Texas Is Auditing the Demand. Nobody Is Auditing the Supply.

Two hundred gigawatts of data-center demand is being audited in Texas right now. 326 projects, each asked to prove it is real before it gets a connection.

Not one question in that audit is about where the electricity comes from.

Grid Alpha's argument has always been that an interconnection queue is a record of intentions, not a forecast. Abbott's audit is the first regulatory instrument in the country built on that premise — it assumes the queue overstates itself, and puts the burden of proof on the applicant. We think that is right. We also think it covers one half of the problem, and that the other half is where the risk sits.

Because a data center is a load. It generates nothing. Every megawatt those projects are asking for has to come from a generator that is itself financed, permitted and built — and generators sit in a different ERCOT queue, one nobody has been asked to verify.

The left column is ERCOT's, from its July 29 presentation to the Senate Committee on Business & Commerce. The right is ours, from the generator queue we have tracked since this publication started. Two separate queues — the columns do not divide into each other, and we show them together to make that point, not to imply a ratio.

What the audit actually asks

The August 3 directive is now an operating procedure. ERCOT is running it as two workstreams: Batch Zero Eligibility Verification for large loads of 75 MW and up, which verifies the attestations behind a project's eligibility, and a separate Community Impact Review for computational loads of 25 MW and up, which collects Abbott's List.

Read the third line closely. Of the five, it is the only one that reaches outside the applicant's own fence, and it asks for an intention rather than a fact. ERCOT will strike a project from Batch Zero for a materially false eligibility attestation. Naming a generator that never gets built is not one of those attestations.

The queue that has to answer

We track the ERCOT generator interconnection queue — solar, wind, storage, gas. Not data centers. This is the supply side of the same grid, and its defining feature is age.

More than 400 of these requests — about 36% of the queue — were filed in 2023 or earlier and are still open. The oldest still-open request dates to 2015: an eleven-year-old intention to build a power plant, still carried as current.

We want to be careful about what this does and does not prove. "Still open" is not "abandoned" — ERCOT carries a request until the paperwork closes. But not one of these requests has signed an interconnection agreement, and 376 of the 444 filed before 2024 have not yet completed their full interconnection study. That is the population a serious verification regime would be interested in.

Applied to loads, that same screen cut ERCOT's large-load queue from 688 projects to 326 eligible for Batch Zero, and 498 GW to 205. Nobody has run it on the supply side.

What we're watching

The RFIs. Not yet issued. They are the mechanism that produces the first documented Abbott's List failure, and when one lands we name the line it failed on, as committed in Issue #003.

December. ERCOT's target for finishing the audit, against an April 9, 2027 study deadline it says it is still holding.

16 TAC §25.194. Still proposed. The $50,000-per-MW figure is a security deposit — collateral, roughly 80% forfeitable — not a fee, and not law yet.

An audit that verifies demand and assumes supply has cut the problem in half and solved the easier half. If 200 GW of load is real enough to survive Abbott's List, the follow-on question writes itself: which generators, specifically, are going to serve it — and when did they last do anything other than sit in a queue?

We have been keeping that list since before there was an audit.