WEBVTT 00:04.160 --> 00:07.766 (item:0:Chairman Gleeson calls meeting to order) This meeting of the Public Utility Commission of Texas will come to order. To consider 00:07.838 --> 00:11.822 matters that have been duly posted with the Secretary of State for August 00:11.886 --> 00:15.390 29, 2024. Good morning, everybody. 00:15.550 --> 00:18.590 It is quite bright up here, Connie, but that's okay. 00:18.710 --> 00:22.510 Except for, except for Courtney who made mention of the fact that my bald head 00:22.550 --> 00:26.182 is blinding her. So if 00:26.206 --> 00:29.758 we want to help her out, I will give my sunglasses. Yeah. 00:29.934 --> 00:40.388 Apologies. So there 00:40.404 --> 00:43.680 we go. Is it a demo? 00:44.660 --> 00:48.292 It's okay. Courtney, Commissioner Hjaltman can 00:48.316 --> 00:51.720 deal with it. Don't worry about it, Connie. 00:53.660 --> 00:56.400 Well, we're off to a rousing start, folks. 00:58.020 --> 01:01.540 Okay. Good morning, Shelah. Good morning. How's everything going? 01:01.620 --> 01:05.012 Great. All right. Will you take us through the consent agenda, 01:05.036 --> 01:08.412 please? I will. And if I may. I'm just going to interject with. I don't usually 01:08.436 --> 01:11.284 do this, but I'm looking around the dais. And just, I know that we're going 01:11.292 --> 01:14.412 to have quite a few items on this agenda. And just remind everybody to move 01:14.436 --> 01:17.548 your microphone close to you so that you can hear. I'm looking at you, 01:17.564 --> 01:21.000 Commissioner Hjaltman. It's quite far away. There you go. So short. 01:21.300 --> 01:25.050 Perfect. You got your nametag, didn't you? I know. 01:25.170 --> 01:27.070 In the underside of six months. 01:29.330 --> 01:30.910 Did it take that long for you? Commissioner Jackson, it took like 6 months. 01:35.130 --> 01:38.522 All right, Chairman. (item:0.1:Commission Counsel Shelah Cisneros lays out Consent Agenda) By individual ballot actually, let me 01:38.546 --> 01:42.778 start off with recusal memos were filed in Project No. 52761. 01:42.914 --> 01:46.650 Chairman Gleeson is recused from Item 6, and Commissioner Hjaltman is recused 01:46.690 --> 01:50.880 from Items 2, 5, 6, and 8. By individual ballot, 01:50.920 --> 01:54.648 the following items are placed on your consent agenda: Items 2, 01:54.744 --> 01:58.056 3, 7, and 9. Additionally, for Rules 01:58.088 --> 02:02.008 and Projects: Items 24, 25, and 26. 02:02.064 --> 02:05.936 Because no one signed up to speak on those items. Thank you, Shelah. (item:0.1:Chairman Gleeson asks for motion to approve items on Consent Agenda) I will 02:05.968 --> 02:10.392 entertain a motion to approve the consent agenda as discussed by Shelah. 02:10.576 --> 02:14.056 So moved. I second. I have a motion and a second. All those in favor 02:14.088 --> 02:17.420 say aye. Aye. Opposed? Motion prevails. 02:18.160 --> 02:21.904 Okay, so I think today, let's go in order, 02:21.952 --> 02:25.896 maybe, with the exception of two things, let's run through the contested 02:25.928 --> 02:29.520 cases, and then we'll go back to the case that 02:29.680 --> 02:33.232 Commissioner Hjaltman and I are recused from, and we'll turn the gavel over to Commissioner 02:33.256 --> 02:37.216 Cobos. And then in talking to Staff, they would like the TEF 02:37.328 --> 02:40.472 discussion to go at the very beginning of the rules and projects piece. So we'll 02:40.496 --> 02:43.806 take Item 19 out of order, if that's okay with everybody? 02:43.958 --> 02:44.930 Okay. Yes. 02:46.270 --> 02:50.150 So with that, I do want to make a couple other announcements. 02:50.230 --> 02:53.998 So we have a couple. Congratulations. So I was told that 02:54.054 --> 02:58.078 Louisa was accepted to the Governor's Executive Development Program. 02:58.174 --> 02:59.530 Congratulations. 03:04.470 --> 03:07.742 You have two people with the honor of getting to sit at this nice table 03:07.846 --> 03:11.054 who are both graduates of that program. So wonderful 03:11.102 --> 03:14.742 role models for all, at least. Connie, I'm not gonna. I don't know about 03:14.766 --> 03:18.158 Barksdale. And I was also told, 03:18.294 --> 03:22.006 where is Werner? There's Werner, who loves for 03:22.038 --> 03:25.870 us to call him out, is gonna be receiving the GCPA 03:25.990 --> 03:27.570 Young Professional Award. 03:31.150 --> 03:37.298 I'm happy, he is so. I 03:37.314 --> 03:39.390 didn't get a lot of eye contact, but I did get a smile. 03:41.090 --> 03:44.114 Congratulations. And that means that he can wear his tennis shoes to the open meeting 03:44.162 --> 03:47.990 for the next year. It's actually required. 03:49.090 --> 03:52.310 I'd say, with what he does for us, he can do whatever he wants. 03:54.810 --> 03:57.042 And there she is. And I told her I was going to do this. 03:57.066 --> 04:00.270 And it is also our friend Peyton Walters dorks birthday today. 04:04.490 --> 04:07.682 Another person that loves to be called out in public. So we won't make her 04:07.706 --> 04:10.130 stand up. I won't ask everyone to sing to her, 04:10.830 --> 04:14.846 but happy birthday, Peyton. I hope Cody 04:14.878 --> 04:16.930 does something very nice for you on your birthday. 04:18.110 --> 04:21.250 It's fair. So, 04:22.270 --> 04:25.934 last thing is, Barksdale would you say that 04:26.062 --> 04:29.702 Summer in Texas runs through September? Is that a fair assessment 04:29.726 --> 04:33.734 of our Summer? Well I can tell you Chairman, that ERCOT 04:33.782 --> 04:36.852 recognizes Summer to run from June through the 04:36.876 --> 04:41.292 end of September. So I think that's probably rooted in policy 04:41.396 --> 04:45.148 and data. Good. A lot of analysis, obviously, you know, 04:45.284 --> 04:48.556 an analytical assessment, which we appreciate, especially at this 04:48.588 --> 04:52.060 open meeting. A lot of analysis. We have Werner to thank for that analysis. 04:52.140 --> 04:56.200 Wonderful. And so, unless Commissioner Glottfelty disagrees, 04:56.780 --> 05:00.478 we'll continue our Summer dress code through the month of September. If you're 05:00.494 --> 05:03.534 okay with that, Jimmy. I don't know. I'll get back to you. Okay, well, 05:03.662 --> 05:07.262 you're always free to put on a tie if the mood strikes you. 05:07.446 --> 05:11.250 I like the way you all think. Okay. And then lastly, 05:11.870 --> 05:15.414 the last open meeting went a little longer than I think we anticipated, and we 05:15.422 --> 05:18.894 didn't take a lunch break. If we get to around 05:18.942 --> 05:22.118 the 11:00 mark, when our court reporter needs 05:22.294 --> 05:25.958 a break, we will break for lunch. If it looks like 05:25.974 --> 05:28.898 we're going to head, you know, well into the afternoon, just to give everybody a 05:28.914 --> 05:31.870 chance to go get some sustenance. So. 05:32.410 --> 05:35.978 Okay, I think that's everything from me. I think Commissioner Hjaltman had 05:36.034 --> 05:40.030 one item to discuss. So hard to look at your head. 05:41.890 --> 05:45.746 I have hired a Chief of Staff/Attorney in my 05:45.778 --> 05:47.830 office, Julie Davis, for everyone. 05:53.190 --> 05:56.462 She has a countdown. Well, not a countdown. She's counting how many days she's already 05:56.486 --> 05:59.894 been here, so it's obviously going well for us. And do 05:59.902 --> 06:02.730 you want me to give everyone your cell phone number? Right. Okay. 06:03.950 --> 06:07.850 Yes. All the details. Most of you already know her bloodstream, 06:09.230 --> 06:12.810 so reach out if you need anything. I'm excited to have her on the team. 06:15.550 --> 06:18.370 And congratulations to you on starting to staff up. 06:19.040 --> 06:21.260 Your staff is probably the happiest for that. 06:23.240 --> 06:26.376 Okay, so now we'll go to the agenda. Shelah, 06:26.448 --> 06:30.096 Item No. 1, public comment. Did anyone sign up for public comment? 06:30.288 --> 06:33.336 (item:1:Shelah Cisneros confirms there are no Public Comments) No, sir. No one signed up for Item No. 1 or any of the remaining 06:33.448 --> 06:37.496 rules and projects on the agenda. Okay, perfect. Thank you. So Items 06:37.528 --> 06:41.380 No. 2 and 3 were consented. So Shelah, will you lay out Item No. 4? 06:41.960 --> 06:45.464 (item:4:Petition of Bobbie Williams to amend City of Royse City’s CCN in Collin County by Streamlined Expedited Release, 56531) Item 4 is Docket No. 56531, 06:45.552 --> 06:49.682 the petition of Bobbie Williams to amend City of Royce City's 06:49.746 --> 06:53.074 certificate of convenience and necessity in Collin county 06:53.242 --> 06:57.074 by Streamlined Expedited Release. Before you as a proposed order. 06:57.202 --> 07:00.802 No corrections or exceptions were filed. A Commission Counsel memo 07:00.826 --> 07:04.314 was filed that recommended changes to the final order, and Chairman Gleeson 07:04.362 --> 07:07.978 filed a memo. Thank you, Shelah. So, as Shelah said, I filed 07:07.994 --> 07:11.670 a memo on this. I think the memo is pretty straightforward. It's dealing with 07:13.020 --> 07:16.476 with a modification of fact 19. Any comments or 07:16.508 --> 07:20.124 questions? I agree with your memo. I'm at 07:20.132 --> 07:23.300 agreement as well. (item:4:Motion to approve proposed order, 56531) Okay, then I will entertain 07:23.340 --> 07:26.996 a motion to approve the proposed order consistent with my memo and Commission 07:27.068 --> 07:31.180 Counsel's memo filed on August 22. So moved. 07:31.300 --> 07:34.316 Second. I have a motion and a second. All those in favor say aye. 07:34.388 --> 07:37.040 Aye. Opposed? Motion prevails. 07:37.740 --> 07:41.044 Shelah, that takes us to Item No. 5. Will you lay out Item 5, 07:41.092 --> 07:45.308 please? (item:5:Application of Lone Star Transmission, LLC to Amend Its CCN and notice of PURA § 14.101 Transaction, 55991) Item 5 is Docket No. 55991, 07:45.444 --> 07:48.828 the application of Lone Star Transmission, LLC to 07:48.844 --> 07:52.204 amend its certificate of convenience and necessity and notice of PURA 07:52.252 --> 07:55.812 14.101 transaction. An order requesting briefing 07:55.836 --> 07:59.900 on certain threshold issues was filed. The parties filed briefs and reply 07:59.940 --> 08:03.492 briefs, and the threshold issues are before you now. 08:03.636 --> 08:06.716 Chairman Gleeson filed a memo in this docket. Thank you, Shelah. 08:06.748 --> 08:10.880 So I filed a memo. It was focused on question one. 08:11.950 --> 08:14.970 So I think we need to have ERCOT review this, 08:15.350 --> 08:18.810 and I think they agree. I think it's the prudent thing to do, 08:19.670 --> 08:23.170 but happy to entertain any discussion or take any questions. 08:23.630 --> 08:27.770 I'm in agreement with your conclusions in the memo on the threshold questions. 08:28.750 --> 08:31.638 I am as well, Mr. Chairman. 08:31.694 --> 08:35.830 I have a few different thoughts that I'd like to speak 08:35.870 --> 08:39.130 and have a discussion on. First, I think 08:39.169 --> 08:42.905 the way that this. The question 08:42.977 --> 08:46.870 of first impression is misguided. (item:5:Commissioner Glotfelty's thoughts on the filed memo, 55991) I think many of the issues here 08:47.690 --> 08:55.270 were decided in the golden spread Docket No. 48212, 08:55.650 --> 08:59.650 and think that we should adhere to 08:59.690 --> 09:03.630 those precedents that were set in that docket. 09:04.780 --> 09:08.720 I think that this 09:09.060 --> 09:12.924 is a unique line. It's got a historical record here of some 09:12.972 --> 09:17.292 challenges with regard to the Krez process and as being 09:17.436 --> 09:21.332 one of the very first, very long gen tie lines 09:21.356 --> 09:23.960 that was created in the state or the only, 09:25.060 --> 09:28.788 but feel that we should give it credence and its 09:28.844 --> 09:32.300 due to understand its value to the 09:32.340 --> 09:36.252 system if it's interconnected and believe that a 09:36.276 --> 09:40.380 long drawn out process would 09:40.420 --> 09:43.600 not be to the benefit of the consumers in that case. 09:44.460 --> 09:48.196 Third, I think that with regard to the rofer 09:48.228 --> 09:51.600 statute, I think that new does not mean existing. 09:51.980 --> 09:55.756 I think that that is specific 09:55.828 --> 09:58.160 enough that the rofer statute would not apply. 09:59.500 --> 10:02.430 I think that if the RPG, 10:03.370 --> 10:06.994 if we decide that the RPG should review it, that we should 10:07.082 --> 10:10.674 try to have some expedited review process because 10:10.762 --> 10:14.434 it is an existing facility. And clearly 10:14.482 --> 10:17.842 we want, if we go this route, we want the RPG and 10:17.866 --> 10:20.978 ERCOT to understand how the interconnection 10:20.994 --> 10:24.906 of that facility in the ERCOT system affects neighbors, 10:24.978 --> 10:28.658 loop flows, other things around the system. But I think that 10:28.674 --> 10:32.492 can be expedited because they're not helping us pick a 10:32.516 --> 10:36.160 route, they're not helping us determine which components of this 10:36.940 --> 10:38.840 are best in terms of. 10:40.140 --> 10:43.800 For the system. Finally, I want to say that 10:44.820 --> 10:48.924 with the. I don't know how much 10:49.092 --> 10:53.180 horse hollow helps with the eye roll in San Antonio and the GTC, 10:53.340 --> 10:56.130 the West Texas GTC, which has historically, 10:56.300 --> 11:00.198 for the last perhaps decade, been the most expensive GTC in 11:00.214 --> 11:04.262 the state. But I think that having a better understanding of 11:04.286 --> 11:07.970 that before we say yes or say no, 11:08.630 --> 11:12.670 would help us make a more informed decision, build the record, get a better 11:12.710 --> 11:16.654 understanding of what our options are. 11:16.822 --> 11:20.326 And finally, I would say that some of the cases are. 11:20.438 --> 11:23.926 Some of the parts of this case that deal with Rofa are contested. 11:23.958 --> 11:27.926 As to, you know, who would get that right to 11:27.958 --> 11:32.030 build, I would like to reserve this 11:32.070 --> 11:35.302 Commission's priority or prerogative to order the 11:35.326 --> 11:38.662 construction built the way that we see fit to most benefit 11:38.686 --> 11:42.318 the consumers of the state. So with that, 11:42.374 --> 11:45.398 I would, you know, be open for discussion. And I think some 11:45.414 --> 11:48.958 of these things that I requested, it could either be staff or ERCOT, or a 11:48.974 --> 11:52.460 combination of both to give us a better 11:52.500 --> 11:55.800 understanding of the issues associated here electrically. 11:56.260 --> 11:59.836 Yeah, and I think that's definitely fine. You know, for this 11:59.868 --> 12:03.772 line being 345 and 200 miles, 12:03.836 --> 12:07.660 you know, I think it's important to get ERCOT's take 12:07.820 --> 12:11.972 on how integrating this into the entire system would 12:11.996 --> 12:16.236 affect the system. And so, you know, for me, I'm happy if there's an expedited 12:16.308 --> 12:19.476 process through RPG, but I do think, for me, at least, 12:19.508 --> 12:21.000 it does need to go there. 12:22.420 --> 12:26.028 So I'm happy if staff would like to talk with 12:26.044 --> 12:30.172 ERCOT or we can have offline talks with ERCOT to see how we 12:30.196 --> 12:33.212 can potentially expedite that. But, yeah, I think, 12:33.236 --> 12:36.356 for me, to your point on ultimately saying yes or 12:36.388 --> 12:40.080 no, I think I need that ERCOT analysis in order to make that determination. 12:42.790 --> 12:46.942 I think those are fair points and would 12:46.966 --> 12:50.238 want to know how quickly ERCOT can look at it as well. If they can 12:50.414 --> 12:53.926 look at it and look at it specific to the issues that Commissioner Glotfelty 12:54.038 --> 12:57.302 raised with respect to the impact to the West Texas GTC and the 12:57.326 --> 13:00.822 IRL, would be really good to know. Okay, so can 13:00.846 --> 13:04.438 we ask ERCOT to come back with that information for 13:04.454 --> 13:07.654 the next meeting and repost 13:07.702 --> 13:09.770 this at the next meeting and have that discussion? 13:12.100 --> 13:15.560 Tell me how you propose or Shelah do you have a. 13:16.100 --> 13:20.068 Yeah, I don't know. Do we just defer a decision today 13:20.124 --> 13:22.316 until we get some of this? I don't even know if we need to defer 13:22.348 --> 13:26.316 a decision. I think if everyone agrees it needs to go to RPG, we can 13:26.428 --> 13:30.240 draft that today. Right. Ultimately, this motion is 13:31.020 --> 13:35.428 direct docket management to draft an order on briefing issues so 13:35.604 --> 13:39.118 we can take this discussion. Right, and have a 13:39.134 --> 13:40.370 discussion with ERCOT. 13:43.310 --> 13:46.438 This is a contested docket, and so having a discussion with 13:46.454 --> 13:50.502 ERCOT. I know that they filed. 13:50.566 --> 13:53.942 They are party to the case that limits your 13:53.966 --> 13:57.782 ability to talk to ERCOT. Can ERCOT file a letter saying, why don't we. 13:57.926 --> 14:00.730 Chad, can ERCOT. Can you all come up? 14:03.560 --> 14:07.352 Yeah. So, I mean, if it's easier to punt today and 14:07.416 --> 14:09.936 kind of deal with this at the next meeting, we can do that. It's. 14:10.048 --> 14:12.696 yeah. (item:5:ERCOT's Sr. VP Chad Seely on RPG process, 55991) Chad Seely with ERCOT. 14:12.808 --> 14:16.016 So, hearing Commissioner Glotfelty, I think it's more 14:16.048 --> 14:19.792 about, do you want us to come back with the scope of what 14:19.936 --> 14:23.456 the expedited process is and then include your 14:23.488 --> 14:26.952 additional comments at the next open meeting so that you have an idea of what 14:26.976 --> 14:30.972 we'd be studying and we can work with Christie's 14:30.996 --> 14:34.560 planning team to figure out how long that would take to do? 14:36.780 --> 14:38.600 I think that the. 14:42.780 --> 14:46.156 I think that's one avenue. I think the other avenue would be 14:46.228 --> 14:50.676 to have 14:50.708 --> 14:51.480 you all. 14:55.540 --> 14:59.116 Well, why don't you tell me what you think the other. What other options could 14:59.148 --> 15:02.418 be? All that does, in my opinion, is kick the can down the 15:02.434 --> 15:05.658 road a little bit. So and what 15:05.674 --> 15:08.946 I'm fearful is, is the RPG process. 15:09.058 --> 15:12.554 I think it's inefficient, and it's not 15:12.722 --> 15:15.930 necessary for this line. It's been exempted. The RPG process 15:16.010 --> 15:19.642 has been exempted from other projects as directed by the legislature, 15:19.826 --> 15:23.530 and they are not going 15:23.570 --> 15:26.638 through all of the steps that the RPG does with regards 15:26.694 --> 15:30.406 to tier one and tier two projects. So how would you all think 15:30.438 --> 15:33.662 you would give us information to help us understand the 15:33.686 --> 15:37.358 value of this in context of 15:37.374 --> 15:41.270 the entire system? So we already provided some of the economic 15:41.430 --> 15:45.038 planning criteria analysis in the docket. And, you know, 15:45.054 --> 15:48.686 our initial assessment is it did not meet the economic planning 15:48.718 --> 15:52.946 criteria. So you've raised some additional comments here that 15:53.018 --> 15:56.434 we would need to go talk to the planning department and 15:56.522 --> 15:59.778 incorporate that into a full study. 15:59.954 --> 16:03.778 And if the commission believes this is a priority, then we will devote 16:03.794 --> 16:07.970 the resources to it and come back with that scope and that timeline. 16:08.130 --> 16:11.898 And obviously, that would accelerate the process 16:11.994 --> 16:15.506 through the normal RPG process. Well, that's what I'm trying 16:15.538 --> 16:19.660 to avoid, is the normal RPG process, because the 16:19.700 --> 16:22.620 normal RPG process will be back here next November. 16:22.780 --> 16:27.080 So if you're wanting any stakeholder comments 16:27.500 --> 16:31.036 through the RPG process, then what I want. Okay, so then, 16:31.148 --> 16:36.228 because it's a contested case, so. May 16:36.244 --> 16:37.200 I jump in? 16:38.580 --> 16:42.204 Procedurally, what may happen is that. Right? We're at 16:42.212 --> 16:46.078 the stage right now where we're answering briefing questions. If the Commission decides 16:46.134 --> 16:49.886 that it needs to go through the ERCOT process, likely the parties 16:49.918 --> 16:53.318 would pause or ask for an abatement while it goes through that process, 16:53.414 --> 16:56.130 and then the parties would file updates in the docket. 16:57.870 --> 17:01.094 I guess what I. Listen, I'm a transmission 17:01.142 --> 17:05.038 developer, so these are square pegs 17:05.054 --> 17:08.877 and round holes of the way the construct of 17:08.894 --> 17:10.730 the law and the rules are written to. 17:13.617 --> 17:16.819 When these are utilities that are getting return 17:16.980 --> 17:19.240 on their investment, 17:20.180 --> 17:22.640 it's not a problem. But when these are private companies, 17:23.819 --> 17:27.276 it's private sector dollars being spent in the midst 17:27.308 --> 17:30.636 of our regulatory process. And that's what gives me pause for 17:30.668 --> 17:33.080 just an extended RPG review. 17:36.630 --> 17:39.918 I guess I would suggest that if we have an extended 17:39.974 --> 17:43.850 RPG review, we should just order it to be built. 17:45.950 --> 17:52.694 But again, I'm not here to necessarily 17:52.742 --> 17:56.462 solve it today. I want to get a path forward today so that we 17:56.486 --> 17:59.398 all can be on the same page as to how we're going to ultimately make 17:59.414 --> 18:03.080 a decision here. Another. I will just throw out this 18:03.120 --> 18:06.728 idea just for your consideration. If we're going 18:06.744 --> 18:09.936 to have a lunch break today, perhaps we table this and bring this 18:09.968 --> 18:13.016 back after lunch. It'll give us a chance to talk to each of the offices 18:13.048 --> 18:17.288 individually, because this is sort of a new information as we're discussing it. 18:17.344 --> 18:20.880 If the commissioners think that if you all would like to talk to staff during 18:20.920 --> 18:24.368 the break and then come back and get a little more information that 18:24.384 --> 18:27.224 way before you decide sort of a path for either what to do today or 18:27.232 --> 18:30.248 a path forward. Go ahead, 18:30.264 --> 18:33.592 Chad. So I'm hearing 18:33.616 --> 18:37.272 two different things from the Commission. One, go through the RPG process. 18:37.376 --> 18:41.152 One, don't go through the RPG process. So if the 18:41.176 --> 18:44.180 Commission wants us to do the study, 18:45.080 --> 18:48.360 then we can do the study and add the additional things 18:48.400 --> 18:51.900 that the Commission wants within that scope and 18:52.240 --> 18:55.632 not go through the official RPG process and bring it 18:55.656 --> 18:58.952 back here and say, here's the study, that it contains the other pieces that the 18:58.976 --> 19:02.286 Commission wanted. So I think 19:02.318 --> 19:05.678 that's more in line for what you're saying. I think it is, yeah. But we 19:05.694 --> 19:09.142 would still need to work with the planning resources to 19:09.206 --> 19:12.646 understand the impact of all the work that they're doing and make 19:12.678 --> 19:15.942 this a priority and take your feedback today and come back 19:15.966 --> 19:19.150 with a scope document to get you all sign off, that it would include these 19:19.190 --> 19:22.410 features along with the timeline to get the study back to the Commission. 19:25.160 --> 19:28.020 That sounds suitable to me. Are there any. So. 19:28.640 --> 19:31.808 And just to understand, RPG is, you know, it's kind 19:31.824 --> 19:35.784 of a long, native process with the transmission developers and everybody, the stakeholders 19:35.832 --> 19:39.800 involved. Right. And you were saying this would be sort of an independent 19:39.920 --> 19:43.100 sort of study process. Correct. 19:43.960 --> 19:47.912 As directed by the Commission to do it through this contested case process. 19:48.096 --> 19:52.250 Is there benefit from getting sort of feedback from 19:52.290 --> 19:56.266 some of the sort of neighboring folks? That's why 19:56.298 --> 19:59.882 we have the RPG process. That'll be an issue for 19:59.986 --> 20:04.122 this contested case, whether other parties are potentially impacted 20:04.146 --> 20:06.310 and not able to weigh in on that. 20:07.890 --> 20:11.786 So I think ultimately, we always coordinate with the utilities through our planning 20:11.818 --> 20:14.550 process. So it's the other kind of stakeholders that, 20:15.370 --> 20:19.148 and I don't even know, the deadline for interventions may have already passed and 20:19.164 --> 20:22.520 whether they would miss out on the opportunity to weigh in on things like that. 20:23.900 --> 20:27.628 Good morning, Kristi. Good morning. (item:5:ERCOT's VP of System Planning/Weatherization Kristi Hobbs on RPG timelines, 55991) Kristi Hobbs with ERCOT. Just wanted to give you 20:27.684 --> 20:30.760 first some perspective on the timelines for the RPG process. 20:31.140 --> 20:34.932 On average takes. The RPG process is about 150 20:34.996 --> 20:38.820 days, and the team is telling me, because of where this is 20:38.940 --> 20:42.836 and the information that's already available, we could probably cut out maybe 30 to 20:42.868 --> 20:46.424 60 days of that process by eliminating the initial comment period. 20:46.612 --> 20:50.032 But we do believe it would be beneficial to have input from the 20:50.056 --> 20:53.060 neighboring tsps. Okay. 20:54.160 --> 20:57.360 I mean, if we can do that and have it back in 90 days. 20:57.400 --> 21:00.824 I think that's great. Okay. And that will 21:00.872 --> 21:04.528 add information to the docketed case 21:04.584 --> 21:08.448 that will help us understand the value of this to ERCOT and 21:08.584 --> 21:11.902 to the citizens of another transmission element being in the. 21:11.976 --> 21:15.466 In the market. So you 21:15.498 --> 21:18.954 want us to bring a filing at the. An update filing at 21:18.962 --> 21:22.538 the next open meeting that includes these other pieces 21:22.594 --> 21:25.930 that you highlighted as part of the scope or just move 21:25.970 --> 21:29.322 forward with the expectation that we'll be able to do this 21:29.346 --> 21:32.590 within 90 days? Yeah, I mean. I mean, 21:33.050 --> 21:35.150 my thought is just move forward. 