Author: Keyur Patil
1. Pre-Batch Process (PGRR115 Process)
Before the proposed Batch Study framework, ERCOT relied on an individual, request-by-request approach to evaluate the transmission impacts of large load interconnection requests. This approach was formally codified in Section 9 of the ERCOT Planning Guide through Planning Guide Revision Request (PGRR) 115, effective December 15, 2025, which itself built upon an interim process introduced in March 2022.
Key characteristics of the individual study process include:
- Responsibility for Studies: Large load interconnection studies have historically been performed by individual electric utilities—Transmission Service Providers (TSPs)—rather than by ERCOT.
- Study Scope: Studies typically focus on the host TSP’s system and immediately adjacent areas, rather than assessing impacts across the full ERCOT system.
- Technical Requirements: The lead TSP determines the scope of required analyses, which may include steady-state power flow, short-circuit, motor-start, and stability studies.
- Submission Process: Under the Planning Guide, the lead TSP may submit individual study components to ERCOT as they are completed, rather than as a single consolidated report.
- Frequent Restudies: A defining limitation of the serial, individual study process is the need to restart—or “restudy”—a request whenever another proposed large load request in the same area meets the criteria for inclusion in study cases. As the volume of large load requests has increased, ERCOT has observed that the growing frequency of restudies has become a significant impediment to timely development. Because each request is evaluated independently, the advancement of multiple large loads within the same region can render earlier studies outdated, triggering additional restudies. This dynamic introduces uncertainty for developers and contributes to extended interconnection timelines.
Figure 1: Present Interconnection Process
- ERCOT’s role: ERCOT role under this framework has largely been limited to reviewing utility-performed studies and determining whether additional analyses are required.
The proposed Batch Study process is intended to replace this model with a single, periodic study conducted at defined intervals, with the goal of improving efficiency and reducing the need for repeated restudies.
2. Proposed Batch Study Process
Under the Batch Study approach, the “whack-a-mole” problem—where one new request invalidates prior studies—is largely avoided by evaluating a group of projects together within a defined study window. A high-level overview of the methodology is illustrated in Figure 2.
Figure 2: Batch Study Process – Overview
The Batch Study framework represents a fundamental shift away from individual, project-specific evaluations toward a collective analysis of multiple large load requests (Figure 3). While the illustrative timeline assumes approximately six months, ERCOT has acknowledged that actual durations may vary.
Hypothetical Batch Study Process
2.1 Core Characteristics of the proposed Batch Process:
- Periodic Study Intervals: Rather than initiating a study for each individual request, ERCOT would conduct a single batch study at regular intervals, potentially on a semiannual basis.
- System-Wide Assessment: ERCOT anticipates performing the studies directly, enabling a system-wide evaluation across the entire ERCOT region instead of limiting analyses to individual TSP footprints.
- Defined Inclusion Criteria: Only large loads that meet specified commitment and development thresholds within a designated application window would be eligible for inclusion. This is intended to ensure that study results reflect projects with a high likelihood of proceeding.
2.2 Batch Process Key Objectives
- Elimination of the Restudy Cycle: By grouping projects together, new requests would be deferred to subsequent batches rather than triggering restudies of projects already under evaluation.
- Aggregate Impact Assessment: Studying multiple large loads simultaneously allows for a more accurate assessment of cumulative transmission impacts.
- Improved Upgrade Identification: The batch framework is expected to improve the identification and sizing of transmission upgrades needed to accommodate large loads.
- Capacity Reservation Concept: ERCOT has proposed reserving transmission capacity for committed projects, providing greater certainty that identified capacity will be available at energization.
2.3 Relationship to Customer Commitment
ERCOT’s proposal is intended to place significant emphasis on early and robust customer commitment. Large load customers may be required to meet financial and development milestones—such as executing agreements and potentially posting a Contribution in Aid of Construction (CIAC)—before a batch study begins. This represents a departure from some current draft rules, which suggest that certain commitments could occur after study completion. ERCOT has stated that the effectiveness of the batch framework depends on the principle that only projects with strong commitment signals are included.
2.4 Implementation Timeline
Below is the proposed timeline by ERCOT. That said, the precise regulatory path forward—and how the new process will coexist with existing Planning Guide provisions—remains an open question.
Figure 4: Proposed Timeline For Batch Study Process
2.5 Batch Entrance Criteria
Formal criteria for batch entry have not yet been finalized. ERCOT has indicated that eligibility will likely be tied to indicators of project seriousness, including financial security and demonstrated development progress (e.g., executed contracts or equipment procurement).
To reinforce commitment, ERCOT has proposed milestone-based enforcement mechanisms. If a project fails to meet defined milestones, ERCOT may reclaim the associated transmission capacity and reallocate it to other projects in the queue.
Overall, the Batch Study framework is intended to optimize limited transmission deliverability, improve certainty for serious developers, and ensure that capacity is allocated to projects most likely to be constructed as infrastructure upgrades are completed over time.
2.6 What is Batch Zero?
Batch Zero refers to the initial batch study ERCOT is proposing to evaluate large load interconnection (LLI) requests that are already in the interconnection process. ERCOT plans to share draft criteria for including existing LLI requests in Batch Zero during the February 3 workshop.
Batch Zero is expected to be split into two phases—Batch Zero A and Batch Zero B. This structure reflects the fact that some projects, in order to meet their requested energization dates, must undergo a Quarterly Stability Assessment (QSA) before the full Batch Zero study is completed. Under Section 5.3.5 of the Planning Guide, large loads must be studied in the applicable QSA prior to initial energization.
Figure 5: Batch Process Entry Criteria (Source: ERCOT)
2.7 What Next?
At the February 3 workshop, ERCOT is expected to discuss key Batch Study design elements, including:
- Criteria for including existing LLI requests in Batch Zero
- Deadlines and submission requirements for batch eligibility
- Batch Study scope, process steps, and anticipated timelines
- Methodology for adding generation to study cases, if required
- Allocation of load (MW) where transmission constraints limit deliverability
- Treatment of LLIs that commit to becoming Controllable Load Resources (CLR)
- Treatment of LLIs with existing or proposed co-located generation
- Communication of study results to stakeholders
- Alignment with broader planning frameworks, including the Regional Transmission Plan (RTP) and Regional Planning Group (RPG) processes
3. Challenges with the currently proposed Batch Study Process
Despite its potential benefits, the proposed Batch Study framework raises several concerns:
- Disruption of a Newly Approved Process: The Batch Study approach significantly alters the recently approved PGRR framework without first exhausting incremental improvement opportunities.
- Unclear Commitment Requirements: Commitment thresholds for batch eligibility remain undefined, creating uncertainty for developers.
- Interdependency Within a Batch: A project’s costs, timelines, and outcomes may be materially influenced by other projects included in the same batch.
- Interdependency with the RPG Process: RPG timelines may extend well beyond a typical batch duration, forcing developers to make investment decisions before transmission solutions and costs are finalized.
- Queue Prioritization Risk: Batch sequencing may introduce stakeholder disputes over project ordering and access to limited transmission capacity.
- Batch Zero Execution Risk: The first batch has the potential to disrupt projects already midstream, introducing delays and uncertainty for developments that are well underway.
If you are developing large-load projects in ERCOT or evaluating interconnection risk, ZEG can help you interpret batch eligibility criteria, assess transmission constraints, and anticipate timeline impacts before they affect project economics.
Contact ZEG to evaluate your ERCOT large-load strategy and Batch Study positioning.
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