Meeting Summary - 05/14/2025 PRS Meeting

▶️1 - Antitrust Admonition

▶️2 - Approval of Minutes (Vote)

• Motion to approve the April 9, 2025 PRS meeting minutes as presented added to the combo ballot.

▶️3 - TAC Update

• Approval received for all items sent to the TAC.
• Strategic objectives approved.
• Successful outcome with objectives set for the rest of the year.

▶️4 - Project Update

PRS_May_2025_Project_Update.pdf

• NPRR1253, ICCP, and public API implementation for ESR charging load information to go live in a couple of weeks.
• No changes in the 2025 release targets as they are prioritizing RTC+B.
• Four IAs to be discussed, with prioritization options to be considered.
• Discussion on aging revision request projects and prioritizing them for a post-RTC 2026 queue.
• An Excel file listing 61 items to be revisited for prioritizing revisions has been posted.
• Columns P and Q contain last year's recommendations and notes, while new updates are in Column O.
• Out of seven priority items requested for inclusion before RTC, only one has been completed due to scheduling conflicts with RTC.
• The prioritization discussion will continue next month, with a more in-depth assessment planned.
• Clarification that many projects on hold will be revisited after RTC implementation, likely in early 2026.
• The ongoing evaluation of projects and legislative priorities, such as DRRS, is emphasized.
• ERCOT participants expressed appreciation for the effort in managing and planning project priorities.

▶️5 - Urgency Vote (Possible Vote)

• Two items up for urgency vote, both with no impact and no price.
• Items originating from ERCOT.
• Discussion includes laying out the items by ERCOT and addressing comments received since the April meeting.

▶️5.1 - NPRR1282, Ancillary Service Duration under Real-Time Co-Optimization

• Motion to grant NPRR1282 Urgent status carries unanimously with 1 abstention.
• Motion to recommend approval of NPRR1282 as submitted and to forward to TAC NPRR1282 and the 4/29/25 Impact Analysis passed with 70% in favor and 30% opposed, with 2 abstentions.
• Presentation of NPRR1282 and discussion on urgency and options related to Ancillary Service Duration.
• ERCOT conducted analysis on durations of ancillary services and recommended changes: regulation and responsive reserves increased to 30 minutes, while ECRS reduced to one hour.
• Concerns about meeting NERC obligations, particularly BAL-001, in case of SCED failures.
• Discussion on past SCED failures; eight out of ten events lasted up to 30 minutes.
• ECRS duration change to one hour takes into account system variability, NERC BAL-002 standard, and solar growth.
• Non-spin reserve retains a four-hour duration. Analysis based on historical data.
• Proposal allows ERCOT to run the system during unplanned events efficiently.
• Discussions involved optimal setup for market trials with urgency for 1282 implementation.
• Participants debated implications on battery usage and system reliability.
• Concerns were raised about the impact on non-spin reserves and effective market design.
• Motion proposed for ERCOT's NPRR comments with urgency in light of market trials was widely debated.
• Consideration of potential dates for revisiting parameters and stakeholder involvement in evaluations with no definitive agreement.
• 2027 ancillary service methodology discussions will involve ongoing analysis and adjustments
• There is a debate on splitting the urgency and approval into two separate motions.
• Concerns were raised about duration parameters affecting reliability and market operations
• Discussion on optimization models and indicative pricing for real-time operations, including the limitations and potential developments.
• Acknowledgement that current protocols for market trials must be evaluated and potentially adjusted.
• Stakeholders appreciate ERCOT's willingness to revisit market methodologies, though concerns about urgency driven by software timelines persist.
• Discussion on the integration of innovative market features, such as a multi-interval real-time market, to enhance system reliability.
• Multiple participants expressed the need for ERCOT to commit to future evaluations and adjustments based on market trials.

Additional Notes

• Future market adjustments remain a priority for ERCOT with commitments to review methodologies in the future.
• The procedural handling of urgency and protocol changes required clarification during the meeting.
• Stakeholder engagement and feedback on market trial outcomes will be part of the process moving forward. 

