Meeting Summary – 11/06/2024 WMS Meeting

1 – Antitrust Admonition – Eric Blakey

2 – Agenda Review – Eric Blakey

3 – Approval of WMS Meeting Minutes – Eric Blakey

• Approval of WMS meeting minutes discussed.
• Catch-up on meeting minutes presented.
• September 11th and October 7th meeting minutes shown.
• No comments received on the meeting minutes.

3.1 – September 11, 2024

• Motion to approve the September 11,2024 WMS meeting minutes as submitted, added to the combo ballot.

3.2 – October 7, 2024

• Motion to approve the October 7, 2024 WMS meeting minutes as submitted added to the combo ballot combo ballot.

4 – Technical Advisory Committee Update – Eric Blakey

• Main topic was NPRR1190, a protocol change remanded back to TAC from the board in October.
• The proposal was tabled for future discussion next month.
• Congestion revenue rights auction will have transaction limit changed to 3,000 due to high volume and complexity; approved by TAC.
• Real Time Co Optimization group plans market testing to start on May 5th with a target go live date of December 5th next year.
• NOGRR245 update provided on implementation; next steps will be addressed through PUC rulemaking.
• Discussion led by Eric Goff on NPRR to memorialize the large load interconnection report; received general support from TAC.
• Suggestion to review and possibly disaggregate data for consumer transparency without compromising confidentiality.
• Bill Barnes voiced support and mentioned a potential concept to keep HDL override costs in check to address consumer concerns.
• Acknowledgment of ongoing efforts to make NPRR1190 palatable to all groups.

5 – ERCOT Operations and Market Items

5.1 – 2024 Q3 Unregistered Distribution Generation – Dan Mantena

05-2024-q3-unregistered-distributed-generation-dg-report-wms-update.pdf

• Dan Mantena presented the Q3 strategy report update.
• Total distribution generation (DG) reported for Q3 is over 2,700 MWs.
• Second report excluding DG battery energy storage presented, currently at 73 MWs.
• There was a 6 MW increase from the previous quarter.
• Overall, there was 81 MW of growth from Q2 to Q3.

5.2 – 2024 Q3 Settlement Stability Report- Judy Luu

05-wms_settlement-stability-report_q3_2024.pdf

• Presentation of the 2024 Q3 Settlement Stability Report by Judy Luu from the ERCOT Settlements team.
• No price changes for Q3.
• Resettlements due to non-price errors caused by an EPS meter being incorrectly stopped from November 15th to December 12th, 2023.
• 100% of disputes up to Q3 have been resolved timely.
• Percent changes between initial to final and final to true up settlements discussed.
• Real-time and day-ahead market average, median, maximum, minimum, and total charges from 2011-2024 presented.
• Load volume availability percentage for ESIID consumption data and ESIID count availability percentage highlighted.
• Net allocation to load in millions for settlement areas from September 2023 to September 2024 discussed.
• Securitization default and uplift charges for the last 13 months presented.
• Discussion on the EPS meter issue and corrective measures taken, with Randy Roberts explaining the mistake and three measures implemented to prevent future occurrences.

5.3 – CDR Mockup and NPRR1219 Implementation – Pete Warnken

• The mockup was presented at the Supply Analysis Working Group meeting, with main changes focusing on effective load carrying capabilities and the unit details table.
• The executive summary will have a standard reporting format with both text and graphics, focusing on the first five years where data is more reliable.
• CDR will only report for five years, and load forecasts beyond that will be separated as resource information is unreliable.
• New format will divide resource reports into four seasonal tabs with separate peak load hour information.
• New line items include distribution voltage reduction and restructured inverter-based resources information.
• Planned unconfirmed retirements will now impact reserve margin calculations.
• The unit details will now be presented in a flat file format, similar to the generation interconnection status report.
• CDR status will use column markers to label resource statuses and new categories for mothballed units.
• Plans include consolidating capacity reports into a single table for all seasons.
• New tables will list resource additions and installed capacity by fuel or technology type, including a breakout for battery storage by duration.
• Discussions about load forecasts are ongoing, with no firm decision yet regarding non-contracted loads.
• Documentation will include acronym lists and a tab mapping counties in the ERCOT region to wind and solar regions.
• A methodology document will be provided for additional details.
• Attendees expressed appreciation for the work done and the improvements over the previous format.

