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On May 18, 2026 the Division of Compliance and Enforcement (DICE) of the Public Utility Commission of Texas (PUC) investigated Meadow Park ESS Assets, LLC (Meadow Park) for violations related to its compliance with Electric Reliability Council of Texas (ERCOT) Nodal Protocols and the ERCOT Planning Guide concerning eligibility to register as a market participant.

This memorandum serves as a report to the Commission under PURA1 § 15.024(a) determining violations have occurred, providing a statement of the facts forming the basis of the determination, and providing a recommendation on an administrative penalty.

DICE issues this report to the Commission for its consideration.

“The Lone Star Infrastructure Protection Act (LSIPA)2 prohibits business entities from entering into agreements related to critical infrastructure in the state wherein the agreement would grant direct or remote access or control of critical infrastructure to a company known to be owned or controlled by nationals of, or otherwise headquartered in, China, Iran, North Korea, Russia or any other designated country. DICE has determined that Meadow Park violated Commission rules, ERCOT Nodal Protocols, and ERCOT Planning Guide provisions regarding market participant eligibility when it knowingly provided misleading information concerning its ownership when it submitted its ERCOT Nodal Protocols Section 23, Form Q and ERCOT Planning Guide Section 8, Attachment D attestations. Because Meadow Park’ s violative behavior involved the issuance of false or misleading statements to ERCOT, the violations described herein are significant in nature and may be used in an action revoking Meadow Park’s power generation company (PGC) registration.”

Violations

Meadow Park did not comply with or observe obligations of prospective market participants when attempting to enter the ERCOT market.

“Commission Staff asserts that Meadow Park was ineligible to register as an ERCOT market participant on June 10, 2025, as its owner (Geng Tian) was a Chinese national at the time Meadow Park submitted its Form Q. By its own admission, Meadow Park’ s sole owner was and remains Geng Tian. 15 ERCOT has confirmed that prospective applicants to the ERCOT market are denied admittance in instances where Form D Question 1 has been marked true and Question 2 should not have been answered.”

“Further, Meadow Park violated ERCOT Planning Guide § 5.2.2(3) on June 13, 2025 when it attempted to initiate or maintain a GIM when it was otherwise ineligible. EROCT has confirmed that IEs that marked any of the statements on Attachment D, Question 1 as “true” would have been ineligible to initiate or maintain a GIM, and by extension, would be ineligible to become an ERCOT market participant.”

Meadow Park had knowledge of and withheld its LSIPA exposure when it sought admittance into the ERCOT market.

“Meadow Park violated 16 TAC § 25.503(f)(8) when it submitted knowingly false, misleading, or otherwise inaccurate information to ERCOT in its Form Q and Attachment D attestations. Commission Staff asserts that Meadow Park falsely represented on its Form Q attestation that it marked true on Form Q, Question 1 due to the ownership, citizenship, or headquarters of an affiliate or subsidiary of Meadow Park and that the affiliate or subsidiary would not have direct or indirect access to ERCOT system information. Commission Staff further asserts that Meadow Park as the IE falsely represented on its Attachment D attestation that it was not owned by an individual who was a citizen of an LSIPA Designated Country.

At all points relevant to this investigation, Meadow Park knew it was owned solely by Geng Tian, then a Chinese citizen, on the dates Meadow Park sought and obtained entry as an ERCOT market participant. Commission Staff further asserts that, but for Meadow Park’s misrepresentation as to the reasons why it marked “true” to Form Q Question 1 and its false representation on its Attachment D attestation, Meadow Park would not have been permitted entry as an ERCOT market participant.”

RECOMMENDED DISPOSITION

“The violations described herein are Class A violations as defined by 16 TAC § 25.8(b)(3)(B)(i) and subject to a potential administrative penalty up to $25,000 per day per violation. Additionally, the violations described herein constitute significant violations of Commission adopted rules as they concern the provision of false or misleading information by Meadow Park to ERCOT.

Commission Staff recommends the Commission enter an order reflecting the following:

1. Meadow Park should be assessed an administrative penalty of no less than $50,000 for

two separate violations of PURA § 39.151(j), 16 TAC § 25.503(f)(8), one violation of

ERCOT Nodal Protocols § 16.1.3(3), and one violation of ERCOT Planning Guide Sec. 5.2.2(3);

2. Meadow Park’s PGC registration should be revoked; and
3. Meadow Park’s principals should be prohibited from registering as principals of a retail electric provider or a PGC for a period of at least one year from the entry of an order revoking Meadow Park’s PGC registration.”