CIAC is cash you do not get back. Financial security returns on a 20-percent schedule. Model them as one line and campus liquidity breaks.

Under adopted 16 TAC §25.194, contribution in aid of construction is its own capital instrument: cash only, invoiced before the utility incurs direct interconnection costs, unpaid after 10 working days means draw on financial security and cancel the interconnection request, and CIAC itself is not refundable. Financial security returns 20 percent of the remaining balance at energization, then the rest in 20 percent increments against SLLIA minimum-billing milestones. The October 8, 2026 effective date is six calendar days from this build. Put the asymmetry on one page before the next cash release.

This piece is not a restatement of the September 18 fee-removal capital-gate article, where CIAC appears only as a checklist line. It is not the Category K #46 instrument-election piece on cash versus guaranty versus letter of credit. It is not Batch Zero exhibit packaging, switchyard drawdown, or CapEx sequencing under provisional class flip. This article is about recovery and refund timing: CIAC cash that does not return versus financial security that releases on a remaining-balance schedule, and the liquidity trap when capital models them as one collateral stack.

Figures and form labels below come from PUCT Project 58481 Item 218 (Order Adopting New 16 TAC §25.194, filed September 18, 2026) and Item 219 (effective date October 8, 2026). No campus megawatt or dollar totals are invented.

What the adopted CIAC language locks

At SLLIA, §25.194(f)(2)(C) requires the large load customer to pay all direct interconnection costs through CIAC, with no standard or other allowance offered to offset those payments. The rule then binds five mechanics:

1. Cash only. CIAC must be paid as a direct cash payment. It is not an alternate form of financial security and cannot be satisfied with a guaranty or letter of credit.
2. Invoice before incur. The interconnecting DSP or TSP must invoice the customer for direct interconnection costs before incurring those costs.
3. Ten working days unpaid. If the customer fails to pay an invoice within 10 working days after receipt, the utility may draw on the customer's financial security for the invoiced amount and cancel the interconnection request.
4. True-up is bill credit or surcharge. Once facilities are completed, CIAC is trued up to actual costs. The customer may receive a credit or surcharge on the bill for the difference relative to the estimate. That path is not a refund of CIAC as a posted instrument.
5. CIAC is not refundable. The adopted text states that at the SLLIA CIAC clause and again under the non-utilized transmission capacity path at §25.194(g)(4).

The commission's Item 218 response on timing is explicit: it declined commenter proposals to stretch CIAC payment deadlines, replaced a same-day-of-execution CIAC deadline with invoice-before-incur plus the 10-working-day pay clock, and declined to let long-lead financial security be drawn down to pay CIAC. Cash CIAC and posted financial security remain separate instruments.

What financial security return looks like next to that

Financial security under §25.194 is a different recovery path. At the SLLIA stage, §25.194(f)(3)(C) requires the interconnecting DSP or TSP to return 20 percent of the remaining balance of financial security when the large load customer energizes, and the remainder ratably in 20 percent increments as the customer meets the milestones identified in the SLLIA for large-load minimum billing demand under §25.193.

Read the base carefully. The percentage runs against the remaining balance after outstanding amounts owed are collected. It is not 20 percent of the original posting. An open invoice at energization reduces the base before the first release, and every later increment compounds off the reduced figure.

On withdrawal of all or a portion of contracted peak demand after SLLIA, §25.194(f)(3)(B) requires collection of outstanding amounts owed, then subtraction of 20 percent of the financial security associated with the withdrawn contracted peak demand, before return of the remaining balance. That haircut is a financial-security forfeiture path. It is not a CIAC refund path. CIAC remains non-refundable under the same rule stack.

Intermediate-stage return and forfeiture language in §25.194(d)(3) still runs against financial security, not against CIAC. Direct interconnection costs inside significant-equipment procurement still require cash CIAC, and that CIAC is not refundable even when intermediate financial security credits toward long-lead spend.

The campus liquidity trap

An owner who models "interconnect collateral" as one line item collapses two instruments with opposite recovery profiles.

CIAC cash leaves the campus balance sheet as a direct payment for direct interconnection costs. The rule does not give that cash a return schedule. True-up may adjust the bill after facilities are complete; it does not convert CIAC into returnable security. Miss the 10-working-day invoice clock and the utility may draw the financial security that was supposed to be the returnable stack and cancel the interconnection request. The unpaid CIAC invoice threatens both the cash already owed and the security that was supposed to come back later.

