* This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting. [00:00:01] NINE 30. ALL RIGHT. GOOD MORNING. THIS IS SUSIE CLIFTON FROM ERCOT. WE'RE ABOUT TO GO AHEAD AND GET STARTED WITH THE, UH, TAC MEETING. IF I COULD GET EVERYBODY IN THE ROOM TO JUST GO AHEAD AND TAKE THEIR SEATS, PLEASE, . AND I'LL REAL QUICKLY GO THROUGH THE MEETING REMINDERS, THOSE OF YOU HERE IN THE ROOM TODAY. UM, AS WE GET STARTED, AND YOU WOULD LIKE TO MAKE A MOTION OR, UH, COMMENT FOR DISCUSSION, PLEASE HOLD UP YOUR CARD AND JORDAN'S OVER HERE IN THE CORNER. HE WILL ENTER YOU INTO THE CHAT, OR YOU CAN ENTER YOURSELF INTO THE CHAT IF YOU'RE LOGGED INTO THE WEBEX. AND THEN THOSE, OF COURSE, ON THE WEBEX, YOU'LL NEED TO ENTER THE CHAT AND WAIT FOR THE CHAIR TO RECOGNIZE YOU. AND THEN, UM, AS WE APPROACH THE BALLOTING PROCESS TODAY, AND YOU'RE ON THE WEBEX, PLEASE MAKE SURE TO UNMUTE YOURSELF AS WE APPROACH YOUR SEGMENT. AND THEN AFTER WE BEGIN, UM, AFTER YOU CAST YOUR BALLOT, PLEASE GO BACK TO THE MUTE STATUS AND THAT WILL HELP US BE A LITTLE MORE EFFICIENT WITH THAT PROCESS. AND THEN IF THE WEBEX ENDS FOR ANY MEETING, UH, ANY REASON, WE'LL GO AHEAD AND RESTART WITH A NEW WEBEX DETAILS IF NEEDED, AND SEND THAT TO THE LISTSERV LIKE WE DID THIS MORNING. I DO APOLOGIZE WE HAD SOME TROUBLE WITH THAT, BUT THAT'S THE PROCESS. IF, UH, WE CAN'T RE-LOG IN WITH THE SAME MEETING DETAILS, WE'LL SEND SOMETHING TO THE LISTSERV. AND THE FINAL REMINDER, THERE'S A SIGN IN SHEET OUTSIDE THE MEETING ROOM DOOR, IF YOU'LL PLEASE REMEMBER IF YOU'RE HERE TODAY TO SIGN IN. AND WITH THAT, KAITLYN, WE DO HAVE A QUORUM AND ARE READY TO GET STARTED. GREAT. THANKS, SUSIE. ALRIGHT, GOOD MORNING. UM, IT'S MAY 22ND. THIS IS OUR REGULAR FULL MEETING FOR, FOR MAY TAC. UM, WE HAVE A FULL AGENDA. WE DID HAVE A TOTAL OF THREE ADDITIONAL TAC MEETINGS IN ADDITION TO THIS ONE SCHEDULED BETWEEN APRIL AND JUNE BOARD MEETINGS, UM, WITH A FOCUS ON NO GO 2 45. SO THE PLAN FOR TODAY IS TO TAKE UP OUR, OUR FULL MAY AGENDA, HOPEFULLY WRAP THAT UP AROUND ONE, TAKE A QUICK BREAK FOR LUNCH, AND THEN RESUME TO TAKE UP, NO, GO 2 45 ON THE SCREEN AS ANTITRUST [1. Antitrust Admonition] TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY. PARTICIPANTS IN ERCOT ACTIVITY SHOULD REFRAIN FROM PROPOSING ANY ACTION OR MEASURE THAT WOULD EXCEED OR CUTS AUTHORITY UNDER FEDERAL OR STATE LAW. AND THERE'S MORE INFORMATION ON THE WEBSITE. AND I WANNA SAY THANK YOU TO SUSIE FOR THE NAME TAG. WE WERE SUPPOSED TO HAVE A, A SPECIAL VISITOR TODAY. MY, MY DAUGHTER IS HERE IN TOWN. WE BRIEFLY RELOCATED FROM HOUSTON DUE TO THE STORM. SO WE WANNA THANK EVERYBODY FOR THEIR HARD WORK, RESTORING POWER THERE. UM, AND UNFORTUNATELY SHE WAS NOT ABLE TO JOIN, BUT SHE WOULD'VE JUST MADE A CAMEO AND LEFT. UM, SO FOR PROXIES AND AL ALT REPS, UM, FOR PROXIES IN THE COMMERCIAL CONSUMER SEGMENT WE HAVE, NICK FEHRENBACH HAS GIVEN HIS PROXY TO RICK GARETT. UM, IN THE RESIDENTIAL CONSUMER SEGMENT, ERIC GOFF HAS GIVEN HIS PROXY TO NAVA FOR NOER 2 45 ONLY. UM, IN THE INDUSTRIAL CONSUMER CON SE SEGMENT, GARRETT KENT HAS GIVEN HIS PROXY TO ERIC SCHUBERT AT 2:00 PM IN THE COOPERATIVE SEGMENT. MICHAEL WISE IS GIVING HIS PROXY TO BLAKE COLT AT 1:30 PM AND IN THE, UM, INDEPENDENT RETAIL SEGMENT, JAY HARPO IS GIVING HIS PROXY TO CHRIS HENDRICKS FROM 11:00 AM TO 12:30 PM FOR AL ALT REPS IN THE COMMERCIAL CONSUMER SEGMENT. MARK DREYFUS HAS GIVEN HIS ALT REP TO RICK GARETT IN THE COOPERATIVE SEGMENT. JOHN PACKARD HAS GIVEN HIS ALT REP TO LUCAS TURNER, AND IN THE IOU SEGMENT, KEITH NICKS HAS GIVEN HIS ALT REP TO STACY WHITEHURST. AND WITH THAT, WE CAN GET STARTED. SO OUR FIRST AGENDA ITEM [2. Approval of TAC Meeting Minutes] IS THE APPROVAL OF THE APRIL 15TH TECH MEETING MINUTES. I, I DON'T BELIEVE I'M AWARE OF ANY EDITS OR COMMENTS. SUSIE, CAN YOU CONFIRM THAT THAT IS CORRECT, CAITLYN? ALRIGHT, SO IF THERE'S NO OTHER COMMENTS, CAN WE ADD THIS TO THE COMBO BALLOT? I THINK SO, COREY, I DON'T SEE ANY YESES OR NOS. SO, AND THEN I SEE IN THE QUEUE THAT THE PHRASE OF THE MONTH IS WORDS MATTER. RICHARD ROSS, DO YOU WANNA ELABORATE? BOB HILTON, WOULD YOU LIKE TO ELABORATE? I WOULD JUST ASK FOR A FRIENDLY AMENDMENT ALREADY. ALREADY. HEY, RICHARD, HOW ABOUT THE WORD INNOVATION TO GO ALONG WITH WHAT WE'VE DONE THIS WEEK OR A DERIVATIVE THEREOF? YOU KNOW, I HATE TO BE DIFFICULT, BUT, YOU KNOW, IT'S MOUTH PHRASE OF THE MONTH. SO [00:05:01] , HEY, I CALLED A QUESTION. IT IT, OKAY, THANKS RICHARD. IT, IT STEMS FROM AN ARGUMENT, UH, OR DEBATE THAT, UH, ONE OF THE STAFF MEMBERS AT AN RTO HAD WITH THEIR BOSS. AND IT WAS, IT JUST EVOLVED FROM THERE. IT'S BEEN, BEEN USED QUITE WELL THIS WEEK AT, UH, SPP MEETINGS. AND I, I'M QUITE CONFIDENT Y YOU GUYS CAN PULL IT OFF TODAY AS WELL. OKAY. I THINK IT'LL COME UP A LOT IN THE AFTERNOON DISCUSSION. UM, AND MAYBE WE CAN INNOVATE ON OUR PHRASES OF THE MONTH FOR NEXT YEAR. SO OUR, THE GO AHEAD RICHARD, OR YOU'RE NOT OPEN TO THAT . I WILL, I WILL PUT IT IN THE QUEUE. OKAY. WE'LL PUT IT ON OUR, UH, TACK GOALS SO WE CAN MOVE ON TO MEETING UPDATES. [3. Meeting Updates] UM, SINCE OUR LAST REGULAR TECH MEETING IN APRIL, AS I SAID, WE, WE'VE HAD A NUMBER OF EXTRA MEETINGS, BUT THE ERCOT BOARD HAD MEETINGS ON APRIL 22ND AND 23RD, AND THE PUC HAD AN OPEN MEETING ON APRIL 25TH. UM, AND, AND ON MAY 10TH, WE HAD AN ATTACK WORKSHOP ON NORE 2 45. JUST INDICATED THAT AS A WORKSHOP, BECAUSE IT WAS NON-VOTING AT THE APRIL 22ND AND 23RD BOARD MEETINGS, THE BOARD DID APPROVE ALL REVISION REQUESTS EXCEPT FOR NORE 2 45, WHICH WAS REMANDED HERE. WE'RE ALL FAMILIAR WITH THAT. AND AT THE APRIL 25TH OPEN MEETING, THE PUC APPROVED R-M-G-R-R 180. SO NOW WE ARE ON TO OUR REVISION [4. Review of Revision Request Summary/ERCOT Market Impact Statement/Opinions] REQUEST SUMMARIES, UH, MARKET IMPACT STATEMENTS, AND IMM OPINIONS. UH, WE WILL TURN IT OVER TO ANN. ALRIGHT, WE HAVE OUR REVISION REQUEST SUMMARY FOR THIS TAC MEETING, AND THIS WAS POSTED TO THE TAC MATERIALS. UM, FOR THE REASON FOR REVISIONS, WE HAVE FOUR THAT ARE HITTING THE STRATEGIC PLAN. OBJECTIVE ONE THREE THAT ARE HITTING SP O2 AND THEN GENERAL ASSISTANT PROCESS IMPROVEMENTS. WE HAVE THREE BOARD, PUC DIRECTIVE, WE HAVE TWO. AND THEN REGULAR REGULATORY REQUIREMENTS. WE HAVE ONE, UM, FOR IMPACTS, I WILL POINT OUT 1198 DOES HAVE A 50 TO 80 K BUDGETARY IMPACT AND 180 TO TWO 20 K STAFFING IMPACT. THIS ONE WILL REQUIRE ONE FTE, UM, FOR ERCOT OPINIONS AND MARKET IMPACT STATEMENTS. ERCOT DOES SUPPORT ALL REVISION REQUESTS HERE EXCEPT FOR PGR 1 0 5 AS RECOMMENDED BY ROSS. UM, THAT ONE LATER ON IN THE AGENDA, THERE WAS A REQUEST FOR WITHDRAWAL FILED ON THAT ONE. AND THEN THE IMM OPINIONS, THEY DO SUPPORT 11 98, 12 28, 12 30, PG ONE 13, AND NEGRA 2 58. THEY DID FILE COMMENTS ON 1124. AND THEN NO OPINION ON THE REMAINING REVISION REQUESTS. I GUESS WE'LL ASK THE IMM IF THEY WANNA ADD ANYTHING. NO, NOT AT THIS TIME. THANKS. OKAY, THANK YOU. ALL RIGHT. ANY QUESTIONS OR COMMENTS ON THIS ITEM? OKAY, WE ARE MOVING RIGHT ALONG. I THINK WE [5. PRS Report (Vote)] ARE UP TO THE PRS REPORT. DIANA, ARE YOU READY? I THINK WE, SO WE HAVE A NUMBER OF REVISION REQUESTS BEFORE US FROM PRS AND, AND MANY OF THE UNOPPOSED ITEMS HAD ABSTENTIONS. SO I, I THINK WE'LL TAKE THIS SIDE BY SIDE AND SEE WHAT WE CAN PUT ON THE COMBO BALLOT AND WHAT WE NEED SEPARATE BALLOTS FOR. SO, SO DIANA, LET'S DO THIS FIRST SLIDE AND THEN STOP AND, AND SEE WHAT WE CAN DO WITH FOUR N PRRS. OKAY. GOOD MORNING EVERYBODY. DIANA COLEMAN WITH CPS ENERGY FOR THE MAY PRS REPORT. FOR THE I, THE PROPOSED REVISIONS THAT DON'T HAVE ANY COST ASSOCIATED WITH THEM, WE HAVE 1220 THAT COMES TO US FROM ERCOT. THIS IS MODIFYING THE MARKET RESTART PROCESS. IN APRIL, PRS VOTED TO UNANIMOUSLY RECOMMEND APPROVAL AS SUBMITTED. AND THEN EARLIER THIS MONTH, WE ENDORSED IT AND FORWARDED AN ATTACK WITH THE IA THAT WAS POSTED ON MARCH 20TH FOR 1222. ALSO SPONSORED BY ERCOT. THIS IS CONSISTENT WITH ERCOT CONVERSATIONS. ON THE FINAL APPROVAL FOR THE OTHER BINDING DOCUMENT TO REQUIRE BOARD APPROVAL IN APRIL, WE VOTED UNANIMOUSLY TO RECOMMEND APPROVAL, AND THEN IN MAY, WE ENDORSED IT WITH THE MARCH 20TH IA AS WELL. 1223. ALSO FROM ERCOT, THIS IS UPDATING THE TDSP APPLICATION FOR REGISTRATION. IN APRIL, WE VOTED TO RECOMMEND APPROVAL, AND THEN IN MAY, WE UNANIMOUSLY ENDORSED WITH THE APRIL 5TH PRS REPORT AS REVISED BY PRS AND THE MARCH 21ST [00:10:02] IA, AND THEN 1228 FROM ERCOT. THIS IS DECREASING FROM TWO TO ONE, THE NUMBER OF FIRM FUEL OBLIGATION PERIODS THAT ARE AWARDED IN A PROCUREMENT. EARLIER THIS MONTH, WE VOTED TO UNANIMOUSLY GRANT URGENT STATUS AND THEN RECOMMENDED APPROVAL AS SUBMITTED WITH THE MAY 2ND IMPACT ANALYSIS. OKAY, SO WE WOULD BE LOOKING TO RECOMMEND APPROVAL OF NPRR 12, 20 12, 22, 12 23, AND 1228, ALL AS RECOMMENDED BY PRS IN THE FIVE NINE PRS REPORT. CAN WE ADD THESE TO THE COMBO BALLOT, OR DOES ANYONE WANNA PULL ONE OF THESE OFF FOR A SEPARATE BALLOT? OKAY, I THINK WE CAN ADD THESE FOUR TO THE COMBO BALLOT. OKAY, GREAT. NEXT UP, WE HAVE 1198. THIS IS COMING TO US FROM EDF RENEWABLES. THIS IS DEFINING THE EAPS AS A TYPE OF CONSTRAINT MANAGEMENT PLAN. IN APRIL, WE VOTED TO RECOMMEND APPROVAL OF 1198 AS AMENDED BY THE MARCH 8TH LCRA COMMENTS. THERE WERE FOUR ABSTENTIONS ON THAT VOTE. AND THEN IN MAY, PRS VOTED TO ENDORSE WITH THE APRIL 5TH PRS REPORT AND THE APRIL 30TH IA WITH A RECOMMENDED PRIORITY OF 2025 AND A RANK OF 45 20. AND THEN 1218 COMES TO US FROM ERCOT. THIS IS UPDATING SECTION 14 FOR THE REC TRADING PROGRAM TO COMPLY WITH THE PUC SUBSTANTIVE RULES. THIS WAS VOTED UNANIMOUSLY AT THE APRIL 25TH, OR EXCUSE ME, THE APRIL 5TH PRS, UM, AS AMENDED BY THE APRIL 4TH RELIANT COMMENTS. AND THEN IN MAY, WE VOTED UNANIMOUSLY TO ENDORSE WITH THE MARCH 5TH IMPACT ANALYSIS. OKAY, SO BOTH OF THESE HAVE A IMPACT AND HAD ABSTENTIONS, UM, NPR 1198, WE'D BE LOOKING TO RECOMMEND APPROVAL AS RECOMMENDED BY PRS IN THE FIVE NINE PRS REPORT. DO WE NEED A SEPARATE BALLOT FOR THIS ONE? YES. OKAY. YES. COREY, CAN WE TAKE IT AWAY ON 1198? ARE THERE ANY, BRIAN, DO YOU HAVE COMMENTS? YEAH, SO FOR ERCOT, THE REASON FOR MY ABSTENTION IS THAT, UH, GENERALLY WE THINK THAT SCED SOLUTIONS ARE THE PREFERRED OUTCOME. AND THIS, UM, CONGESTION MITIGATION TOOL IS OUTSIDE OF SCED FOR THESE EAPS. UM, THE LANGUAGE DOES TALK ABOUT TRANSPARENCY. WE LIKE THAT. UM, BUT IT, IT'S MORE OF A, A PHILOSOPHICAL PREFERENCE. THANK YOU. OKAY. AND WE DID WANT TO NOTE THAT WE HAVE ASSOCIATED, UH, PGRR ONE 13 AND NO, 2 58 LATER IN THE ROSS REPORT. DID WE WANT TO ADD THOSE TWO ITEMS TO THIS BALLOT? I, I, I HAVE MY COMMENTS REALLY APPLY TO EVERYTHING. AND IF IT'S MORE ADMINISTRATIVELY EFFICIENT FOR THIS, I'D SUPPORT TAKING THEM ALL UP AT THE SAME TIME. OKAY. OKAY. BECAUSE I'LL BE ABSTAINING ON ALL OF THEM. , I SEE SOME THUMBS UPS. SO LET'S, LET'S DO THAT. AND NODS. OKAY. ALEX MILLER IN THE QUEUE. THANK YOU. I DID. I APPRECIATE BRIAN'S COMMENTS. AND I DID JUST WANNA STRESS THAT WE, UM, YOU KNOW, WERE VERY THOROUGH WITH INCLUDING ALL OF THE INPUT AND REQUESTS FOR ENSURING THAT TRANSPARENCY WAS CONSIDERED THROUGHOUT THE, THE CHANGES THAT WERE MADE AS WE CAME TO THE FINAL LANGUAGE. UM, AND, AND THE, THE CED ISSUE, THIS IS NOT SOMETHING THAT IS DONE OUTSIDE OF SC. IT IS A CHANGE TO THE SYSTEM CONFIGURATION. AND THEN THAT IS WHAT GOES TO SC. SO IT'S NOT BYPASSING SC, IT IS ALLOWING TRANSMISSION O OWNERS TO OPERATE, OPERATE THEIR GRID, CHOOSE WHAT TOPOLOGY IS GOING INTO SKID. SO WE'RE WE, YOU KNOW, HAVE A, HAVE A, UM, JUST WANTED TO, TO CLARIFY THAT, BUT WE DO APPRECIATE AND UNDERSTAND BRIAN'S POSITION. OKAY. ANYONE ELSE IN THE QUEUE BEFORE WE GO TO THE VOTE? AND COREY HAS IT PULLED UP. SO IT WOULD BE TO RECOMMEND APPROVAL OF NPR 1198 IS RECOMMENDED BY PRS IN THE FIVE NINE PRS REPORT TO RECOMMEND APPROVAL OF PIGGER ONE 13 IS RECOMMENDED BY ROSS IN THE FIVE TWO ROSS REPORT. AND TO RECOMMEND APPROVAL OF NOER 2 58 AS RECOMMENDED BY ROSS IN THE FIVE TWO ROSS REPORT. [00:15:01] Q LOOKS CLEAR. I THINK YOU CAN TAKE IT AWAY. CORY, I WOULD LOVE TO GET A MOTION ON A SECOND. OH, MOTION A SECOND WOULD BE GREAT. SORRY, I READ I ALSO BEAUTIFULLY, I, I'M, YEAH, WELL, YOU KNOW, THE BABY WAS SUPPOSED TO DO THAT PART. SO WE'RE GIVE WHO ARE WE GIVING THE MOTION TO? KEVIN HANSEN. AND SECOND TO BLAKE. ALL RIGHT. OKAY. ON THAT MOTION TO RECOMMEND APPROVAL OF 1198 AND FRIENDS, WE WILL START UP WITH THE CONSUMERS. WITH ERIC? YES. HUGH NA. YES. THANK YOU. THANK YOU. GARRETT. YES, SIR. THANK YOU, SIR. ERIC? YES. THANK YOU. AND RICK FOR MARK? YES. THANK YOU. AND THEN RICK FOR NICK? YES. THANK YOU. ONTO OUR CO-OPS. MIKE? YES. THANKS, BLAKE. YES. THANK YOU, ERIC. YES. THANK YOU. THANK YOU LUCAS, FOR JOHN. I SEE HE CAME OFF MUTE. LUCAS, BUT I DIDN'T HEAR YOUR VOTE. I CAN TAKE YOU IN CHAT. OH, I GOT YOU IN CHAD AS A YES. THANK YOU, LUCAS. ONTO OUR INDEPENDENT GENERATORS. BRIAN? YES. I'M SORRY. ABSTAIN. AND THANK YOU FOR, UH, BEARING WITH ME. GOTCHA. CHANGE, CHANGING, CHANGING YOUR MIND IS WHAT TAX'S ALL ABOUT. BRIAN, I APPRECIATE I MEANT, MEANT TO SAY YES. CA THANK YOU FOR, FOR LISTENING TO ME. I THINK HE WAS GONNA BE A YES ON THAT. AND, UH, ABSTAIN ON THE COMBO BALLOT. I HAD TO, I HAD TO DO IT. WORDS MATTER. BRIAN CA CAITLYN YOUR VOTE ABSTAIN, PLEASE. OKAY, THANK YOU. BOB HILTON? YES, SIR. THANK SIR NED? YES, SIR. THANK YOU. CORY AND IPMS REMI? YES. THANK YOU. JEREMY. YES. THANK YOU. THANK YOU. IAN? YES. THANK YOU, CORY. THANK YOU KEVIN. YES, THANK YOU. THANK YOU. ONTO OUR I REPS. BILL? YES. THANK YOU. JENNIFER. I'M NOT SURE IF JENNIFER'S WITH US YET. HOW ABOUT JAY? YES. THANKS SIR. CHRIS? YES. THANK YOU. UNDER IOUS, STACY FOR KEITH? YES. THANK YOU, DAVID. THANK YOU. SAME. THANK YOU IAIN FROM DAVID COLIN? YES. THANK YOU, RICHARD. YES. THANK YOU. ANDRA. MUNIS RUSSELL? YES. THANK YOU. JOSE? YES. THANK YOU, DAVID. YES. YES. THANK YOU. CORY, DID YOU CATCH THE CHANGE IN VOTE IN THE QUEUE FROM LUCAS? OH, OKAY. WE WILL MAKE THAT AN ABSTAIN. OKAY. MOTION CARRIES FOR ABSTENTIONS. OKAY. ANY QUESTIONS OR COMMENTS HERE? ALL RIGHT, DIANA. I THINK WE ARE BACK TO NPR 1218 REC PROGRAM CHANGES. OKAY, SO 1218 COMES TO US FROM ERCOT. THIS IS UPDATING THE, UH, SECTION 14 FOR THE REC TRADING PROGRAM TO BE COMPLIANT WITH THE SUBSTANTIVE RULES AT THE COMMISSION. IN APRIL. WE VOTED UNANIMOUSLY TO RECOMMEND APPROVAL AS AMENDED BY THE, UM, APRIL 4TH RELAYING COMMENTS. AND THEN ON MAY 9TH, WE VOTED UNANIMOUSLY TO ENDORSE AND FORWARD THE APRIL 5TH PRS REPORT WITH THE MARCH 5TH IA. WE ARE LOOKING FOR, UM, TO, TO RECOMME TO APPROVE NPRR 1218 IS RECOMMENDED BY THE BY PRS IN THE FIVE NINE PRS REPORT. DO WE NEED A SEPARATE BALLOT FOR THIS ONE OR CAN WE ADD IT TO THE COMBO BALLOT BILL? I DON'T BELIEVE THIS WAS CONTROVERSIAL AT ALL. AND WE, UM, GOT APPROVAL FROM ERCOT ON THE MODIFIED COMMENTS WE SUBMITTED. SO I'M HOPING THIS IS A COMBO BALLOT ITEM. I THINK THERE WERE A NUMBER OF ABSTENTIONS, SO JUST CHECKING NOT ON, NOT ON THIS ONE. ON 1218. NO, THIS ONE WAS UNANIMOUSLY ENDORSED. I THOUGHT I ABSTAINED ON THIS ONE. OKAY. UM, LET'S ADD IT TO THE COMBO BALLOT THEN. OKAY. I'M NOT GONNA CALL IT A BRIAN SAMS . [00:20:01] OKAY. WE WERE GOING TO TAKE THESE OUT OF ORDER KIND OF BASED ON LENGTH OF TIME THAT WE THINK THEY WILL TAKE TO DISCUSS. SO LET'S GO FIRST TO NPR 1230. OKAY. SO 1230 COMES TO US FROM ERCOT. THIS IS ESTABLISHING A SHADOW PRICE CAP FOR CONGESTION THAT IS IMPACTING AN EYE ROLL, UH, OR AN INTERCONNECTION RELIABILITY OPERATING LIMIT IN MAY. WE VOTED TO GRANT URGENT STATUS AND THERE WERE OPPOSING VOTES ON THAT. AND THEN WE VOTED TO RECOMMEND APPROVAL OF 1230 AS REVISED BY PRS WITH THE MAY 7TH IA. AND THERE WERE 12 ABSTENTIONS ON THAT BOAT. OKAY. ANY DISCUSSION ON NPR 1230? DAVID KEY? YEAH, WE HAD SOME CONCERNS WITH, I GUESS, THE SWIFTNESS AT THIS MOVE THROUGH THE PROCESS. UM, I THINK THERE WAS A TOTAL OF TWO DAYS GIVEN TO PRS TO REVIEW THIS. AND ALTHOUGH IT'S NOT SOMETHING NEW, IT IS A VERY IMPACTFUL CHANGE TO PRICING THAT IS, UH, GIVEN TO US WITH VERY LITTLE NOTICE TO, TO WORK THROUGH. UM, WE'RE, WE HAVE QUESTIONS, WE ARE HAVE SOME TIME SCHEDULED WITH TO WORK THROUGH THIS. UM, GONNA BE ASKING FOR SOME TIME TODAY, UH, FROM THIS GROUP FOR A TABLE. UM, REALLY THE PROCESS TO GET THIS CHANGED IS, UH, BEEN RUSHED. WE FEEL THAT WE NEED SOME MORE TIME TO WORK ON IT. SO WE MAKING A MOTION TO TABLE THAT. OKAY. I, I DON'T THINK WE NEED A MOTION TO TABLE. I THINK IT, WE DO NEED A MOTION 'CAUSE IT'S THE FIRST TIME IT'S BEEN HERE. OKAY. IS THERE A SECOND TO DAVID'S MOTION? SECOND. SECOND FROM ALICIA. ALL RIGHT. I SEE. ARE YOU IN THE QUEUE OTHER THAN THE SECOND? WOULD YOU LIKE TO SPEAK? WOW. . WELL, I HAVE YOUR NAME FIRST AND THEN I'LL GO TO ERIC AND NED. I'M JUST GONNA SECOND WHAT DAVID SAID, BASICALLY. OKAY. OKAY. UH, I SAID THAT REVERSED. I THINK. SO NED, THEN ERIC, THEN BRIAN. THANK YOU, CAITLIN. UM, CERTAINLY APPRECIATE THAT. THIS, UH, THIS CAME IN FORMALLY, UH, RELATIVELY RECENTLY. I CAN REMEMBER TALKING ABOUT THIS AND I, FRANKLY, I CAN'T REMEMBER WHICH SUBCOMMITTEE IT WAS IN, UH, BACK IN THE FALL. SO I, I KNOW THE CONCEPT HAS BEEN, UH, PERCOLATING AND HAS BEEN DISCUSSED BEFORE. IT DOES SEEM LIKE IT'S A VERY, YOU KNOW, ELEGANT SOLUTION TO TRY TO ALLOW SCED TO RESOLVE, UH, AN, AN AN ISSUE AND AVOID EMERGENCY CONDITIONS. SO, UM, YOU KNOW, WE'RE, WE ARE SUPPORT, UH, SUPPORTIVE OF THIS PROPOSAL. UM, BUT UNDERSTAND THAT THERE ARE, THERE ARE FOLKS THAT WANNA UNDERSTAND THAT WANT TO HAVE A LITTLE BIT MORE TIME TO REVIEW. AND I THINK WE CAN STILL GET TO THE JUNE BOARD EVEN WITH THAT TIME, GIVEN THAT WE HAVE ADDITIONAL, UM, ADDITIONAL AT BATS WITH TECH. OKAY. ERIC GUFF, IF WE WERE TO TABLE IT, UM, WE HAVE A, A FEW MEETINGS SCHEDULED. IS THIS SOMETHING, DAVID, THAT YOU'D WANNA SEE COME UP AT ONE OF THE MEETINGS TO GET IT TO THE JUNE BOARD? OR DO YOU, WOULD YOU PREFER IT TO BE TABLED FOR LONGER THAN THAT? I THINK AT THIS POINT WE PREFER TO BE TABLED LONGER THAN THAT. I'LL PROBABLY HAVE SOME BETTER INFORMATION AFTER WE MEET WITH ERCOT. UM, SO I MIGHT BE ABLE TO CHANGE, BUT AT THIS POINT, UM, REALLY LOOKING FOR MORE TIME JUST TO, TO WORK ON IT AND NOT OKAY. GIVEN THE DISCUSSION TODAY, WE'LL SEE HOW LONG IT TAKES TO GET TO, UH, TO ERCOT. SO THEN, I GUESS MY, MY QUESTION, UM, FOR ERCOT IS IF THIS IS NOT IMPLEMENTED, HOW WOULD IT IMPACT MANAGEMENT OF THIS IRRL THIS SUMMER? YEAH, FREDDY, WHY DON'T YOU RESPOND? SO FREDDY GARCIA OPERATIONS AND, AND I GUESS TO GIVE A LITTLE BIT MORE CONTEXT ON, ON WHY THE URGENT STATUSES TO HAVE IT IN FOR, FOR SUMMER AND, AND POTENTIAL TIGHT CONDITIONS AND TO GIVE THE CONTROL ROOM ADDITIONAL TOOLS TO MANAGE THE IOL. UM, IF WE DON'T PUT THIS IN BY THE SUMMER, WE'RE JUST GONNA CONTINUE WITH WHAT WE'VE BEEN DOING LAST SUMMER, IS DOING HDL OVERRIDES THAT, THAT'S THE ALTERNATIVE WE HAVE. AND, AND BASED ON LAST SUMMER CONDITIONS, UH, WE PRETTY MUCH EXPECT THAT WE WILL HAVE TO DO THAT, UM, AS CONDITIONS GET TIGHT. SO HDO OVERRIDES WILL RESULT IN AN UPLIFT, UM, WHEREAS DOING THE SHADOW PRICE CAP WOULD BE, IF PEOPLE ARE HEDGED FOR ENERGY, THEN THEY'D BE HEDGED FOR THE COST OF THE SHADOW PRICE CAP. SO THE SHADOW [00:25:01] PRICE CAP IS CHANGING. I, I CAN'T HEAR YOU. I I WOULD JUST SAY MANY OF US HAVE NOT HEDGED FOR THE SHADOW PRICE CAP CHANGE. OKAY. AND THAT GOES BACK TO THE NOTICE ISSUE THAT WE ARE, YOU'RE TALKING ABOUT, WE HAVE TALKED ABOUT THIS, BUT IT WASN'T PUT FORTH UNTIL, YOU KNOW, TWO DAYS BEFORE PRS MEETING. SO THAT'S THE CONCERN WE HAVE. OKAY. BRIAN SAMS YEAH, I, I AGREE TIMING IS AN ISSUE ON THIS. UH, YOU KNOW, WE DID SEE THAT TWO DAYS BEFORE PRS, UM, MY SHOP REACHED OUT TO ERCOT, AND I REALLY DO APPRECIATE THE TIME ERCOT GAVE TO US, UM, TO JUST HELP US UNDERSTAND IT A LITTLE BIT BETTER. UM, WE ALSO THOUGHT THAT THERE COULD BE SOME OTHER SOLUTIONS BEYOND JUST THE HDL OVERRIDE THAT FREDDIE MENTIONED, UH, INCLUDING, UM, MANAGING SOME OF THE EXISTING GTCS THAT WE ALREADY HAVE, UH, A LITTLE BIT BETTER. UM, AND I CAN GET INTO SOME OF THE DETAILS AROUND THAT OR, OR NOT, BUT, UM, WE, WE WOULD SUPPORT JUST UNDERSTANDING THIS BETTER. THANK YOU. OKAY. DID YOU WANNA GET INTO MORE DETAILS? ALL RIGHT. SO I'M GONNA BE READING THE NOTES HERE THAT I HAVE FOR MY TRANSMISSION DESK, BUT BASICALLY THERE ARE THREE GTCS, THIS NELSON TO SHARP RIO HONDA, THE RAYMONDVILLE, RIO HONDO NORTH EDINBURGH TO LOBO GTCS THAT ARE EXISTING THAT WE'VE SEEN SUCCESSFULLY MANAGE RELIABILITY AND A LOWER LIMIT ON ANY OR ALL OF THOSE CAN HELP CONTROL THE, THE SOUTH TEXAS, UH, POWER FLOWS. AND SO, UH, THAT'S, THAT'S ANOTHER WAY TO HELP. GREAT. THANK YOU. FREDDY, DID YOU HAVE ANOTHER COMMENT? UH, I GUESS JUST TO UNDERSTAND THAT A LITTLE BIT MORE, BRIAN, THAT'S, WE'D BE ARTIFICIALLY DE-RATING THOSE GTCS TO MANAGE A DIFFERENT GTC. IS THAT, IS THAT ESSENTIALLY WHAT I'M HEARING? I DON'T KNOW ABOUT YOUR CHARACTERIZATION OF ARTIFICIALLY, UM, BUT IT, THAT IT WOULD BE LOWERING THOSE LIMITS TO HELP