21:36.530 --> 21:41.850 So, yeah. Unless anyone 21:41.890 --> 21:45.242 has any other thoughts, I'm good with that. 21:45.346 --> 21:49.026 Okay. So, Sheila, do we abate it at this time, or do we just 21:49.058 --> 21:52.714 leave it unresolved at this time? And will it. 21:52.842 --> 21:56.138 Right. I think it may be that the Commission, 21:56.274 --> 22:00.202 however the Commission decides to move forward on the briefing issues, we would just issue 22:00.226 --> 22:04.118 an order on whatever briefing issues you want to decide today, and then the 22:04.134 --> 22:08.230 parties may file and request abatement while that proceeds. 22:08.350 --> 22:11.702 Okay. Okay. Is everybody comfortable with that? 22:11.846 --> 22:14.890 Yeah. Thank you. Okay, thanks, y'all. 22:15.430 --> 22:19.230 Okay. (item:5:Motion to direct docket management to draft an order on briefing issues) Then I would entertain a motion to direct docket management to draft an order 22:19.270 --> 22:23.382 on briefing issues consistent with our discussion and 22:23.406 --> 22:26.370 my memo. So moved. 22:27.110 --> 22:30.166 I second. Have a motion and a second. All those in favor say aye. Aye. 22:30.358 --> 22:32.710 Opposed? Motion prevails. 22:34.930 --> 22:38.110 Thank you, Chad and Kristi. Appreciate y'all's input. 22:39.810 --> 22:43.530 Okay. So Item 6, where I'm recused from. 22:43.570 --> 22:47.050 So that Item 7 was consented. That takes us to Item No. 22:47.130 --> 22:50.050 8. Shelah, will you lay out Item No. 8? 22:50.170 --> 22:54.722 Yes Chairman. (item:8:Application of TNMP for an extension of rate filing requirement under Commission Rule 25.247, 56429) Item No. 8 is Docket No. 56429. 22:54.866 --> 22:58.362 The application of Texas New Mexico Power Company for an 22:58.386 --> 23:02.026 extension of rate filing requirement under Commission 23:02.098 --> 23:05.602 Rule 25.247. Before you is a proposal 23:05.626 --> 23:09.378 for decision. The Office of Public Utility Council filed exceptions to the 23:09.394 --> 23:12.714 PFD. The ALJ filed a memo declining to 23:12.722 --> 23:16.470 make changes to the PFD and Chairman Gleeson filed a memo in this docket. 23:16.930 --> 23:20.730 Thank you, Shelah. So, as I said in my memo, I think. 23:20.810 --> 23:23.890 I think it's appropriate to grant the request. But. 23:23.970 --> 23:27.242 But I think I'm sympathetic to OPUC's 23:27.266 --> 23:30.866 position in this. And next year will have been eight 23:30.938 --> 23:34.242 years since TNMP has been in. I don't think 23:34.266 --> 23:37.626 it's appropriate to put in the order that we want 23:37.658 --> 23:41.930 to make them come in next year, just because, obviously, circumstances can change. 23:42.050 --> 23:45.498 There could always be a reason we don't want them to come in. But I 23:45.514 --> 23:48.962 think, barring anything we don't see now, I'd expect them 23:48.986 --> 23:50.350 to need to come in next year. 23:52.670 --> 23:56.850 I think that's the right path forward. One observation is that 23:57.750 --> 24:00.926 with respect to you won't look favorably at the next. 24:01.038 --> 24:04.150 They ask for another extension. It's been eight years. Right. 24:04.230 --> 24:07.606 And I think if they end up coming in 24:07.638 --> 24:11.654 next year, they have. Will have the benefit of having a historical 24:11.702 --> 24:15.170 test year of 2024, which captures hurricane barrel. 24:15.510 --> 24:19.170 Also, the fact that they have been 24:19.250 --> 24:22.994 able to file DCRFs for 8 years and now 2 24:23.042 --> 24:26.242 per year, and we haven't had a prudency review of that distribution 24:26.306 --> 24:30.402 investment is also a 24:30.426 --> 24:33.538 point I want to make. And so it is important that at some time in 24:33.554 --> 24:37.386 the near future, they do come in so we can review the prudency of 24:37.578 --> 24:40.946 their investments in the distribution network and any 24:40.978 --> 24:44.116 other interim rate relief that they have filed in the last 24:44.148 --> 24:47.320 8 years. Good points. 24:48.540 --> 24:51.092 I'm supportive. I am as well. 24:51.276 --> 24:55.452 Okay. (item:8:Motion to approve the proposed order, 56429) Then I will entertain a motion to approve the proposed order consistent 24:55.476 --> 24:57.360 with my memo in our discussion. So moved. 24:58.180 --> 25:00.892 Second. I have a motion and a second. All those in favor say aye. 25:00.956 --> 25:03.760 Aye. Opposed? Motion prevails. 25:05.140 --> 25:08.636 Item No. 9 was on the consent agenda. So that takes us to 25:08.668 --> 25:12.472 Item No. 10. Sheila, will you lay out Item No. 10, please? (item:10:Application of Entergy Texas for approval of a System Resiliency Plan, 56735) Item 10 is 25:12.496 --> 25:15.592 Docket No. 56735, the application of 25:15.616 --> 25:19.040 Entergy Texas for approval of a System Resiliency 25:19.080 --> 25:22.576 Plan. There's nothing before the Commission right now. This case 25:22.608 --> 25:25.824 is at SOAH, however Commissioner Cobos filed a memo in 25:25.832 --> 25:31.632 this docket. Yes. Thank you, Shelah. (item:10:Commissioner Cobos lays out her memo, 56735) So given 25:31.736 --> 25:34.864 the impacts from Hurricane Beryl to the 25:34.872 --> 25:38.672 Gulf Coast region, and with Entergy serving with 25:38.696 --> 25:42.328 our surface territory being in the Gulf Coast region. I thought it would be prudent 25:42.384 --> 25:46.740 to have the parties address whether 25:47.160 --> 25:50.648 the company's system resiliency plan addresses some 25:50.664 --> 25:54.352 of the issues that the companies experience in the recent hurricanes 25:54.456 --> 25:58.540 like Beryl. Specifically with respect to some of the 25:59.160 --> 26:03.218 areas that we found to be most 26:03.274 --> 26:06.762 impacted by the hurricane, which are the distribution lines and 26:06.786 --> 26:10.970 poles and vegetation management and transmission 26:11.130 --> 26:14.378 lines and facilities, along with, you know, understanding the 26:14.394 --> 26:18.870 win ratings that the company is using for that infrastructure. 26:19.370 --> 26:22.858 So that's. We would 26:22.874 --> 26:26.418 be supplementing the preliminary order in the docket. 26:26.474 --> 26:30.060 That is pretty general to just further ask more 26:30.100 --> 26:33.172 hurricane specific questions at this point. That way, we can 26:33.196 --> 26:37.356 move forward with processing the case and get the information we need so 26:37.388 --> 26:41.332 we can evaluate their plan when it comes before us later 26:41.436 --> 26:44.732 this year. So I think what I 26:44.756 --> 26:48.100 take away from that is you imagine that it's going to address these issues, 26:48.140 --> 26:51.940 but you want it explicitly in there so we ensure that it addresses 26:51.980 --> 26:55.270 these issues. Absolutely. I think that's, you know, it is 26:55.310 --> 26:59.446 prudent for the commission to ensure that given the impacts of Hurricane Beryl and 26:59.638 --> 27:03.102 the public's expectation, the leadership's expectations that 27:03.166 --> 27:07.342 we ensure resiliency and continuous inadequate 27:07.366 --> 27:10.490 service for the customers of these utilities in the Gulf Coast region. 27:12.190 --> 27:15.930 Can we go further and ask all utilities that 27:16.590 --> 27:19.758 are my. No, 27:19.814 --> 27:23.190 I'm smiling. If you're going where I was going to actually suggest something, 27:23.230 --> 27:26.682 probably along the same line. I was just going to say, obviously we've got more 27:26.706 --> 27:30.258 than one Gulf Coast utility. If these, all these questions could be 27:30.274 --> 27:33.842 incorporated into the preliminary orders of 27:33.946 --> 27:37.794 all of the resiliency plans when they come before us. Commissioner, you read my mind. 27:37.962 --> 27:40.994 I didn't get a chance to talk to you all this morning. (item:10:Shelah Cisneros on delegation of authority to OPDM , 56735) But the Commission 27:41.082 --> 27:45.298 previously delegated authority to OPDM to, 27:45.314 --> 27:48.498 approved the preliminary order that we have the standard list of questions so we can 27:48.514 --> 27:51.996 get these to SOAH very quickly. And if the Commission agrees to, 27:52.058 --> 27:55.672 we would just, under the delegation authority, add those issues to the preliminary orders 27:55.696 --> 27:59.248 going forward so that we don't have to do the supplemental preliminary orders. We'll just 27:59.304 --> 28:03.048 incorporate it when we send those to SOA. I'm good with that. Yes, that sounds 28:03.064 --> 28:06.728 like a great plan. And in this particular case, we're not slowing down the 28:06.744 --> 28:10.440 process in any way because entergy obviously has been, and they've 28:10.560 --> 28:13.928 got information out on their website that addresses, you know, 28:13.984 --> 28:18.370 the things that you've brought up here, I think. And this 28:18.410 --> 28:22.242 action will just kind of reinforce, I think, what we think they're already doing. 28:22.306 --> 28:25.706 But we don't anticipate this slowing down the process or anyway. 28:25.778 --> 28:29.178 No, no, it shouldn't. And I think it's important that we get 28:29.194 --> 28:32.990 that information clearly set forth so we can process the plan 28:33.890 --> 28:36.190 at the end of the year. Towards the end of the year. 28:37.450 --> 28:40.746 Okay. (item:10:Motion to direct document management to issue supplemental preliminary order, 56735) Then I would entertain a motion to direct document 28:40.778 --> 28:44.122 management to issue a supplemental preliminary order consistent with, 28:44.146 --> 28:47.802 with Commissioner Cobos memo in our discussion. So moved. 28:47.906 --> 28:50.890 Second. Have a motion and a second. All those in favor say aye. Aye. 28:50.970 --> 28:54.442 Opposed? Motion prevails. Great. And just procedural, 28:54.506 --> 28:57.314 just one procedural thing to bring up, Commissioner Jackson, 28:57.362 --> 29:00.938 along the lines of what you said. We will have an 29:00.954 --> 29:04.218 order drafted very quickly and have that ready for you all to sign today and 29:04.234 --> 29:06.618 get that over so that it can get to so immediately and not slow down 29:06.634 --> 29:08.910 the process. Perfect. 29:09.210 --> 29:12.670 Commissioner Cobos, that will take us back to Item No. 6. 29:13.550 --> 29:16.770 Thank you, Chairman Gleeson. Shelah, can you please lay out this item? 29:17.910 --> 29:21.990 Yes, ma'am. (item:6:Commission Staff’s petition for Declaratory Order regarding opt out of securitization uplift charges by transmission-voltage customers, 56125) Item No. 6 is Docket No. 56125. 29:22.110 --> 29:25.878 This is Commission Staff's petition for declaratory order regarding 29:25.934 --> 29:29.566 opt out of securitization uplift charges by transmission 29:29.638 --> 29:33.102 voltage customers. Before you is the proposed declaratory 29:33.206 --> 29:36.558 order that addresses the request for declaratory relief in this 29:36.574 --> 29:39.700 proceeding. And Commissioner Cobos previously filed a memo. 29:39.830 --> 29:43.200 Yes. (item:6:Commissioner Cobos lays out her memo, 56125) So I continue to recommend that 29:43.320 --> 29:46.340 we approve the declaratory order, 29:47.320 --> 29:51.200 the petitions for in declaratory order proceedings. 29:51.360 --> 29:55.088 We're answering a petition that was filed requesting the declaratory order from 29:55.104 --> 29:58.816 the Commission. And it's really important that we answer 29:58.848 --> 30:02.568 the specific questions because if we get into sort 30:02.584 --> 30:07.120 of a cycle where parties start asking 30:07.200 --> 30:11.464 different, similar, but different questions, we're going to create commission precedent 30:11.512 --> 30:15.680 where in declaratory order proceedings, parties can start asking 30:15.720 --> 30:19.480 other questions and we start answering them, and the other parties in the docket 30:19.520 --> 30:23.672 won't have an opportunity to fully process and understand the impacts of 30:23.856 --> 30:27.360 those similar but related questions, but not exactly the 30:27.400 --> 30:30.880 question being asked. And so I feel like it sets a dangerous 30:30.920 --> 30:34.212 precedent going forward. Forward in declaratory proceedings when we 30:34.236 --> 30:38.052 start sort of meandering off the specific questions that 30:38.076 --> 30:41.548 are the specific question or questions that are asked in the declaratory 30:41.604 --> 30:42.920 order petition. 30:44.740 --> 30:48.440 So I think that I would continue to just limit 30:49.060 --> 30:52.980 our answer to the question in the petition 30:53.100 --> 30:55.440 and take out the language that says that, 30:57.150 --> 31:00.910 that basically the opt out is not able to be 31:01.030 --> 31:04.150 transferred to other entities under the corporate umbrella, 31:04.310 --> 31:07.326 so that we don't make that finding at this time because it's 31:07.358 --> 31:10.798 not part of the petition in this order, I mean, 31:10.814 --> 31:14.850 in this proceeding. So that's where I continue to 31:16.390 --> 31:18.250 stand on this issue. 31:20.710 --> 31:24.508 I kind of feel differently. This case kind 31:24.524 --> 31:27.956 of confused me. But I think where I landed 31:27.988 --> 31:32.040 was that we're kind of deceiving folks that 31:34.260 --> 31:37.700 if they did not get, or if they had 31:37.740 --> 31:42.220 opted out, they weren't going to get an uplift 31:42.260 --> 31:45.924 charge. But if the facility gets. Or if the, 31:46.012 --> 31:49.302 if the facility gets 31:49.326 --> 31:53.918 sold, then they ultimately could 31:53.974 --> 31:57.486 be required to pay some of 31:57.518 --> 32:00.758 these fees. I don't know. I'm not ready to fall on 32:00.774 --> 32:04.238 my sword on it. I just, it seems like we're kind 32:04.254 --> 32:08.198 of going back on what we had said before, and then I think the 32:08.214 --> 32:12.690 tic issue, I mean, selling facilities within a, 32:14.770 --> 32:18.630 within the fence, it just makes logical sense to me. But, 32:20.130 --> 32:24.026 you know, I don't know. I'm just, I understand. I mean, 32:24.058 --> 32:28.066 practically speaking, I hear what you're saying, but as 32:28.098 --> 32:31.810 I sort of look at sort of the legal context of a declaratory 32:31.890 --> 32:35.594 order proceeding and what that means going 32:35.642 --> 32:39.610 forward, if we start answering additional questions that weren't specifically asked, 32:39.650 --> 32:42.770 that sets a dangerous precedent for the commission. In my mind, 32:42.890 --> 32:46.462 and the parties haven't had a, that may not have an opportunity 32:46.486 --> 32:48.450 to address other questions. Also, 32:51.670 --> 32:55.126 if we were to move forward and allow for those opt 32:55.158 --> 32:58.822 outs to be transferred underneath corporate umbrella, 32:58.966 --> 33:02.182 you know, some of these corporations have a lot of subsidiaries and 33:02.206 --> 33:05.830 affiliates. And I'm trying to understand, like, what would be the way for our 33:05.870 --> 33:09.730 staff to sort of track and make sure and confirm 33:10.040 --> 33:13.320 that those entities are still under the corp, are under that 33:13.400 --> 33:17.128 same corporate umbrella. Like, there's still some unanswered information 33:17.224 --> 33:21.000 for me on how it would all work from a staff perspective 33:21.160 --> 33:24.760 in allowing that transfer to happen and how they would confirm, 33:24.920 --> 33:28.888 you know, what, like, what's the process? So I don't know that we're, 33:28.944 --> 33:33.260 we can fully answer all of that right now. And also 33:33.760 --> 33:37.124 that's kind of where practically speaking, I hear what you're saying, but in 33:37.192 --> 33:40.796 practice I have my legal position, but then in practice I'm 33:40.828 --> 33:44.524 like, where, how is this going to work for staff in 33:44.532 --> 33:48.108 the back end? We don't have a methodology or process in place 33:48.284 --> 33:52.120 that can help us confirm the transfers under the umbrella 33:52.940 --> 33:56.120 that's. Could we request a filing? 33:56.900 --> 34:00.452 Well, we're only ordering. I mean, we're only issue out a 34:00.516 --> 34:02.480 declaratory order on the question at this time. 34:05.510 --> 34:06.610 Other views? 34:09.350 --> 34:10.650 It's just us three. 34:12.550 --> 34:16.389 Commissioner Jackson, any thoughts? Well, I see your legal 34:16.429 --> 34:20.661 point that you want to make sure that we stay within the boundaries and 34:20.726 --> 34:24.949 that we only do, I guess, what we're legally obligated 34:24.989 --> 34:25.730 to do. 34:28.040 --> 34:30.219 I think there probably is value in doing that. 34:31.120 --> 34:35.420 Okay. (item:6:Motion to approve proposed declaratory order, 56125) So do I have a motion to approve 34:35.840 --> 34:39.775 the proposed declaratory order consistent with the 34:39.848 --> 34:42.820 changes or direction in my memo? 34:44.760 --> 34:47.460 I move. I so move. Do I have a second? 34:52.840 --> 34:54.739 You said you were not going to die on the sword. 35:00.430 --> 35:04.166 I second. Okay, a reluctant second. 35:04.358 --> 35:07.166 All in favor, say aye. Aye. All right, 35:07.198 --> 35:09.290 motion passes. Thank you all. 35:10.510 --> 35:13.742 Thank you, Commissioner Cobos. So Shelah, I don't 35:13.766 --> 35:18.010 have anything on 11 or 12. So that'll move us into the 35:18.350 --> 35:20.770 electric rules and projects. 35:21.510 --> 35:25.110 So like I said at the outset, we're going to take up Item 19 first. 35:25.230 --> 35:28.942 (item:19:Chairman Gleeson lays out Project No. 56896) So I'd call up Docket No. 56896. 35:29.006 --> 35:33.130 Texas Energy Fund in ERCOT Loan Program Reports and Filings. 35:34.590 --> 35:38.670 So the time has come to see the 35:38.750 --> 35:42.606 portfolio of projects and move forward. 35:42.678 --> 35:45.450 So, David, welcome. Great. Thank you, Chairman Gleeson. 35:46.630 --> 35:50.238 (item:19:Commission Staff's David Gordon lays out memo recommending TEF applications to advance to due diligence, 56896) You'll note that this morning Commission Staff filed a memo recommending 35:50.294 --> 35:54.142 a set of applications to advance to due diligence for the TEF 35:54.206 --> 35:58.734 in ERCOT loan program attachment one shows 35:58.862 --> 36:02.182 those lists of projects and applications we've been in each of your 36:02.206 --> 36:05.886 offices discussing these materials. I know you all have been in them quite 36:05.918 --> 36:09.358 a bit. We are also asking 36:09.414 --> 36:13.526 for a delegation of authority to our executive director to enter into a loan 36:13.558 --> 36:16.968 agreement with applicants who show that there will the after due 36:16.984 --> 36:20.568 diligence review. I should note also that 36:20.704 --> 36:24.472 our recommendation and y'all's vote today to 36:24.496 --> 36:27.568 advance a project of due diligence does not mean that that project will be 36:27.624 --> 36:31.552 awarded a loan. These companies will need to show that 36:31.576 --> 36:35.140 they are worthy of that loan through the due diligence process. 36:37.440 --> 36:40.728 Then finally, attachment two in our memorandum 36:40.784 --> 36:46.600 shows a little bit of a shows information demonstrating 36:47.180 --> 36:50.868 the characteristics of the recommended portfolio set compared to 36:50.884 --> 36:54.636 the full application set. So that's for your review. I'm also 36:54.668 --> 36:58.228 going to turn it over to Tracie Tolle, who will talk a little bit about 36:58.404 --> 37:02.200 the process that we use to get to our set of 37:02.660 --> 37:06.388 recommended projects. Good morning Chairman and 37:06.404 --> 37:10.316 Commissioners. (item:19:Commission Staff's Tracie Tolle on TEF application evaluation methodology, 56896) Tracie Tolle for Staff. I'll give a brief description of the 37:10.348 --> 37:13.780 application evaluation methodology. Staff, together with Deloitte, 37:13.820 --> 37:18.084 our TEF administrator, utilized to comprehensively and comparatively 37:18.132 --> 37:22.044 review the merits of all 72 applications in 37:22.052 --> 37:25.268 the application evaluation. We utilized data from the quantifiable 37:25.324 --> 37:29.420 responses applicants gave to more than 60 application questions 37:29.540 --> 37:33.634 and ranked those into four major categories, being project technical attributes, 37:33.772 --> 37:37.262 application sponsor history, sponsor financials and project 37:37.326 --> 37:40.510 financials. We didn't give any greater priority to anyone 37:40.550 --> 37:44.038 waiting or a single category for application 37:44.094 --> 37:46.846 questions that had non quantifiable responses. 37:47.038 --> 37:50.854 We assessed the responses to determine the impediments and advantages 37:50.942 --> 37:54.062 of each proposed project. Next, for the 37:54.086 --> 37:57.598 two quantifiable policy priorities, which are speed to market and 37:57.614 --> 38:00.886 the ability to address transmission constraints and load growth, we assigned 38:00.918 --> 38:04.236 rankings. After compiling this 38:04.268 --> 38:07.988 data, we went on to perform the iterative work of building the portfolio 38:08.164 --> 38:11.668 by selecting the projects with the top rankings in each of the four major 38:11.724 --> 38:14.964 categories and then elevating projects best achieving 38:15.012 --> 38:17.240 the two quantifiable policy priorities. 38:18.340 --> 38:22.284 We then continued the iterative analysis by applying the three remaining priority 38:22.332 --> 38:26.308 preferences for diversity and resource types, applicant types and locations 38:26.364 --> 38:30.240 throughout ERCOT and adding in those applications with higher rankings 38:30.660 --> 38:33.812 to further achieve the portfolio, diversity staff included no 38:33.836 --> 38:37.600 more than one application per applicant in the recommended portfolio. 38:38.180 --> 38:41.412 This repeatable process led us to the recommended portfolio and 38:41.436 --> 38:43.956 I'm happy to discuss any questions you may have. 38:44.148 --> 38:48.028 Chairman, if I could interject for a moment before you deliberate. 38:48.124 --> 38:51.748 I'd just like to take 1 second to say that this simple 38:51.844 --> 38:55.890 four page memo represents thousands of hours of work and 38:56.590 --> 39:00.158 the first person that I think I want to 39:00.174 --> 39:03.302 thank is Traci because she's been leading from the 39:03.326 --> 39:06.290 front and from the rear from the very beginning of this project. 39:06.750 --> 39:09.942 And irrespective of the decision that you make today on the recommendation, 39:10.006 --> 39:14.358 I think it represents a tremendous amount of work, of diligent 39:14.414 --> 39:17.382 work, not only from Tracy and her team, 39:17.446 --> 39:20.964 but Dave as well, and our partners 39:21.012 --> 39:24.588 at Deloitte, headed by Alfie Zarate, who I think you all got to 39:24.604 --> 39:28.100 meet last week. There's 1520 people 39:28.140 --> 39:31.908 at Deloitte who have been working on this for 39:31.924 --> 39:35.020 the last several months. And so I just want to acknowledge all of their efforts 39:35.100 --> 39:39.228 again, irrespective of the decision you make today, because I think it 39:39.244 --> 39:42.660 might be deceiving how simple this memo is, how much work went into it. 39:42.820 --> 39:46.720 Absolutely. Thank you for that. Barksdale, you're right. 39:47.180 --> 39:50.396 This, you know, when we were discussing this in 39:50.428 --> 39:52.876 May of last year, during the end of the session, 39:53.068 --> 39:56.572 these deadlines were, I think 39:56.636 --> 39:59.560 at one point to one of the Chairman, I described them as wild. 39:59.900 --> 40:03.492 And you all have met them and 40:03.556 --> 40:07.604 we're going to meet the ones that still remain. And that's a testament to the 40:07.772 --> 40:11.516 amount of work that you all can handle. That may not bode well for 40:11.548 --> 40:14.896 us in the future if we. We tell the legislature we can't meet their very 40:14.928 --> 40:17.340 aggressive deadlines, but we'll deal with that in the future. 40:18.200 --> 40:21.592 Amazing work. Thank you for all of it. You know, I'd be remiss 40:21.696 --> 40:25.408 if we didn't thank everyone on staff who had a 40:25.424 --> 40:28.824 hand in this. Barksdale, thank you to you and Connie 40:28.872 --> 40:31.700 for your leadership on this, on the staff side as well. 40:32.480 --> 40:35.576 You know. Thank you to the Lieutenant Governor and the Speaker. To our 40:35.648 --> 40:39.844 Committees of Jurisdiction, particularly the Chairs of those Committees, Chairman Schwertner 40:39.852 --> 40:43.684 and Chairman Hunter. For getting this through the process last Legislative 40:43.732 --> 40:46.720 session so quickly. And yeah, 40:47.020 --> 40:50.276 I'm happy with the recommendation. I think it's an 40:50.308 --> 40:54.156 amazingly good job of weighing all the issues 40:54.228 --> 40:57.908 that the five Commissioners brought to you throughout this process 40:58.004 --> 41:01.652 for what we were looking for in a portfolio. And I'm 41:01.796 --> 41:05.080 prepared to move forward with the recommendation, but happy to hear 41:05.870 --> 41:07.050 those thoughts. 41:10.670 --> 41:13.998 I want to thank staff, too. I mean, this has been a huge lift. 41:14.174 --> 41:18.150 The entire team, you know, Barksdale and Connie and 41:18.270 --> 41:21.990 the staff, the Deloitte team. This is a true 41:22.030 --> 41:26.182 testament of a successful program that the Commission has 41:26.326 --> 41:30.070 stood up first in first case of first impression. 