WEBVTT 00:00:07.578 --> 00:00:13.569 (item:59:Chairwoman Jackson concludes Closed Session, Open Meeting resumed) The Closed Session is hereby concluded at 11:32 on November 00:00:13.579 --> 00:00:17.039 30, 2023 and the Commission will resume its Public 00:00:17.048 --> 00:00:20.420 Meeting. Having discussed litigation matters in Closed 00:00:20.429 --> 00:00:23.359 Session. (item:59:Motion to approve mediated settlement) I will now entertain a motion for the following 00:00:23.370 --> 00:00:27.199 action to approve the mediated settlement of alleged 00:00:27.208 --> 00:00:32.240 underpayments of TUSF amounts reached on November 00:00:32.250 --> 00:00:36.939 3, 2023. As reflected in the mediated settlement agreement 00:00:37.139 --> 00:00:42.759 of that date in AMA Communications, LLC dba AMA 00:00:42.859 --> 00:00:48.579 Tactel Communications versus the PUC. So moved. Second. 00:00:49.289 --> 00:00:52.359 I have a motion and a second. All in favor, say aye. 00:00:52.429 --> 00:00:56.709 Aye. Motion passes. We will now resume our agenda with 00:00:56.719 --> 00:00:58.310 Item No. 33. 00:01:01.969 --> 00:01:07.418 (item:33:Chairwoman Jackson lays out Project No. 54445) Next up is Item No. 33, Project No. 54445. This 00:01:07.430 --> 00:01:10.290 is the Commission's project for rules adopted by ERCOT. 00:01:10.859 --> 00:01:17.888 Um specifically, we're addressing NPRR1184, NPRR1186 00:01:17.900 --> 00:01:23.430 and SCR824. Shelah, do we have anyone from the 00:01:23.439 --> 00:01:28.180 public signed up to speak? No, ma'am. PUC Staff filed 00:01:28.189 --> 00:01:31.150 a memo in a proposed order and Commissioner Glotfelty 00:01:31.159 --> 00:01:34.109 filed a memo. We'll have Staff come up first and provide 00:01:34.120 --> 00:01:36.879 an overview of their recommendations. And then Commissioner 00:01:37.338 --> 00:01:39.579 Glotfelty, you can lay out your memo. So could you 00:01:39.588 --> 00:01:41.579 please state your name for the record? 00:01:45.540 --> 00:01:50.069 Harika Basaran, Staff. Ramya Ramaswamy, Commission Staff. (item:33:PUC Staff's Harika Basaran on memo, ERCOT stakeholder process and NPRRs) I just make two quick 00:01:50.079 --> 00:01:53.989 comments and then Ramya will take over. One of the questions 00:01:54.000 --> 00:01:57.349 I have. Can you move your microphone up there? Do you 00:01:57.359 --> 00:02:01.698 have any questions on the memo? Other than NPRR1186 00:02:01.709 --> 00:02:05.088 NPRR1184 and SCR824. 00:02:07.150 --> 00:02:09.929 I do not. Okay. Thank you. The other thing, I just want to give 00:02:09.939 --> 00:02:13.219 a high level if the you have market analysis covers the 00:02:13.288 --> 00:02:18.020 ERCOT stakeholder process and what we do to monitor NPRRs. 00:02:18.460 --> 00:02:22.338 whenever we receive a notice from notice from ERCOT and NPRR has 00:02:22.349 --> 00:02:26.014 been filed. I immediately assign it to a Staff member 00:02:26.274 --> 00:02:29.213 and throughout the life of the NPRR. We monitor and 00:02:29.224 --> 00:02:32.883 track it and if there is big issue items like this 00:02:32.895 --> 00:02:37.903 one, we make sure Staff contacts ERCOT SAPs, market participants 00:02:37.913 --> 00:02:43.149 IMM and so that we are all knowledgeable on the different 00:02:43.159 --> 00:02:46.149 issues. So we don't take this recommendation lightly 00:02:46.159 --> 00:02:49.229 We want to make sure, you know, we are uh knowledgeable 00:02:49.240 --> 00:02:51.699 in the matter as much as we can before we make our 00:02:51.710 --> 00:02:54.868 recommendations. And as you know, we are also trying 00:02:54.879 --> 00:02:57.879 to elevate our technical expertise like Commissioner 00:02:57.889 --> 00:03:00.699 Glotfelty mentioned like meeting with Siemens, meeting 00:03:00.710 --> 00:03:03.750 with research institute, institute. So we are trying 00:03:03.758 --> 00:03:07.069 to do a lot to elevate our detailed understanding of 00:03:07.080 --> 00:03:11.669 this very complex issues. And then we also meet before 00:03:11.679 --> 00:03:14.588 Board Meeting before we file these recommendations 00:03:14.599 --> 00:03:17.750 with, with my Staff and with Connie we look all of the 00:03:17.758 --> 00:03:21.538 NPRR for approved and what staff we recommend. So 00:03:21.550 --> 00:03:24.229 we have all this process and we are trying to improve 00:03:24.240 --> 00:03:26.580 all that. That's all I wanted to say. Thank you. 00:03:29.588 --> 00:03:32.149 (item:33:PUC Staff's Ramya Ramaswamy on NPRR1186) Good morning Commissioners. Good morning Chair. So 00:03:32.159 --> 00:03:37.250 1186 is here in front of us today. Um where because 00:03:37.258 --> 00:03:41.490 of the rapid growth of batteries that we have in the 00:03:41.558 --> 00:03:44.479 ERCOT portfolio, which is a fantastic problem to have 00:03:44.490 --> 00:03:47.710 We definitely need them and they provide us very good 00:03:47.719 --> 00:03:52.199 reliable service. And we also learned from ERCOT that 00:03:52.210 --> 00:03:57.288 over 14 gigawatts of batteries could be interconnecting 00:03:57.300 --> 00:04:04.460 in 2024. That requires situational awareness for our 00:04:04.469 --> 00:04:10.149 control room operators to understand, to monitor and 00:04:10.159 --> 00:04:13.819 also have visibility into the capabilities that the 00:04:13.830 --> 00:04:19.298 batteries can bring to us at any time. 1186 requires 00:04:19.309 --> 00:04:22.699 USEs to telemeter state of charge of the batteries 00:04:23.019 --> 00:04:26.358 which are committed to providing ancillary services 00:04:26.369 --> 00:04:31.629 and energy in real time. As yulian pointed out in their 00:04:31.639 --> 00:04:36.928 comments, um all resources including DSRs are required 00:04:36.939 --> 00:04:41.100 to comply with all our compliance metrics put in place 00:04:41.139 --> 00:04:45.689 by our rules and by the protocols. 1186 does place 00:04:45.699 --> 00:04:50.899 obligation on the QSE to ensure resource level SOC 00:04:50.910 --> 00:04:54.759 compliance which is above and beyond what is required 00:04:54.769 --> 00:04:58.738 by other resources, other dispatchable resources in 00:04:58.750 --> 00:05:02.540 our ERCOT portfolio. That requirement was put in place 00:05:02.548 --> 00:05:04.970 because batteries are a unique 00:05:06.778 --> 00:05:11.759 resource with unique characteristics and SOC, the state 00:05:11.769 --> 00:05:17.459 of charge does allow ERCOT control room to have real 00:05:17.470 --> 00:05:22.079 time visibility on the capa the capability of what 00:05:22.088 --> 00:05:24.548 the battery can provide us in real time. 00:05:27.139 --> 00:05:32.939 But the QSC who is managing the battery at the time 00:05:33.000 --> 00:05:38.059 that it is providing, the resource can still transfer 00:05:38.069 --> 00:05:42.500 the as obligation from one of their qualified resource 00:05:42.509 --> 00:05:46.588 to another qualified resource within their portfolio 00:05:46.608 --> 00:05:52.059 Similar to how the QSE can transfer between say two 00:05:52.069 --> 00:05:57.869 natural gas units. Further, it is also Staff's opinion 00:05:58.588 --> 00:06:02.488 that with all the enhanced awareness and understanding 00:06:02.500 --> 00:06:06.970 of the capabilities of the batteries, ERCOT should reconsider 00:06:06.980 --> 00:06:10.519 the AS eligibility criteria for DSRs that have been 00:06:10.528 --> 00:06:15.048 put in place by uh NPRR1096 which is the 00:06:15.298 --> 00:06:19.088 two hour and four hour requirement. The additional 00:06:19.100 --> 00:06:24.059 requirements that 1186 requires battery should allow 00:06:24.500 --> 00:06:29.329 ERCOT with their better understanding to treat batteries 00:06:29.338 --> 00:06:33.009 similarly to how other dispatchable resources are being 00:06:33.019 --> 00:06:39.269 treated today. Staff is requesting 1186 be passed 00:06:39.500 --> 00:06:41.540 Please do let me know if you have any questions. 00:06:46.619 --> 00:06:46.899 (inaudible) 00:06:48.619 --> 00:06:50.250 Do we have any questions? How would you like to proceed 00:06:51.949 --> 00:06:52.420 as Staff? Jimmy has memo, 00:06:54.119 --> 00:06:56.730 Commissioner Glotfelty. Or do you want to ask questions to the Staff? Do you want 00:06:56.759 --> 00:06:57.410 me to lay it out? 00:06:58.928 --> 00:07:01.319 May I pose a question in that way it will carry over 00:07:01.329 --> 00:07:04.879 to ERCOT as well, Madam Chair. That might help set the 00:07:04.889 --> 00:07:07.639 table. Boy, it might be the last time I say that. 00:07:09.899 --> 00:07:15.220 Ramya, in your layout you said that under 1186. 00:07:15.230 --> 00:07:18.040 And we're talking about 1186. And, and if you could 00:07:18.048 --> 00:07:21.428 when you answer. (item:33:Commissioner McAdams' question on QSE designations) Clarify, what's in 1186 and then 1209 00:07:21.439 --> 00:07:23.988 follow on policy considerations as it stands today. 00:07:24.000 --> 00:07:27.088 So we know what's, what. If you could take a swing at 00:07:27.100 --> 00:07:28.048 it? But we'll get Dan Woodfin. 00:07:30.278 --> 00:07:30.928 Um 00:07:32.629 --> 00:07:39.410 you said that a QSC can designate an alternate resource 00:07:40.040 --> 00:07:45.579 on state of charge compliance? No, you did not. Okay. 00:07:45.588 --> 00:07:48.569 So this is a foundational distinction. Discharge. 00:07:50.088 --> 00:07:54.369 That's correct. (item:33:Ramya Ramaswamy clarification on QSE and ancillary services) What I said was a QSE can still 00:07:54.379 --> 00:07:57.119 transfer AS obligation. 00:07:59.379 --> 00:07:59.459 AS. Correct. Ancillary. Ancillary Services. 00:08:02.309 --> 00:08:07.259 I apologize. Yes, so performance obligations. Not state to state a charge. Okay. I asked an answer 00:08:07.269 --> 00:08:07.829 Thank you Madam Chair. 00:08:10.358 --> 00:08:14.048 Okay. Do we have any other questions of Staff? I don't at this 00:08:14.059 --> 00:08:15.420 time. I would prefer that 00:08:17.470 --> 00:08:19.449 Commissioner Glotfelty lay out his memo, and then we can deliberate and ask questions. (item:33:Commissioner Glotfelty lays out his memo) Thank you Madam 00:08:19.459 --> 00:08:23.379 Chair. In my memo, I lay out the reasons why I'm opposed 00:08:23.389 --> 00:08:31.819 to 1186. And I might say that this discussion uh and 00:08:31.829 --> 00:08:35.268 the back and forth with Staff in my opinion, has been 00:08:35.278 --> 00:08:39.038 hugely valuable to be able to have the discussion with 00:08:39.048 --> 00:08:43.067 Staff from two different perspectives to learn and 00:08:43.077 --> 00:08:45.148 to figure out how we're going to make this market better. 00:08:45.158 --> 00:08:47.827 So I'm very appreciative that even though we, we're 00:08:47.837 --> 00:08:49.918 falling on two different sides of this issue is that 00:08:49.928 --> 00:08:52.817 we can have these civil conversations. It's really 00:08:52.827 --> 00:08:55.648 really important that, that, that we continue to have 00:08:55.658 --> 00:09:01.769 these in a nutshell. Um I do in a nutshell. There's 00:09:01.779 --> 00:09:04.029 no evidence that this is needed or solves an actual 00:09:04.038 --> 00:09:06.808 problem in the market to enhance reliability. There 00:09:06.820 --> 00:09:10.928 have been no reliability problems from batteries. There's 00:09:10.940 --> 00:09:13.210 been no evidence provided by ERCOT that this has been 00:09:13.219 --> 00:09:17.399 a problem and I have asked for evidence that this has 00:09:17.408 --> 00:09:21.158 been an issue and have not received any second. It's 00:09:21.168 --> 00:09:23.969 totally discriminatory against batteries, the most 00:09:23.979 --> 00:09:26.489 flexible resource that we have on our system today 00:09:26.889 --> 00:09:29.149 and one that will likely get us through the cold winter 00:09:29.158 --> 00:09:30.509 which we're fearful about. 00:09:33.859 --> 00:09:37.210 We've committed to support policies that are nondiscriminating 00:09:37.450 --> 00:09:40.200 discriminatory and help sustain our competitive markets 00:09:40.340 --> 00:09:42.808 And this, in my opinion does not pass the test. It 00:09:42.820 --> 00:09:44.908 is discriminatory against batteries 00:09:47.418 --> 00:09:50.178 primarily from the sense that we are. 00:09:52.058 --> 00:09:56.590 Oh, let me finish reading. I get ahead of myself. Does 00:09:56.599 --> 00:10:00.849 NPRR attacks, attacks flexibility. Which is the very thing that 00:10:00.859 --> 00:10:04.908 we need in the ERCOT system today. Like I've said, 00:10:04.918 --> 00:10:07.830 we don't need to make everything look like a coal plant 00:10:09.639 --> 00:10:12.548 We should be able to understand the benefits of these 00:10:12.558 --> 00:10:16.168 flexible resources without having penalty structures 00:10:16.269 --> 00:10:20.739 that are disproportionately challenging to that resource 00:10:21.649 --> 00:10:25.548 NPRR1186 is the only protocol that would penalize 00:10:25.558 --> 00:10:27.029 a generator for bidding wrong. 00:10:29.359 --> 00:10:31.798 Not a performance penalty, but a bidding penalty. 00:10:34.029 --> 00:10:37.690 (item:33:Commissioner Glotfelty on compliance concerns) And finally, from numerous people fearful that the 00:10:37.700 --> 00:10:41.820 discussion of NPRR that's happened at ERCOT and within 00:10:41.830 --> 00:10:47.798 the TAC and within the ranks of this process have been 00:10:47.808 --> 00:10:50.759 victims or are fearful of compliance, investigations 00:10:50.769 --> 00:10:54.590 from ERCOT, solely for their opposition to this. And 00:10:54.599 --> 00:10:57.190 I don't think that can stand. I don't think that that 00:10:57.200 --> 00:11:00.099 is an appropriate way for a market to function. I don't 00:11:00.109 --> 00:11:02.330 know if it's true. I will stand here and tell you, 00:11:02.340 --> 00:11:06.440 I don't know. But I have heard from many people that 00:11:06.450 --> 00:11:09.250 they are fearful to stand up for this for what's right 00:11:09.259 --> 00:11:11.519 what they think is best for batteries because they 00:11:11.529 --> 00:11:17.149 are fearful of retribution from, from ERCOT. And, and 00:11:17.158 --> 00:11:19.239 I think that's something that we need to nip in the 00:11:19.250 --> 00:11:21.739 bud right now and say that can't stand in this market 00:11:24.928 --> 00:11:28.489 I laid out options for us to consider today. Four, 00:11:28.500 --> 00:11:31.038 I didn't, I didn't throw out a problem and just complain 00:11:31.048 --> 00:11:33.869 about it. I laid out four ideas that I thought we could 00:11:34.119 --> 00:11:37.979 discuss in our process. My preferred one is to vote 00:11:37.989 --> 00:11:41.859 this down, deny the NPRR and request that batteries 00:11:41.869 --> 00:11:45.349 work with ERCOT on state of charge issues so that ERCOT 00:11:45.359 --> 00:11:47.889 can learn how batteries operate to the benefit of our 00:11:47.899 --> 00:11:51.500 system and let flexibility enhance our system rather 00:11:51.509 --> 00:11:54.349 than penalize them for something that they think is 00:11:54.359 --> 00:11:58.070 that ERCOT thinks is wrong. Happy to uh have the discussion 00:11:58.080 --> 00:11:58.229 with y'all. 00:12:01.950 --> 00:12:05.969 Would you like to lay out your other options? Oh, I'd 00:12:05.979 --> 00:12:13.599 be happy to. (item:33:Commissioner Glotfelty on path forward) Um in my uh so the path forward. I 00:12:13.609 --> 00:12:18.099 propose four bullet points. One have the Commission 00:12:18.109 --> 00:12:20.359 Staff initiate a project in a rulemaking to better 00:12:20.369 --> 00:12:23.119 hash out the state of charge issues. This puts it squarely 00:12:23.129 --> 00:12:29.529 in our court and one that we would consider over the 00:12:29.538 --> 00:12:30.960 next year or two. 00:12:32.469 --> 00:12:37.558 (item:33:Commissioner Glotfelty on real time co-optimization) The challenge with that is 1186 is a interim solution 00:12:38.548 --> 00:12:42.658 because all of this goes away when RTC real time 00:12:42.739 --> 00:12:45.739 co-optimization gets completed. And this may even be a 00:12:45.750 --> 00:12:48.548 good carrot to get real time co-optimization done sooner 00:12:49.729 --> 00:12:53.440 But we should have that, we could have that discussion. 00:12:54.979 --> 00:12:58.058 (item:33:Commissioner Glotfelty on delaying NPRR1186 & studying economic impact) We could delay approving NPRR1186 until the market 00:12:58.070 --> 00:13:01.000 monitor can evaluate whether adoption of it as written 00:13:01.009 --> 00:13:04.788 now would cause could cause regulatory, forced withholding 00:13:04.798 --> 00:13:08.019 of battery capacity from ERCOT's ancillary service markets 00:13:08.029 --> 00:13:10.139 and discourage some proposed storage projects from 00:13:10.149 --> 00:13:14.109 investing in ERCOT when we absolutely need them. We 00:13:14.119 --> 00:13:17.038 could also ask the IMM to study the economic impact 00:13:17.048 --> 00:13:19.190 on the ERCOT markets of withholding large portions 00:13:19.200 --> 00:13:22.678 of battery capacity from the energy and didn't really 00:13:22.690 --> 00:13:24.340 mean ancillary service markets. But from the energy 00:13:24.349 --> 00:13:24.918 markets. 00:13:26.849 --> 00:13:30.149 (item:33:Commissioner Glotfelty on deleting penalty provisions) Finally, we could consider deleting all the penalty 00:13:30.158 --> 00:13:35.298 provisions of NPRR, NPRR1186 as well as the follow 00:13:35.320 --> 00:13:39.989 on NPRR. 1209 and adopt only the data collection and 00:13:40.000 --> 00:13:42.469 monitoring provisions. These this data would inform 00:13:42.479 --> 00:13:45.168 studies and models on battery operation and capabilities 00:13:45.190 --> 00:13:48.349 So ERCOT can maximize the value of these resources 00:13:48.719 --> 00:13:51.190 to the reliability of our grid and not force them to 00:13:51.200 --> 00:13:56.129 behave like slower, less flexible grid assets. 00:13:57.639 --> 00:14:00.200 (item:33:Commissioner Glotfelty on understanding how batteries work) Again, I think we should vote it down, but I'm happy 00:14:00.210 --> 00:14:03.210 to have the discussion. We have to learn by, 00:14:05.899 --> 00:14:08.940 we have to understand how batteries work. That's the 00:14:08.950 --> 00:14:10.690 important thing going forward. There are too many of 00:14:10.700 --> 00:14:13.389 them that are in our interconnection queue and we can't 00:14:13.399 --> 00:14:15.979 just put our head in the ground and avoid them and 00:14:15.989 --> 00:14:19.649 say you have to operate this way and we got to learn 00:14:19.658 --> 00:14:22.269 So I think that we should 00:14:25.200 --> 00:14:31.529 deny 1186 and ask the stakeholders in ERCOT to get 00:14:31.538 --> 00:14:33.529 together and figure out a process by which they can 00:14:33.538 --> 00:14:34.408 both learn together. 00:14:37.269 --> 00:14:41.879 May I go next? If I, if you will Chairman. I 00:14:41.889 --> 00:14:44.599 don't know if you have something to say. Um okay. (item:33:Commissioner Cobos on memo) So 00:14:44.609 --> 00:14:46.879 I, I just wanna kind of lay out a backdrop that I 00:14:46.889 --> 00:14:52.158 think is important um to keep in consideration as we 00:14:52.168 --> 00:14:55.690 deliberate and decide what to do with 1186. And that 00:14:55.700 --> 00:14:59.038 is as you know, noted by ERCOT in many presentations 00:14:59.048 --> 00:15:03.190 um from last Summer. Summer '22 to Summer '23, peak load 00:15:03.200 --> 00:15:06.489 has increased by approximately 5000 megawatts about 00:15:06.500 --> 00:15:10.320 a 6.7% increase in load grows from one Summer to the 00:15:10.330 --> 00:15:10.719 next. 00:15:12.239 --> 00:15:16.759 Population economic growth resulting in much higher 00:15:16.769 --> 00:15:20.989 load growth in Texas. Um is, is a reality that we, 00:15:21.000 --> 00:15:25.950 we must address and ERCOT um consistently raises this 00:15:25.960 --> 00:15:29.408 um factor in many of the discussions we have for maintaining 00:15:29.418 --> 00:15:32.769 reliability in the future with many different uh processes 00:15:32.779 --> 00:15:36.009 and market reforms. And, and we got to keep that in 00:15:36.019 --> 00:15:38.058 mind, we have tremendous load growth going on, right 00:15:38.349 --> 00:15:42.469 All right. (item:33:Commissioner Cobos on energy generation statistics) So gas generation the next two years, a 00:15:42.479 --> 00:15:44.389 little bit over 1000 megawatts. That's what we can 00:15:44.399 --> 00:15:48.820 expect based on Interconnection Agreement and um completed 00:15:50.769 --> 00:15:54.729 FIS. Batteries, we have a little bit over 4000 megawatts 00:15:54.739 --> 00:15:59.139 as I understand um in our current system right now 00:15:59.349 --> 00:16:02.330 with about 8000 on the horizon, which could be more 00:16:02.340 --> 00:16:04.719 according to romel stats, we could have, you know, 00:16:05.000 --> 00:16:09.859 14,000 gigs in the next year solar generation uh just 00:16:09.869 --> 00:16:14.129 under 20,000 gigs of solar on our system with about 00:16:14.139 --> 00:16:17.960 24,000 with uh signed IAS and FIS completed. So that's 00:16:17.969 --> 00:16:21.668 potentially 44,000 megawatts of solar in the next two 00:16:21.678 --> 00:16:27.389 years with 100 and 33,000 gigawatts in the queue. Um 00:16:28.239 --> 00:16:32.178 I, I believe from my perspective that we have two, two issues 00:16:32.190 --> 00:16:34.859 to solve here operational issues. One is maintaining 00:16:34.869 --> 00:16:39.548 reliability during high peak demand periods. Traditional 00:16:39.558 --> 00:16:43.168 peak demand and our steeper solar ramp downs that based 00:16:43.178 --> 00:16:46.288 on the statistics I just provided are going to get 00:16:46.298 --> 00:16:49.710 steeper and deeper. And if I said in the past, we'll 00:16:49.719 --> 00:16:52.649 turn into canyons. And that's a reality that we're 00:16:52.658 --> 00:16:55.869 already seeing right now and it's only gonna become 00:16:55.879 --> 00:16:58.190 more and more exacerbated. And how do you fill that 00:16:58.200 --> 00:17:00.928 canyon? How do you fill that steeper load ramp? Will 00:17:00.940 --> 00:17:01.489 you feel it 00:17:03.029 --> 00:17:09.289 with quickstart and storage primarily. But we only 00:17:09.299 --> 00:17:12.219 have 1000 megawatts of gas PGRR on the coming in 00:17:12.229 --> 00:17:15.140 the near future. And we have a lot of solar on, I 00:17:15.150 --> 00:17:18.420 mean, a lot of storage on the horizon with a lot more 00:17:18.430 --> 00:17:22.180 solar coming. So the reality is, is that we gotta fill 00:17:22.189 --> 00:17:27.118 that ramp down and we got to take action to fill those 00:17:27.130 --> 00:17:31.098 ramp downs now. And, and because we're complacent and 00:17:31.108 --> 00:17:35.598 we, and, and we, we, we put up barriers to storage 00:17:35.608 --> 00:17:38.189 we're not going to fill those ramp downs and we're 00:17:38.199 --> 00:17:40.500 going to get caught flat footed. And right now, the 00:17:40.509 --> 00:17:43.118 only resources, dispatchable resources coming on our 00:17:43.130 --> 00:17:47.430 system faster and cheaper is storage. (item:33:Commissioner Cobos on ECRS) And 00:17:50.039 --> 00:17:54.130 you know, in our market reform discussions, we talked 00:17:54.140 --> 00:17:57.568 about ECRS and we talked about how we wanted to encourage 00:17:57.890 --> 00:18:01.578 solar to show up with storage and that's why we made 00:18:01.588 --> 00:18:03.750 it a two hour duration product and we sent that signal 00:18:03.759 --> 00:18:10.670 to ERCOT. ECRS was implemented um in June of 23 and 00:18:11.108 --> 00:18:13.259 five months later, we're having a discussion about 00:18:13.269 --> 00:18:16.059 how all these problems are arising with storage and 00:18:16.108 --> 00:18:19.269 ancillary services. Well, facts are facts. There's 00:18:19.279 --> 00:18:21.269 not a whole lot of storage in ECRS right now and there's 00:18:21.279 --> 00:18:25.029 none in nonspin really? So, I'm trying to understand what 00:18:25.039 --> 00:18:27.689 the fire alarm is all of a sudden. Because I've asked 00:18:27.699 --> 00:18:30.519 for data at Board Meetings as to where is the non compliance 00:18:30.588 --> 00:18:33.078 And I haven't seen any, like you, Commissioner Glotfelty. 00:18:33.088 --> 00:18:35.930 I haven't seen any, I know ERCOT seen on their 00:18:35.939 --> 00:18:38.858 system, they're not charged. You know, potentially 00:18:38.868 --> 00:18:41.098 and, and if they called upon, they wouldn't be available 00:18:41.108 --> 00:18:43.809 but I haven't seen any evidence that they've actually 00:18:43.818 --> 00:18:46.739 called them on them and they weren't available to provide 00:18:46.750 --> 00:18:50.219 the ancillary service. And, and um so 00:18:51.939 --> 00:18:56.088 I've been in search of data um to support ERCOT's position 00:18:56.189 --> 00:18:58.459 I know that this is a new technology and I'm sympathetic 00:18:58.469 --> 00:19:02.380 to ERCOT with respect to accommodating a new technology 00:19:02.390 --> 00:19:04.818 that has unique characteristics that's coming on the 00:19:04.828 --> 00:19:10.930 system relatively fast. But on the flip side, we're 00:19:10.939 --> 00:19:13.618 also getting tremendous value from the storage facilities 00:19:13.630 --> 00:19:16.108 at a time where we have really no other dispatchable 00:19:16.118 --> 00:19:18.618 generation resources coming on the system. Right? And 00:19:18.630 --> 00:19:21.009 that's exemplified by their September 6th event because 00:19:21.019 --> 00:19:25.459 if we hadn't had the 2181 megawatts on the system during 00:19:25.469 --> 00:19:28.519 the event, we would have been low shed and I know they 00:19:28.529 --> 00:19:31.608 highlighted 41% charge before the event, but there's 00:19:31.618 --> 00:19:35.289 no facts surrounding why they're at 41%. And, and we 00:19:35.299 --> 00:19:40.400 need to get that information because if it was at 41% 00:19:40.410 --> 00:19:43.088 because ERCOT had already deployed ECRS multiple times 00:19:43.098 --> 00:19:47.509 before the event, was it 41%? Because perhaps these 00:19:47.519 --> 00:19:50.979 um, you know, energy storage facilities were providing 00:19:50.989 --> 00:19:53.979 energy in real time. You know, we don't know why we 00:19:53.989 --> 00:19:56.019 can't just assume. Well, it's 41%. They wouldn't have 00:19:56.029 --> 00:19:58.140 been there for ancillary service that they had been 00:19:58.150 --> 00:19:59.890 called on. Well, the fact of the matter is they were 00:19:59.900 --> 00:20:03.160 and they saved the day. All right. So there's that 00:20:03.170 --> 00:20:03.729 um, 00:20:05.729 --> 00:20:09.400 then there's a whole web of, of past um, actions, you 00:20:09.410 --> 00:20:12.189 know, one, well, first and foremost, as Ramya highlighted. 00:20:13.130 --> 00:20:17.509 (item:33:Commissioner Cobos on existing compliance frameworks) We have an existing compliance framework where ERCOT 00:20:17.519 --> 00:20:18.759 can refer to the PUC 00:20:20.348 --> 00:20:23.328 instances of failure to provide ancillary services 00:20:23.729 --> 00:20:28.088 It exists, it existed for all resources, there's penalties 00:20:28.098 --> 00:20:31.608 associated with it. Um, there's nothing new there. 