PUCT defers decision on protocol revision re: battery state of charge

On November 21, 2023, the ERCOT Board of Directors approved several market revisions, including Nodal Protocol Revision Requests (NPRR) 1184 and 1186, along with System Change Request (SCR) 824. PUCT staff recommended the approval of these revisions, emphasizing their significance in enhancing ERCOT's operations. NPRR 1186 focuses on the State of Charge (SOC) for energy storage resources (ESRs), intending to enhance awareness, accounting, and monitoring until Real-Time Co-Optimization (RTC) is implemented.

Commissioner Glotfelty filed a memo on November 29, opposing the approval of NPRR 1186. He argued that the NPRR had not been adequately studied and justified, characterizing it as a proposed solution searching for a problem. Glotfelty expressed concerns about potential operational limits and compliance fines imposed on storage resources, especially when ERCOT has not established protocols for real-time fuel availability for thermal plants.

Commissioner Glotfelty recommended alternatives, including: 1) initiating a rulemaking to evaluate the SOC issue, 2) delaying approval until the Independent Market Monitor evaluates its impact, 3) deleting the penalty provisions, or 4) outright rejecting NPRR 1186.

During the open meeting discussion, Staff highlighted the rapid growth of batteries in ERCOT's portfolio, with over 14 GW expected by 2024. NPRR 1186 was presented as a response to this growth. Staff argued that this requirement offers real-time visibility into the capabilities of batteries, which is crucial for ERCOT's control room.

Commissioner Cobos acknowledged the increasing importance of energy storage facilities, particularly batteries, in addressing peak demand and solar ramp downs. She emphasized the need to maintain reliability during high peak demand periods and expressed concerns about barriers to battery participation in ancillary services.

Commissioner Glotfelty contended that NPRR 1186 could be discriminatory against batteries, suggesting that existing market mechanisms and penalties for non-performance are sufficient. He argued against ERCOT imposing command-and-control measures on batteries' SOC.

ERCOT's Vice President of System Operations, Dan Woodfin, defended NPRR 1186, stating that it designates characteristics of products for a clear understanding between ERCOT and ESR providers. He highlighted evidence of noncompliance based on ERCOT's Business Practices document.

The Commission ultimately voted to approve NPRR 1184 and SCR 824 but postponed the discussion on NPRR 1186 until the next open meeting. Commissioner Cobos expressed the need to evaluate options thoroughly, considering the potential impacts on storage facilities and ancillary services.

In summary, the discussion revolved around the approval of ERCOT rule revisions, particularly NPRR 1186, with stakeholders expressing differing opinions on the necessity and implications of the proposed changes. The Commission's decision to postpone a decision on NPRR 1186 reflects the need for further evaluation and consideration of potential impacts on the rapidly evolving energy landscape.