Meeting Summary – PLWG 11/12/24 Meeting

1 – Antitrust Admonition – Chair

2 – Agenda Review – Chair

3 – Review of PLWG Meeting Minutes – Oct 16 & Oct 29 – Chair

• Confirmed October 16th and 28th meeting minutes as final with no additional comments or questions.

4 – General updates – Chair

• Key issues and developments affecting ERCOT were highlighted.
• The Chair emphasized the importance of current and upcoming initiatives.
• Stakeholders were encouraged to stay informed and contribute feedback.
• Brief mention of operational strategies adapting to changing demands.

4.1 – At the Nov 7 ROS meeting, the following occurred

4.1.1 – ROS referred PGRR120 to PLWG

• ROS referred PGRR120 to PLWG for discussion.
• The topic will be covered in the morning meeting.

4.1.2 – ROS voted to approve PGRR117 – ERCOT comments 101124

• ROS voted to approve PGRR117.
• Approval was based on ERCOT comments dated October 11th.

4.1.3 – ROS voted to approve NPRR1247 – ERCOT comments 102324

• ROS voted to approve NPRR1247.
• Approval was based on ERCOT comments posted on October 23rd.

4.2 – Leadership 25 update

• Leadership turnover typically occurs around October and requires a vote at ROS.
• Opportunity highlighted for interested parties to engage in a rewarding leadership position in ROS.
• Encouragement for individuals who have not participated in ROS leadership to consider the opportunity.
• Discussion on taking agenda item PGRR115 out of order due to scheduling conflicts.
• Introduction and fast-paced review of PGRR120 SSO Prevention and Generation for interconnection, newly assigned to PLWG.
• Presentation feedback from a previous ROS meeting was mentioned for further discussion.

5 – PGRR115 – related to NPRR1234 – Interconnection Requirements for Large Loads and Modeling Standards for Loads 25 MW or Greater – PLWG

5.1 – ERCOT Comments TBD – ERCOT

• ERCOT filed comments on NPRR1234 and PGRR115, introducing a new concept requiring updates in protocols.
• Clarified definition for ‘initial energization’ related to generation resource interconnections, making it applicable to both new and modified resources.
• Introduction of a new defined term, ‘Transmission service bus,’ to address maximum load criteria of 1000 megawatts from a single bus.
• Comments address load commissioning plans, clarifying requirements and stability assessments.
• Clarifications on load inclusion in QSA, ensuring it’s tied to loads undergoing commissioning processes.
• Obligations for TSPs specified regarding submission and updating of dynamic load models.
• TSP compliance clarification related to customer behavior and transmission system limitations.
• Discussion around the maximum allowable load from a single transmission point due to frequency stability concerns.
• Two-pronged approach: introducing a load limit of 1000 megawatts from a single point and planning criteria to prevent losing more than 1000 megawatts in a single contingency.
• Addressing feedback from entities like ERCOT Steel Mills and Oncor to incorporate suggestions into ERCOT’s revisions.
• Planning further analysis to potentially adjust the 1000 megawatt limit based on study outcomes.
• Comments on some proposals, such as AEP’s, were considered but not largely adopted due to differing approaches.
• Requests for more review time before finalizing PGRR115 to ensure all stakeholder concerns are considered.

6 – PGRR119 – PGRR119, Stability Constraint Modeling Assumptions in the Regional Transmission Plan – PLWG

6.1 – 119PGRR-05 OPUC Comments 110624

• ERCOT planning clarified that the reliability margin mentioned in OPUC comments is not intended to be created anew in the RTP process, but rather to be used consistent with current operating procedures.
• Alex Miller  from EDF discussed the misunderstanding around the modeling of operating limits, emphasizing the modeling should reflect real-world limits and not just posted limits.
• There was discussion on whether this PGRR is intended to capture similar concepts as in NPRR1070, specifically about modeling GTCs as they occur in reality.
• ERCOT planning confirmed the intention to apply real-world stability limits and address similar concerns as in NPRR1070.
• Alex Miller suggested including the impact of outages on D rates in the PGRR to improve clarity.
• ERCOT planning explained ERCOT’s discretion in applying additional analysis and benefits under PUC substantive rule, relating to outage-related benefits.
• There was a proposal for offline discussions to further explore methodologies for modeling outages related to GTCs.
• ERCOT’s filed comments for NPRR1247 highlighted a white paper addressing weather uncertainty and transmission outages, though it wasn’t specific to stability constraints.
• It was noted that GTCs are uniquely challenging within ERCOT, requiring clarity for stakeholders about modeling processes.
• Discussion on ERCOT’s different activation procedures for IROL and SOL based on stability limits, with reliability margins noted as 10% or 15% depending on the limit type.
• The PGRR119 was tabled previously pending comments, and OPUC’s comments were discussed with a view to move the discussion forward in ROS.
• There were thoughts on possibly refining language for transparency and clarity, with Alex intending to file written comments if needed.