00:20:32.868 --> 00:20:37.719 Um In addition to that NPRR1096 was passed in early 00:20:37.729 --> 00:20:40.459 '23 and that provided ERCOT with the ability to conduct 00:20:40.469 --> 00:20:44.150 unannounced testing on ESRs that provide ECRS and 00:20:44.509 --> 00:20:47.140 nonspin to allow ERCOT to account for monitor battery 00:20:47.150 --> 00:20:50.809 state of charge. Um I've asked, I'm not sure I've gotten 00:20:50.818 --> 00:20:52.328 the information back, but I don't know if ERCOT has 00:20:52.338 --> 00:20:54.328 conducted any unannounced test to figure out what's 00:20:54.338 --> 00:20:56.910 going on with, with these resources, providing those 00:20:56.920 --> 00:20:59.088 ancillary services. But that's obviously a tool ERCOT 00:20:59.098 --> 00:21:01.959 can use and I'm not sure it's been used and I'd love 00:21:01.969 --> 00:21:03.769 to hear from ERCOT, if they have and what they've seen 00:21:03.779 --> 00:21:05.209 with that. Um 00:21:06.739 --> 00:21:09.469 So you have 1096 that provides ERCOT with tools and 00:21:09.479 --> 00:21:13.818 then now you have 1186 that provides the state of charge 00:21:13.828 --> 00:21:19.068 requirements. And, and, and in the backdrop 1209 that 00:21:19.078 --> 00:21:25.098 would provide, you know, compliance, um payment callback 00:21:25.108 --> 00:21:28.439 for failure to provide based on what I understand is 00:21:28.449 --> 00:21:31.439 one resources specific lack of, lack of state of charge 00:21:31.449 --> 00:21:35.519 which can clarify what they like on, on that NPRR as 00:21:35.529 --> 00:21:40.078 well. But as, as I'm looking at just the, you know 00:21:40.088 --> 00:21:41.880 I wanted to lay out the backdrop, right? Cause that's 00:21:41.890 --> 00:21:44.180 important as a state. We're, we're trying to plan for 00:21:44.189 --> 00:21:47.368 the future tremendous load growth, maintain your reliability 00:21:47.519 --> 00:21:50.279 not just day to day operations during extreme weather 00:21:50.289 --> 00:21:55.039 conditions, we need to add more dispatchable um resources 00:21:55.400 --> 00:21:58.719 And the fact of the matter is we need to Adam not 00:21:58.729 --> 00:22:01.568 only to meet peak demand, the usual peak demand, but 00:22:01.578 --> 00:22:03.838 also for the solar ram downs that we are experiencing 00:22:03.848 --> 00:22:05.469 And the only ones that are coming on the system right 00:22:05.479 --> 00:22:10.608 now are the dispatchable storage facilities. So I would 00:22:10.618 --> 00:22:13.000 just want to make sure as I've said it repeatedly at 00:22:13.009 --> 00:22:15.390 the board meetings that we're not setting up hurdles 00:22:15.430 --> 00:22:19.269 for storage, to part to, to enter our market and to 00:22:19.279 --> 00:22:22.719 participate in our ancillary services because we in 00:22:22.729 --> 00:22:26.890 fact encourage that at the Commission. And my understanding 00:22:26.900 --> 00:22:29.068 in visiting with some of the stakeholders. Is that 00:22:29.920 --> 00:22:33.039 well, you know, and to your point, I've heard the same 00:22:33.049 --> 00:22:35.838 things, Commissioner Glotfelty, is that well, it's 00:22:35.848 --> 00:22:39.140 not as bad as the former 1186. We'd rather not have it 00:22:39.150 --> 00:22:42.640 because it's going to lessen our participation in ancillary 00:22:42.789 --> 00:22:45.559 services and especially our investment decisions in 00:22:45.568 --> 00:22:49.059 four hour long duration batteries, which we will need 00:22:49.880 --> 00:22:53.660 eventually. (item:33:Commissioner Cobos' question concerning the urgency of 1186) So, you know, I'm trying to figure out 00:22:53.670 --> 00:22:54.559 what, you know 00:22:56.979 --> 00:23:01.358 why ERCOT needs 1186 right now. ECRS is just went in 00:23:01.368 --> 00:23:05.338 live in June 23. What, what is the fire alarm? Where's 00:23:05.348 --> 00:23:09.088 the compliant non compliance data? Show me the analysis 00:23:09.098 --> 00:23:13.328 to backup 1186 because otherwise I feel like we're 00:23:13.338 --> 00:23:15.358 setting up hurdles and we should just go straight to 00:23:15.368 --> 00:23:19.380 RTC plus B and implement that and, and, and avoid 00:23:19.390 --> 00:23:22.318 sending negative investment signals for resources that 00:23:22.328 --> 00:23:26.588 we need right now. And then there, there's underlying 00:23:26.598 --> 00:23:29.420 eagle, legal issues that I, I feel need to be explored 00:23:29.430 --> 00:23:32.930 Why does the NPRR require QSE to manage the state 00:23:32.939 --> 00:23:35.400 of charge for each ESR they, they don't own and operate 00:23:35.410 --> 00:23:40.170 the asset um due process. The NPRR requires the QSE to 00:23:40.180 --> 00:23:42.549 manage an ESR state of charge and enforcement is at 00:23:42.559 --> 00:23:46.338 the QSE level. Um I mean, should the RE have a voice 00:23:46.348 --> 00:23:48.608 in defending itself in an enforcement investigation 00:23:48.838 --> 00:23:50.858 Well, absolutely, they're the ones that own and control 00:23:50.868 --> 00:23:57.618 the, the asset. (item:33:Commissioner Cobos on discriminatory impact policy) And discriminatory impact policy is 00:23:57.630 --> 00:24:02.430 also tremendously important here. The NPRR would result 00:24:02.439 --> 00:24:05.130 in less esr participations. I potentially, this is 00:24:05.140 --> 00:24:08.739 what I'm hearing in ancillary services and less innovation 00:24:08.750 --> 00:24:10.939 four hour duration batteries. 00:24:13.250 --> 00:24:16.259 You know, it's not a telemetry issue already has telemetry 00:24:16.269 --> 00:24:19.108 to see state of charge. They already have awareness 00:24:19.729 --> 00:24:25.078 Um Has ERCOT studied the cost impact of NPRR1186 and 00:24:25.088 --> 00:24:27.509 battery participation is lessened in ancillary services 00:24:27.519 --> 00:24:30.029 Then you're gonna have more traditional generation 00:24:30.039 --> 00:24:31.920 participating and that's fine, but it's gonna be more 00:24:31.930 --> 00:24:37.618 expensive. Um And then that will result in more thermal 00:24:37.630 --> 00:24:40.098 generation are reserves being held out of the system 00:24:40.108 --> 00:24:42.098 because you have them participating in ancillary services 00:24:42.108 --> 00:24:46.219 and which will increase real time energy prices. Um 00:24:46.539 --> 00:24:48.660 And I, I just feel like we're spending a lot of time 00:24:48.670 --> 00:24:53.049 on this issue and I'm trying to understand um from 00:24:53.098 --> 00:24:59.689 ERCOT, you know what, what the real problem is because 00:24:59.699 --> 00:25:04.390 otherwise I feel like we're spending time on this where 00:25:04.400 --> 00:25:07.108 we could be working on other things to provide market 00:25:07.118 --> 00:25:11.828 certainty and for investment in dispatchable generation 00:25:12.420 --> 00:25:17.108 Um and um authority and a resource that is proven to 00:25:17.118 --> 00:25:21.858 be valuable and there's data showing that and, and 00:25:21.868 --> 00:25:24.219 I just, I want to make sure we're headed in the right 00:25:24.328 --> 00:25:26.578 (item:33:Commissioner Cobos' concerns with NPRR1206) I wanna make sure I understand from ERCOT's perspective 00:25:26.588 --> 00:25:29.809 because this is a really tough NPRR to process and 00:25:29.818 --> 00:25:33.439 and then, and, and especially I know ERCOT has worked 00:25:33.449 --> 00:25:35.420 really hard and trying to find, you know, something 00:25:35.430 --> 00:25:38.328 more workable and, and that's what they've told us 00:25:38.410 --> 00:25:42.410 but waiting in the wings is NPRR1209, which is 00:25:42.420 --> 00:25:46.608 dependent on 1186 passing. And so as a framework holistically 00:25:46.818 --> 00:25:50.509 it's problematic. Okay. So I recognize ERCOT has taken 00:25:50.519 --> 00:25:54.588 steps to try to fix 1186 to make it more palpable. But 00:25:54.598 --> 00:25:58.439 is it when you have 1209 waiting in the wings that 00:25:59.219 --> 00:26:02.239 I believe is problematic at this time as I understand 00:26:02.250 --> 00:26:07.900 it. And so, um, you know, like you commissioner Lotfy 00:26:09.170 --> 00:26:11.949 I have some potential options on how to move forward 00:26:12.400 --> 00:26:16.449 and, and, and um, you know, we could reject the NPRR 00:26:16.459 --> 00:26:19.509 as you prefer to do, we could strike 00:26:21.279 --> 00:26:24.459 section 8.1 from the N pr R and continue to collect 00:26:24.469 --> 00:26:29.670 data. Um which is section 8.1 is the state of charge 00:26:29.680 --> 00:26:32.759 and, and compliance metrics there, I guess. 00:26:34.348 --> 00:26:37.578 I mean, I don't know if it helps to not take action 00:26:37.588 --> 00:26:40.618 on 1186 and have ERCOT work on some of the issues we 00:26:40.630 --> 00:26:42.838 have with 1209 and bring it all back as a package. 00:26:43.818 --> 00:26:48.789 Can we bifurcate the process and have the 1180, 1186 00:26:48.799 --> 00:26:51.338 just apply to the one hour duration batteries. That 00:26:51.348 --> 00:26:54.189 participate in regulation, reserve service and regulation 00:26:54.199 --> 00:26:56.598 up because they're apparently comfortable with 1186 00:26:56.608 --> 00:27:00.000 But long duration is not and continue to explore um 00:27:00.009 --> 00:27:03.989 state of charge for long duration batteries. Should 00:27:04.000 --> 00:27:06.009 we initiate a project here and take more stakeholder 00:27:06.019 --> 00:27:09.959 comment on these broader impact policy decisions and 00:27:10.390 --> 00:27:12.039 and own the policy decision here? 00:27:13.549 --> 00:27:18.078 Just some food for thought and be happy to hear 00:27:18.088 --> 00:27:20.838 your thoughts. Madam Chair, how would you like to proceed? 00:27:20.848 --> 00:27:23.858 Would you like Dan to lay this out? I mean, a lot's 00:27:23.868 --> 00:27:26.858 been said and I certainly have questions to walk through 00:27:26.868 --> 00:27:29.000 practical application. I didn't know if you wanted 00:27:29.009 --> 00:27:31.318 to make your comments first or to go ahead and bring 00:27:31.439 --> 00:27:33.439 out ERCOT. You know, a lot's been said. But 00:27:35.299 --> 00:27:39.640 frankly, I'd like to afford Dan the opportunity to jump 00:27:39.650 --> 00:27:41.719 in here. I don't have a lay out speech or anything 00:27:41.729 --> 00:27:46.848 like that. So, uh you're discretion ma'am. That'd be 00:27:46.858 --> 00:27:49.529 good. Dan, if you could state your name for the record? 00:27:51.509 --> 00:27:54.000 The, um. You need to state your name for the record. 00:27:55.789 --> 00:28:00.098 The. Your name. (item:31:ERCOT's Dan Woodfin on 1186) Dan Woodfin with ERCOT. The 00:28:02.199 --> 00:28:07.019 fundamental thing that 1186 is doing is that we buy 00:28:07.029 --> 00:28:11.400 reliability products, ancillary services in order to 00:28:11.410 --> 00:28:14.400 maintain the reliability of the system. And we buy 00:28:14.410 --> 00:28:18.500 those services. Um, and electric consumers of Texas 00:28:18.509 --> 00:28:22.578 pay for them. And what we're trying to do in 1186 is 00:28:22.588 --> 00:28:27.858 is define what, what is, what are the kind of the characteristics 00:28:27.868 --> 00:28:31.529 of those products that we're buying for reliability 00:28:31.539 --> 00:28:34.799 that consumers are paying for in such a way that there's 00:28:34.848 --> 00:28:39.709 clear understanding between we as the kind of buying 00:28:39.719 --> 00:28:42.880 it for the consumers and the people that are providing 00:28:42.890 --> 00:28:46.279 it, that they understand exactly what it is and what 00:28:46.289 --> 00:28:49.650 the characteristics we're expecting from them. And 00:28:49.660 --> 00:28:52.338 so that, that's just common sense, right? Anytime you 00:28:52.348 --> 00:28:54.930 have a product that that's what happens, you gotta 00:28:54.939 --> 00:28:56.989 get agreement with the buyer and seller as to what 00:28:57.000 --> 00:29:01.949 the characteristics are. And because batteries have 00:29:01.959 --> 00:29:04.959 a unique characteristics, which is that they have a 00:29:04.969 --> 00:29:08.279 limited duration that they can, they can provide that 00:29:08.289 --> 00:29:11.239 service for. That's a, that's another parameter that 00:29:11.250 --> 00:29:14.088 we need to take into account for them that we don't 00:29:14.098 --> 00:29:16.699 take into account for a coal plant. That's not, that's 00:29:16.709 --> 00:29:18.910 not there. So we're in fact not treating them like 00:29:18.920 --> 00:29:21.250 a coal plant. We're taking into account the unique 00:29:21.259 --> 00:29:23.759 characteristics just like in other places, we take 00:29:23.769 --> 00:29:26.088 account the unique characteristics of wind generators 00:29:26.098 --> 00:29:29.848 or solar plants or whatever. You know, there are places 00:29:29.858 --> 00:29:32.479 that we have to treat different technologies differently 00:29:32.489 --> 00:29:36.229 because they have different uh characteristics. And 00:29:36.239 --> 00:29:37.959 so that's what that's what we're doing here is that 00:29:37.969 --> 00:29:41.299 in, if batteries are gonna provide these ancillary 00:29:41.348 --> 00:29:45.608 services, then here's an additional parameter because 00:29:45.618 --> 00:29:48.338 of the unique characteristic that they have that they 00:29:48.348 --> 00:29:50.910 need to take into account, we need to take into account 00:29:50.920 --> 00:29:54.269 in determining whether they're adequately providing 00:29:54.279 --> 00:29:56.930 that service or not. (item:33:Dan Woodfin on compliance) Now, um 00:30:00.189 --> 00:30:06.029 we uh there was some discussion about whether we should 00:30:06.039 --> 00:30:08.719 we, we compliance from a compliance perspective. If 00:30:08.729 --> 00:30:12.098 we laid out that, you know, if we seen episodes of 00:30:12.108 --> 00:30:16.489 non compliance and so forth. Well, we have based on 00:30:16.500 --> 00:30:20.029 this business practice document that we put out stakeholders 00:30:20.039 --> 00:30:23.529 ask us what is the, what, what, what criteria are you 00:30:23.539 --> 00:30:26.430 going to use to determine if you've provided sufficient 00:30:26.439 --> 00:30:30.029 if we, we're providing that service or not. We put 00:30:30.039 --> 00:30:32.259 out a business practice document said here's the criteria 00:30:32.269 --> 00:30:35.439 we're gonna use and some entities didn't follow that 00:30:35.449 --> 00:30:38.549 We're definitely not in compliant with that and argued 00:30:38.559 --> 00:30:41.858 that the business practice document isn't binding that 00:30:41.868 --> 00:30:44.989 it's not something that we can, you know, report people 00:30:45.000 --> 00:30:49.880 for, they don't have to do it. And so 1186 is actually 00:30:49.890 --> 00:30:52.779 the, the solution to that. It's saying, OK, well, we'll 00:30:52.789 --> 00:30:55.390 define in the protocols in the rules. What are the 00:30:55.400 --> 00:30:57.939 criteria that we're going to use to assess whether 00:30:57.949 --> 00:31:00.739 you've provided that reliability product that we're 00:31:00.750 --> 00:31:04.150 they're requesting or not? And uh so that, that was 00:31:04.160 --> 00:31:06.750 really the intent is to get that certainty around how 00:31:06.759 --> 00:31:08.489 how are we going to assess whether you're providing 00:31:08.500 --> 00:31:11.789 it or not? Now, there is also some discussion about 00:31:11.799 --> 00:31:16.029 uh uh whether we should, whether they're providing 00:31:16.039 --> 00:31:19.098 it if they're providing it in advance or not, you know 00:31:20.400 --> 00:31:23.640 I guess that should we wait to assess whether when 00:31:23.650 --> 00:31:27.400 they're called upon to provide the service? Do they 00:31:27.410 --> 00:31:31.259 have the capability of doing that or not? Um Well, 00:31:31.269 --> 00:31:34.380 to me that's too late. It's kind of like if you're 00:31:34.390 --> 00:31:39.519 driving across West Texas and a hot dusty road and 00:31:39.529 --> 00:31:42.439 you have a flat that's too dang late to figure out 00:31:42.449 --> 00:31:44.939 if your spare tire has air in it. And that's really 00:31:44.949 --> 00:31:47.598 what we're doing is in buying the ancillary services 00:31:47.608 --> 00:31:51.239 we're buying, making sure that our flat, our spare 00:31:51.250 --> 00:31:54.809 tire has air in it. We're buying a spare and we're 00:31:54.818 --> 00:31:58.160 making sure we got air in it and we can't wait until 00:31:58.170 --> 00:32:00.699 we need it to figure out. Is it, does it have enough 00:32:00.709 --> 00:32:03.318 air or not? We need to be assessing that all the time 00:32:03.430 --> 00:32:06.108 And that's another thing that 1186 does and maintain 00:32:06.368 --> 00:32:09.500 making sure that we're uh have sufficient state of 00:32:09.509 --> 00:32:13.199 charge all the time. I guess one of the things Ramya 00:32:13.209 --> 00:32:18.989 said is that, that they can uh a QSE can move around 00:32:19.000 --> 00:32:23.039 that what resources within there. (item:33:Dan Woodfin on QSE) The QSE is committing 00:32:23.049 --> 00:32:26.969 to provide the service and so whatever resources they 00:32:26.979 --> 00:32:30.189 represent, they can move around. The, which one of 00:32:30.199 --> 00:32:32.890 those that they're pointing to at any point in time 00:32:32.900 --> 00:32:35.739 as providing the, that's the spare tire you're, you're 00:32:35.750 --> 00:32:38.459 getting right now. And so they can move that around 00:32:38.469 --> 00:32:41.779 just like any other resource can, whether it's within 00:32:41.789 --> 00:32:44.338 a portfolio that's got gas plants, coal plants, they 00:32:44.348 --> 00:32:46.759 can move those around. They can also move it around 00:32:46.769 --> 00:32:50.729 between if they got batteries. If the battery is getting 00:32:50.739 --> 00:32:52.670 low in state of charge, they can move it to another 00:32:52.680 --> 00:32:55.939 battery, they can move it to another gas plant. That 00:32:55.949 --> 00:32:59.130 has had room in their portfolio. And so that's, that's 00:32:59.140 --> 00:33:02.269 the same across all different resource types 00:33:08.180 --> 00:33:09.689 uh on state of charge, 00:33:11.959 --> 00:33:14.219 they can move that around. Yeah. As long as they've 00:33:14.229 --> 00:33:17.559 got sufficient state of charge on, on whatever they're 00:33:17.568 --> 00:33:21.358 moving it to so they can. So, so it's not resource 00:33:21.368 --> 00:33:24.848 specific, it's QSE. It, it's at the QSE level. Yes. 00:33:25.759 --> 00:33:27.479 And that was one of the things that came up during 00:33:27.489 --> 00:33:31.689 the Board discussion that we clarified. Dan, can I before 00:33:31.699 --> 00:33:33.358 you move on to your other points? I just want to hit 00:33:33.368 --> 00:33:35.900 on two issues. (item:33:Commissioner Cobos on business practices) So one, one on the business practice menu. 00:33:36.390 --> 00:33:39.289 So some of the non compliance you've seen has been 00:33:39.309 --> 00:33:44.009 was based on the business practice menu. So that business 00:33:44.019 --> 00:33:46.750 practice manual, as I understand through all the comments 00:33:46.880 --> 00:33:49.279 you know, was never Board approved Commission, you 00:33:49.289 --> 00:33:52.049 know sanctioned approved. There was a state of charge 00:33:52.059 --> 00:33:55.009 policy in there that you guys came up with and then 00:33:55.019 --> 00:33:57.489 you know, there was complaints on the potentially, 00:33:57.500 --> 00:34:00.989 I'm just saying what I, what I understand is complaints 00:34:01.000 --> 00:34:03.549 about the fact that you're relying on a business non-binding 00:34:03.559 --> 00:34:06.259 business practice manual that hasn't been formally 00:34:06.269 --> 00:34:09.769 approved by anyone. And so now um you've moved, that 00:34:10.289 --> 00:34:13.099 moved the business practice manual state of charge 00:34:13.110 --> 00:34:15.300 requirements into a protocol so you can get that formal 00:34:15.309 --> 00:34:17.769 approval. But it sounds like from what you're telling 00:34:17.780 --> 00:34:21.429 me, your non-compliance is based on what you've observed 00:34:21.438 --> 00:34:23.668 in a non-binding business practice manual 00:34:25.449 --> 00:34:29.498 that, you know, so I'm just trying to understand when 00:34:29.509 --> 00:34:31.748 you say non compliance. I mean, 00:34:33.489 --> 00:34:37.429 the batteries are, most batteries are providing 00:34:37.438 --> 00:34:40.849 RRS and regulation. There's hardly any in ECRS. So 00:34:40.860 --> 00:34:44.590 and, and, and nonspin. So when you're saying non-compliance 00:34:44.599 --> 00:34:47.179 first, I guess it's based on a non-binding business 00:34:47.188 --> 00:34:48.820 practice manual and you're not trying to formalize 00:34:48.829 --> 00:34:53.789 in this NPRR. But number two, like what I mean 00:34:54.907 --> 00:34:57.548 I guess where, where's the information with ECRS? 00:34:57.697 --> 00:35:00.838 And I guess nonspin there's none, I mean for nonspin 00:35:00.849 --> 00:35:02.668 anyway, but that's what I'm trying to get at here. 00:35:02.677 --> 00:35:06.528 I think one of the things that will have, I mean, in 00:35:06.539 --> 00:35:11.099 in the. (item:33:Dan Woodfin's follow-up to Commissioner Cobos) If you recall that between the first board 00:35:11.108 --> 00:35:14.599 meeting where we discussed 1186 and the second one. Um 00:35:14.610 --> 00:35:17.179 that where the Board approved it and that's what's 00:35:17.188 --> 00:35:21.539 before you today. We changed kind of the direction 00:35:21.550 --> 00:35:24.539 we were headed with that significantly and to compromise 00:35:24.550 --> 00:35:27.938 with what we were hearing from stakeholders. And um 00:35:28.019 --> 00:35:32.168 so what was in the business practice? Can I ask you 00:35:32.179 --> 00:35:37.128 something on that. I'm sorry. (item:33:Commissioner Glotfelty on remanding to TAC) You all begrudgingly 00:35:37.820 --> 00:35:41.918 remanded that TAC. You all were pushing full speed 00:35:41.929 --> 00:35:47.878 ahead to make that original NPRR pass and begrudgingly 00:35:48.300 --> 00:35:51.389 you remanded it back to TAC. Because one of our market 00:35:51.398 --> 00:35:55.579 participants was correct and you all were wrong in 00:35:55.590 --> 00:35:59.688 how state of charge, how your, how this state of charge 00:35:59.699 --> 00:36:02.648 rule would have applied under an emergency situation 00:36:03.829 --> 00:36:06.619 So you all sent it back and it got fixed the 00:36:06.628 --> 00:36:10.599 way they suggested it to help to the benefit of reliability 00:36:10.610 --> 00:36:14.219 and markets. But, but please don't mischaracterize 00:36:14.228 --> 00:36:18.159 it that you all said. Oh, this is wrong. We've got 00:36:18.168 --> 00:36:20.019 to fix this for reliability. We're going to send it 00:36:20.030 --> 00:36:23.079 back to TAC because that's not the way it happened 00:36:23.090 --> 00:36:27.599 in reality. (item:33:Dan Woodfin on remand) Well, so we fixed two things and when it 00:36:27.610 --> 00:36:30.539 was remanded back, we fixed two things. One was the 00:36:30.550 --> 00:36:33.648 issue that we had, that had been identified by one 00:36:33.659 --> 00:36:36.869 of the market participants that we agreed that with 00:36:37.139 --> 00:36:42.550 the other thing we fixed was a um where we were holding 00:36:42.559 --> 00:36:46.978 them to two hours of state of charge for ECRS and four 00:36:46.989 --> 00:36:53.309 hours for nonspin based on the approval of 1096 back 00:36:53.320 --> 00:36:56.168 several months ago or, you know, more than a year ago 00:36:56.269 --> 00:36:58.820 we were trying to stay consistent with that. And what 00:36:58.829 --> 00:37:02.878 we heard from, from some of you during the board meeting 00:37:02.918 --> 00:37:07.840 is that, that it wasn't expected that 1096 was going 00:37:07.849 --> 00:37:12.639 to, we weren't applying that in the way you'd intended 00:37:12.769 --> 00:37:15.628 And so with that flexibility, we were able to loosen 00:37:15.639 --> 00:37:20.239 up what we were requiring in 1186. And so we actually 00:37:20.250 --> 00:37:23.958 responded and, and fixed that, not because we did anything 00:37:23.969 --> 00:37:27.449 wrong, but because we were implementing the policy 00:37:27.458 --> 00:37:29.958 that as we understood it. And there was a clarification 00:37:29.969 --> 00:37:33.760 around that policy. I don't remember the 1096 discussion 00:37:33.769 --> 00:37:36.688 on that. But what I did ask at the board meeting, have 00:37:36.699 --> 00:37:39.469 you all conducted any unannounced testing that is allowed 00:37:39.478 --> 00:37:42.639 under 1096 at all during this time period of looking 00:37:42.648 --> 00:37:45.469 at state of charge. And I actually don't know the answer 00:37:45.478 --> 00:37:46.000 to that. (item:33:Commissioner McAdams reference details from September 6th meeting) And 00:37:47.688 --> 00:37:52.208 interesting factoids to come out from September 6th 00:37:52.349 --> 00:37:55.360 And this is, we won't delve into this today, but it 00:37:55.369 --> 00:37:57.750 was referenced in Commissioner Glotfelty letter. So 00:37:57.760 --> 00:38:04.510 it is relevant was pardon me? It was a 00:38:06.500 --> 00:38:11.840 I booked my wrong page Section 4.10 of the September 00:38:11.849 --> 00:38:17.449 6th after action report and I'll quote, "Maximum instantaneous 00:38:17.458 --> 00:38:23.059 energy storage resource net output was 2181 megawatts 00:38:23.099 --> 00:38:27.989 at 19:20 hours. This was which is 7:20pm for you 00:38:28.000 --> 00:38:32.500 layman. This was ERCOT's record ESR net output to date. 00:38:33.139 --> 00:38:35.719 Prior to the event, the average state of charge for 00:38:35.978 --> 00:38:41.019 ESRs was approximately 41.4% by the end of the event 00:38:41.159 --> 00:38:44.579 that percentage state of charge dropped to a low of 00:38:44.590 --> 00:38:50.809 15.07% at 20:04 hours." So it shows that there's some 00:38:50.820 --> 00:38:54.119 type of monitoring going on. But, but there's a lot 00:38:54.128 --> 00:38:56.469 underneath that monitoring like is it because there 00:38:56.619 --> 00:38:59.969 is exhausting through ECRS through nonspin like we can't 00:38:59.978 --> 00:39:01.958 just take that at face value and assume that the state 00:39:01.969 --> 00:39:04.820 of charge wasn't there for ancillary services. That's 00:39:04.829 --> 00:39:07.639 the intent. Let's bring that up as an example of accounting 00:39:07.949 --> 00:39:12.329 that is going on. (item:33:Connie Corona suggestion to add Project 54444 to the discussion if needed) Commissioners? Oh, sorry. Pardon my interruption. 00:39:12.550 --> 00:39:16.139 I believe if we're going to continue with this part 00:39:16.148 --> 00:39:18.878 of the discussion, you should also bring up project 00:39:18.889 --> 00:39:22.539 No. 54444. And I won't delve into it further than 00:39:22.550 --> 00:39:25.519 that Madam Chair. So I'll limit my discussion to that. 00:39:25.530 --> 00:39:25.909 Thank you. 00:39:27.628 --> 00:39:31.269 So it's hereby recognized and we're talking about that 00:39:31.280 --> 00:39:36.449 now. Anyway, so um batteries did perform it. It showed 00:39:36.750 --> 00:39:40.750 a um a performance value during a high-risk period 00:39:40.978 --> 00:39:44.820 I would argue that that shows a state of charge compliance 00:39:44.829 --> 00:39:49.250 to a degree with market signals and ancillary signals 00:39:49.260 --> 00:39:53.070 It's a, it's a good thing they, they showed up. Um 00:39:54.349 --> 00:39:58.289 But if y'all would humor me, I'd ask him uh an anecdotal 00:39:58.300 --> 00:40:01.708 question about how this may work. 00:40:03.340 --> 00:40:06.668 All right. And, and maybe we might have uh additional 00:40:06.679 --> 00:40:09.989 Staff people come up. I understand now that state of 00:40:10.000 --> 00:40:12.570 charge is not transferable. 00:40:14.139 --> 00:40:19.260 Ancillary service obligations is among the QSC qualified 00:40:19.269 --> 00:40:24.039 resources. But state of charge on a resource basis 00:40:24.219 --> 00:40:27.590 is not transferable. So it's on a resource basis that 00:40:28.128 --> 00:40:31.648 the obligation because I'm just trying to get clarity 00:40:31.659 --> 00:40:34.030 on that Dan. Yeah so, so yeah. I understand that. 00:40:34.059 --> 00:40:37.958 (item:33:Dan Woodfin on the state of charge) So, so yes, the the state of charge is associated with 00:40:37.969 --> 00:40:40.869 a particular resource. But when we look at the, the 00:40:40.878 --> 00:40:44.389 product that they're providing and, and what do they 00:40:44.398 --> 00:40:47.235 have enough resources a QSE have enough resource within 00:40:47.244 --> 00:40:50.313 their portfolio that have the capability of meeting 00:40:50.324 --> 00:40:53.905 that, that, that requirement. We're looking at what 00:40:53.914 --> 00:40:56.465 resources at each point in time that they're pointing 00:40:56.474 --> 00:40:59.284 to as being the ones that are providing that ancillary 00:40:59.514 --> 00:41:04.885 service. And if they're um and, and, and so then we're 00:41:04.894 --> 00:41:07.264 looking at kind of adding up from the bottom, the state 00:41:07.273 --> 00:41:09.773 of charge that's available on any, if they're using 00:41:09.784 --> 00:41:13.510 batteries and any other capabilities. If their, if 00:41:13.519 --> 00:41:20.019 their HSL on a gas plant isn't sufficient to, to and 00:41:20.030 --> 00:41:22.739 they don't have enough headroom, then then it would 00:41:22.750 --> 00:41:25.978 be the same issue. Ok. So, so here's an example 00:41:29.570 --> 00:41:34.628 before 1186 any resource including storage or I'm sorry 00:41:34.639 --> 00:41:37.329 I guess that would be after 1186 any resource including 00:41:37.340 --> 00:41:41.579 storage, well, especially storage would be in violation 00:41:41.590 --> 00:41:45.800 Oh, ok. (item:33:Commissioner McAdams on state of charge violations) Before 1186 any resource that failed to provide 00:41:45.809 --> 00:41:49.280 energy again, that's failed to provide would be penalized 00:41:49.320 --> 00:41:52.179 if they did not comport with their provision under 00:41:52.188 --> 00:41:58.398 the ancillary contract. All right. Um Now, under 1186 00:41:58.659 --> 00:42:02.469 an energy storage resource could completely satisfy 00:42:03.539 --> 00:42:06.628 its ancillary service requirements. So they would dispatch 00:42:06.639 --> 00:42:10.070 energy. Ok. QSE would dispatch 00:42:11.780 --> 00:42:14.909 and still be in violation could be in violation of 00:42:14.918 --> 00:42:18.438 state of charge requirements of 1186. If the particular 00:42:18.449 --> 00:42:22.188 battery which did not hold the amount of power that 00:42:22.199 --> 00:42:23.929 they needed to is that possible 00:42:26.090 --> 00:42:28.829 if they're pointing to. So it's not, it's, it's the 00:42:28.840 --> 00:42:32.260 flat. Right. It's the, the, did you have air in the 00:42:32.269 --> 00:42:35.159 tire of your flat regardless of whether you need the 00:42:35.168 --> 00:42:38.128 flat or not? Did you have enough to error in there? Yeah 00:42:38.139 --> 00:42:43.389 Can I, can I. I hear what you're saying. Do we over 00:42:43.398 --> 00:42:48.280 procure ancillary services? Do we procure enough that 00:42:48.289 --> 00:42:50.699 if one ancillary service obligation fails, there's 00:42:50.708 --> 00:42:51.500 another behind it. 00:42:55.449 --> 00:42:58.648 If uh, if it fails. (item:33:Dan Woodfin on procuring ancillary services) No, we don't have. We actually 00:42:58.659 --> 00:43:03.969 we, we procure enough so that if it deploys, then then 00:43:03.978 --> 00:43:07.648 and then it runs out of time or, you know, we need 00:43:07.659 --> 00:43:10.590 to restore it in order to meet our NERC obligations. 