Digital Power Network Urges Texas Regulators to Align Large-Load Interconnection Rules with ERCOT Realities and Flexible Load Growth
FOR IMMEDIATE RELEASE
Washington, D.C. — The Digital Power Network (DPN), the nation’s largest coalition of Bitcoin miners and digital infrastructure operators, today submitted formal comments to the Public Utility Commission of Texas (PUCT) in Project No. 58481, addressing the Commission’s proposed Large Load Interconnection Standards under 16 TAC §25.194.
DPN’s filing supports the Commission’s goal of improving transparency, predictability, and efficiency in the large-load interconnection process, while urging targeted refinements to ensure the rules reflect ERCOT’s operational realities and the unique characteristics of flexible, interruptible loads such as Bitcoin mining, high-performance computing, and advanced data centers.
“Texas leads the nation in large-load growth because it pairs reliability with innovation,” said The Digital Power Network. “Interconnection standards should distinguish between flexible and inflexible loads, align with ERCOT protocols, and avoid unnecessary barriers that could slow investment or undermine grid reliability.”
Key Themes from DPN’s Filing
Recognize Flexible Loads as Grid Assets
DPN emphasizes that flexible, interruptible loads increasingly support ERCOT reliability through demand response, curtailment, and market participation. The proposed rule should explicitly recognize operational differences between flexible digital infrastructure and traditional industrial loads.
Align Thresholds and Definitions with ERCOT Practice
DPN recommends aligning the large-load threshold with ERCOT’s existing study triggers and clarifying definitions to reflect phased, modular development common in digital infrastructure projects.
Avoid Overly Burdensome Financial and Security Requirements
The filing cautions that proposed security requirements, such as a $50,000/MW financial obligation, could create excessive upfront capital barriers, particularly for phased projects. DPN urges the Commission to adopt phased, proportional, and capped security structures tied to actual project milestones and utility risk.
Protect Confidentiality and Market Competitiveness
DPN raises concerns about repeated disclosure requirements related to “substantially similar interconnection requests,” warning that vague standards could expose commercially sensitive information without providing commensurate reliability benefits.
Preserve Texas’ Investment-Friendly Development Model
The comments urge the Commission to avoid turning electric utilities into de facto monitors of non-electric permitting, land use, or commercial development, which could slow projects and exceed ERCOT’s jurisdictional role.
Supporting Reliability While Sustaining Growth
DPN’s filing underscores that Texas’ success in attracting large-scale digital infrastructure stems from clear rules, cost-causation principles, and flexibility, not rigid timelines or one-size-fits-all requirements.
“The goal should be to ensure serious projects move forward efficiently while discouraging speculative queue positions, without chilling investment in the very loads that help stabilize the grid,” DPN noted.
DPN looks forward to continued engagement with the Commission, Commission Staff, ERCOT, and stakeholders to finalize a framework that protects ratepayers, enhances reliability, and keeps Texas globally competitive in energy-intensive industries.
DPN’s full comments in Project No. 58481 are available here.
About the Digital Power Network (DPN):
The Digital Power Network (DPN) is the largest coalition of Bitcoin miners and digital infrastructure leaders in the United States, representing over 85% of the Bitcoin hash rate among publicly traded U.S. mining companies. DPN advocates for policies that promote energy innovation, grid resilience, economic development, and the strategic role of digital assets in the 21st-century economy.