Getting Power in Texas: ERCOT Large-Load Interconnection, SB 6 and Batch Zero Explained

Who grants power in ERCOT: the utility, ERCOT or the PUCT?

The utility (TSP/DSP: Oncor, CenterPoint, AEP Texas, TNMP, co-ops, munis) takes the request, signs the agreements, invoices interconnection costs and builds the wires. ERCOT runs the system studies, allocates capacity through Batch Zero and approves energization. The PUCT writes the rules — 16 TAC §25.194, adopted September 18, 2026, effective October 8 (PUCT, Sep 2026) — and decides co-location cases; since August the governor has directed both the PUCT and TCEQ by letter. The rule covers any load with a non-coincident peak of 75 MW or more at one site, including expansions and co-located loads; the PUCT rejected industry carve-outs (White & Case, Sep 2026).

What are the three size classes, and which rules reach each?

Medium loads "are not affected by the pause," but non-energized computational requests of 25 MW or more got eligibility RFIs and medium loads got community-impact RFIs (ERCOT, Aug 20, 2026). Splitting a campus into sub-75 MW pieces fails on paper: the test is peak demand at a single site, and each request must disclose any "substantially similar" request elsewhere in Texas (White & Case). Hence 20–60 MW sites move first (Small Bespoke AI Data Centers).

What does Senate Bill 6 require, in plain English?

SB 6 took effect June 20, 2025 (Texas Legislature). For loads of 75 MW and more: a study fee of at least $100,000; officer-level disclosures of site control, backup generation and duplicate requests; curtailment protocols for loads interconnected after December 31, 2025; disclosure of backup able to serve 50% or more of load, which ERCOT may order run, or the load curtailed, in an emergency; a 4CP review with any change adopted by December 31, 2026; and a new demand-reduction service (NatLawReview, Jul 2025). Co-location gets a generator notice, a 120-day ERCOT study and 60 days at the PUCT (White & Case, Aug 2026). The money and refunds were left to §25.194.

How does the 75 MW process work, gate by gate?

For 100 MW the pre-study cash is $5.1 million (White & Case; Colocation Scout, Sep 2026). Security is charged on gross MW; co-located or backup generation does not reduce it. Batch Zero cash may roll into SLLIA security; IAs dated on or before June 1, 2025 keep their direct-cost terms (Colocation Scout). Refunds reward energizing on time:

• 20% back at initial energization; the remaining 80% in 20% tranches as minimum-billing milestones are met.
• Withdraw before the study, or get 0 MW: 100% back, less amounts owed.
• Withdraw after allocation: 20% of the security on allocated MW is forfeited.
• 24 months late, measured across the whole phased schedule: the utility reports the unused capacity to ERCOT within 30 days, draws what is owed, keeps 20% on the unused capacity and returns the rest.

What is Batch Zero, and what do Base, Studied and Excluded mean?

Read as text

• Batch Zero: 66.4 GW fixed, 302.2 GW waits for Batch 1
• ERCOT's provisional classification of about 735 large-load projects, September 3, 2026. Block widths are proportional to GW.
• 204 + 158 + 373 = 735 PROJECTS · PROVISIONAL · FINAL IN/OUT EXPECTED DECEMBER 2026
• BASE LOAD
• 66.4GW
• GW
• 204 projects
• Fixed. Energized or advanced enough; counts against capacity, not at risk.
• Fixed.
• STUDIED
• 127.9GW
• 158 projects
• No guaranteed allocation. MW may be cut by the steady-state and stability studies.
• No guaranteed allocation.
• EXCLUDED
• 302.2GW
• 373 projects
• Waits for the next batch. Batch 1 applications were expected in summer 2027 under pre-pause guidance.
• Waits for the next batch.
• DYNAMIC MODELS · ~18% · of 290 reviewed were acceptable on first pass; uncured models are removed
• TOP BASE-LOAD COUNTIES · Dallas · 5,713 MW · Harris · 5,672 MW · Haskell · 2,689 MW
• READY, BUT PAUSED · 6,608 MW · 17 loads fully processed, waiting on ERCOT's Aug 3 energization pause
• FINAL RESULTS · Apr 9, 2027 · The date on paper; ERCOT told its board on Sep 11 the study will not finish by then

Batch Zero is ERCOT's one-time batch study of large loads that met readiness criteria by mid-2026 (PGRR145/NPRR1325, approved June 2026). A process built for 40–50 large loads at a time (Lloyd Gosselink, Apr 2026) now sorts about 735 projects into three bins and allocates capacity by year (ERCOT, Sep 11, 2026; definitions per Texas Commercial Plans):

• Base Load — 204 projects, 66.4 GW: energized or advanced enough to be treated as fixed; counts against capacity, not at risk.
• Studied — 158 projects, 127.9 GW: no guaranteed allocation; MW can be cut by the studies.
• Excluded — 373 projects, 302.2 GW: held for the next batch.