00:43:10.679 --> 00:43:15.269 Then we'll, we'll we have more that we can of another 00:43:15.280 --> 00:43:18.059 type within some period of time can be there. Right. 00:43:18.070 --> 00:43:20.579 (item:33:Commissioner Glotfelty's dialogue with Dan Woodfin) And all ancillary services are different. I recognize 00:43:20.590 --> 00:43:22.449 that there are different time frames and different 00:43:22.458 --> 00:43:26.208 products. But if a gas plant has an ancillary service 00:43:26.219 --> 00:43:31.878 obligation and has a forced outage what happens? If 00:43:31.889 --> 00:43:35.369 they, they can move it to their obligation, a QSE can 00:43:35.378 --> 00:43:37.628 move their obligation to another thing in their portfolio. 00:43:37.639 --> 00:43:42.559 That's right. So the next resource, the next best resource 00:43:42.570 --> 00:43:46.179 steps up. Yes. That's the way the system should work 00:43:46.188 --> 00:43:49.409 and that has the capability of doing it, that is qualified 00:43:49.418 --> 00:43:52.119 and has the sufficient state of charge and all that 00:43:52.128 --> 00:43:54.599 (item:33:Commissoner Glotfelty on command/control and market differences) So that's my view, which is, and I think this is the 00:43:54.610 --> 00:43:59.898 crux of where where y'all and I differ on this. Y'all 00:44:00.010 --> 00:44:02.369 the way I view it is command and control. I want to 00:44:02.378 --> 00:44:05.539 know, I want to see, I want to own their state of 00:44:05.550 --> 00:44:10.208 charge to prove that they can be there. And I say we 00:44:10.219 --> 00:44:13.869 live in a market, y'all operate a market and there 00:44:13.878 --> 00:44:18.079 are penalties that you have outlined for failure to 00:44:18.090 --> 00:44:22.760 provide. And if a comp, if a battery wants to fail 00:44:22.769 --> 00:44:25.949 to provide, they're going to get penalized, they're 00:44:25.958 --> 00:44:27.969 going to get clawed back and they're going to pay the 00:44:27.978 --> 00:44:31.010 delta and the ancillary service price that they bid 00:44:31.019 --> 00:44:34.688 and, and what it was and that will be very detrimental 00:44:34.699 --> 00:44:38.570 to that facility. And the bankers and the lawyers and 00:44:38.579 --> 00:44:41.918 the financiers will not stand for it. And that's where 00:44:41.929 --> 00:44:46.030 I believe that the market is self correcting the market 00:44:46.039 --> 00:44:49.840 will benefit these batteries and you'll get more charge 00:44:49.929 --> 00:44:54.159 into the market which will or more a discharge into 00:44:54.168 --> 00:44:54.728 the market 00:44:56.938 --> 00:45:00.599 in the ancillary services market and in the energy 00:45:00.610 --> 00:45:05.289 and real-time markets when you relax this and not force 00:45:05.300 --> 00:45:09.139 them in your box, that's what I think. And that's where 00:45:09.148 --> 00:45:12.849 the crux of my, the different view is from me. 00:45:15.128 --> 00:45:17.289 (item:33:Commissioner Cobos on non-compliance) When you're looking at the, whether there's enough 00:45:17.300 --> 00:45:21.789 air for, for the flat tire. I mean, I see you're doing 00:45:21.800 --> 00:45:24.860 that for a battery and you have NPRRs that will 00:45:24.869 --> 00:45:27.628 give you visibility into the coal and gas plants. But 00:45:27.958 --> 00:45:29.849 there's a difference there, right? I mean, the difference 00:45:29.860 --> 00:45:33.610 is to say, to charge requirement will trigger non compliance 00:45:33.619 --> 00:45:39.599 But if the plant doesn't have enough coal or gas, then 00:45:39.750 --> 00:45:42.840 that doesn't trigger non compliance. (item:33:Dan Woodfin on non-compliance) Well, if the plant 00:45:42.849 --> 00:45:45.199 doesn't have enough coal or gas, they're supposed to 00:45:45.208 --> 00:45:48.010 reflect that in their current operating plan, that 00:45:48.019 --> 00:45:51.219 there's a limitation there on they can't produce at 00:45:51.228 --> 00:45:53.958 the level that, you know, it reduces the amount they 00:45:53.969 --> 00:45:59.239 can produce. And so that, and in fact, there is a 00:45:59.250 --> 00:46:02.929 NPRR1170 that has some comments that just came in yesterday 00:46:02.938 --> 00:46:06.019 that makes it very clear that you're supposed to do 00:46:06.030 --> 00:46:08.929 that if you, if you see that there's gas restrictions 00:46:09.369 --> 00:46:13.329 And so it's, there's already a requirement there on 00:46:13.340 --> 00:46:16.679 other kind of plants based on the technologies that 00:46:16.688 --> 00:46:20.550 they are. All we're doing is adding another consideration 00:46:20.559 --> 00:46:23.159 that's because of the unique technical characteristics 00:46:23.168 --> 00:46:28.159 of the batteries. I mean, the, the defining technical 00:46:28.168 --> 00:46:30.300 characteristics, they've got lots of other benefits 00:46:30.309 --> 00:46:32.949 And, and I just want to say just to be clear because 00:46:32.958 --> 00:46:35.590 I think this is obvious there are a lot of batteries 00:46:35.599 --> 00:46:38.139 in the queue and they're the only thing that are coming 00:46:38.148 --> 00:46:42.300 and we want to encourage them to come. We're not talking 00:46:42.309 --> 00:46:44.679 about all those tens of gigawatts of batteries. We're 00:46:44.688 --> 00:46:48.159 talking about the ones that have obligated themselves 00:46:48.168 --> 00:46:51.989 to provide or their QSE is obligated them to provide 00:46:52.000 --> 00:46:54.978 an ancillary service, a reliability product that consumers 00:46:54.989 --> 00:46:58.809 are paying for. But, but that's all we're really doing 00:46:58.820 --> 00:47:01.989 is taking into account those unique technical characteristics 00:47:02.000 --> 00:47:05.429 of the, of the batteries. (item:33:Commissioner Cobos on stakeholders and ancillary services) But, but one signal for the 00:47:05.438 --> 00:47:08.820 batteries and their continued investment and development 00:47:08.829 --> 00:47:10.789 in a portfolio of revenues is the ancillary service 00:47:10.800 --> 00:47:15.878 market. Right. And um again, what I hear from stakeholders 00:47:15.889 --> 00:47:18.878 is some of them, they're all in different positions 00:47:19.110 --> 00:47:23.128 is that, well, this is better than the old version 00:47:23.139 --> 00:47:26.159 It's not great. It'll lessen our ability to participate 00:47:26.168 --> 00:47:30.300 in ancillaries and we'll certainly stat um, further 00:47:30.309 --> 00:47:33.469 development in longer duration batteries past, you 00:47:33.478 --> 00:47:38.099 know, two hours. So, you know, the batteries are coming 00:47:38.110 --> 00:47:40.000 but they're coming for a reason because there's, you 00:47:40.010 --> 00:47:41.949 know, revenue streams that they can take advantage 00:47:41.958 --> 00:47:45.159 of and, and um whether that's, you know, the real time 00:47:45.168 --> 00:47:48.590 market or, or definitely the, the day ahead ancillary 00:47:48.599 --> 00:47:52.639 service market, which is a more steady um source of 00:47:52.648 --> 00:47:59.349 revenue for resources. And so, um, you know, I'm just 00:47:59.360 --> 00:48:01.309 trying to figure out how we move forward. You know 00:48:01.320 --> 00:48:05.398 I, I have concerns as I've, I've laid out um, um, some 00:48:05.409 --> 00:48:09.849 of, you know, legal policy concerns. Um and I'm, I'm 00:48:09.938 --> 00:48:11.648 (item:33:Commissioner Cobos on appropriate path forward) I understand where you're trying to come from. You're 00:48:11.659 --> 00:48:14.128 trying, you're reacting to it to a new resource that 00:48:14.139 --> 00:48:15.989 you're trying to get your arms around and, and ERCOT 00:48:16.000 --> 00:48:18.389 does this right with wind, with solar now, batteries 00:48:19.429 --> 00:48:22.599 Um, but I'm, I'm not, I'm, I'm trying to figure out 00:48:22.610 --> 00:48:25.969 what the appropriate path forward is because I'm not 00:48:25.978 --> 00:48:28.829 sure that, you know, 1186 yes, you've gone back and 00:48:28.840 --> 00:48:31.478 you've corrected some issues. But again, waiting in 00:48:31.489 --> 00:48:34.760 the wings is NPRR1209. That has, I believe some problems 00:48:34.769 --> 00:48:39.820 and it's causing even more concern by the storage community 00:48:40.050 --> 00:48:44.478 So it's not just like, you know, 1186 got better. Well 00:48:44.489 --> 00:48:47.500 you gotta look at 1186 and 1209 because that's coming 00:48:47.510 --> 00:48:51.978 down the pike. Um, and, and trying to figure out what 00:48:51.989 --> 00:48:55.760 the best path forward is, we could reject the NPRR 00:48:55.769 --> 00:48:58.079 but is there a better path forward that we can kind 00:48:58.090 --> 00:49:03.389 of get, you know, move forward in with respect to, 00:49:04.530 --> 00:49:07.679 you know, trying to give you maybe a little more comfort 00:49:08.418 --> 00:49:12.809 and, and but also not creating barriers to battery 00:49:12.820 --> 00:49:17.208 participation in ancillary services, particularly ECRS 00:49:17.219 --> 00:49:18.869 as that's what we're trying to do over here in our 00:49:18.878 --> 00:49:20.668 market reform discussions. I went back and I read the 00:49:20.679 --> 00:49:23.628 transcripts, that's what we wanted to do with ECRS 00:49:23.639 --> 00:49:25.780 and we're not gonna get to batteries participating 00:49:25.789 --> 00:49:31.329 in nonspin if we continue down this path. (item:33:Commissioner Cobos on growth) And so I'm 00:49:31.340 --> 00:49:34.059 trying to plan for a future where we have tremendous 00:49:34.070 --> 00:49:38.648 population growth and economic growth and higher load 00:49:38.659 --> 00:49:41.860 growth and we need dispatchable resources and while 00:49:41.869 --> 00:49:43.820 batteries are not going to solve every issue and I 00:49:43.829 --> 00:49:45.269 always hear, well, they're not going to solve the multi 00:49:45.378 --> 00:49:49.728 day event. Well, multi day events are not 24/7 all 00:49:49.739 --> 00:49:52.500 the time, like Uri. We have multi day events like Elliot 00:49:52.510 --> 00:49:54.659 where we have our peaks and it goes down and then we 00:49:54.668 --> 00:49:57.860 flatten out. And so not every multi day event is gonna 00:49:57.869 --> 00:50:02.119 be 24/7, you know, all day long uh that you need 00:50:02.128 --> 00:50:05.829 your, your, your, the unit or the, the ESR to be participating 00:50:06.188 --> 00:50:09.030 So we got to take advantage of what we have now. We 00:50:09.039 --> 00:50:12.989 don't, we need resources now and we don't need to be 00:50:13.000 --> 00:50:15.510 throwing up barriers and I understand you wanna get 00:50:15.519 --> 00:50:17.719 comfortable, but we gotta get comfortable with where 00:50:17.728 --> 00:50:21.159 we're headed to in terms of reliability. So, so, so. 00:50:21.168 --> 00:50:25.519 (item:33:Commissioner McAdams on energy drops and ancillary commands) Here's an example that that may be, it must be so for 00:50:25.679 --> 00:50:31.099 um and again, it goes back to September 6th. So 00:50:31.110 --> 00:50:38.628 when you have that day where uh you've used 2181 megawatts 00:50:38.639 --> 00:50:41.750 of energy dispatched into the system, good electrons 00:50:41.760 --> 00:50:46.398 that we needed that day. Our operators did. And 00:50:46.409 --> 00:50:50.030 it drops down to 15%. That's a lot of energy uh being 00:50:50.039 --> 00:50:50.739 dispatched. 00:50:53.019 --> 00:50:58.159 Inevitably in the, in the scope of that dispatch event 00:50:58.489 --> 00:51:03.918 numerous ESRs would have been found in violation or 00:51:03.929 --> 00:51:08.909 potentially fined under the structure of 1186. I think 00:51:08.918 --> 00:51:11.599 it's possible because so much energy would have been 00:51:11.648 --> 00:51:15.269 firing off trying to meet both the energy signals and 00:51:15.280 --> 00:51:19.719 the ancillary commands being sent from ERCOT, especially 00:51:19.728 --> 00:51:21.728 in that, I mean, that was, that was a bang bang play. 00:51:21.739 --> 00:51:23.648 That was happening very quickly. I think your operators 00:51:23.659 --> 00:51:26.648 releasing services as well. So they wouldn't have had 00:51:26.659 --> 00:51:29.869 the obligation anymore because it was released. But 00:51:29.889 --> 00:51:34.219 bottom line is, if somebody's, again, there's a congestion 00:51:34.228 --> 00:51:36.449 point and there's a foul up on the transmission system. 00:51:36.458 --> 00:51:41.239 And so one, one battery is not able to dispatch at your command 00:51:41.250 --> 00:51:45.320 So QSC points to another one, they perform. Okay. That 00:51:45.329 --> 00:51:49.070 dispatches that congestion constraint for some reason 00:51:49.079 --> 00:51:52.329 comes back up during the event. So they've got power 00:51:52.340 --> 00:51:54.199 sitting in that battery, but they're still holding 00:51:54.208 --> 00:51:56.719 back because they are subject to a penalty under stated 00:51:56.728 --> 00:52:01.489 charge. Well, I would say because they've, they've 00:52:01.500 --> 00:52:06.139 committed to provide an ancillary service and we haven't 00:52:06.789 --> 00:52:09.679 released that ancillary service to let them be able 00:52:09.688 --> 00:52:12.418 to provide the energy. And so we're still in, in, in 00:52:12.429 --> 00:52:14.659 your hypothetical, but they would have comported with 00:52:14.668 --> 00:52:17.320 the performance obligation through another resource 00:52:17.628 --> 00:52:20.989 But that, that, that resource in particular is still 00:52:21.000 --> 00:52:23.360 holding energy because they're scared of the enforcement 00:52:23.369 --> 00:52:26.079 action to be taken on the state of charge requirement 00:52:26.168 --> 00:52:29.510 Well so okay actually, I've got something else. I'd 00:52:29.519 --> 00:52:30.250 like to say in a minute. 00:52:32.199 --> 00:52:34.728 Sure sure. And Barksdale and you, y'all take care. The, the, the 00:52:37.378 --> 00:52:41.688 in that case. (item:33:Dan Woodfin on releasing an ancillary service) We would, if we haven't released I mean 00:52:41.699 --> 00:52:43.719 if we've released the ancillary service, there's no 00:52:43.728 --> 00:52:47.148 compliance action because it's been released, we've 00:52:47.159 --> 00:52:49.918 deployed whatever that is ECRS, if they were holding 00:52:49.929 --> 00:52:53.519 that or responsive reserve, we release that. And so 00:52:53.530 --> 00:52:57.570 if we've done that. There's no I, I don't understand 00:52:57.590 --> 00:52:59.599 part of what we're doing with this. NPRR is trying 00:52:59.610 --> 00:53:02.820 to clarify exactly what those are what, what those 00:53:02.829 --> 00:53:05.628 compliance requirements are. Have at it Barksdale. Thank you, 00:53:05.639 --> 00:53:08.489 sir. (item:33:PUC Staff's Barksdale English on compliance clarifications) Barksdale English for Commission Staff. And, and I 00:53:08.500 --> 00:53:11.869 think what Dan is saying is, is 100% correct. That if 00:53:11.878 --> 00:53:16.769 a QSE has an ancillary service obligation and that 00:53:16.780 --> 00:53:21.010 QSC has multiple qualified resources that it represents 00:53:22.119 --> 00:53:25.918 if one of those resources is carrying that obligation 00:53:25.929 --> 00:53:29.579 on behalf of the QSC, but for one reason or another 00:53:29.590 --> 00:53:34.030 is incapable of providing that service, the QSC may 00:53:34.039 --> 00:53:37.889 shift that resources responsibility to another one 00:53:37.898 --> 00:53:41.139 of its qualified resources. The QSC may do that, the 00:53:41.148 --> 00:53:47.579 QSC may do that so long as the QSC is correctly communicating 00:53:47.659 --> 00:53:53.579 with ERCOT the change in resource obligation, there is 00:53:53.590 --> 00:53:58.148 no further enforcement or compliance activity after 00:53:58.159 --> 00:54:03.239 that. Additionally, if there is an ancillary service 00:54:03.250 --> 00:54:07.708 award to a resource and that ancillary service is dispatched 00:54:09.320 --> 00:54:13.369 once the dispatch occurs so long as that resource performs 00:54:13.378 --> 00:54:17.269 to its obligation, there is no further compliance or 00:54:17.280 --> 00:54:21.050 enforcement action after that. But for the next hour 00:54:21.228 --> 00:54:23.898 are we still dealing with hours here? It depends on what 00:54:23.909 --> 00:54:27.809 the award was for. So if the award was for one hour 00:54:27.820 --> 00:54:32.188 then as, as soon as the, the obligation concludes, 00:54:32.199 --> 00:54:35.628 so long as the resource performed during that obligated 00:54:35.639 --> 00:54:41.590 period, or the QSC switched the obligation to another 00:54:41.599 --> 00:54:46.378 resource that could provide and communicated that correctly 00:54:46.389 --> 00:54:49.929 to ERCOT. There's no problem. But again, what I'm trying 00:54:49.938 --> 00:54:52.280 and I apologize for beating this horse man. 00:54:53.889 --> 00:54:55.188 That is, that is 00:54:58.070 --> 00:55:01.500 that clears the QSE of the failure to provide. But 00:55:01.510 --> 00:55:04.599 what about the state of charge? (item:33:Barksdale English on the state of charge) The state of charge 00:55:04.610 --> 00:55:10.570 is, is simply it's a status that the asset itself has 00:55:10.820 --> 00:55:14.219 You can think of it. Dan gave the analogy of a high 00:55:14.250 --> 00:55:16.789 sustainable limit. You can also think of it in terms 00:55:16.800 --> 00:55:20.478 of a coal stack or, or how much natural gas has been 00:55:20.489 --> 00:55:24.938 nominated in the day ahead. The QSE understands the 00:55:24.949 --> 00:55:28.579 status of all of its assets that it, that it represents 00:55:29.119 --> 00:55:34.179 And if there are three assets in a hypothetical, one 00:55:34.188 --> 00:55:37.119 of them is carrying an ancillary service obligation 00:55:37.458 --> 00:55:40.550 The other two didn't nominate gas in the day ahead 00:55:40.559 --> 00:55:44.750 market. If the QSE switches that ancillary service 00:55:44.760 --> 00:55:48.530 obligation to one of those resources that has no natural 00:55:48.539 --> 00:55:53.110 gas available, that's a violation. I, I think the confusion 00:55:53.119 --> 00:55:57.878 here. (item:33:Commissioner Cobos on 1186's state of charge policy requirement) Is that 1186 contains a state of charge policy 00:55:57.889 --> 00:56:01.119 requirement that is that is being used to determine 00:56:01.128 --> 00:56:04.030 whether a battery is gonna be able to provide ancillary 00:56:04.039 --> 00:56:07.280 services. And if it and my understanding and Dan, please 00:56:07.289 --> 00:56:10.250 correct me because it sounds like if, if I'm wrong 00:56:10.260 --> 00:56:18.389 I it, it sounds like ERCOT will look and, and, and 00:56:18.398 --> 00:56:20.969 if that ancillary service, let's just say ECRS and 00:56:21.000 --> 00:56:24.559 ERCOT looks and they're not charged enough whether 00:56:24.570 --> 00:56:27.079 or not they provide ancillary services or, you know 00:56:27.090 --> 00:56:28.909 it doesn't matter, you weren't charging enough to provide 00:56:28.918 --> 00:56:31.219 it and it is a failure to provide. That's what it sounds 00:56:31.228 --> 00:56:33.719 like to me. Excuse me. I'm sorry for interrupting. 00:56:34.769 --> 00:56:37.250 (item:33:Barksdale English on thermal resource) We would do the same thing for a thermal resource as 00:56:37.260 --> 00:56:41.260 well. If a thermal resource has an ancillary service 00:56:41.269 --> 00:56:44.329 award and for one reason or another, we're conducting 00:56:44.340 --> 00:56:47.309 an investigation and we recognize that they did not 00:56:47.320 --> 00:56:50.699 nominate gas for the day on which they had that ancillary 00:56:50.708 --> 00:56:53.659 service obligation, we would enforce against that if 00:56:53.668 --> 00:56:55.659 you're conducting an investigation. But there's no 00:56:55.668 --> 00:56:58.849 established policy surrounding those units. Like there 00:56:58.860 --> 00:57:02.340 is for the energy storage. (item:33:Barksdale English on HSL) There is established policy. 00:57:02.349 --> 00:57:08.918 If you, if you switch the analogy from fuel to HSL 00:57:09.329 --> 00:57:12.789 then that policy does exist because all resource have 00:57:12.800 --> 00:57:19.739 to telemeter HSL ahead of time. And if the HSL is insufficient 00:57:19.750 --> 00:57:23.030 to cover the ancillary service obligation plus whatever 00:57:23.039 --> 00:57:25.708 that resource is providing in real-time energy, then 00:57:25.719 --> 00:57:26.780 that would get reported. 00:57:28.918 --> 00:57:32.409 I've asked ERCOT to say if there's been any instances of 00:57:32.418 --> 00:57:34.938 non compliance and they've been looking at the business 00:57:34.949 --> 00:57:37.128 practice manual. I'll ask you, have there been any 00:57:37.139 --> 00:57:40.500 instances of non compliance referred to you from ERCOT 00:57:40.929 --> 00:57:44.519 for QSEs that have, that represent storage companies? 00:57:45.269 --> 00:57:48.349 As I sit here right now, I'm not aware of any but 00:57:48.659 --> 00:57:50.239 you know, I'd have to go back and just double check 00:57:50.250 --> 00:57:53.208 that to make sure that I'm correct. Because I mean, those are issues 00:57:53.219 --> 00:57:59.699 we're not involved in, but I've heard very specific 00:57:59.708 --> 00:58:02.860 information. So I'm, I'm a little confused as to what's 00:58:02.869 --> 00:58:04.619 going on. If you don't know. 00:58:06.309 --> 00:58:09.199 We've kind of get some clarity around what the measuring 00:58:09.208 --> 00:58:12.500 stick is and that's what we're trying to do in 1186. 00:58:12.869 --> 00:58:17.090 So can I, can I ask another question? Barksdale, so 00:58:17.099 --> 00:58:20.449 a response that I got from ERCOT on this is um, 00:58:23.309 --> 00:58:25.760 ERCOT's position. 00:58:27.708 --> 00:58:30.300 Has been that failing to maintain sufficient state 00:58:30.309 --> 00:58:35.760 of charge violates PUC Rule 25.503, Subsection G(3). 00:58:36.760 --> 00:58:42.409 So set aside 1186. Do you believe that it already violates 00:58:42.418 --> 00:58:46.750 the state of charge provision in our rule? (item:33:Barksdale English on violations to the state of charge provision) I, I think 00:58:46.760 --> 00:58:50.039 if I recall in the business, that's where they refer 00:58:50.050 --> 00:58:52.539 to that in the business practices, man. Well, first 00:58:52.550 --> 00:58:54.780 I'll say the business practice manual is not enforceable. 00:58:54.909 --> 00:58:59.849 They say that too. Second, I think if I recall subsection 00:58:59.860 --> 00:59:02.699 G(3) correctly. I looked at it last night with Harika and 00:59:03.219 --> 00:59:03.269 Ramya. 00:59:05.090 --> 00:59:11.739 I believe that as of this moment in time, if QSE representing 00:59:11.750 --> 00:59:16.250 a battery does not operate that battery in a way to 00:59:16.260 --> 00:59:19.309 meet its ancillary service obligation. That is a violation 00:59:19.320 --> 00:59:24.688 of our current rules G(3) as well as F(6). 00:59:28.239 --> 00:59:30.619 And what about for any other resource type for any 00:59:30.628 --> 00:59:31.750 other resource type as well? 00:59:33.409 --> 00:59:37.289 How do you determine for any other resource type? Do 00:59:37.300 --> 00:59:41.878 you, do we make phone calls to the gas companies to 00:59:41.889 --> 00:59:45.260 ensure that they have gas online when there's a ancillary 00:59:45.269 --> 00:59:48.559 service obligation. I will be the first to admit that 00:59:48.570 --> 00:59:52.918 the requirement to provide state of charge ahead of 00:59:52.929 --> 00:59:58.909 time is different than what we require of thermal resources 00:59:59.840 --> 01:00:02.969 in terms of their fuel availability. 01:00:05.208 --> 01:00:09.128 That being said the policy may or may not be right 01:00:09.159 --> 01:00:12.469 on an interim basis as the operator gets more and more 01:00:12.478 --> 01:00:15.610 used to dealing with the batteries. Whether that's 01:00:15.619 --> 01:00:18.510 a thing that we want to enforce against. I think is 01:00:18.519 --> 01:00:21.469 a matter of policy because we do have the discretion 01:00:22.219 --> 01:00:25.728 to enforce against certain things. I would advise you 01:00:25.739 --> 01:00:29.438 that at a minimum. You, you should be enforcing against 01:00:29.449 --> 01:00:32.760 reliability violations for ancillary services that 01:00:32.769 --> 01:00:35.719 are not provided after the fact. And I totally agree 01:00:35.728 --> 01:00:39.119 with you. I don't want to mince my words and that is 01:00:39.128 --> 01:00:41.869 if you have a, if you're bidding into the ancillary 01:00:41.878 --> 01:00:45.000 service market and you're selected for a product and 01:00:45.010 --> 01:00:48.898 you fail to provide, there is a penalty structure in 01:00:48.909 --> 01:00:51.559 place and an enforcement structure in place that should 01:00:51.570 --> 01:00:56.128 be pursued. Yes, I totally agree with that. If I may 01:00:56.139 --> 01:00:59.510 Chair, just address one other thing. (item:33:Barksdale English on enforcement) Commissioner Cobos 01:00:59.519 --> 01:01:05.610 I, I heard you wonder about. Excuse me. The, the legality 01:01:05.619 --> 01:01:09.489 of enforcing against QSEs instead of resource entities. 01:01:10.269 --> 01:01:16.208 And excuse me. I'm just treading very carefully here. 01:01:16.219 --> 01:01:19.750 I would like to just ask for caution when we talk about 01:01:19.760 --> 01:01:25.349 this because it's the fundamental regulatory paradigm 01:01:25.378 --> 01:01:30.699 of how ERCOT works. ERCOT only talks to QSEs. QSEs that 01:01:30.708 --> 01:01:34.280 represent load and QSEs that represent resources. 01:01:34.849 --> 01:01:38.320 All of your enforcement that occurs here is against 01:01:38.329 --> 01:01:42.679 QSEs. And so as a matter of policy, if that's a 01:01:42.688 --> 01:01:46.708 thing that you, you want to discuss. Then I would respectfully 01:01:46.719 --> 01:01:50.679 ask that we do that very, very deliberately. (item:33:Commissioner Cobos on follow-up communication) And I 01:01:50.688 --> 01:01:53.478 would also respectfully ask that when I request to 01:01:53.489 --> 01:01:56.110 know what it gets referred to you from ERCOT in enforcement 01:01:56.119 --> 01:01:58.418 proceedings. That you actually follow back up with me. 01:01:58.530 --> 01:02:00.699 Because I asked days ago and I still don't have an 01:02:00.708 --> 01:02:03.780 answer as to. You know, you're the head of enforcement 01:02:03.789 --> 01:02:05.728 you should be able to tell me that answer. And I still 01:02:05.739 --> 01:02:07.760 don't have an answer. Because all I'm trying to do is 01:02:07.769 --> 01:02:11.168 find what has actually happened. What non-compliance 01:02:11.179 --> 01:02:13.500 has actually happened. ERCOT has provided me what they 01:02:13.510 --> 01:02:19.829 have. But it sounds like you might have information 01:02:19.840 --> 01:02:24.280 that on some referrals that I, I still haven't received. 01:02:24.349 --> 01:02:26.179 You can take a look at the email that I sent to 01:02:26.188 --> 01:02:28.800 your office last week while I was on vacation to answer that question. Right, 01:02:28.809 --> 01:02:33.110 but that was, that was an inquiry on storage developers. 01:02:33.119 --> 01:02:34.869 I asked you a different question that I still don't 01:02:34.878 --> 01:02:37.398 have an answer to. I'll be happy to talk with you offline. 01:02:37.610 --> 01:02:41.409 Okay. (item:33:Chairwoman Jackson question on battery operator's perspective) So we've had a lot of discussion I think about 01:02:41.418 --> 01:02:45.050 in the passive which has been good. But I'd like 01:02:45.059 --> 01:02:48.369 to take an opportunity to ask uh Dan, a question that's 01:02:48.378 --> 01:02:52.728 more maybe in the active. And um to kind of ask you 01:02:52.739 --> 01:02:55.438 you know, from an operator's perspective. If you could 01:02:55.510 --> 01:03:00.010 literally paint the picture of us sitting in that console 01:03:00.019 --> 01:03:03.619 operator's chair. Can you kind of share with us um 01:03:03.628 --> 01:03:06.889 from that operator's perspective you know, having 01:03:06.898 --> 01:03:13.199 1186. Um how in, in your mind, does that impact that 01:03:13.208 --> 01:03:19.360 ability of that operator to um to, to maybe better 01:03:19.369 --> 01:03:23.010 optimize the system, better utilize the resources uh 01:03:23.030 --> 01:03:24.599 of the batteries? 