Meeting Summary – 10/30/24 TAC Meeting

1 – Antitrust Admonition – Caitlin Smith

2 – Approval of TAC Meeting Minutes – Vote – Caitlin Smith

• Motion to approve the September 19, 2024 TAC meeting minutes as presented added to combo ballot

3 – Meeting Updates – Caitlin Smith

3.1 – September/October Board/PUCT Meetings

• Multiple meetings have occurred since the September TAC meeting.
• ERCOT board meetings took place on October 9th and 10th.
• All revision requests except NPRR1190 were approved at the October board meetings.
• NPRR1190 was remanded and is on the current agenda for further discussion.
• PUC open meetings were held on September 26, October 3, and October 24.
• All revision requests in front of the Commission were approved in the September 26 PUC meeting.
• Two discussion items were highlighted in the update agenda item.

3.1.1 – Subcommittee Reporting to the Board

• At the October board meeting, a longer TAC report with more information was well received.
• Efforts are being made to improve communication and transparency to the board and the commission.
• The October board meeting included highlights from all subcommittees and task forces, not just TAC.
• Proposed direction is for subcommittees and task forces to highlight contentious items before board voting.
• Clarification that not all news needs to be contentious, but highlights of consensus and improvements are also valued.
• No input was received during the meeting regarding the reporting strategy.
• Continued collaboration with subcommittee and task force leadership will happen offline.

3.1.2 – NOGRR245 Update

• The Commission has approved NOGRR245, and it was bifurcated, indicating a need for a phase two.
• The remaining details of the exemption process are to be addressed through a PUC rulemaking instead of continuing under NOGRR.
• A PUC-selected team is collaborating with ERCOT staff to define the rulemaking process.
• The new rule will establish scenarios and criteria under which entities can request exemptions from reliability rules.
• ERCOT will propose mitigation strategies when exemptions are possible, to maintain grid reliability.
• A process for entities to appeal ERCOT’s decisions will be included, entailing a contested case process.
• The rulemaking is in its early stages, with expectations for robust written comments.
• The aim is to adopt the rule by early spring to align with upcoming filing requirements.

4 – Board Remand of NPRR1190, High Dispatch Limit Override Provision for Increased Load Serving Entity Costs – Vote

• The board remanded NPRR1190, which was previously voted through TAC in June and tabled by the board in August.
• The item is being presented as a reintroduction to TAC, considering further action needs to be taken.
• The approach proposed is to use the current meeting as an educational session and defer the vote to November for a substantive vote.
• Any decisions made by November would go to the December board meeting, aligning with the existing timeline.

• Motion proposed to table NPRR1190 for further discussion with an aim to refine the scope and address Board concerns.
• Motion to table NPRR1190 carries with 29 in favor and one opposed.

• A request was made for any alternative proposals to be filed a week before the November meeting.
• Discussion on NPRR1190 is to continue in the November meeting.

4.1 – ERCOT Presentation – Austin Rosel

NPRR1190 October TAC ERCOT v3.pdf

• Austin Rosel presented the background on the current protocol language of NPRR1190.
• NPRR1190 modifies existing policy set by NPRR649, originally put in place to compensate QSEs for losses from high dispatch limit (HDL) overrides.
• The policy originated from a PUC case involving Odessa and subsequent settlement with ERCOT.
• NPRR649, initially called the “lost opportunity payment,” was finalized in 2016 to cover financial losses due to HDL overrides.
• NPRR1190 extends the coverage to municipalities and entities with both generation and load under the same QSE without requiring a DAM obligation or bilateral contract.
• The TAC recommended approval of NPRR1190, but it faced opposition from the consumer segment, leading to its remand by the ERCOT Board following PUC’s comments.
• Discussion involved ensuring fair compensation for entities affected by HDL overrides, highlighting differences in contractual language and obligations.
• Austin Energy brought this to light through an ADR process, emphasizing inconsistencies in compensating entities without paper contracts.

