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  • 00:00:36
    Good morning. This is Susie Clifton with ERCOT. Everyone is
  • 00:00:39
    going to go ahead and take their seats in here. Someone on the WebEx could
  • 00:00:43
    confirm you could hear me? Okay?
  • 00:00:47
    Yes, we can hear you.
  • 00:00:52
    Thank you. I appreciate it. All right, just quickly, the meeting reminders.
  • 00:00:56
    If you are here in the meeting room today, most of you are familiar with
  • 00:00:59
    that process. You can enter yourself into the chat, or you can
  • 00:01:03
    hold up your card. And Erin is over here in the right hand corner,
  • 00:01:06
    and she will enter you into the chat. But we are using the
  • 00:01:09
    chat to queue for motions or discussion. Please wait for the chair to
  • 00:01:13
    recognize you before you begin speaking. And when we go
  • 00:01:17
    to the ballot, if you are on the WebEx, please make sure
  • 00:01:20
    to unmute yourself as we approach your segment and
  • 00:01:23
    then to engage in mute function when you have cast
  • 00:01:27
    your vote. And that will help us be more efficient with the ballot. If you're
  • 00:01:30
    here in person today, please make sure to sign in in the
  • 00:01:34
    sign in sheet outside this meeting room door so that in order,
  • 00:01:37
    we can capture that you are here and in person.
  • 00:01:40
    Finally, if the WebEx ends for any meeting, I mean, for any reason,
  • 00:01:44
    give us just a few moments and we'll restart with the same meeting details
  • 00:01:47
    or send something to the PRS listserv. And with that,
  • 00:01:51
    Diana, we do have a quorum and are ready to get started.
  • 00:01:55
    Okay, great. Thank you, Suzy. Good afternoon, everybody.
  • 00:01:59
    Welcome to the September 12 afternoon edition
  • 00:02:02
    of the PRS. For the month, we will start
  • 00:02:06
    like we do every month, with the antitrust admonition.
  • Item 1 - Antitrust Admonition - Diana Coleman
    00:02:09
    To avoid raising concerns about antitrust liability,
  • 00:02:12
    participants in ERCOT activities should refrain from proposing any action or measure
  • 00:02:16
    that would exceed ERCOT's authority under federal or state law. For additional
  • 00:02:20
    information, stakeholders can see the statement of position on antitrust for
  • 00:02:24
    members that is located on the ERCOT website, and also, all presentations
  • 00:02:29
    and materials that are submitted by market participants or any other entity to
  • 00:02:32
    ERCOT staff for this meeting are received and posted with the acknowledgement
  • 00:02:36
    that the information will be considered public in accordance with the ERCOT website
  • 00:02:41
    management operating procedures.
  • 00:02:46
    Okay, thank you, Corey.
  • 00:02:51
    All right, so that takes us to item number two
  • Item 2 - Approval of Minutes - Vote - Diana Coleman
    00:02:54
    on our agenda. Did we have any edits or revisions to anything
  • 00:02:58
    on the August 8 minutes?
  • Item 3 - TAC Update - Diana Coleman
    00:03:02
    No. Okay. So, Corey, we can go ahead
  • 00:03:05
    and add those to our comma ballot at the end of the meeting
  • 00:03:09
    for the TAC update. Last month, we had two proposed revision
  • 00:03:13
    requests that they both approved.
  • 00:03:16
    NPRR1221 and NPRR1236 were both approved by TAC,
  • 00:03:20
    and those are on the way to the board.
  • 00:03:25
    Any questions on anything that was sent over to TAC.
  • 00:03:30
    Troy, are you flagging me? Okay.
  • 00:03:33
    All right, so that'll take us up to Troy and he will give us his
  • 00:03:37
    project update. Go ahead, Troy. Thank you, Diana. Good afternoon.
  • Item 4 - Project Update - Troy Anderson
    00:03:41
    This is Troy Anderson with ERCOT portfolio management with the
  • 00:03:44
    monthly project report. So starting with the
  • 00:03:48
    agenda, you'll see we're taking a month off of talking about aging revision
  • 00:03:52
    requests. And in its place, we'll talk about the impact analysis
  • 00:03:56
    accuracy over the past few years. But before we
  • 00:03:59
    get to that, let's go to slide three.
  • 00:04:02
    So our August release did deploy the five
  • 00:04:06
    items that we've talked about previously.
  • 00:04:09
    And our upcoming September release will be on the 26th.
  • 00:04:14
    And it's mainly around some RIOO updates relating to
  • 00:04:17
    single model. We've added the NOGRR208 on
  • 00:04:21
    here. That was part of the market notice.
  • 00:04:24
    In addition, some CDR reports are being changed
  • 00:04:28
    by a project called forecast presentation
  • 00:04:31
    platform. There was a lengthy our
  • 00:04:37
    list of these changes in the market notice that came out on,
  • 00:04:40
    I believe it was August 30. So nine
  • 00:04:44
    different CDR reports are being changed. We're adding some
  • 00:04:47
    columns and changing some field names. And that's all described
  • 00:04:50
    in the market notice. Next slide.
  • 00:04:56
    So minimal changes here, but a couple things I'd like to
  • 00:04:59
    highlight of one down at the bottom on eleven one,
  • 00:05:05
    a recent market notice came out about NPRR1205 and
  • 00:05:10
    the conclusion of that NPRR, which relates to,
  • 00:05:15
    as you see in my notes at the bottom, credit rating type information.
  • 00:05:18
    So then I backed up and looked at the first half of 1205 that went
  • 00:05:22
    live on July 1 and added it back in. And it relates
  • 00:05:26
    to credit limit percentages. So the market notices
  • 00:05:29
    are out there and between these NPRR1205 will be implemented.
  • 00:05:35
    My other note is that SCR799,
  • 00:05:40
    it's still in planning, but it's wrapping planning up and we are expecting
  • 00:05:43
    to go live with that in Q4. So as
  • 00:05:47
    I looked at the schedule, it showed a December go
  • 00:05:51
    live. Speaking with the PM, he says
  • 00:05:54
    there may be reason to be optimistic. It might even be sooner than that.
  • 00:05:57
    So I just labeled it Q4 for now, but it
  • 00:06:01
    looks pretty promising that we can get that deployed before
  • 00:06:05
    the year is out.
  • 00:06:10
    Next slide. We'll have two items for priority
  • 00:06:14
    and rank, and they both, I think, involve some discussion. So I'd like to
  • 00:06:17
    hold that until the items come up later in the agenda.
  • 00:06:23
    Next slide. TWG met on the 29th and
  • 00:06:26
    this was the agenda and discussion points. Next meeting
  • 00:06:30
    is the 26th,
  • 00:06:34
    and that takes us to our annual review
  • 00:06:38
    of IA accuracy. And I
  • 00:06:42
    know this September seems kind of late to be talking about this but as
  • 00:06:46
    you know, we've been working that aging revision request report
  • 00:06:50
    for quite some time. So I've been holding this back until that
  • 00:06:54
    reached a certain point of completion. Just a reminder
  • 00:06:58
    of what this chart says. What you see here are
  • 00:07:03
    26 projects that delivered 47
  • 00:07:08
    revision requests over the last three years.
  • 00:07:11
    And every dot on here shows where that
  • 00:07:15
    particular project landed in relation to the
  • 00:07:18
    cost range that I reported on the IAEH. If you hover
  • 00:07:22
    over that, I think, Corey, if you take us out of presentation mode,
  • 00:07:25
    if you have this pulled up every dot, if you hover over it,
  • 00:07:28
    you'll see what it relates to.
  • 00:07:31
    Plus there's an appendix on slide nine. So for
  • 00:07:35
    those viewing at home, you can. That's a shortcut
  • 00:07:39
    to find out what each dot is. When the
  • 00:07:42
    dot is on the green line, that means the cost fell within the range.
  • 00:07:48
    So, for example.
  • 00:07:52
    Well, maybe I won't bring out an example. I think it's pretty obvious.
  • 00:07:55
    Any of those that are on the line, the 14 projects, that means it fell
  • 00:07:59
    within the range. If it's above the line,
  • 00:08:02
    that means the cost exceeded the maximum of the range by whatever
  • 00:08:06
    percentage on the left on the y axis
  • 00:08:09
    shows. And if it came in under the cost
  • 00:08:13
    range, then it's the percent below the minimum.
  • 00:08:17
    So, as you see, nine of the projects succeeded.
  • 00:08:20
    Three were below and 14 hit the range.
  • 00:08:24
    So what I'd like to highlight are a couple of more significant
  • 00:08:28
    outliers. The first one, obviously,
  • 00:08:32
    is the last one, dot number 26, which is ERCOT,
  • 00:08:37
    so ERCOTitive.
  • 00:08:41
    The cost range for that was one to 1.5
  • 00:08:44
    million, and the actual cost came in at 2.4.
  • 00:08:49
    So it's exceeded the range by 930k.
  • 00:08:52
    That's 62%. And that's why that dot shows up there.
  • 00:08:56
    I did some studying of the actual costs,
  • 00:09:00
    and it was really across the board. Internal labor
  • 00:09:04
    came in almost double of what we had thought in the
  • 00:09:07
    IA, and the vendor labor came in about 70%
  • 00:09:11
    higher than we had in the IA. So we clearly
  • 00:09:15
    missed that a little bit on the low side.
  • 00:09:18
    Just a repeat one to one and a half million on the range.
  • 00:09:22
    The final cost was 2.4. We've kind of found
  • 00:09:25
    that when we're doing things that are new,
  • 00:09:30
    what we sometimes call Greenfield, we run this risk of
  • 00:09:33
    underestimating because we're not. We don't really know what we don't know.
  • 00:09:37
    So to a degree, I think that might explain
  • 00:09:40
    ERCOT. I think it was the first brand new ancillary
  • 00:09:45
    service since nodal.
  • 00:09:49
    I could take a question. Okay, Eric,
  • 00:09:55
    are these costs, inclusive of both it
  • 00:09:59
    costs as well as FTE costs.
  • 00:10:03
    These are just project deployment costs,
  • 00:10:07
    so they are not. I don't include.
  • 00:10:10
    If something requires a new person, I'm not including their salary
  • 00:10:14
    and overhead. I think one of the things that
  • 00:10:18
    people have been curious about in the past is whether or not the FTE
  • 00:10:22
    projections are also correct. When I say this, just for
  • 00:10:25
    anyone listening, in general, I think it's good for ERCOT to have as many people
  • 00:10:29
    as they need. But it is whether or not the projections are correct
  • 00:10:34
    in the IAS. Is that something that we could look into
  • 00:10:38
    as well? We absolutely can.
  • 00:10:42
    A unique factor of the FTE portion is that we have
  • 00:10:46
    a two year budget cycle. And so often, if something
  • 00:10:50
    is coming up in advance of the cycle, the affected
  • 00:10:53
    manager knows it's coming and they'll factor it in. If it comes
  • 00:10:57
    after the cycle, then we have to wait until the next cycle, in which
  • 00:11:01
    case by then, maybe they figured out how to resolve it without the new FTE.
  • 00:11:04
    That happens sometimes. So we could do some.
  • 00:11:07
    Yeah. Just curious history on that.
  • 00:11:10
    And not just to reiterate, you know,
  • 00:11:14
    you need as many people as you need. But,
  • 00:11:18
    you know, I think there's been speculation among
  • 00:11:21
    stakeholders in the past about the extent of the,
  • 00:11:24
    you know, how that works. Sure.
  • 00:11:28
    I can undergo some analysis
  • 00:11:32
    on that to bring back in the next couple months.
  • 00:11:37
    Okay. Now, an example of something that's on the low side
  • 00:11:40
    here. I've kind of picked some examples that I think are
  • 00:11:44
    maybe more interesting or something people would remember. That dot
  • 00:11:48
    number 15 is NPRR1108. That's the ERCOT
  • 00:11:52
    shall approve or deny all resource outage requests.
  • 00:11:55
    That was one that came in and we did
  • 00:11:59
    our best to turn that around quickly. And when
  • 00:12:03
    things are moving quicker, then some, often they come in under
  • 00:12:07
    the expected cost. So in that example,
  • 00:12:10
    1108.
  • 00:12:14
    Sorry. Okay. We thought it was going to be 300
  • 00:12:17
    to 400k. It came in at 173k.
  • 00:12:21
    So without it be eight to twelve months. It came in at 7.9
  • 00:12:26
    months. So we were under on both, which I think kind
  • 00:12:30
    of contribute together to the fact that we underran
  • 00:12:34
    the cost estimate. I think it's important to note
  • 00:12:37
    that the IE is an estimate. If we end up doing,
  • 00:12:41
    achieving things more quickly or efficiently, then that's what the cost is going
  • 00:12:44
    to be. We don't have
  • 00:12:48
    a connectivity from that IA to the final cost.
  • 00:12:51
    It's just a measure of accuracy on our estimation.
  • 00:12:57
    Okay. And we can always jump back, but let's
  • 00:13:00
    go ahead and look at duration. You know, over the years, I've explained how
  • 00:13:04
    duration is the more challenging of the metrics we put on the IA.
  • 00:13:08
    And historically, we've either met the mark or we've
  • 00:13:12
    missed it short. But we're seeing
  • 00:13:16
    now that we have a larger collection of things that are below. In fact,
  • 00:13:19
    more items were below the range than were above, which is quite unusual.
  • 00:13:24
    But the big outlier above is number seven.
  • 00:13:28
    Number seven is NPRR902, ERCOT,
  • 00:13:32
    critical energy infrastructure information. Now,
  • 00:13:35
    that's the one around ECEII and things,
  • 00:13:39
    you know, put in to a more access
  • 00:13:43
    limited area. On the ERCOT website. This one,
  • 00:13:50
    we thought was going to run six to nine months and it
  • 00:13:53
    ran 18 and a half months. So it missed the
  • 00:13:57
    mark quite a bit over the top. Now, part of that reason
  • 00:14:01
    is that on the IA, we thought it'd be a single deployment.
  • 00:14:05
    It ended up being a three phase delivery.
  • 00:14:08
    So that stretched things out by four months,
  • 00:14:13
    at least based on when the first deployment went in versus the last.
  • 00:14:16
    So that certainly had an impact on the duration.
  • 00:14:21
    In terms of cost, we thought it'd be 150 to 225k.
  • 00:14:25
    Came in at 282. So that was 25%
  • 00:14:29
    over. So we're finding that some of these reporting type
  • 00:14:33
    projects, while we think are pretty straightforward,
  • 00:14:37
    there's a lot of complexity in our systems
  • 00:14:41
    that end up impacting the testing and the work and the overall time
  • 00:14:45
    to deliver. Now,
  • 00:14:48
    some quick, some of the ones that are
  • 00:14:52
    under the example I pulled out
  • 00:14:55
    there, actually a couple of firm fuel.
  • 00:14:59
    That's Dot number 16, create firm fuel
  • 00:15:02
    supply service. That one, we thought it'd be nine
  • 00:15:06
    to twelve months. It came in at 7.4 months. Now,
  • 00:15:09
    that was one where we were trying to meet a target time and get
  • 00:15:13
    that deployed. And when we have found
  • 00:15:17
    that, if we. I'm not saying we drop everything, but if
  • 00:15:20
    we drop a lot of things in order to get something moving, we can beat,
  • 00:15:25
    you know, the estimates. We're not. We're usually not estimating
  • 00:15:29
    the IA with a drop everything mentality.
  • 00:15:32
    Another one that was under is NPRR1093 and
  • 00:15:36
    NPRR1101. Load resource participation in non spinning
  • 00:15:40
    reserve. That's dot number 18,
  • 00:15:44
    1093. We thought it'd be ten to 14 months
  • 00:15:48
    and that would. That's what the 1093 IA had. And the
  • 00:15:51
    NPRR1101 IA came out. I think it was three to five months, but we
  • 00:15:55
    said it'd be within the ten to 14, so we didn't add them together.
  • 00:16:00
    Ultimately, we did that in 7.6 months.
  • 00:16:03
    And I believe that was one that we were doing our best to get that
  • 00:16:06
    delivered before summer of 2022.
  • 00:16:12
    So those are some examples of some of the variations.
  • 00:16:17
    But on the duration side, ten hit the mark.
  • 00:16:21
    As I mentioned, seven were over. Nine, nine were under.
  • 00:16:25
    And it's kind of unusual that we had so many under.
  • 00:16:29
    I think that's partly reflective of prior
  • 00:16:33
    reporting that showed that we were never going under, which meant I was
  • 00:16:37
    probably estimating too far on one end of
  • 00:16:40
    the range or the other. So we've tried to adjust
  • 00:16:44
    our estimation to be more middle of the
  • 00:16:48
    road.
  • 00:16:51
    Last slide is the legend,
  • 00:16:54
    and I'm happy to take any questions.
  • 00:16:59
    Go ahead then, Troy. Thanks for putting this
  • 00:17:03
    together on both of these. I think it would be helpful
  • 00:17:08
    to have a graph line that also shows the overall under
  • 00:17:13
    overage. Each of these projects had a very different amount
  • 00:17:17
    of time or dollars associated with it. So a project
  • 00:17:21
    that comes in under budget but was only a, say,
  • 00:17:24
    a $20,000 project, and a project that comes in very
  • 00:17:27
    over but was a $2 million project,
  • 00:17:30
    there's no scale on here. So I think a line
  • 00:17:34
    graph for next year showing the overall
  • 00:17:37
    would be great to help us better understand this.
  • 00:17:41
    But I also wanted to point out on the duration one,
  • 00:17:44
    this looks like a awesome job of accuracy where our
  • 00:17:49
    cup was too far on one side, too far on the other side, and zero
  • 00:17:52
    right in. So thank you very much for your continued work on this.
  • 00:17:56
    Thank you. Thank you. Ian, would it help if I sized the dot,
  • 00:18:00
    maybe according to the project size? Would that, is that kind of what you're
  • 00:18:03
    getting at, or. I think there's whatever way you guys see fit.
  • 00:18:07
    My thought was. So on this duration one, if overall
  • 00:18:11
    you guys are x months,
  • 00:18:15
    if you take the total months that the projects took,
  • 00:18:20
    less the amount that you had forecasted, are we
  • 00:18:23
    above or below is what I'm trying to look at.
  • 00:18:27
    So I think there's ways to do it where you could show it with the
  • 00:18:29
    dots. I think there's also just adding another line
  • 00:18:34
    that kind of shows the overall amount of months.
  • 00:18:37
    Gotcha. And dollars. And I know historically the
  • 00:18:40
    y axis was number of months, and internally
  • 00:18:44
    we've kicked around. Is that more meaningful than showing a percentage? I think
  • 00:18:47
    that's kind of what you're getting at, a way to show both an
  • 00:18:51
    example on the duration.
  • 00:18:54
    Let's go to the cost. Corey, number slide seven maybe
  • 00:19:01
    actually meant duration. Well, anyway, like NOGRR195.
  • 00:19:06
    It was a. I'm sorry, I meant
  • 00:19:10
    NPRR1081. We said it was 25 to 45k.
  • 00:19:13
    It came in at 24k. You know, it was one k under.
  • 00:19:17
    So that means we missed. And I'm like, I guess that's dot number one right
  • 00:19:20
    there. So I like those misses, but you're,
  • 00:19:23
    you're right that that is materially as meaningless
  • 00:19:27
    compared to a large thing that might miss 10% and that could
  • 00:19:31
    be, you know, 300k. So now I think
  • 00:19:34
    the percentage is very good for helping us understand the accuracy,
  • 00:19:40
    but I think understanding the cumulative accuracy is also
  • 00:19:43
    needed. Gotcha. Thank you. Appreciate that feedback.
  • 00:19:48
    Thank you. Ian. Roy,
  • 00:19:54
    thanks. This is Roy Troy. I was just going to ask a little
  • 00:19:58
    bit different way of viewing this, and that would
  • 00:20:01
    be that on an annual basis,
  • 00:20:05
    you take all of these and aggregate them together and come up
  • 00:20:08
    with a value that's either plus or minus for all of
  • 00:20:12
    the projects for the year.
  • 00:20:17
    I can certainly do that. I have all the data, so. Yeah,
  • 00:20:20
    yeah, I understand. Thank you. I'm just
  • 00:20:24
    trying to understand, you know, whether we're,
  • 00:20:27
    you know, seeing a large or small underage or
  • 00:20:31
    overage of the entire year. Just.
  • 00:20:34
    I think that'd be a good point.
  • 00:20:36
    Thanks. Okay. Thank you for that,
  • 00:20:39
    Roy.
