Meeting Summary – 08/22/24 Permian Basin Reliability Plan Workshop

0.1 – Opening Statements – Commissioner Cobos

• Permian Basin is a priority area for the commission due to its critical importance and growing electricity demand.
• ERCOT forecasts more than 150 gigawatts total load by 2030, with 26 gigawatts from the Permian Basin region.
• Texas Legislature passed 88R-HB5066 to address electricity needs of the Permian Basin region.
• Commission directed ERCOT to develop a Permian Basin reliability plan, with ERCOT’s final plan submitted in July and commission approval expected in September.
• Encouragement for feedback on infrastructure buildout through 2038, consideration of EHV transmission lines, and cost impacts.

1 – What is the best approach to approve a plan that gives the Commission flexibility to consider and benefit from ERCOT’ s EHV study that will be completed by the end of 2024?

Michael McMillin – TIEC

• TIEC supports the Commission approving a full plan through 2038.
• The plan should use 345 kV infrastructure.
• TIEC prioritizes timely action to move forward with CCN applications.
• Highlighted the importance of starting construction as soon as possible.

Meghan Griffiths – PBPA

• PBPA is one of the largest regional oil and gas associations in the U.S.
• The current plan is critical for PBPA members facing load issues in the region.
• The region is about a decade behind in infrastructure.
• PBPA supports the plan for the full 2038 load and endorses the 345 plan as it seems fully developed. Requests that the Commission approve a full plan in their order this fall.
• PBPA members present include Endeavor Energy, ConocoPhillips, Coterra Energy, Diamondback Energy, and Targa.
• PBPA has been collaborating with ERCOT and appreciates their efforts.
• Griffiths emphasizes the importance of a full and complete plan for serving the load.

Kamran Ali – AEP Texas

• Kamran Ali, VP of Transmission Planning for AEP Texas.
• Discussed a projected load increase of 24,000 megawatts in the Permian Basin and an expected  total increase of 60,000 megawatts across Texas.
• Highlighted the need for significant high voltage transmission at 765 kV to manage uncertainties around generation locations.
• Believes that a 765 kV system will be the solution to their lack of a regional backbone overlay interstate system to allow power transmission between different regions.
• Emphasized AEP’s experience with operating roughly 2200 miles of 765 kV lines in the PGM region.
• Recommended holding a workshop with manufacturers, vendors, and construction companies to discuss the feasibility of the 765 kV plan by 2030.
• Emphasized the benefit of seeing results from the RTP analysis expected to be published by the end of the year.
• Concluded by stating that this long-term planning would be more beneficial for ratepayers compared to temporary solutions.

Stephen Mack – WETT

• WETT is open to phasing in extra high voltage projects so they can be studied as part of the ERCOT larger plan. Emphasized the importance of extra high voltage to WETT.
• WETT agrees with consumer groups to initially approve a 345 kV plan that can be upgraded later.

Liz Jones – Oncor

• Oncor has filed comments in both the extra high voltage inquiry and the current project.
• Oncor has been heavily involved in developing ERCOT’s load forecast for the Permian Basin reliability plan.
• There is concern that bifurcating the plan as suggested by ERCOT will create bottlenecks, impacting the ability to serve customers.
• Primary recommendation is to proceed with the 345 plan.
• Secondary recommendation is to designate certain 345 paths as 765 paths and to direct utilities to begin preparation of a CCN addressing both 345 and EHV alternatives.
• Certainty needed for customers and maintained optionality for infrastructure options.
• Consideration to build at 765 and operate at 345, introducing complexity.
• Hope that between Commission’s Permian Basin order and key CCN decisions, voltage upgrade determinations will be made.
• Advocate for oil and gas customers who supported HB5066.

