# Texas Energy Fund ledger audit

Checked October 30, 2026 against the saved current [PUCT program table](https://www.puc.texas.gov/industry/electric/business/texas-energy-fund/), the separate governor announcements, SEC disclosures, executed NRG exhibits, and statutory text cited in the research memo.

## Inventory and arithmetic

| Check | Result |
|---|---|
| Executed-loan inventory | All nine official rows included; all nine MW figures match. No pending application included. |
| Loan capacity | 5,446 MW. Only 916 MW is listed as operating by the cutoff; the remaining 4,530 MW is planned. |
| Commitment total precision | PUCT's rounded summary rows sum to $4,104.3m. Using the Pin Oak governor announcement's $278.3m rather than the summary table's $278m produces the ledger's $4,104.6m. Both should be described as approximately $4.1bn. |
| Exact amount versus announcement | Cedar Bayou's executed $561,901,530 is stored separately from its $562m announcement. TH Wharton's later grant release specifies $215.56m, versus its rounded $216m loan announcement. |
| Big Three grouping | NRG's three loans plus Constellation/Calpine and Vistra: 2,952 MW, 54.2%; $2,009.6m announced commitments, 49.0%. Outside these three: 51.0% of dollars. |
| Customer-owned sponsors | Kerrville plus Rayburn: 692 MW, 12.7%; $516m, 12.6%. |
| Outstanding borrowings | $1.463bn is the sum for **six projects at June 30, 2026**. It is not the amount drawn across all nine loans as of October 30. Missing draws remain blank. |
| Completion grants | All five official rows match: 1,438 MW and $172.56m maximum conditional future payments. |
| Loan/grant overlap | Pin Oak and TH Wharton overlap by 916 MW. Unique capacity across the two programs is 5,968 MW, not 6,884 MW. |
| Loan versus grant accounting | Principal commitments and maximum bonus grants are not added and labeled taxpayer expense. State loans create financial assets; concession value, expected default loss and contingent grants are separate measures. |
| CPV accounting discount | $318m par minus $207m carrying value = $111m. The separate $209m fair-value disclosure is not the carrying-value number used in that subtraction. |
| Pending queue | Three applications / 1,781 MW in the current official aggregate. Project names reconstructed separately. Historical project MW sum to 1,711 MW and are not silently substituted for the current figure. |

## Source and interpretation checks

- **Chronology:** authorization in 2023; first agreement signed June 25, 2025. Announcement dates are not silently treated as contract dates. Pecos's exact signing date remains blank.
- **Recourse:** Vistra's current SEC filing explicitly describes non-recourse debt; NRG's debt table classifies its loans as recourse. The executed Cedar Bayou guaranty contains a specific pre-completion contribution exception, preserved in the memo.
- **Collateral:** the linked PUCT rule PDF is dated 2024. SB2268's 2025 amendment expressly permits municipal/cooperative parity debt and broader system collateral. Actual Rayburn and Kerrville instruments remain unreviewed.
- **Leveraged equity:** CPV's Bank Leumi borrowing, KPUB's revenue bonds and Continental's Mercuria note are separate documented sources of the non-TEF financing. Sponsor borrowing does not remove the state's project-level equity cushion or automatically give the other lender priority over the state.
- **Pecos ownership:** Continental's Q3 report filed October 30, 2026 verifies a 50% economic and non-controlling JV interest, $224.1m contributed by September 30, a $257.8m capital commitment and $150m partner note. Mercuria's full beneficial chain and the precise intervening entity chain remain unresolved.
- **Capacity definitions:** PUCT announced capacities are used consistently within the TEF denominator. They are not mixed with NRG's net/summer measures, nameplate generator sums, or ERCOT seasonal capability.
- **Additionality:** the existence of a loan does not establish that the plant would not otherwise have been built. Reimbursement of prior costs is permitted. The pending New Gulf letter shows cheap capital can coexist with an unresolved revenue-contract problem.
- **Completeness:** the executed-loan list is exhaustive against the official current table. The guarantee/beneficial-owner investigation is not complete for every row; explicit missing fields and evidence notes preserve that boundary.