Meeting Summary – 12/12/2024 – PRS Meeting

1 – Antitrust Admonition

2 – Approval of Minutes

2.1 – November 14, 2024

• Motion to approve the November 14, 2024, PRS Meeting Minutes as presented added to combo ballot.

▶️ 3 – TAC Update – Diana Coleman

• Several items were sent to TAC for consideration; four were approved.
• NPRR1246 was approved by TAC but remanded by the board.
• NPRR1246 involves ESR terminology alignment for the single model era.
• ERCOT Legal identified language cleanup needed due to NPRR1188 passage.
• ERCOT will review and address the language issue in NPRR1246.

▶️ 4 – Project Update – Troy Anderson

prs_december_2024_project_update.pdf

• No major updates this month; next year will include updates on FTE information and post RTC revision request prioritization.
• The 2026-2027 ERCOT budget is in progress, considering funding for future revision requests post-RTC go-live.
• Recent project implementations include NPRR1231 tweaks and discontinuation of VDI related to NPRR1217.
• Expected project completions include export functionality for SCR799 and the move for NPRR1183 reports.
• NPRR1184 and related PGRRs go live; NPRR945 target moved to January.
• Slide updates show NPRR and RTC timelines without major changes, with focus on holiday month challenges.
• TWG meetings occur monthly with focus on RTC and other technical aspects.
• A question from Alex about NPRR1198 and NPRR258, both with a 2025 priority, was raised without a definite answer at the time.

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

▶️ 5.1 – NPRR1243, Revision to Requirements for Notice and Release of Protected Information or ECEII to Certain Governmental Authorities*

• Motion to endorse and forward to TAC the 11/14/24 PRS Report and 7/24/24 Impact Analysis for NPRR1243 added to combo ballot.
  • This involves revisions to the requirements for notice and release of protected information.
  • The focus is on information release to certain governmental authorities.
  • The discussion aimed to better define what constitutes protected information.

▶️ 5.2 – NPRR1250, RPS Mandatory Program Termination*

• Motion to endorse and forward to TAC the 11/14/24 PRS Report and 8/27/24 Impact Analysis for NPRR1250 added to the combo ballot.
  • No cost associated

▶️ 5.3 – NPRR1252, Pre-notice for Sharing of Some Information, Addition of Research and Innovation Partner, Clarifying Notice Requirements*

• Motion to endorse and forward to TAC the 11/14/24 PRS Report and 8/28/24 Impact Analysis for NPRR1252 add to combo ballot.
  • No costs associated

▶️ 5.4 – NPRR1253, Incorporate ESR Charging Load Information into ICCP

• Motion to table NPRR1253 added to the combo ballot.
  • Request was made to PRS to table NPRR1253.
  • Decision to revisit NPRR1253 based on updates expected from Troy in January.

▶️ 5.5 – NPRR1258, TSP Performance Monitoring Update*

• Motion to endorse and forward to TAC the 11/14/24 PRS Report and 10/29/24 Impact Analysis for NPRR1258 added to combo ballot.
  • Discussion on NPRR1258, originating from ERCOT with no associated costs.

▶️ 6 – Revision Requests Tabled at PRS – Possible Vote – Diana Coleman

6.01 – 6.02

• Not Discussed

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

• NPR1200 is being withdrawn.

▶️ 6.04 – NPRR1202, Refundable Deposits for Large Load Interconnection Studies

• Engie filed comments in support of NPRR1202.
• The issue is still under discussion at WMS and WMWG.
• There is strong stakeholder support for NPRR1202, with recent comments filed by Engie.
• ERCOT staff have concerns but support advancing NPRR1234.
• Bill Barne’s suggestion to move fee concepts from NPRR1202 to NPRR1234 to advance the entire package.
• Doug Fawn from ERCOT Legal has convened internally and plans to discuss fee concept with stakeholders soon.
• Participation in upcoming discussions expected from stakeholders with interest in transitioning NPRR1202 fees to NPRR1234.

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

• NPRR1214 was discussed at the CMWG and WMS meetings earlier this month.
• Conversations ongoing.

▶️ 6.06 – NPRR1226, Demand Response Monitor

• Ongoing meetings with Mark Patterson and Floyd Trefny regarding NPRR1226.
• Potential to integrate NPRR1226 into another revision request.
• ERCOT’s legal team was unavailable for comment review before the meeting.
• Plan to revisit NPRR1226 at the January PRS meeting to assess further developments.