6 – Congestion Management Working Group – Alex Miller

06-cmwg-update-2024-11-wms.pdf

• CMWG meeting held on October 14th.
  • Focus: Methodology for setting transmission shadow price caps.
  • Update: First month of implementation data discussed; example from August 19th reviewed.
  • Impacts:
    • Increased congestion cost.
    • Increased system lambda.
  • Ongoing: Will continue updates as more data becomes available.
  • Issues: Solution time issues noted.
  • Strategies:
    • Administrative guardrails being pursued.
    • Minimum bid prices and unawarded bid fees are paused while exploring alternative options for market incentives.
    • Increase system performance by examining the removal of the multi-month product.
  • Ongoing Studies:
    • Pricing report option to reduce price discovery participation.
    • New TOU super peak obligation to avoid some option bidding.
  • Future Plans: Expect NPRR introduction for changes.
  • Objective: Reliability deployment price adder fix for locational price signals.
  • Updates:
    • Draft comments posted.
    • Main changes address ERCOT feedback.
    • Stakeholders had limited feedback.
  • Potential Vote: May come to WMS for a vote.
  • NPRR1230
  • CRR Long Term Auctions
  • NPRR1214

7 – Supply Analysis Working Group – Greg Lackey

07-20241106_supply-analysis-working-group-update-to-wms_v2.pdf

• Presented SAWG’s agenda from October including long-term load forecast, discussion on NPRR1235, and NPRR1219 implementation / December CDR preparation.
• Updates to load, economic, large flexible load, electric vehicle, and rooftop PV forecasts were discussed.
• Discussion on timing of long term load forecast updates with a final release expected between March and early April.
• Issues around NPRR1235 including using DRRS as a resource adequacy tool, with staff mentioning filing comments.
• IMM’s position on NPRR1235, including advocating for real-time procurement and co-optimizing DRRS.
• DRRS designed as an operational reliability product rather than for resource adequacy.
• Upcoming SAWG meeting on November 22nd to further discuss NPRR1235 and its components.
• Potential delay of implementing DRRS until real-time co-optimization is feasible.
• Mention of a need to satisfy statutory real-time procurement requirements and concerns regarding incentivization for offline units to stay offline.
• Discussion on consideration of timeline extensions to meet statutory requirements.

8 – Wholesale Market Working Group – Blake Holt

08-wmwg-update-to-wms-of-october18-meeting.pdf

• Reviewed aging open action items from WMS; members instructed to identify important items or otherwise recommend removal.
• Discussed the minimal pricing impacts due to LDL overrides on April 8th eclipse.
• Anticipated discussions for NPRR1229 Real-Time CMP energy payment and NPRR1241 with potential new language from Luminant scheduled for December.
• Explored the consideration of wholesale storage load in ERCOT’s load forecasts relating to NPRR1253, with follow-up materials expected by December.
• In-depth discussion on NPRR1202 regarding refundable deposit of large load interconnection studies; mixed responses from market participants.
• ERCOT staff expressed support for expediting the interconnection process but disagreed with NPRR1202’s additional fee proposal.
• Debated tabled items and the possibility of incorporating discussed concepts into an NPRR.
• Intended to educate members for a vote next month while avoiding deep discussions during the meeting.

