[00:00:02]
ALL RIGHT, WE ARE GONNA GO AHEAD AND GET STARTED THIS MORNING.
UM, THANK YOU ALL FOR YOUR PATIENCE.
WE JUST HAD A LITTLE BIT OF A DELAY HERE.
VERY QUICKLY, I'M JUST GOING TO REMIND THOSE OF YOU SEATED HERE, SEATED REPS.
UM, YOU CAN PUT YOURSELF IN THE CHAT, UH, FOR DISCUSSION OR TO MAKE A MOTION, OR YOU CAN HOLD YOUR CARD UP AND ERIN IS OVER HERE IN THE CORNER AND SHE WILL ADD YOU INTO THE CHAT.
OF COURSE, THOSE OF YOU ON THE WEBEX, PLEASE GO AHEAD AND DO THAT YOURSELF.
UM, IF THE WEBEX ENDS FOR ANY REASON, PLEASE GIVE US JUST A FEW MINUTES AND WE'LL RESTART IT.
AND THEN, UM, THE FINAL REMINDER IS PLEASE MAKE SURE YOU SIGN IN IF YOU'RE HERE TODAY, SEATED REPRESENTATIVES, ERCOT STAFF, CONSULTANTS, UH, ANYONE HERE THAT WANTS TO BE CAPTURED IN THE MINUTES, PLEASE MAKE SURE YOU SIGN IN OUTSIDE.
AND WITH THAT, KAITLYN, WE DO HAVE A QUORUM AND ARE READY TO GET STARTED.
THIS IS OUR MARCH TECH MEETING.
AND, UH, WE ARE TRYING SOMETHING NEW WITH LUNCH, SO HOPEFULLY EVERYBODY GOT THE EMAIL FORWARDED AND IF IT'S SUCCESSFUL, WE CAN TRY AGAIN AND MAYBE FIND OTHER OPTIONS.
[1. Antitrust Admonition]
THE SCREEN.UM, YOU CAN GO AHEAD AND READ IT TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY.
PARTICIPANTS IN ERCOT ACTIVITIES SHOULD REFRAIN FROM PROPOSING ANY ACTION OR MEASURE THAT WOULD EXCEED ER CUTS AUTHORITY UNDER FEDERAL OR STATE LAW.
AND THERE'S MORE INFORMATION ON THE WEBSITE, UM, ON THAT LUNCH FRONT.
I THINK WHEN IT ARRIVES, WE WILL TRY TO FIND A GOOD STOPPING POINT SOMETIME SOON AFTER AND TAKE A 15 MINUTE BREAK AND, AND ALSO BRING KIND OF FOOD BACK TO THE TABLE SO WE CAN KEEP WORKING.
UM, TODAY FOR PROXIES AND ALT REPRESENTATIVES FOR ALT REPS, WE HAVE, UH, FOR JOHN PACKARD AT STACK, WE HAVE ALTERNATE REPRESENTATIVE LUCAS TURNER.
UM, FOR DAVID MERCADO AT CENTER POINT, WE HAVE ALTERNATE REPRESENTATIVE JIM LEE.
WELCOME JIM FOR PROXIES FOR RESIDENTIAL CONSUMER ERIC GOFF HAS GIVEN HIS PROXY TO NAVA AT OPEC FOR THE ENTIRETY OF TAC.
ERIC WILL BE REPRESENTING NEXTERA RESOURCES, ENERGY RESOURCES FOR NOGO 2 45 AND THE COMMERCIAL CONSUMER, UH, SEGMENT.
NICK FEBA OF CITY OF DALLAS HAS GIVEN HIS PROXY TO MARK DREYFUS AND THE IPM SEGMENT.
UH, REMI SRIN, UH, SHELL HAS GIVEN HER PROXY TO IAN HAILEY WITH MORGAN STANLEY.
WERE THERE ANY ADDED THAT I MISSED? ALL RIGHT, I THINK WE CAN GO AHEAD AND GET STARTED ON OUR AGENDA.
[2. Approval of TAC Meeting Minutes (Vote)]
WE HAVE APPROVAL OF THE FEBRUARY 14TH MEETING MINUTES.I'M NOT AWARE OF ANY EDITS OR COMMENTS.
CAN YOU CONFIRM THAT FOR ERCOT, SUSIE OR ANN? THAT'S CORRECT.
UNLESS THERE ARE FURTHER EDITS OR COMMENTS, I WOULD SUGGEST WE PUT THAT ON THE COMBO BALLOT.
DID WE RESOLVE THE SOUND ISSUE I'M SEEING IN THE QUEUE? YES.
[3. Meeting Updates]
MEETING UPDATES.SO WE DID HAVE THE FEBRUARY BOARD MEETING ON FEBRUARY 26TH AND 27TH.
UH, THAT WAS SINCE OUR LAST FEBRUARY TECH MEETING.
THE BOARD DID APPROVE ALL REVISION REQUESTS IN FRONT OF THEM.
THAT INCLUDED NPR 1186 AS RECOMMENDED BY THE ERCOT TWO 12 COMMENTS, WHICH HAD ADDRESSED THE REMAND AND DIRECTION FROM THE PUCT COMMISSIONERS.
AND THOSE, UH, REVISION REQUESTS THAT WERE APPROVED AT THE, THE FEBRUARY TECH AND FEBRUARY BOARD WILL BE CONSIDERED AT THE APRIL 11TH PUC MEETING.
[4. Review of Revision Request Summary/ERCOT Market Impact Statement/Opinions]
REVISION REQUEST SUMMARIES, WHICH IS THE, THE NEW PART, THE ERUPT MARKET IMPACT STATEMENTS.AND IM M OPINIONS AND I WILL TURN IT OVER TO ANN ALL.
SO THE REVISION REQUEST SUMMARY FOR THE, UH, REVISION REQUESTS THAT ARE ON THE T AGENDA THIS MONTH, THERE ARE SIX THAT ARE NO IMPACT WITH TWO OF THOSE WHERE IMPACTS ARE CAPTURED IN RELATED REVISION REQUESTS, WE HAVE 1205 THAT HAS A 80 TO ONE 20 K BUDGETARY IMPACT.
AND THEN NORE 2 45 THAT HAS, UM, THE FOUR 80 TO FIVE 70 ANNUAL RECURRING O AND M IMPACT.
WE HAVE THREE THAT FALL IN THE GENERAL SYSTEM AND PROCESS IMPROVEMENT CATEGORIES, AND THEN TWO THAT ARE, UH, STRATEGIC PLAN, OBJECTIVE ONE AND TWO THAT ARE STRATEGIC PLAN OBJECTIVE TWO.
UM, ERCOT DOES SUPPORT ALL OF THE REVISION REQUESTS, OF COURSE, EXCEPT FOR NORE 2 45 AND PG 1 0 5 AS RECOMMENDED BY ROSS.
AND, UM, THE MARKET IMPACT STATEMENTS ARE PROVIDED AS WELL.
AND THE IMM HAS NO OPINION ON ANY OF THE REVISION REQUESTS THAT ARE HERE AT TAG THIS MONTH.
[00:05:01]
OR COMMENTS ON ANY OF THOSE REVISION REQUEST SUMMARIES OR OPINIONS? ALRIGHT, I THINK WE CAN MOVE RIGHT ALONG.[5. PRS Report (Vote)]
WE ARE UP ON OUR PRS REPORT WITH DIANA COLEMAN.DIANA, I THINK THIS IS A SHORT REPORT, SO I WON'T STOP YOU.
JUST GO THROUGH THE WHOLE ONE SLIDE AND, AND THEN WE CAN TAKE, I THINK WE'LL HAVE TO TAKE THESE REVISION REQUESTS ONE AT A TIME THOUGH.
UH, DIANA COLEMAN WITH CPS ENERGY FOR THE MARCH PRS REPORT THIS MORNING.
WE HAVE TWO, UH, CONSIDERATIONS FOR ATTACK THIS MORNING TO LOOK AT.
THAT COMES TO US FROM N-G-P-R-S.
VOTED TO RECOMMEND APPROVAL OF THIS LANGUAGE IN FEBRUARY.
HAS REVIS, EXCUSE ME, HAS REVISED BY THE ENCORE COMMENTS AND REVISED BY SOME DESKTOP EDITS AT PRS.
AND THEN IN MARCH WE VOTED TO ENDORSE THIS TO TACK THIS IS NO COST, NO IMPACT, SO THERE'S NO COST ASSOCIATED WITH THIS CHANGE.
WE DID HAVE ONE OPPOSING OR ONE ABSTENTION FROM THE COOPERATIVE SEGMENT, UH, BY STUCK.
THEY FELT IT WAS COUNTER TO THEIR PREVIOUS, UH, REVISION REQUEST, WHICH WAS 1194.
AND THEN WE HAVE 1205, WHICH IS THE REVISIONS TO THE CREDIT QUALIFICATION REQUIREMENTS.
THIS IS, UH, A COST OF BETWEEN 80 AND $120,000 AND PRIORITY OF 2025 IN A RANK OF 45 20 PRS VOTED UNANIMOUSLY IN FEBRUARY TO RECOMMEND APPROVAL OF THE LANGUAGE AS AMENDED BY THE JANUARY 16TH LUMINANT COMMENTS.
AND THEN IN MARCH, WE VOTED UNANIMOUSLY TO ENDORSE AND FORWARD IT TO TAG WITH THE IA IN THE PRIORITY RANK THAT YOU SEE BEFORE YOU.
LET'S TAKE, UM, NPR 1197 FIRST.
SO WE WOULD BE LOOKING TO RECOMMEND APPROVAL OF NPR 1197 AS RECOMMENDED BY PRS IN THE THREE 20 PRS REPORT AS DIANA OUTLINED.
CAN WE, WOULD WE BE ABLE TO PUT THIS ON THE COMBO OR DO WE NEED A SEPARATE BALLOT ON THIS ONE? ALRIGHT, I SEE LUCAS TURNER IN THE QUEUE.
AND I SEE COREY HAS IT UP, BUT I THINK WE WILL NEED A MOTION AND A SECOND FOR APPROVAL OF NVR 1197 IS RECOMMENDED BY PRS.
CAN WE GET THAT MOTION? AND SECOND? ALRIGHT, MOTION FROM RICHARD SECOND.
FROM, UH, JENNIFER ALL GO AHEAD, COREY.
THE MOTION TO RECOMMEND APPROVAL OF 1197 AS RECOMMENDED BY PRS IN THE MARCH PRS REPORT.
WE WILL START UP WITH THE CONSUMERS WITH NJ.
YOU AND THEN, UH, N BUT FOR ERIC.
AND THEN MARK FOR NICK? YES, AGAIN, THANK YOU, SIR.
ONTO OUR INDEPENDENT GENERATORS.
BRIAN, I GOT YOUR YES IN CHAT.
ONTO OUR IPM, SETH NOT SEEING SETH.
HOW ABOUT JEREMY? YES, THANK YOU.
THANK YOU THEN IAN? YES, THANK YOU.
[00:10:02]
YES.ONE OPPOSED? ALL RIGHT, THANKS COREY.
UM, ANY QUESTIONS OR COMMENTS TO WRAP UP? 1197.
OKAY, SO WE COULD MOVE ON TO NPRR 1205.
WE DO HAVE A REVISED IMPACT ANALYSIS TO REVIEW.
I BELIEVE THIS ADDRESSES IMPLEMENTATION AND IT'S NOT A BUDGET CHANGE, BUT IT IS ON THE SCREEN.
AND DID SOMEBODY FROM
TROY'S GONNA, I SEE TROY RUNNING UP
UM, WE ADDED THE COMMENT THERE AT THE BOTTOM THAT COREY HAS PULLED UP INDICATING WE EXPECT TO MANUALLY IMPLEMENT THIS AND THEN FOLLOW UP WITH THE SYSTEM IMPLEMENTATION, UH, IN 2025.
UM, ALSO AT PRS, UH, I WAS ASKED ABOUT THE COST AND WE TOOK A SECOND LOOK AT THAT.
AND AFTER REVIEWING WITH SOME OF THE KEY GROUPS, WE DID ADJUST THE ACTUAL COST A LITTLE BIT, BUT IT STILL FALLS WITHIN THAT ESTIMATE, SO THERE'S NO CHANGE TO THE COST ESTIMATE.
ALRIGHT, IF THERE ARE NO QUESTIONS OR COMMENTS ON THIS, I THINK WE WOULD BE LOOKING TO PUT, UH, THIS ON THE COMBO BALLOT.
IT WOULD BE RECOMMENDED APPROVAL OF NPR 1205 AS RECOMMENDED BY PRS IN THE THREE 20 PRS REPORT AND THE 3 26 REVISED IMPACT ANALYSIS.
ALL RIGHT, COREY, I THINK WE CAN PUT THIS ON THE COMBO BALLOT.
ALL RIGHT, WE ARE MOVING RIGHT ALONG.
SO I THINK WE HAVE WRAPPED UP, UH, PRS, WE ARE ONTO
[6. Revision Requests Tabled at TAC (Possible Vote) (Part 1 of 2)]
REVISION REQUEST TABLED AT TECH.SO THE FIRST IS O-B-D-R-R 46, I BELIEVE THIS CAN REMAIN TABLED.
UM, WE ARE WAITING ON NPR 1188, WHICH IS STILL APPEAR AT PRS.
ANY QUESTIONS OR COMMENTS THERE? NEXT IS OBDR 51.
WE ARE WAITING ON NPRR 1216, WHICH IS TABLED AT PRS.
ANY QUESTIONS OR COMMENTS FOR THIS? AND THEN WE HAVE PICKER 1 0 5.
UM, THIS IS STILL, I BELIEVE WE ARE WAITING ON THE, THE COMMENTS TO THE COMMISSION AND THE WORK THERE AND WAITING ON FEEDBACK FROM THE COMMISSION SO WE CAN CONTINUE TO KEEP THAT TABLED.
THEN I BELIEVE AFTER NOER 2 45.
SO THAT LEAVES US WITH NOER 2 45, WHICH IS SORT OF OUR MAIN EVENT.
AND I WILL LET PARTIES GET READY.
UM, I WILL MAKE A COUPLE OF COMMENTS.
I KNOW PEOPLE, UM, WILL PROBABLY BE ANXIOUS TO GET IN THE QUEUE, SO, SO I'LL CALL ON THOSE IN ORDER.
BUT THIS IS, UM, THE NOUR ON INVERTER BASED RESOURCE RIDE THROUGH REQUIREMENTS.
AS, AS YOU'LL REMEMBER, WE HAD A ROBUST DISCUSSION.
AND I SEE YOU, BOB, I'LL GET, I'LL GET TO YOU AS SOON AS I'M DONE.
WELL, I SEE RICHARD ROSS IN THE QUEUE FIRST, ACTUALLY.
UM, SO, SO WE HAD A ROBUST DISCUSSION ON THIS IN JANUARY.
UM, WE, WE LET PARTIES KIND OF GO OFF FOR QUOTE UNQUOTE SETTLEMENT CONFERENCES TO BRING THIS BACK IN FEBRUARY.
WE HAD BRIEF DISCUSSION AND AGREED TO EXTENDED IT AT THAT TIME.
WHERE WE ARE TODAY IS WE HAVE, UM, THREE SETS OF COMMENTS FROM TWO PARTIES.
AND SO THOSE, THAT'S TWO SETS FROM ERCOT AND ONE SET FROM JOINT COMMENTERS WHO ARE NEXTERA SOUTHERN POWER, INVENERGY, AVAN GRID IN CLEARWAY.
UM, I KNOW WE ARE REALLY EAGER TO TALK ABOUT THIS, BUT I, I THINK IT'S IMPORTANT TO ALSO GET TAX OPINIONS ON THE RECORD.
UM, I THINK WE'RE SORT OF IN A NEW ROLE AS, AS WE'VE HAD A FULLY INDEPENDENT BOARD, AND THE PUC IS REVIEWING ALL THESE REVISION REQUESTS.
MY UNDERSTANDING IS THERE IS, YOU KNOW, A GREAT NEED TO, TO THE STATE FOR US TO DISCUSS, REVIEW THESE, YOU KNOW, USE ALL OUR POINTS OF VIEW ON RELIABILITY AND GET EVERYTHING ON THE RECORD HERE SO THAT THERE'S NO, YOU KNOW,
[00:15:01]
NEW INFORMATION COMING AT, AT THE BOARD AND AT COMMISSIONERS AS THEY MAKE THESE IMPORTANT DISCUSSIONS.SO, I THINK COMPROMISE IS A FEATURE OF THIS SYSTEM, BUT I, I WANNA MAKE SURE WE GET SORT OF EVERYTHING ON THE RECORD HERE.
UM, UNLESS THERE IS A, A MOTION TO, TO CALL THE QUESTION OR LIMIT DEBATE, WHICH WE WILL RESPECT.
UM, SO I'LL GO AHEAD AND TAKE UP THE QUEUE.
WE DID HAVE THOSE SETS OF COMMENTS.
IF, IF WE GET TO REVIEWING THOSE, WE THOUGHT ABOUT GIVING THOSE PARTIES MAYBE ROUGHLY 20 MINUTES EACH TO GO THROUGH THEIR POSITIONS AND COMMENTS.
UM, SORT OF EXCLUDING QUESTIONS.
I, I THINK WE'D LIKE TO BUCKET QUESTIONS INTO, YOU KNOW, SORT OF TOPIC AREAS SO WE'RE NOT POPCORNING BACK AND FORTH BETWEEN DIFFERENT SUBJECTS WITH QUESTIONS.
BUT, UM, WE WILL TRY TO ADJUST AS THIS DEBATE PLAYS OUT.
I WILL HONOR WHAT'S IN THE QUEUE, AND I WILL GO TO RICHARD ROSS FIRST.
WELL, YOU, YOU MAY NOT WANT MY COMMENTS YET.
I MEAN, I'M, I AM, I'M EAGER FOR US TO MOVE FORWARD WITH SOMETHING.
WE'VE BEEN WAITING ON THIS FOR SOME TIME.
WE'VE PROVIDED ADDITIONAL TIME FOR, UH, DISCUSSIONS.
I THINK ERCOT HAS MADE AN ADMIRABLE ATTEMPT TO TRY TO ACCOMMODATE AS MUCH AS THEY CAN.
UM, AND AT THIS POINT, I'M PREPARED TO MAKE THE MOTION TO APPROVE ERCO T'S, UH, COMMENTS, WHICH I THINK WOULD BE THE MAY, MARCH, UH, 20TH COMMENTS, UM, FOR APPROVAL.
IF YOU'RE NOT READY TO TAKE THAT MOTION RIGHT NOW, I'LL HOLD OFF ON THAT.
BUT THAT'S, THAT'S WHAT I'M PREPARED TO DO.
I, I THINK WE CAN TAKE THE MOTION AND CONTINUE DISCUSSION AND, AND WE DO THAT WHEN THERE'S MOTIONS ON THE TABLE, BUT WE WOULD NEED A SECOND FOR THAT MOTION.
IS THERE A SECOND? OKAY, SO THE SECOND WOULD BE FROM JIM LEE.
UH, APPRECIATE GETTING ME IN HERE.
AND ONE OF THE THINGS I WANNA DO IS I WANNA CHANGE THAT, AND I WANNA MAKE A MOTION TO AMEND, UH, THE, UH, THE MOTION THAT RICHARD ROSS MADE TO THE, UH, JOINT COMMENTER'S COMMENTS 2 45 WITH JOINT COMMENTER'S COMMENTS, THE LATEST.
AND I AM GOING TO GUESS THIS IS NOT A FRIENDLY AMENDMENT.
OKAY? SO THAT'S WHY I SAID A
SO WE, I THINK, SO WE WOULD NEED A SECOND ON THAT MOTION TO AMEND THE MOTION.
DO WE HAVE A SECOND ON THE MOTION TO AMEND? OKAY.
OH, AND, AND CHRIS HENDRICKS IN THE QUEUE AS WELL.
IS THERE DISCUSSION AT THIS TIME? DO WE WANT TO GO AHEAD AND TAKE THIS MOTION? DO WE WANT TO REVIEW COMMENTS? I THINK WE CAN GO AHEAD AND TAKE THE MOTION TO AMEND.
I WOULD THINK SO, YEAH, BECAUSE THE, ANY DISCUSSION THAT HAPPENS NEED TO BE RELEVANT TO RELEVANT THE MOTION.
SO I WOULD THINK WE WOULD TAKE THIS ONE NOW.
AND THEN ONCE THIS ONE'S DONE, HOWEVER IT SHAKES OUT WHATEVER YOUR MAIN MOTION ON THE TABLE THEN OPENS IT UP TO EVERYONE ELSE.
BUT FOR THIS SIDE MOTION, OR WHAT DO YOU CALL IT? SUPPLEMENTARY MOTION.
I DON'T KNOW IF ALL OF THAT WAS ON THE MIC.
SO WE, WE HAD A MOTION TO APPROVE, UM, THE ERCOT THREE 20 COMMENTS, AND THEN A MOTION TO AMEND THAT TO, UM, I BELIEVE THE, THE WHAT, WHAT DATE IS ON THE JOINT COMMENTER'S COMMENTS 3 22.
AND SO WE ARE GOING TO NOW GO TO A BALLOT TO, AND THE MOTION ON THE TABLE IS WHETHER WE'RE APPROVING THAT MOTION TO AMEND THE FIRST MOTION, BUT THERE'S DISCUSSION ON THE MOTION, RIGHT? SO I BELIEVE THE DISCUSSION HAS TO BE RELATED TO THAT.
SO THE DISCUSSION RIGHT NOW WOULD HAVE TO BE RELATED TO AMENDING THE FIRST MOTION.
SO I THINK WE'RE GONNA VOTE ON THE MOTION TO AMEND.
AND THEN WE KNOW WHAT THE MAIN MOTION IS, RIGHT? AND THEN DISCUSS THE MAIN MOTION THAT WE'RE THE SUBSTANTIVE MOTION.
DO YOU HAVE DISCUSSION ON THE MOTION TO AMEND? ALRIGHT, IAN, DO YOU HAVE DISCUSSION ON THE MOTION TO AMEND? UH, JUST A THOUGHT.
I THINK, UM, THERE MAY STILL BE PEOPLE WHO ARE MAKING UP THEIR MINDS ON THIS, AND I THINK THAT THE DIS THE MOTION TO AMEND WOULD BE INFORMED BY THE DISCUSSION OF, UH, WHICH SET OF COMMENTS TO, UH, THIS GROUP WOULD LIKE TO APPROVE.
UM, SO I'M NOT SURE IF THE BEST COURSE OF ACTION, UM, TO FACILITATE THAT IS TO, FOR THIS GROUP TO UNDERSTAND THAT THESE, THIS CONVERSATION WOULD BE TO DEBATE THAT, OR, UM, IF THE MOTION TO AMEND MOTIONS WOULD
[00:20:01]
LIKE TO WITHDRAW THAT SO THAT AN INFORMED VOTE ON THAT COULD BE TAKEN.UM, I'M, I'M OPEN, BUT I JUST THINK THAT, UH, I JUST THINK THAT WE'RE GONNA NEED TO HAVE THIS DISCUSSION BEFORE WE ACTUALLY VOTE.
I, SO WE, IAN, YOU WERE TOLD TO GET CLOSER TO THE MIC.
I THINK THAT THE SUMMARY WAS THAT PROPOSED.
WE GO OVER THE SUBSTANCE BEFORE TAKING THIS MOTION TO AMEND, BECAUSE IT DOES INFORM THE SUBSTANCE.
UM, I THINK, YOU KNOW, ROBERT'S RULES WISE, WE COULD TAKE A SUBSTANTIVE MOTION TO APPROVE JOINT COMMENTERS, AND THAT'S DIFFERENT THAN THE MOTION TO AMEND.
UM, BUT, BUT WHY DON'T, IF EVERYBODY'S OKAY WITH THAT, WHY DON'T WE GO AHEAD AND REVIEW THE COMMENTS BEFORE TAKING THESE MOTIONS UP.
SO LET'S START WITH ERCOT AND THEN GO TO JOINT COMMENTERS AND ER, ERCOT.
I BELIEVE YOU CAN KIND OF COVER BOTH SETS OF COMMENTS IN ONE GO.
UM, IF, IF YOU HAVE QUESTIONS THAT ARE VERY RELEVANT TO THE LANGUAGE OR THE ARGUMENT PRESENTED, I WOULD SAY GO AHEAD.
BUT I THINK IF WE'RE DEBATING SOME OF THE MAIN DECISION POINTS, MAYBE HOLD OFF ON THAT AND WE CAN TRY TO GROUP THOSE INTO TO DECISION POINTS.
STEVEN, ARE YOU UP FOR ERCOT? WELL, GOOD MORNING EVERY GOOD MORNING EVERYBODY.
THIS IS STEVEN SLIS, PRINCIPAL SYSTEM OPERATIONS IMPROVEMENT WITH ERCOT.
I'M HERE TODAY TO TALK ABOUT NOER 2 45, AND WE DID HAVE A PRESENTATION, UH, THAT I THINK ACTUALLY DIDN'T GET POSTED UNTIL JUST NOW.
UM, BUT IT, IT SHOULD BE ON THE PRESENTATION MATERIALS.
AND, AND REALLY THIS IS JUST TO GIVE KIND OF AN OVERVIEW AT A HIGH LEVEL OF KIND OF WHERE WE'RE AT, HOW WE GOT HERE, AND THE WORK THAT, UH, HAS OCCURRED OVER THE LAST COUPLE OF MONTHS.
FOR THOSE OF YOU THAT ARE PERHAPS NOT AWARE, NORE 2 45 WAS PUT IN PLACE AS A RESPONSE TO THE ODESSA DISTURBANCES THAT OCCURRED IN 2021 AND 2022.
THIS IS TO IMPLEMENT A NERC RECOMMENDATION THAT WAS MADE TO ERCOT TO ALIGN WITH THE MOST RELEVANT PARTS OF IEEE 2,800, AS RECOMMENDED BY AN EPRI ANALYSIS THAT WAS DONE COMPARED TO THE PROTOCOLS AND OPERATING GUIDE.
SO ERCOT TOOK THAT AND PRESENTED NORE 2 45 AT THE BEGINNING OF JANUARY OF 2023.
UH, DURING THAT TIME, AS IT'S GONE THROUGH THE PROCESS, NOGA 2 45 WA HAD A VERSION THAT WAS ADOPTED BY ROSS BACK IN SEPTEMBER OF LAST YEAR.
UH, THAT VERSION HARMS RELIABILITY, IT DOES NOT ADDRESS WHAT NOER 2 45 WAS INTENDED TO ACCOMPLISH.
AND SO ERCOT HAS BEEN WORKING CONTINUOUSLY WITH JOINT COMMENTERS TO TRY TO FIND, UH, SOME TYPE OF COMPROMISE LANGUAGE THAT BALANCES THE RISK THAT WE'RE TRYING TO MITIGATE WITH THE IMPACT ON THE GENERATOR OWNERS.
THAT BEING SAID, UH, FERC ORDER 9 0 1 DID COME OUT AS WELL, AND ERCOT TOOK THAT INTO CONSIDERATION.
UH, WE DID AN RFI AT THE END OF 2023 TO TRY TO GET INFORMATION FROM OEMS AND GENERATOR OWNERS OR RESOURCE ENTITIES TO TRY TO THOROUGHLY UNDERSTAND WHERE THERE WAS SIGNIFICANT CHALLENGES FOR THEM TO MEET REQUIREMENTS.
UH, SINCE THAT TIME, WE HAVE LOWERED THE REQUIREMENTS.
WE HAVE TRIED TO ACCOMMODATE WITH EXEMPTIONS AND EXTENSIONS ALL TO MAKE THE IMPACT LESS, BUT ESSENTIALLY WE HAVE, OH, I'M SORRY.
IF WE COULD GO TO THE NEXT SLIDE, PLEASE.
SO IT, WE HAVE WORKED WITH THEM.
WE'VE MADE SIGNIFICANT CONCESSIONS.
UH, WE DO LOOK AT WHAT WAS REFLECTED IN THE RFI RESPONSES AS THE MOST CHALLENGING REQUIREMENTS, AND WE PROPOSE TO BIFURCATE THOSE AND ADDRESS THOSE IN A, IN A SEPARATE NOER IMMEDIATELY TO FOLLOW THIS BECAUSE MORE TECHNICAL DISCUSSION IS NEEDED TO THOROUGHLY UNDERSTAND THOSE ASPECTS.
EVEN THE IEEE 2,800 STANDARD DRAFTING TEAM THAT IS CURRENTLY WORKING ON VERSION TWO RECOGNIZES THESE CHALLENGES AND IS AMENDING THE LANGUAGE IN IEEE 2,800 TO ACCOMMODATE IT.
WHERE WE'RE AT WITH OUR CURRENT COMMENTS IS AS FAR AS
[00:25:01]
ERCOT CAN GO, WE CANNOT MEET WHAT WE ARE CHARGED WITH IN THE PUCT SUBSTANTIVE RULES WITH ANY OTHER LANGUAGE.WE CANNOT MAKE ANY ADD ADDITIONAL CONCESSIONS.
WE HAVE PUT THIS NOER INTO A PLACE THAT IF YOU WERE TO APPROVE THE JOINT COMMENTER'S LANGUAGE, IT WOULD NOT ADDRESS THE RELIABILITY RISK.
IN FACT, IT WOULD NEGATIVELY GO FROM WHERE THE CURRENT REQUIREMENTS ARE AND IT WOULD MAKE THE REQUIREMENTS LESS BECAUSE THEY PUT IN LANGUAGE THAT EFFECTUALLY, IF THEY HAVE A PERFORMANCE FAILURE, EVEN TO TODAY'S STANDARDS, WOULD NOT HAVE TO RECTIFY IT, EXCEPT FOR WHAT THEY DETERMINE IS COMMERCIALLY REASONABLE ERCOT VIEWS THAT AS NEGATIVE TO RELIABILITY AND NOT ADDRESSING THE RISK THAT WE ARE TRYING TO ADDRESS.
WHEN WE LOOK AT THE EFFECTIVE DATES, ERCOT ORIGINALLY TRIED TO LOOK AT A 1 1 23 DATE FOR WHEN IEEE 2,800 REQUIREMENTS WOULD BE MANDATORY AND EFFECTIVE.
WE'VE MOVED THAT DATE TO 6 1 23 AND WE'VE PROPOSED TO MAINTAIN THAT DATE.
THE REASON BEING IS SINCE THAT TIME UP INTO WHAT IS JUNE OF PROPOSED FROM THE JOINT COMMENTERS, IT WOULD RESULT IN AN ADDITIONAL 20 TO 30 GIGAWATTS OF IBR THAT WOULD BE SUBJECT TO THE LOWER REQUIREMENTS AND NOT THE HIGHER REQUIREMENTS THAT ARE REQUIRED BY SECTION 2.9 0.1 OF OUR PROPOSED REQUIREMENTS AND IEE 2,800, WE DO ALLOW EXEMPTIONS AND EXTENSIONS TO ACCOMMODATE THIS PHASE IN PERIOD FOR THESE NEW HIRE REQUIREMENTS.
BASED ON FEEDBACK FROM THE JOINT COMMENTERS AND OTHER STAKEHOLDERS, WE FEEL THAT THIS IS REASONABLE AND STRIKES THE APPROPRIATE BALANCE FOR RELIABILITY AND THE IMPACT.
I JUST WANT TO POINT OUT THAT MOST OF ALL OF THE COMMENTS THAT WE HAVE RECEIVED HAVE BEEN THAT THIS IS REASONABLE, THIS IS A REASONABLE APPROACH AND IT ACCOMMODATES THE NEEDS.
WE'VE HAD DIFFERENT OEMS COME TO ERCOT AND SAY, WE'RE REALLY CLOSE.
WE JUST CAN'T MEET THIS SMALL PORTION.
AND WE THINK IT'S BEST FOR RELIABILITY IF YOU ALLOW EXEMPTIONS.
SO WE HAVE, AS LONG AS IT'S COMMERCIALLY OPERATIONAL BEFORE THE END OF 2026, THERE ARE EXEMPTIONS THAT ARE ALLOWED.
IF FOR SOME REASON YOU CAN'T MAKE 2026, YOU GET AN EXTENSION POTENTIALLY UP TO THE END OF 2028 OR THE BEGINNING OF 28, 28, I APOLOGIZE.
SO WE HAVE ALLOWED FOR A PHASE IN PERIOD, THE JOINT COMMENTERS, THEY PROPOSE THAT THERE'S ESSENTIALLY NO ENFORCEMENT FOR WRITE THE REQUIREMENTS ON LEGACY IBR.
SO IF THEY HAVE A PERFORMANCE FAILURE, THEY LOOK AT IT, THEY SAY, CAN I DO ANYTHING COMMERCIALLY REASONABLE? IF NOT, WELL THEN I NEED ANOTHER EXEMPTION.
SO YOU COULD HAVE A SYSTEMATIC JUST LOWERING OF REQUIREMENTS OVER TIME AND TO ERCOT, THAT'S UNTENABLE AND THAT IS NEGATIVE FOR RELIABILITY.
THE FAULT DISTURBANCE RIDE THROUGH REQUIREMENTS VERSUS NON-FAT IS WHAT'S AT DEBATE RELATED TO PHASE ANGLE ROFF, UH, RATE OF CHANGE OF FREQUENCY AND MULTIPLE EXCURSION REQUIREMENTS.
IF YOU HAVE BEEN FOLLOWING INVERTER BASE RESOURCE WORKING GROUP, IF YOU HAVE BEEN FOLLOWING IEE 2,800, THIS HAS BEEN A MATTER OF DEBATE THAT HAS OCCURRED AND CLARIFICATIONS ARE NEEDED.
WE NEED TO UNDERSTAND HOW THESE ENTITIES ARE USING THOSE PARAMETERS AND PROTECTION SYSTEMS. WE NEED TO GET CONSISTENCY IN HOW IT'S MEASURED SO THAT WE CAN CREATE THE APPROPRIATE REQUIREMENTS.
THIS TAKES ADDITIONAL TECHNICAL DISCUSSION THAT WE NEED TO HAVE.
ERCOT IS PROPOSING TO ADDRESS THOSE IN A FUTURE NODAL OPERATING GUIDE.
REVISION REQUESTS, THE JOINT COMMENTERS ARE PROPOSING TO HAVE EXEMPTIONS.
AND SO ERCOT HAS TRIED TO PUT GUARDRAILS IN THE FACT THAT WE HAVE OPENED UP AS PART OF OUR CONCESSIONS TO ALLOW EXEMPTIONS FOR ALL LEGACY IBR RESOURCES VERSUS WHAT WE PROPOSED TO STOP THAT AT JANUARY 16TH, 2014.
THAT OPENS NOT 16 BUT 66 GIGAWATTS OF IBR THAT CAN HAVE SOME TYPE OF EXEMPTION IN AN ATTEMPT TO TRY TO ALLOW FOR CIRCUMSTANCES WHERE THEY DIDN'T
[00:30:01]
KNOW THAT THEY WERE NON-COMPLIANT.TODAY THEY FIND OUT THAT THEY ARE, BUT IT'S A MARGINAL RISK TO THE, TO THE RELIABILITY OF THE ERCOT SYSTEM.
WE WANT TO BE REASONABLE, WE WANT TO ALLOW THOSE THINGS, BUT WE PUT GUARDRAILS IN PLACE SO THAT WE CAN ENSURE THE RELIABILITY FOR THE CUSTOMERS OF TEXAS.
THE JOINT COMMENTERS PROPOSE TO ALLOW EXEMPTIONS TO REMOVE THOSE GUARDRAILS THAT HAVE BEEN INSERTED BY ERCOT, WHICH CREATES A VERSION THAT IS UNRELIABLE FOR ERCOT.
THE LIMITED TECHNICAL, EX TECHNICAL EXEMPTIONS, UH, THERE ARE SOME CAVEATS TO THAT.
IT, THOSE EXEMPTIONS NEED TO BE MODELED ACCURATELY.
AND THE REASON THIS IS IMPORTANT, WE WANT TO BE VERY CLEAR TO ALLOW EXEMPTIONS MEANS THAT WE HAVE TO TAKE THAT RISK AND WE HAVE TO ADDRESS IT IN OTHER WAYS.
SO WE HAVE TO MODEL THAT RISK.
WE HAVE TO SHOW THOSE AS CONTINGENCIES, AND THEN WE HAVE TO PROTECT THE ERCOT SYSTEM.
THAT MEANS WITH EXEMPTIONS COMES ADDITIONAL CONGESTION, ADDITIONAL STABILITY LIMITATIONS.
IF THERE IS A HARDER FREQUENCY DECLINE, IT'S GOING TO IMPACT THE, THE EQUIPMENT.
IF YOU HAVE SYNCHRONOUS GENERATION AND YOU HAVE A SHARPER FREQUENCY DECLINE, IT'S GONNA PUT STRESS ON YOUR EQUIPMENT.
WE WANT TO BE VERY TRANSPARENT THAT THERE ARE EFFECTS AND COSTS ASSOCIATED WITH ALLOWING THESE EXEMPTIONS SO THAT EVERYBODY IS FULLY AWARE.
WE ALSO WANT TO SAY THAT ERCOT EXPECTATION IS THAT THE EXEMPTIONS THAT WE'VE ALLOWED WILL RESULT IN ABOUT TWO TO FOUR GIGAWATTS BASED ON THE BEST INFORMATION WE HAVE FOR IBR IN SERVICE BEFORE 2014.
AFTER THAT, WE HAVE PUT GUARDRAILS IN PLACE.
AND OUR EXPECTATIONS IS THAT IT WOULD BE A VERY SMALL AMOUNT BECAUSE ESSENTIALLY FROM OUR PERSPECTIVE, IF YOU'RE ASKING FOR AN EXEMPTION BASED ON HOW THE REQUIREMENTS ARE WRITTEN AFTER JUNE, JANUARY OF 2014, IT TECHNICALLY MEANS YOU'RE NON-COMPLIANT TODAY TO TODAY'S REQUIREMENTS.
ERCOT WANTS TO BE VERY CLEAR THAT THESE CONCESSIONS ARE SIGNIFICANT, AND WE HAVE DONE THEM IN A MATTER OF TRYING TO ALLOW THIS NOER TO PROGRESS.
THERE IS A LOT, A LOT OF FIXES THAT ARE OUT THERE THAT OEMS ARE WAITING ON TO GET THIS NOER DONE SO THAT THEY CAN IMPLEMENT.
AND THAT IS WHY ERCOT HAS MADE SUCH SIGNIFICANT CONCESSIONS.
BUT THE JOINT COMMENTER'S COMMENTS GO TOO FAR.
THEY WILL NOT SUPPORT RELIABILITY AND THUS OUR ERCOT OPPOSES THEM.
WE INCLUDED THE COMMERCIALLY REASONABLE EFFORT SECTION AND WE WANT TO BE VERY TRANSPARENT THAT THIS IS A, SUCH A HUGE CONCESSION THAT EVERYONE NEEDS TO GIVE CAUTION TO IT OR COP MADE THIS CONCESSION ONCE AGAIN TO TRY TO GET NOER 2 45 TO GO THROUGH.
BUT THESE LIMITED TECHNICAL EXEMPTIONS MAY BE ALLOWED IF TECHNICAL FEASIBLE IMPROVEMENTS ARE NOT COMMERCIALLY REASONABLE.
SO THAT MEANS YOU MAY HAVE SOME FIXES THAT ARE AVAILABLE, SOME IMPROVEMENTS, AND THEY DEEM IT TO BE NOT COMMERCIALLY REASONABLE.
AND SO THAT, THAT PUTS RISK ON THE SYSTEM.
PUCT WILL DETERMINE THE EXTENT TO WHICH IBR OR WGS MUST MITIGATE THE PERFORMANCE FAILURE.
THIS IS AN IMPORTANT CONCEPT BECAUSE WHILE ERCOT IS GOING TO SCREEN THOSE EXEMPTIONS, WE'RE GONNA TRY TO ALLOW REASONABLE EXEMPTIONS TO TAKE PLACE.
