Austin Rosel presented the background on the current protocol language of NPRR1190.
NPRR1190 modifies existing policy set by NPRR649, originally put in place to compensate QSEs for losses from high dispatch limit (HDL) overrides.
The policy originated from a PUC case involving Odessa and subsequent settlement with ERCOT.
NPRR649, initially called the "lost opportunity payment," was finalized in 2016 to cover financial losses due to HDL overrides.
NPRR1190 extends the coverage to municipalities and entities with both generation and load under the same QSE without requiring a DAM obligation or bilateral contract.
The TAC recommended approval of NPRR1190, but it faced opposition from the consumer segment, leading to its remand by the ERCOT Board following PUC's comments.
Discussion involved ensuring fair compensation for entities affected by HDL overrides, highlighting differences in contractual language and obligations.
Austin Energy brought this to light through an ADR process, emphasizing inconsistencies in compensating entities without paper contracts.
Eric Blakey from PEC presented a history of the NPRR proposal concerning financial loss recovery due to manual high dispatch limit overrides filed by Austin Energy and other utilities.
The proposal aimed to recover losses during reduced power output and stimulate discussions about market participation and stakeholder concerns.
Several meetings were held from September to December with stakeholders' reviews and alternative approach proposals.
Residential consumer comments suggested narrowing NPRR1190's scope for clarity.
Reliant proposed edits to include QSEs in the scope, highlighting burdensome proof of contract issues.
Financial harm through ERCOT's overrides was regularly discussed, focusing on limiting excessive use while considering cost relief.
Discussions about payment alternatives and consideration of NPRR1190 led to a vote with some opposing votes from consumers and abstentions.
There were multiple instances of abstention and opposition from consumer segments and other stakeholders during the approval process.
Impact analysis indicated no significant financial or budget implications from the proposal.
Discussions continued up to October with consumers expressing concerns about eligibility expansion to various entities without contracts.
The proposal and its numerous meetings and discussions were acknowledged as valuable for informing TAC and board decisions.
No significant financial impact was noted historically, however, instances like Winter Storm Uri were cited as potential concerns.
Opposition to NPRR1190 due to it being inconsistent with nodal market principles and rewarding over scheduling that leads to consumer subsidies for inefficient hedging.
ERCOT market's adoption of nodal dispatch aimed to prevent paying for undelivered scheduled power, emphasizing fairness and risk of delivery on market participants.
Discussion on confidentiality issues with transmission system information that affect generator operations and potential penalties.
Concerns over frequent occurrences of side payments to generators for reliability dispatches, aiming to make price the primary motivation for actions.
Clarifications sought on the concept of 'over scheduling' and its impact on pricing and power delivery.
Debate over HDL override payments, justified as necessary for reliability constraints that SCED cannot manage.
Issues regarding the expandability of current protocols to better reflect system pricing challenges.
Calls to avoid expanding side payments that could undermine market efficiency, emphasizing necessary preplanning for contingencies.
5 - Review of Revision Request Summary/ERCOT Market Impact Statement/Opinions - Ann Boren/ IMM
Summary update on NPRR1247, with an outlined schedule for ROS and PRS endorsements to hit the December board meeting as requested by commission and ERCOT.
6.1 - NPRR1180, Inclusion of Forecasted Load in Planning Analyses
Motion to table NPRR1180 added to the combo ballot.
IA between $2M and $2.4M
NPRR1180 is sponsored by Oncor and involves revisions to commission rules on certification criteria.
On September 12, PRS voted to recommend approval of NPRR1180 with amendments from the August 28 comments, with two abstentions.
On October 17, it was unanimously voted to endorse and forward to TAC the September 12 PRS report and the October 16 IA .
Discussion occurred regarding the high costs and FTE requirements cited by ERCOT, leading to a revised IA for TAC consideration.
Additional TCPA comments were also noted.
The related agenda item involves publication of shift factors for active transmission constraints, recommended for approval by PRS on September 12 and endorsed on October 17.
Discussion on NPRR1180 with revisions and stakeholder comments, especially regarding staffing and related legislation.
Concerns raised about additional costs already being incurred by ERCOT, which were addressed in a revised document.
Mention of the need for transparent criteria for forecasting and planning related to large load growth to prevent unnecessary transmission build-out.
