BATCH ZERO / VERIFICATION RFI / BLOG
Your capital release still treats "financial security posted" as one checkbox. The Verification RFI Exhibit List splits it across three submitters.
Batch Zero Verification does not ask whether someone once said collateral was posted. It asks the ILLE for a deed and a financial-security exhibit, then asks the Interconnecting TSP or DSP to confirm cash (ACH) or a letter of credit on their own exhibit rows. Put those files in the naming convention before the next irreversible capital release.
Batch Zero Verification does not ask whether someone once said collateral was posted. It asks the ILLE for a deed and a financial-security exhibit, then asks the Interconnecting TSP or DSP to confirm cash (ACH) or a letter of credit on their own exhibit rows. Put those files in the naming convention before the next irreversible capital release.
This piece is not about who can press Submit in RIOO. That portal gate is covered separately. It is also not a repricing of $ per MW security, tariff non-utilization, or lender hedge covenants. Those exposure instruments are covered separately. This article is about the evidence package the Exhibit List actually indexes, and why a capital checklist that collapses land control and collateral into one "done" line fails the audit the RFI is built to run.
What the Exhibit List samples
On September 9, 2026, ERCOT posted the BZ Verification RFI Exhibit List. It is a four-column spreadsheet: exhibit identifier, submitter, title of supporting document, and file name of supporting document. The sample rows are not decorative. They show who must produce which proof.
| Exhibit | Submitter | Supporting document (sample title) |
|---|---|---|
| A | ILLE | Executed property deed |
| B | ILLE | Financial Security |
| A | TSP | ACH payment confirmation of ILLE cash collateral posting |
| B | TSP | Supporting documentation re: financial security |
| A | DSP | Letter of credit for ILLE financial security |
| B | DSP | Supporting documentation re: financial security |
Two facts follow immediately.
First, site control and financial security are separate ILLE exhibits. An executed deed does not stand in for the financial-security row, and a letter of credit does not stand in for the deed.
Second, cash collateral and letters of credit are not proved only by the ILLE. The sample TSP row is an ACH payment confirmation of the ILLE cash collateral posting. The sample DSP row is a letter of credit for ILLE financial security. The utility's confirmation is its own exhibit, under its own submitter code, with its own file name.
Why that split matters for capital
ERCOT's August 20, 2026 Batch Zero Verification and Audit presentation to the PUCT labels financial security as a TSP/DSP-confirmed requirement (sign-off type T). Examples of additional evidence listed there include the interconnection agreement, letter of credit, certified board resolution proving authorization, and a bank statement confirming security provided. Site control is listed separately, with documents demonstrating ownership interest such as a deed, lease, purchase and sale agreement, or option agreement.
Read that against a typical LOI capital-release condition that says "financial security posted" or "site controlled." Those phrases do not map one-to-one onto the Exhibit List. The RFI package can still be incomplete when:
- the ILLE has a deed but no financial-security exhibit file;
- the ILLE has an LOC copy but the DSP has not prepared its Exhibit A LOC confirmation row;
- cash was wired but the TSP has no ACH confirmation ready to upload under the TSP naming convention;
- an officer will attest, but the certified board resolution proving binding authority is not in the exhibit index.
None of those gaps are abstract. Market Notice M-A090926-01 (September 9, 2026) requires complete responses, including all required supporting documentation and notarized attestations from the ILLE, the Interconnecting TSP, and the Interconnecting DSP, through RIOO no later than 10 Business Days after issuance. An ILLE may request an extension of no more than 5 Business Days. The attestation chain and the exhibit files travel together. A capital release that assumes "we posted it" without naming which submitter holds which file is pricing an assumption, not an uploadable package.
Naming is part of the instrument
ERCOT's sample file names are themselves a control: `BZ9999_ILLE_ExhibitA_VerificationRFI_20260823`. Identifier, party, exhibit, document type, date. The User Guide (v1.1, September 11, 2026) tells parties that file naming conventions are specified in the Instructions, that supporting documents attach in the portal, and that sections such as site control and financial security are assigned by role. A shared drive folder labeled "FS docs" that is not indexed to exhibit identifier and submitter is not yet an RFI package.
What this piece does not claim
- It does not restate the portal rule that only the Interconnecting TSP path can submit the combined response. That is the separate Verification RFI process article.
- It does not reprice Planning Guide financial-security dollars per MW, Oncor non-utilization, or hedge/covenant mechanics. That is the separate financial-exposure article.
- It does not restate the §25.194 two-step study / SLLIA capital gate. That is the separate PUCT adoption article. Batch Zero Verification exhibits and §25.194 instrument forms can both be true on the same campus; they are different instruments.
- It does not invent MW, $, campus totals, or bank-product menus beyond the sample exhibit titles and the PUCT presentation evidence examples.
Capital checklist before the next irreversible spend
Before the next LOI hard date, PSA deposit, or construction draw that assumes Batch Zero verification will clear on schedule, put these on one page with a named owner on each line:
- ILLE Exhibit A - site control. Executed deed (or other ownership-interest document the package will actually rely on). File named to the convention.
- ILLE Exhibit B - financial security. The ILLE financial-security exhibit file, not a narrative status email.
- TSP path - cash. If cash collateral, ACH payment confirmation ready as a TSP exhibit, plus supporting FS documentation.
- DSP path - LOC. If a letter of credit is the instrument, DSP Exhibit A LOC file ready, plus supporting FS documentation.
- Authorization. Certified board resolution (or equivalent) proving the attesting person has binding authority, indexed with the package.
- Attestations. Notarized ILLE attestation and TSP/DSP attestations staged so they are not the last search on day nine.
- Index. One Exhibit List workbook row per file, matching identifier / submitter / title / file name before anyone touches RIOO.
If any line is blank, capital is still treating "financial security posted" as one checkbox. The Exhibit List does not.
Sources
- ERCOT, BZ Verification RFI Exhibit List, September 9, 2026 - https://www.ercot.com/files/docs/2026/09/09/BZ-Verification-RFI-Exhibit-List.xlsx
- ERCOT Market Notice M-A090926-01, Issuance of Batch Zero Verification Requests for Information, September 9, 2026 - https://www.ercot.com/services/comm/mkt_notices/M-A090926-01
- ERCOT, RFI Portal in RIOO, Batch Zero Verification, User Guide for TSPs, DSPs and Load Entities, Version 1.1, September 11, 2026 - https://www.ercot.com/files/docs/2026/09/11/Verification-RFI-User-Guide-v1.1.pdf
- ERCOT, Batch Zero Verification and Audit (PUCT presentation), August 20, 2026 - https://www.ercot.com/files/docs/2026/08/20/Batch-Zero-Verification-and-Audit-PUCT-Presentation.pdf
- ERCOT Large Load Integration page (exhibit list, attestations, user guide) - https://www.ercot.com/services/rq/large-load-integration
Related Sitebraid pieces (do not collapse)
- Process / portal: https://sitebraid.dev/blog/ercot-batch-zero-verification-rfi-developer-response-texas/
- Exposure / tariffs / covenants: https://sitebraid.dev/blog/ercot-batch-zero-financial-exposure-security-tariff-covenants/
- §25.194 capital gate: https://sitebraid.dev/blog/puct-adopted-25194-large-load-financial-security-texas/