01:03:27.570 --> 01:03:31.438 Yeah. (item:33:Dan Woodfin on operations) So with, with the changing resource mix, you 01:03:31.449 --> 01:03:33.840 know, not, not only on the supply side, but the demand 01:03:33.849 --> 01:03:36.070 side, more price, responsive demand and those kind 01:03:36.079 --> 01:03:39.228 of things that we've got a lot more uncertainty in 01:03:39.239 --> 01:03:43.599 operating the system than we've ever had. And uh because 01:03:43.610 --> 01:03:48.869 of that, the way we manage that uncertainty largely 01:03:48.878 --> 01:03:54.398 is through our ancillary services. And so um so that 01:03:54.409 --> 01:03:57.619 when a unit trips or when the wind doesn't blow or 01:03:57.628 --> 01:04:01.478 the sun doesn't shine or large flexible loads don't 01:04:01.489 --> 01:04:04.039 turn off the way we think they're going to on a particular 01:04:04.050 --> 01:04:07.090 day, we've got to have something to balance the system 01:04:07.389 --> 01:04:10.239 uh and make sure that we don't cause a bigger problem 01:04:10.250 --> 01:04:12.570 And the way we do that is through our ancillary services 01:04:12.898 --> 01:04:15.659 And so ancillary services are becoming as, as, as the 01:04:15.668 --> 01:04:21.019 system becomes less certain, more, more variability 01:04:21.320 --> 01:04:24.590 We're leaning on those ancillary services more and 01:04:24.599 --> 01:04:27.610 more and that's one of the reasons that that the quantities 01:04:27.619 --> 01:04:30.708 have gone up, it's also the reason we added the ECRS 01:04:30.719 --> 01:04:34.228 service, but that, that, that's happening. And if we 01:04:34.239 --> 01:04:36.059 want to maintain the reliability system, that's what 01:04:36.070 --> 01:04:40.398 has to happen. And so the next level of that is that 01:04:40.409 --> 01:04:42.269 we're depending on the ancillary services, that means 01:04:42.280 --> 01:04:47.780 when we need them, we're expecting them to be there 01:04:47.789 --> 01:04:50.909 and we're expecting them to be there and able to provide 01:04:51.239 --> 01:04:56.128 for a long enough period of time that then we can get 01:04:56.139 --> 01:04:59.239 the next ancillary service online. And we put that 01:04:59.250 --> 01:05:01.820 back into the reserve for the next thing that could 01:05:01.829 --> 01:05:05.429 go wrong. And so that, that, that's just how we're 01:05:05.438 --> 01:05:08.019 using ancillary services and, and it's, it's a function 01:05:08.030 --> 01:05:11.250 of the changing system that we're operating. And so 01:05:11.260 --> 01:05:13.829 it's really important for us to, to make sure that 01:05:13.840 --> 01:05:17.119 we're back to my flat tire analogy. We need to make 01:05:17.128 --> 01:05:21.250 it. It's one thing if you're driving down uh I-35 to 01:05:21.260 --> 01:05:25.300 to San Antonio. There's, you know, good chance that 01:05:25.309 --> 01:05:27.260 the other cars that are gone in front of you are going 01:05:27.269 --> 01:05:29.110 to pick up all the nails and you're not going to have 01:05:29.119 --> 01:05:32.579 a flat. But if you're driving through and down a road 01:05:32.590 --> 01:05:36.030 in West Texas, there's much more chance that you're 01:05:36.039 --> 01:05:38.849 gonna run over a flat, uh run over a nail and, and 01:05:38.860 --> 01:05:41.599 get a flat. And so if you're driving in that, that 01:05:41.610 --> 01:05:46.079 more uncertain world, you need to make even more sure 01:05:46.090 --> 01:05:49.760 that, that your, your tires have sufficient air in 01:05:49.769 --> 01:05:52.010 them. And I think that's what we're trying to do is 01:05:52.019 --> 01:05:55.398 clarify that this is the, this is the, the rules we're 01:05:55.409 --> 01:05:58.010 going to use for making sure that we've got enough 01:05:58.019 --> 01:06:00.438 air in that tire that we've got enough reserves on 01:06:00.449 --> 01:06:07.599 the system, uh to, to, to, um, manage that system that's 01:06:07.610 --> 01:06:10.478 much more uncertain than what it's historically been. 01:06:11.478 --> 01:06:13.898 (item:33:Chairwoman Jackson question on 1186's overall objective) So the specific parameters that we're talking about 01:06:13.909 --> 01:06:20.820 in 1186 can you, you know, talk more specifically about 01:06:20.829 --> 01:06:24.510 those and how that helps you to accomplish your overall 01:06:24.519 --> 01:06:27.599 objective? Because I'm assuming that's the whole rationale 01:06:27.610 --> 01:06:30.409 why it was put in the practices manual. That's why 01:06:30.418 --> 01:06:34.708 it became 1186 is because it provides some overall benefit 01:06:34.719 --> 01:06:37.409 to the system as a whole that you would have, that 01:06:37.418 --> 01:06:41.659 you otherwise wouldn't have. (item:33:Dan Woodfin on 1186's overall objective) So it's, it's if 01:06:41.668 --> 01:06:47.369 you're assessing whether a particular QSE has the capability 01:06:47.378 --> 01:06:50.010 of providing the ancillary services that we're paying 01:06:50.019 --> 01:06:54.918 for, that consumers of Texas are paying for. Um does 01:06:54.929 --> 01:06:58.869 that uh do the resources, how, how are we gonna assess 01:06:58.878 --> 01:07:01.269 where the resources that make up that portfolio that 01:07:01.280 --> 01:07:03.449 they're pointing to at that point in time, have the 01:07:03.458 --> 01:07:05.929 capability of providing those ancillary services or 01:07:05.938 --> 01:07:08.688 not? And so it's really a question of how, how do you 01:07:08.699 --> 01:07:13.389 assess that? And right now with the business practice 01:07:13.398 --> 01:07:19.228 document not being binding, we need 1186 to be able 01:07:19.239 --> 01:07:23.070 to tell them and to, for us to know this is how 01:07:23.349 --> 01:07:26.228 they, they will have sufficient state of charge that 01:07:26.280 --> 01:07:28.760 if we need to deploy that ancillary service at that 01:07:28.769 --> 01:07:33.179 point in time, it will be there to provide what we're 01:07:33.188 --> 01:07:38.208 paying for. That makes sense. Um I mean, that's really 01:07:38.219 --> 01:07:42.119 the point we had one. (item:33:Ramya Ramaswamy on three definitions being added 1186) So the three definitions that 01:07:42.128 --> 01:07:47.128 are being added in 1186 which is the minimum SOC, the 01:07:47.139 --> 01:07:49.969 maximum SOC. I forget the third one. 01:07:53.789 --> 01:08:00.409 And so it is those three definitions that allow for 01:08:00.418 --> 01:08:06.500 extra information on what the capability, capability 01:08:06.510 --> 01:08:10.070 of the battery is at any point. So those definitions 01:08:10.079 --> 01:08:11.809 definitely uh help. 01:08:13.530 --> 01:08:16.609 (item:33:Dan Woodfin on planned SOC) Oh, that's good. Our beginning planned SOC. So that 01:08:16.619 --> 01:08:20.878 that, that is one where that allows the QSE by setting 01:08:20.890 --> 01:08:27.020 that let us, let them use SCED to manage their dispatch 01:08:27.029 --> 01:08:29.649 in such a way that they can maintain the, the state 01:08:29.659 --> 01:08:31.819 of charge that they need to provide the ancillary service. 01:08:32.970 --> 01:08:35.609 (item:33:Chairwoman Jackson's question on the benefits of 1186) So from an operator's perspective, they're wanting 01:08:35.619 --> 01:08:40.069 to know what is going on in real time and they're also 01:08:40.628 --> 01:08:44.520 wanting to know what's going to happen in, in the near 01:08:44.529 --> 01:08:49.270 term so that if conditions change that they're better 01:08:49.279 --> 01:08:52.259 prepared to be able to respond. And so I guess what 01:08:52.270 --> 01:08:54.569 I'm searching for is we've got different parameters 01:08:54.579 --> 01:08:58.189 we've got different um definitions. So, is there a 01:08:58.199 --> 01:09:03.289 way to kind of quantify what that benefit is kind of 01:09:03.298 --> 01:09:05.600 going forward with 1186? 01:09:13.618 --> 01:09:14.038 Um 01:09:19.180 --> 01:09:22.970 I, I guess certainly I guess there, there is a provision. 01:09:22.979 --> 01:09:25.109 (item:33:Dan Woodfin on the benefits on 1186) I mean part, part of this is reporting so that we're 01:09:25.119 --> 01:09:27.958 doing calculations of, we're setting what the, what 01:09:27.970 --> 01:09:31.270 the, what the parameters are, the, the what the minimum 01:09:31.279 --> 01:09:34.000 state of charge is at each point in time during the 01:09:34.009 --> 01:09:36.359 hour. It's that curve I showed at the board meeting 01:09:36.689 --> 01:09:41.048 And, and we're also start calculating whether QSEs 01:09:41.060 --> 01:09:44.500 are preserving enough in their portfolio to, to manage 01:09:44.509 --> 01:09:50.259 that. And so um part of the benefit of 1186 is that 01:09:50.668 --> 01:09:54.088 doing the calculations and having an assessment. So 01:09:54.100 --> 01:09:56.250 we will be able to measure whether people are doing 01:09:56.259 --> 01:10:01.270 it or not as a result of it of 1186. I guess 01:10:01.279 --> 01:10:03.220 what I'm searching for is how does it make the overall 01:10:03.229 --> 01:10:08.279 system more efficient and more reliable? Well. Why is this 01:10:08.289 --> 01:10:11.409 a good thing for you, Dan? So why is this good for ERCOT? (item:33:Dan Woodfin on why 1186 is needed) Maybe 01:10:11.418 --> 01:10:14.079 I can explain it the other way. Why, why what's bad 01:10:14.088 --> 01:10:17.810 if we don't have it? So we have a bad day and 01:10:17.819 --> 01:10:22.140 we need to deploy an ancillary service and we tell 01:10:22.149 --> 01:10:26.239 right now, QSE could be telling us they've got 1000 01:10:26.250 --> 01:10:29.850 megawatts of reserves and this actually happened during 01:10:29.859 --> 01:10:35.890 the uh September 6th event that um we uh I, I don't 01:10:35.899 --> 01:10:38.829 think we're gonna go into that today, but that's ok 01:10:38.838 --> 01:10:42.220 Well the so our, our PRC our physical responsive 01:10:42.229 --> 01:10:46.439 capability on that day was 500 some odd megawatts less 01:10:46.588 --> 01:10:49.939 than what we were calculating from the input data we 01:10:49.949 --> 01:10:53.470 were getting from all the different QSEs. And a portion 01:10:53.479 --> 01:10:56.930 of that was from thermal resources that couldn't quite 01:10:56.939 --> 01:11:00.298 get to the HSL that they were reporting to us. But 01:11:00.310 --> 01:11:04.470 there's no require the, the, we did an NPRR1185 a 01:11:04.479 --> 01:11:07.458 year or so ago that said there's some, there's some 01:11:07.470 --> 01:11:10.588 bandwidth around what they have to report to us. And 01:11:10.600 --> 01:11:14.109 so they may have been off by less than 5% or 10 01:11:14.119 --> 01:11:18.088 megawatts per unit. But in the aggregate, that wound 01:11:18.100 --> 01:11:21.739 up being more megawatts across all the thermal fleet 01:11:21.859 --> 01:11:25.369 we also had some storage resources that were telling 01:11:25.378 --> 01:11:28.560 us that they had 100, I think it was 112 01:11:28.569 --> 01:11:32.409 megawatts, 113 megawatts of capacity that was available 01:11:32.418 --> 01:11:35.289 but they were really out of state of charge. And so 01:11:35.298 --> 01:11:38.329 they couldn't really get to that, that amount. And 01:11:38.338 --> 01:11:41.869 so we had much less PRC than, than what we were reporting. 01:11:41.878 --> 01:11:45.100 (item:33:Dan Woodfin on how 1186 can help improve reliability) So that, that, that is an example uh where, where it 01:11:45.109 --> 01:11:49.789 was a, it was a bad day. If those megawatts had been 01:11:49.798 --> 01:11:52.569 some that we were counting on for ancillary services 01:11:52.579 --> 01:11:55.918 and we deployed the ancillary services to solve a reliability 01:11:55.930 --> 01:11:58.458 problem. And yet they didn't have any juice in the 01:11:58.470 --> 01:12:02.199 tank or didn't have enough juice in the tank, then 01:12:02.208 --> 01:12:03.939 we would potentially have to shed load. 01:12:06.458 --> 01:12:09.369 Is that if 1186 had been in place. Would you have the 01:12:09.378 --> 01:12:11.259 date and the information you needed to make a better 01:12:11.270 --> 01:12:14.378 decision? They should have been maintaining sufficient 01:12:14.390 --> 01:12:17.060 state of charge to be able to provide the ancillary 01:12:17.289 --> 01:12:20.529 service for the, for the ancillaries. But the PRC is 01:12:20.539 --> 01:12:25.359 not just, I mean, that's, I agree, I'm mixing two things 01:12:25.369 --> 01:12:27.668 there a little bit. But what about the reverse hypothetical 01:12:27.680 --> 01:12:30.649 that, you know, all of a sudden, you know, you need 01:12:30.659 --> 01:12:33.289 every Megawatt you can get and your state of charge 01:12:33.298 --> 01:12:37.239 requirement is um causing a negative effect and you 01:12:37.250 --> 01:12:40.798 can't get the power in because they're afraid of $25,000 01:12:41.628 --> 01:12:45.298 or whatever they were loaded. (item:33:Dan Woodfin on releasing ancillary services & reserves) But, but, but if they're 01:12:45.310 --> 01:12:48.649 providing ancillary services, then we. That, that's 01:12:48.659 --> 01:12:52.453 a reserve. We hold it in reserve, we've paid for it 01:12:52.462 --> 01:12:55.012 or the consumers of Texas have paid for it. We're holding 01:12:55.021 --> 01:12:58.862 it in reserve to protect against unit trips and really 01:12:58.872 --> 01:13:02.432 bad things that could happen. Right. And so we need 01:13:02.442 --> 01:13:05.002 it to be there. And then if it gets to the point 01:13:05.012 --> 01:13:08.152 where we're running out of energy, otherwise we'll 01:13:08.162 --> 01:13:11.085 start to release those ancillary services. And that's 01:13:11.095 --> 01:13:13.645 what you saw us doing on September 6th, we started 01:13:13.654 --> 01:13:17.555 to release nonspin, then we release ECRS. Ultimately 01:13:17.564 --> 01:13:21.125 we released some responsive reserve, all of that gets 01:13:21.136 --> 01:13:24.064 released so that you can turn it into energy and actually 01:13:24.076 --> 01:13:28.225 serve load because at that point, it's less risky to 01:13:28.234 --> 01:13:33.509 to, to forgo your reserves than it is to not serve 01:13:33.520 --> 01:13:36.720 load. And so that's really what we're, we're doing 01:13:36.729 --> 01:13:40.939 in those cases. Then why don't you just release a battery 01:13:40.949 --> 01:13:43.569 without penalty if they don't have the state of charge 01:13:43.579 --> 01:13:45.350 and just go to the next one and allow them to go 01:13:45.359 --> 01:13:47.220 into the energy market? Well, in this case, that's 01:13:47.229 --> 01:13:49.680 all we've got left. I mean, effectively, that's all 01:13:49.689 --> 01:13:52.369 we've got left is what, what's in reserve at that point 01:13:52.378 --> 01:13:55.199 before we start to release them. I mean, I guess again 01:13:55.208 --> 01:13:58.829 (item:33:Commissioner Glotfelty on facilities providing their ancillary service obligation) I, I struggle with this because if you have a gas plant 01:13:58.838 --> 01:14:01.789 that is providing an ancillary service and it trips 01:14:03.430 --> 01:14:06.430 and it cannot provide its ancillary service obligation 01:14:06.609 --> 01:14:10.409 Next man up, you all go to the next resource in the 01:14:10.418 --> 01:14:13.770 ancillary service stack and provide that re and provide 01:14:13.779 --> 01:14:17.180 that ancillary service. If the 01:14:18.850 --> 01:14:21.060 no, no, no, even if, even if it has to go to 01:14:21.069 --> 01:14:25.479 a different QSE, even if the ancillary service 01:14:27.039 --> 01:14:31.439 is out, if all of the ancillary services resources 01:14:31.449 --> 01:14:38.079 are deployed in, if all of the QSE ancillary services 01:14:38.088 --> 01:14:41.779 are deployed and you have a gas plant that trips. What 01:14:41.789 --> 01:14:45.609 happens? Well, from a system perspective, we're going 01:14:45.619 --> 01:14:47.708 to try to balance generation load and we'll use whatever 01:14:47.720 --> 01:14:51.810 we can. But from that QSES perspective, then they will 01:14:51.819 --> 01:14:54.458 have a failure to provide. That's right. That's my 01:14:54.470 --> 01:14:57.989 point. That's exactly right. (item:33:Commissioner Glotfelty on risk free options for revenue) The market has a mechanism 01:14:58.000 --> 01:15:01.659 to solve for that, which is they will fail to provide. 01:15:02.039 --> 01:15:04.708 They will meet Barksdale and they'll have a great lunch 01:15:04.720 --> 01:15:08.069 with Barksdale. And they won't ever want to do it again. 01:15:10.619 --> 01:15:14.048 Because the market will fix itself and it will function 01:15:14.060 --> 01:15:16.810 And the financiers of those plants are going to say 01:15:17.279 --> 01:15:20.560 don't you ever do that again? Don't you ever go into 01:15:20.569 --> 01:15:24.060 a queasy? That only, that has no other resources, don't 01:15:24.069 --> 01:15:28.689 you ever go into XY and Z because they need risk free 01:15:28.699 --> 01:15:30.000 options for revenue? 01:15:31.509 --> 01:15:35.350 That's the way I view it. So I, I had a Commissioner 01:15:35.619 --> 01:15:37.859 Cobos asked while ago, is there, is there a plan forward 01:15:37.869 --> 01:15:41.208 on this? (item:33:Dan Woodfin's thoughts on 1209 vs. 1186) And I, I guess maybe there is an idea that 01:15:41.220 --> 01:15:45.859 that, you know, 1209 is not in front of you today. 01:15:45.869 --> 01:15:49.310 It's, it's still in the stakeholder process. Everybody 01:15:49.319 --> 01:15:51.970 back here has heard what went on in the state, what 01:15:51.979 --> 01:15:54.479 you've talked about today. And so, and there's actually 01:15:54.489 --> 01:15:58.729 a PRS meeting to talk about it in a few minutes. And 01:15:58.739 --> 01:16:04.600 so, so that, that one's still in play. And so 01:16:04.609 --> 01:16:07.640 we can talk about that one when, when it, you know 01:16:07.649 --> 01:16:13.109 that comes. 1186 really is more about how do you assess 01:16:13.119 --> 01:16:15.720 providing some certainty is what product we're buying 01:16:15.729 --> 01:16:20.109 and what product they're selling. Uh There is one paragraph 01:16:20.119 --> 01:16:25.298 in there that's actually in a gray box that says what's 01:16:25.310 --> 01:16:28.640 in the black line language says that you will uh 01:16:30.259 --> 01:16:32.930 that, that we will if, if they're not meeting their 01:16:32.939 --> 01:16:36.668 their state of charge requirements, given some parameters 01:16:36.890 --> 01:16:40.149 We'll tell the QSE, we'll do the assessment and we'll 01:16:40.159 --> 01:16:44.000 tell the QSE what that they're not meeting it and we'll 01:16:44.009 --> 01:16:45.979 do that for at least three months. Then there's some 01:16:45.989 --> 01:16:51.039 gray line gray box language that says if you, uh, uh 01:16:51.418 --> 01:16:56.399 if you, after that three, at least three months, we 01:16:56.409 --> 01:16:58.850 will report, if they're not meeting that state of charge 01:16:58.859 --> 01:17:02.319 requirement, we will report them to the, the reliability 01:17:02.329 --> 01:17:05.319 monitor and then it goes through that reliability monitor 01:17:05.329 --> 01:17:08.819 and they ultimately meet Barksdale, um, potentially. 01:17:08.829 --> 01:17:13.310 But that's completely, one is in gray box at this point 01:17:13.329 --> 01:17:16.449 And two, what does gray gray box means? It's not in 01:17:16.458 --> 01:17:17.208 effect 01:17:19.418 --> 01:17:24.128 and, and two, it's, you know, there's all, there's 01:17:24.140 --> 01:17:26.470 it's completely in y'all's control as to whether they 01:17:26.479 --> 01:17:28.878 actually get any kind of penalty. So it's really back 01:17:28.890 --> 01:17:33.359 to, to Commissioner Glotfelty's option three. I think 01:17:33.369 --> 01:17:33.958 it was, 01:17:36.009 --> 01:17:39.369 yeah, require the obligation to continue to work with 01:17:39.378 --> 01:17:42.489 you all. Look at state of charge but not, but eliminate 01:17:42.500 --> 01:17:46.539 the penalty section. Yeah. And so, so that's a, that's 01:17:46.548 --> 01:17:50.569 that's a possibility, I guess not, not the, not the 01:17:50.579 --> 01:17:55.319 that is a potential way forward, not to turn down 1209 01:17:55.329 --> 01:17:57.878 now because I think it's one is not in front of you 01:17:57.890 --> 01:18:01.220 and two, it's, it's, um, uh, there are some things 01:18:01.229 --> 01:18:04.789 in there we probably need, even if you don't want the 01:18:04.798 --> 01:18:10.220 the, some of the, the uh penalty structure. (item:33:Dan Woodfin on 1186's gray box) But as 01:18:10.239 --> 01:18:13.199 far as 1186 goes, that one box is the only thing in 01:18:13.208 --> 01:18:15.548 question and, and there's a lot of flexibility about 01:18:15.560 --> 01:18:18.479 whether or when that gets enforced. 01:18:21.239 --> 01:18:25.539 Is that a potential? Ok. Can we just hear from? Can 01:18:25.548 --> 01:18:28.418 I just have a question to Dan? May I ask him? Can 01:18:28.449 --> 01:18:32.930 you also the engine, the impact of 1186 so it can improve 01:18:32.949 --> 01:18:35.649 the engine? Can you ask 01:18:37.579 --> 01:18:40.298 for just a moment? It's a, it's an important discussion 01:18:40.310 --> 01:18:42.899 But if, if you all can be careful to not talk over 01:18:42.909 --> 01:18:45.140 each other, it's going to be better for the transcript 01:18:47.199 --> 01:18:50.750 Could you ask it again, but in the mic? Yeah, sorry. Can you talk 01:18:50.759 --> 01:18:54.588 about the impact of 1186 improvement on the R engine 01:19:00.069 --> 01:19:01.029 Yeah, so I, 01:19:02.689 --> 01:19:06.020 I don't think 1186 is affecting the rock engine 01:19:07.689 --> 01:19:11.979 SCED only it helps, it helps the QS to maintain the 01:19:11.989 --> 01:19:14.708 state of charge through the base points that they get 01:19:15.489 --> 01:19:15.520 in. 01:19:18.149 --> 01:19:22.689 I don't think so that we'd like for it to, but that's 01:19:22.699 --> 01:19:25.668 going to have to come in RTC plus B. Dan, if you 01:19:25.689 --> 01:19:27.159 can speak into the microphone, the court reporters 01:19:27.168 --> 01:19:32.109 having trouble hearing you. Ok, Dan. Oh, that was me 01:19:32.250 --> 01:19:33.668 I thought I was. Thank you. 01:19:36.939 --> 01:19:40.270 Uh Dan, you. I'd like to take some time to review the 01:19:40.279 --> 01:19:43.329 gray box language. Um We've had a lot of discussion 01:19:43.338 --> 01:19:45.930 here and a lot of different issues raised and, and 01:19:45.939 --> 01:19:49.100 I just, so I'm just So I understand what your proposal 01:19:49.109 --> 01:19:53.720 is. Is that um, kind of let NPRR1209 work 01:19:53.729 --> 01:19:58.369 itself out because it's not before us. Um, but look at 01:19:58.759 --> 01:20:03.560 um, 1186 through the auspices of Commissioner Glotfelty's 01:20:03.569 --> 01:20:08.939 um, option number three and think about, I believe 01:20:08.949 --> 01:20:10.640 I heard this but correct me if I'm wrong stripping 01:20:10.649 --> 01:20:11.628 out that section 01:20:13.259 --> 01:20:16.548 8.1. (item:33:Dan Woodfin on reporting non compliance) Well it's not, it's not all of Section 8. 01:20:16.560 --> 01:20:22.180 It's really just the gray box that's on page 74. Ok 01:20:22.189 --> 01:20:23.789 Yes, it's the new um, 01:20:25.310 --> 01:20:26.689 8.14 01:20:28.250 --> 01:20:32.930 that wouldn't be. And so even, even if that gray 01:20:32.939 --> 01:20:37.430 box became in effect, we could still report the non 01:20:37.458 --> 01:20:40.418 compliance to the end of the reliability monitor process 01:20:40.869 --> 01:20:43.029 But then it's up to the Commission to decide whether 01:20:43.039 --> 01:20:45.060 there would be any kind of penalties associated with 01:20:45.069 --> 01:20:48.750 that. So the stripping would be 4 in the gray box. 01:20:48.770 --> 01:20:51.039 Just so I'm clear that either we could strip it or 01:20:51.048 --> 01:20:52.259 or not. Ok. 01:20:55.289 --> 01:20:59.128 In fact you could, you could approve 1186 today 01:21:00.680 --> 01:21:04.588 and then we could delay and just not implement that 01:21:04.600 --> 01:21:08.079 gray box. Your lawyer is shaking his head. No, behind 01:21:08.088 --> 01:21:11.569 you. The problem with sitting here is that you can't 01:21:11.579 --> 01:21:13.088 see what's going on back there. 01:21:19.390 --> 01:21:24.338 Take some time to think about that. So Madam Chair, may I 01:21:24.350 --> 01:21:31.140 ask a question? Sure. Okay Dan, the necessity of timely approval 01:21:31.149 --> 01:21:36.918 today versus potentially the 14th, our next open meeting 01:21:38.539 --> 01:21:42.180 so that we can continue to address this with our look 01:21:42.189 --> 01:21:44.418 there are stakeholders that are super nervous behind 01:21:44.430 --> 01:21:49.259 you. The San Antonio Express is super nervous, clearly 01:21:49.689 --> 01:21:55.199 almost 1200 words or whatever. So how important is 01:21:55.208 --> 01:21:59.009 timely adoption today in terms of operationalization 01:22:03.708 --> 01:22:07.338 I don't see any help back there. The the the um 01:22:09.699 --> 01:22:13.039 (item:33:Dan Woodfin on importance of a timely implementation of 1186) I think the 14th is probably OK, the 14th of December 01:22:13.759 --> 01:22:18.319 Yeah. Ok. Um I, I that's probably ok. That's not a significant 01:22:18.329 --> 01:22:21.259 delay. If we start delaying it longer than that. The 01:22:21.270 --> 01:22:23.759 same people that need to work on this are working on 01:22:23.770 --> 01:22:26.640 lots of other projects and it starts to potentially 01:22:26.649 --> 01:22:29.378 affect things like RTC and so forth and we don't want 01:22:29.390 --> 01:22:32.208 to do that. And so it would be better to go ahead 01:22:32.220 --> 01:22:34.739 and get a timely resolution, especially if we can come 01:22:34.750 --> 01:22:37.680 out with a something like this where we're going ahead 01:22:37.689 --> 01:22:43.609 and implementing 1186 but without that box, so does 01:22:43.619 --> 01:22:47.289 1186 take resources away from RTC. 01:22:49.149 --> 01:22:54.588 (item:33:Dan Woodfin on taking away resources from RTC) Not if we go ahead and do it soon. If we 01:22:54.600 --> 01:22:57.759 if we delayed until January or February and had some 01:22:57.770 --> 01:23:00.869 other process, then yes, I mean, my, my view, I think 01:23:00.878 --> 01:23:04.628 Commissioner Cobos as well is like RTC plus B is the 01:23:04.640 --> 01:23:07.449 most important thing that you all can do. Right now 01:23:07.458 --> 01:23:09.378 If we go ahead and do it, you know, within the next 01:23:09.390 --> 01:23:11.869 couple of weeks, we're going ahead and doing some of 01:23:11.878 --> 01:23:15.423 the the coding and making it where it's not the, it's 01:23:15.435 --> 01:23:18.244 parameterized. So it's not in effect. So we're able 01:23:18.253 --> 01:23:21.074 to go ahead and fit it in at this point. But if 01:23:21.083 --> 01:23:25.164 we had to delay for months that, that it would start 01:23:25.173 --> 01:23:27.824 to affect our, the. Well, well, I think from a market 01:23:27.833 --> 01:23:30.864 certainty standpoint, we would want to give you a decision 01:23:30.875 --> 01:23:33.984 sooner rather than later. So everybody can plan forward 01:23:33.994 --> 01:23:36.604 with whatever direction we end up going, right? So 01:23:36.614 --> 01:23:39.164 (item:33:Commissioner Cobos on path forward to implementation) I don't envision this being delayed for months, but 01:23:39.819 --> 01:23:44.600 to your point, um RTC plus B ultimate implementation 01:23:44.609 --> 01:23:49.789 is the number one priority. And so um I mean I, I 01:23:49.798 --> 01:23:51.930 would appreciate having some time till the 14th to 01:23:51.939 --> 01:23:55.149 come back and evaluate this third option as you've 01:23:55.159 --> 01:23:57.819 laid out and, and see what we can get on a path 01:23:57.829 --> 01:24:00.708 forward. But I, I feel like I need to analyze it and 01:24:00.720 --> 01:24:02.899 maybe, you know, visit with y'all offline, visit with 01:24:02.909 --> 01:24:05.520 stakeholders offline, see if there's something that 01:24:05.529 --> 01:24:09.659 we can work through there again, trying to give you 01:24:09.668 --> 01:24:11.539 the tools you need. But at the same time trying to 01:24:11.548 --> 01:24:18.548 make sure that um you know, work, we're utilizing the 01:24:18.560 --> 01:24:22.789 resources as best as we can uh for reliability and 01:24:22.798 --> 01:24:25.600 incenting further development and investment. And so 01:24:25.609 --> 01:24:27.390 we're trying to strike a balance here. If there's, 01:24:27.399 --> 01:24:30.109 if there's an opportunity to do that, 01:24:31.958 --> 01:24:36.520 I would be OK with delaying the final consideration 01:24:36.529 --> 01:24:40.418 of that of this NPRR until the next meeting and 01:24:40.479 --> 01:24:43.500 go ahead and passing the two that are within the same 01:24:43.509 --> 01:24:43.859 order. 01:24:45.859 --> 01:24:48.239 Well, it sounds like we're in agreement regarding 01:24:48.250 --> 01:24:54.079 NPRR1184 and SCR824. So would you like to go 01:24:54.088 --> 01:24:58.500 ahead and take a vote on those two NPRRs at this time. 01:24:59.628 --> 01:25:02.430 I would move for approval of those two NPRRs. (item:33:Motion to approve modified proposed order NPRR1184 and SCR825) I would 01:25:02.439 --> 01:25:04.930 entertain a motion to modify the proposed order to 01:25:04.939 --> 01:25:09.168 approve Nodal Protocol Revision Request, NPRR1184 and 01:25:09.180 --> 01:25:13.500 System Change Request 824 and postpone discussion of 01:25:13.509 --> 01:25:17.259 Nodal Protocol Revision 1186 until a future open meeting. 01:25:18.220 --> 01:25:21.390 So moved. Second. I have a motion and a second. All in favor, 01:25:21.399 --> 01:25:25.390 say aye. Aye. Motion. Aye, motion passes. 01:25:27.250 --> 01:25:31.970 (item:33:Connie Corona on produces for consideration of NPRRs) Chairman, thank you for the discussion. I, I would note 01:25:31.979 --> 01:25:35.930 that our procedures for consideration of NPRRs. So 01:25:36.239 --> 01:25:40.250 when you consider uh 1186 at the next open meeting 01:25:40.699 --> 01:25:46.708 um allows for you to approve, remand or deny. So you 01:25:46.720 --> 01:25:52.560 would not be actually editing the NPRR language. You 01:25:52.569 --> 01:25:55.189 would be sending it back to the Board. 