Public AdministrationStrategy & OperationsDigital Infrastructure
Texas Pauses Data Center Approvals as ERCOT Rule Names Northern Virginia
The duties did not lapse. What stopped is the check that happens before a facility is energized.
Texas answered a disclosure-compliance failure by pausing the process that administers behavior. The directive was triggered by data centers not answering a water-and-power survey, and all five of its questions ask about consumption and siting. The process it halted had just removed 47 projects for a different failure: not filing the document that describes how a facility behaves during a fault. The behavior duties themselves do not lapse and get stricter with delay. What lapses is the verification that happens before a facility is energized.
- The August 3 directive halts approvals until an audit is complete and states its own cause: the failure of some data centers to comply with the commission's survey measuring water and power usage under the General Appropriations Act. None of its five information categories asks about fault behavior, ride-through, dynamic models or disconnection.
- ERCOT's eligibility slide, data as of July 28, records 47 projects removed from Batch Zero because no dynamic model was submitted by July 10. There was no extension and no cure period at that gate, while projects whose models were merely deficient had until August 31 to fix them.
- Of the 373 projects that cleared the qualifying-study gate, the 47 are 12.6 percent by project count but only 8.9 percent by megawatt, because the failing cohort averages 426 MW against a 724 MW mean across all 688 screened projects. A gigawatt-denominated funnel cannot show this, which is the most likely reason published funnel analysis did not report it. Size does not explain who failed: the cohort that passed as base load averages 433 MW.
- The behavior rule took effect on August 1, two days before the letter. Section 2.14 requires a qualifying load to stay connected and return to 90 percent of pre-disturbance consumption within two seconds of voltage recovering above 0.9 per unit, and Section 2.14(6) bans schemes that transfer to backup on a count of voltage sags, annotated by ERCOT: intent is to mitigate risk as seen in northern Virginia events.
- The duties survive the pause and ratchet with it. The letter's enforcement sentence incorporates state law by reference, the post-event remedy in paragraph (7) runs 90 days to root cause, 90 to a plan and 180 from submitting it to implementation, with a disconnection power attached, and the stricter voltage tier attaches to loads qualifying after January 1, 2028, a date a pause cannot move.
A Survey Failure Halted the Process That Administers Behavior
Texas wrote its new grid rule with northern Virginia in mind. The prohibition on sag-counting schemes that took effect August 1 carries ERCOT's own note "Intent is to mitigate risk as seen in northern Virginia events". In July 2024 about 1,500 megawatts of data center load came off the Eastern Interconnection at once after a line fault, and NERC interviewed the owners. A faulted line does not produce a single voltage depression: the breaker opens and recloses to test whether it has cleared, and a scheme set for three attempts at each end produced six in 82 seconds. The facilities' controls were set to transfer the building to backup power on a count of three within a minute, and to stay there until a person reconnected them. Nothing on either side malfunctioned. On July 22, 2026, an Ashburn-area fault did it again, more than 3 gigawatts moving to backup within minutes. Two days after the rule took effect, Governor Greg Abbott paused the process that administers it, pending an audit prompted by a different failure: data centers not answering the state's water-and-power survey.
- The Directive and Its Stated Trigger. ERCOT is weighing roughly 474 GW of connection requests, about 90 percent of them data centers and more than five times the grid's record peak. The letter directs an audit of every data center in the queue and denies connection to any that fails the commission's, the operator's or state law's requirements. Its stated cause is not a grid event: "The failure of some data centers to comply with the PUC's survey measuring water and power usage under the General Appropriations Act makes this necessary". The five categories that follow are incentives, electricity consumption and on-site generation, water and cooling, community impacts and ownership.
- The Survey That Was Not Answered. The Texas Tribune and E&E News both report Texas Water Development Board officials telling a June state House committee that about 17 percent of data centers answered a mandatory water-use survey, against a statute that requires recipients to return it and makes non-response a Class C misdemeanor. The commission's own voluntary water-use study drew a response rate below 30 percent. The same month, the governor pledged to seek legislation requiring large data centers to report electricity and water usage to the commission annually. June proposed the reporting; August cited the reporting failure. The instrument is internally coherent on its own terms.
