ERCOT Protocol Revision Subcommittee Meeting Notes - 12/15

Agenda

1.     Antitrust Admonition

2.     TAC Update

a.     TAC met on December 4^th and approved NPRR1181 (regarding coal and lignite inventory), NPRR1201 (regarding resettlement and default uplift adjustments) and NPRR1204 (regarding SOC with RTC).

b.     They approved the withdrawal of NPRR1203 regarding DRRS, as well as the two associated OBDRR’s.

3.     Project Update

a.     ERCOT presentation posted and given.

b.     Stakeholders asked about the priority of various revisions, and ERCOT noted that their resources are tight, but there are a few implementations that are running ahead, like SCR819.

4.     Review PRS Reports, Impact Analyses, and Prioritization (Vote) (*) denotes no impact

a.     SCR825, ERCOT Voice Communications Aggregation

                                               i.     ERCOT needs another month to complete this IA.

5.     Revision Requests Tabled at PRS (Possible Vote)

a.     NPRR956, Designation of Providers of Transmission Additions

b.     NPRR1070, Planning Criteria for GTC Exit Solutions

c.     NPRR1162, Single Agent Designation for a QSE and its Sub-QSEs for Voice Communications over the ERCOT WAN

d.     NPRR1170, Capturing Natural Gas Delivery Information for Natural Gas Generation Resources

                                               i.     Joint commenters filed comments regarding notifications associated with fuel supply disruptions. ERCOT supports these comments.

                                             ii.     Recommended for approval as amended by the 11/28/23 Joint Commenters comments, on the combo ballot

e.     NPRR1179, Fuel Purchase Requirements for Resources Submitting RUC Fuel Costs – URGENT

                                               i.     WMS endorsed this earlier in December. ERCOT indicated that all of the ERCOT and stakeholder comments seem to be resolved.

                                             ii.     A question was asked about why the IA wasn’t being brought back to PRS, however, this was granted urgency in May.

                                            iii.     Recommended for approval as amended by the 11/28/23 ERCOT comments, on the combo ballot

f.      NPRR1180, Inclusion of Forecasted Load in Planning Analyses

g.     NPRR1188, Implement Nodal Dispatch and Energy Settlement for Controllable Load Resources

h.     NPRR1190, High Dispatch Limit Override Provision for Increased NOIE Load Costs

i.      NPRR1191, Registration, Interconnection, and Operation of Customers with Large Loads; Information Required of Customers with Loads 25 MW or Greater

j.      NPRR1194, Wholesale Storage Load Auxiliary Netting

                                               i.     Stakeholders recommended rejection because the matter is a legal issue. STEC objected to rejection because the Planning Interpretation Request is not a viable path.

                                             ii.     Rejected via individual ballot

k.     NPRR1195, Resource Entity Metering Facilities Maintenance

                                               i.     This is sponsored by STEC and was endorsed at WMS earlier this month.

                                             ii.     Recommended for approval as submitted, on the combo ballot

l.      NPRR1197, Energy Storage Resource (ESR) Non-Charging Load(s) Optional Exclusion from EPS Netting Arrangement

m.   NPRR1198, Congestion Mitigation Using Topology Reconfigurations

n.     NPRR1199, Implementation of Lone Star Infrastructure Protection Act (LSIPA) Requirements

                                               i.     Numerous comments have been filed. ERCOT spoke to theirs, which incorporate numerous comments from Market Participants through their comments, or during the workshop.

                                             ii.     Joint Commenters of generators supported ERCOT’s efforts to make changes and summarized their other comments which seek to align the NPRR to the NERC CIP requirements and the LSIPA language. They would like to see the knowledge qualifier carried though into the attestation form. They also addressed the purchases and potential to track transaction history of procured items, and the affiliate definition. The affiliate definition currently proposed is the PURA definition, which is very broad. They’ve proposed qualifying it based on who could actually access an item through their affiliate.

                                            iii.     Oncor touched on their comments. They also challenged the requirement to track manufacturing of components because that is beyond the statute and impossible to track.

                                            iv.     The current sticking points ERCOT has include: deleting maintenance from being a ‘service’, exclusion of upstream affiliates (particularly with regard to manufactured items that are resold), the affiliate line of business exclusion and other affiliate definition aspects, and what the knowledge criterion should be.

                                              v.     ERCOT stated that their timeline is to get this to the February Board. They originally requested urgency, and they would like to have some offline meetings and be ready to produce an additional set of comments for the January PRS.

o.     NPRR1200, Utilization of Calculated Values for Non-WSL for ESRs

p.     NPRR1202, Refundable Deposits for Large Load Interconnection Studies

q.     NPRR1205, Revisions to Credit Qualification Requirements of Banks and Insurance Companies

r.      NPRR1206, Revisions to QSE Operations and Termination Requirements, and Elimination of Providing Certain Market Participant Principal Information

                                               i.     Recommended for approval as amended by the 12/14/23 ERCOT comments as revised by PRS, on the combo ballot

s.     NPRR1209, Board Priority – State Of Charge Ancillary Service Failed Quantity Allocations under NPRR1149 – URGENT

                                               i.     ERCOT presentation posted and given, to show a spreadsheet of specific examples of how NPRR1209 works in tandem with NPRR1149.

