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 deadline-anchored artifact. **ERCOT Batch Zero — T-7 to July 10, then T-21 to July 24.** Yesterday's newsletter covered this in detail. The Interconnecting Large Load Entity (the data center operator) must complete, sign, and notarize Form W Part A and submit it to the serving Transmission Service Provider or Distribution Service Provider by July 10, 2026. The TSP/DSP then submits the completed form plus supporting modeling data (including the minimum Load Participation Commitment limit per study year) to ERCOT by July 24. This is a two-step deadline chain. Miss July 10 and the load drops into the standard interconnection queue, which now holds more than 438,000 MW of proposed demand (89% data centers per ERCOT's own trending topic PDF from June 18), and which is estimated 3-5 years slower than the Batch Zero pathway. For a hyperscaler with a Texas site targeting a 2028 or 2029 go-live, missing July 10 is functionally a project restart. Form W is now officially posted on ERCOT's Large Load Integration page. **PJM 2028/29 capacity auction — bidding window closes T+4 (Tuesday July 7), results July 14.** PJM's Base Residual Auction for the June 2028 to May 2029 delivery year opened Monday June 30 and closes Tuesday July 7. Results will be reported after 4 PM Eastern on July 14. This auction is structurally different from the last two auctions in one important way: the price band was pre-negotiated by the governors of all 13 PJM states before bidding opened. Prices are floored at $175/MW-day and capped at approximately $325/MW-day (specifically the FERC-approved cap that was $329.17/MW-day in prior cycles). This means the 2028/29 auction cannot produce a runaway clearing price like the 2027/28 auction did (which cleared at the FERC cap, driving a projected $1.4 billion in additional capacity market costs across PJM ratepayers starting June 2026). For data centers colocated in PJM, this establishes a clear ceiling on 2028/29 capacity-related electricity cost inputs — which is a legitimate positive for hyperscaler bookings modeling. It's also a first-of-kind precedent for state-governor pre-negotiation of RTO price bands, which is a structural political shift worth logging. **Maryland ratepayer-cost-allocation complaint at FERC — comment deadline extended to July 27.** On June 17, 80 Maryland state lawmakers formally supported a complaint at FERC over how PJM allocates costs for transmission lines built specifically to serve new data center load. The core allegation: PJM's current cost-allocation framework spreads transmission-upgrade costs across all ratepayers in the affected zone, meaning Maryland residential and small commercial customers pay for high-voltage transmission upgrades that primarily benefit hyperscaler data center customers. The relief sought is a rule change that would allocate those upgrade costs specifically to the load driving them. FERC extended the comment deadline to July 27 to give more state parties time to weigh in. This is directly analogous to Virginia's rate-class filing at the Virginia State Corporation Commission (approved November 2025, effective January 2027) that already imposed 85% distribution and 60% generation demand cost recovery on large data center customers. Maryland is now trying to accomplish through federal (FERC) rulemaking what Virginia already accomplished through state (SCC) rulemaking. If FERC grants the Maryland complaint, that becomes a PJM-wide precedent affecting Ohio, Illinois, Pennsylvania, and every other PJM state — a much more consequential outcome than a single state rate class filing. **Hochul still not formally delivered NY A11560 — 10-day gubernatorial clock hasn't started.** The New York Legislature passed the Responsible Data Center Development Act (S10642 / A11560) on June 4, 2026 — a 1-year moratorium on Department of Environmental Conservation permits for data centers ≥20 MW. Under the New York constitution, once a passed bill is formally delivered to the Governor's desk, she has 10 days to sign or veto it, and failure to act allows the bill to become law without signature. As of yesterday's tracker check, the bill has NOT yet been formally delivered. This is a common Albany maneuver — the Legislature delays delivery to give the governor flexibility on veto timing. Once delivered, Hochul has 10 days. That means the actual signature/veto/passive-enactment window is still ahead. Given Hochul's public equivocation ('review it in context...status quo can't continue'), a passive enactment via non-action is a plausible political landing spot — she avoids the labor / building-trades backlash of a signature and avoids the environmentalist backlash of a veto. Watch for the formal delivery date; it starts the 10-day clock. Why the four deadlines matter together. Each is a discrete deadline-anchored moment. ERCOT Form W is the Texas developer-execution moment. PJM 2028/29 auction close and results are the wholesale-power-cost bounding moment. Maryland FERC comment is the state-party political-alignment moment. New York A11560 delivery starts the New York state-clock. All four are inside a 24-day window. That's an unusually compressed calendar of discrete buying-signal events, and Cliff should be reaching out to every ERCOT-adjacent, PJM-adjacent, and NYISO-adjacent developer contact this week with a specific deadline-anchored offer.