Kristi Hobbs – ERCOT

• Recognized the consumers’ need for power certainty both regionally and state-wide.
• Acknowledged concerns regarding rapid load growth in the region.
• Proposed moving forward with the “no regrets” option labeled as the local imports, costing approximately $4 billion.
• Proposal also includes providing certainty around by the end of the year or early January, looking at the full plan in order to:
  • Determine best options for power transmission through high voltage lines while addressing extra transfer capacity for Permian Basin consumers
  • Address uncertainty about where generation may be sited

Liz Jones – About question 1

• The Permian Basin currently has load needs that must be addressed without delays.
• It is essential to move forward with a complete plan to comply with HB 5066 directives.
• Approval of a comprehensive 345 kV solution for 2038 is necessary.
• The load estimates between 2030 and 2038 show a minimal difference, indicating the need for immediate planning.
• By 2030, 90% of the 2038 load is expected; by 2032, it is estimated to be 95%.
• The plan must be in place by 2030, covering both generation import paths and local projects.
• A clarification was added for the public record that the state’s plan, expected by year-end, is focused on serving 2030 load growth.

Emily Jolly – LCRA

• Raised concerns about the lack of information on some EHV alternatives and their impact on the 345 kV system.
• Recommended proceeding with 345 kV system for now due to commission’s time constraints but supports future integration of EHV solutions.
• Emphasized that approving a 345 kV plan now doesn’t prevent adding or substituting with EHV elements later.
• Highlighted that additional analysis on how much investment 60 gigawatt of load will drive is needed.
• Discussed the necessity of completing dynamic and stability analysis for both 345 kV and 765 kV systems.
• Noted historical requirement of fast devices for the 345 kV network, compared to reactors needed for 765 kV due to higher voltages.

Cyrus Reed – Sierra Club

• Identified three types of costs: local congestion, 2030 import, and 2038 costs.
• Suggested that some proceedings could be separated, e.g., move forward with 2030 and not 2038 costs.
• Expressed concerns about whether projected demand will materialize.
• Specifically noted support for electrifying the oil and gas industry due to environmental benefits.
• Questioned the transparency and realism of future demands from entities like Oncor regarding hydrogen, crypto mining, and data centers.
• Advocated for taking more time to ensure demand before major investments.
• Mentioned possible Legislative actions and protocols within ERCOT that could influence future proceedings.

Brett Desayo – Coterra

• Brett Desayo addressed the issue about whether the load will be there in 2032, affirming that the majority of the load is expected and projects are planned accordingly.
• Mentioned that several hundred megawatts of load have been pending for multiple years and are currently needed.

2 – Would there be any permanent, negative impacts to any stakeholder if the Commission were to approve a phased approach where a complete 2030 plan would be approved in September of 2024 , and a future plan for 2038 would be approved at a no later than date explicitly specified in the Final Order when Commission approves the 2030 phase of the plan?

Bryson Dillon – ConocoPhillips

• ConocoPhillips aims to meet energy demand sustainably and contribute to the energy transition.
• Focus on electrification to reduce GHG emissions and improve efficiency.
• Collaborated with other operators to commission a load study with S&P Global.
• Study identified a significant “grid connect gap” for load access to the grid.
• Current infrastructure lagging, leading to reliance on costly on-site generation with higher emissions.
• Emphasized the need for necessary infrastructure projects to meet Permian demand.
• Encouraged approval of the plan according to the original timeline of HB5066.
• Hopes the plan enables transmission service providers to start necessary projects.

Michael McMillin – TIEC

• Michael McMillin expressed concerns that a phased approach would not provide the certainty intended by HB 5066 to consumers in the Permian Basin.
• Emphasized the need to include import paths to the Permian Basin in the current plan to avoid delays due to potential contentious policy decisions on EHV.
• Believes import paths will be needed before 2038 and delays would force customers to wait longer to interconnect, affecting electrification in historically underserved areas.
• Stressed that facilities take 4-6 years to complete, meaning approval today results in operational status by 2029-2031.
• Noted significant load growth expected between now and 2031, which requires immediate action to meet demand.
• Cited the S&P study showing high load production from renewable assets, which may not meet the demand for high load factor activities such as oil and gas in the Permian Basin.
• Stressed the need for a way to get power from the rest of the grid into the Permian Basin, as renewables may not always be reliable.
• Discussed that assumptions in the S&P study might underestimate load growth as they assume load constraints due to transmission availability.
• Advocated for the commission to approve a complete 345 plan now and retain the option to add or substitute EHV later after thorough evaluation.