WITH THE, UM, THE SOUTH TEXAS GTC. I MEAN, JUST THINKING ABOUT THAT, IT JUST SEEMS LIKE THAT MIGHT BE SOMETHING ALSO DIFFICULT TO HEDGE AGAINST AS WELL. UM, WHERE IF, IF WE'VE ESTABLISHED THE SHADOW PRICE CAP, WE KNOW WHAT, WHAT'S GONNA HAPPEN, WHAT, WHAT THE PRICES COULD GO TO. I DO UNDERSTAND THAT IT, IT IS SHORT NOTICE, BUT IT, I FEEL LIKE IT'S SOMETHING THAT'S A LITTLE BIT MORE FIRM AND PREDICTABLE ONCE IT'S ESTABLISHED SMI. UH, SO WE DO SUPPORT, UH, THE DIRECTION THIS IS GOING WHERE, UH, WE ARE TRYING TO SOLVE THE PROBLEM THROUGH SCARED. ONE CONCERN I HAVE IS, UH, THE GRAY BOOKS THAT WAS ADDED, THAT'S A GOOD ADDITION, BUT IT SAYS IT'S EFFECTIVE FROM DECEMBER 1ST. UM, SO THE CONCERN THAT I HAVE IS, UH, OR WE HAVE IS LIKE WE ESTABLISH A MAX SHADOW PRICE NOW, AND THEN, UH, IN THE MIDDLE OF THE SUMMER IT CHANGES. SO CAN WE CHANGE IT TO SOMETHING LIKE, GIVE US 30 DAYS FROM AUGUST 1ST OR SOMETHING. SO ONCE YOU ESTABLISH IT IN JUNE OR JULY, AND THEN, UM, MARKET HAS ENOUGH NOTICE IF SOMETHING NEEDS TO BE CHANGED. AND NOTICE IS VERY IMPORTANT, AS EVERYONE HAS ALLUDED TO, UH, WITH THE NEED FOR HEDGING AND MARKETS UNITY. THIS IS VERY, AGAIN, I THINK I, I'M, I'M AMENABLE TO THAT. I THINK THAT WAS THE INTENT. UM, BUT I DON'T HAVE ANY HEARTBURN WITH THAT, THAT CHANGE. OKAY. THANK YOU. BOB HILTON? YEAH, I'M NOT SURE ABOUT PUSHING THIS OFF TOO FAR. UH, FIRST OF ALL, DE-RATING THE SYSTEM DOESN'T WORK. I MEAN, ALL THAT'S DOING IS WE'RE SUPPOSED TO BE USING THE TRANSMISSION SYSTEM TO THE EXTENT WE CAN AND, AND USING IT IN AN EFFICIENT MANNER. I DON'T THINK DE-RATING IS DOING THAT. I THINK THAT'S DOING THE OPPOSITE. SO JUST WANTED TO BRING THAT OUT. UH, THE SECOND PIECE IS I WOULD GO AHEAD AND MAKE A MOTION THAT WE TABLE THIS UNTIL WHEN IS OUR SECOND MEETING? YOU DON'T WANNA DO THAT. I, I'M NOT SUPER OPEN TO THE JULY. ARE YOU TALKING, WE, SO WE HAVE JUNE MEETINGS. I WANNA GET IT TO THE NEXT BOARD MEETING. SO WHAT I WAS LOOKING FOR, WE CAN MOVE IT TO THE NEXT ONE WE HAVE IF WOULD BE, WE HAVE A TECH MEETING, MAY 31ST, AND WE HAVE A TECH MEETING JUNE 7TH. MM-HMM. IF NEEDED. AND IDEALLY WE WOULD NOT NEED THAT'S, I THOUGHT IT WAS ALREADY BE JUNE 7TH MEETING. ALRIGHT, SO I'LL, I'D SAY LET'S TABLE IT TILL THE 31ST AND SEE WHAT WE WANT. OKAY. THAT IS NINE [00:30:01] DAYS FROM NOW. YEAH. SO DOES THAT GIVE SOMEBODY US TIME? GIVE YOU, THAT PUTS SOME MOVEMENT IN THERE, . IT HELPS, BUT IT'S NOT A WHOLE LOT OF TIME. THERE'S, OKAY. NO, THAT'S THE ISSUE. OKAY. SO WE, WE HAVE THE MOTION AND TABLE ALREADY. UM, BOB, ARE YOU WITH THAT? ARE YOU DONE WITH YOUR COMMENTS? YES. OKAY. UH, DAN WOODFIN. SO AMAZINGLY WHAT BOB SAID WAS EXACTLY WHAT I WAS GONNA SAY, ALMOST ONE. THIS IS A MORE EFFICIENT SOLUTION THAN, THAN OVERRIDES. IT ALLOWS SCED TO DO, TO BRIAN'S POINT, WHILE IT, IT ALLOWS SCED TO DO WHAT SCDS DESIGNED TO DO AND DO IT EFFICIENTLY. UM, IF WE CAN GO AHEAD AND TRY TO GET IT TO THE BOARD BY JUNE, THAT WOULD BE REALLY HELPFUL SO THAT WE CAN ACTUALLY HAVE IT IN PLACE FOR MOST OF THE SUMMER. UM, AND USE, USE THE TOOLS FOR WHAT THEY'RE INTENDED TO DO. DAN, COULD YOU WRITE THAT DOWN THAT WE AGREED YEAH. FOR LATER TODAY. . OKAY. SETH. SETH, ARE YOU THERE? ERIC, DO YOU WANNA SPEAK WHILE WE FIND SETH? SURE. UM, I THINK I WOULD, WOULD, UM, VOTE NO ON A GENERAL MOTION TO TABLE, BUT YES, ON A MOTION TO TABLE TO THE 31ST. IF AT THE 31ST MEETING YOU'RE STILL NOT SATISFIED, AND THEN AT THE MEETING WITH ERCOT, UM, THEN WE CAN ALWAYS KEEP IT TABLED. UH, WE WOULDN'T NEED A NEW MOTION TO KEEP IT TABLED, I THINK. WOULD THAT RIGHT? I SEE COREY SHAKING HIS HEAD THAT WHAT YOU JUST SAID IS WHY WE DON'T PUT AN EXPIRATION DATE ON THE MOTION TO TABLE. SO BY SAYING YOU'RE OKAY WITH TABLING IT TODAY. YEAH. BUT BECAUSE YOU'RE ON THE MAY 31ST MEETING, YOU WANT MAKE SURE THAT 1230 AGENDA IS AT LEAST LISTED ON THE AGENDA FOR A VOTE. I THINK THAT'S SOMETHING THAT CAN WE DO THAT VERBALLY? TACK LEADERSHIP CAN AGREE TO SAY AS MUCH AS YOU MIGHT BE TRYING TO SLIM DOWN THE MOTION, THE AGENDA FOR 5 31 TO ONLY FOCUS ON NORE 2 45 THINGS LIKE THIS, THAT IF WE WANTED TO SLIDE THOSE ON AS LONG AS THEY'RE LISTED ON THE AGENDA, THEN EXACTLY WHAT YOU JUST SAID, ERIC, IF SOMEBODY WANTS TO MAKE A MOTION, THEY CAN, IF THEY WANNA LEAVE A TABLED, THEY CAN, BUT IT WOULD AT LEAST BE PROPERLY NOTICED FOR A VOTE ON MAY 31ST. OKAY. WE'RE, WE'RE FINE WITH HAVING THAT ON THE MAY 31ST AGENDA. OKAY. THANK YOU. BUT WE'RE NOT, I'M NOT COMMITTING TO THE JUNE 7TH AGENDA. SOUNDS GOOD. I APPRECIATE THAT. OKAY. WE FOUND SETH. SETH, DO YOU WANNA SPEAK YOUR QUESTION, PHONE ISSUE? DO WE KNOW THE SPC VALUES UNDER THIS NPRR FOR EACH ROL FREDDY? DO YOU HAVE AN ANSWER FOR THAT? OR, OR SORRY, WHAT WAS THAT MISSED THAT IT'S IN, IT'S IN THE CHAT. I DON'T THINK YOU CAN SEE IT CAN'T. OH, SORRY. DO WE, DO WE KNOW THE SPC VALUES UNDER THIS NPRR FOR EACH IROL? SO, SO, UM, I DID FILE SOME COMMENTS JUST TO CLARIFY, BASED ON SOME FEEDBACK FROM PRS THAT THE SHADOW PRICE CAP INCREASE WOULD ONLY APPLY TO IOLS IF NEEDED AS NEEDED. SO IT WOULDN'T BE FOR ALL IOLS, IT WOULD JUST BE ON A AS NEEDED BASIS. UM, THE CALCULATED, UH, SHADOW PRICE THAT WE'RE ANTICIPATING IS IN 19,721, I THINK IS, IS WHAT WE'VE CALCULATED. UM, BUT THAT, THAT'S WHAT WE'RE ANTICIPATING. OKAY. IT, THAT WOULD BE ONLY FOR THE SOUTH TEXAS EXPORT IOLS. OKAY. AND THE REMAINING IOLS WOULD, WOULD CONTINUE TO USE THE CURRENT, UM, UH, GENERIC TRANSMISSION, UH, PRICE CAP FOR BASE CASE CONSTRAINTS. ALRIGHT. DAVID KEY? YEAH, I THINK YOU, YOU JUST SAID THAT THIS IS ONLY GONNA BE FOR THE SOUTH TEXAS GTCS, BUT YOU COULD CHANGE THAT. OR DID I MISUNDERSTAND THAT? YES, THIS LANGUAGE WOULD, WOULD GIVE US THE ABILITY TO EVALUATE IT IF WE NEED TO. AND IT'S, THERE'S A PERIODIC EVALUATION ON AN ANNUAL BASIS AS WELL. ON AN ANNUAL BASIS. AND THEN HOW MUCH NOTICE WILL WE GET ONCE YOU'VE MADE THE DECISION TO CHANGE? NO, THAT LANGUAGE RIGHT THERE, WHAT RES WAS REFERRING TO EARLIER WAS A 30 DAY NOTICE PRIOR [00:35:01] TO BECOMING EFFECTIVE. RIGHT. OKAY. THANKS. SO YOU WILL CHANGE IT, RIGHT? UH, CAN I ASK A QUESTION? SURE, GO AHEAD. SMI. SO YOU WILL CHANGE IT FROM DECEMBER TO AUGUST OR ON EFFECTIVE OR WHICHEVER, WHAT WILL YOU CHANGE IT TO? I MEAN, I, I'M OKAY WITH THAT. IF WE WANT TO DO SOME DESKTOP EDITS TO THESE COMMENTS. I'M, I'M UNCOMFORTABLE. WELL, WE HAVE A MOTION TO TABLE. YEAH, WE'RE JUST TABLING IT SO IT WON'T MATTER. WE JUST REMIND FREDDY WE ADDED THIS IN BECAUSE ON THE TIMELINE IT'S ON RIGHT NOW, IF THE BOARD APPROVES IT IN JUNE, IT WOULD GO TO THE PUC IN JULY. THE LANGUAGE WOULD TAKE EFFECT AUGUST 1ST. AND WE HAD SAID, WELL, IF IT TAKES EFFECT AUGUST 1ST, I CAN'T REALLY GIVE YOU 30 DAYS NOTICE TO DO SOMETHING THIS SUMMER, BECAUSE I'M ALREADY ON AUGUST 1ST. SO WE WANTED TO SAY THE 30 DAY COUNTDOWN WOULD START SOMETIME AFTER THIS SUMMER TO M'S POINT. IF WE JUST STARTED IMMEDIATELY ON AUGUST 1ST, WE'RE JUST SAYING WE DON'T NEED THIS GRAY BOX. WE CAN JUST SAY YOU'LL ALWAYS GET 30 DAYS AND WE DON'T NEED ANY, WE DON'T NEED ANY SHORT-TERM RELIEF THIS SUMMER ON A TIGHTER TIMELINE THAT WE WOULD BE FINE WITH 30 DAYS WHENEVER. SO WE CAN ULTIMATELY DO DESKTOP EDITS OR COMMENTS. BUT FOR RIGHT NOW, CAITLIN'S RIGHT, THE MOTION IS JUST A TABLE, SO WE DON'T HAVE TO EDIT ANYTHING TODAY. SO JUST TO CLARIFY, ONCE THIS LANGUAGE IS EFFECTIVE, WE ARE ABLE TO UPDATE THAT SHADOW PRICE CAP, AND THEN ANYTHING AFTER THAT WOULD REQUIRE 30 DAY NOTICE IF, AS IT'S DRAFTED RIGHT NOW. OKAY. RE'S POINT IS, IF WE PULL THIS BACK FROM DECEMBER TO BE AUGUST 1ST, THEN THAT MEANS IMMEDIATELY ON AUGUST 1ST. THIS IS THE LANGUAGE THAT YOU'RE BOUND BY AND NOT THIS LANGUAGE ABOVE. NO, NO, NO. YEAH. AND THAT'S NOT, NO, NO, NO, NO. UH, I THINK THERE IS A POTENT, SORRY, CAITLIN, CAN I SAY, UH, I THINK THERE IS A POTENTIAL THAT PUCT WILL, UM, WAIVE THE NOTICE. SO IT CAN GO EFFECTIVE JUNE OR JULY 1ST OR SOMETHING. JULY 1ST. AND SO I'M NOT SAYING YOU CAN'T CHANGE ANYTHING IMMEDIATELY. I'M SAYING ONCE YOU CHANGE SOMETHING, DON'T CHANGE IT THE NEXT DAY OR LIKE IN A WEEK. YEAH. SO, SO JUST TO BE SAFE COULD SEPTEMBER 1ST. OKAY. UH, THEN THE SUMMER WILL BE OVER, SO YEAH. YEAH. SO MAYBE SOMETHING LIKE 30 DAYS AFTER THE FIRST THING. AUGUST 2ND. YEAH, YEAH. SOMETHING LIKE THAT. YEAH. OKAY. DAVID KEY. YEAH, I THINK YOU'VE, I THINK RAISED ME, RAISED THE POINT THAT I WAS GONNA MAKE AND I WAS GONNA BE, UH, BASICALLY SAYING WE THINK IT'S, WE THINK IT'S AUGUST, BUT THERE COULD BE A POTENTIAL THAT THE COMMISSION COULD WANT THIS IN SOONER. UM, SO I'M SYMPATHETIC TO THAT. I I, I DO RECOGNIZE THE VALUE HERE, BUT I ALSO DO, UM, STILL HAVE ISSUES WITH THE, THE VERY DRASTIC CHANGE. SO, UH, JUST BE, UM, YEAH, THE CHALLENGE STILL IS, UH, I DON'T WANNA SAY POOR PLANNING, BUT, YOU KNOW, THE LACK, THE LACK OF ABILITY TO BRING THIS IN SOONER, HAVE IT TALK THROUGH AND SAY, THIS IS A CHANGE WE'RE GONNA BE DOING. UM, THAT THAT'S REALLY OUR ISSUE. I THINK THE OTHER THING THAT I WANTED TO MA MAKE A, A FRIENDLY REQUEST, AND WE CAN TALK ABOUT THIS OFFLINE, BUT, UM, IN, IN ADDITION TO NOTICE, UH, THE STAKEHOLDER PROCESS IS PRETTY VALUABLE FOR ASKING QUESTIONS AND GAINING, UM, GAINING SUPPORT BEFORE WE MAKE CHANGES. SO AS, AS PART OF THE 30 DAYS NOTICE IN THE FUTURE, MAYBE WE COULD ASK THAT, UH, THIS BE TAKEN TO, UH, A WORKING GROUP OR SUBCOMMITTEE JUST FOR REVIEW. LIKE, HERE'S WHAT WE'RE GONNA DO AND THEN THE CHANGES THAT ARE COMING UP, GIVE, GIVE, GIVE US SOME, SOME WAY TO UNDERSTAND IT AND KINDA GIVE US A LITTLE, LITTLE HEADS UP AS THE MARKET AS A WHOLE. I DON'T NEED IT PERSONALLY, JUST, YOU KNOW, EVERYBODY NEEDS TO HAVE THAT VISIBILITY. SO JUST A GENERAL PRACTICE TO GO AHEAD AND, AND REVIEW THE CHANGE WITH CMWG OR SOME GROUP TO, TO GIVE EVERYONE A HEAD A HEADS UP THAT RIGHT. MORE NOTICE, THE BETTER. THIS IS WHAT WE'RE THINKING. OUR, OUR ISSUE IS, IS THE, IS THE HEDGING AROUND AND BEING PREPARED AND UNDERSTANDING THESE CHANGES. AND THEN THE MORE NOTICE WE HAVE, THE BETTER FOR EVERYBODY. I MEAN, SURE. OKAY. NED, I WAS GONNA SAY PRETTY MUCH THE, THE SAME THING THAT, THAT REMI AND DAVID BROUGHT UP, WHICH IS IF THE, I DON'T WANNA PRESUME WHAT THE COMMISSION WILL DO, BUT IF THEY DO WAIVE THE 30 DAYS, THEN THEY COULD COME UP SOONER. SO INSTEAD OF ANCHORING TO A HARD DATE, IT MIGHT BE BETTER TO, TO ANCHOR TO PUC APPROVAL. UM, BUT I, I AGREE, IT'S, UH, IT'S A FINE BALANCE TO STRIKE. THIS IS, I MEAN, IT'S A, IT'S A TOOL TO ENHANCE RELIABLE OPERATIONS. IT'S A, IT'S A KNOWN ISSUE THAT WE RAN INTO LAST YEAR, SO, UM, AND WE CLEARLY ANTICIPATE THAT THAT'S GONNA CONTINUE INTO THIS YEAR. SO IT'S A GOOD TOOL TO HAVE, UM, THEN STRIKING A, A DECENT BALANCE IS WHAT WE HAVE TO DO. OKAY. THANK YOU. SETH. IS YOUR PHONE WORKING NOW? YEAH, I THINK SO. UM, SO I JUST HAVE A QUICK, ANOTHER QUICK QUESTION. UM, IS THERE KIND GONNA FOLLOW THIS METHODOLOGY STRICTLY, OR IS IT STILL LIKE UP TO DISCRETION? SO IF YOU FIND THAT, UM, YOU COULD, IN FACT UNDER THIS CALCULUS THAT YOU HAVE HERE, RAISE THE SHADOW PRICE CAP, DOES THAT MEAN THAT YOU'LL DEFINITELY [00:40:01] DO IT? OR IS THERE DISCRETION IN ITS APPLICATION ITSELF? YEAH, I, I MEAN, I GUESS THE, THE LANGUAGE IS PRETTY CLEAR IN THE NPRR, THIS IS THE METHOD THAT WE WILL USE. I, I DON'T KNOW IF THERE'S MUCH ROOM FOR, FOR VARIANCE THERE. IT'S PRETTY STRICT IN THE PARAGRAPH THERE. DAVE, DID YOU WANNA ADD? OKAY, SO IN OTHER WORDS, OH, SORRY, GO AHEAD SETH. I WAS GONNA SAY, SO IN OTHER WORDS, WHEN YOU SEE A CONSTRAINT, AN IRL THAT UM, WOULD BE VIOLATED, BUT FOR BEING ABLE TO RAISE A SHADOW PRICE CAP, UM, YOU'RE GOING TO GO AHEAD AND DO THAT. I THINK WE WOULD EVALUATE IT AND SEE IF, IF IT PROVIDES ANY BENEFIT TO DO SO. UM, AND IF IT DOES, UH, GIVE SKID ADDITIONAL LEVERAGE TO MANAGE THE CONSTRAINT, I THINK WE WOULD. OKAY. IS THERE ANY CAP TO THIS? SO IN THEORY, IF YOU HAVE THE LOWEST LEVERAGE, UH, SHIFT FACTOR AND YOU HAVE, UH, IN YOUR, THAT THEIR OFFERING AT THE CAP, UM, YOU COULD HAVE A, WHAT, A $50,000 SHADOW PRICE CAP. IS THERE ANY, IS THERE ANY HARD CAP ON THIS? SO THAT, THAT'S WHAT WE WERE TRYING TO DO BY REFERENCING THE FREQUENCY BIAS IS WE'RE NOT GONNA GO ALL THE WAY TO A 1% SHIFT FACTOR. THAT WOULD BE A, A HUGE, UH, SHADOW PRICE CAP. BUT WE'RE, WE'RE TRYING TO DRAW A LINE IN THE SAND. THIS IS, IS THIS IS HOW MANY MEGAWATTS CORRESPONDING TO SHIFT FACTOR WE'RE WILLING TO CONSIDER FOR THAT CALCULATION. AND IT'S ROUGHLY 900 MEGAWATTS. SO THAT THAT, THAT GIVES SOMEWHAT OF A, A, A LIMIT. OKAY. I, I'LL HAVE TO THINK ABOUT THAT. UM, SURE. BUT I THANK YOU FOR THE RESPONSE. AND CAITLIN, I GUESS IF I CAN JUST ADD TO THAT, EVERYTHING FREDDY SAID WAS CORRECT. I THINK IT'S KIND OF THE, WE DO THIS SIMILAR FOR THE IRRESOLVABLE IN SCED CONCEPT. OBVIOUSLY THAT'S THE, THE LOWERING OF SHADOW PRICE CAP, BUT THERE'S WHAT PUTS SOME GUARDRAILS AROUND THAT IS SOME SHIFT FACTOR CUTOFFS THAT, THAT DRIVE THAT. I GUESS THE ONE THING I WANTED TO MAKE CLEAR, I THINK IT'S RELATED TO ETH QUESTION, IS AROUND JUST FUNCTIONALLY, ONCE WE CHANGE THE SHADOW PRICE CAP IN THE SYSTEM, THAT'S THE VALUE WE'RE USING. SO THERE'S NOTHING IN THE SYSTEM THAT WOULD ALLOW IT TO SWITCH BACK AND FORTH ON, YOU KNOW, DEPENDING ON HOW WELL IT'S RESOLVING. SO HOPEFULLY THAT'S, UH, HELPFUL AS WELL IS JUST UNDERSTANDING THE FUNCTIONALITY. SO IT WOULD REMAIN AT THAT NUMBER AND, AND SCED WOULD USE IT UNTIL THERE WAS THE, THE NOTICE TO CHANGE IT WITH THE, THE 30 DAYS THAT, THAT WE'VE BEEN TALKING ABOUT. OKAY. THANK YOU. SMI. UM, SO IF I UNDERSTAND CORRECTLY, THERE IS IN THIS CALCULATION A SHIFT FACTOR CUTOFF, RIGHT? AND THAT'S 0.01. SO, UH, IT MAY BE EASIER. THERE, THERE IS A PRESENTATION POSTED TO THE VR SITE AND THAT GOES THROUGH THAT PROCESS. YEAH, BUT THAT ONE IS BASED ON A MEGAWATT AND THERE WAS NO SHIFT FACTOR CUTOFF AT THAT. IT, IT'S THE, AT THAT, THE, SOME OF THE HSLS FOR ALL THE UNITS FOR THE TOP SHIFT FACTORS, THE UNIT THAT WHERE YOU SUM UP TO 900 MEGAWATTS, WHAT'S THE CORRESPONDING SHIFT FACTOR? AND THAT'S YOUR SHIFT FACTOR CUTOFF. YEAH. SO THAT IS NOT A SHIFT FACTOR CUTOFF, RIGHT? THAT IS JUST A, WHATEVER IT COMES UP TO. WHAT I'M SAYING IS MAYBE TO MAKE IT EASIER FOR EVERYONE AND TO, UM, ENSURE THAT THE PRICES DON'T GO LIKE HUMONGOUS HAYWIRE, MAYBE WE SHOULD PUT A SHIP FACTOR CUT OFF IN THIS CALCULATION. I KNOW THERE IS NO SHIP FACTOR CUTOFF IN INSTEAD, BUT WHATEVER IS THE SHIP FACTOR CUTOFF, MAYBE 0.01 OR WHATEVER, SOMETHING YEAH. THAT'S SOMETHING THAT WE CAN, WE CAN CONSIDER. YEAH. OTHERWISE THE CALCULATION CAN GO REALLY, REALLY HIGH. VERY SETH. YEAH. DOES THIS WHOLE THING OVERRIDE THE IRRESOLVABLE THRESHOLD? SO IF YOU SEE A SHOWER PRICE CAP GET UP THERE, YOU KNOW, LIKE THIS 20 K VALUE, YOU COULD VERY EASILY ACCRUE SOME CONGESTION RENTS THAT WILL HIT THAT IRRESOLVABLE THRESHOLD FAIRLY FAST. SO DOES THIS STILL, IS THIS STILL BEHOLDEN TO THAT? THIS IS DAVE. I I CAN TAKE THAT ONE. THE, I CAN GO BACK AND LOOK AT THE LANGUAGE. I DO NOT THINK, UH, IN THE LANGUAGE TODAY, THERE'S ANYTHING [00:45:01] EXPLICITLY THAT WOULD SAY THAT THE IRRESOLVABLE SCED PROCESS DOES NOT APPLY. SO, SO PERHAPS THAT'S SOMETHING AGAIN, WE CAN COME BACK AND IF THIS DOESN'T MOVE FORWARD TODAY, WE CAN, WE CAN TALK ABOUT THAT AT THE, THE NEXT TECH MEETING. OKAY. I'M NOT TAKING A POSITION ON THAT NECESSARILY. I'M JUST, I'M JUST TRYING TO FIGURE IT OUT. UM, BUT I THINK THAT THAT SHOULD BE CLARIFIED. YEAH, FAIR ENOUGH. AND I GUESS JUST FOR, FOR FOR CLARITY, THERE'S HOW THAT WORKS. THERE'S A FIRST CRITERIA THAT'S SIMPLY A FUNCTION OF THE AMOUNT OF TIME IN RECENT HISTORY THAT THE CONSTRAINT HAS BEEN AT THE SHADOW PRICE CAP. THAT'S SORT OF THE FIRST LAYER IN WHICH THERE'S A, A POTENTIAL LOWERING OF THE SHADOW PRICE CAP. BUT, BUT EVEN UNDER THAT FIRST CRITERIA, THE NEW VALUE CAN BE ANYWHERE BETWEEN THE CURRENT CAP AND $2,000 PER MEGAWATT HOUR. THERE IS THEN A SECOND TRIGGER RELATED TO A, A NET MARGIN CALCULATION THAT DOES LOOK AT AN ACCRUAL OF CONGESTION RENT. AND, AND THAT'S A, A SECOND LOWERING. AND, AND IT SOUNDS LIKE, UH, IN PARTICULAR, THAT MAY BE THE MORE CONCERNING ONE, SETH. WELL, WELL, YOU, I MEAN, YOU'RE RIGHT. IF, IF YOU'RE RAISING THESE SOUTH PRICE CAPS, IT MAY NEVER BE IRRESOLVABLE BECAUSE THAT'S THE WHOLE POINT. UM, SO MAYBE IT NEVER EVEN GETS IN THROUGH THE GATE. UM, BUT YEAH, THAT, THAT'S JUST THE THINGS I'M THINKING ABOUT IT. IF, IF THESE, THESE I LS WOULD STILL BE SUBJECT TO THE, THAT WHOLE METHODOLOGY. YEP. YEAH. I MEAN, IT CERTAINLY FEELS LIKE IT COULD DEFEAT THE POINT RIGHT. OF WHAT WE'RE TALKING ABOUT HERE. OKAY. ALL RIGHT. ANY FURTHER DISCUSSION ON 1230? SO DO WE NEED A SEPARATE BALLOT FOR THIS ONE? OKAY, GO AHEAD, COREY. ALL RIGHT. I'M JUST DOUBLE CHECKING WITH SUSIE. WE, WE GOT OUR MOVER AND SECONDER RECORDED FROM THE START OF ALL THIS. I THINK WE DID, BUT DAVID AND ALICIA? YEP. OKAY. ON THE MOTION TO TABLE NPR 1230, WE WILL START OFF WITH CONSUMERS. WITH ERIC. YES. THANK YOU. NARAJ? YES. THANK YOU, GARRETT. YES, SIR. THANK YOU, ERIC. YES, THANK YOU, UH, RICK FOR MARK? YES. THANK YOU RICK FOR NICK. YES. THANK YOU. ONTO OUR CO-OPS. MIKE? YES. THANK YOU, BLAKE. YES. THANK YOU, ERIC. YES, THANK YOU. THANK YOU LUCAS FOR JOHN? YES, THANK YOU. THANK YOU. ONTO OUR INDEPENDENT GENERATORS. BRIAN? YES, OFFICIALLY. THANK YOU. UM, MS. AND CAITLIN. BOB HILTON? YES, SIR. SIR NED ABSTAIN. OOPS. THANK YOU FOR JUSTIFYING THE SEPARATE BALLOT ONTO THE IPMS RASHMI, UH, I HAVE A QUESTION. SO, IS IT JUST A PLAIN TABLE OR PLAIN TABLE, OR TABLE UNTIL THE NEXT STACK MEETING? EVERY TABLE IS A TABLE UNTIL THE NEXT TAC MEETING. SO YES, THIS IS JUST A TABLE IT. AND THEN NOW EVERY TAC MEETING FROM HERE ON OUT HAS THE OPTION OF LISTING THIS ON THE AGENDA FOR A VOTE, IN WHICH CASE IT CAN BE TAKEN UP AT. AND WE, THAT TIME WE GOT CONFIRMATION FROM THE CHAIR AND VICE CHAIR THAT IT'LL BE ON THE 31ST MEETING, WHICH IS WHY I VOTED YES. THE TABLE. OKAY. OKAY. YES. OKAY. JEREMY? YES. THANK YOU. THANK YOU. IAN? YES. THANK YOU, KEVIN. YES, THANK YOU. OKAY. ONTO THE I REPS BILL? YES. THANK YOU, JENNIFER. WE GOT JENNIFER. HOW ABOUT JAY? YES, THANK YOU, CHRIS. YES, THANK YOU. ONTO THE IOUS. STACY FOR KEITH? YES. THANK YOU, DAVID. YES, THANK YOU, COLIN. YES, THANK YOU, RICHARD. YES, THANK YOU. AND OUR MUNIS, RUSSELL. YES. THANK YOU, JOSE. YES. THANK YOU, DAVID. YES. THANK YOU, ALICIA. YES, THANK YOU. MOTION CARRIES ONE ABSTENTION. THANK YOU CO. DIANA, WE'RE GONNA MOVE BACK TO THE PRS REPORT AND MOVE ON TO 1224. OKAY. OKAY. ONE MORE. UH, 1224 COMES TO US FROM ERCOT. THIS IS INTRODUCING A TRIGGER THAT ERCOT CAN USE TO MANUALLY RELEASE ECRS FROM SC. ALSO REQUIRES AN ENERGY OFFER CURVE FOR THE CAPACITY ASSIGNED TO ECRS AT NO LESS THAN A THOUSAND DOLLARS PER MEGAWATT HOUR ON APRIL 5TH, PRS VOTED TO GRANT, UH, 1224 URGENT STATUS. THERE WERE TWO OPPOSING VOTES ON THAT VOTE. UM, ON, [00:50:01] LET'S SEE, WE THEN VOTED TO TABLE IT, AND THERE WERE THREE ABSTENTIONS ON THAT TABLE. AND THEN EARLIER IN THIS MONTH, ON MAY 9TH, WE VOTED TO RECOMMEND APPROVAL OF 1224 AS AMENDED BY THE APRIL 30TH TCPA COMMENTS AS REVISED BY ERCOT. THERE WERE FIVE OPPOSING VOTES AND SIX ABSTENTIONS ON THAT VOTE. THANKS, DIANA. NED IS FIRST IN THE QUEUE. THANK YOU, CAITLIN. UM, I FIGURED I'D PROBABLY DO A STRAW POLL AND SEE IF WE CAN, UH, PUT THIS ON THE COMBO BELT WITH THE PRS COMMENTS. LAUGHTER IS A, IS AGREEMENT. NO, UM, I, YOU KNOW, I I, I'M HAPPY TO WALK THROUGH SOME OF THE JOINT COMMENTERS COMMENTS, UM, ON BEHALF OF TCPA AND OTHERS, IF THAT'S, IF THAT'S HELPFUL. UM, YOU KNOW, I THINK, I THINK WITH THIS, WE'VE REALLY GOT, UM, YOU KNOW, CASE OF, YOU KNOW, REASONABLE MINDS WILL DIFFER. AND WE, IT'S A TOUGH PROBLEM WHERE WE'RE TRYING TO BRIDGE TWO WORLDS. UM, WE'RE TRYING, YOU KNOW, WE WE'RE, WE'RE LOOKING AT A, A PRODUCT THAT WAS ORIGINALLY INTENDED TO GO LIVE WITH REALTIME CO OPTIMIZATION, ENDED UP GOING LIVE AHEAD OF REALTIME CO OPTIMIZATION. UM, YOU'VE GOT A LOT OF FOLKS THAT ARE, UH, I THINK THINKING ABOUT, UH, YOU KNOW, THE EXTREME HEAT AND, UH, SCARCITY THAT WE HAD LAST SUMMER AND, AND, YOU KNOW, REACTING TO THAT. UM, WHEREAS I THINK THE JOINT COMMENTERS LOOKED AT THIS AND SAID, WELL, WE, WELL, WE MAY NOT, UH, WE MAY NOT AGREE THAT ECRS, YOU KNOW, THE WAY THAT IT'S CURRENTLY OPERATED IS, IS A PROBLEM. WE RECOGNIZE THAT THERE IS A CONCERN. AND, AND SO AS A, UH, YOU KNOW, A, A STEP TOWARDS COMPROMISE THOUGHT, WELL, LET'S TRY TO ALIGN WHATEVER IS IN NPR 1224 TO WHAT WE SEE IN THE, UH, IN THE REALTIME CO REALTIME CO OPTIMIZATION ANCILLARY SERVICE DEMAND CURVES. AND SO THAT WAS, THAT WAS REALLY THE, THE APPROACH WAS, YOU KNOW, LOOK AT WHAT'S OUT THERE AND SEE, YOU KNOW, THE, THE, THE BASELINE EFFECT IN NPR 1224 IS OUR COP PROPOSES TO RELEASE, UH, 500 MEGAWATTS OF ECRS, UH, BASED ON THE, UH, SOME, SOME PRICE QUANTITY PAIRS ON THE POWER BALANCE PENALTY CURVE. AND SO WHEN WE LOOKED AT WHERE THAT SITS, UM, YOU KNOW, ON THE VARIOUS ANCILLARY SERVICE DEMAND CURVES, 'CAUSE