In electricity, curtailment is a deliberate cut in power use or output to keep the grid balanced. For a Texas business on the ERCOT grid it comes in two forms. One is involuntary: a controlled outage, or rolling blackout, that ERCOT orders in a grid emergency and your utility carries out. The other is voluntary: load you choose to cut, either to lower next year's transmission charges or to earn a payment in an emergency program.
You can't contract your way out of the first, but you can plan for it. The second is a set of choices with real obligations. This guide covers both, using ERCOT's Protocols and PUCT rules as they stood in early September 2026: the emergency ladder, who decides which buildings go dark, what Winter Storm Uri showed, the voluntary programs, and how your contract fits in.
The word has other meanings too. Grid operators curtail wind and solar output, gas utilities curtail deliveries in shortages, and lenders use "curtailment" for early principal payments. The first two get a short section below. The rest of the article is about your meter.
What Curtailment Means, and the Meanings That Aren't About Your Meter
In power markets, curtailment is any intentional reduction of supply or demand that keeps the system in balance. On the customer side, that means reducing or cutting load. On the generation side, it means a power plant produces less than it could.
Generation curtailment is what most search results for the word describe. According to the U.S. Energy Information Administration, ERCOT curtailed about 5% of available wind output and 9% of available utility-scale solar output in 2022. In a 2023 projection, EIA estimated those shares could reach 13% and 19% by 2035 without more transmission, and it tied 36% of projected curtailment to transmission constraints. Those are 2022 actuals and a 2023 forecast, not current figures. If you are weighing a renewable deal, curtailment risk belongs in the contract review. Our guide to power purchase agreements for Texas businesses covers the structures involved.
Gas curtailment happens when a Texas gas utility can't serve every firm customer, and a Railroad Commission rule sets the order in which deliveries are cut. It is covered under interruptible service below.
What Is a Rolling Blackout? Load Shedding Defined
Load shedding is deliberately disconnecting customer load so supply and demand stay balanced and the grid avoids an uncontrolled, system-wide collapse. A rolling blackout is load shedding that rotates: the utility switches blocks of circuits off and back on so no single area carries the whole outage.
ERCOT's term is controlled outages. Its 2026 Energy Emergency Alert Overview describes them as "ordered by ERCOT but implemented by transmission and distribution service providers," and used "as a last resort."
If you searched "what is loadshedding," you may have seen South Africa, where loadshedding has been rotated through published area schedules. Texas has no standing schedule. ERCOT orders firm load shed only after it declares Energy Emergency Alert Level 3, described below.
There is also no standard length for a Texas rotation. Each utility sets durations in its own plan, and ERCOT's overview notes that ERCOT "does not have oversight into these outage plans." Be wary of any source that promises outages of a fixed number of minutes.
How ERCOT Gets From a Tight Grid to Controlled Outages
ERCOT tracks a real-time measure of reserve capacity that can respond quickly, called Physical Responsive Capability (PRC). As PRC falls, the ERCOT Nodal Protocols (Section 6.5.9.4, version effective August 28, 2026) walk the grid through a fixed sequence:
- Watch: PRC below 3,000 MW. ERCOT may deploy Emergency Response Service.
- EEA Level 1: PRC below 2,500 MW and not expected to recover within 30 minutes.
- EEA Level 2: PRC below 2,000 MW, or a sustained low-frequency trigger. TDU load management programs and Load Resources are deployed.
- EEA Level 3: PRC can't be held above 1,500 MW, or frequency triggers are met. ERCOT directs utilities to shed firm load.
Before an Emergency: Notices and a Watch
Most tight days never reach an emergency. ERCOT's public notice system, TXANS, issues a Weather Watch about three to five days ahead of weather that could strain the grid, then a Voluntary Conservation Notice or a Conservation Appeal if conditions tighten. Inside the control room, the Protocols provide for a Watch when PRC falls below 3,000 MW. If PRC stays below 3,000 MW and isn't projected to recover within 30 minutes after Non-Spinning Reserve is deployed, ERCOT may deploy Emergency Response Service (Protocols §6.5.9.4.1).