THERE WILL BE A, A PROCEDURE SO THAT IF THE JOINT COMMENTERS OR OR GENERATOR OWNERS DON'T AGREE WITH ERCOT ASSESSMENT, IF WE DENY AN EXEMPTION REQUEST, THAT THEY'RE ABLE TO QUICKLY TAKE THAT TO THE COMMISSION TO BE ABLE TO GET THEM TO WEIGH IN ON THAT MATTER.
AND JOINT COMMENTERS WORKED WITH ERCOT TO MAKE SURE THAT THAT LANGUAGE WAS A FASTER PROCESS THAN SAY, UH, USING THE A DR PROCESS.
WE WANTED TO MAKE SURE THAT, UH, WE TOOK THEIR OTHER FEEDBACK ON ALIGNING OF REPORTS.
WE MODIFIED THE TABLES A AND B, UH, TO ENSURE NO REDUCTION OF VRT REQUIREMENTS FOR NEW IBR.
I DON'T THINK THE JOINT COMMENTERS NECESSARILY HAD ISSUE WITH IT EXCEPT THAT IT WAS A LAST EDITION.
WE ARE ONLY ADDING IN A VERY SMALL PORTION OF THE VOLTAGE RIDE THROUGH CURVE TO MATCH WHAT OUR EXISTING CURVES ARE TODAY, BELOW 0.25 PER UNIT.
THAT WILL MAKE THE TESTING PROCESS MUCH
[00:35:01]
MORE EFFICIENT.AND THESE ARE REQUIREMENTS THAT ARE IN PLACE TODAY FOR EXISTING LEGACY IBR.
WE DID ADD LANGUAGE DESCRIBING PROCESSES FOR EXEMPTIONS EXTENSIONS AND APPEALS TO GIVE MORE CONSISTENCY AND AS MENTIONED TO SPEED UP THE A DR PROCESS, SOME ADDITIONAL COMMENTS THAT WE WANT TO MAKE.
ERCOT SET THE 6 1 23 SGIA DATE, UM, ON PURPOSE THAT WAY THERE WAS TRANSPARENCY THAT THE IMPACT OF MOVING THAT DATE TO 6 1 24 WOULD RESULT IN ADDITIONAL 20 TO 30 GIGAWATTS NOT REQUIRED TO MEET THE NEW REQUIREMENTS.
WE, WE WANT TO MAKE SURE THAT WE'RE VERY CLEAR.
I BS WITH THE COMMERCIAL OPERATIONS DATE BEFORE 12 31 26 CAN REQUEST LIMITED TECHNICAL EXEMPTIONS AFTER 12 31 26.
YOU CAN HAVE A REQUESTED LIMITED EXTENSION UP TO THE END OF 2028.
WE ALSO ARE SAYING THAT WE DO NOT SUPPORT THE COMMERCIALLY REASONABLE CONCEPT.
UH, WE DON'T DO THAT BECAUSE REMOVING SIGNIFICANT RELIABILITY RISK IN WGR RIDE THROUGH PERFORMANCE FAILURES POSE TO GRID SHOULD OUTWEIGH COMMERCIAL CONSIDERATIONS.
IF YOU LOOK AT OUR LATEST COMMENTS, I THINK THIS IS THE MOST SIGNIFICANT THING FOR EVERYBODY TO UNDERSTAND.
THIS IS NOT WHERE SOME HAVE AN ISSUE WITH HOW ERCOT IS TAKING AN APPROACH TO A SET OF REQUIREMENTS.
THIS IS NOT EEAS, THIS IS NOT EVEN WINTER STORM URI.
THIS IS NOT WHERE IT WAS COLD.
WE HAVE RIDE THROUGH, WE HAVE, UH, COLD WEATHER FAILURES AND WE HAVE EEAS AND WE HAVE CONTROLLED LOAD SHED.
THIS IS THE TYPE OF RISK THAT IF THE FAULT HAPPENS AND YOU HAVE ENOUGH IBR THAT DON'T RIDE THROUGH WITHIN 30 SECONDS, IT'S A COMPLETE SYSTEM BLACKOUT.
I WANT Y'ALL TO UNDERSTAND THAT THAT'S THE TYPE OF RISK THAT WE'RE DEALING WITH HERE.
THERE IS NO TIME FOR OPERATORS TO RESPOND TO.
THIS IS THE MOST BASIC AND FUNDAMENTAL PART OF ELECTRIC SYSTEM RELIABILITY, THAT NORMAL DISTURBANCES, LIGHTNING STRIKES, WHATEVER HAPPENS TO CAUSE A FAULT.
CURRENT INTERRUPTING DEVICES ARE ABLE TO ISOLATE THAT FAULT AND GENERATORS ARE ABLE TO STAY ONLINE AND CONTINUE TO GENERATE.
THIS IS FUNDAMENTAL TO ELECTRIC SYSTEM RELIABILITY AND TO TOY AROUND WITH IT, TO NOT GIVE IT THE APPROPRIATE SERIOUSNESS AND TO NOT DO EVERYTHING THAT WE CAN TO ENSURE THAT GENERATORS CAN TRANSITION RELIABLY IS NOT, IS NOT A GOOD CONCEPT.
I WANT TO MAKE SURE THAT THERE IS COMPLETE TRANSPARENCY TO THAT PARTICULAR ISSUE.
STEVEN? YES? CAN I, CAN WE STAY ON THE PREVIOUS SLIDE FOR A SECOND? SURE.
CAN YOU HELP US RECONCILE ERCOT POSITION ON THE COMMERCIALLY REASONABLE? UM, I, I HAVE TO SAY I WAS A LITTLE CONFUSED AND AND DISAPPOINTED IN THE COMMENTS.
I I I JUST NEED TO UNDERSTAND HOW WE ARE PUTTING IN WRITING.
WE ARE INCLUDING COMMERCIALLY REASONABLE EFFORTS, BUT IN ERCOT POSITION WHO'S INCLUDED IT, YOU DO NOT SUPPORT THOSE EFFORTS OR YOU THINK THAT'S DETRIMENTAL TO RELIABILITY? I JUST, YOU KNOW, AS, AS A TAC BODY AND THEN FOR THE, THE BOARD AND THE COMMISSION, I WANNA RECONCILE THAT POSITION AT ERCOT.
'CAUSE I, I WANNA MAKE SURE THAT THE TECH'S REALLY UNDERSTANDING ERCO T'S POSITION ON THIS, UM, TO THE EXTENT THAT, YOU KNOW, WOULD, WOULD NEED TO CHANGE LATER.
AND SO ON THE COMMERCIALLY REASONABLE EFFORTS THAT THE POSITION IS YOU DID GET COMFORTABLE INCLUDING IT OR, OR YOU DID NOT GET COMFORTABLE INCLUDING IT.
I THINK THAT INTERNAL TO ERCOT, THERE'S A LOT OF, UH, INCONSISTENCIES.
I THINK ERCOT STAFF, YOU'LL NOTICE JOHN SCH SMALL'S NAME IS NOT ON ANYMORE, UH, AS AN ENGINEER.
HE, HE COULDN'T SIGN OFF ON IT.
THE ONLY WAY THAT WE REASONABLY APPROACH THIS IS THAT THE, THE BENEFITS WE GET BY THE SOFTWARE CHANGES AND THOSE THINGS THAT THEY CONSIDER COMMERCIALLY REASONABLE WILL BE GOOD ENOUGH TO HOLD OFF THE SEVERE, THE SEVERE CATASTROPHIC TYPE EVENT.
THAT'S THE, THAT'S THE REASONING OF WHY AND WE'RE TRYING TO GET THIS NOER UNLOCKED.
SO IT IS A CONCESSION THAT IN OUR LANGUAGE IS VERY LIMITED
[00:40:02]
TO THIS PARTICULAR ISSUE.AND WHAT WE WANT TO BE VERY CLEAR IS IT SHOULD NOT BE EXPANDED UPON SO THAT ALL THESE OTHER THINGS IN THE PROTOCOLS AND OPERATING GUIDES ARE THUS WE'VE OPENED THE DOOR.
IF IT'S COMMERCIALLY REASONABLE HERE, IT SHOULD BE COMMERCIALLY REASONABLE FOR EVERYTHING ELSE WE'RE TRYING TO ADDRESS THIS PARTICULAR ISSUE.
SO WE'RE TRYING TO PUT ALL SORTS OF CAUTION FLAGS ON THIS THAT PUTTING THIS LANGUAGE IN IS A ONE-TIME DEAL.
UNDERSTOOD AND UNDERSTOOD THAT THE, THEY WILL HAVE THAT PERSPECTIVE ON, YOU KNOW, THEIR INVESTMENT CASE FOR, FOR RELIABILITY AND THEIR VISION.
I JUST WANTED TO MAKE SURE IN KO'S COMMENTS WE WERE GETTING KO'S VIEW ON, ON THE COMMERCIALLY REASONABLE EFFORTS.
SO I'M GONNA TRY TO SPEED THROUGH THIS A LITTLE BIT 'CAUSE I KNOW I'M AT THE END OF MY TIME.
WE DO WANT TO MAKE SURE THAT BY US MOVING FORWARD WE CAN GET THE BENEFITS OF PARAMETERIZATION AND THE COMMERCIALLY REASONABLE UPGRADE KITS GOING THAT ARE SITTING THERE WAITING FROM, BASED ON WHAT WE'VE HEARD FROM OEMS. LET'S GET THOSE THINGS IN PLACE BECAUSE THE RISK IS CONTINUING, WE WANT TO ALLOW NOER 2 45 TO PROGRESS AND BIFURCATE THE TECHNICALLY COMPLEX PARAMETERS OF ROW CALL PHASING WILL JUMP MULTIPLE EXCURSIONS.
WE DON'T WANT TO SIT HERE AND PUT A BUNCH OF EXEMPTIONS THAT ARE GOING TO BASICALLY TAKE THE GUARDRAILS OFF AND, AND PUT US INTO A PLACE WHERE THIS NOER IS UNRELIABLE.
WE WANT TO ALLOW A FEASIBLE PATH FORWARD FOR IBR WITH THE SGIA BEYOND 6 1 23 SO THAT WE CAN START PHASING IN IEEE 2,800 ADOPTION.
WE WANT TO BE VERY TRANSPARENT THAT WITH THE EXEMPTIONS COMES A REMAINING AMOUNT OF RELIABILITY RISK THAT ERCOT IS OBLIGATED TO ADDRESS AS PLANNER AND OPERATOR FOR THE ERCOT SYSTEM.
THAT WILL RESULT IN IMPACTING OTHER ENTITIES, BOTH FROM A CONGESTION AND STABILITY LIMIT AND POTENTIALLY THE OTHER SIDE WITH HAVING TO INSTALL NEW TRANSMISSION PROJECTS, WHICH PASSES COSTS ON TO CUSTOMERS.
WE ALSO WANT TO MAKE SURE THAT SOME NEWLY MODELED LIMITATIONS AND REPEATED PERFORMANCE FAILURES MAY REQUIRE NEW CONTINGENCIES THAT WILL CREATE ADDITIONAL THERMAL CONGESTION AS WELL.
SO THE KEY TAKEAWAY HERE IS THAT THE PROPOSED EXEMPTIONS WILL HELP EXPEDITE THE ADOPTION OF NOGA 2 45 AND IEE 2,800.
BUT THERE IS AN EXPENSE ASSOCIATED WITH CONTINUED RELIABILITY RISK IN THE ASSOCIATED IMPACTS.
WE WANT TO BE VERY CLEAR TOO THAT OUR PROPOSAL IS PART OF AN OVERARCHING SET OF CHANGES.
NOT ONLY DO WE NEED NOER 2 45, WE NEED ADDITIONAL GRID STRENGTHENING WITH THE SIX SYNCHRONOUS CONDENSERS THAT HAVE BEEN PROPOSED, WE NEED TO CONTINUE TO PROGRESS WITH GRID FORMING CAPABILITY ADOPTION.
WE NEED TO MAKE SURE THAT MODELING AND TESTING REQUIREMENTS ARE ENHANCED TO ACCOMMODATE NOER 2 45 AND KNOWN ISSUES.
'CAUSE WE CONTINUE TO SEE MODELING NOT REFLECT ACTUAL REAL WORLD BEHAVIOR.
WE NEED TO MAKE SURE THAT NOER 2 55 PROGRESSES AS WE'RE GOING TO DISCUSS LATER TODAY, SO THAT WE HAVE THE APPROPRIATE DISTURBANCE MONITORING EQUIPMENT TO MONITOR THE PERFORMANCE AND BE ABLE TO MAKE CORRECTIVE ACTIONS QUICKLY TO OFFSET THE RISK OF EXEMPTIONS.
IT MUST BE ACCOMPANIED BY CLEAR EXPECTATIONS FOR OPERATING RESTRICTIONS, FOR FOR FAILURES THAT POSE RELIABILITY RISK.
THIS IS ANOTHER ISSUE THAT JOINT COMMENTERS HAVE RAISED.
WE WANT TO BE VERY CLEAR THAT ERCOT HAS IN OUR CORE MISSION TO ENSURE RELIABILITY.
THE PECT SUBSTANTIVE RULES REQUIRE THAT WE ASSURE THAT RELIABILITY AS AN INDEPENDENT ORGANIZATION AND TO TAKE AWAY AS OUR AUTHORITY TO BE ABLE TO ENSURE THE RELIABILITY OF THE ERCOT INTERCONNECTION IS SOME OF THE JOINT COMMENTERS COMMENTS PROPOSED IS UNTENABLE TO ERCOT.
IT IS AGAINST EVERYTHING THAT WE TRY TO DO.
WE HAVE TO ENSURE THE RELIABILITY OF THE ERCOT SYSTEM AND WE INTEND TO CONTINUE TO USE OUR AUTHORITY IN THAT SPACE AS REASONABLE AND AS NECESSARY TO ENSURE THE LIGHTS STAY ON.
MODELS AND CONTINGENCIES NEED TO ACCURATELY REFLECT LIMITATIONS.
SO EVERY TIME THERE'S A PERFORMANCE FAILURE, THE MODELS NEED TO BE UPDATED TO CORRECT, UH, ANY TYPE OF ISSUES THAT SHOW UP.
AND WE HAVE TO ENSURE THAT PROPER ACTIVE AND REACTIVE POWER CONTROLS COORDINATION TAKES PLACE.
THESE ACTIONS REQUIRED TO OFFSET RISK COULD
[00:45:01]
LEAD TO ADDITIONAL OPERATIONAL AND PLANNING IMPACTS SUCH AS CONGESTION AND SYSTEM IMP IMPROVEMENTS.SO THE KEY TAKEAWAY IS THAT THE PROPOSAL ASSUMES A WILLINGNESS TO ACCEPT MORE LIABILITY RISK, ADOPTING OTHER RISK OFFSET ACTIVITIES AND OTHER SYSTEM COST IMPACTS ARE ACCEPTABLE TO EVERYBODY.
WE DID UPDATE THE TIMELINE FOR EVERYBODY'S REFERENCE THAT THE NEW CHANGES PROPOSE.
SO YOU CAN COMPARE THIS TO THE LAST VERSION.
THIS REFLECTS A, A PROCESS THAT IF TAC APPROVES TODAY, ERCOT BOARD IN APRIL, PECT APPROVAL IN JUNE WITH THE JULY 1ST, UH, NOER 2 45 IN EFFECT.
AND THERE IS SEVERAL KEY MILESTONES THERE, UH, AS FAR AS EXTENSIONS DUE DATES, ANNUAL, UH, CHECKS, UH, FOR COMMERCIAL REASONABLE EFFORTS AND, UM, THE END OF TIMES WHERE YOU CAN APPLY FOR EXEMPTIONS AND EXTENSIONS AS WE PHASE IN IEE 2,800.
IN SUMMARY, ERCOT STRONGLY RECOMMENDS TAC ADOPT ERCOT 3 19 24 COMMENTS.
ERCOT HAS SERIOUS CONCERNS WITH THE COMMERCIALLY REASONABLE CONCEPT AS PRIORITIZING ONE MARKET SEGMENTS COMMERCIAL, UH, INTERESTS OVER SOCIETAL RISK OF UNCONTROLLED LOSS OF ERCOT SYSTEM.
HOWEVER, CONTINUED DELAYS TO IMPLEMENTING NOGA 2 45 WILL CONTINUE EXPOSING ERCOT SYSTEM TO AN UNACCEPTABLE LEVEL OF RISK.
WE CONTINUE RECOMMENDING ENTITIES MAXIMIZE RIDE THROUGH CAPABILITIES WITHOUT DELAY TO MINIMIZE RELIABILITY RISK TO THE ERCOT SYSTEM AND ADDITIONAL RULE CHANGES WILL BE NEEDED TO ADDRESS THE MORE COMPLEX TECHNICAL RULES.
SO WITH THAT BEING SAID, UH, I'LL PAUSE FOR QUESTIONS.
OKAY, UH, JENNIFER, AND THEN I SEE JOHN IN THE QUEUE.
DO WE KNOW WHAT PERCENTAGE OF THE IBR IN QUESTION ARE AT RISK OF NEEDING HARDWARE UPDATES SINCE THAT SEEMS TO BE WHERE THE COMMERCIALLY REASONABLE LANGUAGE AND INCREMENTAL RISK OF EXTREME FAILURE BECOMES MOST IMPORTANT? LIKE WHAT YES TO THE WHAT, HOW MUCH RISK ARE WE TALKING ABOUT? TO THE BEST OF MY INFORMATION, UM, THERE IS PROBABLY TWO TO THREE GIGAWATTS OF UPDATES THAT ARE READILY AVAILABLE TODAY THAT I'VE GOT KIND OF SOME INDICATION OF PRICING AND IT SEEMS LIKE THEY WOULD PROBABLY BE COMMERCIALLY REASONABLE FOR THEM TO DO THAT.
SORRY, TO CLARIFY, WHAT PERCENTAGE ARE SOFTWARE UPGRADES THAT ACCOMPLISH WHAT PERCENTAGE OF THE RISK AND THEN WHAT PERCENTAGE ARE HARDWARE UPGRADES? AND THEN LIKE OF THAT? I THINK THAT'S A SECTION YOU'RE SPEAKING TO.
YEAH, I WOULD SAY THAT PROBABLY, UM, OUT OF 66 GIGAWATTS, PROBABLY ABOUT TWO THIRDS OF THOSE WILL HAVE SOFTWARE UPDATES THAT CAN IMPROVE THEIR PERFORMANCE OUT OF THE OTHER THIRD.
UM, THERE'S PROBABLY, LET'S JUST SAY THAT THERE'S 20 GIGAWATTS LEFT OUT OF THE 20 GIGAWATTS THAT ARE LEFT.
THERE'S 15 THAT DON'T EVEN NEED TO DO ANYTHING.
THEY, THEY DON'T NEED TO MAKE ANY CHANGES.
THERE'S ABOUT FIVE WHERE THEY WOULD HAVE TO HAVE MORE SIGNIFICANT HARDWARE UPGRADES AND SO THEY'LL APPLY FOR THE EXEMPTIONS.
SO WE'RE TALKING ABOUT 8% OF THE IBR IS IN QUESTION THAT POSE THE MOST SIGNIFICANT RISK AND IS WHERE THE GAP IN THESE COMMENTS IS LARGELY FOCUSED? IS THAT A I I THINK THE FAIR ASSESSMENT, I THINK THE GAP IN THE COMMENTS IS MOVING FORWARD, HAVING THE APPROPRIATE PERFORMANCE REQUIREMENTS.
ERCOT HAS ACCOMMODATED THE CONCERNS ABOUT COST OF UPGRADES.
WHAT THE JOINT COMMENTERS ARE SEEKING IS A BROADER SET OF EXEMPTIONS MOVING FORWARD SO THAT IF THEY HAVE A PERFORMANCE FAILURE TO EVEN WHAT THEY TELL US THAT THEY CAN DO, THAT THEY DON'T HAVE TO GO IN AND MAKE CHANGES LATER.
SO THAT'S REALLY AT THE HEART OF THE DIFFERENCES OF OPINION THAT'S REMAINING.
AND YOU THINK BY ADOPTING ERCOT VIEW, WE WOULD CAP THE RISK AT THIS 8% OF POTENTIALLY NON-PERFORMING IVRS? YES.
AND THEN WE HAVE A MECHANISM FOR NEWLY DISCOVERED RISKS TO GET MITIGATED AS THEY
[00:50:01]
BECOME PRESENT TO US.AND YEAH, BEFORE I'LL, I'LL GET TO THIS QUEUE, BUT BEFORE WE GET TOO FAR DOWN, I DO WANNA GIVE JOINT COMMENTERS AND OPPORTUNITY TO GO THROUGH THEIR COMMENTS.
I THINK WE DO HAVE A FEW OUTSTANDING ISSUES.
THE, THE EFFECTIVE DATE FOR THE NEW IBR, THE, YOU KNOW, HA HARDWARE VERSUS SOFTWARE UPGRADES AND COMMERCIALLY REASONABLE.
UM, AND THEN, YOU KNOW, SOME, SOME OF ERCOT AUTHORITY AND, AND DISCONNECTING AND, AND PERFORMANCE AND OPERATIONAL BASED REQUIREMENTS.
SO I THINK WE CAN TRY TO TACKLE THOSE AFTER WE HEAR FROM BOTH PARTIES.
BUT I'LL, I'LL GO AHEAD AND GO THROUGH THIS QUEUE.
JOHN RUSS HUBBARD, I CAN WAIT UNTIL WE GET TO THE LATER PORTION.
MARK SPENCER, DO YOU WANNA SAY YOUR COMMENT? YES, THANK YOU.
UM, I GUESS MY QUESTION HERE IS, IS THE LEGACY EXEMPTION AND IS IT A FOREVER EXEMPTION OR IS ERCOT GOING TO REQUIRE THE LEGACY ASSETS TO REPLACE THEIR INVERTERS AT THE END OF THAT ACCOUNTING LIFE? NOT THE ACTUAL LIFE, BUT THE ACCOUNTING LIFE? 'CAUSE MY UNDERSTANDING IS THAT AN INVERTER TYPICALLY HAS A LIFE OF ABOUT 15 YEARS, SO AT THAT TIME IT SHOULD BE FULLY DEPRECIATED AND THERE SHOULD BE A BUDGET FOR REPLACEMENT.
AND UNLESS THERE'S SOME, YOU KNOW, SOME TETHER, THEN I THINK THAT THE RESOURCE COULD POTENTIALLY A REPLACEMENT CONDUCT NOT OPERATING.
IS THAT MY UNDERSTANDING? SO I'M, I'M GONNA ANSWER YOUR QUESTION TWO DIFFERENT PARTS.
SO THE WAY THE RULES ARE CONSTRUCTED, IF THEY DO A REPLACEMENT, THEY HAVE TO MEET THE NEW REQUIREMENTS IF THAT REPLACEMENT HAPPENS AFTER JANUARY 1ST, 2028.
SO IT ALLOWS FOR A LOT OF CHANGES UP UNTIL THAT POINT IN TIME TO COME INTO COMPLIANCE IF YOU WEREN'T WITHOUT HAVING TO TRIGGER THE HIGHER REQUIREMENTS.
BUT AFTER THAT GRACE PERIOD, AT THE END OF THE ASSET'S LIFE, IF THEY REPLACE THEIR EQUIPMENT, WE WANT THEM TO REPLACE IT WITH THE LATEST AND GREATEST CAPABILITIES AND BE ABLE TO MEET THOSE NEW REQUIREMENTS.
WE HAD ONE OEM IN PARTICULAR TELL US FOR A TYPE THREE WIND TURBINE THAT THEY CAN GET REALLY CLOSE, BUT THEY CAN'T FULLY MEET THOSE REQUIREMENTS FOR IEEE 2,800 WITH THEIR TYPE THREE DESIGN.
AND SO WE ALLOWED A SPECIFIC CARVE OUT FOR THAT.
SO A TYPE THREE WIND TURBINE CAN HAVE A PORTION OF THE RIDE THROUGH CURVE WHERE THEY ALMOST MEET IT EVEN AFTER THEY REPLACE IT OR REPOWER AND HAVE AN EXEMPTION TO ACCOMMODATE THAT SHORT FALLING.
BUT FOR THE MOST PART, OTHER THAN THAT, UH, IF YOU REPLACE, YOU WOULD NEED TO MEET THE NEW REQUIREMENTS.
JUST TO FOLLOW UP THOUGH, I MEAN, I THINK WHAT I'M HEARING THOUGH, IT'S THE RESOURCE OWNER'S CHOICE WHEN THEY DECIDE TO REPLACE, IT'S NOT SET ON THE ACCOUNTING LIFE OF ASSET.
IF THEY EXTEND THE LIFE OF THEIR ASSET SOMEHOW BEYOND WHATEVER DURATION, THEY CONTINUE TO HAVE THE LOWER REQUIREMENTS FOR THAT PERIOD OF TIME, WHEN THEY TRIGGERED THE GIM PROCESS AND PLANNING GUIDES TO REPOWER TO REPLACE THAT IS WHEN THEY WOULD BE SUBJECT TO THE NEW REQUIREMENTS.
AND THIS, UH, THIS KIND OF FEEDS INTO THE, THE ISSUES THAT YOU WERE FRAMING UP, BUT I JUST WANTED TO ASK, UM, BOTH STEVEN, BOTH YOU AND THE JOINT COMMENTERS IN THEIR RESPONSE TO, UH, DIAL IN ON THE DISCONNECTION AUTHORITY QUESTION BECAUSE I, FOR THE RECORD, STEVEN, I I AGREE WITH YOU.
ERCOT NEEDS TO HAVE THAT CAPABILITY TO DISCONNECT RESOURCES IF THEY DO POSE A RELIABILITY THREAT THAT AGREED, THAT'S A, A FOUNDATIONAL ISSUE.
UM, HOWEVER, I HAD NOT READ INTO THE JOINT COMMENTERS FRAMEWORK THAT IT WOULD UNDERMINE THAT.
UM, YOU KNOW, BUT I THINK, AND YOU RECOGNIZE THIS, I'VE READ IN YOUR COMMENTS, YOU, YOU, THAT'S NOT WHAT YOU WANT TO DO.
IT'S, IT'S THE LAST RESORT THAT ERCOT WOULD EVER WANT TO GO TO.
AND I THINK THAT PRUDENCE IN EX IN EXERCISING THAT AUTHORITY IS, IS, IS VERY WELL JUSTIFIED.
UM, BUT IN YOUR PRESENTATION HERE, UH, I TOOK AWAY THAT YOU READ THE JOINT COMMENTER'S APPROACHES UNDERMINING THAT AUTHORITY.
SO I WANTED TO, TO GET YOUR PERSPECTIVE ON THAT.
IF YOU COULD JUST DOUBLE DOWN ON, ON THAT ARGUMENT.
AND THEN I'D LIKE TO HEAR FROM THE, THE JOINT COMMENTERS TO COUNTER THINKING THAT, UM, SO REALLY A LOT OF OUR RESPONSE THERE IS BASED ON THEIR COMMENTS THAT THEY THINK THAT THAT NEEDS TO BE SOMETHING THAT IS PASSED ON TO THE COMMISSION.
AND WE EXERCISE THAT AUTHORITY TODAY.
[00:55:01]
WE HAVE GENERATORS THAT HAVE SUB SYNCHRONOUS OSCILLATIONS THAT CAN CREATE ALL SORTS OF SIGNIFICANT DAMAGE.IF WE ALLOWED THAT TO PERSIST, YOU WOULD HAVE POTENTIALLY OTHER GENERATORS DAMAGED.
AND WE HAVE TO PROTECT THE ERCOT SYSTEM FOR THAT.
AND SO WHEN IT POSES THAT TYPE OF RISK, WE HAVE, UM, ASKED THEM TO OPEN THE BREAKER UNTIL THEY CAN ADDRESS THE ISSUE.
WE'VE HAD OSCILLATIONS JUST IN BASIC REACTIVE CONTROLS THAT CAN BECOME AMPED.
AND IF YOU HAVE THAT IN THE STABILITY ISSUE, IT CAN RESULT IN A, IN A, A LOCALIZED, UH, INSTABILITY THAT OCCURS.
WE'VE TAKEN THEM OFFLINE FOR THAT.
AND SO WHAT WE'VE DONE IS INSTEAD OF HAVING A WHOLE ENTIRE PARAGRAPH AND SECTION ABOUT OPERATIONAL RESTRICTIONS AND HOW WE WOULD EMPLOY THAT, AND, AND IT WASN'T JUST FOR A REAL TIME RELIABILITY ISSUE, IT WAS FOR A BROADER SET OF THINGS.
WE'VE TAKEN THAT FEEDBACK AND WE TOOK ALL THAT LANGUAGE OUT.
WE, WE PUT IT IN THERE TO TRY TO BE VERY TRANSPARENT.
THEY TOLD US A WHILE BACK, Y'ALL NEED TO HAVE GUARDRAILS.
WE TRIED TO IDENTIFY THOSE GUARDRAILS AND ULTIMATELY IT WAS, WE DON'T EVEN WANT IT IN THERE.
SO WE TOOK IT OUT, WE TOOK A PARAGRAPH FROM PROTOCOL SECTION 3 15 4 WHERE IT TALKS ABOUT I IRRS THAT ARE AT LESS THAN 10% OF REACTIVE CAPABILITY THAT ERCOT CAN REMOVE THOSE.
AND WE JUST TOOK THAT LANGUAGE AND JUST MIRRORED IT SO THAT IF WE HAVE A RELIABILITY ISSUE IN REAL TIME, WE SEE SOMETHING HAPPEN.
WE HAD A BUNCH OF THINGS NOT RIGHT THROUGH, THERE'S A LOT OF SEVERE WEATHER IN THE AREA, WE NEED TO HAVE THEM STAY OFF AND, AND GET IT FIXED AND NOT CREATE A WORSE ISSUE.
WE WANT TO BE VERY TRANSPARENT.
THAT'S WHAT WE'RE GOING TO DO.
AND I THINK THAT THEY STILL TOOK EXCEPTION TO EVEN THAT LANGUAGE, WHICH WE TRIED TO LIMIT EVEN FURTHER.
IT, IT MAY JUST BE A PERCEPTION, BUT EVERY TIME WE TOOK A STEP, IT SEEMED LIKE IT WASN'T GOOD ENOUGH.
WE NEED, WE, WE, WE, WE NEED TO TAKE IT OUT ALL THE WAY.
SO I THINK THAT'S WHERE WE ENDED UP WITH EVEN WITHOUT THAT LANGUAGE.
I THINK TO YOUR ULTIMATE POINT, NED, WE'D STILL EXERCISE THAT AUTHORITY.
I WANNA MAKE SURE JOINT COMMENTERS GET A CHANCE TO, TO GO THROUGH THEIR COMMENTS.
BILL AND AHI, ARE THESE SPECIFIC TO ERCOT QUESTIONS OR DO THEY START TO GET INTO KIND OF THE, THE POINT COUNTERPOINT? I HAVE A COUPLE QUESTIONS FOR ERCOT.
UM, WHY DON'T WE DO THAT AND THEN WE'LL, WE'LL, I PROMISE WE'LL GET BACK TO THIS.
I WANNA MAKE SURE ERIC AND AND JOINT COMMENTERS GET TO GO THROUGH THEIR POSITION.
YEAH, SO WHY DON'T WE GO TO BILL, UM, AND THEN AHI DE DEPENDING ON WHAT YOUR QUESTION IS.
THOSE TWO ARE SPECIFIC TO ERCOT, SO LET'S TAKE THOSE QUICKLY AND THEN, UM, WE'LL, WE'LL PUT ERIC NEXT IN THE QUEUE TO PRESENT JOINT COMMENTERS.
THANKS CAITLYN AND STEVEN APPRECIATE ALL THE WORK THAT ERCOT HASS PUT IN ON THIS.
UM, IT, IT IS DOES, IT'S RECOGNIZED REALLY ON, ON THE STAKEHOLDER SIDE THAT ERCOT IS REALLY, UM, ATTEMPTED TO TRY TO FIND A COMPROMISE.
AND SAME WITH THE JOINT COMMENTERS.
I THINK THERE'S A LITTLE BIT OF DISAPPOINTMENT ON MY PART THAT HOPING THAT WE WOULD REACH A COMPROMISE HERE.
AND I REALIZE THAT YOU GUYS HAVE, UH, REACHED A POINT WHERE THERE'S, THERE'S NO FURTHER FURTHER PROGRESS IS LIKELY TO BE MADE.
SO WE NEED TO MAKE A DECISION.
UM, WHAT MAKES THIS SO CHALLENGING IS AN ISSUE FOR A PARTY LIKE US THAT'S PRETTY NEUTRAL.
OUR MAIN CONCERN IS HAVING A RELIABLE SYSTEM, RIGHT? WE ARE A COMPETITIVE MARKET ENTITY.
UH, COMPETITIVE MARKET NEEDS A RELIABLE SYSTEM.
THE CHALLENGE WHEN WEIGHING THE SEVERITY OF THE RELIABILITY RISK, UM, IS REALLY OVER THE, AND THIS IS MORE OF A GENERAL STATEMENT.
I MEAN, SINCE THERE HAVE BEEN A LOT OF PROCESS CHANGES, A LOT OF RULE CHANGES, UH, THAT HAVE BEEN REALLY EXPLAINED AS ALMOST LIKE A RELIABILITY CRISIS, RIGHT? WE'VE, WE'VE GREATLY INCREASED THE AMOUNT OF ANCILLARY SERVICE PROCUREMENTS.
WE'VE RESTRICTED THERMAL PLANT OUTAGES.
UH, THERE ARE A LOT OF DIFFERENT, UM, CHANGES THAT HAVE BEEN MADE.
SO IT'S HARD TO ASSESS THE SEVERITY OF THE RELIABILITY RISK HERE.
SO WHEN YOU BRING THIS TO US AND YOU MAKE THAT CLAIM, AND WE THINK ABOUT ALL THE CHANGES IN THE LAST FEW YEARS, IT'S, IT THAT'S WHERE IT'S A STRUGGLE IS HOW, HOW IMPORTANT IS THIS? HOW MUCH DO YOU REALLY NEED IT? UM, VERSUS HEY, BILL, WE'RE GETTING SOME FEEDBACK THAT IT'S HARD TO HEAR YOU AND I'VE NOTICED, UM, SOME PEOPLE ARE KIND OF FAR AWAY FROM THE MIC TODAY.
SO THAT'S BEEN ONE POINT OF, UM,
[01:00:01]
I THINK DIFFICULTY FOR, FOR US AS A NEUTRAL, NEUTRAL, NEUTRAL PARTY TRYING TO MAKE A DECISION ON THIS.NOW WE'VE RECOGNIZED THE ACTUAL EVENTS THAT HAVE OCCURRED, RIGHT? AND THAT IS DIFFERENT FROM A THEORETICAL RISK, RIGHT? YOU MENTIONED SSO, UM, THE SSO RISK, I THINK IS ONE OF A LOWER PROBABILITY EVENT.
WE'VE ACTUALLY SEEN EVENTS OCCUR ON THE SYSTEM HERE.
UM, SO YOUR COMMENTS, THE ONES THAT WERE FILED YESTERDAY, WHAT YOU'VE MADE TODAY, I MEAN THAT, THAT CARRIES A LOT OF WEIGHT, RIGHT? BUT WE ALSO RECOGNIZE, AND YOU KNOW, WE'LL GET TO THE JOINT COMMONERS IN A SECOND, IS PUTTING INVESTMENT, EXISTING INVESTMENT AT RISK IS ALSO SOMETHING THAT WE CAN'T, WE HAVE TO, YOU KNOW, THAT IS A VERY DIFFICULT DECISION.
SO IN TERMS OF RELIABILITY RISK AND ASSESSING, UH, THE IMPACTS ON THE SYSTEM, UM, JENNIFER TOUCHED ON THE COMMERCIALLY REASONABLE POINT, WHICH I HAD THE SAME QUESTION ABOUT.
UH, WHAT I'VE HEARD, AND I'D LIKE TO GET SOME CLARITY ON, IS THE IMPACT TO EXISTING RESOURCES AND THE POTENTIAL FOR PERMANENT RETIREMENTS.
I'VE HEARD THAT THROUGH DISCUSSIONS.
DO YOU HAVE A SENSE OF IF THE ERCOT VERSION OF THIS GOES THROUGH, WHICH IS WILL CERTAINLY IMPROVE THE WRITE THROUGH REQUIREMENTS AND CAPABILITIES, ARE YOU GONNA ACTUALLY LOSE GENERATION AS A RESULT OF THAT PERMANENTLY? OR DO YOU THINK THAT'S JUST A THERE HIGHLY CORRELATED? I I THINK WE, WE HAVE SOME FEEDBACK WE NEED TO MUTE IN THE BACKGROUND.
SO BACK TO THE QUESTION, UH, IS ADAM, A CONCERN FOR YOU IS THAT, HAVE YOU DONE ANY TYPE OF ASSESSMENT ON THE POTENTIAL FOR PERMANENT RETIREMENTS AS A RESULT OF THIS? TO THE BEST OF OUR KNOWLEDGE, THERE SHOULD BE NO RETIREMENTS.
WE, WE'VE ACCOMMODATED EXEMPTIONS AND EXTENSIONS TO BASE, EVEN THOUGH ERCOT STAFF SAID UHUH, NO, DON'T OPEN IT UP TO THE 66 GIGAWATTS.
ARE WE ABLE TO MUTE FROM OUR SIDE? OKAY, THANKS SUSIE.
WE, WE OPENED UP THE EXEMPTIONS TO EVERYBODY AND THAT THAT'S, THAT'S THE REAL BIG CONCERN THAT WE HAVE.
SO WE PUT GUARDRAILS ON, RIGHT? WE SAID, OKAY, IN THESE CIRCUMSTANCES WE'RE NOT.
AND WHAT REALLY, REALLY CONCERNS ME, BILL, IS BECAUSE OF HOW WE SUGGESTED THE LANGUAGE THAT THEY CONTINUE TO WANT TO PUSH.
IT REALLY MAKES US UNEASY THAT THERE'S SOMETHING THAT HASN'T BEEN FORTHCOMING TO US, THAT THERE'S SOME RISK THAT'S OUT THERE THAT WE HAVEN'T BEEN TOLD THAT THEY'RE AWARE OF AND THEY'RE TRYING TO PROTECT THEMSELVES AGAINST.
AND BECAUSE WE ALLOW EXEMPTIONS, WE ALLOW EXTENSIONS, WE, WE, WE WANT TO MAKE SURE THAT WE DO OUR DUE DILIGENCE, THAT WE'RE NOT GOING TO ALLOW SOMETHING THAT'S GROSSLY GONNA CAUSE A RELIABILITY ISSUE, BUT BY AND LARGE, WE'RE GOING TO ALLOW THOSE EXEMPTIONS AS THEY COME IN AND THEY REQUEST IT.
WE'VE ALLOWED THAT FOR ALL THE IBR IF THEY HAVE AN ISSUE WITH ROW CALL PHASE ANGLE, THOSE TYPES OF THINGS.
AFTER THE RFI CAME BACK THAT SAID THEY, THE OEM SAID WE HAVEN'T EVEN TESTED THESE, WE DON'T EVEN KNOW, WE DON'T MONITOR THIS.
THEY'RE JUST TRYING TO HAVE SOME BLANKET EXEMPTION SO THAT IF, IF THEY HAVE A PERFORMANCE FAILURE, THAT THEY HAVE A PROTECTION THAT THEY DON'T HAVE TO GO BACK AND ADDRESS IT UNLESS IF IT'S COMMERCIALLY REASONABLE FOR THEM TO DO SO AND PERHAPS ALLOW ADDITIONAL EXEMPTIONS.
SO IT'S LIKE WE HAVE NO FLOOR, WE HAVE NO BASIS TO GO FORWARD AND SAY WE CAN ASSURE RELIABILITY BECAUSE THEY WANT TO PUT IN A CONSTRUCT THAT CAN LOWER THE FLOOR OVER TIME.
AND THAT'S THE CORE ISSUE THAT WE HAVE WITH THE LANGUAGE.
