08/22/2024
09:30 AM
Video Player is loading.
Search
- 00:00:12Good morning, everybody. Welcome to the workshop for project 55718.
- 00:00:178 /minute basin reliability plan.
- 00:00:26Is it better now? Yes. Okay. Good morning,
- 00:00:29everybody. Welcome to the workshop. Project 55718 for
- 00:00:32the Permian Basin. Before we start, Commissioner Cobos
- 00:00:36will make some opening statements. Thank you, Herika.
- Clip 0.1 - Opening Statements - Commissioner Cobos00:00:39Yeah. Good morning. Thank you all for being here at today's workshop. The workshop
- 00:00:43discussion will be very important for our staff as they
- 00:00:47start to prepare a recommendation for the commission
- 00:00:51on how to move forward with the implementation of the Permian Basin
- 00:00:54reliability Plan. It has been an honor to lead this effort.
- 00:00:57The Permian Basin is a priority for the commission.
- 00:01:01It's a critically important area for our state, our country and
- 00:01:05the world. Electricity demand in the permian basin is
- 00:01:08growing and is expected to continue to grow significantly with the
- 00:01:12electrification and expansion of the oil and gas industry
- 00:01:16in the permian basin, including the Delaware Basin, and the continued
- 00:01:20proliferation of crypto mining and siding of data centers and hydrogen facilities.
- 00:01:25Based on ERCOT's recent load forecast data, ERCOT expects more than
- 00:01:28150 gigawatts of total load by 2030.
- 00:01:32That is in the next five years, including new load of 40
- 00:01:36gigawatts. Of this new load, approximately 26,000
- 00:01:40or 26 gigawatts is from the Permian Basin region. In recognition
- 00:01:45of the importance of the permian basin, the Texas legislature passed
- 00:01:48HB5066 with language that specifically
- 00:01:52addresses the electricity needs of the Permian Basin region.
- 00:01:55HB5066 required the commission to direct ERCOT
- 00:01:59to develop a reliability plan for the Permian Basin region.
- 00:02:03After the passage of HB5066, the commission held a workshop
- 00:02:06in Midland in December of 2023 and subsequently thereafter
- 00:02:10directed ERCOT to develop a reliability plan for the Permian Basin region.
- 00:02:15The commission's direction to ERCOT included a timeline for ERCot's
- 00:02:18development of a plan with deadlines and deliverables.
- 00:02:21ERCOT submitted a final reliability plan to the commission in July and
- 00:02:25the commission will approve a plan in September.
- 00:02:28I want to thank the hard work from ERCoT
- 00:02:32and thank ERcot for their hard work and staff. This has been a
- 00:02:35monumental task in a very short amount of time.
- 00:02:38And, you know, we look forward to getting your feedback
- 00:02:42today. Again, your feedback will be very important on the important
- 00:02:45questions that staff laid out today that include how
- 00:02:49to move forward, the path forward for building out infrastructure
- 00:02:54through 2038, the potential inclusion
- 00:02:58of EHV or 500 or 765 kV transmission lines
- 00:03:02and cost impacts for on the various options of building out
- 00:03:06the infrastructure in the plan.
- 00:03:09We look forward to getting your feedback and I encourage you in the coming
- 00:03:13weeks, if you want to, you know, provide additional feedback
- 00:03:17to reach out to my office and to the other commissioners offices as
- 00:03:21we look to put the best plan forward to meet the future needs
- 00:03:25of the Permian Basin region. And thank you very much again for being
- 00:03:29here today. Thank you, commissioner.
- 00:03:32So I'm just going to start with staff introductions. I am Harika
- 00:03:36Basaran. I'm the director of market analysis.
- 00:03:41I'm Julia Wagner. I'm also in market analysis as an
- 00:03:44engineering specialist. Hi, I'm John Poole.
- 00:03:48I'm in the infrastructure division. I'm an engineering specialist as well.
- 00:03:52Chris Rolsey, infrastructure division engineering
- 00:03:57section manager. And we also have Terese and Mark is
- 00:04:01also from PUC staff. So I just want
- 00:04:04to go over the logistics. We have the questions, nine questions.
- 00:04:08Julia is going to read each questions and anybody wants to speak on
- 00:04:11that questions, please come. And please make sure you state
- 00:04:15your name and the company every time you come. We just need
- 00:04:19that for clarity. And ERCOT staff is here as
- 00:04:22a resource and it's recorded
- 00:04:25on the Admin Monitor. Lucy here is going to try to
- 00:04:30keep up the time. We dedicated 30 minutes under each
- 00:04:33bucket of questions, but we are not tied to that. If there is really
- 00:04:37important actions, subjects, and we need to spend
- 00:04:40more time under one question other than the other, we can do that.
- 00:04:44And then there is at the end, catch all questions. If you want to have
- 00:04:47anything to say. You didn't speak, but you just want to say something.
- 00:04:51You are welcome to speak on question nine as well.
- 00:04:57I think that's all I have. Julia, it's yours. Okay.
- 00:05:03All right. Starting under the heading of plan question
- 00:05:07one, what is the best approach to approve a
- 00:05:11plan that gives commission flexibility to
- 00:05:14consider the benefit from ErCOT's EHV study
- 00:05:17that will be completed by the end of 2024?
- 00:05:23Please come. Anyone?
- 00:05:36Anybody else? We just want everybody to come and sit at the same time
- 00:05:50and we can start in that order. So that will be mainly easier.
- 00:05:56Good morning. Is this on? Yes.
- Clip 1 - Michael McMillin - TIEC00:06:00 Good morning. Michael McMillin for Texas Industrial energy consumers.
- 00:06:04And it's TIECs position that the
- 00:06:07commission should approve a full plan through 2038
- 00:06:11using 345 kV infrastructure
- 00:06:15and do that as soon as possible. I mean, TIEC is
- 00:06:21voltage agnostic, but we're not timing agnostic.
- 00:06:24And we think that the most important thing right now is to get
- 00:06:28utilities moving forward with CCN applications so we
- 00:06:32can actually get steel in the ground as quickly as possible.
- Clip 1 - Meghan Griffiths - PBPA00:06:37Good morning. My name is Megan Griffiths and I'm here today representing the Permian Basin
- 00:06:41Petroleum association. And for those of you who aren't
- 00:06:44familiar with PDPA, they are one of the largest
- 00:06:48regional oil and gas associations in the United States. And this plan is very
- 00:06:52critical to their members who have load in the region right now
- 00:06:55that is clamoring to come online and frankly, hasn't been able to come
- 00:06:59online and has been having to self serve for
- 00:07:03many years. You know, their concern is that the region is about
- 00:07:06a decade behind where it needs to be. So we
- 00:07:10need to we support and echo what TIEC said,
- 00:07:14that the plan should be for the
- 00:07:17full, complete plan. It should be for the full 2038
- 00:07:21load. And for that reason, we're supporting the 345 plan
- 00:07:25because, frankly, it's a plan that appears fully baked right now.
- 00:07:28And so whatever order that the commission issues this fall,
- 00:07:32we would request that it include approval of that full plan.
- 00:07:36If in the future, 765 for the region makes sense,
- 00:07:39the commission could look in that, could look at that. But right now,
- 00:07:43what we need is a full and complete plan to serve the load.
- 00:07:46And this is a very important plan for our members. So we also have members
- 00:07:49here today that I want to recognize. PBPA has been working
- 00:07:53with ERCOT on the plan, and we appreciate Ercot's efforts.
- 00:07:57But today, probably in response to question two,
- 00:08:00we have here certain members, including endeavor energy.
- 00:08:04We have ConocoPhillips, we have Coterra Energy here,
- 00:08:08Diamondback energy, and then Targa is also here
- 00:08:12as well. And so we appreciate
- 00:08:15the Commission's work on this very important project and support a
- 00:08:19full, complete plan in the order as well.
- Clip 1 - Kamran Ali - VP AEP Texas00:08:24Good morning. Can you guys hear me all right? Kamran Ali, vice president of transmission
- 00:08:28planning for AEP and representing AEP Texas here.
- 00:08:31First of all, I want to thank the commission for this workshop and
- 00:08:34all the good work that ERCOT has done in coming up with this plan.
- 00:08:38AEP's position is that, you know, 24,000 megawatt of
- 00:08:42load increase in Permian Basin is not the only
- 00:08:46increase that we are seeing across Texas. As a matter of fact,
- 00:08:49ERCOT is currently performing an analysis that is expected
- 00:08:53to be completed by the end of this year, which contemplates a total increase,
- 00:08:57including the permian load of 60,000 megawatt.
- 00:09:01And we believe that that analysis will very clearly demonstrate
- 00:09:05that we will require significant transmission at extra high voltage,
- 00:09:09like 765 kV to be able to deal with the
- 00:09:13uncertainty that we still have around generation. I mean, the analysis
- 00:09:17that ERCOT has done, I think they've done a great job, but there is still
- 00:09:20a lot of uncertainty around where the generation will show up. And a 765
- 00:09:24kb plan would allow for us to transmit
- 00:09:28and transport that generation, regardless of where that is located.
- 00:09:32I think the challenge we are seeing right now, even in our areas like
- 00:09:36lower Rio Grande Valley, where we just got some lines approved,
- 00:09:39and those lines are not even yet in service, but in our models, they're fully
- 00:09:42subscribed. What we're seeing is that these facilities are where
- 00:09:46the customers are directly connecting, of course, and we
- 00:09:50don't have a regional backbone overlay interstate system
- 00:09:54that would allow transportation transmission of power between different
- 00:09:58regions, between different pockets. So we believe the 765 kV plan
- 00:10:02does that also from a timing perspective, we have a
- 00:10:05lot of experience with 765 kV. We own and
- 00:10:09operate roughly 2200 miles of that in the PGM region.
- 00:10:13And we have talked to a lot of our vendors and manufacturers and construction
- 00:10:17companies, and we believe this is something that can definitely be achieved if
- 00:10:21we have the lead time that we currently see in
- 00:10:25this plan of 2030. And for that matter,
- 00:10:28our recommendation is to have a workshop where we can
- 00:10:32bring in the manufacturers, the vendors, to bring in
- 00:10:35the contracting companies that construct it, so we can hear them.
- 00:10:39And that would give us the time to also see the results of the
- 00:10:42RTP analysis that our quad is expected to publish by the end of this
- 00:10:46year. And that will be the right thing for the ratepayers, because then we're not
- 00:10:49putting these band aid fixes and having to come back and replace and add more
- 00:10:53transmission. Thank you.
- Clip 1 - Stephen Mack - WETT00:10:56Good morning. Stephen Mack with WETT.
- 00:10:59WETT is not only a transmission provider in the Permian Basin area,
- 00:11:03but also a member of the community. They have local offices there,
- 00:11:07personnel, they have longstanding relationships
- 00:11:10with the community and the political infrastructure.
- 00:11:14With us here today, the CEO of WETT,
- 00:11:18Wayne Morton, is here, along with Dennis Donnelly, Arthur Dandrea
- 00:11:22and Alessandra Papa. WETT would
- 00:11:26be agreeable either to a phasing of the three, I'm sorry,
- 00:11:30the extra high voltage, so that it can be studied along with the
- 00:11:33ERCOT larger plan. But extra high
- 00:11:37voltage is something that's very important to WETT. WETT is also agreeable,
- 00:11:41as some of the consumer groups,
- 00:11:44ratepayers have said, to approve
- 00:11:47a plan now at 345 that could be upgraded
- 00:11:51later on. Thank you. Good morning.
- Clip 1 - Liz Jones VP Reg. Affairs Oncor00:11:55 Liz Jones Oncor electric delivery.
- 00:11:58Oncor has filed comments both in the
- 00:12:02extra high voltage inquiry and in this project.
- 00:12:06We have been heavily involved in the development of the
- 00:12:10load forecast that ERCOT used to prepare the
- 00:12:14Permian Basin reliability plan. And we
- 00:12:18are very concerned that bifurcating it in the manner
- 00:12:21that ERCOT has suggested will
- 00:12:25create the same sort of bottleneck that we are currently facing
- 00:12:29in terms of our ability to serve customers.
- 00:12:32Now, our primary recommendation is let's
- 00:12:36get on with the 345 plan. Our adjacent
- 00:12:41recommendation is that certain of those 345
- 00:12:45paths can be designated as 765
- 00:12:49paths. And you can ask the utilities who
- 00:12:52are, or direct, I should say, order the utilities who
- 00:12:56are responsible for those corridors to
- 00:13:00begin preparation of a CCN that would
- 00:13:03address both 345 and EHV
- 00:13:06alternatives. And that
- 00:13:10way you have given the certainty to the customers
- 00:13:14that I believe they need, and at the same time
- 00:13:18you have gotten the initial order out but reserved
- 00:13:21some optionality. It's true
- 00:13:26that we could even build this at 765 and
- 00:13:30then operate at 345. That's where it gets more complicated.
- 00:13:35And so as a prime as our core
- 00:13:38position, we're hopeful that in the time between
- 00:13:42the commission's permian basin order and the
- 00:13:47decisions on those key CCNs, the commission will
- 00:13:51make a determination about whether and at what voltage
- 00:13:55they want to upgrade that infrastructure. And I
- 00:13:59think to do otherwise is a disservice to
- 00:14:03all of the customers who are in that region, but particularly the oil
- 00:14:07and gas customers who work so hard to get
- 00:14:11HB5066 in place.
- 00:14:14Thank you.
- Clip 1 - Kristi Hobbs - VP ERCOT00:14:18Good morning. Kristi Hobbs, vice president of system planning and weatherization for ERCOT
- 00:14:22so I wanted to start off by thanking
- 00:14:26the TSPs and the consumers for all the work that they helped
- 00:14:30put into helping get us information on the forecast so that
- 00:14:33we could provide the best plan in the short amount of time
- 00:14:37that was provided. I also want to recognize the
- 00:14:41consumers need for certainty in the region. We recognize
- 00:14:46your need for power as well as the need for power across the state.
- 00:14:50We're also seeing the load growth across the state and
- 00:14:54I've also, I hear the consumers concerns about load
- 00:14:58growth continuing in the region at a faster pace.
- 00:15:03We believe the looking at the entire state
- 00:15:06picture, an option that would be beneficial
- 00:15:10to provide certainty to the consumers and to keep us moving forward
- 00:15:13would be to move forward now on the
- 00:15:18no regrets option, which we've labeled
- 00:15:23as the local imports, which is about $4
- 00:15:26billion worth of projects, as well as provide
- 00:15:30certainty with a time certain before
- 00:15:35either the end of the year or closer to January,
- 00:15:40where we'll have the full plan out where we can look at the
- 00:15:44best options for moving power across the state through higher
- 00:15:47voltage lines as well, which would hit on providing
- 00:15:51extra transfer capacity for those consumers in
- 00:15:55the permian basin region, as well as address the uncertainty about where
- 00:15:59generation may be cited within the state and how to
- 00:16:02best move power into the region to capture that power for
- 00:16:06them. Thank you. Anybody else on
- Clip 1 - Liz Jones VP Reg. Affairs Oncor - About question 100:16:09question one? So I'd like to add one
- 00:16:12thing. We are respectful of ERCOT's
- 00:16:16plan and the recommendation that they've made.
- 00:16:20It would be a shame to hold the Permian Basin plan hostage
- 00:16:24to what may or may not be a lengthy process for the commission
- 00:16:28to develop and approve its 765
- 00:16:31plan and guidelines. And so as
- 00:16:36you all make your recommendations to the commissioners, I hope that you bear that in
- 00:16:39mind. I just like to
- 00:16:43echo that sentiment. I appreciate Oncor's comments on that.
