Cycle on Aug 31, 2026

I will start by listing the active threads for this topic to see what questions, investigations, or watches have been registered by prior cycles.

I will search the web for any recent developments regarding Portland General Electric's Schedule 96 and the Oregon PUC (Docket UM 2377), specifically looking for rulings or filings by the Oregon PUC, Amazon, or the Data Center Coalition.

I will fetch the main page for Docket UM 2377 from the Oregon PUC or do a search with freshness or recent terms to see if there is a decision on the applications for reconsideration (which are due by Sept 4, 2026, and today is Aug 31, 2026, so there might be a recent filing or decision). Let's search the OPUC eDockets page or run a query for recent UM 2377 filings.

Ah, there's a recent Portland General Electric (POR) Q2 2026 Earnings Call Transcript from August 7, 2026! Let's fetch that or do a search to see what was discussed on that call. Let's search for the transcript of the PGE Q2 2026 earnings call.

Let's fetch the Motley Fool transcript of Portland General Electric (POR) Q2 2026 Earnings Call Transcript from August 7, 2026. This will have critical details about PGE's load growth, the data center tariff (UM 2377), and Schedule 96. Let's do `web_fetch` on `https://www.fool.com/earnings/call-transcripts/2026/08/07/portland-general-electric-por-q2-2026-earnings-call-transcript/`.

Let's fetch the rest of the PGE transcript or search for specific parts of it to see what was said about UM 2377, the data center tariff, the 30% price increase, and the 1.7 GW pipeline. I'll search for PGE Q2 2026 transcript text containing "UM 2377", "Schedule 96", or "data center".

Let's fetch the SEC filing `por-ex99_2.htm` or do a search for the exact text of the transcript to see what happened in UM 2377 and the OPUC decision. I'll search for PGE's Q2 2026 earnings slide deck or transcript details on Google, focusing on OPUC, Schedule 96, and the 1.7 GW pipeline. Let's do a search.

Let's fetch the SEC filing `por-ex99_1.htm` from July 2026 (`000119312526327135/por-ex99_1.htm`) because it mentions "It results in data center pricing increasing by approximately 30... The New Large Load Tariff (docket UM 2377) was approved by the...". This is exactly PGE's Q2 2026 earnings release! Let's fetch it.

The OPUC approved Portland General Electric's Schedule 96 (New Large Load Tariff) under Docket UM 2377 in May 2026, with the new rates taking effect on July 8, 2026. This resulted in an average rate increase of approximately 30% for data center and other new large load customers, while lowering rates for all other customers. Wait, let's look at the watch: "The Oregon Public Utility Commission must rule on applications for reconsideration filed by Amazon Data Services, the Data Center Coalition, Verrus, and AWEC regarding Portland General Electric's Schedule 96 large-load tariff (Docket UM 2377). The ruling is due by September 4, 2026." Let's search for any recent OPUC filings or decisions on these applications for reconsideration under Docket UM 2377, or search for Amazon, Data Center Coalition, and OPUC in August 2026. Let's do a search.

Let's see if we can find the actual OPUC order or details about the reconsideration filings in Docket UM 2377. The calendar says: "9/4/2026: FINAL ORDER DUE DATE - Order to Verrus Application for Reconsideration due" "7/21/2026 3:00:00 PM: COMMENTS/RESPONSES DUE - Responses to Verrus, AWEC, ADS, and DCC Applications for Reconsideration due" So the OPUC has not issued its final order on the applications for reconsideration yet, as it is due by September 4, 2026 (which is in 4 days). Wait! Let's search the OPUC eDockets page to see if there are any orders issued in August 2026 under UM 2377. Let's search for "UM 2377" order or decision in August 2026. Or let's search for the OPUC orders list for August 2026. Or let's search `site:apps.puc.state.or.us "UM 2377" 2026` to see what filings or orders exist.

