NPRR-1337: What ERCOT’s Proposed ERS Changes Mean for Bitcoin Miners

ERCOT just filed a rule change that could reshape demand response revenue for bitcoin miners in Texas. Most operators haven’t heard about it yet.

On May 26, 2026, ERCOT filed Nodal Protocol Revision Request 1337. It hasn’t generated much industry attention yet, but it should. Roughly 52% of the current ERS portfolio is bitcoin mining, and ERS is the single highest-revenue demand response opportunity in ERCOT right now. This filing puts both of those facts in a new light.

What ERCOT is proposing

ERS requires 95% availability during contracted time periods. Bitcoin miners can hit that threshold while responding to real-time prices, curtailing whenever mining becomes unprofitable. The problem is straightforward: when ERCOT actually needs that capacity, prices are most likely high, and price-responsive loads have typically already curtailed. ERCOT ends up paying for reserves that were going to leave the grid regardless.

NPRR-1337 addresses this with a new Alternate Baseline Test that disqualifies loads whose flat baseline doesn’t fit a price-driven consumption pattern, and a shift to per-Time-Period availability scoring that eliminates the ability of strong periods to offset weak ones. The filing also references Senate Bill 6 (89R), which directs development of a separate large-load demand management service explicitly excluding price-responsive loads.

The proposal still has a long path ahead

NPRR-1337 must clear the ERCOT stakeholder process, the ERCOT board, and the Public Utility Commission of Texas. Mid-2027 is the earliest realistic implementation if it survives intact. It may be modified significantly or rejected outright. But regardless of what happens to this specific filing, the direction ERCOT is moving is the more important signal.

Ancillary services remain a substantial opportunity

Even if ERS closes to price-responsive loads, which stands to be a very controversial change, the ancillary services market stays open. Programs such as RRS, ECRS, and Non-Spin all represent meaningful revenue for flexible loads — and the biggest historical barrier to miner participation has been removed.

Day-ahead ancillary awards used to obligate loads to stay online during awarded hours, creating serious exposure when real-time prices moved against them. Most miners steered clear for exactly that reason, or gambled by only offering into hours where they anticipated pricing would settle low. ERCOT’s RTC+B implementation changed the structure entirely. Ancillary procurement now happens on every SCED run, every five minutes, in real time. Loads no longer have to stay online when prices spike; they can curtail and pay the ancillary obligation, without being penalized for having capacity offline or being stuck paying high LMPs. The hedging requirement that kept miners out of ancillaries is gone.

Proration risk and the CLR advantage

One real constraint remains in the ancillary market: proration. When more capacity is offered than ERCOT needs, every offer gets discounted proportionally. If 10 GW shows up for a 3 GW RRS procurement, awards are scaled back 70%. If a meaningful share of the 52% of ERS capacity currently held by bitcoin mining migrates into ancillaries, proration pressure across the entire pool will increase.

Currently, Controllable Load Resources (CLRs) are not subject to proration. A CLR designation places the load into the market with generators, requiring fast, precise power shifts within 5 minutes of a dispatch — ERCOT can call for 500 kW out of a 10 MW site rather than requiring a full curtailment. Coupled with RTC+B, resources can also move obligations to higher paying programs in the real-time market to capture more revenue when ERCOT’s paying a premium.  A CLR-certified site can still choose not to offer ancillaries on any given day. It preserves optionality and positions the site for the market ERCOT is building toward: flexibility first.

OBM is the only firm enabling bitcoin miners to pass CLR qualification

CLR qualification requires a demonstrated five-minute dispatch capability, rapid frequency response within 15 seconds of a deviation, real-time telemetry, and an  operational discipline that stands to challenge most mining sites, should they pursue it alone. OBM’s Foreman platform and Advanced Power Management capabilities are purpose-built for this level of control. Revolution Mining recently earned CLR designation with OBM’s support, and since, OBM has helped hundreds of MWs across multiple mining sites across Texas perform as CLRs.

What operators should be thinking about now

NPRR-1337 may or may not pass in its current form. But the policy direction is clear, and CLR qualification takes time to build toward. Bitcoin miners who want to preserve and grow their demand response revenue in ERCOT should be evaluating their options now — well ahead of any forced timeline.

OBM helps mining operators understand where they stand, qualify sites for CLR designation, and optimize participation across the ancillary services market under RTC+B. 

Operators running bitcoin mines in ERCOT who want to talk through what this means for their operation are encouraged to reach out.