- 00:16:47That is our key concern. You know, the Permian Basin
- 00:16:50has load there today that needs to be served. And so slowing
- 00:16:55that up for a regulatory process that could face delays.
- 00:16:59And we all know that those delays happen and
- 00:17:02that they're likely to happen. And so we want to move forward
- 00:17:06with the full plan, the full complete plan, in order to meet the directives in
- 00:17:09HB 5066. And so frankly, I think
- 00:17:13that the only way to do that is to approve an order that blesses the
- 00:17:16whole 345 kV solution for 2038.
- 00:17:20And we can address this more in response to question two. But the
- 00:17:23reality is, is that the load estimates between 2030
- 00:17:26and 2038. The incremental difference is really
- 00:17:30quite small. 90% of the 2038
- 00:17:34load is going to be there by 2030.
- 00:17:3695% is estimated to be there by 2032.
- 00:17:41And it's really like 2700 difference. So the reality
- 00:17:45is the plan needs to be in place so that the
- 00:17:48parties can move forward by 2030. And everything needs to be in place. The generation
- 00:17:52import pathlines as well as, as the local project.
- 00:17:55So we can address that in the phasing question. If I can add one
- 00:17:59clarification, just for the public record, for those that
- 00:18:03aren't as involved maybe in the transmission
- 00:18:06planning process. That plan that we are going to be putting out by the end
- 00:18:09of the year for the entire state would be for serving load for
- 00:18:132030. So it will be looking
- 00:18:16at that load growth, providing that extra transfer capability
- 00:18:20and optionality for the consumers, not just in the permian,
- 00:18:24but for across the state. And so that's
- 00:18:28kind of what's driving our recommendation.
- Clip 1 - Emily Jolly - LCRA00:18:33Can we give us Emily Jolly? Thank you Harika. Emily Jolly with LCRA
- 00:18:36Transmission Services Corporation. I want to follow up on
- 00:18:40some of the other comments from the TSP's and echo our support for the approach
- 00:18:43that's been articulated today. Specifically,
- 00:18:47we understand the need for EHV and ERCOT. I think that's becoming readily apparent
- 00:18:51and we look forward to working with ERCOT and all of our partners to ensure
- 00:18:54that that is successfully deployed per the commission's
- 00:18:58direction. One of the concerns that we raised, and I'm
- 00:19:02happy to elaborate further on in our comments, is just the
- 00:19:06interplay, the lack of information that we have today about some
- 00:19:10of the EHV alternatives. And if you
- 00:19:13have, you know, 765 kV system
- 00:19:17and a loss of an element, that's going to have an impact on the underlying
- 00:19:21345 kV system. And so there's a lot of interplay that we
- 00:19:24just want to better understand. And given the time constraints
- 00:19:28that the commission is faced with here in this part of the process,
- 00:19:33that's really the driver, I think, for our recommendation to proceed with 345
- 00:19:37at this point. But obviously we do see the
- 00:19:40need for those solutions in the future and are supportive of working with ERCOT
- 00:19:44to determine the best way to integrate that going forward.
- 00:19:50So I wanted to build on some of the other comments
- 00:19:54and note that approving a full plan using
- 00:19:58345 at this point in no way prevents the commission from
- 00:20:02reserving flexibility to, once the EHV
- 00:20:06studies are done, either add in EHV elements or substitute
- 00:20:11portions of the 345 plan with EHV
- 00:20:14assets. So on that basis,
- 00:20:18TIEC thinks that it's really the no regrets thing to go
- 00:20:21with 345 at this point, and then reserve flexibility
- 00:20:25for when we get around to evaluating the EHB options.
- 00:20:32The question we're hoping and requesting that the commission considers
- 00:20:36here is that if 20 gigawatt roughly of load
- 00:20:40drives $13 billion of roughly investment,
- 00:20:43then how much investment we think 60 gigawatt of load
- 00:20:46is going to drive is going to be significant. We know that and
- 00:20:50it's going to be across the state of Texas and all the rate payers
- 00:20:53are going to be paying for that. So at the end of the day,
- 00:20:57two months or three months to wait for that analysis,
- 00:21:00I don't think is disservice to the rate.
- 00:21:04Second thing is, I think you mentioned around the analysis the
- 00:21:08analysis that occurred has performed for 765 and 345 kV.
- 00:21:12It uses the same criteria that
- 00:21:16ERCOT has and it coordinates with the NERC PPL
- 00:21:20standard. So the contingencies that you're mentioning of 765 kV
- 00:21:23outages, those have been reviewed by our court. If anything,
- 00:21:27the analysis that has not been completed is dynamic and stability analysis,
- 00:21:32which we know from our experience that the 345 kV
- 00:21:35network would require a lot of fax devices to be able to load the
- 00:21:39345 kV system to deliver this much of power to an area.
- 00:21:43We have seen that historically where we had to add fax devices like series capacitor
- 00:21:47to do that. On the other hand, a 765 kV,
- 00:21:50the surge impedance loading for that is so much higher that you
- 00:21:54typically don't require those type of fax devices. On the contrary,
- 00:21:58you require reactors because the voltages are higher. And that is something that is
- 00:22:01already baked into the cost of the 765 kV.
- 00:22:08Kristi, do you have anything anybody ask? Question?
- 00:22:11Mom. Cyrus, please go here. Cyrus, I'll step down.
- Clip 1 - Cyrus Reed - Sierra Club00:22:20 Cyrus Reed Sierra Club I did not file comments in this
- 00:22:24proceeding, so it's okay. I'm still allowed
- 00:22:28to speak. I want to remind folks
- 00:22:31that ultimately, consumers, all consumers, large and small,
- 00:22:35pay for these. So being careful and thoughtful is important.
- 00:22:40And want to remind folks that in this, in ERcot
- 00:22:44study, you know, there are really three
- 00:22:48costs. There's that local congestion costs, which I
- 00:22:51think everyone believes we can move forward.
- 00:22:55There's the 2030 costs, import costs, and then there's 2038
- 00:22:58costs. So it seems to me there's actually three proceedings.
- 00:23:02So you guys could decide to go forward with one and
- 00:23:05two and not three, as an example, and work on the first two imports.
- 00:23:10And then the other comment, and I'm sure I'll make this later,
- 00:23:12is one of the. Our concerns,
- 00:23:16is whether all this demand will really be there,
- 00:23:19and in particular, not so much oil and gas. We're actually in
- 00:23:23favor of electrifying oil and gas because it leads to less air emissions.
- 00:23:26So that's a good thing for the environment. More concerned,
- 00:23:31and I know this was required by the legislation that you look at
- 00:23:34this, but to the extent Oncor
- 00:23:38and others have letters indicating
- 00:23:41that hydrogen or crypto mining or data is
- 00:23:44coming in, there's not a lot of transparency for the public to know how real
- 00:23:48this is. So that,
- 00:23:51to me, argues for some amount of taking
- 00:23:55a little more time to make sure the demand is really going to be there
- 00:23:58before you build everything makes a certain amount of sense. And I know there's a
- 00:24:01lot of. There are protocols working through their way
- 00:24:05through Ercot, and I'm sure there will be more discussion at the
- 00:24:08legislature. So that may be something to consider is,
- 00:24:13you know, will there be more transparency going forward, or even
- 00:24:16some requirements that some of these units be
- 00:24:20used as controllable load resources, and therefore, maybe the
- 00:24:23demand isn't as great as you think it would be. So that, to me,
- 00:24:27says, you can spend a little more time. I know you've
- 00:24:31got your deadlines, and, you know, I'm not saying don't move forward in anything,
- 00:24:34but taking a little more time might make sense.
- 00:24:38Thanks. Anybody else?
- 00:24:47How many minutes do we have for the first ten
- Clip 1 - Brett Desayo - Coterra00:24:51minutes left? This won't be long. Brett Desayo, Coterra speaking
- 00:24:55to that comment in terms of will the load be there?
- 00:24:58As Megan mentioned,
- 00:25:01majority of the load will be there in 2032 and a lot of our
- 00:25:05projects are already planned to that extent.
- 00:25:09Speaking to load now, we do in fact have several hundred
- 00:25:13megawatts that we have been waiting on for multiple years. So there's
- 00:25:17load now that we need and there will be load
- 00:25:20in the future that we also need. Thank you.
- 00:25:24Okay, can we go to question two? Okay, you can stay here if you
- 00:25:28are going to talk at the question so you don't have to go back and
- 00:25:30forth.
- 00:25:33Question two would there be any permanent
- 00:25:36negative impacts to any stakeholder if the commission were to approve a
- 00:25:40phased approach where a complete 2030 plan would
- 00:25:44be approved in September of 2024 and a future plan
- 00:25:47for 2038 would be approved at a no later than
- 00:25:51date explicitly specified in the final order when commission
- 00:25:54approves the 2030 phase of the plan.
- 00:25:59And I just want to explain that question, what staff thinking, you know,
- 00:26:02you guys mentioned it as well. We want certainty and optionality.
- 00:26:06Is there any way can maybe if they are just playing Pollyanna
- 00:26:10can make everybody happy. So that's really if you have any
- 00:26:14ideas, any creative solution, can we
- Clip 2 - Bryson Dillon - ConocoPhillips00:26:17start from there? Sure. Good morning. Bryson Dillon with
- 00:26:21ConocoPhillips we'd like to thank the PUC for holding the
- 00:26:24stakeholder workshop to seek feedback on the permian
- 00:26:29reliability plan for the Permian Basin. We'd also
- 00:26:32like to thank the collaborative efforts of the PUC, ERCOT,
- 00:26:35the transmission service providers, and other basin operators to
- 00:26:40bring this plan to this stage. Additionally, let us thank our elected officials
- 00:26:44for their support on this critical issue.
- 00:26:47At ConocoPhillips, we are focused on sustainably meeting energy demand while
- 00:26:51creating lasting energy transition,
- 00:26:55while creating value for employees, communities and stakeholders.
- 00:26:58We intend to play a valued role in the energy transition by achieving the
- 00:27:02three objectives of our triple mandate,
- 00:27:05meeting transition pathway demand, delivering competitive
- 00:27:09returns to shareholders, and driving accountability
- 00:27:12for the emissions that are within our control.
- 00:27:16Key to achieving the objectives in our triple mandate is the electrification
- 00:27:20of our operations. Electrification plays a role in delivering
- 00:27:24low ghg intensity volumes and provides
- 00:27:27additional avenues to sell gas volumes that would otherwise be vented or used for
- 00:27:31combustion purposes. Given the height and electrification
- 00:27:35of operations, it became very clear that load demand would continue
- 00:27:39increasing rapidly over time, magnitudes much greater
- 00:27:42than we've seen historically. This is why
- 00:27:46ConocoPhillips collaborated with other operators to commission a revised permian
- 00:27:49basin load study with S&P global to account for
- 00:27:53this demand. The S&P study identified the
- 00:27:57grid connect gap and this is what was touched on largely
- 00:28:01in question number one and what we're seeing materially today.
- 00:28:06The grid connect gap illustrates that there already exists a
- 00:28:10significant gap in grid access from load that wishes to connect to the grid
- 00:28:13and is unable to.
- 00:28:16And this is really for traditional
- 00:28:20oil and gas operations but also just with everything else that we've
- 00:28:24committed and needs to be connected now and into the future.
- 00:28:29As the infrastructure continues to lag behind, demand increasingly are forced to
- 00:28:33turn to costly on site generation that has higher emissions
- 00:28:37intensity associated with it and also higher cost.
- 00:28:40This is just power to produce our wells even for the traditional operations
- 00:28:44that we're talking about here. The S&P
- 00:28:48study we recognize was just really one step along this journey to identify
- 00:28:52the necessary infrastructure projects needed to serve permian demand.
- 00:28:57There is subsequent hard work of the entities represented in this room again including the
- 00:29:01PUC, ERCOT, the TSP's and other basin
- 00:29:04operators. We now have what we feel is a well laid plan that sets
- 00:29:08the stage for building this crucial infrastructure.
- 00:29:12It is our hope that the plan is approved along the original
- 00:29:16timeline consistent with the legislative intent of HB5066
- 00:29:20and subsequently enables the TSP's
- 00:29:24to begin sequencing projects and filing CCNs.
- 00:29:27Ultimately we encourage the commission to approve a plan that
- 00:29:31addresses the significant need that already exists today and
- 00:29:35will exist for years to come. Thank you.
- Clip 2 - Michael McMillin - TIEC00:29:38Thank you. Michael McMillin for TIEC
- 00:29:42so TIEC thinks that under a
- 00:29:46phased approach that consumers in the permian
- 00:29:50basin are not going to get the certainty that HB 5066
- 00:29:54was meant to provide. And if we don't
- 00:29:57include in this first plan the import paths
- 00:30:01into the permian basin then potentially those
- 00:30:05import paths will be held up by a potentially
- 00:30:09contentious policy decision on EHV that
- 00:30:13we don't have the information on quite yet. And we honestly
- 00:30:17don't know how long that will take.
- 00:30:20It seems likely that the import paths will be needed before 2038.
- 00:30:25And if those import paths
- 00:30:29are not in place then customers are going to be forced to wait longer
- 00:30:32to interconnect. As you just heard from a customer in the
- 00:30:36permian basin and as we hear from our members that there
- 00:30:40is load in the permian basin right now that
- 00:30:43would like to electrify the areas historically underserved
- 00:30:47we're already behind to put it bluntly.
- 00:30:51And so we think
- 00:30:54that a plan that doesn't include the transfer paths
- 00:30:58into the permian basin is not going to effectively meet
- 00:31:02the demand and the increasing demand that we're
- 00:31:07seeing in coming years. So because these
- 00:31:11facilities are going to take four to six years to complete. I mean if we
- 00:31:14approved them today, they're not going to be in the ground and
- 00:31:18operational until 2029,
- 00:31:192031 somewhere in there.
- 00:31:23And as you saw in the S&P study, there's a lot of
- 00:31:26load coming online between now and then.
- 00:31:30And if it's the situation
- 00:31:34that we. That the commission gets started on
- 00:31:37the local portions of the project without the import paths,
- 00:31:41then we could end up in a situation where the TSPs have
- 00:31:45additional load that wants to interconnect and they have the transmission there
- 00:31:49to interconnect them. But they don't have the generation.
- 00:31:52Because as we discussed in our comments, the S&P
- 00:31:56study included a pretty high expected
- 00:32:00production from renewable assets. And the
- 00:32:04vast majority of the load in the permian basin is for example,
- 00:32:08oil and gas load. That's extremely high load factor. They run flat out
- 00:32:1224 hours a day. And that's when the sun isn't shining,
- 00:32:15when the wind isn't blowing. And so there needs to be some way to get
- 00:32:19power from the rest of the grid into the permian basin
- 00:32:23also. And this we discussed in our comments
- 00:32:27as well. We think that the assumptions on load
- 00:32:31growth in the S&P study were actually decrease
- 00:32:35the expectations a little bit because of the way that they assumed
- 00:32:39that load that is already there,
- 00:32:42that's hoping to electrify would come onto the system. They assumed that
- 00:32:46that would be constrained by the availability of
- 00:32:50transmission. And so the load that's
- 00:32:54spaced out. The load growth that's spaced out between 2029
- 00:32:57and 2032, if the transmission and
- 00:33:00the generation were available in 2029, they could interconnect then.
- 00:33:04So, you know, once again, the hope is that
- 00:33:07the commission will approve a full 345 plan now,
- 00:33:11retain optionality to add on EHV
- 00:33:15or substitute EHV at a later point once we've
- 00:33:18been able to fully evaluate that. But to get the ball rolling now.