EEA Level 1
ERCOT declares EEA1 when PRC falls below 2,500 MW and isn't projected to recover within 30 minutes. It brings on all available generation, uses imports over the DC ties that connect ERCOT to neighboring grids, and deploys any ERS-10 and ERS-30 not already called (Protocols §6.5.9.4.2(1)).
EEA Level 2
ERCOT will declare EEA2 when PRC falls below 2,000 MW, and may declare it when grid frequency averages below 59.91 Hz for 15 consecutive minutes. Its tools at this level are distribution voltage reduction, instructions to utilities to run their load management programs, deployment of Load Resources that provide reserve services, and a public conservation appeal (Protocols §6.5.9.4.2(2)). ERCOT's EEA Overview gives planning estimates of up to 1,000 MW from Load Resources, 70–300 MW from TDU load management and 1,200–1,300 MW from voltage reduction.
EEA Level 3: Firm Load Shed
ERCOT will declare EEA3 when PRC can't be maintained above 1,500 MW, or when frequency averages below 59.91 Hz for 25 consecutive minutes. It may declare at 20 minutes or when steady-state frequency falls below 59.8 Hz, and it must declare immediately below 59.5 Hz. At this level ERCOT directs every transmission operator to shed firm load in 100 MW blocks, enough to restore frequency to 59.91 Hz and recover 1,500 MW of PRC within 30 minutes (Protocols §6.5.9.4 and §6.5.9.4.2(3)).
A note on older sources: ERCOT's own September 2023 release gave 1,750 MW for EEA2, and a lot of web coverage still says load shed begins at 1,000 MW. The thresholds in this article come from the Protocols in effect in August 2026.
Who Decides Whether Your Building Goes Dark
ERCOT decides how much load to shed. It doesn't pick buildings. Each utility's share of a load-shed order is based on its previous year's peak load, reviewed every year (Protocols §6.5.9.4(9)). The utility then decides which feeders to open. For a business in a competitive area, that is your TDU: CenterPoint, Oncor, AEP Texas, TNMP or Lubbock Power & Light. ERCOT's EEA Overview describes the same split.
Your REP has no part in that decision, and neither does your supply contract. Utilities must keep a load shed annex in their emergency operations plans. It covers procedures for controlled load shedding, priorities for restoring shed load, and a registry of critical load customers updated at least once a year (16 TAC §25.53). If the difference between your REP and your utility is fuzzy, read REP vs. TDU in Texas. Businesses served by a municipal utility or a cooperative follow that utility's own load-shed and demand response plans. Our guide to deregulated energy states and Texas cities shows which areas have retail choice.
Critical Load Designation: What It Does and Doesn't Do
PUCT rule 16 TAC §25.497 sets up two designations for non-residential customers, both handled through the TDU:
- Critical Load Public Safety Customer: facilities such as hospitals, police and fire stations, and critical water and wastewater facilities.
- Critical Load Industrial Customer: an industrial customer for whom an interruption would create a dangerous or life-threatening condition on its premises.
Eligibility is worked out among the customer, the REP and the TDU, and the TDU decides if they disagree. A designated customer qualifies for notice of interruptions under the TDU's tariff. The rule is also explicit about the limit: designation "does not guarantee the uninterrupted supply of electricity."
Two related provisions sit in 16 TAC §25.52. Natural gas facilities designated as critical by the Railroad Commission are treated as critical load during an energy emergency, again without a guarantee. And utilities must give assisted living, hospice, nursing and dialysis facilities the same restoration priority as hospitals.
In practice, where your building sits on the wires matters. A business on the same feeder as a hospital may stay on during a rotation, but that is a side effect of the circuit layout, not a right, and nobody can promise it. Health care operators should ask their TDU directly about designation and notice procedures.