AND THEN THANK YOU FOR THAT RESPONSE.
SECOND QUESTION YOU MENTIONED IN YOUR SLIDES, THERE ARE TRANSMISSION SOLUTIONS THAT WE'RE CONSIDERING THE SYNCHRONOUS CONDENSER PROJECT, AND THIS IS REALLY GETS TO THE HEART OF THE RELIABILITY RISK VERSUS THE COST AND WHO PAYS THE COST.
CONSUMERS ARE GONNA BE FUNDING THE, THE SYNCHRONOUS CONDENSER PROJECT, BUT YOU DON'T FEEL THAT THAT IS EITHER ONE COMING QUICK ENOUGH OR TWO SUFFICIENT ENOUGH TO ADDRESS THE, THE ENTIRE CONCERN.
AND IF YOU, IF WE DON'T DO ERCOT COMMENTS, DO YOU THINK YOU'LL NEED ADDITIONAL SYNCHRONOUS
[01:05:01]
CONDENSER PROJECTS? WE'LL BE ADDITIONAL COST TO CONSUMERS IF WE GO WITH JOINT COMMERCE VERSION VERSUS ERCOT? IF YOU DON'T GO WITH ERCOT COMMENTS, THERE'S, THERE'S NO NUMBER OF SYNCHRONOUS CONDENSERS THAT'S GONNA SOLVE THE PROBLEM.IT IS AN ALL TOGETHER ISSUE THAT HAS TO BE DONE.
AND I JUST WANT TO BE VERY CLEAR.
WE HAVE LOWERED, WE HAVE CONCEDED AS FAR AS WE CAN IN, IN ALLOWING EXEMPTIONS AND EXTENSIONS TO GO FURTHER.
WE JUST CAN'T SUPPORT, YOU'RE GONNA HAVE TO TAKE MY NAME OFF.
WE'RE GONNA HAVE TO SEE IF THERE'S ANYBODY ELSE ON THE ERCOT SIDE THAT'S WILLING TO SIGN ON THOSE COMMENTS.
AS AN ENGINEER, IT'S UNETHICAL.
I CAN'T GO AND TELL YOU IT'S GONNA BE RELIABLE WITH ANY FURTHER CONCESSIONS.
I JUST CAN'T, I CAN'T PUT MY HEAD DOWN AT NIGHT, CAN'T LOOK MY FAMILY IN THE EYE AND SAY, WE'VE DONE WHAT WE NEED TO, TO KEEP YOUR LIGHTS ON.
UM, THANK YOU SO MUCH FOR, UM, PROVIDING VAST MAJORITY ALREADY HUNDRED PERCENT REQUIRED.
WE KNOW THAT STATE, WHAT WE DON'T KNOW, WHICH IS VERY IS THAT TODAY A DIFFERENT APPROACH TO, THERE IS ALREADY A PRESUMPTION IN THAT YOU DON'T SHOW UP IN APARTMENT WITH INVESTMENT, A CONTRACT WITH A SUPPORT YOUR FAMILY IF YOU ARE GOING BE ALWAYS COMES FROM WRONGDOING ON A SINGLE EVENT, NOT BASED ON MULTIPLE, BASED ON SPECIFIC DEFENSE WHICH HAVE ROBUST LITIGATION, MEANINGFUL WHEREVER TO ACTUALLY STANDARD AS AN ENGINEER POSITION.
I WORK HUNDRED EVERY DAY THAT THE SAME YOU DO PEOPLE WHO WORK WITH THEM ON WHICH PROPOSITION, WHATEVER POSITION TO BE REASONABLE ENOUGH THAT CONTRACT SOME POSITION.
WE'VE BEEN RECEIVING COMMENTS, UH, SINCE WE POSTED THIS BACK IN JANUARY OF 2023.
AND WE HAVE INCORPORATED FEEDBACK THROUGH MULTIPLE ITERATIONS.
WE'VE ISSUED AN RFI FROM OEMS AND IF YOU LOOK AT OUR COMMENTS POSTED, UH, YESTERDAY, YOU WILL SEE ALL A LISTING OF ALL THE MEETINGS THAT WE HAD WITH JOINT COMMENTERS TO TAKE THEIR FEEDBACK AND IMPLEMENT IT INTO THE VERSION THAT WE PROVIDED.
YOU'LL ALSO SEE IN THERE THAT THERE IS, THERE WAS NOT ONE EVENT, THERE HAVE BEEN MULTIPLE EVENTS APPROACHING 30 WITHIN OUR INTERCONNECTION ALONE, NOT ACCOUNTING FOR ALL OF THE OTHER INTERCONNECTIONS WHERE THEY'VE SEEN SUCH RIDE THROUGH FAILURES INCLUDING A BLACKOUT IN AUSTRALIA.
SO TO MINIMIZE THE RISK, I JUST AM COMPELLED TO MAKE SURE THAT EVERYBODY IS CLEAR.
THIS IS MULTIPLE EVENTS THAT CONTINUE TO OCCUR ON THE ERCOT SYSTEM.
[01:10:01]
RIGHT, WHEN THE CONDITIONS LINE UP, YOU HAVE THE RISKS THAT WE'VE, UH, REVEALED, REVEALED TO EVERYBODY COULD OCCUR, WHICH IS AN INSTANTANEOUS LI UH, LOSS OF THE ERCOT SYSTEM.CONTRACT IN VIOLATION CONSTITUTION.
SO WE HAVE, UH, TAKEN THE FEEDBACK FROM THE JOINT COMMENTERS AND WE'VE TRIED TO INCORPORATE IT TO THE EXTENT POSSIBLE THAT STILL PROVIDES THE RELIABILITY BENEFIT THAT NOGA 2 45 PRESENTED.
UH, I'M SURE THAT THERE ARE OTHER, UH, LEGAL INSTANCES WHERE SOCIETAL RISK, UM, AND EVEN IF YOU LOOK AT THE PSTT SUBSTANTIVE RULES, UM, THERE ARE INSTANCES WHERE YOU NEED REQUIREMENTS IN PLACE TO ASSURE RELIABILITY, EVEN WHEN THERE MIGHT BE A COST IMPACT TO MARKET PARTICIPANTS.
WE TAKE THAT SERIOUSLY AND WE HAVE PUT FORTH THE BEST LANGUAGE THAT WE CAN.
OKAY, I SEE A QUESTION OR COMMENT FROM ROBERT.
ROBERT, DO YOU WANT TO COMMENT? ALL RIGHT, LET'S MOVE ON TO JOINT COMMENTERS.
WILL THAT BE ERIC GOFF SPEAKING ON BEHALF OF NEXTERA ENERGY RESOURCES? YES.
UM, NEXTERA IS ONE OF THE JOINT COMMENTERS.
UM, THERE ARE OTHERS THAT ARE AVAILABLE, BUT I'M GONNA TAKE THE LEAD IN THIS CONVERSATION.
JENNIFER, CAN WE HOLD YOUR QUESTION UNTIL THEY PRESENTED? OKAY.
I JUST FEEL COMPELLED AFTER THE LAST COMMENT TO SAY THIS HAS BEEN A CONVERSATION FOR ALMOST TWO YEARS NOW.
SO TO COME IN AND SAY THAT THERE IS SOME SORT OF LIKE SUBSTANTIAL BACK, UH, LOOKING COMPLIANCE REQUIREMENT, I THINK IS UNFAIR TO THE WORK THAT ERCOT HAS DONE ON THIS WORK ON 2 45.
AND SO I DO THINK WE NEED TO BE CLEAR THAT THE IBR REQUIREMENTS HAVE BEEN PART OF AN ONGOING CONVERSATION, AND THIS IS THE CULMINATION OF THAT CONVERSATION.
SO THE COMPLIANCE DATE REFLECTS THE, THAT PERIOD OF CONVERSATION POST ODESSA.
UM, AND I JUST WANT TACK TO BE ALIGNED THAT THE RETROACTIVE NATURE OF THIS IS BECAUSE OF THOSE TIMELINES.
UM, SO THANK YOU EVERYONE, UM, FOR YOUR TIME AND CONSIDERATION ON, ON THIS TOPIC.
SO FAR, THIS HAS BEEN AS, AS, AS A PARENT, A REALLY CHALLENGING CONVERSATION, UH, FOR US.
BUT I DO THINK THAT, UM, THIS IS WHAT OUR PROCESS IS FOR.
THIS IS WHY WE SHOW UP TO THESE MEETINGS.
AND SO I I APPRECIATE EVERYONE'S DILIGENCE ON THESE TOPICS.
SO I JUST WANNA START BY SAYING THAT THE JOINT COMMANDERS COMPLETELY UNDERSTAND ERCOT PERSPECTIVE ON, ON THE RISK WE'RE TRYING TO ADDRESS HERE.
UM, AND WE CONTEND THAT OUR APPROACH IS THE BETTER WAY TO RESOLVE IT, NOT JUST FOR ECONOMICS AS ARCHAD HAS STATED, BUT ALSO FOR RELIABILITY.
UM, AND I'LL GET INTO WHY THAT'S THE CASE.
UM, I, I THINK THAT THERE'S A FUNDAMENTAL ISSUE WITH HOW ERCOT HAS ADDRESSED OUR CONCERNS, WHICH IS WHEN, UH, STEVEN SAID EVERY TIME WE TOOK A STEP, THEY SAID IT WASN'T GOOD ENOUGH.
AND AS I'LL GET INTO IN THE COMMENTS, I BELIEVE THAT'S THAT'S BECAUSE THEY HAVEN'T UNDERSTOOD THE REASONING BEHIND OUR POSITION AND THE PRINCIPLES BEHIND IT.
SO OUR APPROACH IS A RISK-BASED APPROACH THAT WILL RESULT IN A MORE ROBUST RELIABILITY OUTCOME THAN ERCOT BECAUSE IT ADDRESSES THE ISSUES THAT WE KNOW ABOUT, UM, HAS A PATH TO ADDRESSING OTHER UNKNOWN ISSUES, AND IT PROTECTS INVESTOR CONFIDENCE TO CONTINUE TO INVEST IN THIS MARKET AT A TIME WHEN WE NEED AN EXTENSIVE AMOUNT OF NEW INVESTMENT, UH, FROM PEOPLE THAT, THE SAME GROUPS OF PEOPLE THAT ARE INVESTING IN, IN THESE RESOURCES.
UM, SO WE DON'T SEE THIS AS A, AS JUST A COMPROMISE.
UM, WE SEE IT AS A, A BETTER OUTCOME, AND WE DESIGNED IT WITH THE, WITH THE HOPES THAT, UH, TAC AND ERCOT WOULD SEE THAT.
UM, SO FIRST OF ALL, WE REQUIRE IBR TO TAKE THE MEDICINE THAT WE KNOW CURE THE DISEASE SOFTWARE AND SETTINGS CHANGES ARE THE WAY TO ADDRESS THE KNOWN AND WELL-STUDIED
[01:15:01]
ISSUES IN THE ODESSA AND THE PANHANDLE WIND ISSUES.UM, AND WE HAVE ERCOT AND THE TEXAS RE AND NERC TO THANK FOR THEIR ROBUST REVIEWS OF THOSE EVENTS THAT LED TO THOSE SOFTWARES.
UH, AND, AND SETTING EXCHANGES BEING AVAILABLE ALONG WITH ENGINEERS AND SOFTWARE DEVELOPERS AT THE OEMS. UM, OUR PROPOSAL GOES BEYOND JUST SOFTWARE THOUGH, UM, AND JUST THE INTERCONNECTION PROCESS, WHICH IS WHERE OTHER ISOS AROUND THE COUNTRY ARE LANDING.
UM, WE ALSO REQUIRE HARDWARE, UH, WHEN IT'S COMMERCIALLY REASONABLE, AND THAT'S NOT A GET OUTTA JAIL FREE CARD OR A VOLUNTARY COMPLIANCE MECHANISM.
UH, THERE IN MANY CASES, THERE AREN'T, YOU KNOW, KITS ON THE SHELF WAITING TO BE UPGRADED, BUT WE THINK OUR PROPOSAL COULD CREATE THEM BECAUSE AN OEM SALES PERSON WILL KNOW IF I CREATE AN AFFORDABLY PRICED KIT, I KNOW MY CUSTOMER HAS TO BUY IT.
SO WE'RE CREATING A STRONG INCENTIVE FOR THIS SOFTWARE THAT DOESN'T, UH, THIS HARDWARE THAT DOESN'T EXIST TO BE CREATED.
UM, THE OTHER KIND OF OF HARDWARE THAT IS AVAILABLE ARE, YOU KNOW, REPLACING THE CONVERTER, REPLACING THE MACHINE.
AND THAT WILL HAPPEN OVER TIME.
UM, AND IT WILL HAPPEN SOONER IN TEXAS THAN IN OTHER PLACES BECAUSE THE AGE OF OUR FLEET.
UM, SO IF IT'S POSSIBLE FOR AN OEM TO MAKE AN AFFORDABLE UP UPGRADE KIT, THEY'RE GONNA TRY BECAUSE THEY KNOW WE HAVE TO BUY IT.
UH, WE ALSO, LIKE I SAID, ADDRESS THE OTHER CRITICAL COMPONENT OF RELIABILITY, WHICH IS INVESTOR CONFIDENCE.
UNDER OUR PROPOSAL, ERCOT WON'T POTENTIALLY SCARE AWAY THE INVESTORS THAT WE WANT TO MEET THE DRAMATIC LOAD GROWTH THAT'S BEING FORECASTED IN THE NEXT FEW YEARS.
UM, CHANGING THE RULES ON INVESTORS, UM, AFTER YOU MADE THE INVESTMENT IS, IS FRIGHTENING FOR THEM.
AND WE HAVE SEEN RECENT CHANGES TO THE TECHNICAL REQUIREMENTS, UM, THAT ARE IN THIS NOER.
UM, THE VOLTAGE RIDE THROUGH CURVES HAVE CHANGED AN ORCAS PROPOSAL FROM LAST TACK.
UH, AND THOSE CHANGES MIGHT BE OKAY, BUT WE DON'T KNOW BECAUSE THEY'RE NEW.
AND SO TO THE EXTENT THAT THERE IS DISCUSSION ABOUT, WE'VE KNOWN ABOUT THIS FOR A LONG TIME, I JUST WANNA POINT OUT THAT, UM, THESE ARE ONGOING CHANGING, UH, REQUIREMENTS AND THERE'S A LOT OF DISCUSSION ABOUT HOW TO MEET THOSE REQUIREMENTS.
UM, AND YOU KNOW, AND ALSO IN REGARDS TO CONFIDENCE, PEOPLE HAVE TALKED ABOUT, WELL, WHAT ABOUT, YOU KNOW, THE EPA, YOU KNOW, EPA DOES THINGS.
AND I WANNA REMIND YOU THAT, UH, TEXAS HAS A STRONG STANCE ON PROTECTION OF PRIVATE PROPERTY RIGHTS AND OUR CONSTITUTION AND OUR STATE LAW, AND IN OUR PRINCIPLES AS A STATE.
UM, AND OUR GOVERNOR SUED THE EPA OVER EACH ONE OF THOSE ISSUES WHEN HE WAS THE ATTORNEY GENERAL.
UM, SO WE DON'T BELIEVE THIS LOWERS RELIABILITY, IT ENHANCES IT.
UH, THERE ARE ENFORCEMENT REQUIREMENTS.
IF YOU IDENTIFY AN ISSUE, YOU HAVE TO COME UP WITH A PLAN TO FIX IT, UH, OR IDENTIFY WHY YOU CAN'T DO IT, AND TRY TO, TO MEET IT AND MAKE SURE ERCOT COMPLETELY UNDERSTANDS HOW THE MACHINES OPERATE ON THIS GRID.
UM, THE PROCESS IS TO RECOGNIZE WHAT'S POSSIBLE AND DO IT IF IT'S POSSIBLE.
ON THE DEBATE OF COMMERCIAL REASONABILITY, UM, I THINK THAT ERCOT USED THE WORDS OF COMMERCIAL REASONABILITY IN THEIR APPROACH WITHOUT UNDERSTANDING WHY IT MATTERS, BECAUSE THEY WANT TO RETAIN ULTIMATE CONTROL OVER WHAT HAPPENS IN COMMERCIAL REASONABILITY.
AND THE WHOLE PURPOSE OF IT WAS TO PROTECT THAT INVESTOR CONFIDENCE AND NOT TO HAVE A COST-BASED ASSESSMENT, BUT TO HAVE IT BE BASED ON THE CONTRACTS, THE, THE DETAILS OF, OF FINANCES AT EVERY SITE.
THAT IS COMPLICATED, AS WE ALL KNOW.
UH, SO IT'S NOT JUST A PHRASE OR TIC, BUT THE PRINCIPLES AND PROCESS BEHIND IT.
IT'S, IN OTHER WORDS, IT'S A RHETORICAL CONCESSION AND NOT SUBSTANTIVE ONE, UM, ON COST TO CONSUMERS.
BILL, YOU ASKED THIS QUESTION.
UH, I THINK THE TRANSMISSION ISSUES IN THIS, IN THE STATE WILL BE, UH, A MAJOR TOPIC AT THE, UM, COMMISSION AND AT ERCOT.
AND I AM CONFIDENT THAT WHEN THOSE CONDENSES WERE APPROVED, YOU KNOW, THIS IS THEIR QUESTIONS RAISED BY THE COMMISSIONERS BECAUSE THEY WANNA UNDERSTAND HOW TO KEEP THOSE COSTS CONTROLLED.
UM, ERCOT WILL HAVE TO MAKE CHANGES.
SOME OF THOSE CHANGES WILL RESULT IN CONGESTION, LIKE YOU MENTIONED, THAT WILL RESULT IN DECLINING VALUE TO THE IBR THAT WE'RE TALKING ABOUT.
SO THEY'LL HAVE AN INCENTIVE COMMERCIAL INCENTIVE TO FIX THE ISSUE IF THAT WILL ADDRESS THE CONGESTION COSTS.
UM, I ALSO WANT TO NOTE THE DISCUSSION ABOUT ERCO AUTHORITY DISCONNECT.
UM, THIS IS ONE OF THE HEARTS OF OUR CONCERNS BECAUSE AS INITIALLY PROPOSED, AND IT SEEMS TO BE STILL THE CASE,
[01:20:01]
ERCOT DESIRES THE AUTHORITY TO DISCONNECT A RESOURCE AND SAYS THEY HAVE THE AUTHORITY TO COMPLETELY REMOVE SOMETHING FROM THE GRID.THEY SAY THEY WON'T DO IT, BUT THE PROCESS ON HOW THEY PROPOSE THAT IS BASED ON A VAGUE STANDARD.
AND, UM, THEY'RE NOT JUST ASKING FOR THEIR EXISTING STANDARD, BUT ARE ADDING TO THAT IN THEIR PARAGRAPH 2.9 0.1 0.5, WHICH GIVES THEM ADDITIONAL AUTHORITY.
WHAT WE'RE ASKING FOR THE ALTERNATIVE IS TO KEEP THE EXISTING LANGUAGE AROUND THEIR DISCONNECTION AUTHORITY THE SAME IN THE OPERATING GUIDES, AND TO REQUEST THAT THE COMMISSION REVIEW HOW TO BALANCE THAT AUTHORITY WITH ALL THE OTHER COMPETING INTERESTS, HOW TO DO IT IN A CLEAR, TRANSPARENT WAY, HOW TO MAKE SURE THAT IT'S IN A SPECIFIC CRITERIA WITH DUE PROCESS.
UM, SO WE'RE ASKING THE COMMISSION TO GIVE CERTAINTY AROUND HOW THIS AUTHORITY WILL HAPPEN IN REALITY.
UM, ALSO WE MENTIONED OUR COMMENTS, THE ODESSA EVENTS AND HOW THE ODESSA EVENTS AND THE NERC REPORTS, UH, CAN LARGELY BE RESOLVED THROUGH THE SOFTWARE CHANGES THAT HAVE BEEN IDENTIFIED AND WILL BE REQUIRED BY OUR PROPOSAL.
AND THE COMMENTS FROM Y YESTERDAY, ERCOT ALSO MENTIONED THE PANHANDLE WIND EVENT.
THAT WAS 7 65 MEGAWATTS OF THOSE ACCORDING TO THE, THE, UH, NERC REPORT.
UM, MANY OF THOSE ISSUES WERE ALSO SOFTWARE RELATED, OR NOT RIDE THROUGH RELATED.
UM, THERE WERE CONSEQUENTIAL TRIPS THAT WERE NOT RIDE THROUGH RELATED, UM, PLANT CONTROL INTERACTIONS THAT ARE SOFTWARE TUNING ISSUES, AC OVER VOLTAGE TRIPPING, THAT'S A SOFTWARE BUG DYNAMIC ACTIVE POWER REDUCTION, THAT'S A SOFTWARE CONTROL TUNING ISSUE.
AND OTHER ISSUES THAT MIGHT BE HARDWARE ISSUES OR MINOR HARDWARE ISSUES THAT ARE ON THE LOW END OF THAT LIST.
THE, THE TOP THINGS WHEN YOU SORT BY MEGAWATTS ARE SOFTWARE ISSUES.
UM, AS FOR, UM, THE, THE COMPLIANCE STATE, UM, ERCOT HAS PAINTED THIS AS, IF YOU HAVE OUR PREFERRED APPROACH VERSUS THEIR PROPOSED APPROACH, YOU'LL HAVE 20 TO 30 GIGAWATTS OF, OF RESOURCES THAT DON'T MEET THE STANDARD.
I THINK THAT'S MISLEADING OR, UM, IT'S NOT AS BLACK AND WHITE.
THIS MAY BE A A WAY TO SAY IT WITHOUT, UM, CHARACTERIZATION.
UM, MOST OF THOSE RESOURCES CAN MEET MOST OF THE STANDARD, AND SOME OF THEM CAN MEET ALL OF THEM.
MY UNDERSTANDING IS THAT THE SOLAR FACILITIES CAN MEET ALL OF THOSE REQUIREMENTS.
UM, MOST OF THE BATTERIES CAN MEET ALL OF THOSE REQUIREMENTS, AND THE ONES THAT CAN'T, CAN ONLY NOT MEET A SMALL PORTION OF, UH, THE VOLTAGE RIGHT THROUGH CURVE WIND, TOO CAN MEET MOST OF THOSE REQUIREMENTS.
SO WE'RE NOT INSTALLING EQUIPMENT THAT IS, UM, NOT, NOT COMPLIANT OR NOT GOOD.
IT, THE OEMS ARE DESIGNING AND INSTALLING THINGS THAT ARE MEETING MANY OF THE REQUIREMENTS WE HAVE HERE TODAY.
SO IT'S NOT A, A BLACK AND WHITE ISSUE.
SO I JUST WANNA CONCLUDE BY REMINDING YOU THAT WE'RE LUCKY THAT WE'RE IN THE SITUATION WHERE MOST OF THE ISSUES THAT HAVE BEEN IDENTIFIED CAN BE ADDRESSED WITH SOFTWARE CHANGES AND THE REMAINING HARDWARE ISSUES, UH, SHOULD BE ADDRESSED IN A WAY THAT'S COMMERCIALLY REASONABLE BECAUSE OF THE RELIABILITY IMPACT OF MAKING INVESTORS NOT TRUST THE MARKET OUTCOMES HERE.
AND WE'RE CREATING A NEW INCENTIVE FOR THAT HARDWARE TO BE CREATED.
UM, SO WE GENERALLY BELIEVE THAT BECAUSE WE'RE ADDRESSING THE ISSUES THAT LED TO THE FILING OF THIS NPRR WITH REQUIREMENTS TO FIX THOSE ISSUES AND WE'RE PROTECTING INVESTOR CONFIDENCE AND POTENTIALLY CREATING NEW INCENTIVES FOR NEW HARDWARE, THIS IS A BETTER RELIABILITY OUTCOME OF WHAT ERCOT PROPOSED.
ERCOT DOESN'T BELIEVE THAT AND I, I WISH THEY DID, BUT I THINK THAT YOU CAN WITH CONFIDENCE, UM, VOTE FOR THIS PROPOSAL AND IN FAVOR OF A RELIABILITY OUTCOME.
ERIC, DO WE HAVE QUESTIONS OR COMMENTS? OKAY, STEVEN, GO AHEAD.
I THINK JUST A COUPLE OF THINGS IS I DO WANT TO ACKNOWLEDGE WHAT ERIC MENTIONED.
UM, WE, WE AGREE THAT THE FACT THAT THE JOINT COMMENTERS AGREED TO SOFTWARE AND PARAMETERIZATION CHANGES AS BEING DEEMED COMMERCIALLY REASONABLE BY DEFAULT, THAT WAS PART OF THE MAIN REASON WHY WE WE WENT DOWN THAT ROUTE TO ALLOW THAT LANGUAGE, BECAUSE THAT GIVES US THE MOST BENEFIT IN THE SHORT TERM FOR RELIABILITY.
SO HE, HE'S VERY ACCURATE AND THOSE WERE PRODUCTIVE PARTS OF OUR DISCUSSIONS.
UM, WE RAISED THE ISSUE BECAUSE WE, WE DON'T WANT IT TO BE EXPANDED UPON.
WE BEYOND THOSE PARTICULAR SECTIONS ON, ON THE INVESTOR CONFIDENCE AND CHILLING EFFECT
[01:25:01]
IT, EVERYBODY HERE, IF YOU GO TO BUY A HOUSE, YOU'RE GONNA CHECK OUT YOUR NEIGHBORS, RIGHT? AND IN THIS INSTANCE, IF YOU HAVE A LOT OF NEIGHBORS THAT ARE TRIPPING OFF CAUSING, YOU KNOW, ISSUES WITH YOUR EQUIPMENT, IF YOU END UP TRYING TO INTERCONNECT TO AN INTERCONNECTION WHERE THERE'S JUST CONTINUED IBR ISSUES JUST PERSISTING, THAT'S GONNA HAVE A CHILLING EFFECT ON GENERATION EVEN MORE THAN GETTING THE RELIABILITY ISSUES ADDRESSED.SO IT'S IMPORTANT TO KEEP THAT IN CONSIDERATION.
I THINK THE OTHER THING I JUST WANNA MENTION IN WHILE WE HAVE COME TO A LOT CLOSER TOGETHER, IF YOU LOOK AT THEIR LAST SECTION TWO, TWO POINT 14, UH, 6.2 POINT 14, THAT THAT'S REALLY, AS I MENTIONED, ONE OF THE CORE ISSUES IS THEY TOOK OUT THE GUARDRAILS THAT WE PUT IN PLACE AND THEY CAN, THEY CAN CONTINUE TO APPLY FOR EXEMPTIONS IF THEY FIND OUT THAT THEY DIDN'T PERFORM.
THOSE ARE SOME OF THE CORE ISSUES THAT WE HAVE WITH THEIR PROPOSAL.
AND, AND PERHAPS THEY DON'T VIEW THAT AS A RELIABILITY CONCERN, UM, BUT ERCOT DOES.
AND, AND THAT'S A BIG SIGNIFICANT PORTION OF WHY, UH, WE'RE STILL, UH, OPPOSED TO THAT LANGUAGE.
UH, CAN I ASK A FOLLOW UP TO THAT, STEVEN? SURE, SURE.
UM, WE ATTEMPTED TO ADD THAT TO PROVIDE CLARITY THAT WE THOUGHT ASKING FOR, BUT BY THE TIME THAT WE WERE WRITING IT, WE HAD BOTH GONE OUR OWN DIRECTIONS AND WRITING.
AND SO WE'D BE HAPPY TO TALK ABOUT THAT SECTION WITH YOU.
IF, IF THAT'S YOUR CORE ISSUE, UM, WE COULD BREAK AND, AND TALK ABOUT THAT ISSUE.
IF, IF YOU'RE OKAY WITH THE REST OF OUR COMMENTS.
IT WE'RE, THAT'S JUST ONE OF THE, THE MAJOR ISSUES THAT WE HAVE.
BUT I, I DO WANT TO POINT OUT THAT WHEN YOU, WHEN YOU MAKE THE ASSERTION THAT YOU WISH WE COULD SEE IT AS AS BETTER.
ONCE AGAIN, WE ALL TRY TO GET AS CLOSE AS WE COULD, AND THEN WE ALL ARE SEEING LANGUAGE WITHIN THE LAST FEW DAYS AND TRYING TO DIGEST EVERYTHING.
BUT THERE'S DEFINITE NEGATIVES ASSOCIATED WITH THE LANGUAGE THAT CREATES THE RELIABILITY CONCERNS.
AND, AND WITH ALL HONESTY, WE LOOKED AT THE LANGUAGE TO SAY, CAN WE LIVE WITH THIS? CAN, CAN WE MOVE FORWARD WITH THIS AND BE OKAY? AND WE JUST CAN'T WITH THE WAY IT WAS DRAFTED.
UH, SIMILAR LINE OF QUESTIONING, UH, TO STEVEN.
AGAIN, THIS ISSUE US COMES DOWN TO ASSESSING THE RELIABILITY RISK VERSUS THE IMPACT EXISTING INVESTMENT, WHICH IS SOMETHING WE TAKE VERY SERIOUSLY.
SO DO YOU HAVE A SENSE, UM, I'D ASK THE RETIREMENT QUESTION.
I'D BE CURIOUS TO YOUR OPINION THERE IS JUST GONNA ACTUALLY REMOVE MEGAWATTS FROM THE GRID, THEN TWO, DO YOU HAVE A SENSE OF THE MAGNITUDE OF THE IMPACT, UH, TO EXISTING INVESTMENT? YEAH, UH, THANK YOU FOR THAT QUESTION.
SO TO THE EXTENT THAT, UM, ERCOT WOULD HAVE ULTIMATE DECISION MAKING AUTHORITY OVER WHETHER OR NOT AN EXEMPTION IS GRANTED AND THEY DON'T DO IT BECAUSE THEY BELIEVE YOU SHOULD MAKE AN INVESTMENT THAT YOU DON'T WANNA MAKE, THAT WILL LEAD TO THE ASSET OWNER TRYING TO DECIDE WHETHER OR NOT THEY WANT TO RETIRE OR INSTALL THE EQUIPMENT.
ERCOT HAS SAID THEY'LL GRANT THE EXEMPTIONS, SO I HOPE THAT IT DOESN'T LEAD TO THAT.
BUT THE HONEST ANSWER IS WE DON'T KNOW UNTIL WE FIND IT.
OUR ALTERNATIVE IS TO SAY, IF YOU MEET THE CLEAR EVIDENTIARY REQUIREMENTS OF OUR EXEMPTION PROCESS, YOU'LL GET THE EXEMPTION.
AND IF YOU, UH, IF ERCOT BELIEVES THAT YOU DON'T MEET THAT, THEN IT'S UP TO THE COMMISSION TO DECIDE.
SO WE, WE THINK OURS RESOLVES THAT ISSUE OF RETIREMENTS BECAUSE WE HAVE A CLEAR EVIDENTIARY PROCESS AND NOT A, A MORE VAGUE STANDARD.
I DID WANNA MAKE SURE WE GOT AN EARLIER QUESTION TO STEVEN.
DID YOU GET A CHANCE TO RESPOND, UM, NED'S EARLIER QUESTION ON THE, THE DISCONNECTION AUTHORITY AND, AND THE JOINT COMMENTER'S PERSPECTIVE ON THAT? UH, YEAH, SO ON THAT TOPIC, UM, THAT THAT WAS ONE OF THE, THE KEY REASONS AS TO WHY WE WERE SO CONCERNED WITH THE INITIAL ERCOT PROPOSAL AND, UH, ERCOT IN THEIR JANUARY AND THE LATEST COMMENTS, MY UNDERSTANDING IS THEY DELETED THAT.
SO IT CAN BE, IT CANNOT BE DISCUSSED IN THIS NOER, BUT, UM, CONTEND
[01:30:01]
THAT THEIR EXISTING AUTHORITY ALLOWS THEM TO DISCONNECT RESOURCES.AND WE DON'T DISAGREE THAT THEY HAVE DISCONNECTION AUTHORITY.
UM, HOWEVER WE, UH, THINK THAT HAPPENS WITHIN THE, THE CONTEXT OF THE COMMISSION'S RULES, UM, AND, UH, THE STATE'S, UH, LAWS AND CONSTITUTION AS WELL AS THEIR OBLIGATIONS UNDER NERC.
AND SO BECAUSE THERE'S UNCERTAINTY AROUND HOW DISCONNECTION AUTHORITY WOULD BE APPLIED IN THIS SITUATION, THAT CAN BE LONGER THAN AN HOUR A DAY, LIKE A R DECOM COMMITMENT, RIGHT? UM, THEN, UM, WE, WE WANT THERE TO BE A PROCESS, UM, AT THE COMMISSION TO JUST DEFINE HOW THIS AUTHORITY WILL BE USED BECAUSE WE THINK THAT'LL GIVE ERCOT MORE CONFIDENCE IN USING THAT AUTHORITY AND US MORE CONFIDENCE IN, IN KNOWING HOW IT'LL BE USED.
SO RATHER THAN RELYING ON A GENERAL BROAD AUTHORITY, WE WOULD LIKE FOR THERE JUST TO BE A COMMON UNDERSTANDING OF WHEN IT'LL HAPPEN, HOW IT'LL HAPPEN, AND WHY IT'LL HAPPEN.
AND FURTHER, I WOULD JUST ADD AGAIN, IN, UM, 2.9 0.1, PARAGRAPH FIVE, THEY'RE EXPANDING THAT AUTHORITY, WHEREAS WE'RE TRYING TO LEAVE IT ALONE SO THE COMMISSION CAN CONSIDER IT.
POTENTIALLY COULD BE WORKED OUT OFFICE.
SO THIS HAS BEEN TABLED A FEW TIMES.
IT'S BEEN TALKED ABOUT FOR A WHILE.
UM, WE SPENT, I THINK STEVEN DESCRIBED IN HIS COMMENTS HOW HOW MUCH WE'VE BEEN SPENT TALKING TO EACH OTHER.
AND I THINK, UM, I WOULD, I WOULD LOVE FOR THERE TO BE A COMPROMISE, BUT WE, WE'VE, WE'VE TRIED OUR HARDEST TO GET THERE.
UM, I I THINK THAT IT'S, IF TAC WANTS TO, TABLE TAC HAS THE RIGHT TO TABLE, BUT WE'RE NOT ASKING TAC TO DO THAT.
UM, I, I HOPE THAT IF A VERSION PASSES TODAY, UM, THERE'S ALWAYS AN OPPORTUNITY TO FILE COMMENTS TO FIX THINGS THAT ONE PART OR THE OTHER DOESN'T LIKE ABOUT THE OTHER SIDE BEFORE THE BOARD MEETING.
UM, BUT, UM, SPEAKING TO ERCOT AND A NUMBER OF THE TAC VOTERS, I THINK PEOPLE WOULD LIKE TO MOVE FORWARD TODAY.
THANK YOU AND I THAT, UM, WE DO WANT TO SUPPORT AN COMPROMISE, BUT PERSPECTIVE FOR THAT NOT EVEN FRUSTRATION THAT IT'S REALLY CASE.
I DON'T REALLY A, THAT RELIABILITY BETWEEN NOW TWO FROM NOW AND NOW YEARS FROM NOW.
RELIABILITY, WHICH IS WHY I ASKED THE QUESTION FROM YOU.
AND I IMAGINE THAT REGARDLESS OF THE OUTCOME TODAY, UM, THE TWO SIDES WILL TALK AT LEAST THREE TIMES BETWEEN NOW AND THE BOARD MEETING.
STEVEN, DID YOU WANT TO RESPOND TO THAT TABLE IN QUESTION? I THINK I JUST WANTED TO COMMENT FROM ERCOT PERSPECTIVE.
I, I THINK WE WANNA MOVE FORWARD AND WE WANT TO TAKE WHATEVER THE DECISION TAC IS.
OBVIOUSLY WE WANT TAC TO TAKE A VERSION TO THE BOARD THAT REFLECTS RELIABILITY,
[01:35:01]
THAT, YOU KNOW, THAT'S THE CORE MISSION OF ERCOT AND WE WANT TO PRESENT SOMETHING TO THEM THAT, UH, WE CAN ALL STAND BE BEHIND FROM A RELIABILITY PERSPECTIVE.AND SO THAT'S REALLY, UM, WE DON'T WANT TO TABLE IT.
WE'D PREFER TO KEEP IT MOVING.
AND I THINK TO ERIC'S POINT, I HOPE ERCOT HAS DEMONSTRATED THAT THERE, IF THERE IS LANGUAGE CHANGES THAT WE CAN MAKE WHERE WE HAVE COMMONALITY AND, AND WE'RE WILLING TO MAKE THOSE LANGUAGE CHANGES EVEN BETWEEN NOW AND THE BOARD.
UM, BUT WE'VE HAD ENOUGH DISCUSSIONS THAT WE UNDERSTAND WHERE OUR CORE FUNDAMENTAL DIFFERENCES STILL REMAIN, WHICH IS A, WHICH IS A SMALLER LIST.
WE, WE DID MAKE A LOT OF PROGRESS IN THE LAST COUPLE OF MONTHS.
UM, AND I DO WANNA NOTE, YOU KNOW, IT IS UP TO TECH.
UH, A MAJORITY OF THESE CONVERSATIONS HAVE BEEN SORT OF CLOSED DOOR CONVERSATIONS BETWEEN ERCOT AND JOINT COMMENTERS.
THIS IS HIGHLY TECHNICAL MATERIAL.
UM, AND THANK YOU, OUR, OUR ROSS CHAIR, KATIE RICH HAS DONE A LOT OF WORK ON THIS AS WELL.
UM, SO, SO IF TAC NEEDS MORE TIME TO CONSIDER THE ISSUES, IF THERE'S MORE INFORMATION TAC WANTS, UM, WE, WE'VE HAD VERSIONS OF PRESENTATIONS WHERE WE WENT THROUGH THOSE DIFFERENCES, UM, THAT, THAT REALLY IS UP TO TAC AND IN MY EYES.
AND SO IF THERE'S SOME VALUE FROM THESE MEMBERS HAVING MORE TIME OR WANTING MORE IN INFORMATION FROM OTHER EXPERTS OR ASKING QUESTIONS ON, ON THIS HIGHLY TECHNICAL MATERIAL, UM, E EVEN THOUGH, YOU KNOW, THE, THE TWO KIND OF NEGOTIATING PARTIES MIGHT HAVE COME AS FAR AS THEY COULD COME.
I, I THINK THAT THAT IS HIGHLY VALUABLE AS WELL.
SO I WILL, WITH THAT, I WILL GO BACK TO THE QUEUE.
UH, CHASE SMITH, WE CAN CHASE.
UM, UM, I FIRST START OFF BY ADDITIONAL HERE TODAY CONVERSATION AND OTHER
AND YOU KNOW, UNFORTUNATELY IT WASN'T ENOUGH TO, TO JOIN PROPOSED ONE CONCEPT, BUT I DO THINK THAT THEY REPRESENT, UM, FURTHER CLOSER
MY COMMENT IS IN RESPONSE TO QUESTION 15, UM, WHAT WE THINK, WHAT MAY BE MORE AWARE OF WHAT MAY NOT BE IN SOFTWARE, VERY TECHNICAL ITEMS THAT WE OPINION WITH.
UH, AND THAT RELATES TO, UH, BREAKING FREQUENCY MULTIPLE TIME THROUGH AND
BUT, UM, YOU KNOW, I ARE REQUIRED TO WRITE THROUGH, UH, THE CURRENTLY AND
UM, BUT I JUST WANNA OUT THAT, UM, THERE CURRENTLY ARE NOTHING E IATION FOR FAILING AND
AND I, I THINK WHAT JOINT OFFICER SERVICE ARE IS IF WE, WE MOVE FORWARD WITH
[01:40:01]
UM, YOU WILL HAVE, THE RESOURCES WILL NOT BE ABLE TO PROVIDE CURRENT APPROPRIATELY.
UM, AND THEN, YOU KNOW, THAT'S JUST A LIMITATION THAT CONTINUE TO DEFINE DEFINED, BETTER DEFINED.