- 00:33:22Thank you.
- Clip 2 - Meghan Griffiths - PBPA00:33:25Yeah. And I'd like to address some of the risks of a phased approach
- 00:33:29just so that everybody's clear on the cost impacts,
- 00:33:33the negative cost impacts of a phased approach. So the
- 00:33:38generation import path lines are necessary to bring energy
- 00:33:42into the basin. There's not enough generation to serve the load that's clamoring to
- 00:33:45get online. So if the commission were to adopt a phased
- 00:33:49approach to only approve the local
- 00:33:52projects, Ercot's so called no regrets option,
- 00:33:57or it were to only do as Mister Reid said
- 00:34:01and do you know, the local projects and the 2030 projects
- 00:34:05that would have a lot of regrets because all the load that is clamoring
- 00:34:08to come online will not be able to get online and because
- 00:34:12there won't be sufficient energy to serve the load. And so you're going
- 00:34:16to have a situation. The commission needs to approve a plan that
- 00:34:19will facilitate load growth so that the load that needs to
- 00:34:23get on can get there and then the costs can be spread over the new
- 00:34:27load growth. And so it's important for
- 00:34:31that reason also to approve the full
- 00:34:34345 kV plan. And if there is some
- 00:34:38ability to pivot after the full plan is approved,
- 00:34:41the commission can. But I
- 00:34:45think the commission would have deep regrets if it phased
- 00:34:49the plan in such a way and then subsequently
- 00:34:52the generation import pass were significantly delayed or
- 00:34:57they weren't approved or something were to happen that we can't quite see right
- 00:35:01now while we're trying to figure out the 765 options. So the no
- 00:35:04regret solution is actually the full 2038 345
- 00:35:08case solution. Because as ConocoPhillips has
- 00:35:12said, as TIBC has said, the demand forecasts in
- 00:35:16that SMP study were actually quite conservative. They were
- 00:35:20developed in 2021. You know, we're three years
- 00:35:23later and many of the companies have actually accelerated their ESG goals
- 00:35:28to electrify. They would have put higher
- 00:35:31electrification demand in those, in those particular load estimates
- 00:35:35had they been able to do so at that time. So we're actually,
- 00:35:40we actually think that the demand forecast for the oil and gas load in
- 00:35:44ERCOT study is quite conservative. So we
- 00:35:47need to build out the full plan in order to serve that load.
- Clip 2 - Kamran Ali - VP AEP Texas00:35:52Yeah, I think my colleagues here are making the case for 765
- 00:35:55because if our demand is actually lower than what it's going to be,
- 00:35:59the AirCott analysis is very clearly showing that there is
- 00:36:02a limit to which the 345 kV import export paths can
- 00:36:06bring in power. And beyond that you're going to need 765 kV.
- 00:36:10The 765 kV paths have a lot more transfer capability
- 00:36:14for that reason. So again, if we think there is a lot of uncertainty in
- 00:36:17load, then definitely we should be looking at a plan that
- 00:36:20is a no regret plan to make sure we are reliably able to
- 00:36:23meet the demands there. I think there is maybe some,
- 00:36:27you know, assumptions here that 765 may
- 00:36:31take much longer to develop than 345 kV.
- 00:36:35And in my view, you know, again, not a lot
- 00:36:39of people on this table have actually developed 765
- 00:36:42kV, except maybe AEP. And again, we don't want
- 00:36:45to be the only one whose opinion, you know, the commission
- 00:36:49should count on. For that reason, we really recommend that
- 00:36:52there should be a workshop where we have vendors and contractors and construction
- 00:36:56companies and standards folks who can come in and talk about
- 00:37:00what does it take to build transmission such as 765
- 00:37:03kV. We believe that we can build 765 kV
- 00:37:07in the same amount of time that it would take to build 345 kV.
- 00:37:10At the end of the day, the land impact. End of the day, the land
- 00:37:13impact will be less because you're going to need less of that. And there's a
- 00:37:16lot more transfer capability. Also, the analysis
- 00:37:20that have not yet been performed around stability are going to
- 00:37:23be, are going to show that the 765 kb
- 00:37:27performance is much superior. And finally, I'll underline the point I
- 00:37:30made again, I think one thing that we got to be very sensitive to is
- 00:37:34that the generation assumptions we made are assumptions.
- 00:37:37They're forecast. We're assuming that the generation will show up at
- 00:37:41x location. And if that doesn't show up where we're assuming it's
- 00:37:45going to show up. That details the transmission plan
- 00:37:49that we're building. So we need a very flexible transmission
- 00:37:53system that is able to take generation regardless of where the
- 00:37:57location is to where the load is. Excuse me, I'm going to just
- 00:38:01jump in. I would like to make sure everybody's understanding the implication
- 00:38:04of this hypothetical number two is to that there would
- 00:38:08be imports, it would have the 2030 would have imports associated with it.
- 00:38:11So I just want to make sure when you're answering that's
- 00:38:15the assumption, it maybe is not clear by the question. So that is all.
- Clip 2 - Stephen Mack - WETT00:38:18Go ahead. Thank you, Stephen Mack for WETT, we support
- 00:38:21the positions of ConocoPhillips and TIEC
- 00:38:25and other oil and gas producers. We want to get them connected,
- 00:38:28get them the local transmission and the imports that
- 00:38:31they need. But we don't think it's a choice either
- 00:38:35one or the other. I think that EHV can
- 00:38:39be considered more robustly later on when ERCOT
- 00:38:43does the ERCOT wide study. There are
- 00:38:47others besides AEP who have experience, as commented
- 00:38:50in the extra high voltage project.
- 00:38:54WETT is one of those. And they would very much appreciate
- 00:38:58working with stakeholders in a ERCOT
- 00:39:02wide solution. So it doesn't have to be one or the other,
- Clip 2 - Eric Goff - TEBA00:39:06I guess. Eric Goff,
- 00:39:09on behalf of the Texas Energy Buyers Alliance,
- 00:39:12Tiva has more than 260 members that represent some of the largest
- 00:39:16energy consumers and employers in the state.
- 00:39:20We don't want there to be a phased approach on this,
- 00:39:24but don't want there to be missed opportunities for extra high voltage.
- 00:39:27As part of that, we think that the AEP
- 00:39:32is probably correct that you can do extra high
- 00:39:36voltage on the same timeline with more
- 00:39:40opportunities. There are many of our members that
- 00:39:44are looking to continue to invest in Texas and request
- 00:39:49more load interconnections and the biggest constraint on that is
- 00:39:52just the physical infrastructure that you need to do so.
- 00:39:57So we would like
- 00:40:01for you to, you know, try to hear
- 00:40:04from these vendors that AEP mentioned as quickly as possible, as well
- 00:40:08as maybe a brief round
- 00:40:11of additional questions on just the incremental cost and
- 00:40:14benefits of the extra high voltage.
- 00:40:18What are the lost opportunities if you don't go with that?
- 00:40:21And try to just focus in on whether
- 00:40:27the extra high voltage can happen in the same timeline or
- 00:40:32has any additional benefits? And alternatively, are there
- 00:40:35risks like this stability analysis that we haven't considered yet
- 00:40:39for 345 kb? We think you can
- 00:40:42do that in a couple of weeks so it's not a delay to your overall
- 00:40:45project schedule and encourage you to
- 00:40:49narrow in and focus on whether there are
- 00:40:53any lost opportunities for not going with the extra high voltage option right now.
- 00:40:56Thank you. Before ERCOT, I want to go to people sitting there. Did you
- Clip 2 - Scott Seamster - TMNP Texas00:41:00please introduce yourself? Scott Seamster,
- 00:41:03TMNP. And I'm glad for the clarification because our
- 00:41:06primary concern is simply delay. We need the import pass.
- 00:41:10We have existing customers that are operating at lower loads because capacity
- 00:41:14is not there. We're not just talking forecast. They've already built their
- 00:41:18plants, they've already built their facilities.
- 00:41:22Any delay just is lost. That's the permanent harm.
- 00:41:26These folks have waited long enough.
- Clip 2 - Ryan Murphy - Diamondback Energy00:41:40 Hi, Ryan Murphy, I'm with Diamondback Energy.
- 00:41:44Just like to thank the PUC for samples workshop and giving the
- 00:41:48opportunity to speak. So I've lived in my
- 00:41:52family and I have lived in the permian basin for ten years or so.
- 00:41:56You know, Diamondback, we talk a lot about ESG projects.
- 00:42:00So I do feel like I'm here representing diamondback, but also the community.
- 00:42:05You know, I was reviewing the S&P study this last week and
- 00:42:09I'd have to echo what some of my peers have stated regarding,
- 00:42:12even though it's only, you know, around two years old, some of the data
- 00:42:16is quite conservative at this point.
- 00:42:19You know, the industry does continue to evolve, push the
- 00:42:23envelope regarding artificial lift,
- 00:42:26regarding drilling, regarding completions. And so I'd
- 00:42:30say horsepower in general has continued to increase even over a two year
- 00:42:33period. So I would certainly echo that.
- 00:42:37The load is here and it is a, if you build
- 00:42:41it, they will come sort of scenario.
- 00:42:44We at the moment have, you know, 100 to 120
- 00:42:49power waiting to get on the grid.
- 00:42:52So it's certainly of
- 00:42:55the utmost importance that we go forward with a plan that
- 00:42:59is sensitive to timing. I just like to also
- 00:43:03discuss that direct line generation is probably the least reliable
- 00:43:07form of power, is that wedge continues
- 00:43:10to grow as our, as our reliance on generation continues to grow.
- 00:43:14From my perspective, it also creates a risk during extreme weather
- 00:43:18events. So I would say, you know,
- 00:43:22keeping a reliable feedstock of gas is a concern.
- 00:43:26We certainly need to continue to trim that wedge down and
- 00:43:30get as much on the grid at timely manner is possible.
- 00:43:33So we as well support a single phased
- 00:43:37approach of 345 kV just because we
- 00:43:40feel like from a risk perspective,
- 00:43:44it reduces risk of projects being implemented in a timely
- 00:43:47manner.
- Clip 2 - Harley Henninger - Endeavor Energy00:43:51Good morning. Harley Henninger with Endeavor Energy. You're an
- 00:43:55oil and gas producer in the permian basin and the
- 00:43:59main point I'd like to stress is that the, like my peers have stated,
- 00:44:03the load is there now. There's a lot of things that we would
- 00:44:07energize off of the grid if we had the opportunity.
- 00:44:10And just historically the supplying of our needs has always
- 00:44:14been lagging. The need, the oil and gas timeframe
- 00:44:17that we need energy is just, it's kind of out
- 00:44:20of sync and ahead of what the grid has traditionally supported.
- 00:44:26It is definitely in our interest. You know, we're always fighting reducing generators
- 00:44:30and local generators and things like that. As far as local units
- 00:44:34connected directly in an island mode or
- 00:44:38something to supply our items. I mean, and that's in our best interest.
- 00:44:42That reduces our environmental footprint.
- 00:44:45We don't like to create emissions any more than we
- 00:44:49have to, that it's more reliable for us to be off the
- 00:44:52grid. We have less outages. So that all
- 00:44:56of these things kind of lead into reducing our cost of production,
- 00:44:59which benefits Texas and the nation
- 00:45:03and the world as a whole.
- 00:45:09We have spent quite a bit of time and effort
- 00:45:12to build out a distribution infrastructure internal to our company
- 00:45:16and we got ahead of that. I think we were ahead of a lot of
- 00:45:18people in that and it's supported us very well. But now
- 00:45:22we're starting to come up against transmission limitations. And so we have
- 00:45:26this distribution infrastructure and without these
- 00:45:29imports and without this power, we're kind of being pushed back
- 00:45:33into having to have more local generation and
- 00:45:37things like that. There's a lot of things like electric
- 00:45:40driven drilling and frac and
- 00:45:45even electric compression that I
- 00:45:49think my peers have stated already. But I'll just reiterate, those things are there and
- 00:45:53we would put more on the grid if the, if the power was available.
- 00:45:56Those things help not just with the emissions and things. It reduces vehicles on
- 00:46:00the road. When you're not trucking diesel and things. There's safety concerns with that.
- 00:46:04I mean if you visited Midland please come by. If you haven't.
- 00:46:08There's a lot of traffic and it's better these days but there's still a
- 00:46:12lot more traffic we could reduce. And so there's safety concerns.
- 00:46:15There's just concerns upon concerns and the load is there. Now I
- 00:46:19want to encourage us to come out with a plan
- 00:46:23sooner rather than later that can be implemented sooner rather than
- 00:46:27later. Thank you.
- Clip 2 - Caleb Troxclair - TAEP00:46:30Good morning. My name is Caleb Troxclair. I'm representing the
- 00:46:33Texas alliance of energy producers. The alliance has nearly 3000
- 00:46:38members around the state, many of which are producers
- 00:46:41in the permian basin. We'd like to echo the comments of
- 00:46:45PDPA, TIEC Oncor and several others here
- 00:46:49this morning. We believe the whole plan should be adopted
- 00:46:52now and not be bifurcated and do support the
- 00:46:55345 plan since that's the plan that will enable
- 00:46:59the needed transmission to be underway as expediently as possible.
- 00:47:03As a statewide organization we recognize the benefit of
- 00:47:07pursuing options for the whole state.
- 00:47:10However, HB5066 and the subsequent
- 00:47:13commission order have tasked this plan with addressing
- 00:47:17this long term and long lasting deficit in the permian basin alone.
- 00:47:21And we hope and ask that all parties keep this in mind. The greatest
- 00:47:25negative impact would be delaying what we needed yesterday in the
- 00:47:28permian for what we hope to accomplish at some point tomorrow.
- 00:47:32Thank you.
- Clip 2 - Cory Allen - STEC00:47:40Good morning. My name is Cory Allen. I'm with South Texas Electric Cooperative
- 00:47:44and you're probably going to have to give extra time after I'm through for everybody
- 00:47:48to come up here and argue with me. Right. Okay. So I'm
- 00:47:52here to say on behalf of nine distribution cooperatives who
- 00:47:56are going to pay their share of this investment
- 00:48:00as a TSP we're ready to help the plan but we
- 00:48:04want it to be the right investment.
- 00:48:09With that the permanent negative impact part of this question
- 00:48:14and the question about the timing on
- 00:48:18the approval, both of those wait for all the
- 00:48:21information that ERCOT get done is what we would
- 00:48:25urge. I understand lodes
- 00:48:30positions. They're in the permian basin. They're ready
- 00:48:33to connect up and understand that.
- 00:48:37But this is at
- 00:48:41least a $13 billion plan so far out of ERCoT's maybe
- 00:48:44higher. If it goes like KREZ it's going to be a lot higher
- 00:48:49and our ratepayers
- 00:48:53are going to be supporting that. So it should be a prudent
- 00:48:58investment. So we urge the commission to make a prudent investment.
- 00:49:01How do you make a prudent investment? Well, you invest in what's
- 00:49:05needed. You don't overinvest. We're not against 765
- 00:49:08kV at stack because at one point
- 00:49:11in time, you know, 345 kV made sense.
- 00:49:15Over 138. At some point in time, in some place 765
- 00:49:19kV makes sense. Over 345 or
- 00:49:22500 kV, whichever one is
- 00:49:26most economical. But in the permian
- 00:49:29basin,
- 00:49:33very many of the speakers this morning are
- 00:49:36oil and gas related, which is, I think that's where the legislation came from.
- 00:49:40And we're not arguing against that. But not all of
- 00:49:44that is committed. And I understand the legislation says hey, you don't
- 00:49:47have to have a commitment, but you gotta have a letter.
