Meeting Summary – 11/14/24 PRS Meeting

1 – Antitrust Admonition – Diana Coleman

2 – Approval of Minutes – Vote – Diana Coleman

2.1 – October 17, 2024

• Motion to approve the October 17, 2024, PRS Meeting Minutes as presented added to the combo ballot.

3 – TAC Update – Diana Coleman

• TAC approved three proposals: NPRR1245, NPRR1197, and NPRR1249.
• NPRR1180 was tabled by TAC and will be reconsidered with PGRR107.
• TAC decision on NPRR1180 is pending until PGRR107 progresses.

4 – Project Update – Troy Anderson

prs_november_2024_project_update.pdf

• Major projects have been added back as requested.
• Working on FTE analysis for a future meeting.
• Ideas to improve capacity for revision requests are being considered.
• November updates: Second Part of 1205 and 1218 for the REC program went live, and Texas SET was smoothly implemented.
• NPRR1231 is going live tomorrow, as notified in market notices.
• December updates include: wrapping up NPRR1217, final piece of SCR799 relating to export functionality, and some RIOO updates in NPRR1184.
• PGRR082 part of December release; PGRR088 moved to January.
• Reporting on projects is aligned with Matt Mereness’ RTC reporting.
• Major project slide updated for RTC go live in late 2025, and stabilization into 2026.
• NPRR1023 with CRR on hold for process improvements.
• Discussion about future projects DRRS and PCM, less resource demanding compared to RTC.
• NPRR1219 concerning CDR not explicitly noted; will be addressed offline.
• DRRS implementation project might start in Q4 2025, not going live then.
• December go-live target for NPRR945 on the 18th.
• Revised IAs and priorities/ranks posted for discussion in future agenda items.
• TWG meets monthly for technical discussions; technical teams are encouraged to participate.
• Acknowledgments for ERCOT and market participants for successfully implementing Texas SET.

5 – Review PRS Reports, Impact Analyses, and Prioritization – Vote – denotes no impact – Diana Coleman

• Four items are up for impact analysis and prioritization: items 1239 and 1240 have revised Impact Assessments.
• The goal is to move reports from the secure portion of ERCOT to the public-facing webpage.

5.1 – NPRR1239, Access to Market Information

• Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/29/24 Revised Impact for NPRR1239 with a recommended priority of 2025 and rank of 4540 added to the combo ballot.
  • Costs for NPRR1239 and time requirements for project implementation were presented.
  • Costs to build out APIs were removed to be aligned with other ERCOT API work in 2025 for efficiency.
  • The initiative seeks to convert 63 reports from secure to public status.
  • Implementation will depend on potential impacts with RTC, with hopes to progress in parallel.
  • Priority was adjusted from 26 to 25, aiming for completion in 2025, with a consistent rank as both items will be handled together.

5.2 – NPRR1240, Access to Transmission Planning Information

• Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/29/24 Revised Impact for NPRR1240 with a recommended priority of 2025 and rank of 4540 added to the combo ballot.
  • Discussion on combining NPRR1239 and NPRR1240 on the combo ballot.
  • Consensus reached with no objections noted.
  • Acknowledgment and confirmation to add items 1239 and 1240 to the meeting minutes.

5.3 – NPRR1246, Energy Storage Resource Terminology Alignment for the Single-Model Era*

• Motion to endorse and forward to TAC the 10/17/24 PRS Report and 7/31/24 Impact Analysis for NPRR1246 added to the combo ballot.
  • Discussed NPRR1246 regarding Energy Storage Resource (ESR) terminology alignment.
  • Preparation for RTC initiative scheduled for next year.
  • No costs associated with the implementation.
  • Previous unanimous vote to recommend language approval.
  • Acknowledged amendments by September 20th ERCOT comments.

5.4 – NPRR1254, Modeling Deadline for Initial Submission of Resource Registration Data*

• Motion to endorse and forward to TAC the 10/17/24 PRS Report and 10/2/24 Impact Analysis for NPRR1254 added to the combo ballot.
  • Final topic from ERCOT discussed was regarding the modeling deadline for initial submission of resource registration data.
  • Proposal to modify the timeline by extending it one month.
  • Purpose is to allow ERCOT and resource entities time to ensure submissions are error-free.
  • No cost or project is associated with this change.

6 – Revision Requests Tabled at PRS 

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

• Discussion on NPRR1200 focused on utilizing calculated values for non-wholesale storage load for Energy Storage Resources (ESRs).
• Item was previously discussed at the Wholesale Market Subcommittee (WMS) last week.
• A motion was made to revisit this item in the next month and to bring it to the Metering Working Group.
• The Metering Working Group has a scheduled meeting on the 20th where further discussions on NPRR1200 are expected to take place.

6.04 – NPRR1202, Refundable Deposits for Large Load Interconnection Studies

• WMWG has been reviewing this agenda item.
• Comments were filed after last month’s PRS meeting.
• Decision needed on whether those who filed comments want to address them or keep the item tabled.
• Reminder noted that if item remains tabled, no immediate action is required.

