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October 30, 2024
Meeting Summary - 10/17/24 PRS Meeting
1 – Antitrust Admonition – Diana Coleman
2 – Approval of Minutes – Vote – Diana Coleman
- Motion to approve the September 12, 2024, PRS Meeting Minutes as presented added to the combo ballot.
3 – TAC Update – Diana Coleman
- TAC met last month to review proposed revision requests from PRS.
- Three proposed revision requests were approved by TAC.
- NPRR1188: Implementation of nodal dispatch and energy settlement for CLRs.
- NPRR1237: Retail market qualification testing requirements.
- NPRR1244: Clarification of CLR primary frequency response responsibilities.
- No additional comments or thoughts were shared for the TAC update.
4 – Project Update – Troy Anderson
prs_october_2024_project_update.pdf
- The September release went live on September 26 with several RIOO items and changes to CDR reports.
- XML implementation began October 1 related to NPRR1217; both XML and VDI will be supported until December 1.
- SCR799 went live on October 9.
- Upcoming changes include NPRR1205 on November 1 and TexasSET 5.0 in November around the 10th.
- NPRR1184 planned for December regarding cash collateral procedures.
- NPRR945 is expected to go live in December.
- NPRR1183 moved to March 2025 and NPRR1145 planned for March concerning calculated ERCOT wide TLFs.
- RTC+B targeted to go live on December 5, 2025.
- NPRR965 GREDPE shutdown exemption to be integrated with RTC in late 2025.
- Several projects deferred until after RTC due to resource constraints.
- SCR799 implementation appreciated; a project which faced execution and resource hurdles.
- Future planning includes tabling priorities for further review and potential cost-saving solutions.
- Discussions about post-RTC project sequence planning emphasized.
5 – Review PRS Reports, Impact Analyses, and Prioritization – Vote – denotes no impact – Diana Coleman
5.1 – NPRR1180, Inclusion of Forecasted Load in Planning Analyses
- Motion to endorse and forward to TAC the 9/12/24 PRS Report and 10/16/24 Impact Analysis for NPRR1180 carried unanimously.
- Recommendation to approve NPRR1180, already voted last month with amendments from August 28 ERCOT comments.
- Discussion over the impact analysis (IA), suggesting ERCOT to withdraw and reconsider it due to misalignment with NPRR language.
- ERCOT’s IA includes changes in load definitions for planning models, triggered by legislative House Bill 5066.
- ERCOT adds new definitions (b and c) regarding independent third party load forecast and letters from TDSP officers.
- Impact on planning studies, requiring additional resources: 11 FTEs added across RTP, RPG, and load forecasting groups.
- Need for staff increases not solely tied to this NPRR but necessary due to system growth and legislative requirements.
- Support for ERCOT obtaining necessary staffing, although some believe the issue should align with normal budget processes.
- Mark Dreyfus suggests that impact analyses should strictly align with the effects of NPRRs and not broader changes, advocating review.
5.2 – NPRR1239, Access to Market Information
- Motion to table NPRR1239 added to the combo ballot.
5.3 – NPRR1240, Access to Transmission Planning Information
- Motion to table NPRR1240 added to the combo ballot.
- Request to table NPRR1240 to reevaluate and potentially have revised items for November.
- Potential to leverage NPRR1240 with an upcoming internal public API project.
- Four-week period requested to consider factors and possibly revise items to stay on track for December board.
- Plan to revisit and potentially come back with revised IAs next month.
5.4 – NPRR1245, Additional Clarifying Revisions to Real-Time Co-Optimization
- Motion to endorse and forward to TAC the 9/12/24 PRS Report and 7/30/24 Impact Analysis for NPRR1245 added to the combo ballot.
- Item originated from ERCOT.
- Approval was voted last month with amendments from the September 5 ERCOT comments.
- Some on-the-spot revisions were made by PRS.
- No costs are associated with this change.
5.5 – NPRR1248, Correction to NPRR1197, Optional Exclusion of Load from Netting at EPS Metering Facilities which Include Resources
- Motion to endorse and forward to TAC the 9/12/24 PRS Report and 8/16/24 Impact Analysis for NPRR1248 added to the combo ballot.
- NPRR1248 presented by ERCOT as an administrative change.
- The change captures language missed in NPRR1197.
- The adjustment aligns with the initial intent of NPRR1197 and the PRS action taken in February.