BUT UNFORTUNATELY WE DON'T HAVE UNDERSTANDING OF THAT.
STEVEN, DID YOU WANT TO RESPOND TO THAT? YEAH, I THINK JUST TO CLARIFY A LITTLE BIT IN THAT, IF YOU LOOK BACK AT THE RFI RESPONSES, I THINK HE CHASE ALLUDED TO IT, MOST OF THE CHALLENGES THAT WE GOT WERE OEMS DIDN'T ACTIVELY MONITOR THESE PARAMETERS AND THEY REALLY HADN'T TESTED THEIR EQUIPMENT OUT TO KNOW IF IT CAN OR IF IT CAN'T.
AND SO WHEN WE WERE TALKING WITH OEMS ABOUT LANGUAGE CHANGES, UH, THE OEMS TOLD US IF WE WERE TO PUSH OUT THOSE REQUIREMENT CHANGES INTO THE FUTURE, THAT WOULD ALLOW THEM TO MORE SUBSTANTIVELY STATE THAT THEY CAN MEET THE, THE REQUIREMENTS PROPOSED.
SO THAT'S WHY ERCOT IS TRYING TO BIFURCATE AND PUSH THOSE INTO A SEPARATE NOER, WHICH WE COMPLETELY WANT TO WORK WITH THE GENERATOR OWNERS TO GET THE RIGHT REQUIREMENTS, WHICH WILL INCLUDE SOME LEVEL OF EXEMPTIONS EXTENSIONS IF NEEDED, TO ACCOMMODATE THAT.
BUT IF YOU LOOK AT WHAT THE IEE 2,800 TEAM IS SAYING THERE, THERE NEEDS TO BE AN AGREEMENT ABOUT HOW YOU MEASURE THESE THINGS, OR YOU CANNOT GAUGE IF THEY PERFORM TO OR NOT TO THESE PARAMETERS.
THERE NEEDS TO BE A BETTER UNDERSTANDING ABOUT THE ERROR.
CAUSE CODES THAT COME IN DUE TO THESE PARAMETERS, UH, WE'RE VERY CONCERNED THAT YOU COULD HAVE SOME ERROR CODE THAT COMES IN THAT IS MAYBE LOOSELY RELATED TO IT, THAT THESE EXEMPTIONS THEN WOULD NEGATE THEIR NEED, UH, TO RECTIFY THOSE ISSUES.
IT, IT WON'T SAY PHASING WILL TRIP, IT WON'T SAY ROFF TRIP, IT'LL SAY LOSS OF SYNCHRONISM.
IT'LL BE SOME VERY GENERIC FAILURE MODE THAT THEN WE'RE GONNA GET A RESPONSE TO ERCOT THAT SAYS, THIS WAS ROFF AND SO THANK YOU FOR THE INQUIRY.
BUT, UH, WE DON'T NEED TO MITIGATE IT.
WE'RE TRYING TO PROTECT ABOUT AGAINST THOSE THINGS.
WE WANT TO GET TO WHERE THEY'RE COMFORTABLE, BUT WE NEED ADDITIONAL TIME TO DO THAT.
WE NEED ADDITIONAL TECHNICAL DISCUSSION
[01:45:01]
AND WE WANT TO MOVE FORWARD WITH THE VALUE THAT WE SEE THAT'S OUT THERE, THAT OM SAY WE JUST NEED TO GET NOGA 2 45 APPROVED SO THAT WE CAN MOVE FORWARD WITH THESE SOFTWARE PARAMETER CHANGES.WE ONTO IAN HAILEY, THANK YOU VERY MUCH.
UM, WANTED TO EXPLAIN, UH, WHY OUR COMPANY MORGAN STANLEY WILL BE VOTING THE WAY WE ARE.
UM, WE DO NOT HAVE ASSETS ON THIS GRID.
UM, HOWEVER, FROM TIME TO TIME WE HAVE DONE OFFTAKE AGREEMENTS WITH RESOURCES AS THEY NEWLY COME ON THE GRID.
UM, A RULE LIKE THIS, UH, ADDS A LEVEL OF RISK THAT WE DO NOT THINK WE CAN QUANTIFY AND THEREFORE, UM, GOING DOWN A PATH LIKE THIS WOULD SEVERELY LIMIT OUR ABILITY TO TAKE OFF, TAKE AGREEMENTS IN THE FUTURE.
ADDITIONALLY, UM, MORGAN STANLEY PROVIDES A LOT OF LIQUIDITY FOR INVESTMENTS AND CALCULATING IN THAT A RESOURCE.
UM, IAN, CAN YOU GET A LITTLE CLOSER TO THE MIC? SORRY.
IS THIS BETTER FOR THOSE ON THE PHONE? THANK YOU.
UM, ALSO, UM, ON THE INVESTMENT SIDE, CALCULATING IN A RISK FACTOR OF HOW A RESOURCE COULD BE RETROACTIVELY REQUIRED TO CHANGE, UM, IS NOT SOMETHING WE THINK WE COULD BE ABLE TO CALCULATE AND THEREFORE, UM, WOULD REQUIRE US AT A MINIMUM TO PUT A RISK PREMIUM THAT MUCH HIGHER, UM, THAN WE THINK THE LIKELIHOOD WILL BE.
UH, BOTH OF WHICH WOULD SEVERELY LIMIT OUR ABILITY TO, UM, DO AS WE THINK AN INDEPENDENT POWER MARKETER IS SUPPOSED TO DO, WHICH IS PROVIDE LIQUIDITY IN THIS MARKET, UM, BECAUSE OF THOSE RISKS AND RISKS TO INVESTMENT SIGNALS, UM, WE ARE ALIGNED WITH THE JOINT COMMONERS.
UH, RICHARD ROSS, I I GUESS ONE POINT OF, YOU KNOW, I'VE GOT A NUMBER OF THINGS THAT I'M NOT GONNA GO INTO JUST 'CAUSE I DON'T WANT TO C CREATE MORE OF A BACK AND FORTH GOING, BUT THE, ONE OF THE CORE ISSUES, UH, THAT IT SEEMS TO BE HERE IS WHOSE DISCRETION THERE IS IN TERMS OF DETERMINING WHAT COMMERCIALLY REASONABLE IS.
UM, I CAN CERTAINLY UNDERSTAND NOT WANTING TO TRUST ERCOT TO BE REASONABLE WITH THAT.
I CAN CERTAINLY UNDERSTAND ERCOT NOT WANTING TO TRUST, UH, THE RESOURCE ENTITIES WITH THE RELIABILITY DECISION, BUT I THINK THE BEAUTY OF ERCOT BEING IN THE POSITION THEY ARE IN, IF THEY ARE THE DECISION MAKER, IS IF THEY ARE UNREASONABLE, IT CAN ALWAYS BE APPEALED TO THE COMMISSION AND THE COMMISSION CAN DECIDE.
SO TO ME, THAT ISSUE OUGHT TO BE OFF THE TABLE IS A CORE ISSUE.
UM, AND, AND WE OUGHT TO BE ABLE TO MOVE FORWARD.
I KNOW THAT MAY NOT BE PERFECT, IT MAY NOT BE EXPEDIENT, IT MAY CREATE UNCERTAINTY, BUT IT IS A PATH FORWARD.
SO IF I COULD, I'M GONNA LET, UH, GO, GO AHEAD AND RESPOND TO THAT.
I, I THINK THAT WHAT YOU'RE ASKING FOR IS WHAT'S IN THE JC APPROACH.
SO WHAT WE, TELL ME IF I'M MISINTERPRETING ANYTHING, BUT, WELL, MY, MY POINT IS THAT IT'S WHAT'S IN THE ERCOT APPROACH WELL AS WELL.
HERE WE, THE, THE DIFFERENCE BETWEEN THE JC APPROACH AND THE ERCOT APPROACH WITH RESPECT TO APPROVING, UM, UH, A REQUEST FOR EXEMPTION OR EX EXTENSION IS THE ABILITY OF A MARKET PARTICIPANT TO CONTINUE TO WORK WITH ERCOT TO MAKE SURE THEY HAVE ALL THE INFORMATION THEY NEED TO MAKE THAT DECISION.
SO UNDER, UNDER ERCO T'S CURRENT PROPOSAL, UM, ERCOT WILL, YOU KNOW, EVALUATE THE COMMERCIAL REASONABILITY OF IT AND EITHER ACCEPT OR REJECT THE REQUEST.
AT WHICH POINT THE ONLY, THE ONLY ALTERNATIVE FOR THE, UM, RESOURCE IS TO APPEAL IT TO THE COMMISSION.
UNDER THE JOINT COMMENTER'S APPROACH, UM, THE, THE RESOURCE ENTITY MAKES A DETERMINATION OF COMMERCIAL, OF COMMERCIAL REASONABILITY AND THEN REQUESTS AN EXEMPTION OR EXTENSION AT WHICH POINT ERCOT EVALUATES MAKES A DECISION TO GRANT OR REJECT.
IF ERCOT REJECTS, THEN THE MARKET PARTICIPANT HAS THE ABILITY TO WORK WITH ERCOT TO MAKE SURE THEY HAVE ALL THE INFORMATION THAT THEY NEED.
AND THEN ERCOT, YOU KNOW, IF IT STILL DOESN'T BELIEVE IT HAS THAT INFORMATION CAN REJECT AGAIN.
AND THEN THERE'S AN APPEAL TO THE COMMISSION.
JULIANA, YOU ARE SPEAKING ON BEHALF OF JOINT COMMENTERS, JOINT COMMENTERS AND BAN GRID.
[01:50:01]
OKAY, LET'S AS YOUR CUT STAFF, PLEASE DO ANDREW GALLO, UH, FROM ERCOT LEGAL, BOTH PROPOSALS ALLOW AN APPEAL TO THE COMMISSION IN CASE THE MARKET PARTICIPANT DOESN'T AGREE WITH ERCO T'S DECISION.FRANKLY, NEITHER PROPOSAL NEEDS TO REQUIRE THAT BECAUSE THE, THE PDC RULES ALWAYS ALLOW, ALREADY ALLOW A MARKET PARTICIPANT TO APPEAL ANY ERROR CUT ACTION IT DOESN'T AGREE WITH.
BUT I WOULD SUBMIT THAT THERE'S AN EXTRA STEP IN THE JOINT COMMENTER'S PROPOSAL ON FOR AN APPEAL.
WE HAVE SAID, SUBMIT WHAT YOU'VE GOT TO ERCOT TO SUPPORT YOUR REQUEST.
ERCOT WILL LOOK AT IT, ERCOT WILL GO BACK AND FORTH, HEY, DO YOU HAVE THIS? HEY, DO YOU HAVE THAT? CAN YOU GIVE US THIS? DO YOU HAVE INFORMATION ON THAT? THAT'LL BE AN ITERATIVE PROCESS.
AND THEN ERCOT WILL MAKE A DECISION AND AT THAT POINT, IF, IF THEY DON'T LIKE THE DECISION, THEY CAN GO TO THE COMMISSION, ADDING ANOTHER STEP TO SAY, WE WANNA MEET WITH ERCOT AGAIN, DIDN'T MAKE MUCH SENSE TO US.
AND THAT'S ALL, I GUESS REALLY I CAN SAY ABOUT THAT.
ARE ARE WE GOOD ON YOUR COMMENT? ALRIGHT, HOLD EVERYTHING ELSE.
I AM, I FIND MYSELF WONDERING IF WE'RE GETTING REALLY HUNG UP ON MISSING THE PICTURE.
BIG PICTURE IS WE ARE IN ENERGY TRANSITION, WE ARE MID ENERGY TRANSITION ON THE CUSP OF HOW WE INTEGRATE TECHNOLOGIES AS THEY ADAPT AND CHANGE TO NEW STANDARDS AND HOW WE ADDRESS RELIABILITY IN A WORLD WHERE THE MAJORITY OF THE GRID CAN BE POWERED BY IBR ON A GIVEN DAY.
AND RIGHT NOW WE ARE GETTING INTO HOW DO WE TALK ABOUT A SINGLE UNIT THAT ERCOT HAS IDENTIFIED AS RISKY? IT GOES TO THE PUC, WE'VE TALKED ABOUT THIS IN OTHER CONTEXTS.
ALL MARKET PARTICIPANTS BEAR SOME RISK OPERATING IN THIS MARKET.
THAT IS WHY WE ARE STAKEHOLDERS HERE.
THAT'S WHY WE HAVE THIS STAKEHOLDER PROCESS.
AND I FIND IT CHALLENGING THAT ERCOT HAS COME TO THE TABLE AND CONCEDED SO MANY POINTS OVER SO MANY MONTHS, AND WE ARE HAVING SUCH SPECIFIC CONVERSATIONS ABOUT A SPECIFIC POTENTIAL UNIT OF AN IBR SOMEHOW SETTING A REAL PRECEDENCE FOR INVESTMENT IN ERCOT.
I DON'T FIND THAT TO BE AN ACCURATE REPRESENTATION OF THE PRECEDENT THAT WOULD BE SET BY APPROVING ERCOT AS IS BECAUSE THE UNITS WE ARE TALKING ABOUT ARE, AS WE DISCUSSED AT THE BEGINNING, 8% OF ALL I BS ON THE GRID THAT WOULD REQUIRE HARDWARE UPDATES OF THAT, A FRACTION THAT WILL NOT BE ABLE TO MAKE HARDWARE UPDATES WITH NEW OEM DELIVERABLES THAT ARE IMMINENT.
I AM REALLY STRUGGLING TO UNDERSTAND HOW WE'RE MAKING A CASE THAT THIS WOULD AFFECT A BANK'S ABILITY TO INVEST IN ERCOT WHEN THE RISK TO THE INVESTMENT IS INCONSEQUENTIAL TO THE OVERALL ORIGINAL IMPLEMENTATION.
SO I WOULD URGE EVERYONE ATTAC TO THINK ABOUT MATERIALITY HERE BECAUSE WE ARE FRACTIONING OVER SOMETHING THAT WE'RE GONNA HAVE TO FIGURE OUT MUCH MORE DIFFICULT.
WE'VE GOT STORAGE RESOURCES WHERE TECHNOLOGY IS EVOLVING AT A CLIP WE HAVE NOT HAD TO DEAL WITH WITH IIV.
SO PLEASE THINK ABOUT MATERIALITY, STOP MAKING STATEMENTS THAT CONFLATE HOW SEVERE THIS IMPACT IS BECAUSE 2 45 HAS TO MOVE TODAY, WE HAVE TO HAVE THIS REGULATION IN PLACE FOR JULY SO THAT ERCOT CAN DO THEIR JOB.
SO PLEASE, I URGE EVERYONE HERE TO MAKE A SENSIBLE DECISION.
UM, SO, UH, MAYBE AS, UH, UH, DOVETAILING ON ON JENNIFER'S COMMENT ABOUT NEEDING TO MAKE A DECISION TODAY.
UM, YOU KNOW, I KIND OF GO BACK TO SOME COMMENTS OF MADE PREVIOUSLY.
THIS SEEMS LIKE A, IT WOULD'VE BEEN A GREAT CANDIDATE TO BIFURCATE BACK IN JANUARY, 2023.
THAT'S NOT THE DECISION THAT WE HAVE IN FRONT OF US THOUGH.
WE HAVE TO CHOOSE A PATH FORWARD ON WHAT'S IN FRONT OF US, AND WE HAVE TWO CHOICES.
UM, YOU KNOW, ON ONE FRAME, ONE HAND, ARCOT FRAMES THE JOINT COMMENTERS AS, UH, APPROACHES BEING NEGATIVE TO RELIABILITY AND MOVING BACKWARDS.
UH, JOINT COMMENTERS ON THE OTHER
[01:55:01]
HAND SAY THAT IF WE ADOPT THEIR COMMENTS, WE'LL HAVE THE MOST STRINGENT STANDARD IN THE COUNTRY, WHICH I, I, DESPITE THE CONVERSATION TODAY, I STILL HAVE TROUBLE RECONCILING.BUT, UM, I, I DO WANT TO RECOGNIZE AND APPRECIATE ALL OF THE EFFORTS THAT HAVE GONE INTO, UH, TO REACH A COMPROMISE AND THE CONCESSIONS THAT ARCOT HAS MADE.
UM, YOU KNOW, STEVEN, THOSE ARE, UH, YOU, YOU, UH, ELABORATED ON THOSE VERY CLEARLY AND, UM, UH, ALSO WANNA RECOGNIZE THOSE.
UM, FOR US AS LUMINANT, THE MATERIAL MATTER OF PRINCIPLE IS THAT THE RULES SHOULD BE APPLICABLE ON A FORWARD LOOKING BASIS PRIMARILY AND ONLY LOOK BACKWARDS AND BE RETROACTIVE AND, AND VERY LIMITED AND, AND UNIQUE CIRCUMSTANCES.
UM, SO ON THAT BASIS ALONE, THE, UH, YOU KNOW, THE EFFECTIVE DATE FOR, UM, YOU KNOW, NEW RESOURCE REQUIREMENTS IN THE JOINT COMMENTERS PROPOSAL OF, UH, JUNE 1ST, 2024 IS AT LEAST CLOSER ALIGNED TO THE EFFECTIVE DATE OF WHEN THIS NOGA WOULD BE PROPOSED.
I KNOW IN YOUR TIMELINE IT LOOKED LIKE THAT WOULD TECHNICALLY MOVE INTO JULY, BUT WELL
UM, YOU KNOW, JENNIFER, I RESPECTFULLY DISAGREE THAT, YOU KNOW, JUST BECAUSE IT HAS BEEN IN THE STAKEHOLDER PROCESS FOR, YOU KNOW, THE LAST YEAR IN CHANGE AND, YOU KNOW, DISCUSSED BEFORE THAT, THAT THAT NECESSARILY CREATES AN OBLIGATION FOR FOLKS TO, UM, YOU KNOW, TO PLAN AROUND THAT.
IT, YOU KNOW, IT SHOULD GIVE A HEADS UP OF WHERE THINGS ARE GOING, BUT, YOU KNOW, THE, THE REQUIREMENT DOESN'T BECOME BINDING UNTIL THE ERCOT BOARD HAS ENDORSED IT AND THE PUC HAS THEN APPROVED IT.
THAT'S THE, THE POLICY MAKING STRUCTURE THAT WE HAVE.
SO, YOU KNOW, THAT'S, THAT IS A, THAT'S A KEY ISSUE FOR US.
AND, AND ULTIMATELY, YOU KNOW, WE WILL END UP, YOU KNOW, IF WE HAVE TO PICK ONE, WE'RE GOING TO PICK THE JOINT COMMENTERS ON THAT BASIS ALONE.
UM, BUT THEN ALSO, YOU KNOW, THE, UH, SO I, I DON'T THINK WE'LL GET UNIFIED ON THE RETROACTIVITY COMMENT, UM, UNFORTUNATELY.
UM, AND SO I WANTED TO AT LEAST LAY THAT OUT FOR, YOU KNOW, WHY WE'D BE VOTING THE WAY WE ARE.
BUT ALSO, YOU KNOW, OUR SMES, OUR ENGINEERS HAVE LOOKED AT THE JOINT COMMENTER'S PROPOSAL AND OUR CO'S PROPOSAL AND, AND BELIEVE THAT THE JOINT COMMENTER'S PROPOSAL IS A REASONABLE APPROACH.
UM, YOU KNOW, I DO WANNA BE CLEAR, LIKE, LIKE I SAID EARLIER, STEVEN, YOU KNOW, WE DON'T SEE THAT AS, UH, UNDERMINING OUR CO'S ABILITY TO TAKE ACTIONS TO PROTECT THE GRID.
UM, AND, UM, BUT WE THINK IT'S A WORKABLE FRAMEWORK AND THE, YOU KNOW, THE COMMERCIAL REASONABILITY APPROACH, THE, THE RATIONALE THAT OUR, THAT, UH, ERIC GAVE FOR TRYING TO CREATE AN INCENTIVE FOR, UH, YOU KNOW, FOR THE DEVELOPMENT OF SOLUTIONS THAT MAKES SOME INTUITIVE SENSE TO US.
WITH, WITH IBR YOU HAVE A LOT, A VERY, UM, DIVERSE MIX OF, UM, OEMS THAT HAVE, YOU KNOW, SOME, SOME AREN'T AROUND ANYMORE.
YOU DON'T HAVE THE, THE NATURAL ECONOMIES OF SCALE THAT YOU HAVE WITH SOME OTHER TECHNOLOGIES TO CREATE AN ECOSYSTEM OF SUPPORTS AROUND IT.
SO PUTTING CARROTS OUT THERE FOR COMMERCIAL REASONABILITY HAS SOME INTUITIVE SENSE TO ME BASED ON THE DISCUSSION WE'VE HAD TODAY.
UM, SO I'LL LEAVE IT WITH THAT, UM, UNDERSTANDING THAT, UH, YOU KNOW, TACKLE VOTE AS THEY WILL AND THERE'LL DEFINITELY BE DISCUSSIONS BEFORE THE BOARD, BUT, UM, YOU KNOW, I APPRECIATE THE EFFORTS TO GET, GET CLOSER.
JENNIFER, YOU WANTED TO RESPOND? YEAH, JUST FROM THE LSC PERSPECTIVE.
UM, I APPRECIATE YOUR FEEDBACK, NED.
I GUESS I WOULD ADD THAT I SOLD TEXAS CUSTOMERS FORWARD POWER CONTRACTS RIGHT NOW, AND IF THE GRID GOES DOWN, I DON'T THINK THEY'RE GONNA BE SUPER HAPPY WITH THE RATE THEY GOT RELATIVE TO NOT HAVING POWER.
AND SO WHILE YOU'RE TALKING ABOUT RETROACTIVITY IN TERMS OF HOW IT AFFECTS COMMERCIAL VIABILITY AS A LOAD SERVING ENTITY, MY COMMERCIAL VIABILITY IS ON THE LINE EVERY SINGLE DAY ON A FORWARD POWER CONTRACT.
AND SO I DO THINK THAT THERE'S SOME LEVEL OF, PERHAPS COULD WE SAY ALL STAKEHOLDERS HAVE DIFFERENT TYPES OF RISK, AND SO AGING TECHNOLOGY IS PROBABLY A RISK MORE UNIQUE TO A GENERATOR TYPE.
I BEAR A LOT OF FINANCIAL RISK ON WHETHER THOSE GENERATORS PERFORM.
AND SO I THINK IT'S REALLY IMPORTANT FOR US TO RECOGNIZE THAT THE IBR ARE NOT UNIQUE IN ADAPTING TO THE ENERGY TRANSITION AND SOME LEVEL OF FLEXIBILITY, WHICH I THINK ERCOT HAS TRIED TO STRIKE THE BALANCE ON, IS PART OF US WORKING TOGETHER TO BE THE MOST SUCCESSFUL POWER RTO, UM, HOPEFULLY IN THE WORLD.
BUT I THINK WE CAN MAKE IT NATION AND, AND MY
[02:00:01]
COMPANY SHARES THE LSE RISK AS WELL, UH, THE, ALL THOSE SAME RISKS.SO WE HAVE TO BALANCE BOTH, BOTH SIDES.
UM, BUT WHAT I'VE, WHAT I'VE HEARD TODAY IS THAT THE JOINT COMMERCE APPROACH CAN AT LEAST IMMEDIATELY ADDRESS MOST OF THE ISSUES, ALL THE SOFTWARE FIXES THAT, THAT ARE, YOU KNOW, EASIER OFF THE SHELF.
AND, AND STEVEN, I HEARD, I THINK I HEARD YOU SAY THAT, YOU KNOW, THAT THAT GETS TO THE MOST OF THE WAY THERE, UM, IN TERMS OF ADDRESSING THE IMMEDIATE CONCERNS.
NOW THERE, THERE WILL BE SOME, SOME TRAILING ISSUES AND I THINK THE FRAMEWORK THAT THE JOINT COMMONERS HAVE WILL, IT SHOULD BE SUCCESSFUL IN, IN GETTING TO THAT AND, AND ADDRESSING THE RISK.
'CAUSE YOU'RE RIGHT JENNIFER, WE DO NEED TO SOLVE THAT FOR OUR, YOU KNOW, FOR ALL IDRS.
THEY'RE GONNA CONTINUE TO GROW ON THE SYSTEM AND IT'S IMPORTANT FOR US TO, TO MAKE A, A CUT AND MOVE FORWARD SO THAT THERE IS SOME CLARITY, YOU KNOW, WHERE WE DRAW THE LINE ON WHAT MOVE FORWARD IS, YOU KNOW, THAT'S A, I THINK A MATTER MATTER OF PRINCIPLE, BUT I AGREE WITH YOU THAT, THAT IMPROVEMENTS DO NEED TO BE MADE AND WE NEED TO MOVE FORWARD.
I SEE STEVEN WANTS TO RESPOND AND THEN WE HAVE BOB HILTON IN THE QUEUE, AND THEN I THINK WE'LL TRY TO SEE IF WE CAN ACT ON ONE OF HER MOTIONS RIGHT AFTER THAT.
SO I THINK FIRST I WANNA SAY THAT ERCOT PROPOSAL PROVIDES A FRAMEWORK TO MOVE FORWARD JUST THE SAME.
UH, AND I I ALSO WANNA MENTION ON THE RETROACTIVE IN THE, IN THE JUNE 1ST, 2023 VERSUS JUNE 1ST, 2024, IF YOU GO BACK AND LOOK AT THE LAST SET OF RIDE THROUGH REQUIREMENT CHANGES BACK IN 2014, YOU'LL SEE THAT THE JANUARY 16TH, 2014 DATE THAT ENDED UP IN THE RULE IS HAPPENED IN THE PAST AND IT DIDN'T GO INTO EFFECT UNTIL MULTIPLE MONTHS LATER.
SO THEY FOUND A DATE AND SAID, OKAY, HERE, EVEN THOUGH THAT THE STAKEHOLDER PROCESS CONTINUED ON, SO THERE'S NOT SOME TYPE OF PRECEDENT HERE THAT WE'RE, WE'RE BREAKING IT IS TRYING TO ADHERE TO THAT DATE.
AND WE WANT TO BE VERY TRANSPARENT ABOUT THE 20 TO 30 GIGAWATTS.
IF YOU GO AT THE GENERATOR INTERCONNECTION LIST AND YOU LOOK WITH THE EXCEPTION OF THREE UNITS, THEY'RE ALL SOLAR AND BATTERY IN THERE THAT ARE ALL VERY CAPABLE.
AND WE GIVE AN APPROACH FOR EVEN THOSE WIND GENERATION, WHICH WE'RE ASSUMING THOSE ARE THE ONES THAT ARE PUSHING BACK TO HAVE EXEMPTIONS FOR WHERE THEY FALL SHORT.
BUT THE REAL DIFFERENCE IS IF THE CURRENT RULES ARE THAT YOU GOTTA JUMP ONE FOOT HIGH AND THE NEW RULES ARE THAT YOU GOTTA JUMP TWO FEET HIGH, WHAT WE'RE SAYING IS THAT IF YOU CAN ONLY JUMP A FOOT AND A HALF, THAT'S OKAY.
BUT THERE'S A DIFFERENCE BETWEEN PERFORMANCE AT ONE AND A HALF FEET VERSUS ONE FOOT.
AND THAT'S WHAT WE'RE TRYING TO SAY IS IF YOU'RE CAPABLE, THEN PERFORM TO YOUR CAPABILITIES OR THE HIGHER REQUIREMENTS SO YOU HAVE A PATH FORWARD.
ALL WE'RE DOING IS ALLOWING THOSE 20 TO 30 GIGAWATTS THAT'LL BE THERE BY THE END OF JUNE TO NOT HAVE TO MEET THE HIGHER PERFORMANCE REQUIREMENTS, EVEN THOUGH THEY CAN.
AND THAT SEEMS CONTRARY TO RELIABILITY FOR ERCOT.
SO THAT'S REALLY WHY WE'RE TRYING TO MAKE SURE THERE'S TRANSPARENCY TO THE ISSUE THAT'S BEING VOTED ON.
BOB? YEAH, JUST REAL QUICKLY, A COUPLE OF THINGS.
UH, THE FIRST ONE IS NONE OF US BENEFIT FROM THE GRID GOING DOWN.
THAT WOULD BE THE WORST THING THAT COULD EVER HAPPEN.
'CAUSE NUMBER ONE, WE'RE GONNA BE BACK INTO A WORLD THAT NONE OF US LIKED.
SO TO SAY THAT, YOU KNOW, THAT, THAT THAT'S A POTENTIAL OUT THERE, IT NEEDS TO BE REALLY, REALLY STATED CLEARLY, AND WE NEED TO SOLVE THAT PROBLEM 'CAUSE IT DOESN'T BENEFIT ANYBODY.
UH, HOWEVER, WITH THAT SAID, THERE'S BEEN A LOT OF TALK ABOUT RELI ERCOT RELIABILITY.
THERE'S BEEN A LOT OF TALK AND INSINUATIONS THAT IF YOU'RE ATTACK MEMBER AND YOU DON'T VOTE FOR ERCO PROPOSAL, YOU'RE AGAINST RELIABILITY ON THE SYSTEM AND YOU'RE READY TO SHUT IT DOWN.
THAT TO ME, SHOULDN'T BE SAID IN THIS ROOM.
UH, WITH THAT SAID, UH, I'M GONNA SUPPORT THE JOINT COMMENTERS, OF COURSE I MADE THE MOTION TO AMEND.
UH, BUT I THINK WE NEED TO REALIZE THAT THESE ARE JUST KEY DIFFERENCES BETWEEN TWO GROUPS LOOKING TO GET TO THE SAME GOAL IN DIFFERENT DIRECTIONS.
AND THE QUESTION IS, IS WHICH ONE IS GOING TO GET THERE AND GET THERE IN THE MOST REASONABLE MANNER, AND THEN EVERYONE WILL VOTE THE WAY THEY WANNA VOTE.
BUT I DON'T LIKE THE IDEA OF SOMEONE SAYING THAT IF YOU DON'T VOTE FOR ONE, YOU'RE AGAINST RELIABILITY.
AND I JUST WANT TO CLARIFY THAT IT'S NOT WHAT WE'RE HERE FOR.
[02:05:02]
THANK YOU, BOB.AND, AND THANKS FOR YOUR COMMENTS AND, AND JENNIFER, FOR YOURS AS WELL.
EVERYBODY HAS THEIR OWN PERSPECTIVE ON RISK AND RELIABILITY.
I THINK THAT IS THE POINT OF HAVING THIS STAKEHOLDER GROUP ATTACK AND CERTAINLY THE, THE RELIABILITY SUBCOMMITTEE GROUP AS WELL.
UM, THAT, THAT'S WHY I REALLY WANTED TO DRILL DOWN WITH ERCOT ON THEIR PERSPECTIVE ON THE COMMERCIALLY REASONABLE, BECAUSE I THINK YOU SHOULD BE CLEAR ON WHAT YOUR PERSPECTIVE IS.
BUT A GENERATOR'S PERSPECTIVE ON RELIABILITY CAN BE DIFFERENT AND THAT'S APPROPRIATE.
AND A LOAD SERVING ENTITY'S PERSPECTIVE ON RELIABILITY CAN BE DIFFERENT AND THAT'S APPROPRIATE AS WELL AS A, A TSPS AS WELL.
UM, THAT SAID, I THINK WE HAVE HAD VERY PRODUCTIVE CONVERSATION.
UM, YOU KNOW, I, I'M NOT ADVOCATING TO TABLE AND ANNE WILL GET MAD AT ME, BUT, BUT I JUST WANTED TO BE CLEAR.
THIS IS SET TO GO TO THE APRIL BOARD.
IF IT WOULD COME BACK TO TAC WE COULD PROBABLY QUE STILL SQUEEZE IT IN TO THE, THE APRIL BOARD AS WELL.
BUT I JUST WANTED TO BE CLEAR ON, ON THAT TIMELINE.
UM, AS YOU MENTIONED AHEAD, JENNIFER, AHEAD OF SUMMER, SO RIGHT NOW THIS IS SCHEDULED FOR THE, THE APRIL BOARD.
UM, IF WE REALLY NEEDED IT, APRIL TECH, WE COULD PROBABLY MAKE THAT STILL HAPPEN AT THE APRIL BOARD.
I I DON'T KNOW IF WE WOULD NEED AN UPDATED IMPACT ANALYSIS, UM, FOR EITHER VERSION.
MAYBE NOT FOR ERCOT VERSION, BUT I I DON'T BELIEVE THAT THERE'S A LONG IMPLEMENTATION TIME.
YEAH, IF YOU'LL LOOK AT THE VERSIONS, THEY INCLUDE A RIO.
SO THERE WILL NEED TO BE REVISIONS TO IMPACT ANALYSIS DEPENDING ON, ON EITHER VERSION.
SO ARE WE READY? THE, THE MOTION ON THE TABLE ABOUT AN HOUR AND A HALF AGO.
SO THIS IS ACTUALLY KIND OF WHAT I EXPECTED IN LENGTH OF TIME FOR CONVERSATION WAS A MOTION.
THE FIRST MOTION MADE WAS TO APPROVE KOTS THREE 20 COMMENTS.
AND THEN WE HAD A MOTION TO AMEND.
AND THAT MOTION TO AMEND IS WHAT WE ARE VOTING ON, WHETHER TO ACCEPT THE MOTION TO AMEND OR NOT.
AND THAT WOULD AMEND THIS FIRST MOTION SO THAT THE THEN SECOND MOTION WE WOULD TAKE WOULD BE VOTING TO APPROVE THE JOINT COMMENTERS VERSION.
OKAY, I SEE TWO PEOPLE IN THE QUEUE.
BOB WHITMEYER, UH, JUST, JUST FOR CLARITY, A MOTION TO AMEND REQUIRES WHAT PERCENTAGE TO PASS? UH, IT'S TWO THIRDS, BUT THANKFULLY HERE EVERYTHING AT TAC HAS TWO THIRDS, SO THANK YOU.
YOU'RE THINKING OF PRS WHEN WE START GETTING TO HASH OUT 50% VERSUS TWO THIRDS HERE.
EVERYTHING HAS THE SAME BAR TO CLEAR.
DID THAT ANSWER YOUR QUESTION, JENNIFER? NO, I JUST WANTED TO CONFIRM THAT THE JOINT COMMENTERS WANT TO MAINTAIN THEIR FULL COMMENTS, THAT THEY DON'T HAVE A, A MORE SIMPLIFIED MOTION THAT STARTS WITH
WE'RE JUST DOING MOTION TO AMEND ON THE FULL JOINT COMMENTER.
UH, WE DID BASE OUR COMMENTS ON THE JANUARY ERCOT COMMENTS, SO WE DID INCLUDE MANY OF THE THINGS THAT WERE IN THE JANUARY COMMENTS.
UM, IT WOULD BE A STRUGGLE TO BASE NEW COMMENTS, UH, TODAY FROM ERCOT COMMENTS LAST WEEK.
UM, IF TAC DIRECTS US TO, WE'RE HAPPY TO TRY TO DO THAT, BUT THAT'S NOT SOMETHING THAT COULD HAPPEN TODAY.
OKAY, COREY? I THINK WE CAN GO AHEAD.
WE'RE VOTING TO APPROVE THE JOINT COMMENTERS, OR WE'RE JUST VOTING ON A MOTION.
WE'RE VOTING ON A MOTION TO AMEND THE, WHAT I WOULD CALL THE SUBSTANTIVE MOTION.
AND THEN THAT WOULD BE THE VOTE.
SO IF YOU VOTE FOR THIS, YOU ARE SAYING THAT THAT SECOND VOTE WILL BE TO VOTE ON JOINT COMMENTERS VERSION.
IF YOU VOTE AGAINST IT THAT SECOND, YOU'RE SAYING YOU WANT THE SECOND VOTE TO BE TO VOTE ON THE ERCOT THREE 20 VERSION.
AM I ALLOWED TO PUT IT THAT WAY? NO, YOU, YOU, YOU'RE, THERE'S NO WAY TO EXPLAIN IT.
THAT'S NOT CLEAR AS MUDS, BUT YES, ERIC, THIS IS, THIS IS THE MOTION TO DECIDE WHICH SET WHICH MAIN MOTION YOU WANT.
UH, RICHARD AND JIM TEED UP THE ERCOT COMMENTS TO VOTE ON THE ERCOT COMMENTS.
BOB HAS NOW SAID, LET'S INSTEAD VOTE ON THE JOINT COMMENTERS COMMENTS.
SO THIS, THIS VOTE IS JUST TO DECIDE WHICH MAIN MOTION YOU WANT TO CONSIDER.
SO TO CAITLIN'S POINT, IF YOU WOULD LIKE TO MOVE FORWARD WITH THE JOINT COMMENTERS, YOU SHOULD VOTE YES ON THIS.
IF YOU'D LIKE TO CONSIDER THE ERCOT COMMENTS OR ANY OTHER MOTION, YOU'D NOT VOTE YES ON THIS, BUT, BUT IT'S NOT A VOTE UP OR DOWN ON EITHER OF THE COMMENTS.
YOUR VOTE ON THIS WILL HAVE NO ON THE MOTION BEARING ON YOUR SUBSEQUENT VOTE.
[02:10:02]
DO YOU KNOW WHAT YOU'RE DOING? I GOT IT.SO ON THE MOTION, ON THE MOTION TO AMEND THE MAIN MOTION, WE WILL START UP WITH THE CONSUMERS WITH NAGE ABSTAIN.
AND THEN NARA FOR ERIC EPSTEIN.
ERIC SCHUBERT, YOU WITH US? ALL RIGHT ABOUT MARK? YES.
THANK YOU LUCAS FOR JOHN? NO, THANK YOU, SIR.
ONTO OUR INDEPENDENT GENERATORS.
MOVING ON TO OUR IPMS AND LATE BREAKING ASSIGNMENT, UH, IAN'S CARRYING SETH'S VOTE.
AND I'LL GO AND TAKE YOURS NOW, IAN FOR, OR SORRY, IAN FOR REMI.
AND LET'S GO AND GET THE HAT TRICK.
YOU DIDN'T WANNA SIGN THAT TO IAN? ALL RIGHT, FAIR ENOUGH.
KEITH? NO, THANK YOU, JIM FOR DAVID.
MOVING ON TO OUR MUNIS, RUSSELL.
ERIC SCHUBERT VOTE YES IN CHAT.
59%, FOUR 41% AGAINST, WITH THREE ABSTENTIONS.
OKAY, SO THAT MEANS WE ARE NOW THE MOTION TO AMEND FAILED.
SO RICHARD'S ORIGINAL MOTION STANDS, CORRECT? CORRECT.
NOW THE MOTION IN FRONT OF Y'ALL IS TO RECOMMEND APPROVAL OF NO 2 45 AS RECOMMENDED IN THE ROSS REPORT AS AMENDED BY THE MARCH 20TH ERCOT COMMENTS.
AND DEBATE CAN CONTINUE ON THAT NOW, IF, OKAY.
SO CAN CONTINUE OR WE CAN VOTE.
UM, ANY COMMENTS WE WANNA TAKE AT THIS TIME? ALL RIGHT, GREAT.
COREY, WHY DON'T WE TEE UP THAT MOTION.
SO IT IS THE MOTION TO RECOMMEND AS, AS OUT OF THE ROSS REPORT A AS AMENDED BY THE ERCOT THREE 20 COMMENTS.
MOTION WAS MADE BY RICHARD AND SECONDED BY JIM, I BELIEVE.
AND SO WE ARE, SO NOW WE ARE VOTING ON A SUBSTANTIVE UP OR DOWN MOTION.
GIMME A SECOND TO GET THAT BALLOT.
WE CAN'T PUT THIS ON THE COMBO BALLOT.
WE'RE, WE ARE TOTALLY SLAYING THAT IS THAT THE THEME OF THE MONTH IS WE'RE SLAYING.
UM, COREY, COULD YOU REMIND US IF A MOTION ATTACK DOES NOT PASS TO APPROVE A, A NOER, WHAT IS THE OUTCOME? AND DO ANY STEPS NEED TO BE TAKEN IMMEDIATELY AFTER? UH, THANK YOU IAN.
