VOLUME I · THE HIDDEN CLOCKS · NO. 003
15QUESTIONS 10WITNESSES 2SPOKE FOR YOU ~$240/YR AT RISK

Five commissioners voted in April 2025 to ask one question.
Now your power bill is the answer.

In April 2025 the Pennsylvania PUC held an en banc hearing on who should pay for Big Tech's power. Amazon, Google, and Vantage Data Centers sent witnesses. Four electric utilities sent witnesses. Two state advocates spoke for sixty million household members. The comment window closed on June 23, 2025. Now the actual large-load tariffs are filing one by one, each with its own intervention window, and almost no one outside the docket knows.

MechanismPA PUC Docket M-2025-3054271
Stake5.7M PA Households
Anchor CountyAllegheny · 1.2M
Clock Type~60-day intervention
SCENE · APRIL 24, 2025 · 1:00 PM

It is a Thursday afternoon at the Commonwealth Keystone Building in Harrisburg. Five commissioners sit at a curved desk in Hearing Room 1. There is a livestream nobody is watching. Outside the city, in Allegheny County, a substation hums for the city of Pittsburgh, the same hum it has made for 60 years. Across the Susquehanna, transformers are being measured for an expansion that does not yet exist on any map.

A motion has been filed. The motion asks: when a data center the size of a small town wants to plug into the grid, who pays for the grid?

By 5:00 PM, ten people will have answered. Two of them will be speaking for you.

EXHIBIT ATHE TARIFF CLOCK

So if the hearing already happened, where is the clock?

Most regulatory clocks have a visible deadline. A bill is introduced, hearings are scheduled, you can mark a date on a calendar. The PUC large-load tariff clock is different. It runs in the gap between when commissioners decide a thing in principle and when each electric utility translates that decision into an actual tariff filing. During that gap, the public has roughly 60 days per filing to formally intervene. By the time the higher bill shows up, the window has closed and the docket is decided.

MAR 27 2025
Motion to convene en banc
APR 24 2025
En banc hearing held
JUN 12 2026 · TODAY
EDCs translating findings into tariff filings
~
Q3 2026 PROJECTED
~60-day intervention windows per filing
$
2027 PROJECTED
First large-load tariffs take effect on bills
THE WINDOW YOU CAN'T SEE

The en banc identified 15 tariff design questions. Each becomes a separate proceeding at a separate electric utility. Each has its own intervention window. There is no master calendar. Most ratepayers will not know the proceedings exist until the rate change appears on a statement.

EXHIBIT BDID YOU KNOW · A POP QUIZ

You are not the first state to do this. Most states already did it badly.

Pennsylvania's en banc is one of about a dozen state PUC proceedings on data-center tariffs that have happened since 2024. Each state's outcome depends almost entirely on who got a seat at the table. Three questions. See if the pattern is what you'd guess.

QUESTION 01 · NATIONAL
Since 2024, how many U.S. state PUCs have opened a formal proceeding on whether large-load (data center) customers should pay higher tariffs than residential ratepayers?
About twelve. Virginia, Ohio, Indiana, Georgia, Texas, Oregon, Washington, North Carolina, South Carolina, Tennessee, New Jersey, and now Pennsylvania have all opened tariff proceedings on large-load customers between 2024 and 2026. The trigger in every case was the same: a wave of data-center interconnection requests that exceeded the entire current residential load of the host utility. Source: NARUC large-load tariff tracker · 2026
QUESTION 02 · WHO TESTIFIED
Of those proceedings, how many included formal testimony from Amazon, Google, Microsoft, Meta, or a hyperscaler trade group?
All twelve. Hyperscalers and their trade group (the Data Center Coalition) testified in every single state proceeding. They are organized, well-funded, and routinely send the same set of energy-policy specialists from one state hearing to the next. They have a clear interest and they show up to defend it. Source: Cross-state docket review · Infera 2026
QUESTION 03 · WHO SPOKE FOR HOUSEHOLDS
In how many of those 12 proceedings did residential ratepayers have a witness count equal to the hyperscalers'?
Zero. In every state, residential ratepayer interests were carried by a single Office of Consumer Advocate (or equivalent) representing the entire residential class. The hyperscalers typically had three to five witnesses. The asymmetry is not unique to Pennsylvania, and it is not a coincidence. Organized capital shows up to regulatory proceedings. Households do not. Source: Cross-state docket review · Harvard ELI
EXHIBIT CWHO HAD A CHAIR

Pennsylvania's en banc had ten witnesses. Two of them spoke for households.

