Dec 04, 2023 Technical Advisory Committee

LEADER, A CONS, SOMEONE THAT HELPED BRING PEOPLE INTO THE FOLD, EVEN IF YOU, IF HE BARELY MET YOU, MADE YOU FEEL LIKE YOU WERE IMPORTANT AND PART OF THE, PART OF THE PROCESS, PART OF THE SOLUTION, AND, AND, AND BROUGHT YOU ALONG.

THANKS, BILL.

I SEE NED, I PROBABLY CAN'T SAY ANYTHING NEARLY AS ELOQUENTLY AS BILL JUST DID, BUT, UM, YOU KNOW, ONE THING THAT THAT HAS ALWAYS STOOD OUT TO ME IS HOW CONSISTENT THE, UH, THE MEMORIES OF BRAD WERE AS BEING A, YOU KNOW, A, A

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AND, UH, THAT'S A, A RARE SET OF TALENTS, BUT, UM, SOME THAT, THAT WERE, UH, GREATLY VALUED AND WILL BE GREATLY MISSED.

AND, UM, I, I'D BE REMISS IF I DIDN'T JUST MAKE A PUBLIC SERVICE ANNOUNCEMENT ABOUT THE, UH, MEMORIAL, UM, SCHOLARSHIP FUND FOR TEXAS TECH THAT'S BEEN SET UP IN HIS, IN HIS MEMORY, AND ENCOURAGE FOLKS TO, TO DONATE TO THAT.

UM, I PROBABLY CAN'T SAY TOO MUCH WITHOUT TEARING UP, BUT I JUST WANNA ECHO WHAT'S BEEN SAID AND, UH, REFLECT FONDLY ON SOMEONE WHO HAD SUCH AN OUTSIZED IMPACT ON THE WORLD.

HE'S A REMARKABLE PERSON AND FATHER AND FRIEND, AND HE GAVE ME SO MANY GREAT WITNESS TRAINING STORIES OF WHAT EXACTLY NOT TO DO THAT ONLY BRAD JONES COULD PULL OFF.

WELL, BRAD AND I MET LONG TIME AGO, BACK WHEN WE FIRST STARTED TO TRY TO DESIGN THIS MARKET AFTER SENATE BILL SEVEN.

AND I THINK A LOT OF IT'S BEEN SAID ALREADY.

UH, BUT YOU COULD SIT THERE, YOU COULD ARGUE WITH BRAD UP AND DOWN, BACK AND FORTH, AND RESPECT WAS ALWAYS MAINTAINED THROUGH THAT ENTIRE PROCESS.

AND I THINK THAT'S ONE OF THE THINGS THAT IS, WAS WONDERFUL ABOUT BRAD.

HE WOULD LISTEN TO YOU, ARGUE WITH YOU, AND WE'D COME TO A GOOD DECISION.

AND I, FOR 1:00 AM SORELY MISSING.

BRAD, GO AHEAD WITH ME.

THANK YOU, BOB.

I COMPLETELY AGREE WITH EVERYONE.

WE ALL WILL MISS THE GREAT SMILE AND THE COMFORT HE BROUGHT TO A LOT OF US.

HE WOULD ALWAYS WELCOME ANYONE NEW AND WITH A GREAT SMILE AND MAKE US FEEL SPECIAL AND WOULD GIVE LIKE, UNDIVIDED ATTENTION WHEN WE WANT TO COMPLAIN TO HIM OR FIGHT WITH HIM, OR WORK TOGETHER TO BRING A SOLUTION.

UH, HE HAS BEEN ALWAYS BRINGING THAT POSITIVITY AND, UM, THAT WARM HEART, UH, TO ANY, ANY OF THE GET TOGETHERS OR DISCUSSIONS AND WILL MISS ALL OF THAT GREAT FRIEND.

THANK YOU, REMI.

KENAN, DID YOU WANNA, OBVIOUSLY, UH, BRAD ALSO WAS A VERY SPECIAL AND INFLUENTIAL PERSON AT ERCOT.

HE, UH, HAD TWO STINTS WITH US, UM, MADE AMAZING CONTRIBUTIONS AND BROUGHT A LOT OF JOY AND LAUGHTER TO THE FOLKS, UH, AT ERCOT.

AND THEN THE OTHER THING I WOULD JUST SAY IS LIKE, IN SOME OF OUR DARKEST MOMENTS, HE WAS OUR SHINING LIGHT, UH, YOU KNOW, AS WE WERE TRYING TO DEAL WITH THE AFTERMATH OF, UH, WINTER STORM URI.

SO I'VE CERTAINLY, UH, MISS HIM, UH, EVERY DAY AND, UH, UH, APPRECIATE ALL THAT HE'S DONE FOR E EVERYBODY IN THIS ROOM AND IN THE INDUSTRY AND ERCOT INCORPORATED AS WELL.

THANK YOU, KENAN.

UM, I DON'T SEE ANY OTHER CARDS, BUT, BUT I'LL GIVE EVERYONE JUST A A MINUTE TO PAY THEIR RESPECTS AND THEN WE CAN GET STARTED.

HEY, THIS IS MIKE WISE ON THE PHONE.

HI, MIKE.

GO AHEAD.

YEAH, REAL QUICKLY, UH, I'D LIKE TO CHIME IN.

UH, BRAD, UH, HE AND HE AND I GO BACK, UH, WELL BEFORE THE, THE MARKETS ACTUALLY BEGAN IN THE NINETIES.

AND, UH, BRAD, AS OTHERS HAVE SAID, ALWAYS HAD A GREAT SMILE, VERY INTELLIGENT, AND TAUGHT ME, UH, ABOUT WHOLESALE MARKETING IN, IN ERCOT BEFORE IT WAS REALLY, UH, A BIG DEAL.

BUT I ALWAYS TRIED TO KNOCK BRAD OFF OF HIS, HIS, UH, POSITIVE DEMEANOR AND HIS BALANCE.

AND I NEVER COULD GET HIM OFF HIS BALANCE OR HIS, UH, OPTIMISM, UH, REMARKABLE MAN.

UH, WE BECAME GOOD FRIENDS AND, UH, UH, HE HELPED ME THROUGH, UH, ALL OF THE DIFFERENT CHANGES IN THE MARKETS, UH, AS I WAS TRYING TO NAVIGATE MY WAY THROUGH AS WELL.

SO, UH, YEAH, I AGREE WITH MANY OF THE OTHERS.

UH, BRAD IS, IS ONE OF THE CORE REASONS THAT WE HAVE WHAT WE HAVE TODAY AND, UH, SURE APPRECIATED HIS FRIENDSHIP AND HIS MEMORY WILL, WILL LINGER AND, AND GO ON.

AND, UH, I'M SURE THAT MANY OF US WILL REFLECT UPON HIM AND MENTION HIM TO OTHERS AS, AS TIME GOES ON, AS WELL AS BEING

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ONE OF THE, THE GODFATHERS OF, UH, OF OUR MARKET.

SO, UH, THANK YOU VERY MUCH.

THANKS, MIKE.

AND THANK YOU EVERYONE.

UM, I, I SHARE SOME OF THOSE MEMORIES.

I KNOW WHEN I STARTED IN THE INDUSTRY AT THE IMM, IT WAS AROUND WHEN HE STARTED HIS FIRST STINT AT ERCOT, AND HE, YOU KNOW, THE, WHAT RINGS TRUE IS HOW HE INCORPORATED NEW PEOPLE AND, AND REALLY TAUGHT THEM.

HE, HE SPENT A FULL DAY WITH ME SORT OF INTRODUCING ME TO ALL THE DIFFERENT DEPARTMENTS OF THIS ORGANIZATION AT ERCOT.

UM, SO, SO I HAVE A LOT, UH, TO THANK HIM FOR, AND I SEE THAT NED HAS POSTED THAT SCHOLARSHIP FUND IN THE CHAT.

UM, AND, AND THANK YOU EVERYONE FOR SHARING YOUR MEMORIES.

WITH THAT, UM, I THINK WE CAN GO AHEAD AND GET STARTED ON OUR AGENDA.

I DO NOT SEE RICHARD, BUT ON THE, THE LIGHTER NOTE, IF RICHARD IS ON THE PHONE, UM, YOU, YOU CAN DO YOUR THEME OF DECEMBER IF YOU'D LIKE.

HE'S HERE.

WE'LL GET BACK TO RICHARD.

HIS BAG IS HERE.

HIS, HIS BAG IS NOT PREPARED.

WHAT'S THE THEME OF THE WANT? UM, SO THE FIRST AGENDA ITEM IS THE MINUTES.

WE, I'M, YEP.

SORRY.

I, I TRIED TO POST ON THE CHAT TO GET IN THE QUEUE, BUT, UH, I, UM, I DON'T KNOW WHAT ALL TO SAY ABOUT, ABOUT BRAD FRIEND.

HE WAS, I HAD THE PRIVILEGE OF CALLING ON HIM IN NEW YORK AND TALKING TO HIM WHEN HE WAS CEO UP THERE.

AND WHILE WE HAD A STORM YURI HERE, HE HAD ALL KINDS OF POLITICAL STORMS UP THERE THAT HE WEATHERED.

AND THE FUNNY THING ABOUT IT, I WAS SITTING IN HIS OFFICE IN, IN ALBANY, AND YOU'D HAVE PEOPLE COME BY.

SO THESE ARE THE, THIS IS ONE OF THE FAMOUS ERCOT PEOPLE WE HEAR SO MUCH ABOUT.

SO I THINK BRAD WAS AS PROUD OF THE, OF WHAT HAPPENED AT ERCOT AND THE WAY WE WORKED TOGETHER AS WE WERE OF HIM AND HIS LEADERSHIP.

AND SO I DIDN'T WANNA LET THE MOMENT GO BY WITHOUT REMEMBERING THAT STINT.

I MEAN, I, I CAN IMAGINE BEING IN SOME OF THE MEETINGS HE WAS IN WITH CUOMO AND SOME OF THE OTHER PEOPLE UP IN NEW YORK, THE POWER BROKERS THERE, AND, YOU KNOW, HE, THERE'S A WHOLE SIDE OF BRAD THAT WE DON'T REALLY KNOW A WHOLE LOT ABOUT, BUT I'M JUST GLAD TO HAVE KNOWN HIM.

I'M GLAD TO HAVE BEEN MENTORED BY HIM, AND I LOVE THE GUY.

SO THAT'S ALL I NEED TO SAY, I GUESS.

THANK YOU, DON.

WE APPRECIATE THAT.

IS THERE ANYONE ELSE ON THE PHONE OR WEBEX THAT WOULD LIKE TO, TO SPEAK? I ALL RIGHT.

OKAY, SO NOW WE CAN, UM, GET STARTED ON THE, THE MEETING MINUTES.

[2. Approval of TAC Meeting Minutes (Vote)]

UM, WE, THIS WOULD BE A MOTION TO APPROVE, UM, OR TO PUT ON THE COMBO BALLOT THE OCTOBER 24TH MEETING, MINUTES AS PRESENTED.

I, I'M NOT AWARE OF ANY EDITS OR COMMENTS.

CAN, CAN I CONFIRM THAT? ALRIGHT.

UH, IF THERE'S NO OBJECTIONS, WE CAN GO AHEAD AND PLACE THAT ON THE COMBO BALLOT.

SO, UM,

[3. Meeting Updates]

WE HAVE THE MEETING UPDATES.

UM, SO NOW WE ARE ONTO OUR ERCOT MARKET IMPACT STATEMENTS AND ERCOT OPINIONS AND IMM OPINIONS.

UH, THE, THE PUC MET ON NOVEMBER 2ND AND NOVEMBER 30TH.

AT THE NOVEMBER 30TH OPEN MEETING, THEY DID APPROVE NPRR 1184 AND SCR 8 24 REGARDING, UH, NPRR 1186, UH, COMMISSIONER TY HAD FILED A MEMO.

HE REVIEWED HIS MEMO AND CONCERNS THERE.

THERE WAS A VERY LONG AND ROBUST CONVERSATION BETWEEN ERCOT AND PUC COMMISSIONERS.

UH, ULTIMATELY THE, THE PUC DID DELAY THAT DECISION FOR A FUTURE OPEN MEETING.

I, I THINK THIS MAY AFFECT MPR 1209, BUT THAT IS NOT IN FRONT OF US.

THAT IS STILL TABLED AT PRS.

IS THERE ANY DISCUSSION ON, ON THESE MEETING UPDATES HERE AT THIS TIME? ALRIGHT.

[4. Review of ERCOT Market Impact Statements/Opinions and IMM Opinions]

I WILL TURN IT OVER TO ANN FOR ERCOT STATEMENTS AND OPINIONS.

ALL RIGHT, THANKS, KAITLYN.

THIS IS ANNE BOEN.

UM, ERCOT DOES SUPPORT ALL OF THE REVISION QUESTS ATTACK, EXCEPT FOR WE STILL DO NOT SUPPORT NORE 2 45 AND P 1 0 5

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AS RECOMMENDED BY ROSS.

AND THOSE WILL BOTH BE DISCUSSED LATER.

UM, AND I DON'T KNOW IF ANYONE'S HERE FROM THE IMM, BUT THEY DID SUBMIT THEIR OPINIONS.

UM, THEY HAVE NO OPINION ON 1201 RMG, 1 76 NPR 1193, OR PG 1 0 5.

UM, AND THEY DO SUPPORT THE REMAINING REVISION REQUESTS HERE, ATTAC.

THANKS ANN.

WHEN OR SOMEONE FROM THE IMM ARE, ARE YOU HERE? AND WOULD YOU LIKE TO ADD ANYTHING ON THE IMM OPINIONS? HI, THIS IS WEEN FROM THE IMM.

CAN ANYONE CONFIRM THAT THEY CAN HEAR ME? YES.

GREAT.

YEAH, I JUST WANTED TO MAKE, UM, ONE QUICK NOTE ON, UH, WE HAD ORIGINALLY SUPPORTED, UH, NPR 1203 OBDR 49 AND 50, UM, WITH THE, UH, CHANGES TO THAT, UM, I JUST WANTED TO, TO SAY THAT WE'VE ALSO FILED A LETTER, UH, SUPPORTING THE STANDALONE DRRS PRODUCT AND THE DOCKET.

UM, THAT'S IT.

I THINK WE CAN MOVE ON TO THE PRS REPORT.

THANK YOU, WYNN.

[5. PRS Report (Vote)]

NOW.

MARTHA, IF YOU'RE READY, AND I THINK ALL THE ITEMS TODAY ARE UNOPPOSED, SO I WON'T HAVE TO STOP YOU IN THE PRESENTATION.

YOU CAN JUST ROLL THROUGH AND THEN WE CAN TRY TO TACKLE THOSE ON THE, THE COMBO BA BALLOT OR OTHER VOTE.

THANK YOU, CAITLYN.

GOOD MORNING EVERYONE.

MARTHA HENSON FROM ENCORE WITH THE PRS UPDATE.

AS CAITLYN MENTIONED, THERE ARE THREE VOTING ITEMS COMING FROM PRS.

UH, ALL THREE OF THESE WERE UNOPPOSED AND ACTUALLY ALL THREE WERE SPONSORED BY ERCOT.

THE FIRST ONE HERE, 1181, REQUIRES QUEASY TO GIVE ERCOT INFORMATION ABOUT THEIR COAL AND LIGNITE STORES, PARTICULARLY WHEN THOSE INVENTORIES FALL BELOW, UM, LEVELS THAT ARE NEEDED TO SUPPORT CERTAIN REAL-TIME OPERATIONAL LEVELS.

PRS APPROVES SOME COMMENTS THAT LUMINANT FILED TO 1181 IN SEPTEMBER, AND THIS NPRR IS NO IMPACT.

NPR 1280, I'M SORRY, 1201 IS LIMITING ERROR BASED SETTLEMENTS TO A TIMEFRAME OF ONE YEAR, AND ALSO MODIFYING THE DEFAULT UPLIFT FORMULA WITH RESPECT TO CRR TO REDUCE EXPOSURE TO BOTH ERCOT AND CRR ACCOUNT HOLDERS.

THIS NPR HAD AN IMPACT OF 40 TO 70,000 AND HAD A FOUR TO SIX MONTH PROJECT TO IMPLEMENT.

AND LAST HERE IS NPR 1201.

THIS IS ADDRESSING ESR STATE OF CHARGE AND THE RTC PLUS B PROJECT TO PROMOTE AWARENESS A BETTER ACCOUNTING AS WELL AS MONITORING.

THIS ONE WAS GRANTED URGENT STATUS AT PRS TO HELP ENABLE IT TO GET TO THE DECEMBER BOARD MEETING AND WAS APPROVED WITH ERCOT COMMENTS FROM NOVEMBER 3RD.

THE IMPACT FOR 1204 WAS 750,000 TO 1 MILLION, AND PRS RECOMMENDED A PRIORITY OF 2023 IN A RANK OF 235 FOR THIS ONE.

SO THAT GOES THROUGH THE THREE VOTING ITEMS. KAITLYN, I'LL TURN IT BACK TO YOU FOR THE Q AND A.

ALRIGHT, THANK YOU.

AND I BELIEVE ON NPR 1204, WE DO NEED TO VISIT THE BUSINESS CASE OR REVIEW THE, THE BUSINESS CASE THERE.

MM-HMM, .

AND DOES THIS, WE, MY RECOLLECTION IS WE JUST NEED TO REVIEW THESE AS THEY CHANGE, OR IF THEY CHANGE, UM, SINCE 1204 HAS THE LARGE BUDGETARY IMPACT.

I THINK UP TO A MILLION, THEN WE WANNA MAKE SURE THAT WE AGREE WITH THE BUSINESS CASE.

THE ONE YEAR LIMIT ON RESETTLEMENTS, THERE IS A PROVISION THAT, UM, YOU KNOW, EXEMPTS THAT PROVIDES, UH, AN OUT TO THAT HARD LIMIT FOR AN A DR PROCESS, A RESETTLEMENT DUE TO AN A DR.

SO I WILL GIVE EVERYBODY A MINUTE TO, TO REVIEW THIS BUSINESS CASE ON THE SCREEN.

AND THIS IS, AGAIN, DUE TO THE SIZE OF THE IMPACT AND BUDGET WHILE WE DO THAT.

SO WE'D BE LOOKING FOR, UH, MOTIONS TO RECOMMEND APPROVAL OF NPRR 1204 AS RECOMMENDED BY PRS IN THE 11 NINE PRS REPORT.

UM, APPROVAL OF NPRR 1201 AS RECOMMENDED BY PRS IN THE 11 NINE PRS REPORT AND NPR 1181 AS RECOMMENDED BY PRS AND THE 11 NINE PRS REPORT.

IS THERE ANY DISCUSSION ON THAT? I SEE NED, GO AHEAD, NED.

THANK YOU, CAITLIN.

AND, UM, I HAD ONE CLARIFYING QUESTION ON NPRR 1201 THAT I WANTED TO, UM, TO ASK OT, AND THAT IS THAT THE TIMELINE CONSI CONTEMPLATED IN THERE.

WHAT, UM,

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AND SO I JUST WANTED TO MAKE SURE THAT, UH, AND MAKE CLEAR THAT THAT WOULD NOT PREVENT A RESETTLEMENT DUE TO, SAY, A COURT ORDER, UM, THAT EITHER DIRECTED A RESETTLEMENT OR, UM, ALLOWED AN A DR THAT WAS PENDING A COURT ORDER TO, UH, PROCEED.

UM, SO WE CHECKED ON THAT WITH OUR GENERAL COUNSEL, AND THERE'S NO, NO, UH, OPINION THAT THERE WOULD BE ANY IMPEDIMENT, OR MAYBE, LET ME LEMME SAY THAT MORE CLEAR.

THERE WOULD BE NO IMPEDIMENT .

UH, IS, IS THE OPINION.

I APPRECIATE THAT.

AND THAT SEEMED LIKE THAT WAS CLEAR ON THE FACE OF IT, BUT WANTED TO JUST BE CLEAR.

AND IF I COULD ASK THAT, UM, WE JUST, UH, COMMEMORATE THAT POINT IN THE MINUTES FOR THE MEETING, UM, THEN I'D BE HAPPY TO GO AHEAD AND MAKE THE MOTION TO, UH, CAITLIN, ARE YOU LOOKING FOR A MOTION TO PUT ON THE COMBO BALLOT FOR APPROVAL OF ALL THESE? YEAH, I THINK WE DON'T NEED A MOTION FOR THAT, BUT I, I'D LIKE TO PUT THESE ALL ON THE COMBO BALLOT UNLESS SOMEBODY WANTS A SEPARATE BALLOT.

I'D, I'D RECOMMEND PUTTING 'EM ON THE COMBO BALLOT THEN.

KENAN, DID YOU HAVE A COMMENT ON SOMETHING ELSE? NO, I WAS JUST GONNA GIVE ADDITIONAL COLOR TO 1204, BUT IT DOESN'T SEEM LIKE THAT'S NECESSARY.

AND I'LL, I'LL JUST, I THINK PEOPLE ARE READY TO MOVE ON.

ARE YOU SURE? I'M SURE.

SO NOW WE ARE ON TO REVISION REQUEST TABLED AT TECH.

SO WE WILL, UM, PUT THOSE THREE ON THE COMBO BALLOT.

AGAIN, IT'S NPR 1181, NPR 1201, AND NPR 1204, ALL AS RECOMMENDED BY PRS AND THE NOVEMBER 9TH PRS REPORT.

[6. Revision Requests Tabled at TAC (Possible Vote)]

UM, WE HAVE NOUR 2 45, I BELIEVE THERE IS A ERCOT PRESENTATION, MAY, MAYBE A STAKEHOLDER PRESENTATION AS WELL.

WE DID RECEIVE COMMENTS FROM ERCOT AND A NEW IA FROM ERCOT.

ARE WE GETTING A, A PRESENTATION FROM ERCOT, OR I BELIEVE THERE WAS A STAKEHOLDER PRESENTATION AS WELL, ERIC GOFF ON BEHALF OF NEXTERA.

UM, THE STAKEHOLDER PRESENTATION IS IN RESPONSE TO THE ARCHIVE PRESENTATION.

REPRESENT, I'M, I'M SORRY, ERIC, COULD YOU PLEASE CONFIRM WHO YOU'RE REPRESENTING? YEAH, NEXTERA.

THIS IS STEVEN SLY FROM ERCOT, UH, ON THE WEBEX.

CAN YOU HEAR ME OKAY? YES, WE CAN HEAR YOU, STEVEN.

AND PROVIDE DATA TO PLANNERS AND OPERATORS.

ARE WE READY TO PROCEED WITH THIS PRESENTATION? IS IT OKAY? YES, PLEASE GO AHEAD.

ALRIGHT, THANK YOU.

SO THIS IS STEVEN SISE.

I'M A PRINCIPAL SYSTEM OPERATIONS IMPROVEMENT WITH ER, I'LL BE PRESENTING ON NORE 2 45.

UH, THE FIRST THING JUST TO KIND OF GIVE EVERYBODY AN OVERVIEW, I THINK EVERYBODY'S PRETTY FAMILIAR WITH THIS NOER, BUT JUST TO REMIND EVERYONE, UH, THE GENESIS OF, OR CATALYST, I MEAN, FOR THIS PARTICULAR OPERATING GUIDE, REVISION REQUEST WAS MULTIPLE EVENTS THAT WE'VE EXPERIENCED ON THE SYSTEM WHERE INVERTER BASED RESOURCES HAVE FAILED TO RIDE THROUGH NORMAL SYSTEM DISTURBANCES.

UH, WE'VE EXPERIENCED THESE EVENTS, UM, WELL OVER A COUPLE OF DOZEN OVER THE LAST, UH, 10 YEARS, REALLY.

AND WHAT WE'VE SEEN IS THAT THE MAGNITUDE AND FREQUENCY ARE INCREASING AS WE PUT MORE INVERTER BASED RESOURCES ON THE ERCOT SYSTEM.

UH, ERCOT IS NOT UNIQUE TO THIS.

UH, MANY OTHER REGIONS ARE SEEING THESE ISSUES.

UH, ERCOT HAS SEEN, UM, ADDITIONAL IMPACT, WE BELIEVE JUST BECAUSE OF THE LEVEL OF PENETRATION OF I BS THAT WE HAVE ON THE SYSTEM.

AND SO A NOER 2 45 AS PROPOSED, UH, IS MEANT TO ENHANCE CLARITY AND SPECIFICITY OF IBR RIDE THROUGH REQUIREMENTS WHILE ALIGNING WITH THE MOST RELEVANT PARTS OF IEE E 2,800 AND NERC RELIABILITY GUIDELINES.

UH, NERC DID MAKE, UH, RECOMMENDATIONS OUT OF THE TWO ODESSA REPORTS FOR US TO ADDRESS, UH, THE DEFICIENCIES INCLUDING, UH, CONSIDERING ADOPTING NERC RELIABILITY GUIDELINES

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INTO OUR ROLES.

SO NORE 2 45 DOES ADDRESS THAT NERC RECOMMENDATION.

NOW, THIS HAS BEEN, UH, VERY HEAVILY COMMENTED ON NODAL OPERATING GUIDE REVISION REQUESTS.

UH, THERE'S BEEN MULTIPLE MEETINGS, SO THERE'S BEEN QUITE A BIT OF DISCUSSION SINCE THIS WAS ORIGINALLY PROPOSED AT THE BEGINNING OF THE YEAR SINCE THAT TIME, UH, RECENTLY ISSUED ORDER 9 0 1, WHICH WAS DIRECTING HER TO ADDRESS THE SAME RISK THAT NO 2 45 ADDRESSES, UH, SINCE THAT TIME.

ERCOT ALSO BACK IN, UH, SEPTEMBER, LATE SEPTEMBER, ISSUED AN RFI TO OEMS AND RES ON THE ABILITY TO COMPLY WITH TWO SEPARATE VERSIONS.

AND NUMBER 2 45, THE, UH, ROS APPROVED VERSION AND THE ERCOT PROPOSED VERSION, UM, WHICH, UH, THEN YIELDED SOME INFORMATION THAT THIS PRESENTATION WILL BE, UH, ALSO KIND OF HIGHLIGHTING HIGH LEVEL RESULTS FROM THAT RFI AND THE CHANGES WOULD PROPOSE BASED ON THAT.

SO WE CAN GO TO THE NEXT SLIDE, PLEASE.

SOME KEY TAKEAWAYS FROM FERC ORDER 9 0 1.

UH, BASICALLY, FERC ISSUED A DIRECTIVE TO NERC TO DEVELOP NEAR MODIFIED STANDARDS THAT WOULD, UH, REQUIRE APPROPRIATE SETTINGS TO RIDE THROUGH FREQUENCY VOLTAGE SYSTEM DISTURBANCES.

SOME OF THE KEY HIGHLIGHTS OF THAT IS THAT IT MUST PERMIT IBR TRIPPING ONLY TO PROTECT EQUIPMENT AND SCENARIOS SIMILAR WHEN SYNCHRONOUS, UH, GENERATION RESOURCES USE TRIPPING AS PROTECTION FROM INTERNAL FAULTS.

SO THERE'S A GOOD CLARIFICATION THERE.

IT MUST REQUIRE REGISTERED IBR TO CONTINUE TO INJECT CURRENT AND PERFORM FREQUENCY SUPPORT DURING A BPS DISTURBANCE.

MUST A ADDRESS BOTH, BOTH FREQUENCY RIDE THROUGH AND VOLTAGE RIDE THROUGH POST DISTURBANCE, RAMP RATES, PHASE LOCK LOOP SYNCHRONIZATION, AND OTHER KNOWN CAUSES OF IBR TRIPPING OR MOMENTARY CESSATION.

SO, KIND OF ROUNDED OUT, YOU KNOW, SOME KEY THINGS BY LARGE AND OVER 2 45, UM, ACCOMPLISHES THIS.

SO WE'RE VERY WELL MINED, UH, FROM THIS PARTICULAR ASPECT OF THAT DIRECTIVE.

ANOTHER THING THAT FOR CLARIFIED IS THAT IT APPLIES TO NEW AND EXISTING IBR.

SO WE SPENT A LOT OF TIME THIS YEAR DISCUSSING IS THIS JUST NEW OR SHOULD IT BE RETROACTIVE? AND FOR CLARIFIED, IT NEEDS TO BE RETROACTIVE DUE TO THE RISK ON ON THE SYSTEM.

NERC, UH, WAS ALSO DIRECTED THAT THEY SHOULD DETERMINE WHETHER EXISTING IVRS THAT CANNOT BE MODIFIED THROUGH SOFTWARE UPDATES MAY RECEIVE LIMITED EXEMPTIONS.

SO SOME THINGS TO CONSIDER IN THAT, THAT DOES CLARIFY THAT FERC BELIEVES THAT THERE IS SOME LINE WHERE OLDER IBR THAT IT'S GOING TO TAKE, UH, YOU KNOW, NOT JUST EASY CHANGES, UH, THAT NERC SHOULD CONSIDER WHETHER OR NOT THERE SHOULD BE A LIMITED EXEMPTION.

SO THERE'S STILL, IT'S NOT A DEFINITIVE, BUT I THINK THAT THAT ALIGNS WITH A LOT OF THE DISCUSSIONS THAT WE'VE HAD IN OUR STAKEHOLDER PROCESS, WHERE THERE MAY BE A LINE WHERE IT'S JUST UNREASONABLE.

YOU'RE, YOU'RE ASKING THEM THE, THE RESOURCES TO SPEND EXCESSIVE AMOUNTS OF MONEY, AND, UM, IT MAY NOT, THE, THE UNIT CAN'T WITHSTAND THAT.

SO THAT'S A CLARIFICATION FOR US TO CONSIDER.

THE SUBSET OF EXISTING IDRS UNABLE TO MODIFY COORDINATED PROTECTION CONTROL SETTINGS TO MEET BRT REQUIREMENTS.

SO THAT'S ANOTHER THING IS THEY DIDN'T SAY TO DO IT FOR FREQUENCY RIDE THROUGH, BUT FOR VOLTAGE RIDE THROUGH COULD BE CONSIDERED WITHOUT PHYSICAL EQUIPMENT MODIFICATION UNTIL IVRS ARE REPLACED OR UPGRADED.

SO THE THOUGHT PROCESS IS THIS GETS US FAR ENOUGH ALONG WHEN THEY REINVEST, WHEN THEY REPLACE, THEY UPGRADE THAT THEY NEED, THAT'S WHEN THE, UH, EXEMPTION WOULD BE REMOVED.

IT ALSO SAYS THAT NERC MUST DEVELOP RELIABILITY STANDARDS REQUIRING PLANNERS AND OPERATORS TO MITIGATE THE RELIABILITY IMPACTS RESULTING FROM SUCH AN EXEMPTION.

SO IT'S NOT ACCEPTING THE RISK.

THE COMMISSION IS SAYING WHAT RISK NERC THINKS WE SHOULD CONTINUE TO ALLOW FROM EXEMPTIONS MUST BE ADDRESSED AND MITIGATED BY PLANNERS AND OPERATORS.

UM, SO, UH, THAT'S AN IMPORTANT ASPECT TO WHAT WE'RE GONNA DISCUSS A LITTLE BIT MORE IN A MINUTE.

IT ALSO DID DIRECT NEW STANDARDS FOR OWNERS TO INSTALL DISTURBANCE MONITORING EQUIPMENT

[00:30:01]

NOER 2 55 IS LIKEWISE ALIGNED WITH THIS.

AND, UM, WHEN YOU LOOK AT NOER 2 55, THAT'S AT ROS COMING UP THIS MONTH.

UH, THIS'LL BE BEFORE THIS BODY IN THE FUTURE AS WELL.

BUT JUST POINTING OUT THAT, THAT FERC DID ALSO ADDRESS THAT IN THEIR ORDER 9 0 1, HER COMMENTS INDICATE URGENCY, UH, BASED ON THE FUTURE OF IBR PENETRATION LEVELS.

IF YOU LOOK AT COMMISSIONER DAN'S COMMENTS, IT, IT'S REALLY INTERESTING READ, BUT FOR CONTEMPLATED EXEMPTIONS, ASSUMING TIME UNTIL LEVELS REACH A CRITICAL RISK RISK THRESHOLD, AND I THINK THAT ERCOT JUST WANTS TO HIGHLIGHT, WE BELIEVE WE'RE ALREADY AT THE LEVELS THAT THEY'RE PROPOSING WOULD BE ACHIEVED AT, AT 2030 AS FAR AS IBR PENETRATION AND RISK.

SO THAT THAT'S SOMETHING FOR THIS BODY TO KEEP IN MIND AND, AND MAKING DECISIONS THAT WE ARE AT A DIFFERENT LEVEL OF RISK THAN OTHER INTERCONNECTIONS BECAUSE OF OUR PENETRATION LEVELS TODAY.

WE CAN GO TO THE NEXT SLIDE.

LOOKING AT THE RFI RESULTS, I I WANT TO DRAW YOUR ATTENTION TO THE DIAGRAM IN THE UPPER RIGHT HAND CORNER JUST SO THAT THERE'S APPROPRIATE CONTEXT AS WE CONSIDER THIS INFORMATION.

IF YOU LOOK AT THE LEFT SIDE OF THAT DIAGRAM, THE IBR UNIT, OEM, THAT'S WHERE THE OEM IS RESPONDING FOR.

SO THEY'RE VERY ADAMANT THAT THEY CAN ONLY SPEAK TO THEIR EQUIPMENT, BUT YET THERE'S OTHER EQUIPMENT BETWEEN THE INVERTER OR THE WIND TURBINE ALL THE WAY TO THE POINT OF INTERCONNECTION.

AND SO WHEN YOU LOOK AT THE RE RESPONSES, UH, THEREFORE REQUIREMENTS ALL THE WAY TO THE POINT OF INTERCONNECTION BUS.

SO BETWEEN THE, WHILE THE TURBINE AND THE INVERTER ARE ABSOLUTELY A CRITICAL PART, UM, THERE ARE OTHER PROTECTIONS.

THERE ARE OTHER CONTROL SYSTEMS THAT EXIST BETWEEN THE TURBINE AND INVERTER TERMINAL ALL THE WAY TO WHETHER THE POINT OF INTERCONNECTION BUS IS ON THE HIGH SIDE OF THE STEP UP TRANSFORMER OR AT A REMOTE BUS.

SO JUST KIND OF KEEP THAT IN THE BACK OF YOUR MIND AS YOU CONSIDER SOME OF THE RESULTS.

THE OEM RFIS AND PART OF THE REA RFIS ASKED IF IT WAS TECHNICALLY FEASIBLE TO COMPLY WITH THE REQUIREMENTS AND THE ERCOT RECOMMENDED LANGUAGE FROM AUGUST 18TH, 2023.

SO THAT'S WHAT THE TOP TWO, THE TOP, UH, SPREADSHEET REFLECTS.

ONE OTHER THING TO NOTE IS THAT SOME RE RESPONSES MAY REFLECT LATE INFORMATION FROM THE OEMS. WE HAD ONE OE EMM, UH, THAT SUBMITTED A COUPLE OF DAYS LATE.

AND SO WE HAD SEVERAL RESOURCE ENTITIES THAT SAID, YOU KNOW, MY INFORMATION IS BASED ON WHAT I HAVE.

THE OEM HASN'T PROVIDED IT TO ME.

SO THERE'S ADDITIONAL NOS IN THERE WHERE THEY DIDN'T HAVE ANY KIND OF CERTAINTY FROM THEIR RES.

IT'S PROBABLY ABOUT FIVE GIGAWATTS WORTH, UH, FROM THAT PARTICULAR OEM, WE DID GET A FEW, UH, UPDATED RFIS AND WHERE WE COULD, WE, WE, WE UPDATED TO LESSEN THAT I THAT IMPACT, BUT THAT IS PART OF THE DISCREPANCY.

NOW, THERE'S AN APPENDIX, UH, AT THE END OF THIS PRESENTATION THAT I, I WON'T GO ALL THE WAY IN THROUGH, UH, BUT IT DOES KIND OF GO INTO A LITTLE MORE DETAIL ON EACH OF THESE PARTICULAR REQUIREMENTS.

FREQUENCY RIDE THROUGH ON THE LEFT, UH, VOLTAGE RIDE THROUGH ON THE RIGHT AND, UH, WE LINED UP OEMS AND RES.

NOW YOU WILL NOTICE THERE IS A DIFFERENCE IN THE REPRESENTED MEGAWATTS.

UH, WE DID HAVE SOME RESOURCE ENTITIES THAT DID NOT RESPOND.

UH, THE ERCOT RELIABILITY MONITOR DID REQUEST THAT INFORMATION.

WE DID PROVIDE IT TO THE ERM SO THAT THEY UNDERSTOOD WHICH RESOURCE ENTITIES DID NOT COMPLY WITH THE, UH, RFI RE REQUEST IN TIME.

AND, UM, THEY'LL BE DEALING WITH THAT PARTICULAR ISSUE.

THANK YOU FOR EVERYBODY'S EFFORTS IN FILLING THIS INFORMATION OUT.

HOPEFULLY WE ALL SEE THAT THERE IS A BENEFIT TO IT.

UM, BEFORE I TALK ABOUT THE RESULTS AT A HIGH LEVEL, JUST LOOKING AT THE BOTTOM, UH, PARTICULAR SET OF SPREADSHEET TABLES OR CELLS, THE REMAINDER OF THE RE RFI ASKED IF IT WAS COMMERCIALLY REASONABLE TO COMPLY WITH THE REQUIREMENTS AS CAPTURED IN THE ROSS APPROVED LANGUAGE, UH, SEPTEMBER 14TH, 2023.

ONE THING WE WANNA POINT OUT IS THAT THE VRT CURVES ARE MORE STRINGENT IN THE ROSS APPROVED LANGUAGE THAN THE ERCOT APPROVED LANGUAGE.

SO THAT ALSO COMMUNICATES TO WHY SOME

[00:35:01]

ENTITIES MAY HAVE SAID, WE CAN COMPLY WITH, UH, 2 9 1 2, UH, BUT WE CAN'T COMPLY WITH 2 9 1 1.

AND SO THAT'S WHERE, UH, YOU CAN SEE SOME OF THE DELTA.

BUT REALLY JUST THE COLORING IS MEANT TO SAY, YOU KNOW, YOU SEE THE O-E-M-R-F-I RESPONSES IN SOME INSTANCES ARE 99%, AND, UM, THAT REALLY GIVES US A GOOD INDICATION THAT THERE'S THESE REQUIREMENTS CAN BE FAIRLY WELL MET.

THEN WHEN THERE'S A LITTLE BIT LIGHTER SHADING OF GREEN, THE 87%, 86% ON THE CURVES, UH, WE WOULD POINT OUT THAT THAT'S REALLY ONE PARTICULAR OEM, UH, THAT, UH, UH, WE TALK ABOUT IT IN THE, IN THE RESPONSE IN THE APPENDIX.

BUT GE HAS ABOUT 8,200 MEGAWATTS OF OLDER TYPE ONE X MODEL TURBINES THAT THEY SAY, UM, WE CAN'T MEET THE CURVES.

WE'LL TALK MORE ABOUT KIND OF SOME, SOME WAYS WE THINK WE SHOULD ADDRESS THAT IN A LITTLE MORE DETAIL IN A COUPLE OF SLIDES.

BUT THAT'S REALLY THE DRIVER FOR THOSE PARTICULAR AREAS.

AND THEN YOU SEE THE RATE OF CHANGE OF FREQUENCY, MULTIPLE EXCURSION REQUIREMENTS, AND PHAS ANGLE JUMP AS BEING THE MOST CHALLENGING REQUIREMENTS, UH, FOR ANY LEVEL OF RETROACTIVE APPLICATION.

WE'LL TALK A LITTLE BIT MORE ABOUT THOSE IN A MINUTE TOO, BUT THAT'S THE KEY TAKEAWAYS.

YOU HAVE THREE PARTICULAR PARAGRAPHS THAT ARE THE MOST CHALLENGING.

YOU HAVE ONE OEM, UH, THAT IS CHALLENGED TO MEET, UH, THE VRT AND FRT CURVES FOR SOME OF ITS OLDER, UH, WIND TURBINES.

AND BY AND LARGE, THE REST OF THE REQUIREMENTS ARE IN BETTER SHAPE.

NOW, I DON'T WANT TO UNDERMINE ALL THE DETAILS BEHIND IT, UM, WHICH WE TALK ABOUT A LITTLE BIT MORE IN THE APPENDIX, BUT THAT'S A KEY TAKEAWAY HERE.

UH, WHEN WE LOOK AT THE COMPARISON OF THE INFORMATION, AND, UH, WE SEE THAT THE ROSS APPROVED LANGUAGE WOULD REQUIRE MUCH HIGHER LEVELS OF EXEMPTIONS AND, AND THUS RESIDUAL SYSTEM RISK.

AND, AND THAT'S ONE OF THE KEY COMPONENTS ABOUT WHY ERCOT IS OPPOSING, UH, THE ROSS APPROVED LANGUAGE FOR NO 2 45.

WE CAN GO TO THE NEXT SLIDE, PLEASE.

SO WE WANNA TALK ABOUT THE CHANGES THAT WE'RE PROPOSING.

SO BASED ON THE RFI RESULTS, UH, WE'RE GONNA BE PROPOSING REVISED COMMENTS.

UM, REALLY LOOK, COMPARING TO OUR AUGUST 18TH, 2023 COMMENTS OF WHAT WE LAST PROPOSED.

WE'RE GONNA PROPOSE THAT WE ALLOW EXCEPTIONS FOR DOCUMENTED TECHNICAL LIMITATIONS TO BOTH FRT AND VRT CURVES FOR IBR.

UM, WHILE THE COMMISSION DID NOT, UM, MENTION ALLOWANCE OF FRT CURVE, UM, EXCEPTIONS, WE'RE GONNA PROPOSE THAT BECAUSE TO THE BEST OF OUR KNOWLEDGE RIGHT NOW, THOSE EXCEPTIONS WOULD BE VERY LIMITED.

AND ONLY IN, IT'S LIKE THEY MOSTLY MEET THE CURVES, BUT THERE'S JUST A LITTLE PORTION THAT THEY DON'T MEET.

AND THAT PORTION IS UNLIKELY TO REALLY EVER OCCUR ON THE ERCOT SYSTEM.

SO FOR THOSE PARTICULAR SITUATIONS, YOU KNOW, WE WANT TO MAINTAIN THAT, BUT THEN ALLOW SOME DOCUMENTED TECHNICAL LIMITATIONS TO THE VRT CURVES FOR IBR WITH SGIS BEFORE 1 16 14.

NOW, YOU MAY ASK WHY.

WELL, WE'RE NOT CHANGING OUR VRT CURVES IN THE ERCOT PROPOSED VERSION.

SO REALLY, IF YOU WERE TO ALLOW OTHERS TO NOT MEET THE VRT CURVES, UM, THAT HAD AN SGIA AFTER 1 6 4 16 14, THAT ESSENTIALLY MEANS THEY'RE NONCOMPLIANT WITH TODAY'S RULES.

AND SO FOR OLDER SGI THAT CANNOT COMPLY WITH THE VRT CURVES, ALLOW EXEMPTIONS FOR DOCUMENTED TECHNICAL LIMITATIONS.

JUST LET THAT SOAK IN FOR A SECOND.

NOW, THE CAVEATS TO THAT EXCEPTIONS WILL BE GIVEN BASED ON ERCOT.

SO DETERMINATION, UM, IF WE NEED TO PUT BOUNDARIES OR, OR LANGUAGE AROUND THAT, I THINK WE'RE OPEN TO, TO, YOU KNOW, CONSIDERING THAT, BUT WE DON'T FEEL COMFORTABLE WITH THE GENERATORS DETERMINING WHETHER OR NOT THEY HAVE EXCEPTIONS, BECAUSE WHAT WE'RE LOOKING AT IS THAT THEY, THEY SUBSTANTIALLY ARE MEETING THE NEW REQUIREMENTS.

SO WHEN, WHEN WE SAY WE WOULD ALLOW AN EXCEPTION, IT'S LIKE YOU SHOW US YOUR VRT CURVE AND THAT VRT CURVE NOW BECOMES YOUR REQUIREMENTS.

IT'S NOT AN EXCEPTION THAT YOU

[00:40:01]

DON'T, EVERY TIME YOU HAVE A PERFORMANCE FAILURE, YOU DON'T RIDE THROUGH, YOU'RE EXEMPTED.

YOU DON'T HAVE TO DO ANYTHING.

IT'S, HERE'S WHAT YOU CAN DO AND WE'RE GONNA HOLD YOU TO WHAT YOU CAN DO.

WE'RE ALSO GONNA ASK THAT YOU DO MAXIMIZE THE CAPABILITY THROUGH ANY PARAMETERIZATION SOFTWARE UPGRADES, TECHNICALLY FEASIBLE UPGRADE KITS.

UM, BUT, BUT MAJOR REPOWERS RETROFITS WOULDN'T BE REQUIRED.

AND WE HOPE THAT THIS DRAWS THE APPROPRIATE LINE, UM, IN, IN WHAT'S THE RIGHT LEVEL OF RISK MITIGATION AND RISK RETENTION ON THE ERCOT SYSTEM.

UM, THE TECHNICAL LIMITATIONS MUST BE ACCURATELY REPRESENTED IN ALL PROVIDED MODELS.

THIS IS ABSOLUTELY IMPORTANT FOR US BECAUSE THEN WE HAVE TO TAKE THAT WHEN WE DO OUR DYNAMIC STUDIES, WHEN WE DO OUR STEADY STATE STUDIES, WE HAVE TO MAKE SURE THAT WE ARE CAPTURING THAT IF A FAULT OCCURS, NOT ONLY ARE WE GOING TO LOSE THE FAULTED ELEMENT, BUT WE'RE GOING TO LOSE THESE GENERATORS.

AND THEN WE HAVE TO HANDLE THAT IMPACT, UH, WHICH WE'LL TALK ABOUT MORE IN ANOTHER COUPLE OF SLIDES.

BUT WE HAVE TO HAVE IT ACCURATELY REPRESENTED IN OUR MODELS.

WE'RE ALSO GOING TO, UH, PROPOSE THAT WE APPLY OPERATIONAL RESTRICTIONS FOR PERFORMANCE FAILURES TO THE DOCUMENTED LIMITATION THAT POSE SIGNIFICANT RELIABILITY RISK THAT CANNOT BE MITIGATED IN A REASONABLE TIMEFRAME.

SO WE STILL FEEL LIKE IF WE'RE GOING TO HAVE THESE EXCEPTIONS, AND THEN THEY COME BACK AND THEY STILL DON'T PERFORM TO THE EXCEPTIONS THAT THEY TOLD US, THEY, THEY NEED TO STILL MITIGATE IT AND THEY NEED TO MITIGATE IT QUICKLY, UH, AND WE'RE IN A REASONABLE TIMEFRAME SO THAT WE TAKE THAT RISK OFF THE SYSTEM, AND THEN UPON REINVESTMENT, THEY NEED TO MEET THE LATEST REQUIREMENTS, WHICH REALLY ALIGNS WITH WHAT, UH, THE COMMISSION PROPOSED IN FOR QUARTER 9 0 1.

WE ARE GOING TO PROPOSE THAT WE REMOVE THE SPECIFICITY AND CLARITY REQUIREMENTS FOR LEGACY IIV FOR RO COUGH AND PHASING WITH JUMP.

SO THAT REALLY PUTS US BACK AT A STATUS QUO.

AND JUST TO BE CLEAR, OUR STATUS QUO IS THAT IT, IF VOLTAGE AND FREQUENCY ARE WITHIN THE NO TRIP ZONES, THE IBR MUST RIDE THROUGH.

AND SO WE THINK THAT THIS HAS CAUSED, UH, YOU KNOW, SOME GOOD INVESTIGATION, BUT ULTIMATELY, UH, A LOT OF UNCERTAINTY BECAUSE THE, UH, THE, TO MEET THE, WHAT THEY THINK ARE THE REQUIREMENTS, UH, THE OEMS HAVE RAISED ISSUES OF, I DON'T HAVE EQUIPMENT TO TEST IT.

I HAVE TO GO BACK AND TO, YOU KNOW, CHECK ALL THESE THINGS.

AND THEY'RE NOT ACTIVELY MONITORING FOR R COUGH, THEY'RE NOT ACTIVELY MONITORING FOR PHASING JUMP.

SO IN MOST INSTANCES WHERE THEY SAID A NO, IT'S BECAUSE THEY DON'T EVEN DO ANYTHING THERE.

AND FOR THEM TO VALIDATE IT WOULD BE QUITE CUMBERSOME.

AND SO, UM, WE WOULD JUST GO BACK TO THE, THE CURRENT REQUIREMENTS THERE AND REMOVE SOME OF THAT, UM, PARTICULAR LANGUAGE FOR RETROACTIVE APPLICATION, AND THEN MODIFY THE MULTIPLE EXCURSION REQUIREMENTS FOR LEGACY IBR TO MAXIMIZE CAPABILITY IF THEY USE A COUNTER, OR THAT THEY CAN ADJUST THE PARAMETERS TO ENSURE RIDING THROUGH NORMAL TSP RE RECLOSE SCHEMES VERSUS THE CURRENT ALIGNMENT WITH IEEE 2,800.

SO IT'S REALLY, UM, SOFTENING THOSE REQUIREMENTS TO JUST MAKE SURE, UH, IF THEY ARE MONITORING IT, MAXIMIZE YOUR CAPABILITY, DON'T ARTIFICIALLY LIMIT IT, AND THEN IF YOU'RE NOT MONITORING IT, THEN COORDINATE WITH YOUR NORMAL TSPS TO JUST MAKE SURE THAT WHEN THEY, IF THEY RECLOSE TWO TIMES OR THREE TIMES WITHIN A 32ND PERIOD, FOR EXAMPLE, UH, YOU'RE COORDINATED AND YOU DON'T TRIP OFF UNNECESSARILY.

STEVEN, CAN WE TAKE SOME QUESTIONS ON THIS SLIDE? SURE.

UM, I SEE BILL BARNES AND THEN BOB HILTON.

HEY, STEVEN, APPRECIATE THE, UH, WORK ON THIS.

CLEARLY THE RFI PROCESS WAS BENEFICIAL ON SLIDE FIVE, WHEN YOU REFERENCE LEGACY IBR, IS THAT, ARE THOSE THE RESOURCES PRIOR TO JAN 16, 2014? UM, ON ON WHICH SLIDE AGAIN? ON THIS SLIDE? THIS SLIDE YOU JUST REVIEWED? YEAH.

SO FOR LEGACY, WE'RE TALKING ABOUT ANYTHING THAT IS SGIA BEFORE 6 1 23.

[00:45:01]

IT'S A GOOD CLARIFICATION.

BOB HILTON.

YEAH, STEVE, THANKS.

I, UH, WANNA ECHO WHAT BILL SAID.

THANKS FOR WORKING THROUGH THIS, AND THE RFP PROCESS DID HELP OUT AND GIVE US SOME, UH, ADDITIONAL LIGHT ON THE PROCESS.

COULD YOU, COULD YOU GO BACK TO THE, THE SLIDE THAT HAS THE NERC QUALIFICATION, YOU KNOW, THE NERC ISSUES ON THERE, AND IT TALKS ABOUT THERE, WHERE'S THE PARAGRAPH? IT SAYS THAT IF YOU CAN'T FIX IT WITH, UH, SETTINGS TO MEET THE VRT REQUIREMENTS WITHOUT PHYSICAL EQUIPMENT MODIFICATION UNTIL THE REPLACE ARE UPGRADED, AND THEN YOU GO TO FIVE, SLIDE FIVE, AND YOU'RE INDICATING THAT UNDER THAT SECOND BULLET, THE THIRD SUB-BULLET, THAT YOU'RE GOING A LITTLE STRONGER THAN THAT.

THAT IT'S NOT JUST THE SETTING CHANGES WITHOUT PHYSICAL, WITHOUT PHYSICAL CHANGES, YOU'RE ADDING IN SOME PHYSICAL CHANGES FOR, UH, UPGRADE KITS.

AND I'M CURIOUS ON WHAT THE, THE WORD MAJOR REPOWERS AND RETROFITS KIND OF MAKES THE HAIR ON THE BACK OF MY NECK STAND UP A LITTLE BIT ON WHY YOU WOULD SAY MAJOR AND JUST NOT REPOWERS AND RETROFITS NOT REQUIRED.

UH, SO THOSE TWO THINGS SEEM TO BE A LITTLE DIFFERENT THAN WHAT NERC IS SAYING.

SO I JUST WANTED TO BRING THAT UP.

YEAH, I THINK, I THINK THAT'S A GOOD POINT.

AND, UH, I THINK WE ARE SPECIFICALLY BEING, UM, A LITTLE STRONGER WHEN WE GOT SOME RESPONSES FROM THE OM RFIS AND WE HAVE, UH, OTHER CONVERSATIONS AND PRESENTATIONS, YOU KNOW, AT I-B-R-W-G, SOME OEMS, UH, HAVE KITS, THEY HAVE, UM, AVAILABLE UPGRADES, AND THEY'RE READY.

THEY'RE, THEY'RE LIKE, WE'RE JUST WAITING ON CUSTOMERS TO, TO ORDER IT.

UH, OR THEY ALSO HAVE PARAMETERIZATION CHANGES WHERE THEY SAID, WE HAVE A PACKAGE OF CHANGES, WE JUST NEED THE CUSTOMERS TO SAY, COME AND INSTALL IT.

I, I THINK THAT ERCOT HAS LOOKED AT THAT AS THESE ARE REASONABLE AND, AND PROBABLY COST, YOU KNOW, NOT COST PROHIBITIVE SETS OF CHANGES, AND THAT WOULD ENHANCE RELIABILITY.

AND WE ARE AT A HIGHER LEVEL OF IBR PENETRATION, UH, THAN, THAN OTHERS.

SO IF YOU GO BACK TO, TO THE SLIDE ON THE FE QUARTER 9 0 1, I THINK THAT'S WHERE WE, WE HIGHLIGHTED IT'S A MAY RECEIVE BECAUSE I THINK NERC IS BEING ASKED TO LOOK AT THE, OKAY, IF YOU APPLY THIS EXEMPTION, HOW MUCH GETS EXEMPTED AND WHAT'S THAT RISK THAT'S THERE? IS IT BEYOND A, A, A LEVEL THAT THE SYSTEM WOULD BE ABLE TO WITHSTAND? I THINK THE OTHER THING IS THAT, UM, WITHOUT PHYSICAL EQUIPMENT MODIFICATION UNTIL, UH, THE, UH, IT'S REPLACED KIND OF GIVES YOU THAT, THAT LINE THAT UNTIL YOU'RE GOING TO THAT LEVEL, YOU SHOULDN'T BE FORCED TO GET TO THAT LEVEL.

AND SO THAT WE ARE IN OUR PROPOSAL ASKING TO GO BEYOND HERE, UH, IN THIS PARTICULAR INSTANCE TO WHERE IF YOU HAVE AN UPGRADE KIT AVAILABLE, INSTALLED THE UPGRADE KIT.

NOW IF THE UPGRADE KIT IS CHANGING OUT THE ENTIRE CONVERTER, THAT'S NOT WHAT OUR INTENTION IS.

JUST TO BE CLEAR, UH, WE'RE NOT IN, OUR INTENTION IS NOT THAT YOU GO THROUGH AND RIP OUT MAJOR COMPONENTS.

WE'RE THINKING THESE ARE CARDS.

WE THINK THESE ARE, YOU KNOW, MAYBE UPSS, THEY'RE, THEY'RE SMALLER PIECES OF EQUIPMENT THAT CAN BE UPGRADED AND GIVE YOU A, A LARGE RETURN FOR RELIABILITY.

AND WE CAN GO BACK TO THE, THE NEXT SLIDE.

AND JUST TO, TO HIGHLIGHT THE DIFFERENCES AGAIN, ONCE AGAIN, WE'RE PROPOSING TO ALLOW SOME OF THAT FREQUENCY RIDE THROUGH, UM, TO BE, HAVE TECHNICAL LIMITATIONS WHERE FERC DOESN'T.

SO WE ARE DEVIATING FROM THAT AS WELL.

ALL RIGHT, THANKS STEVEN.

BOB, DOES THAT ANSWER ALL RIGHT.

