[00:00:03]
OKAY, I THINK WE ARE READY TO GO AHEAD AND GET STARTED.
[1. Antitrust Admonition]
THE ANTITRUST IS ON THE SCREEN.UH, TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY, PARTICIPANTS IN
AND THERE IS MORE INFORMATION ON THE WEBSITE.
[2. Agenda Review and Workshop Goals]
CAN WE GO BACK TO THE KIND OF AGENDA PAGE? PERFECT.UM, SO THANK YOU FIRST, FIRST OF ALL FOR EVERYBODY'S HARD WORK ON THIS.
NO G AND WE HAD SOME OFFLINE DISCUSSIONS IN DEVELOPING THIS AGENDA.
WE HAVE SOME GREAT ROBUST PRESENTATIONS.
SO, SO THANKS EVERYBODY FOR THE HARD WORK ALREADY.
UM, THE, THE QUICK AGENDA REVIEW IS, UH, AFTER I SPEAK, COLIN IS GOING TO DO A KIND OF TACK BACKGROUND ON THE, THE PROCEDURAL HISTORY AND THE BOARD DIRECTION THAT WE HAVE IN FRONT OF US.
UM, THEN WE ARE GONNA DO SOME MORE EDUCATIONAL AND INTRODUCTORY PRESENTATIONS.
UH, TRE WILL PRESENT AND JULIA FROM THE INVERTER BASED WORKING GROUP.
UM, AND THEN ERCOT WILL PRESENT AN ANALYSIS OF THE IBR NUMBERS THAT THEY HAVE SPOKEN TO VERBALLY IN THE PAST.
I THINK THERE'S A BREAKDOWN BY TECHNOLOGY TYPE, AND THEN ERCOT WILL CONTINUE TO PRESENT ON THE TECH APPROVED NOER AS WELL AS, UH, MAYBE THE MARKET.
NOTICE THAT, THAT WE GOT MAY 1ST WE WILL TAKE A BREAK AT SOME POINT FOR LUNCH, A 30 MINUTE BREAK, I THINK, AND, AND JUST EAT HERE AND, AND COME BACK AND CONTINUE A WORKING LUNCH IF NECESSARY.
AND THEN WE WILL GO TO THE JOINT COMMENTERS PRESENTATION AND THEN SPECIFICALLY KIND OF DO A DEEPER DIVE ON THE DEFENSE IN DEPTH APPROACH.
UM, SO THE, THE BROADER GOAL FOR THIS IS REALLY TO GET THE DISCUSSION MORE OUT INTO THE OPEN FOR ALL TAC MEMBERS.
WE, WE HAD A LOT OF KIND OF BEHIND THE SCENES DISCUSSION BETWEEN JOINT COMMENTERS AND ERCOT BEFORE, WHICH WAS GOOD AND PRODUCTIVE.
BUT AS WE KIND OF RE-LOOK AT THIS ISSUE, WE WANNA MAKE SURE ALL THE TAC MEMBERS HAVE ALL THE INFORMATION THEY NEED.
WE DO HAVE ANOTHER TAC IN LESS THAN TWO WEEKS, AND, AND WE DESIGNATED THE AFTERNOON PORTION OF THAT TO TALK ABOUT THIS, AND THEN EVEN ANOTHER ADDITIONAL TECH MEETING FOR THE SNOW GROUP BEFORE THE BOARD IF NECESSARY.
UM, AS FAR AS GOALS, I THINK WE WANT TO HOPEFULLY, IF THERE ARE CONCEPTS WHERE WE HAVE AGREEMENT, MAKE SURE THAT THAT THAT AGREEMENT IS CLEAR TO EVERYBODY.
AND THEN I THINK THE FOCUS IS REALLY MORE ON CONCEPTS, YOU KNOW, EDUCATION, MAKING SURE EVERYBODY UNDERSTANDS IMPLICATIONS OF THINGS, UM, BEFORE WE REALLY DEBATE WORDS OR, OR QUESTIONS MORE, MORE, UM, SPECIFICALLY.
AND THEN AT THE END, I DO WANNA MAKE SURE WE DEFINE OUR, OUR NEXT STEPS FOR THOSE NEXT MEETINGS, UM, AS WELL.
[3. TAC Background - Procedural History and Board Direction]
WITH THAT, I WILL TURN IT OVER TO COLIN.GOOD MORNING AND HAPPY FRIDAY.
SO I'M GONNA KEEP THIS, TRY TO KEEP THIS BRIEF.
UH, THIS WILL BE KIND OF A RECAP IF ANYBODY WAS AT OR LISTENING TO SOME OF THE R AND M MEETING.
UH, AND THEN, YOU KNOW, ERCOT DID A GOOD JOB OF OUTLINING A LOT OF THE FEEDBACK FROM R AND M AND THE BOARD AND, AND THEIR SLIDES.
SO I'LL, I'LL KEEP MY PIECE OF THIS PRETTY BRIEF.
UM, SO IN NOGA 2 45, THE FIRST TIME TACK HEARD ABOUT IT, KIND OF UNOFFICIALLY WAS IN AUGUST.
UH, NOT HEARD ABOUT IT, BUT CAME KIND OF FROM A CONTEXT OF IT COMING TO US NEXT.
UM, ROSS LEADERSHIP PRESENTED THE HIGHLIGHTS IN NOGA 2 45 IN AUGUST OF 2023, AND NOTED THAT THEY'D BE VOTING ON IT IN SEPTEMBER.
UH, AND, YOU KNOW, BASED ON THAT MANY TAC MEMBERS PARTICIPATED IN THE SEPTEMBER ROSS MEETING, YOU KNOW, ANTICIPATING THAT THIS WOULD BE COMING UP TO TAC UH, PRETTY SOON, UH, IN SEPTEMBER, UH, WE, WE HAD OUR INITIAL TAC DISCUSSION ON NORE 2 45.
UH, AT THAT MEETING, ERCOT REQUESTED TABLING OF THE NORE TO ALLOW TIME TO COLLECT ADDITIONAL DATA AND KIND OF WALK THROUGH THE, THE PROCESS THEY ENVISIONED ON AN RFI TO OEMS AND RESOURCE ENTITIES, UH, TO KIND OF GET A BETTER, UH, DEPTH OF UNDERSTANDING ON CAPABILITIES AND, AND THE DIFFERENT CONTEXT THERE.
AND, YOU KNOW, BASED ON THE TIMING OF THAT CIRCLE BACK TO TAC IN DECEMBER.
UH, DURING THAT SEPTEMBER MEETING, UH, WE DISCUSSED TAC DISCUSSED BIFURCATING THE TOPIC TO POTENTIALLY SPLIT THE ISSUE BETWEEN EXISTING AND NEW FACILITIES.
YOU KNOW, GIVEN THE EXPECTED TIMELINE FOR THE RFI AND THE NEED TO GATHER MORE FACTS, AND, YOU KNOW, THE REAL EXPECTATION THAT IT'S GONNA TAKE A COUPLE MORE MEETINGS AND, AND MONTHS TO, YOU KNOW, WORK THROUGH A COUPLE OF TURNS IN THE, IN THE LANGUAGE.
AND AT THAT TIME, THERE WAS, UH, ERCOT HAD SOME OPPOSITION TO, TO BIFURCATING THE TOPIC IN OCTOBER, UH, THE NOTE TO REMAIN TABLED PENDING RESULTS OF THE RFI.
AND THERE WAS CONTINUED DISCUSSION OF THE, THE URGENCY ON THE TOPIC AND THE NEED TO, UH, RESOLVE THIS IN DECEMBER AND HOPEFULLY GET IT TO THE DECEMBER BOARD MEETINGS.
AT THE DECEMBER ATTACK MEETING, WE REVIEWED THE RESULTS OF THE RFI AND HAD A PRETTY ROBUST DISCUSSION.
THE RFI RESULTS HIGHLIGHTED THE NEED TO CONSIDER, UH, FIGURE OUT THE RIGHT WAY TO CONSIDER CERTAIN EXCEPTIONS BASED ON TECHNICAL LIMITATIONS AND REQUIREMENTS THAT WERE IN
[00:05:01]
PLACE AT THE TIME OF THE INTERCONNECTION.AND THIS STARTED TO DRIVE THE DISCUSSION ON WHAT, WHAT IS MEANT BY UPGRADES.
YOU KNOW, SOME DISCUSSIONS ON SOFTWARE AND PARAMETERS VERSUS HARDWARE UPGRADES AND YOU KNOW, WHO, WHO, WHO HAS, WHO IS THE KEY DECISION MAKER ON DECIDING WHAT IS REASONABLE.
UM, AT THE SIMILAR TAP MEETING, IT REMAINED TABLED IN ANTICIPATION OF ADDITIONAL COMMENTS AND REVISIONS THAT WOULD COME IN.
PRIOR TO THE JANUARY MEETING FROM ERCOT AND OTHER MARKET PARTICIPANTS.
AT THE JANUARY ATTACK MEETING, WE DISCUSSED, UH, A NEW VERSION OF ERCOT COMMENTS AND JOINT COMMENTER COMMENTS THAT WERE FILED IN RESPONSE TO THE RFI RESULTS AND THE DISCUSSIONS WE HAD AT THE DECEMBER ATTACK MEETING.
UH, AT, AT THAT MEETING, IT APPEARED, UH, THAT WE COULD HAVE THE POSSIBILITY OF, YOU KNOW, ALIGNING MORE BETWEEN ERCOT AND THE JOINT COMMENTERS WITH A LITTLE MORE TIME OR, OR AT LEAST GETTING TO A POINT WHERE HE HAD MORE CONSISTENT LANGUAGE AND DELINEATING THE, THE CORE DIFFERENCES BETWEEN THE TWO PROPOSALS.
SO, TAC ASKED ERCOT AND JOINT COMMENTERS TO COLLABORATE AND MOVE FORWARD IN THAT DIRECTION, AND REQUESTED THAT WE HAVE COMMENTS FILED A WEEK IN ADVANCE TO THE NEXT MEETING SO THAT ALL TAC MEMBERS WOULD'VE TIME TO DIGEST THAT AND BE PREPARED FOR DISCUSSION.
UH, AT THE JANUARY TAC MEETING, WE, WE SPECIFICALLY RESCHEDULED THE FEBRUARY TAC MEETING IN ANTICIPATION OF, OF GETTING THOSE, UH, YOU KNOW, NEW COMMENTS AND HOPEFULLY A GOOD PATH FORWARD THERE.
GOING TO THE FEBRUARY ATTACK MEETING, ERCOT PROVIDED A, A POSITIVE REPORT THAT THE DISCUSSIONS BETWEEN ERCOT AND JOINT COMMENTERS WERE, WERE GENERALLY POSITIVE AND MAKING PROGRESS, BUT THEY HADN'T YET REACHED CONSENSUS.
UH, AND ERCOT REQUESTED THAT NOGA REMAIN TABLED SO THEY CAN CONTINUE TO WORK WITH THE JOINT COMMENTERS ON GETTING TO A, TO A COMMON SPOT THERE.
UH, IT TAKES US TO, TO MARCH, AND I WON'T GO THROUGH ALL OF THE, THE, THE DETAILS AT MARCH.
EVERYBODY WAS THERE, AND THAT'S PRETTY, SHOULD BE PRETTY FRESH IN OUR MEMORIES.
UH, BUT WE HAD, YOU KNOW, TWO, TWO COMMENTS, TWO VERSIONS OF NOGA 2 45 IN FRONT OF US.
UH, THEY WERE VERY DIFFERENT FROM A LANGUAGE PERSPECTIVE.
AND AT THE MEETING IN MARCH, IT JUST BASED ON THE DIFFERENT STARTING POINTS, IT WAS DIFFICULT TO REALLY DRILL IN AND TWEAK INDIVIDUAL ISSUES, UH, BASED ON THE SIGNIFICANT GAP FROM THE, FROM A STARTING POINT STANDPOINT.
AND IN MARCH, WE HAD THREE VOTES ON THREE DIFFERENT VERSIONS OF THE NORE AND THE THIRD VOTE, UH, NARROWLY PASSED THE JOINT COMMENTERS VERSION WITH SOME SOME MINOR TWEAKS.
SO, GOING TO THE, THE BOARD DISCUSSION, UH, THERE WAS, THERE WAS A LOT OF GOOD DISCUSSION AT THE R AND M COMMITTEE, UH, WENT FOR ABOUT AN HOUR AND A HALF ON, ON THE DISCUSSION THERE.
UH, I'LL TOUCH ON ERCOT THREE PRIMARY CONCERNS THAT THEY NOTED, AND I'LL USE THEIR WORDS.
AND I KNOW IN THEIR, THEIR SLIDES THEY HAD POSTED THIS MORNING, THEY GO INTO QUITE A BIT MORE DETAIL ON THE, ON THE THREE PRIMARY CONCERNS AND, AND, AND OTHER CONCERNS AS WELL.
UH, THE THREE ITEMS ERCOT NOTED WERE THAT ANY, ANY ASSESSMENT OF EXEMPTIONS, EXTENSIONS, OR FUTURE UPGRADES MUST CONSIDER BROADER IMPACTS ON SYSTEM RELIABILITY AS WELL AS COMMERCIAL CONSIDERATION FOR, FOR RESOURCE OWNERS.
UH, THE SECOND ONE, WE, WE CANNOT AVOID RIDE THROUGH REQUIREMENTS BY REPEATEDLY REQUESTING EXEMPTIONS AFTER A RESOURCE FAILS TO PERFORM TO APPLICABLE REQUIREMENTS.
AND THE THIRD IS KIND OF FOCUSED ON THE, THE NEW IVRS AND THE, AND THE, YOU KNOW, THE WATER UNDER THE BRIDGE BETWEEN JUNE 23 AND JUNE OF 24.
UH, THE 20 TO 30 GIGAWATTS THAT ERCOT IS QUOTED WITH SGIS AFTER JUNE OF 2023, UH, SHOULD BE REQUIRED TO MEET IEE 2,800 AND NOT LIMIT THEIR PERFORMANCE TO WHAT'S REQUIRED IN THEIR LEGACY REQUIREMENTS.
SO THOSE WERE THE, THE KEY THREE PRIMARY CONCERNS THAT ERCOT HAD NOTED.
UH, ERCOT RECOMMENDATION TO R AND M WAS TO REMAND NOGA 2 45 BACK TO TAG WITH INSTRUCTIONS TO EITHER MODIFY, UH, THE LANGUAGE IN NOGA 2 45 TO ADDRESS THE RELIABILITY RISKS IDENTIFIED BY ERCOT.
OR ALTERNATIVELY, EXPLAIN IN DETAIL HOW ERCOT CONCERNS ARE ALREADY ADDRESSED WITH THE EXISTING LANGUAGE AT R AND M.
UH, I'LL JUST CHERRY PICK A FEW, FEW COMMENTS FROM THE DISCUSSION FROM, FROM BOARD MISSION BOARD MEMBERS AND COMMISSIONERS, UH, THE KIND OF THE DIRECTION THAT R AND M GAVE.
THEY, THEY WANT TO MODIFY THE LANGUAGE IN NOGA 2 45 TO MORE DIRECTLY ADDRESS THE RELIABILITY RISKS.
UH, THERE'S A DESIRE TO SEE, UH, I THINK THE TERM THAT, THAT THE CHAIR OF R AND M USED WAS LESS DAYLIGHT BETWEEN THE TWO VERSIONS BETWEEN ERCOT VERSION AND THE JOINT COMMANDERS VERSION.
UH, THEY WANNA MAKE SURE THAT, THAT FROM AN ECONOMIC STANDPOINT, THAT WE ARE BEING COGNIZANT AND ADDRESSING THE RELIABILITY RISK SIDE OF THAT EQUATION.
UH, SO WE'VE TALKED A LOT ABOUT THE COMMERCIAL SIDE OF THIS FROM A, FROM A RESOURCE STANDPOINT.
UH, BUT THERE'S QUESTIONS ON WHAT IS THE, YOU KNOW, THE DOLLAR RISK FROM A ERCOT SYSTEM STANDPOINT, IF THERE IS A RELIABILITY EVENT, YOU KNOW, TIED TO THESE, UH, WRITE THROUGH CONCERNS.
UH, RM SPECIFICALLY STATED THAT THEY NEED TO HAVE, HAVE THIS BE BIASED MORE TOWARDS RELIABILITY.
UM, AND ANOTHER SPECIFIC COMMENT THAT WAS MENTIONED WAS ALLOWING AN ENTITY TO GIVE ITSELF AUTOMATIC EXEMPTIONS WITHOUT LIMITATION DOES NOT MEET THE STANDARD OF AN INDEPENDENT ASSESSMENT OF RELIABILITY IMPACT.
[00:10:02]
SO THOSE ARE JUST A COUPLE OF THE CHERRY PICKED COMMENTS FROM THE DISCUSSION.UH, UH, MOVING TO THE ACTUAL BOARD, UH, DIRECTION, UH, THE FOLLOWING DAY, THE BOARD REMANDED OVER 2 45 ATTACK WITH INSTRUCTION TO PROVIDE A MORE DETAILED SET OF COMMENTS ON WHATEVER COMES BACK TO THE BOARD IN JUNE.
UH, ATTACK SHOULD EXPLAIN POLICY RATIONALE ON WHY IT DID OR DID NOT ADDRESS ERCOT KEY CONCERNS FROM THE R AND M PRESENTATION.
AND ADDITIONALLY, IT WOULD LIKE TAC TO ADDRESS ERCOT MORE MINOR OR MODERATE CONCERNS AS WELL.
UH, THEY CLOSED BY NOTING THIS IS A CRITICAL RELIABILITY FOR ERCOT AND THEY EXPECT TO SEE BACK AT THE, EXPECT TO SEE IT BACK AT THE BOARD IN JUNE.
KAITLYN, ANYTHING YOU'D LIKE TO ADD? NO, I THINK YOU DID A GOOD JOB OF COVERING IT AND WE DON'T HAVE A QUEUE, WHICH IS PROBABLY GOOD.
[4. NERC Disturbance Event Reports, NERC IBR Alerts, NERC Standards Workplan for FERC901AOrder]
ALRIGHT.UM, TREI, I DON'T KNOW IF MARK OR OR JOE WAS JOSEPH STARTING? YEAH, GO, GO AHEAD.
UH, MY NAME IS JOSEPH YOUNGER.
I'M THE, UH, VICE PRESIDENT AND CHIEF OPERATING OFFICER AT TEXAS.
RE, UH, WITH ME IS, UH, MARK HENRY, WHO'S OUR CHIEF ENGINEER AND DIRECTOR OF RELIABILITY SERVICES.
AND ALSO WITH US IS DAVID PENNEY, WHO'S OUR I WHO MARK IS OUR CHIEF ENGINEER AND DIRECTOR OF RELIABILITY OUTREACH.
DAVID PENNEY IS OUR DIRECTOR OF RELIABILITY SERVICES.
UH, SO WE'VE BEEN ASKED BY, UH, TECH LEAD LEADERSHIP AND IS, IS CAITLIN MENTIONED AT THE OUTSET JUST TO COME AND SET SOME OF THE CONTEXT, UH, BASED ON THE EVENTS THAT WE'VE SEEN IN THE PAST, AND WE'VE ANALYZED AND PROVIDED REPORTS AND RECOMMENDATIONS ON, AS WELL AS, UH, SOME OF THE DATA THAT WE'VE COLLECTED THROUGH OUR DATA COLLECTION PROCESSES AND WHAT'S GOING ON, UH, ELSEWHERE IN THE COUNTRY IN TERMS OF EVENT ANALYSIS AND GIVE SOME INFORMATION, UH, TO FRAME THE DISCUSSIONS.
THE OTHER ASK WAS FOR US TO, UH, SPEAK A LITTLE BIT ABOUT WHAT'S HAPPENING AT THE FEDERAL LEVEL, UH, BOTH IN THE IMPLEMENTATION OF FERC ORDER 9 0 1 AND THE VARIOUS STANDARDS PROJECTS THAT ARE IN THE NERC WORK PLAN.
UH, SO MARK'S GONNA TOUCH ON THE EVENT ANALYSIS AND DATA FOR A LITTLE BIT, AND THEN I'LL JUST COME BACK UP AND TALK BRIEFLY ABOUT FERC ORDER 9 0 1 AND, UH, NERC WORK PLAN.
IT'S A GREAT PLEASURE FOR US TO BE HERE.
WE DON'T COME TOO OFTEN AND, UH, WE APPRECIATE ALL THE WORK THAT'S BEEN GOING ON WITH THIS SUBJECT.
UM, WHAT I WANNA DO IS REALLY JUST, AGAIN, GET SOME BACKGROUND.
IT'S GONNA BE FAMILIAR TO A LOT OF YOU, UH, SO HOPEFULLY, UH, IT'LL JUST HELP SET US AND NAVY Y'ALL TO MOVE INTO THE MORE MEATY PART OF THIS.
BUT THE FIRST THING I WANNA TALK ABOUT IS THAT THE ISSUES THAT WE ARE COUNTERING HERE HAVE TO DO WITH NOT REALLY SOLAR OR BATTERY STORAGE.
THEY'RE NOT THE, THE OPERATIONAL TIME ARISING QUESTIONS.
THEY'RE NOT THE LONG TERM PLANNING QUESTIONS.
IT, IT HAS SOME RELATION, IT'S STUFF THAT HAPPENS SO FAST THAT AN OPERATOR CAN'T DO ANYTHING ABOUT IT.
UH, THOSE OF YOU WHO ARE PLANNERS, THIS IS TRANSIENT SUB TRANSIENT TIMEFRAME.
UH, AND THAT WE'RE, WE'RE REALLY LIMITED IN WHAT WE CAN DO, UH, IF THESE SORT OF PROBLEMS DEVELOP AND, AND GET FURTHER INTO THE SYSTEM.
SO THERE HAVE BEEN A BUNCH OF REPORTS THAT CAME OUT STARTING IN 2017.
UH, IT ALL STARTED IN CALIFORNIA.
UM, AND THERE WAS SOME WORK AT THAT TIME, BUT IT DIDN'T, IT DIDN'T TAKE OFF.
IT WAS A FEW YEARS, BUT THESE THINGS SHOWED UP IN TEXAS.
UH, AND, UH, I'LL GO INTO THAT A LITTLE BIT MORE.
THESE THINGS ARE STILL SHOWING UP.
NERC RIGHTS REPORTS ON A FEW OF THESE.
UH, THERE ARE A NUMBER OF OTHER ONES.
THERE'S A COUPLE OF NEW ONES THAT ARE, ARE BEING WORKED ON.
UH, IT'S THE SAME SORT OF THING THAT APPEARS TO BE SHOWING UP ACROSS MOST OF THESE REPORTS.
IT'S NOT TO SAY THAT THERE HASN'T BEEN A LOT OF WORK AND PROGRESS WITH UNDERSTANDING THE ISSUES, BUT THESE THINGS ARE STILL OUT THERE AND THEY'RE ACROSS THE SYSTEM.
UH, AND, UM, WELL, WE HAVE THREE OF THE REPORTS, UH, IN THE SPACE OF A LITTLE OVER A YEAR.
WE HAD A DISTURBANCE IN ODESSA, UH, LOST ABOUT A GIGAWATT OF INVERTER BASED RESOURCES.
AND THE THING ABOUT THIS IS THAT YOU DON'T EXPECT THIS.
THE AMOUNT OF MEGAWATTS IS NOT SO MUCH A CONCERN.
THESE PLANTS ARE DISPERSED AS WE'LL SEE ON ANOTHER SLIDE.
AND THIS IS OCCURRING AT MULTIPLE SITES.
UH, IF WE LOSE A LARGE PLANT AND WE DID LOSE A PLANT, A GAS FIRED PLANT AT ODESSA AND BOTH OF THE ODESSA EVENTS, UM, THE IMPACT ON THAT PLANT IS SOMETHING THAT WE PLAN FOR AND EXPECT.
WE DON'T NECESSARILY EXPECT TO, TO SEE A GROUP OF PLANTS IN A GEOGRAPHIC AREA SEPARATE ACROSS MULTIPLE VENDORS TO HAVE SOME SORT OF ISSUE WITH RIDING THROUGH A DISTURBANCE.
[00:15:01]
WIND DISTURBANCE, UH, AGAIN, MOSTLY INVOLVE WIND TURBINES.Y'ALL HAVE BEEN DISCUSSING THOSE SORTS OF THINGS IN SOME DETAIL.
SO I FOCUS ON THE, THE ODESSA TWO EVENT, WHICH IS THE LAST ONE NER WROTE TO REPORT ON.
AGAIN, THERE'S A SITUATION IN PRETTY MUCH ALL THESE EVENTS IS WE HAVE A TRANSMISSION FAULT AND WE DON'T EXPECT TO SEE A LOT OF RESOURCES, JUST LIKE WE DON'T EXPECT TO SEE ADDITIONAL TRANSMISSION BECOME AFFECTED BY THIS OTHER THAN AIDING IN THE RECOVERY.
AND THIS EVENT WAS THE FIRST OF WHAT NERC CALLS A CATEGORY THREE OR THREE A EVENT IN, IN QUITE SOME TIME.
UH, THAT'S NOT AN IMPORTANT THING TO KEEP IN MIND.
IT JUST, IT KIND OF RAISED THE LEVEL.
THIS WAS THE, THE EVENT THAT HAD HAD THE LARGEST MEGAWATT IMPACT OF ANY OF THE NERC EVENTS THAT HAD BEEN FOLLOWED UP ON.
NOW AGAIN, SOME OF THE PROBLEMS WERE, UH, THEY WERE SYNCHRONOUS GENERATORS.
UH, THE PLANT THAT WAS FURTHEST AWAY WAS IN THE VALLEY.
THESE THINGS WILL HAPPEN FROM TIME TO TIME.
YOU CAN LOOK THROUGH OUR HISTORY OF DOING EVENT ANALYSIS, AND IT'S USUALLY SOMETHING OUT OF THE ORDINARY THAT ENDS UP WITH US WRITING A REPORT.
BUT WHAT STANDS OUT IS THAT WE HAD OVER 1700 MEGAWATTS OF SOLAR INVERTER BASED RESOURCES THAT CHANGED THEIR OUTPUT, UH, DIDN'T PROVIDE POWER INTO THE GRID AND DIDN'T HELP SUPPORT THE RECOVERY.
WE, WE HAVE THE RESERVES, THE CAPABILITY, THE TOOLS IN THAT OPERATIONAL TIME HORIZON TO ADDRESS THESE.
BUT YOU'LL NOTE AT THIS PERIOD OF TIME, WE HAD, UH, NOT QUITE NINE GIGAWATTS OF INSTALLED SOLAR CAPACITY.
WHERE ARE WE AT TODAY? WHERE ARE WE AT TODAY? UM, THERE WAS SOME OTHER THAT'S ALSO IN TRANSITION.
SO WE, WE'VE DOUBLED THIS AND I DON'T KNOW THAT WE HAVE THE CERTAINTY ABOUT HOW THESE ADDITIONAL RESOURCES ARE GONNA PERFORM.
UH, I WON'T GO INTO THESE CAUSES.
I THINK THOSE OF YOU WHO'VE BEEN IN THE IBR DISCUSSIONS AND JULIE WILL PROBABLY COVER A LITTLE BIT MORE OF THOSE TOO.
THERE'S A VARIETY OF THINGS THAT SHOWED UP.
AND FROM THE FIRST EVENT, ODESSA TO THE SECOND, WE SAW SOME OF THE SAME THINGS OCCUR.
WE SAW SOME, I'LL CALL 'EM, LAYERING OF THE ONION PROBLEMS AS SOMETHING THAT WE TRIED TO FIX IN THE FIRST EVENT, UH, LED TO SOMETHING ELSE REVEALING ITSELF AS AN ISSUE.
SO THERE AREN'T, I THINK, THE CLEAR GUIDANCE THAT THE INDUSTRY NEEDS YET, UH, TO HELP ADDRESS THESE.
AND CERTAINLY THE EXPERIENCE WE GAIN HERE IS ESSENTIAL.
UH, THESE, THIS IS NEW TECHNOLOGY FOR US GENERALLY IN OPERATING THE GRID.
SO WE, WE ARE NOT NECESSARILY SURPRISED BY SOME ISSUES, BUT WE WANT TO ADDRESS THEM.
AND YOU ALL ARE DOING TREMENDOUS WORK IN TEARING THROUGH THIS.
SO THE RECOMMENDATIONS AND NERC ALWAYS INCLUDES RECOMMENDATIONS IN THEIR DISTURBANCE REPORTS.
UM, THEY TALK ABOUT THE NEED FOR RELIABILITY STANDARDS.
JOSEPH WILL TALK A LITTLE BIT MORE ABOUT WHAT NERC HAS HAD GOING ON.
BUT IT'S A SLOW PROCESS AND, UH, IT IT TAKES A LOT OF EFFORT AND IT DOESN'T NECESSARILY SPEAK TO US IN OUR SITUATION WHERE WE ARE TODAY.
NERC ALSO IS GONNA GATHER SOME MORE DATA.
I'LL TOUCH ON THAT, SOMETHING WE CALL A NERC ALERT.
UM, BUT AS, AS A GENERAL RECOMMENDATION, NERC POINTED OUT THAT THE INDUSTRY NEEDS TO WORK TOGETHER ON A VARIETY OF TOPICS.
WHEN WE TALK ABOUT NOER 2 45, WE ALSO HAVE A NEED FOR DATA.
UM, UH, THERE'S A VARIETY OF GUIDELINES.
I I DON'T EVEN HAVE A GOOD COUNT OF HOW MANY GUIDELINES THAT NERC HAS WRITTEN TO TRY AND ADVISE THE INDUSTRY.
AND THESE GUIDELINES ARE NOT, UM, THEY'RE NOT NERC STAFF SITTING IN A CORNER WRITING SOMETHING UP WITH, UH, REGULATORS.
UH, YOU ALL PEOPLE FROM YOUR COMPANIES THAT HAVE GOTTEN TOGETHER WITH NERC, UH, ON AN IBR PERFORMANCE GROUP THERE.
UH, AND THE EFFORT HAS BEEN TO TRY AND PROVIDE GUIDANCE WE HAVEN'T SEEN AS EVEN AN APPLICATION, BUT CERTAINLY IT'S A COMPLEX ISSUE AND IT'S CHALLENGING.
UH, THE REPORT ENDED WITH SPECIFIC RECOMMENDATIONS FOR ERCOT.
AND I THINK, YOU KNOW, WHAT, WHAT WE'RE DOING HERE TODAY IS REALLY, UH, A BIG PART OF THAT.
THERE ARE, AGAIN, OTHER ASPECTS OF INTEGRATING IBR FULLY AND RESOLVING HOW THEY FIT INTO OPERATIONS.
UH, TODAY WE'RE TALKING ABOUT PERFORMANCE.
UM, THERE'S BEEN QUITE A BIT OF FOLLOW UP.
THERE'S ADDITIONAL WORK THAT WE'RE NOT GONNA BE TOUCHING ON TODAY DIRECTLY, BUT IT, IT ALL IS RELATED.
IT'S GONNA TAKE A LOT TO DO THIS TRANSITION.
AND, UH, AGAIN, WE'RE VERY PLEASED TO SEE THE EFFORTS IN COOPERATING AND WORKING THROUGH THESE THINGS.
SO OUTSIDE OF OUR REGION, IN THE MEANTIME, SINCE ODESSA, THERE'VE BEEN A COUPLE OTHER REPORTS WRITTEN.
UM, ONE WAS IN UTAH, SO IT'S NOW IT'S NOT CALIFORNIA OR TEXAS AND ISO, THIS WAS PACIFIC CORE.
AND THEY HAD, AGAIN, A LAR, A SIGNIFICANT NUMBER OF DISPERSED UNITS IN RESPONSE TO TRANSMISSION FAULT.
UH, HAD SOME OF THE SAME PERFORMANCE ISSUES THAT WE'VE BEEN TALKING ABOUT WITH THESE OTHERS.
UH, UNDERNEATH IT ALL, THERE'S AGAIN, A CHALLENGE STARTS WITH HOW YOU COMMISSION,
[00:20:01]
UH, WHAT KIND OF MODELS YOU HAVE.BUT WHEN YOU GET DOWN TO IT, IT'S A PERFORMANCE ISSUE THAT REVEALS THE NEED FOR WORK HERE.
UM, THERE ARE SOME THINGS ABOUT DATA, BUT WE'RE NOT GONNA TALK SO MUCH ABOUT THAT.
UNDERNEATH ALL THIS THOUGH, THESE ARE WHAT NERC REFERRED TO AS LATENT RISKS THAT THREATEN BULK POWER SYSTEM RELIABILITY OF CALIFORNIA EVENTS.
UM, WHAT I POINT OUT ABOUT THEM IS THAT THEY INVOLVE BATTERY INVERTERS, WHICH WE HAD NOT ANTICIPATED.
UH, SO WE GENERALLY CONSIDER NERC CHANGE THEIR IBR DEFINITION RULE BIT.
IT'S ANYTHING AGAINST POWER ELECTRONICS, UH, THAT'S TIED TO RESOURCES IS WHAT WE CONSIDER HERE.
AND IT MAY INVOLVE THINGS WE DON'T EVEN HAVE YET.
UH, FUEL CELLS IS ONE OF THE THINGS THAT'S MENTIONED.
UH, DISTRIBUTED ENERGY RESOURCES, AGAIN, THEY HAVE INVERTERS.
THEY HAVE SOME THINGS THAT, UH, ARE BEING APPLIED, UH, TO TRY AND HELP THEM BE BETTER GRID CITIZENS, IF YOU WERE.
BUT, UH, IT'S AN INTER, IT'S AN INDUSTRY IN TRANSITION.
SO I MENTIONED THAT NERC SENT OUT SOMETHING CALLED AN ALERT ABOUT THIS TIME LAST YEAR, OR WELL, MONTH OR TWO BEFORE.
AND AGAIN, IT WAS IN RESPONSE TO ALL THESE EVENTS.
WE'RE TRYING TO UNDERSTAND MORE BEFORE SOMETHING HAPPENS TO GET A GENERAL PICTURE OF, OF WHERE SOME OF OUR INSTALLATIONS ARE AT.
UH, WE LIMITED THE DISCUSSION TO THOSE LARGER FACILITIES THAT ACTUALLY ARE REGISTERED WITH NERC, UH, THAT WE HAVE CONTACT WITH, BUT STILL AMOUNTED OVER 53 GIGAWATTS OF, UH, SOLAR.
AND IT WAS LIMITED TO SOLAR AS WELL.
UH, AT THE TIME, I DON'T THINK THE BATTERY REPORT HAD COME OUT AND, WELL, IT'S, MAYBE IT'S BETTER TO TAKE THINGS OFF IN A MORE DIGESTIBLE CHUNK.
BUT THIS IS, UH, UH, SOMETHING THAT ERUPT PARTICIPATED IN.
WE HAD ALMOST 11 GIGAWATTS THAT PARTICIPATED.
NOW AGAIN, WHERE ARE WE AT NOW? WE'RE IN THE TWENTIES.
SO WE DON'T HAVE ALL THE DATA THAT WAS COLLECTED, UH, FOR, AT THE TIME FOR SOME OF OUR NEWER FACILITIES TO UNDERSTAND EXACTLY WHERE THEY FALL.
BUT I THINK THE TRENDS THAT CAME UP WILL BE, UH, EVIDENT.
SO THE FIRST THING IS, IS, AGAIN, OUR FOCUS LATELY HAS BEEN ON VOLTAGE AND FREQUENCY RIDE THROUGH.
SO THIS CHART, IT LISTS THE MANUFACTURERS IN ERCOT AND, UH, HOW THEY HAD, UH, RESPONDED TO A QUESTION ON THE POINT THAT THEY SELECTED, UH, ON THE RIDE THROUGH CURVES TO HAVE THEIR EQUIPMENT SET UP.
UH, AND GENERALLY, UH, IT'S FOUND THAT THEY HAVE NOT TRIED TO DO THAT TO MEET THE MAXIMUM CAPABILITY OF THAT INVERTER.
IT SEEMS LIKE IT'S MORE BEEN A MATTER OF, UH, THIS RIDE THROUGH CURVE LOOKS LIKE A SET POINT, AND THEY PUT THEIR, UH, POINT OF, OF OPERATION CLOSE TO THAT, IT LOST MARGIN.
THERE ARE SOME THINGS ABOUT THIS THAT, UH, CERTAINLY HAVE TO BE EXPLORED.
THERE ARE LIMITATIONS IN EQUIPMENT, BUT THAT IS THE FINDING HERE, IS THAT IN GENERAL, UH, THESE PIECES OF EQUIPMENT ARE NOT BEING SET UP TO MAXIMIZE THEIR CAPABILITY TO SUPPORT THE GRID, TO CONTINUE TO PROVIDE POWER AND TO HELP PROVIDE THAT INPUT SO WE CAN CLEAR FAULTS IN THE SYSTEM.
AGAIN, I WON'T GO THROUGH THIS.
THIS IS, THIS IS MORE ABOUT SUPPORTING THE SYSTEM.
UH, THE, THE THINGS ARE A LITTLE BETTER LOOKING HERE.
AND THAT, UH, ABOUT TWO THIRDS OF THE INVERTERS WE LOOKED AT WERE PROVIDING REACTIVE AND REACTIVE CURRENT INJECTION.
THERE'S STILL A LARGE NUMBER THAT WEREN'T.
AND AGAIN, AS I MENTIONED, THERE'S A LOT OF RESOURCES THAT WE DID NOT HAVE DATA ON WHEN THIS NERC ALERT WAS COLLECTED.
THE LAST PIECE I'LL THROW OUT IS IT'S A LITTLE DIFFERENT.
THE OTHER TWO WERE SPECIFIC TO ERCOT.
UH, AND BY THE WAY, THE, THE ERCOT NUMBERS WERE ACTUALLY NOT QUITE AS GOOD, UH, AS THE GENERAL AGGREGATED NERC FIGURES.
THEY WERE VERY SIMILAR IN TERMS OF WHAT PERCENT WE'RE PROVIDING.
WHAT WE'LL SAY IS, IS MORE DESIRABLE RESPONSE.
UH, THIS IS JUST A CHART ABOUT, UH, VOLTAGE SUPPORT.
UH, IT'S MORE FOR, UH, WELL STEADY STATE AND DYNAMIC ARE INCLUDED, BUT THIS IS AN ISSUE WITH, UH, HOW MUCH CAPABILITY YOU HAVE.
UH, AND IN THIS CASE, WE'RE FINDING ABOUT A THIRD OF THE UNITS ACROSS NERC, WE'RE LIMITING THEIR REACTIVE SUPPORT TO A CONSTANT POWER FACTOR.
THIS IS AN OLD ISSUE HERE, GOING WAY BACK, UH, WHEN I STARTED EVEN WITH OTHER PLANTS.
BUT, UH, THERE ARE A LOT OF THINGS THAT WE NEED TO UNDERSTAND AND SEE THAT, UH, FOLKS IN THE INDUSTRY ARE, ARE UNDERSTANDING, UH, WHAT THE NEEDS OF THE SYSTEM ARE, HAVE THE EQUIPMENT SET UP TO MAXIMIZE THE SUPPORT THAT IT CAN PROVIDE WITHOUT, UH, PUTTING IT AT RISK OF DAMAGE.
AND NOW I'M GONNA HAND IT OVER TO JOSEPH.
I HOPE NONE OF THIS WAS PARTICULARLY NEW OR SURPRISING TO YOU.
I JUST WANTED TO KIND OF SET THE, THE BACKGROUND ON WHAT WE SAW THAT STARTED THESE THINGS A FEW YEARS BACK.
JOE'S JUST GONNA TAKE UP WHERE NERC IS AT WITH SOME OF THEIR PROJECTS.
CAN WE TAKE A QUICK QUESTION FROM BOB HILTON? YEAH, JUST A REAL QUICK ONE, MARK.
[00:25:01]
UH, COULD YOU GO BACK TO SLIDE, UH, 11 OR 12? I CAN'T REMEMBER.THAT'S, THAT'S WHAT NERC IS FINDING AND WHAT YOU'RE SEEING NOW, OUR REQUIREMENTS IN ERCOT ARE NOT THAT.
SO I JUST WANTED TO CLARIFY THAT WHILE WE'RE LOOKING AT THAT, THAT'S NOT THE REQUIREMENTS HERE.
AND, AND BOB, I THINK THAT'S, THAT'S FAIR.
UH, I DIDN'T GET A BREAKDOWN ON WHAT THE RESPONSES ARE IN OUR CUT, BUT I WILL TELL YOU ON SOME OF THE OTHER SLIDES WE HAD, WE DID FIND SOME UNITS THAT WERE, UH, INSIDE THE RIDE THROUGH CURVE, WHICH WAS, UH, PROBABLY NOT IN ALIGNMENT WITH CURRENT OR CURRENT REQUIREMENTS.
BUT YEAH, THIS IS JUST A, A GENERAL SENSE THAT THE INDUSTRY AS A WHOLE AND, AND YOU ALL, FOR THE MOST PART, YOU REPRESENT A LOT OF DIFFERENT INSTALLATIONS, COMPANIES THAT SUPPLY MAYBE ACROSS THE GLOBE.
UH, SO IT'S JUST AN UNDERSTANDING THAT WE HAVE.
BUT THANK YOU FOR POINTING THAT OUT.
YEAH, SO KIND OF TURNING BACK TO, UM, UH, THE FERC ORDER 9 0 1, AND WE KIND OF MENTIONED THIS AT THE OUTSET.
IN, IN OCTOBER, 1920, UH, OCTOBER 19TH, 2023, UH, FERC ISSUED AN ORDER TO NERC TO DEVELOP NEW OR MODIFIED RELIABILITY STANDARDS, UH, TO ADDRESS RELIABILITY GAPS IN REALLY FOUR KEY AREAS.
UH, THE FIRST IS AROUND DATA SHARING REQUIREMENTS, AND THAT INCLUDES PROVISION OF COMPLETE AND ACCURATE MODELING DATA, UH, MODEL VALIDATION REQUIREMENTS TO ACCURATELY REFLECT, REFLECT IBR BEHAVIOR AND PERMIT PLANTERS AND OPERATORS TO PERFORM VALID INTERCONNECTION STUDIES AMONG OTHER ACTIVITIES.
UH, THE THIRD ELEMENT WAS, UH, REQUIREMENTS FOR PLANNING AND OPERATIONAL STUDIES.
THAT INCLUDES AN EVALUATION OF IBR, UH, AND DISTRIBUTION CONNECTED IBR IN THE AGGREGATE.
AND THEN FINALLY, UH, WHAT WE'RE FOCUSED ON TODAY, UH, PERFORMANCE REQUIREMENTS FOR IBR, INCLUDING DISTURBANCE RIDE THROUGH, UH, REQUIREMENTS AND REQUIREMENTS TO ADDRESS CERTAIN OPERATIONAL CHARACTERISTICS LIKE RAMP RATE INTERACTIONS.
UH, SO THAT WAS THE SCOPE OF THE ORDER.
AND ALL THESE AREAS, UH, REFLECTED RECOMMENDATIONS THAT CAME OUT OF THE EVENT REPORTS, THE 20 21, 20 22 ODESSA REPORTS, AND SOME OF THE OTHER REPORTS THAT, THAT MARK TOUCHED ON.
UH, AND ONE OF THE THEMES THAT CAME OUT OF THE FERC ORDER WAS, UH, FERC WAS REALLY SEEKING TRANSPARENCY FROM, FROM NERC ABOUT HOW NERC PLANS TO IMPLEMENT A HOLISTIC RESPONSE ON SOME OF THE RELIABILITY CHALLENGES THAT WERE COMING OUT OF THE REPORTS AND THAT WE'RE SEEING IN, IN TERMS OF INTEGRATING IIV INTO THE SYSTEM.
SO THE FIRST STEP IN THE ORDER WAS FOR NERC TO SUBMIT A COMPREHENSIVE WORK PLAN TO FERC, UH, OUTLINING HOW ARE WE GONNA DO THESE STEPS? WHAT'S, WHAT'S THE, WHAT'S THE PROCESS LOOK LIKE? SO IN JANUARY, NERC SUBMITTED A WORK PLAN DETAILING FOUR KEY MILESTONES ASSOCIATED WITH THE DATES OF COMPLETION THAT FERC OUTLINED IN THEIR ORDER, THE DIFFERENT TIMELINES THAT THAT FERC SPECIFIED.
AND THE NERC WORK PLAN, UH, CONSISTS OF FOUR MILESTONES.
UH, THE FIRST MILESTONE IS SUBMITTING THE WORK PLAN ITSELF, UH, AND THAT OCCURRED IN JANUARY, AS I MENTIONED.
MILESTONE TWO THEN CONCERNS THE DEVELOPMENT OF RELIABILITY STANDARDS TO ADDRESS PERFORMANCE REQUIREMENTS AND POST-EVENT PERFORMANCE VALIDATIONS.
AND THESE ACTIVITIES HAVE TO BE COMPLETED.
THOSE WOULD BE THE ONES IN LIGHT BLUE UP THERE.
THOSE HAVE TO BE COMPLETED BY NOVEMBER 4TH OF THIS YEAR, 2024, MILESTONE THREE.
UH, THEN LOOKS AT REQUIREMENTS TO ASSURE PERFORMANCE STATUS PROVIDED TO PLANNERS, UH, AND THE ASSOCIATED MODELS ARE VERIFIED.
THAT'S, UH, DUE IN NOVEMBER, NOVEMBER 4TH, 2025.
AND THEN FINALLY, MILESTONE FOUR ADDRESSES PLANNING AND OPERATIONAL STUDIES.
AND THAT WILL BUILD ON THE MILESTONE THREE ACTIVITIES.
AND THAT'S TO ENSURE THAT THOSE OPERATIONAL AND PLANNING STUDIES ACCURATELY, UH, REPRESENT THE, THE, THE, THE REAL OPERATIONAL CHARACTERISTICS OF IBR.
AND THAT'S, UH, DUE NOVEMBER 4TH, 2026.
SO THE LAST STEP, SO AS YOU CAN KIND OF SEE FROM THE SLIDE IN FRONT OF YOU, THE NERC WORK PLAN PROVIDES A, A WHAT I THINK IS KINDA A HELPFUL OVERVIEW ABOUT HOW THE VARIOUS STANDARD DEVELOPMENT PROJECTS THAT ARE CURRENTLY UNDERWAY, UH, FIT INTO THE BROAD ELEMENTS OF THE FERC ORDER AND RELATE TO, UM, HOW THEY'RE GOING TO INTERACT TOGETHER.
AND THIS, THIS PARTICULAR GRAPH, WHICH COMES FROM THE NERC WORK PLAN, KIND OF LOOKS AT IT IN THE CONTEXT OF A DISTURBANCE EVENTS LIKE THE ONE THAT WE'VE SEEN IN THE ODESSA REPORTS.
SO AS YOU CAN SEE FROM THE SLIDE, THERE ARE THREE STANDARD DEVELOPMENTS, PROJECTS THAT ARE PRESENTLY UNDERWAY IN THE MILESTONE TWO ACTIVITIES.
UH, SO FOLLOWING A GRID DISTURBANCE EVENT, THE FIRST, UH, PROJECT, THE FIRST STEP WOULD BE TO FOCUS ON COLLECTING, UH, THE, THE NECESSARY DATA TO ANALYZE THE EVENT ITSELF.
[00:30:01]
20 21 0 4 IS CURRENTLY LOOKING AT REVISIONS TO OUR PRC TWO STANDARD REQUIREMENTS AND CREATING A NEW IBR MONITORING AND REPORTING STANDARD THAT'S PRC 28.AND THAT'S TO ENSURE THAT THE LOCATION REQUIREMENTS AND THE ASSOCIATED PERIODIC ASSESSMENTS, UH, ACCURATELY REFLECT THE DISTINCT IBR MONITORING AND, AND TECHNICAL REQUIREMENTS.
SO IF YOU GO BACK TO THE 2021 ODESSA DISTURBANCE REPORT THAT, THAT MARK MENTIONED, YOU KNOW, WE HIGHLIGHTED IN THAT REPORT THE FACT THAT ERCOT AND THE GENERATORS IN TEXAS, UH, GENERALLY ALREADY HAVE EXTENSIVE HIGH RESOLUTION DATA.
AND, UH, THEY HAVE THE INVERTER LEVEL SEQUENCE OF EVENTS RECORDING AMONG OTHER DATA SOURCES THAT WE WERE ABLE TO LEVERAGE TO DO THE ROOT CAUSE ANALYSIS.
SO THE REPORT ENDED INDICATED THAT THOSE TYPES OF MEASUREMENTS THAT ARE IN PLACE HERE, UH, THAT REALLY SHOULD BE STANDARD ACROSS INDUSTRY, UH, FOR PURPOSES OF EVENT ANALYSIS AND REDUCING THE RISK OF PLANT PERFORMANCE.
UH, AND THEN, UH, Y'ALL HAVE ALREADY TAKEN STEPS THROUGH NOVO 2 55 TO KINDA ENHANCE THOSE MORE.
SO, SO THAT'S A, I THINK, A GOOD EXAMPLE OF SOMETHING THAT Y'ALL, AS THE ERCOT STAKEHOLDERS HAVE IMPLEMENTED HERE AT THE LOCAL LEVEL, THAT'S GETTING PICKED UP NOW ON, ON THE BROADER NATIONAL STAGE AS THESE PROJECTS DEVELOP.
AND IT'S BEEN HIGHLIGHTED IN SOME OF THE REPORTS.
SO, SO THE SECOND, UH, UH, ITEM UP THERE THEN IS THE, UH, NEW POST DISTURBANCE RIDE THROUGH REQUIREMENTS, WHICH IS WHAT WE'RE TALKING ABOUT HERE TODAY.
AND IN, IN THIS PROJECT, THE SDT IS CURRENTLY PROPOSING TO ADDRESS THESE REQUIREMENTS PRIMARILY BY CREATING ANOTHER NEW STANDARD PRC 29.
UH, THAT, AGAIN, WILL FOCUS ON, UH, ON ESTABLISHING CRITERIA FOR FREQUENCY, UH, AND VOLTAGE RIDE THROUGH, AS WELL AS, UH, OTHER PERFORMANCE METRICS LIKE POST DISTURBANCE, RAMP RATES, PHASE LOCK LOOP SYNCHRONIZATION, AND OTHER KNOWN CAUSES OF IVR TRIPPING THAT WE'VE SEEN COMING OUTTA THE REPORTS.
AND THEN, AND THEN FINALLY, PROJECT 20 23 0 2, THE THIRD PROJECT UP THERE THAT FOCUSES ON REQUIRING ANALYSIS AND MITIGATION OF UNEXPECTED OR UNWARRANTED PROTECTION AND CONTROL SYSTEM OPERATION.
SO NOT NECESSARILY LIMITED TO SOMETHING THAT OCCURS FOLLOWING A DISTURBANCE EVENT OR FREQUENCY AND VOLTAGE RIDE THROUGH, BUT, UH, JUST AN ABNORMAL, UH, OPERATING, UH, CHARACTER PERFORMANCE EFFECTIVELY.
AND SO THAT STANDARD IS, AGAIN, PROPOSING ANOTHER NEW STANDARD PRC 30.
SO YOU CAN SEE A TREND 28, 29, AND 30 THAT WOULD ADDRESS THOSE ISSUES.
SO THE VARIOUS, UH, PERFORMANCE AND ANALYSIS REQUIREMENTS CONTEMPLATE GENERATORS IMPLEMENTING, AS YOU CAN SEE AT THE BOTTOM CORRECTIVE ACTION PLANS, IF THEY DON'T MEET THE REQUIREMENTS THAT WOULD COME IN EITHER IN THE, EITHER IN THE FORM OF A CORRECTIVE ACTION PLAN WITHIN THE STANDARD REQUIREMENTS ITSELF, OR A MITIGATION PLAN, IF THERE IS A VIOLATION OF THE STANDARD AND SOMETHING NEEDS TO BE ADDRESSED.
UM, THE PROPOSED RELIABILITY STANDARD REVISIONS, JUST TO GIVE YOU A SENSE OF THE TIMELINE FOR THESE THREE PROJECTS, UH, THEY'RE DUE IN NOVEMBER, SO THAT MEANS THEY NEED TO GO TO THE NERC BOARD IN AT ITS AUGUST MEETING, SO AUGUST 14TH AND 15TH.
SO, GIVEN THE EXPEDITED TIMELINES, NERC HAS REQUESTED WAIVERS OF THE STANDARD, UH, THE, THE TYPICAL STANDARD DEVELOPMENT PROCESS, UH, TO EXPEDITE THOSE.
THEY ALL THREE OF THESE, UH, PROJECTS HAVE PUT THE NEW STANDARDS OUT FOR BALLOT THAT OCCURRED IN APRIL.
UH, SO WHAT WE'RE LOOKING AT NOW OVER THE SUMMER IS MUCH SHORTER, 15 DAY COMMENT PERIODS TO HAMMER THIS OUT, UH, IN ADVANCE OF THE NERC BOARD MEETING IN AUGUST, WHICH IS REALLY THE DROP DEAD DEADLINE FOR GETTING THIS WORK DONE.
SO THERE'S GONNA BE A TREMENDOUS AMOUNT OF RELIABILITY STANDARDS, UH, DEVELOPMENT ACTIVITY AT THE NERC LEVEL GOING ON THIS SUMMER.
UM, AND, UH, DAVID, MARK AND I BE HAPPY TO KEEP EVERYONE POSTED ON THESE DEVELOPMENTS HERE OR AT THE IBR TASK FORCE AS THAT WORKS THROUGH THE PROCESS.
UH, SO IF THAT, I'M HAPPY TO TAKE ANY QUESTIONS YOU MIGHT HAVE FOR ME OR ANYTHING ELSE FOR, FOR MARK AS WELL.
LOOKS LIKE BOB HILTON HAS A QUESTION.
JUST REAL QUICKLY ON THE TIMELINE THAT YOU MENTIONED, YOU MENTIONED THAT ASSOCIATED WITH THE PROJECTS, HOW DOES THAT RELATE TO THE TIMELINES FOR 28, 29 AND 30? DO DO YOU HAVE ANY IDEA ON THAT? SO, UH, IT'S, IT'S A GOOD QUESTION.
SO I, I THINK WHAT YOU'RE TALKING ABOUT IS THE IMPLEMENTATION PLAN.
WHEN ARE THE STANDARDS GONNA BE EFFECTIVE? RIGHT.
SO, UH, SO WE DON'T KNOW, UH, BECAUSE WE DON'T HAVE LANGUAGE IN THE STANDARDS PROJECTS, UH, WHAT THAT THE, THE NOVEMBER 4TH DATE IS THE DATA HAS TO BE FILED AT FERC.
UH, SO WITHIN THE DRAFT STANDARD LANGUAGE THERE, THERE IS, IT'S CONTEMPLATED AND IT'S THE, THE NORM THAT THERE'S USUALLY SOME TYPE OF IMPLEMENTATION PERIOD.
AND THAT CAN RANGE FROM, FROM THE DATE, THE EFFECTIVE DATE OF
[00:35:01]
THE STANDARD ITSELF, WHICH WOULD BE HAPPEN UPON FERC APPROVAL ALL THE WAY TO SEVERAL YEARS AND PHASE IMPLEMENTATIONS, WE DON'T HAVE THAT LANGUAGE.UH, THAT'S, THERE'S NOT, THERE'S NOT ACTIVE LANGUAGE THAT'S OUT THERE.
NOW, THE PRC 29 STANDARD, WHICH AGAIN, I'LL, I'LL SAY THIS CAVEATING, THAT THERE'S A PROPOSAL AND THAT PROPOSAL FAILED.
SO WE DON'T KNOW WHAT THE LANGUAGE IS.
WHAT THE DRAFTING TEAM PROPOSED WAS A 12 MONTH IMPLEMENTATION PERIOD, UH, FROM THE FERC APPROVAL DATE.
SO IT'S THE FIRST DAY, FIRST CALENDAR QUARTER FOLLOWING FERC APPROVAL, 12 MONTHS FROM THAT.
BUT, BUT THAT'S NOT ON THE TABLE.
'CAUSE AGAIN, IT FAILED THE PROCESS.
SO WE'LL HAVE TO SEE WHAT COMES OUT OF IT, BUT THAT'S HOW THAT WOULD WORK.
SO THESE WOULDN'T BECOME ENFORCEABLE EFFECTIVE ON NOVEMBER 4TH, IT'D BE SOME POINT AFTER THAT.
I'M CURIOUS, NED, I SEE WAS WAS IKA IN FIRST GO? GO AHEAD NED, AND THEN WE'LL GO TO IKA IN THE QUEUE.
OH, I CAN, I CAN YIELD IF SHE WAIT.
UH, JOSEPH, CAN YOU JUST EXPLAIN AT A VERY HIGH LEVEL COMPARE COMPARED FOR 9 0 1 STANDARDS VERSUS NUMBER 2, 4 5, WHICH ONE IS MORE STRICT, LESS STRICT? CAN YOU DO ANY COMPARE AND CONTRAST FOR US? THANKS.
I WOULD LOVE TO, BUT AGAIN, I'D SAY WE DON'T HAVE STANDARD LANGUAGE FOR, UH, FOR THE P PRC 29 30 AND, AND 28, THOSE.
SO WE HAVE, THERE ARE PROPOSALS, THOSE PROPOSALS FAILED.
SO THE DRAFTING TEAM IS COMING BACK AND THEY'RE GONNA PUT OUT A NEW PROPOSAL PROBABLY IN THE NEXT COUPLE WEEKS, BUT WE DON'T KNOW WHAT THE, WHAT THE SPECIFIC TEXTS IS.
SO IT WOULD BE, IT WOULD BE SPECULATION ON, ON OUR PART, YOU KNOW, WHAT'S STRICTER AND WHAT'S NOT.
UM, NOW I CAN, YOU KNOW, TALK A LITTLE BIT ABOUT WHAT THE FERC ORDER SAYS, UH, IN, IN SOME AREAS, UH, AND THE FERC ORDER, LIKE ONE OF THE, ONE OF THE ITEMS THAT THE, YOU KNOW, THE FERC ORDER CALLS OUT, IT LOOKS AT, AGAIN, IF WE'RE GONNA TALK ABOUT PERFORMANCE CRITERIA, UH, IT TALKS ABOUT FREQUENCY RIDE THROUGH, IT TALKS ABOUT VOLTAGE RIDE THROUGH THESE OTHER OPERATING CHARACTERISTICS.
THE FERC ORDER CONTEMPLATES A COMMERCIAL EXEMPTION PROCESS, UH, FOR, UH, FOR ONLY FOR VOLTAGE RIDE THROUGH, NOT FOR THE OTHER ELEMENTS.
AND THAT WAS, UH, PRETTY EXPLICIT IN THE FERC ORDER.
I THINK IT'S PARAGRAPH 1 93, UH, CALLS THAT OUT.
AND IT, AND IT LIKE LAYS THOSE, UM, THAT CRITERIA OUT.
IT ALSO TALKS ABOUT THE SCOPE AROUND, UH, HARDWARE VERSUS SOFTWARE AND THOSE TYPES OF ITEMS. UH, SO THE DRAFTING TEAM IS KIND OF TAKING THAT AND FOLDING THAT INTO THEIR PROCESS.
THE, UH, THE PROPOSAL AGAIN, WHICH DID NOT PASS, UH, INCLUDED A COMMERCIAL EXEMPTION FOR VOLTAGE RIDE THROUGH CONSISTENT WITH THE FERC ORDER.
UH, AND THAT WOULD BE FOR FACILITIES THAT, UH, ESSENTIALLY WERE, UM, REGISTERED AND OPERATIONAL BEFORE THE, UH, A DATE CERTAIN, WHICH WOULD BE THE EFFECTIVE DATE OF THE STANDARD, IS HOW THE DRAFTING TEAM PROPOSED THAT, AGAIN, DIDN'T PASS.
SO, UH, WHAT THEY COME BACK WITH, WE DON'T KNOW.
UH, BUT THAT'S WHAT THAT, THAT'S KIND OF WHAT THE PROPOSAL WAS.
UH, I, I ACTUALLY HAD A SIMILAR, UH, IT MAY BE AS A A DOVETAIL QUESTION OFF OF IKAS.
UM, AND I THINK YOU WERE GETTING AT IT, UH, TOWARDS, TOWARDS THE END THERE.
UH, I WAS CURIOUS WHAT KINDS OF COMMENTS, UH, NERC HAS RECEIVED, UH, IN THOSE PROPOSED STANDARDS AND, AND YOU KNOW, WHERE SOME OF THE, YOU KNOW, ROOM FOR REVISIONS ARE OR, OR ANTICIPATED, UH, CHANGES ARE THAT, YOU KNOW, SINCE YOU'RE GONNA BE GOING THROUGH ITERATIONS IN THE SUMMER, UH, TRYING TO GET SOMETHING TO THE NERC BOARD IN AUGUST.
AND, AND I'LL JUST, JUST, UH, FULL DISCLOSURE.
SO TEXAS RE IN THE STANDARDS PROCESS IS A COMMENTER.
SO THE REGION, SO WE'RE NOT DOING THE DRAFTING, UH, BUT WE ARE, WE'RE ACTUALLY PROVIDING COMMENTS.
AND, AND I'LL SAY THE COMMENTS ARE, I'VE REVIEWED SOME OF THEM, I HAVEN'T GONE THROUGH THE FULL, THERE'S A LOT OF COMMENTS ON ALL THESE PROJECTS.
UH, AND THEY'RE, THEY RANGE, UH, FROM, UH, FOLKS LOOKING AT AGAIN, HOW ARE WE GONNA IMPLEMENT THIS? WHAT ARE THE CRITERIA? WHAT ARE THE TECHNICAL SPECIFICATIONS? UH, OUR COMMENTS FOCUS ON MAKING SURE THE CRITERIA ARE CLEAR AND ENFORCEABLE.
UH, AND THAT'S, THAT'S WHERE WE FO UH, FOCUSED OUR ATTENTION IS, UH, DO WE NEED TO VERIFY OR CAN WE VERIFY THIS THING, UH, THESE, THE SETTINGS UP FRONT? UH, CAN WE HAVE A PROCESS THAT AUDITS THAT? AND THEN HOW DO WE, UH, AUDIT THIS ON THE BACK END FOLLOWING A PERFORMANCE EVENT? AND SO MAKING SURE THAT THOSE CRITERIA ARE CLEAR AND UNDERSTOOD, UM, HOW ALL THAT, THE DRAFTING TEAM KIND OF
[00:40:01]
TAKES ALL THAT AND, AND, UH, AND CONVERTS IT INTO, INTO LANGUAGE IS, UH, IT'S A, IT'S A, IT'S A TORTURED PROCESS.BUT, UH, AND THEY HAVE THEIR WORK CUT OUT FOR 'EM.
'CAUSE THERE'S A LOT OF COMMENTS AND THEY'RE COMING AT IT FROM DIFFERENT SIDES AND DIFFERENT PERSPECTIVES.
I DON'T, UH, DID YOU HAVE ANYTHING YOU WANTED TO ADD, MARK? TORTURED PROCESSES ARE, UH, NOT UNFAMILIAR.
YEAH, I THINK Y'ALL KIND OF GOT THAT NAILED.
SO, YEAH, THE ONLY THING I WANTED TO ADD IS THE WORK YOU ALL ARE DOING HERE, I HOPE WILL INFORM THAT AND, AND HELP, UH, THE REST OF THE COUNTRY, UH, COME TO A CONSENSUS AND BE ABLE TO MOVE SOMETHING FORWARD THERE.
UH, WHAT HAPPENS HERE CHANGES THE WORLD, RIGHT? SO, ANY OTHER QUESTIONS? UH, CAITLIN, I DID WANT TO HAVE, I HAD ONE ADDITIONAL CLARIFICATION FROM, UH, SOMETHING YOU MENTIONED THAT JOSEPH MENTIONED, AND THAT WAS THAT THE PROPOSED STANDARD THAT DID NOT PASS, THAT DID HAVE A DATE CERTAIN THAT WAS ON THE EFFECTIVE DATE OF THE APPROVED STANDARD.
WE MAY HAVE, MAY HAVE, WE MAY HAVE TO TAKE THAT ONE BACK TO, TO BE CLEAR, LEMME, I DON'T WANT TO, IT THERE IS A DATE CERTAIN I CAN GET IT FOR YOU.
I DON'T WANT, I DON'T WANNA SAY THE WRONG THING, UH, BUT, UH, IT WAS, UH, I THINK IT WAS TIED, IT WASN'T TIED TO THE NOVEMBER 4TH DATE.
IT'S A, IT'S A LATER DATE, BUT LET ME GET THE DATE AND I'LL GIVE IT TO YOU.
AND, YOU KNOW, FULL DISCLOSURE, THE, THE, THE EXACT DATE PROBABLY IS NOT AS, AS IMPORTANT AS THE PRINCIPAL, AT LEAST FROM MY STANDPOINT THAT IT'S SOMETHING IN THE, IN THE FUTURE.
'CAUSE I KNOW THAT'S ONE OF THE THINGS THAT TAC HAS GRAPPLED WITH ON, ON, ON SOME OF THESE ISSUES.
AND, UM, I THINK THAT'S ONE OF THE THINGS THAT WE HAVE TO ADDRESS.
SO WANTED, AND TO BE CLEAR AND TO CLEAR WHAT THAT, WHAT THAT DATE SAYS, JUST TO BE LIKE WHAT AND WHAT IF, WE'LL REMEMBER WHAT THE DATE, THE ACTUAL SPECIFIC DATE IS.
IT'S WHO IS ELIGIBLE FOR ANY TYPE OF COMMERCIAL EXEMPTION, WHICH UNDER THE DRAFT IS UNDER R SECTION R SIX IS WHERE THAT'S DEFINED.
AND SO YOU, IF YOU'RE POST THAT DATE, THERE IS NO COMMERCIAL EXEMPTION PROCESS CONTEMPLATED AGAIN BY THE CURRENT DRAFT, UH, WHICH IS, UH, YOU KNOW, NOT ON THE TABLE ANYMORE.
BUT THAT'S HOW THE, THE INITIAL CUT WAS, IS THAT IF YOU'RE ON BEFOREHAND, YOU WOULD BE ELIGIBLE FOR THE COMMERCIAL EXEMPTION THAT'S DESCRIBED IN R SIX.
AND IF AFTER THAT DATE, YOU WOULD NOT BE ELIGIBLE.
AND THAT'S, THAT'S SORT OF THE DIVIDING LINE THAT THEY, THEY DREW.