- 00:49:51And then there's half of the 26,000 mw.
- 00:49:56That's not all in gays, right. Well that part we urge the commission to be
- 00:50:00careful. I'm not asking for a commitment. But even at
- 00:50:04stack we're at 2000.
- 00:50:08If all the load requests were all added together that
- 00:50:12we're working on, in four years we'll be at 10,000 mw.
- 00:50:16On one hand you say oh yeah, that supports ERCoT's load growth.
- 00:50:19On the other hand. Is that reasonable?
- 00:50:22Let's make sure it's reasonable. I'm sure that some of those permian basin
- 00:50:27loads, those letters from TSP's,
- 00:50:31some of those loads of probably make up part
- 00:50:35of more than one letter. So that's one way
- 00:50:38that the commission can make sure that,
- 00:50:42you know, you're not trying to serve duplicate loads out
- 00:50:46in the Permian Basin and over investing.
- 00:50:50Right. Because on behalf of our ratepayers,
- 00:50:54that's what we don't want them to have to do is over invest.
- 00:50:57And the other is how many of these loads
- 00:51:01that were going to spend 1315
- 00:51:05or whatever billion on are
- 00:51:10able to get off of a 4CP. So we would urge the commission
- 00:51:13to look at a way to pay for
- 00:51:17those investments other than right now where
- 00:51:21our residential and small business businesses are supporting
- 00:51:26more than their fair share. So we would really want
- 00:51:29it to be a fair investment payment
- 00:51:35plan other than burden residentials and
- 00:51:38small businesses. So we want the commission to look at 25,192 b.
- 00:51:42Thank you.
- Clip 2 - Warren Lasher - TXOGA00:51:45Yeah. I'm Warren Lasher representing TXOGA.
- 00:51:49So completely understand Corey's comments
- 00:51:53about costs. Texoga members are
- 00:51:57significant users of electricity so we are
- 00:52:00very cognizant of costs as well. In addition,
- 00:52:04this plan will enable a significant increase in
- 00:52:08customer demand on the grid. And oil and gas companies
- 00:52:12are going to be paying their fair share of the
- 00:52:16transmission costs as we move forward, not just for this plan, but for all
- 00:52:20of the transmission improvements on the system going forward.
- 00:52:25I wanted to reiterate, the demand is there today.
- 00:52:28We have companies out there today that want to electrify,
- 00:52:32want to move to the grid. The forecasted increase
- 00:52:36is extremely front loaded. Like Megan said,
- 00:52:40most of that demand is going to show up in 2032 before
- 00:52:44really we're able to fully implement whatever plan the
- 00:52:48commission approves. But I wanted to take
- 00:52:51a step back, and I wanted to say decision
- 00:52:55points don't come that frequently.
- 00:52:58I spent a long time in transmission planning,
- 00:53:01and I know that friction of I'm
- 00:53:05going to know something tomorrow that I wish I knew today.
- 00:53:10But if you take a step back and you think about how we got to
- 00:53:13this room here today, the producers started,
- 00:53:17what, three years ago, three and a half years ago,
- 00:53:20thinking, hey, you know, maybe we need a better forecast
- 00:53:25of what our electrification is going to be. And then
- 00:53:29a lot of people in this room spend a lot of time at the
- 00:53:32Capitol, not just this past session, but the session before
- 00:53:35that. So there were two sessions that led up to the
- 00:53:39governor signing legislation June of 23rd,
- 00:53:44June of 23rd with instant effect.
- 00:53:48HB5066. And that has brought us here
- 00:53:53today and hopefully will bring us to
- 00:53:56a commissioned decision in September. The idea
- 00:54:00that we're going to have another decision point in January
- 00:54:04or February or March of next year.
- 00:54:08Decision points don't come that frequently.
- 00:54:11And there's been a lot of work that has gotten us to this
- 00:54:15point here today. The producers have
- 00:54:18been waiting, been a decade of insufficient
- 00:54:22transmission. And I know because I'm responsible for some of that,
- 00:54:26unfortunately, and I apologize. But going
- 00:54:30forward, I can try to fix mistakes. Now,
- 00:54:35the demand is there today. The forecasted demand is going to
- 00:54:38be there very quickly. The only thing we got on the table
- 00:54:42today that we can say build that
- 00:54:46is the 345 kV plan for the entire
- 00:54:49package. That's what Texoga is asking for after
- 00:54:53all of the hard work that the producers and everyone has done to fashion
- 00:54:58the legislation that we're trying to implement here today.
- Clip 2 - Chad Burnett - VP AEP Texas00:55:02Thank you. So, my name is Chad Burnett.
- 00:55:05I'm the vice president of regulatory and finance for AEP Texas. You know, and I
- 00:55:09want to start by saying I really appreciate hearing all of the consumer
- 00:55:13positions on this because I think what you're hearing really loud and clear is
- 00:55:17the loads are here today, that these customers are ready to connect and it's
- 00:55:21going to frustrate them. Them. If we can't get them connected sooner.
- 00:55:24And I can tell you in my seat, I feel that often.
- 00:55:28But I want to tell you, there's been a lot of discussion about the load
- 00:55:31forecasts and about the study that was done that was dated.
- 00:55:35And I want to highlight that that was not all that this load forecast that
- 00:55:38Ercot's using is based off of, because the other piece that we did was
- 00:55:43an attestation letter. And so let me put
- 00:55:46this back into context, because the growth is not just coming,
- 00:55:49it is here. So from 2011
- 00:55:53to 2021, AEP Texas on average
- 00:55:57grew by 50 year. In 2022,
- 00:56:01our load increased by 550.
- 00:56:05Same thing happened in 2023. And through the
- 00:56:09first half of the summer, before school started this week, we've already gone up
- 00:56:12another 300 mw. So within the last two and a half
- 00:56:15years, we've experienced 25 years of growth in
- 00:56:20two and a half years. This was done during the same
- 00:56:23period or basically after the study was completed. Right. So this
- 00:56:27is not just will these loads come. I'm telling you as a testimony,
- 00:56:31it is here. And it's never been any like this before.
- 00:56:34So that is a the reality. But let's talk about
- 00:56:38the loads themselves. So last summer, we set a new all time peak at seven
- 00:56:41and a half gigs. And what we submitted to ERCOT
- 00:56:45was 22 gigs of new loads. Which sounds ridiculous, right?
- 00:56:49Because we're talking about quadrupling ourselves. And the study
- 00:56:52is about 2032 and 2030. That's what we're focused on.
- 00:56:56These loads are wanting to connect by 2027 and 2028.
- 00:57:00And so it's not about when they talk about the difference between
- 00:57:04those two. There is no, people aren't waiting till 2038.
- 00:57:07They're saying, can we get here sooner than that? The other things that's happened is
- 00:57:11the dynamics have changed dramatically. Like, it's no longer.
- 00:57:14Oil and gas has always been the predominant load in the Permian until
- 00:57:18recently. And we're seeing a tremendous amount of interest from these
- 00:57:22data centers, crypto miners and all other
- 00:57:26places across the state. We're seeing a lot of growth in other industries, but some
- 00:57:28of these can connect really, really rapidly. And there's a
- 00:57:32concern that if we go forward with a short sighted plan that
- 00:57:36doesn't accommodate the true needs of the growth that we're seeing,
- 00:57:40that they may still be frustrated because somebody else can scoop up and take
- 00:57:44that capacity away from them. So I think we need to think more long term
- 00:57:47and holistically. But talking specifically about those, when we
- 00:57:51submitted the 22 gigs of loads at that time,
- 00:57:54we had basically eleven gigs of customers that had
- 00:57:57signed and already paid money to us. So we've already received,
- 00:58:01through a kayak payment, millions of dollars for these customers that are saying,
- 00:58:04I want to connect to the Texas grid. The other were
- 00:58:09customers that were not shopping. These were customers that have already come to us.
- 00:58:13They were in line and saying, I also want to connect. And as soon
- 00:58:16as you can finish the study, I'm willing to pay. And they were largely
- 00:58:20waiting for us to be able to tell them what is the, when can we
- 00:58:23get them connected? And they're waiting on a lot of the ERCOT studies to be
- 00:58:26performed. So we're talking, these 22 gigs are
- 00:58:29the ones of just customers that have already paid us money because they want
- 00:58:32to connect, or ones that are in line to pay us money because they want
- 00:58:36to connect. And there's a whole nother 20 gig that is still
- 00:58:39shopping in our foot that we didn't even include to ERCOT. And we said,
- 00:58:43well, we'll wait until maybe next year or until there's more serious commitment
- 00:58:47there, because this was a reputational thing for us. So when you hear a lot
- 00:58:51of reference to the S&P study and there's some current concern about,
- 00:58:53are these loads going to show up? I just want to tell you, from AP's
- 00:58:56perspective, we were very judicious and conservative because
- 00:59:00I spent the first 25 of my years of my life doing load forecasting
- 00:59:04and I've never seen it like this before. And it was hard for me to
- 00:59:07believe. But I guess when I think about who's going to be harmed, I really
- 00:59:10think we need to think about the future of this economy, the future of
- 00:59:14where we're going, because we're looking at, it's not just oil and gas. We're seeing
- 00:59:17a lot of interest with hydrogen, which a lot of oil and gas producers are
- 00:59:20helping. We're seeing a lot of growth in Lng and exports, those sorts
- 00:59:24of things. It's all across the state, it's all across the board. It's not just
- 00:59:27the Permian. And so I just want to make sure that we are thinking about
- 00:59:31a plan that's not short sighted, that we really are thinking about the needs,
- 00:59:35not only where we have been, where we are today, but where we're going.
- 00:59:39Thank you. Anybody else? Because I want to give to ercot
- 00:59:43the last word.
- 00:59:48All right. Well, it's hard to follow. Chad,
- 00:59:53want to just reiterate, we understand the need
- 00:59:58and how we got here, the needs of the consumers in the
- 01:00:02Permian. And what we're trying to do is provide you the
- 01:00:05best plan. I recognize the desire for
- 01:00:09certainty. I think we can work with the commission to give a certainty
- 01:00:13on timing so that we have a little bit additional time
- 01:00:17to consider all of the consumers of Texas and the best solution
- 01:00:20for all consumers. And I believe it will also be a better
- 01:00:24solution for the consumers in the permian. Because moving
- 01:00:28to a higher voltage will provide you more certainty on
- 01:00:33the generation availability, as well as the capacity for
- 01:00:37future load growth in your region. I'm going
- 01:00:40to turn it over to Prabhu, who's going to give you a little bit of
- 01:00:43information, which goes back to your actual question that we started with,
- 01:00:49based off of the plan and some of the different options and what
- 01:00:52it would do from a cost perspective.
- Clip 2 - Prabhu Gnanam - ERCOT01:00:56Thank you. Good morning. This is Prabhu Gnanam. I'm the
- 01:01:00director of planning here in ERCOT.
- 01:01:04To answer your question directly to question
- 01:01:08number two, there were two parts. The impacts of approving
- 01:01:11a 2030 plan with the import lines we identified two,
- 01:01:15if you look at 345, there's two import pads identified for 2030.
- 01:01:20And the question is, if we move to the next
- 01:01:24phase later, what is the impact? So from what
- 01:01:28we know today, we are working on the 2024 regional transmission
- 01:01:31plan, which is looking at a holistic view of what is needed for serving all
- 01:01:35loads within this. Within the state of Texas.
- 01:01:39And that plan is looking at
- 01:01:42several alternatives. Looking at 345 and EHB
- 01:01:46options. 500 kV, 765. So if
- 01:01:49we were to proceed with approving the 2030
- 01:01:53plan with import path, that would have an impact on the
- 01:01:58overall holistic plan that ERCOT is looking. Because if
- 01:02:01you approve parts of the projects that could probably delay
- 01:02:06or change the future transmission
- 01:02:10needs in the permian region, especially with the
- 01:02:13EHB. So now you could be looking at a
- 01:02:18mixed option. Like you're looking at a combination of 345
- 01:02:21for 2030 plus any additional EHV.
- 01:02:25So obviously, that's going to take more time to review.
- 01:02:28We're not looking at that option now. So if we were to do that,
- 01:02:32we need more time to find out the holistic plan for
- 01:02:35our cut. And it also has
- 01:02:39the potential to overall increase the cost. Because as
- 01:02:43such, presented in the permian plan, each of the options,
- 01:02:47you know, there is a. Some efficiency in building a
- 01:02:50345 versus 765. So when you do
- 01:02:54a mixed option, we think the overall cost will
- 01:02:57be higher than, you know, moving forward with the
- 01:03:01765 holistic plan that I'm going
- 01:03:04to stop. Thank you.
- 01:03:07Anybody else on question two? Okay,
- 01:03:10question three. Bill Barnese
- 01:03:14and I really would like Texago as well. The reason we asked that question
- 01:03:22really because in their comments energy
- 01:03:26said that this is used in the gas industry and
- 01:03:29I want you to rebut Bill. Is it true? Does it work? Is it an
- 01:03:33example we can use or it's completely irrelevant. So that's why
- 01:03:37we are coming. And just for the record, I'm going to read it even though
- 01:03:39you all know, seem to know. Number three is the network open
- 01:03:43season concept proposed by NRG and used in the natural
- 01:03:47gas industry a viable option to consider for transmission build out in
- 01:03:50ERCoT for new large loads? I'm gonna start with
- Clip 3 - Bill Barnes - NRG01:03:54Bill on that one. I really appreciate that. Bill Barnes,
- 01:03:57NRG. There any Tupac fans in
- 01:04:01the house? He's got a song me against the world. I probably should have listened
- 01:04:04to that drive in this morning.
- 01:04:08I guess. First of all, I would like to just go through
- 01:04:12some of our perspective, background why we proposed this.
- 01:04:16Hopefully to calm down some of the concerns that we've heard
- 01:04:20as well. We identified
- 01:04:24potential policy need that our
- 01:04:27current policies don't accommodate. Giving the significant investment that's coming.
- 01:04:31That is needed by the way. And so really what we're offering here is
- 01:04:36a suggestion, something to think about in terms
- 01:04:39of how we address parts of the Permian Basin project
- 01:04:43and what's coming next. Our primary concern for
- 01:04:47proposing this is the long term cost impact for
- 01:04:50consumers in Texas that will pay for this, particularly the residential class of consumers
- 01:04:54in competitive territories. So first of all,
- 01:04:58background and perspective. NRG supports
- 01:05:02transmission expansion for load growth. We have
- 01:05:06been participating in the RPG discussions for many years.
- 01:05:09We have seen the needs of TSPs
- 01:05:13to include in their planning forecasts
- 01:05:17load that is not. That does not have signed contracts so that they can get
- 01:05:21in front of the problem. And that is what HB5066 Washington intended
- 01:05:24to do, which we support. We were part of those discussions as well.
- 01:05:28And at that time the uncommitted load
- 01:05:32portion was met by, you've heard referenced a few times an S&P global
- 01:05:36load forecast study that really helped
- 01:05:40identify the need. That was in
- 01:05:43addition to signed contracts that,
- 01:05:47based on our participation in those discussions, really the intent of
- 01:05:50HB5066. What additional analysis
- 01:05:55or step can be used to help identify future
- 01:05:59load growth that's not met by signed contracts because
- 01:06:03that will inevitably delay the development which we've heard,
- 01:06:06which we believe is true. We have customers. We talk to them. They need transmission
- 01:06:11service expansion in the Permian Basin to serve oil and gas
- 01:06:14load growth. The problem is
- 01:06:18since then, two years ago, the world's changed.