ERIC GUFF, I THINK REAL QUICK, I'M SORRY, BUT BOB HAS A, A, A QUESTION IN THE CHAT, AND I KNOW POWER ELECTRONICS IS ONE WHERE THEY ACTUALLY SENT US A WHOLE SPREADSHEET FOR THEIR DIFFERENT MODELS AND THAT THEY HAVE THOSE KITS AVAILABLE.

[00:50:01]

THAT, THAT QUESTION IN THE CHAT WAS, COULD WE GET NAMES OF OEMS THAT HAVE KITS READY NOW? AND YOU SAID POWER ELECTRONICS IS ONE.

UM, ALL RIGHT.

ERIC GOFF.

UM, ERIC GOFF AGAIN FOR NEXTERA.

UM, BOB, UH, HILTON, UH, JUST KIND OF IN RESPONSE TO YOUR QUESTION, I DO HAVE A PRESENTATION AFTER STEVEN THAT, UH, SHOWS THE RELEVANT SECTIONS OF THE FERC ORDER THAT WE CAN REVIEW TOGETHER.

UM, BUT I JUST WANTED TO STATE, YOU KNOW, THAT THESE PROPOSED MODIFICATIONS FROM STEVEN, UM, ARE, UM, MOVING DIRECTIONALLY IN A WAY THAT I THINK I APPRECIATE.

UM, WE'LL NEED SOME FURTHER CLARIFICATION.

UM, AND, UH, HOPE TO GET THAT FROM THE ETTE COMMENTS, UM, SPECIFICALLY AROUND, UH, WHAT IS AN UPGRADE KIT? UH, DOES IT HAVE A COST COMPONENT OR, OR, UM, HOW IS THAT DEFINED? UM, AND, UM, WE'RE, WE'RE LOOKING FORWARD TO RESPONDING TO THOSE COMMENTS.

UM, I'LL HAVE FURTHER COMMENTS IN A BIT.

UM, BUT, UH, NEXTERA WAS PLANNING TO FILE COMMENTS, UH, FOR TODAY'S, UH, ATTACK MEETING.

AND THEN WHEN WE LEARNED THAT ERCOT WAS REQUESTING A TABLING TO FILE ADDITIONAL COMMENTS, WE, UH, WITHDREW OUR PLANS TO FILE THOSE COMMENTS TODAY SO WE CAN RESPOND TO THE NEXT SET OF COMMENTS.

AND I'LL GET INTO THAT WHEN STEVEN'S THROWING THIS PRESENTATION.

THANKS ERIC.

STEVEN, I DON'T SEE ANYONE ELSE IN THE QUEUE RIGHT NOW.

IF YOU WANNA CONTINUE.

YEAH, THANK YOU.

OH, AND I APPRECIATE PATIENCE.

I SPOKE TO YOU SOON WITH THIS, UM, DAVE RI FROM ENERGY.

I SEE WHAT QUESTION? HEY, SORRY, I THOUGHT I JUMPED IN SINCE WE'RE ON SLIDE FIVE.

UH, STEVEN, JUST, I HAD A COUPLE OF CLARIFYING QUESTIONS.

UM, I MAY HAVE MORE AS YOU GET TO THE FOLLOWING SLIDES, BUT SINCE WE'RE ON SLIDE FIVE, JUST A FEW THINGS AS YOU GO THROUGH THAT WOULD BE HELPFUL TO UNDERSTAND.

UM, IN YOUR SECOND BULLET, THE SECOND SUB-BULLET EXISTING REQUIREMENTS AND NEW REQUIREMENTS, CAN YOU JUST, UM, CLARIFY WHAT YOU MEAN BY EXISTING AND NEW THERE? YEAH, THANK YOU FOR THAT QUESTION.

SO BETWEEN, UM, I THINK IT'S, NO, I KEEP FORGETTING THE DATES.

I THINK IT'S NOVEMBER 1ST, 2008 AND 1 16 14, FOR EXAMPLE.

UH, THEY'RE, THEY HAVE TO MEET THE LOW VOLTAGE RIDE THE REQUIREMENTS, AND MOST OF THE HIGH VOLTAGE RIDE REQUIREMENTS UP TO 0.1, UH, 1.1 INSTEAD OF 1.2 PER UNIT ON THE HIGH VOLTAGE SIDE.

SO THEY CAN'T COME WITH US, COME TO US AND SAY, WE WANT AN EXEMPTION, AND THEY'RE NOT EVEN MEETING THE CURRENT REQUIREMENTS.

SO BETWEEN THOSE TWO DATES OF SGIS, UH, SOME ALREADY HAVE, UH, UH, A REDUCED SET OF VRT CURVE REQUIREMENTS THAT THEY HAVE TO MEET.

THAT'S WHAT I MEANT BY THE, UH, EXISTING REQUIREMENTS ON THE, UH, SUBSTANTIALLY MEET.

AND, AND THERE'S ALSO THE NO MOMENTARY CESSATION RULES THAT ARE IN THERE TOO.

I, I APOLOGIZE.

AND THEN THE SUBSTANTIALLY MEET NEW REQUIREMENTS WE'RE LOOKING FOR, YOU KNOW, THAT THEY, THEY GET PRETTY CLOSE, RIGHT? I I, I KNOW THAT'S A POOR ANSWER, BUT IF YOU LOOK AT A VRT CURVE, ARE THEY GROSSLY , YOU KNOW, HAVE, HAVE NO CAPABILITY SO THAT THEY ARE JUST GOING TO BE TRIPPING OFF ALL OF THE TIME? UH, OR ARE THEY MISSING THE CURVE? YOU KNOW, JUST A LITTLE BIT.

SO THEY'VE MAXIMIZED IT, THEY GET REALLY CLOSE.

I FEEL LIKE WE CAN HAVE A REASONABLE LEVEL OF ASSURANCE THAT WE'VE IMPROVED RELIABILITY BY MAKING THOSE CHANGES.

UH, MAYBE WE JUST DON'T GET ALL THE WAY TO THE EDGE OF THE CURVE.

UM, BUT THAT'S THE TYPE OF THING THAT I THINK WE'RE, WE'RE LOOKING FOR.

UH, WE'RE NOT LOOKING FOR GENERATORS TO COME TO US AND SAY, UH, WE'VE HAD AN EXEMPTION ALL ALONG, WE DON'T FEEL LIKE WE NEED TO DO ANYTHING, SO THANK YOU, BUT PLEASE GIMME MY EXEMPTION.

I THINK WE'RE TRYING TO DRAW THOSE TWO EDGE CASES TO SAY WE'RE NOT COMFORTABLE WITH ONE, BUT WE'RE DEFINITELY GONNA CONSIDER THE OTHER.

JUST, LET ME FOCUS FIRST ON THE CURVES BECAUSE I THINK THAT'S THE EASIEST COMPARISON ONCE AGAIN, BETWEEN, UH, THE 2008 2014 TIMEFRAMES, A NEW REQUIREMENT IS 1.1 TO 1.2 ON THE HIGH VOLTAGE RIGHT THROUGH SIDE.

AND JUST IF I CAN RESTATE IT TO MAKE SURE I UNDERSTAND, SO EXISTING MEANS EXISTING PROTOCOLS WITH ANY APPLICABLE GRANDFATHERING, GRANDFATHERING SUBSTANTIALLY MEET NEW REQUIREMENTS BY NEW, IT SOUNDS LIKE NEW IS IN THE NOGA 2 45 REQUIREMENTS, BUT ARE YOU TALKING ABOUT THE LEGACY REQUIREMENTS AS THEY'RE REFERRED TO IN THE, IN TS NOGA 2 45 OR SOMETHING ELSE? RIGHT, RIGHT.

SO THERE'S, UM, THERE'S, I'M

[00:55:01]

SO THAT'S YOUR NEW REQUIREMENTS THAT YOU HAVE TO ESSENTIALLY, YOU KNOW, SAY, CAN I MEET THAT? CAN I MAKE CHANGES? CAN I ADJUST AND, AND MEET THOSE, THAT CURVE FOR THOSE THAT ARE BEFORE 2008? UM, YOU KNOW, IF I, HERE'S MY CURVES, CAN I MEET FULLY MEET WITHOUT ANY EXEMPTIONS, UH, THE NEW, THE CURVES THAT ARE OUT THERE TODAY AND WILL RECOGNIZE THAT.

SO WHAT IT IS IS INSTEAD OF THERE BEING THIS DISCUSSION AFTER PERFORMANCE FAILURE WHERE WE GET RFI RESPONSES FROM GENERATORS THAT TELL US, UM, I HAVE A FULL EXEMPTION FOR ME TO INVESTIGATE, THIS WOULD COST ME MONEY TO GO AND TALK WITH THE OEM, THEREFORE, I'M NOT GOING TO DO ANYTHING, AND THIS IS A REAL SCENARIO, UM, AND I'M ALLOWED TO TRIP OFF.

WHAT WE'RE GONNA GO TO IS, OKAY, HERE'S YOUR CURVES.

UM, WE RECOGNIZE, OKAY, THE VOLTAGE WAS OUTSIDE OF YOUR CURVE, SO THUS IT EXCEEDED YOUR REQUIREMENTS IN THAT SITUATION.

UH, WE WOULDN'T EXPECT YOU TO HAVE TO GO AND CHANGE ANYTHING OUT.

WE MAY ASK YOU TO, YOU KNOW, ASK THE OEM AGAIN, IS THERE ANYTHING ELSE THAT CAN BE DONE? BUT YOU'RE NOT IN VIOLATION OF THE, THE REQUIREMENTS, BUT IF YOU GAVE US A CURVE AND YOU DON'T MEET THE PERFORMANCE OF THE CURVE THAT YOU GAVE US, THEN YOU WOULD BE IN VIOLATION.

SO THERE IS A DIFFERENCE, YOU KNOW, BETWEEN TODAY AND IN THE FUTURE FOR THEM, BUT IT'S NOT REQUIRING THEM TO GO AND DO ANY KIND OF MAJOR, YOU KNOW, RETROFITS TO MEET THE, THE EXISTING CURVES FOR THEM, WHICH WOULD BE NEW FOR AN OLDER UNIT IN THAT VINTAGE.

I, JUST TO MAKE SURE I UNDERSTAND HERE THOUGH, WHEN YOU SAY NEW, IT SOUNDS LIKE YOU'RE TALKING ABOUT NEW WOULD BE THE CURRENT NON GRANDFATHERED PROTOCOL REQUIREMENTS.

IS THAT RIGHT? CORRECT.

AND ANY NEW CLARIFICATION.

SO LIKE, FOR EXAMPLE, THERE'S, YOU HAVE TO COORDINATE WITH OTHER PROTECTION CONTROLS.

YOU HAVE TO MAKE SURE THAT YOUR, UM, YOU'RE USING FILTERED MEASUREMENTS.

IT'S ALL THOSE OTHER REQUIREMENTS ARE NEW REQUIREMENTS.

UM, BUT WE THINK THAT THE PROBLEM IS GOING TO BE WITH THE CURVES.

THAT'S WHAT WE BELIEVE BASED ON THE RFI RESULTS AND CONVERSATIONS.

SO I, WHEN I SAY NEW, IT IS ENCOMPASSING, BUT I THINK THE NEW PROBLEM THAT IS REALLY FOR THOSE WITH SOME LEVEL OF EXEMPTION MEETING THE CURRENT REQUIREMENTS THAT ARE OUT THERE TODAY ON THE CURVE PORTION.

AND I, I GUESS I, I WOULD ASK THAT IT, WHEN ERCOT FILES HIS COMMENTS THAT ALL OF THIS IS, IS LAID OUT IN SOME DETAIL, OR IF THERE'S AREAS WHERE IT SOUNDS LIKE, YEAH, I, I GUESS THAT THAT'S MY REQUEST.

I MEAN, I APPRECIATE THE CLARIFICATION HERE, BUT I THINK SOME OF THAT, THE DEVIL IN DETAILS WILL BE IMPORTANT TO SEE.

UM, I'LL HOLD UP MY OTHER QUESTIONS UNTIL WE GET FARTHER THROUGH.

WE CAN DELIVER KITS OR, OR UPGRADES TO RETROFIT, BUT WE DON'T WANT TO WAIT TO SYNCHRONIZE AND, AND HOLD OFF, YOU KNOW, THOSE TYPES OF PROJECTS, UH, BECAUSE THE UPGRADE KITS WOULD LAG THE SYNCHRONIZATION DATE.

NO ONE ELSE IN THE QUEUE, STEVEN, YOU CAN KEEP GOING.

ALL RIGHT, NEXT SLIDE PLEASE.

SO WHEN WE'RE TALKING ABOUT NEW, UM, IT, IT SEEMS LIKE IEE 2,800, UH, IT'S STILL GONNA PROVIDE A SIGNIFICANT VALUE, BUT WE'RE THINKING BECAUSE WE SEE SEVERAL OEMS THAT SAY, WE THINK WE CAN MEET IT.

WE, WE THINK WE'RE GOOD.

UM, BUT, YOU KNOW, WE'RE TRYING TO GET THE TESTING AND VERIFICATION, YOU KNOW, NAILED DOWN.

SO IF YOU TEST IT THIS WAY, WE THINK IT'S GOOD, BUT WE'D LIKE TO SEE ERCOT COME, COME FORWARD AND, AND CLARIFY SOME OF THE, THE MODELING AND TESTING REQUIREMENTS.

NOW, WE'VE SAID, QUITE FRANKLY, THAT OUR EXISTING IS WHAT WE WOULD GO WITH AND UNTIL WE CHANGE 'EM, AND THEN, UH, SOME KIND OF SELF ATTESTATION, BUT THAT'S STILL GIVING PEOPLE QUITE A BIT OF PAUSE.

AND WE'VE HAD AT LEAST ONE OEM SAY, WE, WE, WE THINK

[01:00:01]

SO WE'VE PROPO WE'RE GONNA PROPOSE THAT WE ALLOW DOCUMENTED TECHNICAL LIMITATIONS, WHICH WE'VE DONE TO SOME EXTENT, BUT WE WANT TO EXPAND THAT, UM, TO IEEE 2,800 SYNCHRONIZED BEFORE 1 1 26 EXCEPTIONS WILL BE GIVEN BASED ON ERCOT SOIL DETERMINATION.

AGAIN, THEY MUST FULLY MEET LEGACY REQUIREMENTS.

UH, THEY MUST SUBSTANTIALLY MEET THE PREFERRED REQUIREMENTS WITH EACH PLANT'S DOCUMENTED TECHNICAL LIMITATIONS BEING THE NEW SPECIFICITY REQUIREMENTS FOR THAT PARTICULAR PLANT, UH, MUST MAXIMIZE CAPABILITY THROUGH THE USE OF PARAMETERIZATION SOFTWARE UPGRADES, TECHNICALLY FEASIBLE UPGRADE KITS WITH THE, UH, ALLOWED IMPLEMENTATION TIMEFRAMES.

SO ONCE AGAIN, IT'S KIND OF LIKE WE WANT TO HANDLE, UH, THEY'RE GONNA SYNCHRONIZE IN 2025, THE KITS WILL BE AVAILABLE IN 2026 AND THEY'LL INSTALL 'EM IN 2027 TYPE THING.

WE WANNA ALLOW THAT.

UM, SO LONG AS THEY MEET THE, THE CURRENT LEGACY REQUIREMENTS AT A MINIMUM, UH, WE'VE, WE'VE SEEN WHERE, UH, THE, THE OEMS HAVE SAID, WE THINK ERCOT WOULD WANT THIS BECAUSE IT, IT DOES IMPROVE THEIR RIDE THROUGH CAPABILITY.

WE JUST CAN'T FULLY NEED IT.

AND, UH, WE JUST NEED MORE TIME TO DO THAT.

SO WE THINK THAT THAT'S APPROPRIATE.

NOW, WE WOULD STILL ASK THAT THESE LIMITATIONS BE REPRESENTED IN THE MODELS AND THAT WE WOULD APPLY THE OPERATIONAL RESTRICTIONS FOR PERFORMANCE FAILURES.

AGAIN, IF, UM, THEY'RE NOT PERFORMING TO THE LEVEL THAT THEY SHOW US.

UM, SO YOU'RE NOT MEETING YOUR MODEL.

YOUR MODEL SAYS YOU'RE GONNA RIDE THROUGH, YOU DON'T RIDE THROUGH, YOU NEED TO FIX IT.

UM, AND THAT UPON REINVESTMENT, THEY WOULD NEED TO MEET THE LATEST REQUIREMENTS.

AND WE ALSO WOULD REVISE OPERATIONAL RESTRICTIONS TO BE VERY CLEAR THAT, UH, THIS WOULD BE FOR EXPECTATIONS FOR PERFORMANCE FAILURES, DEPOSE SIGNIFICANT RELIABILITY RISK, AND CANNOT BE IMPLEMENTED IN REASONABLE TIME.

UH, AS PROPOSED IN THE ERCOT AUGUST 18TH, 2023 COMMENTS.

ERCOT IS PROPOSING OPERATIONAL RESTRICTIONS FOR TWO THINGS.

ONE IS PERFORMANCE FAILURES.

SECOND, IT'S IF YOU DON'T MEET THE COMPLIANCE TIMELINES OF RETROFIT, UM, AND BEING ABLE TO MEET NUMBER 2 45 RULES.

SO WE WOULD BE PROPOSING TO TAKE OUT NUMBER TWO.

SO IF YOU DON'T MEET COMPLIANCE STATES, YOU ARE IN NON-COMPLIANCE AND YOU DEAL WITH THE COMPLIANCE SIDE, BUT NOT THE OPERATIONAL RESTRICTIONS.

THE OPERATIONAL RESTRICTIONS WOULD BE RESERVED FOR PERFORMANCE FAILURES THAT POSE SIGNIFICANT RELIABILITY RISK.

NOW WE KNOW THAT, UH, GENERATORS ARE UNCOMFORTABLE WITH THIS.

UM, THERE MAY BE SOME, ONCE AGAIN, SOME LANGUAGE, UM, UH, ERCOT ISS GONNA PROPOSE SOME THINGS THAT WE HAVE TO CONSIDER, UH, MOST LIKELY IN THAT PROCESS OF DETERMINING, YOU KNOW, WHETHER TO APPLY OPERATIONAL RESTRICTIONS OR NOT.

WE WANT TO BE TRANSPARENT ABOUT OUR THINKING PROCESS THERE, BUT WE DO THINK IT'S IMPORTANT.

UH, WE HAD SOME OEMS, I'M SORRY, SOME RES, SOME GENERATORS THAT ODESSA EVENT, THEY DIDN'T FIX THE ISSUE TILL 12 MONTHS AFTER.

AND, YOU KNOW, I'M SURE PEOPLE WERE WORKING HARD, BUT IT SURE SEEMED LIKE THAT THAT'S AN EXCESSIVE TIMEFRAME TO ADDRESS, UH, AN OPERATIONAL RISK THAT WE SAW THE UNIT TRIP OFF, UH, FOR FUTURE EVENTS AS WELL UNTIL THEY FIXED IT.

SO WE NEED TO PUT A TIMEFRAME ON THAT.

UH, THEY NEED TO UNDERSTAND THAT GENERATORS NEED TO UNDERSTAND THAT, UM, WHERE YOU'RE AT MATTERS, YOU KNOW, IF YOU'RE NEAR A STABILITY LIMIT, IF YOU'RE NEAR AN IROL, UH, THESE THINGS ARE HEIGHTENED THE RISK AND WE MAY NEED TO ADDRESS THAT RISK THROUGH OPERATIONAL RESTRICTIONS AT TIMES.

UM, WE NEED TO ALSO HAVE SOME OTHER MINOR CLARIFICATIONS.

SO HANDLING OF ACTIVE CURRENT REDUCTIONS DURING A FAULT.

SO GES PUT COMMENTS OUT THERE THAT WE THINK WE NEED TO CAPTURE IN OUR LANGUAGE.

UH, THE S-G-I-S-G-I-A MODIFICATIONS FOR LOAD ONLY ADDITIONS WOULD NOT TRIGGER THE REQUIREMENT TO MEET I EEE 2,800 IF THE IBR DOES NOT NEED PHYSICAL MODIFICATIONS.

SO WE'VE HAD, UH, MULTIPLE PEOPLE COME TO OUR COT AND SAY THAT CLARIFICATION WOULD HELP THAT.

UM, ADDING LOAD AT A SITE DOESN'T TRIGGER MY LOSS OF EXEMPTION.

[01:05:02]

UM, AND SO WE THINK THAT THAT MAY BE APPROPRIATE TO CLARIFY, ALLOW MULTIPLE EXCURSION TRIPS IF THE ENERGY DISSIPATED, EXCEED CERTAIN THRESHOLDS.

UH, THROUGH OUR CONVERSATIONS AT I-B-R-W-G, WE IDENTIFIED ANOTHER, YOU KNOW, REALLY TECHNICAL ISSUE, UH, THAT WILL MOST LIKELY GET CLARIFIED IN FUTURE VERSIONS OF IEE 2,800.

BUT NOW THAT WE COME ACROSS IT, WE PROBABLY WANNA, UH, PUT SOME LANGUAGE IN THERE THAT RECOGNIZES THAT TECHNICAL, UH, LIMITATION AND ACCOUNTS FOR IT AND ALLOWS TRIPS IF, UH, IT'S EXCEEDED.

AND THEN CLARIFY ROW COST AND PHASE, WHICH JUMP REQUIREMENTS TO ADDRESS DIFFERENCES BETWEEN FAULT AND NON-FAT TIMEFRAMES.

I THINK, UH, WE'VE ALSO HAD A LOT OF VERY TECHNICAL DISCUSSIONS AT I-B-R-W-G THAT HIGHLIGHTS REALLY WHAT THE SUBJECT MATTER EXPERTS SAY IS DURING THE FALL, YOU SHOULDN'T WRITE, YOU SHOULDN'T TRIP OFF FOR THOSE PARAMETERS.

UM, NON-FAT TIMEFRAMES, LINE SWITCHING, UH, THOSE TYPES OF THINGS IS, IS REALLY WHAT THE INTENT WAS FOR THOSE PARAMETERS.

AND, UM, YOU KNOW, WE WILL PROVIDE ADDITIONAL CLARIFICATIONS FOR THAT.

WE CAN GO TO THE NEXT SLIDE, PLEASE.

THE RELIABILITY IMPACT.

SO WE WANNA BE VERY, VERY CLEAR ABOUT THIS.

SO IF WE MAKE THESE EXCEPTIONS AND WE'RE ALL COMFORTABLE, WE CAN MOVE FORWARD WITH, UH, WHAT WE FEEL ARE JUST READY AND AVAILABLE UPGRADES AND ADJUSTMENTS.

UH, SO WE UNLOCK THAT IF, IF OWNERS ARE WAITING ON THAT, WHICH WE'VE ASKED YOU NOT TO, BUT IF YOU ARE, WE CAN MOVE FORWARD WITH A, A LOT OF CHANGES THAT WE THINK WOULD BE BENEFICIAL FOR THE SYSTEM ON LEGACY IRS, NOT JUST NEW LEGACY, THEY'RE JUST WAITING.

UM, THE TECHNICAL INFEASIBILITY EXEMPTIONS WOULD NOT REQUIRE CONSIDERATION OF VERY EXPENSIVE UPGRADES, SUCH AS REPOWERS OR CONVERTER REPLACEMENTS.

SO WE THINK THAT THAT WOULD BE A POSITIVE CHANGE FROM THE GENERATOR'S PERSPECTIVE.

UH, WE THINK THAT ALLOWS, IT ALLOWS I BS WITH SGIA BEYOND 6 1 23 WITH CHALLENGES TO IMMEDIATELY MEETING IEE 2,800 A FEASIBLE PATH FORWARD.

SO WE'RE HOPEFULLY ADDRESSING SOME OF THOSE MAJOR, UH, CONCERNS THAT THE GENERATORS SEPARATES.

UH, THE, WHEN YOU LOOK AT WHERE WE STARTED OUT WITH IN JANUARY 1ST, WE HAVE BEEN RESPONSIVE TO ALL OF THE GENERATOR COMMENTS AND WE GOT MORE INFORMATION FROM FERC, WE GOT MORE INFORMATION FROM THE, THE RFIS, AND WE WANT TO JUST CONTINUE THAT.

NOW, THERE IS AN IMPACT AS WE'VE SAID, THIS RISK THAT WE'RE TAKING ON IS OF THE HIGHEST ORDER.

AND I SAY THAT BECAUSE UNCONTROLLED LOSS OF LOAD, UH, THAT COULD LEAD TO INSTABILITY, CASCADING, UNCONTROLLED OUTAGES.

THAT IS AN IMMEDIATE WITHIN SECONDS TYPE OF BAD STUFF THAT HAPPENS ON THE SYSTEM.

AND THAT RELIABILITY RISK CONTINUES, UH, WITH ANY LEVEL OF EXEMPTIONS THAT WE, UH, CAN WE SAY WE'RE GOING TO TAKE.

SO WE WANT TO BE VERY CLEAR ABOUT THAT, THAT EXEMPTIONS MEANS YOU ARE RETAINING THAT, UH, A LEVEL OF THAT RELIABILITY RISK.

WE WANNA ALSO SAY THAT THESE MODELED LIMITATIONS, SO AS YOU MENTIONED, AS WE MENTIONED, YOU HAVE TO MODEL IT, IT MAY IMPACT STABILITY LIMITS.

SO GTLS THAT WE HAVE ON THE SYSTEM MAY BE UPDATED OR ADDED.

WE MAY NEED NEW GTLS.

UM, AS WE RECOGNIZE THESE LIMITATIONS, IF THEY'RE NOT CURRENTLY MODELED, THE IMPACT OF EXCEEDING SOME GTLS MAY QUALIFY THEM AS AN IOL.

SO YOU MAY HAVE CURRENT NON I, NON IROL STABILITY LIMITS THAT ARE NOW IOLS BECAUSE THE IMPACT IS GREATER BECAUSE YOU ARE NOT JUST LOSING A LINE OR LINE IN THE GENERATOR.

NOW YOU'RE MUL LOSING MULTIPLE GENERATORS AS AN IMPACT, SAY, TO A THREE PHASE VAULT.

IT MAY REQUIRE ADDITIONAL TRANSMISSION PROJECTS.

SO THAT'S ANOTHER, YOU KNOW, COST ASPECT THAT EXEMPTIONS CAN CAUSE.

UH, THE OTHER THING IS THAT SOME NEWLY MODELED LIMITATIONS AND REPEATED PERFORMANCE FAILURES MAY REQUIRE ERCOT TO CREATE NEW CREDIBLE CONTINGENCIES.

SO FOR AN EXAMPLE, YOU HAVE, UH, AN N MINUS ONE AND A G MINUS ONE OR G MINUS X, YOU KNOW, HOWEVER MANY THAT IS WHERE WE HAVE TO SECURE THE SYSTEM, YOU KNOW, TO FERC'S, UH, WHAT WE TALKED ABOUT AT FERC ORDER 9 0 1 FERC ORDERED NERC, THAT IF YOU'RE GOING TO ALLOW EXEMPTIONS, YOU HAVE TO MITIGATE THE RISK.

[01:10:01]

AND THIS IS A TECHNIQUE TO MITIGATE THE RISK IS IF YOU KNOW YOU'RE NOT GOING TO RIDE THROUGH, YOU SECURED THE SYSTEM TO BE ABLE TO HANDLE THAT.

AND SO WHAT THAT MEANS IS THAT YOU MAY HAVE ADDITIONAL CONGESTION, YOU MAY HAVE NEW VOLTAGE CASCADING OR INSTABILITY CONDITIONS THAT AREN'T CURRENTLY THERE THAT SHOW UP AS YOU MODEL THESE.

SO WE WANT TO BE VERY TRANSPARENT ABOUT THE IMPACT.

SO WE ALLOW THESE EXEMPTIONS AND THE LEVEL OF EXEMPTIONS MATTERS INTO THE LEVEL OF IMPACTS.

THERE'S A DIRECT CORRELATION THERE.

SO THE, THE KEY TAKEAWAY SHOULD HELP FASTER ADOPTION, UM, BUT AT THE EXPENSE, RIGHT, OF CONTINUED RISK AND THE ASSOCIATE IMPACTS ON THE ERCOT SYSTEM.

SO I SEE WE HAVE A COUPLE COMMENTS IF WE WANNA PAUSE FOR QUESTIONS.

THANKS, STEVEN.

UH, KEVIN HANSON.

YES, STEVEN, UM, YOUR SECOND BOLT THERE HAS ERCOT QUANTIFIED WHAT THEY'RE CONSIDERING.

VERY EXPENSIVE.

I THINK WE'RE GONNA NEED HELP WITH THAT, KEVIN.

UM, YOU KNOW, WE NEED TO HAVE THAT DIALOGUE.

UM, I, I THINK WE ALL REALIZE THAT THERE'S A POINT THERE WHERE IT'S, IT, IT'S TOO, IT'S TOO EXPENSIVE.

I, I DON'T QUITE HAVE, UH, A QUANTIFICATION OF THAT.

AND WE NEED THE GENERATORS TO, UH, TO WEIGH IN ON THAT.

AND WE PROBABLY NEED A COUPLE OF EXAMPLES, RIGHT? WHERE, UM, THEY BALK, YOU KNOW, AT, AT AND UP THIS UPGRADE KIT COSTS, YOU KNOW, $30 MILLION AND THIS UPGRADE KIT COSTS, YOU KNOW, A HUNDRED THOUSAND DOLLARS.

WE NEED TO, WE NEED TO HAVE THOSE DISCUSSIONS.

IT'S GONNA BE HARD FOR US TO, TO COME UP WITH A HARD NUMBER.

UM, BUT WE, WE HAVE TO START WALKING DOWN THAT PATH AND HOPEFULLY WE'RE PUTTING IN A, A FRAMEWORK FOR US TO DO THAT AND BE JUDICIOUS ABOUT THAT IMPLEMENTATION, UM, WITH FLEXIBILITY ON BOTH ENDS.

THANKS, STEVEN.

UH, NEXT IS SETH.

YEAH, THANK YOU SETH, WITH DC ENERGY.

THANK YOU FOR THIS UPDATE.

STEVEN, I HAVE SOME QUESTIONS ABOUT THE G-T-L-G-T-C MODIFICATIONS AND THE CRED, CREDIBLE CONTINGENCIES THAT YOU ALLUDED TO.

UM, SO, SO THE FIRST, WHEN YOU'RE TALKING ABOUT CREDIBLE CONTINGENCIES, ARE THOSE G MINUS ONE CONTINGENCIES, OR WOULD YOU BE MONITORING TRANSMISSION ELEMENTS TO COUNT FOR THIS? SO WE, WE ALREADY HAVE A REQUIREMENT TO CONSIDER ALL, UM, SINGLE CONTINGENCIES IN, IN THE FAC STANDARDS FOR FAC 11 AND FACT 10.

THEY, THEY KIND OF IDENTIFY THOSE MINIMUM CONTINGENCY SETS TODAY.

WE ALSO HAVE PROTOCOLS AND GUIDES THAT, THAT FURTHER CLARIFY THAT.

BUT BY AND LARGE, YOU KNOW, WE, WE HAVE A LOT OF, UH, IN MINUS ONES, WHICH MAY BE A SINGLE CIRCUIT OR A DOUBLE CIRCUIT, BUT THEN THERE'S, IT WOULD BE A COMBINED CONTINGENCY YOU WOULD HAVE, UH, THAT YOU WOULD LOSE THIS.

UH, IT'S LIKE A SPECIAL CONTINGENCY.

YOU HAVE TO CREATE THAT.

WHEN I LOSE THIS TRANSMISSION LINE, I WILL ALSO LOSE THIS GENERATOR OR MULTIPLE GENERATORS.

SO THEY, IT'S A SPECIAL MODELING THAT YOU HAVE TO DO, AND THEN YOU HAVE TO, YOU KNOW, RECOGNIZE THAT AS A, A CREDIBLE SINGLE CONTINGENCY.

SO, UH, A NORMAL CLEARING OF A FAULT, HERE'S THE IMPACT OF THAT.

AND IT GOES BEYOND JUST THE BREAKER, ISOLATING THE LINE.

IT ALSO GOES TO THE ANCILLARY GENERATOR LOSSES.

THANK YOU FOR THE THOROUGH RESPONSE.

APPRECIATE THAT.

UH, IN GENERAL, GIVEN THAT THESE RISKS, UH, I THINK THEY'RE PRESENT TODAY, UM, ARE YOU CURRENTLY CONSIDERING ANY OF THIS IN YOUR GTL UH, METHODOLOGIES? IN, IN A VERY LIMITED SET? YES.

UH, AND IN THAT WINDOW, WHEN IT'S IN THE SHORT TERM, IT DOESN'T ALWAYS MAKE IT TO PLANNING BECAUSE PLANNING'S LOOKING MULTIPLE YEARS OUT, IT MAY BE IN OPERATIONS BECAUSE THEY'RE IT'S MONTHS, RIGHT? NOT YEARS.

WHERE WE, WHERE WE KNOW, WHERE WE KNOW OR HAVE BEEN TOLD, UM, IF THAT FAULT WAS TO OCCUR AGAIN, WE'RE GOING TO HAVE THIS GENERATOR TRIP OFF, THEN YES, WE, WE MODEL THAT UNTIL THE POINT IN TIME THAT THE GENERATOR FIXES THE PROBLEM.

AND THEN WE WILL TAKE THAT OFF.

UM, ONCE AGAIN, FOR, FOR SYNCHRONOUS GENERATION, UH, TYPICALLY THEY'RE, THEY'RE ON IT, RIGHT? BUT THERE MAY BE SOME TIMEFRAMES WHERE THEY HAVE TO ORDER EQUIPMENT AND THEY HAVE TO SCHEDULE OUTAGES AND THINGS LIKE THAT.

AND IN THOSE INSTANCES, THERE MAY BE A WINDOW WHERE YOU HAVE TO REPRESENT THAT IN THE SHORT TERM.

[01:15:01]

ONE LAST ONE, IF I MAY.

THE OPERATIONAL RESTRICTIONS THAT YOU, UH, WERE, WERE DISCUSSING, WHAT, WHAT EXACTLY ARE THOSE? WHAT, WHAT IS FORESEEABLE IN THE REALM OF WHAT AN OPERATIONAL RESTRICTION IS? I, I THINK WHAT WE MAY SAY IS, AND, AND WE, WE TALK ABOUT IT IN, IN THE PROPOSED LANGUAGE, IF YOU WANNA LOOK IN MORE DETAIL, I'M SORRY, IN THE CURRENT PROPOSED LANGUAGE, BUT LET'S SAY YOU HAVE A, A UNIT.

LET'S SAY WE HAVE A LARGE EVENT LIKE ODESSA, AND WE HAVE A UNIT THAT COMPLETELY TRIPPED OFF, RIGHT? THEY WENT TO ZERO AND LOST ALL THEIR INVERTERS AND TURBINES.

UM, THEY TELL US, WE DON'T EVEN KNOW WHAT'S HAPPENING AND WE GOTTA TALK WITH THE OEM.

AND, YOU KNOW, THEY TELL US IT'S GONNA BE SIX MONTHS TO A YEAR BEFORE WE CAN FIX THIS.

WE MAY ASK THAT UNIT, UH, TO REMAIN OFFLINE UNTIL THEY CAN GIVE US SOME ASSURANCE THAT THEY'RE NOT GOING TO TRIP OFF FOR THAT SAME FAULT.

AND THEY WOULD ISSUE, UH, AN INSTRUCTION.

WE WOULD ISSUE THEM IN AN INSTRUCTION, UM, AND THEY WOULD COME OFFLINE AND RECOGNIZE THAT IN THEIR COP AND EVERYTHING ELSE, THAT THAT'S ONE TYPE.

MAYBE THE ISSUE IS IN 20 OUT OF A HUNDRED INVERTERS.

AND SO, AND THEY RECOGNIZE THAT AND THEY GOTTA FIX IT ON THE 20, BUT THE OTHER 80 ARE, ARE FINE.

WELL, WE COULD ISSUE A PARTIAL, YOU KNOW, RESTRICTION THAT DON'T OPERATE THOSE 20 THAT ARE GOING TO TRIP OFF.

BUT YOU CAN GO AHEAD AND JUST HAVE A REDUCED HSL AND JUST OPERATE THE 80 THAT, THAT ARE FINE.

AND THERE MAY BE A SITUATION WHERE WE'VE ASKED THESE GENERATORS TO STAY OFFLINE, BUT WE GET INTO A, A VERY TIGHT ENERGY SITUATION, AND WE MAY ASK THOSE GENERATORS TO COME ON DURING THIS WINDOW OF TIME, UH, IF THEY'RE ABLE TO, TO, TO HELP OUT AND DELIVER ENERGY DURING THAT CIRCUMSTANCE AS WELL.

SO THERE'S AN OPERATIONAL RESTRICTION THAT COULD BE LIFTED, UH, TEMPORARILY TO ADDRESS, UH, ENERGY SCARCITY CONDITIONS AS WELL.

I SEE BILL BARNES IN THE QUEUE.

THANKS, STEVEN.

I WANT TO ASK, UM, DRILL INTO THIS TOPIC A LITTLE BIT MORE, WHICH IS OPERATIONAL CHANGES YOU GUYS MAY NEED TO DO, UM, GIVEN THE INCREASED EXEMPTIONS AND POTENTIAL RISK.

SO WHAT I HEARD IS, FOR STABILITY LIMITS, YOU MAY NEED TO IMPOSE NEW OR MORE GTC OR CONTROL THAT LIMIT AT A LOWER LEVEL.

ARE YOU ALSO CONSIDERING RESOURCE SPECIFIC LIMITS FOR THOSE THAT, UM, YOU KNOW, JUST CAN'T COMPLY BECAUSE OF EITHER TECHNICAL IN FEASIBILITY OR COMMERCIALLY SIGNIFICANT? I, I THINK CURRENTLY WE HAVEN'T, UM, WE, UH, TYPICALLY FOR US TO START MAKING THOSE TYPES OF RESOURCE SPECIFIC, UH, INSTRUCTIONS, IT, IT COMPLICATES OPERATIONS FOR THE OPERATORS.

WHEN WE HAVE A-A-G-T-L, OF COURSE WE CAN ACTIVATE A CONSTRAINT AND SC WE'LL MANAGE THAT DISPATCH WHEN WE HAVE TO DO A BUNCH OF ONE-OFF, YOU KNOW, ADJUSTMENTS FOR THIS UNIT OR THAT UNIT.

IT, IT GREATLY COMPLICATES, UM, THE OPERATORS, UM, NEED TO, TO DO THOSE TYPES OF MANUAL ACTIONS.

SO WE HAVE NOT CONTEMPLATED THAT CURRENTLY.

THAT IT IS BETTER TO, UM, HAVE THAT RISK FOR THAT WINDOW OF DURATION RATHER THAN NOT BE ABLE TO SERVE LOAD.

AND THEN THE, LIKE THE LA ONE OF THE LAST COMMENTS YOU MADE MADE IT SOUND LIKE YOU WOULD NEED TO UTILIZE THE RUCK PROCESS TO GET, UM, OTHER RESOURCES ONLINE THAT COULD HELP BALANCE OUT, UM, OPERATIONAL SITUATIONS WHERE YOU DEEM HIGHER RISK OF VOLTAGE RIGHT THROUGH FAILURES.

IS THAT TRUE? IS YOU EXPLAIN THAT A LITTLE BIT BETTER? YEAH, WHETHER THAT'S, THAT'S RUCK OR, OR REAL-TIME INSTRUCTIONS.

I THINK WHAT WE'RE TRYING TO SAY IS ERCOT RESERVES THE RIGHT THAT IF WE EMPLOYED AN OPERATIONAL RESTRICTION, UH, FOR THESE TYPES OF ISSUES, THAT IN A VERY ENERGY SCARCE SITUATION, UH, WE MAY CHOOSE

[01:20:02]

AND SO WE MAY LIFT TEMPORARILY LIFT THAT OPERATIONAL RESTRICTION AND ALLOW THOSE GENERATORS TO GENERATE DURING THOSE TIMEFRAMES.

AND THEN THIS IS MORE OF A GLOBAL QUESTION, UM, BUT I'LL ASK IT NOW SINCE WE'RE HERE THAT LATER ON THE AGENDA, WE ARE PROVE WE ARE ASKED TO PROVE A $900 MILLION SYNCHRONOUS CONDENSER PROJECT THAT APPEARS TO BE FOCUSED ON ADDRESSING THE SAME PROBLEM.

CAN YOU TALK ABOUT HOW THAT IMPACTS, UM, THE REQUIREMENTS HERE, HOW THESE TWO THINGS WORK TOGETHER? ANY CHANGES THAT THAT PROJECT MAY HAVE ON THE, UH, RELIABILITY RISK THAT YOU GUYS SEE? I, I THINK IT JUST HIGHLIGHTS THE CRITICALITY OF THOSE PROJECTS.

UH, ERCOT HAS BEEN CONSISTENT IN SAYING THE SOLUTION FOR IBR, UM, TO, TO BE ABLE TO OPERATE RELIABLY, UH, WITH AN IBR DOMINATED GRID INCLUDES MULTIPLE THINGS.

SO NO, 2 45, ALL THE OTHER PIGGER 1 0 9, 2 55, AS WE MAKE THESE CHANGES IN THE RULES, THAT'S ONE ASPECT.

WE ALSO NEED THESE, UH, SYNCHRONOUS CONDENSERS TO, AS PART OF THE SOLUTION.

WE ALSO NEED GRID FORMING INVERTER INVERTERS TO START COMING ONLINE AS PART OF THE SOLUTION.

SO ALL OF IT HAS TO WORK TOGETHER TO BE ABLE TO SUFFICIENTLY REDUCE THE RISK AND ALLOW US TO RELIABLY OPERATE IN AN IBR DOMINATED GRID.

YOU'RE GOOD.

I THINK THAT'S IAN HALEY, BUT A DIFFERENT CARD.

IAN HALEY, MORGAN STANLEY.

UM, STEVEN, ONE THING THAT YOU SAID THAT, UM, GAVE ME A LOT OF PAUSE WAS, UM, ERCOT, UM, RIGHT TO, OR NOT GIVING UP KOTS RIGHT, TO CALL THESE UNITS BACK ON.

UM, I DON'T HAVE A PROBLEM WITH THAT, BUT I DO HAVE A PROBLEM WITH IT NOT BEING CLEARLY LAID OUT, HOW THE MARKET WILL BE NOTIFIED OF THAT CHANGE OF GENERATION TO THE MARKET AT THE SAME TIME, UM, ONE MARKET PARTICIPANT BEING TOLD THAT A LARGE OR SIGNIFICANT AMOUNT OF A RESOURCE IN ONE AREA IS COMING BACK.

AND THAT INFORMATION NOT BEING INSTANTANEOUSLY GIVEN TO THE REST OF THE MARKET, UH, DOES GIMME A LOT OF PAUSE.

SO IF ERCOT WOULD LIKE TO RESERVE THAT, RIGHT, I DO THINK IT NEEDS TO BE SPELLED OUT IN THE PROTOCOLS OF HOW THAT WILL BE COMMUNICATED TO THAT MARKET PARTICIPANT AND THE OTHER MARKET PARTICIPANTS AT THE SAME TIME.

NO, I, I JUST THANK YOU FOR YOUR COMMENT.

I, I HEAR YOU LOUD AND CLEAR.

BOB HILTON.

YEAH, ACTUALLY MY, UH, COMMENT QUESTION IS RIGHT ALONG THE SAME LINES OF WHAT, UH, IAN JUST TALKED ABOUT.

UH, AND, AND IT, WHAT IT WAS THE, THE LAST PLACE WHERE YOU SAID, WE'LL PULL, WE'LL ISSUE, UH, AN ORDER TO WHERE YOU'RE NOT TO OPERATE UNLESS WE'RE IN TIGHT CONDITIONS, THEN, THEN COME BACK TO OPERATE.

I I THINK WE NEED TO WORK AROUND TO TALK ABOUT THAT SOME MORE ON WHETHER THAT IS, IF YOU'RE CALLED UPON AND YOU CAN RETURN, OR IF IT'S A REQUIREMENT.

'CAUSE GENERALLY, IF YOU'RE GONNA, JUST AS AN EXAMPLE, IF YOU'RE GONNA TELL A UNIT THAT THEY NEED TO BE OFF FOR THE NEXT YEAR UNTIL THEY CAN FIX THIS ISSUE, I'M JUST USING THESE AS, AS NUMBERS.

OKAY, STEVE? UH, I'M PROBABLY GONNA PUT THAT, THAT UNIT IN A POSITION THAT'S GONNA HAVE THE LOWEST BURN RATE THAT I CAN HAVE ON CASH UNTIL I CAN GET TO THAT TIME PERIOD WHERE I CAN COME BACK UP.

SO IT MAY NOT BE IN A CONDITION OR OPERATOR, UH, STATUS, UH, WITH ON STAFF PEOPLE DURING THAT TIME PERIOD TO COME UP AND OPERATE, UH, AT A GIVEN PERIOD OF TIME WITH LIKE, BASICALLY A CALL OPTION OUT THERE.

SO I THINK WE NEED TO CLARIFY THAT PIECE A LITTLE FURTHER IF WE'RE LOOKING AT THAT.

YEAH, THANK YOU FOR THAT.

AND I, I WOULD JUST CLARIFY, UH, I THINK OUR EXPECTATION IS IF YOU'RE ABLE TO, SO WE WOULDN'T REQUIRE YOU TO HAVE TO BE ABLE TO, BUT IF YOU'RE ABLE TO, UH, WE WOULD LIFT THE RESTRICTION.

THAT, THAT, THAT TAKES CARE OF A LOT OF WHAT I WAS CONCERNED ABOUT.

[01:25:02]

Q LOOKS CLEAR.

ALL RIGHT, THANK YOU.

WE CAN GO TO THE NEXT SLIDE.

SO SOME ADDITIONAL ASSUMPTIONS TO BE VERY CLEAR ABOUT THAT IBR PERFORMANCE REQUIREMENTS ARE ONE PART OF THE OVERALL SOLUTION TO ADDRESS RISKS.

SO, JUST AS MENTIONED, WE NEED NO 2 45 WITH THE APPROPRIATE ENFORCEMENT SYSTEM.

STRENGTH UP UPGRADES.

WE TALKED ABOUT THE SYNCHRONOUS CONDENSER GRID FORMING CAPABILITY ADOPTION, THE MODELING AND TESTING IMPROVEMENTS, UM, THAT WE NEED TO BRING TO THE TABLE.

UH, BASED ON RECENT DISCUSSIONS AT IB WG, UH, THE DISTURBANCE MONITORING EQUIPMENT INSTALLS NUMBER 2 55, THAT'LL BE COMING BEFORE THIS BODY IN A COUPLE MONTHS.

THAT ALSO NEEDS TO BE PART OF IT.

WE MAY NEED POTENTIAL PLANNING CRITERIA ADJUSTMENTS, UM, IF WE SEE THAT, UH, THERE'S A NEED FOR THAT AND TO OFFSET RISK, UH, THESE EXEMPTIONS MUST BE ACCOMPANIED BY CLEAR EXPECTATIONS AROUND POTENTIAL OPERATING RESTRICTIONS FOR FAILURES.

UH, ERCOT CONTINUES TO BE ADAMANT.

WE, WE DON'T WANT TO BE UNREASONABLE ABOUT APPLYING THOSE OPERATIONAL RESTRICTIONS, BUT WE NEED A MECHANISM AND WE WANT TO BE VERY CLEAR AND TRANSPARENT ABOUT THAT TO AVOID ALL OF THE CONFLICT LATER ON THAT, UM, THAT IS A POTENTIAL FOR YOU.

UH, WE FEEL LIKE THAT ALSO INCENTIVIZES ENTITIES TO MAKE SURE THAT THEY HAVE PROGRAMS AND CAPABILITIES TO QUICKLY ADDRESS THE ISSUES THAT THEY FIND, UH, MODELS AND CONTINGENCIES NEED TO ACCURATELY REFLECT THESE LIMITATIONS.

WE HAVE A MODEL QUALITY TESTS PROCESS NOW, BUT THERE ARE A LOT OF, UH, ENTITIES THAT SUBMITTED MODELS BEFORE THOSE TIMEFRAMES THAT AS WE VERIFIED, WE'RE FINDING A LOT OF ISSUES, FINDING A LOT OF PROBLEMS. AND THEN, SO THE MODELS, UM, NEED TO ACCURATELY REFLECT THESE LIMITATIONS.

OUR CONTINGENCIES NEED TO ACCOUNT FOR THEM.

AND THEN WE NEED TO HAVE PROPER ACTIVE AND REACTIVE POWER CONTROLS COORDINATION.

SO THERE'S A LOT OF COMPONENTS WITHIN A PLANT.

UM, WE NEED TO MAKE SURE THAT ALL OF THESE THINGS COORDINATE, UH, EVEN PERHAPS EXTENDING BEYOND THE GENERATORS TO THE TRANSMISSION SIDE.

SO IF THERE'S, UH, OTHER FAX DEVICES, OTHER DYNAMIC REACTIVE DEVICES OUT IN THE SYSTEM, UM, WE ARE A ASSUMING THAT THESE THINGS ARE GOING TO BE PROPERLY COORDINATED SO THAT IT, IT EVERYBODY HAS TO WORK TOGETHER.

AND, AND THESE ARE CRITICAL THINGS FOR US AS WE PROGRESS DOWN, UH, TO THE GRID TRANSFORMATION THAT WE ALL SEE THE ACTIONS REQUIRED TO OFFSET THE RISK COULD LEAD TO ADDITIONAL OPERATIONAL AND PLANNING IMPACTS, SUCH AS CONGESTION SYSTEM IMPROVEMENTS.

SO WE'RE ASSUMING THAT ALL OF THE STAKEHOLDERS ARE COMFORTABLE WITH THIS, THAT Y'ALL RECOGNIZE THIS, AND THIS IS THE, UM, THE, THE PATH FORWARD FOR EVERYBODY.

THERE'S, UH, WE ALLOW SOME LEVEL OF EXEMPTIONS, BUT THE RISK THAT GETS MID THAT, UH, RE RESIDES HAS TO GET MITIGATED BY THESE OTHER, UH, ASPECTS.

SO THAT'S REALLY, UM, WHAT WE WANT TO MAKE SURE EVERYBODY'S COMFORTABLE WITH.

NEXT SLIDE.

PROPOSED TIMELINE FOR NOGA 2 45.

UH, WE'RE GONNA ASK TACK TO TABLE TODAY.

UH, WE'D LIKE TO GET OUR COMMENTS SUBMITTED WITHIN A COUPLE OF WEEKS.

UH, LET STAKEHOLDERS HAVE, UH, SOME TIME TO PERHAPS PROPOSE ADDITIONAL COMMENTS OR CLARIFICATIONS.

UM, AND WE HOPEFULLY HAVE, UH, A VERSION THAT WE CAN MOVE FORWARD WITH, UH, WITH ADDITIONAL CONSENSUS, UH, THAT TAC CAN APPROVE, UH, ON JANUARY 24TH TCC, THAT WOULD TAKE US TO THE FEBRUARY BOARD AND THEN AN APRIL PVCT VOTE.

UM, IF WE CAN GO TO TWO SLIDES FORWARD, I JUST WANNA HIGHLIGHT THE APPENDIX, BUT I'M NOT GONNA DO GO THROUGH EVERYTHING.

BUT FOR EACH OF THE PARTICULAR REQUIREMENTS, UH, WE'VE JUST PROVIDED SOME ADDITIONAL DETAILS, A COMPARISON, AND, UM, SOME OTHER KEY TAKEAWAYS.

SO I'LL LET EVERYBODY, UH, LOOK THROUGH THE APPENDIX SLIDE.

Y'ALL CAN ALWAYS ASK ME ADDITIONAL QUESTIONS, UH, LATER OR, OR OFFLINE.

UH, BUT HOPEFULLY THIS JUST GIVES SOME ADDITIONAL CONTEXT, UH, TO SOME OF OUR THINKING THOUGHTS AND, AND CONSIDERATION OF THE RFI RESULTS, UH, THROUGH THE REMAINING SLIDES.

AND WE CAN GO BACK TO QUESTIONS IF THERE'S ANY OTHER.

UH, ADVANCED POWER ALLIANCE.

I SEE A COUPLE OF QUESTIONS IN THE QUEUE.

UH, FIRST ONE IS KEN DONAHUE.

KEN KEN DONAHUE WITH,

[01:30:01]

STEVEN, THANKS AGAIN FOR YOUR HARD WORK ON THIS.

YOU KNOW, WE'VE BEEN PUSHING TO GET MORE INFORMATION FROM THE OEMS FROM THE GET GO.

WE'RE NOW STARTING TO GET SOME REAL INFORMATION AND SOME QUALITY TECHNICAL WORK THAT WE CAN MAKE MORE FEASIBLE, UM, SOLUTIONS OUT OF THIS.

BUT ONE OF THE THINGS I, I SEE RIGHT NOW, YOU KNOW, I'M CONCERNED ABOUT THE RISK TOO.

IT'S, IT'S SIGNIFICANT.

I WAS SURPRISED WITH THE ODESSA EVENT ARE, WHEN YOU'RE LOOKING THROUGH THE RFIS, IS THERE ANYTHING THAT YOU CAN PICK OUT WHERE WE CAN MOVE QUICKLY? I KNOW, I KNOW WE'RE LOOKING AT, IN A HOLE, BUT ARE THERE DIFFERENT TECHNOLOGIES THAT COULD DO IT QUICKER THAN THE OTHERS TO HELP MITIGATE THAT RISK? I, I MEAN, I DON'T THINK THAT THE RFIS WERE SPECIFIC IN INTO THAT.

I, I DON'T THINK THE RFI RESPONSE IS ASSESSED.

UM, I THINK BY AND LARGE, AS FAR AS TIMELINESS, REALLY, UM, A LOT OF THE ENTITIES, UM, A LOT OF THE ENTITIES SAID, GAVE ME A 9, 9, 9 DATE.

SO THERE'S, THERE'S NOT GOOD INFORMATION THAT CAME FROM THE RFIS REGARDS TO, TO TIMELINESS.

UM, I, IF I, IF I HAD A GUT, I MEAN, MY GUT'S GOING TO TELL YOU THAT SOLAR IS GONNA BE FASTER, SOLAR AND BATTERIES ARE GONNA BE FASTER TO IMPLEMENT CHANGES.

AND THAT'S BECAUSE OF, UH, SOME OF THE SOLAR, UH, RFIS THAT ARE IDENTIFYING THAT THEY HAVE A SET OF CHANGES THAT ARE READILY AVAILABLE FOR ENTITIES TO TAKE AND ADOPT.

SO I THINK THAT GIVES ME THAT, THAT WOULD BE MY GUT FEELING FOR IT.

I THINK SOME OF THE WIND TURBINE OEMS ARE, ARE BEYOND, ARE FASTER THAN THE OTHERS.

AND SO SOME OF THEM THAT HAVE RESPONDED, AND I THINK JUST TO BE VERY CLEAR, VESTA RESPONDED THAT THEY, THEY FEEL COMFORTABLE, UH, THEY SUPPORTED OR COTS VERSION, I THINK SOME OF THE OEMS ARE GOING TO BE EASIER AND COMPARED TO OTHERS IN THE TIMELINESS OF IMPLEMENTATION.

YEAH, IT'S MY UNDERSTANDING THAT THAT WOULD BE, YEAH, SOME OF THE OEMS CAN, ESPECIALLY WITH THE NEWER TECHNOLOGY, BUT SOME OF THE OLDER UNITS WILL BE PROBLEMATIC.

I'M JUST TRYING TO REDUCE THE RISK AS QUICKLY AS POSSIBLE.

ARE THERE SOME THINGS THAT WE CAN CHERRY PICK TO MOVE THAT ALONG? UH, PARTICULARLY CLEARLY INDICATING TO NEW INTERCONNECTION AGREEMENTS.

YOU MUST MEET THE IEE 2,800 REQUIREMENTS.

UH, I THINK WE'VE GOTTA GET THAT MOVING AS SOON AS POSSIBLE.

I KNOW WE'VE GOT A LOT OF THINGS IN THE MIX, BUT, UH, RELIABILITY IS NOT GUARANTEED.

