ERCOT Batch Zero Clears PUCT: Texas Large-Load Connections Now Have a Fast-Track Path
On June 18, 2026, the Public Utility Commission of Texas approved ERCOT's Batch Zero process, replacing the first-come-first-served large-load queue with a coordinated batch study for sites over 75 MW. Here is what changes for Texas commercial electricity buyers below that threshold.
Key takeaways
- After the ERCOT Board voted unanimously to endorse Batch Zero on June 2, 2026, it was approved by the PUCT on June 18, 2026.
- A "large load" refers to any single site with peak demand greater than 75 MW. Batch Zero is applicable only to this category.
- As of mid-2026, ERCOT's large-load interconnection queue held 438,076 MW of proposed demand, 90 percent of which was associated with data centers.
- Batch Zero classifies applicants as Base Load, Studied Load, or Excluded and provides two optional reliability tracks: WLPUN and PCLR.
- Commercial buyers below 75 MW do not interact with Batch Zero directly, but transmission upgrades sized for the batch will be included in TDU rates that all 4.7 million Texas commercial and industrial accounts pay.
- TxCP currently shows 493 active commercial plans as of July 2026 across the 5 ERCOT-region TDUs at 10.73 cents per kWh, which is the market average.
What is ERCOT Batch Zero?
ERCOT Batch Zero is a group-study interconnection process for large users of electricity on the ERCOT grid that allows them to avoid the one-by-one study process for each request over 75 MW. Instead of studying requests in the order they arrive, ERCOT collects all requests that meet the criteria and processes them as a single batch. On June 18, 2026, the Public Utility Commission of Texas approved this method and adopted NPRR 1325 and PGRR 145 as the rules governing this process.
The goal is to resolve a backlog of over 438 GW of proposed demand, which ERCOT confirmed in its June 18, 2026 news release. For context, the peak demand of the ERCOT grid is around 85 GW, so the queue represents roughly 5.15x the entire current system peak. Batch Zero is the method that ERCOT and PUCT chose to address the backlog without having to start over on engineering studies for each new project that enters the queue.
Pablo Vegas, ERCOT President and Chief Executive Officer, told the ERCOT Board on June 2, 2026, per RTO Insider's meeting coverage, that the batch approach would provide developers "a clearer indication as to when they can connect to the grid" and that this approach could "become a model for other grid operators across the U.S."
Legal counsel at Willkie Farr and Gallagher wrote in a June 2026 client alert that the prior first-come-first-served model was "unsustainable" because each new large project "could invalidate studies for projects further along in the process, triggering costly restudies and delays."
Who is considered a large load under NPRR 1325?
For the purposes of Batch Zero, a large load is defined as a single premises with peak electric consumption of over 75 MW. ERCOT's Trending Topic PDF of June 18, 2026 sets this threshold. This definition captures all of the major categories driving the queue, including hyperscale data centers, AI training campuses, crypto mining operations, large industrial and manufacturing facilities, and select petrochemical plants.
Businesses with less than 75 MW at a single site are excluded from Batch Zero. A distribution-connected office, retail center, warehouse, or small- to mid-sized manufacturer connects via their Transmission and Distribution Utility (Oncor, CenterPoint, AEP Texas, or TNMP) and is subject to the same interconnection standard as before June 18, 2026. The commercial electricity plan a small or mid-sized buyer signs with a Retail Electric Provider (REP) is unaffected on its face. If you are new to how the REP layer works, see the TxCP guide to Texas commercial electricity providers.
Base Load, Studied Load, or Excluded: What each classification means
Each large-load applicant gets sorted into one of three buckets. Willkie's June 2026 client alert on NPRR 1325 and ERCOT's own Trending Topic document describe them as follows:
- Base Load. Projects that are energized or sufficiently advanced to be considered fixed. Their capacity is not at risk in the batch study, but they count against the transmission capacity available for the batch.
- Studied Load. Projects that do not have a predetermined allocation of electricity. Steady-state and stability analysis within the batch may lower the MW value a Studied Load project receives. Most new hyperscale requests are expected to land in this category.
