▶️4 - PGRR120 – SSO Prevention for Generator Interconnection
AEP and Lone Star discussed the PGRR120 with an emphasis on the grandfathering date, moving towards a 04/01/2026 date.
AEP's original suggestion was 01/01/2026, but discussions leaned towards adjusting this date to allow more flexibility.
AEP acknowledged that Lone Star's project list was more extensive, affecting their preference for the date.
AEP and Lone Star reached a consensus on accepting ERCOT's comments and proposed a tabletop edit for the date.
Lone Star expressed concern about projects affected by increased expenses, seeking exemptions for some projects, pending further legal discussion.
Consensus was reached to conduct a desktop edit to update the date to 04/01/2026 and plan to move forward with the edits before the ROS meeting.
Stakeholder feedback emphasized the importance of filing comments to ensure a clear paper trail through the approval process.
Kristin Cook from Southern Power expressed satisfaction with the language of PGRR120 and acknowledged NPRR1280 as a potential mitigation strategy.
Plans were made for NPRR1280 to be discussed in an upcoming PLWG meeting.
▶️5 - PGRR122 – Reliability Performance Criteria for Loss of Load
John Ross Hubbard from TIEC highlighted concerns about codifying system limitations without clarity on outcomes if triggered, fearing a moratorium on interconnections.
TIEC is particularly worried about the impact on regions like the Permian Basin due to unexpected load growth and modeling uncertainties.
There is a suggestion for ERCOT to publish modeling parameters to assist developers in designing compliant facilities.
TIEC suggests requiring Transmission Service Providers to offer potential transmission solutions for triggered load loss limits.
Jeff Billo clarified that PGRR122 wouldn't create a moratorium on interconnections; operational decisions would determine this.
There was a discussion on loads without ride-through capability and their impact on the 2,600 MW limit.
Jeff Billo mentioned previous attempts at setting a standard large load voltage ride-through requirement received pushback.
John Hubbard emphasized the need to codify what ERCOT's modeling tests for clearer developer guidelines rather than impose requirements on large loads.
Concerns were expressed about functional moratorium due to modeling requirements yet Jeff stated ERCOT aims to ensure respectful adherence to system operating limits.
Ken Donohoo highlighted differences in load characteristics like oil and gas versus AC loads across Texas, affecting voltage issues.
Ken and Jeff discussed past voltage events and the impact of synchronous condensers and future 765 voltage support.
Clayton Stice asked about progress on creating a load commissioning plan, which Agee Springer indicated was in development.
Discussion on commissioning plans factoring in max load and load ramp schedules to ensure compliance over time.
If a problem creates system risk, shutting down the load is the only operational solution, representing significant financial impact.
Entities connecting to the grid need to be aware of potential issues in advance and work towards resolving them.
Shedding load is considered a last resort; alternative solutions are being explored.
Assumptions are being made in studies about loads tripping off based on the ITIC curve; alternatives exist if better performance settings are identified.
A large load working group report is expected by June or July to discuss alternative solutions.
There are regulatory challenges with implementing battery solutions on the grid side; load side batteries are considered an option for loads to solve issues independently.
Concerns were raised about implementing operating limits instead of a moratorium on interconnections.
ERCOT needs a mechanism to decide which loads to shut off without straightforward solutions in operational limits.
Studies are underway to identify which loads cause problems, but ERCOT is not yet at the operational point of shutting loads off.
The discussion includes the treatment of voltage-sensitive loads and consequential load loss in relation to limits.
The limitations imposed by PGRR122 have broader implications, including potential delays for new connections awaiting transmission upgrades.
Further comments and consensus are required before progressing to the board with PGRR122.
ERCOT aims for identification of issues in the large load interconnection study rather than during operations to avoid disruptive load shedding or moratoriums.
PGRR122, as a part of addressing loss of load issues, is a step within larger planning and operational strategies.
Low confidence in current dynamic modeling of load demands; efforts are underway to improve these models.
Conservative assumptions are currently applied to operations due to limitations in dynamic modeling.
The issue of consequential load loss is discussed, particularly for loads sensitive to voltage with less than three tie lines, affecting interconnection limits.