AND I THINK THAT'S VERY SIMILAR TO WHAT WE'VE UH, DISCUSSED HERE.
SO THAT'S, UH, THAT'S HELPFUL CONTEXT.
ARE WE TO ERIC GOFF? AND I THINK YOU HAD A RESPONSE TO A EARLIER QUESTION.
YEAH, ERIC GOFF AND AS USUAL IN THIS TOPIC, I'M SPEAKING FOR NEXTERA.
UM, SO, UM, IKA, I, I THOUGHT I COULD MAYBE PROVIDE SOME COLOR AND I THINK, UM, STEVEN JUMPED IN, I GUESS FOR A SIMILAR REASON ABOUT, UM, WHAT THE DIFFERENCES ARE IN 9 0 1 AND 2 45, AND I THINK THEY'RE INFORMING EACH OTHER, UM, AS THEY'RE BOTH MOVING THROUGH THE PROCESS IN A SIMILAR FASHION.
UM, SO FOR EXAMPLE, UM, THE SOFTWARE REQUIRED IDEA THAT CAME OUT OF, UM, A PAST VERSION AND IT'S NOW IN THE TAC REPORT, UH, WAS ADDED TO THE, UM, GER AS SOFTWARE IS ALWAYS COMMERCIALLY REASONABLE AFTER FERC ORDER TO 9 0 1, UH, WAS PUBLISHED, UM, BECAUSE FE ORDER TO 9 0 1 DREW A DISTINCTION BETWEEN, UH, SOFTWARE AND HARDWARE REQUIREMENTS FOR LEGACY EQUIPMENT.
UM, WE MAINTAINED THE, UM, HARDWARE REQUIREMENTS IF IT'S COMMERCIALLY REASONABLE FOR LEGACY EQUIPMENT.
UM, AND, UH, THAT GOES KIND OF BEYOND A, A PURE HARDWARE VERSUS SOFTWARE DISTINCTION THAT YOU, YOU COULD READ INTO THE FIRST QUARTER.
UM, SO IF NERC IMPLEMENTS A, UM, A HARDWARE VERSUS SOFTWARE DISTINCTION WITHOUT, YOU KNOW, A COMMERCIAL REASONABILITY TEST, THEN UM, ERCOT REQUIRING HARDWARE CHANGES IF THEY'RE COMMERCIALLY REASONABLE MIGHT EXCEED THE NERC REQUIREMENT.
BUT WE HAVE TO SEE HOW IT GOES THROUGH THE DRAFTING PROCESS.
AND IT'S, YOU KNOW, I, I AGREE WITH MARK THAT THIS WILL INFORM THAT PROCESS AND THAT'S INFORMING THIS PROCESS.
STEVEN, YEAH, THIS STEVEN SLEEVES WITH ERCOT.
A FEW QUESTIONS FOR TEXAS RE I, I HEARD A COUPLE OF TIMES THE WAY YOU, UH, KIND OF CHARACTERIZE THE EXEMPTION PROCESS IN FERC ORDER 9 0 1 IS COMMERCIAL, DOES, DOES FERC ORDER 9 0 1 OR PRC 29 CONTEMPLATE, UH, THAT EXEMPTION
[00:45:01]
PROCESS BEING A COMMERCIAL APPLICATION OR BASED ON TECHNICAL LIMITATIONS? IT'S A DOCUMENTED EQUIPMENT LIMITATION, STEVEN.SO I APPRECIATE THAT CLARIFICATION AND I PROBABLY SHOULD HAVE, UH, BEEN MORE CAREFUL IN MY TERMS. BUT IT'S A, LIKE THE, THE DRAFT R SIX REQUIREMENT, WHICH IMPLEMENTS THE FERC ORDER SPEAKS OF A DOCUMENTED EQUIPMENT LIMITATION THAT WOULD PREVENT AN APPLICABLE IBR, UH, THAT'S IN SERVICE BY THE EFFECTIVE DATE OF THE STANDARD, UH, FROM MEETING THE VOLTAGE RIDE THROUGH REQUIREMENTS.
THAT'S, THAT'S THE SPECIFIC LANGUAGE AS AN R SIX THAT COMES FROM THE FERC ORDER.
UH, I APPRECIATE THE CLARIFICATION.
AND THEN A SECOND QUESTION I HAD IS, I THINK YOU EMPHASIZED THAT THE, UH, FERC ORDER 9 0 1 DOES NOT CONTEMPLATE, IT ONLY CONTEMPLATES SUCH AN EXEMPTION FOR VOLTAGE RIDE THROUGH.
SO, UM, FOR FREQUENCY RIDE THROUGH FOR FERC ORDER 9 0 1, UM, SILENT ON ALLOWING EXEMPTIONS FOR FREQUENCY RIDE THROUGH REQUIREMENTS.
SO I I I WOULDN'T CHARACTERIZE IT AS SILENT.
I THINK IT'S, IT'S ACTUALLY VERY EXPLICIT THAT IT'S VOLTAGE RIDE THROUGH.
I MEAN, I'LL, I ACTUALLY, I'LL I'LL JUST QUOTE.
SO WHAT IT, WHAT IT SAYS IN FOR, AND THIS IS PARAGRAPH 1 93, IS ANY SUCH EXEMPTION SHOULD BE ONLY FOR VOLTAGE RIDE THROUGH PERFORMANCE FOR THOSE EXISTING IBR THAT ARE UNABLE TO MODIFY THEIR COORDINATED PROTECTION AND CONTROL SETTINGS TO MEET THE REQUIREMENTS WITHOUT PHYSICAL MODIFICATIONS OF THE I B'S EQUIPMENT.
THAT'S THE, THE LANGUAGE, UH, STRAIGHT FROM THE FERC ORDER.
SO IT, IT'S, IT'S FAIRLY EXPLICIT THAT IT'S FOCUSED ON VOLTAGE RIDE THROUGH PERFORMANCE.
AND I THINK ONE FINAL QUESTION IS, IS IT Y'ALL'S OPINION AS WELL THAT ANY SUCH EXEMPTIONS, THE RISK ASSOCIATED WITH ALLOWING THOSE EXEMPTIONS MUST BE ADDRESSED BY THE PLANNERS AND OPERATORS? UM, IS THAT CAPTURED IN FERC ORDER 9 0 1 AS WELL? SO WHAT I WOULD SAY THERE IS, UH, IT'S THE FERC ORDER 9 0 1, UH, SPEAKS TO, UH, A SUITE OF THINGS.
UH, IT SPEAKS TO MODELING INTERCONNECTION PROCESS SPEAKS TO, UH, UM, ENSURING THAT, UH, THAT, THAT THE GENERATORS PERFORM IN A, IN A, IN AN UNDERSTOOD WAY.
UH, SO IT DOESN'T, UH, NECESSARILY, I, I DON'T KNOW IF IT'S, IF YOU GO SO FAR AS TO SAY OR I WOULDN'T BE COMFORTABLE SAYING IT'S, IT SORT OF SHIFTS THE RISK, BUT IT DOES SPEAK TO ENSURING, UH, PERFORMANCE DATA IS PROVIDED, UH, THAT, THAT GENERAT THESE GENERATORS ARE ACCURATELY PLANNED FOR AND MODELED.
AND SO THAT HAS TO BE INCORPORATED INTO THE PROCESS.
I REALLY APPRECIATE THE RESPONSE, AND I DON'T MEAN TO PUT YOU ON THE SPOT IF THAT'S NOT A PARTICULAR AREA THAT, THAT Y'ALL PREPARED FOR, BUT IT IS A PARTICULARLY IMPORTANT ASPECT, I THINK AS WE APPROACH SOLVING THIS PROBLEM IN, UH, I, I THINK AT LEAST IN ERCOT READ OF IT, UH, WE HAVE CONTEMPLATED THAT THE COMMISSION EXPLICITLY SAID THAT AS NERC CONSIDERS, UH, THE POTENTIAL FOR THESE EXEMPTIONS FOR TYPICALLY OLDER IBR TECHNOLOGY, THAT THEY SHOULD AT THE SAME TIME, UH, DETERMINE HOW THE COORDINATORS, RELIABILITY COORDINATORS AND PLANNING COORDINATORS WOULD MITIGATE THE RISK ASSOCIATED WITH THOSE EXEMPTIONS.
UH, I THINK TO WHAT ERIC MENTIONED EARLIER, I THINK THAT THERE HAS BEEN AN ADAPTATION TO NOGA 2 45 AS WE'VE GOTTEN ADDITIONAL CLARITY AS WE'VE HAD ADDITIONAL DISCUSSIONS.
UM, BUT I THINK AS THE DISCUSSIONS UNFOLD TODAY, UH, THOSE ARE GOING TO BE SOME CORE, UH, THINGS THAT WE HAVE TO CONSIDER IS HOW WE BALANCE.
AND I THINK EVEN WITHIN FERC ORDER 9 0 1, THERE IS A, A CONCEPT OF BALANCE THAT WE, THEY WANT INDUSTRY TO EVALUATE TO ALLOW EXEMPTIONS, BUT MAKE SURE THAT THE SYSTEM DOESN'T FALL APART IN THAT PROCESS.
WELL, AND THE ONLY THING I WOULD ADD, STEVEN, AND, AND I'LL, I'LL GO BEYOND FERC ORDER 9 0 1 AND JUST TALK ABOUT, YOU KNOW, FROM OUR PERSPECTIVE, UH, AS THE RELIABILITY, UH, ENTITY IN THE REGION IS WHAT WE REALLY WANT IS RELIABLE PERFORMANCE, LIKE LEAVING ASIDE THE STANDARDS AND THE ORDER, WE WANT A, A RELIABLE OUTCOME HERE.
AND SO HOW Y'ALL STRIKE THAT BALANCE AND THERE'S, THERE IS A, I THINK A BALANCE THAT Y'ALL ARE WORKING TO STRIKE,
[00:50:01]
THAT THE NERC STANDARDS ARE WORKING TO STRIKE, BUT YOU HAVE TO FACTOR IN THE RELIABILITY COMPONENT INTO THAT.UH, SO I THINK THAT'S, THAT'S A FAIR STATEMENT THAT, YOU KNOW, WE WANT THE SYSTEM TO BE AS RELIABLE AS POSSIBLE.
WE UNDERSTAND THAT, THAT INDICATE THAT NEEDS, THERE HAS TO BE A BALANCE STRUCK BETWEEN WHAT IS, UH, WHAT EQUIPMENT CAN DO, WHO'S ON THE SYSTEM, YOU KNOW, HOW THAT, LIKE WHAT, UH, HOW YOU GET RESOURCES ON.
THAT'S WHAT Y'ALL ARE GONNA DEAL WITH.
WHAT FROM OUR PERSPECTIVE, WHAT WE WANT IS WE WANT RELIABILITY.
UM, AND THAT'S REALLY, AT THE END OF THE DAY, THAT'S WHAT WE'RE CHASING.
I DON'T HAVE MUCH TO ADD, STEVEN.
YOU KNOW,
UH, THE THING IS, IS THIS IS A MULTIFACETED PROBLEM, AND TODAY WE'RE FOCUSED ON PERFORMANCE.
YOU'VE GOT TO HAVE GOOD MODELS FOR ALL THAT EQUIPMENT TO BE ABLE TO PREDICT AND, UH, IN A FAIR WAY ASSESS WHAT MAY HAPPEN ON THE SYSTEM.
SO AGAIN, THIS IS, THIS IS VERY COMPLEX ISSUE.
AND, UH, I GUESS WHAT I WANNA CLOSE IS I APPRECIATE THE EFFORT THAT'S GOING INTO THIS AND THE EFFORT TO FIND THAT, THAT COMMON GROUND, WE'RE GONNA HAVE A LOT OF WORK IN THE YEARS AHEAD TO, UH, FULLY INTEGRATE AND ENGAGE THIS.
AND AT SOME POINT WE'RE GONNA START SEEING THE REAL BENEFITS OF THIS TECHNOLOGY AS WELL.
I THINK WE'RE ALREADY STARTING TO TOUCH ON THAT.
UH, IT SEEMED LIKE, UH, ONE EVENING THIS WEEK, UH, WE SAW SOME THINGS THAT WERE VERY FAVORABLE.
SO WITH THAT IS, IS THERE ANYTHING ELSE YOU WANTED TO ASK ABOUT STEVEN? I, I THINK I HAD A DIFFERENT QUESTION.
UM, AND, AND MAYBE I LEAVE THIS WITH Y'ALL TO, TO TAKE AWAY AND, AND MAYBE LATER Y'ALL INTERJECT, BUT WE HAVE ALSO READ IN THE DEFINITION OF AN OPERATIONAL PLANNING ANALYSIS AND A REAL TIME ASSESSMENT THAT WE HAVE TO, WE ARE OBLIGATED TO CONSIDER EQUIPMENT LIMITATIONS WITHIN THOSE PROCESSES AND Y'ALL BEING THE, UH, REGIONAL ENTITY FOR NERC AND THAT BEING A NERC DEFINITION, NERC REQUIREMENT, I THINK THAT'S ALSO IMPORTANT.
IT WEIGHS ON OUR MINDS THAT WE HAVE TO BE ABLE TO HAVE THIS INFORMATION MODELED AND IT HAS TO BE INCLUDED IN THOSE ASSESSMENTS OR IT EXPOSES, YOU KNOW, UH, POTENTIAL NON-COMPLIANCE WITH THOSE REQUIREMENTS.
AND WE'RE JUST CURIOUS IF, IF TEXAS RE SHARED THAT SAME VIEW OF THOSE DEFINITIONS.
WHAT I'D LIKE TO DO IS GO BACK TO WHAT JOSEPH SAID IS WE NEED A RELIABLE OPERATION IN THE SYSTEM.
UH, THERE ARE THINGS, UH, AT ANY GIVEN TIME, THERE ARE THINGS THAT CAN HAPPEN WITH EQUIPMENT.
YOU REMEMBER I POINTED OUT WITH THE ODESSA TWO EVENT THAT WE HAD ANOTHER PLANT EVEN FURTHER AWAY IN THE VALLEY THAT TRIPPED.
UH, THERE'S NO WAY PROBABLY THAT WE'RE GONNA HAVE THE KIND OF MODELING THAT CATCHES SOME THINGS LIKE THAT.
BUT, UH, THIS IS SOMETHING THAT AGAIN, WE, WE FEEL LIKE THESE ARE SYSTEMIC ISSUES.
YOU NEED TO HAVE THE UNDERSTANDING OF THEM TO MAKE PRUDENT DECISIONS ABOUT HOW YOU'RE GONNA PLAN FOR THE OPERATING DAY AND HOW JOHN'S GONNA PLAN FOR WAY OUT IN THE FUTURE TOO.
UM, I THINK I SEE HAIKA AND THE QUEUE AGAIN.
UH, JOSEPH, YOU MENTIONED WHEN YOU ARE ANSWERING A QUESTION REGARDING THE EXEMPTION PROCESS, DOCUMENTED EQUIPMENT LIMITATION.
CAN YOU EXPLAIN THAT MORE? WHAT DOES MEANS? THANKS.
SO A DOCUMENTED EQUIPMENT LIMITATION, UH, SO THE, THE, AGAIN, I'LL SAY THIS, I'LL SAY IT EVERY TIME, UH, THE DRAFT LANGUAGE AS JUST A DRAFT AND IT WAS REJECTED, BUT WHAT THE, THE, THE DRAFTING TEAM DEFINED THAT AS, AND THIS IS SIMILAR TO THE PROCESS THAT'S IN THE CURRENT PRC 24 STANDARD.
UH, I THINK R THREE, UH, WHICH LAYS OUT A PROCESS WHERE YOU PROVIDE DOCUMENTATION, UH, TO, UH, IDENTIFYING THE IVR, UH, WHICH ASPECTS OF THE REQUIREMENT YOU'RE NOT ABLE TO MEET, UH, THE SPECIFIC PIECES OF EQUIPMENT THAT CAUSE THE LIMITATION AND, UH, INFORMATION ABOUT PLANS TO REPAIR OR REPLACE EQUIPMENT.
THAT'S ANOTHER THING THAT'S CALLED OUT IN THE FERC ORDER, UH, EXPLICITLY, IS IF YOU TAKE SOMETHING AND YOU REPLACE IT, UH, THEN THE EXEMPTION THAT DOCUMENTED EQUIPMENT LIMITATION NO LONGER WOULD APPLY.
UH, AND YOU PROVIDE THAT TO, UH, IN THIS REGION, YOU'D BE PROVIDING THAT TO ERCOT AS THE RELIABILITY COORDINATOR ALONG WITH, UH, TRANSMISSION PLANNERS.
IT CALLS OUT THE, THE FUNCTIONAL ENTITIES, UH, PLANNING COORDINATORS, TRANSMISSION PLANNERS, AND RELIABILITY COORDINATORS, WHICH WOULD BE ERCOT.
SO THAT'S HOW THAT PROCESS WORKS.
AND IT'S SIMILAR TO, OR AT LEAST IN SIMILAR IN SPIRIT TO WHAT'S IN PRC 24, R THREE, WHICH ALLOWS YOU TO DOCUMENT AN EQUIPMENT LIMITATION AND SUBMIT THAT, THAT PAPERWORK EXPLAINING WHAT THAT IS.
SO I THINK THAT'S WHAT THE, THE TERM THEY'RE GETTING AT.
[00:55:01]
YOUR QUESTION? THANK YOU SO MUCH.UM, SO I THINK THAT ON SOME OF THE, UM, OBLIGATIONS FOR ERCOT, UH, AND, UM, THAT WILL FALL OUT OF 9 0 1 FER CODE TO 9 0 1, I THINK WE'LL PROBABLY HAVE TO HAVE ONGOING DISCUSSIONS ABOUT, UH, HOW TO DO THAT.
I THINK SOME OF THE THINGS THAT YOU'RE ALLUDING TO AREN'T SPECIFICALLY IN, UM, NOGA 2 45 RIGHT NOW, AND I THINK THERE'LL BE A MORE DISCUSSION AND MORE NO GOODS IN THE FUTURE ABOUT HOW TO, UH, MANAGE THIS, UH, ONGOING CHANGING GRID.
UM, I ALSO, UM, THINK THAT TAC WILL PROBABLY WANT TO GET, YOU KNOW, ROUTINE UPDATES ABOUT, UM, THE IMPLEMENTATION OF 9 0 1.
UM, AND I'M GLAD WE HAVE AN IBR WORKING GROUP.
UM, SO HOPEFULLY THAT CAN BE PART OF FUTURE ROSS REPORTS.
GOOD MORNING, DAVE RY WITH ENERGY.
UM, JUST A CLARIFYING QUESTION ON 9 0 1 AND THE EQUIPMENT LIMITATION DOCUMENTATION.
AM I RIGHT THAT, UM, IF YOU DOCUMENT THE EQUIPMENT LIMITATION, IT DOESN'T INCLUDE AN OBLIGATION TO REPLACE THE EQUIPMENT, RIGHT? IT'S JUST IN THE EVENT THAT YOU REPLACE THE EQUIPMENT, THEN THE REQUIREMENT MAY CHANGE.
IS THAT CORRECT? THAT'S CORRECT.
UH, SO WHAT, WHAT THE, UH, IF, IF I'M REMEMBERING THE FERC ORDER AND WHAT THE, THE REQUIRE THE DRAFT REQUIREMENTS TO IMPLEMENT IT, THE FERC ORDER SAYS YOU, YOU CAN, YOU DOCUMENT AN EQUIPMENT LIMITATION.
HOWEVER, IF YOU REPLACE, IF YOU DO REPLACE THE EQUIPMENT, THEN THAT LIMITATION, UH, GOES AWAY AND YOU'RE NO LONGER ELIGIBLE FOR THAT, UH, THAT EXEMPTION ANY LONGER.
UH, BUT THERE'S NO OBLIGATION, UH, UH, IN MY MIND TO REPLACE, YOU DON'T HAVE TO GO AND REPLACE THE EQUIPMENT ITSELF.
I THINK THAT DRAWS A DISTINCTION BETWEEN THE TAC APPROVED REPORT AND, UM, PER ORDER 9 0 1, WHERE THE TAC APPROVED REPORT WOULD REQUIRE CERTAIN PHYSICAL MODIFICATIONS, 9 0 1 THAT YOU DOCUMENT THE EQUIPMENT LIMIT LIMITATION, YOU'RE NOT OBLIGATED TO REPLACE IT.
I THINK JULIA WANTS TO JUMP IN AND ANSWER THIS.
YEAH, NO, I JUST WANTED TO ADD TO THIS.
SO THIS IS, UH, SPECIFICALLY ON PRC 29, WHICH IS A NEW WRITE THROUGH STANDARD DRAFT, UH, FROM NERC.
SO THE IMPLEMENTATION PLAN, UH, SAYS YOU SHOULD, UM, LIST THE LIMITATIONS AND ALSO COME UP WITH THE MITIGATION PLAN.
AND SO THAT'S ONE OF THE, PART OF THE COMMENTS THAT CAME BACK IS LIKE, OKAY, SO I HAVE A MITIGATION PLAN, AND THEN WHAT DO YOU DO? IS THERE, YOU KNOW, TIMELINE FOR IMPLEMENTATION OF MITIGATION PLAN? SO ON.
BUT I, I WOULDN'T INTERPRET IT THAT THERE IS NOTHING BUT REPORT LIMITATIONS.
THERE IS ALSO, UM, POINT THERE THAT SAYS YOU SHOULD HAVE A MITIGATION PLAN.
ARE WE GOOD ON THAT QUESTION? LET'S GO TO JOHN HUBBARD.
HI, CAN Y'ALL HEAR ME OKAY? IT'S A LITTLE FAINT, BUT WE CAN HEAR YOU.
UM, I WAS JUST CURIOUS, I THINK THE INFORMATION ABOUT SOME OF THE PAST EVENTS HAS BEEN HELPFUL.
I WAS CURIOUS HOW THE SOFTWARE UPDATES HAVE, HAVE THEY HELPED MITIGATE EVENTS? HAVE THERE, HAVE THERE BEEN EVENTS POST KIND OF IMPLEMENTING SOME OF THE SOFTWARE UPDATES? HI JOHN, THIS IS MARK HENRY AND, UM, THERE WAS ANOTHER EVENT IN SOUTHWEST UTAH.
UNFORTUNATELY, WE DON'T HAVE THE REPORT IN THE DETAILS OUT YET, BUT IT DOES APPEAR THAT SOME CHANGES OCCURRED.
I JUST CAN'T CHARACTERIZE WHAT THE NATURE OF THEM WAS.
IT STILL IS AN EVENT THAT WILL RESULT IN A NERC REPORT.
SO IT WAS A SIGNIFICANT ENOUGH EVENT TO, UH, TO GENERATE THAT.
AND, UM, UNFORTUNATELY AT THIS POINT WE DON'T, WE DON'T NECESSARILY HAVE A GOOD SENSE OF THAT.
I KNOW THAT ERCOT THROUGH THE WONDERFUL WORK OF THE IBR WG HAS BEEN GETTING UPDATES ON, UH, THINGS THAT ARE BEING ROLLED OUT IN OUR REGION.
UH, WE HAVE SOME CORRESPONDENCE WITH PEOPLE IN WEC AND THERE ARE SOME ACTIONS THAT WE'RE AWARE OF, BUT I, I DON'T HAVE A WHOLE LOT OF DETAIL FOR YOU ON THAT.
WE WILL TRY TO GET MORE INFORMATION.
UH, IT'S SOMETHING THAT I THINK NER NER CAN DO, CERTAINLY TO CONTINUE TO FOLLOW UP.
WE JUST WANT TO PUT OUR EFFORT INTO, UH, SHOWING HOW THE FIXES ARE SHOWING ARE BEING APPLIED AS OPPOSED TO TALKING ABOUT ANOTHER EVENT.
MARK, I HAVE A SLIDE ON THIS, I THINK.
YEAH, JULIA'S GOT A SLIDE ON IT.
I THINK I WAS PARTICULARLY ASKING ABOUT TEXAS, UM, POST THE ODESSA EVENT, NOT UTAH.
UM, 'CAUSE I, YEAH, I, I THINK THE STANDARDS HERE ARE DIFFERENT, BUT I COULD BE MISTAKEN.
[01:00:01]
ANYTHING ELSE? MR. HILTON? I SEE BOB HILTON.I'M TRYING TO RECONCILE SOMETHING IN MY MIND THAT YOU SAID THAT'S WHAT'S YOU'RE TALKING ABOUT.
THE STANDARD IS SAYING A MITIGATION PLAN 9 0 1 IS SAYING YOU THAT YOU HAVE TO DO EVERYTHING UP TO A PHYSICAL REPLACEMENT OF EQUIPMENT.
AND I'M TRYING TO RECONCILE THOSE TWO.
AND WHAT YOU MEAN BY MITIGATION PLAN IS THAT A MITIGATION PLAN BY AN OWNER, IS THAT MITIGATION PLAN BY THE PLANNERS? LIKE I THINK STEVE MM-HMM.
'CAUSE THERE SEEMS TO BE A BIG DISCONNECT.
YEAH, I THINK THAT'S KIND OF WHERE CONFUSION COMES FROM.
UH, FOR 9 0 1 IS A DIRECTIVE TO NERC TO UPDATE AND DEVELOP NEW STANDARDS FOR IBR AS NEEDED TO ADDRESS, UM, CERTAIN ISSUES THAT WE'VE BEEN SEEING.
SO NOW NERC IS DEVELOPING THIS SLEW OF STANDARDS THAT, UH, MARK WAS TALKING ABOUT, UH, AND ONE OF THE STANDARDS PRC 29, WHICH IS THE NEW STANDARDS FOR I THROUGH FOUR IBR.
AND, UH, THIS STANDARD HAS ITS OWN IMPLEMENTATION PLAN AS EVERY STANDARD WILL HAVE.
AND SO THIS IMPLEMENTATION PLAN HAS THIS, UH, LIKE NUMBER OF ITEMS THAT, THAT THE GENERATOR OWNER HAS TO, UM, LIST, UM, AS A PART OF THEIR LIMITATIONS.
UM, AND I HAVE A SLIDE ON THAT TOO, BUT THEN LIKE ONE POINT ON THE SLIDE IS, UM, YOU SHOULD LIST LIMITATIONS AND ALSO PROPOSED MITIGATION, BUT WHERE IT LEAVES KIND OF EMPTY SPACE AS TO WHAT DO YOU DO NEXT, UM, AND YOU, I MEAN, GENERATOR OWNER, SO THAT'S ON GENERATOR OWNERS TO DO THAT.
YOU PUT UP AND THAT THAT MITIGATION PLAN COULD BE REPLACED THE EQUIPMENT, BUT THEN 9 0 1 WOULD SAY YOU DON'T HAVE TO DO THAT IF IT'S NOT ECONOMICALLY FEASIBLE.
WELL, IN 2 45, IT'S NOT ECONOMICALLY FEASIBLE UNDER 9 0 1.
YOU DON'T HAVE TO DO IT THE WAY IT'S SET RIGHT NOW.
SO, SO IT HAS THIS TECHNICAL FEASIBILITY, UH, PIECE AS, UM, STEVEN HAS MENTIONED, BUT I HAVE, UM, EXACT LANGUAGE ON MY SLIDE SO WE CAN COME BACK TO THAT.
I JUST WANNA REMIND, UM, WHEN WE TALK ABOUT, UH, ASSESSING RISK AND, UH, THE ODESSA ONE EVENT, THE ODESSA TWO EVENT, SO MUCH OF THAT HAS TO DO WITH, UH, STUDIES.
AND I KNOW ERCOT HASS BEEN CHALLENGED A LOT TO GIVE US A STUDY THAT SHOWS WHAT THE RISK IS.
AND I JUST WANNA MAKE SURE WE ALL REMEMBER THAT.
UH, WE DON'T HAVE THE MODELS TO DO THOSE STUDIES.
SO THESE RESOURCES AREN'T PROVIDING MODELS IN A LOT OF CASES THAT ACCURATELY PREDICT WHAT THE RISK IS ASSOCIATED WITH THESE UNITS ON THE SYSTEM.
AND SO THE ABILITY TO PRODUCE A STUDY, TO PROVIDE A MITIGATION PLAN TO DO A LOT OF THAT WORK ISN'T THERE.
AND SO THAT'S SOMETHING THAT, UH, AS WE GO THROUGH THIS TODAY, WE NEED TO KEEP THAT IN MIND IS THAT, UH, AS WALTER REED USED TO TALK ABOUT, WE'VE GOT THE BIG ANALOG SYSTEM, BUT WE DON'T HAVE A SIMULATION SYSTEM THAT WE CAN ACCURATELY PREDICT WHAT'S GONNA HAPPEN ON THAT BIGGER SYSTEM, WHICH IS THE ONE WE ALL WORRIED ABOUT.
ALRIGHT, JUST GOING BACK TO THE 9 0 1 AND PRC 29 FOR A MOMENT, AND, AND BOB'S QUESTION, UM, AND LOOKING FORWARD TO SEEING JULIA'S SLIDES ON, ON THE TOPIC AS WELL.
I THINK PART OF THE APPARENT DISCREPANCY IS THAT, I MEAN, 9 0 1 THE ORDERS PUBLISHED AND PRC 29 AS, UM, FOLKS FROM NRC AND TRE HAVE POINTED OUT, UM, IS IS STILL IN A DRAFT FORM IN THE FIRST BALLOT, I THINK ONLY 25% APPROVED THE ORIGINAL DRAFT LANGUAGE.
SO THAT'S WHAT MAKES IT A LITTLE HARD, I GUESS TO SAY DEFINITIVELY WHERE PRC 29 IS GONNA COME OUT WITH RESPECT TO WHAT HAPPENS WHEN YOU HAVE A LIMITATION.
I WAS CHARACTERIZING WHAT WAS IN THE FERC 9 0 1 REPORT AND OR FERC 9 0 1 ORDER.
SO I THINK THAT'S PART OF THE REASON THAT THERE'S SOME CONFUSION.
BILL BARNES QUESTION FOR WOODY.
SO WHAT, WHAT ARE WE MISSING OR WHAT INFORMATION IS NOT BEING PROVIDED TO ERCOT TO ALLOW YOU TO MORE ACCURATELY MODEL AND DO A RISK ASSESSMENT OF THE EXISTING RESOURCES? IS IT A CHANGE TO THE RESOURCE DEFINITION GLOSSARY WHERE WE NEED TO GET DIFFERENT INFORMATION, OR IS IT JUST INABILITY TO ACTUALLY SIMULATE THE DISTURBANCE THAT OCCURS? HOW DO WE CLOSE THAT GAP? WELL, I THINK THE GAP IS WITHIN THE MODELS THAT ARE SUPPLIED THEMSELVES.
SO IF THE MODELS THAT WERE SUPPLIED ACT ACTUALLY REPRESENTED THE PERFORMANCE OF THE UNITS DURING THOSE CONDITIONS, THERE WOULDN'T BE A GAP.
[01:05:01]
WHEN SOMEONE SUBMITS US A MODEL OF THEIR RESOURCE, WE LOOK AT THE MODEL AND WE DO WHAT WE CALL A MODEL QUALITY TEST.AND WE SAY, SURE ENOUGH, THAT MODEL PASSES THE TEST.
AND SO THE UNIT IS THEN ENERGIZED AND GOES THROUGH A QUARTERLY STABILITY ASSESSMENT, PASSES THAT IT ACTUALLY GETS ENERGIZED.
BUT THE WHOLE, THE GAP IS THAT THE MODEL ITSELF DOESN'T ACTUALLY REPRESENT WHAT HAPPENS WHEN THE SYSTEM VOLTAGE FLUCTUATES.
SO THAT'S JUST A, YOU KNOW, THAT'S, THAT'S A REALITY THAT EVERYONE IN THE ROOM NEEDS TO BE AWARE OF IS THAT WE DON'T HAVE THE MODELS TO PRODUCE ACCURATE STUDIES AT THIS POINT IN A LOT OF CASES.
SO, I MEAN, ERCOT, YOU KNOW, FULL OF ENGINEERS, WE LOVE TO DO STUDIES, WE LOVE TO PROVIDE ASSESSMENTS.
WE DO 'EM ALL THE TIME, BUT THEY'RE ALWAYS BASED ON THE MODEL OF THE SYSTEM THAT YOU HAVE.
BECAUSE YOU CAN'T, YOU CAN'T DO ASSESSMENTS ON THE BIG ANALOG SYSTEM ON THE ACTUAL GRID.
YOU CAN'T ACTUALLY DO ASSESSMENTS THERE.
YOU CAN LOOK AT RESULTS AND THAT'S WHAT YOU SEE WITH ODESSA ONE AND ODESSA TWO AND SOME OF THESE OTHER ONES.
BUT IT'S THAT LACK OF, AND I THINK IF EVERYONE WILL, WILL, WILL, UH, LEVEL SET ON THAT TO BEGIN WITH, IT REALLY HELPS THE REST OF THE CONVERSATIONS WE'RE GONNA HAVE TODAY.
UM, WE ARE AT ERIC GOFF AND WE'LL GET YOU IN THE QUEUE.
UM, SO I THINK THAT, UM, ONE THING TO POINT OUT AND MOD, I THINK IT'S A GOOD POINT ON MODELING AND, UM, I EXPECT THAT'LL GET A LOT OF ATTENTION OVER TIME.
UM, BUT ONE THING THAT'S NOTABLE IN, UH, THE ATTACK REPORT OF NOGA 2 45 IS THAT TO GET AN EXEMPTION, YOU HAVE TO SUBMIT AN UPDATED MODEL.
UM, SO, UH, I THINK THAT'S, AND ERCOT HAS TO ACCEPT THE MODEL, SO I JUST WANTED TO POINT THAT OUT.
YEAH, GO, GO AHEAD AND RESPOND TO THAT.
SO WHEN YOU GIVE US A MODEL, WE LOOK AT THE MODEL, WE PUT IT IN THE SIMULATOR, WE LOOK TO SEE IF IT DOES, IF IT MEETS THE REQUIREMENTS OF THE SYSTEM YEP.
DOES IT RIDE THROUGH, DOES IT PERFORM? AND IF IT DOES IT MEETS THAT MODEL TEST, THEN WE PASS IT.
BUT THEN WHEN AN ACTUAL EVENT OCCURS, WE FIND OUT THREE YEARS LATER, FIVE YEARS LATER, WHENEVER, WELL THAT'S, THAT UNIT DIDN'T ACTUALLY RESPOND LIKE THE MODEL SAID IT WOULD.
SO I AGREE, GIVEN THIS AN UPDATED MODEL, THAT'S GOOD, BUT HOPEFULLY THE UPDATED MODELS MORE ACCURATELY WILL REPRESENT, BUT AT THIS POINT WE DON'T HAVE PROOF THAT THAT'S HAPPENING.
I, I TOTALLY AGREE AND UNDERSTAND AND THERE'S A HISTORY OF, OF EXACTLY WHAT YOU'RE DESCRIBING, YOU KNOW, SO YOU'RE SPEAKING FROM EXPERIENCE AND I HOPE THAT AS WE DIVE IN TO THE, THE SPECIFIC DETAILS OF THIS, UM, YOU'LL GET BETTER AND BETTER MODELS OVER TIME.
AND I EXPECT MODELING WILL BE AN ONGOING CONVERSATION AT ROSS IN THE IB WORKING GROUP.
AND I, AND I EXPECT MODELS WILL GET BETTER.
BUT LIKE I SAID, AND THAT WAS REALLY MY POINT, RIGHT, IS THAT AT THIS POINT IN TIME, I, YEAH, THE PROOF IS IN THE PERFORMANCE AND WE'RE NOT TO THE POINT WHERE WE HAVE THE PROOF YET.
AND SO THAT NEEDS TO FACTOR IN TO EVERYTHING WE TALK ABOUT TODAY.
YEAH, I UNDERSTAND YOUR POINT.
LET'S, LET'S JUST GO IN ORDER OF THE QUEUE.
YEAH, THANK YOU FOR THAT, WOODY, UH, APPRECIATE THAT.
AND I UNDERSTAND THE MODELING IS AN ISSUE AND THAT'S PART OF OUR PROBLEM.
WE FIND OUT WHENEVER WE GET TO REAL TIME WHAT'S WORKING AND WHAT'S NOT.
UH, THE ONLY THING I WOULD SAY, AND I THINK YOU ALLUDED TO IT A LITTLE BIT, IS THE MODELS AND RE AND WHAT HAPPENS IN REAL TIME ISN'T GOING TO EVER MATCH.
THERE ARE GONNA BE SOME GAPS THERE.
SO WE CAN NEVER SAY IT'S GONNA BE PERFECT BECAUSE WE'RE DOING INPUTS FROM WHAT WE PUT IN AND WHAT THE MODELS PUT IN FOR THEIR INPUTS AND YOUR ASSUMPTIONS.
AND THEN THE WAY THEY REACT IS WHAT HAPPENS AND WHEN THE ASSUMPTIONS ARE NOT ASSUMPTIONS ANYMORE OF WHAT ACTUALLY HAPPENS ON THE SYSTEM.
SO, UH, I THINK WE'VE GOT A LONG WAY TO GET BETTER ON THE MODELS.
BUT WE'RE NEVER GONNA GET PERFECT IN MY MIND.
[01:10:01]
TO KEN, KEN, DONNA WITH ADVANCED POWER ALLIANCE.WOODY WOULD IMPLEMENTATION, I KNOW KOTS BEEN WORKING ON IMPLEMENTING TSA IN THE OPERATIONAL ENVIRONMENT.
WOULD THAT HELP ON THIS SITUATION? BECAUSE THEN YOU'D HAVE IMMEDIATE OPERATIONAL FEEDBACK GETTING OUT OF THE ANALOG WORLD, MOVING INTO THE DIGITAL WORLD WITH TSAI THINK THE, THE HELPFULNESS OF HAVING AN ONLINE STABILITY ASSESSMENT IS ONLY AS GOOD AS THE MODELS THAT YOU HAVE.
SO IT WOULD STILL BE LIMITED, BUT I THINK YOU'D HAVE IMMEDIATE FEEDBACK FROM THE OPERATIONAL EN ENVIRONMENT RATHER THAN TRYING TO GO BACK THROUGH THE PLANNING ENVIRONMENT AND DO IT.
YOU'RE DOING IT WITH ACTUAL TSA ONLINE TOOLS.
WE WOULD HAVE IMMEDIATE FEEDBACK THAT WE HAD ANOTHER ODESSA EVENT.
THAT'S WHAT WE'RE SHOOTING FOR.
I MEAN, I BETTER MODELS WILL HELP MAKE THAT MORE EFFECTIVE, BUT WE STILL NEED BETTER MODELS.
YEAH, I THINK A COUPLE COMMENTS.
ONE TO THAT QUESTION THAT KEN JUST POSED.
I THINK ONLINE REAL TIME MODEL VALIDATION IS SOMETHING THAT ERCOT SHOULD LOOK AT, BUT IT'S GONNA TAKE PMU DATA BEING STREAMED TO ERCOT FROM GENERATORS.
UM, WE WOULD NEED THAT TYPE OF HIGH SPEED REAL-TIME DATA TO DO SUCH AN EFFORT SO THAT THAT WOULD BE AN ADDITIONAL COST TO THE GENERATORS AND WE'D NEED TO START LOOKING AT THAT TYPE OF APPROACH.
I THINK THE OTHER THING I JUST WANTED TO MENTION IS AS WE GO THROUGH THIS PROCESS, ONE OF THE THINGS I KNOW, I KNOW WE'RE GONNA TALK ABOUT THE BOARD FEEDBACK, BUT WHERE WE AGREE IS GONNA BE IMPORTANT FOR US TO CAPTURE, AND IT SURE SOUNDS LIKE WE BOTH AGREE THAT WE NEED MODELS TO DO THAT AND WE NEED THEM ACCURATE TO DO ANY TYPE OF ASSESSMENT FOR AN EXEMPTION.
AND HOPEFULLY Y'ALL UNDERSTAND THAT ERCOT NEEDS MODELS TO MEET OUR OBLIGATIONS AS WELL, UH, FOR PLANNING AND OPERATIONS.
SO AT AT LEAST TO, TO WOODY'S POINT, AND I'M GLAD TO HEAR ERIC AGREE, THAT MAY BE SOMETHING WE CAPTURE AS WE GO ALONG THE WAY THAT THAT IS SOMETHING WE AGREE ON.
UM, DAN? YEAH, SO, UM, I MEAN THE, THE, WE WE'RE TALKING ABOUT BETTER MODELS, BUT WHAT WHAT WE'RE TALKING ABOUT REALLY IS MORE COMPLETE MODELS WHERE THERE ARE WHOLE MECHANISMS WITH WITHIN PLANTS THAT PROTECTION SYSTEMS THAT TRIP OFF THE PLANT THAT AREN'T EVEN INCLUDED IN THE CONTROL SYSTEM SIMULATION FOR THE PLANT THAT WE, THAT THEY PROVIDE TO US.
AND SO THERE ARE THINGS THAT, THERE ARE MECHANISMS THAT WILL CAUSE THE PLANT TO BEHAVE BADLY IN THE REAL WORLD OR BEHAVE APPROPRIATELY IN THE REAL WORLD, BUT AT LEAST FROM WHAT IT'S DESIGNED TO.
BUT THOSE THINGS ARE NOT IN OUR SIMULATIONS.
THE OTHER PROBLEM IS THAT WE'VE HEARD THAT, THAT A LOT OF TIMES THAT THEN THERE'S THE PARAMETERS THAT WERE WITHIN THOSE MODELS, OKAY, WHAT ARE THE NUMBERS? THIS, THIS, THIS VALUE FOR THIS PARTICULAR PART OF THE CONTROL SYSTEM, THIS GAIN CAN BE LOW OR HIGH.
AND WHAT WE'VE HEARD IS A LOT OF PEOPLE GIVE US, WHEN THEY'RE FILLING OUT THE FORMS, THEY GIVE US THE NUMBER THAT MEETS THE REQUIREMENT AS OPPOSED TO WHAT THE PLANT CAN ACTUALLY DO.
I MEAN IT GETTING INTO THOSE KINDA LEVELS OF DETAIL, THE, THE, THE WAY THAT YOU FIND THOSE IS BY THE FOLKS AT THE PLANT, THE FOLKS THAT ACTUALLY KNOW HOW THE SETTINGS ARE SET, THAT UNDER THE OEMS THAT UNDERSTAND HOW THE PLANTS ARE WORKING, ACTUALLY PROVIDING THOSE MODELS TO US, PROVIDING 'EM TO THE RE AND THEN PROVIDING 'EM TO US AND MAKING SURE THAT THINGS AREN'T BEING TUNED IN THE PLANT DIFFERENTLY THAN WHAT THEY'RE, THEY'RE SET UP TO DO.
AND THERE NEEDS TO BE INCENTIVE TO DO THAT.
THERE'S ALREADY A REQUIREMENT THAT THEY DO IT, BUT IT'S NOT HAPPENING TODAY.
AND SO THAT'S, THAT'S REALLY THE KIND OF THE UNDERLYING ROOT PROBLEM IS THAT IT, IT'S NOT THAT WE CAN'T SIMULATE THIS STUFF, IT'S THAT WE DON'T, AND JUST BACK TO WHAT WOODY SAID, I DON'T WANNA FIND OUT, I DON'T WANNA HAVE TO WAIT TO FIND OUT THESE THINGS ARE WRONG AFTER WE'VE HAD AN EVENT.
I MEAN, THAT SHOULDN'T BE, WHEN YOU FIND OUT THAT YOU DON'T HAVE THE RIGHT PARAMETERS, YOU'VE GOTTA FIND OUT AHEAD OF TIME.
THERE'S GOTTA BE SOME RIGOR AROUND PROVIDING THOSE MODELS SO THAT THEN OUR SIMULATIONS AND OUR ASSESSMENTS WORK.
AND SO THAT'S REALLY THE, THE, THE KEY THING IS TO MAKE SURE THAT WE'RE DOING THAT IN ADVANCE AND NOT WAITING FOR,
[01:15:01]
YOU KNOW, THE BIG ANALOG SYSTEM TO, TO TELL US THAT IT'S WRONG.WE HAVE ERIC AND THEN I THINK WOODY AGAIN.
UM, AND I THINK WE'RE GONNA GET MORE INTO THIS, UH, IN A LATER PRESENTATION.
UM, BUT IN ADDITION TO THIS MODELING CONVERSATION, I JUST WANNA PROVIDE THE CONTEXT THAT AFTER THESE EVENTS LIKE, UH, JOHN RUSS WAS ASKING ABOUT, THERE HAVE BEEN SOME SOFTWARE AND SETTINGS CHANGES THAT HAVE BEEN MADE IN RESPONSE TO THE EVENTS AND LESSONS LEARNED.
AND, UM, THIS NOER IN THE TAC REPORT WILL REQUIRE THAT TO HAPPEN ACROSS THE BOARD.
UM, SO YES, THE MODEL MODELING PROCESS IS AN AREA FOR IMPROVEMENT, UM, BUT NOGA 2 45 ADDRESSES THAT.
AND, UM, WE KNOW THAT EVEN THOUGH THERE ARE UNKNOWNS ABOUT THE FUTURE, LIKE I I AGREE WITH YOU WOODY, UM, THERE, WE DO KNOW AND HAVE EVIDENCE THAT WE'VE ADDRESSED THE KNOWN KNOWNS OR WE'RE IN THE PROCESS OF ADDRESSING THE KNOWN KNOWNS.
WOODY, DID YOU WANNA COMMENT AGAIN? YEAH, JUST REAL BRIEFLY, JUST REAL BRIEFLY.
UM, I JUST WANT TAC TAC MEMBERS TO KEEP THAT IN MIND AS WE THINK ABOUT THE OVERALL RELIABILITY IMPACT OF HOW THESE STANDARDS ARE SET.
THAT IF ERCOT COULD GIVE YOU A COMPLETE RELIABILITY ANALYSIS OF EXACTLY THE, THE, UH, THE, THE, THE TACK VERSION VERSUS THE ERCOT VERSION, HERE'S THE EXACT RELIABILITY IMPACT, HERE'S THE EXACT RISK THAT, THAT YOU'RE WILLING TO ACCEPT.
BUT THAT IS NOT A POSSIBILITY TODAY THAT CAN'T BE DONE TODAY.
AND SO YOU MAY HEAR THIS LATER TODAY THAT, UH, ERCOT HAS NOT PRODUCED STUDIES TO QUANTIFY THE RISK.
AND SO I, I THINK I JUST REALLY THINK THAT'S AN IMPORTANT THING TO, UM, TO KEEP AT THE, AT THE FRONT OF YOUR MIND AS WE TALK THROUGH THESE THINGS TODAY.
YEAH, VERY BRIEF, JUST AS A FACT, AND ERCOT PRESENTED THIS AT I-B-R-W-G, BUT TWO YEARS LATER, WHILE WE HAVE, UH, WORKED WITH ENTITIES TO IMPLEMENT, UH, CERTAIN CHANGES SPECIFICALLY FOR THE ODESSA UNITS, UM, TWO YEARS LATER, IT'S PROBABLY ABOUT A FOURTH OF THEM THAT HAVEN'T UPDATED THEIR MODELS YET.
WE STILL HAVEN'T RECEIVED UPDATED MODELS.
AND THAT'S, THAT'S PART OF THE CHALLENGE TOO, IS THE TIMELINESS.
AND I THINK ONE FURTHER COMMENT, WE'LL, WE WILL TALK MORE ABOUT SOME OF THE WIND EVENTS IS THERE ARE SEVERAL WIND EVENTS WHERE ERCOT WAS TOLD WERE EXEMPTED.
UM, WE'RE NOT GOING TO INVESTIGATE ANY TYPE OF IMPROVEMENTS.
SO THERE ARE A LOT OF EVENTS WHERE WE TRY TO LOOK AT WAYS OF MITIGATING IT.
WE WERE TOLD THANKS, BUT NO THINGS.
AND SO THERE IS SOME LEVEL OF UNMITIGATED RISK AND RELIABILITY ISSUES THAT HAVEN'T BEEN ADDRESSED.
UM, I WAS JUST TRYING TO UNDERSTAND WHAT HE, UH, THAT LAST COMMENT A LITTLE MORE.
YOU'VE SAID THAT, UM, PEOPLE MIGHT SAY THAT ERCOT HASN'T DONE ANY STUDIES TO QUANTIFY THE RISK.
I WAS JUST TRYING TO UNDERSTAND, IS THE REASONING THAT ERCOT IS NOT ABLE TO DO THOSE STUDIES BECAUSE, UM, THE MODELING INFORMATION IS ACCURATE OR BECAUSE IT CAN'T QUANTIFY HOW MANY RESOURCES ARE IN NON-COMPLIANCE? CAN YOU, I JUST NEED TO UNDERSTAND THAT A LITTLE BIT MORE.
I THINK IT'S A COMBINATION OF BOTH THOSE THINGS.
I MEAN, IF YOU LOOKED AT WHAT WE HAD ON OUR, ON OUR DESK BEFORE THE ODESSA EVENT, AND IF THAT SAME LOW VOLTAGE EVENT HAD OCCURRED, WE WOULD NOT HAVE BEEN ABLE TO ANTICIPATE WHAT HAPPENED IN ODESSA ONE OR ODESSA TWO.
THAT WOULDN'T HAVE HAPPENED USING THE INFORMATION THAT WE HAD
AND THAT LEADS TO THE QUESTION, WHAT'S THE NEXT EVENT THAT WE'RE NOT GONNA BE ABLE TO PREDICT? BECAUSE WE DON'T HAVE THE DATA, WE DON'T HAVE THE MODELS, OR WE DON'T HAVE THE MODELS WITH THE CORRECT INFORMATION INSIDE 'EM.
[01:20:01]
THAT, HOW CAN, HOW CAN 2 45 SOLVE THAT IF, IF YOU'RE CHASING THINGS THAT YOU'RE NOT SURE HOW THINGS WILL REACT? WELL, I THINK THAT'S PART OF 2 45.I MEAN, IT TALKS ABOUT THAT THE TSP OR THE THE RES WILL PROVIDE ACCURATE MODELS.
AND SO AN EMPHASIS ON THAT, AND MY POINT TODAY WAS TO MAKE SURE THAT TAC MEMBERS ARE AWARE AS YOU EVALUATE THE OPTIONS HERE OF WHAT THE INFORMATION IS IN YOUR HAND.
SO IT'S, I THINK IT'S IMPORTANT FOR TAC TO JUST REALIZE WHEN YOU'RE LOOKING AT THIS STUFF IS WHAT WE'RE, WHAT THE TOOLS ARE, WE HAVE TO ACTUALLY EVALUATE THE RISK AND THAT THERE'S A LOT OF UNCERTAINTY IN THE MODELS THAT WE'RE BEING GIVEN NOW.
NOW I AGREE WITH ERIC, WE'RE THEY'RE GETTING BETTER.
UM, AND, UM, IT'S A FAST MOVING, I MEAN, NEW INVERTERS, NEW TECHNOLOGY, NEW SOFTWARE SOLUTIONS, THAT STUFF IS MOVING PRETTY QUICKLY.
AND SO IT'S, IT'S SOMEWHAT UNDERSTANDABLE THAT YOU'RE GONNA HAVE SOME UNCERTAINTY THERE, BUT TAC MEMBERS NEED TO FACTOR THAT INTO YOUR DECISIONS THAT WE'RE A LONG WAYS AWAY FROM HAVING THE CERTAINTY WE HAVE WITH SYNCHRONOUS UNITS.
AND SO THAT NEEDS TO BE PART OF YOUR CALCULATION TODAY WHEN, AS YOU THINK ABOUT THE OPTIONS THAT ARE BEING PUT IN FRONT OF YOU, I'M GONNA ASK A QUICK FOLLOW UP TO THAT.
THE, SO THE, THE PROBLEM WITH HAVING A LACK OF ACCURATE MODELING AND, AND THEN BEING ABLE TO NOT HAVE ACCURATE DATA OR STUDIES THAT, THAT YOU WANTED TO LEVEL SET TACK WITH AND, AND CORRECT ME IF I'M WORDING THAT INCORRECTLY, WHAT HE, IS THERE ANOTHER AREA COMPARABLE TO, TO THIS RIDE THROUGH REQUIREMENTS WHERE, WHERE ERCOT SEEN AN ISSUE LIKE THAT, THAT WE'VE TACKLED IN THE PAST? SO WEATHERIZATION MIGHT BE A, MIGHT BE ONE THAT WE THINK ABOUT, AND THERE'S SOME, SOME SIMILARITIES WITH WEATHERIZATION AND SOME DIFFERENCES.
THE DIFFERENCE WITH WEATHERIZATION IS THAT YOU CAN SEND AN INSPECTION CREW OUT TO MEASURE THE AMOUNT OF INSULATION OR THE WEATHER STRIPPING OR, OR THE WIND BREAKS, THINGS LIKE THAT.
AND SO THERE IS AN ACTUAL PHYSICAL WAY OF LOOKING AT HOW WELL THE WEATHERIZATION, WE COULD CALL IT A MODEL OF A FOR A PLANT HAS BEEN IMPLEMENTED.
WE DON'T HAVE THAT EQUIVALENT WITH THE STABILITY MODELING.
YOU ACTUALLY HAVE TO WAIT FOR AN EVENT, LOOK AT PMU DATA, THINGS LIKE THAT.
AND SO THAT MIGHT BE A, UH, YOU KNOW, WEATHERIZATION WAS A RETROACTIVE, UH, STANDARD THAT CAUSED GENERATORS TO HAVE TO SPEND MONEY TO ACHIEVE A RELIABILITY CENTER.
AND, UM, THAT'S, THAT'S, THAT'S THE ANALOGY THAT COMES TO MY MIND.
AND THERE'S PROBABLY NOT LIKE A SAFER, REASONABLE WAY TO HAVE SOMEONE GO OUT AND TEST.
WHAT WOULD THE PERFORMANCE WOULD BE LIKE? I'M NOT AWARE OF, OF HOW YOU WOULD SAY HOW YOU WOULD DO THAT.
FIRST I WANT TO THANK THE TRE STAFF AT THAT, THAT PRESENTATION ABOUT THE STUDIES AND STANDARDS IS REALLY HELPFUL FOR ME FOR CONTEXT.
I'VE BEEN LOOKING FOR SOMETHING LIKE THAT FOR A, A LONG TIME IN THIS PROCESS.
SECONDLY, I I, I AM REALLY TRYING TO BE OPEN-MINDED IN THIS DISCUSSION AND, AND LISTEN TO AND, AND UNDERSTAND AND RESPECT THE OPINIONS OF EVERYBODY AND THE INFORMATION THAT'S BEEN PRESENTED.
AND SO I'M, I'M REALLY FOCUSED NOW ON THIS STUDIES ISSUE BECAUSE WE CLEARLY HAVE COMMON GROUND.
WE CLEARLY HAVE COMMON GROUND ON THE IMPORTANCE AND NEED FOR IMPROVEMENT OF STUDIES.
AND I HEARD DAN SPECIFICALLY SAY THAT WE HAVE AN ISSUE WHERE MODELS PRESENTED TO ERCOT DO NOT REFLECT SETTINGS IN FACILITIES.
AND I HEARD STEVEN SPECIFICALLY SAY 25% OF THE FACILITIES HAVE NOT UPDATED THEIR MODELS.
WE HAVE CONSENSUS, THIS IS IMPORTANT, AND THESE PROBLEMS ARE FIXABLE.
SO WHY DON'T WE FOCUS ON THE PROBLEMS, THE FUNDAMENTAL PROBLEMS THAT ARE FIXABLE, AUDITS, INSPECTIONS, ALL THE OTHER THINGS THAT WE CAN DO TO ASSURE THAT MODELS ARE ACCURATE OF THE SETTINGS AND THAT MODELS GET DONE.
LET'S, UH, TAKE THE STEPS IN THIS NOER
[01:25:01]
OR OUTSIDE OF THIS NOER TO MAKE SURE THAT THINGS THAT ARE KNOWN CONSENSUS AND FIXABLE GET FIXED.AND I WOULD LIKE TO COME OUT OF TODAY WITH AN AGREED LIST OF CONS, CONSENSUS.
UM, AND, AND KIND OF ECHOING SOMETHING BOB SAID EARLIER, YOU KNOW, MODELS AREN'T ALWAYS GONNA BE PERFECT, BUT, UH, AGREE THEY HAVE TO BE USEFUL AND, AND SO THE POINT'S WELL TAKEN THAT, YOU KNOW, DAN, LIKE YOU SAID, IF THERE'S, IF THERE IS PROTECTION EQUIPMENT THAT'S NOT EVEN INCLUDED IN THE MODEL, THAT'S THAT'S A BIG GAP THAT, THAT, THAT, THAT, I CAN'T SEE WHY WE SHOULDN'T BE, UH, FOCUSED ON THAT.
BUT, UH, I AM CURIOUS BECAUSE, YOU KNOW, STEVEN, WHEN YOU SAY THAT 25% OF THE, UH, THE ODESSA IMPACTED UNITS HAVEN'T UPDATED THEIR MODELS, I'M JUST CURIOUS WHAT THOSE RESOURCES HAVE RELAYED THE, THE HOLDUPS ARE, OR, YOU KNOW, ARE THERE BOTTLENECKS WITH, UH, MODELING CONSULTANTS? IS IT ISSUES WITH THE, LIKE OEM SUPPORT? UM, YOU KNOW, WHAT DO YOU MENTION? THIS IS A NEW TECHNOLOGY THAT'S DEVELOPING RAPIDLY AND, UH, I UNDERSTAND MY UNDERSTANDING IS THAT, UH, INVERTERS DON'T HAVE, UH, YOU KNOW, QUITE THE LIFESPAN OF, OF SUPPORT AS MAYBE SOME OF THE SYNCHRONOUS MACHINES DO, UH, ONCE THEY MOVE ON TO NEW ITERATIONS OR AN OEM GOES OUTTA BUSINESS, FOR EXAMPLE.
SO, UH, CAN Y'ALL SPEAK TO, TO WHAT SOME OF THOSE ISSUES HAVE BEEN? UM, ALL I CAN SAY AT THIS POINT IS THE ERM AND AND COMMISSION STAFF ARE, ARE FOLLOWING UP ON, ON THESE.
AND BECAUSE OF THAT, THERE'S A CONFIDENTIALITY AROUND IT.
I CAN JUST SAY WE'VE REPEATEDLY OUTREACHED FOLLOWED UP.
UH, WE'VE GONE ABOVE AND BEYOND TO TRY TO EDGE THESE THINGS ALONG AND IT JUST GETS TO A POINT WHERE WE HAVE TO LET IT GO THROUGH THE REST OF THE PROCESS.
ARE YOU GOOD? ARE YOU GOOD? YOU'RE STRUGGLING.
OKAY, LET'S GO TO KEN, KEN, DON HILL WITH ADVANCED POWER LINES.
A AGAIN, THIS IS BRINGING BACK YEARS AGO WE HAD THE SAME ISSUES.
IT ALWAYS COMES DOWN TO THE MODELS AND, UM, THE DIFFICULTY AROUND THE MODEL DEVELOPMENT, PARTICULARLY IN THE OPERATING ENVIRONMENT.
WOODY, REMEMBER MANY YEARS AGO WHEN PLANNING MODELS WERE SEPARATE FROM OPERATING MODELS AND WE JOINED THE TWO TOGETHER AND WE HAD A LOT OF PAINFUL MODELING ISSUES, GETTING THE PLANNERS TO RECOGNIZE THEIR OPERATIONAL DIFFERENCES.
THAT'S KIND OF WHY I'M FOCUSING ON TSA MODELS AND ACTUAL OPERATIONAL RESPONSE BACK.
UM, THERE ARE ALWAYS DIFFERENCES BETWEEN THE ANALOG WORLD, WHICH I CALL PLANNING AND THE DIGITAL WORLD, WHICH I CALL ACTUAL OPERATIONS.
AND THE SETTINGS AND THE MODELS THAT WE SET UP ARE BASED UPON CERTAIN ASSUMPTIONS IN OPERATIONS.
YOU'RE GONNA SEE MANY MORE SITUATIONS THAN YOU WILL EVER SEE IN THE ACTUAL PLANNING ENVIRONMENT.
SOUNDS LIKE TO ME, WE NEED TO HAVE MORE OF AN EFFORT AROUND GETTING THOSE OPERATIONAL MODELS BETTER AND THEN TRY TO FEED THAT BACK INTO THE PLANNING PROCESS AND IF IT ACTUALLY MEETS SOME OF THESE EVENTS.
SO THAT'S WHY I THINK SOMETIMES WE NEED TO FOCUS A LITTLE BIT MORE ON IT, BUT ALSO HAVE THE OPERATIONAL FEEDBACK.
BUT IT'S EXTREMELY DIFFICULT DEVELOPING THOSE MODELS.
UH, I WAS TALKING WITH SEVERAL OF THE CONSULTANTS JUST EARLIER THIS WEEK ON HOW WE'RE GONNA TRY TO TACKLE THIS.
IT'S A LOT OF HEAD SCRATCHING GOING ON.
SO, AND THAT'S WHY I'M TRYING TO FOCUS ON THE OPERATIONAL ENVIRONMENT AND THE FEEDBACK FROM TSA.
THANK YOU DAVE RY WITH ENERGY.
UM, I JUST WANTED TO MAKE A CLARIFYING COMMENT HERE AS WE'RE TALKING ABOUT MODELING AND, AND THE DATA AVAILABLE FOR UNDERSTANDING RISK AS IT APPLIES TO, TO THIS ISSUE ON A FORWARD LOOKING BASIS.
I THINK WE ALL AGREE, RIGHT? THE, OF THE IMPORTANCE OF HAVING ACCURATE MODELS AND THE TAC APPROVED VERSION REQUIRES, AS ERIC POINTED, ERIC K POINTED OUT, YOU HAVE TO FILE A MODEL THAT ACCURATELY REFLECTS THE LIMITATIONS.
AND TO THE EXTENT THAT THERE ARE THINGS THAT CANNOT BE REFLECTED IN A MODEL JUST BY THE NATURE OF THE TYPE OF LIMITATION, THEN YOU HAVE TO PROVIDE INFORMATION ON THAT AS WELL.
AND THEN I UNDERSTAND THAT WITHIN ERCOT, RIGHT, THERE WAS PGRR 1 0 9 SPECIFICALLY ADDRESSES SOME OF THESE MODELING ISSUES.
AND I BELIEVE THAT WAS EFFECTIVE AS OF THE FIRST OF THIS MONTH.
SO I DON'T THINK THERE'S ANY DISA DISAGREEMENT ABOUT THAT.
UM, I THINK THE QUESTION HERE IS WHAT STANDARD OF EVIDENCE IS GOING TO BE APPLIED TO
[01:30:01]
ERCOT CLAIMS ABOUT WHAT IS NECESSARY FOR RELIABILITY AND WHETHER, AND HOW THAT'S DIFFERENT THAN WHAT THE TAC UH, REPORT ACHIEVES, RIGHT? AND SO IT'S TRUE ON THE ONE END, IN A PERFECT WORLD, YOU WOULD HAVE A SYSTEM LEVEL MODEL WHERE YOU CAN SIMULATE EVERYTHING, RIGHT? AND THEN SAY, HERE'S THE PRECISE LEVEL OF RELIABILITY AND HOW IT CHANGES WITH, UH, VARIOUS PROPOSALS.BUT I THINK THERE, JUST BECAUSE WE CAN'T REACH THAT PERFECT STANDARD DOESN'T MEAN THAT WE KIND OF, THERE, THERE ISN'T OTHER EVIDENCE THAT SHOULD BE BROUGHT TO BEAR, UH, TO JUSTIFY COMMENTS ABOUT RELIABILITY AND RISK.
UM, I THINK ON THE WEATHERIZATION FRONT, RIGHT? I MEAN, THAT'S A TRICKY ANALOGY TO MAKE.
AND, BUT EVEN THERE, I MEAN, THE WEATHERIZATION STANDARDS WERE PROCEEDED BY, YOU KNOW, DETAILED WEATHER, UM, DATA ANALYSIS OF LIKE HISTORICAL WEATHER EVENTS BY REGION WITHIN ERCOT TO SET THE APPROPRIATE STANDARD.
AND IT VARIED, RIGHT? SO AGAIN, I DON'T WANNA PUSH THAT ANALOGY TOO FAR, BUT I THINK THAT'S WHAT WE'RE REALLY TALKING ABOUT.
SO AS WE TALK LATER IN THE, YOU KNOW, AS ERCOT PRESENTS AND, AND AS THE JOINT COMMENTERS PRESENT, I THINK THAT'S THE DISTINCTION THAT WE'RE DRAWING HERE IN TERMS OF WHAT EVIDENCE DO WE NEED BEYOND JUST, UM, AN A HISTORICAL RECORD OF EVENTS, RIGHT? AND ACKNOWLEDGING THAT THOSE EVENTS IN MANY CASES, MITIGATION MEASURES HAVE PUT IN PLACE.
AND THEN THE FINAL COMMENT JUST ON THE, ON THE MODELING, AND AGAIN, NOT TO, I THINK HAVING THE UPDATED MODEL WAS OBVIOUSLY IMPORTANT AND NO ONE DISAGREES.
I GUESS JUST LOOKING AT ERCOT SUMMARY OF THE POST ODESSA EVENT IMPROVEMENTS, I MEAN, I'M LOOKING AT ONE OF THE SLIDES THAT JUST HAS T MIC AND THERE OF THE, I THINK IT'S EIGHT PLANTS, TWO HAVE MODEL UPDATES SUBMITTED AND THE REST DON'T.
UM, BUT ALL OF THEM HAVE COMPLETED, UH, THE UPGRADES IN THE FIELD AS OF MARCH.
SO AGAIN, THERE'S, THERE'S STILL IMPROVEMENT EVEN IF THE MODEL UPDATES ARE STILL PENDING.
OKAY, ERIC, UM, JUST REAL BRIEFLY, ONE OTHER, I THINK OBVIOUS, BUT JUST FOR THE RECORD FACT ABOUT THE WEATHERIZATION CHANGES IS WHAT LED TO THAT WAS A CHANGE IN LAW, UH, THAT THE LEGISLATURE PASSED AND SAID TO DO THAT SPECIFIC THING.
SO I DON'T KNOW IF WE NEED TO GET FURTHER INTO IT, BUT JUST WANNA POINT IT OUT.
I THINK WE'RE GONNA GET FURTHER INTO IT.
ONE LED TO IT WAS A RELIABILITY EVENT.
I MEAN, UNDERLYING FOR THE TECHNICAL ADVISORY COMMITTEE, IT WAS A REACTION TO A RELIABILITY EVENT.
