Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/29/24 Revised Impact for NPRR1239 with a recommended priority of 2025 and rank of 4540 added to the combo ballot.
Costs for NPRR1239 and time requirements for project implementation were presented.
Costs to build out APIs were removed to be aligned with other ERCOT API work in 2025 for efficiency.
The initiative seeks to convert 63 reports from secure to public status.
Implementation will depend on potential impacts with RTC, with hopes to progress in parallel.
Priority was adjusted from 26 to 25, aiming for completion in 2025, with a consistent rank as both items will be handled together.
5.2 - NPRR1240, Access to Transmission Planning Information
Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/29/24 Revised Impact for NPRR1240 with a recommended priority of 2025 and rank of 4540 added to the combo ballot.
Discussion on combining NPRR1239 and NPRR1240 on the combo ballot.
Consensus reached with no objections noted.
Acknowledgment and confirmation to add items 1239 and 1240 to the meeting minutes.
5.3 - NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era*
Motion to endorse and forward to TAC the 10/17/24 PRS Report and 7/31/24 Impact Analysis for NPRR1246 added to the combo ballot.
Discussed NPRR1246 regarding Energy Storage Resource (ESR) terminology alignment.
Preparation for RTC initiative scheduled for next year.
No costs associated with the implementation.
Previous unanimous vote to recommend language approval.
Acknowledged amendments by September 20th ERCOT comments.
5.4 - NPRR1254, Modeling Deadline for Initial Submission of Resource Registration Data*
Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/2/24 Impact Analysis for NPRR1254 added to the combo ballot.
Final topic from ERCOT discussed was regarding the modeling deadline for initial submission of resource registration data.
Proposal to modify the timeline by extending it one month.
Purpose is to allow ERCOT and resource entities time to ensure submissions are error-free.
No cost or project is associated with this change.
Technology Working Group will be addressing NPRR1226.
Further discussions are expected in the next PRS meeting on NPRR1226.
6.07 - NPRR1229, Real-Time Constraint Management Plan Energy Payment
Comments were filed on NPRR1229.
Bill Barnes provided an update on agenda item 1202 and 1234.
ERCOT expressed a desire to move forward with item 1234 while continuing to address concerns with 1202.
Proposal to combine fee structures from Longhorn comments on 1202 with 1234.
ERCOT is interested in the idea of combining components from the two.
Comments have been shared with ERCOT staff regarding the potential combination.
PRS members informed about the ongoing discussion regarding the integration of components.
6.08 - NPRR1234, Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater
ERCOT filed some comments earlier in the week regarding NPRR1234.
Conversations about these comments are ongoing and expected to continue between 1202 and 1234.
6.09 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
NPRR1235 was initially tabled in June and referred to ROS and WMS.
The item remains tabled at SAWG awaiting possible PUC discussion.
The item is also still under discussion at WMS.
Recent comments were filed by Luminant for NPRR1235.
Ongoing discussions are taking place regarding NPRR1235.
6.10 - NPRR1238, Voluntary Registration of Loads with Curtailable Load Capabilities
Comments were submitted by Steel Mills regarding the definition for VECL sat the end of last month.
WMS may take action on these comments.
Further developments are anticipated in December.
6.13 - NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities
Motion to recommend approval of NPRR1243 as amended by the 10/10/24 ERCOT comments added to the combo ballot.
Oncor filed comments proposing a streamlined notification process for ERCOT disclosures to FERC, NURC, and TRE.
No new comments were filed on NPRR1243, and the committee considered moving the Oncor comments forward on a combo ballot.
There was discussion about the language concerning compliance premiums not being awarded after December 31, 2024, and the potential need for an earlier effective date.
Introduction of a new concept of a research and innovation partner by ERCOT, with suggestions to provide visibility into shared information via a website.
Oncor's initial concerns about transparency in information disclosure were addressed through a compromise solution.
A suggestion was made to strike the use of 'fax' from notification methods, aligning with modern communication practices.
Doug Fawn flagged a future NPRR to clean up standard form agreements regarding fax notification, projected for January.
6.14 - NPRR1247, Incorporation of Congestion Cost Savings Test in Economic Evaluation of Transmission Projects
Motion to grant NPRR1247 Urgent status; to recommend approval of NPRR1247 as amended by the 11/11/24 ERCOT comments; and to forward to TAC NPRR1247 and the 8/9/24 Impact Analysis carries: 86% approval 13% opposition and 4 abstentions.
NPRR1247 concerns a congestion cost savings test discussed extensively since it was filed in August.
The proposal was approved at ROS with 11 abstentions and several no votes due to contentions over protocol references.
ERCOT prefers revising the NPRR description rather than including references to two related white papers in protocol language.
A special planning group workshop and several comments have been considered in the development of NPRR1247.
Urgency is required to proceed with NPRR1247 due to its significant impact on congestion cost savings.
Matt Arthur from ERCOT filed comments on Nov 11 recommending revisions in the revision description referring to two supporting white papers.