REMEMBER IN REAL TIME CO-OP OPTIMIZATION, THE VALUE CHANGES, DEPENDING ON WHAT THE ANCILLARY SERVICE PLAN IS FOR THAT DAY, IT HAS TO FIT INTO THE, THAT BROADER ORDC SHAPE. SO SOME DAYS IT'S GOING TO HAVE A, A, YOU KNOW, A LOWER STARTING POINT AND A PRETTY WIDE RANGE. SOME DAYS IT'S A MORE NARROW RANGE. SOME DAYS IT'S GONNA START UP AT THE CAP AND, AND COME DOWN INTO THE MIDDLE POINT. SO, UM, IF, IF YOU CAN SCROLL DOWN A LITTLE BIT, UM, YOU KNOW, THIS WAS A, ALMOST A CRAYON EXERCISE, BUT IT WAS HELP HELPING TO, TO ILLUSTRATE THE POINT IS THAT IN THE YELLOW LINE, WHEN, YOU KNOW, YOU SEE AN APPROXIMATION OF ABOUT 500 MEGAWATTS SHORT, UH, ACROSS THE BLUE AREA, WHICH IS THE ECRS ANCILLARY SERVICE DEMAND CURVE. AND THEN WE JUST DREW THAT UP TO THE TOP POINT AND SAID, WHERE DOES THAT, WHERE DOES THAT SIT ON THE, UH, ON THE Y AXIS WITH PRICE? AND IT'S, IT'S ACROSS VARIOUS, UH, VARIOUS PRICE POINTS. UM, IN SOME INSTANCES, UH, FIRST TO ADMIT IT IS BELOW THE, UH, THE PRS REPORTS RECOMMENDED $1,000, UH, LEVEL, BUT IN, IN MOST INSTANCES, IT'S ACTUALLY AT OR ABOVE THAT LEVEL. AND SO, UH, CONSIDERING THAT NPRR 1224 PROPOSES TO ALSO ALLOW ERCOT TO RELEASE ADDITIONAL ECRS CAPACITY, WE THOUGHT, YOU KNOW, THAT SEEMS LIKE IT'S A, A FAIRLY CONSERVATIVE ASSUMPTION AND IS CONSISTENT WITH WHERE THE, UH, WHERE THE MARKET'S MOVING TOWARDS IN, UH, 2026 WHEN REALTIME CO OPTIMIZATION GOES LIVE. UM, AND THEN JUST FOR COMPARISON, UH, YOU KNOW, WE INCLUDED IN, IN THE GREEN DASH LINE IS WHERE THE PRS REPORT, UH, WOULD BE AT THE, UM, 40 MEGAWATTS OF, UM, OF, UM, UNDER GENERATION ON THE POWER BALANCE PENALTY CURVE, ROUGHLY, UH, APPROXIMATES THE THOUSAND DOLLARS PRICE POINT. AND THEN WE COMPARE THAT TO WHAT WE'RE IN THE, UM, THE IMS, UH, MAY 15TH COMMENTS, WHICH WAS AT THE, UH, FIVE MEGAWATT, UH, POINT ON THE POWER BALANCE PENALTY CURVE. SO THAT WAS ABOUT 250. AND THE SECOND PRINCIPLE TO HIGHLIGHT HERE IS THAT IN REAL TIME CO OPTIMIZATION, WHEN WE DO GO SHORT ON AN ANCILLARY SERVICE, WHEN THAT IS RELEASED FOR ENERGY, THAT DOES CREATE THE NEW PRICE FLOW. THAT IS THE OPPORTUNITY COST TO THE MARKET OF HAVING THOSE RESERVES, UH, AND THE RELIABILITY VALUE THAT COMES WITH THEM. AND SO THAT, THAT'S THE SECOND PRINCIPLE THAT'S EMBEDDED IN HERE, IS THAT ONCE WE HAVE RELEASED IT, THAT THAT BECOMES THE, THE, THE BASELINE FOR, UH, FOR MARKET PRICING HELPS TO REFLECT THAT SCARCITY. SO, UM, YOU KNOW, I [00:55:01] THINK MAYBE THE, THE CHOICE SET THERE FOR T TO CONSIDER IS, UM, YOU KNOW, IS NPR 1224 MEANT TO, UM, HA RESULT IN PRICE REVERSAL WHEN ERCOT IS RELEASING ECRS? OR IS IT MEANT TO BE A PRICE ARREST, UH, FUNCTION WHERE, YOU KNOW, IT'S, IT'S KIND OF A MIDDLE GROUND BETWEEN WHERE, UH, WHERE FOLKS HAVE, UH, SEEN, UH, SEEN THE IMPACTS OF ERCOT RESERVING THAT CAPACITY, UM, VERSUS WHERE WE WOULD REASONABLY EXPECT IT TO BE IN, UH, THE REALTIME CO-OP OPTIMIZATION WORLD. SO, UM, THAT'S JUST A GENERAL LAYOUT. UM, HAPPY TO TAKE QUESTIONS, BUT I ALSO DO WANT TO JUST UNDERSTANDING THAT THERE'S A LOT OF DIFFERENT, UH, THERE'S PROBABLY DIFFERENT OPINIONS ON THIS, BUT GIVEN THAT PRS DID GIVE US A REPORT, I DO WANT TO LAY OUT A MOTION FOR TAC TO ENDORSE THE PRS REPORT AND, UM, AND START FROM THERE. AND I'M SURE WE'LL HAVE LOTS OF DISCUSSION. AND, UM, SO THAT'S A MOTION. THAT IS A MOTION. IS THERE A SECOND FOR THAT MOTION TO ENDORSE THE PRS REPORT? BLAKE? OKAY. SO WE'LL GO BACK TO THE QUEUE. RICK, I'M GOING TO GO AHEAD AND MAKE A SUBSTITUTE MOTION IF I CAN, TO ENDORSE THE IMM COMMENTS FILED ON MAY 15TH AND MAY 17TH. OKAY. WELL, I THINK WE, WE'D HAVE TO MAKE A MOTION TO AMEND THAT MOTION, THE FIRST MOTION ON THE TABLE. IS THAT CORRECT, COREY? CORRECT. SO WE HAVE A MOTION TO ENDORSE THE PRS REPORT, AND THEN A MOTION TO AMEND THE PRS REPORT VERSION TO THE VERSION WITH THE IMM COMMENTS. YES. IS THERE A SECOND FOR RICK'S MOTION? OKAY, THERE'S A SECOND FROM ERIC. SHOULD WE VOTE ON THIS MOTION TO AMEND THE MOTION BEFORE GETTING TO THE REST OF THE QUEUE? I THINK YOU SHOULD. OKAY. ANN THINKS WE SHOULD, BUT OH, SAID, TAKE DISCUSSION FIRST. OKAY. CAN WE GET THE IMMS THOUGHTS? WE CAN GET THE IMMS THOUGHTS? YES. THIS IS, UH, JEFF MCDONALD WITH POTOMAC ECONOMICS, UH, AND IMM FOR THE ERCOT MARKET. UM, AND I HAVE WITH ME ANDREW RUMORS, SO, UH, YOU WANT OUR THOUGHTS? I, I'D BE HAPPY TO, UM, CERTAINLY WOULD BE HAPPY TO FIELD QUESTIONS. UM, I CAN SUMMARIZE WHAT WE PUT IN OUR COMMENTS, IF THAT'S HELPFUL, IF THAT'S A HELPFUL LAUNCHING POINT. UM, SO REGARDING THE PROCUREMENT TRIGGER, UM, OUR POSITION IS ANY KI OR NOT PROCUREMENT TRIGGER, I'M SORRY, THE DEPLOYMENT TRIGGER. UM, ANY DEPLOYMENT TRIGGER IS A MOVE IN THE RIGHT DIRECTION FROM NO DEPLOYMENT TRIGGER. SO, AND EVERYONE HERE IS FAMILIAR WITH THE ANALYSIS THAT WAS, YOU KNOW, PUT OUT BY OUR GROUP, UH, LAST YEAR ON A COUPLE DIFFERENT POINTS, SO I WON'T REHASH THAT. BUT, BUT IN OUR VIEW, UM, AND REFLECTING ON THAT ANALYSIS, WHEN WE LOOK AT THE, UH, RELIABILITY VALUE THAT, THAT ANALYSIS, UM, CALCULATED FOR THE ECRS PROCUREMENT, YOU KNOW, WE LOOKED, WE, WE SAW AVERAGE RELIABILITY VALUES OF ABOUT $16, UH, PER MEGAWATT, AND, UH, A MARGINAL RELIABILITY VALUE WHEN CONSIDERING THE ENTIRE POOL OF ECRS PROCURED AT ANY TIME OF $0. SO THERE WAS NO MORE RELIABILITY BENEFIT TO HAVING ONE MORE, UH, MEGAWATT OF ECRS. SO, SO DRAWING ON THAT, AND THAT'S A FUNDAMENTAL PRINCIPLE, I THINK, UH, IN SHAPING OUR POSITION IN GENERAL, IS THAT WE FELT THAT ECRS WAS OVER PROCURED BASED ON RELIABILITY VALUE AND THEREFORE, UH, SE SEQUESTERING THAT ECRS OR A LARGE PORTION OF THAT ECRS FROM BEING AVAILABLE IN THE REAL TIME ENERGY MARKET AND THE PRICE INCREASES THAT RESULTED FROM THAT SEQUESTRATION, UH, WERE ARTIFICIALLY INDUCED OR, OR UNNECESSARY, UH, ANOTHER WAY TO PUT IT OR, UH, NOT WARRANTED BASED ON THE RELIABILITY VALUE AS WE CALCULATED IT. SO, AND THAT, THAT ALL FELL OUT OF THAT ANALYSIS FROM 2023. SO YOU'LL SEE A LOT OF OUR, A LOT OF THE PARTICULARS, UH, OF OUR RECOMMENDATIONS OR OBSERVATIONS FALL OUT OF THAT PREMISE, UH, IN PARTICULAR AND THROUGH CONVERSATIONS WITH, UM, MARKET PARTICIPANTS, FOLKS AT, UH, UH, AT ERCOT, YOU KNOW, I, I THINK THAT PROBABLY IS A FUNDAMENTAL DIFFERENCE, AND IT'S VERY FUNDAMENTAL TO OUR POSITION. [01:00:01] SO IF YOU DON'T SEE THAT THERE WAS SOME LEVEL OF OVER PROCUREMENT IN 2023, THEN SOME OF OUR RECOMMENDATIONS MAY MAKE LESS SENSE TO YOU. BUT I THINK THAT'S AN IMPORTANT BASIS, AND THAT'S WHERE WE COME FROM, UM, YOU KNOW, BASED ON OUR ANALYSIS. SO, SO GIVEN THAT WE DO FEEL THAT, YOU KNOW, A MATERIAL PORTION OF ECRS COULD BE MADE AVAILABLE, UH, TO SCAD, UH, AND THAT THE PRICE INCREASES THAT WERE OBSERVED IN 2023 WERE THE RESULT OF NOT MAKING THOSE AVAILABLE. UM, AND AGAIN, THEY WERE ARTIFICIAL PRICE INCREASES BECAUSE WE BELIEVE THAT, THAT THAT CAPACITY WAS ARTIFICIALLY SEQUESTERED FROM, FROM SC. SO, HAVING SAID THAT, W WE LOOK AT ANY FORM OF DEPLOYMENT, MAKING THOSE, UH, MEGAWATTS AVAILABLE TO SCED AND, AND THEREFORE AVAILABLE TO A ECONOMIC DISPATCH AND PRICE FORMATION AS AN IMPROVEMENT IN THE STEP IN THE RIGHT DIRECTION. YOU'LL SEE FROM OUR COMMENTS, WE, WE DO HAVE SOME COMMENTS REGARDING USING UNDER GEN AS A TRIGGER FOR SC VERSUS SOME OTHER METHOD. AND TO BE FAIR, YOU KNOW, IN CONVERSATIONS, YOU KNOW, UH, FOR THOSE WHO HAVE BEEN AROUND A WHILE IN THE WHOLESALE ELECTRICITY SPACE, UH, MARKET DESIGN IS AN EVOLUTIONARY PROCESS. SO IN EARLIER CONVERSATIONS WITH ERCOT THAT, YOU KNOW, WE HAD A NUMBER OF, UM, POTENTIAL, UH, DEPLOYMENT TRIGGER OPTIONS ON THE TABLE THAT WE HAD FLOATED, UH, UNDER GENERATION WAS ONE OF 'EM. UH, I, I ACTUALLY WASN'T HERE AT THAT TIME, BUT I'VE SEEN THE OPTIONS. UH, THERE WERE OTHERS PRESENTED AS WELL. AND THROUGH CONVERSATIONS WITH SOME PARTICIPANTS AND INTERNAL CONVERSATIONS, WE'VE COME UP WITH SOME OTHERS. SO, SO, YOU KNOW, PART OF, PART OF OUR CONCERN AND RECOMMENDATION IN THE DEPLOYMENT SPACE IS WE HAVE CONCERNS, YOU KNOW, DESPITE EARLIER CONVERSATIONS OF HAVING, UH, A UNDER JAN TRIGGER AS ONE OF OUR RECOMMENDATIONS, YOU KNOW, I'LL NOTE THAT HAVING UNDER JAN AS A TRIGGER BECAUSE OF THE POWER BALANCE CONSTRAINT VIOLATION PENALTY, UH, NECESSARILY INJECTS A ADMINISTRATIVE PENALTY PRICE INTO PRICE FORMATION. AGAIN, DRAWING BACK ON, YOU KNOW, WE BELIEVE, UH, CAPACITY WAS OVER SEQUESTERED FROM THE REAL TIME MARKET, THAT CONDITION, THAT OVER GEN CONDITION IN OUR, OUR POSITION IS A FALSE CONDITION OR AN ARTIFICIAL CONDITION. AND SO USING OR OR VIEWING A ONE OR MULTIPLE POWER BALANCE CONSTRAINT VIOLATION, PENALTY PRICES AS A, AS A REASONABLE BASIS PRICE, UH, IS, IS I, I THINK ACCEPTING AN ARTIFICIAL PRICE AS A BASIS PRICE WHEN IN FACT, OUR, OUR BIG POINT WAS WE NEED TO ELIMINATE, UH, THE ARTIFICIAL SHORTAGE CONDITION MANIFESTING ITSELF IN PRICE FORMATION. SO, SO HAVING SAID THAT, UH, ERCOT PROPOSAL MOVES THE BALL IN THE RIGHT DIRECTION, IT IS DEFINITELY DIRECTIONALLY CORRECT, UH, YOU KNOW, FROM THE, FROM THE 2023 BASIS OF NO DEPLOYMENT TRIGGER, BUT, BUT WE DON'T LIKE THE FACT THAT IT INJECTS, UH, AT A 40 MEGAWATT UNDER JAN ABOUT A THOUSAND DOLLARS, UH, OF BASICALLY SHORTAGE PRICING, UH, INTO THE PRICE FORMATION. SO WE, WE, WE DISAGREE WITH THAT, AND THAT IS ONE OF THE PREMISES THAT'S THE LINKAGE, I GUESS, UH, ONE LINKAGE FROM, UH, THE DEPLOYMENT TRIGGER ITSELF TO THE OFFER PRICE FLOOR, WHICH I'LL GET TO IN A SECOND. SO THERE ARE ALTERNATIVES. UH, I KNOW THOSE ALTERNATIVES AREN'T ON THE TABLE TODAY FOR, FOR THE, UM, DEPLOYMENT TRIGGER, BUT THERE ARE ALTERNATIVES THAT COULD INVOLVE PRICES, UM, PRECEDING A SHORTAGE CONDITION, UH, AND AN INCREASE IN PRICE PRECEDING A SHORTAGE CONDITION THAT MIGHT, UH, SIGNAL DEPLOYMENT IS WARRANTED PRIOR TO A TRUE SHORTAGE CONDITION WHERE YOU GET ADMINISTRATIVE PRICING INJECTED INTO THE PRICE FORMATION. THAT'S ONE OPTION. ANOTHER OPTION IS, UH, BASED ON HEADROOM, UH, AVAILABLE IN SCED. SO AS THE HEADROOM, UH, SHRINKS BEYOND A CERTAIN LEVEL, UH, DEPLOYMENT WOULD BE TRIGGERED AT THAT POINT. UH, SO THAT'S NOT PRICE SPECIFIC, BUT, BUT IT'S PROBABLY THE MOST DIRECT, UM, MEASURE OF WHEN FREEING UP ECRS WOULD BE ADVANTAGEOUS TO ECONOMIC DISPATCH AND SCED. SO ON, ON THE DEPLOYMENT, THAT'S, I GUESS A SUMMARY, IF YOU COULD EVEN CALL THAT A SUMMARY. 'CAUSE THAT WAS PROBABLY LONGER THAN, UM, ANYONE ELSE'S SUMMARY. I, I WILL GET TO, UH, THE PRICE FLOOR. SO, AND, AND, AND I THINK THAT PRIOR DISCUSSION IS REALLY CRITICAL IN TALKING ABOUT AN OFFER PRICE FLOOR AS WELL. SO, SO IN OUR VIEW, UH, YOU KNOW, SOME PORTION OF SCED SHOULD HAVE BEEN OPTIMIZED OR SOME PORTION OF THE ECRS THAT WAS SEQUESTERED SHOULD HAVE BEEN OPTIMIZED AND SCED, UM, PRIOR TO REACHING A SCARCITY CONDITION. I LOOK AT AND KNOW, AND I UNDERSTAND, I ACTUALLY DO UNDERSTAND THE ARGUMENT AGAINST, OR, OR THE ARGUMENT FOR A PRICE FLOOR TO PROTECT AGAINST PRICE SUPPRESSION WITH A LARGE RELEASE OF, OF RESERVE INTO THE ECONOMIC DISPATCH. HOWEVER, [01:05:02] UM, THERE ARE MECHANISMS IN PLACE RIGHT NOW THAT WOULD, UH, INJECT ADMINISTRATIVE PRICING INTO, INTO THE ENERGY PRICE FORMATION AS RESERVES, UH, SHRUNK ANYWAY. SO YOU'VE GOT THE ORDC, UH, CURVE THAT IS ALREADY IN PLACE. A LOT OF THE CONVERSATIONS THAT WE'VE BEEN IN HAVE BEEN SORT OF JUXTAPOSING AN RTC WORLD AGAINST, AGAINST THE CURRENT SITUATION. I'LL SPEAK TO THE CURRENT SITUATION BECAUSE I THINK IT'S CLEAR AND I, AND I DO THINK THAT THERE'S A CERTAIN AMOUNT OF CONFUSION THAT GETS INJECTED INTO THE CONVERSATION WHEN WE START BOUNCING IN BETWEEN AN RTC WORLD AND OUR CURRENT SITUATION. THE, THE GENERAL PRINCIPLE OF CO-OP OPTIMIZATION IS WHAT'S DRIVING, UM, I THINK EVERYBODY'S DISCUSSION ABOUT HOW DO WE USE ECRS IN THE ECONOMIC DISPATCH, BUT WITH RESPECT TO THE CURRENT SITUATION, YOU KNOW, IF, IF, IF 500 MEGAWATTS IS RELEASED, UH, INTO SC UH, WITH, YOU KNOW, X MEGAWATTS OF UNDER GEN, IT DOESN'T MATTER, 30 MEGAWATTS 10 40, YOU WOULD EXPECT THAT THAT AMOUNT OF UNDER GEN TO BE DISPATCHED ALMOST IMMEDIATELY, IF NOT IMMEDIATELY, UH, FROM THE, THE RELEASED ECRS, THE REMAINING ECRS, UH, IS STILL AVAILABLE, UH, TO BE COUNTED IN AS, AS A RESERVE AND UTILIZED IN THE OR DC CALCULATION OF WHETHER OR NOT AND TO WHAT EXTENT, UH, AN ADMINISTRATIVE PRICE SHORTAGE PRICE IS INJECTED INTO THE PRICE FORMATION IN THE ENERGY MARKET. SO WITH THAT IN PLACE, WE DON'T SEE ANY REASON TO, NOT TO OVERUSE THE WORD, BUT TO ARTIFICIALLY OR MANUALLY FORCE A PRICE INTO THE, THE, THE SCED PRICE FORMATION THROUGH AN OFFER PRICE FLOOR BECAUSE, AND ESPECIALLY IN THE CASE WITH A, UM, UH, UNDER GEN TRIGGER, YOU'RE ALREADY, YOU'RE ALREADY ON THE PATH TO POTENTIALLY HAVING A SHORTAGE CONDITION ARISE AND, UH, BE PRICED THROUGH THE ORDC. SO, ORDC IS ALREADY AN, AN ADMINISTRATIVE PRICE TO REFLECT SCARCITY IN ENERGY. I THINK OVERLAYING ANOTHER ADMINISTRATIVE PRICE ON TOP OF THAT, ESPECIALLY AT A THOUSAND DOLLARS, UM, IS IN A SENSE PROTECTING, UH, SOME OF THE 12 AND A HALF BILLION DOLLARS THAT WE CALCULATED AS A OVERAGE COST, UH, FROM 2023. SO, SO WE, WE WOULD LIKE TO SEE THAT NOT HAPPEN, UH, AND WE WOULD PREFER TO SEE NO OFFER PRICE FLOOR, UM, INJECTED INTO THE RELEASED CAPACITY. UM, WE, WE, WE DON'T SEE A JUSTIFICATION FOR IT. AND AGAIN, IF I, THIS IS A LITTLE BIT OF A LONG SUMMARY, BUT, BUT TO ADD A PUNCHLINE, I GUESS TO IT IS A THOUSAND DOLLARS. HOWEVER, IT'S JUSTIFIED, UM, AND, AND IT HAS BEEN THROUGH VARIOUS DISCUSSIONS WE'VE BEEN IN, IS STILL BASED ON A, A PRICE BASIS THAT RECOGNIZES SHORTAGE AS THE CORRECT CONDITION. AND OUR PREMISE IS SHORTAGE IS NOT THE CORRECT CONDITION. THE ECRS SHOULD HAVE BEEN AVAILABLE TO SC PRIOR TO HITTING A SHORTAGE CONDITION. SO A THOUSAND DOLLARS IS NOT, OR $500 IS NOT THE RIGHT PRICE BASIS BECAUSE IT EMBODIES A SHORTAGE CONDITION THAT WE FEEL SHOULD NOT HAVE HAPPENED. SO HOW, HOW WAS THAT FOR A SUMMARY CONCISE? GREAT. DO YOU WANT TO, UH, MENTION THE SAVINGS NUMBERS OR SAY THAT FAST? YEAH. OKAY. THANK YOU SMI. SO, UH, THANK YOU JEFF AND THANK YOU ACOR FOR ALL THE ANALYSIS AND DISCUSSION ON IT. UM, I CAN SEE WHERE IMM IS COMING FROM. UM, THEY ARE EXPECTED TO ARGUE FOR WHAT'S THEORETICALLY THE CORRECT MOST EFFICIENT MARKET OUTCOME. AND FROM THEIR PERSPECTIVE OR FROM THE MOST EFFICIENT MARKET OUTCOME, IT CAN BE, UM, ARGUED THAT CONSERVATIVE OPERATION DOESN'T PROVIDE ANY ADDITIONAL RELIABILITY VALUE AND THERE IS NO, UH, COST THAT NEEDS TO BE ADDED AND NO PRICE FLOOR NEEDS TO BE ADDED. AND, UH, A PRICE FLOOR, UH, COULD BE REMOVED BECAUSE THE ORDC IS REFLECTING THE SCARCITY. BUT WE ALL KNOW THAT IS THE MOST EFFICIENT MARKET IS NOT WHERE WE ARE AT THIS POINT RIGHT NOW. REGULATORS HAVE ALREADY DECIDED TO GO WITH THE CONSERVATIVE OPERATION, AND IF THE CONSERVATIVE OPERATION IS GOING FORWARD, WE ALREADY KNOW THAT THAT IS DRIVING OUT VALUE OUT OF THE, OR DC RESERVES. IT'S NOT PRICING ANYTHING RIGHT NOW. AND IF YOU, IF REGULATORS [01:10:01] NEED THIS CONSERVATIVE OPERATION, THEN THOSE RESERVES NEEDS TO BE VALUED APPROPRIATELY. AND, UM, I WOULD REALLY ENCOURAGE PEOPLE TO LOOK AT THE, UH, SLIDES PROVIDED AT THE END OF TCPA COMMENTS TO SEE WHAT IS THE RELIABILITY VALUE THAT WE CAN SEE FROM THE CURRENTLY APPROVED A SDC. UM, THAT IS THE VALUE THAT YOU SEE IN RTC RIGHT NOW, IF WE GO IN IMPLEMENTING RTC RIGHT NOW, UH, ANYONE WHO HAS FOLLOWED RTC TASK FORCE DISCUSSION WOULD KNOW THAT THERE'S LOT OF THINGS THAT SHOW THAT CURRENTLY APPROVED A SDC ITSELF IS NOT VALUING THE RESERVES APPROPRIATELY. AND WHAT TCPA PROPOSED IS JUST PUTTING IT AT THE LEVEL THAT WE ALL AGREED AND THE PUCT APPROVED, UH, BASED ON THE RDC. SO REMOVING THE OFF FLOOR, EVEN THOUGH THAT IS THEORETICALLY THE MOST EFFICIENT RESULT, MAY NOT BE WHAT THE REALITY WE ARE IN RIGHT NOW. AND THAT IS SIGNIFICANTLY WILL UNDERVALUE THIS RESERVES. UM, I KNOW THAT ACCORD, WHEN THE PRESENTED, UH, THE DIFFERENT APPROACHES FOR ADDRESSING THIS, UM, ECRS RELEASE, THERE WERE MANY OPTIONS THAT WERE PRESENTED. AND ONE OF THE OPTION WAS TO HAVE A STANDING DEPLOYMENT OF, UM, ECRS AT A PRICE FLOOR. AND IF I REMEMBER CORRECTLY, THERE WAS DESIRE TO ENSURE THAT ECRS IS STILL PROVIDING VALUE. SO IT NEEDS TO BE AT A, A LEVEL PRICE LEVEL WHERE IT DOESN'T GET DEPLETED OR IT GET, DOESN'T GET USED UP FIRST SO THAT THE REST OF THE RESOURCES CAN GO AWAY. UH, JEFF IS CORRECT THAT IT, THE, EVEN IF IT GETS USED UP FIRST, THERE MAY BE OTHER RESOURCES STANDING BY, BUT THAT DOESN'T PREVENT IT FROM THE OTHER RESOURCES FROM GOING OFFLINE OR NOT BEING AVAILABLE. SO IF YOU REALLY WANT THE RESERVES TO BE, UM, AVAILABLE, YOU NEED TO HAVE IT EITHER, UH, PRESERVED OR BEHIND, UH, SOME PRICE, UH, LEVEL. SO I WOULD LIKE TO, UM, MAYBE HEAR FROM ERCOT, UH, ABOUT, UM, THE CONCERNS WITH HAVING, UH, RELEASING IT EARLIER OR HAVING NO PRICE FLOOR OR, UH, THE VALUE THAT, UH, ELCOT SEES, IF THAT'S OKAY. OKAY. THAT'S FINE. AND I, I HAVE SOME MORE AFTER THAT. MAYBE . ALRIGHT, GO AHEAD JEFF. YEAH, SO, UH, MAYBE, UH, SO I, SO I HAVE SOME COMMENTS. MAYBE BEFORE I DO THAT, I'D LIKE TO GET CLARIFICATION. SO I, AS I READ THE MAY 17TH IMM COMMENTS, JEFF, I, I THINK THAT YOU ALL, YOU ALL JUST REMOVED THE, THE OFFER FLOOR CONCEPT ALTOGETHER. IT IT, AM I UNDERSTANDING THAT RIGHT? THAT'S CORRECT. OKAY. OKAY. SO, SO, UM, AND, AND, AND MAYBE BEFORE I, UM, GO TOO FAR, I, I WANT TO REMIND EVERYONE THAT THERE ARE SORT OF THREE PARALLEL EFFORTS GOING ON RIGHT NOW. SO WE HAVE THIS, UH, PUC ANCILLARY SERVICES STUDY, UH, WHERE WE ARE WORKING, UH, WITH, UH, THE IMM, AND WE'RE LOOKING AT ARE THERE, UH, THINGS THAT WE NEED TO CHANGE IN THE METHODOLOGY ON HOW WE CALCULATE ANCILLARY SERVICES, WHAT, WHAT ANCILLARY SERVICES WE HAVE, THOSE SORTS OF THINGS OR OTHER FUNDAMENTAL CHANGES THAT WE NEED TO MAKE. AND SO THAT IS A, A, A PARALLEL EFFORT THAT, UH, WE'RE WORKING ON. AND, UH, I THINK WE HAVE TO FILE SOMETHING AT THE COMMISSION BY SEPTEMBER 1ST. UM, ANOTHER PARALLEL EFFORT IS THE 2025 ANCILLARY SERVICES METHODOLOGY, WHICH WE HAVE ALREADY INTERNALLY STARTED WORKING ON. AND, AND I THINK THAT WE WILL START TAKING THAT TO WORKING GROUPS, UH, ROUGHLY JULY, I, I, I BELIEVE. UM, AND, AND SO AGAIN, THAT'S LOOKING AT THE 2025, UH, AS METHODOLOGY, WHICH, WHICH I THINK WILL BE, I THINK, SIMILAR TO WHAT YOU'VE SEEN IN, IN THE PAST. UH, SO I DON'T EXPECT ANY OF THE, ANY OF THE CHANGES THAT, THAT MAY OR MAY NOT COME OUT OF THE PUC AS STUDY. I I, I DON'T THINK THAT, THAT THOSE WOULD MAKE THEIR WAY INTO THE 2025 AS METHODOLOGY. THERE MAY BE SOME THINGS ALONG THE EDGES, BUT NO SIGNIFICANT CHANGES. UM, AND THEN THE, THE THIRD PARALLEL EFFORT IS THIS NPRR AS WELL AS A FOLLOW-UP NPRR THAT, THAT WE, [01:15:01] UM, CURRENTLY HAVE IN, UH, DRAFT INTERNALLY. UH, AND THE IDEA BEHIND THESE, UH, TWO, NPRS 1224 AND, AND THE FOLLOW UP ONE, UH, IS TO ADDRESS WHAT WE WERE ASKED TO DO COMING OUT OF, UH, LAST YEAR'S THAT OR, BUT THE 2024 AS METHODOLOGY, WHICH WAS TO REVISIT ECRS. UM, AND, UH, AND SO THERE'S THIS NPRR, WHICH WAS, UH, AN ATTEMPT TO GET A, AN ADDITIONAL MANUAL TRIGGER FOR RELEASING ECRS EARLY. UH, WE HAVE A, AS I MENTIONED, A FOLLOW-UP NPRR, WHICH IS A STANDING DEPLOYMENT NPRR WITH, WITH, UH, YOU KNOW, OBVIOUSLY YOU'D HAVE TO HAVE AN OFFER FLOOR WITH THAT. UM, AND SO WE ARE WORKING ON THAT. UH, AGAIN, AS, AS A FOLLOW UP, WE'RE SOMEWHAT WAITING TO SEE WHAT HAPPENS WITH 1224 BEFORE WE POST THAT NPRR. UH, BUT ANYWAY, SO JUST, JUST WANTED TO MAKE SURE EVERYONE WAS ON THE SAME PAGE. UM, SO THAT, THAT SAID, UH, SO WE HAVE IN, IN THE CONTEXT OF ALL OF THOSE, UH, WE, WE HAVE HAD SOME REALLY PRODUCTIVE CONVERSATIONS WITH THE IMM. I THINK WE BOTH UNDERSTAND EACH OTHER BETTER. I, I, I HOPE THE IMM WOULD AGREE WITH THAT. UH, I DON'T WANNA PUT WORDS IN THEIR MOUTH, BUT, UM, BUT, UH, SO WE'VE HAD SOME REALLY GOOD CONVERSATIONS. UM, I, I THINK WE, WE STILL, TH THERE'S STILL A, A GAP IN, IN WHERE WE'RE AT. TH THERE'S STILL, UM, AS WAS STATED, THERE'S SOME FUNDAMENTAL DIFFERENCES IN HOW WE VIEW THE RELIABILITY VALUE OF ECRS. AND I THINK WE, WE DO SEE THAT THERE IS A BENEFIT TO THE SYSTEM FOR HOLDING BACK 10 MINUTE RESERVES FOR VARIOUS RELIABILITY EVENTS. AND I THINK WE'RE, WE'RE STILL WORKING THROUGH THAT. UM, BUT, UM, YOU, YOU KNOW, I THINK THAT THAT'S WHERE OUR, OUR DIFFERENCES AND, AND I THINK THAT'S WHY YOU SEE US, UM, YOU KNOW, COMING AT THIS, UH, WITH, WITH DIFFERENT VIEWPOINTS ON, UH, ON, ON HOW TO DO, UH, THIS, UM, THE, THE OFFER FLOOR. UH, I, I, I PERSONALLY THINK THAT, THAT THE DIFFERENCES MAY BE MORE OF A QUANTITY ISSUE IN, IN, UH, HOW MUCH WE BUY. UH, I, I THINK AT THE END OF THE DAY, I, I HOPE EVERYONE SEES THAT THERE IS VALUE, SOME VALUE IN SOME AMOUNT OF 10 MINUTE RESERVES. UM, AND, AND SO I, I PERSONALLY THINK IT'S PROBABLY MORE OF A QUANTITY ISSUE. UH, SO WE'RE, WE'RE GONNA CONTINUE THAT DISCUSSION AS PART OF THAT PUC AS STUDY, UM, AND WE'LL CONTINUE TO WORK ON THAT. UM, BUT WE THINK THAT THE PRINCIPLE OF THE FLOOR, WE, WE NEED TO DO THAT CORRECTLY, UM, REGARDLESS OF THE QUANTITY, AND THEN WE CAN CONTINUE TO WORK ON WHAT IS THE RIGHT METHODOLOGY FOR DETERMINING THE