SO THIS IS A CHANCE TO BE PROACTIVE.
AND I THINK WE, WE, WE ARE BEING THAT WAY, BUT WE, I DON'T WANT TO GET A BACK AND FORTH THAT'S NOT PRODUCTIVE.
UM, I, I WAS ONLY TRYING TO MAKE A POINT JUST FROM A, A LEGAL PERSPECTIVE AND NOT A RELIABILITY PERSPECTIVE.
ONE QUESTION FOR STEVEN, SO IS MAYBE I MISSED WHAT HE SAID EARLIER.
SO, SO HOW MANY GIGAWATT THAT NEED, UH, EXCEPTION FOR THIS PROCESS, IS THAT TWO GIGAWATT OR SOMETHING THAT YOU SPOKE LAST DECK IS, IS, IS THAT STILL THE CASE? I, I THINK YOU'RE ASKING HOW I CAME UP WITH THE KIND OF TWO TO FOUR GIGAWATT ESTIMATES.
OH, GO AHEAD WITH YOUR QUESTION.
SO IS THAT A TWO GIGAWATT NEED, UH, EXCEPTION AT THIS TIME, OR, UH, I MEAN, I HEAR THAT LAST TIME IN THE ATTACK, BUT, UH, I, I HAVEN'T FOLLOWED AFTER THAT.
IS THAT STILL THE CASE OR THE THINGS HAVE BEEN CHANGED ALREADY? SO THE, WITH THE ERCOT VERSIONS THAT WE PROPOSED, WE HAD CERTAIN LANGUAGE IN THERE THAT ASSURED WE WOULD BE ABLE TO DO A RELIABILITY RISK ASSESSMENT.
WE WOULD HAVE GUARDRAILS WITH THOSE ASSUMPTIONS AFTER SPEAKING WITH THE OEMS. AND AFTER WE HAD FURTHER LOWERED THE LEGACY REQUIREMENTS TO WHERE WE PROPOSED THE ESTIMATE WAS TWO TO FOUR GIGAWATTS OF EXEMPTIONS NEEDED.
AND THEN WITH THE RFI RESULTS, THERE WAS ABOUT ANOTHER GIGAWATTS.
SO THAT'S HOW WE CAME UP WITH THOSE ESTIMATES.
THE TAC APPROVED VERSION, UH, REMOVED THOSE GUARDRAILS.
AND SO THERE IS UNCERTAINTY TODAY ON HOW MANY EXEMPTIONS WOULD BE APPLIED WITH THE TAC APPROVED VERSION.
AND WE WILL DISCUSS ALL OF THIS IN MORE DETAIL IN
[01:35:01]
DAN'S PRESENTATION.I THINK, UH, IEEE UH, PRESENTATION IS STILL, UH, I THINK WE'RE WAITING THAT THING, UH, JUST WANTED TO KNOW IN A VERY CLEAR PICTURE WITH THAT, UH, I MEAN, APPLICATION OF THIS IEEE AT THE END OF THE DAY, HOW MANY IBR AND WGR WILL BE RETIRING? THAT IS MY FUNDAMENTAL QUESTION.
I'M, I'M WAITING SINCE LONG AND I HOPE, UH, ANY, ANY OF YOU WILL ANSWER THAT, THAT THING TODAY.
I'M, I'M, I'M WAITING FOR THAT.
OKAY, DAN? YEAH, I'M, I'M GONNA TRY TO PUT A BOW ON THIS
'CAUSE TE IS ESSENTIALLY STILL UP AT THE STAND.
I THINK WOODY'S POINT IN BRINGING THIS UP ORIGINALLY IS A GOOD ONE, UH, THAT, YOU KNOW, WE'RE, WE'VE HEARD SOME STUFF THAT, WELL, ERCOT HASN'T PROVED WE GOT A RELIABILITY PROBLEM.
AND HIS POINT WAS WE CAN'T REALLY MAKE THAT, WE CAN'T REALLY PROVE THAT USING SIMULATION BECAUSE WE DON'T HAVE GOOD MODELS FROM THE RESOURCE ENTITIES TO DO THAT.
BUT THAT, I DON'T WANT TO LEAVE ANYBODY WITH THE IMPRESSION THAT IMPROVE MODELING WOULD FIX EVERYTHING THAT WE'RE TRYING TO FIX IN NOGA 2 45.
BUT I THINK THE, THE POINT WHEN WE COME TO THAT THIS AFTERNOON, WE, WE, WE WILL NEED TO, TO TALK ABOUT THAT, BUT WE NEED TO GET ON WITH SOME OF THE OTHER PRESENTATIONS.
AND, AND THAT'S EXACTLY RIGHT.
I THINK WE'VE BEEN HAVING A DISCUSSION AROUND THE MODELING AND, AND HOW THAT RESULTS IN, IN NOT BEING ABLE TO GET DATA ON CERTAIN SCENARIOS.
BUT WE DO HAVE SEVERAL OTHER PRESENTATIONS, UM, AND HOPING NOT TO RE REPEAT THE SAME CONVERSATIONS OVER AND OVER.
[5. IEEE2800 and Adoption in Other Jurisdictions, IEEE2800.2]
JULIA, ARE YOU READY TO PRESENT FOR US? ALL RIGHT.UH, MY NAME IS JULIA VOS AND I'M HERE AS A SET OF CHAIRS
I'LL BE PRESENTING AS, UH, ERCOT, I-B-R-W-G CHAIR.
UH, I ALSO CHAIR A SUBGROUP IN I AAA 2800.2, AND I'LL TELL YOU IN A MINUTE WHAT THAT IS.
UM, AND THEN I ALSO CHAIR NEURO CONVERTER BASED RESOURCE PERFORMANCE SUBCOMMITTEE.
SO THAT'S BASICALLY SIMILAR SCOPE AS I-B-R-W-G, BUT AT NRC LEVEL, UM, SUBCOMMITTEE FOCUSING ON PERFORMANCE OF INVERTER BASED RESOURCES.
ALRIGHT, SO, UH, 2800.2 STANDARD.
I JUST WANTED TO RECAP SO WE, YOU KNOW, ALL KNOW ON THE SAME PAGE HOW IT CAME TO BE.
UM, THE STANDARD HARMONIZES CENTRAL CONNECTION REQUIREMENTS FOR WIND, SOLAR, AND STORAGE PLANTS.
SO ALL IN EB BASED RESOURCE PLANTS CONNECTING TO SUB TRANSMISSION AND TRANSMISSION LEVEL.
AND THE STANDARD WAS DEVELOPED BY, UM, SMES, UM, IN WORKING GROUP OF ABOUT 175 SMES, UH, REPRESENTING DEVELOPERS, GENERATOR OWNERS, UH, MANUFACTURERS, RESEARCH ORGANIZATIONS, SYSTEM OPERATORS, TRANSMISSION PLANNERS.
UH, THEY WORKED FOR TWO YEARS.
UH, STANDARD HAS BEEN APPROVED WITH A REALLY HIGH APPROVAL RATE, WHICH IS UNUSUAL FOR THIS TYPE OF MASSIVE STANDARD 94% APPROVAL, UH, 90% RESPONSE RATE.
UH, IT WAS PUBLISHED IN APRIL, 2022, AND I BELIEVE ORCO STARTED LOOKING AT, UM, KIND OF GAP ANALYSIS AND BENEFITS OF THE STANDARD IN ORCO AREA IN MAY, JUNE, UH, 2022 TIMEFRAME.
UH, THE STANDARD IS NOT ENFORCEABLE, SO IT'S ONLY ADOPTED IF, UH, THERE IS A, UM, A BODY WITH JURISDICTION IN THE AREA THAT ADOPTS THE STANDARD AND THEN IT BECOMES A STANDARD IN THAT AREA.
UM, SO WHERE WE ARE TODAY IN TERMS OF ADOPTION, UH, THERE ARE THREE TYPES OF HOW PEOPLE ADOPT THE STANDARD.
UH, GENERAL REFERENCE IS BASICALLY WHERE THEY SAY IN THE DOCUMENTATION, THOU SHALL BE 2,800 AND THIS IS IT.
THEY JUST REFER TO 2,800 DOCUMENT.
UH, DETAILED REFERENCE IS WHERE THEY PICK, UH, CLAUSES OF 2,800, UH, AND PUT IT IN THEIR OWN, UM, INTERCONNECTION REQUIREMENTS.
UH, IN FULL SPECIFICATION IS WHERE PEOPLE LIFT LANGUAGE FROM 2,800 AND PUT IT IN THEIR OWN REQUIREMENTS.
I THINK THIS LAST VERSION, THIS LAST OPTION IS NOT NECESSARILY RECOMMENDED BECAUSE, UM, A LOT OF THINGS ARE LOST IN TRANSLATION AS, UM, EXPERIENCE IS SHOWING.
SO WHAT YOU SEE IN GREEN ARE AREAS THAT ALREADY ADOPTED 2,800, AND YOU CAN SEE IN WHICH CATEGORY OF ADOPTION THEY ARE FALLING, UH, IN YELLOW THERE, THESE ARE AREAS THAT ARE STILL WORKING ON ADOPTION OF 2,800.
UM, AND, AND KOTT, YOU SEE THEY STARTED AS A FULL SPECIFICATION, BUT I THINK NOW IT'S KIND OF MOVED TOWARDS DETAIL REFERENCE WHERE IT REFERS
[01:40:01]
TO CLAUSES OF 2,800, UH, IN PARTS OF THE REQUIREMENTS.UH, IF WE LOOK AT ADOPTION PROCESS, UM, WE CAN SEE KIND OF A PATTERN THERE.
SO BASICALLY PEOPLE ARE LOOKING, DO THEY HAVE EXISTING REQUIREMENTS IN THE AREA? AND IF THEY DO, THEN UH, THEY EITHER GO WITH ADOPTION BY DETAIL REFERENCE OR BY FULL SPECIFICATION.
THEY DO GAP ANALYSIS AND PRIORITIZATION OF DIFFERENT REQUIREMENTS, MAKE A DECISION ON APPLICABILITY DATE, UM, AND, AND THEN ADD EXISTING REFERENCES TO 2,800 TO THE DOCUMENTS OR DEVELOP NEW LANGUAGE IN THE DOCUMENTS THAT REFLECTS 2,800 REQUIREMENTS.
UH, AND THEN, UH, THEY GO ON AND DEVELOP, UH, TESTING SPECIFICATIONS FOR, UH, TESTING CONFORMITY, IT WAS 2,800.
THOSE WHO DON'T HAVE DETAILED REQUIREMENTS IN THE AREA USUALLY GO WITH GENERAL REFERENCE AND THEY JUST SAY, THOU SHALL BE 2,800.
UM, AGAIN, MAKE A DECISION ON APPLICABLE DATE.
UM, MAKE A REFERENCE 2,800 IN THE DOCUMENTS.
UM, AND THEN GENERALLY THEY DECIDE TO WAIT UNTIL 2800.2 IS PUBLISHED.
AND I'LL TELL YOU IN A SECOND WHAT 2800.2 IS.
UH, THIS IS JUST, UM, ANOTHER EXAMPLE OF MISO ADOPTION PROCESS.
UH, SO THEY WENT BY DETAILED, UH, FERENCE DETAILED SPECIFICATIONS.
SO THEY, UM, SORRY, UH, GIMME A SEC.
YEAH, DETAILED REFERENCE THAT'S CALLED.
UM, AND THEY, UH, DETERMINED WHICH PARTS OF 2,800, UM, SHOULD BE APPLICABLE TO WHAT, WHAT, WHAT IS IN MISO JURISDICTION.
THE FIRST SET OF PRIORITIES GOT ADDRESSED IN, UH, LAST YEAR, AND IT'S ALREADY PUT IN THE DOCUMENTATION, AND NOW THEY'RE WORKING ON THE SECOND PHASE OF PRIORITIES.
UM, SO THE FIRST PHASE INCLUDED VOLTAGE RIGHT THROUGH FAST REACTIVE CURRENT INJECTION FREQUENCY, RIGHT THROUGH PHASE JUMP RIGHT THROUGH, UM, ENTER SERVICE AND MEASUREMENT ACCURACY.
SO THESE ARE REQUIREMENTS THAT THEY SAW WERE MORE VITAL, UH, TO IMPLEMENT FASTER IN THE AREA.
NOW THEY'RE FOCUSING ON REACTIVE POWER RANGE CAPABILITY, VOLTAGE CONTROL, PRIMARY FREQUENCY RESPONSE, UM, AND AGAIN, MEASUREMENT AND MONITORING.
UM, THIS SLIDE IS JUST TO SAY, YOU KNOW WHAT IT IS.
IT'S BASICALLY DEVELOPING RECOMMENDED PRACTICES FOR TESTING AND VERIFICATION PROCEDURES.
UH, FOR INVERTER BASED RESOURCES TO, UH, ESTABLISHED CONFORMITY WAS 2,800.
UM, SO BASICALLY ONCE YOU HAVE THE REQUIREMENT, IT'S NOT IT, YOU ACTUALLY HAVE TO FIGURE OUT HOW YOU'RE GOING TO TEST FOR CAPABILITIES, UM, AND, AND CONFORMITY WITH THIS REQUIREMENT.
UH, SO THE STANDARD, THIS 2800.2, UH, PROCEDURES WILL COVER EVERYTHING FROM TYPE TESTING OF INVERTER UNITS.
SO THIS WILL BE HAPPENING AT THE MANUFACTURER FACILITIES WHERE THEY HAVE LAB TESTS AND THEY TEST SINGLE INVERTERS.
AND THE REASON FOR TESTING IT IS TO DEVELOP SINGLE INVERTER MODEL.
SO I'LL, I'LL STOP A LITTLE BIT ON THE SLIDE HERE BECAUSE WE TALKED ABOUT MODELS IN PREVIOUS CONVERSATIONS OR PROVIDE A LITTLE BIT OF FEEDBACK HERE.
SO ONCE YOU TESTED THE MODEL, THE MODEL OF INVERTER CAN ACTUALLY BE VALIDATED AND YOU CAN ACTUALLY, UM, PRETTY ACCURATELY PRODUCE THE MODEL OF A SINGLE INVERTER.
BUT THEN WHAT HAPPENS, YOU PUT IT TOGETHER IN ONE PLANT, AND THE PLANT MODEL IS USUALLY AN AGGREGATE.
YOU DON'T MODEL EVERY SINGLE INVERTER IN A PLANT.
IF YOU WOULD HAVE, THEN IT WOULD BE MORE ACCURATE MODEL, BUT IT WOULD BE VERY HIGHLY COMPUTATIONALLY AND WOULD NOT BE POSSIBLE TO SIMULATE THE ENTIRE ERCOT EVEN IN PSSC WITH THIS TYPE OF MODELS.
SO THESE MODELS ARE AGGREGATED AND REPRESENT ONE SINGLE INVERTER THAT IS SCALED TO PRESENT ENTIRE PLANT, AND THERE IS AN EQUIVALENT OF COLLECTOR SYSTEM, UH, AND THERE IS A EQUIVALENT OF ANY KIND OF, UH, SUPPORTING EQUIPMENT LIKE REACTIVE COMPENSATION EQUIPMENT AND SOME SUCH.
UH, SO THIS MODEL IS ALREADY KIND OF LIKE LEVELED DOWN IN ACCURACY BECAUSE, UM, IT'S, IT'S LIKE A STEP FROM A SINGLE INVERTER THAT WAS TESTED IN A TEST, UH, TO THIS, UH, AGGREGATED MODEL.
UM, THEN THERE IS, UM, PLANT MODEL, UM, DEVELOPMENT AND PLANT MODEL DESIGN EVALUATION.
SO THIS IS WHERE DEVELOPER AND FUTURE GENERATOR OWNERS WORKING WITH MANUFACTURER, MAKING SURE THAT THE PLANT ITSELF AS DESIGNED IS CONFORMED WITH 2,800.
AND AT THE SAME TIME, THEY ARE AGAIN MODIFYING, UH, PLANT MODEL TO MAKE SURE THAT THE MODEL IS ALSO CONFORMED WITH 2,800.
UH, THEN THERE IS AS BUILT INSTALLATION EVALUATION.
SO THIS IS WHERE, UM, DEVELOPER, UH, COMPARES THE, THE SETTINGS AND EQUIPMENT, UH, AS INSTALLED IN THE PLANT IS ACTUALLY CON UH, CORRESPONDING TO WHAT WAS MODELED IN THE MODEL.
AND AGAIN, THERE IS A CHANCE TO UPDATE MODELS AND SUBMIT TO, UM, TO, UH, ORGANIZATIONS SUCH AS, UH, THEN THERE ARE COMMISSIONING TESTS.
UH, AND AFTER COMMISSIONING TESTS, THERE IS ACTUALLY A CHANCE TO VALIDATE MODELS.
AGAIN, WITH IS JUST SMALL SUBSET OF TESTS.
THESE TESTS ARE ALL SMALL DISTURBANCE TESTS.
SO THEY, THEY ARE NOT REPRESENTATIVE OF ODESSA TYPE EVENT,
[01:45:01]
BUT THEY ARE SMALL VOLTAGE STEPS, UH, SMALL FREQUENCY STEPS TO MAKE SURE THAT IT RESPONDS, UM, AS REQUESTED.UM, AND THEN, UH, POST COMMISSIONING MONITORING.
SO THIS IS A NEW TYPE OF PROCESS THAT IS NOT, PIECES OF IT EXIST HERE AND THERE, BUT THIS PROCESS GENERALLY IS NOT APPLIED TODAY.
AND THIS IS WHERE I THINK THERE IS A REALLY BIG GAP.
UH, AND THIS IS WHERE WE CAN ACTUALLY DO A LOT TO IMPROVE MODELS FOR THE FUTURE.
SO THIS IS THE MEANING OF THIS IS AS THE PLAN BECOMES OPERATIONAL, AS THE CHANGES ON THE PLANS ARE HAPPENING, UPDATES, SOFTWARE UPDATES, UH, HARDWARE UPDATES, ALL OF THIS NEEDS TO FIND ITS WAY BACK IN THE MODELS AS, UM, EVENTS ARE HAPPENING.
UM, THE GENERATOR OWNER NEEDS TO EVALUATE THE MODEL, VALIDATE THE MODEL, AND SUBMIT UPDATED MODEL BACK TO ORCO, FOR EXAMPLE.
SO, SO THIS TYPE OF PROCESS IS NOT THERE TODAY IN 2800 0 2 IS TRYING TO FILL THAT GAP.
BILL, YOU WANNA ASK THE QUESTION NOW IT'S PROBABLY ON THE SLIDE, IS THAT THE ROOT CAUSES TO WHAT WOODY WAS EXPLAINING WHY THE MODELS DON'T REFLECT THE ACTUAL BEHAVIOR IN THE FIELD IS BECAUSE WE CAN'T GET TO THAT LEVEL OF GRANULARITY ON AN INDIVIDUAL INVERTER BASIS.
SO, SO THAT'S ONE OF THE THINGS, UH, BUT I THINK WHAT, WHAT DAN WAS ALSO TALKING ABOUT, UM, THERE ARE PROTECTIVE FUNCTIONS IN INVERTERS.
THIS FUNCTIONS, THEY MAY BE REPRESENTED IN A SINGLE INVERTER EVEN, UH, BUT IT DOESN'T FIND ITS WAY INTO THE ENTIRE PLANT MODEL.
SO THIS IS WHERE IN ACCURACY, UH, CREEPS IN.
UM, AND THEN, YOU KNOW, SOME OF THE SETTINGS AS THE PLANT IS DESIGNED MAY CHANGE FROM, UH, YOU KNOW, OFF THE SHELF INVERTER AND THE SETTINGS AGAIN, ARE NOT UPDATED IN THE MODEL.
SO THIS, AGAIN, WHAT CAN HAPPEN, UH, AND ON WHAT YOU HEAR A LOT, IT'S NOT ONLY IN ROCO, YOU HEAR IN OTHER AREAS BECAUSE INTERCONNECTION PROCESS IS SUCH A, YOU KNOW, BIG DEAL FOR GENERATOR OWNER, THERE IS THIS INCENTIVE IN A WAY TO SUBMIT A MODEL THAT WILL BE ACCEPTED.
AND SO, I MEAN, EVERYBODY TRIES TO DO THEIR BEST, BUT BASICALLY THIS IS, THIS, THE MARKER IS I NEED TO GO THROUGH INTERCONNECTION PROCESS AS FAST AS POSSIBLE, NOT, NOT HAVE ANY DELAYS IN THE PROCESS, AND I SUBMIT A MODEL AS MODEL QUALITY TEST REQUIRES.
UM, BUT THEN THIS, THIS CHECK AS BUILT EVALUATION, ERCOT HAS SOME REQUIREMENTS FOR THAT.
IT'S RELATIVELY RECENT, I BELIEVE MAYBE TWO YEARS AGO THIS REQUIREMENT GOT INTRODUCED THAT THE MODEL HAS TO BE CHECKED WITH AS BUILT SETTINGS, UM, IN SOME OTHER AREAS IT'S NOT BEING DONE EVEN TODAY.
SO, SO THAT'S, THAT'S EXACTLY ANOTHER STEP.
ONE OTHER THING TO MENTION IS THAT THESE MODELS, WHEN THE PLANT, ENTIRE PLANT MODEL IS THERE, IT'S A BLACK BOX MODEL AND ONLY SOME OF THE PARAMETERS OF THE MODEL ARE OPEN TO THE USER OF THE MODEL.
AND, AND ALSO LIKE MANUFACTURER DOESN'T REALLY WANT YOU TO CHANGE MODELS, UM, IN THE STUDY BECAUSE MAYBE IT AFFECTS THE EQUIPMENT DOWN THE LINE, MAYBE IT'S NOT POSSIBLE TO IMPLEMENT THE SETTING CHANGES.
SO THE MODEL IS BLACK BOX, IT ONLY HAS CERTAIN SET OF PARAMETERS THAT ARE VISIBLE TO ERCOT.
SO ERCOT PHYSICALLY ACTUALLY CANNOT CHECK ALL OF THE PARAMETERS OF ACTUAL PLANT WITH THE MODEL.
SO IT WOULD BE ON THE GENERATOR OWNER AND MANUFACTURER SIDE, UM, TO GO AND DO THESE CHECKS AND MAKE SURE THAT THE MODEL CORRESPONDS TO WHAT'S BEEN BUILT IN THE FIELD AND THEN ATTEST TO ORCO AND SAY THIS MODEL IS ACCURATE TO OUR BEST KNOWLEDGE.
ALRIGHT, UM,
UH, CURRENTLY WE'RE WORKING ON 2,802.
WE ARE HOPING TO FINISH, UM, ALL OF THE PROCEDURES BY THE END OF THIS YEAR.
SO AT THAT TIME IT WILL GO TO INDUSTRY COMMON AND THEN TO A BALLOT.
UM, AND THEN AT THE SAME TIME AS I SHOWED, SOME OF THE AREAS ARE ALREADY WORKING ON ADOPTION OF 2,800.
UM, THERE ARE SOME OF THE ONGOING DISCUSSIONS.
SO NOT ALL OF THE QUESTIONS WILL BE EVEN ANSWERED IN 2,800.
AND AS WE WORK ON DEVELOPING TESTS, WE'RE FINDING, UM, SOME CHALLENGES BOTH IN IEE UH, 2800.2, BUT ALSO IN I-B-R-W-G.
UM, AND THESE ARE TECHNICAL DISCUSSIONS AROUND, UM, RIDE THROUGH, UH, ROCK OFF AND VOLTAGE ANGLE PHASE JUMP.
UH, AND IN THIS DISCUSSIONS WE BASICALLY FIGURE OUT IT NOT, IT CANNOT BE RELIABLY MEASURED DURING EVENTS.
UH, SO BASICALLY WHERE WE HAD IT TODAY WITH THIS IS THAT IT SHOULDN'T BE MEASURED AND EQUIPMENT SHOULDN'T BE TRIPPING ON MEASURED ROCK OFF AND MEASURED PHASE JUMP DURING FAULTS BECAUSE THERE IS NO WAY IT CAN BE RELIABLY MEASURED.
SO THE PLAN SHOULDN'T BE TRIPPING ON THAT.
UM, WE'RE STILL WORKING ON HOW TO MEASURE AND CALCULATE ROCK OFF AND FACE JUMP, UH, DURING NON-FAT EVENTS.
AND SO THAT'S ALSO SOMETHING WE'RE WORKING IN I-B-R-W-G, UM, TRYING TO GET ON THE SAME PAGE WITH THAT.
THERE ARE SOME MECHANICAL LIMITATIONS THAT HAVE BEEN PUT INTO 2,800 STANDARD, BUT THERE ARE ALSO THERMAL LIMITATIONS AND SOME, UH, TYPES OF WIND PLANTS,
[01:50:01]
UM, THAT PREVENTS THEM FROM RIDING THROUGH SOME OF THE MULTIPLE WRITE THROUGH EVENTS.AND SO AGAIN, WE'RE DEVELOPING LANGUAGE IN 2,800 AND TRYING TO REFLECT IT IN, UM, I-B-R-W-G DISCUSSIONS, UH, TO HAVE THIS EXEMPTION FOR WIND PLANTS, UH, TRANSCEND NOVA VOLTAGE.
THERE IS A STILL QUESTION HOW TO TEST FOR IT, UH, BOTH AT INVERTER LEVEL AND PLANT LEVEL.
I THINK WHERE WE HEADED WITH THAT IS THAT, UM, KNOWN LIMITATIONS IN THE EQUIPMENT, UH, WILL BE RECORDED.
SO THE, BASICALLY IT'S HARD TO MODEL AND IT'S HARD TO SIMULATE, BUT THERE SHOULD BE, UH, RECORDED CAPABILITY OF EQUIPMENT TO RIDE THROUGH A CERTAIN LEVEL OF, UH, TRANSCEND OVER VOLTAGE.
UM, ANOTHER QUESTION IS A CONFORMITY WITH 2,800.
UM, AS SYSTEM CONDITIONS CHANGE, AND I THINK THIS IS SOMETHING ERCOT NEEDS TO, UM, AS A MARKET NEEDS TO THINK ABOUT AS WELL, IS THAT YOU DEVELOP A PLANT, YOU CONNECT TO CERTAIN AND YOU DEVELOP IT TO CERTAIN EXISTING REQUIREMENT AND YOU CONNECT THE PLANT.
BUT OVER TIME, UM, THE SYSTEM CHANGES, SYSTEM STRENGTHS, CHANGES, UH, SYSTEM CONDITIONS CHANGES.
IS THE EXPECTATION THAT THE PLANT IS ALWAYS CONFORMED WITH REQUIREMENTS AS THE SYSTEM CHANGE OR SHOULD THERE BE A MINIMUM LEVEL OF SYSTEM STRENGTHS THAT SAY, OR COTTON INSURERS AND THEN YOU CAN MAKE SURE THAT THE PLANT IS CONFORMED THROUGHOUT ITS LIFETIME.
SO THAT'S SOMETHING STILL, YOU KNOW, TO TALK ABOUT AND FIGURE OUT.
UH, AND YEAH, BUT ME BEING KIND OF ON THE LEADERSHIP TEAM OF BOTH OF THIS, I'M BRINGING THESE DISCUSSIONS BACK TO KOTT, I-B-R-W-G.
I WANTED TO GO BACK TO FOUR CODE OR 9 0 1, SORRY, FORGOT ONE HERE.
UM, THESE ARE STANDARDS THAT ARE FALLING OUT OF, UH, FOUR CODE OR 9 0 1, UH, SPECIFICALLY APPLICABLE TO THIS DISCUSSION.
SO THERE IS PRC 29, WHICH IS FREQUENCY AND VOLTAGE WRITE THROUGH STANDARD.
UH, IT'S HIGH PRIORITY STANDARD AND TO BE COMPLETED THIS YEAR.
PRC 28 IS FOR DATA MONITORING.
PRC 30, UM, THIS IS AN INTERESTING ONE.
UH, IT'S, UH, THERE WAS A STANDARD BEFORE CALLED PRC 0 0 4, UH, WHICH WAS A PROTECTION STANDARD PROTECTION MIS OPERATION STANDARD.
SO EVERY TIME IT'S OPERATION OF PROTECTION HAPPENS AT A SYNCHRONOUS PLANT OR IT SAYS AT THE GENERATOR ACTUALLY, UH, SO THEN THE GENERATOR OWNER HAS TO FOLLOW UP, UH, AND DEVELOP A MITIGATION PLAN FOR, FOR WHATEVER HAPPENS.
SO DO ROOT CAUSE ANALYSIS AND DEVELOP MITIGATION.
UM, SO THE DIFFERENCE WITH IBR IS THAT NOT ALL AS UNEXPECTED TRIPS ARE A RESULT OF MIS MIS OPERATION OF PROTECTION.
IT MAY BE A PROTECTIVE FUNCTION IN THE INVERTER, BUT IT'S NOT A PHYSICAL PROTECTION DEVICE.
SO WITH THAT, UH, NOC SAW THAT THERE IS A NEED TO DEVELOP A SEPARATE STANDARD JUST FOR IBR.
SO THIS IS PRC 30, UM, AND WHAT THAT'S TRYING TO ACHIEVE, THAT'S EVERY TIME THERE IS AN UNEXPECTED TRIP OF A GENERATOR, THE GENERATOR OWNER HAS TO FOLLOW UP AND MAKE SURE THEY UNDERSTAND WHY THE PLANT TRIP, UH, AND MAKE SURE THAT THEY ADDRESS, UH, WHATEVER HAPPENED AND HAVE MITIGATION PLAN IN PLACE.
I THINK IT'S, IT'S, IT'S A VERY GOOD ONE.
IT WILL MAKE GENERATOR OWNERS ALSO LOOK AT THEIR PLANS AND, AND CONTINUOUSLY FOLLOW UP ON WHAT'S HAPPENING.
UM, AND THEN UOP FOUR, UH, THIS IS EVENT REPORTING STANDARD.
PREVIOUSLY IT'S BEEN FOCUSED ON REALLY, REALLY BIG EVENTS.
AND SO THIS IS, THESE ARE EVENTS ON, BASED ON WHICH NERC THEN DOES EVENT ANALYSIS.
UM, AND CURRENTLY THEY, THEY'RE TRYING TO REDUCE THE THRESHOLDS, UH, THAT, THAT TRIGGER THIS TYPE OF ANALYSIS.
SO BASICALLY IT'S NOT REALLY HUGE IBR EVENTS, BUT MAYBE IT'S LIKE 500 MEGAWATT TYPE EVENTS THAT THAT NRK STARTS LOOKING AT AND ANALYZE AND HOPEFULLY IT, IT, IT LETS US NOT TO LEAD TO HIGHER, LARGER EVENTS.
SO WE ADDRESS ALL THE PROBLEMS EARLY ON AND LARGER EVENTS, UM, DON'T EVEN HAPPEN.
UM, I WOULD SAY I'M, I'M PARTICIPATING IN SOME OF THE STANDARD DRAFTING TEAMS. I'M NOT A MEMBER OF ANY OF THE TEAMS, BUT AS AN OBSERVER, UH, AND I WOULD SAY THE STANDARD DRAFTING TEAMS ARE TRYING TO ALIGN, UH, WITH 2,800 AS MUCH AS POSSIBLE, NERC BASICALLY CANNOT USE 2,800 AS A REFERENCE.
SO THEY, UH, THERE ARE SOME LEGAL ISSUES WITH THAT, THAT I'M NOT, I WILL NOT EVEN TRY TO GO INTO
UH, BUT BASICALLY NARCAN CANNOT JUST REFER TO 2,800.
UH, AND THIS IS ALSO ONE OF THE THINGS IS THEY NEED TO BE ABLE TO, UH, BE RESPONSIBLE ON HOW THE STANDARD CHANGES.
AND THEY DON'T HAVE, UM, THIS RESPONSIBILITY WITH, YOU KNOW, 2,800, THEY CANNOT FOLLOW ON HOW THE STANDARD CHANGES, HOW THEY UPDATE THEY LANGUAGE.
SO THEY KIND OF LOSE THIS, UH, TRACK, UH, OF, OF STANDARDS THIS WAY.
UM, BUT ON THE STANDARD DRAFTING TEAMS, PEOPLE ARE TRYING TO ALIGN WITH 2,800 AS MUCH AS POSSIBLE BECAUSE THEY ALSO UNDERSTAND THAT SOME OF THE AREAS ALREADY STARTED ON ADOPTION AND NOBODY WANTS TO CREATE THIS BIG CONFLICT.
UM, THIS IS 2,800 IMPLEMENTATION PLAN, UM, DRAFT.
I PICKED THIS BECAUSE I THOUGHT IT COULD BE
[01:55:01]
INTERESTING FOR THIS DISCUSSION.I THINK WE ALREADY TOUCHED ON SOME OF THIS.
UM, SO BASICALLY AS A PART OF IMPLEMENTATION PLAN, WHAT IS SAYING IS THAT ENTITIES SHALL NOT BE REQUIRED TO COMPLY WITH REQUIREMENT R SIX.
AND I'LL SAY WHAT R SIX IS IN A MINUTE, UH, UNTIL SIX MONTHS AFTER EFFECTIVE, UH, IMPLEMENTATION DATE OF PRC 29.
UH, AND THE REQUIREMENT R SIX CURRENTLY IN PRC 29 DRAFT IS THAT EACH, UH, GO WITH LIMITATIONS SHOULD DOCUMENT THE LIMITATIONS, UH, THAT WOULD PREVENT ITS ABILITY TO COMPLY WITH, UH, VOLTAGE RIDE THROUGH REQUIREMENTS.
SO SPECIFICALLY R ONE AND R TWO REQUIREMENT.
AND THIS IS BECAUSE FOUR CODE OR 9 0 1 IS ALSO ONLY ALLOWING EXCEPTION FOR THIS, UH, SPECIFIC REQUIREMENTS.
UM, ONE, I THINK IMPORTANT DIFFERENCE WITH THIS, WITH WHAT, WHAT IS IN, UH, UGUR 2 45 IS THAT THIS IS A FIXED TIME PERIOD.
SO, SO YOU HAVE SIX MONTHS TO EVALUATE YOUR LIMITATIONS AND THIS IS IT.
AND THEN ON THE EXEMPTIONS WILL ONLY APPLY TO THIS SET OF LIMITATIONS.
AND IF FURTHER EVENTS ARE HAPPENING IN THE FUTURE, AND THERE ARE OTHER LIMITATIONS THAT ARE FINDING OUT, THERE IS NO OTHER, UH, WAY TO CAPTURE THIS LIMITATIONS ANYMORE.
SO ONCE YOU CAPTURED LIMITATIONS THAT YOU THINK YOU HAVE IN YOUR PLANT, THIS IS IT, THEN THE PLANT IS EXPECTED TO OPERATE TO ALL OTHER CAPABILITIES THAT ARE THERE.
UM, AND SO, SO THAT'S SOMETHING THAT I THINK THAT THERE IS A DIFFERENCE BETWEEN KOTS VERSION OF NO 2 45 AND, UM, JC VERSION OF THAT.
AND THERE IS A LIST OF, UH, WHAT KIND OF LIMITATIONS, UH, THE GENERATOR OWNER NEEDS TO CAPTURE, UM, UH, ASPECTS.
AND, AND, AND THERE IS A, THERE IS ALSO REQUIREMENT FOR, UH, MITIGATION, UH, TO REMOVE LIMITATIONS.
SO THAT'S THE LAST POINT, BOB.
THAT'S WHAT, UM, WE WERE TALKING ABOUT IN THE DISCUSSION.
UM, SO SWITCHING GEARS FROM, UH, 2800.2, UH, AND FOR QUARTER 9 0 1 TO I-I-B-R-W-G, UH, WE STARTED THIS GROUP, UH, AS A TASK FORCE IN FEBRUARY, 2022.
SO IN THE WAKE OF THE FIRST, UH, ODESSA EVENT, UM, THEN THE SECOND ODESSA EVENT HAPPENED.
UH, IN THE SCOPE OF THE GROUP, WE REVIEW RESULTS OF DISTURBANCE EVENT, UM, UH, AND ANY KIND OF FOLLOW UPS THAT HAPPENS SINCE WITH GENERATOR OWNERS.
UM, WE FOLLOWED THROUGH GAP ANALYSIS OF 2,800, UH, STANDARD AND ORCUTT INTERCONNECTION REQUIREMENTS AT THE TIME DISCUSSED.
UM, ANY UPDATES TO NOER, UH, 2 45 AND 2 55.
UM, MANUFACTURERS BROUGHT PRESENTATIONS ON CAPABILITIES AND LIMITATIONS OF THE EXISTING EQUIPMENT AND NEW EQUIPMENT.
UM, FEW GENERATOR OWNERS TOWARDS THE END OF LAST YEAR PRESENTED ON LIMITATIONS WITH REGARD TO NO 2 45 REQUIREMENTS.
UM, I MUST SAY THIS IS KIND OF, UH, THIS WORKING GROUP, UH, SEES MORE PARTICIPATION FROM MANUFACTURERS, UH, ORCUTT STAFF, NERC, UH, TRE AND OTHER, UM, SMES FROM THE OUTSIDE.
UH, WHAT I THINK ORCO REQUESTED MULTIPLE TIMES AND WOULD BE REALLY BENEFICIAL TO SEE MORE GENERATOR OWNERS ACTIVELY PARTICIPATING.
WE HAVE, UH, AROUND A HUNDRED PEOPLE ON THE CALL EVERY TIME, UH, BUT GENERATOR OWNERS AND, UH, GENERATOR DEVELOPERS ARE NOT ACTIVELY SPEAKING UP.
THERE WAS NO KIND OF FEEDBACK DURING THE TIME AS GAP ANALYSIS WAS DONE WITH 2,800 AS 2 45 LANGUAGE WAS DEVELOPED.
I WOULD SAY WE ONLY STARTED GETTING SOME FEEDBACK FROM GENERATOR OWNERS WHEN, UM, THERE WAS LANGUAGE
AND I THINK WITH EVERYTHING THAT'S HAPPENING AND WITH COMPLEXITY OF THIS EQUIPMENT, IT'S NOT JUST ABOUT WHAT'S IN THE LANGUAGE.
IT'S ABOUT LEARNING MAYBE EVEN FROM OTHER EVENTS, OUTSIDE EVENTS AND BRINGING IT BACK TO YOUR EQUIPMENT AND SEEING, YOU KNOW, WHAT'S MY EQUIPMENT IS DOING AND BRINGING IT BACK TO YOUR OWN PLANT PERFORMANCE AND THINKING ABOUT IT PROACTIVELY, BECAUSE I DON'T THINK IT'S POSSIBLE ANYMORE WHERE YOU CAN JUST BUILD A PLANT AND LEAVE IT.
AND UNTIL LANGUAGE CHANGES IN PROTOCOLS ONLY, THEN YOU NEED TO GO BACK AND SEE, YOU KNOW, IF YOU NEED TO MAKE ANY CHANGES.
I THINK IT NEEDS TO BE MORE PROACTIVE.
UM, I ALSO, UH, THINK THAT LIKE LOOKING AT, UH, I-B-R-W-G AND HOW IT WORKS, I THINK I REALLY FEEL FOR SOME LARGER, UH, GENERATOR OWNERS AND MANUFACTURER AND, AND DEVELOPERS BECAUSE I THINK THEY ARE MORE PROACTIVELY PARTICIPATING.
UH, BUT THAT ALSO CREATES, UH, KIND OF BIGGER BURDEN ON THEM.
AND IF SMALLER GENERATOR OWNERS, SMALLER DEVELOPERS ARE NOT PARTICIPATING, NOT ADDRESSING THESE ISSUES, THIS REFLECTS ON ALL INVERTER BASED RESOURCES AND THEREFORE PUTS MORE BURDEN ON LARGER DEVELOPERS AND LARGER GENERATOR OWNERS.
[02:00:01]
SO, YOU KNOW, IF WE CAN DO ANYTHING TO ALSO ATTRACT MORE PARTICIPATION FROM, UH, SMALLER, LESS PROACTIVE GENERATOR OWNERS AND DEVELOPERS, THAT WOULD HELP EVERYONE.UM, I PULLED SOME, UM, MATERIAL FROM PRESENTATIONS THAT HAPPENED AT I-B-R-W-G, UM, JUST BASED ON, UM, WHAT I THOUGHT WOULD BE INTERESTING FOR THIS, UH, MEETING.
UM, AFTER THIS EVENT HAPPENED, THERE WAS FOLLOW UP WITH GENERATOR OWNERS AND, UH, ORCA PRESENTED, UH, IN MARCH I-B-R-W-G MEETING ABOUT WHAT HAPPENED.
UM, THERE WERE THREE MANUFACTURERS THAT WERE INVOLVED IN BOTH ODESSA EVENTS.
ONE OF THE MANUFACTURERS IS CURRENTLY OUT OF BUSINESS ALREADY.
THEY HAVE SOME SUPPORT MECHANISMS HERE AND THERE, BUT I THOUGHT IT'S NOT AS IMPORTANT MAYBE TO BRING THIS ONE HERE.
SO I ONLY HAVE FOLLOW UP FROM TWO MANUFACTURERS ON THE SLIDES.
UH, BUT YOU'RE WELCOME TO GO BACK TO MARCH EIGHTH'S PRESENTATION AND SEE MORE DETAILS.
UH, SO TEAM MIKE, UH, THE CORRECTIVE ACTIONS WERE IDENTIFIED AND IMPLEMENTED FOR SYSTEMATIC ISSUES, UM, ON ALL EIGHT RESOURCES ENROLLED IN THE EVENT.
UM, AS SOMEBODY ALREADY MENTIONED ON THE CALL, ONLY TWO, UH, GENERATOR OWNERS, UM, SUBMITTED UPDATED MODELS, UH, BACK TO ERCOT, AND THAT'S AS OF MARCH.
MAYBE, YOU KNOW, MAYBE SOMETHING ELSE HAPPENED IN BETWEEN, UH, SINCE THEN, UH, OUT OF EIGHT EXISTING FACILITIES THAT CURRENTLY USE TI CONVERTERS, UH, 11 HAVE UP UPTODATE FIRM FIRMWARE AND RECOMMENDED SETTINGS ALREADY.
UH, NINE HAVE, UH, SCHEDULED COMPLETION OF THIS UPGRADES, UH, BY END OF THIS YEAR.
AND SEVEN ARE DEVELOPING, UH, SCOPE OF WORK, UH, WITH TEAM.
I, I THINK THERE IS LIKE ONE OR TWO MISSING FROM THIS IF YOU PUT IT ALL TOGETHER.
AND I THINK KO'S STILL FOLLOWING UP WITH THOSE.
UM, AND, AND TEAM I NOTIFIED ORCO THAT ALL NEW PROJECTS, UH, WILL HAVE UP TO DATE FIRMWARE WITH, UH, WITH THE SETTINGS THAT KIND OF, UH, WERE FOUND IN THE EVENTS.
UH, THE POWER ELECTRONICS, UM, THIS ONE, THEY DIDN'T HAVE AS SYSTEMATIC, UH, ISSUES AS T MIC, SO IT'S KIND OF MORE INFORMATION HERE.
UH, THERE WERE TWO PLANTS WITH OLDER INVERTERS, UH, THAT THEY STILL CONTINUE HAVING THIS RIDE THROUGH ISSUES.
UH, THIS APPEARS TO BE LIMITATION OF THE INVERTER CAPABILITY.
UM, BUT ARE WE RESUBMITTED THE MODELS, UH, TO ORCO THAT REFLECTS THIS LIMITATION.
SO AT LEAST LIKE IF KOTT SIMULATES THIS FAULTS, THEY CAN SEE THAT, UM, RESOURCE TRIPS OR REDUCES MEGAWATT UH, OUTPUT.
UM, ANOTHER PLANT ALSO HAS DIFFERENT OLDER INVERTERS FROM THE SAME MANUFACTURER.
AGAIN, UH, RE HAS ADJUSTED, UH, LOW VOLTAGE DRIVE-THROUGH SETTINGS AND PROTECTION SETTINGS.
UH, AND FACILITY HAS SHOWN IMPROVED PERFORMANCE IN THE SUBSEQUENT EVENTS.
UH, RE RESUBMITTED MODEL TO ERCOT, UH, WITH THOSE UPDATES.
UH, THE POWER ELECTRONICS HAS DEVELOPED FIRMWARE UPDATES TO IMPROVE RIGHT THROUGH PERFORMANCE.
UM, AND, UM, OUT OF 18 EXISTING FACILITIES WITH P INVERTERS.
CAN I GO BACK ONE SLIDE? ALL RIGHT, THANKS.
UM, WHERE WAS, YEAH, 18 EXISTING FACILITIES, UH, HAVE FIRMWARE.
UH, EIGHT 16 HAVE IMPLEMENTED FORMER UPDATES AND PE NOTIFIED ORCA THAT GOING FORWARD, THEY'LL HAVE THIS UPDATED SETTINGS AND ALL NEW EQUIPMENT, UH, OTHER EVENTS.
UH, SO DURING THE TIME OF, UH, TASK FORCE AND WORKING GROUPS EXISTENCE, UH, ORCAD BROUGHT, UH, SOME ADDITIONAL EVENTS THAT HAPPENED, UH, OR GOT STARTED MONITORING SMALLER EVENTS, UH, TRYING TO BE PROACTIVE AND, UH, FOLLOW UP WITH RESOURCES BEFORE A LARGE EVENT HAPPENED.
SO THERE WAS ONE EVENT IN JANUARY, 2023 IN WEST TEXAS WHERE NORMALLY CLEARED FAULT RESULTED IN POST DISTURBANCE LOSS OF 298 MEGAWATT OF SOLAR GENERATION FROM EIGHT DIFFERENT FACILITIES.
SEVEN OF THOSE WERE INVOLVED IN ODESSA EVENTS.
UM, AND DURING THE FALL, THEY SAW REDUCTION OF 600 MEGAWATT.
UM, IN OCTOBER, 2023, WEST TEXAS, AGAIN, UH, NORMALLY CLEARED FAULT RESULTED IN POST, UH, EVENT LOSS OF 140 MEGAWATTS ACROSS SEVEN, UH, SOLAR EVENT, UH, SOLAR UNITS.
UM, THERE WAS, AGAIN, LARGER REDUCTION DURING THE EVENT.
UM, AND THIS IS A LITTLE BIT OF, UM, NOT A LITTLE BIT, BUT THIS IS A PROBLEM THAT ORCUTT IS SEEING, UH, AND IT MANIFESTS ITSELF AS A SPIKE DOWN IN, UH, SYSTEM FREQUENCY.
SO THIS IS WHY LIKE IT MAKES ERCOT CONCERNED.
UH, ONE THING TO SAY ALSO THAT ALL OF THESE EVENTS, THEY WERE NOT REALLY DEEP VOLTAGE WRITE THROUGH EVENTS.
THEY'VE BEEN MAYBE, IF I REMEMBER CORRECTLY, THE LOWEST, UH, VOLTAGE THAT WAS SEEN AT POI WAS 0.6, UH, UH, 0.6,
[02:05:01]
UH, PER UNIT.UH, SO BASICALLY THIS IS NOWHERE NEAR THE BOTTOM OF THE LOWER VOLTAGE RIGHT THROUGH CURVE.
SO, UM, UH, THE REDUCTION, SOMETIMES MEGAWATT REDUCTION THAT ORCUTT IS SEEING IN THIS EVENT IS TOO DRASTIC FOR THE AMOUNT OF VOLTAGE DIP THAT THE PLANT IS EXPERIENCING.
UH, THERE WERE THREE EVENTS IN SOUTH TEXAS.
ALL OF THESE WIND EVENTS, AGAIN, NORMALLY CLEAR FAULT RESULTED IN RELATIVELY SMALL POST DISTURBANCE LOSS, UH, BUT RELATIVELY LARGE LOSS DURING THE EVENT.
UH, AND THEN I BELIEVE IN EITHER IN AUGUST OR SEPTEMBER I-B-R-W-G MEETING, UH, OR GOT PRESENTED ON REQUESTS FROM STAKEHOLDERS, UH, REPORTS FROM MULTIPLE SMALLER EVENTS, UH, IN LAST FIVE YEARS WHERE, UH, WIND PLANTS WERE INVOLVED.
BECAUSE THE QUESTION WAS, WELL, THEES EVENTS WERE ONLY SOLAR.
IS THERE SIMILAR ISSUES THAT YOU'RE SEEING WITH WIND AND THEREFORE, OR GOT, WENT BACK AND LOOK AT, UM, OTHER EVENTS THAT HAPPENED? AND SO YOU CAN SEE HERE THAT, UM, IN THIS ANALYSIS, 17% OF, UH, WIND RESOURCES WITH, UH, THAT ARE REALLY OLD WITH SJA BEFORE, UH, NOVEMBER, 2020, 2008, EXPERIENCED AT LEAST ONE RIGHT THROUGH, UH, FAILURE, 34%, UH, OF, UH, PLANS WITH SGIA BETWEEN NOVEMBER, 2008 AND, UH, JANUARY, 2014, EXPERIENCED, AGAIN, MORE THAN ONE RIGHT THROUGH FAILURE IN 25% OF NEWER, UH, RESOURCES POST, UH, JANUARY, 2014 EXPERIENCED MORE THAN ONE EVENT.
UM, ALSO, KO HAS, IF YOU GO BACK TO THIS PRESENTATION, ERCOT HAS NUMBERS OF INSTALLED CAPACITY OF THESE PLANTS THAT TRIPPED, UH, AND WHAT ACTUALLY WAS LOST IN THE EVENT, UH, AND WHAT THEY WERE PRODUCING AT THE TIME.
AND THEY INDICATED THAT FOR SOME REASON, ALL OF THESE EVENTS HAPPENED DURING RELATIVELY LOW PRODUCTION FROM THIS WIND PLANTS.
AND, UH, WOULD THEY HAVE BEEN PRODUCING MORE WHEN THIS EVENT HAPPENED? UH, THE LOSS, MEGAWATT LOSS WOULD'VE BEEN HIGHER.
UM, SO THIS ONE SLIDE IS KIND OF MY REFLECTION ON ALL OF THIS.
UM, AND YOU MAY BE ASKING, YOU KNOW, WHY ARE WE TALKING ABOUT THIS? WHY HAVEN'T WE HAD THESE ISSUES BEFORE? AND I THINK, AS WOODY MENTIONED, SOME OF THE, THE SYNCHRONOUS GENERATORS, THEY PERFORM PRIMARILY BASED ON THEIR PHYSICAL CHARACTERISTICS.
UM, EVEN CONTROLS THAT ARE APPLIED TO SYNCHRONOUS GENERATORS, THEY'RE REALLY WELL STANDARDIZED.
WE HAD A HUNDRED YEARS TO FIGURE IT OUT.
UM, AND, AND ALL CONTROLS ARE STANDARDIZED.
IF YOU OPEN PSSE, YOU HAVE STANDARD MODELS FOR GOVERNOR.
YOU HAVE STANDARD MODEL FOR VOLTAGE REGULATOR, UH, FOR, FOR FREQUENCY CONTROL.
UM, SO THERE ARE VERY WELL ESTABLISHED PRINCIPLES ABOUT MODELING.
AND IN CONTRAST IN EBASE RESOURCES, UH, PRIMARILY THE PERFORMANCE IS BASED ON CONTROL AND SOFTWARE, AND THEY'RE SIGNIFICANTLY MORE COMPLEX.
AND SOME OF THE CAPABILITIES ARE STILL DEVELOPING.
THERE ARE STILL NEW MANUFACTURERS APPEARING AND SO ON.
SO THERE IS VARIETY OF CONTROL PHILOSOPHIES, UH, PLANT LEVEL CONTROLLED, APOLOGIES.
THE WAY THEY SYNCHRONIZE TO THE GRID, UH, THE CONTROL, UH, MECHANISM, THEY'RE VARY.
THEY CAN HAVE FREEZE AND UNFREEZE LOGIC.
SO BASICALLY WHERE THEY KIND OF STOP INJECTING, START INJECTING AGAIN.
AND AS I MENTIONED, THEY HAVE BUILT IN PROTECTIVE FUNCTIONS.
SO NOT PROTECTION RELAYS, BUT PROTECTIVE FUNCTIONS THAT ARE INSIDE INVERTER.
UM, SOME OF THIS, UH, RESPONSES ARE REALLY FAST.
SO MANY OF THIS, NOT MANY, BUT LIKE SOME OF THE FASTER TIMEFRAME RESPONSES CANNOT BE REPRESENTED IN PHASE OF DOMAIN MODELS.
SO PC TYPE OF MODELS, TS A, UH, TYPE OF MODELS, THEY WILL NOT EVEN CAPTURE TRANSIENT OVER VOLTAGE DRIP ON INSTANTANEOUS, UH, UH, MEASUREMENTS.
NONE OF THIS, BECAUSE IT'S NOT IN THE DOMAIN OF THE MODEL TO EVEN CAPTURE THAT.
SO FOR THAT, YOU WILL REQUIRE EMT SIMULATION.
LARGE SCALE E MT SIMULATIONS, UM, ARE VERY COMPUTATIONALLY EXPENSIVE.
UH, ERCOT HAS A MODEL OF PANHANDLE, NEAR PANHANDLE AREA AND SOUTH TEXAS MODEL FOR EMT.
UH, BUT THERE IS NO ERCOT WIDE EMT MODEL, AND I DON'T THINK IT'S CURRENTLY COMPUTATIONALLY POSSIBLE.
UM, ANOTHER ISSUE THAT WAS BROUGHT UP ACTUALLY AT ONE OF THE IBR WG MEETINGS, UM, IS THE LACK OF CONTINUITY BETWEEN DEVELOPING OF THE PLANT AND OWNERSHIP OF THE PLANT.
PLANTS ARE CHANGING HANDS SEVERAL TIMES, AND DURING THIS TIME, ALL THESE TEENY TINY DETAILS ABOUT EQUIPMENT, UM, AND CONTROLS ARE BEING LOST.
UH, AND THAT CREATES GAPS IN PLANT MODELING.
UM, AND, AND UNDERSTANDING OF CAPABILITIES AND POTENTIAL PERFORMANCE ISSUES.
AND AS UPGRADES ARE HAPPENING, HOW THESE UPGRADES NEED TO FIND ITS WAY BACK TO MODELS AND BACK TO
UM, SO ALL OF THESE COMPLEXITIES, I THINK, MEAN THAT GENERATOR OWNERS CANNOT JUST BUILD AND LEAVE IT, YOU KNOW, TO OPERATE AND GENERATE MEGAWATTS AND PROVIDE ESSENTIAL RELIABILITY SERVICES THAT WERE INTENDED FROM THE BEGINNING.
THEY NEED TO HAVE MORE PROACTIVE ROLE IN ALL THE FORUMS WHERE IBR PERFORMANCE IS BEING DISCUSSED, WHERE ISSUES ARE BEING BROUGHT UP, WHERE LESSONS LEARNED ARE BEING BROUGHT UP, AND
[02:10:01]
TAKE IT BACK TO THE SHOP AND MAKE SURE THAT THE PLANS DON'T HAVE THESE ISSUES, OR IF THEY DO MAKE CHANGES TO THE PLANS, UPDATE THE MODELS, SUBMIT BACK.AND IT IS A LOT OF WORK REQUIRES A LOT OF PEOPLE.
I THINK WITH, UM, DOING MORE EVENT ANALYSIS PROACTIVELY AND MAKING SURE THAT THE MODELS ARE VALIDATED BASED ON ACTUAL EVENTS.
I THINK WE WERE TALKING ABOUT HERE ABOUT, UH, BEING ABLE TO DO ACTUAL EVENT ANALYSIS BASED ON BMU DATA.
AND, UM, ISO NEW ENGLAND HAS A TOOL THAT, UH, THEY DO THAT PROACTIVELY.
SO BASICALLY EVERY TIME EVENT HAPPENS, UH, AUTOMATICALLY THE TOOL PICKS UP PMU DATA, FEEDS IT INTO THE MODELS, UH, RUN THE MODELS THROUGH SIMULATION AND THROWS IT ALL INTO AN EMAIL AND SENDS EMAIL TO ENGINEER AND ENGINEER CAN EYEBALL IT AND SEE IF THERE ARE ISSUES IN THE PLANT.
UH, SO THIS KIND OF TOOL, I KNOW ERCOT MAYBE STARTS LOOKING INTO THAT, UM, THAT WOULD BE USEFUL.
AND WITH THAT, UM, I THINK I HAVE IT ALL HERE.
SO I HAVE A LINK TO I-B-R-W-G GROUP JOIN OUR MEETINGS.
UH, WE NEED ALL FEEDBACK FROM GENERATOR OWNERS, FROM DEVELOPERS, UM, AND THERE IS ALSO DOE IS STARTING A NEW, UH, FORUM FOR IMPLEMENTATION OF RELIABILITY STANDARDS.
UH, AND THIS IS SOMETHING THAT, UM, E-CIG ORGANIZATION THAT I'M WORKING FOR, WE ARE GOING TO HELP THEM LEAD.
UM, AND THE IDEA HERE IS TO BRING THE INDUSTRY TO THE SAME LEVEL WITH IMPLEMENTATION AND CHANGING STANDARD, UH, LANDSCAPE, BOTH LOOKING AT 2,800 IMPLEMENTATION, BUT ALSO FOR CODE OR 9 0 1 AND CHANGING OUR STANDARDS.
UH, SO THE FIRST MEETING WE'LL BE HAVING ON MAY 28TH, UM, SO PLEASE JOIN THAT AS WELL.
THANK YOU, JULIA, I'M GONNA ASK A QUICK QUESTION BEFORE WE GET TO THE QUEUE.
IF YOU COULD GO BACK TO SLIDE THREE.
I GUESS THE FIRST PIECE IS KIND OF JUST AN OBSERVATION.
IT, THIS ONE SEEMED LIKE WHEN WE FIRST SAW AN NOVA 2 45 AND ERCOT STARTED WORKING THROUGH THIS IN, IN 2022 AND FILED THIS IN JANUARY OF 23, ERCOT WAS KIND OF ON THE, THE FRONT EDGE.
IS THAT A FAIR ASSESSMENT? YEAH, THAT'S THAT'S VERY FAIR.
UH, OBSERVATION ACTUALLY, UH, I THINK ERCOT WAS FORCED TO START.
UH, AND THEN, UH, FPL, THAT'S FLORIDA POWER AND LIGHT.
UH, THEY CAUGHT UP UTILITY IN FLORIDA AREA.
THEY CAUGHT UP RELATIVELY QUICKLY AND THEY WERE THE FIRST ONES TO IMPLEMENT IN 2022.
SO I BELIEVE IN SECOND QUAR, UH, IN THE PAST LAST QUARTER OF 2022, UH, THAT THEY HAVE ADOPTED 2,800 ALREADY AND OTHERS, UH, SALMON GREEN, SOUTH RIVER PROJECT, UM, THOUSAND COMPANY, UM, THEY HAVE IMPLEMENTED LAST YEAR, SO TOWARDS SUMMER OR LAST YEAR.
UH, AND SO WHEN I'M SAYING IMPLEMENTED MEANS THEY HAVE IMPLEMENTATION, UH, EVERY NEW GENERATOR THAT HAVE SIGNED INTO CONNECTION AGREEMENT BY THAT DATE, UH, WILL HAVE TO COMPLY WITH 2,800 REQUIREMENT.
UH, MY, SO FOR THE FIRST PHASE OF REQUIREMENTS THAT I HAD ON MY SLIDE HERE, UH, FOR THIS FIRST PHASE OF REQUIREMENTS, THEY ALREADY HAVE IT IMPLEMENTED AND THEY APPLYING IT TO THE, UM, GENERATOR STUDY CYCLE OF 2022.
SO ALL OF THE GENERATORS THAT WILL COME OUT OF THE CYCLE AND WILL CONNECT, WILL BE REQUIRED TO COMPLY WITH THIS SUBSET OF 2,800 REQUIREMENTS.
SO THOSE INDEEDS THAT WERE ON THAT SLIDE, THEY'RE APPLYING THESE REQUIREMENTS ON A GO FORWARD BASIS, NOT USUALLY, UH, THEY ARE APPLYING ON GOING FORWARD BASIS.
I THINK THE, UH, KIND OF DIFFERENCE WITH ORCO IS THAT BECAUSE THEY KIND OF OUTRAN ORCO IN THIS, THEY ALREADY ARE APPLYING THIS TO, UH, FUTURE PLANS IF THEY SIGN INTERCONNECTION AGREEMENT BY THE DATE WHEN, YOU KNOW, WHEN THIS BECAME EFFECTIVE.
FIRST OF ALL, I JUST WANTED TO REALLY EXPRESS APPRECIATION FOR ALL YOUR LEADERSHIP THAT YOU PROVIDE REALLY NATIONALLY FOR THE INVERTER BASED RESOURCE PERFORMANCE ISSUES.
UH, I, I RUN INTO YOU ALL THE TIME ON ALL THESE DIFFERENT MEETINGS WHEN WE GET AN OPPORTUNITY, AND I KNOW HOW HARD YOU WORK, SO I, I APPRECIATE IT.
SO ON, ON ALL OF THE SLIDES THAT YOU SHOWED ABOUT POWER ELECTRONICS TEAM, I, IN YOUR EXPERIENCE, IS THE OEM'S EQUIPMENT THE ONLY THING THAT NEEDS TO BE CURED TO ENSURE PLANT PERFORMANCE? YEAH, NO, IT'S, IT'S, IT'S, I GUESS THAT'S WHERE DIFFICULTY IS.
IT'S SAME AS IT WAS TESTING, RIGHT? WITH TESTING A SINGLE INVERTER VERSUS VERIFYING PLANT
[02:15:01]
MODEL.SAME ISSUE EXISTS WITH FIXING ISSUES.
SO YOU FIX AN ISSUE ON AN INVERTER LEVEL, YOU STILL NEED TO MAKE SURE THAT THE ENTIRE PLANT WORKS AS INTENDED.
AND THIS IS ALSO WHERE COMPLICATION IS WITH APPLYING 2,800, BECAUSE UNLIKE IEE 1547, WHICH APPLIES TO DISTRIBUTION LEVEL INVERTERS, IS THAT THAT IS INVERTER LEVEL STANDARD THAT YOU CAN CERTIFY TO BE 1547 CAPABLE, WHEREAS 2,800 APPLIES AT THE POI OR PO POINT OF MEASUREMENT.
UH, AND, AND, AND THEREFORE YOU CANNOT ENSURE COMPLIANCE WITH JUST HAVING COMPLIANT EQUIPMENT AND YOU WILL NOT HAVE COMPLIANT EQUIPMENT.
YOU CAN SAY THIS EQUIPMENT HAS CAPABILITIES THAT WILL HELP YOU ENSURE 2,800, BUT 2,800 CONFORMITY NEEDS TO BE INSURED AT THE PLANT LEVEL BECAUSE PLANT IS MUCH MORE COMPLICATED AT THE TRANSMISSION LEVEL.
IT CONSISTS OF HUNDREDS OF INVERTERS.
IT HAS, YOU KNOW, COLLECTOR SYSTEM IN BETWEEN.
IT HAS PROTECTIVE EQUIPMENT IN BETWEEN, AND IT HAS, UH, YOU KNOW, REACTIVE SUPPORT EQUIPMENT THERE AS WELL.
FOLLOW UP A QUESTION REAL QUICK.
UM, WITH YOUR EXPERIENCE WORKING ON THE NERC INVERTER RESOURCE PERFORMANCE SUBCOMMITTEE, IS NERC AWARE OF THE MODELING ISSUES? ARE THEY DOING ANYTHING ACTIVELY ON ADDRESSING THE MODELING ISSUES WE'VE BEEN TALKING ABOUT TODAY? YEAH, I THINK NEWARK IS WELL AWARE FROM EVERY DISTURBANCE EVENTS.
IF YOU LOOK AT RECOMMENDATIONS, UH, ONE OF THE RECOMMENDATION IS TO IMPROVE MODELS BECAUSE, UH, WHERE SOME AREAS WENT BACK AND, AND RAN THIS EVENTS IN THE SIMULATION, THEY WERE NOT ABLE TO REPLICATE THE EVENTS.
UH, THERE ARE SOME EFFORTS GOING ON, UM, THAT, YOU KNOW, TO UPDATE MODELS, UH, THAT THERE'LL BE MODELING STANDARDS EFFORTS THAT ARE ALSO HAPPENING.
THEY WOULD BEEN TO MY, UM, SADNESS BEEN PUT ON THE LOWER PRIORITY.
I THINK THIS NEED TO BE HIGHER PRIORITY, BUT, UH, THESE ARE DUE IN 20 25, 20 26 TIMEFRAME, UH, MODELING STANDARDS ON IMPROVING MODELS AND SPECIFICALLY ALSO ON EMT MODELS.
I KNOW YOU WERE, UH, INVOLVED, UH, AS A VICE CHAIR WHENEVER EPRI PRESENTED ITS GAP ANALYSIS ON IEE 2,800 FOR ERCOT.
IN YOUR OPINION, WITH YOUR EXPERIENCE, UH, DO YOU SEE ADOPTION OF IEEE 2,800 AS BENEFICIAL FOR RELIABILITY HERE IN ERCOT? I, I THINK IT'S BENEFICIAL EVERYWHERE, NOT JUST IN ERCOT.
IT'S, UH, US OVERALL IS VERY FAR BEHIND IN TERMS OF, UH, PERFORMANCE STANDARD.
SO IF YOU, I'VE BEEN ASKED MULTIPLE TIMES, YOU KNOW, IF YOU LOOK BACK AT OTHER AREAS, ARE YOU SEEING THIS EVENTS? NO, WE, WE ARE NOT SEEING THIS EVENTS IN EUROPE.
THERE ARE NO MASSIVE IBR TRIP EVENTS IN EUROPE BECAUSE THEY HAD STANDARDS FOREVER.
I STARTED, YOU KNOW, MY CAREER IN 2002 OR EARLY TWO THOUSANDS WHEN THEY STARTED DEVELOPING WHAT THEY CALL GRID CODES, UH, FOR INVERTED BASED RESOURCES.
UH, AND IN 2016 THEY HAD UNIFIED STANDARD FOR INTERCONNECTION REQUIREMENT FOR THE ENTIRE EUROPE, UH, THAT'S BEEN APPROVED AND IMPLEMENTATION TIMELINE WAS 2019.
SO SINCE 2019, THEY HAVE A HARMONIZED SET OF REQUIREMENTS ACROSS ENTIRE EUROPE.
UH, SOME AREAS LIKE IN GERMANY, THEY HAVE VERY RIGOROUS TESTING.