41:30.110 --> 41:34.410 So thank you all. And I'm satisfied with the direction to where the 41:35.150 --> 41:39.558 analysis points. So I 41:39.574 --> 41:43.206 was particularly, I guess, excited to see the diversity in the 41:43.238 --> 41:46.838 number of projects that are coming forward, both in the size 41:46.894 --> 41:50.830 and the types of resources, because for me, that was important because 41:50.950 --> 41:54.190 we know that we have an aging fleet and that we want 41:54.230 --> 41:57.498 to replace at least some of our combined cycles. 41:57.654 --> 42:01.482 And so using this as a mechanism to do that, I think is very 42:01.546 --> 42:05.362 appropriate. I mean, I'd like to thank all the applicants. 42:05.426 --> 42:09.026 We had 72 folks who were interested and wanted 42:09.058 --> 42:11.394 to, if you will, kind of get in the game, put a lot of thought 42:11.442 --> 42:15.210 into it, and hopefully, you know, we'll approve 42:15.250 --> 42:18.466 these today and there'll be an opportunity for more 42:18.498 --> 42:22.146 to come. So a great step forward. Absolutely. 42:22.178 --> 42:25.938 What we need to ensure reliability 42:25.994 --> 42:30.310 of the grid and a great work effort by staff and everyone who 42:30.610 --> 42:34.710 participated in this. So thank you. (item:19:Commissioner Hjaltman's question on the process of TEF application due diligence, 56896) One quick question. 42:35.170 --> 42:38.690 You went through, and you talked about how once it's approved today, 42:38.850 --> 42:42.154 you'll go back and you'll do further due diligence. And in 42:42.202 --> 42:45.754 that further due diligence, if you find more information, 42:45.882 --> 42:49.698 obviously, because you were only given so little to start with, and that is something 42:49.754 --> 42:52.946 concerning. Is that then a decision of our Executive Director, 42:53.018 --> 42:56.738 Connie, to not go forth with a contract? Do you come back here? 42:56.914 --> 43:00.498 And that's kind of a second part of what happens. 43:00.554 --> 43:04.130 If that happens to a few, will you go back to the drawing board of 43:04.170 --> 43:06.946 who applied or where do you move from there? Thanks. 43:06.978 --> 43:10.578 Commissioner Hjaltman? Yes. What we would be asking for today 43:10.634 --> 43:14.048 is a delegation of authority to the ED to enter into contracts 43:14.154 --> 43:17.604 with these companies if they satisfy the due diligence requirements. 43:17.652 --> 43:21.020 So if there is something that they are not able to 43:21.060 --> 43:24.244 prove relating to their application 43:24.332 --> 43:28.560 and that is material to the Executive Director's discretion, 43:29.100 --> 43:31.920 then that application would not advance. 43:33.020 --> 43:36.916 Okay. And then if enough of that happens, and obviously we 43:36.948 --> 43:40.564 still have funds and or we're not getting close to that marker of 43:40.612 --> 43:44.490 megawatts, do you come back forth with applicants that are 43:44.530 --> 43:47.762 in the pool, or will we deal with that at the time? Sure. 43:47.946 --> 43:50.674 So thank you. As Dave said, 43:50.842 --> 43:54.226 the invitation isn't necessarily a guarantee 43:54.258 --> 43:57.930 of funding those going to due diligence. So no official 43:58.010 --> 44:01.830 action is being taken at this time. For the other 55 applications, 44:02.290 --> 44:05.730 subject to funding availability, timing constraints, 44:05.850 --> 44:09.432 and continued interest, additional applications may 44:09.456 --> 44:13.800 be recommended in the future, but any decision regarding 44:13.880 --> 44:17.520 additional invites to due diligence would need to occur 44:17.680 --> 44:20.912 before March 2025. And I'll just add 44:20.936 --> 44:24.248 that if that is the case, we will bring them to you again in a 44:24.264 --> 44:27.592 subsequent open meeting for consideration. Very good. Thank you all so 44:27.616 --> 44:30.500 much for your work on this. Yeah. 44:31.040 --> 44:34.410 Just to echo everybody, I think you all have done an amazing 44:34.450 --> 44:37.602 job getting something that we had no clue how 44:37.626 --> 44:40.922 to do into a process, a structure, 44:41.026 --> 44:45.114 a methodology, an interface on the web to collect 44:45.162 --> 44:48.870 applications, and a very 44:49.290 --> 44:53.110 structured process on how to evaluate them. And I applaud you all for that. 44:55.450 --> 44:59.386 I think it's. I won't say it's a work in progress, because it looks 44:59.418 --> 45:02.546 pretty darn good to me, but if there are improvements for 45:02.578 --> 45:06.422 the next round, if we have a next round, I'll be happy to see them 45:06.446 --> 45:10.690 as well. But I think you all did a fantastic job. I like 45:11.150 --> 45:14.454 the entirety of the group of projects that are recommended, 45:14.502 --> 45:18.250 and I will totally support them. I will say that one of my 45:19.750 --> 45:22.890 priorities was projects in the Houston load zone. 45:23.870 --> 45:27.734 And while this is not called the Houston Load Zone Energy Fund, 45:27.782 --> 45:31.512 it's called the Texas Energy Fund, I appreciate that one project is 45:31.536 --> 45:35.336 there, and in subsequent rounds, it may be something that 45:35.488 --> 45:38.656 will be valuable or looked at in the future. Finally, 45:38.688 --> 45:42.272 I'd like to say that I think the way that you, the criteria that you 45:42.296 --> 45:46.128 looked at dealing with transmission 45:46.184 --> 45:50.032 congestion was really valuable for everybody 45:50.056 --> 45:53.704 in the power system. You all know, many people 45:53.752 --> 45:57.626 don't, that transmission and generation can substitute each other. 45:57.738 --> 46:01.058 You may not need to build transmission if you can get generation to solve a 46:01.074 --> 46:04.458 constraint. And with ERCOT's review of this, I think that was 46:04.474 --> 46:07.698 a valuable resource for this, for this input. So I thank 46:07.714 --> 46:11.858 you for that. I thank ERCOT for that, and I'm totally ready 46:11.874 --> 46:14.962 to support this. Yeah, and I think that's a great point, working with ERCOT. 46:14.986 --> 46:18.270 Thank you to the ERCOT staff as well, for working with our staff 46:19.090 --> 46:23.044 to look at where locational diversity 46:23.092 --> 46:25.200 would really be helpful to the system. 46:26.300 --> 46:30.084 Sometimes we get really lucky. We're blessed here with a lot of great talent. 46:30.252 --> 46:33.524 But in this circumstance, it's very clear, Tracie, 46:33.692 --> 46:37.564 you coming on board to do this. I think this doesn't 46:37.612 --> 46:41.828 work well, if at all, without you. So our profound 46:41.884 --> 46:45.188 thanks to you for everything you've done in particular on this. 46:45.364 --> 46:48.278 Thank you. Thank you so much. Mr. Chairman? 46:48.374 --> 46:52.134 Will we be getting updates? As you go forth, 46:52.182 --> 46:55.014 and you do go ahead and sign contracts, will you come back to the commission 46:55.062 --> 46:58.530 and provide that information? Yes, I will certainly do that. 46:59.230 --> 47:01.810 (item:19:Executive Director Connie Corona on TEF applications due diligence, 56896) To your point earlier, Commissioner Hjaltman. 47:03.070 --> 47:06.806 The applications that are not proceeding forward in due diligence 47:06.918 --> 47:10.262 at this time remain open. And the 47:10.406 --> 47:14.326 confidentiality, as well as all 47:14.358 --> 47:18.550 of the policies that the Commissioners and 47:18.590 --> 47:22.166 Staff have adopted in not discussing the applications with the 47:22.198 --> 47:24.770 applicants will continue in place. 47:26.190 --> 47:30.170 Thank you for that, Connie. I think the last thing I'll say is, you know, 47:30.870 --> 47:34.262 we got the first 5 billion, we look forward in the next session to 47:34.286 --> 47:38.810 getting the remainder of the next 5 billion to complete all of the programs 47:39.320 --> 47:41.860 in the legislation from last session. So, 47:42.560 --> 47:45.792 Okay. (item:19:Motion to advance set of TEF applications to due diligence review, 56896) With that, I will entertain a motion to advance the set 47:45.816 --> 47:49.096 of applications to due diligence review and delegate authority 47:49.128 --> 47:52.752 to the executive director to approve and enter into a loan agreement with 47:52.776 --> 47:56.808 any applicant that satisfies due diligence to the Executive Director's 47:56.904 --> 48:00.744 satisfaction or deny an application that fails to meet due diligence 48:00.792 --> 48:04.144 requirements. So moved. I second. I have a 48:04.152 --> 48:07.950 motion and a second. All those in favor say aye. Aye. Opposed? The motion 48:07.990 --> 48:10.810 prevails. Thank you very much. 48:13.150 --> 48:16.630 Okay. (item:13:Chairman Gleeson lays out Project No. 55999) So that will now take us back to the beginning 48:16.710 --> 48:20.550 of the rules and projects under the electric subheading to Item 48:20.590 --> 48:24.886 No. 13. That is Docket No. 55999, 48:24.958 --> 48:28.302 reports of the Electric Reliability Council of Texas. And I 48:28.326 --> 48:30.370 believe we have an RMR update. 48:42.400 --> 48:46.392 Thank you, Chairman, Commissioners. (item:13:ERCOT's Chad Seely with CPS/RMR/MRA update, 55999) Chad Seely with ERCOT and Davida Dwyer with ERCOT. 48:46.456 --> 48:49.340 wanted to give the Commission an update of, 48:49.760 --> 48:53.976 obviously, the CPS RMR MRA process 48:54.088 --> 48:57.438 and kind of where we are. Obviously, in our past couple of discussions, 48:57.494 --> 49:01.702 we've been focused on doing a pre RMR inspection 49:01.806 --> 49:05.450 for the Bronig unit three. We talked about this at our board meeting 49:06.070 --> 49:09.798 earlier this week as well. Sorry, last week. Getting the days 49:09.854 --> 49:13.510 confused here. Some developments occurred over 49:13.590 --> 49:17.610 the weekend into the early part of the week as we've been working with CPS 49:17.990 --> 49:21.650 to kind of get the contract framed up on the policy issues. 49:22.240 --> 49:26.104 Considering the cost, on how we would allocate the load ratio 49:26.152 --> 49:29.752 share over those 60 days, we thought it would be more prudent 49:29.816 --> 49:33.192 to change course. And our filing yesterday 49:33.296 --> 49:37.544 indicates the reasons why we want to change course with those policy 49:37.632 --> 49:41.552 considerations to continue to work through with CPS energy and 49:41.576 --> 49:44.808 potentially the Commission as well. I'm going to turn it over to Davita to walk 49:44.864 --> 49:48.608 through more of what's laid out in the filing. But I want to 49:48.624 --> 49:52.344 also say thanks to the Commission, thanks to Commission 49:52.432 --> 49:55.840 staff and to CPS energy for continuing to work with 49:55.880 --> 50:00.168 us. This is a very dynamic, difficult reliability 50:00.304 --> 50:03.560 and cost effectiveness issue for the grid, 50:03.720 --> 50:07.048 and we headed down one path that the Commission was well aware of. 50:07.104 --> 50:11.008 We needed to change course really quickly. We tried to get communications 50:11.104 --> 50:14.868 out to all the Commissioners as quickly as we made that decision. 50:15.024 --> 50:18.820 So I apologize for kind of the pivot here. In the last 48 50:18.860 --> 50:22.116 hours, we tried to talk to every one of the Commissioners on why 50:22.148 --> 50:25.692 we were making those changes, getting communications out to everyone, 50:25.756 --> 50:30.004 talking to CPS legislative members as well, 50:30.172 --> 50:33.940 to make sure everybody knows that we are trying to be very thoughtful in 50:33.980 --> 50:37.700 how we make this decision. This is an extraordinary situation to 50:37.860 --> 50:41.406 do a pre RMR inspection for a unit, a unit 50:41.438 --> 50:45.534 that, obviously, through our reliability analysis, shows that we need all 50:45.582 --> 50:48.854 three of the CPS units, and these units 50:48.942 --> 50:52.910 are situated in a prime area that relieves the 50:52.950 --> 50:56.326 IRL. It's one of the best assets right now in the 50:56.358 --> 51:00.070 system until we see other solutions to help relieve 51:00.110 --> 51:03.502 the overloads of the IRL for the next couple of years. So that's why 51:03.526 --> 51:07.504 it's critically important to be deliberative in these critical policy issues 51:07.552 --> 51:10.392 on how we approach this. I do want to turn it over to Davita, 51:10.416 --> 51:12.960 just kind of walk through what was in the filing yesterday. It was a three 51:13.000 --> 51:16.096 page filing. That kind of lays out the rationale on kind of where we are 51:16.128 --> 51:17.580 now and where we see it going. 51:20.360 --> 51:24.320 Thank you, Chad. (item:13:ERCOT's Sr. Corporate Counsel, Davida Dwyer on filing considerations, 55999) And I'll start by reiterating the thanks 51:24.440 --> 51:27.728 and y'all's indulgence. We know that there's a lot of work involved 51:27.784 --> 51:31.752 when, for example, a good cause exception request is made, and we know that 51:31.776 --> 51:35.576 people were already working on that. And we appreciate you 51:35.648 --> 51:38.820 considering our change in thinking as well. 51:40.000 --> 51:43.936 The filing, as Chad mentioned, lays out some of the considerations for 51:43.968 --> 51:47.216 why we think that now doing the outage after 51:47.288 --> 51:51.152 the winter peak load season makes more sense. As Chad 51:51.216 --> 51:55.480 mentioned, one of the things that ERCOT has been working on 51:55.600 --> 51:59.600 was the appropriate settlement. If the settlement 51:59.680 --> 52:03.410 were to take place during the presumed two 52:03.450 --> 52:07.290 months of the outage, that would be a sizable chunk of change for people 52:07.330 --> 52:09.870 to be paying over a very short period of time. 52:10.570 --> 52:14.090 Furthermore, another consideration that we pointed out was the 52:14.130 --> 52:17.830 risk that if the unit were opened up in the fall and 52:18.130 --> 52:21.714 long term, long lead time repairs, 52:21.762 --> 52:25.122 replacements are needed, then the unit wouldn't be available, 52:25.226 --> 52:28.170 or might not be available for winter peak load load. 52:29.310 --> 52:32.726 If we waited until after winter peak load, we believe we'd 52:32.758 --> 52:37.206 still have plenty of time, barring unforeseen circumstances, 52:37.358 --> 52:41.326 to have the unit inspected and repaired during 52:41.398 --> 52:44.966 another shoulder season for outages and before 52:45.118 --> 52:48.782 the summer peak load season. So again, we still think if you 52:48.806 --> 52:52.590 wait until April 1 to open up the unit, it's too 52:52.630 --> 52:56.760 late. But if we were able to wait until perhaps mid February 52:56.920 --> 53:00.576 or early March, you'd still have several months 53:00.648 --> 53:04.048 before the summer peak. We did note a 53:04.064 --> 53:06.936 downside is that this doesn't provide, you know, 53:07.008 --> 53:09.860 better information to the board in making the decision. 53:10.280 --> 53:14.064 Fortunately, the construct for the RMR process already, 53:14.232 --> 53:17.460 because of the 150 day timeline normally afforded, 53:17.760 --> 53:21.266 has some outs, including the absolute right to cancel 53:21.298 --> 53:25.154 the contract. So there is the ability to say 53:25.202 --> 53:29.074 no and not incur costs for large, 53:29.122 --> 53:32.514 unexpected repairs. And I 53:32.522 --> 53:34.514 think that's a fair summary. Is there anything else you want to point out, 53:34.522 --> 53:38.146 Chad? A couple other things. So in the filing, we laid out kind of these 53:38.178 --> 53:41.634 critical policy issues that are important to the commission, 53:41.722 --> 53:44.850 that are important to the stakeholders. They come with a balance 53:44.890 --> 53:47.858 of reliability and cost effectiveness for consumers. 53:48.034 --> 53:51.746 And even last night we talked to commission staff 53:51.818 --> 53:55.530 about, is there an opportunity to frame this up in a policy 53:55.610 --> 53:59.146 way for the Commission to weigh in within this additional timeframe as well? 53:59.258 --> 54:02.538 That may or may not be possible, depending on y'all's priority work that you're trying 54:02.554 --> 54:06.274 to accomplish by the end of the year as far as a rulemaking 54:06.362 --> 54:09.946 or a contested case. But even if that's not possible, and we're 54:09.978 --> 54:13.644 still working with them on the feasibility of doing that, we would 54:13.692 --> 54:17.452 continue to want to come back and make sure that the commission is aware 54:17.516 --> 54:21.212 of the framework that would be in this contract. If we had 54:21.236 --> 54:24.980 proceeded under the original course, you would have gotten a filing yesterday with 54:25.100 --> 54:28.788 a draft contract that included these critical policy 54:28.884 --> 54:31.920 issues and what the cost to the consumers would have been. 54:32.220 --> 54:35.800 And it is a high cost to do it within a 60 day period. 54:36.420 --> 54:40.180 And so we want to be very thoughtful about other options for cost consideration 54:40.220 --> 54:43.718 for consumers as we work through this difficult issue. We also want 54:43.734 --> 54:47.718 to see, as we extended the timeline for the RFP for 54:47.734 --> 54:51.318 the must run alternatives. Those offers are now due the second 54:51.374 --> 54:54.662 week of October, and I think that's an important data point for 54:54.686 --> 54:58.246 all of us to have to see if the industry has responded with 54:58.278 --> 55:02.254 enough megawatts that will provide relief on this constrained area 55:02.382 --> 55:05.966 in the South Texas area. So the additional time affords 55:05.998 --> 55:09.292 us more deliberative process on these 55:09.316 --> 55:12.700 critical policy issues to see if the industry is going to respond to the must 55:12.740 --> 55:16.476 run alternative and then continue to move forward with, as Davida 55:16.508 --> 55:20.476 indicated, a path where we still think it's appropriate and prudent for 55:20.508 --> 55:24.364 reliability to start to open up the unit in advance of any 55:24.412 --> 55:28.292 April 1 RMR agreement. And I'm 55:28.316 --> 55:31.932 sorry, I should have consulted my notes before wrapping up. We did want to 55:31.956 --> 55:35.650 note that we withdrew our request for a good cause exception. 55:35.770 --> 55:39.506 We believe that this additional timeline affords you all the opportunity to 55:39.538 --> 55:43.370 make these decisions yourselves, if you are so inclined, 55:43.490 --> 55:47.074 and we recognize that you're very busy tackling a lot of issues. 55:47.242 --> 55:50.722 And then also the good cause exception request in 55:50.746 --> 55:54.122 part, was driven by timing considerations that would be 55:54.146 --> 55:57.714 resolved by doing this later, such as the exceedance of the 55:57.802 --> 56:01.088 potential exceedance of the MDR PoC and the timing of when 56:01.104 --> 56:03.460 cps would need to submit their outage request. 56:04.880 --> 56:08.320 Thank you. I think you're right. We definitely don't want this 56:08.360 --> 56:11.300 unit out of service over Winter peak. 56:12.120 --> 56:14.740 The one thing I think I would say just as caution, 56:15.480 --> 56:19.216 mid February, we know can still have some issues around it. 56:19.248 --> 56:22.780 So we need to be flexible on when we were, 56:23.120 --> 56:26.386 what our timeline is obviously working together to 56:26.458 --> 56:30.106 figure out the best timing to potentially take these units out of 56:30.138 --> 56:33.642 service. And yeah, I think you're right. I mean, I look to Connie 56:33.666 --> 56:37.034 and Barksdale, I think the idea of having any rule 56:37.082 --> 56:40.866 around this by the end of the year is probably not a timeline that 56:40.898 --> 56:44.378 we can meet. Is that fair to say? That's very fair to 56:44.394 --> 56:45.350 say. Okay. 56:46.610 --> 56:50.018 Commissioners? (item:13:Commissioner Cobos' question to Chad Seely concerning the MRA process , 55999) I think it's prudent we're going to, 56:50.034 --> 56:53.634 if the Commission wants to move forward with a rule making proceeding 56:53.682 --> 56:57.306 to amend our RMR rule. I think it's really important that we're able to thoughtfully 56:57.338 --> 57:00.434 do that and not do it in a rushed manner by the end of 57:00.442 --> 57:02.990 the year, given everything else we have on our plate. 57:04.570 --> 57:08.106 So when will you know what you got in the 57:08.258 --> 57:11.750 MRA process? The offers are due, 57:12.210 --> 57:15.506 the, I want to say the October 7, October 8 57:15.578 --> 57:18.806 time frame. And so 57:18.838 --> 57:22.246 we have a board meeting a couple days after that and we will 57:22.278 --> 57:25.646 be prepared to talk to the Commission and the board around the 57:25.678 --> 57:28.902 results. You know, from an aggregate standpoint on what 57:28.926 --> 57:32.534 we received. We may not be able to at that point say 57:32.662 --> 57:36.190 if everything was eligible, but we can at least have 57:36.310 --> 57:39.726 the first data point about how many megawatts offered in 57:39.878 --> 57:43.250 subject to going through our kind of due diligence eligibility process. 57:44.780 --> 57:48.052 And I know you had previously stated that it was 57:48.156 --> 57:51.908 not looking, it was looking kind of bleak on the MRA side. Do you 57:52.004 --> 57:55.508 just, generally speaking, is it looking any better? I don't think 57:55.524 --> 57:58.756 we have a real indication of that. I mean, I know, you know, we amended 57:58.828 --> 58:02.076 the RFP based upon the 58:02.108 --> 58:05.516 feedback that we got from stakeholders. We have allowed 58:05.548 --> 58:09.052 even more flexibility around the hours that we're focused 58:09.076 --> 58:12.222 on. So we've narrowed the amount of hours across those seasons, 58:12.396 --> 58:16.226 really to help hopefully on the demand response side and maybe 58:16.258 --> 58:19.434 for battery solutions that can provide that service in a shorter time period 58:19.482 --> 58:23.002 where we expect to see those most likely time periods 58:23.026 --> 58:26.722 with exceedances. So we're hopeful with the amendments that we 58:26.746 --> 58:30.298 put forward and allowing really almost another 58:30.394 --> 58:33.666 month of time for people to go do their due diligence, 58:33.738 --> 58:37.170 talk to their shops about options, that we will see 58:37.250 --> 58:43.872 a higher amount of offers come in October. Courtney, 58:43.896 --> 58:47.456 do you have anything? You can go first. (item:13:Commissoners questions to ERCOT on RMR contracts, 55999) I was just going to 58:47.488 --> 58:50.472 ask, so I'm clear in my mind, 58:50.536 --> 58:54.032 if you all do this RMR contract, is it 58:54.056 --> 58:57.344 just for one year? Is it a one year contract or is it 58:57.352 --> 59:01.224 a multi year contract that you all can get out of? I asked this question 59:01.272 --> 59:04.336 in the context of CPS's announcement yesterday, 59:04.408 --> 59:07.518 that they've secured an additional 350 mw on the 59:07.534 --> 59:10.742 north side of the constraint. And then if there are other things that we don't 59:10.766 --> 59:14.294 know about that are going to happen as a result, is this something that 59:14.462 --> 59:17.810 becomes a one year challenge as opposed to a multi year challenge? 59:18.230 --> 59:21.918 Right now it's a two year challenge and that's what we've 59:22.054 --> 59:25.766 focused on in the RFP. But in 59:25.798 --> 59:29.350 all the contracts, we will have the ability to terminate once we believe the risk 59:29.390 --> 59:32.760 has been mitigated. As far as the exit of strategy. Okay. 59:33.740 --> 59:34.880 It's just a. 59:37.380 --> 59:40.996 It makes it a much more expensive one year solution if in fact 59:41.028 --> 59:43.640 it gets solved the second year. 59:44.020 --> 59:47.948 And we know that it's just a. This is one of those unfortunate things. 59:48.004 --> 59:51.516 But as, as we know, the stability of the grid is 59:51.548 --> 59:54.772 the most important thing for the economic viability of the state. 59:54.836 --> 59:58.126 So that's all I have. I guess I need some 59:58.158 --> 59:59.130 clarification. 01:00:01.510 --> 01:00:05.014 We don't think we can get that timeline met. So are you pushing forward 01:00:05.062 --> 01:00:08.934 with the contract request now? We're going to continue to develop 01:00:09.022 --> 01:00:12.214 these policy issues as part of the contract, 01:00:12.342 --> 01:00:16.086 continue to consult with commission staff on what are our options 01:00:16.158 --> 01:00:18.970 to get as much feedback from the Commission. 01:00:19.750 --> 01:00:22.942 If we can't do a rulemaking by the end of the year that gives that 01:00:22.966 --> 01:00:26.266 kind of certainty, then there's other ways that we'll look 01:00:26.298 --> 01:00:30.178 for trying to get commission input and to be transparent to 01:00:30.194 --> 01:00:34.482 the market that we're setting up this framework with these critical policy issues 01:00:34.546 --> 01:00:38.402 and how those costs will be afforded and 01:00:38.426 --> 01:00:42.386 for stakeholders, obviously great to communicate 01:00:42.418 --> 01:00:45.682 with the staff here, will the stakeholders then be communicating to staff and giving 01:00:45.706 --> 01:00:49.162 you that information that have thoughts on the process as well? I think 01:00:49.186 --> 01:00:52.310 we definitely want to think about the way to, you know, put out 01:00:52.350 --> 01:00:55.838 something and start to engage the stakeholders. We've already been talking to some 01:00:55.854 --> 01:00:59.982 of the stakeholders around taking this unit out as a pre RMR, 01:01:00.046 --> 01:01:03.590 so we've gotten some initial feedback, but I think this additional time will afford 01:01:03.710 --> 01:01:06.726 the ability to talk to those stakeholders as well. Okay. 01:01:06.838 --> 01:01:10.382 Yeah, I know this is kind of the way 01:01:10.406 --> 01:01:13.550 of the future. So I think it's important that we make sure we're 01:01:13.590 --> 01:01:17.082 starting it correctly. We expect more 01:01:17.106 --> 01:01:21.070 retirements to probably be coming. So it's an issue that we're going to have 01:01:21.370 --> 01:01:24.930 definitely before us. So I just want to make sure that we handle 01:01:24.970 --> 01:01:27.842 and get the stakeholder input. These are big policy decisions, 01:01:27.866 --> 01:01:31.698 like you stated, not necessarily ones ERCOT should be making on 01:01:31.714 --> 01:01:35.146 their own. They should be making those here at the dais and 01:01:35.258 --> 01:01:39.370 at the legislature to kind of tell who makes the policy. So agree. 