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Texas PUC Approves Nodal Operating Guide Revision That Industrial Customers Have Warned Indicates That ERCOT Can Regulate Any Load, Including Residential HVAC
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The Texas PUC approved, without specific discussion at its open meeting, ERCOT Nodal Operating Guide Revision Request 282 (NOGRR282), which establishes frequency and voltage ride-through requirements for Large Computational Loads (LCLs).
As previously reported, Texas Industrial Energy Consumers claimed that, in providing justification for ERCOT's authority to impose ride-through requirements on Large Computational Loads who are not market participants, "ERCOT Legal has claimed that it can regulate any load, including residential HVAC, if it creates a reliability concern[.]"
"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
See background here
The Data Center Coalition has likewise said that ERCOT lacks statutory authority to regulate retail customers, as NOGRR282 would do
ERCOT has said that NOGRR282, "is a valid exercise of ERCOT's statutory mandate to ensure the reliability of
the ERCOT System."
ERCOT has said that, "ERCOT's broad
reliability mandate establishes the legal basis for many provisions in its Protocols, Operating
Guides, Planning Guide, and Other Binding Documents that impact the operation and planning of
the ERCOT grid."
Addressing arguments that PURA does not specifically grant ERCOT with authority to regulate retail customers, ERCOT has said that, "a specific grant of authority to regulate customers is not necessary because ERCOT already has
broad authority to ensure system reliability under PURA Section 39.151(a)(2), and that authority
is not restricted to any specific categories of entities, assets, or risks."
While the PUC at its recent open meeting did not discuss its decision to approve NOGRR282, PUC Staff had filed a memo supporting NOGRR282, with PUC Staff stating that, "the Commission has complete authority
over ERCOT."
PUC Staff said, "the Commission's
consideration of NOGRR282 only implicates future ERCOT activity to the extent that the
Commission chooses to permit that activity. Most importantly, the issue at hand is whether
ERCOT has sufficient authority to implement NOGRR282 -- not the scope of ERCOT's
authority more generally. The fear, for example, that ERCOT may choose to regulate HVAC
units in the future would be better understood as the fear that ERCOT may request permission
from the Commission to regulate HVAC units in the future."
Staff said of opposition to NOGRR282, "Fundamentally, the commentors that claim ERCOT lacks sufficient authority for
NOGRR282 seem to be working under the assumption that explicitly statutory authority is
required. Staff respectfully submits that delegated authority is sufficient."
PUC Staff said, "Ridethrough requirements for large computational loads such as those embodied in NOGRR282
are part of ERCOT's responsibility to maintain the reliability of the regional electric network.
That responsibility naturally includes operating standards for how connected devices can
permissibly interact with it. The fact that these interactions may be controlled by retail
customers does not limit the Commission or ERCOT's authority with respect to the regional
electrical network."
PUC Staff said, "Staff contends that the appropriate starting point for evaluating ERCOT’s authority is PURA § 39.151(d), which directs the Commission to 'adopt and enforce rules relating to the reliability of the regional electrical network and accounting for the production and delivery of electricity among generators and all other market participants' or to delegate those responsibilities to ERCOT. The Commission has delegated these responsibilities under PURA § 39.151(d) to ERCOT as reflected in 16 Texas Administrative Code (TAC) § 25.361(b). Therefore, absent some exception, NOGRR282 is permissible to the extent it is within the scope of 'ensur[ing] the reliability and adequacy of the regional electrical network.' There does not appear to be any dispute that voltage and frequency ride-through requirements are within that scope."
TIEC and other NOGRR282 opponents have said 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, rather than ride-through requirements directly applied to end users
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July 13, 2026
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Reporting by Paul Ring • ring@energychoicematters.com
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