THEY HAVE THIRD PARTY CERTIFICATION TESTING.
IT'S MAYBE A LITTLE BIT, YOU KNOW, OVERBOARD AND TAKES A LOT OF TIME TO TEST, BUT THEY ACTUALLY DO.
MARK WAS SAYING, YOU KNOW, IF, IF YOU CAN TEST SOMEHOW, THEY ACTUALLY DOING CONTAINER FOLD TESTING FOR MODEL VALIDATION DURING, UH, INTERCONNECTION.
I'M NOT SAYING YOU SHOULD GO THAT WAY, BUT, UH, JUST TO SHOW THE RANGE OF WHAT PEOPLE DOING, UM, IN OTHER AREAS.
AND SO FROM THAT PERSPECTIVE, I THINK IN 2,800, IT, THEY HAD A REALLY GOOD SET OF SMES.
I THINK THEY PULLED ON EXPERIENCE FROM AUSTRALIA, FROM, UH, EUROPE WHEN DEVELOPING REQUIREMENTS MANUFACTURERS WERE AT THE TABLE.
SO IT'S NOT LIKE THE STANDARD WAS DEVELOPED BY A SET OF PEOPLE THAT, YOU KNOW, DIDN'T KNOW WHAT'S IN THE MANUFACTURING.
SO, UH, I THINK THIS WAS DEVELOPED IN GOOD PHASE OF WHAT CAPABILITIES OF INVERTED BASED RESOURCES ARE AND OUGHT TO BE TO, UM, RELIABLE PERFORMANCE.
KEN DONAHUE? YEAH, KEN, DONNA WITH A PA JULIA ON THE OAM INPUT INTO 2,800.
IF YOU COULD, YOU KNOW, HAVE YOU GOTTEN FEEDBACK FROM THEM? CAN YOU KIND OF DO A GENERAL DISCUSSION? I KNOW THEY'VE BEEN PARTICIPATING IN A LOT OF THE 2,800 STANDARDS, PARTICULARLY 2800.2.
AGAIN, MY BIGGEST CONCERN WITH THE OEMS, THAT'S EACH INDIVIDUAL TURBINE OR EACH INDIVIDUAL DEVICE.
IT'S NOT NECESSARILY A PLANT MODEL.
SO, BUT IF YOU CAN PROVIDE SOME IMPACT ON 2,800 WITH THE OEMS, I MEAN, THE PART 2,800, I WAS ONLY
[02:20:01]
INVOLVED IN BITS AND PIECES OF IT.I WAS NOT PART OF THE WORKING GROUP.
UH, I KNOW THEY WERE INVOLVED IN THE DEVELOPMENT AND STANDARD, IF YOU LOOK AT THE, UM, SET OF AUTHORS, SOME OF THEM EVEN LED, UH, SOME OF THE SUBGROUPS I BELIEVE.
AND SAME THING IS HAPPENING IN 2,800 OR TWO.
THEY'RE AT THE TABLE, UH, FOR THE, UM, DESIGN.
GIMME A SEC, I'LL GET TO THIS ONE.
UH, YEAH, SO, SO WHAT WILL BE HAPPENING HERE IS THIS, UH, PLANT MODEL DEVELOPMENT AND DESIGN EVALUATION.
SO THIS IS WHERE MANUFACTURER NEEDS TO GET TOGETHER WITH THE GENERATOR DEVELOPER AND FROM BOTH OF THESE SITES, THEY NEED TO ENSURE THAT FIRST EQUIPMENT IS, HAS CAPABILITIES, UH, THAT ARE COMPATIBLE WITH 2,800, UH, THAT SINGLE EQUIPMENT HAS BEEN TESTED AND VALIDATED FOR THE MO YOU KNOW, SINGLE UNIT MODEL.
UH, AND THEN AS THIS PLANT IS BEING PUT TOGETHER BY DEVELOPER OR THE CONSULTANT THAT THEY WORK TOGETHER WITH MANUFACTURER TO MAKE SURE THAT IT ALL, UH, YOU KNOW, REPRESENTS THE PLANT.
THIS MODEL, AGAIN, JUST COMING BACK TO THAT, THIS IS NOT VALIDATED MODEL AT THAT POINT.
THERE IS NO WAY TO VALIDATE PLANT MODEL UNTIL ACTUAL EVENT HAPPENS.
YOU CAN VALIDATE BASED ON SMALL COMMISSIONING TESTS, BUT THIS IS JUST, YOU KNOW, SMALL SUBSET OF VALIDATION DOESN'T SHOW YOU HOW THE PLANT WILL PERFORM, UH, DURING EVENTS.
SO AS EVENTS ARE HAPPENING, THEN YOU KIND OF NEED TO GO BACK.
UM, YOU NEED TO CAPTURE SMALLER EVENTS FIRST AND PROACTIVELY GO BACK AND VALIDATE MODEL AND, UH, MAKE SURE THAT THE MODEL IS, UH, REPRESENTING THE PLANT.
UH, AND THIS WAY IF THIS CONTINUOUSLY IS BEING DONE, THEN, UH, MAYBE DOESN'T GET TO BIGGER EVENTS.
BUT YEAH, MANUFACTURERS ARE INVOLVED THROUGHOUT THE ENTIRE PROCESS.
THEY'VE BEEN, FOR EXAMPLE, FOR THIS MULTIPLE WRITE THROUGH LIMITATION, VESTAS BROUGHT A GREAT PRESENTATION BOTH TO I-B-R-W-G, UH, AND ALSO TO, UM, SUBGROUP FIVE OF 2,800 OR TWO.
YOUR SUMMARY OF THE POST ODESSA MITIGATIONS, UM, I THINK IS EXTREMELY HELPFUL AND GETS TO ONE OF THE KEY QUESTIONS FOR TODAY'S DISCUSSIONS, WHICH IS HOW ARE SOME OF THESE ISSUES BEING MITIGATED AND KIND OF WHAT'S THE REMAINING RELIABILITY RISKS IN LIGHT OF MITIGATIONS TO DATE OR PLANNED, OR OTHER ITEMS THAT, YOU KNOW, GENERALLY WOULD BE EXPECTED TO HELP? UM, SO THANKS FOR, THANKS FOR GOING OVER THOSE.
UM, I HAVE ONE OTHER QUESTION.
I BELIEVE IT'S ON YOUR SLIDE 11 ON PRC 29 MM-HMM,
UM, AND THE REASON I ASK IS, UM, JUST BECAUSE AS WE TALK ABOUT WHAT THE TAC APPROVED VERSION OF NORE 2 45 IS, AND KIND OF COMPARING AND CONTRASTING WITH WHERE PRC 29 MIGHT GO WHEN IT'S ULTIMATELY REVISED AND ADOPTED, CAN YOU JUST CLARIFY WHERE YOU SEE THE MITIGATION REQUIREMENT AS OPPOSED TO JUST THE DOCUMENTATION OF, UM, THE LIMIT, UH, INFORMATION REGARDING ANY PLANS TO REPAIR OR REPLACE LIMITING EQUIPMENT THAT WOULD REMOVE LIMITATION? OKAY, SO YOU'RE READING THAT AS AN AFFIRMATIVE OBLIGATION TO ACTUALLY REPAIR, REPLACE EQUIPMENT VERSUS, I MEAN, IF IT'S A REPAIR THAT'S A LITTLE DIFFERENT, BUT YOU READ THAT AS AN AFFIRMATIVE, UH, OBLIGATION TO REPLACE EQUIPMENT THAT IS
BUT AGAIN, THIS IS A DRAFT, SO THIS, THIS MAY CHANGE.
ONE OF THE FEEDBACK, SOMEBODY ASKED ABOUT COMMENTS, UH, THAT CAME BACK FROM REVIEW OF, UH, STANDARDS.
SO ONE OF THE COMMENTS FOR PRC 29 WAS, UM, LACK OF WAYS TO PROVE SOME OF THE REQUIREMENTS.
AND SO I THINK THIS, THIS HERE LEAVES A HUGE GAP OF EVEN, YOU KNOW, OKAY, I HAVE A PLAN TO REPLACE LIMITING EQUIPMENT, BUT DO I HAVE TO COMPLY WITH THE PLAN? HOW DO I SHOW THAT I IMPLEMENTED THE PLAN? THERE IS, THERE IS A GAP THERE THEY, THAT THEY LEFT, I THINK AND THEY NEED TO ADDRESS.
AND I UNDERSTAND THAT THIS IS, UM, UNDER REVIEW AND REVISION MM-HMM.
AND SO WE'LL, WE'LL SEE KIND OF WHERE IT GOES.
I WOULD, I WOULD SAY WE, WE DON'T READ IT AS AN AFFIRMATIVE OBLIGATION THERE, BUT IT THAT'LL GO THROUGH THE COMMENT PROCESS.
JULIE, AS YOU KNOW, THIS HAS BEEN A CHALLENGING ISSUE FOR STAKEHOLDERS TO DEAL WITH.
YOU ALSO WORK FOR A NON-PROFIT, SO I WOULD CONSIDER YOU AN INDEPENDENT EXPERT.
UM, I AM SEEKING GUIDANCE FROM THOSE THAT ARE INDEPENDENT AND HAVE EXPERTISE IN THIS SUBJECT.
I'M NOT TRYING TO BE PRO PROVOCATIVE WITH THIS QUESTION, BUT I'M WONDERING IF YOU HAVE CONCERNS WITH THE TECH APPROVED VERSION OF 2 45 OR IF YOU COULD SUMMARIZE PROS AND CONS OF THE OPTIONS WE ARE PRESENTED WITH TODAY.
[02:25:01]
I THINK IT'S, I MEAN, THE LANGUAGE IS JUST RED LINE AND I WOULD, MY RECOMMENDATION WOULD BE TO, IF WE ARE HAVING MORE OF THIS WORKSHOPS TO CLEAN UP THE LANGUAGE AND JUST HAVE SOME KIND OF BLACK LINE THAT THAT CAN BE READ CORRECTLY.I THINK IN MY MIND, TWO STICKING POINTS ARE THIS COMMERCIAL REASONABILITY.
I THINK FROM, FROM ERCOT PERSPECTIVE, I CAN SEE LIKE AS A RELIABILITY RESPONSIBLE ENTITY IS REALLY HARD TO LEAVE IT TO A DEVELOPER TO DECIDE WHAT'S COMMERCIALLY REASONABLE.
I THINK FROM WHAT I'M SEEING FROM I-B-R-W-G AND HOW ERCOT WORKS WITH RESOURCES, I THINK THIS CAN BE LEFT TO WORK ONE-ON-ONE WITH, UH, ERCOT AND, AND FIGURE OUT.
AND I THINK AS ERCOT IS WORKING WITH DEVELOPERS THROUGH THIS LEGACY EQUIPMENT, THEY'LL GAIN EXPERIENCE OF WHAT'S POSSIBLE AND WHAT'S NOT.
THEY DO TALK TO MANUFACTURERS, AND SO THEY'LL FIGURE OUT WHAT'S TECHNICALLY FEASIBLE AND WHAT'S NOT.
UH, AND I THINK IT CAN BE KIND OF, IT DOESN'T HAVE TO BE SET IN HARD LANGUAGE, THIS COMMERCIAL REASONABILITY AND THE GENERATOR OWNER DECIDES, BUT IT'S MORE, NEEDS TO BE MORE OPEN, I FEEL LIKE, BECAUSE AS A RELIABILITY RESPONSIBLE ENTITY OR, UH, CANNOT JUST, JUST, YOU KNOW, TAKE IT AS FACE VALUE.
ONE OTHER THING IS IF IT'S, YOU KNOW, OKAY, IT'S COMMERCIALLY REASONABLE OR GOT ACCEPTED, IT NEEDS TO FIND LIMITATIONS, NEED TO BE MODELED.
AND SO WHAT HAPPENS THEN IS IN THE MODELS, OR GOT, STARTS SIMULATING LARGE EVENTS AND THEY SEE A LOT OF GENERATION TRIP IN AN EVENT, IT LEADS TO FREQUENCY EVENTS THAT ARE NOT ACCEPTABLE ON EVERYDAY BASIS.
AND WHAT THEY WILL DO AS A RESULT, THEY WILL START TO DISPATCH SOMEHOW TO AVOID THAT.
AND SO THAT'S NOT DESIRABLE OPTION FOR ANYBODY.
UH, ONE OF THE EXAMPLES I CAN BRING UP IS LIKE IN, UM, UH, GREAT BRITAIN, THERE IS A LIMITATION ON LARGE, LARGEST CONTINGENCY THAT THEY CAN HANDLE, AND THEY ACTIVELY DISPATCH DOWN, UH, LARGEST LOSS, LARGEST CONTINGENCY TO AVOID THIS FREQUENCY EVENT.
SO, SO THAT'S, THAT'S KIND OF ONE THING THAT, UM, ERCOT IS, YOU KNOW, RESPONSIBLE FOR RELIABILITY WE NEED TO DO.
UM, AND THEN ONE OTHER THING WAS, AND THAT'S WHY I BROUGHT THIS ONE HERE, IS THIS, UM, AS, AS ERIC MENTIONED, WE HAVE ALL, WE KNOW, ALL KNOWN UNKNOWNS
IT'S BASICALLY WHAT GIVES A WAY OUT TO LESS PROACTIVE GENERATOR OWNERS NOT TO DO THE HOMEWORK NOW AND WAIT UNTIL EVENT HAPPENS AND THEN REPORT LIMITATION.
AND I THINK THAT NEEDS TO BE DONE NOW THEN EVEN THAT'S HOW PRC DRAFT IS THINKING RIGHT NOW.
YOU NEED TO GO TO A PLAN TO EVALUATE LIMITATIONS AND, UM, RECORD IT NOW RATHER THAN WAIT FOR NEXT EVENT KNOWING THAT YOU CAN PUT IN LIMITATION IN THERE.
SO THESE ARE TWO THINGS THAT I THINK KIND OF I HAVE PROBLEM WITH IN, IN THESE TWO DRAFTS.
NED, THANK YOU JULIA FOR THAT.
AND, AND THANKS BILL FOR ASKING THAT QUESTION.
I THINK THAT'S, THAT'S REALLY HELPFUL TO, TO GET YOUR INDEPENDENT, UH, PERSPECTIVE, JULIA.
ONE WAS, UH, RELATED TO YOUR SECOND TO LAST SLIDE, UM, WHERE YOU MENTIONED THAT THERE ARE ISSUES WITH, UM, PROJECTS CHANGING HANDS AND, AND, YOU KNOW, POTENTIAL, YOU KNOW, DROPPING OF THE BALL WHEN THAT HAPPENS.
I, I'M CURIOUS IF YOU CAN CHARACTERIZE HOW, UH, JUST HOW PREVALENT THAT IS, HOW MUCH THAT'S CONTRIBUTED TO SOME OF THE ISSUES IDENTIFIED.
AND THIS MAY BE A QUESTION FOR, FOR ERCOT AS WELL, IF THIS IS SOMETHING THAT HAS COME UP FOR, UH, FOR Y'ALL IN, IN TROUBLE ROOT CAUSE ANA, ROOT CAUSE ANALYSIS OF, UM, MODEL ISSUES.
YEAH, I'LL, I'LL LET ORKA CHIME IN.
UH, THE, WHEN IT CAME UP, UH, THIS WAS MORE ABOUT, UM, LEGACY MODELS FOR EMT MODELS FOR, UH, EXISTING RESOURCES.
UH, AND, AND SO BASICALLY CONSULTANT THAT WORKS WITH GENERATOR OWNERS SAID THAT, UH, THEY SEE THIS ISSUE A LOT WHERE I KNOW GENERATORS CHANGE HANDS AND THEY DON'T KNOW, UH, ABOUT THE SETTINGS OF THE EQUIPMENT, ABOUT, UH, YOU KNOW, MODEL AND VINTAGE OF THE EQUIPMENT.
UM, AND YEAH, SO THAT'S HOW THEY BROUGHT IT UP.
STEVEN, DID YOU WANNA ADD TO THAT? Y YEAH, I WOULD JUST SAY IT'S, IT'S RATHER PREVALENT AND, AND TO HER, UH, TO JULIA'S POINT, WHEN IT CHANGES HANDS, THAT'S WHEN YOU TYPICALLY SEE IT.
LIKE A NEW OWNER COMES IN AND THEN THEY DON'T HAVE THE KNOWLEDGE BASE THAT MAY BE CONTRIBUTING BOTH TO,
[02:30:01]
UH, WHAT MITIGATIONS ACTUALLY HAPPEN AND THE TIMELINESS OF IT.'CAUSE THEN THEY HAVE TO GO HIRE ANOTHER THIRD PARTY ENGINEERING FIRM.
THEY COME IN, THEY START INVESTIGATING, OR THEY HIRE AN OEM ENGINEERING FIRM.
AND SO THAT LACK OF EXPERTISE AND THAT HANDOFF, I THINK IS CONTRIBUTING TO SOME OF THE DELAY THAT WE'RE SEEING IN THE TIMELINESS.
AND STEVEN, IN YOUR, FROM WHAT YOU'VE SEEN DOES, IS THERE A DIFFERENCE BETWEEN WHETHER THE HANDOFF OCCURS AT THE, UH, WHEN A PROJECT IS AN INTERCONNECTING ENTITY VERSUS AN EXISTING RESOURCE ENTITY? I I THINK IT STILL DEPENDS.
YOU CAN HAVE AN EXISTING RESOURCE ENTITY THAT ACQUIRES ASSETS AND THEN THEY, THERE'S A KNOWLEDGE TRANSFER, UH, ISSUE THERE.
AND THEN YOU HAVE SOME WHERE, UH, SOME OF THE MORE ESTABLISHED, UH, OWNERS MAY HAVE MORE ROBUST IN-HOUSE ENGINEERING, AND IT'S, IT'S NOT AS MUCH OF AN ISSUE.
IT MIGHT DEPEND ON WHO THE, THE ACQUIRING ENTITY IS.
UH, THE, THE OTHER QUESTION I HAD, JULIA, WAS, UM, EARLIER ON YOU, YOU MENTIONED THAT THERE ARE SOME, UH, YOU KNOW, SOME ISSUES WHERE, UM, A AN OEM MIGHT LIMIT VISIBILITY INTO THE MODELS TO PROTECT I, UH, INTELLECTUAL PROPERTY.
I BELIEVE THAT ERCOT HAVING THAT MODEL CANNOT ACTUALLY, EVEN IF THEY GO TO A PLANT, CANNOT VERIFY THAT ALL OF THE SETTINGS IN THE PLANT ARE REFLECTED IN THE MODEL.
AND SO THAT'S, THAT SHOULD BE GENERATOR OWNER'S JOB WORKING TOGETHER WITH MANUFACTURER.
SO THAT'S ON THE VERIFICATION SIDE.
I MEAN, WHEN, WHEN DOING UPDATE AGAIN, THE GENERATOR OWNER NEEDS TO MAKE SURE THAT WHATEVER UPDATE WAS MADE FOUND ITS WAY BACK INTO THE MODEL AND SENT BACK TO
I I ALSO WANT TO THANK YOU FOR YOUR RESPONSE TO BILL'S QUESTION, WHICH I, I THINK WAS VERY INFORMATIVE BOTH ON THE, THE ISSUES WHERE, UH, THERE'S ROOM FOR ADDITIONAL, ADDITIONAL DEVELOPMENT BETWEEN THE TWO PARTIES TO, TO GET SOME RESOLUTION.
AND ALSO ON YOUR ISSUE ON THE RED LINE, WHICH I KNOW WHY WE DO THE RED LINE, BUT IT'S TOTALLY UNREADABLE AND IT'S MAKING IT VERY DIFFICULT TO WORK THROUGH THIS PROCESS.
UM, I'M STILL STUCK ON THE ISSUE THAT WE HAVE SOME KNOWN CONSENSUS ISSUES WHERE MAYBE WE HAVE SOME FIXES AND IMPROVEMENTS AND WE, WE TALKED ABOUT THAT WITH THE MODELING ON THE PART OF THE FACILITY, UH, THE, ON THE PART OF THE FACILITY.
AND SO NOW I'M WONDERING ABOUT THE O-M-O-E-M ANGLE ON THAT.
IS THERE INFORMATION DATA PARTICIPATION THAT WE NEED FROM THE OEMS TO ALLOW FOR IMPROVEMENTS IN MODELING THAT WE ARE NOT RECEIVING? AND, AND WHAT IS IT THAT WE ARE NOT RECEIVING FROM THE OEMS THAT WOULD BENEFIT THE MODELING PROCESS THAT ARE FIXABLE? I, I, I THINK FROM KIND OF STATE OF THE ART TECHNOLOGY, ALL OF IT IS THERE.
IT'S, IT'S MORE OF JUST, YOU KNOW, PROJECT CHANGE, PROJECT CHANGING HANDS IN, IN THE SENSE THAT, YOU KNOW, FROM MANUFACTURER TO DEVELOPER TO THE CONSULTANTS, RIGHT? AND SO I THINK THERE IS THIS KIND OF INFORMATION IS BEING LOST IN THAT PROCESS.
SO IF GENERATOR DEVELOPER PROACTIVELY WORKS WITH MANUFACTURER, UH, AND, AND THERE ARE CLEAR REQUIREMENTS ON MODELING REQUIREMENTS IN THE AREA, I THINK THAT ALL CAN WORK WELL TOGETHER.
UH, TALKING ABOUT FOLLOW UP WITH LEGACY EQUIPMENT NOW WITH NOER 2 45, I WAS THINKING ABOUT THAT AND I'M THINKING THERE IS A LOT OF SIMILAR EQUIPMENT OUT THERE, AND I THINK THERE IS REAL BENEFIT INSTEAD OF EACH GENERATOR OWNER GOING BACK TODAY MANUFACTURER ONE BY ONE AND FIGURING OUT WHAT THE LIMITATIONS ARE, MAYBE THERE IS SOME EFFICIENCY IN WORKING TOGETHER.
AND SO MAYBE WE CAN FACILITATE IT THROUGH I-B-R-W-G, MAYBE CLOSE MEETINGS IF THERE IS SOME CON CONFIDENTIAL INFORMATION INVOLVED WHERE DEVELOPERS THAT HAVE SAME TYPE MANUFACTURER TYPE AND VINTAGE OF EQUIPMENT CAN GET TOGETHER AND WORK LIKE COLLABORATIVELY.
[02:35:01]
UH, WORKING WITH MANUFACTURERS.THERE WILL STILL BE DIFFERENCES PLANNED BY PLAN BECAUSE ALL PLANTS ARE DESIGNED DIFFERENTLY AT THE END OF THE DAY, BUT AT LEAST FROM EQUIPMENT LIMITATIONS POINT OF VIEW, THERE IS NO POINT FOR EACH GENERATOR OWNER GOING BACK TO MANUFACTURER ONE BY ONE.
I, I, I THINK THAT THAT'S A VERY THOUGHTFUL, UH, APPROACH AND, AND I, I'M JUST GONNA KEEP COMING BACK TO THIS MODELING ISSUE BECAUSE I THINK IT'S SO FUNDAMENTAL TO THE PLACE THAT WE ARE AT.
AND AS WOODY EXPLAINED, IF WE, IF WE HAD BETTER RESOLUTION OF THE MODELING, WE COULD DO BETTER RELATIVE RISK ASSESSMENT.
AND THAT'S WHAT I'VE BEEN LOOKING FOR THROUGH THIS WHOLE PROCESS.
FIRST JUST WANNA HIT ONE PIECE THAT YOU MENTIONED ABOUT THE MODELING, WHICH I FULLY AGREE NEEDS TO BE IMPROVED, BUT I HAVE TO SAY THAT WE DO HAVE ISSUES GETTING MODELS FROM THE OEMS THAT HAPPENS EVERY DAY.
SO, SO YOU MENTIONED THAT, THAT YOU DIDN'T THINK THAT WAS A PROBLEM.
IT WAS MORE WHENEVER IT WENT FROM OWNER TO OWNER, WE HAVE PROBLEMS. UH, THAT HAPPENS ALL THE TIME.
THAT'S WHY A COUPLE EXAMPLES, AND I THINK IT MAY BE MENTIONED IN THE ERCOT UH, SLIDES, THAT WHEN THE RFI CAME OUT, YOU KNOW, THERE WERE ANSWERS PUT BACK IN.
AND I COULD TELL YOU FOR, FROM OUR PERSPECTIVE, THERE'S PROBABLY SOME NOS IN THERE BECAUSE WE COULD NOT GET THE MODELS OF THE DATA FROM THE, THE OEMS AND WE HAD TO SAY NO, 'CAUSE WE COULDN'T SAY YES.
SO I THINK, YOU KNOW, THAT'S ONE PIECE.
THE OTHER ONE IS TO THROW AN EXAMPLE LIKE THE TSAT, YOU KNOW, WE HAVEN'T GOT ALL THE TSAT S IN RIGHT NOW.
THEN THE RE PART OF THE REASON FOR THAT IS GETTING MODELS FROM THE OEMS. SO I, I THINK THAT THERE IS SOME IMPROVEMENT THAT NEEDS TO BE THERE.
AND I'M NOT POINTING OUT ANY OEM, UH, IN PARTICULAR, BUT I THINK WE DO NEED TO LOOK AT THAT FROM AN INDUSTRY.
UH, MIKE, WELL, CAN I JUST REFLECT TO THAT? YEAH, I THINK IT'S VERY GOOD COMMENT.
AND I THINK SAME COMMENT THAT I MADE BEFORE APPLIES TO OEMS AS WELL, IS WHERE SMALLER OEMS, UH, OR MAYBE LIKE, YOU KNOW, LESS KNOWN, UH, OEMS, THEY HAVE MORE ISSUES MM-HMM.
AND AS A RESULT IT REFLECTS POORLY ON THE ENTIRE TECHNOLOGY.
SO SAME THING EXISTS THERE AS WELL.
MY OTHER ONE WAS ON, WHEN YOU WERE TALKING ABOUT THE COMMERCIALLY VIABLE MM-HMM.
SO AM I, I'M JUST TRYING TO UNDERSTAND YOUR POSITION.
SO YOU'RE IN DISAGREEMENT WITH 9 0 1 THAT SAYS THAT YOU HAVE TO DO ALL OF THE STUFF THAT'S, UH, THAT'S SOFTWARE AND, AND THOSE THINGS, BUT IF YOU HAVE TO REPLACE HARDWARE, WHICH CAN BE EXPENSIVE, THAT YOU DON'T NEED TO DO THAT UNLESS YOU DO A REPOWERING OR SOME OTHER THING LIKE THAT.
SO YOU'RE SAYING THAT'S NOT THE WAY YOU WOULD GO? NO, THAT'S NOT WHAT I SAID.
SO WHAT I SAID IS, THAT'S WHAT I'M TRYING TO CLARIFY.
IN THE JOINT COMMENTERS VERSION, IT SAYS THE DECISION WHAT'S COMMERCIALLY VIABLE IS ON GENERATOR OWNER SIDE.
AND SO WHAT I THINK NEEDS TO HAPPEN IS YOU WORK WITH THE OEM AND YOU BRING LIMITATIONS, TECHNICAL LIMITATIONS, NO MATTER WHAT THEY ARE, BE IT EVEN I NEED TO EXCHANGE EQUIPMENT, THERE'S NOTHING ELSE I CAN DO.
YOU BRING IT TO ORCUTT AND YOU WORK WITH ORCUTT AND THEN THE DECISION IS MADE, WHAT CAN BE DONE AND WHAT CANNOT BE DONE.
AND I THINK SWAPPING INVERTERS, THAT'S NOT SOMETHING THAT ORCO WILL ASK YOU TO DO.
WELL, THAT I DON'T KNOW THAT ANSWER.
THAT'S WHY I'M BRINGING IT UP IS YEAH, BECAUSE, BUT NO MATTER MATTER WHAT THEY FIND, IF IT'S EQUIPMENT LIMITATION AND YOU CANNOT DO ANYTHING BUT SWAPPING YOUR INVERTERS, THAT NEEDS TO FIND ITS WAY IN THE MODEL.
OH, FULLY, FULLY AGREE WITH THAT.
EVERYTHING NEEDS TO BE IN THE MODEL.
EVERYTHING NEEDS TO BE DONE SO THAT, SO THAT ERCOT KNOWS EXACTLY WHAT TO EXPECT.
THEY'RE SAYING YOU GOTTA MAKE A CAPITAL EXPENDITURE.
AND IN A LOT OF CASES, IF THE OWNER HAS ALREADY SAID THAT'S NOT ECONOMICALLY VIABLE, THE PLANT'S LIKELY GONNA GO AWAY, IS WHAT CAN HAPPEN THERE.
AND THAT, I THINK THAT IS NOT NECESSARILY A PLACE WE WANNA BE EITHER, BECAUSE ALL THE GENERATION WE HAVE, WE NEED
SO I THINK THERE'S A BALANCE IN THERE SOMEWHERE THAT WE NEED TO HIT.
THERE NEEDS TO BE A BALANCE, BUT I THINK IT JUST, I THINK NEITHER WAY HAS TO BE, I MEAN, I WORKED FOR ERGOT 10 YEARS.
NEITHER WAY SHOULD BE THERE IN, IN HARD LANGUAGE BECAUSE IT CREATES BARRIERS FOR BOTH OF YOU FROM GENERATOR OWNER'S PERSPECTIVE IS, YOU KNOW, THIS COMMERCIAL REASONABILITY FROM ERCOT PERSPECTIVE, THIS, AM I RELIABLE? UM, I THINK YOU NEED TO WORK TOGETHER ON
[02:40:01]
YOUR LIMITATIONS AND, AND KIND OF MAKE CHANGES THAT MAKE SENSE AND LEAVE LIMITATIONS.THEY NEED TO FIND THIS WAY IN THE MODEL.
IF ORCO SEES THIS LIMITS, UH, ENDANGERING RELIABILITY, THEY'LL TAKE, UH, OPERATIONAL STEPS WHICH HAVE THE ABILITY FOR RELIABILITY HAVE THE ABILITY TO DO TODAY.
SO, UH, JULIE, WE'LL GET INTO THIS IN MY PRESENTATION SOME, BUT I, I WOULD LIKE YOUR REACTION WHEN WE GET TO IT BECAUSE I THINK SOME OF THE CONCERNS YOU RAISED ABOUT THE JOINT COMMENTER PROPOSAL, UM, MIGHT BE ADDRESSED BY THE TAC UH, RECOMMENDATION.
AND SO WE KIND OF POINT TO WHERE, AT THE CASE, I AGREE THAT THE RED LINE PROCESS IN THIS INSTANCE HAS MADE THIS TOO DIFFICULT FOR EVERYONE.
AND SO I JUST WANNA NOTE FOR EVERYONE THAT IF EVEN JULIA CAN'T FOLLOW ALL THE RED LINES, SOMETIMES MAYBE WE NEED TO HAVE A BETTER WAY TO GET THE TAC REPORT WRITTEN.
UM, BECAUSE OBVIOUSLY SHE'S, SHE'S HERE BECAUSE SHE'S THE EXPERT.
UM, SO, UM, ON, UM, BUT ON THOSE POINTS SPECIFICALLY, UM, SOFTWARE WILL BE REQUIRED.
IT'S ALWAYS COMMERCIALLY REASONABLE AND SETTINGS CHANGES, RIGHT? AND AS WE'LL GET INTO, AND I CAN GET INTO IT NOW IF YOU WANT TO, BUT I ALSO AGREE THAT WE COULD, WE CAN HOLD IT FOR THE NEXT PRESENTATION.
ERCOT DOES HAVE THE ABILITY TO REJECT THE COMMERCIAL REASONABILITY EXEMPTION REQUEST IF THEY DON'T THINK IT IS, UM, IF THEY THINK IT IS COMMERCIALLY REASONABLE.
SO, UM, AND, AND, BUT I JUST WANNA POINT THAT OUT NOW TO GIVE UP THE CONVERSATION.
I WOULD APPRECIATE YOUR REACTION LATER ON IF YOU'D LIKE.
I'M JUST, YOU KNOW, KIND OF THINKING HOW, HOW THAT COMMERCIAL REASONABILITY, UH, WILL BE LOOKING LIKE.
AND I CAN IMAGINE, AGAIN, LIKE MORE PROACTIVE GENERATOR OWNERS, DEVELOPERS BRINGING IN DETAILED TECHNICAL INFORMATION WITH COSTS OF EACH UPGRADE AND SAYING, YOU KNOW, THIS IS, THIS MAKES SENSE.
THIS IS SO MUCH PERCENT OF MY PROJECT COSTS.
AND, AND I ALSO CAN'T IMAGINE SOMEBODY JUST BRINGING, UH, YOU KNOW, JUST SAYING CAN DO THIS, CANNOT DO THAT.
AND THIS COSTS ME SO MUCH AND IT'S NOT ITEMIZED ENOUGH WHERE ORCO CAN EVEN LIKE LOOK INTO IT AND UNDERSTAND THIS.
THIS COMES FROM, UH, EVEN I-B-R-W-G.
I THINK AS WE STARTED LOOKING AT IMPACTS OF 2 45, PEOPLE WERE BRINGING PRESENTATIONS AND SOMETIMES IT WILL BE JUST CANNOT DO.
THAT WOULD BE INITIAL REACTION.
AND THEN OVER TIME, ASCOT WAS ASKING FOR MORE AND MORE DETAILS AND IT WENT INTO DIFFERENT VINTAGES OF I IBS AND, UH, WHAT THEY CAN AND CANNOT DO.
I THINK THAT'S WHAT THEY ARE LOOKING FOR.
AND I THINK THAT BECAUSE
SO, UH, WE THINK THAT WILL BE A, A STRONG PIECE OF EVIDENCE AND WE'RE, WE'RE HAPPY TO CLARIFY THAT PROCESS IF, IF IT WOULD BE VALUABLE.
BUT, UM, ANYWAY, I LOOK FORWARD TO THE NEXT PART OF THE CONVERSATION.
BILL BARNES, SO YOU TOUCHED ON ONE OF THE KEY ISSUES, WHICH IS THE RETROSPECTIVE, UM, APPLICATION.
AND I'M CURIOUS IN THE OTHER REGIONS THAT ARE IMP IMPLEMENTING, UH, IEEE 2,800, ARE THEY ALSO APPLYING RETROACTIVE AS WELL AS IT ONLY FORWARD LOOKING? SO CURRENTLY, UH, ALL OF THEM FORWARD LOOKING, UM, AS I SAID, SOME OF THEM APPLIED IT LAST YEAR, SO IT'S ALREADY APPLIES TO RESOURCES THAT CONNECTING FROM THEN ON.
SO LAST YEAR, FBL AUGUST, 2022, UH, OTHERS KIND OF SUMMER 2023.
SO THAT APPLIES GOING FORWARD.
UM, I TALKED TO SRP YESTERDAY AND I HEARD THEY ARE LOOKING, UM, TO DO, UH, BY 2,800 ADOPTION BY DETAILED REFERENCE INSTEAD OF, UM, GENERAL SPECIFICATION AS THEY DID INITIALLY.
SO INITIALLY THEY JUST SAID, THOU SHOULD BE 2,800, BUT NOW THEY THINK THEY NEED TO PROVIDE MORE INFORMATION.
AND SO THEY'RE LOOKING TO REVISE THAT AND THEY ARE POTENTIALLY CONSIDERING TO DO RETROACTIVE AS WELL, BUT THEY'RE JUST LIKE TAKING STEPS ON THAT ONE THING.
I MEAN, YEAH, IF YOU LOOK, YOU CAN SAY, YOU KNOW, ORCA IS THE ONLY ONE DOING THAT.
BUT ALSO IF YOU THINK ABOUT THAT ORCO HAS 70 GIGAWATT OF INVERTED BASED RESOURCES, THEY ARE, I BELIEVE MAYBE WITH, COMPARED TO SPP, MAYBE THEY'RE LIKE TAGGING ALONG, BUT THEY'RE ONE OF THE LARGEST STATES THAT HAS LARGEST SHARES OF INVERTED BASED RESOURCES ALREADY.
UH, AND THEY'RE SINGLE INTERCONNECTION.
SO THAT'S WHERE KIND OF I CAN SEE, UM, WHY THEY HAVE MORE NEED THAN OTHERS BECAUSE THEY'RE NOT SYNCHRONOUSLY INTERCONNECTED WITH THE REST AND NEED TO PROTECT FOR DISTURBANCES THAT HAPPEN IN NORCO.
OKAY, DINEH, UH, HI, I'M DINEH PERMAN.
[02:45:01]
UM, SO SOME OF OUR INVERTERS WERE INVOLVED IN THE ODESSA EVENTS.I JUST WANTED TO MAKE A COUPLE OF POINTS IN TERMS OF MODELING FOR SITES AS WELL AS INVERTERS.
SO WHAT WE HAVE SEEN HAPPEN IN OUR EXPERIENCE IS THAT WE PROVIDE INVERTER MODELS TO OUR CUSTOMERS TO DO STUDIES, AND THEY DO THE STUDIES, THEY BUILD A PLAN MODEL AND THEY TRY TO MEET ALL THE PERFORMANCE REQUIREMENTS SET BY KART THROUGH MQT STUDY.
AND THE MODELS GET SUBMITTED TO KART, BUT THOSE SETTINGS ARE NOT ALWAYS CARRIED OVER TO THE FIELD BECAUSE AS OEM, WE HAVE TO GET THOSE MODELS BACK FOR US TO BE ABLE TO PROGRAM THOSE SETTINGS ONTO THE INVERTERS IN THE FIELD.
SO WE SEE THAT GAP THERE THAT THIS DOESN'T SEEM TO BE HAPPENING.
AND WE HAVE SEEN THIS GAP FOR THE PAST TWO, THREE YEARS, UH, RECENTLY IT HAS BEEN CHANGING.
UM, I THINK WE HAVE CHANGED OUR PROCESS THAT WE RECOMMEND OUR CUSTOMERS DO A STUDY EVERY TIME SOMEBODY'S ASKING FOR A SETTINGS CHANGE IN OUR INVERTERS.
BUT THE SIGNIFICANT GAP HERE IS THAT ONCE THE STUDY IS COMPLETE, THE, THE MODELS NEED TO GO BACK TO THE OEM SO THAT THE OEM CAN PROGRAM THE RIGHT SETTINGS ON THE INVERTERS.
UH, AND THIS IS A MAJOR GAP THAT WE SEE.
AND I THINK NERC IS ALSO TRYING TO ADDRESS THIS BY COMING UP WITH A WHITE PAPER ON COMMISSIONING FOR THESE INVERTER SETTINGS.
UM, SO I'M, I'M, I'M IN A GROUP THAT, THAT IS DRAFTING THIS WHITE PAPER.
WE SEE THIS MOVING FORWARD AS A OEM.
WE HAVE DEVELOPED GUIDELINES NOW FOR, UH, GENERATOR OWNERS OR OPERATORS SO THAT THEY CAN, YOU KNOW, UNDERSTAND WHAT THE PROCESS IS FROM AN OEM PERSPECTIVE.
UH, I KNOW THAT YOU'VE HEARD FROM, FROM ISO PERSPECTIVE THAT, YOU KNOW, THE MODELS ARE NOT ACCURATE AND THAT ONE OF THE REASONS IT'S BECAUSE O OEMS ARE NOT GETTING THE MODELS BACK.
AND MAYBE THAT'S, THAT'S ONE OF THE FEEDBACK TO TAKE, I'M NOT SURE IF IT'S IN THE PLANNING GUIDE YET, BUT IT'S MAYBE ONE OF THE THINGS TO TAKE BACK TO, UM, BECAUSE THERE IS A PIECE ON MODEL VERIFICATION THERE NORCOTT PROTOCOLS RIGHT NOW.
BUT I THINK MAYBE THIS PIECE TO CAPTURE MAYBE HAVING AT A STATION FROM OEMS AT THE COMMISSIONING OF THE PLANT, THAT'S SOMETHING YEP.
IT IS SLOWLY CHANGING TO CAPTURE.
WE, WE SEE THAT NOW PARAMETER VERIFICATION REPORTS ARE REQUIRED BY KART.
SO SITES ARE COMING TO US AND, YOU KNOW, TAKING THE MODELS AND TAKING THE FIELD SETTINGS.
WE PROVIDE REPORTS OF SETTINGS INSTALLED IN THE FIELD AND THEY'RE DOING COMPARISONS TO MAKE SURE THAT IT'S THERE.
BUT WE DON'T SEE THIS HAPPENING AT ALL SITES.
BUT IT'S SLOWLY CHANGING, BUT THERE IS NO REQUIREMENT TO GET TO A M UM, AT THE STATION THAT PARAMETERS IN THE FIELD ARE SET AS IN THE MODEL IS THERE.
SO WE, WHENEVER WE DO A COMMISSIONING PROCESS, WE ASK OUR CUSTOMERS, DO YOU HAVE A MODEL THAT YOU WANT TO REFLECT IN THE FIELD? MM-HMM.
SO, BUT RECENTLY THIS HAS BEEN CHANGING.
WE ARE, WE ARE GETTING SETTINGS BACK FROM OUR CUSTOMERS, ESPECIALLY AFTER THE ODS EVENTS, WE ARE GETTING MORE MODELS.
UH, SO THAT IS SLOWLY CHANGING.
AND ONE OF THE REASONS WE ACTUALLY OBSERVED THIS IN THE OD SIDE IN WATER THAT TRI WAS THAT, UM, THESE INVERTERS WERE PROGRAMMED WITH DEFAULT SETTINGS THAT COME FROM THE OEM.
THEY DID NOT REALLY, UM, YOU KNOW, THE STUDY WAS MAYBE DONE.
WE, WE DID NOT KNOW ABOUT IT, BUT THE SETTINGS WERE DEFAULT SETTINGS.
BEFORE WE GO, ONE OF THE THINGS JUST TO, I, I REMEMBERED MENTIONING WHEN WE HAD IBR WG MEETINGS AS A FOLLOW UP OF ODESSA EVENTS, THERE WAS THIS ISSUE BY THE TIME LIKE TEAM I AND UH, POWER ELECTRONICS ACTUALLY FOUND A FIX, UH, ORCO SAID, WELL NOW GO IMPLEMENT THE FIX IN EXISTING PLANTS THAT, THAT HAVE THIS, UH, EQUIPMENT.
BUT THE, THE WAY THINGS WORK IS THAT THE GENERATOR OWNER AND DEVELOPER NEEDS TO GO BACK TO MANUFACTURER AND REQUEST IT FIRST.
AND SO BASICALLY, I GUESS LIKE MANUFACTURER CANNOT GO TO GENERATOR OWNER AND ASK TO IMPLEMENT THE SETTINGS, UH, AND NEEDS TO COME, THE REQUEST NEEDS TO COME FROM GENERATOR OWNER.
SO THERE IS THIS KIND OF GAP IN THE PROCESS AS WELL.
SO THAT ONE, JUST TO COMMENT ON, UM, WE HAVE WORKED WITH ERCOT AS A WAY OF ADDRESSING IT.
WE HAVE REQUESTED ERCOT ISSUE A MARKET NOTICE, AND THEY HAVE ISSUED NOTICE TO ALL GENERATOR OWNERS TO UPDATE SETTINGS TO COME BACK TO T MIC OR WHERE THE OEMS. AND WE HAVE ADDRESSED IT THAT WAY.
SO EVEN THOUGH WE CANNOT CONTACT EVERYONE DIRECTLY, WE'VE DONE IT THROUGH A CARD.
MY QUESTION IS, UH, JULIA, YOU MENTIONED, I THINK VERBALLY DURING
[02:50:01]
THE SLIDES THAT, YOU KNOW, THE IBR ARE MUCH MORE DIFFERENT SOFTWARE BASED, AND I THINK YOU MADE A REFERENCE TO ONE OF THE MODELS, TSAP MODELS THAT ERCOT HAS REGIONAL MODELS.BUT YOU, YOU MADE A COMMENT THAT EVEN ERCOT HAS ALL THE INFORMATION, ALL THE SETTINGS FROM EVERY GENERATOR.
THERE IS NOT CAPABILITY TO MAKE LARGE SCALE SIMULATION.
LIKE THERE IS NOT ENOUGH POWER.
CAN YOU PLEASE TALK ABOUT THAT? LOOK, EVEN IF ORCA WANTED GET EVERYTHING THEY WANTED, BUT THEY STILL CANNOT SIMULATE THE ORCA SYSTEM, OR MAYBE I MISUNDERSTOOD.
SO, SO THERE IS A MIX OF SEVERAL THINGS.
UH, ERCOT CURRENTLY, LET'S TRY TO UNWRAP IT.
UH, ERCOT CURRENTLY REQUIRES TSAT MODEL, PSSE MODEL.
SO TSAT AND PSSE, THEY USE ABOUT SAME, UM, LEVEL OF DETAIL, UM, IN THE MODELS.
UM, AND, AND THIS IS MORE UNDERSTOOD AND MORE WIDELY USED IN THE INDUSTRY FOR MANY, MANY YEARS NOW.
UH, AND FOR THOSE TYPES OF MODELS, ORCA ONCE RECEIVE DETAILED AND, UH, UH, ACCURATE MODELS THEY CAN SIMULATE.
UH, THERE IS ALSO ANOTHER TYPE OF SIMULATION ENVIRONMENT CALLED, UH, ELECTROMAGNETIC TRANSIENT.
SO THESE MODELS ARE MUCH MORE DETAILED AND THEY REPRESENT KIND OF MILLISECOND BY MILLISECOND WHAT'S HAPPENING IN THE EQUIPMENT.
AND THESE TYPES OF MODELS ARE MUCH MORE DETAILED.
UH, THEY'RE THREE PHASE, AND, UH, THEY REQUIRE MUCH LONGER TIME TO SIMULATE.
SO FOR THESE TYPES OF MODELS, ERGOT REQUIRES THESE MODELS.
UH, A LOT OF, UH, PERFORMANCE ISSUES CAN BE CUT IN MODEL QUALITY TESTS EVEN FOR THIS TYPE OF MODEL.
SO EVEN LIKE TESTING SINGLE MODEL ON AN EQUIVALENT FOR ERGOT SYSTEM, YOU CAN LOOK AT PERFORMANCE OF THAT PLANT AND VERIFY IF IT COMPLIES WITH REQUIREMENTS OR IT DOESN'T.
UH, BUT FOR WIDE SYSTEM STUDY, ERCOT CURRENTLY DOESN'T HAVE A MODEL THAT REPRESENTS THE ENTIRE ERCOT IN EMT.
UH, IT HAS PIECES OF THE, UH, SYSTEM THAT'S REPRESENTED IN EMT, WHICH IS LIKE PANHANDLE, UH, NEAR PANHANDLE AREA AND SOUTH TEXAS AREA WHERE THEY CAN DO THIS MORE DETAILED STUDY AND LOOK AT, UM, KIND OF MORE, UH, SYSTEMATIC PERFORMANCE ISSUES FROM IBS.
BUT THIS IS KIND OF WHAT, WHAT YOU CANNOT CAPTURE IN EMT MODEL IS A SUBSET OF THIS FASTER RESPONSES FROM IBS AND FASTER TRIPPING FROM IBS.
THAT'S NOT THE MODELING NEEDS.
ERCOT HAS BEEN TALKING REGARDING NO, 2, 4, 5, RIGHT? THAT'S TWO DIFFERENT RISKS, TWO DIFFERENT ISSUES, RIGHT? ERCOT, I, I WOULD SAY IT'S TWO DIFFERENT ISSUES.
SO THERE'S ONE ISSUE WHERE THE POSITIVE SEQUENCE MODELS, UH, BOTH THE PSSE AND, AND TSAT ARE NOT ACCURATE.
MEANING THEY DON'T REFLECT REAL WORLD BEHAVIOR.
THERE'S TRIPS THAT HAPPEN AND THE SIMULATION SAYS IT SHOULDN'T.
BUT I THINK WHAT WE'RE ALSO SAYING HERE IN THE DIFFERENCE IN EMT MODEL IS MORE DETAILED AND MAY HAVE ADDITIONAL THINGS THAT WILL SHOW TO TRIP THAT A POSITIVE SEQUENCE MODEL DOES NOT.
AND SO YOU TRY TO COMPARE THE TWO TO MAKE SURE THAT THE POSITIVE SEQUENCE MODEL WILL AS ACCURATELY AS POSSIBLE, REFLECT THE SAME LEVEL OF PERFORMANCE THAT THE VERY DETAILED MODEL DOES.
BUT THEN THERE, THE NEXT LEVEL OF COMPLICATION IS HOW DOES THE VERY DETAILED MODEL INTERACT WITH ALL THE OTHER VERY DETAILED MODELS AROUND IT, NOT JUST AT ONE PLANT BECAUSE THERE'S CONTROL INTERACTIONS.
UM, BUT WOODY'S PRIMARY COMMENTS AT THE VERY BEGINNING WAS JUST THE POSITIVE SEQUENCE MODELS THAT WE USE IN EVERYDAY OPERATIONS AREN'T REFLECTING THESE BEHAVIORS THAT WE'RE OBSERVING ON THE SYSTEM.
THAT'S THE FIRST MAJOR ISSUE OF MODEL QUALITY.
BUT ALSO COMING BACK TO WHAT CAN AND CANNOT BE EVALUATED, STEVEN, IF YOU LOOK AT, UM, ESSA EVENT AND CAUSES OF TRIP, I BELIEVE LIKE THREE CAUSES OF TRIP WERE ONES THAT CANNOT EVEN BE REPRESENTED IN PHASER DOMAIN MODELS BECAUSE JUST THE WAY THAT, UM, KIND OF ASSUMPTIONS WORK THERE AND HOW NOT DETAILED THIS, THIS SIMULATIONS ARE, UH, THIS THREE CAUSES OF EVENTS CAN ONLY BE REPLICATED IN EMT.
SO THEN NOW SAY YOU DON'T HAVE THIS TRIPPING,
[02:55:01]
UH, FUNCTIONS SET IN THE MODELS.YOU RECEIVE THE EMT MODEL, YOU RUN IT THROUGH A MODEL QUALITY TEST, IT PERFORMS NICELY AND YOU ASSUME IT WILL WORK.
UH, IF YOU RUN EMT STUDIES, SAY ON PANHANDLE AREA, AND YOU APPLY THIS FAULT THAT CAUSES THAT CAUSE ODESSA, THEN YOU DON'T SEE IT.
AND SO EVEN IF THE LIMITATIONS ARE DONE IMPLEMENTED BACK INTO THE MODELS EMT MODELS, YOU STILL NEED TO DO EMT STUDY TO SEE WHAT IT DOES TO AT LEAST THIS PART OF THE SYSTEM, UM, HAVING THIS LIMITATION IN THE, IN THE PLANT.
LET'S GO TO, UM, ANDY GALLO AND THEN BOB HILTON.
AND I, I THINK WE'LL TRY TO WRAP THIS PART OF THE WORKSHOP OFF UP AFTER THOSE TWO COMMENTS AND THEN WE'LL BREAK FOR LUNCH.
UH, ANDY, ARE YOU WITH US, SANDY? ALL RIGHT, LET'S GO TO BOB.
YEAH, JUST REAL QUICKLY, JULIA, UH, YOU KNOW, WHENEVER BILL ASKS HIS QUESTION ON, ON THE, THE, THE TACK PROOF COMMENTS, KIND OF WHERE WE ENDED UP TALKING WAS RETRO AND EVERYTHING ELSE IN THAT MANNER.
SO I JUST HAD A QUESTION SO WE COULD KIND OF COVER THE WHOLE GAMBIT.
DO YOU SEE THAT THE TAC DO YOU SEE WHETHER THE TAC COMMENTS OR OR APPROVED REPORT IS HEADING IN THE SAME DIRECTION AS AS NERC? YOU KNOW, THE, THE 28, 29, 30 AND 2,800.
DO YOU THINK THAT'S, THAT THAT MEETS THAT? OR DO YOU SEE AN ISSUE THERE ALSO THAT WE NEED TO CONSIDER ON NEW INTERCONNECTIONS THAT WE'RE GOING FORWARD WITH? ON, ON THE TECHNICAL REQUIREMENTS YOU MEAN? YEAH.
MOST TECHNICAL REQUIREMENTS AND IMPLEMENTATION OF THOSE REQUIREMENTS.
YEAH, I GUESS ONE THING WHERE I NEED TO UNDERSTAND BETTER IS THE, UM, DIFFERENCE IN THE IMPLEMENTATION DATE.
SO IF YOU, AS I, AS I MENTIONED, IF YOU LOOK AT OTHER AREAS THAT HAVE, UH, ADOPTED IT, IT WAS FROM LAST YEAR, RIGHT? UM, THEORETICALLY THE STANDARD BUS BEEN OUT THERE TWO YEARS.
UM, IF I UNDERSTAND CORRECTLY, AND CORRECT ME IF I'M WRONG, THERE IS STILL A WAY TO APPLY FOR EXEMPTIONS OR, YOU KNOW, REPORT YOUR LIMITATIONS TO ERCOT.
IF WITH NEW EQUIPMENT YOU CANNOT COMPLY WITH 2,800 REQUIREMENTS OR WRITE THROUGH REQUIREMENTS THAT ERCOT ADOPTED.
SO THAT'S LIKE, I DON'T SEE BIG ISSUE WITH THIS ONE YEAR DIFFERENCE.
LIKE WHY, WHY THIS ONE YEAR, BECAUSE THE STANDARD BEEN AROUND FOR A WHILE.
THERE IS OEMS KNOWN ABOUT THAT FOR A WHILE.
THERE ARE SOME LIKE SMALL THINGS AROUND, UM, MULTIPLE RIDE THROUGH AND ROCK OFF AND FACE JUMP THAT WE NEED STILL TO IRON OUT ON THE VALID CONFORMITY ASSESSMENT SIDE.
BUT FROM THE CAPABILITY PERSPECTIVE, I THINK IT SHOULD BE POSSIBLE TO IMPLEMENT FROM LIKE LAST YEAR IMPLEMENTATION DATE.
SO YEAH, I MAYBE, I DON'T UNDERSTAND LIKE WHERE THE UM, WHAT THE LIMITATION STEMS FOR FROM, JUST TO FOLLOW UP NOW, 2,800 HAS A WHOLE LOT OF OTHER THINGS IN IT.
UH, BUT I, I'M SPECIFICALLY TALKING ABOUT THE VOLTAGE RIDE THROUGH ISSUE.
SO ARE YOU SAYING THAT LAST YEAR THERE WERE, THAT WHOEVER'S IMPLEMENTING 2,800 IMPLEMENTED VOLTAGE RIDE THROUGH RIGHT THROUGH REQUIREMENTS STANDARDS THAT WE HAVE, LIKE WE'RE TALKING ABOUT TODAY? YES.
SO, SO LIKE S-R-P-F-P-L MISO, UM, IT ALL NOW APPLIES TO EQUIPMENT THAT WILL GO COMMERCIAL, UM, AND, AND FROM THAT DATE THAT THEY ADOPTED IT.
OKAY, I THINK WE CAN WRAP THAT UP HERE FOR, FOR NOW WITH JULIA AND WE'LL TAKE 15 MINUTE BREAK, 15 MINUTE BREAK LUNCHES HERE.
UM, AND SO WE'LL GET STARTED AT 1245 OR MAYBE MORE REALISTICALLY 1250.
UM, AND THEN WE STILL HAVE A PRETTY LENGTHY AGENDA, SO, UM, MAYBE I'LL TALK TO A COUPLE PEOPLE OFFLINE DURING LUNCH AND, AND TRY TO COME BACK WITH, WITH SOME REALISTIC GOALS FOR TODAY.
[03:00:05]
YES.WE'RE GONNA GET READY TO, WE'RE JUST GONNA GET STARTED AND EVERYBODY WILL SHOW UP IN THE ROOM SOON.
[Items 6 & 7]
ON TO THE ERCOT PRESENTATION.I THINK WE'RE GONNA START WITH THE ANALYSIS BY OF THE RFI.
IS THAT RIGHT? NO, WE'RE NOT GONNA START WITH THAT.
WE ARE GONNA START WITH THE POWERPOINT, THE SCARY 45 SLIDE POWERPOINT.
SO I, I THINK WHAT, UH, THE REASON NOT FOR DOING THE, UM, UM, SURVEY RESULTS IS, I THINK WE'VE SUMMARIZED A LOT OF IT IN THE COURSE OF THE PRESENTATION, BUT WHEN WE GET THROUGH, IF YOU'VE GOT MORE QUESTIONS ABOUT THAT, THAT YOU WANNA GO LOOK AT IT DISCREETLY, THEN WE CAN DO THAT.
UM, SO I THINK FROM A HISTORY PERSPECTIVE, COLIN WENT OVER THIS THIS MORNING, SO I'M NOT GONNA GO OVER THIS SLIDE A LOT.
UM, THERE'S BEEN LOTS OF WATER UNDER THE BRIDGE ON THIS.
SO THE BOARD REMANDED, UH, 2 45 BACK WITH INSTRUCTIONS TO ADDRESS THE RELIABILITY CONCERNS THAT WE HAD, UM, TO PROVIDE DETAILED COMMENTS ON, UM, SUPPORTING WHATEVER VERSION THAT TAC SENDS BACK TO THE BOARD, PROVIDING DETAILED COMMENTS EXPLAINING WHY THAT MAKES, UH, SENSE AND WHY IT, UM, DOES OR DOES NOT ADDRESS ERCOT, UH, RELIABILITY CONCERNS.
AND SO THAT'S KIND OF THE, THE, THE GOAL, I GUESS, OF THE NEXT THREE MEETINGS THAT WE'RE GONNA HAVE.
I, I NEED TO TALK TO ANNE AND MAYBE WE'LL TALK TO CHAD, BUT I, I THINK AS FAR AS GETTING COMMENTS FROM THE BODY, UM, WE, WE JUST MIGHT NEED SOME FEEDBACK ON THE BEST WAY TO DO THAT.
I KNOW THAT WE ARE ALWAYS GONNA HAVE KIND OF THE T REPORT THAT NOW INCLUDES ALL THE, THE EXPLANATIONS FOR NO VOTES.
UM, BUT I WANNA MAKE SURE THAT WHATEVER WE GET IS RESPONSIVE TO, TO THESE QUESTIONS, BUT IT'S A LITTLE BIT UNUSUAL AND TRICKY, I THINK, TO COME UP WITH DETAILED WRITTEN COMMENTS ON BEHALF OF THE WHOLE TAC BODY.
SO, UM, CHAD, IF YOU WANNA SAY ANYTHING NOW, BUT, BUT I THINK ANNA AND I WILL, WILL GET WITH YOU AND, AND MAKE SURE WE HAVE A PLAN FOR HOW TO DO THAT.
YEAH, WE CAN WORK THROUGH THAT PROCESS.
IT'LL, ARE YOU TALKING ABOUT HOW WE'RE GONNA RESPOND BACK TO THE BOARD? YES.
AND WHETHER WE'RE ANSWERING ALL THE QUESTIONS THAT WERE PUT INTO THE ERCO PRESENTATION.
UM, IS THAT WHAT YOU'RE TRYING TO DEAL WITH? NOT, I DON'T KNOW IF THE QUESTIONS EXACTLY.
HAVEN'T CONFIRMED THAT THE QUESTIONS HERE MATCH WITH THE BOARD, BUT SO THE BOARD DIRECTION, I BELIEVE THE ACTUAL ACTION WAS A REMAND, BUT INCLUDED IN THE DIRECTION WAS TO ANSWER QUESTIONS THAT HAD BEEN IN YEAH.
UM, I MEAN, I, I WOULD AGREE THAT THIS SLIDE HAS A ACCURATE CHARACTERIZATION.
I'M TALKING ABOUT THE QUESTIONS LATER ON IN THE, THE PRESENTATION THAT WE ARE, ARE NOT GOING TO, I THINK WE'LL GET THERE WHEN WE GET THERE.
I, I CAN MAKE MY COMMENTS WHEN WE GET TO THE FIRST QUESTION IF YOU WOULD LIKE.
I THINK AS FAR AS THIS, AND I'M, BUT I BET YOU HAVE AN OPINION ON THIS.
I MEAN THAT IN A NICE WAY, UM, ON HOW TO GET THE BOARD, YOU KNOW, IF, IF WE NEED TO GET THEM SPECIFICS IN WRITING.
I THINK THAT'S A LITTLE BIT UNUSUAL FOR TAC WE DO ALWAYS HAVE A TAC REPORT THAT INCLUDES, YOU KNOW, WHY, WHY THERE IS OPPOSITION.
UM, BUT I JUST WANT TO MAKE SURE WE'RE WORKING WITH, WITH
SO SOME OF THE, WE PROVIDING A SUMMARY ON THIS SLIDE OF SOME OF THE DISCUSSION THAT WENT ON, UH, FROM BOARD, BOTH BOARD MEMBERS AND, AND SOME OF THE COMMISSIONERS.
AND THE IDEA IS THAT, THAT, I MEAN, THE ONE, SO ONE OF THE IDEAS WAS THAT RELIABILITY IS PARAMOUNT.
IF, IF THERE'S A CONFLICT BETWEEN COST AND AND RELIABILITY.
WE'VE GOT TO MAINTAIN RELIABILITY.
UM, THAT ERCOT IS IN EVALUATING.
IF, IF ERCOT ISS IN THE DRIVER'S SEAT OF EVALUATING EXEMPTION REQUESTS, THEN WE HAVE TO BE ABLE TO CONSIDER RELIABILITY IN THAT.
ONE OF THE OTHER, UH, COMMENTS THAT WAS MADE WAS THAT, UH, WHATEVER CONSIDERATION OF COMMERCIAL REAL REASONABILITY THERE IS NEEDS TO HAVE FIRM CRITERIA THAT'S APPLIED, UM, OBJECTIVELY AND HAS EVIDENCE IN CASE OF AN APPEAL TO THE PUC.
UM, AND IT, THEN THERE WERE OTHER COMMENTS THAT IT NEEDED
[03:05:01]
TO, IM CONSIDER THE IMPACT ON THE CITIZENS OF TEXAS OR RELIABILITY FAILURE IMPACT THE, UM, TEXAS CITIZENS OF, UH, THE COST OF TRANSMISSION SOLUTIONS.SO WE CAN'T JUST LET THE PROBLEM EXIST.
THERE'S EITHER GONNA BE, IF, IF IT'S NOT FIXED THROUGH THE RESULTS OF NORE 2 45, THEN IF THERE IS A WAY TO FIX IT THROUGH TRANSMISSION SOLUTIONS, WE'RE GONNA HAVE TO DO THAT, WHICH THAT'S AN IF AND IF NOT, THEN WE'RE GONNA HAVE TO HAVE CURTAILMENT.
AND SO THAT, THAT THERE'S, THERE'S COST TO ALL THAT AND THOSE NEED TO BE CONSIDERED.
AND THEN IT ALSO NEEDS TO BE CONS, UH, CONSIDERED WHETHER THE, THE RESOURCE ENTITIES HAVE A COST OF NON-COMPLIANCE.
AND SO THERE'S BASICALLY THAT, THAT COST FUNCTION AND WHATEVER IT IS, NEEDS TO CONSIDER ALL THOSE THINGS, NOT JUST THE PROFITABILITY OF THE, UH, INDIVIDUAL RESOURCE OWNERS ON THAT PARTICULAR PROJECT.
UM, THE, UM, COMMERCIAL STANDARD, UH, THAT DOESN'T ALLOW US TO LOOK AT, AT RELIABILITY ISN'T ACCEPTABLE, WAS A, A ANOTHER WAY OF REFERRING TO THAT, AND MAINLY BECAUSE OF THE CONCERN THAT THAT WOULD LEAD TO JUST MANY, MANY APPEALS TO THE PUC.
AND SO THAT'S ANOTHER ARGUMENT FOR IT BEING A, UH, OBJECTIVE STANDARD, WHATEVER IT IS.
AND, UM, SO IN ALL THIS DISCUSSION ABOUT COSTS, YOU KNOW, WE'RE, WE'RE TALKING ABOUT SOME REALLY BIG NUMBERS, RIGHT? I MEAN, IF YOU START LOOKING AT WHAT THE COST OF US HAVING TO SHED LOAD, BECAUSE THERE'S A BIG, YOU KNOW, THE, IF UNDER FREQUENCY LOAD SHED WERE TO ACTIVATE, EVEN IF IT'S 5% OF THE LOAD, THAT'S A LOT OF LOAD THAT WOULD BE OUT.
AND EVEN IF YOU USE OUR KIND OF AVERAGE VALUE OF LOSS LOAD THAT'S IN EXISTENCE TODAY OF $5,000 A MEGAWATT, THAT'S A, THAT MEGAWATT HOUR, THAT'S A, THAT'S A BIG NUMBER.
AND THAT'S REALLY WHAT WE'RE TRYING TO ILLUSTRATE HERE, IS THAT THAT, YOU KNOW, THE, WHEN WE CONSIDER THESE COSTS, THE COSTS OF OUTAGES IS, IS REALLY BIG NUMBER.
AND THESE ONLY, THIS ONLY CONSIDERS THE 5,000 MEGAWATT DOLLARS A MEGAWATT HOUR.
THE CONTROLLER, UH, ESTIMATED THAT YURI WAS A LOT MORE EXPENSIVE THAN THAT TAKING INTO ACCOUNT NOT JUST THE DIRECT COST, BUT KIND OF THE DOWNSTREAM COST OF SOCIETY, NOT JUST IN TEXAS, BUT BEYOND.
AND SO, UM, THE, WE REALLY HAVE TO CONSIDER RELIABILITY WHEN WE'RE CONSIDERING THE, THE, THAT IF WE'RE GONNA DO A COST CALCULATION OF WHAT'S, WHAT'S, WHAT'S IT WORTH TO FIX THIS? IT'S SOME REALLY BIG NUMBERS ON THE COST OF NOT HAVING RELIABILITY SIDE.
SO WE'VE TRIED TO, UH, ILLUSTRATE HERE THAT, THAT WE, UH, THAT KIND OF WHAT ARE, WHAT ARE, WHAT ARE WE PROPOSING? WHAT ARE, WHAT ARE WE PROMOTING IN, IN NO 2 45? UM, AND ONE OF THE THINGS IS, WE, WE'VE TALKED ABOUT IT A LOT THIS MORNING, UM, THAT IF WE'RE GOING, IF WE'RE GONNA DO SOFTWARE PARAMETER UPGRADES, FIRMWARE UPGRADES, THOSE CAN'T BE JUST TO THE, UH, TO THE KIND OF THE MINIMAL REQUIREMENTS.
IT NEEDS TO BE ALL THE WAY UP TO THE, UH, FULL CAPABILITY OF THE EQUIPMENT.
