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ERCOT paused its Batch Zero large load study and asked the PUCT to excuse the deadlines it missed while it audits data center interconnection requests
The interesting part is not the pause. It is that ERCOT told the Commission it will treat a materially false eligibility attestation as a disqualification from Batch Zero, and that it is asking for community impact data from loads far below the Batch Zero threshold.
Bottom line: This is a request, not an order. ERCOT asked the Public Utility Commission of Texas to grant good cause exceptions under 16 TAC 25.3(b); the filing includes a Draft Proposed Order the Commission had not signed as of the filing date. The pause of Batch Zero, however, is something ERCOT says it has already done.
Who this affects: Data center and virtual currency mining developers with loads queued in ERCOT, the Interconnecting Large Load Entities behind them, and the Interconnecting Distribution Service Providers and Transmission Service Providers that filed their attestations. Also energy counsel and regulatory affairs leads at hyperscale and colocation operators.
Issue date: Filed August 10, 2026. ERCOT said it would provide more detail on scope and timing at the Commission's August 20, 2026 open meeting, and that the verification and audit will take several months.
What changed: ERCOT missed the August 7, 2026 classification deadline in Planning Guide 9.3.1(2)(a) and is not classifying any Large Load until the audit finishes. It also asked to keep unclassified loads in the August 1 and November 1, 2026 quarterly stability assessments, and to notify entities of dynamic model deficiencies after the August 7 deadline with a 24-day cure period running from notice.
Analysis: Read Section III.B. ERCOT states that if it finds an attestation false in any material respect, or if an entity fails to respond to the request for information, it will classify the associated Large Load as ineligible for Batch Zero. That converts a commercial readiness attestation from paperwork into an exclusion trigger, and the review is being run with outside counsel.
Primary sources: ERCOT filing, PUCT Interchange (PDF)
- Instrument (EN)
- ERCOT's Requests for Good Cause Exceptions Relating to Batch Zero Deadlines and Status Update on Additional Matters Including the Long-Term Load Forecast
- Authority
- Electric Reliability Council of Texas, Inc., filing before the Public Utility Commission of Texas
- Jurisdiction
- Texas, United States (ERCOT Region)
- Status
- Filed and pending. A Draft Proposed Order granting the relief was attached as Attachment A.
- Bindingness
- The request binds nobody until the Commission acts. The Batch Zero pause and the freeze on energization approvals are ERCOT's own stated conduct.
- Issue date / next deadline
- Filed August 10, 2026. Further detail promised for the August 20, 2026 open meeting. Batch Zero study results deadline of April 9, 2027 left untouched for now.
- Legal hook
- 16 TAC 25.3(b) good cause exception from 16 TAC 25.361(b)(16), covering Planning Guide 5.3.5(5)(a)(ii), 9.2.2(3)(a) and 9.3.1(2)(a).
- Trigger
- Governor Greg Abbott's letter of August 3, 2026 to the PUCT Chairman and ERCOT's chief executive.
- Primary source
- https://interchange.puc.texas.gov/Documents/58317_27_1672569.PDF
What ERCOT actually filed
On August 10, 2026 ERCOT's general counsel Chad V. Seely wrote to the five Commissioners and attached the substantive filing, which sits in Project No. 59142 and was copied into Project No. 58317 as Item 27. The letter answers Chairman Gleeson's August 6 memorandum asking for an update at the August 14 open meeting.
Three exceptions are requested. First, relief from the August 7, 2026 deadline in Planning Guide 9.3.1(2)(a) to classify each Large Load as base load, studied load, or load that did not qualify. Second, relief from Planning Guide 5.3.5(5)(a)(ii) so that loads ERCOT has determined are eligible for base load status, but has not formally classified, can still sit in the August 1 and November 1, 2026 quarterly stability assessments. Third, permission to keep reviewing dynamic data submissions past August 7 and to give each late-notified entity the same 24-day cure window.
ERCOT put a Draft Proposed Order in front of the Commission as Attachment A. That is a convenience, not a decision. The signature block on it is blank.
Where the pause came from
Governor Greg Abbott wrote to the Commission and ERCOT on August 3, 2026 directing a comprehensive verification and audit of all data centers advancing through the interconnection process, and directing that it be completed before any additional data centers are approved to move forward. The Commission and ERCOT read data centers to include virtual currency mining facilities and other computational loads.
ERCOT's response was to stop. It issued Market Notice M-A080326-01 telling the market it would not meet the August 7 classification deadline, and it says it will not grant further approvals to energize any Large Load data center or virtual currency mining facility until verification is done.
The timing problem is structural rather than administrative. Planning Guide 9.1(8) lets ERCOT run site-readiness verification any time through April 9, 2027, so ERCOT had planned to verify during the study. The Governor's letter requires verification before classification. Two weeks separated the July 24 attestation notice from the August 7 classification deadline, which was never enough room to run a verification first.
The attestation exposure
Batch Zero was created by Planning Guide Revision Request 145, approved June 18, 2026, as a one-time transitional study of loads of 75 MW or more. Seven eligibility paths lead to base load status; one leads to studied load. Several of those paths turn on commercial readiness: site control, having ordered all equipment with lead times of at least 18 months, holding the discretionary approvals the relevant municipality or governmental entity requires, and posting financial security for system upgrades.