                                             ii.     A stakeholder asked whether there was going to be an allowance for clawbacks due to telemetry issues. The short answer from ERCOT was no. They agree that for a unit that is not available, there could be an issue with a failed quantity and AS failure to perform. However, when telemetry is coming incorrectly to quantify the amount of AS produced and it isn’t sending proper AS signals due to failed telemetry that the incorrect telemetry results in the inability to provide AS, which is why those disputes are usually automatically denied unless the telemetry issue on in ERCOT’s end.

                                            iii.     A question was asked about the ability to transfer AS obligation between batteries that are owned by the same QSE’s. If they are in the same sub-QSE it’s quick to transfer the obligation, but if they are in different sub-QSE’s the transfer is more cumbersome, because these look like different entities in some of the ERCOT calculations. Between different sub-QSE’s the transfer has to be done through an AS trade and there are limitations on how/when that trade an occur. Conversely, when they are in the same sub-QSE or QSE, the entity just has to update their telemetered information. The group discussed the reasons why entities choose to structure as different QSE’s or sub-QSE’s. ERCOT commented that IF there is a desire for their systems to account for separate QSE’s differently to allow such transfers more readily, that is a larger discussion to be had.

                                            iv.     Some commenters raised questions about how thermal resources are treated when it comes to failed quantities and failure to provide AS, and whether the proposed treatment of ESR’s is equivalent. ERCOT noted that NPRR1170/1149 give an equivalent requirement for thermal resources, because NPRR1170 requires thermal to telemeter ahead of time. They stated that this is similar to the requirement here in NPRR1209. ERCOT is also trying to layer-in Load Resources and the ongoing consumption and ability to perform their AS load reduction into the AS process.

                                              v.     Stakeholders indicated discomfort with voting on this revision until the commission finishes its discussion on NPRR1186.

t.      SCR826, ERCOT.com Enhancements

u.     SCR827, Grid Conditions Graph Addition for Operating Reserve Demand Curve (ORDC) Level

6.     Review of Revision Request Language (Vote)

a.     NPRR1207, Incidental Disclosure of Protected Information and ECEII During ERCOT Control Room Tours

                                               i.     ERCOT has proposed an addition to ECEII, that covers allowable visitors that enter the ERCOT Control Room who have been vetted and background checked.

                                             ii.     Recommended for approval as submitted

b.     NPRR1208, Creation of Invoice Report

                                               i.     This is for invoice reports at the counterparty level to help QSE’s to understand and track all pending invoices. It was reviewed and agreed at CFSG.

                                             ii.     ERCOT stated that they are neutral on this, but agree with the language.

                                            iii.     Recommended for approval as submitted

c.     NPRR1210, Next Start Resource Test and Load-Carrying Test Frequency

                                               i.     ERCOT drafted this because they saw a challenge with meeting the NERC requirement for testing. Stakeholders asked what the concern is, and ERCOT answered that they have to test units every 5 years, but that can be a challenge due to the procurement schedules. The concern isn’t necessarily the reduction from 5 years to 4 years, but generators are still evaluating this.

                                             ii.     BSWG has reviewed this, and didn’t have significant comments. Other stakeholders suggest that ROS should review it.

                                            iii.     Tabled on the combo ballot and referred to ROS

d.     NPRR1211, Move OBD to Section 22 – Methodology for Setting Maximum Shadow Prices for Network and Power Balance Constraints

                                               i.     Recommended for approval as submitted

e.     NPRR1212, Clarification of Distribution Service Provider’s Obligation to Provide an ESI ID

                                               i.     This is to ensure that before a resource can come online that the ESIID is in place and ready to avoid unaccounted for energy.

                                             ii.     A stakeholder asked RIWG to review this to allow tweaking of some of the language.

                                            iii.     Tabled on the combo ballot

f.      NPRR1213, Allow DGRs and DESRs on Circuits Subject to Load Shed to Provide ECRS

                                               i.     This revision is to allow distributed resources to be able to provide ECRS. ERCOT is okay with a portion of ECRS coming from these resources, meaning that they wouldn’t obtain frequency response from distribution resources, and that the appropriate percentage of DGR’s in AS will be determined in future AS Methodologies.

                                             ii.     Recommended for approval as submitted

Combo Ballot

g.     Ballot approved

7.     Other Business

Adjourn