- 01:06:22We now have double the amount of load growth in the permian
- 01:06:25basin from non oil and gas loads,
- 01:06:29which puts the projected load forecast in the future
- 01:06:33in far west to be almost equivalent to the coastal
- 01:06:37weather zone, which includes the fourth
- 01:06:41largest metropolitan, metropolitan complex in the United States.
- 01:06:44So significant load growth since
- 01:06:49then. In the rest of ERCOT,
- 01:06:52we have another six gigawatts of crypto load,
- 01:06:55another 30 gigawatts of data center load, another 21
- 01:06:59gigawatts of green hydrogen. Those loads were not supported
- 01:07:03by an independent study of S&P global load forecast.
- 01:07:07They're supported by TSP executive officer
- 01:07:11letters, which we believe is a good first step in the process.
- 01:07:16But as you've heard from other speakers, there's not a
- 01:07:19whole lot of transparency on what that load,
- 01:07:22what consists of that load, what commitments those customers
- 01:07:26have made, how real it is or how real it isn't. And that is a
- 01:07:30concern for us in terms of are we sizing the transmission
- 01:07:34development properly,
- 01:07:38cost allocation components, and really comes down to the CCN
- 01:07:42process as well. We put ourselves in the shoes of the commissioners and
- 01:07:46it feels like we would. We need more to be able to meet the need
- 01:07:50requirement in approving a CCN for non oil gas load
- 01:07:54growth, particularly when we're talking about the next phase, which will come outside of
- 01:07:58ERCOT. So this is really introducing a concept
- 01:08:02for consideration that can help verify,
- 01:08:05prove up the need for the investment potential.
- 01:08:08And this is really the idea kind of started with like
- 01:08:12a data center Crez, which that was a big
- 01:08:16part of the Crez process is the wind generators that
- 01:08:20needed service. There was an entire case dedicated to
- 01:08:24customers, those customers identifying themselves, raising their hands,
- 01:08:27saying, yep, we're here, we need service, posting a deposit.
- 01:08:32And that is really what kind of led us to the network open
- 01:08:36season concept to apply to a phased approach.
- 01:08:41One thing to be clear, we are not intending to slow down
- 01:08:44the need to get transmission to West Texas for oil and gas customers
- 01:08:48that have been underserved for years.
- 01:08:50So I would think of this as something that we could consider
- 01:08:54in a phased approach, or when we're talking about transmission expansion
- 01:08:58needs outside of the permian basin, we are
- 01:09:02going to need some additional policy tool to address that,
- 01:09:05because we've got a really big wave coming of investment
- 01:09:09and we're concerned about the long term impacts to consumers.
- 01:09:13So here's the other thing.
- 01:09:16We don't have this, all the details figured out. This is really
- 01:09:20a thought, an idea that we wanted to bring forward.
- 01:09:24It's not fully baked. It would be something that would require
- 01:09:28a lot of discussion amongst stakeholders amongst ERCOT commission.
- 01:09:34Probably a separate project, maybe even statutory
- 01:09:37changes, which that was included as part of Crez. Right.
- 01:09:41There were some. There were specific statutory requirements
- 01:09:44in language that helped accommodate the Crez project. But this is of equivalent
- 01:09:48size and magnitude that we think it's appropriate and could be included if
- 01:09:52there's agreement in commission scope report in the future,
- 01:09:55particularly if we're talking about a second phase that
- 01:09:58is 2038 and beyond. So the
- 01:10:02principles of what a network open season concept could do or
- 01:10:06look like would be having large
- 01:10:09customers, and that would be open to debate.
- 01:10:13One marker on that is ERCOT has filed
- 01:10:17a protocol revision request. And we've talked about this in a large flexible load
- 01:10:21task force that identifies large customers as 75
- 01:10:24mw or greater, would post some type of
- 01:10:28refundable deposit and reserve future transmission capacity.
- 01:10:33And that would help the commission and ERCOT size
- 01:10:36the investment to what the actual needs are and have the customers
- 01:10:40show commitment beyond what's in the TSP letter.
- 01:10:46That would also help potentially with locations,
- 01:10:50what infrastructure is needed where,
- 01:10:55and have show
- 01:10:59that there's commitment with a refundable deposit over
- 01:11:02some period of time. We propose ten years. That may be too long.
- 01:11:06A shorter period of time may be more appropriate, but I
- 01:11:10would just think about it in that context.
- 01:11:14At the very least, though, we need to revisit
- 01:11:17cost allocation. Continuing forward with the
- 01:11:21cost of these projects and what's coming next with our existing
- 01:11:25cost allocation methodology is wholly
- 01:11:29inappropriate and will could have pretty devastating financial impacts.
- 01:11:33So at least I would recommend we study the
- 01:11:38commission, study what the impact to
- 01:11:41consumer classes are as a result of these projects. That can be done pretty easily
- 01:11:45and then have a whole separate discussion on how cost should be allocated.
- 01:11:49I will stop there. So I really want to hear from Texarka.
- 01:11:53Is this really a concept used in oil and gas?
- 01:11:56Like, does it apply? Do you have any experience? Anything helps staff to understand.
- Clip 3 - Megan Griffiths - PBPA01:12:01 So this is Megan Griffiths and I'm speaking for the Permian Basin Petroleum
- 01:12:04association. And so I am not
- 01:12:08able to speak to the network open season concept in the gas industry.
- 01:12:11But what I can point out is the obvious point that bill made,
- 01:12:15which is that what they're proposing here would require protocol
- 01:12:19changes, rule changes, potentially statute changes.
- 01:12:22And what we need to recognize with respect to this plan is
- 01:12:27that HB5066 carved out
- 01:12:31a specific provision for the permian.
- 01:12:34Right. So under 39.167 b,
- 01:12:38the commission is to adopt a plan that must address extending
- 01:12:42transmission service to where mineral resources have been found.
- 01:12:46The plan should address, address increasing available capacity to meet forecasted
- 01:12:50load and provide available infrastructure to reduce interconnection
- 01:12:54timelines in areas without access to transmission service.
- 01:12:57So I find it an interesting concept that
- 01:13:01bill is raising. We're not prepared to have a position
- 01:13:04on it at this time. But I do appreciate his
- 01:13:08comment that it's not fully baked. And what we have right here
- 01:13:11is a really fully baked problem getting transmission in permian. And so
- 01:13:15I do not think it is appropriate to inject this concept
- 01:13:19into the permian plan and because there are much
- 01:13:22larger policy issues that they're raising.
- 01:13:26And so I'll leave it at that and don't have much to
- 01:13:30offer on, you know, network open seasons and how we would modify
- 01:13:34existing PUC rules and regulations to do that.
- 01:13:38Texoka, do you have any, is it used in your industry?
- Clip 3 - Warren Lasher - TXOGA01:13:43Yes, this is Warren Lasher with TXOGA. I would agree with what Megan said.
- 01:13:48It sounds like it's an idea for future consideration,
- 01:13:52but it's just simply not timely. But it's not used in the gas industry.
- 01:13:57Is it not used in the gas industry for the pipelines? No.
- 01:14:02Open seasons are used in the gas industry. The natural gas delivery
- 01:14:06system is extremely different from the transmission, the electric transmission.
- 01:14:10I mean, there's. From a physical perspective, they're very,
- 01:14:14very different. So, you know, I mean, it may be an interesting idea
- 01:14:18porting it over to the electric industry.
- 01:14:21Porting it over to the electric industry in ERCOT.
- 01:14:24The unique market design we have here in ErcoT.
- 01:14:28That's a. It's a very lengthy conversation.
- Clip 3 - Kristina Rollins - NRG01:14:34 Christina Rollins, assistant general counsel of regulatory affairs for NRG,
- 01:14:38providing some legal help to my friend here, Bill Barnes.
- 01:14:41So in looking at what
- 01:14:44we're all here to do today, I think there are three sections of the statute
- 01:14:47that are important. Right? There's 350561,
- 01:14:52which adds language to the CCN statute that talks about need.
- 01:14:55And so then there's the question of what latitude does that addition give the
- 01:14:58commission an assessing need? And then there are also the two new
- 01:15:02sections of the statute of 39. 166 and 167.
- 01:15:06167 addresses the Permian Basin plan. And then 166,
- 01:15:11I think, is about the high load growth areas. And so when you take all
- 01:15:14of those together, what do those different sections mean
- 01:15:17with respect to the assessment of need? Would it be possible,
- 01:15:20for example, for the permian basin, for oil and gas to determine that you
- 01:15:24have determined need or you have assumed that need exists to
- 01:15:28serve that oil and gas load such that it makes the subsequent CCN proceeding a
- 01:15:32lot faster? Because you don't have to go through the need process
- 01:15:35and for the network open season concept that bill discussed,
- 01:15:39perhaps that is something that you do apply in a different phase
- 01:15:42to assess other load that may be coming in where you're more speculative
- 01:15:46on need. So those are how we're also thinking about it within the context
- 01:15:51of how you fit them within the criteria for a CCN. Thank you.
- Clip 3 - Michael McMillin - TIEC01:15:56 Michael McMillin for TIEC I'd like to reflect Miss
- 01:15:59Griffith's comments and note
- 01:16:02that this just isn't the forum to inject this
- 01:16:06concept. I mean, as Mister Barnes said, this would require changes
- 01:16:10throughout the statute's rules, protocols.
- 01:16:14And that is a much more lengthy discussion
- 01:16:17than the one that we're having here. And I think that the
- 01:16:21critical point is that we shouldn't hold up the
- 01:16:25Permian Basin projects and the Permian Basin plan to
- 01:16:29try to implement this. Now to the extent the commission wants to explore
- 01:16:32it, that should be a separate project and a separate rulemaking.
- 01:16:36Yeah, that's not the intent. It's just to gather data. No. And I understood
- 01:16:40that from Mister Barnes's comments. I just wanted to,
- 01:16:44I just want to do one joke. It's very interesting to see TIEC advocate
- 01:16:48for more TIEC course. It's really refreshing.
- 01:16:52I had to say that Ned. Sure.
- Clip 3 - Ned Bonskowski - Vistra01:16:55 Ned Bonskowski with Vistra.
- 01:16:59You know, first off, I want to say that we support and recognize
- 01:17:04the interest that's apparent before you today. You've heard a lot from,
- 01:17:08from our friends in the oil and gas industry about
- 01:17:11the pent up demand that they have in the region. And we support serving
- 01:17:15that and getting the grid service that it needs
- 01:17:21efficiently and expeditiously. We have read some of the
- 01:17:25comments. We haven't heard as much today, but I have
- 01:17:28read some of the comments that raise concerns about the costs and
- 01:17:32some cases proposed some pretty material changes to the policy
- 01:17:36around those. And so I think there is
- 01:17:41perhaps some sympathy to
- 01:17:45potential impacts. When you start looking at the costs associated
- 01:17:49with the Permian Basin reliability plan, not only is
- 01:17:52it a large headline number, but it almost starts to get into some of
- 01:17:56the costs that we've looked at for, say, how much it takes to invest
- 01:17:59in a dispatchable generation plant, right.
- 01:18:02In terms of just total dollars per megawatt of transfer capacity.
- 01:18:08So I can understand why that comes up. But this
- 01:18:12is the plan we have in front of us. And NRG's
- 01:18:16proposal does seem to seem to offer an opportunity
- 01:18:20to maybe turn some of that around and have a way to not delay the
- 01:18:24process but provide a way to inject
- 01:18:28some additional say, evidence of need
- 01:18:31that will come up in the CCN process and pressure test some of the
- 01:18:35load forecast assumptions that I think you've heard about from others.
- 01:18:39I think what you've heard today probably would support that.
- 01:18:42A lot of that is there and you would see that and be able to
- 01:18:45rely on it. But understand also that it
- 01:18:48is not a big concept. So, you know, if it can't
- 01:18:52be implemented quickly, then we should certainly discuss it on
- 01:18:57a forward basis. Thank you.
- Clip 3 - Cory Allen - STEC01:19:02 Cory Allen with South Texas Electric Coop STEC
- 01:19:07thinks it is potentially viable concept.
- 01:19:11We think we probably want the commission
- 01:19:14to go another step. I got every faith in the world you can change a
- 01:19:17rule in a hurry. All right, so we
- 01:19:21are. Warren said the industrial
- 01:19:25customers are paying their share of
- 01:19:29the transmission and I'm not going to say some of them are not.
- 01:19:32But we all know some can get off,
- 01:19:35get off the line, reduce or load through
- 01:19:39a few intervals and four months of the year and
- 01:19:44not pay for quite a few kW's worth of
- 01:19:48transmission service. So what we would urge
- 01:19:51the commission to do is if you're looking at this
- 01:19:56network overseas or something else,
- 01:19:59I took it more as a level of commitment,
- 01:20:03but we would urge the commission to go further and make sure
- 01:20:06that this very large build out to loads
- 01:20:10that many have shown the ability to
- 01:20:14get off over 4CP and shift those costs,
- 01:20:17that there is some method there of
- 01:20:20paying for that service. Thank you.
- Clip 3 - Eric Goff - TEBA01:20:24 Eric Goff, Texas Energy Buyers alliance.
- 01:20:27Most of what I would say has already been said. So I would just
- 01:20:31say, I'm not saying that was what Bill suggested, but when you
- 01:20:34get into cost allocation disputes and other jurisdictions,
- 01:20:38that can be the biggest cause of delay for projects. And so
- 01:20:41I'm not saying that's what Bill is suggesting here, but we just need to be
- 01:20:44cautious. Sounds like this is a separate proceeding and everyone agrees about that.
- 01:20:48So I'm glad to go last and say we all agree this is a separate
- 01:20:50proceeding. Can I go last?
- 01:20:54Last, yeah, last. Last. I just wonder. Oh no,
- 01:20:57Liz is here. I was just going to say,
- 01:21:01just to reiterate because I heard the point a few times, is that we're not
- 01:21:05intending for this to slow down the development
- 01:21:08that's needed in Permian Basin. We know the oil and
- 01:21:12gas industry has been needing service for many, many, many years now. So that's not
- 01:21:15the intent. And given an
- 01:21:19opportunity to bring this up and the significant change or the
- 01:21:23facts on the ground changed for what this project had intended,
- 01:21:27was initially intended. So we feel it's appropriate to discuss and introduce
- 01:21:31the topic here. If the commission does have interest in talking more
- 01:21:34about it, we have hired Rob Gramlick from
- 01:21:38grid strategies that helped put together the NaSS concept. He has worked on
- 01:21:41similar network open season projects in the gas industry
- 01:21:45and in the electric industry in western United States. So thanks
- Clip 3 - Liz Jones VP Reg. Affairs Oncor01:21:51 Liz Jones. Oncor. Couple of things to bear
- 01:21:54in mind as we have this discussion.
- 01:21:58Unless Bill's proposal is adopted,
- 01:22:02we do not have a reservation of capacity system in
- 01:22:06ERCOT. We have availability as our mantra
- 01:22:10and we can talk about what 5066
- 01:22:14was or was not intended to fix. And certainly the first project
- 01:22:18was focused on the Permian because of the oil and gas needs.
- 01:22:22The fact is though, anyone can come
- 01:22:25to a TDU or a coop
- 01:22:29or a muni and request service, and if the
- 01:22:32capacity is available, it is our obligation to interconnect
- 01:22:36them. So if we were to ignore the
- 01:22:40other capacity, the non oiling gas capacity
- 01:22:44that has been forecast,
- 01:22:47Oncor at least is very concerned that
- 01:22:51the other loads will come anyway and that there
- 01:22:55will be inadequate capacity to serve the oil and gas.