01:25:57.720 --> 01:26:01.279 That's correct. I just want to make sure we're on the 01:26:01.369 --> 01:26:02.680 same page procedurally. Thank you. 01:26:05.970 --> 01:26:08.829 It's two weeks and we can put our heads together and 01:26:08.838 --> 01:26:10.088 talk to people. I think it will be 01:26:12.310 --> 01:26:13.048 important. One moment. 01:26:15.668 --> 01:26:16.189 (inaudible) 01:26:24.958 --> 01:26:28.449 All right we, we can move forward. But I don't have 01:26:28.458 --> 01:26:32.859 anything on Items 34 or 35. We'll take up Items 36 01:26:32.869 --> 01:26:37.729 and 38 together. (item:36:Chairwoman Jackson lays out Project 53298) Item 36 is Project No. 53298. The 01:26:37.739 --> 01:26:40.029 Commission's project for wholesale electric market 01:26:40.039 --> 01:26:44.350 design implementation. (item:38:Chairwoman Jackson lays out Project 55000) Item 38 is project number 55000. 01:26:45.140 --> 01:26:48.119 The Commission's project for the performance credit 01:26:48.128 --> 01:26:50.649 mechanism. Shelah, do we have anyone from the public 01:26:50.659 --> 01:26:54.979 signed up to speak on Items 36 or Items 38. No ma'am, 01:26:54.989 --> 01:26:58.009 no one signed up to speak on either of those items. 01:26:58.569 --> 01:27:02.789 PUC Staff is here to provide responses to the questions 01:27:02.798 --> 01:27:05.439 that Commission Cobos asked in her memo from November 01:27:05.449 --> 01:27:10.569 1. Please state your name for the record. (item:38:PUC Staff's Chris Brown on Commission Staff's memo)Good afternoon 01:27:10.579 --> 01:27:14.399 Chris Brown, Commission Staff. We filed a memo responding 01:27:14.409 --> 01:27:17.810 to the questions posed by Commissioner Cobos and uh 01:27:18.829 --> 01:27:20.989 high level overview of these. So the first question 01:27:21.000 --> 01:27:23.128 was addressing whether ERCOT captured all decision 01:27:23.140 --> 01:27:25.890 points and milestones for the PCM development and our 01:27:25.899 --> 01:27:29.600 determination was that they did respond to each decision 01:27:29.609 --> 01:27:32.878 point. We also felt that a review of the 12 PCM 01:27:32.890 --> 01:27:35.619 principles was warranted for the development of the 01:27:35.628 --> 01:27:39.159 strawman. And so we went through each of those points 01:27:39.168 --> 01:27:40.909 or each of those principles. 01:27:42.729 --> 01:27:48.439 The second question was regarding which elements of 01:27:48.449 --> 01:27:51.520 the PCM design should be addressed in commission rulemaking 01:27:51.529 --> 01:27:54.798 stakeholder process or both. And we provided a preliminary 01:27:54.810 --> 01:27:58.239 list of some of the key points we think are best addressed 01:27:58.250 --> 01:28:02.949 in rulemaking, but note that that may develop or change 01:28:02.958 --> 01:28:06.539 as the straw has developed. And then the final question 01:28:06.548 --> 01:28:08.939 concerned how the PCM will interact with the reliability 01:28:08.949 --> 01:28:14.770 standard. We tried to provide um some important considerations 01:28:14.779 --> 01:28:19.770 here of how we see that interacting with the PCM development 01:28:20.789 --> 01:28:21.489 Um 01:28:24.039 --> 01:28:26.859 And I think that's kind of the overview of the memo 01:28:26.869 --> 01:28:30.779 but happy to answer any questions. (item:38:Commissioner Cobos on performance standards) Thank you, Chris 01:28:30.789 --> 01:28:34.149 and Werner. For developing this memorandum in response 01:28:34.159 --> 01:28:37.958 to my questions um in my memo from last open meeting. 01:28:37.970 --> 01:28:41.319 I think y'all did a great job of, of highlighting um 01:28:41.680 --> 01:28:45.409 you know, the, the principles that we adopted in our 01:28:45.418 --> 01:28:50.229 January 23 order and the um parameters now put in place 01:28:50.239 --> 01:28:54.088 in House Bill 1500. As I read through the memo, 01:28:54.100 --> 01:28:56.890 there was a couple of areas I wanted to touch on. Um 01:28:56.899 --> 01:29:00.810 one of them is on um be believe page two under the 01:29:00.819 --> 01:29:03.128 principle of clear performance standards. 01:29:04.649 --> 01:29:13.208 You've highlighted that um PURA 39.1594, Subsection 01:29:13.220 --> 01:29:18.520 85 stipulates that an electric generating unit can 01:29:18.529 --> 01:29:21.609 receive credit only for being able to perform in real 01:29:21.619 --> 01:29:25.949 time um during the tightest intervals of low supply 01:29:25.958 --> 01:29:29.600 and high demand on the grid. Um And that, that um same 01:29:29.609 --> 01:29:34.529 provision um limits the total amount of um PCs that 01:29:34.539 --> 01:29:37.838 can be earned by a generator to the amount they offered 01:29:37.850 --> 01:29:41.189 um into the P in, into the PCMs forward market. And 01:29:41.199 --> 01:29:44.909 you highlighted a discrepancy and you know, mm uh with 01:29:44.918 --> 01:29:49.329 respect to what the statute requires per 1500 for the 01:29:49.338 --> 01:29:51.810 PCs being limited what's offered in the forward market 01:29:52.060 --> 01:29:57.168 and also um that the PCs would be provided for performance 01:29:57.569 --> 01:30:03.039 And that ERCOT S filing had noted um that the straw 01:30:03.048 --> 01:30:05.890 man would address whether the PCs were earned for 01:30:05.899 --> 01:30:10.119 availability um and potentially offers in the real 01:30:10.128 --> 01:30:12.829 time market dispatch or otherwise. So there, there's 01:30:12.850 --> 01:30:12.859 a, 01:30:14.729 --> 01:30:17.359 I think what you're trying to highlight is what ERCOT 01:30:17.369 --> 01:30:19.770 put in their filing and maybe there's just some confusion 01:30:19.779 --> 01:30:24.569 going on here. But um what put in their filing versus 01:30:24.579 --> 01:30:29.119 what's required in the statute per 1500. So um the 01:30:29.128 --> 01:30:32.109 PCs need to pay for performance, not availability 01:30:32.119 --> 01:30:35.409 and the PCs are tied to the forward market, not the 01:30:35.418 --> 01:30:37.640 real time market. And I think that has to be clear 01:30:37.930 --> 01:30:42.829 so that the strawman can be properly structured per 01:30:42.838 --> 01:30:48.020 the requirements of 1500 in PURA. So that's one area 01:30:48.029 --> 01:30:51.708 that I think Staff highlighted. It's important to clarify 01:30:52.020 --> 01:30:55.048 um in the strawman um for the requirements in the 01:30:55.060 --> 01:30:55.520 statute. 01:30:58.279 --> 01:30:59.909 Do you have any feedback on that Werner? (item:38:Wener Roth's response to Commissioner Cobos) Werner Roth 01:31:01.939 --> 01:31:06.500 No, I'd say what you just stated is accurate. I'm able 01:31:06.509 --> 01:31:10.750 to perform is straight out of the statute. So any payment 01:31:10.759 --> 01:31:13.750 for performance credits needs to be tailored to that 01:31:14.100 --> 01:31:15.458 Can you state your name for the record? 01:31:17.168 --> 01:31:22.369 Werner Roth, Commission Staff? Okay. So it's important 01:31:22.378 --> 01:31:24.958 that that gets captured in the strawman that um ERCOT 01:31:24.970 --> 01:31:28.739 and Commission Staff will be working on. Um, the other 01:31:28.750 --> 01:31:33.699 area I wanted to touch on was um towards the back of 01:31:33.708 --> 01:31:37.399 the memo with respect to net cone 01:31:39.539 --> 01:31:43.470 and our discussion Werner. (item:38:Comissioner Cobos on net cone) And I think, you know, we 01:31:43.479 --> 01:31:46.319 adopted our principles, principles that didn't touch 01:31:46.329 --> 01:31:49.149 on net cone. You three study touched on net cone. 01:31:49.338 --> 01:31:54.270 There was a lot of discussion at the Legislature on 01:31:54.279 --> 01:32:00.829 cones. And um ultimately, I think based on, you know 01:32:00.838 --> 01:32:04.829 Werner, your explanation of how you view um the PCM 01:32:04.859 --> 01:32:09.659 and the reliability standard and how the, the, the 01:32:09.708 --> 01:32:13.750 demand curve that we establish as part of the PCM 01:32:13.759 --> 01:32:17.369 would work in concert with the reliability standard 01:32:17.378 --> 01:32:21.229 And, and you explain that if your, your understanding 01:32:21.399 --> 01:32:23.989 would be that if we're not meeting the reliability 01:32:24.000 --> 01:32:28.750 standard, then the PCM will be used to meet the reliability 01:32:28.759 --> 01:32:33.779 standard through the demand curve. And so as part 01:32:33.789 --> 01:32:38.409 of that, you would have a certain level of PUC revenue 01:32:38.418 --> 01:32:40.350 which arguably would be a little higher than if you 01:32:40.359 --> 01:32:42.890 were, if you were meeting the reliability standard 01:32:43.229 --> 01:32:47.239 and that PUC revenue plus energy and ancillary service 01:32:47.250 --> 01:32:52.628 revenue would be need to altogether equal net cone 01:32:54.029 --> 01:32:58.350 Am I capturing that correctly? Yes. (item:38:Werner Roth on net cone) So the um Werner Roth, 01:32:58.449 --> 01:33:00.859 Commission Staff. So the way that we've envisioned 01:33:00.869 --> 01:33:03.588 this similar to out of the E3 report is that in 01:33:03.600 --> 01:33:06.628 the long run as you have the quantity of PCs necessary 01:33:06.640 --> 01:33:09.350 to meet the reliability standard, the Commission um 01:33:09.359 --> 01:33:12.270 chooses that should, when we're meeting that exact 01:33:12.279 --> 01:33:14.869 level or that or at that level, we should be expecting 01:33:14.878 --> 01:33:17.020 the um performance credit mechanism to be paying out 01:33:17.088 --> 01:33:19.470 approximately net cone for those years on average. 01:33:19.479 --> 01:33:21.699 And that should be the expected signal for that year 01:33:21.708 --> 01:33:25.029 end going forward when we're at the reliability standard. Subject to 01:33:25.359 --> 01:33:29.250 the statutory cap. Yes. Yes, that is correct. It would 01:33:29.259 --> 01:33:32.298 have to be subject to the cap that is in statute. So 01:33:32.350 --> 01:33:34.609 as a stand alone basis, it would not be able to achieve 01:33:34.619 --> 01:33:38.909 the reliability standard. It is part of the sum 01:33:40.579 --> 01:33:42.859 of all efforts to achieve the reliability standard. 01:33:42.909 --> 01:33:45.399 (item:38:Werner Roth on reliability standard) Yes, that is Staff's understanding that it would, I 01:33:45.409 --> 01:33:47.899 mean, depends on what the reliability standard the 01:33:47.909 --> 01:33:50.009 Commission ultimately chooses to move forward with 01:33:50.390 --> 01:33:53.829 but it may or may not on its own, be able to 01:33:53.838 --> 01:33:58.479 meet that standard. Ok. But, and, and then as the second 01:33:58.770 --> 01:34:02.060 aspect to this, if we are meeting the reliability standard 01:34:02.069 --> 01:34:05.899 this you've explained to me, then the PCM will still 01:34:05.909 --> 01:34:10.119 produce PC revenues. They, they won't be zero. They 01:34:10.128 --> 01:34:13.729 it'll be a lower amount of PCs that will be added 01:34:13.739 --> 01:34:16.739 to the energy and ancillary service revenue to still 01:34:16.750 --> 01:34:19.899 meet net cone even if we are meeting the reliability 01:34:19.909 --> 01:34:22.838 standard. Is that correct? (item:38:Werner Roth on PCs) So, yes, if the number of 01:34:22.850 --> 01:34:26.569 PCs is exactly 100% what we need, need to meet the 01:34:26.579 --> 01:34:29.579 liability standard, we would expect the um the maker 01:34:29.588 --> 01:34:32.140 of to meet or to pay out um performance credits equal 01:34:32.149 --> 01:34:35.770 to net cone and if we have performance credits and excess 01:34:35.779 --> 01:34:38.649 of the amount needed to meet the reliability standard 01:34:38.659 --> 01:34:40.989 in a given year, we would expect that to be pay out 01:34:41.000 --> 01:34:44.298 less than that price all the way down to zero if we 01:34:44.310 --> 01:34:46.979 have an extremely excessive amount of performance credits 01:34:46.989 --> 01:34:49.819 during that year. So, so even if we're meeting the 01:34:49.829 --> 01:34:52.369 reliability standard, there will still be PC revenue 01:34:52.378 --> 01:34:57.770 it won't be zero. Yes, that is if net cone is greater 01:34:57.779 --> 01:35:01.439 than if the, if the energy ancillary service revenues 01:35:01.449 --> 01:35:04.149 don't exceed cone, then yes, there would be an expectation 01:35:04.159 --> 01:35:06.989 of that paying out for that year. There's a minimum 01:35:07.869 --> 01:35:10.739 there's a minimum obligation, minimum obligation. What 01:35:10.750 --> 01:35:14.600 do you mean Commissioner McAdams? It doesn't zero out supposed to be self 01:35:14.668 --> 01:35:18.588 correcting, supposed to be correct. We spend a lot 01:35:18.600 --> 01:35:23.088 of time talking about that aspect of self correcting 01:35:23.100 --> 01:35:25.520 and zero P CS if we're meeting certain parameters, 01:35:25.529 --> 01:35:30.250 right? But your, your explanation is not exactly what 01:35:30.259 --> 01:35:33.189 we've been discussing. (item:38:Commissioner Cobos on annual cone pay outs) So I wanted to highlight that 01:35:33.199 --> 01:35:35.310 so that we can have a discussion about that and figure 01:35:35.319 --> 01:35:37.850 out where we're headed because, and the, and the other 01:35:37.859 --> 01:35:39.250 piece of that is, 01:35:41.869 --> 01:35:45.259 are we gonna be paying net cone or cone year after 01:35:45.270 --> 01:35:48.409 year? Do we need to be paying cone year after year 01:35:48.418 --> 01:35:51.140 to an asset? Can you explain your thoughts on that 01:35:52.640 --> 01:35:55.850 (item:38:Werner Roth on cone payouts) So even under the current paradigm, that would be the 01:35:55.859 --> 01:35:59.500 case in years where we are, if we are on average, seeing 01:35:59.869 --> 01:36:02.930 energy answers service revenues paying out um at a 01:36:02.939 --> 01:36:06.850 net margin below the um cost of due entry. We 01:36:06.859 --> 01:36:09.619 would expect um ok, that's sending a signal. No generation 01:36:09.628 --> 01:36:11.729 needs to be built. In fact that there might be sending 01:36:11.739 --> 01:36:14.020 a signal that ok, our more expensive facilities need 01:36:14.029 --> 01:36:17.180 to be retiring at this point um, years where we have 01:36:17.189 --> 01:36:19.569 a signal that showing multiple times. Um the cost of 01:36:19.579 --> 01:36:22.199 new entry there are answering service markets that's 01:36:22.208 --> 01:36:25.180 showing, ok. There's, if you build this PGRR unit 01:36:25.189 --> 01:36:28.009 there is right now a financial incentive for them to 01:36:28.609 --> 01:36:31.369 come into the market because they'd be able to cover 01:36:31.378 --> 01:36:36.369 their own for cost. Um This is the performance credit 01:36:36.378 --> 01:36:40.369 mechanism is another means of just ensuring more year 01:36:40.378 --> 01:36:43.798 to year certainly in the revenue that generation will 01:36:43.810 --> 01:36:46.970 be able to receive. But this is just the PC revenues 01:36:46.979 --> 01:36:48.680 won't just be paid to a new generation, it will be 01:36:48.689 --> 01:36:51.789 paid to existing generation. And so if you structure 01:36:51.798 --> 01:36:55.119 the that's cone year after year for existing, no 01:36:55.128 --> 01:36:56.029 I didn't sign up for that. 01:36:59.250 --> 01:36:59.600 Yes, 01:37:03.119 --> 01:37:07.640 (item:38:Commissioner Cobos on PC revenue and annual cone payout) I'm just trying to understand that because we, I was 01:37:07.649 --> 01:37:09.970 trying to understand your memo and then you explained 01:37:09.979 --> 01:37:12.149 to me, you know, the differences between media and 01:37:12.159 --> 01:37:16.659 not meeting the reliability standard. Um And, and when 01:37:16.668 --> 01:37:19.770 we are meeting the reliability standard, we're still 01:37:19.779 --> 01:37:23.918 paying PC revenue, it's not zero. Number two, you 01:37:23.930 --> 01:37:25.409 know, we got to get comfortable with the concept that 01:37:25.418 --> 01:37:29.329 we're paying cone year after year for new, certainly new 01:37:29.338 --> 01:37:31.229 you know, you want to send new generation to come in 01:37:31.239 --> 01:37:32.989 but we also get to get comfortable with the fact we're 01:37:33.000 --> 01:37:35.009 going to be paying and year after year for existing 01:37:36.088 --> 01:37:39.409 which I believe during our discussions with E3 01:37:39.418 --> 01:37:41.500 at our work sessions. E3 highlighted most of the 01:37:41.509 --> 01:37:44.259 revenue in the at the beginning would be going to the 01:37:44.270 --> 01:37:47.759 existing anyway. So generation. So I, I just wanted 01:37:47.770 --> 01:37:50.579 to kind of highlight that, I mean, I, I don't know 01:37:50.588 --> 01:37:53.250 where we go for with that from here with the strawman 01:37:53.259 --> 01:37:53.569 but 01:37:55.208 --> 01:37:57.609 we've had a lot of discussions on, on these issues 01:37:57.619 --> 01:37:59.430 and I just wanted to make sure we're all on the same 01:37:59.439 --> 01:38:02.310 page in terms of what we're trying to build and for 01:38:02.319 --> 01:38:04.109 the reasons we're trying to build it. So 01:38:08.220 --> 01:38:11.359 I, I think I agree with my colleague that's problematic 01:38:11.489 --> 01:38:17.739 Um I'm gonna go reread the statute again too. (item:38:Commissioner McAdams concerns with memo) The 01:38:18.729 --> 01:38:22.720 and that, that gets to the blueprint and how we negotiated 01:38:22.729 --> 01:38:26.350 that blueprint and, and, and those parameters, 01:38:27.899 --> 01:38:30.100 it was supposed to be normalizing. I mean, when you 01:38:30.109 --> 01:38:33.779 were at equilibrium costs were supposed to go away 01:38:33.789 --> 01:38:36.449 there wasn't supposed to be a minimum value introduced 01:38:36.458 --> 01:38:39.989 into the system. Um The market is supposed to be able 01:38:40.000 --> 01:38:42.569 to work. I have. 01:38:44.989 --> 01:38:49.479 How did, PJM doesn't do it like that? The forward capacity 01:38:49.489 --> 01:38:52.079 markets don't do it like that, do they? 01:38:53.750 --> 01:38:57.259 I mean, not to my knowledge. SPP certainly doesn't. So 01:38:57.569 --> 01:38:58.109 um, 01:38:59.750 --> 01:39:02.279 Werner, I think you're gonna need to work on this. Uh, otherwise 01:39:02.289 --> 01:39:03.298 this will go to lawsuit. 01:39:08.208 --> 01:39:10.789 Okay. And you know I, I want to encourage that with. Thank 01:39:10.798 --> 01:39:12.750 you for all your feedback. I, I know these are tough 01:39:12.759 --> 01:39:17.319 issues. (item:38:Commissioner Cobos on PUC Staff and ERCOT engagement) And um, I just wanna encourage Staff to be engaged 01:39:17.329 --> 01:39:19.949 very engaged in this. As ERCOT has already agreed, 01:39:19.958 --> 01:39:22.609 they're working with you all on developing this strawman 01:39:22.619 --> 01:39:24.588 You know, when we agreed to the straw man, we agreed 01:39:24.600 --> 01:39:27.918 that ERCOT, I mean that the PUC would be developing 01:39:27.930 --> 01:39:33.520 the plan for implementation um for the PCM. Um ERCOT 01:39:33.529 --> 01:39:36.279 is obviously gonna be very involved in that and, and 01:39:36.289 --> 01:39:40.359 has, you know, expertise that will assist them. Um 01:39:40.369 --> 01:39:43.378 But I, I really want to make sure that we're very involved 01:39:43.390 --> 01:39:48.128 in developing this plan and that um we stay consistent 01:39:48.140 --> 01:39:51.500 with the principles of, of that we, as you noted, um 01:39:51.509 --> 01:39:54.128 strongly negotiated to come up with the blueprint. 01:39:54.850 --> 01:39:58.770 And ultimately, I think um the Commission should be 01:39:58.779 --> 01:40:01.029 in the driver's seat of determining what stays here 01:40:01.039 --> 01:40:03.949 and what goes to ERCOT and what goes to both forums 01:40:03.958 --> 01:40:07.609 eventually. Because ultimately, as I've said, all along 01:40:07.619 --> 01:40:10.350 we're going to be the ones that set the policy on this 01:40:10.359 --> 01:40:14.560 major market reform uh measure and, and, and implementation 01:40:14.569 --> 01:40:16.310 and we want to make sure we build it right, and that 01:40:16.319 --> 01:40:20.390 we have all of the bases covered both here at uh PUC 01:40:20.869 --> 01:40:24.628 the Commission per rule and out of the ERCOT protocols 01:40:24.640 --> 01:40:28.899 too. So, um it's just something we got to remain diligent 01:40:29.060 --> 01:40:32.909 on. (item:38:Chairwoman Jackson on continued engagement) And I guess from my perspective, I think, you know 01:40:32.918 --> 01:40:37.640 having um put forth those workflow diagrams, the overviews 01:40:37.649 --> 01:40:41.048 that um ERCOT has been doing, you know, not only on 01:40:41.060 --> 01:40:44.149 the PCM initiative but other, you know, part of the 01:40:44.159 --> 01:40:48.220 top five. It's a, it's an evolving process and it's 01:40:48.229 --> 01:40:51.659 something that um as we give feedback and input, we're 01:40:51.668 --> 01:40:55.859 able to um you know, take the product and can through 01:40:55.869 --> 01:40:59.060 continuous improvement, make it better. And so um certainly 01:40:59.069 --> 01:41:01.798 have the opportunity to do that. And uh I think the 01:41:01.810 --> 01:41:05.859 work so far and the interface between ERCOT and uh 01:41:05.878 --> 01:41:09.079 and the Commission has been very good. Look forward 01:41:09.088 --> 01:41:10.180 to seeing that continue. 01:41:11.949 --> 01:41:16.470 (item:38:Commissioner Glotfelty's appreciation for Commission Staff) Madam Chairman, I want to say similar. I think Werner 01:41:16.729 --> 01:41:20.159 and Chris, I want to thank you. We're charting uncharted 01:41:20.168 --> 01:41:22.949 territory here and y'all are learning something really 01:41:22.958 --> 01:41:26.458 at the front end of a new policy here. So 01:41:28.569 --> 01:41:32.819 don't be frustrated if we have fits and starts. We 01:41:32.829 --> 01:41:35.378 want your expertise, we want to help get it right. 01:41:35.390 --> 01:41:39.159 And I just thank you for the work. This is, this is 01:41:39.168 --> 01:41:42.220 a pretty unique area. So thanks for your hard work 01:41:42.229 --> 01:41:44.619 on it. (item:38:Commissioner McAdams' appreciation for Commission Staff) Madam Chair, if I could echo that. Werner, Chris 01:41:44.838 --> 01:41:46.899 he's doing a good job. This is a good job. This thing 01:41:46.909 --> 01:41:50.789 is a big dynamic, there was a lot of stuff in it 01:41:50.798 --> 01:41:53.069 We're, we're trying to harmonize statute now statute 01:41:53.079 --> 01:41:54.750 with the blueprint as well. 01:41:56.628 --> 01:42:00.119 Every move there's going to be cost associated with 01:42:00.128 --> 01:42:02.449 it. And frankly, for the Legislature to consider what 01:42:02.458 --> 01:42:05.039 is effective in the future on that cap. You know, whether 01:42:05.048 --> 01:42:07.449 to remove the cap, whether to adjust it, what is the 01:42:07.458 --> 01:42:13.199 value necessary to apply toward the credits to allow 01:42:13.399 --> 01:42:15.759 whatever the framework is to achieve that reliability 01:42:15.770 --> 01:42:19.020 standard. And that's the overall goal. So I completely 01:42:19.029 --> 01:42:23.838 understand where there may be some difference of interpretation 01:42:23.850 --> 01:42:28.000 on that. And I apologize for my reaction. Man, we 01:42:28.009 --> 01:42:31.708 we so heavily argued over those parameters, you know 01:42:31.720 --> 01:42:35.470 that, but I appreciate the work you put in and you 01:42:35.479 --> 01:42:38.159 know, this Commission is doing a good job. Thank you. 01:42:39.970 --> 01:42:44.449 Thank you y'all. (item:37:Chairwoman Jackson lays out Project 54584) Next up is Item No. 37, Project No. 01:42:44.458 --> 01:42:48.439 54584. This is the Commission's project for the reliability 01:42:48.449 --> 01:42:51.000 standard. Shelah, do we have anyone from the public 01:42:51.009 --> 01:42:55.458 signed up to speak on Item No. 37? No, ma'am. ERCOT 01:42:55.470 --> 01:42:58.350 filed an update, providing revised results for the 01:42:58.359 --> 01:43:02.588 first 48 scenarios simulated for the reliability standards 01:43:02.600 --> 01:43:05.439 study to rectify an incorrect time shift in certain 01:43:05.449 --> 01:43:09.869 historic weather year files used in the in the serving model 01:43:10.029 --> 01:43:13.699 The update also includes results from the 2023 prompt 01:43:13.708 --> 01:43:16.659 year study as recommended by the IMM and requested 01:43:16.668 --> 01:43:20.890 by the Commission. Woody with ERCOT is here. So if 01:43:20.899 --> 01:43:25.418 you could please come up and state your name for a 01:43:25.430 --> 01:43:29.369 record and provide an overview of ERCOT's filing. 01:43:29.378 --> 01:43:33.149 (item:37:ERCOT's Woody Rickerson provides updates) Woody Rick, Woody Rickerson with ERCOT. So, yeah, we've 01:43:33.159 --> 01:43:37.628 completed the, the 48 refiled those. So you have those 01:43:37.640 --> 01:43:41.789 Now, we uh the Commission Staff has asked for some 01:43:41.798 --> 01:43:44.649 additional runs and those are being worked on now and 01:43:44.659 --> 01:43:46.069 you'll receive those shortly. 01:43:47.609 --> 01:43:52.128 We also delivered the uh prompt your results. So you 01:43:52.140 --> 01:43:59.329 have those as well. Any questions? Madam Chair, if 01:43:59.338 --> 01:44:03.949 you'll indulge me Woody, just some clarifying questions. 01:44:04.060 --> 01:44:06.119 And, and they're not, they're not difficult, you'll 01:44:06.128 --> 01:44:08.689 be able to shed some light. But could we go through 01:44:08.699 --> 01:44:11.989 it page by page? Just it's not that long of a filing 01:44:12.359 --> 01:44:17.869 but on on page two of your filing. Yes sir. Of the 01:44:17.878 --> 01:44:21.020 prompt year. Yes sir. (item:37:Commissioner McAdams on weatherization results) So that will be 2023 prompt year 01:44:21.029 --> 01:44:26.970 analysis result. Yeah. It, it overall the statement 01:44:26.979 --> 01:44:29.699 it seems like theoretically our weatherization standards 01:44:29.708 --> 01:44:32.829 are making a significant impact or at least an impact. 01:44:34.640 --> 01:44:39.259 But one number that jumps out to me, sir, on the 2023 01:44:39.930 --> 01:44:46.229 with weatherization results is it looks like you think 01:44:46.239 --> 01:44:53.548 we have a 0.31 loss of load expectation for 2023. Question 01:44:53.560 --> 01:44:55.640 am I understanding that correctly or do you think we're 01:44:55.649 --> 01:44:59.600 on path? Is, is that the path you think we're on? So 01:44:59.970 --> 01:45:03.500 and does that imply we're going to have outages once 01:45:03.509 --> 01:45:08.819 every three years? The 0.3, 0.31 under the simulated 01:45:08.829 --> 01:45:13.509 2023 with weatherization results for frequency LOLE. (item:37:Woody Rickerson on weatherization results) So 01:45:13.520 --> 01:45:14.048 that's 01:45:15.569 --> 01:45:20.289 if you compare that to the 48 scenario results, that 01:45:20.298 --> 01:45:24.159 would be a frequency of three. So that's 2011 at those 01:45:24.168 --> 01:45:28.909 3000. Uh ok. So we're, we're low. Okay. 01:45:31.449 --> 01:45:34.958 And that's over the 42 year historic data. Okay. And 01:45:34.970 --> 01:45:37.048 that includes Winter Storm Uri, right? Or the weather? 01:45:37.369 --> 01:45:38.979 The weather free Winter Storm Uri. 01:45:41.128 --> 01:45:45.140 Yeah, it had a similar impact on the LOLE and SPP as 01:45:45.149 --> 01:45:49.199 I as I alluded to in terms of the implied reserve margins 01:45:49.208 --> 01:45:53.949 that they'd need. Okay, sir. (item:37:Commissiner McAdams on exceedance probabilities) So page three, if we could 01:45:54.259 --> 01:45:58.149 the exceeding probabilities for 23 and 26 based scenario 01:45:58.159 --> 01:46:02.418 analysis. It seems like that if an outage occurs, the 01:46:02.430 --> 01:46:06.970 chances are chance of a high magnitude and high duration 01:46:06.979 --> 01:46:11.958 event is fairly unlikely. So why is the exceedance 01:46:11.970 --> 01:46:15.569 probability for magnitude of 2026 so much higher than 01:46:15.579 --> 01:46:16.680 for 2023? 01:46:20.668 --> 01:46:25.430 (item:37:Woody Rickerson on exceedance probabilities) So that would relate to if you think about you're making 01:46:25.439 --> 01:46:30.048 these 1000 runs and you're producing a probability 01:46:30.060 --> 01:46:34.279 distribution and the 2026 probability distribution 01:46:34.289 --> 01:46:40.069 will have more events in detail that exceed um mag 01:46:40.338 --> 01:46:43.989 exceed the standards. And so that the way I look at 01:46:44.000 --> 01:46:50.939 that is um if you're at 4% then 96 times, you don't 01:46:50.949 --> 01:46:55.430 have a problem before you do. So you just have to think 01:46:55.439 --> 01:46:58.369 of it from a probability of distribution that the tail 01:46:58.378 --> 01:47:03.869 on the 2026 events have more events, more runs that 01:47:03.878 --> 01:47:07.149 exceed the uh, the criteria. Okay. 01:47:09.259 --> 01:47:11.958 They're acting like an anchor or they're waiting, it 01:47:12.128 --> 01:47:14.909 it, it's not there that, that has the effect because 01:47:14.918 --> 01:47:20.750 they're, they were of such magnitude. So, um, on page 01:47:20.759 --> 01:47:21.649 four, if you would, 01:47:24.418 --> 01:47:26.329 Okay. 01:47:31.640 --> 01:47:34.020 I want to make sure I'm on. So can you add this 01:47:34.029 --> 01:47:35.000 table to, 01:47:38.048 --> 01:47:41.850 can you add to this table your assumed 2023 actual 01:47:41.859 --> 01:47:48.409 costs? Yes. Okay. That would be helpful to that. Yeah 01:47:48.600 --> 01:47:53.449 just to give us a basis baseline, you want the actual 01:47:53.458 --> 01:47:55.539 cost 2023. Cost 2023. Okay. 01:47:57.680 --> 01:48:01.680 Would it be helpful to get '26 as well? So we'll have 01:48:01.689 --> 01:48:07.220 actual for 2023 as the prompt year stuff? That's fine 01:48:08.000 --> 01:48:08.180 (item:37:Commissioner McAdams on transmission constraints) So, 01:48:09.729 --> 01:48:12.878 so also why did you decide not to include transmission 01:48:12.890 --> 01:48:16.979 constraints in conservative ops in 2023 analysis? Is 01:48:17.359 --> 01:48:20.350 it, isn't it included in the 2026 criteria? Because 01:48:20.359 --> 01:48:23.009 that's what we're forecasting, we're going to be operating 01:48:23.020 --> 01:48:25.500 under. (item:37:Woody Rickerson on transmission constraints) So, 01:48:30.720 --> 01:48:33.180 or is it possible to run a scenario with conservative 01:48:33.189 --> 01:48:35.958 operations as an assumption? 