Behind 265.5 MW of wind, Texas approved a ~525.5 MW campus. Curtailment is not capped by paired gen.

If you are underwriting a Texas BTM campus against an existing wind or gas unit, stop treating paired generation as the ceiling on how much load can be dropped.

That is the mistake Docket 59220 closes.

On July 24, 2026, the Public Utility Commission of Texas approved adding Crusoe Two (~260 MW) behind GOODNIT1, a 265.5 MW wind facility. Crusoe One (~265 MW) was already approved in Docket 58881. The result is a ~525.5 MW campus sitting behind ~265.5 MW of paired generation.

The order does not cap curtailment at the paired generator. Condition 1 requires full curtailment of Crusoe Two within 30 minutes of an ERCOT instruction to Goodnight’s QSE for an actual or anticipated transmission emergency or Energy Emergency Alert. That is the campus decision. Price the off-switch, or do not model the arrangement as firm load.

What §25.205 already said

Project 58479 adopted 16 TAC §25.205 for net metering of a large load customer co-located with an existing generation resource or energy storage resource in the ERCOT region.

The rule applies where the large load’s total expected non-coincident peak demand at a single site is 75 MW or greater, and the existing generation or energy storage resource was registered with ERCOT as stand-alone as of September 1, 2025.

ERCOT studies system impacts within 120 days of receiving the necessary information. The Commission then has 60 days to approve, condition, or deny the arrangement.

The preamble is plain. The full capacity of the existing generation resource is made available first and foremost through full curtailment of the co-located large load. No compensation is provided to the large load customer for that curtailment.

That is the rule spine. Docket 59220 shows how the Commission applies it when campus load exceeds paired generation.

What Docket 59220 actually ordered

The July 24, 2026 Order approves the Crusoe Two net metering arrangement subject to conditions. The material campus terms are not subtle.

Condition 1: after energization of Crusoe Two, within 30 minutes of ERCOT’s instruction to Goodnight’s QSE that curtailment or availability of GOODNIT1 is necessary to avoid or mitigate an actual or anticipated transmission emergency or EEA, Ensign fully curtails Crusoe Two, and Goodnight makes GOODNIT1 available unless the unit is on outage. Breaker disconnect is required if needed to ensure compliance.

When practicable, ERCOT must give at least 60 minutes of advance notice. The operator may elect a 10-minute capability in writing to ERCOT.

Condition 3: Crusoe Two may not participate in any ERCOT or TDSP demand response product, Ancillary Service, ERCOT Emergency Response Service, ERCOT-procured capacity contract, or TDSP load-management program.

The conditions bind successors. Compliance filings run in Docket 59970. The parties must return for a Commission revisit between 36 and 60 months after the Order.

Applicants argued that requiring Crusoe Two to curtail on top of Crusoe One would drop ~525.5 MW of load behind a 265.5 MW generator. The Commission still imposed full curtailment of Crusoe Two. The paired BTM does not cap how much load gets dropped.

Rehearing is closed for administrative purposes

On August 31, 2026, Commission Advising issued the Ballot Memo in Docket 59220 Item 74. The Commission voted not to add Ensign’s motion for rehearing to any open meeting agenda. The Order stands.

Do not treat rehearing as still open. Administrative rehearing closure is not a ruling on any further court path. A district-court path, if any, is outside what these filings resolve.

The developer dilemma

A co-located campus looks clean on a term sheet when load and existing gen share a point of interconnection and net for settlement. The underwriting temptation is to treat paired megawatts as the reliability and curtailment envelope.

Docket 59220 rejects that envelope.

If you are stacking phases behind one existing unit, each approved large load can carry its own full-curtailment condition. The second phase is not protected because the first phase already “covers” the generator. The Commission’s logic in 59220 is that GOODNIT1’s capacity must still be made available to the grid in emergency conditions, and that objective fails if Crusoe Two stays on while only Crusoe One drops.

For gas or wind co-location economics, that means:

• Model unconditional full-load drop on ERCOT emergency instruction, not a MW-matched offset to the paired unit.
• Do not underwrite Ancillary Service, ERS, or TDSP load-management revenue for the curtailed BTM load when Condition 3 style restrictions apply.
• Carry successor liability and a 36-to-60-month revisit into transfer and refinance documents.
• Treat “when practicable, 60 minutes notice” as operational courtesy, not a contractual floor. The binding clock in Condition 1 is 30 minutes, with a voluntary 10-minute election.

This sits next to the broader Texas large-load calendar. Do not collapse it into TCEQ permitting or Batch Zero energization. Those are adjacent workstreams. The BTM net-metering off-switch is its own instrument.

What changes in the model

Before the next LOI amendment, PSA hard date, or construction draw that assumes firm BTM load, rewrite three lines in the campus model.

First, curtailment volume. Use campus load subject to the order, not paired gen MW. For a 59220-style fact pattern, that is the co-located large load named in Condition 1, against a campus that can already exceed the generator.

Second, compensation. §25.205’s preamble states no compensation to the large load for the curtailment that makes existing gen available. Do not plug in a demand-response credit to “offset” Condition 1 risk unless a separate, authorized product actually applies. Condition 3 in 59220 blocks the usual ERCOT and TDSP participation paths for Crusoe Two.

Third, notice and control. Price 30-minute full curtailment and breaker-level disconnect capability as an operating design requirement, not a best-efforts aspiration. If the campus cannot drop on that clock, the arrangement is not ready for the condition set the Commission is using.

Campus Readiness Diagnostic

Run this on one page before the next irreversible spend on a Texas BTM co-location.

1. Paired resource status. Was the generator or ESR registered stand-alone with ERCOT as of September 1, 2025? If not, §25.205’s existing-resource path may not be the right frame. 2. Campus MW vs paired MW. List every approved or planned large-load phase behind the same POI. Sum campus load. Compare to paired gen. If campus exceeds paired gen, assume curtailment is not capped by the generator. 3. Condition 1 clock. Can the operator fully curtail the named load within 30 minutes of ERCOT instruction to the QSE, including breaker disconnect if required? Document the answer with a named owner. 4. Revenue exclusions. Confirm whether the draft order or comparable conditions bar Ancillary Service, ERS, ERCOT capacity contracts, and TDSP load management for that load. 5. Successor and revisit. Are transfer acknowledgments and the 36-to-60-month revisit mapped into the PSA, financing covenants, and compliance calendar (here, Docket 59970)? 6. Compensation assumption. Has anyone left a curtailment payment or DR credit in the model that §25.205’s preamble and Condition 3 would wipe out?

If any of those six are “unknown,” the campus is not ready to treat BTM co-location as firm load.

The practical move is not to abandon co-location. It is to underwrite the off-switch at full campus scale, on the Commission’s clock, with no paired-gen ceiling and no assumed curtailment check.

That is the position Docket 59220 leaves on the table.

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Verified against: 16 TAC §25.205 (Project 58479 adoption order), https://ftp.puc.texas.gov/public/puct-info/agency/rulesnlaws/subrules/electric/25.205/58479adt.pdf; PUCT Docket 59220 Order (Jul 24, 2026), https://interchange.puc.texas.gov/Documents/59220_69_1668205.PDF; Docket 59220 Item 74 Ballot Memo (Aug 31, 2026), https://interchange.puc.texas.gov/Documents/59220_74_1678681.PDF. Not legal advice. Not a substitute for counsel, interconnection engineering, or counterparty review.