01:01:39.450 --> 01:01:43.216 And to Commissioner Cobos and Chairman 01:01:43.248 --> 01:01:46.704 Gleeson and I had a conversation at the board meeting last week. Around we're going 01:01:46.712 --> 01:01:50.328 to learn a lot through this overall RMR MRA process. 01:01:50.464 --> 01:01:54.392 It will probably be appropriate at some time to open up the RMR 01:01:54.456 --> 01:01:57.704 role anyway and start to work through, you know, 01:01:57.752 --> 01:02:00.976 changes in policy for that. And I think 01:02:01.008 --> 01:02:04.700 that that's going to be important in getting the feedback from this process with CPS. 01:02:05.920 --> 01:02:09.486 But ultimately, I don't want RMR to be the norm. 01:02:09.598 --> 01:02:13.686 Right. I mean, obviously, that's the market that controls that and investment decisions, 01:02:13.718 --> 01:02:17.222 and there's a lot of different factors, but the whole 01:02:17.286 --> 01:02:20.702 goal here is to stay away from RMR. I mean, and we 01:02:20.726 --> 01:02:24.310 have, as we just approved, 9700 mw 01:02:24.350 --> 01:02:27.862 worth of generation to move 01:02:27.886 --> 01:02:31.062 forward in due diligence in the TF. I mean, there's a lot of 01:02:31.086 --> 01:02:34.494 factors in flux, and I, and I think having a 01:02:34.502 --> 01:02:38.800 process in place in a role to do pre Mr. Inspection work and RMR 01:02:39.220 --> 01:02:43.132 for the future is important. But I also think that, 01:02:43.316 --> 01:02:46.920 you know, that's hopefully not the new norm. 01:02:49.140 --> 01:02:52.908 (item:13:Commissioner Jackson's question on an alternative to RMR, 55999) You mentioned getting input from people who had 01:02:53.044 --> 01:02:57.252 submitted requests in the past about changing maybe 01:02:57.276 --> 01:03:00.560 the scope going forward this time in the alternative. 01:03:01.830 --> 01:03:05.214 Do you think there's any room there? Is that an opportunity 01:03:05.382 --> 01:03:08.190 to take another look at that and maybe do that in a little bit different 01:03:08.230 --> 01:03:11.830 way to avoid the RMR? Absolutely. I think once 01:03:11.870 --> 01:03:15.446 we see how the market responds on the submission date 01:03:15.518 --> 01:03:19.062 in October, that'll give us a pretty good indication on 01:03:19.246 --> 01:03:22.902 the current requirements that we have from us for alternatives and whether it's hitting the 01:03:22.926 --> 01:03:26.166 mark to really attract those alternative solutions 01:03:26.278 --> 01:03:30.134 into the market. But would you be able to go in and 01:03:30.302 --> 01:03:33.862 adjust those again and maybe get some more participation, or do you feel 01:03:33.886 --> 01:03:37.326 like you're pretty much where you. We have to follow kind of the request 01:03:37.358 --> 01:03:40.806 for proposal process from a contracting standpoint. So we've 01:03:40.838 --> 01:03:44.230 made our last amended solution to the governing 01:03:44.270 --> 01:03:48.190 documents around that with the timeline, you know, whether we could do 01:03:48.270 --> 01:03:51.622 a subsequent RFP, I haven't really thought about that, but we would need 01:03:51.646 --> 01:03:55.120 to conclude this RFP process first before we could consider 01:03:56.020 --> 01:03:59.720 a second round so as cost goes up on the mister 01:04:00.620 --> 01:04:04.836 must run alternative, maybe the consideration for the alternative 01:04:04.908 --> 01:04:08.404 maybe would be a little bit different pending that outcome. Something we'll have 01:04:08.412 --> 01:04:11.120 to look at as we start to see how the market responds. 01:04:13.500 --> 01:04:16.572 Anything else for ERCOT? Thanks y'all 01:04:16.596 --> 01:04:17.920 for being here. Thank you. 01:04:20.510 --> 01:04:23.910 Okay, I don't have anything on 14. (item:15:Chairman Gleeson lays out Project No. 55837) So that brings us 01:04:23.950 --> 01:04:27.702 to Item No. 15. That is Docket 55837, 01:04:27.766 --> 01:04:30.690 review of value of lost load in the ERCOT market. 01:04:31.350 --> 01:04:35.254 Staff made a filing ERCOT filed, made a 01:04:35.262 --> 01:04:39.006 filing with Brattle. Staff, if you want to come up. 01:04:39.078 --> 01:04:40.850 I also filed a memo in this. 01:04:45.440 --> 01:04:49.104 Morning, Chris. Morning. (item:15:Commission Staff's Chris Brown with VOLL study update, 55837) Good morning Chairman, Commissioners. 01:04:49.152 --> 01:04:54.780 Chris Brown, Staff. Yes, so we filed a memo discussing 01:04:55.560 --> 01:04:58.976 our review of the VOLL study. I just want to highlight a few points from 01:04:59.008 --> 01:05:02.592 this. So we want to thank EROCT, Brattle, planned beyond for the hard work on 01:05:02.616 --> 01:05:06.940 this. They developed this comprehensive survey 01:05:07.360 --> 01:05:10.318 consistent with the Lawrence Berkeley National Lab methodology. 01:05:10.374 --> 01:05:13.770 And as a result, this data is going to be helpful in the ice 01:05:14.270 --> 01:05:16.930 interruption cost estimate calculator two point, 01:05:17.710 --> 01:05:21.382 excuse me, 2.0 effort, and staff intends to stay engaged in that 01:05:21.406 --> 01:05:25.270 process. So we reviewed 01:05:25.430 --> 01:05:27.770 the methodology and survey effort. 01:05:28.510 --> 01:05:31.890 Happy to discuss any of those details, but I think the 01:05:32.310 --> 01:05:36.072 key points here are the results. And before jumping into 01:05:36.096 --> 01:05:40.300 the final number, I did want to highlight one other interesting result that Brattle found, 01:05:40.640 --> 01:05:43.888 the impact of advanced warning on the VOLL estimates. So this was 01:05:43.904 --> 01:05:47.328 a significant result. They found that advance warning can lower 01:05:47.464 --> 01:05:50.512 this VOLL value, the costs incurred, 01:05:50.696 --> 01:05:53.856 and we've requested some additional details on the magnitude of this 01:05:53.888 --> 01:05:57.328 impact, and we're happy to follow up with that. But we think that is a 01:05:57.504 --> 01:06:00.540 potentially interesting finding for future policy analysis. 01:06:02.570 --> 01:06:06.770 So using the data collected in the survey effort, they estimated rattle 01:06:06.810 --> 01:06:09.938 estimated VOLL values by customer class, 01:06:09.994 --> 01:06:14.082 and then did a weighted average of this to come to this final determination of 01:06:14.106 --> 01:06:17.850 an ERCOT-wide volume value of around $35,000 per megawatt 01:06:17.890 --> 01:06:21.642 hour. In staffs memo, we note 01:06:21.666 --> 01:06:24.994 that the small commercial and industrial 01:06:25.042 --> 01:06:28.866 estimate is substantially higher than what we've seen from previous 01:06:28.938 --> 01:06:32.058 studies reviewed by Brattle. And as a result, 01:06:32.114 --> 01:06:35.794 our recommendation is to be somewhat more conservative 01:06:35.842 --> 01:06:39.470 and adopt a $30,000 per megawatt hour VOLL. 01:06:41.530 --> 01:06:44.830 I think those are the. Oh, and then the final thing I'd like to reiterate, 01:06:45.250 --> 01:06:48.874 this VOLL value will be used for the purposes of cost benefit analysis, planning models, 01:06:48.922 --> 01:06:51.510 and won't impact anything currently in the market. 01:06:52.660 --> 01:06:55.268 And so with that, happy to take any questions. Thank you, 01:06:55.284 --> 01:06:58.876 Chris. (item:15:Chairman Gleeson lays out his memo, 55837) Commissioners, you know, as I laid out in my memo. The reason 01:06:58.908 --> 01:07:01.676 I ended up writing a memo on this is because I kind of vacillated back 01:07:01.708 --> 01:07:05.492 on forth. I'm comfortable 01:07:05.636 --> 01:07:09.640 with the analysis Brattle did and the number they came up with. 01:07:10.620 --> 01:07:14.212 I'm really glad we have our data analysis team here 01:07:14.236 --> 01:07:16.160 to be doing these types of checks. 01:07:17.820 --> 01:07:21.860 I will continue to give Commissioner Glotfelty his 01:07:21.900 --> 01:07:25.732 due for being the Commissioner that asked for 01:07:25.756 --> 01:07:29.700 us to put in our last lar, the funds and the ftes 01:07:29.740 --> 01:07:32.892 to have a data analysis team. I think it continues to prove 01:07:32.916 --> 01:07:36.916 very valuable. So thank you for the analysis you did, as well. 01:07:37.108 --> 01:07:40.836 With that being said, we asked ERCOT to 01:07:40.868 --> 01:07:44.442 go out and do this. I'm comfortable with their results. 01:07:44.626 --> 01:07:48.786 I did talk to ERCOT before this. I think it's probably appropriate. We don't need 01:07:48.898 --> 01:07:52.466 the extra numbers in there. I think 35,000 is 01:07:52.618 --> 01:07:56.226 an acceptable volume, but happy to have the discussion 01:07:56.258 --> 01:07:57.550 if you all have any questions. 01:08:00.890 --> 01:08:04.858 I want to thank ERCOT, too, for all their work 01:08:05.034 --> 01:08:08.226 in conducting the literature review, but also the survey. 01:08:08.338 --> 01:08:11.748 That was critically important. We haven't done that, I think, ever. 01:08:11.844 --> 01:08:14.520 We've been wanting to do it at the Commission and it got done. 01:08:15.540 --> 01:08:20.492 (item:15:Commissioner Cobos' thoughts on the VOLL study update, 55837) You know, from my understanding, from staff feedback, 01:08:20.676 --> 01:08:25.439 is that the difference between 35 and 30 is not a huge impact. 01:08:26.260 --> 01:08:29.240 And I think, as a starting point, 01:08:29.620 --> 01:08:33.399 35,000 would be good. As we move forward, 01:08:33.700 --> 01:08:37.260 we can continue to review and adjust if necessary. 01:08:37.600 --> 01:08:41.460 We've got to start somewhere. I really appreciate staff's 01:08:42.520 --> 01:08:46.256 analysis into the report. It is just, I found 01:08:46.287 --> 01:08:49.696 it invaluable that you all dig into so deep into reports 01:08:49.768 --> 01:08:53.095 and filings and your observations and 01:08:53.127 --> 01:08:56.696 recommendations are. Have been just very 01:08:56.808 --> 01:09:00.136 good and robust. And so I want to thank you all for that 01:09:00.167 --> 01:09:03.917 as well. But ultimately, I'm in agreement with the chairman. I think 01:09:03.934 --> 01:09:07.062 we just go with 35 and adjust, if needed, 01:09:07.086 --> 01:09:10.206 in the future and just get going with the planning. And thank you for saying 01:09:10.238 --> 01:09:13.573 that. I apologize. I should have said that to ERCOT staff. 01:09:13.662 --> 01:09:16.845 Thank you for, you know, the communication with my office 01:09:16.957 --> 01:09:20.390 on this as we were going through this has been great. 01:09:20.510 --> 01:09:24.037 And so, you know, Rebecca, everyone that worked on this, thank you for 01:09:24.134 --> 01:09:27.925 keeping me in the loop and our staff and. And working well with my 01:09:27.957 --> 01:09:29.849 office and with the Commission Staff. 01:09:32.109 --> 01:09:35.292 (item:15:Commissioner Hjaltman's question on High & Low VOLL, 55837) I think for the public out there 01:09:35.341 --> 01:09:38.701 that is unaware of what maybe this means, 01:09:38.845 --> 01:09:41.444 or if we have a high volume versus a low volume, if you all could 01:09:41.477 --> 01:09:44.787 speak to that a little. From what we see in the report, 01:09:44.868 --> 01:09:48.701 it's pretty much on par with those around us. But can you 01:09:48.725 --> 01:09:51.635 speak to what it would do if we did something lower, or what we did 01:09:51.756 --> 01:09:54.540 versus higher? Yes. So, 01:09:55.080 --> 01:09:59.096 again, the intent of this volume is for planning 01:09:59.128 --> 01:10:02.216 studies, and it's used to assess 01:10:02.288 --> 01:10:06.400 the cost of being able to. Of unserved 01:10:06.440 --> 01:10:09.616 energy. So if there is an outage, we can estimate the amount 01:10:09.648 --> 01:10:12.840 of energy that would go unserved. And this is an economic 01:10:12.960 --> 01:10:18.020 proxy for the costs and I. 01:10:19.870 --> 01:10:23.086 The costs associated with that outage. And so it allows us to 01:10:23.198 --> 01:10:26.718 conduct cost benefit studies to see where we 01:10:26.734 --> 01:10:29.490 can improve things to avoid those kinds of costs. 01:10:30.670 --> 01:10:33.862 I'm in agreement, Mr. Chairman, with the 35. I think that 01:10:33.886 --> 01:10:37.534 is a number based off the research and what we got from consumers 01:10:37.582 --> 01:10:40.766 and those that use this, 01:10:40.878 --> 01:10:42.450 that is an adequate number. 01:10:44.600 --> 01:10:47.660 (item:15:Commissioner's thoughts on VOLL study update, 55837) So, as we've kind of discussed in the past, 01:10:48.240 --> 01:10:51.560 there's kind of two pieces, I guess, to this study. And so, 01:10:51.640 --> 01:10:54.392 you know, the first piece was the literature survey. And we had, 01:10:54.496 --> 01:10:58.200 you know, kind of a preliminary VOLL and then we came back on top 01:10:58.240 --> 01:11:02.260 of it with a survey which hadn't been done, you know, in many, many years, 01:11:02.920 --> 01:11:06.232 with the hope and expectation that it would kind of, you know, validate or be 01:11:06.256 --> 01:11:09.562 close to that initial number. And so that's the other 01:11:09.586 --> 01:11:12.402 thing I wanted to kind of point out, is that we, in fact, have kind 01:11:12.426 --> 01:11:15.738 of two checks here. Right? We have almost two surveys that 01:11:15.754 --> 01:11:19.106 were done, a survey with the public, and then the literature, 01:11:19.178 --> 01:11:21.802 technical survey, and the comparison with other areas. 01:11:21.866 --> 01:11:25.266 So I think it's a good work product. I think, 01:11:25.458 --> 01:11:29.410 you know, the approach of taking the 35,000, 01:11:29.490 --> 01:11:32.906 which was the result of what ERCOT is 01:11:32.938 --> 01:11:36.492 recommending, is, is the direction 01:11:36.516 --> 01:11:37.440 we ought to take. 01:11:40.100 --> 01:11:43.324 I'm a Mr. Chairman. I think 01:11:43.492 --> 01:11:47.268 going with your number and the bridal shuttle, I think is fine. I appreciate 01:11:47.324 --> 01:11:50.916 the analytics. Again, I really just 01:11:50.948 --> 01:11:52.960 want to thank myself for pushing the. 01:11:55.380 --> 01:11:58.692 Kidding, kidding, obviously. Listen, 01:11:58.836 --> 01:12:02.142 the analytics team is far exceeding what I ever even thought it would 01:12:02.166 --> 01:12:06.358 do, and this is in year one. So, Chris, thank you to everybody. 01:12:06.454 --> 01:12:10.366 That's part of that. I think as we integrate that into 01:12:10.438 --> 01:12:13.542 lots of our policies, we're going to get better data, we're going to be able 01:12:13.566 --> 01:12:17.334 to check and balance things. And I think that's really, really valuable. 01:12:17.382 --> 01:12:20.558 It doesn't always mean that we're going to go with that, but it's really an 01:12:20.574 --> 01:12:24.038 important piece. So thank you and I'm supportive of 01:12:24.054 --> 01:12:27.552 your memo in the process. Thanks, y'all. ERCOT, you have what you 01:12:27.576 --> 01:12:30.512 need. Okay, thanks, 01:12:30.536 --> 01:12:31.140 y'all. 01:12:34.520 --> 01:12:37.864 Okay. (item:16:Chairman Gleeson lays out Project No. 54584) That will bring us to Item No. 16. 01:12:38.032 --> 01:12:41.872 That's Docket No. 54584, reliability standard for 01:12:41.896 --> 01:12:45.296 the ERCOT market. So, before us today is a proposal 01:12:45.328 --> 01:12:48.648 for adoption for the reliability standard for the ERCOT market. 01:12:48.824 --> 01:12:51.660 Commissioner Cobos filed a memo. 01:12:52.800 --> 01:12:56.440 Would you like staff to kind of lay out. Sure. Their position. 01:12:56.560 --> 01:12:59.140 Okay. David, Werner, good morning. 01:13:01.520 --> 01:13:05.136 Hello, yeah. (item:16:Commission Staff's David Smeltzer on PFA for reliability standard, 54584) Before you is a proposal for adoption on 01:13:05.168 --> 01:13:08.752 the reliability standard. The content of 01:13:08.816 --> 01:13:12.344 commission staff's recommendation largely reflects the 01:13:12.472 --> 01:13:15.540 decision points that we discussed with you at the last open meeting. 01:13:16.160 --> 01:13:19.602 The only material departure from that discussion is 01:13:19.626 --> 01:13:24.282 upon review, based on the time that a good assessment 01:13:24.346 --> 01:13:28.442 and review of possible options should we 01:13:28.506 --> 01:13:31.858 fail to meet the reliability standard, because of how in depth and thorough we would 01:13:31.874 --> 01:13:35.202 want that assessment to be, we have. We're now recommending that that's 01:13:35.226 --> 01:13:38.794 done every three years, as opposed to every two years, which aligns 01:13:38.842 --> 01:13:42.314 with the forward looking nature of staff's recommendation, which is, 01:13:42.402 --> 01:13:46.430 it's a three year, four, and we would do that every three years. So otherwise, 01:13:46.930 --> 01:13:50.450 we've made no significant material changes from last 01:13:50.490 --> 01:13:54.522 open meeting, other than attempt to flesh out the process a little bit more 01:13:54.666 --> 01:13:57.110 on the assessment and review process, 01:13:58.450 --> 01:14:02.058 which also reflects the discussion that we had at the last open meeting. And we're 01:14:02.114 --> 01:14:05.642 happy to answer questions or whatever 01:14:05.666 --> 01:14:07.710 else you guys need from us at this open meeting. 01:14:10.590 --> 01:14:13.966 Commissioner Cobos? First of all, I do want to thank 01:14:13.998 --> 01:14:17.086 you, Dave and Werner and the team that worked on this role. 01:14:17.118 --> 01:14:20.182 (item:16:Commissioner Cobos lays out her memo, 54584) Obviously, it's a very important role and you all have put 01:14:20.206 --> 01:14:23.598 a lot of thought and hard work into the rule. And I appreciate 01:14:23.654 --> 01:14:27.462 the amendments that you all made, from the proposal for publication 01:14:27.526 --> 01:14:31.174 to the proposal for adoption. I think it's important to have a clear 01:14:31.262 --> 01:14:34.662 and robust process for ERCOT's ongoing, 01:14:34.766 --> 01:14:38.446 continuing reliability assessments, especially if they find 01:14:38.478 --> 01:14:42.358 it efficiency. And so I appreciate all the thought process 01:14:42.454 --> 01:14:46.210 that was put into this. I'll walk through 01:14:46.590 --> 01:14:50.970 my proposed changes and I'll leave the one that I think will merit more discussion 01:14:51.350 --> 01:14:54.686 to the end. But if you've had a chance 01:14:54.718 --> 01:14:58.010 to review my memo, a lot of it is mostly clarification. 01:14:59.270 --> 01:15:03.030 On page two, I have. And my changes are in blue. 01:15:03.330 --> 01:15:06.050 Yeah, that's one thing that I was going to ask. Which ones are your changes? 01:15:06.090 --> 01:15:09.550 Blue. Okay. Yes. Thank you for asking. 01:15:10.610 --> 01:15:14.002 And so, a one. 01:15:14.146 --> 01:15:17.370 I'm sorry, a two. On page two, the insertion of 01:15:17.410 --> 01:15:21.138 during an EEA three event, I thought that was important to clarify, 01:15:21.194 --> 01:15:24.946 because if you look at staff's language 01:15:24.978 --> 01:15:29.250 and just see minimum required operating reserves, 01:15:29.370 --> 01:15:32.426 you want to have just a little bit more clarification inside the EA three event 01:15:32.458 --> 01:15:36.042 when we're actually shedding load, which is 1500 megawatts. 01:15:36.066 --> 01:15:40.226 So just a clarification there, I think is important to really 01:15:40.258 --> 01:15:42.670 just kind of pinpoint it to EEA3 event. 01:15:43.690 --> 01:15:47.070 So there's that one. 01:15:47.970 --> 01:15:51.538 The next page on page three, staff's original 01:15:51.594 --> 01:15:54.654 language on subsection one, at the top, 01:15:54.702 --> 01:15:58.094 on frequency, said that the expected loss of 01:15:58.102 --> 01:16:01.926 load events for the ERCOT region must be less than one 01:16:01.958 --> 01:16:05.094 event per ten years, on average, 01:16:05.142 --> 01:16:07.530 0.01 loss of load expectation. 01:16:07.910 --> 01:16:12.010 So less than is even a more conservative metric, 01:16:12.910 --> 01:16:17.038 frequency metric, than the one in ten. So I 01:16:17.054 --> 01:16:20.926 thought it would be helpful to clarify that it's equal to or less than one 01:16:20.958 --> 01:16:24.702 event in ten years, as one in ten is the 01:16:24.766 --> 01:16:28.454 industry standard that I think staff wanted to continue 01:16:28.582 --> 01:16:32.570 to use for the frequency metric. 01:16:34.110 --> 01:16:37.334 Okay, and I'll skip over the 01:16:37.502 --> 01:16:40.598 exceedance tolerance sections for now and go to 01:16:40.614 --> 01:16:45.104 the bottom of subsection three and so on. 01:16:45.112 --> 01:16:49.240 The magnitude section I inserted beginning December 01:16:49.320 --> 01:16:52.960 1, 2024, and for ERCOT's 01:16:53.000 --> 01:16:57.016 annual filings, on the maximum amount of number of megawatts of load 01:16:57.048 --> 01:17:00.552 shed that can be safely and effectively rotated during a loss load event. 01:17:00.736 --> 01:17:03.340 So, as ERCOT has stated, 01:17:03.760 --> 01:17:07.856 their current numbers are based on a 2023 01:17:07.928 --> 01:17:11.162 RFI results or survey results 01:17:11.226 --> 01:17:15.050 from the TSP's. And so, after we approve the proposal 01:17:15.090 --> 01:17:18.722 for adoption, ERCOT is going to survey the 01:17:18.746 --> 01:17:22.674 TSPs again to update their numbers. And so 01:17:22.722 --> 01:17:25.458 that's going to be about a two month process, and then our staff will have 01:17:25.474 --> 01:17:29.298 to review the numbers. So, based on my discussions with ERCOT 01:17:29.354 --> 01:17:32.402 on sort of a timeline that works for them, and would give our staff an 01:17:32.426 --> 01:17:36.316 opportunity to look at the megawatts and the survey results, December 1 01:17:36.388 --> 01:17:40.492 was a date that they felt comfortable with that 01:17:40.516 --> 01:17:43.660 would allow them to do their work and get 01:17:43.700 --> 01:17:46.660 that information over to us. So, I thought it would be helpful to start this 01:17:46.700 --> 01:17:50.372 year to at least get the 2023 numbers. I'm sorry, 01:17:50.436 --> 01:17:53.628 the updated numbers that they'll run from this survey and then going 01:17:53.684 --> 01:17:57.884 forward annually, on December 01:17:57.932 --> 01:18:01.122 1 of each year. So, that's where the month came. 01:18:01.156 --> 01:18:05.010 Came from. And that was from my conversations with ERCOT, 01:18:06.550 --> 01:18:09.822 and I'm assuming that's suitable for staff, too. I know, Connie. I think 01:18:09.846 --> 01:18:13.270 I talked to y'all about it too. Or Dave 01:18:13.310 --> 01:18:16.958 actually, on the timeline for that end. 01:18:17.054 --> 01:18:20.278 Yeah. On that number, ERCOT has to do the work there. So if they 01:18:20.294 --> 01:18:23.366 say they can do it on that timeframe, we believe them. 01:18:23.518 --> 01:18:26.770 Okay. Okay. So, the bottom of page four, 01:18:27.780 --> 01:18:29.200 subsection Big C. 01:18:31.380 --> 01:18:35.000 And this is basically just sort of like the tail end of 01:18:35.620 --> 01:18:38.120 the review of ERCOT's inputs and assumptions. 01:18:38.660 --> 01:18:42.348 And so, as it states, after reviewing filed comments, ERCOT, 01:18:42.364 --> 01:18:46.076 in consultation with commission staff, must file its final recommended modeling 01:18:46.108 --> 01:18:49.988 assumptions for the Commission review. I wanted to give staff 01:18:50.044 --> 01:18:53.792 an opportunity to file a separate recommendation if they 01:18:53.816 --> 01:18:57.632 continue to have concerns or disagreement with any 01:18:57.656 --> 01:19:00.752 of the inputs and assumptions. So that's 01:19:00.776 --> 01:19:04.016 a may. If they have an agreement, obviously they don't 01:19:04.048 --> 01:19:08.504 have to do it. But if there's any kind of still lingering feedback 01:19:08.552 --> 01:19:11.112 they have on any of the input and assumptions, I want them to have the 01:19:11.136 --> 01:19:14.420 opportunity to give us a separate recommendation. 01:19:15.720 --> 01:19:19.818 And then you go to page five 01:19:19.994 --> 01:19:23.378 and I have struck out subsection little 01:19:23.434 --> 01:19:26.190 three under two big a little three. 01:19:28.450 --> 01:19:32.106 So that section has us 01:19:32.138 --> 01:19:35.670 doing a market equilibrium reserve margin analysis. 01:19:36.170 --> 01:19:40.554 And that's concerning to me because that is an economic exercise 01:19:40.602 --> 01:19:44.066 that we've seen in other market design forums. 01:19:44.218 --> 01:19:47.466 And it's essentially kind of like what e three did. They went in and they 01:19:47.498 --> 01:19:51.290 removed like 10,000 mw from the system and then built up the system 01:19:51.450 --> 01:19:55.390 to meet reliability. There's a lot of hypothetical 01:19:56.090 --> 01:19:59.882 assumptions that are made in a market equilibrium reserve margin 01:20:00.026 --> 01:20:04.226 that could show that we're basically 01:20:04.338 --> 01:20:07.738 tremendously deficient based on what inputs and assumptions 01:20:07.794 --> 01:20:08.710 go in there. 