ERCOT Reliability and Operations Subcommittee Meeting Notes - 1/5

Agenda

1.     Antitrust Admonition

2.     Membership Introductions

3.     Election of 2023 ROS Chair and Vice Chair (Vote)

a.     Chase Smith - Chair

b.     Katie Rich – Vice Chair

4.     Agenda Review

5.     Approval of ROS Meeting Minutes (Vote)

a.     December 1, 2022

6.     Technical Advisory Committee (TAC) Update

a.     ROS leadership provided a verbal update. All three revisions ROS sent to TAC were approved.

b.     CSAPR NOx Season Allowance Discussion

                                               i.     Generators requested that the group give some thought to how this will impact ERCOT before the rule is finalized because the implementation time line for the rule will be very short, if the rule is approved.

                                             ii.     ERCOT was asked whether they are planning to perform any studies of the impacts to the generation fleet of the proposed rule. ERCOT responded that they have done some preliminary work in this area, but it is not public. They will discuss internally whether to do a broader study.

                                            iii.     ROS leadership proposed workshop between ROS and WMS. WMS leadership agreed.

                                            iv.     Sierra Club pointed out that the proposed rule looks at both NOx and also SO2.

                                              v.     It was not clear when the EPA will take action on this proposed rule, but ROS leadership stated that a previous update had stated that the rule might go into effect as soon as spring 2023.

c.     Calculating Loads/Load Shedding in Real-Time (related to NOGRR243)

                                               i.     TAC referred this to ROS. GCES spoke to say that they would like to see the real-time load shed tables considered, in lieu of the two seasonal tables (which was why TAC referred it).

                                             ii.     GSEC is leading the discussion on this issue and encourages those who want to participate in the discussion to weigh in. Updates of those stakeholder discussions will be provided to ROS.

7.     ERCOT Reports

a.     Operations Report  

                                               i.     From the Operations Report:

1.     The unofficial ERCOT peak load for the month was 53,308 MW and occurred on 11/09/2022, during hour ending 16:00.

2.     There were 2 frequency events.

a.     A frequency deviation where a small loss of generation on 11/18 was raised by stakeholders because of the duration of the recovery. ERCOT will bring information about this event next month.

3.     There were 8 instances where Responsive Reserves was deployed.

4.     There were 20 HRUC commitments.

5.     There were 18 days of congestion on the North Edinburg to Lobo GTC, 17 days on the West Texas Export GTC, 17 days on the Panhandle GTC, 14 days on the Treadwell GTC, 13 days on the Nelson Sharpe to Rio Hondo GTC, 10 days on the North to Houston GTC, 10 days on the East Texas Export GTC, 10 days on the Valley Export GTC, 9 days on the McCamey GTC, and 1 day on the Wharton GTC. There was no activity on the remaining GTCs during the month. There were 2 DC Tie Curtailments for the DC_R due to forced or unplanned outages.

6.     1 OCN issued for taking manual action on the WESTEX IROL due to topology change

7.     1 AAN issued for possible future emergency condition

8.     1 Advisory issued due to the unavailability of the Voltage Security Assessment tool.

9.     There was also a question about schedule errors in Section 6. The amount flips from one value to the other, which could be the result of a natural data issue or something behavioral that may need to be further examined. ERCOT will look at this.

                                             ii.     ERCOT provided a verbal update on the December weather event.

1.     Thankfully ERCOT didn’t have the issues that other areas of the country did, but they are still examining the event. There were some generators that tripped off or encountered gas restrictions.

2.     RFI’s will be going out to generators that had outages or fuel supply issues during the event. A timeline for the RFI’s was not known yet, but the turn-around time will be short.

3.     Commenters raised questions about the load forecast and the fact that the actual load came in almost 10GW over the already conservative load forecast. They requested that ERCOT include this issue in their analysis. It was already on ERCOT’s list for examination.

4.     Commenters also requested information on how the Firm Fuel Supply Service was used during the event.

b.     System Planning Report  

                                               i.     ERCOT is currently reviewing proposed transmission improvements with a total estimated cost of $347.95 million as of November 30, 2022.

