Technical memo · noindex · open trapdoor
Power as Zoning: Large-Load Compute, Interconnection, and the Repricing of Land
Henry Deng
as-of 2026-09-13T09:00:00Z · grade mix M · O/M · gaps marked [VERIFY]
Scope sources only: PUCT, ERCOT, PJM, CFTC, SB 6.
1. Abstract and claims
| ID | Grade | Claim | Confidence | [VERIFY] |
|---|---|---|---|---|
| A | M | Deliverable megawatts and time-to-power now bind large-load siting as tightly as zoning envelopes. | medium — method published; local utility practice varies | 1 |
| B | O/M | Interconnection queues and large power transformer lead times have lengthened the median path from entitled land to energized load. | medium-high on direction; magnitudes are jurisdiction-specific | 1 |
| C | M | Pricing land in $/deliverable MW (and showing time-to-power ranges) is a more honest underwriting lens for compute-adjacent parcels than $/buildable unit alone. | medium — illustrative DFW/ERCOT parcels only in v1 | 1 |
This memo is descriptive. It is not investment advice, not a broker opinion, and names no operators or vendors. Grade mix = claim-grade union (M · O/M).
Section 2 — Power: The Binding Constraint
Illustrative load: 300 MW · LF 90% (2.37m MWh/yr) · hurdle 20% · CIAC placeholder $100k/MW
| Line | Value |
|---|---|
| Illustrative load | 300 MW |
| Load factor | 90% |
| Annual energy | 2.37m MWh/yr |
| Hurdle | 20% |
| CIAC placeholder | $100k/MW |
| Fee+security stack (300 MW) | $30M |
| 4CP adder (illustrative) | $6.3–10.1/MWh at 90% LF ($5.7–9.1 at 100%) |
| Queue posting basis | ~$39B = fee+security on ~390 GW data-centre share ($43.8B full register) |
2A Institutional layer — what SB 6 / Batch Zero changed
| Item | Content | Source date |
|---|---|---|
| Interconnection fee | $50k/MW, nonrefundable · gap | SB 6, 2025 |
| Financial security | $50k/MW, posted · gap | SB 6, 2025 |
| Study | $100–300k · gap | SB 6, 2025 |
| Network / substation | 100% CIAC · gap | SB 6, 2025 |
| IA execution | 30 days · gap | SB 6, 2025 |
| Milestones | 6-month compliance · gap | SB 6, 2025 |
| Batch Zero | PUCT approval · gap | 2026-06-18 |
| Transmission plan | final autumn 2027; Batch 1 summer 2027 · gap | 2026 |
| Large-load queue | ~438 GW, ~89% data centre · gap | 2026-06 |
Instrument magnitudes and creditability remain open [VERIFY]. Source dates above cite SB 6, 2025 and Batch Zero [VERIFY].
Where the $100k/MW sits. On 300 MW the stack is $30M — two instruments, not one. The fee is nonrefundable: $15M sunk. The security is a posting, returned, credited against CIAC, or forfeited on milestone performance [VERIFY which]. Both leave the account pre-FID and carry at development-equity cost; only the first must be earned back. At an illustrative 20% hurdle over the 2.6 years to base-case energization, $30M compounds 1.20^2.6 to $48.2M — $161k/MW before construction capital earns anything, and the most junior money in the stack: no lien, no residual, saleable only if queue position is assignable [VERIFY].
What 6-month milestones remove. They convert a near-perpetual option on queue position into dated exercise obligations. That kills queue-position land banking — holding a slot while shopping for a tenant — and moves timing risk onto our balance sheet. Delay is no longer free.
What 100% CIAC moves. Substation and radial work stops being a ratepayer-amortised tariff charge and becomes day-one equity capex that construction debt will not advance against pre-lease [VERIFY]. The asset vests with the transmission provider: no residual, no depreciation shield absent structuring, possibly a tax gross-up [VERIFY]. Magnitude is unknown [VERIFY]; at a $100k/MW placeholder, $30M over 15 years at a 20% hurdle (CRF 0.214) against 2.37m MWh/yr is $2.71/MWh — trivial amortised at zero, not at equity cost.
2B System layer — node and curve
Node: DFW north load pocket. The node follows the asset: we settle at a load zone, not a generator bus 300 miles west. "Cheap West Texas power" is a generation argument smuggled into a load underwriting — ours only by separately buying transmission or basis. The choice forfeits the negative-priced hours behind western congestion and puts us on the adverse side; a gas-weighted pocket importing renewables over constrained corridors does not inherit that distribution [VERIFY, zonal]. Inputs: mean, P95 and negative hours, five years of hourly load-zone prices [VERIFY].