- Excluded Load. Projects that in this cycle do not qualify for Base or Studied Load. Excluded projects are put on hold for the next batch study instead of advancing now.
Classification decisions for the first batch fall on August 7, 2026, according to ERCOT's published Batch Zero timeline.
WLPUN and PCLR: The two reliability opt-ins
Batch Zero combines the group study with two voluntary paths designed to limit the exposure of the grid to a large new load. Both are listed in the ERCOT June 18, 2026 Trending Topic:
- Withdrawal-Limited Private Use Network (WLPUN). The large user pairs on-site generation with the site so its net draw from the ERCOT grid stays under a defined cap. This is a common practice for data-center campuses that co-locate gas turbines or fuel cells.
- Provisional Controllable Load Resource (PCLR). The large user consents to ERCOT curtailing its load during localized grid stress in exchange for more favorable participation terms for Batch Zero.
A sub-75 MW commercial customer does not have access to either option, but both are relevant to the buyer-side story: WLPUN and PCLR lessen the amount of new transmission the state needs to build to serve the batch. Less transmission construction translates to a smaller pass-through cost recovery in the TDU rate cases that every Texas commercial customer is eventually subjected to. TxCP's analysis of the 2026 TDU rate hike cycle walks through how those cases translate to a bill.
What is the Batch Zero timeline?
ERCOT has posted a five-milestone calendar for the first Batch Zero cycle. The dates below are from ERCOT's June 18, 2026 Trending Topic PDF:
| Milestone | Date | What happens |
|---|---|---|
| Technical documents due | July 10, 2026 | Deadline for applicants to submit engineering studies and site documentation |
| Classification notice | August 7, 2026 | ERCOT notifies each applicant of its Base Load, Studied Load, or Excluded status |
| Capacity allocation | Spring 2027 | Studied Load projects receive their final MW allocation |
| Financial and site commitment | Q2 2027 | Developers must post financial security and prove site control |
| Final transmission plan | Fall 2027 | ERCOT publishes the transmission upgrades needed to serve the batch |
The base financial security posted by large-load projects is $50,000 per MW as a default, per ERCOT's Batch Zero technical materials. For a 500 MW data center, that is $25,000,000 at stake before the developer walks into 2027 with a decision. Across the full 438,076 MW queue, if even 10 percent qualifies as Base Load, the aggregate posted security would exceed $2.19 billion.
Why did ERCOT scrap first-come-first-served for large load queues?
The previous system examined all large-load requests on an individual basis, in filing order. When a new 500 MW or 1,000 MW application arrived, the transmission model changed, and engineering studies for the projects behind it in line had to be redone. Analysts and ERCOT staff cited this "restudy loop" as the primary failure mode of the first-come-first-served methodology. With each new hyperscale filing every quarter, the queue would self-reset, and no one could provide a firm connect-by date.
The RTO Insider coverage of the ERCOT Board vote on June 3, 2026 framed the issue as the queue "invalidating itself" with each cycle of new filings. Willkie's June 2026 legal alert described the same phenomenon: individual studies "often resulting in expensive restudies and delays as new projects superseded previous ones." Batch Zero overcomes this by stabilizing the study population for a batch, running one coordinated model, and only updating the model in the subsequent batch.
Between 2018 and 2020, ERCOT and MISO ranked highest among U.S. grid operators for interconnection agreement completion rates, close to 42.6 percent, according to an Advanced Energy United scorecard published by Utility Dive in 2024. ERCOT is wagering that Batch Zero will allow its system to maintain that relative performance edge as the queue expands beyond 400 GW.
How does Batch Zero affect small and mid-sized Texas commercial electricity buyers?
Batch Zero does not alter any Texas business plan, contract, or rule that applies to businesses with less than 75 MW at a single site. Instead, it alters the make-up of the load ERCOT plans to serve for the next 24 to 36 months, and therefore the transmission investment small and mid-sized commercial customers will help pay for through TDU rates.