IF I KNOW, IF A MOTION TO RECOMMEND APPROVAL FAILS AND THERE IS NO SUBSEQUENT MOTION, THAT REVISION REQUEST WOULD BE DEEMED REJECTED.
AND THEN WHEN A REVISION REQUEST IS DEEMED REJECTED, IT CAN BE APPEALED TO THE NEXT, UH, POSITION UP THE LADDER OF STAKEHOLDER CONCERN.
UH, BUT ALSO IN THAT IT'S IF NO
[02:15:01]
OTHER MOTION IS MADE.SO IF A MOTION RECOMMEND APPROVAL FAILS, ANOTHER MOTION TO RECOMMEND APPROVAL WITH SOME OTHER SET OF COMMENTS, A MOTION TO TABLE COULDN'T REVIVE IT FROM THE, UH, IMMINENT REJECTION.
SO POTENTIALLY, UH, I WON'T CALL IT FRIENDLY, BUT COMPASSIONATE, UH, MOTION TO TABLE UNTIL NEXT MONTH, UH, MAY BE NEEDED SO THAT WE'RE NOT BACK HERE IN A FEW MONTHS.
WHAT? SO, SO IF IF THE MOTION FAILS, WE CAN, IT'S DEEMED REJECTED SO WE DON'T HAVE TO DO ANYTHING.
BUT WE COULD TAKE UP A MOTION TO TABLE.
I'M SAYING THAT'S GONNA BE BAD FOR EVERYBODY IF IT'S DEEMED REJECTED.
SO I'M SAYING LET'S JUST MAKE A MOTION TO TABLE IF IT ISN'T APPROVE.
WELL, WE COULD IMMEDIATELY THEN TAKE A MOTION TO THE TABLE.
THAT'S, THAT'S WHY I WAS REMINDING PEOPLE.
CAN WE STILL TAKE THIS? YOU'RE NOT TRYING TO SUPERSEDE THIS MO MOTION ON THE TABLE THOUGH, CORRECT? NO, I WAS JUST TRYING TO GET OUR DUCKS IN THE LINE FOR IN CASE THIS DOESN'T PASS.
THAT'S ALL I WAS TRYING TO DO.
AND IF THIS DOESN'T PASS, I BELIEVE WE, WE COULD TAKE UP ANOTHER MOTION TO APPROVE AS WELL, BECAUSE THE MOST OF US BROUGHT LUNCH SUBSTANTIVE.
LUNCH IS, WE COULD ALSO DO HERE, BUT I, YOU KNOW, DIDN'T WANNA INFLUENCE THE VOTE.
YOU GUYS HAVE TO GET THROUGH THIS BEFORE YOU CAN HAVE LUNCH.
SO THE MOTION IS TO RECOMMEND APPROVAL OF NORE 2 45 AS RECOMMENDED BY ROSS IN THE SEPTEMBER ROSS REPORT.
AND AS AMENDED BY THE THREE 20 ERCOT COMMENTS.
YEAH, I JUST WANTED TO MAKE SURE OVER THAT LAST COMMENT, WE ARE SPECIFICALLY JUST VOTING ON THE MOTION FOR ERCOT COMMENTS.
THE LAST VOTE HAD NOTHING TO DO WITH PROVING OR DISAPPROVING THE JOINT COMMENTERS THAT IT DID NOT, IT WAS JUST THE MOTION.
SO I WANNA MAKE CLEAR THAT, 'CAUSE YOU, YOU PUT REJECTION IN SOMEBODY'S MIND WHENEVER IAN WAS TALKING ABOUT THAT, WHICH WAS, WAS GOOD.
BUT JUST BECAUSE THIS ONE GOES DOWN, IF IT DOES, THAT DOESN'T MEAN THAT THIS IS REJECTED.
THERE WOULD COULD BE AGREED WILL BE ANOTHER MOTION THAT WOULD GO A DIFFERENT DIRECTION AND THEN WE COULD VOTE ON THAT.
AND IF THAT FAILED, THEN WE COULD DO THE TAPE.
YES, WE CAN CONTINUE KIND OF THROWING THAT OUT THERE TO MAKE SURE EVERYBODY KNEW EXACTLY WHAT IS WILL HAPPEN UNDER DIFFERENT CIRCUMSTANCES.
WE CAN CONTINUE TO TAKE OTHER MOTIONS TO APPROVE.
MY UNDERSTANDING IS YOU CAN'T TAKE THE EXACT SAME MOTION TWICE WITHOUT SUBSTANTIVE DISCUSSION, BUT WE HAVE NOT TAKEN ANY SUBSTANTIVE MOTION SO FAR.
WE HAVE NOT UP OR DOWN VOTED ON JOINT COMMENTERS.
WE JUST UP OR DOWN VOTED ON A MOTION TO AMEND.
RICHARD, THAT'S, I JUST WANNA BE IN THE QUEUE AFTER THIS VOTE IF I CAN DO IT.
SO NOW WE ARE BACK TO A MAIN MOTION TO RECOMMEND APPROVAL OF NORE 2 45 AS RECOMMENDED BY ROSS IN THE SEPTEMBER, 2023 ROSS REPORT AS AMENDED BY THE MARCH 20TH ERCOT COMMENTS, CORY, BEFORE YOU, IT'S EXTRA TO RECOMMEND INSTEAD OF RECOMMENDED JUST KEEPING THE RECORD STRAIGHT.
OH YEAH, THAT CHANGES EVERYTHING.
JUST A CROSS TS DOT I'S, THANKS JIM.
BONUS POINTS FOR JIM PAYING ATTENTION.
ALRIGHT, SO NOW THE MOTION TO RECOMMEND ENGLISH IS HARD.
WE WILL START UP WITH THE CONSUMERS WITH NASH ABSTAIN.
FOR NICK, UH, RELUCTANTLY, NO.
UNDER OUR INDEPENDENT GENERATORS.
ONTO OUR IPMS. IAN FOR SETH? NO, THANK YOU.
HOW ABOUT IAN FOR RASHMI? NO, THANK YOU.
BILL? YES, THANK YOU, JENNIFER.
[02:20:03]
YES, THANK YOU CHRIS.KEITH? YES, THANK YOU JIM FOR DAVID.
56 OPPOSED WITH THREE ABSTENTIONS.
NOW THERE IS NO CURRENT MOTION ON THE TABLE.
RICHARD, MY QUESTION ABOUT TABLING, I I'M NOT INTERESTED IN TABLING PERSONALLY.
UH, I'D REALLY LIKE US TO JUST LEAVE IT IN THE SITUATION THAT IT IS IN.
I THINK THAT PUTS BOTH ERCOT AND JOINT COMMENTERS IN A POSITION TO APPEAL, UH, THIS TO THE BOARD.
UH, MY QUESTION IS, IN THE EVENT SOMEONE TABLES, DOES THAT IN ANY WAY PRECLUDE ERCOT ABILITY TO APPEAL THIS DECISION TO THE BOARD? WE'VE TAKEN AN ACTION.
IT CAN BE APPEALED RIGHT NOW, SO YEAH, IF IZED THE TABLE, THEN ANYBODY CAN STILL APPEAL THAT MOTION TO THE BOARD.
YEAH, I BELIEVE YOU CAN APPEAL ANY MOTION THAT IS MADE HERE.
I HOPE ERCOT DOES THAT, BUT I JUST, IF I COULD MAKE A REQUEST TO RICHARD, IF IT'S OKAY, I'M NOT, I THINK BOB WOULD LIKE TO MAKE A MOTION ON OUR COMMENT JUST SO PEOPLE CAN GET ON THE RECORD.
JUST SO WE HAVE AN UP OR DOWN VOTE ON BOTH OF THEM.
YEAH, THAT'S EXACTLY WHAT I WAS GONNA DO TO MAKE SURE THAT WE DID HAVE AN UP OR DOWN ON BOTH.
I'D, I'D MOVE THAT, UH, T RECOMMEND APPROVAL OF NOGA 2 45, AS WAS STATED UP THERE WITH THE ROSS COMMENTS ON THEIR DATE WOULD WITH THE JOINT COMMENTERS ON THEIR DATE.
I DON'T KNOW IF THEY CAN HEAR YOU ON THE PHONE, BUT THE MOTION WAS, GO AHEAD.
YEAH, THE MOTION WAS TO APPROVE THE, UH, NORE 2 45 UH, AS, AS RECOMMENDED BY ROSS WITH THE JOINT COMMENTER'S COMMENTS, WHICH WERE THE 21ST, OR, I CAN'T REMEMBER.
OKAY, SO WE NEED A SECOND ON THAT MOTION.
DAVID, KEY SECONDS AND CHRIS IN THE QUEUE.
LET'S, LET'S GIVE IT TO DAVID.
SO NOW WE HAVE A MOTION TO RECOMMEND APPROVAL OF NOER 2 45, AS RECOMMENDED BY THE SEPTEMBER ROSS REPORT AS AMENDED BY 3 22 JOINT COMMENTERS MOTION, UM, FROM BOB HELTON AND SECOND FROM DAVID KEY.
LET'S, UH, MIKE WISE QUESTION FOR ERCOT.
UH, WHAT IS YOUR VIEW OF THIS PARTICULAR MOTION RIGHT NOW? IF IT GOES UP, WHAT ARE YOU GONNA DO IF IT GOES DOWN, WHAT ARE YOU GONNA DO? I THINK AS IT STANDS RIGHT NOW, IF THE JOINT COMMENTER'S, UH, LANGUAGE WAS APPROVED BY TAC, WE WOULD APPEAL TO THE BOARD.
WE WOULD APPEAL TO THE COMMISSION, AND WE'RE GONNA CONTINUE TO DO WHATEVER WE NEED TO DO TO ENSURE RELIABILITY, WHETHER THAT'S REACHING OUT TO OTHER INDUSTRY STAKEHOLDERS, WE'RE GONNA REACH OUT TO OUR COUNTERPARTIES IN OTHER REGIONS.
IF I NEED TO CALL THE, UH, FEDERAL ENERGY REGULATORY COMMISSION STAFF THAT I'M AWARE OF, WE'RE GONNA CONTINUE TO ESCALATE THIS VERY GRAVE RELIABILITY CONCERN TO WHATEVER WE NEED TO DO TO MAKE SURE THAT RELIABILITY IS SERVED.
SO IT'S CLEAR TO ME THAT YOU SEE THIS AS A NEGATIVE AND A, UH, MEASURABLE, MEANINGFUL, UH, NEGATIVE IMPACT ON RELIABILITY.
WITH THE INCREASING LEVEL OF INVERTER BASE RESOURCES ON THE ERCOT SYSTEM, AND WITH THE, UH, COMPROMISES TO EXTEND BEYOND THE COMPROMISES THAT WE'VE ALREADY ALLOWED, WOULD GO BEYOND WHAT WE FEEL IS ALLOWED IN OUR CHARGE IN THE SUBSTANTIVE RULES THAT WHERE WE WOULD BE IN VIOLATION, BECAUSE WE'RE NOT ASSURING RELIABILITY.
BOB HILTON, I SEE YOUR CARD UP AGAIN.
BASED ON THAT QUESTION, THAT ANSWER, I JUST CAN'T BE QUIET.
UH, I'LL GO BACK TO WHAT I SAID EARLIER.
WE'RE ALL HERE TO DO ONE THING, AND THAT'S HAVE A COMPETITIVE MARKET
[02:25:01]
THAT HAS THE HIGHEST RELIABILITY WE COULD GET TO MAKE SURE THE LIGHTS DON'T GO OUT.AND I'VE SAID THIS AGAIN, I'M GONNA SAY IT AGAIN, THAT THIS DIFFERENCE IS A DIFFERENCE IN MY MIND OF GETTING TO THE SAME PLACE JUST WITH DIFFERENT METHODS.
AND TO SAY THAT IF THIS BODY DOES NOT VOTE A CERTAIN WAY, YOU'RE GONNA BE SHUT.
VOTING TO SHUT THE GRID DOWN IS JUST UNACCEPTABLE.
AND I DON'T THINK IT'S VERY HELPFUL.
SO THAT'S WHAT I DIDN'T LIKE ABOUT THE LAST COMMENTS THAT WERE MADE, AND, UH, I UNDERSTAND WHY THEY'RE MAKING THEM.
UH, BUT I, I WOULD RATHER US SEE TO TRY TO WORK THIS OUT IN A, A MINIMAL MANNER RATHER THAN AN ARGUMENTATIVE MANNER.
UM, ANY OTHER COMMENTS BEFORE WE TAKE UP THIS MOTION? ERIC BLAKEY, UNDER THE RULES, NEW RULES.
WILL WE BE, IF WE SAY NO ON THIS, DO WE NEED TO GIVE AN EXPLANATION? YES, WE ARE NOT GONNA TAKE THOSE.
UM, IN REAL TIME THOUGH, ANN WILL SEND A EMAIL OUT.
AND SO I THINK FOR IF THE MOTION PASSES, MOTION PASSES.
SO IF THIS MOTION PASSES, WE WOULD, YOU KNOW, NOTE THE, THE OPPOSING VOTES FOR THE BOARD.
AND ANN, WE WON'T TRY TO TAKE THOSE IN REAL TIME, BUT THAT'S ONLY IF THE MOTION PASSES.
BUT YES, FOR, FOR THIS NOER, I THINK THAT WOULD BE FAIRLY TIME CONSUMING AND MAYBE REHASH A LOT OF THE ARGUMENT WE HAD.
SO ANN WILL TAKE THOSE, UM, BY EMAIL IN THE EVENT WE, WE NEED THOSE.
YOU'RE SLAYING IT ON, ON THE MOTION TO RECOMMEND APPROVAL OF NORE 2 45 WITH THE JOINT COMMENTER'S COMMENTS.
WE WILL START UP ONCE AGAIN WITH THE CONSUMERS, WITH NARA ABSTAIN.
AND THEN NA BARRAGE FOR ERIC ABSTAIN.
ERIC SCHUBERT? YES, THANK YOU.
AND LUCAS, FOR JOHN, THANK YOU.
ONTO OUR INDEPENDENT GENERATORS.
BRIAN, SAM, STILL WITH US? ALL RIGHT, CAITLIN? YES.
YES, THANK YOU, COREY, THANK YOU.
ONTO OUR IPMS. IAN FOR SETH? YES.
HOW ABOUT IAN FOR REMI? UH, YES.
KEITH? NO, THANK YOU JIM FOR DAVID.
35% OPPOSED WITH SIX ABSTENTIONS.
OKAY, SO I THINK WE CAN PAUSE AT THIS MOMENT.
WE, WE CAN JUST, BOTH VOTES FAILED, SO IT WOULD BE DEEMED REJECTED AND I THINK BOTH PARTIES WOULD BE ABLE TO APPEAL AT, AT THIS, AT THIS JUNCTURE.
UM, SO WE DON'T HAVE TO TAKE FURTHER ACTION UNLESS WE WANT TO.
JENNIFER, IN THE SPIRIT OF HAVING TAC BE THE BODY THAT I WANT US TO BE, I AS THE LSC, UM, WOULD LIKE TO PROPOSE A MOTION THAT ATTEMPTS TO BRIDGE THE GAP, RECOGNIZING THAT IT IS MEANT TO GIVE THE BOARD DIRECTION FROM TAC NOT BE CRUCIALLY SPECIFIC ON THE DETAILS OF THE COMMENTS IN QUESTION.
SO COULD I PROPOSE A MOTION FOR THIS, FOR A VOTE? YEAH, OF COURSE, OF COURSE.
I WOULD PROPOSE THAT TAC APPROVE THE ROSS, UH, APPROVED VERSION OF 2 45,
[02:30:01]
RECOMMENDED VERSION OF 2 45 WITH KOTS COMMENTS AND THE FOLLOWING THREE AMENDMENTS.FIRST, THAT WE WOULD LIKE THE BOARD TO BE MINDFUL OF RETROACTIVE APPLICATION TO IVRS.
SECOND, THAT WE WOULD LIKE THE BOARD TO BE MINDFUL OF TENABLE HARDWARE UPDATES.
AND THIRD, THAT WE WOULD LIKE THE BOARD TO, I'M MISSING ONE.
HOLD ON,
CORY, ARE YOU, SO, SO WHAT I, I GUESS JENNIFER, WHAT, WHAT, WHAT ARE WE ASKING THE BOARD TO DO HERE? WHEN, WHEN WE'RE USING BE MINDFUL? ARE WE, ARE WE ASKING? IT DOESN'T HAVE THEM TO AMEND, JUST TO AMEND THE COMMENTS TO BASICALLY SAY WE AS TAC, WE WOULD APPROVE ERCOT COMMENTS ON THE ROSS APPROVED AND HAVE THREE PRINCIPLES THAT TAC WOULD LIKE APPLIED TO KOTS COMMENTS.
SO WE, WE WOULD BE ASKING THE BOARD TO PRODUCE A NEW VERSION OF NO GER 2 45, I THINK SO, SORRY, I KNOW THIS IS A BIT OF A CONVERSATION, BUT WHEN 1186 WENT FORWARD, WHAT ENDED UP IN 1186 WAS NOT THE TECH APPROVED.
WHAT I WOULD LOVE TO SEE IS FOR TECH TO COME TOGETHER ON A VOTE THAT SAYS IN SUBSTANCE, WE ARE ALIGNED THAT IN SUBSTANCE, THERE IS NOT A RELIABILITY CONCERN HERE, EXCEPT THAT WE THINK THAT THERE ARE VALID POINTS TO BE MADE BY BOTH ERCOT AND THE JOINT COMMENTERS.
AND WE WOULD LIKE, LIKE THAT JUST A CO LIKE THE, THE TWO OR THREE POINTS THAT HAVE BEEN THE, THE DEPTH OF THIS DISCUSSION, BUT THAT WE APPROVE SOMETHING OUT OF TAC, I GUESS IS MY ASK.
I THINK WE WOULD WANT THE LANGUAGE FROM TAC UM, COREY, I'LL LET COREY WEIGH IN AND THEN I SEE ERIC GOFF AND, AND BOB HILTON.
I THINK THE CLOSEST THING WE COULD GET TO THAT WOULD BE IF WE WANTED TO REVISE AZT, ANYBODY SETS OF COMMENTS TO ADD IN LANGUAGE TO THE COVER PAGE OF THE NOER.
UH, WE'VE DONE THIS IN THE PAST SOMETIMES YEAH.
WITH BUSINESS CASES OR JUST NOW IT'S JUSTIFICATION FOR RE BUT, OR IF WE WANNA SUNSET DATE OR SOMETHING, REVIEW FOR THINGS TO SAY WHAT IF, IF WE NEEDED TO PUT IN ANYTHING TO SAY THIS IS WHAT IT IS AND WHAT IT ISN'T, AND WE WANNA MAKE IT ABUNDANTLY CLEAR IN ADDITION TO WHATEVER'S IN THE TAC MINUTES THAT WOULD BE COMING OUT, UH, AFTER A DECISION.
BUT THAT'S THE CLOSEST WE COULD GET IN TERMS OF VOTING ON OR REVISION REQUEST WITH MODIFYING IT, WE WOULD NEED TO PUT THE ACTUAL WORDS ON THE SCREEN YEAH.
SO THAT EVERYONE AROUND TECH COULD SEE.
HERE ARE THE RED LINE COMMENTS TO THE NODAL OPERATING GUIDE.
AND THEN, NOW HERE'S THE, COMMENTARY ISN'T THE RIGHT WORD, BUT HERE'S THE OTHER LANGUAGE WE WANNA PUT IN TO MAKE IT ABUNDANTLY CLEAR ON THE COVER PAGE OF THIS THING.
HERE ARE THE, WHATEVER, ANY OTHER THINGS THAT WE WANTED TO PROVIDE ON THE FRONT AND CENTER ON THE COVER PAGE THAT WOULDN'T ALREADY BE IN THE, THE MINUTES OR IN THE TAC PRESENTATION TO THE BOARD.
WE WOULD, WE WOULD NEED TO GET THAT, THOSE WORDS ALL AGREED ON.
WE WOULD NEED THE WORDS TO VOTE AND WE CAN DO THAT.
WE, WE CAN TAKE A BREAK FOR LUNCH AND WE HAVE, YOU KNOW, MORE OF AN AGENDA.
SO WE COULD TAKE A BREAK AND DO THAT.
LET, LET'S TAKE THE OTHER COMMENTS.
BUT THAT CERTAINLY IS, IS AN OPTION WE WOULD NEED TO SEE THE LANGUAGE THAT WE ARE VOTING ON.
SO I THINK IT'S ERIC, THEN BOB HILTON, THEN BILL BARNES.
AND, AND MAYBE THIS WILL HELP IN GENERAL, IF, IF WE'RE GONNA, SO LUNCH IS OUTSIDE.
IF THERE'S SOME DISCUSSION ABOUT SOMETHING THAT COULD GET THE ONE OR TWO MORE VOTES NECESSARY THAT WE COULD PASS TODAY.
THAT'S WHAT I WANNA DO AT LUNCH.
MAYBE WE JUST NEED SOME, TAKE SOME TIME TO TALK.
YEAH, JUST, JUST REAL QUICKLY ACTUALLY, JENNIFER, THANKS.
I APPRECIATE WHERE YOU'RE TRYING TO GO WITH THAT, WHERE YOU'RE TRYING TO GO WITH THAT.
LEMME GET NEAR THE, THE MIC QUESTION IS, WHY DON'T YOU JUST SAY IT THE OTHER WAY AROUND.
APPROVE THE JOINT COMMENTERS WITH THE SAME CONCERNS.
SO TO ME, IT LOOKS IT WHEN YOU, WE DO THAT, WE'RE GIVING SOME INDIFFERENCE TO WHO, WHOEVER COMMENTS GET PASSED.
AND THAT CONCERNS ME TO SOME DEGREE WE'RE SAYING.
'CAUSE ACTUALLY I WOULD EXPECT THE BOARD TO DO JUST EXACTLY WHAT YOU'RE SAYING, REGARDLESS OF WHICH ONES WAS
[02:35:01]
APPROVED.SO THAT'S, THAT'S WHAT MY ONE CONCERN WITH THAT.
THERE'S ALSO ANOTHER AVENUE, UH, ON ANY ONE OF THESE TWO MOTIONS.
ANYONE THAT VOTED AGAINST IT, I'M NOT SURE ABOUT ABSTENTIONS, IF THEY CAN OR NOT, COULD ASK FOR A MOTION TO REVOTE.
AND IF SOMEBODY WANTED TO CHANGE THAT VOTE TO GET THIS OVER THE TOP, THEY COULD DO SO.
I DON'T KNOW IF WE CAN REVOTE ON THE EXACT SAME MOTION WITHOUT A MOTION TO RECONSIDER.
YOU HAVE TO VOTE AND IT HAS TO BE SOMEONE TO RECONSIDER VOTED AGAINST IT.
OR I'M NOT SURE ABOUT ABSTENTIONS, ABSTENTIONS DO THAT, BUT I DON'T KNOW.
WE'D HAVE TO DO A VOTE TO RECONSIDER FIRST POINT OF VOTER.
A MOTION TO RECONSIDER IS FOR A SUCCESSFUL VOTE.
AND WE HAVEN'T HAD A SUCCESSFUL VOTE.
HAVEN'T HAD A SUCCESSFUL VOTE.
FIGURE ALL THAT OUT OVER THE BREAK.
THERE MIGHT BE ANOTHER OH, OKAY.
LET'S TAKE THE QUEUE FOR EVERYBODY LISTENING, AND THEN YES, WE CAN DO A LOT OF THINGS OVER BREAK, BUT WE'RE NOT THERE YET.
LET'S TAKE BILL BARNES AND THEN WE CAN BREAK FOR 30 MINUTES AND EAT LUNCH AND HAVE THESE DISCUSSIONS.
I'M ACTUALLY, I OUTTA THE QUEUE, BUT SINCE YOU'RE GIVING ME THE OPPORTUNITY, WHAT ARE WE GONNA DO ABOUT THE, YOU WERE IN THE QUEUE.
YEAH, I PUT MY CARD DOWN THOUGH, ERIC PRETTY MUCH TOOK MY COMMENTS.
BUT ARE WE GONNA HAVE A HARD STOP FOR THE DRS WORKSHOP OR ARE WE GONNA KEEP GOING? I BELIEVE DRS WORKSHOP CAN, IT'S LATER OF WHEN TECH, IT'S AFTER TECH.
SO WE COULD START AT FIVE MAYBE.
IDEALLY WE WOULD NOT START AT FIVE.
I DON'T BELIEVE WE HAVE I MAYBE AN HOUR FOR THE AGENDA AFTER THIS.
IT'S, IT'S NOT A LENGTHY AGENDA AFTER THIS.
SO WE'RE STILL TALKING ABOUT MAYBE WITH A HALF HOUR BREAK.
MAYBE TWO OR TWO AND A HALF HOURS AT MOST.
STEVEN, UH, I JUST REALLY NEEDED TO ADDRESS THE TWO OPTIONS ON THE TABLE.
THE JOINT COMMENTERS, AND MAYBE ERIC CAN CLARIFY FOR ME, BUT DID Y'ALL BUILD UPON OUR COMMENTS OR DID YOU BUILD UPON WHICH, WHICH COMMENTS DID Y'ALL BUILD BUILD UPON THE JANUARY ERCOT COMMENTS? THAT'S RIGHT.
AND SO I NEED TO GO BACK, BACK IN DETAIL, BUT HOW EXTENSIVE WE PROVIDED YOU A DRAFT OF OUR COMMENTS, RIGHT? YEAH, I UNDERSTAND WHAT YOU'RE SAYING.
AND, AND THERE'S A LOT OF OTHER WORDING CHOICES THAT ARE BEYOND THE CORE ISSUES THAT ARE PROBLEMATIC.
SO I'M, I'M JUST IN YOUR PROPOSAL WANTING TO UNDERSTAND WHAT THINKING IS.
UH, YEAH, I'M HAPPY TO, TO, IF THERE THERE'S OTHER ISSUES YOU WANNA TALK ABOUT, I'M HAPPY TO TALK ABOUT 'EM.
UM, YOU KNOW, JUST TO COLOR IN THE CONVERSATION ABOUT WHAT YOU'RE SAYING SO THAT PEOPLE UNDERSTAND WHAT WE'RE TALKING ABOUT.
YOU GAVE US A, A EARLY DRAFT OF WHAT YOU ENDED UP SUBMITTING THAT WAS SLIGHTLY DIFFERENT THAN WHAT YOU ACTUALLY SUBMITTED.
WE TRIED TO INCORPORATE SOME OF THAT, BUT IF THERE'S SOMETHING THAT YOU WANNA MAKE SURE IS IN THERE, WE'RE HAPPY TO TALK ABOUT IT.
SO I, I THINK WITH THAT BASIS OF TWO DIFFERENT PEOPLE BUILDING UPON, OBVIOUSLY WE'VE VETTED OUR COMMENTS RATHER EXTENSIVELY WITH OUR COT LEGAL, AND, AND WITH THAT IT CREATES A WHOLE SET OF CHALLENGES, ESPECIALLY ON SOME OF THE PROCESS LANGUAGE TO, TO START FROM THE JOINT COMMENTER'S LANGUAGE WITH ANY CHANGES.
SO MY ADVISEMENT WOULD BE THAT IF WE NEEDED TO MODIFY, IF, IF THAT WAS EVEN A STRATEGY, THAT IT WOULD BE FROM THE ERCOT COMMENTS THAT WE SEE WHAT NEEDED TO BE ADDED OR, OR ADJUSTED TO ADDRESS JOINT COMMENTERS CONCERNS NOT THE OTHER WAY AROUND OR ELSE IT WOULD BE TOO EXTENSIVE AND WE'D NEED TO VET IT.
I THINK LET'S, LET'S HAVE THIS DISCUSSION OVER LUNCH.
UM, AND WE WILL RESUME, LET'S RESUME AT 1245.
SO GIVE EVERYONE HALF AN HOUR TO DISCUSS YOUR NAME SHOULD BE ON YOUR LUNCH IS MY UNDERSTANDING.
WE ARE GOING TO TRY TO GET STARTED.
I'LL GIVE EVERYONE A MINUTE TO SIT DOWN, BUT NED'S HERE AND THAT'S IMPORTANT.
ARE YOU GETTING IN THE QUEUE? I JUST LIKE TO TELL PEOPLE WHAT WE DID.
I THINK, UM, OKAY, LET'S, LET'S PICK IT UP WHERE WE LEFT OFF BEFORE LUNCH, WHICH IS STILL ON 2 45.
WE HAD, UM, TWO FAILED SUBSTANTIVE VOTES ON THE ERCOT THREE 20 COMMENTS AND THEN THE JOINT COMMENTERS 3 22.
WE HAD SOME DISCUSSION AT LUNCH AND I BELIEVE WE MAY HAVE A NEW MOTION, BUT E ERIC IS GONNA SUMMARIZE.
[02:40:01]
YOU EVERYONE FOR TAKING LUNCH.I THINK ORDERING LUNCH WAS A GOOD IDEA.
UM, AND, UM, WE, UH, WOULD YOU SAY IT WAS A GENIUS IDEA? IT WAS A, OF COURSE IT WAS A GENIUS IDEA.
UM, AND, UH, WE, WE HAD, UH, THE JOINT COMMENTERS HAD DISCUSSION WITH, UH, THE RETAILERS AND WITH ERCOT DURING THE BREAK AND HAVE AGREED TO CONSIDER IF TAC WOULD ALLOW A COUPLE OF AMENDMENTS TO, UH, THE JOINT COMMONS APPROACH.
UM, MY UNDERSTANDING IS THIS DOESN'T SATISFY ORCAS CONCERNS, UM, BUT, UM, IT, IT'S STRIKING SOME THINGS THAT THEY EXPRESS CONCERN ABOUT.
SO, UM, THE MAIN CHANGE IS IN, WE, WE PROPOSED A NEW SECTION TWO POINT 14, UM, THAT, UM, IT'S ESSENTIALLY BACK AN AFTER ACTION, UH, PROCESS THAT ERCOT CHARACTERIZED AS LEADING TO CONTINUAL DEGRADATION.
WE DON'T BELIEVE THAT IT DID THAT, BUT, UM, WE'RE, WE'D BE HAPPY TO HAVE TAC RECOMMEND REMOVING IT.
AND THERE'S ANOTHER SECTION IN THE COMMERCIAL REASONABILITY SECTION ABOUT A, A REQUIREMENT ABOUT HOW YOU INSTALL SOMETHING.
AND SO I, WITH THAT, I'M, I'M HAPPY TO ANSWER ANY QUESTIONS, BUT I, I THINK THAT WE HAD A PRODUCTIVE LUNCHTIME DISCUSSION.
I THINK WE HAVE, UM, BOB IN THE QUEUE.
I SEE COREY HAS THE COMMENTS, UM, AND I KNOW ERCOT WANTS TO RESPOND, SO WHY DON'T I TAKE BOB THEN STEVEN.
UM, AND THEN WE'LL GO TO BILL BARNES.
SO I THINK WE'LL BE DOING THE MOTION.
WELL, I WAS GONNA GO AHEAD AND DO IT.
YEAH, I WAS GONNA GO AHEAD AND MOVE THE TAC APPROVE.
LET ME GET NEXT TO THE MICROPHONE.
DID YOU WANT, WELL, LET'S SEE.
THE TAC APPROVE NPRR OR NOT NPRR NOER 2 45 AS SUBMITTED BY ROSS, AMENDED BY THE JOINT COMMENTERS WITH THE FOLLOWING DESKTOP EDIT EDITS BY TAC AND THAT WOULD BE REMOVING SECTION TWO ONE, OH WAIT, 2 13 1 1 NUMBER 4 2 13 1 1 PARAGRAPH FOUR.
THIS RIGHT HERE, PARAGRAPH FOUR.
IF COMMERCIALLY REASONABLE SECTION, WE WOULD STRIKE THAT.
GIVE FOLKS A CHANCE TO LOOK AT WHAT'S BEING STRUCK.
THIS WOULD, THIS PARAGRAPH WOULD GO AWAY AS YES, THAT PARAGRAPH GOES AWAY.
ARE WE, ARE WE COMPLETED WITH THE EDIT? NO, WE'RE NOT COMPLETED WITH THE MOTION.
LET'S, LET'S FINISH THE MOTION AND THEN LET'S FINISH THE MOTION.
LET'S TAKE KOTS COMMENTS ON IT.
YEAH, BUT LET'S, LET'S GET THE MOTION ON THE SCREEN, COREY, AND GIVE PEOPLE TIME TO PROCESS IT.
THEN WE'LL TAKE KOTS COMMENTS ON IT, AND THEN WE WILL GO TO BILL BARNES AND THEN JOHN RUSS HUBBARD.
WHAT'S NEXT, BOB? THE NEXT ONE IS, WE WOULD REMOVE SECTION 2.14 IN ITS ENTIRETY, WHICH THAT'S THE ACTIONS FOLLOWING AN APPARENT FAILURE TO THE RIDE THROUGH WHICH ERCOT DID HAVE A MAJOR CONCERN WITH.
BUT I, I'LL LET THEM TALK FOR THEMSELVES.
HOLD ON A SECOND, BOB TO TWO 14, AS PROPOSED IN ITS ENTIRETY.
WELL, NO, BUT AS PROPOSED, IT'S REFERENCED UP IN OTHER SECTIONS SAYING THINGS LIKE, ENTITY SHALL TAKE ALL THE ACTIONS DESCRIBED.
DO YOU DROP THAT ALL TOGETHER OR DO YOU WANNA REVISE THAT TO SAY WHAT THE RESOURCE ENTITY WOULD DO? I THINK IT WOULD DROP REFERENCES TO, YEAH, ALL THE, ALL THE REFERENCES WOULD DROP.
SO FOR EXAMPLE, THIS PARAGRAPH EIGHT WOULD JUST GO AWAY ENTIRELY BECAUSE IT'S PREDICATED ON IF THIS HAPPENS DUE TWO 14, YES.
THAT'S WHAT HAPPENS WHEN YOU'RE DOING THINGS ON A FLY DURING LUNCH.
AND THEN SIMILARLY, LANGUAGE ABOUT FAILED TO PERFORM TWO 14 YES.
AND CORY, THERE'S ONE IN TWO 13, UH, 1, 2 13, 1 11
[02:45:04]
THAT I'M LOOKING AT RIGHT NOW.AND, AND WE'LL JUST ADD FOR PEOPLE THAT ARE CONCERNED ABOUT CHANGES IN THE FLY, THAT IF WE NEED TO MAKE CONFORMING COMMENTS AFTER THIS WE'LL FILE, IF NEED BE, WE CAN FILE COMMENTS TO THE BOARD TO CLEAN UP ANYTHING HERE.
UM, WE'RE, WE'RE HAPPY TO, TO MAKE SURE THE BOARD HAS A COMPLETE DOCUMENT.
WELL THIS WOULD GO IN TECH COMMENTS TO YEAH, THAT'S RIGHT.
THE BOARD, BUT IF NECESSARY IT MAYBE EXPLAINER COMMENTS OR SOMETHING.
SO OVERALL WHAT THE, WHAT THE MOTION DOES, IT REMOVES THE NUMBER FOUR UNDER 2 13 1 1.
THEN IT REMOVES, REMOVES TWO 14 AND ALL REFERENCES 2 4 2 14.
WELL, COULD YOU GIVE US JUST ONE SECOND? YEAH, I'M GETTING SOME ON THE FLY FEEDBACK.
COULD YOU, CAN WE, CAN WE TAKE COMMENTS? DO YOU GUYS WANNA GET WITH CORY AND LOOK AT THIS AND WE'LL TAKE COMMENTS FOR A MINUTE? THINK STEVEN HAS COMMENTS RIGHT THERE.
I'M GONNA TAKE SOME COMMENTS FROM STEVEN AND THEN IF SURE.
AND YOU GUYS CAN CONTINUE TO WORK MAYBE WITH COREY AND MAKING SURE THIS IS CLEANED UP.
SO THIS STEVEN LEASE FROM ERCOT, THE CHANGES YOU'RE MAKING MAKE IT WORSE BECAUSE YOU'RE COMPLETELY REMOVING ALL REFERENCES TO WHAT NEEDS TO BE DONE WHEN THERE'S A PERFORMANCE FAILURE.
WHAT WE HAD CHALLENGES WITH IS THE LANGUAGE IN THERE THAT SAID IF YOU DO, YOU ONLY HAVE TO IMPLEMENT COMMERCIALLY REASONABLE CHANGES AND THEN YOU SEEK AN EXEMPTION BEYOND THAT.
THAT'S THE PROBLEMATIC LANGUAGE.
SO THESE STRIKINGS AND REFERENCES YEAH.
TAKE AWAY ALL LANGUAGE ABOUT WHAT YOU HAVE TO DO.
ALL THE MODEL VALIDATION, EVERYTHING THAT WE HAD IN KOTS COMMENTS.
YEAH, I UM, WHAT IF WE, I THINK THE INTENTION WAS TO DO THAT, UH, AND RATHER THAN STRIKING TWO POINT 14, WE COULD ADD ER KAT'S LANGUAGE THAT YOU CAN'T MAKE THE CAPABILITY WORSE OVER TIME.
IF YOU WERE TO ADD THOSE PARAGRAPHS THAT WE HAD AND THAT REFERENCE THE OTHER SECTIONS, YOU'D HAVE TO THEN FURTHER MODIFY IT BECAUSE NOW THOSE SECTIONS THAT ERCOT HAD LANGUAGE IS NOT THE SAME SECTIONS IN, IN Y'ALL'S LANGUAGE.
BUT TO YOUR POINT, THAT WOULD GET YOU CLOSER TO WHAT YOU'RE TRYING TO ACCOMPLISH.
I, I HEAR YOU IN THE INTEREST OF TRYING TO GET SOMETHING DONE AT TAC IF WE ADDED LANGUAGE TO TWO 14 THAT SAID, UM, THAT YOU CAN'T, THAT THE ACTIONS FROM TWO 14 CAN'T MAKE THE CAPABILITY WORSE OVER TIME.
AND THEN IF WE NEED TO MAKE ANY OF THE CONFORMING CLEANUPS THAT STEVEN SUGGESTED, WE CAN FILE COMMENTS BEFORE THE BOARD DID MAKE ANY CLEANUP OF THIS CAP WITH THE INTENTION OF TAC WITH SPECIFIC RED LINE LANGUAGE.
SO IF YOU, UM, HAPPY TO HAVE CONVERSATIONS AROUND THAT, IF YOU WERE TO TAKE THAT LANGUAGE THERE THAT YOU JUST STRUCK, UM, AND IF YOU'RE GONNA KEEP THAT CONSTRUCT TO NOT HAVING WHAT YOU NEED TO DO THERE, THEN YOU HAVE TO MAKE THE MODIFICATIONS IN TWO 14 TO ACTUALLY ACCOMPLISH WHAT'S THE CONCERN.
AND, AND SO THEN YOU WOULDN'T STRIKE TWO 14, YOU WOULD KEEP TWO 14, BUT YOU'D HAVE TO MODIFY IT.
CAN I THINK WE SAY THE SAME THING? SO IF WE, IF YOU, IF WE, WE CAN, CAN YOU GUYS TAKE THIS OFFLINE AGAIN MAYBE, AND, AND WE CAN PRESENT TO COREY KIND OF YEAH.
THE COHESIVE 'CAUSE WE'RE DISCUSS THIS IN THE TIME.
WANNA, IF YOU WANNA GO BACK TO THE OTHER TECH BUSINESS.
WHY, WHY DON'T WE MOVE ON WITH THE AGENDA AND CIRCLE BACK TO THIS.
ALTHOUGH I THINK YOU LET THOSE TWO GET BACK SO THAT WE KNOW THE EXACT CHANGES THAT I NEED TO MAKE SOME MOTION UPON.
CORY, DOES THAT WORK FOR YOU? I GUESS YOU NEED TO KEEP RUNNING THE MEETING, BUT I DON'T KNOW IF YOU NEED TO BE IN THAT DISCUSSION OR NOT.
