TexasElectricity.org · Deep Dive · Large Loads
How to Get Power for a New Data Center in Texas
How a new data center actually gets electricity in Texas: from the first land search to the day the racks light up. Written for curious readers and for the teams who have to get it done, and updated for the rules ERCOT and the PUCT put in place in 2026.
The short version
A data center is, electrically, one of the largest customers a utility will ever connect. A single AI campus can want 300, 500 or 1,000 megawatts. For scale, ERCOT says one megawatt can serve about 250 Texas homes on a hot summer day.11 A 500 MW campus wants roughly what 125,000 homes use at peak, delivered every hour of the year, at a single address.
Getting that much power to one spot in Texas is a sequence of gates. You find land near strong transmission. You sign up with the utility that owns the wires there. You put money down, the utility and ERCOT study whether the grid can carry your load, and ERCOT tells you how many megawatts you can have and when. You sign a standard agreement, post more security, pay for your own connection equipment, and wait while a substation (and sometimes new transmission lines) gets built. Then you prove your facility will behave on the grid, register, and energize in steps.
Since 2025 that sequence has been rewritten. Senate Bill 6 gave the Public Utility Commission of Texas (PUCT) authority to standardize how large loads connect, what they pay, and when they can be curtailed.19 ERCOT replaced its one-project-at-a-time studies with a batch study that looks at every eligible project together.3 And in the second half of 2026 the state paused new data center interconnections and permits while it audits data centers' grid use, water use and community impacts.
Plan for three to six years from site search to full load on a large greenfield campus, with the power timeline, not the building, setting the pace. The rest of this guide explains each gate, what it costs, and where projects stall.
Why power is the hard part
The building is rarely the bottleneck. Shell, cooling and fit-out typically take about two years. The bottleneck is that Texas has far more requests for power than it has grid to deliver it.
ERCOT's large-load queue, in context
Large load requests compared with ERCOT's grid. Horizontal bars: about 474 gigawatts of large-load requests; about 194 gigawatts conditionally included in Batch Zero as of September 2026; about 91.1 gigawatts preliminary all-time peak demand set July 22, 2026; about 9.5 gigawatts approved to energize.
| Measure | Gigawatts |
|---|---|
| Requests in queue | ~474 GW |
| Batch Zero included | ~194 GW (Sept., conditional) |
| Record peak demand | ~91.1 GW (July 2026, prelim.) |
| Approved to energize | ~9.5 GW |
ERCOT says it is tracking roughly 474 GW of large loads seeking to connect, with about 90% of that from data centers.4 That is not a realistic forecast and ERCOT does not treat it as one. ERCOT's 2025 long-term load forecast report found that sites reached on average 49.8% of the megawatts they had requested, and in its April 2026 forecast filing ERCOT cautioned against planning on raw request totals.23 Many requests are duplicates: one developer shopping the same campus to several utilities, or several developers chasing the same parcel.
Even approved load is not yet running at full size. Of the 9,456 MW of large loads ERCOT has approved to energize, the sum of their individual monthly peaks was about 4.1–4.4 GW in July through September 2026.22 Another 17 data center and crypto loads, about 6.6 GW of planned peak demand, have finished every ERCOT step except approval to energize, and are held by the 2026 pause.35
That speculation is exactly what the 2025 and 2026 reforms target. Nearly every new requirement in this guide, from site-control proof to per-megawatt collateral, exists to make a queue position cost something so that only serious projects hold one.
The grid side is growing too. In April 2025 the PUCT approved a Permian Basin plan built on Texas's first 765-kV lines, three new import paths, with individual line routes certified separately; ERCOT's board endorsed the rest of a 765-kV backbone in December 2025.30 Those lines take years to permit and build. In the meantime, available capacity at any specific substation is what decides your project's fate.
Who you will deal with
Texas is unusual. About 90% of the state's load sits on the ERCOT grid, which is mostly isolated from the rest of the country and regulated in Austin rather than by FERC. The rest of Texas belongs to other regional grids. Which one your site sits on changes nearly everything that follows.
ERCOT Texas versus the rest of Texas
Outside ERCOT, four pieces of Texas sit on other grids: far West Texas around El Paso (El Paso Electric, Western Interconnection), much of the Panhandle and South Plains (Xcel Energy's SPS, in the Southwest Power Pool), parts of Northeast Texas (SWEPCO, also SPP), and Southeast Texas around Beaumont (Entergy Texas, MISO). Those utilities are vertically integrated: they own generation and wires and sell you power under a tariff. Their large-load processes follow their own tariffs and their regional operator's rules, not ERCOT's batch study, though the PUCT still regulates their rates.
Inside ERCOT, the split that matters is competitive versus non-competitive territory. In the areas served by the big investor-owned wires companies, you choose your electricity supplier. In most electric cooperative and municipal utility areas (CPS Energy in San Antonio, Austin Energy, and most co-ops), you buy from the utility. SB 6's standards apply to these utilities too, but the law lets co-ops and city utilities add their own requirements on top.19
How power reaches the racks
It helps to picture the physical chain before getting into paperwork. Every requirement in the process maps to one of these links.
From power plant to server
Power delivery chain for a grid-connected data center. Generation feeds high-voltage transmission at 138, 345 or 765 kilovolts. The utility builds a switching station at the point of interconnection, where the revenue meter sits. Power then flows to the customer substation, which steps it down to medium voltage, then through switchgear and UPS systems to the server racks. Backup generators and optional on-site generation sit behind the meter.