ESPECIALLY IF THESE, THE COST OF THE SOFTWARE PARAMETER UPGRADES ARE RELATIVELY LOW AND EVERYBODY AGREES IT'S A GOOD IDEA TO DO IT.
WHY JUST DO IT TO THE POINT THAT YOU'RE, YOU'RE MEETING THE REQ MINIMUM REQUIREMENTS, NOT GOING ALL THE WAY UP TO KIND OF WHAT, WHAT THE EQUIPMENT ITSELF CAN DO.
THAT'S, THAT'S THE RE THAT WAS THE RECOMMENDATION FROM SOME OF THE NERC, UH, WORK.
UM, IT SHOULD BE WHAT WE'RE PROPOSING AS WELL, THE EXEMPTION PROCESS.
AND I THINK WE ARE, WE'RE IN AGREEMENT THAT THERE SH SHOULD BE AN AGREEMENT PROCESS.
SO BACK TO MARK DREYFUSS COMMENT ABOUT WHAT, WHAT ARE WE AGREEING ON? I THINK WE'RE AGREEING IN GENERAL THAT THERE SHOULD BE AN EXEMPTION PROCESS, BUT WHAT ARE THE GUARDRAILS AROUND THAT EXEMPTION PROCESS? ONE OF THEM IS THAT WE'VE GOTTA BE ABLE TO CONSIDER THE RISKS TO RELIABILITY AND THE COST TO SOCIETY OF NOT HAVING RELIABILITY IN ADDITION TO JUST LOOKING AT, AT, UH, KIND OF THE, THE PROFITABILITY OF INDIVIDUAL PLANTS WHEN CONSIDERING THAT, UM, EXEMPTION, WHETHER, WHETHER IT'S APPROVED OR NOT, UM, THAT THERE SHOULDN'T.
THE SECOND ONE IS THAT THERE SHOULDN'T BE AN EXEMPTION FOR THAT ALLOWS PEOPLE TO, I I THINK JULIA CALLED THEM FOLKS THAT AREN'T AS ENGAGED TO NOT GO OUT AND TRY TO IDENTIFY EVERY PLACE THAT, THAT THEY'VE GOT, THEY HAVE A POTENTIAL FAILURE.
BUT, UH, INSTEAD FORCE EVERYBODY GO OUT AND FIGURE OUT, REALLY FIND
[03:10:01]
OUT FROM YOUR, YOUR PLANT, UH, OEMS, UH, MAKE SURE THAT YOU UNDERSTAND WHAT ARE YOUR SETTINGS ARE, AND, AND THEN ASK FOR AN EXEMPTION OF THAT IF IT'S GRANTED.THERE'S NO SUBSEQUENT EXEMPTIONS, AS I TOLD THE BOARD.
IT DOESN'T MAKE SENSE TO CONTINUALLY LOWER THE, THE, THE STANDARD BY NOT IDENTIFYING THOSE, UH, PROBLEMS. AND THEN CONTINUING TO, TO ASK FOR EXEMPTIONS EVERY TIME YOU HAVE A FAILURE.
UM, ONE, THERE'S A COST TO THOSE FAILURES, AND TWO, THAT'S JUST NOT, NOT THE RIGHT WAY TO, TO KIND OF IDENTIFY WHAT THE PROBLEMS ARE IS THROUGH A FAILURE.
UM, THAT INCLUDES THIS CONCEPT OF PHASE ANGLE JUMP.
AND, AND, UH, ROV, UH, WE TALKED ABOUT EARLIER THAT THERE'S NO REAL WAY TO MEASURE IT THE WAY THE THE TAC APPROVED VERSION IS WRITTEN TODAY.
THERE'S, UH, BASICALLY SAYING, WELL, WE DON'T KNOW HOW TO MEASURE IT, SO LET'S JUST LET US, UH, MAKE IT WHERE WE'RE NOT, UM, RESPONSIBLE FOR ANY TRIPS THAT HAPPENED BECAUSE OF THAT.
THAT'S NOT REALLY THE RIGHT ANSWER.
THE RIGHT ANSWER IS TO LET'S, LET'S DEFER THAT SOLUTION UNTIL WE CAN FIGURE OUT HOW TO SOLVE IT AND KEEP THE, UH, NOT ALLOW EXEMPTIONS FOR THAT.
UM, THE, UM, IF THERE IS SOMETHING THAT COMES UP THAT DOESN'T RESULT IN AN, UH, THAT, THAT AFTER YOU'VE GONE THROUGH THIS EXEMPTION PROCESS, WE'VE APPROVED WHATEVER EXEMPTIONS OR WOULD OCCUR, UM, ONCE THAT'S BEEN DONE, IF THERE'S SOMETHING ELSE THAT COMES UP THAT YOU DIDN'T DIG INTO ENOUGH TO FINALIZE, FI FIGURE OUT THAT YOU NEEDED TO ASK FOR AN EXEMPTION FOR THEN, AND THEN YOU HAVE A FAILURE THAT NEEDS TO BE MITIGATED.
UH, NOT, THERE'S NO GET OUTTA JAIL FREE CARD FOR THAT.
IT'S, IT'S THAT WE NEED, YOU NEED TO FIX THE PROBLEM AND GET BACK UP TO THE PERFORMANCE THAT, THAT, THAT YOU SAID YOU COULD DO.
SO THAT'S ONE OF THE THINGS THAT WE'RE, UH, WOULD BE SUPPORTIVE OF AN EXEMPTION PROCESS THAT INCLUDES THAT, UM, THE, UM, THE TIMEFRAMES THAT ARE IN THE TAC APPROVED VERSION FOR US, LOOKING AT ALL THESE EXEMPTIONS ARE VERY SHORT.
I THINK OF THE INITIAL, WHETHER WE WE NEED TO ASK FOR MORE INFORMATION OR NOT IS ONLY 10 DAYS.
AND THE PRESUMPTION IS A LOT OF THESE ARE GONNA COME IN AT THE SAME TIME.
SO THAT REALLY DOESN'T GIVE US ENOUGH TIME TO LOOK AT IT.
AND SO WE ARE SUPPORTIVE OF AN EXEMPTION PROCESS THAT GIVES US SUFFICIENT TIME TO ACTUALLY REVIEW THOSE THINGS.
UM, THE, UM, WE'VE BEEN HAVING THIS DISCUSSION ABOUT WHAT'S THE RIGHT DATE TO START, UM, ENFORCING THE, UH, IEEE 2,800 STANDARD AS OPPOSED TO THE LEGACY STANDARD.
UM, AND SO WHAT WE'RE, WE WOULD BE SUPPORTIVE OF IS HAVING THAT BE BACK WITH THE TIME THAT WE, UH, SIX MONTHS AFTER WE FILED THIS, THIS NOER, BUT WITH A, A, A EXEMPTION PROCESS THAT ALLOWS FOLKS THAT HAVE ALREADY BOUGHT EQUIPMENT THAT CAN'T BE UPGRADED TO, TO MEET THE REQUIREMENTS, THEN WE WOULD, UH, UH, SUPPORT, UH, GOING THROUGH THIS EXEMPTION PROCESS THAT WE'RE TALKING ABOUT HERE WITH THOSE RESOURCES AS OPPOSED TO KIND OF THIS, THIS IDEA OF LET'S JUST PUSH THE REQUIREMENT OUT INTO THE FUTURE.
UH, AND EVEN THOUGH THESE PLANTS COULD DO IT, NOT MAKING THEM DO IT.
AND WE'LL TALK MORE ABOUT THAT WHEN WE GET TO THE SUBSEQUENT SLIDE.
AND FINALLY, UM, THE, THERE WAS SOME DISCUSSION THAT I THINK THE JOINT COMMENTERS HAD BACKED OFF OF THAT SAYS, ERCOT WOULDN'T BE ABLE TO IMPOSE OPERATIONAL RESTRICTIONS IF THE, UH, UNIT, UH, IS CAUSING A PROBLEM ON THE SYSTEM.
AND WE JUST CAN'T, UH, ENDORSE ANYTHING LIKE THAT AS AN EXEMPTION.
AND SO, UM, I THINK THAT THAT KIND OF GIVES YOU THE HIGH LEVEL OVERVIEW.
I AM GONNA SPEND MORE TIME GOING THROUGH EACH OF THESE IN MORE DETAIL AND PROVIDING THE FACTS AROUND WHY WE BELIEVE THAT THOSE ARE IMPORTANT, UH, TO, UH, AND THE WAY WE'LL DO THAT IS THROUGH, THIS IS KIND OF THE ROADMAP, IF YOU WILL, UH, EACH OF THESE ISSUES.
AND THEY'RE REALLY THE, THE FLIP SIDE OF WHAT I JUST SAID, WE WOULD SUPPORT THESE THINGS.
THIS IS KIND OF THE, THE ISSUES THAT ARE IN THE TACT LANGUAGE THAT NEED TO BE RESOLVED IN ORDER FOR US TO, TO MEET THESE, THESE, UH, UH, THINGS THAT WE COULD SUPPORT.
[03:15:01]
HAD TIME TO LOOK AT THIS, UH, THE, THIS IS KIND OF THE ROADMAP IN THAT WHEN WE TALK ABOUT THE INDIVIDUAL ISSUES ON THE SUBSEQUENT SLIDE, THEY'RE REFERENCED BACK TO THESE ISSUE ONE, ISSUE TWO A, ISSUE TWO B, AND SO FORTH.AND SO, UM, I'M NOT GONNA GO THROUGH THIS.
I'LL GO THROUGH IT AS WE GO THROUGH THE, UH, INDIVIDUAL SLIDES.
I THINK WE HAD AT LEAST ONE QUESTION, ERIC, I THINK YOU WERE ON THE FIRST SLIDE TOO, RIGHT? YEAH.
UH, ON THE, UH, THE SLIDE WITH THE NUMBERS.
UM, SO THE PRIOR SLIDE, THAT ONE, YEAH.
SO, UM, I APPRECIATE THE INTENTION OF, OF THIS SLIDE, BUT, UM, SINCE YOU PUT IT IN THIS CONTEXT THAT THE LOLP THAT YOU'RE ASSUMING HERE IS ONE, RIGHT? NO, IT'S, IT'S THAT IF, IF THE, UH, IF AN EVENT HAPPENS THAT, UH, LASTS, UH, EIGHT HOURS AND IS 5,000 MEGAWATTS OF LOAD THAT'S OUT FOR THAT EIGHT HOURS, IF YOU TAKE THAT MEGA MEGAWATT HOURS AND MULTIPLY TIMES 5,000, YOU GET, UM, THE 200 MILLION.
SO, OH, I THINK WE JUST SAID THE SAME THING, BUT YOU SAID NO, RIGHT? CLAYTON, YOU'RE IN THE Q2.
IF YOU WANNA JOIN THE CONVERSATION, YOU TALK ABOUT THE SAME THING.
IT'S EIGHT TIMES, 5,000 TIMES, UM, OVER WHAT TIME PERIOD, 5,000 MORE.
RIGHT? IF, IF YOU'RE LOOKING AT SYSTEM COSTS IN THIS PERSPECTIVE, YOU HAVE TO ALSO CONSIDER THE LOSS OF LOAD PROBABILITY.
NOW, THIS IS, THIS IS IF YOU HAVE AN EVENT.
AND SO IF YOU HAVE AN EVENT THAT RESULTS IN 5,000 MEGAWATT LOAD LOSS, FOR EXAMPLE, FOR EIGHT HOURS, THE PROBABILITY IS ONE.
THAT SIMPLE, THAT SIMPLE ARITHMETIC.
WHAT, WHERE YOU'RE DISAGREEING IS THE FACT THAT YOU'RE SAYING IF THE EVENT OCCURS, AND ERIC IS SAYING, WHAT IS THE PROBABILITY OF THAT EVENT OCCURRING? AND, AND I, I MEAN, I, I TRIED TO STAY OUT OF THIS, BUT I MEAN, IT GETS TO THE POINT WHERE I CAN'T, UM, THIS SLIDE IS THE POINT WHERE I CAN'T, UH, YOU, YOU, YOU, YOU'RE THROWING BIG NUMBERS OUT THERE FOR SCARE FACTOR, AND YOU, YOU REALLY GOTTA, THIS, THIS IS NOT HELPFUL.
YOU GOT TO DO SOMETHING WITH A LITTLE BIT MORE ANALYSIS TO IT.
I MEAN, WE'VE HAD N MINUS SEVEN EVENTS.
UM, DO WE, DO WE OPERATE AROUND N MINUS SEVEN EVENTS OR DO WE EVEN PLAN FOR N MINUS SEVEN EVENTS OTHER THAN THE, THE DYNAMICS? I, I THINK THE, THE POINT IS THAT IF WE HAVE AN EVENT, THE COST IS GONNA BE HUGE, RIGHT? THAT WAS, THAT WAS THE WHOLE POINT OF THIS.
AND SO WE NEED TO, UH, PREVENT THOSE EVENTS FROM HAPPENING, EVEN IF, EVEN IF THE CHANCE OF IT HAPPENING IS A REALLY SMALL PERCENTAGE, IT STILL BECOMES SOME VERY BIG NUMBERS IN A HURRY.
AND SO WE NEED TO, WELL, SO DOES AN N MINUS SEVEN EVENT, DAN, UH, YOU KNOW, WHAT, WHAT WAS YOUR NN MINUS 20 G MINUS 30, YOU KNOW, AND IT WAS A BIG EVENT, AND THAT'S WHAT WE'RE, I MEAN, WE'RE TRYING TO THROW THESE NUMBERS OUT HERE, LIKE THAT'S A NORMAL OCCURRENCE.
AND SO THAT, THAT'S, THAT'S MY CONCERN.
I THINK THAT'S ERIC'S CONCERN.
SO I MEAN, JUST, AND, AND I'M NOT TRYING TO TAKE SIDES HERE.
I'M JUST, LET'S, LET'S TRY TO BE REAL WITH, WITH OUR ANALYSIS, BUT, BUT I THINK THAT, I THINK THE, THE POINT IS THAT THAT, UH, IN SOME OF THE EARLIER DISCUSSIONS, THERE'S NOT A LOT OF WEIGHT GIVEN TO THE RELIABILITY IMPLICATIONS OF NOT RIDING THROUGH.
AND SO IF UNITS DON'T RIDE THROUGH, DON'T MEET THE STANDARD, WE HAVE A UNDER FREQUENCY LOAD SHED, UM, THEN THERE'S A LOT OF COST ASSOCIATED WITH THAT.
AND SO IT'S NOT A MATTER OF PROBABILITY, IT'S A MATTER OF IF YOU'RE SPENDING A SMALL AMOUNT OF DOLLARS THROUGH SOFTWARE UPGRADES TO PREVENT SOMETHING THAT CAN HAPPEN FOR UP TO THE EQUIPMENT RATINGS, FOR EXAMPLE, LET'S JUST TALK ABOUT THAT PARTICULAR ONE.
IF YOU CAN SPEND A SMALL AMOUNT OF COST GETTING UP TO THE EQUIPMENT RATINGS IN ADDITION AND CUT OUT SOME PORT, SOME PORTION OF THE RISK FOR THAT, UM, EVENT HAPPENING, THEN YOU COMPARE THAT SMALL COST TO THE COST OF A MAJOR EVENT, IT, IT DWARFS IT.
AND SO WHY WOULD YOU NOT GO AHEAD AND DO THE UPGRADE? AND WE ARE REQUIRING SOFTWARE UPGRADES, RIGHT? YEAH.
I THINK WE WE'RE GETTING INTO A FEW DIFFERENT CONVERSATIONS.
UM, AND I, YOU KNOW, UNDERSTAND THE, THE CONCERNS HERE.
UM, I THINK DAN, I'LL SAY, I THINK YOU'RE, YOU'RE JUST TRYING TO PUT NUMBERS TO THIS, RIGHT? WE'VE HAD A LOT OF DISCUSSION ABOUT THE COMMERCIAL SIDE AND, AND I
[03:20:01]
THINK IT WAS PART OF THE BOARD DIRECTION TO THINK ABOUT THE FINANCIAL IMPACTS OF, OF THE LOSS OF LOAD.UM, SO I THINK WE CAN TAKE THAT AS IT IS, KNOWING THAT THERE'S A, A LOT, UM, BEHIND VALUE OF LOSS LOAD AND, AND PROBABILITY OF LOSS LOAD.
UM, SO, AND HOPEFULLY ERIC, WE WILL GET TO AGREEMENTS ON SOFTWARE, UM, SHORTLY.
I DON'T, I DON'T WANNA BELABOR THIS SLIDE.
I, I, I ACTUALLY DID WANT TO GIVE SOME, JUST SOME BALANCE IN, UH, RECOGNIZING DAN, I THINK IN, IN THIS CASE, THE, THIS, THE SPECTRUM YOU HAVE ON THE VERTICAL AXIS.
AM AM I CORRECT IN READING THE FIRST THREE ROWS IS EFFECTIVELY BEING, LIKE YOU SAID, AN UNDER FREQUENCY LOAD, SHE EVENT THAT'S, YOU KNOW, MORE LIMITED VERSUS THE OTHER ONES WOULD BE MORE THE UNCONTROLLED, UH, OUTAGE SCENARIOS? YES.
AND, YOU KNOW, JUST TO PUT, YOU KNOW, PUT SOME ADDITIONAL COSTS AROUND IT, YOU KNOW, IT'S NOT JUST THE VALUE OF LOSS LOAD IN THOSE SCENARIOS, BUT YOU KNOW, EVERYONE IN THIS ROOM THAT, YOU KNOW, CREATES OR SELLS POWER PROBABLY WOULD ALSO HAVE ADDITIONAL ECONOMIC, UH, IMPACTS FROM THAT.
SO, YOU KNOW, IT UNDERSTAND WE NEED TO THINK ABOUT IT FROM A PROBABILISTIC STANDPOINT.
AND, BUT, YOU KNOW, I THINK IT IS A FAIR POINT THAT THE COST OF AN UNCONTROLLED OUTAGE OR AN INFREQUENCY LOAD SHED WOULD, WOULD BE MEANINGFUL.
AND SO I'LL, I'LL LEAVE IT AT THAT.
I THINK WE CAN GO BACK TO WHEREVER I WAS.
SO THE FIRST ISSUE, UM, BASICALLY THE IDEA, UH, ON THIS IS THAT THE NERC ALERT SAID, AS WE'VE TALKED ABOUT THIS MORNING, YOU SHOULD DO WHATEVER, UH, UH, SETTINGS, CHANGES, FIRMWARE CHANGES, SOFTWARE CHANGES THAT GETS YOU UP TO THE EQUIPMENT, THE CAPABILITY OF THE EQUIPMENT, AND NOT JUST MAKE THE CHANGES UP TO THE POINT THAT THEY'RE, UH, YOU'RE MEETING THE KIND OF THE REQUIREMENT.
AND SO IF THE, IF THE CAPABILITY OF THE EQUIPMENT IS THAT YOU COULD RIDE THROUGH A MORE SEVERE FAULT, UH, FOR EXAMPLE, THEN WHAT IS REQUIRED, IF YOU'RE A 2016 VINTAGE UNIT, WHY WOULDN'T YOU GO AHEAD AND, AND MOVE UP TO THAT LEVEL? UM, SINCE THE SOFTWARE CHANGES ARE, IT'S A MATTER OF CHANGING THE PARAMETERS, CHANGING WHATEVER, WHY WOULD YOU NOT GO AHEAD AND DO THAT THE WAY THE, THE WAY THE T LANGUAGE IS WRITTEN, AND YOU CAN SEE IT THERE, IT BASICALLY ONLY REQUIRES YOU TO GO UP TO THE, UH, TO THE, TO YOUR LEGACY REQUIREMENT, WHATEVER REQUIREMENT THAT YOUR VINTAGE UNIT IS.
BUT WHY WOULDN'T YOU GO AHEAD AND GO FURTHER IF, UM, IF YOU CAN, WHILE MAKING THOSE SOFTWARE UPGRADES? UM, WHAT WE'VE SEEN IS THAT FROM THE, WHAT MARK, MARK HENRY, AND AND JOSEPH PRESENTED THIS MORNING IS THAT, THAT A LOT OF JUST THE, JUST LOOKING AT, AND I KIND OF DON'T LIKE THE, JUST LOOKING AT THE ODESSA EVENT BECAUSE THE FACT THAT AN EVENT'S HAPPENED DOESN'T MEAN THERE'S NOT LOTS OF THINGS OUT THERE THAT COULD GO WRONG THAT HAVEN'T HAPPENED YET.
BUT JUST FOCUSING IN ON, ON SOME OF THE RESULTS OF THE, THE, UM, THEY DID A SURVEY, UM, OF ALL THE UNITS AND FOUND THAT FOR PG PVG AND FOUND THAT A LOT OF THESE UNITS AREN'T, HAVEN'T, DON'T HAVE SETTINGS UP TO THE KIND OF THEIR EQUIPMENT CAPABILITY.
THEY COULD, THEY COULD DO A LOT MORE IN TERMS OF WRITING THROUGH, BUT THEY DON'T HAVE THINGS SET THAT WAY.
IN FACT, A LOT OF THEM INTENTIONALLY SEEM TO HAVE SET IT TO WHERE IT'S JUST MEETING THE REQUIREMENT AS OPPOSED TO MAXIMIZING.
AND, UM, SO WHY WOULDN'T YOU GO FURTHER IF, IF IT'S NOT GONNA COST ANYMORE? UM, AND SO THAT THIS IS ONE OF THE THINGS THAT WE'D LIKE TO PUSH FOR IS, IS GOING AHEAD AND MAXIMIZING THAT CAPABILITY THROUGH THOSE SOFTWARE AND FIRMWARE UPGRADES AND PARAMETER CHANGES, UH, TO THE EXTENT THAT THERE'S NOT, AND I THINK THE LANGUAGE WE USE TO THE EXTENT THERE'S NOT SOME, UH, WHERE YOU, WHEN YOU WORK THROUGH AT THE INTERCONNECTION AGREEMENT WITH YOUR, UH, TSP OR ERCOT, THERE ISN'T SOME OTHER REASON THAT'S DOCUMENTED THAT YOU SHOULD, UH, NOT MOVE TO THAT.
SOME HAVE SOME PARAMETER THAT'S SET TO THAT MAX TO MAXIMIZE THAT RIDE THROUGH.
UM, SOME ESTIMATES THAT WE'VE MADE, UM, IS THAT, UM, IF YOU, IF YOU APPLY THE, THE, THE, TO THE SOLAR, THE, TO THE, WHAT WAS ON THE PREVIOUS SLIDE, THERE'S ONLY ABOUT 20 TO 35 4% OF THE IBR THAT ARE SET RIGHT NOW TO MAXIMIZE UP TO
[03:25:01]
THEIR, THEIR EQUIPMENT CAPABILITY.UM, THE, THE DIFFERENCE BETWEEN MA SETTING IT TO MAXIMIZE TO YOUR EQUIPMENT CAPABILITY AND SETTING IT TO MAXIMIZE TO YOUR, OR TO ONLY MEET THE REQUIREMENTS, THERE WOULD BE AN ADDITIONAL, UM, 50 50.
I PROBABLY, I'LL THINK I'M GONNA SAY IT WRONG.
SO LOOKING AT THE TWO CHARTS DOWN THERE, THE TOP ONE IS THE TAC APPROVED VERSION.
THE BOTTOM ONE IS WHAT OUR ERCOT PROPOSES.
AND BECAUSE WE ARE JUST USING THE SOLAR, THE ONE POINT WE HAVE IS THIS IS THE, UH, SOLAR SURVEY.
SO IF WE ASSUME THAT 25% OF ALL THE 70 GIGAWATTS IS SET UP CORRECTLY, THEN 16 SHOULDN'T HAVE TO TOUCH IT.
BUT BECAUSE THE LANGUAGE, THE WAY IT'S WRITTEN IN THE TAC APPROVED VERSION SAYS JUST TO THE REQUIREMENTS, WELL, WE'RE ASSUMING THAT MEANS ONLY ABOUT 17 AND A HALF, UH, RIGHT THERE WOULD NEED TO MAXIMIZE.
WHEREAS WHAT WE'RE PROPOSING IS TO ALL THE OTHER 54 SHOULD THEN MAXIMIZE TO THE EQUIPMENT CAPABILITY.
SO THERE'S A PRETTY BIG GAP THERE JUST IN THE LANGUAGE.
AND THAT GAP LOOKS TO, TO US TO BE ABOUT 36 GIGAWATTS OR MORE THAT IT LOOKED LIKE WE WERE ON THE SAME PAGE ABOUT SOFTWARE PARAMETERIZATION, BUT THE LANGUAGE DOESN'T SUPPORT.
AND THAT'S THE DISCONNECT WE SEE RIGHT THERE.
CAN WE, IS THE LANGUAGE ON THE PAGE BEFORE THIS? I WOULD, YOU KNOW, I WOULD LIKE TO GET OUT OF TODAY AREAS WHERE WE ARE AGREED, AND I, I THOUGHT THIS IS ONE WHERE WE WERE PRETTY CLOSE TO AGREEMENT.
SO IF WE CAN GET TO, AND IT DOESN'T NEED TO BE FINAL LANGUAGE, BUT IF WE CAN GET TO KIND OF A CONCEPT OF AGREEMENT REGARDING SOFTWARE, I, I WOULD LIKE TO DO SO.
UM, BUT WHY, WHY DON'T I TAKE THE REST OF THE QUEUE WHILE WE THINK ABOUT THAT BOB HILTON? YEAH, JUST REAL QUICKLY ON SLIDE EIGHT, WELL NO SE UH, NINE, I GUESS IT IS YEAH.
THAT, THAT'S COMING OUT OF THE RFIS RIGHT? THAT YOU SENT OUT LAST, LAST NOVEMBER FOR, THIS IS ACTUALLY A, A, UM, A RFI THAT NER DID OR TRE DID.
'CAUSE THE REASON I'M ASKING IS ON THE RFIS, THERE'S A LOT OF TIMES WE HAD TO SAY NO RATHER THAN YES, WHEN WE FIGURED IT WAS ALREADY A YES BECAUSE WE DIDN'T HAVE THE DATA FROM THE OEM IN SOME PLACES ON THE RFIS YOU GUYS SENT OUT.
SO I WAS JUST TRYING TO FIGURE OUT IF THAT'S PART OF THE CASE THERE.
THIS, THIS IS ACTUALLY FROM THE ONE THATT RE SENT OUT.
WHICH COULD HAVE THE SAME ISSUES.
I HAVEN'T REALLY LOOKED AT THAT ONE.
AND AND SECONDLY, OVER ON THE NEXT ONE, JUST A QUICK QUESTION.
UH, YEAH, YEAH, THAT WOULD BE FINE.
UH, UH, I'M TRYING TO FIGURE OUT, AND MAYBE A DUMB QUESTION, BUT YOU'RE SAYING MAXIMIZE TO THE UNIT'S CAPABILITY, WHO DECIDES THAT WHAT IS MAXIMUM CAPABILITY? IS THAT THE OM SAYS THEY'VE DONE AS MUCH AS THEY COULD DO? OR IS THAT ERCOT SAYING, NO, YOU GOTTA GO FURTHER, OR, I'M JUST TRYING TO FIGURE OUT WHAT THAT MEANS.
UH, I THINK MOST OF THE TIME IT'S GONNA BE THE OEMS. OKAY.
BUT ONCE AGAIN, UH, THESE ARE PLANT LEVEL REQUIREMENTS.
SO FOR EXAMPLE, IF YOU LOOK AT YOUR OEM, YOUR INVERTER AND THEY SAY, YEAH, WE CAN WIDEN THIS BAND HERE, WE CAN ALLOW MORE CAPABILITY, YOU MAY NEED TO GO TO THE NEXT LEVEL UP, AND YOU MAY HAVE A PROTECTION MULTIFUNCTION RELAY AT THE PLANT LEVEL, THAT THEN ALSO NEEDS TO BE CONFIGURED TO MAKE SURE THAT IT ALL COORDINATES TOGETHER.
AND SO THE, THE RESOURCE ENTITY, THE PLANT OWNER, UM, THEY'RE THE ONES THAT WOULD BE RESPONSIBLE TO COORDINATE WITH THE OEMS, UNDERSTAND THAT PIECE, LOOK AT THE BALANCE OF THE PLANT, MAKE SURE IT ALL WORKS TOGETHER, CONTROLS EVERYTHING, AND THEN YOU'VE MAXIMIZED IT, UH, TO YOUR EQUIPMENT CAPABIL.
I WAS JUST TRYING TO FIGURE OUT WHAT THAT ACTUALLY MEANT.
'CAUSE IT WAS KIND OF EGGED TO ME.
SO WAS THE INTENT OF THE TAC VERSION THAT YOU WOULD MAXIMIZE ALL THE WAY TO THE CAPABILITY? I MEAN, IS THAT, ARE WE ARGUING ABOUT THE SAME THING THAT YOUR INTENT WAS TO TAKE EVERYTHING? YEAH, BECAUSE IF THAT'S THE INTENT, THEN WE'VE GOT THIS ONE SOLVED.
I'M GLAD YOU ASKED 'CAUSE I JUMPED IN THE QUEUE
[03:30:01]
TO TALK ABOUT THIS.UM, SO THE, THE, WHAT WE MODIFIED ON WHAT SOFTWARE WAS REQUIRED FOR LEGACY WAS THE PRIOR JANUARY ERCOT COMMENTS THAT SAID LEGACY.
UM, SO THAT'S WHY IT'S REFERRING TO THAT.
UM, BUT WE'RE DEFINITELY OPEN TO A REQUIREMENT TO, UH, HAVE SOFTWARE REQUIREMENTS BE ABOVE LEGACY.
WE'D WANNA TALK ABOUT THE DETAILS.
SO FOR EXAMPLE, DOES MAXIMIZING MEAN POTENTIALLY REDUCING THE REAL POWER OUTPUT? PROBABLY NOT, RIGHT? SO WE HAVE TO FIGURE OUT WHAT DOES MAXIMIZE MEAN.
BUT, UM, WE'RE HAPPY TO TALK THROUGH THE, YOU KNOW, HOW TO WRITE SOMETHING THAT WOULD TALK ABOUT HOW TO MAXIMIZE SOFTWARE REQUIREMENTS.
JUST TO GIVE YOU THE SHORT ANSWER.
YEAH, MARK WENT DOWN FOR AGREEMENT, THEN WE JUST GOT THAT ONE SOLVED.
ANN IS GONNA TELL ME WE CAN'T AGREE 'CAUSE IT'S A WORKSHOP.
UM, BUT CORY HASN'T GOTTEN MAD YET, SO I THINK WE'RE STILL IN THE CLEAR.
UM, AND I, I THINK THIS
SO IT'S THE CONCEPT WE'RE GREEN ON IS THAT THE INTENT IS ON THAT WE WOULD REQUIRE SOFTWARE UPGRADES.
AND THE WORD IS THAT MAXIMIZE CAPABILITY AS LONG AS THAT'S DEFINED, RIGHT? BUT NOT NECESSARILY ONLY TO LEGACY REQUIREMENTS.
I THINK THAT THE DETAILS MATTER.
SO I DON'T THINK WE WANT AN EVER EVOLVING STANDARD OF, YOU KNOW, BUT YES, UM, IN GENERAL WE'RE OPEN TO THIS REQUIREMENT.
BILL, ARE YOU GOING TOAG AGREE OUR AGREEMENT, THIS SEEMS, UH, SUPER REASONABLE TO ME AND I WAS GONNA ASK JOINT COMMENTERS IF THEY ARE IN AGREEMENT, WHICH ERIC ALREADY ANSWERED THAT, SO I THINK WE CAN MOVE ON.
ALRIGHT, LET'S KEEP GOING THEN, DAN.
ONE DOWN, SEVERAL MORE TO GO, UM, WITH THAT.
WELL, YEAH, I THINK WE CAN PROBABLY SKIP THAT ONE.
I, I GUESS THE, ONE OF THE REASONS THAT THIS IS IMPORTANT IS IF YOU LOOK AT THIS, THIS BLUE AREA HERE, THAT'S KIND OF THE CURRENT RIGHT VOLTAGE RIDE THROUGH REQUIREMENTS.
THE IEE REQUIREMENTS KIND OF COME OUT INTO THIS AREA A LITTLE MORE.
AND SO IF YOU'VE GOT UNITS THAT COULD, AND THERE'S A LOT OF THEM THAT CAN ACTUALLY ALMOST DO THE IEE 2,800 REQUIREMENTS, IF THEIR, THEIR EQUIPMENT CAN DO IT, IF THE SOFTWARE AND THE SETTINGS AND SO FORTH WERE SET, RIGHT? AND SO THAT'S REALLY WHY THIS IS IMPORTANT IS THAT WE CAN ACTUALLY GET EVEN CLOSER TO IEEE 2,800 JUST BY, BY DOING THIS.
SO, LOOKS LIKE STEVEN'S GONNA, YEAH, I I THINK AN IMPORTANT POINT HERE, I JUST WANT TO PAUSE AND MAKE, BECAUSE OF THE MODEL ISSUE THAT WE TALKED ABOUT IS WITH PIGGER 1 0 9, WHEN YOU MAKE THESE EQUIPMENT SETTING CHANGES, YOU'RE GOING TO LOOK AT YOUR PARAMETERS, YOU'RE GONNA UPDATE YOUR MODELS.
AND BY JUST CHANGING THIS LANGUAGE, WE KIND OF KNOCK OUT TWO BIRDS WITH ONE STONE.
WE GET THE BETTER CAPABILITY AND WE'RE GONNA GET A MODEL REVIEW AT THE SAME TIME.
SO THIS, THIS ACTIVITY RIGHT HERE DOES PROVIDE A LOT OF VALUE THAT THAT'S GREAT.
AND I THINK ANOTHER THING FOR US IS CONSIDERING THE DETAILS, BUT JUST POINTING IT OUT SINCE WE'RE MAYBE DOING A LITTLE BIT OF, AT LEAST A LITTLE BIT OF KUMBAYA RIGHT NOW, UH, IS LIKE THE TIMING OF THE MODEL UPDATE VERSUS THE SOFTWARE CHANGE HAS, SOMETIMES IT'S BEEN LIKE A, WHAT'S EXACTLY THE PRIORITY, AND I THINK IT VARIED FROM PROJECT TO PROJECT.
AND SO THAT'S SOMETHING TO FIGURE OUT.
WELL, P 1 0 9 IDENTIFIES THAT TIMING AND PROCESS.
I, OKAY, WE, I MAYBE WE'RE TALKING PAST EACH OTHER SO WE CAN TALK LATER.
SO AT SOME LEVEL WE ARE IN AGREEMENT TO THIS BLUE BOX ON THIS SLIDE.
LANGUAGE SHOULD REQUIRE THAT SOFTWARE PARAMETERS PROTECTION AND CONTROL SETTINGS MAXIMIZE TO EQUIPMENT CAPABILITY, NOT JUST TO REQUIREMENTS.
JUST I WANT TO CAVEAT AGAIN, SINCE THAT WE NEED TO FIGURE OUT WHAT MAXIMIZE MEANS, BUT IN GENERAL, YES.
SO WE DON'T WANT IT TO HAMPER THE ABILITY OF THE UNIT TO MAKE MEGAWATT HOURS TO A LARGE EXTENT.
[03:35:01]
OKAY.NOW THERE'S SEVERAL, UM, TYING BACK TO SOME OF THE, UM, I GUESS ERIC AND, AND HIS PRESENTATION OF THE BOARD HAD THIS, UH, THIS DIAGRAM, THERE'S SEVERAL ISSUES THAT WE WANNA TALK TO.
THEY'RE BASICALLY ALL IN THIS KIND OF NUMBER TWO CATEGORY.
UM, WE'LL SEE IF WE CAN RESOLVE THOSE.
CAN WE TAKE BOB HILTON'S QUESTION REALLY QUICK? YEAH.
AND IT MIGHT COME UP IN HERE TOO.
'CAUSE, AND, AND STEVEN MENTIONED IT, YOU KNOW, ALL THIS IS GONNA FOLLOW UNDER 1 0 9 AND THAT I DON'T EVEN KNOW HOW LONG THAT PROCESS IS GONNA TAKE FOR EACH GENERATOR, MUCH LESS HOW MANY YOU'RE GONNA BE HAVING.
AND I WOULD HATE TO SEE PLANTS TAKEN OFFLINE OR FULLY LIMITED DURING THE EARLY PART OF, OF THE EXEMPTION REVIEW.
BECAUSE ANYTHING THAT'S GONNA HAVE TO HAPPEN, IT'S GONNA HAVE TO GO THROUGH 1 0 9, WHICH IS GONNA EXTEND THAT OUT EVEN FURTHER.
SO, UH, JUST SOMETHING I'M WANTED TO KEEP IN MIND ABOUT.
YEAH, I THINK JUST A GENERAL COMMENT FOR EVERYBODY'S AWARENESS IS THAT, UM, MOST IBR SHOULD BE COMPLIANT TODAY.
THE, THE LION'S SHARE, RIGHT? IT'S JUST THE OLDER ONES THAT HAVE SOME LEVEL OF EXEMPTIONS THAT ARE GONNA HAVE TO, UH, COME UP TO SPEC.
SO THE MAXIMIZING PROCESS FOR THOSE THAT ARE CURRENTLY ALREADY COMPLIANT, AND WE HAVEN'T CHANGED THE CURVES FOR THEM, IT'S REALLY JUST GOING FROM WHERE THEY'RE COMPLIANT TO THE BEST THEY CAN DO.
SO THERE SHOULDN'T REALLY BE AN IMPACT AS FAR AS EXEMPTIONS FOR THEM, RIGHT? IT WOULD JUST BE FOR THE OLDER ONES THAT THROUGH THIS PROCESS IDENTIFY, HEY, I'VE TRIED TO DO THE BEST I CAN AND I CAN'T QUITE GET THERE.
AND RIGHT NOW, TO THE BEST OF OUR KNOWLEDGE, THAT'S TWO TO FOUR GIGAWATTS.
JUST TO, JUST TO FOLLOW UP, UH, MORE WHAT I'M TALKING ABOUT, NOT JUST THE EXEMPTION.
WELL, IT COULD LEAD TO THAT IS IF YOU'VE GOT SOMEBODY OUT THERE THAT HAS THE NEWER GENERATION THAT THAT CAN, IS FULLY CAPABLE OF, OF COMPLYING, BUT THEY'RE TUNED WRONG
THEY'RE GONNA HAVE TO GO BACK IN TUNE, YOU KNOW, TO SET, GET THEIR SETTINGS RIGHT TO TO, TO GET TO WHERE THEY NEED TO BE AND TO COME IN COMPLIANCE THAT MAY REQUIRE AN EXEMPTION WHILE THEY DO THAT, WHICH IS GONNA HAVE TO GO THROUGH THE 1 0 9 PROCESS.
THE WAY I UNDERSTAND IT, THAT'S KIND OF THE OTHER SIDE OF WHAT I WAS TALKING ABOUT.
I THINK WE'LL GET INTO ONE OF THOSE ITEMS HERE.
SO I DON'T WANT TO GET TOO FAR AHEAD, BUT WE DO NEED TO TALK ABOUT, BECAUSE, UH, THAT'S ONE OF THE, THE DIFFERENCES I THINK IS HOW DO YOU HANDLE THIS TIME PERIOD WHILE YOU'RE SEEKING AN EXEMPTION? YEAH.
THAT'S WHY I WAS BRINGING IT UP FOR 'CAUSE THERE WE OKAY.
CAN'T SEE THE QUEUE UP HERE, SO NOPE, WE'RE GOOD.
THE, UM, SO, SO THE NEXT THING HAS TO DO WITH, UM, UM, ERCOT AUTHORITY IN REVIEWING, UH, THE EXEMPTIONS.
AND, UM, I KNOW THE, UH, THIS MAY BE ONE THAT WE CAN GET TO AN AGREEMENT ON, I DON'T KNOW.
UM, BUT THE JOINT COMMENTERS SAID SEVERAL TIMES THAT WE BELIEVE ERCOT HAS, UM, KIND OF THE ULTIMATE AUTHORITY OVER THIS.
UM, BUT WHEN YOU READ THE, THE TAC LANGUAGE THERE, THE TAC APPROVED ENDORSED LANGUAGE, UM, IT SAYS ERCOT, UH, MAY DENY AN EXEMPTION, BUT THEN IT CAVEATS THAT DOWN TO SOME VERY LIMITED CIRCUMSTANCES UNDER WHICH WE WOULD BE ABLE TO GIVE THAT EXEMPT, GIVE A, UH, DENY AN EXEMPTION.
ONE IS THAT THE RESOURCE HAS DECIDED THAT IT'S, UM, THAT IT'S NOT COMMERCIALLY REASONABLE.
UM, AND THE OTHER ONE IS THAT THEY HAVE GIVEN US THE RIGHT MODEL THAT THEY'VE APPROPRIATELY REPRESENTED THE, THE, THE, THE LIMITATIONS OF THE UNIT.
AND SO IT'S, IT'S REALLY ONLY ALLOWING US TO DO IT IF, IF WE BELIEVE THAT THERE'S COMMERCIALLY REASONABLE MODIFICATIONS THAT EXIST.
AND IF THE, THE, THE MODEL DOESN'T REFLECT THOSE LIMITATIONS TO THE BEST OF THE RE'S UNDERSTANDING.
SO IF THEY TELL US THE MODEL'S WRONG, THEN, THEN WE COULD DENY IT.
BUT THERE'S, IT'S, IT'S REALLY THE, THE LANGUAGE IS, IS A LITTLE ODD.
I'M NOT EVEN SURE IT MAKES SENSE THE WAY IT'S WRITTEN RIGHT NOW.
UM, BUT IT CERTAINLY RESTRICTS WHEN WE COULD, UH, UM, UH, DENY, UH, A REQUEST REQUEST FOR AN I ON A REQUE REQUEST FOR AN EXEMPTION.
AND I, I DON'T THINK THAT'S WHAT, I DON'T THINK TAC IS GOING TO AGREES THAT ONCE YOU READ THE LANGUAGE, THAT THAT'S WHAT WAS INTENDED NOW,
[03:40:01]
UM, AN AN EXEMPTION PROCESS THAT WE CAN SUPPORT, WE'VE TRIED TO GO THROUGH AND SAY, OKAY, UNDER WHAT CIRCUMSTANCES WOULD WE BE WILLING TO, IF WE, IF WE, IF IT REALLY IS IN OUR AUTHORITY TO DEFINE OR DENY OR ACCEPT AN EXEMPTION, HOW WOULD WE DO THAT? AND SO WE'VE PUT TOGETHER SEVERAL SCENARIOS HERE.UM, THE FIRST ONE IS THAT THE, THE GETTING TO THAT WHERE YOU DON'T NEED THE, THE STAND, THE EXEMPTION IS EITHER IT'S NOT THE EXEMPT, IT'S NOT TECHNICALLY FEASIBLE TO DO IT, OR IT IS TECHNICALLY FEASIBLE IS A REALLY HIGH COST, AND THEN THERE'S NOT, THERE'S AN ACCEPTABLE RELIABILITY RISK.
AND WE TALK ABOUT ON THE NEXT SLIDE, AND I'LL COME BACK TO THAT, WHAT THE ASSUMPTION IS.
SO IT'S EITHER A REALLY HIGH COST OR IT JUST CAN'T BE DONE AND IT DOESN'T CAUSE ANY MAJOR RELIABILITY PROBLEMS. IF THEY DON'T MEET THAT STANDARD, THEN IN THAT CASE, WE GRANT THE EXEMPTION THAT I THINK EVERYBODY WOULD AGREE THAT'S THE, THAT'S THE RIGHT ANSWER.
UH, AND THEN, SO THERE, THERE IS, WHILE THERE MAY NOT BE A BIG RELIABILITY RISK, THERE'S STILL, YOU KNOW, THE CHANCE THAT UNITS IN THE AREA WOULD TRIP, SMALL NUMBER OF UNITS WOULD TRIP OR SOMETHING LIKE THAT.
AND SO WE WOULD PUT IN PLACE A GTC OR SOME OTHER RESTRICTION THAT SAYS WE'RE NOT GONNA LET IT GET ABOVE THAT LEVEL.
THAT WOULD CAUSE IT TO BE A BIG PROBLEM.
SCENARIO TWO IS THAT THERE IS A TECHNICALLY FEASIBLE SOLUTION THAT'S FAIRLY LOW COST CHANGING OUT CARDS ON AN OR SOMETHING LIKE THAT ON THE CONTROL SYSTEM.
UM, AND THERE'S A, IF, IF THEY DIDN'T DO THAT, IT WOULD STILL BE AN ACCESS ACCEPTABLE RELIABILITY RISK.
WELL, IN THAT CASE, THERE'S STILL A CHANCE THAT THEY'D TRIP OFF, BUT THERE'S A LOW COST SOLUTION, WHY WOULDN'T YOU GO AHEAD AND DO IT? UM, AND SO IN THAT CASE WE WOULDN'T, BECAUSE THE COST IS LOW, WE WOULDN'T, UH, GRANT AN EXEMPTION.
UM, IF THEY, IT'S 'CAUSE THEY'RE NOT MEETING AND THEN BECAUSE THEY'RE NOT MEETING THE STANDARD, WE WOULD REPORT THEM TO ERM.
UM, IN SCENARIO THREE, THERE IS A TECHNICALLY FE THERE'S NO TECHNICALLY FEASIBLE SOLUTION AND NOT, UH, FIXING THE PROBLEM CAUSES A BIG RELIABILITY RISK.
UM, IN THAT CASE WE D WOULDN'T GRANT AN EXEMPTION.
WE WOULD REPORT 'EM TO TERM AND WE'D CREATE A GTC.
UM, I THINK YOU, I THINK YOU GET THE IDEA.
I I GUESS I'LL GO AHEAD AND GO THROUGH THOUGH.
THERE'S, UH, IF THERE'S A TECHNICALLY FEASIBLE SOLUTION AND THERE'S AN UNACCEPTABLE RELIABILITY RISK, EVEN IF IT'S HIGH COST, WE STILL WOULDN'T GRANT THE EXEMPTION.
IN THAT CASE, YOU'D HAVE TO MITIGATE THE PROBLEM OR WE PUT THE GTC AROUND YOU AND THEN THERE'D BE SOME FINANCIAL INCENTIVE TO, UH, TO MITIGATE IT.
UM, THAT MIGHT CHANGE THE COST.
AND I THINK THAT'S ONE OF THE KEY THINGS IS IF WE CAN IDENTIFY THAT THERE'S NO WAY TO PUT A GTC AROUND IT, THEN THAT CHANGES THE COST EQUATION TO SOME EXTENT.
UM, AND THEN FINALLY, FOR UNKNOWN CAPABILITY OR KIND OF, THIS IS THE GENERIC, WE, WE HAVEN'T DONE OUR WORK TO FIGURE OUT IF WE'VE GOT A PROBLEM OR NOT.
UM, THEN IN THOSE CASES WE'RE NOT GONNA GRANT AN EXEMPTION BECAUSE IT'S JUST NOT, UM, UH, DOESN'T MAKE SENSE, UM, TO DO SO.
SO ANYWAY, LEMME LET ME GO THROUGH SOME OF THE, UM, LET ARE THE ASSUMPTIONS AROUND THIS.
AND SO ONE OF THE KEY ONES, BACK TO THE POINT THAT WE SPENT A LOT OF TIME DISCUSSING THIS MORNING, KNOWING WHETHER SOMETHING IS AN ACCEPTABLE RELIABILITY RISK OR NOT IS GONNA REQUIRE US DOING SIMULATIONS TO SHOW HOW MUCH UNIT, HOW MUCH IS GONNA TRIP.
AND BEING ABLE TO DO THAT MEANS WE'VE GOTTA HAVE GOOD MODELS THAT ACCURATELY REFLECT THE CAPABILITIES OF THE UNITS, THE PROTECTION SYSTEMS, THE TUNING THAT'S BEEN DONE.
SO WHAT PARAMETERS ACTUALLY EXIST IN THE FIELD.
ALL THAT'S GONNA HAVE TO BE THERE, THAT'S GONNA BE PARAMOUNT AND, AND HAVE TO HAPPEN EARLY FOR US TO BE ABLE TO DO THIS WHOLE EXEMPTION PROCESS AND GRANT THEM OR NOT BECAUSE WE'VE GOT OTHERWISE WE'RE NOT GONNA BE ABLE TO, UH, TO EVALUATE HOW MUCH RELIABILITY RISK WE REALLY HAVE.
UM, THE NEXT THING TO UNDERSTAND IN THE ASSUMPTION ON THE, THAT, THAT THE PREVIOUS, THE, HOW WE WOULD DO THIS ON THE PREVIOUS PAGE IS THAT THE EXEMPTIONS ARE GONNA BE BASED NOT ONLY ON THE INDIVIDUAL IMPACTS ON THE PLANT, WHETHER THAT PLANT TRIPS OR NOT, BUT ALSO THE AGGREGATE IMPACT ACROSS THE, THE REGION.
SO IF THAT PLANT AND ALL THESE OTHER PLANTS AROUND IT TRIP
[03:45:01]
AS A RESULT OF THEM NOT HAVING THE, THE MEETING, THE STANDARD, THEN THAT WOULD BE, UH, GROUNDS FOR NOT, UH, APPROVING IT.UM, THE, UH, OTHER PIECE OF THIS IS BECAUSE OF THAT, THEN WE WOULDN'T BE ABLE TO GRANT THESE EXEMPTIONS OR NOT UNTIL WE'VE GOT MODELS AND WE'VE GOT ALL THE EXEMPTION REQUESTS IN THAT MIGHT BE RELEVANT TO THE ASSESSMENT OF EACH INDIVIDUAL, UH, RESOURCES, UM, REQUEST FOR AN EXEMPTION AND WHETHER THEY CAUSE A, A WIDESPREAD RELIABILITY PROBLEM OR NOT.
UM, IF YOU GIVE US A MODEL AND THEN WE GRANT AN EXEMPTION, BUT THEN YOU DON'T ACT, WE FIND OUT LATER THAT BECAUSE OF AN EVENT OR SOMETHING THAT THAT MODEL WASN'T ACCURATE, THEN YOUR EXEMPTION MIGHT BE, UH, TAKEN AWAY, IF YOU WILL.
IT WOULD, UM, BECAUSE, BECAUSE IT WAS BASED ON INACCURATE INFORMATION, IT WOULD'VE TO BE REVISITED, UM, OPERATIONAL RESTRICTIONS, WHETHER HOPEFULLY THROUGH A GTC OR SOMETHING LIKE THAT WOULD BE DONE WHERE THERE'S AN UNACCEPTABLE RELIABILITY RISK THAT'S NOT MITIGATED.
AND THEN OBVIOUSLY I THINK THAT'S A REPETITIVE A LITTLE BIT, WE, WE, WE HAVE TO HAVE THE NECESSARILY INFORMATION TO BE ABLE TO DO THIS ASSESSMENT.
AND SO THAT'S KIND OF HOW WE WOULD DO IT.
WHAT ARE THE ASSUMPTION, WHAT I KEEP SAYING UNACCEPTABLE RELIABILITY RISK.
WHAT DOES THAT MEAN? DOESN'T NECESSARILY MEAN ONE PLANT TRIPPING OFFLINE.
UM, AND SO WE'VE TRIED TO DEFINE IT HERE THAT, UH, IT'S, IT'S UNCON, IT'S THE WHAT NERC CALLS YOU'VE MISSED.
THE EVIL THREE, THE UNCONTROLLED SEPARATION INSTABILITY OR CASCADING OUTAGES.
SO IF ANY OF THOSE OCCUR AS A RESULT OF THE, UH, UNIT NOT GRANTING OR NOT BEING ABLE TO MEET THEIR, THE STANDARD, THEN THAT THAT WOULD BE AN UNACCEPTABLE RELIABILITY RISK.
UH, IF IT CAUSES A LOSS OF GENERATION CAPACITY OVER 500 MEGAWATTS, UH, WE WOULD DEEM THAT TO BE A, A UNACCEPTABLE RELIABILITY RISK LOSS OF LOAD OVER 75 MEGAWATTS.
AND WE'VE SEEN THIS HAPPEN WHERE WHEN THERE'S A, A UNIT, UH, TRIP SOMETIME WE HAVE KIND OF A SYMPATHETIC TRIP OF, OF NEARBY LARGE LOADS, AND SO WE'D HAVE TO PROTECT AGAINST THAT AS WELL.
UH, AND THEN OF COURSE SAFETY AND, AND EQUIPMENT DAMAGE WOULD BE INCLUDED IN THAT AS WELL.
SO THAT'S KIND OF THE CRITERIA THAT WE WOULD, WE'RE PROPOSING TO USE FOR WHAT IS AN UNACCEPTABLE RELIABILITY RISK.
IF IT'S BETTER THAN THOSE THINGS, THEN WE WOULD, UH, BE OKAY.
AND THEN FINALLY, FROM A COST PERSPECTIVE, THE ASSUMPTION IS THAT THAT, UH, AS WE'VE BEEN TALKING ABOUT SOFTWARE FIRMWARE PARAMETER CHANGES, ALL THOSE WOULD BE DEEMED TO BE LOW COST.
UM, THEN WE'D LET BACK TO THE, THE GOAL THAT THE BOARD AND THE COMMISSIONERS MENTIONED THAT WE NEED A OBJECTIVE CRITERIA FOR ASSESSING THE COSTS.
WE'VE PUT SOMETHING HERE, UH, THIS IS SOMETHING WHERE TECH REALLY NEEDS TO WEIGH IN ON WHAT'S THE RIGHT NUMBER, WHAT'S THE RIGHT CRITERIA THAT WE, WE SHOULD USE FOR CONSIDERING HOW MUCH COST IS, IS TOO MUCH.
UM, AND SO WE'VE PROPOSED SOMETHING HERE, BUT, BUT YOU KNOW, IT'S OPEN TO DISCUSSION AND SO I THINK I'VE ACCUMULATED A FEW CARDS.
OKAY, ERIC, UH, SO A FEW THINGS ON HERE, UM, BUT I'LL START WITH THE LAST ONE.
WHY DID YOU PROPOSE RAISING THIS TO 50% FROM YOUR 20% THAT YOU HAD PREVIOUSLY? 50% OF THE COST VERSUS 20% OF THE COST? SO WHEN WE WERE PREPARING THE PRESENTATION, WE WERE TRYING TO SIMPLIFY SO THAT IT COULD BE A VERY EASY, UH, CHART INSTEAD OF HAVING MULTIPLE LAYERS OF COST, LIKE A LOW, MEDIUM HIGH.
SO WE JUST SIMPLIFIED IT SO THAT WE KNEW THAT TAC REALLY NEEDS TO TALK THROUGH WHAT THAT THRESHOLD NEEDS TO BE.
'CAUSE IT'S REALLY A SINGULAR THRESHOLD WE THINK WE NEED TO COME UP WITH.
THAT WILL MAKE IT EASY FOR THE COMMISSION TO WEIGH IN ON.
SO, UM, WE, WE CONTINUED TO OPPOSE ARBITRARY THRESHOLDS, UM, FOR I THINK GOOD REASON AND APPRECIATE THAT TAC AGREED WITH US ON THIS LAST POINT.
THE, THE REASONING AS I SAID PREVIOUSLY
[03:50:01]
WAS THAT IT IS A PROJECT BY PROJECT EVALUATION ON, ON WHAT MAKES SENSE TO DO.UM, AND IT CAN VARY BY LOCAL L AND P OR THE AGE OF THE EQUIPMENT OR THE PRODUCTIVITY AT THE SITE IN TERMS OF WIND, THE SOLAR ASSETS, UM, THE TIMING OF WHEN A CONTRACT IS IS AVAILABLE VERSUS NOT AVAILABLE, UH, AND, AND MANY OTHER FACTORS.
UM, AND ANYTHING THAT IS AN ARBITRARY CUTOFF, UH, HAS THE RISK OF POTENTIALLY VIOLATING STATE LAW, UM, AROUND WHETHER OR NOT SOMETHING IS A TAKING.
SO WE, WE THINK IT'S IMPORTANT TO HAVE A COMMERCIAL REASONABILITY APPROACH THAT, UM, CAN BE CONTEXT SENSITIVE.
AND IF ERCOT WANTS, YOU KNOW, INFORMATION ABOUT HOW THAT DECISION WAS MADE, WE'RE HAPPY TO HAVE A STEP IN THE PROCESS TO SAY, EXPLAIN YOURSELF.
UH, AND, AND WE THINK THAT WOULD BE REQUIRED BECAUSE IT'S, AS YOU SAW ON THE, ON THE EARLIEST SLIDE, IT'S TO ERCOT, UH, REASONABLE SATISFACTION SO YOU CAN ASK FOLLOW UP QUESTIONS, UM, AND YOU HAVE ALL THE DATA FROM EVERYBODY ELSE.
SO I, I THINK THIS IS A KEY POINT.
UM, AND AN AN ARBITRARY CUTOFF.
UM, I CAN UNDERSTAND WHY THAT WOULD BE SIMPLER, BUT THE, THE WORLD IS IN A SIMPLE PLACE, UNFORTUNATELY.
UM, IN REGARDS TO THE UNACCEPTABLE LIABILITY RISK, UM, LANGUAGE, UM, WE THINK THAT THIS IS, UM, PROBABLY SOMETHING THAT WOULD NEED A LOT MORE DISCUSSION.
AT THE VERY MINIMUM, UM, WE, WE HEARD EARLIER, WE SPENT MOST OF THE MORNING TALKING ABOUT HOW WE CAN'T MODEL THINGS.
AND SO I DON'T HAVE A CLEAR UNDERSTANDING OF HOW ERCOT COULD DRAW A CONCLUSION AROUND, UM, AROUND SOME OF THESE NUMBERS AND, AND OUTCOMES.
UM, WHEN DOING AN EVALUATION OF A, UH, EXEMPTION REQUEST, IF, IF YOU'RE UNSURE, ARE YOU GONNA MAKE THE WORST CASE ASSUMPTION BECAUSE I DON'T THINK THAT'S APPROPRIATE.
UM, AND UM, SO, SO THERE'S, THOSE ARE TWO POINTS.
I THINK A FEW OTHER POINTS, UM, ON THE TIMING OF, UH, AND THE PROCESS FOR THE EXEMPTION.
I THINK WE'RE DEFINITELY OPEN TO YOU HAVING MORE TIME TO REVIEW THOSE.
UM, AND KATHY WEB KING, IF YOU CAN COME UP SPECIFICALLY ON THAT PROCESS.
AND IF YOU COULD GO BACK TO THE PRIOR SLIDE.
I THINK I, I'VE FORGOTTEN ONE OF MY OTHER POINTS.
UM, I I THINK THERE'S ONE MORE SLIDE.
UM, SO HERE, UM, ERCOT CAN DENY, UM, IF IT'S NOT TO, TO ERCOT REASONABLE SATISFACTION, WHICH IS THE POINT THAT, THAT WE WERE MAKING EARLIER.
AND SO ON THE POINT OF THE, THE RESEARCH ENTITY'S UNDERSTANDING, WE CAN'T PROVIDE YOU A MODEL THAT TELLS YOU SOME ABOUT SOMETHING WE DON'T KNOW ABOUT.
AND SO I DON'T KNOW WHAT THE DISPUTE IS, AND SO WE GET SOME CLARIFICATION ON THAT.
UM, WE, THE, THE REASON WE PUT THAT IN THERE IS BECAUSE THERE MAY BE THINGS THAT WE'RE UNAWARE OF, UM, AND UM, I DON'T KNOW HOW WE CAN MODEL SOMETHING WE DON'T KNOW ABOUT.
AND KATHY, I'D APPRECIATE IF YOU HAD ANY FOLLOW UP ON, ON THAT.
UM, I'M HAPPY TO FOLLOW UP AND I'M ALSO MINDFUL TO THE CHAIR OF THE, OF THE AGENDA, BUT I'M HAPPY TO DO A BRIEF FOLLOW UP THAT WE CAN GO INTO, WE HAVE IT FURTHER.
Q DO YOU WANT TO, OKAY, I'M GETTING THE IT'S OKAY.
ON THE, UH, EXEMPTION PROCESS AND THE REVIEW OF COMMERCIALLY REASONABLE ERCOT DOES HAVE THE SAY AND THERE'S A LIST OF FACTORS IN THE, IN THE TAC REPORT THAT Y'ALL ADOPTED THAT, THAT ARE THE FACTORS GENERALLY THAT WOULD BE CONSIDERED IN WHAT WOULD BE COMMERCIALLY REASONABLE, INCLUDING THE RELIABILITY IMPACTS OF THE POTENTIAL CHANGE OR NOT.
UM, SO, AND, BUT YOU KNOW, ALL OF US ARE ALL OPEN TO LANGUAGE.
IF THERE'S SOME NEEDS TO TIGHTEN THAT OR ADD MORE FACTORS OR TAKE AWAY MORE FACTORS, UM, THAT KIND OF THING, I THINK THAT COULD ALL BE REVIEWED.
BUT THE, THE CURRENT DRAFT THAT Y'ALL HAVE APPROVED, UM, LEAVES THE FINAL SAY IN ERCOT HANDS AS TO WHETHER OR NOT THERE IS A COMMERCIALLY REASONABLE FIX THAT, THAT, UM, THE RESOURCE ENTITY DID NOT PROPOSE TO MAKE.
I THINK WHERE THE, THE REAL DIFFERENCE RUNS INTO THIS UN THIS SUBSET OF AND CREATES AN UNACCEPTABLE
[03:55:01]
RELIABILITY RISK.SO I THINK WHAT WE HEARD FROM DAN IS THAT REGARDLESS OF WHETHER OR NOT THERE'S A FIX THAT'S EVEN TECHNICALLY FEASIBLE OR NOT A FIX, LET ME, LET ME START THAT BACK A MINUTE.
WE'RE TO SET THE STAGE, WE'RE ONLY TALKING ABOUT CURRENT FACILITIES THAT ARE ON THE GROUND TODAY, SOME OF WHICH ARE WIND FACILITIES THAT ARE OLDER THAN 2008 THAT HAVE THEIR OWN, YOU KNOW, SET OF CURRENT REQUIREMENTS IN THESE AGE FACILITIES.
SO WE'RE ONLY TALKING ABOUT THE APPLICATION OF THESE POTENTIAL NEW STANDARDS THAT WOULD REQUIRE PHYSICAL CHANGES TO THESE OLDER FACILITIES.
AND SO THE EVALUATION IS WHETHER OR NOT THOSE PHYSICAL CHANGES CAN BE ORDERED OR SHOULD BE ORDERED OR NOT.
AND THAT'S THE CONTEXT OF ALL OF THIS.
SO AT, AS WE UNDERSTAND THIS LANGUAGE ABOUT UNACCEPTABLE RELIABILITY RISK, THAT WOULD BE ERCOT DETERMINING THAT THOSE EXISTING FACILITIES THAT HAVE BEEN ON THE GRID FOR, FOR LONG PERIODS OF TIME NOW CREATE AN UNACCEPTABLE RELIABILITY RISK AND WOULD NOT, WOULD BE REQUIRED TO MAKE PHYSICAL CHANGES TO TAKE THEM TO SOME DIFFERENT STANDARD.
UM, REGARDLESS OF, OR IF THERE'S NOT.
AND I THINK UNDER DAN'S SLIDE, IF THEY'RE NOT, IF THERE'S NOT EVEN A TECHNICALLY FEASIBLE CHANGE TO MAKE, THEY WOULD NOT BE GRANTED AN EXEMPTION.
I THINK WE'LL PROBABLY HAVE MORE FOLLOW UP ON THAT, BUT WE'LL GO BACK TO THE QUEUE FOR NOW.
UM, I THINK MY FIRST QUESTION'S ALREADY BEEN, UH, ADDRESSED THAT WAS WHAT'S THE, THE ACCEPTABLE RELIABILITY RISK THAT YOU'RE TALKING ABOUT.
SO, UM, THANKS FOR COVERING THAT ON THE SLIDES.
UM, THE SECOND QUESTION I HAD WAS ON THIS ONE, AND I THINK WE'VE PROBABLY SCRATCHED THE SURFACE OF, OF THIS AND THAT'S THE, THE BEST OF THE REQUESTING ENTITIES UNDERSTANDING.
IT SEEMS LIKE THAT WAS, THAT'S THE KEY TERM IN HERE THAT IS, UH, OF THE MOST CONCERN TO ERCOT.
AND IT SEEMS LIKE MAYBE THERE WERE DIFFERENT, UH, INTENTIONS WITH THAT LANGUAGE THEN, THEN THE WAY KO'S READING IT.
SO I'M WONDERING IF, IF THERE'S A WAY TO REPHRASE THAT OR, OR JUST CHANGE THE WORDS, ELIMINATE THE WORDS AND, YOU KNOW, PUT A NOTE IN THE, IN THE, IN THE MARGIN.
BUT IT SEEMS LIKE THERE'S, THERE MIGHT BE MORE COMMON AGREEMENT THAN JUST WHAT THE TEXT ON THE PAGE SAYS.
UM, AND THAT WAS MEANT TO BE, YOU KNOW, THESE, AS WE'VE HAD A LONG DISCUSSION THIS MORNING,
AND IF IT'S, IF THERE'S A, YOU KNOW, WE CAN ONLY PROVIDE WHAT WE CAN PROVIDE.
RESOURCE ENTITIES CAN ONLY PROVIDE WHAT THEY HAVE SO, AND WORKING WITH THEIR MANUFACTURERS, ET CETERA.
SO I'M SURE WE COULD WORK ON THE, THOSE WORDS.
SO, BUT TO BE CLEAR, THAT'S NOT INTENDED TO BE A AN OUT FOR THE UNKNOWN UNKNOWNS.
'CAUSE THAT'S, I THINK THAT'S THE CONCERN THAT I'VE HEARD FROM ERCOT AND WHAT I'M HEARING IS THAT'S NOT THE INTENTION OF THAT, THAT PHRASE.
AND, AND THE INTENTION IS THIS WHOLE THING IS DRAFTED, IS THAT IF YOU'RE SEEKING AN EXEMPTION, YOU HAVE TO SPECIFY THE EXEMPTION.
IT'S NOT JUST A A COVERALL SAFETY NET, IT'S FOR A KNOWN ISSUE.
DID YOU HAVE A RESPONSE, STEVEN? YEAH, I THINK FROM ERCOT PERSPECTIVE, IF Y'ALL ARE CONCEPTUALLY ON THE SAME PAGE THAT UNKNOWN RISKS SHOULD NOT BE ALLOWED TO HAVE EXEMPTIONS.