IF, IF, IF, CAN THEY, DO YOU WANT THEM TO EMAIL YOU A VERSION IF, IF POSSIBLE, LIKE AN INTERPRETIVE DANCE? NO, AN EMAIL WOULD BE GREAT IF Y'ALL, IF Y'ALL CAN, IF Y'ALL CAN MARK UP WHO, WHOEVER'S BASE COMMENTS, EITHER START FROM ERCOT AND WORK IN Y'ALL'S DIRECTION OR START FROM JOINT COMMENTERS AND WORK IN THE OTHER DIRECTION.
HOW LONG DO YOU GUYS NEED? DO YOU WANNA COME BACK TO THIS AT THE VERY END OF THE AGENDA? OR, SORRY.
THANK, THANK YOU JIM FOR A FUNNY COMMENT.
I THINK IT WAS JANUARY OF 2000 SOMETHING.
WE WILL COME BACK TO THIS FOR,
[02:50:01]
YOU KNOW, LET, LET'S COME BACK TO THIS RIGHT BEFORE OTHER BUSINESS.SO WE'LL RUN THROUGH EVERYTHING INCLUDING ERCOT REPORTS AND THEN TAKE THIS UP RIGHT BEFORE OTHER BUSINESS.
DOES THAT SOUND RIGHT TO EVERYONE? OKAY.
[7. RMS Report (Vote)]
NOW TO THE RMS REPORT.IS THAT JOHN TODAY? IT'S JOHN.
AND THANK YOU FOR BEING READY ON THIS.
I KNOW WE'VE TAKEN BREAKS AND GONE BACK AND FORTH, SO GO AHEAD JOHN.
OKAY, SO WE HAD TWO VOTING ITEMS FROM THIS RMS REPORT.
AND SO IT'S RECOMMENDED APPROVAL OF R-M-G-R-R 1 77 AS RECOMMENDED BY RMS IN THE THREE FIVE RMS REPORT AND THEN APPROVE THE RMS GOALS AS PRESENTED.
CAN WE ADD BOTH OF THESE TO THE COMBO BALLOT? JIM LEE SAYS YES.
NABA, DO YOU HAVE A COMMENT? I WOULD LIKE TO MAKE A SEPARATE BALLOT FOR THESE 1 77.
SO WE ARE DOING A SEPARATE BALLOT FOR R-M-G-R-R 1 77.
UM, SO THE MOTION WOULD BE RECOMMEND APPROVAL, UM, OF R-M-G-R-R 1 77 AS RECOMMENDED BY RMS IN THE THREE FIVE RMS REPORT.
SO WE WOULD NEED A MOTION AND A SECOND FOR THIS BALLOT.
CAN I GET A MOTION FROM JIM LEE SECOND FROM IAN HAILEY, DO WE NEED TO GET OR COMMENT FROM IAN HAILEY? I WAS COMMUNICATING WITH SOMEONE ACROSS, OKAY.
COMM COMMUNICATION FROM IAN HAILEY ACROSS THE ROOM.
SO MOTION FROM JIM LEE AND A SECOND FROM ANYONE? NO.
DO WE NEED TO FETCH ANYBODY FROM OUTSIDE DISCUSSIONS TO VOTE? LET'S, I WILL GO DO THAT, BUT GO AHEAD COR AND GET STARTED.
ON THE MOTION TO RECOMMEND APPROVAL OF RMGR 1 77 IS RECOMMENDED BY RMS. WE WILL START UP WITH THE CONSUMERS WITH N EPSTEIN.
AND THEN NAVA FOR ERIC EPSTEIN.
THANK YOU AGAIN ONTO OUR CO-OPS BLAKE FOR MIKE? YES.
ONTO OUR INDEPENDENT GENERATORS.
[02:55:03]
I UH, NO WORRIES.I DIDN'T GET YOU, UH, BUT I'VE GOT YOU NOW.
BACK TO OUR IRPS IAN FOR SETH? YES, FOR ALL THREE.
I DON'T GET TO ASK YOU EVERY TIME, BUT, ALL RIGHT, JEREMY? YES.
KEITH? YES, THANK YOU JIM FOR DAVID? YES, THANK YOU, COLIN.
UM, SO THEN THE SECOND VOTING ITEM ON THAT REPORT WAS TO APPROVE THE RS GOALS AS PRESENTED.
EVERYBODY FINE TO PUT THAT ON COMBO BALLOT.
[8. ROS Report (Vote)]
SO NOW WE ARE ONTO THE ROSS REPORT.KATIE, RICH, ARE YOU READY? THANKS, CAITLYN.
I WILL WAIT FOR MY SLIDES TO BE PULLED UP.
AND I BELIEVE WE NEED STEVEN FOR GER 2 55, SO WE ARE WORKING ON THAT AS WELL.
SO WE HAVE TWO VOTING ITEMS BEFORE YOU TODAY, NOER 2 55.
UM, WE DID APPROVE THE IA, LUMINANT DID ABSTAIN FROM THAT BECAUSE WE WERE GOING TO FILE COMMENTS, WHICH WE SUBSEQUENTLY DID.
UM, SO I WILL LET NED SPEAK TO THAT.
AND THEN WE ALSO APPROVED OUR ROSS GOALS, AND IF YOU WOULD TAKE US TO THE SECOND SLIDE, PLEASE.
SO HERE ARE SOME ITEMS WHERE WE HAVE APPROVED LANGUAGE, UM, THE SSWG PROCEDURAL MANUAL, AND THEN WE DO HAVE, UM, PAUL HOFFER FOR VICE CHAIR FOR DSWG.
SO THAT MAKES OUR LEADERSHIP COMPLETE AT ROSS, WHICH ALL MAKES US ALL VERY HAPPY WHERE THERE'S ENOUGH TO DO.
SO WE APPRECIATE EVERYONE WHO VOLUNTEERS TO SERVE IN THOSE ROLES.
UM, AND SO WE DO STILL HAVE, UM, WE DO STILL HAVE QUITE A LIST.
WE ARE GETTING REALLY CLOSE ON SOME OF THESE.
UM, SO I, I APPRECIATE MY LEADERSHIP.
EVERYONE'S DOING A VERY THOROUGH REVIEW AT ALL OF THE WORKING GROUPS, UM, AND MAKING SURE THAT THEY REVIEW ALL THE STAKEHOLDER COMMENTS BEFORE THEY COME BACK WITH A DECISION FOR US, UM, TO MOVE FORWARD AT ROSS.
AND THEN IF YOU WILL, TAKE US DOWN TO THE FOLLOWING SLIDE, PLEASE.
SO WE DID HAVE A VERY ROBUST DISCUSSION ABOUT THE SOUTH TEXAS GTCS.
I BELIEVE THAT WAS DISCUSSED LAST WEEK AT THE OPEN MEETING AS WELL.
UM, SO YOU CAN KIND OF SEE A LITTLE FLAVOR OF WHAT WE DISCUSSED.
UM, THERE WERE SOME COMMENTS THAT WERE SUBMITTED AHEAD OF TIME AND FREDDIE DID HIS BEST TO ADDRESS THOSE COMMENTS, RECOGNIZING THAT THERE WERE SOME CONFIDENTIALITY ISSUES BECAUSE IT WAS STILL WITHIN THE 60 DAY WINDOW.
AND, UM, I ALSO KNOW THAT THE RPG MEETING ALSO HAD SOME QUESTIONS ABOUT WHAT SHOULD GO INTO THAT PLANNING PROCESS SO THAT WE GET MORE ADVANCED NOTICE ABOUT THE GTCS GOING INTO EFFECT.
WE HAVE HAD A LOT OF, UM, CONFLICTS WITH OPEN MEETINGS THIS YEAR.
SO WE'VE GONE TO WEBEX FOR MANY OF THEM, BUT FOR ANYBODY THAT WOULD LIKE TO HAVE SOME FACE-TO-FACE TIME AT ROSS EQUAL FOURTH IS YOUR CHANCE.
AND WITH THAT, I WILL SEE IF THERE ARE ANY QUESTIONS FOR ME.
ANY QUESTIONS ON OR COMMENTS ON KATIE'S? SLIDES ON ROSS? ALRIGHT, SO WE DID HAVE, UM, I THINK TWO VOTING ITEMS HERE AS WELL.
SO THE ROSS GOALS, CAN WE PUT THAT ON THE COMBO BALLOT? ALRIGHT.
UM, NO G 2 55 IS THERE DISCUSSION HERE? UM, I THINK WE WILL NEED A SEPARATE BALLOT, BUT, SO THERE'S A ROSS RECOMMENDED VERSION AND THEN, UH, LUMINANT 3 22
[03:00:01]
COMMENTS, AND I THINK ERCOT 3 26 COMMENTS.NED, DO YOU WANNA TAKE US THROUGH? SURE.
UH, IF THAT'S THE, THE, THE BEST WAY TO DO IT, THEN WE CAN GO BACK AND FORTH.
UM, SO I PROMISE THIS, THIS WILL HOPEFULLY NOT BE AS, AS IN DEPTH OR, OR AS LONG A DISCUSSION AS WE HAD THIS MORNING.
AND, UM, THANK YOU AGAIN STEVEN, FOR YOUR, UH, YOUR, YOUR FEEDBACK AND INTERACTION ON THIS.
I KNOW YOU'VE BEEN VERY BUSY WORKING WITH THE OTHER ITEM.
UM, YOU KNOW, I THINK GENERAL THEME IS, UH, YOU KNOW, FOR, I KNOW FOR US, FOR A LOT OF FOLKS, 2 45 HAS SUCKED A LOT OF AIR OUTTA THE ROOM.
AND SO, YOU KNOW, AS WE'VE BEEN TRYING TO KEEP UP WITH 2 55 AS WELL, UM, YOU KNOW, WE, WE'VE IDENTIFIED WHAT I THINK IS, UM, AT, AT A HIGH LEVEL IS JUST A CONCERN ABOUT, UH, A CONCERN WITH WHAT WE SEE IS, UH, ADDING REQUIREMENTS THAT ARE BEING CONTEMPLATED FOR IBR IN, UH, NER R'S PRC OH TWO EIGHT, UH, PROPOSED, UH, STANDARD TO, UH, TO NON IBR RESOURCES THAT ARE, UH, CURRENTLY AND WOULD STILL BE SUBJECT TO NER R'S PRCO OH TWO STANDARD.
SO, YOU KNOW, IN, I THINK THERE'S REALLY THREE BIG BUCKETS THAT I CAN, I CAN SUMMARIZE OUR COMMENTS IN.
ONE IS, YOU KNOW, AVOIDING WHAT WE WOULD CONSIDER MAYBE COLLATERAL DAMAGE ALONG THOSE LINES OF, YOU KNOW, APPLYING THOSE MORE STRINGENT STANDARDS TO THE NON IBR, UM, WITHOUT HAVING THE, YOU KNOW, THE BASIS AND NERC STANDARDS.
AND, UH, NUMBER TWO IS AVOIDING WHAT WE THINK MIGHT BE JUST POTENTIAL, UH, TECHNICAL COMPLIANCE TRAPS, UM, THAT YOU CAN BE PRETTY EASILY ADDRESSED BY, UH, PARTICULARLY FOR THE FAULT, UH, THE FAULT RECORDING PROVISIONS BY ALLOWING FOR CONTINUOUS, UH, CONTINUOUS RECORDING WHERE, UM, IT ACTUALLY REDUCES THE RISK THAT YOU MIGHT HAVE LIKE A TRIGGER, A MISHAP.
AND THAT WAY YOU ACTUALLY HAVE THE DATA FOR THE ENTIRE EVENT AND YOU CAN GO BACK AND, AND GET THAT.
SO, UM, WE THINK THAT THAT'S A, A, AN IMPROVEMENT FOLKS WILL MAKE IN FOLKS THAT MAKE INVESTMENTS IN THE CAPABILITY TO, TO MEET THAT, UM, THAT ENHANCED CAPABILITY.
THEY'VE TAKEN ON ADDITIONAL COSTS TO, SORRY, I'M BEING TOLD I'M TOO FAR FROM THE MIC.
UH, SO FOLKS WILL TAKE ON ADDITIONAL COST IN ORDER TO GET THAT CAPABILITY, AND I DON'T THINK WE WANT TO THROW THAT BABY OUT WITH THE BATH WATER IN APPROVING THE, UH, THIS NOER.
AND THEN, UH, NUMBER THREE IS A COMMON THEME THAT WE, WE DID TALK ABOUT IN NOER 2 45.
AND THAT IS, YOU KNOW, AS A MATTER OF PRINCIPLE LUMINANT, AS OPPOSED TO HAVING RETROACTIVE REQUIREMENTS FROM THE DATE THAT THE ACTUAL NOER IS APPROVED, NOTWITHSTANDING THAT THEY'LL ACT, YOU KNOW, THE, THE NOER WOULDN'T BECOME EFFECTIVE UNTIL THE PUC APPROVES IT.
AND FROM THE TIMELINE WE SAW THIS MORNING ON 2 45, I GUESS THAT PROBABLY WOULD MOVE CLOSER INTO MID-JUNE, BUT WE'LL CALL JUNE 1ST, 2024.
GOOD ENOUGH FOR JUST TRYING TO PICK A DATE IN THE STAKEHOLDER PROCESS.
AND SO WE'VE MADE THAT PROPOSED, UH, CHANGE AS WELL.
UM, SO I CAN GO INTO A LITTLE BIT MORE DETAIL, BUT IN THE INTEREST OF TIME, WHY DON'T I JUST PAUSE THERE, STEVEN, I KNOW YOU HAD SOME COMMENTS ON TOP OF OURS, SO LOVE TO HEAR THOSE AND HEAR YOU TALK TO THOSE AND THEN WE CAN DISCUSS.
THIS IS STEVEN SLI WITH ERCOT, I THINK IN GENERAL.
YEAH, I APPRECIATE NED, Y'ALL REACHING OUT TO US AHEAD OF TIME AND YOU KNOW, WE TRIED TO GIVE YOU PRETTY CLEAR WE WOULDN'T HAVE ANY ISSUES WITH CERTAIN LANGUAGE EDITS.
OTHERS WE DID OPPOSE, I THINK WE SPECIFICALLY CALLED OUT, UH, THOSE AREAS WHERE WE DID OPPOSE IN OUR COMMENTS THAT WE SUBMITTED.
AND REALLY, UM, OUR PROPOSAL IS THAT, UH, WE BIFURCATED OUT THE ISSUE, UH, AROUND HAVING TO HAVE A CERTAIN EQUIPMENT ON IBR AND, UH, ON THE LOW VOLTAGE SIDE, AND WE SAID WE'RE GONNA WAIT FOR PRC 28 AND THEN WE'RE GONNA COME BACK IN AND SYNCHRONIZE.
SO I THINK ONCE AGAIN, BECAUSE OF THE LATE HOUR, BECAUSE OF THE NEED TO CONTINUE TO MOVE THIS FORWARD, OUR PROPOSAL IS TO CON TO HAVE AZTEC TO PROGRESS 2 55 WITH ERCOT COMMENTS.
UM, IF THERE ARE SOME MINOR DESKTOP EDITS THAT, YOU KNOW, WE COULD DO ON THE FLY, IT'S NOT THAT WE WOULD OPPOSE THAT, BUT WE THINK A MORE EFFICIENT WAY WOULD BE A, A FOLLOW UP NOER TO THIS TO ADDRESS Y'ALL'S CONCERNS.
IN PRINCIPLE, WE DON'T NECESSARILY HAVE AN ISSUE WITH, UH, SOME OF THE LANGUAGE CHANGES THAT YOU MADE AND SOME UNIQUE CIRCUMSTANCES WHERE PERHAPS YOU CAN'T UPGRADE, YOU CAN'T, YOU KNOW, DO THINGS AND, OR IT'S VERY COSTLY TO DO THAT.
I THINK THAT IT'S REASONABLE TO CONSIDER THAT SOME LOCATIONS MAY BE GOOD ENOUGH, BUT SOME OF YOUR COMMENTS LIKE TO CHANGE THE FAULT RECORDING WINDOW FROM 60 CYCLES TO 30 CYCLES DOESN'T JUST AFFECT GENERATION RESOURCES.
[03:05:01]
IT AFFECTS OTHER MULTIPLE LOCATIONS.AND WHAT WE'RE SEEING ON THE SYSTEM IS THAT NOT ONLY IS IT THE FAULT OCCURRING IN THE FAULT CLEARING, BUT IT'S THE AFTER EFFECTS OF HOW THE SYSTEM IS MOVING AFTER THAT WITH LOAD TRIPPING OFF WITH DER, MAKING ADJUSTMENTS WITH DYNAMIC REACTIVE DEVICES MOVING THAT THE FAULT RECORDING WINDOW NEEDS TO BE LONGER.
AND SO THAT'S WHERE WE ASKED FOR FIVE SECONDS, BUT WE ALREADY SETTLED FOR 60 CYCLES, WHICH IS ONE SECOND.
AND TO GO BACK BELOW THAT, WE CAN'T JUSTIFY THAT WE WOULD GET THE DATA THAT WE NEED TO ANALYZE SYSTEM EVENTS.
UM, ALSO Y'ALL CHOSE TO STRUCK THE LANGUAGE THAT IF WE HAVE LOAD LOCATIONS WHERE DGRS AND DSRS OR OTHER DISTRIBUTION LEVEL EQUIPMENT IS CAUSING LARGE VARIATIONS ON THE ERCOT SYSTEM, 20 MEGAWATTS.
AND, AND ONCE AGAIN, THIS WAS LANGUAGE VETTED.
UM, WE ALREADY TOOK OUT THE LANGUAGE THAT SAID WE WOULD ALWAYS PUT IT IN.
IT'S JUST IF THERE'S AN EVENT, THEN WE WOULD TALK TO THE TSPS.
THE TSPS WOULD WORK WITH ERCOT TO FIND THE LOCATION THAT THEY CAN ACTUALLY PUT IT IN AND TRY TO PUT EQUIPMENT SO THAT WE CAN ANALYZE SYSTEM EVENTS.
UH, WE HAVE LARGE GROWING DISTRIBUTION SET OF RESOURCES, AND WE'RE TRYING TO PUT IN THE LANGUAGE THAT ALLOWS US TO GET THE EVENT ANALYSIS EQUIPMENT THAT WE NEED, AND WE FEEL LIKE WE DID IT AT A REASONABLE LEVEL.
SO, UH, I, I CAN COMMIT TO YOU THAT WE WILL WORK WITH YOU, UM, WITH THE NEW NOER.
I, I UNDERSTAND THAT MAY NOT BE Y'S DESIRE, UM, AND YOU HAVE A LOT OF EDITS THAT I THINK WE WOULD POTENTIALLY CONSIDER, JUST NOT ALL OF THEM AS PROPOSED BY LUMINATE IN YOUR COMMENTS.
ARE WE ON THE QUEUE OR DO YOU NED YEAH, GO AHEAD AND RESPOND AND THEN LET'S GO TO THE QUEUE.
UM, TWO QUICK RESPONSES OR ACTUALLY, UH, THREE QUICK RESPONSES ON THAT.
UM, ONE WAS ON THE, THE CHANGE FROM 60 CYCLES TO 30 CYCLES.
UM, WE SAW THAT IN THE CONTEXT OF THE FAULT RECORDING, UH, CAPABILITIES, AND BASED ON YOUR COMMENTS, WE, WE WERE CONCERNED THAT YOU MIGHT BE LOOKING AT THE FAULT RECORDING CAPABILITIES TO ADDRESS WHAT SOME OF THE DDR UH, CAPABILITIES ARE MEANT TO ADDRESS AS OPPOSED TO FAULT.
SO LIKE, LIKE YOU SAID, THE DYNAMIC RESPONSES.
UM, BUT HAVING THAT LONGER RECORD THEN COMPRESSES THE ABILITY FOR THE DEVICES TO, YOU KNOW, UH, MAINTAIN MEMORY FOR SAY, MULTIPLE EVENTS OR, UM, YOU KNOW, IF IT, IF THE DEVICE HAS THE ABILITY TO RECORD AT A BETTER QUALITY LEVEL THAN WHAT'S IN THE MINIMUM, YOU MAY HAVE TO REDUCE THAT QUALITY TO WHAT THE MINIMUM IS.
AND I, YOU KNOW, I THINK TO OUR CONVERSATION EVEN THIS MORNING, UH, WE DON'T WANT FOLKS TO ONLY DO THE BARE MINIMUM.
IF YOU HAVE A HIGHER CAPABILITY, YOU KNOW, YOU SHOULD USE IT BOTH FOR YOUR OWN BENEFIT AND FOR, FOR ERCOT BENEFIT.
SO THAT'S, THAT'S ONE DISTINCTION THAT, UM, FOR, OR THE RATIONALE, I SHOULD SAY FOR, FOR WHY WE SUGGESTED THAT.
AND CONSISTENCY WITH THE PRC O2 STANDARD, RIGHT? THAT'S THE, THE COMMON THEME THAT WE KEEP COMING BACK TO.
UM, ON THE, ON THE LOAD PIECE.
UM, I DID WANNA CLARIFY, I DON'T THINK WE PROPOSED STRIKING THAT WE DID FLAG IT BECAUSE, UH, I THINK MAYBE IN AN EARLIER DRAFT THAT WE SENT YOU, WE HAD, WE MAY HAVE HAD THAT, BUT WE DIDN'T ULTIMATELY INCLUDE EDITS TO THAT IN, UM, IN WHAT WE SUBMITTED.
AT LEAST THAT WAS NOT OUR INTENTION
UM, BUT THERE WERE SOME, WE HAD SOME CONFUSION ABOUT WHAT, UM, WHAT THE REQUIREMENTS WERE THERE, AND IT SEEMED VERY, UH, VERY SIMILAR TO OTHER LANGUAGE THAT WOULD'VE CREATED REQUIREMENTS FOR GENERATION RESOURCES THAT DIDN'T NECESSARILY HAVE BO UH, BOUNDS ON WHAT WOULD BE REQUIRED.
UM, IN THAT CONTEXT, OUR, OUR PRESUMPTION IS THAT IF A GENERATION RESOURCE HAS COMPLIED WITH THE REQUIREMENTS OF THE OPERATING GUIDES, THAT SHOULD BE SUFFICIENT IN ORDER TO, TO MEET ALL OF THE, UM, YOU KNOW, THE, THE CASES THAT WHERE ERCOT WOULD BE LOOKING FOR, UH, FOR THAT DATA.
UM, SO WITHOUT HAVING ANY BOUND ON IT, IT, IT JUST SEEMED LIKE KIND OF AN OPEN, AN OPEN BOX.
UM, THERE WAS SIMILAR LANGUAGE FOR LOADS.
WE FLAGGED THAT, UM, I THINK IN PART BECAUSE THE TERM FACILITY WAS A LITTLE UNCLEAR WHETHER THAT WAS REFERRING TO THE, THE TRANSMISSION SERVICE PROVIDER'S FACILITY OR, UM, THE, THE LOAD FACILITY.
UM, BUT WE DIDN'T PROPOSE EDITS THERE.
UM, AND THEN, YOU KNOW, AS FAR AS, UM, UH, I SHOULD HAVE WRITTEN THIS DOWN, UM, YOU KNOW, AS FAR AS PATH TO MOVE FORWARD, UM, I REALLY APPRECIATE THAT, THAT THERE ARE SOME THINGS THAT, UH, THAT Y'ALL SEE IN THERE THAT, UH, YOU THINK YOU COULD LIVE WITH.
UM, IF THAT IS THE CASE, YOU KNOW, WE WOULD LOVE TO
[03:10:01]
MOVE FORWARD WITH MAYBE WITH THE LUMINANT COMMENTS TODAY, AND THEN WE CAN WORK TO MAKE ADJUSTMENTS AND HOPEFULLY FIND, UH, FIND SOME CONSENSUS THAT WE MIGHT BE ABLE TO PUT OUT, UM, YOU KNOW, HEAD OF BOARD CONSIDERATION OR, UM, YOU KNOW, FRANKLY, I'M ALSO OPEN TO TABLING.I KNOW YOU'VE GOT, THERE'S A TIMELINE THAT YOU'D LIKE FOR US TO HIT, AND SO THAT'S WHY WE, UM, YOU KNOW, WHY WE TRY TO GET THOSE COMMENTS IN, BUT AHEAD OF TIME, UH, FOR CONSIDERATION HERE TODAY.
UM, SO LET'S GO TO THE Q UH, JOHN RU HUBBARD.
UH, HI, JOHN RUS HUBBARD ON BEHALF OF TIEC.
UM, I, THIS IS, YOU KNOW, WE RECENTLY STARTED LOOKING AT THE LANGUAGE, UH, AND SO WE WOULD ALSO BE SUPPORTIVE OF TABLING IT.
UM, BUT I WAS HOPING TO, TO GET SOME CLARIFICATION FROM ERCOT ABOUT, UH, SOME OF THE SUBSECTIONS.
UM, SO SPECIFICALLY 6.1 0.2 0.2, PARAGRAPH ONE J UM, SAYS, AND THIS APPEARS ELSEWHERE, IT SAYS THAT ANY LOAD CONSISTING OF ONE OR MORE FACILITIES AT A SINGLE SITE, AND THEN UNDER THAT SUBPARAGRAPH IT DESCRIBES THE T DSPS OR DSPS INSTALLING EQUIPMENT.
BUT THEN LATER IT ALSO SAYS THAT THE TRA THAT THE FACILITY OWNER SHALL INSTALL THE EQUIPMENT.
SO I'M JUST, I'M UNCLEAR OF WHETHER ERCOT IS TRYING TO PUT AN OBLIGATION ON THE LOAD OR PUT AN OBLIGATION ON THE TDSP.
YEAH, THIS IS STEVEN SLI WITH
I, I THINK THAT, UH, IT, WE DIDN'T NECESSARILY SUGGEST THIS LANGUAGE, BUT MY, UH, UNDERSTANDING AND I CONFIRMED, YOU KNOW, DURING THE BREAK IS THAT THIS WAS FOR THE TSP AND DSP TO INSTALL THAT EQUIPMENT, AND THEY PROPOSED THIS COORDINATION.
IF YOU LOOK AT THE SET OF COMMENTS PRIOR TO THIS THAT ERCOT TELLS 'EM THERE'S A NEED AND THEN THEY LOOK AT THE FACILITIES THEY OWN AND THEY FIND THE BEST LOCATION TO PUT IT THERE IF IT CAN EVEN WORK BECAUSE THEY HAD CONCERNS WITH BEING REQUIRED TO PUT THAT EQUIPMENT AT A LOCATION THAT THEY DON'T OWN.
AND SO THE CONSTRUCT HERE THAT WAS INTRODUCED BY THE TSPS WAS FOR THEM TO HAVE THE OBLIGATION TO INSTALL IT AT A LOCATION, UH, THAT WORKS BEST FOR THE PARTICULAR AREA OF NEED.
THA THANK YOU FOR THAT CLARIFICATION.
I GUESS THE LANGUAGE DOESN'T CLEARLY REFLECT THAT BECAUSE IT SAYS THAT THE, IT SAYS BEHIND THE SERVICE DELIVERY POINT, SO PRESUMABLY THAT WOULD BE ON THE LOAD SIDE OF THE FACILITIES, AND THEN IT SAYS THAT THE FACILITY OWNER SHALL INSTALL, WHICH WOULD BE IN THAT SITUATION, THE LOAD.
SO I THINK THIS LANGUAGE NEEDS TO BE IRONED OUT.
SO IF I COULD JUST POINT OUT IN J UH, I, I GUESS THE, THE, THE LANGUAGE THAT'S THERE THAT SAYS THE INTERCONNECTING TSP OR DSP SHALL ENSURE THE RECORDING EQUIPMENT IS INSTALLED, I THINK WAS THE LANGUAGE THAT THEY PROPOSE WOULD REQUIRE THEM IN CLEAR TERMS. IS THERE AN ADJUSTMENT TO THAT THAT NEEDS TO, THAT YOU WOULD SUGGEST AS A FRIENDLY AMENDMENT? YEAH, AS, AS A FRIENDLY AMENDMENT, I'D SUGGEST THAT TOO.
NOT LITTLE I TOO, BUT THE TWO BELOW THAT SAYS, SHOULD SAY THE, UH, TRANSMISSION FACILITY OWNER.
AND THERE'S A COUPLE OTHER SITUATIONS WHERE THAT APPEARS, WELL, I GUESS COULD IT BE A DISTRIBUTION FACILITY AS WELL? SURE.
TRANSMISSION OR DISTRIBUTION FACILITY OWNERS.
I DON'T THINK OUR CUT WOULD BE OPPOSED TO THAT.
CLARIFICATION ON LOOKING OVER AT ENCORE, UM, WOULD Y'ALL HAVE ANY ISSUES? OKAY.
THAT SAME CHANGE WOULD BE NEED TO BE MADE ON 6.22 SUB TWO? YEAH, THE, THE ONLY THING I WOULD PROPOSE IS THAT THOSE EDITS WOULD BE MADE ON
SO WE'RE PROPOSING DESKTOP EDITS HERE.
BILL, DO YOU WANNA MAKE YOUR COMMENT WHILE WE'RE YEAH, MINE'S BRIEF.
I, JOHN RUSS HUBER, DID YOU ANTICIPATE YOUR COMMENTS ON LUMINANCE VERSION OR ON ERCOT, OR DID, DID YOU NOT HAVE A PREFERENCE? I'M FINE WITH
[03:15:01]
EITHER ONE.WE, UM, WE WERE PRETTY SYMPATHETIC TO LUMINANT'S COMMENTS.
WE FOLLOWED THIS THROUGHOUT THIS PROCESS AT, AT ROSS, UM, AND HAVE CONSIDERED SIMILAR REVISIONS.
AND SO I, I STEVEN, I'M, I'M JUST, I'M WONDERING, UM, THE, THE LUMINANT VERSION SEEMS TO STILL MEET YOUR NEEDS AND GET YOU THE INFORMATION THAT YOU REQUIRE IN COMPLIANT WITH THE NERC STANDARD.
UM, JUST KIND OF GETTING A SENSE FROM YOU AND I APPRECIATE THE OFFER ON MAKING SOME OF THE ADDITIONAL EDITS IN THE FUTURE NO.
OR TWO AND MAY TAKE YOU UP ON THAT.
JUST YOU'RE WANTING TO KIND OF SEE YOUR THOUGHTS ON POTENTIALLY MOVING THE LUMINATE LANGUAGE FORWARD.
UM, AND IF, IF THAT WAS GAVE YOU TOO MUCH HEARTBURN, I'M KIND OF CURIOUS.
SO I GUESS WE WOULD NEED TO KNOW WHAT VERSION HAVE A MOTION FOR A VERSION TO MAKE THE DESKTOP EDITS ON THOSE.
UM, NED, GO AHEAD AND I'M HAPPY TO MAKE A MOTION TO APPROVE THE LUMINANT COMMENTS WITH THE DESKTOP EDITS THAT, UH, TIEC HAS RECOMMENDED.
I WAS TRYING TO WEIGH WHETHER, I'LL SECOND, BUT, UM, SINCE THE MOTION'S ON THE TABLE, I'LL SECOND THAT.
WELL, AND THEN I'LL, I'LL NEED Y'ALL TO WALK ME THROUGH.
THERE'S FAC THE PHRASE FACILITY OWNER POPS UP DOZENS OF TIMES.
AND SO TO THE EXTENT THAT FACILITY OWNER ISN'T DESCRIPTIVE ENOUGH AND WE NOW NEED TO DROP IN DISTRIBUTION OR TRANSMISSION FACILITY OWNER, WE, WE KIND OF NEED TO STEP THROUGH ALL OF 'EM AND MAKE SURE THAT WE'RE OKAY.
SO FIRST ONE'S IN 6, 1, 2 2, OKAY.
AND IT HAS THESE, THIS SIMILAR STRUCTURE OF, I MEANT BEFORE WE DO ALL THIS FACILITY OWNER SHALL INSTALL.
IS, DOES THAT NEED CLARIFICATION OR IS THAT SELF EVIDENT? I THINK BECAUSE TWO DESCRIBE IT BA IS BASED OFF THE DESCRIPTION.
ONE, IF YOU CHANGE TWO, IT SHOULD BE FINE NOT HAVING TO CHANGE.
WE DO HAVE A COMMENT FROM ENCORE BEFORE WE, WE GO THROUGH ALL OF THAT.
SO LET'S TAKE, UH, COLIN'S COMMENT AND THEN GO BACK THROUGH.
THAT'S COLIN MARTIN WITH ENCORE.
SO STEVEN, YOU, YOU HAD SUGGESTED TRANSMISSION OR DISTRIBUTION FACILITY OWNER.
I MEAN, I, I DON'T HAVE THIS UP AND I HAVEN'T LOOKED THROUGH THE ENTIRE THING HERE JUST IN THIS SECOND, BUT AS COREY WAS SCROLLING THROUGH THERE, I THINK IT'S PRETTY CONSISTENTLY SPOKEN TO AS TRANSMISSION FACILITY OWNER.
IS THERE A REASON THAT DISTRIBUTION WOULD BE APPROPRIATE TO INCLUDE, INCLUDE IN THERE? I, I, I THOUGHT THE LANGUAGE WAS FINE AS IS.
I'M JUST TRYING TO OFFER WHATEVER CLARIFYING EDITS MAY CLARIFY.
I MEAN, IN SOME INSTANCES WHERE IT REFERS TO GENERATION, IT NEEDS TO THEN SAY GENERATION, UM, BUT FACILITY OWNERS, WHEN IT'S THERE, IT'S MORE UNIVERSAL TO CAPTURE WHETHER IT'S TRANSMISSION, DISTRIBUTION OR GENERATION BASED ON THE SUBPARTS ABOVE.
I MEAN, IT, IT, SO IT JUST FEELS LIKE TO ME THAT IT'S RELATIVELY CLEAR AS IS IF WE'RE GONNA TAKE THIS BACK AND, AND EXPAND KIND OF WHAT FACILITY OWNERS IS I'D, I'D KIND OF LEAN TOWARDS TAKING THIS BACK AS A TABLE TO ASSESS FURTHER.
THANKS, NED, DID WE GET TO YOU IN THE QUEUE THE LAST TIME YOU WERE IN IT? YOU DID, PLEASE.
I'D JUST LIKE TO PIGGYBACK OFF OF COLLIN'S COMMENT, UM, THAT IF WE ARE GONNA ADD MORE REVISIONS, I WOULD LIKE TO TABLE AS WELL FOR FURTHER REVIEW.
I THINK WE WOULD NEED A MOTION TO TABLE THIS, RIGHT? BECAUSE THIS IS THE FIRST TIME ATTACK.
IS THAT A MOTION? IS THAT A MOTION? WELL, ARE WE MAKING THESE CHANGES? I, I WA I DON'T KNOW IF WE'VE, I DON'T THINK WE'VE HEARD A MOTION ON ANYTHING.
SO YEAH, I'VE MADE A MOTION BILL MADE A MOTION.
WE DID HAVE A MOTION TO, TO APPROVE THAT IS TO BILL, BUT A MOTION TO TABLE WOULD BLOCK THAT.
A MOTION IF MOTION TABLE DOES TRUMP MOTION AND SECONDER ARE WILLING TO REMOVE THE MOTION, WE CAN THROW ON THE COMBO BALLOT A MOTION TO TABLE NOER 2 55 IF THEY AGREE THAT A LITTLE MORE BAKING WOULD BE WARRANTED.
YEAH, I AM, LIKE I SAID, I'M NOT OPPOSED TO TABLING TO, TO IRON OUT, YOU KNOW, THIS IS OKAY.
SO IT WOULD BE A FRIENDLY MOTION TO TABLE.
YEAH, BUT THE MOTION HAS NOT BEEN MADE.
THEY WOULD IT IF THEY, IF THEY'RE WILLING TO REMOVE, IF THEY'RE WILLING TO WITHDRAW THEIR MOTION TO RECOMMEND APPROVAL.
AND THEN THERE'S NO OBJECTION TO US PUTTING A MOTION TO TABLE ON THE COMBO BALLOT.
WE DON'T HAVE TO TAKE A VOTE SEPARATELY AT ALL.
WOULD YOU, SO WHAT WE'RE DISCUSSING IS WITHDRAWING THE MOTION TO APPROVE TABLING IT, AND THEN WE CAN MAKE THESE EDITS BETWEEN NOW AND APRIL THAT THAT IS ACCEPTABLE TO US.
SO IF UNLESS THERE'S CONCERNS WITH THE COMBO BALLOT,
[03:20:01]
WE, WE WOULD, UH, WITHDRAW A MOTION.OKAY, SO WE WOULD PUT TABLE NO G 2 55 ON THE COMBO BALLOT.
I WAS JUST GONNA ADD THAT THAT'LL ALSO ENSURE IT STILL GETS TO THE SAME BOARD MEETING.
SO YOU'RE NOT CHANGING THE TIMELINE FROM THAT, THAT PERSPECTIVE.
I JUST WANTED, SO WE, AS IS, IT'S, IT'S A TIGHT TIMELINE.
I DON'T THINK ERCOT IS PLANNING ON BRINGING EVERYTHING FROM APRIL TECH TO APRIL BOARD.
I I MENTIONED THAT WE COULD FOR NO 2 45 'CAUSE I, I THINK WE COULD DO IT, BUT THE MATERIALS ON THINGS OUT OF APRIL TACK WOULD GET TO THE BOARD A LITTLE BIT LATER THAN NORMAL MATERIALS.
YEAH, I WAS JUST TRYING TO MAKE SURE THAT IF ERCOT WANTED THAT TO GO THROUGH QUICKLY RATHER THAN THAT, THAT OPPORTUNITY WAS THERE.
DO ERCOT, DO YOU NEED THIS TO IT TO A PARTICULAR BOARD MEETING? ARE ARE WE ALL OKAY WITH, UH, MOTION TO TABLE THIS UNTIL APRIL TACK? GO AHEAD STEVEN.
YEAH, I THINK ER HU'S JUST GONNA BE ON THE RECORD TO CONTINUE TO TRY TO PROGRESS THIS AS QUICKLY AS POSSIBLE.
THIS IS NOT THE SAME, UM, RISK LEVEL, I WOULD SAY THAT NOGA 2 45 IS WHERE WE'RE ADAMANT TO THAT SAME DEGREE.
WE DON'T WANT TO CAUSE PROBLEMS HERE IN TRYING TO DO THE RIGHT THING.
SO IF, IF TABLING IF THERE IS PERCEIVED VALUE IN TABLING, UH, THAT WE'RE ACTUALLY GONNA GET A BETTER PRODUCT HERE, UH, AT THE NEXT TACK, THEN I'M OPEN TO THAT.
BUT I GUESS I WOULD LIKE TO HEAR WHAT'S GONNA HAPPEN BETWEEN NOW AND WHAT, WHAT IS PERCEIVED TO HAPPEN BETWEEN NOW AND NEXT T THAT WOULD BE DIFFERENT THAN THE LUMINANT VERSION THAT'S BEFORE US TODAY.
I, I MIGHT BE ABLE TO HELP WITH THAT JUST FOLLOWING THE DISCUSSION.
I THINK THEY'RE, THEY WANT TO INCORPORATE, UH, TIA'S COMMENTS BUT NOT DO IT ON THE FLY REALLY IS WHAT IT'S COMING DOWN TO BASED ON WHAT I HEARD AND THE FEEDBACK I GOT FROM ENCORE AS THE EDITS STARTED GETTING A LITTLE BIT MORE COMPLEX.
SO IS LUMINANT GOING TO SUBMIT THOSE COMMENTS OR WHO'S GOING TO BE SUBMITTING THEM? THAT'S A, THAT'S A GOOD QUESTION.
WE'RE HAPPY TO, TO WORK WITH THE, WITH TIEC AND ENCORE TO, TO SUBMIT THOSE.
WE'RE HAPPY TO WORK WITH YOU IN MAKING REVISIONS, YOU KNOW, AND THIS WAS IN UNDER THE, UNDER THE GUN WITH 2 45 AS WELL.