4.2 – WMS/WMWG Discussion Summary – Eric Blakey

NPRR 1190 Timeline to TAC – Oct 30 2024.pdf

• Eric Blakey from PEC presented a history of the NPRR proposal concerning financial loss recovery due to manual high dispatch limit overrides filed by Austin Energy and other utilities.
• The proposal aimed to recover losses during reduced power output and stimulate discussions about market participation and stakeholder concerns.
• Several meetings were held from September to December with stakeholders’ reviews and alternative approach proposals.
• Residential consumer comments suggested narrowing NPRR1190’s scope for clarity.
• Reliant proposed edits to include QSEs in the scope, highlighting burdensome proof of contract issues.
• Financial harm through ERCOT’s overrides was regularly discussed, focusing on limiting excessive use while considering cost relief.
• Discussions about payment alternatives and consideration of NPRR1190 led to a vote with some opposing votes from consumers and abstentions.
• There were multiple instances of abstention and opposition from consumer segments and other stakeholders during the approval process.
• Impact analysis indicated no significant financial or budget implications from the proposal.
• Discussions continued up to October with consumers expressing concerns about eligibility expansion to various entities without contracts.
• The proposal and its numerous meetings and discussions were acknowledged as valuable for informing TAC and board decisions.
• No significant financial impact was noted historically, however, instances like Winter Storm Uri were cited as potential concerns.

4.3 – Consumer Presentation – Consumer Presenter

• Opposition to NPRR1190 due to it being inconsistent with nodal market principles and rewarding over scheduling that leads to consumer subsidies for inefficient hedging.
• ERCOT market’s adoption of nodal dispatch aimed to prevent paying for undelivered scheduled power, emphasizing fairness and risk of delivery on market participants.
• Discussion on confidentiality issues with transmission system information that affect generator operations and potential penalties.
• Concerns over frequent occurrences of side payments to generators for reliability dispatches, aiming to make price the primary motivation for actions.
• Clarifications sought on the concept of ‘over scheduling’ and its impact on pricing and power delivery.
• Debate over HDL override payments, justified as necessary for reliability constraints that SCED cannot manage.
• Issues regarding the expandability of current protocols to better reflect system pricing challenges.
• Calls to avoid expanding side payments that could undermine market efficiency, emphasizing necessary preplanning for contingencies.

5 – Review of Revision Request Summary/ERCOT Market Impact Statement/Opinions – Ann Boren/ IMM

4-revision-request-summary-103024.pdf

• Some requests tabled, but ERCOT supports all.
• NOGRR264 still pending.
• NPRR1235 has pending impacts; NPRR1180 revised IA no impact.
• NPRR1249 has a $25k-$45k impact.
• Out of 10 requests, 7 are general system/process improvements, 1 is ERCOT board/PUC directive, 1 is regulatory, 1 fall is strategic plan objective 2.
• CFSG reviewed NPRRs; no credit implications found.
• No formal response from IMM received regarding revision requests; IMM has no additional comments beyond earlier stakeholder process.
• TAC requires IMM opinion; captured as no opinion unless comments were filed.
• Bill Barnes expressed preference to IMM ‘no opinion’ over ‘pending’ status.
• Clarification and consistency needed for IMM opinion reporting.

6 – PRS Report – Vote – Diana Coleman

PRS Presentation to TAC 103024.pdf

• Summary update on NPRR1247, with an outlined schedule for ROS and PRS endorsements to hit the December board meeting as requested by commission and ERCOT.

6.1 – NPRR1180, Inclusion of Forecasted Load in Planning Analyses

• Motion to table NPRR1180 added to the combo ballot.
  • IA between $2M and $2.4M
  • NPRR1180 is sponsored by Oncor and involves revisions to commission rules on certification criteria.
  • On September 12, PRS voted to recommend approval of NPRR1180 with amendments from the August 28 comments, with two abstentions.
  • On October 17, it was unanimously voted to endorse and forward to TAC the September 12 PRS report and the October 16 IA .
  • Discussion occurred regarding the high costs and FTE requirements cited by ERCOT, leading to a revised IA for TAC consideration.
  • Additional TCPA comments were also noted.
  • The related agenda item involves publication of shift factors for active transmission constraints, recommended for approval by PRS on September 12 and endorsed on October 17.
  • Discussion on NPRR1180 with revisions and stakeholder comments, especially regarding staffing and related legislation.
  • Concerns raised about additional costs already being incurred by ERCOT, which were addressed in a revised document.
  • Mention of the need for transparent criteria for forecasting and planning related to large load growth to prevent unnecessary transmission build-out.
  • Request to table NPRR1180 is set for the combo ballot after extensive discussion and multiple participant inputs.

