ERCOT batch zero / TAC May 19-20

Why it matters

Three updates. (1) Confirmation of yesterday's pending verification #1 and #2 — both ERCOT companion items have now cleared the subcommittee level on the same Urgent track, and the May 19-20 TAC vote is structurally locked rather than soft-scheduled. The submission-validator's PCLR / PCLR-companion-planning-guide modules need to be feature-complete against the 5/2-amended versions of *both* documents (not just NPRR1325's protocol language) by close-of-business May 18. The PGRR145 5/2 amendments are likely procedural-overlap with NPRR1325's amendments — same comment package, written by the same ERCOT staff — but the planning-guide language has separate definitions for 'Eligible Large Load,' 'Batch Zero Application Window,' and the milestone-fee escalation schedule that the protocol-side NPRR doesn't contain. The Layer-5 product needs to parse both. (2) The 'Urgent on both sides' posture is procedurally aggressive in a way that Cliff's customers should plan for. ERCOT's standard governance cycle for a paired NPRR+PGRR runs 4-6 months from filing to effective date; the Batch Zero pair is on track for ~4 months (March 4 filing → July 10 effective) which is the fast end of the cycle. The Urgent-on-both-sides pattern means stakeholder objection at TAC has a structurally higher bar — TAC by ERCOT bylaw is supposed to defer to PRS and ROS recommendations on Urgent items unless there's a reliability-implication objection that wasn't surfaced at subcommittee. The realistic risk profile for May 19-20: TAC approves both as recommended (highest probability), TAC remands one item back to subcommittee for additional comment (lower probability — would push effective date 1-2 months), or TAC rejects (very low probability given Urgent status on both sides). Cliff's customers underwriting Texas sites with Q3-Q4 2026 in-service dates can now plan against a real PCLR effective date of July 10, 2026 with reasonably high confidence. (3) The 5/2-amendment comment package is the new authoritative source for PCLR rules — pull the file overnight from ERCOT's issue-page comment archive and diff against the original 3/4 filing. Specific items to surface: (a) Provisional Curtailment Capacity (PCC) calculation method — original filing used historic-15-min-peak; 5/2 amendments may have moved this to projected-load-curve or a 12-month-rolling-90th-percentile method. (b) Curtailment-trigger-event definition — original filing tied PCLR curtailment to Energy Emergency Alert (EEA) Level 1; 5/2 amendments may have moved this to EEA Level 2 (later trigger, more usage allowed before curtailment), which is what most large-load customers want. (c) The milestone-fee schedule — original filing had application-stage / readiness-stage / commercial-operation-stage fee milestones; 5/2 amendments may have softened the readiness-stage thresholds. The submission-validator's PCLR economics calculator needs to be re-run against whichever of these three (or other) changes the 5/2 package contains, before May 18.