GRID / UTILITY SIDE
- 01Generation
gas, wind, solar, storage, nuclear
- 02Transmission
138 / 345 / 765 kV
- 03Switching station
utility-owned, you pay (CIAC)
Batch study decides how many MW can flow across this line, and when.
CUSTOMER SIDE (BEHIND THE METER)
- 04Customer substation
transformers step to 34.5 or 13.8 kV
- 05MV switchgear
+ UPS / batteries
ride-through - 06IT load
racks, GPUs, cooling plant
SB 6: disclose if they can carry 50%+ of load
optional: turbines, engines, solar + storage (WLPUN)
New lines need a PUCT certificate (CCN) and can add years.
Large campuses almost always connect at transmission voltage (typically 138 kV or 345 kV in ERCOT) rather than to a distribution feeder. That makes your wires company a Transmission Service Provider (TSP) and puts you in ERCOT's large-load process. Loads that connect to a distribution system work through a Distribution Service Provider (DSP), but at 75 MW and above they land in the same ERCOT process.1
The thresholds that matter:
- 75 MW or more at one site: a "Large Load." Triggers ERCOT's large-load interconnection process and the PUCT's SB 6 standards, including study fees, security, and curtailment obligations.7
- Large Computational Load (LCL): a Large Load where at least half the site demand is computing, meaning data centers and crypto mines (earlier drafts called it a Large Electronic Load). These carry extra ride-through requirements.1718
- 25 to 75 MW: "medium" loads. Below the main process, but ERCOT included data centers of 25 MW and up in its 2026 community-impact survey, which covered 214 medium data centers.1011
The 75 MW test also applies to expansions: a site crossing 75 MW for the first time, or an existing 75 MW+ site adding another 75 MW or more, is treated like a new interconnection.7
Site selection and land
In Texas today, power is the site-selection criterion. Land, fiber, water and labor still matter, but a parcel with good fiber and no available transmission capacity is a parcel with a five-year wait.
What to screen for
- Distance to high-voltage lines and substations. Proximity to an existing 345 kV line or a substation with spare transformer capacity is worth more than almost any other attribute. Each mile of new line is cost, right-of-way and permitting time.
- Headroom on the local grid. A substation can be close and still saturated by other large loads already allocated there. Utilities and consultants can run informal capacity screens before you file anything. Ask for them.
- Who the utility is. Competitive versus co-op or city territory changes your supply options, your contract, and sometimes your speed. Non-ERCOT parts of Texas follow a different process entirely.
- Congestion and pricing. ERCOT prices vary by location. A West Texas site near wind and solar may see cheap midday prices and transmission congestion; a site near Dallas or Houston may see higher but steadier prices.
- Gas supply. If you might build on-site generation, a nearby high-pressure pipeline with firm capacity is now a first-tier criterion.
- Water. Evaporative cooling needs large volumes. Local water availability is now under explicit state scrutiny (see Permits).
- Community and local rules. Setback ordinances, noise limits and local opposition have become real schedule risks. The Governor's September 2026 conditions explicitly include compliance with local setback ordinances.7
Site control is now a regulatory requirement
Land used to be something you locked up after power looked promising. Not anymore. Texas rules now require proof that you control the site before you can hold a place in line. ERCOT's 2026 planning compliance plan, for example, counts a large load in its forecast only with a deed or a lease running at least five years past the expected peak-demand date.37 The 2026 audit went further, asking projects to prove readiness with deeds, leases and permits.11
SB 6 also requires you to disclose whether you have substantially similar requests pending elsewhere in Texas.38 Multi-site shopping is still legal, but it is no longer invisible, and each request now carries its own fee and collateral.
Your utility and the first agreement
Your formal entry point is the wires company that serves the site. You do not apply to ERCOT directly. The utility (TSP or DSP) is your sponsor and submits your project into ERCOT's process.
Early conversations
Before anything formal, utilities typically hold pre-application meetings, discuss feasible points of interconnection, and give a rough sense of what upgrades a site would need. Many now charge for engineering studies even at this stage. CPS Energy, for example, has started charging fees for large-load engineering studies.39
The intermediate agreement (the SB 6 entry ticket)
Under the PUCT's final rule, adopted September 18, 2026, nothing gets studied until you sign an intermediate agreement with the utility and do four things:7
- Pay a $100,000 study fee. The PUCT dropped the tiered fees and the non-refundable $50,000-per-MW charge it had proposed in March.8
- Submit technical disclosures attested by a company officer: requested peak demand, ramp schedule, equipment, backup generation and similar details.
- Post financial security of $50,000 per MW of requested peak demand. For a 300 MW request, that is $15 million before any study starts.
- Provide site control evidence: a deed, a lease running at least five years past the date the load reaches its requested peak, or a signed purchase or lease option, plus disclosure of the state and local approvals still needed.66
Once that is done, the utility has 60 days to contact ERCOT to start your study.7 False or unsupported disclosures are not a paperwork issue; the rule allows penalties up to losing allocated transmission capacity.7
Engineering models are part of the application
ERCOT requires detailed electrical models of how your facility behaves, including dynamic models showing how it responds to faults and voltage dips. These were a hard eligibility gate for Batch Zero: projects that did not submit dynamic models by the deadline were excluded.4 Your electrical engineer and your UPS and power-electronics vendors need to be involved from the start, not after the study.