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

• Motion to recommend approval of NPRR1245 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
  • No impact IA
  • Proposal to put NPRR1245 into consideration.
  • Focus on clarifying revisions related to Real-Time Co-Optimization.

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

• Motion to recommend approval of NPRR1248 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
  • No impact IA
  • Discussion on NPRR1248 which addresses corrections to the previous NPRR1197.
  • Focus on the optional exclusion of load from netting at EPS (Electric Power Supply) metering facilities that include resources.
  • Clarification on how this correction impacts current metering practices and requirements.
  • Considerations for implementing these corrections to ensure accurate data representation at metering facilities.
  • Potential implications for resource operators and how they integrate with ERCOT’s systems.

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

• Motion to recommend approval of NPRR1249 as recommended by PRS in the 10/17/24 PRS Report added to the combo ballot.
  • On September 12 PRS unanimously voted to recommend approval
  • On October 17 PRS endorsed and forwarded to TAC the September 12 PRS report and the October 15 IA with a priority of 2026 and rank of 4740.

7 – Revision Requests Tabled at TAC – Possible Vote – Caitlin Smith

• Discussion on revision request tables at TAC.

7.1 – OBDRR052, Related to NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era

• OBDRR052 is pending and will remain tabled.
• Awaiting NPRR1246 progress for any developments on OBDRR052.

7.2 – NOGRR264, Related to NPRR1235, Dispatchable Reliability Reserve Service as a Stand-Alone Ancillary Service

• NOGRR264 can remain tabled.
• Awaiting NPRR1235 resolution.

8 – OBDRR053, Alignment with NPRR1131, Controllable Load Resource Participation in Non-Spin, and Minor Clean-Ups – Vote – Nitika Mago

• Motion to recommend approval of OBDRR053 as submitted and the 10/17/24 Impact Analysis added to the combo ballot.
  • OBDRR053 is a follow-up to NPRR1131, which was implemented at the end of August.
  • Changes are needed to the OBD to support NPRR1131’s implementation.
  • OBDRR053 aims for alignment and is said to have no impact.
  • Recommendation for approval of OBDRR053 as submitted along with the October 17 impact analysis.
  • No objections were raised to include this item on the combo ballot.

9 – RMS Report – Debbie McKeever

• RMS is supporting retail market participants for TexasSET 5.0 implementation.
• MarkeTrak SCR817 changes are being prepared for implementation on the weekend of November 9th and 10th.
• A total of 7 market changes will be implemented that weekend.
• Recent completion of flight 0924, a market test flight for testing current market participants for TexasSET 5.0, concluded yesterday at 5 pm.

10 – ROS Report – Vote – Katie Rich

ROS_Update_to_TAC 10 30 24.pdf

• Three voting items will be tabled until accompanying NPRRs are ready.
• Recent ROS actions mentioned; PGRR107 related to NPRR1180 and IA is set to return next Thursday 
• The DWG procedure manual will come back next week with necessary language updates.
• Next ROS meeting scheduled for November 7th.
• Katie encourages review of Luminant comments for PLWG changes; PLWG draft and ERCOT version of comments will be drafted for ROS consideration.
• Aim to finalize discussions next week with PLWG leadership and reach a decision.
• Draft PLWG comments will be posted on the ROS meeting page along with update slides.
• A compromise set of comments would be filed to the NPRR.
• Suggestion to put the three voting items on a combo ballot.

10.1 – PGRR116, Related to NPRR1240, Access to Transmission Planning Information

• Motion to table PGRR116 added to the combo ballot.
  • Awaiting developments on NPRR1240.