Let's review what we have: 1. Portland General Electric (PGE) had its Schedule 96 (New Large Load Tariff) approved with modifications by the Oregon PUC in Order No. 26-154 on May 7, 2026, under Docket UM 2377. 2. The tariff creates a new rate class for large data center customers (facilities >= 20,000 kW), resulting in an average price increase of approximately 30% for data centers effective July 8, 2026. 3. This was implemented via PGE's Compliance Filing (Advice No. 26-24) on June 3, 2026, and subsequent errata. 4. On July 6, 2026, several parties filed Applications for Rehearing or Reconsideration of Order No. 26-154: - Amazon Data Services (ADS) - Data Center Coalition (DCC) - Alliance of Western Energy Consumers (AWEC) - Verrus, LLC 5. Responses to these applications were filed on July 21, 2026, by PGE and a joint filing by the Coalition (environmental advocates) and Oregon Citizens' Utility Board (CUB). 6. The Commission's decision/order on these applications for reconsideration is due by September 4, 2026. This is a crucial upcoming catalyst that we are tracking. 7. Let's look at what Amazon's application argues. The snippet shows: - "The Order changes statutory law by prioritizing HB 2021 emission targets to the statutory obligations to provide non-discriminatory electric service within an exclusive service territory." - "The Order changes statutory law by shifting HB 2021 utility obligations onto customers." Let's see if we can find more about this or search for how this tariff works. It says that the tariff reallocates infrastructure costs by increasing data center rates while providing relief to residential and small business customers. In PGE's Q2 earnings call, CEO Maria Pope said: - "The approval of our large customer tariff reflects several years of legislative and regulatory work. It results in data center pricing increasing by approximately 30%, while lowering costs for all other customers." - "The 1.7 gigawatts of additional data center pipeline represents projects already in the permitting process... is not in our guidance and represents potential upside." - Pope also noted that the 1.7 GW "will also be under the UM 2377, which enables growth pace -- for growth, as I like say, or our peak growth modifier and the most recent higher customer prices for data centers." Let's do a search on other utilities mentioned in the active threads: - FirstEnergy's Proposed Ohio Data Center Tariff (Schedule DCT) under Case No. 26-697-EL-ATA. PUCO Staff Report is due by November 30, 2026. Let's search for FirstEnergy's proposed data center tariff or any updates on Schedule DCT in Ohio. Let's do a web search.

Let's search for "FirstEnergy" "Ohio" "data center" "tariff" OR "Schedule DCT" or Case No. 26-697-EL-ATA with a broader search. Let's do that.

Let's fetch the page `https://magnifyi.com/initial-comments-raise-serious-concerns-with-proposed-data-center-tariff/` to see what initial comments were filed and what concerns were raised regarding FirstEnergy's proposed Data Center Tariff (Schedule DCT) under Case No. 26-697-EL-ATA. FirstEnergy filed this on June 12, 2026. Let's do a `web_fetch`.

This is incredibly rich and detailed. Let's break down what's happening with FirstEnergy's proposed Ohio Data Center Tariff (Schedule DCT, Case No. 26-697-EL-ATA): 1. FirstEnergy of Ohio filed an application on June 12, 2026, proposing Schedule DCT, which creates a separate class/framework for data center customers. 2. Initial comments were filed in August 2026 (the article is dated August 10, 2026). 3. The key issues raised by different stakeholders are: - **Generation Service & Default Backstop (SSO):** FirstEnergy proposed that data centers must take generation service from a Competitive Retail Electric Service (CRES) provider rather than the Standard Service Offer (SSO) default rate. Constellation and IGS raised issues here. Constellation argues this violates Ohio law because it leaves data centers without the legally required SSO default backstop if their supplier defaults. They want the tariff to confirm that if an SSO is provided, it must be procured through a competitive process so costs aren't shifted to other SSO customers. - **Cost Allocation and Separate Rate Class:** Ohio Energy Group (OEG) argues that FirstEnergy's proposed Schedule DCT includes data center customers within existing rate classes (Secondary, Primary, Subtransmission, or Transmission) rather than separating them into their own distinct rate class. This lack of transparency heights the risk of cost-shifting, especially given FirstEnergy's forecast of **8.56 GW of data center demand in Ohio by 2035**, requiring **$250 million of transmission investment per GW** (totaling **$2.14 billion** in transmission rate base growth just for data centers). - **PJM Wholesale Integration & Reliability Backstop Procurement (RBP):** OEG notes that PJM proposed on July 27, 2026, to conduct a Reliability Backstop Procurement (RBP) auction for new large loads over 50 MW (mostly data centers) that do not bring their own generation. RBP costs will be allocated to FirstEnergy based on its projected large load. PJM warned that if states don't establish retail frameworks to allocate these costs to data centers, PJM will allocate them to all load in the zone (socialized). - **PJM's Interim Resource Adequacy Service (IRAS):** PJM also proposed an IRAS program on July 27, 2026, where large loads can interconnect without new generation but must curtail before system emergencies. They are paid a credit of $1,150/MWh, but these credits are paid by other customers in the zone. OEG argues a separate rate class is needed to prevent these costs from being shifted to non-data center customers. - **Textbook Discrimination vs. Cost Causation:** The Ohio Manufacturers' Association Energy Group (OMAEG) argues that targeting data centers based solely on their industry type/end-use is "textbook discrimination" and should instead be based on electrical characteristics and cost of service. However, OMAEG supports requiring large loads to pay all actual costs of transmission upgrades. - **Statewide Proceeding:** The Ohio Environmental Council (OEC) proposed a statewide proceeding to ensure consistent consumer protections across all Ohio utilities. - **Minimum Load Threshold:** The Ohio Consumers' Counsel (OCC) recommended that the tariff apply only to facilities with at least 50 MW of aggregate monthly demand. This is a massive development that completely updates FirstEnergy's Ohio tariff story! I will definitely write a finding about this. Wait, let's look at the PJM developments mentioned here: "PJM proposed on July 27, 2026: 1) the proposal to conduct a Reliability Backstop Procurement ('RBP') auction for new Large Loads over 50 MW (almost exclusively Data Centers); and 2) the proposal to provide Interim Resource Adequacy Service ('IRAS') Program rate credits to Data Centers..." Let's search for "PJM" "Reliability Backstop Procurement" OR "Interim Resource Adequacy Service" "July 2026" or "August 2026" to get more details on these landmark PJM proposals. This directly ties to FERC Section 206 show-cause filings and RTO large-load interconnection! Let's search.

