Texas SB 6 and ERCOT Batch Zero: how Texas connects data centers

ERCOT, the Texas grid operator, is weighing more than 474 GW of large load requests, about 90 percent data centers, per the Governor's office in August 2026. That is over five times its record peak. Senate Bill 6 sets a 75 MW threshold, study fees and curtailment duties, and ERCOT now studies requests in batches.

This post explains what the law says, how the batch process works, how to read the queue numbers, and what remains open as of 19 October 2026. It is the detailed Texas companion to our overview of US AI data centre hubs.

Key numbers at a glance

• 91.1 GW: ERCOT's all time peak hourly load, set on 22 July 2026 (US Energy Information Administration, 15 October 2026).
• 85.5 GW: the previous ERCOT record, which EIA dates to 20 August 2024 (same EIA article).
• More than 233 GW of large load requests, over 70 percent from data centers, with about 7.5 GW actually connected (BIC Magazine, 6 March 2026).
• About 410 GW of requests, 87 percent data centers, as described by ERCOT's chief executive to a Texas House committee (Texas Tribune, 17 April 2026).
• About 438 GW of requests by late May 2026, more than 300 GW of them with no completed studies (ERCOT's Jeff Billo, as reported by New Project Media).
• More than 474 GW of requests, about 90 percent data centers (Office of the Texas Governor, 3 August 2026).
• About 8,927 MW of large load approved to energize, and about 3,900 MW of observed non simultaneous peak use in June 2026 (ERCOT working group figures, as summarised by Zero-Emission Grid, 23 June 2026).
• 367,790 MW: ERCOT's preliminary 2032 peak demand forecast, which its chief executive said is probably higher than actual growth will be (American Public Power Association, 17 April 2026).
• 75 MW: the default large load threshold in Senate Bill 6 (Texas Legislature, enrolled text).
• $100,000: the minimum flat fee for an initial screening study under SB 6 (same text).
• 120 and 60 days: ERCOT's study window and the PUC's decision window for pairing an existing generator with a new large load (same text).
• $50,000 per MW: default Batch Zero financial security where upgrade costs cannot be determined (Sheppard Mullin, via Mondaq, 26 June 2026).
• 9 April 2027: the date Batch Zero study results and megawatt allocations are due (same source).

Why Texas is its own case

Most of the US grid falls under the Federal Energy Regulatory Commission for interstate transmission. Texas is different. ERCOT, the Electric Reliability Council of Texas, runs a grid that is not interconnected with neighbouring states for this purpose, and Compute Law Blog notes that it "operates outside FERC's interstate jurisdiction." The Public Utility Commission of Texas, called PUCT, is the state regulator, and the Legislature writes the statute. So the federal large load rules in our FERC post do not directly set Texas's rules.

Texas has also had a reputation for speed. Developers have chosen it for available land, plentiful generation and a process that moved faster than elsewhere. That reputation drew a flood of requests, and the flood is now the problem the state is trying to manage.

The record peak, and why two numbers circulate

The EIA reported on 15 October 2026 that ERCOT's hourly load reached 91.1 GW on 22 July 2026, 6.5 percent above the pre 2026 record of 85.5 GW. EIA dates that earlier record to 20 August 2024. The agency attributed the summer's records across several grids to regional heat waves in the hottest summer on record nationally, and it did not tie them to data centers.

Readers will still see 85.5 GW quoted as the all time record in material written before July 2026. Reports from April 2026, such as the Texas Tribune and the American Public Power Association, gave 85,508 MW on 10 August 2023. The 2023 and 2024 peaks were almost the same size, which is why sources date the old record differently. EIA notes that its hourly data are reported by balancing authorities as is and may differ from figures the operators publish. Either way, the old figure is superseded: the current record is 91.1 GW, set on 22 July 2026.