IF CONCEPTUALLY YOU ARE ON THE SAME PAGE THAT ERCOT SHOULD BE ABLE TO ASSESS RELIABILITY IN THE PROCESS OF ALLOWING OR DENYING AN EXEMPTION.
WE JUST NEED THE LANGUAGE TO CLEARLY AND UNAMBIGUOUSLY STATE THAT VERY SIMILAR TO THE LANGUAGE THAT WE PROPOSED WHERE WE EXPLICITLY SAY WE WOULD NOT ALLOW IT FOR UN, YOU KNOW, FOR UNRELIABLE CONDITIONS.
WE WOULD NOT ALLOW IT FOR UNKNOWN.
THE, SO THE REASON THAT WE OPPOSED THE LANGUAGE YOU HAD PREVIOUSLY WAS 'CAUSE IT WAS NOT A CLEAR STANDARD.
WE'RE HAPPY TO TALK IF, IF, IF YOU CAN IDENTIFY A, A CLEAR STANDARD THAT TAC THINKS IS POSSIBLE TO DO, WE'RE HAPPY TO TALK ABOUT IT.
WELL, I THINK CAN I, I I JUST WANNA MENTION, I, I THINK OUR DISCUSSION IS ONCE AGAIN, UH, I APPRECIATE Y'ALL'S POSITION.
BUT WE WANNA MAKE SURE WE UNDERSTAND THE TAC MEMBERS FEELING AND SENTIMENT ON THAT.
DAN, YOU WANTED TO EVEN SAID, WHAT I WAS GONNA SAY IS THAT I DON'T THINK THIS IS A NEGOTIATION BETWEEN ERCOT AND THE JOINT COMMENTERS.
I THINK IT'S A ERCOT AND THE JOINT COMMENTERS INFORMING TAC SO THAT TAC CAN DECIDE WHAT IT WANTS TO PUT INTO THE LANGUAGE AND REPRESENT TO THE BOARD.
I JUST WANTED TO KIND OF REFRAME THAT BECAUSE THAT'S THE,
[04:00:01]
WHETHER ERIC AGREES WITH THE LANGUAGE OR NOT, IT'S WHETHER TAC AGREES WITH THE LANGUAGE IS THAT'S IMPORTANT BECAUSE THAT'S WHAT'S GONNA NEED TO GO TO THE, UM, TO THE BOARD.I WOULD AGREE WITH THAT, BUT, BUT I THINK, YEAH, I THINK FOR TODAY THE INFORMATION IS MOST IMPORTANT.
SO IF WE CAN GET TO CONSENSUS, THAT'S GREAT.
THE, ALL THESE THINGS THAT WE'RE GETTING AN AGREEMENT TO, THAT'S, THAT'S AWESOME.
BUT ULTIMATELY THE OTHER IS THE TRUTH.
FIRST YOU GO ON TO, WAS IT 16? YOUR EXAMPLES? SLIDE 16.
UH, I, I WANNA UNDERSTAND THIS 'CAUSE IT, IN SOME CASES I'M GOING, WHAT DOES THIS ACTUALLY MEAN IN EACH YEAR SCENARIOS? SO ON, LET'S TAKE SCENARIO TWO.
YOU'RE SAYING NO EXEMPTION REPORT TO THE ERM.
WELL LET'S GO ON TO THREE, LET'S GO THREE.
THAT ONE, THAT ONE I IS NOT A PROBLEM.
NO TECHNICAL FEASIBLE SOLUTION, UNACCEPTABLE RELIABILITY RISK.
GET THAT YOU SAID NO EXEMPTION REPORT TO ERM AND THEN YOU SAY YOU'RE GOING TO CREATE A GTC OR IMPLEMENT RESTRICTIONS.
RIGHT? SO, UH, TO ME THAT DOESN'T MAKE A WHOLE LOT OF SENSE.
SO IT'S, SO YOU'RE TELLING ME IF YOU'RE NOT, IF YOU'RE NOT MEETING THE CURRENT REQUIREMENTS, UHHUH FOR EXAMPLE, YOU'RE NOT MEETING THE CURRENT REQUIREMENTS, YOU ASK FOR AN EXEMPTION TO THE CURRENT REQUIREMENTS.
'CAUSE YOU'VE RECOGNIZED YOU CAN'T DO THE BY WHATEVER, LET'S SAY WE HAVE A OPEN SEASON ON EXEMPTIONS, RIGHT? YOU ASK FOR AN EXEMPTION, YOU'RE NOT ABLE TO MEET THE CURRENT LEGACY REQUIREMENTS.
UM, AND WE RECOGNIZE WE, YOU GIVE US AN UPDATED MODEL AND THE MODEL STARTS SHOWING THAT, GOSH, ALL THE UNITS IN THIS AREA ARE GONNA TRIP AND IT'S 5,000 MEGAWATTS OR SOMETHING.
I'M JUST SAYING IT'S UNACCEPTABLE TO RELIABILITY RISK, WHATEVER THAT CRITERIA IS.
THEN IN THAT CASE, WE DON'T GIVE YOU AN EXEMPTION TO THAT TO, TO THE LEGACY STANDARD.
WE DON'T, UH, WE, YOU'RE NOT MEETING THE EXISTING STANDARD.
SO WE REPORT THAT TO THE ERM AND THEN WE HAVE TO, BECAUSE THERE'S THIS UNACCEPTABLE RELIABILITY RISK WE HAVE TO PUT A GTC OR SOME KIND OF RESTRICTION IN PLACE TO MAKE SURE WE DON'T MANIFEST THAT UNACCEPTABLE RELIABILITY EVENT.
NOW LET ME GO BACK TO THE QUESTION.
AND, AND SO YOU'RE GONNA REPORT TO THE ERM.
WHAT ARE YOU EXPECTING THE ERM TO DO? THE ERM WILL EITHER, UM, COME UP WITH A, WELL, I DON'T WANNA SPEAK.
I THINK WE CAN PROBABLY LET SOMEBODY, WELL, I MEAN ARE YOU LOOKING FOR THEM TO GO THROUGH A, A COMPLIANCE PROCESS AND POTENTIALLY BE FINED? WELL THEN YOU SHUT THE PLANT DOWN.
THAT'S WHAT I DON'T GET IS WHAT WOULD HAPPEN.
UNACCEPTABLE RELIABILITY RING.
I'M NOT ARGUING WITH YOU, DAN, UH, BUT YOU'RE, YOU'RE SAYING THAT YOU'RE GOING TO CREATE A GTC OR IMPLEMENT RESTRICTIONS TO ALLOW THEM TO RUN, BUT YOU'RE GOING TO GO HIT 'EM WITH A COMPLIANCE HIT FOR SOMETHING THEY HAVE NO CONTROL OVER.
TO ME, THAT'S WHAT'S CONFUSING IS IF, IF YOU THINK THAT'S THAT BIG OF A PROBLEM, THEN YOU DO WHAT YOU COULD DO TODAY AND TAKE 'EM OFFLINE.
BUT TO SAY I'M GONNA FINE YOU AND LET YOU RUN, THAT AIN'T GONNA HAPPEN.
THAT'S WHY I'M, I'M KIND OF CONFUSED ON, ON SOME OF THE, THE, THE, THE SCENARIOS.
SO IT IS JUST, I THINK SEMANTICS IN SOME CASES WE PROBABLY CASES COULD HAVE LEFT OUT.
WE ALSO HAD SOMETHING IN HERE ON THIS SLIDE ABOUT TRANSMISSION PLANNING WHERE WE PUT A GTC IN PLACE.
THERE'S THE POTENTIAL FOR A FUTURE TRANSMISSION UPGRADE.
WE HAD A PHRASE ON THERE THAT SAID THAT, AND WELL, THAT'S TRUE OF ANY GTC.
IT HAS TO GO THROUGH THE ECONOMIC PLANNING CRITERIA AND IF IT THERE'S SOME TRANSMISSION IMPROVEMENT THAT SOLVES THE GTC PROBLEM, THEN, THEN IT CAN BE SOLVED.
UM, AND SO, BUT WE TOOK THAT OUT AND SO THERE'S PROBABLY SOME OF THIS ABOUT REPORTING TO ERM THAT COULD HAVE BEEN TAKEN OUT.
'CAUSE IT'S KIND OF OBVIOUS ANYWAY.
SO THAT'S THE, THE PART THAT REALLY CONFUSED ME ON THIS.
YOU'RE GONNA LET 'EM RUN, BUT YOU'RE GONNA FIND THEM.
SO THAT DIDN'T MAKE A LOT OF SENSE TO ME 'CAUSE I WOULDN'T DO THAT
'CAUSE IF YOU CONTINUE TO RUN, UH, THE WAY THAT COULD GO IS YOU'RE FINE.
SO MUCH PER DAY PER EVENT, PER EVERYTHING ELSE.
SO THAT DOESN'T MAKE A LOT OF SENSE TO ME.
BUT MAYBE YOU JUST TRYING TO FIGURE THAT OUT.
MAYBE YOU'RE ALLOWED TO WANTED A, A LOWER OUTPUT LEVEL.
AND NOW, UH, ON THE NEXT SLIDE, AND THIS IS A LITTLE BIT OF WHAT WAS TALKED ABOUT A LITTLE EARLIER ON THE, UH, THE COST PIECE.
UH, YEAH, JUST A STANDARD CAP NUMBER BOT DOES BOTHER ME.
UH, I WOULD EXPECT, AND I'LL TAKE A LITTLE DIFFERENT TACT ON WHAT, WHAT I WAS THINKING IS
[04:05:01]
THAT I'LL GO BACK TO PAST EXPERIENCE.WHEN I, WHENEVER WE WENT AND WE, UH, MOTHBALLED THE HAYES COMBINED CYCLE PLANTS, DAN JONES CALLED ME IN AND SAID, SHOW ME ALL YOUR NUMBERS TO THAT.
SAY YOU'RE, YOU'RE, YOU'RE MOTHBALLING THIS THING AND NOT WITHHOLDING.
I WOULD EXPECT SOMETHING ALONG THE SAME LINES IN THAT CASE TO WHERE YOU'RE GONNA COME IN AND SAY, HERE IS WHY WE DON'T BELIEVE THIS IS COMMERCIALLY VIABLE TO DO.
RATHER THAN, AND I DON'T THINK THAT CHANGES A WHOLE LOT.
AT LEAST IT GIVES, UH, THE NUMBERS OUT THERE ON WHY.
'CAUSE I BELIEVE, I AGREE WITH THE OTHER COMMENTS.
IF I'VE GOT A, A 2008 PLANT THAT I KNOW ONLY HAS A FEW YEARS LEFT, UH, I'M NOT GONNA INVEST A BUNCH OF MONEY INTO IT.
AND SO I THINK THAT WOULD BE DIFFERENT THAN, THAN WHAT YOU CALL A LOW COST AND A HIGH COST, BUT JUST A, JUST A CAP.
SO I WANNA THROW THAT PIECE OUT THERE.
I THINK WHAT WE'RE TRYING TO, UH, UH, RESPOND TO THERE IS THIS IDEA THAT WE HEARD AT THE BOARD MEETING THAT WHATEVER CRITERIA OF COMMERCIAL REASONABILITY WE COME UP WITH, UH, HAS TO BE, UM, UM, WHERE IT MINIMIZES THE DISPUTES TO THE COMMISSION.
IT'S BASED ON OBJECTIVE INFORMATION.
IF WE CAN COME UP WITH A PROFORMA THAT SAYS, HERE'S THE PROFORMA THAT WE USE.
IN THE CASE OF EVERY UNIT THAT COMES IN AND SAYS SOMETHING'S NOT COMMERCIALLY REASONABLE, THEN MAYBE THAT'S ACCEPTABLE.
UM, BUT UM, IT JUST NEEDS TO BE AN OBJECTIVE CRITERIA.
AND SO MAYBE SOMETHING LIKE THAT'S DOABLE AS OPPOSED TO A STRICT PERCENTAGE.
WE JUST NEED A, A, THE CRITERIA WE NEED IS AN OBJECTIVE CRITERIA OR THE OKAY.
BILL BURNS, I APPRECIATE THE DIALOGUE THERE WITH MR. HELTON.
I THINK THAT HELPS A NEUTRAL TAC MEMBER.
TRYING TO FIGURE OUT WHERE THE STICKING POINTS ARE ON THIS.
CAN YOU REMIND ME WHAT TECHNICAL FEASIBILITY MEANS IF IT'S NOT TECHNICALLY FEASIBLE? THAT MEANS THERE IS REALLY, IS NO LIKE, RETROFIT OR UPGRADE THE FACILITY OWNER COULD DO.
IS THAT WHAT THAT MEANS? YEAH, UH, I MEAN WE, WE HAD SOME DEBATE ABOUT THIS TECHNICALLY FEASIBLE MEANS WITHIN THEIR PLANT WHAT THEY CAN DO.
I MEAN, THERE COULD BE A POSSIBILITY OF ADDING A STAT COM OR SOMETHING LIKE THAT.
IS THAT TECHNICALLY FEASIBLE IF IT SOLVES THE PROBLEM? I, I DON'T KNOW THAT, I DON'T THINK THAT'S WHAT'S IN THE CURRENT DEFINITION.
I THINK IT CURRENTLY, THE DISCUSSION THAT'S BEEN HAD IS ALL ABOUT WHAT CAN YOU DO TO THE PLANT.
I MEAN, I GET THE, THE CONCERN THAT BOB'S RAISING, IF YOU FALL INTO SCENARIO THREE, I MEAN, YOU
AND IT, YOU MAY HAVE BUILT THIS THING FIVE YEARS AGO OR WHATEVER.
AND I, I UNDERSTAND AS A RESOURCE OWNER WHY THAT IS CONCERNING.
AND I WONDER IF THAT CAN BE MANAGED THROUGH.
SO IF YOU GO TO 17, I ACTUALLY REALLY LIKE AN OBJECTIVE LIST OF CRITERIA TO HOW THESE THINGS ARE EVALUATED.
I THINK THAT MAKES IT NOT ARBITRARY.
I KNOW, ERIC, YOU SAID ARBITRARY A FEW TIMES THAT LIKE A CLEAR LIST OF HERE'S WHAT THIS MEANS, SEEMS TO MAKE A LOT OF SENSE.
AND I, I YOU GUYS SAYING THAT THE BAR IS TOO LOW ON WHAT AN UNACCEPTABLE RELIABILITY RISK IS, MEANING THAT THOSE THRESHOLDS NEED TO BE HIGHER? NO, OR I WAS SAYING THE ARBITRARINESS OF THE 20% VERSUS 50%.
ONE IS, DID JOINT COMMUTERS AGREE THAT THAT LIST OF WHAT'S AN ACCEPTABLE OR UNACCEPTABLE RELIABILITY RISK MAKES SENSE? OR IS THERE THINGS THERE THAT YOU DISAGREE WITH? I'M NOT GONNA SPEAK TO A FINAL CONCLUSION ON THAT, BUT THIS IS THE FIRST TIME WE'VE SEEN THOSE NUMBERS.
LET'S, OR ANY, OR ANY SPECIFICATION AROUND MAYBE NOT TRY TO NEGOTIATE.
I DON'T AGREEMENT ON CONCEPTS, BUT, BUT THIS IS THE FIRST TIME THAT CONCEPTS COME OUT.
SO THERE'S SOME ROOM FOR MOVEMENT ON THAT ONE.
I, AND SO AN APPROACH MIGHT BE TO HAVE A LIST OF THINGS THAT SOLVE IT.
ANOTHER APPROACH MIGHT BE THIS PERCENTAGE.
ANOTHER APPROACH MIGHT BE, LIKE I SAID, A PROFORMA THAT SAYS, HERE'S HERE'S THE NUMBERS WE'RE USING.
I MEAN, I JUST, I PERSONALLY, THIS IS HELPFUL FOR ME 'CAUSE I'VE KIND OF ALWAYS WONDERED WHAT, WHAT ERCOT THOUGHT THAT MEANT.
SO ON THE COST, THIS IS WHERE, UH, YOU CAN STAY ON 17, DAN? YEAH.
I WANTED TO GO BACK SOMETHING.
SO THE, IT SOUNDS LIKE THE STICKING POINT
[04:10:01]
ON THE COST THRESHOLD, WHICH IS REALLY THE, THE BAR FOR HOW YOU'RE MEASURING LOW VERSUS HIGH COST IMPACTS, IS THE ERCOT PROPOSED 50%, WHICH THEY HAVE A LITTLE ASTERISK THERE THAT SAID, TA CONSIDER ALTERNATIVE REASONABLE THRESHOLDS, JOINT COMMENTERS WENT 20%.UM, ERCOT PREVIOUSLY PROPOSED 20% AND NOW IT SEEMS THEY'VE RAISED IT TO 50%.
AND WE SAY ANY SORT OF COST THRESHOLD IS ARBITRARY BECAUSE IT DEPENDS ON PROJECT SPECIFICATIONS.
SO IN BOB'S EARLIER EXAMPLE, IT DOESN'T, IT MIGHT NOT MAKE SENSE TO SPEND SIGNIFICANTLY ON A 2008 VINTAGE SITE IF YOU'RE, YOU'RE PLANNING TO REPLACE IT IN THREE YEARS IN ANYWAY WITH MODERN EQUIPMENT.
WHAT ABOUT THE LIST OF TYPES OF EQUIPMENT THAT NEED TO BE REPLACED AS EITHER LOWER KIND COST? UH, ALL OF THAT GOES INTO A COST EVALUATION.
SO DEPENDING ON WHAT THE REQUIREMENTS ARE TO UPGRADE IT, THAT CAN INCREASE THE COSTS.
SO THINGS LIKE THE CARD CHANGE OUTS, YOU KNOW, IT'S CHEAPER THAN REPLACING THE CONVERTER.
AND, AND ALL THAT GO GOES INTO THE ASSESSMENT.
SO THERE'S NO VERSION OF THE, OF THIS COST MEASUREMENT THAT JOINT COMMONERS WOULD ACCEPT, LIKE CHANGING THE NUMBER OR SOMETHING? BILL? I DON'T, I DON'T THINK WE'RE, THIS IS THE FIRST TIME WE'VE SEEN THAT LIST TOO.
SO I DON'T THINK WE'RE AT A PLACE TO TRY TO DRAW THOSE KINDS OF CONCLUSIONS.
WELL I, I APPRECIATE ERCOT PRESENTING THIS.
'CAUSE I, I, AGAIN, I THINK IT'S HELPFUL TO KNOW WHAT, WHAT ERCOT BELIEVES IS LOW VERSUS HIGH COST AND HOPEFULLY THERE'S AN OPPORTUNITY HERE TO FIND SOME AGREEMENT.
OKAY, WOODY? YEAH, JUST REAL QUICK, GO BACK TO THAT LANGUAGE ONE MORE TIME.
SO KATHY AND I SPENT THREE DAYS TALKING ABOUT THIS AND COULDN'T AGREE, BUT WHEN WE READ THIS, IT SOUNDS LIKE ERCOT ONLY HAS, ACTS CAN ONLY DENY A SUBSET OF EXEMPTIONS.
SO AS TAC MEMBERS LOOK AT THAT AND READ THAT LANGUAGE AND WHAT IT REALLY NEEDS, AND MAYBE THE INTENT IS THE SAME ON BOTH SIDES, BUT WHEN WE READ THAT, IT SOUNDS LIKE WE CAN ONLY DENY AN EXEMPTION FOR A SUBSET.
AND, AND JUST ON THAT POINT, UM, I DON'T KNOW IF WE WANNA FINE TOOTH COMB EVERYTHING, BUT WHEN WE SAY THAT WE'RE RELYING ON DEMONSTRATING TO YOUR SATISFACTION THAT THAT'S THE PHRASE WE'RE RELYING ON.
SO IF YOU'RE NOT REASONABLY SATISFIED, THEN THAT'S A PROBLEM.
WELL, IT SOUNDS LIKE IF, IF, IF YOU'VE DONE EVERYTHING THAT YOU HAVE DETERMINED IS REASONABLY COMMERCIALLY REASONABLE, AND IF YOU'VE GIVEN SOME MODEL, THEN ERCOT CAN'T SAY NO TO IT NO MATTER WHAT THE IMPACT IS TO THE OVERALL RELIABILITY.
THAT'S THE STICKING POINT THAT TAC SHOULD THINK ABOUT WHEN THEY READ THAT LANGUAGE, THAT'S WHEN WE READ IT.
THAT'S WHAT STICKS WITH US, IS THAT WE DON'T HAVE ACCESS TO SAY NO FOR THINGS THAT THE OPERATOR HAS TOLD US IS COMMERCIALLY REASONABLE AND THEY'VE GIVEN US A MODEL THAT'S PARAGRAPH ONE AND TWO.
THAT'S, THAT'S THE POINT FOR US CHAIR.
CAN CLARIFY THAT REALLY QUICKLY.
THAT THAT IS NOT THE INTENT FOR ERCOT TO ONLY HAVE THE ABILITY TO ACCEPT OR DENY THE COMMERCIALLY REASONABLE ASSESSMENT OF THE, OF THE RESOURCE.
IT'S ERCOT REASONABLE JUDGMENT AGAINST THE WHAT'S PRESENTED TO THEM BY THE RESOURCES TO WHAT'S COMMERCIALLY REASONABLE.
UM, AND SO ERCOT CAN SAY, NO, THERE IS SOMETHING ELSE, OR WE DON'T THINK YOU'VE GIVEN US ENOUGH DATA TO SHOW THAT YOU'VE REALLY SERIOUSLY LOOKED FOR SOMETHING COMMERCIALLY REASONABLE.
YOU KNOW, WHATEVER THOSE STANDARDS ARE.
AND THERE'S A LIST OF THOSE THINGS THAT WOULD APPLY INCLUDING RELIABILITY.
WELL MAYBE JUST THE ADDITION OF ONE MORE SENTENCE THERE TO HELP OUR CUT THROUGH THAT WOULD BE ENOUGH TO SOLVE THIS ONE.
I KNOW I SAID WE WEREN'T DOING LANGUAGE, BUT WHAT, JUST SO I'M FOLLOWING WHAT, WHAT WOULD THE ADDITIONAL SENTENCE BE LIKE, OH, MY GUYS ARE GONNA KILL ME.
BUT I WOULD SAY SOMETHING LIKE, IF KOS CHAD CAN DENY AN EXEMPTION FOR, FOR RELIABILITY REASONS, IF THAT WAS IN THERE, I, I THINK WE GOT ENOUGH TODAY TO UNDERSTAND WHAT JOINT COMMENTERS ARE SAYING.
THAT ERCOT HAS THE FINAL SAY LOOKING AT HOLISTICALLY EVERYTHING.
SO IT WILL HAVE TO BE RESTRUCTURED TO MAKE IT MORE OBJECTIVE AND CLEAR.
SO AS LONG AS WE'RE AGREEING TO THE PRINCIPAL, THE JOINT COMMENTERS OR WHOEVER THE RESOURCE OWNER IS, IS PRESENTING WHAT THEY BELIEVE IS COMMERCIALLY REASONABLE AND WE STILL NEED TO TALK THROUGH THAT, I THINK.
BUT THE ERCOT WILL CONSIDER OTHER THINGS INCLUDING A RELIABILITY ASSESSMENT AS IT MAKES ITS OVERALL DECISION, THEN
[04:15:01]
WE CAN PROBABLY GET TO LANGUAGE THAT WILL LEAD THAT AS A STANDARD THAT CAN BE APPLIED UNIFORMLY.SO, 'CAUSE WHAT WE HEARD AT R AND M WAS THAT THE JOINT COMMANDERS WANTED A STANDARD OF EVIDENCE, AND I THINK THAT'S A TERM OF ART THAT IS BEING USED FOR A WAY IN WHICH IF THERE ARE DISPUTES, IT CAN BE APPLIED CONSISTENTLY IN FRONT OF THE COMMISSION.
SO AS LONG AS WE'RE WORKING ON THE LANGUAGE, IT ULTIMATELY GIVES ERCOT THAT DISCRETION AND EVALUATING ALL THE PIECES THAT DAN HAS BEEN TALKING THROUGH, THEN I THINK WE CAN GET TO BETTER LANGUAGE THAT CLEARLY DENOTES THAT.
SO WE DON'T WANT TO CATEGORICALLY LIMIT ERCOT ABILITY TO DENY, DENY EXEMPTIONS, BUT WE DO WANT SOME ELABORATION ON HOW THAT IS DONE, IS KIND OF WHAT WE'RE AGREED TO.
SO IT'S NOT THAT THEY CAN ONLY DENY EXEMPTIONS IN CERTAIN CIRCUMSTANCES, BUT WE DO WANT MORE WORDS AROUND HOW THOSE THAT EXEMPTION PROCESS IS EVALUATED.
IT IT SOUNDS LIKE THERE'S CONVERSATIONS TO BE HAD.
YEAH, I'M STILL NOT SURE THERE'S A COMPLETE MEANING IN THE MINDS, BUT WE CAN OKAY.
CERTAINLY HAVE CONVERSATIONS ABOUT IT.
SO, BUT I, I THINK CAITLIN, WHAT YOU JUST RAISE, THIS IS AN IMPORTANT POINT.
WAS IT ONLY MEANT TO LIMIT US TO GRANT CERTAIN EXEMPTIONS AND NOT OTHERS? MM-HMM.
BUT IF TAC IS INTENDING TO RESTRICT WHAT ERCOT CAN DO AS FAR AS EXEMPTIONS AND NO EXEMPTIONS, THEN I THINK WE NEED TO UNDERSTAND THAT TODAY.
SO IT SOUNDS LIKE WE PROBABLY ARE NOT IN A PLACE TO AGREE ON THAT, BUT WE ARE NOT FOR SURE DISAGREED AS OF RIGHT NOW.
SO WE ARE TO CHRIS HENDRICKS, I BELIEVE.
SO A COUPLE OF QUESTIONS AND THEN A COUPLE OF COMMENTS.
SO FIRST QUESTION IS, I STILL HAVE A FUNDAMENTAL ISSUE WITH THE RETROACTIVITY.
SO WOULD ERCOT CONSIDER BIFURCATING IT AND HAVING ONE, ONE FOR THE EXISTING RESOURCES AND ONE FOR FUTURE RESOURCES? I MEAN, FIRST ON THE RETROACTIVITY THING, APPLYING THIS TO UNITS THAT HAVE A SIGNED IA BUT AREN'T ACTUALLY IN CONSTRUCTION YET.
HAVEN'T THAT, THAT'S NOT RETROACTIVE.
I THINK, I THINK THERE'S BEEN A, CHAD MAY HAVE TO HELP ME WITH THIS, BUT, UH, I THINK THERE'S BEEN A MISUNDERSTANDING, A MISREPRESENTATION OF WHAT RETROACTIVITY MEANS.
RETROACTIVITY MEANS YOU'RE GOING 65 MILES AN HOUR DOWN THE HIGHWAY AND AFTER YOU'VE GONE BY THE SP STOP SIGN OR BY THE, THE SPEED LIMIT SIGN, SOMEBODY CHANGES THE SPEED LIMIT TO 55 AND, AND THEY GA AND THEN THEY GIVE YOU A TICKET BASED ON IT.
THAT'S NOT REALLY WHAT WE'RE TALKING ABOUT DOING HERE.
AND SO THAT'S, UH, THE FACT THAT YOU PUT THE FACT THAT WE PUT WEATHERIZATION REQUIREMENTS ON ALL THE GENERATORS AND ALL THE TRANSMISSION OWNERS AFTER IT WAS ALREADY CONSTRUCTED BECAUSE OF THE HIGH RISK ASSOCIATED WITH THAT, THAT'S NOT REALLY RETROACTIVE IN, IN THE KINDA LEGAL SENSE FROM MY UNDERSTANDING AS AN ENGINEER.
UM, SO THAT'S THE FIRST THING.
THE, THE SECOND THING IS THAT, UH, WE'RE, WE ARE OKAY AND WITH, UH, TWO DIFFERENT SETS OF STANDARDS, THERE'S A QUESTION ON WHAT THE DIVIDING LINE IS BETWEEN WHICH ONES WOULD BE SUBJECT TO THE, WHAT WE CALL THE PREFERRED SET OF, UH, STANDARDS, THE IEE 2,800 FOR, UH, MEETING THAT STANDARD FOR NEW UNITS WHENEVER THAT IS, UH, DEFINED TO START AND THE LEGACY REQUIREMENTS FOR EXISTING PLANTS, WE'RE OKAY WITH THAT.
NOW, FOR THOSE THAT ARE IN THAT LEGACY BUCKET, IF YOU'RE MAKING SOFTWARE CHANGES, LIKE WE TALKED ABOUT EARLIER, THIS IS THE, THE ISSUE ONE, YOU SHOULD NOT JUST GET UP TO THAT LEGACY STANDARD, BUT IF YOU'RE MAKING SOFTWARE CHANGES TO RIDE THROUGH MORE THAN THAT, UM, IF YOU CAN UP TO YOUR EQUIPMENT CAPABILITIES, YOU OUGHT TO DO THAT, BUT YOUR STANDARD WOULD STILL BE TO THE THE, THE LEGACY REQUIREMENTS.
SO WE'RE OKAY WITH HAVING TWO BUCKETS, I GUESS IS THE ANSWER.
YOUR MUCH SHORTER ANSWER TO YOUR QUESTION.
AND I THINK YOU HIT IT, IS I'M NOT REALLY CONCERNED ABOUT THE UNITS THAT, YOU KNOW, HAVEN'T COMPLETED
[04:20:01]
THEIR, YOU KNOW, BUILD YET.OR EVEN THE ONES THAT ARE WERE BUILT A COUPLE YEARS AGO.
I'M MORE CONCERNED ABOUT THE ONES THAT WERE FOUR OR FIVE YEARS AGO, OR THE OLDER WIND GEN GENERATING UNITS THAT SOFTWARE'S NOT GONNA FIX IT FOR 'EM.
IT'S, IT'S GONNA TAKE A LOT MORE STUFF.
AND SO THOSE ARE THE ONES THAT CONCERN ME WHEN WE TALK ABOUT, AND THAT'S WHAT I, WHENEVER I SAY RETROACTIVE NOT PRECISE, BUT THAT'S WHAT I, I MEANT.
YEAH, I MEAN, IF, IF THEY CAN'T MEET THE LEGACY REQUIREMENT THAT THEY'RE SUPPOSED TO BE MEETING, THEN THAT'S WHERE THIS EXEMPTION PROCESS COMES IN AND THAT'S WHERE WE'RE ARGUING ABOUT, YOU KNOW, WHAT, WHEN WE WE GRANT THAT EXEMPTION OR NOT, IF THEY WERE BUILT IN 2016, SAY, AND SO THEY'RE CLEARLY SUBJECT TO THE, THE VOLTAGE RIDE THROUGH STANDARDS THAT ARE IN THE PROTOCOLS TODAY.
UH, IF THEY'RE NOT ABLE TO MEET THAT, THEN, YOU KNOW, THEY WOULD HAVE TO REQUEST AN EXEMPTION.
WELL, THEY'D BE SUBJECT TO COMPLIANCE RIGHT NOW ONCE IT'S DISCOVERED THAT THEY HAVE A PROBLEM AND THEY WOULD, UM, THE EXEMPTION PROCESS WOULD HAVE TO BE WHAT WE WERE JUST GETTING THROUGH TALKING ABOUT.
AND THE, UH, NEXT ONE, ON YOUR NEXT SLIDE ON SLIDE 16, I GUESS I JUST HAVE TO ASK FOR SCENARIO THREE, DO WE HAVE ANY UNITS LIKE THAT CURRENTLY? I, I, I GUESS PART OF THE ANSWER IS WE DON'T KNOW BECAUSE OF THE MODELING ISSUE THAT WE WERE TALKING ABOUT EARLIER, THAT, UH, WE DON'T SEE THAT THERE ARE ANY, UM, KIND OF, I DON'T THINK THAT FALL INTO THIS UNACCEPTABLE RELIABILITY RISK AS DEFINED NOW.
UM, THAT'S ONE OF THE PROBLEMS WITH ALL THIS IS THAT, UM, YOU KNOW, WE, WE CAN'T, UM, COMPLETELY MODEL ALL THE PROTECTION SYSTEMS AND SO FORTH THAT ARE MANIFESTING IN REAL LIFE AND CAUSING THESE UNITS TO TRIP OFFLINE.
THEY'RE NOT IN THE MODELS THAT THE RESOURCE ENTITIES HAVE PROVIDED TO US.
AND THEN KIND OF COMMENT ABOUT THE COST AND, AND I THINK BILL TALKED ABOUT A LITTLE BIT THERE, AND I CAN UNDERSTAND BOTH SIDES.
I CAN UNDERSTAND ERIC, I CAN UNDERSTAND KIND OF THE COMMENTS FROM THE, THE R AND M AND I MEAN, WHENEVER I THINK ABOUT LOW COST, I THINK ABOUT THE 10% RANGE, BUT IT PROBABLY NEEDS TO BE A TWO PART COMPONENT OF 10% OF THE KIND OF REPLACEMENT COSTS ARE OTHER AND HAVE, YOU KNOW, HAVE THE GENERATORS COME TO THEM FOR OTHER, IF THEY'RE, YOU KNOW, IF THEY'RE, YOU KNOW, THE CONTRACT EXPIRES OR, YOU KNOW, THERE'S OTHER STUFF GOING ON THAT ARE, REGARDLESS OF HOW MUCH A REPLACEMENT COSTS ARE, IT STILL DOESN'T MAKE ECONOMIC SENSE TO, TO FIX IT.
AND THEN, UM, THE OTHER COMMENT I HAD WAS THE LANGUAGE THAT WE'RE DISCUSSING THE LANGUAGE THAT IS, YOU KNOW, THE TAC APPROVED VERSION THAT GRANTED AT THE MARCH MEETING, THERE WAS A LOT OF TAC DISCUSSION AT THE TAC MEETING, BUT THAT IS THE ONE THAT ULTIMATELY PASSED AFTER MUCH DISCUSSION.
SO THAT IS THE ONE THAT KIND OF IS THERE.
NOW GRANTED, PART OF THAT IS THROUGH THE STAKEHOLDER PROCESS BECAUSE OF THE REDLINING AND CHANGE IN, THAT'S WHY A LOT OF THE PROTOCOL REVISIONS ARE NEVER RIGHT THE FIRST TIME.
WE ALWAYS HAVE TO GO BACK AND MAKE TWEAKS TO IT BECAUSE THE LANGUAGE, SOMETHING GETS MISSED, BUT FOR THE DETAILS.
BUT THAT IS THE LANGUAGE THAT TACK APPROVED.
IN FACT, THAT'S, THAT'S WHAT ALL THIS IS OUR CONCERN IS WITH THE TAC ENDORSED LANGUAGE, UM, THAT WAS APPROVED AT THE, UH, THE, AND THEN WENT TO THE BOARD.
AND SO WE'VE KIND OF REFERENCED IT BACK TO THAT LANGUAGE AS WE GO THROUGH THIS PRESENTATION.
GRANTED, AND I MEAN, I THINK PART OF THAT GOES BACK TO THE JUST, YOU KNOW, TRYING TO CHANGE IT ON THE FLY YEAH.
IN THE MEETING OR SHORT NOTICE WITH, YOU KNOW, NOT A LOT OF TIME TO THINK ABOUT OR A LOT OF TIME TO GET ALL THE SUBJECT MATTER EXPERTS AT THE DIFFERENT COMPANIES TOGETHER TO, TO RUN IT THROUGH.
SO YOU HAVE DIFFERENT PEOPLE HAVE TAKEN IT DIFFERENT WAYS.
SO SOMETIMES LANGUAGE GETS MISSED.
I, YOU, YOU'VE SPOKEN LIKE SOMEBODY THAT'S BEEN, UH, DOING THIS FOR A LONG TIME, THAT SOMETIMES THE EDITS ON TOP OF EDITS, UH, BECOME HARD TO FOLLOW.
AND I DEFINITELY AGREE WITH WHAT JULIA SAID THIS MORNING IS IT WOULD BE BETTER TO KIND OF CLEAN IT UP.
IN FACT, I DID THIS PERSONALLY, I DID A OKAY ON THESE SEC, I TOOK OUR VERY FIRST, UH, VERSION OF THIS BLACK LINE, TOOK OUT ALL OF OUR INITIAL CHANGES WHEN WE FILED THIS BACK TO BLACK LINE AND COMPARED IT RED LINE CLEAR THROUGH TO THE TAC APPROVED VERSION.
SO IT LOOKS LIKE ONE SET OF CHANGES REGARDLESS OF WHO MADE THEM.
AND I THINK THAT'S PROBABLY WHAT WE NEED TO DO GOING FORWARD.
WE'LL GET BACK TO THE QUEUE, BUT COLIN AND I WERE DISCUSSING OVER HERE IT'S ABOUT TWO 20.
UM, I DON'T THINK PEOPLE ARE GONNA WANT TO BE HERE PAST PROBABLY NOW, BUT, YOU KNOW, BY FOUR 30 OR FIVE ON A FRIDAY.
UM, AND SO, AND I KNOW WE NEED TO GET TO JOINT COMMENTERS, SO I, IT LOOKS LIKE ON TWO ON THE EXEMPTION PROCESS, I, I DON'T
[04:25:01]
THINK WE'RE GONNA GET TO AGREEMENT TODAY.UM, SO MAYBE WE COULD TRY TO GET THROUGH THIS SECTION A LITTLE BIT MORE QUICKLY.
BUT, BUT I WILL TAKE THE, THE COMMENTS IN THE QUEUE ALREADY.
UM, AND THEN, YOU KNOW, AGAIN, JUST REITERATING, APPRECIATING ALL THE WORK PEOPLE HAVE DONE THAT THIS WAS A WORKSHOP, A LITTLE BIT UNUSUAL SENTIMENT.
SO, SO THE PRESENTATIONS CAME IN LATE, BUT THAT'S, THAT'S GOOD BECAUSE THEY WERE SORT OF VOLUNTARY PRESENTATIONS, UM, AND WE WEREN'T EXPECTING TO VOTE OR ANYTHING, BUT I THINK WE WOULD TAKE SOME FEEDBACK AT THE END OF TODAY TO ON, YOU KNOW, WHAT THE, THE PROCESS AT THE SUBSEQUENT TECH MEETINGS WOULD LOOK LIKE IF, IF WE'D BE ABLE TO TAKE STRAW POLLS OR EVEN REAL VOTES ON, ON SOME OF THESE CONCEPTS, UM, AT THE NEXT MEETING AND, AND THINGS LIKE THAT.
SO I'LL, I'LL, WITH THAT, I'LL TAKE US BACK TO THE QUEUE, BUT LET'S KEEP IN MIND KIND OF TIMING AND, AND WHERE WE CAN GET TO AGREEMENT TODAY AND, AND HOW WE WANNA TACKLE THE, THE AREAS OF DISAGREEMENT MOVING FORWARD.
SO STEVEN, I THINK YOU'RE NEXT.
I I JUST WANTED TO POINT OUT A COUPLE QUICK THINGS.
NUMBER ONE, UM, JUST SO EVERYBODY'S CLEAR THAT ERCOT AS THE ERM DOES NOT ASSIGN PENALTIES OR SANCTIONS, UH, WE, WE SIMPLY PASS IT ON TO THE COMMISSION WHEN IT'S FOUND TO BE A, A VERIFIED VIOLATION.
SO THAT'S REALLY THE ROLE THERE.
UH, IF YOU GO TO THE NEXT SLIDE, DAN, I JUST WANTED TO MENTION THE LOW COST PHYSICAL CHANGES LESS THAN WHATEVER COST THRESHOLD IS THERE.
THAT LIST IS REALLY, UH, AN AGGREGATED EXPERIENCE THAT WE'VE GOTTEN FROM WHAT OEMS HAVE TOLD US ARE AVAILABLE, UH, WHAT WE'VE HEARD OTHER ENTITIES HAVE DONE TO MITIGATE PERFORMANCE FAILURES THUS FAR WITH, UH, SOME OF THE EVENTS OR IN ANTICIPATION OF HIGHER REQUIREMENTS, THEY HAVE, UM, STARTED UPGRADING SOME OF THESE THINGS.
SO THAT'S WHERE THAT LIST CAME FROM.
AND I DON'T THINK YOU GOT A CHANCE TO GO TO THE NEXT SLIDE, DAN, BUT THAT NEXT SLIDE IS ALSO IMPORTANT IN THAT, UH, OUR CONCERN IS BEING ABLE TO, UM, ASSESS THE RELIABILITY RISK ASSOCIATED WITH, UH, BOTH AT AN INDIVIDUAL PLANT LEVEL AND AN AGGREGATE LEVEL.
AND THEN WE HAVE CONTINUED TO, UH, STATE THAT WE NEED GUARDRAILS TO ENSURE THAT WE DON'T HAVE UNKNOWN OR UNVERIFIED CAPABILITIES PHASING WITH JUMP ROLL OFF.
THESE GUARDRAILS KEEP US FROM ESSENTIALLY A POTENTIAL FLOOD OF EXEMPTION REQUESTS, UM, WHERE WE'RE NOT EVEN ABLE TO PROPERLY EVALUATE IT.
AND WE HAVE A COUPLE OF QUESTIONS THERE.
UH, IF TAC MEMBERS GET AN OPPORTUNITY ON THE NEXT SLIDE TO BE SURE THAT THEY, UH, CONSIDER, UH, IN, IN KIND OF GAUGING THEIR OPINIONS BECAUSE THAT WILL GUIDE US INTO THE DIRECTION WE NEED TO HEAD.
FIRST, UH, JUST A QUICK QUESTION, UH, GO BACK TO TRYING TO REMEMBER WHICH SLIDE IT WAS, UH, ON THE RELIABILITY STANDARD.
SO I'M ASSUMING THAT THE LANGUAGE THAT WOODY, YOU WERE TALKING ABOUT, THE ADD IN ON WHAT THE LANGUAGE WAS WOULD LEAD BACK TO THE UNACCEPTABLE RELIABILITY RISK THAT YOU HAVE SET UP.
THAT'S WHAT YOU'RE GONNA BE EVALUATING THAT AGAINST IF YOU PUT THAT SENTENCE IN.
ANOTHER QUESTION IS, REAL QUICKLY, IT SAYS YOU'RE GONNA DO A GTC OR LIMITATIONS.
I MEAN, YOU'RE NOT GONNA PUT A GTC IN FOR A LOSS OF 500 MEGAWATTS OF GEN, ARE YOU
SO THAT'S GONNA BE AN EVALUATION ON WHICH WOULD BE THE MOST, UH, BEST WAY TO DO THAT ALSO? CORRECT.
I I, I WOULD JUST SAY WE HAVE, WE HAVE TO TAKE WHATEVER OPERATIONAL ACTIONS WE HAVE TO, AND THERE MAY BE A SITUATION WHERE THAT 500 MEGAWATT LOSS CREATES OTHER ISSUES.
AND THEN FINALLY ON THE RETRO THING THAT YOU BROUGHT UP, UH, I UNDERSTAND THAT THE ONLY CAVEAT I WOULD THROW IN THERE IS THAT BY GOING BACK TO LIKE 2023, I THINK EVERYTHING'S GONNA BE FINE WITH, YOU KNOW, THE INVERTERS THAT THIS CAN BE PUT IN, BUT THERE COULD BE AN ISSUE SOMEWHERE BECAUSE THESE MOST INVERTERS ARE BOUGHT TWO TO THREE YEARS BEFORE SGIA IS SIGNED.
SO I I I, I DON'T QUITE FULLY AGREE WITH NOT BEING A RETROFIT.
UH, BUT I UNDERSTAND YOUR CONCEPT AND I WASN'T TRYING TO ARGUE WITH THAT.
I JUST WANTED TO MAKE THAT WELL, THE KEY THING IS, IS THAT, THAT EVEN IF IT'S, SO YOU GOT A UNIT THAT SIGNED AN INTERCONNECTION AGREEMENT DECEMBER OF 2023, IF, IF WE PASS
[04:30:01]
THE RULES AND SAID, OKAY, THEY'RE SUBJECT TO THE PREFERRED RE NOW THE P 2,800 REQUIREMENTS, BUT THEY PHYSICALLY CAN'T DO IT, AND SO THEY ASK FOR AN EXEMPTION AND THEN WE GO THROUGH THE EXEMPTION PROCESS THAT THAT'S THE OTHER.AND SO THAT'S A MUCH BETTER WAY TO DO IT THAN SETTING THE BAR LOWER BY SAYING THEY'RE ONLY SUBJECT TO THE LEGACY REQUIREMENTS.
THAT WAS ACTUALLY THE SECOND PART.
I DIDN'T, DIDN'T STATE THAT THAT'S WHAT WOULD HAPPEN.
THAT TAKES CARE OF WHAT I WANTED TO KNOW.
YEAH, I JUST WANTED TO ASK QUESTION JUST TO CLARIFY THE STRUCTURE HERE A LITTLE BIT, RIGHT? BECAUSE WE'RE BACK, WE'RE GOING BACK AND FORTH BETWEEN KIND OF PRACTICAL CONSIDERATIONS AND THEN THEORETICAL SCENARIOS, RIGHT? AND IN SOME OF THESE CASES, THE THEORETICAL SCENARIO MIGHT NOT ACTUALLY EXIST AS A PRACTICAL MATTER, RIGHT? SO THE, I GUESS THE THING I'M TRYING TO UNDERSTAND IS WHAT NEW UNACCEPTABLE RELI RELIABILITY RISKS DOES ERCOT THINK EXISTS THAT THEY'RE GONNA HAVE TO DENY EXEMPTIONS FOR KEEPING IN MIND THAT YOU'VE GOT EQUIPMENT OPERATING ON THE SYSTEM DOWN HAS BEEN OPERATING FOR A WHILE, AND THE FACT THAT THE EXEMPTION ONLY KICKS IN WHEN YOU START TALKING ABOUT PHYSICAL MODIFICATIONS, RIGHT? SO WE'RE TALKING ABOUT AFTER WE'VE DONE EVERYTHING TO MAXIMIZE CAPABILITY FROM A SOFTWARE STANDPOINT AND GIVEN WHAT EXISTS TODAY AND GIVEN THE MITIGATIONS THAT ARE ALREADY UNDERWAY OR THE ISSUES THAT HAVE BEEN IDENTIFIED WITH SOLUTIONS, I'M TRYING TO UNDERSTAND AS A PRACTICAL MATTER, WHAT IS THIS NEW UNACCEPTABLE RELIABILITY RISK THAT WOULD REQUIRE, UM, FOR EXAMPLE, LIKE, UH, IF YOU GO BACK TO SLIDE 16, THIS SCENARIO NUMBER FOUR, RIGHT? SOMETHING THAT'S TECHNICALLY FEASIBLE AND HIGH COST AND PRESENTS AN UNACCEPTABLE RELIABILITY RISK.
IS THAT, IS THAT SCENARIO REALLY EXIST OR IS THAT JUST A HYPOTHETICAL? WELL, I THINK IT'S POSSIBLE THAT WHEN YOU, WHEN OKAY, ALL OF THIS IS PREDICATED, THAT'S ONE OF THE ASSUMPTIONS ON THE ASSUMPTION SLIDE, THAT, THAT WE GET BETTER, MORE COMPREHENSIVE MODELS THAT ACCURATELY REFLECT BOTH THE, THE, THE TUNING IN THE FIELD AND THE RESPONSE TO, TO VOLTAGE.
UM, ONCE WE GET THOSE MODELS IN FROM A SET OF RESOURCES IN AN AREA, IT COULD BE THAT WE HAVE, IF YOU GET A LIGHTNING STRIKE AT THIS POINT, WE HAVE 2000 MEGAWATTS THAT TRIP OFFLINE THAT WE'VE JUST NEVER HAD THE LIGHTNING STRIKE AT THAT POINT YET.
BUT WHEN WE DO THE SIMULATIONS WITH THOSE IMPROVED MODELS, WE DO SEE A PROBLEM.
AND SO THAT'S REALLY KIND OF WHAT WE'RE WORRIED ABOUT.
UM, I THINK THAT'S, OR AT LEAST THAT'S AN EXAMPLE OF THE, UH, WHERE WE WOULD FALL IN THAT BUCKET.
I MEAN, I THINK YOUR ASSUMPTION IS THAT, THAT IN YOUR QUESTION IS THAT, WELL, IT HASN'T HAPPENED YET, SO IT'S NOT A PROBLEM.
THAT'S NOT QUITE THE WAY THAT I WAS ASSUMING IT.
I THINK WHAT I'M SAYING IS I, I DON'T, WHEN YOU LOOK AT THE RISK AND THE ACTIONS TAKEN SINCE THE RISKS WERE IDENTIFIED, AND THEN CONSIDERING THAT YOU HAVE A FINITE SET OF ASSETS THAT OVER TIME, AGE, AND RETIRE AND CAN'T REDUCE THEIR EXISTING CAPABILITY BECAUSE THAT'S EXPRESSLY PROHIBITED.
AND THEN ON TOP OF THAT YOU'RE ADDING MORE CAPABLE EQUIPMENT ALONG WITH COMPLIMENTING GRID IMPROVEMENTS.
I'M TRYING TO UNDERSTAND AS A WHOLE WHY THAT, WHY WE WOULD THINK A NEW UNACCEPTABLE RELIABILITY RISK WOULD BE ARISING KIND OF AGAINST THAT BACKDROP AS A PRACTICAL MATTER, NOT AS LIKE A THEORETICAL THAT I UNDERSTAND THAT THEORETICAL CASE THAT ONCE YOU MODEL THIS, IT'S POSSIBLE, BUT I'M, I'M TRYING TO UNDERSTAND, DOES THAT SEEM LIKELY TO ERCOT, LET'S JUST SAY I HOPE NOT, BUT IT COULD HAPPEN.
AND, AND REALLY LET'S, CHAD, I JUST WANNA ADD, WE WE WANTED TO BE AS TRANSPARENT AS POSSIBLE ON OUR THOUGHTS AROUND THE EXEMPTION PROCESS.
THEY'RE ALL JUST SCENARIOS RIGHT NOW TO GIVE Y'ALL A TRANSPARENCY IN HOW THIS WOULD BE APPLIED.
IT DOESN'T MEAN THAT PRACTICALLY THERE IS SOMETHING THERE.
WE DON'T KNOW UNTIL WE GET THE MODELS IN AND START TO DO THE RELIABILITY ASSESSMENT.
BUT THERE'S ONLY A COUPLE OF SCENARIOS ON HOW THIS WOULD PLAY FROM AN EXEMPTION PROCESS.
IF TAC OR THE JOINT COMMONERS TALKING TO TAC HAVE A DIFFERENT WAY ON WHAT THEY WERE THINKING THE EXEMPTION PROCESS WAS GONNA LOOK LIKE, IT WOULD BE HELPFUL TO SEE THOSE SCENARIOS BECAUSE THAT REALLY GOES TO THE HEART OF WHAT THIS LANGUAGE WAS MEANT TO ACCOMPLISH.
AND WE ARE GONNA TRY TO GET TO THE JOINT COMMENTER'S PRESENTATION TODAY.
UM, SO WE ARE TO NED THIS WILL BE FAST.
UM, IT WAS ACTUALLY A, IT WAS A COMMENT IN RESPONSE TO WHAT SOMETHING YOU HAD MENTIONED, CAITLYN, ABOUT NEXT STEPS.
UM, IT WAS GONNA BE TONGUE IN CHEEK AND SAY WHAT POINT IN THE SCHEDULE ARE WE GONNA GO THROUGH THE RED LINES
[04:35:01]
AND JUSTUM, BUT I, I'M, I'M, I'M GLAD NO ONE SAVED THE ROTTEN TOMATOES AND CABBAGE TO THROW AT ME.
UM, BUT DAN, YOU MENTIONED THAT YOU HAD ACTUALLY GONE THROUGH AND CLEANED UP THE TAC APPROVED VERSION JUST TO GET DOWN TO WHAT THE ACTUAL RED LINES ARE.
THAT WOULD BE, I THINK, YOU KNOW, WE MAY ALL NEED TO LOOK THROUGH AND, AND AND DO A RED LINE.
SO THAT WOULD ACTUALLY BE REALLY HELPFUL IF THAT'S SOMETHING WE COULD POST.
AND I DON'T KNOW IF FROM A MARKET RULE STANDPOINT, IF THAT'S SOMETHING WE COULD PUT UP AS EXEMPLARY ON THE, ON THE MEETING PAGE FOR FOLKS TO REFERENCE OR NED YOU'RE LOOKING TO ME, BUT I REALLY THINK WE NEED TO LOOK TOWARDS COREY, CORY FOR THAT.
JUST AS STRANGE, THIS COME UP SO MANY TIMES WITHIN WORD, YOU GUYS CAN GO UP TO VIEW AND TOGGLE THAT TO EITHER NO MARKUP OR SIMPLE VIEW AND ALL OF THOSE 75 COLORS WILL GO AWAY AND YOU'LL SEE THE LANGUAGE AS IT WOULD BE IF IT WERE APPROVED, IF IN, IF WITHIN THAT VIEW YOU SEE SOMETHING YOU DISAGREE WITH, MAKE EDITS, AS LONG AS TRACK CHANGES ARE ON, IT'LL TRACK YOU AS THE 500TH AUTHOR ON THAT.
BUT YOU, YOU GUYS CAN WITHIN WORD WHAT'S OUT THERE POSTED RIGHT NOW, YOU CAN GET VERSIONS THAT WILL BE READABLE TO YOU, US GOING IN AND MANUALLY TRYING TO CREATE AN ARTIFICIAL DOCUMENT THAT REPRESENTS WHAT THE T REPORT IS.
BUT I WOULDN'T WANT ANYONE MAKING DECISIONS BASED ON SOMETHING COREY MOCKED UP AS A REFERENCE.
'CAUSE YOU ULTIMATELY WON'T BE VOTING ON THAT.
YOU WILL BE VOTING ON THE ATTACK REPORT.
SO WHAT I GUESS BY THAT, GUESS WHAT I WAS, WHAT I WAS GETTING TO IS KIND OF THE NET OF, YOU KNOW, THERE WERE COMMENTERS THAT ADDED SOME THINGS, THEN THOSE GOT STRUCK AND THEN YOU ADDED SOMETHING ELSE AND THEN THAT GOT STRUCK AND THEN SOMETHING GOT PUT BACK IN AND THEN THAT GOT STRUCK OR MODIFIED JUST GETTING TO THE NET OF THE CHANGES AND DOING LIKE SINGLE AUTHORSHIP AS THE TAC APPROVED VERSION AS A, AS A BASELINE.
THAT'S, THAT'S WHAT I WAS THINKING.
MAYBE DAN, YOU HAD SAID YOU HAD, YOU HAD WORKED TO, AND THAT WOULD SEEM, WELL WE CAN DO THAT.
I DIDN'T DO IT AS CORY, WE WE CAN DO THAT.
WE CAN TAKE OUT ALL THE ADDITIONAL COMMENTS AND JUST DO THE NET ONE COLOR RED LINE SO YOU CAN SEE WHAT THE VERSION LOOKS LIKE.
AND I RECOGNIZE WE COULD EACH DO THAT INDIVIDUALLY, BUT A COMMON BASELINE MAY BE HELPFUL.
BECAUSE I'M GUESSING WE'RE GONNA HAVE TO DO SOME, SOME EDITING AS A GROUP BEFORE THE, THE, UH, THE NEXT 30 DAYS ARE OUT.
YEAH, WE WOULD JUST, WE WOULD JUST TITLE IT APPROPRIATELY THAT REPRESENTS WHAT IT IS, WHICH IS THE NET CHANGES OF, YOU KNOW, THE TAC APPROVED VERSION AND THAT, BUT THAT WOULD JUST THEN BE USED AS YOUR GUIDE TO THEN HAVE THE TAC REPORT OPEN AND PROPOSE ALL THE ADDITIONAL RED LINES YOU'D WANNA DO ON THAT OTHER DOCUMENT.
SO NOW YOU'RE JUST JUGGLING BETWEEN THE TWO DOCUMENTS AND MAKING SURE YOU'RE PUTTING THE EDITS WHERE YOU INTEND THEM TO BE.
YEAH, IT'S STILL GONNA HAVE SOME VALUE, I THINK, JUST TO REMOVE ALL THE OTHER CHANGES THAT HAVE HAPPENED IN THIS 18 MONTH PROCESS.
SO WE'RE TALKING ABOUT A CLEAN LINE OF THE TECH APPROVED VERSION, THAT'S ALL WE'RE TALKING ABOUT, RIGHT? CORRECT.
SO IT'S A, IT'S A DELTA BETWEEN THE ORIGINAL LANGUAGE AND THE T OF VERSION.
WAS IT, DO YOU THINK IT WAS IMPORTANT MOVE OFF NEXT SLIDE.
OKAY, LET'S MOVE ON TO THE NEXT SLIDE.
YEAH, I'LL, I'LL TRY TO FIND A WAY TO END THIS.
UH, I GUESS ONE MORE THING I WANTED TO SAY ON THIS SLIDE THOUGH IS THAT ONE OF THE THINGS THAT I'VE RECOGNIZED IS, IS THE, IF WE COULD GET THE RIGHT MODELS AND THE RIGHT, UM, UH, THAT WHERE IT ACTUALLY SIMULATE WHERE WE COULD DO SIMULATIONS AND SET UP THE GTCS IN THE WAY THAT THEY ACTUALLY REFLECT WHAT WOULD HAPPEN THEN A LOT OF THIS IS GOING TO THE, THE, THE, THE COST NOW TO, IF, IF TO THE, UH, SYSTEM AND THE COST TO THE, THE RESOURCE ENTITIES ARE GONNA COME CLOSER TOGETHER.
'CAUSE NOW YOU'RE GETTING CURTAILED A LOT BECAUSE OF YOU'RE NOT ABLE TO MEET THE REQUIREMENTS.
AND SO NOW THERE'S SOME IN ADDITIONAL FINANCIAL INCENTIVE TO PUT IN THOSE UPGRADES, UM, THAT DOESN'T EXIST TODAY.
BUT YOU KNOW, THAT THERE'S, I THINK I SAID IT IS THREE TIMES THERE.
SO, YOU KNOW, THAT WOULD BE THE, THE KIND OF THE GOOD WAY, PLACE TO GET TO.
UH, WE ALREADY TALKED ABOUT EXEMPTIONS FOR UNCERTAINTIES.
I'M NOT GONNA GO OVER THAT ONE TOO MUCH.
THERE'S, THERE'S A LOT OF THINGS THAT, THAT AT LEAST THE RESOURCE ENTITIES WHEN WE DID THE SURVEY SAID THEY DIDN'T KNOW THE OEMS SEEMED TO KNOW MORE, BUT OF COURSE THAT'S AT THE TURBINE LEVEL.
AND SO, UM, YOU KNOW, WE DON'T BELIEVE IT'S APPROPRIATE TO KIND KIND OF THIS ONGOING, UM, EXEMPTION PROCESS.
UM, THERE'S A, UM, NOW THIS IS ABOUT COST PROHIBITIVENESS, UH, I SHOULD HAVE PUT THIS UP EARLIER.
[04:40:01]
IF, IF, IF EVERYBODY ASSESSES THEIR COMMERCIAL REASONABILITY IN A COMPLETELY DIFFERENT WAY, DIFFERENT PLANTS CAN COME TO COMPLETELY DIFFERENT ANSWERS FOR REASONS THAT DON'T MAKE SENSE THAT THEY WOULD BE DIFFERENT.AND THAT'S WHERE IF, IF WE'RE GONNA GO DOWN THE PATH OF DOING SOME KIND OF FINANCIAL ANALYSIS, IT WOULD BE BETTER FOR THAT TO BE A PROFORMA WHERE EVERYBODY THAT'S ASKING FOR AN EXEMPTION LOOKS AT IT USING THE SAME VARIABLES AND THE SAME ASSUMPTIONS TO THE EXTENT THEY'RE NOT, YOU KNOW, DIFFERENT BETWEEN COMPANIES OR SOMETHING.
IT'S A WHOLE LOT SIMPLER IF YOU JUST COME UP WITH A 50% NUMBER OR A 10% NUMBER THAT SOMEBODY MENTIONED WHILE AGO.
UM, I'LL STOP ON THESE QUESTIONS.
UM, THE, YOU KNOW, I I, I DON'T THINK THIS IS EVEN A QUESTION.
I THINK THE BOARD IS, AND THE COMMISSION REALLY WANTS IT TO BE A, A CONSISTENT OBJECTIVE, REPEATABLE CRITERIA THAT'S USED ACROSS ALL OF THESE EXEMPTIONS.
AND SO WE NEED TO COME UP WITH A MECHANISM FOR DOING THAT.
CAN, CAN I JUST FOR THE RECORD STATE THAT ERCOT IS NOT PROMOTING A 10% CRITERIA YEAH.
THAT TENDS TO GET GRABBED AND THEN REUSED AND, AND PLOTTED EVERYWHERE.
THAT'S NOT WHAT WE'RE WE PROPOSE.
AND I THINK, SO 22 TO 24 HAS KIND OF ALL SAME VARIATION OF CREATING A COST BASED CRITERIA THAT STAYS AS A FIRM CRITERIA.
IS THAT, THAT'S NOT SOMETHING WE CAN GET TO AN AGREEMENT ON, I DON'T THINK, CERTAINLY NOT TODAY, BUT I, THE FACTORS THAT WERE LAID OUT EARLIER, I MEAN, THERE'S THINGS TO DISCUSS.
THERE'S THINGS TO DISCUSS THERE.
AND IT'S SOMETHING ALL THE TAC MEMBERS CAN CONSIDER.
UM, WHAT HAPPENS WHEN SOMEBODY'S ASKED FOR AN EXEMPTION? THERE'S A PROCESS THERE.
UM, THE, UM, UM, SHOULD THEY AVOID? SHOULD THEY BE, ARE THEY STILL SUBJECT TO THE CURRENT REQUIREMENTS UNTIL THE EXEMPTION IS GRANTED? THAT'S REALLY THE, THE QUESTION HERE.
AND SO I THINK THAT'S A, THAT'S ANOTHER QUESTION.
YOU KNOW, DO YOU HAVE A YEAH, UH, I'M NOT THAT'S GOOD ENOUGH.
UM, I MENTIONED EARLIER WE NEED TO MAKE SURE WE'VE GOT, IF, IF A LOT OF THESE EXEMPTION REQUESTS COME IN AT THE SAME TIME, WE NEED TO MAKE SURE WE'VE GOT THE, THE ENOUGH TIME TO DO THAT.
RIGHT NOW THERE'S SOME PRETTY STRICT REQUIREMENT, UH, TIMELINES IN THE TAC APPROVED VERSION THAT PROBABLY DON'T ALL ALLOW, THEY MAY BE FINE FOR KIND OF ONE-OFFS THAT COME IN, UH, FOR SOME OF THESE NEW PLANTS THAT ARE SIGNING AN SGIA AND FIND OUT THEY'VE GOT AN ISSUE OR SOMETHING, BUT THEY, THEY DON'T WORK WHEN WE'RE GONNA GET THIS HUGE MASS IN.
UM, ONCE THIS BECOMES, UM, HEY DAN.
I THINK WE'D LIKE THE LANGUAGE TO BE RATHER FLEXIBLE SO THAT IT'S, YOU KNOW, WE WOULD TARGET A CERTAIN TIME, BUT WE COULD GET EXTENSIONS OR AS SOON AS PRACTICAL.
OUR, OUR COMMITMENT IS TO TRY TO GET IT DONE AS SOON AS POSSIBLE, BUT WHEN WE DON'T HAVE A FIRM IDEA ABOUT THE VOLUME, IT'S HARD FOR US TO COMMIT TO THAT TIME.
BUT, UM, I DID WANT TO JUST BASED ON SOME EARLIER COMMENTS, I THINK IT MIGHT BE GOOD TO JUST ASK, IS THIS AN AREA OF AGREEMENT THAT WE COULD HAVE? WE'RE OPEN TO MORE TIME HERE.
WE LIKE A CLEARLY DEFINED PROCESS.
UM, SO WHEN YOU TALK ABOUT AS SOON AS PRACTICAL, THAT START TO MAKE ME NERVOUS, BUT GIVING YOU MORE TIME, I THINK IS SOMETHING WE'RE OPEN TO TALKING ABOUT.
YOU WANNA LET JULIA, AND IF I MIGHT INTERJECT FOR JUST A SECOND THERE, WE'RE DEFINITELY OPEN TO DISCUSSING MORE DAYS AND THAT KIND OF THING.
THE TOTAL DAYS FOR REVIEW WAS 180 DAYS UNDER THE WHAT TAC APPROVED, UM, WHAT TAC ALSO APPROVED WAS THIS FIRST THING THAT WAS MORE AKIN TO LIKE AN ADMINISTRATIVELY COMPLETE KIND OF DETERMINATION.
AND IF THERE'S MORE TIME NEEDED FOR THAT, OF COURSE, I MEAN THAT, THAT WASN'T INTENDED TO BE AN ONEROUS THING AT ALL.
IT'S JUST TRYING TO KEEP THE BALL MOVING.
IF, IF ERCOT SEES SOME BIG DATA POINT MISSING,
[04:45:02]
WE WANNA GET IT TO YOU AS QUICK AS POSSIBLE.I THINK WE'VE GOTTA FIGURE OUT WHAT THE REST OF THE PROCESS IS LIKE.
I THINK TO GRANT EXEMPTIONS, WE'RE GONNA HAVE TO GET ALL THEIR EXEMPTIONS REQUESTS IN KIND OF AT A COMMON TIME SO WE CAN ACCESS, UH, ASSESS THE JOINT IMPLICATIONS OF ALL THOSE EXEMPTIONS AND THOSE KIND OF THINGS.
SO IT'S ALMOST LIKE WE'VE GOTTA DEFINE THE WHOLE PROCESS AND THEN AS STEVEN SAYS, IT'S STILL GONNA BE HARD BECAUSE WE DON'T KNOW HOW MANY WE'RE GONNA GET.
BUT, UM, ONCE WE, WE JUST NEED TO DO MORE WORK ON DISCUSSING WHAT THAT PROCESS LOOKS LIKE.
I THINK, YEAH, I WOULD JUST ADD THAT THERE IS A LEVEL OF TRIAGE WE CAN DO EARLY.
UM, WE NEED MORE TIME BECAUSE WE COULD GET A, A LARGE VOLUME IN.
