ERCOT Large Load Batch Study Workshop #4, March 10,2026
Author: Basit Mushtaq
ERCOT held the fourth Large Load Interconnection (LLI) Batch Study Workshop on March 10, 2026, to review the filed protocol revisions for the Batch Zero process. This was the first stakeholder session following ERCOT’s formal filing of PGRR145 and NPRR1325 on March 4, 2026, which initiate the governance process for implementing the transitional Batch Zero framework.
The workshop focused on reviewing the filed language, clarifying eligibility criteria and timelines, and addressing stakeholder concerns raised after the filing. Several updates and clarifications compared with the February 26 workshop were highlighted in the presentation.
Governance Timeline
ERCOT confirmed the governance schedule for approval of the Batch Zero proposal.
- March 4, 2026 – ERCOT files PGRR145 and NPRR1325
- May 6, 2026 – Protocols Revision Subcommittee (PRS) vote
- May 7, 2026 – Reliability and Operations Subcommittee (ROS) vote
- May 19–20, 2026 – Technical Advisory Committee (TAC) vote
- June 1, 2026 – ERCOT Board consideration
- August 1, 2026 – Target effective date for protocol changes
- Additional workshops and working group discussions will continue through March and April to resolve remaining design issues before committee votes.
Key Eligibility Milestones
Several specific dates and milestones determine whether large loads qualify for Batch Zero treatment. These dates were emphasized in the workshop and appear in PGRR145 eligibility provisions (Sections 9.2.1–9.2.2). Under this framework, large load projects are categorized as Base Load, Studied Load (included in Batch Zero), or not included in the Batch Zero process, depending on energization status, study completion, agreements, and development progress.
Base Load Treatment
- Projects that will be modeled as base load and will not be evaluated further in the Batch Zero study. This includes loads that:
- Achieved initial energization before March 25, 2022, or
- Energized between March 25, 2022, and July 15, 2026.
- Projects may still qualify as base load if they:
- Have requested energization on or before December 31, 2027,
- Have valid interconnection studies,
- Have satisfied required equipment procurement and development attestations
- Have executed an Interconnection Agreement consistent with PGRR145 §9.7.2.
- If the requested Initial Energization date is on or after January 1, 2028, then to qualify as base load:
- Have valid interconnection studies,
- Have executed an Interconnection Agreement consistent with PGRR145 §9.7.2 (By July 15 2026).
Loads Included in the Batch Zero as Studied Loads
- Projects that do not qualify as base load but meet eligibility requirements will be included in the Batch Zero as studied loads. Requirements include:
- Requested energization date on or before December 31, 2027, or later with qualifying conditions.
- Execution of an Intermediate Agreement meeting PGRR145 §9.7.1.
- If the requested Initial Energization date is on or after January 1, 2028, then to qualify as loads studied in batch zero:
- Have studies sufficient for inclusion under Section 9.2.1.4, and
- Have executed an Intermediate Agreement meeting Section 9.7.1 by the required eligibility deadline (July 15, 2026)
- Their MW allocation is determined through the Batch Zero study.
Projects Not Included in Batch Zero
- Projects are excluded if they:
- Do not meet criteria in §9.2.1.1 or §9.2.1.2, or
- Fail to submit required information by July 15, 2026.
- Development Activity Requirements
- ERCOT highlighted that projects requesting energization by December 31, 2027, must demonstrate development progress by July 15, 2026.
- Two qualification pathways were discussed:
- Path 1 – Stability Assessment Path – Inclusion in a Quarterly Stability Assessment or interim ride-through assessment by May 1, 2026, and Attestations confirming site preparation and equipment procurement.
- Path 2 – Valid Study Path – ERCOT confirms existing studies are valid:
- An interconnection agreement has been executed, and
- Evidence of site preparation and equipment procurement is provided.
- ERCOT noted that these requirements are intended to ensure that only projects demonstrating meaningful development progress are included in the Batch Zero process.
Batch Zero Study Timeline
ERCOT provided the expected timeline for the study and commitment process:
- Early 2027 – ERCOT completes Batch Zero stud
- ~January 2027 – Preliminary MW allocations communicated to developers
- March 1, 2027 – Developer commitment deadline
- Developers will have approximately 30 days after receiving allocation results to execute interconnection agreements and provide required financial commitments.
Allocation and Commitment Rules
ERCOT clarified several rules governing MW allocations:
- Allocations become fixed after commitment. ERCOT will not reduce MW allocations or delay delivery years once commitments are made.
- The refinement study phase will only determine transmission solutions and will not change MW allocations.
- If a project withdraws after the commitment milestone, ERCOT does not plan to reallocate unused capacity within Batch Zero. Capacity may instead be addressed in future batches.
Interaction with Transmission Planning
Batch Zero results will not affect the 2026 Regional Transmission Plan (RTP) because commitments occur after the 2026 planning cycle.
Projects that meet the March 2027 commitment milestone may be incorporated into the 2027 RTP planning cycle. Capacity allocation assumptions:
- Years 1–5 – allocations limited by existing transmission capability.
- Year 6 – assumes transmission upgrades identified through RTP and RPG processes.
- Projects may therefore receive partial allocations in early years and full capacity after transmission upgrades are completed.
Study Modeling Assumptions
ERCOT clarified that additional generation will be modeled according to the methodology established under PGRR127. Batch Zero study cases will include a “no-solar” scenario to evaluate system performance under stressed conditions.
Stakeholder Feedback and Issues Raised
Stakeholders broadly supported using: Site preparation and construction, Site control, and Financial security or deposits as indicators of development progress. Two notable concerns were raised:
- Project ordering under Planning Guide §9.2.1.4 is based on the date of the most recent restudy rather than the original study completion date, which may affect queue ranking.
- A sequencing issue exists between development attestations and study validation. Developers must provide construction and equipment attestations by July 15, 2026, while ERCOT’s validity review of studies may not conclude until early August 2026.
Key Takeaways
- Preliminary MW allocations are expected in early 2027, followed by a commitment deadline around March 2027.
- MW allocations become fixed after commitment, and ERCOT does not plan to reallocate unused capacity within Batch Zero.
- Additional policy topics, including CLR participation and BYOG configurations, will be addressed in future revision requests.
- ERCOT removed non-utilized capacity reallocation provisions from PGRR145 after stakeholders raised potential conflicts with PUC rulemaking (SB 58481 implementation).
- Under Planning Guide §9.2.1.4, project ordering is determined by the date of the most recent restudy, not the original study completion. Implication to this is Projects that completed studies years ago but were recently restudied may rank lower in the queue.
- ERCOT acknowledged an unintended consequence in the proposed framework:
- Loads not included in the 2026 RTP base cases could receive 0 MW allocations under the “lesser-of” rule, even if studies were complete. ERCOT indicated it intends to address this issue.
Navigate the ERCOT Large Load Interconnection Process with Confidence
Misinterpreting the Batch Zero process or entering the queue without detailed system insight can expose projects to significant delays or upgrade risk.
At ZEG, we support developers, data center operators, and utilities with advanced grid modeling, interconnection strategy, and due-diligence analysis to navigate complex ISO/RTO processes.
Our engineering team provides:
- Large-load interconnection strategy and queue positioning analysis
- ERCOT system modeling and congestion risk assessments
- Transmission upgrade exposure analysis
- Technical due diligence for data center and large-load developments
- Comprehensive interconnection application and study support
If you are evaluating a large-load or data center interconnection in ERCOT, contact ZEG to ensure your project enters the queue with the technical clarity needed to reduce risk and improve development certainty.
