Large Load Second Workshop Takeaway: Parallel Tracks for Co-Located Generation, But Batch Zero Moves Ahead Anyway

ERCOT's initial workshop proposed a centralized batch-study framework to unstick hundreds of queued large-load projects, featuring a two-phase "Batch Zero" transition with snapshot dates and a June 2027 energization cutoff. The proposal drew 109 survey responses and 35+ written comments totaling 120+ pages, with stakeholders raising concerns about retroactive cutoffs, rules for controllable loads and co-located generation, what MW "allocations" mean for firm energization, and project timelines.

What Changed at Workshop 2

Between workshops, the PUCT provided guidance at its February 6, 2026 Open Meeting: develop the transitional Batch Zero within the ERCOT stakeholder process (not via Good Cause Exception), remove the Batch Zero A/Zero B option, and encourage Revision Request(s) for June 2026 ERCOT Board consideration.

ERCOT's key pivots:

• Single Batch Zero: ERCOT collapsed the two-phase Batch Zero (A/B) into a single Batch Zero study followed by Batch One.
• Retroactivity off the table: The Batch Zero A/Zero B snapshot dates are "no longer in play," and the June 2027 energization cutoff is "no longer valid." ERCOT will "run studies for all energization dates."
• Stability screening won't reduce allocations: ERCOT committed that subsequent stability analysis results "will not reduce the MW allocation," addressing industry concerns about certainty and firmness.
• CLR and BYOG: Separate but parallel tracks: ERCOT intends to file separate revision requests for Controllable Load Resources (CLRs) and for Bring Your Own Generation (BYOG)/co-located generation. For CLRs, large loads would declare CLR intent at interconnection, binding them to register as CLRs once operational and enabling SCED dispatch to resolve constraints. For BYOG/co-located generation, ERCOT would define technical requirements and prevent load energization until generation is operational. ERCOT will advance CLR/BYOG revision requests in parallel, but will not "sacrifice Batch Zero" if they can't finish on the same timeline—meaning the co-located generation and controllable load frameworks stakeholders requested likely won't be codified for Batch Zero.
• Allocation methodology clarified: ERCOT stated that allocations in constrained areas will be based on each large-load customer's impact on constraints.
• Cost allocation deferred to PUCT: ERCOT pointed to SB 6 rulemaking—PUCT Projects 58484 (cost allocation) and 58481 (large-load interconnection standards)—for deposit and cost allocation answers.

What This Means

ERCOT acknowledged the industry's central concern: without frameworks for controllable loads and co-located generation, there's a risk of over-building transmission while underutilizing the tools designed to defer or avoid those upgrades. ERCOT committed to creating those frameworks—just on a parallel track that won't delay Batch Zero.

The timeline is aggressive: February 26 all-day workshop to review draft NPRR language, stakeholder votes in May, June 1 ERCOT Board vote, and a targeted August 1 effective date. Critical questions around cost allocation, deposits, and firmness ultimately depend on PUCT rulemaking under SB 6.

For developers with projects in the queue, the message seems mixed: more certainty on MW allocations and no retroactive cutoffs, but the policy tools to optimize transmission investment may arrive too late for the first batch.