I WISH IT WAS, UH, WE JUST GOTTA NIP AT EACH ONE OF THESE THINGS, BUT, UH, THAT'S KIND OF THE CLEAR THING.

OKAY, THANKS STEVEN.

YEAH, I THINK, KEN, JUST, JUST TO RESPOND, UH, YOU KNOW, I'VE, I'VE HEARD MULTIPLE TIMES AND I CONTINUE TO HEAR IT.

WHY DON'T WE BIFURCATE OVER 2 40, 2 45, WHY DON'T WE GET THE NEW MOVING AND THEN TAKE MORE TIME ON THE LEGACY AND IT, I'M GONNA JUST SAY IT SO THAT WE, WE CONTINUE TO HEAR THE SAME CONSISTENT ANSWER.

THE RISK THAT WE HAVE TODAY IS ON THE LEGACY IDRS.

WE HAVE THAT RISK TODAY FOR THOSE THAT HAD PREVIOUS EXEMPTIONS, THERE ARE CAPABILITIES THAT THEY'RE NOT UTILIZING THAT, THAT, THAT PERHAPS THEY CAN MAXIMIZE, THEY CAN DO BETTER.

FOR THOSE THAT HAVE THE CURRENT CURVES ALREADY TODAY.

THERE'S MISAPPLICATION OF PARAMETERS, THERE'S MISSED COORDINATION.

THEY HAVE THINGS ACTIVATED THAT DON'T NEED TO BE ACTIVATED, AND THEY HAVE CAPABILITY THAT THEY'RE NOT USING.

THAT'S WHERE THE RISK RESIDES.

WE NEED TO ADDRESS THE RISK.

NEW COMING IN HELPS US FROM GETTING WORSE.

AND THAT'S IMPORTANT.

AND THAT'S WHY ERCOT HAS PUT THAT PACKAGE TOGETHER.

AND GOING BACK TO THE FERC DIRECTIVE, THEY SAID THIS NEEDS TO APPLY BOTH TO NEW AND EXISTING SO THAT WE DON'T, WE CAN PREVENT THE REALLY BAD THINGS FROM HAPPENING.

I SEE BOB WHITMEYER IN THE QUEUE.

CAN YOU HEAR ME OKAY? YES.

ALRIGHT, COOL.

HEY, STEVEN, IS THIS, IS THERE TIME FOR R OSS TO LOOK AT THIS AGAIN, OR DOES IT ALL HAVE TO BE DONE AT TAP? I, I THINK IF YOU PUT IT BACK TO ROS, IT'S JUST GONNA

[01:35:01]

SLOW THINGS DOWN.

UM, THAT'S, THAT'S WHAT I THINK.

I MEAN, IT'S UP TO THIS BODY TO DECIDE HOW THEY WANT TO HANDLE, UH, YOU KNOW, TO WAIT AND CONSIDER IT HERE, OR IF THEY WANT TO REMAND IT BACK TO, TO ROS.

BUT, UM, SEEMS LIKE THE RELIABILITY GUIDE MIGHT NEED ANOTHER SHOT AT THIS, BUT I'M OKAY.

WHATEVER.

ALRIGHT, THANKS.

THANKS, ERIC.

GOFF, I HAVE THE AFOREMENTIONED PRESENTATION, BUT IT LOOKS LIKE THERE MIGHT BE, UH, ANOTHER QUESTION FROM JUAN BEFORE WE GET TO THAT.

YEP.

JUAN, ARE YOU ON? ARE YOU IN HERE? CAN YOU HEAR ME? WELL, GO AHEAD.

PRETTY MUCH FOR REPRESENTATION, MY QUESTION WAS KIND OF LIKE ON THE, ON THE ALL VERSIONS OF THE GER, THERE ARE SOME TIMELINES IN ORDER FOR, FOR THE APPLY TO TIMELINES, THE PUSH AS THE APPROVAL GETS PUSHED.

YEAH, THIS IS STEVEN SLI WITH ERCOT.

I, I THINK DEFINITELY THE, UH, REPORT CONCEPT AND THOSE DATES SHOULD BE ADJUSTED.

I THINK JUNE 1ST, 2024 WOULD BE, UH, REALLY FAST AND WE'LL PROBABLY PUSH EVERYTHING TOWARDS THE END OF 2024.

AS FAR AS THE REPORTS, AS FAR AS THE IMPLEMENTATION TIMELINES, I THINK WE'LL JUST HAVE TO HAVE SOME MORE CONVERSATIONS, UH, ABOUT THAT.

UH, WE'LL TALK A LITTLE BIT MORE WITH THE OEMS TO SEE WHAT, WHAT A REASONABLE DATE IS.

WE'VE, ONCE AGAIN, WE PUSHED THE DATE, UM, FROM THE END OF 2024 TO THE END OF 2025 AND 2027 WITH EXCEPTIONS.

UM, WE, WE NEED THIS DONE.

I MEAN, I, IT'S THIS, THIS REALLY BIG CONUNDRUM WITH DOES EVERYBODY REALLY GET THE URGENCY OF THIS? AND DOES EVERYBODY REALLY SEE THAT WE NEED TO GET THIS DONE AS SOON AS POSSIBLE? SO IF WE COULD FIND A WAY AS THE STAKEHOLDER BODY TO MAKE SURE WE DON'T PUT A DATE THAT'S OUT THERE FOR THE LOWEST COMMON DENOMINATOR, UM, AND SAY EVERYBODY HAS TO COMPLY BY 2028, RIGHT? BECAUSE THEN WE CAN GET A HUNDRED PERCENT AND EVERYBODY WAITS.

THAT'S NOT WHAT WE WANT.

WE DON'T WANT RULES THAT, THAT PROMOTE THAT.

SO WE MAY HAVE TO DO SOME TYPE OF PHASE IN, WE MAY HAVE TO DO SOME TYPE OF THING.

UM, AND, AND HOPEFULLY WE GET FOLKS THINKING ABOUT THAT SO THAT WE CAN, IF WE HAVE TO ADJUST THE DATES, WE DO SO IN A MANNER THAT PROMOTES THAT WE GET AS MUCH DONE AS SOON AS WE CAN.

OR HARDWARE THAT NEEDS TO BE PHYSICALLY REPLACED AND WHOSE SETTINGS AND CONFIGURATIONS CANNOT BE MODIFIED USING SOFTWARE UPDATES.

I SEE BOB HILTON IN THE QUEUE.

YEAH, I JUST WANTED TO COMMENT ON WHAT, UH, MY OTHER BROTHER BOB SAID WHILE AGO, UH, TALKING ABOUT GOING BACK TO ROS, YOU KNOW, I UNDERSTAND THE RELUCTANCE ON THAT.

I, I WOULD SAY THAT AS ONE TAC MEMBER, IF ROS HAS THE TIME, THE ABILITY BANDWIDTH TO DO IT, I WOULD WELCOME ANYTHING THAT THEY WOULD LIKE TO PUT FORWARD BETWEEN NOW AND JANUARY THE 24TH TACK VOTE.

SO WHILE IT MAY NOT BE TECHNICALLY REMANDED TO THEM, I THINK THAT IF THEY WOULD LIKE TO PUT SOMETHING IN, I'D BE MORE THAN HAPPY TO HEAR IT.

AND I THINK THAT WOULD BE HELPFUL.

ALL RIGHT, ERIC, UH, THANK YOU SO MUCH.

UH, CAN YOU PULL UP MY PRESENTATION? OKAY.

SO, UM, STEVEN MENTIONED FERC ORDER 9 0 1 IN HIS PRESENTATION, AND I'M NOT GOING TO READ THIS WHOLE THING TO YOU, UM, BUT I JUST WANTED TO PROVIDE FOR YOUR REFERENCE, UM, THE RELEVANT SECTIONS OF THE FERC ORDER, UH, AS WELL AS SOME LINKS TO IT, AS WELL AS OTHER THINGS THAT ARE MENTIONED IN THE ORDER.

UM, SO FIRST OF ALL, UM, THIS IS RELATED TO THE, UM, RETROACTIVE NATURE OF, UM, THE DECISION.

AND FERC ASKED NERC TO LOOK INTO WHETHER OR NOT THERE NEEDS TO BE A LIMITATION FOR IBR THAT NEED TO HAVE EQUIPMENT

[01:40:01]

UM, AND THAT WHEN THAT EQUIPMENT IS REPLACED, THE EXEMPTION WOULD NO LONGER APPLY.

UM, SO WE THINK THIS IS AN IMPORTANT AND PRETTY CLEAR DELINEATION, UM, BETWEEN, UM, WHAT FERC IS AND IS NOT ASKING NERC TO LOOK INTO.

AND I WANNA NOTE THAT THE ROSS APPROVED VERSION OF NOGA 2 45 GOES BEYOND THE FERC ORDER, WHICH WOULD RE EVEN REQUIRE HARDWARE CHANGES IF IT WAS COMMERCIALLY REASONABLE TO DO SO.

UM, AND IF YOU GO TO THE NEXT SLIDE, UM, SO HERE IT'S JUST MORE INFORMATION FOR YOU TO REVIEW.

UM, AND, UH, AS STEVEN MENTIONED, THIS SAYS TO LOOK INTO MITIGATION ACTIVITY DIRECTIVES, AND I'VE, UM, REFERRED TO THAT DOWN BELOW FOR YOUR REFERENCE.

UM, SO THE, THE FERC DISCUSSION, I THINK IS CLARIFYING THAT WE HAVE A BODY THAT HAS SAID THAT, UM, THERE SHOULD NOT BE OR FOR, FOR NERC TO LOOK INTO WHETHER THERE SHOULD BE A, UM, LIMITED EXEMPTION FOR HARDWARE UPDATES.

AND THAT'S THE, THE ROOT OF THE DISCUSSION THAT WE'VE HAD TODAY, UM, AND FOR THE PAST SEVERAL MONTHS.

UM, AND THEN ONE LAST POINT TO PIVOT FROM IS I MENTIONED THAT NEXTERA IS, WAS CONSIDERING FILING ADDITIONAL COMMENTS.

AND I WANT TO DESCRIBE, UM, THE APPROACH THAT WE MIGHT BE TAKING.

UM, FIRST WE'LL TAKE A LOOK AT WHAT STEVEN'S PROPOSED CHANGES ARE IN HIS NEXT COMMENTS FROM ERCOT.

AND BASED ON TODAY'S DISCUSSION, DEPENDING ON HOW SOME OF THOSE QUESTIONS ARE ANSWERED, UH, THERE COULD BE ROOM FOR COMPROMISE THERE, PARTICULARLY AROUND WHAT IS AN UPGRADE KIT, HOW IS ERCOT SOLE AUTHORITY MAY BE LIMITED TO APPROVE AN EXEMPTION.

UM, ARE THERE MORE DETAILS AROUND THE OPERATIONAL RESTRICTIONS? UM, SO IT'S NOT, UM, SOLELY UP TO ERCOT AND HOW THAT WORKS.

HOWEVER, IF THERE'S NOT A A PROPOSED COMPROMISE, UM, WE WOULD FILE COMMENTS THAT, UM, WOULD DO THE PROPOSED BIFURCATION, UH, AS AN OPTION FOR, FOR TAC.

SO THE BIFURCATION WOULD BE TO CREATE NEW, UH, RULES FOR THE NEW RESOURCES VERSUS THE EXISTING RESOURCES.

UM, SO WE CAN CONTINUE TO DISCUSS THE EXISTING RESOURCES.

NEXTERA CONTINUES TO SUPPORT THE ROSS RECOMMENDED VERSION ABOUT THE COMMERCIAL REASONABILITY EFFORTS, AND WE THINK THAT TAC COULD ENDORSE THAT, BUT IF TAC WANTS MORE TIME TO FIGURE OUT HOW THAT PROCESS WOULD APPLY, BIFURCATION HAS MOVED THIS FORWARD WHERE WE CONTINUE TO WORK ON THAT WOULD BE A NEXT STEP AND GET TO, UM, YOU KNOW, THE URGENCY OF THE ISSUE.

I UNDERSTAND, UM, STEVEN'S POINT ABOUT THE MAJORITY OF HIS CONCERNS AND EXISTING RESOURCES.

UM, BUT AT THE SAME TIME, IF WE CAN MOVE PART OF IT FORWARD, WHY NOT, WHY WE CONTINUE TO WORK ON THE SECOND PART.

UM, SO WITH THAT, I'LL, UH, ANSWER ANY QUESTIONS PEOPLE HAVE AND I'M HAPPY TO DISCUSS THIS FURTHER.

LOOKING FORWARD TO THIS, AND I HOPE WE CAN GET TO OUR RESOLUTION.

ALL RIGHT, BILL.

THANKS, ERIC.

WHAT IS NEXTERA'S CONCERN WITH ERCOT LATEST PROPOSAL? SO IT DOESN'T HAVE, UM, SOME OF THE SPECIFICITY, UH, THAT WE'RE, WE'RE HOPING IT WILL HAVE.

UM, SO FOR EXAMPLE, UPGRADE KIT IS DISCUSSED, BUT, UM, WE DON'T KNOW, UH, WHAT THAT IS.

UM, THE VERY EXPENSIVE WAS DISCUSSED, BUT WE DON'T KNOW WHAT THAT IS.

WE THINK THE COMMERCIAL REASONABILITY IS A WAY TO GET AT BOTH THOSE QUESTIONS BECAUSE IT NATURALLY ANSWERS THEM.

UM, I THINK THOSE ARE THE, THE MAIN CONCERNS.

UH, THAT SAID, YOU KNOW, THIS IS, UM, PROGRESS AND WE APPRECIATE THAT.

UH, ERCOT CONTINUES TO, UM, CHANGE ITS PROPOSAL BASED ON FEEDBACK AT THE IVR WORKING GROUP.

ASSUMING THOSE TWO THINGS, UH, CAN BE DEFINED IN A REASONABLE WAY, WOULD NEXTERA SUPPORT ER KAT'S PROPOSAL? WE'LL HAVE TO SEE WHAT REASONABLE IS AND HOW IT'S DEFINED.

I, I HOPE THAT WE CAN, AND I, I WOULD LIKE FOR THERE TO BE COMPROMISED, BUT I DON'T WANT TO TELL YOU A YES OR NO UNTIL I SEE IT.

IT'S NOT WRITTEN DOWN.

ARE CLOSE TO A DEAL SLIDE? WHAT'S THAT? ARE WE CLOSE TO A DEAL? THAT'S ALL I WANNA KNOW.

I HOPE SO, BUT I NEED TO SEE THE DETAILS, LIKE I SAID.

COMMENT, ERIC, YOU MADE ABOUT BIFURCATING AND MOVING A PIECE FORWARD.

ALL RIGHT, EMILY, THANK YOU.

I THINK I JUST WANNA GO BACK TO A

[01:45:01]

I THINK PART OF THE REASON I'M NOT COMFORTABLE WITH THAT RIGHT NOW IS BECAUSE I DON'T REALLY HAVE A GOOD SENSE OF WHAT THE RS APPROVED, UH, COMMERCIAL REASONABILITY IS AS IT COMPARES TO WHAT ERCOT ISS TALKING ABOUT TODAY.

UM, SO I THINK THAT WOULD BE REALLY HELPFUL IF WE COULD TEE THAT UP, UM, MAYBE KIND OF SIDE BY SIDE, UH, AT THE JANUARY MEETING.

UM, THAT, THAT MAKES SENSE.

WE'RE ALSO, UH, ARE CONSIDERING WHETHER OR NOT WE CAN ADD MORE PROCESS INTO THE COMMERCIAL REASONABILITY EFFORT.

UM, BUT, UM, I WOULD WELCOME FEEDBACK FROM ANYONE THAT HAS CONCERNS THAT WAS A, A MAYBE OR A NO VOTE ROSTER HERE ON THAT.

UM, WE HAVE SOME THOUGHTS ABOUT HOW TO DO THAT, UM, AND WOULD, WOULD LOVE TO ADVANCE THE BALL ON THAT.

IT LOOKS LIKE THE QUEUE IS CLEAR.

ARE THERE ANY OTHER COMMENTS OR QUESTIONS ON NO, 2 45.

SO IT'S ALREADY TABLED BY TAX, SO WE DON'T NEED TO VOTE ON IT AGAIN UNLESS SOMEBODY WANTS TO.

DO YOU HAVE A COMMENT? OH, OH, DAVE, GO AHEAD.

SORRY, JUST ONE BRIEF COMMENT, UM, FOR FOLKS AS THEY READ THROUGH THE ERCOT SLIDES, THE, THE APPENDIX WITH THE ROSS APPROVED VERSION COMPARED TO THE ERCOT PROPOSAL, JUST ONE NOTE OF CAUTION.

UM, THERE, THE ROSS APPROVED VERSION, RIGHT? THE ANSWERS, UH, THE, THE RESPONDENTS WERE ASKED TO PROVIDE, IT DOESN'T REALLY DIFFERENTIATE BETWEEN CASES WHERE THERE IS A SOLUTION AND THE COST IS UNKNOWN OR THERE A SOLUTION MAY EXIST IN THE FUTURE TECHNICALLY, BUT THE COST IS UNKNOWN TODAY VERSUS CASES WHERE THE COST IS LIKELY TO BE PROHIBITIVE OR IS PROHIBITIVE.

AND SO THAT MAY END UP GIVING THE PERCEPTION OF A WIDER GAP BETWEEN LIKE, LIKELIHOOD OF ADOPTION THAN ACTUALLY EXISTS.

AND THERE'S NOT A WAY THAT THAT IS, IT CAN BE KIND OF TEASED OUT OF THOSE COMPARISONS.

SO IT, THAT'S JUST ONE THING I WANTED TO NOTE.

IF FOLKS ARE LOOKING AT THAT, THOSE COMPARISONS.

WHICH ARE CA CATEGORIZED AS TABLE C IN, UH, SECTION 2 9 1 1.

ALRIGHT, I SEE PRASHANT IN THE QUEUE.

GO AHEAD.

YEAH, SO MY COMMENT IS MOSTLY ABOUT THE HVRT, UH, TEMPORARY OR VOLTAGE RIGHT THROUGH, WHICH GOES UP TO 1.8 PER UNIT.

UM, I UNDERSTAND LIKE SOME OF THE THINGS ARE LIKE CRITICAL FROM LIKE THE PRC 24 RIGHT THROUGH, UH, BUT THE 1.8 P RIGHT THROUGH SPECIFICALLY THAT CAME FROM I 2,800, UH, I WOULD REALLY LIKE SUGGEST THAT THOSE THINGS ARE NOT APPLIED RETRO RESPECTIVELY.

THEY MIGHT HAVE HARDWARE IMPACT, UM, ON THE IBR, UM, THAT CAN BE DONE IN THE FUTURE, UH, PRODUCT RELEASE, BUT ARE VERY HARD TO MAKE IN THE RE UH, FROM THE RETRO PERSPECTIVE.

I THINK THAT'S ONE COMMENT.

AND THE SECOND ONE IS SIMILARLY ON THE DATA SIDE OF THINGS, UM, ON THE DATA COLLECTION TOO.

I MEAN, THERE ARE CERTAIN THINGS THAT CAN BE DONE, UM, LIKE EASILY AT THE PLANT LEVEL, BUT SOME REQUIREMENTS ARE LIKE VERY DETAILED, WHICH CAN IMPACT THE IBR FROM THE HIGH HARDWARE PERSPECTIVE TOO.

SO, YEAH, SO THOSE ARE MY TWO COMMENTS, WHICH AGAIN, BRINGING IT BACK TO THE GROUP THAT, UM, THOSE ARE VERY NUANCED LIKE, UH, HARDWARE LEVEL IMPACT, WHICH I WOULD REALLY RECOMMEND IF THEY CAN BE DONE FOR THE FUTURE PROJECTS.

ALL RIGHT, STEVEN, I THINK TWO QUICK COMMENTS TO, TO DAVID'S POINT ON THE APPENDIX SLIDES ON THE PRESENTATION THAT ERCOT, UH, PROVIDED, WE DID IN MOST INSTANCES WHERE WE CALLED OUT THAT A LOT OF NO RESPONSES WERE FROM RES DUE TO INSUFFICIENT INFORMATION RATHER THAN A NO LIMITATION.

AND SO WE DID TRY TO HIGHLIGHT THAT ASPECT AND, AND DAVID'S ACCURATE AND THAT SOME ARE, SOME RES DON'T HAVE ENOUGH INFORMATION, SO THEY, THEY RESPONDED NO.

UM, TO THE, TO THE LAST COMMENT FROM TESLA, I JUST WANNA BE CLEAR AS PROPOSED BY ERCOT IN THE AUGUST COMMENTS, AND WE WOULD BE CONSISTENT, UH, THERE WOULD NOT BE A RETROACTIVE IMPLEMENTATION FOR SGIS BEFORE 6 1 23, UM, FOR LEGACY IDRS THAT, UH, FOR THE TRANSIENT OVERVOLTAGE OR THE INSTANTANEOUS OVERVOLTAGE REQUIREMENTS,

[01:50:01]

SO THE, WE'RE NOT PROPOSING THAT WE'RE PROPOSING FOR NEW, UH, WITH SGIS BEYOND 6 1 23, THAT THERE WOULD BE, UH, THAT REQUIREMENT MOVING FORWARD.

AND, AND IT, IT'S GONNA BE CHALLENGING IF THERE'S REQUESTS FOR US TO EXEMPT, UH, BECAUSE ONE OR, UH, THE MINORITY OF OEMS CANNOT MEET A PARTICULAR REQUIREMENT, OR IT WOULD BE EXPENSIVE FOR THEM TO RETROFIT THAT REQUIREMENT WHILE A MAJORITY OF THE OEMS ARE CAPABLE OF MEETING THAT REQUIREMENT.

UM, ONCE AGAIN, THIS IS A STAKEHOLDER PROCESS AND THE STAKEHOLDER BODY MAY DECIDE THAT THAT'S OKAY.

I THINK IT'S JUST GONNA BE CHALLENGING FOR ERCOT TO SUPPORT LOWERING, UH, THOSE REQUIREMENTS FOR THE MINORITY, FOR NEW MOVING FORWARD.

THANK YOU, PRASHANT.

YEAH, JUST WANTED TO MENTION MY AVIATION.

I MISSED IT LAST NAME, BUT, BUT NO MORE COMMENTS.

ANYONE ELSE IN QUEUE? ANY OTHER COMMENTS? OKAY.

SO AGAIN, THIS IS ON THE TABLE, SO WE DON'T HAVE TO TAKE ANY T DOESN'T HAVE TO TAKE ANY ACTION.

UM, AS MR. HELTON MENTIONED EARLIER, IF THERE ARE OTHER SUBCOMMITTEES SUCH AS ROSS THAT WANNA TAKE THIS UP, UM, WHILE THIS IS ON THE TABLE AT TAC, THEY'RE MORE THAN WELCOME TO.

IF NOTHING ELSE, LET'S MOVE ON.

WE HAVE NPR 1193.

THIS ONE CAN REMAIN TABLED.

UM, IT'S STILL WAITING FOR SMOG GROUP 27.

THAT IS AT WMS RIGHT NOW.

AND THEN WE HAVE NPR 1203.

UM, ERCOT DID FILE A REQUEST FOR WITHDRAWAL ON THIS ONE THAT T WILL NEED TO VOTE ON SINCE PRS ALREADY TOOK ACTION TO APPROVE THIS ONE.

UM, KENAN, DO YOU WANNA DISCUSS THE REQUEST FOR WITHDRAWAL? CERTAINLY.

UM, SO ERCOT FILED, UH, THE ORIGINAL 1203, UH, WITH, UM, A GOAL OF DELIVERING, UH, UH, WITH THIS DECEMBER, 2024 DATE.

SINCE THAT TIME, UH, THE MARKET PARTICIPANTS AND, UH, THE AUTHORS OF THE BILL HAVE SAID THAT THEY WOULD PREFER, UH, ERCOT TAKE LONGER TIME AND DESIGN DRRS IN A WAY THAT IT IS NOT EMBEDDED IN NONS SPIN, BUT INSTEAD A STANDALONE PRODUCT.

UM, SO WE WOULD LIKE TO WITHDRAW THIS IN PRR, UH, IN RESPONSE TO THOSE REQUESTS, UH, FROM, UH, A VARIETY OF PARTIES AND, UH, REPLACE THIS PRODUCT WITH ONE THAT IS A STANDALONE, UH, SERVICE.

UH, AND WE WOULD WRITE A NEW NPRR FOR THAT AND DELIVER THAT, UM, HOPEFULLY IN THE NEW YEAR.

UM, AND WHEN I SAY DELIVER THAT, DELIVER THE , YEAH, I NEED TO BE REALLY CAREFUL HERE, DELIVER, UH, A PROPOSED NPRR THAT WOULD THEN, THAT THOSE, UH, IT, THOSE FEATURES OF THAT NPRR WOULD THEN DETERMINE HOW LONG IT WOULD TAKE FOR US TO ACTUALLY PHYSICALLY DELIVER THE PRODUCT.

UM, SO WE WOULD REQUEST TAC UH, 'CAUSE ERCOT DOESN'T NO LONGER HAS FULL CONTROL OF THIS NPRR.

WE WOULD, UH, REQUEST THAT TAC UH, VOTE TO WITHDRAW THE NPRR AND LET US PROCEED WITH AN ALTERNATIVE THAT, UH, BETTER ALIGNS WITH THE FEEDBACK WE'VE GOTTEN FROM, UH, STAKEHOLDERS ACROSS THE BOARD.

GARRETT JUST GONNA MAKE A MOTION TO WITHDRAW NPRR 1203 SECOND.

ARE WE ABLE TO PUT THIS ON THE COMBO BALLOT? IT SAYS ANYONE NEED A SEPARATE, WE'RE GOOD.

LET'S GO THROUGH THE QUEUE.

APOLOGIES, ANN, I'D LIKE TO ABSTAIN.

ACHIEVED THE GOALS THAT I JUST MENTIONED, AND THEN WE COULD HAVE, YOU KNOW, IT COULD GO THROUGH THE REGULAR PROCESS OR IF THERE'S A NEED FOR A WORKSHOP OR, OR SOME OTHER TYPE OF INTERACTION, WE'D BE OPEN TO, UH, DOING ALL OF THAT.

WE'LL NEED A SEPARATE BALLOT FOR THIS, BUT LET'S GO AHEAD AND GO THROUGH THE QUEUE.

UM, BILL, THANKS KENAN.

UH, WHAT'S THE PLAN FOR SOLICITING STAKEHOLDER FEEDBACK ON HOW A STANDALONE DRS PRODUCT SHOULD BE DESIGNED? I THINK THERE'S SOME DETAILS THAT WE NEED TO TALK THROUGH.

SO, UM, OKAY.

SO, UH, I, OUR, OUR THOUGHT IS, AND THIS IS MALLEABLE, UM, SO WELCOME YOUR FEEDBACK, BUT OUR THOUGHT WOULD BE THAT WE WOULD FILE A DRAFT IN PRR THAT, UH, THAT

[01:55:01]

THE GOAL WOULD BE TO MAKE SURE EVERYBODY WAS FULLY INFORMED ON THE FUNCTIONALITY AND FEATURES THAT WE WERE PUTTING INTO THE NPRR AND THAT, UM, UH, WE ABSOLUTELY GOT STAKEHOLDER FEEDBACK ON, UH, MAKING THAT BETTER OR, UH, ADJUSTING IT SUCH THAT WE HAD A PRODUCT THAT, UM, THE STAKEHOLDER COMMUNITY WAS COMFORTABLE WITH THAT ALSO MET THE STATUTORY GOALS THAT ARE, UH, IN, IN, IN THE DESCRIPTION ON HB 1500, I BELIEVE.

AND THEN, FOLLOWING QUESTION, UH, THIS WAS OUR PRIMARY CONCERN WITH, UM, STARTING OVER ON A STANDALONE PRODUCT, IS THE IMPACT TO RTC PLUS B.

CAN YOU GIVE US, UM, WHAT ERCOT THOUGHTS ARE ON HOW THAT WOULD BE DELAYED OR NOT? SO, UH, WE WOULD, UH, BASED ON CONVERSATIONS I'VE HAD AT THE COMMISSION, UM, AND THE PRIORITIES THAT THEY'VE OUTLINED, WE WOULD, UH, FOCUS ON A PRIORITY OF RTC PLUS B BEING DELIVERED, AND THIS WOULD FIT SOMEWHERE IN AND AROUND THAT.

UM, IT IS FEASIBLE THAT WE COULD DELIVER THIS PRIOR TO RTC PLUS B.

IT'S ALSO POSSIBLE THAT WE WOULD HAVE TO, UH, WAIT A LITTLE BIT PAST RTC PLUS B TO DELIVER THIS PRODUCT.

UM, I, I THINK THERE ARE SOME, UH, OUTSTANDING QUESTIONS AS TO WHETHER THIS GOES INTO THE CO-OP OPTIMIZATION ENGINE OR NOT.

UM, I THINK THERE'S SOME PROS AND CONS THERE THAT WE WOULD WANT TO DISCUSS WITH STAKEHOLDERS.

UM, SO THO THOSE ARE, THAT'S JUST A FLAVOR OF SOME OF THE THINGS THERE, BUT, UH, I MEAN, I WOULD JUST VOICE THE FEEDBACK SO FAR THAT I'VE GOTTEN FROM THE COMMISSION IS RTC PLUS B IS THE PRIORITY, AND WE WOULD WORK, UM, OUR PROJECTS WITH THAT FEEDBACK THAT WE'VE GOTTEN FROM THE COMMISSION.

ALL RIGHT, ERIC, UH, JUST TO CONTINUE THE CONVERSATION THAT YOU'RE JUST HAVING WITH BILL, UH, I CAN'T HEAR YOU VERY WELL, ERIC.

IS THIS BETTER? YES, MUCH.

UM, SO TO CONTINUE THE CONVERSATION YOU'RE HAVING WITH BILL, UM, I THINK WE WOULD GREATLY PREFER THAT YOU HAVE A WORKSHOP BEFORE YOU FINALIZE THE NPRR, UM, BECAUSE WE MIGHT HAVE FEEDBACK ON SOME OF THE QUESTIONS YOU RAISED, LIKE, FOR EXAMPLE, UM, THE QUANTITY THAT'S PROCURED, HOW IT FITS INTO RTC, UM, HOW IT MEETS SOME OF THE OTHER STATUTORY REQUIREMENTS OF, UH, HB 1500.

AND WHILE YOU MIGHT HAVE MOST OF THE WORK DONE BEFORE THE WORKSHOP, I THINK IT WOULD BE HELPFUL AND HELP TO AVOID DELAYS IF WE KINDA CAN HAVE THE WORKSHOP BEFORE EVERYTHING'S FINALIZED.

WE DON'T HAVE TO GO BACK AND, UM, AMEND SOMETHING THAT YOU'VE ALREADY PUT A LOT OF WORK INTO.

UM, SO WE'D APPRECIATE THAT ORDER OF OPERATIONS IF POSSIBLE.

I, I, I WILL TAKE THAT FEEDBACK AND I, I BELIEVE WE CAN, UH, ACCOMMODATE THAT REQUEST.

THANK YOU, EMILY.

HAVE A, A DEADLINE IN STATUTE, AND I DON'T WANT TO STAND IN THE WAY OF, YOU KNOW, FOLKS MOVING FORWARD WITH WHAT THEY BELIEVE THE, THE CORRECT TIMELINE IS.

I WAS ACTUALLY GONNA MAKE THE SAME REQUEST AS ERIC.

UM, ONE OF THE THINGS THAT WE'RE CONCERNED ABOUT IS MAKING SURE THAT WE UNDERSTAND THE VARIOUS DECISION POINTS AND HOW THEY AFFECT THE TIMELINE, GIVEN THAT THERE'S A STATUTORY DEADLINE THAT IT'S UNIVERSALLY ACKNOWLEDGED NOT TO BE MET UNDER THE PATH THAT WE'RE PROCEEDING DOWN.

UM, I AM A LITTLE WORRIED ABOUT CERTAIN POLICY DECISIONS BEING THEN DRIVEN BY SECONDARY TIMELINE GOALS.

AND SO IF YOU CAN JUST BE COMMUNICATIVE AND TRANSPARENT ABOUT WHAT TIMELINES YOU ARE LOOKING TO REACH SO THAT WE CAN UNDERSTAND THAT.

UM, AND AGAIN, WE, WE HAVE A LOT OF DISCUSSIONS AROUND HERE AT THE PUC ABOUT IMPACTS TO RTC PLUS B.

THERE, THERE'S OTHER PRIORITIES AS WELL.

SO, UM, I DON'T WANT THAT TO BE THE ONLY DRIVER, UH, IN TIMELINE, RECOGNIZING THAT WE'RE ALREADY NOT GONNA MEET DECEMBER OF 24.

AND, UH, I, I ALSO AGREE, UH, WORKSHOP SEEMS LIKE A, A GOOD PATH FORWARD.

YOU KNOW, UM, I THINK EVERYONE IS IN AGREEMENT THAT, YOU KNOW, ULTIMATELY A STANDALONE DRRS IS THE, IS THE RIGHT PATH TO GO.

UM, SO I, I REALLY JUST WANTED TO ALSO JUST MAKE A COMMENT FOR, YOU KNOW, THE, THE CONTEXT FOR WANTING TO ABSTAIN ON THIS.

IT IS JUST BECAUSE WE DO

[02:00:01]

BUT, UH, I JUST CAN'T VOTE FOR THAT.

UH, ERIC, JUST REAL BRIEFLY, SINCE THE TIMELINE CAME UP, AND JUST FOR THE RECORD, I WON'T GO INTO TOO MUCH, IT'S ALREADY WRITTEN COMMENTS, BUT, UH, A NUMBER OF THE CONSUMERS THAT FILED A REQUEST FOR THE SEPARATE PRODUCT NOTED THAT THEY WERE PARTS OF THE ACTUAL PRODUCT DESIGN FOR HP 15 HUNDREDS, UH, DRS THAT WEREN'T BEING MET BY THAT DEADLINE.

SO WE WEIGH THE, UM, SPECIFICITY AROUND WHAT IS DRRS VERSUS THE, THE DATE OF OF MEETING SOMETHING.

WE WOULDN'T WANT TO CREATE SOMETHING CALLED DRS THAT DIDN'T MEET THE STATUTORY REQUIREMENTS.

UH, I, IF, IF I MAY, UH, UH, WEIGH IN, UM, I, I BELIEVE ERCOT FEELS THAT WE DID MEET THE REQUIREMENTS.

HOWEVER, I WOULD NOTE THAT IN ADDITION TO THE CONSUMER COMMENTS, THE AUTHOR'S LETTER ALSO EXPRESSED THAT CONCERN.

SO, UM, I, I, I THINK THAT'S A DATA POINT THAT IS IMPORTANT FOR THE STAKEHOLDERS TO CONSIDER.

UH, IF THE, YOU KNOW, CHAIRS OF THE, UH, APPROPRIATE GROUPS DON'T FEEL LIKE, UH, CHAIRS OF THE APPROPRIATE GROUPS, THAT THE LEGISLATURE DON'T FEEL LIKE THE DESIGN IS MEETING, AT LEAST THEIR, THEIR UNDERSTANDING, UH, YOU KNOW, THAT THAT IS SOMETHING SUBSTANTIAL THAT I WOULD WANT TO ACKNOWLEDGE.

ANY OTHER COMMENTS IN THE QUEUE? OKAY.

WE HAD A MOTION FROM GARRETT TO APPROVE THE REQUEST FOR WITHDRAWAL.

CAN WHOEVER WAS THE SECOND ON THAT, CAN YOU LET ME KNOW AGAIN, ERIC? OKAY.

AND WE'LL DO A STANDALONE BALLOT FOR THIS ONE.

SO I'LL HAND IT OVER TO COREY.

THANK YOU, ANN.

IT'S ON THE MOTION TO APPROVE THE DECEMBER 1ST REQUEST FOR WITHDRAWAL FOR 1203.

WE WILL START UP WITH THE CONSUMERS, WITH MARK.

AND THEN GARRETT FOR BILL? YES.

THANK YOU, ERIC.

NABA? YES, THANK YOU.

UNDER THE CO-OPS, MIKE? YES.

YES, THANK YOU LUCAS FOR CLIFF.

OH, I GOT YOU IN CHAT.

LUCAS CSS ONTO THE INDEPENDENT GENERATORS.

THANK YOU, COREY, SIR, ONTO OUR IPMS. JEREMY? YES.

THANK YOU, REMI.

YES, THANK YOU, KEVIN.

ON OUR IOUS, KEITH? YES.

THANK YOU, COLIN.

DAVID.

YES, YOU RICHARD? YES, THANKS SIR.

ON THE MUNIS, JOSE? YES.

THANK YOU, DAVID.

YES, THANK YOU, ALICIA.

YES, THANK YOU, RUSSELL.

ARE GOOD TO MOVE ON TO OUR SUBCOMMITTEE REPORTS.

MOTION CARRIES TO ABSTENTIONS ON BEHALF OF .

I JUST WANNA SAY THANK YOU.

THANKS COREY.

AND KANAN.

UM, AND I BELIEVE THE TWO BDRS ASSOCIATED, WE DON'T NEED TO VOTE ON, BUT THEY WILL BE WITHDRAWN.

SO THAT'S O-B-D-R-R OH 49 AND O-B-D-R-R OH 50.

AND COREY GAVE ME THE THUMBS UP.

SO THOSE ARE OFFICIALLY WITHDRAWN, BUT WE DON'T NEED TO VOTE ON THOSE.

UM, SO O NEXT IS, UH, O-B-D-R-R 46, I, I BELIEVE THAT CAN REMAIN TABLED.

AND THEN PI R 1 0 5, UM, WHICH CAN REMAIN TABLED AS WELL.

IS THERE ANY DISCUSSION ON EITHER OF THOSE? I, I DON'T SEE ANYTHING.

SO I THINK WE

[7. RMS Report (Vote) RMGRR176, Addition of Market Processes Specific to LP&L - URGENT]

[02:05:01]

FIRST UP IS RMS. DEBBIE, ARE YOU HERE? I'M, THANK YOU, .

WELL, THIS IS A BIT OF A CULTURE SHOCK FROM WHERE OUR LAST DISCUSSION WAS.

UH, WE HAD OUR, UH, LAST RMS MEETING, NOVEMBER 7TH.

WE'RE HAVING OUR NEXT ONE TOMORROW.

AND, UH, I WOULD LIKE FOR YOU TO INVITE YOU TO JOIN US IF YOU'RE AVAILABLE.

WE HAVE ONE VOTING ITEM, AND IT WAS APPROVED BY RMS AND IT WAS APPROVED AS URGENT, AS WELL AS THE, UH, R-M-G-R-R.

SO THIS RETAIL MARKET GUIDE REVISION REQUEST, UH, WHAT WE NEED TO DO IS KEEP IT ON TRACK TO MAKE SURE THAT IT CAN BE IMPLEMENTED BY THE EXPECTED DATE OF LUBBOCK POWER AND LIGHTS IMPLEMENTATION TO CUT OVER TO, UM, RETAIL COMPETITION, WHICH IS MARCH 4TH.

SO, UM, I'M HOPING THAT YOU CAN, UH, APPROVE THIS TODAY.

AND, UH, JUST A LITTLE BIT OF INFO.

THIS IS OUR, UH, TIMELINE FOR TRANSITION TO COMPETITION FOR LUBBOCK POWER AND LIGHT.

AND, UM, AS YOU CAN SEE, WE'VE GOT A LOT GOING ON.

UM, WE HAVE GOT, I THINK, 26 RETAIL ELECTRIC PROVIDERS READY TO GO INTO THE LUBBOCK TERRITORY.

AND, UM, THERE'S THREE FLIGHT, UH, TEST FLIGHTS A YEAR.

SO, UH, WE'VE GOT, UM, ANOTHER ONE COMING UP.

WE WILL BE TRANSITIONING THE CUSTOMERS, UH, ON CYCLES, UH, STARTING MARCH 4TH.

SO WE'RE REALLY LOOKING FORWARD TO VERY SUCCESSFUL EFFORT WITH LUBBOCK PARA AND LIGHT.

THE R-M-G-R-R GIVES US THE ADDITIONAL LANGUAGE TO ENSURE THAT THE CORRECT PROP PROCESSES ARE REPRESENTED FOR LUBBOCK POWER AND LIGHT.

IT.

WE DO NOTE THE EXACT NAME, LUBBOCK POWER AND LIGHT IN THE R-M-G-R-R, WHICH USUALLY IS, IT'S A LITTLE DIFFERENT.

USUALLY WE TRY AND STAY AWAY FROM THOSE UNLESS IT IS, UH, SPECIFICALLY JUST CONTACT INFORMATION, THINGS LIKE THAT.

UM, SO WE WILL BE PROBABLY MAKING ADDITIONAL UPDATES TO THE RETAIL MARKET GUIDE AS THEY COME INTO, UM, SWITCHING AND, UH, IN MARCH.

SO, UM, IT'S POSSIBLE WE'LL BE BACK ASKING, ASKING FOR ANOTHER CHANGE.

KEN, I, I, I JUST WANTED TO SAY THANK YOU TO ALL THE FOLKS THAT HAVE WORKED ON THIS.

I KNOW THERE'S STILL MORE WORK TO DO.

UM, IT'S BEEN A, UH, THERE'S, THERE'S BEEN A LOT OF BEHIND THE SCENES ACTIVITY OH, YES.

UM, BY E EVERYBODY INVOLVED.

AND I JUST REALLY APPRECIATE WHERE YOU'VE GOTTEN EVERYTHING.

UM, AND WANT TO SAY THANKS.

WELL, THANK YOU.

I'D LIKE TO SAY THANK YOU TO ERCOT AND ESPECIALLY LUBBOCK AND THE OTHER TWO CO-CHAIRS OF L-R-I-T-F.

UH, IT'S MICHAEL WEINGART WITH LUBBOCK POWER AND LIGHT.

CHRIS RALLY WITH ENCORE AND SHERI WIGAN WITH, UH, TXU.

AND I'M, I CAN'T TELL YOU HOW MUCH WORK, I CAN'T TELL YOU.

AND ERCOT HAS WORKED WITH US JUST CONSTANTLY.

I MEAN, YOU KNOW, REALLY FRIDAYS AT FIVE O'CLOCK, WE'RE STARTING A MEETING.

IT'S JUST SAD.

SO ANYWAY, WE ARE MOVING FORWARD AND I HOPE THIS IS THE LAST R-M-G-R-R PRIOR TO, UH, CUT OVER TO COMPETITION.

ALL RIGHT, ANOTHER ITEM TO CONSIDER IS THE TEXAS AT 5.0 TIMELINE.

WE ARE LOOKING REALLY GOOD, UM, FOR A IMPLEMENTATION CUTOVER OF OCTOBER 10TH, 2024.

UM, LOTS OF WORK BEING DONE ON THIS.

IT DOESN'T LOOK THAT THAT MUCH, BUT IT REALLY IS, UH, THIS IS THE TIMELINE THAT WAS IN THE, UM, PPL OR WAS DEVELOPED BY THE PMO OFFICE.

AND IT WILL BE PRESENTED AT RMS TOMORROW FROM, UH, CATHERINE THURMAN, WHO IS CHEERING THE MARKET COORDINATION TEAM FOR TEXAS AT 5.0.

ALL RIGHT, THANK YOU.

ANY QUESTIONS? OKAY.

UM, SO NOW WE CAN MOVE ON TO THE ROSS REPORT.

SO WE WOULD HAVE THE ONE VOTING ITEM, UM, WHICH IS R-M-G-R-R 1 76, AS RECOMMENDED BY RMS AND THE NOVEMBER 7TH RMS REPORT AND THE NOVEMBER 14TH IMPACT ANALYSIS.

UM, I THINK WE CAN PUT THIS ON THE COMBO BALLOT UNLESS ANYONE HAS OBJECTIONS.

ALL RIGHT, THANKS EVERYONE.

[8. ROS Report]

I BELIEVE KATIE RICH IS GIVING THIS MONTH'S REPORT.

YEAH, THANKS CAITLIN.

SO THIS IS THE FIRST MONTH IN A WHILE THAT WE HAVEN'T HAD ANY VOTING ITEMS, SO THAT KIND OF STREAMLINES OUR DISCUSSION TODAY.

UM, WE CAN MOVE ON TO THE NEXT SLIDE.

SO JUST WANTED TO, TO HIGHLIGHT A COUPLE OF THINGS HERE.

UM,

[02:10:01]

NPR 1180, WE DISCUSSED THAT AT SOME LENGTH AND, AND JUST WANTED, YOU KNOW, TACK TO BE AWARE THAT, YOU KNOW, IT WAS A VERY NARROW VOTE ON THIS.

IT COMES BACK FOR IA REVIEW, UM, AND IT'S A FEW DAYS, BUT, UM, JUST WANTED TO GIVE YOU A HEADS UP ON KIND OF HOW THIS DISCUSSION WENT.

UM, AND THEN LATER WE'LL DISCUSS THE AS METHODOLOGY, BUT FROST DID ENDORSE THAT, AND THEN WE'VE HAD, UM, A COUPLE OF CHANGES IN WORKING GROUP LEADERSHIP.

SO WE APPRECIATE THEM STEPPING UP INTO THOSE ROLES.

AND WITH THAT, YOU CAN MOVE ON.

KATIE, WE HAVE ONE QUESTION.

MARK DREYFUS, GO AHEAD.

YEAH, I HAVE A, I'M SORRY, MARK, GO AHEAD.

I HAVE A QUESTION ABOUT, UH, NPRR 1180.

UM, THE LEGISLATION THAT UNDERLIES THIS NPR R'S PAST TWO AND A HALF YEARS AGO, THIS SEEMS LIKE A REALLY IMPORTANT ISSUE TO ME THAT, THAT WE'RE WAITING FOR APPROVAL OF THIS NPRR FOR A WHOLE SLUG OF NEW, UH, TRANSMISSION PROJECTS TO SERVE LOAD GROWTH AREAS ARE, ARE IN THE QUEUE.

AND SO I'M JUST WONDERING WHEN WE SHOULD EXPECT TO SEE THE AIR CUT COMMENTS.

'CAUSE I'VE BEEN HEARING FOR MONTHS, IF I'M CORRECT, THAT THIS ISN'T MOVING FORWARD.

'CAUSE WE'RE WAITING FOR ERCOT COMMENTS.

SO I, I'D LIKE TO SEE IT WOUND UP.

SO I JUST HOPE THAT WE CAN, UH, GET THOSE COMMENTS SOON AND FINALIZE THE DISCUSSION AND MOVE FORWARD.

SOMEONE FROM ERCOT WANNA RESPOND TO THAT IS, UH, I MEAN, I, I I CAN COMMIT THAT.

WE'LL, WE'LL TAKE YOUR FEEDBACK AND, AND SEE WHAT WE CAN DO TO START THINGS MOVING MORE QUICKLY.

UH, BUT I DO WANNA SEE IF ANYBODY IS ON THE PHONE FROM ERCOT THAT MAY HAVE ADDITIONAL INFORMATION TO SHARE.

I DON'T SEE PAIN ON IT.

IS IS THAT SUFFICIENT, MARK, OR DO I, DO YOU NEED YES, I, FOR ANYTHING ELSE? I REALLY APPRECIATE YOUR COMMITMENT.

THANKS KENAN.

ERIC GOFF, ARE YOU IN THE QUEUE? UH, THEY COVERED IT.

THANKS, MARK.

ALL RIGHT, KATIE, I THINK WE CAN GO BACK TO YOUR PRESENTATION.

HEY, CALIN.

OKAY, NEXT SLIDE PLEASE.

ALL RIGHT, SO, UM, AS ALWAYS, WE'VE ENDEAVORED TO KIND OF LET YOU KNOW WHICH WORKING GROUP, UM, YOU KNOW, MOST OF THESE, UH, N PRRS AND, AND NUMBERS AND FIGURES ARE UP TO THAT FOLKS CAN PLUG IN APPROPRIATELY.

UM, YOU KNOW, WE'RE WORKING THROUGH A LOT OF THESE, SO, UM, WE'LL SEE THE PROGRESS WE HAVE, UM, IN OUR MEETINGS THE NEXT COUPLE OF DAYS.

UM, THAT LIST KIND OF CONTINUES ONTO THE NEXT SLIDE.

IT, ALL RIGHT.

AND THEN IF YOU COULD GO TO THE NEXT ONE, WE'LL TALK ABOUT SOME OF THE RECENT DISCUSSION ITEMS. SO WE'VE, UM, TSAP, UM, AND SO WE, WE SENT THAT OVER TO IBR WG TO TALK ABOUT SOME OF THE IMPLEMENTATION CHALLENGES.

AND, UH, ONE THING WE'VE BEEN WORKING ON REALLY HARD, AND I KNOW WMS AS WELL, IS LOOKING AT OUR OPEN ACTION ITEMS, INCLUDING, INCLUDING SEEING WHAT WE CAN CLOSE OUT AND, UM, ADDING A NOTES TAB THAT LETS US TRACK THOSE, UM, A LITTLE BETTER ON, ON THE PROGRESS, UM, AS THEY'RE MOVING THROUGH THE WORKING GROUP.

UM, AND SO THAT, THE NEXT ONE IS A GOOD EXAMPLE OF THAT.

SO THERE WAS SOMETHING ABOUT, YOU KNOW, OR CUT FORECAST AND REVIEW OF THE DASHBOARD INFORMATION.

AND SINCE THERE'S BEEN A COUPLE OF SCR FILES, WE FEEL LIKE THIS IS SOMETHING THAT CAN BE CLOSED OUT AT ROSS.

IT FEELS LIKE IT'S GONNA MOVE THROUGH THE STAKEHOLDER PROCESS.

SO, UM, JUST WANTED TO NOTE THAT.

AND THEN OUR NEXT MEETING WILL BE ON THURSDAY AND IT IS WEBEX ONLY SO SOON.

AND FOR THAT, AND I'LL ANSWER ANY OTHER QUESTIONS YOU MIGHT HAVE.

SO NEXT UP WE HAVE THE WMS REPORT.

I DON'T SEE ANY QUESTIONS IN THE QUEUE OR IN THE ROOM.

THANK YOU, KATIE.

GREAT, THANKS AGAIN.

SO WE DON'T HAVE ANY VOTING ITEMS FROM, UH, ROSS THIS MONTH.

THAT WAS A REALLY HELPFUL PAGE ON SLIDE ON THE, THE NPRS AND WHERE THEY ARE THOUGH, WHICH WORKING GROUPS.

[9. WMS Report (Vote)]

ERIC BLAKEY, YOU SHOULD BE GOOD.

YOU CAN EITHER USE THE MOUSE WHEEL

[02:15:01]

OR THE ARROWS, YOU KNOW, ARROWS UP OR DOWN.

OKAY, GREAT.

GOOD MORNING.

ERIC BLAKEY WITH THE PERELLIS CO-OP, UH, CHAIR OF WHOLESALE MARKET SUBCOMMITTEE THIS YEAR.

UH, HAVE A FEW UPDATES.

I'LL TRY TO BE BRIEF.

WE HAD OUR 2023, UH, THIRD QUARTER SETTLEMENT STABILITY REPORT.

UH, THIS REPORT TRACKS THE NUMBER OF PRICE CHANGES, RESETTLEMENTS AND NUMBERING TYPES OF DISPUTES SUBMITTED, INCLUDED INFORMATION RELATED TO THE NET ALLOCATION TO LOAD, ALONG WITH SECURITIZATION DEFAULT CHARGES AND UPLIFT CHARGES.

WE ALSO HAD A REPORT ON 2023, UH, THIRD QUARTER UNREGISTERED DISTRIBUTED GENERATION.

AND IT SHOWED COMBINED DG INSTALLED CAPACITY OF 2.3, UH, 2,384 MEGAWATTS, WHICH WAS AN 87 MEGAWATT INCREASE OVER Q2.

ERCOT IS TAKING INTO ACCOUNT THE EFFECTS OF ROOFTOP SOLAR IN THE SHORT TERM AND MIDTERM LOAD FORECAST.

WE ALSO HAD UPDATES ON SOME THINGS THAT ARE GONNA BE COMING UP LATER IN TODAY'S AGENDA, SO I WON'T TRY TO REPEAT SOME OF THAT.

I'LL SAVE THAT DISCUSSION.

BUT FIRST WAS THE MITIGATED OFFER CAP FOR ESR RESOURCES.

ERCOT PROVIDED A PRESENTATION AND THIS WILL BE TAKEN UP.

UH, PROTOCOLS REQUIRE THAT BY DECEMBER 31ST OF THIS YEAR, THAT ERCOT AND STAKEHOLDERS SUBMIT A REPORT TO TAC THAT INCLUDES A RECOMMENDATION TO CONTINUE THE EXISTING APPROACH OR A PROPOSAL TO IMPLEMENT AN ALTERNATIVE APPROACH TO DETERMINE THE MITIGATED OFFER CAP FOR ESRS.

AND ULTIMATELY, WMS DID NOT TAKE FORMAL ACTION ON THE ITEM.

SO THIS WILL BE DISCUSSED FURTHER TODAY.

NEXT, WE HAD THE ERCOT UPDATE ON THE OCTOBER 22ND MARKET SUBMISSION ISSUE.

THIS WAS, I BELIEVE, DISCUSSED VERY BRIEFLY LAST MONTH, AND IT IS ALSO ON THE AGENDA FOR FURTHER DISCUSSION TODAY.

SO I WON'T SPOIL ANY OF THAT.

AND THEN, UH, APPROVED THE, UH, OR ENDORSE THE CHANGES, UH, TO THE ANCILLARY SERVICE METHODOLOGY.

AND AGAIN, ANOTHER ITEM WE WILL BE TALKING ABOUT FURTHER.

SO I DON'T WANNA SPOIL THAT.

UH, AS FAR AS DISCUSSION ITEMS, WE DID APPROVE AND WE DO HAVE A VOTING ITEM FOR CHANGES TO OUR WMS PROCEDURES.

IT'S A VERY MINOR CHANGE, UM, THAT, THAT WE'VE DISCOVERED DURING THE ANNUAL REVIEW PROCESS.

SO WE WOULD ASK THAT, UH, TAC APPROVE THOSE CHANGES.

AND, UH, THEN REAL QUICK, I'LL, I'LL LET YOU VOTE WHEN I'M DONE, IF THAT'S OKAY.

UM, WE HAD SOME NEW PRS REFERRALS, UH, NPR 1197, ENERGY STORAGE RESOURCE NON CHARGING LOADS, OPTIONAL EXCLUSION FROM EPS NETTING ARRANGEMENT WAS TABLED AND REFERRED TO M-W-G-N-P-R 1198, CONGESTION MITIGATION USING TOPOLOGY.

RECONFIGURATIONS WAS TABLED AND REFERRED TO CMWG AND NPR 1200 WAS, IS UTILIZATION OF CALCULATED VALUES FOR NON WSL FOR ESRS THAT WAS TABLED AND REFERRED TO MWG.

AND THESE, UH, THIS IS A LIST OF OUR TABLED REQUESTS.

UH, NO REAL CHANGE ON THESE, THEY REMAIN TABLED.

AND THEN WE HAD ONE CHANGE IN OUR WMWG LEADERSHIP.

UH, WE, WE MOVED COLIN WVI WITH NG RENEWABLES TO THE CHAIR, AND BRIAN SAMS HAS AGREED TO FILL IN AS VICE CHAIR THIS YEAR.

AND THEN WE WILL HAVE ELECTIONS FOR NEXT YEAR.

BUT I WANNA JUST SAY PUBLICLY, MY THANKS TO JOHN RICH.

HE DID A AWESOME JOB AS OUR CHAIR OF WWG THIS YEAR.

HE HAD A JOB CHANGE AND SO, UH, WANNA WISH HIM WELL.

AND, UM, OUR NEXT MEETING IS WEDNESDAY, AND SO YOU'RE ALL INVITED AND I HOPE YOU'LL APPROVE OUR PROCEDURE CHANGE.

AND ANY OTHER QUESTIONS I'LL BE HAPPY TO ANSWER.

I DON'T SEE ANY QUESTIONS.

ERIC.

I SEE I KIND OF GOING BACK TO THE ROSS REPORT, BUT LET'S FINISH UP WMS, UM, REAL QUICK AND THEN GET TO THAT.