  • 00:20:42
    Cheri, we have a cleared queue, but I just wanted to ask,
  • 00:20:45
    have we seen this chart before,
  • 00:20:49
    or is this brand new, or has it just been a while? It's been a
  • 00:20:52
    while. Usually I'm bringing this in February or March,
  • 00:20:56
    because when a year ends, that's when it seems like the time to
  • 00:20:59
    talk about it. In this case, you know,
  • 00:21:02
    we've been in the aging revision request discussions,
  • 00:21:05
    so it had. It's. This is at least the third time,
  • 00:21:09
    and it might even be the fourth time I've presented this. I think.
  • 00:21:12
    I think every time you do, it's just there's a lot of work that
  • 00:21:16
    went into this and there's a lot of information that you've been able to succinctly
  • 00:21:19
    put on one page. And so it's just. Thank you for
  • 00:21:22
    that, because it's a really good visual representation
  • 00:21:26
    of where we are and it's just very impressive. I mean, if I had
  • 00:21:30
    to guess over, under duration or cost,
  • 00:21:34
    I mean, that would be challenging, but it's
  • 00:21:38
    just a really good illustration of overall
  • 00:21:41
    where we are. So we appreciate that. Well, thank you. I have folks back on
  • 00:21:45
    my team that are instrumental in helping me put this together.
  • 00:21:49
    My goal is for folks here to understand what type
  • 00:21:52
    of accuracy you should expect when you see an IA. So that's
  • 00:21:56
    why I think it's only fair that we come back and report on the results
  • 00:21:59
    after the fact. And I think, you know, please let them know that
  • 00:22:03
    we really do appreciate that. And I think this may be one of
  • 00:22:06
    the elements that will be super helpful tying into your aging projects summaries
  • 00:22:11
    that we've been pulling into, because some of the NPRRs that are still pending
  • 00:22:15
    are several years old. And so we're going to have to take a look at
  • 00:22:18
    that. And so that'll be also good to see where
  • 00:22:22
    we are on some of the older IAs that will need to be looked at
  • 00:22:25
    again. Yep. Okay, thank you. Any other
  • 00:22:28
    questions for Troy? Okay,
  • 00:22:32
    thank you, Troy. Thank you for your team's work, too. Thank you.
  • Item 5 - NPRR1247 - Urgency Vote - Diana Coleman
    00:22:39
    Okay, so that takes us to item number five on
  • 00:22:43
    our agenda. This is for urgency
  • 00:22:47
    as well. This is the first time we've had 1247 here at PRS.
  • 00:22:50
    It comes to us from ERCOT. It is incorporating the congestion cost
  • 00:22:54
    savings test and economic evaluation of transmission projects.
  • 00:22:58
    I know we also had some comments on this one,
  • 00:23:01
    so I wanted to see if ERCOT wanted to start us off and give us
  • 00:23:05
    an overview about it, and then we'll go and we'll take a look at the
  • 00:23:08
    TIEC comments.
  • 00:23:11
    Yes, Diana. This is pinyin with arcade planning, so I can
  • 00:23:15
    give a brief overview of this NPRR.
  • 00:23:18
    So, the main purpose for this NPRR is to incorporate
  • 00:23:22
    the congestion cost savings test that
  • 00:23:26
    is required by SB1281 and
  • 00:23:29
    also the amended PUC substantive
  • 00:23:33
    rule. So, before we came
  • 00:23:36
    up with this NPRR, ERCOT did hire
  • 00:23:40
    E3 as our consultant to survey the best industry
  • 00:23:44
    practices in economic projects evaluation,
  • 00:23:48
    especially in the congestion cost reduction
  • 00:23:52
    perspective. And E3 provided their final
  • 00:23:56
    recommendation and recommended ERCOT to measure that
  • 00:24:00
    from the load cost reduction perspective
  • 00:24:04
    as the congestion cost savings test. So,
  • 00:24:08
    this NPRR is implementing the
  • 00:24:11
    recommendations from E3,
  • 00:24:15
    the main objective of this NPRR.
  • 00:24:18
    And while we are working on the language in that portion
  • 00:24:22
    of the protocols, we also identified there
  • 00:24:26
    some language became obsolete,
  • 00:24:29
    and those language are removed
  • 00:24:34
    as part of this revision request.
  • 00:24:37
    So that's the overview of the intention and changes
  • 00:24:41
    of this revision request.
  • 00:24:45
    Okay, great. Thank you. Sure. We have a. We have
  • 00:24:49
    a question from Bill. Thanks, Dana.
  • 00:24:52
    Can you hear me? Okay. Can hear you. Great. Bill, go ahead. Awesome. So,
  • 00:24:56
    Penn, we were kind of curious why you filed this as an urgent
  • 00:25:00
    NPRR. I know we've been kind of working on this for a
  • 00:25:03
    while, and obviously, we're obligated
  • 00:25:07
    to implement it at some point,
  • 00:25:11
    but this is a pretty big policy change. We're pretty uncomfortable with
  • 00:25:15
    the lack of detail in the actual protocol itself.
  • 00:25:19
    And if you're planning to follow up with a PGRR, we would
  • 00:25:23
    definitely want to wait then to see the details on how you plan
  • 00:25:26
    to actually implement a congestion
  • 00:25:30
    cost savings test. And then also,
  • 00:25:34
    you probably know this, ROS asked that this be referred to the PLWG.
  • 00:25:37
    So we're not supportive of urgency on
  • 00:25:41
    this, just because we think it needs to bake a little bit longer.
  • 00:25:45
    Yeah. Thanks, Bill. So I think our legal
  • 00:25:48
    department, Matt Arthur, will be able to speak more about the
  • 00:25:52
    urgency as of the details about
  • 00:25:56
    this particular test. ERCOT does plan to develop
  • 00:26:00
    a white paper to give all the details about the
  • 00:26:04
    calculation. The amount of details
  • 00:26:08
    that goes into the calculation will make it kind
  • 00:26:12
    of like, infeasible to incorporate that in
  • 00:26:16
    either the protocols or planning guide. So that is our
  • 00:26:20
    intention. So, with that, I will turn that to
  • 00:26:23
    Matt to talk a bit more about the urgency request.
  • 00:26:29
    Thank you. Yeah, this is Matt, Arth. So I'm not
  • 00:26:33
    sure if commissioned staff is on the line and
  • 00:26:36
    has thoughts about the urgency, but at least from ERCOT's perspective,
  • 00:26:42
    under the PUCT's rule §25.101,
  • 00:26:47
    we are supposed to use the generator
  • 00:26:50
    revenue reduction test until this congestion
  • 00:26:54
    cost savings test is developed
  • 00:26:57
    and becomes effective. So,
  • 00:27:00
    currently, the plan is to include
  • 00:27:05
    the congestion cost savings test calculations
  • 00:27:09
    in the RTP, which is coming out
  • 00:27:12
    in December. And so I think,
  • 00:27:16
    from an urgency perspective, we would just
  • 00:27:20
    say that. I think that the projects
  • 00:27:24
    that are calculated
  • 00:27:28
    under the congestion cost savings test will likely be
  • 00:27:31
    included in the RTP, regardless of whether
  • 00:27:35
    this NPRR is approved prior to
  • 00:27:38
    that time. But that being said, I think that the transmission
  • 00:27:44
    and the transmission utilities that would be bringing projects
  • 00:27:48
    under the congestion cost test justification,
  • 00:27:53
    I don't think that ERCOT could recommend those projects until
  • 00:27:58
    this test is effective,
  • 00:28:01
    as per the PUC's rule. So I think that that's
  • 00:28:05
    part of the risk here, is that if the
  • 00:28:09
    NPRR is not approved by the
  • 00:28:13
    end of the year, then that will just delay
  • 00:28:20
    the ability of utilities to bring projects
  • 00:28:23
    under the congestion cost savings test.
  • 00:28:31
    Thank you, Matt. Melissa,
  • 00:28:37
    I think I'm mostly echoing Bill's comments. We're concerned with
  • 00:28:41
    a lack of transparency here and specifics. We support TIEC's
  • 00:28:45
    comments, so I don't think we're prepared to support urgency today
  • 00:28:49
    either.
  • 00:28:55
    Alex, I apologize. I missed you. Go ahead. That's okay.
  • 00:28:59
    Thank you. And I see other
  • 00:29:03
    lots of thoughtful people in the queue. Can you speak up just a little bit?
  • 00:29:07
    We can hear you, but just barely. How is this a
  • 00:29:11
    little bit better? I am struggling. My WebEx audio
  • 00:29:15
    is struggling for some reason. That's better. Okay,
  • 00:29:18
    I have a procedural question.
  • 00:29:22
    Hypothetically, one thing that is confusing is that the
  • 00:29:26
    PGRR117 that is associated
  • 00:29:30
    with this PUC ruling is not linked
  • 00:29:34
    to this NPRR. Is there a way after the fact?
  • 00:29:37
    These are, you know, and there's a new PGRR 119. I don't know
  • 00:29:41
    if that's related, but if. Is there a way
  • 00:29:45
    after the fact to link these revision requests together
  • 00:29:49
    so that for posterity. And so when people are trying to look
  • 00:29:52
    at a package that goes together, they're, you know, they all have
  • 00:29:56
    different market rules specialists on them.
  • 00:30:00
    What's the procedure there for going back and
  • 00:30:04
    linking revision requests?
  • 00:30:09
    This is Matt Arthur. Yeah, maybe I'll just jump in for a second. So PGRR
  • 00:30:13
    118, which addresses the addition of the resiliency
  • 00:30:18
    assessment criteria from the commission's rules
  • 00:30:21
    to the planning guides. That is,
  • 00:30:24
    obviously, resiliency assessments do fall under the commission's rule
  • 00:30:28
    16, tag §25.101. But I don't think that those are necessarily
  • 00:30:33
    linked to the congestion cost savings test. So that's
  • 00:30:36
    why we didn't link that PGRR to
  • 00:30:40
    NPRR1247.
  • 00:30:47
    Okay. And then just one other comment.
  • 00:30:50
    So that's. I understand why, but if stakeholders
  • 00:30:54
    don't agree and ask that they
  • 00:30:57
    do be linked together, is there a mechanism to do that for market rules?
  • 00:31:01
    And then a comment on the.
  • 00:31:04
    It seems like if you get to the point of
  • 00:31:09
    applying this test and having it make a difference and whether a project will
  • 00:31:13
    be endorsed or not, and the. And the
  • 00:31:17
    protocols haven't been finalized yet,
  • 00:31:20
    and you went to the commission with, here's our findings,
  • 00:31:24
    applying what you told us to do. It seems like they
  • 00:31:27
    would heavily weight ERCOT's opinion on that, even if the
  • 00:31:31
    protocols were still, were in process
  • 00:31:34
    of being approved. I'll let others take the
  • 00:31:38
    floor.
  • 00:31:43
    Thank you, Alex. Katie,
  • 00:31:47
    thanks. I didn't know if Matt wanted to respond to that,
  • 00:31:50
    but I just wanted to respond from a ROS perspective.
  • 00:31:53
    So we got a report from PLWG
  • 00:31:57
    at a ROS meeting on Monday. And, you know, there was just
  • 00:32:00
    sort of an informal presentation. So I think there was understanding
  • 00:32:05
    that this would go back to ROS and PLWG. So I
  • 00:32:09
    understand it has urgency on it, but I think that there's more review needed.
  • 00:32:13
    So just wanted to make sure folks were aware of that discussion and intention.
  • 00:32:19
    That's helpful, Katie. Thank you,
  • 00:32:22
    Mark. Hey, let me check
  • 00:32:26
    my audio. Can you hear me okay? I can hear you. Great. Go ahead.
  • 00:32:30
    Thank you. Yeah, I guess so. This is Mark Bruce and I'm
  • 00:32:34
    representing pattern energy on these issues.
  • 00:32:37
    I find myself. Can you speak up just a little bit? Yeah,
  • 00:32:41
    I will try to do that. I just mentioned that I represent
  • 00:32:44
    pattern energy on this, and I,
  • 00:32:49
    too, have some concerns about urgency,
  • 00:32:52
    not least because in protocols section
  • 00:32:57
    21.5, it's actually very explicit
  • 00:33:00
    that there are two reasons that urgency may be
  • 00:33:04
    granted separate and apart from the designation
  • 00:33:07
    of something as a board priority to
  • 00:33:11
    be granted urgent status, the revision must
  • 00:33:14
    deal with an imminent threat to system reliability or
  • 00:33:18
    market operations, or it has to,
  • 00:33:22
    you know, address an imminent problem with market settlement.
  • 00:33:27
    And this NPRR does none of those
  • 00:33:30
    things. So I don't really think, you know,
  • 00:33:33
    as just following the rule of law here,
  • 00:33:37
    I don't think this NPRR actually qualifies
  • 00:33:41
    for urgency. I don't think we really can designate it urgent
  • 00:33:46
    under the restrictions of section 21.5
  • 00:33:49
    of the protocols. That being said,
  • 00:33:53
    I often kind of check myself when I read TIEC
  • 00:33:57
    comments and find myself nodding my head. But I
  • 00:34:01
    did in this case. Whether I agree with their prescriptions
  • 00:34:05
    or not, I certainly agree with where they point out that there's some
  • 00:34:08
    vagueness. There needs to be some additional transparency.
  • 00:34:13
    There's some data that even if it's not included
  • 00:34:16
    here, it's something that needs to be posted. All of these things
  • 00:34:20
    go to Katie's point about the ROS and PLWG
  • 00:34:24
    discussions that, you know, we need some, some vetting
  • 00:34:28
    of this, we need some discussion. So I would
  • 00:34:31
    hope that, that PRS would not grant urgency to
  • 00:34:34
    this and that you do refer it, as requested,
  • 00:34:38
    through ROS to PLWG for further consideration.
  • 00:34:41
    Thanks.
  • 00:34:45
    Thank you, Mark Kennedy.
  • 00:34:49
    Okay. Echoing everybody else's comments, I kind
  • 00:34:52
    of follow along and it's kind of interesting. We're all nodding our head with the
  • 00:34:55
    IEC on this point. Ken, can you speak up just a little bit?
  • 00:34:59
    I'm sorry, for some reason, the phone is very, very faint today. Okay.
  • 00:35:02
    Huh. I usually have a. Use your
  • 00:35:06
    loud voice. Usually I have to go down, not up.
  • 00:35:11
    So cool. Thanks again. And I'm happy with that. That's good.
  • 00:35:14
    But, yeah, I'm echoing everybody else's kind of comments and
  • 00:35:18
    I'm representing APA on this one. It's kind of hard to support urgency
  • 00:35:21
    on this one. But do we have a target
  • 00:35:25
    for when this white paper is going to be out?
  • 00:35:31
    Does ERCOT want to respond to that? Yes. So, Ken, the white
  • 00:35:35
    paper is currently under development,
  • 00:35:38
    so it should be available in the next month or two.
  • 00:35:43
    Well, I will tell you right now until we start
  • 00:35:46
    seeing some details. And by the way, I think the stakeholders have been very
  • 00:35:51
    patient waiting for this information.
  • 00:35:54
    And I'm sorry, I'm going to be doubtful on the timeline,
  • 00:35:57
    but right now we'd really like to see it because I think
  • 00:36:01
    until we understand, I think it'd be very hard for a project to
  • 00:36:05
    go forward without that, those details behind it. And I know you
  • 00:36:08
    guys are on the crunch, but this has also been
  • 00:36:12
    around for a while, and we've been talking
  • 00:36:15
    about it for a while, so. And I know you guys are busy.
  • 00:36:19
    In fact, I thought you did an excellent job on the Permian Basin study,
  • 00:36:23
    and the discussion of the commission that went through today was very, very good.
  • 00:36:26
    But again, we need to see some details before I think we can support
  • 00:36:30
    urgency on this. And I kind of agree with Mark. I don't see how this
  • 00:36:33
    qualifies, so. And I know you're under the. Under the
  • 00:36:36
    gun, and I agree with it. You can do anything in the
  • 00:36:39
    RTP because it's your regional transmission plan, but we'd
  • 00:36:43
    really like to see some details.
  • 00:36:47
    Thank you, Ken. Eric,
  • 00:36:52
    could you walk me through the urgency as it relates
  • 00:36:56
    to the RTP again? Matt or ping?
  • 00:37:01
    Yes, this is Matt. Just on
  • 00:37:06
    the terms of Protocol 21,
  • 00:37:10
    you know, I guess I would just say on urgency, that. I understand that PRS
  • 00:37:13
    has read that liberally on many occasions
  • 00:37:17
    in the past, but understood for the RTP.
  • 00:37:21
    I think that the plan is to use the congestion cost
  • 00:37:25
    savings test in the RTP. That is to be posted
  • 00:37:29
    in December. And so now,
  • 00:37:34
    whether utilities can rely on
  • 00:37:38
    projects that would satisfy the
  • 00:37:41
    congestion cost savings test in bringing those projects to
  • 00:37:45
    RPG afterward, I think that is
  • 00:37:49
    the risk here, at least from ERCOT's perspective,
  • 00:37:51
    is ERCOT's not going to be able to recommend a
  • 00:37:55
    project under the congestion cost savings test for board
  • 00:37:59
    approval if the NPRR has
  • 00:38:03
    not been approved. And I think that that's because
  • 00:38:07
    of the language from 16 Tech 25 101,
  • 00:38:14
    little a or actually little b, I think.
  • 00:38:17
    But, yeah. So it's really a matter of if those projects
  • 00:38:22
    are to be brought and to move forward. I think that we cannot.
  • 00:38:25
    That ERCOT cannot recommend approval of them, even if they are
  • 00:38:29
    included in the RTP.
  • 00:38:33
    So the RTP will include the
  • 00:38:37
    projects, and if
  • 00:38:41
    the utility were to bring a project that
  • 00:38:45
    was approved by this test, but not the production cost
  • 00:38:48
    savings test, then there
  • 00:38:53
    may be some risk there. But the
  • 00:39:00
    math is the math. Right?
  • 00:39:04
    So I appreciate your perspective,
  • 00:39:07
    and I can see a justification for urgency, potentially,
  • 00:39:11
    if this would have impacted the RTP. But if
  • 00:39:14
    it's not, I don't know. I'm not 100%
  • 00:39:18
    persuaded by urgency if
  • 00:39:21
    it won't impact the RTP, because it seems like you have some time to figure
  • 00:39:25
    it out before any CCN or recommendation
  • 00:39:28
    of a project. Am I missing something?
  • 00:39:39
    I think you're right. There. I'm not sure. Looked like Pravio was in the queue.
  • 00:39:42
    I'm not sure if he has anything to add to that. But yes,
  • 00:39:46
    I would agree with how you characterized it. Eriche. Okay,
  • 00:39:48
    thanks. Prabhu. Did you want to chime
  • 00:39:52
    in? Yeah, this prabhu. Nana Margat.
  • 00:39:54
    So I just wanted to just like backtrack a little bit.
  • 00:39:57
    So this one here, what we have proposed is
  • 00:40:02
    what was recommended in NPRR1281 and the subsequent rulemaking.
  • 00:40:06
    So the ask was to come up with the criteria
  • 00:40:09
    to capture the congestion cost test. And we went through a lengthy process.
  • 00:40:13
    We hired consultant with that process. We went through several discussions,
  • 00:40:17
    stakeholders, and last, my recollection
  • 00:40:21
    is everybody agreed that the criteria
  • 00:40:24
    itself, people were not opposing. The stakeholders
  • 00:40:28
    agreed that this is the criteria, at least support.
  • 00:40:33
    What we are trying to do here is put the criteria in place because there
  • 00:40:36
    are so many things, other things,
  • 00:40:39
    subsequent NPRRs or PGRRs that can evolve from here
  • 00:40:43
    because there are already outstanding issues not
  • 00:40:47
    related directly to this criteria. But in order
  • 00:40:50
    to get those things done, you need to have clarity in the criteria.
  • 00:40:54
    Number one, we had production cost savings.
  • 00:40:58
    Now we have a new test. We are trying to quantify that
  • 00:41:02
    in the protocols and say what that is. And the white
  • 00:41:06
    paper or the document you're referring to is the details
  • 00:41:10
    of what the test is. We cannot put all those things in the NPRR.
  • 00:41:14
    So it's like a procedure document that's going to show it's nothing
  • 00:41:17
    any different from what we do from the production cost. So we will
  • 00:41:21
    have that ready and that's not going to change.
  • 00:41:24
    My ask is, you know, having this,
  • 00:41:27
    you know, urgency or getting this implemented does not,
  • 00:41:32
    or it's not going to change what we are proposing by future
  • 00:41:36
    revisions or NPRRs. This is the way I see it is this
  • 00:41:39
    is fundamental to some of the discussions that need to happen
  • 00:41:43
    subsequent to, like, you know, whatever change the stakeholders want to do.