ERCOT's batch study
Until 2026, each large load got its own study, usually performed by the utility and reviewed by ERCOT. The problem: whenever a new project showed up nearby, earlier studies could become invalid and need to be redone. With hundreds of projects landing in the same areas, that loop never ended.4
The fix is a batch (cluster) study. ERCOT gathers every eligible request, studies them together against the grid's actual capability, and allocates megawatts by year. The capacity that comes out of a study is reserved, which prevents endless restudies.4 ERCOT describes itself as the first U.S. grid operator to use a batch process to connect large loads.3 The PUCT approved the framework on June 18, 2026.3
Batch Zero: the transition batch
"Batch Zero" is the one-time first batch for projects already in the pipeline. Its eligibility deadlines fell in July 2026. Projects were sorted into three groups:342
- Base load: projects that had already completed prior individual studies and met a higher bar. They are modeled as existing background load.
- Studied load: eligible projects that get evaluated in the batch and receive year-by-year allocations.
- Excluded: projects that missed requirements. They wait for a future batch.
In September 2026, ERCOT conditionally included 362 projects in Batch Zero (204 as base load, about 66 GW; 158 as studied load, about 126–128 GW) and excluded 373 projects totaling about 302 GW, with final classifications due after the audit.5
The Batch Zero path, with the 2026 audit
Batch Zero process steps and dates. Step 1, eligibility package due July 10 to 24, 2026. Step 2, classification, originally August 7, now conditional. Step 3, the Governor's audit, with reports due December 10, 2026. Step 4, the batch study, originally targeted to deliver results April 9, 2027, now delayed. Step 5, sign the interconnection agreement and post security by a deadline to be reset after the audit (originally about 30 days after results). Step 6, refinement study and transmission plan. Step 7, energize in stages.
- 1 · EligibilityJul 10–24, 2026
Dynamic models, attestations, PCLR election
- 2 · Classificationconditional
Base / studied / excluded
- 3 · State auditreports Dec 10
Grid, water, money, ownership, community impact; deeds, permits
- 4 · Batch studywas Apr 9, 2027
MW by year, LPC and MPC
- 5 · Commitdeadline TBD
Sign SLLIA, post security
- 6 · Transmission planrefinement study
Upgrades and cost estimates
- 7 · Energizein stages
QSA, registration, commissioning
- ERCOT postponed the Batch Zero study (set to begin by Sept. 2) and gave only conditional classifications.
- It paused approvals to energize data centers and crypto sites of 75 MW+ (other large loads can still proceed).
- Failing or ignoring eligibility verification means disqualification; skipping the separate community-impact survey (due Oct. 12) gets a project reported to the PUCT and Governor.
What the study gives you: LPC and MPC
Each studied project receives two numbers per year for the first six years:6
- LPC (Low Power Consumption): the firm megawatts you can draw from the grid with no obligation to curtail.
- MPC (Maximum Power Consumption): your full requested peak.
If you made no special election, you are capped at your LPC. (The PCLR election described next is available to studied loads.) The gap between the two is where the interesting options live.
Firm versus flexible megawatts (illustration)
Illustrative LPC and MPC allocation over six years. Hypothetical 300 megawatt project. Maximum power consumption is 300 megawatts every year. Firm allocation, the LPC, rises from 75 megawatts in year 1 to 120, 180, 240, then 300 in years 5 and 6. The gap above the firm amount is available only under the controllable pathway.
| Year | LPC (MW) | MPC (MW) | MPC gap (MW) |
|---|---|---|---|
| 1 | 75 | 300 | 225 |
| 2 | 120 | 300 | 180 |
| 3 | 180 | 300 | 120 |
| 4 | 240 | 300 | 60 |
| 5 | 300 | 300 | 0 |
| 6 | 300 | 300 | 0 |
The PCLR option: trade flexibility for speed
A Provisional Controllable Load Resource (PCLR) can energize above its LPC, up to its MPC, if it agrees to follow ERCOT's dispatch instructions at all times, including instructions to cut consumption. ERCOT does not guarantee you can actually run at MPC in real time.6 You stay in this mode until an exit date set by the study, when transmission upgrades make the capacity firm, and during that time you cannot sell ancillary services.40
Whether PCLR makes sense depends on your workload. AI training runs that can checkpoint and pause, or crypto-style flexible loads, may live comfortably with curtailment. A colocation facility with uptime SLAs to tenants generally cannot, unless on-site generation covers the gap.
For Batch Zero, the PCLR election was a two-step commitment: a notarized declaration of intent with the July eligibility package (including the minimum LPC you would accept each year), then acceptance of the actual results with your signed interconnection agreement after the study.41 If the grid cannot reliably support even that minimum in a given year, the project's allocation for that year is zero.60 PCLR obligations also transfer automatically to a buyer in an acquisition or financing.6
After Batch Zero: Batch 1 and beyond
The permanent process runs recurring batches. ERCOT described clustering requests roughly every six months, and before the audit had planned to open Batch 1 applications in summer 2027.42 Treat that date as provisional until ERCOT confirms the post-audit schedule. A new project that starts today should plan to enter Batch 1 or a later batch, and should start the land, model and agreement work now so it is ready when the window opens.