What Winter Storm Uri Showed About Load Shed
ERCOT has ordered controlled outages four times: 1989 (500 MW), 2006 (1,000 MW), 2011 (4,000 MW) and February 15–18, 2021 (20,000 MW), according to its EEA Overview. The 2021 event, Winter Storm Uri, is the one every Texas facility plan should be tested against.
ERCOT's February 24, 2021 board presentation sets out the sequence. ERCOT entered EEA3 early on February 15 with a 1,000 MW load-shed order, which rose to 20,000 MW at the peak. Frequency stayed below 59.4 Hz for 4 minutes 23 seconds and bottomed out at 59.302 Hz. Had it stayed below 59.4 Hz for 9 minutes, more generating units would have tripped offline. At the worst point, 52,277 MW of generation capacity, 48.6% of the total, was out. ERCOT cancelled the last controlled-outage orders at 12:42 a.m. on February 18. The Texas Department of State Health Services later confirmed 246 deaths related to the storm in its final mortality report.
| ERCOT measure | February 2011 | February 2021 |
|---|---|---|
| Maximum generation forced out | 14,702 MW | 52,277 MW |
| Maximum load shed requested | 4,000 MW | 20,000 MW |
| Duration of load-shed orders | 7.5 hours | 70.5 hours |
| Lowest frequency | 59.58 Hz | 59.30 Hz |
| Estimated peak load without load shed | 59,000 MW | 76,819 MW |
Three planning lessons follow from those numbers:
- Rotation broke down at scale. When the shed volume is large and lasts for days, the rolling model stops working in practice and outages stop rotating.
- Outages can last days, not minutes. Load-shed orders ran almost ten times longer than in 2011.
- Critical systems need a plan that doesn't assume rotation. Refrigeration, process loads and water systems are the first things to plan around. See our comparison of cold storage and dry warehouse electricity for why refrigerated load can't simply be switched off.
The record since then is calmer, though that doesn't mean the risk is gone. ERCOT declared an EEA2 on September 6, 2023 and recovered without controlled outages. In its February 2026 operations update, ERCOT reported that Winter Storm Fern (January 23–27, 2026) had minimal impact on system reliability and that the grid never entered EEA Level 2. A U.S. Department of Energy emergency order issued for Fern authorized ERCOT to direct backup generators at data centers and other large industrial and commercial sites to run as a last resort before or during an EEA3. Because the grid stayed out of EEA2, ERCOT didn't need to use it. ERCOT's 2026 news releases through early September announce no Energy Emergency Alert.
Uri also caused a pricing crisis for businesses exposed to the wholesale market. Our guides to fixed vs. variable rates and index rate plans cover that side.
Voluntary Curtailment: The Ways a Business Chooses to Cut Load
Voluntary curtailment is where a business has real choices. The options differ in who you sign up with, how much notice you get, and whether the value comes as a lower bill or a payment. Most of them fall under the broad heading of demand response.
| Option | Who runs it | Notice and commitment | How value arrives |
|---|---|---|---|
| 4CP response (current rule; 12CP proposed) | You, often with a REP's 4CP alert service | No official call; you curtail on likely summer peak days | Lower transmission charges the next year, for 4CP-billed classes |
| TDU load management | Your TDU, through a project sponsor | 30 minutes' notice and a capped number of events in 2025 manuals | Per-kW incentive for verified curtailment |
| Emergency Response Service (ERS) | ERCOT, through a QSE | Contract terms four times a year; deployed before and during emergencies | ERCOT pays the QSE that represents you |
| Load Resources | ERCOT reserve markets, through a QSE | Deployed in EEA2; some trip automatically on low frequency | Reserve service revenue |
| REP demand response | Your REP, outside ERCOT's markets | Set by each program | Per-kW or per-kWh incentive under the program terms |
| SB 6 large-load service (pending) | ERCOT, under PUCT rules in progress | At least 24 hours' notice; loads of 75 MW and up | Competitively procured service |
4CP Transmission Cost Avoidance, and the 12CP Proposal
ERCOT's own demand response study, prepared by Charles River Associates for the April 2026 board meeting, found that 4CP transmission cost allocation "currently provides the strongest incentive for load reductions in ERCOT."