6.07 

• Not Discussed

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

• PLWG will discuss NPRR1234’s related PGRR next week.
• Ongoing discussions are happening at various working groups regarding NPRR1234.

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

• NPRR1235 is still under active discussion
• IMM filed comments at the end of November, with further discussion expected in the January PRS meeting.
• Current focus is on understanding potential compliance implications from IMM comments.
• Clarification provided that IMM should discuss their comments during the SAWG meetings as the main discussions are happening there.

6.10

• Not Discussed

▶️ 6.11 – NPRR1241, Firm Fuel Supply Service – FFSS – Availability and Hourly Standby Fee

• WMWG reached consensus this week on NPRR1241.
• They will report to WMS on their endorsement with 12/03 Luminant comment.
• Potential update expected in January.

▶️ 6.12 – NPRR1251, Updated FFSS Fuel Replacement Costs Recovery Process

• Motion to recommend approval of NPRR1251 as amended by the 12/5/24 WMS comments carried unanimously with 1 abstention from the Consumer segment.
  • Melissa raised a question about the necessity of the fuel oil index price.
  • Eno explained that the fuel oil index price is used when resources utilize existing fuel inventories rather than purchasing new fuel.
  • The price is capped using the fuel oil index to address difficulties in verifying past purchase costs.
  • Resource entities can choose to replace utilized fuel or recover costs based on past purchases, but reimbursement for past purchases is capped.
  • Discussion clarified that new fuel purchases are reimbursed at actual costs, whereas past fuel amounts are limited to the fuel oil index price.
  • No further questions or concerns were raised about NPRR1251.

▶️ 6.13 – NPRR1255, Introduction of Mitigation of ESRs

• Caitlin Smith requested that NPRR1255 be tabled again this month. ERCOT and stakeholders have been having productive offline discussions regarding NPRR1255.
• The NPRR deals with the mitigation of ESRs, and stakeholders are generally comfortable with the framework.
•  Discussions include:
  • Addressing commitment to ancillary services and the state of charge preservation.
  • Exploring options like setting a floor on offers for mitigation to consider opportunity costs.
  • Considering whether there should be a state of charge threshold where mitigation would not apply.
• Jupiter might file comments by January based on progress in discussions. No action is required currently, and the item remains tabled for flexibility in further discussions.

▶️ 6.14 – NPRR1256, Settlement of MRA of ESRs

• WMS requested to continue tabling NPRR1256 to allow WMWG further review.
• WMWG will revisit NPRR1256 in January.

▶️ 6.15 – NPRR1257, Limit on Amount of RRS a Resource can Provide Using Primary Frequency Response

• Motion to recommend approval of NPRR1257 as submitted added to the combo ballot.
  • ROS unanimously approved NPRR1257 earlier in the month.
  • The item might be ready for further actions or decisions.
  • Consideration for adding NPRR1257 to a combination or agenda list.

▶️ 6.16 – NPRR1259, Update Section 15 Level Response Language

• Motion to recommend approval of NPRR1259 as amended by the 12/10/24 RMS comments added to the combo ballot.
  • NPRR1259 was unanimously endorsed by RMS.
  • A retail system outage approved by a tax subcommittee was included in the endorsement.
  • The motion on the combo ballot is to recommend approval of NPRR1259 as amended by the December 10 RMS comments.
  • No action has been taken on either system change request.

▶️ 6.17 – SCR826, ERCOT.com Enhancements

• No update.

▶️ 6.18 – SCR827, Grid Conditions Graph Addition for Operating Reserve Demand Curve – ORDC – Level

• No update.

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

• Discussion on NPRR1260 initiated by ERCOT to reinstate language inadvertently removed when NPRR863 was approved.

▶️ 7.1 – NPRR1260, Corrections for CLR Requirements Inadvertently Removed

• Motion to recommend approval of NPRR1260 as submitted added to the combo ballot.
  • There were no objections or concerns raised about NPRR1260.

▶️ 7.2 – NPRR1261, Operational Flexibility for CRR Auction Transaction Limits

• Motion to recommend approval of NPRR1261 as submitted added to the combo ballot.
• The purpose of NPRR1261 is to provide more operational flexibility by modifying CRR transaction limits.
• Samantha Finley from ERCOT explained the need for differentiating transaction limits among auction types to accommodate varying network capacities.
• The new transaction limits are intended to prevent issues with hitting limitations and to solve auction processes more efficiently.
• Bill Barnes expressed curiosity about the extent of the benefits but supported moving the NPRR forward.
• There was consensus among the members about the positive impact and readiness to proceed with NPRR1261.
• CMWG and WMS have extensively discussed the issue, leading to a positive perception of the increased transparency and flexibility.
• DC Energy filed comments in support of NPRR1261, particularly appreciating ERCOT’s engagement with CMWG.

