# CCI-01 Statewide Enforcement Package

Status: Public negotiation packet · not an executed agreement

The statewide packet turns the public CCI-01 idea into a contract and operating architecture that every required party can inspect, negotiate and complete without pretending that Data Center Direct creates governmental or utility authority.

> Data Center Direct does not manufacture authority. It connects existing or voluntarily contracted authority through an auditable, deterministic enforcement protocol.

## Architecture

1. Enumerated commitment
2. Independent evidence
3. Notice and cure
4. Authorized public decision
5. Bounded operator execution
6. Independent effect verification
7. Technical failure procedure
8. Public Full Stop decision
9. Serving-utility procedure
10. Verified restoration

## Authority map

### Existing authority

**A serving utility enforces its own approved rules and customer contract.**

That does not make a county vote or a Data Center Direct certificate an automatic utility default.

### Contractually creatable

**The operator accepts a narrow endpoint, agreed operating states, evidence gates, cure rights and restoration conditions.**

The schedule must be signed, site-specific and accepted by qualified engineering and legal reviewers.

### Contractually creatable

**Data Center Direct verifies a complete authorization package, transmits only an allowlisted command and records the result.**

Data Center Direct does not decide legal breach, public policy, electrical safety or utility action.

### Unresolved until negotiated

**A Failure Certificate becomes a defined event in the actual customer-utility agreement.**

The serving utility must accept the rider, interface, notice, safety and restoration procedure.

### Rejected

**A county or Data Center Direct directly operates utility, electrical, cooling or general facility controls.**

Those controls remain with the operator and serving utility.

## Georgia Power, EMC and municipal paths

### Georgia Power is one branch, not the statewide default.

The Georgia Public Service Commission fully regulates Georgia Power but describes more limited jurisdiction over electric membership corporations and municipal systems. The statewide standard therefore needs a utility-neutral adapter.

### Large-load contracts already receive special treatment.

The Commission’s January 2025 rule permits specialized terms for new Georgia Power customers above 100 MW and requires those contracts to be submitted for Commission review. That creates a serious negotiation path; it does not pre-approve a CCI trigger.

### Utility enforcement is not automatic.

Georgia Power’s published rules contemplate discontinuance after due notice for a customer contract or rule violation. A CCI Failure Certificate is not such a violation unless the parties make it one through accepted contract language.

### Restoration belongs in the same agreement.

The utility procedure must specify notice, safety, exception handling, reconnection and restoration before any Full Stop backstop is represented as available.

### Utility adapters

- **Georgia Power adapter.** Customer-service rider, Commission review path, utility-owned notice and operating procedure, authenticated referral method, exception notice and reconnection conditions.
- **EMC adapter.** Actual cooperative, tariff and service agreement, board or staff authority, accepted interface, load-management options, notice, safety and restoration.
- **Municipal adapter.** Actual city utility, governing ordinance and service agreement, authorized decision maker, accepted referral channel, operating limits and restoration.

### Worked Georgia cases

#### Project Camellia / Effingham County

Status: Georgia Power branch identified; CCI rights not established

The public record identifies Georgia Power and a large flexible-load arrangement. The substantive 3,210 MW service contract is confidential, so no public source establishes that CCI-01, a Data Center Direct command or a Full Stop referral is part of it.

#### QTS / Fayette County

Status: Serving utility not established in the reviewed public record

Local project agreements and recurring verification relationships may provide attachment points. A utility-specific backstop must remain unclaimed until the actual provider and operative service documents are verified.

