Outline of Texas with a server icon at its center, under a voltage waveform showing one sag highlighted in red

ERCOT NOGRR282 in plain English: who it covers, what it requires, what it does not

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Last updated: 2026-10-30

ERCOT’s NOGRR282 has been in effect since 2026-08-01 (ERCOT NOGRR282). The Public Utility Commission of Texas approved it on 2026-07-09 (PUCT report). It adds two new sections to the Nodal Operating Guide, 2.6.4 for frequency and 2.15 for voltage (PUCT report). The ERCOT issue page lists the voltage section as 2.14, but the approved text heads it 2.15 (ERCOT NOGRR282). Ride-through here means the load stays connected and keeps drawing power through a disturbance (PUCT report, 2.6.4(5) and 2.15(3)).

Who it covers

The rule covers a Large Computational Load. The ERCOT Protocols define a Large Load as one or more facilities at a single site with aggregate peak demand of 75 MW or more (NPRR1308 report). A Large Computational Load is a Large Load in which 50% or more of the demand is power electronic computational load, such as data centers and cryptocurrency mining (NPRR1308 report).

The exemption

A customer is exempt if it can demonstrate that the load was operating, or had written ERCOT approval to energize, on or before 2025-11-14. A second route requires all interconnection or service extension agreements to have been executed by that date. On that route the transmission provider must have had notice to proceed with construction and the financial security by that date. Either the interconnection study must have been approved by that date, or ERCOT must have approved a utility attestation and the load must energize by 2026-12-31. A later modification that meets the study trigger in Planning Guide 9.2.1 ends the exemption (PUCT report, 2.6.4(1) and (2), 2.15(1) and (2)).

What the text requires

For frequency, the load must ride through 58.8 to 61.2 Hz continuously. It must ride through 57.5 to 58.8 Hz and 61.2 to 63.0 Hz for at least 299 seconds (PUCT report, 2.6.4 Table A). Ride-through is not required while the load acts under an under-frequency load shed program or an Ancillary Service (PUCT report, 2.6.4(3)).

For voltage, the minimum ride-through times are below. The measurement point is the Service Delivery Point, or the Point of Interconnection Bus where the load shares a site with a generation or storage resource (PUCT report, 2.15 Table A).

Voltage, per unitMinimum time
Above 1.10 to 1.201.0 s
0.90 to 1.10Continuous
0.80 to below 0.902.0 s
0.50 to below 0.800.5 s
0.35 to below 0.500.25 s
Below 0.350.15 s

Cooling or mechanical load may trip below 0.35 per unit (PUCT report, 2.15(3)). Below 0.8 per unit the load may reduce consumption. It “shall return to at least 90% of its pre-disturbance consumption level from the grid within two seconds of voltage at the Service Delivery Point or POIB returning to above 0.90 per unit” (PUCT report, 2.15(3)(c)). A load-transfer scheme has a tighter window. It must begin returning within 0.25 seconds and reach 90% within 0.5 seconds of voltage recovering above 0.9 per unit (PUCT report, 2.15(3)(e)).

The table reads voltage at the Service Delivery Point (PUCT report, 2.15 Table A). A regulated supply behind that point holds its output power, so its input current rises as the voltage falls (3DFS data centers page). The rise adds to the drop on the facility’s own impedance (3DFS data centers page), so voltage at a panel can sit below voltage at the Service Delivery Point.

What that means in the electrical room

On a power failure the generator set starts automatically after a short delay (TM 5-689, paragraph 6-4 a). The UPS rectifier later moves from battery back to the ac source (TM 5-689, paragraph 6-4 a). Protection that trips or transfers the load must allow ride-through “to the maximum level the equipment allows” (PUCT report, 2.15(5)). Frequency protection shall not trip the load on an instantaneous frequency measurement (PUCT report, 2.6.4(8)). Instantaneous over-current and over-voltage protection must use filtered quantities or time delays (PUCT report, 2.15(6)).

The sag-counting rule

From discussions with data center owners, NERC reported a scheme that counts voltage disturbances and keeps the load on backup until someone reconnects it by hand. Three disturbances within one minute was the typical setting (NERC Incident Review, p. 7). A load shall not use a trip or transfer scheme “due solely to a certain number of voltage sags or swells within a certain period of time” if it must ride through each one. Where equipment limits force such a scheme, the load must stay connected through at least six sags or swells within 90 seconds (PUCT report, 2.15(7)).

Failure, root cause and disconnection

If ERCOT finds that a load failed to ride through, the customer must report the root cause within 90 days of the ERCOT request. It must then submit a plan within 90 days and implement it within 180 days of that, unless ERCOT approves a longer timeline. If operation after the failure poses an imminent risk to local or system reliability, ERCOT “may require the LCL to disconnect from the ERCOT System” until the customer demonstrates that the load can comply (PUCT report, 2.6.4(9) and 2.15(8)).