Base load concentrates in Dallas (5,713 MW), Harris (5,672 MW) and Haskell (2,689 MW) counties; 11 projects are BYOG or WLPUN sites; nine depend on a future good-cause exception and the other conditional projects must cure dynamic-model data (ERCOT, Sep 11, 2026). Of 290 dynamic models reviewed, about 18% were acceptable on first pass; uncured models are removed (ERCOT, Aug 20, 2026).

On paper: classification August 7, provisional results September 3, final results April 9, 2027. ERCOT told its board on September 11 that the study will not be done by April 9; the pause's impact is "TBD" (ERCOT, Sep 11, 2026). Pre-pause guidance had allocation in spring 2027, commitments in Q2, a final transmission plan in fall 2027 and Batch 1 applications in summer 2027 (Utility Dive, Jun 2026); Oncor now expects project identification to slip past February 2027 (Sempra, Aug 2026).

Which pause applies to my project: ERCOT's August 3 or TCEQ's September 21?

ERCOT expects verification to take "several months, but less than nine" (Gibson Dunn, Aug 2026); BNEF puts 49.8 GW at risk of delay and $8–15 billion of revenue at risk by Q1 2027, "possibly as late as April" (POWER, Aug 2026). TCEQ's six conditions include absorbing all dedicated grid costs, lower residential bills and no water needed by communities (Office of the Governor, Sep 21, 2026; Troutman, Sep 2026; Bracewell, Sep 2026).

What hardware must a large load now install?

Ride-through. NOGRR282 (effective August 1, 2026): stay connected 2 seconds at 0.85 per-unit voltage, scaling to 150 ms below 0.35 pu; inrush no more than 150% at the POI; 90% consumption within 2 seconds of recovery; six sags in 90 seconds; about 18 GW of existing load exempt (ERCOT LLWG, Aug 21, 2026; ZeroEmissionGrid, Aug 2026). NERC counted 26 ERCOT large-load ride-through events in under three years. Mitigation: BESS, E-STATCOM or UPS.

Variation limits. A draft operating-guide revision would cap load swings at 10 MW per 5 seconds (ERCOT, Sep 17, 2026).

Curtailment. Loads interconnected after December 31, 2025 must install equipment for direct ERCOT curtailment in firm load shed; backup covering 50% or more of load must be disclosed so ERCOT can order it run, or the load dropped (NatLawReview, Jul 2025).

Can co-located or behind-the-meter generation get around the queue?

Partly, on hard terms. On July 24, 2026 the PUCT approved Docket 59220: Crusoe's 260 MW Load Two in Armstrong County (with Google; assigned to Ensign Infrastructure in March) behind the 265.5 MW Goodnight I wind farm. Terms: full disconnect within 30 minutes of an ERCOT instruction, curtailment sized to the meter rather than the generator, no compensation, no demand response, ancillary services or ERS, obligations binding successors, review at 36–60 months; with Load One (Docket 58881, 265 MW) the obligation is 525.5 MW (White & Case, Aug 5, 2026).

BYOG and WLPUN sites are a defined path — 11 are in Batch Zero — but on-site generation cuts grid draw, not security (ERCOT, Sep 11, 2026), and the TCEQ pause blocks the air permits an islanded plant needs (Bracewell). DFW and West Texas developers have made on-site gas the main workaround (Construction Owners, Jul 2026); see How Data Centers Are Powered.

How does it look utility by utility?

How long will it really take, 2026 to 2030?

The queue's history explains the pause: about 233 GW in December 2025, "almost 300%" above end-2024 (Utility Dive, Jan 2026); ~410 GW by March 26, 2026 (ERCOT, Apr 2026); more than 438 GW by June (Utility Dive, Jun 2026); ~474 GW by late July, more than five times the 91.1 GW record peak of July 22 (ERCOT, Jul 29, 2026; EIA, Aug 2026). Against that, about 2,168 MW was approved to energize in the twelve months to March 2026 (ZeroEmissionGrid, Mar 2026); BNEF expects 1.2 GW of ERCOT data center additions from Q2 2026 to Q1 2027 and ~17.2 GW installed by 2030 (POWER, Aug 2026). ERCOT publishes no duration for sub-75 MW loads; US norms run 12–24 months in emerging markets against a national average near four years (Construction Owners, Jul 2026).

