Aug 12, 2026 · Research · 8 min

Reading the ERCOT large load queue

Update. October 10, 2026. The Commission adopted §25.194 on September 18 (Project 58481, Item 218). The Texas Register lists it effective October 8 (51 TexReg 6875). The August 27 note below describes the proposal. Pallara’s read of the adopted rule: Unverifiable now costs the same as false.

The June 19, 2026 LLWG deck, with data as of June 18, reports 466,497 MW of large-load requests. Its projection table reports 5.7 GW in the Observed Energized tier. That tier is based on all-time non-simultaneous peak consumption. The ratio is about 1.2%, or roughly one to 82. It compares different measures; it is not a project completion rate or an estimate of capacity under construction.

Queue-source status: this article analyzes the June 18, 2026 snapshot. It does not present that historical total as the current queue. The August process notes below are preserved as dated history; the October rule update supersedes their proposal-status statements.

It is not a construction schedule. It is a request ledger. A request is not an approval. An approval is not an operating load. The rest of this article is what happens when those three layers get collapsed into one headline.

The sentence vs the source

Most of the damage is done in one sentence. “Texas has 466 gigawatts of data centers in the queue.” Four errors live in that line. The megawatts are requests, not plants. The data-center share is not a printed total in the June queue table. The queue is not a schedule. And 466 GW is a rounded restatement of 466,497 MW from one dated deck.

Governor Abbott’s August 3 letter used “approximately 90 percent” against an approximate 474 GW request figure. That is a Governor’s-letter figure. It is not ERCOT’s published queue total. Mixing the two is how 466,497 MW becomes “474 GW of data centers” in a briefing memo.

Three numbers that have to add

The deck prints 8,926 MW approved to energize in slide 6’s chart and 8,927 MW in slide 8’s text. Retain that one-megawatt source discrepancy rather than infer its cause. Slide 4’s rounded tiers are 5.7 GW observed energized and 3.2 GW approved but not operational, totaling 8.9 GW. Those rounded tiers do not cross-foot to either exact MW total. This article uses 8,926 MW when referring to the chart.

graph TB
  Q["Requested
466,497 MW"] --> N["No studies submitted
257,600 MW"]
  Q --> A["Approved to energize
8,926 MW"]
  A --> E["Observed energized
5,700 MW"]
  A --> W["Approved, not yet on
3,200 MW"]

  style Q fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style E fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style N fill:none,stroke:#0a0a0a
  style A fill:none,stroke:#0a0a0a
  style W fill:none,stroke:#0a0a0a
          

A separate panel prints 3,900 MW as the June 2026 non-simultaneous monthly peak of loads already approved to energize. That is not the 5,700 MW Observed Energized tier. Swap them and the conversion rate moves, the story changes, and the source has been misread. ERCOT’s July 17 Monthly Operational Overview later prints 3,966 MW for that same June peak measurement. 3,900 is the LLWG round. 3,966 is the later operational print. Neither is 5,700.

Reconciling the May and June snapshots

The May 21 deck printed 438,595 MW for its May 20 snapshot. The June deck’s historical chart instead shows May at 471,415 MW and June at 466,497 MW. The June presentation describes a pre-Batch-Zero ticket cleanup, including cancellations, duplicates and combined multistage tickets. A difference between unreconciled snapshots is not evidence that the same amount of physical capacity was built.

Batch Zero locked a process. The queue did not move.

On June 18, 2026, the Public Utility Commission of Texas approved ERCOT’s Batch Zero package, PGRR145 and NPRR1325. The PGRR145 issue page reads “Approved on 06/18/2026.” That locked the process. It did not energize 466 GW. It put filing dates on a calendar. Filing dates are not commercial operation dates.

The PUCT’s August 20 order granted all three requested good-cause exceptions. In M-A080326-02, ERCOT says it intends to notify each interconnecting DSP or TSP of its Large Load’s conditional classification by August 31. Receipt starts the Planning Guide §9.3.1(2)(a)(i)-(iii) dispute and reconciliation process.

The $100,000 per MW mistake

Historical status as of August 27, 2026: §25.194 was then a proposal. Staff’s Item 206, filed August 24, contained recommended changes, not adopted text. That description is preserved to explain the earlier analysis. It was superseded by the September 18 adoption order and October 2 Texas Register publication, listing an October 8 effective date.

The March proposal’s two $50,000/MW figures were already one capital event, not $100,000/MW. Item 206 then struck the non-refundable interconnection fee. Do not write $50,000/MW as the interconnection fee. That fee is not in the current staff draft.

What remains in Item 206 is proposed security. At the intermediate agreement, $50,000 per MW of requested peak demand. At the SLLIA, the greater of $50,000 per MW of contracted peak demand or the costs allocated to the customer for system upgrades. Both are proposed. Neither is a fee.

graph TB
  M["March proposal:
security plus fee"] --> I["Item 206 staff draft:
fee struck"]
  I --> A["Proposed intermediate security
$50k/MW of requested peak"]
  I --> S["Proposed SLLIA security
greater of $50k/MW or
allocated upgrades"]
  X["Struck fee"] -.->|"do not write as $50k/MW fee"| I

  style I fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style A fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style S fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style M fill:none,stroke:#0a0a0a
  style X fill:none,stroke:#0a0a0a
          

Planning Guide study fees are a separate instrument from proposed §25.194 security. Mixing them into an “all-in per MW” number is the same error as treating proposed security as a fee. If a model cannot show the instrument, the evaluation date, and the cited section, it cannot compute the cash event.

A marketing page is not Demand

Campus websites advertise power. That is a public fact about advertised capacity. It is not expected aggregate peak Demand at a single site, not computational share, and not a ride-through finding under NOGRR282 / NPRR1308. Defaulting the brochure into the obligation is how a public brief becomes a false compliance conclusion.

graph TB
  Q["Queue request"] --> S["Study"]
  S --> C["Classification"]
  C --> A["Approval to energize"]
  A --> E["Observed energized"]

  P["Advertised campus MW"] -.->|"does not substitute"| D["Expected aggregate peak Demand"]

  style Q fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style E fill:#e8e8e8,color:#0a0a0a,stroke:#0a0a0a
  style P fill:none,stroke:#0a0a0a
  style D fill:none,stroke:#0a0a0a
          

A serious screen keeps three values. Known. Unknown. Cannot determine. An obligation that needs an unknown input cannot be marked as applying. It stays undetermined until the project owner confirms the missing record.

What survives the next hard question

The useful artifact is not another 466 GW dashboard. It is a project record that states what applies, what is known, what is missing, who owns the next action, and which source was current when the statement was made. Every rule claim needs a primary-source URL and a verified or unverified flag. Proposed text stays proposed. Unknowns stay unknown.

ERCOT’s Large Load Integration page and dated market notices remain the process sources. Pallara’s tracker at lli-radar.pallara.xyz mirrors those files. It does not replace them. A named-project screen from public facts lives at pallara.xyz/ercot.

This is decision support, not legal advice. It does not replace counsel, project engineers, or authorized representatives. Re-verify every deadline, fee, and megawatt figure against the cited source before relying on it.

Factual review: October 26, 2026. Original publication date retained. Primary sources are linked alongside the revised claims. Queue figures remain a historical June snapshot.