▶️5.2 - NPRR1283, Modification of SSR Mitigation Timeline

• Motion to table NPRR1283 and refer the issue to ROS added to the combo ballot.
• NPRR1283 proposes moving the requirement for SSR study and mitigation from initial synchronization to initial energization due to identified SSR risks.
• ERCOT emphasized the urgency due to recent system events and projects nearing commissioning with SSR risks.
• Concerns were raised about the impact on project timelines, possibly delaying projects set to commission soon.
• There is debate on the balance between urgent implementation and allowing projects time to adjust.
• Some members suggested a need for further discussion on the timing and process related to SSR studies.
• A suggestion to explore early screening processes for SSR risks was mentioned.
• Concerns were expressed about the potential regulatory and market impacts if the proposal is implemented hastily.
• Members discussed the challenge of implementing changes that might affect projects eligible for state bonuses tied to completion timelines.
• The timing of planning studies and the necessity of prescreening were discussed, particularly relating to whether these issues need to be addressed within the Reliability Operating System (ROS) or are already covered in the planning guide section 5.3.1.
• The SSFR issue during the interconnection process needs to be resolved before transformer energization to prevent equipment and transmission damage.
• During commissioning, a past situation required a corrective action plan due to SSFR impacting other generators. This may set a precedent for future occurrences.
• Discussion was held around whether SSFR requirements are part of the SSO study, and how they may or may not influence project synchronization and energization.
• Concerns were raised about timing, especially for resources unable to energize if SSR studies aren't completed, which has shifted responsibility from synchronization to energization stages.
• Protocol language regarding study completion has not specified a due date, leading to potential resource delays at energization.
• There's existing risk to projects due to the timings and these changes. Shifting requirements might impact already developing projects, potentially causing project delays if not planned accordingly.
• Motion was discussed to table the proposal and refer it to ROS, due to the need for more internal discussion about its implications on planning and synchronization processes.
• Urgency and possible impacts of tabling this issue were acknowledged, considering it affects pending interconnections and overall system reliability.

▶️6 - Review PRS Reports, Impact Analyses, and Prioritization - Vote - * denotes no impact

▶️6.01 - NPRR1214, Reliability Deployment Price Adder Fix to Provide Locational Price Signals, Reduce Uplift and Risk

• Motion to table NPRR1214 added to the combo ballot.
• The joint sponsors requested to table NPRR1214 for further clarifications and discussions.
• Issues related to the emergency pricing program and the proposed language for NPRR1214 still need resolution.
• The concept of price adders is problematic as they can move in both directions, leading to discussions on binding prices from the RDPA process.
• Concerns were raised about energy indifference payments and scenarios not covered by current language.
• Discussions included the need for clarity around binding prices for ancillary services.
• NPRR1214 implementation will occur post RTC+B project, so the delay will not affect its implementation timeline.
• Revisions are intended to make the NPRR1214 clearer for implementation without affecting the intended range in the IA.
• Residential and consumer support is based on the ability for prices to increase and decrease contextually, which is being retained in revisions.
• A suggestion was made for a motion to table NPRR1214, allowing ERCOT more time to address these issues and update the language.
• Concerns were expressed about the importance of the NPRR due to indifference payments and the market's reaction to scarcity pricing.
• There's hope that the delay will not further postpone its implementation.

▶️6.02 - NPRR1226, Estimated Demand Response Data

• Motion to endorse and forward to TAC the 3/12/25 PRS Report as revised by PRS and 5/5/25 Impact Analysis for NPRR1226 with a recommended priority of 2026 and rank of 4770 added to the combo ballot.
• Agenda item NPRR1226 originates from steel mills and was tabled back in March.
• Desktop edits will be needed when proceeding with the IA.
• NPRR1226 has been filed for over a year, going through various approvals and recommended for approval without opposed votes.
• The item was approved by PRS in February, but ERCOT requested more time to conduct an IA, which is now completed.
• No recommended priority and rank initially provided; discussion suggests targeting year 2026 with a rank of 4770.
• The item will be part of the revision requests discussed in the coming months for future planning.
• ERCOT sees potential value in developing a future demand response dashboard as an internal project.
• A suggestion to include a minor desktop edit in the IA process to harmonize the paragraph structure.
• The revised PRS report would move forward with the 2026 target and rank 4770, including desktop edits.
• Consensus seems to be reached on moving NPRR1226 forward with the noted changes.

