ERCOT Develops New Batch Study Process for Large Load Interconnections

by Jack M. Klug

ERCOT continues to navigate how to meet unprecedented energy demand currently projected in the State of Texas. In particular, ERCOT has projected that by 2031 forecasted energy demand may reach 145 gigawatts (“GW”), which is almost double the all-time peak demand of approximately 85.5 GW. Large Load customers, such as cryptocurrency miners and data centers, are being added in abundance to the ERCOT system and are responsible for much of this unprecedented load growth since they require a significant amount of power – at least 75 megawatts.

One of ERCOT’s primary responsibilities is the examination of all new interconnection requests from Large Load industries to ensure the grid will have sufficient transmission capacity to serve them. However, because of the influx of new data centers and other Large Loads seeking grid connections, ERCOT now has a hard time keeping up. While ERCOT previously studied these Large Loads on an individual basis, it is now transitioning to studying these Large Load interconnections in “batches.” According to ERCOT Vice President of System Planning and Weatherization Kristi Hobbs, ERCOT rules were developed to consider 40-50 Large Loads at a time, but ERCOT received 225 new Large Load interconnection requests last year.

In contrast to the current Large Load interconnection study process, the batch study process will allow ERCOT to conduct a single interconnection study for all loads across the system included in the batch. Many Large Loads under the current system have found themselves locked in a “doom-loop” — that is, a situation wherein their potential impacts on the grid face repeated reevaluations from ERCOT because of potential offsetting impacts from nearby loads also seeking interconnections. ERCOT CEO Pablo Vegas has said the proposed batch system will address these problems and likewise give developers a clearer indication as to when they can connect. More specifically — after a batch study is complete, each proposed load will be required to make certain financial commitments. If the proposed load satisfies the financial commitments by the specified deadline, a corresponding amount of grid capacity will be “reserved” for the project in future studies.

ERCOT is planning to conduct the batch study process in multiple phases. The first phase, or Batch Zero, will include loads already in the study process. ERCOT officials have said guidelines to determine Batch Zero project eligibility will be sorted out during the upcoming stakeholder workshops. Because the final criteria will determine winners and losers, stakeholder participation remains high. Stakeholders range from residential, industrial, and commercial consumers to investor-owned utilities and independent generators.

ERCOT presented a framework for the batch study process during the February 20, 2026 PUC Open Meeting. While ERCOT initially planned to obtain approval of the batch study process from the ERCOT Board at its February meeting, the Commissioners directed ERCOT and stakeholders to defer implementation of the batch approach pending adoption of Revision Requests in the stakeholder process, with a deadline for ERCOT Board of Directors approval of June 2026.

Jack Klug is an Associate in the Firm’s Energy and Utility Practice Group. If you would like additional information or have questions related to this article, please contact Jack at 512.322.5837 or jklug@lglawfirm.com.