- What Stopped. ERCOT told the market the same day that, based on the directive in the governor's letter, it would not notify providers how any Large Load is classified in the ERCOT's one-time system-wide study that converts a queue of already-studied large loads into year-by-year megawatt allocations against shared transmission constraints. It replaced a serial process that ERCOT said it had outgrown, and it is the process the August directive paused. study by August 7, and that it would seek a good cause exception on the Batch Zero timelines before the commission's August 20 open meeting. Batch Zero is the one-time system-wide study that turns an interconnection request into a year-by-year megawatt allocation; five days earlier ERCOT had told a Texas Senate panel that roughly 205 GW was eligible. The Data Center Coalition said the review can "showcase the good actors" rather than delay them. What the notice stops is classification. It says nothing about review of the dynamic models already submitted, and nothing about the The obligation to stay connected and keep drawing power through a defined voltage or frequency excursion rather than tripping or transferring to backup. It is a behavior duty, not a consumption limit, and it is the opposite of what a facility's own protection is usually designed to do. duties.
- The Gate That Had Already Removed Projects. ERCOT's eligibility slide, with data as of July 28, carries this category: "Not Included In Batch Zero - No An executable representation of a facility that a transmission planner drops into a network case and runs. Its input is the voltage and frequency at the facility's terminals over time; its output is the current the facility draws, cycle by cycle. In practice it is the site's own protection and control settings handed to the grid operator in machine-readable form. (47): These loads had one or more studies that made them eligible for inclusion but were removed when no dynamic model was submitted to ERCOT by July 10". A dynamic model is the file that describes how a site behaves electrically.
- The Rule That Took Effect Two Days Earlier. NOGRR282 and NPRR1308 were approved by the commission on July 9 and took effect on August 1. Under Section 2.14(2) a qualifying load "shall remain connected to the Transmission Grid during voltage conditions requiring ride-through," and under 2.14(2)(b), for a sag below 0.9 Voltage expressed as a fraction of nominal. A sag to 0.8 per unit is a 20 percent drop; the Texas rule's continuous band is 0.90 to 1.10, and everything below 0.90 carries a minimum ride-through time. that recovers within two seconds, it "shall continue consuming active power from the grid during the low voltage condition," may reduce consumption proportional to the voltage drop, and "shall return to 90% of its pre-disturbance consumption level from the grid within two seconds" of voltage recovering above 0.9 per unit.
The Audit Asks About Everything Except Behavior
The paused process verifies a dynamic model. It is an executable file a planner drops into a network case and runs, and it returns the current a site will draw while the voltage at its terminals moves through a fault and back. It is the only artifact in Batch Zero whose subject is the facility's electrical behavior. Everything else collected is a quantity, a date, a location or a cost. That is why 47 otherwise-eligible projects were removed solely because no model arrived by July 10.
The gate had a sharp edge. A project that submitted no model had no extension and no cure period. A project that submitted a deficient one had until August 31 to fix it. Failing to describe behavior could not be cured; describing it badly could. The audit's five categories are a different kind of question. Projected consumption and on-site generation plans have a representation in a study case, and both were already collected. Abatements, water sourcing, cooling technology, noise, setbacks and ownership do not appear in a power-flow or stability case at all. None of the fourteen items across the governor's two letters is about conduct in the two seconds after a fault.
None of which means the duties stop. NOGRR282 and NPRR1308 took effect on August 1, 2026 and bind independently of Batch Zero, and the letter's own enforcement sentence pulls them in by reference to state law. The judgment here is that what changes is where the assurance sits. It used to sit in front of the meter, as a submitted model reviewed by the operator before energization. If the pause reaches that review, the operative machinery is the one that starts after something happens: 90 days to determine root cause, 90 more to produce a plan, 180 to implement it, with ERCOT able to require disconnection in the meantime. Post-event verification is not weaker in what it demands. It is later.
Two correct protection schemes that are incompatible by design
Digital Infrastructure. The 2024 collision is fully documented and nothing in it failed. Auto-reclosing produced six faults in 82 seconds, and NERC's verdict on the transmission side is that the protection system "detected these faults and cleared them properly". On the customer side, NERC found a scheme that counts voltage disturbances and transfers on a count within a window, typically three within one minute. Six against a threshold of three is the whole problem: transmission protection operating exactly as designed produces the condition the facility protection is set to act on. About 1,260 MW dropped off at the third voltage depression "and did not return for hours." Two protection philosophies, each right for its own objective, cannot both be satisfied where they meet.
Manufacturing & Materials. The manufacturers describe the same behavior from inside. Vertiv's director of engineering told ERCOT's large-load working group that data centers "are very cautious to return to utility; they may run on generator for several minutes to hours," so the utility "sees a large load loss which can cause grid stability issues". Eaton, to the same group, set out rectifier and power-sharing settings restoring pre-fault demand and called them "relatively easy to implement to existing UPS technology," while flagging that a "centralized BESS may have significant cost impact on MV" distribution. What the grid wants sits mostly in control behavior, and is not free everywhere.