Three specific pass-throughs matter for sub-75 MW commercial buyers:
- TDU transmission cost recovery. Each transmission upgrade ERCOT approves under the Batch Zero plan will be recovered through TDU rate cases at Oncor, CenterPoint, AEP Texas, and TNMP. Commercial customers on non-residential TDU tariffs bear a portion of that cost on their monthly bills, separate from the energy rate they contracted with their REP.
- Curtailment and demand response programs. As ERCOT and PUCT implement stricter curtailment measures (see TxCP's analysis of the 75 MW mandatory curtailment rules from May 2026) and voluntary demand response, mid-sized commercial and industrial sites are increasingly viewed as flexible-load partners. That is a revenue opportunity for buyers with shiftable load.
- Contract-term risk. If Batch Zero's final transmission plan (Fall 2027) leads to substantial TDU rate-case filings in 2028, short-term commercial contracts signed today at floating or 6- to 12-month terms will be the first to reprice into the new TDU rate environment. Longer fixed-rate contracts shield the energy component of the bill from that reset.
The TxCP Batch Zero Exposure Framework
To assist a Texas commercial buyer in deciding how much Batch Zero reprice risk to hedge right now, TxCP built an original framework called the TxCP Batch Zero Exposure Framework. It is a 2x2 exposure matrix where the horizontal axis is average site demand and the vertical axis is current contract term. The framework produces a per-buyer exposure rating (Low, Moderate, High, Very High) that drives a specific hedge recommendation for each cell.
| Short-term contract (month-to-month, 3 to 12 months) | Long-term contract (24 months or longer) | |
|---|---|---|
| Small load (under 500 kW) | Moderate exposure. TDU pass-through hits, but load size is small enough that a rate move a fraction of a cent per kWh is absorbable. Reshop at renewal. | Low exposure. Fixed energy rate plus capped size = limited dollar impact. Hold. |
| Mid load (500 kW to 2 MW) | High exposure. TDU rate case in 2028 lands mid-renewal cycle; energy rate is also floating. Consider re-fixing before the Fall 2027 transmission plan is published. | Moderate exposure. Energy rate is locked, but TDU charges still pass through. Model the delta before renewing early. |
| Large mid-market (2 MW to 75 MW) | Very high exposure. TDU charges are a material line item at this size, and short-term contracts reprice into both energy and TDU movement. Fix in soon. | Moderate to high exposure. TDU pass-through is the residual risk; consider index-plus-TDU visibility clauses at renewal. |
The framework is a decision aid, not a forecast. It says: at your size and contract profile, which lever moves the most dollars if Batch Zero-driven transmission upgrades land in the next TDU rate case?
Will Batch Zero raise Texas commercial electricity rates?
The direct answer: not immediately, and not through the energy component of a commercial bill. Batch Zero is a queue-management reform, not a rate case. It does not affect the wholesale price of electricity ERCOT clears in the day-ahead or real-time market, and it does not affect the retail offerings REPs are providing right now.
The indirect answer: yes, over a 24 to 48 month horizon, assuming the Fall 2027 transmission plan entails a significant new build. Every transmission mile ERCOT approves gets built by a TDU, and every TDU is allowed to recover its capital investment plus a return through rate cases filed at the PUCT. Those cases flow into the non-energy portion of the commercial bill (transmission and distribution charges).
TxCP's July 2026 data set provides commercial buyers a live baseline for future comparisons:
- 493 active commercial plans across the 5 ERCOT-region TDUs.
- Market average commercial rate: 10.73 cents per kWh.
- Short-term (1 to 12 months) plan average: 11.63 cents per kWh, from 369 tracked plans.
- Mid-term (13 to 23 months) plan average: 8.63 cents per kWh, from 52 tracked plans.
- Long-term (24 months plus) plan average: 7.76 cents per kWh, from 37 tracked plans.
The gap between short and long-term energy rates is substantial: entering into a 24-month-plus contract today secures a rate approximately 33 percent lower than the short-term market average. That discrepancy acts as a hedge against multiple risks at the same time: summer scarcity pricing, TDU rate-case outcomes, and the transmission cost recovery that Batch Zero will eventually surface. The TxCP complete guide to Texas commercial electricity rates breaks these components out on a sample bill.