What the rule does not do

The approved NOGRR282 text names no fine or penalty (PUCT report). A separate request, NOGRR289, would let a load whose cooling load cannot yet meet the requirements comply within 365 days after its in-service date (NOGRR289 ROS report). ROS granted it Urgent status and tabled it on 2026-08-06, and the ERCOT issue page lists it as pending (ERCOT NOGRR289).

What Software-Defined Electricity does at the panel

Software-Defined Electricity is a computer at the panel. It measures the current waveform itself and corrects it digitally, within the same cycle (3DFS SDE summary page). The controller samples over 1,000 times per sine wave and responds in under 5 microseconds (3DFS SDE summary page). It separates the working current from the reactive, harmonic and unbalanced parts. It supplies the non-working parts from the panel, within its rating, at the moment the loads need them (3DFS SDE summary page).

The source then carries less of those currents, and the voltage drop they made shrinks with them (3DFS voltage stability page). On a stiff utility service that share is small. On a generator, a long feeder or a microgrid it is the larger one (3DFS voltage stability page). Source-side current falls to near the working current, so the transformer, feeder and switchgear run cooler (3DFS resilience page).

Correction on a PDU behind the UPS lightens the UPS inverter and the PDU transformer (3DFS data centers page). It reaches the utility or the generator only on static bypass, maintenance bypass or eco mode (3DFS data centers page).

How Software-Defined Electricity is the differentiator during a sag

A sag puts the site’s own load against it. A regulated supply holds its output power, so the UPS rectifier draws more current as the voltage falls (3DFS data centers page). That current deepens the drop on the facility’s own impedance, so a panel sees a deeper sag than the Service Delivery Point, and the protection has less room before it trips (3DFS data centers page).

Correction removes the part of that current that does no work. The corrected loads present working current only, without the reactive and harmonic share, so the drop the site adds to its own sag shrinks and the gap between load level and trip level widens (3DFS data centers page). In our assessment of two server racks, reactive current at the fundamental fell from 7.27 A to 0.18 A (3DFS resilience page). On bypass, when racks near 0.98 leading land on a generator at 12 to 20% impedance, correction to unity removes the leading current that drives a generator unstable above roughly 20% of its rating (3DFS data centers page).

The controller does not provide ride-through (3DFS standards compliance). The UPS, the static switch, the battery and the protection settings decide whether the facility stays connected (3DFS data centers page). What correction does is take the site’s own share out of the sag and out of the trip margin, every cycle, before the event (3DFS resilience page). The first step is small and can be undone. The controller connects alongside the panel, not in the power path, and power stays on during installation (3DFS products page). Removing or powering down the controller leaves the panel as installed (3DFS data centers page).

Critical perspective

The Texas Blockchain Council told ERCOT that a low-voltage fix costs “upwards of $1 million per MW” (Texas Blockchain Council, March 18, 2026). The same filing says its members already ride through frequency and high-voltage events, leaving “the most extreme scenarios” of low voltage (Texas Blockchain Council).

So the estimate prices the last part of the envelope, and it comes from a party that would pay it. ERCOT’s own cost is staff, at $600K to $750K a year (PUCT report).

The exemption carries the larger risk. ERCOT wrote on September 25 that many operating computational loads are exempt and “may significantly reduce consumption during normal system disturbance events” (ERCOT, NOGRR289 comments). It expects to hold consumption at identified exempt sites below each operating limit’s 3,200 MW cap in real time, counted across the exempt sites in that group (ERCOT). Transmission Operators and Qualified Scheduling Entities would carry out those plans (ERCOT). The exempt sites pay in curtailment, not in retrofit.

NOGRR289 would add cooling load to that exposure. ERCOT’s preliminary assessment assumed cooling at 20% to 30% of approved load and found more load unable to ride through in the affected areas (ERCOT). ERCOT asked for further talks before the request proceeds (ERCOT). If any cooling exemption survives, ERCOT wants it to end no later than June 30, 2027 (ERCOT).

A developer in the ERCOT queue should not schedule around NOGRR289 relief. ERCOT’s June 30, 2027 is the earliest end date on the record (ERCOT). Google and Skybox proposed December 31, 2029, and the request is still pending (Google and Skybox comments on NOGRR289, ERCOT NOGRR289).

Frequently asked questions

Does NOGRR282 apply to a 30 MW data center? Not as a Large Computational Load. The Large Load definition starts at 75 MW of aggregate peak demand at a site (NPRR1308 report).

Does backup power satisfy the rule? Not by itself. The text bars schemes that move load to backup solely on a sag count when the load must ride through each sag (PUCT report, 2.15(7)).

Is there a fine? The approved text states no fine. ERCOT may require disconnection when operation after a failure poses an imminent reliability risk (PUCT report, 2.15(8)(c)).

Does a power quality controller meet the rule? No. Our controller corrects the reactive, harmonic and unbalanced current at the panel, within its rating and within the same cycle (3DFS SDE summary page). It does not provide ride-through (3DFS standards compliance). The UPS, the static switch, the battery and the protection settings decide whether the facility stays connected (3DFS data centers page).

Related: data center grid rules in one place, data center and compute solutions, 3,800 MW left the grid.

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