01:48:37.918 --> 01:48:40.918 We can go back and look at that. I just wondered how 01:48:40.930 --> 01:48:45.180 it would be impacted. Um, the model that we're running 01:48:45.270 --> 01:48:49.109 doesn't include the transmission system. So you would 01:48:49.119 --> 01:48:53.689 have to put those numbers in. This is a, this is, doesn't 01:48:53.699 --> 01:48:57.979 include Monte Carlo. Yeah. Got it. Yeah. So this isn't 01:48:58.088 --> 01:48:58.509 a, uh, 01:49:00.989 --> 01:49:03.759 you're not looking at the deliverability. Yeah. Yeah 01:49:03.789 --> 01:49:07.810 I get that. Um, okay. 01:49:09.759 --> 01:49:15.838 So also gas prices, could you also run a scenario with 01:49:15.850 --> 01:49:19.619 $5.80 MMBtu to help us understand how sensitive the 01:49:19.628 --> 01:49:22.579 numbers are to gas prices? That would be helpful. 01:49:25.020 --> 01:49:29.369 (item:37:Commissioner McAdams on average market prices) Oh, page five, sir. Average market price by weather 01:49:29.390 --> 01:49:31.298 year. Right. Um, 01:49:32.899 --> 01:49:37.119 so the higher price was due to natural gas prices and 01:49:37.128 --> 01:49:38.600 conservative operations, correct? 01:49:40.899 --> 01:49:44.810 Okay. So conservative operations show up well. (item:37:Woody Rickerson on market prices) And also 01:49:46.180 --> 01:49:48.989 the weather. Yeah. Yeah. No, no, I get it. You're right 01:49:49.000 --> 01:49:50.819 I mean, that was conservative operations in the face 01:49:50.829 --> 01:49:53.640 of that was the big time weather, extraordinary summer 01:49:54.039 --> 01:49:59.770 I got it. Okay. Page 6, make sure. Um in fact, I 01:49:59.779 --> 01:50:02.000 would say the weather was probably the, maybe the biggest 01:50:02.009 --> 01:50:02.668 factor there. 01:50:04.439 --> 01:50:07.399 Yeah, I know. I think that's true in other areas too 01:50:08.250 --> 01:50:13.418 (item:37:Commissioner McAdams on economic growth assumptions) Um, on page six, what are the economic growth assumptions 01:50:13.430 --> 01:50:18.949 used in the 2022 and 2023 studies? Exactly. And, and 01:50:18.958 --> 01:50:22.970 as kind of in that context, what are we using and assuming 01:50:22.979 --> 01:50:27.048 for 2026 scenarios? (item:37:Woody Rickerson on economic growth assumptions) I'd have to, I don't have those 01:50:27.060 --> 01:50:30.020 in front of me. I'd have to give you or ask someone 01:50:30.029 --> 01:50:35.310 for those. All right. So you want to know what economic 01:50:35.319 --> 01:50:40.789 growth was being used for those, those uh, those years 01:50:44.310 --> 01:50:46.588 just to figure out what ballpark we're operating in 01:50:47.739 --> 01:50:52.560 (item:37:Commissioner McAdams on lower LOLEs) Um, the 2026 scenarios include Winter Storms Uri and 01:50:52.569 --> 01:50:57.000 Elliott. But have a much lower LOLE than what you're 01:50:57.009 --> 01:51:00.838 showing for 2023. Even in the one in five scenario 01:51:00.850 --> 01:51:04.430 is even the one in five scenario is only reached when 01:51:04.439 --> 01:51:08.739 you remove coal and gas assets. Why is that? 01:51:11.378 --> 01:51:16.199 (item:37:Woody Rickerson on lower LOLEs) Because the base set of generation resources give you 01:51:16.208 --> 01:51:19.329 a frequency higher than one in five. So you have to 01:51:19.338 --> 01:51:23.279 take stuff out to get it down to 15. And the reason 01:51:23.289 --> 01:51:26.958 we included those different scenarios was to kind of 01:51:26.970 --> 01:51:31.229 give you bookings on uh on, on your results. So just 01:51:31.239 --> 01:51:33.640 to show you the sensitivity, if you were to lose a 01:51:33.649 --> 01:51:37.020 certain number of megawatts, you, you could have it 01:51:37.029 --> 01:51:42.509 one in five. Ok. Ok. Um 01:51:45.708 --> 01:51:48.048 Tell you what. That, that's my questions right now, 01:51:48.060 --> 01:51:50.739 Madam Chair. I think Woody's done well. Thank you 01:51:50.750 --> 01:51:54.869 sir. No, I'm good. No. Okay. Thank you. 01:51:56.779 --> 01:51:59.439 Item 38 was already taken up. I don't have anything 01:51:59.449 --> 01:52:03.789 on Item No. 39. (item:40:Chairwoman Jackson lays out Project 55837) Next up is Item No. 40, Project 01:52:03.798 --> 01:52:07.329 number 55837. This is the Commission's project for 01:52:07.338 --> 01:52:10.529 the review of the value of lost load in the ERCOT market. 01:52:10.680 --> 01:52:12.750 Shelah, do we have anyone from the public signed up 01:52:12.759 --> 01:52:16.208 to speak on Item No. 40. Chairman, no one has signed 01:52:16.220 --> 01:52:19.109 up to speak on No. 40. (item:40:Shelah Cisneros suggest a short break) Before we get into that particular 01:52:19.119 --> 01:52:22.350 Item. We are getting, we are about at the two hour mark 01:52:22.359 --> 01:52:24.449 since we're getting close to the two hour mark, since 01:52:24.458 --> 01:52:27.899 we returned from Close Session. And I'm just checking 01:52:27.909 --> 01:52:31.079 in to see if it's possible to schedule a time for the 01:52:31.088 --> 01:52:33.689 Court Reporter to have a 15 or 20 minute break either 01:52:33.708 --> 01:52:36.149 before this item or after this item. I'll defer to 01:52:36.159 --> 01:52:36.869 you all on that. 01:52:38.850 --> 01:52:42.069 This might be a good stopping point. So we can go ahead 01:52:42.079 --> 01:52:42.509 and 01:52:44.159 --> 01:52:48.409 take a, a recess. And then take up Item 40 after the 01:52:48.418 --> 01:52:49.720 recess. We'll take up Item 40 after the recess. 01:52:55.128 --> 01:52:57.350 Okay. We'll just give you a moment. I know that I interrupted 01:52:57.359 --> 01:53:00.829 and to find the recess language. Okay. (item:40:Chairwoman Jackson calls for brief recess) I'd like to recess 01:53:00.838 --> 01:53:05.708 briefly. Let's recess for um, 15 minutes. 15 minutes, 01:53:05.720 --> 01:53:12.458 yes ma'am. 15 minutes and we'll be back at um 1:40. 01:53:12.829 --> 01:53:14.168 1:40. Thank you. 01:53:21.220 --> 01:53:24.159 (item:40:Chairwoman Jackson resumes open meeting) The Commission will now resume its public meeting at 01:53:24.168 --> 01:53:28.949 1:46 beginning with Item No. 40. Next up is Item 01:53:28.958 --> 01:53:32.649 No. 40, Project No. 55837. This is the Commission's 01:53:32.659 --> 01:53:35.270 project for the review of the value of lost load in 01:53:35.279 --> 01:53:37.918 the ERCOT market. Shelah, do we have anyone from the 01:53:37.930 --> 01:53:42.350 public time to speak on Item No. 40? No, ma'am. ERCOT filed 01:53:42.359 --> 01:53:45.770 an update. Would you come and provide an overview 01:53:45.779 --> 01:53:49.029 of your update? Please state your name for the record. 01:53:53.680 --> 01:53:56.100 (item:40:ERCOT's Matt Arth on lost load study update) Good afternoon Commissioners. Matt Arth with ERCOT. 01:53:57.310 --> 01:54:01.009 Yes, we filed the uh value of lost load study update 01:54:01.020 --> 01:54:04.899 with the commission last week. Um We are happy to report 01:54:04.909 --> 01:54:08.369 that has engaged um, the Brattle Group along with their 01:54:08.378 --> 01:54:12.149 subcontractor Plan Beyond to perform the vol study 01:54:12.298 --> 01:54:16.009 Uh The Plan beyond um uh, uh yall are familiar with 01:54:16.020 --> 01:54:18.390 Brattle Plan beyond brings um survey administration 01:54:18.399 --> 01:54:21.449 expertise to this um in a number of industries including 01:54:21.458 --> 01:54:25.649 the electric industry. Um the vol study will consist 01:54:25.659 --> 01:54:28.699 of a literature review as well as the development of 01:54:28.708 --> 01:54:32.449 an interim bow value. Um And of course, crucially the 01:54:32.458 --> 01:54:35.878 customer survey um that literature, all three of those 01:54:35.890 --> 01:54:39.609 pieces are um, uh, being worked on presently and, and 01:54:39.619 --> 01:54:44.250 have been for uh, a few weeks now, at least. Um, and 01:54:44.259 --> 01:54:46.939 the literature review and the development of the interim 01:54:46.949 --> 01:54:49.829 vol value, we expect to file um, the week before the 01:54:49.838 --> 01:54:54.449 Christmas holidays. Um and the interim vol value just 01:54:54.458 --> 01:54:57.668 to put a little bit more on that is essentially using 01:54:57.989 --> 01:55:03.048 um, the, uh, Lawrence Berkeley National Labs, um uh 01:55:03.060 --> 01:55:05.699 formulas and, and uh information that they've used 01:55:05.708 --> 01:55:08.958 in their ice calculator update plus publicly available 01:55:08.970 --> 01:55:11.350 um, data that's specific to the ERCOT region from the 01:55:11.359 --> 01:55:14.560 EIA and, and census data um to come up with an 01:55:14.569 --> 01:55:17.548 interim vol value that can be used, you know, as, as 01:55:17.560 --> 01:55:20.128 the Commission would like perhaps in the reliability 01:55:20.140 --> 01:55:23.109 standards study to inform that in, in the interim until 01:55:23.119 --> 01:55:27.149 the, the customer surveys can be completed. Um The 01:55:27.159 --> 01:55:30.418 the customer survey piece is uh obviously a, uh uh 01:55:30.439 --> 01:55:35.689 um um, it's a complex piece because of uh the exchange 01:55:35.699 --> 01:55:39.109 of, of data and uh making sure that we have the right 01:55:39.119 --> 01:55:42.890 um, contact information to, to contact customers. Um 01:55:43.359 --> 01:55:46.149 so, um, well, actually let me take a step back for 01:55:46.159 --> 01:55:49.060 a second and say, um, one other piece, I, I alluded 01:55:49.069 --> 01:55:51.729 to Lawrence Berkeley National Labs, LBNL. They are 01:55:51.739 --> 01:55:55.259 currently performing on a nationwide basis, an update 01:55:55.270 --> 01:55:58.319 to their ice calculator, the ice calculator 2.0. And 01:55:58.329 --> 01:56:01.509 they have developed um, three surveys to perform, um 01:56:01.520 --> 01:56:04.939 that ice calculator update. It's a, a residential survey 01:56:04.949 --> 01:56:07.659 a small and medium commercial and a large commercial 01:56:07.668 --> 01:56:11.189 and industrial survey. Um So, in consultation with 01:56:11.199 --> 01:56:14.369 with Brattle and Plan Beyond, um ERCOT uh recommends 01:56:14.378 --> 01:56:19.399 using um LBNL's survey to perform the ERCOT vol um study 01:56:19.409 --> 01:56:23.189 with the opportunity to um add perhaps a few uh limited 01:56:23.199 --> 01:56:26.958 questions to that. We think that does um two, two big things. 01:56:26.970 --> 01:56:29.949 One, it helps to ensure that we can um you know, stay 01:56:29.958 --> 01:56:33.270 on uh a timely delivery process to, to, to deliver 01:56:33.279 --> 01:56:36.729 the full vol um uh report to y'all by the second quarter 01:56:36.739 --> 01:56:40.100 of next year of 2024. Um But also, you know, of course 01:56:40.109 --> 01:56:44.378 critically um leveraging the significant um testing 01:56:44.390 --> 01:56:47.310 and expertise that went into those surveys on a, on 01:56:47.319 --> 01:56:50.829 a nationwide basis. (item:40:Matt Arth on data exchange) And we um ERCOT has entered into 01:56:50.838 --> 01:56:54.739 an agreement with the labs to um have a data exchange 01:56:54.829 --> 01:56:59.020 So um the, the labs within Texas have worked with a 01:56:59.029 --> 01:57:03.208 AEP Texas to update the ice calculator for um uh for 01:57:03.220 --> 01:57:06.168 that initiative for their ice calculator 2.0 initiative 01:57:06.350 --> 01:57:11.270 Um And so we'll be able to um uh uh swap data 01:57:11.279 --> 01:57:13.699 with them, get, see the data that they've um collected 01:57:13.708 --> 01:57:16.418 from the AEP Texas area and also share with them the 01:57:16.430 --> 01:57:19.548 the data that uh uh we would be collecting uh for the 01:57:19.560 --> 01:57:24.930 rest of the ERCOT region. Um um So that, I guess that 01:57:24.939 --> 01:57:28.079 brings me to the uh the distribution of the survey 01:57:28.088 --> 01:57:31.128 piece. (item:40:Matt Arth on distribution survey) which they are really, I think uh as we see 01:57:31.140 --> 01:57:34.729 it three options uh before us as, as a way to get 01:57:34.739 --> 01:57:38.039 the survey to retail customers. And I think that that's 01:57:38.048 --> 01:57:41.399 something that uh particularly uh we would be interested 01:57:41.409 --> 01:57:43.199 in the market would be interested in the commission's 01:57:43.208 --> 01:57:46.918 feedback on. Um The first of those options would be 01:57:46.930 --> 01:57:51.079 for um the stakeholders to provide ERCOT and ERCOT 01:57:51.088 --> 01:57:54.588 then to provide that data to um Brattle and Plan Beyond 01:57:54.609 --> 01:57:58.279 um customer contact information. Um That information 01:57:58.289 --> 01:58:01.569 is probably protected customer information uh which 01:58:01.579 --> 01:58:07.009 comes with a set of um constraints around um um stakeholders 01:58:07.020 --> 01:58:09.250 being able to share that with anybody including with 01:58:09.310 --> 01:58:14.409 ERCOT. Um So the second option would be to avoid having 01:58:14.418 --> 01:58:18.289 to um have that transfer of data, um have the stakeholders 01:58:18.298 --> 01:58:22.128 which would primarily be the reps and the noise perhaps 01:58:22.140 --> 01:58:25.649 with some support from the TDUs, push um the survey 01:58:25.659 --> 01:58:29.199 out to um retail customers themselves using their own 01:58:29.208 --> 01:58:32.279 customer contact information that they have. Um under 01:58:32.289 --> 01:58:35.909 the direction of, of Brattle and Plan Beyond. Um I 01:58:35.918 --> 01:58:39.039 think that there's uh also some, some drawbacks of 01:58:39.048 --> 01:58:44.208 that uh uh um option uh and that it involved, it will 01:58:44.220 --> 01:58:47.418 involve a significant um um expense and, and manpower 01:58:47.430 --> 01:58:50.829 and, and effort on those organizations parts. Um And 01:58:50.838 --> 01:58:54.520 uh you know, introduces some uh risk for uh delay just 01:58:54.529 --> 01:58:58.128 from having to aggregate um information from all of 01:58:58.140 --> 01:59:01.739 those um stakeholders. And so the third option, which 01:59:01.750 --> 01:59:04.449 I would say is probably ERCOT's recommended option 01:59:04.458 --> 01:59:08.668 is, is uh the hybrid option. (item:40:Matt Arth on hybrid option & CBCI) Whereby ERCOT uses um 01:59:08.680 --> 01:59:11.609 customer contact information that it already has uh 01:59:11.619 --> 01:59:15.779 which is called CBCI. Um customer billing contact 01:59:15.789 --> 01:59:19.378 information that competitive retailers submit to ERCOT 01:59:19.390 --> 01:59:24.208 on a monthly basis. Um uh which contains customer contact 01:59:24.220 --> 01:59:28.569 information. It contains um billing addresses as a 01:59:28.579 --> 01:59:32.100 mandatory field and it also has an optional field for 01:59:32.109 --> 01:59:36.378 email addresses. Um Now, the, the primary purpose of 01:59:36.390 --> 01:59:41.324 CBCI is to facilitate um mass transitions when a uh 01:59:41.333 --> 01:59:45.104 a competitive retailer exits the market and then um 01:59:45.114 --> 01:59:48.654 in certain situations, ERCOT can um give that information 01:59:48.664 --> 01:59:53.104 to the, to the gaining um competitive retailer um uh 01:59:53.125 --> 01:59:58.064 uh to facilitate that, that transition. Um So, um to 01:59:58.074 --> 02:00:01.814 my knowledge, I think uh the CBCI has never been used 02:00:01.824 --> 02:00:04.895 for any other purpose other than to support a mass 02:00:04.904 --> 02:00:09.029 transition. And in fact, um CBCI is developed under 02:00:09.039 --> 02:00:14.359 rule 25.43(p)(6) and (7) of the Commission's rules 02:00:14.369 --> 02:00:19.069 Uh And uh and is also enumerated uh in uh protocol 02:00:19.079 --> 02:00:23.509 Section 15. Um those uh the Commission's rule and, 02:00:23.520 --> 02:00:26.890 and also the, the um flushing out of it in the, in 02:00:26.899 --> 02:00:32.310 the protocols do specify that um uh protected customer 02:00:32.319 --> 02:00:36.609 information that is provided to a polar um uh cannot 02:00:36.619 --> 02:00:40.548 can only be used for the sole purpose of a mass transition 02:00:40.720 --> 02:00:44.708 Um We believe that um although it is a novel approach 02:00:44.720 --> 02:00:48.595 that, that would leave leeway for ERCOT that holds 02:00:48.604 --> 02:00:51.845 that data in the interim to use the customer billing 02:00:51.854 --> 02:00:55.274 contact information to, to for other purposes, including 02:00:55.284 --> 02:00:59.944 for um um distributing the value of lost load study. 02:01:00.154 --> 02:01:05.253 Um We have engaged um with the stakeholders over the 02:01:05.265 --> 02:01:08.244 last several weeks. We've, we've had discussions with 02:01:08.454 --> 02:01:11.494 um the reps, the noise, the TDUs, um various trade 02:01:11.503 --> 02:01:15.489 associations and, and with Staff of course. Um and 02:01:15.500 --> 02:01:18.208 uh and we will also be at uh RMS and TAC 02:01:18.289 --> 02:01:20.338 next week. To continue those, those discussions and 02:01:20.350 --> 02:01:24.819 those forums as well. But um the stakeholders that 02:01:24.829 --> 02:01:29.878 we have engaged with have expressed a desire to um 02:01:30.000 --> 02:01:33.509 uh get some, some clarity around, around the permissibility 02:01:33.520 --> 02:01:37.088 of, of any of the three options. Um But also ERCOT's 02:01:37.229 --> 02:01:40.949 use of CBCI for, for that purpose. Um I think 02:01:40.958 --> 02:01:43.079 that we think that there is the leeway there to use 02:01:43.088 --> 02:01:45.458 that and the, and the benefit of that is not having 02:01:45.470 --> 02:01:49.180 to request that data through a different avenue from 02:01:49.439 --> 02:01:53.989 um stakeholders. But if we uh uh do not use the CBCI 02:01:54.000 --> 02:01:55.949 then I think that that probably puts us into one 02:01:55.958 --> 02:01:59.020 of the other buckets uh uh for distribution, which 02:01:59.029 --> 02:02:04.100 does have its own challenges. Um So, um let's see. 02:02:05.298 --> 02:02:07.859 Um So we wanted to bring this to y'all's attention 02:02:07.869 --> 02:02:10.520 so that um everyone has a chance to uh consider it 02:02:10.529 --> 02:02:13.958 and, and of course, um we'll receive your feedback 02:02:14.088 --> 02:02:16.918 Um We probably will continue to bring y'all updates 02:02:16.930 --> 02:02:19.458 before every open meeting for the next, you know, in 02:02:19.470 --> 02:02:23.185 in December or January as well. Um with the goal of 02:02:23.194 --> 02:02:26.555 beginning the distribution of the, of the survey in 02:02:26.564 --> 02:02:30.154 February and concluding that within um concluding the 02:02:30.164 --> 02:02:33.125 collection of that data within a few weeks and um and 02:02:33.134 --> 02:02:35.454 then concluding the analysis of it and filing the report 02:02:35.463 --> 02:02:36.395 in the second quarter. 02:02:38.149 --> 02:02:42.529 (item:40:Matt Arth on next steps) So our, our probably next step is to file um prior 02:02:42.539 --> 02:02:46.699 to the December 14th open meeting. Um the kind of more 02:02:46.708 --> 02:02:50.930 flushed out uh vol survey plan which would um identify 02:02:50.939 --> 02:02:53.329 you know, which of the options um that we are going 02:02:53.338 --> 02:02:56.850 to use to distribute the survey. It would also identify 02:02:56.859 --> 02:03:01.470 information like sample size and um uh branding of 02:03:01.479 --> 02:03:03.569 the survey and, and that sort of thing. 02:03:05.310 --> 02:03:07.619 Um I think those are the main points that I wanted 02:03:07.628 --> 02:03:10.168 to highlight, but I'll be happy to answer any questions. 02:03:12.470 --> 02:03:19.489 Matt if you um on CBCI. So that, that is purposely gathered 02:03:19.500 --> 02:03:22.220 for the intended purpose of, of mass transition. So 02:03:23.439 --> 02:03:27.180 if we went that route, we would forego the opportunity 02:03:27.189 --> 02:03:33.430 to survey noise areas. Is that correct? (item:40:Matt Arth on CBCI) That's a, that's 02:03:33.439 --> 02:03:37.899 a very good point. They don't submit CBCI, because 02:03:37.918 --> 02:03:40.579 they don't mass transitions wouldn't apply in their 02:03:41.399 --> 02:03:44.409 we can't make them do anything anyway. So I think it 02:03:44.418 --> 02:03:48.640 will be, um, if we, if we want to survey in the 02:03:48.649 --> 02:03:52.439 nays service areas, which I, I think that we do, um 02:03:52.449 --> 02:03:56.289 it will be incumbent on uh partnering with, with the 02:03:56.298 --> 02:03:59.350 to do that. And I should say we have had some 02:03:59.359 --> 02:04:01.680 um good conversations with them and they've expressed 02:04:01.689 --> 02:04:04.458 interest in, in supporting us and I think those conversations 02:04:04.470 --> 02:04:07.954 are ongoing. But, but under that um hybrid option number 02:04:07.963 --> 02:04:13.134 three, that would still require one of the um either 02:04:13.145 --> 02:04:16.024 that no, he's giving us their customer contact information 02:04:16.034 --> 02:04:18.774 in order for us to perform it or for them or for 02:04:18.784 --> 02:04:21.003 them to do it for us. And I, I think that there 02:04:21.015 --> 02:04:26.645 is some openness to doing it for us within their service 02:04:26.654 --> 02:04:29.935 territories. But I wouldn't say that affirmatively 02:04:29.944 --> 02:04:32.253 that at this time, I think that we're still exploring 02:04:32.265 --> 02:04:34.475 that. Did Loris Berkeley National Lab have any feedback 02:04:34.484 --> 02:04:37.114 on that? I mean, I know our offices engage with them 02:04:37.369 --> 02:04:40.289 They've been trying to get these going for a while 02:04:40.298 --> 02:04:44.390 they believe in it but, and they're very aware of the 02:04:44.560 --> 02:04:49.789 regulatory distinction between Cooper and State Commissions 02:04:49.798 --> 02:04:51.838 Did they have any recommendations or feedback on how 02:04:51.859 --> 02:04:54.779 to crack them up to my knowledge on the, no question 02:04:54.789 --> 02:04:57.310 specifically. No, I, I haven't heard anything from 02:04:57.319 --> 02:04:59.750 the labs on that. I would say that we have of course 02:04:59.759 --> 02:05:01.833 had significant coordinations with the lab labs and 02:05:01.845 --> 02:05:04.345 have been gleaning the, the learnings that they have 02:05:04.354 --> 02:05:07.333 provided uh in, in other areas. But they do, you know 02:05:07.345 --> 02:05:11.364 the lab does, um contract with, as I understand it 02:05:11.375 --> 02:05:14.003 um, utilities throughout the country, I think, including 02:05:14.015 --> 02:05:19.384 potentially. Um And uh uh uh so they would, you 02:05:19.395 --> 02:05:21.074 know, that, I guess that would be a slightly different 02:05:21.083 --> 02:05:23.625 situation if they're in a direct con contract with 02:05:23.634 --> 02:05:26.979 that entity to perform the study for them. So, so Matt 02:05:26.989 --> 02:05:28.890 I, I would encourage you to continue to visit with 02:05:28.899 --> 02:05:31.458 them because I, my office has received some feedback 02:05:31.470 --> 02:05:33.659 that they're, they're concerned about their ability 02:05:33.668 --> 02:05:37.060 to survey their customers that not every, you know 02:05:37.069 --> 02:05:40.088 that they're smaller. There's some out there 02:05:40.100 --> 02:05:43.298 potentially that just won't have a capability to survey 02:05:43.310 --> 02:05:46.409 Um, I guess, you know, if you can continue to engage 02:05:46.418 --> 02:05:49.798 with them to see if what, what the, the possibility 02:05:49.810 --> 02:05:53.619 is of them doing that, I would encourage that because 02:05:53.628 --> 02:05:56.060 that's at least some feedback we have received, um 02:05:56.069 --> 02:05:59.390 at my office. (item:40:Matt Arth on partnerships) Certainly. And I would say, I think that 02:05:59.399 --> 02:06:03.930 the goal is to um identify a few limited, uh to 02:06:03.939 --> 02:06:06.640 to partner with on this. And um as you, as you may 02:06:06.649 --> 02:06:09.939 have seen just from the um uh from the presentation 02:06:09.949 --> 02:06:12.569 at the back of the update filing, we provided some 02:06:12.579 --> 02:06:15.680 um approximate numbers of the level of customer outreach 02:06:15.689 --> 02:06:18.000 and the level of responses that that would be necessary 02:06:18.009 --> 02:06:20.819 Those those numbers were developed based on previous 02:06:20.829 --> 02:06:23.750 full studies that have been done in other areas. And 02:06:23.759 --> 02:06:26.439 just looking at approximately how many people needed 02:06:26.449 --> 02:06:28.810 to be contacted in order to get that level of response 02:06:28.819 --> 02:06:31.979 to achieve a statistically significant um level of 02:06:31.989 --> 02:06:35.100 response. And so those aren't large numbers compared 02:06:35.109 --> 02:06:37.259 to, you know, the total number of customers that are 02:06:37.270 --> 02:06:41.850 in the ERCOT region. So, um we do think, um you know 02:06:41.859 --> 02:06:46.520 the Brattle and Pan Beyond would use um customer usage 02:06:46.529 --> 02:06:50.289 data to wait the selection of the, of the um of the 02:06:50.298 --> 02:06:52.458 customers that are contacted to make sure that we're 02:06:52.470 --> 02:06:55.869 getting a uh a geographically diverse and, and other 02:06:55.878 --> 02:07:00.220 diverse um uh category of, of folks that are being 02:07:00.289 --> 02:07:03.869 receiving the survey. Um But uh um that's sort of a 02:07:03.878 --> 02:07:06.770 long way of saying, I think uh we would probably uh 02:07:06.779 --> 02:07:09.369 not need to partner with a, a great number of noys 02:07:09.390 --> 02:07:12.668 uh probably could, could have fairly limited sets. 02:07:15.168 --> 02:07:17.850 Oh, no, I'm sorry. (item:40:Commissioner Glotfelty gives appreciation of the study) I was just going to say thanks, 02:07:17.918 --> 02:07:21.329 most people here know that I'm a pretty strong advocate 02:07:21.338 --> 02:07:23.708 for Lawrence Berkeley National Lab and our other labs 02:07:23.720 --> 02:07:26.729 and our efforts. And I want to thank you, I'm on the 02:07:26.739 --> 02:07:29.770 project advisory committee for the Ice calculator upgrade 02:07:29.779 --> 02:07:33.279 And I'm, I hope, and I love to hear back from you 02:07:33.289 --> 02:07:36.619 all, if it's from your, your perspective, you know 02:07:36.628 --> 02:07:40.079 once that, once you go through the survey process and 02:07:40.270 --> 02:07:43.918 and I just wanted to reinforce what Commissioner Cobos 02:07:43.930 --> 02:07:49.409 said and will about but be more specific. 02:07:50.128 --> 02:07:55.729 I think it's the fear is that some small co-ops that 02:07:55.739 --> 02:07:59.208 don't get email that have, you know, limited broadband 02:08:00.378 --> 02:08:03.869 can have a voice in this as well. So do whatever you 02:08:03.878 --> 02:08:06.409 all need to do in an extraordinary fashion to at least 02:08:06.520 --> 02:08:10.220 find one of those and have them have some input into 02:08:10.229 --> 02:08:11.168 this process. 