Meeting Summary – 09/12/24 PRS Meeting

1 – Antitrust Admonition – Diana Coleman

2 – Approval of Minutes – Vote – Diana Coleman

• Motion to to approve the August 8, 2024, PRS Meeting Minutes as presented added to the combo ballot.

3 – TAC Update – Diana Coleman

• Two proposed revision requests, NPRR1221 and NPRR1236, were approved by TAC last month.

4 – Project Update – Troy Anderson

Troy Anderson presented the monthly project update from ERCOT portfolio management.

• No discussion on aging revision requests this month; focus shifted to impact analysis accuracy over the past few years.
• August release deployed five items; upcoming September release scheduled for the 26th focusing on RIOO updates and NOGRR208 integration.
• Nine CDR reports will have columns added and field names changed, as detailed in the August 30 market notice.
• Recent market notice on NPRR1205 (credit rating type information), first half went live on July 1.
• SCR799 still in planning; expected to go live in Q4.
• Review of impact analysis accuracy covering 26 projects with 47 revision requests over the past three years:
  • 14 projects met the cost range, 9 exceeded, and 3 were below the expected cost.
  • Highlighted significant outliers: Example – Project cost exceeded estimates by 62%.
  • Projects sometimes fall short of estimations due to unpredictable factors, especially with new initiatives AKA ‘Greenfield’ works.
  • Example: NPRR1108 came under budget due to quicker-than-expected turnaround.
• Impact Analysis duration accuracy discussed: more items completed faster than expected.
  • Notable outlier in duration: NPRR902, which ran 18.5 months instead of 6-9 months.
• Plans to analyze FTE projection accuracy in future reports.
• Suggestion for future reports: show a graph line to represent overall under/overage in time and budget.
• Discussion on understanding cumulative accuracy and potential methods for graphical representation.

5 – NPRR1247 – Urgency Vote – Diana Coleman

Motion to table NPRR1247 and refer the issue to ROS added to combo ballot.

Overview:

• The NPRR1247 is for incorporating the congestion cost savings test required by SB1281 and economic evaluation of transmission projects.
• ERCOT hired E3 to survey best industry practices and recommended measuring from the load cost reduction perspective.

Comments and Concerns:

• Bill Barnes raised concerns about the urgency and lack of detail in the protocol.
• ERCOT’s Matt Arthur explained the urgency related to compliance with PUC substantive rule §25.101.
• Melissa Trevino and others echoed concerns over transparency and detail.
• Alex Miller inquired about linking relevant revision requests for clarity, mentioning PGRR117.
• Katie Rich highlighted the need for further review by ROS and PLWG.
• Several stakeholders echoed discomfort with the urgency status, emphasizing the need for detailed documentation and transparency.

Procedural Clarifications:

• Matt Arthur clarified that without NPRR1247’s approval, ERCOT cannot recommend projects under the congestion cost test for board approval.
• Prabhu Gnanam from ERCOT emphasized the importance of this criteria for subsequent discussions and changes.

Next Steps:

• Proposal to table NPRR1247 and refer it to ROS on a normal timeline.
• Consensus to refer the item to ROS without urgency, pending further discussions and transparency improvements.

6 – Review PRS Reports, Impact Analyses, and Prioritization – Vote – denotes no impact – Diana Coleman

6.1 – NPRR1188, Implement Nodal Dispatch and Energy Settlement for Controllable Load Resources

• Concerns raised about potential EPS meter disrupting prior arrangements between generator and load.
• Agreement from ERCOT and Oncor on language changes, aiming to move forward to TAC.
• Mention of a recommended priority of 2026 and rank of 390 based on August 8 PRS report and June 27 impact analysis.
• Issues discussed regarding the need for action by PRS, with an emphasis on either a motion or second to proceed.
• Decision to take a break to draft language edits and reconvene after 10 minutes.
• Agreement reached on desktop edits including required EPS meter installation with CLR consent.
• Motion made to approve NPRR1188 with desktop edits, followed by second by Melissa Trevino.

6.2 – NPRR1237, Retail Market Qualification Testing Requirements

• Motion to endorse and forward to TAC the 8/8/24 PRS Report and 8/27/24 Impact Analysis for NPRR1237 added to combo ballot.