The rule in force today. Under 16 TAC §25.192, transmission costs are allocated using the average of ERCOT's coincident peak demand in June, July, August and September, known as 4CP. Each distribution provider pays on its previous year's 4CP, which ERCOT files by December 1 for billing the following year. At retail, TDU tariffs pass this through as a charge per 4CP kW (Oncor) or per 4CP kVA (CenterPoint), and only on larger, interval-metered (IDR) classes. The PUCT's September 1, 2026 rate reports show these charges on both utilities' interval-metered secondary, primary and transmission-level classes (Oncor; CenterPoint). Non-IDR demand classes pay transmission on their own billed demand instead.
That is why businesses curtail on hot summer afternoons. Your demand in four 15-minute system peak intervals sets a year of transmission charges. The CRA study notes that REPs in competitive areas offer 4CP advisory services to customers billed this way, while residential and small commercial customers generally pay transmission per kWh and have little individual 4CP incentive. To see how those intervals show up on a bill, read our guides to capacity vs. energy charges, heat waves and business electric bills, demand charges and kW vs. kWh. To find your own peaks in interval data, see warehouse demand charges and interval data and load factor.
The proposal, not yet adopted. Senate Bill 6 (2025) required the PUCT to evaluate whether 4CP still assigns transmission costs appropriately. On July 9, 2026 the Commission approved a proposal for publication in Project No. 58000. The proposal would replace 4CP with 12CP, built from the 12 monthly 30-minute coincident peak intervals. It would also require minimum billing demand for large load customers, update class allocation factors every year, and add a new §25.252 for large load customer tariffs. Its transition clause ties the first 12CP billing demands to the PUCT's next annual transmission charge proceeding after adoption. It does not set a date for retail TDU bills to change. Comments closed August 11, 2026, and as of September 2026 the project docket held comments but no adoption order.
| 4CP (in force) | 12CP (proposed) | |
|---|---|---|
| Months measured | June through September | All 12 months |
| Interval | 15-minute system peak interval | 30-minute |
| Large-load minimum billing demand | None | Proposed |
| Status | 16 TAC §25.192 | Proposal approved July 9, 2026; comments closed August 11, 2026 |
The practical point is that a curtailment strategy built only on four summer afternoons may not survive the rulemaking. If you are deciding now whether to invest in summer peak shaving, watch Project 58000 before you commit.
TDU Load Management Programs
TDUs run commercial load management standard offer programs, funded through energy efficiency cost recovery. Businesses agree to curtail when called, and ERCOT can request the programs before or during EEA2 or EEA3. According to the CRA study, the programs held about 290 MW of summer and 120 MW of winter capacity in 2025. ERCOT has asked TDUs to deploy them only once, during the September 6, 2023 EEA2.
The terms below come from the 2025 program-year manuals. Check the current manual before you enroll, since terms and incentives are reset each year.
- CenterPoint (summer 2025 and winter 2025–26 manual): curtail within 30 minutes of notice; at least 50 kW of curtailable load per site or meter; up to four unscheduled events of up to 4 hours plus up to two scheduled tests of 1 to 3 hours, for a maximum of 22 hours a year. Unscheduled events can be called when an EEA2 has been reached or is imminent.
- Oncor (2025 manual): 100 kW minimum and 30 minutes' notice; available around the clock from June 1 to November 30, 2025, with a 1 to 7 p.m. peak period; up to six called events of 3 to 12 hours. A participant has to curtail at least 90% of its obligation to be paid.
Both programs pay an incentive per kW of verified curtailment, set in each year's manual. Participation runs through a project sponsor, which can be the customer or a third party.