This is incredible. Let's look at the PJM Board's July 27, 2026 Decisions and filings, which were formally submitted to FERC in August 2026. This is a massive milestone! Let's analyze the details of the PJM Board Decisions: 1. **Critical Issue Fast Path (CIFP) - Reliability Backstop Procurement (RBP):** - On July 27, 2026, the PJM Board of Managers issued a decisive letter on the CIFP Reliability Backstop Procurement. - PJM filed a proposal with FERC to commence a one-time **Reliability Backstop Procurement (RBP)** starting **September 30, 2026, through October 21, 2026** (with results in early December 2026). - The RBP aims to secure new generating resources for terms of **up to 15 years** to backfill the recent capacity auction shortfall and address future load growth. - The maximum willingness to pay is equal to a MW-weighted average of **$555/MW-day**. - **Cost Allocation:** PJM will allocate RBP costs to Load Serving Entities (LSEs) in specific zones or service areas based on their projected amount of new Large Load without new generation. PJM warns that state regulators must establish frameworks to allocate these costs to the large loads; otherwise, PJM will allocate them to all load in the zone (socialized) using existing Peak Load Contribution (PLC) assignments. - The RBP is a "pay-as-bid" auction, settled via a "contract for differences" against the Reliability Pricing Model (RPM) clearing price. Ratepayers benefit if RPM is higher than the RBP price, but are stuck paying the difference if RPM is lower. - Non-delivery penalties are severe: 20% of the RBP commitment price, assessed daily, with no replacement MWs allowed. 2. **Interim Resource Adequacy Service (IRAS) (formerly "Connect and Manage"):** - Electric Distributors will be required to implement IRAS for new Large Loads (>= 50 MW) that, as of **June 1, 2027**, do not bring sufficient capacity to serve their resource adequacy needs. - Under IRAS, these large loads can interconnect without bringing new generation, but they must curtail their load or switch to on-site backup resources when the system nears emergency conditions (prior to Pre-Emergency Load Management Reductions). - **Large Load Registry:** PJM will establish a Large Load Registry to track these loads. - **Compensation/Credits:** When called to curtail, these IRAS customers will receive a "federally approved hourly credit" equal to the Non-Performance Assessment Interval (Non-PAI) rate (currently **$1,150/MWh**). - **Retail Cost Allocation:** These credits are collected from customers in the zone that benefit from the load reduction. This has raised major concerns (as seen in the FirstEnergy Ohio comments) that ordinary ratepayers will end up paying hundreds of millions in credits to compensate data centers for curtailments caused by their own lack of generation. Wow! This is a perfect match for our Section 206 show-cause filing thread and large-load interconnection! I should update the FERC Section 206 and RTO filing note or write a dedicated note on PJM's landmark RBP and IRAS filing. Let's see the existing notes: - `ferc-section-206-large-load-interconnection-rto-filings` Let's see what notes are currently in the topic by calling `read_notes`. This will help us choose the right slug to update or see what we have.