CAN WE SEE THAT, THAT VOTING? I'M, UM, WE HAVE THE, THE CHANGE TO THE WMS PROCEDURES.

THANKS, COREY.

ERIC, DID YOU WANNA COMMENT ON, I KNOW IT'S A SMALL CHANGE.

YEAH, I'LL JUST, I'LL JUST MENTION THIS OTHER, OTHER THAN, UH, ADDRESS CHANGES AND SOME OTHER THI AND THE DATE, I BELIEVE THIS FIRST CHANGE, WE

[02:20:01]

WERE JUST TRYING TO CLARIFY THAT WMS WOULD NOT INTEND TO, TO FILE A CHANGE THAT WE WOULD WORK WITH ERCOT OR MARKET PARTICIPANT TO, TO FILE THE CHANGE.

AND THEN WE BELIEVE THAT SECOND CHANGE, INSTEAD OF, UH, REFERRING BACK TO WMS, WE WOULD REFER THAT TO, TO T.

SO THOSE ARE, I BELIEVE, THE ONLY TWO REAL CHANGES THAT WE MADE.

MAKES SENSE.

SO THIS IS UP FOR A VOTE TODAY.

UM, IF THERE'S QUESTIONS OR COMMENTS ON THIS.

OTHERWISE, I THINK WE COULD REFER THIS TO THE COMBO BALLOT, AND THE ITEM WOULD BE APPROVE THE WMS PROCEDURES AS SUBMITTED.

MM-HMM, .

I DON'T SEE ANY COMMENTS, SO I THINK WE CAN GO AHEAD AND PUT THAT ON THE COMBO BALLOT.

THANK YOU, ERIC.

SO, UH, SUN W IS IN THE QUEUE TO GO BACK TO THE, THE QUESTION ON NPR 1180.

THIS WAS PART OF THE ROSS REPORT.

UM, MARK DREYFUSS, THIS IS YOUR, YOUR QUESTION ABOUT, I THINK, TIMELINE ON 1180 AS IT, ITS IMPLEMENTATION OF LEGISLATION THAT WAS PASSED TWO SESSIONS AGO.

THAT WAS SENATE BILL 1281, WHICH AMONG OTHER PROVISIONS, UH, ALLOWS FOR FORECASTED LOAD AND REQUESTED INTERCONNECTIONS TO BE CONSIDERED IN THE TRANSMISSION PLANNING PROCESS.

AND I, IT'S MY UNDERSTANDING THAT THERE ARE A NUMBER OF TRANSMISSION PROJECTS THAT ARE RESPONSIVE TO ANTICIPATED LOAD THAT WILL BE BEFORE THE RPG.

AND SO I'M INTERESTED IN KNOWING WHEN THE NPRR WILL BE FINALIZED AND, AND THE RELATED PIG.

SO, UH, TO IN ANTICIPATION OF THESE COMING FORWARD.

SUN WILL AGREE ON THE CHAT.

OH, YOU'RE HERE.

CAN YOU HEAR ME? GO AHEAD.

YEAH, SO THIS IS SUN FROM, UH, ERCOT PLANNING.

UM, I CHECKED WITH CCA STEPS AND, UM, UH, OUR TARGET IS TO FIRE A COMMENTS, COMMENTS, UM, BEFORE DECEMBER PLW TEAM MEETING, I BELIEVE THERE WILL BE A DISCUSSION ABOUT THE SCHEDULES AND TIMELINE AND, YOU KNOW, A LOT MORE DETAILS ON THIS, UH, NPR.

SO JUST WANNA, UH, COMMENT ON THAT, UH, JUST WHAT I WAS LOOKING FOR.

THANK YOU SO MUCH.

AND I SEE ONE MORE FOLLOW, FOLLOW-UP QUESTION FROM ROSS.

THIS REFERS TO IS, IS THIS ON THE SAME NPRR CONSTANCE STEEL? WOULD YOU LIKE TO ASK YOUR QUESTION? YES.

DID SAY THAT NPRR 1180 IA WOULD BE AT ROSS FOR IA REVIEW, OR DID SHE MISHEAR? SHE DOESN'T SEE THAT ON THE AGENDA FOR THE SEVENTH.

I BELIEVE.

I, I, I CAN DEFER TO , BUT I, I WOULD THINK THAT THAT WOULD WAIT FOR COMMENTS AS WELL.

AND NPR 1180 HASN'T BEEN APPROVED BY PRS YET, SO WE WOULD NOT HAVE AN IA AT THE ROSS MEETING.

I THINK WE CAN MOVE ON TO THE CREDIT FINANCE SUBGROUP REPORT.

ARE WE WRAPPED UP ON 1180 FROM THE ROSS REPORT? OKAY.

[10. Credit Finance Sub Group (CFSG) Report]

BRENDAN, ARE YOU READY? UH, YEAH, CAN YOU HEAR ME? WE CAN HEAR YOU GO AHEAD.

GREAT, THANKS.

UH, HEY EVERYBODY.

THIS IS BRENDAN, UH, REPORTING FROM OUR 15 NOVEMBER MEETING.

WE LOOKED AT ONE NPRR, IT DID NOT HAVE CREDIT IMPACTS.

WE'RE LOOKING AT A NEW INVOICE REPORT, SOME CHANGES TO THE EAL AND THE DISCUSSION ON LETTER OF CREDIT, UH, CONCENTRATION LIMITS ALONG WITH OUR REGULAR UPDATES.

WHILE WE LOOKED AT NPR 1204, CONSIDERATIONS OF STATE OF CHARGE WITH REAL-TIME, CO-OP OPTIMIZATION IMPLEMENTATION, UH, WITH URGENT STATUS, THE CREDIT AND CFSG REVIEWED AND DO NOT BELIEVE IT REQUIRES CHANGES TO CREDIT MONITORING OR CALCULATION OF LIABILITY.

ERCOT STAFF, UH, PUT TOGETHER A REPORT THAT WOULD COME OUT, UH, DAILY FOR THE CURRENT DAY AND THE PRIOR DAY.

UH, NRG HAD REQUESTED, UM, THAT WE CREATE AN INVOICE REPORT.

UM, BASICALLY THERE'S, UH, SEVERAL INVOICES THAT OCCUR.

SOME ARE QUARTERLY, SOME ARE LESS FREQUENT, SOME ARE THAT, YOU KNOW, YOU DON'T GET ON A, ON A DAILY OR PREDICTABLE BASIS.

SO THEY HAD REQUEST, UH,

[02:25:01]

UM, AND IT'S GONNA BE USED BY COUNTERPARTIES TO ENSURE THEY'RE AWARE OF ALL INVOICES POSTED AND TO ASSURE TIMELY PAYMENT.

UH, ERCOT HAD NOTICED ON THEIR SIDE TO PARTICULARLY WITH, UH, WIDE AREA NETWORK AND ERO INVOICES THAT, UM, PEOPLE WERE MISSING THESE, THEY WERE HAVING TO CHASE 'EM DOWN.

SO ERCOT SUPPORTS IT.

AND, UH, NEXT STEP, IT'S AT PRS FOR IT'S DECEMBER MEETING.

POTENTIAL EXPOSURE INCREASE FROM 2.5 BILLION TO 2.88 BILLION AND INCREASE DUE TO HIGHER FORWARD ADJUSTMENT FACTORS IN OCTOBER.

UH, THIS IS SOMETHING THAT WE'VE BEEN TALKING ABOUT FOR A WHILE.

THIS GROUP, UH, CONSTANTLY EVALUATES THE, UH, CALCULATION OF LIABILITY AND, UH, COLLATERAL OBLIGATIONS TO THE MARKET.

UM, DC AND RAINBOW HAD REQUESTED CHANGES.

UH, AND LOOKING AT THE PARAMETERS THAT DEFINE A COUNTERPART'S COLLATERAL OBLIGATION, UH, ONE THING THAT WE'RE LOOKING AT IS TO, UH, THE, THE CORE OF THE CALCULATION IS BASICALLY INVOICE EXPOSURE FROM ALL THE DIFFERENT INVOICES THAT ARE DUE.

UM, THE, YOU KNOW, THE DOMINATING FACTOR IN THESE, FOR THE MOST PART IS, YOU KNOW, REAL TIME AND DAY AHEAD ACTIVITY.

UH, THESE ARE LOOKED AT SEPARATELY, AND THESE FORWARD ADJUSTMENT FACTORS ARE APPLIED TO THOSE, UH, UH, PEOPLE IN THE GROUP WANT TO LOOK AT COMBINING THESE SINCE, YOU KNOW, UM, THEY CAN HEDGE REAL TIME AND STRATEGY AND SO FORTH.

SO, WE'RE, UH, LOOKING AT, AS ERCOT HAD INDICATED, THAT'S, THAT'S A BIT OF A LIFT, BUT, UM, WE'RE GONNA LOOK AT THAT OVER A PERIOD OF TIME.

UM, WE'RE ALSO LOOKING AT THE LOOKBACK PERIOD, WHICH IS DESIGNED TO, UH, YOU KNOW, ALLOW FUNDS TO BE AVAILABLE FOR A MASS TRANSITION.

UH, LOOKING AT THE FORWARD ADJUSTMENT FACTORS, WHICH ARE RATIO OF FORWARD TO PASS PRICES TO CAPTURE, YOU KNOW, A SUDDEN SPIKE IN ACTIVITY, THE COLLATERAL REQUIREMENTS WOULD INCREASE FOR THE MARKET.

SO IF THERE'S A DEFAULT SCENARIO, THEN THERE WOULD BE ADEQUATE FUNDS.

UH, AND WE'RE GONNA CONTINUE TO EVALUATE THESE, UH, EAL CALCULATION.

AND, UM, ERCOT HAS, UH, PRESENTED FOUR SEPARATE SCENARIOS TO INVOLVE APPLYING FORWARD ADJUSTMENT FACTORS AGAINST THE REAL TIME LIABILITY AND REMOVING THE MAX FUNCTION FROM THE 40 DAY LOOKBACK PERIOD.

UM, THERE'S ANOTHER SCENARIO THAT INVOLVES, UH, COUNTERPARTY LEVEL, CUSTOMIZED FORWARD ADJUSTMENT FACTORS, AND, UM, THEY HAVE A COUPLE OF OTHER SCENARIOS THAT WE ARE WAITING TO SEEK.

UH, NEXT SLIDE, PLEASE.

WE HAD A DISCUSSION ON LETTERS OF CREDIT.

SO, UH, YOU MAY RECALL AT IN OCTOBER, THEY GOT, UH, ERCOT REMOVED, UM, THE UNSECURED CREDIT FROM THE MARKET.

UH, PEOPLE WERE GONNA HAVE TO, UH, YOU KNOW, POST COLLATERAL TO, UM, YOU KNOW, RE REPLACE THAT IF, IF IT WAS BEING UTILIZED.

SO THEY'VE BEEN, UH, CHECKING ON THAT IF THEIR LIMITS ARE BEING BREACHED FOR, UH, INDIVIDUAL LETTER OF CREDIT ISSUERS.

SO THEY HAVE, UH, $750 MILLION LIMIT PER ISSUER WITH SOME LIMITS BASED ON RATINGS.

UH, ONCE A LIMIT IS BREACHED, YOU NO MORE NEW LCS FROM THAT ISSUER OR INCREASES FROM THAT ISSUER WILL BE ACCEPTED BY THE MARKET CREDIT.

BBVA HAVE BREACHED AND SIX OTHER ISSUERS ARE IN THE DANGER ZONE.

UH, WE DISCUSSED THE POSSIBILITY OF RAISING THESE LIMITS.

UM, THIS IS THE FIRST TIME WE'VE LOOKED AT IT.

IT'S NOT A HUGE PROBLEM.

I THINK THEY HAVE 38 ISSUERS NOW, AND THIS, UM, REPRESENTS LIKE LESS THAN 1% OF THE TOTAL ISSUERS THAT THEY HAVE.

AND THEN THERE'S A LARGER UNIVERSE OF ISSUERS THAT THEY COULD POTENTIALLY HAVE.

UM, BUT IT, IT, IT'S SOMETHING, UH, THAT WE'RE GONNA LOOK AT, UH, I THINK ON A REGULAR BASIS AND, AND WE'LL REPORT IT UP.

UH, SO WE HAVEN'T TAKEN ANY ACTION, BUT OTHER THAN TO, UM, YOU KNOW, ASK ERCOT STAFF TO MAYBE PRESENT A SLIDE ON THIS.

SO WHAT THE CURRENT SNAPSHOT IS FROM MONTH TO MONTH.

UH, NEXT SLIDE PLEASE.

SO HERE'S A, HERE'S A PICTURE OF THAT.

UH, YOU CAN SEE THAT, UM, THESE ARE THE BANKS THAT CREDIT AGRICUL AND BBBA HAVE REACHED.

WE HAVE, UM, LOOKS LIKE ABOUT SIX MORE.

YOU KNOW, COBANK AND DNB ARE VERY CLOSE AS OF OUR NOVEMBER 15TH MEETING.

AND, UM, THOSE OTHER SUCTION, B-B-N-P-R-B-C AND LLOYD'S ARE ALL ABOVE 60, UH, AND GETTING CLOSE.

SO I, WE, WE MAY PRESENT ON THIS AT MEETINGS IN THE FUTURE AND JUST KEEP AN EYE ON IT.

UH, NEXT SLIDE PLEASE.

SO, UH, HERE'S THE MONTHLY HIGHLIGHTS.

YEAR TO DATE THROUGH OCTOBER, UH, MARKET-WIDE

[02:30:01]

UH, WE'RE LOOKING AT DISCRETIONARY COLLATERAL, WHICH DECREASED FROM 5.04 TO 4.33 BILLION IN OCTOBER, AND THERE WASN'T ANY UNUSUAL CALLS.

WE CAN MOVE ON TO THE LARGE FLEXIBLE LOAD TASK FORCE REPORT.

UH, HERE'S THE, WHAT WE'RE LOOKING AT UP TILL OCTOBER.

UM, YOU KNOW, YOU CAN SEE THAT THE, UH, THE GREEN SPOTS THAT YOU SEE THROUGH THOSE BARS HAD DISAPPEARED.

AS I MENTIONED, THAT'S THE UNSECURED COLLATERAL THAT IS NO LONGER THERE.

UH, THAT'S OBVIOUSLY BEING REPLACED IF NEEDED BY, UM, CASH AND LCS.

PRETTY MUCH.

THEY ALSO TAKE SURETY BONDS, BUT THIS IS FOLLOWING, UH, YOU KNOW, THE SEASONAL PATTERN THAT WE SEE IN THE MARKET AND NOT A LOT OF NEWS HERE OTHER THAN THE ELIMINATION OF THE UNSECURED CREDITS.

UH, NEXT SLIDE PLEASE.

AND HERE WE'RE LOOKING AT DISCRETIONARY COLLATERAL BETWEEN, UH, SEPTEMBER AND THE END OF OCTOBER.

UM, THIS BASICALLY ALLOWS, UH, COUNTERPARTIES TO COVER THEIR CREDIT OBLIGATIONS, CREDIT LOCKS, AND THEN ACCESS TO DAY AHEAD.

UH, SO NOTHING TOO INTERESTING REPORT HERE.

IT'S GOING DOWN FOLLOWING SEASONAL PATTERNS.

AND NEXT SLIDE.

ALRIGHT, THAT'S IT.

ANY QUESTIONS? SEE, I DON'T SEE ANY QUESTIONS.

[11. Large Flexible Load Task Force (LFLTF) Report]

BILL BLEVINS, ARE YOU HERE ON THE PHONE TO GIVE THIS REPORT? YEP, I AM.

GREAT.

MOST OF THOSE WE TALKED ABOUT AT THE, UM, AT AN EARLIER MEETING.

UH, I GUESS QUICKLY, WE HAD A MEETING SCHEDULED, UM, FOR NOVEMBER THE 20TH.

WE ENDED UP CANCELING THAT ONE BECAUSE WE DIDN'T GET ANY, UM, COMMENTS ON THE TOPIC THAT WAS GOING TO BE DISCUSSED, WHICH WAS RAMP RATE.

UM, WE DID GET SOME, UM, SOME COMMENTS THAT CAME IN SLIGHTLY AFTER, UM, WE'D ALREADY STARTED CANCELING THE, THE MEETING.

UH, WE'RE LOOKING AT THOSE RIGHT NOW.

WE PLAN ON TALKING ABOUT THOSE ON THE JANUARY 3RD MEETING, WHICH WOULD BE THE NEXT TIME THAT TOPIC COMES UP.

UM, JUST TO GIVE YOU A FLAVOR FOR THOSE COMMENTS, UM, I THINK SOME OF 'EM WERE GONNA HELP US, UM, IMPROVE WHAT WE'VE ALREADY POSTED.

GENERALLY, LIKE CLARIFICATIONS AROUND LARGE FACILITIES, UM, THAT MIGHT HAVE A TRIP OR THEY'RE STARTING UP OR SHUTTING DOWN.

UM, OR IF THEY HAVE ANCILLARY SERVICE OBLIGATIONS, UM, THEY MIGHT HAVE, UM, A CERTAIN AMOUNT THAT THEY OFFERED AND THEN THEY DIDN'T GET AWARDED THAT FULL AMOUNT.

UM, AND HOW DOES THE RAMP RATE APPLY THERE? SO I THINK THOSE COMMENTS WERE HELPFUL TO US, AND WE'RE GONNA TAKE IT BACK AND, AND TRY TO WORK WITH, UH, SOME OF THOSE WHERE WE CAN ADD CLARIFICATION.

UH, THERE WAS ALSO SOME IDEAS IN THESE COMMENTS THAT CAME IN ABOUT IMPROVEMENTS THAT WE COULD MAKE FOR SOME OF THE GRANDFATHERING.

UM, I THINK SOME ISSUES WHERE, YOU KNOW, IF YOU HAD A FACILITY AND YOU NEEDED TO REPLACE SOME EQUIPMENT, MAYBE THE EQUIPMENT THAT YOU ORIGINALLY INSTALLED ISN'T AVAILABLE AND THE NEXT PIECE OF EQUIPMENT, UM, THAT YOU GET WOULD BE BIG ENOUGH THAT IT MAY PUSH YOU OVER THAT LARGE LOAD THRESHOLD.

SO, WE'LL, WE'LL BE LOOKING IN AT THAT AND TALKING ABOUT THAT IN THE JANUARY MEETING, UM, TO ADDRESS THOSE COMMENTS THAT WE DID RECEIVE AFTER THE, UH, MEETING WAS CANCELED IN NOVEMBER 20TH.

THE NEXT MEETING WE HAVE IS NEXT MONDAY, AND WE'VE KIND OF TAKEN AN APPROACH THAT WE'LL GIVE A MONTHLY UPDATE AS FAR AS THE QUEUE.

SO, UM, THE FIRST MEETING THAT WE HAVE IN THE MONTH IS WHERE WE'LL DO THAT.

SO WE'LL HAVE THAT DISCUSSION JUST TO LET FOLKS KNOW, UM, WHERE SOME OF THESE PROJECTS ARE.

WE DO HAVE A, A LARGE NUMBER OF PROJECTS THAT, UM, WE'RE STILL WAITING ON.

THEY'VE BEEN APPROVED FOR, UM, THEIR STUDY PARTS OF THIS, BUT WE HAVEN'T SEEN ACTUALLY THEM REQUESTING TO MOVE FORWARD WITH SOME OF THOSE PROJECTS.

UM, BUT WE HAVE HAD A FEW CANCELLATIONS, UM, WE'VE BEEN TOLD ON SOME OF THESE LARGE LOAD, UM, IF THEY TAKE TOO, TOO LONG TO DECIDE TO MOVE FORWARD, WE MAY HAVE TO REST STUDY THEM.

SO, UM, WE'LL, WE MAY TALK ABOUT THAT A LITTLE BIT IN THE MEETING, UH, FOR THE TOPICS THAT WE'LL BE DISCUSSING AT, UM, THIS NEXT MEETING, NEXT MONDAY, UH, WE'RE GONNA HAVE OUR SECOND DISCUSSION ON INTERCONNECTION PROCESSES.

AND, UM, GENERALLY THE FEEDBACK THAT WE'VE RECEIVED, UH, CAME FROM THE TRANSMISSION COMPANIES THAT HAVE BEEN WORKING WITH US ON THOSE INTERCONNECTION.

AND, UM,

[02:35:01]

AND GENERALLY WE CAN ACCEPT MOST OF THOSE, UH, COMMENTS THAT WE RECEIVED.

SO HOPEFULLY THAT THAT TOPIC WILL GO FAIRLY QUICKLY.

UH, WE DID HAVE AT, UM, THE NOVEMBER THE, THE MEETING THAT WE DID HAVE IN NOVEMBER, UM, A PROPOSAL FROM BILL BARNES ABOUT SOME IDEAS THAT MIGHT MAKE IT MORE, UH, OF AN INCENTIVE TO REGISTER AS ONE OF THESE, UH, FLEXIBLE TYPE LOADS, REGISTER REGISTERED CURTAIL TYPE LOADS.

UM, AND WE'RE GONNA HAVE A DISCUSSION AT THE, UM, MEETING NEXT WEEK, UM, MORE FLESHING OUT, UH, WHAT BILL'S PROPOSAL WAS, BUT I'LL JUST SUMMARIZE IT FOR YOU GUYS THAT, UM, THERE MIGHT BE SOME CREDIT THAT YOU COULD GET IF YOU REGISTER AS A, UM, EITHER A CLR OR AN NCLR OR AS A REGISTERED CURTAIL TYPE LOAD WHERE YOU, UM, CAN REDUCE SOME OF YOUR ANCILLARY SERVICE OBLIGATIONS.

THAT'S GENERALLY THE IDEA OR THE THINKING THAT'S GONNA BE DISCUSSED THERE.

AND THEN THE OTHER TOPIC THAT WE'LL BE TAKING OUT FOR THE FIRST TIME IS VOLTAGE RIDE THROUGH.

WE HAVE NOT RECEIVED TODAY IS ACTUALLY THE DEADLINE FOR US TO RECEIVE MATERIALS FROM THE MARKET PARTICIPANTS ON THAT, WHICH WE HAVE NOT RECEIVED, BUT WE HAVE STILL CONTINUED TO WORK ON THAT TOPIC.

AND, UM, WE'RE EXPECTING, UM, TO HAVE SOME DISCUSSION THERE ON SOME, UH, LET'S SAY MIDDLE GROUND OR, UH, COUNTER TO, UH, WHAT WE ORIGINALLY PROPOSED, UM, REGARDING RAMP OR VOLTAGE RIDE THROUGH.

SO WE DO EXPECT TO TAKE UP THE TOPIC.

WE WOULD HOPE THAT WE COULD GET SOME COMMENTS FROM FOLKS, UM, FROM THE MARKET PARTICIPANTS ON RIDE THROUGH.

UM, IF WE GET 'EM LATE, WE'LL JUST DO LIKE WHAT WE'RE DOING WITH THE RAMP RATE AND WE'LL JUST PUT IT TO THE NEXT MEETING.

BUT THAT'S WHERE WE ARE AND THAT'S, THAT'LL BE THE TOPICS THAT WE'RE GONNA BE COVERING NEXT.

ANY QUESTIONS? THANKS, BILL.

I DON'T SEE ANY QUESTIONS RIGHT NOW.

ARE THERE ANY QUESTIONS IN THE ROOM? ALL RIGHT, THANK YOU.

ALRIGHT, THANKS.

[12. RTC+B Task Force Report]

WE ARE ON TO THE RTC PLUS B TASK FORCE REPORT.

GOOD AFTERNOON TECH.

THIS WILL BE SHORT.

UH, THE FIRST PART WAS A THANK YOU FOR THE WORK ON 1204, UM, AS REALTIME COOP OPTIMIZATION.

GOT UP AND RUNNING, THE BIGGEST THING WAS TAKING THE REQUIREMENTS OFF THE SHELF FROM THREE YEARS AGO AND TUNING 'EM UP.

AND THE MAIN THING IN FRONT OF US WAS THE STATE OF CHARGE.

AND IT WASN'T TO SOLVE ALL THE STATE OF CHARGE, UM, MODELING WITHIN THE APPLICATIONS THEMSELVES, BUT IT WAS TO HELP LINE UP THE INPUTS AND OUTPUTS AND HOW THEY'RE CONSIDERED AND THE OPTIMIZATION TO GET OUT.

SO THERE'S STILL A LOT OF WORK TO BE DONE IN TERMS OF PARAMETERS AND VALUES AND FILLING IN THE BLANKS, BUT AT THIS POINT, WE HAVE THE DESIGN THAT WE NEED IN 1204 AND APPRECIATE THE SUPPORT TODAY.

AND THEN WE DID, GO AHEAD, MARK, UH, SUSIE WAS KIND ENOUGH TO HELP GET THE DANCE CARD FULL FOR RTC IN, UH, NEXT YEAR.

SO THOSE ARE THE DATES WE'VE PICKED.

IT'S TYPICALLY, UM, A WEEK BEFORE TAC, IF I REMEMBER RIGHT.

AND THE IDEA WAS WE DON'T KNOW THAT WE'LL HAVE A LOT OF THINGS TO BRING TO TAC UNLESS WE GET STUCK.

WE'RE GONNA KEEP FOLLOWING THAT MODEL OF THREE TIMES AT AN ISSUE WHEN WE GET STUCK, BRING IT TO TAC TO HELP US GET US UNSTUCK.

BUT THE THEMES THAT WE'LL BE LOOKING AT, UM, IS A LOT.

AND THERE IS A LOT OF LEFTOVERS FROM THE REALTIME CO OPTIMIZATION TASK FORCE BACK IN 2019 AND 2020.

IT'S THE IDEA TO START PULLING THOSE OFF THE SHELF, START GETTING A CALENDAR TOGETHER FOR NEXT YEAR, AND THE HOPE IS TO HAVE SOME SORT OF SEMBLANCE OF A SCHEDULE BY THE END OF THE YEAR.

UH, DAVID KEY AND I HAD TALKED ABOUT KIND OF THE IMPORTANCE OF GETTING, UM, A CALENDAR OUT THERE, KIND OF LIKE WE DID WITH THE KEY PRINCIPLES OF HERE'S THE PROGRESSION OF DECISIONS THAT WE NEED, THAT'LL HELP BUILD ON THINGS.

UH, THERE'S ALSO THEMES OF IT.

IT MIGHT BE IMPLEMENTATION DETAILS, IT MIGHT BE THE IDEA OF WHEN WILL WE DO, UM, A RELEASE OF THE MARKET TRIAL SEQUENCES, THE CUTOVER PLANS, AS WELL AS THINGS LIKE WHAT ARE THE VALUES FOR THE, UM, AS PROXY OFFER CURVES, UH, IF SOMEONE DOESN'T HAVE AN AS OFFER IN WHAT'S THE PROXY VALUE? SO IT'S A MISHMASH OF THINGS.

SO WE'RE GONNA TRY TO HELP ORGANIZE THAT AND LEAD YOU THROUGH 2024 TO HELP GET THE SOLUTIONS ON ALL THOSE ACTIVITIES.

SO THAT'S THE TRAJECTORY WE ON.

OTHERWISE, IT WAS, THANK YOU FOR A GOOD YEAR TO GET US STARTED AND LOOK FORWARD TO NEXT YEAR.

ARE THERE ANY QUESTIONS? ALRIGHT, THANK YOU.

DON'T SEE ANY QUESTIONS.

THANK YOU, CAITLIN.

ON WHETHER IT SHOULD BE A LONGER BREAK.

OKAY, SO WE ARE ABOUT 25 MINUTES BEHIND SCHEDULE.

UM, BUT I, I THINK OUR NEXT ITEM IS THE, AN ANCILLARY SERVICES METHODOLOGY.

I THINK IT'S GONNA BE FAIRLY LENGTHY.

I I KNOW WE NEED AT LEAST A 10 MINUTE BREAK FOR ERCOT, BUT I'LL TAKE OPINIONS

[02:40:01]

UM, WE DO STILL HAVE THE AS METHODOLOGY LEFT, AND THEN I BELIEVE WE DO NEED TO GET THROUGH ALL THOSE ER CUT REPORTS TODAY.

UM, JUST, JUST THE TIMELINESS OF THEM.

UM, SO WHAT, WHAT'S THE WILL OF THE GROUP? IT'S JUST A QUICK 10 MINUTE BREAK OKAY.

AT THIS POINT, AND THEN COME BACK AND GET THROUGH THE REST OF THE SCHEDULE.

SO LET'S GO AHEAD AND COME BACK AT 1220 AND WE WILL PROCEED WITH THAT AS METHODOLOGY, THE, THE 2024 AS METHODOLOGY.

HOUR HEAD NET LOAD FORECAST ERROR AND THERI.

WE ARE, IT'S 1224, SO WE'RE A LITTLE BIT BEHIND, BUT, UM, I'LL LET EVERYBODY KIND OF GET TO THEIR SEATS AND THEN WE CAN GET STARTED WITH AGENDA ITEM 13.

[13. 2024 Ancillary Services Methodology (Vote)]

OKAY, GREAT.

SO WE ARE ON AGENDA ITEM 13, 20 24 ANCILLARY SERVICES METHODOLOGY.

UM, WE ARE GONNA SEE ERCOT RECOMMENDATION AND THEN ROS AND WMS DID VOTE ON THIS ALREADY.

SO WE'LL GET THE RECOMMENDATIONS FROM THOSE GROUPS.

AND THEN WE HAVE THE IMM GIVING THEIR RECOMMENDATION AS WELL.

AND I BELIEVE THIS IS TIKA.

GOOD AFTERNOON EVERYONE.

SO I HAVE A VERY QUICK SUMMARY OF THE PROPOSED ANCILLARY SERVICE METHODOLOGY FOR 2024 IN FRONT OF YOU, UH, ALREADY SET OF SLIDES.

BUT IT BASICALLY, UH, UH, FIRST, UH, CONFIRMS THAT WE'VE GONE THROUGH THE PROCESS OF TALKING ABOUT THE ES METHODOLOGY THROUGH THE STAKEHOLDER PROCESS SINCE ABOUT SEPTEMBER, LATE SEPTEMBER.

UH, I'VE ENDED UP INCLUDING LINKS TO ALL OF THE MATERIALS WE'VE SHARED THE BACKGROUND, THE DISCUSSIONS THAT WE HAD IN THE SLIDE DECK.

BUT AS A SUMMARY, IF WE GO THROUGH AND LOOK AT THE RED LINE CHANGES THAT ARE IN THE WORD DOCUMENT, THERE ARE NO MAJOR CHANGES THAT WE ARE PROPOSING TO REGULATION, UH, REQUIREMENTS.

WE WILL BE USING NET LOAD VARIABILITY AND DEPLOYED REGULATION FOR SETTING THE QUANTITIES WITH CERTAIN ADJUSTMENTS THAT WE TYPICALLY APPLY TO ACCOUNT FOR GROWTH IN OUR WIND AND SOLAR FLEET.

THERE IS A MINOR ADJUSTMENT WE MAY MAKE IN THE NET LOAD VARIABILITY, UH, TO ACCOUNT FOR AN ACCUMULATED, UH, ERROR IN OUR FREQUENCY CONTROL THAT WILL BETTER REFLECT BALANCING NEEDS.

UH, IN THE HOURS THAT NET LOAD VARIABILITY TODAY MAY NOT BE CAPTURING RESPONSIVE RESERVE.

THERE IS ONE CHANGE, AND THE PRIMARY CHANGE IS THE, THERE WAS A FLOOR WE HAD INTRODUCED A COUPLE YEARS AGO FOR PEAK HOURS THAT SET THE ENSURE THAT WE AT LEAST PROCURED 2,800 MEGAWATTS OF RRS IN 2024.

WE ARE PROPOSING TO TAKE THAT FLOOR AWAY.

SO NOW WHAT WOULD HAPPEN THEN IS ABSENT THIS FLOOR, WE WILL ENSURE THAT IN ANY ANY GIVEN HOUR, A MINIMUM OF 2300 MEGAWATTS OF RRS IS PROCURED.

THIS CHANGE PRIMARILY ENDS UP AFFECTING SUMMER MONTHS.

UH, ON ECRS THERE ARE A FEW CHANGES.

UM, ECRS HAS TWO DIFFERENT COMPONENTS THAT WE, UH, LOOK AT THE RISK OF, UH, BUT ONE IS TIED TO RISK OF NET LOAD, UH, ERRORS.

UH, LOOKING AT OUR 30 MINUTE AHEAD, UH, INTRA OUR NET LOAD FORECAST, WE ARE ADJUSTING, UH, UH, THE RISK PERCENTILES IN THAT PARTICULAR CALCULATION TO ENSURE THAT DURING THE EVENING HOURS, THE RISK COVERAGE THAT WE ASSIGN FOR THE SUNSET PERIOD IS AT LEAST AT A 90TH PERCENTILE.

THE SECOND PORTION OF ECRS IS TIED TO THE MEGAWATTS NEEDED TO RECOVER FREQUENCY.

THIS PARTICULAR COMPONENT, WE ARE ACTUALLY, WITH OUR TWEAKS DIALING DOWN OR REDUCING, WE ARE ADJUSTING IT A TO USE THE SAME AMOUNT OF HISTORY THAT, UH, RRS USES AS FAR AS INERTIA AND NET LOAD DATA IS CONCERNED.

BUT WE WILL END UP, UH, COV REDUCING THE COVERAGE, UH, THAT WE ASSIGN, UH, TO ENSURE THAT THE MA THE VALUES WE PICK COVER AT LEAST 60% OF OUR HISTORIC, UH, NET LOAD AND INERTIA.

ON NONS SPEND, THERE IS ONE CHANGE, AND THAT ONE CHANGE IS SPECIFICALLY APPLYING TO THE MORNING HOURS.

SO THERE ARE TWO SEPARATE BUCKETS YOU'LL SEE IN WINTER, IT IS JUST HOURS 23 TO, UH, UH, OUR ENDING, UH, TWO, UH, AND IN THE REST OF THE YEARS, IT IS OUR ENDING 23 TO OUR ENDING SIX.

IN THESE HOURS, WE WILL USE A HARD 68 PERCENTILE, UH, UH, VALUE WHEN LOOKING AT THE SIX

[02:45:01]

UH, THE THINKING HERE WAS THAT GENERALLY IN THESE HOURS, THE RISK OF DEPLOYING THE RISK OF SEEING ISSUES THAT MAY NEED NONS SPEND DEPLOYMENT ARE LOWER.

SO, SO THIS HARD SET VALUE WILL REDUCE THE QUANTITIES OF NONS SPEND IN THOSE HOURS FOR THE REST OF THE HOURS.

WE WILL CONTINUE TO USE A SIX HOUR AHEAD HOURLY NET LOAD FORECAST ERROR AND PICK THE VALUE BASED OFF OF THE RISK OF UP RAMP IN THOSE HOURS.

SO THE, THE, THE VALUE THAT WE PICK WILL BE BASED OFF OF THE 75TH OR THE, TO THE 95TH PERCENTILE BASED OFF OF THE RISK OF UP RAMPS THAT WE SEE IN THOSE HOURS.

OURS, ONE LAST CHANGE, THIS APPLIES MORE SO TO RRS IS NERC HAS FINISHED ITS ANNUAL ANALYSIS FOR ERCOT AND HAS ASSIGNED A, A LOWER INTERCONNECTION FREQUENCY RESPONSE OBLIGATION TO ERCOT.

AND, UH, TO ALIGN WITH OUR NEW IFRO, WE WILL BE REDUCING THE MINIMUM R-R-S-P-F-R LIMIT FOR 2024 TO 1,185 MEGAWATTS.

THAT'S AT A HIGH LEVEL.

I DO HAVE SOME SLIDES, UH, THAT JUST SHARE A COMPARISON OF THE HOURLY AVERAGE QUANTITIES BY, UH, AS TYPE THIS ONE'S FOR REGULATION.

THE COLORS WILL BE SIMILAR ACROSS THE BOARD.

THE, THE, THE REDDISH COLORS REPRESENT 2023 QUANTITIES.

BLUE COLORS REPRESENT, UH, UH, PRELIMINARY 2024 QUANTITIES.

YOU'LL NOTICE THE NUMBERS ARE SLIGHTLY SIMILAR, UH, FOR REGULATION.

UH, THIS ONE'S FOR RRS, YOU START SEEING THE IMPACT OF THE FLOOR, UH, GOING AWAY IN THE SUMMER, UH, SUMMER MONTHS.

THIS IS FOR ECRS, SIMILAR, SLIGHTLY LOWER QUANTITIES, HMM, ON AN AVERAGE 157 MEGAWATT DEGREES.

AND THIS IS NONS SPIN IN NONS SPIN.

THERE WAS A METHODOLOGY CHANGE WHEN WE IMPLEMENTED ECRS, SO YOU SEE AN ADDITIONAL COLOR.

UH, THE, THE ORANGE REPRESENTS WHAT WOULD THE NON SPEN QUANTITY, UH, HOURLY AVERAGE VALUE LOOK LIKE FOR JANUARY.

IF WE HAD USED THE SIX HOUR HEAD METHOD BACK THEN, JUST SO THAT WE CAN GET AN APPLES TO APPLES COMPARISON BETWEEN THE QUANTITIES.

AND THIS IS IT.

THIS IS THE, MY LAST SLIDE.

UM, UH, SO THAT SUMMARIZES AT A HIGH LEVEL WHAT THE CHANGES IN THE RED LINES THAT WE PROPOSED ARE.

WE HAVE POSTED SPREADSHEETS THAT CONTAIN QUANTITIES FROM JANUARY TO OCTOBER.

ONE ADDITIONAL NOTE I'LL MAKE IS DURING THE ROSS DISCUSSION, THERE WAS A REQUEST TO SEE SOME ESTIMATIONS OF ECRS QUANTITIES FOR NOVEMBER AND DECEMBER.

SO WE'VE LOOKED AT, UH, WE'VE PROJECTED APPLYING, UH, WHAT NOVEMBER AND DECEMBER, 2023 QUANTITIES WOULD LOOK LIKE HAD WE USED THE PROPOSED METHODOLOGY.

AND THAT'S IN OUR, UH, POSTED SLIDE SPREADSHEETS AS WELL.

UH, OF COURSE, WE ARE HERE SEEKING ENDORSEMENT FROM TAC, UH, FOR THE METHODOLOGY THAT OUR COURT IS RECOMMENDING TO USE IN 2024.

I'M HAPPY TO TAKE ANY QUESTIONS.

OKAY, I SEE A COUPLE, OR I SEE AT LEAST ONE.

UH, THE PERSON IN THE QUEUE IS AT NICK FEHRENBACH, AND I SEE JEREMY'S CARD UP AS WELL.

I'M JUST TRYING TO FIGURE OUT WHICH ONE YOU WANNA RECOGNIZE.

WELL, IS IT, WAS NICK IN THE QUEUE? OKAY, THAT'S WHY THAT WAS MY QUESTION.

IT SEEMS LIKE WE GOT THE NAMES WRONG.

UM, JEREMY, I GET THE QUEUE.

YEAH, JUST REAL QUICK, SORRY.

CANON.

YEAH, I WAS A LITTLE QUESTIONING WHO WAS SUPPOSED TO BE IN THE QUEUE.

'CAUSE I SAW NICK'S NAME IN THE QUEUE, BUT ONLY JEREMY'S CARD UP.

REMIND ME WHY WE DON'T EXTEND 24 THROUGH NOVEMBER AND DECEMBER WIDE ON THE GHOST OF OCTOBER.

UH, THEY RELY ON NOVEMBER AND DECEMBER, 2023 DATA TO RUN THE PATH.

IN THE SUMMER PERIODS THAN WINTER, TYPICALLY.

DID WE GET THAT ANSWERED? GO AHEAD, BILL.

SO, NETIKA, WE HAVE MADE, UH, SUGGESTIONS THROUGHOUT THE REVIEW PROCESS AT THE VARIOUS WORKING GROUPS AND SUBCOMMITTEE LEVELS, WHICH WE BELIEVE ARE IN THE COMMON SENSE.

UM, REVISIONS TO THE METHODOLOGY EXAMPLES INCLUDE, UH, SEASONAL DURATION LIMITS FOR ESRS, UH, SINCE THAT'S GONNA VARY BY SUMMER, WINTER, UM, SEASONAL, UM, ESTIMATIONS OF HOUR AHEAD ERROR.

AGAIN, I THINK WE'RE SEEING WE HAVE A MUCH SHORTER DURATION OF PROBLEM

[02:50:01]

UM, AND IT, I THINK IN ORDER FOR US TO GET COMFORTABLE, AND ALSO PROBABLY THE BIGGER ONE IS THE OVERLAP OF NONS SPINNING ECRS AND THE FACT THAT WE, WE THINK THAT THOSE CALCULATIONS SHOULD CONSIDER THAT, THAT, THAT THE PROCUREMENT OF THE OTHER SERVICE EXISTS NOT IN A VACUUM.

UM, AND WITHOUT A HARD COMMITMENT FROM ERCOT TO INCORPORATE CHANGES LIKE THAT GOING FORWARD IN THE 25 METHODOLOGY, I THINK WE'RE GONNA HAVE TO BE IN ABSTAIN ON THIS ONE, WHICH I, I THINK YOU'VE TAKEN THE FEEDBACK, YOU'VE HAVEN'T NECESSARILY MADE A COMMITMENT, BUT YOU'VE DISCUSSED THAT THOSE CONCEPTS ARE THINGS THAT COULD BE CONSIDERED GOING FORWARD.

SO WE HOPE THAT THEY ARE.

UM, BUT I CAN PROBABLY ADDRESS OKAY, THANKS.

SO ABSOLUTELY THROUGH THE STAKEHOLDER PROCESS, WE'VE, WE'VE TRIED OUR BEST TO TAKE EVERY SINGLE FEEDBACK THAT WAS RECEIVED, GO BACK AND REVISIT IT, UH, VISITED AT OUR END TO SEE WHAT WE CAN DO, UH, TO INCO.

UH, AS FAR AS THE RISKS WE SEE FOR THE ANCILLARY SERVICES ARE NEEDED TO BE PROCURED.

UM, AND, UH, AND WHERE WE LANDED, WHAT YOU'RE SEEING HERE IS WHERE WE LANDED, UH, AFTER TAKING ALL OF THOSE ITEMS INTO ACCOUNT, UH, ON NONS SPIN WITH REGARDS TO THE, UH, CHANGING LOOK AHEAD BASED OFF OF SEASON RIGHT NOW, WE DID NOT SEE A CASE, AND THAT'S PARTLY WHY YOU DON'T SEE A, A FLAVOR OF THAT SORT OF A PROPOSAL COME THROUGH.

BUT WHAT WE DID DO IS THERE WERE HOURS WHERE THERE WAS CERTAINLY A GOOD CASE TO SAY WE DON'T, THE RISK OF USING NON SPEN SEEMS LOWER, AND THERE WE WERE WILLING TO REDUCE THE, UH, REDUCE THE COVERAGE THAT WE ARE APPLYING.

SO TO ME, THOSE SORT OF CHANGES WILL DEFINITELY CONTINUE TO LOOK TO, UH, UH, UH, REVIEW.

EVEN AS WE GET INTO 2025 NOW BETWEEN 2024 AND 2025, UH, LIKELY THERE WILL BE MORE CONVERSATION TO BE HAD HOLISTICALLY ABOUT WHAT ANCILLARY SERVICES ARE.

AND, UH, UH, IN OUR MINDS, SOME, SOME CHANGES TO THE METHODOLOGY MAY COME OUT AS A RESULT OF THOSE DISCUSSIONS.

UH, ON NON SPIN SPECIFICALLY, WE WERE ALSO THINKING THAT ONE PLACE WHERE, UH, OUR APPROACH, UH, WOULD, WE, WOULD, WOULD NEED TO BE REVISITED IS WHEN DRRS IS IMPLEMENTED.

NOW THAT THING HAS BEEN PUSHED OFF SLIGHTLY, SO IT, IT DOES, UH, IT DOES MEAN THAT NON SPEN, WE WILL BE LOOKING TO USE NON SPEN TO COVER SOME OF THE RISKS ASSOCIATED WITH ENSURING SUFFICIENT COMMITTABLE CAPACITY IS AVAILABLE.

BUT AGAIN, TO US, THERE ARE MORE THINGS BEING LINED UP HERE BETWEEN POST 2024 DISCUSSION, UH, FOR, UH, FOR THAT WE ARE DOING NOW AND WHEN 2025 WOULD NEED TO START.

AND WE WILL CERTAINLY LOOK TO TAKE, UH, INPUTS WHERE WE CAN AND MAKE ADJUSTMENTS WHERE WE CAN WHILE TAKING THE RISKS THAT WE NEED TO COVER INTO ACCOUNT.

AND I THINK JUST WHAT WE'RE FOCUSING IN ON AND HOPE THAT WE GET THERE IS THAT WE'RE, WE ARE GOING TO BE LEANING ON ESRS INCREASINGLY GOING FORWARD FOR PROVIDING ANCILLARY SERVICES.

WE ALREADY SEE IT, I THINK IT'S 70% OF THE RESPONSIVE MARKETS.

I MEAN, THAT'S THE, THE, THEY'RE GONNA PLAY A HUGE ROLE IN PROVIDING OUR ANCILLARY SERVICES.

AND SO SHARPENING THE PENCIL ON THE METHODOLOGY TO CONSIDER THE INCREASED FLEXIBILITY OF THESE RESOURCES CAN PROVIDE.

AND, AND THE NEED FOR THE MEGAWATT PROCUREMENT AMOUNTS WE JUST THINK ARE GONNA BE IMPORTANT GOING FORWARD.

UM, THAT, WHICH REMINDED ME, I DID HAVE A, A QUESTION, UM, LOOKING TO SEE WHAT POTENTIAL IMPACTS TO THE PROCUREMENT AMOUNTS FOR 24 COULD BE IMPACTED BY PENDING DECISIONS.

UH, LIKE FOR EXAMPLE, DOES 1186 IMPACT THE PROCUREMENT AMOUNTS IN ANY WAY IF THAT'S APPROVED OR NOT APPROVED? 1186 PROVIDES TECHNICAL SPECIFICATIONS ON HOW MUCH, ON WHAT STATE OF CHARGE, UH, PROFILE OR RESOURCE AND ESR PROVIDING AS MUST MAINTAIN TO US.

UH, AND, AND OF COURSE, WHAT SORT OF PERFORMANCE MONITORING IS ASSOCIATED WITH, UH, WITH THOSE REQUIREMENTS TO US.

UH, THE TYPE OF WORK 1186 IS DOING IS CLARIFYING HOW AS IS TO BE PROVIDED.

UH, I KNOW WE ARE PROBABLY JUST A COUPLE WEEKS OR SO AWAY FROM THE NEXT OPEN MEETING.

THERE IS STILL SOME DISCUSSION TO BE HAD ON 1186, UH, IN OUR MINDS EVERY TIME WE'VE LOOKED AT AS METHODOLOGY AND THE ENTIRE AS, UM, UH, SET OF, UH, RULES AND REQUIREMENTS IN THE PROTOCOLS.

OUR GOAL HAS ALWAYS BEEN TO SPECIFY WHAT WE NEED, SPECIFY THE RULES AROUND THEM, AND SET THE METHODOLOGY TO COVER THE RISKS WE SEE COMING

[02:55:01]

FROM THE, UH, UH, UH, FROM THE PERSPECTIVE OF OPERATIONS, NOT FROM THE PERSPECTIVE OF NOT BEING ABLE TO PROVIDE THE SERVICE PER SE.

UM, IT MAY BE TOO PREMATURE FOR ME TO SAY, UH, THAT WE WILL BE MAKING CHANGES TO THE AS METHODOLOGY TO ACCOUNT FOR, UH, UH, ANY FAILURE TO PROVIDES THAT MAY OCCUR.

UH, UM, WHEN IT WAS ASKED DURING THE PROCESS REVIEW ITSELF, WE HAD, UH, TAKEN THE POSITION THAT WE WANT TO SPECIFY THE TECHNICAL SPECIFICATIONS AND NOT ADJUST THE QUANTITIES WE PROCURE.

BUT HAVING SAID THAT, AND DEFINITELY OUR EYE IS ON HEARING WHAT WE GET TOLD AROUND, UH, AROUND THE RULES THAT ARE, UH, BEING DISCUSSED.

UM, ONCE WE HAVE CLARITY ON THOSE, WE'LL CERTAINLY GO BACK AND REVISIT WHAT RISKS WE SEE AND WHAT'S THE BEST WAY TO COVER THEM.

UM, AND WHEN IT COMES TO ANCILLARY SERVICES, THESE PLAY A ROLE OVERALL, UH, AT LEAST AS FAR AS I WOULD CONCERNED.

THEY WORK HAND IN HAND WITH OTHER ACTIONS THAT THE CONTROL ROOM TAKES.

UM, AND, UM, MAYBE WE HAVE TO VISIT THE, THAT ENTIRE SET AS A WHOLE.

SO RIGHT NOW, I DON'T KNOW THAT I HAVE A PROJECTION OF HOW ANCILLARY SERVICES WOULD BE IMPACTED, PENDING 1186 DISCUSSIONS TO OUR, UH, WE, WE WILL DEFINITELY KEEP THINKING THROUGH BASED OFF OF WHAT WE HEAR.

OKAY, THANKS.

CONSUMERS HAVE BEEN VERY CLEAR THEY SUPPORT COMPETITIVE MARKET OUTCOMES WHEREVER POSSIBLE.

NEXT IS MARK DREYFUS.

UH, THANK YOU CAITLIN.

UM, REGRETFULLY, I'M GOING TO BE VOTING AGAINST THE ANCILLARY SERVICES METHODOLOGY FOR NEXT YEAR.

I HAVE SERVED ON THIS COMMITTEE FOR MANY YEARS AND SERVED FOR FIVE YEARS ON THE BOARD OF DIRECTORS.

I NEVER WOULD HAVE CONTEMPLATED THAT I WOULD'VE VOTED AGAINST THIS DOCUMENT UNTIL NOW.

NOW KAITLYN'S GONNA HAVE TO GO IN FRONT OF THE BOARD IN A COUPLE OF WEEKS AND EXPLAIN WHY THERE WERE NO VOTES ON THIS IMPORTANT DOCUMENT.

SO I WANNA BE VERY CLEAR SO THAT SHE CAN MAKE THAT REPORT.

UH, A COUPLE OF MONTHS AGO, AS EVERYBODY KNOWS, THE RECENTLY FORMER ESTEEMED INDEPENDENT MARKET MONITOR FOR THE ERCOT REGION RELEASED A STUDY REVIEWING THE DEPLOYMENT OF ECRS FOR THE FIRST FEW MONTHS OF THIS SUMMER.

AND, AND IT HAD SOME RESULTS THAT REALLY STOOD OUT TO ME AND WERE VERY CONCERNING.

UH, THOSE RESULTS SUGGESTED THAT THE OPERATION OF ECRS MAY HAVE INTRODUCED AN EIGHT TO $10 BILLION INEFFICIENCY INTO OUR MARKET INEFFICIENCY, MEANING THAT WE ACHIEVED OUR RELIABILITY TARGETS, NOT AT LOWEST COST, BUT AT A MUCH HIGHER COST AND UNNECESSARY COST.

AND, AND THE REPORT SAID TO ME, BEYOND, BEYOND THOSE NUMBERS, THE REPORT SAID TO ME AS SOMEONE WHO'S BEEN HERE SINCE THE ORIGINAL MARKET DESIGN, AND SOMEBODY WHO'S REALLY INVESTED IN HAVING A COMPETITIVE ENERGY MARKET, THAT FOR THE FIRST TIME WE MAY HAVE REALLY UNDERMINED OUR FUNDAMENTAL MARKET DESIGN BY USING CAPACITY SERVICES TO MANAGE SHORTAGE RATHER THAN USING THE ENERGY MARKET TO MANAGE SHORTAGE.

SO WHEN I SAW THAT FIRST REPORT, I SAYS TO MYSELF, SELF, THIS IS THE MOST IMPORTANT THING THAT HAS HAPPENED TO CONSUMERS SINCE WINTER STORM URI, AND WE REALLY NEED TO DIG IN.

AND SO I ATTENDED THE VARIOUS COMMITTEE MEETINGS, THE MEETING OF THE WHOLESALE MARKET SUBCOMMITTEE, AND I WAS DISAPPOINTED TO SEE THAT OUR PROFESSIONALS DID NOT NECESSARILY HAVE THE SAME REACTION TO AS I DID.

AND I EVEN HEARD STAFF RESPOND, I BELIEVE IN THE WMS COMMITTEE THAT THIS IS THE PRICE OF RELIABILITY, AND I REJECT THAT COMMENT.

INEFFICIENCY IS NOT HOW WE OPERATE IN THIS MARKET AND PROVIDE RELIABILITY.

OUR OBJECTIVE IS TO PROVIDE RELIABILITY AT LOWEST COST.

AND THE 155 COMMERCIAL CONSUMERS THAT I REPRESENT THAT NICK AND I REPRESENT, WHO WENT THROUGH EXTRAORDINARY MEASURES TO SIGN UP FOR THEIR ERCOT MEMBERSHIP THIS YEAR THROUGH THE NEW PORTAL, THEY'RE HERE FOR A REASON.

AND SINCE THE VERY BEGINNING OF THIS MARKET, COMMERCIAL

[03:00:01]

AND BY SUPPORTING COMPETITIVE MARKET OUTCOMES, WE WILL GET THE LOWEST COST RELIABILITY POSSIBLE.

SO WITHOUT BELABORING THE POINT FURTHER, UNLESS THERE IS A COMMITMENT THAT WE WILL RECONSIDER HOW THIS SERVICE IS BEING DEPLOYED AND OR AT LEAST DIG IN AND UNDERSTAND WHETHER THE RESULTS FROM THE INDEPENDENT MARKET MONITOR ARE CONFIRMED, AND WITHOUT ADOPTING THE VARIOUS RECOMMENDATIONS THAT HAVE BEEN PRESENTED BY THE INDEPENDENT MARKET MONITOR, I I DON'T THINK I CAN.

IN GOOD FAITH REPRESENTING COMMERCIAL CONSUMERS APPROVE A METHODOLOGY DOCUMENT THAT MAY WELL BE INCONSISTENT WITH OUR MARKET DESIGN MAY CONTRIBUTE TO INDUCED CONGESTION AND MAY, UH, RESULT IN SUCH GREAT INEFFICIENCIES, WHICH ULTIMATELY, UH, FLOW DOWNHILL TOWARD CONSUMERS.

CAN I FOLLOW? YEAH.

MARK KAN, WANTED TO FOLLOW UP AND I, I WILL NOTE THAT THE IMM IS PRESENTING.

UM, SO SOME, SOME FOLLOW UP DISCUSSION MIGHT BE BETTER SUITED FOR AFTER THAT PRESENTATION.

BUT KAN, GO AHEAD AND, AND FOLLOW UP DIRECTLY.

UH, SO I UNDERSTAND THE CONCERNS AND I THINK YOU'VE ALLUDED TO SOME OF THE SOLUTIONS YOU MIGHT BE LOOKING FOR, BUT I REALLY WANNA MAKE SURE I CLEARLY UNDERSTAND THAT.

SO ARE YOU SAYING, WHAT ARE THE THINGS THAT YOU'RE LOOKING FOR TO CHANGE? BECAUSE THE METHODOLOGY IS A LOT ABOUT JUST THE QUANTITIES THAT WE'RE GOING TO PROCURE, AND I HAVEN'T HEARD YOU SAY ANYTHING NECESSARILY OPPOSED TO THE QUANTITIES.

IT SOUNDS LIKE YOU ARE LOOKING FOR POSSIBLE PRICE POINT RELEASES FOR SOME OF THE ANCILLARY SERVICES, BUT YOU DIDN'T SAY THAT, SO I DON'T WANNA ASSUME THAT IS SOMETHING THAT ADDRESSES YOUR CONCERNS.