ERCOT Emergency Response Service (ERS)
ERS is ERCOT's paid emergency program for resources, such as business loads, that can cut consumption on short notice. When the PUCT adopted its rule in 2007, the service was called Emergency Interruptible Load Service, which is why "interruptible" still turns up in conversations about it. PUCT rule 16 TAC §25.507 sets the framework:
- ERCOT procures ERS to help prevent or alleviate an actual or anticipated energy emergency.
- Every ERS resource must be represented by a Qualified Scheduling Entity (QSE), and offers go through that QSE. Loads can be aggregated to reach ERCOT's minimum size.
- ERS spending is capped at $75 million in a 12-month period unless the PUCT sets otherwise, with up to $25 million more for contract renewals if ERS is exhausted.
- Deployment is limited to contracted hours, up to 24 cumulative hours per contract period.
- ERCOT pays the QSE and recovers the cost from QSEs by load ratio share.
ERCOT's ERS program page lists four standard contract terms (December–March, April–May, June–September and October–November) and two service types, ERS-10 and ERS-30. ERCOT can deploy ERS when PRC is below 3,000 MW after Non-Spin deployment and during EEA1 (Protocols §6.5.9.4.1 and §6.5.9.4.2).
The CRA study summarizes the participation rules. There is a 0.1 MW (100 kW) minimum offer, and a 15-minute interval meter is required. The obligation is up to 24 hours in the December–March term and 12 hours in the others. A resource already in another demand response program, including a TDU program, can't also offer ERS. ERS was last deployed in August–September 2023. Confirm the details against ERCOT's current ERS Technical Requirements before you offer, and don't treat past ERS clearing prices as a forecast of what your site would earn. They swing widely between terms and time periods.
Load Resources in ERCOT's Reserve Markets
Large, controllable loads can register as Load Resources and sell reserve services: Responsive Reserve, ERCOT Contingency Reserve Service or Non-Spinning Reserve. They are deployed in EEA2, and loads on under-frequency relays trip automatically. The CRA study reports 2025 qualified Load Resource capacity of 7,820 MW for Responsive Reserve, 4,113 MW for ERCOT Contingency Reserve Service and 976 MW for Non-Spin. How each of those products works is covered in ERCOT ancillary services explained.
REP Demand Response Programs
REPs also run their own commercial demand response programs, separate from ERCOT's markets. ERCOT doesn't procure or pay for them. According to the CRA study, designs vary: some pay per kW, some per kWh, some give advance notice of events, and some make participation in each event voluntary. Before you enroll, ask whether the program conflicts with an ERS or TDU program you are already in or considering.
Interruptible Service
For electricity in ERCOT's competitive areas, "interruptible" mostly describes a program status, not a rate you pick from a menu. You become an interruptible customer by agreeing to be curtailed ahead of others in exchange for a payment or a lower cost, through ERS, a Load Resource registration, a TDU load management program or a REP program. If a salesperson offers an "interruptible rate," ask exactly which program or contract term is meant and who can call the curtailment.
For natural gas, the term has a legal definition. Railroad Commission rule 16 TAC §7.455, effective September 1, 2022, defines interruptible service as natural gas deliveries "not described as firm under a contract or tariff." A gas utility interrupts interruptible deliveries before it reduces any firm customer. If it then has to curtail firm service, it applies this priority list in descending order, so the lowest tiers are cut first:
- Human needs customers, and local distribution systems serving them
- Electric generation facilities
- Industrial and commercial users that need a minimum amount of gas to prevent physical harm or for critical safety, when no alternate fuel is available
- Small industrial and commercial loads using less than 3,000 Mcf per day
- Large industrial and commercial users of gas for fuel or raw material with no alternate, whose operations would shut down
- Large industrial and commercial users of gas for fuel or raw material with an alternate, whose operations would shut down
- All other firm customers
Interruptible deliveries sit outside that firm list entirely. If your gas supply agreement or your utility's tariff doesn't describe your service as firm, plan for it to be among the first cut. Our guides to commercial natural gas rates, the winter 2026–27 gas outlook and reading a commercial gas meter cover the rest of the gas side.