What it costs to get in line
The SB 6 rule turned interconnection into a staged financial commitment. Here is how the money moves under 16 TAC §25.194.7
Money at each gate, 300 MW example
Financial commitments for a hypothetical 300 megawatt project. At the intermediate agreement: $100,000 study fee and $15 million security. At the standard agreement: security equal to the greater of $15 million or the allocated transmission upgrade cost, plus direct interconnection costs paid as contribution in aid of construction before they are incurred. At first energization, 20 percent of security is returned. The remaining 80 percent is released in 20 percent steps as milestones are met. Withdrawal after allocation forfeits 20 percent.
- GATE 1 · Intermediate agreement$15.1M
$100k study fee
+ $50k/MW security
Security back (less owed) if you exit pre-study or get 0 MW; fee not refunded - GATE 2 · Standard agreement≥ $15M
Greater of $50k/MW or your allocated upgrades
Exit now: lose 20% of that security - DURING BUILD · CIACSite-specific
Direct connection costs, invoiced before the utility spends them.
Not refundable. - AFTER GO-LIVE · Security released20% + 4×20%
20% at energization, then 20% steps as you pay minimum billing demand
Miss your energization date by more than 24 months and the utility tells ERCOT your capacity is unused, applies your security to what you owe, and returns the balance within 60 days. Security is based on gross contracted peak; on-site or backup generation does not reduce it.
The Standard Large Load Interconnection Agreement (SLLIA)
After ERCOT allocates capacity, you sign the SLLIA, update your disclosures, and true up security to the greater of $50,000 per MW of contracted peak or your allocated share of transmission upgrade costs.7 The PUCT is writing a separate rule for the standard agreement itself, which will fold in the disclosure, financial and technical requirements from the other SB 6 rules.43
Contribution in aid of construction (CIAC)
You pay the utility up front for the facilities built specifically to connect you, such as the switching station and the line tap. Under the rule, the utility invoices those costs before incurring them, and the payment is not refundable.744 For a transmission-level campus these direct connection costs are site-specific and can be substantial, especially if a new line is needed.
Minimum billing demand: paying for capacity you reserved
The SLLIA obligates you to pay a large load minimum billing demand under the utility's transmission cost recovery factor.7 In plain terms, you pay transmission charges based on capacity you contracted for, even if your actual usage ramps up slowly. The PUCT's July 2026 proposal in Project 58000 floated fixing that minimum for 20 years and asked whether it should phase down or ratchet instead.45 This is one to watch closely, because it determines what an under-used campus costs to carry.
4CP to 12CP: the transmission-charge rule is changing
ERCOT-area transmission costs have long been allocated using "four coincident peak" (4CP): your share is based on your demand during the single highest 15-minute interval in each of June through September. Large flexible customers have saved heavily by dropping load during those intervals. SB 6 required the PUCT to review whether 4CP still assigns costs fairly and to amend its rules by December 31, 2026.20 In July 2026 the PUCT proposed, in Project 58000, to replace 4CP with a 12-coincident-peak (12CP) method measured on 30-minute intervals, one peak in every month, and to add a large-load tariff rule (new §25.252) with a minimum billing demand lasting at least 20 years. That minimum is the greater of contracted peak, the prior year's highest demand, or 12CP demand. Comments closed August 11, and the PUCT has said it expects a final decision in December 2026.4562 If you are modeling operating costs that assume 4CP avoidance, treat that savings as likely to shrink or disappear.
Building the substation
Once your capacity is allocated and the agreement is signed, the physical work begins. The utility designs and builds the facilities on its side; you build your customer substation and everything behind the meter. If network upgrades or a new line are needed, those go through ERCOT's Regional Planning Group and, for new lines, a PUCT certificate of convenience and necessity (CCN). The statute sets a 180-day decision deadline for most CCN cases, but routing, landowner notice and construction add much more.
Long-lead equipment is the real critical path
The single biggest physical constraint right now is equipment. Large power transformers are custom-built, depend on specialized electrical steel, and are mostly imported.
Typical lead times, 2026 (weeks)
Equipment and on-site generation lead times. Ranges in weeks. Data-center-class switchboards, 52 to 84 or more. Pad-mounted transformers, 68 to 113 per Cushman and Wakefield. Backup generators, 60 to 100. Large power transformers, about 128 average. Generator step-up transformers, about 144 average. On-site generation, delivery through commissioning: reciprocating engine plants 104 to 130 weeks; gas turbine plants 130 weeks or more.