8.1 – Proposed Changes to CARD Allocation Methods

1. WMWG update on CARD and CRRBA allocation options.pdf

• Adverse Incentive in CARD Allocation
  Details: Concerns were raised about an adverse incentive in the CARD and CRR balancing account allocation methodology. Loads ramp up in peak intervals to capture more revenue.
• Proposal Highlights
  Details: Three proposals from IMM, City of Georgetown Utilities, and Vistra were presented for consideration with a voting planned in December.
• IMM Proposal
  Details: The IMM proposal suggests allocation based on the peak 500 hours each month, with pros being reduced incentives to change load consumption to increase CARD revenue and cons being a shift of revenue from residential to industrial loads.
• City of Georgetown Proposal
  Details: Recommended using the same allocation as Transmission Cost of Services (TCOS), aligning CRR benefits with transmission cost incentives. The pros include alignment with transmission incentives, while cons include calculation lag and separation from transmission costs.
• Vistra Proposal
  Details: Vistra suggests averaging the Load Ratio Share (LRS) realized in the top 60 hours for the month along with the top 4 hours of the top 15 peak days for the month, aimed at reducing change in load consumption incentives but considered more complex than the IMM approach.
• Concerns and Suggestions
  Details: Several stakeholders expressed support for compromise solutions and debated the pros and cons of each proposal with specific attention to market price distortion and equity in allocation.
• Next Steps
  Details: Engagement with ERCOT and IMM for further discussion, stakeholder examination of zonal allocation implications, and stakeholders acknowledged the hard work of proposal development.

9 – WMS Revision Requests Tabled at WMS – Eric Blakey

• Discussion of WMS revision requests that are currently tabled.
• Eric Blakey presented the status of these revision requests.
• The focus of the discussion was on determining the next steps for these requests.

9.1 – SMOGRR028, Add Series Reactor Compensation Factors

• The NOGRR28 has been at MWG.
• There is a suggestion to keep the item tabled as the MWG has not met.
• No additional comments were made on the agenda item.

9.2 – VCMRR042, SO2 and NOx Emission Index Prices Used in Verifiable Cost Calculations

• Introduction of VCMRR042 regarding SO2 and NOx emission index prices.

9.3 – NPRR1242, Related to VCMRR042 SO2 and NOx Emission Index Prices Used in Verifiable Cost Calculations

• VCMRR042 and related NPRR1242 were tabled and referred to RCWG (Reliability and Compliance Working Group).
• The RCWG has not yet met, thus no action is required at this moment.
• Comments will be filed in advance of the RCWG meeting.
• The goal is to progress after the comments are filed and reviewed.

10 – Revision Requests Tabled at PRS and Referred to WMS – Eric Blakey

10.01 – NPRR1070, Planning Criteria for GTC Exit Solutions

• NPRR1070 was previously discussed at PRS.
• Eric Goff made comments regarding NPRR1070 at PRS.
• Discussion focused on potentially removing the item.
• Eric Goff requested input from the IMM.
• Historical context mentioned an IMM report from two to three years ago, recommending action on NPRR1070.
• Unclear future actions on NPRR1070; reviewing options.
• Meeting participants asked to review the NPRR and provide feedback.
• Decision pending further review and input.

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

• NPRR1200 has been tabled for about 14 months, introduced to expand the usage of calculated values for certain energy storage resources.
• The NPRR1200 proposes extending a provisional exception from 2020 to allow use for series reactors, considering complex layouts or high design costs.
• The Metering Working Group  showed preference for SMOGGR028, deemed a more technically sound approach compared to NPRR1200.
• No scheduled meetings for MWG currently, but ongoing discussions are still active.
• Some stakeholders believe a MWG meeting should occur to resolve and make progress on SMOGRR028 before potentially rejecting NPRR1200.
• There were technical issues associated with NPRR1200, but it remains active in case SMOGGR028 discussions stagnate.
• Kara Beckmann from Nextera expressed concerns about the timing and readiness of NPRR1200 for a vote without MWG discussions.
• Plan suggested for MWG to meet, discuss NPRR1200 and SMOGGR028, and provide updates next month.
• Following discussions, meetings may be scheduled possibly by December to advance the issues further.
• Feedback expressed disappointment for the lack of urgency to resolve the matter, urging that discussions should happen to push forward.