Financial security, by contrast, is designed to release. Energization starts a remaining-balance 20 percent return, then 20 percent increments against SLLIA minimum-billing milestones. Withdrawal after allocation still returns a remainder after amounts owed and a 20 percent haircut on the security tied to withdrawn demand. That is recovery timing. It is not available for CIAC.

The trap is sequencing. Capital that reserves one collateral pool for "utility interconnect" without naming CIAC cash versus financial security will understate irreversible cash at invoice, overstate recoverable collateral at energization, and miss the cancel path that fires when a CIAC invoice sits unpaid for 10 working days. Form election for financial security is Category K #46. This piece is the recovery asymmetry after the forms are chosen.

Clock: October 8, 2026

Item 219 sets the effective date of new 16 TAC §25.194 at October 8, 2026. From this build day (October 2, 2026) that is six calendar days. Campuses still underwriting as if CIAC and financial security shared one return schedule, or as if the March proposal's non-refundable interconnection fee were the only non-recoverable line, are underwriting a superseded model. The September 18 fee-removal article covers fee deletion and dollar gates; this article isolates CIAC recovery timing.

What this piece does not claim

• It does not restate the study-fee / intermediate FS / greater-of SLLIA FS dollar gates, the fee-removal story, or the accepted FS forms election as the spine.
• It does not restate Batch Zero exhibit / submitter rows, Community Impact disclosure, switchyard drawdown cost-to-complete, or CapEx sequencing under provisional class flip.
• It does not invent megawatts, campus dollar totals, bank products, or client outcomes.
• It is mechanics description, not legal, tax, accounting, treasury, or regulatory advice. Executed utility agreements and the live SLLIA form rulemaking (including Project No. 58000) govern where they refine milestones.

Capital checklist before the next CIAC invoice or FS release assumption

Before the next SLLIA cash release, CIAC invoice payment, or capital model that treats interconnect collateral as one recoverable pool, put these on one page with a named owner on each line:

1. Instrument named. CIAC cash versus financial security. Not "utility collateral."
2. CIAC cash reserved. Direct interconnection costs sized as cash only; no guaranty or LOC substitution assumed.
3. Invoice-before-incur calendar. Who receives DSP/TSP invoices, who approves wire/ACH inside 10 working days, and who owns escalation before day 10.
4. Miss-pay consequence staged. Unpaid CIAC invoice: utility may draw FS for the invoiced amount and cancel the interconnection request.
5. Non-refundable labeled. CIAC is not refundable. True-up is bill credit or surcharge after facilities complete, not a security return schedule.
6. FS return schedule separate. Energization: 20 percent of remaining balance; then 20 percent increments against SLLIA minimum-billing milestones. Base is remaining balance after amounts owed.
7. Withdrawal haircut separate. Withdrawal of contracted peak: amounts owed first, then 20 percent of FS associated with withdrawn demand, then remainder returned. Still not a CIAC refund.
8. October 8 clock owned. Effective date on the capital calendar; models that still price a shared CIAC/FS return path marked superseded.

If line 1 is still "interconnect collateral," capital is still collapsing a non-refundable cash instrument into a returnable security schedule. The adopted rule text does not. Broader §25.194 owner readiness (without collapsing this recovery spine) is in the Project 58481 Filing 206 Large-Load Owner Readiness Pack linked in Sources.

Related Sitebraid pieces (do not collapse)

• §25.194 fee removal / dollar gates (adjacent): https://sitebraid.dev/blog/puct-adopted-25194-large-load-financial-security-texas/
• Interconnect security instrument election (K46): https://sitebraid.dev/blog/texas-data-center-interconnect-security-loc-cash-guaranty/
• Batch Zero Verification FS exhibits / submitter split (K40): https://sitebraid.dev/blog/ercot-batch-zero-verification-rfi-financial-security-exhibits/
• Switchyard drawdown cost-to-complete (K41): https://sitebraid.dev/blog/texas-data-center-customer-built-switchyard-drawdown-controls/
• Batch Zero CapEx / class flip (K45): https://sitebraid.dev/blog/texas-data-center-batch-zero-reclassification-capex/