  • 00:41:47
    And I think there is,
  • 00:41:51
    I did see the DiC comments. There are several things raised in there,
  • 00:41:54
    but in my mind, none of this is directly changing the
  • 00:41:58
    criteria. There are additional things or clarity to the criteria which we
  • 00:42:02
    intend to present to the stakeholders, but those things doesn't have to
  • 00:42:05
    be in the binding documents or protocols.
  • 00:42:09
    So we are working towards that. And also the fact that the
  • 00:42:13
    urgency, we do believe that the language in the PUC
  • 00:42:17
    allows us to work until this criteria is
  • 00:42:20
    implemented and effective. We are required
  • 00:42:24
    to use this generated revenue requirement as a proxy for the
  • 00:42:28
    congestion cost, which we are doing. But we have got one step ahead
  • 00:42:32
    and we have also implemented this congestion cost test,
  • 00:42:34
    because everybody has agreed, or at least there is
  • 00:42:38
    consensus, this is the test that needs to represent that congestion cost.
  • 00:42:42
    So we are pursuing that as part of the RTP. And then
  • 00:42:46
    the question comes, like, how do you select those projects
  • 00:42:50
    based on the 2024, whether this needs to be effective. We think this
  • 00:42:54
    needs to be effective to make those recommendations
  • 00:42:57
    based on the new congestion cost test. And I
  • 00:43:01
    personally feel that know, having the clarity now. We have.
  • 00:43:04
    We have made several, you know,
  • 00:43:08
    proposals to change, and I'm not saying this is the end of it,
  • 00:43:11
    but there is. There are things we can do,
  • 00:43:14
    including the TIEC comment. Like I looked at the comment, there are things which
  • 00:43:18
    we can resolve now, and there are things which probably needs
  • 00:43:22
    additional stakeholders in terms of,
  • 00:43:24
    like, you know, having the transparency or if you all need additional information for.
  • 00:43:28
    Not only for this criteria. Right, when we do economic analysis,
  • 00:43:32
    if you want additional outputs or results
  • 00:43:36
    that needs to be shared with stakeholders, the applies for both,
  • 00:43:40
    not the congestion cost, but also the production cost. So we can have
  • 00:43:43
    those discussions and subsequently. But I think
  • 00:43:48
    my final ask is, whatever we are proposing here
  • 00:43:52
    is not going to be affected by the changes that's going to be brought in
  • 00:43:55
    the subsequent figures. Thank you.
  • 00:43:58
    So, just to make sure I'm understanding what you're saying,
  • 00:44:02
    ERCOT believes that the language that's in 1247
  • 00:44:06
    is lining up with what was approved at the commission, but the conversations
  • 00:44:11
    that ROS and otherwise could continue while it
  • 00:44:14
    goes on its way to approval. Am I understanding that correctly?
  • 00:44:18
    Yes. Okay.
  • 00:44:22
    Where are we in the chat? Bryan Sams.
  • 00:44:28
    Hi there. Just a quick mic check,
  • 00:44:32
    just a little bit louder. That would be great. All right.
  • 00:44:36
    Well, Calpine is a. Me too, on opposition
  • 00:44:39
    to urgency for some of the reasons that were stated by others.
  • 00:44:43
    We support tabling, referring to ROS and then ultimately the PLWGD,
  • 00:44:48
    and allowing the NPRR to run through its normal course.
  • 00:44:52
    We support transparent planning rules. The actual planning
  • 00:44:55
    criteria don't seem to be available,
  • 00:44:58
    and there's no white paper at this time. Also not
  • 00:45:02
    sure that we agree with that. The details are too voluminous or detailed
  • 00:45:05
    to be included in the planning guides. I think generally
  • 00:45:09
    we're trying to move away from documents or criteria that aren't
  • 00:45:12
    in roles and guides. And I'm also just confused
  • 00:45:16
    about what procedure document is binding for planning
  • 00:45:20
    here. Seems like we've run into some issues with guidelines
  • 00:45:23
    that aren't binding recently at the commission, for example,
  • 00:45:27
    some of the state of charge issues. So it seems like ERCOT would
  • 00:45:31
    want this to be included in some kind of binding
  • 00:45:35
    document. Thank you.
  • 00:45:41
    Thank you, Bryan. Constance.
  • 00:45:45
    Hi, Diana. Can you hear me? I can. Please go ahead.
  • 00:45:50
    So, just briefly, this is Constance McDaniel Wyman, on behalf of
  • 00:45:53
    ETT. And, you know,
  • 00:45:57
    we appreciate ERCOT's work on developing this revision
  • 00:46:00
    and the work that they've done with E3.
  • 00:46:03
    And we, you know, we want to see this move forward.
  • 00:46:07
    We certainly want to see, you know, as somebody whose
  • 00:46:10
    projects come before RPG, we'd like to see
  • 00:46:13
    the new congestion cost savings test replace the generator revenue
  • 00:46:17
    reduction test.
  • 00:46:20
    And, you know, I'm not sure we haven't. We haven't
  • 00:46:24
    had a chance to discuss internally the idea of holding this up
  • 00:46:27
    for the PGRR language that other stakeholders are raising.
  • 00:46:31
    But I do want to. I got in the queue
  • 00:46:35
    to kind of respond to something that Eric Goff said
  • 00:46:39
    because, not. Not because he said it, but because it touches
  • 00:46:42
    on a concern that we've noticed
  • 00:46:46
    in the ERCOT language, the original revision
  • 00:46:49
    is proposed. You know, Eric made a comment
  • 00:46:52
    that there may be some. I'm not trying to quote you, Eric,
  • 00:46:56
    and I may paraphrase you badly, I apologize, I do.
  • 00:46:59
    But that there may be some view
  • 00:47:04
    about whether the congestion cost savings test is different and
  • 00:47:08
    distinct from the production cost savings test in the way
  • 00:47:11
    that this is written. And,
  • 00:47:14
    you know, when I looked at. When we looked at, you know,
  • 00:47:17
    paragraphs or bullets five and six that ERCOT has in there,
  • 00:47:22
    that's the exact concern that we saw looking at this.
  • 00:47:27
    You know, and so, for reasons different
  • 00:47:31
    from what the other stakeholders from other
  • 00:47:35
    sectors are talking about, you know,
  • 00:47:40
    it may be possible that this revision could benefit from some language
  • 00:47:43
    clarity about,
  • 00:47:46
    you know, that the model. Because five talks about the model in the production
  • 00:47:51
    cost savings test, and then I. Six basically talks about the congestion
  • 00:47:54
    cost savings test and refers back to the model that's quantified
  • 00:47:58
    in five. And it does kind of make it look like the congestion
  • 00:48:02
    cost savings test might be dependent upon the
  • 00:48:06
    production cost savings test. And others may have
  • 00:48:09
    other opinions, may disagree, but,
  • 00:48:13
    you know, we certainly view them as distinct and
  • 00:48:17
    separate tests. So I think that may be a point that needs
  • 00:48:21
    some development here.
  • 00:48:24
    Thank you. Thank you, Constance.
  • 00:48:28
    Alex, is my. Sound better now?
  • 00:48:33
    Try a little louder. Okay. I don't know why this sounds kind of low today.
  • 00:48:36
    Yeah, I found one setting. Hopefully it's a little bit better.
  • 00:48:40
    So I do. Thank you, Constance. I think that's a great point. And just
  • 00:48:44
    general, overall, the frustration here is
  • 00:48:48
    there are. While we are also anxious, we have
  • 00:48:52
    feel a sense of urgency to get this done.
  • 00:48:55
    There does need to be stakeholder discussion with ERCOT
  • 00:49:00
    and that we haven't had the opportunity that this was drafted months ago
  • 00:49:04
    and then filed at the last minute with urgency and
  • 00:49:08
    with the expectation that we would not have conversations around it and.
  • 00:49:13
    And fully develop. It is frustrating.
  • 00:49:17
    This deserves attention, it deserves discussion, and it
  • 00:49:21
    deserves an opportunity to get it right.
  • 00:49:25
    I agree with Constance that there may be a gap. One of the things
  • 00:49:28
    that we discussed previously was using Xero
  • 00:49:32
    as a bid price and production cost for
  • 00:49:38
    zero fuel cost units, whereas in the real world,
  • 00:49:43
    many of them bid negative, and that negative bidding will drastically
  • 00:49:47
    impact congestion costs. Where we did concur that it's not as big
  • 00:49:51
    of a driver for production cost, but details like that
  • 00:49:54
    need to be discussed and understood how they'll be modeled,
  • 00:49:58
    whether it's the same or differently, and we need
  • 00:50:02
    the full package. We need to understand what's happening before
  • 00:50:06
    we just rubber stamp language.
  • 00:50:11
    Thank you, Alex. Mark. Apologies. That was my fault. Go ahead.
  • 00:50:15
    Yeah, no worries. Just on the question of urgency that's
  • 00:50:19
    before us now. I just want to circle back and maybe this question is
  • 00:50:23
    to legal or to Prabhu, but, you know,
  • 00:50:26
    procedurally, if ERCOT can't recommend
  • 00:50:29
    a project until these rules are in place, so that makes
  • 00:50:33
    sense, right? You follow the rules in order to make a recommendation,
  • 00:50:36
    but your recommendation would come, and this is where I want to check
  • 00:50:40
    my understanding and be sure that I'm right here. Your recommendation
  • 00:50:43
    would come at the conclusion when you draft your report of the ERCOT
  • 00:50:47
    independent review of a project that's gone through the regional planning
  • 00:50:51
    group after it's been identified in the RTP.
  • 00:50:55
    So, if I understand this right, you put out. You do in the RTP now,
  • 00:50:59
    and you can use this test in that. There's no prohibition on doing
  • 00:51:02
    that, so you don't need the rules prior to the RTP. And when
  • 00:51:06
    the RTP is done and published, TSPs can pick
  • 00:51:09
    up projects that are recommended from there and form them into proposals for
  • 00:51:13
    regional planning group analysis. Then ERCOT will
  • 00:51:16
    conduct its independent review through that process.
  • 00:51:20
    So, in order for the TSPs to rely on the congestion
  • 00:51:23
    cost savings test as the basis of a CCN application following
  • 00:51:27
    an ERCOT endorsement, you really don't
  • 00:51:30
    need this in place, am I right? Until, I mean,
  • 00:51:34
    almost this time next year, before you get around to
  • 00:51:37
    completing the independent review through RPG of things that come
  • 00:51:41
    out of RTP in December 24.
  • 00:51:45
    This is Matt Arthur again. Yes, we'd agree with your characterization of the
  • 00:51:49
    process there, Mark. Okay, that's. That's helpful.
  • 00:51:53
    Thank you.
  • 00:51:55
    Thank you, Mark. Mister Barnes.
  • 00:52:00
    Yeah, I was going to attempt to move us along. I think the
  • 00:52:04
    will of PRS is pretty clear. I'd be willing to make a motion
  • 00:52:08
    to table this NPRR and refer to ROS on a normal timeline
  • 00:52:11
    if that's a preferred route. Or perhaps put on the
  • 00:52:14
    combo ballot or wait till later in the agenda when it comes up.
  • 00:52:19
    All right, thank you, Bill. I'm getting a second from Melissa.
  • 00:52:28
    Any other thoughts or comments on 1247
  • 00:52:33
    if there's a consensus, Corey, we can add this to the combo ballot
  • 00:52:37
    or do we need an end? Only if anyone wants to take ERCOT
  • 00:52:41
    side like y'all are unanimous to table and refer this to ROS.
  • 00:52:44
    So if that's table and refer to ROS, it can go on the combo ballot.
  • 00:52:47
    Or if we need a standalone ballot for anyone, we can absolutely
  • 00:52:51
    do that too. So either way works. There's a separate ballot needed.
  • 00:52:55
    No. Okay. It may be helpful too
  • 00:52:59
    to hear from the commission. I know that we had an open meeting this morning
  • 00:53:03
    just from their perspective too. So we'll try to reach out and see if we
  • 00:53:07
    can gather some more intelligence on that as well.
  • 00:53:11
    Okay,
  • 00:53:19
    thank you, Corey.
  • 00:53:22
    All right, so that takes us to section six. (item:6:Review PRS Reports, Impact Analyses, and Prioritization - Vote - denotes no impact - Diana Coleman)These are the previously
  • 00:53:26
    approved changes that we're going to look out for cost and for prioritization
  • 00:53:31
    for 1188. I'm going to hand it over to Andy and let him
  • 00:53:34
    get this one started. Oh, yeah. Thanks, Diana. I just
  • 00:53:38
    wanted to. No issue on the IA, but constellation
  • 00:53:41
    has been working with ERCOT and Oncor on some
  • 00:53:44
    potential language. Corey, I don't know if you can pull up the NPRR
  • 00:53:48
    and scroll down to, I think it's page 195 or 196.
  • Item 6.1 - NPRR1188, Implement Nodal Dispatch and Energy Settlement for Controllable Load Resources
    00:53:53
    There's a specific piece in there and just full disclosure,
  • 00:53:56
    consolation is going to file comments on this prior to
  • 00:54:00
    TAC, but we did since I had this opportunity,
  • 00:54:03
    I'll go ahead and preview it with you. Can you scroll up,
  • 00:54:06
    Corey?
  • 00:54:15
    Scroll up.
  • 00:54:28
    Perfect. Thanks, Corey. So the section you all see before you deal
  • 00:54:31
    specifically with a generation site that has a
  • 00:54:35
    single Poi and a controllable load
  • 00:54:38
    resource is sitting behind that generator's Poi.
  • 00:54:42
    Here it talks about the TDSP will install an EPS meter
  • 00:54:46
    to separately meter the controllable load resource as
  • 00:54:50
    long as all the entities approve. I think one of the big things that constellation
  • 00:54:54
    is looking to add is some additional clarification on
  • 00:54:57
    both the coordination with the CLR and the entities
  • 00:55:01
    that are sitting behind that single Poi. In that there
  • 00:55:05
    will be both the notification
  • 00:55:09
    to all of the entities that sit behind the POI of the
  • 00:55:12
    EPS meter installation requests as well as written
  • 00:55:16
    consent. I think the key piece here is that this
  • 00:55:21
    potential EPS meter could disrupt any prior arrangements,
  • 00:55:25
    whether it be netting or any of the.
  • 00:55:28
    Any of the arrangements behind that Poi between the generator and the load.
  • 00:55:32
    And that just adds further clarification to ensure sufficient
  • 00:55:36
    coordination before that EPS
  • 00:55:40
    meter gets installed. So happy to answer any questions,
  • 00:55:44
    but we will have comments here later today or
  • 00:55:48
    latest tomorrow to talk about that.
  • 00:55:58
    So I. This is NPRR1188, right? Yes. So I.
  • 00:56:02
    As I told you all the beginning of the meeting, I'm representing Lansing on this
  • 00:56:05
    item.
  • 00:56:08
    So you're asking to get it tabled today?
  • 00:56:12
    No, I think ERCOT has a desire to see it move forward. And so because
  • 00:56:16
    the language that I'm planning to submit has both
  • 00:56:20
    ERCOT and Oncor blessing, I think I feel comfortable moving
  • 00:56:24
    it forward to TAC and then having it there. So all of the interested
  • 00:56:27
    parties are. Have. Have essentially blessed this
  • 00:56:31
    additional clarification.
  • 00:56:35
    Okay, so, Corey, it sounds like we need to do a separate ballot for NPRR1188.
  • 00:56:39
    So we get the voting. So we'll need a motion and a second to
  • 00:56:44
    approve NPRR1188. And this will be. Let me make
  • 00:56:48
    sure.
  • 00:56:51
    Endorsement forward. Thank you, Corey. To the TAC, the August
  • 00:56:55
    8 PRS report and the June 27 impact analysis with
  • 00:56:59
    a recommended priority of 2026 and a rank of 390.
  • 00:57:07
    Dave? Sorry, go ahead. No problem at all. I hope you all
  • 00:57:10
    can hear me. I know that the volume has been having some trouble. I guess
  • 00:57:13
    only just based on Andy's comments, I did want to confirm that we
  • 00:57:16
    would like to see this move forward. So I appreciate you all looking to
  • 00:57:19
    potentially take a vote on it. Thank you. Thank you,
  • 00:57:22
    Dave. Appreciate it.
  • 00:57:25
    Okay, so we need a motion and a second, and then we can move forward.
  • 00:57:31
    Not everybody at once.
  • 00:57:47
    Okay, so if we don't get a motion,
  • 00:57:52
    what do we need to do? Cory, it just
  • 00:57:56
    remains obligated to take action today to do something
  • 00:58:00
    with it. It sounds like you all are free to make motions
  • 00:58:03
    in seconds as well. So if
  • 00:58:07
    Andy would like to. Do you want to make a mission, Andy? Or.
  • 00:58:10
    I don't have. Okay.
  • 00:58:15
    It's the tough part, right? I know. I'm submitting changes to it.
  • 00:58:18
    Why would I. Sounds like
  • 00:58:22
    it may not be quite ready
  • 00:58:26
    then.
  • 00:58:29
    PRS can still make a motion to table. Then if folks are silent because
  • 00:58:33
    they don't want this to move forward, a motion to table will stop it from
  • 00:58:36
    moving forward forward. It's just you voted, you recommended approval of language last
  • 00:58:39
    month, so now it's back for your second vote. So some sort of action by
  • 00:58:43
    PRS section 21 quoted at us already.
  • 00:58:46
    So if we're going to adhere to the sanctity of section 21,
  • 00:58:51
    please PRS numbers, make a motion in a second for some sort
  • 00:58:54
    of action on NPRR1188. So if
  • 00:58:57
    there's not a motion in a second, then it'll stay tabled.
  • 00:59:01
    No, it's not. It hasn't been tabled. That's just it. It's recommended for
  • 00:59:05
    approval. It's now back for PRS to take action.
  • 00:59:09
    So we need some sort of action today.
  • 00:59:13
    So this is just the IA portion of it because we already approved the
  • 00:59:16
    language last month. So what we're looking at is for the IA and
  • 00:59:20
    the prioritization. Yeah,
  • 00:59:23
    well, there's language concerns as well, as Andy mentioned. So you still file
  • 00:59:26
    comments to TAC and Andy's plans to, for Constellation's behalf
  • 00:59:30
    to further refine the language. We can
  • 00:59:34
    make desktop edits today if that's what is stopping anyone from taking
  • 00:59:39
    a vote on this. I mean, pull up last month's
  • 00:59:43
    ballot to show that folks were okay with the language last month.
  • 00:59:49
    And just as a refresher, the June 27,
  • 00:59:53
    2023 IA was 1.8 to
  • 00:59:57
    2.5 million. Correct. Okay,
  • 01:00:11
    Troy has a comment. Go ahead, Troy. And I
  • 01:00:15
    could add the priority of 2026 I've recommended
  • 01:00:19
    is post RTC because of the size of the project,
  • 01:00:22
    you know, $2 million, 11,000 internal
  • 01:00:26
    ERCOT hours and 2600 vendor hours.
  • 01:00:29
    So that's why the 2026 priority
  • 01:00:33
    is suggested. Well, what we could try
  • 01:00:36
    to do, possibly, is see if we can do desktop edits. If we have,
  • 01:00:40
    I'll be, I'd be happy to make a motion. Maybe if we sidebar and get
  • 01:00:44
    with Corey and maybe do some desktop edits, I'd be happy to make the motion
  • 01:00:48
    since it sounds like all the parties already agreed to the language and
  • 01:00:51
    then we can kind of get this ball moving.
  • 01:00:57
    Do we want to come back to it and I can.
  • 01:01:04
    Yeah, we could take a quick break. Yeah.
  • 01:01:07
    Okay. What if we do this, it is
  • 01:01:11
    02:01 what if we take a ten minute break,
  • 01:01:14
    come back at 211, see if we can have some language drafted at that point,
  • 01:01:17
    and we'll come back at 211 and we'll see if we are ready at that
  • 01:01:20
    time for everybody to take a look for consideration for the language and
  • 01:01:24
    see if we can try to move this forward. Okay. All right.
  • 01:01:27
    We'll be back at 211.
  • 01:11:14
    Okay, guys, it's 211. Let's see if we can get back so we can get
  • 01:11:17
    everybody out of here. Since we are a 01:00 start today.
  • 01:11:24
    Okay. All right, so we have some desktop edits
  • 01:11:28
    on the screen. Thank you, Corey. And then I'll go ahead and I'll hand it
  • 01:11:31
    back over to. To Andy and we'll see what we can do with this one.