6.3 – NPRR1244, Related to NOGRR263, Clarification of Controllable Load Resource Primary Frequency Response Responsibilities

• Motion to endorse and forward to TAC the 8/8/24 PRS Report as revised by PRS and the 9/6/24 Impact Analysis for NPRR1244 with a recommended priority of 2025 and rank of 4530 added to combo ballot.
  • Troy provided an update on NPRR1244, noting its importance and potential scheduling challenges.
  • Priority Power initiated the discussion.
  • The priority and rank recommendation for NPRR1244 took into consideration the EMS impact and the ongoing RTC project.
  • Troy suggested seeking PRS input on prioritization to avoid jeopardizing the RTC project.
  • Discussion included setting a tentative prioritization for 2025 with the ability to adjust if risks to the RTC project were identified.
  • Michael Jewell on behalf of Priority Power emphasized the goal of making more CLRs schedule dispatchable and supported the tentative prioritization approach.
  • It was confirmed that NPRR1244 is not technically dependent on NPRR1188.

7 – Revision Requests Tabled at PRS – Possible Vote – Diana Coleman

7.1 – NPRR956, Designation of Providers of Transmission Additions

• Not Discussed

7.2 – NPRR1070, Planning Criteria for GTC Exit Solutions

• Not Discussed

7.3 – NPRR1180, Inclusion of Forecasted Load in Planning Analyses

Follow-Up Questions:

• Concern about the distinction between uppercase and lowercase ‘load’ and possible confusion in the future.
• Agreement that the issue should be addressed for consistency and accuracy in protocols.

Future Action Items:

• ROS to revisit and vote on NPRR1180 in early October.
• PLWG to address the terminology issue of uppercase and lowercase ‘load’.

7.4 – NPRR1200, Utilization of Calculated Values for Non-WSL for ESRs

• Not Discussed

7.5 – NPRR1202, Refundable Deposits for Large Load Interconnection Studies

• Not Discussed

7.6 – NPRR1214, Reliability Deployment Price Adder Fix to Provide Locational Price Signals, Reduce Uplift and Risk

• Not Discussed

7.7 – NPRR1226, Demand Response Monitor

• Amy Loften presented the MP Guide for website changes
• Feedback from market participants on digital channels is desired, with established methods including protocols, system change requests, and other binding documents.
• Displays and dashboards feedback should not use the system change request process as they are not considered systems.
• Digital channels discussed include ERCOT.com, MIS, the mobile app, and public information on ERCOT.com.
• A redesign effort for the ERCOT.com website and the mobile app is ongoing, with feedback mechanisms in place via webmastercott.com and userexperienceercot.com.
• A proposed electronic form process for dashboard feedback was introduced to separate dashboard requests from system change requests.
• Questions and concerns about the differentiation between systems and dashboards, and whether ERCOT needs veto power over dashboard requests.
• The discussion included the appropriateness of the current process for handling such requests and implications for the demand response monitor.
• Suggestions were made to create a formalized process for dashboard requests that is distinct from the existing system change request process.
• There was mention of NPRR1226 continuing under the current NPRR process until a new process is developed.
• Concerns were raised about whether the demand response monitor process was clear and comprehensible regarding defining systems and protocols.
• A suggestion was made for creating an ‘other binding document’ with a distinct change control process from SCR’s for dashboard requests.
• The need for transparency and providing feedback to market participants was emphasized.
• It was proposed that a public document trail should exist to show how feedback is handled, while some participants expressed hesitancy about quick process changes.
• ERCOT’s stance was clarified that the SCR process has been used successfully in the past for similar changes and it may be open for modification.
• Floyd Trefny’s proposal for the demand response monitor involved using state estimator load points to indicate demand response without representing the aggregate value of real-time demand response.
• ERCOT would need to identify and aggregate appropriate state estimator load points and ensure confidentiality.
• A concern about potential inaccuracies in demand response data due to load variations and operational issues was raised.
• Consideration for accurate, meaningful data in evaluating demand response was highlighted.
• Discussion included the importance of disseminating more real-time information to market participants.
• Consensus was to continue conversations on NPRR1226 with no immediate motion or activity needed.

7.8 – NPRR1229, Real-Time Constraint Management Plan Energy Payment

•  Not Discussed

7.9 – NPRR1234, Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater

• Not Discussed

7.9.1 – NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service

• ROS endorsed NOGRR264 this week.
• Comments filed in support of NPRR1235 were considered.
• Eric Goff suggested ERCOT provide an estimate on the amount of reserve service they plan to buy to understand its market impact.
• Katie Rich requested the item remain tabled, to be revisited at a special SAWG meeting on September 27.
• Consensus to keep the item tabled for another month and revisit next month.