QUANTITY. UH, SO ALL, ALL OF THAT TO SAY, UH, WE, WE FILED 12 12 24 WITHOUT A, UH, AN OFFER FLOOR. UH, WE ARE OKAY WITH 1224 MOVING FORWARD WITHOUT AN OFFER FLOOR, WHICH I, I THINK IS THE, I, I THINK WOULD BE THE MAY 17TH COMMENTS. I, I, SO I, I WOULD SAY WE ARE NOT OPPOSED TO THE LANGUAGE. I, I HAVE SOME FUNDAMENTAL DISAGREEMENTS IN SOME OF THE, THE PREAMBLE, UH, YOU KNOW, WORDS THAT, THAT WERE IN, IN THE COMMENTS THAT THE IMM FILED. BUT, UM, YOU KNOW, I DON'T, I DON'T THINK THAT'S ANY SURPRISE TO THE IMMI, I THINK, YOU KNOW, WE'RE, WE'RE CONTINUING TO HAVE THOSE DISCUSSIONS. UM, UH, BUT WE DO THINK THAT, UH, IF THERE IS AN OFFER FLOOR THAT IT NEEDS TO APPROPRIATELY VALUE HAVING THAT 10 MINUTE RESERVE PRODUCT THAT THE ECRS, UH, AND, AND, UM, AND SO WE WOULDN'T WANT THAT TO BE LOW. SO WITH THAT SAID, WE ARE ALSO OKAY WITH THE PRS VERSION. SO IF STAKEHOLDERS FEEL LIKE THEY WANT 1224 TO GO THROUGH WITH AN OFFER FLOOR, THEN WE ARE OKAY WITH WHAT HAS BEEN PROPOSED IN, UH, AND, UH, APPROVED IN THE PRS VERSION. SO I HOPE, HOPE THAT HELPS. REMI, YOU SAID YOU HAD, YEAH, MORE COMMENTS, , UH, SO THANK YOU JEFF AND I, I THINK, UH, IT'S, UM, GOOD TO HEAR YOU SAY THAT WE NEED TO APPROPRIATELY VALUE THE RESERVES. AND, UM, UH, CAN WE SCROLL DOWN A LITTLE BIT ON THIS COMMENT? UH, THIS IS THE TCPA COMMENT, RIGHT? UH, THE TC. SO, UH, I WOULD ENCOURAGE EVERYONE TO LOOK AT THE TCPA COMMENTS TO THE LAST SLIDE, WHICH SHOWS THAT, UM, WITH THAT A SDC CURVE, UM, THOUSAND IS A VERY REASONABLY LOW VALUE COMPARED TO ALL OF THE, UM, TIMES AT WHICH 500 MEGAWATTS OF EASY R IS RELEASED AND WHAT THAT PRICE CORRESPONDS TO. UH, THAT BEING SAID, I CAN SEE, UH, THE CONCERNS THAT CONSUMERS HAVE, UH, ABOUT, UM, [01:20:03] HIGH PRICES GOING. I WOULD SAY THAT, UH, TO CONSUMERS, WE NEED TO HAVE A BALANCE, UH, IN VALUING THE RESERVES THAT WE ARE PROCURING. AND, UM, GETTING THE RIGHT LEVEL OF RESERVES IS, UH, IS IMPORTANT, BUT SENDING THE RIGHT PRICE SIGNAL IS ALSO IMPORTANT. UH, SO IN, UM, IN THE SPIRIT OF, UH, COMPROMISE, CAN YOU SEE, LIKE I CAN, YOU CAN SEE LIKE 500 IS THE LOWEST, LOWEST VALUE IN, IN, IN THOSE. SO I COULD, UM, I, I COULD SEE US REACHING A COMPROMISE FOR MAYBE A $500 FLOOR, BUT I WOULD REALLY ENCOURAGE TAC TO LOOK AT, UM, GIVE THAT AN OPTION. SO, UM, CONSIDER THE THOUSAND DOLLARS FLOOR AND SEE WHERE THAT GOES, AND SEE WHERE THE MARKET CAN GET TO BEFORE WE COMPLETELY IGNORE THE PRICE ROAD, BECAUSE VALUING THOSE RESULTS RESERVES IS REALLY CRITICAL. UM, SO IF I COULD MAKE A FRIENDLY AMENDMENT, I DON'T KNOW WHAT'S THE, UH, RIGHT NOW WE ARE TALKING ABOUT THE, YEAH, WE, WE HAVE TWO, WE HAD AN INITIAL MOTION, UM, TO APPROVE BASED ON THE PRS MOTION, AND THEN A MOTION TO AMEND THE MOTION BASED ON IMM COMMENTS. I THINK WE SHOULD TRY TO KEEP THIS DISCUSSION RIGHT NOW TO THAT MOTION BEFORE WE START COMPROMISING WHEN WE HAVEN'T TAKEN THAT VOTE YET. OKAY. SO IF WE COULD GO THROUGH THIS QUEUE AND KEEP COMMENTS RELEVANT TO YEAH. THIS MOTION, AND THEN IF NECESSARY, GET TO, OKAY. SO I CAN COME BACK AND MAKE THAT THOSE COMMENTS FRIENDLY AMENDMENT AFTER WE GET THROUGH THIS MAYBE. OKAY. ANDREW, THANK YOU. WELL, I DON'T WANT TO PREVENT YOU FROM MAKING A MOTION, BUT I THINK IT WOULD BE AN AMENDMENT ON TOP OF AN AMENDMENT. SO I DON'T KNOW WHERE ROBERT'S RULES IS ON THAT. I DON'T THINK YOU GET TO MAKE ENDLESS AMENDMENTS TO AMENDMENTS. I THINK WE NEED, YOU SAID IT CORRECTLY, WE NEED TO RESOLVE THIS ONE FIRST. OKAY. AND ONCE THIS IS RESOLVED AND WE'RE BACK TO A MAIN MOTION, WE CAN GO RIGHT BACK INTO THE MOTION TO AMEND THE MOTION CYCLE AGAIN. BUT WE NEED TO ADDRESS THIS ONE FIRST. YES. SO WE ALREADY DECIDED TO GO THROUGH THIS QUEUE, BUT IF WE COULD LIMIT COMMENTS IN THIS QUEUE, UM, GO GOING THROUGH JOHN RUSS HUBBARD, AND MAYBE ENDING THERE IF WE COULD LIMIT THE, THE COMMENTS IN, IN THIS CURRENT QUEUE TO THIS MOTION TO AMEND THE FIRST MOTION. ANDREW, ANDREW REERS. IMM. I MIGHT NOT HAVE FOLLOWED ALL OF THE AMENDMENT LOGIC, BUT I DO WANT TO JUST RESPOND TO SOME OF THE FRAMING AS FAR AS HOW THE, UH, A SDC IS BEING USED AS A REFERENCE POINT FOR A 500 MEGAWATT RELEASE OF ECRS. UH, A 500 MEGAWATT RELEASE OF ECRS, GIVEN THE WAY SC CURRENTLY OPERATES, ISN'T REALLY ANALOGOUS TO A 500 MEGAWATT SHORTAGE OF ECRS UNDER RTC. SO IF YOU RELEASE 500 MEGAWATTS OF ECRS IN THE CURRENT PARADIGM, ONLY SOME OF THAT ENERGY IS GOING TO BE DISPATCHED. IF WE USE THE 40 MEGAWATTS OF UNDER GEN EXAMPLE, PERHAPS 40 MEGAWATTS OF THAT ECRS CAPACITY WILL BE GIVEN BASE POINTS, AND THE OTHER 460 MEGAWATTS OF IT WOULD STILL BE IN RESERVE. SO IF WE WANT TO COMPARE THIS TO AN RTC SITUATION, YOU WOULD AWARD THAT OTHER 460 MEGAWATTS BACK TO ECRS, AND THEREFORE YOU'RE ONLY GOING SHORT BY 40 MEGAWATTS. AND SO I JUST WANNA STATE THAT KIND OF PEGGING THE OFFER FLOOR BASED ON A 500 MEGAWATTS SHORTAGE GIVEN, UH, CRUDELY DRAWN MIGHT BE TOO CRUEL OF A COMMENT, BUT BASED ON THESE A SDC CURVES, WHERE THEN THE OTHER COMMENT WOULD BE, THERE'S STILL SOME DISAGREEMENT ABOUT WHAT THE SHAPE OF THE CURVES SHOULD BE IN THE FIRST PLACE, UH, THAT WOULD LOWER THE BASE POINT THAT PEOPLE ARE USING TO MAKE THEIR ASSUMPTIONS ABOUT WHAT THE OFF FLOOR SHOULD BE. UH, GRANTED, ONCE YOU RELEASE 500 MEGAWATTS OF ECRS, ALL OF IT COULD EVENTUALLY BE DISPATCHED. AND SO THESE ARE INHERENT LIMITATIONS OF THE CURRENT SC VERSUS RTC SC, AND IT'S HARD FOR ME TO TELL BASED ON THOSE FIGURES WHAT 40 MEGAWATTS OF AN ECRS RELEASE WOULD BE, BUT IT'S A LOT LOWER THAN WHAT IT WOULD BE FOR 500 MEGAWATTS. THANK YOU. BILL BARNES, MAD CHAIR. I'D LIKE TO HOLD MY COMMENTS AFTER THE VOTE IN THE MOTION. THANK YOU. YOU'RE THE BEST. OKAY. BLAKE. BLAKE, HOLE, L-C-R-A-A. A LOT OF MY POINTS HAVE BEEN MADE [01:25:01] BY OTHERS, SO I'LL, I'LL TRY TO KEEP IT SHORT, BUT MY INTERPRETATION OF THIS NPRR IS MEANT TO ADDRESS PRICE, PRICE FORMATION CONCERNS, UM, AND WE'VE BEEN TOLD THAT WE SHOULD PUSH IT THROUGH BECAUSE IT IS DIRECTIONALLY RIGHT. UH, WHAT WE HAVEN'T BEEN GIVEN IS CONTEXT TO HOW MUCH OF A PRICE IMPACT THIS WOULD'VE HAD LAST SUMMER. AND, YOU KNOW, I THINK THAT'S THE REASON FOR SOME OF THE DIVIDE WE'RE SEEING HERE. UH, MY PERSONAL OPINION IS THIS GROUP SHOULD BE MORE CONCERNED ABOUT DESTINATION THAN DIRECTION, ESPECIALLY IN TERMS OF PRICE FORMATION. THE JEFF AND JEFF HAVE ALREADY KIND OF LAID OUT THE FOUNDATION OF THE ISSUE HERE. UM, THERE'S A DISAGREEMENT ABOUT ECRS PLAN SIZE, UM, YOU KNOW, LCRA IS VIEWING THIS NPR THROUGH THE LENS THAT THE PLAN IS RIGHT SIZED BASED ON A RE-REVIEW OF THE PLAN BY ERCOT. UM, SO I THINK WHEN YOU LOOK AT IT LIKE THAT, THESE RESERVES HAVE VALUE, WHICH REMI HAS POINTED OUT, AND JEFF HAS POINTED OUT. AND WHAT THIS GROUP SHOULD BE LOOKING TOWARDS IS GUIDANCE ON WHAT THAT VALUE IS. AND I THINK WHAT WE CAN DO TO WALK DOWN THAT PATH IS TO LOOK AT WHAT WOULD HAPPEN UNDER THE MECHANISMS OF THIS NPRR AT A 40 MEGAWATT UNDER GEN PENALTY ON THE CURVE, THERE IS A TRADE OFF FOR ERCOT TO SUBSTITUTE RESERVES FOR ENERGY. AND WHAT DOES THAT TRADE OFF VALUE? IT'S $1,000. THE PRICE AT THAT TIMEFRAME FOR THOSE THREE SC INTERVALS WILL BE AT LEAST $1,000. SO, IN MY MIND, THAT GIVES US DIRECTION TOWARDS WHAT A DESTINATION FOR A PROPER PRICE SHOULD BE FOR THE ECRS RELEASE. AND I WOULD URGE THOSE, UH, THAT IN THIS VOTE TO AT LEAST CONSIDER THAT, UM, WHEN THEY ARE MAKING THEIR DECISION. THANK YOU. THANK YOU, ERIC. YES. I'M, I'M GONNA STEP BACK AND TAKE A BIGGER PICTURE VIEW ON THIS. UM, PROCURING MORE ANCILLARY SERVICES IN SHOULDER MONTHS, ECRS, MAYBE LONG-TERM DRRS MAKES SENSE. IF YOU WANNA RUN THE SYSTEM CONSERVATIVELY, THERE'S A LOT. YOU, YOU HAVE UNUSUAL WEATHER. WE HAVE MORE VARIABILITY AND OUTPUT, UH, OF GENERATION BECAUSE OF THE INCREASING PENETRATION AND RENEWABLE. SO IT MAKES SENSE TO INCREASE THE PROCUREMENT FROM A RELIABILITY POINT OF VIEW. IF ERCOT IS BEING ASKED TO RUN THE SYSTEM MORE CONSERVATIVELY DURING THE SUMMER, IT IS A REDUNDANT REQUEST. AND WHAT DO I MEAN IS THAT FOR THE LAST TWO DECADES, THIS ENERGY ONLY MARKET HAS RUN ON THE IDEA THAT SCARCITY PRICING AND SENSE COMMITMENT AND COMMITMENT IS INCENTED BY CONTRACTING BILATERALLY. OKAY? SO EVERYONE PRETTY MUCH FIGURES, IF YOU'RE IN MID-AUGUST AND YOU'RE HITTING RECORD HIGHS AND YOUR RECORD HIGHS EVERY SINGLE DAY, THAT EVERY UNIT, EVERY RESOURCE IS GONNA BE AVAILABLE TO THE DEGREE IT CAN. NO ONE SITTING BACK AND SAYING, I DON'T THINK SO. SO THE PROCUREMENT OF THE EXTRA PROCUREMENTS ARE REDUNDANT IN THAT REGARD. AND IT'S, SO, AND THIS IS BECOMING SO BECAUSE OF YURI, THE KNOWLEDGE OF THE RISK OF RELIABILITY INCIDENTS DURING SUMMER SO HIGH THAT IT'S ON THE TV. AND MY KIDS SAY ONCE IN A WHILE, HEY, DAD, THEY'RE TALKING ABOUT ERCOT AGAIN ON THE TV, RIGHT? UM, SO IT SEEMS TO ME THAT THE IMM HAS IT RIGHT IN THE SENSE THAT THE OVER PROCUREMENT IS ESSENTIALLY ARTIFICIALLY RESTRICTING THE ABILITY OF THE MARKET PARTICIPANTS TO BILATERALLY CONTRACT AT A, AT A, AT A, AT A MORE EQUITABLE PRICE AND INVOLVING RELIABILITY, MARKET RISK, ET CETERA. AND SO THE THOUSAND DOLLARS IS AN ARTIFICIAL CONSTRUCT DURING THE HEIGHT OF SUMMER, WHICH I ASSUME IS THE, THE LARGEST PART OF THE COST ASSOCIATED WITH THE, UM, UM, COST OVERRUNS THAT THEY TALK ABOUT. SO WE DEFINITELY SUPPORT THE I'S COMMENTS AS PART OF THIS PROCESS BECAUSE IT REFLECTS THE REALITY OF HOW THE MARKET WORKS. NOT JUST RELIABILITY, BUT ALSO HOW THE MARKET WORKS AS WELL. THANK YOU. THANK YOU. AND I DO HAVE A UPDATE AND A HISTORY LESSON. WE HAVE ALLOWED TWO MOTIONS TO AMEND BEFORE THE LAST TIME WAS IN 2013 ON NPRR 5 68, WHICH IMPLEMENTED THE ORDC. SO REMI OUTTA FAIRNESS, IF, IF YOU WANTED TO MAKE A SECOND MOTION TO AMEND, SO CAN I JUST, WOULD IT BE AMENDING THEIR MOTION OR WOULD IT BE AMENDING? YOU'D BE AMENDING THE SEC, THE SECOND MOTION TO AMEND. WE'D HAVE TO, TO TAKE A VOTE ON THAT. AND THEN THE VOTE ON THE FIRST MOTION TO, I JUST, YEAH, WE GO BACK. I JUST WAIT, WAIT FOR THIS [01:30:01] TO GO THROUGH AND THEN I'LL, THAT'S WHAT CORY WOULD PREFER, BUT A TERRIBLE, UM, RIGHT NOW WE'RE ON A SUPPLEMENTAL MOTION TO AMEND THE MAIN MOTION. THERE'S NO RULES TO MAKE A SUPPLEMENTAL ON THE SUPPLEMENTAL. WE NEED TO TAKE IT UP A, A MISTAKE THAT WAS MADE IN 2013 BEFORE I WAS HERE. I'M, IT'S REGRETTABLE. I'M SO SORRY. WE WOULD NOT HAVE THE ORDC BUT FOR TWO MOTIONS TO AMEND. NO, YOU WOULD, YOU WOULD HAVE THOUGH, BECAUSE ALL YOU NEED TO DO, YOU WOULD HAVE IT. NO MOTION HERE SUCCEEDS UNLESS TWO THIRDS OF YOU WANT IT. SO IF YOU GUYS LIKE SMIS IDEA OF, I'D LIKE TO GO BACK TO THE PRS REPORT AND TALK ABOUT DESKTOP EDITS TO CHANGE THE THOUSAND VOTE NO ON THIS SO THAT YOU DO NOT TURN THE MAIN MOTION INTO THE IMM COMMENTS. SO IF THAT'S A ROUTE Y'ALL WANT TO GO, YOU CAN DO THAT. YOU DON'T HAVE TO TRY TO AMEND THE AMEND THE AMEND ADDRESS THIS. AND IF THAT'S WHAT TWO THIRDS OF Y'ALL WANT, THAT'S WHAT WILL HAPPEN. YOU DON'T, YOU DON'T HAVE TO PLAY A PROCEDURAL GAME OF WHOSE MOTION GETS PUT ON THE TABLET FIRST. IT'S JUST WHATEVER TWO THIRDS OF Y'ALL WANT IS WHAT THE ACTION OF TACK WILL BE. I'M SO SORRY FOR THAT. COREY, LET'S GO TO NED . ALRIGHT, UM, I'M GONNA TRY TO BE QUICK. UH, FIRST OF ALL, I, I DO WANNA SAY, UM, YOU KNOW, I REALLY APPRECIATE THE I'S ENGAGEMENT ON THIS. I, I, WHEN I STARTED OFF SAYING, YOU KNOW, REASONABLE MINDS MAY DIFFER, WHAT I WAS GETTING AT IS I REALLY APPRECIATE THE, THE ENGAGEMENT Y'ALL HAVE HAD. I ECHO JEFF'S COMMENTS THAT THE MORE WE'VE TALKED, I THINK THE MORE WE'VE UNDERSTOOD WHERE EACH OTHER COMING FROM, AND THAT'S, UH, YOU KNOW, THAT'S VALUABLE. I THINK THAT'S WHAT THAT, WHAT TAX SHOULD BE TRYING TO FOCUS ON DOING AS WE WORK THROUGH SOME OF THESE REALLY COMPLICATED ISSUES. SO, UM, WHILE, WHILE WE MAY NOT, WE MAY NOT AGREE ON THE RIGHT OUTCOME, I THINK WE'VE HAD A, A GOOD DIALOGUE IN THE PROCESS. SO, UM, FIRST OF ALL, WANTED TO SAY THAT, UM, AND I THINK I'LL ECHO WHAT, UH, WHAT BLAKE HAD SAID ABOUT, YOU KNOW, JOINT COMMENTERS. LOOK AT THIS NOT FROM, YOU KNOW, NOT FROM THE WAY THAT, YOU KNOW, SOMEONE WOULD ARGUE THE WORLD OUGHT TO BE. WE TAKE IT AS, AS A GIVEN. SO IF ERCOT OPERATIONAL PREFERENCES ARE WHAT THEY'RE, BLESS YOU, , UH, IF, IF ERCOT OPERATIONAL PREFERENCES ARE WHAT THEY ARE, THE MARKET NEEDS TO REFLECT THAT. AND THAT'S, THAT'S THE FUNDAMENTAL PRINCIPLE THAT, THAT WE'RE GETTING AT. WE'RE WE'RE, WE'RE TAKING THAT AS A, AS A GIVEN AT ANY GIVEN POINT IN TIME AND JUST SAYING WE DON'T WANT THOSE TO BE DISCONNECTED. UM, WE'VE SEEN HOW THAT PLAYS OUT IN THE PAST. THAT'S, UH, THAT THAT'S GIVEN US A LOT, LOT OF, UH, NIGHTMARES ABOUT RUCKS IN, IN RECENT YEARS. AND, UM, SO THAT'S, THAT'S THE OVERARCHING PRINCIPLE THAT WE'VE, WE'VE, UM, TRIED TO EMBODY IN THAT AS WELL AS, YOU KNOW, THE TRYING TO BRIDGE TWO WORLDS CONCEPT. UM, AND I I WILL SAY NO, NO OFFENSE TAKEN ON THE, ON THE CR DRAWING, I WILL BE THE FIRST TO ADMIT MY LIMITATIONS. , THAT'S, UH, THAT'S, UH, THAT'S DEFINITELY ONE OF 'EM. UM, BUT REALLY THAT WAS JUST MEANT TO BE A, YOU KNOW, A HELPFUL REPRESENTATION OF, OF THE PRINCIPLE THAT WE WERE TRYING TO, TO REFLECT. UM, I DO THINK ONE OF THE THINGS THAT'S COME OUT OF OUR, UH, OUR CONVERSATIONS HAS BEEN, UM, REALLY THAT DIFFERENCE OF, OF PERSPECTIVE ON WHAT THE VALUE OF RESERVES ARE UNDER THE CURRENT OEDC FRAMEWORK VERSUS THE ANCILLARY SERVICE DE ANCILLARY SERVICES DEMAND CURVES UNDER REALTIME CO OPTIMIZATION. AND THE BIG DIFFERENCE THERE IS, WHAT I THINK JEFF WAS GETTING AT, IS THAT THERE ARE DIFFERENT QUALITIES OF RESERVES. THE ODC TODAY DOESN'T CARE IF YOU'RE A BATTERY THAT ONLY HAS FIVE MINUTES. STATE OF CHARGE LEFT, DOESN'T MATTER IF IT'S A CONTROLLABLE LOAD RESOURCE, IF IT'S A GAS, UH, QUICK START GAS PLANT THAT HAS FIRM FUEL OR ONSITE FUEL OR, YOU KNOW, A SLOW MOVING RESOURCE BASE, LOAD RESOURCE THAT, YOU KNOW, HAS LSL TO HSL BUT IS PROBABLY NOT GONNA GET THERE IN THE NEXT 30 MINUTES. DESPITE THAT, THAT'S THE, THE FRAMEWORK OF THE ORDC, THE ANCILLARY SERVICE DEMAND CURVES PIVOT. AND THEY SAY, NO, WE HAVE A VERY SPECIFIC RANK ORDER IN OUR PREFERENCE FOR RESERVES. AND GENERALLY SPEAKING, THE FASTER THE BETTER. AND, UM, YOU KNOW, WE WANT THOSE FASTER RESERVES AND WE'RE GONNA VALUE THOSE APPROPRIATELY. AND SO THAT'S, THAT I THINK IS ONE OF THE BIG DIFFERENCES IN, IN THE WAY THAT WE'VE, WE'VE VIEWED THIS. SO, UM, ANYWAY, WITH, WITHOUT, UH, JUMPING THE GUN, UM, ON, ON RASHMI'S COMMENTS, I, I, I WOULD NOT ACCEPT A FRIENDLY AMENDMENT. I DO THINK THAT THE, THE PRINCIPLE BASIS THAT WE'VE LAID OUT IS THAT THE PRS REPORT IS MOST CLOSELY LINKED TO THE ANCILLARY SERVICE DEMAND CURVES. AND I THINK WE SHOULD BE, UH, VOTING ON THAT FIRST AND FOREMOST. AND WITH THAT, I WILL, UH, OKAY. GET OUTTA THE WAY. BOB HILTON. YEAH, REAL QUICKLY, I LIKE TO BOIL THINGS DOWN. UH, REALLY IT COMES DOWN TO TWO THINGS. THEN I GOT ANOTHER COMMENT AFTER THAT IN THE I'S POSITION AND, AND DOWN HERE WITH THE, THE CONSUMERS, THE STARTING PLACE IS THERE'S TOO MUCH BEING BOUGHT AND THEREFORE THERE'S NO VALUE ON THOSE RESERVES WHENEVER THEY'RE RELEASED. ERCOT IS NOT IN THAT CAMP NORM. AND SO THEY'RE, THEY VALUE THOSE, THEY BUY THEM, THEY SEE VALUE IN THEM. ALL THE JOINT COMMENTER'S COMMENTS ARE DOING IS PLACING THAT VALUE ON THEM. AND THAT'S WHAT WE'RE DOING WITH THOSE COMMENTS. NOW, THERE'S ONE THING THAT WAS SAID BY THE IMM [01:35:01] THAT SAID THAT, WELL, WHEN THEY'RE RELEASED, UH, YOU WOULDN'T EXPECT ALL OF THAT 500 TO BE, TO BE DEPLOYED. YOU CAN'T SAY THAT BECAUSE YOU DON'T KNOW WHAT THE OFFER CURVE'S GONNA BE FOR WHAT THEY'RE PUTTING IN. I'M OUT THERE, I'M SETTING, I'M GETTING A, A CAPACITY PAYMENT FOR ECRS. NO, I'M GONNA GET RELU REDO, YOU KNOW, GET POTENTIALLY DEPLOYED. I MAY ADJUST MY OFFER CURVE FROM BEHAVIORAL CHANGES THAT WOULD MAKE SURE THAT WHENEVER I GOT DEPLOYED ON ECRS, I GOT DISPATCHED. AND THAT'S WHAT WE'RE WORRIED ABOUT WITH SOME OF THE PRICE REVERSAL ISSUES. 'CAUSE WHERE THAT COMES FROM, 'CAUSE WE'VE SEEN IT IN THE PAST. JOHN, JOHN RUSS HUBBARD WITH TIC, UH, I THINK WE APPRECIATE ALL THE COMMENTS THAT HAVE BEEN MADE. IT'S BEEN A HELPFUL DIALOGUE. UH, WE CONTINUE TO SUPPORT THE I'S APPROACH. UM, AND I THINK IT'S, IT'S NOTABLE ERCOT FILED THE NPRR WITH NO PRICE FLOOR. SO WHILE ERCOT MIGHT HAVE SOME VALUE IN KEEPING THESE RESERVES AND VALUING THESE RESERVES WITHOUT ADDITIONAL STUDY AND FIGURING OUT EXACTLY WHAT TYPE OF A FLOOR IS APPROPRIATE, I I, I THINK THAT TAKES MORE STUDY. AND SO TODAY, MOVING FORWARD WITHOUT A FLOOR MAKES THE MOST SENSE ON A TEMPORARY BASIS. IT'S ONLY GONNA BE AROUND FOR A YEAR. AND YOU HEARD THAT ERCOT IS WORKING ON A SUBSEQUENT NPRR THAT WILL HOPEFULLY HAVE MORE OF AN ANALYSIS, UM, TO JUSTIFY, POTENTIALLY JUSTIFY A FLOOR. BUT AT THIS POINT, TODAY, A, A FLOOR DOESN'T MAKE SENSE. THANK YOU. OKAY, THANKS JOHN. MY INITIAL THOUGHT WAS TO TRY TO WRAP UP WHERE, WHERE THAT QUEUE ENDED WITH JOHN, BUT YEAH, LET'S, I WAS JUST THE, THE COUPLE IN THERE, BUT LET'S TRY TO, I WAS ACTUALLY HIM TO CALL THE QUESTION IN CASE WE GOT THAT FAR. SO I, I THINK WE, AT THIS POINT, I'M READY TO CALL THE QUESTION ERIC AND REMI, DID YOU, YOU YOU WANT TO VOTE TO CALL THE QUESTION OR CAN WE SKIP THAT VOTE AND JUST, I THINK JOHN HUBBARD PRETTY MUCH COVERED WHAT I WAS GONNA SAY, SO, OKAY. YEAH, I, I'D REALLY JUST LIKE TO VOTE. OKAY. YEAH, GO AHEAD. OKAY, COREY, WHAT ARE WE VOTING ON? OKAY, SO RIGHT NOW THIS IS THE MOTION TO AMEND THE MAIN MOTION TO BE APPROVAL OF 1224 WITH THE FIVE 17 IMM COMMENTS THAT REMOVED THE OFFER FLOOR. SO THIS IS JUST A VOTE TO DECIDE WHAT VOTE Y'ALL WANT TO TAKE NEXT. SO NED'S ORIGINAL MOTION WAS AS P AS FROM PRS WITH A THOUSAND DOLLARS PRICE FLOOR. WE HAVE A MOTION TO AMEND THAT MOTION TO INSTEAD BE WITH THE IMM COMMENTS, WHICH WOULD REMOVE THAT PRICE FLOOR. THIS IS JUST TO DECIDE WHAT THE MAIN MOTION WILL BE. SO YOU'RE JUST VOTING ON WHETHER YOU WANT TO CHANGE THE MAIN MOTION TO BE WITH THE IMM COMMENTS. SO IF THIS SUCCEEDS, WE'LL THEN TAKE A VOTE AS AMENDED BY THE IM COMMENTS. IF THIS FAILS, WE'LL BE BACK TO NED'S MAIN MOTION, WHICH IS JUST THE AS SENT BY PRS. YEAH. SO THIS IS NOT A UP OR DOWN VOTE ON EITHER. CORRECT. THIS IS JUST A PROCEDURAL VOTE TO DECIDE WHICH MAIN MOTION Y'ALL WOULD PREFER TO TAKE UP. SO, GREAT. SO ON THIS MOTION TO AMEND THE MOTION TO BE WITH THE MAY 17TH IMM COMMENTS, WE WILL START UP WITH ERIC. YES. CONSUMERS. WITH ERIC. THANK YOU. NARAJ. YES. THANK YOU, GARRETT. YES, SIR. THANK YOU, ERIC. YES, THANK YOU. THANK YOU, UH, RICK FOR MARK? YES, THANK YOU. AND THEN RICK FOR NICK? YES. THANK YOU. ONTO OUR CO-OPS. MIKE? NO THANK YOU, BLAKE. NO, THANK YOU ERIC. NO, THANK YOU LUCAS. FOR JOHN? NO, THANK YOU. ONTO OUR INDEPENDENT GENERATORS. BRIAN? NO, THANK YOU, CAITLIN. NO, THANK YOU. BOB. NO SIR. THANK YOU, SIR. NED? NO, THANK YOU. CO HERE ONTO THE IPMS. RASHMI? NO, THANK YOU, JEREMY. NO, THANK YOU. THANK YOU, IAN. NO, THANK YOU. CO. THANK YOU KEVIN. NO, THANK YOU. THANK YOU. ONTO OUR IRES. BILL. YES, THANK YOU, JENNIFER. YES, THANK YOU. UH, JAY, WE'RE RIGHT AT THE WINDOW, SO I DON'T IF YOU'RE, IF YOU'RE STILL HERE. OTHERWISE HIS PROXY GOES TO CHRIS. YOU WITH US, JAY? OKAY. PUT YOU ON THE SPOT. CHRIS, HOW ABOUT CHRIS OR J? YES. OKAY. AND THEN CHRIS FOR YOURSELF? YES. THANK YOU. ANDRE. IOUS. STACEY FOR KEITH. UPSETTING. OKAY. THANK YOU. DAVID ABSTAIN. THANK YOU, COLIN. NO, THANK YOU RICHARD. UH, NO THANK YOU. ANDRA MUNI IS RUSSELL. NO THANK YOU JOSE. NO, THANK YOU DAVID. NO, THANK YOU. AND ALICIA? NO. OKAY. MOTION TO AMEND. THE MOTION FAILS WITH 64% AGAINST IT TO ABSTENTIONS. SO NOW WE ARE BACK TO THE MAIN MOTION. [01:40:02] OKAY. CAN WE VOTE ON THIS MOTION OR DO WE NEED TO TAKE RESUME AND BILL'S COMMENTS? YOU HAVE TO VOTE ON THIS. WE HAVE TO VOTE THIS MOTION. WE CAN VOTE ON THIS MOTION. WE CAN, MY COMMENTS ARE RIGHT FOR DISCUSSION. NOW DISCUSS IF POSSIBLE WE'RE GONNA, WE CAN'T AMEND THIS THOUGH. OKAY. GO AHEAD. BILL. CAN'T AMEND THIS. WE CANNOT. NO. A MOTION TO AMEND AN ORDER. NOW THAT YOU'RE BACK TO THE MAIN MOTION, I DON'T THINK YOU COULD MAKE THE SAME MOTION TO AMEND. YEAH, YOU CAN. YEAH. MOTION. WE WOULD, THAT WOULD JUST BE FILIBUSTERING. BUT IF YOU WANTED TO TRY TO, NED ALREADY SHOT DOWN FRIENDLY DESKTOP EDITS. SO THIS WOULD BE, ONE COULD ALSO SAY, IF YOU DON'T AMEND THIS VOTING NO ON THIS WOULD THEN CLEAR THE BOARD. YOU'RE BACK TO NO MAIN MOTION. SOMEONE CAN MAKE A MOTION TO A RECOMMEND APPROVAL OF THE PRS REPORT WITH DESKTOP EDIT. SO WE'RE BACK TO TWO THIRDS CAN GET IT DONE, WHATEVER YOU GUYS GUYS WANT. OKAY. YEAH. MY MOTION WAS TO DO A FRIENDLY AMENDMENT FOR HIS TWO 500, BUT HE ALREADY DECLINED IT, SO, OKAY. I'LL MAKE A, IF THIS FAILS, I'LL MAKE A MOTION FOR 500. OKAY. BILL, DID YOU HAVE A COMMENT OR I WOULD LIKE DISCUSSION ITEM. I WOULD LIKE TO MAKE A MOTION TO AMEND. OKAY. WHAT IS THE MOTION TO AMEND ON AN ATTEMPT AT A COMPROMISE? UH, AMEND THE PRS REPORT. THE OFFER FLOOR TO $500. IS THERE A SECOND? AND SO THIS IS NOT A UP OR DOWN ON 500. COREY, DO YOU WANNA DO YOUR WHOLE SPIEL AGAIN? IT'S JUST ANOTHER MOTION TO AMEND THE MOTION THAT WE'D BE VOTING ON. CORRECT. THIS WOULD BE, AND I CAN PULL IT UP. THIS WOULD BE TO TAKE THE PRS REPORT AND MAKE A BUNCH OF DESKTOP EDITS TO TURN ALL OF THESE THOUSANDS INTO 500 INSTEAD. AND THAT WOULD BE THE, THE MOVER AND SECONDERS WISH THAT THE MAIN MOTION BECOME PRS REPORT AS REVISED BY TAC, WHERE THE TAC REVISIONS WOULD BE LOWERING ALL OF THESE THOUSANDS TO 500. BUT IF YOU SUPPORT THE THOUSAND VOTING TO SAY, I DON'T WANNA AMEND IT DOES NOT NECESSARILY CONFLICT WITH LATER. IF THE THOUSAND FAILS, SAY YOU GOT IT EXACTLY RIGHT. FIVE. YEAH, WE STILL WOULDN'T BE VOTING ON THE LANGUAGE ITSELF. WE BE VOTING ON, WE'RE STILL ON THE THOUSAND. THE MAIN MOTION THAT YOU WANT TAKE. OKAY. OKAY. CAN YOU CLARIFY AGAIN? SO IF THIS ONE FAILS, YOU CAN STILL PUT A $500. YES, IT'S A DIFFERENT MOTION. 