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Rules being developed by the Public Utility Commission of Texas regarding batch study criteria are not expected to be final until this summer.

New requirements for large electric load developers are in the pipeline at the Electric Reliability Council of Texas.

Developers of load of 75MW or more must submit full project information, and in some cases their application fees, through their transmission or distribution service provider by July 15 to ERCOT to be included in a study called Batch Zero.

An influx of large load interconnection requests in recent years, many from data centers, has resulted in restudies of some individual requests due to outdated assumptions as other requests in the area meet the milestones to be considered “must study” loads.

Restudies have created uncertainty and risk for developers, ERCOT said, and have slowed the process to interconnect.

Power consultancy Aurora Energy Research said that outcomes for large load developers will depend on the projects of their peers studied in the same batch.

Retail electricity providers will get better medium-term load forecasts from the batch studies, which would let them align procurement and hedging strategies, Aurora said. The consultancy added that retailers will have limited leverage over ramp profiles at individual loads.

ERCOT was tracking 2,042 active generation interconnection requests totaling 431,936 MW as of September 30.

The batch process could make access to available transmission capacity more competitive, and places new eligibility criteria and stricter project maturity requirements on developers.

After a batch study is complete, each proposed load in it will have 30 days to make a financial commitment.

Part of the goal of Batch Zero is to discourage speculative projects. Financial security and interconnection fee commitments were originally set at $100,000 per megawatt, but the utility commission later halved that amount.

If a project withdraws or misses milestones, financial security is drawn to cover incurred costs, according to Aurora. Only 20% of the remaining balance can be refunded, with the rest flowing through to the rate base of the transmission service provider. Any contribution in aid of construction is not refundable.

Loads that are energized receive refunds of their financial security gradually and only in full after five years of sustained operation at contracted peak demand, Aurora said.

ERCOT is expected to deliver the interconnection study for Batch Zero by January, which will show developers their capacity allocations per year for 2028-2032, along with proposed transmission improvements and costs.

The large loads must then make a decision within 30 days to support energization beginning in 2028.

By June 2027, Batch Zero would be refined, and a final transmission plan including cost estimates and any alternate improvements would be submitted to ERCOT’s Regional Planning Group.

The Batch Zero study refinement should include the expected cost of transmission projects, transmission topology, transmission facility modeling parameter data and all studies. ERCOT will perform a generation sensitivity analysis as part of its review of proposed transmission projects to evaluate the effect of proposed generation or storage in or near the study area.

Regulators throughout the country have complained that data centers are making multiple applications for interconnection.

As part of ERCOT’s evaluation, the load must disclose whether it is pursuing a substantially similar interconnection request for electric service, the approval of which would result in the load materially changing, delaying or withdrawing the request in the batch study.

The load must eventually disclose the expected schedule for phased energization of the contracted peak demand expressed in megawatts, power factor and megavolt ampere reactive units.

The load must also inform distribution or transmission providers whether the facility plans to have on-site backup generating facilities.

Some large loads are effectively grandfathered and already are considered baseload because interconnection agreements have been reached in ERCOT. These loads will not be subject to the Batch Zero study.

Both ERCOT and the utility commission would have to approve the batch study process in a series of votes in coming months for final rules to take effect.
The changes stem from Senate Bill 6, adopted in Texas last year, which changed ERCOT’s approach to large load growth by tightening interconnection requirements to protect system reliability.

Responses to Batch Zero at the commission are technical and case-specific, and not all commentors favor the proposal.

“There is significant uncertainty among utilities and customers regarding how existing customers with outstanding load requests are to be treated in the batch study proposed framework,” Texas New Mexico Power said.

The utility asked that the commission prioritize pre-existing load requests over new requests. Texas New Mexico Power added that customers that entered the interconnection queue years ago must not be overlooked by new requests simply because new capacity becomes available.

The west Texas arm of oil and gas producer Oxy questioned the authority for ERCOT to establish or enforce new operational standards on interconnecting large loads.

Oxy also believes that establishing requirements for pure retail large load customers would be inappropriate, given the structural distinctions between retail customers and market participants.

The company operates as a pure retail customer at some locations and as a market participant at others, providing responsive reserve service.

Hyperscaler Google and energy technology company Lancium asked for reduced financial requirements in Batch Zero. “Failure to refund securities while also charging CIAC [contribution in aid of construction] is a double charge,” they said.

Retail electricity provider and power generator Vistra Operations said that net metered loads should continue to be evaluated through the legacy processes and not the batch process.

“There are no more efficient large load integration opportunities than co-location with an existing generator,” Vistra said. “They require less transmission infrastructure and cost to interconnect the large load, can free up other existing transmission infrastructure for other generation resources and loads, and allow greater and more efficient utilization of existing generation infrastructure.”

The timely connection of data centers has vexed utilities, grid operators and developers around the world.

The Electric Power Research Institute announced last month that it is developing a framework to help accelerate time to power for large loads.

The framework, called Flex Mosaic, intends to be a technology neutral way to evaluate large loads based on power system requirements like congestion relief, peak reduction, balancing and frequency response. The result will be tiered ratings that identify how grid flexibility can be satisfied by large loads.

The institute and almost 50 entities worldwide including grid operators, utilities, data centers and the advisory sector seek to discover how data centers can meet grid requirements in peaking events, scarcity events, fast start needs and with fully grid responsive resources.

ERCOT has not yet joined Flex Mosaic, but the Lower Colorado River Authority and Rayburn Electric Cooperative have signed on.