ERCOT’s stance on white papers is that they are non-binding documents providing operational details without stakeholder approval, differing from binding protocol language.
Martha Henson expressed support for keeping NPRR1247 out of protocol references and motioned for its urgency and approval, which was seconded.
Comments were shared expressing concerns about the expedited process and potential suboptimal outcomes, including issues unresolved concerning the generation-load gap in models.
Stakeholders expressed a desire for further discussion on related white papers, which ERCOT commits to addressing in future discussions.
6.15 - NPRR1250, RPS Mandatory Program Termination
Motion to recommend approval of NPRR1250 as submitted added to the combo ballot.
The item 1250 was tabled in September and referred to WMS, which unanimously endorsed it as submitted.
Discussion was held about adding 1250 to the combat ballot.
Concerns were raised about the effective date of the RPS program termination, with some feeling it needs to be sooner.
The termination date of the RPS program is defined by HB1500, not ERCOT, and set for September 1st.
Procedural steps for NPRR were discussed, with a hope for approval before September 1st.
Concerns about confidentiality provisions not being removed before the program's termination were addressed, emphasizing the importance of not exposing information before deletion of the program.
6.15b - NPRR1250, RPS Mandatory Program Termination
Discussion on NPRR1250 regarding the termination of RPS Mandatory Program.
Reference to compliance premiums will not be awarded after December 31, 2024, as stated in NPRR1218.
NPRR1218 already includes the language regarding compliance premiums which is in force.
Clarification and confirmation that NPRR1250's language echoes NPRR1218.
Addressed concerns related to repetition of language from NPRR1218.
Explanation that NPRR1250's language modifications will be "gray boxed" until September 1, 2025.
Language about premiums expiring on December 31, 2027, is the new addition.
Consensus to proceed with NPRR1250 in a combo ballot.
6.17 - NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements
Motion to recommend approval of NPRR1252 as amended by the 11/8/24 ERCOT comments added to the combo ballot.
Acknowledgment of pending cleanup next year.
Mention of ERCOT's November 8th comments regarding this item.
Discussion on integrating NPRR1252 with the November 8th comments.
6.18 - NPRR1253, Incorporate ESR Charging Load Information into ICCP
Motion to recommend approval of NPRR1253 as amended by the 10/10/24 ERCOT comments added to the combo ballot.
WMSWG is still reviewing NPRR1253.
The item was tabled last month to allow the sponsor time to file comments.
Awaiting comments from the sponsor before proceeding.
6.19 - NPRR1255, Introduction of Mitigation of ESRs
General agreement from past discussions to not implement until after RTC.
For NPRR1255, Caitlin requested to table it due to a longer implementation outlook and agreed to provide more details by the next PRS meeting.
There is consensus to keep NPRR1255 tabled until comments are filed or comfort with ERCOT is established.
NPRR1253 was discussed within the Wholesale Market Working Group, but its official status is unclear as it is not tabled with ROS.
TIEC had questions on NPRR1253 but is now open to moving it forward as their questions were addressed.
NPRR1253 needs to be in effect by June 1, with a version of language recommended for approval.
Discussion on NPRR1253 included the October 10th ERCOT comments related to Patterson and Company's proposal, aiming to clean up references to prices and data.
Further cost analysis for NPRR1253 to be done as indicated by Mr. Whitmire.
7 - Review of Revision Request Language - Vote - Diana Coleman
Motion to table NPRR1256 and refer the issue to WMS added to the combo ballot.
Introduction of NPRR1256, concerning settlement MRA for energy storage resources.
This item is being introduced by ERCOT and it is the first time it is being discussed at PRS.
No representative from ERCOT present to speak on the proposal.
Consideration to table and refer the item for further review.
Suggestion for PRS and WMS to examine and verify the proposal.
The item relates to protocol language updates needed for energy storage resources.
Current protocols use generation resource language which needs adaptation for the integration of energy storage resources as a single model.
Potential updates to MRA language to reference generation resources or energy storage resources.
Mathematical validations required, possibly by WMS.
7.2 - NPRR1257, Limit on Amount of RRS a Resource can Provide Using Primary Frequency Response
Motion to table NPRR1257 and refer the issue to ROS added to the combo ballot.
This proposal originated from recommendations by a consultant, GE, to address the risk of common mode failure, which could lead to NERC requirements violations.
A static limit derived from studies conducted by ERCOT is proposed, with a recommended limit of 157 megawatts per resource.
The limit applies per resource and not per station, with each resource expected to have independent controls to mitigate risks from common mode failures.
There are companion NOGRR documents providing detailed application instructions for the proposed limit.
Some concerns were raised on regulatory certainty and changeability of the limit number, but these were addressed collaboratively with ERCOT.
Questions were raised regarding the application of the limit: 20% of HSL or 157 megawatts for thermal resources, and verified droop performance for batteries.
Recommendation to table this NPRR for further discussion and consideration by the ROS and PDCWG.