The developer attests to that. The Interconnecting DSP or TSP passed the attestation to ERCOT by July 24, 2026. Nobody audited it at the time.
Now ERCOT says it will issue requests for information to every entity with a Large Load submitted for Batch Zero, sent through the DSP or TSP, and will use the responses to verify each eligibility attestation. On ERCOT's account, an attestation found false in any material respect, or a failure to respond at all, results in the Large Load being classified as ineligible for Batch Zero. Outside counsel and other third parties are supporting the work.
The 25 MW question
Batch Zero applies at 75 MW. The community impact collection does not. ERCOT told the Commission it will seek the community impact information the Governor identified from all data centers and virtual currency mining facilities of 25 MW or more that have not yet energized.
ERCOT sized that population from an earlier request for information tied to the 2026 Regional Transmission Plan: 258 loads with peak demand of at least 25 MW and less than 75 MW seeking interconnection by 2032, totalling 13,473 MW, of which roughly 157 are data centers or virtual currency mining facilities representing 8,766 MW.
The categories the Governor's letter names are financial self-sufficiency, power supply, water use and cooling technology, community-impact mitigation, and ownership and controlling interests. ERCOT says a failure to answer will be reflected in the report it files with the Commission at the end, handled so as to protect confidential information.
Knock-on effects ERCOT flagged but did not ask to fix
The Long-Term Load Forecast slips. The Commission had approved, on June 18, 2026, ERCOT's request to adjust the 2026 forecast using Batch Zero base load classifications, and ERCOT expected to finalise it by mid-August. Without classification there is nothing to finalise, which pushes the Triennial Reliability Assessment and could push the December 2026 Capacity, Demand, and Reserves Report. ERCOT argued the delay is worth it and did not request a methodology change.
The April 9, 2027 deadline to deliver Batch Zero study results is untouched. ERCOT said it does not yet know how long the audit will take and will come back with another good cause exception request or go through the stakeholder process if it needs to.
Separately, ERCOT received 41 requests from entities seeking good cause exceptions from Batch Zero eligibility criteria themselves. Twenty-one of those touch the qualifying interconnection study requirement, which the July 23 market notice had expressly placed outside the exception process. ERCOT will not forward those 21 to the Commission, and says those entities will be ineligible for Batch Zero unless they separately qualify as studied load. The rest, which concern financial security or the Form W deadline, remain under evaluation.
What we did not verify
We opened the filed PDF at PUCT Interchange, Control Number 58317, Item Number 27, filed 2026-08-10, which contains both Seely's cover letter to the Commissioners and the full Project No. 59142 filing with the Draft Proposed Order.
We did not open Governor Abbott's August 3, 2026 letter, Market Notice M-A080326-01, Market Notice M-B062326-06, Planning Guide Revision Request 145, or any of the cited Planning Guide sections in their own text. Every description of those documents here is ERCOT's characterisation of them, taken from this filing.
We do not claim the Commission granted any of these exceptions. As of the document we read, the order was a draft with no signatures and the item was set for consideration. We also make no claim about which specific projects or companies are in Batch Zero; the filing names none.
If you attested to commercial readiness to get a Texas large load into Batch Zero, the document you signed in July is now the document being audited. ERCOT has said in a public filing that a materially false attestation, or silence in response to its request for information, results in the load being classified ineligible. Anyone below 75 MW who assumed Batch Zero was somebody else's problem should note the community impact collection reaches down to 25 MW. Nothing is classified and nothing new energizes until the audit closes.
Source File
https://interchange.puc.texas.gov/Documents/58317_27_1672569.PDF
Open the PDF at PUCT Interchange Control Number 58317, Item 27, and confirm the filed date of August 10, 2026, the three requested exceptions in Section II covering Planning Guide 9.3.1(2)(a), 5.3.5(5)(a)(ii) and 9.2.2(3)(a), the ineligibility consequence for false attestations in Section III.B, and the 258 medium-sized load figure in the same section.
ERCOT will not approve any authorizations to energize data center Large Loads until the verification and audit process is complete and such Large Loads have met the Batch Zero verification requirements. ยท ERCOT filing, Public Utility Commission of Texas, August 10, 2026
FAQ
Is Batch Zero cancelled?
No. On ERCOT's account it is temporarily paused while the verification and audit run. ERCOT told the Commission it has not asked to move the April 9, 2027 deadline for delivering study results, though it left open that it may need to.
Does inclusion in a quarterly stability assessment mean my load can energize?
The filing says the opposite. ERCOT states that QSA inclusion does not by itself authorize energization, and that it will allow an included Large Load to energize only once verification confirms base load eligibility and all other energization conditions are met.
My load is 40 MW. Does any of this reach me?
Batch Zero itself applies at 75 MW and above. But ERCOT said it will collect the Governor's community impact information from all data centers and virtual currency mining facilities of 25 MW or more that have not yet energized, working through DSPs and TSPs.
What happens if my dynamic data was flagged late?
ERCOT asked the Commission to let it notify entities of dynamic model deficiencies after the August 7, 2026 deadline and to give each late-notified entity 24 days from notification to cure, the same period Planning Guide 9.2.2(3)(a) provides. That relief was requested, not yet granted, in the document we read.
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