10.03 – NPRR1202, Refundable Deposits for Large Load Interconnection Studies

• Longhorn power desires to accelerate NPRR1202’s approval.
• TCPA supports the acceleration, while TIC raised concerns about Longhorn’s suggestion aligning with cost causation principles.
• Concerns about speculative interconnection requests making the queue unmanageable.
• Longhorn’s proposed fees may not match with costs needed to serve large loads.
• Concerns over prioritizing interconnections based on commercial agreements, which may contradict non-discriminatory access principles.
• Discussions are ongoing in legislative contexts rather than at the PUC.
• No consensus reached; debate over pursuing the proposal aggressively versus waiting for policy direction.
• ERCOT prefers NPRR1234, highlighting concerns with integrating fees and hiring staff due to budget constraints.
• Alternatives like using funds for contractors during peak times have been suggested.
• Balancing fee adjustments, possibly enhancing upfront fees and avoiding recurring charges, debated.
• Some members supportive of NPRR1202 concept to ensure ERCOT has necessary resources.
• Unresolved need for an interconnection fee to expedite the queue for economic development purposes.
• Recommendation to consider passing NPRR1234 and observe its effects before deciding further on NPRR1202.

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

• Joint comments were filed regarding this agenda item.
• The discussions on NPRR1214 at CMWG are believed to be exhaustive with no further questions raised.
• The decision was made to keep NPRR1214 tabled at CMWG for further discussion and review.

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

• New comments have been filed in the past few days.
• The plan is to revisit the discussion at a future meeting.
• Discussed the connection between NPRR1190 and previous ideas on capping uplift costs.
• Clarified that openness to discussing caps on uplift costs applied to NPRR1190
• Consideration of caps on spending for different types of generators.

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

• NPRR1235 was discussed with the SAWG and will remain tabled.

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

• Discussion began with an update request on the status of comments regarding NPRR1238.
• Joe Dan Wilson from GSEC sought information on ERCOT’s comments.
• Comments were initially filed by steel mills; concerns include whether wholesale issues are resolved.
• Blake mentioned that earlier pricing concerns were withdrawn, and no further market concerns exist.
• Some operational concerns persist and are being addressed on the ROS side.
• Katie Rich supported moving the discussion forward since issues were cleared at WMS/OWG leadership’s level.
• There’s an interest in getting ERCOT’s pending comments to finalize discussions and remove tabled items.
• The group considers deferring action to allow ROS to consolidate further discussions.
• Chair and vice chair to prepare for potential voting on unresolved items in the next month’s meeting.

10.08 – NPRR1241, Firm Fuel Supply Service Availability and Hourly Standby Fee

• Blake’s report indicates Luminant is working on language for the next WMWG.
• The item will remain tabled until further development.

10.09 – NPRR1250, RPS Mandatory Program Termination

• Motion to endorse approval of NPRR1250 as submitted added to the combo ballot.
  • NPRR1250 concerns the termination of the RPS mandatory program.
  • The item was tabled in the last meeting and has statements to move forward.
  • ERCOT met with Eric Goff and reached an agreement to proceed with voting.
  • Comments were called to address the concern of language effect upon program termination.
  • The termination date is set for September 1, 2025.
  • No recent comments have been added; the latest ERCOT comments provided no red lines.

10.10 – NPRR1251 Updated FFSS Fuel Replacement Costs Recovery Process

• The item has been referred to the Resource Cost Working Group.
• The RCWG has not yet met regarding this matter.
• A discussion on this item is planned for November 15th.
• No additional tabled items related to this agenda point were mentioned.

11 – Combo Ballot – Eric Blakey

• Motion to approve the Combined Ballot as presented passed unanimously.
  • Motion to approve the September 11,2024 WMS meeting minutes as submitted.
  • Motion to approve the October 7, 2024 WMS meeting minutes as submitted.
  • Motion to endorse approval of NPRR1250 as submitted.

12 – Other Business – Eric Blakey

12.01 – Review Open Action Items – Jim Lee

• David Maggio asked about the incorporation of battery charging load into the load forecast.
• Blake mentioned coordinating with David to include this in the WMS agenda, potentially in December.
• Encouragement for participants to protect items important to them in the open action items list.
• Reminder that nominations are underway among all segments and participation in committees is important.
• Acknowledgment of the great talent and participation of volunteers at ERCOT.

12.02-12.4 – Not Discussed

13 – Adjourn – Eric Blakey

• The next meeting is scheduled for December 4th.