10.2 – NOGRR266, Related to NPRR1239, Access to Market Information

• Motion to table NOGRR266 added to the combo ballot.
  • Action pending the outcome of NPRR1239.

10.3 – NOGRR267, Related to NPRR1240, Access to Transmission Planning Information

• Motion to table NOGRR267 added to the combo ballot.
  • NOGRR267 is awaiting NPRR1240 approval.

11 – WMS Report – Eric Blakey

WMS Report To TAC – October 30 2024.pdf

• Discussions on CRR auction due to concerns about allocation incentivizing overconsumption; proposals to be voted on in December.
• Updates on large flexible load interconnection now being presented to TAC.
• Possible need for an NPRR that memorializes reports in protocols while balancing data sharing and customer confidentiality.
• Strong interest in more information on large load queues; discussion needed to balance privacy and insight.
• Parking lot items being reviewed for efficiency; discussion on whether to retain the parking lot.
• Two NPRRs tabled for discussion: NPRR1250 on RPS program termination and NPRR1251 on FFSS fuel replacement cost recovery.
• NPRR1235 discussions consolidated at SAWG; continues to explore its relevance as an operational or resource adequacy tool.
• Stakeholder process noted as essential in fleshing out varied opinions, emphasizing statutory requirements.
• Next WMS meeting scheduled for the 6th of the November.

12 – Credit Finance Sub Group Report – Vote – Brenden Sager

TAC_CFSG_30Oct2024 (002).SD.pdf

• Discussion on changes to estimate aggregate liability, collateral commitment, reporting enhancements, and regular credit updates.
• Implementation of system changes in December 2024 due to NPRR1184 for managing interest received by ERCOT.
• Explanation and discussion of RFAF and DFAF in relation to EAL.
• Introduction of automated notification systems for letters of credit and surety bond matters.
• Austin Rosel, ERCOT, expressed an opinion that CFSG is coalescing around a proposal for changes to exposure calculations; looking for support but not fully resolved.
• A presentation to TAC suggested for broader discussion before implementation.
• Key changes in the EAL calculation focus on netting real-time and day-ahead liabilities.
• Discussion on forward adjustment factors and attempts to reduce volatility and over-collateralization during volatile market events.
• The proposed framework aims to minimize collateral shortages while optimizing over-collateralization.
• Concerns about higher volatility in TPEA addressed and focused on reducing overall collateral costs to the market.
• Regular financial updates showed decreased market TPE and discretionary collateral from $1.88B to $1.72B August to September.

12.1 – Approval of CFSG Membership

• Motion to approve the CFSG membership addition as presented (Brian Kozlowski, Wolframium Power LP, IPM) added to the combo ballot.
  • A new member, Brian Kozlowski, is proposed for the credit finance subgroup.
  • Approval by TAC is required for the new member.

13 – RTC+B Task Force Report – Possible Vote – Matt Mereness

RTCBTF_TAC_Update_10302024.pdf

• Purpose and function of the task force explained, focusing on coordinating timelines, activities, and Market Readiness.
• Approval sought for coordinating market readiness and cutover activities.
• Announced a go-live date of December 5, 2025, for the project.
• Sequence progression outlined, noting nothing changed from last TAC.
• Emphasis on coordinating and gaining consensus on market readiness and transition activities.
• Discussed the importance of Market trials plan for a successful transition in 2025.
• Presented a review of current issues such as AS proxy offer floors and state of charge parameters.
• Highlighted the approach to market readiness, including just-in-time PowerPoint presentations and videos that will act as self serve training.
• Requested endorsement of the Market trials plan after four reviews.
• Identified ongoing discussions regarding ancillary service and energy ramp sharing.
• ERCOT Task Force reviewed NOGRR268, PGRR118, and OBDRR052, relating to battery energy storage details.
• Discussed the completion of ripple effect terminology and issues needing approval before go-live.
• Outlined a new approach to include technical workshops starting in 2025.
• Discussed TAC approved parameters, expressing concerns and plans to include them in formal protocols rather than other binding documents.
• Plan to propose an ‘omnibus’ NPRR to solidify TAC approved parameters for market readiness.