  • 01:11:35
    Yeah, thanks, Diana. And appreciate everyone giving
  • 01:11:39
    me a chance to recess to get these desktop edits again
  • 01:11:42
    with these edits here, it does highlight that the
  • 01:11:46
    EPS meter does need to be required to be installed.
  • 01:11:50
    However, it includes the language that the
  • 01:11:55
    CLR needs to get consent from all of the resource,
  • 01:11:58
    both the resource entity and all the parties behind the POI, as well
  • 01:12:02
    as providing notification to those entities consuming
  • 01:12:05
    energy behind the POI of that EPS meter.
  • 01:12:08
    And so with that, I'm happy to make a motion to approve
  • 01:12:13
    1188 with the desktop edits.
  • 01:12:18
    Okay. And we have a second by Melissa Trevino.
  • 01:12:22
    Okay. And Corey, we have captured that there's desktop
  • 01:12:26
    edits, right? Yes, ma'am. That is exactly
  • 01:12:30
    what turned the motion that was on screen into. Now it is as revised
  • 01:12:33
    by PRS. So that is just to add in the highlighted portions here
  • 01:12:37
    that and you reviewed for folks.
  • 01:12:42
    And then Troy already talked about the priority and rank for us.
  • 01:12:46
    So if there's no further discussion on the motion, we will
  • 01:12:50
    start up with the consumers with
  • 01:12:53
    Mark Dreyfus. Yes, thank you.
  • 01:12:57
    Thank you. Melissa. Yes. Thank you. Thank you.
  • 01:13:00
    Onto our CoOps. Lucas.
  • 01:13:03
    Yes.
  • 01:13:07
    Is that a yes? Lucas? I'm sorry. That was really brief. Yes,
  • 01:13:11
    thanks. Blake? Yes, sir. Thanks,
  • 01:13:15
    sir. Eric. Blakey. Yes, thank you.
  • 01:13:19
    On to our independent generators. aNDY. Yes, thank you.
  • 01:13:23
    Bryan Sams. Yes, thank you.
  • 01:13:27
    Alex? Yes, thank you. David?
  • 01:13:34
    Yes, thank you.
  • 01:13:37
    Onto our IPMs. John Barnell,
  • 01:13:46
    you with us?
  • 01:13:51
    Trying to come off mute. Yes, thanks, sir.
  • 01:13:57
    Onto our IREPs. Bill. Yes, thank you.
  • 01:14:00
    Aaron? Yes, thank you.
  • 01:14:04
    On to our IOUs. Martha. Yes, thank you.
  • 01:14:07
    Rob? Yes, thank you. Jim? Yes, thanks. Corey.
  • 01:14:11
    Thank you. On to our Munis. Diana?
  • 01:14:14
    Yes, thank you. Ashley?
  • 01:14:17
    Yes, thank you. And Fei.
  • 01:14:21
    Yes, thank you. Motion carries unanimously.
  • 01:14:30
    Okay, thank you everybody for that
  • 01:14:34
    collaborative effort there. We appreciate that.
  • 01:14:37
    Okay, so next up, we have 1237.
  • Item 6.2 - NPRR1237, Retail Market Qualification Testing Requirements
    01:14:40
    That comes to us from CenterPoint.
  • 01:14:44
    Last month we voted unanimously to recommend approval of 1237
  • 01:14:48
    as amended by the August 6 WMS comments
  • 01:14:52
    and the August 27 impact analysis, which is no cost and no project required.
  • 01:14:58
    Is this one ready for a combo ballot? I'm seeing nods.
  • 01:15:03
    Okay, Corey. If we can add NPRR1237.
  • Item 6.3 - NPRR1244, Related to NOGRR263, Clarification of Controllable Load Resource Primary Frequency Response Responsibilities
    01:15:08
    And then next we have NPRR1244. That is coming to us
  • 01:15:12
    from Priority Power.
  • 01:15:17
    Let's see. Troy gave us an update on this one earlier.
  • 01:15:22
    Let me look at my notes real quick.
  • 01:15:27
    Go ahead, Troy. Thank you.
  • 01:15:32
    I go through my usual process on trying to determine a recommended
  • 01:15:36
    priority in rank, and the conclusion was we
  • 01:15:39
    wanted to get PRS input. And if I put on my RTC+B
  • 01:15:43
    hat, you know, I would say, hey, can we make this
  • 01:15:47
    after RTC because of the EMS impact? But if I put
  • 01:15:51
    on a different hat, it's not the largest project out there and half
  • 01:15:54
    of it's NDCRC. So the EMS impact
  • 01:15:57
    isn't, isn't overly large, but nonetheless is
  • 01:16:01
    wanting to see PRS's thought on
  • 01:16:05
    whether this is important enough to try to squeeze in or if we can
  • 01:16:08
    push it to 2026. Will it risk the
  • 01:16:12
    RTC project, Troy, or just you don't know?
  • 01:16:16
    I don't know at this moment. But if it does risk
  • 01:16:19
    it, we would definitely want to
  • 01:16:22
    push it. So it seems like,
  • 01:16:26
    is there a way to say, let's try, but if you see a risk,
  • 01:16:29
    come tell us and we'll change it, because we all want RTC.
  • 01:16:33
    Because we could approve it with a certain prioritization that could be modified,
  • 01:16:37
    correct? Or certainly. Okay, so we could
  • 01:16:40
    do a good, a good guess, because that's a good point, Eric. We don't want
  • 01:16:43
    anything to interfere with the RTC
  • 01:16:49
    project. So we could do a priority and a rank,
  • 01:16:53
    and then if that needs to be modified at some certain time, we can take
  • 01:16:57
    a look at that.
  • 01:17:01
    Any other thoughts or comments? Michael?
  • 01:17:05
    Oh, Whitmire. Sorry.
  • 01:17:10
    Hi. Michael Jewell. On behalf of priority power, I think that sounds like a
  • 01:17:14
    good idea. Obviously, we don't want to jeopardize real time co optimization,
  • 01:17:18
    but setting this up in order to help get more clrs to
  • 01:17:22
    be scheduled dispatchable is really what we're after.
  • 01:17:24
    Okay, thank you. Go ahead.
  • 01:17:28
    So what priority rank would it be to go before, and then you'll
  • 01:17:31
    tell us if there's a risk and we can revise our.
  • 01:17:34
    Sure. If we could squeeze it in, I'd suggest 2025
  • 01:17:39
    45 30.
  • 01:17:43
    So that would be trying to squeeze it in.
  • 01:17:47
    If we. And I think we can make a pretty quick determination on that
  • 01:17:51
    within a. Yeah, no more than two months, perhaps by
  • 01:17:54
    next month. Okay,
  • 01:17:58
    go ahead, Bob. Troy, is this one dependent on,
  • 01:18:01
    is 1244 in any way dependent on
  • 01:18:05
    1188? I'm glad you asked that,
  • 01:18:08
    Bob. I have a note about that and forgot to mention it.
  • 01:18:11
    Apparently there's been some discussion with maybe a subset of market
  • 01:18:15
    participants that led people to think that this is
  • 01:18:18
    dependent on 1188. It is not, and we
  • 01:18:22
    have confirmed. Great answer. Thank you. There's no technical dependency.
  • 01:18:26
    So that has been confirmed by our experts.
  • 01:18:29
    Thank you for asking that.
  • 01:18:34
    Any other thoughts on
  • 01:18:38
    1244?
  • 01:18:42
    Okay, so we can do the priority of 2025 in the rank of 45
  • 01:18:45
    30 based on Troy's projections.
  • 01:18:50
    How does everybody feel about 1244 on the combo ballot?
  • 01:18:54
    I'm getting nods. Okay, Corey, let's go ahead and add that one as well here.
  • 01:18:57
    At the risk of upsetting things,
  • 01:19:02
    1244, when it was originally filed, was filed as a related
  • 01:19:06
    NPRR to NOGRR263.
  • 01:19:09
    But in the process of developing the IA and as the NOGRR went through ROS,
  • 01:19:13
    it was found that the costs actually resided on the NPRR.
  • 01:19:17
    So ROS approved changes to the NOGRR to
  • 01:19:21
    make it point to the NPRR instead. So what I'm proposing
  • 01:19:24
    here would be desktop edits to the title of 1244 to stop
  • 01:19:28
    pointing at NOGRR263 and let NOGRR263
  • 01:19:32
    point at it. So it would be exact
  • 01:19:36
    same motion on the combo ballot, but as revised by PRS to make this
  • 01:19:40
    title change. We're getting thumbs up. Okay, thanks, y'all.
  • 01:19:43
    Okay, thank you, Corey. That was a good clarification. I forgot about
  • Item 7 - Revision Requests Tabled at PRS - Possible Vote - Diana Coleman
    01:19:47
    the nought. Okay,
  • 01:19:50
    so on to the sea of tabled items.
  • 01:19:53
    I believe the first item that we're going to have up is 1180.
  • 01:20:04
    Hold on, real quick. Let me pull up my notes.
  • Item 7.3 - NPRR1180, Inclusion of Forecasted Load in Planning Analyses
    01:20:11
    Okay. And so on 1180 where we are on this one.
  • 01:20:17
    There we go. All right, this is coming to us from Oncor.
  • 01:20:22
    We have had this tabled and we had it referred over to ROS.
  • 01:20:27
    I know that there has been an appetite to have some motion on 1180
  • 01:20:31
    this PRS meeting. So ROS
  • 01:20:35
    approved ERCOT's August 28 comments for the
  • 01:20:39
    PGRR 107, which is associated with 1180.
  • 01:20:43
    Certainly appetite for moving 1180 and adding
  • 01:20:47
    that one to the combo ballot.
  • 01:20:51
    Seeing nods. Okay, so, Corey, can we add
  • 01:20:54
    1180 as well?
  • 01:20:58
    1180 with the august ERCOT comments?
  • 01:21:01
    Yes, please. August 28 ERCOT comments.
  • 01:21:05
    Will do. Oh, there you go.
  • 01:21:08
    We need a separate ballot because Bryan would like to abstain.
  • 01:21:12
    Got it. Thank you, Bryan. Let me get you a ballot.
  • 01:21:24
    Okay, so we're going to need a motion in a second for
  • 01:21:27
    1180 for approval as approved
  • 01:21:31
    with the ERCOT August 28 comments. Do I have a motion? Motion by Jim
  • 01:21:34
    Lee. Do I have a second?
  • 01:21:40
    Oh, katie, go ahead. I'm sorry, I'm not
  • 01:21:44
    trying to hold up the ballot, but just wanted to mention
  • 01:21:47
    that ROS approved PGRR 107 with the August 28
  • 01:21:51
    comments. And one of the members did ask that we put 1180
  • 01:21:56
    back on the agenda for October to see
  • 01:22:00
    if we wanted to, you know,
  • 01:22:03
    include the August 20 comments on 1180. So we
  • 01:22:07
    would do that early October, so we would have it back in time for
  • 01:22:11
    PRS during the IA review if we
  • 01:22:15
    do decide to do that. So just wanted to give you a heads up that
  • 01:22:18
    ROS is going to look at this one one more time.
  • 01:22:24
    Okay, so sounds like we need to keep this tabled.
  • 01:22:27
    So go ahead, Martha. Thank you.
  • 01:22:30
    Martha Henson with Oncor. So that's fine if ROS wants
  • 01:22:35
    to take a vote on it. They've already voted on it once. It was last
  • 01:22:37
    year sometime. It's a previous set of comments.
  • 01:22:41
    I would be appreciative if we could proceed with the motion. I'll second Jim's motion
  • 01:22:45
    so that we can get a vote on it today. I would like to make
  • 01:22:47
    sure that ERCOT has adequate time to prepare an impact analysis
  • 01:22:50
    since this is a market participant sponsored NPRR,
  • 01:22:53
    which sometimes can take a little bit longer than the one month turnaround.
  • 01:22:57
    So I'll second Jim's motion and
  • 01:23:00
    appreciate if we could do the vote. Thanks. Thank you. Martha.
  • 01:23:08
    Any other thoughts? Okay,
  • 01:23:11
    I think we're ready. Corey.
  • 01:23:14
    All right. Thank you all. On the motion to recommend approval of NPRR1080, as amended
  • 01:23:18
    by the August 28 ERCOT comments, we will start up with the
  • 01:23:21
    consumers, with Eric. Yes, thank you.
  • 01:23:25
    Mark Dreyfus. Yes. Thank you. Thank you.
  • 01:23:28
    Melissa. Yes. Thanks. Corey. Thank you. Onto our co ops.
  • 01:23:32
    Lucas. Yes. Thank you.
  • 01:23:36
    Blake. Yes. Thank you.
  • 01:23:39
    Eric Blakey. Yes, thank you, sir. Onto our independent
  • 01:23:42
    generators. Andy? Abstain. Thanks. Corey.
  • 01:23:47
    Thank you. Bryan. Same.
  • 01:23:51
    Thank you. Alex.
  • 01:23:54
    Yes. Thank you. David.
  • 01:24:00
    Yes. Thank you. Under our IPMS. John?
  • 01:24:10
    Yes, sir. On to our IREPs Bill.
  • 01:24:14
    Yes, thank you. Aaron? Yes.
  • 01:24:18
    Ontor IOUs. Martha? Yes, thank you.
  • 01:24:21
    Rob. Yes, thanks, sir. Jim.
  • 01:24:24
    Yes. Thanks for Munis.
  • 01:24:27
    Diana. Yes. Thank you. Ashley.
  • 01:24:31
    Yes. Thank you. And Fei. Yes.
  • 01:24:34
    Thank you. Motion carries, two abstentions.
  • 01:24:38
    Can I ask a follow up question on that? I didn't want to get
  • 01:24:41
    in the way of the vote, but maybe talk into
  • 01:24:45
    the mic so we can. I didn't want to get in the way of the
  • 01:24:47
    vote, but I've got a follow up question in this
  • 01:24:51
    comment section. Is there some risk of
  • 01:24:55
    being there to be distinction between the meaning of an uppercase load
  • 01:24:59
    and a lowercase load that people who don't remember these comments will
  • 01:25:02
    have four years from now in general, in the protocols?
  • 01:25:06
    And do we need to take a look at making sure
  • 01:25:10
    that we're using that term appropriately throughout all of the protocols?
  • 01:25:17
    I just. It makes me a little nervous that we're making a distinction between uppercase
  • 01:25:21
    and lowercase load. And I just want to. I don't want. Want there to be
  • 01:25:24
    an issue. Do we need to deal with that?
  • 01:25:30
    I know no one wants to deal with that, but is
  • 01:25:37
    that something that we should think about, Nathan?
  • 01:25:40
    There we go. Go ahead, Nathan. Yeah,
  • 01:25:43
    Eric, I think that's a fair question. Can you talk up just
  • 01:25:46
    a little bit? Sorry, the sound is really low. Yeah. Let me see if I
  • 01:25:49
    can juice up my mic here.
  • 01:25:53
    Apparently, Bluetooth is making something very, very subtle.
  • 01:25:58
    Can you all hear me now? Oh, that's perfect.
  • 01:26:02
    Awesome. Yeah, I mean, Eric, I think that is a fair question.
  • 01:26:06
    As I pointed out to PLWG back in July, ERCOT has a
  • 01:26:10
    long history of misusing the term load
  • 01:26:13
    throughout the protocols. It's got
  • 01:26:16
    a pretty narrow definition that's focused on an energy value.
  • 01:26:20
    And as you know, we've used it in many different ways
  • 01:26:25
    beyond just its energy definition.
  • 01:26:29
    And it's just been a habit, I think, of our organization
  • 01:26:32
    to capitalize it, and that's
  • 01:26:36
    not quite accurate. So there's question around, what's the best way to address that?
  • 01:26:40
    How. How critical an issue is that, really?
  • 01:26:44
    I do think that in most contexts, you're going to find that
  • 01:26:47
    the meaning of the term is pretty clear.
  • 01:26:50
    And so while I do think it's regrettable that there has been maybe
  • 01:26:55
    not an ardent observance
  • 01:26:59
    of that definition,
  • 01:27:02
    I don't know that it's really, in most cases, going to be a legally
  • 01:27:05
    critical question. But I do think, in terms of overall improvement,
  • 01:27:11
    that certainly should be in our to do list. I think it is.
  • 01:27:15
    If you're getting at whether we should reject the comment.
  • 01:27:18
    No. Okay. I think it's better to
  • 01:27:22
    do good going forward, notwithstanding the dissonance.
  • 01:27:26
    In practice, maybe, but there's already
  • 01:27:29
    an inconsistency. It's not a universal misuse.
  • 01:27:33
    It's just a 90% or so misuse, I would guess. Nathan, could you do me
  • 01:27:37
    a favor and get a summer associate for next year to handle this?
  • 01:27:41
    Well, this may be an important item. I think
  • 01:27:45
    we probably got some other important items we want to assign first to summer associates,
  • 01:27:49
    if we had any. But I hear you, and I
  • 01:27:53
    think it is something that should merit attention at
  • 01:27:58
    an appropriate time. I. You know, I don't
  • 01:28:01
    think this is a hill to die on as far as our comments go,
  • 01:28:03
    frankly, either way, in the comments. Right, right. I'm just.
  • 01:28:07
    Yeah, I'm just. I'm just telling you, I don't think it's a big deal,
  • 01:28:10
    but we, you know, it is an issue. That we need to address in
  • 01:28:14
    our rules, because it's. It's not an accurate use of the term based on the
  • 01:28:18
    definition. All right, sounds good.
  • 01:28:23
    Blake, holt,
  • 01:28:28
    I'll go ahead and let Katie go first. Okay. Katie, go ahead.
  • 01:28:32
    Yeah, I just wanted to add that we had this discussion at ROS on
  • 01:28:36
    Monday and was added as an action item under PLWG.
  • 01:28:40
    So, Eric, to your point, we are working
  • 01:28:44
    on it on the ROS side.
  • 01:28:51
    Thank you, Katie.
  • 01:28:55
    Any other thoughts on
  • 01:28:59
    1188?
  • 01:29:03
    Oh, excuse me, 1180.
  • 01:29:07
    Okay, the next item under
  • 01:29:10
    section seven,
  • 01:29:13
    I'm going to ask ERCOT if this is where they want to discuss this on
  • 01:29:17
    NPRR1226. Andy and I have had some conversations based out
  • 01:29:21
    on the August NPRR conversation
  • 01:29:25
    that we had regarding the request for
  • 01:29:30
    ERCOT having certain information on
  • 01:29:33
    their webpage. I see that you all filed a
  • 01:29:37
    presentation. I don't know if it was the intention for
  • 01:29:41
    ERCOT to talk about it here or in other business or if y'all have
  • 01:29:44
    that preference.
  • 01:29:55
    Okay. Okay, Amy, come on
  • 01:29:59
    up and we'll talk.
  • 01:30:03
    Corey, can we pull up her presentation, please?
  • Item 7.7 - NPRR1226, Demand Response Monitor
    01:30:09
    So, one of the conversations points that we had with ERCOT
  • 01:30:12
    was, and I'm not sure if it's actually included Amy in
  • 01:30:16
    this presentation, but where on the website
  • 01:30:20
    market participants can go.
  • 01:30:23
    And I believe, if I understood it correctly, that the protocols
  • 01:30:27
    and the system change requests are not what's needed in order to
  • 01:30:31
    be able to request. So I'll let you walk through the presentation and
  • 01:30:34
    we'll see what questions we have. Sure.
  • 01:30:38
    So this is just regarding
  • 01:30:42
    the feedback. And I just want to start with saying we do want feedback
  • 01:30:46
    from market participants for all
  • 01:30:50
    of our digital channels. And there's been some confusion
  • 01:30:54
    about how to give us that feedback and
  • 01:30:58
    how to present that feedback to us.
  • 01:31:03
    So, basically, I'm just going to briefly
  • 01:31:06
    go over the ways that are already established
  • 01:31:10
    to give us feedback, which is through the protocols,
  • 01:31:14
    through the system change request, and then
  • 01:31:17
    the other binding documents. And then I'll talk briefly about
  • 01:31:21
    the digital channel feedback, which is ercot.com
  • 01:31:25
    dot mis, the market information
  • 01:31:29
    systems, the mobile app, and then the one
  • 01:31:33
    that seems to be the biggest barrier
  • 01:31:37
    here is the displays and the dashboards.
  • 01:31:41
    So, again, this is very familiar for you all. This is
  • 01:31:45
    for the revision request for the nodal protocols,
  • 01:31:49
    the planning guides, and then the system change request.
  • 01:31:54
    So this one I will address briefly.