'CAUSE THIS IS NOT A SUBSTANTIVE MOTION. THIS IS JUST A MOTION TO AMEND THAT. NO, IF THIS, IF THIS MOTION FAILS, WE'RE BACK TO NED'S WHERE THERE IS NO DESKTOP EDIT. YES. IT'S JUST CLEAN. AND THEN AFTER THAT, IF THAT FAILS, WE COULD STILL MAKE THE DESKTOP EDIT. THAT'S NOT THE SAME MOTION AS THIS. 'CAUSE THIS IS NOT A SUBSTANTIVE MOTION. THIS IS JUST A MOTION TO AMEND THE MOTION. ACTUALLY, CAN I JUST ASK A POINT OF ORDER JUST TO MAKE SURE WE'RE ALL ON THE SAME PAGE. IF A, IF THE MOTION TO AMEND AT 500 FAILS, WOULD ANOTHER EVEN MAIN MOTION FOR 500 BE AN ORDER LATER? IT WOULD BE ALLOWED, RIGHT? BECAUSE THIS IS NOT A SUBSTANTIVE MOTION, CORRECT? IT'S, YEAH. IT, THIS IS A SUBSTANTIVE, THIS IS A SUBSTITUTE MOTION THAT SOMEONE'S MAKING. SO YEAH, IN THE SPIRIT OF IT, YOU'D HAVE, YOU'D PROBABLY HAVE TO LOOK TO THE GROUP TO DECIDE IF ENOUGH HEARTS AND MINDS HAD CHANGED IN THE COURSE OF IT. BUT I THINK ON THE TECHNICALITY BASIS, BECAUSE THIS ISN'T A MAIN MOTION, IT WOULD BE ALLOWABLE. OKAY. ONLY IF ONLY IF NEDS FAILS. SO, SO IT WILL BE ALLOWED ANOTHER $500. YES. OKAY, THANKS. BECAUSE THIS IS NOT A SUBSTANTIVE MOTION. IT'S JUST A MOTION TO CHANGE THE MOTION. RIGHT. BUT, BUT IN SPIRIT OF IT, IF, IF TWO THIRDS OF YOU DON'T WANT TO AMEND THE MOTION TO BE THIS, THEN SOMEBODY MAKING A MOTION AND SECOND FIVE MINUTES FROM NOW, IT, THE SPIRIT OF IT IS WHY IN BETWEEN THAT WE WOULD VOTE ON NED'S MOTION. SO THAT CHANGES THE CIRCUMSTANCES. YES. OKAY. LET'S, LET'S VOTE ON THIS, PLEASE. COULD WE DISCUSS THE MOTION? SO I DON'T WANT TO BELABOR THIS ANY LONGER THAN I HAVE TO, BUT I DO WANT TO SAY THAT WE APPRECIATE THAT THERE IS A MOTION TO HAVE AN EARLIER TRIGGER. THANK YOU. BUT IT'S NOT A, IT'S NOT A MOTION FOR EARLIER TRIGGER YET. IT'S A MOTION TO CHANGE THE MOTION TO ONE WITH AN EARLIER TRIGGER. WELL, IT, IT, IT INCLUDES AN EARLIER TRIGGER IN THE LANGUAGE. ALL OF IT DOES SO FAR. GO FOR IT. OKAY. SO AGAIN, WE'RE JUST MAKING A MOTION TO AMEND THE MOTION TO DECIDE WHAT MAIN MOTION YOU GUYS WOULD LIKE TO VOTE ON. SO INSTEAD OF THE IMM COMMENTS, NOW WE'RE BACK TO THE PRS REPORT WITH LOWERING THE FLOOR FROM A THOUSAND TO 500, AS THOSE WOULD BE DESKTOP EDITS BY T. SO IF YOU WANTED THAT TO BE YOUR MAIN MOTION VOTE YES ON THIS. IF YOU'D LIKE TO GO BACK TO NED'S VERSION, VOTE NO ON THIS. ALRIGHT, [01:45:01] WE WILL START UP WITH THE CONSUMERS. WITH ERIC. NO Q NOT BARRAGE. NO. THANK YOU GARRETT. NO, SIR. THANKS SIR. ERIC? NO, THANK YOU. THANK YOU RICK FOR MARK. NO, THANK YOU RICK. FOR NICK. NO THANK YOU. ONTO THE CO-OPS. MIKE? NO THANK YOU BLAKE. NO, THANK YOU ERIC. NO, THANK YOU LUCAS. FOR JOHN. NO, THANK YOU ONTO THE INDEPENDENT GENERATORS. BRIAN, COME BACK TO ME. CAITLIN. NO, THANK YOU. BOB. NO SIR. THANK YOU, NED. NO, THANK YOU. COREY. THANK YOU. ONTO THE IPMS RUSH. ME. NO, THANK YOU JEREMY. NO, THANK YOU. IAN. NO, THANK YOU. COREY. THANK YOU KEVIN. NO, THANK YOU. THANK YOU. ONTO THE I REPS. BILL. WE GOT THIS GUYS. YES. . JENNIFER? YES. ENTHUSIASTIC? YES. OH YES. CHRISTOPHER J YES. AND CHRIS? YES. THANK YOU. ONTO THE IOUS STACEY FOR KEITH ABSTAIN. THANK YOU. DAVID ABSTAIN. THANK YOU, COLIN. YES. THANK RICHARD. UM, YES, THANK YOU. ONTO THE MUNIS RUSSELL. YES. THANK YOU JOSE. YES. THANK YOU, DAVID. YES, THANK YOU ALICIA. YES. THANK YOU BRIAN. NO MOTION FAILS ABOUT TWO THIRDS AGAINST TWO ABSTENTIONS. SO NOW, SO NOW WE ARE BACK TO NED'S ORIGINAL MOTION. CORRECT. ALRIGHT. ON WHICH I HOPE WE CAN VOTE. WE WILL. I SEE NOBODY IN THE QUEUE. YES. YOU MAY MAKE ONE COMMENT. IT'S A COMIC RELIEF COMMENT. COREY, IF I, NEXT TIME I WATCH A TIME TRAVEL MOVIE OR INCEPTION, I, I, I WANT YOU TO BE THERE. 'CAUSE I THINK YOU'LL YOU'D BE AN EXCELLENT CO-PILOT FOR THAT. FAIR ENOUGH. DON'T INTERACT WITH YOUR PARENTS. I, I WAS ALSO TOLD WE'VE DONE THE DOUBLE AMENDMENTS MULTIPLE TIMES. COREY, WE'RE GONNA FIND AN INSTANCE OF ONE WHEN YOU WERE HERE. I I, I THINK THE DOUBLE AMENDMENT IS ALLOWED, BUT THIS MIGHT BE A LITTLE BIT CLEANER. OKAY. LET'S VOTE ON NEXT MOTION BEFORE. I LOVE COREY KICKS US ALL OUT. YEAH, I, I'VE DONE THE RESEARCH AND COULDN'T FIND, UH, ANYTHING THAT EXPRESSLY ALLOWED. SO THERE'S SIMULTANEOUS RESEARCH HAPPENING DURING . I THINK I AGREE WITH ANN, BUT I LIKE THE CLEANNESS OF THIS. I THINK. ANYWAY, WE'RE, LOOK, I'M LOOKING FORWARD TO VOTING RIGHT NOW. YEAH. UM, ALL RIGHT. BACK TO NED'S MOTION WITH THE PRS REPORT AS SENT. UH, WE WILL START UP WITH THE CONSUMERS, WITH ERIC. NO THANK YOU. NO BARRAGE. NO THANK YOU GARRETT. NO SIR. THANK SIR. ERIC? NO, THANK YOU. THANK YOU RICK FOR MARK. NO, THANK YOU RICK. FOR NICK. NO, THANK YOU. ONTO THE CO-OPS. MIKE? YES. THANK YOU, BLAKE. YES. THANK YOU ERIC. YES. THANK YOU LUCAS FOR JOHN? YES. THANK YOU. INDEPENDENT GENERATORS. BRIAN? YES. THANK YOU, CAITLIN. YES, THANK YOU, BOB. YES SIR. THANK SIR NED? YES. THANK YOU, SIR. THANK YOU. ON THE IPMS RASHMI. YES. THANK YOU, JEREMY. YES. YES. THANK YOU. THANK YOU. IAN. YES. THANK YOU KEVIN. YES, THANK YOU. THANK YOU. ON THE I REPS BILL. NO, THANK YOU, JENNIFER. NO, THANK YOU. CHRISTOPHER J NO. AND THEN CHRIS. NO THANK YOU ON THE IOUS, STACY FOR KEITH TEXTING. THANK YOU, DAVID. YES, THANK YOU, COLIN. YES, THANK YOU RICHARD. YES. THANK YOU. ONTO THE MUNIS RUSSELL. NO, THANK YOU. JOSE ABSTAIN. OKAY. AND DAVID ABSTAIN. THANK YOU. AND ALICIA ABSTAIN. THANK YOU. MOTION FAILS. 58% IN FAVOR. 42 AGAINST FOR ABSTENTIONS. SO NOW WE HAVE NO MOTIONS ON THE TABLE. IF NO SUBSEQUENT MOTION IS MADE ON 1224, IT'LL BE DEEMED REJECTED. 5 0 1, BOB, IAN, REMI, BOB, GO FIRST. YEAH. OKAY. COULD, COULD WE GO BACK TO THE JOINT COMMENTERS? UH, OR, OR WELL, THE PO UH, YEAH, [01:50:01] EITHER WAY. THE JOINT COMMENTERS COMMENTS, RIGHT. JUST REAL QUICKLY AND THEN GO BACK TO THE, THAT EXACTLY. THE SDC CURVES. AND FROM LOOKING AT THAT, YOU KNOW, WE THOUGHT WE HAD PUT SOMETHING IN THERE THAT WAS CLOSE, AND NOW WE'VE KIND OF HIT BOTH, BOTH OF THE BOOKENDS. AND IF YOU NOTICE ON THE SECOND ONE DOWN ON THE LEFT, IT HITS, WHICH IS A MORE CONSERVATIVE NUMBER THAN THE THOUSAND DOLLARS. A LITTLE LESS CONSERVATIVE, OF COURSE, THAN THE 500. SO I'D MAKE A MOTION THAT WE SET IT THE FLOOR AT $750 GOING ONCE. OKAY. IS THERE A SECOND FOR BOB'S MOTION AT SEVEN 50? REMI SECOND. IAN, DID YOU WANNA MAKE A COMMENT STILL? OKAY. ARE YOU ABANDONING THE MOTION? ALL RIGHT. SO THE MOTION NOW IS THE PRS REPORT AS REVISED BY DESKTOP EDITS THAT BOB JUST MADE TO SET THE FLOOR AT SEVEN 50. NED. SO STICKING WITH THE, THE PRINCIPLE THAT THAT, YOU KNOW, WAS EMBODIED IN THE JOINT COMMENTS AND TRYING TO LINK TO THE, THE ANCILLARY SERVICE DEMAND CURVES, I, IT SEEMS LIKE THE FURTHER YOU GO DOWN THAT CURVE, THE MORE IT BECOMES, YOU KNOW, A RISK THAT ERCOT RELEASES MORE THAN THE 500 MEGAWATT BLOCK. AND THEN YOU, YOU, YOU DO GET OUTSIDE OF THAT. UM, YOU DO RUN INTO, UM, UNDERVALUING THAT RELEASE AGAIN. SO, UM, BOB, I, I WONDER IF YOU WOULD BE WILLING TO ACCEPT A FRIENDLY AMENDMENT TO LIMIT THE RELEASE TO 500 MEGAWATTS. OKAY. THAT'D BE FINE. OKAY. AND RECIPE'S NODDING TOO. SO COREY IS GOING THROUGH, SO THAT'S THE LIMIT, THE RELEASE TO 500 MEGAWATTS. ALRIGHT, DAN WOODFIN. YEAH. SO NOW YOU GOT ME WAIT, UH, PAYING ATTENTION BECAUSE WE ARE NEUTRAL ON A LOT OF THIS, BUT WE CAN'T LIMIT WHEN WE CAN RELEASE OUR RESERVES FROM RELIABILITY PERSPECTIVE. THAT'S NOT, UH, 'CAUSE ULTIMATELY THAT'S WHY WE BUY THEM AND WE NEED TO BE ABLE TO RELEASE THEM AT THE APPROPRIATE TIME. SO SAY IT'S A FREQUENCY EVENT, WE CAN'T LIMIT WHAT WE WOULD, UH, RELEASE CLARIFICATION, THEN IT WOULD NOT BE LIMITS ON ERCOT ABILITY TO RELEASE IT UNDER ANY CIRCUMSTANCES. IT WOULD BE MANUAL RELEASE FOR THE, UNDER THE UNDER GEN FRAMEWORK THAT'S CONTEMPLATED IN NPR 1224. ESSENTIALLY IT'S RELEASING FOR YEAH. MARKET DAMPENING. OKAY. IKA, DID YOU WANNA ADD? SO I'VE RAISED MY HAND A BIT TOO EARLY. SO, UH, LOOK AT THE LANGUAGE THE WAY IT'S WRITTEN RIGHT NOW. SO WE WOULD RELEASE IT IN UP TO BLOCKS OF 500. I THINK WHAT YOU JUST SAID IS UNDER THE UNDER GEN CONCEPT, YOU WANT US TO RELEASE ONLY 500 MEGAWATTS. UH, I HAD READ IT AS, AS THAT WAS THE, SORRY, I SHOULD SPEAK INTO THE MIC. I HAD READ IT AS, UH, AND THIS MAY HAVE BEEN BASED ON ONE OF THE EARLY PRESENTATIONS, SO IT COULD BE MM-HMM. MISUNDERSTANDING ON MY PART. BUT I HAD READ IT AS ERCOT WILL RELEASE 500 MEGAWATT BLOCK AND THEN COULD BE INCREMENTAL TO THAT. CORRECT? CORRECT. CORRECT. THAT IS WHAT THE LANGUAGE HERE SAYS. SO MAYBE YOU MAY WANT TO TELL US HOW, HOW ARE YOU LOOKING FOR US TO AMEND THE THOUGHT THAT YOU JUST YEAH, MAYBE NO MORE THAN WOULD BE THE RIGHT LANGUAGE. I THINK YOU JUST STRIKE THE LAST SENTENCE ON FIVE TO GET WHERE YOU WANT TO GET. I, I THINK THE QUESTION TO SOME EXTENT COMES TO OH YEAH. AND THAT WHAT HAPPENS IF ANOTHER TWO INTERVALS OF 40 MEGAWATT UNDER GEN HAPPENS? IS THAT ANOTHER TRIGGER FOR MORE DEPLOYMENTS? IS THAT THE SITUATION YOU'RE REFERRING TO? THAT'S THE LAST SENTENCE. YEAH. YEAH, I THINK THAT'S, THAT'S, THAT'S PROBABLY RIGHT. YEAH. 'CAUSE IF THERE, IF YOU HAVE ANOTHER SECOND ROUND OF THAT, THEN YOU GET ERCOT RELEASING MORE AND SO THEN YOU'VE GONE BEYOND THE 500 MEGAWATT BLOCK. THAT'S, AND THAT'S, YOU KNOW, THAT'S WHERE OUR INITIAL FOCUS WAS. BUT IF YOU, IF THEY END UP SAY RELEASING A THOUSAND MEGAWATTS, WELL THEN YOU'RE FURTHER UP THAT CURVE AND, AND WE'VE GOTTEN FURTHER AND FURTHER AWAY FROM, YOU KNOW, THE, THE MIDDLE GROUND BETWEEN TWO WORLDS THAT WE'VE BEEN TRYING TO, TO FORGE A BRIDGE THROUGH. UM, SO [01:55:04] BILL, I'M JUST MAKING IT KNOWN TO TAC MEMBERS THAT I FEEL LIKE EVERYONE DESERVES A SECOND CHANCE. SO IF THIS VOTE HAPPENS TO FAIL, UH, I WILL BE MAKING A MOTION TO, UH, SET THE FLOOR AT 500 AGAIN. THANKS. I SECOND THAT. BOB HILTON. I JUST WANNA ASK, 'CAUSE SINCE DAN SAID SOMETHING ABOUT, UH, THE RELEASE ISSUE BASED ON WHAT WE JUST TALKED ABOUT, DO Y'ALL STILL HAVE AN ISSUE WITH THAT? IF YOU DO, THEN I'LL CHANGE THAT, BUT, UH, I JUST WANNA MAKE SURE LANGUAGE, WHAT LANGUAGE DO YOU WANT? MAYBE THAT MIGHT HELP LESS SENTENCE. SO I THINK THE, BECAUSE WORDS MATTER. YEAH. BECAUSE WORDS MATTER. YES. YEAH. DELETION OF THE LAST SENTENCE. UH, IT , THAT'S A, THAT'S A GOOD CLARIFICATION. YES. WORDS DO MATTER. I THINK DELETION OF THE LAST SENTENCE ADDRESSES THAT. UM, AND THAT WOULD NOT PRECLUDE ERCOT FROM RELEASING OR DEPLOYING ECRS FOR ANY OF THE OTHER, OTHER PURPOSES. IT WOULD ONLY BE IN THIS MANUAL RELEASE CONSTRUCT. SORRY, THIS IS THE DANGER OF DESKTOP EDITS, GUYS. YEP. UM, , POINTED OUT THAT ALSO THE, UH, THAT SENTENCE, YEAH. STARTING WITH FOLLOWING WOULD ALSO BE STRUCK TO BE IN LINE WITH THAT. SO NED, YOU'RE PROPOSING TO REMOVE THE HIGHLIGHTED SENTENCE AND THE LAST SENTENCE? YES. THAT HIGHLIGHTED SENTENCE. AND THE LAST SENTENCE WOULD BE, WOULD BE STRUCK, I GUESS. THANK YOU FOR COMING ON THIS JOURNEY WITH ME GUYS. OKAY. UH, NIKA, DID YOU HAVE ANY THOUGHTS ON THAT OR CAUGHT FEEDBACK? CAN I THROW ONE MORE SCENARIO AT YOU, ? SO RIGHT NOW IT SAYS 40 FOR AT LEAST 10 MINUTES. SAY YOU STRIKE BOTH THOSE STATEMENTS OUT. WE RELEASE ECRS 500 MEGAWATTS UP TO PER THIS BLOCK. AFTER 30 MINUTES, WE HAVE ANOTHER ROUND OF ALARMING THAT WE HAVE A 10 MINUTE WE VIOLATED UNDER JEN PER THE STATEMENT FOR 10 MINUTES. ARE WE, ARE WE, HOW SHOULD WE READ THIS LANGUAGE? SO IF I'M FOLLOWING CORRECTLY, IT'S, YOU'VE HAD ONE TRIGGER, YOU RELEASED THINGS NORMALIZE, AND THEN YOU HAVE IT HAPPEN AGAIN, THEN YOU WOULD DO THIS. YEAH. HAVE YOU, HAVE YOU RESTORED YOUR ANDROGEN SCENARIO SINCE THEN? MAY NOT HAVE, I'M STILL THINKING YOU'RE IN THE AFTERNOON. YOU, YOU'VE STILL NOT YET PASSED THE EVENT FULLY. HOW WOULD ERCOT LIKE , LEMME PUT IT BACK. WHAT IS WHAT? BECAUSE ULTIMATELY THIS COMES DOWN TO ERCOT OPERATIONAL PREFERENCES, RIGHT? WE'RE TRYING TO ALIGN THE MARKET OUTCOME WITH WHAT, WITH WHAT Y'ALL WOULD, WOULD DO. AND WOULD IT MAKE SENSE TO HAVE A SECOND STEP THAT THAT GOES FURTHER UP THE A SDC? BECAUSE THAT'S, THAT'S WHERE, YOU KNOW, THINKING ON THE FLY, I WOULD THINK WOULD THE APPROPRIATE NEXT STEP WOULD BE, UM, AND, UH, GO AHEAD RUSSELL FRANKLIN, WHILE THEY'RE WORKING ON THAT. NO, I WAS JUST GONNA SAY THAT I THINK THAT WE WERE WILLING TO, UH, SUPPORT THE $750 FLOOR, BUT WITH THESE CHANGES NOW, I, I THINK THAT I, I CAN'T SUPPORT IT WITH, UH, TRYING TO TO LIMIT THE 500 MEGAWATTS OR TWO 500 MEGAWATTS. SO, UM, DIDN'T WANT US TO GO TOO FAR DOWN THIS PATH SAYING, HEY, I THINK THAT WE WOULD BE WILLING TO HAVE A FRIENDLY COMPROMISE. BUT NOW WITH WHERE WE'RE AT, I THINK THAT I CAN'T, UM, AGREE TO WHERE WE'RE GOING. THAT'S IT. OKAY. WE'RE, WE'RE WORKING ON LANGUAGE. CAN, CAN I SAY SOMETHING? I, BOB, I THINK BOB, I THINK THERE IS SOME CONCERN WITH THE LIMITING TO 500. SO MAYBE WE SHOULD UH, NOT ADD THAT, BUT OKAY. GIMME [02:00:01] A MINUTE. OKAY. , IF YOU WANT TO KEEP IT SIMPLE. YEAH, I AGREE WITH YOU. OKAY. SO THE FRIENDLY AMENDMENT HAS BEEN UNACCEPTED. IT APPEARS TO BE GETTING OVERLY COMPLICATED. WE THOUGHT IT WAS MORE SIMPLE THAN THAT. IT DOES APPEAR TO BE COMPLICATED. IT APPEARS TO BE A LITTLE MORE COMPLICATED. OKAY. FRIENDLY AMENDMENT. IT'S JUST SEVEN 50 AND NO LIMIT. OKAY. CAN WE VOTE ON THE MOTION? SO NOW IT'S JUST THE SEVEN 50 FLOOR. YES. OKAY. NO OTHER CHANGES. OKAY. WE ALL GOOD? YES. DO YOU WANNA TELL US WHAT THE MOTION IS? SO THIS IS THE MOTION TO RECOMMEND APPROVAL OF THE MAY PRS REPORT THAT STILL HAS THE OFFER FLOOR, BUT WITH DESKTOP EDITS TO LOWER IT FROM A THOUSAND TO SEVEN 50. NO OTHER CHANGES. NO OTHER CHANGES. OKAY. LET'S GO. COOL. WE'LL START UP WITH THE CONSUMERS. WITH ERIC? NOPE. THANK YOU. NARAJ. HELLO. THANK YOU GARRETT. NO SIR. THANK YOU ERIC. NO, THANK YOU. THANK YOU RICK FOR MARK. NO THANK YOU RICK. FOR NICK. NO, THANK YOU. ONTO THE CO-OPS. MIKE? YES. THANK YOU BLAKE? YES, THANK YOU ERIC. YES, THANK YOU LUCAS. FOR JOHN? YES. THANK YOU. ONTO THE INDEPENDENT GENERATORS. BRIAN? YES, THANK YOU CAITLIN. YES, THANK YOU BOB. YES SIR. THANKS SIR. NED, I'LL GIVE HER A RELUCTANT. YES. ALRIGHT, THANKS SIR. ONTO THE IPM. MS. RASHMI? YES. THANK YOU JEREMY. YES, THANK YOU. THANK YOU. IAN? YES, THANK YOU. YOU KEVIN? YES, THANK YOU. THANK YOU. ONTO THE IRES BILL. NO, THANK YOU JENNIFER. NO, THANK YOU. CHRISTOPHER J? NO THANK YOU CHRIS. NO THANK YOU. ONTO THE IOUS. STACEY FOR KEITH? YES, THANK YOU DAVID. YES, THANK YOU COLIN. YES, THANK YOU RICHARD. YES, THANK YOU. ONTO THE MUNIS RUSSELL. YES, THANK YOU JOSE. YES, THANK YOU DAVID. YES, THANK YOU ALICIA. YES, THANK YOU. MOTION CARRIES 67% IN FAVOR. THANK YOU. COREY, CAN YOU LET THEM KNOW THAT WE'LL EMAIL THEM. OKAY. SO FOR NO VOTES WE ARE GOING, ANN WILL EMAIL YOU ON THE, THE REASONS FOR NO VOTES, BUT THOSE ARE NOW INCLUDED AS PART OF THE TECH REPORT. OKAY. CHRIS, HOW DO I MEAN FOR THE KIND OF, HOW DO THE IMM COMMENTS GET TO THE BOARD? YOU CAN REFILE THEM TO THE BOARD. SO THIS TAC REPORT WILL GO TO THE BOARD AND THE IMM CAN FILE COMMENTS AGAIN. OKAY. ARE YOU GOOD ANDREW? YOUR CARD UP? NO. OH, DO YOU HAVE STEVEN'S CARD UP? OKAY. OKAY, SO WE ARE FINISHED WITH THE PRS REPORT. DO YOU WANNA TAKE A QUICK BREAK? 10 MINUTES THERE. LUNCH IS HERE, BUT I WOULD RECOMMEND WE NOT DO LUNCH UNTIL WE ARE READY FOR 2 45. BUT I'M OPEN TO A 10 MINUTE BREAK IF THAT'S WHAT PEOPLE NEED. OKAY, LET'S DO, LET'S DO A 10. I CAN'T STOP YOU FROM EATING BUT , BUT WE'RE GONNA START IN 10 MINUTES. PLEASE. PLEASE EAT BRIAN. UM, 11. SO WE'LL RESUME AT 1145. ALRIGHT, IF EVERYBODY CAN TAKE YOUR SEAT. WE'RE GONNA GET STARTED. GONNA MOVE BACK TO ITEM SIX ON [6. Revision Requests Tabled at TAC (Possible Vote)] THE AGENDA REVISION REQUEST TABLED AT TAC. [02:05:06] WE HAVE THREE ITEMS THAT ARE STILL TABLED AT TAC. IT'S OBDR OH FOUR SIX OBDR OH FIVE ONE AND ER 1 0 5. I BELIEVE THE TWO O BRR CAN REMAIN TABLED AND NO ACTION IS NEEDED ON THOSE. AND ON ER 1 0 5, UH, RAINBOW HAS SUBMITTED A REQUEST FOR WITHDRAWAL. SO I BELIEVE ALL THREE OF THESE CAN, UH, BE ADDRESSED ON THE COMMON BALLOT, CORRECT CORY? THANKS TO THAT. UH, CORRECT. OH, THE OBDS WILL STAY TABLED THE WAY THEY ARE, BUT THEN YES, IF NO ONE OBJECTS PICKER, 1 0 5 WOULD TAKE A VOTE FROM TAC TO APPROVE THE WITHDRAWAL. SINCE IT, SINCE AN ACTION WAS TAKEN AT ROSS, THE SUBMITTER NO LONGER HAS THE LUXURY OF JUST PULLING DOWN AND WITHDRAWING IT. SO IF TAC IS AMENABLE TO ALLOWING P 1 0 5 TO BE WITHDRAWN, YES, WE WOULD THROW THAT ON THE COMBO BALLOT. SO ANY DISCUSSION ON P 1 0 5 OR ANY OF THE OTHER ITEMS SUPPORTED GOING ON THE COMBO? OKAY, WE'LL PUT THOSE ON THE COMBO BALLOT. OKAY, MOVING ON TO THE [7. RMS Report] RMS REPORT. JOHN SCHATZ, I'M HERE FOR THE SAKE OF BREVITY. UH, LET'S GO AHEAD AND JUST SKIP TO SLIDE NUMBER FOUR PLEASE AND I'LL GET OUTTA Y'ALL'S WAY. ALRIGHT, SO, UM, TEXAS SET 5.0 IS BEING IMPLEMENTED IN NOVEMBER OF THIS YEAR. FLIGHT 0 9 2 4 IS THE FLIGHT TEST FOR TEXAS SET 5.0. EVERY LSE MUST TEST AND CERTIFY FOR TEXAS SET 5.0. THE APPLICATION DEADLINE IS JULY 3RD. SIGNUP DEADLINE IS JULY 31ST AND THEN YOU CAN SEE THE, THE DATES FOR TESTING. IF THERE'S ANY QUESTIONS, UH, CERTAINLY CONTACT YOUR ERCOT ACCOUNT MANAGER. AND WE ARE IN THE PROCESS OF PLANNING A BASICALLY A MARKET INFORMATION SESSION, UH, REGARDING HOW TO REGISTER, UH, FOR, FOR FLIGHT TESTING, HOW TO USE FLIGHT TRACK. A LOT OF ENTITIES HAVEN'T TESTED WITH ERCOT PROBABLY SINCE 4.0. UM, SO THIS MAY BE NEW TO A LOT OF PEOPLE. SO, UH, MORE COMMUNICATIONS WILL BE COMING. UH, IF YOU HAVE ANY QUESTIONS, UH, YOU KNOW, SPEAK UP NOW OR JUST, UH, EMAIL ME OR DEBBIE MCKEEVER WOULD CERTAINLY, UH, ANSWER ANY QUESTIONS YOU MAY HAVE. THAT'S IT FOR THE RMS UPDATE. ANY QUESTIONS FOR JOHN? OKAY, THANK YOU JOHN, FOR THE BRIEF UPDATE. GONNA MOVE [8. ROS Report (Vote)] ON TO AGENDA ITEM EIGHT ROS REPORT. KATIE, BELIEVE YOU WAS SEAN, THAT WAS, THAT WAS QUICK. I'M NOT SURE I CAN BEAT THAT AND I'M TAKING MY SEAT, BUT I'M GONNA NOTE WHY I'M TAKING MY SEAT BECAUSE I'M GONNA LET COREY STAY IN THE SPOTLIGHT 'CAUSE I THINK HE DESERVES IT AFTER RUNNING ALL THOSE BALLOTS. SO WE APPRECIATE YOU. THANK YOU, THANK YOU. I DUNNO WHAT THE LAUGH WAS FOR BRIAN, YOU CAN TELL ME LATER. BUT, UM, SO WE'VE GOT TWO, UM, RSS HERE THAT ARE ASSOCIATED WITH NPR 1198. WE TRIED TO DO THESE AS A COMBO BALLOT AT ROSS, BUT THERE WERE DIFFERENT FOLKS ABSTAINING ON THESE. UM, WE ALREADY TALKED ABOUT 1198, SO I'M NOT SURE I NEED TO GO THROUGH THESE. UM, AND THEN WE CAN TAKE THAT VOTE UP IN JUST A SECOND. ALRIGHT, SO LET'S TALK ABOUT SOME RECENT ROCK, ROCK ROSS ACTIONS, IF I CAN SPEAK TODAY. SO, PRS FORMALLY REFERRED 1221 OVER TO US. WE'D ALREADY REFERRED THAT TO OWG AND THEY'D HAD ONE DISCUSSION. WE'VE NOW HAD, UM, TWO DISCUSSIONS ON THESE ITEMS. I BELIEVE ENCORE FILED SOME COMMENTS AND THEN, UM, WE HAVE NOER 2 63. THAT ONE'S OVER AT, UH, P-D-C-W-G, AND THEN 1006. UM, THE IMPORTANCE OF THIS ONE, THIS ONE'S BEEN OUT HERE QUITE A WHILE, UM, BUT THERE IT WAS RECOMMENDED APPROVAL. SO WE WILL BRING THESE BACK FOR, UM, WELL, THE NOER AND THE PIGGER WILL BRING THAT BACK FOR, FOR IA REVIEW. AND THEN, UM, SO AS WE USUALLY DO EACH MONTH, WE, WE NOTE SOME OF THE REVISION REQUESTS THAT ARE STILL WITH US AND WHERE THOSE ARE CURRENTLY BEING DISCUSSED, SO PEOPLE KNOW WHERE TO, UM, CHIME IN. SECOND PAGE IS JUST MORE OF THE SAME. OUR LIST IS GETTING SHORTER IF YOU WANNA NOTE THAT. AND THEN OUR NEXT MEETING, UM, IS IN PERSON ON JUNE 6TH. SO PLEASE SHOW UP, PLEASE, UM, HELP US MOVE QUICKLY THROUGH THAT AGENDA. UM, I DID GET NOTED FOR, I THINK I SET A RECORD FOR COMPLETING [02:10:01] ROSS IN ABOUT AN HOUR AND 15 MINUTES. NOT SAYING THAT I DON'T ALLOW PEOPLE TO MAKE COMMENTS, BUT WE WERE TRYING TO MAKE SURE NOBODY MISSED THE PUC HEARING. AND WITH THAT, UM, I THINK WE'RE READY TO, UH, FIGURE OUT HOW WE WANT TO PROCEED WITH PICKER ONE 13 AND NO, 2 58. THANK YOU, KATIE. I THINK THE EARLIER STANDALONE BALLOT ON NPRR 1198 INCLUDED THOSE TWO ITEMS. UH, SO IF THERE'S NOT ANY OTHER DISCUSSION OR QUESTIONS FOR KATIE, WE'LL MOVE ON TO [9. WMS Report] THE NEXT ITEM. OKAY. AGENDA ITEM NINE. UH, WMS REPORT, ERIC? OKAY. GOOD MORNING TACK. ERIC BLAKEY WITH PERELLIS CO-OP CHAIR OF WMS, UH, HOPE TO BE BRIEF. WE HAD A WEBEX ONLY MEETING ON MAY THE FIRST. WE HAD A COUPLE OF ERCOT ITEMS UPDATES ON, UH, SETTLEMENT STABILITY REPORT AND THE ANNUAL UNREGISTERED DG REPORT HAD AN UPDATE ON FIRM FUEL SUPPLY AND WANTED TO RAISE JUST THIS ONE. UH, WE HAVE ONE TAX ASSIGNMENT, WHICH I'M VERY PROUD OF. WE STARTED WITH 15, UH, JIM AND I WHEN WE CAME ON BOARD, AND WE'RE DOWN TO ONE, SO I DON'T WANT TO JINX IT BY ANY MEANS. BUT I DO WANT TO JUST RAISE THIS TO THE TAX ATTENTION THAT WE ARE AWARE THAT WE HAVE THIS ASSIGNMENT AND THAT, UH, IT HAS TO DO WITH REVIEW, IT IMPACTS OF EXISTING AND PROPOSED EPA REGULATIONS. UH, WE'RE, WE'RE AWARE THAT THERE'S BEEN A RECENT EPA, UH, RULING, UH, RULE MAKING THAT HAS COME OUT. AND I KNOW THERE'S SEVERAL THAT HAVE, UH, IN FACT, THE STATE OF TEXAS HAS FILED AN APPEAL TO THAT. UH, WE'RE, WE'RE WATCHING THAT. UH, WE WILL DO ANYTHING THAT TAC DIRECTS US TO DO. IF YOU'D LIKE US TO, TO DO ANYTHING MORE, UH, PLEASE LET US KNOW. YOU CAN CONTACT US OFFLINE. WE'LL BE HAPPY TO, UH, TO FOLLOW THE DIRECTIONS OF, OF TAC ON THIS ISSUE. NEXT SLIDE. THESE ARE, ARE TABLED, UH, REQUEST AND STATUS. UH, AN UPDATE ON 11. CAN'T READ MY WRITING. 