Meghan Griffiths – PBPA

• Discussed the risks of a phased approach, particularly the negative cost impacts.
• Emphasized the necessity of generation import path lines to bring energy into the basin.
• Warned that only approving local projects or a partial plan would prevent new loads from getting adequate energy.
• Urged the Commission to approve a plan that facilitates load growth, spreading costs over new load growth.
• Recommended approving the full 345 kV plan, which allows for flexibility to adjust later if needed.
• Highlighted that a phased plan could lead to significant delays or issues with generation import paths.
• Argued that the full 2038 345 kV plan is the “no regret solution”.
• Pointed out that demand forecasts from a 2021 study were conservative and didn’t account for accelerated ESG goals.
• Noted that higher electrification demand would have been predicted if ESG goals were considered at the time.

Kamran Ali – AEP Texas

• There is a limit to the 345 kV import/export paths, necessitating 765 kV for higher transfer capability.
• 765 kV paths can handle more power, making them essential for uncertain load demands.
• Misconceptions exist about the time required to develop 765 kV compared to 345 kV.
• Recommendation for a workshop with vendors and contractors to discuss building 765 kV transmission.
• Claims that 765 kV can be built in the same time as 345 kV with less land impact and superior stability performance.
• Need for a flexible transmission system to accommodate generation regardless of its location.
• Clarification that import assumptions for 2030 are included in the analysis.

Stephen Mack – WETT

• WETT supports the positions of ConocoPhillips, TIEC, and other oil and gas producers.
• WETT aims to connect oil and gas producers to local transmission and necessary imports.
• EHV can be addressed more thoroughly during ERCOT’s broader study.
• Stakeholders with experience in extra high voltage projects, including WETT, want to collaborate on an ERCOT wide solution.

Eric Goff – TEBA

• Supports AEP’s view that extra high voltage can be achieved on the same timeline with additional opportunities.
• Requests the need for more load interconnections, citing physical infrastructure constraints.
• Suggests further questioning about incremental costs and benefits of extra high voltage.
• Concerns about potential lost opportunities if extra high voltage is not pursued.
• Urges focus on extra high voltage feasibility in the current timeline and its benefits.
• Mentions the need to consider stability analysis for 345 kb to assess any risks.
• Proposes a two-week period to conduct these additional analyses without delaying the project schedule.

Scott Seamster – TNMP Texas

• Expressed a primary concern about delays in receiving the import pass.
• Noted that existing customers are operating at lower loads due to lack of capacity.
• Mentioned that customers have already built their plants and facilities.
• Highlighted that any delay results in permanent harm and lost time for customers.

Ryan Murphy – Diamondback Energy

• Ryan Murphy from Diamondback Energy mentioned his ten-year residence in the Permian Basin and representing both Diamondback and the community.
• Murphy discussed the ESG projects and industry evolution in terms of artificial lift, drilling, and completions.
• He highlighted that the S&P study data, although only two years old, is now conservative.
• He raised concerns over direct line generation’s reliability, especially during extreme weather events.
• Murphy supported a single-phased approach of 345 kV to reduce the risk of project delays.

Harley Henninger – Endeavor Energy

• The current load demand is significant and there are many potential uses for grid electricity.
• Local generation is a necessity due to reliability, reduced emissions, and cost-effectiveness.
• Endeavor Energy has built out a robust internal distribution infrastructure but is facing transmission limitations.
• The need for grid power to support electric drilling, fracking, and compression is emphasized.
• Reducing vehicular traffic related to energy production can improve safety and reduce emissions.
• Henninger calls for a rapid implementation of a plan to address these needs.

Caleb Troxclair – TAEP

• Caleb Troxclair represents the Texas Alliance of Energy Producers (TAEP) with nearly 3000 members.
• TAEP supports the comments of PBPA, TIEC, Oncor, and others.
• Advocates for adopting the whole plan now without bifurcation.
• Supports the 345 kV plan for its expedient transmission initiation.
• Stresses the importance of pursuing options beneficial to the whole state.
• Notes that HB5066 and the subsequent commission order focus on addressing the deficit in the Permian Basin.
• Emphasizes the urgency of addressing the needs in the Permian Basin immediately.