  • 01:31:58
    The dashboards themselves and the displays
  • 01:32:02
    should not come through the system change request because
  • 01:32:06
    we don't consider them a system. A system to
  • 01:32:09
    us would be like the RIOO
  • 01:32:13
    or one of the EMS systems, or something of that
  • 01:32:16
    sort that needs to be changed
  • 01:32:20
    or requested to change. So we don't recommend
  • 01:32:23
    that dashboards feedback come through a system change request.
  • 01:32:29
    Of course, there's the other binding documents as well,
  • 01:32:33
    so we don't deal with the feedback on this item
  • 01:32:37
    either. So the digital
  • 01:32:41
    channels that we are going to
  • 01:32:45
    talk about today is the changes for ERCOT.com.
  • 01:32:50
    and the issue is, we have
  • 01:32:53
    all public information on ERCOT.com. however, there's lots
  • 01:32:57
    of different ways to give us that feedback. So we have the displays
  • 01:33:00
    and dashboards, we have protocols. So how do we separate
  • 01:33:05
    that information for
  • 01:33:10
    the general feedback, such as design or
  • 01:33:14
    improvement for search, things like this?
  • 01:33:17
    We would recommend that this comes to
  • 01:33:21
    either these two emails here,
  • 01:33:25
    the webmastercott.com or the user experiencercott.com
  • 01:33:30
    dot. Once we receive the feedback,
  • 01:33:34
    we do look at it,
  • 01:33:37
    look and see if there's anything
  • 01:33:42
    that we can go forward with. If so, what we do is put it
  • 01:33:46
    in our backlog. And then when. Once it's in our
  • 01:33:49
    backlog, we try to put it into either a project
  • 01:33:54
    or what we call OEM, the operations budget,
  • 01:33:58
    to get that change to the
  • 01:34:02
    website. And, again,
  • 01:34:05
    these changes can be driven by protocols,
  • 01:34:09
    but not all of it is, because a lot of the information on
  • 01:34:12
    ERCOT.com is considered complementary.
  • 01:34:17
    We also do have a current redesign
  • 01:34:21
    effort in progress. And here
  • 01:34:24
    is the page that this could
  • 01:34:28
    be found on. It's under the about and the redesign
  • 01:34:32
    section. We've been working for the last year
  • 01:34:36
    to get feedback from market participants to
  • 01:34:40
    tell us what you want to see in the new ERCOT redesign.
  • 01:34:47
    So, the market information system, again, this is protocol
  • 01:34:51
    driven. So if there are changes for this
  • 01:34:55
    section, it does need to come through one of
  • 01:34:59
    the either the protocol section or the
  • 01:35:04
    planning guide for the
  • 01:35:08
    mobile app. Again, we are redesigning the mobile app,
  • 01:35:11
    and there will be a new build coming at the end
  • 01:35:15
    of this, this month.
  • 01:35:18
    We do recommend feedback with that as well.
  • 01:35:22
    And it's the same email address here.
  • 01:35:26
    You can either send it to userexperiencearchot.com or
  • 01:35:30
    webmastercod.com dot. And again, this has been an
  • 01:35:33
    ongoing effort for the last year, then we've gotten
  • 01:35:37
    lots of great feedback for that. And once we receive
  • 01:35:41
    these, again, just like for ERCOT.com comma,
  • 01:35:45
    it goes into our backlog. We evaluate when and where
  • 01:35:48
    we can get these updates completed
  • 01:35:52
    and then put it on the
  • 01:35:56
    website, or, I'm sorry, on the. The mobile app.
  • 01:36:00
    So, the one I'm really going to talk about here is the dashboards and
  • 01:36:03
    displays and how to get us feedback on that.
  • 01:36:07
    Here is the proposed flow of
  • 01:36:11
    how to get us that information.
  • 01:36:15
    We are going to be setting up an electronic
  • 01:36:19
    form for you to enter the information
  • 01:36:23
    to us. And then once we get that information,
  • 01:36:27
    we're going to consider it in that consideration.
  • 01:36:31
    There's lots of different departments that are going to be touched in
  • 01:36:35
    that process. So first of all, we will need to see if
  • 01:36:38
    that data is actually available for that recommended
  • 01:36:43
    change or recommended new dashboard.
  • 01:36:47
    So once it is found
  • 01:36:51
    that we could do this and the SME's do agree
  • 01:36:55
    that it would be a great dashboard to add
  • 01:36:58
    or change for the dashboard, then we go
  • 01:37:02
    through the regular impact analysis to see
  • 01:37:06
    where we can fit it into either a project or
  • 01:37:10
    just OEM efforts and then get it out to
  • 01:37:14
    the proper channels. Now, if it is not
  • 01:37:18
    something that can be done either because
  • 01:37:22
    we don't have the data or it's just not recommended by our
  • 01:37:26
    SME's, internal SME's, then we
  • 01:37:30
    will recheck that. But overall,
  • 01:37:34
    this is going to be the recommendation from
  • 01:37:38
    the digital content management department
  • 01:37:42
    and we will go forward from here.
  • 01:37:45
    So I'll pause, Diana and take any questions.
  • 01:37:49
    Thank you so much, Whitmire. Yes. So I
  • 01:37:53
    think probably what triggered this was NPRR1226,
  • 01:37:58
    which was the demand response monitor.
  • 01:38:02
    Sounds like when they did that, they did it correctly
  • 01:38:05
    as an NPRR. Right. But now we're changing
  • 01:38:10
    the process and going forward, they would
  • 01:38:13
    submit a dashboard request. Correct.
  • 01:38:17
    So we would like the dashboard request
  • 01:38:20
    and the reports to be separated
  • 01:38:24
    because once we receive an NPRR or
  • 01:38:28
    a system change request that makes us,
  • 01:38:32
    you know, the mustachal will or got, mosthaller will
  • 01:38:37
    complete this work. And we don't always know that this
  • 01:38:40
    work is doable.
  • 01:38:44
    Okay, so when, so we all understand the
  • 01:38:47
    NPRR process and a bunch of people weigh
  • 01:38:51
    in on an NPRR. Does the same
  • 01:38:54
    apply to a dashboard request? Because frankly, just because Floyd
  • 01:38:59
    wants something, I don't know that we would give it to him. But if we
  • 01:39:02
    get a vote by TAC that says, yeah, that's a good
  • 01:39:06
    thing to do, that carries a lot more weight
  • 01:39:09
    than something that, you know, an individual wanted. How do we capture
  • 01:39:13
    that in this process? And again, this process is
  • 01:39:17
    still being developed and we hope to have an
  • 01:39:21
    answer by the end of the year on that and we will definitely
  • 01:39:26
    consider, you know, have. So then
  • 01:39:30
    should 1226 continue down the path
  • 01:39:34
    of an NPRR like it is for now
  • 01:39:38
    since.
  • 01:39:42
    Yes, in a minute. Okay, cool. I'll wait.
  • 01:39:48
    Eric, seems like
  • 01:39:51
    we're reinventing the wheel is
  • 01:39:55
    the issue. Just that there are some system change requests
  • 01:39:59
    where ERCOT wants a veto? I mean.
  • 01:40:03
    No. So, I'm sorry, it seems like
  • 01:40:06
    that's the core of the issue. Right. The issue is we don't
  • 01:40:10
    consider dashboards to be systems.
  • 01:40:13
    So what is a system? A system would be one of the.
  • 01:40:18
    I mean, what's the definition of a system? Not an example.
  • 01:40:22
    I don't have the definition of a system, but not
  • 01:40:27
    sure if it's in the protocols or in the language.
  • 01:40:32
    Yeah, I think system change request is
  • 01:40:36
    defined in the protocols, and I
  • 01:40:39
    think it's pretty clear that we've done
  • 01:40:43
    very similar things to this through system change requests in the past, and there's
  • 01:40:46
    nothing about the system change request process that's changed since
  • 01:40:50
    then. And I think that
  • 01:40:54
    ERCOT is.
  • 01:40:57
    I understand your motivation very
  • 01:41:01
    clearly that you want to protect the ERCOT.com website, because so
  • 01:41:04
    many people use it. But I think we need to have a clearly defined process
  • 01:41:08
    here and not this. So, for example,
  • 01:41:12
    there some concerns are,
  • 01:41:16
    can the utility commission order ERCOT to create a dashboard?
  • 01:41:23
    So, again, it's not that we
  • 01:41:27
    don't want to create these dashboards, it is.
  • 01:41:30
    There is a lot of data that goes into each
  • 01:41:34
    one of these and we have to evaluate each one.
  • 01:41:38
    That what we do with the impact analysis process, though,
  • 01:41:41
    it is. But our stance is we don't want it to
  • 01:41:45
    go through a system change request, because that
  • 01:41:48
    puts us in the business of having
  • 01:41:52
    to complete these changes. So,
  • 01:41:56
    to go back to my earlier question, it seems like the distinction between this and
  • 01:41:59
    Ser is you want to veto the SER process, and if that's
  • 01:42:03
    the case, let's talk about it. No, sir, that's not what I'm saying.
  • 01:42:06
    Okay. Well, then what about. What did
  • 01:42:10
    I say is incorrect? I think that
  • 01:42:13
    the incorrect portion of this is we don't consider dashboards
  • 01:42:18
    a system. So what is the.
  • 01:42:21
    I don't want to put you on the spot, but it seems like we need
  • 01:42:24
    to talk about this some more, because I think it's very clear in
  • 01:42:28
    the legal and common meaning of the word system that a dashboard as a
  • 01:42:32
    system, and I'm not trying to put you
  • 01:42:35
    on the spot, but I don't think that this is an adequate process. And it
  • 01:42:39
    occurs to me that if you were to answer that you
  • 01:42:42
    do want to veto over some SCR's, then we could develop
  • 01:42:46
    an other binding document that has a different change control process
  • 01:42:49
    than SCR's. We have a process in the protocols driving
  • 01:42:53
    a different approval process for some other vending
  • 01:42:57
    document. So it's possible that we could create
  • 01:43:01
    an other binding document with a different change control process that's
  • 01:43:05
    similar to this, but it'd be formalized and not informal and
  • 01:43:08
    ad hoc. And so I'd
  • 01:43:12
    like for us to. If what you
  • 01:43:15
    want is to be able to say no to some kinds of system changes,
  • 01:43:20
    let's create a process that's formalized,
  • 01:43:24
    because if we have an informal process,
  • 01:43:29
    it will only lead to trouble.
  • 01:43:33
    So that's something for us to consider. If you
  • 01:43:37
    look on slide six of this presentation, it talks about how
  • 01:43:41
    some of the binding documents can have a different change
  • 01:43:45
    control process.
  • 01:43:48
    Correct.
  • 01:43:51
    So maybe we can create one where ERCOT
  • 01:43:57
    has an opportunity to say no to dashboard requests
  • 01:44:02
    and we can develop a process around that.
  • 01:44:06
    Because if we have a. I don't want to get in a place where
  • 01:44:10
    we have to argue that some systems aren't systems.
  • 01:44:15
    So, you know, I understand this is
  • 01:44:19
    relatively new. I'm not asking you to react on the fly. You might want to
  • 01:44:22
    think about it, but I don't think that this is a
  • 01:44:26
    tenable, as suggested.
  • 01:44:29
    So, Eric, would you like me to reach out to you and work
  • 01:44:32
    with you with this? Sure. Okay. I can do
  • 01:44:36
    that. I appreciate it,
  • 01:44:39
    Rory.
  • 01:44:42
    Yes. Thanks. I was just going to say,
  • 01:44:46
    just a little bit louder. It's kind of quiet.
  • 01:44:49
    Sorry. They look at me funny when I talk
  • 01:44:53
    loud in the office. So I just
  • 01:44:56
    wanted to ask if, regardless what we end
  • 01:45:00
    up with, as the process flow,
  • 01:45:03
    somewhere in here, there needs to be a.
  • 01:45:07
    A provision of the information regarding up
  • 01:45:11
    or down, whether or not these get done back to market
  • 01:45:15
    participants, so that we know what's going on and, if necessary,
  • 01:45:19
    you know, we can discuss these with ERCOT,
  • 01:45:23
    you know, whether they get the. The ability to
  • 01:45:26
    say yes or no is immaterial.
  • 01:45:30
    But I would really like to understand, you know, how it is. It's going to
  • 01:45:33
    be reported, so that if necessary, it could be discussed
  • 01:45:37
    by the market participants. Thank you.
  • 01:45:41
    Thank you, Roy. Ian?
  • 01:45:45
    Thank you, Roy.
  • 01:45:49
    I agree with you, but I actually think it needs to be much
  • 01:45:52
    stronger. I think anything that's proposed to
  • 01:45:56
    ERCOT under one of these processes needs to be public
  • 01:46:00
    very much, kind of how Eric is saying,
  • 01:46:03
    it seems like we're reinventing the wheel for something we have.
  • 01:46:07
    I'm fine with creating a,
  • 01:46:13
    like a D&D, RR dashboards and design
  • 01:46:17
    revision requests, or some process that mimics what we already have,
  • 01:46:21
    which. Which utilizes ERCOT.com quote s already,
  • 01:46:24
    process flow and such. Um, if we need to give
  • 01:46:28
    ERCOT additional, um, ability to
  • 01:46:32
    veto it. Um,
  • 01:46:37
    I'm a little leery of that. I think ERCOT
  • 01:46:40
    has plenty of ability to appeal to the board at this point.
  • 01:46:44
    Um, as it's a completely independent board with
  • 01:46:47
    no stakeholder representation. Um, even unanimous,
  • 01:46:52
    um, decisions by TAC can be easily overturned
  • 01:46:55
    at the board if ERCOT can show the board that
  • 01:46:58
    it is negative to ERCOT.
  • 01:47:03
    So I understand that we don't want to use SCR's anymore, but I do think
  • 01:47:07
    we need to utilize something that we already have
  • 01:47:11
    and have experience with and already have groundwork to
  • 01:47:15
    use. I also would like to see
  • 01:47:18
    it move a little faster.
  • 01:47:22
    As Eric said, we've used SCR's previously for
  • 01:47:26
    the website.
  • 01:47:29
    We've been told now that our stakeholders have now been
  • 01:47:32
    told that SCR is not appropriate. I think if
  • 01:47:36
    ERCOT does not wish to use SCR's, I think that process
  • 01:47:40
    needs to be outlined and delivered to stakeholders
  • 01:47:44
    very quickly. Because if there
  • 01:47:47
    are issues with the website that
  • 01:47:51
    stakeholders find that are, let's say there's something that is inaccurate,
  • 01:47:55
    and ERCOT does not wish to show that they were inaccurate for
  • 01:47:59
    years on this. I think it's important that there
  • 01:48:03
    is a train of public
  • 01:48:07
    documents that show that this was brought to them or cut us, said no or
  • 01:48:11
    got us rejected, etcetera. And I do think that
  • 01:48:14
    process needs to be developed pretty quickly to continue having
  • 01:48:18
    that ability.
  • 01:48:22
    Thank you. Okay, so we have a cleared queue.
  • 01:48:26
    And I just want to say thank you again to ERCOT for being here this
  • 01:48:29
    afternoon and for having the conversations quick,
  • 01:48:36
    like a formal question. So I know that when we've had conversations,
  • 01:48:40
    and we talked about it last month as well,
  • 01:48:43
    what were we, I know that y'all
  • 01:48:47
    have been in conversation with the still mills as
  • 01:48:50
    far as 1226 itself. What were the plans to do
  • 01:48:53
    with that NPRR at this point moving forward? And I don't know if, Mark,
  • 01:48:56
    if that's better for you. Okay, go ahead.
  • 01:49:05
    Thank you. Amy.
  • 01:49:16
    So before I get into that, we try to get back to
  • 01:49:20
    Bob's question about, is this an NPRR
  • 01:49:23
    or is this something else?
  • 01:49:26
    First of all, the work that I was asked to do was to get
  • 01:49:30
    with Floyd, talk through what he wrote in his
  • 01:49:34
    NPRR, and figure out if we can make, if we
  • 01:49:37
    can make that a deliverable type project or not. Okay. It was just
  • 01:49:41
    really getting more information from Floyd. From what
  • 01:49:44
    he told me. He doesn't, I mean, he wrote it as
  • 01:49:48
    if he wanted it to be a dashboard because he didn't know
  • 01:49:52
    this mess that we just discussed and how to deliver. I mean,
  • 01:49:56
    how it should be, be presented, I guess, to the stakeholders.
  • 01:50:00
    He was fine with it if it not a dashboard,
  • 01:50:03
    just the data itself, as long as it can be made available,
  • 01:50:08
    like through ICCP or something. So obviously, if we. So I'm
  • 01:50:11
    not here to say which way. Give a recommendation of which way it should go.
  • 01:50:15
    Maybe that's for the stakeholders to discuss if the,
  • 01:50:19
    if this goes forward or not. But if it's,
  • 01:50:22
    if it goes through ICCP, that should be through an NPRR
  • 01:50:26
    because we would change section. There's a section of the protocols,
  • 01:50:30
    six having to do with real time ERCOT activities. I think that's
  • 01:50:33
    where it probably go into. If it's a dashboard, then it's
  • 01:50:37
    going to have to follow the new procedure that I guess you're going to
  • 01:50:40
    hear about in the. In a couple months. Okay.
  • 01:50:44
    So hopefully those, I mean, I know that's not an answer, but that's,
  • 01:50:47
    it's probably one way or another it could go, depending on the
  • 01:50:51
    delivery mechanism for the data. Is that clear?
  • 01:50:56
    Yeah, that's fine. I think I just point out that until there's a
  • 01:51:00
    new process, probably continuing down
  • 01:51:03
    that process is the right way for ERCOT to
  • 01:51:07
    consider this, given that
  • 01:51:10
    there is no other process. Well, I. Well, again, maybe I
  • 01:51:14
    shouldn't speak for myself. We can just. I would think
  • 01:51:18
    the NPRR is probably a good starting point. We can develop it
  • 01:51:21
    and then if it changes course, then we'll change course. Okay. But we can
  • 01:51:24
    work through the details through originally an NPRR.
  • 01:51:28
    That's what I would think. Okay. So let me get into the.
  • 01:51:32
    What we learn and what I wanted to share with
  • 01:51:35
    the group. I thought this was really important.
  • 01:51:38
    Before we close out the last comment, there's one
  • 01:51:42
    more relevant item that I just want to point out, and I'm not trying to
  • 01:51:45
    create an argument, but previously ERCOT
  • 01:51:49
    has approved SCR755,
  • 01:51:52
    which was titled ERCOT.com website enhancements.
  • 01:51:56
    So I think unless the process has changed
  • 01:52:00
    since then, we just need to
  • 01:52:03
    recognize that SCR's have, as recently
  • 01:52:07
    as an NRG approved NRG
  • 01:52:11
    recommended SCR just a couple years ago, affected the ERCOT website.
  • 01:52:16
    So that's why I was trying to
  • 01:52:19
    make the point about if we need to change
  • 01:52:22
    that process, I'm open to changing that process. But we have an existing process
  • 01:52:26
    that's worked as recently as a couple years ago where
  • 01:52:30
    SCR's are affected. The ERCOT website.
  • 01:52:33
    Thank you, Eric. That was actually one of the questions asked. So appreciate that,
  • 01:52:39
    Mark, go ahead. Okay. So when
  • 01:52:43
    I first got involved with it, it's the very first thing that I found was
  • 01:52:47
    important information for me, and I wanted to share it right up front with this
  • 01:52:51
    group, is, after speaking with Floyd, I want to make sure it's clear
  • 01:52:55
    of what his proposal was and what it
  • 01:52:58
    is not. His proposal
  • 01:53:02
    would be, it would only. The data would
  • 01:53:06
    only be an indicator to the market that demand
  • 01:53:10
    response was occurring. I want
  • 01:53:13
    to make sure what it is not would be a representation of,
  • 01:53:17
    in aggregate, the value of demand response
  • 01:53:21
    that is occurring in real time within ERCOT. So it
  • 01:53:25
    would only be an indicator and it would only be an indicator based
  • 01:53:29
    on the state estimated load points that ERCOT would choose
  • 01:53:33
    to identify if demand response
  • 01:53:37
    was going on. Okay, so, with that in
  • 01:53:40
    mind, so what else? So,
  • 01:53:45
    and this was pretty clear in the language he wrote, though,
  • 01:53:49
    is that ERCOT would ident need to identify state
  • 01:53:53
    estimated load points.
  • 01:53:56
    That. And we could go through a process of.
  • 01:54:00
    Of these load points that are showing, have historically demonstrated
  • 01:54:04
    that they respond to things such as 4CP to
  • 01:54:08
    prices. It could even be to ERCOT's
  • 01:54:13
    conservation notices. We can do the work to identify
  • 01:54:17
    those points that we think would be candidates to include
  • 01:54:21
    in this aggregation. That's all doable.