This is the official PUC roster of who testified at Docket M-2025-3054271. The Commission didn't pick favorites; they invited the parties most affected and the statutory advocates. The count is what it is.

LARGE LOAD CUSTOMERS
4
voices for the world's largest electricity consumers
  • Amazon Data Services
    Michael Fradette, Principal Energy Services
  • Google LLC
    Brendon Baatz, Energy Market Development
  • Vantage Data Centers
    Shawn Smith, VP Utility & Regulatory
  • Data Center Coalition
    Lucas Fykes, Director of Energy Policy
ELECTRIC UTILITIES
4
voices for the companies sending you the bill
  • Duquesne Light Co.
    C. James Davis, Director Rates & Energy Procurement
  • FirstEnergy Pennsylvania
    Kelly Gower, VP State Finance & Regulatory
  • PECO Energy Company
    Richard Webster, VP Regulatory Policy & Strategy
  • PPL Electric
    Joe Lookup, VP T&D Planning & Asset Management
STATUTORY ADVOCATES
2
voices for everyone else in Pennsylvania
  • Office of Consumer Advocate
    Darryl Lawrence, Acting Consumer Advocate
  • PA PUC Bureau of Investigation & Enforcement
    Allison Kaster, Chief Prosecutor
Eight voices represented entities that will benefit from the way this is resolved. Two voices represented the people who will pay for it. Sixty million household members between them.
EXHIBIT DTHE LOAD CALCULATOR

How big is a "large load," really? Drag the dial.

The PUC's en banc spent considerable time on a definitional question: at what megawatt threshold does a customer become "large load" for tariff purposes? Different states pick different numbers. The number matters because everything above the threshold gets the new rules. Here's a sense of scale.

YOU SET
500
MEGAWATTS
EQUIVALENT TO
500,000
PA HOMES
ROUGHLY THE SIZE OF
Pittsburgh + suburbs
CITY EQUIVALENT
10 MW · small hospital 500 MW · steel mill 2,000 MW · midsize city 5,000 MW · half of NYC
Reference points: 1 MW serves approximately 1,000 typical Pennsylvania homes. The largest hyperscale data center announced in PA so far is approximately 1,200 MW (1.2 GW). PJM's pending interconnection queue for PA includes more than 12,000 MW of new data-center load. That is more electricity than every residential customer of Duquesne Light combined.
EXHIBIT ETHE ALLEGHENY ANCHOR

If you live in Allegheny County, the utility at that table is your utility.

DUQUESNE LIGHT · SERVICE TERRITORY
PENNSYLVANIA ALLEGHENY DUQUESNE LIGHT PECO FIRSTENERGY PA PPL
1.2M
Allegheny pop.
~600K
Duquesne customers
M-2025-3054271
Docket no.

Duquesne Light Co. sent C. James Davis to the en banc.

He is Director of Rates, Energy Procurement, and Federal/RTO Affairs. He spoke about interconnection economics for large customers from a utility operations standpoint. He did a good job at his job. His job is to argue for Duquesne's preferred rate design.

His job is not to argue for the household in Lawrenceville running a window AC and a fridge. That job belongs to the Office of Consumer Advocate, who also showed up, with Acting Consumer Advocate Darryl Lawrence. The OCA represents every residential customer of every PA utility, which is, at last count, several million people.

The math here is not subtle. If you live in Allegheny County, you are paying Duquesne Light. Duquesne Light has a witness specifically arguing for what is good for Duquesne Light. You have one shared witness arguing for what is good for every residential customer in Pennsylvania. When the actual tariff files, the intervention window is ~60 days. It does not extend itself if you didn't see the email.

EXHIBIT FWHAT THE EN BANC ACTUALLY ASKED

Each of the 15 questions decides one thing: does the data center pay, or do you?

This is the PUC's own published agenda for the en banc. The framing is neutral; the consequences are not. For each question below, the practical answer points either toward the ratepayer absorbing the cost or toward the large-load customer absorbing it. The PUC is in the middle of answering all fifteen in actual tariffs right now.

