America’s electric grid is facing a structural breaking point. Trillions of dollars of artificial intelligence infrastructure, data centers, and industrial reshoring demand power today, but traditional high-voltage transmission upgrades take five to seven years to deliver firm capacity. Under the status quo, large energy consumers are forced to wait in line, threatening stymied global leadership and lost economic growth.
Breathlessly we ask: do we save the economy or the grid?
Why not both?
Stifled beneath the long-established arc of how we think about grid policy—as the core job of policymakers—is the innovation potential of private capital and private innovators to get the job done in partnership with public entities and heavily regulated franchises. We operate our power grids in the United States largely in a construct where power access involves consumers being price-takers, not price-creators.
Everything worth innovating—the architecture, the engineering, the modeling, the power flow risk models—has historically rested on the shoulders of wires companies, operators, and load-serving entities. Most of these entities are backed by the same institutional capital guaranteeing the slow-paced, low-risk returns Americans want to see in our pension funds, 401(k)s, and life insurance policies; millions of Americans have positive exposure to utility ROI through retirement plans. But this financial safety net has inadvertently cast a web of technological stagnation. We have effectively tasked the most risk-averse pools of capital in the world with funding the most urgent, high-stakes technological transformation of our time.
Making What is Backward Go Forward
Could it be more backward? We lack naturally occurring pathways that empower consumers to be price-creators, and to therefore take on the risk of engineering a modernized power grid.
Over the past six years, I have specialized in creating those pathways. In the last two years, my venture studio has collocated on either side of the problem statement: building paths for distributed and large centralized power users, while giving existing generators a reason to contract for revenues they are not currently making in the markets. Prior to that, I spent four years doing the same thing as an energy markets strategic lead at Tesla. There, I enabled STEM-to-market access frameworks for large battery farms and distributed solar-battery business models. This included making it possible to commission Tesla Megapacks in ERCOT and send aggregated grid services to ERCOT 24/7 from clean-powered home batteries.
In my own shop, that is what I do all day now. I burn hours and brain cells reversing this systemic failure. I work to create markets for private technology companies and regulated power utilities to compete their way to higher returns, investing time, capital, and reputation in closely held technology so that my IP for America’s power grids also comes back to me in private returns. Private returns mean exits, but they also bring meaning to my existence. Homes in multiple cities have power during and after storms because of this work—that is a deeper platform for the job, and one that pays endless dividends.
Privatized Firm Delivery Risk is the Capital Markets Solution to Waiting for the Grid to Build
Going forward in Texas energy markets means enabling a private firming solution for large loads and creating frameworks for risk-takers to actually take risks. It means ending the hand-waving from private capital that backs billions in AI infrastructure—investors who claim they need to take risks to save our economy from foreign adversaries, yet simultaneously attempt to de-risk every aspect of enabling speed-to-energization.
The idea is not simply to beat the drum so that large loads can have their cake and eat it too. The idea is to enable private capital to back parties who say they can make a bigger cake, eat a bigger slice, and share it. This means investing in grid utilization and turning loads and generators into carefully orchestrated transmission congestion and dispatch solutions. It means large energy users should be able to voluntarily accept early energization by acting as a shock absorber for local transmission constraints. So, this is exactly what we did.
>>>READ: How Renewables and Batteries Saved the Texas Grid in 2025
A Brief and Intense Climb to Speed-to-Power Market Design
In September 2025, the Luminary Strategies venture team worked with ERCOT allies to propose a white paper to the ERCOT Large Load Working Group (LLWG). We proposed a fundamental shift: if recent market reforms (NPRR1188) enabled large loads to be locationally dispatched under grid operator direct control (no funny business, no air gaps, no “opting out”), then those loads are also available to help manage headroom constraints, just like generators are. So, why are they not eligible to “connect and manage,” energizing faster just like generators do?
The idea was incredibly complex, yet beautifully simple. Indeed, this is the core thesis of “connect and manage.” Heatmap reporter Matthew Zeitlin picked up on this when he titled the origin story article on our efforts, “A New Plan for Texas to Treat Data Centers Like Solar Farms.” (Note that industrial loads are very excited about the solution, and might execute it first in practice).
The grind that followed was essentially legendary. Just a month after Luminary filed the proposal with ERCOT, the Governor asked Texas regulators to create something brand new to fix the broader power access issues for large power users. We had to figure out how to rally multiple power and tech companies to convince ERCOT to see the merit in prioritizing a market structure for curtailment-ready loads whilst designing a completely new “batch” process for the behemoth task of load interconnection itself. So, we activated a marketplace of doers in order to activate the market design itself. The proposal was fine-tuned into the text of the batch load rules. On May 19, 2026, the ERCOT Technical Advisory Committee unanimously voted out a new large load “batching” framework, and a “connect and manage” loads solution is part of it.
Go Forth and Compete
The framework pioneered in Texas has had many twists, turns, and refinements in an incredibly short period of time. Simultaneously, multiple aspects of this approach to “Speed-to-Power” have glimmering parallels in development on smaller grids around the country, and some on other continents, which are less beleaguered by the challenges of directly integrating loads into transmission security operations.
Ironically, prior work to enable small loads to participate in transmission security operations is a core tenet of why ERCOT is ready to consider large loads doing the exact same thing.
>>>READ: A Consumer-First Framework for Transmission Reform
The Road Ahead: What PCLR Means for the Market
The unanimous approval of the curtailable load framework in Batch Zero is the starting gun. We have activated the market design; now, we must navigate the execution. For private capital and large energy consumers, electing this status, known as Provisional Controllable Load Resource (PCLR), dictates a rigorous timeline of action:
- Right Now (Summer 2026): It is about securing a place in line and signing the dotted line to commitment to operational flexibility. By July 10, 2026, developers must submit the first part of “Form W” to commit to PCLR registration. This means coming to the table immediately with advanced dispatch modeling, curtailment assessments, and a clear understanding of risk profiles.
- In a Few Months (Fall 2026): Once ERCOT officially notifies transmission providers of load classifications in early August, the massive Batch Zero Interconnection Study kicks into gear. Over the subsequent months, ERCOT will run system-wide steady-state and stability screens to determine the firm-load floor—the maximum Low Power Consumption (LPC) limit—that can be reliably served for these studied loads.
- A Year From Now (Spring 2027): In April 2027, ERCOT is scheduled to deliver the final study results and limits. At that point, developers must sign Form W Part B, making a binding commercial decision to accept their capacity allocations and execute their Interconnection Agreements, and commit to an operational profile that includes a “can curtail” tranche of power demand.
These milestones comprise only half of the racing lanes. In parallel over the next year, the actual implementation rules, system changes, and software coding for NPRR1188—the mechanism that allows these large loads to be locationally dispatched and bid-capped under ERCOT’s direct control—must be finalized.
My hope is that the marketplace of doers that rallied with us to get PCLR approved will stay intensely engaged with commercial heft behind their efforts – something that is harder to actuate when we are drafting the rules. We need market participants, tech innovators, and policymakers to unite in building the strongest possible framework for operations. If we get the code, the risk-sharing, and the market rules right, we don’t just solve Texas’s power bottleneck—we blueprint the consumer-first, agile grid required to win the AI century.
By Arushi Sharma Frank, C3 Advisory Board, Founder, Luminary Strategies
The views and opinions expressed are those of the author’s and do not necessarily reflect the official policy or position of C3.