BUT ONCE WE DO THE AGGREGATE ASSESSMENT, ASSUMING WE CAN SET A FIRM DATE THAT THEY'RE ALL IN AND THAT STARTS THE CLOCK FOR LIKE 180 DAYS FOR THIS ONE TIME ASSESSMENT, THEN, YOU KNOW, THAT MAY BE A, A STRUCTURE TO CONSIDER.
SO BASED ON THE CURRENT VERSION, WHAT IS THAT DUE DATE FOR EXEMPTION REQUESTS TO COME IN FEBRUARY 1ST, 2025.
I I WOULD JUST SAY FEBRUARY 1ST, 2025 FOR THE LEGACY, ANY NEW EXEMPTIONS FOR IEEE 2,800 DON'T HAVE THAT FIRM DATE.
IT WOULD BE AS THEY APPROACH, UH, COMMERCIAL OPERATIONS.
JULIA? YEAH, I HAD A, I MEAN, I MENTIONED THIS IN MY PRESENTATION TOO, BUT THEN IF YOU GO TO SLIDE 25, I BELIEVE, UH, NO, WHERE YOU HAD BAR CHARTS.
SO, UM, I'M JUST THINKING IF THERE IS A WAY TO DO IT MORE EFFICIENTLY BY BATCH PROCESSING PLANTS WITH THE SAME TYPE OF EQUIPMENT, AND THIS WAY IT MAKES IT MORE TRANSPARENT FOR EVERYBODY.
SO IN TERMS OF LIKE COMMERCIAL REASONABILITY VERSUS TECHNICAL FEASIBILITY, IF YOU LOOK AT THE SAME EQUIPMENT, SAME MODEL MAKE TOGETHER, THIS WAY IT'S VERY CLEAR WHAT'S TECHNICALLY POSSIBLE, WHAT'S COMMERCIALLY REASONABLE.
THERE'LL STILL BE DIFFERENCES FROM THE PLANT LEVEL PERSPECTIVE, BUT THEN, UH, I THINK YOU CAN CLEAR OUT A BATCH OF ISSUES MUCH FASTER AND IN STREAMLINE MANNER AND IN MORE KIND OF OPEN WAY BETWEEN THE GENERATORS AND THE ORCO.
YEAH, I, I THINK THAT'S A GOOD QUESTION.
IF WE CAN HAVE THE GUARDRAILS THAT ERCOT PROPOSED AND WE HAVE MORE CERTAINTY ON THE TWO TO FOUR GIGAWATTS, THEN WE'VE SPOKEN WITH THE OEMS TO WHERE THEY, AND IN PUBLIC COMMENTS, THEY'VE IDENTIFIED WHICH ONES ARE MOST AT RISK.
SO WE CAN DO THAT TYPE OF BATCHING, BUT WE GOTTA GET EVERYBODY IN TOGETHER, NOT JUST ONE OEM BECAUSE WE HAVE TO LOOK AT THE SYSTEM ASSESSMENT.
BUT WE NEED THOSE GUARDRAILS BECAUSE AS SOON AS YOU OPEN UP FOR ALL THE UNKNOWN THINGS, IT COULD, IT COULD BALLOON REALLY QUICKLY.
YEAH, JUST, JUST A COUPLE QUICK QUESTIONS ON, ON THE PIECE WHERE YOU'RE TALKING ABOUT YOU WANT IT, YOU'RE, YOU'RE GONNA SAY ON YOUR SIDE YOU'RE SAYING YOU WANT FULL COMPLIANCE UP UNTIL THE TIME YOU GET AN EXEMPTION.
THAT'S, THAT'S WHAT I'M HEARING.
RIGHT? AND WE KNOW THAT THAT AIN'T GONNA HAPPEN, YOU KNOW, 'CAUSE OTHERWISE YOU WOULDN'T HAVE FILED AN EXEMPTION.
SO THOSE THAT ARE OPERATING UNTIL THEY GET THE AB UH, ABSTENTION ARE OPERATING IN A NON-COMPLIANT ATMOSPHERE, ARE YOU GOING TO REPORT THEM TO THE ERM WHEN THEY FILE THAT EXEMPTION? OR, OR WHAT ARE YOU GONNA DO? I MEAN, WE ALREADY KNOW ONCE YOU GET THE EXEMPTION, THEY'RE NOT DOING IT SO WELL.
SO IF SOMEBODY, IF SOMEBODY TODAY TRIPPED OFFLINE AT 95% VOLTAGE OR SOMETHING LIKE THAT, THEY DIDN'T, YOU KNOW, WE HAD A MINOR FAULT FAR AWAY AND THEY TRIPPED OFFLINE AND THEY WERE SUPPOSED TO, YOU KNOW, THERE WERE A 2016 VINTAGE UNIT, THEN WE WOULD PROBABLY REPORT 'EM TO THE ERM TODAY.
WELL, THAT, THAT'S WHAT I WAS TRYING TO MAKE SURE.
LIKE I SAID, THE ONLY REASON I'M ASKING IS, YOU KNOW, THEY'RE OUTTA COMPLIANCE WHETHER I UNDERSTAND THE PIECE.
IF WE HAVE AN EVENT AND THEY TRIP OFFLINE OF, OF, THAT'S HUGE ISSUE.
THE ONLY THING I'M CHECKING ON IS, YOU KNOW, THEY'RE OUTTA COMPLIANCE IMMEDIATELY.
DOES THAT GET REFERRED TO THE ERM
[04:50:01]
BECAUSE THEY ARE KNOWN TO BE OUTTA COMPLIANCE WITH WHERE YOU'RE AT? OR WOULD IT BE JUST IN THE EVENT THERE WAS A, UH, UH, AN EVENT AND THEY DIDN'T RIDE THROUGH SOMETHING LIKE THAT? THE, THE LATTER, RIGHT? BECAUSE IF WE'RE RECOGNIZING IN THE PROCESS THAT WE'RE GOING TO ALLOW EXEMPTIONS, WE NEED TO HAVE A PROCESS FOR PEOPLE TO SUBMIT THEIR EXEMPTIONSSO WE'RE NOT GONNA THEN REFER ALL THOSE EXEMPTIONS OF THE ERM AND SAY, OH, WE GOT 'EM ALL OUT OF COMPLIANCE WITH THEIR RIDE THROUGH REQUIREMENTS.
WE'D ONLY BE IN AN ACTUAL PERFORMANCE FAILURE WHERE WE WOULD HAVE TO MAKE THAT REFERRAL OVER.
SO HOPEFULLY THAT ANSWERS YOUR QUESTION, BUT IT, IT, IT DOES.
IT'S TO, IT'S, IT'S THE WAY THE PROCESS NEEDS TO WORK IS WE NEED TO SEE, EVERYBODY NEEDS TO HAVE AN OPPORTUNITY TO SUBMIT THEIR EXEMPTIONS AND IT NEEDS TO BE EVALUATED BY ERCOT ON THE OVERALL RELIABILITY ASSESSMENT THAT WE AGREE TO IN, IN THE FRAMEWORK.
AND THEN FROM THERE GO, IT'S NOT TO, IF WE GET 200 EXEMPTIONS TO REQUEST IN BY FEBRUARY, 2025, WE'RE GONNA REFER 200 TO THE ERM.
I DIDN'T FIGURE YOU WERE, BUT I'M TRYING TO YEAH.
UH, IS THERE A CHANCE, AND I DON'T KNOW IF YOU THINK ABOUT IT THAT THE WAY YOU WORD IT, AND I'D HAVE TO LOOK AT THE WORDS AGAIN, THAT YOU WORD IT IN A MANNER THAT CLARIFIES WHAT YOU JUST SAID, THAT IT'S BASED ON PERFORMANCE AND NOT JUST STATIC COMPLIANCE.
YEAH, I MEAN I THINK THAT YEAH, THAT'S ANOTHER OPPORTUNITY FOR, FOR CLARITY, SETTING THE EXPECTATIONS, RIGHT? YEAH.
YEAH, THAT'S WHAT THE, THE EXEMPTION PROCESS WOULD BE.
DO YOU WANNA KEEP GOING? AND I GUESS WE'LL TRY TO WRAP THIS UP, YOU KNOW, AS SOON AS YOU CAN IN THE NEXT 15 MINUTES.
MAYBE
WELL WE CAN, I, I WANNA MAKE SURE WE GET, YOU KNOW, PRETTY EQUAL TIME TODAY JUST WI WITH EVERYBODY PRESENT AT THE SAME TIME AND, AND YOU KNOW, THINGS ON THEIR MIND.
BUT I THINK SOME OF THESE TOPICS HAVE BEEN REPEATING THROUGHOUT THE PRESENTATIONS SO WE CAN KIND OF ASSESS BY TOPIC AND, AND AGAIN, YOU KNOW, THINK ABOUT HOW WE'RE GONNA TAKE THINGS AT NEXT T BUT I, I DO WANNA MAKE SURE WE TRY TO GIVE JOINT COMMENTERS, UM, SOME TIME FOR THEIR PRESENTATION TODAY AS WELL.
SO THIS IS ONE THAT I THINK WE MAY BE ABLE TO GET TO AGREEMENT ON BECAUSE RIGHT NOW, UH, THERE'S THE, UH, FOR A UNIT THAT HAS A PERFORMANCE FAILURE, THEY SUBMIT AN EXEMPTION REQUEST, THEY COME UP WITH A MITIGATION PLAN.
THERE'S NOT CURRENTLY ANY LANGUAGE THAT SAYS THEY HAVE TO MITIGATE THAT OR IMPLEMENT THAT MITIGATION PLAN.
SO I, I'M HOPING THAT'S WAS JUST, UM, UM, A MISTAKE IN THE EDITING, UM, THAT IF YOU HAVE TO MITIGATE, IMPLEMENT A MITIGATION PLAN, YOU KNOW THAT IF YOU DEVELOP ONE THAT'S NOT REALLY DOING ANYTHING, YOU HAVE TO IMPLEMENT IT.
THE UNDERSTANDING THERE IS FOLLOWING WHATEVER MITIGATION PLAN YOU ADOPT.
SO YES, THAT'S, AND HAPPY TO CLARIFY LANGUAGE AT THAT.
IF THERE'S ANY QUESTION THERE.
ALMOST FEEL LIKE WE SHOULD END ON THAT ONE.
SO THAT WAS, CAN YOU GO BACK, JUST SO WE'RE CLEAR ON THAT WAS THREE CHECK RECOMMENDED VERSION.
SO THE AGREEMENT HERE NOW IS, SO I THINK WE JUST ADD A SENTENCE AND SHALL IMPLEMENT THE MITIGATION PLAN OR A PHRASE.
SO CAN I JUST WANT TO POINT OUT ONE OTHER ISSUE HERE WHEN Y'ALL LOOK AT THE LANGUAGE IS THAT AS READ TODAY, EVERY SINGLE PERFORMANCE FAILURE MANDATES A NEW EXEMPTION TO BE FILED OR UPDATING AN EXISTING.
SO THAT JUST MAY BE SOMETHING ELSE Y'ALL CONSIDER.
DID YOU REALLY INTEND TO MANDATE A NEW EXEMPTION? EVERY SINGLE PERFORMANCE FAILURE? UM, WE WANNA MAKE SURE THAT THE MODELS ARE ACCURATE.
AND SO AFTER A PERFORMANCE FAILURE, YOU'RE REQUIRED TO SUBMIT, UH, AN UPDATED MODEL AND MAKE ANY CHANGES THAT ARE COMMERCIALLY REASONABLE TO ADDRESS THE PERFORMANCE FAILURE AND THAT FOLLOWS THIS EXEMPTION PROCESS.
I, I HEARD EVERYTHING YOU SAID, BUT IT REALLY DIDN'T ANSWER, UM, THE QUESTION.
THE WAY WE READ IT IS THAT IT SEEMS TO, UH, REQUIRE
[04:55:01]
Y'ALL TO SUBMIT A NEW EXEMPTION IF YOU HAVE A PERFORMANCE FAILURE AUTOMATICALLY BY DEFAULT AS OPPOSED TO MITIGATING THEM.I'M NOT SURE THAT WAS THE INTENT ONE WAY OR THE OTHER, BUT WE CAN TAKE A LOOK AT IT.
YEAH, WE'LL TAKE A LOOK AT IT, BUT WE, WE MIGHT BE SPEAKING PAST EACH OTHER, BUT IF YOU HEARD EVERYTHING WE SAID, THEN MAYBE WE'RE ENGRAVING EACH OTHER, BUT WE SHOULD TALK MORE.
BOB HILTON? NO, GO AHEAD AND TAKE ME OUT.
GO BACK TO THAT PAGE, NOT THAT ONE.
'CAUSE THIS, ANY MITIGATION PLAN IS GONNA HAVE TO GO THROUGH 1 0 9 AND EVERYTHING ELSE.
SO YOU'RE GONNA HAVE TO LOOK AT, AND ACTUALLY MAYBE THERE'S SOMETHING WE COULD PUT IN HERE ABOUT, ABOUT, YOU KNOW, PART OF THE MITIGATION PLAN WOULD HAVE TO BE TO FILE A NEW MODEL RATHER THAN AN EXEMPTION.
'CAUSE YOU'RE GONNA GET DENIED ON THE EXEMPTION BASED ON THE CRITERIA AUTOMATICALLY.
SO, UH, YOU HAVE TO THINK ABOUT THAT.
IF YOU LOOK AT THE CRITERIA THEY HAVE, WE HAVE A SLIDE ABOUT THIS IN OUR PRESENTATION.
I THINK IN RESPONSE TO STEVEN'S QUESTION, AND THE LANGUAGE IS UP HERE, BUT IT'S A LITTLE HARD TO SEE BECAUSE THE CLAUSES ARE SO LONG.
IF YOU'RE AN EXISTING RESOURCE THAT HAS A PERFORMANCE FAILURE, THEN YOU IMMEDIATELY ARE IN A POSITION WHERE YOU NEED TO DETERMINE WHAT YOU CAN DO TO MITIGATE THAT FAILURE.
AND SO YOU'VE GOTTA UPDATE THE DOCUMENTATION YOU ALREADY HAVE WITH ERCOT AND SUBMIT A PLAN, RIGHT? TO UPDATE YOUR, WITH ANY SOFTWARE AND THEN COMMERCIALLY REASONABLE PHYSICAL MODIFICATIONS TO SOLVE THAT ISSUE.
SO THAT'S WHY THERE'S, IN EVERY CASE A FILING REQUIREMENT.
AND THIS IS IN A, WITH A BUNCH OF CLAUSES AFTER IT, BUT THAT'S WHAT'S HAPPENING.
SO IT'S NOT THAT YOU AUTOMATICALLY GET ANOTHER EXEMPTION, IT SAYS A NEW EXEMPTION OR EXTENSION REQUEST.
SO YOU HAVE AN EVENT, YOU'RE NOW NOT COMPLYING WITH THE CAPABILITY THAT YOU SAID YOU HAD.
YOU HAVE TO GO, YOU IMMEDIATELY SAY, OKAY, WELL I NEED SOME TIME THEN TO MITIGATE IT.
AND YOU'VE GOTTA UPDATE THAT INFORMATION WITH ERCOT.
AND THEN OBVIOUSLY IN B IT IS THEN MAKE THOSE SOFTWARE IN COMMERCIALLY REASONABLE PHYSICAL MODIFICATIONS TO MITIGATE TO THE EXTENT THAT YOU CAN.
YEAH, I I THINK Y'ALL TAKING IT AWAY AND, AND REALLY LOOKING AT IT AGAIN WOULD BE JUST THE BEST THING.
IT, IT'S JUST, I PRETTY SURE Y'ALL DIDN'T MEAN WHAT THE WORDS ARE THERE, SO JUST TAKE A MOMENT AND, AND REVIEW IT.
UM, SO THEN THERE'S THE QUESTION OF WHAT ABOUT THE DATE FOR NEW REQUIREMENTS? AND I GUESS THE, YOU KNOW, THERE, THERE'S ALL THE NUMBERS ARE IN HERE ABOUT WHICH ONE, WHAT, HOW MANY UNITS? IT'S THE, WE GOT TO THE 20 TO 30 GIGAWATTS THAT WE TALKED ABOUT BEFORE.
UM, BUT REALLY THE, I THINK THE, THE KEY ISSUE IS DO YOU START THE, THE IEEE 2,800 REQUIREMENTS BACK IN SIX SIX, UH, JUNE OF, OF LAST YEAR AND THEN ALLOW EXEMPTIONS FROM THERE.
OR DO YOU START THE NEW REQUIREMENTS OUT INTO THE FUTURE, YOU KNOW, FALL OF THIS YEAR AND THEN LET ALL THESE PEOPLE IN THE MIDDLE MEET THE OLD REQUIREMENTS WITHOUT ANY, UH, INCENTIVE TO TRY TO MEET THE BETTER REQUIREMENTS.
IT SEEMS LIKE IT'S BETTER FOR EVERYBODY TO SET IT BACK OVER AT WHEN WE FILED THE NO, OR ACTUALLY SIX MONTHS AFTER WHEN WE FILED THE NOER AND THEN ALLOW THE EXEMPTION PROCESS TO DETERMINE WHICH ONES DON'T HAVE TO DO IT.
TO SOME EXTENT, THIS BECOMES A SMALLER THING IF EVERYBODY HAS TO GO UP TO THE EQUIPMENT RATINGS OR THE EQUIPMENT CAPABILITY ANYWAY.
BUT IT WOULD STILL BE CLEARER TO MAKE IT, TO PUT IT BACK AT THIS 6 23 DATE AND THEN ALLOW EXEMPTIONS, UH, FOR PLANTS THAT ARE CURRENTLY IN DEVELOPMENT THAT CAN'T MEET IEE 2,800.
BOB, WERE YOU UP FIRST? I DON'T KNOW.
SO IF YOU FILE AN EXEMPTION THE WAY
[05:00:01]
YOU'RE TALKING, UH, IT'S LOW, IT'S TECHNICALLY FEASIBLE, LOW CLOCK CROSS AND IT HAS ACCEPTABLE RISK.YOU'RE NOT GONNA GET AN EXEMPTION.
YOU'RE GONNA GET REFERRED TO THE ERM IS WHAT'S GONNA HAPPEN.
SO IN MY MIND THAT'S KIND OF AN UNACCEPTABLE CONDITION TO BE IN, UH, FOR THAT PLACE.
AND THAT'S WHY I DON'T NECESSARILY DISAGREE WITH GOING TO THE 2024 TO GIVE SOME TIME HERE FOR THE, THE PEOPLE THAT ARE BUYING THEIR, THEIR INVERTERS AND EVERYTHING AND THE TESTING AND EVERYTHING CAN GET TO THE POINT THEY NEED TO BE.
AND IF THEY DO DO THAT, THERE'S PROBABLY GONNA BE FEWER THAN MORE IN MY MIND.
'CAUSE YOU'RE NOT GONNA GRANT THE EXEMPTION ANYWAY.
UH, 'CAUSE THAT'S GONNA BE A SCENARIO MOST LIKELY WITH THE NEWER TECHNOLOGIES, THEY'RE GONNA BE PRETTY CLOSE, MAY NOT BE ALL THE WAY THERE, THERE MAY BE SOFTWARE CHANGES AND STUFF THEY HAVE TO DO, WHICH ARE GONNA BE LOW COST.
UH, AND WHETHER THERE'S ACCEPTABLE RISK OR NOT ACCEPTABLE RISK, YOU'RE STILL GONNA GET THROWN OVER TO THE ERM.
AND I KNOW THAT THAT OR THE ERM DOESN'T FIND LIKE IT WAS PUT IN THERE, THAT WASN'T MY INTENTION OF SAYING THAT EARLIER, BUT YOU'RE SUBJECTED TO THAT, UH, AND SOMEONE ELSE WILL MAKE THAT DECISION.
SO YOUR DESTINY IS NOT IN YOUR OWN HANDS.
SO YOU'RE TALKING ABOUT SCENARIO TWO? YEAH, 'CAUSE THAT'S EXACTLY WHAT I BELIEVE, BUT IT SAYS IF YOU DON'T IMPLEMENT THE LOW COST SOLUTION, SO UNDER THAT SCENARIO TOO, OKAY, NEVERMIND.
BECAUSE IT WELL YOU HAVE TO READ THE, I MEAN IT SAYS IF SOLUTION IS NOT IMPLEMENTED RIGHT.
I MEAN, CLEARLY IF YOU DON'T IMPLEMENT THE LOW COST SOLUTION, THEN YOU'RE RIGHT.
UH, SO THIS, THIS IS ONE WHERE THERE'S A, THERE'S A PRINCIPLED ARGUMENT THAT THAT'S REALLY IMPORTANT TO US AND THAT IS THAT NEW NEW REQUIREMENTS SHOULD ONLY BE APPLICABLE ON A GO FORWARD BASIS.
IT'S CERTAIN IT'S, IT'S A HIGH BAR EVEN TO HAVE RETROACTIVE REQUIREMENTS AND THAT, YOU KNOW, WE AGREE THAT THIS IS A SCENARIO THAT THAT RISES TO THAT BAR.
AND SO, YOU KNOW, THAT'S WHY WE'RE TALKING ABOUT HOW DO YOU ADDRESS THEM.
BUT THIS IS EXACTLY THE REASON WHY WE SUPPORTED BIFURCATING THE APPROACH FROM THE GET GO IS WE COULD HAVE, YOU KNOW, ANSWERED, WE COULD HAVE PUT A LINE IN THE SAND FOR NEW RESOURCES A LONG TIME AGO AND, AND, YOU KNOW, NOT BE, NOT HAVE THIS AS ONE OF THE HANGUPS.
UM, BUT THIS IS, THIS IS ONE WHERE JUST AS A, AS A MATTER OF PRINCIPLE, WE'RE, IT'S IMPORTANT TO US THAT THIS BE APPLICABLE ON A GO FORWARD BASIS ONLY WHETHER WE GET THAT EXACTLY RIGHT, YOU KNOW,
UM, OR WE, YOU KNOW, WE GET IT IN THE BALLPARK.
I KNOW ON NORE 2 55, FOR INSTANCE, WE CHOSE JUNE 1ST, BUT IT TURNS OUT PROCEDURALLY THAT, YOU KNOW, THE BOARD'S NOT GONNA BE ABLE TO TAKE IT UP UNTIL JUNE AND THE PC WON'T TAKE IT UP UNTIL AFTER THAT.
BUT IT'S CLOSE ENOUGH, RIGHT? IT'S, IT'S, WE DON'T HAVE TO ALWAYS HAVE IT EXACTLY ON THE DATE, BUT WE SHOULD BE TRYING TO ALIGN THOSE EFFECTIVE DATES OF NEW REQUIREMENTS TO A POINT WHERE, YOU KNOW, FOLKS THAT ARE MAYBE NOT FOLLOWING THE STAKEHOLDER PROCESSES AS CLOSELY AS OTHERS MAY, YOU KNOW, THEY'LL, THEY'LL AT LEAST BE ABLE TO LOOK AT IT AND, AND HAVE A REASONABLE CHANCE OF SEEING THAT.
THAT'S, THAT'S WHEN THINGS APPLY.
AND IT SEEMS LIKE THAT'S CONSISTENT WITH PRETTY MUCH WHAT EVERY OTHER, WHAT NERC HAS BEEN LOOKING AT AND WHAT, UH, MOST OTHER JURISDICTIONS, MAYBE WITH THE EXCEPTION OF SALT, SALT RIVER PROJECT, UH, AS JULIA MENTIONED EARLIER.
YEAH, SO WHAT I SAID IS LIKE LAST YEAR, WHOEVER ADOPTED IT LAST YEAR, THEY HAVE THIS DATE FROM, FROM LIKE WHEN THEY ADOPTED GOING FORWARD.
AND EVEN IN THAT CASE, IF I WAS UNDERSTANDING THE COMMENT CORRECTLY, WHAT THEY'RE LOOKING AT DOING RIGHT NOW THAT WOULD BE RETROACTIVE IS REALLY CLARIFYING WHAT WAS ALREADY PUT IN PLACE ON A PROSPECTIVE BASIS, RIGHT? THEY HAD DONE A WHOLESALE ADOPTION AND NOW THEY'RE, THEY'RE LOOKING TO CLARIFY, THEY'RE LOOKING LIKE PIECE BY PIECE AND THEN POTENTIALLY MAY GO RETROACTIVE ON SOME OF THE PIECES LIKE WRITE THROUGH, FOR EXAMPLE, LIKE MORE IMPORTANT ONES.
ONE THING JUST TO MENTION IS THAT IT'S, IT'S LIKE THE DATE EFFECTIVE DATE IS, IT'S LOOKING LIKE, LIKE IT'S KIND OF LIKE, YOU KNOW, BACK IN THE PAST, BUT IN REALITY THESE PLANS ARE STILL NOT OPERATIONAL.
AND SO EVEN IF THEY ADOPTED, SAY LAST YEAR, THESE PLANS THAT WILL HAVE TO COMPLY WITH THIS REQUIREMENTS WILL PROBABLY HIT THE GROUND IN THE NEXT COUPLE OF YEARS BECAUSE IT'S, IT'S, IT'S APPLIED THERE, BUT IT'S APPLIED THAT SIGNED INTO CONNECTION AGREEMENT OR SIGNED CONTRACTS OR SOMETHING LIKE THAT.
BUT THEN IT ALSO TAKES TIME BEFORE THE PLANT IS EVEN BUILT.
[05:05:01]
EXCELLENT.SO DAN, FROM A RELIABILITY STANDPOINT, HOW DOES ORCO FEEL ABOUT A JUNE 20, 24 DATE, ASSUMING THAT WE GET THE LANGUAGE IN THERE THAT MAXIMIZES CAPABILITY? YEAH, SO I GUESS THE, THE DISTINCTION IS IF THEY, IF THEY WOULD, IN BOTH CASES, IT WOULD GET YOU TO THE POINT THAT YOU'RE TRYING TO MAXIMIZE CAPABILITY.
I THINK THE, THE DIFFERENCE WOULD BE THOSE 20 OR 30 GIGAWATTS IN THE MIDDLE, WHETHER THEY'RE, UM, THERE'S ACTUALLY ANY, UM, STICK THAT CAUSES THEM TO TRY TO MEET THAT REQUIREMENT.
SO THEY, THEY REALLY ARE WOULD, UH, UH, IF, IF IF YOU HAVE IT ON 6 23, THEN THEY WOULD BE NOT ONLY, UM, OBLIGATED TO MAXIMIZE UP TO THEIR EQUIPMENT CAPABILITY, BUT THEY'D ALL SO BE HELD TO COMPLIANCE TO THAT LEVEL AS OPPOSED TO IF, IF, IF YOU DO IT AT 6 24, THEN THEY'D PROBABLY BE AT THE SAME LEVEL.
THEY GET AN EXEMPTION IN THEIR UP TO THEIR EQUIPMENT CAPABILITY, BUT THEY'D ONLY BE HELD TO COMPLIANCE TO THE LEGACY REQUIREMENT.
AND SO THERE'S NOT AS MUCH INCENTIVE TO MAKE SURE THEY'RE REALLY MEETING THAT.
UM, I THINK THAT'S RIGHT, STEVEN.
IS THAT, AM I GETTING IT RIGHT? YEAH.
AND I THINK TO REALLY LOOK AT THE RELIABILITY IN ASPECTS YOU MAY WANT TO JUMP OVER TO SLIDE 41.
AND, AND SO, YOU KNOW, WE'RE NOT JUST MAKING THIS ARBITRARILY AND IN A VACUUM, RIGHT? WE HAVE 70 GIGAWATTS.
UH, THIS REPRESENTS ABOUT ANOTHER 22 COMING.
AND EVEN OUTSIDE OF THESE 22, THERE'S ANOTHER, IF YOU LOOK AT THE APPENDIX LATER, THERE'S A LOT COMING ON REALLY, REALLY FAST.
SO WE NEED TO ADAPT REALLY QUICKLY.
AND THERE'S, AS, AS BOTH SIDES HAVE ARGUED, THEY ARE CAPABLE.
97% ARE RATHER CAPABLE OF MEETING THE REQUIREMENTS OR AT LEAST GETTING VERY CLOSE.
WE'RE GONNA BE BASING OUR PLANNING ASSUMPTIONS.
WE'RE GONNA BE BASING OUR OPERATIONAL ASSUMPTIONS ON THE CAPABILITIES THAT THEY TELL US THEY HAVE.
AND SO IF THEY DON'T PERFORM, BUT TO A MUCH LOWER LEVEL, THAT CREATES A LARGE GAP IN WHAT WE ASSUMED WAS GONNA BE ON THE SYSTEM AND WHAT ISN'T.
SO WE SEE THAT AS A CONCERN, BUT HERE ARE JUST SOME BULLET POINTS.
AND I WANT TO, YOU KNOW, SINCE YOU MENTIONED, I KNOW ENCORE SUBMITTED COMMENTS ABOUT THE NEGATIVE SEQUENCE, CURRENT INJECTION EARLIER INTO THE PROCESS.
AND, YOU KNOW, I WOULD ASK BACK, DO Y'ALL SEE A CONCERN WITH, UH, MISS OPERATIONS OR THINGS THAT ARE OCCURRING RELATED TO THE NEGATIVE SEQUENCE CURRENT INJECTION FROM ENCORE? YEAH, WE HAD SUBMITTED THOSE COMMENTS BACK, YOU KNOW, OVER A YEAR AGO, UH, IN RESPONSE TO A COUPLE EVENTS THAT WE DID SEE ON THE SYSTEM.
YOU KNOW, NOT SIGNIFICANT EVENTS, BUT, YOU KNOW, PROTECTION SYSTEM TYPE ITEMS. AND IT, IT IS AN ISSUE THAT, THAT NEEDS TO BE ADDRESSED GOING FORWARD.
UM, WE, WE KIND OF PUT THAT PLACEHOLDER OUT THERE EARLY IN THE PROCESS, JUST KIND OF RECOGNIZING THAT THIS IS AN ISSUE AND IT'S NOT SOMETHING THAT'S CURRENTLY WAS IN NO 2 45 AT THAT TIME.
AND JUST TO KIND OF WAVE THAT FLAG THAT IT'S SOMETHING GOING FORWARD WOULD BE IMPORTANT TO ADDRESS.
AND I PRESUME THAT THOSE TYPE OF THINGS ARE THINGS THAT COULD BE ADDRESSED THROUGH SOFTWARE AND PARAMETER CHANGES AND MAXIMIZING CAPABILITIES, RIGHT? BUT THEY, IF IEEE 2,800 IS NOT THERE, THERE'S NO OTHER REQUIREMENT OR ANYTHING FOR THEM TO TRY TO COME INTO CONFORMITY WITH, TO SET UP THEIR CONTROLS TO BE ABLE TO PROVIDE THIS TYPE OF BENEFIT.
FOR UNBALANCED FAULTS, AND I DON'T WANT TO GO THROUGH THE ENTIRE LIST, BUT ON THE TRANSIENT OVERVOLTAGE RIGHT, THROUGH REQUIREMENTS, UM, WE HAVE A LOT OF LARGE LOADS COMING ON REALLY QUICKLY ONTO THE ERCOT SYSTEM.
UM, WHEN YOU CONSIDER THE TRANSITION WE'RE GOING INTO, AND THESE UNITS ARE RATHER CAPABLE, ONCE AGAIN, EVERYBODY AGREES TO THAT, WE HAVE AN ALLOWANCE FOR AN EXEMPTIONS.
WE'RE, WE'RE JUST HAVING A HARD TIME UNDERSTANDING WHY WE WOULD OPPOSE USING THIS CAPABILITY FOR ERCOT, WHO'S LEADING, WE'RE ON THE BLEEDING EDGE OF THINGS.
AND SO I ASKED TECH MEMBERS TO GIVE SOME TIME AND CONSIDERATION TO THIS SLIDE AND, AND LOOKING AT THE RISK IN MAKING THAT DETERMINATION, UM, BECAUSE WE THINK THIS IS IMPORTANT AND WE WANT IT TO BE VERY TRANSPARENT ABOUT IT SO THAT THE TAC MEMBERSHIP CAN MAKE AN EDUCATED DECISION.
UH, CHRIS HENDRICKS, OOPS, SORRY ABOUT THAT.
THE, UM, YEAH, ONE NED SAID MOST OF WHAT I WANTED TO SAY ABOUT THE DATE.
UH, THE ONE THING I WOULD ADD THERE IS, I MEAN, TYPICALLY THESE, WE'D LIKE TO THINK ABOUT IT AS WHEN THE BO, WHEN
[05:10:01]
THE PUC APPROVES IT NOW SINCE THE PUC HAS TO APPROVE THEM.AND SO FROM A TAX STANDPOINT, WHEN IN MY MIND WHEN WE WERE TALKING ABOUT THE DATE, IT WAS GIVEN ENOUGH TIME TO GET THROUGH THE WHOLE PROCESS AND THE, THE PUC TO APPROVE IT AND TRYING TO GET A DATE IN THERE WITHOUT SAYING LIKE, SOME OF THE OTHER JURISDICTIONS DUE SO MANY DAYS AFTER PUC APPROVAL.
AND SO THAT WAS WHY THE DATE CERTAIN WAS IN THERE.
AND THEN MY OTHER ONE WAS, IS JUST A GENERAL COMMENT SINCE IT'S NOW A LITTLE BIT AFTER THREE AND WE'VE BEEN GOING SINCE 1250 FROM THE ERCO SIDE FOR, YOU KNOW, A COUPLE OF HOURS OVER AND I THINK WE WERE ALLOCATED AN HOUR FOR THEIR PORTION OF THE AGENDA.
DOES IT MAKE SENSE TO MAYBE TRY TO SCHEDULE ANOTHER WORKSHOP BEFORE THE NEXT TECH MEETING? I'M WORRIED ABOUT WE'RE GONNA START LOSING A LOT OF PEOPLE ON A FRIDAY AFTERNOON AT THREE O'CLOCK.
BUT THE AGENDA HAD THE ADJOURNMENT AT TWO 30.
UM, WE'LL TALK ABOUT THAT HERE AND GET BACK HERE IN JUST A SECOND.
BUT I, I THINK WE'RE GETTING TOWARDS THE, THE END OF T'S PRESENTATION.
YOU GOT ONE MORE KEY ISSUE, DAN, WE'LL GET BACK ON THE TIMEFRAME.
SO THIS ONE'S ACTUALLY KIND OF A, UM, IT SEEMS LIKE A SMALL ISSUE, BUT IT'S NOT REALLY, IT'S, IT'S, THERE IS A DISTINCTION BETWEEN THE RIDE THROUGH CURVES FOR, UH, NEW IBR BETWEEN, UM, THE IEE 2,800 AND, AND OUR CURRENT REQUIREMENTS.
AND SO TO, BECAUSE OF THE, BECAUSE OF FIGURE 1 0 9, WE'RE, WE'VE GOT A PROCESS FOR CHECKING THESE THINGS AND WE'D LIKE IT TO BE CONSISTENT BETWEEN THOSE TWO.
I THINK THAT'S THE BEST WAY TO SAY IT.
UM, AND AND WHAT IT WOULD REALLY BE DOING IS LOWERING THE REQUIREMENT UNDER THE, UM, THE, THE PROPOSED TAC VERSION AS OPPOSED TO MAKING IT CONSISTENT ACROSS ALL OF THEM.
SO IT'S KIND OF A SMALL THING, BUT, BUT WE'D REALLY LIKE TO FIX THAT.
I CAN JUST MENTION SOMETHING REAL QUICKLY.
I THINK WE SAID IN OUR COMMENTS WE'D EVALUATE THIS.
UM, THIS IS THE REQUIREMENT THAT'S IN NOGA 2,800 IS BASED ON WHAT'S AN IEE 2,800.
AND SO THE, THE KEY QUESTION IS, ARE THE OEMS DESIGNING TO IEE 2,800? AND IF SO, THIS COULD JUST CREATE A COMPLIANCE RISK.
UM, SO, BUT WE'RE HAPPY TO TALK THROUGH THOSE DETAILS.
WE, WE UNDERSTAND WHY YOU'RE ASKING FOR IT AND OKAY.
I'M NOT GONNA GO THROUGH THE REST OF THIS AND YOU'VE ASKED ENOUGH QUESTIONS.
[8. Joint Commenters Presentation]
GONNA GO AHEAD AND GIVE JOINT COMMENTERS SOME TIME TO RUN THROUGH THEIR CONTENT.ERIC PROMISES IT WON'T BE SUPER EXTENDED 'CAUSE HE DIDN'T WANT PEOPLE TO BE MAD AT HIM.
AT THE END OF THE DAY ON A FRIDAY.
COLIN, I JUST WANNA SAY ONE THING REAL QUICK WHILE HE'S GETTING READY.
UH, I WANNA THANK ERCOT FOR PUTTING THIS TOGETHER AND COMING THROUGH AND TRYING TO DRIVE US TO A, TO A GOOD ANSWER FOR A LITTLE HUMOR ON IT.
I, I TELL YOU, I DON'T KNOW WHO WROTE THE QUESTIONS THAT WERE IN RED ON THE, UH, THE SLIDE DECK AND EVERYTHING, BUT WHOEVER IT WAS DID A FABULOUS JOB OF LAWYERING THAT THING TO WHERE IT LED YOU TO ONLY ONE ANSWER THAT WOULD BE ERCOT.
THE ONLY ONE HUMOROUSLY THAT WAS MISSING WAS TACK, WHEN DID YOU QUIT BEATING YOUR DOG?
SO WHOEVER EVER DID THAT, DID A REALLY GOOD JOB AT WHAT THEY WERE DOING.
UM, WE DON'T WANT, UM, THE LONG DAY TO CAUSE YOU TO, UH, NOT, UM, PAY AS MUCH ATTENTION TO THIS AS, AS PRE PREVIOUS THINGS.
AND SO WE MAY BENEFIT FROM ADDITIONAL DISCUSSION AND WE'RE HAPPY TO SCHEDULE MORE TIME TO DO THAT.
UM, BUT I DID THINK IT WAS IMPORTANT TO GET THROUGH SOME KEY POINTS AND, UM, IF TAC WANTS TO, WE CAN HAVE, YOU KNOW, AN ONLINE EXTENSION OF THIS WORKSHOP.
UM, ALSO SOME OF THE SLIDES IN HERE ARE THINGS THAT WE'VE COVERED, UM, ALREADY IN THIS CONVERSATION.
JOHN, JUST POINT THAT OUT SO YOU CAN SEE OUR PERSPECTIVE AND SOME OF THE TAKES WE'VE HAD SO FAR.
AS ALWAYS, YOU KNOW, PLEASE INTERRUPT ME WITH QUESTIONS OR COMMENTS.
[05:15:01]
SO HERE ARE THE JOINT COMMENTERS.UM, I THINK OUR GOALS FOR THE DAY ARE PRETTY CLEAR, BUT WE WANT TO RECAP WHAT IS IN THE TAC REPORT, RESPOND TO QUESTIONS AND CONCERNS, AND TRY TO IDENTIFY THE ACTUAL RISK THAT, UM, IS REMAINING AFTER THE THE TAC REPORT.
UH, WE THINK THIS IS WHAT WE HEARD FROM A LOT OF PEOPLE AS TO WHY THEY VOTED YES ON THE TAC REPORT.
UM, YOU WERE MEMBERS THAT, THAT VOTED.
SO I, I DON'T HAVE TO REMIND YOU OF THIS, BUT JUST WANTED TO TO STATE IT.
UM, HERE ARE THE CITATIONS TO SECTIONS THAT INCREASE RELIABILITY WITHOUT, UH, REQUIRING UNREASONABLE PHYSICAL MODIFICATIONS.
UM, SO YOU'RE, WE'RE GOING BEYOND, AS YOU'VE SAID, UH, FOR QUARTER 9 0 1 AND, AND WE SHOULD ACKNOWLEDGE THAT.
AND, AND, UH, MOVING ON, UM, THIS SLIDE HERE.
KATHY, DO YOU, DO YOU THINK ANYTHING WE SHOULD COVER IN THIS SLIDE? NO.
UM, EXISTING IBR HAVE TO MAKE SOFTWARE MODIFICATIONS.
SO HERE'S SOME QUESTIONS THAT PEOPLE MIGHT HAVE ABOUT WHAT'S IN THE TAC REPORT.
I'M HAPPY TO ADDRESS ANY OF THESE AND PAUSE FOR A FEW SECONDS TO SEE IF ANYONE WANTS TO TALK ABOUT ANY ONE OF THESE THINGS.
HEY, YEAH, JUST, JUST REAL BRIEFLY, SO EX EXISTING IRS MUST MAKE SOFTWARE MODIFICATIONS TO MAXIMIZE YEP.
WHAT IS THE INTENT? SO THE, TO WHAT STANDARD THAT'S THE YEP.
UH, IT, THE LANGUAGE HAS TWO LEGACY AND WE SAID EARLIER TODAY WE WOULD TALK ABOUT HOW ELSE WE CAN FIND MAXIMIZATION.
UM, WE THINK THIS IS REALLY IMPORTANT, UM, OR ABOUT THE, THE PROCESS FOR EXEMPTIONS, BUT WE TALKED ABOUT THIS ALREADY IN RESPONSE PREVIOUSLY, SO I'M JUST GONNA PAUSE FOR A FEW SECONDS AGAIN.
SO, UM, IBR WILL HAVE TO IDENTIFY, EVALUATE, AND DEPLOY.
UM, WE MUST SUBSTANTIATE OUR CLAIMS AND ER WILL RECEIVE ANNUAL REPORTS FROM EVERYBODY.
SO YOU CAN SEE WHAT'S CHANGED OVER TIME.
STEVEN, I SEE YOUR HAND OR YOUR QUEUE.
YEAH, A A COUPLE OF TIMES AND I JUST WANTED TO VET THIS OUT 'CAUSE I'VE HEARD A COUPLE TIMES WHERE WE'VE KIND OF ASKED DO, UH, DO YOU ALL BELIEVE IS TAC THAT THE TAC APPROVED VERSION ALLOWS ERCOT TO ASSESS RELIABILITY RISK? AND THEN I HEAR THE RESPONSE SAY, YES, WE, WE ALLOW ERCOT TO ASSESS WHETHER OR NOT COMMERCIALLY REASONABLE UPGRADES HAVE BEEN MADE.
SO I HEAR A YES, BUT THEN I HEAR DIFFERENT TERMINOLOGY USED.
SO I WANT TO BE CLEAR, WE DON'T CURRENTLY SEE WHERE THE TAC APPROVED VERSION ALLOWS US TO DENY IF THE RELIABILITY RISK ASSESSMENT SAYS IT'S UNRELIABLE.
DO Y'ALL BELIEVE THAT YOUR VERSION DOES THAT? KATHY, DO YOU WANNA TAKE THIS FIRST? SURE.
UM, IN THE LIST OF WHAT SHOULD BE CONSIDERED WHEN EVALUATING COMMERCIALLY REASONABLE RELIABILITY IMPACTS ARE KEY, RIGHT? WE CAN LOOK AT A, AT A LARGE COST AND A TINY RELIABILITY INCREASE OR A SMALL COST AND A BIG RELIABILITY INCREASE.
AND THAT, THAT WOULD WEIGH HEAVILY IN THE CONSIDERATION OF COMMERCIALLY REASONABLE.
I THINK THE OTHER FACTOR THAT I THINK I'M HEARING YOU SAY IS THAT BESIDES WHAT MAY OR MAY NOT BE COMMERCIALLY REASONABLE, WE HAVE CONCERNS THAT FOR EXISTING FACILITIES THAT HAVE ARE OPERATING TODAY, IT SOUNDS LIKE ERCOT WANTS ANOTHER STANDARD OF RELIABILITY.
EVEN THOUGH WE'RE COMPLYING WITH EXISTING STANDARDS AND THE EXEMPTIONS ARE TO TO COVER BETWEEN EXISTING AND 2,800, WE NEED AN EXEMPTION.
'CAUSE WE CAN'T GET TO WHATEVER THE NEXT LEVEL STANDARD IS.
AND THERE'S NOTHING ELSE COMMERCIALLY REASONABLE OR EVEN TECHNICALLY FEASIBLE TO DO.
I THINK WHAT ERCOT SLIDE SAID IS, BASED ON RELIABILITY CONCERNS, THEY WOULDN'T BE ABLE TO DENY THAT EXEMPTION REGARDLESS.
AND KATHY, HERE'S THE CITATION WHERE THE, UH, TAC REPORT DOES CONSIDER THE IMPROVEMENTS.
SO LAST LINE SITES ENT FOR WHETHER THE IMPROVEMENT WOULD MATERIAL ENHANCE ITS RIGHTS OF CAPABILITIES AS A CONSIDERATION OF THE COMMERCIAL REASONABILITY ASSESSMENT.
SO I I THINK I, I APPRECIATE THE RESPONSE.
'CAUSE IT TENDS TO CLARIFY WHEN Y'ALL TALK ABOUT A RELIABILITY ASSESSMENT, YOU'RE TALKING ABOUT WITHIN YOUR OWN PLANT,
[05:20:01]
AND I THINK ERCOT IS SPEAKING ABOUT A RELIABILITY ASSESSMENT ON THE ERCOT SYSTEM, WHICH IS WHAT WE'RE RESPONSIBLE FOR.AND SO, UH, RISK ASSESSMENT AT YOUR OWN PLANT IS NOT THE SAME THING IN ERCOT VIEW AS A RISK ASSESSMENT OF THE SYSTEM.
AND I THINK THAT MAY BE THE POINT OF CONFUSION THAT MAY BE OCCURRING THAT HOPEFULLY THAT CLARIFIES FOR TAC YEAH.
YEAH, I THINK IF WE, AND I THINK WE CAN TAKE A LOOK AT THAT, BUT THE, BUT THIS RELIABILITY ASSESSMENT FOR A COMMERCIALLY REASONABLE DETERMINATION WHEN IT'S NOT LIMITED TO JUST THE PLANT, IT'S JUST TO LOOK AT WHAT THE OVERALL RELIABILITY INCREASE WOULD BE FROM WHATEVER CHANGE IS BEING CONSIDERED.
SO HOW ARE YOU IF YOU DON'T HAVE THE MODELS FOR THE SYSTEM, IF YOU DON'T HAVE THE REST OF THAT TO BE ABLE TO ASSESS HOW ARE YOU ASSESSING BEYOND THE, THE PLAN? I'M NOT SAYING THAT WE CAN ASSESS BEYOND THE PLAN, BUT WE CAN GIVE YOU EVERYTHING WE HAVE.
AND THEN IT'S ERCO T'S ROLE IN THE LANGUAGE IS TAC APPROVED TO EXERCISE YOUR REASONABLE SATISFACTION OF WHETHER OR NOT THE RELIABILITY IMPACTS ARE PROPERLY CONSIDERED.
SO THAT LANGUAGE THAT YOU JUST SAID ABOUT THE RELIABILITY IMPACTS ON THE SYSTEM IS NOT THERE TODAY.
AND I THINK THAT'S THE KEY POINT THAT WE WANT TO MAKE SURE TAC MEMBERS HERE IS ERCOT NEEDS THE ABILITY TO ASSESS THE RELIABILITY IMPACT ON THE ERCOT SYSTEM.
AND WE ARE THE ENTITY THAT HAS THE MODELS, THAT HAS THE INFORMATION, THE TOOLS AND THE PROCESSES TO DO THAT.
AND SO OUR OBLIGATION UNDER NOGA 2 45 IS TO INCREASE OUR RIDE THROUGH REQUIREMENTS.
SO THAT'S A GOOD REASON TO LOOK AT WHETHER OR NOT THE IMPROVEMENT INCREASES OUR RIDE THROUGH REQUIREMENTS.
I THINK MAYBE TECH MEMBERS COULD LOOK AT THAT PARAGRAPH TWO 11 ER'S NOT IN THAT PARAGRAPH.
IT'S, THEY'RE NOT, WE'RE NOT IN IT AT ALL.
SO THERE MAY BE, I MEAN, IF THE INTENT IS THE SAME, MAYBE JUST A SIMPLE INCLUSION OF WHAT WE JUST TALKED ABOUT, AN OVERALL SYSTEM RELIABILITY SENTENCE IN THAT TWO 11 PARAGRAPH WOULD SOLVE ALL OF THIS.
AND AS I SAID EARLIER, UM, WE'RE HAPPY TO TALK ABOUT THAT, BUT AT THIS POINT IT'S NOT CLEAR TO ME HOW THAT CAN BE A, A STANDARDIZED EVALUATION.
SO FOR TAC I THINK THAT IS A, A REALLY STICKY STICKING POINT AT THIS POINT.
SO YOU MIGHT REMEMBER THIS LIST, UH, FROM THE, THE PRESENTATION THAT WAS GIVEN TO THE RMC.
UM, SO WE WANTED TO POINT OUT HERE, UM, THAT OF THESE FOUR, FOUR WERE NERC REPORTABLE EVENTS.
UM, AND MANY OF THESE WERE, UM, AS WE NOTE IN THE NERC, UH, QUOTE HERE ON SOLAR PV RESOURCES THAT CAN BE ADDRESSED TO SOFTWARE AND SETTING CHANGES.
AND WE TOOK THIS INFORMATION AND PRESENTED IT IN A DIFFERENT WAY TO SHOW THAT, UH, THIS LONG HISTORY THAT'S PRESENTED IN MANY CASES, THESE ARE RELATIVELY SMALL EVENTS UNDER 500 MEGAWATTS GENERALLY, BUT NOT ALWAYS.
UM, AND WE DON'T SEE IT, UH, NECESSARILY A LARGE INCREASINGLY RISK OVER TIME EXCEPT FOR THE TWO OUTLIERS WITH SOLAR FOR OD DESCENT, ONE AND TWO THAT HAVE BEEN ADDRESSED, UH, THROUGH MANY OF THE CHANGES WE'VE TALKED ABOUT ALREADY.
SO, UM, WE WOULD CONTEND THAT YES, THERE'S RISK IN THE SYSTEM, BUT THEY'RE BEING, THEY'RE BEING ADDRESSED AND NOGA 2 45 HELPS TO MAKE SURE THAT THEY'RE FURTHER ADDRESSED.
JUST TO GIVE EVERYBODY SOME QUICK CONTEXT.
BACK IN 2019 WHEN YOU SEE THAT REAL HIGH CONCENTRATION, WE DID MEET WITH, UH, WIND DEVELOPERS, UH, THO THOSE WERE HAPPENING PRIMARILY IN SOUTH TEXAS AND THEY MADE SOME ADJUSTMENTS THERE.
UH, THEY WERE WILLING TO LOOK AT THEIR MAINTENANCE PRACTICES AND THAT THAT WAS, UH, SOME LEVEL OF EFFORT THAT WAS MADE.
BY AND LARGE, MOST OF THE WIND EVENTS, UM, IN THE OLDER TIMEFRAME DIDN'T HAVE DISTURBANCE MONITORING EQUIPMENT TO BE ABLE TO PROPERLY DIAGNOSE A LOT OF, UH, RESPONSES CAME BACK AND SAID, WE'RE EXEMPT.
WE'RE NOT GOING TO DO ANYTHING.
AND SO THERE IS QUITE A BIT OF UNMITIGATED RISK THAT EXISTS ON THE SYSTEM.
AND I BELIEVE NERC IS, IS ACTUALLY PREPARING A, A REPORT THAT'S GONNA BE GOING OUT SHORTLY ABOUT A LOT OF THESE WIND EVENTS.
AND SO AS, AS WE CONSIDER THOSE THINGS, ALSO REMEMBER THE TIMING OF THOSE EVENTS MATTERS.
SO IF THE WIND'S BLOWING HIGH, YOU MAY HAVE A COMPLETELY DIFFERENT VALUE.
AND I THINK ONE OTHER ASPECT, IF YOU LOOK AT THE APPENDIX AND ERCOT PRESENTATION WHERE WE GIVE SOME MORE STATISTICS ON THIS, UH, YOU'LL ALSO BE ABLE TO KIND OF DISTINGUISH, UH, SOME ADDITIONAL, YOU
[05:25:01]
KNOW, HOW MUCH COULD IT HAVE BEEN, UH, ON EACH OF THESE EVENTS AS YOU LOOK AT IT HOLISTICALLY.SO I APPRECIATE Y'ALL PUTTING THIS TOGETHER.
IT'S, IT'S YOUR CAR STILL UP, WOODY.
SO, UM, I'M HAPPY TO ANSWER ANY FOLLOW UP QUESTIONS, BUT I ENCOURAGE EVERYONE TO LOOK AT THIS AND THINK THROUGH, 'CAUSE WE'RE, WE'RE TRYING TO MAP OUT THE REMAINING RISK AND, UH, WE REALLY THINK WHAT THIS TELLS YOU IS THAT THERE HAS BEEN SOME LEVEL OF RISK AS THE WAYS IT'S EVEN BEEN PUT ON THE SYSTEM, BUT IT'S BEEN THERE FOR A WHILE AND THAT'S, IT'S JUST A COUNTING DAYS.
IT'S NOT TRYING TO MAKE A, A VALUE JUDGMENT NECESSARILY, ALTHOUGH OBVIOUSLY I'M MAKING A VALUE JUDGMENT IS YOUR BACK UP? YEAH.
JUST REAL QUICK TOO, THE, THE VOLUME HAS, HAS INCREASED, UH, KIND OF ALONG WITH THE LEVEL IBR PENETRATION.
SO THAT'S ANOTHER KEY ASPECT THAT YOU REALLY DON'T SEE ON THIS SLIDE IS AS THE NUMBER OF IBR INTERCONNECTING TO THE ERCOT SYSTEM HAVE INCREASED, SO HAVE THE FREQUENCY OF MAGNITUDE OF THESE EVENTS AS IT CONTINUES ON AND THE MITIGATION.
SO SPEAKING OF MITIGATION, HERE'S THE MODIFICATIONS.
WE WENT OVER THIS SLIDE PREVIOUSLY, SO I'M NOT GONNA GO OVER IT EXTENSIVELY HERE, BUT THIS IS FROM AN
UM, AND, UH, THIS SHOWING THAT THE ISSUES THAT CAME UP IN ODESSA ONE AND TWO, THERE ARE SOLUTIONS FOR NOGA 2 45 FIXES IT.
HMM, I'M SORRY, BUT NOT FULLY DEPLOYED.
NOT FULLY WHAT I SO NOT FULLY DEPLOYED.
I AGREE, BUT NOGA 2 45 WILL REQUIRE IT.
IT'S NOT FULLY DEPLOYED, BUT IF, IF WE PASS NOGA 2 45 AND SAYS YOU HAVE TO DEPLOY IT, THAT'S A GOOD THING.
RIGHT? SO, UM, HERE'S ANOTHER TAKE ON THE SAME THING.
UM, THIS IS THE SUM OF SEVERAL ER CAT REPORTS.
ODESSA WANTED US A TWO PANHANDLE AND THE NOVEMBER 23 OTHER REPORT.
UM, AND, UM, IT IS THINGS THAT, WELL, IT'S SELF SELF-EVIDENT STEVEN.
YEAH, I I JUST WANTED TO QUICKLY MENTION, WE, WE DIDN'T, WE RAN OUTTA TIME TODAY, BUT YOU KNOW, ERCOT DID ISSUE A MARKET NOTICE RECENTLY THAT, UH, PASSED THE BOARD DIRECTION.
UH, WE ISSUED THAT MARKET NOTICE.
AND IT GOES ALONG WITH, I THINK THE SLIDE THAT YOU'RE PRESENTING HERE, THAT THERE'S A LOT OF TREMENDOUS VALUE, UM, FOR THESE, UH, SOFTWARE'S, IMPLEMENTATIONS TO BE DONE UP TO THE EQUIPMENT CAPABILITY.
AND I THINK THIS ALSO FURTHER ILLUSTRATES THAT IF THIS IS CORRECT, THE AMOUNT OF EXEMPTIONS SHOULD BE RELATIVELY LOW.
UM, IF YOU'RE ABLE TO ADDRESS SO MUCH OF THIS WITH SOFTWARE.
UH, SO I'M JUST GONNA SAY WE'RE NOT GONNA TALK ABOUT THE MARKET NOTICE.
I DON'T WANNA HAVE A MUCH LONGER MEETING, BUT I APPRECIATE THAT YOU BROUGHT IT UP.
BILL, IS THIS PERCENTAGE OF, UH, IMPACTED MEGAWATTS? WHAT'S I'M A MEGAWATTS.
AND THEN THE BLUE PART FIX OR REQUIRED IF SOFTWARE OR COMMERCIALLY REASONABLE PHYSICAL MOD.
WHAT, WHAT IS THE REQUIRED IF SOFTWARE? YEP.
SO THIS IS, I, UH, IF SOFTWARE IS REQUIRED, UH, IF SOFTWARE'S AVAILABLE TO BE REQUIRED, BUT IT'S JUST NOT KNOWN WHAT THE FIX IS.
SO WE'RE SAYING TO THE EXTENDED SOFTWARE, NOGA 2 45 WOULD FIX IT, AND TO THE EXTENT THAT IT'S COMMERCIALLY REASONABLE HARDWARE, NOGA 2 45 WOULD FIX IT, BUT THE REPORT WASN'T ABLE TO IDENTIFY THE CAUSE AT THE TIME THE REPORT WAS WRITTEN ALL.
SO, SO THE GREEN IS A KNOWN, KNOWN, UH, RISK THAT CAN BE FIXED THROUGH SOFTWARE.
THE BLUE IS THE PHYSICAL MODIFICATIONS AND IF, AND IT'S NOT CLEAR IF THE SOFTWARE CAN FIX IT.
NO, I'M JUST, I'M CONFUSED AS THE SOFTWARE PART OF THE BLUE PIECE, WHY IT'S NOT IN THE GREEN, JUST BECAUSE IT'S NOT KNOWN IF IT'S SOFTWARE.
SO PERCENTAGE OF PAST RIDE THROUGH FAILURES THAT CAN BE FIXED.
AND WE TALKED ABOUT JUST 2 45 JUST NOW THAT, UH, WOULD REQUIRE FIXES.
WOULD ALL THOSE GREEN FALL, I MEAN, IF YOU WERE JUST GOING TO THE LEGACY REQUIREMENT, WOULD ALL THOSE GREEN BE APPLIED OR IS IT, HOW DOES THAT WORK? I'M, I'M UNCLEAR.
UM, I THINK GENERALLY IT WOULD BE REQUIRED, BUT WE ALREADY TALKED ABOUT HOW WE'RE WILLING TO TALK ABOUT LEGACY VERSUS SOMETHING ELSE EARLIER.
SO I DON'T HAVE A DIRECT ANSWER FOR YOU, BUT IT'S A GOOD QUESTION.
AND WE WE'RE TALKING ABOUT THE EXACT LEVEL THAT SOFTWARE WOULD BE REQUIRED TO AS PART OF THE POINT OF CONSENSUS.
BUT FROM A TAC ADDRESSING THE TAC VERSION YEP.
THAT'S SOMETHING TO KEEP IN MIND.
THAT ALL THAT GREEN MAY NOT BE, YOU MAY NOT GET ACCESS TO ALL THAT GREEN STUFF
[05:30:01]
WITH THE CURRENT T VERSION.UM, QUICK QUESTION, ERIC, DID I READ AT THE BOTTOM, UH, THAT THAT IS BASED ON THOSE FOUR EVENTS ONLY? YES.
SO IF WE CROSS REFERENCE THAT WITH YOUR OTHER SLIDE, WOULD THAT BE THE ONES THAT WERE LARGER AND NOT ALL THE SMALLER ONES BASICALLY? YEAH.
SO THIS IS JUST FROM THESE FOUR, FOUR EVENTS.
THOSE ARE THE ONES THAT WE SUMMARIZED? YES.
THERE WOULD BE THE ONES THAT YOU'RE, THAT YOU POINTED OUT.
SO YOU SEE THE, THE ONES THAT ARE LABELED HERE OKAY.
SO ALL THE OTHERS WOULD NOT BE IN THAT PARTICULAR ANALYSIS, IS THAT CORRECT? YES.
BUT THAT DOESN'T MEAN THAT IT'S NECESSARILY A DIFFERENT OUTCOME.
UH, NED, I SEE YOUR CARD'S UP.
YOU'RE CALLING ON YOUR OWN PEOPLE, ERIC, JUST TO CONFIRM.
UM, I DON'T WANT YOU TO FEEL LIKE YOU, YOU HAVE TO RUSH.
I WANTED TO MAKE A COUPLE OF COMMENTS.
YOU KNOW, I, I KNOW WE ARE OVER THE SUGGESTED TIME ON THE AGENDA, BUT LIKE, LIKE MANY OF OUR
SO WE CERTAINLY, LIKE EVERY OTHER AUP MEETING WILL NOT ADHERE EXACTLY TO THAT.
AND THE MAIN REASON FOR THAT IS NOT TO HAVE TO CUT PEOPLE OFF AT EXACTLY 30 MINUTES.
I DON'T WANT YOU TO HAVE TO FEEL LIKE YOU HAVE TO RUSH THROUGH CONTENT.
I'M, I'M NOT, I UNDERSTAND THAT, BUT I ALSO KNOW THAT PEOPLE HAVE HUMAN BRAINS.
WE DO HAVE TWO MORE EXTRA WORKSHOPS SCHEDULED BEFORE THE BOARD MEETING.
SO WE, WE HAVE A LOT MORE TIME TO DISCUSS THIS.
WE, UM, AND, YOU KNOW, IF, IF POSSIBLE MAYBE CUT DOWN A LITTLE BIT ON THE, THE BACK AND AND FORTH.
STEVEN
UM, SO, SO IF WE COULD FOCUS MAYBE ON THE QUESTIONS TAC HAVE HAS, BUT AGAIN, YOU KNOW, SUPER RELEVANT FOR, FOR ERCOT TO WEIGH IN WHERE WE MIGHT BE MISSING A PIECE OF INFORMATION.
SO CONTINUE TO DO THAT, BUT I, I THINK IF WE COULD FOCUS ON GETTING THE INFORMATION NEEDED TO THOSE WHO ARE STILL WITH US, NED, I ALWAYS GIVE THE BIG SPEECHES BEFORE NED, AND THEN HE HAS TO LIKE, SHEEPISH SHEEPISHLY GO BACK TO SOMETHING
WELL, ON THAT NOTE, I HAD, I HAD A QUESTION ON THE PRIOR SLIDE.
UM, AND IT, IT WAS WHAT WOODY HAD SAID THAT, UH, IT WAS A, AN INTERPRETING THE 90, SORRY, THE 85% OF SOFTWARE FIXABLE, UH, YEAH.
UM, ISSUES FROM PRIOR EVENTS IS NOT NECESSARILY BEING AVAILABLE UNDER THE TAC VERSION.
I WAS HOPING TO UNDERSTAND THAT A LITTLE BIT BETTER BECAUSE MY UNDERSTANDING IS THAT THE TAC APPROVED VERSION YEP.
REQUIRES, I THINK DAVE JUMPED IN THE QUEUE THAN WITHDREW FOR THIS VERY REASON.
SO DAVE, DO YOU WANNA JUMP IN? YES.
THE, THE ANSWER IS THE SOFTWARE FIXES ARE REQUIRED.
HOW, I THINK, I THINK ERCOT, OR SORRY, I THINK ERIC WAS TRYING TO, UM, ACCOUNT FOR THE FACT THAT THE TAC APPROVED VERSION DOES HAVE THAT, YOU KNOW, UH, MODIFICATIONS ARE REQUIRED UP TO THE LEGACY, RIGHT? THE NEW LEGACY REQUIREMENTS AS OPPOSED TO BEYOND.
BUT NO, THE SIMPLE ANSWER HERE IS THAT THESE SOFTWARE FIXES ARE REQUIRED.
SO HASHING OUT THE, THE DIFFERENT COMMENTS THEN, WOODY IS YOUR COMMENT THAT THE TECH VERSION DOESN'T REQUIRE THEM GOING TO THE MAXIMUM CAPABILITY? IT WAS JUST A QUESTION.
WHAT THIS IS INTENDED TO DO LARGELY IS TO DO TWO THINGS.
THE, THE PREVIOUS SLIDE HAS THE ODESSA, UM, THE DETAILS ON THE ODESSA DEPLOYMENT FROM ERCOT, UM, OWN PRESENTATION.
AND WE THOUGHT THAT WAS HELPFUL BECAUSE THEN YOU SEE THE FULL SCALE, RIGHT? FOR THOSE TWO REALLY LARGE EVENTS, THE FULL SCALE OF WHAT'S BEING DONE WHERE, AND YOU CAN SEE IT'S BOTH HAPPENING WITHIN THE SET OF PLANTS THAT WERE DIRECTLY PART OF THAT DISTURBANCE EVENT, AND THEN SIMILARLY SITUATED PLANTS OUTSIDE OF ODESSA ACROSS THE REST OF ERCOT, RIGHT? UM, BUT IT DOESN'T GIVE YOU A NICE GRAPHIC TO SAY, OKAY, BUT AT A HIGH LEVEL, WHAT FRACTION DOES THAT TAKE CARE OF IN TERMS OF THE ISSUES THAT WE'VE SEEN? AND THEN THE FOLLOWING SLIDE INCLUDES BOTH OF THOSE REPORTS, THE PIE CHART, SORRY, BOTH OF THE ODESSA REPORTS, PLUS THE TWO SMALLER WIND REPORTS.
AND YOU CAN SEE THE, YOU KNOW, THE, THE THEME THERE THAT, THAT WE'RE TALKING ABOUT LARGELY SOFTWARE FIXABLE ITEMS, MODIFICATIONS THAT WOULD BE REQUIRED, AND THEN THERE'S SOME UNCERTAINTY IN THAT BLUE SWATCH BECAUSE IT'S UNCLEAR WHAT THE FIX WOULD REQUIRE.
SO THAT'S THE, THAT'S SUPPOSED TO BE WHAT WE'RE DOING HERE.
WHAT WE'RE TRYING TO DO IS GET TO THE KEY QUESTION HERE, WHICH IS WHAT, WHAT IS THE RELIABILITY RISK THAT WE'RE TALKING ABOUT? AND HOW MUCH OF IT REALLY REMAINS? AND, AND SO WE'RE TRYING TO GIVE SOME PERSPECTIVE WITH THESE SLIDES TO HELP ANSWER THAT QUESTION IN A WAY THAT WE HOPE IS HELPFUL FOR TAC.