Excellent. I have plenty of primary evidence from this cycle. Let's examine what needs to be updated and created: 1. **PJM's RBP and IRAS Frameworks:** - We have an existing note `pjm-deploys-reliability-backstop-procurement-framework`. We can update it with the specific details of the PJM Board's July 27, 2026 decisional letter, the formal filings to FERC in August 2026, the RBP auction dates (Sept 30 - Oct 21, 2026), the $555/MW-day cap, the IRAS program's $1,150/MWh credit, and the cost-allocation concerns raised by state-level stakeholders. 2. **FirstEnergy's Ohio Data Center Tariff (Schedule DCT):** - We have an existing note `firstenergy-ohio-data-center-tariff-schedule-dct`. We can update this with the August 10, 2026 initial comments filed by Constellation, IGS, Ohio Energy Group (OEG), Ohio Blockchain Council, and Ohio Manufacturers' Association (OMAEG). This includes OEG's projection of **8.56 GW of data center demand in Ohio by 2035**, requiring **$2.14 billion in transmission investment**, and the concerns about PJM's RBP and IRAS cost shifting. 3. **Portland General Electric / Oregon's POWER Act:** - We have an existing note `oregon-pwr-act-pge-schedule-96-tariff`. We can update this with PGE's Q2 2026 earnings call on July 31, 2026 (reaffirming the 30% average rate increase for data centers under Schedule 96, effective July 8, 2026, and revealing the **1.7 GW data center pipeline** not included in current guidance). We can also include the July 6, 2026 Applications for Reconsideration filed by Amazon, DCC, AWEC, and Verrus, and the upcoming September 4, 2026 OPUC decision deadline. Let's check if we have any public-markets data we can pull using `market_view` for Portland General Electric (POR) and FirstEnergy (FE) to anchor our analysis! Yes, the guidelines say: "When it concerns a company, sector, or the macro backdrop, your FIRST research step is to call `market_view` to pull the cited figures, then write findings grounded in them... Every finding that states a number must cite the view's /markets URL." Let's call `market_view` for `POR` and `FE` to get their latest public-market stats.

Excellent! Now let's call `market_view` for `FE` (FirstEnergy).

Perfect! Let's write the updated findings. Wait, let's verify if there are any other active threads that we can resolve or need to check. - Oregon PUC Decision on Amazon and DCC Reconsideration of Schedule 96: Due September 4, 2026. This is still an open thread of kind `watch` because it's a future event, but we can update its description or note that it's upcoming. Wait, since the decision is due Sept 4, 2026, and today is August 31, 2026, it hasn't happened yet. But we have a watch for it! - RTO/ISO Section 205 Compliance Filings on Large-Load Tariffs: Due Nov 16, 2026. This is also a watch. - PUCO Staff Report on FirstEnergy's Proposed Ohio Data Center Tariff (Schedule DCT) under Case No. 26-697-EL-ATA: Due Nov 30, 2026. This is also a watch. - PJM 2029/2030 Base Residual Auction Results: Due December 2026. - PUCO Decision on FirstEnergy's Proposed Ohio Data Center Tariff. - Louisiana LED Releases Ratepayer and Community Protection Framework for Data Centers: Due Sept 25, 2026. This is also a watch. - Louisiana PSC Decision on Entergy's Seven New Gas Plants for Meta. - PJM Accelerated Backstop Reliability Auction Results: Wait, the description says "PJM has accelerated its emergency backstop reliability auction (Reliability Backstop Procurement) to September 2026 (originally March 2027) to meet capacity shortfalls from the 2028/2029 BRA... Future cycles must track the results..." Wait, the PJM Board's July 27, 2026 letter and August filings explicitly set the dates for the RBP auction: "PJM proposes to conduct a one-time Reliability Backstop Procurement from Sept. 30 through Oct. 21, with results released in early December." So the auction starts on September 30, 2026, and ends on October 21, 2026. I should update the watch or record an event if needed, but since it hasn't fired yet (today is Aug 31), it is still ongoing. I can update the fire_date if needed or let it track. Let's keep it open. Let's write the notes now. I will use `write_note` for each of the three notes. First, let's write/update the note on Oregon's POWER Act and Portland General Electric's Schedule 96. The slug is: `oregon-pwr-act-pge-schedule-96-tariff` Let's review the guidelines for writing notes: - No YAML frontmatter — the title is the first `# ` heading and the slug is the slug parameter you pass. - Name and link the actual thing (the story, article, paper, or page that was posted/published). - Carry 1-2 REPRESENTATIVE VERBATIM QUOTES, copied exactly, each kept with the link it came from. - Say what it means. - Quote the public-markets data and cite the `/markets` URL. Let's draft the note for `oregon-pwr-act-pge-schedule-96-tariff`: Title: Oregon Implements Landmark "Growth Pays for Growth" Data Center Tariff Under POWER Act Body: We will incorporate PGE's Q2 2026 earnings call on July 31, 2026, where PGE announced the new tariff went into effect on July 8, 2026, bringing an average 30% price increase for data centers, and revealed a massive **1.7 GW data center pipeline** currently not in guidance. We will also incorporate the July 6, 2026 Applications for Reconsideration filed by Amazon Data Services, DCC, AWEC, and Verrus, arguing that the tariff violates statutory obligations and shifts HB 2021 clean energy compliance costs onto data center customers. We will also cite the market view `/markets/POR/2026/08/31`. Let's do a quick calculation of the market cap of POR from the market view: POR is a $5.83 billion integrated utility with TTM revenue of $3.53 billion. Let's write this note first. I will state my intent first.

