Oct 12 is not another Batch Zero exhibit clock. It is the State and Community Impact RFI.

Campus capital still prices the October 12, 2026 State and Community Impact RFI like optional paperwork next to Batch Zero Eligibility Verification. That is the wrong instrument. Complete responses, supporting documents, and a notarized developer attestation must land in RIOO by 5:00 p.m. CPT on October 12. Non-response is reported to the Public Utility Commission of Texas and the Office of the Governor. Section C water answers are issued on TWDB's behalf and carry a Texas Water Code §16.012 criminal path for failure to fully respond.

This piece is not a restatement of the Batch Zero Eligibility Verification RFI or the K40 financial-security exhibit split. It is not the live TWDB water-survey enforcement read against the October 14 Governor update clock. It is not the adopted §25.194 financial-security / CIAC capital gate. Those instruments decide eligibility exhibits, survey enforcement, and study / SLLIA postings. This article is about disclosure and capital readiness for the separate Community Impact RFI before the next LOI, PSA hard date, or construction draw that treats October 12 as soft.

What the Market Notice actually issued

Market Notice M-B091426-01 (September 14, 2026) issued ERCOT's Request for Information regarding Data Center State and Community Impacts. The hub page and the RFI Question Reference (v1.0, September 18, 2026) restate the directed topics from the Governor's August 3, 2026 letter: public financial assistance and tax benefits; dependency on grid power and use of on-site generation; water sources and consumption; cooling technologies; noise, light, and traffic impacts; and ownership and controlling interests.

ERCOT intends to collaborate with the PUCT and publish a report on or before December 10, 2026. That report date is not a substitute for the October 12 response clock.

Two applicability buckets, not one queue story

Under M-B091426-01, the RFI goes to developers in either of these buckets:

1. Any Interconnecting Large Load Entity developing a data center facility that ERCOT has conditionally classified as base load or studied load in Batch Zero, that has not yet energized its facility or facility addition at transmission voltage (60 kV or above).
2. Any developer of a proposed data center with peak requested load of at least 25 MW but less than 75 MW that a TSP or DSP reported in the August 19, 2026 Medium Load RFI, classified as a "Substantiated Load" under ERCOT Protocols Section 2.1, and not yet energized at any voltage level.

If your capital memo still asks only whether the campus is in Batch Zero Verification, you are asking the wrong screening question for this instrument. Medium-load Substantiated Load campuses sit inside Community Impact even when they sit outside Large Load Batch Zero. Batch Zero conditional campuses sit inside Community Impact even when Verification RFI work is already underway. The RIOO User Guide is explicit that the two RFI workstreams have different questions and different deadlines.

How the package actually closes

The Responsible TSP or DSP receives the RFI in RIOO and must submit at least one developer contact by the end of the second Business Day after issuance. The developer completes the questionnaire, uploads supporting documents, and uploads the notarized attestation (Section G). Only the Responsible TSP or DSP can submit the completed package to ERCOT.

Complete responses, including required supporting documentation and the notarized attestation, are due through RIOO no later than 5:00 p.m. Central Prevailing Time on October 12, 2026. Failure to respond to the RFI or any part of it will be reported to the PUCT and the Office of the Governor.

That is a disclosure gate with named escalation, not a soft planning ask you can leave open while treating the LOI as current.

Section C is water on TWDB's behalf. Do not collapse it into the survey piece.

The September 14, 2026 Governor letter directed TWDB to partner with ERCOT on water consumption, sources, and water-efficient technologies. ERCOT coordinated Section C with the PUCT and TWDB. The TWDB Executive Administrator authorized ERCOT to issue Section C on TWDB's behalf. ERCOT forwards those answers to TWDB. Respondents do not separately send Section C to TWDB.

M-B091426-01 and the Question Reference state that, in accordance with Texas Water Code §16.012, any failure to fully respond to Section C may subject a respondent to criminal penalties and other potential consequences.

Hold the overclaim. The separate TWDB water-use survey letter prices missed Calendar Year 2025 survey return as criminal-offense and Chapter 11 risk, with October 14 as the Governor's enforcement-progress update. That clock belongs to the live TWDB piece and checklist resource. This article claims only what Section C primaries say: criminal penalties and other potential consequences under §16.012 for failure to fully respond. Do not invent Chapter 11 disqualification for Section C itself. Two water surfaces can both be true on one campus. They are not the same instrument.

Capital checklist before the next irreversible spend

Before the next LOI amendment, PSA hard date, or construction draw that assumes October 12 is optional, put these on one page with a named owner:

1. Applicability. Confirm whether the campus sits in the Batch Zero conditional base/studied not-yet-energized transmission bucket, the Medium Load 25–<75 MW Substantiated Load not-yet-energized bucket, both, or neither.
2. Workstream split. Track Community Impact separately from Batch Zero Eligibility Verification. Different questions. Different deadline. Different attestation.
3. RIOO path. Confirm Responsible TSP/DSP contact invitation, developer login, and that only the Responsible TSP/DSP submits to ERCOT.
4. Section coverage. Assign owners for Sections A (tax / public assistance), B (grid vs on-site generation), C (water on TWDB's behalf), D (cooling), E (noise / light / traffic / community measures), and F (ownership / controlling interests).
5. Section C discipline. Treat incomplete Section C as a §16.012 exposure path per the Market Notice and Question Reference. Keep the TWDB survey / October 14 checklist on a separate row.
6. Notarized attestation. Complete the ERCOT attestation form with authorized signature and Texas notary, then upload before TSP/DSP submission.
7. Submission evidence. Capture Ready-for-TSP/DSP-review status, TSP/DSP submit confirmation, and any ERCOT return-for-correction loop before capital treats the package as closed.
8. Capital calendar. Do not authorize spend that assumes a clean Community Impact file after 5:00 p.m. CPT on October 12 if the RIOO confirmation is still blank.

If line 1 or line 8 is blank, capital is still pricing a Governor-directed disclosure RFI like a soft ask.

What this piece does not claim

• It does not restate Batch Zero Eligibility Verification exhibit rows, Verification clocks, or K40 financial-security exhibit splits.
• It does not restate the live TWDB survey criminal-offense / Chapter 11 / October 14 piece as the spine. Cross-link it; do not collapse it.
• It does not restate adopted §25.194 study / SLLIA financial-security and CIAC gates.
• It does not invent campus counts, MW totals, dollar outcomes, or client results.
• It is not legal, engineering, accounting, tax, or regulatory advice. The RIOO RFI, Market Notice, Question Reference, attestation form, executed interconnection documents, and counsel review govern.

Related Sitebraid pieces (do not collapse)

• TWDB survey enforcement (adjacent water surface): https://sitebraid.dev/blog/texas-twdb-data-center-water-survey-enforcement-oct-14/
• TWDB water-survey campus readiness checklist: https://sitebraid.dev/resources/texas-twdb-water-survey-campus-readiness-checklist/
• Batch Zero owner readiness pack: https://sitebraid.dev/resources/ercot-pgrr145-batch-zero-large-load-owner-readiness-pack/
• §25.194 capital gate: https://sitebraid.dev/blog/puct-adopted-25194-large-load-financial-security-texas/
• Batch Zero Verification FS exhibits (K40): https://sitebraid.dev/blog/ercot-batch-zero-verification-rfi-financial-security-exhibits/
• Resources library: https://sitebraid.dev/resources/