01:20:11.960 --> 01:20:15.320 I feel that if we run that analysis, there could 01:20:15.360 --> 01:20:18.872 be a potential to one paint a very grim picture 01:20:18.896 --> 01:20:22.280 that doesn't actually, is not actually the picture that we're trying to plan 01:20:22.320 --> 01:20:25.488 for. Right. So we're trying to plan, we're trying to make sure we're meeting a 01:20:25.504 --> 01:20:30.024 reliability standard based on the best information that 01:20:30.072 --> 01:20:33.584 we have three years out. And that information is going 01:20:33.592 --> 01:20:37.166 to come from ERCOT load forecasts and I generation they're 01:20:37.198 --> 01:20:40.614 seeing being announced and retired. But once we start 01:20:40.662 --> 01:20:44.382 sort of going beyond that and doing economic hypothetical 01:20:44.446 --> 01:20:47.250 analysis like the market equilibrium reserve margin, 01:20:49.270 --> 01:20:52.774 that to me can get kind of tricky. And I 01:20:52.782 --> 01:20:56.430 don't want to be sending signals to the outside world through that 01:20:56.510 --> 01:20:59.650 exercise that somehow we're 01:21:00.390 --> 01:21:04.128 not meeting the reliability standard and relying 01:21:04.184 --> 01:21:07.872 on that analysis to plan based on 01:21:07.896 --> 01:21:12.200 the best available information we have. Not an economic reserve 01:21:12.240 --> 01:21:15.400 margin exercise. So I just feel 01:21:15.440 --> 01:21:18.864 that you need to look at your current system and you need to look three 01:21:18.912 --> 01:21:22.200 years out and we should have enough data to look three years out. I don't 01:21:22.240 --> 01:21:25.392 know that the Miram analysis provides any real value to 01:21:25.416 --> 01:21:28.820 this other than inject an additional fact exercise, 01:21:28.940 --> 01:21:32.524 economic exercise, that could skew 01:21:32.652 --> 01:21:38.836 what we're trying to plan for. So that's why I struggled down 01:21:38.868 --> 01:21:42.124 at the bottom, you see that I struck out the deficiency process that was in 01:21:42.132 --> 01:21:45.940 there and I just moved it over to the sort of area 01:21:46.020 --> 01:21:50.000 that subsection three commission review and determination. 01:21:50.460 --> 01:21:53.896 So I moved it over and bolstered it under 01:21:53.968 --> 01:21:58.300 subsection CI. And so 01:21:58.800 --> 01:22:02.048 as you, as you read through that I kind of add a 01:22:02.064 --> 01:22:05.592 little bit more meat to ERCOT's role if we find 01:22:05.616 --> 01:22:08.688 a deficiency, and that is that, I would like for ERCOT to provide us with 01:22:08.704 --> 01:22:12.280 a summary explanation of the deficiency, and it's supporting analysis so we can understand 01:22:12.360 --> 01:22:16.824 the deficiency that they've identified. And then ERCOT 01:22:16.992 --> 01:22:20.344 would provide us with the menu of proposed recommended market design changes 01:22:20.432 --> 01:22:23.500 that are intended to address the deficiency. 01:22:23.840 --> 01:22:27.592 And then they would be providing 01:22:27.616 --> 01:22:31.320 the Commission with. Also providing the commission the expected system 01:22:31.400 --> 01:22:34.420 costs associated with each of the proposed recommended changes. 01:22:34.800 --> 01:22:38.176 And I use system cost because that's the language that the staff use with 01:22:38.208 --> 01:22:40.952 respect to cost. But what I mean is just the cost, like, what is the 01:22:40.976 --> 01:22:44.904 cost impact? Right. And then 01:22:44.952 --> 01:22:48.580 the IMM section, which was already in there, I just added, you know, 01:22:48.920 --> 01:22:52.504 tying it more to the process that I inserted up in the above 01:22:52.592 --> 01:22:56.616 subsection for the IMM to give us their 01:22:56.648 --> 01:22:59.580 view on ERCOT's proposed market design changes, 01:23:00.200 --> 01:23:03.576 and also on cost. And then the last 01:23:03.608 --> 01:23:06.888 subsection, which was still in, you know, in staff's proposal, but just, 01:23:06.944 --> 01:23:10.096 you know, a little bit more clear on staff's role 01:23:10.208 --> 01:23:12.020 in providing recommendation to the commission, 01:23:13.120 --> 01:23:17.090 considering cost and reliability, on whether any market design 01:23:17.130 --> 01:23:21.194 changes would be needed or any other changes to address 01:23:21.362 --> 01:23:24.762 the deficiency. So it's just, I think, kind of bolstering, 01:23:24.946 --> 01:23:28.442 making it more clear and bolstering it a little 01:23:28.466 --> 01:23:32.910 bit more as to the roles, the critically important roles of ERCOT, 01:23:33.850 --> 01:23:37.578 the IMM and staff. And the stakeholders, of course, will have 01:23:37.594 --> 01:23:41.480 an opportunity, as the paragraph above states, to provide 01:23:41.820 --> 01:23:46.196 comments within the 30 day period on 01:23:46.228 --> 01:23:51.308 the reliability assessment and on the reliability assessment that's deficient, 01:23:51.364 --> 01:23:54.996 that shows a deficiency. (item:16:Commission Staff's questions on Commissioner Cobos' memos, 54584) Commissioner, as part of your layout, 01:23:55.028 --> 01:23:58.980 I think since we discussed this yesterday, there were two questions 01:23:59.020 --> 01:24:02.268 about what your intent might be with those that you may want to 01:24:02.284 --> 01:24:06.002 just address offhand, before the discussion starts with your peers. And the 01:24:06.026 --> 01:24:09.442 first is when you move. I interpreted 01:24:09.466 --> 01:24:13.618 this to be a structural reorganization, where you 01:24:13.634 --> 01:24:17.434 wanted it to flow evenly, so that it was clear that we'd get 01:24:17.442 --> 01:24:21.066 the ERCOT assessment, we'd get comments, IMM would perform their 01:24:21.098 --> 01:24:24.330 analysis, then staff would perform recommendations. But I think because 01:24:24.370 --> 01:24:26.550 of where it is in the draft, 01:24:28.890 --> 01:24:32.330 what I thought the intent was, is that the comment period would come after 01:24:32.490 --> 01:24:36.146 ERCOT provided its recommendations, so that folks would get to comment on 01:24:36.178 --> 01:24:39.818 those recommendations, not, not. Not prior to ERCOT giving the 01:24:39.834 --> 01:24:43.050 recommendations. Is that. Are we understanding this the same? 01:24:43.210 --> 01:24:46.434 Because it now appears lower than it. But that's just a structural change, correct? 01:24:46.522 --> 01:24:49.746 Yeah. Where you had the deficiency analysis process was under 01:24:49.778 --> 01:24:53.506 the assessment components, and it just felt kind of misplaced, like, 01:24:53.538 --> 01:24:56.578 I would rather have just one process. ERCOT, 01:24:56.674 --> 01:25:00.548 you know, submits their reliability assessment. Stakeholders get 01:25:00.564 --> 01:25:04.480 a chance to comment whether it's deficient or not. 01:25:04.980 --> 01:25:08.876 But if it's deficient, then you have clear steps for the commission 01:25:08.948 --> 01:25:12.000 immigration. But the intent is that the stakeholders, 01:25:13.580 --> 01:25:17.308 if ERCOT is giving recommendations, they would give those recommendations at 01:25:17.324 --> 01:25:21.084 the same time as the assessment, so that stakeholders could comment on those recommendations. 01:25:21.212 --> 01:25:24.558 That's the intent, right? Yes. And then the 01:25:24.574 --> 01:25:28.318 other clarification question that I wanted to ask that's come 01:25:28.334 --> 01:25:31.430 up since yesterday is, I think that you lay 01:25:31.470 --> 01:25:34.678 out that you want a menu of options from ERCOT. And I think the 01:25:34.694 --> 01:25:37.630 good insight there is, you know, we would like to know what the different choices 01:25:37.670 --> 01:25:41.238 are, but based on the phrasing, 01:25:41.334 --> 01:25:45.046 did you intend that change to mean that we didn't want ERCOT to 01:25:45.078 --> 01:25:48.330 give, like, a primary first choice recommendation 01:25:48.910 --> 01:25:52.182 or where that is still sort of our goal would be like, give us the 01:25:52.206 --> 01:25:54.810 best answer, but tell us what the other answers are as well. 01:25:55.270 --> 01:25:58.350 I would like options. I mean, if they only have one and there's absolutely nothing 01:25:58.390 --> 01:26:01.934 else, then fine, tell us, tell us, tell us. There's not really any other 01:26:01.982 --> 01:26:05.670 alternatives, but I think it's helpful for the commission to have 01:26:05.710 --> 01:26:08.918 options. We've always look at market design with 01:26:08.934 --> 01:26:12.214 a variety of options and ultimately decide on going down 01:26:12.262 --> 01:26:15.232 one path, so. Or a combination of line path. 01:26:15.336 --> 01:26:18.864 And so I just would like to have the opportunity to 01:26:18.912 --> 01:26:21.260 have options. 01:26:21.920 --> 01:26:24.816 Excellent. Yeah, I knew that there were questions about that, so I wanted you to 01:26:24.928 --> 01:26:28.512 get to expound on what your thoughts were. Yeah. And we're 01:26:28.576 --> 01:26:31.872 running up on eleven, so why don't we. If there are questions 01:26:31.976 --> 01:26:35.432 for Commissioner Cobos or discussion on this, why don't we try to get that done 01:26:35.496 --> 01:26:38.488 and then we'll take our break and then we'll get into the exceedance tolerance, 01:26:38.664 --> 01:26:41.910 if that works for everybody. Chairman? 01:26:42.770 --> 01:26:46.802 Commissioner Cobos, may I ask a clarifying question on your proposed edit 01:26:46.866 --> 01:26:50.002 on page seven? This is in romanette 01:26:50.066 --> 01:26:50.670 three. 01:26:53.450 --> 01:26:57.026 On commission staff's recommendation, you've provided 01:26:57.058 --> 01:27:01.034 a suggestion that we would. That staff would recommend. Provide a recommendation 01:27:01.082 --> 01:27:04.706 on whether any market design change may be necessary, 01:27:04.778 --> 01:27:07.988 whereas staff's language was that 01:27:08.004 --> 01:27:11.484 we'd provide a recommendation on the 01:27:11.532 --> 01:27:15.228 design changes that may be needed. And so I 01:27:15.284 --> 01:27:19.316 just want to understand your intent. Do you propose 01:27:19.388 --> 01:27:23.068 that staff only provide a recommendation back to 01:27:23.084 --> 01:27:27.628 the Commission that a change may be needed and not provide recommendations 01:27:27.724 --> 01:27:31.800 on those changes that have been proposed or other ideas that it might have? 01:27:33.810 --> 01:27:37.602 I want them to be able to provide a recommendation based on ERCOT's 01:27:37.626 --> 01:27:41.186 feedback on what they think of those and whether or not we should 01:27:41.218 --> 01:27:45.362 move forward with any of them. And would 01:27:45.386 --> 01:27:48.586 your change allow staff to provide its own recommendations that are 01:27:48.618 --> 01:27:51.070 outside of anything that ERCOT might be suggesting? 01:27:52.650 --> 01:27:53.750 Let's see here. 01:27:57.860 --> 01:28:01.436 I think it's written flexibly and it says, must provide a recommendation to the Commission 01:28:01.508 --> 01:28:04.876 considering expected system costs and reliability on whether any changes or other 01:28:04.908 --> 01:28:07.724 changes may be necessary to address the deficiency. 01:28:07.772 --> 01:28:10.684 So it could look at ERCOT's or they can come up with their own. 01:28:10.732 --> 01:28:14.520 I didn't tie it to ERCOT's language. Okay. Thanks for that clarification. 01:28:16.420 --> 01:28:19.484 I have a few questions. So, 01:28:19.532 --> 01:28:23.006 in the adding during an energy emergency alert three 01:28:23.078 --> 01:28:26.610 event we have gone 01:28:27.030 --> 01:28:31.118 through, as in September 6 last year, where we kind of skipped 01:28:31.214 --> 01:28:34.070 an EEA step. So what will this. 01:28:34.110 --> 01:28:37.798 Does this say only during an EEA3? What if 01:28:37.814 --> 01:28:41.398 we skipped a step and went to the next? How would you like. 01:28:41.414 --> 01:28:44.422 Are we missing a word? Does it need to include something else if we are 01:28:44.446 --> 01:28:45.970 going to add that language in? 01:28:48.280 --> 01:28:50.952 So I just went by the fact that it's a loss of load event, 01:28:51.016 --> 01:28:54.936 which happens in EEA3, so whether we skip steps or not, the loss 01:28:54.968 --> 01:28:58.432 of load event would be happening in EEA3. Okay. But that's when we're shedding 01:28:58.456 --> 01:29:02.600 load. Okay. Yeah. So we don't think we need to clarify anything 01:29:02.640 --> 01:29:05.300 there? I don't think so. Staff. 01:29:07.560 --> 01:29:10.688 I want to route the commission staff. No, I believe that's correct. 01:29:10.784 --> 01:29:14.970 That should capture what we need here. Okay. And then I. 01:29:15.120 --> 01:29:18.782 I have a question for ERCOT on one item, but in regards to 01:29:18.846 --> 01:29:22.222 what we move, you have 01:29:22.246 --> 01:29:24.370 moved out of the assessment components. 01:29:26.190 --> 01:29:29.710 I understand your thoughts on not needing 01:29:29.750 --> 01:29:33.646 necessarily to have the market equal legal burden reserve margin 01:29:33.758 --> 01:29:37.382 component in there, but also the way the rule 01:29:37.406 --> 01:29:41.670 is written, it is up to the Commission to move forward, forward and 01:29:42.330 --> 01:29:45.386 take all the analysis and act if we want to. 01:29:45.498 --> 01:29:48.618 So I'm not sure if, you know, if we are giving ourselves 01:29:48.714 --> 01:29:52.658 that wiggle room, why we could just go ahead and have all 01:29:52.674 --> 01:29:56.818 the information and hypotheticals that might be out there if 01:29:56.834 --> 01:30:00.510 we believe ourselves able to make those judgment calls, which we are saying we do. 01:30:05.810 --> 01:30:09.152 So staff does not have any problem with that being removed from 01:30:09.176 --> 01:30:12.780 this? We did include that in there initially because we look at the 01:30:13.560 --> 01:30:16.656 current year and three year as more short term views and the resource 01:30:16.688 --> 01:30:20.088 accuracy picture, whereas a market equilibrium would be okay if we make no changes to 01:30:20.104 --> 01:30:23.880 the market design. That would be the long term outcome of where 01:30:23.920 --> 01:30:27.420 we would end up and providing that data point there, we thought might be beneficial, 01:30:28.400 --> 01:30:32.120 based off of what we've seen from berm studies, particularly through the PCM, 01:30:32.200 --> 01:30:35.724 with what e three has provided us, I think it is fair to 01:30:35.732 --> 01:30:38.900 say that it is unrealistic to expect that this Commission would ever allow 01:30:39.020 --> 01:30:41.996 for the system to get to a market equilibrium, 01:30:42.028 --> 01:30:44.720 because that is an extremely unreliable system. 01:30:45.340 --> 01:30:48.932 So we're not opposed to that being removed from these assessment. 01:30:49.036 --> 01:30:52.852 Okay. And then I think the only other item would 01:30:52.876 --> 01:30:56.052 be for ERCOT on something that we 01:30:56.076 --> 01:30:56.760 changed. 01:30:59.750 --> 01:31:02.502 So I think, just to kind of clarify, I think a couple of things that 01:31:02.526 --> 01:31:05.430 you brought up, and I think you mentioned this, 01:31:05.470 --> 01:31:08.454 that we want to make sure that, 01:31:08.542 --> 01:31:12.170 you know, ERCOT is having the opportunity to. 01:31:13.670 --> 01:31:17.422 That the ERCOT's recommendations are 01:31:17.446 --> 01:31:21.278 a part of what stakeholders will be able to provide feedback 01:31:21.334 --> 01:31:25.158 on. And I don't think, you know, as you kind of read it, I think 01:31:25.334 --> 01:31:28.580 it looks as if breaking apart, at least in this 01:31:28.620 --> 01:31:32.572 language, the assessment from the recommendation and the recommendations are 01:31:32.596 --> 01:31:35.720 kind of falling off out later in the process. 01:31:36.060 --> 01:31:39.580 So, you know, if we can go in and, you know, shore this 01:31:39.620 --> 01:31:40.600 up to where, 01:31:43.380 --> 01:31:46.600 and to make sure that the stakeholders have the opportunity to 01:31:47.380 --> 01:31:50.720 give feedback on not just the assessment piece 01:31:51.020 --> 01:31:54.182 as to whether or not you meet the standard or not, but also on any 01:31:54.206 --> 01:31:56.890 kind of recommendations, I think that. 01:31:57.790 --> 01:32:01.198 Yeah, as you mentioned earlier, I think that's 01:32:01.214 --> 01:32:04.790 the intent. Definitely the intent. We want stakeholder feedback on the assessment, 01:32:04.830 --> 01:32:08.530 whether it's showing a deficiency or not, on the inputs and assumptions. 01:32:08.910 --> 01:32:11.450 It could be a little clear. You can insert another, like, 01:32:11.870 --> 01:32:15.550 little, little four in there and state that they can provide feedback 01:32:15.590 --> 01:32:19.288 on the assessment that 01:32:19.304 --> 01:32:22.584 has a deficiency. And there are any recommendations that are made by ERCOT or 01:32:22.592 --> 01:32:23.700 even commission staff. 01:32:25.560 --> 01:32:28.608 I envision stakeholder feedback in that part of the process. Right. 01:32:28.624 --> 01:32:30.808 Yeah, it sounds like we're all on the same page on what we want the 01:32:30.824 --> 01:32:34.176 outcome to be. So I get the sense that we might be making a few 01:32:34.208 --> 01:32:37.400 edits to the preamble and the rule text after this open meeting, 01:32:37.440 --> 01:32:40.808 so we can, staff can look at it and 01:32:40.944 --> 01:32:44.078 propose a tweak for the signature copy, and we'll come and I make sure that 01:32:44.094 --> 01:32:47.530 it aligns with your intent, if that feels like the best outcome. 01:32:48.630 --> 01:32:52.370 And I feel like it also, as you mentioned earlier, needs to be clear that 01:32:53.350 --> 01:32:57.334 we expect a recommendation from ERCOT, not just a 01:32:57.382 --> 01:33:00.366 list or menu of all the various options. 01:33:00.438 --> 01:33:03.518 But my expectation would be, as the system operator, 01:33:03.574 --> 01:33:07.158 we would very much want them to look and decide or 01:33:07.254 --> 01:33:10.606 make a recommendation in terms of whether it's. It's one thing 01:33:10.638 --> 01:33:14.078 they recommend, or whether it's a suite of several things, but as 01:33:14.094 --> 01:33:17.542 a system operator, being able to put together that recommendation and so, 01:33:17.686 --> 01:33:21.534 you know, maybe talk about it in terms of 01:33:21.702 --> 01:33:24.574 a recommendation from ERCOT and the alternatives, 01:33:24.622 --> 01:33:27.942 but I feel like as a system operator, they definitely need 01:33:27.966 --> 01:33:31.142 to come to us and tell us what it is based on what they see, 01:33:31.206 --> 01:33:34.718 their experience, the landscape, what they would recommend. And then, 01:33:34.734 --> 01:33:37.718 of course, as it comes to the commission, then we can look at that along 01:33:37.774 --> 01:33:41.062 with the other alternatives. But I definitely think that they need to, 01:33:41.086 --> 01:33:44.118 if you will, draw that conclusion in a sentence. And I think that's what I 01:33:44.134 --> 01:33:47.726 envisioned. The language is very general. It says a menu of options. And I think 01:33:47.758 --> 01:33:51.302 in providing the options, they would have the ability to 01:33:51.406 --> 01:33:55.886 talk about independent options, combined options 01:33:56.078 --> 01:33:59.446 and their recommendation ultimately, on which one or ones are 01:33:59.478 --> 01:34:02.904 better for moving forward. Yeah, and I think we can handle that the 01:34:02.912 --> 01:34:04.872 same way as the last. I mean, there might just be. Maybe we can just 01:34:04.896 --> 01:34:08.032 put in including a primary recommendation or something, something along those lines 01:34:08.056 --> 01:34:11.824 for clarity. And I can, when we make other edits for the signature 01:34:11.872 --> 01:34:15.260 copy, I'll come and chat with you guys to make sure we're hitting the 01:34:16.080 --> 01:34:18.704 head nail on the head. As long as we all agree in principle, which it 01:34:18.712 --> 01:34:20.780 sounds like we do, that's fine. 01:34:23.520 --> 01:34:27.110 I don't have anything, Courtney. 01:34:28.450 --> 01:34:32.090 I mean, I can ask ERCOT, but I'm making sure that by December 01:34:32.130 --> 01:34:35.258 1 of this year, they would be able to get that done. 01:34:35.354 --> 01:34:36.390 That's my main. 01:34:40.730 --> 01:34:44.586 Sure. (item:16:ERCOT's Kristi Hobbs on RFIs & TSPs, 54584) Kristi Hobbs with ERCOT Staff, just to clarify 01:34:44.778 --> 01:34:47.554 something that was discussed earlier, 01:34:47.682 --> 01:34:51.338 it's not just ERCOT doing the work. So we will send out rfis to 01:34:51.354 --> 01:34:54.980 the TSP's to get their information. I think what we're considering 01:34:55.020 --> 01:34:58.412 is, historically we've done the RFI process before the 01:34:58.436 --> 01:35:02.204 summer and before the winter and we wanted to make sure we get 01:35:02.252 --> 01:35:06.132 updated information. We've already done the summer 2024 RFI, 01:35:06.276 --> 01:35:09.924 but we want to make sure we true that up with them as well 01:35:09.932 --> 01:35:13.012 as get the upcoming winner's information 01:35:13.116 --> 01:35:16.796 as well. So we'll put out an RFI to the TSP's, 01:35:16.828 --> 01:35:20.686 get that information, and then we'll need to coordinate with commission staff staff and 01:35:20.718 --> 01:35:24.518 with the TSPs before that December 1 date to 01:35:24.534 --> 01:35:27.822 be able to come back with a recommendation so that we can 01:35:27.846 --> 01:35:31.046 all agree upon whether it meets the standard of the 01:35:31.078 --> 01:35:35.142 rule of effectively and safely. Because we believe that's a bigger policy 01:35:35.246 --> 01:35:38.726 question. We need input from the TSPs on 01:35:38.758 --> 01:35:42.286 what they can do as well as, you know, commission staff's 01:35:42.318 --> 01:35:46.104 involvement. So not hearing, you know, you can't meet it, 01:35:46.152 --> 01:35:49.464 but is that super tight? I mean, you're. It'll be 01:35:49.472 --> 01:35:51.500 a quick timeline, but I think it's doable. 01:35:53.200 --> 01:35:56.688 Yeah. The data I got was based on my conversations with Kristi and Chad yesterday. 01:35:56.744 --> 01:36:00.216 So I wanted to build flexibility for them to have 01:36:00.248 --> 01:36:03.752 time to survey, collect the data, but then also have staff 01:36:03.816 --> 01:36:07.328 be able to analyze that, the survey results, 01:36:07.424 --> 01:36:08.060 so. 01:36:10.810 --> 01:36:14.874 (item:16:Commission Staff's Barksdale English on calculation of load shed, 54584) Commissioner? I also want to highlight that staff 01:36:15.042 --> 01:36:18.322 in this recommendation also thought about the fact that 01:36:18.346 --> 01:36:22.706 ERCOT might need to develop protocols 01:36:22.738 --> 01:36:26.818 or other kinds of processes by which stakeholders could 01:36:26.914 --> 01:36:30.314 understand exactly the process that they're going to use 01:36:30.402 --> 01:36:34.186 to calculate the amount of load 01:36:34.218 --> 01:36:37.628 that can be shed safely and effectively. And so 01:36:37.764 --> 01:36:41.548 I would imagine that the number that 01:36:41.564 --> 01:36:44.676 we'll get in December this year will 01:36:44.708 --> 01:36:47.932 probably follow the same process that we've been using in the past. I'm not saying 01:36:47.956 --> 01:36:51.724 that there might be a change in the future, but we won't have the time 01:36:51.852 --> 01:36:55.812 to develop that process for the transparency 01:36:55.876 --> 01:36:58.884 for the stakeholders until probably next year. 01:36:59.052 --> 01:37:03.036 So if we see a change, it will be, because I'm not going to 01:37:03.148 --> 01:37:06.348 say that there will be a change or if there is a change, why there 01:37:06.364 --> 01:37:09.524 was a change. I'm just saying that in terms of the process, because a lot 01:37:09.532 --> 01:37:12.956 of folks have been focusing on process and transparency, 01:37:13.148 --> 01:37:16.420 and I don't think we get to execute that part of what 01:37:16.460 --> 01:37:20.796 staff was envisioning through this rulemaking, probably until 2025. 01:37:20.868 --> 01:37:21.560 Okay. 01:37:24.020 --> 01:37:27.840 I had one other question for ERCOT, and this is something 01:37:27.880 --> 01:37:31.696 that I saw in the filing. And so, you know, when we started, I guess 01:37:31.888 --> 01:37:35.608 the process we talked about doing, potentially the 01:37:35.624 --> 01:37:39.296 look see on the whole reliability standard every five years, and we've shortened it 01:37:39.328 --> 01:37:43.060 to three. But from the time that ERCOT, 01:37:43.560 --> 01:37:46.576 you know, is, starts to work on, 01:37:46.728 --> 01:37:50.416 you know, what that assessment and recommendations will be, 01:37:50.448 --> 01:37:54.484 that whole process. I thought I saw in your filing 01:37:54.532 --> 01:37:58.228 that you said it was anywhere from one to two years. 01:37:58.404 --> 01:38:02.092 (item:16:ERCOT's Kristi Hobbs on estimates on timeline for the different processes, 54584) That's correct. So what we've done is we've started to put together, based off of 01:38:02.196 --> 01:38:05.116 the work that it took to get to this point, 01:38:05.268 --> 01:38:08.668 some estimates on the timelines for the different processes and looking what's 01:38:08.684 --> 01:38:12.324 in the rule and knowing where there's different comment periods. So, for example, 01:38:12.452 --> 01:38:15.172 when we come to you with a set of assumptions, there, 01:38:15.356 --> 01:38:18.724 per the rule, there will be a comment period and the commission will weigh in 01:38:18.772 --> 01:38:21.662 on those. And. And so we've looked at that and that's where we think, 01:38:21.766 --> 01:38:25.030 you know, it's really, it's probably closer to a two year time period 01:38:25.190 --> 01:38:27.610 to go through all of the steps. 01:38:27.950 --> 01:38:31.566 And that was, I think, one of the reasons that staff was looking at 01:38:31.758 --> 01:38:35.750 adjusting the time period to every three years, because if we kept it at every 01:38:35.790 --> 01:38:39.046 other year, then we're basically in continuous mode 01:38:39.078 --> 01:38:41.810 of updating the reliability standard and review. 01:38:42.150 --> 01:38:44.462 But on the same token, I mean, if you do it every three years, 01:38:44.486 --> 01:38:48.218 you have to wait for the three years of the data. Right. And then theoretically, 01:38:48.274 --> 01:38:51.482 you've got two years before you would have another recommendation 01:38:51.546 --> 01:38:53.950 for a different reliability standard. 