The words tenant, lessee and occupant appear zero times in the rule that allocates your megawatts

Update, September 13, 2026. ERCOT issued conditional Batch Zero classifications on September 3, 2026 under Market Notice M-A080326-04. The classifications are conditional: ERCOT states that conditional inclusion is not final interconnection approval and does not establish an energization date. The allocation mechanics described below are unchanged. The timing caution at the end of this post stands, and the process remains behind its original schedule.

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Not in the adopted PGRR145. Not in any of the twelve sections of the ERCOT Planning Guide. We searched the full text of both for tenant, tenants, lessee, occupant, sublease and subtenant, and the count is zero in every case.

That is not an oversight to complain about. It is the structural fact that governs every multi-tenant campus in the Batch Zero process, and it means the hardest allocation problem on your campus is one the rules will never solve for you.

Here is why. A Large Load is defined by site and point of interconnection, not by occupant:

"One or more Facilities at a single site with an aggregate peak Demand greater than or equal to 75 MW behind one or more common Points of Interconnection (POIs) or Service Delivery Points."

Aggregation is geographic. So a campus with four tenants across three phases is one Large Load. One Interconnecting Large Load Entity. One Load Commissioning Plan. One interconnection agreement. One financial security posting.

ERCOT issues a number to that entity. What the entity does with it among tenants who signed leases at different times, for different phases, with different commencement dates, is not addressed anywhere in the rule.

The allocation is per year, and the early years are constrained

The Batch Zero Interconnection Study does not produce a single megawatt figure. Under Section 9.3.2 it assesses steady state and stability impact "for years 2028 through 2032" and determines "the amount of load that may be served reliably for each year within the study scope."

Five studied years, each with its own number. Then 2033: "The amount of load that may be reliably served for 2033 will be set to the requested amount."

Read that carefully, because it is easy to misread as good news. The 2033 figure is not an engineering finding that upgrades will have landed. It is an administrative default. The rule sets it to what you asked for.

For the studied years, Section 9.2.4(2) is explicit that some of your capacity may be contingent:

"the Interconnecting TSP shall update the preliminary LCP to reflect the amount of peak Demand that can be served reliably for each year of the Batch Zero Interconnection Study scope. If one or more levels of Demand in the LCP are contingent on one or more transmission upgrade projects... those transmission projects shall be identified in the updated LCP."

And release of the contingent portion is gated, under Section 9.6(2)(b):

"The applicable TSP shall notify ERCOT when a transmission upgrade identified in an LCP becomes operational. ERCOT must give written approval before Demand may increase."

So the realistic shape of a Studied Load outcome is not a number. It is a schedule: this much in 2028, more in 2030 if a named upgrade is in service, the balance later. That is a phasing document before it is a grid document.

What the Load Commissioning Plan actually requires

The LCP is the instrument that carries your allocation. Its definition in Planning Guide Section 2.1:

"An agreed upon schedule between the interconnecting Transmission Service Provider (TSP) and Interconnecting Large Load Entity (ILLE) for connecting a Large Load in increments defined by the ILLE, compiled in the format prescribed by ERCOT, detailing dates, cumulative peak Demand amounts, and transmission upgrades that would be required to be in service for each amount of peak Demand."

Four required elements: dates, cumulative peak demand amounts, load increments, and the upgrades required in service for each level. Section 9.2.4(1) adds that the LCP "must specify the load increments and timeline by which the ILLE intends to increase peak Demand."

Two things follow for a campus. The increments are "defined by the ILLE," so the ramp schedule is yours to propose, which means it has to be built from tenant commencement dates you may not have yet. And Section 9.5.1(1)(a)(ii)(B) makes the LCP an operating constraint, not a forecast: the ILLE must "Maintain Load consumption at or below the level(s) of peak Demand established in the Load Commissioning Plan."

A tenant that ramps faster than your LCP says is your compliance problem, not theirs.