13.1 – Endorse RTC+B Market Trials Plan

• Motion to endorse the RTC+B Market Trials Plan as presented added to the combo ballot.
  • Development of the RTC+B market trials plan resulted in an eight-page document, reviewed four times by the RTC+B task force.
  • Details regarding the low frequency control test were discussed and deferred to the handbook for further clarification.
  • The plan’s language was adjusted without affecting the objective, timing, and criteria; the handbook will detail the implementation process.
  • Participants were satisfied with the plan, which avoided concerns and facilitated recommendations for TAC endorsement.
  • Discussions emphasized the importance of QSEs proper telemetry and production tests to match current systems without needing dummy data.
  • The finalized version of the plan was shared with TAC materials for endorsement, serving as a formal document within ERCOT.
  • The board does not need to approve the document, which remains within TAC’s purview, serving as a reference for resolving future challenges.
  • Training videos and further details will be posted on the RTCBTF meeting page
  • The endorsement process aimed for a combo ballot with no objections, supporting a streamlined approval method.
  • Further deliberation on memorializing TAC-approved parameters and potential removal via NPRRs is anticipated.

14 – Update of Stakeholder Process and Communication Discussion – Caitlin Smith

• Improved communication aspects are being worked on.
• Commission staff, including Barksdale, plan to participate in meetings.
• Efforts to include subcommittee information at the board level were discussed.
• Presentation on stakeholder process was given at R&M; looking for future topics.
• Discussion on ERCOT responses or filings to have oppositions before board presentation.
• Analyzed other ISOs’ TAC duties, responsibilities, and representation.
• Some improvements might require TAC procedure or board bylaw changes.
• Board might be working on ideas, possibly with the PUC.
• Hoping to have Chairman Flores in upcoming TAC meetings.
• Further discussion on ideas requiring document changes is needed.

15 – ERCOT Reports

15.1 – AEPSC Brownsville Area Improvements Transmission Project – Possible Vote – Prabhu Gnanam

Brownsville_Area_Improvement_Regional_Planning_Group_Project_EIR_TAC_October_2024.pdf

• Motion to endorse AEPSC Brownsville Area Improvements Transmission Project – Option 2A added to the combo ballot.
  • Introduction of the AEP Brownsville Area Improvement Project, a Tier 1 project estimated at $387.7 million.
  • The project addresses thermal and voltage issues in Brownsville, Cameron County, and requires a CCN.
  • Discussions on thermal issues including 100 miles of 138kV line overloads and existing transformer overloads under various conditions.
  • Evaluation of eight alternatives to address thermal and voltage issues, with Option 2A being least cost and addressing operational concerns.
  • Option 2A involves building 26 miles of new right of way, estimated at $423.8 million.
  • SSR screening concluded no adverse impacts due to existing or proposed generation resources.
  • Congestion analysis identified issues, but no additional upgrades met economic criteria.
  • Recommendation to endorse Option 2A to address reliability needs, with implementation by May 2029 at $423.8 million.
  • Project plan includes building new circuits and stations, involving new and existing 138kV and 345kV lines.
  • Proposal includes adding a 150MW statcom at the Xiaomei 138kV station.
  • Discussion about endorsing Option 2A on the combo ballot.

15.2 – Reduce per CRRAH Transaction Limit – Possible Vote – Matt Mereness

TAC-CRR-CMWG_10302024.pdf

• Motion to approve a CRR Account Holder transaction limit for all Long-Term Auction Sequences of 3,000 added to the combo ballot.
  • Matt Mereness discussed reducing the per CRRAH transaction limit due to frequent oversubscriptions.
  • Suggested lowering the current limit from 4,000 to 2,800, or 3,000, to mitigate oversubscription frequencies.
  • The proposal aims to address system constraints and improve auction performance.
  • Discussion on whether the change is temporary or permanent; Matt indicated it as temporary until other solutions are implemented.
  • Concerns were raised about applying this solution to all auction sequences equally.
  • ERCOT reported performance improvements following software upgrades but mentioned limitations remain.
  • There was a preference among some participants for more comprehensive communication regarding system limitations.
  • Proposal to adopt the new limit immediately was met with support from participants seeking market stability.
  • A motion to adopt the reduced limit was proposed and supported, indicating a move towards a formal vote.