Relay and UPS data from the July 22, 2026 Ashburn event shows a facility scheme operating outside its own design intent. The collision would be misconfiguration, not two correct designs.
On the protection side: the rule bars transferring on a sag count, so what obliges a site that has already gone to generator to come back, and on whose clock?
The removal rate is visible by project and invisible by megawatt
Digital Infrastructure. The slide prints project counts in the legend and gigawatts on the bars, so both denominators are available. Of the 373 projects that cleared the study gate, 47 were removed for the missing behavior file: 12.6 percent by project, but only 8.9 percent by megawatt, 20 GW of 224. The failing cohort averages 426 MW against a 724 MW mean across all 688 screened projects. A gigawatt-denominated funnel cannot show that, which is the most likely reason published funnel analysis did not. Nor does size explain it: the cohort that passed as base load averages 433 MW, essentially identical.
Markets & Finance. The pause lands on a population pre-selected for having already spent. Batch Zero's evidence review requires entities to produce "purchase orders for long-lead equipment, real estate agreements and land use approvals, agreements with end-users, and construction agreements," and disqualifies those that cannot. Financial security runs to $50,000 per megawatt. Every contract in that stack carries a date; the audit carries none, so two practitioners quoted in E&E expect a hold of undefined length to sort projects by the maturity of their capital rather than by anything the paused process measured.
Batch Zero resumes with the eligible megawatt total still near 205 GW and no material withdrawal during the hold. An undated pause would not be sorting projects by the maturity of their capital.
On the capital side: every contract in the Batch Zero evidence stack carries a date and the audit carries none, so which projects can hold those commitments open?
Today the only enforceable behavior obligation is the state one
Regulatory Policy. Federal reliability jurisdiction under Section 215 of the Federal Power Act reaches all users, owners and operators of the bulk-power system, ERCOT included, which is what puts this on a Washington clock. It arrives through two gates that are both currently shut. FERC ordered NERC on July 16 to file computational-load reliability standards by December 31, and, separately, registry criteria "necessary for registration of computational load entities" by the same date. Until both land, no federal standard runs to a data center in Texas.
Public Administration. The letter names one statute, the General Appropriations Act, and names it as the source of the data centers' survey obligation. Its enforcement sentence routes through other instruments: any project failing to comply "with the requirements set forth by the PUC and ERCOT, and by state law, must be denied connection to the Texas grid." That construction keeps the behavior duties alive through the pause, and fixes the directive's reach at grid membership rather than state borders: the Panhandle and far west of the state sit on other grids entirely.
A compliance or enforcement action reaches a Texas data center's fault behavior under an existing Reliability Standard before NERC's December 31 filing. The federal gate would already be open.
On the jurisdiction side: the directive reaches grid membership rather than state borders, so what governs a Texas project sitting on the Panhandle or Western grid?
The Weave maps a single development across domains and across time. Each row follows one domain from where things stand now through the next eighteen months, and expands for the reasoning behind that trajectory.
- An order aimed at an operator reaches only that operator's queue, so the grid is the border.
- Parts of the state sit on other interconnections with their own processes, outside that reach.
- The survey track carries no such boundary, so the two tracks stop at different lines.
- A ride-through failure lands on uptime, which is the one thing the facility actually sells.
- The remedy runs close to a year, so the exposure is a standing liability, not a one-time cost.
- It attaches only after energization, which is why a check before service carries the weight.
- The interconnecting customer funds the duty entirely, and the spend earns nothing either way.
- Nothing here is socialized through a rate base, so permission itself lands as a capital line.
- Crossing the meter does not shed the obligation; it adds a harder one on top of the first.
- No simulator can derive a setting somebody chose, so it enters a study only once declared.
- A transfer threshold is a choice made in a control system, not a property of the physics.
- An operator can only plan around behavior that someone has written down somewhere first.
The Pause Moves the Schedule, Not the December or 2028 Clocks
Four dates sit inside the forward window and the first has already been overtaken. Everything here appears in a published record or does not, and each can be checked without anyone's permission.
- The August 20 Open Meeting. ERCOT told the Senate it would issue Batch Zero classifications on or before August 7 and begin the study no later than September 2. Its August 3 notice says it will seek a good cause exception on the Batch Zero timelines, in advance of the commission's August 20 open meeting. That filing, and whether the commission grants it, is the next checkable thing. No revised dates are published.
