Six Grid Operators File Monday. The Seventh Doesn't Have To.

On June 18, the Federal Energy Regulatory Commission issued six show cause orders under Section 206 of the Federal Power Act. Each one tells a grid operator — and the dozens of transmission owners behind it — the same thing: your rules for connecting large loads may be unjust and unreasonable, and you have sixty days to defend them or replace them.

Those sixty days land on Monday, August 17.

Whether Monday actually arrives is now the story. Between July 28 and August 3, respondents in all six proceedings — covering PJM, MISO, SPP, CAISO, ISO New England, and NYISO — moved to hold their cases in abeyance, a formal pause, for 90 days (in SPP's docket, 95). Five of the six operators filed the motions themselves; in PJM's docket the request came from a transmission owner. Six dockets, six requests for more time.

As of this morning, FERC has not ruled. The filings are due today unless the Commission stops the clock.

ERCOT is not among the six.

FERC drew a line most coverage has skipped past. Its suggested definition of a large load — the baseline the six operators will be negotiating against — is a new facility above 50 MW, seeking transmission service above 69 kV. Operators may propose their own variants, but the suggested line is low enough to capture essentially every hyperscale campus in development, and specific enough that a developer can determine on day one whether federal process is likely to apply. FERC did not ask the six operators to study the problem. It made a preliminary finding that their existing tariffs may be inadequate, and put the burden on them to prove otherwise.

The abeyance motions are the most informative signal the dockets have produced so far. The mechanism converts a defensive posture into a proposal — an operator granted abeyance develops its own Section 205 filing and writes the rule rather than defending the one it has. An operator confident in its tariff answers on schedule. In every docket, someone asked for time instead.

The ERCOT market sits outside FERC's rate and tariff jurisdiction under the Federal Power Act, because ERCOT does not transmit power in interstate commerce — its grid does not synchronously interconnect across state lines, a separateness Texas has protected since the 1930s and Congress wrote into the statute's ERCOT-specific provisions in 1978. FERC still holds reliability jurisdiction over ERCOT, and specific statutory hooks can reach ERCOT entities. But the tariff process these six orders run on cannot touch the ERCOT interconnection queue.

Be precise about what that means, because the precision is the story: this is an ERCOT exemption, not a Texas one. FERC's orders reach Texas directly — Entergy Texas is a named respondent in the MISO docket, and Southwestern Public Service and SWEPCO in the SPP docket. Roughly a tenth of Texas load lives outside ERCOT and is fully inside the federal process. FERC is regulating large-load interconnection in Texas right now — just not in the market that holds the densest concentration of data center interconnection requests in the country.

Readers of Issue #003 know the shape of it: Senate Bill 6, signed June 20, 2025 and effective immediately, plus the August 3 directive to the PUCT and ERCOT to audit every data center in the interconnection queue — roughly 690 projects claiming more than 474 GW — and to deny connection to any that fail. Abbott's List, the five disclosures now required of every project, is the Texas answer to the same question FERC put to the other six: who is actually real, and how would we know.

The two answers are not the same, and the difference is where the money is.

Put a 500 MW campus in front of a developer today and it faces two entirely different regulatory products.

In a FERC region, the developer gets process. Whatever the six eventually file, the direction is toward a defined interconnection procedure for large loads — study timelines, cost allocation, queue position, rights that attach to a request. That process may be slow, and six abeyance motions say it will be slower. But it is legible, it is federal, and it will look broadly similar across the regions.

In ERCOT, the developer gets speed, and now a bill. No federal standard applies. What applies instead is Senate Bill 6, Batch Zero's 75 MW threshold, and a $50,000-per-MW security deposit — $25 million parked for that same 500 MW campus — most of it forfeited on withdrawal under the rules the PUCT has proposed. Plus Abbott's List, plus an audit with no announced end date.

Texas is not the deregulated option any more. It is the option that charges you up front to prove you are serious, then moves fast for whoever survives the test. FERC's regions are the option that makes you wait for a rule and then treats everyone in line the same way.

Those are different products from a capital perspective. A developer with committed offtake and a balance sheet will take the Texas trade every time — $25 million is a rounding error against a $7 billion campus, and the audit is survivable if the project is real. A developer with a term sheet and a queue position will prefer a federal process that does not ask for cash before it asks for evidence.

The sorting has already started. It is just not visible yet in any single filing.

Issue #003 flagged the category the Texas audit does not touch: projects that generate their own power behind the meter, without an ERCOT interconnection.

The FERC orders do not reach them either. Whatever threshold each operator lands on, the regime attaches to loads seeking transmission service. A campus that never touches transmission is outside both regimes at once — no federal show cause proceeding, no Texas security deposit, no Abbott's List.

That is not a loophole anyone designed. It is what happens when two jurisdictions define their authority by the same wire and a developer stops using the wire.

Chevron's Energy Forge One structure — a 20-year Microsoft offtake paired with four ERCOT queue entries totalling 2,707 MW in Reeves County — was a template when we wrote about it in Issue #002. After August 3 it was an exemption from Texas process. If the federal rules land where they are pointed, it will be an exemption from federal process as well.

We are not going to claim this was foreseen. It was not. But it is now the only structure in American power that answers to neither regulator's interconnection process, and capital notices that kind of thing faster than it notices anything else.

The abeyance ruling — before the filings themselves. Respondents in all six dockets asked FERC to stop the clock; two parties in the CAISO docket went further and moved to be cut out of the order entirely. Whether FERC holds the line or grants the delay is the first real signal of how hard it intends to push.

The filings, whenever they land — read them for who defends and who proposes. An operator filing a full Section 205 replacement has decided its existing tariff is indefensible, which tells you more than the tariff does.

August 20 — the PUCT open meeting, where ERCOT seeks its good cause exception on the Batch Zero classification deadline it missed. Carried over from Issue #003 and still the date that matters most to anyone holding a Texas queue position.

Behind-the-meter announcements, next sixty days. Issue #003 said an acceleration here would confirm the off-grid thesis. That test now has a second regulator behind it. If the announcements come, they are answering two exemptions, not one.

Abbott's List — as promised, it stays in every issue until the audit ends. Nothing failed on it this fortnight that we can source to a filing. When something does, we will name the line.

For a decade the argument for building in the ERCOT market was that nobody would ask you hard questions. That is over. Texas now asks the hardest financial question in American power — post the cash — and asks it before anyone studies your interconnection.

What ERCOT still does not have is a federal process defining what fair treatment of a large load looks like. The other six regions are being marched toward one — slowly, and now with a request to go slower. Whether the exemption becomes an advantage for Texas or a liability depends entirely on whether the audit ends with a rule or just ends.

We will be reading the filings either way — whichever Monday they arrive on.

Grid Alpha reads the filings so you don't have to. We track power projects across the Texas market and score each one on the questions both regulators are now asking — permits, financing, site control, offtake, ownership — before they make headlines. The live data is at gridalpha.com.

— Grid Alpha Intelligence