NOTICE DATE: September 19, 2025

NOTICE TYPE: M-B090225-02 Legal

SHORT DESCRIPTION: Addition of Energy Storage Resources to List of Stand-Alone Generation Resources Subject to PURA Section 39.169 Net Metering Review

INTENDED AUDIENCE: ERCOT Market Participants and Customers Seeking Interconnection of Loads 75 MW or Greater in Size

DAY AFFECTED:  September 1, 2025

LONG DESCRIPTION:  In Market Notice M-B090225-01, issued on September 2, 2025, ERCOT identified each existing "stand-alone generation resource" that would be subject to the review process required by Public Utility Regulatory Act (PURA) Section 39.169 in the event of a proposed net metering arrangement involving the generation resource and a new large load customer.  As noted in that Market Notice, ERCOT did not include Energy Storage Resources (ESRs) in this list but deferred to the Public Utility Commission of Texas (PUCT) as to whether ESRs should be considered stand-alone generation resources for the purposes of PURA Section 39.169. 

At the PUCT's September 11, 2025 open meeting, PUCT Staff expressed support for including ESRs within the scope of the statutory review process, and ERCOT agreed that this was a reasonable interpretation of PURA Section 39.169.  Accordingly, ERCOT has modified the list of stand-alone generation resources to include ESRs.  Consistent with the criteria ERCOT used for including Generation Resources on the list, ERCOT's list now includes each ESR that was (1) included in ERCOT's Network Operations Model as of September 1, 2025 and (2) was part of a modeled generation facility that did not include a modeled Private Use Network (PUN) load as of that date.  The revised list is attached to this Market Notice and has been posted to the Large Load Integration page of ERCOT's website under "Forms and Other Documents."

The procedures described in this Market Notice and in Market Notice M-B090225-01 are established on an interim basis for the purposes of timely implementing PURA Section 39.169.  The form and these procedures are subject to change and may be preempted by the PUCT's forthcoming rules governing the process for studying and reviewing net metering arrangements.

ADDITIONAL INFORMATION: Please see Market Notice M-B090225-01 for information about the review process, including the required form of notice and the process for claiming an exemption under PURA Section 39.169(b)(2). 

CONTACT: If you have any questions, please contact your ERCOT Account Manager. You may also call the general ERCOT Client Services phone number at (512) 248-3900 or contact ERCOT Client Services via email at ClientServices@ercot.com.

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