▶️6.03 - NPRR1238, Registration of Loads with Curtailable Load Capabilities

• Motion to endorse and forward to TAC the 4/9/25 PRS Report as amended by the 5/7/25 ERCOT comments and 5/13/25 Impact Analysis for NPRR1238 with a recommended priority of 2026 and rank of 4535
• Bob Wittmeyer highlighted that the intention of NPRR1238 was to utilize large flexible loads and address compliance issues for loads wanting to curtail during high-demand periods.
• Concerns about the high cost of implementation, estimated between $700,000 to $1 million, and the 10 to 14 months required for execution.
• Golden Spread Electric Cooperative emphasized the ongoing compliance issues without the implementation of NPRR1238, although they were also aware of the long timeline and high costs.
• Discussion on Senate Bill 6, which has some relevant provisions, but does not directly address all concerns or include large loads like crypto loads.
• Several stakeholders expressed the importance of implementing NPRR1238 despite costs and time, citing compliance and future economic benefits for Texas.
• A technical discussion ensued regarding real-time data and load shed tables, with multiple parties advocating for improved real-time situational awareness for ERCOT operators.
• There was support for moving forward with NPRR1238 to ensure system reliability and compliance, yet recognizing the need for further analysis and possible cost reduction.
• Conversation about the importance of immediate action to prevent further compliance issues and potential negative economic impacts.
• A motion was made to advance NPRR1238 to TAC despite the noted costs and extensive timeline, with acknowledgment of potential re-evaluation in terms of priorities and project ranking.

▶️6.04 - NPRR1267, Large Load Interconnection Status Report

• Motion to endorse and forward to TAC the 4/9/25 PRS Report and 5/13/25 Impact Analysis for NPRR1267 with a recommended priority of 2026 and rank of 4760 added to the combo ballot.
• NPRR1267 was sponsored by joint sponsors.
• IA was filed the previous day.
• ERCOT can deliver a manual approximation of the report within one to two months.
• Automating the report would take five to eight months.
• Priority and ranking for the report were discussed in the slides.
• Bill Barnes, NRG, asked about the possibility of implementing it manually sooner.
• Agreed to put the topic on the December combo agenda.

▶️6.05 - NPRR1275, Expansion of Qualifying Pipeline Definition for Firm Fuel Supply Service in Phase 3*

• ERCOT sponsored the item with no impact.
• The WMS had previously filed comments to keep the item tabled.
• No further action was required since the item is already tabled.

▶️6.06 - NPRR1276, Move OBD to Section 22 – Emergency Response Service Procurement Methodology

• Motion to endorse and forward to TAC the 4/9/25 PRS Report and 3/10/25 Impact Analysis for NPRR1276 
• NPRR1276 is brought by ERCOT.
• IA is less than 5,000.

▶️7 - Revision Requests Tabled at PRS (Possible Vote)

▶️7.07 - NPRR1264, Creation of a New Energy Attribute Certificate Program (WMS)

• ERCOT is still unsure of their position on NPRR1264.
• ERCOT intends to provide more transparency and raise awareness to the board and the commission.
• Discussion on this item is scheduled for the June board meeting.
• A reminder was given to avoid being caught off guard by the upcoming discussion.

▶️7.12 - NPRR1277, Revisions to EAL Formula (PRS)

• Motion to recommend approval of NPRR1277 as submitted added to the combo ballot
• NPRR1277 was tabled for an additional month to allow further review, but no comments have been filed.
• The language was endorsed by CFSG in December before being filed.
• The item is already tabled, but can be added to the combo ballot for further action.
• Discussion on changing 'EAL' to 'EEL' throughout the document before approval.
• General agreement to approve as submitted with the proposed change.