ON-SITE GENERATION — DELIVERY THROUGH COMMISSIONING
| Equipment | Weeks |
|---|---|
| Switchboards (DC class) | 52–84+ |
| Pad-mount xfmrs (C&W) | 68–113 |
| Backup generators | 60–100 |
| Large power transformer | ~128 avg |
| Generator step-up xfmr | ~144 |
| Recip. plant (to operation) | 104–130 |
| Gas turbine plant (to oper.) | 130+ (30+ mo) |
Because those waits now exceed a typical study cycle, serious developers place reservation orders or slot deposits for transformers and switchgear before their allocation is known, accepting the risk of owning equipment for a project that may change. Utilities face the same problem on their side of the meter, and some are buying substation transformers years ahead of specific projects.47
Phased ramp
Very few campuses energize all at once. Your Load Commissioning Plan, agreed with the utility, sets out how many megawatts come online in each step and when. Batch study allocations are by year, and your building phases should be designed to match.32
On-site and co-located power
With grid timelines stretching, many Texas projects now plan to make some or all of their own power. Texas leads the nation in gas plants proposed for data centers, and roughly half of the gas generation under development in the state is expected to run off the grid, serving data centers directly.48 The Stargate campus in Abilene, for example, pairs its ERCOT connection with permitted on-site gas generation, including aeroderivative turbines, which analysts expect could serve as primary power in early phases.49
| Option | How it works | Main advantage | Main catch |
|---|---|---|---|
| Grid only | Standard batch allocation, firm up to LPC | Simplest operations; market supply options | Speed limited by batch timing and upgrades |
| Grid + PCLR | Run above LPC under ERCOT dispatch until exit date | More megawatts sooner | Must curtail on instruction; no ancillary service sales |
| Grid + backup gens | Diesel or gas gens for reliability | Uptime protection | If they can carry 50%+ of load, ERCOT can order you onto them in emergencies |
| Bring your own generation (WLPUN) | On-site generation netted against load behind an enforceable grid-withdrawal limit | Smaller grid draw; treated more favorably in batch study | Generation equipment lead times, air permits, fuel price risk |
| Co-locate with an existing plant | Net-metering arrangement with a plant already in ERCOT | Existing power and interconnection | ERCOT study (120 days) plus PUCT approval (60 days); curtailment conditions |
| Medium load (25–<75 MW) | Utility's own approval-to-energize process, outside the batch | Not affected by the 2026 energization pause | Size cap; still covered by the community-impact survey |
| Non-ERCOT utility | Integrated utility tariff or special contract | Outside the batch process | Long minimum terms (e.g., El Paso Electric's proposed 20 years); state permit pause still applies |
| Fully islanded | No grid connection at all | Outside ERCOT's interconnection process | You carry 100% of reliability; permits still required (and currently paused) |
Withdrawal-Limited Private Use Networks
ERCOT's batch rules include a WLPUN pathway, sometimes called "bring your own generation." On-site generation and load operate together behind a hard limit on how much the site can pull from the grid at its single point of interconnection, with that limit set by the batch study.3426 Analysts note that loads with their own generation are treated more favorably in the batch process.50 The trade is that you take on the generation, its fuel, and its permits.
Co-locating with an existing power plant
Putting a data center next to an existing plant and taking its output behind the meter was an attractive shortcut, and SB 6 made it a regulated one. New net-metering arrangements between a 75 MW+ load and a standalone generator that was already registered with ERCOT as of September 1, 2025 need an ERCOT study (up to 120 days) and PUCT approval (within 60 days after that).16 The PUCT approved its first arrangements under the new rule in spring 2026: a 265 MW data center beside a 265.5 MW wind farm in Armstrong County (April) and a 760 MW data center at a 1,099 MW gas plant in Freestone County (May). In each case the load must cut use or switch to backup, and the plant must return its output to the grid, within 30 minutes of an ERCOT instruction.61 A July 23, 2026 order (Docket 59220), covering a second data center at the Armstrong County wind site, went further. Emergency curtailment is not capped at the paired generator's output: the data center must disconnect fully from the ERCOT system on instruction during a transmission emergency, and it may not participate in ERCOT or utility demand response or ancillary service programs.1565 New generation built specifically for a load is not subject to this pre-approval requirement.19
Operating rules you sign up for
Connecting is not the end of your obligations. Several 2025–2026 rules govern how a large data center must behave once it is on the grid.
Emergency curtailment and backup generation
SB 6 requires you to disclose on-site backup generation that cannot export to the grid but can serve at least half your demand. During an energy emergency, ERCOT can give notice directing such customers to either run that backup generation or reduce load.20 Separately, utilities must have a way to remotely curtail transmission-voltage customers during firm load shed, and large loads connected after December 31, 2025 must have the equipment to make that possible.19 ERCOT held a workshop on October 6, 2026 on the deployment mechanics and registration for SB 6 curtailment.51
Ride-through (NOGRR 282)
In several grid events, large computing loads dropped offline all at once when voltage dipped, which itself destabilizes the grid. ERCOT's NOGRR 282 requires Large Computational Loads to ride through defined voltage and frequency disturbances rather than trip. The PUCT approved it July 9, 2026 and it took effect August 1, 2026.52 This drives real design choices in your UPS, power-supply and protection settings, and some conventional low-voltage UPS designs struggle to comply.53 Confirm your electrical design against the final NOGRR 282 tables before you buy equipment.
Large Load Demand Management Service
SB 6 also created a voluntary, paid program in which large loads bid to reduce demand ahead of an anticipated emergency. The PUCT proposed the rule (new 16 TAC §25.521) in August 2026.21 For loads that can flex, it may become a revenue line.
Buying the electricity
Interconnection gets the wires to you. You still have to buy the energy that flows over them, and at data center scale the supply contract is one of the largest numbers in the operating budget. A steady 300 MW load uses about 2.6 million megawatt-hours a year.
In competitive ERCOT areas
If your site is in Oncor, CenterPoint, AEP Texas or TNMP territory, you choose your supplier. Your bill has two parts: regulated delivery charges from the wires company (including transmission charges and any minimum billing demand), and the energy price from your Retail Electric Provider. Common structures include:
- Fixed price for a term: predictable, but the provider prices in risk premiums for load shape and volume swings.
