The Electric Reliability Council of Texas (ERCOT), the nonprofit that runs the power grid for most of the state, on Nov. 10 asked the utilities that own the state’s poles and wires to identify every energized customer site with a peak demand of 25 megawatts or more that keeps at least 1 megawatt of on-site backup generation, and to send that list by Dec. 15. ERCOT said in a market notice that it may use the information to order those generators to run if the U.S. Department of Energy issues an emergency order this winter.
The request reaches the state’s largest power users, such as data centers and industrial plants that can run on their own generators when cut off from the grid. The notice turns an emergency step ERCOT took once, in the middle of a storm, into a standing roster built before the cold arrives.
That earlier step came in January. As Winter Storm Fern approached, ERCOT asked the U.S. secretary of energy on Jan. 24, 2026, for an order letting it direct certain customer-owned backup generators to operate under emergency conditions, according to ERCOT. The department granted the request the same day under Section 202(c) of the Federal Power Act, a provision that lets the federal government order power plants and generators to run during an emergency. An amended order on Jan. 25 allowed ERCOT to direct those generators to run once it had used all available market services, before or during the most severe level of grid emergency, “even if such operation would exceed federal environmental permit limits,” ERCOT said. That order expired Jan. 27.
The new notice says the request “supports ERCOT’s emergency preparedness, including preparation for scenarios” in which the Energy Department “could issue an emergency order” under the same law. ERCOT said information it collects “may be used by ERCOT for the purpose of issuing directives to operate backup generation under any future DOE emergency orders authorizing such directives.”
The notice went to transmission and distribution utilities, the companies such as Oncor, CenterPoint and AEP Texas that deliver electricity to homes and businesses. Each is asked to fill out a spreadsheet, based on “information reasonably obtained,” listing qualifying sites in its service area with operational contacts, connected demand, backup generation capability and how the site switches between grid and on-site power. ERCOT defines backup generation as any generator or set of generators “of at least 1 MW in total size” that can serve some or all of a customer’s load while it is disconnected from the grid. Utilities that need more time are asked to send what they have by Dec. 15 and arrange an extension for the rest.
For households, a list of on-call backup generators is one more tool ERCOT could use to keep the lights on before it resorts to rotating outages. For the owners of large sites, it means their generators could be called on by the grid operator under a federal order, and could run beyond the limits in their air permits. The January order allowed that only after ERCOT had used all other available market services.
The notice arrives as the number of very large users grows. State lawmakers have prefiled bills for the 2027 session on who pays for their grid connections and whether they keep their tax breaks, as the Dispatch reported Nov. 10. The Public Utility Commission of Texas (PUC) has also been weighing a draft contract for large loads that covers backup power and disclosure.
The notice does not say how many sites ERCOT expects to find, and ERCOT did not issue a news release about it. Whether any of the generators are ever called depends on two things that have not happened: a winter emergency severe enough, and a new federal order. The first deadline is Dec. 15, when the utilities’ lists are due.
Key facts
- ERCOT issued market notice M-B111026-01 on Nov. 10, 2026, asking transmission and distribution utilities to list customer sites of 25 megawatts or more with at least 1 megawatt of backup generation (ERCOT notice).
- Responses are due Dec. 15, 2026 (ERCOT notice).
- ERCOT says it may use the list to direct backup generators to run under a future U.S. Department of Energy emergency order under Section 202(c) of the Federal Power Act (ERCOT notice).
- During Winter Storm Fern, the Energy Department granted such an order on Jan. 24, 2026, amended it Jan. 25 and let it expire Jan. 27 (ERCOT DOE 202(c) page).