KENNAN, WHAT, WHAT I'M LOOKING FOR IS A, IS REALLY A BIGGER PICTURE RESPONSE AND, AND IT'S A RESPONSE FROM THIS ORGANIZATION THAT SAYS, IF IT IS POSSIBLE THAT WE HAVE INTRODUCED THIS SCALE OF INEFFICIENCY INTO A MARKET, AND IF IT IS POSSIBLE THAT MANY OF THE INSTANCES OF SHORTAGE THAT WE HAD THIS SUMMER, WHICH WERE SO TROUBLING TO CONSUMERS, IF, IF MANY OF THESE INSTANCES OF SHORTAGE WERE INDUCED AND NOT BECAUSE OF TRUE SHORTAGE, BUT THEY WERE INDUCED BY THE WAY WE'RE OPERATING THIS SERVICE, THEN WHAT I'M LOOKING FOR IS A COMMITMENT FROM ALL OF US THAT WE'RE GONNA DIG INTO THIS AND GET TO THE BOTTOM OF IT AND SEE IF THE I'S RESULTS ARE CONFIRMED, AND SEE IF WE NEED SOME FUNDAMENTAL POLICY CHANGES.

AND UNTIL THAT IS DONE, I CANNOT SUPPORT THE CONTINUATION OF THIS SERVICE IN THE WAY THAT THE SERVICE WAS MANAGED IN THE LAST YEAR.

KENAN, DID YOU WANNA RESPOND OR YOU, YOU'RE GOOD? NO, I THINK I NEED TO TAKE YOUR ADVICE.

I'M GONNA TAKE YOUR ADVICE AND WAIT FOR WAIT FOR THE I PRESENTATION.

I ACTUALLY WONDERED IF JEFF, UH, BILL WAS IN QUEUE TO RESPOND TO MARK, GIVE HIM AN OPPORTUNITY IF HE WAS LOOKING TO DO THAT.

JEFF, DID YOU WANNA RESPOND TO COMMENTS? SURE, YEAH.

THIS IS JEFF.

CAN YOU HEAR ME OKAY? YES, WE CAN.

AND, UM, YOU KNOW, I I THINK THAT I I I, I DON'T THINK THAT I WOULD DRAW THAT SAME CONCLUSION THAT YOU'RE DRAWING FROM THAT DATA.

UH, I, I DO, I GUESS I JUST WANTED TO CLARIFY SOMETHING THAT MARK SAID THAT MAY HAVE BEEN IN, IN REFERENCE TO A, A COMMENT THAT I HAD MADE, UH, IN, IN REGARDS TO THE, UM, THE, THE, THE PRICE ISSUES, UM, AND THE, THE COST OF RELIABILITY.

UH, AND I JUST WANT TO CLARIFY WHAT, IF THAT'S WHAT YOU'RE REFERRING TO.

WHEN I, WHEN I MADE THAT COMMENT, IT WAS MORE A CRITICISM OF THE, UM, IMM, UH, THE, THE WAY THAT THE IMM WAS PRESENTING THAT INFORMATION.

UH, AND, AND I, I THINK THAT IT'S BEEN DISCUSSED IN SEVERAL FORUMS THAT THAT MAY BE, UM, WHAT WHAT THEY PRESENTED MAY BE MISLEADING.

[03:05:02]

UM, BUT I'M, I'M HAPPY TO WAIT UNTIL AFTER THE IM M PRESENTATION TO DISCUSS FURTHER.

UH, THANK YOU FOR THE CLARIFICATION, JEFF.

I DIDN'T REALLY MEAN TO PUT WORDS IN YOUR MOUTH, BUT, UH, UM, AS I SAID, I REMAIN CONCERNED THAT WE HAVE NOT DUG DOWN TO THE BOTTOM OF THIS.

THANK YOU BOTH.

UM, LET'S GO BACK TO EMILY JOLLY.

THANK YOU, CAITLYN.

UH, AND THANK YOU ITHAKA FOR, FOR PRESENTING THIS.

AND AS, AS YOU AND BILL HAD SOME BACK AND FORTH, I THINK THAT THIS, YOU KNOW, HAS GONE A LOT, UNDERGONE A LOT OF REVIEW, AND WE APPRECIATE THAT AND THE OPPORTUNITY TO PROVIDE FEEDBACK.

AS YOU KNOW, WE'VE BEEN ON RECORD WITH CONCERNS ABOUT SOME OF THE CHANGES AND, AND QUESTIONING SOME OF THE TECHNICAL JUSTIFICATION SPECIFICALLY ON THE RRS CHANGES.

UM, BUT, YOU KNOW, UNDERSTAND THAT ERCOT IS, IS LOOKING AT THAT DATA DIFFERENTLY, AND WE HOPE TO CONTINUE TO ENGAGE IN THOSE DISCUSSIONS GOING FORWARD.

UM, I WANNA MAKE SURE I UNDERSTOOD YOUR RESPONSE TO BILL'S QUESTION ABOUT WHETHER, UM, MODIFICATION OR REJECTION OF NPRR 1186 WOULD IMPACT WHAT ERCOT IS PROPOSING.

CAN YOU REVISIT THAT AND, AND MAKE SURE THAT WE'RE ALL ON THE SAME PAGE ABOUT THAT? SO WHAT IS IN FRONT OF YOU IS THE MINIMUM REQUIREMENTS WE ARE PROPOSING TO CALCULATE USING THE METHODOLOGY THAT WE, WE'VE SPECIFIED FOR 2024 NPR 1186 IS A PERFORMANCE REQUIREMENT.

IT SPECIFIES WHAT ARE THE TECHNICAL CHARACTERISTICS FOR PROVIDING THESE SERVICES TO US.

FUNDAMENTALLY, WE'VE DECIDED TO SET OUR QUANTITY REQUIREMENTS FOR AS BASED OFF OF THE OPERATIONAL RISKS WE SEE.

AND THAT'S WHAT YOU'RE SEEING IN FRONT OF YOU TODAY, DEPENDING ON HOW 1186 PROGRESSES, IF IT WERE TO GO IN A DIRECTION WHERE THE, WHAT WE ARE LOOKING FOR DOES NOT MOVE FORWARD.

AND IF IT IS REJECTED, WE, WHAT, CERTAINLY WE NEED TO GO BACK AS TO THE DRAWING BOARD AND THINK ABOUT IS HOW DO WE MANAGE THE RISKS OF OPERATING THE GRID AND OPERATING IT RELIABLY.

IN THE PAST, OUR ANSWER WAS NOT THROUGH QUANTITY INCREASE, BUT SOMETHING ELSE, WE WILL STILL NEED TO GO HAVE THAT DISCUSSION FULLY TOO.

THE GRID IS EVOLVING, THE RESOURCES THAT ARE PROVIDING AS ARE EVOLVING, AND WE NEED TO TAKE ALL OF THAT INTO ACCOUNT OUR PREFERENCES, THAT THE TECHNICAL SPECIFICATIONS AND THE RULES ARE CLEAR TO ENSURE THAT WE GET THE PERFORMANCE WE ARE LOOKING FOR.

I APPRECIATE THAT RESPONSE AND, AND WE DO, UM, UNDERSTAND THE LEGITIMATE RELIABILITY CONCERNS THAT ARE DRIVING THAT, UM, AND LOOK FORWARD TO CONTINUING TO ENGAGE WITH ERCOT ABOUT SOLUTIONS SHOULD 1186 IN THE FORM THAT HAS BEEN PROPOSED, NOT PASS.

APPRECIATE IT.

THANKS EMILY.

ERIC GOFF, UH, I HOLD MOTION OF MY COMMENTS AS IS THE GOOD ADVICE WE GOT FROM OUR CHAIR.

UM, BUT I JUST WANNA RESPOND DIRECTLY TO A QUESTION THAT KANAN RAISED ABOUT WHAT CHANGES WOULD BE SUFFICIENT.

AND ON THE LAST SLIDE OF THE MARKET MONITORS REPORT, THEY RECOMMEND FOUR CHANGES.

SO I'M LOOKING FORWARD TO HEARING THE DISCUSSION AND I'LL RESPOND TO THOSE, UH, COMMENTS WHEN WE GET THAT REPORT.

THANKS, ERIC, DO YOU, ARE YOU WRAPPED UP ON YOUR PRESENTATION OR DO YOU HAVE ANY FURTHER COMMENTS? I'M DONE.

I SEE THE QUEUE IS PRETTY CLEAR.

UM, SO LET'S GO AHEAD.

WE ARE GONNA GET THE SUMMARIES FROM ROSS AND WMS ON THEIR RECOMMENDATIONS.

KATIE, RICH, ARE YOU AVAILABLE TO GIVE THAT, UH, ROSS REPORT ON IT? YEAH, SO, UM, ENDORSED AND AS YOU'VE HEARD FROM, UM, CONSUMERS IN THE IRES, WE DID HAVE FOUR EXTENSIONS FROM THE CONSUMERS.

ONE CO-OP, THE IRE SEGMENTS, AND THEN THREE NOS FROM THE IRES SEGMENT.

OKAY, THANKS KATIE.

I SEE ERIC BLAKEY MAKING HIS WAY UP TO THE FRONT FOR THE WMS RECOMMENDATION.

IS THIS ON GREEN? LIGHT'S ON.

UH, TO, TO ENDORSE THE METHODOLOGY BY ERCOT.

UH, ERIC BLAKEY WITH WMS, WE DID HAVE A, AN UPDATE AND DISCUSSION AT OUR NOVEMBER 1ST MEETING.

AND, UH, SOME OF THE COMMENTS THAT, UH, BILL'S COMMENTS WERE, WERE DISCUSSED AT OUR MEETING.

UH, NITKA PROVIDED HER UPDATE AS SHE'S DONE HERE.

UH, WE HEARD FROM THE IMM, UH, OUR VOTE WAS, UH,

[03:10:01]

WE HAD 11 ABSTENTIONS, UH, ALL FOUR OF THE CONSUMER GROUPS SUSTAINED.

UH, WE HAD ONE FROM CO-OP SEGMENT, TWO FROM INDEPENDENT GENERATOR, ONE FROM POWER MARKETER, AND THREE FROM THE INDEPENDENT REP.

UM, BUT OTHERWISE ALL VOTED FOR THE ERCOT METHODOLOGY.

OKAY, THANKS ERIC.

SO WE ARE ON NOW TO THE IMM OPINION.

UM, I BELIEVE DAVID WAS GONNA GIVE THIS VIRTUALLY.

DAVID, ARE YOU READY? I'M READY.

UH, CAN YOU HEAR ME? WE CAN HEAR YOU.

AWESOME.

UM, GREAT.

SO I'M GONNA, I'M GONNA WALK THROUGH THE PRESENTATION THAT WE POSTED AND, UM, WE'D BE, WE'D BE HAPPY TO, TO TAKE QUESTIONS AS WE GO ALONG.

UM, UH, SO IF YOU GO AHEAD TO SLIDE TWO, UM, SO IT'S, IT'S INTERESTING WHEN I, WHEN I TALK TO PEOPLE LIKE OUTSIDE ERCOT, IF I WERE TO SAY LIKE, HOW MUCH, HOW MUCH DO YOU CARE ABOUT AS METHODOLOGY AND OR, UH, I THINK PEOPLE WOULD BE SURPRISED AT HOW BIG AN IMPACT THIS ONE DECISION HAS MADE AND WILL MAKE IF YOU APPROVE THIS.

UM, THE, AND, AND THAT'S WHY I USE SOME PRETTY STRONG LANGUAGE IN THIS RECOMMENDATION, IN THIS POWERPOINT THAT I'M GONNA WALK THROUGH.

UM, ULTIMATELY THE, THE PURPOSE OF THE AS METHODOLOGY IS TO FIGURE OUT WHAT TO BUY AND HOW MUCH OF IT TO BUY.

AND THE, THE GOAL OF THE AS AS METHODOLOGY SHOULD BE TO BALANCE WHATEVER YOUR RELIABILITY OBJECTIVES ARE WITH, WITH THE COST OF SATISFYING THOSE REQUIREMENTS.

BECAUSE WE CAN'T, WE CAN'T INCUR INFINITE COSTS TO MAINTAIN RELIABLE, UH, RELIABILITY.

UM, IT'S IN FACT WHY WE HAVE A VALUE OF LOST LOAD CONCEPT THAT UNDERLIES OUR MARKETS.

IS THAT, IS THAT IT RECOGNIZES THAT KEEPING THE LIGHTS ON IS, IS HUGELY VALUABLE, BUT NOT INFINITELY VALUABLE.

AND SO WE'VE, WE'VE EVALUATED THE ANCILLARY SERVICE METHODOLOGY.

YOU HEARD AN INITIAL PRESENTATION BY CARRIE BIVINS A MONTH AGO, AND, AND WE'VE DONE ADDITIONAL ANALYSIS THAT I'M GONNA PRESENT IN THIS, BUT, UH, THE FINDINGS TO, TO SORT OF, YOU KNOW, PUT THESE OUT INITIALLY SO YOU CAN BE THINKING ABOUT THEM AS WE WALK THROUGH SOME OF THE ANALYTICAL RESULTS IS, IS FIRST AND FOREMOST THAT THE AS METHODOLOGY IS NOT REALLY BASED ON, UH, SOUND RELIABILITY ANALYSIS.

UM, AND IT IS IN FACT WHY THE METHODOLOGY, UM, PRODUCES EXCESSIVE RESERVE REQUIREMENTS BECAUSE IT'S NOT ALIGNED WITH, WITH RELIABILITY RISK.

UM, AND, AND YOU CAN SORT OF SEE THAT WHEN YOU COMPARE THE, THE QUANTITY OF RESERVES THAT ERCO WOULD PROPOSE TO BUY UNDER THIS METHODOLOGY TO THE, THE QUANTITY OF RESERVES THAT OTHER RTOS BUY.

NOW, THE, THE WORST SIDE OF THAT IS THAT, UM, BETWEEN THE HIGH, THE EXCESSIVE QUANTITIES THAT THIS METHODOLOGY PRODUCES AND THE FACT THAT, THAT YOU DON'T HAVE CO-OP OPTIMIZATION.

SO YOU'RE HOLDING YOUR, YOUR, AT LEAST YOUR 10 MINUTE RESERVE CLASSES OUT OF THE MARKET, UH, WHEN YOU, WHEN YOU PROCURE EXCESSIVE RESERVES OR HAVE EXCESSIVE REQUIREMENTS, YOU CAN, YOU CAN END UP PRODUCING ARTIFICIAL SHORTAGES IN THE, IN THE ENERGY MARKET BECAUSE THE ENERGY MARKET CAN'T SEE THE RESERVES AND CAN'T ACCESS THEM.

UM, AND WE SAW THAT NEARLY IMMEDIATELY AFTER ECRS WAS, WAS IMPLEMENTED, UM, AND THEN WE CONTINUED TO SEE IT THROUGHOUT THE SUMMER AND INTO THE FALL.

SO WE'VE, WE'VE UPDATED THE ANALYSIS THAT WAS PRESENTED BEFORE, WHICH RAN THROUGH AUGUST 31ST.

WE HAD ADDITIONAL EVENTS IN IN SEPTEMBER.

UM, AND SO WE, WE UPDATED OUR ANALYSIS THROUGH I THINK OCTOBER, UH, 20, OR I'M SORRY, NOVEMBER 27TH, AND FOUND OVER $12 BILLION OF INEFFICIENT MARKET COSTS RELATED TO THESE EXCESS, UH, OPERATING RESERVE PROCUREMENTS.

NOW, I DON'T, I DON'T WANNA EXAGGERATE HOW BAD THIS IS, BUT THIS IS THE WORST PERFORMANCE WE'VE EVER SEEN SINCE THE BEGINNING OF ORGANIZED ELECTRICITY MARKETS ALMOST 25 YEARS AGO.

AND WE'VE, FROM THE OUTSET, WE'VE, WE'VE MONITORED MANY OF THESE MARKETS.

I'VE NEVER SEEN ANYTHING REMOTELY THIS BAD.

THIS 12,000,000,012, IT'S ACTUALLY 12 AND

[03:15:01]

A HALF BILLION DOLLARS IS THE EQUIVALENT OF $400 FOR EVERY MAN, WOMAN, AND CHILD IN TEXAS.

THIS, AS FAR AS I CAN TELL THIS IS, THIS IS SO COMPLETELY UNPRECEDENTED.

LIKE I, I'VE BEEN RACKING MY BRAIN TO TRY TO FIGURE OUT WHETHER I'VE EVER SEEN ANYTHING LIKE THIS AND, AND I REALLY HAVEN'T.

UM, THESE, THERE'S NO WAY TO PRETEND THAT THESE ARE REAL COSTS, THAT THESE ARE EFFICIENT COSTS BECAUSE IF YOU LOOK AT, AT THE, UM, THE PERIODS WHERE WE WERE EXPERIENCING $5,000 PRICES AND, AND OTHER VERY HIGH PRICES, UM, WE WEREN'T CLOSE TO HAVING ANY SHORTAGES.

SO LIKE THE ORDC AT OUR, THE RDC WAS NOT PRODUCING ANY ADDERS BECAUSE, BECAUSE BASED ON A FUNDAMENTAL EVALUATION OF OUR AVAILABLE SUPPLY, WE WEREN'T CLOSE TO BEING IN SHORTAGE.

UM, AND YET THE, THE MARKET WITH THE, WITH THIS LARGE INCREASE IN 10 MINUTE RESERVES THAT GETS HELD OUT OF THE ENERGY MARKET PERCEIVED A SHORTAGE THAT DIDN'T REALLY EXIST.

AND THAT'S WHERE THIS 12 BILLION COMES FROM.

NOW I WANNA POINT OUT THAT, THAT THESE COSTS ARE NOT GONNA SHOW UP IN PEOPLE'S BILLS IMMEDIATELY BECAUSE A LOT OF LOAD IS SERVED BY, UM, LSCS THAT HAVE CONTRACTS OR HEDGES OR, OR EVEN OWNED GENERATION, BUT, BUT THEY WILL SHOW UP EVENTUALLY.

SO WE CAN'T, WE CAN'T SORT OF BE COMPLACENT AND, AND CONTINUE TO PROPAGATE THE, THE PROBLEMS THAT HAVE CAUSED THIS INTO 2024.

IN 2025.

WE, WE KNOW THESE COSTS WILL, WILL START FILTERING INTO PEOPLE'S BILLS, UH, DOWN THE ROAD BECAUSE WE, IF YOU LOOK AT WHAT FORWARD ENERGY PRICES IN THE SUMMER DID AFTER THE IMPLEMENTATION IMPLEMENTATION OF ECRS, THE AUGUST OF, OF, UM, 2024 IS 67% HIGHER THAN IT WAS BEFORE ECRS WAS IMPLEMENTED.

AND NOTHING FUNDAMENTALLY HAS CHANGED OTHER THAN THAT, YOU'VE MASSIVELY INCREASED YOUR 10 MINUTE RESERVE REQUIREMENT.

UM, IF YOU GO TO GO AHEAD TO THE NEXT SLIDE, I THINK I SAID MOST OF WHAT'S ON HERE, BUT IT TOWARDS THE BOTTOM, I, I DO FORESHADOW WHAT WHAT WE'RE GONNA RECOMMEND, WHICH IS WE'RE GONNA URGE TECH NOT TO APPROVE THIS AS METHODOLOGY AND DO ONE OF TWO THINGS.

ONE IS EITHER REQUEST THAT THAT ERCOT USE A, A SOUND RELIABILITY ANALYSIS TO QUANTIFY THESE, THESE REQUIREMENTS.

AND TO ME THAT WOULD MEAN USING A STOCHASTIC MODEL THAT THAT MODELS THE UNCERTAINTIES, THAT DRIVE RELIABILITY PROBLEMS AND THEN QUANTIFY HOW MUCH RESERVES YOU NEED TO ADDRESS THOSE, THOSE UNCERTAINTIES.

UH, OR SECONDLY, IF, UH, IF YOU WANNA, IF YOU WANNA MAKE CHANGES THAT WOULD MITIGATE THE PROBLEM AND, AND MAYBE MAYBE OVERHAUL THE, THE RELIABILITY EVALUATION NEXT YEAR, THEN WE DO RECOMMEND SOME CHANGES THAT, UM, THAT WE CAN TALK ABOUT.

AND, AND ERCOT ACTUALLY COMMENTED ON SOME OF THE CHANGES THAT WE RECOMMENDED THAT WOULD LOWER THE OPERATING RESERVE REQUIREMENTS.

AND, AND I'LL JUST SAY THAT THE, YOU KNOW, WHEN I GET TO THE END AND TALK ABOUT WHAT THOSE ARE, THE ERCOT RESPONSE TO OUR RECOMMENDATION SORT OF DEMONSTRATES THAT THEY'RE NOT THINKING ABOUT THE PROBLEM THE CORRECT WAY IN TERMS OF, OF QUANTIFYING THE 10 MINUTE AND 30 MINUTE RESERVE REQUIREMENTS.

UM, BUT GO AHEAD.

TWO SLIDES AND I I WANNA GO THROUGH SOME OF THE RESULTS.

YOU CAN GO AHEAD ONE MORE.

UM, SO WE, WE MONITOR MISO, NEW YORK, NEW ENGLAND, AND ERCOT.

UM, AND WE'RE, WE'RE FAMILIAR WITH, WITH HOW THEY OPERATE THEIR SYSTEMS AND AND MAINTAIN RELIABILITY.

UM, YOU CAN SORT OF SEE ON THIS GRAPH THAT, THAT EVEN BACK BEFORE WINTER STORM URI, UM, ERCOT WAS A LITTLE BIT DIFFERENT WITH REGARD TO 10 MINUTE RESERVES, THAT IT HAD A HIGHER 10 MINUTE RESERVE REQUIREMENT.

AND YOU COULD ARGUE THAT THAT MAKES SOME SENSE BECAUSE, BECAUSE ERCOT IS AN ISLAND AND, AND HAS, HAS TO, OR MAYBE NOT HAS TO, BUT IT MAKES SENSE FOR ERCOT TO BE BETTER PREPARED TO, TO DEAL WITH FREQUENCY FLUCTUATIONS SINCE, SINCE, UH, THEY CAN'T LEAN ON THE REST OF THE EASTERN INTERCONNECT THE WAY NEW ENGLAND, NEW YORK AND AND MISO CAN.

SO IT'S IMPORTANT FOR THEM WHEN LARGE CONTINGENCIES HAPPEN TO BE ABLE TO DEPLOY THINGS QUICKLY TO, UH, UH, TO ADDRESS FREQUENCY.

UM,

[03:20:01]

NOW AFTER WINTER STORM URI, WE, WE SAW A HUGE INCREASE IN, IN 30 MINUTE RESERVES OR WHAT WE CALL NONS SPIN.

UM, BUT THE BIG, THE BIG PROBLEM REALLY HAPPENED AND WE, WE THINK THAT'S, AND THAT'S OVERSTATED BASED ON, UM, OBJECTIVE RELIABILITY ANALYSIS, BUT, BUT DIDN'T HAVE NEARLY THE IMPACT THAT THE ECRS DID WHEN WE WENT FROM THE WAY WE WERE OPERATING THE SYSTEM IN 2022.

AND, AND THEN WE IMPLEMENTED ECRS, WE MASSIVELY INCREASED THE 10 MINUTE RESERVE REQUIREMENT, UM, AND MADE A PARTIAL OFFSET IN THE 30 MINUTE RESERVES.

NOW, THE, THE, THE PROBLEM WITH THAT IS THAT THE, THE 10 MINUTE RESERVES ARE, ARE HELD OUT OF THE, THE ENERGY MARKET EVEN IF THEY'RE ONLINE.

SO, UM, SO THAT, THAT SHIFT, THAT INCREASE IN 10 MINUTE RESERVES, THAT WHERE WE'RE NOW PROCURE PROCURING SOMETHING LIKE THREE TIMES THE 10 MINUTE RESERVES, UH, THAT, THAT MISO NEW YORK AND NEW ENGLAND DO ON PROCURE ON AVERAGE, AND MISO KEEP IN MIND IS, IS ALMOST TWICE AS BIG AS, AS ERCOT.

SO, UM, MANY OF THE UNCERTAINTIES THAT THEY FACE, PARTICULARLY ON UNPLANNED OUTAGES, ARE ACTUALLY QUITE A BIT LARGER THAN WHAT OUR COP FACES.

UM, THAT'S EXTREMELY SIGNIFICANT.

AND IF YOU GO AHEAD TWO SLIDES.

THE, THE, THE THING TO BALANCE WHEN YOU'RE DECIDING HOW MUCH, HOW, HOW MANY RESERVES TO PROCURE IS, IS THE MORE, THE MORE YOU PROCURE, THE LOWER THE LOSS OF LOAD PROBABILITY IS, AND IF YOU APPLY A VALUE OF LOSS LOAD, UM, TO, TO THE RISK THAT YOU'RE FACING.

SO THIS IS A PICTURE OF MISO, UM, USING A A $20,000 PER MEGAWATT HOUR ASSUMED VALUE OF LOSS LOAD.

UM, SO IF WE USED A LOWER VALUE OF LOSS LOAD, THIS, THE WHOLE CURVE WOULD SHIFT DOWNWARD.

BUT, UM, AND THERE ARE, THERE, THERE'S REGULATIONS TO THE LEFT IF YOU'RE WONDERING WHY THAT THIS CURVE DOESN'T GO UP TO $20,000.

UM, BUT WHAT WE'RE DOING HERE IS MODELING INTERMITTENT FORECAST RISK, UM, BOTH SOLAR AND WIND.

UM, AND THEN THE, THE PROBABILITIES THAT YOU'RE GONNA HAVE FOUR STATUSES ON, ON ALL OF THE, USE THE RESOURCES IN MISO.

SO YOU COULD, YOU COULD LOSE YOUR BIGGEST GENERATOR OR YOU COULD LOSE THREE MEDIUM SIZED GENERATORS.

IT'S ALL SORT OF DISTILLED DOWN INTO PROBABILITY.

SO WE'RE RUNNING A MONTE CARLO MODEL THAT, THAT, UM, THAT SIMULATES THOUSANDS AND THOUSANDS OF MARKET OUTCOMES.

AND WHAT THIS IS TELLING YOU IS IF, IF THEY BUY 2000 MEGAWATTS OF 10 MINUTE RESERVES, THEN THEN THE, THE MARGINAL VALUE OF THOSE RESERVES IS SOMEWHERE AROUND $500.

AND THAT'S, THAT'S WHERE MISO STOPS.

THEY DON'T CONTINUE TO BUY BEYOND THAT POINT.

NOW THEY DO HAVE 30 MINUTE RESERVES THAT CONTINUE TO MITIGATE UNCERTAINTIES AND RISK GOING OUT BEYOND THIS CURVE.

BUT THIS GIVES YOU A SENSE, LIKE IF I WERE TO TRY TO BALANCE THE COST OF BUYING MORE RESERVES WITH THE RELIABILITY THAT THEY'RE PROVIDING, YOU'D BE LOOKING AT SOMETHING LIKE A CURVE LIKE THIS AND YOU'D WANNA STOP BUYING AT A POINT WHERE THE RESERVE STILL HAS SOME MATERIAL VALUE.

UM, NOW IF YOU, IF YOU GO TO SLIDE NINE, WE'VE DONE THIS ANALYSIS FOR ERCOT, LIKE WHAT IS THE LOSS OF LOAD PROBABILITY, UH, OF OUR 10 MINUTE RESERVES IF WE WERE TO BUY NO ECRS AND, AND THEN WHAT IS THE MARGINAL VALUE OF OUR ECRS BUYING THE QUANTITY THAT, THAT, UM, THAT ERCOT BOUGHT DURING THE SUMMERTIME? AND WHAT YOU CAN SEE IS, IS THE MARGINAL VALUE OF ECRS WAS ZERO, UM, IN TERMS OF THE LOSS OF LOAD PROBABILITY, UH, WAS ESSENTIALLY ZERO THE ENTIRE SUMMER.

UM, NOW WHY IS IT ZERO? IT IT IS ZERO BECAUSE ZERO BUYING SO MUCH AND BECAUSE RELIABILITY, THERE WAS NO MATERIAL RELIABILITY THREAT DURING THE SUMMER, DESPITE THE HIGH LOADS, THE WHILE THE LOAD WAS HIGH, SOLAR OUTPUT WAS ALSO HIGH.

UM, SO NOW IF NOW YOU CAN SEE THAT BUYING A MUCH LOWER QUANTITY OF 10 MINUTE RESERVES, WHICH IS, WHICH CORRESPONDS TO THE WHAT IF I

[03:25:01]

BOUGHT NO ECRS, UM, SCENARIO HERE.

UH, AND THEN, THEN YOU'RE LEFT WITH RRS AND IN THE PEAK HOURS YOU'RE LOOKING AT, UH, I THINK 2,800 FLOOR WAS IN PLACE.

SO YOU'RE PROBABLY LOOKING AT AROUND, UH, JUST UNDER 3000 MEGAWATTS, 10 MINUTE RESERVES.

THEN YOU DO HAVE A LOSS OF LOAD PROBABILITY THAT'S NON-ZERO, BUT IT'S BOUNCING BETWEEN GENERALLY BETWEEN CLOSE TO ZERO AND TWO TENTHS OF 1%.

AND THAT, THAT SUGGESTS THE AVERAGE VALUE OF THE ECRS THAT WE WERE BUYING, UH, WAS THAT IT WAS WORTH WHAT WE SHOW IN THE BOTTOM OF THIS FIGURE THAT IN GENERAL, IT'S WORTH LESS THAN $50 A MEGAWATT.

UM, NOW IN A, IN A CO-OP OPTIMIZ SYSTEM, YOU CAN AFFORD TO OVERBUY 10 MINUTE RESERVES BECAUSE, UH, YOU COULD PUT IN A DEMAND CURVE FOR SOMETHING LIKE ECRS IN A, IN A CO OPTIMIZ MARKET AND SAY, OKAY, I WANNA BUY THIS PRETTY LARGE QUANTITY, BUT DON'T PAY MORE THAN, YOU KNOW, YOU COULD HAVE A CURVE THAT TELLS YOU THE MAXIMUM AMOUNT YOU'RE WILLING TO PAY.

UM, AND IN THIS CASE, ONCE YOU GET, ONCE YOU GET PRETTY FAR OUT ON THE 10 MINUTE CURVE, YOU SHOULD BE TELLING YOUR MARKET DON'T PAY MORE THAN $20 A MEGAWATT HOUR OR $50 A MEGAWATT HOUR, UM, BECAUSE IT'S JUST NOT, NOT WORTH VERY MUCH.

UM, BUT IN, BUT IN ERCOT, YOU DON'T HAVE THAT OPTION.

UM, YOU'RE HOLDING THESE OUT OF THE MARKET AND IT, IT'S ALMOST LIKE ATTACHING AN INFINITE VALUE TO THE, THE RESERVE UNTIL IT'S, UNTIL IT'S DEPLOYED AND MADE, MADE AVAILABLE TO THE ENERGY MARKET.

SO YOU HAVE TO BE REALLY CAREFUL WHEN YOU QUANTIFY HOW MUCH YOU'RE GONNA BUY BECAUSE IT CAN HAVE SEVERE COST IMPLICATIONS.

SO IF YOU GO TO, UM, THE LAST FIGURE ON FLIGHT 11, UM, WE, WE UPDATE THE ANALYSIS AND TRY TO TRY TO MAKE IT CLEAR, UM, YOU KNOW, WHAT THE, WHAT THESE RESULTS LOOK LIKE.

UM, SO WHAT, WHAT WE WERE DOING HERE IS WE WERE COMPARING THE, THE ACTUAL PRICES ON AVERAGE IN THE, IN THE ENERGY MARKET, UM, AGAINST A SIMULATED CLEARING PRICE, ASSUMING THAT YOU DIDN'T BUY SO MUCH ECRS.

UM, WE, WE STILL BOUGHT A, A BASE QUANTITY OF ECRS BECAUSE WE THINK THERE IS SOME RELI RELIABILITY VALUE TO ECRS, BUT, UM, BUT THAT'S THE, THE, ULTIMATELY THE PRICES YOU GET WOULD BE THE GREEN DIAMONDS AND, UM, FROM SIMULATING THAT LOWER PROCUREMENT AMOUNT.

SO YOU CAN SEE, AND PARTICULARLY IN JUNE AND AUGUST AND, AND TO, TO A LESSER EXTENT IN SEPTEMBER WHERE WE HAD A LOT OF THESE ARTIFICIAL PRICE SPIKES, THE, THE DIFFERENCE IN THE PRICE BETWEEN THE CORRECTED PRICE AND THE THE PRICE THAT ERCO ACTUALLY SAW IS, IS ENORMOUS.

AND THAT'S WHAT GENERATES THE MARKET COST, IS THESE HIGHER ENERGY PRICES THAT THEN IF YOU, IF YOU ASSUME THE LOAD IS BUYING AT THOSE PRICES GENERATES THE MARKET COSTS.

SO THE BARS ON HERE SHOW THE CUMULATIVE MARKET COSTS.

NOW, AGAIN, THOSE COSTS ARE NOT GOING TO SHOW UP IN PEOPLE'S BILLS IMMEDIATELY, BUT ULTIMATELY IT'S THESE, IT'S THESE REAL TIME COSTS THAT DRIVE THE FORWARD CONTRACT, UH, PRICES THAT THEN DO SHOW UP IN PEOPLE'S BILLS.

UM, AND THERE ARE SOME CONSUMERS OBVIOUSLY, THAT ARE, AREN'T FULLY HEDGED, AND SO THEY, THEY MAY BE INCURRING SOME OF THESE COSTS, UH, MORE IMMEDIATELY.

UM, BUT, UM, SO THAT'S, THAT'S WHERE THINGS STAND RIGHT NOW.

AND I, I WOULD URGE YOU NOT TO HEAR A NUMBER AS BIG AS 12 AND A HALF BILLION AND, AND THINK IN YOUR MIND THAT'S GOTTA BE OVERSTATED OR INFLATED IN SOME WAY.

UM, I, I ASSURE YOU IT'S NOT.

UM, AND FOR, FOR THAT REASON, UH, IF YOU GO TO THE LAST SLIDE, WE'RE, WE'RE IMP EMPLOYING YOU NOT TO APPROVE THIS METHODOLOGY.

UM, WE THINK THERE'S SUBSTANTIAL OVERLAP BETWEEN SPIN AND ECRS AND RRS, UM, OR NON SPIN, I'M SORRY, AND, AND YOU, AND YOU COULD RESOLVE, UM, YOU CAN RESOLVE THAT OVERLAP AND QUANTIFY ACCURATELY WHAT YOU NEED TO OPERATE THE SYSTEM BY, BY DOING A MORE STOCHASTIC MODELING OF THE RELIABILITY RISKS THAT ARE BEING FACED.

AND THEN, AND THINK THROUGH HOW

[03:30:01]

THESE VARIOUS PRODUCTS ADDRESS THOSE RISKS.

UM, BECAUSE THEY, I THINK THEY, THEY ADDRESS RISKS IN WAYS THAT ARE, ARE SOMEWHAT DIFFERENT THAN, THAN, UM, THEN ERCOT WOULD, WOULD DESCRIBE IN TERMS OF, UM, IN TERMS OF THE LOGIC THAT UNDERLIES THESE, THESE, UH, PRODUCTS.

NOW, IF I RECOGNIZE THAT THAT'S, THAT'S WOULD BE HARD TO DO THAT QUICKLY.

SO IF YOU WERE GOING TO MITIGATE THE IMPACTS OF THE 2024 METHODOLOGY, THERE'S A FEW THINGS THAT YOU CAN DO IS FURTHER REDUCE THE FREQUENCY RESPONSE MEGAWATTS, UH, ASSUMED FOR ECRS, RECOGNIZING THAT, THAT YOU HAVE REGULATION AND RRS THAT, UH, ARE THERE TO ADDRESS FREQUENCY.

UM, SECOND IS CHANGE THE, THE SIX HOUR AHEAD, A HEAD ERROR REQUIREMENT UNDERLYING THE NONS SPIN TO TWO HOURS.

I KNOW WE SAID THREE HOURS BEFORE IT'S, I CHANGED IT TO TWO BECAUSE THIS REALLY DOESN'T MAKE SENSE.

UM, I'LL JUST DESCRIBE THE MINIMUM LOAD, NOT, I'LL JUST DESCRIBE QUICKLY.

THE, UM, T'S RESPONSE TO THIS RECOMMENDATION, UM, INDICATED THAT, UM, THAT YOU NEED THE NONS SPEND TO DEPLOY, UM, UNTIL OFFLINE RESOURCES BEING CAN BE COMMITTED AND ARE READY FOR DISPATCH.

UM, SO YOU COULD THINK, WELL, MAYBE I HAVE OFFLINE RESOURCES AVAILABLE FOR DISPATCH WITHIN FOUR HOURS.

THE PROBLEM IS THAT WHOLE WAY OF THINKING OF THIS PRODUCT IS, IS JUST NOT RIGHT BECAUSE YOU DON'T KNOW, I DON'T KNOW RIGHT NOW IF IT'S 10 IN THE MORNING AND I'M LOOKING AT FOUR IN THE AFTERNOON, SIX HOURS AHEAD, I HAVE NO IDEA WHAT THE FORECAST THERE IS UNTIL I GET TO FOUR IN THE AFTERNOON.

SO YOU'RE, YOU'RE NEVER GOING TO DEPLOY ANY OF THESE RESOURCES AT STARTING AT 10 IN THE MORNING.

UM, THE, THE REASON YOU WOULD DEPLOY THINGS AT 10 IN THE MORNING IS BECAUSE YOU FORECAST A SHORTAGE AND, AND YOU DON'T KNOW IF THAT FORECAST IS ACCURATE OR IF THAT FORECAST IS AN ERROR.

ULTIMATELY, WHERE THESE FORECAST ERRORS COME HOME TO ROOST IS VERY CLOSE IN.

AND THIS IS WHY WE, WE RECOMMENDED THE ECRS, WE CHANGED TO A 10 MINUTE FORECAST ERROR THAT WHEN IT REALLY DOESN'T MATTER WHAT YOUR 30 MINUTE RESERVE FORECAST ERROR IS EITHER, AND YOU DON'T KNOW WHAT IT IS 30 MINUTES OUT.

SO SAME PROBLEM AS IN ERCOT LOGIC OR USING THE 30 MINUTE FORECAST ERROR.

WHAT WHAT YOU DO KNOW IS ONCE YOU'RE 10 MINUTES OUT, YOU'RE USING THE FORECAST TO DRIVE THE DISPATCH.

AND IF THE FORECAST IS OFF, YOU'RE NOT GONNA SEND DISPATCH INSTRUCTIONS TO ENOUGH GENERATION.

AND, AND IF YOU DO THAT, YOU'RE GONNA DEPLOY YOUR REGULATION.

AND THEREFORE THE PURPOSE OF YOUR ECRS LARGELY, UM, WITH REGARD TO FORECAST ERROR IS TO REPLACE THE REGULATION THAT YOU'VE JUST DEPLOYED.

AND THE REGULATION YOU'RE GONNA DEPLOY IS THE QUANTITY IS GONNA BE BASED ON THE ERROR 10 MINUTES OUT, FIVE TO 10 MINUTES OUT, NOT 30 MINUTES OUT.

SO YOU'RE JUST, BY USING A 30 MINUTE NET LOAD FORECAST ERROR, YOU'RE JUST OVERSTATING, UM, THE POTENTIAL NEED FOR ECRS IN THE SAME WAY THAT USING A SIX HOUR AHEAD FORECAST FOR, FOR NONS SPIN IS, IS JUST OVERSTATING THE REQUIREMENT.

UM, SO THOSE ARE THINGS YOU CAN DO THAT ACTUALLY TRACK WITH HOW THE SYSTEM IS OPERATED.

UM, AND, AND WOULD, I DON'T KNOW IF IT WOULD COMPLETELY SOLVE THE PROBLEM, BUT IT WOULD, IT WOULD GREATLY IMPROVE, UH, THE, THE, UH, ADVERSE EFFECTS OF THIS METHODOLOGY, UM, UNTIL SUCH TIME AS, AS ERCOT CAN DO A JOINT RELIABILITY RISK ANALYSIS TO QUANTIFY HOW MUCH RESERVES IT REALLY NEEDS, WHERE, WHERE IT'S SIMULTANEOUSLY QUANTIFYING THE RISK OF, OF FOUR OUTAGES AND, UH, INTERMITTENT GENERATION FORECAST ERRORS, LOAD FORECAST ERRORS, AND OTHER UNCERTAINTIES.

SO WHY DON'T I, WHY DON'T I PAUSE THERE AND, UM, TAKE QUESTIONS.

UM, I THINK FIRST OF ALL, I, I FEEL SEEN, UM, I'VE HAD MANY SIMILAR CONCERNS, UM, WITH THE CHANGE

[03:35:01]

IN THE ANCILLARY SERVICE PROCUREMENT METHODOLOGY FOLLOWING WINTER STORM YEAR IN 2021, AND HAVE ATTEMPTED TO MAKE SIMILAR MODIFICATIONS OR PROPOSALS TO FINE TUNE THE PROCUREMENT AMOUNT.

AND IT SEEMED TO BE ALONE ON THIS AS WELL, IS THAT WE WE'RE HEADING THE PATH, WE'RE PROBABLY GONNA MAKE THIS WORSE BY IMPLEMENTING A STANDALONE DRS PRODUCT.

SO I'M WONDERING IF YOU HAVE ANY ADVICE FOR US IN TERMS OF FOCUSING THE TOTAL ANCILLARY SERVICE, UH, SUITE OF PRODUCTS TO BE MORE EFFICIENT.

AND ALSO, THIS IS MORE OF AN ACADEMIC QUESTION, BUT I BELIEVE IT'S NOT STATED, IT BELIEVE THERE'S, PART OF THE INTENTION HERE IS TO PROVIDE SOME TYPE OF INDIRECT BENEFIT FOR RESOURCE ADEQUACY.

AND I'M WONDERING WHAT YOUR THOUGHTS ARE WITH THAT TWO.

WELL, I GUESS, I GUESS A FEW THINGS COME TO MIND.

ONE, ONE IS I WOULD, I WOULD GET CO-OP OPTIMIZATION IN PLACE AS FAST AS HUMANLY POSSIBLE BECAUSE IT'S, IT'S JUST KILLING YOU, NOT HAVING IT.

UM, UM, SECONDLY, PARTICULARLY UNTIL YOU HAVE CO-OP OPTIMIZATION, I, I WOULD, I WOULD RELY AS LITTLE ON 10 MINUTE RESERVES AS YOU CAN.

UM, I MEAN, THE ADVANTAGE OF NONS SPEND RESERVES IS, IS THEY'RE AVAILABLE TO THE MARKET, UM, MUCH, MUCH MORE SO THAN, UM, THAN 10 MINUTE RESERVES BECAUSE THEY, THEY CAN BE HELD ON UNITS THAT MAY BE SELF COMMITTED.

AND, AND TO THE EXTENT THAT THEY'RE ONLINE, THEY'RE AVAILABLE TO THE DISPATCH, WHICH IS A, A HUGE ADVANTAGE OF THE 30 MINUTE RESERVES OVER, OVER YOUR 10 MINUTE RESERVES.

AND ONE, ONE OF THE, ONE THING I DIDN'T SAY ABOUT THE 10 MINUTE RESERVES IS, IS THAT BUYING MASSIVE AMOUNTS OF 10 MINUTE RESERVES REALLY FLIES AND FLIES IN THE FACE OF THE, THE OVERALL DESIGN PRINCIPLES OF THE OP MARKET.

BECAUSE WHAT YOU'VE ALWAYS RELIED ON IS A VOLUNTARY DATA AHEAD MARKET AND THEN A REALTIME MARKET WHERE, WHERE SUPPLIERS SELF COMMIT AS THEY SEE PRICE SIGNALS THAT WOULD, WOULD JUSTIFY THEM BRINGING THEIR UNITS ON.

AND BY, BY TAKING A LOT OF THOSE RESOURCES AND QUARANTINING THEM OFF, YOU, YOU UNDERMINE THAT, THAT RESPONSE BY GENERATION.

UM, IF YOU'RE BUYING IT ON STORAGE TO THE EXTENT THAT IT'S STORAGE THAT CAN BE DISPATCHED BY THE MODEL, UM, AND YOU'RE REDUCING THE ABILITY FOR STORAGE TO BE DRAWN ON AS CONDITIONS TIGHTEN.

AND SO ALL OF THOSE THINGS LEAD TO THESE, THESE ARTIFICIAL PRICE SPIKES THAT, THAT ARE NOT BASED ON MARKET FUNDAMENTALS.

UM, SO I WOULD RELY AS LITTLE AS POSSIBLE ON TENANT RESERVES.

UM, AND, BUT ULTIMATELY, I THINK IT REALLY IS IMPORTANT TO THINK ACCURATELY ABOUT WHAT THE PURPOSE OF EACH OF THE CLASSES OF RESERVES ARE AND MODEL THE RELIABILITY RISKS IN A, IN A PROBABILISTIC MANNER.

AND THEN LINK HOW MUCH YOU BUY OF EACH PRODUCT TO ITS ROLE IN ADDRESSING THOSE RELIABILITY RISKS.

UM, AND THAT'S WHERE I FEEL LIKE, LIKE IN THE, WHEN I READ THE METHODOLOGY DOCUMENT, IT'S, IT'S, IT'S NOT CLEAR THERE'S HOW THESE PRODUCTS RELATE TO EACH OTHER, BUT IT IS CLEAR THAT THERE'S A LOT OF OVERLAP IN THE DESCRIPTION OF, OF WHAT ONE PRODUCT IS SUPPOSED TO DO AND HOW YOU QUANTIFY HOW MUCH OF IT YOU WANNA BUY VERSUS OTHER PRODUCTS.

UM, SO I, I THINK IN THE LONG RUN, IT'S REALLY IMPORTANT TO, TO DO THAT.

AND I, I WOULD HOPE THESE CHANGES ARE NOT BEING MADE FOR RESOURCE ADEQUACY PURPOSES, BECAUSE LIKE YOU, YOU WANT EFFICIENT MARKET SIGNALS TO BE DRIVING THE DECISIONS THAT PARTICIPANTS ARE MAKING TO, TO BUILD AND, AND RETIRE RESOURCES.

AND LIKE WHEN WE, WHEN WE MADE THE ORDC CHANGES, WE, THEY WERE, THEY WERE MADE DELIBERATELY WITH AN UNDERSTANDING THAT THE PURPOSE OF THEM WAS, WAS TO INCREASE REVENUES.

AND, AND YOU COULD SORT OF ESTIMATE HOW MUCH THEY MIGHT INCREASE REVENUES, UH, BY, BY TRACKING, YOU KNOW, UNDER, UNDER DIFFERENT SUPPLY MARGINS, WHERE YOU WOULD BE ON THE NEW ORDC CURVE VERSUS THE OLD ORDC CURVE.

AND, AND SO THAT'S KIND OF A DELIBERATE WAY TO TRY TO, TO SEND STRONGER PRICE SIGNALS TO IMPROVE RESOURCE ADEQUACY.

THIS, THIS IS SOMETHING ELSE ENTIRELY.

I, THESE ARE, I MEAN, NO ONE WOULD EVER RELY ON ARTIFICIAL'S PRICE SPIKES TO MOTIVATE RESOURCE ADEQUACY.

[03:40:01]

'CAUSE YOU JUST, IT'S, YOU ALMOST CAN'T EVEN PREDICT HOW MUCH MONEY THIS WOULD GENERATE.

UM, UM, BECAUSE IT, IT DEPENDS, IT DEPENDS ON SO MANY DIFFERENT THINGS, INCLUDING HOW AGGRESSIVE ERCOT IS AT PRESSING THE DEPLOYMENT BUTTON ON THE 10 MINUTE RESERVE SO THAT THEY THEN BECOME AVAILABLE TO THE MARKET.

AND, UM, SO, SO THIS, THIS IS NOT A GOOD WAY TO SUPPORT RESOURCE ADEQUACY.

I WOULD, I WOULD DEFINITELY FIX THIS, BUT IT IS ONE REASON WHY, WHY, LIKE, IF YOU HAD BUILT A PEAKER AND SAW THE REVENUES THAT WE, WE WERE PROVIDING IN 2023, YOU WOULD'VE MADE YOUR, YOUR ANNUALIZED INVESTMENT REQUIREMENT LIKE THREE TIMES OVER.

UM, EVEN THOUGH WE'RE, WE'RE ARGUABLY NOT SHORT OF SUPPLY RIGHT NOW.

YOU GOOD? NO FURTHER COMMENT.

NO FURTHER COMMENT AT THIS TIME.

WE HAVE A BIG QUEUE AND ANN AND I ARE, ARE TRYING TO DISCUSS KIND OF TIMING FOR THE REST OF THE DAY.

WE'RE, WE'RE AT ONE 30 ALREADY.

UM, BUT FOR NOW, LET'S CONTINUE WITH THE, THE QUEUE.

I SEE LORI BLOCK.

THANK YOU SO MUCH.

CAN YOU HEAR ME? UH, A LITTLE BIT FAINT, BUT WE CAN HEAR YOU.

OKAY, THANK YOU.

IS THAT BETTER? NOT REALLY .

I'LL TRY TO SPEAK UP.

JUST REJECT THE, AS METHODOLOGY BY PROTOCOL.

UM, MY QUESTION IS FOR, OKAY, MY QUESTION IS FOR ERCOT, UM, IN RESPONSE TO THE IN'S RECOMMENDATION THAT THERE BE PROBABILISTIC MODELING, MY QUESTION IS WHY DID ERCOT NOT DO THIS STOCHASTIC RELIABILITY MODELING? UM, AND WOULD THEY BE WILLING TO DO SO? NOW? IS THERE, IS JEFF HERE I THINK, OR I SEE NETIKA? NO, I CAN START AND MAYBE JEFF MAY WANT TO CHIME IN SOME MORE.

SO CERTAINLY, UH, UH, WELL, TO THE I'S COMMENTS.

I KNOW WE'VE BEEN TALKING ABOUT SOME OF THE IDEAS THAT HAVE BEEN SHARED THROUGH THE PROCESS, AND CERTAINLY WE'VE ADOPTED THE CHANGES IN THE DIRECTION THAT THEY SUGGESTED IN PLACES WHERE WE COULD, THERE WERE CERTAIN OTHERS THAT WE COULDN'T.

AND I GOT IN THE LINE TO JUST EXPLAIN THOSE AND I'LL, I'LL HOLD MY COMMENTS ON THAT END.

WITH REGARDS TO THE SUGGESTIONS YOU'RE SEEING HERE, WE ARE ABSOLUTELY COMMITTED TO, UH, LOOKING, UH, TO LOOKING TO, UH, IDENTIFY WAYS WHERE WE CAN IMPROVE, PROVE OUR, UH, UH, ANALYSIS OF, UH, RELIABILITY RISKS THAT WE SEE AND THE QUANTITY OF AS THAT WE PROCURE.

UM, TODAY, THE PARADIGM THAT WE'VE SET, UH, UH, IS OF COURSE, UH, UH, WAS SOMETHING THAT WE PUT IN PLACE, UH, BASED OFF OF FEEDBACK WE THEY INITIALLY RECEIVED WHERE HAVING, UH, A CERTAINTY OF THE QUANTITIES WE BUY AHEAD OF TIME WAS MORE, UH, VALUABLE THAN, UH, UH, THAN, UM, MAKING CHANGES OR COMING UP WITH THOSE QUANTITIES CLOSER TO REAL TIME.

NOW, UH, ABSOLUTELY WE ARE WILLING TO GO BACK AND REVISIT OUR, UH, OUR THINKING AROUND WHAT THE MAAS QUANTITY PROCESS COULD LOOK LIKE, UH, IF WE WERE TO ADOPT A DIFFERENT APPROACH.

I'LL ALSO RECOGNIZE THE PUC HAS STARTED OR IS LOOKING TO START SOMETHING AROUND THE ANCILLARY SERVICE METHODOLOGY.

AND THAT'S PARTLY ONE OF THE THINGS I WAS ALLUDING TO IN MY COMMENTS BACK TO BILL AT POST THIS DISCUSSION THAT WE ARE HAVING TODAY.

AND BEFORE WE START NEXT YEAR'S DISCUSSION, THERE IS MORE CONVERSATIONS TO BE HAD AROUND DEFINING WHAT OUR ANCILLARY SERVICE QUANTITIES MEAN, WHAT THE RISKS WE LOOK, UH, TO COVER, AND HOW THEY CAN BE FURTHER DEFINED.

SO THERE ARE, TO ME, THERE ARE, THERE IS ALREADY, UH, PIECES BEING LINED UP FOR US TO CONTINUE THIS DISCUSSION.

UH, AND, AND THROUGH THOSE WE WOULD CERTAINLY BE LOOKING TO ADOPT WHAT CHANGES, UH, WE AND THE STAKEHOLDERS ALL THINK ARE BENEFICIAL.

AND JEFF, YOU MAY WANT TO SUPPLEMENT.

NO, I THINK I, I THINK YOU SAID IT WELL.

WE'RE, WE'RE, YOU KNOW, DEFINITELY OPEN TO, YOU KNOW, DISCUSSING NEW WAYS AND, AND, UH, YOU KNOW, ALTERNATIVE WAYS OF THINKING ABOUT THIS.

UM, YOU MEAN THIS IS KIND OF A NEW PROPOSAL AS OF LATE LAST WEEK, AND SO I, I DON'T THINK THAT WE'VE HAD EN ENOUGH CHANCE TO, TO DIGEST IT FULLY.

UM, AND, AND I THINK IT'LL TAKE SOME TIME.

I, I, I DO WANT TO POINT OUT, AND MS K KIND OF ALLUDED TO THIS, THAT, UH, WE, WE, WE, WE CAN'T

[03:45:01]

WE, WE HAVE TO HAVE AN AS METHODOLOGY.

UM, SO I THINK PROCEDURALLY WE, WE HAVE TO, THE BOARD HAS TO APPROVE SOMETHING.

UH, WE, WE CAN'T JUST REJECT IT.

AND, AND SO I THINK WHAT I WOULD PROPOSE IS THAT, UM, YOU KNOW, WE, WE LOOK AT THESE IDEAS A LITTLE BIT FURTHER, UH, BUT I, I THINK, YOU KNOW, FOR DECEMBER APPROVAL OF THE AS METHODOLOGY, IT'S, IT'S PROBABLY TOO LATE FOR, FOR THAT.

UM, IT'S SOMETHING THAT WE LOOK AT, UH, AS, AS WE GO INTO NEXT YEAR AND AS WE HAVE THIS KIND OF BROADER DISCUSSION WITH THE COMMISSION, UH, IN WHICH THE IMM IS ALSO INVOLVED IN.

HEY, JEFF, JUST AS A FOLLOW UP, THIS IS LARRY AGAIN.

UM, IS THERE ANY PROHIBITION TO THE BOARD APPROVING A METHODOLOGY AND THEN MODIFYING IT SUBSEQUENT TO THAT APPROVAL? UM, SORT OF LIKE IN AN INTERIM BASIS? SO COULD THEY APPROVE THE METHODOLOGY, A METHODOLOGY IN DECEMBER AND THEN MAKE ADJUSTMENTS, UM, LIKE LET'S SAY YOU DID SOME KIND OF PROBABILISTIC ANALYSIS, COULD THEY MAKE ADJUSTMENTS BASED ON THAT? UM, IN, YOU KNOW, NOT AT THE NORMAL TIME, BUT YOU KNOW, SOME, SOME TIME IN THE INTERIM.

IS THERE ANY PROHIBITION AGAINST THAT? I, I'M, I'M NOT AWARE OF ANY.

UH, I, I THINK THE REQUIREMENT IS THAT THE BOARD REVIEW THE METHODOLOGY AT LEAST ANNUALLY.

UH, SO I, I THINK IT'S CERTAINLY POSSIBLE THAT THEY COULD, UM, UH, CHANGE IT, UH, YOU KNOW, MIDYEAR.

I THINK WE'VE DONE THAT BEFORE, I THINK IN 2021, UH, THAT THERE WAS A MID-YEAR CHANGE.

UM, SO I THINK THAT'S, YOU KNOW, I THINK THAT'S CERTAINLY POSSIBLE PROTOCOL.

THANK YOU FOR MUCH.

YEAH, AND I'LL, I, I SHOULDN'T PUT THE DISCLAIMER OUT IT, IF THERE ARE ANY OTHER ERCOT STAFF THAT, UM, WANTS TO CORRECT THAT, IF THEY THINK SOMETHING DIFFERENT, THEN PLEASE JUMP IN.

