Batch Zero isn't the last large-load study rule

Batch Zero set one Large Load study frame. ERCOT is now remaking Batch studies, model and case building, the Regional Transmission Plan, and RPG review into a single Comprehensive Transmission Planning (CTP) process, with Batch 1+ Revision Requests still ahead. Before you treat Batch Zero as the last interconnection study framework your campus underwrites, read the Workshop 3a proposals that ERCOT says are ready to move into those Revision Requests.

The CTP / Batch 1+ remake covers re-study and carry-forward for unmet ramp and uncommitted loads, Batch Zero-excluded loads into Batch One, change-request restudy rules, the LIOO portal, and the NPRR/PGRR path. Batch Zero tenant allocation is already covered at Batch Zero tenant allocation. The PGRR145 Batch Zero readiness pack is at PGRR145 Batch Zero owner readiness pack.

What CTP remakes

ERCOT's September 14-15, 2026 Board update on Comprehensive Transmission Planning states the objective in plain terms: integrate the batch study, modeling, and reliability studies into a single comprehensive transmission planning process.

The same deck lists initial Batch 1+ Revision Request priorities across four focus areas:

• Large Load interconnection: ILLE-TSP-ERCOT interaction, unmet-ramp resubmittal across Batches, carry-forward of non-committed Large Loads, and governance for post-study project changes.
• Eligibility: financial security methodology for transmission upgrades and direct interconnection costs aligned with PUCT Project 58481 / adopted §25.194.
• Study frameworks: Batch study scope, short circuit, SSO, and dynamic model change evaluation.
• Bring-Your-Own-Generation and Withdrawal-Limited Private Use Network options.

The §25.194 financial-security mechanics sit in the adopted rule itself and aren't restated below.

Stakeholder workshops run through the fall to inform those Revision Requests, with Workshop #3 now split into 3a and 3b in place of the Board deck's single October 14 date:

• Workshop #1: August 31, 2026
• Workshop #2: September 24, 2026
• Workshop 3a, Batch Scope: October 15, 2026, 1:00 PM, ERCOT Austin
• Workshop 3b, Planning Scope: October 20, 2026, 1:00 PM, ERCOT Austin
• Initial NPRR/PGRR filing target: November 1, 2026
• TAC consideration: March 2027
• Board consideration: April 2027

The filing, TAC and Board dates are targets.

Workshop 3a: re-study and carry-forward proposals moving into Revision Requests

The Workshop 3a deck was posted October 9, 2026 for the October 15 meeting. It states three Batch re-study proposals. It then says ERCOT considers stakeholder conceptual review substantially complete for those items and will begin incorporating them into Revision Requests.

Q6, ILLEs with unfulfilled ramp: ERCOT is proposing that ILLEs with unfulfilled ramp may request re-study under their original Large Load Batch (LLB) tracking number.

Q7, uncommitted large loads: ERCOT is proposing that large load projects that did not commit in a prior Batch may request inclusion in subsequent Batch studies if they (i) formally request it and (ii) pay a new study fee. The ILLE's financial security, intermediate agreement, LL tracking number, and all portal information would carry forward to the new Batch study.

Q8, large loads excluded from Batch Zero: ERCOT is proposing to allow large loads that received a tracking number but were excluded from Batch Zero to request inclusion in Batch One. ERCOT will waive the subsequent Batch fee if the interconnecting TSP/DSP attests that the ILLE has already paid at least $100k in study fees for the project. The ILLE must meet all other Batch One study requirements.

Who asks, who attests, and who incorporates: the ILLE requests re-study or later-Batch inclusion; the interconnecting TSP or DSP attests for the $100k fee-waiver path; ERCOT proposes the approach and says it will begin incorporating the items into Revision Requests. Do not read the deck as already-filed NPRR or PGRR text.

Change requests and what "restudy in the next Batch" means

The same deck sets preliminary rules for ILLE changes to batch projects. The ILLE must submit a change request in the portal. Some changes are subject to restudy while keeping base-load status for prior commitments where the deck says so. Examples include an earlier in-service date, an MW increase, an earlier or larger LCP ramp, a non-equivalent POI change, or an adverse VRT/FRT dynamics impact. Some later or smaller changes need no restudy but still show up in the next Batch / CTP study. Administrative changes stay administrative. Those include ownership, disclosure info, and a DSP change with no POI change.

The deck defines "restudy in the next Batch" unless otherwise noted. The Large Load will forfeit any previously allocated MWs. The Large Load will enter the next Batch as a "studied load." The Large Load must pay the Batch study fee and meet all other prerequisites for the Batch study, including any relevant deadlines. That forfeiture line is the CapEx and schedule risk.

ERCOT again states that stakeholder conceptual review is substantially complete for these change-request and restudy items and that it will begin incorporating them into Revision Requests. Until those Revision Requests file and clear the PRS / ROS / TAC / Board path, treat the deck language as proposed process design, not Protocol text.

LIOO portal and Large Load transparency

Workshop 3a also previews Load Integration & Ongoing Operations (LIOO): ERCOT's centralized application and data repository for Large Loads. The deck describes a single location to request, collect, and maintain Large Load information across the interconnection lifecycle, with improved visibility into interconnection status. For the initial release, anticipated December 2026, ERCOT will enter and maintain Large Load data; external participants will initially have read-only dashboard access. ERCOT notes it is still working process sequence and hand-offs for a later discussion.

On reporting, the deck points to NPRR 1267 (approved June 2025, not yet implemented) as the starting point for Large Load transparency.

NPRR 1267's Protocol section 3.2.7 would require a monthly Large Load Interconnection Status Report on the ERCOT website. The report would aggregate requests by Load Zone, TSP, load type, calendar quarter of TSP submittal, requested energization quarter, size range, interconnection status, and co-location status, with customer-data protections. That report is a transparency baseline proposal in the workshop materials. Because NPRR 1267 is not yet implemented, the monthly report is not publishing today.

Before the next commitment

How to structure any re-study request, later-Batch inclusion, fee-waiver attestation path, or change request is the sponsor's call, made with counsel. So is how to underwrite forfeiture of previously allocated MWs if a restudy is required. The steps below gather the facts for those calls. None of this is legal advice.

1. Map every open Large Load against its LLB tracking number, commitment status, allocated MW (if any), and whether any ramp remains unfulfilled.
2. If the load was excluded from Batch Zero but holds a tracking number, gather the study-fee payment evidence a TSP/DSP would need to attest that at least $100k has already been paid, and calendar Batch One study prerequisites separately.
3. List every planned change that would go through the portal (in-service date, MW, LCP ramp, POI, load dynamics, co-location, ownership) and mark which deck row treats it as restudy, no-restudy-but-next-Batch, or administrative.
4. Price the restudy consequence in plain terms: forfeit previously allocated MWs, re-enter the next Batch as studied load, and pay the Batch study fee again.
5. Track Workshop 3a (Oct 15) and 3b (Oct 20) materials and any NPRR/PGRR filing against the Board's November 1, 2026 initial-filing target. Once those materials post, use the posted Revision Request text and later workshop decks, not the pre-workshop summary above.
6. Decide with counsel whether CapEx, tenant, and financing models still assume Batch Zero study outcomes as final, or whether they need a Batch 1+ / CTP contingency for re-study and carry-forward.

If your energization date now depends on Batch 1 or later transmission planning, our Power & energization work tests each power route against the dates your tenants have been promised.