02:08:12.739 --> 02:08:15.409 (item:40:Commissioner McAdams question on surveys sent by email vs postal mail) Yeah I, I had a question about that. If the consultant 02:08:15.418 --> 02:08:20.489 or the labs had had kind of a feel on the magnitude 02:08:20.500 --> 02:08:24.350 of how much it matters in terms of the expected response 02:08:24.359 --> 02:08:27.770 on emailed surveys versus mailed. I mean, I know it 02:08:27.779 --> 02:08:30.890 certainly has cost implications and it's difficult 02:08:31.298 --> 02:08:36.199 but how much you lose by doing. (item:40:Matt Arth on surveys sent by email vs postal mail) So, I don't know the 02:08:36.208 --> 02:08:38.720 number of that offhand. I do know that that's something 02:08:38.729 --> 02:08:41.048 that, that Brattle and Plan Beyond are considering 02:08:41.060 --> 02:08:45.600 and have significant experience with. Um uh just taking 02:08:45.609 --> 02:08:50.369 the CBCI as an example. Um uh ERCOT sends out um 02:08:50.378 --> 02:08:54.039 snail mail in some instances, uh using that information 02:08:54.048 --> 02:08:58.689 um care of the Public Utility Commission. Um uh in 02:08:58.699 --> 02:09:01.729 addition to phone calls and email uh and email. So 02:09:01.739 --> 02:09:04.619 um there is the capability to send out a physical mail 02:09:04.628 --> 02:09:08.088 in addition to email, I think that we definitely see 02:09:08.100 --> 02:09:13.609 email as being the primary way of doing it. Um But 02:09:13.619 --> 02:09:17.048 we're also cognizant that a lot of people don't have 02:09:17.060 --> 02:09:20.109 email addresses and we don't want to bias the results 02:09:20.119 --> 02:09:23.668 by only reaching out to people who have email addresses 02:09:24.220 --> 02:09:26.069 which actually brings me to one other point that I 02:09:26.079 --> 02:09:28.229 probably should have highlighted before. (item:40:Matt Arth on including email addresses for CBCI) Which is that 02:09:28.369 --> 02:09:31.699 that CBCI well, I mentioned that billing addresses 02:09:31.708 --> 02:09:34.458 are mandatory but email addresses are optional. I think 02:09:34.470 --> 02:09:38.680 we would um request the um competitive retailers in 02:09:38.689 --> 02:09:42.239 the, in their January and February CBCI submissions 02:09:42.329 --> 02:09:45.939 to include um email addresses to the extent that they 02:09:45.949 --> 02:09:48.029 have them and just aren't including them because it's 02:09:48.039 --> 02:09:52.319 an optional field. Um And uh that would give us a fuller 02:09:52.329 --> 02:09:56.220 um data set there. I do think that um uh you know 02:09:56.229 --> 02:10:00.289 we, we've spoken with uh uh several competitive retailers 02:10:00.298 --> 02:10:02.939 and I think that there's, there is some potential concern 02:10:02.949 --> 02:10:07.609 there that um just about uh the use of CBCI 02:10:07.619 --> 02:10:10.539 and whether, whether those competitive retailers are 02:10:10.548 --> 02:10:16.520 um allowed to provide um email addresses for CBCI 02:10:16.560 --> 02:10:18.548 um that would be used for this other purpose other 02:10:18.560 --> 02:10:23.838 than a mass transition. Um So I think uh uh uh as 02:10:23.850 --> 02:10:28.069 I stated before, I think we uh we think that the um 02:10:28.199 --> 02:10:30.939 competitive retailers would just be submitting um data 02:10:30.949 --> 02:10:35.430 as they always do um to using the CBCI process um 02:10:35.708 --> 02:10:39.189 uh for, for purposes of a mass transition. Now, what 02:10:39.378 --> 02:10:42.390 ERCOT does with that data once it has it um is a 02:10:42.399 --> 02:10:45.208 is a, is a different question. And I think ERCOT has 02:10:45.220 --> 02:10:49.180 leeway to use that data in ways that um um uh obviously 02:10:49.189 --> 02:10:52.850 the pollers could not. Um but uh I, I think that there 02:10:52.859 --> 02:10:56.250 is a sense that to the extent that the Commission um 02:10:56.259 --> 02:10:58.128 would provide feedback on that. I think that that would 02:10:58.140 --> 02:11:03.128 be appreciated. Okay, so one question. (item:40:Chairwoman Jackson's question on survey response rate) You talked 02:11:03.140 --> 02:11:06.329 about the statistical significant difference that you 02:11:06.338 --> 02:11:09.560 wanted to make sure that you had in your data. And 02:11:09.569 --> 02:11:13.918 so, and you kind of mentioned um that you were looking 02:11:13.930 --> 02:11:17.180 for that and in, I guess the number of surveys that 02:11:17.189 --> 02:11:20.000 you were putting out there to make sure that they, 02:11:20.009 --> 02:11:23.520 you know, it was in the right geographic area. Um What 02:11:23.640 --> 02:11:27.208 a what about responses so you can put them out? But 02:11:27.220 --> 02:11:29.449 it's like, you know, you get a different response rate 02:11:29.458 --> 02:11:33.409 across. So, I mean, shouldn't you also be looking at 02:11:33.418 --> 02:11:36.060 a statistical significant difference within the response 02:11:36.069 --> 02:11:40.168 rate? (item:40:Matt Arth on survey response rate) I, I think that um that is something that uh 02:11:40.180 --> 02:11:42.310 Brattle and, and plan beyond will be looking at as 02:11:42.319 --> 02:11:45.609 part of this. And uh I think that the, the bigger the 02:11:45.619 --> 02:11:48.579 um the pool of people that you contact, the more likely 02:11:48.588 --> 02:11:52.100 that you'll be to get, um, responses from all of the 02:11:52.109 --> 02:11:54.829 areas that you need. But, uh, I guess that that is 02:11:54.838 --> 02:11:58.399 always, um, uh, as I understand it, uh, a difficulty 02:11:58.409 --> 02:12:01.279 with, with surveys is you just don't know what specific 02:12:01.289 --> 02:12:04.220 responses you'll, you'll get. But, um, but certainly 02:12:04.229 --> 02:12:07.390 I think that, uh, um, that, that, that is being taken 02:12:07.399 --> 02:12:10.140 into consideration to make sure that, uh, we, uh, get 02:12:10.149 --> 02:12:11.878 the responses that we need from the right, you know 02:12:11.890 --> 02:12:16.060 from a, from a broad spectrum. Hey, Matt. So now we're 02:12:16.069 --> 02:12:19.020 sitting at the end of November, uh surveys will go 02:12:19.029 --> 02:12:23.918 out February. Do you have a, a view or does Woody or 02:12:23.930 --> 02:12:28.009 Chad or Kenan anybody at ERCOT have a view from ERCOT's 02:12:28.020 --> 02:12:33.109 perspective on the use cases for the vol, um especially 02:12:33.128 --> 02:12:36.774 as it relates to the reliability standard because I 02:12:36.784 --> 02:12:40.034 know the Commission probably has individual ideas of 02:12:40.043 --> 02:12:44.234 how it could be used and should be used. But given 02:12:44.244 --> 02:12:46.314 your expectations and now that you're working with 02:12:46.324 --> 02:12:50.324 Brattle, does ERCOT as, as an organization have a view 02:12:50.333 --> 02:12:51.793 on how it will be incorporated? 02:12:53.359 --> 02:12:56.979 Um I'm not sure that I have the answer to that question 02:12:56.989 --> 02:12:58.020 but um 02:13:02.529 --> 02:13:07.009 Woody blessed it so he can take a swing. (item:40:ERCOT's Kenan Ögelman on policy decisions) Kenan Ögelman with 02:13:07.140 --> 02:13:15.229 ERCOT. Um So, uh I, I think there are uh uh references 02:13:15.239 --> 02:13:19.079 that the Bol study will provide you in terms of other 02:13:19.088 --> 02:13:23.270 policy decisions that you're going to make. Um uh For 02:13:23.279 --> 02:13:26.329 example, today, you were asking Woody about uh the 02:13:26.338 --> 02:13:31.369 the study that has some cost elements in it in terms 02:13:31.378 --> 02:13:35.430 of achieving certain reliability standards. And um 02:13:35.439 --> 02:13:39.789 the kind of other side of that is the possibility that 02:13:40.109 --> 02:13:44.270 there's some controlled shedding of load and that, 02:13:44.279 --> 02:13:48.189 that has a cost also. So, uh, that, that's one area 02:13:48.199 --> 02:13:51.689 and I believe Commissioner Cobos, you have kind of 02:13:51.699 --> 02:13:55.449 raised this issue in the past also. So, uh, I think 02:13:55.458 --> 02:13:59.680 it starts, uh, informing the Commission uh, on some 02:13:59.689 --> 02:14:03.529 of the policy decisions that they will make in term 02:14:03.539 --> 02:14:08.439 of trying to decide these tradeoffs between how much 02:14:08.449 --> 02:14:12.600 do you wanna, you know, invest in various infrastructure 02:14:12.609 --> 02:14:16.628 improvements versus the, the benefit that, that you 02:14:16.640 --> 02:14:17.899 would realize there. 02:14:20.208 --> 02:14:20.699 Mhm. 02:14:22.439 --> 02:14:26.029 (item:40:Commissioner Cobos appreciation of ERCOT study) Overall I, I really want um, I want to thank ERCOT 02:14:26.039 --> 02:14:29.949 for their work and um hiring Brattle and their contractor 02:14:29.958 --> 02:14:32.989 and engaging Lawrence Berkeley National Lab. I think 02:14:33.000 --> 02:14:37.088 it's a very robust approach to the literature review 02:14:37.100 --> 02:14:39.668 and the survey process. We haven't conducted a survey 02:14:40.479 --> 02:14:44.109 in ERCOT. And I think this is um a move in 02:14:44.119 --> 02:14:47.149 the right direction. It seems like um a lot of good 02:14:47.470 --> 02:14:51.109 work will be done in this bol process. And I know we 02:14:51.119 --> 02:14:54.520 still gotta figure out some underlying um survey approaches 02:14:54.529 --> 02:14:57.239 and, and provide y'all feedback on that. But overall 02:14:57.250 --> 02:14:59.680 I think the general direction of where this is headed 02:14:59.689 --> 02:15:02.560 seems very robust. And you guys, you know, ERCOT has 02:15:02.569 --> 02:15:06.100 hired some, some good contractors um and experts on 02:15:06.109 --> 02:15:06.720 this matter. 02:15:08.668 --> 02:15:10.569 So, thanks y'all. Thanks. Thank you. 02:15:13.890 --> 02:15:16.430 I don't have anything for Item No. 41. 02:15:18.449 --> 02:15:22.579 (item:42:Chairwoman Jackson lays out Project 55718) Next up is Item No. 42, Project No. 55718. This 02:15:22.588 --> 02:15:25.100 is the Commission's project for the reliability plan 02:15:25.109 --> 02:15:27.930 for the Permian Basin. Shelah, do we have anyone from 02:15:27.939 --> 02:15:30.699 the public signed up to speak on Item No. 42? No 02:15:30.750 --> 02:15:34.838 ma'am. Commissioner Cobos, you have an update. Yes 02:15:34.878 --> 02:15:39.020 ma'am. (item:42:Commissioner Cobos' update for reliability plan for Permian Basin) So, um there will be a workshop held in Midland 02:15:39.100 --> 02:15:42.640 Odessa, uh University of Texas Premium Basin on December 02:15:42.649 --> 02:15:45.579 12th, um where we will engage with the oil and gas 02:15:45.588 --> 02:15:49.588 community. Um I plan to attend along with um some PUC 02:15:49.600 --> 02:15:53.958 Staff and ERCOT Staff um to learn about um you know 02:15:53.970 --> 02:15:55.689 some of the feedback that the oil and gas community 02:15:55.699 --> 02:15:58.539 wants to provide us of that workshop and um excited 02:15:58.548 --> 02:16:01.409 to get out there and, and engage with um the stakeholders 02:16:01.418 --> 02:16:08.439 and hear their perspective as we look to work with 02:16:08.449 --> 02:16:10.878 ERCOT in developing the reliability plan for the Permian 02:16:10.890 --> 02:16:11.220 Basin. 02:16:13.208 --> 02:16:15.350 (item:42:Chairman Jackson gives appreciation for Commissioner Cobos' leadership) So I know I've heard from a number of folks and they're 02:16:15.359 --> 02:16:18.399 very excited that you're coming and uh I think this 02:16:18.409 --> 02:16:21.338 is a great outreach opportunity for the Commission 02:16:21.350 --> 02:16:24.029 and I think uh a great ambassador for the Commission 02:16:24.039 --> 02:16:26.229 that you're going up there personally. And I think 02:16:26.239 --> 02:16:29.029 that makes such a difference when uh when, when you 02:16:29.039 --> 02:16:32.149 get to have that kind of one on one very personal uh 02:16:32.159 --> 02:16:35.790 way of receiving feedback and kind of seeing the lay 02:16:35.799 --> 02:16:37.940 of the land. So I really commend you for doing. That 02:16:38.398 --> 02:16:40.369 might be the first time in history, Lori. That there'll 02:16:40.378 --> 02:16:42.609 be like a town hall of people. Glad to see you to 02:16:42.619 --> 02:16:43.677 talk about transmission 02:16:45.328 --> 02:16:48.007 lines. Enjoy. Right. Exactly. The first time to hear about 02:16:48.018 --> 02:16:50.568 a lot of transmission being built. Well, yeah. 02:16:52.909 --> 02:16:55.940 Okay. (item:43:Chairwoman Jackson lays out Project 55421) Next up is Item No. 43, Project No. 02:16:55.950 --> 02:16:59.530 55421. This is the Commission's project for the Texas 02:16:59.540 --> 02:17:02.530 Advanced Nuclear Reactor working group, Sheila, do 02:17:02.540 --> 02:17:04.649 we have anyone from the public signed up to speak on 02:17:04.659 --> 02:17:07.950 Item No. 43? No, ma'am. Commissioner Glotfelty, 02:17:07.959 --> 02:17:11.739 you have an update. (item:43:Commissioner Glotfelty's update on Nuclear Reactor Working Group) Like Commissioner Cobos, this is 02:17:11.750 --> 02:17:14.250 just an announcement that we're having a meeting December 02:17:14.259 --> 02:17:19.148 5th here in Austin. Nuclear Regulatory Commissioner 02:17:19.158 --> 02:17:23.427 David Wright will be speaking. It will likely be at 02:17:23.439 --> 02:17:26.718 the Barbara Jordan building next door. We'll make sure 02:17:26.727 --> 02:17:28.798 that everybody knows that it will be posted into the 02:17:28.808 --> 02:17:32.539 docket number once that's finalized. Two other things 02:17:32.548 --> 02:17:35.308 just as a heads up, we've created a leadership structure 02:17:35.318 --> 02:17:40.488 in this working group. Mike Kotara, an executive at Zachary 02:17:40.498 --> 02:17:44.388 Construction, Doug Robison from Nutra and Abilene Christian 02:17:44.819 --> 02:17:48.179 and Derek Haas from the University of Texas are all the 02:17:48.190 --> 02:17:52.838 three leader. Kind of the, the three amigos on the on 02:17:52.849 --> 02:17:56.790 the leadership team to help facilitate this. They will 02:17:56.799 --> 02:18:01.079 drive our success and very eager to uh to, to push 02:18:01.088 --> 02:18:04.870 this group to its limits. (item:43:Commissioner Glotfelty on next meeting December 5, 2023) This next meeting, we will 02:18:04.879 --> 02:18:06.909 on the 5th we'll set up our subgroups and our sub 02:18:06.929 --> 02:18:10.129 chairs where we'll be going through these specific 02:18:10.138 --> 02:18:15.519 items that, that we need to address. I want to take 02:18:15.530 --> 02:18:19.709 a minute and thank Carol Maxwell, our librarian here. 02:18:19.718 --> 02:18:23.299 Without any request, without anything. She has been 02:18:23.308 --> 02:18:30.259 a, a great resource for us and the PUC library for 02:18:30.269 --> 02:18:34.599 just helping us get nuclear articles together, summarizing 02:18:34.610 --> 02:18:36.569 and understanding different reports and, and that's 02:18:36.579 --> 02:18:39.319 been great. And Rich and his staff also have been great 02:18:39.329 --> 02:18:42.659 in helping us with these meetings. So I wanted to say 02:18:42.668 --> 02:18:43.418 thank you to them. 02:18:47.149 --> 02:18:52.459 Great job, great update. (item:44:Chairwoman Jackson lays out Project 54702) Next up is Item No. 44, Project No. 02:18:52.468 --> 02:18:56.338 54702. This is the Commission's project for the report 02:18:56.440 --> 02:19:00.849 of Texas Reliability Entity. Shelah, do we have 02:19:00.860 --> 02:19:03.168 anyone from the public signed up to speak on Item No. 02:19:03.179 --> 02:19:06.989 44? No, ma'am. So Commissioner Glotfelty as our Texas 02:19:07.000 --> 02:19:11.319 R.E. Board Member, do you have an update? Thank you. (item:44:Commissioner Glotfelty gives Texas R.E. update) I uh 02:19:12.359 --> 02:19:13.939 I'm not going to go through all the introductions. 02:19:13.949 --> 02:19:17.828 They can do themselves but Joseph, Mark and David. 02:19:17.968 --> 02:19:20.689 Please introduce yourself before you speak. So the 02:19:20.699 --> 02:19:23.378 court reporter knows your name and who you're with. 02:19:23.558 --> 02:19:29.138 As a board member of the Texas Reliability Entity. 02:19:29.149 --> 02:19:31.250 It's important that we continue to coordinate with 02:19:31.259 --> 02:19:34.530 them. They don't have a reporting function to us nor 02:19:34.540 --> 02:19:38.129 to ERCOT and but they control a tremendous amount of 02:19:38.138 --> 02:19:41.040 what happens in the market behind the scenes with every 02:19:41.049 --> 02:19:43.329 transmission company, with every generator owner and 02:19:43.338 --> 02:19:49.319 operator and, and with ERCOT itself. So I, uh, I have 02:19:49.329 --> 02:19:52.200 asked them to come talk about the, uh, the Winter 02:19:52.250 --> 02:19:54.888 Storm Elliott Report. And then I also wanted to ask 02:19:54.899 --> 02:19:59.360 them um about, uh, the Grid X exercise um that they 02:19:59.370 --> 02:20:04.959 just helped many, uh, Texas um, uh market participants 02:20:04.968 --> 02:20:08.120 go through and see how that, uh, from your perspective 02:20:08.129 --> 02:20:12.558 came out. So, Joseph. (item:44:Texas RE's Joseph Younger introduce other Texas RE officers)Thank you so much. Uh, Commissioner 02:20:12.579 --> 02:20:13.610 Glotfelty. Uh, 02:20:15.159 --> 02:20:17.459 My name is uh Joseph Younger. I'm the Vice President 02:20:17.468 --> 02:20:21.308 and Chief Operating Officer at uh Texas R.E. With 02:20:21.319 --> 02:20:24.500 me is uh Mark Henry who's our, our Chief Engineer 02:20:24.509 --> 02:20:27.409 and Director of Reliability Outreach and David Penney 02:20:27.418 --> 02:20:30.870 who's our Principal Senior in our organization. 02:20:30.918 --> 02:20:33.769 Both Mark and David worked on the Winter Storm Elliott 02:20:33.780 --> 02:20:37.009 report along with NERC. The other reliability regions 02:20:37.019 --> 02:20:40.000 as well as FERC Staff. So they're gonna walk through 02:20:40.009 --> 02:20:43.030 uh the recommendations and findings uh at a high level. 02:20:43.040 --> 02:20:45.110 And then after they're done, I'll, I'll touch on Grid 02:20:45.120 --> 02:20:45.909 X briefly. 02:20:48.259 --> 02:20:50.979 Okay. (item:44:Texas RE's Mark Henry on Winter Storm Elliott report) Again thank you for the opportunity to enlighten 02:20:50.989 --> 02:20:54.610 you about something that mostly happened outside of 02:20:54.620 --> 02:20:57.569 Texas. Uh But we still feel like it's important and 02:20:57.579 --> 02:21:00.338 it's been a very big effort. We had about 50 people 02:21:00.399 --> 02:21:03.388 from all the NERC regions, NERC staff and uh Federal 02:21:03.399 --> 02:21:05.989 Energy Regulatory Commission were involved in this 02:21:06.000 --> 02:21:08.370 and uh you know, where the reports out came out early 02:21:08.379 --> 02:21:12.450 November about 167 pages. Not that that's 02:21:12.459 --> 02:21:14.888 important. Uh You'll have so many pages of things to 02:21:14.899 --> 02:21:19.519 look at. Um, but uh we wanted to just give you a 02:21:19.530 --> 02:21:22.638 quick overview of this event and sort of contrast it 02:21:22.649 --> 02:21:25.379 to Uri a little bit along the way. And I wanted to 02:21:25.388 --> 02:21:27.849 focus initially on, you know what it was, it was not 02:21:27.860 --> 02:21:30.829 nearly as severe a storm that affected the Eastern 02:21:30.838 --> 02:21:34.729 US as what we experienced in 2021 but when you have 02:21:34.739 --> 02:21:38.179 a drop over 40 degrees in just a few hours, it makes 02:21:38.190 --> 02:21:41.599 some unusual things happen in the power system. Unfortunately 02:21:42.088 --> 02:21:44.509 this one wasn't nearly as sustained as yours. Just 02:21:44.519 --> 02:21:46.780 a couple of days. I think in the East, the 23rd and 02:21:46.790 --> 02:21:49.849 24th of December were the tough days for us. We had 02:21:50.190 --> 02:21:52.819 we had some difficulties on 22nd, 23rd, I'm sorry, 02:21:52.829 --> 02:21:58.629 23rd and 24th. No, 22nd, 23rd. I think this right little 02:21:58.638 --> 02:22:03.229 shift there as it moved across the country and uh the 02:22:03.239 --> 02:22:06.610 impact again as we experienced. And there's been 02:22:06.620 --> 02:22:09.500 five Winter events that have raised a lot of attention 02:22:10.069 --> 02:22:13.069 There was over 90 gigawatts of generation that was 02:22:13.079 --> 02:22:15.388 affected. I think just looking at nameplate planned 02:22:15.399 --> 02:22:18.838 and unplanned outages. The peak in the Eastern grid 02:22:18.849 --> 02:22:23.799 was, I think 127 gigawatts was unavailable. So it's 02:22:23.808 --> 02:22:28.218 kind of hard to comprehend how this could happen. But 02:22:28.229 --> 02:22:30.769 again, it's a great challenge to operate these facilities 02:22:30.780 --> 02:22:36.299 and these conditions about 18% of the anticipated resources 02:22:36.308 --> 02:22:42.099 were not available in the East. And it was necessary 02:22:42.110 --> 02:22:46.950 because of the shortages there to conduct some load 02:22:46.959 --> 02:22:52.319 shed. 5400 megawatts across several different Southern 02:22:52.329 --> 02:22:55.299 utilities. TVA is the one most prominent. It's the 02:22:55.308 --> 02:22:57.979 first time they'd ever had to shed load. In fact, this 02:22:57.989 --> 02:23:01.019 was the largest load shed in the Eastern interconnect 02:23:01.280 --> 02:23:06.250 to date. And TVA I think had to go up to 02:23:06.259 --> 02:23:09.120 around three gigawatts of load shed around seven or 02:23:09.129 --> 02:23:13.459 eight hours total. Some of the other utilities shorter 02:23:13.468 --> 02:23:17.540 but still in aggregate, there was quite a bit of power 02:23:17.549 --> 02:23:19.799 that had to be cut off. And even for those that didn't 02:23:19.808 --> 02:23:24.718 MISO, Southwest Power Pool, PJM. They went into the first 02:23:24.729 --> 02:23:27.360 or second level of energy emergency alerts, they were 02:23:27.370 --> 02:23:30.540 able to meet their customer demand, however, they weren't 02:23:30.549 --> 02:23:33.329 able to transfer power, which would have helped some 02:23:33.338 --> 02:23:36.479 of the other folks out who had to go into that situation 02:23:36.918 --> 02:23:39.819 MISO also had to shed just a little bit of load 02:23:39.829 --> 02:23:42.579 for some transmission problems that they had on the 02:23:42.588 --> 02:23:46.019 system to remain secure. So this is not something that 02:23:46.360 --> 02:23:50.360 just occurs here in Texas occasionally. Um Thank you 02:23:50.370 --> 02:23:51.299 for pointing that out. 02:23:53.370 --> 02:23:58.588 So of that expected unserved energy for TVA. How much 02:23:59.769 --> 02:24:02.250 do you happen to know? I don't know what they're expecting 02:24:02.259 --> 02:24:03.209 I mean, I don't think they have any. 02:24:04.799 --> 02:24:07.509 Yeah, so basically they're, they're EUE equivalent 02:24:07.709 --> 02:24:10.149 you know, what, what did they, in fact experience in 02:24:10.299 --> 02:24:12.620 terms of unserved energy? (item:44:Mark Henry on EUE equivalent) Well, the numbers that I 02:24:12.629 --> 02:24:14.579 have in my short notes and I can follow up a little 02:24:14.665 --> 02:24:18.093 but mo is about three gigawatts gigawatts the duration 02:24:18.125 --> 02:24:20.415 I don't have in front of me. Yeah, it's somewhere in 02:24:20.424 --> 02:24:21.763 the neighborhood of seven or eight hours. I think they 02:24:21.774 --> 02:24:26.235 had two periods once in the evening of the 23rd and 02:24:26.245 --> 02:24:28.683 then on the 24th in the morning, they again had some 02:24:28.694 --> 02:24:32.780 issues. Um So those are, those are kind of the background 02:24:32.790 --> 02:24:35.679 pieces of this. I was gonna ask David to talk a little 02:24:35.690 --> 02:24:39.750 bit more about the generation outages because he's 02:24:39.759 --> 02:24:42.229 gone in depth through the data there. And because that's 02:24:42.239 --> 02:24:45.638 probably most immediate interest to us here as to how 02:24:45.649 --> 02:24:48.610 are things playing out in the rest of the country where 02:24:48.620 --> 02:24:50.959 they should be a little more familiar with cold weather 02:24:50.968 --> 02:24:54.120 perhaps than us. (item:44:Texas RE's David Penney on Winter Storm Elliott report) And again, my name is David Penney 02:24:54.129 --> 02:24:57.239 a Senior Principal Engineer with uh with Texas RE. And 02:24:57.479 --> 02:25:00.468 I had the uh uh the unfortunate privilege of serving 02:25:00.479 --> 02:25:03.168 on both the grid operations, sub team and the generation 02:25:03.179 --> 02:25:05.929 sub team uh as the subject matter expert for this event. 02:25:05.940 --> 02:25:08.759 So, you know, as Mark alluded to, uh you know, this 02:25:08.769 --> 02:25:11.989 Was the one of the largest data collection efforts 02:25:12.000 --> 02:25:14.000 that FERC has ever undertaken for an event of this 02:25:14.009 --> 02:25:18.558 size. Uh We hit first for virtually every balancing 02:25:18.569 --> 02:25:20.929 authority and reliability coordinator coordinator in 02:25:20.940 --> 02:25:23.319 the Eastern interconnect with the exception of Florida 02:25:23.329 --> 02:25:27.009 and New England. So we touched a lot of companies and 02:25:27.019 --> 02:25:29.569 as Mark, Mark mentioned this was the fifth of these 02:25:29.579 --> 02:25:31.638 types of cold weather events in the last five years 02:25:31.649 --> 02:25:34.269 And all of them had several common allies related to 02:25:34.338 --> 02:25:38.229 related to them being, you know, loss of a large amounts 02:25:38.239 --> 02:25:42.329 of generation due to cold weather issues, uh uh uh 02:25:43.229 --> 02:25:46.950 inaccuracies and uh load forecasting issues as well 02:25:46.959 --> 02:25:49.418 as effects on the gas system. Uh And so that, that's 02:25:49.429 --> 02:25:51.940 common across all five of those events that Mark, Mark 02:25:51.950 --> 02:25:56.019 mentioned. Uh as Mark mentioned, uh you know, the, 02:25:56.030 --> 02:25:58.940 the the high point in the uh unplanned dodges was just 02:25:58.950 --> 02:26:02.530 over 90 gigawatts. And that's we, we talk about unplanned 02:26:02.540 --> 02:26:04.649 dodges are forced dodges forced to rate to 02:26:04.659 --> 02:26:07.149 start up failures. Uh And that was on the morning of 02:26:07.159 --> 02:26:11.620 the 24th and at that point in time, actually PM became 02:26:11.629 --> 02:26:14.629 a net importer which affected their ability to transfer 02:26:14.638 --> 02:26:16.690 power to the adjacent balancing authorities, which 02:26:16.700 --> 02:26:18.888 was, you know, part of the reason in addition to their 02:26:18.899 --> 02:26:22.129 own generation losses led to the EEA conditions that 02:26:22.138 --> 02:26:26.058 that that happened when you look at the sum total of 02:26:26.069 --> 02:26:28.870 the generation outages, it was just over 1700 units 02:26:29.659 --> 02:26:33.388 and 3500 plus outages that we recorded during that 02:26:33.399 --> 02:26:36.040 event period, which was from the 21st to the 26th. 02:26:36.218 --> 02:26:40.338 Uh 63% of those were gas fired generation, gas fired 02:26:40.349 --> 02:26:44.000 generation. (item:44:David Penney on Elliott vs. Uri) It's important to note that there was a 02:26:44.384 --> 02:26:47.963 difference in Elliott vs Uri in that the wind impact 02:26:47.974 --> 02:26:51.254 on the wind generation was minimal. Elliott did not 02:26:51.263 --> 02:26:54.065 have the same type of icing freezing precipitation 02:26:54.075 --> 02:26:57.304 snow conditions that Uri did. So. With the exception 02:26:57.315 --> 02:27:00.144 of some of the Far North areas of MISO area, the wind 02:27:00.155 --> 02:27:02.985 generation was relatively not impacted by, by this 02:27:02.995 --> 02:27:07.319 event and was available when you break down the causes 02:27:07.329 --> 02:27:11.030 of the degeneration. We keep referring to them as 02:27:11.040 --> 02:27:15.718 the big three, either freezing issues, gas fuel issues 02:27:15.729 --> 02:27:19.509 or mechanical electrical failure issues. When you look 02:27:19.519 --> 02:27:23.110 at the freezing issues, same issues we always run across 02:27:23.120 --> 02:27:25.739 freezing instrumentation, freezing sensing lines, frozen 02:27:26.099 --> 02:27:30.388 bows. It was interesting to note that in excess of 02:27:30.399 --> 02:27:33.870 70% of the units that had freezing issues were in the 02:27:33.879 --> 02:27:36.579 South, Central or Southeastern portion of the Eastern 02:27:36.588 --> 02:27:39.718 interconnection. Those types of units are designed 02:27:39.729 --> 02:27:41.950 similar to the units we have in Texas, they're designed 02:27:41.959 --> 02:27:44.968 to withstand heat. So they're much more open architecture 02:27:45.019 --> 02:27:47.888 And so that's what you know, and that's the similarity 02:27:47.899 --> 02:27:50.479 that those units experience a lot more freezing issues 02:27:50.489 --> 02:27:53.200 than the folks in the North did because those units 02:27:53.209 --> 02:27:54.799 are designed to handle cold weather. The units in the 02:27:54.808 --> 02:27:59.009 South aren't one of the other pieces we collected in 02:27:59.019 --> 02:28:03.110 data was the minimum minimum design temperature that 02:28:03.120 --> 02:28:06.099 the unit is designed to operate at. When we looked 02:28:06.110 --> 02:28:09.019 at the correlation between the actual ambient temperatures 02:28:09.030 --> 02:28:11.588 at the generation facilities versus what their design 02:28:11.599 --> 02:28:14.799 temperatures. 80% of the units that had freezing issues 02:28:14.808 --> 02:28:17.468 were at a temperature higher than their designed sign 02:28:17.479 --> 02:28:20.388 temperature, which means that there's some gaps, potential 02:28:20.399 --> 02:28:22.790 gaps in their ability to weatherize their units. 02:28:24.450 --> 02:28:27.459 When you look at the fuel issues, which was about 24% 02:28:27.468 --> 02:28:31.110 of the total outages, primarily all gas in excess. 