1190 IS THE, UH, HIGH DISPATCH LIMIT OVERRIDE PROVISION FOR INCREASED NO A LOAD COST. AND THAT WAS ENDORSED AND SENT TO PRS AND NPR 1216. UH, IMPLEMENTATION OF EMERGENCY PRICING WAS ENDORSED, UH, WITH THE ERCOT COMMENTS AND VCMR OH THREE NINE, UH, RELATED TO THE EMERGENCY PRICING WAS RECOMMENDED FOR APPROVAL. AND THEN JUST A QUICK UPDATE. WE'D VOTED TO APPROVE, UH, SOME NEW CO-CHAIRS, UH, AND A CHAIR OF DSWG. JUST WANTED TO PROVIDE AN, UH, UPDATED LIST OF OUR CURRENT WORKING GROUP LEADERSHIP. WE'RE VERY PROUD TO HAVE ALL THESE SPOTS FILLED AGAIN, UH, WITH VERY GOOD LEADERSHIP, AND WE'RE VERY THANKFUL FOR THEM FOR, FOR THEIR INVOLVEMENT. SO I THINK THAT'S IT. WE HAVE OUR NEXT MEETING ON JUNE THE FIFTH, AND YOU'RE WELCOME TO ATTEND AND BE HAPPY TO ANSWER ANY QUESTIONS. ANY QUESTIONS FOR ERIC? OKAY. THANK YOU, ERIC. MOVE ON [10. Large Flexible Load Task Force (LFLTF) Report] TO AGENDA ITEM 10, LARGE FLEXIBLE LOAD TASK FORCE REPORT. UH, DO WE HAVE BILL BLEVINS ONLINE? YEAH, THIS IS BILL. UM, JUST A, A REAL QUICK UPDATE. SO, UH, AT THE LAST TASK FORCE, UH, WE COVERED, UH, SOME CHANGES THAT WE'RE MAKING TO, UH, THE ORIGINAL PROPOSED RULES. UM, AT A HIGH LEVEL, THE JUNE 3RD MEETING, WE'RE TARGETING TRYING TO SHOW THE LANGUAGE, UH, WITH THE ADJUSTMENTS, UH, IN MORE DETAIL. AND I THINK THAT WE'LL BE FOCUSED ON THAT. HOPEFULLY WE CAN GET THOSE RULES MOVING FORWARD. UH, NOW THAT WE'VE KIND OF, UH, ADDRESSED SOME OF THE MORE CONFRONTATIONAL ITEMS, SO WE'RE HOPEFUL THAT WE CAN GET THIS LANGUAGE OUT, GET IT REVIEWED, AND GET IT START, STARTED MOVING THROUGH THE STAKEHOLDER PROCESS. THAT'LL BE THE SCOPE OF THE NEXT MEETING. OKAY, THANK YOU, BILL. ANYBODY HAVE ANY QUESTIONS FOR BILL ON THE L-F-L-T-F REPORT? OKAY, UH, AGENDA ITEM [11. RTC+B Task Force Report (Vote)] 11, RTC PLUS B TASK FORCE REPORT. MATT, GO AHEAD. GOOD AFTERNOON, TACK, UH, ABOUT FIVE OR 10 MINUTES. I DO HAVE ONE ENDORSEMENT REQUEST AT THE END OF THE PRESENTATION. SO ONE THING I WANTED [02:15:01] TO SHARE IS A PERSPECTIVE OF WHERE WE'RE AT IN THE, THE PROCESS OF IMPLEMENTING RTC PLUS B. UH, AS YOU'VE SEEN MANY OF YOU MAY HAVE SEEN, UH, AT THE BOARD MEETINGS, WE'RE STARTING TO PRESENT SCHEDULES. NOW, WE DON'T HAVE THE FINAL SCHEDULE AT THIS POINT, BUT WE ARE STARTING TO TRIANGULATE INTO WHAT DOES IT MEAN TO GET THIS SEQUENCE DEVELOPED. AND SO JP HASS BEEN PROVIDING THIS TO THE BOARD, UH, TECHNOLOGY AND SECURITY GROUP. AND THE KEY PIECE HERE IS DOWN AT THE BOTTOM, YOU SEE THE DEVELOP AND PUBLISH EXTERNAL SPECS, WHICH ERCOT IS IN THE PROCESS OF DOING AND HAVING WORKSHOPS ABOUT. AND THEN WE'RE PIVOTING INTO THE MARKET PARTICIPANT SYSTEM UPDATES AND ULTIMATELY MARKET TRIALS. THE QUESTION MARK HAS BEEN, WHEN DO MARKET TRIALS START AND WHAT DOES THAT LOOK LIKE? AND SO WE DON'T HAVE A DATE, BUT WHAT WE ARE TRACKING TOWARDS IS THAT MAY, 2025, YOU'LL SEE THE FIVE SLASH 25 THAT, UH, OUR VENDOR HAS COME IN WITH A FEBRUARY MARCH DELIVERY DATE. SO OUR LAST DROP OF CODE IS IN EARLY 2025, WHICH MEANS WE COULD BE POSITIONED FOR MARKET TRIALS AS EARLY AS MAY. SO IF YOU LOOK AT MARKET TRIALS BEGINNING IN MAY, WHAT DOES THAT LOOK LIKE? HOW DO WE UNFOLD THAT? AND THIS IS KIND OF FIRST CUT AT WHAT WE BELIEVE THE SEQUENCE LOOKS LIKE. UM, THE FIRST PIECE IS CONNECTIVITY, KIND OF LIKE MOAT TESTING THAT YOU DO. WHEN WE WENT LIVE WITH ECRS, IT WAS CONNECT, CAN I SUBMIT FOR THIS NEW AS, UM, PRODUCT. AND SO WE HAVE A TWO MONTH SHAKEOUT ON MARKET SUBMISSION ITEMS. BUT IN PARALLEL TO THAT IS ALSO NEW TELEMETRY POINTS. UH, THE WAY RTC HAS BEEN DESIGNED, UH, IS IT'S ALMOST GONNA BE AN OVERLAY OF TELEMETRY TO WHERE INSTEAD OF FOLLOWING AN UPDATED SET, YOU'RE GONNA, INSTEAD OF AN UPDATED DESIRED BASE POINT, YOU'LL NOW FOLLOW A SET POINT THAT INCLUDES THE REGULATION SIGNAL. SO WE'RE TALKING ABOUT WHAT IT LOOKS LIKE TO CO-MINGLE THOSE TELEMETRIES TOGETHER AND BE ABLE TO PROGRESS THROUGH A SERIES OF TESTS OVER A FOUR TO FIVE MONTH PERIOD, AND ULTIMATELY GET TO THE TWO MONTH LOAD FREQUENCY CONTROL TEST WHERE WE'D BE RUNNING SC IN OUR CONTROL ROOM AND THE QUES IN THEIR CONTROL ROOM. AND THEN FOLLOWING TELEMETRY SIGNALS FOR YOUR FLEET TO FOLLOW THE REGULATION SIGNALS, UH, TO ENSURE THAT WE HAVE A STABLE, UM, TUNE SYSTEM FOR GO LIVE FOR RTC. UH, AND THEN PARALLEL TO THAT, WE'LL HAVE A COUPLE OF DAY HEAD MARKETS JUST TO, YOU KNOW, SHAKE OUT HOW THE REWARDS LOOK AND WITH THE AS DEMAND CURVES IN THAT ULTIMATELY LEADING TO A GO LIVE. AND SO, AGAIN, WE'LL DO PROBABLY WHAT WE DID FOR NOTAL BEFORE THAT WORKED WELL, WHICH WAS KIND OF A ONE MONTH BEFORE RING THE BELL 30 DAY NOTICE. THIS IS WHEN WE'RE GONNA GO LIVE AT MIDNIGHT ON DATE X, AND THEN THAT WOULD BE THE CUTOVER. SO JUST WANTED TO START THIS CONVERSATION. SO THIS IS EARLY ON AT R-T-C-B-T-F, BUT WE'RE JUST STARTING TO PEEL AWAY THE DETAILS OF WHAT THAT MIGHT LOOK LIKE SO THE MARKET PARTICIPANTS CAN BE READY. UH, IN TERMS OF WHY I NEED TODAY IS, AGAIN, WE'RE WORKING THROUGH THE ISSUES LIST. THESE ARE THE IMPLEMENTATION ISSUES THAT WE NEED TO TACKLE, UH, AND GET THROUGH. SO THE THINGS THAT WE'VE MOVED UP A LITTLE EARLIER TO THE LEFT ARE SHADED AND BLUE. THAT WAS THE IDEA OF SOME OF THESE MARKET TRIALS DISCUSSIONS. UH, AND THEN THE NICE PART IS SOMETHING WENT GREEN ON THIS. AND SO AS WE BUILD MOMENTUM AND START TO DEAL WITH THREE OR FOUR THINGS AT A TIME, WE'LL GO GREEN. BUT THAT R CAPACITY SHORT IS WHAT WAS APPROVED AT THE LAST TAC. AND FOR THIS TAC MEETING, WE WANTED TO TALK ABOUT THE VERIFIABLE COST, MANUAL CHANGE. AND, UM, WHAT I DID DO, THIS IS SILLY, BUT IT HELPS ME, THIS SPREADSHEET NOW HAS A COMPLETED TASK, UH, WORKSHEET BEHIND IT. SO THAT WAY WE'LL ALWAYS HAVE A LOG OF WHAT'S TO DO, HOW DID WE RESOLVE IT, WHAT'S THE NEXT STEP TO GET IT OUT OF THE WAY? SO THIS IS KIND OF A ALL IN ONE SHOP FOR THAT. IN TERMS OF THE PRIOR MEETING, UH, THE ONE THAT WE'RE GONNA TEE UP FOR THE VOTE IS THIS, UH, ISSUE FOR THERE IS THE ONLINE HYDRO RESOURCES. UH, YOU KNOW, TODAY THEY'RE PROTECTED BY A HASSLE AND RTC, THE IDEA OF YOU DON'T HAVE A HASSLE THAT'S PROTECTING IT. AND IT'S OPEN TO THE ENERGY OFFER CURVE. AND THE CO-OP OPTIMIZATION OF AS THIS WAS PICKED UP EARLY ON BACK IN TPT, I'M SORRY, WOO, BACK IN RT. THE RT, WOW, THERE'S A HARD BLANK. R-T-C-T-F, THANK YOU TOO MANY, UH, ACRONYMS. AND SO THE, THE STACK PICKED UP ON IT AND SAID, WHAT'S GONNA HAPPEN IF WE'RE SITTING ON A DAM? WE'VE BEEN AWARDED RESPONSIVE RESERVE AND SCED PRICES HIT A POINT WHERE THE MITIGATED OFFER CAP STARTS TO KICK IN FOR THOSE, UH, UNITS. THEY'D START DRAINING THE WATER OUT UNCONTROLLABLY. AND SO THE IDEA WAS LET'S GET THIS MITIGATED OFFER CAP SET TO A HIGHER LEVEL. SO IT'S REALLY THE QUEASY THAT'S SETTING THOSE OFFER PRICES ON ENERGY WITH AS AND CO-OP OPTIMIZATION SO THAT IT'S NOT DISPATCHING IN A WAY THAT WASN'T DESIGNED. AND SO THE PROPOSAL THAT WE HAD, UM, THAT ERCOT BROUGHT FORWARD AND EVERYONE HAS BEEN, UM, UNANIMOUS ON, IS THE IDEA OF SEEKING ENDORSEMENT OF THIS CONCEPT. SO GIVEN THAT HYDRO RESOURCES OPERATE IN SYNCHRONOUS CONDENSER MOTOR NOT DISPATCHED BY SCED, ERCOT PROPOSES THE MITIGATED OFFER CAP FOR ALL HYDRO RESOURCES TO BE SET TO THE REALTIME SYSTEM-WIDE OFFER CAP. THIS WILL BE DONE IN A PROTOCOL AND VERIFIABLE COST MANUAL CHANGE BY SETTING THE, UM, O AND M VALUE TO THE MARK MITIGATED OFFER CAP TO THE REALTIME OFFER CAP, AND [02:20:01] SETTING THE HEAT RATE TO ZERO. AND SO FOR THE GROUP, THAT WAS SOMETHING WE WANTED TO SEEK ENDORSEMENT ON TODAY TO SEE IF THE GROUP AGREES WITH THAT, TO THEN MEMORIALIZE IT AND MOVE IT ON WITH THE NPRS AND BOB HILTON. YEAH, FIRST I'D SEE IS ANYONE HAVE A PROBLEM WITH THIS GOING ON THE COMBO BALLOT? YEAH, THAT WAS THE FIRST THING. THE SECOND THING IS JUST A QUICK QUESTION FOR YOU. UH, I'M CURIOUS ON ARE YOU GETTING AN ACCEPTABLE AMOUNT OF INVOLVEMENT IN THE TECHNICAL WORKSHOPS AT THIS POINT, OR IS THERE YES, I'M A LITTLE JEALOUS ACTUALLY. UH, I THINK THEY HAD, WE'RE CURING I THINK 70 TO 80 ON OURS FOR THE R-T-C-B-T-F ON THOSE, IT'S SOME OF Y'ALL PLUS THE VENDORS AND OTHER IT FOLKS. SO I'VE SEEN AS HIGH AS 150 ON THOSE. THAT'S GREAT. I JUST WANTED TO MAKE SURE OF THAT. YEAH, SO THESE TWO WORKSHOPS THAT WE HAVE HERE, THOSE ONE TO FOUR, BACK ON APRIL 18TH AND MAY 6TH, UH, WENT ALMOST THE FULL THREE HOURS WITH 150 PEOPLE ONLINE. GREAT. THANK YOU. ALL RIGHT. SO IF THAT GOES TO THE COMBO BALLOT, I WILL SAY, UH, I'VE BEEN REACHING OUT TO THE NEXT TASK FORCE MEETING IS THE SAME DAY, UM, AS THE TEXAS SENATE, UM, BUSINESS AND COMMERCE COMMITTEE, THEY'LL BE LOOKING AT THE MARKET DESIGN. SO I WAS GONNA MOVE OUR MEETING OVER TO FRIDAY IS PROBABLY A WEBEX ONLY, SO DIDN'T WANT TO DECOUPLE THOSE. AND THAT'S IT. ARE THERE ANY QUESTIONS? LET'S SEE. BRIAN SAMS. BRIAN SAMS OKAY, BACK TO THE SLIDE WHERE YOU'VE GOT ALL THE, THE KIND OF OPEN ITEMS YOU'VE GOT ISSUE 18, I I, I GUESS I WANNA FLAG THAT THAT'S NOT SOMETHING YOU'RE EXPECTING LIKE TAC TO VOTE ON, RIGHT? UM, YOU'RE, THERE'S JUST DISCUSSION HAPPENING. I'M STILL UNCLEAR ABOUT HOW UM, OR IF THE RTC CURVES, THE ANCILLARY SERVICE DEMAND CURVES WILL BE REFORMED TO REFLECT ORCO OPERATIONAL PREFERENCES. YEAH, SO WHAT WAS ASKED AT THE LAST MEETING WAS, AGAIN, WHAT WE'VE BEEN DOING IS WE CARVED THAT OUT IS THE SHAPE OF THE ORDC CURVE IS DEFINITELY A PUC ISSUE. IF THERE IS A SLICING AND DICING OF THEM, THOSE COULD BE AN NPR, BUT WOULD BE AFTER GO LIVE. THERE'S THIS SPOT IN THE MIDDLE IS ERCOT IS BEING ASKED FOR MORE ANALYSIS. AND SO THAT'S WHAT, THAT WOULD BE BROUGHT TO THE NEXT WORKSHOP WITH SOME FEEDBACK FROM OPERATIONS ON WHETHER OR NOT THERE'S ANY ISSUES WITH THE CURVES. THAT WAS THE SPECIFIC ASK FROM SHAMS AT THE LAST TASK FORCE. AND THAT I, I'M CONFUSED ABOUT YOUR COMMENT ON AFTER GO LIVE. I MEAN, IF THEY MADE A, A POLICY CHOICE TO CHANGE THE SHAPE OF THE CURVES THAT COULD BE DONE BEFORE GO LIVE COULD BE DONE BEFORE. THANK YOU. SORRY. THERE'S THOSE TWO ISSUES. AND I COULD GO BACK TO THE OLD TAX SLIDES THAT SHOWED, THERE'S THE TWO THINGS. ONE WAS THE SHAPE OF THE RDC CURVE UPON APPROVAL, WE COULD GET IT LIVE IN A MONTH. OKAY, THANK YOU. BUT THEN THERE'S THE SLICING OF THE CURVES TO SAY, LET'S COMMINGLE THE AS TO GO FROM RESPONSIVE TO REG AND ECRS AND THEN PUT THEM IN DIFFERENT SLOTS. JUST GENERALLY, DO YOU HAVE ANY UPDATE ON KIND OF WHERE THAT DISCUSSION IS, IF AT ALL, UM, WITH THE COMMISSION? OH, NO, I DO NOT. THANK YOU. OKAY, QS, CLEAR. APPRECIATE IT. MATT. WE'LL GO AHEAD AND PUT THE ENDORSEMENT OF THE ED OFFER CAPS FOR HYDRO FOR RTC ON THE COMBO BALLOT. OKAY. [12. Credit Finance Sub Group (CFSG) Report] NEXT ITEM IS ITEM 12, CREDIT FINANCE SUBGROUP REPORT. BRENDAN SAGER, CAN YOU HEAR ME BRENDAN HERE? YEAH, WE CAN HEAR YOU. OKAY, GREAT. UM, THANK YOU. SO I GOT A LITTLE BIT OF GROUND COVER TODAY BECAUSE JUST THE TIMING OF THE MEETINGS. I HAVE TO GO OVER TWO OF OUR MEETINGS. UH, WE LOOKED AT OPERATIONAL NPRS WITHOUT, UH, CREDIT IMPACTS, UM, LOOKED AT, UH, NPR 1215, WHICH I'LL DISCUSS. UH, WE'RE STILL LOOKING AT OUR EAL CHANGE REPO PROPOSALS. THERE WAS, UH, WE FINISHED OUR DISCUSSION ON THE INDEPENDENT AMOUNT POSTING REQUIREMENT. UM, TALK ABOUT NPR 1215 CLARIFICATIONS TO DAM AND ENERGY ONLY OFFER CALCULATION. UH, I DID A FORWARD ADJUSTMENT FACTOR HISTORICAL ANALYSIS. UH, E THREE, THE CONSULTANT GROUP ON THE PCM, UH, CAME AND GAVE A PRESENTATION TO US, UH, OR CUT TREASURY ALSO DISCUSSED, UH, ISSUES AROUND, UH, COLLATERAL HOLDS, WHICH ARE BECOMING, UH, AN INVOICE HOLDS THAT ARE BECOMING A LITTLE BIT MORE FREQUENT, AND THEY'LL TALK MORE TO US ABOUT IT ALONG WITH OUR REGULAR CREDIT EXPOSURE UPDATES. NEXT SLIDE, PLEASE. UH, SO IN ON THE INDEPENDENT AMOUNTS, UH, THIS WAS AS A RESULT OF NPR 1165, WHICH IMPLEMENTED APRIL 1ST. ALL COUNTERPARTIES REQUIRED TO POST IA, UH, ERCOT INFORMED US BACK IN APRIL THAT FOUR COUNTERPARTIES WERE TERMINATED AFTER NOT POSTING OR CHOOSE TO NOT POST. UH, THE REQUIREMENT FOR CR ONLY IS 500 K MULTI-MARKET 200 K. UH, RAMSEY CRIPE CAME IN FROM SE ENERGY AND PRESENTED CONCERNS OVER THE ADDED COST OF THIS AND POTENTIAL LIQUIDITY CONSTRAINTS [02:25:01] FOR SMALLER MARKET PARTICIPANTS. AND IT, THIS COULD ALSO REDUCE HEDGING IN THE MARKET. UH, ERCOT RESPONDED THAT, UM, EXEMPTIONS COULDN'T BE GRANTED FOR LEGAL AND REGULATORY REASONS, AS WELL AS CONCERNS OPERATIONAL CONCERNS AROUND MANAGING SORT OF, UH, ONE-OFFS. NEXT SLIDE, PLEASE. UH, SO WE TALKED ABOUT THE NPR 1215 CLARIFICATION, THE DAY AHEAD MARKET DAM ENERGY ONLY OFFER CALCULATION. THIS, FRANKLY IS JUST A CLERICAL KIND OF CLEANUP OF THE LANGUAGE. UM, THERE WERE TWO CLARIFICATION EDITS AND THE ABSOLUTE VALUE OF NEGATIVE PRICES USED TO INCREASE THE EXPOSURE WHEN PRICES ARE NEGATIVE. UH, A REFERENCE TO IN THE PROTOCOL PARAGRAPH REFERENCE WAS RESOLVED IN IT, AND IT INCLUDED THE INCORPORATION OF THE ASBUILT VALUE OF E TWO USED IN THE CALCULATION OF CREDIT EXPOSURE FOR DAM OFFERS. UH, AND WE VOTED TO ENDORSE THIS AS AMENDED BY ERCOT COMMENTS APRIL 12TH. NEXT SLIDE. LEE, HOLD ON A SECOND. BRENDAN, BOB, DID YOU HAVE A QUESTION ON THIS SLIDE? OUR PREVIOUS ONE AT THE END? OKAY. UH, OKAY. UH, FORWARD ADJUSTMENT FACTOR HISTORICAL ANALYSIS. JUST SO FOR CONTEXT, UM, THE WAY THE COLLATERAL OBLIGATION IS CALCULATED IS INVOICES TIMES A FORWARD ADJUSTMENT FACTOR SUBJECT TO A LOOKBACK. UH, SO, UH, ERCOT PROVIDED DATA AROUND THE, UH, HISTORICAL DATA ON THE HISTORICAL, OR EXCUSE ME, THE, UH, FORWARD ADJUSTMENT FACTORS FOR RA AND DA. WE'RE JUST LOOKING AT RA SINCE THEIR, UH, CORRELATION, UH, OR OF COEFFICIENCY. COEFFICIENCY OF CORRELATION IS 0.87. UH, THIS, THE RFA IS ALSO MORE PROMINENT IN THE EAL CALCULATION, THAT'S ESTIMATE AGGREGATE LIABILITY, UH, WHICH IS APPLIED TO A REAL TIME INVOICE AMOUNT IN THE LOOKBACK PERIOD. UM, AND WE TALKED ABOUT FIXING, FIXING THESE AMOUNTS AT MAXIMUM VALUES TO GIVE CERTAINTY AROUND, YOU KNOW, UH, COLLATERAL, UH, POSTINGS, AND THEN MIN VALUES, WHICH KIND OF HAIRCUT THE INVOICE EXPOSURE AND COULD POTENTIALLY POSE SOME CREDIT RISK. UH, AND THESE ARE STRAIGHTFORWARD OF, OF ALL THE THINGS WE'RE CONSIDERING, THESE ARE PRETTY STRAIGHTFORWARD TO IMPLEMENT IF WE DECIDE TO MOVE AHEAD. UH, NEXT SLIDE PLEASE. ACTUALLY, BOB, GO AHEAD. YEAH, ACTUALLY I, YEAH, IT IS ON THIS PIECE. I, I WANT TO ASK YOU A QUESTION ON WHAT IF THIS, ONE OF THE THINGS THAT'S BEEN BROUGHT TO, UM, TO MY ATTENTION, AND I'M CURIOUS IF THIS IS PART OF THE REASON THE GROUP IS LOOKING AT THIS, IS WE'RE UNDERSTANDING THAT THERE'S A PRETTY HIGH OVERCOLLATERALIZATION OF LARGE FLEXIBLE LOADS THAT ARE PRICE SENSITIVE AND FROM WHAT THEIR INVOICE HISTORY IS AND WHAT THEIR COLLATERAL IS, THERE'S A BIG GAP IN THERE. WOULD THIS HELP TAKE CARE OF THAT PROBLEM? UH, YEAH. SO, UM, THAT IS, WE'RE LOOKING AT THIS KIND OF TWO WAYS. ONE, THE, THE MAIN THING WE WANT TO PREVENT IS UNDER COLLATERALIZATION. THAT IS WHEN RIGHT INSTANCES WHERE THE AGGREGATE INVOICE AMOUNT IS NOT SUPPORTED BY THE APPROPRIATE AMOUNT OF COLLATERAL. THE OTHER PART WE'RE LOOKING AT IS OVERCOLLATERALIZATION. UM, AND, UH, I'LL, I'LL GET INTO THAT A LITTLE BIT, UH, FURTHER IN THIS PRESENTATION. BUT, UM, YES, THAT IS A HIGH PRIORITY AND, AND WE'RE LOOKING AT THAT. OKAY. ALRIGHT. THANK YOU BRENDAN. YEP. UH, NEXT SLIDE PLEASE. OKAY. SO THIS IS JUST SOME OF THE HIGHLIGHTS OF THE DATA OF THE FORWARD ADJUSTMENT FACTOR SUMMARY AND JUST, AND BASICALLY THE WAY THIS WORKS IS YOU HAVE THREE WEEKS OF FORWARD PRICES AT ERCOT NORTH HUB OVER, THERE'S A RATIO OF THAT TO A RATIO OF, I THINK, TWO WEEKS OF, UH, ERCOT NORTH HUB SETTLEMENT PRICES. SO BASICALLY, YOU KNOW, IF THE FORWARDS ARE HIGHER, IT'S GONNA BE GREATER THAN ONE IF THEY'RE LOWER, AND IT'S GONNA BE LESS THAN ONE. SO YOU CAN SEE, UM, IN GENERAL, UH, THE FORWARD ADJUSTMENT FACTOR IS UNDER TWO 90% OF THE TIME, 2.5 95% OF THE TIME, 3 2 5 97 POINT OF THE TIME. AND 5 2 5 90 9% OF THE TIME, THE HIGHEST WAS DURING URI OF 10.61, AND THE LOWEST WAS, UM, 0.1. AND WE LOOKED AT, AND THERE'S A 2200 VALUES THAT WE'VE LOOKED AT. UM, SO HERE YOU CAN KIND OF SEE WHERE IT SETTLES OUT. SO MOST OF THE TIME, BASICALLY YOU'RE LOOKING AT YOUR INVOICE EXPOSURE, BUT WHEN FORWARDS POP, UM, YOU CAN GET A, UH, YOU KNOW, A VERY HIGH COLLATERAL REQUIREMENT THAT IS BEYOND YOUR INVOICE AMOUNT. AND THEN GIVEN THE MAX FUNCTION IN THE LOOKBACK, IT THAT GO WILL GO AGAINST, YOU KNOW, 40 DAYS OF INVOICE HISTORY. UH, NEXT SLIDE PLEASE. OKAY. UM, SO THIS IS PROBABLY, WE, WE, WE HAVEN'T COME TO ANY CONCLUSIONS ON THIS, BUT, UM, WE WE'RE, AGAIN, LOOKING AT A MAX VALUE 'CAUSE IT WAS BROUGHT UP SEVERAL TIMES THAT, YOU KNOW, IF WE, [02:30:01] IF WE IMPOSE A MAXIMUM VALUE, UM, THEN THAT WILL JUST GIVE MORE CERTAINTY AROUND WHAT'S THE WORST CASE THAT ANY ORGANIZATION WOULD HAVE TO POST TO THE MARKET. UM, AND WE ALSO CONSIDERED, UM, LUCK MAKING THE MINIMUM AMOUNT OF THE FAF AT ONE, UH, TO JUST BASICALLY REFLECT, WE DON'T WANT TO CUT, UM, INVOICE EXPOSURE. HOWEVER, WE WOULD ONLY DO THAT IF WE CHANGE THE LOOKBACK VALUE. SO IF WE DON'T CHANGE THE LOOKBACK, WE'LL JUST LEAVE IT ALONE AS FAR AS THAT GOES. AND, UH, AND, AND AGAIN, YOU KNOW, THESE WOULD BE PRETTY STRAIGHTFORWARD IMPLEMENTATIONS VERSUS, YOU KNOW, MORE, UH, FULSOME CHANGES TO THE, UH, ALGORITHM THAT WE'RE LOOKING AT. AND WE'LL LOOK AT NOW. NEXT SLIDE, PLEASE. OH, UH, YEAH, THAT'S RIGHT. AND PCM STOPPED BY, UM, I OR E THREE, FOLLOWED BY ON THEIR, UH, PERFORMANCE COLLATERAL, UH, MANAGEMENT, UM, PRESENTATION THAT THEY GAVE APRIL 17TH TO THE ERCOT STAKEHOLDER WORKSHOP. SO, UH, BACKGROUND ON THIS IS, UH, POST YURI SENATE BILL THREE PASSED A BOLSTER FINANCIAL, UH, STABILITY ON THE GRID IN JANUARY, 2023. PUC PROPOSED A NOVEL PERFORMANCE CREDIT MECHANISM, OR PCM. THE PCM CONSTRUCT WOULD PROVIDE ADDITIONAL REVENUE STREAM TO GENERATORS THAT COMMIT IN ADVANCE TO BEING AVAILABLE TO PROVIDE POWER DURING HOURS OF HIGHEST RELI RELIABILITY RISK. UH, AND HB 1500 ADDED ADDITIONAL GUARDRAILS SUCH THAT THE COST OF THE PCM CANNOT EXCEED $1 BILLION A YEAR. NEXT SLIDE, PLEASE. CAN WE PAUSE THERE? I JUST HAD A YES, ABSOLUTELY. SORRY, GO AHEAD, ERIC. UM, HEY, I JUST WANNA, SINCE YOU MENTIONED A GUARDRAIL IN PARTICULAR, I DON'T WANNA BREAK OUT INTO A PCM WORKSHOP IN THIS TAX MEETING, BUT I THINK THERE'S ALSO A SPECIFIC CREDIT GUARDRAIL AROUND, UM, SECURED COLLATERAL THAT ENSURES AGAINST NON-PERFORMANCE AND NON-PAYMENT. AND IF Y'ALL ARE GONNA BE TALKING ABOUT ANY GUARDRAIL, I'D LIKE TO MAKE SURE THAT'S THE ONE YOU TALK ABOUT OF, OF, OF NON NON-PAYMENT. YEAH, THERE'S A GUARDRAIL THAT SAYS, UM, THAT OTHER PARTICIPANTS ARE PROTECTED AGAINST NON-PERFORMANCE OR NON-PAYMENT, WHICH I THINK IS THE, THE, THE COLLATERAL GUARDRAIL. I JUST WANNA MAKE SURE, SINCE YOU MENTIONED A GUARDRAIL, THAT THAT ONE'S ON YOUR LIST. OKAY. YEAH, I'LL, UH, I'LL, I'LL REACH OUT TO YOU AFTER THIS AND YOU CAN, WE CAN DIG IN A LITTLE BIT ON THAT, UH, OR FEEL FREE TO COME TO THE MEETING AND SHARE YOUR THOUGHTS. UM, IAN, THANK YOU. UM, YES, ERIC, THAT WAS DISCUSSED ERCOT LEGAL, MADE SURE AS WE WERE, AS THE GROUP WAS DISCUSSING HOW THIS COULD BE, UM, REDUCED, ELIMINATED, ET CETERA. UM, THAT WAS BROUGHT UP BY ERCOT LEGAL. AND SO THE, THE GROUP IS TRYING TO FIGURE OUT HOW BEST TO MOVE FORWARD. UM, I DO WANNA SAY, UM, AS A TAC MEMBER TO THIS GROUP, THANK YOU VERY MUCH FOR, UM, DIVING INTO THIS. I HAD ASKED THEM TO, UM, AND REALLY APPRECIATE ALL THE LIGHT THEY'VE SHED ON, UM, THIS PART OF IT THAT I THINK WAS OVERLOOKED BY A LOT OF US, INCLUDING MYSELF. YEAH. THANK YOU. I APPRECIATE IT. IT IS OUR PLEASURE. NEXT SLIDE, PLEASE. OKAY. SO THE E THREE'S PROPOSAL IS SUBSTANTIALLY DIFFERENT FROM, UH, HOW WE DO THIS NOW. UM, TO CALCULATE COLLATERAL OBLIGATIONS, THEY'RE STRUCTURED AS PREPAYMENTS OF FUTURE COSTS WITH PROPOSED SETTLEMENTS AND TRUE UP AT DIFFERENT POINTS IN TIME. COLLATERAL OBLIGATION IS EXPECTED PERFORMANCE CREDIT, PRICE TIMES THE EXPECTED REQUIREMENT MINUS THE FORWARD MARKET PROCUREMENT. UM, YOU