News Stories

On September 3-4, 2026 parties file comments in response to the Public Utility Commission of Texas’s (PUCT) proposal for publication (PFP) to implement large load demand management service (LLDMS) standards under Public Utility Regulatory Act (PURA) § 37.170 enacted by Senate Bill 6, 89th Texas Legislature, Regular Session (SB 6).

The PFP establishes a September 4, 2026 deadline for stakeholders to file comments.

Comments filed include:

Engie –  “ENGIE supports the Commission’s objective of creating a voluntary reliability service that can provide dependable demand reduction from large loads during qualifying emergency conditions. ENGIE respectfully requests targeted changes and clarifications to ensure that LLDMS is technology-neutral, measurable, and commercially workable. In particular, the final rule should recognize verified demand reductions delivered by behind-the-meter battery storage at the point of interconnection; allow separately measured load and uncommitted battery capacity to participate in other ERCOT services without double counting; clarify registration, metering, Wholesale Storage Load (“WSL”), and charging treatment; and provide compensation sufficient to attract meaningful participation.

ENGIE notes that the Data Center Coalition (“DCC”), Texas Industrial Energy Consumers (“TIEC”), Texas Advanced Energy Business Alliance (“TAEBA”), Voltus, Inc. (“Voltus”), Enchanted Rock, LLC (“Enchanted Rock”), and Eolian, L.P. (“Eolian”) have filed comments addressing the design of LLDMS. ENGIE shares the broader stakeholder interest in a workable and commercially viable service. These comments add to that record by focusing on the metering, registration, revenue-stacking, and economic considerations applicable to battery-supported participation. ENGIE does not incorporate any stakeholder filing in full and addresses only the positions expressly stated in these comments.”

Data Center Coalition – “DCC believes that a large load customer who is available but ultimately not instructed to deploy during the obligation period be compensated for their availability to deploy. Maintaining availability during an LLDMS obligation period requires participating loads to maintain operational flexibility, increase staffing readiness, defer certain operational activities, and remain prepared to curtail load on short notice. These actions create real economic costs regardless of whether deployment ultimately occurs. The reliability value provided by these resources is their commitment and availability during the obligation period, not solely the amount of energy curtailed during a deployment event. DCC recommends that participating resources receive a guaranteed “deployment charge” or commitment payment for maintaining readiness throughout the applicable obligation period, regardless of whether they are ultimately deployed. In addition, resources that are instructed to curtail should receive incremental compensation based on the amount of demand reduction provided and the duration of the deployment event.”

“Flexibility in Procurement Participation: Once participating in the program, there should be no obligation on large loads to consistently submit offers during every procurement opportunity. Large Loads may have certain operational requirements, maintenance activities, times of the year, etc. where the ability to curtail may be more difficult. ERCOT should allow for participant flexibility to determine when participation is appropriate.”

“Redirecting Curtailment Obligations Across Facilities: DCC requests the Commission and ERCOT to evaluate whether there are circumstances in which a participant could be permitted to redirect or satisfy a curtailment obligation through another facility under common ownership or operational control, provided the required reliability benefit can be verified. Many large load customers, including data center operators, operate multiple facilities within Texas and may have differing operational capabilities across those locations. In some situations, one facility may be better positioned to absorb a curtailment request while another facility may be supporting a more critical operational function.”

Google – “Google, LLC supports efforts by the Commission to implement demand management programs like the proposed Large Load Demand Management Service (LLDMS) as a means to maintain grid reliability in both tough weather and market conditions. Various forms of demand response are needed for the ERCOT grid to be reliable and the ERCOT market to be effective and efficient over the long term.

