The "Batch Zero" Interconnection Cliff
Date: March 28, 2026
Subject: Critical Deadlines for Large Load Interconnections (20MW–80MW)
The transition from individual studies to the Batch Zero framework (PGRR145) has created an immediate "survival" timeline for Texas industrial loads. If your project is in the queue, these three updates are your current reality:
1. The July 15th Execution Deadline
To be included in the transitional Batch Zero study, developers must move from "interested" to "committed" by July 15, 2026.
The Requirement: You must have executed intermediate agreements and provided notarized attestations from your TSP/DSP.
The Risk: Projects that fail to meet this window will be pushed to the "Permanent Batch Process," which is currently not scheduled for Board approval until September 2026, likely delaying energization by 12–18 months.
2. The $50,000/MW Financial Security Shift
The PUCT has officially moved to a draft rule (16 TAC §25.194) that requires a $50,000 per MW financial security deposit.
The Math: For a 50MW Tier 2 data center, that is a $2.5 Million cash, letter of credit, or guaranty requirement just to stay in the study.
The Strategy: By architecting a Controllable Load Resource (CLR) or BYOG (Bring Your Own Gen) configuration now, we can argue for reduced collateral based on the "Self-Limiting Facility" framework being finalized in June.
3. The "0 MW Allocation" Probability
ERCOT's new study process will allocate capacity in year-by-year blocks (2028–2032).
The Bottleneck: If your site is not already in the 2026 Regional Transmission Plan (RTP), the Batch Zero study may result in a 0 MW allocation for your requested in-service date.
The Bypass: The "Power Architect" solution is a BESS Bridge. By deploying on-site storage, you can accept an "On-Ramp" allocation (e.g., 20MW instead of 80MW) and use the battery to handle your peak operational load until the 2030 transmission upgrades are complete.
Internal Action Items for Iron Harbor Partners:
Audit TSP Communications: Ensure your Transmission Service Provider has filed your "Necessary High-Voltage Equipment" attestations before the May 1st stability assessment cutoff.
Verify Batch Status: Confirm if your project is being modeled as "Base Load" (pre-March 2022) or "Batch Zero" (post-March 2022).
Evaluate BYOG Co-location: Determine if your site layout supports a G-1 secure behind-the-meter configuration to fast-track your approval.