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

• CMWG is still reviewing NPRR1214 for an additional month.
• The item will be reconsidered by WMS in December.
• Joint comments were filed earlier in response to ERCOT’s August 9 comments.

6.06 – NPRR1226, Demand Response Monitor

• Technology Working Group will be addressing NPRR1226.
• Further discussions are expected in the next PRS meeting on NPRR1226.

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

• Comments were filed on NPRR1229.
• Bill Barnes provided an update on agenda item 1202 and 1234.
• ERCOT expressed a desire to move forward with item 1234 while continuing to address concerns with 1202.
• Proposal to combine fee structures from Longhorn comments on 1202 with 1234.
• ERCOT is interested in the idea of combining components from the two.
• Comments have been shared with ERCOT staff regarding the potential combination.
• PRS members informed about the ongoing discussion regarding the integration of components.

6.08 – NPRR1234, Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater

• ERCOT filed some comments earlier in the week regarding NPRR1234.
• Conversations about these comments are ongoing and expected to continue between 1202 and 1234.

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

• NPRR1235 was initially tabled in June and referred to ROS and WMS.
• The item remains tabled at SAWG awaiting possible PUC discussion.
• The item is also still under discussion at WMS.
• Recent comments were filed by Luminant for NPRR1235.
• Ongoing discussions are taking place regarding NPRR1235.

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

• Comments were submitted by Steel Mills regarding the definition for VECL sat the end of last month.
• WMS may take action on these comments.
• Further developments are anticipated in December.

6.13 – NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities

• Motion to recommend approval of NPRR1243 as amended by the 10/10/24 ERCOT comments added to the combo ballot.
  • Oncor filed comments proposing a streamlined notification process for ERCOT disclosures to FERC, NURC, and TRE.
  • No new comments were filed on NPRR1243, and the committee considered moving the Oncor comments forward on a combo ballot.
  • There was discussion about the language concerning compliance premiums not being awarded after December 31, 2024, and the potential need for an earlier effective date.
  • Introduction of a new concept of a research and innovation partner by ERCOT, with suggestions to provide visibility into shared information via a website.
  • Oncor’s initial concerns about transparency in information disclosure were addressed through a compromise solution.
  • A suggestion was made to strike the use of ‘fax’ from notification methods, aligning with modern communication practices.
  • Doug Fawn flagged a future NPRR to clean up standard form agreements regarding fax notification, projected for January.

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

• Motion to grant NPRR1247 Urgent status; to recommend approval of NPRR1247 as amended by the 11/11/24 ERCOT comments; and to forward to TAC NPRR1247 and the 8/9/24 Impact Analysis carries: 86% approval 13% opposition and 4 abstentions.

• NPRR1247 concerns a congestion cost savings test discussed extensively since it was filed in August.
• The proposal was approved at ROS with 11 abstentions and several no votes due to contentions over protocol references.
• ERCOT prefers revising the NPRR description rather than including references to two related white papers in protocol language.
• A special planning group workshop and several comments have been considered in the development of NPRR1247.
• Urgency is required to proceed with NPRR1247 due to its significant impact on congestion cost savings.
• Matt Arthur from ERCOT filed comments on Nov 11 recommending revisions in the revision description referring to two supporting white papers.
• ERCOT’s stance on white papers is that they are non-binding documents providing operational details without stakeholder approval, differing from binding protocol language.
• Martha Henson expressed support for keeping NPRR1247 out of protocol references and motioned for its urgency and approval, which was seconded.
• Comments were shared expressing concerns about the expedited process and potential suboptimal outcomes, including issues unresolved concerning the generation-load gap in models.
• Stakeholders expressed a desire for further discussion on related white papers, which ERCOT commits to addressing in future discussions.

6.15 – NPRR1250, RPS Mandatory Program Termination

• Motion to recommend approval of NPRR1250 as submitted added to the combo ballot.
  • The item 1250 was tabled in September and referred to WMS, which unanimously endorsed it as submitted.
  • Discussion was held about adding 1250 to the combat ballot.
  • Concerns were raised about the effective date of the RPS program termination, with some feeling it needs to be sooner.
  • The termination date of the RPS program is defined by HB1500, not ERCOT, and set for September 1st.
  • Procedural steps for NPRR were discussed, with a hope for approval before September 1st.
  • Concerns about confidentiality provisions not being removed before the program’s termination were addressed, emphasizing the importance of not exposing information before deletion of the program.

6.15b – NPRR1250, RPS Mandatory Program Termination

• Discussion on NPRR1250 regarding the termination of RPS Mandatory Program.
• Reference to compliance premiums will not be awarded after December 31, 2024, as stated in NPRR1218.
• NPRR1218 already includes the language regarding compliance premiums which is in force.
• Clarification and confirmation that NPRR1250’s language echoes NPRR1218.
• Addressed concerns related to repetition of language from NPRR1218.
• Explanation that NPRR1250’s language modifications will be “gray boxed” until September 1, 2025.
• Language about premiums expiring on December 31, 2027, is the new addition.
• Consensus to proceed with NPRR1250 in a combo ballot.