- 01:22:59So I think it's incumbent on all of us in the 50 66
- 01:23:04analysis to consider all the loads and not
- 01:23:07just some of the loads. Unless somebody can
- 01:23:12figure out a way that reserves capacity for only some kinds
- 01:23:16of customers, because that's never been the practice before.
- 01:23:19Thanks. Anybody else on this question?
- 01:23:22Yes, here. Sorry.
- 01:23:33Cyrus Reid, Sierra Club do you know the song enemy by Drake?
- 01:23:36Sorry, sorry.
- 01:23:43Like the idea, like the concept needs to be a separate proceeding.
- 01:23:47But I do appreciate a couple of comments that
- 01:23:51NRG made really separate from the concept.
- 01:23:54One is again talking about oil and gas
- 01:23:58loads versus non oil and gas loads, figuring out a way to
- 01:24:01have better transparency so we understand more
- 01:24:05the reality of that load and where it is and therefore what
- 01:24:09transmission projects are needed for that load, I think would be important.
- 01:24:12And then looking at can
- 01:24:16we put further requirements so that certain loads
- 01:24:19are controllable for our peak times. I think are
- 01:24:23two important concepts that weren't necessarily in NSO,
- 01:24:26but I were mentioned in your comments and very much appreciate
- 01:24:30those comments, I think. So I won't come back up for question
- 01:24:33number nine, but those are two things that I think you guys
- 01:24:37should explore as part of this. Thanks.
- 01:24:41Okay, next group of questions are really CCN process
- 01:24:44and I'm going to look at my infrastructure staff and OPDM staff
- 01:24:49to pay more attention on those because market analysis we are not involved in,
- 01:24:53but that's really important for us. How are we going to do all this work
- 01:24:57once we approve the plan? Okay, number four,
- 01:25:02should the commission approve a plan at the September 26,
- 01:25:052024 open meeting. By what date can TSPs,
- 01:25:10with the input of ERCOT, provide an implementation plan,
- 01:25:14including sequencing of projects for use
- 01:25:18by the commission to establish a schedule to sequence priority projects
- 01:25:21in subsequent projects?
- Clip 4 - Stephen Mack - WETT01:25:32 Stephen Mac for WETT
- 01:25:35is not one of the TSP's
- 01:25:40in the plan with the most transmission,
- 01:25:44but we could commit to get a plan together as
- 01:25:48soon as possible and working with others
- 01:25:52as soon as possible means in weeks.
- 01:25:56I think it depends on what the order requires
- 01:26:01as far as how much detail is
- 01:26:05in the plan.
- Clip 4 - Emily Jolly - LCRA01:26:08Thank you. Emily jolly with LCRA. So there's a lot of considerations
- 01:26:12that I wanted to bring up around these questions that are going to
- 01:26:16impact how this moves forward. One thing that we've
- 01:26:19heard a lot about today is flexibility and the commission approving
- 01:26:23a plan that maybe doesn't decide definitively in September the
- 01:26:27path forward in terms of voltage, or considers phases
- 01:26:31and leaves a lot of things to be determined in the future.
- 01:26:35I just want to point out that one risk associated with all
- 01:26:39of that uncertainty is that it's going to mean that our CCN
- 01:26:43filings either have to include more information and optionality.
- 01:26:47Right? So routing alternatives that include whether 345
- 01:26:50kb double circuit, which is going to have different cost estimates,
- 01:26:54different right of way, needs, all the information that's
- 01:26:57required in the CCN application will be different. If we need to include a 345
- 01:27:01kV circuit option versus 500 versus 765,
- 01:27:05that will take longer to prepare and there will be some uncertainty
- 01:27:09associated with those cost numbers because the
- 01:27:13time really associated with the commission implementing that
- 01:27:17just introduces a lot more delay. Right. Which means our
- 01:27:20as built costs might look very different from what we assume when
- 01:27:24we're working on the plan today. Another issue I
- 01:27:27just want to point out is if the expectation is
- 01:27:31that certain projects are going to be in service on a specific timeline
- 01:27:35and we're not able to move forward and finalizing contracts with vendors
- 01:27:39for specific facilities, and some of them will be different depending on the voltage,
- 01:27:44then that pushes our in service dates out that much more.
- 01:27:48So obviously optionality is important and it's good to
- 01:27:52understand that the benefits from it,
- 01:27:55I think, as well as the challenges that that poses at
- 01:27:58the CCN phase. But once you have the plan just in the question,
- 01:28:02how long do you think TSPs need? Well, and so that
- 01:28:06that goes to what is the commission approving? Right. So if they're saying we
- 01:28:09need to have alternatives in the CCN
- 01:28:13applications, then those applications are going to get, take longer
- 01:28:17to prepare. If there are alternatives, if they say, bill, three, four,
- 01:28:20double circuit to 45 kV, then I think we all move forward with
- 01:28:24whatever is in the plan. They're all priority. TSPs take different
- 01:28:29timelines, right, to prepare CCN applications. They won't all be filed
- 01:28:32on the same day, even if the work begins. Some of the folks identified
- 01:28:37with scope in ERCOT's study report have
- 01:28:41more and others have less experience in this part of the world and
- 01:28:45certificates projects throughout ERCOT, and they're just
- 01:28:48a disparity, right, of experience. Those of us with
- 01:28:52much more experience in that area, and I'm sitting next to Oncor, obviously,
- 01:28:55they've been doing the most, but, you know, having worked with
- 01:28:59them and having partnered with other TSPs in this area for other joint projects,
- 01:29:03we've just. You just see variability, right? And so you
- 01:29:07could tell everyone to start on day one, and we won't all come in on
- 01:29:10day 90, but I do think it's important to tell everyone to
- 01:29:13move as expeditiously as possible, and the CEQA team will work itself
- 01:29:17out just by nature of the different timelines
- 01:29:21that the TSPs will operate on.
- Clip 4 - Liz Jones VP Reg. Affairs Oncor01:29:25 Liz Jones Oncor I'd
- 01:29:28like to offer a couple of different perspectives. One is,
- 01:29:32if this question is
- 01:29:36directed at, at staff's ability to plan for
- 01:29:40and process these CCN applications,
- 01:29:43then I think that's an important input. And I would
- 01:29:46hope that staff on September 27 could
- 01:29:51say, look, we are interested in seeing not
- 01:29:54more than fill in the blank 510,
- 01:29:581520 CCNs filed
- 01:30:03right in each calendar month. So that,
- 01:30:06as a gating issue, seems really important to me, and is,
- 01:30:10of course, something that we don't have any visibility into.
- 01:30:14If you look at this on the side of the
- 01:30:18TSP's that are assigned to undertake the projects,
- 01:30:23we're all going to be looking at issues like Brownfield
- 01:30:27versus GReenfield, because Brownfield
- 01:30:30is in general, less expensive, because we're reusing existing right
- 01:30:34of way and potentially even some existing structures.
- 01:30:37On the other hand, getting an outage in the Permian on a transmission
- 01:30:41line is almost impossible.
- 01:30:45And so doing the brownfield projects first would
- 01:30:49be fast to say, ready, set,
- 01:30:53go, and then would be much slower and potentially more expensive because
- 01:30:57we wouldn't be able to take outages and we would have to build a
- 01:31:01number of temporary bypasses in order to accomplish
- 01:31:05the upgrades. So there is a
- 01:31:09balance to be had here between Brownfield and Greenfield.
- 01:31:13Some greenfield will facilitate, some brownfield
- 01:31:17also, there are going to be some. Some lines
- 01:31:21and projects that are going to be pretty straightforward in terms of
- 01:31:25who the right TSPs are. To undertake the build.
- 01:31:28There are going to be others where there are some contested issues and
- 01:31:32Oncor specifically recommended to the commission
- 01:31:37that you all establish a second phase
- 01:31:40process after that September 26 order, where with
- 01:31:44Ercot's facility facilitation or kind of, the TSPs
- 01:31:49all feed into what I'll call an Excel spreadsheet,
- 01:31:52for lack of a better picture,
- 01:31:57so that if there are more
- 01:32:01than one TSP thinks they're assigned to more than one project, to the same
- 01:32:04project, there is an opportunity for those TSPs to
- 01:32:08either work it out or to then
- 01:32:12pivot and file a request in a commission
- 01:32:15follow on proceeding for an interpretation of how
- 01:32:20370 five six e
- 01:32:26the real lawyer would apply to the facts on
- 01:32:29the ground. We don't think that those need be particularly complex
- 01:32:33processes because the facts are going to be fairly clear,
- 01:32:37cleared. It's going to be the legal inter application.
- 01:32:42And so that's a piece of housekeeping
- 01:32:45that may delay somewhat the preparation for
- 01:32:49those CCNs. I don't think it has to be a lengthy delay, but I
- 01:32:53do think it's another gating issue. And then
- 01:32:57finally, as we move forward,
- 01:33:01I have received numerous requests from customers
- 01:33:06to tell me where exactly the lines are going to be and the stations are
- 01:33:09going to be and when they're going to be in service, so they can go
- 01:33:11ahead and get signed up and get on it now.
- 01:33:14So if you ask any customer in this room what
- 01:33:18should be the sequencing, they're going to say, the projects that serve me,
- 01:33:22of course. Right. And so I think there
- 01:33:25is, again, an opportunity for ERCOT and the team
- 01:33:28TSPs to gather together and discuss
- 01:33:32sequencing. But I think if there is a
- 01:33:36project by project identification of
- 01:33:40sequencing, that we're going to be three to six months from now working
- 01:33:44all that out. So I think that's the important part
- 01:33:47of staff, tells us what their constraints
- 01:33:51are. The TSPs and ERCOT work together, to the
- 01:33:55extent possible, to sort of segment
- 01:33:59the different kinds of projects. And then I very much agree with
- 01:34:03Emily that the more optionality the commission wants
- 01:34:07in a particular CCN application, the longer
- 01:34:10it will take to prepare. The last thing I'll say,
- 01:34:14and I'm sorry to tag on, because I didn't want to crowd the room,
- 01:34:20these are customers that will pay bills now,
- 01:34:25do they pay their fair share? I mean, that's another policy discussion,
- 01:34:28just like my friend Bill Barnes Nos proposal. So,
- 01:34:32I mean, we can have that discussion, but I can assure you that even
- 01:34:36in Oncor's last rate case, the allocation of
- 01:34:40costs to the rate classes that these oil
- 01:34:43and gas customers are in the, went up significantly
- 01:34:48because their load was a greater share of
- 01:34:52Oncor's total load. And so again,
- 01:34:57want to make all the room we need for fairness,
- 01:35:00but I don't think that's today's discussion. So thank you.
- 01:35:04Thank you.
- Clip 4 - Nabaraj Pokharel - OPUC01:35:08 My name is Nabaraj Pokharel from director, market and
- 01:35:11revenue policy from Office of Public Unity Council.
- 01:35:16To the extent this question number four, should the commission approve plan
- 01:35:20at the September 26 open meeting?
- 01:35:24My quick answer for this is no,
- 01:35:29because Eckerd is planning to file the
- 01:35:32full analysis by the end of September.
- 01:35:36And I think commission needs some time
- 01:35:40and all these stakeholders need some time to read
- 01:35:43it, go through it, at least need some time to study.
- 01:35:47So approving at this time,
- 01:35:51September 26, does not
- 01:35:55fit there. Number 1. Second thing
- 01:35:59is HB5066 requires commission
- 01:36:03to direct arcade to develop the reliability
- 01:36:06plan for permission basin to address
- 01:36:09extension of transmission service.
- 01:36:12However, there is no mandate requiring
- 01:36:16the commission to approve this plan for immediate implementation.
- 01:36:20We filed a comment on 55718
- 01:36:24as well, and we mentioned this clearly that OPEC
- 01:36:28recommends Commission's deliberation and recommendation
- 01:36:32ultimately be submitted to the Texas Legislature
- 01:36:36for further consideration, particularly given the significant
- 01:36:40cost involved for residential and small commercial consumers who
- 01:36:44are not primary driver behind these investments.
- 01:36:48Thank you. Maybe yes.
- Clip 4 - Chad Burnett - VP AEP Texas01:36:52 So I just, on this particular issue,
- 01:36:55I think it really depends on what you decide initially. And the one
- 01:36:59other argument about, we've been obviously advocating the 765,
- 01:37:03and one of the reasons that we also are doing that is because it does
- 01:37:06dramatically simplify the CCN process, which could accelerate
- 01:37:10the pace at which we can get these customers actually connected.
- 01:37:15I did want to tag onto what Liz
- 01:37:19was just saying, though, in terms of, you know, we don't need to.
- 01:37:23Again, I think what you're hearing from all of us is that there's an
- 01:37:27urgent need today. Now, again, I think there is a no regrets
- 01:37:31approach that we should be looking at this. And that's where,
- 01:37:34again, from our perspective, and you've heard lots of different perspectives of,
- 01:37:38is the 345 the no regrets? Is the 765 the no regrets?
- 01:37:41Is there something there? But I think we just need to be cognizant
- 01:37:45of the pace. But more importantly, you know,
- 01:37:48these, there's a lot fewer CCNs, a lot fewer lines
- 01:37:52with the 765. I think if I heard a stat earlier that
- 01:37:55it's about half as much land that we would have to need.
- 01:37:59And when you think about going through each of those different CCNs, so when you
- 01:38:02think about sequencing, maybe there's an opportunity to combine them.
- 01:38:05But again, my initial position is it really depends
- 01:38:08on what that first decision is on how that's going to impact the CCN.
- 01:38:12But ultimately, it's our belief that the
- 01:38:15765 will be the quicker regulatory path and require fewer
- 01:38:19ccns because it will allow us to do that much quicker and it's
- 01:38:23a much smaller impact on landowners in the state.
- 01:38:26Thank you. Anybody else on question four? Can I
- Clip 4 - Emily Jolly, LCRA - Comments on question 401:38:30add something? Thank you. So we didn't comment on this,
- 01:38:34and it's something I've been thinking about and trying to figure out if this is
- 01:38:37an issue for staff. But in thinking about work loaded sequencing,
- 01:38:40and I don't have the site in front of me, but the provision bureau that
- 01:38:44requires consolidation of CCN applications that have a
- 01:38:47common endpoint, that was obviously
- 01:38:51not the case in Cres. There was an additional sentence
- 01:38:55in that provision that was stricken last session that applied to
- 01:38:58the proceedings for Cres and said, this is inapplicable.
- 01:39:02I think the policy for not requiring that is the same
- 01:39:06these import pass that we're talking about. Because in some cases, I mean,
- 01:39:09you're looking at hundreds of miles. Right. And so the idea
- 01:39:13of having consolidated proceedings for a 250 miles
- 01:39:17transmission line where the impacted community on
- 01:39:21the east end is completely different and unique from what's
- 01:39:25happening on the other end of the line, particularly if the commission determines
- 01:39:29at the outset anything related need and
- 01:39:33where the endpoints are fixed. And so, you know,
- 01:39:36I think Oncor and El CIA are the reason that this was even in the
- 01:39:39statute, right. Because once upon a time we had two CCN proceedings
- 01:39:43that were not consolidated and they had to link up.
- 01:39:46Right, but they had to link up at a place that didn't exist.
- 01:39:49And so you couldn't have one CCN that fixes a route here
- 01:39:53and the other side coming in that fixed the route down here because they weren't
- 01:39:57going to connect and that didn't serve the need. And so as
- 01:40:00a result of that proceeding, Cres notwithstanding,
- 01:40:03if you're going to sync up two separate projects, that has to be consolidated.