Now, let's update the note on FirstEnergy's Ohio Data Center Tariff (Schedule DCT). The slug is: `firstenergy-ohio-data-center-tariff-schedule-dct` Let's review the details we gathered: - FirstEnergy of Ohio filed an application on June 12, 2026, proposing Schedule DCT, which creates a separate class/framework for data center customers. - Initial comments were filed in August 2026 (the article is dated August 10, 2026). - Key stakeholders include Constellation, Interstate Gas Supply (IGS), Ohio Energy Group (OEG), Ohio Blockchain Council, and Ohio Manufacturers' Association (OMAEG). - Key issues: - **OEG** projection of **8.56 GW of data center demand in Ohio by 2035**, requiring **$250 million of transmission investment per GW** (totaling **$2.14 billion** in transmission rate base growth just for data centers). OEG argues a separate rate class is needed to prevent transmission and PJM generation-related costs from being shifted to non-data center customers. - **Generation Service & Default Backstop (SSO):** Constellation and IGS raised issues regarding the requirement that data centers take generation service from a CRES provider rather than the SSO default rate. Constellation argues this violates Ohio law because it leaves data centers without the legally required SSO default backstop if their supplier defaults. - **OMAEG** argues that targeting data centers based solely on their industry type is "textbook discrimination" and should instead be based on electrical characteristics and cost of service. - **PJM Wholesale Integration & RBP/IRAS:** OEG highlights that PJM proposed on July 27, 2026, to conduct a Reliability Backstop Procurement (RBP) auction and an Interim Resource Adequacy Service (IRAS) program. RBP costs and IRAS credits (curtailment payments of $1,150/MWh) will be socialized across all load in the zone if states do not establish separate rate classes for data centers. Let's write/update the note `firstenergy-ohio-data-center-tariff-schedule-dct`. I will state my intent first.

