + behind-the-meter (reform category 3) is the loophole the hyperscalers are betting on. If a hyperscaler campus has its own dedicated gas turbine or restarted nuclear unit on-site (Microsoft + Chevron Project Kilby, Talen-AWS-Susquehanna, Meta + various SMR partnerships), the colocation rule determines whether that arrangement counts as 'load on the grid' (subject to tariff) or 'behind-the-meter generation' (largely outside tariff). FERC's December 18, 2025 PJM colocation order already pointed toward a stricter interpretation; the August 17 PJM filing will be the next iteration. (4) NYISO is the highest-leverage RTO to watch in this cycle. If Hochul signs NY S.10642, NYISO has to operationally implement BOTH the state moratorium AND whatever FERC's reform requires by August 17. That's a uniquely difficult regulatory geometry — federal regulator demanding tariff reform that accommodates large loads, while state legislature is pausing the loads. The likely outcome is a NYISO filing that says 'our tariff will be reformed to accommodate large loads, but the state moratorium constrains how many of those loads can actually exist for the next 12 months.' That's the first explicit collision of federal-RTO authority and state-legislative authority over the same load class.
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Related filings
T-7 ERCOT ILLE Form W Jul 10 / T-21 Form W step 2 Jul 24 / PJM 2028-29 auction closes Jul 7 / results Jul 14 / price band $175-325 MW-day / 13-state governor pre-negotiated band / MD FERC ratepayer complaint comment deadline Jul 27 extended / NY A11560 not delivered to Hochul / 10-day clock not started / passive enactment plausible / 4 deadline-anchored windows next 24 days
Plain-English background on why the four operational-track deadlines all matter this month. Each of these deadlines drives a specific action by developers, hyperscalers, or state parties, and each represents a concrete moment where Cliff can produce a...
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
Plain-English version of what happened. Tuesday, June 23 was the single most active moratorium day Florida has had — three county boards moved separate ordinances forward in a coordinated wave. Clay County (just south of Jacksonville, ~220,000 residents) gave...
Spartanburg County SC / Jun 22 1 yr / pending ordinance doctrine fast track / Duke Energy Carolinas / Woodbury County IA / Jun 23 1 yr / Salix MidAmerican annexation carve out / MISO West / Cumberland County NC / Jun 15 6 mo / Duke Energy Carolinas / Jackson County MO / Jun 9 120 to 180 day extension / SPP MISO boundary / Lexington Fayette KY / Jun 9 until Oct 31 / KU LG and E / non-RTO non-IOU geographic expansion
Plain-English background. A 'data center moratorium' is a county or city ordinance that pauses all new data center applications for a fixed period (commonly 6 or 12 months) so the local government can write zoning rules, set impact fees, or just decide...
PJM / Dec 18 2025 co-location order / Feb 23 2026 Sec 205 compliance filing / Jul 31 effective date / abeyance candidate
The chronology. December 18, 2025, FERC issued a separate order (not yesterday's) directing PJM specifically to revise its tariff to provide clear rates, terms, and conditions for co-located load (a data center plus its own on-site generation, sitting at the...
Gibson Dunn — analysis of Dec 18, 2025 FERC order to PJM ↗