By TDU territory, the median commercial rate ranges from 9.76 cents per kWh in AEP Central to 11.85 cents per kWh in AEP North, with Oncor at 10.73 cents, CenterPoint at 9.89 cents, and TNMP at 11.55 cents. That 21 percent spread across TDU territories tells commercial buyers with multi-site operations to shop each meter separately, because Batch Zero transmission recovery will not flow into every TDU rate case at the same pace.
The state Legislature has also granted TDUs a control mechanism separate from Batch Zero. The 2026 TDU rate hike cycle, covered separately, has already begun to weave into commercial bills in 2026. Batch Zero-driven transmission is a 2028-and-beyond story on top of that.
What should Texas commercial buyers do right now?
For a business with less than 75 MW, Batch Zero is not an action item. The rate environment surrounding it is. Four moves are defensible on the data:
- Reprice your contract against the current TxCP market averages. If your renewal offer is significantly higher than the 10.73 cent per kWh market average for your TDU and load size, shop it against the plan pool. The wider the offered rate is from the market median, the more potential there is to close the gap without changing REPs.
- Consider extending contract term before Fall 2027. Current data for long-term commercial plans in TxCP show pricing 33 percent below short-term averages. If your load profile is consistent, securing a 24-month-plus rate now moves you off the segment of the curve most vulnerable to TDU rate-case pass-through in 2028.
- Enroll flexible load in a demand response program. If you have processes that can shift, ERCOT and TDU-run demand response programs monetize that flexibility. NRG/CPower's 2026 expansion and ERCOT's July 2026 curtailment rules both created pull for mid-sized commercial and industrial participants.
- Track the Fall 2027 transmission plan. ERCOT will publish the Batch Zero transmission plan in Fall 2027. The size of that plan is the leading indicator for the 2028 TDU rate-case impact on commercial bills. TxCP will republish rate baselines following that release.
Understanding Batch Zero as "good" or "bad" policy is not the point of any of the above. Each item represents a lever a commercial buyer already had, and the value of these levers simply increases as the transmission-recovery story continues to unfold publicly.
Sources
- ERCOT News Release, "PUCT Approves ERCOT's New Batch Connection Process for Large Electricity Users," June 18, 2026.
- ERCOT Trending Topic, "New Batch Connection Process for Large Electricity Users," PDF, June 18, 2026.
- RTO Insider, "ERCOT Board Endorses Batch Zero Rule Changes," June 3, 2026.
- Willkie Farr and Gallagher LLP, "ERCOT Approves Implementing New Batch Zero Process for Large Load Interconnections," June 2026.
- Sheppard Mullin, "PUCT Approves Batch Zero Framework," June 2026.
- Utility Dive, "ERCOT, CAISO, PJM interconnection queue scorecard," 2024.
- TxCP Live Plan Catalog, July 2026 snapshot (texascommercialplans.com).
Frequently Asked Questions
When was ERCOT Batch Zero approved?
The Public Utility Commission of Texas approved Batch Zero on June 18, 2026, along with NPRR 1325 and PGRR 145. The ERCOT Board of Directors unanimously endorsed the framework at its June 2, 2026 meeting.
What size electricity load qualifies for Batch Zero?
A single site must have peak electricity demand of more than 75 MW to qualify. Any business with a load less than 75 MW does not participate in Batch Zero.
Does Batch Zero apply to small businesses or retail customers?
No. Small commercial customers, including offices, warehouses, retail sites, and most mid-market industrial sites, are well below the 75 MW threshold. They connect with their TDU under the same rules that existed before June 18, 2026.
How many large-load projects are in the ERCOT queue?
ERCOT confirmed on June 18, 2026 that the large-load interconnection queue holds 438,076 MW of proposed demand, of which nearly 90 percent is from data centers.
Will Batch Zero increase my commercial electricity bill?
Not the energy component, and not immediately. Over a 24 to 48 month time frame, the transmission upgrades ERCOT authorizes in the Fall 2027 transmission plan will be included in TDU rate cases, which all Texas commercial customers contribute to via the non-energy portion of the bill. Long-term fixed-rate energy plans hedge the energy side of that risk but not the TDU side.