Very Large and Transmission-Voltage Sites: SB 6 Curtailment Rules
Most businesses are far below this size, but data centers and heavy industrial sites should know that Senate Bill 6, enacted in 2025, added three curtailment provisions to PURA:
- Utilities serving transmission-voltage customers interconnected after December 31, 2025 must have a protocol, including any needed equipment, so that load can be curtailed during firm load shed (§39.170(a)). Critical load industrial customers and critical natural gas facilities are excluded.
- ERCOT must develop a competitively procured demand-reduction service for loads of 75 MW and up, with at least 24 hours' notice (§39.170(b)). Price-responsive loads and loads already in another reliability or ancillary service can't take part.
- Large loads covered by the 75 MW interconnection standards whose on-site backup generation can serve at least 50% of their demand can be directed to run it or curtail once ERCOT has deployed all available market services except frequency-responsive ones (§37.0561(e)).
ERCOT's May 2026 legislative status update listed the demand-reduction service as in progress under PUCT Project No. 58482, and its work on the transmission-voltage curtailment protocol as waiting on PUCT direction. Treat both as pending.
How Your Electricity Contract Interacts With Curtailment
This is where a broker's review is useful. A contract can't keep your lights on during an EEA3, but it does decide what an emergency costs you and who benefits when you curtail.
Load Shed Treats Fixed and Index Contracts the Same
Your TDU picks feeders during an emergency, and supply contract type isn't part of that choice. A fixed-price account and an index account on the same circuit go dark together.
Index and Real-Time Exposure During Emergencies
The price side is different. When ERCOT deploys ERS or Load Resources, or directs firm load shed in EEA3, the Protocols apply a Real-Time Reliability Deployment Price Adder. During EEA3 firm load shed, that adder is set so real-time prices reflect the value of lost load used in ERCOT's ancillary service demand curves (Protocols §6.5.7.3.1). Those demand curves are part of real-time co-optimization, which went live on December 5, 2025.
So a business whose supply price floats with real-time prices faces the highest prices at exactly the moment outages are happening. A fixed-price customer is shielded on the energy line, subject to its contract's terms. Read index rate plans for Texas businesses and hedging electricity price volatility before you take on that exposure. ERCOT LMP explained covers how real-time prices are formed, and our ERCOT market explainer covers the market as a whole.
Transmission Charges: Passed Through or Bundled?
If your contract passes TDU charges through at cost, any 4CP reduction you achieve shows up on your bill, and so would a future 12CP reduction. If transmission is bundled into a single price, ask how the REP treats a lower 4CP and whether any of the reduction reaches you. Practice varies by REP and contract, so get the answer in writing. Our guide to Texas TDU delivery charges explains what sits on that side of the bill.
Who Keeps the Demand Response Value?
Before you enroll in any program, put these questions to your REP, your QSE and the program sponsor:
- Does my supply agreement restrict demand response participation, or require notice to the REP?
- Do the ERS, TDU and REP programs I'm considering exclude each other?
- Could curtailment events push my usage outside a usage band or swing tolerance in my contract?
- If a REP program pays for curtailment, how is that payment split and credited?
Force Majeure and Outages
Contracts treat grid emergencies and outages differently in their force majeure and material-change clauses. Review those clauses with counsel before you rely on them. This article is general procurement information, not legal advice.
A Curtailment Plan for a Texas Business: Checklist
- Get the notices. Sign up for ERCOT's TXANS alerts and your TDU's outage notifications.
- Ask about critical load status. Ask your TDU whether your site qualifies for a critical load designation, and plan as though it guarantees nothing, because it doesn't.
- Rank your loads. Sort equipment into must-run, can-cycle and can-drop tiers. Refrigeration in warehouses and cold storage, convenience stores and food and beverage operations usually lands in the first tier. So do life-safety systems in health care and guest-facing systems in hotels. Industrial and oil and gas sites often have process loads that can be scheduled.
