ERCOT Batch Study Process for Large Load Interconnections Workshop #7 –Summary
Author: Basit Mushtaq
The ERCOT Large Load Batch Study Workshop (#7), held on April 9, 2026, marked the culmination of the stakeholder engagement process for developing the Batch Zero framework. The workshop focused on refining remaining design elements, addressing stakeholder concerns, and aligning the Planning Guide Revision Request (PGRR145) with ongoing regulatory developments under PUCT Project No. 58481.
The discussion reflects a transition from conceptual design to finalization and governance approval, with most technical aspects of the framework now stabilized and remaining uncertainties primarily tied to regulatory and commercial considerations.
(1.) Timeline and Governance
Batch Zero has officially entered the governance phase. PGRR145 and NPRR1325 were filed on March 4, 2026, and are progressing through ERCOT’s approval structure (PRS → ROS → TAC → Board).
Key milestones include:
- PRS/ROS/TAC approvals expected in May 2026
- ERCOT Board approval targeted for June 2026
- Implementation target around July 2026
(2.) Controllable Load Resource (CLR / PCLR)
The workshop provided important clarity on the treatment of Controllable Load Resources (CLRs), specifically Provisional Controllable Load Resources (PCLRs).
Key points:
- CLR will not be introduced through a separate revision request. Instead, it will be implemented through updates to existing PGRR145 and a companion NPRR1325.
- PCLRs will be studied at full consumption in stability screening studies. This means ERCOT will assume the full requested demand when evaluating system impacts.
- The financial security requirement of $50k/MW applies to the full requested load, not just the firm or LPC portion. This reflects the expectation that transmission infrastructure will eventually be built to serve the entire load.
- PCLR obligations are binding during a defined lock period and remain in place even if project ownership changes.
(3.) Bring Your Own Generation (BYOG)
Workshop provided substantially clearer direction on how BYOG is expected to function operationally, even though final rule language is still under development.
Core Concept
- BYOG is built on three key elements:
- Batch Allocation: Load is still evaluated through the Batch Zero study, even if co-located with generation
- Coordination: Load and generation must operate in a coordinated manner within system limits
- Operating Agreement: Defines obligations, especially self-limiting behavior during contingencies
- Operating Modes
- ERCOT is considering a range of operating configurations:
- Net-zero (islanded): Generation fully serves load
- Net generation: Excess generation exported to grid
- Hybrid operation: From limited import to full export
- ERCOT is considering a range of operating configurations:
- A critical clarification was that if a generator already satisfies Section 6.9 requirements at the start of Batch Zero, it will not be treated as BYOG and will not receive credit. BYOG is conceptually supported but not fully finalized. Further rulemaking is expected to define its implementation in detail.
(4.) ERCOT Responses to Stakeholder Comments
ERCOT reviewed its April 4 responses to stakeholder comments and incorporated several clarifications into PGRR145. Key clarifications incorporated:
- DSP role flexibility: ERCOT clarified that the Interconnecting DSP may designate another entity to fulfill its responsibilities under Section 9.
- Recognition of prior studies: The Permian Basin Reliability Plan Study (2024) was explicitly included as a valid study under the evaluation of existing interconnection studies.
- Dynamic model data updates: ILLEs are required to provide updated dynamic data when project changes occur, and this data must be shared with the interconnecting DSP/TSP.
- Study transparency and governance: ERCOT committed to presenting the Batch Zero study scope and methodology to the Regional Planning Group (RPG) to allow stakeholder review and input.
- Additional clarifications: ERCOT also refined language to better define responsibilities and corrected inconsistencies and references across sections.
(5.) Major Unresolved / Contested Issues
Despite multiple workshops, several key issues remain unresolved and are dependent on either PUCT rulemaking (Project 58481) or further revisions to PGRR145.
(a) Financial Security & Cost Allocation (Most Contentious)
- Stakeholders raised significant concerns regarding:
- $50k/MW financial security requirement
- Contribution in Aid of Construction (CIAC)
- Upgrade cost recovery mechanisms
- Refundability and treatment of reallocated MWs
- A key concern highlighted was: ILLEs may be required to post financial security for full requested capacity, even if that capacity is later reallocated or delayed, with unclear refund treatment.
- ERCOT position:
- ERCOT is currently aligning with the proposed PUCT 58481 rule
- No immediate changes to PGRR145 Sections (e.g., 9.2, 9.7)
- Will revise once the final PUCT rule is adopted
(b) Scope of Planning Guide vs. PUCT Jurisdiction
- Utilities raised concerns that:
- Financial/accounting provisions do not belong to Planning Guide
- Should be handled entirely under PUCT rulemaking
- Status:
- ERCOT is open to removing or modifying some financial language, but no final change yet
(c) Eligibility Criteria & Study Validity
- There is ongoing disagreement regarding:
- What qualifies as a “complete and valid” interconnection study
- Treatment of:
- Loads included in RPG projects
- Previously studied loads
- Advanced-stage projects without fully compliant studies
- Stakeholders emphasized:
- Expanding eligibility for advanced-stage projects
- Adjusting cutoff dates and prioritization criteria
- Providing a pathway for projects close to completion but lacking formal study validation
- Status: Still evolving and dependent on:
- Final PUCT guidance
- ERCOT’s final eligibility framework
(d) Timeline Constraints & Commitment Windows
- Stakeholders raised concerns that:
- The proposed 30-day commitment window after the Batch Zero study report is too short
- There is broad support for:
- Extending the timeline to 60 days
- ERCOT response:
- Decision deferred pending PUCT 58481 guidance
- No change implemented yet
(e) Alignment with SB6 / PURA §39.169 (Co-located Load + Generation)
- Stakeholders highlighted potential conflicts between:
- Batch Zero timelines, and
- Statutory requirements under PURA §39.169
- Need to:
- Preserve legacy process for near-term projects
- Avoid delays for co-located configurations
6. PUCT Project No. 58481 Summary
A separate session was included to clarify confusion around various cost components, given that much of the PGRR145 language is tied to PUCT Project 58481. The primer clarified that:
- The proposed framework includes multiple distinct financial obligations
- These are often misunderstood but serve different purposes and timelines
- Key Financial Obligations: The framework includes three main requirements:
- Financial Security ($50k/MW)
- Posted at Intermediate Agreement
- Applies to full requested load
- Partially refundable
- Demonstrates project commitment
- CIAC (Contribution in Aid of Construction)
- Paid at Interconnection Agreement
- Covers direct interconnection facilities
- Non-refundable
- Upgrade Security
- Paid at Interconnection Agreement
- Covers transmission upgrades identified in the study
- Partially refundable over time
- Financial Security ($50k/MW)
7. Overall Status and Conclusion
At the conclusion of Workshop #7:
- What is finalized:
- Batch study structure and workflow
- Load categorization approach
- Integration with planning and stability processes
- What remains open:
- Financial structure and cost allocation
- BYOG implementation details
- Final eligibility criteria
- Commitment timelines
In summary, Batch Zero is technically and procedurally complete, but its final implementation depends on regulatory alignment and resolution of remaining commercial issues. The process is now transitioning from stakeholder design to final approval and implementation.
ERCOT Batch Zero Workshop #7 Meeting Materials
