With large load growth continuing to strain Texas's interconnection queue, ERCOT has taken a major formal step toward structural reform. On March 4, 2026, ERCOT filed Planning Guide Revision Request 145 (PGRR145), Batch Zero Process for Large Load Interconnections, alongside the companion Nodal Protocol Revision Request 1325 (NPRR1325). These filings mark the formal governance review process for what may become a fundamentally restructured large load interconnection framework in ERCOT.
It is important to note that PGRR145 is proposed language. All provisions discussed below remain subject to stakeholder review, committee votes, ERCOT Board and PUCT approval before taking effect.
What Is PGRR145?
PGRR145 proposes to replace the current individual Large Load Interconnection Study (LLIS) process with a system-wide, batch-based approach. The existing one-off processes were built for incremental changes on the system and this new process aims to better manage the volume and impact of new large load connections. This is expected to help better manage assessment backlogs, coordination, and ultimately lead to more certainty for developers, TSP and ERCOT.
Under the proposed framework, ERCOT would evaluate groups of large loads together, allocate available transmission capacity on a year-by-year basis, and produce an actionable transmission plan. PGRR145 establishes Batch Zero as a one-time, transitional process, with a separate future filing anticipated to implement a repeatable batch framework built on lessons learned.
Governance Timeline
The March 4 filing initiated a targeted, defined governance sequence, with ERCOT continuing to refine the proposal in response to stakeholder input:
Stakeholders may continue submitting comments on both NPRR1325 and PGRR145 throughout this process.
How Batch Zero Would Work: The Two-Phase Structure
Under PGRR145, Batch Zero would consist of two sequential phases:
Phase 1 - Batch Zero Interconnection Study
ERCOT would conduct a system-wide steady-state and stability screening study for years 2028 through 2032, determining:
- The maximum peak demand that can be reliably served for each large load in each year, and
- The transmission upgrades required to support these allocations.
Phase 2 - Batch Zero Refinement Study:
ERCOT would update the study to include only those large loads that have met the commitment requirements, right-sizing the transmission plan accordingly before delivering it to RPG, TAC, and the Board for review and approval.
A key design principle is that once a large load meets the commitment requirement, its MW allocation is locked and is not reduced during the refinement phase.
ERCOT has indicated that certain interim deadlines may be adjusted to improve coordination between developers and TSPs, based on stakeholder feedback.
How Large Loads Would Be Categorized
Under the proposed framework, each large load in ERCOT's queue would fall into one of three categories:
- Base Load (Not Subject to Further Study)
- Studied in Batch Zero and eligible for MW allocation
- Not Included in Batch Zero, these loads may seek inclusion in a future batch process once eligibility criteria are met.
ERCOT Feedback to Stakeholder Comments: Key Clarifications and Adjustments
ERCOT’s written responses and workshop discussions reflect several important refinements driven by stakeholder input:
- How Legacy Projects Would Be Treated: ERCOT clarified that large load projects that satisfy key LLIS milestones prior to the PGRR145 filing date are not automatically invalidated by Batch Zero. ERCOT will evaluate legacy projects sequentially to determine appropriate treatment, addressing concerns about unintended loss of study progress.
- Removal of Non-utilized Capacity Provisions: ERCOT removed provisions that would have allowed reclamation of “non-utilized capacity,” confirming that this concept does not apply to Base Load or Batch Zero MW allocations.
- Dynamic Data Requirements: ERCOT clarified that updated dynamic data submitted during the process must not be expected to adversely impact study results, rather than requiring exact consistency with initial submissions. This approach offers greater flexibility to account for normal project refinement while maintaining study integrity.
- Alignment With PUCT Rulemaking: ERCOT updated PGRR145 to better align with the Public Utility Commission of Texas rulemaking in Project No. 58481, including adjustments to financial security amounts, site control requirements, and withdrawal provisions incorporated into the Batch Zero commitment framework.
- Transparency and Data Posting: ERCOT clarified that Batch Zero study cases will be posted to MIS Secure, balancing transparency with protection of commercially sensitive information
CLR and BYOG: A Separate Filing Coming
ERCOT is developing a separate, targeted revision request to clarify the treatment of Controllable Load Resources (CLR) and Bring-Your-Own-Generation (BYOG) configurations within the Batch Zero framework, with an April filing currently targeted (subject to change).
At the March 10 workshop, ERCOT outlined four potential configurations for Batch Zero. Three are considered potentially feasible:
- Load-Only CLR with no behind-the-meter generation
- CLR with non-synchronous backup generation that cannot export to the grid
- BYOG Self-Limiting Facility (SLF) where co-located load and generation operate behind a single POI under a defined net injection/withdrawal limit.
- Netted Network, which would allow simultaneous load and generation market participation behind the same POI, is currently considered not feasible for Batch Zero. However, this configuration may become viable in the future if ERCOT develops and implements the appropriate market rules and operational framework to support it.
Stakeholder feedback has reflected broad support for the BYOG SLF framework as a workable interim solution and strong interest in formalizing CLR as a bridge capacity mechanism while transmission upgrades are completed. ERCOT has indicated it is incorporating this feedback into the forthcoming filing.
What This Means for Large Load Developers
If approved, PGRR145 would represent the most significant structural change to ERCOT's large load interconnection process to date. For developers, the implications are immediate and concrete:
- Eligibility deadlines are not far away
- Financial commitments could be substantial and largely non-refundable
- MW allocations, once locked, are protected
- CLR and BYOG treatment remains in development
Critically, the proposed framework shifts more decision-making and financial commitment earlier in the process, before full transmission certainty is available.
How EPE Can Support
As ERCOT's Batch Zero framework moves through governance, early preparation is critical for Batch Zero and the upcoming batches. EPE is actively engaged in ERCOT's Large Load Working Group and Batch Study workshops, closely tracking every development in this rapidly evolving process. To discuss how PGRR145 may impact your interconnection strategy and how we can support your large load project readiness, contact us today using the form below.
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