  • 01:54:26
    And then once you identify all those load points, you just will aggregate that
  • 01:54:29
    altogether and put that into a single data stream.
  • 01:54:34
    The next piece, though, is to calculate. He was requesting
  • 01:54:37
    that we calculate how much demand response was occurring
  • 01:54:42
    based on that set of state estimator points.
  • 01:54:46
    And he was requesting. He was stating that it'd be like,
  • 01:54:49
    within a two hour window, you would. ERCOT would determine what
  • 01:54:53
    the maximum load was of, in aggregate, for all of
  • 01:54:57
    those load points, and you just do a comparison between that
  • 01:55:01
    value and then, in real time,
  • 01:55:04
    what those load points are showing. And after consulting with
  • 01:55:08
    Carl Reich on this, because he'd probably be the one that would be doing a
  • 01:55:11
    lot of the upfront work,
  • 01:55:14
    that would be a problem only because
  • 01:55:18
    we know for a fact that just take.
  • 01:55:22
    And I'm actually already getting into my next slide.
  • 01:55:26
    Carl's already shown when we have 4CP events, 4CP events
  • 01:55:30
    can last for four or 5 hours long.
  • 01:55:35
    Many cases, they start deploying maybe around 03:00 in the afternoon,
  • 01:55:38
    and we've seen them stay deployed all the way up till eight in the evening.
  • 01:55:42
    If you're only using a two hour window to do this evaluation,
  • 01:55:46
    you're probably going to get a lot of false positives about
  • 01:55:50
    how much demand response is going on. So our recommendation
  • 01:55:53
    would be that we would like the
  • 01:55:59
    NPRR to be changed,
  • 01:56:02
    modified. That gives ERCOT the flexibility of how
  • 01:56:06
    we would do this. Look back on these
  • 01:56:09
    state estimator loads to determine what the maximum value was
  • 01:56:13
    for those points during a window
  • 01:56:17
    of time. That would be basically the baseline that we would use to
  • 01:56:20
    calculate the demand response. So that's a key point,
  • 01:56:24
    is if we go down the point of an NPRR, we would suggest
  • 01:56:28
    we modify the language to give ERCOT the flexibility
  • 01:56:31
    of how to do that calculation so that it makes sense
  • 01:56:35
    for the best, I mean, for the best estimate
  • 01:56:39
    of what we're trying to do to provide, to provide the delta between
  • 01:56:43
    the maximum amount and real time load on those data points.
  • 01:56:48
    There are only a few other minor issues that we'd actually
  • 01:56:51
    probably even need to understand. And I think the
  • 01:56:55
    more important one, more important ones to just state
  • 01:56:58
    here is there
  • 01:57:01
    are going to be some state estimator points that ERCOT
  • 01:57:06
    would probably identify. Highly likely that
  • 01:57:09
    our ERCOT would identify that we'd want to use.
  • 01:57:13
    But we got to be very careful that we
  • 01:57:16
    don't communicate what state estimator points we are
  • 01:57:20
    actually including in our aggregation, because I think there's
  • 01:57:24
    a lot of confidentiality issues that we
  • 01:57:27
    could get into by doing that. So that's going to need
  • 01:57:31
    to stay only within ERCOT to understand what points we're using
  • 01:57:34
    and not communicate that out to the public. And the next thing is,
  • 01:57:38
    we'll have to think a little bit about how transmission switching
  • 01:57:42
    could impact this in real time as well,
  • 01:57:46
    what type of information we may need to
  • 01:57:49
    understand if transmission switching occurring. And there's
  • 01:57:53
    loads that are going in and out of the state estimator
  • 01:57:56
    points that would also possibly give false
  • 01:58:00
    indicators that we have demand response.
  • 01:58:03
    So it's all. So the bottom line to what I was asked
  • 01:58:06
    to do is, can we make this, can we talk to Floyd
  • 01:58:11
    and get enough information to make this a meaningful
  • 01:58:14
    project? ERCOT feels confident we can,
  • 01:58:18
    but ultimately, it will be up to stakeholders to determine
  • 01:58:22
    if this information is of value that
  • 01:58:26
    we would need to do that, and then we would get back involved and help
  • 01:58:29
    Floyd modify, and we could stay with the NPRR for right now,
  • 01:58:33
    modify the language in the NPRR to give ERCOT the flexibility that we feel we
  • 01:58:37
    would need to do. That's really all I've got to
  • 01:58:40
    share. Thank you, Mark. We do have one comment
  • 01:58:44
    from John Varnell.
  • 01:58:47
    Yes, I think that Mark has
  • 01:58:51
    most of the problems written down,
  • 01:58:54
    but I really believe that there have to be
  • 01:58:57
    a profile built of those state estimator points,
  • 01:59:02
    and to really understand
  • 01:59:08
    if there is a real, uh,
  • 01:59:11
    decrease in, uh,
  • 01:59:14
    in, or if there is really a demand response
  • 01:59:18
    thing going on because of the way some of these
  • 01:59:21
    people do it. They don't just cut it off.
  • 01:59:25
    And it's a. I mean, it's a.
  • 01:59:28
    They start decreasing,
  • 01:59:31
    like Mark said, hours ahead sometimes and
  • 01:59:35
    keep it decreased for a long time through these things.
  • 01:59:39
    So I think that there's some. Still some problems
  • 01:59:42
    with how to use the data and what it really means.
  • 01:59:46
    And I. That's where I'm having a problem,
  • 01:59:49
    is how is
  • 01:59:53
    this data going to be really meaningful if it's not
  • 01:59:57
    really right? And so I just don't want to
  • 02:00:00
    spend extra money doing something that
  • 02:00:04
    were. That I don't believe will be meaningful.
  • 02:00:08
    Thank you,
  • 02:00:11
    John. That's a really good point.
  • 02:00:15
    And I think Carl has identified that as well.
  • 02:00:19
    And I added a bullet point on my presentation.
  • 02:00:23
    I just didn't mention it. But we have to also be very careful that those
  • 02:00:26
    points that we do pick are.
  • 02:00:29
    Are very much nonconforming.
  • 02:00:32
    The loads that behind those points are nonconforming. In other words,
  • 02:00:35
    they're not going to be varying with weather, temperature,
  • 02:00:38
    things such as that. They truly are just things that
  • 02:00:42
    operationally would turn up or down.
  • 02:00:47
    And yes, it goes beyond just that. But we got to be very careful
  • 02:00:51
    when we're picking these points that we don't get.
  • 02:00:54
    Points that are going to give false indicators of demand response.
  • 02:01:00
    Eric, these are some great points.
  • 02:01:04
    Mark, I appreciate reviewing this of
  • 02:01:07
    the merits. Another, I think related issue is when
  • 02:01:12
    does a load change its consumption
  • 02:01:17
    based on a process issue and not a price
  • 02:01:20
    issue? So,
  • 02:01:24
    you know, in the example of a steel mill for, you know, they might
  • 02:01:28
    stop running a furnace because of
  • 02:01:32
    the current needs to melt a car.
  • 02:01:36
    Like, you don't need to do that right now. So you stop the furnace
  • 02:01:40
    and being able to tell the difference between that and a
  • 02:01:44
    price based. I'm stopping melting cars right now because the price is too
  • 02:01:48
    high. I don't know how this system
  • 02:01:52
    would do that. And maybe you can iterate over time and it can improve over
  • 02:01:54
    time, but this kind of feedback on the merits is appreciated
  • 02:01:58
    and I'm happy to keep it on the table.
  • 02:02:05
    We appreciate all the presentations from ERCOT
  • 02:02:08
    and the conversations. That sounds like we're going to keep those conversations going.
  • 02:02:12
    And no motion or no activity needed on
  • 02:02:16
    1226 right now. Go ahead, Ian.
  • 02:02:20
    Just wanted to back up what Eric said.
  • 02:02:23
    Having more information is something our shop is very
  • 02:02:27
    appreciative of. And so taking the steps we can
  • 02:02:30
    to provide that information, even if we know there may
  • 02:02:34
    be flaws and is important to us. I understand ERCOT's
  • 02:02:38
    hesitancy and Eric's hesitancy to put out information that may
  • 02:02:42
    be incorrect. But the more information we can put out
  • 02:02:45
    there, and the more the market gets to learn from that information, I think the
  • 02:02:48
    better it is. I don't. I think with the changing
  • 02:02:53
    the way the grid is changing with so much load,
  • 02:02:57
    participating in different aspects,
  • 02:02:59
    this is information that we all need disseminated
  • 02:03:04
    more to us, more in real time. So thank you very much for working
  • 02:03:07
    on this.
  • 02:03:11
    Thank you.
  • 02:03:13
    Okay,
  • 02:03:17
    so we'll keep those conversations on 1226 going.
  • 02:03:20
    In the interest of time, I'm going to pause
  • 02:03:24
    the tabled items real quick and we're going to go
  • Item 8.5 - NPRR1249, Publication of Shift Factors for All Active Transmission Constraints in the RTM
    02:03:27
    to 1249. I know Steve Reedy has a time
  • 02:03:31
    certainty that he needs to get out of here for, so we're going to jump
  • 02:03:35
    forward to section eight under 1249.
  • 02:03:38
    Steve, do you want to lay out your publication of shift factors
  • 02:03:42
    for all active transmission constraints? Yeah. Thanks for being flexible
  • 02:03:45
    with time. I have a 330.
  • 02:03:48
    The. This is. And so, Steve Reedy,
  • 02:03:53
    Synvue consulting. And I just want to be clear that this is a behalf of
  • 02:03:56
    Synvue consulting, not on behalf of a client.
  • 02:04:01
    The background is that ERCOT publishes
  • 02:04:05
    shift factors. That is how various generators affect
  • 02:04:10
    flows on constraints. They publish those
  • 02:04:14
    shift factors for the real time market,
  • 02:04:18
    only for the constraints that end up binding
  • 02:04:22
    in the auction. So they calculate that
  • 02:04:26
    ERCOT systems determine a number of interesting
  • 02:04:30
    constraints that might be a problem in a real time market
  • 02:04:34
    run. Those are called active constraints.
  • 02:04:37
    They calculate shift factors for all of the active constraints.
  • 02:04:42
    It sends that information over to the market system.
  • 02:04:46
    The market runs, SCaD runs, using all
  • 02:04:49
    those shift factors. Only some of
  • 02:04:53
    those constraints end up being binding.
  • 02:04:57
    And what ERCOT is doing. I mean,
  • 02:05:01
    I don't mean to. It sounds like I'm beating
  • 02:05:05
    on ERCOT. It's just that ERCOT doesn't publish all the shift factors, only the
  • 02:05:08
    ones for the binding constraints. If you
  • 02:05:12
    want to rerun SCADA and change
  • 02:05:16
    things, like my company does, and see how that would have affected
  • 02:05:19
    the market run, it would be helpful to
  • 02:05:23
    have all of those active constraints. Also, if you
  • 02:05:26
    want to shadow the constraint competitiveness test,
  • 02:05:30
    you need to have all of those constraints. And finally,
  • 02:05:34
    this isn't a formal NPRR yet, but the proposed
  • 02:05:38
    NPRR that
  • 02:05:42
    would mitigate batteries. If you
  • 02:05:46
    want to shadow that process and examine that
  • 02:05:49
    process, you need all of the constraints. So all
  • 02:05:53
    the shift factors for all of the constraints. So,
  • 02:05:56
    ERCOT's already calculating this information.
  • 02:06:00
    All that this NPRR does is ask for ERCOT
  • 02:06:04
    to include that information in the same
  • 02:06:08
    reports where it includes the binding constraint information.
  • 02:06:12
    So it's a relatively simple. Thanks, Corey. It's a relatively
  • 02:06:15
    simple language change. And I did reach out.
  • 02:06:20
    I've discussed this with ERCOT, and Dave
  • 02:06:24
    Maggio said that he was going to be on the line and available for
  • 02:06:27
    questions if anyone has any curiosity about ERCOT's
  • 02:06:31
    feelings on this. NPRR.
  • 02:06:35
    Thank you, Steve. Any thoughts or comments on
  • 02:06:39
    1249?
  • 02:06:45
    Bill?
  • 02:06:49
    I think in general, more transparency, more data
  • 02:06:53
    is a good thing. I think the key with this one is assessing. Can you
  • 02:06:56
    speak up? We can't hear you. Impact.
  • 02:07:01
    I think more transparency is a good thing. More data access
  • 02:07:05
    is a good thing. I think the key with this one is assessing the impact
  • 02:07:08
    analysis, which requires approval first, which we support.
  • 02:07:12
    Thank you, Bill. Blake.
  • 02:07:16
    Blake Cole, LCRA Echo Bill's comments and agree with
  • 02:07:21
    Steve's reasoning behind getting these active constraints posted.
  • 02:07:25
    What I'm curious about, and maybe this is what Bill
  • 02:07:29
    was indicating, but if Dave Maggio could maybe
  • 02:07:33
    give some context on how large this report would
  • 02:07:36
    be in some cases, if you're actually publishing all of
  • 02:07:40
    the active transmission constraints,
  • 02:07:44
    Dave, do you have that level of context
  • 02:07:47
    right now?
  • 02:07:50
    Hopefully you can hear me. I switched to my,
  • 02:07:54
    your audio as opposed to my earbuds. Per.
  • 02:08:00
    We can. I don't have a good feel off the top of
  • 02:08:03
    my head. Maybe if I had to make a guess, it could,
  • 02:08:10
    you know, in some cases, double or triple the size as,
  • 02:08:15
    as folks know, we only activate a Susan
  • 02:08:19
    that obviously will vary considerably throughout the day,
  • 02:08:22
    but I think that would be the potential size of the file. Now,
  • 02:08:25
    the way we post this tend to be more. We're not posting a
  • 02:08:29
    big historical file that includes days and days of
  • 02:08:33
    information. It may actually just be per sket interval, so it
  • 02:08:38
    will increase those file sizes. But the files themselves are
  • 02:08:42
    pretty focused.
  • 02:08:47
    Thanks, Dave. Well,
  • 02:08:50
    I see your comment in the chat. How does everybody feel about putting
  • 02:08:54
    this on the combo ballot as submitted? Okay,
  • 02:08:58
    we'll wait to see what the IA says and we'll add this to.
  • 02:09:02
    All right, Corey, thank you. Thank you, Steve.
  • 02:09:06
    Yeah, thanks, everyone.
  • 02:09:10
    See how easy and painless that was if you just confined your revision request
  • 02:09:14
    to five words or less?
  • 02:09:27
    Excellent. Okay, so that takes us back to the tabled
  • 02:09:30
    items. I think the next item that was possibly
  • 02:09:34
    up for consideration or some conversation would be 1235.
    EditCreate clip
  • Item 7.9.1 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
    02:09:37
    That's coming to us from ERCOT. This has been discussed
  • 02:09:41
    extensively in the stakeholder process. ROS did endorse
  • 02:09:45
    the NOGRR264 this week.
  • 02:09:50
    We did have some imm comments that were filed in support of
  • 02:09:54
    1235. Wanted to see if there was any
  • 02:09:57
    thoughts or conversations. Go ahead, Eriche.
  • 02:10:01
    I'm okay advancing this, but I just like to reiterate my
  • 02:10:04
    desire for ERCOT to try to give us some estimate of
  • 02:10:08
    how much of this they want to buy that's going to have such
  • 02:10:12
    a big impact on the market if they buy a lot of it.
  • 02:10:15
    And given our experience with ECRS,
  • 02:10:18
    we'd really like for ERCOT to make an attempt to give
  • 02:10:23
    us a number, even if they wouldn't say, this is our
  • 02:10:26
    current best guess and we might revise it in the future, but just an
  • 02:10:30
    indication of size would be extraordinarily helpful.
  • 02:10:34
    Thank you, Eric.
  • 02:10:39
    Katie Rich. Yeah.
  • 02:10:43
    Just wanted to point out we had this discussion at WMS yesterday.
  • 02:10:48
    I asked it to remain tabled, and we're going to be taking up at a
  • 02:10:51
    special SAWG meeting on the 27th.
  • 02:10:55
    So I would ask that it remain tabled here for another month.
  • 02:10:59
    Appreciate that, Katie. Thank you. All right, so we'll keep the conversation going
  • 02:11:03
    at September 27 SAWG, and then we'll take a look at this
  • 02:11:06
    next month. Bryan,
  • 02:11:12
    nothing bad. I'm great with that outcome. Thank you.
  • 02:11:20
    Okay, so we're going to leave this table and then.
  • Item 7.9.3 - NPRR1239, Access to Market Information
    02:11:27
    Okay, so that takes us to 1239.
  • 02:11:32
    This is coming to us from ERCOT.
  • 02:11:37
    We.
  • 02:11:40
    So this one. Hold on, guys. I'm sorry.
  • Item 7.9.4 - NPRR1240, Access to Transmission Planning Information
    02:11:44
    If it helps, in the interest of time, 1239 and 1240 were
  • 02:11:48
    very similar in nature.
  • 02:11:51
    ROS and ROS has now endorsed them both as submitted.
  • 02:11:55
    Okay, so we asked for ROS feedback. We've got it.
  • 02:11:58
    It might be good for combo, if that's what I was trying to remember.
  • 02:12:01
    I knew that there was one. I was like, it was at the one before
  • 02:12:03
    or after? So 1239 and 1240s looks like this one might be good for
  • 02:12:07
    combo. Okay. Getting head nods.
  • 02:12:12
    Thank you, Blake.
  • Item 7.9.5 - NPRR1241, Firm Fuel Supply Service - FFSS - Availability and Hourly Standby Fee
    02:12:17
    And then 1241. WMS filed some comments this morning asking us
  • 02:12:21
    to keep this table so this conversation can keep going
  • 02:12:24
    at WMWG. Is there any other
  • 02:12:28
    items under the tabled list that we didn't raise that anybody wants to talk about?
  • Item 7.9.7 - NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities
    02:12:35
    Bill Barnes. Thanks, Diane. I want
  • 02:12:38
    to update on NPRR1243.
  • 02:12:41
    When reviewing that NPRR, we had some concerns
  • 02:12:47
    about notice provided to
  • 02:12:50
    market participants when ERCOT's disclosing confidential information to
  • 02:12:54
    major regulatory agencies. ERCOT legal
  • 02:12:58
    did reach out to me and they have some concerns with. With CFTC.
  • 02:13:03
    There's an order that the CFTC approved
  • 02:13:07
    about ten years ago that would challenge
  • 02:13:13
    pre disclosure of information before
  • 02:13:17
    submission to pre disclosure notice
  • 02:13:20
    to the market participant. We discussed about potentially
  • 02:13:24
    modifying that to be post disclosure
  • 02:13:27
    notice after ERCOT discloses information
  • 02:13:31
    to the CFTC. They felt like that could still violate
  • 02:13:35
    the spirit of the CFTC order. We did
  • 02:13:38
    confirm in discussion that ERCOT doesn't disclose information very
  • 02:13:42
    often to the CFTC, which makes sense because they regulate financial
  • 02:13:46
    markets, not physical markets like ERCOT. That addressed our concerns.
  • 02:13:51
    So I will, I am planning to file up comments
  • 02:13:55
    that remove the edit
  • 02:13:58
    of the CFTC language and restore the
  • 02:14:02
    disclosure requirement for NERC, FERC and
  • 02:14:06
    cyber security agencies.
  • 02:14:11
    Fantastic. Thank you. Okay. Yep. Thanks.
  • 02:14:17
    Any other thoughts or comments on 1243?
  • 02:14:21
    Eric, go ahead.
  • 02:14:26
    One of the questions I've had, and I don't even answer to this today,
  • 02:14:31
    but to ERCOT legal, is there any situation where a
  • 02:14:34
    subpoena is or isn't required in order to release the information?
  • 02:14:38
    Does that need to be covered as part of the process?
  • 02:14:49
    Not hearing anything, Eric. I'm happy to wait.
  • 02:14:52
    Okay, Martha,
  • 02:14:55
    thank you. I think I mentioned this last month, but I did want to reiterate
  • 02:14:59
    that Oncor is working on comments to this as well. Bill, I'm happy to coordinate
  • 02:15:02
    with you offline on the timing so that we're not, you know,
  • 02:15:06
    introducing more edits to reconcile with each other. But we've
  • 02:15:10
    also had couple of conversations with the sponsors of this,
  • 02:15:13
    and I'm hoping we can work through a couple of concerns
  • 02:15:17
    that Oncor has that can be discussed next month through comments.
  • 02:15:21
    Thanks. Thank you, Martha.