5.6 – NPRR1249, Publication of Shift Factors for All Active Transmission Constraints in the RTM
- Motion to endorse and forward to TAC the 9/12/24 PRS Report and 10/15/24 Impact Analysis for NPRR1249 with a recommended priority of 2026 and rank of 4740, added to the combo ballot.
- The proposal is from Steve Reedy.
- Unanimous recommendation for approval last month.
- Cost impact estimated between $25,000 and $45,000.
- Implementation duration expected to be three to five months.
- IA deemed satisfactory.
6 – Revision Requests Tabled at PRS
6.01 – NPRR956, Designation of Providers of Transmission Additions
- NPRR956 is one of the oldest NPRRs and still on the list.
- ERCOT is monitoring ongoing litigation related to Senate Bill 1938.
- A final judicial determination on the constitutionality of Senate Bill 1938 is awaited.
- There was discussion about whether to withdraw or redo NPRR956 upon the final decision.
- Current intent is to keep NPRR956 tabled until further decisions are made.
6.02 – NPRR1070, Planning Criteria for GTC Exit Solutions
- NPRR1070 is an old proposal that is still under discussion.
- Conversations are ongoing regarding the overlap between NPRR1070 and NPRR1247.
- There is a desire to hear from the market monitor before withdrawing or changing NPRR1070, as it was a recommendation from several years ago.
- There is acknowledgment that although NPRR1247 might resolve some issues, there is no official endorsement of it by the market monitor.
- Discussion has been affected by staff changes at the market monitor.
6.03 – NPRR1200, Utilization of Calculated Values for Non-WSL for ESRs
- NPRR1200 is presented by Nextera and is an older proposal that was tabled at the WMS.
- It is pending review by the metering working group, and the timing of their next meeting is uncertain.
- The NPRR1200 aims to achieve similar objectives as SMOGRR28.
- The last ERCOT board discussed SMOGRR28, and ERCOT is collaborating with market participants to develop comments for the metering working group.
- The ERCOT board hopes to have more discussions and progress on this proposal soon.
- It’s indicated that the metering working group has not met recently as they await developmental comments.
- There is a preference for SMOGRR28 within the group.
6.04 – NPRR1202, Refundable Deposits for Large Load Interconnection Studies
- Discussion initiated by Lancium, highlighting comments filed by ERCOT and Longhorn Power in response to NPRR1202.
- Revised header for NPRR1202 focuses on accelerating generation and load interconnections.
- Bottleneck identified at the study approval stage by TDSP and ERCOT, resource integration engineers have high project loads.
- Proposal includes charging user fees for connecting load/generation to accelerate study processes.
- Proposed fees include a $25,000 initial charge and $5,000 quarterly fee.
- Concerns about lack of automation within ERCOT systems and need for user-accessible project tracking.
- Longhorn Power supportive of idea to increase discipline and certainty in project queues, with reference to higher fees at PJM as a comparison.
- ERCOT’s response highlights ongoing efforts to speed up current queue processes and address stale projects.
- Discussion of a potential recurring fee; ERCOT not opposed but cautious about its structure due to cost justification requirements.
- Acknowledgment of increased project activities leading to possible fee adjustments in future budget cycles.
- Concern over ERCOT’s staffing being a bottleneck; emphasis on holding ERCOT accountable for timely processing.
- Stakeholders willing to invest to accelerate project processes, seeking solutions such as staff training or contractor use.
- Further discussions scheduled at the WMWG meeting.
6.05 – NPRR1214, Reliability Deployment Price Adder Fix to Provide Locational Price Signals, Reduce Uplift and Risk
- The item was discussed at CMWG earlier this week.
- There were joint comments proposing adjustments to the RTO, RDPA.
- Goal to file comments in time for WMS consideration next month.
- There is ongoing movement and updates expected next month on NPRR1214.
6.06 – NPRR1226, Demand Response Monitor
- Discussion held to raise awareness about NPRR1226 and its progress.
- ERCOT provided a presentation on how stakeholders can request dashboards or website items for required information.
- ERCOT is working on establishing an official process rather than relying on informal communications.
- The importance of sharing ideas and information among stakeholders was emphasized.
- Suggestions included involving the technology working group to address current constraints.
- A meeting with the technology working group is scheduled for the 21st to discuss NPRR1226.
- Stakeholder feedback is deemed crucial while working within ERCOT’s evolving framework.
- An update on the process is expected next month, though it may take longer internally at ERCOT.
6.07 – NPRR1229, Real-Time Constraint Management Plan Energy Payment
- NPRR1229 originated from STEC.
