Tafel Power

Who Holds the Fuel Risk?

Gas moved by $39 to $59 a megawatt-hour over three years. Where that lands is a drafting choice, not a market fact.

For infra funds · For developers · For utilities · For hyperscalers · large-load · project-economics · capital · procurement

Kris Narayanan · Tafel Power · August 16, 2026 · 3 min read


Here is that swing, machine by machine, at the Henry Hub prices the market actually printed between August 2023 and July 2026.

Fuel cost of one megawatt-hour across the Henry Hub range of the trailing thirty-six months, August 2023 to July 2026, at low $1.49, median $2.96 and high $7.72. Combined cycle H class 2x2x1 at 6,266 Btu per kWh runs $9 to $48, a $39 swing. Combined cycle H class 1x1x1 at 6,226 runs $9 to $48, a $39 swing. Simple cycle H class at 9,142 runs $14 to $71, a $57 swing. Simple cycle aeroderivative at 9,447 runs $14 to $73, a $59 swing. Whoever holds the pass-through absorbs the whole bar, and the less efficient the machine the wider the bar.
Heat rates are EIA design assumptions for new plants on a higher heating value basis, not realized performance. Henry Hub monthly spot from EIA. No forecast is implied. Analysis: Tafel Power.

Nobody gets to swap machines month to month. You buy one and you ride its whole bar. So the only question that matters is who is holding it.

That is not a market fact. It is a drafting choice, and the four structures read here made it four different ways. In one of the four, the public order does not state the answer.

Virginia put it in the tariff

Dominion's data center schedule was approved by the Virginia commission in November 2025. It covers generation, and sets a minimum generation charge at 60 percent of contracted demand alongside 85 percent for distribution and transmission.

So the generation sits inside the regulated relationship, not in a separate commercial contract. How much of a gas move reaches the customer, and how fast, depends on a recovery mechanism this analysis did not extract.

Ohio left it out of the tariff entirely

AEP Ohio's data center schedule looks like the same instrument. It is not, because of what it covers.

Schedule DCT applies to electric distribution service. Its demand charges are distribution demand charges. Customers under it buy their actual electricity somewhere else, either from the default standard service offer or from a competitive retail supplier they choose.

So the eighty-five percent ratchet everyone quotes secures the wires. The fuel is in a different contract, with a different counterparty, on different terms, and the tariff never reaches it. Read Ohio's schedule end to end and you have not learned who holds the gas.

The campus passed it to the tenant

Fermi's campus in the Texas Panhandle will buy its power from a generator building on site. Under a framework agreement entered August 11, 2026, Fermi will buy capacity at a fixed charge with gas costs treated as a pass-through. That capacity charge is passed through again, to Fermi's tenants. Management said the same of the fuel on August 13: "fuel costs are passed through to the tenant as well."

The tenant holds the whole bar. The machine sets the width of the bar, and under the framework the generator intends to finance, build, own and operate the plant. A simple-cycle aeroderivative swings $59 where a combined cycle swings $39, so the choice of machine sets how much gas price risk passes through.

Louisiana's order does not state it

The Louisiana commission accepted a settlement for a large customer in August 2025. The order names the instruments it used: an electric service agreement, minimum monthly charges with a true-up, contribution in aid of construction agreements, parent guaranties, credit insurance and collateral, and an early termination fee.

Correction, September 25, 2026: an earlier version left minimum monthly charges out of this list and said the commission approved the settlement. The order accepts it, and names minimum monthly charges with a true-up.

The order states no magnitude for any of them and does not state where the fuel sits. It records that the utility did not seek approval of the agreements themselves. The public order does not answer the fuel question.

What to take from it

Two of those four answers are not in the document you would be handed first.

Where the fuel sits
Dominion VirginiaInside the tariff. Recovery mechanism not extracted
AEP OhioOutside it. The schedule covers distribution service only
The Fermi campusWith the tenant, by pass-through
Entergy LouisianaNot stated in the order

A price per megawatt-hour tells you none of this. Before comparing one price to another, find out which document the fuel lives in. In half of these it is not the one in front of you.

The four structures read in full, with the ledger of every instrument and all sources, are in the record. The companion analysis on what these contracts set their minimums against is Fifty Percent of What?.


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Questions, corrections or disagreement on any of this are welcome: kris@tafelpower.com

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