Cory Allen – South Texas Electric Cooperative (STEC)

• STEC supports the plan but emphasizes that the investment should be prudent.
• Concerns about permanent negative impacts and approval timing should be addressed after gathering all necessary information.
• The investment currently stands at $13 billion, with potential to increase significantly.
• Ratepayers should not bear unnecessary financial burdens; investments should be economically justifiable.
• Support for higher voltage levels (765 kV) where appropriate, but the decision should be based on economic factors.
• The Commission should ensure no duplication of load requests to avoid over-investment.
• Proposal to find alternative ways to fund investments to prevent over-burdening residential and small business ratepayers.

Warren Lasher – TXOGA

• Warren Lasher represents TXOGA, highlighting the importance of understanding costs.
• TXOGA members are significant electricity users and are aware of the associated costs.
• The plan will lead to an increase in customer demand on the grid.
• Oil and gas companies will bear a fair share of transmission costs for upcoming improvements.
• There is a current demand for electrification with companies ready to move to the grid.
• The forecasted increase in demand is expected to manifest by 2032.
• Decision points are infrequent but significant, with a long planning process leading to the present meeting.
• Previous legislative sessions and the signing of HB5066 in June 2023 were crucial to reaching this point.
• Acknowledgment of past issues with insufficient transmission but a commitment to resolving them going forward.
• TXOGA supports the 345 kV transmission plan for its comprehensiveness and alignment with legislative efforts.

Chad Burnett – AEP Texas

• AEP Texas average growth was 50 MW/year from 2011-2021; increased to 550 MW in 2022 and similar in 2023.
• Expressed concern about outdated load forecasts guiding ERCOT’s planning.
• Mentioned significant increases in data centers, crypto miners, and other industries wanting rapid connection.
• Submitted 22 GW of new loads to ERCOT, with a notable portion already paid or lined up to pay.
• ERCOT studies pending completion are delaying many connections.
• Highlighted additional 20 GW of potential load not yet submitted to ERCOT.

Prabhu Gnanam – ERCOT

• Impacts of approving a 2030 plan with import lines: There are two import paths identified for 2030 at 345 kV.
• Impact of proceeding with the next phase later: ERCOT is currently working on the 2024 regional transmission plan, considering several alternatives including 345 kV, EHV options, 500 kV, and 765 kV.
• Potential delay or change in future transmission needs in the Permian region with EHV  if parts of the projects are approved could lead to mixed options combination. This could delay the overall review and increase costs.
• Mixed options might increase costs compared to moving forward with a 765 kV holistic plan.

3 – Is the Network Open Season (NOS) concept proposed by NRG1 and used in the natural gas industry a viable option to consider for transmission buildout in ERCOT for new large loads?  

Bill Barnes – NRG

• Emphasized the importance of transmission expansion for load growth and the need for policies that address future load growth, especially in the Permian Basin.
• Identified significant load growth in the Permian Basin, with projections almost equivalent to major metropolitan areas, and noted additional growth in other regions.
• Raised issues about lack of transparency and proper sizing in transmission development, especially for non-oil and gas load growth.
• Proposed a network open season concept to help verify investment needs, drawing parallels to the CREZ process.
• Stressed that this proposal does not intend to delay transmission needs for oil and gas customers in West Texas.
• Suggested that the proposed concept would need detailed discussions, stakeholder input, possibly separate projects, and statutory changes.
• Highlighted the need to revisit cost allocation methodologies to avoid negative financial impacts on consumers.
• Called for studying the impact on consumer classes and having discussions on cost allocation.

 Meghan Griffiths – PBPA

• Acknowledged Bill’s point on network open season concept requiring changes in protocols, rules, and possibly statutes.
• Emphasized the importance of HB5066 which mandates specific provisions for the Permian Basin under 39.167(b), focusing on extending transmission service, increasing capacity for forecasted load, and reducing interconnection timelines.
• Stated that current issues with transmission in the Permian Basin are more immediate and should not be mixed with new concepts.
• Confirmed no strong position or detailed knowledge on network open seasons and their impact on existing PUC rules and regulations.