KNOW, AND, AND YOU COULD SEE THESE DETAILS, IT'S, IT'S A LOT OF, UM, EXTRAPOLATED VALUES, EXPECTED VALUES, WHERE THE WAY WE DO THINGS NOW IS WITH INVOICES BASICALLY, AND AGGREGATING THE INVOICES AND BUILD AND UNBUILD AMOUNTS. UM, SO DURING YURI COLLATERAL POSTED TO ERCOT ROSE TO NEARLY 20 BILLION FROM A MORE TYPICAL THREE TO 4 BILLION, AND SOME ARE 2023, IT WAS AROUND EIGHT TO 10. UH, AND KEEP IN MIND, YOU KNOW, THAT'S WHEN THE OFFER CAP, UH, DECLINED, YOU KNOW, AFTER URI AND BEFORE THE SUMMER OF 2023. UH, SO THERE'S SOME UNCERTAINTY AROUND CONFLICTS BETWEEN HB 1500 GUARDRAIL, COST CAPS, AND THE CURRENT MESSAGE, WHICH FAR EXCEED THAT. UM, AND WE ALSO VOICE CONCERNS ABOUT WHAT I DISCUSSED USING THEIR ALGORITHMIC APPROACH VERSUS, YOU KNOW, ACTUAL INVOICES AND, AND REAL DATA. UM, SO THAT IS THAT, UH, NEXT SLIDE PLEASE. SO, SWINGING BACK TO THE EAL CHANGES IN ANALYSIS, UM, THIS IS, AGAIN, THIS ESTIMATE AGGREGATE LIABILITY THAT, UH, IS A NUMBER THAT CALCULATES IT, UM, TENDS TO, UH, LEAD TO A COLLATERAL POSTING REQUIREMENT. UH, MEMBERS, WE, THE WAY WE, IT'S DAY AHEAD IN REAL [02:35:01] TIME EXPOSURES ARE LOOKED AT SEPARATELY, AND THERE'S SOME DISCUSSION ABOUT MAYBE COMBINING THESE, UM, AS ONE IS KIND OF A, POTENTIALLY A HEDGE FOR ANOTHER. UH, WE'RE LOOKING, AGAIN, WE'RE EVALUATING THE LOOK BACK PERIOD, WHETHER IT'S MAYBE TOO LONG, UM, THAT THAT LOOKBACK PERIOD TO THE QUESTIONER'S EARLIER POINT IS REALLY, I THINK, SUBSTANTIALLY DRIVES THE OVERCOLLATERALIZATION VERSUS, UM, THE FORWARD ADJUSTMENT FACTOR. BUT THE FORWARD ADJUSTMENT FACTORS ALSO CAN, AND THEY'RE DESIGNED TO DO THIS, YOU KNOW, AS PRICES RISE TO LEAD TO A SUDDEN, UH, UH, COLLATERAL REQUIREMENT. SO WE'LL CONTINUE TO LOOK AT THESE. AND THE ERCOT CREDIT TEAM TO THEIR, UH, IMMENSE CREDIT, UM, HAS DONE A LOT OF WORK AROUND THIS. THEY'VE BASICALLY, YOU KNOW, TAKEN THESE ALGORITHMS AND JUST RERUN, UM, THE CREDIT ENGINES TO, UH, ACCOMMODATE THIS ANALYSIS GOING BACK FOR QUITE A PERIOD OF TIME. NEXT SLIDE, PLEASE. UM, OKAY. SO THIS IS OUR SCENARIO FOR THIS, I THINK IS THE LAST ONE THAT WE'VE, THAT WE'RE LOOKING AT, GOING BACK, I DON'T KNOW, AT LEAST SIX MONTHS. UM, SO THE KEY TO LATER ITERATIONS INCLUDES THE NETTING OF DAY AHEAD IN REAL TIME, WHERE A FAF MULTIPLIER IS APPLIED TO THE MAX VALUE AT THE LOOKBACK PERIOD CALCULATION INCLUDES UNBUILD LIABILITY LAST 14 DAYS, REALTIME STATEMENT AVERAGE PLUS LAST 14 DAYS, DAY AHEAD, UH, INITIAL STATEMENT BASED ON REALTIME INITIAL OPERATING DAY TIMES THE M TWO FACTOR. AND THIS SCENARIO ACTUALLY RESULTED IN THE HIGHEST COLLATERAL REQUIREMENT OF ALL PREVIOUS SCENARIOS. SO, UM, MAYBE NEXT TIME I'LL KIND OF SUM IT ALL UP, BUT WE'RE PROBABLY NOT TOO KEEN ON, UH, INCREASING THE COST TO THE MARKET. UM, SO WE'LL CONTINUE TO LOOK AT THIS AND, UH, YOU KNOW, I'LL COME BACK AND REPORT, UM, NEXT SLIDE, PLEASE. UH, THE, UH, YEAH, WE CAN GO TO THE NEXT SLIDE. I KIND OF COVERED THAT. OKAY. UH, THE NPRS I'M NOT GONNA READ ALL THESE. THESE WERE ALL, UM, CONSIDERED OPERATIONAL WITHOUT ANY CREDIT IMPACTS. NEXT SLIDE PLEASE. SO, THE MONTHLY HIGHLIGHTS FROM MARCH TO APRIL INCREASED TPE INCREASE FROM 1.37 BILLION TO 1.52 IN FROM MARCH TO APRIL. THIS WAS DUE TO HIGHER FORWARD ADJUSTMENT FACTORS AND REAL TIME DATA AHEAD PRICES, UH, UH, WE'RE LOOKING AT DISCRETIONARY COLLATERAL, WHICH IS THE EXCESS COLLATERAL PEOPLE POST, UM, OVER THEIR REQUIREMENTS. UH, AND IT IS REQUIRED TO GET ACCESS TO THE, UH, DAY AHEAD MARKET. SO AVERAGE DECRE DISCRETIONARY COLLATERAL DECREASED FROM 4.43 BILLION IN MARCH 24 TO FOUR POINT 10 BILLION IN APRIL 24. AND AS I NOTED BEFORE, FOUR COUNTERPARTIES DEFAULTED FOR NOT POSTING THE INDEPENDENT AMOUNT. THEY DID NOT HAVE ANY ACTIVITY IN THE MARKET AND DIDN'T WANNA POST. NEXT SLIDE, PLEASE. SO THIS IS, YOU KNOW, KIND OF REFLECTING THE SEASONAL PATTERN, UM, UH, OF THE INDIVIDUAL COLLATERAL TYPES. UNSECURED CREDIT IS NO LONGER A FACTOR IN THE MARKET AFTER OCTOBER. UM, MOST OF THIS IS LETTERS OF CREDIT AND SOME CASH AND, UH, SMALL AMOUNTS OF SURETY BONDS. UM, NEXT SLIDE, PLEASE. UH, THIS IS HOW THAT, WHAT I JUST, JUST DESCRIBED LOOKS IN A PICTURE. SO, YOU KNOW, THE ACTUAL REQUIREMENT IS THE DARK BLUE, GRAY AND PURPLE, AND THE, UH, COLLATERAL POSTED IN EXCESS OF THE REQUIREMENT IS THE LIGHT BLUE. SO, AND AGAIN, YOU NEED AT LEAST SOME OF THAT TO GET ACCESS TO THE DAY AHEAD. NEXT SLIDE, PLEASE. UH, WE HAD DISCUSSED, UM, EARLIER ERCOT RAISED THE, UH, TOTAL AMOUNTS PER ISSUER, THE, THE CREDIT LIMITS BASICALLY FOR, UH, LETTERS OF CREDIT. 'CAUSE WE WERE RUNNING INTO A LOT OF, UH, OVERAGES AND, UH, SO I THINK THERE WERE, I THINK LIKE A, MAYBE A DOZEN AT ITS PEAK, AND NOW IT'S JUST ONE WITH LLOYD'S, BUT OTHERS ARE GETTING CLOSER. NEXT SLIDE, PLEASE. I THINK THAT'S THE END. YES. ANY QUESTIONS, BRENDAN, MAYBE NOT TO COVER RIGHT NOW, BUT I, I'D LIKE TO GET A BETTER UNDERSTANDING OF THE PCM DISCUSSIONS THAT ARE HAPPENING AT, AT THAT GROUP. AND, AND MAYBE I MISSED A TAC DIRECTION OR, OR ASK THERE, BUT I, I THINK FOR THE FUTURE IT WOULD BE GOOD IF WE KNEW AT TAC WHAT WAS HAPPENING THERE REGARDING PCM DISCUSSIONS. YEAH, IAN KIND OF, UH, HASTILY SENT OUT AN EMAIL TO US ALL TO LET US KNOW THAT THAT WORKSHOP HAPPENED. AND, YOU KNOW, THEY'RE TALKING ABOUT, YOU KNOW, 12 TO $20 BILLION. AND SO YEAH, THERE'S, THERE'S A LOT OF DIGGING IN WE'RE GONNA HAVE TO DO ON THAT. AND, UH, E THREE AND OR CO LEADERSHIP HAS BEEN VERY HELPFUL, UM, IN, UH, HELPING US OUT. SO WE'LL DEFINITELY HAVE MORE ON THAT FOR NEXT TIME. UH, AUSTIN, I THINK IAN WANTED TO DIRECTLY RESPOND TO, TO THAT TOPIC, SO WE MIGHT LET HIM GO FIRST. BRENDAN, UH, OKAY, GO AHEAD. UM, [02:40:01] NO, I, I REALLY APPRECIATE THE GROUP TAKING THAT ON AND, UM, HAVING AS IN DEPTH AND AS WELL ATTENDED DISCUSSIONS FROM E THREE AND AIRCRAFT AS THEY HAVE, UH, AFTER A PCM WORKSHOP, UH, I WAS QUITE SURPRISED THAT THE AMOUNT OF COLLATERAL BEING DISCUSSED WAS BEING DISCUSSED, UM, SO NONCHALANTLY AND HAD CONCERNS THAT IF THIS WASN'T WELL UNDERSTOOD BY OUR SMES AND CREDIT, THAT IT COULD DERAIL ALL OF PCM AT A LATER DATE AFTER A LOT OF WORK WAS PUT IN. SO I HAD IMMEDIATELY EMAILED, UH, THE LEADERSHIP ASKING THEM TO DISCUSS IT IN HOPES THAT EVERYONE COULD GET A BETTER UNDERSTANDING OF THIS, AND THEN THAT COULD INFORM ANY COMMENTS THEY HAD TO THE COMMISSION. UM, SO IT WAS MORE OF JUST A REQUEST THAT THEY, THEY DISCUSS IT OPEN, GET A LITTLE LIGHT ON EVERYTHING, SO EVERYONE HAD A BETTER CHANCE TO, UH, IDENTIFY ISSUES THAT THEY SAW NEEDED TO BE IDENTIFIED IN THEIR COMMENTS TO THE COMMISSION. OKAY. I THINK, YEAH, ONE, ONE THING I WOULD ADD TO THAT TOO IS LIKE, JUST BASED THE WAY THE METHODOLOGY WORKS, AND I DON'T WANT TO SPEAK FOR IT AS AN EXPERT OR, UM, NECESSARILY REFLECTING THE NOTIONS OF THE GROUP, BUT THEY'RE BASICALLY GONNA HAVE PEOPLE PREPAY. UM, YOU KNOW, AND THEN, THEN IT'S GONNA BE TRUED UP OVER SOME DIFFERENT PERIODS OF TIME. SO, YOU KNOW, THE CURRENT SYSTEM HAS ITS DISADVANTAGES, BUT ITS ADVANTAGE IS YOUR COLLATERAL POSTINGS FOLLOW YOUR ECONOMIC ACTIVITY VERSUS HERE THEY'RE GONNA HAVE SOME KIND OF ESTIMATE, WHICH, YOU KNOW, I HAVE NO IDEA HOW THEY'RE GONNA DO THAT. AND THEN YOU'RE GONNA TRUE, UH, WHICH MAY NOT BE AT A TIME WHERE YOU'RE GETTING PAID FOR EVERYTHING THAT YOU'RE DOING. UM, SO YEAH, THAT, THAT'S MY BIG CONCERN. OKAY. I THINK THAT MAKES SENSE. IT MIGHT BE GOOD TO FIGURE OUT A WAY, UM, YOU KNOW, I, I KNOW THAT'S A REALLY HIGH IMPORTANCE TOPIC, SO THERE MIGHT BE MORE PEOPLE INTERESTED IN THAT PARTICULAR DISCUSSION THAN WHO REGULARLY GOES TO THE CREDIT FINANCE SUBGROUP. SO I, I THINK IT WOULD BE, YOU KNOW, I, I TOTALLY UNDERSTAND AND APPRECIATE THAT DIRECTION AND DISCUSSION, BUT I, I THINK IT MIGHT BE GOOD IF IN THE FUTURE WE COULD LET TAC MAYBE KNOW, SO, SO PEOPLE COULD ATTEND THOSE DISCUSSIONS AND, AND HAVE THEIR INTERNAL SUBJECT MATTER EXPERTS ATTEND AS WELL. YEAH, NO, DEFINITELY WE ENCOURAGE PEOPLE TO ATTEND AND WE'LL, WE'LL BE TALKING ABOUT IT CERTAINLY NEXT TIME. OKAY. AUSTIN. YEAH, SO I SEE MATT IS AFTER ME, SO HOPEFULLY I'M NOT STEALING TOO MUCH OF HIS THUNDER. HOPEFULLY HE DOESN'T COME IN AND JUST CORRECT EVERYTHING I SAY. BUT I POSTED, I PASTED THE, UH, WHAT MATT BROUGHT UP, UM, WHAT ERIC WAS TALKING ABOUT, ABOUT THE, UH, GUARDRAIL, UM, THAT WAS ADDED TO, TO PIRA. I PASTED IT IN THE CHAT IF THAT'S HELPFUL, THAT GUARDRAIL. UM, AS FAR AS I KNOW, WE DON'T HAVE A GUARDRAIL LIKE THAT FOR OUR CURRENT COLLATERAL PRACTICES, SO THAT'S SOMETHING WE'RE LOOKING AT AND THINKING ABOUT HOW THAT, UM, COULD REQUIRE POSSIBLY MORE STRINGENT, UH, COLLATERAL REQUIREMENTS THAN WHAT WE DO TODAY. SO I JUST WANTED TO MENTION THAT TO YOU ALL, 'CAUSE I KNOW YOU'RE GETTING COMMENTS AND, AND STUFF TOGETHER. UM, AND ALSO I KNOW THE NEXT HAPPY TO KEEP DISCUSSING THIS, BUT I KNOW THE NEXT, UH, CREDIT FINANCE SUBGROUP MEETING IS LIKE THE DAY BEFORE, UH, ANSWERS ARE DUE TO THE PUC. UM, SO YEAH, AND I ACTUALLY KIND OF FLOATED TRYING TO GET SOMETHING , YOU KNOW, GET SOMETHING VOTED OUT OF OUR GROUP THAT, YOU KNOW, WE DON'T LOVE THIS IDEA, BUT, UM, UH, THE GROUP DECIDED NOT TO DO THAT. I, I THINK MAYBE VOTES, YOU KNOW, I DON'T WANNA SPEAK OUT ATTORNEY THERE, BUT I THINK WE SHOULD MAYBE WAIT ON POLICY DECISIONS ON THIS UN UNTIL WE HAVE MORE INFORMATION FROM THE, THE COMMISSION. WELL, BUT THAT, LIKE, LIKE HE WAS SAYING, IT WAS JUST DRIVEN BY, THIS IS GOING BEFORE THE PC, LIKE, YOU KNOW, BEFORE WE'LL HAVE A CHANCE TO DO ANYTHING WITH IT, YOU KNOW, SO JUST WANTED TO MEMORIALIZE SOME OF OUR CONCERNS IN SOME WAY. BUT PS POC ACTUALLY WAS THERE AT THE MEETING, SO, UM, THEY DEFINITELY HAVE HEARD THE DISCUSSION AND, AND, UH, SO THAT'S WORTH, CAN I WEIGH IN ON THIS? IT PLEASE DO IT. I'M, UH, PRETTY NERVOUS ABOUT THIS GROUP, POTENTIALLY FRONT RUNNING THE COMMENT PROCESS AT THE COMMISSION. YEAH, ME, ME TOO. OKAY. I, I THINK IT'S INDIVIDUAL STAKEHOLDERS WILL COMMENT AT THE COMMISSION. SO I, I, YOU KNOW, I, I THINK THAT WOULD BE UP TO MEMBERS OF THIS GROUP, BUT IT SEEMS LIKE THAT WOULD BE A TRICKY BALANCE TO HAVE MEMBERS OF THIS GROUP VOTE ON THINGS AND THEN THEIR INDIVIDUAL COMPANIES BE TRYING TO IN, YOU KNOW, STILL ADVOCATE ON THEIR OWN POSITIONS. GO, SORRY, GO AHEAD, ERIC. YEAH, I, I APPRECIATE THAT. I, I AGREE. I, I DON'T KNOW THAT, [02:45:01] UM, WELL, LET ME SAY THIS A DIFFERENT WAY. WHILE IT'S UP TO THE COMMISSION TO INTERPRET AND ENFORCE THIS GUARDRAIL HB 1500, UM, WE HAVE TO, YOU KNOW, FOLLOW, YOU KNOW, THE MEANING OF THESE WORDS. AND SO I APPRECIATE THAT AUSTIN PASTED THEM INTO THE, INTO THE, UH, CHAT. AND, UM, IF IT ENDS UP DRIVING, YOU KNOW, MORE COLLATERAL THAN WE HAVE IN OUR EXISTING MARKET, UM, THEN THAT'S SOMETHING THAT THE COMMISSION WILL HAVE TO CONSIDER, YOU KNOW, AND MAKING DETERMINATIONS AROUND THE PCM. BUT, UM, WE HAVE TO FOLLOW WHATEVER THE INTERPRETATION OF THE LAW IS AND NOT, AND NOT, NOT DO THAT. OKAY. MAYOR A, DID YOU WANNA WEIGH IN? UM, I WAS MOSTLY JUST GONNA ADD THAT WE APPRECIATE THE DISCUSSION AT CFSG, AND I THINK THAT THAT WAS INTENDED AS, UM, EDUC AN EDUCATIONAL OPPORTUNITY TO LEARN ABOUT HOW THE VARIOUS OPTIONS FOR, UM, THE PCMS COLLATERAL MECHANISM ARE, UM, BEING CONSIDERED. BUT YEAH, DEFINITELY I THINK THAT THE ANTICIPATION IS, IS THAT, UH, ANY STAKEHOLDERS WHO HAVE THOUGHTS ABOUT WHICH OPTIONS SHOULD BE DONE OR, OR THE RAMIFICATIONS OF ANY OF THOSE OPTIONS WOULD BE HEAVILY ENCOURAGED TO FILE COMMENTS WITH THE PUBLIC UTILITY COMMISSION IN PROJECT 5 5 0 0 0, WHICH THE COMMISSION'S GOING TO CONSIDER STAFF'S QUESTIONS FOR COMMENT AT TOMORROW'S OPEN MEETING. AND ASSUMING, ASSUMING THAT THE COMMISSION ADOPTS THOSE QUESTIONS FOR COMMENT RESPONSES WOULD BE DUE ON JUNE THE 20TH. AND I THINK THAT IT'S QUESTION NUMBER NINE THAT ASKS ABOUT THE COLLATERAL DESIGN. UM, SO YEAH, WE JUST, UH, ENCOURAGE FOLKS TO, UH, FILE THEIR COMMENTS THERE. OKAY. I, I DON'T KNOW TO WHAT EXTENT WE COULD INFORM THE AGENDA, BUT IS THAT SORT OF A REQUEST TO MAYBE NOT FORM AN OPINION WHILE WE HAVE PENDING COMMENTS AT THE, AT THIS, UH, CFSG? SO, YEAH, WE, WE DIDN'T TAKE ANY ACTION OR ANYTHING. WE JUST, UH, HAD A PRESENTATION AND A DISCUSSION, SO WE'RE NOT REALLY CONTEMPLATING DOING ANYTHING RIGHT NOW. I JUST THREW IT OUT THERE. IT'S A, OKAY. THANKS BRENDAN. THANK YOU. OKAY, WE ARE ONTO [13. ERCOT Reports] OUR ERCOT REPORTS. UM, THE, THE FIRST ONE IS PROPOSED REVISIONS TO BOARD POLICIES AND PROCEDURES. WE'VE HAD THIS HERE A COUPLE OF TIMES. IS THIS KIM OR JOHN PRESENTING? I SEE KIM COMING TO THE FRONT. THANK YOU. GOOD AFTERNOON. THIS IS KIM RAINWATER FOR ERCOT LEGAL. SO VARIOUS UPDATES ARE PROPOSED TO THE BOARD POLICIES AND PROCEDURES DOCUMENT, AND AT THE APRIL TAC MEETING, WE GATHERED FEEDBACK ON REDLINE, SPECIFICALLY REGARDING THE BOARD'S PROCESS TO REVIEW REVISION, UH, TO CONSIDER REVISION REQUESTS. TAC ENDORSEMENT ISN'T REQUIRED, BUT TAC ASKED THAT WE COME BACK AFTER APPLYING SOME FEEDBACK. SO THE NEXT SLIDE THAT WE HAVE KIND OF GIVES GIVES SOME INSIGHT INTO HOW WE APPLIED FEEDBACK THAT WE HEARD AT THE TAC MEETING. AND SUBSEQUENT TO THAT, SO IN THE FIRST COLUMN, YOU SEE THAT THE SECTIONS THAT WE REVISED AND 1.3 THERE WAS FEEDBACK, LUMINANT AND TEAK, ESSENTIALLY WANTING TO CLARIFY THAT THERE'S NOT A POLICY OF DISCRETIONARY EXCLUSION OF COMMENTS AT PUBLIC MEETINGS OF THE BOARD OR BOARD COMMITTEES. SO WE CAN LOOK AT THOSE RED LINES AND YOU'LL SEE THAT WRITTEN OR IN-PERSON COMMENTS, UM, ARE PERMITTED. AND THESE RED LINES REALLY INTEGRATE POLICIES THAT ARE ALREADY IN EFFECT AND MEMORIALIZES THEM. SO WE HAVE A SHARED EXPECTATIONS ABOUT THE BOARD'S PROCESSES. UM, IN SECTION 1.3 0.1, YOU'LL SEE SOME FEEDBACK THAT BAKER BOTS GAVE FOR EOAN ANTIQUE, RECOGNIZING THAT WRITTEN COM COMMENTS CAN ALWAYS BE SUBMITTED TO THE BOARD IN SECTION 8.3, THERE WAS REFERENCE TO THE BOARD, UM, HAVING THE ABILITY TO DISCOUNT [02:50:02] COMMENTS THAT ARE OUT OF TIME OR PRESENT NEW OR CHANGED INFORMATION THAN WHAT WAS PRESENTED TO TAC FOR THE TAC VOTE. AND SO WE REFLECTED ON RELIANCE COMMENTS AND REMOVED THE OUT OF TIME LANGUAGE CONSIDERING THESE REQUESTS ARE MOVING FORWARD. AFTER THE BOARD, THEY DO GO TO THE COMMISSION. SO WE JUST STRUCK THAT LANGUAGE REGARDING 8.4 AND 8.5. UH, ANJI AND JUPITER POWER DID WANT SOME TYPE OF RECOGNITION THAT THE RELIABILITY AND MARKETS COMMITTEE WAS FORMED TO FACILITATE, UM, CERTAIN ENTITIES PERSPECTIVES BEING CONVEYED TO THE BOARD, AND AT THE SAME TIME WANTING TO RECOGNIZE THERE ARE OTHER, OTHER PARTIES. UH, SO WE ADOPTED SOME LANGUAGE SUCH AS FROM THE TEXAS ADMINISTRATIVE CODE, WHICH IS INTERESTED PARTIES. CAITLIN, DID YOU WANNA PAUSE HERE? YEAH, SO I, I DON'T KNOW WHERE THIS IS GOING, BUT THAT JUST DOES NOT ACCURATELY REFLECT WHAT MY CONCERN WAS. I, I BELIEVE WE RESOLVED IT, BUT IF THIS IS GOING SOMEWHERE SAYING THAT WAS JUPITER POWER'S CONCERN, THAT THAT WASN'T A, THAT'S NOT AN ACCURATE REPRESENTATION. OKAY. I, I MEAN, I, I FIGURED THERE MIGHT BE SOME TAKING ISSUE WITH THIS IS THE, THE SUMMARY THAT I HAVE BASED ON THE NOTES THAT I TOOK DURING THE MEETING. BUT WHEN WE LOOK AT THE RED LINES, YOU'LL SEE THOSE NAMED PARTIES. AND I THINK THAT IN OUR FOLLOW UP FOLLOW UP CONVERSATIONS, YOU WERE SPECIFICALLY TALKING ABOUT ENTITIES LIKE ERCOT, IMM, BASICALLY SECTION 21 ENTITIES. UM, SOME OF THOSE ENTITIES ARE ALSO NAMED IN THE TEXAS ADMINISTRATIVE CODE. SO WHEN WE GO TO THE RED LINES, UM, WE COULD FURTHER CONSIDER IF IT, IF IT IMPLEMENTS WHAT YOU ARE CONVEYING. SO MY CONCERN HAD BEEN THAT FOR NON ERCOT ENTITIES, FOR, FOR A MARKET PARTICIPANT, WE ARE REMOVING THE ABILITY TO THE EQUIVALENT OF AN APPEAL, BUT HAVE, YOU KNOW, A, A, I FORGOT WHAT THE WORD IS NOW, BUT, BUT TO HAVE AN OPPOSITION TO A UP VOTE. AND WE BROUGHT UP THE OTHER PARTIES LIKE ERCOT IN THE IMM IN THAT CONTEXT, BECAUSE THEY SEEM TO HAVE AND HAVE OTHER SECTIONS IN LANGUAGE WHERE THEY HAVE ABILITY TO PUT THINGS ON THE, THE BOARD AGENDA. AND SO THE, THE ISSUE THERE WAS REALLY STAKEHOLDERS MAKING SURE THAT WE'RE PRESERVING THE RIGHT TO HAVE THE EQUIVALENT OF WHAT'S NOW THE OPPOSITION TO A YES VOTE. OKAY. UH, I HEAR WHAT YOU'RE SAYING. I THINK THAT REGARDS, AS YOU CAN SEE, THE, THE NEXT LINE ALSO HAS 8.4 AND 8.5 LISTED. AND SO THE SENTIMENT THAT YOU'RE EXPRESSING, I THINK IS MORE ON THAT LINE. AND THAT WAS THE CONCERN. AND, AND, UM, YOU KNOW, IT SHOULD SAY JUPITER POWER UNDER BAKER BOTTS FOR EO. AND BASED ON THE FEEDBACK YOU'RE GIVING RIGHT NOW, UM, A CONCERN THAT THE BOARD IS PROVIDED WITH ALL THE NECESSARY INFORMATION TO MAKE A REASONABLE DETERMINATION ON REVISION REQUEST AND CREATE AN ADEQUATE RECORD, SHOULD THERE BE A LATER APPEAL TO THE COMMISSIONER COURT. SO THERE IS A, UM, PROCESS CALLED ATTACK RECOMMENDATION OPPOSITION. IT APPLIES TO THINGS THAT ARE NOT REVISION REQUESTS FOR ATTACK RECOMMENDATION IS REQUIRED, AND THEN SOMEBODY WANTS TO OPPOSE THAT THEY FILE COMMENTS TO THAT EFFECT FOR REVISION REQUESTS. WHAT WE'RE DOING IS, UH, MEMORIALIZING IN TWO NEW SECTIONS DEVOTED SPECIFICALLY TO REVISION REQUESTS. SO WE'RE ADDING MORE PROCESS, UM, NOT SO MUCH TAKING AWAY, UM, WE'RE NOT CALLING IT ATTACK RECOMMENDATION OPPOSITION, BUT WE'RE ADDING 8.4 AND 8.5, WHICH ALLOWS A FORMAL PROCESS FOR WRITTEN COMMENTS AND IN-PERSON COMMENTS. AND IN ADDITION, AS YOU'RE AWARE, UH, STAKEHOLDER SERVICES PREPARES A BOARD REPORT FOLLOWING THE BOARD'S DECISION, WHICH HAS THE REVISION REQUEST, LA LANGUAGE SUMMARIES OF ALL THE STAKEHOLDER DISCUSSIONS. UM, IT HAS COMMENTS FILED BEFORE ATTACK, AND THEN ON TOP OF THAT, YOU WOULD HAVE THE MINUTES OF THE MEETING REGARDING IN-PERSON COMMENTS, AND THEN YOU WOULD HAVE ANY COMMENTS THAT WERE FILED TO THE BOARD. SO ADDING THESE NEW PROVISIONS, I THINK DOES ADDRESS, UH, THE CONCERN FOR AMPLE RECORD. AND THEN IN THE APPENDIX B, WE DID ADD, UM, WE FURTHER IDENTIFIED SOME REGULATIONS, UH, MADE MORE CLEAR REFERENCES TO P 39, 1 51, UH, G SIX, UH, 1 5 1, 1 B. AND THEN, UH, AS I MENTIONED, THE TEXAS ADMINISTRATIVE CODE OR PUCT SUBSTANTIVE RULES [02:55:01] 25 360 2, C ONE AND TWO. SO WE CAN TAKE A LOOK AT THE RED LINES. THE BEST WAY TO SCROLL THROUGH THESE, JUST KIND OF, OKAY, SO I WANNA FOCUS ON WHAT WE FOCUSED ON LAST, LAST TIME WAS, UM, SECTION ONE AND SECTION EIGHT. THERE ARE SOME OTHER RED LINES THAT DON'T REGARD THE REVISION REQUEST PROCESS, AND THOSE ARE AVAILABLE IN THE MEETING MATERIALS. UM, PROVISION 1.2, JUST REGARDS, UM, ACCESS TO PUBLIC PORTIONS OF THE MEETING. IT FOLLOWS THE PROCESS THAT'S CURRENTLY IN PLACE. AND SECTION 1.3, THIS, THIS MAIN PORTION AT THE TOP HERE IS JUST DESCRIBING THAT, UH, THE AGENDAS FOR BOARD MEETINGS INCLUDE INSTRUCTIONS FOR PUBLIC COMMENTS AND 1.3 0.1, UH, THIS IS THE LANGUAGE THAT WE ADDED. SPECIFYING COMMENTS IN WRITING CAN ALWAYS BE SUBMITTED. 1.3 0.2 TWO'S CLARIFYING THAT WHEN WE DO HAVE PUBLIC COMMENTS, UM, AS IS ALREADY THE CASE, THE BOARD CHAIR OR THE COMMITTEE CHAIR CAN ALLOCATE THAT TIME, UM, AS NEEDED FOR THE OPERATION OF THE MEETING. AND 1.3 0.3, CLARIFYING THAT FOR URGENT MEETINGS CONDUCTED VIA TELECONFERENCE, UH, COMMENTS MAY BE REQUIRED TO BE IN WRITING AND, UM, OR URGENT MEETINGS ARE ALREADY DEFINED IN THE, UH, ERCOT BYLAWS. LET ME SEE IF I CAN MAKE THIS A LITTLE FASTER INSTEAD OF SCROLLING. OKAY. NEW SECTION EIGHT 8.2 JUST MEMORIALIZES THE CURRENT PROCESS FOR THE CONSENT. CONSENT AGENDA. MOST REVISION REQUESTS FALL THERE MOST ARE UNANIMOUSLY RECOMMENDED BY TAC IN 8.3. THIS IS THE PROCESS YOU HAVE SEEN A LOT AT THE R AND M COMMITTEE, UM, SINCE ITS FORMATION, ESPECIALLY LAST YEAR SO FAR THIS YEAR, APPLYING LESSONS LEARNED. AND IN THIS PROCESS, UH, THE BOARD COMMITTEE CAN, UH, SHARE A REPORT WITH THE BOARD ABOUT THE DELIBERATIONS, CONVEY THE COMMITTEE'S RECOMMENDATION ON THE REVISION REQUEST, UH, FOLLOWED BY ANY ADDED TIME ALLOCATED BY THE BOARD CHAIR, VICE CHAIR, UM, ALLOCATED EQUALLY BY POSITION. SO YOU MAY HAVE SEEN THAT WITH NORE 2 45 AT THE BOARD. UM, ERCOT SPOKE TAC, I THINK THE TAC CHAIR, TAC REPRESENTATIVE SPOKE, ERCOT SPOKE, AND THEN WE HAD SEVERAL COMMENTERS WHO SPOKE CAITLIN. SURE. UM, SO THERE, THAT WAS A SET OF JOINT COMMENTERS. IF YOU HAD TWO PARTIES THAT, YOU KNOW, HAD THE SAME VOTING POSITION, MM-HMM, , BUT SLIGHTLY DIFFERENT, YOU KNOW, DIFFERENT REASONING AND DIFFERENT POSITIONING, WOULD THAT BE AGGREGATED AS WELL? OR COULD IT BE AGGREGATED AS WELL? UH, THIS, THE LANGUAGE, YOU KNOW, BASED ON ALL THE FEEDBACK THAT WE GOT WAS TIME MAYBE AGGREGATED FOR MULTIPLE PARTIES FOR A POSITION. SO, YOU KNOW, THE TIME, IF TWO ENTITIES HAD A DIFFERENT POSITION, THEN THE TIME WOULD BE, THAT WOULD AFFECT THE ALLOCATION. NOT THAT IT WOULDN'T BE EQUAL, BUT THEY MIGHT NOT BE LUMPED TOGETHER. AND SO, UM, THAT THAT'S THE DISCRETION OF THE BOARD. THEY'RE GONNA HAVE TO ANALYZE THE NUANCE OF THAT SITUATION. BUT I DO THINK THAT AS YOU SAW WITH NOGA 2 45, 45 AT THE BOARD LAST TIME, MOST OF THE COMMENTERS WERE IN LINE AND THEY SHARED THAT TIME. IT WOULD BE DIFFERENT IF PERHAPS THERE WAS DISTINCTION THERE. OKAY. SO WE'RE NOT DEFINING POSITION HERE AS THE SAME VOTE ON A RR RIGHT, TO BE, SO LIKE ON, ON 1224, IF NED HAD VOTED NO BECAUSE THE FLOOR WASN'T HIGH ENOUGH AND THAT CONSUMER HAD VOTED NO BECAUSE IT WAS TOO HIGH, THAT TIME WOULDN'T BE AGGREGATED. UH, IT'S LEFT AS POSITION THERE. I THINK THAT, YOU KNOW, WE CAN ANTICIPATE THE, THE BOARD CHAIR, VICE CHAIR WILL TAKE A REASONABLE APPROACH TO THAT AND, YOU KNOW, WANT TO HEAR IF THERE'S A DISTINCTION. UM, OKAY, SO, UH, IN 8.4, THIS IS GETTING TO THE, [03:00:01] OKAY, 8.8 0.4, AND 8.5 IS GETTING TO THE NAMED PARTIES VERSUS INTERESTED PARTIES. SO 8.4 REGARDS, UH, WRITTEN COMMENTS. AND IT BASICALLY TAKES FROM SECTION 21 AND THE ADMINISTRATIVE CODE, CERTAIN ENTITIES, UM, ABOUT THREE OF THESE ENTITIES ARE IN THE ADMINISTRATIVE CODE, THINK ERCOT, IMM AND RELIABILITY MONITOR, MONITOR. BUT WE'VE ALSO NAMED OTHER ENTITIES THAT ARE IN SECTION 21. WE'VE LISTED THEM, UM, AS THEY ARE LISTED IN SECTION NINE, UM, REGARDING OTHER MATTERS, AND BASICALLY MEMORIALIZE THE PROCESS THAT EXISTS TODAY WHERE IF ONE OF THOSE ENTITIES WANTS TO SUBMIT WRITTEN COMMENTS, THEY SUBMIT THEM TO REVISION REQUESTS@ERCOT.COM. IF THERE'S ANOTHER INTERESTED PARTY SUCH AS THE PUBLIC, THEY WANNA SUBMIT COMMENTS, THEY GO BACK TO THE WHAT, UH, THE INSTRUCTIONS ON THE AGENDA, WHICH IS DESCRIBED IN 1.3 0.1. ERIC, JUST OUTTA CURIOSITY, AND I, I DON'T NECESSARILY NEED THE ANSWER TODAY, BUT, UM, WOULD, HOW, HOW WOULD ERCOT IDENTIFY ITSELF AS THE RELIABILITY MONITOR AND COMMENTS? I KNOW THE RELIABILITY MONITORS CALLED OUT, BUT I'M JUST CURIOUS IS, IS THERE A PROCESS IN PLACE FOR THAT? OR, AND IF THERE'S NOT, THAT'S OKAY FOR, FOR ERCOT TO SUBMIT COMMENTS SINCE FOR THE RELIABILITY MONITOR TO SUBMIT COMMENTS SINCE ERCOT, I THINK IS THE RELIABILITY MONITOR. UM, ERIC, THIS IS CHAD. YEAH, WE WOULD JUST SUBMIT COMMENTS SAYING THAT THE, THOSE INDIVIDUALS THAT ARE DESIGNATED AS RELIABILITY MONITOR EMPLOYEES ARE SUBMITTING THOSE COMMENTS ON BEHALF OF THE RELIABILITY MONITOR. THAT MAKES SENSE. ALL RIGHT. 