Meeting Summary – 09/24/24 PLWG Meeting

1 – Antitrust Admonition – Chair

2 – Agenda Review – Chair

3 – Review of PLWG Meeting Minutes – Aug 13 – Chair

• No comments were received on the draft minutes.
• Minutes were deemed final and posted on the PLWG event page.

4 – General updates – Chair

4.1 – At its Sept 9 meeting, ROS voted to endorse PGRR107 – related to NPRR1180 – Inclusion of Forecasted Load in Planning Analyses – ERCOT’s Aug 28 comments – after desktop edits.

• ROS voted to endorse PGRR107 related to NPRR1180.
• PGRR107 pertains to the inclusion of forecasted load in planning analyses after desktop edits.
• An action item was assigned to review and revise the planning guide regarding capital ‘L’ and small ‘l’ load terminology.
• Changes made around the load terminology resulted in desktop edits and were endorsed by ROS.
• The planning guide will be reviewed as a broader document to reflect changes in load terminology.

4.2 – 2025 PLWG meetings, RPG/PLWG joint meetings or standalone.

• Discussion on whether PLWG meetings should continue to be held jointly with RPG or as standalone meetings.
• Concern over lengthy agendas for both RPG and PLWG, raising the question of adequate time allocation.
• Benefits of joint meetings include travel efficiency, allowing attendees to address both meetings in one trip.
• Suggestions for joint meetings to be scheduled on adjacent days (day before or day after) to accommodate overruns and ensure adequate discussion time.
• Challenge noted in scheduling due to room availability; potential fallback to WebEx for split meetings deemed less optimal for travel purposes.
• Acknowledgement that predicting the length and scheduling of ERCOT meetings is difficult, thus complicating planning.
• Consideration of future meeting structure adjustments due to changing and potentially lengthier meeting times.
• Possibility of canceling and rescheduling meetings based on agenda size to manage travel and accommodation more effectively.
• Reminder about 2025 PLWG leadership opportunities with discussions and nominations starting around November, transitioning in February.

5 – PGRR115 related to NPRR1234 – Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater

5.1 – CenterPoint Energy comments 08/29/24

Jim Lee from CenterPoint Energy discussed comments filed in late August on PGRR115.

• Key focus on clarifying the load commissioning plan: definition, responsibilities, contents, and updates.
• Added definitions for “load facility” and “load point”, capitalized throughout the document.
• Proposed separating generator interconnections (section 5.3.5) and large loads (new section 9.5).
• Clarifications on data modeling responsibilities: TSP receives and passes data to ERCOT but not responsible for validation.
• Edits emphasize TSP responsibility for studies and decisions on study requirements due to familiarity with systems and large load relationships.
• Changed wording from “complete” to “proposed” for the load commissioning plan, recognizing it as a living document.
• Extended timelines of large load interconnection study scoping processes to 10 days.
• Standardized terminology to “lead TSP” throughout the document.
• Clarifications on responsibility for providing dynamic data for large loads.
• Highlighted importance of including relevant large loads and their upgrades in steady state studies.
• Significant discussion on co-located facilities and the need for coordinated study process.
• Recognition of differing views between TSPs like Oncor and CenterPoint on specific edits (e.g., breaker requirements).
• Questions raised for ERCOT regarding clarity and specifics on certain sections.
• Monica and other members raised points about the need for clarity on resource entity involvement in cases of co-located loads and generation.
• ERCOT expressed concern over making stability studies discretionary and indicated plans for further comment and discussion.

5.2 – Oncor comments 09/09/24

Martha Henson from Oncor presented comments on the PGRR document.

• Oncor categorized comments into two buckets: modifications through red lines and items seeking more information.
• Proposed edits to Quarterly Stability Assessment (QSA) language for loads, specifically clarifying responsibility for providing a dynamic load model.
• Suggested ERCOT review the model early in the process to confirm appropriateness for the QSA.
• Discussion on separating load QSA provisions to streamline approach for loads.
• Request to add distribution providers in the LLIS process to ensure specific mention.
• Proposed to strike paragraph C in section 9.2.1, citing inconsistencies with paragraph B regarding capacity increases and existing load facilities.
• Edits to 9.2.2 to clarify distinctions in LCP preliminary and final processes.
• 9.2.3 clarifies that ILLE is responsible for providing dynamic load model to TSP, and for notifying TSP if the model is updated by the customer.
• Opposed ERCOT’s broad prohibition on customer demand increases post-LLIS process.
• Added small language changes in 9.3.2-9.5 covering kick-off meetings, certification of distribution providers, study case projects, interconnection agreements, and financial security.
• Insistence that load commissioning plans should be managed by TSP and follow LCP without extra back-and-forth with ERCOT.
• Requests for more clarity and possible templates from ERCOT for LCPs and LLIS entry.
• Discussion ensued on whether temporary interconnections via remotely operated switches will undergo comprehensive studies.
• ERCOT emphasized necessity for POI changes to go through large load interconnection process.
• Concerns about provisions for remotely operated interruption devices and potential safety issues.
• The need for ERCOT to further clarify and align planning guide language, taking into context how ‘large load’ is defined and applied across different sections.