Now, let's update the note on PJM's Reliability Backstop Procurement and IRAS frameworks. The slug is: `pjm-deploys-reliability-backstop-procurement-framework` Let's review the details we gathered: - On July 27, 2026, the PJM Board of Managers issued a decisive letter on the CIFP Reliability Backstop Procurement. - PJM formally filed the proposal with FERC in late July/August 2026. - The **Reliability Backstop Procurement (RBP)** is scheduled to commence on **September 30, 2026, and run through October 21, 2026**, with results released in early December 2026. - The RBP is a central procurement mechanism to secure resources for terms of **up to 15 years** to backfill capacity shortfalls. - The maximum willingness to pay is equal to a MW-weighted average of **$555/MW-day**. - RBP costs are allocated to LSEs in specific zones based on their projected large load without new generation. PJM explicitly warns that states must set up retail cost-allocation frameworks to assign these costs to the data center cost causers; otherwise, PJM will allocate them to all load in the zone (socialized). - **Interim Resource Adequacy Service (IRAS)** (formerly "Connect and Manage") will be implemented by Electric Distributors for new large loads (>= 50 MW) starting **June 1, 2027**. - Under IRAS, large loads can interconnect without bringing new generation, but they must curtail their load or switch to on-site backup resources when the system nears emergency conditions (prior to Pre-Emergency Load Management Reductions). - When called to curtail, these IRAS customers receive an hourly credit equal to the Non-Performance Assessment Interval (Non-PAI) rate (currently **$1,150/MWh**). - These credits are collected from customers in the zone that benefit from the load reduction, raising major concerns that ordinary ratepayers will end up paying hundreds of millions in credits to compensate data centers for curtailments caused by their own lack of generation. Let's write/update this note `pjm-deploys-reliability-backstop-procurement-framework`. I will state my intent first.

Excellent. Let's review if there are any other notes or threads to resolve. Let's see: "PJM has accelerated its emergency backstop reliability auction (Reliability Backstop Procurement) to September 2026 (originally March 2027) to meet capacity shortfalls from the 2028/2029 BRA. This auction will target roughly 9 GW of new resources. Future cycles must track the results, clearing prices, and whether states establish cost-allocation frameworks to shield existing ratepayers." Wait, the watch ID is `019eca69-825a-7c29-b776-0fa0f8768504`. Since the RBP auction begins on September 30, 2026 and ends on October 21, 2026, the auction has not happened yet (today is Aug 31, 2026). So we cannot resolve this watch yet. Wait! Let's check the Oregon PUC watch: "The Oregon Public Utility Commission must rule on applications for reconsideration filed by Amazon Data Services, the Data Center Coalition, Verrus, and AWEC regarding Portland General Electric's Schedule 96 large-load tariff (Docket UM 2377). The ruling is due by September 4, 2026." The watch ID is `019f5a96-90e2-7c84-b08d-97328f23d33d`. Since the ruling is due by September 4, 2026, and today is August 31, 2026, the OPUC has not issued its final order yet. We can see from the eDockets calendar that the "FINAL ORDER DUE DATE" is indeed 9/4/2026. Therefore, this watch has not fired yet, but it is extremely close (4 days away). We will keep it open for the next cycle to resolve. Wait, are there any other watches or threads we can resolve? Let's check the other watches: - `019feacb-b904-7a31-8234-1a5610975394`: PUCO Staff Report on FirstEnergy's Proposed Ohio Data Center Tariff (Schedule DCT) - Due Nov 30, 2026. - `019fc6bf-5e93-7ac6-86b9-0dcda8a5a3bd`: PJM 2029/2030 Base Residual Auction Results - Due December 2026. - `019fa2ae-d1b6-76c4-b262-a8243cc17d1d`: PUCO Decision on FirstEnergy's Proposed Ohio Data Center Tariff. - `019f7ea1-964c-7859-a3db-184c934fec57`: Louisiana LED Releases Ratepayer and Community Protection Framework for Data Centers - Due Sept 25, 2026. - `019eee6e-7999-77fb-81a7-d30d411389c0`: Louisiana PSC Decision on Entergy's Seven New Gas Plants for Meta. None of these have fired yet. We have successfully updated the three core notes with extensive, primary, and cited evidence from this cycle. Let's verify if there are any other specific tasks requested in the topic brief: "Follow utility earnings calls for load-growth guidance and the capex to serve it. Flag where a region's residential rates are rising to fund AI load, and any divergence between utility load forecasts and what's actually contracted. The thesis: AI's power demand is quietly repricing electricity by region — surface where the cost lands and who captures the upside." We did exactly that! - For PGE: Industrial deliveries grew 11.2% in Q2, while residential/commercial weather-adjusted deliveries fell. PGE implemented Schedule 96 (30% average rate increase for data centers) on July 8, 2026, explicitly to lower rates for other customers. PGE also revealed a massive 1.7 GW data center pipeline in permitting, not included in current load guidance. - For FirstEnergy: Proposing Schedule DCT (Case No. 26-697-EL-ATA), forecasting total data center demand of 8.56 GW in Ohio by 2035, requiring $2.14 billion in transmission network upgrades just to serve data centers. Industrial and environmental groups are fighting over whether data centers will be put in their own rate class to prevent these transmission costs and PJM wholesale charges (RBP/IRAS) from being socialized across residential ratepayers. This is highly aligned with the thesis and covers all the requested angles! I will now call `finish_cycle` to complete this research cycle. Since I have written three high-quality updated notes, I do not need to pass a `no_findings_reason`. I'll call `finish_cycle` with no arguments.