- Index or block-and-index: buy a hedged block at a fixed price and float the rest on ERCOT real-time prices. Usually cheaper on average, with exposure to price spikes.
- Power purchase agreements: physical or virtual contracts with specific wind, solar, storage or gas plants, often paired with a retail contract to shape and deliver the power.
- Self-supply via a QSE: the largest buyers sometimes become, or hire, a Qualified Scheduling Entity and manage wholesale positions directly.
Flexibility has real value in ERCOT. Loads that can curtail during price spikes, participate in demand programs, or (while it lasts) manage 4CP intervals can lower their effective cost substantially. The flip side: if you are a PCLR, ERCOT's curtailment instructions will arrive whether or not they suit your hedge.
In co-op and city utility areas
CPS Energy, Austin Energy and most co-ops sell bundled power under their own tariffs, and SB 6 explicitly lets them impose requirements beyond the PUCT's.38 Expect negotiated agreements with minimum bills, long terms, and sometimes special large-load rate classes; CPS, for instance, has discussed creating a separate large-load rate class.39
Outside ERCOT
In El Paso Electric, SPS, SWEPCO and Entergy Texas territory, you contract with the integrated utility under its large-power tariffs and special contracts. Retail choice does not apply. El Paso Electric has proposed a 20-year minimum contract duration for large loads, one example of how long these commitments are becoming.54
Permits, water and taxes
Environmental permits
Data centers typically need TCEQ authorizations for backup generator air emissions, construction stormwater, and sometimes water rights or wastewater discharges. A campus with on-site gas generation needs air permits for a power plant. On September 21, 2026, the Governor directed TCEQ to halt issuing permits related to data center projects until ERCOT completes its review, and said no other state agency should advance data center approvals in the meantime.1213 TCEQ described the pause as covering air and water permits and authorizations for infrastructure directly supporting data centers.55 An October 2026 FracTracker review of TCEQ records through October 16 found 11 construction stormwater approvals and 7 air authorizations recorded after the order, with 14 applications still in review. The Governor's office says no permits have been approved and that the pause covers approvals, not processing; TCEQ reported on its compliance in an October 19 letter.1456
The Governor's letter tied resumed permitting to six conditions for data center sponsors: cover all dedicated grid infrastructure costs; show the project will lower, not raise, residential electric bills; complete the ERCOT and TWDB audits; show operations will not consume water communities need; file electricity and water use reports; and comply with local setback ordinances.7
Water
Water has become as politically sensitive as power. The Texas Water Development Board has surveyed data centers about water use for years, but response rates have been low: a June legislative hearing heard 17% for the 2025 survey, while TWDB put its response rate at about 30% as of August 2026.5729 On September 14, 2026 the Governor directed TWDB to enforce the reporting requirement and coordinate with ERCOT's audit, and on September 24 the Attorney General announced an investigation into non-responding facilities.29 Failing to return the survey is a Class C misdemeanor and can make a facility ineligible for certain TCEQ water permits.2958
Practically, a credible water plan (closed-loop or air-cooled designs, reclaimed water, or contracted supply that does not compete with local needs) is now part of getting power, not just part of getting a building permit.
Tax incentives
Texas has offered a state sales and use tax exemption for qualifying data centers since 2013, covering equipment and the electricity used to operate the facility. Qualifying generally means at least $200 million of investment over five years, 100,000 square feet and 20 jobs.63 The Senate Finance Committee projects the exemption will cost about $3.3 billion in the 2028–29 budget period, and the Comptroller's office told lawmakers that estimate is already outdated and the next one will likely be significantly higher. Of 20 recently audited projects, six were found noncompliant or withdrew.28 At a July 27, 2026 hearing, legislators made clear the exemption, including its application to existing projects, will be a major target in the 2027 session.27 The Governor's September 21 letter says he will work with the Legislature to eliminate state tax exemptions and economic development incentives for data center developments that do not meet his conditions.7 Local incentives (county abatements under Chapter 312, school district agreements under the JETI Act, and Chapter 380/381 agreements) remain available case by case.59 Any pro forma built on today's incentives should carry a scenario without them.
Commissioning and go-live
The last stretch is technical and unforgiving about deadlines.
- Stability assessment (QSA). Before initial energization, a new large load must be included in ERCOT's stability assessment, which checks how new loads and large generators affect grid stability.32 It has run every three months. A revision (PGRR 146), recommended by ERCOT's Reliability and Operations Subcommittee in August and October 2026 and now pending at ERCOT's Technical Advisory Committee, would move it to every four months and rename it the "qualifying stability assessment," with a proposed effective date of September 1, 2027.33 Missing a submission window can push energization back a full cycle.
- Models and settings match the real equipment. If your as-built design differs materially from what was studied, ERCOT can refuse energization.32
- Registration and metering. Your facility is registered in ERCOT's systems, with settlement-quality metering and, for controllable loads, telemetry and dispatch capability.
- Curtailment equipment tested. Remote disconnect capability for firm load shed must work.
- Phased energization. Load comes online in the steps of your Load Commissioning Plan. Each step can face operating limits if studies show a stability concern.
- Security release begins. At initial energization, 20% of your SLLIA security comes back.7
A realistic timeline
Here is how the pieces overlap for a hypothetical 300 MW greenfield campus starting today. Your project could be faster with an available substation, or much slower if new transmission lines are needed.