One issue not addressed directly in the proposed rule or the Commission’s questions is where LLDMS should sit within ERCOT’s existing hierarchy of reliability tools. ERCOT already relies on Non-Spin, ECRS, ERS, and, under SB 6, emergency curtailment authority that may require large loads to reduce consumption without compensation. Google recommends that the Commission convene a workshop to examine how these tools should work together, including the applicable triggers, sequencing, and circumstances under which each should be used. The objective should be to provide large loads with a predictable framework that allows them, where practicable, to organize industrial and other operations around a known reliability event and voluntarily reduce demand before ERCOT must resort to involuntary curtailment or other more severe emergency actions.

Even without a broader workshop to determine the full suite of emergency operations, the Commission should better capture the shape of the LLDMS program including the duration, frequency, and magnitude of response that ERCOT expects to need. Greater clarity on those parameters would help inform key design decisions, including procurement timing, deployment sequencing, compensation, and the appropriate budget for the program.”

OPUC – “OPUC recommends that the Commission eliminate the proposed availability payment for large load customers that are subject to availability verification but are not instructed to deploy during the LLDMS obligation period.3 PURA provides that Electric Reliability Council of Texas (ERCOT) “shall include a deployment under this section when calculating any price adjustments for reliability deployments.”

“[T]o determine an appropriate budget for the LLDMS program, it is strongly recommended that the Commission conduct a study or survey with the existing load and load that will interconnect in the next year to gather data on the potential load that would prequalify and potentially participate in the LLDMS program. The study or survey should include multiple variations of the proposed PFP language regarding the assessment cadences and availability pricing as suggested in OPUC’s response to PFP Question 1. Results from that study or survey will help determine the appropriate budget.”

“The monthly assessment for LLDMS in proposed 16 TAC § 25.521(d)(1)(A) should be eliminated as it is unnecessarily rigid and may require ERCOT to determine the amount of service needed before it has sufficient information about the conditions and resources that may be available during an emergency event. Thus, the monthly assessment could result in ERCOT procuring and paying for resources a month in advance of a proj ected emergency event that ultimately either never occurs or the extent of the emergency is drastically reduced by the time the event occurs.”

Texas Industrial Energy Consumers – “Many industrial sites are not flexible and do not typically participate in the wholesale market but are able to reduce their usage in advance of an emergency event with sufficient notice. This notice allows users to pre-position site personnel and adjust site operations to achieve an orderly ramp down over a longer period, which is not currently facilitated by existing services with deployment times at thirty minutes or less.”

“TIEC appreciates that the proposed rule adopts an “as-needed” procurement model consistent with TIEC’ s prior recommendation, under which ERCOT would generally procure participation ahead of an identified extreme weather event only if needed.”

Vistra Corporate Services Company – “Vistra generally disfavors out-of-market capacity programs for demand response in an energy-only market, where demand should have a natural an intrinsic motivation to avoid market costs – especially during times of scarcity. The Large Load Demand Management Service (LLDMS), however, is required by statute so is not optional, and fortunately is at least required to offset its market-distortive impacts on price formation. Still, it is important to note that LLDMS inherently provides a duplicative value by providing both a capacity payment (LLDMS procurement) and the avoided cost of energy while curtailed. While Vistra has concerns with the potentially duplicated value of LLDMS being incongruent with the rest of the market construct, it is a statutorily-required program and the competitive single clearing-price procurement should discipline the clearing price.”

“So while Vistra would not typically support establishing this kind of demand response program in an energy-only market, within the statutory context Vistra observes that the proposed rule executes on its statutory charge generally well, and Vistra’s substantive comments are focused on clarifying and coordinating the proposed rule with other statutory and rule requirements, as well as practical implementation considerations along four themes:

• The curtailment directive in proposed 16 TAC § 25.521(a)(1) should apply to loads not already otherwise curtailed and include statutory customer coordination language;
• Limited deployments for actual transmission emergencies should be allowed for LLDMS; • Clarify that payments are for the LLDMS clearing price, not the wholesale energy price; and
• Recover the cost on a fixed, self-leveling $/MWh-basis fee across the year, not on an event basis.

See all filed comments at docket link.