Request to table NPRR1180 is set for the combo ballot after extensive discussion and multiple participant inputs.
6.2 - NPRR1245, Additional Clarifying Revisions to Real-Time Co-Optimization
Motion to recommend approval of NPRR1245 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
No impact IA
Proposal to put NPRR1245 into consideration.
Focus on clarifying revisions related to Real-Time Co-Optimization.
6.3 - NPRR1248, Correction to NPRR1197, Optional Exclusion of Load from Netting at EPS Metering Facilities which Include Resources
Motion to recommend approval of NPRR1248 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
No impact IA
Discussion on NPRR1248 which addresses corrections to the previous NPRR1197.
Focus on the optional exclusion of load from netting at EPS (Electric Power Supply) metering facilities that include resources.
Clarification on how this correction impacts current metering practices and requirements.
Considerations for implementing these corrections to ensure accurate data representation at metering facilities.
Potential implications for resource operators and how they integrate with ERCOT’s systems.
6.4 - NPRR1249, Publication of Shift Factors for All Active Transmission Constraints in the RTM
Motion to recommend approval of NPRR1249 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
On September 12 PRS unanimously voted to recommend approval
On October 17 PRS endorsed and forwarded to TAC the September 12 PRS report and the October 15 IA with a priority of 2026 and rank of 4740.
7 - Revision Requests Tabled at TAC - Possible Vote - Caitlin Smith
Discussion on revision request tables at TAC.
7.1 - OBDRR052, Related to NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era
OBDRR052 is pending and will remain tabled.
Awaiting NPRR1246 progress for any developments on OBDRR052.
7.2 - NOGRR264, Related to NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
NOGRR264 can remain tabled.
Awaiting NPRR1235 resolution.
8 - OBDRR053, Alignment with NPRR1131, Controllable Load Resource Participation in Non-Spin, and Minor Clean-Ups - Vote - Nitika Mago
Motion to recommend approval of OBDRR053 as submitted and the 10/17/24 Impact Analysis added to the combo ballot.
OBDRR053 is a follow-up to NPRR1131, which was implemented at the end of August.
Changes are needed to the OBD to support NPRR1131's implementation.
OBDRR053 aims for alignment and is said to have no impact.
Recommendation for approval of OBDRR053 as submitted along with the October 17 impact analysis.
No objections were raised to include this item on the combo ballot.
Discussion on changes to estimate aggregate liability, collateral commitment, reporting enhancements, and regular credit updates.
Implementation of system changes in December 2024 due to NPRR1184 for managing interest received by ERCOT.
Explanation and discussion of RFAF and DFAF in relation to EAL.
Introduction of automated notification systems for letters of credit and surety bond matters.
Austin Rosel, ERCOT, expressed an opinion that CFSG is coalescing around a proposal for changes to exposure calculations; looking for support but not fully resolved.
A presentation to TAC suggested for broader discussion before implementation.
Key changes in the EAL calculation focus on netting real-time and day-ahead liabilities.
Discussion on forward adjustment factors and attempts to reduce volatility and over-collateralization during volatile market events.
The proposed framework aims to minimize collateral shortages while optimizing over-collateralization.
Concerns about higher volatility in TPEA addressed and focused on reducing overall collateral costs to the market.
Regular financial updates showed decreased market TPE and discretionary collateral from $1.88B to $1.72B August to September.
Caitlin Smith and Cory Phillips discussed improving the TAC procedure by considering a consolidated redline version of documents for easier readability.
The idea is to simplify documents by consolidating numerous redline changes into a single, coherent version, while preserving authorship recognition.
Past issues, such as with NOGRR245, involved complex and multicolored documents that were difficult to process, often requiring extensive time and effort.
Cory and Caitlin are exploring options to modify current procedures and potentially amend Section 21, allowing TAC leadership discretion to consolidate document redlines for more efficient processing.
The proposal aims to make the comment review process streamlined and user-friendly, without losing authorship clarity.
Richard Ross expressed a view that there is nothing prohibiting the use of a consolidated version. TAC's adoption makes it legitimate, and individual redlines can still be referred to if necessary.
There is room for revising Section 21 if needed, and these considerations will be addressed in upcoming NPRR discussions.
No final decisions were made, but Cory and Caitlin will continue to refine the proposal and present it in future NPRR sessions.