02:28:31.120 --> 02:28:35.588 80% were those gas issues. The raw numbers were about 02:28:35.599 --> 02:28:40.239 28 gigawatts were curtailments or restrictions on firm 02:28:40.250 --> 02:28:43.269 transportation or interruptible transportation contracts 02:28:43.638 --> 02:28:46.968 There was 7500 megawatts in change for gas pressure 02:28:46.979 --> 02:28:50.319 issues, but there was also a very large number of in 02:28:50.329 --> 02:28:53.019 excess of 24 gigawatts that were due to gas market 02:28:53.030 --> 02:28:55.679 issues. (item:44:David Penney on how market was unable to be supported) And this is one of the interesting pieces of 02:28:55.690 --> 02:28:59.040 this event because it occurred coming up on a holiday 02:28:59.049 --> 02:29:02.239 weekend because of the things that Mark alluded to 02:29:02.250 --> 02:29:05.149 with inaccuracies in the load forecast and BAs were 02:29:05.159 --> 02:29:07.388 not committing their units far enough ahead of time 02:29:07.489 --> 02:29:09.959 So these units weren't committed. So when they were 02:29:09.968 --> 02:29:12.838 asked to be committed, it was too late to get gas. 02:29:12.849 --> 02:29:14.849 The market wasn't there to support it because of the 02:29:14.860 --> 02:29:17.209 timing differences in the electric, electricity markets 02:29:17.218 --> 02:29:18.950 and the gas markets. And that again, that was about 02:29:18.959 --> 02:29:25.190 24 gigawatts of, of, of things um on the mechanical 02:29:25.200 --> 02:29:28.638 electrical failure cause this was about 40% of the 02:29:28.649 --> 02:29:31.290 total causes one of the interesting things that when 02:29:31.299 --> 02:29:34.500 we did the statistics on this was the correlation between 02:29:34.509 --> 02:29:37.468 those the rates of mechanical electrical failures with 02:29:37.479 --> 02:29:40.459 the drop in temperatures. We saw significant increases 02:29:40.468 --> 02:29:43.679 in those failure rates of units that at least they 02:29:43.690 --> 02:29:45.989 identified as a mechanical electric failure with the 02:29:46.000 --> 02:29:48.790 falling drop in temperatures. And there's a recommendation 02:29:48.799 --> 02:29:52.388 which I'll talk to related to that. Did that pick up 02:29:52.399 --> 02:29:55.530 kind of ambient temperature versus, I mean, did that 02:29:55.540 --> 02:30:00.149 pick up windshield? We have windshield data but we 02:30:00.159 --> 02:30:02.138 were mainly looking when we did our statistics, we 02:30:02.149 --> 02:30:04.120 were mainly looking at ambient temperatures, actual 02:30:04.190 --> 02:30:04.579 ambient temperatures. 02:30:06.190 --> 02:30:08.649 (item:44:David Penney on recommendations) So when you look at the recommendations, recommendation 02:30:08.659 --> 02:30:11.299 number one in particular is related to these generation 02:30:11.308 --> 02:30:15.069 causes and it piggybacks. A lot of the same recommendations 02:30:15.079 --> 02:30:19.229 from the UI report looking at developing an implementation 02:30:19.239 --> 02:30:21.870 of the standards, NERC standards that were recommended 02:30:21.879 --> 02:30:26.269 after Uri plus also some robust monitoring to see if 02:30:26.280 --> 02:30:30.579 there's still a potential gaps that may exist some 02:30:30.588 --> 02:30:33.088 of the outreach and follow up activities we're looking 02:30:33.099 --> 02:30:35.918 at. And in the in this as a result of this is 02:30:35.929 --> 02:30:38.599 you know, NERC issued a, a cold weather alert uh several 02:30:38.610 --> 02:30:41.129 months back and we have that data in our hands now 02:30:41.399 --> 02:30:44.860 and we're using that data to try to educate where our 02:30:44.870 --> 02:30:48.159 our high risk units are. Uh so we can look at, you 02:30:48.168 --> 02:30:50.049 know what we're going to do from an outreach perspective 02:30:50.058 --> 02:30:52.329 as well as you know, potential compliance monitoring 02:30:52.338 --> 02:30:57.409 around those high risk units um on the mechanical electrical 02:30:57.418 --> 02:30:59.870 failure rates. It's recommendation number two that's 02:30:59.879 --> 02:31:05.360 looking at a having an probably NC will be contracting 02:31:05.370 --> 02:31:08.620 with RI potentially to look at a study or some other 02:31:08.629 --> 02:31:10.909 academic institution that's qualified to do this type 02:31:10.918 --> 02:31:13.418 of study, to look at that correlation between mechanical 02:31:13.429 --> 02:31:17.379 electrical failure rates and temperatures. Uh The last 02:31:17.388 --> 02:31:20.019 thing to talk about briefly is the black start units 02:31:20.030 --> 02:31:24.729 After um after Uri, there was a recommendation in 02:31:24.739 --> 02:31:27.739 the, in the FERC report on Uri to look at the the 02:31:27.750 --> 02:31:31.190 failure rates that we saw from in ERCOT during Uri uh 02:31:31.218 --> 02:31:34.259 related to the black start units due to failure to 02:31:34.269 --> 02:31:37.909 start and multiple issues. Uh FERC has initiated that 02:31:37.918 --> 02:31:42.299 inquiry or uh study and the report is, is expected 02:31:42.308 --> 02:31:45.088 to be published sometime in December. Now when you 02:31:45.099 --> 02:31:48.780 look at the impact of Elliott in the East, there was 02:31:48.790 --> 02:31:53.299 roughly 150 plus black start units, 19,000 megawatts 02:31:53.308 --> 02:31:55.759 and chains that had a failure to start forced outer 02:31:55.780 --> 02:31:59.110 of forced rate. Many, many of those were gas units 02:31:59.120 --> 02:32:02.319 75% of those are gas units. So recommendation number 02:32:02.329 --> 02:32:05.479 three of the LA report is looking at doing a similar 02:32:05.489 --> 02:32:08.110 type of study that we're doing. We we just are finishing 02:32:08.120 --> 02:32:12.530 for Uri in the Eastern Interconnection. So look forward 02:32:12.558 --> 02:32:16.099 to that. Yeah. Yeah. And, and we did do, I did do 02:32:16.110 --> 02:32:18.659 some uh you know, again like Mark talked about you 02:32:18.668 --> 02:32:22.349 know Elliott, Elliott from ERCOT's perspective was 02:32:22.360 --> 02:32:24.819 a relatively low impact event, but I don't want to 02:32:24.829 --> 02:32:27.808 leave you with the fact that we know we had impacts 02:32:27.819 --> 02:32:30.058 We did have units that experienced gas restrictions 02:32:30.069 --> 02:32:32.489 we did have freezing and, and, and other failures. 02:32:32.769 --> 02:32:36.459 Uh and we did have the experienced the same issues 02:32:36.468 --> 02:32:38.638 with load forecast errors that the East did. And they've 02:32:38.649 --> 02:32:41.468 already taken issues or things to address some of that 02:32:41.799 --> 02:32:44.750 When, when you look at SPPs and MISO areas that are 02:32:44.759 --> 02:32:47.819 inside the Texas State line, they also had some PGRRs 02:32:47.829 --> 02:32:51.918 13 plus units, 5700 megawatts and chains of SPP and 02:32:52.159 --> 02:32:53.819 MISO units that are inside the Texas border that were 02:32:53.829 --> 02:32:57.620 impacting this. SPP the wind was blowing. Yeah, it was 02:32:59.099 --> 02:33:02.690 so just, just a couple of things to mention too. I 02:33:02.700 --> 02:33:05.058 (item:44:Mark Henry on winterization of natural gas facilities) I know it's another floor in this building that's more 02:33:05.069 --> 02:33:07.409 interested in natural gas issues. But as David pointed 02:33:07.418 --> 02:33:10.950 out, uh loss of natural gas supplies is, is a big deal 02:33:10.959 --> 02:33:14.329 and recommendation four has a series of parts that 02:33:14.338 --> 02:33:19.250 relate to Legislation or regulation to cause natural 02:33:19.259 --> 02:33:22.388 gas facilities to be winterized, better to identify 02:33:22.399 --> 02:33:24.808 critical loads and to create something sort of like 02:33:24.819 --> 02:33:28.329 what we call a reliability coordinator or better communications 02:33:28.489 --> 02:33:31.700 among the operators within the gas industry to try 02:33:31.709 --> 02:33:35.750 and improve the ability of that fuel to get delivered 02:33:35.759 --> 02:33:38.159 We know it's difficult with the way the natural gas 02:33:38.168 --> 02:33:40.459 industry works and the way wells change and things 02:33:40.468 --> 02:33:43.750 like that. That's one of the, the key areas and I think 02:33:43.759 --> 02:33:46.459 there'll be, uh, quite a bit of discussion nationally 02:33:46.540 --> 02:33:50.588 about that. Do you talk to those people? Not a lot 02:33:50.599 --> 02:33:53.479 a little bit, a little bit. We know that, that NERC 02:33:53.729 --> 02:33:57.979 has done several assessment type reports over the years 02:33:57.989 --> 02:34:01.280 on gas electric coordination's an ongoing matter. We 02:34:01.290 --> 02:34:04.329 try to be aware and if we can provide some information 02:34:04.338 --> 02:34:07.534 we will, we want to see that that that's followed through. 02:34:07.604 --> 02:34:10.245 Uh Certainly, uh some of the things we've done here 02:34:10.254 --> 02:34:14.284 like the gas critical load mapping that you all the 02:34:14.293 --> 02:34:17.843 Railroad Commission worked on a great example. People 02:34:17.854 --> 02:34:19.665 are very impressed with that. That's the sort of thing 02:34:19.674 --> 02:34:22.665 that uh I think part of what this report has done, 02:34:22.989 --> 02:34:25.459 maybe not in big bold letters but talked about the 02:34:25.468 --> 02:34:29.668 efforts taken here in the state to bring us to a better 02:34:29.679 --> 02:34:32.569 position. And folks are looking at that around the 02:34:32.579 --> 02:34:35.599 country too. (item:44:David Penney on successful Legislative actions) The inquiry team definitely recognized 02:34:35.610 --> 02:34:38.944 the I'll say success of the Legislative actions that 02:34:38.954 --> 02:34:42.224 were taken by Texas particularly around winterizing 02:34:42.284 --> 02:34:46.584 the gas critical gas industry components or supply 02:34:46.593 --> 02:34:49.155 chain as well as identifying critical loads. And that's 02:34:49.165 --> 02:34:51.995 why parts of recommendation are or are worded the way 02:34:52.004 --> 02:34:54.963 they are to try to extend that same type of thought 02:34:54.974 --> 02:34:58.269 process into the Eastern Interconnection. (item:44:Joseph Younger on Black Start Report) And Commissioner 02:34:58.280 --> 02:35:01.489 McAdams, I'll just add uh Mark's correct with regards 02:35:01.500 --> 02:35:04.280 to natural gas folks. But we we've been in contact 02:35:04.290 --> 02:35:07.360 with the Railroad Commission. We had them along with 02:35:07.370 --> 02:35:10.519 the PUC Staff at our winterization workshop as well 02:35:10.690 --> 02:35:13.440 So, so we're having those conversations with them. 02:35:13.780 --> 02:35:16.519 David mentioned the Uri Black Start Report, which will 02:35:16.530 --> 02:35:20.290 be out in December, the FERC and NERC Staff as well 02:35:20.299 --> 02:35:23.000 as our Staff has worked on that report. They've coordinate 02:35:23.009 --> 02:35:25.940 with the PUC Staff as well as Railroad Commission Staff 02:35:25.950 --> 02:35:28.899 on those recommendations as well. So, so we're there 02:35:28.909 --> 02:35:31.149 there is an exchange of information with the, with 02:35:31.159 --> 02:35:33.088 the railroad commission on these topics. 02:35:37.729 --> 02:35:39.780 I don't have any other questions on that. Do you all 02:35:40.690 --> 02:35:43.668 So I would like Joseph to talk really quickly about 02:35:43.679 --> 02:35:47.500 Grid X. We don't talk about cybersecurity much and 02:35:47.509 --> 02:35:51.769 we shouldn't. But we know it's that understood 02:35:54.069 --> 02:35:57.099 necessary component that we have to take very seriously 02:35:57.110 --> 02:36:01.700 and NERC consistently has this program called Grid X, which 02:36:01.709 --> 02:36:06.709 is a big tabletop exercise. And I know uh PUC Staff 02:36:06.718 --> 02:36:10.360 Chuck Bondra, I was looking for him too. Oh, hi John 02:36:12.849 --> 02:36:16.860 Anyway, I wanted Joseph to give us a background on 02:36:16.870 --> 02:36:19.099 that just a little bit. And if y'all are happy with 02:36:19.110 --> 02:36:21.649 the participation within ERCOT and within Texas. 02:36:21.659 --> 02:36:23.569 Yeah, absolutely. Well, it was a great event. (item:44:Joseph Younger on Grid X) It's 02:36:23.579 --> 02:36:27.440 the seventh Grid X exercise. It's a biannual exercise 02:36:27.450 --> 02:36:31.069 So every other year and there's generally several 1000 02:36:31.079 --> 02:36:35.009 participants across the North America, several 100 02:36:35.019 --> 02:36:39.585 different organizations from the industry, also from 02:36:39.595 --> 02:36:44.595 telecom water, other critical infrastructure partners 02:36:44.606 --> 02:36:48.897 that are working together. I can't speak a lot as you 02:36:48.906 --> 02:36:51.996 referenced about this specific exercise this year. 02:36:52.246 --> 02:36:56.816 What it did do is simulate a coordinate cyber and physical 02:36:56.826 --> 02:37:00.085 TAC on the electric grid. And it was really looking 02:37:00.095 --> 02:37:04.843 at a long duration determined type event. So something 02:37:04.852 --> 02:37:09.462 that lasted uh multiple weeks and simulating that response 02:37:09.472 --> 02:37:13.542 There were two phases to the exercise. Uh On November 02:37:13.552 --> 02:37:17.722 14th and 15th, uh there's the distributed play exercise 02:37:17.734 --> 02:37:20.824 where different organizations are testing their response 02:37:20.833 --> 02:37:23.574 plans, their communication protocols, those all those 02:37:23.583 --> 02:37:26.984 activities. Uh Several of our staff including including 02:37:27.090 --> 02:37:31.500 David had the opportunity to observe ERCOT's activities 02:37:31.510 --> 02:37:36.760 in that phase of the Grid X exercise. On the 16th, Jim 02:37:36.771 --> 02:37:39.990 Albright, who's our CEO and myself, we participated 02:37:40.000 --> 02:37:44.170 in the executive tabletop which is looking at similar 02:37:44.180 --> 02:37:47.230 a similar scenario but talking through at an executive 02:37:47.240 --> 02:37:50.430 level responses across industry. So they are representatives 02:37:50.441 --> 02:37:54.168 from the gas sector again, uh other critical industries 02:37:54.179 --> 02:37:56.649 and how they would coordinate a response to those attacks 02:37:56.659 --> 02:37:59.468 as well as all the government agencies involved uh 02:37:59.479 --> 02:38:02.500 to your point. Um Commissioner Glotfelty, the, the, the 02:38:02.558 --> 02:38:05.989 the, the, the group that organizes grid X as part of 02:38:06.000 --> 02:38:10.280 NERC is the EISAC. That's the energy information. I'll 02:38:10.290 --> 02:38:14.530 read it. Sharing and analysis center. And, and 02:38:14.558 --> 02:38:17.269 like we've, we've always had great participation from 02:38:17.280 --> 02:38:20.509 this region in Grid X and with the EISAC. But 02:38:20.519 --> 02:38:23.468 I would be remiss if I missed an opportunity to encourage 02:38:23.479 --> 02:38:28.379 folks that to sign up for EISAC, they provide security 02:38:28.388 --> 02:38:31.319 alerts, lots of information. It's not a compliance 02:38:31.349 --> 02:38:34.610 based organization, but they provide a tremendous amount 02:38:34.620 --> 02:38:38.829 of information about threats, both logical and physical 02:38:38.838 --> 02:38:41.718 threats. So it's a really important thing that we like 02:38:41.729 --> 02:38:44.940 to promote. They organize Grid X and it's a, it's a 02:38:44.950 --> 02:38:47.599 it's a good exercise. So I'm really happy you gave 02:38:47.610 --> 02:38:49.819 us a chance to kind of promote it. So, thank you. Thank 02:38:50.079 --> 02:38:53.588 you. I did have a question. So you did the tabletop 02:38:53.718 --> 02:38:57.299 and oftentimes there are findings, right? And so is 02:38:57.308 --> 02:39:00.360 there a follow up? (item:44:Joseph Younger on EISAC) Yes, I'm I'm really glad I forgot 02:39:00.370 --> 02:39:03.308 to mention it. So the EISAC will be producing a public 02:39:03.319 --> 02:39:06.509 report that will come out early next year that will 02:39:06.519 --> 02:39:09.388 contain lessons learned, recommended actions and other 02:39:09.399 --> 02:39:12.950 items. So when that comes out, we will file it in our 02:39:12.968 --> 02:39:16.829 project at the Commission. Thank you. (item:44:Commissioner Glotfelty on getting involved in EISAC) And Madam Chair 02:39:16.838 --> 02:39:21.110 as you know, the one of the benefits of these exercises 02:39:21.120 --> 02:39:24.638 is the more you do them, the better you get. So the 02:39:24.649 --> 02:39:28.429 more this is the seventh one, as we get more of our 02:39:28.440 --> 02:39:31.700 stakeholders in Texas participating in this, the better 02:39:31.709 --> 02:39:33.549 they can coordinate if something would ever happen 02:39:33.558 --> 02:39:36.149 to our system. So I think it's really valuable that 02:39:36.790 --> 02:39:39.019 everybody that's listening, that's not part of the 02:39:39.579 --> 02:39:42.429 EISAC you know, get involved in that. And if you have 02:39:42.440 --> 02:39:46.280 the resources but the big players around the state 02:39:46.290 --> 02:39:49.200 are very intertwined in that effort and we need them 02:39:49.209 --> 02:39:53.019 to be because they're the linchpin of the success and 02:39:53.899 --> 02:39:55.599 security of the system. 02:39:57.519 --> 02:40:00.259 Great. Yeah, thank you. Thank you, Jim. 02:40:04.349 --> 02:40:09.769 Mhm. So I don't have anything on Items 45 or 46. (item:47:Chairwoman Jackson lays out Project No. 41211) Next 02:40:09.780 --> 02:40:13.968 up is Item No. 47, Project No. 41211. This is 02:40:13.979 --> 02:40:16.190 the Commission's project for information related to 02:40:16.200 --> 02:40:18.870 the organization of MISO States. Shelah, do we have 02:40:18.879 --> 02:40:21.149 anyone from the public signed up to speak on Item No. 02:40:21.159 --> 02:40:24.168 47? No, ma'am. Commissioner Cobos, I believe you have 02:40:24.179 --> 02:40:27.088 an update. (item:47:Commissioner Cobos provides update on MISO states) Yes Chair Jackson. So I'm just providing 02:40:27.099 --> 02:40:30.588 an update. You know, we filed comments uh the Commission 02:40:30.599 --> 02:40:36.690 filed comments at FERC on um MISO's RBDC PURA filing. 02:40:37.599 --> 02:40:41.629 And on November 22, FERC issued a deficiency letter 02:40:41.638 --> 02:40:45.120 requesting additional information from MISO among the 02:40:45.129 --> 02:40:47.700 14 questions included in, there are four related to 02:40:47.709 --> 02:40:53.030 the MISO opt out provision. And um they basically ask 02:40:53.040 --> 02:40:56.149 why MISO is proposing that analysis that elects to 02:40:56.159 --> 02:40:59.138 use the RBDC opt out must opt out for its entire 02:40:59.149 --> 02:41:02.218 resource adequacy requirement rather than have the 02:41:02.229 --> 02:41:05.759 option to elect to opt out for a portion of its resource 02:41:05.769 --> 02:41:09.849 adequacy requirement. And how the um second example 02:41:09.860 --> 02:41:13.709 question is how the RBDC uh opt out adder is designed 02:41:13.718 --> 02:41:16.700 to provide comparable treatment to LSEs who participate 02:41:17.519 --> 02:41:21.558 in MISO's proposed reliability demand based auction 02:41:21.918 --> 02:41:25.399 And those lies that elect to use the RBDC opt out 02:41:25.668 --> 02:41:29.968 Essentially, I think what FERC is doing is um asking 02:41:29.979 --> 02:41:35.319 MISO why their opt out provision isn't flexible enough 02:41:35.329 --> 02:41:41.700 to accommodate um a portion of um uh and opt out by 02:41:41.709 --> 02:41:44.540 utility or their resource adequacy requirement, which 02:41:44.549 --> 02:41:49.129 is um basically our position, you know, with it, you 02:41:49.138 --> 02:41:52.138 know, we, we were generally fine with um MISO pursuing 02:41:52.149 --> 02:41:54.269 the reliability demand based curve with the downward 02:41:54.280 --> 02:41:55.950 sloping curve because it's better than the vertical 02:41:55.959 --> 02:42:00.218 demand curve for economic um more, more efficient pricing 02:42:00.229 --> 02:42:04.409 and reserves. However, our concern in our comments 02:42:04.418 --> 02:42:09.489 uh had been is and had been through ERSC resolutions 02:42:09.500 --> 02:42:14.049 that we adopted that MISO's opt out process was uh very 02:42:14.058 --> 02:42:17.700 onerous. So it was in, in, in turn really kind of trying 02:42:17.709 --> 02:42:20.099 to incent all the utilities put all their generation 02:42:20.110 --> 02:42:23.918 into the auction. So I, I think with this deficiency 02:42:23.929 --> 02:42:30.370 letter um, um you know MISO or FERC rather has essentially 02:42:30.379 --> 02:42:32.718 reviewed all the comments that are filed and I think 02:42:32.729 --> 02:42:35.718 we managed to crack a little bit of a door opening 02:42:35.729 --> 02:42:40.500 here to have FERC take into consideration or evaluate 02:42:40.808 --> 02:42:44.349 MISO's flexibility. Why Miso hasn't provided flexibility 02:42:44.360 --> 02:42:47.899 in their opt out process? Okay. So, uh FERC has asked 02:42:48.239 --> 02:42:52.860 MISO to respond to the deficiency letter um by December 02:42:52.870 --> 02:42:58.979 22nd and then um uh parties will have an opportunity 02:42:58.989 --> 02:43:02.290 to comment all comments in response to MISO's response 02:43:02.299 --> 02:43:07.588 to FERC by January 12th. Our next open meeting would 02:43:07.599 --> 02:43:10.909 be, I guess around that time would be January 18th. 02:43:11.280 --> 02:43:14.790 So what I would like to request is that, um, there'd 02:43:14.799 --> 02:43:17.409 be delegated authority to direct outside counsel to 02:43:17.418 --> 02:43:21.500 follow comments in response to the MISO's filing. 02:43:21.509 --> 02:43:24.308 If, if necessary, consistent with the position that 02:43:24.319 --> 02:43:27.769 we took in our initial comments in the docket. I agree 02:43:27.790 --> 02:43:30.750 with that. I agree as well. That would help. So we 02:43:30.759 --> 02:43:33.459 won't have to ask for an extension at FERC and we 02:43:33.468 --> 02:43:35.450 can just follow the comments sometime at the next open meeting. 02:43:37.729 --> 02:43:40.468 Shelah, do you need motion on that or you good? No. I think, I think the discussion and agreement among 02:43:40.479 --> 02:43:43.440 the Commissioners is sufficient. And you've already 02:43:43.450 --> 02:43:45.808 done a lot of the work. Yes, it sounds like somebody 02:43:45.819 --> 02:43:48.718 read your letter. Yes. Yes, finally. Just send them the same 02:43:48.729 --> 02:43:49.019 thing. 02:43:53.099 --> 02:43:55.168 Okay. Well, thank you for your work on this. It sounds 02:43:55.179 --> 02:43:59.899 like it's um, making an impact and appreciate it. I 02:43:59.909 --> 02:44:04.500 don't have anything on Items 48, 49 or 50. (item:51:Chairwoman Jackson lays out Project No. 2) Next up is 02:44:04.509 --> 02:44:08.540 Item No. 51, Project No. 2. This is the Commission's 02:44:08.549 --> 02:44:12.069 project regarding the filing of Open Meeting transcripts. 02:44:12.679 --> 02:44:15.290 Shelah, do we have anyone from the public signed up 02:44:15.299 --> 02:44:19.989 to speak on Item 51? No, ma'am. Commission Staff filed 02:44:20.000 --> 02:44:23.629 a memo with draft minutes from the October 20th Open 02:44:23.638 --> 02:44:27.319 meeting. You have any thoughts? They look good to me. 02:44:27.558 --> 02:44:30.879 Yeah, I would, would you entertain a motion? I would. 02:44:30.888 --> 02:44:33.399 (item:51:Motion to approve minutes of the PUC October 20, 2023 Open Meeting) I would move to approve the minutes of the October 02:44:33.409 --> 02:44:37.290 20, 2023 Open Meeting of the Public Utility Commission. 02:44:37.950 --> 02:44:40.120 Second. I have a motion and a second. All in favor, 02:44:40.129 --> 02:44:44.168 say aye. Aye. Motion passes. I don't have anything for Item 02:44:44.179 --> 02:44:48.379 number 52. (item:53:Chairwoman Jackson lays out Project No. 55153) Next up is Item No. 53. Project No. 02:44:48.388 --> 02:44:52.229 55153. This is the Commission's project for review 02:44:52.239 --> 02:44:57.049 of 22.52 relating to notice and licensing proceedings. 02:44:57.088 --> 02:44:59.269 Shelah, do we have anyone from the public signed up 02:44:59.280 --> 02:45:03.479 to speak on Item 53? No ma'am, we do not. PUC Staff 02:45:03.489 --> 02:45:07.829 is here if there are any questions? To quote my old 02:45:07.838 --> 02:45:09.929 boss. This is looking pretty good, Dave. 02:45:12.879 --> 02:45:16.329 Yeah. Okay. (item:53:Motion to approve PUC Staff's recommendation for adoption) I would move that we adopt the proposal. Second. 02:45:17.099 --> 02:45:21.259 Okay. So we have a motion to approve Staff's recommendation 02:45:21.269 --> 02:45:24.929 for adoption. And we have a second. All in favor, 02:45:24.940 --> 02:45:27.418 say aye. Aye. Motion passes. 02:45:29.209 --> 02:45:32.450 I don't have anything on Item No. 54. 02:45:32.459 --> 02:45:37.269 (item:55:Chairwoman Jackson lays out Project No. 55603)Next up is Item No. 55, Project No. 55603. This 02:45:37.280 --> 02:45:40.088 is the Commission's project for its public notice of 02:45:40.099 --> 02:45:42.860 summary of customer complaints and enforcement. 02:45:42.870 --> 02:45:45.610 Shelah, do we have anyone from the public signed up 02:45:45.620 --> 02:45:50.269 to speak on Item No. 55? No, ma'am. PUC Staff 02:45:50.280 --> 02:45:53.588 is here to answer any questions. Do you have any thoughts? 02:45:54.918 --> 02:45:55.739 (item:55:Chairwoman and Commissioners congratulate Commission Staff for job well done) I just. 02:46:02.379 --> 02:46:06.418 Know it as always. I think the division is doing a great 02:46:06.429 --> 02:46:10.049 job. If anything, we could scrape together more 02:46:10.058 --> 02:46:14.159 resources but somebody will try to do that next Session. 02:46:14.168 --> 02:46:16.629 But uh I, I think it's great. 02:46:18.519 --> 02:46:20.870 I'd just like to add my thanks to Chris and Barksdale 02:46:20.879 --> 02:46:23.138 for providing the data in this report. It's great to 02:46:23.149 --> 02:46:26.530 see where we are from year to year. Especially 02:46:26.540 --> 02:46:29.338 to see the number of cases and penalties that's increased 02:46:29.388 --> 02:46:31.709 since the division of compliance and enforcement loss 02:46:31.718 --> 02:46:35.349 launched this just over two years ago so. Goes to show 02:46:35.360 --> 02:46:37.338 that we're totally making an impact. And I think y'all 02:46:37.349 --> 02:46:38.968 should be really proud, y'all are doing a really good 02:46:38.979 --> 02:46:39.379 job. 02:46:41.360 --> 02:46:43.360 Shows that we're not letting the important thing slip 02:46:43.370 --> 02:46:46.040 off the plate either um with all this other important 02:46:46.049 --> 02:46:49.229 stuff that we have to do. So, thanks. (item:55:Connie Corona on management action from 2010 Sunset Review) Commissioners, 02:46:49.239 --> 02:46:53.179 I'd like to note at this time. This um originated with 02:46:53.190 --> 02:46:56.838 the management action from our 2010 Sunset Review. 02:46:56.860 --> 02:47:02.308 Is that right? Yes, we've uh since undergone a um a 02:47:02.569 --> 02:47:06.679 subsequent Sunset Review with additional management 02:47:06.690 --> 02:47:12.558 recommendations. Um among those was um making our website 02:47:12.569 --> 02:47:19.290 more robust and, and able to access data of interest 02:47:19.299 --> 02:47:22.579 to consumers and the general public. And so we will 02:47:22.588 --> 02:47:27.530 be transitioning this sort of annual posting of a static 02:47:27.540 --> 02:47:33.009 report into more of an ongoing living uh dashboard 02:47:33.019 --> 02:47:34.888 if you will on our website. 02:47:36.759 --> 02:47:38.388 Excellent improvement. Thank you. 02:47:40.030 --> 02:47:43.979 Okay. (item:56:Chairwoman Jackson lays out standing item for Agency Administrative Issues) Next up is Item No. 56 our standing item for 02:47:43.989 --> 02:47:47.379 Agency Administrative Issues. Shelah, do we have anyone 02:47:47.388 --> 02:47:50.349 from the public signed up to speak on Item No. 56? 02:47:50.450 --> 02:47:53.638 No ma'am. Thomas, do you have an update? Yes, ma'am. 02:47:53.649 --> 02:47:56.750 (item:56:PUC Staff's Thomas Gleeson on impaneling TX Backup Power Package Advisory Committee) Thank you Madam Chair, Commissioners. So what I have 02:47:56.759 --> 02:48:00.319 this afternoon is really a request for some action. 02:48:00.329 --> 02:48:03.530 So, as you're aware earlier this month, the voters 02:48:03.540 --> 02:48:06.860 approve the Texas Energy Fund, one of the programs 02:48:06.870 --> 02:48:09.599 and that is the Texas Backup Power package. At our 02:48:09.750 --> 02:48:13.649 last open meeting. You all adopted a rule concerning 02:48:13.709 --> 02:48:16.509 the Texas Backup Power Package Advisory Committee. 02:48:16.968 --> 02:48:20.049 So now that that rule is effective, we actually need 02:48:20.058 --> 02:48:23.418 to empanel a committee. So what I'm asking for is anyone 02:48:23.429 --> 02:48:26.349 who is interested in being on that Advisory Committee 02:48:26.360 --> 02:48:30.959 to submit a resume and statement of interest to Texas 02:48:30.968 --> 02:48:36.599 Backup Power at puc.texas.gov. Please do that by December 02:48:36.610 --> 02:48:40.418 29th. I'd like to have the Advisory Committee impaneled 02:48:40.429 --> 02:48:43.620 so I can discuss it at our January Open Meeting. If 02:48:43.629 --> 02:48:45.479 anyone has any questions, you can always reach out 02:48:45.489 --> 02:48:48.659 to David Gordon on our Staff. And if there are any 02:48:48.668 --> 02:48:52.290 questions about uh the roles and responsibilities of 02:48:52.299 --> 02:48:54.829 the Committee. You can look to the rule that was previously 02:48:54.838 --> 02:48:58.479 adopted 25.515. And you pick those people, so you need 02:48:58.489 --> 02:48:59.838 you need email. That is, that is correct. 02:49:01.879 --> 02:49:05.179 All right, very good. Thank you. Good, good progress here. I don't 02:49:05.190 --> 02:49:10.030 have anything on Items 57 or 58. We already took up 02:49:10.040 --> 02:49:13.530 Item 59 which is Closed Session. (item:59:Chairwoman Jackson adjourns meeting) There being no further 02:49:13.540 --> 02:49:15.610 business to come before the Commission. This meeting 02:49:15.620 --> 02:49:18.299 of the Public Utility Commission of Texas is hereby 02:49:18.308 --> 02:49:20.110 adjourned at 2:42.