The mechanic that should be in every lease, and is in almost none

Your allocation is protected against the grid operator and unprotected against your tenant. Both halves of that are in the rule, and they are not in tension. One shields your number from ERCOT changing it. The other exposes it to your own non-performance.

The protection first. Section 9.5(5):

"The Batch Zero Refinement Study described in this section shall not include an adjustment to the allocated MWs for any Large Loads included in the Batch Zero Interconnection Study for which the Large Load has met the required commitment criteria per Section 9.4."

That shields committed megawatts from downward adjustment in the Refinement Study specifically. It is a real protection, and it is narrow.

The exposure sits elsewhere, in mandatory terms, twice:

Section 9.7.3(1)(f): "ERCOT must reallocate contracted peak demand that is withdrawn by an ILLE."

Section 9.7.4(6): "ERCOT must reallocate non-utilized capacity."

Must, not may. And withdrawal is not the only trigger. Section 9.7.4(1):

"Not later than 30 days after an ILLE fails, by six months, to satisfy a milestone in its schedule for phased energization, the Interconnecting DSP or the Interconnecting TSP must notify ERCOT of the ILLE's non-utilized capacity."

Miss a phased energization milestone by six months and your capacity enters mandatory reallocation without you having withdrawn anything.

The cost of getting there is set out in Section 9.7.3(1)(c) through (e): financial security is drawn down, 20 percent of the balance is refunded, the remaining 80 percent goes to TSP rate base, and contributions in aid of construction are not refundable.

Now put that next to a multi-tenant campus. Your LCP milestone dates are built on tenant commencement. If an anchor tenant delays a phase by two quarters, that is a leasing conversation. If the delay reaches six months against an LCP milestone, it becomes a reallocation event with a security forfeiture attached, and the tenant whose delay caused it has no privity with ERCOT and no obligation under your interconnection agreement.

That asymmetry is the thing to draft for.

What belongs in the lease

Five provisions, none of which appear in a standard data center lease.

An LCP milestone covenant. Tie the tenant's energization and ramp obligations to the specific LCP milestone dates, not to generic commencement language. The LCP is a filed document with named dates. Reference it.

A shortfall apportionment formula, agreed before the allocation arrives. If the campus receives less than requested in a given year, which tenant absorbs it? Pro rata by contracted load, priority by lease execution date, and phase seniority all produce different answers, and all of them are defensible. What is not defensible is discovering in February 2027 that three leases each promise capacity the campus did not receive.

Three defensible formulas, three different tenants short

Take a campus that requested 600 MW and received 350 MW for 2028, with a further 150 MW contingent on a named transmission upgrade expected in 2030. Three tenants are signed:

The 2028 shortfall is 250 MW. Here is what each apportionment rule does with it:

Same allocation, same three leases, three different outcomes. Pro rata shorts everyone and satisfies no one. Lease execution priority rewards Tenant A, who signed first but does not energize until 2030, and leaves Tenant C with nothing in a year it expected to be building. Phase seniority gives Tenant B its full contracted load and zeroes the tenant who signed first.

Every one of those is defensible. None of them is obvious. And if the leases are silent, the question gets decided under commercial pressure, after the number arrives, by whoever has the most leverage rather than by whatever the parties would have agreed at signing.

That is the conversation to have while the leases are still being drafted.

A contingent capacity provision. For the portion of your allocation gated on a named transmission upgrade, the lease should say what happens if the upgrade slips: reduced commencement, abated rent, extension right, or termination. Section 9.6(2)(b) means that capacity does not exist for you until ERCOT approves it in writing.

Ramp discipline with teeth. The ILLE carries the obligation to stay at or below LCP levels. The lease needs a corresponding tenant obligation and a remedy, because the consequence of breach lands on the campus, not the tenant.

Delay damages sized to the actual exposure. A six-month milestone slip risks 80 percent of posted security plus non-refundable CIAC. Standard delay damages are not calibrated to that. Size them to it, or accept that the campus is carrying a tenant's schedule risk unpriced.