Greenfield campus, month by month (illustration)
Illustrative project timeline over 72 months. Site screening months 0 to 6. Land and site control 3 to 9. Utility engagement and intermediate agreement 6 to 12. Wait for and run batch study 12 to 30. Sign agreement, post security, pay CIAC 30 to 33. Long-lead equipment orders 10 to 44. Utility substation and line work 33 to 52. State and local permits 8 to 30. Building construction 26 to 50. Stability assessment, registration and commissioning 46 to 54. Phased ramp to full load 52 to 72.
grid timing sets the pace
2026 pause adds risk
| Step | Start month (illustrative) | End month (illustrative) |
|---|---|---|
| Site & power screening | 0 | 6 |
| Land / site control | 3 | 9 |
| Utility + intermediate agmt | 6 | 12 |
| Batch window + study | 12 | 30 |
| SLLIA, security, CIAC | 30 | 33 |
| Long-lead equipment | 10 | 44 |
| State & local permits | 8 | 30 |
| Utility substation / lines | 33 | 52 |
| Building construction | 26 | 50 |
| QSA, registration, commission | 46 | 54 |
| Phased ramp to full load | 52 | 72 |
The levers that actually shorten this: picking a site with existing capacity, being fully ready (land, models, collateral) when a batch window opens, ordering long-lead equipment early, designing the building in phases that match the yearly allocation, and considering PCLR or on-site generation to bridge years where firm capacity is short.
Developer checklist
- Confirm which grid and which utility serve each candidate site, and whether it is competitive, co-op or municipal territory.
- Get informal capacity screens from the utility or an engineering consultant before committing to land.
- Lock site control with a deed, a lease running at least five years past expected peak, or a signed purchase or lease option, with extensions tied to interconnection milestones.
- Budget the SB 6 entry costs: $100,000 study fee plus $50,000 per MW in security at the intermediate agreement.
- Engage your electrical engineer and UPS vendors early to produce dynamic models and a NOGRR 282 ride-through compliant design.
- Decide your flexibility posture: firm only, PCLR, on-site generation (WLPUN), co-location, or a mix.
- Disclose all similar requests elsewhere in Texas and any backup generation that can carry 50%+ of load.
- Reserve transformer and switchgear production slots as early as your risk tolerance allows.
- Prepare a water plan and file all required TWDB surveys for any existing facilities.
- Plan permits (air, stormwater, local) and track the TCEQ pause and its conditions.
- Model operating costs on a 12CP basis, with and without the sales-tax exemption, and with a 20-year minimum billing demand.
- Line up electricity supply: retail structure, PPAs or QSE strategy, aligned to your ramp schedule.
- Build a Load Commissioning Plan that matches your yearly MW allocation and construction phases.
- Calendar every ERCOT and PUCT deadline; a missed commitment date counts as withdrawal.
Glossary
- 4CP / 12CP
- Four coincident peak: the method that allocates ERCOT transmission costs based on demand during the four summer monthly system peaks. Proposed to be replaced by 12CP, one peak every month (decision expected December 2026).
- Batch study
- ERCOT's cluster study that evaluates all eligible large loads together and allocates capacity by year.
- CCN
- Certificate of convenience and necessity. PUCT approval needed to build a new transmission line.
- CIAC
- Contribution in aid of construction. Up-front payment for facilities built specifically to connect you.
- DSP / TSP
- Distribution or Transmission Service Provider. The utility that owns the wires at your site and sponsors your request.
- ILLE
- Interconnecting Large Load Entity. ERCOT's term for the customer seeking to connect.
- Large Computational Load
- LCL. A 75 MW+ load where at least half the demand is computing. Formerly called a Large Electronic Load. Subject to NOGRR 282 ride-through rules.
- LCP
- Load Commissioning Plan. The agreed schedule of how many MW come online and when.
- LPC / MPC
- Low and Maximum Power Consumption. Your firm allocation and your full requested peak from the batch study.
- PCLR
- Provisional Controllable Load Resource. Runs above LPC subject to ERCOT dispatch until an exit date.
- QSA
- Quarterly Stability Assessment, required before initial energization. PGRR 146 (pending) would rename it the qualifying stability assessment and run it every four months.
- QSE
- Qualified Scheduling Entity. Registered party that schedules and settles energy in ERCOT's wholesale market.
- REP
- Retail Electric Provider. Sells electricity to customers in competitive ERCOT areas.
- SB 6
- Senate Bill 6 (2025). The law behind Texas's large-load interconnection, cost, co-location and curtailment rules.
- SLLIA
- Standard Large Load Interconnection Agreement. The binding agreement signed after capacity is allocated.
- WLPUN
- Withdrawal-Limited Private Use Network. On-site generation and load operating behind a cap on grid withdrawals.
Sources
- ERCOT, Large Load Integration
- ERCOT, New Batch Connection Process for Large Electricity Users (June 18, 2026)
- ERCOT, PUCT Approves ERCOT's Batch Zero Process (June 18, 2026)
- ERCOT, Update to Texas Senate (July 29, 2026); also ERCOT Large Load Update (April 2026)
- ERCOT Board, Batch Zero Update (September 2026)
- Sheppard Mullin, PUCT Approves Batch Zero Framework
- White & Case, PUCT sets financial commitments for data center interconnection as governor pauses permit approvals (Sept. 25, 2026)
- Utility Dive, Texas PUC adopts softened rules on data center interconnection
- Akin Gump, Texas Pauses Data Center Interconnections Pending Statewide Audit
- Utility Dive, ERCOT aims to complete Texas governor's data center audit by December
- Texas Public Radio (Houston Public Media), Gov. Abbott's data center audit is underway. Here's what ERCOT is asking.