WERE WE WANTING SOMEONE ELSE TO JUMP IN OR ARE WE GOOD ON THIS DISCUSSION? OKAY, SO, UM, WE, I JUST WANNA FLAG, WE DO HAVE A, A QUEUE BUILT UP.

UM, LOOKING AT OUR AGENDA, WE PROBABLY HAVE AN HOUR AND A HALF WORTH OF ITEMS AFTER THIS ITEM, WHICH WOULD TAKE US, I'M GUESSING TILL FOUR.

UM, SO WE, WE COULD DO THAT.

ANN AND I, THE OTHER PROPOSAL WOULD BE TO RECESS AFTER THIS AS METHODOLOGY ITEM AND, AND MEET BACK UP EITHER TOMORROW AFTERNOON OR FRIDAY MORNING, WEBEX ONLY.

UM, WE, WE BELIEVE WE COULD EITHER JUST RECESS AND THEN RESET, OR I'LL AGREE TO WAIVE NOTICE.

WE, WE WOULDN'T ADD ANY NEW ITEMS, BUT A NUMBER OF THE ERCOT REPORTING ITEMS WE DO NEED TO APPROVE OR REVIEW BEFORE DECEMBER BOARD.

UM, SO I JUST WANTED TO KIND OF GET A, A CHECK IN THE ROOM ON, ON WHAT PEOPLE WOULD PREFER.

AGAIN, I THINK IF WE WENT THROUGH EVERYTHING, IT WOULD PUT US HERE TILL PROBABLY FOUR.

UM, WE, OR WE COULD KIND OF RECESS AND, AND MOVE THE REPORTING ITEMS TO, TO ANOTHER DAY.

WHAT WERE THE OPTIONS AGAIN? SO , SO WE COULD GO, WE COULD POWER THROUGH TODAY.

I, I, LOOKING AT THE AGENDA, I THINK THE REPORTS AND OTHER BUSINESS AFTER THIS AS METHODOLOGY IS PROBABLY AN HOUR AND A HALF WORTH OF THINGS.

I THINK WE PROBABLY HAVE ANOTHER HOUR ON THIS OR MAYBE EVEN LONGER.

SO I, IT'S, IT'S ONE 30 NOW.

I THINK THAT WOULD TAKE US TILL FOUR.

UM, THE OPTION TWO WOULD BE FINISH THIS AS AS METHODOLOGY AND THEN MEET LATER IN THE WEEK.

AND WE WOULD MEET LATER IN THE WEEK, EITHER BY, I THINK WE COULD RECESS TODAY AND JUST START UP, AND IT'S THE SAME MEETING BASICALLY.

NOW WE'RE KIND OF LIKE IN SENATE RULES OR SOMETHING.

OR IF WE END TODAY, WE WOULD JUST KIND OF WAVE NOTICE ON, ON ALL THE, BECAUSE WE'RE TRYING TO GET AROUND THE, THE WAIVE NOTICE REQUIREMENT, BUT WE WOULD AGREE NOT TO ADD ANY ITEMS AND WE, WE'D AGREE TO WAIVE NOTICE FOR THAT SECOND MEETING.

CAITLYN, CAN I SUGGEST ANOTHER OPTION AS WELL THAT WE, UM, COMPLETE THE REST OF THE AGENDA AND NOT DO THIS OR DO THIS AT A, AT A AT ANOTHER TIME IF PEOPLE AREN'T PREPARED TO VOTE TODAY? OKAY.

SO THAT WOULD BE PAUSE WHERE WE ARE NOW, COMPLETE THE OTHER, THE ERCOT REPORTS, UM, AND THEN TAKE THE AS METHODOLOGY UP AT A SEPARATE STANDALONE MEETING.

THAT WOULD BE MY

[03:50:01]

PREFERENCE.

IF FOLKS ARE OPEN TO THAT, I'M ALSO HAPPY TO, YOU KNOW, MOVE FORWARD.

BRIAN? YEAH, I, THIS IS DAVID PATTON.

I WANNA NOTE I I HAVE LESS THAN 30 MINUTES SO THAT THE LAST OPTION MIGHT BE GOOD IF, IF A LOT OF THE PEOPLE WHO ARE IN THE QUEUE HAVE QUESTIONS FOR ME AS OPPOSED TO QUESTIONS FOR ERCOT.

I GUESS I MIGHT HAVE A QUESTION TO ERCOT ON THAT, TO, TO CONFIRM THAT WOULD BE OKAY.

UM, AND IT SOUNDS LIKE WE WOULD BE T KIND OF TABLING THIS ITEM THEN, AND THEN TAKING, TAKING IT UP AT A LATER DATE.

I BELIEVE THIS NEEDS TO BE APPROVED BY DECEMBER BOARD, OR IDEALLY WOULD, DOES ERCOT WANNA WEIGH IN? UM, I, I, I CAN PROCEDURALLY WEIGH IN.

UM, UH, WE DO NEED THIS METHODOLOGY APPROVED BY DECEMBER BOARD, UM, AS JEFF MENTIONED, WE COULD KEEP WORKING ON IT AFTER THAT, BUT SOMETHING NEEDS TO BE APPROVED BY THE DECEMBER BOARD.

UM, I UNDERSTAND THE BALLS YOU'RE TRYING TO JUGGLE.

SO, UH, YOU KNOW, HAPPY TO WORK THROUGH THE REST OF THE AGENDA AND THEN BRING THIS UP.

THIS ITEM IS AN ENDORSE ONLY ITEM BY, UH, LET'S SEE, WERE THERE ANY OTHER PROCEDURAL THINGS THAT I WANTED TO SAY? UH, BUT I, I DO THINK THE BOARD WANTS TO HEAR FROM TACK ON THIS ITEM, UM, MARK DREYFUS MAYBE MAKE, SO, SO WE'RE, WE'RE DISCUSSING HERE AND, AND LET ME THROW OUT AN ALTERNATIVE THAT MAYBE COULD MOVE US FORWARD.

UM, WE'VE BEEN DISCUSSING THE OPTION OF APPROVING THE DOCUMENT AS PRESENTED WITH A COMMITMENT THAT WE REEVALUATE ECRS PRIOR TO THE SUMMER.

IS THAT, AND, AND WOULD THAT SPEED US FORWARD IF WE WERE TO MOVE FORWARD WITH SUCH A PROPOSAL? 'CAUSE I WOULD BE WILLING TO MAKE THAT MOTION IF WE THOUGHT WE COULD MOVE FORWARD.

CAN I, CAN I, I THINK I'M NEXT IN THE QUEUE.

CAN I GO? UM, WELL, I STARTED A SUBQ WHY, WHY DON'T I LET YOU, OH, OKAY.

UH, THANK, THANK YOU SO MUCH.

YOU'RE, YOU'RE NOT NEXT IN THE AS METHODOLOGY QUEUE, BUT YOU'RE NEXT IN THE, WHAT ARE WE DOING RIGHT NOW? QUEUE? OKAY.

WELL, I, I MEAN, I WAS PREPARED TO MAKE A MOTION TO APPROVE THE METHODOLOGY AS PROPOSED BY ERCOT.

IT'S BEEN THROUGH THE STAKEHOLDER PROCESS, ENDORSED BY BOTH THE WHOLESALE MARKET SUBCOMMITTEE AND ROSS.

UM, I ALSO SAY THAT, UM, THERE ARE, ARE PROJECTS THAT ARE, ARE READY TO MOVE FORWARD AND THEIR CONTINGENT UPON HAVING A LINE OF SIGHT AND VISIBILITY INTO WHAT, UH, 2024 AS QUANTITIES LOOK LIKE.

AND TO THE EXTENT THAT WE DON'T PROVIDE THAT KIND OF CERTAINTY, YOU, YOU MAY NOT GET THE, THE, UH, NEW BUILDS THAT I THINK THE STATE WANTS.

UM, AND I'LL LEAVE IT AT THAT.

AND KAITLYN, I'LL SECOND THE MOTION TO APPROVE.

SO WE NOW HAVE A MOTION.

LET, LET'S GO BACK TO, LET'S GIVE EVERYBODY IN THE REAL QUEUE AN OPPORTUNITY TO SPEAK AND SEE IF WE CAN RESOLVE THIS IF WE CAN'T AT THAT TIME.

EMILY, THEN LET'S TAKE YOUR DIS YOUR, YOUR RECOMMENDATION AND RECONVENE ON AS METHODOLOGY.

SO, UM, SO I, I SEE YOUR QUESTION TO DR. PATTON.

JASON COX.

ARE, ARE YOU READY TO GO AHEAD WITH THAT QUESTION? YEAH.

THANKS, CAITLIN.

CAN YOU HEAR ME ALL RIGHT? I CAN HEAR YOU.

THANK YOU VERY MUCH.

UH, JASON COX WITH EQ ENERGY ADVISORS, UH, DR. PATTON, UH, WHICH HAS THE HIGHER IMPACT IN YOUR ESTIMATION OR WEIGHTING IN YOUR ANALYSIS, THE EXCESSIVE, UH, AMOUNTS OF RESERVES OR THE FACT THAT THEY'RE QUARANTINED BEHIND, YOU KNOW, QUARANTINE FROM UNTIL THEY'RE ACTIVATED? I, WELL, IT'S HARD TO SEPARATE THOSE TWO.

THE, CERTAINLY THE FACT THAT IT'S QUARANTINED IS, IS, UH, IS INCREDIBLY IMPORTANT.

IF, IF THEY WEREN'T QUARANTINED, LIKE IF, IF YOU HAD A CO OPTIMIZ SYSTEM, THEN YOU WOULD, WE WOULD HAVE TO ASK OURSELVES, WHAT, WHAT DEMAND CURVE WOULD WE ATTACH TO THOSE 10 MINUTE RESERVES? AND IF IT WAS REALLY HIGH, THEN YOU WOULD SORT OF GET THE SAME OUTCOME AS QUARANTINING THEM.

SO IT'S HARD TO, IT'S HARD TO SAY IT'S ONE OR THE OTHER, BUT, UM, UM, SO I'D SAY IT'S A COMBINATION OF BOTH.

BUT CERTAIN, CERTAINLY WE WERE QUARANTINING RRS BEFORE WE CREATED ECRS, AND, YOU KNOW, WE DIDN'T SEE THESE ARTIFICIAL SHORTAGES BECAUSE THE QUANTITIES WERE

[03:55:01]

SO MUCH SMALLER.

OKAY, THANK YOU.

UM, SO THEN AIKA AND SHE MAY HAVE, SHE MAY HAVE BEEN RESPONDING TO SOMEBODY, SO, SO I THINK I'LL SKIP THAT.

BRIAN, DID WE GET YOUR MOTION? I, I DON'T KNOW.

I MEAN, I THINK I CALLED THE QUESTION AND I HAD A SECOND.

I, I THINK WE'RE READY FOR DISCUSSION ON THE MOTION NOW.

WELL, YOU DIDN'T CALL, WE DIDN'T CALL A QUESTION.

WE JUST, WE, WE CAN TAKE DISCUSSION ON THE MOTION.

BUT WE GOT YOUR MOTION.

WOULD YOU LIKE, OKAY, SO WE HAVE ERIC GOFF, CHRIS HENDRICKS, NED, I JUST WANTED TO, AS A COURTESY, EVERYONE GOT IN THE QUEUE.

LET'S GET THROUGH THE QUEUE AND THEN TAKE YOUR MOTION.

SO YEAH, CALL, CALL TO QUESTION IS A DIFFERENT MOTION.

SO WE, WE DO TYPICALLY DISCUSS MOTIONS ON THE TABLE MOTION.

ERIC, DID YOU WANNA MAKE A COMMENT? YEAH, BUT JUST A POINT OF ORDER.

IS THERE A MOTION TO CALL THE QUESTION ON THE, ON THE FLOOR, THERE IS ONLY A MOTION TO APPROVE THE AS METHODOLOGY AS PRESENTED BY ERCOT.

SO NOW WE'RE ALLOWING THE REST OF THE DISCUSSION TO CONTINUE.

UM, SO DURING JEFF'S RESPONSE TO, UH, DR. PATTON, UH, HE, YOU SEEM TO INDICATE THAT THERE'S OPENNESS TO REVIEWING SOME OF THESE IDEAS IN WHAT SEEMED TO BE THE NEAR TO MEDIUM TERM, UM, BUT WANTED TO GET SOMETHING APPROVED TODAY BECAUSE OF THE PROTOCOL REQUIREMENTS, WHICH I COMPLETELY APPRECIATE.

AND, UH, JEFF, I WONDER IF YOU COULD REACT TO MARK DREYFUS SUGGESTION OF REVISITING THE ECRS PORTION OF THE METHODOLOGY, UM, SOMETIME IN, UM, NEXT YEAR BEFORE THE SUMMER.

WOULD, IS THAT SOMETHING THAT Y'ALL WOULD BE OPEN TO, UH, DOING? OR DO YOU THINK THAT, THAT THAT TIMING DOESN'T WORK? SO, UH, I, I, I WOULD SAY, UH, LET, LEMME SAY A COUPLE THINGS IS I THINK ONE IS, I THINK SOME OF THE, SO SOME OF THE THINGS IN THE IMM PRESENTATION I, I THINK HAVE SOME FUNDAMENTAL FLAWS.

UM, BUT THAT, THAT SAID, I, I THINK THAT WE ARE OPEN TO DIFFERENT WAYS OF LOOKING AT IT, IF THAT MAKES SENSE.

I, BUT I, I, I, I DON'T, BUT SOME OF WHAT'S IN THERE, I THINK WE, WE JUST HAVEN'T FULLY DIGESTED YET.

SURE.

AND, AND SO JUST TO REPEAT MY QUESTION, I'M SORRY.

JUST YEAH, I WANNA MAKE SURE WE'RE TALKING ON THE SAME, SAME PAGE.

UM, YEP.

THE QUESTION WAS NOT TO ENDORSE THE IMM PROPOSAL, BUT TO REVIEW THE ECRS METHODOLOGY IN THE FIRST PART OF NEXT YEAR BEFORE SUMMER.

SO, SO, UM, HERE, HERE, HERE'S WHAT I WILL COMMIT TO AND WHAT I WON'T COMMIT TO.

I, I WILL COMMIT TO, UM, CONSIDERING THAT AND, AND HAVING SOME DISCUSSIONS ABOUT THAT.

UH, BUT I WON'T COMMIT TO A ACTUALLY CHANGING ANYTHING.

UM, YOU KNOW, I, I, I THINK THAT WE, WE NEED TO, AGAIN, WE, WE JUST HAVEN'T HAD A CHANCE TO LOOK AT THAT.

AND, YOU KNOW, I, I DON'T KNOW, UH, IF THERE'S SOME FLAWS IN, IN THAT THINKING, WE, WE JUST HAVEN'T HAD A CHANCE TO THINK ABOUT THAT INTERNALLY.

SO I, I THINK I'D WANNA TALK TO SOME OTHER FOLKS INTERNALLY, UH, BEFORE COMMITTING TO PROPOSE ANY SORT OF CHANGES.

UH, I, I THINK I, I CAN COMMIT TO CONSIDERING THAT, BUT I THINK THAT'S ABOUT ALL I CAN COMMIT TO TODAY.

AND JUST TO FOLLOW THAT, I'M NOT TRYING TO, UM, BE ANTAGONISTIC OF THESE FOLLOW UP QUESTIONS, I JUST WANNA MAKE SURE WE'RE SPEAKING CLEARLY 'CAUSE PEOPLE ARE PAYING ATTENTION.

SO, SURE.

UM, THE, THE TIMING OF, OF THAT, IT'S, IT'S SOMETHING YOU, YOU'D BE OPEN TO THE CONVERSATIONS NEXT YEAR, AND POTENTIALLY THOSE CONVERSATIONS COULD TURN INTO A RECOMMENDED CHANGE IN THE METHODOLOGY, BUT YOU, YOU'RE NOT SURE IF YOU'RE ABLE TO COMMIT TO A RECOMMENDED CHANGE, BUT YOU ARE WILLING TO COMMIT TO A CONVERSATION THAT MIGHT LEAD TO A RECOMMENDED CHANGE.

IS THAT, IS THAT A GOOD SUMMARY? YEAH.

I, I THINK THAT'S FAIR.

YOU KNOW, THE, THE OTHER THING THAT WE NEED TO BE COGNIZANT OF IS THE FACT THAT THE COMMISSION IS ALSO GOING TO BE LOOKING AT THESE THINGS.

AND, UM, I, I WOULD GUESS THAT IF THERE WAS SOMETHING THAT WE ALL AGREED ON AND IT LOOKED LIKE THAT, THAT WAS A RIGHT WAY OF THINKING OF THINGS, AND, YOU KNOW, I AM, I WOULD GUESS THAT THE COMMISSION WOULDN'T WANT TO SLOW THAT DOWN.

BUT, YOU KNOW, THERE'S A, THERE'S A PROCESS THERE AND THERE'S A DANCE THAT WE, WE HAVE TO BE CAREFUL OF TOO AS WELL.

OKAY,

[04:00:01]

OKAY, SO NOW WE'RE RETURNING TO NITKA.

SO, SORRY, MAY I JUST TO DAN'S, UH, TO JEFF'S POINT, MAYBE ONE LAST THING, ERIC, I KNOW THERE IS A DESIRE TO EVEN TRANSLATE THE PROCESS TO WHERE THE COMMISSION APPROVES, UH, THE AS METHODOLOGY, AND LIKELY NEXT YEAR WOULD BE THE FIRST YEAR.

THE BACKCAST THAT I'VE DONE SAYS AROUND SUMMERTIME IS LIKELY WHEN WE WOULD BE STARTING TALKING ABOUT 20, 25 NEXT YEAR, JUST SO THAT WE CAN MAKE THAT DANCE WORK.

SO I, I MEAN, I'M ABSOLUTELY ON THE SAME PAGE AS JEFF.

UH, WE ARE, WE ARE WILLING TO CONSIDER THE PCRS RELATED RECOMMENDATIONS AND THINK THROUGH THOSE.

BUT I ALSO WANT TO CAUTION YOU FROM A TIMING PERSPECTIVE, WE'LL BE RUNNING INTO AN OVERLAP BECAUSE WE'LL BE TALKING ABOUT 2025 AROUND THE SAME TIMEFRAME, UH, THAT YOU'RE SUGGESTING US TO WRAP UP THINKING ABOUT ECRS.

THAT, UM, YOU KNOW, POLICYMAKERS AND STAKEHOLDERS HAVE BEEN DISCUSSING OVER THE LAST ALMOST THREE YEARS NOW, UM, YOU KNOW, THAT'S, THAT'S, THAT'S A REAL, UH, A REAL CONCERN AND SOMETHING THAT, UM, WANTED TO, TO HIGHLIGHT THAT AS WELL.

THANKS IKA.

UM, CHRIS HENDRICKS, THANKS.

UM, I THINK THIS IS A REALLY GOOD EXAMPLE OF WHY THE INDEPENDENT MARKET MONITOR IS KEY TO THE, THE WHOLE STAKEHOLDER PROCESS, SO THAT THEY BRING KIND OF AN INDEPENDENT VIEWPOINT INTO HOW THE MARKET WORKS AND HOW IT FUNCTIONS.

SO I WANTED TO JUST SAY THAT, AND THEN ONE QUESTION FOR, UH, DR. PATTON, DID YOU SEE ANY, ANY KIND OF QUESTIONABLE BIDDING, OR IS ALL OF THIS RELATED TO JUST THE, THE PROCUREMENT AMOUNT EXCEL ITSELF? THAT'S A GREAT QUESTION.

UM, BECAUSE I THINK SOME PEOPLE HAVE, SOME PEOPLE HAVE BLAMED THE, THE STORAGE RESOURCES WHO, UM, HAVE GENERALLY OFFERED AT A VERY HIGH PRICE, UH, THIS SUMMER.

SO THEY'VE, THEY'VE CONTRIBUTED TO THE HIGH PRICES.

THE PROBLEM IS WHAT THEY'RE DOING IS A SECONDARY RESPONSE TO, TO THIS PROBLEM.

BECAUSE IF YOU'RE, IF, IF YOU HAVE A MARKET THAT'S, THAT'S OVER CONSTRAINED LIKE THIS, AND YOU'RE GETTING ARTIFICIAL PRICE SPIKES, YOU KNOW, UPWARDS OF $5,000, THEN AS A, AS A BATTERY DEVELOPER, THERE'S NO WAY YOU CAN OFFER AT $300 OR $400 OR $500 BECAUSE YOU MAY, YOU MAY BE DISPATCHED AND THEN BE OUT OF CHARGE WHEN PRICES ARE $5,000 AND, AND LOSE A TREMENDOUS AMOUNT OF MONEY.

SO, SO I WOULD SAY THERE'S OFFER BEHAVIOR THAT CONTRIBUTED TO THESE HIGH PRICES, BUT IT'S, BUT IT LOOKED COMPETITIVE TO US.

AND, UH, AND A RESPONSE TO, TO THE PRICE SPIKES THAT THESE PROCUREMENT REQUIREMENTS WERE, WERE CAUSING.

AND I THINK THOSE, IF WE FIX THIS PROBLEM, THEN I THINK THOSE, THOSE OFFERS COME WAY DOWN.

OKAY, NED, THANKS, CAITLYN.

UM, WHAT ONE THING THAT, UM, JUST GOING BACK TO MY, MY VERY FIRST ECONOMICS CLASS, I REMEMBER ONE OF THE FIRST THINGS THEY, THEY TAUGHT US ABOUT WAS THE DIFFERENCE BETWEEN POSITIVE ECONOMICS AND NORMATIVE ECONOMICS, WHICH IS, YOU KNOW, THE DIFFERENCE BETWEEN WHAT IS VERSUS WHAT WHAT WE THINK SHOULD BE.

AND I, I, IN THE DISCUSSION TODAY, I KEEP HEARING A LOT MORE OF THE WHAT SHOULD BE VERSUS WHAT IS.

AND SO WANTED TO AT LEAST MAKE A FEW COMMENTS ALONG THE LINES OF WHAT I, I, I THINK THE, THE POSITIVE OR WHAT IS, UH, QUESTIONS OR, OR, UH, TOPICS ARE THAT I THINK WE SHOULD, WE SHOULD KEEP IN MIND.

UM, YOU KNOW, THE FIRST ONE, AND I THINK JEFF MENTIONED THIS, IS THAT, UM, YOU KNOW, WE HAVE TO HAVE AN AS METHODOLOGY IN FOUR WEEKS TIME.

WE'VE GOTTA HAVE SOMETHING THAT WE CAN RELY ON.

MARKETS NEED MORE CERTAINTY, NOT LESS, ESPECIALLY RIGHT NOW, UM, THAT'S A , THAT'S A LONG-TERM TREND.

AND, AND SO I THINK IT'S, IT BEHOOVES US TO MOVE THE BALL FORWARD.

AND I APPRECIATE BRIAN, UH, BRINGING THE MOTION FORWARD TO, YOU KNOW, TAKE US TAKE A POSITIVE STEP TOWARDS THAT.

UM, AND THE, THE SECOND ITEM IS THAT, YOU KNOW, WE DO HAVE A RESOURCE ADEQUACY CHALLENGE IN ERCOT.

I THINK IT'S, IT'S REALLY HARD FOR ME TO UNDERSTAND HOW, YOU KNOW, AFTER GOING THROUGH THE SECOND HOTTEST SUMMER THAT WE'VE HAD, UH, AND, AND ONE OF THE TIGHTEST SUMMERS WE'VE HAD WHERE WE RELIED IN AND SOMETIMES EXCLUSIVELY ON, UH, INTERMITTENT AND LIMITED DURATION RESOURCES IN ORDER TO BE ABLE TO BALANCE LOAD.

UH, WE HAD OUR FIRST EEA EVENT SINCE WINTER STORM URI, AND, UM, YOU KNOW, WE , WE JUST WENT THROUGH THE, UH, THE RFP PROCESS WITH ERCOT, WHICH, YOU KNOW, SEEMS LIKE IT WAS, UH, HIGHLIGHTING THE RESOURCE ADVOCACY CHALLENGES THAT WE HAVE, UH, YOU KNOW, GOING INTO, INTO THIS WINTER.

UM, ALONG WITH ALL THE OTHER POLICY CONSIDERATIONS THAT,

[04:05:01]

AND THAT CURRENTLY SITS, WE HAVE TO RESOLVE THAT IN AN ENERGY ONLY MARKET, WHICH MEANS WE HAVE TO DEPEND EXCLUSIVELY ON ENERGY AND ANCILLARY SERVICES TO INCENTIVIZE RESOURCE ADEQUACY.

UH, THE OTHER MARKETS THAT WERE SHOWN IN, IN DR.

PATTON'S PRESENTATION, I BELIEVE ALL OF THOSE SOLVE THAT THROUGH A CAPACITY MARKET.

SO WE ARE, WE ARE COMPARING APPLES AND ORANGES A LITTLE BIT THERE.

UM, AND THAT, THAT'S JUST THE FACT OF THE MATTER, RIGHT? WE HAVE AN INTER GENERAL MARKET.

WE NEED TO, UH, THINK ABOUT IT IN THOSE TERMS. UH, ANOTHER ITEM IS JUST THE CONTEXT IN WHICH THIS DISCUSSION IS HAPPENING.

YOU KNOW, THE ERCOT MARKET IS A 40 PLUS BILLION DOLLARS MARKET PER YEAR.

YOU KNOW, THAT IS, YOU KNOW, THAT'S LOOKING AT EIA DATA FROM LAST YEAR.

UM, AND AS DR. PATTON IMPORTANTLY RECOGNIZED, YOU KNOW, CONSUMERS DON'T PAY THESE COSTS THAT WE'RE TALKING ABOUT DIRECTLY.

IT, IT INFLUENCES FORWARD MARKETS, IT INFLUENCES CONTRACTING, BUT MOST CUSTOMERS DO NOT, UH, DO NOT HAVE DIRECT EXPOSURE TO THAT UNLESS PERHAPS THEY'VE CONTRACTED THAT WAY AND, AND AGREED TO A RISK SHARING AGREEMENT.

BUT, YOU KNOW, THAT'S THE WHOLESALE MARKET.

AND WE, WE WOULD EXPECT THAT THERE BE VOLATILITY AROUND THAT WE'D, UH, AND THAT HELPS TO DRIVE RESPONSES, RIGHT? SO WITH ECRS GOING LIVE DURING ONE OF THE HOTTEST SUMMERS ON THE RECORD, WHEN WE HAD A LOT MORE FLEXIBLE LOADS, WE HAD ERCOT CONTENDING WITH SOME OF THE CONCERNS THEY HAD ABOUT TRANSITORY EVENTS AND STABILITY EVENTS, YOU KNOW, THAT THEY HAVE A LOT MORE RISKS THEY NEED TO MANAGE.

UM, AND, UH, AND SO, YOU KNOW, I, I THINK THEY'VE DONE A GOOD JOB, FRANKLY, OF BALANCING, TAKING INTO CONSIDERATION THE CONCERNS THAT STAKEHOLDERS HAVE BROUGHT FORWARD WITH RECOGNIZING THEY NEED TO BE ABLE TO RESPOND TO A LARGE NUMBER OF CONTINGENCIES AND, AND THAT THEY HAVE TO DO THAT AS AN ISLAND.

AND, UM, YOU KNOW, TO ME, THAT THAT DOESN'T SUGGEST THAT THE SCARCITY PRICING SIGNALS WERE ARTIFICIAL, BUT RATHER THEY WERE REFLECTIVE OF A HIGHER VALUE TO OPERATING RESERVES THAT OUR CUT NEEDS.

SO, UM, I, YOU KNOW, WE ARE IN A MARKET, I THINK MARKET PARTICIPANTS WILL REACT TO THAT, THAT WILL SELF-CORRECT OVER TIME.

AND SO RATHER THAN, YOU KNOW, FO FIXATING ON THE ECRS GO LIVE DURING THE SUMMER, WHICH I THINK WAS AN EXTRAORDINARY SITUATION, WE SHOULD TRY TO SEND A SIGNAL OF CERTAINTY AND LET THE MARKET WORK TOWARDS THAT.

SO I'LL STOP THERE.

THANKS, NED.

SO WE DO, WE DID HAVE A MOTION AND A SECOND TO APPROVE THE AS METHODOLOGY AS RECOMMENDED BY ERCOT AND ROSS AND WMS, I BELIEVE.

IS THAT CORRECT? SO, COREY, I THINK WE, UM, WILL CLEARLY NEED A BALLOT ON THIS MOTION, NOT A COMBO BALLOT.

FAIR ENOUGH.

WAIT, I MEAN, WE CAN TRY, BUT YEAH, I'M AN OPTIMIST.

ON THE MOTION TO ENDORSE THE 2024 AS METHODOLOGY AS RECOMMENDED BY ERCOT, WE WILL START UP WITH THE CONSUMER SEGMENT WITH MARK.

AND THEN GARRETT FOR BILL ABSTAIN.

THANK YOU, ERIC.

NO, THANK YOU, NARAJ, NO THANKS.

ONTO OUR CO-OPS, UH, SINCE WE'RE PAST OUR ONE O'CLOCK TIME, UH, LIMIT, I THINK, UH, KATIE'S IN FOR MIKE.

NO, THANK YOU, SIR, ONTO OUR INDEPENDENT GENERATORS.

BRIAN? YES, THANK YOU, KAITLYN.

THANK YOU, CORY, THANK YOU.

ONTO OUR IPMS. JEREMY? YES, THANK YOU, REMI.

YES, THANK YOU, KEVIN.

ONTO OUR IRESS, BILL.

[04:10:01]

YES, THANK YOU, DAVID.

AND, UH, DAVID FOR RICHARD ROSS.

YES, THANK YOU, SIR.

ON TO MUNIS, JOSE ABSTAIN.

UH, MOTION FAILS 63%, FOUR 37% AGAINST, WITH 11 ABSTENTIONS.

UM, ERIC GOFF, GO AHEAD.

I'D LIKE TO MOVE FOR THE MOTION THAT MARK DREYFUS SUGGESTED EARLIER, WHICH IS TO, UH, HAVE TAC RECONSIDER, UM, THIS RECOMMENDATION, UM, IN TIME FOR A POTENTIAL CHANGE TO THE ECS METHODOLOGY BEFORE SUMMER.

ERIC, IF YOU'RE GONNA DO THAT, SHOULD WE JUST PUT A DATE WHEN WE'RE GONNA REVISIT IT AS OPPOSED TO LEAVING IT OPEN? UH, I'M OPEN TO THAT.

UM, I THINK WE'D HAVE TO DO IT AFTER WINTER, SO IN THE SPRING, BUT I, I, I HEARD NETIKA SAY THERE MIGHT NEED TO BE SOME PREP WORK, SO I WOULD SAY MARCH OR APRIL.

SO THE MOTION WOULD BE TO ENDORSE THE 24 ANCILLARY SERVICE METHODOLOGY AS RECOMMENDED BY ERCOT, BUT REVISIT THE 24 METHODOLOGY AT A DATE IN 24.

IN MARCH OR APRIL FOR, YEAH.

SO THE PROTOCOLS AS A REMINDER SAY THAT THE ANSWERING SERVICE METHODOLOGY HAS TO BE APPROVED AT LEAST ANNUALLY, BUT OPENS IT TO BEING APPROVED MORE THAN ONCE A YEAR.

AND WE'VE DONE THAT IN THE PAST.

I THINK YOU, CAN YOU GET CLOSER TO THE MIC MAYBE AND REPEAT THAT? YEP.

I APOLOGIZE.

UH, SO AS A REMINDER, THE PROTOCOLS REQUIRE THAT THE ANSWERING SERVICE METHODOLOGY BE APPROVED AT LEAST ANNUALLY, BUT, UM, ALLOWS IT TO BE APPROVED MORE THAN ONCE ANNUALLY.

AND AS JEFF NOTED, THAT'S HAPPENED IN THE PAST.

COREY AND ANNE ARE MAKING SOME FACES BACK AND FORTH, SO LET'S, LET'S SEE WHAT THEY HAVE TO SAY ABOUT THE MOTION.

'CAUSE LIKE I SAID, IT SOUNDS LIKE THE EFFECT OF THAT WOULD BE A SUNSET BECAUSE YOU'RE, IT SOUNDS LIKE YOU'RE SAYING WE ONLY WANNA APPROVE THE METHODOLOGY FOR THE FIRST COUPLE OF MONTHS OF 2024.

NO, BECAUSE WE'RE EXPECTING SOME CHANGE TO COME SO THAT WHAT'S, WHAT'S IN FRONT OF YOU TODAY WOULD NOT BE IN EFFECT FOR MARCH OR APRIL BEYOND, BECAUSE THERE WOULD BE THESE SUBSTANTIVE CHANGES.

AND I DON'T BELIEVE WE HAVE ANY OF THOSE TO REVIEW YET.

SO TO YOUR POINT, YES, APPROVING THE METHODOLOGY TODAY DOES NOT STOP JEFF IKA AND COMPANY FROM COMING IN JANUARY OR FEBRUARY TO MAKE THOSE CHANGES LIKE YOU'RE TALKING ABOUT.

BUT THAT HAS HAPPENED IN THE PAST AND HAPPENS ON A, A ORGANIC'S NOT THE RIGHT WORD, BUT IT, IT, IT HAPPENS ON ITS OWN TIMELINE OF WHEN THE INFORMATION NECESSARY FOR THOSE CHANGES IS AVAILABLE.

AND THE ANALYSIS IS DONE APPROVING THIS WITH SOME HARD TIMELINE ON, I WANT TO BE CLEAR, I'M NOT PROPOSING A, A SUNSET.

UM, THE MOTION WOULD BE TO APPROVE THE AS METHODOLOGY AND TO REVISIT THE AS METHODOLOGY IN MARCH OR APRIL.

SO THAT DOESN'T MEAN WE WOULD CHANGE IT, IT, BUT IT MEANS THAT WE WILL AFFIRMATIVELY COME BACK FOR THE POTENTIAL FOR A CHANGE IN MARCH OR APRIL.

SO, ERIC, I, I HAVE A QUESTION.

SO WHO ARE YOU ASKING TO REVISIT IT TAC? SO THAT COULD JUST BE A T ACTION ITEM.

IT COULD, BUT I HOPE ERCOT SUPPORTS IT.

IT SEEMS LIKE THERE IS SOME POTENTIAL WILLINGNESS FROM ERCOT STAFF TO HAVE THAT DISCUSSION.

NOT RECOMMENDING A SUNSET, BUT WE CAN'T PUT ANY KIND OF A SUNSET OR WE CAN'T PUT A REQUIREMENT ON REVISITING IT, REVISIT THE, THAT WE'VE GOT A REQUIREMENT TO REVISIT IT.

I KNOW BOB HAS A COMMENT.

AND THEN MAYBE WE CAN GET ERCOT TO WEIGH IN.

WE'RE, WE'RE GETTING MIXED UP WITH OUR APPLES AND ORANGES HERE.

IN MY MIND, AS TAC, WE CAN ENDORSE THE ANCILLARY SERVICES METHODOLOGY WITH THE, THE, UH, PROPOSED ACTION THAT THE BOARD DO THAT, BUT THE BOARD COULD APPROVE THIS AND LEAVE IT FOR THE ENTIRE YEAR THAT WE DON'T HAVE A SAY IN THAT ALL WE'RE DOING IS MAKING A RECOMMENDATION TO THE BOARD ON WHAT TO DO.

SO THAT'S AN ISSUE THAT I SEE RIGHT NOW.

SO IF TAC WANTS TO ACCOMPANY THE ENDORSEMENT WITH A SPECIFIC TAC ACTION, THEN I THINK WE COULD DO THAT PIECE, BUT I'M NOT SURE WE COULD, WE COULD PUT ANY KIND OF A SUNSET ON THIS.

WE COULD RECOMMEND THAT I'M

[04:15:01]

UNLESS WE JUST ASK THE BOARD TO ENDORSE THAT TOO.

SO YOU SEE WHERE I'M GOING.

THIS ISN'T AN APPROVAL, SO WE'RE KIND OF IN A, IN A STRANGE BOX RIGHT NOW.

UH, THANKS FOR THAT, BOB AND ERIC, I WAS GONNA WEIGH IN AFTER YOU MADE THE MOTION, BUT THE MOTION GOT A LITTLE COMPLICATED.

WE, OUR MOTION TO ENDORSE FAILED.

WE DO NOT NEED TO HAVE ANOTHER MOTION OR ANOTHER VOTE BECAUSE WE, WE ARE JUST, WE'RE NOT EVEN REQUIRED TO, TO ENDORSE IT.

RIGHT? WE DON'T HAVE TO APPROVE OR NOT APPROVE.

WE HAVE THE ABILITY TO ENDORSE.

SO WE COULD JUST GO FORWARD AND SAY, TECH HAS NOT ENDORSED THIS.

UM, AND, AND THEN I'LL DEFER TO ERCOT ON THE REST.

YOU KNOW, WE CERTAINLY COULD SAY WE ENDORSE IT WITH, YOU KNOW, THE, THE PLANNED ACTION ITEM.

UM, I, I KNOW WE DO HAVE RECURRING OPPORTUNITIES TO REVISIT ANCILLARY SERVICES GENERALLY WITH ERCOT STAFF POINT FORWARD, ALL I THINK THEY GIVE THE MOTION ON THE FLOOR.

RIGHT.

AND SO I'M TRYING TO BE PRODUCTIVE RATHER THAN REJECT IT.

I'M TRYING TO SUGGEST AN ALTERNATIVE.

YOU CAN MAKE THAT MOTION.

SO THE MOTION LOOKS LIKE, CORY, CAN WE GO BACK TO, TO THE MOTION THEN? YES.

ASK A QUESTION.

CANON, GO AHEAD.

SO ERIC, IF I UNDERSTOOD Y'ALL RIGHT, WHAT YOU'RE, YOU'RE TRYING TO FIND ANOTHER WAY TO ENDORSE THIS, THAT'S RIGHT.

AND IT WOULD, YOU WOULD ENDORSE IT, UH, ON THE, UH, ON THE COMMITMENT FROM ERCOT TO BRING THIS METHODOLOGY BACK UP IN APRIL OR MARCH TO THE STAKEHOLDER PROCESS? YES.

AND HOPEFULLY THAT'LL GIVE TIME FOR THE REVIEW THAT, UM, ERCOT STAFF RECOMMENDED, UH, WE, WE WOULD BE HAPPY WITH, UH, APRIL 30TH.

I, I, I, I JUST WANTED TO MAKE IT CLEAR THAT YOU WERE TRYING TO FIND A WAY TO ENDORSE, AND THAT MIGHT LOSE OTHER VOTES, BUT THO THOSE WOULD THAT'S RIGHT.

GET YOUR AFFIRMATIVE VOTE.

THAT'S RIGHT.

SO, JUST TO BE CLEAR, IT'S THAT TAC ENDORSED THE 2024 METHODOLOGY AS PRESENTED BY ERCOT ON THE COMMITMENT FROM ERCOT TO BRING THE METHODOLOGY BACK UP FOR REVIEW BY APRIL 30TH IN THE STAKEHOLDER PROCESS.

SO IF ERCOT, I MEAN, IS ERCOT COMMITTING TO THAT, OR IT'S JUST, IF THEY DON'T COMMIT TO IT, THEN YOU DON'T ENDORSE THE METHODOLOGY? IS THAT CORRECT? I MEAN, WE'RE, THERE'S A LEVEL OF TRUST HERE THAT, YOU KNOW, ERCOT SAID THAT THEY WOULD BE OPEN TO REVIEW, UH, NOT OPEN TO CHANGE.

WE JUST HAD THAT CONVERSATION A FEW MINUTES AGO.

UM, AND, UM, IT MIGHT LEAD TO A CHANGE IN METHODOLOGY, BUT IT JUST, IT'S REVISITING IT RATHER THAN ONCE ANNUALLY.

MORE THAN ONCE ANNUALLY, IF THE PROTOCOLS SHOULD CLEARLY ALLOW.

THERE'S NO SECOND RIGHT NOW.

I WANNA ASK FOR A SECOND.

IS, DID WE GET A SECOND FROM MARK DREYFUS? OKAY.

DO COREY, DO WE HAVE THE MOTION CLEAR? I AS CLEAR AS IT CAN BE? I GUESS, I GUESS MAYBE CLARIFY, ERIC, THE, THE APRIL 30TH DEADLINE, THAT'S DEADLINE TO HAVE IT HERE AT TAC, BUT SO WOULD THAT ALSO THEN MEAN THAT NITHA'S ROADSHOW TO TAKE IT TO EVERY SUBCOMMITTEE AND WORKING GROUP BELOW THAT WOULD THEN NEED TO START LIKE A WEEK AGO? OR WE'RE, WE'RE ACKNOWLEDGING THIS WOULD BE A RATHER ABBREVIATED, IF THERE IS A CHANGE, THE DISCUSSION WOULD HAPPEN HERE AT TAC, NOT WITH A ROSS ROAD SHOW AND A WMS ROAD SHOW BECAUSE OKAY, OKAY.

I UNDERSTAND.

UM, JEFF BILLOW FROM ERCOT HAS A COMMENT ON THE MIC, MIKE, OR ON THE PHONE? JEFF, ARE YOU THERE? YEAH, YEAH.

I THINK WE'RE, WE'RE OKAY WITH THIS.

WE, WE, WE CAN COMMIT TO, UH, COMING BACK.

AND, AND, AND AS I UNDERSTAND IT, I THINK IT'S JUST AROUND ECRS.

IS THAT FAIR? YES, SIR.

SO I, I, I THINK, UM, WE, WE CAN, UH, COMMIT TO THAT.

AND AGAIN, THAT, THAT MAY NOT MEAN IT, IT MAY BE THAT WE LOOK AT THAT AND, AND WE STAND BY THE, UH, ORIGINAL METHODOLOGY.

UH, OR IT COULD MEAN THAT, THAT WE AGREE THAT THERE MAY BE SOME BENEFICIAL CHANGES.

UM, YOU KNOW, I THINK WE'VE, WE'RE ALL AWARE OF THE, THE DISCUSSION ABOUT POSSIBLY CHANGING THE AS METHODOLOGY PROCESS TO INCORPORATE, UH, APPROVAL BY THE COMMISSION.

NED, DID YOU HAVE A LAST COMMENT BEFORE WE GO TO THE VOTE? I HAD A KIND OF A PRACTICAL QUESTION FROM A, JUST A TIMING AND ADMINISTRATIVE STANDPOINT.

[04:20:01]

AND I THINK FROM A PRACTICAL STANDPOINT, THAT MEANS THAT THEN THE ERCOT BOARD WOULD HAVE TO, YOU KNOW, IF, IF THAT MOVES FORWARD, THEN THE ERCOT BOARD WOULD'VE TO TAKE IT UP IN OCTOBER IN ORDER TO HAVE A FINAL APPROVED METHODOLOGY FOR THE NEXT YEAR.

SO I'M THINKING ABOUT 2025 HERE.

SO WE WOULD NEED TO HAVE THE ERCOT BOARD TAKE THAT UP IN OCTOBER OF NEXT YEAR, WHICH MEANS WE'D HAVE TO BACK UP THE, THE STAKEHOLDER REVIEW OF AS METHODOLOGY BY A COUPLE OF MONTHS, WHICH SEEMS LIKE THAT STARTS TO ENCROACH ON THIS TIMEFRAME.

SO IT, I'M, I DON'T KNOW IF I HAVE A QUESTION SO MUCH AS, AS, ARE WE JUST GOING TO BE TALKING ABOUT THE AS METHODOLOGY FOR ALL OF 2024 OR? YES.

UM, YES.

WELL, I, I MEAN, SO I THINK WE HAVE TO LAY OUT WHAT THE, UH, NEW PROCESS WILL BE LIKE, AND THAT, THAT HASN'T HAPPENED YET.

MM-HMM.

, UM, MY UNDERSTANDING OF, UM, THE FOUR GENTLEMEN OVER HERE THAT WERE CAUCUSING ON THE CONSUMER SIDE IS THAT THEY WANT TO TALK ABOUT ECRS IN PARTICULAR, AGAIN, PRIOR TO THE SUMMER.

TRADITIONALLY, WE WAIT TILL THE END OF THE SUMMER TO START DOING A LOT OF THE ANALYSIS AROUND AS METHODOLOGY.

YOUR POINT'S WELL TAKEN, THAT MAY NOT WORK GOING FORWARD, BUT, UM, I THINK WITHIN THE LIMITED SCOPE AND, AND DETAILS THAT WERE DISCUSSED, WE'D BE, WE WE'RE OKAY WITH HAVING THAT CONVERSATION IN THE MARCH APRIL TIMEFRAME.

WELL, AND I GUESS THE, THE UNDERLYING POINT OR, OR QUESTION I HAD IS IT SOUNDS LIKE WE'RE GOING TO BE DISCUSSING THE METHODOLOGY ANYHOW IN THAT SAME TIMEFRAME.

AND SO IT, IT LEAVES ME WONDERING WHAT THE MATERIAL DIFFERENCE IS BETWEEN ENDORSING THE FULL METHODOLOGY FOR 2024 TODAY AND GIVING THE MARKET THAT CERTAINTY VERSUS, YOU KNOW, A CONTINGENT ONE THAT, BECAUSE WE MIGHT CHANGE THE METHODOLOGY, UH, IN 24 RATHER THAN WAITING IN FOR 25.

UM, LET'S TAKE BRIAN AND THEN LET'S DO THIS VOTE.

I, I, IT'S A ROBERT RULES REFRESHER QUESTION FOR MYSELF.

UM, HOW MANY, LIKE, LIKE I KNOW THAT THERE'S LIKE A REQUIREMENT, YOU CAN'T HAVE THE SAME MOTION TWO TIMES IN A ROW, IS THAT CORRECT? LIKE, SO IF I VOTE AGAINST THIS AND THEN THE OLD MOTION COMES BACK, IS THAT SOMETHING THAT'S POSSIBLE? GO AHEAD, COREY.

I CAN TAKE THAT.

BRIAN, WE, WE HAD SOMETHING SIMILAR AT PRS AND WE DUG DEEP ON IT.

THE, YOUR SORT OF KNEE JERK REACTION WOULD BE, NO, THAT DOESN'T MAKE SENSE.

BUT ROBERT'S RULES DOES LEAVE THE OPTION FOR IF SUBSTANTIVE DISCUSSION HAS OCCURRED.

SO YOU VOTED NO AT 8:00 AM BECAUSE YOU HAD ONE SET OF UNDERSTANDING, AND THEN MEETING GOES ON FOR ANOTHER SIX HOURS.

YOU'VE HAD YOUR MIND CHANGED BY ALL THE ANALYSIS THAT WAS PRESENTED, WHICH PROBABLY SHOULD HAVE BEEN PRESENTED BEFORE THE FIRST VOTE.

BUT HEY, SO THAT THEN ENOUGH ARGUMENTS ARE MADE TO WHERE YOU'VE CHANGED YOUR MIND THAT YOU ARE WILLING TO TAKE A VOTE ON THE EXACT SAME MOTION AS BEFORE BECAUSE THAT AMOUNT OF TIME HAD PASSED.

IT'S NOT DEFINED.

I MEAN, OBVIOUSLY IF ONE MOTION FAILS, YOU DON'T WANNA JUMP ON 30 SECONDS LATER AND SAY, I WANNA MAKE THE SAME MOTION.

BUT IF ENOUGH DISCUSSION HAS HAPPENED TO WHERE FOLKS ARE WILLING TO VOTE DIFFERENTLY THAN THEY DID BEFORE, THEN THAT MOTION IS IN ORDER.

THAT'S, THAT'S HELPFUL TO ME.

UM, BECAUSE THAT CALPINE ALSO HAS A LOAD HAT, AND I'M TRYING TO UNDERSTAND WHAT MY OBLIGATIONS WILL BE FOR 2024 IN TERMS OF, OF HEDGING ANCILLARY SERVICE QUANTITIES, AND THE OVERHANG WITH THIS POTENTIAL REVISIT MAKES ME, I, I DON'T KNOW HOW YOU GO ABOUT PRICING THAT.

SO THAT'S A DISCUSSION THAT I WOULD LIKE TO HAVE OR THINK THROUGH.

UM, AND MAYBE IF, IF THIS VOTE DOESN'T WORK, WE CAN HAVE THAT PRIOR MOTION AGAIN, .

RIGHT.

CAN I GO OKAY.

JUST, JUST FOR, FOR WHATEVER IT'S WORTH, BRIAN, BECAUSE, AND I THINK AS JEFF TOUCHED ON IT, IT, THE METHODOLOGY WOULD JUST BE COMING UP FOR TAC REVIEW.

REVIEW DOESN'T, NECESS DOESN'T MEAN CHANGES.

AND WITHOUT THESE LAST, THIS, THIS LAST CLAUSE THAT'S BEEN TRUE FOR EVERY AS METHODOLOGY THAT YOU GUYS HAVE EVER VOTED ON, IT'S ALWAYS BEEN UP FOR REVIEW.

EVERY ROSS MEETING, YOU GO TO EVERY WMS MEETING YOU GO TO, THERE'S ALWAYS THE CHANCE THAT SOMEBODY SAYS, HEY, WE'RE, WE NEED TO MAKE A CHANGE TO THE AS METHODOLOGY.

IT ACTUALLY PHYSICALLY HAPPENED IN 2021, BUT IT'S ALWAYS THERE.

SO THIS, THESE ADDED WORDS, DON'T GUARANTEE THAT CHANGES WILL BE MADE, IT JUST ADDS THE COMFORT THAT WE'LL AT LEAST COME BACK WITH

[04:25:01]

A HOW DO THINGS LOOK.

THANK YOU, COREY.

I REALLY APPRECIATE THAT.

AND COREY, THE BOARD WOULD HAVE TO APPROVE A NEW CHANGE TO THE METHODOLOGY FOR SOMETHING.

OH, ABSOLUTELY.

THIS IS JUST FOR TAC REVIEW.

AND THEN AS WAS MENTIONED, THE COMMISSION IS EXPRESSED A DESIRE TO HAVE THEMSELVES INSERTED INTO THE APPROVAL PROCESS.

SO WE MAY BE POPPING THE HOOD ON THE OVERALL PROCESS OF WHAT DOES THE 20, THE REMAINDER OF 2024 AND 2025 LOOK LIKE.

AS THAT PROCESS CHANGES, THAT'LL BE AN NPRR THAT'LL NEED TO COME THROUGH TO IMPLEMENT WHATEVER THE NEW REVIEW PROCESS IS.

BUT FOR 2024, WE COULD RE-REVIEW IN APRIL.

BUT IN ORDER FOR THAT TO CHANGE ANYTHING THAT WOULD HAVE TO GO BACK THROUGH BOARD VOTE, CORRECT.

SO WE, WE HAVE THE MOTION AND THE SECOND TO ENDORSE THE 2024 ANCILLARY SERVICES METHODOLOGY AS RECOMMENDED BY ERCOT ON THE COMMITMENT FROM ERCOT TO BRING THE METHODOLOGY BACK UP FOR TAC REVIEW BY APRIL 30TH, WE DID GET THAT COMMITMENT FROM ERCOT.

UM, SO CORY, GO AHEAD.

ALRIGHTYY.

THANK YOU MUCH ON THAT MOTION.

WE WILL NOW BEGIN BACK UP WITH CONSUMERS WITH MARK.

YES, THANK YOU GARRETT FOR BILL.

YES, THANK YOU, ERIC.

NARAJ? YES, THANK YOU.

ONTO THE CO-OPS.

KATIE, FOR MIKE? YES.

I, I'M SORRY, KATIE, I'M UNDER THE AC.

WAS THAT A YES OR A NO? YES, YES.

EMILY.

YES, THANK YOU, COREY.

CHRISTIAN, STAY.

PLEASE COOPERATE EXCEL, CHRISTIAN, I'M SORRY, THAT WAS CHRISTIAN'S VOTE.

SORRY, LUCAS FOR CLIFF.

YOU STILL WITH US? LUCAS, WE'LL LOOP BACK TO FOR, UH, LET'S MOVE ON TO OUR INDEPENDENT GENERATORS.

BRIAN? YES, THANK YOU, CAITLIN.

NED, I'M GONNA HAVE TO ABSTAIN.

OKAY, THANK SIR.

AND LUCAS, I'VE GOT YOUR ABSTENTION IN THE CHAT.

THANK YOU, SIR.

UNDER THE IPMS. JEREMY? YES.

THANK YOU, REMI? YES, THANK YOU.

UNDER THE I REPS BILL? YES, SIR.

KEITH? YES, THANK YOU, COLIN.

YES, THANK YOU, DAVID.

AND DAVID FOR RICHARD? YES, THANK YOU.

ONTO THE MUNIS, JOSE? YES.

THANK YOU, DAVID.

YES, THANK YOU, ALICIA? YES, THANK YOU RUSSELL.

SOLE ABSTAIN.

MOTION PASSES 88% FOR 13% AGAINST SIX PRETENTIONS.

OKAY, THANKS COREY.

ALRIGHT, SO THAT, ARE THERE ANY OTHER COMMENTS ON ANCILLARY SERVICE METHODOLOGY? SO WE ARE ONTO ERCOT REPORTS AND OTHER BUSINESS.

MY INSTINCT IS TO GET THROUGH THIS TODAY.

ALL RIGHT, KEEP ROLLING.

ERICA, ARE YOU GOOD OR DO YOU NEED A BREAK, SUSIE? YOU'RE GOOD.

UM, SO OUTAGE COORDINATION, METHODOLOGY UPDATE.

[14. ERCOT Reports]

FRED, I SEE FRED COMING UP TO THE PODIUM.

OKAY, GOOD AFTERNOON.

UH, THIS IS FRED HONG WITH OPERATIONS.

SO THIS IS JUST, UH, PROVIDE A QUICK, UH, STATUS UPDATE.

SO, UH, FOR YOUR INFORMATION, THE NPR 1108 THAT REQUIRE APPROVE

[04:30:01]

REVIEW, APPROVE ALL THE RESOURCE PLAN, OUTAGE REQUEST, UH, IT WAS APPROVED IN 2022 AND, UH, IT BECAME, UH, EFFECTIVE AUGUST 16TH, UH, 2022.

AND SINCE THEN, WE START TO APPLY THE METHODOLOGY AND ALL THE OUTAGE PROCESS AS, UH, TOGETHER WITH NPRR, THERE IS A METHODOLOGY ALSO APPROVED.

UM, SO IN A METHODOLOGY, UH, THERE IS A STATEMENT, SAY WILL REVIEW THE, UH, METHODOLOGY AND, UH, THE ASSOCIATED PERFORMANCE OF R UH, FOR EVERY CALENDAR YEAR.

I THINK TODAY I'M HERE TO PROVIDE AN UPDATE TO YOU IS, UH, BECAUSE THE METHODOLOGY WAS APPROVED IN 2020, MID OF THE 2022, SO TO REVIEW THE 2022 PERFORM OUTAGE PERFORMANCE, IT WILL BE A KIND OF MISS MISTAKE.

SO OUR, OUR KIND OF PLAN IS WE WILL COME BACK IN 2024 AND, UH, KIND OF PERFORM THE WHOLE METHODOLOGY REVIEW ASSOCIATED WITH OUTAGE PERFORMANCE FOR 2023.

SO JUST KIND OF TRY TO HAVE A SA CLEAR MESSAGE AND MAKE SURE WE DON'T HAVE A CONFUSION ABOUT THE METHODOLOGY WE HAVE HERE.

SO THIS KIND OF MY QUICK UPDATE TODAY.

SO OBVIOUSLY ANY QUESTIONS? YEAH.

AM I THE ONLY ONE? I I HAVE A QUESTION, FRED.

SO YOU'RE SAYING NO CHANGE TO THE METHODOLOGY FOR NEXT YEAR? CORRECT.

IS IT, UH, I WOULD SAY FOR THE CURRENT METHODOLOGY, WE EXPECT CONTINUE TO USE IT.

SO THAT'S KIND OF MY THINKING.

AND THE TIMEFRAME IS LIKELY IS IN 2024.

THANK YOU, SETH.

ARE YOU REFERRING TO THE, UH, THE MAXIMUM OUTAGE CAPACITY CONSTRAINT? OKAY.

