ERCOT’s Batch Study Process: What Large Load Developers Need to Know

Last Updated: March 18, 2026 | This article reflects the status of ERCOT’s batch study process as of mid-March 2026. Protocol language, timelines, and stakeholder positions are evolving rapidly. Contact SK Energy for current analysis.

ERCOT’s large load interconnection queue has reached 238,000 MW — and that number is probably already outdated. Over 70% of the queue is data centers. The old serial study process can’t keep up, and everyone knows it. ERCOT is building a new batch study framework from scratch, on a compressed timeline, while developers with billions of dollars in committed capital wait to find out whether their projects still have a path to interconnection.

If you’re a large load developer, generation developer, or anyone with a project in the ERCOT interconnection queue, understanding the batch study process isn’t optional. It will determine your project’s timeline, your MW allocation, and whether studies you’ve already completed still count.

Here’s where things stand after four public workshops and two major protocol filings.

Why Batch Studies? The Serial Process Hit a Wall

For years, ERCOT processed large load interconnection requests one at a time through a serial study process under Planning Guide §9.4 and §9.5. That worked when the queue was manageable. It doesn’t work when the queue quadruples in a single year.

The numbers tell the story:

238,629 MW in the official queue as of March 2026
77.5% data centers — the single largest category
99 projects at 1,000+ MW each
69,000 MW added in the last 12 months alone
137 new submissions (~140,000 MW) filed since January 2026 — not yet reflected in official reports

When the queue was a few thousand megawatts, serial studies took months. At this scale, they’d take decades. The PUC directed ERCOT to fix it, and Chairman Gleason locked in a June 1, 2026 Board vote as the deadline for getting the new framework approved.

That’s an aggressive timeline for a process this consequential.

The Workshop Progression: February to March 2026

ERCOT has run four public workshops since February, each building on the last. Understanding what happened in each one matters because the design decisions are cumulative — and some of the most significant changes came from stakeholder pushback, not ERCOT’s original proposals.

Workshop #1 (February 3): The Framework Takes Shape

The first workshop introduced the core concept: replace the serial study process with a batch framework that can process hundreds of projects simultaneously. ERCOT presented initial eligibility criteria, a proposed study timeline, and a stakeholder feedback mechanism.

The key question from day one: what happens to projects already in the serial pipeline? Developers with completed or in-progress studies wanted to know whether their prior work would carry forward. ERCOT didn’t have a definitive answer yet.

Workshop #2 (February 12): Scope Decisions

The second workshop made several important structural calls:

Batch Zero A/B split eliminated — ERCOT originally planned to divide the first batch into two groups. Stakeholder feedback consolidated it into a single Batch Zero process
August 1, 2026 protocol effective date confirmed as the target
Three modular NPRRs announced — one for the core Batch Zero framework (top priority), one for Controllable Load Resources (CLR), and one for Bring Your Own Generation (BYOG)
Batch One explicitly deferred past the June Board vote

This was also where the CLR concept first gained real traction. A stakeholder survey with 109 responses showed strong support for allowing loads to register controllable capacity alongside their firm allocation — a mechanism that could let developers bring projects online sooner with less than their full requested MW.

Workshop #3 (February 26): The Design Inventory

Workshop #3 delivered the first comprehensive inventory of design elements — not draft protocol language, but the building blocks ERCOT planned to formalize.

Key details that emerged:

Study horizon: 2028–2032, with loads receiving full allocation in 2033
Study scenarios: Summer peak load, summer peak net load, and fall peak
Timeline: Case build (13 weeks) → steady-state analysis (15 weeks) → stability screening (14 weeks, parallel) → refinement study (13 weeks) → RPG review (3–4 weeks)
Developer commitment deadline: approximately mid-2027 (~24 weeks after Batch Zero starts)
Post-Batch Zero cadence: 6-month batches going forward

Three CLR tiers were introduced: Manual CLR, SCED-automated CLR, and a “Netted Network” concept combining supply and demand at the same point of interconnection. ERCOT also confirmed the March 4 filing date for the core protocol documents.

Workshop #4 (March 10): Filed Language Meets Stakeholder Reality

This was the pivotal workshop — the first time stakeholders could review actual filed protocol language rather than conceptual frameworks.

On March 4, ERCOT filed PGRR 145 (Planning Guide revisions) and NPRR 1325 (Nodal Protocol revisions). These documents replace the entire interconnection framework with two parallel tracks: Batch Zero and Legacy LLIS.

Three things stood out:

First, ERCOT removed non-utilization reallocation from PGRR 145 after stakeholders flagged a reliability conflict. That’s a meaningful concession — and the kind of responsive iteration this process needs.

Second, ERCOT acknowledged that the RTP inclusion gap is unintentional. Loads not included in the 2026 Regional Transmission Plan would receive 0 MW under the “lesser of” test, even with completed studies. ERCOT committed to address it.

Third, the ordering mechanism under §9.2.1.4 uses the date of your last restudy — not your original study completion date. This is critical for developers to understand: if your project was restudied recently, you may rank lower in the queue than projects that started the process years after you did.

The §9.2.1.4 Problem: Retroactive Study Invalidation

Section 9.2.1.4 of the filed PGRR 145 is where the most significant controversy sits. Under this provision, ERCOT claims authority to retroactively evaluate the validity of prior interconnection studies. Developers with completed §9.4 and §9.5 studies — some of whom have signed agreements, issued notices to proceed, and begun construction — could have their study results reclassified.

The design creates a circular timing problem. To qualify as a “Base Load” (no restudy required), developers must submit a physical construction attestation by July 15, 2026 confirming their MW commitment. But the §9.2.1.4 validity review won’t conclude until early August. In other words, developers are being asked to commit capital before knowing whether their MW allocation will be confirmed.