- Whether Model Review Continues. An ERCOT notice saying model review proceeds through the pause would narrow this story considerably; one saying it does not would widen it. The August 3 notice said neither. It is the single fact that most changes how much verification stopped.
- The December Filing. This is the date that takes the question out of Texas. FERC has directed NERC to file computational-load reliability standards, and the registry criteria that would make them bind, by December 31 on a clock no state pause tolls. Watch whether the entity category captures the facility or the company behind it: that choice decides whether a data center is a customer with a tariff duty or a registered entity inside a penalty regime. It would land hardest where the load is densest, in Loudoun County and the PJM footprint rather than ERCOT.
- The 2028 Boundary. The stricter voltage tier attaches to loads qualifying after January 1, 2028, and drops the "if capable" allowance that the interim cohort enjoys. Nothing about a pause changes that date. If the audit runs long, some projects that would have qualified under the interim tier will qualify under the later one instead, which means schedule risk quietly converts into specification risk on a fixed calendar.
- The Tell. If the eventual questionnaire acquires a behavior question, whether ride-through capability, protection settings or transfer thresholds, the two tracks have been reconciled. If it ships as the letter describes it, behavior stays in an operating guide administered at a gate, and the durable question is what happens to verification the next time that gate closes for an unrelated reason.
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Primary sources30
- Office of the Texas GovernorLetter directing the Public Utility Commission of Texas and ERCOT to conduct a comprehensive verification and audit of data centers in the interconnection processAug 3Primary · Today the only enforceable behavior obligation is the state one · What does the paused ERCOT process verify that the audit does not? · Where Things Stand · The Weave
- ERCOT (System Protection Working Group)Large Electronic Load Ride-Through Requirements (NOGRR282 and NPRR1308)Feb 24Primary · What does the paused ERCOT process verify that the audit does not? · Looking Forward · Where Things Stand · The Weave
- North American Electric Reliability CorporationIncident Review: Considering Simultaneous Voltage-Sensitive Load ReductionsJan 8Primary · Two correct protection schemes that are incompatible by design · Where Things Stand · The Weave
- ERCOT (Texas Senate testimony)ERCOT Update: Senate Committee on Business and Commerce, Panel 1, Assessing the GridJul 29Primary · The removal rate is visible by project and invisible by megawatt · What does the paused ERCOT process verify that the audit does not? · Looking Forward · Where Things Stand · The Weave
- Eaton (to ERCOT Large Load Working Group)Data Centers - A Good Grid Citizen (Keith Watson, Regional Application Engineer, Mission Critical Solutions)Jul 11Primary · Two correct protection schemes that are incompatible by design · The Weave
- Vertiv (to ERCOT Large Load Working Group)UPS Voltage Disturbance Ride Through (Brian Heber, Director of Engineering)Jul 11Primary · Two correct protection schemes that are incompatible by design · The Weave
- NERC (compliance bulletin)Standards, Compliance and Enforcement Bulletin, July 13-19, 2026Jul 13Primary · The Weave
- Public Utility Commission of Texas (Project 58481)Proposal for Publication of new 16 TAC 25.194, Large Load Interconnection Standards (Project No. 58481)Mar 12Primary ·
- ERCOT (rule tracker NOGRR282)NOGRR282: Board Priority - Large Computational Load Ride-Through RequirementsJul 9Primary · Where Things Stand
- ERCOT (rule tracker NPRR1308)NPRR1308: Board Priority - Related to NOGRR282, Large Computational Load Ride-Through RequirementsJul 9Primary · Where Things Stand
- ERCOT (rule tracker PGRR145)PGRR145: Batch Zero Process for Large Load InterconnectionJul 11Primary ·
- 16 U.S.C. 824o (Federal Power Act Section 215)16 U.S. Code 824o - Electric reliabilityAug 8Primary · Today the only enforceable behavior obligation is the state one · What does the paused ERCOT process verify that the audit does not? · The Weave
- 16 U.S.C. 824k (Federal Power Act Section 212 / ERCOT carve-out)16 U.S. Code 824k - Orders requiring interconnection or wheelingOct 24Primary · What does the paused ERCOT process verify that the audit does not?