                                             ii.     Transmission Projects endorsed in 2022 total $2.957 billion as of November 30, 2022.

                                            iii.     All projects (in engineering, routing, licensing, and construction) total approximately $11.093 billion as of October 1, 2022.

                                            iv.     Transmission Projects energized in 2022 total approximately $1.198 billion (as of October 1, 2022).

c.     ERCOT Update on Implementation of Amendments to PUC Rule 25.101 in Project No. 53403

                                               i.     ERCOT presentation posted and given regarding the key changes in the rule. They also discussed NPRR1070.

                                             ii.     ERCOT was asked how the new congestion cost savings (CCS) test would differ from the generator revenue reduction (GRR) test. ERCOT stated that they plan to hire a consultant to look at how the test should be structured and to work with stakeholders.

                                            iii.     ERCOT was asked if they can provide a guidance document showing how the GRR test will work. ERCOT answered that they are following the old criteria that was removed from the protocols in 2011.

                                            iv.     It was pointed out that the RTP did not include the GRR. Starting with 2023 the RTP will incorporate both the GRR and PCS tests.

                                              v.     In the evaluation of cost:benefit for economic projects, based on October 2020 numbers, the first-year revenue requirement that will apply in the PCS will equate to 13.2% of capital costs. For the GRR, the average of the first three years of revenue requirement equates to 12.9% of capital costs.

                                            vi.     ERCOT was asked to think about what assumptions are going to be used in the GRR test for solar and battery facilities. They will bring this back when they scope the RTP. Currently for the PCS, the software can dispatch solar based on LMP.

                                           vii.     ERCOT pointed out that in the past they have included some resiliency in the RPG reviews, however, the process for how they will implement the resiliency “plus factor” is new.

                                         viii.     ERCOT will be sponsoring a PGRR to cover the mechanics of the grid reliability and resiliency assessment. They anticipate having the first study completed by December 2024.

                                            ix.     ERCOT suggested keeping NPRR1070 on hold. Stakeholders asked why we wouldn’t just reject this revision. The sponsor (EDFR) spoke to say that they appreciated that the Commission addressed most of the components of NPRR1070 in the PUC rule, but they wants to see the draft language for the relevant revision requests prior to withdrawing (or rejecting) this NPRR.

                                              x.     ERCOT was asked when they plan to file the required revision requests. They need to look at how to line up the timing for this process and the associated revisions. They expect the main discussions to occur and be led at PLWG.

d.     Operational issues related to Energy Storage Resources (ESRs)

                                               i.     ERCOT presentation posted and given. These are topics that they covered at PDCWG and WMWG in the fall, and they were asked to give a high-level presentation here. There are several common issues that affect ESR performance and their ability to perform in BP’s.

                                             ii.     Stakeholders expressed an interested in being able to move around AS obligations between resources.

                                            iii.     ERCOT intends to plan an ESR workshop in the coming months.

8.     ROS Revision Requests (Vote)

a.     Language Review

                                               i.     PGRR103, Establish Time Limit for Generator Commissioning Following Approval to Synchronize

1.     The sponsor, ERCOT, introduced the revision request. The purpose of the revision is to require Interconnecting Entities to complete all conditions for commercial operation of a Generation Resource or Energy Storage Resource (ESR) within 180 days of receiving approval for Initial Synchronization from ERCOT.

2.     Projects get into the Part 2 or Part 3 of the synchronization process and stall. There 53 units and 11,180MW capacity that have not met the timing requirements for Part 3 requirements. There are some projects (18 projects, 3,137MW) have been in this status for two years. The majority of these projects are wind units. It is likely that most of the projects that haven’t completed the process haven’t completed the testing requirements.

3.     Stakeholders suggested that this may be the result of commercial decisions, and that some projects are testing in good faith. Supply chain issues complicate the issue.

4.     Stakeholders asked about the timing expected for correcting issues. ERCOT stated that there is an unofficial 30-day time frame, but commenters noted the extremely long supply chain issues that can mean getting some components before others, or the long time to replace a component that fails. ERCOT stated that after 180 days the issue would be referred to the compliance department, but it was not certain how the Compliance group would proceed.