6 – PGRR117 – Addition of Resiliency Assessment and Criteria to Reflect PUCT Rule Change
PLWG – 30 min PGRR117

• Resiliency assessment and criteria reflect PUC rule change, second presentation at PLWG.
• Comments received from LCRA, discussed by Andrew in absence of Blake.
• Wordsmithing changes to item one: change position of reliability/resiliency, ‘must’ to ‘shall’.
• Clarifications on resiliency assessment cases, inclusion of scaled RTP cases as discussed by Robert Golen of ERCOT.
• Contingency set clarification:
  • P0, P1, and P2.1 as defined by NERC TPL-001.
  • Common tower outages as defined in ERCOT planning guide §4.1.1.1.
• Proposal to strike power supply language in item B, deemed redundant and covered elsewhere.
• Wordsmithing in section 4.1.2, strike unnecessary phrases.
• Add duration consideration for load loss impact as suggested by CenterPoint, debate over its necessity and emphasis.
• Clarification required on ‘load loss’ terminology to align with planning guide language.
• Suggestion to keep ‘impact’ broad to incorporate various factors without singling out duration.
• ERCOT plans to study more scenarios in future assessments based on stakeholder feedback.
• Discussion on preventing system instability under extreme weather conditions as part of resiliency.
• Risk of piecemeal studies was acknowledged, intention to cover more comprehensively in future assessments.

Questions Raised

• Impact of adding ‘duration’ in resiliency criteria, whether it should be considered separately or under ‘impact’.
• Necessity and placement of generation assumptions in item two versus item three.
• Clarification on coincident vs. non-coincident load values for regional transmission plan study cases.
• Definition of ‘load loss’ vs. ‘load shedding’ and how to align terminology with current planning guides and protocols.
• Preventing instability as part of resiliency criteria and its relationship with existing reliability and GTC criteria.
• Exact scope and criteria RMS will use to recommend resiliency projects.

Comments From Stakeholders

• Concerns over adding duration raised by Laurie Block, supported by Mark Bruce and others.
• General preference for seeing comprehensive package including NPRR expected from ERCOT.
• Need to ensure ERCOT guidelines align with both legislative requirements and existing planning guides.

Responses From ERCOT

• ERCOT acknowledged ongoing internal discussions and intentions to revise language for clarity.
• Commitment to incorporate various feedback and re-evaluate positioning of generation assumptions and load values.
• Assurance of considering broader spectrum of factors under the term ‘impact’.
• Working towards aligning terminologies used in different documents and guidelines.

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

Draft Congestion Cost Savings Test Evaluation Guideline

• Laurie Block raised a question about ERCOT’s response to TIEC’s comments on timeline consistency.
• Ping Yang explained ERCOT’s approach to studying-years, up to six years out due to uncertainties in the future.
• Yang clarified that ERCOT compares annual savings with annual revenue requirements for projects.
• Yang confirmed that ERCOT is open to adding clarifications to address stakeholders’ concerns.
• Dylan Preas brought up reviewing the NPRR1247 language and suggested having ERCOT’s documents for reference.
• Constance McDaniels Wyman, ETT & APSC,  expressed support for NPRR1247 but noted potentially confusing language and suggested improvements so that the CCS components don’t appear to point back to the PCS.
• ERCOT mentioned the development of a white paper to add transparency to the congestion cost savings test process.
• Mark Bruce sought clarification on the current process and a historical review of ERCOT’s application of specific cost-benefit considerations.
• Stakeholder questions focused on details related to economic benefit calculations, inflation factors, and price responsive loads.
• Concerns were raised about the legal binding nature of the white paper and whether it needs to be referenced in protocols.
• Matt Arth from ERCOT explained that the white paper adds clarity but does not have the same legal binding as protocols.
• Discussion on potentially including the white paper by reference in NPRR for future updates.

Next Steps: The discussion will be tabled for the next meeting until ROS formally assigns it to the PLWG (Planning Working Group) for further discussion.

8 – NERC Topics Roundtable – future topics

8.1 – CIP-014-4 – Physical Security – topic pending new draft

• New draft version (Draft 2) of CIP-014-4 was posted on NERC Project 2023-06.
• The draft is open for comments.
• An industry webinar is scheduled for October 17 to discuss proposed changes.
• The comment window is a 45-day period, likely closing in the first week of November.
• Transmission planners are encouraged to review the draft and attend the webinar.

8.2 – TPL-008 – Transmission System Planning Performance Requirements for Extreme Temperature Events

The discussion centered around TPL-008, concerning extreme weather events and transmission planning.

• Sun wook, ERCOT, mentioned that two drafts have been developed so far, with the team holding daily virtual meetings to address comments.
• A new version of TPL-008 is expected to be issued in early October, followed by a 15-day comment period.
• Details on tested contingencies remain confidential but the changes aim to address industry feedback.
• The revision is significant for transmission planners and will require their attention.

9 – Review Open Action Items Chair

Key Discussion Points:

• Identification that some documents (including those posted online) lacked listed action items.
• Open action item assigned to PLWG by ROS to review the use of load in the planning guide.
• Discussion on addressing inconsistencies in the use of certain terms (e.g., large load versus little load).
• ERCOT hasn’t committed to taking the lead on addressing these inconsistencies yet.
• Proposition to address inconsistencies as they come up during revisions rather than making a blanket revision.
• Need for internal discussions within ERCOT regarding the best approach to handle the inconsistencies.
• Discussion on whether PLWG should start the revision request process.
• Clarification sought on whether a working group can sponsor a revision request without a stakeholder representative.
• Commitment to report back to ROS after gathering more information.

Next Steps:

• Further discussions within ERCOT to determine the best approach for addressing inconsistencies.
• Erin to research and provide more information on the process for sponsoring a revision request.
• Report back to ROS with findings and potential plans.

10 – Other business

• A reminder was issued to submit the ROS, PLWG update by Thursday.
• A presentation will be prepared despite not having full input from the working group.
• Discussion emphasized giving ROS members sufficient time to review the presentation before the ROS meeting.
• A request was made for a list of WebEx participants due to people frequently coming in and out.
• Erin acknowledged the request for the participant list and agreed to follow up.
• Market services may assist in providing the requested list of WebEx attendees.

11 – Adjourn