Warren Lasher – TXOGA

• Warren Lasher agrees with Meghan’s Griffiths stance.
• Idea discussed may be considered for future but is not presently timely.
• Not used in the gas industry, especially for pipelines.
• Open seasons are utilized in the gas industry.
• Natural gas delivery system significantly differs from electric transmission.
• The idea of porting the concept over to the electric industry in ERCOT requires a lengthy conversation.

Kristina Rollins – NRG

• Kristina Rollins, NRG, provided legal insights.
• Discussed three important sections of the statute: 35.056 C1, 39.166, and 39.167.
• 35.056 C1 adds language to the CCN statute, focusing on the concept of ‘need.’
• 39.167 addresses the Permian Basin plan.
• 39.166 concerns high load growth areas.
• Examined how these sections impact the assessment of need for the commission.
• Considered whether the Permian Basin’s oil and gas needs could streamline the CCN process.
• Discussed network open season concept for speculative load assessments.
• Explored how these ideas fit into criteria for a CCN.

Michael McMillin – TIEC

• McMillin notes this forum is not suitable for injecting the discussed concept.
• Changes would be required in statutes, rules, and protocols, which necessitate a longer discussion.
• McMillin advises not to delay Permian Basin projects and plans for implementation.
• Any further exploration should be conducted as a separate project and through separate rulemaking.
• McMillin acknowledges understanding Mr. Barnes’s intent to gather data..

Ned Bonskowski- Vistra

• Costs are comparable to those for investing in a dispatchable generation plant.
• Highlighted NRG’s proposal as a potential way to address concerns without delaying the process.
• Suggested the proposal could inject additional evidence of need and pressure test load forecast assumptions.
• Stressed the importance of discussing implementation if it cannot be done quickly.

Cory Allen – STEC

• Cory Allen of South Texas Electric Coop (STEC) believes the concept is potentially viable and suggests that the commission should advance it further.
• Warren mentioned that industrial customers are paying their share of transmission, but some can reduce their load during peak times and avoid significant transmission charges.
• Urges the Commission to ensure that the large build-outs to loads, capable of avoiding these costs, have a method for paying for the service.

Eric Goff – TEBA

• Most points already addressed by previous speakers.
• Emphasized caution in cost allocation disputes to avoid delays in projects.
• Confirmed agreement that this is a separate proceeding.
• Highlighted the longstanding need for service in the oil and gas industry.
• Noted significant change or facts could prompt new discussions.

Liz Jones – Oncor

• Liz Jones from Oncor emphasized the absence of a reservation capacity system in ERCOT unless Bill’s proposal is adopted.
• Stressed the importance of considering all types of loads, not just oil and gas, in the HB5066 analysis.
• Highlighted the problem of inadequate capacity to serve differing loads if only specific types are reserved capacity.
• Cyrus Reid from Sierra Club suggested having a separate proceeding for the load capacity topic.
• Discussed the need for better transparency to understand the reality of different loads and required transmission projects.
• Proposed further requirements to make certain loads controllable during peak times.
• Raised a question about the approval and implementation plan sequencing of projects for the commission’s meeting on September 26, 2024.

4 – Should the Commission approve a plan at the September 26,2024 open meeting, by what date can TSPs, with input from ERCOT, provide an implementation plan-including sequencing of projects-for use by the Commission to establish a schedule to sequence priority projects and subsequent projects?  

Stephen Mack – WETT

• Stephen Mack from WETT discussed their position regarding transmission plans.
• WETT is not one of the TSPs in the plan with the most transmission.
• Committed to putting a plan together as soon as possible.
• Timeline for working with others is within weeks.
• Plan details depend on what the order requires.

Emily Jolly – LCRA

• Flexibility in Commission plans is crucial but can introduce uncertainty.
• CCN filings may need more details and optionality, affecting costs and right of way needs.
• Routing alternatives with different voltage levels will require distinct preparations.
• Preparation delays may extend final in-service dates.
• Certain projects need fixed timelines and vendor contracts to avoid further delays.
• Disparity in experience among TSPs affects preparation timelines for CCN applications.
• Experience variability results in different completion times despite the same starting point.
• The recommendation to move forward expeditiously despite variability in TSP timelines.