6.17 – NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements

• Motion to recommend approval of NPRR1252 as amended by the 11/8/24 ERCOT comments added to the combo ballot.
  • Acknowledgment of pending cleanup next year.
  • Mention of ERCOT’s November 8th comments regarding this item.
  • Discussion on integrating NPRR1252 with the November 8th comments.

6.18 – NPRR1253, Incorporate ESR Charging Load Information into ICCP

• Motion to recommend approval of NPRR1253 as amended by the 10/10/24 ERCOT comments added to the combo ballot.
  • WMSWG is still reviewing NPRR1253.
  • The item was tabled last month to allow the sponsor time to file comments.
  • Awaiting comments from the sponsor before proceeding.

6.19 – NPRR1255, Introduction of Mitigation of ESRs

• General agreement from past discussions to not implement until after RTC.
• For NPRR1255, Caitlin requested to table it due to a longer implementation outlook and agreed to provide more details by the next PRS meeting.
• There is consensus to keep NPRR1255 tabled until comments are filed or comfort with ERCOT is established.
• NPRR1253 was discussed within the Wholesale Market Working Group, but its official status is unclear as it is not tabled with ROS.
• TIEC had questions on NPRR1253 but is now open to moving it forward as their questions were addressed.
• NPRR1253 needs to be in effect by June 1, with a version of language recommended for approval.
• Discussion on NPRR1253 included the October 10th ERCOT comments related to Patterson and Company’s proposal, aiming to clean up references to prices and data.
• Further cost analysis for NPRR1253 to be done as indicated by Mr. Whitmire.

7 – Review of Revision Request Language – Vote – Diana Coleman

7.1 – NPRR1256, Settlement of MRA of ESRs

• Motion to table NPRR1256 and refer the issue to WMS added to the combo ballot.
  • Introduction of NPRR1256, concerning settlement MRA for energy storage resources.
  • This item is being introduced by ERCOT and it is the first time it is being discussed at PRS.
  • No representative from ERCOT present to speak on the proposal.
  • Consideration to table and refer the item for further review.
  • Suggestion for PRS and WMS to examine and verify the proposal.
  • The item relates to protocol language updates needed for energy storage resources.
  • Current protocols use generation resource language which needs adaptation for the integration of energy storage resources as a single model.
  • Potential updates to MRA language to reference generation resources or energy storage resources.
  • Mathematical validations required, possibly by WMS.

7.2 – NPRR1257, Limit on Amount of RRS a Resource can Provide Using Primary Frequency Response

• Motion to table NPRR1257 and refer the issue to ROS added to the combo ballot.
  • This proposal originated from recommendations by a consultant, GE, to address the risk of common mode failure, which could lead to NERC requirements violations.
  • A static limit derived from studies conducted by ERCOT is proposed, with a recommended limit of 157 megawatts per resource.
  • The limit applies per resource and not per station, with each resource expected to have independent controls to mitigate risks from common mode failures.
  • There are companion NOGRR documents providing detailed application instructions for the proposed limit.
  • Some concerns were raised on regulatory certainty and changeability of the limit number, but these were addressed collaboratively with ERCOT.
  • Questions were raised regarding the application of the limit: 20% of HSL or 157 megawatts for thermal resources, and verified droop performance for batteries.
  • Recommendation to table this NPRR for further discussion and consideration by the ROS and PDCWG.

7.3 – NPRR1258, TSP Performance Monitoring Update

• Motion to recommend approval of NPRR1258 as submitted added to the combo ballot.
  • Removal of duplicative language in section 8.3 and section 3.
  • Clarification on requirements for submissions to ERCOT via the common information model to follow a defined naming convention.
  • The submission system automatically rejects non-compliant naming conventions, reducing the need for additional performance monitoring.
  • Monitoring program viewed as redundant and potentially pose compliance risks.

7.4 – NPRR1259, Update Section 15 Level Response Language

• Motion to table NPRR1259 and refer the issue to RMS added to the combo ballot.
  • Clarification that retail transaction response timing requirements are not included for planned and approved retail system outages.
  • Consideration to table and refer the item to RMS for further review.
  • Discussion on the need for additional clarification on approval by the TAC Subcommittee regarding ERCOT planned outages.

8 – Other Business – Diana Coleman

• Discussed possibility of not having PRS meeting in December as there will not be a December TAC meeting
• January PRS meeting is scheduled prior to the TAC meeting.
• NPRR1151 allows cancellation of monthly PRS meetings.
• Concern raised about skipping the December meeting as new NPRRs are available for discussion.
• If December meeting is skipped, certain NPRRs would be delayed to future meetings.
• Productivity noted with end-of-year NPRRs and filing deadlines approaching.
• Suggestion to consider using Webex or alternate options for December meeting if needed.

9 – Combo Ballot – Vote – Diana Coleman

• Motion to approve combo ballot carries unanimously 

10 – Adjourn – Diana Coleman