7.9.2 – NPRR1238, Voluntary Registration of Loads with Curtailable Load Capabilities

• Not Discussed

7.9.3 – NPRR1239, Access to Market Information

• Motion to recommend approval of NPRR1239 as submitted added to combo ballot.

7.9.4 – NPRR1240, Access to Transmission Planning Information

• Motion to recommend approval of NPRR1240 as submitted added to combo ballot.

7.9.5 – NPRR1241, Firm Fuel Supply Service – FFSS – Availability and Hourly Standby Fee) WMS filed some comments this morning asking us to keep this table so this conversation can keep going at WMWG. Is there

• WMS filed some comments requesting to keep the table for ongoing discussion at WMWG.

7.9.7 NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities

• Concern about notice provided to market participants regarding ERCOT’s disclosure of confidential information to major regulatory agencies.
• Issue specifically with pre-disclosure notice to CFTC as it could violate a CFTC order.
• Potential modification to post-disclosure notice discussed but deemed still problematic.
• Infrequent disclosure of information to CFTC noted, addressing primary concerns.
• Plan to file comments removing the CFTC language edit and restoring disclosure requirements for NERC, FERC, and cyber security agencies.
• Oncor has been in conversations with the sponsors of NPRR1243 to address some concerns, which will be discussed through comments next month.

7.9.8 – NPRR1229, Real-Time Constraint Management Plan Energy Payment

• Not Discussed

7.9.9 – SCR827, Grid Conditions Graph Addition for Operating Reserve Demand Curve (ORDC) Level

• Not Discussed

8 – Review of Revision Request Language – Vote – Diana Coleman

8.1 – NPRR1245, Additional Clarifying Revisions to Real-Time Co-Optimization

• Motion to recommend approval of NPRR1245 as amended by the 9/5/24 ERCOT comments as revised by PRS added to combo ballot.
  • NPRR1245 involves revisions to protocols based on the RTC+B project, including some minor desktop edits.
  • Additional clarifications are needed due to changes since the passing of previous RTC NPRRs and other changes layered on top.
  • Most of the changes have been discussed with the RTC+B task force in multiple meetings.
  • Recent comments were filed earlier this month, containing two main types of changes: related to NPRR1015 and NPRR1093 regarding Ancillary Services, and settlement equations.
  • No questions have been raised by the task force about these changes up to this point.
  • A desktop edit was found that changes subparagraph c parameters from 2000 to 3000 for the new minimum contingency level, aligning it with the formula language above.

8.2 – NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era

• Motion to table NPRR1246 added to combo ballot.
  • Discussion on language alignment for energy storage resources with the single model era.
  • NPRR1246 is similar to previous NPRR1245 and eliminates the combo model.
  • Important for NPRR1246 to go live with RTC+B.
  • Initial posting was made at the end of July and discussed in RTC+B meetings.
  • Subcommittees were asked to review NPRR1246.
  • Other related documents include NOGRR and PGRR.
  • Need time to work through comments and address some inadvertent errors.
  • ROS suggested tabling the four revision requests and reviewing at the RTC+B meeting before deciding in October.

8.3 – NPRR1247, Incorporation of Congestion Cost Savings Test in Economic Evaluation of Transmission Projects

• Not discussed.

8.4 – NPRR1248, Correction to NPRR1197, Optional Exclusion of Load from Netting at EPS Metering Facilities which Include Resources

• Motion to recommend approval of NPRR1248 as submitted added to combo ballot.
  • NPRR1248 addresses missing revisions from NPRR1197.
  • The missing revisions were due to an oversight where the last page was not included in the February PRS report.
  • As a result, some revisions from Oncor comments were omitted from multiple reports: PRS, TAC, Board, and PUC.
  • NPRR1248 aims to incorporate the missed changes to ensure the intended clarifications of NPRR1197 are complete.
  • The correction is described as a ‘cleanup language’ and has no impact.
  • There was a suggestion to recommend approval of NPRR1248 as submitted.
  • The participants agreed to move forward with the approval.

8.5 – NPRR1249, Publication of Shift Factors for All Active Transmission Constraints in the RTM

Motion to recommend approval of NPRR1249 as submitted added to combo ballot.

