HD Intelligence Desk · September 21, 2026
ERCOT Issues the Community-Impact RFI. The Large-Load Rule Is Filed
Published September 21, 2026
What Happened
On September 14 at 5:07 p.m., ERCOT issued Market Notice M-B091426-01, the State and Community Impact RFI. It goes to Batch Zero data-center loads conditionally classified as base or studied that have not energized at transmission voltage, and to substantiated data-center load of at least 25 MW and under 75 MW reported on the August 19 medium-load RFI. Complete responses, with a notarized developer attestation, are due in RIOO by 5 p.m. CPT on October 12. The TSP or DSP files the response. A miss is reported to the PUCT and the Office of the Governor. Section C, on water, is issued for the Texas Water Development Board under a September 14 gubernatorial letter. ERCOT expects its report by December 10. The notice says this RFI is separate from the September 9 Batch Zero eligibility RFI. On September 18 the PUCT filed the Order Adopting new 16 TAC §25.194 in Project 58481. The Texas Register acknowledgement the same day sets the effective date at October 8. The September 3 staff recommendation that went to that vote set financial security at $50,000 per MW.
Why It Matters
This is a second paper clock, not a second freeze. The September 9 verification RFI still excludes a missed or incomplete response from Batch Zero. The community-impact RFI reports a miss to the commission and the Governor and feeds a December 10 report. It also reaches substantiated load below 75 MW. We hold ERCOT at A-. Trend stays down because both clocks are live and ≥75 MW computational energization is still gated on the audit. The same shock is not cut twice. Section 25.194, effective October 8, is the staff security number made a rule. It is not a thaw.
The rest of the board
SPP's ER26-3685 clarification of Conditional High Impact Large Load policy still has comments due September 23. The path is still open. We hold B+. MISO's ER26-3650 comment date was September 18. No order is located on that docket. That remains process, not reserve margin. Hold C. FERC has not ordered PJM's Reliability Backstop Procurement (ER26-3380) or IRAS. The September 30 bid window is still contingent on that order. Hold D; trend down on the calendar. CAISO's large-load draft final proposal and draft tariff language are still posted for September 24, with a hybrid meeting October 1 and the Board of Governors October 28. Hold C+.
Sources
- 01ERCOT Market Notice M-B091426-01 — State and Community Impact RFI, Sep 14 2026 (responses due Oct 12)
- 02ERCOT Data Center State and Community Impact RFI — Question Reference Guide, posted Sep 18 2026
- 03ERCOT State and Community Impact RFI Attestation, Sep 14 2026
- 04PUCT Project 58481 — Order Adopting new 16 TAC §25.194, filed Sep 18 2026; Texas Register acknowledgement effective Oct 8 2026
- 05SPP §205 filing ER26-3685 — Revisions to Clarify the Conditional High Impact Large Load Policy, Sep 2 2026 (comments Sep 23)
- 06MISO ER26-3650 — Interconnection Reliability Requirements for Large Loads, filed Aug 28 2026 (comments Sep 18)
- 07PJM Answer, Docket ER26-3380-000 — Reliability Backstop Procurement, Sep 10 2026
- 08CAISO Large Loads initiative — draft final proposal posting Sep 24, hybrid Oct 1, Board of Governors Oct 28