For the past three years, Texas has been in the midst of a bitcoin-mining gold rush. Bitcoin is a digital currency that relies on data centers to verify transactions in a decentralized manner.  The verification process consumes a significant amount of electricity. While early bitcoin miners relied on residential power supply to run mining algorithms on personal computers, modern bitcoin mines are large industrial facilities with peak demands as high as 450 MW. 

Citing environmental and security concerns, regulators in China, Quebec, and New York, have imposed restrictions on bitcoin mining, making Texas, with its deregulated energy markets, an attractive jurisdiction for relocating bitcoin miners. Particularly as Texas allows Large Flexible Loads (“LFLs”) (such as bitcoin miners) to participate as load resources on the ERCOT Grid to participate in ERCOT’s energy and ancillary service markets. Thus, a bitcoin mine can receive payments from ERCOT for turning off (i.e., reducing load) during periods of high demand or grid instability. 

Despite the price of bitcoin retreating from its 2021 high, the number of bitcoin mines proposed in ERCOT continues to grow. As of January 2023, 38,143 MW of LFSs are in ERCOT’s interconnection queue, the majority of which are bitcoin mines. In comparison, the ERCOT’s current peak load is only 80,038 MW. While only a fraction of the planned bitcoin mines will likely come to fruition, they will still significantly change the ERCOT’s load profile. Integrating these miners into the ERCOT system has also proved logistically difficult for several reasons. 

First, there is a limited amount of transmission capacity within ERCOT. Concerned about the amount transmission capacity available to serve the new projects, ERCOT has created an interim LFL interconnection process. Transmission Service Providers (“TSPs”) must submit interconnection studies to ERCOT before interconnecting loads that are 75 MW or greater (or 20 MW or greater if co-located with a generation resource). ERCOT reviews the studies for compliance with the North American Reliability Corporation (“NERC”) standards and allocates existing transmission capacity based on the results of its review. Thus, a bitcoin miner applying for a 500 MW project might only receive approval to interconnect 100 MW of load and would be required to wait to interconnect the remaining 400 MW until additional transmission capacity is constructed.

Bitcoin mining is currently a low-margin industry. When power prices rise, bitcoin mining quickly becomes uneconomic, which should incentivize bitcoin miners to curtail power consumption during periods of high prices. However, there is concern that some miners may not fully respond to these economic price signals and contribute to scarcity conditions. 

In 2022, ERCOT established the Large Flexible Load Task Force ("LFLTF") to evaluate modeling, nodal pricing, primary frequency response, and under-frequency load shedding issues associated with the integration of large loads on the ERCOT System. The LFLTF also serves as a forum for ERCOT and market participants to design a permanent process for the interconnection of large loads and explore methods to help ensure that bitcoin miners will not exacerbate grid conditions during periods of insufficient generation. We expect 2023 will continue to see significant growth in both the ERCOT-based bitcoin mining and the continued development of bitcoin mining-related energy regulations.

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