- Office of the Texas Governor (June 10 letter)Letter to the Public Utility Commission of Texas and ERCOT directing action on data center interconnection costsJun 10Primary · What does the paused ERCOT process verify that the audit does not? · Where Things Stand
- Texas Legislature OnlineSB 6, 89th Legislature Regular Session, bill historyJun 20Primary ·
- Texas Water Code Section 16.012Texas Water Code Section 16.012, Water use surveyJan 1Primary · Where Things Stand · The Weave
- ERCOT (market notice)Market Notice M-B062326-01: Implementation of the Batch Zero Process (PGRR145/NPRR1325)Jun 23Primary ·
- ERCOT (news release)PUCT Approves ERCOT's Batch Zero Large Load Interconnection ProcessJun 18Primary ·
- Meta Platforms (investor relations)Meta Reports Second Quarter 2026 ResultsJul 29Primary · What does the paused ERCOT process verify that the audit does not? · The Weave
- Texas Utilities Code Section 12.052Texas Utilities Code Section 12.052, Presiding OfficerJan 1Primary · The Weave
- Texas Utilities Code Section 39.151Texas Utilities Code Section 39.151, Essential OrganizationsJan 1Primary ·
- Texas Utilities Code Section 39.1513Texas Utilities Code Section 39.1513, Governing Body of Independent OrganizationJan 1Primary · The Weave
- Texas Constitution Article XV Section 9Texas Constitution, Article XV, Section 9, Removal of Appointed OfficersNov 4Primary · The Weave
- ERCOT (about the grid)About ERCOT: the ERCOT region and compliance oversightJan 1Primary · Today the only enforceable behavior obligation is the state one · The Weave
- ERCOT (peak demand records)All-Time Peak Demand RecordsJul 22Primary ·
- International Electrotechnical CommissionIEC 62040-3:2021, Uninterruptible power systems (UPS) - Part 3: Method of specifying performance and test requirementsJan 1Primary · The Weave
- Public Utility Commission of Texas (Docket No. 59220)Order, Docket No. 59220: Application of Crusoe Energy Systems LLC, FGE Goodnight I, LLC, and Ensign Infrastructure LLC for Approval of a Net Metering ArrangementJul 24Primary · What does the paused ERCOT process verify that the audit does not? · The Weave
- Federal Energy Regulatory CommissionOrder Directing the North American Electric Reliability Corporation to File Reliability Standard(s) Pertaining to Computational Load Integration, Docket No. RD26-7-000, 196 FERC 61,031Jul 16Primary · Today the only enforceable behavior obligation is the state one · What does the paused ERCOT process verify that the audit does not? · Looking Forward · The Weave
- US Energy Information AdministrationToday in Energy: Hourly peak load in ERCOT set a new record, exceeding 91 GW on July 22Aug 3Primary ·
- ERCOT (market notice M-A080326-01)Market Notice M-A080326-01: Update Regarding Batch Zero Timelines and ProcessesAug 3Primary · What does the paused ERCOT process verify that the audit does not? · Looking Forward · Where Things Stand · The Weave
Secondary sources, by sector12
- RTO InsiderLine Fault Causes 3 GW in Data Center Load to Drop in VirginiaJul 23Secondary · What does the paused ERCOT process verify that the audit does not?
- RTO Insider (FERC order)FERC Directs Large Loads Standards by End of 2026Jul 16Secondary · What does the paused ERCOT process verify that the audit does not?
- Utility DiveTexas approves AI data center co-location next to wind farm with curtailment conditionsJul 30Secondary · What does the paused ERCOT process verify that the audit does not?
- Facilities DiveTexas approves AI data center co-location next to wind farm with curtailment conditionsJul 31Secondary · What does the paused ERCOT process verify that the audit does not?
- Utility Dive (queue growth)ERCOT's large load queue jumped almost 300% last year: officialJan 6Secondary · What does the paused ERCOT process verify that the audit does not? · The Weave
- DataCenterKnowledgeFault in Data Center Alley Triggered 3 GW Load DropJul 23Secondary · What does the paused ERCOT process verify that the audit does not? · Where Things Stand
- E&E News by POLITICOTexas data center approval halt scrambles grid plansAug 4Secondary · Where Things Stand · The Weave
- The Texas TribuneData center approvals in Texas halted until audits completed, Gov. Greg Abbott saysAug 3Secondary · Where Things Stand
- The Texas Tribune (water survey)Most data centers are not telling Texas how much water they useJun 23Secondary · Where Things Stand · The Weave
- Texas Public RadioMost data centers won't share data about water use with Texas lawmakersJun 26Secondary · Where Things Stand
- Amarillo TribuneAbbott halts data center approvals pending audits, but Panhandle data centers will not be affectedAug 4Secondary · Today the only enforceable behavior obligation is the state one · The Weave
- Virginia MercuryData centers want to build their own gas turbines. Would that skirt state renewable energy laws?Jul 20Secondary · What does the paused ERCOT process verify that the audit does not?