WEBVTT

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(item:59:Chairwoman Jackson concludes Closed Session, Open Meeting resumed) The Closed Session is hereby concluded at 11:32 on November

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30, 2023 and the Commission will resume its Public

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Meeting. Having discussed litigation matters in Closed

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Session. (item:59:Motion to approve mediated settlement) I will now entertain a motion for the following

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action to approve the mediated settlement of alleged

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underpayments of TUSF amounts reached on November

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3, 2023. As reflected in the mediated settlement agreement

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of that date in AMA Communications, LLC dba AMA

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Tactel Communications versus the PUC. So moved. Second.

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I have a motion and a second. All in favor, say aye.

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Aye. Motion passes. We will now resume our agenda with

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Item No. 33.

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(item:33:Chairwoman Jackson lays out Project No. 54445) Next up is Item No. 33, Project No. 54445. This

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is the Commission's project for rules adopted by ERCOT.

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Um specifically, we're addressing NPRR1184, NPRR1186

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and SCR824. Shelah, do we have anyone from the

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public signed up to speak? No, ma'am. PUC Staff filed

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a memo in a proposed order and Commissioner Glotfelty

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filed a memo. We'll have Staff come up first and provide

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an overview of their recommendations. And then Commissioner

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Glotfelty, you can lay out your memo. So could you

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please state your name for the record?

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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

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comments and then Ramya will take over. One of the questions

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I have. Can you move your microphone up there? Do you

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have any questions on the memo? Other than NPRR1186

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NPRR1184 and SCR824.

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I do not. Okay. Thank you. The other thing, I just want to give

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a high level if the you have market analysis covers the

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ERCOT stakeholder process and what we do to monitor NPRRs.

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whenever we receive a notice from notice from ERCOT and NPRR has

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been filed. I immediately assign it to a Staff member

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and throughout the life of the NPRR. We monitor and

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track it and if there is big issue items like this

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one, we make sure Staff contacts ERCOT SAPs, market participants

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IMM and so that we are all knowledgeable on the different

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issues. So we don't take this recommendation lightly

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We want to make sure, you know, we are uh knowledgeable

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in the matter as much as we can before we make our

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recommendations. And as you know, we are also trying

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to elevate our technical expertise like Commissioner

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Glotfelty mentioned like meeting with Siemens, meeting

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with research institute, institute. So we are trying

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to do a lot to elevate our detailed understanding of

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this very complex issues. And then we also meet before

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Board Meeting before we file these recommendations

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with, with my Staff and with Connie we look all of the

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NPRR for approved and what staff we recommend. So

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we have all this process and we are trying to improve

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all that. That's all I wanted to say. Thank you.

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(item:33:PUC Staff's Ramya Ramaswamy on NPRR1186) Good morning Commissioners. Good morning Chair. So

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1186 is here in front of us today. Um where because

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of the rapid growth of batteries that we have in the

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ERCOT portfolio, which is a fantastic problem to have

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We definitely need them and they provide us very good

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reliable service. And we also learned from ERCOT that

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over 14 gigawatts of batteries could be interconnecting

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in 2024. That requires situational awareness for our

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control room operators to understand, to monitor and

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also have visibility into the capabilities that the

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batteries can bring to us at any time. 1186 requires

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USEs to telemeter state of charge of the batteries

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which are committed to providing ancillary services

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and energy in real time. As yulian pointed out in their

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comments, um all resources including DSRs are required

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to comply with all our compliance metrics put in place

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by our rules and by the protocols. 1186 does place

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obligation on the QSE to ensure resource level SOC

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compliance which is above and beyond what is required

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by other resources, other dispatchable resources in

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our ERCOT portfolio. That requirement was put in place

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because batteries are a unique

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resource with unique characteristics and SOC, the state

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of charge does allow ERCOT control room to have real

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time visibility on the capa the capability of what

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the battery can provide us in real time.