01:38:56.010 --> 01:38:59.642 I'm sorry, I shouldn't have said I had one. It's not a change 01:38:59.706 --> 01:39:03.410 from Commissioner Cobos' memo. So it is a word that's in 01:39:03.530 --> 01:39:06.858 the magnitude section. So I don't know if it's okay to do now or if 01:39:06.874 --> 01:39:09.338 you would like to wait till. Sure, go ahead and do it. I think we 01:39:09.354 --> 01:39:11.430 just focus on the exceedance. 01:39:13.060 --> 01:39:16.796 This was a request from stakeholders, 01:39:16.868 --> 01:39:20.500 and I just want to kind of discuss when we're talking 01:39:20.540 --> 01:39:24.596 about load shed, we had that that can be safely rotated and the word 01:39:24.708 --> 01:39:28.868 and effectively was added. And legally 01:39:28.964 --> 01:39:32.080 adding any extra words that have not been defined 01:39:32.540 --> 01:39:34.920 previously can be problematic. 01:39:36.140 --> 01:39:40.830 I know I talked about this with staff, but from 01:39:41.250 --> 01:39:44.242 can we discuss, you know, the thought process behind that, 01:39:44.306 --> 01:39:47.650 what the benefit and or repercussions 01:39:47.690 --> 01:39:50.898 of adding that word might be? Because I do see it as being something that's 01:39:50.954 --> 01:39:54.170 not defined. And everyone can have a different 01:39:54.210 --> 01:39:57.870 definition of that from a transmission perspective. 01:40:02.090 --> 01:40:05.562 Commissioner, I'm happy to take a first stab at 01:40:05.586 --> 01:40:08.722 addressing your question. I think the reason why effectively 01:40:08.786 --> 01:40:12.730 shows up in our final recommendation here is because there 01:40:12.770 --> 01:40:16.802 may be new technologies that are installed 01:40:16.826 --> 01:40:20.562 on distribution systems that allow for different kinds 01:40:20.586 --> 01:40:23.730 of rotation patterns than what we see today. 01:40:23.850 --> 01:40:27.810 And so allowing the TSPs and ERCOT 01:40:27.850 --> 01:40:32.492 to consider how technology is integrated to 01:40:32.516 --> 01:40:36.300 be able to not only safely rotate that load, 01:40:36.420 --> 01:40:39.640 but do it in a way that's reliable, that we can count on 01:40:40.380 --> 01:40:44.332 and that we know that it will. The load will 01:40:44.476 --> 01:40:47.596 roll on and then roll off and then roll on and then roll off. 01:40:47.628 --> 01:40:52.252 So that the actual rotation is effective in 01:40:52.276 --> 01:40:56.124 terms of maintaining or minimizing 01:40:56.172 --> 01:40:59.938 the number of hours that any individual, individual load is without power during a 01:40:59.954 --> 01:41:03.750 load shed event. I think that's the intention behind the word effectively here. 01:41:05.330 --> 01:41:08.218 And I was texting Barksdale that that's why I was looking at my phone when 01:41:08.234 --> 01:41:11.594 you were trying to talk to me. Apologies about the confusion. Uh huh. 01:41:11.682 --> 01:41:12.510 Prove it, 01:41:14.570 --> 01:41:21.810 Barksdale. Make sure that it says yes. 01:41:21.850 --> 01:41:25.580 Okay. Okay. So let's break here. 01:41:25.660 --> 01:41:28.160 (item:16:Chairman Gleeson recesses open meeting) We'll stand in recess until 11:30. 01:41:33.380 --> 01:41:36.756 Okay. (item:16:Chairman Gleeson resumes open meeting) We will reconvene at 11:32. All right, 01:41:36.788 --> 01:41:40.780 Commissioner Cobos, do you want to go through your memo changes on exceedance 01:41:40.820 --> 01:41:44.988 tolerance? Yes. (item:16:Commissioner Cobos lays out memo changes on exceedance, 54584) So I 01:41:45.004 --> 01:41:48.476 just want to say, I didn't mean to cause our staff, or any stakeholders 01:41:48.508 --> 01:41:52.322 out there anyhow, heartburn with this, really. My goal here was to 01:41:52.346 --> 01:41:55.950 create flexibility. I think staffs, 01:41:57.210 --> 01:42:00.794 staffs for change from the PFP to the 01:42:00.842 --> 01:42:03.442 proposal for adoption, going from, I think, 01:42:03.466 --> 01:42:07.530 0.25% exceedance probability to 1% was a great step 01:42:07.570 --> 01:42:11.050 in the right direction, as we know. There's just 01:42:11.090 --> 01:42:14.844 so much happening in our market in so many moving 01:42:14.892 --> 01:42:16.320 pieces at this time. 01:42:18.380 --> 01:42:21.700 I just thought that 1% is a great starting 01:42:21.740 --> 01:42:25.252 point, and I don't have any other figures in my 01:42:25.276 --> 01:42:28.548 mind as to what would be, you know, what other percentages would be good to 01:42:28.564 --> 01:42:32.396 go to, but I just wanted to make the 1% a 01:42:32.428 --> 01:42:35.556 floor rather than an absolute. So, 01:42:35.588 --> 01:42:39.548 like, if sometime in the future, and I tie this mostly to the magnitude, 01:42:39.644 --> 01:42:43.740 that's really what, where I think the change is 01:42:43.780 --> 01:42:46.320 most helpful. I understand duration. 01:42:48.380 --> 01:42:52.868 ERCOT may have some feedback on that and 01:42:52.884 --> 01:42:56.196 why I say magnitude, obviously, that's the binding constraint. That's the most 01:42:56.268 --> 01:42:59.692 important metric in my mind, that really moves the 01:42:59.716 --> 01:43:03.580 standard around a lot. And that magnitude metric 01:43:03.660 --> 01:43:07.578 is tied to the amount of megawatts that ERCOT 01:43:07.714 --> 01:43:11.018 gets from, is going to get from the tsps on an annual basis. 01:43:11.194 --> 01:43:15.350 And that's going to continue to change in the future. As the 01:43:16.130 --> 01:43:20.190 transmission distribution companies continue to invest in their system, as their load 01:43:20.970 --> 01:43:24.122 changes, the characteristics of their load, maybe you get 01:43:24.146 --> 01:43:27.830 more industrials on your system and you can't. And their 01:43:28.130 --> 01:43:32.200 connect that transmission voltage. And so, like the character large 01:43:32.240 --> 01:43:36.216 loads, the characteristics of the load is going to change and the TDU's 01:43:36.248 --> 01:43:39.840 abilities to safely and effectively rotate 01:43:39.920 --> 01:43:43.512 out their customers is going to 01:43:43.536 --> 01:43:46.424 continue to evolve. So I thought that, 01:43:46.592 --> 01:43:50.020 you know, setting the 1% as a floor and starting there 01:43:50.720 --> 01:43:53.968 would, would create flexibility. So I just really put that in 01:43:53.984 --> 01:43:57.184 there as a discussion point. I don't have any other 01:43:57.232 --> 01:44:00.600 figure in mind, you know, beyond 1%. 01:44:00.680 --> 01:44:04.624 But I wanted to give ERCOT and the commission flexibility 01:44:04.712 --> 01:44:08.128 in the future to. If they found out, 01:44:08.184 --> 01:44:11.272 you know, through their analysis, that maybe it's not 1%, 01:44:11.336 --> 01:44:14.432 maybe it's 1.25 or one and a half, that they 01:44:14.456 --> 01:44:18.344 can continue to move forward without requiring our 01:44:18.392 --> 01:44:21.680 staff to open up 01:44:21.760 --> 01:44:25.460 the role and make changes to the role and have to go through that process. 01:44:25.840 --> 01:44:28.680 And, you know, I did get some feedback from ERCOT. They're like, well, you don't 01:44:28.720 --> 01:44:31.952 have. If you set it as a floor, you can go up to 200%. 01:44:32.136 --> 01:44:35.504 Well, I realistically, I don't think that's going to happen. 01:44:35.552 --> 01:44:39.416 I mean, there's so much analysis that's going to go in and so much 01:44:39.448 --> 01:44:42.860 feedback along the way till we get the reliability assessments that, 01:44:43.800 --> 01:44:47.280 you know, the band of how much exceedance tolerance 01:44:47.360 --> 01:44:51.674 that the Commission wants, ultimately will continue to be largely 01:44:51.722 --> 01:44:55.106 focused on making sure we have a reliable system. 01:44:55.298 --> 01:44:58.746 So that's kind of where I was coming from with 01:44:58.858 --> 01:45:03.498 just trying to provide some flexibility so that we 01:45:03.514 --> 01:45:06.962 just have flexibility in the future. And I'm 01:45:06.986 --> 01:45:10.594 open to your thoughts, and it's, again, this is a discussion point. 01:45:10.722 --> 01:45:14.670 And, you know, ultimately, whatever y'all think is best, 01:45:15.940 --> 01:45:19.680 we can talk about. Werner, do you want to talk real quick 01:45:20.820 --> 01:45:24.308 just about your thoughts on this? And I know you, I think in 01:45:24.324 --> 01:45:27.708 my briefing, you were pretty strong on the 1%. So can you just kind of 01:45:27.724 --> 01:45:31.840 talk through your thoughts on that? Sure thing. (item:16:Commission Staff's Werner Roth on exceedance tolerance, 54584) Werner Roth, Commission Staff. 01:45:34.380 --> 01:45:37.908 so, from commission staff, when ERCOT 01:45:37.924 --> 01:45:41.092 gave us their initial recommendation, they provided us used 01:45:41.116 --> 01:45:45.292 for frequency, duration and magnitude, and did not. There were not any exceedance tolerances 01:45:45.396 --> 01:45:48.840 for that at all. That required. Would have required on the magnitude piece, 01:45:49.140 --> 01:45:53.080 an extremely reliable, and therefore an extremely costly system. 01:45:53.380 --> 01:45:56.756 Recognizing that commission staff did recommend putting in these 01:45:56.788 --> 01:46:00.420 exceedance tolerances, that allowed for some additional, 01:46:00.500 --> 01:46:03.844 pretty much cost savings. Acknowledging that trying to plan a system around avoiding all 01:46:03.852 --> 01:46:06.950 of these events entirely was inferior, feasible, and overly 01:46:06.990 --> 01:46:10.086 costly. So allowing for some frequency of these to occur. 01:46:10.198 --> 01:46:13.730 Originally, a one in 400 for magnitude, a one in 100 on the duration 01:46:14.670 --> 01:46:17.638 that ended up. I don't remember the exact cost figure, but it ended up bringing 01:46:17.654 --> 01:46:21.270 it down from a one in 27 LOLE to a 01:46:21.310 --> 01:46:24.370 one in 1.01 in 11.1 or something like that. 01:46:24.670 --> 01:46:28.170 And there was a significant cost savings associated with that. 01:46:28.630 --> 01:46:32.112 After listening to the commission conversation at the meeting, 01:46:32.136 --> 01:46:35.696 when we wrote the original proposal for publication, there was a hint that, 01:46:35.728 --> 01:46:39.552 okay, we may need to be flexible on that number and consider where 01:46:39.576 --> 01:46:43.120 this should go. And we've read all the comments 01:46:43.240 --> 01:46:46.440 very thoroughly. I think the one that stood out 01:46:46.560 --> 01:46:50.872 to that effect was the IMM's 01:46:50.896 --> 01:46:54.776 comments, disappointed that this magnitude metric would be 01:46:54.808 --> 01:46:58.336 the most susceptible to modeling inputs in assumptions. 01:46:58.408 --> 01:47:01.560 And we acknowledge that their initial recommendation 01:47:01.600 --> 01:47:04.384 was to remove it entirely, but they did provide an alternative. That said, if we 01:47:04.392 --> 01:47:08.620 went up to the 1.0%, that that would be something they could live with. 01:47:09.200 --> 01:47:13.056 That's where that recommendation came in. We believe from a. Just trying to 01:47:13.088 --> 01:47:17.096 establish a policy perspective, having a high magnitude 01:47:17.128 --> 01:47:20.752 event as a one in 100 event, having a high duration event as a one 01:47:20.776 --> 01:47:24.650 in 100 event, those are the policies we can get behind. 01:47:25.430 --> 01:47:28.654 And so that's kind of where we've drawn our line in 01:47:28.662 --> 01:47:31.530 the sand, if you will, for what that threshold should be. 01:47:32.830 --> 01:47:36.294 So Commissioner Cobos, thank you 01:47:36.382 --> 01:47:39.686 for bringing this up. (item:16:Chairman & Commissioners thoughts on memo, 54584) I've thought about this a lot since 01:47:39.878 --> 01:47:43.358 I read your memo. You know, I'm a fan. 01:47:43.454 --> 01:47:46.158 I like optionality. I like flexibility. 01:47:46.334 --> 01:47:50.216 That's a good thing. Certainty is also also a good thing. 01:47:50.288 --> 01:47:53.952 And I think on balance, for me in this discussion, especially our 01:47:53.976 --> 01:47:57.496 first cut at a reliability standard, I think we need a bright line. 01:47:57.688 --> 01:48:01.304 We are not bound by this. The analysis will happen. 01:48:01.392 --> 01:48:06.296 I think I would be more open to this if not 01:48:06.328 --> 01:48:10.104 meeting this required us to take action. But because we have 01:48:10.192 --> 01:48:13.528 the flexibility to, regardless of what this says, 01:48:13.664 --> 01:48:17.500 get comments, get feedback, and then decide later if we want to act or not, 01:48:17.660 --> 01:48:20.884 I'm comfortable. I think 1% for both duration 01:48:20.932 --> 01:48:24.076 and magnitude is the right starting place in this discussion. I agree with 01:48:24.108 --> 01:48:27.280 staff, and that would be my recommendation for moving forward. 01:48:29.780 --> 01:48:34.196 I'm in agreement, Mister chairman. I think that the legislative 01:48:34.228 --> 01:48:38.148 intent of SB three was clear. To set a reliability standard. You know, 01:48:38.164 --> 01:48:41.802 how far that would go was not necessarily put forth. But I do think 01:48:41.826 --> 01:48:44.870 that they expected us to adopt something that would be measurable. 01:48:45.330 --> 01:48:48.562 And without, you know, if we go too much 01:48:48.586 --> 01:48:51.562 further, we're not going to have that ability to measure anything. 01:48:51.666 --> 01:48:55.594 It will be obviously with the exceedance, it will be an open ended equation 01:48:55.642 --> 01:49:00.026 to put forth. So I think the 1% is 01:49:00.058 --> 01:49:03.098 a middle ground. When we started with none, went to 0.25, 01:49:03.274 --> 01:49:06.764 hit one. I think that is a firm line that I would be happy to 01:49:06.772 --> 01:49:10.760 stand behind as well. I'm with you, Mister chairman. I think 01:49:11.300 --> 01:49:15.120 a very specific number is important 01:49:19.940 --> 01:49:25.628 within the context of the fact that we 01:49:25.644 --> 01:49:28.812 need to have the bright line. We got to have the bright line. It's that 01:49:28.836 --> 01:49:33.074 simple. I say that with total 01:49:33.122 --> 01:49:36.290 support for the number and hesitancy for the standard. 01:49:36.330 --> 01:49:39.802 Again, I will say, you know, as ERCOT continues to move 01:49:39.826 --> 01:49:43.510 away from one in ten, this is the first 01:49:44.850 --> 01:49:48.430 region, NERC region that will have a three legged stool for 01:49:48.890 --> 01:49:52.410 frequency, duration, and magnitude. And I think that's really 01:49:52.450 --> 01:49:55.858 important. We're going to lead the way and see how this one 01:49:56.034 --> 01:50:00.100 in ten works with EUE. I think it becomes a more well rounded 01:50:00.140 --> 01:50:06.156 standard, reporting those numbers as well. So I support your 01:50:06.188 --> 01:50:10.172 position. I'm appreciative of Commissioner Cobos' 01:50:10.196 --> 01:50:14.036 thinking about flexibility. But I think, you know, from my perspective, 01:50:14.068 --> 01:50:17.980 in this particular case, the exceedance tolerance is 01:50:18.140 --> 01:50:21.652 actually an integral part of the reliability standard. I think in 01:50:21.676 --> 01:50:25.170 some ways it's the strength of the standardization, particularly for 01:50:25.510 --> 01:50:29.278 having it in both the duration and the magnitude. 01:50:29.334 --> 01:50:33.198 And again, appreciate your thoughtfulness 01:50:33.294 --> 01:50:36.598 in wanting to have something that is maybe more evergreen kind 01:50:36.614 --> 01:50:40.142 of moving forward. But I think in this particular case, again, because we 01:50:40.166 --> 01:50:43.446 are sending a message, this is our first stab, if, 01:50:43.558 --> 01:50:47.574 you know, the 1% as we move forward, again, it doesn't necessarily 01:50:47.622 --> 01:50:51.656 require us after the assessment to do 01:50:51.688 --> 01:50:55.740 anything other than actually evaluate it and make a thoughtful and deliberate decision. 01:50:56.200 --> 01:50:59.504 And so I would favor leaving in the 1% 01:50:59.592 --> 01:51:02.620 on both the duration and the magnitude at this time. 01:51:03.000 --> 01:51:06.020 Okay. I mean, I just wanted to have the discussion, and, 01:51:06.760 --> 01:51:10.336 you know, I was sort of started in the camp of 01:51:10.528 --> 01:51:14.820 not having one in there to having one, I think, and then being 01:51:16.770 --> 01:51:20.426 appreciative of staff increasing it from 0.25% to 1%. 01:51:20.618 --> 01:51:23.970 And so, you know, again, I just 01:51:24.010 --> 01:51:27.042 wanted to have the discussion on whether flexibility would be beneficial, 01:51:27.106 --> 01:51:29.990 just because I know that, at least for the megawatts, 01:51:30.810 --> 01:51:33.522 those numbers are already going to change this fall. 01:51:33.586 --> 01:51:37.050 So. But, you know, Chairman Gleeson, your point? 01:51:37.130 --> 01:51:39.310 I mean, we'll have an opportunity, 01:51:40.930 --> 01:51:44.850 the commission, staff, the stakeholders will have an opportunity to 01:51:44.970 --> 01:51:48.858 offer feedback on the inputs and assumptions. And we find over time that the 01:51:48.874 --> 01:51:53.002 1% needs to be changed, then we'll get that feedback, and maybe 01:51:53.026 --> 01:51:57.242 there will be a limited opening of a rulemaking proceeding to adjust it. 01:51:57.426 --> 01:52:01.546 But I just want to have the discussion, and I certainly appreciate everyone's 01:52:01.578 --> 01:52:04.710 feedback, and I'm happy to withdraw that proposed change. 01:52:06.380 --> 01:52:09.980 Go ahead, David. So do you feel at this point 01:52:10.020 --> 01:52:13.396 you have what you need? I think that we've had discussion on all the points 01:52:13.468 --> 01:52:17.196 because of the importance of this rule. It's been suggested 01:52:17.228 --> 01:52:20.444 by the always wise Sheila that perhaps we bring you back some language 01:52:20.492 --> 01:52:23.588 after lunch break or something so that you guys can lay finalize on the final 01:52:23.644 --> 01:52:26.988 edits to the rule, at least before you take your 01:52:27.004 --> 01:52:30.692 final vote, just to make sure that we've captured all the nuances 01:52:30.796 --> 01:52:34.480 as intended. That's right. Since we've made changes to changes to changes, 01:52:34.520 --> 01:52:38.232 I think it'd be helpful for all of us to get to see a 01:52:38.256 --> 01:52:42.032 draft of this before we adopt it and before we put our 01:52:42.056 --> 01:52:45.080 signatures on it. So just this once? Yes, justice, 01:52:45.120 --> 01:52:48.272 once. So the plan is going to 01:52:48.296 --> 01:52:52.288 be we're going to recess until 01:00 to give staff time 01:52:52.464 --> 01:52:56.272 to make all these changes, and everyone can 01:52:56.296 --> 01:52:59.406 eat some lunch, and then we'll come back. I don't know how much longer it'll 01:52:59.438 --> 01:53:02.830 take, but staff needs the time to go to incorporate these changes. 01:53:02.870 --> 01:53:05.718 (item:16:Chairman Gleeson recesses open meeting for lunch) So we'll stand in recess until 01:00. Thank you, 01:53:05.734 --> 01:53:09.646 sir. Okay. (item:16:Chairman Gleeson reconvenes open meeting) We are going to reconvene 01:53:09.678 --> 01:53:13.010 our open meeting at 01:06. 01:53:13.750 --> 01:53:15.410 We're still on item 16. 01:53:16.350 --> 01:53:20.510 David or Team Barksdale, thanks for getting us draft 01:53:20.590 --> 01:53:24.930 to look over. I was good with all of the changes. 01:53:25.840 --> 01:53:29.020 Happy to hear. If you all have any other thoughts 01:53:31.200 --> 01:53:34.480 I still would like to discuss effectively real quick. 01:53:34.600 --> 01:53:38.080 Oh, sorry. Thank you. (item:16:Commissioner Hjaltman on clarifying language in memo, 54584) I was hoping maybe it was something 01:53:38.120 --> 01:53:41.088 we could define later, 01:53:41.264 --> 01:53:44.808 but having that word in the rule does still cause me concern as 01:53:44.824 --> 01:53:48.000 it is not defined anywhere. If I could get some 01:53:48.040 --> 01:53:51.154 feedback from you all before I ask for that to be removed, 01:53:51.232 --> 01:53:52.050 commissioners, 01:53:55.350 --> 01:53:57.690 I personally think it's generally understood. 01:53:59.150 --> 01:54:02.710 I think there's, you know, best practices 01:54:02.870 --> 01:54:07.330 and operational historical 01:54:07.670 --> 01:54:10.890 precedent that would, you know, give us, 01:54:11.350 --> 01:54:14.222 at least in my mind, what we need to be able to define that kind 01:54:14.246 --> 01:54:17.700 of going forward. So it didn't give me any pause. 01:54:18.960 --> 01:54:22.340 I'm supportive to remove it if that's what you care to do, 01:54:24.040 --> 01:54:27.820 Commissioner Cobos? I mean either way, I'm fine. 01:54:28.640 --> 01:54:32.216 I hear what you're saying. I mean, what is effective? We know what ineffective 01:54:32.248 --> 01:54:36.120 would look like potentially, but what's like, the criteria for measuring effectiveness? 01:54:36.160 --> 01:54:39.688 So, I mean, I'm good taking it out or I don't know how you 01:54:39.704 --> 01:54:43.368 would define it though. Right? So that would create a lot more technical sort 01:54:43.384 --> 01:54:46.448 of feedback that I don't think is worth doing. 01:54:46.584 --> 01:54:50.384 Okay. I'm happy to support you, commissioner. Thank you, 01:54:50.392 --> 01:54:54.416 Mr. Chairman? Okay, if we could. Sorry. Redraft and remove that word, 01:54:54.568 --> 01:54:57.864 that would be perfect. So we had accepted a change 01:54:57.912 --> 01:55:01.232 and added and effectively to the load shed rotation under the magnitude 01:55:01.256 --> 01:55:04.424 definition. And you would like to wrap that back to or roll that back to 01:55:04.432 --> 01:55:07.678 the PFP language, correct? Yep. Easy enough. Thank you. 01:55:07.744 --> 01:55:09.550 So do you think if we break for an hour. 01:55:11.690 --> 01:55:13.738 I didn't get to eat during the last break, so if you guys all want 01:55:13.754 --> 01:55:17.070 to, you know. Okay, everybody good now? 01:55:17.450 --> 01:55:20.970 All right. (item:16:Motion to approve proposed order adopting reliability standard, 54584) So with that, I will entertain a motion to approve 01:55:21.010 --> 01:55:24.154 the proposed order adopting the reliability standard 01:55:24.202 --> 01:55:27.522 consistent with our discussion and Commissioner Cobos' memo. 01:55:27.626 --> 01:55:31.710 So moved. Second. Have a motion and a second. All those in favor? 01:55:34.460 --> 01:55:37.884 Second. All those in favor say aye. Aye. 01:55:38.052 --> 01:55:41.732 Opposed? Motion prevails. Thanks, y'all. Appreciate it. 01:55:41.836 --> 01:55:42.520 Sorry. 01:55:47.900 --> 01:55:51.500 Okay. (item:17:Chairman Gleeson lays out Project No. 55000) That takes us to Item No. 17. That is Docket 01:55:51.540 --> 01:55:55.120 number 55000, performance credit mechanism. 01:55:56.100 --> 01:55:59.776 So we have staff's final recommend recommendation on design 01:55:59.868 --> 01:56:02.880 parameters for the PCM. So, Werner, 01:56:02.960 --> 01:56:06.112 Chris. Thank you, Chairman Gleeson. (item:17:Commission Staff's Werner Roth with final recommendations on PCM, 55000) I'm Werner 01:56:06.136 --> 01:56:09.980 Roth for commission staff. So staff filed their final recommendations 01:56:10.320 --> 01:56:13.656 this project on the 37 design parameters. On page 01:56:13.688 --> 01:56:17.168 three of our memo, we note four design parameters where we have 01:56:17.184 --> 01:56:20.472 a different perspective or different recommendation than what ERCOT 01:56:20.496 --> 01:56:23.660 provided in their final recommendations that they had filed prior to ours, 01:56:24.040 --> 01:56:27.354 going through those really quickly. Design parameter number four, the metric used to 01:56:27.362 --> 01:56:31.138 determine PC hours. Because this is a product, 01:56:31.194 --> 01:56:34.682 the performance credit mechanism is a product that targets dispatchable generation. 01:56:34.826 --> 01:56:38.354 Staff believes that the hours chosen should be the hours 01:56:38.402 --> 01:56:41.666 where dispatchable generation specifically is most needed, 01:56:41.698 --> 01:56:45.330 and those are during the hours of highest net load 01:56:45.450 --> 01:56:49.018 for other types of risk. Other energy ancillary service products should be 01:56:49.034 --> 01:56:52.240 able to compensate for being available during the hours and be available for 01:56:53.140 --> 01:56:56.836 all generation, not just dispatchable. Design parameter 01:56:56.868 --> 01:57:00.160 number six is a duration base cap for consecutive PC hours. 01:57:00.780 --> 01:57:04.556 For this ERCOT and E3 had been recommending for, say, a storage 01:57:04.588 --> 01:57:08.228 facility that only had a two hour duration. If there were four consecutive PC 01:57:08.284 --> 01:57:11.516 hours, they would only be able to earn performance credits for the first 2 hours. 01:57:11.708 --> 01:57:15.372 Statute simply requires that a resource be 01:57:15.476 --> 01:57:19.272 available. Real time for each of the hours went to our performance credits. So if 01:57:19.296 --> 01:57:23.100 a storage facility was providing ancillary services the first 2 hours and 01:57:23.640 --> 01:57:26.440 being dispatched for the last two, they would be available for all 4 hours. 01:57:26.480 --> 01:57:30.180 So staff believes that a duration based cap is not appropriate. 01:57:31.080 --> 01:57:34.600 Third, design parameter number 20. We've never talked about this. Obviously, that cost 01:57:34.640 --> 01:57:38.024 cap compliance framework one staff continues to 01:57:38.032 --> 01:57:41.328 believe that a firm $1 billion gross cap is the 01:57:41.344 --> 01:57:45.626 only way we can ensure we're complying with what's in statute. The ERCOT recommendation 01:57:45.738 --> 01:57:49.770 from E3 was a counterfactual based off of the energy only market 01:57:49.810 --> 01:57:53.306 that's at equilibrium state. And then 01:57:53.338 --> 01:57:57.090 lastly, we have design parameter number 26, which is performance or 01:57:57.130 --> 01:58:00.298 non performance penalties for performance credits offered but not cleared in the forward 01:58:00.354 --> 01:58:00.950 market. 