▶️ 7.3 – NPRR1262, Ancillary Service Opt Out Clarification

• Motion to table NPRR1262 added to the combo ballot.
• NPRR1262 is aimed at providing clarity to address litigation concerns related to a patent claim involving Bitcoin mining and CLRs by Lancium.
• Lancium has raised objections, preferring ongoing negotiations outside ERCOT’s public process due to potential litigation risks.
• Matt Arth from ERCOT Regulatory Council supports tabling further discussions to understand implications and consider different stakeholder perspectives.
• Bill Barnes expressed concerns about the impact on CLR market participation and requested more details on Lancium’s patent claims.
• ERCOT has engaged in discussions with Lancium, Cholla, and the Blockchain Council to explore implications of the patent claim and potential licensing without committing to agreements.
• Suggestions include delaying the issue’s table until the first quarter, allowing a thorough understanding to be developed by involved parties.
• There are concerns about whether protocol clarifications could inadvertently involve intellectual property issues outside of ERCOT’s purview.
• Clayton Greer emphasized that NPRR is a clarification for transparency, not a policy change, aimed at preventing market participation hesitance.
• Tabling NPRR1262 will provide more time to address legal interpretations and clarify ERCOT’s stance without impacting reliability or stakeholder responsibilities.

▶️ 7.4 – SCR828, Increase the Number of Resource Certificates Permitted for an Email Domain in RIOO

• Motion to recommend approval of SCR828 as submitted added to the combo ballot.
  • Request from NextEra Energy to increase the number of resource certificates for an email domain in the RIOO system.
  • Current limit of 23 certificates poses challenges for larger market participants.
  • Proposal from Zach Reich, ERCOT, to increase the limit to at least 50 certificates, with suggestions to increase to 100.
  • Discussion of system limitations and costs associated with increasing the certificate limit.
  • Agreement on the need for an IA before deciding on the exact number.
  • Acknowledgment of similar past requests and the need for a practical and economically viable solution.

▶️ 8 – Notice of Withdrawal – Diana Coleman

▶️ 8.1 – NPRR1242, Related to VCMRR042, SO2 and NOx Emission Index Prices Used in Verifiable Cost Calculations

• NPRR1242 was withdrawn and PRS does not need to vote on it.
• The sponsors are free to withdraw as PRS never recommended approval.
• Notification was given to prevent any confusion about its removal from the tabled items list.

▶️ 9 – Other Business – Diana Coleman

▶️ 9.1 – ERCOT Dashboard Roadmap – Amy Lofton

mp-guide-for-dashboard-roadmap.pdf

• ERCOT is developing a roadmap for dashboard implementation, with a target for completion in 2025.
• The purpose of the roadmap is to capture recommendations from various stakeholders and establish a formal process for introducing new dashboards and making changes to existing ones.
• A form likely hosted on ServiceNow will allow stakeholders to submit requests, which will then be evaluated for broad stakeholder value, data availability, duplication of effort, and long-term viability.
• The process includes impact analysis and project prioritization to assess costs, resource availability, and potential conflicts with ongoing projects.
• The process will involve transparency and the ability for stakeholders to track the progress of their requests.
• Concerns were raised about potential frequent changes to the dashboards and the need for a formal approval process involving stakeholders.
• It was suggested that stakeholder feedback should be incorporated into the process, possibly via public forums or direct input opportunities.
• Additional dialogue suggested an existing protocol revision request process could be used to incorporate stakeholders’ opinions, but ERCOT maintains dashboards are courtesy postings not formally required.
• Stakeholders expressed a desire for more transparency and input, specifically regarding rejected requests and the overall decision-making process.
• ERCOT confirmed intentions for transparency and stakeholder notification during implementation phases, but specifics of stakeholder appeal or feedback integration were not fully defined.

▶️ 10 – Combo Ballot – Vote – Diana Coleman

• Motion to approve the combined ballot as presented carries unanimously with no abstensions.

▶️ 11 – Adjourn – Diana Coleman