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But the QSC who is managing the battery at the time

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that it is providing, the resource can still transfer

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the as obligation from one of their qualified resource

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to another qualified resource within their portfolio

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Similar to how the QSE can transfer between say two

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natural gas units. Further, it is also Staff's opinion

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that with all the enhanced awareness and understanding

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of the capabilities of the batteries, ERCOT should reconsider

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the AS eligibility criteria for DSRs that have been

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put in place by uh NPRR1096 which is the

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two hour and four hour requirement. The additional

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requirements that 1186 requires battery should allow

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ERCOT with their better understanding to treat batteries

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similarly to how other dispatchable resources are being

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treated today. Staff is requesting 1186 be passed

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Please do let me know if you have any questions.

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(inaudible)

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Do we have any questions? How would you like to proceed

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as Staff? Jimmy has memo,

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Commissioner Glotfelty. Or do you want to ask questions to the Staff? Do you want

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me to lay it out?

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May I pose a question in that way it will carry over

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to ERCOT as well, Madam Chair. That might help set the

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table. Boy, it might be the last time I say that.

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Ramya, in your layout you said that under 1186.

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And we're talking about 1186. And, and if you could

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when you answer. (item:33:Commissioner McAdams' question on QSE designations) Clarify, what's in 1186 and then 1209

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follow on policy considerations as it stands today.

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So we know what's, what. If you could take a swing at

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it? But we'll get Dan Woodfin.

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Um

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you said that a QSC can designate an alternate resource

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on state of charge compliance? No, you did not. Okay.

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So this is a foundational distinction. Discharge.

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That's correct. (item:33:Ramya Ramaswamy clarification on QSE and ancillary services) What I said was a QSE can still 

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transfer AS obligation.

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AS. Correct. Ancillary. Ancillary Services.

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I apologize. Yes, so performance obligations. Not state to state a charge. Okay. I asked an answer

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Thank you Madam Chair.

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Okay. Do we have any other questions of Staff? I don't at this

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time. I would prefer that

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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

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Chair. In my memo, I lay out the reasons why I'm opposed

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to 1186. And I might say that this discussion uh and

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the back and forth with Staff in my opinion, has been

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hugely valuable to be able to have the discussion with

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Staff from two different perspectives to learn and

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to figure out how we're going to make this market better.

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So I'm very appreciative that even though we, we're

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falling on two different sides of this issue is that

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we can have these civil conversations. It's really

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really important that, that, that we continue to have

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these in a nutshell. Um I do in a nutshell. There's

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no evidence that this is needed or solves an actual

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problem in the market to enhance reliability. There

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have been no reliability problems from batteries. There's

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been no evidence provided by ERCOT that this has been

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a problem and I have asked for evidence that this has

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been an issue and have not received any second. It's

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totally discriminatory against batteries, the most

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flexible resource that we have on our system today

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and one that will likely get us through the cold winter

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which we're fearful about.

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We've committed to support policies that are nondiscriminating

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discriminatory and help sustain our competitive markets

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And this, in my opinion does not pass the test. It

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is discriminatory against batteries

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primarily from the sense that we are.

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Oh, let me finish reading. I get ahead of myself. Does

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NPRR attacks, attacks flexibility. Which is the very thing that

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we need in the ERCOT system today. Like I've said,

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we don't need to make everything look like a coal plant

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We should be able to understand the benefits of these

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flexible resources without having penalty structures

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that are disproportionately challenging to that resource

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NPRR1186 is the only protocol that would penalize

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a generator for bidding wrong.

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Not a performance penalty, but a bidding penalty.

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(item:33:Commissioner Glotfelty on compliance concerns) And finally, from numerous people fearful that the

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discussion of NPRR that's happened at ERCOT and within

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the TAC and within the ranks of this process have been

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victims or are fearful of compliance, investigations

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from ERCOT, solely for their opposition to this. And

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I don't think that can stand. I don't think that that

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is an appropriate way for a market to function. I don't

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know if it's true. I will stand here and tell you,

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I don't know. But I have heard from many people that

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they are fearful to stand up for this for what's right

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what they think is best for batteries because they

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are fearful of retribution from, from ERCOT. And, and

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I think that's something that we need to nip in the

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bud right now and say that can't stand in this market

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I laid out options for us to consider today. Four,

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I didn't, I didn't throw out a problem and just complain

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about it. I laid out four ideas that I thought we could

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discuss in our process. My preferred one is to vote

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this down, deny the NPRR and request that batteries

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work with ERCOT on state of charge issues so that ERCOT

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can learn how batteries operate to the benefit of our

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system and let flexibility enhance our system rather

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than penalize them for something that they think is

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that ERCOT thinks is wrong. Happy to uh have the discussion

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with y'all.