▶️8 - Review of Revision Request Language (Vote)

▶️8.01 - NPRR1278, Establishing Advanced Grid Support Service as an Ancillary Service

• Motion to table NPRR1278 and refer the issue to ROS and WMS added to the combo ballot.
• NPRR1278 is proposed by joint sponsors to establish an advanced grid support service through an ancillary service.
• The proposal is based on NOGRR272 and aims to implement the same reliability requirements through an ancillary service.
• The service would be implemented via a yearly RFP process managed by ERCOT, similar to a black start issue.
• It allows ERCOT to decide on requirements, such as quantity and location, which might raise market power concerns.
• The process enables integration of new technologies and designs without protocol changes.
• OWG and PCWG have discussed the proposal, but further work is needed from a reliability standpoint.
• WMS will handle the market-related discussions to determine the viability of this proposal over a mandate.
• Motion to table NPRR1278 and refer it to WMS and ROS for further discussion was supported.
• Agreement on a technology-neutral approach and support for it becoming a paid service expressed.

▶️8.02 - NPRR1279, Reinstate Enhancements to the Exceptional Fuel Cost Process

• Motion to table NPRR1279 and refer the issue to WMS added to the combo ballot.
• Andy Nguyen from Constellation introduced NPRR1279 to reinstate enhancements to the EFC process, originally passed as NPRR1177 in 2023.
• The previous NPRR1177 had a sunset date that expired at the beginning of the year, necessitating a new process for recognizing fuel costs in real-time.
• Under current protocols, there are additional contractual costs not recognized in the mitigated offer curve, leading to potential unrecoverable costs.
• The replacement with energy offer curves aims to allow resources to realize needed energy offer curves without risking mitigation.
• Constellation filed the NPRR without a sunset date to prevent a repeat of the expiration issues.
• Discussion about tabling and referring the NPRR to WMS and WMWG for further debate.
• Andy expressed a goal to have the NPRR approved by winter when resources face gas curtailment impacts.
• Eric Goff expressed appreciation for prior outreach about the NPRR and supports further discussion at WMS.
• Katie Rich with Vistra from the meeting hoped to move the NPRR forward but agreed with tabling for further discussion.

▶️8.03 - NPRR1280, Establish Process for Permanent Bypass of Series Capacitor

• Motion to table NPRR1280 and refer the issue to ROS added to the combo ballot.
• ERCOT aims to establish a process for permanently bypassing existing series capacitors.
• Currently, about 18 series capacitors are installed on major 345 kV transmission lines.
• These capacitors were initially used to improve power transfers and support voltages by reducing line impedances.
• Due to transmission upgrades, the original need for these capacitors may no longer exist.
• A formal process will allow stakeholders to comment during the RPG review process.
• Permanent bypass would save time and cost on SSO studies and mitigation plans.
• Discussion involved whether stakeholders can depreciate unused assets under current protocols.
• Concerns raised regarding the potential need for series capacitors in the future.
• Suggestions to involve ROS and potentially further discussion by other working groups.
• Some discussion on issues related to stranded assets and regulatory rate treatment.
• Direction given to table NPRR1280 and refer it to ROS for further discussion.

▶️8.04 - NPRR1281, Improvements to Alternate FFSS Resource Designation

• Motion to recommend approval of NPRR1281 as submitted added to the combo ballot.
• Blake Holt from LCRA discussed the current issue with the requirement for QSE to email ERCOT when switching from a primary to an alternate resource.
• Settlements group needs to manually adjust their system upon receiving the email to ensure correct settlements.
• Errors can occur if emails are not sent on time or contain incorrect information.
• NPRR1281 aims to modify the settlement system to automate the recognition of availability flags, reducing manual errors.
• The NPRR is expected to decrease ERCOT's processing burden with the anticipated program expansion.
• Proposed changes include notifying ERCOT of resource switches via phone calls instead of emails, enhancing operational awareness.
• A modification restricts each generation resource to be offered as an alternate for only one primary resource.
• Magie Shanks from ERCOT expressed agreement with the NPRR, emphasizing its automation benefits.
• Discussion on whether the restriction of alternate resources to one primary resource may complicate the process.

▶️9 - Notice of Withdrawal

▶️9.01 - NPRR1262, Ancillary Service Opt Out Clarification

• No PRS action needed.
• Notification that NPRR1262 is being withdrawn.
• Item discussed as awareness only.

▶️11 - Combo Ballot (Vote)

• Motion to approve the combined ballot as presented passed unanimously with no abstentions.

▶️12 - Adjourn

• The meeting will reconvene next month in June.