For planning: a grid-served load of 75 MW or more in the base group sits on a 2028–2032 allocation calendar; a studied project may be cut; an excluded one waits for Batch 1. Oncor's 765 kV line energizes in December 2028; CenterPoint expects its 14 GW live by end-2030. A load under 75 MW on a substation with headroom is a utility conversation. Construction timing: Realistic Data Center Timelines; the full sequence: How a Data Center Is Built.

What should a developer do now?

1. Be Base-Load-shaped. ERCOT's evidence list: deed, lease or option; utility-confirmed security; long-lead equipment ordered 18 months out; notice to proceed; end-use customer confirmation; binding GC and substation contracts; CIAC paid (ERCOT, Aug 20, 2026).
2. Fix the dynamic model first; about 18% pass on first review, and PGRR144 adds model-quality testing (ERCOT, Sep 17, 2026).
3. Phase MW honestly. The 24-month trigger spans the whole schedule; a one-year slip, a 20% MW change or a moved point of interconnection is a disclosable material change (Colocation Scout).
4. Budget the stack: $100,000 plus $50,000 per MW at the IA, greater-of security at the SLLIA, non-refundable CIAC, minimum billing demand; generation reduces none of it (White & Case).
5. Carry a bridge, priced honestly. Co-location means 30-minute uncompensated curtailment and no DR, ancillary-service or ERS revenue (White & Case, Aug 2026); BYOG/WLPUN is a defined path; backup covering 50% of load can be ordered on; TCEQ permits for all of it are paused.
6. Design to NOGRR282 with BESS, E-STATCOM or UPS (ZeroEmissionGrid) and to the draft 10 MW per 5 s limit; keep 4CP in the model until the PUCT's December 31 decision (NatLawReview).
7. Give lenders what utilities ask for: signed facility-extension agreements with long-term end-user commitments (Utility Dive, Jul 2026) and collateral kept in place through the pause (White & Case).

What changes next: the calendar

Read as text

• Six dates by Dec 31; the 2027 dates are already slipping
• ERCOT
• TCEQ
• PUCT
• POLITICS
• Date on paper or pre-pause guidance
• Each card: what happens, then what it means for a project
• TODAY (OCT 14) → DEC 31: SIX DATES
• 2026 · REPORTS, A VOTE, A MEETING, A DEADLINE
• 2026
• Oct 19 · TCEQ
• Oct 19
• TCEQ compliance report on the permit pause
• FOR A PROJECT · Whether the permit pause narrows
• FOR A PROJECT
• Nov 1 · ERCOT
• Nov 1
• Quarterly stability assessment: 17 loads, ~6,874 MW (Q2-27)
• FOR A PROJECT · A required screen, not energization approval
• Nov 3 · ELECTION
• Nov 3
• ELECTION
• General election
• FOR A PROJECT · The directives' author is on the ballot
• KEY DATE
• Dec 10 · ERCOT
• Dec 10
• Verification and community-impact reports
• FOR A PROJECT · Final Batch Zero in/out; basis for lifting or extending the pause
• Dec 17 · PUCT
• Dec 17
• PUCT open meeting
• FOR A PROJECT · Expected action on the reports
• Dec 31 · PUCT · SB 6
• Dec 31
• PUCT · SB 6
• SB 6 deadline for any 4CP change
• FOR A PROJECT · Transmission cost exposure from 2027
• 2027 · THE STUDY AND THE NEXT BATCH
• 2027
• Jan 2027 · LEGISLATURE
• Jan 2027
• LEGISLATURE
• Legislature convenes; PUCT seeks broader authority; TAC on Batch 1 rules Jan 20
• FOR A PROJECT · New statutory terms possible
• Feb 8–9 · ERCOT BOARD
• Feb 8–9
• ERCOT BOARD
• ERCOT Board on Batch 1 revisions
• FOR A PROJECT · Oncor expects project identification to slip past February
• ERCOT: WILL MISS
• Apr 9 · ERCOT
• Apr 9
• Batch Zero results due on paper
• FOR A PROJECT · ERCOT told its board on Sep 11 it will miss this date
• Spring–fall · ERCOT
• Spring–fall
• Pre-pause plan: allocation, Q2 commitments, final transmission plan
• FOR A PROJECT · Allocated MW trigger the SLLIA within 60 days
• Summer · ERCOT
• Summer
• Batch 1 applications expected
• FOR A PROJECT · Entry point for excluded projects

Frequently asked questions

What is a large load in ERCOT?

A load with a non-coincident peak of 75 MW or more at one site, including expansions that cross 75 MW and co-located loads, under SB 6 and 16 TAC §25.194. A 25 to under 75 MW "medium load" stays with the utility; below 25 MW is ordinary distribution service.