7 – PGRR120 – SSO Prevention for Generation Interconnection – ERCOT

06-november_ros_sso_prevention_pgrr120

• Series compensated circuits: Discussed the ownership and installation timelines, highlighting TSP and non-TSP owned locations.
• Explanation of SSO: Defined subsynchronous phenomena, including SSR, SSCI, and SSFR, and outlined mitigation efforts.
• Past SSR events: Reviewed occurrences since 2009, including forced outages and mitigation attempts, particularly in South Texas.
• PGRR120 proposal: Aims to prevent new generation projects from interconnecting in a manner that renders them radial to a series capacitor.
• Impact on existing projects: Clarified the effect on ongoing projects and the process for new and existing projects, potentially hindering some from continuing if screen checks are not completed in time.
• Real-time SSO mitigation: ERCOT’s ability to prohibit operations if real-time SSO is detected.
• Project screening and check stage: Emphasized on topology checks as part of the interconnection process to ensure compliance with the PGRR.
• Discussion on future transmission fix: Debated if TSPs should seek transmission solutions to allow new generation connections despite series caps.
• Inverter OEM discussions: Mentioned ongoing considerations with OEMs regarding resonance prevention.
• Complexity in addressing SSR: Highlighted difficulties in mitigation even when approved measures are in place or generators maintain compliance.

Questions and Comments:

• Monica Jha, Vistra: Question: Permanency of generation restriction near series caps if transmission fixes are made?
• Mina: Question: Requested more detailed information on 2023 SSR events.
• Nicholas Jalabar with RWE: Comment: Discussion on mitigating series compensation by grid infrastructure upgrades.
• Brett Rollo with Green Belt Renewables: Question: Clarification on alternatives if screening study isn’t completed before PGRR implementation.
• Freddie and Megan, various participants: Discussion: Concerns around new resources and SSR mitigation effectiveness, including historical issues.

Action Items:

• ERCOT to take back questions regarding topology checks for existing projects.
• Consider providing detailed statistics on potentially impacted generation capacity by proximity to series capacitors.
• Ensure communication availability for reviewed processes in Interconnection protocols.

8 – NERC Topics Roundtable – future topics – PLWG

• Discussion on ongoing topics related to NERC roundtable.
• Focus on future topics for PLWG.

8.1 – CIP-014-4 – Physical Security

• Discussion on CIP-014-4 physical security revisions at the NERC level.
• The latest ballot for CIP-014-4 failed again.
• The drafting team plans to review comments and issues, especially with R2 and R3.
• A new red line version will be posted for the next ballot.

8.2 – TPL-008 – Transmission System Planning Performance Requirements for Extreme Temperature Events

• Discussion on TPL-008, which concerns transmission system planning for extreme temperature events.
• A ballot vote comment period is open until November 21st for feedback to NERC.
• This is the fourth version of the draft TPL-008, associated with project number 202307.
• The draft includes requirement documents, technical rationales, responses to comments, and examples of benchmark extreme cold and heat events.
• Significant changes have been made to address industry feedback.
• The requirement to file TPL-008 with FERC is by December 15, based on order 896.
• The ballot needs a 67% approval rate to pass, and the last approval rate was 58%.
• Participants expressed appreciation for input from two standard drafting team members.
• Discussion included open action items, particularly the use of big L, little L in the Planning Guide.

9 – Review Open Action Items – Chair

• Consideration of a working draft approach to revise sections of the planning guide during each meeting.
• Discussion on managing workload by revising sections one at a time, particularly the data and modeling section with numerous load references.
• Bob Wittemeyer suggested a slower approach by revising the wording with each PGRR revision instead of an overall review.
• Alex Miller inquired about the frequency of load references and the areas needing adjustment in the planning guide.
• Aaron Gutierrez discussed different revision request options: PLWG could submit a request, draft could be sent to ROS, or a market participant could sponsor it.
• Concerns about potential length and complexity of a full planning guide revision were discussed, with examples of similar past processes.
• Consensus to proceed by addressing one section at a time in meetings to ensure manageability and currency of changes.
• The possibility of scheduling discussions at the end of the agenda to allow participants to opt out if desired was suggested.

10 – Other business – Chair

Brief overview of activities conducted:

• Discussion on PGRR120 – First reading of the SSO for generation single contingency outage revision requests; tabled for further discussion.
• Discussion on PGRR115 – Tabled for one month with a goal to finalize in December; coordination with Bill and Agee required to address comments.
• Discussion on PGRR119 – Consensus reached within PLWG; will be taken back to ROS for further action..

11 – Adjourn – Chair