From a developer’s perspective, this is the most operationally urgent issue to resolve. Multiple stakeholders have proposed a safe harbor: if you completed the serial study process under the existing rules, that should be final. One stakeholder proposed limiting the look-back to 30 days. ERCOT hasn’t adopted either concept yet, but the iterative workshop process suggests they’re listening.

CLR and BYOG: Flexibility for Phased Development

One of the more promising developments in the workshop process is the Controllable Load Resource (CLR) and Bring Your Own Generation (BYOG) framework. These constructs would allow developers to begin operating at less than their full requested MW by registering controllable capacity that ERCOT can dispatch in real time.

Three constructs advanced as potentially feasible for Batch Zero:

Load-Only CLR — Firm MW plus controllable MW registered separately, with ERCOT dispatching the controllable piece via SCED in 5-minute intervals
CLR with Non-Synchronized Backup Generation — Backup generation (diesel, battery) sits behind an open breaker and isn’t visible to ERCOT. The load manages curtailment under SCED dispatch
Self-Limiting Facility (SLF) — A net injection cap at the point of interconnection enforced by EMS/relays, allowing combinations of thermal, solar, and other generation within the cap

A fourth concept — the Netted Network, which would aggregate supply and demand participation — was declared not feasible for Batch Zero due to conflicts with the current market design. ERCOT left the door open for Batch One.

Stakeholder survey results (62 respondents) showed strong support: 82% backed pre-registering non-firm MW as CLR, and 80% supported the SLF concept.

Comments on CLR/BYOG constructs were due March 20, with Workshops 5, 6, and 7 (March 24, March 30, and April 9) dedicated to refinement. The filing target for the CLR/BYOG NPRR is April 8.

The PUC Parallel Track: Project 58481

While ERCOT builds the protocol framework, the PUC is simultaneously writing the rule that governs it.

On March 12, the PUC unanimously approved the Proposal for Publication (PFP) for Project 58481 — the large load interconnection standards under 16 TAC §25.194 — with four changes from the draft. The financial security deposit and the non-refundable interconnection fee both dropped from $100,000/MW to $50,000/MW. Site control requirements broadened to include option-to-lease and option-to-purchase at the intermediate stage, and purchase-and-sale agreements at the interconnection agreement stage.

The Chairman also described a graduated escalator framework — lower financial commitments early in the process, escalating with commercial milestones. It didn’t make it into the PFP, but no commissioner objected, and it’s expected to appear in the comments.

Here’s where the two tracks intersect: under Project 59142, ERCOT presented on PGRR 145 and NPRR 1325 at the same open meeting where 58481 was approved. ERCOT replicated the draft PFP language into those protocol documents so Batch Zero can move forward this summer without waiting for the 58481 rulemaking to finish.

But April 17 is the inflection point. It’s both the PFP comment deadline and the open meeting where ERCOT needs direction from the PUC before the revision requests and the rule start diverging. If you’re filing PFP comments, know that what you argue there will shape what ends up in Batch Zero too.

Technical Requirements Are Tightening Too

Alongside the batch study framework, ERCOT is raising the bar on technical compliance:

PGRR 144 expands the PSCAD dynamic modeling requirement to all large loads, not just Large Electric Loads (LELs). Every interconnecting project will need a validated power systems model
NOGRR 282 raises the high-frequency ride-through threshold from 61.8 Hz to 63.0 Hz and caps overcurrent duration at 0.5 seconds (30 cycles). Data Center Coalition technical objections were rejected on reliability grounds. The ROS vote is scheduled for April 2
New Modular Quality Test (MQT) requirements apply to all large loads, with draft procedure manual sections posted for comment through March 27

These requirements interact with the batch study framework in a way that developers need to watch carefully. Updating your dynamic model to comply with NOGRR 282 could trigger a PGRR 145 restudy — which could change your eligibility classification from Base Load to Study Load. That’s not a hypothetical risk; it’s a structural interaction in the current protocol language.

What Happens Next

The remaining timeline is compressed:

Date	Milestone
March 24, 30, April 9	Workshops 5, 6, 7 (CLR/BYOG refinement)
April 2	ROS vote on NOGRR 282
April 8	CLR/BYOG NPRR filing target
April 17	PFP comment deadline + PUC open meeting
May 6–7	PRS + ROS votes on PGRR 145 / NPRR 1325
May 19–20	TAC vote
June 1	Target Board vote
August 1	Target protocol effective date

Every one of these dates matters. The Board vote on June 1 is the hard deadline — it determines whether Batch Zero launches this summer or slips.

What This Means for Your Project

If you have a project in the ERCOT interconnection queue — or you’re considering filing one — the batch study process will define your path forward. The framework is still being built, which means the decisions being made in these workshops and comment periods will directly affect your project’s timeline, cost, and feasibility.

The developers who come through this process in the strongest position will be the ones who understand the protocol language, engage in the comment process, and have advisors who can translate regulatory complexity into project-level decisions.

SK Energy’s interconnection consulting practice works with large load developers navigating the ERCOT queue. We track every workshop, every protocol revision, and every PUC filing — and we translate it into actionable guidance for your project.

Email info@tryskenergy.com to discuss your interconnection strategy.

SK Energy, LLC provides interconnection consulting and electricity brokerage services in the ERCOT market. This article reflects the status of ERCOT’s batch study process as of mid-March 2026 and is provided for informational purposes. Protocol language, timelines, and regulatory positions are subject to change. Contact SK Energy for current project-specific analysis.