- 01:40:07And generally the commission has done that. I think Oncor filed comments on
- 01:40:11this issue, though I didn't memorize them,
- 01:40:14but that talks about where there might be some
- 01:40:17wiggle room. So again, if that's impacting staff's consideration
- 01:40:21for how these cases are process, I think it actually could slow things down and
- 01:40:25make things more bottlenecked and more challenging to process at the commission.
- 01:40:30If we require the entirety of those import paths to be consolidated,
- 01:40:34filed together, prosecuted at the same time that
- 01:40:38was the only other thought I had on that piece. I'm going to turn to
- 01:40:40Teresa and Mark. Do you guys have everything you need? This is
- 01:40:44ready? I think so, yeah. Okay, we can go to the next question.
- 01:40:51Number five. What methodology should
- 01:40:54be used to prioritize and sequence the individual CCN applications
- 01:40:58to fulfill the objectives of Pura section 39.167,
- 01:41:03to optimize efficient transmission buildup?
- Clip 5 - Stephen Mack - WETT01:41:08 Stephen Mack for WETT
- 01:41:11We believe it would be needed based on need.
- 01:41:14What is the most immediate need, at least initially,
- 01:41:17but after,
- 01:41:21we also think that the plan should be revisited. As far
- 01:41:25as need, load and generation, where is it showing up?
- 01:41:29And in addition to that, we would suggest
- 01:41:32that the commission also include an economic analysis
- 01:41:36in the prioritization.
- Clip 5 - Emily Jolly01:41:41 There's a couple different ways to think about this. You know, one thing we haven't
- 01:41:45really seen at this point in time, particularly as it pertains to the
- 01:41:48EHV alternatives, is the kind of relative cost
- 01:41:52benefit analysis, the load serving, load carrying
- 01:41:55capability of the various import pass at various alternatives.
- 01:42:00That information would be helpful, I think, for all of us to better
- 01:42:03understand and think about priority.
- 01:42:06In the absence of that being complete and ERCOT providing
- 01:42:10that information, I think it's evident that
- 01:42:14there is a path of least resistance here. That if the commission approves
- 01:42:17the 2038 345 kV plan, that itself
- 01:42:22is the determination of need. And that dictates,
- 01:42:26I think, to TSP to go out and prepare your applications in
- 01:42:30terms of what's planned. I think the fallout for how
- 01:42:34things get sequenced will just naturally occur, as I said before,
- 01:42:38based on the TSP's different pace of being able to
- 01:42:41prepare those applications. But the stage gating idea
- 01:42:45of not x amount, not to exceed x amount
- 01:42:49of applications on a month, but certain staggering
- 01:42:52process, I think could work. If that's the concern being addressed
- 01:42:56by this question, if I may, what do you mean by
- 01:43:00economic analysis, Stephen? So right now,
- 01:43:03it's just based on the need driven by the load.
- 01:43:07But there is, as I understand it, no sort of
- 01:43:11analysis as to the benefits that could be brought from certain
- 01:43:15projects and lowering costs. So that's something that could be
- 01:43:18added to the analysis. In terms of
- 01:43:23sequencing, do you mean congestion costs? Yes.
- Clip 5 - Liz Jones VP Reg. Affairs Oncor01:43:27 So I guess my concern is ERCOT has
- 01:43:31only recently brought forward an
- 01:43:34economic test that I think is generally
- 01:43:38consistent with what the legislature passed
- 01:43:42in 2021, but it hasn't been road tested.
- 01:43:45And I know there are folks who have some concerns about the way it
- 01:43:49is presently structured. So there is no
- 01:43:53economic test per se that is available right
- 01:43:56now. And I
- 01:44:02would argue that an economic analysis in this instance is kind of like
- 01:44:06the NOS proposal from NRG. It's interesting,
- 01:44:10but it's likely to require a significant other
- 01:44:17project to work out all the details that would be associated
- 01:44:20with it. I think it is fair to say that all of
- 01:44:24these projects are needed for reliability. They are needed to serve customers.
- 01:44:28And so the notion that we can pick one
- 01:44:32project over another because it has some
- 01:44:35particular benefit, I mean, that's certainly a conversation that TSP
- 01:44:39could have themselves to try to facilitate that.
- 01:44:42But I think asking ERCOT to undertake that analysis is
- 01:44:46a pretty heavy lift in what I think.
- 01:44:50I think it will delay the build of all transmission
- 01:44:54rather than trying to speed up what
- 01:44:58we might otherwise determine to be priority projects.
- 01:45:02And I agree with you that all the projects here are driven by.
- 01:45:06And what I was referring to was the sequencing of it,
- 01:45:09which will be done over a period of time. It's not
- 01:45:13necessarily by the date that an order is needed.
- Clip 5 - Chad Burnett - VP AEP Texas01:45:19 I just wanted to, again, echo what Liz said, because, again, I think there's
- 01:45:23tons of analysis that could be done. I mean, if you think about, we're talking
- 01:45:26about the need from the load side, but we've
- 01:45:30also, since the study was completed, learned a. About a whole lot of generation
- 01:45:33through the Texas energy fund that will be utilizing this
- 01:45:37transmission as well. So, I mean, you could always go back and restudy more
- 01:45:40and do more analysis. But at the end of the day, like,
- 01:45:44we've got customers that have been waiting for years for this build out.
- 01:45:48And, you know, I get the point of the question is, should we sequence
- 01:45:52these or prioritize these? But the need is, we need it everywhere
- 01:45:55and we need it now. You know, I just,
- 01:45:58I think we need to be cognizant of what impact,
- 01:46:02you know, if we try to slow this down or, you know,
- 01:46:06restudy things again or, you know, put these in a different order so that,
- 01:46:09you know, parts of the system are going to be at the tail of that
- 01:46:12and some get put to the front of the line. Like, I just, when you
- 01:46:15think about what are the optics of that for these different customers, I think
- 01:46:19that's, that's a different. That puts us in a difficult position as well.
- 01:46:22And so, I mean, again, I think hopefully, hopefully when we approve, we get
- 01:46:25this approval. Like, it's going to be a complete view
- 01:46:29of this and not, you know, having to say, okay, we're going to start here
- 01:46:32and then do these other ones after the fact.
- 01:46:38This is really more impact on the commission staff. Like, are we going to do
- 01:46:41100 CCN cases in four weeks. You know, we have 180 days to do
- 01:46:45them. That's really more around that. These questions.
- 01:46:50Okay. Question six. Question six.
- 01:46:54Due to the large scope of the Permian Basin reliability plan,
- 01:46:57are there any additional outreach efforts the commission should consider
- 01:47:01outside of what is required by Pura in the commission rule?
- Clip 6 - Liz Jones VP Reg. Affairs Oncor01:47:10I'll go first. Liz Jones Oncor so
- 01:47:14I think it would be very valuable for the commission to
- 01:47:19issue a press release and particularly
- 01:47:23reach out to the communities in West Texas that will
- 01:47:27feel these impacts so that the population is generally aware.
- 01:47:31I'm sorry, I can't recall the gentleman's name, but the gentleman from
- 01:47:35Diamondback said, you know, I live here and I think it
- 01:47:39is important not necessarily in a super formal way,
- 01:47:43but in as many ways as possible for all of
- 01:47:47us to inform the folks in those communities
- 01:47:51and in that region. So whether it's other customers, whether it's
- 01:47:55local government, all of those channels, I think it's incumbent on
- 01:48:00us as TSPs. But I think also the customers to
- 01:48:04encourage an awareness of this so that it, and nobody feels
- 01:48:07blindsided. In terms of formal process.
- 01:48:10Though I think that the commission's
- 01:48:14CCN preparation and public meeting requirements
- 01:48:19and the notice requirements that are associated with those steps
- 01:48:23will be sufficient in these instances because
- 01:48:27I mean, we've been building a lot of infrastructure out in the Permian over
- 01:48:31the last ten years. So some of them may duck when they see
- 01:48:35us coming, but they will not be surprised.
- Clip 6 - Emily Jolly - LCRA01:48:39Yeah, I echo that. I do think that the commission has kind
- 01:48:43of best in class public engagement rules relative to some of
- 01:48:47the other agencies that we work with. And also in particular
- 01:48:50as a governmental entity, we work extra hard
- 01:48:54to engage with all of our electives, with all the communities.
- 01:48:58That's important. That's core to our identity. And in part that's
- 01:49:01why some of our applications take a little longer to prepare
- 01:49:05because of the level of feedback that we're taking from the community
- 01:49:09and addressing our application.
- 01:49:13This question does kind of bring up a particular
- 01:49:16challenge that's unique to this area that I want to just raise for your consideration.
- 01:49:22And that is there might be a perception that
- 01:49:25routing in these areas is very simple because you
- 01:49:29don't have some of the same environmental sensitivity in the
- 01:49:32landscape, you don't have the same amount of residential
- 01:49:37and commercial development in a lot of these areas. But what
- 01:49:40you do have is a whole lot of oil and gas infrastructure.
- 01:49:44And there are obviously safety concerns associated with
- 01:49:47routing high voltage electric facilities,
- 01:49:51transmission facilities in and around oil and gas infrastructure.
- 01:49:55And in our experience, you know, we have
- 01:49:58projects currently in flight, we have other projects we built and energized in far
- 01:50:02west Texas. That is the most challenging routing constraint
- 01:50:05is the oil and gas infrastructure. And so I think we have a unique
- 01:50:09opportunity because of the amount of engagement we've had with the oil and gas community
- 01:50:12around this project. You know, we've all been
- 01:50:15in lots of meetings with Mister Cobos and with representatives from the
- 01:50:19associations that you've heard from today and a lot of the producers, a lot of
- 01:50:22the folks on the ground. If there's a particular issue
- 01:50:25that we could maybe forward in our communications
- 01:50:29is understanding, you know, the impact
- 01:50:33of routing, because the last thing that we want to be doing is filing CCNs
- 01:50:37and having a bunch of oil and gas producers intervening and opposing our routing
- 01:50:41because they don't want the transmission facilities near their above ground infrastructure or
- 01:50:45their below ground pipelines. Both pose different
- 01:50:48but important challenges. We have criteria that we utilize
- 01:50:52in routing for what we know about and what we know exists,
- 01:50:56which is a limited data set. And we all understand the drawbacks of having
- 01:51:00to rely on publicly available information. Where we've
- 01:51:03had better engagement with oil and gas producers and area, we get
- 01:51:06a lot better information and we can avoid that. We can have safe buffers,
- 01:51:11but that is something that we don't always have great information and we don't want
- 01:51:14to be in the position of trying to certificate build,
- 01:51:17construct and operate this new infrastructure with opposition
- 01:51:21from the folks because they don't want it on their property or where they
- 01:51:25have mineral interests. So that's attention that we see now.
- 01:51:28And we think that through this engagement process, through the engagement engagement of
- 01:51:32the representatives here at this meeting, we can hopefully better
- 01:51:35engage, communicate, coordinate going forward. Thank you,
- 01:51:41Stephen Mack, for what we don't have anything to add about additional outreach
- 01:51:44the commission should order or need to do, but we do maintain
- 01:51:48regular contact with community leaders and let them know what's
- 01:51:52coming. So I think from at least our perspective,
- 01:51:56what we've got going on now.
- Clip 6 - Megan Griffiths - PBPA01:52:01Sure. Megan Griffiths on behalf of PBPA and I
- 01:52:04appreciate a lot of what Emily said and so we are not advocating any
- 01:52:09change in the notice process or anything like that because I agree,
- 01:52:12I think that the TSP's in
- 01:52:16the area have worked very well with the oil and gas loads to get the
- 01:52:19plan to where it is today. And I think that those communication efforts are important
- 01:52:23and I expect that they will continue. And so we have
- 01:52:27already invited them out and the commission out to the region and they
- 01:52:30have accepted that invitation and have been there for CCN cases,
- 01:52:34it is always important upfront for the TSPs
- 01:52:38to work with the impacted pipelines oil
- 01:52:41and gas interests. And so they all do
- 01:52:45that to a certain extent. I would encourage them to continue to do so,
- 01:52:48because, Emily, point is well taken, and so.
- 01:52:51But I think that none of that is going to require
- 01:52:55change in existing rules.
- 01:52:59Yeah. Obviously, Emily and Megan have covered
- 01:53:02the issue quite well. Texaco members are committed
- 01:53:06to participating in the process to make sure that we can
- 01:53:10expedite these CCN. Anybody else?
- 01:53:13Question six.
- 01:53:26Question seven. If ERCOT publishes the endpoints
- 01:53:30of all the projects, along with which entity owns each endpoint,
- 01:53:34would that information suffice for TSP's to move forward
- 01:53:38with filing CCNs or contested cases over project ownership?
- Clip 7 - Liz Jones VP Reg. Affairs Oncor01:53:45So, Liz Jones Oncor. I think that probably gets
- 01:53:49us a significant way down the road, and it would
- 01:53:53certainly facilitate the
- 01:53:57elevation of any disputes so that it's clear that
- 01:54:01there are some disputes.
- 01:54:04I think there's a nuance here that is missing,
- 01:54:08and I think the nuance just has to be grappled with
- 01:54:12as a part of the ERCOT plan. There are endpoints,
- 01:54:17there are new endpoints that no one presently owns,
- 01:54:21and there is, I think, some disagreement
- 01:54:25among the lodzaring entities about
- 01:54:29how that new endpoint point changes
- 01:54:33or does not change the distribution of the
- 01:54:36projects. So I say this not because it's
- 01:54:41going to be a stop the presses kind of exercise, but because
- 01:54:45I want you all to understand that as we move forward into that next
- 01:54:49phase and try to resolve contested issues,
- 01:54:53that's the wrinkle that isn't necessarily as straightforward,
- 01:54:57or one of the wrinkles that's not as straightforward.
- Clip 7 - Emily Jolly - LCRA01:55:01Thanks. Yeah, I think the concern we would have is just
- 01:55:04the duplication of effort. If it's not known what is contested
- 01:55:08and you have different TSPs putting together CCN applications
- 01:55:12for the same scope, that would be a huge waste of resources,
- 01:55:15especially for the commission. And so the earlier those conflicts
- 01:55:19can be identified and resolved. And probably.
- 01:55:23I crossed my fingers, maybe I'm the Pollyanna now on this panel without
- 01:55:28the need for intervention by the commission. But, yeah,
- 01:55:32I'm working with ERCOT and I know that they were under a tremendous
- 01:55:36time crunch and couldn't necessarily provide everyone the information about
- 01:55:40which projects could fall under this umbrella of being contested in
- 01:55:44order to get everything in front of the commission on the timeline that was required.
- 01:55:48But hopefully, we can do more now in the coming days and weeks to help
- 01:55:52resolve that. And I would encourage you to leave
- 01:55:56space in the process for the
- 01:56:00TSPs to both confer and resolve,
- 01:56:04or confer and contest as circumstances may need.
- 01:56:08But once we have that data set, we can proceed.
- 01:56:15Anybody else on questions? Therese, Mark, you guys?
- 01:56:20All right,
- 01:56:24question eight. Are there any protocol
- 01:56:27changes ERCOT should consider to better facilitate
- 01:56:31this plan's build out?
- Clip 8 - Liz Jones VP Reg. Affairs Oncor01:56:39 Liz Jones, on behalf of Oncor,
- 01:56:43I think there are certainly ways that the regional planning
- 01:56:46group could function differently
- 01:56:50for high growth areas. But I think,
- 01:56:54much like some of the other issues we've heard
- 01:56:58about today, that's out
- 01:57:01of scope, I think, for this proceeding, because I think
- 01:57:05it's more complex. I do, however, hope that
- 01:57:09the commission's order in this proceeding will
- 01:57:12consistent with its first order. Note that additional
- 01:57:16RPG review of these projects is not needed,
- 01:57:20that ERCOT has undertaken the review,
- 01:57:24and it now falls in the commission's purview through
- 01:57:28this order and the subsequent CCNs. I know
- 01:57:31there is some debate about that, but I
- 01:57:35think it's important to recognize that the RPG
- 01:57:39process is, at its core, advisory.