01:58:02.690 --> 01:58:06.322 ERCOT and E3 did have a recommendation for a penalty for 01:58:06.426 --> 01:58:10.294 resources that didn't clear the forward market after consulting with 01:58:10.302 --> 01:58:13.530 the IMM. The IMM has filed comments to this effect as well. 01:58:13.830 --> 01:58:17.598 Assigning a penalty for a PC that offers into 01:58:17.614 --> 01:58:21.598 the Ford market but does not clear and then does not perform when 01:58:21.614 --> 01:58:25.166 we get to the actual PC hours, is essentially assigning a penalty to them for 01:58:25.238 --> 01:58:28.694 an obligation that they haven't been compensated for. So we don't believe a penalty would 01:58:28.702 --> 01:58:32.174 be appropriate for those that did not clear the Ford market. With that, I'm happy 01:58:32.182 --> 01:58:35.438 to take any questions. Thank you. Werner, I want to say thanks for appreciate you 01:58:35.454 --> 01:58:38.230 taking the time, time to walk me through all this earlier in the week. 01:58:38.390 --> 01:58:41.490 I'm comfortable with staff's recommendations. 01:58:42.270 --> 01:58:45.686 Happy to have any discussion, or if you all have questions for Werner 01:58:45.718 --> 01:58:49.446 or Chris? Can I ask one 01:58:49.478 --> 01:58:52.894 question for you? (item:17:Commissioner Glotfelty's question on net load vs. lowest surplus available generation, 55000) On the, 01:58:53.062 --> 01:58:56.726 on item number four, the metric used to determine the PC hours, 01:58:56.798 --> 01:59:01.150 there was a question of net load versus the 01:59:01.190 --> 01:59:04.290 lowest surplus available generation. Can you explain those? 01:59:05.470 --> 01:59:08.870 Do those logically? They seem to overlap 01:59:08.910 --> 01:59:11.974 some, but did you find in the analysis that they, 01:59:12.022 --> 01:59:15.590 in fact, don't? So the hours 01:59:15.630 --> 01:59:18.942 of highest net load would capture a majority of the risk under 01:59:18.966 --> 01:59:22.462 the system we see there. I mean, the one situation where we could see 01:59:22.606 --> 01:59:25.982 the lowest surplus capturing risk that isn't captured by highest net load would 01:59:26.006 --> 01:59:29.450 be during, like, an event where we have a high level of thermal outages, 01:59:30.090 --> 01:59:33.578 for example. So, I mean, there is, there are periods of risk. Say that 01:59:33.594 --> 01:59:36.590 again, because that's what I was trying to make sure that we caught. 01:59:37.050 --> 01:59:40.722 When thermal outages are highest, so will 01:59:40.746 --> 01:59:44.370 we catch those that would not necessarily be caught in the highest net low? 01:59:44.410 --> 01:59:47.150 There's a chance that that would not be captured in that, 01:59:47.450 --> 01:59:51.778 but I would say staff's position on that is that 01:59:51.954 --> 01:59:55.738 because this, again, this product is very specifically targeted towards having. 01:59:55.834 --> 01:59:59.654 Towards dispatchable generation. By definition, 01:59:59.742 --> 02:00:03.650 the hours that we need, the highest level of dispatchable generation are during those 02:00:04.830 --> 02:00:08.214 hours of highest net load. I'm sorry, 02:00:08.262 --> 02:00:11.670 but during times of high thermal outages, like as we do, 02:00:11.750 --> 02:00:14.958 I think that would be something we want megawatts of all varieties. I mean, 02:00:15.054 --> 02:00:17.950 there should be compensation for megawatts of intermittent resources, 02:00:18.070 --> 02:00:21.748 anything that's available to be during those hours. 02:00:21.934 --> 02:00:25.380 So I'm not suggesting we change it. I was just. 02:00:26.240 --> 02:00:29.540 Because to me, it seems like we need to capture those 02:00:32.160 --> 02:00:35.232 forced outage rates somewhere in this process. 02:00:35.336 --> 02:00:38.504 And so I'm happy with what you said, 02:00:38.552 --> 02:00:41.100 and we'll see how it goes. 02:00:43.280 --> 02:00:49.138 Yeah, well, I support periods 02:00:49.234 --> 02:00:52.642 with the highest net load because that is 02:00:52.826 --> 02:00:56.306 consistent with the blueprint we adopted in January 19, 02:00:56.338 --> 02:01:00.042 2023, where we said that we would recommend the 02:01:00.066 --> 02:01:03.954 creation of a new reliability service to ensure enough dispatchable generation 02:01:04.002 --> 02:01:07.522 is available during periods of low renewable output. 02:01:07.666 --> 02:01:12.322 And so I think that stays consistent with the blueprint that we 02:01:12.346 --> 02:01:15.930 adopted back in January of '23. 02:01:16.230 --> 02:01:20.070 And I would also 02:01:20.190 --> 02:01:21.810 support this change. 02:01:24.910 --> 02:01:28.454 I'm good with what staff is recommended. I do. I know 02:01:28.462 --> 02:01:31.686 it's been a lot of work. So thank you, staff, for going 02:01:31.718 --> 02:01:34.734 forth and putting this out for us. Very helpful. 02:01:34.862 --> 02:01:37.810 Appreciate it Werner, Chris. Y'all have everything you need? 02:01:38.270 --> 02:01:41.940 I believe so. If there's no other changes to any of the other 02:01:42.100 --> 02:01:45.644 design parameters. Yeah, we'll just take the ones we have identified as staff recommendations that 02:01:45.652 --> 02:01:49.420 are different than ERCOT and we'll notify ERCOT and E3 and the IMM 02:01:49.460 --> 02:01:53.040 so they can begin doing their benefit cost assessments for us. That's correct. 02:01:53.420 --> 02:01:57.060 Thanks, y'all. Chairman, if I. If I may just get a quick 02:01:57.100 --> 02:02:00.644 head nod from the IMM and from ERCOT that they 02:02:00.692 --> 02:02:05.288 do, in fact, have what they need in order to start the cost benefit analyses 02:02:05.404 --> 02:02:09.072 that they need to be doing. Just a head nod. I don't 02:02:09.096 --> 02:02:12.616 think you guys need to come up. Yes, 02:02:12.728 --> 02:02:16.260 I see one head nod from the IMM. 02:02:24.320 --> 02:02:25.940 Matt, do you want to come up? 02:02:28.560 --> 02:02:32.216 So close, Barksdale. So close. (item:17:ERCOT's Regulatory Counsel Matt Arth cost benefit analysis, 55000) Apologize for the confusion. 02:02:32.368 --> 02:02:36.380 Matt Arth for ERCOT. I guess the difficulty is the magnitude, 02:02:36.960 --> 02:02:39.620 because it's not established in the rule, 02:02:40.760 --> 02:02:44.340 in order to perform the cost benefit analysis, I think 02:02:45.080 --> 02:02:48.192 both ERCOT and I don't want to speak for the IMM, but we would need 02:02:48.216 --> 02:02:51.520 to begin that fairly soon, in September. 02:02:51.680 --> 02:02:56.696 So I think we would need to proceed with a 02:02:56.728 --> 02:03:00.086 magnitude that is nothing, the magnitude that will be determined through this assessment, 02:03:00.118 --> 02:03:03.518 that's done by December 1. So I 02:03:03.534 --> 02:03:07.646 guess we could use 19 gigawatts, as was included 02:03:07.718 --> 02:03:11.542 in the proposed white paper 02:03:11.686 --> 02:03:14.982 in April, to perform that study, and that 19 02:03:15.046 --> 02:03:18.326 is the amount that can be not effectively, 02:03:18.398 --> 02:03:21.278 but reliably rolled, is that right, 02:03:21.334 --> 02:03:22.650 Commissioner? Yes. 02:03:25.440 --> 02:03:29.256 Werner do you agree? Yes, I would say that that would 02:03:29.288 --> 02:03:32.160 be the number they should be using for this initial assessment, since that is the 02:03:32.200 --> 02:03:35.384 most current number we have for the megawatts of load that can 02:03:35.392 --> 02:03:37.180 be safely rotated. 02:03:37.920 --> 02:03:41.800 Okay, thanks, Matt. That was 02:03:41.840 --> 02:03:44.140 fast. Runners safely. 02:03:48.760 --> 02:03:51.884 All right. (item:18:Chairman Gleeson lays out Project No. 55845) That'll take us to Item No. 18. Docket No. 02:03:51.952 --> 02:03:55.604 55845, review of ancillary services in the ERCOT market. 02:03:55.732 --> 02:03:57.920 Believe we have an update from staff. 02:04:06.260 --> 02:04:10.164 Hi, Harika Basaran for Staff and I have with me Julie Gauldin. 02:04:10.292 --> 02:04:13.460 And she has been leading this coordination between IMM, 02:04:13.500 --> 02:04:16.612 ERCOT and staff, and she just give you an update about 02:04:16.716 --> 02:04:20.470 all the progress. Thank you. 02:04:22.570 --> 02:04:26.074 (item:18:Commission Staff's Julie Gauldin on update of review with ERCOT, IMM & Staff, 55845) Staff continues our collaboration with ERCOT and IMM 02:04:26.122 --> 02:04:29.410 on the as study. Yesterday, we had a workshop 02:04:29.490 --> 02:04:33.634 at ERCOT to present draft study results and provide a chance for 02:04:33.722 --> 02:04:37.418 questions from stakeholders to be answered. 02:04:37.474 --> 02:04:40.738 Both ERCOT and the IMM presented their draft recommendations and 02:04:40.754 --> 02:04:45.160 we had a very robust discussion of a number of technical and policy issues. 02:04:45.660 --> 02:04:49.796 Staff's plan for the next steps are as follows. By the end of September, 02:04:49.868 --> 02:04:53.060 we'll file a draft study report based on the 02:04:53.100 --> 02:04:56.724 outline of the approved scope. Shortly after this, we'll file 02:04:56.772 --> 02:05:00.980 questions for stakeholders to provide comments on. On October 31, 02:05:01.020 --> 02:05:04.892 there'll be a staff led workshop at the Commission and the agenda 02:05:04.916 --> 02:05:08.160 will be informed by the comments received to staff's questions. 02:05:09.350 --> 02:05:13.158 This workshop is now posted on our public website during 02:05:13.214 --> 02:05:16.870 November and December. Staff's plan is that the study will be discussed during 02:05:16.910 --> 02:05:20.998 at least two open meetings before being finalized and submitted to the legislature 02:05:21.174 --> 02:05:23.530 as part of our biennial agency report. 02:05:25.030 --> 02:05:28.414 Finally, staff would like to extend our appreciation to ERCOT and the IMM 02:05:28.462 --> 02:05:31.742 staff for their cooperation and their hard work, and I'm happy 02:05:31.766 --> 02:05:35.180 to answer any questions you might have. Thank you for the update. Commissioners. 02:05:35.880 --> 02:05:39.304 Any questions? Not at this time. 02:05:39.352 --> 02:05:41.700 No, I'm good. Thanks, y'all. 02:05:46.960 --> 02:05:51.056 (item:20:Chairman Gleeson lays out Project No. 56966) That'll take us to item No. 20. That is Docket 02:05:51.128 --> 02:05:54.768 No. 56966, goal for reducing 02:05:54.824 --> 02:05:57.460 average total residential load in the ERCOT region. 02:05:57.800 --> 02:06:01.680 Commissioner Hjaltman filed a memo in this project. 02:06:02.540 --> 02:06:05.640 If you'd like to lay out your memo. (item:20:Commissioner Hjaltman lays out her memo, 56966) Sure. I think just 02:06:06.180 --> 02:06:10.180 quickly, the purpose of the memo is to really 02:06:10.220 --> 02:06:14.004 make sure that we at the Commission and staff are getting the 02:06:14.092 --> 02:06:18.668 data and information back from the stakeholders. 02:06:18.804 --> 02:06:22.188 It's not to ask anyone to go on rabbit holes or 02:06:22.284 --> 02:06:25.452 dive down anything big, but just to make sure that they're out there, they've done 02:06:25.476 --> 02:06:28.832 this, make sure you're getting the most information. So that was 02:06:28.856 --> 02:06:33.512 the purpose of the memo in general. So nothing 02:06:33.696 --> 02:06:35.780 big in the memo laid out other than that. 02:06:37.560 --> 02:06:40.960 Commissioners, any questions? I guess maybe a few 02:06:41.000 --> 02:06:44.576 comments and some good ones. (item:20:Commissioner Jackson's thoughts on memo, 56966) This obviously is a great step forward 02:06:44.648 --> 02:06:47.920 in terms of demand response. And, you know, we've heard a lot, I think, 02:06:47.960 --> 02:06:51.440 from the opportunities that the reps 02:06:51.480 --> 02:06:54.694 have to, to do this type of program and then the value of 02:06:54.742 --> 02:06:58.334 actually getting the devices that are needed 02:06:58.382 --> 02:07:01.934 to the hardware, if you will, to start implementing it and as 02:07:01.982 --> 02:07:05.278 importantly, the data, and so really, 02:07:05.334 --> 02:07:09.382 really excited about moving forward and would just ask folks, I think, 02:07:09.526 --> 02:07:13.302 as they comment on the proposed rule, to be thinking about 02:07:13.366 --> 02:07:16.878 that data gathering piece and if we need 02:07:16.894 --> 02:07:21.102 to consider that, you know, in a different way or 02:07:21.126 --> 02:07:24.414 any thoughts and ideas on the data gathering, because that's going to be, I think, 02:07:24.462 --> 02:07:28.254 you know, the foundation of what we're looking for 02:07:28.302 --> 02:07:31.614 in order to kind of value this demand response moving forward. 02:07:31.782 --> 02:07:35.774 And then also, you know, any thoughts and ideas on actually participating, 02:07:35.902 --> 02:07:40.222 because it's twofold. We have to give the opportunity, but we also have to incentivize 02:07:40.286 --> 02:07:44.070 participation. So I think a great opportunity in the rural 02:07:44.110 --> 02:07:47.936 to, to maybe ask, maybe specifically for those types 02:07:47.968 --> 02:07:52.312 of inputs moving forward so that we can have a successful program. 02:07:52.416 --> 02:07:55.920 But thanks for working on it. A great job. Ramya, 02:07:55.960 --> 02:07:59.112 thanks for talking to my office about this as well. And I apologize. I did 02:07:59.136 --> 02:08:02.608 this all backwards. If you wanted to, if you had any comments 02:08:02.784 --> 02:08:06.552 that you wanted to make. (item:20:Commission Staff's Ramya Ramaswamy on demand response, 56966) Ramya Ramaswamy, 02:08:06.576 --> 02:08:10.008 Commission Staff. Thank you Commissioner Hjaltman 02:08:10.064 --> 02:08:13.812 and Commissioner Jackson for your comments. Just want to let you know that the 02:08:13.836 --> 02:08:17.668 data will allow for the validation of what we've heard as 02:08:17.724 --> 02:08:21.276 anecdotal evidence on how 02:08:21.388 --> 02:08:25.100 data demand response works today, and it will allow us 02:08:25.140 --> 02:08:29.348 to facilitate revising the goal in the future. So that definitely 02:08:29.404 --> 02:08:31.800 would be helpful. Thank you. 02:08:33.780 --> 02:08:37.080 Any other questions? No. Thank you for your work on this. 02:08:38.300 --> 02:08:42.124 (item:20:Motion to approve proposal for publication, 56966) I will entertain a motion to approve the proposal for publication consistent with 02:08:42.172 --> 02:08:45.636 Commissioner Hjaltman's memo in our discussion. So moved. 02:08:45.788 --> 02:08:49.116 Second. Have a motion and a second. All those in favor say aye. Aye. 02:08:49.308 --> 02:08:52.716 Opposed? Motion prevails. Thank you, Ramya. Thanks, 02:08:52.748 --> 02:08:56.444 David. All right. (item:21:Chairman Gleeson lays out Project No. 54224) That'll take us to 02:08:56.612 --> 02:09:00.340 Item 21 and 22. I'm going to call those up 02:09:00.380 --> 02:09:04.276 together. So item 21 is 02:09:04.308 --> 02:09:08.202 Docket No. 54224, cost recovery for service 02:09:08.306 --> 02:09:12.258 to distribute energy resources. (item:22:Chairman Gleeson lays out Project No. 54233) And Item No. 22 02:09:12.354 --> 02:09:16.106 is Docket 54233, technical requirements 02:09:16.258 --> 02:09:19.922 interconnection process for distributed energy resources. 02:09:19.986 --> 02:09:23.474 And Commissioner Glotfelty, he filed a memo in both of these dockets. 02:09:23.602 --> 02:09:26.962 Thank you, Mr. Chairman. I appreciate this. (item:21:Commissioner Glotfelty lays out his memo, 54224) As you all know, 02:09:27.066 --> 02:09:31.942 we've been working on this issue for quite some time. It has started 02:09:32.006 --> 02:09:35.262 and slowed and started and slowed for the last 02:09:35.406 --> 02:09:38.998 two years. This is an attempt to see if we can 02:09:39.014 --> 02:09:42.470 get this across the finish line. I have totally thrown something out 02:09:42.510 --> 02:09:46.134 here that is totally different and new policy and 02:09:46.262 --> 02:09:49.822 something that is applied at the 02:09:49.846 --> 02:09:52.942 transmission level just as a result of this year that I 02:09:52.966 --> 02:09:57.210 was proposing at the distribution level to deal with interconnection costs. 02:09:57.710 --> 02:10:01.654 (item:22:Commissioner Glotfelty lays out his memo, 54233) I would suggest that instead of totally preparing 02:10:01.702 --> 02:10:05.630 to publish a rule right now, we at least ask for comments from 02:10:05.670 --> 02:10:08.566 the stakeholders. Comments, 02:10:08.758 --> 02:10:11.890 they should be filed in both docket numbers together 02:10:12.430 --> 02:10:15.846 and have them come and tell us if this is a viable option 02:10:15.878 --> 02:10:19.302 to move forward. If so, yes. If not, 02:10:19.406 --> 02:10:23.126 why? I've been working with 02:10:23.158 --> 02:10:27.184 staff on timelines and such to try to get something finished, 02:10:27.232 --> 02:10:30.736 and I'm really appreciative that you all have taken the time to do 02:10:30.768 --> 02:10:34.456 so. And I think the next step is to see where we go 02:10:34.488 --> 02:10:38.208 before we take the final pathway. 02:10:38.264 --> 02:10:41.680 Pick the final pathway, because the policy issues that are embedded in here 02:10:41.760 --> 02:10:45.368 are pretty substantial that we all need to have some 02:10:45.504 --> 02:10:48.592 discussion time on. And I also think that 02:10:48.776 --> 02:10:51.220 over the next month or so, 02:10:51.800 --> 02:10:55.432 Ramya, if you can begin to brief the other offices 02:10:55.496 --> 02:10:58.912 on this, on the issues that we face with this, that would 02:10:58.936 --> 02:11:02.320 be great. Yeah, that's what I was going to say. I think I could benefit 02:11:02.360 --> 02:11:05.632 from some briefing on these issues. They're new to 02:11:05.656 --> 02:11:08.872 me, so I think briefing on this would be helpful. And if you all 02:11:08.896 --> 02:11:09.980 had any comments? 02:11:12.480 --> 02:11:15.672 (item:21:David Smeltzer on briefings, 54224) If the Commission briefing is definitely something that we agree should happen, 02:11:15.696 --> 02:11:19.266 and we're happy to do that. If the Commission is interested in receiving comments from 02:11:19.298 --> 02:11:22.850 stakeholders, commission staff is 02:11:22.890 --> 02:11:26.418 happy to put out a memo with a comment deadline in a filing location and 02:11:26.434 --> 02:11:30.026 things like that. I might recommend just doing it in a single docket 02:11:30.058 --> 02:11:33.870 54224, just so that everything is consolidated in one place. That's great. 02:11:35.370 --> 02:11:39.122 Yeah. And staff's objective was to be able to brief. And so whatever input 02:11:39.146 --> 02:11:41.570 you guys want, that is what we want to make sure that you get. 02:11:41.610 --> 02:11:45.432 So just let us know. Do you want to add any more guidance 02:11:45.496 --> 02:11:49.272 to kind of put, to say this, to put guardrails 02:11:49.296 --> 02:11:52.912 around the comments we receive or I think 02:11:53.016 --> 02:11:56.528 what you have in the memo, I think it's what we have in the memo, 02:11:56.584 --> 02:12:00.020 which is the concept of 02:12:00.640 --> 02:12:04.040 creating an interconnection allowance at the distribution 02:12:04.120 --> 02:12:07.800 level similar to that at the transmission level. What will that capture 02:12:07.840 --> 02:12:11.680 and what will that leave out? And then, of course, the component that deals with. 02:12:11.760 --> 02:12:15.152 So how would this happen in a muni and cooperative area? We need to 02:12:15.176 --> 02:12:18.216 respect that and we need to understand that before we move forward. 02:12:18.288 --> 02:12:21.592 Big policy issue there. I would like to see the 02:12:21.616 --> 02:12:25.440 comments for sure. For the price that that 02:12:25.520 --> 02:12:28.744 and who would be paying for that at the distribution level. Right. For the. 02:12:28.872 --> 02:12:32.680 Obviously the consumer would be paying for that. And then also. And staff 02:12:32.720 --> 02:12:36.628 might be able to say yes or no very quickly. (item:22:Commissioner Hjaltman's question on generation allowance, 54233) The generation allowance 02:12:36.684 --> 02:12:40.700 was statutorily driven from the legislature. Can a Commission do 02:12:40.740 --> 02:12:45.076 that without that driven from the legislature, 02:12:45.268 --> 02:12:48.820 from just us adopting that? So I haven't done a 02:12:48.900 --> 02:12:52.120 deep statutory analysis. What maybe. 02:12:54.100 --> 02:12:57.428 Did everyone hear that? You know, I mean, 02:12:57.444 --> 02:13:00.754 I think the Commission has jurisdiction on some of these things. You know, 02:13:00.762 --> 02:13:03.578 I'd want to think through them and you and co op issues and look 02:13:03.594 --> 02:13:07.290 into a little bit, but we do look over Tcost and review 02:13:07.370 --> 02:13:10.554 rates in a lot of these circumstances. So it's plausible from a 02:13:10.562 --> 02:13:14.370 legal perspective. But I haven't focused on this specifically. 02:13:14.410 --> 02:13:17.586 Just something to think about and I would suspect if those think we don't, 02:13:17.618 --> 02:13:20.698 they'll tell us. Very likely. Just a hunch, 02:13:20.754 --> 02:13:24.682 yes. So what would you envision ERCOT's role being at this point in time 02:13:24.826 --> 02:13:28.206 on this? I don't think ERCOT has a role right now. I think 02:13:28.238 --> 02:13:31.798 that they get 02:13:31.814 --> 02:13:35.950 a pass on this one until we make some policy decisions upon how 02:13:35.990 --> 02:13:39.366 this would be funded or 02:13:39.398 --> 02:13:42.854 if it gets funded this way, or. Cause these are 02:13:42.902 --> 02:13:46.798 distributed resources or generating facilities that are interconnected at 02:13:46.814 --> 02:13:50.206 the distribution voltage that play in the wholesale market. So there definitely 02:13:50.238 --> 02:13:53.730 will be a role for them. I just don't know that it's yet. 02:13:55.200 --> 02:13:58.184 Are you specifically asking about the funding issue or, 02:13:58.232 --> 02:14:02.096 in general, the interconnection and standardization of Der's 02:14:02.168 --> 02:14:04.660 issue? Just in general. 02:14:05.880 --> 02:14:09.500 Depending upon the size of the distributed resources, 02:14:10.000 --> 02:14:13.616 they will have to go to ERCOT for their interconnection. 02:14:13.768 --> 02:14:17.300 And that is all part of the rule language that we have 02:14:17.640 --> 02:14:21.018 that we will be briefing you on. But funding, 02:14:21.074 --> 02:14:23.786 I think, is separate from what we were talking about. 02:14:23.858 --> 02:14:27.338 Yeah, I mean, 02:14:27.354 --> 02:14:29.338 it's been a while since we looked at these issues, so I think it would 02:14:29.354 --> 02:14:32.710 be helpful to get a briefing and just refresh. 02:14:33.050 --> 02:14:36.714 I know there's the interconnection piece and the cost allocation piece and 02:14:36.882 --> 02:14:40.522 just understanding that. And I'm fine with getting comments on the 02:14:40.546 --> 02:14:44.058 questions that Commissioner Glotfelty laid out in 02:14:44.074 --> 02:14:47.892 his memo. And commission staff is happy in its 02:14:47.996 --> 02:14:51.236 filing memo when we're doing a deadline to put 02:14:51.268 --> 02:14:54.900 some reasonable boundaries on the topics that we think are of interest 02:14:54.940 --> 02:14:58.280 to you guys. Does that work, Jim? Absolutely. Okay. 02:14:58.580 --> 02:15:00.160 All right, thanks, y'all. 02:15:03.620 --> 02:15:07.724 All right. (item:23:Chairman Gleeson lays out Project No. 55718) That'll take us to Item No. 23. Docket No. 02:15:07.772 --> 02:15:11.116 55718, reliability plan for the Permian Basin 02:15:11.188 --> 02:15:14.760 under Pura, section 39.167. 02:15:15.100 --> 02:15:18.360 And I believe we have an update on this. 02:15:18.660 --> 02:15:21.948 Staff or Commissioner Cobos? Yes, I was hoping to get an 02:15:21.964 --> 02:15:25.124 update from commission staff. I know we had a staff 02:15:25.172 --> 02:15:29.044 led workshop on August 22 and just kind of describe what 02:15:29.092 --> 02:15:32.404 next steps are left from our processing of 02:15:32.412 --> 02:15:34.680 the Permian Basin reliability plan at the Commission. 02:15:43.910 --> 02:15:48.650 (item:23:Commission Staff's Therese Harris with details on August 22 workshop, 55718) Therese Harris, Commission Staff. So 02:15:49.190 --> 02:15:52.686 the workshop was very informative. We heard from 02:15:52.758 --> 02:15:56.130 many of the stakeholders. We are taking that information 02:15:56.590 --> 02:16:00.222 along with the responses to questions 02:16:00.246 --> 02:16:04.056 that were posed earlier. We will compose 02:16:04.168 --> 02:16:08.240 a memo for your consideration. We will 02:16:08.320 --> 02:16:11.352 give you pros and cons on different ways to 02:16:11.376 --> 02:16:14.944 proceed. And then, of course, leave the decision up to you whether 02:16:14.992 --> 02:16:18.704 or not to approve something that ERCOT has laid 02:16:18.752 --> 02:16:21.220 out or something else. 02:16:22.600 --> 02:16:26.584 (item:23:Commission Staff's Harika Basaran on next ERCOT meeting & processing CCNs, 55718) And we are meeting with ERCOT again today. We are very in close 02:16:26.712 --> 02:16:29.870 contact with. Since it's a really complex issue, 02:16:30.530 --> 02:16:34.290 when do you anticipate filing the memo? I know our next open meeting is September 02:16:34.330 --> 02:16:37.642 12, and y'all are under a tight, you know, kind of got 02:16:37.665 --> 02:16:40.040 a few weeks, couple of weeks or so, but I know there's a lot of 02:16:40.066 --> 02:16:43.656 information to process. We tried to meet Connie's deadline of one 02:16:43.714 --> 02:16:47.178 week, but sometimes we can be happy to waive it. 02:16:47.272 --> 02:16:50.850 Five days. Just kidding. Yeah. No later than Friday maybe, 02:16:50.888 --> 02:16:53.892 so that you will have the weekend at least before the briefings of. 02:16:53.946 --> 02:16:58.224 Right. That will be before the open meeting. I'm 7th. 02:16:58.352 --> 02:17:00.860 Right. One week, maybe around eight. Latest? 