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Would you like to lay out your other options? Oh, I'd

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be happy to. (item:33:Commissioner Glotfelty on path forward) Um in my uh so the path forward. I

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propose four bullet points. One have the Commission

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Staff initiate a project in a rulemaking to better

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hash out the state of charge issues. This puts it squarely

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in our court and one that we would consider over the

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next year or two.

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(item:33:Commissioner Glotfelty on real time co-optimization) The challenge with that is 1186 is a interim solution

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because all of this goes away when RTC real time 

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co-optimization gets completed. And this may even be a

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good carrot to get real time co-optimization done sooner

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But we should have that, we could have that discussion.

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(item:33:Commissioner Glotfelty on delaying NPRR1186 & studying economic impact) We could delay approving NPRR1186 until the market

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monitor can evaluate whether adoption of it as written

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now would cause could cause regulatory, forced withholding

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of battery capacity from ERCOT's ancillary service markets

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and discourage some proposed storage projects from

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investing in ERCOT when we absolutely need them. We

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could also ask the IMM to study the economic impact

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on the ERCOT markets of withholding large portions

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of battery capacity from the energy and didn't really

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mean ancillary service markets. But from the energy

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markets.

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(item:33:Commissioner Glotfelty on deleting penalty provisions) Finally, we could consider deleting all the penalty

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provisions of NPRR, NPRR1186 as well as the follow

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on NPRR. 1209 and adopt only the data collection and

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monitoring provisions. These this data would inform

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studies and models on battery operation and capabilities

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So ERCOT can maximize the value of these resources

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to the reliability of our grid and not force them to

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behave like slower, less flexible grid assets. 

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(item:33:Commissioner Glotfelty on understanding how batteries work) Again, I think we should vote it down, but I'm happy

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to have the discussion. We have to learn by,

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we have to understand how batteries work. That's the

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important thing going forward. There are too many of

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them that are in our interconnection queue and we can't

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just put our head in the ground and avoid them and

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say you have to operate this way and we got to learn

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So I think that we should

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deny 1186 and ask the stakeholders in ERCOT to get

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together and figure out a process by which they can

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both learn together.

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May I go next? If I, if you will Chairman. I

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don't know if you have something to say. Um okay. (item:33:Commissioner Cobos on memo) So

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I, I just wanna kind of lay out a backdrop that I

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think is important um to keep in consideration as we

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deliberate and decide what to do with 1186. And that

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is as you know, noted by ERCOT in many presentations

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um from last Summer. Summer '22 to Summer '23, peak load

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has increased by approximately 5000 megawatts about

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a 6.7% increase in load grows from one Summer to the

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next.

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Population economic growth resulting in much higher

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load growth in Texas. Um is, is a reality that we,

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we must address and ERCOT um consistently raises this

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um factor in many of the discussions we have for maintaining

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reliability in the future with many different uh processes

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and market reforms. And, and we got to keep that in

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mind, we have tremendous load growth going on, right

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All right. (item:33:Commissioner Cobos on energy generation statistics) So gas generation the next two years, a

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little bit over 1000 megawatts. That's what we can

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expect based on Interconnection Agreement and um completed

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FIS. Batteries, we have a little bit over 4000 megawatts

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as I understand um in our current system right now

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with about 8000 on the horizon, which could be more

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according to romel stats, we could have, you know,

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14,000 gigs in the next year solar generation uh just

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under 20,000 gigs of solar on our system with about

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24,000 with uh signed IAS and FIS completed. So that's

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potentially 44,000 megawatts of solar in the next two

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years with 100 and 33,000 gigawatts in the queue. Um

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I, I believe from my perspective that we have two, two issues

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to solve here operational issues. One is maintaining

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reliability during high peak demand periods. Traditional

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peak demand and our steeper solar ramp downs that based

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on the statistics I just provided are going to get

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steeper and deeper. And if I said in the past, we'll

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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.