How big is the queue: a dated timeline

Large load requests have been counted several times in 2026, by different people, and the totals rose quickly. Read them as a timeline, not as competing claims:

• About 14 months before March 2026, the count was 63 GW, according to BIC Magazine.
• On 6 March 2026, BIC Magazine reported more than 233 GW, with more than 70 percent from data centers, about 128 GW without submitted studies and about 7.5 GW actually connected. ERCOT received 225 new large load requests in 2025, against rules designed for 40 to 50 large loads at a time, the same report said.
• In April 2026, ERCOT chief executive Pablo Vegas told the Texas House State Affairs Committee that ERCOT was tracking requests that could require about 410,000 MW, 87 percent of them data centers, according to the Texas Tribune.
• At a late May 2026 board meeting, Jeff Billo, ERCOT's vice president for interconnection and grid analysis, reported about 438 GW, up about 28 GW since April, with more than 300 GW lacking completed studies, according to New Project Media. He said: "We just don't have a lot of information on these requests at this time."
• On 3 August 2026 the Governor's office put the figure at more than 474 GW, about 90 percent from data centers, and described it as more than five times ERCOT's record peak. Against the 91.1 GW record that ratio is about 5.2.

Billo also said that as ERCOT moved to batch studies, "some of these numbers become a little bit less relevant," and that the operator expected to present different metrics. So later counts may not be directly comparable with these.

Why would so many speculative requests exist? Under the older approach a developer could file at low cost and hold a place. Several sites could be filed for one real project. The result is a line full of placeholders, and the operator cannot easily tell which are real. The new rules are built to find out.

How to read a Texas headline about gigawatts

Headlines about Texas power demand mix several kinds of number, and the gap between them is large.

A request is a form filed by a developer. Under the old process it cost little and said nothing about financing, land or a customer. The 474 GW figure is a count of requests.

Approved to energize means ERCOT has cleared a load to draw power. ERCOT working group figures from June 2026, as summarised by the engineering firm Zero-Emission Grid, put that at about 8,927 MW, after duplicate and cancelled requests were removed.

Observed load is what is actually drawing power. The same summary gives a June 2026 non simultaneous peak of about 3,900 MW, meaning the sum of each large load's own monthly maximum, and a simultaneous peak of about 3,675 MW.

A forecast is the operator's planning assumption. In April 2026 ERCOT filed a preliminary long term forecast reaching about 367,790 MW of peak demand by 2032, as required by SB 6. Vegas said ERCOT believed "this forecast to be higher than expected future load growth," and the PUCT chair, Thomas Gleeson, said the agencies needed "to refine this number into something that's more usable," according to the Texas Tribune. ERCOT called the filing a preliminary snapshot, "not a prediction of what will be built," per the American Public Power Association.

Set side by side, roughly 474 GW requested, about 8.9 GW approved and about 3.9 GW observed show why the queue cannot be read as demand. When you see a state with hundreds of gigawatts of demand, ask which of these categories the number belongs to.

What Senate Bill 6 says

Senate Bill 6 passed in the 89th Legislature in 2025. Its enrolled text sets out these provisions:

Standards. The PUC must write standards for interconnecting large loads in ERCOT, aiming to support growth, limit stranded infrastructure costs and protect reliability. Stranded costs are costs of grid equipment built for a customer that never shows up or leaves early, which would otherwise fall on other ratepayers.

Threshold. Section 37.0561 says "the commission shall establish a demand threshold of 75 megawatts unless the commission determines that a lower threshold is necessary." It applies to new or expanded interconnections at a single site.

Disclosure of duplicates. An applicant must disclose whether it is pursuing a substantially similar request elsewhere in Texas that could lead it to change, delay or withdraw this one.

Fees and financial commitment. Initial screening studies carry "a flat study fee of at least $100,000," and any unused portion is credited toward obligations at the same site. Financial commitment options include per megawatt security, contributions in aid of construction and advance payment for equipment.