Why it matters
Three implications. (1) The 24-day compressed calendar (Jul 7 PJM close, Jul 10 ERCOT step 1, Jul 14 PJM results, Jul 24 ERCOT step 2, Jul 27 MD FERC comment) is a legitimate go-to-market window for Cliff. Every ERCOT-adjacent developer contact should get a Form W preparation checklist this weekend, every PJM-adjacent developer should get a 2028/29 auction impact model early next week, and every Maryland / DC / Northern Virginia contact should get a FERC comment template ahead of July 27. Not one broad newsletter; four discrete deadline-anchored outreach lists. (2) The 13-governor pre-negotiated PJM price band is the single most important structural political precedent of the week. If the 2028/29 auction clears meaningfully below the $325 cap (say, in the $220-280 range), the pre-negotiation model has proven it can reshape RTO auction outcomes without formal FERC intervention — that becomes the template every state governor's office will study going into 2027 auctions and will be copied by CAISO / MISO / ISO-NE governors. Cliff should publish an analysis piece the afternoon of July 14 immediately after results drop — that's a free content-marketing wedge into every state utility commission staff office in the country. (3) Hochul's non-action on NY A11560 is the emerging model for blue-state governors who want to avoid both the labor backlash of signing an incentive freeze and the environmentalist backlash of vetoing one. Passive enactment via non-delivery gives her cover on both sides. If that model works for Hochul in July 2026, expect Newsom, Whitmer, and Walz to study it carefully for parallel bills in their own states in 2027. That further reduces the probability of active-signing incentive freezes in CA / MI / MN — because the political path of least resistance is passive enactment or passive rejection via non-action, not signature. Cliff should factor this into probability estimates for follow-on state incentive freezes.
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Related filings
FERC show cause orders Jun 18 / Section 206 / PJM MISO SPP CAISO ISO-NE NYISO / 30-day informational report Jul 20 / 60-day tariff response Aug 17 / 90-day abeyance request Aug 3 / five reform categories / cost-shift prevention is the big one / colocation + BTMG rules / flexible-load transmission services
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'...
Oracle sued Wisconsin PSC Jun 19 Ozaukee County / challenging April tariff rule / $100M/year financial security / very large customer >20 MW sub-A credit / Oracle BBB / Port Washington $15B 672 acres 1 GW 4 buildings We Energies / statutory-authority + discrimination + due-process theories / parallel administrative reconsideration / first hyperscaler-vs-PSC ratepayer-protection lawsuit / template for VA SCC MD FERC IL DCIP TX SB6 / AWS BBB+ adjacent risk / expected 6-12 months to ruling
Plain-English background on why this lawsuit matters more than a single facility dispute. Multiple states have enacted or are enacting 'ratepayer protection' rules for hyperscaler-scale customers in 2025-2026: Virginia's SCC rate class (approved Nov 2025,...
T+3 PJM bid close Jul 7 / T+3 Lakeland FL first reading Jul 6 9AM / T-6 ERCOT Form W Jul 10 / T+11 PJM auction results Jul 14 / T+16 Lakeland FL final vote Jul 20 / T+23 MD FERC comment deadline Jul 27 / Prince George's MD 2-year moratorium vote queued next week / NY A11560 not delivered to Hochul / 10-day clock not started / 6 deadline windows 24 days
Plain-English rollup of what didn't change over the July 4 weekend and what's coming next week. **ERCOT Batch Zero Form W Part A — T-6 to Thursday July 10.** No change since Thursday. The Interconnecting Large Load Entity (data center operator) must...
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...