What does it cost to enter the ERCOT large-load queue?

A $100,000 study fee and $50,000 per MW of security before any ERCOT study: $5.1 million for 100 MW. At agreement, security becomes the greater of $50,000 per contracted MW or the allocated upgrade cost, plus non-refundable CIAC and minimum billing demand.

Is Texas pausing data centers?

Two pauses apply as of October 14, 2026: ERCOT has not approved energization of computational loads of 75 MW or more since August 3, pending reports due December 10, and TCEQ has issued no permits sought by data center projects since September 21, at any size. Sub-75 MW utility work continues.

What is Batch Zero, and is my project in it?

ERCOT's one-time batch study of large loads that met readiness criteria by mid-2026. The September 3 classification put 204 projects in Base Load, 158 in Studied and excluded 373; excluded projects wait for Batch 1, expected summer 2027. ERCOT says results will miss April 9, 2027.

Can ERCOT shut off a data center, and does on-site generation avoid that?

Loads interconnected after December 31, 2025 must install equipment for direct curtailment in firm load shed, and ERCOT can order qualifying backup to run. Co-located loads on the Goodnight Wind terms drop fully within 30 minutes, uncompensated. On-site generation cuts grid draw, not security, and its TCEQ permits are paused.

Sources

1. Order adopting 16 TAC §25.194, Project 58481 — Public Utility Commission of Texas, 2026-09-18
2. PUCT sets financial commitments for data center interconnection; Governor pauses permits — White & Case, 2026-09-25
3. Texas PUC adopts large-load interconnection rule — Colocation Scout, 2026-09-26
4. Batch Zero Verification and Audit — PUCT presentation — ERCOT, 2026-08-20
5. Senate Bill 6, 89th Legislature, enrolled text — Texas Legislature Online, 2025-06-20
6. Texas Senate Bill 6 ushers in major overhaul of large load interconnection and grid access rules — National Law Review, 2025-07-09
7. PUCT affirms curtailment authority over co-located data centers in first net-metering decision — White & Case, 2026-08-05
8. Batch Zero Update (Board item 14) — ERCOT, 2026-09-11
9. ERCOT develops new batch study process for large load interconnections — Lloyd Gosselink, 2026-04-30
10. ERCOT Batch Zero: PUCT approval and what it means for Texas commercial buyers — Texas Commercial Plans, 2026-07-15
11. Texas, facing 438 GW queue, approves initial large load interconnection process — Utility Dive, 2026-06-22
12. Sempra Energy Q2 earnings call highlights — Nasdaq, 2026-08-09
13. ERCOT TAC July 2026 highlights — ZeroEmissionGrid, 2026-08-05
14. What Governor Abbott's data center audit directive means for ERCOT and the Batch Zero study process — Gibson Dunn, 2026-08-14
15. Texas audit could delay 49.8 GW of data center load, cost projects up to $15 billion, BNEF warns — POWER, 2026-08-06
16. Governor Abbott directs TCEQ to halt data center permits — Office of the Texas Governor, 2026-09-21
17. Governor Abbott directs TCEQ to halt all data center permits pending ERCOT, TWDB audits — Troutman Pepper Locke, 2026-09-22
18. Governor Abbott orders TCEQ to pause all permit issuance for data center projects — Bracewell, 2026-09-23
19. Market Notice M-A080326-01 — ERCOT, 2026-08-03
20. Large Load Working Group presentation — ERCOT LLWG, 2026-08-21
21. Interconnection and Grid Analysis Update (Board item 10, revised) — ERCOT, 2026-09-17
22. How long it actually takes to power a data center in 2026: a US market-by-market reality check — Construction Owners, 2026-07-01
23. Oncor Q2 2026 earnings exhibit (Form 8-K) — Oncor Electric Delivery, 2026-08-06
24. ERCOT's large load queue jumped almost 300% last year — Utility Dive, 2026-01-06
25. CenterPoint expects 14 GW of Texas Batch Zero large load — Utility Dive, 2026-07-28
26. CenterPoint Energy raises investment plan by $12bn as data center load pipeline grows — Data Center Dynamics, 2026-07-31
27. Interconnection and Grid Analysis Update (Board item 9) — ERCOT, 2026-04-13
28. Assessing the Grid — Texas Senate panel presentation — ERCOT, 2026-07-29
29. Hourly peak load in ERCOT set a new record, exceeding 91 GW on July 22 — U.S. Energy Information Administration, 2026-08-03
30. ERCOT large load interconnection 2026: LLWG recap — ZeroEmissionGrid, 2026-03-19
31. Texas hits pause on data center grid connections amid growing oversight push — Troutman Pepper Locke, 2026-08-04