Curtailment. Section 39.170 applies "only to a load interconnected after December 31, 2025." Utilities serving transmission voltage customers must have a protocol for curtailing those loads during firm load shed, the emergency step of cutting customers off to protect the grid. Critical industrial loads and designated critical natural gas facilities are excluded.

Demand reduction. ERCOT must create a reliability service to "competitively procure demand reductions from large load customers with a demand of at least 75 megawatts," with at least 24 hours' notice and limited to designated periods.

Backup generation. Large loads must disclose on site backup generation that cannot export to the grid and can serve at least 50 percent of on site demand. ERCOT may direct deployment of that backup or curtailment of the load.

Co-location. Before an existing stand alone generator is paired with a new large load in a net metering arrangement, ERCOT must be notified. ERCOT studies it within 120 days of receiving complete information, and the PUC acts within 60 days of the study results. If the PUC does not act, the arrangement is considered approved.

Forecasting and cost allocation. The PUC must set criteria for how ERCOT counts forecast large loads in planning. It must also review the current four coincident peak method for wholesale transmission charges, which bases a customer's share on its use during the four monthly summer peaks, and amend its rules by 31 December 2026 so costs are assigned appropriately.

The bill does not use the phrase "remote disconnect." It speaks of protocols and equipment that let a load be curtailed, a narrower and more precise requirement.

From one at a time to batches: ERCOT's Batch Zero

Under the old model ERCOT studied each request on its own. In February 2026 board materials, ERCOT said this "can lead to repeated restudies that invalidate earlier results as conditions change," according to Industry Insider Texas. The replacement groups qualifying requests of 75 MW or more and studies them together. The steps reported were a market notice in January 2026, a board update in February, an update filed in PUCT Project No. 59142 on 5 March 2026, revision requests for the transitional Batch Study Zero in June 2026 and for an ongoing process in September 2026.

On 18 June 2026 the PUCT approved two ERCOT revisions creating the Batch Zero framework, according to a Sheppard Mullin client alert published on Mondaq on 26 June 2026. The alert describes how it works:

• Base Load: loads that met commitment criteria by 10 July 2026 are modelled in the study but are not subject to further reliability evaluation or megawatt allocation.
• Studied Load: loads that met criteria including site control, posted financial security and a notarized attestation by 24 July 2026 are assessed and allocated megawatts. Others wait for a future batch.
• Each Studied Load gets a Low Power Consumption level, its firm maximum draw, and a Maximum Power Consumption level, its desired peak. A load can go above the lower level only as a Provisional Controllable Load Resource, which must follow ERCOT dispatch including curtailment, or by pairing with on site or co-located generation under a withdrawal limit.
• Phase 1 is a system wide screening study producing megawatt allocations, due 9 April 2027. Phase 2 refines transmission upgrades for ERCOT's Regional Planning Group by 1 June 2027, with a final transmission plan expected in fall 2027.
• Default security is $50,000 per MW where specific upgrade costs cannot be determined. On withdrawal, or missing milestones by six months, 20 percent of remaining security is refunded and 80 percent goes to the transmission provider's rate base. Direct interconnection costs are paid in cash and are non refundable.

The August audit

On 3 August 2026 Governor Greg Abbott directed the PUCT and ERCOT to verify and audit every data center in ERCOT's interconnection process. The press release says the audit must be finished "before any data center project moves forward," and projects that fail "will be denied connection to the Texas grid." Each project must disclose state financial support, projected annual and peak electricity use, on site generation, water use and sources, cooling technology, community impact measures and ownership.

Gibson Dunn's client alert of 14 August 2026 says ERCOT filed for good cause exceptions on 10 August 2026 to move several Batch Zero deadlines, including the 7 August classification notices, and that the study process was temporarily paused while the audit runs. ERCOT expected verification to take "several months, but less than nine months." The firm saw "no imminent impact" on the 9 April 2027 results date, though ERCOT could ask for another exception. About 8,766 MW of loads between 25 and 75 MW, outside Batch Zero, were also to receive requests for information. The alert stresses that the directive "is not a moratorium on data center development."