Discussion Points:

• Speaker: Steve Reedy
  Affiliation: CIMVIEW Consulting
  Key Points:
  • ERCOT publishes shift factors for the real-time market (RTM) only for constraints that bind in the auction.
  • Synvue is proposing ERCOT publish all shift factors for all active constraints, not just the binding ones.
  • This would help companies like Synvue rerun SCADA and perform shadow constraint competitiveness tests.
  • Necessary for the proposed NPRR that mitigates batteries.
  • A relatively simple language change is needed to include all active constraints in the same reports.
• Speaker: Bill Barnes
  Affiliation: NRG
  Key Points:
  • Supports more transparency and data access.
  • Emphasizes the importance of assessing the impact analysis, which requires approval.
• Speaker: Blake Holt
  Affiliation: LCRA
  Key Points:
  • Echoes Bill’s comments and agrees with Steve’s reasoning.
  • Seeks clarity on the potential size of the report if all active transmission constraints are published.
• Speaker: Dave Maggio
  Affiliation: ERCOT
  Key Points:
  • The report size could potentially double or triple.
  • Reports are typically per SCADA interval, which would increase file sizes but keep them focused.

8.6 – NPRR1250, RPS Mandatory Program Termination

• Motion to table NPRR1250 and refer the issue to WMS added to combo ballot.
  • ERCOT introduced NPRR1250 aimed at implementing HB1500 for the retirement of the RPS program.
  • Clarification needed on the implementation date, intended for September 1, 2025.
  • Concerns raised about premature implementation and lack of clarity in the filing.
  • Discussion about maintaining the confidentiality of transmission-level customer information.
  • Proposal to refer NPRR1250 to WMS for further discussion due to existing comments and concerns.

8.7 – NPRR1251, Updated FFSS Fuel Replacement Costs Recovery Process

• Motion to table NPRR1250 and refer the issue to WMS added to combo ballot.
  • NPRR1251 updates the firm fuel replacement cost recovery process.
  • Clarification that QSEs representing farm fuel supply generators can restore fuel services with existing inventories.
  • Allows generators to use large storage tanks to provide available fuel services immediately rather than waiting for new purchases.
  • Addition of two compensation options: purchase new fuel (ERCOT reimburses costs) or use existing inventory (payments based on fuel oil price index plus transportation costs).
  • The proposed changes aim to expedite service availability during disruptions but may not necessarily reduce overall restocking costs.
  • Some members suggest tabling and referring the proposal to WMS and WMWG for further discussion.
  • Clarification given on restocking approval timings and conditions, particularly towards the end of the season.
  • Flexibility in the proposal allows generators to avoid repurchasing fuel if existing stocks can be utilized efficiently.

8.8 – NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements

Motion to table NPRR1252 added to combo ballot.

• ERCOT’s proposal NPRR1252 includes three main changes.
• Change 1: ERCOT proposes to remove the pre-notice requirement for disclosing ECEII (Electricity Critical Energy Infrastructure Information) or protected information to vendors.
  • Vendors sign non-disclosure agreements meeting Section 1 of the protocols.
  • Vendors undergo a risk management assessment survey reviewed by ERCOT’s cybersecurity department.
  • Vendors’ employees requiring access privileges must pass a NERC CIP background check.
  • Removal of pre-notice requirement for market participants providing ECEII to their vendors.
• Change 2: Addition of a new entity type: ERCOT research and innovation partners (RNI).
  • These partners collaborate with ERCOT to improve system and market operations.
  • Pre-notice is not required if ECEII is provided to RNI partners.
• Change 3: Clarification and updating of notice requirements. 
  • Allow email and market notice as acceptable forms of notice.
  • Elimination of requirement to follow up email notices with mailed notices.
• Venkat Tirupati emphasized the importance of RNI partners in addressing grid transformation challenges.
• RNI partners such as universities and national labs will follow stringent cyber and risk management controls.
• General agreement on the proposal’s benefits but calls for more time to contemplate definitions and implications.
• Martha Henson (Oncor): Clarity needed on the distinction between PI (Protected Information) and ECEII, and related notice requirements.
• Consensus to table NPRR1252 for a month to further consider proposals and ensure balanced notice provisions.

9 – Other Business – Diana Coleman

• Heads up about the next two open meetings.
• Discussion about possible overlap between open meetings and PRS scheduled meetings.

10 – Combo Ballot – Vote – Diana Coleman

11 – Future Meetings – Diana Coleman

• Possible future meetings on October 17 and November 14.