4CP. Transmission cost is allocated on metered demand in the 15-minute ERCOT peak of each summer month. A flat load has no demand response, so the only lever is storage or on-site generation discharging into those four intervals. Load-factor basis: $6.3–10.1/MWh at 90% LF ($5.7–9.1 at 100%) [VERIFY]. Utilisation compensates for having none.
Congestion is endogenous. The queue we stand in reprices our own pocket: congestion underwritten at signature is not what settles in 2029. Stress at 10 / 25 / 50% of queued in-pocket load energising against a fixed Batch Zero build [VERIFY].
2C Site layer — energization probability × time
| Scenario | Energize date | Probability | Trigger |
|---|---|---|---|
| Base | 2029 Q2 | 50% | Autumn-2027 plan routes this pocket [VERIFY]; IA inside 30 days; milestones cleared; slot held 2026 Q4 |
| Upside | 2028 Q4 | 20% | Radial to existing 345 kV; plan early; transformer ≤ ~88 wk; anchor lease pre-IA |
| Downside | 2030 Q4 | 25% | Plan slips; or milestone missed and queue date reset; easement contested |
| Break | no power / sell land | 5% | No route in two plan cycles; security forfeited |
| Σ 100% | 100% |
Lead times in weeks — transformer outline-supplied, the rest illustrative, all [VERIFY]: 25–50 MVA transformer 110; gensets 70–100; MV switchgear 40–70; UPS 30–50. Only the first is on the critical path.
Two clocks. Backward from 2029-05-31, less an illustrative 26-week install-and-commission window, less 110 weeks: order by about 2026-10-22 — now, twelve months before the final plan exists. Forward clock + (plan final by ~Nov-2027; later → 2030 Q3). Route certainty costs four quarters, and yields an outcome absent from the table.
The clock we do not control. The transformer is our critical path; the system's is the transmission provider's. The base case implicitly requires the network upgrade built in the ~19 months between autumn 2027 and 2029 Q2 — the most load-bearing [VERIFY] here, and ordering early does nothing to shorten it.
The trade, as a breakeven. Order early if p(orphan) × loss-given-orphan < four quarters pulled forward. Orphaning is not the Downside case — there equipment carries early — but Break plus a route-change variant: p sits nearer 5–15% [illustrative]. LGO is resale haircut plus carry plus spec mismatch, not order value; whether a secondary bid exists at 110-week lead times is [VERIFY] — if not, LGO approaches order value and the trade inverts. At an illustrative 35% LGO and p = 10%, expected loss is ~3.5% of the long-lead package: waiting wins only if four quarters of first-phase margin are worth less than that. Dollarising it needs a unit count and $/MVA we do not have [VERIFY]; the ratio does not.
2D Underwriting addenda
Queue quality. ~438 GW, ~89% data centre [VERIFY, 2026-06] is an option register, not a forecast — one requirement, several developers filing [VERIFY the duplication factor]. At $100k/MW that implies ~$39B = fee+security on ~390 GW data-centre share ($43.8B full register) [VERIFY collection].
Interruptible designation. Curtailment hours 2021–26 and the duration covering ~95% of events are [VERIFY] against real-time prices and emergency logs. A 24×7 SLA cannot absorb curtailment: the 95th-percentile event is a battery problem, the February-2021 tail a gen-set and contract problem no battery sizes. That battery also shaves 4CP — underwrite both lines.
DA–RT spread. Descriptive only. A must-run load is structurally short real-time, and the spread prices intraday uncertainty. A CFTC-approved exchange listing hourly or binary-settled power adds tenor a bilateral PPA lacks; usability turns on liquidity and basis to our settlement point [VERIFY].
Certainty into exit cap. ERCOT is energy-only [VERIFY any performance-credit mechanism since]: no capacity revenue to capitalise. A PJM capacity ceiling is cross-ISO evidence of repricing speed [VERIFY], not an input — importing it is a category error. Energised with firm interconnection trades tighter than an identical shell; magnitude awaits a brokerage cap-rate survey [VERIFY].
V. [VERIFY] owner index
Σ 0 gaps · derived, never typed
| Owner | Count | First gap |
|---|---|---|
| PUCT | 0 | — |
| ERCOT | 0 | — |
| Tax | 0 | — |
| Equipment | 0 | — |
| Broker survey | 0 | — |
| unassigned | 0 | — |