SO HAPPY TO HAVE A MULTILATERAL DISCUSSION TO, FOR THE, THE NEXT ROUND.
YEAH, I THINK FOR THIS PARTICULAR ISSUE THAT WAS RAISED BY TEIC, UH, ERCOT JUST REALLY WANTS IT TO WORK.
AND SO WE'RE GLAD TO PARTICIPATE, BUT I FEEL AWKWARD IN LEADING ANY DISCUSSIONS TO WHERE WE REALLY DIDN'T HAVE ISSUES WITH THE LANGUAGE IN THE FIRST PLACE.
SO WE, I'D LIKE TO SEE THAT IF SOMEONE COULD TAKE THE LEAD AND, AND INITIALIZING THOSE AND THEN WE'RE MORE THAN WELCOME TO PARTICIPATE.
STEVEN, WHAT I'M HEARING IS THAT REALLY THEY JUST DON'T WANNA DO ANY HARM TO SOMETHING ELSE THAT IS IMPORTANT TO US.
SO THEY NEED YOUR REVIEW AND, AND I, I GUESS, UH, KIND OF ACCEPTANCE OF, OF WHATEVER IT IS THEY WORK OUT.
SO MY ASSUMPTION IS THERE WILL BE ANOTHER SET OF COMMENTS THAT WILL COME BEFORE TAC THAT WILL MODIFY AND ADDRESS THE CONCERNS THAT WERE RAISED.
SO WE ARE GOING TO TABLE THIS, PUT THAT ON THE COMBO BALLOT AND LUMINATE WILL SPEARHEAD COMMENTS, GET HER COTS TAKE ON IT, AND WE'LL HAVE THAT HERE FOR APRIL TECH AND NOT, WHICH IS NOT GOING TO APRIL BOARD.
[9. WMS Report (Vote)]
TO WMS. IS THAT CORRECT, ERIC? THANK YOU.ERIC BLAKEY, CHAIR OF WMSI HOPE TO BE BRIEF.
THE, UH, HIGHLIGHTS WE HAD OUR WMS GOALS APPROVED OR, UH, FOR TAC CONSIDERATION, UH, MOST OF THE CHANGES I WOULD SAY WERE TO COMPLY WITH, UH, AND BE CONSISTENT WITH THE, THE, UH, APPROVED TAC GOALS.
UM, BUT THOSE ARE BEFORE YOU TODAY.
IF YOU HAVE ANY QUESTIONS, I'LL BE HAPPY TO ANSWER 'EM.
WE HAD A PRESENTATION ON THE ECLIPSE,
[03:25:01]
AS WE ALL KNOW, THAT'S COMING UP ON APRIL THE EIGHTH.WE HAD, UH, A LOT OF DISCUSSION ON, UH, NPR 1190, UH, AND, UM, THIS'LL ADD A PROVISION FOR RECOVERY OF A DEMONSTRABLE FINANCIAL LOSS ARISING FROM A MANUAL HDL OVERRIDE.
ALTERNATIVE PROPOSALS HAVE BEEN FILED AND, UH, FURTHER DISCUSSION WILL CONTINUE.
UH, AND THEN WE HAD, UH, THE EMERGENCY PRICING PROGRAM.
WE HAD A LOT OF DISCUSSION ON THAT.
UH, AND THOSE DISCUSSIONS WILL CONTINUE NEXT WEEK AT WMWG, UH, PREVIOUSLY TABLED ITEMS, THIS IS OUR LIST.
THE ONE ITEM THAT WE TALKED ABOUT WAS, UH, NBR 1202.
UH, WE HAD, UH, ASKED WNWG TO LOOK INTO THIS AND THEY DISCUSSED, THEY FOUND NO ISSUES, BUT WE'RE NOT TAKING ANY ACTION BECAUSE WE ARE LOOKING TOWARDS, UH, L-F-L-T-F, THE LARGE FLEXIBLE LOAD TASK FORCE, UH, ADDRESSING THOSE ISSUES BEFORE WE MOVE FORWARD.
SO, UM, ONE THING I WILL MENTION THAT, THAT CAME AFTER, UH, DEADLINE.
WE, WE'VE HAD SOME CHANGES IN OUR WORKING GROUP, UH, WMWG.
WE'RE GONNA HAVE, UH, NEW LEADERSHIP.
WE HAD, UH, BOTH OUR CHAIR AND VICE CHAIR HAVE TO STEP AWAY.
AND SO KEVIN HANSON HAS AGREED TO STEP IN AS CHAIR AND, UH, BLAKE HOLT HAS AGREED TO SERVE AS VICE-CHAIR, SO WE'RE VERY HAPPY TO HAVE THAT.
UM, THEY'LL MEET ON TUESDAY, I GUESS, AND CONFIRM THOSE, UH, DECISIONS, BUT, UH, REALLY APPRECIATE THEM STEPPING UP IN ALL OF OUR WORKING GROUP LEADERSHIP.
SO, ANY QUESTIONS? HOW MANY WORKING GROUPS IS KEVIN HANSEN CHAIRING? JUST OUTTA CURIOSITY, YOU KNOW, WE NEED A TASK FORCE TO COVER THE TASK FORCES THAT KEVIN HANSEN IS CHAIRING NOW THAT, THANK YOU FOR THE QUESTION.
WE DO, WE DO HAVE A CHALLENGE IN WMS OF KEEPING OUR, OUR WORKING GROUPS FILLED, AND IT'S AN EXCELLENT OPPORTUNITY TO, TO LEARN ABOUT AND BECOME MORE INVOLVED AND ENGAGED.
AND SO I, I ALWAYS ENCOURAGE FOLKS TO LET ME KNOW IF YOU'RE INTERESTED, UH, BECAUSE WE DO HAVE JOB CHANGES QUITE OFTEN.
UH, SO WE'D LOVE TO, TO GET SOME, SOME NEW FOLKS INVOLVED IF, IF YOU'RE INTERESTED, THAT WAS NOT AT ALL A CRITICISM OF KEVIN.
I JUST, YOU KNOW, THREE, I THINK HE CHAIRS THREE WORKING GROUPS, SO I'M SURE HE WOULD WELCOME, UM, SOME OTHER VOLUNTEERS AND IF WE COULD DIVERSIFY THAT LEADERSHIP IF THERE'S ANYBODY WHO WANTS TO, TO GET SOME GOOD LEADERSHIP TRAINING.
ALRIGHT, SO WE DO OUTTA WMS, I BELIEVE WE ARE VOTING ON THE WMS GOALS, AND I THINK WE CAN PUT THOSE ON THE COMBO BALLOT.
JUST A REAL QUICK QUESTION TO STAY OUT OF ROBERT'S RULES JAIL.
CAN YOU GO TO THE AGENDA? YES.
IT DOESN'T, WELL, IT DOES HAVE A VOTE, BUT IT DIDN'T SAY WHAT IT WAS.
SO I'M, I'M JUST MAKING SURE THAT WE'RE OKAY.
MISREAD AND LIST THE VOTING ITEMS. YES, I MISREAD, I MISREAD, NEVERMIND.
YEAH, I THINK, I THINK WE'RE ALL IN ROBERTS RULES JAIL RIGHT NOW.
SO LET'S, CAN WE PUT THAT ON THE, UH, COMBO BALLOT? ALL RIGHT, THANKS.
COREY IS CONFIRMS THAT WE ARE IN ALL IN ROBERTS RULES JAIL.
SO, SO NOW WE ARE TO THE CREDIT FINANCE SUBGROUP.
AND THAT WAS A GOOD NOTE, A TIME CHECK NOTE ALSO, UM, THE DRS WORKSHOP IS SCHEDULED TO HAPPEN AFTER THIS MEETING.
THEY WOULD LIKE TO START, UM, THREE AT THE LATEST, HOPEFULLY BEFORE THREE.
I AM OPTIMISTIC THAT WE CAN WRAP THIS UP BY TWO 30 OR, OR TWO 50.
[10. Credit Finance Sub Group (CFSG) Report]
GO AHEAD.[03:40:50]
I[03:40:50]
DON'T[03:40:50]
SEE ANY QUESTIONS, SO WE'LL MOVE ON TO THE RTC[11. RTC+B Task Force Report]
PLUS B TASK FORCE REPORT.I'LL START QUICKLY AND THEN SLOW DOWN ON THE LAST TWO SLIDES.
THERE'S EIGHT, SO HANG WITH ME.
SO MATT MARINA ERCOT, UH, CHAIR OF R-T-C-B-T-F.
UH, JUST THE TERMS OF THE PROGRAM UPDATE.
THIS IS FROM A SLIDE THAT'S SHARED TO THE BOARD BY OUR CIO, UH, WITHIN THAT IT, UH, GROUP.
AND SO THE DATES I ALWAYS WANNA HIGHLIGHT WITH THIS GROUP IS THE IDEA OF IN SEPTEMBER OF 2024, THE RED LINE IN THE MIDDLE IS WHEN WE PLAN TO HAVE OUR FINAL PLAN FOR WHAT DOES THE GO LIVE SEQUENCE LOOK LIKE IN TERMS OF THE TIMING.
SO THAT'S WHERE WE'RE WORKING TOWARDS THE MARKET TRIALS, THE SEQUENCES, AND THEN ULTIMATELY A GO LIVE DATE.
SO THE REQUIREMENTS ON THE LEFT ARE WRAPPING UP, GETTING INTO THE FINAL PLANNING.
AND THEN, YOU KNOW, THE IDEA, WE HAVE A PLACEHOLDER OUT HERE.
EVERYTHING TO THE RIGHT IS INDICATIVE DATES, BUT WE DO HAVE THE IDEA OF WHETHER OR NOT MARKET TRIAL CONNECTIVITY STARTS AS SOON AS MAY OF 2025.
SO IT'S COMING, UH, THIS IS SAME OLD STUFF.
IT'S THE SCOPE AND WHAT WE'RE DOING AT THE TASK FORCE.
SO THE ISSUES LIST, THIS IS OUR, UH, ROLODEX FOR WHAT WE WANT TO MARCH THROUGH AND WHAT'S THE TIMING OF IT, WHICH ONES DO WE WANT TO HIT FIRST? UM, ONE OF THE THINGS THAT WAS ASKED TO CUT IN LINE WAS THE AS DEMAND CURVES, WHICH I'LL TALK ABOUT IN A MINUTE.
AND SO THAT'S WHERE YOU SEE SOME RED HERE IS THE IDEA OF IN MARCH AND APRIL WE'RE HAVING SOME UNPLANNED AS DEMAND CURVE TYPE, UH, CONVERSATIONS, WHICH IS FINE.
AND THEN WE ALSO ARE MOVING SOME OF THE MARKET TRIALS.
OUR REQUIREMENTS ARE DONE ON THE MMS SIDE.
AND SO WE'LL START BRINGING TO, UH, TO THE FOREFRONT THE TELEMETRY REQUIREMENTS AND THE MARKET SUBMISSION REQUIREMENTS.
WE'RE REALLY KEEN ON GETTING YOUR VENDORS UP AND RUNNING SO THAT THERE'S, AS THINGS KEEP MOVING ALONG, THAT THERE'S, UH, MORE THAN ENOUGH RUNWAY TO GET THROUGH IT.
SO THE TWO PLANNED ACTIVITIES THAT WE HAD WAS REALLY THE R CAPACITY SHORT.
THAT WAS THE IDEA OF HOW TO ACCOMMODATE THE, UH, STATE OF CHARGE, UH, YOU KNOW, THE, UM, IN ACCOMMODATE IF WE'RE RUNNING A R STUDY, HOW DO YOU LOOK AT THE STATE OF CHARGE ON BATTERIES TO ESTIMATE WHERE THEY'RE GONNA BE AT? SO THIS IS THE IDEA OF HOW TO LOOK AT THAT AND WHAT THE CAPACITY SHORT LOGIC IS.
THERE WAS A RELIEF VALVE OFFERED BY SOMEONE THAT SAID, HEY, MAYBE WE DON'T HAVE TO WORRY ABOUT THE DIRECT ASSIGNMENT OF RUCK CAPACITY SHORT, BUT THAT KIND OF TAKE US OUTTA BOUNDS OF WHAT'S WITHIN THE TASK FORCE IS TO STAY WITHIN, UM, ON TARGET FOR THE SAME TYPE OF R CAPACITY SHORT CALCULATIONS.
UH, ALSO THERE'S A CHANGE FOR ONLINE HYDRO RESOURCES AND HOW TO MITIGATE AROUND THAT.
UH, SO THESE TWO ISSUES ARE ON TRACK FOR CONCLUSION IN THE NEXT COUPLE MONTHS, BUT THIS IS THE ONE I WANTED TO PAUSE AND TALK ABOUT.
SO THE AS DEMAND CURVES, WE WERE ASKED TO REVIEW THE AS DEMAND CURVES IN THE CONTEXT OF CURRENT POLICY.
SO WHAT THAT SAYS IS, FROM AN IMPLEMENTATION PERSPECTIVE, WE HAVE THE PROTOCOLS, THE PUC DIRECTION AND WHAT'S NEEDS TO BE BUILT.
AND SO THAT MIDDLE SET OF GRAPHICS IS WHAT WE'RE BUILDING TO, WHICH IS AN ORDC CURVE, WHICH IS ON THE LEFT SIDE, AND THEN HOW WE DISTRIBUTE THE AS DEMAND CURVES WITHIN THE CONTEXT UNDER THAT.
AND SO THE IDEA IS REG UP IS THE FIRST PRODUCT AT 5,000, THE R-R-S-E-C-R-S AND NONS SPEND.
AND SO THAT IS, UM, SOMETHING THAT'S BEEN ESTABLISHED AND AS WE SHARED THAT THERE'S BEEN EXTENSIVE DISCUSSION ON WHETHER OR NOT THIS IS THE BEST, UH, METHOD OF PRICE FORMATION FOR RTC.
AND SO I HAVE THESE TWO BULLETS.
SO THE MARK PARTICIPANTS RAISED QUESTIONS AS TO WHETHER THE CURRENTLY DEFINED ORDC IS ALIGNED WITH OPERATIONS, YOU KNOW, THE SHAPE OF THE RRDC AND THEN WHETHER OR NOT, UH, THERE'S A NEED TO REVISIT THE TAC DECISION TO REDISTRIBUTE THE AS DEMAND CURVES UNDERNEATH TO KIND OF COMMINGLE OR SLICE AND DICE THE CURVES TO WHERE MAYBE SOME ECRS POPS INTO THAT, UM, STACK.
SO IT'S A RE-SEQUENCING OF THE STACK AND THERE'S A TABLE PROVIDED THERE OF SOME THOUGHTS, BUT LEMME KINDA LAND THE PLANE AND OPEN IT UP FOR QUESTIONS.
SO ON THE RUG CAPACITY, SHORT, UH, THE HYDRO MITIGATION WE'RE AT A GOOD PLACE.
ONE THING THAT WE WILL START TO BRING UP IS, UM, AT THE NEXT MEETING IS THE IDEA OF OUR TOOLS AND FRAMEWORK FOR STUDYING MARKET SOLUTIONS.
WE'RE DEVELOPING OUR OWN KIND OF IN-HOUSE RTC WHAT IFS SCENARIO, AND THAT'S A DEVELOPMENT TOOL THAT WE WANNA PUT IN FRONT OF THE MARKET PARTICIPANTS AND SAY, HERE'S
[03:45:01]
THE FUNCTIONAL TESTING WE WANT TO BE ABLE TO DO AND WHETHER OR NOT IT'S TO GO RUN A SEPTEMBER DAY FROM 2023.SO WE'LL START TALKING ABOUT THAT AT NEXT MONTH'S MEETING, BUT ON ISSUE ON THIS AS DEMAND CURVE.
SO I AGREE TO KEEP THE LIGHTS ON IN THE MEETING, BUT THIS WILL BE SOMETHING THAT'S DISCUSSED AT THE END BECAUSE IT'S ON THAT FRAY OF NOT BEING A TASK FORCE ISSUE.
THE TASK FORCE IS NOT GONNA COME FORWARD AND PROPOSE ATTACK, LET'S CHANGE THE DESIGN THAT THAT'S NOT IN OUR WHEELHOUSE.
AND SO WE'LL FACILITATE THOSE DISCUSSIONS.
BUT FOR CHANGING THE SHAPE OF THE RDC CURVE, THE QUESTION IS HOW IS THAT DONE? UH, WE WOULD OFFER THAT THAT IS THE DEMAND CURVES ARE BASED ON THE CURRENT GUIDANCE FROM THE PUC MEMO BACK IN 2019, UH, TO RESHAPE OR DECOUPLE THE DEMAND CURVES FROM THE ORDC WOULD BE A PUC POLICY CHANGE.
AND JUST ACKNOWLEDGING THIS IS NOT A MAGIC NUMBER, BUT WOULD TAKE AT LEAST NINE MONTHS TO GET THINGS UP AND RUNNING OVER THERE ON CONSIDERING THAT.
AND THEN OF COURSE, WE'LL NEED AN NPR WITH THAT.
AND THE GOOD NEWS IS SYSTEM CHANGES ARE NOT REQUIRED.
SO THAT COULD COME DOWN TO A MONTH BEFORE GO LIVE, AND WE COULD STILL GET THOSE PARAMETERS.
AND THAT ORDT CURVE IS A HUNDRED PIECE POINTS THAT WE CAN JUST DIAL IN THOSE NUMBERS.
UNFORTUNATELY, ON THE OTHER ONE, IT'S DIFFERENT, UH, COMPLEX IN A DIFFERENT WAY FOR CHANGING THE DISTRIBUTION OF HOW AS IS UNDER THE CURVE, UH, THAT REQUIRES A PROTOCOL CHANGE.
UH, IT ALSO REQUIRES SYSTEM CHANGES.
WE DID IT, YOU KNOW, PER PROTOCOLS BLOCK ONE, BLOCK TWO, BLOCK THREE, BLOCK FOUR.
THE IDEA OF PUTTING IT INTO A PARAMETERIZED TABLE THAT STARTS TO REDISTRIBUTE IT, UH, AROUND WOULD BE A SYSTEM CHANGE.
SO THAT'S ONE THAT WE WOULD OFFER AS MORE OF A BASELINE TO TYPE CHANGE FOR RTC.
AND THEN I WANTED TO ANNOUNCE THIS.
THIS WAS, THIS IS EVEN CATCHING OUR TASK FORCE.
UM, AS NEW NEWS IS WE ARE LOOKING TO SET UP SOME DEEP DIVES AS WE GET THESE, UH, INTERFACES OUT AND RUNNING AND THE IDEA OF TELEMETRY CHANGES, WE WILL WANT TO ENGAGE KIND OF A MIX OF THE RTC TASK FORCE AND THE TWG TASK FORCE TO TALK ABOUT THOSE SPECS TO HELP TO IRON OUT ANY KINKS BEFORE WE GET TO A FINALIZED SET.
SO THERE'S SOME PRE-WORK AND SOME WORKSHOPS THAT EVERYONE'S INVITED TO, BUT IT'LL BE A DEEP DIVE WITH VENDORS.
IT DEVELOPMENT SHOPS A DIFFERENT CAST.
IT'S NOT Y'ALL, IT'S A DIFFERENT CAST OF PEOPLE THAT WOULD BE INVOLVED IN THOSE.
SO WE'D LIKE TO HAVE TWO OR THREE OF THOSE SHOPS, UH, BETWEEN APRIL AND JUNE.
SO WITH THAT, I'LL OPEN UP FOR ANY QUESTIONS.
UH, FIRST, BILL BARNES, MATT, APPRECIATE THE CONTINUED DISCUSSION OF THE SHAPE OF THE RDC, WHICH IS, UH, YOU KNOW, A PRETTY MAJOR POLICY DECISION NOT ONLY FOR RTC, BUT JUST SCARCITY PRICING AND RESOURCE ADEQUACY IN GENERAL.
UH, ERCOT HAD THE POSITION AT THE LAST MEETING THAT ANY MODIFICATION OF THE SHAPE OF THE RDC TO EXTEND IT, TO REFLECT THE CURRENT AS PROCUREMENT OR, UH, EVEN THE, I THINK THE DISTRIBUTION OF AS UNDER THE RDC WAS A COMMISSION DECISION, SHOULD BE A COMMISSION DECISION.
ERCOT STAFF COMFORTABLE WITH DISCUSSION YEAH.
US MAKING THAT CALL AT AN RTC PLUS B TASK FORCE MEETING.
THAT'S OUTSIDE THE TASK FORCE.
WHAT, HOW DO YOU EXPECT THE PROCESS FOR THAT TO LOOK LIKE? SO IF THERE IS A STAKEHOLDER OR A GROUP OF STAKEHOLDERS THAT WANT TO BASICALLY EXTEND THE RDC CURVE TO REFLECT, UH, CURRENT AS PROCUREMENT QUANTITIES, AND THERE'S A PROPOSAL THAT GETS, WHAT HAPPENS TO THAT THEY WOULD HAVE TO FILE AN NPRR THAT WOULD HAVE TO, OR IS THIS A WE DISCUSS AT THE COMMISSION AND TO GET A PROJECT OPENED, OR, I'M JUST CURIOUS WHAT THAT PROCESS LOOKS LIKE, IF THERE IS ENOUGH SUPPORT TO MOVE FORWARD WITH THAT TYPE OF PROPOSAL.
NOT SAYING THAT MY COMPANY IS OR ISN'T, I'M JUST CURIOUS HOW IT'LL WORK VERY GOOD AS HE KON WILL CHIME IN TO HELP ME.
YEAH, THAT'S A GOOD QUESTION, BILL.
UM, SO TRADITIONALLY WE'VE ONLY MODIFIED THE ORDC CURVE UPON INSTRUCTION FROM, FROM THE COMMISSION.
UM, I WOULD EXPECT THAT IT SHOULD PROBABLY REMAIN IN THAT KIND OF A POLICY FORUM.
UH, HAPPY TO DISCUSS HOW THAT GETS BEFORE THE COMMISSION.
IN THE PAST, UH, THERE HAVE BEEN, UH, UH, REQUESTS OF THE COMMISSION OR THE COMMISSION HAS TAKEN THAT ISSUE UP ON ITS OWN.
UM, SO I THINK THERE'S MULTIPLE WAYS FOR THAT, THAT TO HAPPEN.
UM, I THINK THAT'S WORTH TALKING ABOUT, BUT ULTIMATELY, UM, I DON'T KNOW IF IT SHOULD BE PART OF RTC PLUS B, UH, BUT, UH, YOU KNOW, AND, AND I THINK EVERYTHING ELSE IS KINDA, UH, OPEN TO THE TRADITIONAL WAYS THAT WE HAVE CHANGED THE ORDC CURVE, AND I UNDERSTAND WHY THIS IS A ITEM OF, UH, STRONG INTEREST.
UM, BUT GIVEN SOME OF THE, UH, CONVERSATIONS WE'VE HEARD, HEARD FROM THE DAIS ABOUT, YOU KNOW, POLICY DECISIONS BEING THERE VERSUS, UH, HERE, I THINK, I THINK THAT'S SOMETHING IMPORTANT TO TEE UP BEFORE THEM AND,
[03:50:01]
AND, AND THE TIMELINE FOR THE COMMISSION ON ACTING ON SOME OF THESE THINGS HAS CHANGED BECAUSE OF THE STATUTORY, UH, LANGUAGE CHANGE THAT, UH, I THINK CAME IN IN THE LAST, UH, LAST LEGISLATURE.SO WE PROBABLY NEED TO GIVE OURSELVES A LITTLE BIT MORE RUNWAY THAN WE MIGHT HAVE IN THE PAST.
THAT'D BE THE OTHER POINT I WOULD SHARE WITH TACK ON THAT.
MATT, DID I MISS ANYTHING? NOPE, THAT'S GOOD.
SO, UH, I WAS GONNA ASK A SIMILAR QUESTION TO WHAT BILL HAD ASKED.
AND SO JUST KIND OF, UM, DOVETAILING FROM WHAT YOU WERE SAYING, KENAN, UM, DO I TAKE THAT TO MEAN THAT THE, THE TASK FORCE SHOULD, SHOULD NOT CONTINUE TO DISCUSS IT? BECAUSE I THINK THE, MY TAKEAWAY FROM THE TASK FORCE DISCUSSION WAS THERE CAN BE SOME FORUM FOR, YOU KNOW, EVALUATING OPTIONS, NOT NECESSARILY PUTTING FORWARD A RECOMMENDATION, BUT, YOU KNOW, A SAFE SPACE TO TALK.
UM, AND THAT MAY BE HELPFUL IN INFORMING, YOU KNOW, ANY COMMISSION DECISION DOWN THE LINE, UM, JUST TO HAVE HAD THAT FORUM.
IS THAT, IS THAT STILL, UH, YOUR UNDERSTANDING OR ARE YOU SAYING THAT WOULD NOT BE APPROPRIATE? SO I DID OFFER AT THE TASK FORCE MEETING WAS TO KEEP THE LIGHTS ON AND TURN 'EM OFF AT THE END, BUT THE IDEA WAS TO GET THROUGH THE ISSUES THAT WE HAVE ON, AND THEN THE BALANCE OF THE MEETING CAN BE USED FOR POLICY TYPE DISCUSSIONS, BUT IT'S NOT NECESSARILY THE OWNERSHIP OF THE TASK FORCE, BUT IT'S ALL THE RIGHT PEOPLE IN THE ROOM TO HAVE THAT DISCUSSION.
SO IT COULD BE USED AS A FORM, BUT THE, IF THAT MAKES SENSE.
I JUST WANTED TO CONFIRM THAT WAS, I MEAN, THE, THE, WHAT I WOULD FOCUS ON IS WE, WE HAVE TO DELIVER SOMETHING, UM, AND IT'S, YOU KNOW, MID 20, 26, AND MATT REALLY NEEDS TO FOCUS ON GETTING ALL OF THE HIGH LEVEL DESIGN DONE SO THAT WE CAN TURN THAT INTO REQUIREMENTS AND FUNCTIONALITY, WHATEVER, ULTIMATELY THE, UH, ALL THE INTERESTED PARTIES DECIDE ON WHAT THOSE DEMAND OR PENALTY CURVES LOOK LIKE.
WE BELIEVE WE HAVE PROGRAMMED IN THE OPTIONALITY OF THAT.
I DON'T HAVE ANY PROBLEM WITH FACILITATING ADDITIONAL DISCUSSIONS ON, ON THAT ISSUE.
UM, BUT WHAT I WOULD SAY IS IT'S GONNA BE HARD TO MOVE OFF OF, OFF OF CENTER WITHOUT SOME COMMISSION, UH, IN INPUT ON THAT.
SO IF WE NEED TO SPEND TIME TO FORMULATE WHAT THE BEST ANSWER IS, I THINK THAT'S WORTHWHILE.
I THINK IT, IF WE'RE SPINNING OUR WHEELS, WHETHER WE SHOULD DO THIS OR NOT DO IT, THAT IS JUST GONNA EAT UP RESOURCES WHEN WE SHOULD BE TEEING THIS UP, UH, AT, AT THE PROPER POLICY LEVEL TO, TO GET IT RESOLVED.
AND TO ME THAT IT'S GONNA TAKE A LITTLE BIT MORE TIME THAN WE'RE USED TO ON, ON THIS FRONT.
AND, AND THAT'S WHAT I WOULD KIND OF WANNA SHARE WITH THE STAKEHOLDERS.
ON THE, UH, PUC GUIDANCE SORT OF ISSUE, OR NPRR, THE PUC SORT OF GAVE BROAD GUIDANCE THAT IT SHOULD BE BASED ON THE ORDC, YOU KNOW, UM, CHOPPED UP.
BUT IF WE, UM, YOU KNOW, THE PUC GUIDANCE DOESN'T GO INTO WHETHER WE NEED TO SUBTRACT THE SYSTEM LAMBDA OR HOW MUCH OF THE SYSTEM LAMB WE NEED TO SUBTRACT, OR WHETHER WE NEED TO TAKE OFFLINE CAPACITY INTO ACCOUNT OR NOT.
UM, SO FOR CHANGES LIKE THAT, WOULDN'T NP AN NPRR BE THE, THE, UH, VENUE TO CHANGE THOSE? YES.
THE, IF I'M TRACKING RIGHT, I MEAN, IT SAYS WE WILL USE THE ORDT, THE SQUIGGLY MATH IS IN PROTOCOLS OF HOW THAT MU AND LAMB ARE ALL LINED UP.
AND THEN THE SECOND SECTION SAYS BY BLOCK, THIS IS HOW YOU ASSIGN THOSE.
AGAIN, AND CAITLYN, JUST SO YOU KNOW, THIS WILL START TO BREAK INTO AN RT.
LIKE THIS IS A POLICY DECISION THAT IS A SLOW ROLL, SO WE CAN KEEP TALKING ABOUT IT, BUT, OKAY.
YEAH, WE'RE STILL IN THOSE, WE'RE LISTENING.
WE'RE JUST LOOKING AT, UM, I KNOW YOU HAD SOME BIG STUFF THE TIME AS WELL.
WE, SO WE, WE ARE, AND THANKS FOR THE OPENING.
WE WE'RE TRYING TO WRAP THIS UP, THIS BEING TECH TODAY UP IN TIME TO DO DRS WORKSHOP AT THREE.
WE, WE ARE ENTERING A POLICY DISCUSSION HERE ON RT C PLUS B.
WE HAVE TO FINISH UP NO, G 2 45.
UM, THE ERCOT REPORTS WE DO NEED TO GET TO TODAY BECAUSE THOSE PRICE CORRECTIONS WILL GO TO THE BOARD.
AND THEN ALSO THE UNDER OTHER BUSINESS, THE REVISIONS TO THE BOARD POLICIES AND PROCEDURES WE NEED TO GET TO TODAY AS WELL BECAUSE OF THE BOARD.
UM, SO, SO WE ARE ON A LITTLE BIT OF A, A TIME CRUNCH.
UM, I'LL, I'LL DEFER MATT TO YOU ON, ON HOW YOU WANNA HANDLE THIS.
[03:55:01]
WELL, I JUST SAW DIFFERENT CARDS GOING UP AS WE STARTED GOING DOWN THE RTC REALM.SO WE CLAIM THE ISSUE THAT IT'S BEING DISCUSSED.
NOT A CONCLUSION, NOT A VOTE OR ANYTHING ELSE.
AND IT CAN TAKE, IT CAN KEEP GOING SHAMS, BUT, UM, I JUST WANTED TO LET, I KNOW TACK IS ON A TIMELINE TODAY, SO, OKAY.
SO SHAMS, YOU WANT TO, IS THERE A SPECIFIC PIECE THAT I CAN SAY A YES OR A NO TO OR ARE WE GONNA, I GUESS WE CAN DISCUSS AT, AT THE TASK FORCE MEETING.
SO WE WILL ALL COMMIT TO, UH, COMING TO THE TASK FORCE AND HAVING THOSE POLICY DISCUSSIONS THERE.
AND WE WILL, WE'LL TRY TO, TWO 30 WAS AMBITIOUS, BUT WE CAN GET TWO 50 AND HAVE A 10 MINUTE BREAK AND, AND THEN GET TO OUR DRRS WORKSHOP.
UM, SO LET'S TRY TO TAKE, YOU KNOW, ABOUT 20 MINUTES ON THE REPORTS, 20 MINUTES FOR
[12. ERCOT Reports]
THE NOUR, AND THEN, YOU KNOW, 10, I THINK I'M ALREADY OVER TIME.LET'S TRY TO DO THESE ALL IN 15 MINUTES OR SO EACH.
SO THE PRICE CORRECTIONS, UM, WE HAVE MATT YOUNG, AND I THINK THESE ARE, WE HAVE TWO POTENTIAL PRICE CORRECTIONS.
UH, MATT YOUNG, ERCOT SUPERVISOR OF MARKET VALIDATION, JUST GONNA BE GOING OVER, UH, THIS TWO PRICE CORRECTIONS ARE POTENTIAL PRICE CORRECTIONS THAT WE'LL BE TAKING TO THE BOARD FOR APPROVAL.
UH, THE FIRST ONE I'M GONNA BE TALKING ABOUT IS, UM, AN ISSUE WITH, UH, RATINGS FOR, UH, TRANSMISSION ELEMENTS.
AND, UH, OR COP BECAME AWARE OF THIS ON JANUARY 29TH, UH, WHERE THERE WERE RATINGS, UH, INVALID RATINGS FOR, UH, LINE SERVICE DEVICES, SERIES DEVICES AND TRANSFORMERS.
UH, AS PART OF THE WEEKLY MODEL OR THE WEEKLY MODEL LOAD, EMS UH, RETAINED OUTDATED STATIC RATINGS FOR THESE DEVICES STARTING IN NOVEMBER, UH, THROUGH JANUARY.
UM, AND OF COURSE, THE REAL-TIME MARKET DAY HEAD MARKET USED THESE RATINGS.
JANUARY 30TH, UH, ER ERCOT IMPLEMENTED A FIX TO ENSURE THE CORRECT RATINGS WERE USED.
UM, AND THE NOTICE WAS SENT OUT ON FEBRUARY 5TH, NOTIFYING THE MARKET OF THE ISSUE AND ERCOT INTENT UPON COMPLETION OF ANALYSIS TO SEEK PRICE CORRECTION FROM THE BOARD.
ON MARCH 12TH, UH, WE ISSUED ANOTHER MARKET NOTICE WITH THE, UH, THE RESULTS OF THE IMPACT ANALYSIS.
I'M JUST GONNA GO OVER THE, UH, UH, THE IMPACT ANALYSIS ITSELF.
UM, PROTOCOL REQUIRES THAT TO SEEK BOARD APPROVAL, THE ABSOLUTE VALUE IMPACT TO ANY SINGLE COUNTERPARTY MUST MEET ONE OF THE FOLLOWING TWO CRITERIA, ONE, EITHER 2%, UH, AND OF THE ABSOLUTE VALUE IMPACTS AND, OR, AND GREATER THAN 20,000 OR 20% AND GREATER THAN 2000.
AND ERCOT DETERMINED FOR THE REAL TIME MARKET THAT THERE WERE THREE OPERATING DAYS DURING THIS TIME THAT MET THAT CRITERIA.
UH, THE 15, 17TH AND 19TH WITH, UH, THE HIGHEST BEING, I GUESS THE 15TH AND THE 17TH FOR CRITERIA ONE AND THE 17TH FOUR CRITERIA TWO, UH, FOR THOSE OPERATING DAYS, UM, THE MAXIMUM ABSOLUTE VALUE IMPACT TO ANY SINGLE COUNTERPARTY WAS GREATEST ON THE 17TH WITH, UH, APPROXIMATELY A MILLION.
AND THE PERCENTAGE FOR CRITERIA ONE, UH, MAX BEING 2, 260 2%, AND 565% FOR CRITERIA TWO.
AND THEN, UH, FOR THE TOTAL CHANGE IN, UH, STATEMENT CHARGES DUE TO ERCOT, UM, 17TH AGAIN WAS THE LARGEST WITH, UH, A CHANGE OF 877,000.
UH, AND THIS IS A, A NEGATIVE, WHICH MEANS THAT IT'S, UH, A CHANGE IN THE PAYMENTS TO THE MARKET PARTICIPANTS.
THE DAY AHEAD IMPACT WAS A LITTLE LARGER.
IT WAS, UH, A TOTAL OF EIGHT DAYS.
UM, AS YOU CAN SEE, UH, MORE MARKET OR COUNTERPARTIES MET CRITERIA TWO THAN CRITERIA ONE WITH THE LARGEST BEING ON THE 18TH WITH 41.
AND, UH, FOR THE MAXIMUM ESTIMATED VALUE IMPACT.
THAT'S, UH, THE 19TH 249,000, AND THE LARGEST PERCENTAGE FOR CRITERIA ONE BEING ON THE 18TH WITH 4 47.
AND THEN, UH, THE SAME DAY FOR CRITERIA TWO BEING A HUNDRED OR 1281%.
AND THEN THE LARGEST CHANGE IN STATEMENTS TO ERCOT FOR THE DAY AHEAD MARKET,
[04:00:01]
UH, LARGEST WAS ON THE 19TH WITH A CHANGE IN NET PAYMENT TO THE MARKET MARKET PARTICIPANTS OF 691,000.UM, NEXT STEPS IS TAKING THESE TO, UH, THE, UH, RELIABILITY MARKET COMMITTEE MEETING AS WELL AS THE BOARD FOR APPROVAL.
SO, AND THEN, UH, GO AHEAD AND GO OVER THE SECOND ONE.
UM, SO THIS ONE IS ABOUT, UH, WE HAD AN ISSUE WITH, UH, GTC CONSTRAINT DATA ON FEBRUARY 8TH.
UM, IT WAS DURING ROUTINE MAINTENANCE IN THE PROCESS THAT THAT EXPORTS, THAT CONSTRAINT DATA RAN INTO AN ISSUE, UH, THAT RESULTED IN THE INCON, UH, INCORRECT CONSTRAINT DATA FOR GTCS BEING SENT, UH, TO THE MMS WHERE SCED, UH, USED THEM.
UM, THE AFFECTED SCED INTERVALS WERE BETWEEN 1550 AND 1625.
UM, AND THEN ON THE MARCH 1ST IS WHEN WE SENT OUT AN OPERATIONS NOTICE, UH, NOTIFYING THE, UH, THE MARKET OF THE ISSUE, AND THAT WE'LL BE, WE WOULD BE PERFORMING ANALYSIS, UH, TO SEE IF WE MEET CRITERIA FOR SIGNIFICANCE.
MARKET NOTICE, UH, WAS SENT OUT ON MARCH 18TH WITH THE RESULTS OF THE ANALYSIS AND THAT ERCOT WOULD BE SEEKING, UH, BOARD APPROVAL, UH, THE IMPACT ANALYSIS FOR THAT DAY.
UH, THERE WERE SEVEN COUNTERPARTIES THAT MET FOR CRITERIA ONE AND NINE FOR CRITERIA TWO.
UM, MAXIMUM ESTIMATED, UH, VALUE IMPACT WAS 400 4450 5,000 WITH A MUCH LARGER PERCENTAGE THAN, UH, THE PREVIOUS PRICE CORRECTION OF, UH, 2137% FOR BOTH CRITERIA.
AND THE ESTIMATED CHANGE IN CHARGES DUE TO ERCOT WAS A NET, UH, CHARGE TO THE MARKET PARTICIPANTS OF 277,000.
AND, UH, WE SEEK TO TAKE THIS TO THE RELIABILITY MARKET COMMITTEE MEETING AS WELL AS THE BOARD FOR APPROVAL IN APRIL.
UM, SO THE, YOU KNOW, THE, THE FACT THAT WE DO THIS AND DO IT RIGHT IS VERY IMPORTANT TO, TO ERCOT, BUT EQUALLY IMPORTANT IS, YOU KNOW, THE SOURCE OR THE ORIGIN OF, OF THE ERROR.
AND I JUST WANTED TO SHARE WITH TAC THAT THE FIRST ITEM THAT, UM, THAT MATT IDENTIFIED IS, UM, GONNA BE ONE OF THE ISSUES THAT THE NEW RISK AND, UM, CONTINUOUS IMPROVEMENT GROUP IS, HAS IDENTIFIED AS SOMETHING TO SPEND MORE TIME ON.
SO, UH, AND, AND THAT'S NOT PART OF MATT'S PRESENTATION, BUT I THINK IT'S IMPORTANT TO SHARE WITH TACK THAT IT'S NOT JUST THAT WE'RE GOING THROUGH THIS EXERCISE, BUT WE ARE TRYING TO FIND WAYS TO ELIMINATE THESE ERRORS, UH, AS MUCH AS POSSIBLE.
SO THAT'S A, THAT'S AN IMPORTANT ASPECT TO ME, AND WE'RE TRYING TO STAND UP, UH, A KIND OF A NEW ORGANIZATION THAT WOULD BE VERY FOCUSED ON LOOKING AT ROOT CAUSES AND, AND, UH, HOPEFULLY, UH, ELIMINATING, UH, AND DEFINITELY REDUCING THE INCIDENCES OF THESE TYPES OF ACTIVITIES.
