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Texas Industrials Claim That ERCOT Legal Has Said That ERCOT Can Regulate Any Load, Including Residential HVAC, If Load Creates A Reliability Concern (Impose Operational Requirements On Load)
Texas PUC Staff Seek Comments On ERCOT Authority To Impose Operational Standards On "Pure Retail Customers"
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The Staff of the Texas PUC, in connection with the PUC's consideration of Nodal Operating Guide Revision Request 282 (NOGRR282), have asked for stakeholder comment on the question of whether ERCOT has the authority to impose operational standards on, "pure retail customers."
NOGRR282 would establish frequency and voltage ride-through requirements for Large Computational Loads (LCLs).
The ERCOT Board approved NOGRR282 on June 2
In comments during the stakeholder process, Texas Industrial Energy Consumers claimed that, "ERCOT Legal has claimed that it can regulate any load, including residential HVAC, if it creates a reliability concern[.]"
TIEC cited a comment represented as from ERCOT Legal during a stakeholder meeting, in which the ERCOT representative is said to have stated, "We're addressing this risk because these Large Loads have a potential to cause cascading outages on the grid, and that is essential for us to address. It’s not essential for us to address HVAC units at this point," with TIEC emphasizing the "at this point" language.
"TIEC is concerned about the precedent of imposing operational requirements on pure retail customers through the ERCOT Protocols. ERCOT Legal has claimed that it can regulate any load, including residential HVAC, if it creates a reliability concern, and ERCOT has already indicated it plans to submit subsequent revision requests that will have a broader impact on other pure retail customers. The language in NOGRR282 sets a concerning precedent that risks ERCOT extending its regulatory reach beyond statutory limits, effectively opening the door to lawsuits and overregulation of retail-only customers," TIEC has said in comments during the stakeholder process
TIEC has said in comments during the stakeholder process that ERCOT lacks the statutory authority to impose operational standards on retail customers
TIEC has said in comments during the stakeholder process that ERCOT's reliability concerns should be addressed, as done with prior concerns, through requirements on new interconnecting loads that are enforced through the interconnecting TDSP, and by imposing standards on TDSPs that can be reflected in their tariffs.
"It is completely inappropriate to give ERCOT the ability to directly regulate businesses who are not participating in the wholesale market and are not otherwise regulated entities," TIEC has said in comments during the stakeholder process
PUCT Staff's request for comments was filed in PUC Project 54445
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June 3, 2026
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Reporting by Paul Ring • ring@energychoicematters.com
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