Liz Jones – Oncor

• Staff’s capacity to plan and process CCN applications is crucial and should be disclosed.
• It is important to balance the number of Brownfield versus Greenfield projects.
• Brownfield projects reuse existing infrastructure but can be delayed by difficulty in scheduling outages, especially in high-demand regions like Permian.
• Greenfield and straightforward Brownfield projects need clear assignment to the right TSPs.
• Oncor recommends a second phase process post-September 26 to handle TSP assignments and contested issues.
• ERCOT and TSPs should collaborate on the sequencing of projects to avoid delays.
• More optionality in CCN applications leads to longer preparation times.
• Customer demand for information on project timelines and locations is high.
• Discussion on customer fairness in cost allocation is acknowledged but deemed a separate issue from today’s discussion.

Nabaraj Pokharel – OPUC

• Nabaraj Pokharel introduced himself as the Director of Market and Revenue Policy from the Office of Public Unity Council.
• He addressed the question of whether the commission should approve the plan at the September 26 open meeting.
• He stated his quick answer is ‘no’ because ERCOT is planning to file the full analysis by the end of September, requiring more time for stakeholders to read and study the report.
• Pokharel emphasized that approving the plan on September 26 does not fit the timeline.
• He mentioned that HB5066 requires the commission to direct ERCOT to develop the reliability plan but does not mandate immediate implementation approval.
• Pokharel indicated that their office filed a comment on 55718, recommending that the commission’s deliberation and recommendations be submitted to the Texas Legislature.
• He highlighted the significant cost involved, particularly impacting residential and small commercial consumers who are not the primary drivers behind these investments.

Chad Burnett – AEP Texas

• The decision on the initial strategy is crucial for effective implementation.
• Advocates for the 765 kV approach due to its ability to simplify the CCN process.
• Simplifying the CCN process can accelerate customer connections.
• Discusses a ‘no regrets approach’ to decision-making with options like 345 kV and 765 kV.
• Fewer CCNs and lines are required with the 765 kV, affecting about half as much land.
• Combining CCNs during sequencing might be an opportunity to streamline the process.
• Overall, believes the 765 kV route offers a quicker regulatory path and minimizes landowner impact.

Emily Jolly, LCRA – Comments on question 4

• Discussion on CCN applications consolidation and its impact on staff.
• Provision that required consolidation of applications with a common endpoint was stricken last session.
• Policy rationale for not requiring consolidation is related to import paths, which can cover hundreds of miles with different impacted communities.
• Historical context involving Oncor and El CIA highlighted issues with non-consolidated CCN proceedings.
• Current impact: Consolidating multiple projects could slow down processes, create bottlenecks, and make processing more challenging for the commission.
• Oncor filed comments on this issue, indicating potential flexibility in the process.

 5 – What methodology should be used to prioritize and sequence the individual CCN applications to fulfill the objectives of PURA section 39.167 to optimize efficient transmission build-out?

Stephen Mack – WETT

• Emphasized that the plan should be revisited after initial assessment.
• Highlighted the importance of evaluating load and generation locations.
• Suggested including an economic analysis in the prioritization by the commission.

Emily Jolly – LCRA

• Need for relative cost-benefit analysis, especially for EHV alternatives.
• Importance of understanding load serving and load carrying capabilities of various import paths.
• Without complete information from ERCOT, the path of least resistance is evident if the 2038 345 kV plan is approved.
• Approval of the 2038 345 kV plan determines the need and directs TSP to prepare appropriate applications.
• Sequencing of application preparations will naturally occur based on TSP’s capabilities.
• Stage gating or staggering process of application submissions could address concerns.
• Discussion on economic analysis: currently driven by load needs, but could include benefits analysis in lowering costs.
• Clarification on including congestion costs in the sequencing process.