There is a need for future revisions to consider voltage sensitivity more comprehensively and possibly amend rules to support interconnection projects.
Discussion on how draft rules potentially impact future projects, and recommendation for re-evaluation of studies by Load Customers for operational impacts.
Clarification sought on which interconnection studies would fall under new rules; confirmation that specific studies like SSO analysis may not be necessary.
Operational limitation considerations might focus on load ride-through characteristics.
Discussion on the Permian region's future load interconnections and potential voltage ride-through standards.
Holistic approach needed for long-term solutions, involving transmission options and possibly market-based solutions like battery energy storage.
Emphasis on being cautious with predictions about future changes.
▶️6 - NPRR1272 – Voltage Support at Private Use Networks
Melissa Trevino with Occidental commented that there were no formal comments seen initially.
Comments have been submitted to ERCOT and are under review by market roles.
A deep dive into the comments is underway, with plans to post them soon.
The discussion will continue at the PLWG once written comments are reviewed.
A question was raised regarding the applicability of the protocol section to future technologies such as renewables, solar facilities, SMRs, and gas-fired generators.
Further clarification from ERCOT is requested for the market to better understand how the protocol would apply to these technologies.
This item will be tabled and revisited in the next month's PLWG meeting.
▶️7 - PGRR124 - ESR Maintenance Exception to Modifications
Discussion on PGRR124 regarding ESR Maintenance Exception to Modifications is ongoing.
Eric Goff, Tesla, mentioned that discussions with ERCOT are happening.
A meeting to discuss the item further is in the process of being scheduled.
Scheduling conflicts are causing delays in having the meeting.
The item is tabled for the next month with hopes for a more in-depth discussion.
▶️8 - NPRR1274 - RPG Estimated Capital Cost Thresholds of Proposed Transmission Projects
NPRR1274 discussed adjustments to RPG tier thresholds for proposed transmission projects, last adjusted in 2017.
ERCOT proposes a 35-40% adjustment based on the Consumer Price Index (CPI) tracker; Oncor expresses concerns.
Oncor argues CPI doesn't reflect transmission project costs due to increased construction and material costs.
Oncor recommends doubling tier thresholds again, considering significant cost increases in recent years.
Specific facility costs for Oncor projects have increased by 90-100% in the last five years.
Consideration of the increased frequency of ERCOT reviews for straightforward upgrades due to cost changes.
Proposed changes by Oncor include moving tier one threshold from 100 million to 200 million.
Joint TSP owners, including CenterPoint, support Oncor's view and submitted additional analysis.
Jim Lee from CenterPoint highlights substantial increased costs from temporary construction methods and other factors.
ERCOT acknowledges the conversation started by CPI adjustments and plans to further review the comments.
TSP owners express willingness to collaborate with ERCOT for more accurate threshold adjustments.
ERCOT intends to reach out to commenters for more project-specific information before filing additional comments.
The NPRR decision is tabled to the next meeting, pending further discussion and ERCOT's review of comments.
ERCOT provided an update on the definition of qualified changes required by the new standard FAC-002-4, effective from January 1, 2024.
The aim is to align qualified changes with existing ERCOT processes to avoid increasing stakeholder burdens.
Formal processes for generation and transmission already exist; end-user facility changes were based on interim large load interconnection processes.
With the approval of PGRR115 by the PUC, ERCOT plans to update its qualified change definition for end-user facilities.
PGRR115 will become effective on July 1, with Agee Springer's team sending out market notices before implementation.
The goal is to align the effective date of qualified changes for end-user facilities with the PGRR115 requirements.
Updates to the current qualified change definition involved replacing interim process language with new language in planning guide section 9.2.1, paragraphs b and c.
There was a discussion on the implementation schedule for PGRR115, with further details to be unboxed by June 1 and fully effective by July 1.
Monica Jha from Vistra raised questions about defining 'material change,' which ERCOT agreed to consider within the context of developing a large load interconnection handbook.
A market notice related to these changes is expected to be released soon, by June 1.
The discussion concluded with thanks and confirmation of the next meeting date as June 17.