  • 02:15:26
    Okay.
  • 02:15:30
    All right. I think that take us. Takes us through the tabled items.
  • Item 8 - Review of Revision Request Language - Vote - Diana Coleman
    02:15:35
    Go to. Section 8,
  • Item 8.1 - NPRR1245, Additional Clarifying Revisions to Real-Time Co-Optimization
    02:15:40
    NPRR1245 comes to us from ERCOT. This is some of the revisions to the protocols
  • 02:15:45
    based on the RTC+B project.
  • 02:15:49
    There's been some minor desktop edits. I wanted to see if ERCOT
  • 02:15:53
    wanted to lay this one out for us and see what the will of archive
  • 02:15:57
    is. Go ahead, Dave. Hi, Danny. Yes, thank you very
  • 02:16:00
    much. Again, as you kind of laid out, we had
  • 02:16:04
    filed this NPRR to essentially address
  • 02:16:08
    some clarifications and things like that. The catch up language that
  • 02:16:12
    has changed since the passing of the RTC NPRRs,
  • 02:16:16
    kind of with some of the other additional changes that have been layered over top.
  • 02:16:21
    So I guess there's sort of a number of changes
  • 02:16:25
    in there. I'll mention for the vast
  • 02:16:28
    majority of these, we discussed them all with the RTC+B
  • 02:16:31
    task force. We've actually had a couple of meetings since they were initially
  • 02:16:35
    filed. Really? No edits since
  • 02:16:38
    then, except that I would note that we also filed
  • 02:16:42
    some comments earlier this month, about a
  • 02:16:46
    week ago, and happy to kind of talk about those.
  • 02:16:49
    There's essentially two flavors of those.
  • 02:16:52
    The first is, and these were not changes that
  • 02:16:56
    we originally found, of course, when we filed it, were things related to
  • 02:17:00
    NPRR1015 and NPRR1093. So these were
  • 02:17:03
    changes related to Ansli services that,
  • 02:17:07
    again, all happened after we had passed the RTC NPRRs.
  • 02:17:12
    Really, the impacts here were to some of the section
  • 02:17:16
    three 2.5 disclosure type reporting
  • 02:17:21
    where we're catching up some of the real time market
  • 02:17:24
    language with changes that we made to
  • 02:17:27
    the day ahead market language about reporting. In addition to that,
  • 02:17:31
    we didn't necessarily call out within the RTC protocol the
  • 02:17:35
    fact that load resources could provide non spin. So we were, again, just catching
  • 02:17:38
    up the language with that. The other
  • 02:17:42
    flavor was some settlement equations. I want to
  • 02:17:45
    say, go through those in detail. Perhaps Maggie or someone
  • 02:17:48
    can be on if you do have some questions. But these were, again,
  • 02:17:52
    some things that we found after filing the NPRR. But we actually
  • 02:17:55
    have discussed these with the task force already.
  • 02:17:59
    And again, no questions have been raised by the task force up to this
  • 02:18:03
    point. As you mentioned, we did have one desktop edit,
  • 02:18:07
    and I guess we'd be happy to talk about that as well.
  • 02:18:09
    But essentially, let me just cover it and then Cory can
  • 02:18:13
    scroll down to it. One of the things that we just discovered
  • 02:18:18
    yesterday, as we again, have been going through the requirements and
  • 02:18:22
    design for RTC, was we had
  • 02:18:25
    made some changes to the language, and we had captured this in the language
  • 02:18:29
    up above in changing some of the ord c parameters
  • 02:18:32
    to move from that 2000 to 3000 to adjust
  • 02:18:36
    for the new minimum contingency level that's used for those calculations.
  • 02:18:40
    While we caught it in the formula in the gray box up above, we had
  • 02:18:44
    missed that point down below in sub paragraph c. So the desktop
  • 02:18:48
    edit would simply be able to make that change in sub paragraph
  • 02:18:51
    c to make it from 2000 to 3000.
  • 02:18:55
    So I'll stop there and see what questions you all have for me.
  • 02:19:00
    Thank you. Dave,
  • 02:19:02
    any thoughts or questions on
  • 02:19:07
    1245?
  • 02:19:12
    Okay, Blake, I see your
  • 02:19:16
    motion for combo ballot. What is everybody
  • 02:19:20
    else's thoughts? Combo.
  • 02:19:23
    Okay, Corey, let's go ahead and add 1245
  • 02:19:28
    to the combo ballot.
  • 02:19:34
    Thank you, Dave.
  • 02:19:39
    All right, when Corey gives you the thumbs up, you know you.
  • 02:19:43
    You're doing okay. All right, so that takes us to 1246.
  • Item 8.2 - NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era
    02:19:46
    Also coming to us from ERCOT, some language
  • 02:19:50
    alignment with the single model era for energy storage resources.
  • 02:19:55
    Wanted to see if ERCOT wanted to tee this one up as well.
  • 02:19:59
    Ken, go ahead. Yeah. So this is
  • 02:20:02
    similar to the previous 1245. This is
  • 02:20:06
    an NPRR that does kind of a catch up and
  • 02:20:10
    eliminates the combo model and
  • 02:20:13
    goes to the single model, something that needs to go live.
  • 02:20:16
    The day we go live with RTC+B.
  • 02:20:20
    We posted this back in the end of July.
  • 02:20:23
    We talked about it at RTC+B.
  • 02:20:26
    My understanding is that we wanted the subcommittees to take a look at this
  • 02:20:31
    NPRR, and there's also a NOGRR and there's a
  • 02:20:34
    PGRR and there's an other binding document.
  • 02:20:38
    But I think for today we do have some comments
  • 02:20:42
    that we're working on for this NPRR, and I
  • 02:20:45
    think we need a little more time to work through those comments. We may have
  • 02:20:49
    found a couple of inadvertent misses and some other things.
  • 02:20:52
    So that's the setup. And I don't know
  • 02:20:55
    what if you guys need to assign this to subcommittees or
  • 02:20:59
    how that really works, but that's it.
  • 02:21:03
    Thank you, Katie. Rich.
  • 02:21:07
    Well, you've got the language up on the screen, but just wanted you to
  • 02:21:11
    know ROS kind of wanted to table the whole
  • 02:21:14
    package, the whole four revision requests, and see
  • 02:21:19
    how the RTC+B meeting goes tomorrow.
  • 02:21:22
    And then we'll take it up in October.
  • 02:21:26
    Okay, that sounds like we may want to keep
  • 02:21:30
    this here and tabled and wait on the conversation.
  • 02:21:34
    Does that sound like something that's doable?
  • 02:21:38
    So keep it table or table it, right. I was just going
  • 02:21:41
    to question table it and keep it at PRS. Or do you want to table
  • 02:21:43
    it in, formally refer it to ROS alongside the. There's an NOGRR and
  • 02:21:47
    PGRR over there as well. So six, one, half dozen. The other table
  • 02:21:50
    is the important part. But just if anybody would benefit from a formal
  • 02:21:53
    referral of the issue to ROS, we can TAC that on as well.
  • 02:21:57
    Go ahead, Ken? Yeah, I'm interested in trying to keep this thing moving and
  • 02:22:01
    making sure we can keep track of where it is. So whatever we can do
  • 02:22:04
    to keep it moving, let's try to do that. Okay.
  • 02:22:08
    Do we want to keep it here or do we want to formally.
  • 02:22:12
    We can keep it here and keep an eye on those conversations, and we can
  • 02:22:16
    have those comments like Katie was
  • 02:22:20
    referencing earlier on based on those conversations. So if
  • 02:22:23
    it sounds okay, I'm seeing some head nods. We'll keep it tabled here
  • 02:22:27
    at PRS, and then we'll stay apprised of those conversations,
  • 02:22:30
    Ken, to make sure that all the other associated changes with
  • 02:22:34
    those are staying alignment.
  • 02:22:37
    Okay.
  • 02:22:45
    And then next step is 1248. Is that correct,
  • Item 8.4 - NPRR1248, Correction to NPRR1197, Optional Exclusion of Load from Netting at EPS Metering Facilities which Include Resources
    02:22:48
    Tori? Yes, ma'am. Okay, so this one's
  • 02:22:52
    coming to us. ERCOT.
  • 02:22:57
    Yep. This one is an oops on my behalf.
  • 02:23:01
    So as 1197 was going through the February
  • 02:23:05
    PRS. Y'all recommended approval of a version of that NPRR
  • 02:23:09
    with some Oncor comments and some desktop edits from PRS.
  • 02:23:12
    However, when I built the February PRS report,
  • 02:23:16
    I neglected to conclude the last page. So we dropped the last
  • 02:23:20
    couple of revisions that were in the Oncor comments that y'all voted
  • 02:23:23
    on. And because they were not in that PRS report, they didn't
  • 02:23:26
    end up in the TAC report, which means they didn't end up in the board
  • 02:23:29
    report, which means they didn't end up in the PUC report. So 1197,
  • 02:23:34
    that was intending to clarify things, missed a couple of its clarifications
  • 02:23:38
    as a result. So what this NPRR does is
  • 02:23:41
    1197 already crossed the finish line. It's done.
  • 02:23:44
    These changes to a, b, and c are forklifted
  • 02:23:48
    out of the Oncor commons that you all voted on in February, now dropped into
  • 02:23:52
    a new NPRR to hopefully carry through and close the circle
  • 02:23:56
    on what y'all were trying to do on 1197. And you've got my deepest
  • 02:23:59
    apologies. Is this the first time you've made a mistake?
  • 02:24:04
    First documented case,
  • 02:24:07
    can't speak that. It's the population. However,
  • 02:24:11
    sample size is now one.
  • 02:24:15
    So this sounds like this might be a good one for a combo.
  • 02:24:19
    I would love for you to combo this to recommend approval as submitted.
  • 02:24:22
    Obviously, it's no impact. This is just cleanup language.
  • 02:24:25
    Okay, thank you. I'm getting a lot of nodes, so let's go ahead
  • 02:24:29
    and add this one as well. Thank you, Corey. Thank you all.
  • 02:24:35
    Okay, so that takes us. We did 1249 already. That takes
  • Item 8.6 - NPRR1250, RPS Mandatory Program Termination
    02:24:39
    us to 1250. That's coming to us from ERCOT.
  • 02:24:42
    We also did have some comments. Want to start off
  • 02:24:46
    with ERCOT, if they wanted to lay this out. And then, Michael, we can
  • 02:24:50
    get to yours. Diana, this is Calvin.
  • 02:24:53
    Can you hear me? Barely. Can you.
  • 02:24:57
    What about now? A little bit. Go ahead a
  • 02:25:01
    little bit. Okay. Well, this NPRR
  • 02:25:06
    is set to. It implements the HB1500,
  • 02:25:10
    the retirement, the RPS program.
  • 02:25:15
    And it's really that simple. It's meant
  • 02:25:18
    to be implemented, though, on September
  • 02:25:21
    1, 2025. And when you
  • 02:25:25
    read the comments, it seemed like it wasn't
  • 02:25:28
    clear or that this NPRR would
  • 02:25:32
    be implemented earlier than that. But our intention
  • 02:25:35
    is to retire the RPS program in
  • 02:25:39
    compliance with House bill 1500.
  • 02:25:46
    Okay, thank you,
  • 02:25:49
    Michael. Did you want to speak to your comments? And then we'll.
  • 02:25:52
    We'll go to the queue. Yeah. Thank you very much, Michael Jewell, on behalf of
  • 02:25:56
    Sia. And the question about
  • 02:26:00
    having. When it becomes effective. And making it,
  • 02:26:03
    you know, not earlier than September 1, 2025 is exactly
  • 02:26:07
    what we were concerned about. It wasn't clear from the, the face of
  • 02:26:11
    the filing as it is. Okay,
  • 02:26:16
    bill, kind of similar concern.
  • 02:26:21
    And Calvin, sorry for the late email on this.
  • 02:26:24
    We were worried about the section that removed
  • 02:26:29
    and the protected information status for transmission level customer
  • 02:26:33
    information that opted out. It sounds like
  • 02:26:37
    the timing, the plan
  • 02:26:40
    that you have, Calvin, for implementing this would address
  • 02:26:44
    our concerns. I think that the concern here is that we just don't
  • 02:26:48
    want, if this NPRR is approved, that you start to publish or
  • 02:26:51
    the confidentiality status
  • 02:26:55
    expires on all that information. We would. We would want
  • 02:26:59
    all that information to remain confidential and not
  • 02:27:03
    be publicized in any way or be able to be requested in any way.
  • 02:27:08
    Okay. Since that's the spirit of
  • 02:27:12
    the rule, is that it's confidential. That's in
  • 02:27:16
    section one three. I don't. Doesn't sound like, Calvin, that was your intent.
  • 02:27:20
    And in any way that once this is approved and that information
  • 02:27:24
    becomes public or able to be accessed,
  • 02:27:28
    we just would want to make sure that is super clear in this.
  • 02:27:33
    I don't know if there's a way to clean up the date on when this
  • 02:27:36
    becomes effective. In the protocol language, it feels
  • 02:27:40
    like without a gray box. Once this is approved, that confidentiality expires
  • 02:27:44
    immediately, which is a concern.
  • 02:27:47
    Understood. I can work on that to make it crystal clear
  • 02:27:51
    with legal. Much appreciated.
  • 02:27:59
    All right, Katie.
  • 02:28:02
    Thanks, Diana. Since there have been a couple of comments on the effective
  • 02:28:06
    date, and we had maybe a couple other items that we wanted to explore,
  • 02:28:10
    wanted to see if this could get reflected it over to WMS for more
  • 02:28:14
    discussion.
  • 02:28:19
    Okay. I think that might be a good idea.
  • 02:28:24
    Any other thoughts on tabling this
  • 02:28:27
    and sending it over to WMS?
  • 02:28:32
    Okay. All right, corey, so let's. Let's do that.
  • 02:28:36
    We can add that one to the combo.
  • 02:28:45
    Okay, guys, we only have two more.
  • Item 8.7 - NPRR1251, Updated FFSS Fuel Replacement Costs Recovery Process
    02:28:47
    NPRR1251 comes to us from ERCOT. This is updating the firm fuel
  • 02:28:52
    replacement cost recovery process.
  • 02:28:56
    Did ERCOT want to start us off with this one?
  • 02:28:59
    Yes. This is Ino. I'm here. Hi, Ino. Thanks,
  • 02:29:03
    Diana. So this is a
  • 02:29:07
    continuation of the process improvement of foreign field supply
  • 02:29:11
    services. With this NPRR,
  • 02:29:15
    we're making two changes. One of them is to clarify
  • 02:29:19
    that QSCs that represent farm fuel supply
  • 02:29:23
    generators are able to restore their fuel services,
  • 02:29:27
    meaning procure fuel with or
  • 02:29:31
    replace the fuel that was consumed with existing
  • 02:29:35
    inventories. Most of these power plants have very large
  • 02:29:41
    storage tanks, and they have the capability to
  • 02:29:45
    contain a lot more fuel than what is consumed
  • 02:29:49
    during a deployment. So instead
  • 02:29:52
    of having to go and purchase fuel that was consumed
  • 02:29:56
    and wait two to three weeks,
  • 02:30:00
    they can utilize the fuel inventory
  • 02:30:03
    to make the service available immediately. And ERCOT
  • 02:30:08
    likes that as well, because that way we can have
  • 02:30:12
    the service available in case there's another watch
  • 02:30:15
    or fuel disruption. So that's the clarification.
  • 02:30:19
    I just want to make sure that people understand that the protocols currently allow
  • 02:30:23
    that. I'm not sure it was clear, and we had some
  • 02:30:26
    questions that came up. That's why we submitted
  • 02:30:30
    a clarification. The other change that we are proposing
  • 02:30:34
    is to say, for those resources that
  • 02:30:39
    choose to use existing inventories in
  • 02:30:42
    order to receive compensation, they have two options.
  • 02:30:46
    One, they can go and purchase the fuel, and we will pay them for
  • 02:30:50
    the costs of fuel, whatever they pay.
  • 02:30:53
    Or two, we'll establish the cost
  • 02:30:57
    based on the fuel oil price. Now,
  • 02:31:00
    the fuel oil price is an index price that ERCOT collects,
  • 02:31:04
    and we add five cents per gallon to pay for transportation.
  • 02:31:10
    That's definitely a policy change. So we
  • 02:31:13
    are submitting this for your consideration.
  • 02:31:17
    Thank you, Ino.
  • 02:31:21
    Katie.
  • 02:31:25
    Thanks, Diana. And, you know, thank you for working
  • 02:31:29
    with us on this. I think we, we still need more
  • 02:31:32
    time to analyze what's being proposed. And I
  • 02:31:36
    would suggest a table and referral over to WMS
  • 02:31:40
    and ultimately over to WMWG.
  • 02:31:45
    That'll be fine with us.
  • 02:31:49
    Thank you, Katie. Blake.
  • 02:31:54
    Blake, hold lcra. We also support a table for some additional
  • 02:31:58
    discussion, but I'm curious, you know, if I can just get some clarification
  • 02:32:01
    about paragraph four B.
  • 02:32:05
    Corey, if you could scroll down.
  • 02:32:16
    There you go. And this may be obvious,
  • 02:32:20
    but I just wanted to get some clarification here. Is there
  • 02:32:23
    a reason why the language is considering the FoP
  • 02:32:26
    from the operating day of the approval instead
  • 02:32:30
    of the operating day of the actual restocking?
  • 02:32:35
    Well, so that's a great question. Presumably,
  • 02:32:39
    under this paragraph, restocking occurs immediately
  • 02:32:43
    when ERCOT approves the restocking and
  • 02:32:47
    the resources. We have the fuel on site. So that's
  • 02:32:50
    the same day.
  • 02:32:57
    And so paragraph a indicates they
  • 02:33:01
    can restock within 30 days.
  • 02:33:06
    Is it possible that they delay the restocking?
  • 02:33:11
    Let me clarify that. So let's suppose you have a resource
  • 02:33:15
    that utilizes or restocks or restores
  • 02:33:20
    the service utilizing fuel
  • 02:33:23
    in inventory. They have
  • 02:33:27
    an option to purchase that fuel
  • 02:33:30
    that was consumed within 30 days.
  • 02:33:33
    And let's suppose it costs $20 per gallon.
  • 02:33:37
    We will. Or per mmbtu. Excuse me. We will pay
  • 02:33:40
    that cost. But it is possible they don't want
  • 02:33:44
    to purchase it because they already had it in inventory.
  • 02:33:47
    And they say, well, we're happy with paying,
  • 02:33:51
    receiving the payment based on, on the fuel oil price.
  • 02:33:55
    And that's why we have option b. So you
  • 02:33:59
    have two options. You can go and buy it or we'll pay you
  • 02:34:02
    for the same fuel that was consumed but at the fuel
  • 02:34:06
    oil price index. Index price.
  • 02:34:09
    Very helpful. You know, that makes a lot of sense. Thank you. You're welcome,
  • 02:34:15
    Fei. Thank you. Fei with Austin
  • 02:34:19
    Energy. I'm curious,
  • 02:34:23
    would the proposed change has potential to help reduce
  • 02:34:28
    restocking cost?
  • 02:34:35
    Well, that's a difficult question to answer.
  • 02:34:38
    What it will do for sure is to expedite
  • 02:34:43
    when the service is available to ERCOT because they have
  • 02:34:46
    also fuel. We've known that a lot of these resources have
  • 02:34:50
    a lot more fuel in storage than what they consume during a
  • 02:34:54
    watch. Whether or not it's going to
  • 02:34:58
    reduce overall fuel costs, it is
  • 02:35:01
    difficult to answer because we don't know how much they
  • 02:35:05
    have purchased that fuel in inventory.
  • 02:35:10
    So we haven't done an analysis. I'm not sure we can actually.
  • 02:35:19
    Did that help me?
  • 02:35:21
    Yes. Yeah. I'm just thinking with the proposed, with the
  • 02:35:25
    current proposals,
  • 02:35:27
    FFSSR, who needs to restock,
  • 02:35:31
    they have the option to use existing,
  • 02:35:34
    get the FOP, or make new purchase like 30
  • 02:35:38
    days after the approval versus maybe currently,
  • 02:35:42
    if they wanted to restock, they have to go on the market and buy
  • 02:35:45
    at the spot. Right. So I know it
  • 02:35:49
    may not be clear, and maybe we need to make this even clearer currently.
  • 02:35:54
    Well, resources, when they get dispatched
  • 02:35:58
    and then ERCOT either requires or
  • 02:36:02
    approves restocking.
  • 02:36:05
    Some people just go and purchase fuel and it may take
  • 02:36:08
    a week or two weeks before they can deliver that fuel. And then
  • 02:36:12
    whatever they pay for that fuel, ERCOT pays them back.
