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