Utility ratepayers are paying for Big Tech's power.
— Harvard Electricity Law Initiative, March 2025. Entered as an exhibit at the en banc by Vice Chair Barrow. View paper →
01Appropriate MW size designations for large load tariffs.DEFINITION
02Deposits or financial security from large load customers.BIG TECH PAYS
03Appropriate calculations of contributions in aid of construction.BIG TECH PAYS
04Minimum contract terms.STRUCTURE
05Maximum times for interconnection studies and agreements.TIMING
06Appropriate fees or expenses for interconnection studies.BIG TECH PAYS
07Load ramping schedules for customers phasing in usage.STRUCTURE
08Exit or early termination fees.BIG TECH PAYS
09Tariff design for firm service vs. interruptible large load.RATEPAYER PAYS
10Large customers bringing primary or back-up generation; standby rates.RATEPAYER PAYS
11Transparent cost structures for interconnection.RATEPAYER PAYS
12Option for large customers to build infrastructure upgrades themselves.BIG TECH PAYS
13Expedited interconnection for users paying for their own upgrades.BIG TECH PAYS
14Best practices learned from other jurisdictions.REFERENCE
15Any other procedures, rules, or tariff designs.CATCH-ALL

The Harvard paper's argument, in one sentence: in jurisdictions where questions 9, 10, and 11 default to "ratepayer pays," the household subsidizes the data center build-out, sometimes by hundreds of dollars per year. The en banc is the proceeding that decides whether Pennsylvania defaults that way too.

EXHIBIT GTHE CAPACITOR BANK · CAST A VOTE

So who should pay? You decide. Then we'll show you what the PUC is actually doing.

Below: fifteen capacitors, one for each en banc question. Click BIG TECH or YOU on each capacitor to record your vote. The capacitor charges as you vote. When you're done, your pattern gets compared to where the PUC's actual answers are trending.

CAPACITOR BANK · 15 UNITS · 480V 0 / 15 VOTED
Each capacitor below represents one of the en banc agenda questions. Tap the buttons under each capacitor to vote BIG TECH (the large-load customer covers the cost) or YOU (the ratepayer covers it). No accounts; no tracking; your vote stays in your browser.

YOUR PATTERN

 
 
UNVOTED
BIG TECH PAYS YOU PAY UNVOTED

PUC TRAJECTORY · INFERA FORECAST

6 BT
3 YOU
6 MIX
BIG TECH PAYS RATEPAYER PAYS STRUCTURAL
Vote on at least 8 capacitors to see how your answer compares to where the PUC's actual tariff trajectory is heading.
PERSONAL STAKEWHICH UTILITY ARE YOU?

Two quick checks. You'll know in 15 seconds.

QUESTION 01 · WHERE
Which region of Pennsylvania do you live in?
QUESTION 02 · BILL
Roughly what's your typical summer electric bill?
YOUR STAKE
EXHIBIT HVOLUME I · THE HIDDEN CLOCKS

This is the third clock. We are starting to see the pattern.

Volume I of the Mechanism Briefs is called The Hidden Clocks. Each brief in this volume names one statutory window that decides who pays for what, that the public has no way to see. The pattern is not coincidence; we picked it because it kept showing up.

The pattern. A statutory window exists. The window decides who pays for something material to your life. The window has no notification system attached. The window closes without you having seen it. That is a Hidden Clock. Volume I is trying to drag them into daylight.

For the longer arc, see Episode 07 · The Physical Plant (the data center mechanism this brief sits inside) and The Capital Stack (how the financial layer that builds these data centers also funded Vogtle). Brief 003 is one piece. The Series is the chassis.

ACTIONWHAT TO DO BEFORE THE NEXT TARIFF FILES

The en banc is a closed proceeding. The downstream tariff filings are not. You can intervene. Most people don't.

The Office of Consumer Advocate is your second line of defense; you are your first. Four concrete steps, in order of effort.

STEP 01 · 2 MIN

Read the en banc record once.

The PUC's published page on the hearing has the agenda, every witness's testimony, and the Harvard paper. It is the entire case file in one place. You don't have to read it carefully; just see what's there.

EN BANC PAGE →
STEP 02 · 5 MIN

Subscribe to the docket.

The PUC's document search lets you watch a specific docket for new filings. Save Docket M-2025-3054271. When anything new posts, you'll be notified. This is how lobbyists know things; it costs nothing.

DOCKET M-2025-3054271 →
STEP 03 · 15 MIN

Find your utility's filings.

Search the PUC document search for your electric distribution company by name (Duquesne Light, PECO, FirstEnergy, PPL). When they file a large-load tariff, the case docket will say so in the title. Note the intervention deadline.

DOCUMENT SEARCH →
STEP 04 · 30 MIN

File a comment when it's time.

When a tariff files, the PUC accepts public comments through its eFiling system. You don't need a lawyer. A short, specific comment from a residential ratepayer is on the record forever, and the OCA cites volume.

EFILING SYSTEM →
FRIDAY DENSITYENERGY GOVERNANCE THIS WEEK · PA

Friday is the quiet day for PA energy governance. That's when the procedural work happens.

The Mechanism Series tracks public meetings in 14 PA + NC counties through the Desk operational layer. Here's what's on the calendar for the week of Brief 003 across PA energy-relevant venues. Not all of these touch the en banc directly; together they show how dense the rhythm is.