  • 02:36:15
    We make them whole. Some entities,
  • 02:36:18
    on the other hand, will say, hey, we have the fuel in
  • 02:36:22
    service, in inventory. We want to use that same fuel.
  • 02:36:26
    And by the way, we pay x amount of dollars for
  • 02:36:29
    that fuel three months ago. So we want to reduce,
  • 02:36:33
    maybe I answer to your first question. We want to make sure we reduce
  • 02:36:36
    the cost because if they purchase the fuel three months ago
  • 02:36:40
    at $25 per mmbtu and now,
  • 02:36:43
    and Bodeku purchase it right now at $10,
  • 02:36:47
    why should we pay $25 per mmbtu? So in
  • 02:36:50
    essence, the fuel oil price sort
  • 02:36:53
    of puts a cap on the cost of existing inventory.
  • 02:37:01
    Thank you, Ena. You're welcome, Ian.
  • 02:37:05
    One thing I would add is diesel actually goes bad.
  • 02:37:09
    And so by allowing generators the option to
  • 02:37:14
    do this, you're adding flexibility into what they do. And so
  • 02:37:17
    I would expect that they could reflect that in their offers.
  • 02:37:21
    Because if not, if they're required to.
  • 02:37:25
    If they feel. I should say, if they feel that they're
  • 02:37:28
    required to repurchase diesel at
  • 02:37:33
    the end of the FFSS season,
  • 02:37:37
    they may need to take that into account of then having to burn
  • 02:37:40
    that diesel prior to wanting to
  • 02:37:44
    have that diesel in their tanks. Again,
  • 02:37:49
    I concur with you.
  • 02:37:53
    Good point. Thank you, Ian. Okay, so it sounded like there was
  • 02:37:57
    some appetite to table and refer
  • 02:38:00
    it over to WMS for conversations at WMWG.
  • 02:38:04
    Is that good with everybody? Okay, Diana, can I just use one,
  • 02:38:08
    just one simple comment? Sure.
  • 02:38:12
    Something that Ian said. I want to make sure that everyone
  • 02:38:15
    understands that if we're getting closer to the end of the
  • 02:38:18
    season, most likely ERCOT will not approve
  • 02:38:22
    restocking. Right. So if we have a watch, for example,
  • 02:38:26
    on March 1 and for
  • 02:38:29
    a couple of days, and they burn some fuel,
  • 02:38:33
    and then they want to. The QC calls ERCOT says,
  • 02:38:36
    hey, can I restock? Well, unless we see an
  • 02:38:39
    imminent fuel disruption, we may not approve restocking
  • 02:38:43
    because the program ends on March 15.
  • 02:38:47
    So we have that flexibility.
  • 02:38:51
    Thank you, Ena.
  • 02:38:58
    Okay, more conversations to come.
  • Item 8.8 - NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements
    02:39:06
    Okay, so that takes us to last but not least,
  • 02:39:10
    1252. This is also coming to
  • 02:39:13
    us from ERCOT on the pre notice for sharing some information,
  • 02:39:17
    addition of research and innovation partners, and clarifying notice
  • 02:39:21
    requirements.
  • 02:39:24
    Did ERCOT want to decline that? Go ahead. Thank you, Diana.
  • 02:39:28
    This is Katherine Gross with ERCOT legal. So,
  • 02:39:31
    1152 is attempting to make
  • 02:39:35
    three main buckets of changes. The first change
  • 02:39:39
    is regarding vendors. And so,
  • 02:39:43
    under the proposed changes, ERCOT would not provide
  • 02:39:47
    pre notice of disclosing ECEII or
  • 02:39:51
    protected information to vendors.
  • 02:39:55
    And I thought it'd be helpful to just review a little
  • 02:39:58
    bit some of the vetting and safeties that
  • 02:40:02
    are undertaken for our vendors.
  • 02:40:06
    So, to start out, all of our vendors sign
  • 02:40:09
    non disclosure agreements, and so for those receiving
  • 02:40:13
    ECEII or protected information.
  • 02:40:17
    Excuse me, the non disclosure agreements would meet
  • 02:40:21
    the requirements of section one of the protocols.
  • 02:40:25
    In addition, for any vendors that do it
  • 02:40:28
    or software work, regardless of if they're getting ECEII
  • 02:40:32
    or protected information. So any software it
  • 02:40:36
    vendors, plus all vendors that are getting ECEII and
  • 02:40:40
    protected information, our practice
  • 02:40:43
    is to do a risk management assessment,
  • 02:40:47
    which is a survey that is sent to those vendors.
  • 02:40:51
    And it contains over 60 questions that our
  • 02:40:55
    cybersecurity department reviews. The responses
  • 02:40:58
    to many of those questions are relating to
  • 02:41:03
    NERC, SIP type things like access management or
  • 02:41:06
    malicious code detection and prevention.
  • 02:41:10
    But we also ask questions that are broader than that,
  • 02:41:13
    such as the core business function of
  • 02:41:17
    the vendor or prospective vendor,
  • 02:41:20
    as well as things like, what country are they headquartered
  • 02:41:24
    in, what country are their data centers gonna be if
  • 02:41:28
    they are owned or controlled by citizens of,
  • 02:41:31
    like, Russia or China or North Korea? So things
  • 02:41:35
    like that. And so we get those responses
  • 02:41:38
    back and we send out those surveys to those types of vendors every two
  • 02:41:42
    years and then reevaluate those. And then the
  • 02:41:46
    last thing I wanted to note is, for any vendors that
  • 02:41:49
    require access privileges, whether it's physical
  • 02:41:53
    or electronic access to ERCOT computer
  • 02:41:57
    or information systems, then the employees of those
  • 02:42:01
    vendors are required to do a NERC SIP background
  • 02:42:05
    check. So those are the kinds of vendors
  • 02:42:09
    that are having access to this information,
  • 02:42:12
    the kinds of protections that are in place.
  • 02:42:15
    And so. And so this first bucket would be, again, doing away with the
  • 02:42:19
    pre notice requirement to provide ECEII,
  • 02:42:22
    or protected information, to ERCOT vendors.
  • 02:42:26
    In addition, this first bucket also would get rid of the
  • 02:42:30
    requirement if a market participant is needing to
  • 02:42:33
    give ECEII information to their own vendor.
  • 02:42:37
    There would not need to be pre notice for that. And that's.
  • 02:42:41
    That's also covered in section one,
  • 02:42:44
    3.5 friends one.
  • 02:42:49
    So that's the first main bucket. The second main bucket is to
  • 02:42:52
    add a new kind of entity within the
  • 02:42:56
    definitions, and that's an ERCOT research and innovation partner.
  • 02:43:00
    And so this is kind
  • 02:43:05
    of like a vendor, but they're not being paid.
  • 02:43:08
    And the work that they're doing is collaboration with
  • 02:43:12
    ERCOT that ERCOT believes will improve our ability
  • 02:43:15
    to plan and operate the ERCOT system and
  • 02:43:19
    markets. And so,
  • 02:43:22
    under our proposed red lines, there would not
  • 02:43:26
    be pre notice if ECEII was
  • 02:43:30
    provided to one of these ERCOT RNI vendors
  • 02:43:34
    or. Sorry, I didn't mean to say vendors, because that's confusing. It. It would not
  • 02:43:38
    be required if we're providing ECEII to one of these RNI
  • 02:43:43
    partners. And then
  • 02:43:47
    the last main thing is to
  • 02:43:51
    clarify some of the requirements around notice, or I guess, to update
  • 02:43:54
    them. Currently,
  • 02:43:57
    the requirements around notice are a little
  • 02:44:00
    archaic in that it needs to be mailed
  • 02:44:04
    or faxed. If you email notice,
  • 02:44:08
    then under the current protocols, you have to follow
  • 02:44:11
    up with mailed notice or facts. And so
  • 02:44:15
    this would broaden the acceptable notice to allow
  • 02:44:19
    it to be emailed. Also, market notice,
  • 02:44:23
    because we have a market notice tool that's very effective at reaching
  • 02:44:27
    large numbers of market participants,
  • 02:44:30
    market notice would be allowed as well as a form of acceptable
  • 02:44:35
    notice. And if notice
  • 02:44:38
    is not sent by mail, we're proposing to get rid of
  • 02:44:42
    the requirement that. That we do both. I guess that we,
  • 02:44:46
    after it's emailed to, then send it in
  • 02:44:49
    the mail. So thank you, Catherine.
  • 02:44:54
    Sorry, I was going to say, just on the RNI partner issue,
  • 02:44:58
    Venkat trupity is here just to give kind
  • 02:45:02
    of an idea of what that kind of work looks like. Okay,
  • 02:45:06
    doctor Garrett? Yeah, thanks, Katherine. Hey, good afternoon,
  • 02:45:10
    folks. My name is Venkat Tirupati and I'm
  • 02:45:13
    spearheading the grid transformation research innovation efforts at ERCOT.
  • 02:45:17
    And I've been. I've started this in January of this year.
  • 02:45:21
    And so I wanted to make my case in terms of, of why we think
  • 02:45:24
    it is important to have R&I partners. So I
  • 02:45:27
    don't have to tell you folks, you all are very aware that the grid is
  • 02:45:30
    transforming rather rapidly and both the supply and the demand side, and that
  • 02:45:33
    there are several challenges that we all need to address together.
  • 02:45:37
    ERCOT cannot do this alone. We all need to
  • 02:45:41
    collaborate and make this happen. And so innovation and
  • 02:45:44
    the collaboration to make the innovation happen, we feel are the keys to success
  • 02:45:48
    from which we all will benefit. And the
  • 02:45:51
    value proposition for anyone who wants to work with ERCOT are really the
  • 02:45:54
    challenges that we have within the grid. The domain expertise that
  • 02:45:58
    we have, and the data.
  • 02:46:01
    There's a lot of research and innovation that happens in our space with
  • 02:46:05
    synthetic data that several universities have put together,
  • 02:46:08
    or maybe with small models. And the ideas and tools
  • 02:46:13
    and things that folks develop, ultimately need to be vetted with
  • 02:46:16
    real world data. So if the researchers have access to real world
  • 02:46:20
    data, they can do a better job with their technology tools,
  • 02:46:23
    etcetera. And we feel that we can accelerate the innovation and all
  • 02:46:26
    of us could benefit from that. So the partners that we will
  • 02:46:30
    work with, such as the universities, the national labs, etcetera, we will
  • 02:46:34
    have the statement of works with them. We will have all the controls
  • 02:46:37
    that Catherine mentioned in terms of cyber controls, access management controls,
  • 02:46:41
    risk management controls, etcetera, that we will require
  • 02:46:45
    out of a vendor. So all those stringent protections
  • 02:46:48
    are a must before we share anything with the research and innovation partners.
  • 02:46:53
    So at least I wanted to provide that background in terms of what
  • 02:46:56
    we are thinking from an rna partner. And I'll be happy to take any
  • 02:47:00
    questions. Thank you.
  • 02:47:04
    Go ahead, Eric. I think, in general, that's a strong argument.
  • 02:47:09
    I think it might be worth keeping at table to think about.
  • 02:47:13
    You know, the definitions are,
  • 02:47:17
    I think, intentionally broad, but I
  • 02:47:20
    think a few different kinds of entities could meet
  • 02:47:25
    those. And so it might be worth keeping it. Table just to think through who
  • 02:47:29
    might follow those definitions. But in general, I think you're trying
  • 02:47:32
    to achieve, you know, something good here.
  • 02:47:38
    Okay. Go ahead,
  • 02:47:41
    Martha. Thanks, Dana. Martha Henson with Oncor. Corey, could you
  • 02:47:44
    scroll down one page to the justification section? I had a little
  • 02:47:48
    confusion about one of the statements in here in
  • 02:47:52
    that second paragraph, the second sentence. Clarifying the
  • 02:47:56
    notice requirements that apply prior to ERCOT sharing
  • 02:47:59
    PI or ECEII to these partners is necessary so
  • 02:48:03
    that market participants can have transparency as to what information is
  • 02:48:06
    being shared by ERCOT. And what I thought I heard from Katherine
  • 02:48:10
    is that I know you said multiple times that
  • 02:48:14
    the pre notice provision is being
  • 02:48:18
    recommended to be removed. I'm a little confused
  • 02:48:21
    as to whether it's really all notifications
  • 02:48:25
    to the creating parties of the PI or ECEII
  • 02:48:29
    that would be removed under this NPRR because that's what I read the red lines
  • 02:48:33
    to be doing. Would you be able to clarify that? Yeah. Thank you.
  • 02:48:36
    That's. That's a good question. And I guess rereading
  • 02:48:39
    it now, I'm like, oh, maybe that wasn't written the best,
  • 02:48:42
    but the red lines would.
  • 02:48:45
    You would still need to give pre notice if
  • 02:48:48
    we were giving protected information to a
  • 02:48:53
    RNI partner. The red lines,
  • 02:48:56
    as proposed, would not require pre notice
  • 02:49:01
    if ECEII was being given to a RNI
  • 02:49:04
    partner. Okay. So there's a distinction between PI
  • 02:49:08
    and ECEII. Okay. I didn't. I didn't appreciate that. So that's helpful.
  • 02:49:12
    Yeah, I would. I like your suggestion.
  • 02:49:16
    If it would be possible to have this tabled just for maybe a month
  • 02:49:19
    here at PRS, I would like to have a little bit more time to think
  • 02:49:23
    about how this plays into the comments and issues
  • 02:49:27
    that we had with the other NPRR that
  • 02:49:30
    addresses disclosures to agencies and see if there's
  • 02:49:34
    some maybe common solution across both of those
  • 02:49:38
    that could potentially ensure that the notice provisions
  • 02:49:41
    aren't overly burdensome for ERCOT, but that market
  • 02:49:45
    participants have some insight into what information they
  • 02:49:49
    created that is being shared with these entities. So I
  • 02:49:52
    would appreciate a few weeks to work with you all to see if there's a
  • 02:49:55
    solution there that you'd be okay with. Yes. That makes sense.
  • 02:49:58
    Thank you. Okay,
  • 02:50:03
    so it sounds like we had an appetite to keep it tabled here
  • 02:50:07
    at Pura's or maybe a month and take
  • 02:50:12
    a look at some of the proposals. Okay.
  • 02:50:16
    I will put a motion to table on the comma ballot.
  • Item 10 - Combo Ballot - Vote - Diana Coleman
    02:50:21
    All right, guys, so now we just need a motion in
  • 02:50:24
    a second for all of these items. Look at everything
  • 02:50:28
    we did today. That's so impressive.
  • 02:50:32
    I just need a motion in a second motion by Melissa
  • 02:50:36
    Trevino, second by Martha Henson.
  • 02:50:42
    Martha was the second. Okay,
  • 02:50:45
    Corey. All right.
  • 02:50:50
    On the motion to approve the combo ballot, we will start up with the consumers.
  • 02:50:54
    With Eric. Yep. Thank you. Mark Dreyfus.
  • 02:50:58
    Yes, sir. Thanks, sir. Melissa? Yes. Thanks. Thank you.
  • 02:51:01
    Onto our co ops. Lucas? Yes.
  • 02:51:05
    Thank you. Blake. Thank you.
  • 02:51:13
    Blake Holt, you still with us? Yes, sir.
  • 02:51:16
    Thanks, sir. Eric Blakey.
  • 02:51:20
    Yes, thank you, sir. Onto our independent generators.
  • 02:51:23
    Andy? Yes, thank you. Bryan.
  • 02:51:28
    Got you in chat. Ryan, as a yes, thank you. Alex?
  • 02:51:31
    Yes, thank you. David?
  • 02:51:35
    Yes, thank you. Thank you. On to our IPMs.
  • 02:51:38
    John? Yes, thanks, sir.
  • 02:51:41
    On to our I reps. Bill? Yes,
  • 02:51:45
    thank you. Aaron? Yes.
  • 02:51:49
    You on to our IOUs. Martha?
  • 02:51:53
    Yes, thank you, Rob.
  • 02:51:57
    Jim, you're supposed to keep an eye on him. I tried.
  • 02:52:01
    Jim? Yes, thanks, sir. On to the
  • 02:52:04
    Munis. Diana? Yes, thank you. Ashley?
  • 02:52:08
    Yes, thank you. Thank you. And Fei.
  • 02:52:12
    Yes, thank you. Motion carries unanimously.
  • Item 9 - Other Business - Diana Coleman
    02:52:16
    Thank you all. Thank you, everybody. And then I think
  • 02:52:19
    the only other business that we had was just as a heads up,
  • 02:52:23
    the next two open meetings. And I know there was some conversation at
  • 02:52:26
    open meeting this morning about possible open meetings
  • 02:52:30
    during the same time that PRS is scheduled to meet.
  • Item 11 - Future Meetings - Diana Coleman
    02:52:33
    So October 17 and possibly November 14 as well,
  • 02:52:37
    might have an afternoon edition of PRS, which is just telling
  • 02:52:40
    us that we did a really good thing by moving PRS to Wednesday days for
  • 02:52:44
    next year. But just as a heads up, we'll wait to see what PRS or
  • 02:52:47
    the commission does as far as timing of PRS.
  • Item 12 - Adjourn
    02:52:51
    Okay, thank you guys. Have a good afternoon.
2024-prs-combined-ballot-20240912
Sep 11, 2024 - xls - 113.5 KB
September-12,-2024-prs-meeting-materials
Sep 04, 2024 - zip - 5.9 MB
2024-prs-nprr1180-ballot-20240912
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2024-prs-nprr1188-ballot-20240912
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September-12,-2024-prs-meeting-materials
Sep 05, 2024 - zip - 6 MB
Agenda_prs_20240912
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Sep 09, 2024 - pptx - 504.3 KB
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Sep 10, 2024 - pptx - 85.6 KB
Mp-guide-for-suggesting-changes
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Sep 11, 2024 - zip - 6.8 MB
1 - Antitrust Admonition - Diana Coleman
Starts at 00:02:09
2 - Approval of Minutes - Vote - Diana Coleman
Starts at 00:02:54
3 - TAC Update - Diana Coleman
Starts at 00:03:02
4 - Project Update - Troy Anderson
Starts at 00:03:41
5 - NPRR1247 - Urgency Vote - Diana Coleman
Starts at 00:22:39
6 - Review PRS Reports, Impact Analyses, and Prioritization - Vote - denotes no impact - Diana Coleman
Starts at 00:53:22
6.1 - NPRR1188, Implement Nodal Dispatch and Energy Settlement for Controllable Load Resources
Starts at 00:53:53
6.2 - NPRR1237, Retail Market Qualification Testing Requirements
Starts at 01:14:40
6.3 - NPRR1244, Related to NOGRR263, Clarification of Controllable Load Resource Primary Frequency Response Responsibilities
Starts at 01:15:08
7 - Revision Requests Tabled at PRS - Possible Vote - Diana Coleman
Starts at 01:19:47
7.3 - NPRR1180, Inclusion of Forecasted Load in Planning Analyses
Starts at 01:20:11
7.7 - NPRR1226, Demand Response Monitor
Starts at 01:30:09
8.5 - NPRR1249, Publication of Shift Factors for All Active Transmission Constraints in the RTM
Starts at 02:03:27
7.9.1 - NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
Starts at 02:09:37
7.9.3 - NPRR1239, Access to Market Information
Starts at 02:11:27
7.9.4 - NPRR1240, Access to Transmission Planning Information
Starts at 02:11:44
7.9.5 - NPRR1241, Firm Fuel Supply Service - FFSS - Availability and Hourly Standby Fee
Starts at 02:12:17
7.9.7 - NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities
Starts at 02:12:35
8 - Review of Revision Request Language - Vote - Diana Coleman
Starts at 02:15:35
8.1 - NPRR1245, Additional Clarifying Revisions to Real-Time Co-Optimization
Starts at 02:15:40
8.2 - NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era
Starts at 02:19:46
8.4 - NPRR1248, Correction to NPRR1197, Optional Exclusion of Load from Netting at EPS Metering Facilities which Include Resources
Starts at 02:22:48
8.6 - NPRR1250, RPS Mandatory Program Termination
Starts at 02:24:39
8.7 - NPRR1251, Updated FFSS Fuel Replacement Costs Recovery Process
Starts at 02:28:47
8.8 - NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements
Starts at 02:39:06
10 - Combo Ballot - Vote - Diana Coleman
Starts at 02:50:21
9 - Other Business - Diana Coleman
Starts at 02:52:16
11 - Future Meetings - Diana Coleman
Starts at 02:52:33
12 - Adjourn
Starts at 02:52:51

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