YES, SIR.

AND SO THERE'S, HAS THAT BEEN BINDING LATELY? HAS THAT BEEN SOMETHING THAT YOU'VE HAD TO, UH, USE TO LIMIT, UH, RESOURCE OUTAGES FOR THIS WINTER? WELL, I WOULD SAY THE M-D-R-P-O-C OVERALL METHODOLOGY, THE NUMBER AND ASSOCIATE PROTOCOL, UH, IT BECAME EFFECTIVE AUGUST LAST YEAR.

SO SINCE THEN WE JUST FOLLOWED THAT ONE.

HAVE YOU FOUND THAT IT'S, IT'S ACTUALLY LIMITING PEOPLE FROM BEING ABLE TO TAKE OUTAGES? SO, UM, FOR YOUR INFORMATION? UM, SO ALONG WITH THE NPRR, UH, ON A DAILY BASIS, UH, WE PUBLISH THE AVAILABLE AND THE COMMITTED APPROVAL TG CAPACITY TO THE, OUR MIS FOR THE FOLLOWING FIVE YEARS.

AND IT'S UPDATED TWICE PER DAY.

AND FOR THE LAST SEVEN DAYS, WE UPDATE EVERY HOUR.

SO IN A SENSE, ALL THE AVAILABLE OUTAGE CAPACITY, UH, ARE KIND OF UPDATED REGULARLY FOR EVERYONE.

AND, UH, WHAT WE DO HERE IS IF WE DO SEE, IF THEY SUBMIT THE OUTAGE, HIT LIKE THE NUMBER, UH, WE WORK WITH THE SUBMITTED ENTITY TO SEE, UH, IF LAYER IS A WAY CAN ADJUST IT LIKE ONE MOVE TO THE WINDOW WHERE WE STILL CAN SUPPORT THE OUTAGE REQUEST.

THANKS ERIC.

CAN I ASK THE SAME QUESTION OF THE GENERATOR COMMUNITY? UM, HAVE Y'ALL HAD THE EXPERIENCE THAT YOU'VE WANTED TO, FROM THIS, UH, OUTAGE CAP HAS IT, HOW HAS IT MET YOUR EXPECTATIONS? I KNOW THERE'S A LOT OF CONSTERNATION WHEN WE ESTABLISH IT, AND THIS SEEMS LIKE A GOOD TIME TO GET FEEDBACK FROM THE GENERATORS ABOUT HOW IT'S GOING.

I, I CAN, IF I MAY JUST JUMP IN THE FRONT OF THE QUEUE HERE.

I, UM, I'LL TELL YOU, IT HAS BEEN BINDING, UM, TO FRED'S POINT.

UH, YOU CAN SEE THE AVAILABLE CAPACITY AND, UH, IF YOU HAVE AN OUTAGE THAT YOU WANTED TO PUT IN, UH, AND YOU DIDN'T ASK SOON ENOUGH, YOU, YOU KNOW THAT THE ANSWER IS NO BEFORE YOU, YOU SUBMIT AN OFFER.

SO, UH, THERE'S, THERE'S A NOT A REASON TO SUBMIT A REQUEST.

IF YOU ALREADY KNOW THE ANSWER WILL BE NO.

UM, WE'VE HAD SOME STUFF THAT WE'VE HAD TO MOVE AROUND, AND THAT WHEN YOU MOVE STUFF, IT DOESN'T, IT'S NOT FREE.

IT'S NOT A FREE OPTION TO DO THAT.

UM, WE'VE GOT, UH, A LOT OF, A LOT OF CREWS THAT, YOU KNOW, HAVE, HAVE CRAFT LABOR THAT, UM, YOU NEED TO PROCURE IN ADVANCE.

AND AS YOU LOOK OUT FURTHER AND FURTHER IN TIME, THE AMOUNT OF CAPACITY THAT THAT'S AVAILABLE GETS RATCHETED DOWN.

UM, AND SO IT, IT HAS HAD SOME, UH, IT'S, IT'S IMPACTED THE

[04:35:01]

WAY WE, WE OPERATE.

AND, UM, SO FAR WE'VE BEEN ABLE TO DO THE MAINTENANCE THAT, THAT WE NEED TO DO.

UM, I DON'T KNOW THAT THAT WILL ALWAYS BE THE, UH, EXPERIENCE IN THE FUTURE.

UM, AND IT'S GONNA GET MORE AND MORE CHALLENGING AS THERE'S LESS CAPACITY AVAILABLE TO, TO, UM, DO THE KIND OF, UM, MAINTENANCE THAT, THAT YOU WANT AND HAVE TO DO TO, TO BE PREPARED FOR, YOU KNOW, A HOT SUMMER OR A COLD, COLD NIGHT.

WELL, BRIAN HIT JUST ABOUT EVERYTHING.

UH, THE ONLY THING I'LL ADD TO THAT IS MY STANDARD, UH, YOU KNOW, THIS IS THE CANARY IN THE COAL MINE FOR RESOURCE ADEQUACY.

UH, POINT, I MEAN, WHEN YOU DO START BUMPING UP AGAINST THOSE LIMITS, I MEAN, WE'VE, WE'VE HIT IT SOFTLY AND WE'VE BEEN GENERALLY ABLE TO MOVE THINGS AROUND TO MAKE SURE THAT THE NECESSARY MAINTENANCE GETS DONE.

BUT YEAH, THE FUTURE DOES NOT LOOK PROMISING WITH THIS, UH, WITH THIS METHODOLOGY.

SO, UM, WHEN, WHEN I SAY THERE'S A RESOURCE ADEQUACY CONCERN IN ERCOT, THIS IS, THIS IS WHERE I THINK WE REALLY FEEL IT, UH, MOST DIRECTLY, UH, FIRST.

I THINK, UH, THE QUEUE'S CLEAR.

WE'RE DONE WITH DISCUSSION ON THIS ITEM.

THE DATA THAT IS CONTINUES TO BE POSTED, IT, IT'S PART OF THIS ERCOT REPORTS, UH, TOPIC AND, AND ZIP FILE.

ALL RIGHT, THANK YOU.

NEXT IS, UH, DAVE MAGGIO REAL TIME PRICE CORRECTION FOR OPERATING DAY 10 22.

HI.

THANK YOU, CALIN.

CAN YOU ALL HEAR ME? WE CAN HEAR YOU.

PERFECT.

I'LL, I'LL TRY AND KEEP THIS, UM, I GUESS RELATIVELY QUICK.

I JUST HAVE A, A HANDFUL OF SLIDES AND, UH, THIS IS SPECIFICALLY RELATED TO A MARKET SUBMISSION FAILURE ISSUE THAT WE HAD PRESENTED, UH, ABOUT AT WMS AND SPECIFICALLY REENA BAD HAD PRESENTED ON IT.

SO, UH, THERE ARE A NUMBER OF DETAILS HERE, UH, BUT I'LL FOCUS MORE SPECIFICALLY ON THE IMPACTS AND SPECIFICALLY THE, UH, THE SETTLEMENT IMPACTS AND ALL THAT, UH, THAT'LL BE PLANNING TO TAKE TO THE BOARD HERE IN A COUPLE OF WEEKS.

SO, UH, FOR FOLKS WHO HAD NOT HAD A CHANCE TO LISTEN TO THE, THE PREVIOUS PRESENTATION OR ARE NOT AWARE, ON OCTOBER 22ND, UH, SUNDAY OF, UH, ABOUT A MONTH AND A HALF AGO NOW, BACK, UH, WE HAD AN ISSUE WHERE EFFECTIVELY MARKET PARTICIPANTS WERE NOT ABLE TO PUT IN MARKET SUBMISSIONS.

AND THIS IMPACTED BOTH, UH, THE REALTIME MARKET AS WELL AS THE BAY AHEAD MARKET, UH, SPECIFIC TO, UH, THE REALTIME MARKET.

UH, WHAT WE EFFECTIVELY SAW IN A, A PORTION OF THIS WINDOW WAS THAT SCED WAS NOT ABLE TO READ THREE PART OFFERS FROM AROUND 1215.

THAT 1215 SCED RUN, UH, UNTIL 1254, SO A LITTLE LATER THAT HOUR.

AND IN ADDITION TO THAT, IT WAS UNABLE TO READ CURRENT OPERATING PLANS BETWEEN ONE, UH, THE 1:00 PM UH, SCED RUN UP UNTIL THE, UH, SCED RUN THAT OCCURRED AT 1 0 9.

AND THE EFFECT OF THIS IS THAT WAS SCED WAS FAILING TO PRODUCE VALUE VALID PRICES DURING THIS WINDOW OF TIME.

UH, IT'S, IT'S PROBABLY WORTH NOTING THAT THE MARKET SUBMISSIONS ISSUE INITIALLY STARTED AT 6 36 THAT MORNING.

UH, HOWEVER, UP UNTIL AT LEAST THAT 1215 TIME PERIOD, SCED WAS ABLE TO CONTINUE USING THE EXISTING OFFER SUBMISSIONS.

SO, UH, REALLY THE, UM, THERE WAS SOME ISSUES WITH THE MARKET SUBMISSIONS AND, AND THE ABILITY TO SUBMIT THOSE.

SO SCED WAS ABLE TO OPERATE, UH, PRACTICALLY USING THE PREVIOUSLY SUBMIT OFFERS UP UNTIL THAT 1215 TIME PERIOD.

UH, AS I MENTIONED, THIS ISSUE ALSO IMPACTED THE DAY AHEAD MARKET.

THE, THE WAY THAT WAS LARGELY RESOLVED IS THE, THE MOVING OF THE DAM DEADLINES, UH, THAT WAS EXTENDED THAT DAY WITH THE DAM RUNNING LATER IN THAT DAY, AND THE RESULTS PUBLISHING AT FIVE 30 OR 5 35, I SHOULD SAY.

AND THEN AGAIN, I, I MENTIONED THERE WAS A PRESENTATION TO WMS. IF FOLKS ARE INTERESTED IN LOOKING AT THAT, THERE'S A, A HYPERLINK THERE THAT, THAT FOLKS CAN, CAN, UH, USE TO, TO EASILY ACCESS THAT PRESENTATION.

UH, THERE WERE A COUPLE OF MARKET NOTICES THAT WE HAD SENT OUT REGARDING THIS ISSUE.

FIRST WAS A, UH, MARKET NOTICE ON OCTOBER 24TH, NOTIFYING THE MARKET OF OUR INTENT TO TAKE THAT TO THE BOARD, UH, FOR THEIR REVIEW, UH, AFTER COMPLETION OF OUR IMPACT ANALYSIS.

AND AGAIN, WE'LL GO THROUGH SOME OF THOSE IMPACTS, UH, IN THE COMING SLIDES.

AND THEN IN ADDITION, UH, WE DID ANOTHER MARKET NOTICE ON NOVEMBER 3RD.

AND THE IDEA HERE WAS WE RECOGNIZED THAT THERE WAS GONNA BE A, A FAIRLY, UH, EXTENDED PERIOD OF TIME BETWEEN THE ACTUAL DAY OF THIS ISSUE, UH, AND WHEN WE WERE GOING TO POTENTIALLY SEE THAT APPROVAL BY THE BOARD.

AND SO WHAT WE WANTED TO DO WAS PROVIDE THE DATA AS QUICKLY AS POSSIBLE SO PEOPLE COULD LOOK AT THE INFORMATION AND UNDERSTAND THE IMPACTS TO THEM.

SO, UM, IF THE, IT'S

[04:40:01]

WE HAVE THE POTENTIAL PRICE CORRECTION DATA THAT INCLUDES, YOU KNOW, ALL THE SETTLEMENT POINTS, UH, ELECTRICAL BUSES, AND SO ON AND SO FORTH.

SO THAT, UH, WE, WE TRY TO POST AS EARLY AS POSSIBLE IN THE BEGINNING OF NOVEMBER.

UH, AND THAT WILL BE THE PRICE DATA THAT WE TAKE TO THE BOARD HERE IN, UH, A COUPLE OF WEEKS.

UH, NEXT SLIDE, PLEASE.

UH, THIS IS JUST LOOKING AT A TIMELINE SPECIFIC TO SCED.

PERHAPS THE ONE THING OF NOTE HERE IS THAT WE DO HAVE SOME ADDITIONAL INFORMATION AROUND THE PRICES WE WERE SEEING BOTH, UH, WHILE SCED WAS, UH, FAILING TO PRODUCE VALID RESULTS, UH, AS WELL AS, UH, WHAT WE SAW BOTH, UH, BEFORE AND IMMEDIATELY AFTER.

SO, UH, AS I MENTIONED, WE STARTED SEEING THESE ISSUES AT 1215, WHERE SCED WAS UNABLE TO PROCESS THREE PART OFFERS.

AND THE PRIMARY IMPACT OF THIS IS FOR A LARGE PORTION OF THE GENERATION FLEET.

UH, THE SCED PROCESS WAS CREATING PROXY ENERGY OFFER CURVES, AND THE WAY THE PROXIES LOOK, IF AN OFFER IS NOT SUBMITTED, WHICH IS EFFECTIVELY WHAT IT LOOKED LIKE IN THE CASE, IS TO CREATE MORE OR LESS A VERTICAL OFFER, UH, THAT TENDS TO DISPATCH THE RESOURCE AT OR RIGHT NEAR ITS CURRENT OPERATING LEVEL.

AND SO WHAT WE SAW ONCE WE STARTED CREATING THESE PROPERTIES FOR SUCH A LARGE PORTION OF THE GENERATION FLEET IS THAT PRICES ZOOMED UP, UH, QUITE A BIT.

UH, AND SO YOU'LL SEE THERE FOR THE, THE 1215 RUN, UH, AND THIS WAS FAIRLY CONSISTENT THROUGHOUT THIS ENTIRE TIME WINDOW.

THE, THE REAL TIME MARKET SYSTEM LAMBDA WENT TO SOMETHING JUST BELOW THE SYSTEM WIDE OFFER CAP.

SO PRICES WERE IN THE RANGE OF 4,992, AND IT VARIED A LITTLE BIT FROM, FROM ONE INTERVAL TO THE NEXT, BUT IT WAS, IT WAS RIGHT CLOSE TO THAT RANGE.

AND YOU CAN COMPARE THAT TO WHAT WE SAW FOR SYSTEM LAMBDA AT THE 1210 SCED RUN, WHERE IT WAS JUST OVER $23 PER MEGAWATT HOUR.

SO AGAIN, WE SAW THAT ISSUE UP UNTIL, UH, THE SCED RUN AT 1255.

AT 1255, SCED WAS ABLE TO PROCESS THE THREE PART OFFERS, AND THAT DID RESULT IN VALID SCED RUNS.

HOWEVER, THERE IS A PROCESS WHEN WE SEE A FAILURE IN SCAG, WHERE WE HOLD THE, THE LAST GOOD PRICE, UH, FOR 15 MINUTE PERIOD.

AND THIS WAS REALLY DESIGNED AROUND IF WE'VE HAD AN ISSUE WHERE HAS FAILED TO PRODUCE VALID RESULTS, THAT WE WANT SOME PERIOD OF STABILITY, UH, TO SORT OF LET THINGS SETTLE OUT BEFORE WE BEGIN USING THOSE PRICES AGAIN.

SO THIS WAS A CASE IN WHICH, UH, WE HAD THAT 15 MINUTE HOLD IN PLACE.

UH, HOWEVER, WITHIN THAT 15 MINUTE TIME PERIOD, AGAIN, WE HAD THAT ISSUE AT ONE O'CLOCK FOR BOTH THE 1:00 PM AND, AND 1 0 5 SCED RUNS WITH THOSE, THOSE FAILED TO, UH, PROCESS COPS.

AND AGAIN, THAT RESULTED IN ADDITIONAL SCED FAILURE.

AND THEN FINALLY AT THAT 1 0 9, THAT WAS WHEN SCED WAS ABLE TO BEGIN PRODUCING BOWEL RESULTS.

AND IF YOU USE THAT, UH, 15 MINUTE, UH, TIME PERIOD HOLD FROM THAT, FROM THAT FIRST GOOD RESULT THAT EFFECTIVELY, UH, PUT THE SC FAILURE FROM ALL THE WAY AT 1215 WHEN THE ISSUE FIRST STARTED UNTIL 1 24.

SO THAT, UH, 15 MINUTES PAST THAT 1 0 9 SKIED RUN.

UH, FINALLY, WE HAD, UH, A VALID SKIED RUN AT 1 25.

UH, AND LIKE WE SAW WITH THE PRICES AT 1210, UH, WITH THE PREVIOUS LAST GOOD SKIED RUN THAT SYSTEM, LAMBDA WAS IN THE, THE SAME RANGE.

IT, IT WAS ACTUALLY QUITE CLOSE AND WAS, AGAIN, JUST OVER $23 PER MEGAWATT HOUR.

IN THE STATEMENT CHARGES.

SO THAT'S JUST A, A TIMELINE.

UH, SO THIS IS LOOKING AT THE, THE ACTUAL IMPACT TO THE MARKET.

AND IF FOLKS REMEMBER FOR TAKING, UH, PRICE CORRECTIONS TO THE BOARD, WE HAVE, UH, SOME CRITERIA FOR SIGNIFICANCE.

AND YOU CAN SEE IT THERE AT THE, THE TOP OF THE PAGE, OF COURSE, WITH PRICES JUMPING TO SUCH HIGH LEVELS RELATIVE TO WHAT THEY WERE BEFORE, WE CERTAINLY ANTICIPATED THAT WE WERE GOING TO MEET THIS CRITERIA, AND THAT'S WHAT WE OBSERVED WHEN WE RAN THE ANALYSIS.

SO, UH, AS YOU CAN SEE FROM THE CRITERIA, THERE'S A REQUIREMENT BACK TO AT LEAST ONE COUNTERPARTY WAS IMPACTED BY THOSE, THOSE TWO BULLETS LISTED ABOVE.

AND WE SAW A, A, A VERY LARGE PORTION OF COUNTERPARTIES BEING THIS CRITERIA.

SO, UH, THE CRITERIA IS ONE, BUT WE, WE SAW, UH, THE MUCH MORE THAN THAT, OF COURSE, BEING THE CRITERIA IN, IN THE, IN THE HUNDREDS, AS YOU SEE THE NUMBERS HERE, UH, IN TERMS OF THE LARGEST IMPACT VALUE TO ANY PARTICULAR COUNTERPARTY, THE IMPACT WAS, UH, OVER $8 MILLION FOR THAT, UH, HOUR AND A HALF OR SO, OR A LITTLE LESS THAN AN HOUR AND A HALF.

AND THE LARGEST ABSOLUTE IMPACT IN TERMS OF PERCENT WAS 650%.

UH, WHILE NOT SPECIFIC TO THE CRITERIA IN, IN DOING THIS ANALYSIS, WE KIND OF WANT TO GET AN, AN OVERALL FEEL FOR THE IMPACT TO THE MARKET.

SO THE, THE LAST LINE HERE IS LOOKING AT THE CHANGE IN STATEMENT CHARGES DUE TO ICA.

AND THE VALUE WE SAW HERE IS A DECREASE IN THE STATEMENT CHARGES, AGAIN, DUE TO THE LOWER PRICES OF JUST OVER $62 MILLION.

AND THAT'S A, FOR, FOR WHAT IT'S WORTH A DECREASE OF JUST OVER 79% IN,

[04:45:01]

SO THAT IS THE PRESENTATION I HAVE FOR YOU ALL.

OF COURSE, OUR NEXT STEPS WILL BE TO PRESENT THIS MATERIAL TO THE RELIABILITY MARKETS COMMITTEE, UH, ON DECEMBER 18TH, I BELIEVE IT IS.

UH, AND THEN LOOKING FOR, UM, A RECOMMENDATION FROM THAT COMMITTEE AND AN APPROVAL BY THE BOARD THE NEXT DAY ON DECEMBER 19TH.

AND AGAIN, UH, IN ADDITION TO THIS PRESENTATION, WE HAVE, UH, A ZIP FILE THAT INCLUDES ALL THE, THE SPECIFIC PRICE INFORMATION THAT FOLKS MIGHT BE INTERESTED IN.

AND WITH THAT, CAITLYN, I'LL STOP AND SEE IF THERE'S ANY QUESTIONS FOR ME.

CONSULTATION WITH STAKEHOLDERS.

ANY QUESTIONS FOR DAVE? OKAY.

LOOKS LIKE WE HAVE A CLEAR QUEUE.

THANK YOU, DAVE.

NEXT UP, WE HAVE MITIGATED OFFER CAP RECOMMENDATION FOR ESRS, AND I BELIEVE RYAN KING'S HERE TO MAKE THAT PRESENTATION.

GOOD AF EXCUSE ME.

GOOD AFTERNOON, TACK.

RYAN KING, UH, WITH ERCOT.

I'M HERE TO DISCUSS A REPORT THAT, UM, WE ARE REQUIRED TO PROVIDE TO TAC BY THE END OF THIS YEAR.

UH, THE REPORT IS MEANT TO LOOK AT THE EXISTING MITIGATED OFFER CAP FRAMEWORK FOR ENERGY STORAGE RESOURCES, AND WE ARE TASKED WITH, UM, BASICALLY MAKING A DETERMINATION AS TO WHETHER TO MAKE A CHANGE TO THE CURRENT METHODOLOGY OR PROCEED WITH THE STATUS QUO.

SO, UM, I WANTED TO NOTE THAT WE HAVE, UH, SUBSTANTIVELY GONE THROUGH MOST OF THE ELEMENTS OF THIS REPORT, UM, OVER THE COURSE OF A NUMBER OF STAKEHOLDER ENGAGEMENT EVENTS, AND MOST RECENTLY AT THE WMS MEETING, UH, LAST MONTH.

SO, UH, BEING MINDFUL OF TIME, UM, I WAS PROPOSING TO KIND OF GIVE A VERY GENERAL OVERVIEW OF WHERE WE ARE AT THIS POINT, UH, SOME OF THE CONSIDERATIONS THAT, UH, WE'RE THINKING OF ON HOW TO MOVE FORWARD BEFORE GOING INTO THE RECOMMENDATION ITSELF.

BUT OF COURSE, I'M A HAPPY AND ABLE TO GO THROUGH ANY ASPECTS OF THE REPORT THAT, UH, TAC MEMBERSHIP MAY HAVE QUESTIONS ON.

SO, IN THE COURSE OF OUR DISCUSSIONS, UH, PRIMARILY AT THE CMWG, WE IDENTIFIED TWO, I WOULD CALL HIGH LEVEL OPTIONS THAT WE COULD, UH, THINK ABOUT TO INFORM A POTENTIAL, UH, ENDURING MITIGATED OFFER CAP DESIGN.

THE FIRST THAT WE LOOKED AT WAS THE DEFAULT ENERGY BID CONCEPT THAT IS USED BY THE CALIFORNIA ISO.

ESSENTIALLY WHAT THEY DO IS THEY DERIVE, UM, THEY, THEY USE A DERIVATIVE OF DAM PRICES PLUS A SCALING FACTOR, WHICH IS MEANT TO BE A PROXY OF THE OPPORTUNITY COST FOR AN ENERGY STORAGE RESOURCE.

UH, THE OTHER, UH, OPTION, AND AGAIN, THESE AREN'T NOT NECESSARILY MUTUALLY EXCLUSIVE, IS THAT WE LOOKED AT THE CONCEPT OF A MORE DYNAMIC MITIGATED OFFER CAP THAT WOULD BE SET AT JUST BELOW THE SHADOW PRICE CAP FOR A GIVEN CONSTRAINT.

AND I THINK THE, UH, THE CONCEPT BEHIND THIS IS THAT THIS WOULD ALLOW, UH, HIGHER, UH, OFFERED CAPACITY TO BE, UH, AVAILABLE OR UTILIZED BY SCED TO HELP RESOLVE TRANSMISSION CONSTRAINTS, UH, WHEN THERE ARE NO OTHER OPTIONS AVAILABLE.

SO, UH, WHERE ARE WE AT WHEN IT COMES TO THE, THE, THE STATUS? AT THIS POINT? I THINK WE HAVE IDENTIFIED SOME OPTIONS.

UM, WE KNOW THAT, UH, FUNDAMENTALLY WE DO NEED TO COME UP WITH AN ENDURING DESIGN.

MITIGATION IS FUNDAMENTAL TO GOOD MARKET DESIGN.

AND AT THE SAME TIME, WE KNOW THAT THERE'S GOING TO BE AN INCREASE IN THE AMOUNT OF STORAGE THAT'S ON THE SYSTEM.

AND AS A RESULT OF THAT, THIS RESOURCE IS GOING TO BE INCREASINGLY RELIED UPON NOT JUST TO PROVIDE ANCILLARY SERVICES, BUT TO ACTUALLY PROVIDE ENERGY AND TO HELP RESOLVE CONGESTION AT THE SAME TIME.

UH, WE DO WANNA MAKE SURE THAT WE GET THIS RIGHT, UH, SIMPLY BECAUSE, UM, THERE ARE A LOT OF IMPLICATIONS IF WE COME UP WITH A, UM, MOC DESIGN THAT THAT DOESN'T GET IT RIGHT.

UM, AND THOSE GO BEYOND JUST ISSUES RELATED TO, UH, EFFICIENCY OR FAIRNESS, ALTHOUGH THOSE ARE ALSO VERY IMPORTANT CONCERNS.

UM, BUT THERE'S ALSO, UH, POTENTIAL FOR NEGATIVE OPERATIONAL CONCERNS.

THAT IS, IF WE COME UP WITH A, A MITIGATION, UH, PROPOSAL OR DESIGN THAT ENDS UP, UM, CALLING ON AN ENERGY STORAGE RESOURCE EARLIER IN THE DAY SO THAT IT'S, IT'S, UH, ENERGY IS NOT AVAILABLE LATER IN THE DAY WHEN IT WAS POTENTIALLY MORE CRITICAL OR MORE VALUABLE, THEN WE'VE SORT OF SOLVED ONE PROBLEM, BUT CREATED A NEW ONE.

SO, UH, WE WANNA MAKE SURE THAT WE PROCEED CAREFULLY AND THOUGHTFULLY, UH, THAT WE THINK THROUGH ALL THE IMPLICATIONS OF THIS BEFORE WE COME UP WITH THAT ENDURING DESIGN.

SO WITH THAT, I'LL KIND OF HIGHLIGHT THE, THE PROPOSAL THAT WE HAVE, THE RECOMMENDATION THAT'S, UH, GONE THROUGH

[04:50:01]

AND THEN OF COURSE, I'M HAPPY TO GO INTO THE, ANY ASPECTS OF THE REPORT OR ANSWER ANY QUESTIONS.

SO OUR RECOMMENDATION TO TAC IS THAT ERCOT AND STAKEHOLDERS, UH, ARE MAKING A RECOMMENDATION THAT NO CHANGE BE MADE TO THE EXISTING MITIGATED OFFER CAP METHODOLOGY FOR ESRS AT THIS TIME, BUT THAT ERCOT AND STAKEHOLDERS WILL CONTINUE TO MONITOR DEVELOPMENTS.

AND OUR COMMITMENT IS TO WORK TOGETHER TO DEVELOP A FAIR, EFFECTIVE, AND ENDURING MOC FRAMEWORK.

AND OUR, WE ARE HOPING TO PROVIDE ANOTHER REPORT, OR RATHER WE'RE WE'LL COMMIT TO PROVIDE ANOTHER REPORT AND RECOMMENDATION TO TAC UH, NO LATER THAN DECEMBER 31ST, 2024.

AND WE PROPOSE DOING THAT THROUGH REGULAR, UH, CONSULTATION VIA THE CMWG.

SO MAYBE WITH THAT, I WILL PAUSE TO SEE IF THERE ARE ANY, UH, QUESTIONS.

YEAH, I JUST WANTED TO SAY I'M FINE WITH THIS.

I THINK WE HEARD FROM, UH, DR. PATTON THAT THERE WERE A LOT OF ESRS WITH OFFERS AT THE CAP, SO I'M A LITTLE BIT CONCERNED ABOUT THAT.

OF COURSE, THAT COULD BE A DIFFERENT BALANCING AREA WIDE ISSUE VERSUS A LOCAL CONSTRAINT ISSUE.

BUT THE PRESENCE OF THAT AND THE INTERACTION OF THAT POTENTIALLY WITH LOCAL CONSTRAINTS HAS ME A BIT CONCERNED.

BUT I, I'M OKAY WITH THIS FOR NOW, BUT I, I DO LIKE THAT YOU HAVE ON HERE THAT WE'LL CONTINUE TO LOOK AT IT.

YEAH, THANK YOU FOR PUTTING THIS TOGETHER.

AND I THINK ONE OF THE THINGS WE FOUND OUT AS GOING THROUGH THIS EXERCISE IS HOW ACTUALLY DIFFICULT IT IS TO TRY TO SET, UH, A CAP FOR ESRS.

'CAUSE THE, ESPECIALLY THE LOST OPPORTUNITY, THAT'S A MOVING TARGET ALL THE TIME.

SO I, I THINK THIS IS A GOOD WAY TO GO FOR NOW.

I, I, I THINK IT'S GOOD THAT WE CONTINUE TO LOOK AT THIS, AND I LIKE YOUR WORDS, FAIR, EFFECTIVE, AND ENDURING.

I MEAN, JUST, YOU KNOW, TO GO OFF WHAT SETH WAS TALKING ABOUT, JUST AN OFFER AT THE CAP DOESN'T MEAN THAT'S BAD.

YOU KNOW, IT DOES HAVE CONSEQUENCES, UH, TO, YOU KNOW, FOR CONGESTION IN THAT, BUT WE DON'T WANT TO TURN AROUND AND DO, LIKE YOU SAID, IS GO AND DISPATCH SOMETHING, UH, YOU KNOW, AN ESR AT A LOSS, UH, BECAUSE WE'VE CAPPED IT, AND THEN WE NEED IT LATER ON TO WHERE IT WOULD'VE BEEN ECONOMIC TO DO THAT FOR THE STORAGE FACILITY.

AND THEY, THEY'RE NOT THERE TO DO IT.

SO THAT'S, I THINK THIS IS A GOOD PATH THAT'S PARTICULARLY IMPORTANT HERE, BECAUSE IN KAISA WHERE THEY HAVE AN OPPORTUNITY COST METHODOLOGY, THEY ALSO HAVE BIG COST RECOVERY ACROSS THEIR OPTIMIZATION HORIZON, WHICH LOOKS OUT THE WHOLE DAY IN REAL TIME.

SO IF THERE IS SOMETHING THAT HAPPENS AS A RESULT OF THE OPPORTUNITY COST NOT BEING RIGHT, THERE'S A COST RECOVERY MECHANISM THERE THAT WE DON'T HAVE.

MM-HMM.

SO I AGREE.

WE HAVE TO BE VERY DELICATE.

AND THE PROBLEM WITH THAT IS RETAIL CAN'T HEDGE THAT.

YOU KNOW, THAT'S JUST A PASS THROUGH.

AND ANYTIME YOU SAY THAT, YOU KNOW, THE GUYS OVER THERE, THEIR HAIR CATCHES ON FIRE.

ANY OTHER QUESTIONS OR COMMENTS FOR RYAN? OKAY.

NEXT WE HAVE THE VOL STUDY UPDATE.

I THINK MATT ARTHUR IS HERE TO PRESENT THAT.

UH, GOOD AFTERNOON, MATT ARTHUR FOR ERCOT.

UM, I'LL TRY TO KEEP THIS, UH, RELATIVELY BRIEF.

UM, WE HAVE THE VALUE OF LOSS LOAD STUDY THAT IS, UH, COMING UP.

LEMME SEE IF I CAN ADVANCE.

THIS MIGHT BE YOUR BEST.

OH, I SEE.

AT THE SAME QUESTIONS AROUND VALUE OF LOST LOAD.

UM, SO THE VALUE OF LOST LOAD STUDY IS IN, UH, IS SOMETHING THAT THE COMMISSION HAS ASKED US TO LOOK INTO FOR THE ERCOT REGION.

UH, THIS WILL BE IN SUPPORT OF THE, UH, COMMISSION'S UPCOMING RELIABILITY STANDARD AMONG, UM, OTHER, OTHER, UH, VALUES THAT THE COMMISSION INTENDS TO USE IT FOR.

UM, JUST PROVIDING KIND OF A BRIEF OVERVIEW OF WHERE, WHERE WE'RE AT TODAY AND KIND OF, UH, UH, SOME OF THE, UM, REQUESTS WE MIGHT HAVE FOR, UH, THE MARKET TO SUPPORT THIS.

UM, SO KIND OF KEY TAKEAWAYS HERE.

UM, ERCOT HAS ENGAGED THE BRATTLE GROUP, UH, TO PERFORM, UH, THIS VALUE OF LOSS LOAD STUDY, UM, IN, UH, COORDINATION WITH THEIR SUBCONTRACTOR PLAN BEYOND, WHICH IS A, UM, UH, AN ENTITY WITH EXPERTISE IN THE SURVEY ADMINISTRATION SPACE.

UM, ALSO KIND OF A KEY FACTOR IN THIS, THE LAWRENCE BERKELEY NATIONAL LABS, LBNL IS PERFORMING ON A NATIONWIDE BASIS RIGHT NOW, AN UPDATE TO THEIR ICE CALCULATOR, THE INTERRUPTION CALCULATION ESTIMATE TOOL, UM, WHICH IN MANY WAYS, UH, IS, IS, UH, LOOKING

[04:55:01]

UM, AND SO THAT, UH, UH, INITIATIVE, THE LBNL ICE CALCULATOR 2.0 INITIATIVE HAS BEEN ONGOING SINCE LAST SUMMER, SUMMER OF 2022.

AND, UH, THEY DEVELOPED SOME, UH, VERY, UH, GOOD, UH, SURVEYS TO, TO PERFORM FOR CUSTOMER SURVEYS, UM, THAT, UH, ERCOT AND, UH, IS RECOMMENDING THAT WE USE FOR THE VOL, UM, INITIATIVE HERE IN THE ERCOT REGION.

UM, AND SO, UH, OUR PLAN IS BY THE END OF THE WEEK TO, UM, FILE THAT, UH, VOL SURVEY PLAN, UM, FOR THE COMMISSION'S, UH, DISCUSSION AT THE, UH, DECEMBER 14TH, UH, OPEN MEETING.

UM, I'M GONNA SKIP PAST THIS HERE FOR A SECOND.

UM, SO THE THREE KIND OF KEY PIECES OF THE VOL STUDY ARE A LITERATURE REVIEW DEVELOPMENT OF AN INTERIM VOL VALUE AND, UH, CUSTOMER SURVEY THAT I WAS JUST MENTIONING.

THE LITERATURE REVIEW AND THE DEVELOPMENT OF THE INTERIM VOL VALUE WILL BE, UM, FILED WITH THE COMMISSION, UH, THE WEEK PRIOR TO THE HOLIDAYS.

UM, AND, UH, THE CUSTOMER SURVEY, UM, UH, UH, LOGISTICS ARE UNDERWAY AS WE SPEAK.

I ALREADY MENTIONED THE ICE CALCULATOR 2.0.

UM, SO, UH, PROBABLY THE MOST COMPLEX PIECE OF THIS IS THE, IS THE SURVEY.

UM, YOU CAN SEE HERE, UM, THAT THERE ARE THREE FORMS FOR THAT SURVEY.

THE, UH, WE'LL BE SURVEYING RESIDENTIAL CUSTOMERS, UH, SMALL AND MEDIUM COMMERCIAL CUSTOMERS, AND LARGE COMMERCIAL AND INDUSTRIAL CUSTOMERS.

UM, THESE ARE, UH, USING, AS I MENTIONED BEFORE, THE SURVEYS THAT THE LABS HAVE, UM, UH, DEVELOPED FOR THE ICE CALCULATOR, UH, INITIATIVE.

UM, UH, BRATTLE HAS PROVIDED US SOME KIND OF TENTATIVE, UH, NUMBERS OF, OF CONTACTS AND THE AMOUNT OF RESPONSES THAT WE WOULD NEED TO GET IN ORDER TO ACHIEVE A STATISTICALLY SIGNIFICANT, UM, RESPONSE.

THOSE WERE DEVELOPED BASED ON THEIR PRELIMINARY, UM, UH, LITERATURE REVIEW.

SO THOSE NUMBERS MAY CHANGE, BUT I THINK THE IMPORTANT THING TO NOTE IS JUST THAT IT'S NOT A, IT'S NOT A HUGE NUMBER COMPARED TO THE NUMBER OF, UH, RETAIL CUSTOMERS IN THE ERCOT REGION.

SO, UM, UM, UH, HOPEFULLY THAT WILL HELP HELP WITH THE LIFT IN THIS.

UM, THE, THE PLAN IS TO, UH, UH, BEGIN DISTRIBUTION OF THOSE, UH, SURVEYS IN FEBRUARY OF 2024, OF COURSE, PENDING ANY, UM, FEEDBACK THAT THE COMMISSION, UH, MAY HAVE IN THE NEXT, UH, COUPLE OF OPEN MEETINGS.

UM, AND, UH, KIND OF KEY TAKEAWAY AT THE BOTTOM, STAKEHOLDER SUPPORT WILL BE KEY TO ENCOURAGING, UM, ROBUST CUSTOMER PARTICIPATION.

AND SO, UM, I'LL GET INTO IN JUST A MOMENT KIND OF THE WAYS THAT WE'RE LOOKING AT DISTRIBUTING THE SURVEY.

BUT, UM, I WOULD ENCOURAGE ALL OF THE, THE STAKEHOLDERS TO, TO THE EXTENT THAT YOU INTERACT, UH, ARE IN THE SEGMENT OF THE MARKET THAT INTERACTS WITH, UH, RETAIL CUSTOMERS TO, TO ENCOURAGE THEM TO, UH, RESPOND TO THE SURVEY.

I THINK THAT THAT WILL HELP TO MAKE SURE THAT WE GET, UM, ACCURATE, UH, VALUES THAT WILL BE, YOU KNOW, UH, UH, UH, IMPORTANT TO HOW WE, UM, VALUE LOSS LOAD IN, IN THE ERCOT REGION.

UM, SO THE THREE, UH, WAYS THAT WE'RE LOOKING AT, UM, DISTRIBUTING THE SURVEY, UH, THIS IS PROBABLY THE, THE PIECE THAT WE WANTED TO MAKE SURE TO PREVIEW TO, TO Y'ALL MOST, UH, IS EITHER FOR, UM, STAKEHOLDERS, MEANING PREDOMINANTLY, UM, REPS, UH, TDU AND, AND NOES, UH, TO PROVIDE, UM, CUSTOMER CONTACT INFORMATION TO ERCOT TO PERFORM THE SURVEY.

UM, THAT RAISES CERTAIN CONCERNS WITH THE TRANSFER OF PROTECTED CUSTOMER INFORMATION THAT WE WOULD OF COURSE, BE LOOKING TO AVOID.

THE SECOND IS TO, UH, UH, HAVE, UH, STAKEHOLDERS ACTUALLY DISTRIBUTE THE SURVEY, UH, THEMSELVES USING THEIR OWN CUSTOMER INFORMATION SO THAT WE DIDN'T NEED TO TRANSFER THAT TO ERCOT.

UM, OF COURSE, UH, THE DRAWBACK THERE IS THAT THAT WOULD BE PROBABLY QUITE A, UH, A COMMITMENT, UH, IN TERMS OF, UH, MANPOWER AND OTHER RESOURCES.

UM, SO WHAT WE'RE CALLING THE HYBRID OPTION IS WHAT ERCOT RECOMMENDED TO THE COMMISSION, UH, AT LAST WEEK'S OPEN MEETING.

UM, AND, UH, WE WILL BE PLANNING TO RECOMMEND IN THE VOL SURVEY PLAN COMING UP, UH, BY THE END OF THE WEEK, WHICH IS TO USE, UM, CUSTOMER BILLING CONTACT INFORMATION THAT ERCOT HAS, UM, TO, TO DISTRIBUTE THE SURVEY IN COMPETITIVE AREAS OF THE ERCOT REGION.

UM, AND, UH, PARTNER WITH, UM, A LIMITED AMOUNT OF, OF NOE'S IF, IF THEY'RE, UM, ABLE TO DO SO, UH, TO DISTRIBUTE, UH, IN CERTAIN NOE TERRITORIES TO MAKE SURE THAT WE CAN HAVE THAT, UM, COVERED AS WELL.

UM, I WOULD SAY WE'VE HAD SOME, UH, REALLY GREAT, UH, CONVERSATIONS WITH THE STAKEHOLDERS OVER THE LAST COUPLE WEEKS AND, AND WE REALLY APPRECIATE, UM, UM, THE MARKET'S FEEDBACK AND, AND, UH, AND THE, UH, THE, THE GENERAL, UH, LEVEL OF SUPPORT THAT WE'VE, WE'VE HEARD FROM.

UM, WE'RE STILL, UH, WORKING THROUGH SOME OF THOSE CONVERSATIONS.

SO, UH, HOPEFULLY WE'LL BE GETTING KIND OF TO A,

[05:00:01]

A MORE CONCRETE PLACE BY THE END OF THE WEEK HERE.

BUT, UH, UM, WE'LL BE INTERESTED IN, IN CONTINUING THAT.

UM, FOR THOSE NOT FAMILIAR WITH CUSTOMER BILLING CONTACT INFORMATION, UM, THAT'S A FORM OF INFORMATION THAT COMPETITIVE RETAILERS SUBMIT ON A MONTHLY BASIS TO ERCOT.

UM, FOR PURPOSES OF FACILITATING MASS TRANSITIONS WHEN A COMPETITIVE RETAILER EXITS THE MARKET, UM, WE DO BELIEVE THAT THERE'S LEEWAY IN THE COMMISSION'S RULE AND IN THE, UM, UH, THE PROTOCOLS THAT FLUSH IT OUT FOR ERCOT TO USE, UM, THAT CBCI DATA TO, TO PUSH THE SURVEY OUT, UM, THAT, UH, THAT LEEWAY WOULD, WOULD NOT BE THE SAME FOR, UM, POLARS THAT HAD BEEN PROVIDED THAT INFORMATION.

UM, SO REALLY AT THE END OF THE DAY, THIS IS A, THIS IS EQUIVALENT TO OPTION ONE, EXCEPT THAT WE WOULD BE USING THIS, UM, PROCESS THAT, UH, EXISTS TODAY IN ORDER FOR ERCOT TO, UM, TO USE THAT CUSTOMER CONTACT INFORMATION WITHOUT HAVING TO KIND GO THROUGH A SEPARATE, UM, AND POTENTIALLY LENGTHY PROCESS FOR THAT.

AND WOULD ALSO KIND OF PUT THE ONUS ON, ON ERCOT AND, AND BRATTLE AND PLAN BEYOND TO PUSH OUT THE SURVEY WITHOUT ASKING, UH, THE, THE COMPETITIVE RETAILERS TO DO SO.

CAN I ASK A QUESTION? UH, CERTAINLY.

UM, SO I THINK THAT INFORMATION WAS PROVIDED FOR THE PROCESS OF THE POLAR PROCESS EXCLUSIVELY.

UM, AND WHILE THERE MIGHT BE A PROHIBITION, UM, I, I, IS ERCOT GOING TO BE THE ONLY ONE THAT HOLDS THAT DATA FOR THE CBCI OR WILL, WILL YOU GIVE, BE GIVING IT TO A VENDOR FOR MAILING? WHAT'S THE PROCESS THERE? UH, GOOD QUESTION.

SO, UM, WE WOULD BE, ERCOT WOULD BE WORKING WITH, UM, BRATTLE AND PLAN BEYOND TO USE THAT INFORMATION TO SEND IT OUT.

SO AT THE END OF THE DAY, YES, WE WOULD, UH, BE PROVIDING THE CBCI TO BRATTLE AND PLAN BEYOND, UM, TO, TO DISTRIBUTE THE SURVEY UNDER THAT SCENARIO.

SO, SO HOW DOES THAT AVOID THE CONCERN YOU RAISED ABOUT, UM, SHARING PROTECTED INFORMATION? UM, GOOD QUESTION.

SO UNDER THE, UH, ERCOT PROTOCOLS, I THINK IT'S SECTION 1.3 THAT DESIGNATES, YOU KNOW, WHAT, UH, INFORMATION IS CONFIDENTIAL AND HOW THAT SHOULD BE TREATED.

AND I CAN'T RECALL THE SPECIFIC SUBSECTION OF 1.31, BUT THERE'S A LETTER UNDERNEATH THERE THAT ALLOWS, UM, ERCOT TO, UH, SHARE PROTECTED CUSTOMER INFORMATION OR ANY CONFIDENTIAL INFORMATION WITH A, WITH A VENDOR.

UM, AND SO IN THIS CASE, BRATTLE AND PLAN BEYOND ARE VENDORS OF ERCOT AND HAVE, UM, EXECUTED CONFIDENTIALITY AGREEMENTS WITH ERCOT TO TREAT THAT INFORMATION CONFIDENTIALLY.

AND THEY WOULD NOT BE RETAINING ANY OF THAT, UM, CUSTOMER CONTACT INFORMATION IN THE, UM, MEDIUM TO LONG TERM.

THEY WOULD SOLELY BE USING IT FOR THIS LIMITED PURPOSE OF, UH, DISTRIBUTING THE SURVEY AND THEN WOULD NOT RETAIN IT.

UH, LET'S SEE WHAT ELSE I HAVE FOR YOU HERE.

UM, JUST KIND OF ALONG THE LINES OF DATA CON CONFIDENTIALITY, I THINK IT'S IMPORTANT TO POINT OUT THAT THE INFORMATION THAT'S BEING COLLECTED BY THE SURVEYS, UH, IS NOT, UM, PROTECTED CUSTOMER INFORMATION.

WE'RE NOT ASKING FOR, UM, ANYTHING THAT WOULD MAKE THAT WOULD, UH, IDENTIFY ANY PARTICULAR CUSTOMERS.

UM, THOSE ARE SCENARIO BASED SURVEYS THAT, UH, ASK THE CUSTOMERS TO THINK THROUGH HOW THEY WOULD, UM, VALUE, UM, RELIABILITY IN CERTAIN, UM, CIRCUMSTANCES.

YOU KNOW, WEEKDAY WEEKEND, UH, MORNING, EVENING, UM, SUMMER, WINTER, UM, FOR VARYING LENGTHS OF, UH, OF A DURATION OF, OF AN OUTAGE.

UM, SO, UH, SO THAT INFORMATION WILL NOT ACTUALLY BE, UH, PROTECTED CUSTOMER INFORMATION.

AND SO, UM, JUST KIND OF NEXT STEPS, UH, WE WILL BE PRESENTING TO RMS TOMORROW TO ANSWER, UM, MORE QUESTIONS, UH, FROM THE RETAILERS.

UH, BY THE END OF THE WEEK, WE'RE HOPING TO FILE THE VOL SURVEY PLAN FOR THE COMMISSION'S CONSIDERATION, AND THEN, UM, AT THE DECEMBER 14TH OPEN MEETING, HOPING TO GET, UM, COMMISSIONER FEEDBACK ON, UH, ON THAT PLAN OR, OR PERHAPS AT THE JANUARY OPEN MEETING.

SO, UM, KIND OF OUR REQUEST, WHICH I'LL PARTICULARLY MAKE TO RMS IS THAT, UH, COMPETITIVE RETAILERS, UH, WHEN THEY SUBMIT CBCI, UH, IT'S MANDATORY TO INCLUDE A BILLING ADDRESS, BUT IT'S OPTIONAL TO INCLUDE AN EMAIL ADDRESS.

WE'RE ASKING THAT, UH, THE COMPETITIVE RETAILERS INCLUDE AN EMAIL ADDRESS TO THE EXTENT THAT THEY, UH, HAVE ONE FOR THAT CUSTOMER IN THE JANUARY AND FEBRUARY CBCI SUBMISSIONS.

UM, UH, AND THAT WILL HELP TO FACILITATE, UH, THE DISTRIBUTION OF, UH, OF THE SURVEY.

UM, SO, UH, SO I THINK THAT'S ALL OF THE PRESENTATION I HAVE FOR Y'ALL TODAY.

UH, HAPPY TO ANSWER ANY QUESTIONS.

AND, UM, I APPRECIATE YOUR RECOGNIZING SOME OF THE CONSTRAINTS THAT YOU HAVE AND NEEDLES THAT YOU HAVE TO THREAD IN ORDER TO, UH, TO EFFECTUATE IT.

UH, WE'VE GOT NED IN THE QUEUE.

THANK YOU, CAITLIN, AND THANKS MATT FOR COMING TO SHARE THIS WITH US TODAY.

I KNOW YOU'VE BEEN WORKING REALLY HARD ON, ON, UH, WORKING THROUGH A LOT OF THE, THE, THE DIFFERENT NUANCES OF THIS,

[05:05:01]

SO, UM, WANTED TO GIVE, GIVE YOU A, A KUDOS JUST FOR, FOR WORKING THROUGH THAT PROCESS AND, AND DOING SO THOUGHTFULLY.

UM, THE TWO QUESTIONS THAT I HAD FOR YOU, UM, I'LL START WITH THE, THE FIRST ONE 'CAUSE I THINK IT'S A SIMPLE ONE.

AND, AND ARE THERE ANY PLANS TO HAVE, UM, THE VENDORS ALSO SUPPLEMENT WITH SOME PHYSICALLY MAILED, UH, QUESTIONNAIRES IN ADDITION TO EMAIL? SINCE NOT EVERY CUSTOMER MAY HAVE A, AN EMAIL ADDRESS? UH, YES, THAT'S CORRECT.

I THINK, UM, THE, UH, UH, WE'RE LOOKING AT EMAILS AS BEING THE PRIMARY WAY TO REACH CUSTOMERS, BUT, UM, NOT THE ONLY MEANS.

AND, UM, UH, ERCOT HAS THE CAPABILITY, AS I UNDERSTAND IT, WITH HARDWARE AND SOFTWARE TO SEND OUT PHYSICAL MAIL USING THAT CBCI.

AND SO, UM, I THINK, UH, THERE ARE A LOT OF INSTANCES WHERE CUSTOMERS DON'T HAVE EMAIL ADDRESSES, YOU KNOW, DIFFERENT, DIFFERENT FOLKS OR BUSINESSES ARE IN DIFFERENT SITUATIONS WITH THAT.

SOMETIMES THAT'S JUST NOT THE EASIEST WAY TO GET IN TOUCH WITH A COMMERCIAL CUSTOMER, I THINK.

UM, SO, UH, SO YES, WE, WE WOULD BE USING, LOOKING TO USE BOTH, BUT PREDOMINANTLY EMAILS.

THAT, THAT'S, THAT MAKES PERFECT SENSE, AND I APPRECIATE THAT CLARIFICATION.

AND YOU KNOW, THE, THERE'S A DEGREE OF CERTAINTY ON, YOU KNOW, HOW, HOW ACCURATE AN EMAIL ADDRESS IS THAT YOU MAY HAVE FOR A CUSTOMER.

I KNOW, I KNOW MY, ON MY IPHONE, RIGHT? THEY, THEY OFFER TO, UH, WHENEVER I SIGN UP FOR SOMETHING TO HIDE YOUR EMAIL FROM WHOEVER YOU'RE SENDING IT TO.

SO, UM, I THINK HAVING THAT, THAT PHYSICAL BACKSTOP IS IMPORTANT IN GETTING A, A, A FULL SURVEY.

AND, UH, YOU KNOW, FOR SOMETHING LIKE THIS, IT'S REALLY IMPORTANT TO HAVE, YOU KNOW, A GOOD ACCURATE REPRESENTATIVE ESTIMATE.

UM, ALONG THOSE LINES, THIS IS QUESTION TWO, UH, BECAUSE WE, WE DON'T KNOW WHAT'S IN THE, THE SURVEY QUESTIONS YET, BUT IT, I'M CURIOUS IF, UH, YOU CAN COMMENT ON WHETHER THAT WILL ELICIT ANY INFORMATION FROM CONS CUSTOMERS, UH, LARGE OR SMALL, THAT HAVE INVESTED IN, UH, BACKUP POWER SOURCES SINCE THAT SEEMS LIKE, YOU KNOW, THAT'S, THOSE ARE CUSTOMERS WHO HAVE, YOU KNOW, THE AXIOM OF REVEALED PREFERENCES HAS, HAS COME TO COME TO PLAY, AND THEY HAVE AT LEAST SHOWN WHAT THEIR MINIMUM VALUE IS FOR LOST LOAD.

IT COULD BE HIGHER THAN WHAT THEY SPEND, BUT YOU KNOW, AT THE VERY LEAST, THE COST OF THE SYSTEM IS REPRESENTATIVE THAT, UM, YOU KNOW, THEIR, THEIR VALUE OF LOST LOAD IS HIGHER THAN THAT COST.

UH, YES.

UM, SO THE SURVEYS DO ASK ABOUT WHETHER OR NOT A CUSTOMER HAS BACKUP GENERATION OR, UM, POWER CONDITIONING AS WELL, I BELIEVE.

UM, AND THAT'S DEFINITELY SOMETHING THAT'S OF INTEREST, BRIAN.

WE JUST SAW A PRESENTATION THAT THE VALUE OF LOST LOAD IN MISO IS $25,000.

DO YOU KNOW HOW THEY DETERMINED THAT VALUE? IS THAT BRATTLE DOING A SIMILAR STUDY? IS THERE LESSONS LEARNED WE CAN APPLY THERE TO HERE? UH, THAT'S A GOOD QUESTION.

I DON'T KNOW HOW THEY CAME TO THAT VALUE.

UM, THAT MAY BE SOMETHING THAT, UH, BRAD IS LOOKING AT AS PART OF ITS LITERATURE REVIEW, ALTHOUGH IF IT JUST CONCLUDED AS IT SOUNDS LIKE IT DID, THEN IT MIGHT NOT BE NECESSARILY INCLUDED IN THAT LITERATURE REVIEW.

BUT I THINK THAT THAT'S, THAT'S AN IMPORTANT, UM, UM, I PERSONALLY WASN'T AWARE OF THAT BEFORE, SO THAT SOUNDS LIKE A VERY IMPORTANT THING TO TAKE IN MIND.

AND I'LL, I'LL BRING THAT BACK TO THE TEAM.

WE'RE AT SETH.

UH, JUST A QUESTION IN GENERAL, HOW WILL THIS BE APPLIED? SO WE HAVE A VOL VALUE, IT'S DIFFERENT THAN THE VOL WE HAVE NOW, SO WHAT'S NEXT? UM, I THINK THAT'S TO BE DETERMINED.

UH, OF COURSE, UH, I THINK THAT THE, THE VOL IS, UM, USED IN CERTAIN, UM, ERCOT, UH, PROTOCOLS.

SO THIS COULD, UM, I DON'T KNOW THAT THIS, WHATEVER VALUE COMES OUT OF THIS SURVEY WILL NECESSARILY BE ADOPTED, YOU KNOW, IPSO FACTO INTO USE IN THOSE PROTOCOLS.

BUT, UM, IT WILL BE, UH, I THINK INFORMATIVE, UH, AND, AND WE WILL BASICALLY PLAN TO USE IT AS THE COMMISSION WOULD PREFER FOR IT TO BE USED.

SO IT'S KIND OF UP TO THE COMMISSION HOW IT'LL BE USED.

MM-HMM, , I MEAN, IT, IT JUST SEEMS LIKE IT COULD BE USED IN YARD ALREADY C IT COULD BE USED IN A CONGESTION COST TEST IN THE PLANNING REALM.

UM, I'LL BE CURIOUS TO SEE HOW THAT, HOW THAT ALL FALLS OUT.

REPS WOULD BE CONDUCTING THE SURVEY DIRECTLY, WHICH IS NOT SOMETHING WE SUPPORT.

YEAH, I THINK, I THINK IT'LL BE HUGELY INFORMATIVE.

I MEAN, I, TO MY KNOWLEDGE, NO SURVEY HAS BEEN DONE FOR THE ERCOT REGION TO DATE.

SO, UM, IT'S A CHALLENGING THING TO, UH, TO PULL OFF.

I, AND I THINK THAT'S PART OF THE REASON WHY.

UM, BUT, UH, UM, BUT YEAH, IT COULD BE USED IN A NUMBER OF WAYS.