15.3 – ERCOTs Framework for Evaluating Market Design – Keith Collins

KCollins Market Design Framework – TAC.pdf

• Framework for evaluating market design was initially presented at the BOD meeting in August. Aim is to present it in other forums including TAC.
• Mission of ERCOT includes ensuring reliability and efficient electricity markets.
• Importance of using appropriate tools (design and market tools) for different tasks to achieve reliability and competitive market objectives.
• Need to adjust strategies for changing energy landscape, including increased solar, storage, and wind resources.
• Framework should assist decision-makers in understanding initiative goals and outcomes, avoiding inefficiencies.
• Importance of considering flexibility, dependability, availability, resiliency, and efficiency in market design.
• Feedback from prior presentations included questions about resource adequacy, initiative measurement, and framework alignment.
• Encouragement for submitting feedback to TAC, with suggestions for improving the framework through community input.
• Framework under construction; aims to balance reliability, consumer cost, and efficiency without over-engineering.
• Discussion highlighted importance of consumer cost, political feasibility, and avoiding over-engineering in market solutions.

15.4 – Large Load Interconnection Status Update – Chris Cosway

LLI Queue Status Update – 2024-10-30.pdf

• Significant increase in standalone large load project requests over the past 12 months.
• Queue has grown by over 5 GW despite some project cancellations.
• Projected growth of nearly 13 GW between 2027-2028.
• A significant number of project requests are under review to approve or modify.
• 1,771 MW of large loads approved to energize over the past year.
• Total of 5,697 MW approved to energize.
  • 3,055 MW in load zone West; 2,642 MW in other zones.
  • 4,622 MW consist of standalone projects; 1,075 MW co-located.
  • Of the 5,697 MW, non-simultaneous peak consumption is 3,514 MW.
• Observed simultaneous peak consumption of 2,815 MW.
• Simultaneous peak value discussion and considerations for presenting monthly values.
• Concerns mentioned about confidentiality in data presentation.

• Question from Evan Neal, Lancium, on simultaneous and non simultaneous peak values.
• Evan Neal suggests some loads might have reduced consumption.
• Consideration for providing simultaneous peak monthly values in future reports.

16 – Other Business

• Mention of the commencement of membership segment elections.

16.1 – 2025 ERCOT Membership / Segment Representative Elections – Suzy Clifton

• Date of record is this coming Friday, 11/02/24.
• Membership applications and fees should be completed.
• Election process starts on Tuesday, November 5th.
• Reminders and notices have been sent to segments.
• Election notice will be sent out on November 5th.

16.2 – TAC Procedure Improvements – Caitlin Smith

• Caitlin Smith and Cory Phillips discussed improving the TAC procedure by considering a consolidated redline version of documents for easier readability.
• The idea is to simplify documents by consolidating numerous redline changes into a single, coherent version, while preserving authorship recognition.
• Past issues, such as with NOGRR245, involved complex and multicolored documents that were difficult to process, often requiring extensive time and effort.
• Cory and Caitlin are exploring options to modify current procedures and potentially amend Section 21, allowing TAC leadership discretion to consolidate document redlines for more efficient processing.
• The proposal aims to make the comment review process streamlined and user-friendly, without losing authorship clarity.
• Richard Ross  expressed a view that there is nothing prohibiting the use of a consolidated version. TAC’s adoption makes it legitimate, and individual redlines can still be referred to if necessary.
• There is room for revising Section 21 if needed, and these considerations will be addressed in upcoming NPRR discussions.
• No final decisions were made, but Cory and Caitlin will continue to refine the proposal and present it in future NPRR sessions.

17 – Combo Ballot – Vote – Caitlin Smith

• The motion to approve the combo ballot carried unanimously.