Who is the ILLE, and can it be a tenant

The definition, from Nodal Protocols Section 2, is broader than most people assume:

"Any Entity upon whose behalf a Transmission Service Provider (TSP), Resource Entity, or Interconnecting Entity (IE) has submitted a request to interconnect a Large Load to the ERCOT System."

No ownership test. No tenancy test. "Any Entity." The operative constraint is procedural rather than substantive: the ILLE is whoever the request was submitted on behalf of.

And a tenant can satisfy site control. Section 9.7.1(1)(a)(i) accepts "A signed and executed lease agreement for one or more parcels of land sufficient to accommodate the ILLE's planned facilities at the proposed load location for a duration of at least five years."

So on the face of the rules, either a landowner or a long-term lessee could hold the role. What the rules do not address is whether it can change hands. We found no provision for assignment, transfer, or substitution of the ILLE designation.

The practical consequence is narrower than it first appears. Silence in the Planning Guide is not prohibition, and a change of entity would ordinarily run through TSP and ERCOT registration processes whether or not this rule addresses it. What the silence does mean is that you should confirm the path with your TSP rather than assume it, and settle the question before submission rather than discover it afterward. Whoever holds that designation carries the attestations, answers the verification RFI, posts the security and bears the reallocation exposure. On a campus where the landlord develops and tenants operate, that is a commercial allocation dressed as an administrative formality.

Why Texas is the market you can draft against

The reasonable response to all of this is to ask how Texas compares, and whether the constraints are worse elsewhere.

The honest answer is that Texas is the market where the mechanics are settled enough to plan against, and that is not the same as being the easiest.

Every other major market moved in 2026, and most are still moving. On June 18, 2026, FERC declined to issue a single national rule for large load interconnection and instead issued show cause orders to six RTOs and ISOs under section 206, requiring each to justify why its existing tariff remains just and reasonable. That is the same day the Commission approved PGRR145 in Texas, which is a coincidence rather than a connection: ERCOT is not FERC-jurisdictional for these purposes and was not among the six. Several sought abeyance rather than responding on the original schedule.

The shapes differ more than a ranking would suggest. SPP built the most developed large load framework of any RTO across three orders in 2026, and processes large loads serially, on a rolling basis, while batching generation. PJM's Board declined to create a load interconnection queue at all, writing in January 2026 that "At this time, the Board is not taking action to restrict the interconnection of new load through the creation of a dedicated load interconnection queue or through other limiting measures." The hedge is the Board's own, and it matters: a decision framed as current is a decision that can be revisited. MISO is designing both large load reliability requirements and a cycle-based study process in its stakeholder groups, neither of which is filed or approved. In Georgia, the standard large load tariff was closed in February 2025 to customers with expected peak demand of 100 MW or more at contiguous premises, which moves the terms into a negotiated contract rather than a published rate.

For a campus developer holding optionality across markets, the useful comparison is not which market is fastest. It is which market lets you write a lease against a known allocation mechanic. Today that is a short list, and the items on it are changing quarter by quarter.

What to do before the next milestone

Confirm which entity holds the ILLE designation and whether that is the entity you intend to carry the exposure.

Read your LCP against your rent commencement dates, specifically for the six-month gap that converts a leasing delay into a reallocation event.

Identify which portion of your allocation is contingent on a named transmission upgrade, and confirm that every lease promising that capacity says what happens if the upgrade slips.

Agree the shortfall apportionment formula across all executed leases now, rather than after the number arrives.

One caution on timing. The published Batch Zero dates are adopted rule: the study report and updated LCPs reflecting allocations by January 29, 2027, and the commitment list by March 1, 2027. But the process is already running behind its own schedule under good cause exceptions granted by the Commission, and ERCOT has not yet issued classifications. Plan against the dates. Do not sign against them.

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