- Comments were filed after the last PRS meeting.
- Lucas Turner filed comments to address ERCOT’s request for clarifications.
- The discussion on NPRR1229 is ongoing.
6.08 – NPRR1234, Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater
- ERCOT plans to file comments before the next planning working group meeting.
- NPRR1234 is still in progress.
6.09 – NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service
- Extensive conversation and activity since the last PRS meeting.
- Comments filed by Luminant and Advanced Power Alliance.
- WMS discussed the item earlier in the month but did not vote on it.
- Three issues are currently being worked on.
- Item is tabled at WMS for another month to allow further discussions.
- Potential for more conversation on the topic in the following month.
- ERCOT also provided comments on NPRR1235.
6.10 – NPRR1238, Voluntary Registration of Loads with Curtailable Load Capabilities
- Ongoing conversations about NPRR1238.
- Currently not ready for a vote.
- Discussion held multiple times at OWG meetings.
- Questions raised about minimum cap requirements and nuances of NPRR1238.
- Encouraged the continuation of discussions at OWG.
6.11 – NPRR1241, Firm Fuel Supply Service (FFSS) Availability and Hourly Standby Fee
- Not Discussed
6.12 – NPRR1242, Related to VCMRR042, SO2 and NOx Emission Index Prices Used in Verifiable Cost Calculations
- Not Discussed
6.13 – NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities
- There is a suggestion for either a combo ballot or a motion to approve the most recent version of NPRR1243.
- Oncor showed support for the approval scheduled for October 14.
- Appreciation was expressed for ERCOT legal’s cooperation in finding a reasonable solution.
- Concerns were raised about the careful implementation due to federal protections for the data.
- Potential criminal liability related to incorrect data release was highlighted.
- Recommendation was made to release data under the federal power act as suggested by ERCOT.
- Comments filed on NPRR after discussions were productive.
- Oncor appreciates the collaborative effort to ensure notification of disclosure to regulators is preserved.
- NPRR1243 to be tabled for one more month.
6.14 – NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era
- Motion to recommend approval of NPRR1246 as amended by the 9/20/24 ERCOT comments added to the combo ballot.
- NPRR1246 is an alignment with the single model era, necessitating updates to terminology due to the transition from the combo model era.
- In the single model era, Energy Storage Resources (ESR) are distinct and require their own language, unlike the combo model which shared generation resource language.
- NPRR1246 is part of a set that includes a PGRR, a NOGRR, and an OBDR which are all addressing the alignment of ESR terminology.
- ROS filed a request to table the NPRR1246 along with the OBDR, but PGRR and NOGRR were recommended for approval.
- There were ERCOT comments regarding changes to voltage support service payments and other ESR terminology.
- Discussions on policy direction and stakeholder concerns related to statutory deadlines and terminology clarity continue.
- Discussion also raised issues of compliance and implementation for proposal 1238, focusing on ramp rate limits and responsibility for compliance.
6.15 – NPRR1247, Incorporation of Congestion Cost Savings Test in Economic Evaluation of Transmission Projects
- ERCOT posted a draft white paper last month on NPRR1247, which received several comments.
- The ERCOT board of directors urged moving forward with NPRR1247.
- A special planning working group meeting is scheduled for the 29th to reach consensus before the November PRS
- The PLWG had a lengthy discussion on NPRR1247 and scheduled an additional meeting later this month.
- There is a possibility of submitting comments to ROS in November and revisiting the urgency request.
- No immediate action was suggested for NPRR1247, but the aim is to expedite the process to reach the December board.
6.16 – NPRR1250, RPS Mandatory Program Termination
- WMS voted to keep NPRR1250 tabled for another month due to ongoing work.
- Future intent to move NPRR1250 forward for a vote prior to its termination date, emphasizing compliance with PUC rules.
- Eric Goff from the Texas Energy Buyers Alliance is working on proposed changes to allow additional attributes on certificates, suggesting administrative benefits for keeping NPRR1250 tabled.
- Discussions involve modifying multiple instances in the protocols, adding complexity when considering making changes simultaneously.
- A consensus exists among some members to wait another month to resolve outstanding issues collaboratively.
- A focus remains on working towards separate NPRRs if necessary, ensuring all changes are comprehensively addressed.
6.17 – NPRR1251, Updated FFSS Fuel Replacement Costs Recovery Process
- Not Discussed
6.18 – NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements
- Comments related to NPRR1252 are being prepared by Oncor for next month’s PRS.