02:17:02.200 --> 02:17:05.528 Yeah. Okay. We'll try earlier as early as we 02:17:05.544 --> 02:17:09.216 can. Okay, that sounds good. But that's 02:17:09.248 --> 02:17:12.647 literally the last steps we have is the staff recommendation or pros 02:17:12.664 --> 02:17:15.936 and cons of each of the options that you can look at the Permian Basin 02:17:15.968 --> 02:17:20.020 reliability plan with. And then we have the September 12 and 2016 six 02:17:20.558 --> 02:17:24.058 open meetings to deliberate and 02:17:24.840 --> 02:17:28.820 make a decision on how to move forward. I think 02:17:29.200 --> 02:17:32.632 as you meet, you're probably getting a lot of requests for 02:17:32.656 --> 02:17:35.459 meetings. We are meeting with stakeholders. Yeah. 02:17:36.120 --> 02:17:40.183 You know, that's important too, to get robust feedback 02:17:40.232 --> 02:17:43.056 from all interests on this issue. 02:17:43.248 --> 02:17:46.558 But it's, and I think you should also, you need time to 02:17:46.600 --> 02:17:50.558 write your memo and all that kind of stuff, too. So as 02:17:50.600 --> 02:17:54.544 you meet with stakeholders, I think it's important to get diverse perspectives 02:17:54.592 --> 02:17:58.620 on this issue on how to move forward with approving a plan. 02:18:00.718 --> 02:18:03.820 Is there any other direction that you would need from us at this time? 02:18:05.799 --> 02:18:09.656 The only thing is there are two issues, right. The plan and then processing 02:18:09.688 --> 02:18:13.468 of it. CCN, the order. And on the dead side, we are looking 02:18:13.510 --> 02:18:17.190 to OPDM to take part in leaders. We are just 02:18:17.230 --> 02:18:21.620 focusing on the plan itself, SME's. But the process is 02:18:21.766 --> 02:18:25.549 and order what's going to be included. We are looking up to OPDM staff 02:18:25.629 --> 02:18:29.582 and we are extremely fortunate that we have Mark Hobankamp helping us 02:18:29.606 --> 02:18:32.770 out with those. Yeah, he's got a lot of experience from Prez. 02:18:33.270 --> 02:18:36.816 We've had a discussion. He's a very valuable member of the team. 02:18:36.998 --> 02:18:40.480 So thank you, Mark. (item:23:Commissioner Cobos on CCNs and HB5066, 55718) And so I think 02:18:40.820 --> 02:18:44.548 when we get closer to figuring out where we're headed, it's going to be 02:18:44.564 --> 02:18:47.825 really important for ERCOT and the tsps to get together and figure out, well, 02:18:47.843 --> 02:18:51.959 how many CCNs are we going to have to 02:18:52.580 --> 02:18:57.760 review at the Commission now we're under 180 days timeline 02:18:58.260 --> 02:19:01.236 that was included in House Bill 5066. So we're going to have a very short 02:19:01.268 --> 02:19:05.066 processing timeline for, for a magnitude 02:19:05.098 --> 02:19:08.656 of ccns, even just for the base local 02:19:08.714 --> 02:19:12.530 projects. It's going to be a lot. And so having 02:19:12.650 --> 02:19:16.281 some idea of how many total ccns and 02:19:16.466 --> 02:19:20.754 what's the right sequencing or how many per 02:19:20.802 --> 02:19:24.706 month is going to be very important. I know I've talked to Connie about 02:19:24.778 --> 02:19:28.242 our LaR request and ensuring that we have 02:19:28.306 --> 02:19:32.129 enough staff resources to process the ccns. 02:19:33.029 --> 02:19:35.808 And Connie, you can speak to this, 02:19:36.109 --> 02:19:38.727 with respect to the LAR request, 02:19:39.189 --> 02:19:42.861 yes. In fact, one of our exceptional items has a 02:19:42.885 --> 02:19:46.147 focus on infrastructure resiliency 02:19:46.189 --> 02:19:49.901 and reliability. I believe it 02:19:50.085 --> 02:19:52.729 covers eight ftes. 02:19:53.869 --> 02:19:57.866 With the focus on being able to process some of these contested 02:19:57.898 --> 02:20:01.510 cases and also address some of the 02:20:02.050 --> 02:20:05.830 extreme weather events that we have seen lately 02:20:07.170 --> 02:20:10.578 with respect to the wildfires, the hurricane and so on, there's going to be a 02:20:10.594 --> 02:20:13.242 lot of infrastructure work coming our way. 02:20:13.346 --> 02:20:17.122 Okay. So as we get the data on a more defined number 02:20:17.146 --> 02:20:20.924 of ccns, if you want to relook and make sure that eight and however 02:20:20.972 --> 02:20:24.484 many is dedicated to, like, legal is still enough, that would probably be a 02:20:24.492 --> 02:20:27.716 good idea, because it is even more than Crez, 02:20:27.748 --> 02:20:31.080 I think, in terms of ccns. And so, 02:20:32.380 --> 02:20:35.468 you know, thank you for adding that to the Lar. I think that's important to 02:20:35.484 --> 02:20:38.972 get ready from a staffing standpoint. So, you know, we'll approve a plan 02:20:39.076 --> 02:20:42.980 and then it'll be about the sequencing of 02:20:43.020 --> 02:20:46.406 those dockets. And coming up with that 02:20:46.438 --> 02:20:49.798 plan shortly thereafter is going to be very important so that we can keep the 02:20:49.814 --> 02:20:53.606 ball moving to get the plan completed 02:20:53.718 --> 02:20:56.010 and energized as soon as possible. 02:20:58.670 --> 02:21:02.250 Yes, we'll certainly do that. We have some other 02:21:02.710 --> 02:21:06.710 exceptional items that may help address this workload. We have 02:21:06.870 --> 02:21:10.486 a general staffing increase related to contested 02:21:10.518 --> 02:21:13.240 cases overall and volume of work. 02:21:13.400 --> 02:21:17.264 And we're also seeking funding 02:21:17.312 --> 02:21:21.184 for a case management system that would help streamline 02:21:21.312 --> 02:21:24.816 the manual workflow currently happening in contested 02:21:24.848 --> 02:21:28.736 cases. Thank you, Therese and Harika, 02:21:28.768 --> 02:21:31.224 y'all put in a lot of work on this, and I know, Herika, in the 02:21:31.232 --> 02:21:34.616 middle of market analysis and everything you've got going on there, you got roped into 02:21:34.648 --> 02:21:37.758 this. And Therese and your team has been great to work with. So thank you 02:21:37.774 --> 02:21:41.022 so much, and we look forward to seeing your memo. Thank you. Thanks, 02:21:41.046 --> 02:21:41.650 y'all. 02:21:44.070 --> 02:21:48.358 Okay. (item:32:Chairman Gleeson lays out docket for ERCOT oversight & NOGRR245) So I think that will bring us to Item 02:21:48.414 --> 02:21:51.798 No. 32, which doesn't have a Docket number. 02:21:51.974 --> 02:21:55.650 really, under this kind of litany of words, I think 02:21:56.190 --> 02:21:59.782 bring this up under ERCOT oversight. So at 02:21:59.806 --> 02:22:03.250 the last ERCOT board meeting, I start a bit of firestorm 02:22:03.330 --> 02:22:06.858 by talking about what work should be done 02:22:06.914 --> 02:22:11.106 here and what should be done at ERCOT and 02:22:11.258 --> 02:22:15.034 specifically mentioning NOGRR245. And so I 02:22:15.042 --> 02:22:18.674 just kind of want to have that discussion with you all and with 02:22:18.722 --> 02:22:22.186 staff around how we make that determination, 02:22:22.338 --> 02:22:25.794 what that looks like specific to maybe to 245. 02:22:25.962 --> 02:22:29.540 Barksdale, you and I had discussed this somewhat before the board meeting, 02:22:29.580 --> 02:22:32.772 so just kind of want to discuss it because I think there was some confusion 02:22:32.876 --> 02:22:35.908 about what I said, which is not surprising, given that I was thinking of it 02:22:35.924 --> 02:22:39.036 on the fly so. Thanks, 02:22:39.068 --> 02:22:43.124 Chairman. (item:32:Barksdale English on rule changes) I think 02:22:43.292 --> 02:22:47.120 the foundation that the Commission before you all, 02:22:47.620 --> 02:22:50.964 and with the previous executive leadership 02:22:51.012 --> 02:22:53.720 has laid here on staff, 02:22:54.310 --> 02:22:58.278 we've been able to develop some pretty 02:22:58.334 --> 02:23:01.822 amazing folks and processes. And I think 02:23:01.846 --> 02:23:05.174 that's evidenced by the fact that just in the last two open meetings, 02:23:05.342 --> 02:23:09.150 you all have reviewed seven, I think rule 02:23:09.190 --> 02:23:11.650 changes, whether they're pfas or pfps, 02:23:12.430 --> 02:23:14.890 in addition to VOLL, PCM, 02:23:15.470 --> 02:23:19.262 just some. The markets team, the rules 02:23:19.286 --> 02:23:23.036 in the projects team, they're doing 02:23:23.108 --> 02:23:26.596 a tremendous volume of work, but the consistency 02:23:26.708 --> 02:23:30.800 and the quality of that work has only improved despite that volume. 02:23:31.180 --> 02:23:35.240 That's not to say that workload is sustainable forevermore, 02:23:35.940 --> 02:23:39.724 but I have confidence in our staff's ability 02:23:39.852 --> 02:23:43.220 to take some of these more difficult policy 02:23:43.300 --> 02:23:46.530 items that you were referencing at the board meeting, chairman, 02:23:47.070 --> 02:23:51.494 and bring them here and develop a good way for 02:23:51.622 --> 02:23:55.566 the Commission, for the five of you to lay 02:23:55.598 --> 02:23:59.446 your hands on those issues and provide guidance to ERCOT and 02:23:59.478 --> 02:24:02.982 to the rest of the market to make some better 02:24:03.046 --> 02:24:06.486 technical decisions, provided the policy direction 02:24:06.518 --> 02:24:10.774 that you all provide so 02:24:10.862 --> 02:24:14.502 specific processes to handle. Something like 245. 02:24:14.646 --> 02:24:18.130 I think that's a conversation that we need to continue to develop 02:24:19.150 --> 02:24:22.622 and exactly what form that wants to 02:24:22.646 --> 02:24:25.942 take. I think there are a few different options. And as soon 02:24:25.966 --> 02:24:29.010 as her returns from her much needed vacation, 02:24:29.550 --> 02:24:32.750 I know she and Connie and I will spend a lot of time 02:24:32.790 --> 02:24:36.422 talking about exactly what that process might want to look like. And we'll 02:24:36.446 --> 02:24:39.654 come back to you probably 02:24:39.702 --> 02:24:42.784 in the middle or end of September, if that's all 02:24:42.792 --> 02:24:46.336 right, to talk about some more specific steps. Absolutely. No, 02:24:46.408 --> 02:24:50.096 that timeline works for me. Commissioners, obviously, we haven't had a chance to talk about 02:24:50.128 --> 02:24:54.020 it post board meeting, so be interested in any thoughts you all have about 02:24:54.960 --> 02:24:58.048 the move to maybe bring some of this work back to the Commission that's kind 02:24:58.064 --> 02:25:00.900 of been outsourced or cotton over the years, 02:25:03.040 --> 02:25:06.118 I guess. I think that we are in 02:25:06.134 --> 02:25:09.262 a growing stage now with kind of the new roles at ERCOT and the new 02:25:09.286 --> 02:25:13.334 board at ERCOT. We've had this, you know, we've historically given 02:25:13.382 --> 02:25:16.846 everything to them. And being able to bring some of that back, 02:25:16.878 --> 02:25:20.650 I think is important. I think as we staff up, we build up the 02:25:21.230 --> 02:25:24.366 intellectual capacity here to do it and the tools 02:25:24.398 --> 02:25:28.010 necessary for us to do our job better and really believe that that's 02:25:29.390 --> 02:25:32.832 a positive, a positive for the PUC. So I'm 02:25:32.856 --> 02:25:36.344 supportive of doing that where it makes sense. 02:25:36.512 --> 02:25:39.864 I don't have a bright line as to what it should be right across the 02:25:39.952 --> 02:25:43.088 board. But I do think that we should err on 02:25:43.104 --> 02:25:46.740 the side of bringing it back here. I support 02:25:47.560 --> 02:25:49.700 general paradigm, you know, 02:25:50.640 --> 02:25:54.128 re, I guess, calculation in terms of, like, I don't 02:25:54.144 --> 02:25:57.380 have a bright line either. (item:32:Commissioner Cobos on NOGRR245) But I think where I. 02:25:57.870 --> 02:26:01.310 The issues involve major policy 02:26:01.390 --> 02:26:05.430 calls, not just on reliability, but on 02:26:05.470 --> 02:26:08.598 cost impacts to our Texas consumers, 02:26:08.774 --> 02:26:12.814 that our mission is reliability and cost. And to the extent 02:26:12.862 --> 02:26:16.046 that there are big policy calls that 02:26:16.078 --> 02:26:19.974 involve those two very important factors, 02:26:20.142 --> 02:26:23.210 I think that we should be more involved, 02:26:23.560 --> 02:26:26.528 rather, in the front end and definitely in the back end. 02:26:26.584 --> 02:26:30.080 So, you know, I know NOGRR245, 02:26:30.120 --> 02:26:33.656 for instance, has a lot of, at least the second piece 02:26:33.688 --> 02:26:36.856 of it, the bifurcation process. And I do want to commend ERCOT for all their 02:26:36.888 --> 02:26:39.752 work in the first part of it. I think it was a great success to 02:26:39.776 --> 02:26:42.900 get a settlement on that first piece of it. 02:26:43.200 --> 02:26:46.648 The bifurcation and the exemption process will be 02:26:46.664 --> 02:26:50.190 much more contested. And ultimately, 02:26:51.330 --> 02:26:54.434 if it gets appealed to the commission, we're going to be basically, 02:26:54.562 --> 02:26:57.298 you know, not able to talk to each other and not able to talk to 02:26:57.314 --> 02:27:01.350 ERCOT. And it's just not a great position to be in and 02:27:02.890 --> 02:27:06.910 on a policy issue that I think warrants 02:27:07.770 --> 02:27:11.818 better deliberation and or 02:27:11.874 --> 02:27:15.036 feedback from ERCOT and stakeholders. So I think 02:27:15.068 --> 02:27:19.396 that that may be an area that would benefit from commission 02:27:19.508 --> 02:27:23.244 rulemaking. So we could just set the process forward and 02:27:23.332 --> 02:27:26.644 obviously, with some involvement in ERCOT running the exemption process, 02:27:26.732 --> 02:27:29.680 but it's kind of like we did with weatherization. Right? 02:27:30.500 --> 02:27:33.116 We set the framework and ERCOT runs the framework, 02:27:33.308 --> 02:27:37.320 and their technical expertise will be invaluable in evaluating 02:27:37.820 --> 02:27:41.174 those requests. (item:32:Commissioner Jackson on NOGRR245) So I 02:27:41.182 --> 02:27:44.902 think you bring up a very good point preferenced by 02:27:45.046 --> 02:27:48.750 the change that we're seeing across Texas and the growth. And so, 02:27:48.830 --> 02:27:52.294 you know, more than ever, it's important that we utilize the 02:27:52.382 --> 02:27:55.758 resources at the Commission as effectively as we can and 02:27:55.774 --> 02:28:00.062 the resources that are caught as effectively as we can. And certainly, 02:28:00.126 --> 02:28:03.790 you know, when we have issues that impact the state, 02:28:03.910 --> 02:28:07.298 we need engagement and involvement from both. And I 02:28:07.314 --> 02:28:10.602 think what we're kind of thinking out as change is occurring, you know, 02:28:10.626 --> 02:28:13.858 how do we manage that change and how do we, you know, 02:28:13.954 --> 02:28:17.314 utilize the best resources at the most appropriate time? 02:28:17.482 --> 02:28:21.710 And so, you know, having a very well defined 02:28:22.250 --> 02:28:25.410 work plan, knowing and understanding what those deadlines 02:28:25.450 --> 02:28:29.738 are, knowing and understanding exactly what each entity 02:28:29.794 --> 02:28:32.940 is going to be responsible for in doing, I think, 02:28:32.980 --> 02:28:36.756 always gives you a much better outcome. I mean, we're about managing risk 02:28:36.908 --> 02:28:40.492 and about managing change. And so I think this 02:28:40.516 --> 02:28:44.012 is an excellent approach and always good to have a process 02:28:44.116 --> 02:28:47.492 and always good to have it driven by data and 02:28:47.516 --> 02:28:51.572 policy. I agree. I think that 245 02:28:51.596 --> 02:28:55.120 as the example, is a major policy discussion that should be 02:28:55.540 --> 02:28:58.892 had here at the commission. That is nothing. Say that obviously the 02:28:58.916 --> 02:29:02.332 process that is at ERCOT with those committees that have that in 02:29:02.356 --> 02:29:05.348 depth knowledge is something that we aren't still seeking that will be built into the 02:29:05.364 --> 02:29:08.940 process, obviously, that we're building to have that feedback from the stakeholders. 02:29:08.980 --> 02:29:12.924 So absolutely. I think especially on the technical aspects of these policies. 02:29:13.012 --> 02:29:15.924 Definitely. And forgive me if my comments, 02:29:16.012 --> 02:29:19.596 Commissioners may have implied that 02:29:19.628 --> 02:29:23.044 we were going to leave stakeholders out. In fact, you know, 02:29:23.052 --> 02:29:26.698 I've had met with Caitlin Smith, the Chair of the Technical Advisory Committee, 02:29:26.754 --> 02:29:30.658 to talk about how some of this might look. And I believe 02:29:30.714 --> 02:29:35.426 TAC is going to have a workshop on kind of the 02:29:35.458 --> 02:29:38.914 overarching issues of how decisions are made between ERCOT and 02:29:38.922 --> 02:29:42.498 the commission. I think they have decided to 02:29:42.594 --> 02:29:46.002 move the previously scheduled workshop that I think 02:29:46.026 --> 02:29:48.952 was supposed to happen next week on September 5. I think they're actually going to 02:29:48.986 --> 02:29:51.680 take it up at the regular TAC meeting on the 19th. 02:29:52.540 --> 02:29:56.260 So I'll be attending that meeting and look forward 02:29:56.300 --> 02:30:00.092 to engaging with stakeholders and stakeholder 02:30:00.156 --> 02:30:04.252 leadership as well to try to help make sure that we're coordinating 02:30:04.316 --> 02:30:07.760 and being seamless and thoughtful about our deliberations. 02:30:08.260 --> 02:30:11.908 Thank you, Barksdale, and thanks for the time you've spent talking to me about how 02:30:11.924 --> 02:30:15.232 we can move forward and figuring out how to right size, you know, where the 02:30:15.256 --> 02:30:19.376 work is. Mister chairman. I might say that as 02:30:19.408 --> 02:30:22.888 many of you all know, NERC has this issue in front of 02:30:22.904 --> 02:30:27.140 them as well for the rest of the country. But their modifications 02:30:28.840 --> 02:30:32.192 in these resources apply to us, even though it's. 02:30:32.296 --> 02:30:36.260 They don't. FERC, of course, doesn't have jurisdiction, but NERC does. 02:30:36.760 --> 02:30:39.420 And they are expediting their rules for, 02:30:40.850 --> 02:30:44.002 for IBRs. So we just need to keep that 02:30:44.026 --> 02:30:47.910 in mind as to when we're looking at this second phase. You know, 02:30:48.250 --> 02:30:50.802 we don't want to spend all of the time and resources to go down the 02:30:50.826 --> 02:30:54.642 road, have it get done, and then have them overturn, you know, 02:30:54.666 --> 02:30:57.770 the ability for us to do that. Absolutely. Okay. 02:30:57.930 --> 02:31:01.914 Thanks. Look forward to the works. Thank you, Barksdale. All right. 02:31:01.962 --> 02:31:05.066 (item:34:Chairman Gleeson lays out Project No. 56793) That'll bring us to items 34 and 35. 02:31:05.098 --> 02:31:09.236 I'm going to call them up together. That is Docket No. 56793, 02:31:09.308 --> 02:31:12.476 issues related to the disaster resulting from Hurricane Beryl. 02:31:12.588 --> 02:31:16.452 (item:35:Chairman Gleeson lays out Project No. 56822) And Docket No. 56822, investigation of emergency preparedness 02:31:16.476 --> 02:31:20.156 and response by utilities in Houston and surrounding areas. I think 02:31:20.188 --> 02:31:22.964 we have an update from staff. Connie? Yes. 02:31:23.012 --> 02:31:27.252 Thank you, chairman. Just a few updates on 02:31:27.396 --> 02:31:29.200 both projects. 02:31:31.830 --> 02:31:35.246 (item:35:Connie Corona on RFI deadlines & next update, 56822) RFIs in the investigation are due tomorrow, 02:31:35.318 --> 02:31:38.806 and we have already received several responses that staff is beginning 02:31:38.838 --> 02:31:42.582 to look at. We'll have an investigation 02:31:42.646 --> 02:31:46.810 update for you at the next open meeting on September 12. 02:31:48.590 --> 02:31:52.742 (item:34:Connie Corona with date for PUC's Houston workshop, 56793) We have set a time and location for our Houston workshop. 02:31:52.926 --> 02:31:56.050 It will be held at 09:00 a.m. on Saturday, 02:31:56.390 --> 02:31:59.624 October 5 at the Harris County Department of Education 02:31:59.792 --> 02:32:03.744 Ronald W. Reagan Building. It will be in the fifth floor conference 02:32:03.792 --> 02:32:07.220 center and it will be a commission led workshop. 02:32:09.320 --> 02:32:13.152 (item:35:Connie Corona on working with CenterPoint on their list of commitments, 56822) The investigation team is working with CenterPoint on the 02:32:13.176 --> 02:32:16.320 comprehensive list of commitments that we discussed at the last 02:32:16.360 --> 02:32:20.460 open meeting, including what should suffice as 02:32:21.000 --> 02:32:25.130 supporting documentation for having completed, completed each of those commitments. 02:32:25.670 --> 02:32:29.910 (item:34:Connie Corona on Staff attending CenterPoint Open Houses, 56793) And finally, we have a staff attended 02:32:29.990 --> 02:32:33.790 each of Centerpoint's open houses so far, and they appear 02:32:33.830 --> 02:32:36.250 to have been well received in the community. 02:32:37.070 --> 02:32:40.050 I thought I saw Commissioner Glockfield hit one on social media. 02:32:40.550 --> 02:32:44.718 Oh, I didn't know that. I was, I did attend one. 02:32:44.894 --> 02:32:48.530 I tried to go incognito, but it didn't work so well. 02:32:51.620 --> 02:32:53.320 It was in Waller, Texas. 02:32:54.980 --> 02:32:58.692 You know, there were a handful of executives there, which was nice to talk to, 02:32:58.716 --> 02:33:01.676 but it was really nice to talk to the folks around the table, their head 02:33:01.708 --> 02:33:05.148 arbiter and some other folks that really are involved in the day 02:33:05.164 --> 02:33:08.468 to day management of their issues. So I 02:33:08.484 --> 02:33:11.956 think they're clearly knowledgeable and understand, you know, what their 02:33:11.988 --> 02:33:15.822 roles are. And I think the most, 02:33:16.006 --> 02:33:19.342 the thing that I took away more than anything was as they 02:33:19.366 --> 02:33:22.410 were talking to consumers. 02:33:22.910 --> 02:33:26.390 They showed humility. They want to make it better. 02:33:26.470 --> 02:33:29.662 They want to fix it. They don't want to be in the situation that they 02:33:29.686 --> 02:33:32.970 were, that they were in. So I applaud that. 02:33:33.590 --> 02:33:36.918 Absolutely. So thank 02:33:36.934 --> 02:33:40.302 you, Connie, for following back up on our prior discussion on the how for 02:33:40.326 --> 02:33:43.512 the action items. I have had discussions with Centerpoint. I think they're 02:33:43.536 --> 02:33:47.264 planning to file a response to my question from last open 02:33:47.312 --> 02:33:51.032 meeting today, and then we'll get that and take a look and 02:33:51.216 --> 02:33:54.656 see where we go from there. But thank you all for working on that. 02:33:54.728 --> 02:33:56.860 And that's all I have. 02:33:59.720 --> 02:34:01.980 Okay. Thank you. Thanks, y'all. 02:34:03.000 --> 02:34:06.360 Okay. (item:39:Chairman Gleeson opens up item for update from Executive Director) So the last item I have is Item 02:34:06.400 --> 02:34:09.604 No. 39. That's ED and Commission Counsel 02:34:09.692 --> 02:34:13.844 update. I have just a couple housekeeping 02:34:13.892 --> 02:34:17.412 items for the update. (item:39:Connie Corona on elevator badge readers and PUC open seating) The first 02:34:17.476 --> 02:34:20.940 one being you all may 02:34:20.980 --> 02:34:24.628 have noticed as you rode the elevator up here today 02:34:24.684 --> 02:34:28.480 that we'll now that there are badge readers in each of the elevators 02:34:29.580 --> 02:34:32.980 at some point in the not distant future, 02:34:33.360 --> 02:34:36.728 those will make the elevators accessible 02:34:36.864 --> 02:34:40.264 only to staff who work here in the Travis 02:34:40.312 --> 02:34:43.928 building. That means that it 02:34:43.944 --> 02:34:47.928 will be a little more complicated getting up here for open 02:34:47.984 --> 02:34:53.088 meetings and other meetings. So staff 02:34:53.144 --> 02:34:56.660 will need to badge people up for the open meetings. 02:34:57.240 --> 02:35:01.690 We'll have someone station downstairs to take care of that. But just 02:35:01.730 --> 02:35:05.898 be aware that that may happen before 02:35:06.034 --> 02:35:09.850 an upcoming open meeting. Can we take volunteers 02:35:09.890 --> 02:35:13.002 from the audience to get, like, a guest badge and badge people up? 02:35:13.026 --> 02:35:16.178 Like Katie and Shane are laughing. Look very 02:35:16.234 --> 02:35:19.522 eager to stand down now. Okay. Are we going to have some 02:35:19.546 --> 02:35:21.670 guardrails as to who we're going to let up? 02:35:24.280 --> 02:35:26.568 I'm pleased to know that's for all of us. I just thought it was for 02:35:26.584 --> 02:35:27.660 the 12th floor. 02:35:30.320 --> 02:35:34.696 Yeah. We're going to be drafting people and 02:35:34.728 --> 02:35:38.780 then just, just a very friendly reminder that 02:35:39.360 --> 02:35:42.608 the seats here in the Commissioner's hearing room, in the audience, 02:35:42.744 --> 02:35:45.780 are general admission. They're not reserved seating. 02:35:46.080 --> 02:35:49.184 So we have a couple 02:35:49.232 --> 02:35:52.880 seats reserved for guests that the Commissioners have invited 02:35:52.960 --> 02:35:56.240 to address them, typically for ERCOT, but other 02:35:56.280 --> 02:35:59.696 than that, there are no reserved seats in the commissioner's hearing. Well, 02:35:59.728 --> 02:36:03.128 except y'all have, like, a platinum badge, so. Well, absolutely. 02:36:03.184 --> 02:36:05.860 Anybody who wants to come sit up here is more than welcome. 02:36:08.040 --> 02:36:11.360 All right, Commissioners, anything else? Thank you. 02:36:11.480 --> 02:36:14.616 All right. (item:39:Chairman Gleeson adjourns meeting) With there being no further business before us, this meeting of the Public 02:36:14.648 --> 02:36:16.240 Utility Commission of Texas is adjourned.