Liz Jones – Oncor

• ERCOT has introduced a new economic test consistent with the 2021 legislature but it hasn’t been thoroughly tested yet.
• Liz Jones compares this economic analysis to the NOS proposal from NRG, indicating that it might require significant adjustments before it becomes fully operational.
• All projects discussed are crucial for reliability and customer service, thus prioritizing one over another based on specific benefits is challenging.
• Asking ERCOT to conduct a comprehensive analysis is considered a challenging task.
• Potential delay in the construction of all transmission projects if ERCOT takes up the task, rather than accelerating priority projects.
• Acknowledgment of the phased sequencing of projects, noting that completion is not necessarily tied to the initial order date.

Chad Burnett – AEP Texas

• Recognized need from the load side and new generation from the Texas energy fund.
• Stressed that customers have been waiting for years for the transmission build-out.
• Acknowledged the question of sequencing or prioritizing projects but emphasized the need for immediate action on all fronts.
• Highlighted the potential negative impact of delaying or reordering projects on different customers.
• Expressed the importance of getting a complete approval for the entire project rather than a phased approach.
• Raised concern about the feasibility of handling numerous CCN cases within a tight timeframe.

6 – Due to the large scope of the Permian Basin Reliability Plan, are there any additional outreach efforts the Commission should consider outside of what is required by PURA and Commission rule?  

Liz Jones – Oncor

• Liz Jones emphasized the value of the commission issuing a press release and reaching out to West Texas communities affected by the impacts.
• Highlighted the importance of informing communities to avoid blindsiding them.
• Discussed the sufficiency of the commission’s CCN preparation, public meeting, and notice requirements.
• Noted infrastructure development in the Permian region over the past ten years, suggesting communities are accustomed to this activity.

Emily Jolly – LCRA

• Importance of extensive community engagement and its impact on the preparation time for applications.
• Challenge of routing high voltage electric and transmission facilities through areas with significant oil and gas infrastructure.
• Safety concerns related to routing near oil and gas infrastructure, both above and below ground.
• Unique routing constraints in far west Texas due to oil and gas infrastructure.
• Ongoing engagement with oil and gas community members and associations to better understand the impact of routing.
• Need to avoid having oil and gas producers opposing routes in CCN filings due to safety and infrastructural concerns.
• Reliance on limited publicly available information and the benefits of direct engagement with oil and gas producers to obtain better data.
• Continued efforts to maintain regular contact with community leaders to inform them about upcoming projects.

Meghan Griffiths – PBPA

• PBPA is not advocating for any change in the notice process.
• TSPs in the area have cooperated well with oil and gas loads to reach the current plan.
• Ongoing communication efforts between TSPs and oil and gas loads are important and expected to continue.
• PBPA has invited TSPs and the commission to the region for CCN cases, which they have accepted.
• It is important for TSPs to work with impacted pipelines and oil and gas interests from the beginning.
• TXOGA members are committed to participating in the process to expedite CCN cases.
• A question was raised about whether publishing the endpoints of projects and ownership entities would suffice for TSPs to move forward with filing CCNs or contested cases over project ownership.

7 – If ERCOT publishes the end points of all the projects along with which entity owns each endpoint, would that information suffice for TSPs to move forward with filing CCNs or contested cases over project ownership?

Liz Jones –  Oncor

• Facilitating the elevation of disputes is essential.
• There is a nuance in the ERCOT plan that needs attention.
• Disagreement exists among load sharing entities regarding new endpoints.
• New endpoints impact project distribution disagreements.
• Future phases must address these contested issues.

Emily Jolly – LCRA

• Concern about duplication of effort due to lack of clarity on contested projects.
• Risk of different TSPs creating CCN applications for the same scope, leading to wasted resources.
• Importance of early identification and resolution of conflicts to avoid commission intervention.
• Understanding the constraints ERCOT was under which prevented timely information dissemination.
• Suggestion to improve the process in the coming days and weeks to resolve conflicts.
• Encouragement to provide space in the process for TSPs to confer and resolve or contest as needed.
• Need for a comprehensive data set to proceed effectively.
• Inquiry about potential protocol changes ERCOT should consider for better facilitation of the plan’s build-out.

