Large Load Interconnection Standards — new 16 TAC § 25.194

Senate Bill 6 directed the PUCT to establish interconnection standards for large loads connecting to the ERCOT grid. The resulting rule, new 16 TAC § 25.194, carries real financial machinery at a 75 MW threshold: study fees of $100,000–$300,000, financial security of $50,000 per MW of requested peak demand, site control requirements, and contribution toward direct interconnection costs.

What we filed

Across the request-for-comment, discussion-draft, and proposal-for-publication rounds, the coalition's comments pressed three points:

• The 75 MW threshold should measure additional demand, not total site demand. Without that clarification, the rule could reach "all expanded interconnections for load additions, no matter how modest, at an existing industrial facility that already exceeds 75 MWs of peak demand" — a 100 MW mill adding a 10 MW process line, treated like a new hyperscale campus. The comments proposed specific text inserting "additional" into the operative definitions, arguing that applying the standards to routine upgrades would be disproportionate and counterproductive, contrary to SB 6's target of loads that significantly impact transmission needs.
• ERCOT's "operational standards" authority should be narrowed. The draft rule's open-ended grant is overbroad; the statute (PURA § 37.0561(e)) confines ERCOT's interconnection conditions to backup generation curtailment and deployment.
• The rule should include a good-cause exception, so the Commission can address situations the drafters did not anticipate.

The advocacy has produced partial wins: the proposal for publication adopted a clearer three-prong applicability structure and limited financial security to the increased load, and in the related Project 58480 the Commission raised the large-load forecasting threshold from 25 MW to 75 MW consistent with the coalition's recommendations.

The stakeholder field split along predictable lines — transmission utilities emphasizing cost recovery and security against stranded investment, data-center and flexible-load interests pushing to trim fees and security requirements, and industrial groups aligned with the Steel Mills on incremental-threshold clarity and proportionality for existing sites. The comment record ran through a staff request for comments, a discussion draft, a Commission workshop, and the proposal for publication — with the coalition filing at every stage.

Why the definition matters beyond this rule

The Project 58000 transmission rule proposes a minimum billing demand of no less than 15 years that applies to "large load customers" as defined by § 25.194. However this rule defines the term decides which facilities carry that exposure — which is why definitional precision for existing plants making routine expansions is the central stake of the proceeding.

This summary is drawn from documents on the public record and is provided for general information. It is not legal advice, and it does not disclose any confidential client matter.