03 · Behind-the-meter
A deal room for behind-the-meter and co-location arrangements — FERC, state PUCs, NRC, and local authorities in one workflow. Built for the 46 existing BTM sites that must re-file under FERC’s December 2025 order, and the hundreds more forming now.
Preview
The regulatory graph generates a Gantt for every deal. When PJM files a new transmission service option, every active workspace gets a compliance diff within the same business day — not the same month.
Project Harbor · 960 MW co-location
17 active filings · 4 regulators · critical path 94 days
The problem
FERC rejected the Talen–AWS Susquehanna ISA amendment in November 2024. The resolution — an 18-year, $18 billion retail PPA — required 18 months of legal work. Every deal since then navigates the same fog. PJM filings are due in February, March, and April 2026. Eleven open questions. A transition deadline in 2028. Every month the rules change.
FERC 12/18/2025 order
FERC filings, 2025
FERC docket ER24-2172
Cliffcenter regulatory graph
Active deadlines we're tracking
Deals in flight
Every one of these deals is re-filing, amending, or pre-filing under the new co-location framework. Our customers are inside at least two of them.
200 MW BTM with Williams natural gas in Ohio. Must be in service before end of 2026. New FERC/PJM filing under the co-location framework.
5 GW Louisiana deployment on three H-class gas turbines. Largest behind-the-meter AI deployment announced to date.
933 MW gas plant co-located with a Google AI campus. Active ERCOT large-load request and Texas PUCT filing.
245 MW 15-year lease at Hut 8's River Bend Louisiana campus, scaling to 2.3 GW. $7.0B total contract value announced December 2025.
The wedge
Latham & Watkins runs a ~50-lawyer data center group. Baker Botts brands itself as “the market leader in the data center ecosystem.” Gibson Dunn, Orrick, Pillsbury, and McGuireWoods each have dedicated practices. They charge $1,000–$2,200 an hour and have no structural reason to automate.
Meanwhile, the in-house regulatory teams at Constellation, Vistra, and Talen are processing deal flow that outpaces their bandwidth. They are the customer. They want a regulatory graph, not a partner-level associate in San Francisco who is about to bill them for reading the same FERC order the associate’s summer intern already summarized.
We encode the regulatory graph. Counsel still ships the final filing. The economics of the platform are set by the law firm pricing we’re displacing, not the SaaS pricing we’re building.
How it works
Parties, generation asset, load profile, term, structure (retail PPA, ISA amendment, front-of-meter, co-location). We normalize it into a canonical deal schema.
Works for both new origination and FERC 12/2025 re-filings.
We surface every federal, state, regional, and local filing the deal triggers — FERC ISA amendments, NRC licensing, EPA Clean Air Act permits, state PUC proceedings, retail licensing, and local zoning. Each filing is linked to its dependencies.
17+ distinct filing categories pre-mapped.
The graph produces a Gantt with critical path, deadlines tied to regulatory milestones, and a per-workstream owner. Every filing carries its statutory clock and auto-generates a draft from the deal schema.
Legal, regulatory, engineering, and financial workstreams on one plan.
Deal participants — developer, power company, utility, counsel, financial advisor — all live in one structured workspace with redlining, version control, and regulator-facing exhibits. You stop losing 40 hours a week to email chains.
Observer seats for ISO, RTO, and agency stakeholders.
Features
We track the three PJM transmission service options, the 11 open questions, and the 2028 transition deadline as structured objects. When PJM files anything new — February, March, April 2026 — your deal graph updates automatically.
Three Mile Island, Duane Arnold, Comanche Peak, and every other nuclear co-location deal requires its own filing cadence. We encode the operating license amendment process, the NRC review clocks, and the public hearing schedule.
Every active PUC docket relevant to data center co-location — Virginia SCC, PUCT, PSC Indiana, Georgia PSC — indexed and monitored. You get notified within hours of a ruling that affects your deal.
Produces exhibit-ready filings in the format each regulator expects. Witness testimony scaffolds, rebuttal templates, and hearing prep materials are all first-class objects.
AI-powered retrieval across every co-location-adjacent FERC order from 2019 forward. Query in natural language, cite results directly, and export briefs ready for counsel review.
Model transmission cost shifts across PJM ratepayers, quantify the cost ratepayers would bear under each deal structure, and pre-empt intervener arguments before they appear in the docket.
CBAs are now a common condition of approval. We ship a template library, a benchmarking database against executed CBAs, and a redlining workflow for community coalitions.
FERC open meetings, PUC hearings, rulemaking comment deadlines, and bellwether rulings — all in one calendar, with alerts tied to your active deals.
“There is not yet a standardized regulatory regime. The sheer magnitude and speed of data center development has outpaced the existing rules.”
Built for
Constellation (Three Mile Island), NextEra (Duane Arnold), Vistra (Comanche Peak), Talen (Susquehanna). You are a repeat player; each deal is unique but the workflow repeats. We make the repeating part software.
Microsoft, Meta, Google, Amazon, Oracle, xAI. Your deal structures are under sustained regulatory scrutiny and your legal spend is uncapped. We make the legal spend auditable and the deal timelines predictable.
Not Latham, Gibson Dunn, or Baker Botts — they see automation as a threat. The firms two tiers down use Cliffcenter as a force multiplier, bidding on deals they would not otherwise staff.
Jefferies, Lazard, Evercore, and the private equity funds underwriting $1–18B BTM transactions. Our deal room becomes the single source of truth for the diligence package.
Pricing
One behind-the-meter or co-location deal, from kickoff through execution or regulatory approval.
Unlimited deals across your portfolio, plus dedicated regulatory engineering support.
Full platform access with custom integrations, on-prem data residency, and a named regulatory partner.
Questions
They won’t — the top firms will not. Our wedge is the second tier of firms and the in-house teams at power companies and hyperscalers, who are already losing deals to Latham because they cannot staff them. For them, Cliffcenter is a way to bid and ship.
We built a dedicated regulatory graph that ingests every PJM filing, every FERC response, and every stakeholder comment in the proceeding. When PJM files its three transmission service options in February 2026, our graph updates within 24 hours and every active deal in your workspace gets a compliance diff.
Both. The tracker is the foundation; the drafting happens on top. We auto-generate first drafts for routine filings (ISA amendments, interconnection request packages, standard CBAs) and scaffold exhibit-ready drafts for the complex ones. Your counsel still signs the final version.
Deal rooms are strictly isolated. No cross-deal data sharing. No training on customer data. We offer on-prem and VPC deployments for sensitive transactions, and our SOC 2 Type II audit closes in Q3 2026.
No — the core value is the regulatory graph. A project management tool does not know that the NRC operating license amendment cycle averages 18 months and has a mandatory public hearing window. We do. The work plan is generated from the graph; the graph is the product.
Yes. We integrate with Ironclad, DocuSign CLM, SirionLabs, and LinkSquares. Our deal objects export cleanly; their contract objects import cleanly. We are a layer above CLM, not a replacement.
Related
BTM Workflow
Bring an active deal or an open FERC docket. We’ll stand up a deal room in a week and pre-load it with the regulatory graph for your counterparties.