Batch Zero is ERCOT's first study cohort under the large-load interconnection process the Public Utility Commission of Texas approved on June 18, 2026. Requests of 75 MW and above are studied together rather than one at a time. Classification notices to interconnecting transmission and distribution providers were due August 7, 2026. Study results had a nominal date of April 9, 2027.
The queue behind that process is the number everyone now cites: roughly 474 GW of interconnection requests, about 90% of it data centers, more than five times ERCOT's record peak demand. Batch Zero was the attempt to make that queue legible — to separate projects that can post security, show site control, and take a study position from placeholders.
The August pause
On August 3, 2026 Governor Abbott directed ERCOT and the PUCT to audit data-center load before advancing projects. ERCOT's Market Notice M-A080326-01, issued the same day, said it would not deliver the August 7 Batch Zero classifications. Legal counsel read the pause as lasting several months and less than nine. ERCOT sought good-cause exceptions at the PUCT for the Planning Guide timelines it was about to miss.
By late August the pause had teeth beyond classification. ERCOT skipped the August 7 notices and said it will not authorize data-center or crypto load at or above 75 MW to energize until it finishes a project-by-project verification of MW, site control, financial security, and ownership. At least six projects aimed at Q1 2027 energization, and up to seventeen more at Q2 2027, face slippage. Narrow exceptions to join stability assessments do not authorize energization.
The December 10 clock
On August 21 ERCOT told regulators it aims to finish the audit by December 10, with information requests going to provisionally qualified large loads as early as late August. Roughly 300 loads of 75 MW or larger sit in Batch Zero. ERCOT has also said the long-term load forecast and reliability study will slip past April 9, 2027. New large-load interconnection is effectively paused until the audit closes.
Conditional classifications
On September 3 ERCOT issued Market Notice M-A080326-04: provisional Batch Zero classifications to interconnecting transmission and distribution providers, three days after M-A080326-03 delayed the August 31 date for data validation. ERCOT published no list, no megawatt total, and no names. Classification is conditional on verification, curing dynamic-model data, or a PUCT good-cause exception; ERCOT will not seek an exception for every Large Load that asked. A Base-to-Studied reclassification has a Planning Guide dispute clock. Miss the 14-business-day eligibility cure after utility notice and the load waits for a future study cycle rather than interconnecting on the ERCOT transmission system. Classification is not energization. The freeze on ≥75 MW computational load still runs to the December 10 audit.
The September verification RFIs
On September 9 ERCOT issued Market Notice M-A090926-01 and began sending 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, including notarized attestations from the load, the interconnecting TSP, and the interconnecting DSP, are due in RIOO within 10 business days of issuance. One extension of no more than 5 business days may be requested. Failure to answer completely, or to satisfy verification, excludes the load from Batch Zero. A separate community-impact RFI has been announced and has not issued. The RFIs are the December 10 audit operating. They are not a second freeze.
That is a filter, not a ban. The audit conditions projects on energy self-sufficiency (on-site generation progress), independent water, and financial self-sufficiency versus public incentives. Bring-your-own-power structures that sidestep the shared-grid queue — NRG's reported 1.2 GW hyperscaler agreement is the example on the tape — still clear. Grandfathered capacity ERCOT has said remains cleared to energize in 2026 still energizes.
How HD scores it
Time-to-power is 35% of the HD Market Scorecard. Large-load tariff and moratorium climate is 20%. The Batch Zero pause hit both, which is why ERCOT moved from A to A- on August 17 and held there through the December clock, the energization freeze, the September 3 conditional sort, and the September 9 verification RFIs. One notch: the pause is finite, ERCOT still has the deepest uncommitted capacity and the lowest forward prices on the board, and the audit favors the self-generation path the platform already underwrites. Conditional classification is a sort. The RFI is the paper clock. Energization still waits on December 10.
Raw queue position lost optionality. Executed interconnection standing, clean attestations, and behind-the-meter paths gained it. That re-pricing is the point of Batch Zero as it is actually being run.
