HD Intelligence Desk · September 14, 2026
ERCOT Starts the Batch Zero Paper Clock. Energization Still Frozen
Published September 14, 2026
What Happened
On September 9 at 5:58 p.m., ERCOT issued Market Notice M-A090926-01: Batch Zero Verification Requests for Information to a majority of Interconnecting Large Load Entities whose loads are conditionally included in Batch Zero, with more RFIs going out through month-end. Complete responses — supporting documents and notarized attestations from the load, the interconnecting TSP, and the interconnecting DSP — are due in RIOO within 10 business days of issuance, with one extension of no more than 5 business days on request. Failure to answer completely, or to satisfy verification, excludes the load from Batch Zero. The freeze on ≥75 MW computational load still runs to the December 10 audit filing; a separate community-impact RFI has not issued. On September 11 the PUCT approved the 370-mile Howard-Solstice 765 kV CCN (Docket 59336), pending landowner routing. Project 58481, the ≥75 MW interconnection rule, was Item 24 the same day; no adopted-order filing was located on Interchange through September 13.
Why It Matters
This is the audit running, not a second freeze. The 10-day clock is how Batch Zero culls paper: site control and posted security, sworn, or a later study cycle. We hold ERCOT at A-. Time-to-power is still gated on December 10; the same shock is not cut twice. Trend stays down because the exclusion clock is now live and the freeze is intact. A CCN is steel for Permian import. It is not Batch Zero eligibility and not energization. Henry Hub spot printed $2.81/MMBtu on September 9, still below $3.
The rest of the board
SPP filed ER26-3685 on September 2 to clarify Conditional High Impact Large Load policy; comments are due September 23. The CHILL path is still open. We hold B+. MISO's Zero Injection GIA comments landed September 8: Google, Xcel, and a utility group in support; Sierra Club and NRDC opposed. The Interconnection Reliability Requirements filing (ER26-3650) has comments due September 18. That is 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 a September 29 order. Hold D; trend down on the calendar, not a new cost-shift print. CAISO slipped the large-load draft final proposal and draft tariff language to September 24; Board of Governors still October 28. Hold C+.
Sources
- 01ERCOT Market Notice M-A090926-01 — Issuance of Batch Zero Verification Requests for Information, Sep 9 2026
- 02ERCOT Demands Sworn Data Center Proof or Loss of Place — The Texas Dispatch, Sep 13 2026
- 03ERCOT Batch Zero Update — PUCT, Sep 11 2026
- 04After public pressure, Texas OKs more 765 lines — The Texas Tribune (via KRGV), Sep 11 2026 (PUCT Docket 59336)
- 05PUCT Interchange, Project 58481 — Large Load Interconnection Standards (no adopted order located through Sep 13)
- 06SPP §205 filing ER26-3685 — Revisions to Clarify the Conditional High Impact Large Load Policy, Sep 2 2026 (comments Sep 23)
- 07Google, Xcel, others back MISO's 'zero injection' large-load proposal — Utility Dive, Sep 9 2026
- 08MISO ER26-3650 — Interconnection Reliability Requirements for Large Loads, filed Aug 28 2026 (comments Sep 18)
- 09PJM Answer, Docket ER26-3380-000 — Reliability Backstop Procurement, Sep 10 2026
- 10CAISO Large Loads initiative — draft final proposal posting Sep 24, Board of Governors Oct 28
- 11Henry Hub Natural Gas Spot Price — FRED / EIA, $2.81/MMBtu on Sep 9 2026