- These comments depend on the outcome of NPRR1243, which has been tabled for one more month to allow for a thorough review.
6.19 – SCR826, ERCOT.com Enhancements
- Not Discussed
6.20 – SCR827, Grid Conditions Graph Addition for Operating Reserve Demand Curve (ORDC) Level
- Not Discussed
7 – Review of Revision Request Language – Vote – Diana Coleman
7.1 – NPRR1253, Incorporate ESR Charging Load Information into ICCP
- Motion to table NPRR1253 added to the combo ballot.
- NPRR1253 relates to incorporating ESR Charging Load information into the ICCP data set.
- ERCOT does not currently have wholesale storage load as a value but uses ESR Charging Load as a proxy.
- The NPRR proposes to make ESR Charging Load available via ICCP.
- Minor edits to the protocol were suggested to ensure clarity on data types.
- Discussion on data posting indicated data should be available on both ICCP and the ERCOT website.
- Suggestions were made to include data posting in CSV and XML formats.
- There is an existing CSV file containing this data, but it is hard to access.
- A request to hold off on immediate implementation was made to confirm all stakeholders are aligned and have access.
- Providing data via ICCP is a minor change since the data is already in ERCOT’s system.
- Additional discussions and comments are expected before moving forward with the implementation.
7.2 – NPRR1254, Modeling Deadline for Initial Submission of Resource Registration Data
- Motion to recommend approval of NPRR1254 as submitted added to the combo ballot.
- Introduction of the NPRR1254 to formalize the initial submission deadline for resource registration data.
- The modification is intended to relieve ERCOT staff workload by requiring data submission a month earlier than the previous deadline.
- This NPRR proposal targets reducing errors and providing more time for data validation.
- The calendar change adds a new column for an additional month dedicated to review and data clean-up.
- Concerns were raised about the potential impact on projects already under the current schedule.
- There’s acknowledgment of the urgency of the proposal while wanting to avoid impacting existing timelines.
- Consensus on approving the NPRR1254 with the understanding that its implementation date will be decided to prevent disruption of current projects.
7.3 – NPRR1255, Introduction of Mitigation of ESRs
- Motion to table NPRR1255 added to the combo ballot.
- Introduction of mitigation for energy storage resources (ESR) with mitigated offer cap curves below the system-wide offer cap to prevent market power exploitation.
- Ryan King from ERCOT provided an overview stating it’s a culmination of months-long consultations involving CMWG, WMS, and TAC.
- Proposal aims to replace the existing mitigated offer cap framework for ESRs with a ‘just in time mitigated offer cap’ based on specific conditions.
- Revisions primarily affect section 4.4.9, detailing constraints for flagged ESRs and the determination of the mitigated offer cap.
- Reviewed and refined through feedback with high-level sensitivity analysis showing minimal impact on intervals and capacity.
- Discussion on whether NPRR1255 should be moved forward, with some support for tabling for further review of language and implications.
- Caitlin suggests motion to table to better understand implications and check language accuracy.
8 – Other Business – Diana Coleman
- Reminder to submit membership applications and fees as the election process begins soon.
- Date of record is Friday, November 1, and elections start November 5.
- Market notice will be released on October 28, a week prior to the date of record.
- Questions about TAC affirmation letter and subcommittee letter; no changes from last year.
- Corporate membership list is updated weekly; more frequent updates suggested closer to the deadline.
- Requested earlier distribution of TAC qualification and employment letter examples.
- Plans to send examples three times: after October TAC meeting, on October 28, and November 5.
- Discussion on membership verification process and potential need for a better confirmation system.
- PRS November and December meetings will have afternoon start times to maintain consistency.
- Confirmation that portal notifications will inform when applications and fees are fully processed.
- Shared experience of not receiving payment confirmation but eventually appeared on the membership list.
9 – Combo Ballot – Vote – Diana Coleman
Motion to approve combo ballot carries unamiously.
10 – Adjourn
Related meeting(s): NPRR1205 – SMOGRR028 – NPRR1238 – NPRR1070 – NPRR965 – NPRR1248 – NPRR1184 – NPRR1243 – NPRR1247 – NPRR1180 – NPRR1237 – NPRR1254 – NPRR1229 – NPRR1197 – NPRR945 – NPRR1246 – NPRR1200 – NPRR1239 – NPRR1244 – NPRR1255 – NPRR1234 – NPRR1249 – NPRR1183 – NPRR1250 – NPRR1202 – NPRR1240