- 01:57:42ERCOT is ultimately the owner of the
- 01:57:46plan, whether it is the permian plan or the
- 01:57:49RTP or another independent review.
- 01:57:53And so, with the clarity that additional review
- 01:57:57is not needed for these projects, I think we'd be better
- 01:58:01off trying to work through protocol improvements on a
- 01:58:04separate track. Thank you.
- Clip 8 - Kamran Ali - VP AEP Texas01:58:09Absolutely. Second, what Liz said there, I think those
- 01:58:13improvements are definitely needed. In addition to that, I know there has been a lot
- 01:58:16of conversation around whether this load is real or not real,
- 01:58:20and what instruments we need to rely on to demonstrate that
- 01:58:24this load is real. I know our court is working on revisions
- 01:58:28to the planning guideline, revision request to 115,
- 01:58:31and we do encourage that to work on it and have some
- 01:58:36elements identified that if the TSP's can demonstrate those, then those loads
- 01:58:40are considered for analysis. Because I think what
- 01:58:43we all agree with today is we are a little behind, maybe more
- 01:58:47than a little behind. And the reason for that is because the forecast we
- 01:58:50had, they were not acknowledged appropriately.
- 01:58:53Because a lot of times the customers are waiting for certainty
- 01:58:57on infrastructure before they're going to go make investments in real estate or
- 01:59:01other commodities, whereas we are waiting on
- 01:59:05certainty on the plan and what it's going to take. So,
- 01:59:08I think it's the challenge that we have been dealing with, but we
- 01:59:11really appreciate our course leadership this time around in recognizing the
- 01:59:15load that we have signed, but also load we will be signing in a short
- 01:59:19order and including that in RTP. We just want to make
- 01:59:22sure there is some permanence to that in the future.
- Clip 8 - Meghan Griffiths - PBPA01:59:26 I'm just going to Megan Griffiths on behalf of PvPA. I'm just going to me
- 01:59:30to what Liz said. We don't think there need to be any protocol changes.
- 01:59:33We don't think that the plan needs to go back to RPG. I believe
- 01:59:37we should get an order and get off to the races. Stephen,
- 01:59:41do you have anything, anybody else on
- 01:59:45question eight? Corey.
- 01:59:53Kind of a repeat from an earlier statement. Corey was South Texas Electric cooperative,
- 01:59:57so a lot of the loads right now,
- 02:00:01it's very clear how RPG handles a submittal
- 02:00:05for a transmission improvement to be made to a load.
- 02:00:10And obviously, I think it was mentioned earlier working
- 02:00:14on an NPRR for 75
- 02:00:18above loads, large load study process
- 02:00:21and 25 mw or whatever behind the EPS meter.
- 02:00:27But I believe the commission is going to need to.
- 02:00:30Orlando should have RPG be
- 02:00:35involved in the process of
- 02:00:39making sure this load is real. Okay.
- 02:00:42Right now they do very effectively. You get
- 02:00:46bring a letter of credit or they're not going to give you an endorsement.
- 02:00:49Okay. So I know we're, we're moving away from that. It's mentioned
- 02:00:53in the legislation, but it's mentioned specifically for mineral.
- 02:00:57So I would urge the commission to have the RPG
- 02:01:01have a process of somehow determining.
- 02:01:05I haven't figured out how to do it yet. Somehow determining that
- 02:01:09you don't have duplicative loads going to more than one TSP
- 02:01:13and adding up to half of that 26,000
- 02:01:18mw that's being forecast. I think there's
- 02:01:21some of that going on. I think that we need to look into it.
- 02:01:26ERCOT, do you want to address any of these?
- 02:01:29Okay, but you don't need any protocol change or nothing,
- 02:01:32right? Okay, thank you.
- 02:01:36We are. Last question. We are very good at timing.
- 02:01:41Number nine, is there anything else the commission should consider?
- 02:01:45Already not addressed. That's really your time.
- 02:01:49Speak your mind. Whatever you want to say.
- Clip 9 - Cyrus Reed - Sierra Club02:01:55 Cyrus Reed Lone Star Chapter of the Sierra club wanted to agree with some comments.
- 02:01:59It might have been from TIEC, that while it's not
- 02:02:02required to go to RPG, having some updates
- 02:02:07and even potentially workshops on those updates,
- 02:02:10I think would be important going forward. Whatever the order you do in September,
- 02:02:15whether it's phased in or not phased in, I think it's going to be important
- 02:02:18to have space for updates and conversations going forward.
- 02:02:21So just wanted to make that comment.
- 02:02:25I just want to thank the commission for holding this workshop and in
- 02:02:29advance for all the hard work that is in front of you in coming
- 02:02:32up with the right solution to ensure energy adequacy for the
- 02:02:36state of Texas. I think one thing that we all heard today very
- 02:02:40clearly from every single stakeholder is that the demand we
- 02:02:44are facing is real. And actually it's already there and
- 02:02:48we are late to that. And our
- 02:02:51recommendation from AEP Texas, and AEP in
- 02:02:54particular, is to proceed with the 765
- 02:02:58kb plan that is proposed by ERCOT. Because there is still
- 02:03:02a lot more uncertainty around load. We believe
- 02:03:05there is maybe more load showing up even
- 02:03:09in the permian areas. You heard some of the experts saying that it may have
- 02:03:12been under forecasted, because the data is a little bit, may be
- 02:03:16dated. Similarly, on the other,
- 02:03:20in the other areas, in Texas, we are seeing significant growth as well.
- 02:03:24So when you take that into consideration, one thing that we would need is a
- 02:03:27lot of flexibility on the grid to be able to deal with any changes
- 02:03:31or challenges that may come along, things that we may not have considered. And the
- 02:03:35765 kV plan as stated by our court demonstrates that. And I
- 02:03:38think we don't want to miss the opportunity to be able to build off
- 02:03:42of that as performs the analysis, the RTP
- 02:03:45analysis, to figure out what we do to serve the remaining 40,000
- 02:03:49megawatt. I think that plan will work really
- 02:03:53nicely with this 765 kV segments
- 02:03:57that Arecott has identified to provide the overlay,
- 02:04:01the backbone that we need to ensure energy adequacy
- 02:04:04and sustainability in the future. I do understand that
- 02:04:08maybe not all the information that you need to get comfortable with 765
- 02:04:12kV is out there, because maybe 765 kV
- 02:04:16is not something everybody is familiar with. And especially instead of Texas, I understand
- 02:04:20it will be first for many transmission service providers. And for
- 02:04:24that I think it will be very beneficial for us to have a workshop in
- 02:04:28a very short order where we can have the experts who have done this.
- 02:04:32You know, AEP is not the only company in the world
- 02:04:35who builds 765 kV. Russia has it,
- 02:04:39India has it, Venezuela has it, Brazil has it, South Korea
- 02:04:42has it, South Africa has it. There are a lot of countries
- 02:04:46who have developed this in sixties. As a matter
- 02:04:49of fact, some of these countries are now at 1100 kV.
- 02:04:52So I know we're a little behind when it comes to technology adoption.
- 02:04:56And I believe this is the right time. Our company believes this is the right
- 02:04:58time, so let's take the time. If it means a couple
- 02:05:02of months, that's not going to derail at the end of the day for
- 02:05:05us, the overall plan. So let's do the right thing for the state of
- 02:05:09Texas. Thank you, Stephen.
- 02:05:12No further comments, but just thank you all.
- Clip 9 - Eric Goff -TEBA02:05:18 Eric Goff, Texas Buyers alliance. Again, I just want to reemphasize
- 02:05:22that the physical access to transmission
- 02:05:25system is the single biggest constraint on load growth.
- 02:05:29And many of our members are planning on investments in and
- 02:05:33outside the Permian. And it really feels like
- 02:05:38we might potentially set ourselves up for
- 02:05:41a problem of having spent too much on one plan and having to
- 02:05:45pivot. And so we really encourage you to try to consider
- 02:05:48the trade offs on the 765 kV system in order
- 02:05:52to plan for the future and be cost conscious.
- 02:06:00Bob Whitmire? Bob Whitmire?
- Clip 9 - Bob Whitmire - Longhorn Power02:06:04 Hi, Bob Whitmire, Longhorn Power independent consultant.
- 02:06:08I'm the most conflicted guy in the room. I'm vice chair of the large flexible
- 02:06:12load task force. What I can tell you from personal
- 02:06:16perspective is, as you've heard, the oil
- 02:06:19and gas load is there.
- 02:06:23What I have seen in my practice is if there's any
- 02:06:26place on the system that can take a couple of hundred megawatts of load,
- 02:06:31the load will go there. It's different than we
- 02:06:34used to have. These things can come in very, very quickly.
- 02:06:39As far as the 768, we've been either 765,
- 02:06:43we've been punting that down the road for a good ten years or more.
- 02:06:46That I remember. Those that think we need to wait longer.
- 02:06:50I don't know, we've waited quite a while. It might be
- 02:06:53time to start thinking about upgrading the system. Thank you.
- 02:06:58Right. So I think we've heard a lot of different ideas and perspectives
- 02:07:02today, but I think the one thing that we can all agree on is because
- 02:07:06of the great economy that we have, because of the resources in the state,
- 02:07:10we've got incredible load growth. And I think the other
- 02:07:13thing that we can probably agree upon is we can't keep planning the system the
- 02:07:16way that we used to plan the system. We're no longer seeing that,
- 02:07:20you know, 2% load growth each year. I think, you know, Warren said
- 02:07:25we could blame him for the reason that we're here today,
- 02:07:30but because we have continued planning the system
- 02:07:34the way we always did, and then the load growth
- 02:07:37caught up with us and it's now exceeded us. We now
- 02:07:41have consumers sitting in the room today, also across
- 02:07:45the state, that want to do business in Texas but can't get
- 02:07:48power. I would also say there's another aspect
- 02:07:52that I think is very important. These same TSPs that are sitting in
- 02:07:56the room room that want to build new lines are having problems
- 02:08:00getting outages that they need on the system.
- 02:08:03Because we've maxed the transmission capacity on the system
- 02:08:06for the state. And I know it's a struggle for them,
- 02:08:09but we also have to maintain the reliability of the system. So we also
- 02:08:12have to think about how do we shorten those outages,
- 02:08:16windows, the times that they're going to have current lines out of service
- 02:08:20and how we can get those back. I recognize that's going to be a cost,
- 02:08:23but that's why we're offering you a better solution.
- 02:08:27We believe on how do we get out
- 02:08:30of this jam that we're in as a state and continue
- 02:08:34to provide affordability and reliability and
- 02:08:38the best service for our consumers.
- 02:08:42We recognize that if we don't start building today, they're not
- 02:08:46going to get the power they need. And I think we've already done a lot
- 02:08:49of work, especially in the permian region. We were just looking
- 02:08:52back and since 2014,
- 02:08:55$5.7 billion worth of projects have been
- 02:08:58endorsed in just the permian region alone.
- 02:09:03But we recognize we've got to do more. And so what
- 02:09:06I'd like to leave the group with is bill
- 02:09:10was quoting song lines. I'm going to quote a movie line.
- 02:09:14We've all got to work together. So help me to help you allow
- 02:09:20us that extra couple of months to make sure we've got
- 02:09:24a holistic plan that will not only serve the permian
- 02:09:27short term, but it'll serve them long term as well as the rest of the
- 02:09:31consumers of the state. I think I've
- 02:09:35heard, and I don't think I've heard. I know
- 02:09:38I've heard, and I recognize the need for certainty. And I
- 02:09:41think from what I've been hearing from different commissioners
- 02:09:46as well as different folks that I talked to on the outside, people are
- 02:09:50recognizing the need to make a change. And so as you
- 02:09:54think through what you're going to recommend, how can we
- 02:09:57help provide the consumers the certainty that we're not going to drag
- 02:10:01out this process for many, many months? Because as I said,
- 02:10:05if we're going to build and serve the needs, we've got to start doing
- 02:10:08it now. I think another key
- 02:10:12component of that, some of the concerns about going to a higher voltage,
- 02:10:17I think Cameron had a good suggestion and we will work with commission
- 02:10:20staff to try and host a workshop in the near future
- 02:10:24where we can get some of the vendors to come in and provide some
- 02:10:27additional information.
- 02:10:32We want to give you the certainty. We think this plan that
- 02:10:36we, we'll be providing for the whole state will
- 02:10:40give you more certainty in the availability of generation no
- 02:10:43matter where it sites. We know we've got megawatts coming with tef. We know
- 02:10:47there's other megawatts that are in the queue. This will
- 02:10:51make sure that we can get that power to the region.
- 02:10:54It'll give us more certainty in that
- 02:10:57the capacity will actually be there, meaning the transmission capacity,
- 02:11:02when the oil and gas consumers are ready to hook up.
- 02:11:06So, to Bob's point, those other loads that are able to locate
- 02:11:10and connect very quickly, they will not consume all the
- 02:11:13capacity before the oil and gas folks are able to get their capacity.
- 02:11:19So, again, my message is, how can we continue to work together?
- 02:11:22Help me to help you give us a little bit of extra
- 02:11:26time, and I think we'll all have a better solution for the long term.
- 02:11:29Thank you, Kristina. Anybody else?
- 02:11:32You had me up. Hello.
- 02:11:35Okay, then Therese will be. Do the closing remarks. There's one more.
- Clip 9 - Shana Joyce - TXOGA02:11:39Oh, okay. Sorry. This is Shana Joyce for
- 02:11:42TXOGA. While I appreciate ERCOT and everything that they've done
- 02:11:46to get this plan in place and for us to have options,
- 02:11:49and I feel like, as consumers, we're trying to look at all the options so
- 02:11:52that we can have a plan moving forward. Forward.
- 02:11:56We needed this ten years ago, so more time is really not
- 02:11:59an option for us. And we're really looking forward to hopefully having a final
- 02:12:03order at the end of September. So I felt like that is an important thing
- 02:12:07to say. I feel we've said that throughout our comments and everything, but I just
- 02:12:10kind of wanted to reiterate that as we close this workshop. Thank you.
- 02:12:14Anyone else? Mariah? Nothing?
- 02:12:18Okay. Well, so I'll just sort of recap a
- 02:12:21little bit and then go on to next steps. I mean,
- 02:12:25from everything that I've seen, significant progress has
- 02:12:29been made since the commission directed ERCOT to develop a
- 02:12:32reliability plan. And they have worked tirelessly with the
- 02:12:36TSP's, with the oil and gas, with the large,
- 02:12:38flexible load stakeholders to come up with a plan
- 02:12:43to meet those needs. So we've had
- Clip 10 - Next Steps02:12:46the workshop, we've had questions. So, next step,
- 02:12:50staff will file a recommendation for consideration
- 02:12:54and guidance from the commission, and we
- 02:12:57hope to do that in a period of two open meetings.
- 02:13:01We feel like the commission will want to consider and ask questions.
- 02:13:05We may have to take things back and then come back at a future
- 02:13:09open meeting. Right now, we're planning
- 02:13:13for September open meetings, so that's where the plan is right now.
- 02:13:17Thank you. That's the next step. Any questions?
- Clip 11 - Adjourn02:13:21 Thank you so much for coming. This meeting is adjourned.