8 – Are there any protocol changes ERCOT should consider to better facilitate this plan’ s build Out?

Liz Jones –  Oncor

• Liz Jones addressed the need for regional planning groups to function differently in high growth areas.
• She highlighted that this issue might be out of scope for the current proceeding due to its complexity.
• She expressed hope that the commission’s order would align with the first order, noting that additional RPG review of projects is unnecessary.
• Jones emphasized that ERCOT has already undertaken the review, and it now falls under the commission’s jurisdiction through the order and subsequent CCNs.
• She acknowledged that there is some debate about the necessity of further review but noted that the RPG process is fundamentally advisory.
• Jones stated that ERCOT is ultimately responsible for the plan, whether it is the Permian plan, RTP, or another independent review.
• She suggested that protocol improvements could be better addressed separately.

Kamran Ali – AEP Texas

• Ongoing discussions about the reliability and verification of load data.
• Court working on revisions to planning guidelines, specifically PGRR115.
• Encouragement for identifying elements for TSP’s to demonstrate real loads for analysis.
• Recognition of current lag in forecast accuracy and its impact on planning.
• Customers’ need for infrastructure certainty before making investments.
• Appreciation for leadership in recognizing both signed loads and future loads in RTP.
• Call for ensuring permanence in including these loads in future planning.

Meghan Griffiths – PBPA

• Meghan Griffiths, on behalf of PBPA, agrees with Liz that no protocol changes are needed and does not believe the plan needs to go back to RPG.
• Griffiths advocates for moving forward with an order without further delays.
• Cory Allen mentioned working on an NPRR for large load study processes and suggested the commission ensure RPG’s involvement in validating loads and expressed concerns about potentially duplicative loads and urged further investigation.
• ERCOT was asked if they needed any protocol changes; ERCOT confirmed none were needed.

9 – Is there anything else the Commission should consider already not addressed?

Cyrus Reed – Sierra Club

• Stressed the importance of space for updates and conversations moving forward, regardless of the implementation order in September
• Supported the 765 kV plan proposed by ERCOT due to uncertainties around load, especially in the Permian areas, which may have been under-forecasted
• Highlighted the need for grid flexibility to handle future changes and challenges
• Suggested that 765 kV can provide the necessary backbone for future energy adequacy and sustainability
• Noted the unfamiliarity in Texas with 765 kV and recommended a workshop with global experts in short order
• Urged for the right actions for the state of Texas, even if it requires a delay of a couple of months.

Eric Goff – TEBA

• Eric Goff from Texas Energy Buyers Alliance emphasized that physical access to the transmission system is the major constraint on load growth.
• Members are planning investments both inside and outside the Permian area.
• Concern raised about potentially overspending on one plan and needing to pivot.
• Encouragement to consider trade-offs on the 765 kV system to ensure future planning is cost-conscious.

Bob Whitmire – Longhorn Power

• States that the oil and gas load is there. And that if the system needs to take a couple hundred MW of load, it will go there.
• Stressed the need to stop delaying upgrades to the system, particularly referring to a 765MW upgrade that has been postponed for over a decade.
• Kristi Hobbs highlights that traditional system planning is no longer sufficient due to more-than-expected load growth.
• State’s transmission capacity is maxed out, causing problems for new consumers and upgrades.
• Pointed out the struggle for Transmission Service Providers (TSPs) to get necessary outages for new line construction.
• Asks for extra time to ensure ERCOT has a holistic plan to address both short and long term power requirements.
• Agreed with the need for certainty in the planning process and urged timely action to meet the state’s load demands.
• Proposed future workshops involving vendors to discuss concerns about higher voltage lines.
• Asserted that the proposed plan would ensure availability and capacity for new oil and gas loads without being preempted by other loads.

Shana Joyce – TXOGA

• Emphasized the need for timely options, stating that the plan was needed a decade ago. Looks forward to having a final order by the end of September.

10 – Next Steps

• Staff will file a recommendation for consideration and guidance from the commission.
• Aim to complete this over two open meetings while addressing any questions from the Commission..
• Currently planning for September open meetings.