[05:35:01]
THANK YOU.AND SO JUST TO, SO THAT WE KNOW WHAT, WHAT WE'RE LOOKING AT THAT'S IN THE, THE NON-GREEN SECTION, SINCE BILL HAD ASKED THIS IS, YOU KNOW, A PERCENTAGE OF MEGAWATTS, UM, WHAT IS THE APPROXIMATE, UH, CAPACITY THAT WOULD, THAT'S REPRESENTED IN THE BLUE AND THE GRAY? WE CAN GO BACK AND CHECK THE SPREADSHEET, BUT THIS WAS THE, THERE COULD BE MULTIPLE, UM, MACHINES IN THE SAME REPORT, RIGHT? BECAUSE IT'S THE SUM OF THREE REPORTS THAT MIGHT HAVE, SO WE'D HAVE TO GO BACK AND JUST, AND NET OUT DUPLICATES.
ERIC? UH, WHEN I'M READING, UH, THIS PAGE 12 YEP.
I'M SEEING, I'M SEEING THAT, UH, LIKE 85% IS JUST LIKE A SOFTWARE FIXABLE.
SO CAN YOU, CAN YOU ELABORATE A LITTLE BIT MORE, UH, ABOUT THE SOFTWARE? FIXABLE MEANS? I MEAN, WE, WE TALK ALL DAY ABOUT, UH, ALL OTHER OPTION, BUT, UH, IT LOOKS LIKE TO ME FROM THIS CHART, RIGHT, IS MOST OF THE PROBLEM JUST LIKE A SOFTWARE FIXABLE.
SO CAN YOU GO A LITTLE BIT DETAIL WHAT DOES IT LOOK LIKE EXACTLY? YEAH.
WHEN YOU SAY, WHEN YOU SAY SOFTWARE FIXABLE, DO WE NEED, UH, ANY OTHER EQUIPMENT IN THERE OR JUST A SOFTWARE WORKS, OR HOW DOES IT WORKS? JUST THE SOFTWARE.
IT'S A SOFTWARE OR, OR A FIRMWARE OR A SETTINGS CHANGE AND, AND ALL THAT CAN BE DONE WITHOUT MODIFYING THE EQUIPMENT AND IS REQUIRED TO BUY THE TAC REPORT.
UM, SO, SO ONE MORE, ONE MORE THING.
SO MY QUESTION TO
SO WE'RE, WE'RE TRYING TO, UM, WE AGREE THAT SOFTWARE AND PARAMETERIZATION IS GOING TO ADDRESS A MAJORITY OF THE SYSTEM ISSUES THAT WE HAVE SEEN, BUT THE LEFTOVER AMOUNT, NINE, SIX, 15%, UH, WE NEED AN ASSESSMENT TO VERIFY THAT THE SYSTEM CAN STILL WITHSTAND WHATEVER IS THE REMAINING RISK.
UH, SO WE'D LIKE TO MOVE FORWARD, UH, WITH THE SOFTWARE IMPLEMENTATION GETTING DONE AS SOON AS POSSIBLE.
UM, BUT WE NEED A SYSTEM ASSESSMENT WITH MODELS TO MAKE SURE THAT THE, THE SYSTEM WILL BE OKAY WITH WHAT IS, UH, LEFT OVER, WHAT'S EXEMPTED.
IF, IF YOU LOOK AT, THANK YOU SO MUCH, I'M SORRY.
IF YOU LOOK AT 15% OF JUST 70 GIGAWATTS, UH, YOU'RE DEALING WITH 10 GIGAWATTS, 10 GIGAWATTS, UH, INSTANTANEOUS.
YOU CAN LOOK AT OUR APPENDIX SLIDE AND JUST KIND OF SEE WHAT THAT MIGHT DO.
AND, YOU KNOW, THAT'S A WORST CASE, BUT WE NEED TO ASSESS IF THE SYSTEM CAN HANDLE THAT.
I'M GONNA KEEP MOVING, BUT NOT IN A WAY THAT'S SUPER RUSHED, BUT JUST RIGHT ON TIMING.
A VERY COMFORTABLE, INFORMATIVE, YES.
UM, SO HERE IS AN ATTEMPT TO LOOK AT THE MEGAWATT ADDITIONS, UH, IN DIFFERENT TIMEFRAMES, WHAT THEY, WHAT THEY'RE SUBJECT TO, UM, AND, UM, AND WHAT EXEMPTIONS MIGHT BE REQUIRED.
SO I'M JUST GONNA GIVE PEOPLE A CHANCE TO TAKE A LOOK AT THIS, SEE IF ANY QUESTIONS ABOUT IT.
[05:40:02]
WE GENERALLY KNOW WHAT EXEMPTIONS ARE NEEDED.THERE'S UNCERTAINTY ABOUT, UH, WHETHER THE NEW SPECIFICITY EXISTS.
DOES NOT MEAN THAT YOU'LL GET THE EXEMPTIONS BECAUSE YOU HAVE TO KNOW WHAT THE ISSUE IS TO GET THE EXEMPTION.
SO, UM, THIS GOES THROUGH, UM, A, A TAKE AT THE RFI, UM, AND WE THINK THAT THIS, AS WE SAY HERE IN THIS FIRST BULLET OVER HERE, THAT THE REQUIRED MODIFICATIONS WILL YIELD THE MOST BENEFIT WITH EXEMPTIONS WERE NEEDED.
UM, THERE IS UNCERTAINTY, UM, AROUND THE SPECIFICITY AS
UM, AND THERE'S UNKNOWNS ABOUT BE WHETHER THINGS CAN DO, BECAUSE MANY IIV DON'T MONITOR FOR THOSE ISSUES, OR THE OEMS AND RES DON'T HAVE DATA ON THOSE LIMITATIONS.
SO THE POINT OF THAT IS YOU HAVE TO HAVE A KNOWN ISSUE IN ORDER TO REQUEST AN EXEMPTION.
I THINK THE KEY POINT OF DISAGREEMENT IS ERCOT MIGHT WANT TO NEVER GRANT AN EXEMPTION.
AND FROM OUR PERSPECTIVE, WE'LL GO THROUGH THAT ACTIONS AFTER AN APPARENT RIDE THROUGH FAILURE SECTION.
IF SOMETHING ACTUALLY DOES OCCUR, WE'LL HAVE TO MODEL IT AND THEN POTENTIALLY GET AN EXEMPTION TO THAT LEVEL IF SOMETHING DOES OCCUR.
BUT IF IT'S SOMETHING THAT IS UNKNOWN, THAT MAY NEVER OCCUR, IT MAY NEVER OCCUR.
AND WE DON'T WANT TO TRAP US INTO HAVING TO DEAL WITH THAT AND NOT GET AN EXEMPTION IF IT'S SOMETHING THAT WE DON'T KNOW ABOUT.
DOES THAT MAKE SENSE? I, I DON'T UNDERSTAND THAT.
IN, IN A SCENARIO WHERE EVERYBODY'S GONNA A LEGACY ASSET YES.
SUBMITS A, AN EXEMPTION AND WE EVALUATE IT AND LET'S JUST SAY WE, WE GRANT THE EXEMPTION YEP.
AND THEN SOMETHING UNKNOWN HAPPENS A YEAR LATER.
WALK US THROUGH THAT BECAUSE I DON'T THINK WE UNDERSTAND THIS CONCEPT OF UNKNOWN HAPPENING A YEAR AFTER.
WE'RE WORKING WITH THE OEM, UNDERSTANDING YOUR EQUIPMENT CAPABILITY AND YOUR PLANT, AND YOU'VE SUBMITTED EVERYTHING TO ERCOT TO EVALUATE.
I'VE GOT ANOTHER SLIDE ON THAT.
UM, SO HERE'S THE, UM, OBLIGATION TO MITIGATE, UM, AFTER PERFORMANCE FAILURE.
UM, SO IF IT'S A NEW SGIA UM HUH WE'RE GOOD.
SO ON THE EXISTING ONES IS WHERE IT COMES IN.
SO YOU HAVE TO INVESTIGATE THE EVENT, REPORT THE COST TO ERCOT AND PERFORM MODEL VALIDATION, AND IT'S SUBJECT TO INVESTIGATION BUSINESS ENFORCEMENT, RIGHT? AND THEN, UM, YOU ALSO HAVE TO MITIGATE AND DEPLOY ANY AVAILABLE SOFTWARE AND COMMERCIAL REASONABLE HARDWARE EXCEPTIONS BASED ON THE THING THAT HAPPENED.
UM, SO THE EXEMPTION COMES IN IF THERE'S A KNOWN ISSUE, BUT IT'S NOT COMMERCIALLY REASONABLE TO SOLVE IT.
SO LET'S SAY IT CAN'T MONITOR RATE CHANGE OF FREQUENCY AT THE LEVEL THAT WE WE'VE GOTTEN TO.
AND YOU CAN'T MONITOR IT UNLESS YOU DO A EXPENSIVE HARDWARE UPDATE.
THERE'S AN EXEMPTION THAT'S GRANTED TO THAT ISSUE THAT, THAT WE DIDN'T KNOW ABOUT BEFORE BECAUSE THE OEM JUST DIDN'T KNOW IF THE EQUIPMENT COULD DO THAT BECAUSE OF THE VINTAGE THAT IT WAS DONE AT.
BUT ONCE THE EVENT OCCURS, WE WOULD LEARN ABOUT IT, AND THEN YOU COULD TAKE WHATEVER ACTIONS YOU NEED TO THE TRANSMISSION SYSTEM LIKE WE TALKED ABOUT EARLIER.
UM, BUT UM, WE WOULD HAVE TO UPDATE AND DOCUMENT IT.
AND IF IT'S COMMERCIALLY REASONABLE TO FIX IT, WE'D HAVE TO FIX IT.
I STILL DON'T UNDERSTAND THIS.
THIS COMES BACK TO THE RELATIONSHIP WITH THE, THE RESOURCE IN THE KNEE AND THE OEM MM-HMM.
AND SO, AND WE TALKED A LOT ABOUT THIS MORNING.
HOW DO YOU SOLVE THAT GAP SO THAT ERCOT CAN GET THE ACCURATE MODEL AT THE TIME THAT YOU'RE SUBMITTING THE EXEMPTION REQUEST? SO, UH, DAVE HAS TEXTED ME THAT HE HAS AN ANSWER HE'D LIKE TO GIVE THANKS, ERIC.
I THINK THE PRACTICAL CONSIDERATION AGAIN, THAT WE'RE TALKING ABOUT HERE IS IF YOU'VE GOT, YOU KNOW, GE AND A TURBINE FROM 2008, OLD MODELS ARE GONNA HAVE OLD MODELS OF EQUIPMENT WITH, YOU KNOW, SUB COMPONENTS THAT THEY DIDN'T MODEL A MULTIPLE EXCURSION, YOU KNOW, EVENT AT THE TIME THAT THEY DESIGNED IT, AND THEY DON'T HAVE A TEST BENCH TO TEST IT, AND THEY'VE GOT OTHER MODELS IN FRONT OF IT WHERE THEY'RE GOING TO BE WORKING KIND OF FEVERISHLY TO ANSWER THESE QUESTIONS FOR EXEMPTIONS FOR NEWER EQUIPMENT AND THEN WORK THEIR WAY BACK.
UM, I THINK THAT'S, THAT'S THE PRACTICAL ISSUE HERE WHERE THEY MAY NOT KNOW WHERE THE, THAT THERE'S A UNDERLYING PHYSICAL LIMITATION.
AND I THINK THE TWO, AGAIN, LIKE IF WE THINK AT THE
[05:45:01]
MARKET LEVEL, THAT SHOULDN'T BE SOME BIG WIDESPREAD THING.THESE ARE ALL GENERATORS HAVE BEEN OPERATING FOR YEARS IN, IN ERCOT.
AND FROM A LIKE, MOTIVATION OF THE RESOURCE, WHAT WE'RE TRYING TO SHOW HERE IS WE'RE TAKING THE RISK, RIGHT? WE SAY, WELL, WE DON'T KNOW WHAT THAT, UM, IF THERE'S THIS UNDERLYING PHYSICAL LIMITATION, WE KNOW THAT WE'RE NOT ACTIVELY MONITORING THE TRIP ON THIS THING, WE CAN SAY THAT MUCH.
AND THEN
THAT'S JUST THE NATURE OF THE AGE OF SOME OF THE EQUIPMENT WE'RE DEALING WITH.
THEN IN THAT CASE, IF WE WERE TO TRIP AND HAVE A PERFORMANCE FAILURE, WE'RE SUBJECT TO A COMPLIANCE ACTION.
ALL WE'RE TRYING TO SAY IS IF THAT WERE TO HAPPEN AND THEN WE DISCOVERED A PREEXISTING BUT PREVIOUSLY UNIDENTIFIED LIMITATION AS A CONSEQUENCE, THEN IT WOULD RUN THROUGH THE SAME ANALYSIS THAT WE WOULD'VE DONE IF WE HAD ALL THAT INFORMATION IN FEBRUARY.
BUT WE'RE CERTAINLY MOTIVATED TO DO EVERYTHING WE CAN TO IDENTIFY THAT AS FAST AS POSSIBLE, BECAUSE WE DON'T WANNA BE IN A COMPLIANCE SITUATION.
SO AGAIN, LIKE IN THE AGGREGATE, THAT SHOULDN'T BE THIS MAJOR, UH, ISSUE, BUT AT THE PROJECT LEVEL IT'S POSSIBLE THAT THAT WOULD POP UP.
SO, SO, SO TWO, TWO LIKE HEADLINES FROM THAT.
ONE IS THE AGE OF THE EQUIPMENT.
UM, WE, WE'VE BEEN OPERATING FOR YEARS WITHOUT, YOU KNOW, SIGNIFICANT ISSUES.
UM, THERE ARE UNKNOWN UNKNOWNS THAT WE'VE LEARNED ABOUT, UM, MIGHT EXIST OVER THE LAST COUPLE OF YEARS OF INTENSIVE LOOK AT THIS ISSUE.
AND WE JUST, ONE OF THE THINGS WE KNOW IS THAT THE OEM DIDN'T, UH, HAVE A SYSTEM THAT MONITORS THAT SPECIFIC THING.
AND SO IT MIGHT BE ABLE TO DO IT, IT MIGHT NOT, HOPEFULLY IT'LL EVER HAPPEN, BUT IF IT DOES, WE WANTED TO CREATE A, A PATHWAY TO ADDRESS IT.
SO IS THIS SOMETHING THAT WE NEED THE OEMS TO WEIGH IN ON? BUT BECAUSE WHERE I'M STRUGGLING WITH IS THE RESOURCE THAT NEEDS SUBMITTING IN THE MODEL TO ERCOT IS STILL ESSENTIALLY, BASED ON WHAT DAVID'S SAYING, HAS A LEVEL OF UNCERTAINTY AS FAR AS HIS EQUIPMENT CAPABILITY.
AND SO GOING BACK TO THIS MODEL ISSUE, EVEN THROUGH OUR EXEMPTION PROCESS, THAT WE'RE ALL WILLING TO AGREE THAT THERE SHOULD BE AN EXEMPTION PROCESS.
THE MODELS THAT WE'RE GONNA GET IN, YOU GUYS ARE ACKNOWLEDGING THAT THEY'RE LIKELY GONNA BE WRONG FOR OLDER, NOT NECESSARILY FOR OLDER VINTAGE UNITS.
IT'S PRACTICALLY, THAT'S WHAT DAVID JUST SAID.
WE, WE DON'T KNOW IF, IF IT COULD DO IT OR NOT, BECAUSE IT DOESN'T MONITOR FOR THAT.
SO, UH, AND UNFORTUNATELY, UH, A REPRESENTATIVE FROM GE WAS HERE FOR THE ENTIRE WORKSHOP AND HAD TO LEAVE, WATCH HIS FLIGHT.
UH, HE WAS AVAILABLE FOR THIS QUESTION.
WHY IS, DAVE, IS YOUR COMMENT NEW? YES, I'D LIKE A CHANCE TO RESPOND BECAUSE I THINK THAT THERE'S A LITTLE BIT OF A MISCONCEPTION HERE, SO I'D LIKE TO ADDRESS IT.
CHAD, DID YOU FINISH YOUR COMMENT OR QUESTION? YES.
THE EXAMPLES THAT I'M TALKING ABOUT ARE BY THEIR NATURE EXAMPLES THAT THERE, IT'S, THE EXAMPLE I GAVE IS A PHYSICAL LIMITATION, WHICH BY DEFINITION IS, IT'S THE TYPE OF LIMITATION THAT'S NOT GONNA BE CAPTURED IN THE ELECTRICAL MODELS WE'RE TALKING ABOUT.
AND THAT'S, THAT'S SOMETHING THAT I, I THINK IS, THAT'S JUST THE NATURE OF THE EXTENT TO WHICH SOMETHING CAN BE PLACED IN SOME OF THE MODELS THAT WE'RE TALKING ABOUT AND WHY SOME OF THE, UM, EXEMPTION REQUESTS WOULD HAVE TO INCLUDE OTHER ADDITIONAL INFORMATION IF IT CANNOT BE BY THE, AGAIN, BY ITS NATURE REFLECTED IN THE MODEL.
SO THIS ISN'T A QUESTION OF SUBMITTING A MODEL THAT'S INACCURATE, IT'S A MODEL THAT'S ACCURATE WITH EVERYTHING THAT THE MODEL'S ABLE TO CAPTURE.
BUT IF YOU HAVE A PHYSICAL LIMITATION THAT BY ITS NATURE CANNOT BE CAPTURED IN THE MODEL THAT MAY EXIST.
SO AGAIN, WE'RE TRYING TO DRAW THE DISTINCTION BETWEEN, THERE'S NO REASON TO THINK THAT THIS IS SOME BIG WIDESPREAD UNDERLYING ISSUE.
HOWEVER, FOR SPECIFIC GENERATORS, IT'S POSSIBLE THERE MIGHT BE, AND FOR THOSE GENERATORS WE'RE THE RESOURCE HERE IS TAKING THE COMPLIANCE RISK, IT JUST NEEDS A REASONABLE PATH IF IT DISCOVERS SOMETHING THAT WAS UNKNOWN BUT EXISTED PREVIOUSLY.
SO AGAIN, YOU'RE STARTING WITH WHATEVER CAPABILITY YOU HAVE IT THAT YOU CANNOT MODIFY YOUR GENERATOR TO MAKE THE CAPABILITY WORSE.
AND THEN YOU HAVE AN AFFIRMATIVE OBLIGATION TO DO WHAT YOU CAN TO IMPROVE IT.
RIGHT? SO THIS IS NOT SOME DOWNWARD SPIRAL THAT DOESN'T, THAT CONCEPT'S NOT IN HERE.
UM, BUT AGAIN, I'M JUST TRYING TO EXPLAIN BECAUSE THIS SEEMS LIKE THIS IS AN AREA THAT OF MISCONCEPTION AND I THINK IT, IT MAKES SENSE FOR US TO MAKE SURE THAT WE'RE BEING CLEAR ABOUT WHAT, WHAT THIS IS AND WHY IT EXISTS.
YEAH, I APPRECIATE THE RESPONSE.
I MEAN, I THINK THE, WHAT WE HEARD EARLIER TODAY, AT LEAST FAR AS FERC ORDER 9 0 1, THERE IS NOT THIS TYPE OF EXEMPTION UPON EXEMPTION PROCESS FOR LEGACY ASSETS.
[05:50:02]
BUT MAYBE THAT'S SOMETHING THAT THROUGH THE STANDARDS DEVELOPMENT PROCESS, Y'ALL ARE GONNA TRY TO WEIGH COMMENTS IN ON THAT AS WELL FOR THIS UNKNOWN LIMITATION ISSUE.BUT THAT'S ALSO, THEY ONLY REQUIRE NON-PHYSICAL MODIFICATIONS.
AND WHAT WE'RE TALKING ABOUT HERE IS PHYSICAL MODIFICATIONS.
SO IF WE'RE, IF IT'S IN REFERENCE TO 9 0 1, THIS ISSUE DOESN'T EXIST AND YOU'RE TALKING ABOUT SOFTWARE RELATED CHANGES, WHICH YOU HAVE TO MAKE, I'M HAPPY TO ANSWER ANY OF THE QUESTIONS ABOUT THIS.
AND THEN WHY DON'T WE TRY TO KEEP MOVING.
YEAH, I THINK JUST TO EDUCATE A LITTLE BIT ON THE FERC ORDER 9 0 1 AND THEN THE DRAFTING TEAM.
SO I WAS ON THE DRAFTING TEAM CALL YESTERDAY, AND AT LEAST RIGHT NOW PRC 29.
UM, THEY DON'T, IT'S A ONETIME JUST AS, UH, JULIA HAD PRESENTED, IT'S A ONETIME CAPTURE SIX MONTHS, AND THEN AFTER THAT THERE, THERE IS NO FURTHER EXEMPTION ON IT'S A DRAFT, BUT THAT'S WHERE THEY'RE AT.
UM, SO WE SHOWED, UH, THIS PREVIOUSLY BUT ADDED TO STAR HERE.
UM, I THINK WE TALKED ABOUT THIS EARLIER.
UM, BUT THIS IS BASED ON ERCOT REASONABLE SATISFACTION.
AND SO WE ALREADY, I THINK, HAD THIS CONVERSATION EARLIER BUT WANTED TO GOLD STAR THIS ONE.
UM, SO, UH, WANTED TO DROP IN THIS SLIDE AGAIN.
YOU SAW IT EARLIER, BUT WE THINK THESE ARE SOME OF THE REASONS WHY TAC MEMBERS, UH, VOTED IN FAVOR OF THE TAC REPORT.
I'M HAPPY TO TAKE ANY QUESTIONS.
I'VE ALSO GOT AN APPENDIX IF THERE ARE ANY OTHER QUESTIONS.
IF YOU'RE, YOU FEEL FINISHED FOR TODAY, I KNOW WE DIDN'T GET TO SOME OF YOUR CONTENT.
I KNOW WE DIDN'T GET TO SOME OF ERCOT CONTENT AS WELL.
UM, I THINK WE HAVE SOME AREAS OF CONSENSUS, UM, NOT LANGUAGE YET, BUT YOU KNOW, SOME CONSENSUS AROUND SOFTWARE, UM, THAT WOULD MAXIMIZE CAPABILITY, NOT JUST REQUIREMENTS, BUT WE WOULD, YOU KNOW, HAVE TO WORK FURTHER ON THAT LANGUAGE.
UM, WE HAVE AGREEMENT AROUND THERE SHOULD BE AN EXEMPTION PROCESS, BUT I THINK WHAT EXEMPTIONS WE ARE GOING TO IS, IS, UH, STILL GONNA BE HIGHLY DEBATED.
UM, WE HAD SOME CONSENSUS AROUND THE MITIGATION PLANS AND, AND THAT EXEMPTION AGREEMENT PROCESS, RIGHT? NOT JUST SUBMIT THEM BUT IMPLEMENT THEM AS WELL.
BUT, SO I THINK THE BIG AREA REMAINING IS GONNA BE AROUND EXEMPTIONS TO WHAT EXTENT AND THEN NARROW DEFINITIONS.
UM, I HAD TO BE OUT OF THE ROOM ON THE CONVERSATION ON THE APPLICABILITY DATE TO NEW RESOURCES, BUT I THINK THAT MIGHT STILL BE SOMEWHERE WHERE WE COULD GET TO EVENTUAL CONSENSUS.
WE HAVE A TECH MEETING SCHEDULED FOR THE 22ND.
I THINK THAT SHOULD BE A LIGHTER TECH MEETING DEPENDING ON HOW LONG WE TALK ABOUT ECRS.
UM, BUT WE HAD DEDICATED THE AFTERNOON TO NORE 2 45 AND THEN WE DO HAVE TIME ON THE CALENDAR FOR JUNE 7TH AS WELL.
THE BOARD MEETING I BELIEVE IS JUNE 17TH AND 18TH.
I KNOW IT'S BEEN A LONG DAY, BUT I, I DEFINITELY DO WANT A LOT OF ROBUST FEEDBACK ON NEXT STEPS, ESPECIALLY FROM BILL AND PEOPLE LIKE BILL, UM, YOU KNOW, CERTAINLY VALUE JOINT COMMENTERS AND ERCOT, BUT WE'VE, WE'VE HEARD FROM THEM A LOT, SO I WANNA MAKE SURE ALL THE TECH MEMBERS GET, GET WHAT THEY NEED OUT OF THIS.
I HAVE A SUGGESTION FOR BOTH PARTIES AND IT DOES SOUND LIKE THERE'S SOME MOVEMENT ON SOME PARTS WHERE I THINK WE COULD GET AGREEMENT POTENTIALLY.
UH, THAT SUGGESTION WOULD BE IN THE NEXT STEPS WHEN COMMENTS ARE BEING FILED, IF THERE COULD
[05:55:01]
BE A CLEAN SET OF COMMENTS FILED THAT REFLECT AGREEMENT BETWEEN JOINT PARTIES AND ERCOT AS A BASELINE FOR THE DISCUSSION ATTACK.AND THEN SOMEHOW ANOTHER SET OF COMMENTS THAT EXPLAIN IN A, A SUMMARY VERSION WHAT THE DIFFERENCES ARE.
BECAUSE THE, I MEAN, WE HEARD FROM A FEW OTHER TAC MEMBERS, LIKE TRYING TO POUR THROUGH TWO DIFFERENT SETS OF RED LINES ISN'T, DOES NOT WORK VERY WELL FOR GOOD DECISION MAKING PROCESS.
SO I, IT SOUNDS LIKE THERE'S AGREEMENT ON A STARTING POINT AGREEMENT ON SOME OF THESE KEY ISSUES THAT ERCOT OUTLINED.
IT WOULD BE GREAT TO HAVE A BASELINE VERSION OF WHAT THAT LOOKS LIKE, WHERE THERE IS AGREEMENT WHERE ISSUES HAVE BEEN RESOLVED, AND THEN ANOTHER SET OF COMMENTS THAT HELP EXPLAIN WHERE THE DIFFERENCES ARE THAT THE TAC MEMBERS ARE GONNA HAVE TO ULTIMATELY DECIDE ON.
SO JUST A SUGGESTION TO HELP STREAMLINE THIS PROCESS.
WHO IS TAKING THE PEN ON THAT? NOT ME.
I GUESS THE, THE, THE PROBLEM I HAVE WITH THAT, WHICH I THINK IT'S A, THAT'S, THAT'S AN IDEAL, IDEAL SITUATION, IDEAL SUGGESTION.
THE PROBLEM IS, I THINK THAT'S EXACTLY WHAT WE TRIED TO DO FOR TWO MONTHS.
UM, WE, WE WERE TRYING TO DRIVE TOWARD THAT WHERE IT WAS LIKE, HERE'S THE, HERE'S THE SET OF COMMENTS THAT ONE SET OF COMMENTS, ALL THE THINGS WE HAVE AGREEMENT ON, AND THEN HERE ARE THE PLACES WE HAVE DISAGREEMENT ON A OR B.
AND THAT'S WHAT WE WERE TRYING TO DRIVE TOWARD AND IT DIDN'T WORK THAT WAY.
IN THE END, WE GOT TWO COMPLETELY SEPARATE SET OF COMMENTS THAT, UH, DIDN'T HAVE THAT BECAUSE, NOT MEANING TO BE, BUT IT SEEMED LIKE THE JOINT COMMENTERS IN THEIR LACE VERSION WHEN A COMPLETELY DIFFERENT WAY THAN WHAT, WHERE WE WERE DRIVING TOWARD WHERE WE COULD SEE THOSE, YOU KNOW, A OR B TYPE DIFFERENCES.
SO I, I DON'T KNOW, UNLESS CHAD HAS AN IDEA, I I DON'T KNOW HOW WE, I I DON'T KNOW THAT SEND, TELL SENDING US OFF INTO A ROOM TO DO THAT WORKS 'CAUSE WE ALREADY TRIED IT.
I THINK THE PROBLEM WE HAD LAST TIME TOO, YOU KNOW, COLIN AND I LOOKED FOR SOLUTIONS FOR SOMEBODY EVEN NEUTRAL TO PRESENT AREAS OF DISAGREEMENT AND WE COULD NOT GET BOTH OF THOSE PARTIES TO AGREE ON WHAT THEY DISAGREED ON.
UM, AND I THINK, YOU KNOW, AND, AND THAT WAS PART THE POINT OF TODAY WAS TO THINK ABOUT CONCEPTS MORE THAN LANGUAGE.
AND I, I ACTUALLY THINK ERCOT PRESENTATION IS VERY GOOD AT AT DOING THAT.
LIKE, DID YOU MEAN THIS? UM, I, I UNDERSTAND IT COULD HAVE BEEN PERCEIVED AS LEADING QUESTIONS, BUT I I THINK IT WAS GOOD TO, TO FRAME IT THAT WAY, UM, YOU KNOW, ON CONCEPTS VERSUS LANGUAGE, BUT I, I THINK IF WE GO BACK AND SOMEBODY TRIES TO WRITE LANGUAGE, I, I DON'T SEE US GETTING TO AGREEMENT.
WELL I, IT FELT LIKE AT THE LAST TAC MEETING THERE WAS SOUNDED LIKE MORE AGREEMENT ON JUST BASELINE LANGUAGE AND FOLKS RAN OUTTA TIME TO TRY TO RECONCILE, BUT YEAH, IT APPARENTLY THAT'S NOT THE CASE.
YEAH, AND I WILL SAY, YOU KNOW, IT'S BEEN REITERATED TO ME, WE TECH DID VOTE AVERSION THROUGH, SO THERE WAS A AGREEMENT ON LANGUAGE.
WE DO HAVE, YOU KNOW, NEW, WE HAVE A REMAND AND DIRECTION FROM THE BOARD THAT NECESSITATES A NEW VOTE.
BUT I, I THINK WE CAN GET TACK TO AGREEMENT.
ANOTHER PRESENTING SOME A A A VERSION THAT THERE'S CLEARLY THERE'S AGREEMENT WE'RE HEARING POINTS WHERE THERE IS AGREEMENT AND JUST IT WOULD BE HELPFUL TO HAVE THAT IDENTIFIED IN THE SET OF COMMENTS.
YEAH, I MEAN I, I WAS GONNA MAYBE BUILD UPON WHAT BILL WAS GONNA SAY TO THE EXTENT SOME OF THESE CONCEPTS THAT WE'VE AGREED ON IN PRINCIPLE CAN BE WORKED OUT AS NEW LANGUAGE FOR THE 22ND AND WE CAN FILE THAT AND LOCK TACK THROUGH THAT AND SAY WE'VE AGREED TO THIS LANGUAGE, THEN THAT DOES MOVE THE NEEDLE FORWARD.
AND THEN ERCOT AND JOINT COMMONERS CAN STILL TALK TO TACK ABOUT THE DIFFERENCES RELATIVE TO THE CONTENT THAT WE'VE BEEN TALKING ABOUT TODAY.
'CAUSE I DON'T THINK YOU'RE GONNA SEE A LOT MORE ADDITIONAL ANALYSIS FROM US.
WE GAVE YOU 60 SOMETHING SLIDES AND WE'VE THROWN OUT ALL OF OUR KEY CONCEPTS IN HOW WE'RE THINKING THROUGH THIS AND I DON'T KNOW IF THERE'S MUCH MORE FOR JOINT COMMENTERS, BUT WE COULD HAVE THAT DISCUSSION AS PART OF THE TYPE DIALOGUE ON THE 22ND.
BUT WHAT I HEARD WAS THAT THERE ARE SOME THINGS THAT WHAT CAN CLEAN UP THE LANGUAGE AND TIGHTEN A LITTLE BIT AND EVEN IF WE DON'T GET TO THE FULL PROCESS
[06:00:01]
ON WHAT THE EXEMPTION STANDARD LOOKS LIKE, I HEARD THAT THERE WAS RECOGNITION THAT THERE SHOULD BE A BROADER SYSTEM-WIDE ASSESSMENT AND THAT CONCEPT IS NOT IN THERE.SO MAYBE WE CAN AGREE TO SOME OF THAT LANGUAGE AND THERE'LL STILL BE DIFFERENCES ON OTHER PARTS OF IT.
SO I WOULD AT LEAST THROW THAT OUT AS, YOU KNOW, A MIDDLE APPROACH TO TRY TO WORK THROUGH SOME OF THE LANGUAGE WHERE THERE SEEMED TO BE PRINCIPLES THAT WERE AGREED TO.
CAN I ADD TO THAT? WHO'S IN THE QUEUE? YEAH, YOU'RE, YOU'RE NEXT IN THE QUEUE.
WHAT I WAS THINKING ABOUT IS WHAT MIGHT HELP CUT THIS IS NOT YOU GUYS GET IN THE SAME ROOM AND WRITE SOMETHING AND DO THAT.
ONE OF THE THINGS, SINCE WE ALREADY HAVE A A TAC APPROVED VERSION THAT'S OUT THERE, THAT, AND, AND WHAT WHAT COULD HAPPEN IS IS, UH, CHAD, YOU GUYS COULD REDLINE THE TAC VERSION TO SHOW OF COURSE WHAT WE BELIEVE THE LANGUAGE FOR WHAT WE AGREED ON TODAY.
AND THEN YOU COULD REDLINE THE AREAS WHERE YOU STILL HAVE DISAGREEMENT AND I THINK THAT'LL CLEAN IT UP AND IT'S ALL IN ONE DOCUMENT.
I THINK SOME OF THE, THAT MAKES SENSE.
THE DETAILS OF THE AGREEMENT MATTER A LOT.
AND SO WHAT I WOULD PROPOSE AS AN ITERATION OF THAT IS THAT MAYBE WE CAN COME UP WITH THE THINGS THAT WE AGREE ABOUT AND HOW TO WRITE THAT AS A JOINT RED LINE.
AND THEN FROM THERE, UM, IF THERE ARE ADDITIONAL CHANGES THAT YOU WANT TO MAKE THAT WE DISAGREE WITH, THAT CAN BE A SEPARATE SET OF COMMENTS.
BUT THAT WAY WE HAVE AT LEAST HERE ARE THE THINGS WE AGREE ABOUT THAT WE KNOW WE COULD PASS AND THEN WE CAN DEBATE WHETHER OR NOT TO PASS ADDITIONAL CHANGES AS WELL.
I WAS GONNA RE SAY SOMETHING ALONG THOSE SAME LINES IS, YOU KNOW, GIVEN THAT, YOU KNOW, WE'VE GOT THE TAC APPROVED VERSION, UH, AND YOU KNOW, THERE ARE STILL CONCERNS ERCOT HAS AND YOU KNOW, THOSE, WE HAVE TO BE RESPONSIVE TO ERCOT CONCERNS TO MEET THE BOARD'S REQUIREMENT.
THEN, YOU KNOW, HAVING THAT ESSENTIALLY WHAT BOB JUST SAID, THE THE THE TAC APPROVED VERSION IS THE SINGLE RED LINE, WHICH WOULD BE HELPFUL FOR JUST SEEING WHAT, WHAT CHANGED.
UM, THEN WE CAN TRACK WHAT ELSE, YOU KNOW, WE, WE CAN EITHER SAY YAY, NAY, OR, UM, YOU KNOW, WE CAN, WE CAN WORK ON MODIFICATIONS, UM, FROM THERE.
BUT, UH, ONE, ONE THING I DID WANT TO JUST PLUG IN THERE IS, YOU KNOW, GIVEN THE, THE DELAYS WITH THE, YOU KNOW, THE GO FORWARD DATE, THE CUTOFF SEEMS LIKE THAT'S PROBABLY NOW AUGUST 1ST, GIVEN THAT IT WON'T BE APPROVED AND IT COULD MAYBE JULY 1ST IF THE COMMISSION WAS TO WAIVE THE 30 DAY, UH, HOLDING PERIOD.
BUT, UM, THAT WAS THE ONLY THING I WAS GONNA ADD TO THAT.
AND, AND I'M FINE WITH BOB'S APPROACH TOO, WHICH IS ESSENTIALLY HAVE AN ERCOT RED LINE VERSION ON TOP OF THE TACK.
UM, IT DOESN'T NECESSARILY GET THE, THE FULL BENEFIT OF WHETHER THE JOINT COMMENTERS AGREED WITH THOSE WORDING CHANGES.
AND THEN WE'LL HAVE TO SHOW UP AT TAC AND, YOU KNOW, SAY WHY THEY MAY OR MAY NOT LIKE THAT TYPE OF WORDING CHANGE.
MAY MAYBE I CAN, WE CAN SAY WE ENCOURAGE THE JOINT COMMENTERS TO REACH OUT TO ERCOT AND, AND OFFER FEEDBACK.
I I DON'T WANT TO SAY Y'ALL GO INTO A ROOM AND TRY TO HASH IT OUT.
'CAUSE CLEARLY YEAH, LIKE WE SAID, WE'VE DONE THAT BEFORE.
YEAH, BUT I MEAN THE, JUST CANDIDLY, THE WAY, THE MOST LIKELY WAY FOR, FOR CONSENSUS TO HAPPEN IS IF THE WORDS THAT YOU WRITE DOWN ARE THINGS THAT PEOPLE CAN AGREE TO.
AND SO IT'S IMPORTANT THAT WE GET THOSE WORDS RIGHT AND UM, AND SO THAT'S WHY I THINK WORKING TOGETHER ON THE FRONT END WOULD BE HELPFUL.
BUT WE CAN TALK ABOUT THAT OFFLINE.
JENNIFER, ACTUALLY, I DON'T CARE.
WE GO TO HOW THEY GO TO, OR DO YOU WANT HOW THEY GO ABOUT THAT? OKAY.
SO YEAH, I MEAN IF YOU GUYS GET TOGETHER AND CAN WORK THAT OUT, THAT'S GREAT.
IF YOU CAN'T, THAT'S GREAT TOO.
I THINK BY GETTING THE, I THINK WE'RE GETTING TO THE SAME PLACE.
IT'S JUST A MATTER OF WHETHER YOU GUYS GET TOGETHER OR NOT.
ONE OF THE QUESTIONS I HAD WAS THAT IT SEEMED LIKE THE COMMERCIAL REASON REASONABILITY OR WHATEVER, UM, THAT PASSED IN THE ATTACK APPROVED VERSION WAS A STICKING POINT AND WE TALKED ABOUT IT A LOT TODAY, BUT I DIDN'T HEAR MOVEMENT ON GETTING TO AN ALTERNATIVE SET OF LANGUAGE OR GUIDANCE.
SO THAT'S ONE PIECE WHERE I DON'T THINK ERCOT REDLINING IS GOING TO
[06:05:01]
HAVE AN ANSWER FOR TAC.AND SO I JUST, I WANTED TO ASK IF WE'VE CONSIDERED THAT.
WE, WE DID TALK ABOUT WHERE WE THINK THERE'S AGREEMENT AROUND SOFTWARE, BUT FOR HARDWARE, I, I DON'T THINK WE ARE ANYWHERE CLOSE TO AN AGREEMENT.
UM, AND, YOU KNOW, REALIZING WE DON'T HAVE ALL THE TIME IN THE WORLD, BUT I DO THINK CONCEPTS BEFORE LANGUAGE HELP, UM, LET'S, LET'S KEEP THINKING ABOUT THAT.
NO, I THINK YOU ENDED UP WHERE I WAS GONNA ASK IS I THINK WE SET UP OUR PRESENTATION TO TRY TO GET WHAT THE WILL OF T MEMBERS WERE.
UM, THIS NEEDS TO NOT BE A NEGOTIATION BETWEEN JOINT COMMENTERS AND ERCOT.
I THINK ONCE WE GET WHAT TAC MEMBERS WANT, THEN WE GET THE DIRECTION AND WE GET THE LANGUAGE WRITTEN.
SO I THINK FINDING A WAY MAYBE TO FACILITATE THAT FEEDBACK ON SOME OF THESE KEY CONCEPTS WOULD THEN MAKE THE LANGUAGE EDITS A LOT MORE DIRECT AND TO THE POINT.
I, I DEFINITELY AGREE WITH THAT.
UM, AND I THINK, YOU KNOW, I, I CAN'T TELL PEOPLE THEY CAN'T GET IN A ROOM, BUT I, I THINK THAT WOULD BE MY HESITANCY WITH A JOINT APPROACH IS THAT THAT'S JUST A BACK AND FORTH NEGOTIATION THAT TO SOME EXTENT EXCLUDES TAC, WHICH IS WHAT WE'VE DONE IN THE PAST.
UM, COLIN RAISED THAT EARLIER TOO, ALTHOUGH I COULD LET HIM SPEAK FOR HIMSELF.
I THINK IT'S IMPORTANT FOR TAC LEADERSHIP OR ERCOT TO GET MEMBER FEEDBACK ON, ON THINGS LIKE THE EXEMPTION PROCESS.
UM, I DON'T KNOW THE BEST WAY TO DO THAT.
SO I'M, I'M OPEN TO OPTIONS AND I DON'T KNOW IF THAT'S SOME KIND OF STRAW POLL OR VOTING BY CONCEPT AT THE NEXT MEETING OR WRITTEN FEEDBACK, BUT, BUT I, I THINK THAT'S KIND OF ALONG THE LINES OF WHAT WE WERE THINKING AS WELL.
SINCE THE WORDS OF THOSE THINGS MATTER SO MUCH, UM, I, I THINK A STRAW POLL WITH HIGH LEVEL QUESTIONS, UM, ISN'T HELPFUL.
AND SO, UM, MAYBE WHAT WE CAN DO IS, UM, WORK ON AS MUCH, UM, OF THE ACTUAL PROPOSED LANGUAGE CHANGES AS POSSIBLE TO SEE IF THAT'S SOMETHING THAT TAC WOULD LATER ENDORSE.
I DON'T THINK WE CAN GET DOWN TO EVERY LAST, UH, PERIOD AND, AND COMMA, BUT UM, THE SOONER THAT YOU CAN SEE WHAT A, A PROPOSED CHANGE ACTUALLY MEANS, HAVE A CHANCE TO EVALUATE THE BETTER VERSUS A HIGH LEVEL ASSESSMENT OF, YOU KNOW, SHOULD WE CONSIDER X OR Y.
SO IT SOUNDS LIKE WE STILL DON'T HAVE A PLAN, UM, BESIDES GETTING A BLACKLINE VERSION OF WHAT TAC APPROVED AND I AND ERCOT MAYBE REDLINING THAT FOR WHAT THEY STILL HAVE OUTSTANDING.
I THINK WE AGREED UP TO THAT POINT, YES.
AND I MEAN, AT LEAST SOME, I THINK WHAT KATHY SAID ON THE COMMERCIALLY REASONABLE CNR LIST IS THAT THEY WANTED TO LOOK AT IT MORE BECAUSE THEY JUST SAW IT TODAY AND SEE IF THERE'S, AND I DON'T KNOW, I MEAN YOU, ERIC, YOU'VE TALKED ABOUT TAKINGS AND, AND ALL THAT STUFF.
AND SO IF WE'RE GONNA GET TO THOSE KIND OF LEGAL THRESHOLD ISSUES THAT WOULD BE HELPFUL FOR THE NEXT TAC MEETING WHERE YOU THINK, YOU KNOW, HAVING 20% OR 50% AS AN OBJECTIVE CRITERIA SOMEHOW A TAKINGS CLAIM.
AND I'D WANNA UNDERSTAND THAT MORE AT THE NEXT TAC MEETING BECAUSE WE DO THINK HAVING AN OBJECTIVE CRITERIA IS HELPFUL AND SUSTAINABLE AND, AND, AND PROVIDES EQUAL TREATMENT TO EVERYONE AS WE, AS WE THEN LOOK AT THE OVERALL, UM, SYSTEM RELIABILITY ASSESSMENT AS WELL.
SO THAT WOULD BE ANOTHER PART OF THE, I THINK THE OVERALL T DISCUSSION NEXT WEEK IF THERE'S GONNA BE A DIFFERENCE OF OPINION ON THE COMMERCIAL REASONABILITY OUTCOME PIECE AS FAR AS THE OVERALL EXEMPTION PROCESS.
BUT AT AT LEAST FROM ERCOT VERSION, THE WAY I SEE IT IS THAT, AND COREY I'LL LOOK TO YOU, IS THIS SOMETHING LIKE MONDAY WE COULD SEND OUT THE ONE RED LINE VERSION OF NORE 2 45 JUST TO THE ENTIRE TAC AND POST IT.
IS THAT FAIR? WE CAN TALK ABOUT THE, THE FORMAT THAT YOU WANTED IN.
SO WE'LL AIM TO GET THAT OUT, YOU KNOW, CLOSE THE BUSINESS
[06:10:02]
MONDAY JUST SO EVERYBODY CAN SEE WHAT ONE CONSOLIDATED RED LINE OF THE TAC APPROVED VERSION LOOKS LIKE.AND THEN ERCOT WILL WORK FROM THAT SO THAT YOU CAN SEE WHAT OUR INCREMENTAL RED LINE CHANGES WOULD BE FOR THE SECOND PART OF TAC I GUESS ON THE 22ND OR WHATEVER IT IS.
AND THEN MY PERSPECTIVE IS SIMILAR TO ERIC, TO THE EXTENT WE CAN AGREE ON LANGUAGE BEFORE WE STEP INTO ATTACK, THAT WILL ONLY HELP THIS DISCUSSION.
BUT WE'RE PROBABLY NOT GONNA AGREE ON CERTAIN THINGS AND SO WE'LL NEED TO CONTINUE TO PULL UP OUR PRESENTATIONS AND TALK THROUGH THOSE POLICY ISSUES.
YEAH, MAYBE THE ERCOT RED LINES, WE COULD DISTINGUISH BETWEEN WHAT'S BEEN AGREED UPON, WHAT, WHAT WE THINK HAS BEEN AGREED UPON VERSUS THINGS THAT ARE CLEARLY NOT AGREED UPON.
AND JUST TO CLARIFY THAT A LITTLE BIT, 'CAUSE I, I UNDERSTAND WHAT YOU'RE TRYING TO ACCOMPLISH WITH THAT AND I'D LIKE TO GET TO THE SAME OUTCOME.
SO, UH, THE, SO FOR EXP, I SAID EARLIER, MAXIMIZING SOUNDS LIKE WE, WE CAN TALK ABOUT IT, WHAT MAX, BUT WHAT MAXIMIZING MEANS MATTERS A LOT.
SO THAT'S THE KIND OF THING WE'RE LIKE, WHY DO WE TALK ABOUT THAT? LAY OUT SOME PRINCIPLES FOR HOW TO DO THAT.
WE CAN'T BACK OUT NOW
YEAH, ACTUALLY, WOODY, THAT'S WHAT I WAS THINKING.
I WAS GONNA ASK YOU GUYS IF YOU COULD, 'CAUSE WHEN WE GET INTO THE MEETING ON THE 22ND, I MEAN, WE CAN DO DESKTOP EDITS, WE CAN CHANGE THINGS OR END UP IN SOME DIFFERENT PLACE BY WHAT WE EVENTUALLY DO.
BUT WITH THE OVERALL, IN MY MIND, THE OVERALL CONCEPTS THAT WE KIND OF AGREED HERE TODAY, I KNOW THAT THERE'S, IT GETS DOWN TO THE LANGUAGE, BUT PUT THAT IN, SAY CHARTREUSE, YOU KNOW, AS A RED LINE.
AND THEN PUT YOUR COMMENTS WHERE THERE'S DISAGREEMENT IN RED, YOU KNOW, UH, SO THAT WE'LL HAVE AN IDEA.
THESE WERE THE CONCEPTS WE AGREED ON NOW TO THE WORDS FIT AND HERE'S WHAT YOUR SUGGESTION WAS FOR THOSE WORDS.
AND THEN WE COULD DEBATE THAT OUT IS WHAT I WAS TRYING TO GET TO.
AND THEN IN RED, WE KNOW THERE'S A DISAGREEMENT AND HAVE TO FIGURE THAT OUT.
DOES THAT MAKE ANY SENSE, ERIC? CHART TRUTH? I AGREE.
WELL, I WAS TRYING TO STAY AWAY FROM GREEN BECAUSE EVERYBODY THINK, OH, THAT'S GOOD.
SO I WAS TRYING TO STAY AWAY FROM THAT.
S STRATUS HAS SUPPLY CHAIN PROBLEMS. SO WHAT WAS THE, ON JULIA'S PRESENTATION THERE IS A SNAIL AND A RED HAND SINCE WE'RE TALKING ABOUT, OKAY, GO AHEAD BILL.
SO ONE THING THAT WOULD BE HELPFUL FOR ME IS IF, UM, WE COULD GET A JOINT COMMONER'S VERSION OF ERCOT SLIDE 17, WHICH IS WHERE THEY OUTLINED WHAT THEY BELIEVE THE EXEMPTION PROCESS LOOKS LIKE.
SO THE, WHAT, WHAT IS A UNACCEPTABLE LIABILITY RISK AND HOW IS THE, ESSENTIALLY THE COMMERCIAL REASONABILITY MEASURED IN TERMS OF LOW COST, HIGH COST, SO THINGS THAT YOU GUYS DON'T LIKE THERE, WHAT, HOW YOU WOULD TWEAK THAT LIST IS, FOR ME ANYWAY, LIKE THAT'S MY HANGUP IS SO THE DIFFERENCE BETWEEN WHERE YOU GUYS ARE AND THEY ARE, AS I WOULD LIKE TO UNDERSTAND THAT BETTER.
SO ONE OF THE KEY THINGS, UH, THAT NEED SOME MORE DISCUSSION TO GET TO THAT IS THE FIRST THING THAT DAN SAID IN THAT PRESENTATION IS WE DIDN'T HAVE ALL THE UPDATED MODELS TO KNOW WHAT WE CAN DO.
AND WE HAD JUST SPENT TWO HOURS SAYING, WE'RE NOT SURE THE MODELS ARE RIGHT.
SO I'D LIKE TO KNOW MORE ABOUT HOW ERCOT WOULD MAKE THE DETERMINATION OF WHAT IS, UH, YOU KNOW, AN UNACCEPTABLE LEVEL OF RISK, OR WOULD IT ALWAYS BE TAKING THE MOST, UH, CONSERVATIVE, UM, GUESSES.
BECAUSE IF OUR CORE THING THAT WE WANT FROM A PROCESS IS SOMETHING THAT IS, UM, YOU KNOW, A FACT-BASED PATTERNED AND NOT KIND OF A, A GUT CHECK.
AND SO A MODELING APPROACH COULD ACCOMPLISH THAT.
BUT, UH, I, I JUST DIDN'T HEAR ENOUGH DETAILS TO KNOW HOW IT WOULD WORK.
AND ONE MORE BILL PIECE OF FEEDBACK FROM A NEUTRAL TECH MEMBER THAT'S TRYING TO FIGURE OUT HOW TO DECIDE ON THIS IS I'M STILL KIND OF, I'M REALLY SYMPATHETIC TO THIS SCENARIO THREE ON SLIDE 16 WHERE YOU ENERGIZED A WIND TURBINE A LONG TIME AGO AND NOW YOU FIND YOURSELF IN THE SITUATION WHERE THERE'S NOTHING THAT YOU CAN DO AND ERCOT IS EITHER GOING TO LIKE PUT ON A GTC, THAT PRETTY MUCH LIMITS YOUR OUTPUT
[06:15:02]
OR YOU'RE RESTRICTED FROM PRODUCING.I DON'T, I, THAT ONE BOTHERS ME AND I DON'T KNOW WHAT WE CAN DO TO RESOLVE THAT SITUATION OR EVEN UNDERSTAND HOW MANY MEGAWATTS WOULD POTENTIALLY FALL IN THERE, PARTICULARLY GIVEN WE CAN'T MODEL IT VERY ACCURATELY.
BUT THAT ONE IS TROUBLING TO ME.
AND I DON'T KNOW IF WE HAVE A DIFFERENT BAR FOR WHAT IS A, UH, UNACCEPTABLE RELIABILITY RISK FOR THE THOSE FOLKS.
SO JUST, YEAH, THAT'S WHERE I'M MY HEAD'S AT RIGHT NOW.
SO WE HAVE, UM, FOUR OUTAGES THAT ARE ABOVE THOSE THRESHOLDS ON A RELATIVELY ROUTINE BASIS THAT WE DON'T HAVE GTCS FOR.
AND ONE OF THE THINGS YOU HEARD FROM ERCOT TODAY IS IF WE SET THE GTCS, IT COULD LOWER REVENUE AND ENCOURAGE PEOPLE TO MAKE AN INVESTMENT.
AND I APPRECIATE THE, THE LOGIC OF THAT STATEMENT, BUT I'M CONCERNED THAT THERE COULD BE, AND, AND A LACK OF CLARITY AROUND HOW THOSE GCCS ARE APPLIED.
IF THERE'S A COMMERCIAL, UM, INTENTION BEHIND A GTC VERSUS A RELIABILITY INTENTION.
I'M NOT SAYING THAT WI WILL HAPPEN, BUT UNLESS THERE'S A CLEAR PROCEDURE FOR HOW IT DOES HAPPEN, IT'S SOMETHING THAT PEOPLE MIGHT BE CONCERNED ABOUT.
AND WHETHER, I MEAN, WOODY, YOU SAID YOU MENTIONED TRANSMISSION SOLUTION, WHETHER THE SYNCHRONOUS CONDENSER PROJECT ACTUALLY RESOLVES SOLVE THE PROBLEM FOR THOSE FOLKS.
AND I KNOW THIS KIND OF DEPENDS ON YOUR ABILITY TO MODEL IT, WHICH, YOU KNOW, THERE'S ISSUES THERE.
SO CHAD, DO YOU KNOW WHEN ERCOT WOULD BE ABLE TO GET COMMENTS TO US, US IF IT WAS JUST A RED LINE AND THEN ERCOT COMMENTS ON OUTSTANDING AREAS OF CONCERN? I DON'T KNOW.
UM, AND, AND I REALLY THINK WE'RE GONNA SPEND A HALF A DAY ON THE 22ND WALKING THROUGH IT.
BECAUSE IT'S JUST, THAT'S JUST THE REALITY OF THE SITUATION.
I WAS WONDERING IF WE SHOULD DO A SEPARATE WEBEX MAYBE BEFORE THAT, WHENEVER YOU CAN HAVE COMMENTS WITH WHOEVER WANTS TO ATTEND AND REALLY TRY TO EFFICIENTLY GO THROUGH WHERE JOINT COMMENTERS STILL HAVE QUESTIONS ABOUT THE LANGUAGE, WHERE, YOU KNOW, INTERESTED NEUTRAL STAKEHOLDER, BILL BARNES HAS OUTSTANDING QUESTIONS.
YOU KNOW, THE, THE PEOPLE WHO ARE REALLY DOING THEIR HOMEWORK OR THEY STILL HAVE OUTSTANDING QUESTIONS AND TRY TO GET THROUGH THAT, YOU KNOW, EFFICIENTLY AND TWO, TWO OR THREE HOUR WEBEX.
UM, AND WE, WE COULD DO THAT AHEAD OF THE MEETING.
THAT'S THE BEST IDEA I HAVE ON HOW TO APPROACH THIS.
I DON'T KNOW IF WE COULD DO IT EARLIER.
BECAUSE WE, ERCOT HAS THAT INNOVATION SUMMIT THE DAY BEFORE AND THAT'S PROBABLY GOT A LOT OF PEOPLE, YOU KNOW, POTENTIALLY GOING TO THAT.
SO A LITTLE BIT OF COMPRESSED TIME TO GET IT TO THE 22ND.
BUT THERE COULD BE A WEBEX AFTERWARDS THAT COULD CONTINUE TO GO, UH, AFTER THE 22ND, YOU KNOW, EITHER THE 23RD OR 24TH FOR A COUPLE HOURS THAT COULD CONTINUE TO GO INTO THE RED LINE LANGUAGE.
DO YOU THINK THAT THERE, AND MAYBE THIS IS AN OFFLINE DISCUSSION, SO IF THAT'S THE APPROACH, IS THERE STILL, YOU KNOW, IS THERE PRODUCTIVE CONVERSATION THAT COULD BE HAD IN PERSON IN THE AFTERNOON OF THE 22ND? YES.
WE, WE WILL HAVE RED LINES BY THE 22ND.
I JUST DON'T WANT TO COMMIT THAT WE CAN HAVE IT TO YOU THE MONDAY BEFORE, YOU KNOW, AND, AND PEOPLE ARE REALLY GONNA LOOK AT IT.
I MEAN, YOU'LL HAVE ATTACK AGENDA TOO, AND I ASSUME EVERYBODY ELSE WILL BE LOOKING AT THAT ATTACK MATERIALS.
SO IT MADE ME MORE GIVING IT TO YOU MONDAY AFTERNOON OR TUESDAY AS ERCOT COMMENTS.
AND THEN ACTUALLY WALKING THROUGH SOME OF THE CONCEPTS IN THE AFTERNOON AND SEEING WHERE THE REMAINING PART OF THE, THE DIVISION IS BETWEEN TAC ERCOT AND THE JOINT COMMENTERS.
I, I WOULD NOT EXPECT TAC TO BE ABLE TO ACTUALLY VOTE ON A VERSION ON THE 22ND JUST BECAUSE OF THE TIMING CONSTRAINTS.
AND TO CORY'S POINT ABOUT, WE WOULD HAVE TO THEN WHATEVER TAC ULTIMATELY AGREED TO KIND OF CONSOLIDATE BACK INTO THE, THE OFFICIAL VERSION.
SO IT REALLY IS TO HELP PROVIDE CLARITY ON THE NET VERSION WITH THE INCREMENTAL, HOPEFULLY AGREED TO RED LINES THAT MAYBE ERCOT AND THE JOINT COMMENTERS CAN GET TO WITH ADDITIONAL ITEMS THAT WILL STILL NEED TO BE DISCUSSED.
THE, THE, UH, I THINK THERE ARE SOME ISSUES THAT ARE LANGUAGE HERE IN LANGUAGE HERE, IN LANGUAGE HERE.
AND SO WE WILL HAVE TO DO IT IN SUCH A WAY THAT IT'S NOT JUST, WE'RE GONNA HAVE TO TEE UP THE ISSUES.
I MEAN, THAT WAS WHAT WE WERE TRYING TO DO IN, IN THIS DOCUMENT IS TEE UP THE ISSUES
[06:20:02]
SO THAT YOU COULD, UH, DECIDE ON THOSE DIRECTIONALLY AND THEN WE COULD FIGURE OUT HOW TO MAKE THE LANGUAGE FIT.I UNDERSTAND THE LANGUAGE IS WHAT MATTERS.
IN FACT, THAT'S BEEN PART OF THE PROBLEM.
BUT, UM, WE'RE, I THINK THERE'S STILL GONNA HAVE TO BE A, IN ADDITION TO THE RED LINE, THERE'S GONNA HAVE TO BE ISSUES LIST THAT SAY, OKAY, HERE ARE ALL THE PLACES THAT YOU'D HAVE TO CHANGE IF YOU GO, YOU KNOW, ONE A AND HERE'S ALL THE CHANGES THAT YOU'D HAVE TO DO IF TO GO ONE B ON DECISIONS.
AND SYNCHRONOUS CONDENSERS, DON'T FIX THE PROBLEM.
THAT WAS THE OTHER THING I WAS GONNA SAY.
THE APPROVED SYNCHRONOUS INJURIES, DON'T FIX ALL THE PROBLEMS. NOT ALWAYS STEVEN.
YEAH, I I JUST NOTICED THAT, YOU KNOW, BILL, YOU HAD A GOOD QUESTION THERE, RIGHT? AND BETWEEN NOW AND THEN, I WOULD JUST OFFER, IF ERCOT STAFF CAN HELP ANSWER QUESTIONS, THEN WE'RE WILLING, YOU JUST GOT A LOT OF MATERIAL PRESENTED TO YOU OVERNIGHT FROM YESTERDAY TO TODAY, AND YOU'RE TRYING TO DIGEST EVERYTHING.
AS THESE QUESTIONS COME UP, WE WANT TO INFORM SO THAT YOU CAN MAKE A GOOD DECISION.
THAT'S, THAT'S, THAT'S OUR MAIN PRIORITY HERE.
AND SO FROM NOW TILL THEN, PLEASE REACH OUT IF YOU HAVE QUESTIONS, EVEN IF IT'S MULTIPLE SESSIONS, UH, WE CAN TRY TO ANSWER YOUR QUESTIONS TO THE BEST OF, OF OUR ABILITY AND YOUR SPECIFIC ONE ON A GTC, WE ONLY IMPLEMENT GTC FOR RELIABILITY REASONS.
THERE'S NO TYPE OF COMMERCIAL PUNISHMENT OR ANYTHING LIKE THAT.
THAT WAS PART OF WHY I WAS SUGGESTING SOMETHING BEFORE TAC BECAUSE WE DID GET ALL THIS INFORMATION YESTERDAY, SO, AND TO THE EXTENT WE KEEP PICKING ON YOU BILL, BUT TO, IF OTHER PEOPLE SAID, HEY, I'D REALLY LIKE TO SEE SLIDE X FROM JOINT COMMENTERS OR ERCO VICE VERSA, I'D LIKE A FORUM FOR THAT TOO.
'CAUSE AGAIN, I THINK WHAT WHAT I'M REALLY FOCUSED ON IS MAKING SURE THAT TAC VOTERS HAVE WHAT THEY NEED.
SO IF SOMEBODY WANTS TO SEE MORE DATA OR MORE INFORMATION FROM ERCOT OR FROM JOINT COMMENTERS, UM, AT LIKE A FORM FOR THAT TOO.
AND SO I GUESS THAT COULD BE DONE BY EMAIL, BUT I WANNA MAKE SURE WE'RE GETTING THAT IN ENOUGH TIME TO ALSO GET PEOPLE THAT, THAT INFORMATION BACK.
[10. Next Steps]
ALL RIGHT, COLIN, WHAT ARE WE DOING NEXT? COOL.UM, SO WE'RE MEETING THE 22ND AND WE'LL DO A WALKTHROUGH OF KOTS COMMENTS.
UM, AND THEN MAYBE IF NECESSARY WE COULD DO A WEBEX AS I DESCRIBED WITH WHOEVER WANTS TO ATTEND TO GO OUT, GO THROUGH OUTSTANDING LANGUAGE ON THAT.
SOMETIME THE WEEK OF THE 27TH.
AND THEN WE DO HAVE TIME STILL ALLOTTED FOR THE SEVENTH AS WELL, BUT THAT'S GETTING PRETTY CLOSE.
THE SEVENTH WILL PROBABLY HAVE TO TAKE A VOTE.
SO WE MIGHT NEED AN ADDITIONAL WEBEX I CAN GET WITH SUZY AND COREY AND EVERYONE.
WE, WE MIGHT WANT AN ADDITIONAL WEBEX LIKE THE WEEK OF THE 27TH.
AND THEN FOR ADDITIONAL QUESTIONS, WE COULD DO THAT BY EMAIL REQUEST FOR MORE INFORMATION ON THIS.
DO YOU WANNA TRY TO GET ALL THOSE REQUESTS TO YOU BY WEDNESDAY? I, I THINK IT, I THINK FOR US I'S JUST WHENEVER YOU HAVE QUESTIONS, UH, THIS, THIS IS SUCH AN IMPORTANT MATTER THAT, UH, WE JUST WANT TO BE ABLE TO ANSWER YOUR QUESTIONS AND MAKE SURE YOU HAVE THE INFORMATION YOU NEED WHENEVER THAT IS.
I, I GUESS I, I'M TALKING ABOUT LIKE, IF, IF BILL WANTS A SLIDE, BUT BY THE OTHER PARTY, I WANNA MAKE SURE WE GIVE PEOPLE TIME TO MAKE THAT AND FOR EVERYBODY TO SEE IT.
ALSO, IF, IF THERE'S, YEAH, IF THERE'S CONTENT GIVING US A COUPLE OF DAYS HELPS, UM, OUTSIDE OF THAT WE CAN INFORMALLY RESPOND.
WELL, SO I JUST WANNA ADD THAT WHAT I HEARD WAS, I, I DIDN'T HEAR ANY ADDITIONAL DATA THAT ANYONE'S ASKED FROM ERCOT, BUT THAT, YOU KNOW, A COUPLE ADDITIONAL THINGS THAT MAYBE ERIC AS A JOINT COMMONERS COULD PROVIDE, WHICH IS HOW DID THEY ENVISION THE TAC APPROVED EXEMPTION PROCESS WORKING BY THOSE SCENARIOS THAT WE LAID OUT? AND I THINK
[06:25:01]
THAT WOULD BE HELPFUL FOR, FOR ERCOT.UM, AND, AND MAYBE FURTHER IN, FROM MY PERSPECTIVE, FURTHER IN INFORMATION ON WHAT DAVID WAS TALKING ABOUT ON THIS UNKNOWN ISSUE, BESIDES WHAT WAS IN THIS FLOW CHART WOULD BE ANOTHER KEY ISSUE BECAUSE WE DID NOT AS A T BODY DECIDE ON, ON THAT ISSUE.
AND THAT'LL STILL BE A, A STICKING POINT I THINK TO TALK ABOUT ON THE 22ND, WHICH IS THESE UNKNOWN CHARACTERISTICS THAT WOULD SHOW UP IN THE FUTURE WHERE YOU'RE ASKING FOR AN EXEMPTION.
AND, AND I THINK THE THIRD THING IS A, UM, IF ANYONE HAS A MECHANISM FOR WHAT, UH, HOW WE CAN MAKE THE COMMERCIALLY REASONABLE PART OF THAT ASSESSMENT BE STANDARDIZED AND CONSISTENT AND REPRODUCIBLE AND ALL THOSE KIND OF THINGS OTHER THAN USING A PERCENTAGE WHICH FOLKS DON'T LIKE BUILD A FORMULA.
DO WE HAVE A PLAN KIND OF, SUSIE I THINK HAS A PLAN, SO I'M SORRY,
SO, UM, YOU KNOW, QUESTIONS ALWAYS WELCOME, BUT OUTSTANDING REQUESTS.
MAYBE BY WEDNESDAY WE'LL MEET THE 22ND, WE'LL HAVE A REGULAR TAC AGENDA IN THE MORNING, IN THE AFTERNOON WE WILL IN PERSON WALK THROUGH ERCOT COMMENTS TO A CLEAN TAC APPROVED VERSION.
UM, WE WILL, I WILL GET WITH SUSIE AND COREY AND WHOEVER ELSE, AND WE'LL TRY TO GET A WEBEX SCHEDULED FOR THAT FOLLOWING WEEK IN THE CASE WE NEED IT.
AND THEN WE HAVE JUNE 7TH WEBEX, WHICH WILL LIKELY BE A VOTING MEETING ON THIS TOO.
WELL, I APPRECIATE EVERYBODY STICKING WITH US THROUGH THIS.
UM, SUSIE DID REMIND ME THIS IS ON, THIS IS RECORDED SO THAT PEOPLE, YOU KNOW, IF YOUR FRIENDS HAD TO LEAVE EARLY, REMIND THEM TO WATCH THE VIDEO.