- Confirm your billing class. Check whether your account is interval-metered (IDR) and billed on 4CP. Our guides to reading a commercial electric meter and getting a new or smart commercial meter explain what to look for.
- Pull 15-minute interval data. You need your ESI ID to request it, and a broker needs your written authorization. See the ESI ID lookup guide and what an LOA means.
- Compare programs. Weigh TDU load management, ERS through a QSE and REP demand response, and check which exclude each other.
- Watch Project 58000. Wait for the 12CP decision before committing to a multi-year strategy built only on summer peaks.
- Review your contract exposure. Know how much of your supply price follows real-time prices, and how transmission charges are passed through.
Frequently Asked Questions
What is curtailment in electricity?
Curtailment is a deliberate reduction in electricity use or output to keep the grid balanced. For a business it means cutting load, either involuntarily in a controlled outage or voluntarily through a program or to lower transmission charges. For wind and solar plants it means output the grid cuts back, often because of transmission limits.
What is a rolling blackout in Texas?
A rolling blackout, which ERCOT calls a controlled outage, is a deliberate interruption of customer load during a grid emergency. ERCOT orders it only in Energy Emergency Alert Level 3, and your transmission and distribution utility decides which circuits go out and rotates them. ERCOT has ordered controlled outages four times: in 1989, 2006, 2011 and February 2021.
What is load shedding?
Load shedding is deliberately disconnecting customer load so supply and demand stay balanced and the grid avoids an uncontrolled collapse. In South Africa, loadshedding has been rotated through published area schedules. Texas has no standing schedule: ERCOT orders firm load shed only after it declares an EEA Level 3.
What triggers rolling blackouts in ERCOT?
Under the ERCOT Protocols in effect in August 2026, ERCOT declares EEA Level 3 and directs utilities to shed firm load when its reserve measure, Physical Responsive Capability, cannot be held above 1,500 MW, or when grid frequency averages below 59.91 Hz for 25 consecutive minutes. It must declare immediately if frequency falls below 59.5 Hz. Sources that cite 1,000 MW are out of date.
Can my business be exempt from rolling blackouts?
Almost never. Hospitals, public-safety facilities and sites where an outage would create a dangerous condition can be designated as critical load through their TDU, which qualifies them for notice of interruptions. PUCT rule §25.497 says the designation does not guarantee the uninterrupted supply of electricity, and your supply contract plays no part in the utility's load shed decision.
What is interruptible service?
It is service you agree can be cut ahead of firm service. In ERCOT's competitive areas, a business usually becomes interruptible by enrolling in a program such as ERCOT's Emergency Response Service or a TDU load management program. For natural gas, Railroad Commission rule 16 TAC §7.455 defines interruptible service as deliveries not described as firm under a contract or tariff, and those deliveries sit outside the firm curtailment priority list.
Does a fixed-rate contract protect me during a grid emergency?
It protects your energy price, not your power. Neither a fixed nor an index supply contract changes whether your utility sheds your load. Customers whose supply price follows real-time prices face reliability price adders when ERCOT deploys emergency programs or sheds firm load, so emergency price exposure is a contract question worth asking before you sign.
Is ERCOT changing 4CP?
Possibly. On July 9, 2026 the PUCT approved a proposal in Project No. 58000 to replace 4CP with a 12 coincident peak method measured on 30-minute intervals. Comments closed August 11, 2026. As of September 2026 no rule had been adopted, so 4CP under PUCT rule §25.192 is still the rule in force.
The Bottom Line
Curtailment has two faces for a Texas business. Involuntary load shed is ERCOT's last resort, carried out by your TDU, and no contract or designation guarantees you stay on. That calls for an operations plan. Voluntary curtailment, through 4CP response, TDU programs, ERS or REP demand response, is a set of choices, each with its own notice, obligations and value. Your supply contract sits between the two. It decides how exposed you are to emergency prices and whether the savings from curtailing actually reach you.
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