5.     It was also suggested that it is possible to split the interconnection into parts that are ready to energize/synchronize and those that aren’t. The ones that aren’t ready due to supply chain issues would go onto a new request.

6.     It was pointed out that projects that are doing this are getting paid for the energy they are producing already, without completing the synchronization process. ERCOT needs to motivate them, with potential compliance action, to complete the process.

7.     This may have issues that are relevant for WMS as well as ROS and PLWG. WMS is asked to consider the potential market mechanisms that would motivate projects to complete the process.

8.     Stakeholders with concerns or thoughts we encouraged to provide written comments.

9.     Tabled and referred to OWG and PLWG on the combo ballot

9.     Revision Requests Tabled at ROS (Possible Vote)

a.     PGRR073, Related to NPRR956, Designation of Providers of Transmission Additions

b.     NOGRR230, WAN Participant Security

                                               i.     This has been tabled to allow TWG to discuss it. It was concluded that they didn’t have the right group on the call to discuss the heavy telecom aspects of this change.

                                             ii.     One idea that was raised was to put out an RFI to see what the implications are. ERCOT is trying to get this RFI out in the next couple of weeks.

                                            iii.     Remains tabled

c.     NPRR1150, Related to NOGRR230, WAN Participant Security

                                               i.     Same comments as above for NOGRR 230

d.     The group was asked for an update on NPRR956, but one was not available. This will go on next month’s agenda.

Break

10.  Operations Working Group (OWG)

a.     Presentation posted and given by OWG leadership.

b.     NPRR1070, Planning Criteria for GTC Exit Solutions (OWG/PLWG) (Possible Vote)

                                               i.     Left tabled based on ERCOT’s presentation regarding the PUC 25.101 rule.

c.     NOGRR215, Limit Use of Remedial Action Schemes (OWG) (Possible Vote)

                                               i.     Remains tabled at OWG, pending further discussion

                                             ii.     LCRA filed comments on this revision. Their comments regard conversations that are occurring to help craft changes to this revision. Work continues.

11.  Combo Ballot (Vote)

a.     Ballot passed

12.  Inverter Based Resources Task Force (IBRTF)

a.     There is a FERC notice of rulemaking for IBR’s and they are beginning to give direction to NERC. The NERC IBR performance subcommittee has become very active and they will be starting an EMT task force.

b.     The 2022 NERC Odessa Disturbance Report was filed yesterday at NERC and there was a webinar. ERCOT is reviewing the recommendations in the report.

c.     ERCOT is also finalizing the ride through NOGRR, and it should be filed in the next few weeks.

13.  Network Data Support Working Group (NDSWG)

a.     NDSWG requested approval of leadership for 2023. ROS will review TF and WG leadership at the February 2023 meeting.

14.  Dynamics Working Group (DWG)

a.     Verbal update provided by DWG leadership. They have selected 2023 leadership.

15.  Black Start Working Group (BSWG)

a.     Presentation posted and given by BSWG leadership.

16.  Steady State Working Group (SSWG)

a.     Presentation posted by SSWG leadership.

17.  Other Business

a.     2023 ROS Goals

                                               i.     Discussion of the 2023 goals will begin next month, in tandem with WMS and TAC goal discussions. ROS members were asked to review last year’s goals in advance on next month’s meeting.

b.     2023 Working Group and Task Force Leadership

                                               i.     As mentioned above, ROS will consider TF and WG leadership nominations next month. TF’s and WG’s are asked to submit nominations.

c.     NPRR1156, Priority Revision Request Process and NPRR1157, Incorporation of PUCT Approval into Revision Request

                                               i.     The group was made aware that these NPRR’s have been filed. These are likely to require changes to some of the guides for which ROS is responsible.

d.     Review Open Action Items List

                                               i.      

e.     No Report

                                               i.     Operations Training Working Group (OTWG)

                                             ii.     Performance Disturbance Compliance Working Group (PDCWG)

                                            iii.     Planning Working Group (PLWG)

                                            iv.     Steady State Working Group (SSWG)

                                              v.     System Protection Working Group (SPWG)

                                            vi.     Voltage Profile Working Group (VPWG)

18.  Adjourn