- Office of the Governor, Governor Abbott Directs TCEQ To Halt Data Center Permits (Sept. 21, 2026)
- Bracewell, Governor Abbott Orders TCEQ to Pause All Permit Issuance
- FracTracker Alliance, Texas Continued Data Center Permitting after the Governor's Pause
- White & Case, PUCT affirms curtailment authority over co-located data centers
- Texas Register, adoption of 16 TAC §25.205 (April 10, 2026)
- ERCOT Board, NOGRR 282 and NPRR 1308 update (Feb. 2026, original "Large Electronic Load" term)
- ERCOT, NPRR 1308 (Large Computational Load definition)
- Bracewell, Texas Senate Bill 6 Ushers in Major Overhaul
- K&L Gates, Senate Bill 6: A Texas Bill Impacting Large Load Development
- Texas Register, proposed 16 TAC §25.521 Large Load Demand Management Service (Aug. 14, 2026)
- ERCOT, Monthly Operational Overview, September 2026 (published Oct. 16, 2026)
- Data Center Knowledge, ERCOT Warns Texas AI Power Boom May Not Materialize
- Giga Energy, The constraints that cause lead time delays for data centers
- Avanza Energy, on-site generation delivery timelines (citing CPS Energy, PowerGen 2026)
- Beatty & Wozniak, Texas Data Center Review Delays Batch Zero and Puts Behind-the-Meter Power in Focus
- Holland & Knight, Texas Data Center Tax Exemption Faces Serious Legislative Risk
- Texas Public Radio, Texas lawmakers question billions in tax breaks for data centers
- Foley & Lardner, Texas Escalates Data Center Oversight with Attorney General Water-Use Investigation
- ERCOT, 2025 Report on Existing and Potential Electric System Constraints and Needs
- DC Hub, ERCOT large load queue (compiling ERCOT monthly figures)
- Zero Emission Grid, ERCOT Large Load QSA Explained
- ERCOT ROS Report, PGRR 146 (Aug. 6, 2026)
- Willkie Farr & Gallagher, ERCOT Approves Implementing New Batch Zero Process
- ERCOT, Batch Zero Verification and Audit, PUCT presentation (Aug. 20, 2026)
- Pexapark, Texas Audit Puts ERCOT's Batch Zero Process on Hold Until December
- ERCOT comments on NPRR 1321, describing the 2026 RTP Compliance Plan site-control criteria
- Mayer Brown, Important Texas Regulatory Updates for Data Centers
- CPS Energy, large load presentation (March 2026)
- Keentel Engineering, ERCOT PCLR Guide
- EPE Consulting, New Pathway and Deadlines in ERCOT's Batch Zero: PCLR
- Zero Emission Grid, ERCOT Batch Study Workshop #4 takeaways
- PUCT, SB 6 implementation timeline (Project 58317, Sept. 2026)
- PUCT Project 58481 rule text (draft)
- PUCT Project 58000, proposal for publication (July 9, 2026)
- AmCompute, Behind-the-Meter GPU Deployments (citing Cushman & Wakefield 2026 cost guide)
- Reuters via AJOT, US power companies scramble to secure equipment
- The Center Square via WFMZ, Surge in gas-fired power for data centers with Texas leading
- Cleanview, Stargate Abilene behind-the-meter profile
- Ascend Analytics, Can US Interconnection Queues Survive Data Center-Driven Load Growth?
- ERCOT Market Notice M-A090226-01, SB 6 curtailment workshop
- ERCOT, NOGRR 282
- Crypto Briefing, medium-voltage UPS and large-load ride-through standards
- Lawrence Berkeley National Laboratory, Large-load rate design webinar (Sept. 2026)
- Houston Public Media, Abbott orders TCEQ to pause environmental permits
- Landgate, Texas Paused Data Center Permits. A New Report Says the Paperwork Kept Moving.
- KUT, Texas asked data centers to report their water use
- Water Online, Governor Abbott Directs TWDB To Penalize Data Center Reporting Failures
- Sierra Club Lone Star Chapter, comments to Senate Finance (July 27, 2026), on local incentive tools
- Zero Emission Grid, ERCOT Batch Zero Workshop 6 summary
- ERCOT, Trending Topic: Data Centers and Net Metering Arrangements (June 2026)
- PUCT Chairman letter to the Governor on SB 6 implementation (July 17, 2026)
- Texas Comptroller, Data Centers sales and use tax exemption
- ERCOT, Monthly Operational Overview, July 2026 (preliminary 91,134 MW peak)
- Utility Dive, Texas approves AI data center co-location next to wind farm with curtailment conditions
- Colocation Scout, Texas PUC large load interconnection rule (effective date and site-control summary); Texas Register, Oct. 2, 2026 adopted rules
This guide is general information about a fast-moving regulatory area, current as of October 24, 2026. It is not legal, engineering or financial advice. Rules, dates and figures cited here may change; confirm current requirements with your utility, ERCOT, the PUCT and qualified counsel before making commitments. Illustrations marked as examples use hypothetical numbers.