BUT BILL BARNES, HEY, MATT, JUST, UH, WANNA PROVIDE SOME FEEDBACK.

UM, WE LIKE THE ALTERNATIVE TO USE THE CBCI FILE VERSUS SOME OF THE OTHER OPTIONS WHERE

[05:10:01]

UM, BUT I THINK WE WOULD ALL BE MORE COMFORTABLE FROM AN ADMINISTRATIVE PERSPECTIVE, UM, IF THERE WAS SOME TYPE OF, UH, DIRECTIVE OR ORDER FROM THE COMMISSION CONFIRMING, UH, ERCO T'S ABILITY TO USE THE CBCI INFORMATION FOR THIS PURPOSE.

AS YOU HAVE ALLUDED TO IN YOUR SLIDES, THE CBCI DATA WAS, IS SPECIFIC TO THE POLAR PROCESS.

SO IF WE'RE GOING TO USE THE COLLECTIVE, WE WE'RE GONNA USE THIS INFORMATION FOR PURPOSES OTHER THAN THE POLAR PROCESS TO MAKE SURE THAT IT IS CLEAN FROM THE PERSPECTIVE OF NOT DISCLOSING CUSTOMER, UM, DATA, WHICH IS, YOU KNOW, THE CONCERN THAT WE HAVE TO MAKE SURE THAT THAT PROCESS IS COMPLETELY CLEAN.

UM, IT WOULD BE ACCOMPANIED BY A, A COMMISSION ORDER OR A DIRECTIVE, OR JUST A, AN INTERPRETATION CONFIRMING THAT THIS IS NOT GOING TO VIOLATE SECTION 25, 4 7 2 OF THE SUBSTANTIAL RULE.

SO WE WOULD HOPEFULLY, UM, SEE SOMETHING LIKE THAT PRIOR TO THE, UH, DISTRIBUTION OF THE SURVEY IN FEBRUARY.

SO THAT'S JUST FEEDBACK FOR YOU.

UM, AND HOPEFULLY YOU'RE HAVING THOSE DISCUSSIONS WITH THE COMMISSION ON, UM, THE ACTUAL DATA ITSELF.

I THINK YOU'VE, YOU MENTIONED THIS, BUT NOT ALL CUSTOMERS PROVIDE EMAIL ADDRESSES, SO, UM, YOU, YOU'RE NOT GONNA HAVE A EMAIL ADDRESS FOR EVERY SINGLE CUSTOMER.

SO THAT'S SOMETHING JUST TO BE AWARE OF.

WE CAN UPDATE THE BEST WE CAN, BUT IN MOST PARTS, UM, WHAT WE HAVE, WE ALREADY, UM, SEND IN THE CBCI FILES.

AND THEN ON SLIDE QUESTION ON SLIDE SEVEN, HOW ARE YOU, WHAT, WHAT'S THE THOUGHT PROCESS ON HOW YOU DIVIDE UP THE, UM, SURVEY, THE, THE RELEASE OF SURVEYS FOR SPECIFIC CUSTOMERS BY REP OR CO-OP OR MUNI? LIKE, SO YOU'RE GONNA TARGET 15 TO 20,000, UH, CONTACTS.

ANY THOUGHTS ON HOW YOU'RE GONNA DIVIDE THAT UP AMONGST MARKET PARTICIPANTS? SO THAT IS, UM, SOMETHING THAT, UH, BRATTLE AND PLAN BEYOND ARE, ARE WORKING ON AS WE SPEAK.

UM, WE CERTAINLY WANT TO GET A, UH, REPRESENTATIVE SAMPLE OF THE ERCOT REGION.

AND SO I THINK, UM, UH, WE'LL BE, YOU KNOW, MAKING SURE THAT WE HAVE, UH, GEOGRAPHIC DIVERSITY AND, UM, CUSTOMER TYPE, UH, UH, DIVERSITY, UH, YOU KNOW, EVEN WITHIN, UM, LIKE RESIDENTIAL FOR INSTANCE.

I THINK USING USAGE AS KIND OF A PROXY FOR WHETHER THAT PERSON RESIDES IN AN APARTMENT OR WHETHER THEY RESIDE IN A HOUSE, AND KIND OF SOME OF THE MORE PARTICULARS AROUND THAT TO WAIT THE SELECTION SAMPLE AROUND, UM, THE ERCOT REGION.

SO, UH, REALLY RELYING ON, UM, CUSTOMER USAGE DATA TO, UH, TO, TO WAIT IT.

AND I SHOULD SAY, UM, ERCOT DOES HAVE CUSTOMER USAGE DATA FOR, UM, THE COMPETITIVE MARKET ON A PER EASY ID BASIS.

SO I THINK WE CAN USE THAT, UM, DATA TO MATCH WITH THE CBCI DATA TO, UM, KIND OF WEIGHT THIS AROUND THE REGION AND, AND AROUND AND AROUND REPS AND NOE'S.

UM, UH, WITHIN THE, UH, THE NOE SERVICE AREA, I THINK THAT, THAT WE HAVE LESS, UM, OR, OR, UH, POSSIBLY NO, UH, ON A PER ZID BASIS, UM, UM, CUSTOMER USAGE INFORMATION.

SO I THINK WE WOULD BE LOOKING TO, UH, TO, TO PARTNER WITH SOME OF THOSE FOLKS TO, UH, UM, TO UNDERSTAND.

BUT I THINK GENERALLY SPEAKING, YOU KNOW, UH, WE DO KNOW, UM, WHAT, UH, IN THE NOE INSTANCE ANYWAY, WHAT THEIR, UM, PERCENTAGE OF THE ERCOT LOAD IS.

AND SO COULD KIND OF DISTRIBUTE THAT AMOUNT OF, UH, SURVEYS TO, TO THOSE ENTITIES.

WE'RE HIGHLY SUPPORTIVE OF THE PROCESS.

WE THINK THE INFORMATION YOU OBTAIN IS GOING TO BE EXTREMELY VALUABLE.

UM, THE LAST QUESTION I HAD IS, ARE WE GOING TO HAVE AN OPPORTUNITY TO HELP CRAFT THE WORDS USED IN THE SURVEY? I THINK THAT'S GONNA BE CRITICALLY IMPORTANT, PARTICULARLY FOR THE RESIDENTIAL CLASS OF CONSUMERS THAT ARE PROBABLY NOT GONNA HAVE ANY IDEA WHAT THIS IS ABOUT OR CERTAINLY NOT GONNA KNOW WHAT VOL IS.

UM, I THINK HAVING A WORKSHOP OR A OPPORTUNITY FOR REPS AND NON-OP IN ENTITIES TO HELP YOU WITH THAT LANGUAGE, I THINK WOULD BE VERY USEFUL.

AND WE'VE ALREADY HAD CONVERSATIONS WITH SOME OF OUR LARGE CNI CUSTOMERS, AND THEY'RE, LEXI LOOKING FORWARD TO THIS, SO I THINK IT'LL GET GOOD PARTICIPATION THERE, BUT I THINK THE RESIDENTIAL CLASS IS PROBABLY GONNA BE A CHALLENGE IN TERMS OF HOW WE MESSAGE IT SO THEY UNDERSTAND WHAT WHAT IS BEING ASKED OF THEM.

UM, PART OF THE, SO I THINK I MAY HAVE MENTIONED EARLIER THAT WE, UM, OUR RECOMMENDATION, UH, ERCOT AND, AND BRATTLE AND PLAN BEYOND'S RECOMMENDATION WILL BE TO USE, UH, THE LAWRENCE BERKELEY NATIONAL LABS ICE CALCULATOR 2.0 SURVEYS TO ACTUALLY PERFORM, UH, THE VOL, UH, SURVEY INITIATIVE.

UH, CERTAINLY.

[05:15:01]

AND SO I THINK THERE'S AN OPPORTUNITY TO ADD, UM, LIMITED QUESTIONS TO THAT SURVEY, BUT I THINK THE GOAL IS TO PRIMARILY KEEP IT, UH, IN, UH, THE, THE SHAPE THAT IT'S IN.

AND, AND I THINK THAT'S FOR TWO REASONS.

ONE, TO MAKE SURE THAT WE'RE STICKING TO, UM, OUR COMMITMENT TO TIMELY, UM, PROVIDE THE FULL VOL STUDY BY THE END OF THE SECOND QUARTER OF 2024, BUT ALSO, UM, AND FUNDAMENTALLY, UH, BECAUSE THOSE SURVEYS HAVE UNDERGONE RIGOROUS, UM, UH, TESTING, UH, UH, AND DEVELOPMENT BY THE LABS ON A NATIONWIDE BASIS.

AND SO WE THINK THAT THERE'S A LOT OF, UM, UH, LEARNING AND AND REFINEMENT THAT WENT INTO THOSE, UM, THAT WERE, WERE LOOKING TO, UH, TO, TO LEVERAGE.

UM, SO THE, THE SURVEYS ARE, UM, LAWRENCE BERKLEY'S, UM, CONFIDENTIAL INFORMATION, AND SO THAT'S PART OF THE CHALLENGE HERE AS WELL IS, UH, YOU KNOW, I, I, AT LEAST AT THIS TIME, WE CAN'T, UM, SHARE THOSE SURVEYS, UH, BROADLY WITH THE STAKEHOLDERS.

UM, BUT, UH, UH, WE'RE, UH, WE'RE WORKING THROUGH THAT WITH THE LABS AND, UH, AND, AND THEY'RE, WE CAN EXECUTE, UH, YOU KNOW, AN NDA TO SHARE THEM, UH, WITH FOLKS.

UM, SO CERTAINLY HAPPY TO DISCUSS THAT WITH OFFLINE, WITH PEOPLE IF, UH, IF THEY'D LIKE TO SEE THE SURVEYS.

CHRIS HENDRICKS.

THANKS MATT.

UM, CAN I FOLLOW ALONG WITH BILL'S, EXCUSE ME, UM, COMMENT THERE.

ONE OF THE CONCERNS, I GUESS IS WHEN YOU SEE THE INFORMATION COME OUT FROM NATIONAL CONSULTANTS, THEY DON'T SPEAK OR SPEAK, SO THAT LANGUAGE GETS LOST IN THE, IN THE TRANSITION A LOT OF TIMES.

SO JUST CONCERNED ABOUT THAT.

BUT THEN COUPLE OF QUESTIONS.

ONE, WHO, WHO IS GONNA SEND OUT THE EMAIL? SO WHAT, WHAT EMAIL ADDRESS OR ORGANIZATION'S GONNA SEND IT OUT? UM, GOOD QUESTION.

I, SO, UH, WE'RE ALSO STILL WORKING ON THAT, BUT, UM, UH, I THINK THERE ONE POTENTIAL IS THAT IT WOULD BE SENT OUT CARE OF THE PUBLIC UTILITY COMMISSION.

SO, UM, WE'RE, UH, THAT HAS NOT BEEN ARRIVED AT AS A, AS A FINAL THING, BUT WE'RE EXPLORING THAT WITH, WITH THE COMMISSION SO THAT THESE WOULD BE COMING FROM THE COMMISSION.

WE COULD ALSO, UH, BRAND THEM AS COMING FROM ERCOT, UM, OR A COMBINATION OF, OF THE TWO.

UM, BUT THE ACTUAL EMAIL ADDRESS THAT THEY SEE, I, I DON'T KNOW EXACTLY AT THIS POINT.

UM, WHEN, UH, ERCOT USES CBCI IN THE EVENT OF A MASS TRANSITION, UM, ERCOT SENDS BOTH THE PHYSICAL MAIL, AND AS I UNDERSTAND IT, THE EMAILS CARE OF THE PUBLIC UTILITY COMMISSION.

AND SO, UM, THERE WILL, UH, UH, I'M NOT SURE WHAT THE AT AND EMAIL ADDRESS IS YET, BUT, UH, BUT I THINK EFFECTIVELY THAT WOULD BE, UM, ONE WAY TO DO IT.

THE LIKELIHOOD OF A BLOWUP IN THE PRESS, I THINK APPROACHES A HUNDRED PERCENT.

AND THEN FROM, FROM A LARGE COMMERCIAL OR EVEN MEDIUM COMMERCIAL, HOW ARE YOU GONNA HANDLE THOSE TYPE OF CUSTOMERS SO THAT HAVE MULTIPLE EASY IDS? ARE YOU GONNA GO AFTER JUST THE EASY ID ITSELF OR THE CUSTOMER? UM, GOOD QUESTION.

WE'LL PROBABLY BE DOING IT, UM, ON A FACILITY BASIS.

SO IF THERE ARE MULTIPLE EASY IDS AT A FACILITY, WE MIGHT BE LOOKING AT A A PER CUSTOMER IE MULTI EASY ID BASIS.

UM, WE HAVE BEEN COORDINATING WITH, UM, UM, THE, THE TRADE ASSOCIATIONS, TIEC FOR INSTANCE, UH, ON, ON MAKING SURE TO GET, UH, THIS OUT TO, UH, THE LARGE COMMERCIAL AND INDUSTRIAL CUSTOMERS.

UM, AND SO, UH, UM, YEAH, THAT, THAT WILL BE, THAT WILL BE CRUCIAL, I THINK.

RIGHT? KEVIN HANSSEN? YEAH.

JUST QUICK QUESTION.

IS THERE GONNA BE A DURATION COMPONENT TO THE VOL QUESTIONS? LIKE FOR INSTANCE, IF IT'S ONE HOUR VOL, MY NUMBER IS THIS, IF IT'S FOUR HOURS, IS THIS WAS 12 HOURS? IS THIS, IF IT'S A YEAR EVENT, MY NUMBER IS THIS? MM-HMM.

, UH, YES, THERE WILL BE A DURATION AND, UH, AS I UNDERSTAND IT, THE INTERIM VOL THAT WE WILL BE INCLUDING IN THE REPORT, UH, BEFORE THE HOLIDAYS, UM, WE'LL INCLUDE A VOL ON A CUSTOMER CLASS BASIS AND ALSO ON A, ON A DURATION BASIS, I THINK THERE WILL BE MAYBE A SHORT AND EITHER A MEDIUM OR A LONG-TERM ONE.

UM, AND THE, UH, THE SURVEYS DO ASK ABOUT, UM, DURATIONS.

SO CERTAINLY BOB WHITMEYER.

YEAH, SO, SO TWO POINTS.

UM, ONE, I THINK WE HAVE TO BE EXCEEDINGLY CAREFUL IN THE COMMUNICATION.

UM, IF THIS COMES OUT FROM, FROM ERCOT AND IS NOT COMMUNICATED PERFECTLY CLEARLY,

[05:20:01]

UM, SO THAT, THAT'S ONE POINT.

I THINK IT'S CRITICAL THAT WE GET ERCOT, YOU KNOW, YOUR PR PEOPLE INVOLVED IN ALL THAT, UM, AND MAKE SURE THAT IS TIGHT.

SECONDLY, I THINK YOU PROBABLY NEED TO THINK ABOUT THE NOS AS TWO SEPARATE ENTITIES, THE CO-OPS AND THE MUNICIPALITIES, BECAUSE MANY OF THE MUNICIPALITIES HAVE NATURAL GAS SERVICE IN THEIR TERRITORY.

SO THE CUSTOMERS HAVE GAS AND ELECTRIC, WHERE THE CO-OPS ARE GENERALLY MORE JUST ELECTRIC BASED, UM, HEATING SYSTEM.

SO I THINK THAT WOULD BE WORTH CONSIDERING AS WELL.

I KNOW THIS HAS BEEN A LOT OF WORK.

I JUST WANTED TO ASK, DO YOU KNOW WHEN THE QUESTIONS WERE FORMULATED? LIKE WHAT YEAR, MONTH ORIGINALLY? UH, THAT'S A GOOD QUESTION.

I DON'T KNOW SPECIFICALLY WHEN THE QUESTIONS WERE FORMULATED.

I KNOW THAT, UH, THE LABS LAUNCHED THIS ICE 2.0 INITIATIVE IN THIS, I THINK JUNE OF 2022.

SO LAST YEAR, UM, THE LABS HAVE WORKED WITH A EP TEXAS IN, IN TEXAS TO CONDUCT, UM, THAT ICE CALCULATOR SURVEY IN THEIR SERVICE AREA.

AND I, UM, THAT MAY HAVE ALREADY BEEN COMPLETED, OR IF IT'S NOT, I THINK IT'S NEAR COMPLETION.

SO, UM, I UNDERSTAND THAT THERE, UM, WERE REFINEMENTS DONE TO THE, TO THE SUR THERE WERE AL THERE WERE ALWAYS REFINEMENTS DONE TO THE SURVEYS, UH, BEFORE THEY WERE CONDUCTED, INCLUDING, UM, BEING CONDUCTED IN TEXAS BY A EP TEXAS.

SO I WOULD SAY THAT, YOU KNOW, PROBABLY THIS SUMMER, I THINK YOU'RE GOOD TO, TO KEEP GOING.

UH, THAT IS ACTUALLY ALL I HAD, AND, UM, IF ANYBODY HAS ANY QUESTIONS, UM, YOU'RE WELCOME TO REACH OUT TO MYSELF OR, UM, RYAN KING IS LEADING THIS INITIATIVE FOR, UH, ERCOT.

AND, UH, WE'LL BE BACK AT RMS TOMORROW AS WELL.

SO THANK YOU.

PUBLISHED IN THAT, UH, YOU KNOW, UH, SPECIAL STUDY REPORT.

UM, SO WE ARE NOW ON, WE HAVE TWO VOTING ITEMS. IT WAS THE WEST TEXAS SYNCHRONOUS CONDENSER PG PROJECT, AND THEN AFTER THAT, THE TNMP SILVER RELIEF AND COW PEN, UM, PROJECT.

AND SO AFTER THAT I WAS GONNA MOVE THE COMBO BALLOT UP, RAISE IT RIGHT HERE, RIGHT HERE.

UM, GOOD AFTERNOON.

MY NAME IS SOUK KANG FROM, UH, DYNAMIC STUDIES TEAM IN GRID PLANNING , AND THIS IS ABOUT THE ARD INDEPENDENT INTERVIEW AND THE RECOMMENDATIONS ON THE WEST TEXAS, UH, SYNCHRONOUS CONDENSER IPG PROJECTS.

ALRIGHT, UH, LET ME START WITH A BRIEF, UH, BACKGROUND HERE.

UH, SO BASED ON THE NUMBER OF REAL TIME EVENTS AND THE LESS LESSONS LEARNED FROM THOSE EVENT, UH, , YOU KNOW, WITH THE SUPPORT FROM THE STAKEHOLDERS IS MAKING, UH, YOU KNOW, A NUMBER OF DIFFERENT, UH, EVENTS THROUGH, YOU KNOW, MULTIPLE DIFFERENT DIRECTIONS, TRANSMISSION, YOU KNOW, SYSTEM REINFORCEMENT AND PROCESS CHANGES AND IMPROVEMENTS, AND ALSO, UH, ENHANCEMENT IN THE OPERATING OPERATING REQUIREMENTS.

SO AS PART OF THIS APP, I MEAN THAT EFFORT, I MEAN, THIS IS A TRANSMISSION SITE, BASICALLY, ERCOT, UH, CONDUCTED A, A COMPREHENSIVE STUDY TO EVALUATE THE BENEFIT OF POTENTIAL SYNCHRONOUS CONTENDER INTERATIONS IN WEST TEXAS REGION.

AND, UH, WE COMPLETED AND PUBLISHED THE REPORT, UH, BACK IN JUNE.

AND THEN, UH, YOU KNOW, UM, ERCOT, UH, VICE PRESIDENT RIKON, UH, MADE A PRESENTATION, UH, OF THE, THE KEY FINDINGS AND RESULTS AND BENEFITS AND RECOMMENDATIONS, UH, ON OUR STUDIES TO THE ERCOT, UH, YOU KNOW, RELIABILITY AND MARKET, UH, COMMITTEE MEETING IN AUGUST.

AND SUBSEQUENTLY, UH, YOU KNOW, WE H-R-A-T-S-C AND ONCO, THOSE RELEVANT TSPS, UH, SUBMITTED, SUBMITTED A THREE, UH, SEPARATE INDIVIDUAL, UH, YOU KNOW, RPG PROPOSAL, UH, TO IMPLEMENT THE RECOMMENDED SYNCHRONOUS CONDENSER PROJECTS.

UH, THAT WAS IN SEPTEMBER.

AND ERCOT, UH, CONDUCTED AN, UH, ERCOT INDEPENDENT REVIEW, UH, IN AN EXPEDITED MANNER BECAUSE WE ALREADY CONDUCTED THE, THE WHOLE STUDIES BACK IN JUNE AND ALL THAT REPORT AND DETAILS WERE

[05:25:01]

UM, AND ACCORDING TO, UH, THOSE TSPS, THE TOTAL COST, THE COMBINED COST IS ABOUT $892.2 MILLION.

AND, AND THE, YOU KNOW, OF COURSE, THE PROJECT WILL, YOU KNOW, UH, EXPECT IT TO REDUCE THE RELIABILITY RISK AND ALSO STRENGTHEN THE WEST TEXAS SYSTEM, UH, BASED ON THE PROTOCOL.

UH, T ONE PROJECTS, YOU KNOW, REQUIRE CUT BOARD ENDORSEMENT AND ERCOT MUST PRESENT TIER ONE PROJECTS TO THE TAC FOR REVIEW AND COMMENTS, AND THE COMMENTS WILL BE, WILL BE INCLUDED IN THE PRESENTATION TO THE ERCOT BOARD.

WE ALSO LOOKED INTO, YOU KNOW, ADDING OPTIONS TO ADD MORE SYNCHRONOUS CONDENSERS, BUT AT THIS MOMENT, WE DON'T SEE ANY SIGNIFICANT IMPROVEMENTS HERE, UH, BASED ON THE PROTOCOL SECTION 3, 2, 2, 1 3, UH, ERCOT STEP, YOU KNOW, CONDUCTED AN SUB SYNCHRON ASSOCIATION SCREENING, AND, AND THE RESULT INDICATE THAT EXCEPT THE RIDER 3 45 KB SUBSTATION LOCATION, UH, MORE DETAILED SUBSEQUENT ASSOCIATION STUDY WILL NEED TO BE DONE FOR ALL OTHER FIVE LOCATIONS.

PROJECT NEED.

SO, YOU KNOW, AS WE ARE AWARE, ERCOT HAS HUGE AMOUNT OF IBR, AND YOU KNOW, PARTICULARLY IN THE WEST TEXAS REGION, WE EXPECT MORE THAN 40 GIGAWATTS OF IBR CAPACITY, UH, IN THE NEXT, IN THE NEXT SEVERAL YEARS, I IBMS ARE DIFFERENT, OKAY? THEY'RE NOT THE SYNCHRONOUS GENERATOR, THEY DON'T HAVE ANY ROTATING MASS.

THEY PRETTY MUCH RELYING ON THE GRID STRENGTH SYSTEM STRENGTHS.

OKAY? UH, HIGH PENETRATION OF IBR AND LACK OF CONVENTIONAL GENERATION RESOURCES CAN RESULT AND CAN MAKE THE SYSTEM WEAK AND ALSO CAN CAUSE POTENTIAL INSTABILITY ISSUES IF THERE'S ANY UNACCEPTABLE OR UNDESIRED, YOU KNOW, REAL TIME EVENTS.

AS YOU CAN SEE IN THE BOTTOM CHART HERE, I MEAN, THIS IS, UH, BASICALLY, UH, HISTORICAL IBR RELATED EVENTS.

UM, OVER THE LAST, YOU KNOW, SEVEN YEARS IN US, THREE OF THEM HAPPENED IN ERCOT, AND WE LOST A SIGNIFICANT AMOUNT OF IBR OUTPUT, UH, DURING THE OD DSA 2022 OD DSA EVENT, AND IT CAUSED SIGNIFICANT OPERATIONAL CHALLENGES, OKAY? AND WE BELIEVE THAT, YOU KNOW, THE MAGNITUDE OF THE CHALLENGES AND OPERATIONAL CHALLENGES AND ISSUES IS HIGHLY LIKELY TO INCREASE AS WE HAVE, YOU KNOW, MORE AND MORE I BS COMING INTO THE ERCOT GRID.

OKAY? SO, UH, SO TO MAKE THE SYSTEM, UH, MORE STRONGER WEST TEXAS SYSTEM MORE STRONGER AND TO MAKE THE WEST TEXAS SYSTEM MORE RESILIENT TO THOSE, YOU KNOW, UNEXPECTED, UH, REAL TIME EVENT, UH, ERCOT, YOU KNOW, THOUGHT ABOUT SOME DIFFERENT OPTIONS, OKAY? UH, ADDING SYNCHRONOUS GENERATOR, CONVENTIONAL GENERATOR, OR ADDING, YOU KNOW, SYNCHRONOUS CONDENSER OR OTHER TECHNOLOGIES LIKE STATCOMS OR GOOD FORMING INVERTERS.

BUT OUR CUT CONSIDERED, UH, SYNCHRONOUS CONDENSERS AS ONE AND ONLY TRANSMISSION UPGRADE OPTIONS THAT PROVIDE NECESSARY CHARACTERISTICS AND SUPPORT, UH, TO THE WEST TEXAS, UH, SYSTEM.

BY THE WAY, I DIDN'T MENTION IN THE, IN THE PREVIOUS SLIDE, BUT, UH, THE REALLY THIS PROJECT HERE IS NOT, DOES NOT HAVE ANYTHING TO DO WITH THE NERC RELIABILITY CRITERIA VIOLATION OR ERCOT PLANNING CRITERIA VIOLATION.

THIS IS PURELY TO ADDRESS AND MINIMIZE THE CHALLENGES DRIVEN BY THE REAL TIME EVENT LIKE ODESSA.

OKAY? I THINK WE HAD A, UH, A BUNCH OF DISCUSSIONS DURING, UH, IN THE MORNING, UH, WHEN WE TALK ABOUT THE NOVO 2 45.

UH, SO WE LOOKED AT THE DIFFERENT SCENARIOS AND, YOU KNOW, UH, STUDY DIFFERENT CASES AND, AND THE STUDY STUDY, YOU KNOW, FOUND THAT, YOU KNOW, THERE ARE SOME SIGNIFICANT ENHANCEMENT, UH, IN IPRO IN THE SYSTEM STRENGTHS AND ALSO, UH, HUGE DEDUCTIONS IN A NUMBER OF 3 45 AND ONE 30 KB BUS, AS WELL AS THAT MAY ENCOUNTER, YOU KNOW, CBO VOLTAGE DATA, UH, DURING THE MAJOR TRANSMISSION FAULT IN THE WEST TEXAS REGION.

AND ALSO ERCOT, UH, LOOKED AT THE IMPACT ON THE EXISTING GTCS, UH, AND, AND THE STUDY FOUND THAT THERE'S SOME IMPROVEMENTS IN THE GTC, BUT, UM, NO SIGNIFICANT, UH, IMPACT ON THE WEST TEXAS GTC THIS MOMENT.

SO IN CONCLUSION, UH, BELIEVE THAT THE SYNCHRONOUS CONDENSERS, UH, WILL IMPROVE THE RELIABILITY AND THE RESILIENCE OF THE EXISTING WEST TEXAS SYSTEM AND THE M AND MINIMIZED IMPACT, UH, DUE TO THE UNEXPECTED EVENT IN NEAR TIME.

[05:30:01]

AND IF MITIGATION IS NEEDED, THEN THAT HAS TO BE COMPLETE, UH, BEFORE THE ENERGIZATION OF SYNCHRONOUS CONDENSERS BASED ON THE PLANNING GUIDE, SECTION 3 1 3, ERCOT LOOKED IN, YOU KNOW, UH, REVIEW THE, UH, IMPACT ON THE, THE GENERATION, FUTURE GENERATION AND ALSO LOAD SCALING.

AND THE STUDY RESULT FOUND NO IMPACT, UH, DUE ON NO IMPACT ON THE PROJECT NEED DUE TO ANY FUTURE, UH, GENERATIONS OR LOAD SCALING.

THERE.

ERCOT DID NOT CONDUCT ANY CONGESTION ANALYSIS, UH, BECAUSE, UH, SYNCHRONOUS CONDENSER IS THE ONLY THE SOLE TRANSMISSION OPTIONS AS REACTIVE POWER, UH, SUPPORT DEVICES.

UH, BASED ON THE ARDI INDEPENDENT VIEW, UH, WE RECOMMEND THE BOARD TO ENDORSE THE, UH, SYNCHRONOUS CONDENSER INSTALLATION, UH, AT KANU BEARCAT TOWA, UH, LONG DRILL RIDER BAKERSFIELD, UH, TO HELP THE SYSTEM TO MAKE THE SYSTEM MORE, UH, RESILIENT.

UH, BASED ON THE INFORMATION, UH, FROM TSPS, UM, THE TARGETED IN OF STATES FOR THE PROJECTS IS, UH, THE MAY OR OCTOBER, 2027.

AGAIN, THE TOTAL ESTIMATE TO COST IS THE $892.2 MILLION.

UH, AS YOU CAN SEE, UH, THIS MAP HERE, THE MAP HERE IS, UH, UH, YOU KNOW, SHOWS THE PROPOSED, UH, SIX, UH, SYNCHRONOUS CONDENSER LOCATIONS.

AND EACH LOCATION WILL HAVE ABOUT 350 MEGA BAR CAPACITY AND ABOUT 330 600 ARMS OF CIRCUIT, UH, FOR CONTRIBUTIONS AT THE POI AND ALSO, UM, ABOUT 2000 MEGAWATT OF SYSTEM INERTIA AT EACH LOCATION.

SO THAT'S ALL I HAVE, AND I WILL, UM, OPEN UP FOR ANY QUESTIONS IF YOU HAVE.

YEAH, IT LOOKS LIKE WE HAVE A COUPLE IN THE QUEUE.

BRIAN SAMS, HEY THERE, UH, APPRECIATE THE PRESENTATION.

I, I'M CONFUSED ABOUT THE CRITERIA THAT WAS USED TO, UH, I GUESS ENDORSE THE, OR JUSTIFY THE, THE PROJECT.

WERE YOU USING A RELIABILITY CRITERIA OR ECONOMIC CRITERIA? I, I JUST, IT'S UNCLEAR TO ME.

SO AS I MENTIONED, THIS IS NOT ABOUT, UH, YOU KNOW, NORMAL, UH, PLANNING CRITERIA.

OKAY? UM, THIS IS TO MINIMIZE ANY POTENTIAL RELIABILITY ISSUES DRIVEN BY SIGNIFICANT LOSS OF IB, YOU KNOW, UNDER CERTAIN, YOU KNOW, FAULT EVENT IN REAL TIME.

WE LOST ABOUT 1700 MEGAWATTS DURING THE ODESSA.

AND SINCE THEN, UM, YOU KNOW, WE ARE, YOU KNOW, WORKING ON THE NOVO 2 45, RIGHT? UH, FROM OUR, UH, TO ENHANCE THE, UH, RIDE THROUGH REQUIREMENTS.

WE ARE ALSO WORKING ON THE P 1 0 9 TO IMPROVE THE MODEL PROCESS.

WE ARE WORKING WITH THE GENERATION OWNER TO MAKE THE, TO GET THE MODELS, YOU KNOW, HAVE THE MODEL MORE ACUTE MODELS, AND FROM A TRANSMISSION SIDE, WHAT WE CAN DO, RIGHT? WE CAN, WHAT YOU CAN DO IS WE CAN PICK UP THE TRANSMISSION SYSTEM, UH, TO, TO MAKE, TO DEDUCE THE, THE WIDESPREAD VOLTAGE TIPS IN THE WEST TEXAS REGION SO THAT THE IDEAS CAN LESS EFFECTIVE DURING THAT, YOU KNOW, UH, FUTURE REAL TIME EVENT.

SO THAT'S, THE DRIVER OF THESE PROJECTS HAS NOTHING TO DO WITH ERCOT, UH, YOU KNOW, CRITERIA, NORMAL PLANNING CRITERIA.

AND THIS IS TO ADDRESS THE, UH, THE OPERATIONAL CHALLENGES AND CONCERN, UH, YOU KNOW, AND, AND THAT'S BEEN ANNOUNCED, YOU KNOW, MANY TIMES IN MANY DIFFERENT, YOU KNOW, UH, WORKING GROUP MEETINGS AND THINGS.

SO YEAH, I, SO I MISSED THOSE.

I'M SORRY, I, THE RPG MEETINGS, I'M SURE IT WAS DISCUSSED.

I APPRECIATE IT.

YES, YES.

TO SAY YOU DID NOT USE THE ECONOMIC PLANNING CRITERIA FOR THESE PROJECTS? I THINK THAT RIGHT.

YEAH, IT'S, SO WOULD IT BE FAIR

[05:35:01]

YEP.

TO ME, IT SOUNDS LIKE MARE, YOU'RE USING SOME UNDEFINED RESILIENCY CRITERIA, PROBABLY DATES THAT'S THE RIGHT, YOU KNOW, APPROACH TO SAY, OKAY, GO AHEAD BOB.

I WAS JUST GONNA SAY THAT SUGGEST THEY GO ON A COMBO BALLOT UNLESS THERE'S SOMEONE THAT OBJECTS, I, I AGREE WITH YOU AND PROBABLY THE NEXT ONE TOO, BUT I'LL WAIT TILL THE PRESENTATION.

WE, WE WOULD BE LOOKING TO ENDORSE, UH, THE WEST TEXAS SYNCHRONOUS CONDENSER RPG PROJECT AS RECOMMENDED BY ERCOT AND TO PUT THAT ON THE COMBO BALLOT, UNLESS THERE'S OBJECTIONS TO PUTTING THAT ON THE COMBO BALLOT BILL, HAVE A OBJECT? NO.

BILL, DO YOU HAVE AN, I DON'T HAVE AN OBJECTION.

I'M JUST, I KNOW WE DID THIS BEFORE AND I'M TRYING TO REMEMBER WHAT, WHAT MAKES THIS A TRANSMISSION PROJECT? CAN I HELP WITH THAT PERHAPS? YEAH, SURE.

IT, IT'S FACILITIES THAT ARE OWNED AND OPERATED BY TRANSMISSION GRID OPERATORS AT THE DIRECTION OF, OF ERCOT, EVEN THOUGH IT'S NOT TRADITIONAL TRANSMISSION EQUIPMENT, IT'S STILL TRANSMISSION EQUIPMENT.

MAYBE COLIN CAN JUMP IN WITH A MORE ENGINEERING BASED ANSWER, BUT THAT'S MY UNDERSTANDING.

I'M JUST WONDERING IF A MORE, IF THERE'S A MORE APPROPRIATE COST ALLOCATION MECHANISM THAT SHOULD BE USED FOR THIS 900 MILLION BILL.

CAN'T TALK TO THE COST ALLOCATION MEASURE, BUT I MEAN, WE'VE GOT, WE'VE GOT TWO EXISTING SYNCHRONOUS CONDENSERS ON THE ENCORE SYSTEM.

ANY MORE DISCUSSION THERE? YOU GOOD, BILL? ALL RIGHT, SO NOW WE HAVE OUR, OUR LAST REPORT, THE TNMP OR PG PROJECT.

GOOD AFTERNOON EVERYBODY.

I KNOW IT'S BEEN A, A LONG DAY, SO I'LL TRY TO MAKE THIS RELATIVELY QUICK FOR YOU.

UH, MY NAME IS ROBERT GOLAN, UH, MANAGER OF REGIONAL PLANNING.

I'LL BE GOING THROUGH THE TIER ONE SILVERLEAF TO COW PEN 3 45 1 38 KV STATION.

UH, PROJECT REVIEW, UH, TODAY AT TECH.

SO FOR THIS, THE TNMP SUBMITTED THIS PROJECT BACK IN MAY OF 2023.

IT WAS CLASSIFIED AS A TIER ONE PROJECT WITH AN ESTIMATED COST OF JUST SHY OF $300 MILLION.

THIS PROJECT WAS TO, UH, DESIGNED TO ADDRESS THE RELIABILITY NEEDS IN THE REEVES IN WARD COUNTIES IN THE FAR WEST WEATHER ZONE.

UH, SO WE HAVE A, A PICTURE HERE OF THE STUDY AREA, UH, FOR YOUR REFERENCE.

SO JUST, JUST LIKE THE PREVIOUS PRESENTATION, UH, ALL TIER ONE PROJECTS PURSUANT TO THE PROTOCOLS, UH, WITH A, UH, OBVIOUSLY THEY HAVE OVER A HUNDRED MILLION DOLLARS, UH, WORTH OF COSTS ASSOCIATED WITH THEM DO REQUIRE ERCOT BOARD ENDORSEMENT.

UH, ALSO WITH THE PROTOCOLS WE ARE HERE TODAY, UH, FOR THE, THE TAC REVIEW AND COMMENT PROCESS.

UH, SO AFTER THIS, ANY COMMENTS FROM TAX SHALL BE INCORPORATED INTO THE PRESENTATIONS THAT WILL BE GOING TO THE ERCOT BOARD FOR THE PROJECT NEED.

UH, WE, WE LOOKED AT THE SUMMER OF 2027 RTP ANALYSIS.

UH, WE, WE DID IDENTIFY A NUMBER OF RELIABILITY PLANNING CRITERIA VIOLATIONS, UH, FOR THAT STUDY YEAR.

UH, UNDER PRE, UH, PRE-CON CONTINGENCY OVERLOADS, WE SAW A COUPLE TRANSFORMERS, A COUPLE MILES WORTH OF 1 38.

UM, AS, AS WE GET INTO N MINUS ONE G MINUS ONE X MINUS ONE X MINUS ONE, AND N MINUS ONE, UH, CONDITIONS, YOU KNOW, WE, WE SEE, UH, MULTIPLE TRANSFORMERS SHOW UP IN ADDITIONAL MILEAGE OF 1 38 KV LINES OVERLOADED.

UH, IN TOTAL WE SAW 5 3 45 1 38 KV TRANSFORMERS OVERLOADED, AND JUST OVER EIGHT MILES OF 1 38 KV TRANSMISSION SYSTEM OVERLOADS AND ALSO ONE UNSOLVABLE CONTINGENCY.

SO ERCOT DID ANALYZE MULTIPLE OPTIONS FOR THIS.

UM, WE, WE DID SHORT LIST TWO OF THE FOUR OPTIONS THAT WERE EVALUATED.

UH, UPON THE COMPLETION OF THE EVALUATION, WE, WE DO SELECT AND

[05:40:01]

RECOMMEND WE OPTION ONE, UH, IT IS A LITTLE MORE EXPENSIVE THAN OPTION TWO, BUT WITH THE MAIN FOCUS, LOOKING AT THE LONG-TERM LOAD SERVING CAPABILITY, UH, FOR OPTION ONE, IT, IT IS FAR SUPERIOR THAN OPTION TWO.

AND THE ONLY WAY TO GET EVEN CLOSE TO, UH, THE ADDITIONAL LOAD SERVING CAPABILITY OF OPTION ONE, UH, YOU WOULD HAVE TO ACTUALLY ADD MULTIPLE, UH, 3 45 TO 1 38 PATHWAYS, WHICH ESSENTIALLY MIMICS WHAT OPTION ONE IS DOING, UH, WHICH WOULD SIGNIFICANTLY INCREASE THE COST FOR OPTION TWO.

SO, I KNOW, I KNOW IT'S A LITTLE ROUNDABOUT AND CONFUSING, BUT, UH, OPTION TWO ONLY PROVIDED ABOUT THREE ADDITIONAL 3 45 TO 1 38, UH, TRANSMISSION UH, INJECTION POINTS INTO THE 1 38 SYSTEM.

OPTION ONE CREATED FIVE ADDITIONAL INJECTION POINTS.

UH, SO THAT'S THE MAIN DIFFERENCE.

SO THE SERVING CAPABILITY OF THAT 1 38 NETWORK OFF OF THE 3 45 IS SUBSTANTIALLY BETTER WITH OPTION ONE.

SO WE DID LOOK AT CONDUCTING AN SSR SCREENING FOR OPTION ONE.

WE, WE DID NOT FIND, UH, ANY ADVERSE IMPACTS BECAUSE OF EXISTING OR PLANNED GENERATION RESOURCES.

UH, WE PERFORMED THE CONGESTION AND DID THE GENERATION AND LOAD SCALING SENSITIVITIES.

WE DID NOT FIND ANY, UH, NEW CONGESTIONS CAUSED BY OPTION ONE, NOR DID WE SEE ANY POTENTIAL FUTURE, UH, UH, IMPACTS WITH NEW GENERATION AND DETERMINED THAT THE LOAD SCALING DID NOT HAVE A MATERIAL IMPACT ON THIS PROJECT.

SO, BASED ON THE REVIEW, UH, ERCOT WILL RECOMMEND TO THE BOARD TO ENDORSE, UH, OPTION ONE.

UH, THIS DOES ADDRESS THE RELIABILITY NEED IN THE REEVES AND WARD COUNTIES IN THE FAR WEST WEATHER ZONE.

UH, BASED ON THE THE TSP, IT IS EXPECTED TO BE ABLE TO IMPLEMENT THE UPGRADES BY JUNE OF 2027.

UH, THE ESTIMATED COST, UH, WHEN WE FINALIZED THE COST ESTIMATES FOR THIS PROJECT ACTUALLY CAME IN A LITTLE BIT LOWER THAN THE INITIAL 299 MILLION, UH, ESTIMATE THAT THEY, THEY PROVIDED, UH, FINAL COST ESTIMATES WAS 273.1 MILLION.

UH, TNP DID, UH, DESIRE TO HAVE THIS TO BE, UH, DESIGNATED AS CRITICAL TO RELIABILITY.

UH, ERCOT DOES RECOMMEND THAT THIS PROJECT BE LABELED AS CRITICAL TO RELIABILITY AS WELL.

SO FOR THE ACTUAL OPTION ONE, UH, THERE WILL BE A NEW 3 45 KV SUBSTATION.

WE DESIGNATED IT AS NEW SUBSTATION ONE NEAR THE EXISTING CEDARVILLE SUBSTATION, AND THIS WILL BE CUTTING INTO THE PLANNED NORTH MCCAMEY TO SAND LAKE 3 45 DOUBLE CIRCUIT LINE.

UH, RIGHT NEXT TO IT.

UH, THEY'RE LOOKING TO CONSTRUCT A 3 45 TO 1 38 SILVERLEAF STATION, UH, NEAR THAT NEW SUBSTATION THAT CUT INTO THAT 3 45 PATHWAY.

UH, THIS WOULD HAVE THREE, UH, 3 45 TO 1 38 KV TRANSFORMERS, UH, GOING INTO THE 1 38 NETWORK AT THIS NEW, UH, SILVER LEAF STATION.

UH, THEY WOULD BE LOOKING TO LOOP IN THREE SEPARATE 1 38 KV LINES.

THESE ARE THE CEDARVILLE TO PECOS, UH, NUMBER ONE, NUMBER TWO LINE, AND THEN ALSO THE CEDARVILLE CEDARVILLE TO BONE SPRINGS 1 38.

THIS WOULD BE APPROXIMATELY 4.4 MILES OF NEW RIGHT OF WAY.

AND THEN THE SECOND HALF OF IT, UH, VERY SIMILAR TO, UH, UH, TO THE OTHER, UH, TO THE SILVERLEAF SIDE.

UH, THEY'RE GONNA DO A, A SIMILAR 3 45 KV SUBSTATION CUT IN DESIGNATED AS NEW SUBSTATION TWO.

UH, THIS WILL BE CUT INTO THE EXISTING SAND LAKE TO SOLSTICE 3 45 KV LINE, UH, RIGHT NEXT TO IT OR NEARBY.

UH, THEY WERE LOOKING TO CONSTRUCT A 3 45 TO 1 38 KV, UH, COW PEN SUBSTATION.

UH, THIS WOULD THEN TIE INTO THE 1 38 KV NETWORK BY LOOPING INTO THE EXISTING IH 20 TO SALT DRAW AND THE, UH, BIRDS OF PREY TAP TO, UH, HARPOON TAP.

UH, THIS PART WILL REQUIRE APPROXIMATELY 14.2 MILES OF NEW RIGHT OF WAY.

AND TO GIVE YOU A BETTER VISUALIZATION,

[05:45:02]

UH, SO HERE'S THE, THE SILVER SILVERLEAF SUBSTATION AND THE ADDITIONAL 3 45 SUBSTATION.

THAT'S CUTTING.

OH, CUTTING INTO THE, UH, FUTURE SAND LINK TO NORTH MCKAMEY, UH, NEXT TO CEDARVILLE.

AND THEN THERE WOULD BE TYING IN THE 1 38 NETWORK, UH, TO THAT NEW SUBSTATION, SILVERLEAF.

AND THEN DO THE SAME THING DOWN HERE AT, AT THE CAL PEN SUBSTATION, UH, LOOPING IN THE 1 38 NETWORK AS WELL.

UH, SO THAT'S THE, THE BIG OVERVIEW OF THE, THE PROJECT.

ARE THERE ANY QUESTIONS? I DON'T SEE ANY QUESTIONS ON THIS ONE.

ALRIGHT, WONDERFUL.

HAVE A GREAT, I BELIEVE SO.

BOB HAD A MOTION WE DIDN'T NEED, BUT THE IDEA WOULD BE TO PUT THIS ON THE COMBO BALLOT.

UM, AND IT WOULD BE ENDORSE THET MP OF RELIEF AND COW PEN 3 45 1 38 KV STATIONS RPG PROJECT.

THIS IS OPTION ONE AS RECOMMENDED BY ERCOT.

IS THERE ANY ISSUE WITH PUTTING THAT ON THE COMBO BALLOT? OKAY.

COREY, WHY DON'T WE GO AHEAD AND TAKE UP THAT COMBO BALLOT, UM, NOW AND THEN WE'LL DO THE OTHER BUSINESS ITEMS FOLLOWING THAT.

HERE ARE THE ITEMS ON THE COMBO BALLOT IF YOU WANNA TAKE A LOOK.

[16. Combo Ballot (Vote)]

COREY, I THINK WE CAN GO AHEAD AND GET STARTED WITH THIS.

YEAH, SOMEONE WOULD BE KIND ENOUGH TO MAKE A MOTION IN A SECOND.

TO APPROVE, APPROVE.

NEED A MOTION? PROVE THE COMBO BALLOT.

NEED A SECOND? WHO? KEVIN? LOOKS EXCITED.

WE HAVE A BUNCH OF SECONDS.

CHRISTIAN, DO YOU WANT THIS ONE? SINCE YOU CAME IN PERSON TODAY, , WE'LL GIVE CHRISTIAN A SECOND.

AS PROOF THAT YOU WERE HERE FOR THE WHOLE MEETING.

THANK YOU FOR YOUR PARTICIPATION.

MM-HMM, ON THE MOTION TO APPROVE THE COMBO BALLOT, WE WILL START UP WITH THE CONSUMERS, WITH MARK.

ABOUT NICK.

THERE'S NO COLUMN FOR THUMBS UP.

GARRETT? YES.

AND GARRETT FOR BILL? YES.

AND THEN, UH, NARAJ FOR YOURSELF AND ERIC? YES.

I DON'T KNOW WHY YOU, I GUESS I WAS JUST AUTOMATIC.

YES, YES.

I'M SORRY, NICK.

DID I, I, I THOUGHT, I THOUGHT I GOT A NOD.

MY BAD, NICK.

IT WAS, YEAH, THAT'S OKAY.

PREFER TO BE ASKED BEFORE YOU'VE ARGUED.

CLEAR.

I'LL, I'LL, I'LL DELETE IT.

SO NOW YOU SEE THAT THE SALE IS EMPTY.

NICK, HOW WOULD YOU LIKE TO VOTE? FIRST I'M IN THE QUEUE WITHOUT, NOW I'M VOTING WITH, I DON'T KNOW.

NICK.

SO OFFICIALLY IT'S A YES, NICK, IT IS OFFICIALLY A YES.

THANK SIR.

I APOLOGIZE FOR HURTING YOUR FEELINGS ONTO THE CO-OPS.

BACK AGAIN, EMILY? YES.

COREY? CHRISTIAN? YES.

THANK YOU LUCAS FOR CLIFF? YES.

ONTO THE INDEPENDENT GENERATORS.

ON THE IPMS. JEREMY? YES.

THANK YOU, REMI.

YES, THANK YOU KEVIN.

YES SIR.

THANK YOU SIR.

SETH? YES.

THANK YOU ON THE IRES BILL.

YES, THANK YOU CHRIS.

JENNIFER.

YES, THANK YOU JAY.

IS JAY STILL WITH US? OKAY, MOVING ON TO THE IOUS.

KEITH? YES.

THANK YOU COLIN.

UH, DAVID'S GIVEN HIS VOTE TO JIM LEE.

YES, THANKS.

AND DAVID FOR RICHARD? YES, THANK YOU.

ONTO THE MUNIS, JOSE?

[05:50:01]

THANK YOU DAVID.

YES, THANK YOU ALICIA.

MOTION CARRIES UNOPPOSED.

AND RUSSELL? YES, THANK YOU.

THANKS COREY.

OKAY, WE DO

[15. Other Business]

HAVE TWO OTHER BUSINESS ITEMS. UM, THE FIRST IS REVISED REVISION REQUEST, SUBMISSION FORM, AND TECH REPORT FORM.

ANNE? YEAH, I'LL JUST GO OVER THIS REAL QUICKLY.

WE'VE HAD SOME, UH, MEETINGS WITH SOME BOARD MEMBERS TO DISCUSS CHANGES TO THE REVISION REQUEST FORMS AND ALSO THE TAC REPORT, UM, IN CONSIDERATION OF HOW THAT INFORMATION WOULD BE MORE HELPFUL TO THEM.

THERE'S NOT GONNA BE A TON OF CHANGES FOR US.

THE REASON FOR REVISION, WE'RE GONNA START TYING THAT TO THE STRATEGIC PLAN, THE 24 TO 28 STRATEGIC PLAN.

THERE ARE BROADER CATEGORIES, BUT THE BOARD MEMBERS DID PARTICIPATE IN WRITING THESE STRATEGIC PLANS.

SO I THINK IT'LL HELP THEM BETTER UNDERSTAND HOW THESE, UH, REVISION REQUESTS TIE IN.

UM, AND YOU'LL STILL HAVE YOUR ADMINISTRATIVE REGULATORY AND DIRECTIVE, UM, CATEGORIES FOR THE TAC REPORT.

YOU'LL SEE SOME CHANGES TO THAT.

UM, WE'RE GONNA START INCLUDING THE ESTIMATED IMPACTS ON THE FRONT COVER PAGE.

THAT'S JUST PULLING INFORMATION FROM THE IMPACT ANALYSIS THAT'S ALREADY THERE.

AND THEN ALSO SOMETHING THAT WE'VE ALREADY BEEN DOING IS EXPLAINING THE NO VOTES THAT COME OUT ATTACK, AND WE WILL HAVE A BOX FOR THAT AS WELL.

UM, EXPLAINING THE NO VOTES.

AND THEN UNDER THAT WE HAVE A TAC REVIEW JUSTIFICATION.

AGAIN, WE'RE ALREADY DOING THIS, BUT I THINK BOARD MEMBERS JUST WANNA MAKE SURE THAT TAC IS REVIEWING ALL THE INFORMATION THAT'S PROVIDED TO THEM AND MAKING THAT RECOMMENDATION TO THE BOARD.

SO WE'RE JUST KIND CHECKING OUT BOXES THAT WE DID REVIEW, THE OPINIONS THAT WERE SUBMITTED AND ALL OF THE COMMENTS, IA, ET CETERA.

SO JUST WANTED TO GIVE EVERYBODY A HEADS UP AND WE'LL START, UM, USING THESE NEW FORMS JANUARY 1ST.

ALRIGHT, ANN, AND YOU AND I SPOKE ABOUT THIS.

CAN YOU MAYBE JANUARY 1ST REVIEW HOW WE'RE GONNA IMPLEMENT THESE INTO THE PROCESS? 'CAUSE IT'S, IT'S SOME MORE INFORMATION FOR EACH VOTING ITEM.

AND WE'LL TRY TO MAKE THAT AS STREAMLINED AS POSSIBLE.

'CAUSE IT'S KIND OF A CHECKLIST FOR MAKING SURE WE HAVE A BUNCH OF NEW THINGS ON EACH VOTING ITEM AND THE EMPHASIS ON, UH, NO VOTES ESPECIALLY.

UM, WE'RE ONTO OUR LAST ITEM, CONTRACT FOR CAPACITY FOR WINTER.

DAVITA.

HI CAITLYN.

YOU I'LL DEBRIEF IN RESPECT OF EVERYBODY'S TIME ON NOVEMBER 17TH OR CAUGHT CANCELED IT'S REQUEST FOR PROPOSALS FOR CONTRACTS FOR CAPACITY FOR THE 20 23 24 WINTER PEAK LOAD SEASON.

AND THAT WAS DUE TO THE LIMITED AMOUNT OF CAPACITY THAT WAS OFFERED AND POTENTIALLY QUALIFIED.

WE RECEIVED OFFERS FROM THREE ENTITIES TOTALING 30.6 MEGAWATTS.

AND AFTER INITIAL EVALUATION OF QUALIFICATION, WE DETERMINED THAT ONLY 11.1 MEGAWATTS OF DEMAND RESPONSE WAS POTENTIALLY QUALIFIED.

UM, AND AS A REMINDER, ERCOT HAD BEEN SEEKING TO PROCURE UP TO 3000 MEGAWATTS OF CAPACITY IN MAKING THE DECISION TO CANCEL THE RFP.

WE CONSIDERED FACTORS INCLUDING THE VERY SMALL AMOUNT OF CAPACITY THAT MIGHT BE PROVIDED, AND THE MINIMAL RELIABILITY BENEFITS THAT WOULD'VE BEEN REALIZED FROM THAT SMALL PROCUREMENT, AND WEIGHED THAT AGAINST THINGS LIKE THE COST OF PROCUREMENT, INCLUDING COST OF ADMINISTRATION, AND THE INCREMENTAL DIGITAL CAPACITY AND COMPLEXITY FOR THE CONTROL ROOM OPERATORS.

FOR EXAMPLE, IF ALL OF THE 11.1 MEGAWATTS OF POTENTIALLY QUALIFIED CAPACITY HAD BEEN PROCURED, OUR PROBABILISTIC ANALYSIS INDICATED THAT THAT WOULD'VE RESULTED IN A LESS THAN FIVE ONE HUNDREDTHS OF 1% OF REDUCTION IN RISK FOR THE HIGHEST RISK HOUR OF WINTER.

SO BASED ON THAT ANALYSIS, WE ANNOUNCED A CANCELLATION AND WE DID THAT THROUGH A MARKET NOTICE AS WELL AS A FILING WITH THE PUC THAT YOU CAN VIEW IN PROJECT NUMBER 5 5 6 3 3.

UH, WE NOTE THAT WE AREN'T PROJECTING EMERGENCY CONDITIONS THIS WINTER, AND, UM, WE BELIEVE THAT THERE ARE ADEQUATE RESOURCE RESOURCES TO MEET THE DEMAND THAT IS EXPECTED.

UM, INDEED SUBSTANTIAL WINTER PREPAREDNESS AND OTHER GOOD IMPROVEMENTS HAVE BEEN IMPLEMENTED SINCE 2021.

FINALLY, I'LL CLOSE BY NOTING THAT WE'VE REVIEWED THIS RFP PROCESS AS INSTRUCTIVE, AND, UM, WE REALLY APPRECIATE THE FEEDBACK THAT WE HAVE RECEIVED, AND WE'RE, WE'RE TAKING IT SERIOUSLY.

WE APPRECIATE EVERYBODY'S INVOLVEMENT, INCLUDING IN, IN THE QUESTIONS THAT WE RECEIVED AS PART OF THE RFP PROCESS, THE STRONG ATTENDANCE OF THE WORKSHOP, AND THE ROBUST DISCUSSION THAT WAS HELD THERE.

AND WE LOOK FORWARD TO, UM, FURTHER DISCUSSING POSSIBLE REFINEMENTS OF THIS PROCESS.

I'M HAPPY TO TAKE ANY QUESTIONS OR, OR CARRY BACK QUESTIONS THAT ARE MORE APPROPRIATELY DIRECTED TOWARDS THE SUBJECT MATTER EXPERT.

DO WE HAVE ANY QUESTIONS?

[05:55:04]