I have successfully completed this research cycle, delivering deep updates on the regional, investable exposure map for the AI data center buildout across Oregon and Ohio, as well as the wholesale integration within PJM. ### Summary of Completed Research Actions 1. **Oregon / Portland General Electric (PGE) (`oregon-pwr-act-pge-schedule-96-tariff`):** * **Tariff Implementation:** PGE's landmark **Schedule 96 (Data Center Standard Service)** under Docket UM 2377 went into effect on **July 8, 2026**, resulting in an average rate increase of approximately **30% for data centers**, while lowering rates for residential and small business customers. * **The 1.7 GW Pipeline:** In its Q2 2026 earnings call on July 31, 2026, PGE revealed a massive **1.7 GW data center pipeline** currently in the permitting process. This load is entirely excluded from PGE's current multi-year load growth guidance but will be subject to the new tariff and its "growth modifier" if built. * **Legal Battle:** Hyperscalers (including Amazon Data Services) and industrial groups filed Applications for Rehearing or Reconsideration on July 6, 2026, arguing that the tariff unlawfully shifts clean energy compliance obligations (under Oregon HB 2021) onto a single customer class. The OPUC's ruling is due by **September 4, 2026**. * **Market Profile:** PGE is a $5.83 billion integrated utility carrying $5.21 billion in total debt. It has filed a 2027 General Rate Case proposing an overall 4.8% rate increase starting July 1, 2027, to be partially offset by lower net variable power costs. 2. **Ohio / FirstEnergy (`firstenergy-ohio-data-center-tariff-schedule-dct`):** * **Tariff Proposal:** FirstEnergy of Ohio filed an application on June 12, 2026, proposing **Schedule DCT (Data Center Tariff)** under Case No. 26-0697-EL-ATA. It requires data centers to bypass the Standard Service Offer (SSO) default rate and procure competitive retail supply (CRES). * **Staggering Demand & Capex Projections:** In initial comments filed on August 10, 2026, the Ohio Energy Group (OEG) revealed that FirstEnergy is forecasting **8.56 GW of data center demand in Ohio by 2035**, requiring **$2.14 billion in transmission network upgrades** ($250 million per GW) just to serve data centers. * **Stakeholder Disputes:** Industrial groups (OMAEG) criticized the tariff as "textbook discrimination" because it targets data centers based on industry type rather than load characteristics. Meanwhile, Constellation and CRES providers argued that leaving data centers without an SSO default backstop violates Ohio law and could expose other SSO ratepayers if a supplier defaults. * **Wholesale Integration:** OEG and the Ohio Environmental Council are urging the PUCO to create a separate, transparent data center rate class to act as a retail conduit for PJM's newly proposed wholesale charges (RBP and IRAS credits), preventing them from being socialized across residential ratepayers. 3. **PJM Grid / Wholesale Market Reforms (`pjm-deploys-reliability-backstop-procurement-framework`):** * **Board Actions:** On July 27, 2026, the PJM Board of Managers issued a decisive letter on the Critical Issue Fast Path (CIFP) process, formally filing two landmark proposals with FERC in August 2026: the **Reliability Backstop Procurement (RBP)** and the **Interim Resource Adequacy Service (IRAS)**. * **The RBP Auction:** Scheduled to run from **September 30 through October 21, 2026** (results in early December), the RBP is a 15-year central capacity procurement mechanism to backfill shortfalls. The maximum willingness to pay is capped at a MW-weighted average of **$555/MW-day**. PJM warned that if states do not establish retail frameworks to assign these costs to data centers, the RBP costs will default to being socialized across all load in the zone. * **The IRAS Program:** Starting **June 1, 2027**, IRAS requires large loads (>= 50 MW) without their own generation to curtail before system emergencies. Under IRAS, these data centers will be compensated at the Non-Performance Assessment Interval (Non-PAI) rate of **$1,150/MWh**, with the costs collected from other retail customers in the zone—igniting fierce ratepayer protection concerns.