## Example: recurring nighttime noise

**Illustrative only. This does not assert a threshold, violation or enforcement event at an actual facility.**

1. **Report the pattern.** Resident. The complaint records when, where and how the recurring concern is experienced. A complaint opens review; it does not activate a remedy.
2. **Test the agreed standard.** Independent verifier. Calibrated measurements, weather, source attribution and uncertainty are checked against the signed noise schedule.
3. **Stop or proceed.** Evidence gate. If the evidence does not establish a breach, the finding is published and the enforcement path stops. If it does, the operator receives the complete evidence.
4. **Correct or challenge.** Operator. The operator uses the agreed cure period to fix the condition or challenge invalid evidence through the defined review process.
5. **Choose only an agreed consequence.** Authorized public body. If the breach remains, the named body may authorize only a remedy already tied to that commitment and supported by the agreement.
6. **Validate and transmit.** Data Center Direct. The platform checks the signed authorization package and sends only the allowlisted site state. It cannot improvise a command or roam facility controls.
7. **Verify the result.** Independent verifier. Observed conditions determine whether the required state was achieved and whether the community impact was actually corrected.
8. **Record technical failure without guessing intent.** Failure branch. After the proposed transmission and technical-cure procedure, an unverified required state produces a factual Failure Certificate—not an accusation of refusal.
9. **Consider Full Stop only if it exists.** Public body and utility. The public body may hold the agreed transparent proceeding. The serving utility acts only if it accepted the rider and then only through its own procedure.
10. **Restore by rule.** Operator and verifier. Verified correction, documented authorization and the prewritten safe-return procedure end the remedy and preserve the public record.

## Agreement stack

1. **DCD Enforcement Standard.** Common meanings, evidence gates, certificate formats, security, audit records and branch behavior.
2. **Community Commitment and Enforcement Agreement.** The binding parties, authority, obligations, remedies, review rights, beneficiaries and enforcement forum.
3. **Operator Control Schedule.** The site-specific endpoint, protected loads, operating states, ramps, duration, event budget, safety deferral and restoration.
4. **Utility Backstop Rider.** The actual serving utility’s accepted trigger, authentication, notice, exception, operating and reconnection process.
5. **Data Center Direct Services Agreement.** Platform scope, evidence handling, cybersecurity, fees, intellectual property, confidentiality, liability and termination.

## Security and failure

- Two authorization domains: the public authorization credential and Data Center Direct execution credential are both required.
- A fixed, allowlisted command set with short-lived, signed and idempotent messages.
- No general-purpose access to the operator’s BMS, SCADA or utility controls.
- Protected, attributable logs for the authorization, transmission, acknowledgment, observation and certificate.
- A safety deferral documents the actual hazard and safe alternative; it does not erase the underlying event.
- A Failure Certificate states technical facts and does not claim motive, refusal, liability or entitlement to utility action.

## Negotiation checklist

- [ ] Name the actual owner, operator, compute customer, public entity, serving utility, verifier and authorized signers.
- [ ] Identify the legal or contractual source for every public-party action.
- [ ] Define each commitment, metric, receptor, limit, attribution method, uncertainty rule and evidence source.
- [ ] Select and fund the independent verifier; document qualifications, conflicts, replacement and dispute procedures.
- [ ] Match every remedy to the impact and define caps, security, duplicate-recovery rules and the exact stopping condition.
- [ ] Complete the operator’s signed technical schedule and independent engineering acceptance.
- [ ] Verify the actual serving utility before drafting the utility-specific backstop.
- [ ] Define the accepted utility interface and what happens if the utility says no, not yet or unsafe.
- [ ] Write restoration, assignment and successor obligations before commissioning.
- [ ] Run a witnessed end-to-end test before describing any Kill Switch or Full Stop as operational.

## Official starting points

- [Georgia PSC: January 2025 large-load rule](https://psc.ga.gov/site/assets/files/8617/media_advisory_data_centers_rule_1-23-2025.pdf)
- [Georgia PSC: electric regulation and supplier choice](https://psc.ga.gov/utilities/electric/)
- [Georgia PSC: data-center fact sheet](https://psc.ga.gov/site/downloads/datacenterfactsheet.pdf)
- [Georgia Power: rules and regulations](https://www.georgiapower.com/business/rate-plans-tariffs.html)

## Status boundary

CCI-01 is a nonbinding proposal-development tool. Completing, generating, downloading or sharing a draft does not establish governmental authority, create a contract, waive immunity, confer enforcement rights, appoint an official or verifier, or obligate any county, authority, operator, owner, compute customer, utility or Data Center Direct. Any binding arrangement requires separate negotiation, site-specific legal authority, duly authorized written execution, completed technical, financial, evidence, emergency and enforcement schedules, and all applicable regulatory and engineering approvals.

- [Human-readable package](https://www.datacenterdirect.ai/county-kill-switch/package)
- [Public CCI-01 overview](https://www.datacenterdirect.ai/county-kill-switch)
- [Structured JSON](https://www.datacenterdirect.ai/ai/county-kill-switch-package.json)

- [Complete research packet](https://www.datacenterdirect.ai/documents/cci-01-statewide-enforcement-master-package.md)