SO, I, I JUST WANTED TO SHARE THAT WITH TACK.
IT'LL COME UP AT THE BOARD, UM, BUT I WANTED YOU TO GET A FLAVOR OF THAT ASPECT OF IT AS WELL.
I, I DON'T THINK WE NEED A VOTE ON THIS, CORRECT? WHAT? NO.
THANK YOU VERY MUCH FOR SAYING THAT KAAN.
'CAUSE I WAS GONNA ASK A QUESTION ABOUT THAT, BECAUSE I BELIEVE THE FIRST ONE SPECIFICALLY, SOMEWHERE IN MY DEAD BRAIN CELLS FROM THE PAST, I THINK I RECALL SOME PRICE CORRECTIONS BASICALLY ON THE SAME STUFF ON WHETHER IT MET THE CRITERIA OF WHERE WE DID THE PRICE CHANGE.
I DON'T RECALL, BUT THAT WAS GONNA BE MY QUESTION.
ARE WE LOOKING AT THAT ASPECT? SO YOU'VE ANSWERED IT.
ARE THERE ANY QUESTIONS OR COMMENTS FURTHER? SO WE DO NOT HAVE TO TAKE A VOTE ON THIS.
WE ARE GOING TO, UM, DELAY THE M-D-R-P-O-C UPDATE.
LUKE VERY GRACIOUSLY OFFERED TO DELAY THIS, SO WE WILL DO TAKE THAT UP AT APRIL T AND LET US DO
[04:05:01]
THE NOER AND THEN OTHER BUSINESS, AND THEN WE CAN ALL GET TO THE DRS WORKSHOP.[6. Revision Requests Tabled at TAC (Possible Vote) (Part 2 of 2)]
WE ARE BACK TO NOER 2 45, AND WE HAVE A CARD UP FROM BOB HILTON.OR A SUMMARY OR BOTH? IT'S A MOTION.
AND THEN WE CAN GO INTO SOME DISCUSSION ON THAT, BUT WE MAY, IT'S, IT'S MADE MUCH, MUCH EASIER NOW.
ARE YOU READY? I THINK YOU HAVE THIS LANGUAGE.
I MAKE THE, WHAT WE'RE GONNA CHANGE IS TWO 14, WE'RE ADDING IN PARAGRAPH C, SO I JUST SHOW THEM.
SO WHAT SET OF COMMENTS ARE WE WORKING OFF OF? WE'RE WORKING ON JUST EXACTLY WHAT'S UP THERE.
THERE'S SOME, THERE'S SOME DESKTOP EDITS THAT CORY HAS.
SO WE, YEAH, THIS IS A DESKTOP EDIT THAT WE'RE GONNA BE ADDING TO THE 3 22 JOINT COMMENTS.
SO NOER 2 45, WE ARE LOOKING AT THE 3 22 JOINT COMMENTS, AND WE ARE NOW WORKING ON DESKTOP EDITS.
AND WE'RE JUST ADDING THE ONE, ONE PARAGRAPH.
UH, AND STEVE, THANK YOU FOR, I KNOW YOU'RE PROBABLY NOT GONNA SUPPORT THIS, BUT THANK YOU FOR HELPING WORK THROUGH THAT.
SO LET US, LET'S ERIC GOFF AND THEN STEVEN, IS IT, DO YOU HAVE A CARD UP? HE, HE HAD HIS CARD UP FIRST.
SO I, I APPRECIATE THE EFFORTS THAT WE'RE TRYING TO BE, UH, MADE FOR TAC TO PRODUCE SOMETHING.
I THINK FROM ERCOT PERSPECTIVE, WE'RE BETTER OFF JUST LEAVING THE VOTE WHERE IT WAS, UH, THIS LANGUAGE THAT YOU SEE BEFORE YOU, THIS WAS LANGUAGE THAT ERCOT SHARED WITH THE JOINT COMMENTERS SEVERAL WEEKS AGO.
UH, WE GOT FEEDBACK FROM THE JOINT COMMENTERS THAT SAID WE'D BE OKAY WITH THIS LANGUAGE.
SO LONG AS IT SAID THINGS A CERTAIN WAY THAT YOU SEE BEFORE YOU ERCOT INCLUDED THAT IN ITS COMMENTS, THE JOINT COMMENTERS DID NOT, EVEN THOUGH THAT THEY AGREED TO THAT LANGUAGE, THEY CHOSE NOT TO PUT IT IN THERE.
SO THAT'S THE ONLY THING THAT THEY'VE INCLUDED.
AND IT DOES NOTHING TO ADDRESS THE CONCERN BECAUSE IT STILL TIES TO THE FACT THAT IF THEY HAVE A PERFORMANCE FAILURE, ALL THEY HAVE TO DO IS WHAT THEY THINK IS COMMERCIALLY REASONABLE.
AND, AND SO AFTER THAT, THEY CAN STILL APPLY FOR ANOTHER EXEMPTION AND CONTINUE TO LOWER THE REQUIREMENTS.
SO THIS IS, THIS DOES NOTHING.
AND WHEN YOU LOOK THROUGH THE BODY OF LANGUAGE, SO WE WERE TRYING TO FOCUS AND KEEP THINGS ON A HIGH LEVEL, BUT STARTING OFF WITH THE JOINT COMMENTER'S LANGUAGE, IT DOESN'T ENCAPSULATE A LOT OF WHAT THE WORK THAT WE DID TO COME TO COMPROMISE, BECAUSE THEY'RE STARTING NOT ON TOP OF ERCOT COMMENTS, BUT ON TOP OF THE ONE EIGHT COMMENTS.
AND THEY'VE WORDED THINGS IN A PARTICULAR WAY THAT OFFERS THEM A LOT MORE LATITUDE TO GET OUT OF COMPLIANCE OBLIGATIONS.
SO, ERCOT WITH THIS LANGUAGE, WE CAN'T PROTECT RELIABILITY, AND WE'RE TRYING TO BE VERY TRANSPARENT ABOUT THAT, THAT IF YOU VOTE THIS FORWARD WITH THE JOINT COMMENTER'S LANGUAGE, WE CANNOT ENSURE RELIABILITY.
THERE IS NOT ENOUGH LANGUAGE FOR US TO DO THAT.
AND SO WE APPRECIATE THE EFFORT, BUT FROM OUR COTS PERSPECTIVE, WE'RE BETTER OFF WITH THE TWO FAILED VOTES, AND THEN WE CAN BOTH APPEAL.
ERIC GOFF, UH, THANK YOU ERIC GOFF, AGAIN, ON BEHALF OF NEXTERA AND, UH, SPEAKING, UH, FOR THE JOINT COMMENTERS HERE.
UM, SO WE APPRECIATE THE BACK AND FORTH.
UM, THE INTENTION OF THIS EDITION IS TO BE CLEAR THAT THE EXEMPTION THAT ERCOT WOULD GRANT HERE WOULDN'T BE BELOW THE EXISTING STANDARD.
AND, UM, I APPRECIATE THE OTHER POINTS THAT, UH, STEVEN RAISED.
THIS IS IN THE CONTEXT OF COMMERCIAL REASONABILITY, LIKE HE SAID.
UM, BUT THE COMMERCIAL REASONABILITY PROCESS GOES TO ERCOT FOR ITS, ITS, UH, REVIEW OF THAT.
AND THEY CAN SAY THAT THEY DON'T, THAT THEY THINK THAT SOMETHING IS COMMERCIALLY REASONABLE AND WE HAVE TO APPEAL THAT.
SO I, UM, I HOPE THAT WE CAN, UH, TAKE A VOTE ON THIS AND, AND, AND SEE HOW THE OUTCOME IS.
BILL BARNES, JUST APPRECIATE THE ADDITIONAL EFFORT ON THIS TO TRY TO REACH MORE OF A COMPROMISE.
I THINK THE, THE GOAL HERE IS TO
[04:10:01]
STRIKE SOME TYPE OF BALANCE.UM, AND I UNDERSTAND THAT THAT BALANCE, UM, ISN'T COMPLETELY ACCEPTABLE TO ERCOT.
WHAT ALSO DO THINK IT'S IMPORTANT FOR THE STAKEHOLDER VOICE TO BE HEARD AT THE BOARD, AND THAT ADMITTEDLY IS NOT ENTIRELY ALIGNED WITH MY COMPANY'S VIEW, BUT IT'S ALIGNED ENOUGH AND IT ADDRESSES A LOT OF THE CONCERNS THAT WE HAD AND SENDS A MESSAGE TO THE BOARD FOR CONSIDERATION.
THAT WEIGHS A LOT OF VERY IMPORTANT POINTS.
ADMITTEDLY, I, I, I SHARE A LOT OF THE CONCERNS WITH
THAT IS A BIG CONCERN OF OURS, BUT JUST AS MUCH AS THE IMPACT TO EXISTING RESOURCES IS ALSO A VERY HEAVY ISSUE THAT THE BOARD NEEDS TO WEIGH.
UM, BUT I DO FEEL STRONGLY ENOUGH THAT THIS IS SOMETHING THAT NEEDS TO MOVE FORWARD TO THE BOARD WITH A STAKEHOLDER POINT OF VIEW.
AND SO WE APPRECIATE THE ADDITIONAL INCREMENTAL EFFORT HERE, UH, KNOWING THAT IT, IT'S NOT GONNA SATISFY ALL THE CONCERNS OF ALL THE PARTIES.
OKAY, STEVEN? YEAH, I THINK I JUST WANT TO CLEARLY POINT OUT WHAT THIS LANGUAGE SAYS, WHICH IS VERY SIMILAR LANGUAGE TO WHAT IS IN SECTION THREE 15 OF THERE ARE PROTOCOLS AROUND REACTIVE CAPABILITY REQUIREMENTS.
THAT IS AROUND WHEN YOU REPOWER WHEN YOU MODIFY, YOU CAN'T MAKE IT WORSE.
THAT'S REALLY WHAT THAT LANGUAGE SAYS.
THEY'RE TRYING TO APPLY IT IN A SECTION WHEN THEY HAVE A PERFORMANCE FAILURE.
AND WHAT WE'RE TRYING TO JUST HOLD TO IS THAT IF YOU SAY YOU'RE CAPABLE OF THIS, IF YOUR REQUIREMENT IS THIS BAR AND YOU DON'T PERFORM, YOU NEED TO MODIFY, YOU NEED TO FIX IT, YOU NEED TO GET TO THAT PERFORMANCE BECAUSE WE HAVE BASED ALL OF OUR PLANNING, WE'VE BASED ALL OF OUR OPERATIONS ON THE ASSUMPTION THAT YOU'RE GONNA DO WHAT YOU SAID YOU WERE ABLE TO DO.
AND WHEN YOU CAN'T DO THAT AND YOU JUST GRANT ANOTHER EXEMPTION, HOW LONG DOES IT TAKE TO PLAN THE SYSTEM TO CATCH UP TO THAT ISSUE? YOU'RE GONNA HAVE THAT RISK FOR THAT PERIOD OF TIME.
THIS IS A FUNDAMENTAL PROBLEM THAT I JUST WANT TO MAKE SURE EVERYBODY IN THE STAKEHOLDERS, AS YOU MAKE YOUR TAC OPINION, TAKES THAT INTO CONSIDERATION.
THIS WORSENS RELIABILITY FROM EVEN WHERE WE'RE AT TODAY, BECAUSE AT LEAST TODAY WE HAVE REQUIREMENTS THAT THEY HAVE TO MITIGATE AT LEAST THE CURRENT RIDE THROUGH REQUIREMENTS.
IF YOU FAIL, YOU HAVE TO GO TO THE COMMISSION, YOU HAVE TO MITIGATE IT, YOU HAVE TO FIX IT.
WE ARE PUTTING IN A CONSTRUCT THAT LIMITS THAT, THAT REDUCES IT, AND THAT IS WORSENING RISK FROM ERCOT PERSPECTIVE.
ALICIA, I JUST HAVE A QUICK CLARIFYING QUESTION.
SO WHAT WAS JUST WORKED ON MAKES THE REPS FEEL MORE COMFORTABLE, BUT ERCOT LESS COMFORTABLE THAN THEY WERE TO BEGIN WITH, IS THAT RIGHT? YES, BECAUSE IT IS, IT IS MOVING FORWARD WITH A CONCEPT THAT, BECAUSE WE WENT INTO A ROOM WITH THEM THAT SOMEHOW THIS HAS ERCO T'S INPUT, ERCO T'S INPUT WAS TO MAKE OTHER MODIFICATIONS, WHICH THEY DENIED TO MAKE RIGHT NOW.
AND SO THIS HAS NOT CHANGED ANYTHING.
THEY, THEY BASICALLY THREW A BONE ABOUT LANGUAGE THAT IS IN ERCOT CURRENT RULES, I MEAN, CURRENT PROPOSED LANGUAGE THAT THEY ALREADY HAD AGREED TO IN THE JOINT COMMENTERS DISCUSSIONS THAT WE HAD, BUT THEY DIDN'T INCLUDE IT.
I JUST, I DON'T WANT TO GET HER BACK AND FORTH.
I JUST WANTED TO SAY THAT WE DISAGREE WITH SOME OF THE STATEMENTS THAT STEVEN MADE AND WE LOOK FORWARD TO TAX DECISION.
ERIC BLAKEY, I JUST, IF THIS WAS COVERED, I APOLOGIZE, BUT I'M, I'M CURIOUS WHY THE, WHY THE, UH, THE GROUP DIDN'T WORK OFF OF THE ERCOT COMMENTS TO, TO MAKE THEIR RED LINES INSTEAD OF YEAH.
WANNA, I'M JUST CURIOUS WHY NOT THE, SURE.
SO WE, THESE COMMENTS ARE ON THE JANUARY ERCOT COMMENTS AND, UM, IN ORDER TO MAKE COMMENTS FROM THE COMMENTS THAT ERCOT FILED A WEEK AGO TODAY, YOU WOULDN'T HAVE HAD COMMENTS IN TIME FOR TODAY'S MEETING.
SO WE HAD TO MAKE A JUDGMENT CALL BASED ON WHEN THEY WERE, AND, AND IT'S JUST A PRACTICALITY OF THE MEETING TIMING.
IT WAS OUR INTENTION TO INCLUDE, YOU KNOW, THE CONCEPTS IN THOSE COMMENTS.
AND I THINK WE DID THIS GOOD IF WE COULD BECAUSE WE BASED THEM OFF OF OUR PRIOR SET OF NEVER GOT COMMENTS.
[04:15:01]
I GUESS I'M JUST CURIOUS IS, IS THERE ANY, ANY VALUE IN WORKING ON THAT AND, AND SEEING IF WE COULD TAKE A COMPROMISE POSITION OFF OF THOSE COMMENTS? 'CAUSE IT SEEMS LIKE A LOT OF WHAT I HEAR FROM ERCOT IS Y'ALL AREN'T INCLUDING SOME OF THE THINGS THAT THEY HAD IN THIS LAST VERSION.I, I THINK, UM, I DON'T, I'M NOT, I'M DEFINITELY NOT SPEAKING FOR ERCOT WHEN I SAY THIS, BUT THERE, THEY PREFER THE WAY THINGS ARE WORDED, UM, TO THE WAY THAT WE WORDED THINGS, UM, BECAUSE OF INTERPRETATION DIFFERENCES.
AND I THINK SOME OF THOSE ARE INTENTIONAL ON OUR PART BECAUSE WE'RE TRYING TO MAKE SURE THAT WE'RE PROTECTING, UH, THAT INVESTOR SENTIMENT THAT I MENTIONED EARLIER, AND TO THE, BUT TO THERE ARE ANY UNINTENTIONAL ONES.
IT'S DEFINITELY OUR INTENTION TO REVIEW THIS AGAIN BEFORE THE BOARD TO SEE IF THERE'S ANYTHING ELSE WE CAN DO TO CONTINUE TO IMPROVE THIS.
UM, SO, UH, I EXPECT WE'LL BE DISCUSSING THIS AT THE BOARD, UM, AND WE'LL HAVE TO EXPLAIN OURSELVES TO THE BOARD.
MAY, MAY I MAKE ONE COMMENT, PLEASE? YES.
I WANNA MAKE IT VERY CLEAR THE VERSION YOU'RE LOOKING AT, THE BASIS IS THEIR COMMENTS.
THEY TOOK ONE PARAGRAPH FROM OUR COMMENTS AND PUT IT IN THEIR COMMENTS.
SO I THINK I HEARD ERIC, ERIC SAY THAT YOU'RE LOOKING AT OUR COMMENTS.
YOU'RE NOT, I DIDN'T SAY WHAT'S BEING VOTED ON IS, IS THE JOINT COMMENT OR, ALL RIGHT, SO, SO BOTH OF THE COMMENTS THAT WERE BROUGHT TO THIS MEETING FROM, FROM JOINT COMMENTS IN ERCOT WERE OFF OF JANUARY.
I THINK ERIC'S QUESTION WAS TO WHY THESE INTRA MEETING COMMENTS WEREN'T MADE OFF OF THE ERCOT MARCH COMMENTS INSTEAD OF THE JOINT COMMENT OR MARCH COMMENTS.
I, I THINK THAT JUST WASN'T FEASIBLE AT THE, AT THIS TIME.
YOU KNOW, WE, WE'VE HAD A LOT OF DISCUSSION ON THIS.
IT IS KIND OF SOME SMALL POINTS, BUT WE'RE, WE'RE WRITING IN DIFFERENT LANGUAGES FROM WHAT I CAN TELL.
SO IT'S REALLY HARD TO TRANSPOSE ELEMENTS ONTO ONE VERSION OF THE COMMENTS.
I I'M CERTAINLY NOT OPPOSED TO TACK TAKING MORE TIME OR, YOU KNOW, HAVING A SPECIAL MEETING OR ANOTHER MEETING TO REALLY DEVELOP LANGUAGE.
BUT I THINK WHERE THOSE TWO COMMENTS ARE, THEY'RE KIND OF WRITTEN IN A, A DIFFERENT LANGUAGE WITH DIFFERENT MEANINGS BETWEEN WORDS.
SO IT WOULD TAKE A LOT OF WORK TO GET ONE VERSION IS DO WE HAVE A MOTION ON THIS? WE DID HAVE A MOTION FROM BOB HILTON.
DO WE WANT TO HAVE MORE DISCUSSION? I THINK ERCOT.
ONE, ONE LAST COMMENT FROM ERCOT.
I THINK WE'RE FAIRLY CLEAR ON THEIR POINT OF VIEW, BUT STEVEN, GO AHEAD.
SO ERIC, JUST A QUICK QUESTION.
IF TIME, IF THE REASON WHY Y'ALL DIDN'T MAKE COMMENTS ON TOP OF ERCOT COMMENTS WAS JUST TIME.
ARE Y'ALL WILLING TO SUBMIT ANOTHER SET OF COMMENTS THAT START FROM ERCOT COMMENTS BETWEEN NOW AND THE BOARD? WE, WE WILL TAKE A LOOK AT WHAT YOU HAVE IN THERE.
WE, AS YOU SAID, THERE'S DIFFERENCES OF INTENTION IN SOME OF THE WORDS.
AND SO WHAT, WHAT I CAN DO REACTING OFF THE CUFF TO THE CONVERSATION IS WE WILL HAVE A CONVERSATION WITH THE FULL DRUG COMMENTERS AND YOU TO TALK ABOUT HOW, IF POSSIBLE, WHAT WE CAN DO THERE.
I, I GET THE INTENTION AND THERE MIGHT BE SOME THINGS THAT WOULD, COULD BE IMPROVED BY THAT, AND WE'LL DEFINITELY TAKE A LOOK AT IT.
BUT WITHOUT HAVING SPOKEN TO THE ENTIRE GROUP, I DON'T WANT TO COMMIT TO SOMETHING SPECIFIC ON THAT.
BUT I WILL COMMIT TO REVIEWING THE IDEA BECAUSE TO THE EXTENT THERE'S SOMETHING THAT'S MISSING, THAT'S UNINTENTIONAL, THAT'S NOT OUR, THAT'S NOT OUR INTENTION.
AND I DO THINK THAT THAT IS IN EVERYONE'S BEST INTEREST, WHICH IS PART OF MY SUPPORT IS WORKING TOGETHER, CONTINUING TO WORK TOGETHER WITH ERCOT STAFF TO POTENTIALLY AVOID AN APPEAL.
MY PERSONAL VIEW IS I DON'T THINK IT'S A GOOD LOOK TO HAVE TWO APPEALS GOING TO THE ERCOT BOARD.
AND I VALUE THE STAKEHOLDER OPINION ENOUGH TO GET OVER THE HANGUPS THAT WE HAD SO THAT WE CAN SEND DIVERSION THERE FOR CONSIDERATION AND HAVE ERCOT PRESENT THEIR APPEAL IF THEY WISH TO DO SO.
THE BETTER OUTCOME WOULD BE TO WORK TOGETHER, POTENTIALLY GET THOSE LANGUAGE CHANGES DONE SO THAT THERE'S MORE OF A UNIFIED, UH, UH, POSITION AT THE BOARD.
BUT THAT'S WHERE WE ENDED UP LANDING ON THIS ONE.
I'M GONNA PUT MY CARD UP BECAUSE I, I'M GONNA, I THINK, PUT A PERSONAL OPINION ON THERE.
I, I DON'T KNOW THAT I AG AGREE WITH THAT BILL.
I, I'M LESS CONCERNED WITH THE OPTICS ON HOW, YOU KNOW, IT, IT LOOKS THAN WITH GETTING EVERYBODY'S ACTUAL POSITION ON RECORD.
[04:20:01]
I, I'D HATE TO SAY, YOU KNOW, WE VOTED X WAY OR, OR Y WAY BECAUSE WE DIDN'T LIKE THE WAY TWO APPEALS WOULD LOOK THEN TO NOT GET, YOU KNOW, EV EVERYBODY'S REAL POINT OF VIEW ON, ON PAPER.I DON'T, I DON'T KNOW IF THAT'S WHAT YOU WERE SAYING, BUT I THINK THE, THE OUTCOME WITH TWO APPEALS PRESENTS MORE OF A DIVIDED VIEW THAN I THINK REALLY EXISTS, AT LEAST FROM OUR COMPANY'S POINT OF VIEW.
SO THAT'S, THAT'S THE CLARIFICATION.
I THINK AS I ARTICULATED, I THINK THE DISCREPANCY ARE, ARE ON VERY FEW ISSUES, BUT I THINK WE ARE KIND OF SPEAKING TONALLY AT LEAST, SO SOME DIFFERENT LANGUAGES, SO IT JUST TAKES A LITTLE BIT MORE TIME TO GET TO THE RIGHT PLACE.
COREY, YOU WANNA TAKE IT AWAY? ABSOLUTELY.
SO THE MOTION BEFORE Y'ALL IS TO RECOMMEND APPROVAL AS AMENDED BY THE JOINT COMMENTER, TWO COMMENTS AS REVISED BY TAC.
AND AS BOB POINTED OUT, IT'S JUST THIS ADDITION TO LANGUAGE IN SECTION TWO POINT 14, SO THE REST OF THE JOINT COMMENT OR TWO COMMENTS ARE UNTOUCHED.
SO THAT'S WHAT YOUR MOTION LOOKS LIKE.
AND ON THIS MOTION, WE WILL BEGIN UP WITH THE CONSUMERS WITH NO BRUSH ABSTAIN.
AND THEN FOR ERIC ABSTAIN, YOU? GARRETT? YES.
ERIC SCHUBERT? YES, THANK YOU.
YES, MARK AND MARK FOR NICK? YES.
ONTO THE CO-OPS AND, SORRY, OLD BALLOT.
NEED TO UPDATE WITH ALL THE, UH, DEPARTED, UH, BLAKE FOR MIKE, NO.
MOVING ON TO OUR INDEPENDENT GENERATORS, BRIAN SAMS, I CAN TAKE IN CHAT IF YOU'RE HAVING COMMUNICATION ISSUES.
ONTO OUR IPMS, UH, IAN FOR SETH? YES, FOR ALL THREE.
MOVING ON TO OUR I REPS BILL? YES, THANK YOU, JENNIFER.
JAY, WHAT WAS THAT? ACTUALLY, I'M NOT SEEING JAY IN OUR CHAT ANYMORE.
AND UNDER OUR IOUS, KEITH, THANK YOU, UH, JIM FOR DAVID.
UH, NOW WE'RE DOWN TO DAVID FOR RICHARD.
AND I'M STILL NOT SEEING ANYTHING FROM BRIAN.
69%, FOUR 31% AGAINST, WITH THREE ABSTENTIONS.
WE WERE, I WAS JUST FOLLOWING UP WITH ANN, SO THIS IS A POSITIVE ACTION, SO THERE'S NOT NO APPEALS, BUT WE CAN, PEOPLE CAN FILE COMMENTS AS WE'VE DISCUSSED AND SHE WILL SEND EMAILS ON THE OPPOSING VOTES.
I DO WANNA SAY THANK YOU BECAUSE THAT WAS A LOT OF WORK, UM, THROUGH THE MEETING.
UM, ESPECIALLY STEVEN, THANKS FOR BEING HERE IN PERSON, UH, AND PUTTING ALL THAT WORK INTO IT.
[04:25:01]
BILL, GO AHEAD.CAN WE GO BACK TO THE MAXIMUM DAILY RESOURCE PLAN OUTAGE CAPACITY? IS THAT, DOES THAT HAVE TO BE TAKEN UP AT TAC? CAN WE REFER THAT WMS IT SO WE DON'T HAVE TO WAIT ANOTHER MONTH? THIS IS HAVING A PRETTY BIG IMPACT ON OKAY.
CAN WE, I THINK WE CAN, WE DON'T NEED A VOTE, SO I, I THINK WE'D LIKE TO SEE IT ATTACKED, BUT I DON'T SEE WHY I COULDN'T GO TO WMS FIRST.
WOULD YOU'D LIKE TO HAVE THE DISCUSSION SOONER? 'CAUSE I THINK THERE'S GONNA BE, OKAY.
CAN YOU GUYS PUT THAT ON THE, UM, WHATEVER THANK YOU.
OKAY, SO IT MAY HAVE TO BE FINALIZED, SO IT'LL BE REVISION REVISED WMS AGENDA NUMBER ONE PER PERFECT.
AND THEN, UM, THE BOARD POLICIES AND PROCEDURES, WE ARE GONNA WAIT ON THAT TOO.
WE, WE WILL DISCUSS IT IN APRIL, BUT WE WOULD ASK THAT EVERYBODY REVIEW THAT AND SEND QUESTIONS AND COMMENTS TO KIM.
AND SO WE, THAT WILL BE TAKEN UP AT THE APRIL BOARD, BUT IT'S NOT A VOTING ITEM FOR US.
SO I THINK AS LONG AS WE GET IT DISCUSSED AT THE APRIL TAC, I DO WANNA SPEND MORE THAN 13 MINUTES ON IT.
UM, I THINK IT'S PRETTY IMPORTANT, ESPECIALLY FOR THIS GROUP.
SO PLEASE DO TAKE A LOOK AT THAT AHEAD OF APRIL TECH.
UM, AND IF YOU WANNA SEND QUESTIONS, COMMENTS AHEAD.
AGAIN, THAT'S TO KIM ANN, WOULD YOU LIKE
[13. Other Business]
TO DO A, A QUICK UPDATE ON THE BOARD STAKEHOLDER ENGAGEMENT? WHAT REBECCA'S GONNA DO IT? REBECCA, WE DON'T NEED TO PULL UP THE SLIDES, GIVEN THE TIMING.THE ONE REQUEST IS THAT IF YOU HAVE NOT RESPONDED TO ANNE'S SURVEYS, LOOKING AT THE, UM, TIME SLOTS, IF YOU RESPONDED THE FIRST TIME, WE APPRECIATE IT.
IF YOU HAVE NOT RESPONDED AT ALL, IF YOU DO NOT RESPOND BY THE END OF THE WEEK, WE WILL NOT BE INCLUDING YOU FOR THIS YEAR.
SO PLEASE, IF YOU'RE A STRAGGLER, GET THAT DONE.
AND THEN EVERYBODY RESPOND WITH THE DECEMBER DATES.
WE'LL BE SENDING OUT THE APRIL BOARD PARTICIPANTS, UM, THIS WEEK, AND THEN THE REST OF THE YEAR, HOPEFULLY, UM, LATER IN APRIL.
THE DEADLINE IS THIS FRIDAY TO RESPOND ON THAT, OR YOU'LL NOT, YOU HAVE NOT RESPONDED AT ALL, AND THERE'S A FEW, PLEASE RESPOND BY FRIDAY OR WE'RE MOVING FORWARD WITHOUT SCHEDULING YOU.
UM, THE OTHER TWO THINGS, WE CAN DO THIS DISCUSSION LATER.
I JUST WANTED TO RAISE WITH THE GROUP THE, YOU KNOW, WHEN WE WANNA GET MATERIALS IN FOR REVIEW HERE, UM, WE CAN DO THAT NEXT WEEK.
THE N-S-O-R-M-R PROCESS, I GOT A FEW QUESTIONS ON JUST A REFRESHER OF THAT PROCESS.
UM, I THINK WE MAY HAVE LOST KAN, BUT I DON'T KNOW IF SOMEBODY FROM ERCOT WANTS TO, SO NOT A SUBSTANTIVE UPDATE, JUST A REFRESHER ON THE PROCESS FOR, FOR THOSE WHO ARE ASKING FOR IT.
YEAH, SO THE GENERAL PROCESS IS WE RECEIVED THE THIS NOTICE, UM, AND WE'LL, WE'LL REVIEW THAT TO DETERMINE WHETHER OR NOT AN RMR UNIT'S NEEDED.
ONCE THAT DETERMINATION IS MADE, UH, WE LOOK AT CONTRACTING WITH THE RMR UNIT OR AN MRA PER, UH, PER UH, REQUIREMENTS IN THE PROTOCOLS.
SO THAT ONLY HAPPENS IF THE RMR IS NEEDED.
SO THAT'S KIND OF LIKE THE FIRST BREAK OR FIRST DECISION POINT IS DO WE NEED AN RMR OR NOT FOR RELIABILITY REASONS, THEN IT'S ABOUT DO I NEED TO ENTER INTO A CONTRACT WITH THE RMR RESOURCE OR IS THERE AN MRA AVAILABLE? UM, AND THEN AT, AT THAT POINT, UH, WE WOULD CHOOSE WHICHEVER IS MOST VIABLE IN TERMS OF MEETING THE RELIABILITY NEED.
THE LAST THING THAT THE PROTOCOLS ALSO REQUIRE IS THAT THERE BE AN EXIT, A TRANSMISSION, UH, EXIT STRATEGY TO THE RELIABILITY ISSUE.
UM, SO THAT WOULD, UH, MOVE ALONG AND THE MRA OR RMR WOULD BRIDGE THE TIME PERIOD UNTIL THAT PROJECT WAS DEVELOPED.
HAPPY TO ANSWER ANY OTHER QUESTIONS.
IT LOOKS LIKE BILL MIGHT HAVE A CARD UP.
AM I UP? IS THAT A YES? WHICH BY THE WAY, WELCOME BACK KAN.
THANK, GLAD TO HEAR THAT YOU'RE, UH, STICKING AROUND THREE.
YOUR CONTRACT, WAS THAT IT? YOU'RE ON RRI THINK THIS IS, YEAH, THIS IS KANS SECOND TO LAST TAC MEETING.
TAC I'VE, FOR EVERYBODY TO, I'VE, I'VE NOT SEEN THE RR DETERMINATION YET FOR CANON'S RETIREMENT NOTICE, SO I DON'T THINK THAT'S
I, I HAVE DECIDED THAT CANAN WILL BE A APRIL 15TH ATTACK AND THEN, THEN WE CAN DISCUSS IT AFTER THAT.
[04:30:01]
I WOULDN'T COUNT ON THAT.THE QUESTION I HAD, WHICH I, I APPRECIATE THE ADVANCED NOTICE, UM, FROM CPS ON THE RETIREMENT, BUT I THOUGHT THE PROTOCOLS REQUIRED THE RM R STUDY BE FOCUSED ON THE NEXT UPCOMING SEASON, WHICH THIS WOULD BE SUMMER OF 25 RISK ASSESSMENT VERSUS SUMMER OF 24.
DOES THAT CHANGE ANY OF THE PROCESS AT ALL OR IS IT YOU STILL PERFORM THE RISK ASSESSMENT TAKING THE RESOURCE OUT OF THE MODEL USING SUMMER 25 CASE AND RUN YOUR, YOUR KIND OF POWER FLOW ANALYSIS AND UNDERSTAND WHERE IF THERE'S ANY TRANSMISSION VIOLATIONS USING THAT MODEL? CORRECT.
THERE'S NO CHANGE IN PROCESS GIVEN THE DATE, UH, TO, TO MY KNOWLEDGE THERE, THERE IS NO CHANGE IN PROCESS THAT WE'RE, WE'RE GONNA START RUNNING THE ANALYSIS.
UM, BUT I, I WOULD WANNA RESERVE THE RIGHT TO GO BACK AND DOUBLE CHECK ON THAT.
'CAUSE YOU'RE ASKING A GOOD QUESTION THAT I, UH, I, I DIDN'T CONTEMPLATE THAT WHEN I WAS REVIEWING EVERYTHING.
AND GIVEN THE SIGNIFICANT LOAD GROWTH THAT WE'RE SEEING, AND PARTICULARLY WHAT'S APPEARING IN THE, UM, TRANSMISSION PLANNING CASES, IT WOULD BE GOOD TO GET A REFRESHER.
AND I'M SURE THAT'LL COME OUT IN THE, UM, INITIAL EVALUATION.
WHAT, WHAT CASE I'M LOOKING AT.
JEFF BILL, NOW THAT HE'S HERE THAT KNOWS THIS STUFF PRETTY WELL IS, UH, WHAT CASES ARE BEING USED AND LOAD FORECAST ASSUMPTIONS AND ALL THAT, I THINK IS SOMETHING WE'RE GONNA BE FOCUSED ON.
OH, YOU, YOU PUT ME ON THE SPOT.
'CAUSE UH, I HAVEN'T DONE THAT JOB IN THREE YEARS SINCE I'VE MOVED THE OPERATION, SO I, I APOLOGIZE.
I DON'T REMEMBER THE DETAILS OFF THE TOP OF MY HEAD.
WE CAN FOLLOW UP AND GET BACK THOUGH.
YEAH, I THINK WE, WE ARE BETTER OFF GOING BACK AND, AND MAKING SURE WE, I HAVE THE RIGHT ANSWER FOR YOU, BILL, SO WE CAN FIGURE OUT A WAY TO COMMUNICATE THAT TO TAC UH, APRIL 15TH MEETING THAT YOU'LL ATTEND.
UM, BUT THE, UH, I, I, I MEAN, UH, SO I UNDERSTAND THE DYNAMICS THAT YOU DESCRIBED, BUT THERE'S GONNA BE DYNAMICS BOTH WAYS, RIGHT? WE HAVE SOME TRANSMISSION, UH, PROJECTS THAT WILL ALSO BE COMPLETED IN THE, IN, IN, IN THAT THOSE ENSUING, UH, YEARS AND POSSIBLY LOAD AND GENERATION LOCATING IN VARIOUS PLACES THAT, THAT MIGHT CHANGE THINGS.
BUT, UM, WE, UH, I MEAN MY EXPECTATION IS WE STUDY IT INITIALLY AND, AND UPDATE THOSE STUDIES IS THE WAY I, I REMEMBER IT, JEFF, BUT, UH, I, I'D LIKE TO GO BACK AND DOUBLE CHECK
ANY OTHER QUESTIONS THERE? OKAY.
I SEE A QUESTION ON 2 45 THAT WILL GO TO THE BOARD.
I AM SURE WE'LL SEE ONE OR MORE SETS OF COMMENTS TO THAT.
UM, BUT THAT WILL BE AT THE APRIL BOARD MEETING.
DOES ANYBODY ELSE WANNA BRING ANYTHING UP? OH, COMBO BALLOT, JEFF?
[14. Combo Ballot (Vote)]
YEAH, GO AHEAD AND DO THE COMBO BALLOT THEN I'LL SURE.WE NEED A MOTION AND A SECOND ON THE COMBO BALLOT MOTION.
COREY, ARE YOU READY? I AM, YES.
SO EVERYTHING WAS UP ON THE SCREEN.
WE ALREADY MOVED AWAY FROM THE FEW, THE FEW NON-CONTENTIOUS ITEMS, WHICH IS JUST 1205 FROM PRS TABLING, NO, 2 55 APPROVING SOME MINUTES AND SOME GOALS FOR SUBCOMMITTEE.
SO ON THAT MOTION, WE WILL START UP WITH THE CONSUMERS WITH NAPA.
ON THE CO-OPS BLAKE, FOR YOUR TWO.
THANK YOU LUCAS FOR JOHN, THANK YOU ONTO OUR INDEPENDENT GENERATORS.
BRIAN, YOU WITH US? YEAH, THERE WE GO.
ONTO OUR IPMS. IAN? YES, FOR ALL THREE.
CO UNLIMITED POWER FOR THIS GUY.
I THINK JAY'S JAY HARPO WITH US ANYMORE ABOUT CHRIS.
KEITH? YES, THANK YOU JIM FOR DAVID? YES.
DAVID FOR RICHARD? YES, THANK YOU.
[04:35:01]
JOSE.ALRIGHT, SO, UH, THE, UH, DRS WORKSHOP.
I APPRECIATE TAC ACCOMMODATING US ON THAT TODAY.
UH, AND, UH, HURRYING TO GET THROUGH THE AGENDA.
UH, SO THE PLAN WOULD BE WE WILL START THAT AT THE TOP OF THE HOUR.
UM, UH, SO QUICK BREAK AFTER TACK AND IF, IF YOU'LL GIVE ME LATITUDE TO GIVE A, UH, PSA ON ECRS.
UH, SO, UH, IF YOU HAD NOTICED, UH, WE POSTED A NEW NPRR TODAY AT 1224 ON THE, UM, THE ECRS TRIGGER THAT WE DISCUSSED AT THE WORKSHOP.
SO FOLLOWING THE WORKSHOP, UH, WE, UH, FELT IT BEST TO CODIFY THAT IN NPRR.
UM, OUR, UH, WE, WE ARE TRYING TO, UH, SEE IF THERE'S A WAY TO GET THAT TO THE APRIL BOARD.
UH, SO JUST ENCOURAGE Y'ALL TO, UH, LOOK AT THAT AND, UM, IF ANN TELLS ME THAT WE CAN DO THAT, SHE MAY NOT, BUT IF SHE TELLS ME WE CAN, THEN WE'RE GONNA TRY TO GET THAT TO APRIL BORN.
THIS GOES AGAINST EVERYTHING YOU'VE BEEN TELLING ME FOR THE LAST WEEK.
I, I THINK, I THINK WE CAN ACCOMMODATE IF WE, IF IT'S A APRIL TI THINK THAT WORKS, RIGHT? BUT, UH, DEFER TO ANN AND COREY.
YEAH, WE'VE, UH, DISCUSSED SOME WITH LEGAL AND WE'RE GONNA SEE WHAT, HOW WE CAN MAKE IT WORK.
BUT, UM, IT WOULD STILL NEED TO GET URGENT STATUS UP HERE RS AND GET APPROVED THERE.
JEFF, IS THIS THE SCED UNDER JEN CONCEPT THAT WAS PREVIEWED AT THE ECRS WORKSHOP, OR IS THIS SOMETHING DIFFERENT? YES.
ARE YOU GONNA PREVIEW IT AT ANY WORKING GROUPS SUBCOMMITTEES? YEP.
WE'LL BE AT WMS AND ROS NEXT WEEK.
ANY OTHER, OTHER BUSINESS? ALL RIGHT.
I DO WANNA THANK EVERYBODY FOR, UM, ALL THE TIME AND HARD WORK THEY, THEY SPENT TODAY, ESPECIALLY ON THE, THE NO, 2 45.