# Texas Senate Bill 6: Large-Load Interconnection and Curtailment

Updated September 21, 2026.

How Texas Senate Bill 6 governs ≥75 MW large loads in ERCOT, what the PUCT adopted in §25.194, and why that sits next to the Batch Zero audit.

Senate Bill 6 is the 2025 Texas statute that rebuilt how large loads connect in ERCOT. Governor Abbott signed it on June 20, 2025. The default threshold is 75 MW at a single site — the same cut Batch Zero later used. The bill does not itself freeze interconnection. It directs the Public Utility Commission of Texas to write the standards: study process, site control, financial commitment, net metering for co-located generation, and when ERCOT may curtail or disconnect large load under stress.

Implementation is a stack of PUCT projects, not a single order. Interconnection standards, forecasting criteria, reliability and demand-reduction rules, and transmission cost allocation have been moving on separate clocks through 2026. Developers have been underwriting against the drafts, not waiting for a neat effective date.

## The first net-metering case

On July 24, 2026 the PUCT issued its order in Docket No. 59220, the first net-metering application under SB 6 for a data-center large load paired with a standalone generator. The commission held that emergency curtailment on the co-located load is not capped by the capacity of the paired behind-the-meter generator. The reliability objective, as the order framed it, is to make the existing generator fully available to the ERCOT grid during transmission emergencies.

That is the operational gate. Co-located load that cannot curtail — including physical disconnection if other methods fail — does not get a free ride on the generator's nameplate. White & Case's note on the order is the citation we use; the docket is the primary.

## What SB 6 is not

SB 6 is not the August 2026 Batch Zero pause. The pause is an audit directive layered on top of the statute. The statute is the standing rulebook: Texas will interconnect large load that can be studied, secured, and curtailed, and it will not let co-location socialize reliability risk onto the rest of the grid.

On September 18, 2026 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. The HD Market Scorecard held ERCOT at A-. The adopted rule is that security number, not a new freeze and not a thaw.

## How HD scores it

Large-load tariff and moratorium climate is 20% of the HD Market Scorecard. SB 6 is why ERCOT's climate is no longer an A even before the audit. Combined with time-to-power at 35%, the two Texas factors are 55% of the grade. Curtailment risk sits on the interconnecting customer. Powered land with a contracted, ring-fenced path still clears. Load that assumed unconstrained co-location does not.

## Sources

1. [Texas Senate Bill 6: Understanding the Impacts to Large Loads and Co-located Generation — Baker Botts, July 2025](https://www.bakerbotts.com/thought-leadership/publications/2025/july/texas-senate-bill-6-understanding-the-impacts-to-large-loads-and-co-located-generation)
2. [PUCT affirms curtailment authority over co-located data centers in first net metering case under Senate Bill 6 — White & Case](https://www.whitecase.com/insight-alert/puct-affirms-curtailment-authority-over-co-located-data-centers-first-net-metering)
3. [PUCT Project 58481 — Order Adopting new 16 TAC §25.194, filed Sep 18 2026; effective Oct 8 2026](https://interchange.puc.texas.gov/search/filings/?ControlNumber=58481)
4. [ERCOT Market Notice M-A080326-01 — Update Regarding Batch Zero Timelines](https://www.ercot.com/services/comm/mkt_notices/M-A080326-01)

HTML: https://hyperscapedigital.com/scorecard/explainers/texas-sb6