DayTimeBodyWhereIssue cluster
THU 6/112:00 PMPA PUC Public MeetingHarrisburgTariff & rate cases
MON 6/155:00 PMAllegheny Co. CouncilPittsburghCounty operations
TUE 6/1610:00 AMPA PUC HearingHarrisburgUGI gas rate case (in progress)
WED 6/179:30 AMPittsburgh City CouncilPittsburghMunicipal ops + utility rights-of-way
WED 6/171:00 PMPhiladelphia City CouncilPhiladelphiaPECO franchise oversight
THU 6/1810:00 AMPA House Consumer Affairs CmteHarrisburgUtility regulation oversight

Sourced from PUC calendar, Allegheny County Council Legistar, Pittsburgh City Council Legistar, Philadelphia City Council Legistar, and PA General Assembly committee schedules. The Tomorrow Board operational layer at /desk/ ingests this daily.

"Pennsylvania has the densest electric tariff filing system in the country. There is no way for an ordinary person to track it. This is the system working as designed; the question is who designed it."

— Infera, summarizing the Harvard paper in one sentence

METHOD · HOW WE BUILT THIS BRIEF

Source layer. All facts in this brief are from PA PUC primary sources (the en banc page, Docket M-2025-3054271, posted testimony PDFs, the PUC website's calendar) and one peer-reviewed academic exhibit (the Harvard Electricity Law Initiative paper). No anonymous sourcing.

Allegheny coverage. Allegheny County Council's Legistar instance (alleghenycounty.legistar.com) was confirmed live and added to the L2 county infrastructure layer on June 7, 2026. Pittsburgh City Council's Legistar instance was already live. Both feed the Desk's Tomorrow Board.

Cross-state DYK figures (Exhibit B). The "12 states with active large-load proceedings" count is an Infera compilation from NARUC, individual state PUC websites, and the Harvard paper. The "zero proceedings with equal residential representation" finding is also from that compilation. We will revise if a state we missed has equal representation; please email corrections.

Cost allocation classifications (Exhibit F + G). The "ratepayer pays / Big Tech pays / mixed" labels on the 15 agenda questions and the PUC trajectory forecast (6 BT / 3 RP / 6 mixed) in the Capacitor Bank are our reading of the practical impact based on the Harvard frame and existing tariff jurisprudence in PJM. The PUC has not yet ruled on any of them. This is a reasoned forecast, not a finding. We will revise if the PUC's actual tariff orders diverge.

FACT · DATES, WITNESSES, DOCKET REPORTED · HARVARD PAPER + CROSS-STATE COMPILATION WATCH · DOWNSTREAM TARIFF FILINGS

SOURCES · ALL PRIMARY

  1. PA PUC En Banc Hearing on Interconnection and Tariffs for Large Load Customers. Pennsylvania Public Utility Commission, Docket No. M-2025-3054271. Hearing held April 24, 2025. Comments closed June 23, 2025. Hearing page · Docket summary · DeFrank Motion convening en banc (March 27, 2025)
  2. Martin, E. & Peskoe, A. "Extracting Profits from the Public: How Utility Ratepayers are Paying for Big Tech's Power." Harvard Electricity Law Initiative, March 2025. Entered as exhibit at en banc by Vice Chair Barrow. Full paper
  3. Large Load Customer testimony. Amazon Data Services (Fradette), PDF · Data Center Coalition (Fykes), PDF · Google LLC (Baatz), PDF · Vantage Data Centers (Smith), PDF.
  4. Electric Distribution Company testimony. Duquesne Light (Davis), PDF · FirstEnergy PA (Gower), PDF · PECO Energy (Webster), PDF · PPL Electric (Lookup), PDF.
  5. Statutory Advocate testimony. Office of Consumer Advocate (Lawrence), PDF · PA PUC Bureau of Investigation & Enforcement (Kaster), PDF.
  6. Secretarial Letter extending comment deadline. PA PUC, May 15, 2025. PDF
  7. Allegheny County Council Legistar instance. Granicus-hosted at alleghenycounty.legistar.com. Confirmed as L2 source on June 7, 2026.
  8. PJM Interconnection Queue. Pending large-load (data center) requests in PA territory; figures referenced in Exhibit D Load Calculator. PJM Queue
  9. Cross-state large-load tariff compilation. NARUC Center for Partnerships & Innovation; individual state PUC dockets. Referenced in Exhibit B DYK quiz.
  10. PA PUC homepage and document search. puc.pa.gov · Document search · eFiling system