Co-location in practice: docket 59220

SB 6's co-location rules have now been tested. In docket 59220, the PUCT approved a Crusoe AI data center of about 260 MW sharing an interconnection point with a 265.5 MW wind farm, with the developer's planned total near 525 MW, Utility Dive reported on 30 July 2026. The order requires the campus to be able to curtail its full load within 30 minutes in a grid emergency, rejected the argument that curtailment should be capped at the wind farm's size, and bars the load from paid demand response tied to the arrangement. Building next to a power plant does not take a data center outside grid emergency rules.

What a developer in Texas should expect

Pay to hold a place. Study fees, security and disclosure rules make it costly to sit in the queue without a plan, and most security is lost on withdrawal.

Expect to be curtailable. New transmission connected loads must be built so they can be cut in an emergency unless exempt, and docket 59220 shows the PUCT applying that to co-located sites in full.

Expect a batch calendar and an audit. Results arrive together on the operator's schedule, and the August audit adds disclosure on money, water and ownership before projects advance.

For the cost side of these buildouts, see what a gigawatt of AI capacity costs. For how flexible load can speed access elsewhere, see data center curtailment and flexible load.

What is firm and what is uncertain

Firm:

• SB 6 sets a 75 MW default threshold, a $100,000 minimum study fee, curtailment capability for loads interconnected after 31 December 2025, a demand reduction service and a 120 plus 60 day co-location review. These come from the enrolled bill text.
• ERCOT's record peak is 91.1 GW on 22 July 2026, per the EIA.
• The PUCT approved the Batch Zero framework on 18 June 2026, and the Governor ordered an audit on 3 August 2026.

Uncertain:

• How much of the 474 GW will ever be built. Only about 8.9 GW had approval to energize in June 2026, per ERCOT working group figures as summarised by a third party.
• The 2032 forecast of 367,790 MW, which ERCOT itself called higher than expected growth. A revised forecast was promised.
• Whether the audit delays Batch Zero results beyond 9 April 2027.
• How the PUC finishes the detailed rules on fees, the demand reduction service and transmission cost allocation.

What to watch next

• ERCOT's audit updates to the PUCT and its compiled audit report.
• Batch Zero results and megawatt allocations, due 9 April 2027.
• ERCOT's revised long term load forecast.
• PUC rules on transmission cost allocation, due by 31 December 2026 under SB 6.
• Further co-location cases after docket 59220.

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Quick check

Sources

• PJM, ERCOT, and SPP all set peak load records this summer, EIA Today in Energy, 15 October 2026
• Texas Legislature, Senate Bill 6, 89th Legislature, enrolled text
• Texas grid sees 233 GW of data center requests, BIC Magazine, 6 March 2026
• Texas grid operator forecasts massive growth in demand but says data is likely flawed, Texas Tribune, 17 April 2026
• ERCOT projects approximately 367,790 MW of demand by 2032, American Public Power Association, 17 April 2026
• ERCOT large load requests climb to 438 GW, New Project Media
• ERCOT LLWG summary, 19 June 2026, Zero-Emission Grid, 23 June 2026
• ERCOT moves toward batch study process for large power users, Industry Insider Texas, 17 March 2026
• PUCT approves Batch Zero framework, Sheppard Mullin via Mondaq, 26 June 2026
• Governor Abbott Directs Comprehensive Data Center Audit, Office of the Texas Governor, 3 August 2026
• What Governor Abbott's data center audit directive means for ERCOT and Batch Zero, Gibson Dunn, 14 August 2026
• Texas approves AI data center co-location next to wind farm, with curtailment caveats, Utility Dive, 30 July 2026
• How AI data centers connect to the grid, Compute Law Blog, updated 29 September 2026

Last reviewed: 19 October 2026.