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Neil P. Osnato's avatar

Ryan — the part of this that really jumps out is the distinction between project representation and earned reliance.

A developer can enter a queue, post security and clear an administrative milestone without necessarily establishing that the underlying load, customer, power strategy, timing or operating assumptions have become durable enough for planners to rely upon.

The same issue shows up with flexibility: demonstrated capability is evidence, but it is not permanent assurance that the capability will remain available under the conditions in which the grid later depends on it.

The missing layer seems to be:

Representation → Evidence → Dependency → Decision Gate → Material Change → Revalidation.

Project maturity determines whether a project has earned advancement. Revalidation determines whether the evidence that earned advancement remains true.

Really thoughtful piece.

Neil P. Osnato

Founder | Persistence Analytics Group LLC

John Chambers's avatar

Good piece, but from the operator's chair — 35 years in energy and finance, gas assets in Texas — it treats a real-estate phenomenon as a grid phenomenon.

The 474 GW isn't a load forecast; it's a listing count. Most of the "developers" in that queue have never built, bought, or run a megawatt of generation. A load-study letter from Oncor or AEP became the marketing document for "powered land," and the queue filled up the way an MLS does. Auditing it is fine. Freezing everything punishes the few applicants who can actually energize.

Behind-the-meter in West Texas isn't a bridge, either. Waha gas has traded negative. A producer with stranded gas and a buyer whose economics, by your own numbers, could bear $5,600/MWh aren't building a plant to shut it in year five. The grid tie becomes the backup and the export path; the plant stays primary. Your two facts — GPUs cost far more than power, and on-site power costs more than grid — point the same way: on-site is permanent.

The $50k/MW deposit isn't thin for the population causing the problem. A 500 MW request is $25 million posted. Speculators can't post it; hyperscalers won't notice it. That's the filter working, and the forfeit percentage is beside the point.

ERCOT also doesn't build anything. Oncor, AEP and CenterPoint do, and their crews, transformer deliveries and 765 kV schedules are the gate. No rule change at ERCOT adds a lineman.

Last, the Legislature isn't in regular session until January 2027. SB 6 already gave the state deposits, disclosure, backup-gen reporting and curtailment authority. The freeze is an executive overlay on a statute that was already doing the filtering, and the office that imposed it can narrow it tomorrow. It doesn't need to wait for October 19.

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