Techniques for dynamically generating a headroom voltage for an envelope tracking system. In an aspect, an initial headroom voltage is updated when a signal from a power amplifier (PA) indicates that the PA headroom is insufficient. The initial headroom voltage may be updated to an operating headroom voltage that includes the initial voltage plus a deficiency voltage plus a margin. In this manner, the operating headroom voltage may be dynamically selected to minimize power consumption while still ensuring that the PA is linear. In a further aspect, a specific exemplary embodiment of a headroom voltage generator using a counter is described.