Every federal development described in the first three alerts of this series – the PJM Interconnection (PJM) co-location orders, the Southwest Power Pool (SPP) High Impact Large Load (HILL) framework, the DOE Rulemaking Proposal’s proposed assertion of jurisdiction over large-load interconnections, and the new transmission service requirements and gross demand billing mandates – reinforces the same observation: the structural advantages of the Electric Reliability Council of Texas (ERCOT) for data center behind-the-meter generation and co-located load arrangements (collectively, BTM) have widened with each new federal regulatory action.
Texas is not a regulatory vacuum. Senate Bill 6, the ERCOT batch study transition, weatherization mandates, and multiple active rulemakings before the Public Utility Commission of Texas (PUCT) add genuine compliance complexity. But the starting position, complete avoidance of Federal Energy Regulatory Commission (FERC) jurisdiction over wholesale