8.5, THIS IS THE IN-PERSON COMMENTS PIECE. AGAIN, NAMED PARTIES, IT'S A LITTLE BIT SHORTER THERE BECAUSE WE'RE NOT REDEFINING THEM. UM, THEY CAN COMMENT IN PERSON ON REVISION REQUESTS BY BASICALLY SPEAKING WITH THE SECRETARY OR ASSISTANT SECRETARY. THAT'S USUALLY HOW IT'S ARRANGED. AND ANY OTHER INTERESTED PARTY, LIKE THE PUBLIC CAN REFER TO SECTION 1.32 ABOVE THE INSTRUCTIONS WILL BE ON THE AGENDA. I THINK USUALLY THAT'S SIGNING UP OUTSIDE OF THE BOARD MEETING OR COMMITTEE MEETING. AND IF WE CA, CAITLIN, CAN I ASK A QUESTION ON EIGHT FOUR? YES, PLEASE DO. GO AHEAD, CHRIS. SO ON EIGHT FOUR FOR TRADE ASSOCIATIONS, WOULD THEY BE PUSHED TO 1.3 0.1? I HAVEN'T REFLECTED ON THAT SPECIFICALLY, BUT I THINK YES, THEY'RE, THEY ARE NOT NAMED A TRADE ASSOCIATION WOULD, WOULD FOLLOW THE PROCESS IN 1.3 0.1. SO YOU WOULD, YOU WOULD GO TO THE AGENDA FOR THE MEETING, YOU WOULD READ THOSE PROVISIONS FOR SUBMITTING COMMENTS AND FOLLOW THAT. ALRIGHT. AND THEN THE, I GUESS SIMILAR, I THINK THIS IS A WAY TO READ IT, IS IF YOU'RE A REP BUT, AND A LICENSED REP, BUT YOU'RE NOT A MEMBER OF ERCOT, YOU WOULD THEN ALSO BE 1.3 0.1. IF YOU'RE NOT A A, A CORPORATE MEMBER, YOU COULD STILL, IF YOU'RE A MARKET PARTICIPANT, AND YOU KNOW, THERE'S A, THERE'S A LIST ON THE ERCOT WEBSITE LIST OF MARKET PARTICIPANTS IN THE ERCOT REGION. IF YOU FIND YOURSELF ON THERE, YOU WOULD FOLLOW, UM, YEAH, THE, THE FIRST SENTENCE. AND IF YOU'RE NOWHERE ON, YOU'RE NOT LISTED, MARK COULD PARTICIPANT, YOU'RE NOT A CORPORATE MEMBER. GO TO 1.1. ONE MORE QUESTION THERE FOR THE ERCOT MEMBER. SO IS THERE A DEFINITE DIFFERENCE BETWEEN A CORPORATE MEMBER, AN ASSOCIATE MEMBER, AND A CON COMMERCIAL CONSUMER MEMBER? WE HAVE DIFFERENT TYPES OF MEMBERS, BUT THEY'RE ALL MEMBERS. GOTCHA. SO IF WE GO, I THINK NED HAS A QUESTION. YEAH. THANKS. UM, FIR FIRST OF ALL, COMMENT IN GENERAL, UM, THANK YOU KIM FOR, YOU KNOW, TAKING THE, THE COMMENTS BACK AND, AND, AND WORKING ON THIS. I THINK, UH, BY AND LARGE WHAT I'VE SEEN ADDRESSES MOST OF THE, THE, THE QUESTIONS THAT I'D HAD AT OUR LAST MEETING. BUT CHRIS, UH, YOUR QUESTION ABOUT A TRADE ASSOCIATION GOT ME, GOT ME THINKING, UM, YOU KNOW, UNDER THIS FRAMEWORK, KIM COULD A, COULD A MEMBER, YOU KNOW, REQUEST TIME OR, YOU KNOW, SUBMIT COMMENTS THROUGH THE 8.4 OR THE 8.3 PROCESS? SORRY, I'M GETTING MY SEGMENTS WRITTEN. YOU, YOU'RE TALKING ABOUT WRITTEN OR IN PERSON COMMENTS BY TRADE? YEAH. WRITTEN OR IN PERSON. MM-HMM. . BUT, BUT ESSENTIALLY, YOU KNOW, YIELD TIME OR, OR, YOU KNOW, INCORPORATE THE TRADE ASSOCIATION AS A MATTER OF EFFICIENCY OR AGGREGATING VOICES, YOU KNOW, THE, THE MEMBER CAN CARRY IT, BUT IF THERE'S OTHERS THAT ARE, UH, WANT TO SHOW SUPPORT, THAT MAY BE AN EFFICIENT WAY TO, TO BRIDGE [03:05:01] THAT GAP. SO YOU'RE TALKING ABOUT SPEAKING ON BEHALF OF, OF OTHERS OR, YOU KNOW, REPRESENTING A GROUP. I THINK WE, WE HAD THAT EVEN LAST TIME, LIKE WITH GER 2 45, I THINK, UM, GOLF POLICY HAD SOME COMMENTS AND THEY SPOKE AND THEY, THEY SAID WHO THEY, UM, WERE ALIGNED WITH. YEAH. SO I, I THINK THAT THAT MAY ADDRESS OR MAYBE AN AVENUE, I JUST WANTED TO CONFIRM THAT THAT WAS, UH, THAT WOULD STILL BE AN AVAILABLE VENUE IF WE WANTED TO SAY, GET A TRADE ASSOCIATION'S INPUT. UM, YES. I MEAN, IT, IT'S DIFFICULT TO ANTICIPATE EVERY SINGLE SITUATION AND COMBINATION THAT COULD EXIST, BUT I THINK GENERALLY WHAT WE HAVE HERE ALLOWS AN AVENUE FOR ALL, ALL OF THESE ENTITIES TO COMMENT WITH, UM, YOU KNOW, SOME DISCRETION ALLOWED FOR AGGREGATING. UM, SOMETIMES, YOU KNOW, THE, THE BOARD CHAIR OR VICE CHAIR MAY HAVE A WAY THAT THEY RECOMMEND AGGREGATING AND SOMETIMES THE COMMENTERS, LIKE YOU'RE SAYING, WILL. YEAH. AND, AND THE THOUGHT IS THAT IT'S ACTUALLY MORE EFFICIENT TO, YOU KNOW, HAVE MORE FOLKS REPRESENTED BY A SINGLE TRADE GROUP AS OPPOSED TO HAVING, YOU KNOW, LOTS OF FOLKS COME UP AND SAY SIMILAR, BUT, UH, SUBSTANTIVELY THE SAME THING. SO IT'S A WAY TO SPEAK WITH ONE VOICE AND BE EFFICIENT WITH EVERYONE'S TIME. SOUNDS REASONABLE. ARE THERE OTHER COMMENTS ON SECTION EIGHT? WHAT, WHAT REMAINS, UM, REGARDING THE REVISION RE REQUEST PROCESS IS, UM, BASICALLY JUST WE'VE ADDED THIS APPENDIX. IT'S, IT'S A LITTLE DIFFICULT TO READ ON HERE, BUT IT'S JUST A TABLE. AND, UM, IT SUMMARIZES ALL THE, THE RED LINES REGARDING REVISION REQUESTS ABOVE, WHICH IS, I'D LIKE TO MAKE THIS A LITTLE BIT, UM, SMALLER. OKAY. SO, YOU KNOW, THERE ARE STILL TAC APPEALS. THAT'S THE FIRST, THE FIRST LINE. IT KIND OF OUTLINES HOW PAST, UH, COMMITTEE AND BOARD AGENDAS, UM, THE ORDER OF PRESENTATIONS AND LIST AUTHORITIES THAT RELATE TO THAT TOPIC. UM, REFLECTING THE USE OF CONSENT AGENDAS ABOVE. THAT'S THE, THE SECOND ROW, THE THIRD ROW REGARDS, UH, WHEN A PARTY, UNNAMED PARTY WANTS TO SPEAK IN PERSON OR SUBMIT COMMENTS, AND THEN THE LAST ROW REPRESENTS WHEN INTERESTED NINE, YOU KNOW, SOMEONE MAY NEED TO MUTE ON THE PHONE. UM, AND THEN THE LAST ROW WAS WHEN ANY OTHER INTERESTED PERSON WANTS TO COMMENT IN PERSON OR SUBMIT COMMENTS. AND THESE ARE JUST THE ORDER OF PRESENTATIONS. THIS IS NON-BINDING. IT'S JUST A QUICK VISUAL SO THAT WE CAN BE ON THE SAME PAGE ABOUT WHERE WE MAY, WHAT WE MAY SEE ON AN AGENDA ITEM. SO THERE ARE ANY OTHER QUESTIONS? I DON'T SEE ANY QUESTIONS IN THE QUEUE. THANK YOU. I MAKE ONE LAST COMMENT BEFORE WE WRAP UP. JUST FOR TRANSPARENCY. I WANTED TO LET, UH, LET IT BE, KNOW THAT THERE ARE SOME OTHER PROVISIONS IN THE BOARD POLICIES AND PROCEDURES THAT WE'RE LOOKING AT AMENDING. WE'VE TALKED TO THE HR AND G COMMITTEE CHAIR ABOUT IT. THEY DON'T IMPACT TAC OR MEMBERSHIP. SO WE, WE DIDN'T BRING THEM HERE, BUT THOSE ARE STILL UNDER DISCUSSION. SO WHEN WE GET TO THE HR AND G COMMITTEE DISCUSSION OF THE BOARD POLICIES AND PROCEDURES, YOU MAY SEE MORE REDLINING THAN YOU'RE SEEING TODAY, BUT IT'S, IT'S NOT GONNA INVOLVE TACKER MEMBERSHIP. OKAY. THANKS. THANK YOU. ALL RIGHT. I THINK PROBABLY WAS UP THE ENCORE WEST TEXAS 3 45 KV INFRASTRUCTURE REBUILD PROJECT. THIS IS A VOTING ITEM. YEAH. GOOD AFTERNOON, . SO I'M HERE TO PRESENT THE ENCORE WEST TEXAS 3 45 KB INFRASTRUCTURE REBUILD PROJECT, UH, THAT WAS SUBMITTED TO RPG IN NOVEMBER OF THIS YEAR OR LAST YEAR. SO THIS IS AN OVERVIEW OF THE PROJECT. UM, THIS IS A TIER ONE PROJECT WITH A TOTAL ESTIMATED COST OF ONE POINT, UH, ONE $2 BILLION. AND, UH, THIS IS PRIMARILY TO ADDRESS THE THERMAL OVERLOAD ISSUES AND LOAD GROWTH ISSUES IN SEVERAL COUNTIES IN THE WESTERN FOREST. UM, JUST TO GIVE YOU A BACKGROUND, THIS PROJECT WAS, OR, OR ALL THE ASPECTS OF, YOU KNOW, SUBMITTED IN THIS PROJECT WAS IDENTIFIED AS PREFERRED PROJECTS. UH, WITH THIS IDS HERE, 1, 2, 3, AND 25, IF YOU GO LOOK BACK AT THE, UH, 2021 PERMIAN BASIN [03:10:01] LOAD STUDY THAT WAS COMPLETED BASED ON THE, UH, S AND P FORECAST AND OTHER FORECAST FOR THE LOAD GROWTH PER PARTICULARLY FOR THE OIL AND NATURAL GAS LOAD FORECAST. SO THAT STUDY WAS COMPLETED IN, UH, END OF 2021. AND THIS PROJECT LINES WITH THOSE PROJECT IDENTIFIED THERE. SO, UH, LITTLE BIT, UM, BACKGROUND TIER ONE PROJECT, FALSE, UH, YEAH, OF A HUNDRED MILLION DOLLARS OR MORE. THIS WOULD RE, UH, REQUIRE A BOARD ENDORSEMENT. SO AS PER THE PROTOCOL REQUIREMENTS, WE ARE REQUIRED TO, YOU KNOW, SEEK, UH, TAX COMMENTS AND ANYTHING, UH, YOU WANT TO ADD TO THE BOARD ENDORSEMENT, WE CAN DO THAT. SO THIS IS THE PROJECT NEED, UH, THAT WAS IDENTIFIED FOR THIS AREA FOR THIS, UH, PROJECT. UM, IF YOU LOOK AT THE TABLE HERE, IT'S PRIMARILY OVERLOADS, UM, ANYWHERE FROM 58 MILES TO A HUNDRED, ALMOST 200 MILES OF OVERLOAD OF EXISTING 3 45 KB LINES. SO THAT'S WHAT THIS PROJECT IS TRYING TO ADDRESS. WHAT WE DID IS, UM, WE LOOKED AT THE PROJECTS IDENTIFIED AND OR SUBMITTED BY ENCORE AND SAW WHETHER IT ALIGNS WITH WHAT WAS PREVIOUSLY IDENTIFIED. AND, UH, WE CONCLUDED THIS, YES, THE NEEDS STILL EXIST AND THE PROJECTS SUBMITTED BY ENCORE WITH CERTAIN VARIATIONS, ALIGNS WITH WHAT WAS IDENTIFIED IN THE PER PERMANENT STUDY. SO, OTHER THINGS, AS, AS PART OF THE PROJECT ANALYSIS, WE LOOK AT THE SUB SYNCHRONOUS RESIDENT RESONANCE ISSUE, UM, AND WE CONCLUDED THAT WITH THE ADDITION OF OUR, OF THIS NEW UPGRADES, WE, WE DO NOT SEE ANY ISSUES OR SIGNIFICANT ISSUES WITH THE SSR IMPACT. AGAIN, UH, ALSO LOOKING AT THE CONGESTION ANALYSIS AND SENSITIVITY ANALYSIS FOR BOTH GENERATION AND LOAD, UH, WE CONCLUDED THAT THE PROPOSED PROJECT DOES NOT HAVE A IMPACT ON EXISTING CONGESTION OR INTRODUCE NEW CONGESTION. AND ALSO IT DOESN'T AFFECT THE, UH, LOAD SENSITIVITY AND THE GENERATOR SENSITIVITIES THAT WAS, UH, USED IN THE CASE. SO IN TO CONCLUDE HERE, UM, WE RECOMMEND THE WEST TEXAS INFRASTRUCTURE PROJECT, UH, TO ADDRESS THE NEED BOTH THE RELIABILITY NEED AND THE GROWTH IN OIL AND NATURAL GAS, UH, LOAD IN THE WEST, WESTERN AND FOREST AREA. UM, I SEE ALREADY A SLIDE THERE. I'LL JUST UH, CONCLUDE HERE AND GET BACK TO THE QUESTIONS. SO, UM, OUR RECOMMENDATION TO THE JUNE BOARD WILL BE TO, UH, ENDORSE THIS OR, OR ENDORSE THIS WEST TEXAS INFRASTRUCTURE PROJECT, UH, WITH THE EXPECTED INSERVICE DATE OF, UH, SUMMER OF 2028. UH, THERE IS A LOT OF NEED FOR COORDINATION OF OUTAGES WITH ERCOT. UM, SO THE, THE EXPECTED, UH, OR IN-SERVICE DATE IS SUMMER OF 2028. AND, UH, AGAIN, THE ESTIMATED COST IS $1.12 BILLION. SO THE NEXT THREE SLIDES, UM, PROVIDES THE DETAILS OF THE PROJECT. IT'S FAIRLY LENGTHY, SO I'M GONNA SKIP IT. AND I'M GONNA GO TO THIS LAST SLIDE HERE JUST TO GIVE YOU A HIGH LEVEL OVERVIEW OF WHAT THIS PROJECT IS. SO WHAT YOU SEE ON THE SCREEN IS THE HIGHLIGHTED PORTION WHERE, UM, WE HIGHLIGHTED THE REBUILT OF EXISTING 3 45 KV LINES AND THE DOTTED LINES ADD A NEW 3 45 KV PATH OR SECOND CIRCUIT, AND WHERE YOU SEE THE STARS OR THE NEW SUBSTATIONS. UH, SOMETHING TO NOTE RIGHT NEXT TO MORGAN CREEK, THERE ARE NEW, TWO NEW SUBSTATIONS, RANGER CAP AND CATTLEMEN. ALL THE SUBSTATIONS WILL BE TIED. AND, UM, ALSO AS PART OF THAT, YOU SEE A COUPLE OF OTHER SUBSTATIONS, PRONG MOSS AND, UH, RIDER SUBSTATIONS. THOSE ARE NEW SUBSTATIONS THAT 3 45 KIWI SUBSTATIONS. SO, WITH THAT, I'LL STOP AND SEE IF, UH, THERE ARE ANY QUESTIONS. GATEWAY. ERIC GOFF WAS FIRST, I THINK SO. UM, WE APPRECIATE THE WORK ON THIS PROJECT, UH, NAVARRA AND I WOULD LIKE TO ADD THAT WE THINK ERCOT SHOULD IDENTIFY ECONOMIC ADD-ONS, UH, TO THIS REBUILD PROCESS AND THE RTP DUE IN DECEMBER OF THIS YEAR. THIS COULD INCLUDE RECONDUCTORING, ADDITIONAL CIRCUITS, DYNAMIC LINE RATING EQUIPMENT, AND OTHER ITEMS WHERE THE INCREMENTAL COST OF THE ADD-ON MIGHT PASS THE ECONOMIC BENEFIT TEST REBUILDING AGING INFRASTRUCTURE AS A PERFECT TIME FOR ERCOT TO STUDY THE INCREMENTAL COSTS OF UPGRADES. AND ERCOT SHOULD HAVE ENOUGH ADVANCED KNOWLEDGE OF REBUILD PROJECTS TO PLAN AROUND THEM. SO IF YOU CAN'T DO IT IN, IN THIS RTP IN THE NEXT RTP, WE'VE GOT SOME TIME, BUT WE THINK THIS IS A GREAT OPPORTUNITY TO LOOK FOR ECONOMIC ADD-ONS TO THIS PROJECT, ESPECIALLY GIVEN THE COST. THANKS. YEAH, THANK, THANK YOU FOR THE COMMENT, KEVIN HANSON. YEAH. UM, JUST QUICK QUESTIONS, CLARITY. SO THIS PROJECT WAS APPROVED WITH THE OLDER LOAD FORECAST, NOT THE NEW LOAD FORECAST WE'VE BEEN TALKING ABOUT AT OTHER MEETINGS, CORRECT? YEAH. SO THIS, THIS PROJECT WAS ORIGINALLY STUDIED AS PART OF THE PERMIAN [03:15:01] STUDY THAT WAS, THAT WE DID IN 2021. AND WE IDENTIFIED THE NEED. SO WHAT WE DID HERE IS USING THE CURRENT MODELS, WE VALIDATED THE NEED OF THE PROJECT. YES. SO THIS IS NEEDED BASED ON THE NEW FORECAST TOO? YEAH, THIS ISN'T, SO THIS HAS THE 162 GIGAWATT LOAD FORECAST IMPACTED BY 2030 IN HERE. NOT, NOT QUITE THE 160 GIGAWATT FORECAST. THAT'S SOMETHING WE ARE STUDYING NOW, BUT WE INCORPORATED THE ALREADY KNOWN PERMIAN BASIN LOAD FORECAST. OKAY, GREAT. THANK YOU. YEAH, THANK YOU. IT LOOKS CLEAR. I SAW A SUGGESTION FROM BOB HILTON TO PUT THIS ON THE COMBO BALLOT. ARE WE OKAY WITH THAT? YEP. ALRIGHT, THANK YOU. THANK YOU. WE ARE ON TO THE 2023 MAXIMUM DAILY RESOURCE PLANNED OUTAGE CAPACITY, PERFORMANCE, AND METHODOLOGY REVIEW. THANKS. HEY, GOOD AFTERNOON. UM, LUKE BUTLER ERCOT RESOURCE FORECASTING AND ANALYSIS. UH, SO IF YOU REMEMBER, UH, LAST MONTH, WE, UH, I STOPPED BY AND GAVE A QUICK OVERVIEW OF REALLY JUST THE TIMELINE, UH, THIS'S BASED OFF A REQUIREMENT IN THE M-D-R-P-O-C METHODOLOGY THAT SAYS, EVERY YEAR, LET ME GO TO THE NEXT SLIDE. UH, ERCOT WILL REVIEW THE CURRENT METHODOLOGY AND THE CALCULATED M-D-R-P-O-C AND REPORT ITS FINDINGS TO TAC AND THE FINDINGS WILL INCLUDE BUT NOT BE LIMITED TO. AND THESE, THESE TWO BULLET POINTS HERE, WHICH ARE KIND OF BASIC LEVEL FACTS ABOUT M-D-R-P-O-C, SO THE, THE AGGREGATED HOURS OF RESOURCE OUTAGES, INCLUDING PLANNED OUTAGES, MAINTENANCE OUTAGES, AND FOREST OUTAGES IN THE PROCEEDING CALENDAR YEAR. SO RIGHT NOW WE'RE LOOKING BACK AT CALENDAR YEAR 2023, AND THEN COMPARISON OF THE CALCULATED M-D-R-P-O-C AND THE AGGREGATED HOURS OF THERMAL RESOURCE PLANNED OUTAGES IN THE PROCEEDING CALENDAR YEAR. SO HOW DID THERMAL OUTAGES ACTUALLY STACK UP TO THE M-D-R-P-O-C THAT WAS POSTED? UH, SO THOSE ARE THE TWO POINTS THAT ARE CALLED OUT SPECIFICALLY IN THE METHODOLOGY. AND LAST MONTH WHEN WE STOPPED BY, UH, ATTACK, WE HAD THE REQUEST TO PLEASE SEND US ADDITIONAL COMMENTS OR REQUESTS TO INCLUDE IN THIS PERFORMANCE REVIEW. UM, WHAT WE ENDED UP RECEIVING WAS KIND OF A BULK OF METHODOLOGY COMMENTS RATHER THAN KIND OF PERFORMANCE ANALYSIS PIECES. AND I'LL, I'LL GO INTO THAT NEXT. BUT THE ONE REQUEST THAT WE DID RECEIVE THAT WAS FOCUSED ON PERFORMANCE WAS THIS THIRD BULLET POINT. UM, AND, AND THE REQUEST WAS WHEN REVIEWING M-D-R-P-O-C EFFECTIVENESS, ERCOT SHOULD CONSIDER SENSITIVITIES TO LOAD GROWTH AND GENERATION RETIREMENTS ON THE DECREASING PLANNED OUTAGE AVAILABILITY AND HOW THAT DECREASED PLANNED OUTAGE ABILITY TRANSLATES TO RELIABILITY OUTCOMES. SO REALLY JUST KIND OF HOLISTICALLY LOOKING AT, YOU KNOW, IF WE'RE WE'RE LOSING, UM, DISPATCHABLE GENERATION OR THERMAL GENERATION, UM, AND LOOKING OUT AT M-D-R-P-O-C, WE KIND OF HAD THIS COMMENT THAT YOU GO OUT THREE REALLY ANYTIME IN THE FUTURE YOU SEE THE TRENDS DECREASING, AND IF WE KNOW WE'RE HAVING MORE RETIREMENTS COMING, UM, AND SIGNIFICANT LOAD GROWTH, POTENTIALLY THIS IS SOMETHING WE SHOULD ANALYZE TO SEE HOW THAT MAY AFFECT ALSO KIND OF PLANNED OUTAGES, BUT UP AGAINST M-D-R-P-O-C. SO WE DO PLAN TO INCLUDE THIS IN, UM, OUR PERFORMANCE REVIEW THAT, THAT WE WILL PRESENT. UM, AND THAT'S THE LAST BULLET POINT HERE. THAT'S, UH, WE'LL COME BACK TO TAC BEFORE THE END OF THIS YEAR TO PRESENT THESE THREE BULLET POINTS ALSO. SO THAT WAS ONE COMMENT WE WE RECEIVED, AND I DID WANNA JUST MENTION IF ANYONE, ANY OF THE COMMENTERS WANT TO ADD FURTHER CLARIFICATION OR COMMENTS TO THESE BULLET POINTS, FEEL FREE TO JUMP IN ANYTIME, JUST LET ME KNOW. YOU WANNA GO AHEAD? SURE. UH, THANK YOU LUKE, FOR, FOR TAKING, UH, THE FEEDBACK FROM THE, THE VARIOUS STAKEHOLDERS. I KNOW, I KNOW WE SENT SOME IN TO YOU AS, AS WELL AS OTHERS AND, AND REALLY APPRECIATE YOUR, YOUR REFLECT ON THOSE IN THIS PRESENTATION. UM, ONE, ONE THING THAT, UH, WE'VE SEEN RECENTLY AND, UM, SO I APOLOGIZE FOR NOT PUTTING IT IN THERE EARLIER, BUT, UM, WE HAVE NOTICED THERE ARE TIMES WHEN THE M-D-R-P-O-C AMOUNT WILL, WILL KIND OF JUMP AROUND AS IT GETS UPDATED. AND I'M THINKING ON THE FLY, UH, IF THERE IS A WAY TO CHARACTERIZE, YOU KNOW, THE CHANGES IN HOW FREQUENCY THE M-D-R-P-O-C OUTLOOK CHANGES, THAT MAY BE ANOTHER METRIC THAT WOULD BE HELPFUL IN, IN JUST EVALUATING, UM, YOU KNOW, IS IT CHANGING EVERY DAY? IS IT CHANGING, YOU KNOW, KIND OF BLOCKY IN A WEEK OR EVERY OTHER WEEK OR MONTH? SURE. MONTH TIME FRAMEWORK. OKAY. OKAY. UM, ONE REQUEST. WOULD YOU MIND SUBMITTING THAT KIND OF IN A YEAH. HAPPY TO SUMMARY FORM? SURE. UM, I THINK THAT'S A GOOD POINT TOO. WE CAN DO THAT. OKAY. SO NOW GETTING INTO THE COMMENTS THAT WERE REALLY FOCUSED ON, THE METHODOLOGY ITSELF, AND WHAT I'VE DONE [03:20:01] IS SUMMARIZE THESE, UM, KIND OF TO THE BEST OF MY ABILITY, BUT THAT'S WHERE IF YOU FEEL YOU WANT TO ADD SOME MORE COMMENTS, UH, BETWEEN THE COMMENTERS, PLEASE JUMP IN, LET ME KNOW. UM, DO YOU WANNA GO AHEAD AND ASK ERIC? NO, THAT'S FINE. OKAY. SO FIRST BULLET POINT CONSIDERATION OF BATTERY CONTRIBUTION SHOULD BE REVIEWED, UH, RIGHT NOW AN M-D-R-P-O-C, UH, BATTERY CONTRIBUTION ZERO IN THE METHODOLOGY. UM, SO SOMETHING TO CONSIDER SHOULD THAT BE SOMETHING ELSE. UM, LOOKING AT SOMETHING LIKE MOURA AND WHAT THEY CONSIDER MAYBE AS A STARTING PLACE, BUT SOMETHING TO CONSIDER. UH, SECOND ONE, CONSIDERATION OF NEW GENERATION BEYOND PLANNING GUIDE 6.9 SHOULD BE REVIEWED DUE TO SIGNIFICANT LOW GROWTH. SO RIGHT NOW THE METHODOLOGY IS VERY CLEAR OF WHAT, WHAT CAN BE CONSIDERED FOR FUTURE GENERATION SHOULD THIS BE REVISED. UH, THIRD BULLET POINT, THE CURRENT CONTRACT PERIOD FOR A FIRM FUEL SUPPLY SERVICE F-F-F-F-S-S RUNS FROM NOVEMBER 15TH THROUGH MARCH 15TH OF THE FOLLOWING YEAR. TO ENSURE THESE RESOURCES HAVE COMPLETED NECESSARY MAINTENANCE PRIOR TO THE CONTRACT PERIOD, START DATE PLAN OUTAGE REQUESTS FROM THESE UNITS SHOULD BE PRIORITIZED IN THE PLANNING OUTAGE QUEUE. UM, SO SOMETHING TO CONSIDER. UM, NEXT BULLET POINT, PRIORITIZE PLAN RESOURCE OUTAGES FOR MAJOR TURBINE INSPECTIONS AND MAINTENANCE. UH, SO I THINK THE, THE WAY THIS WAS KIND OF SUBMITTED WAS THERE'S, THERE'S DEFINITELY, UM, SUBSETS OF OUTAGE REQUESTS THAT REQUIRE, UM, GREATER KIND OF, UM, INSPECTION PERIOD AND KIND OF COMMITMENT TO THOSE OUTAGES AND SCHEDULING. THOSE ARE SEEM TO BE MORE, MORE DIFFICULT, WHICH IS UNDERSTAND UNDERSTANDABLE. SO IF THERE'S A WAY TO PRIORITIZE THOSE OR LUMP THOSE INTO A DIFFERENT CATEGORY, MAYBE THAT'S SOMETHING WE SHOULD CONSIDER. AND THEN ALLOW ERCOT FLEXIBILITY TO APPROVE OUTAGES THAT MAY EXTEND A DAY BEYOND AVAILABLE CAPACITY. SO IF IT JUST HAPPENS TO BE THAT THE LAST TAIL END OF THE OUTAGE IS CAUSING AN AN ISSUE, MAYBE THAT'S, THERE'S SOME WIGGLE ROOM THERE THAT WE COULD BUILD INTO THE METHODOLOGY. DID YOU WANT SOME? YEAH, I THINK, UH, MANY OF THESE COMMENTS WERE THINGS THAT WERE, UH, PREVIOUSLY RAGED BY TCPA AND ITS MEMBERS. AND I JUST WANTED TO POINT OUT AS WE'RE WORKING THROUGH DEVELOPING THIS PROCESS, THAT WE THINK MOST OF THOSE COMMENTS MAKE SENSE. WE'VE GOT ONE OR TWO DETAILED QUESTIONS, BUT YOU KNOW, DIRECTIONALLY, UM, WHAT TCPA IS ATTEMPTING TO ACCOMPLISH HERE MAKES SENSE TO US. AND SO I, I HOPE WE CAN SEE SOME REFORM TO THIS PROCESS. GO AHEAD, NED. OH, SOMEONE ELSE? ERIC? YES. I DON'T KNOW IF THIS IS THE FORUM TO, TO DISCUSS THIS, BUT, UH, WE'VE HAD A LOT OF, UH, LINGERING FORCED OUTAGES THIS YEAR, AND I WAS WONDERING HOW THIS IS GONNA BE REVIEWED BY ERCOT IN TERMS OF PROCESS, UH, IN TERMS OF, UM, BETTER COORDINATION. OBVIOUSLY DRRS DOWN THE LINE MIGHT TAKE CARE OF SOME OF THAT, BUT IS THERE ANY THOUGHT GIVEN, GIVEN TO WHAT WE'VE SEEN THIS, THIS PAST YEAR OF, OF WHAT MIGHT BE DONE, FRED? YEAH. HI, IT'S FRED FROM WORK. I THINK IF THAT IS NOT RELATED TO M-D-R-P-O-C, BUT IT'S KIND OF VOLTAGE, UM, SORRY, OUTAGE RELATED, WE THEN MORE THAN HAPPY TO WORK WITH YOU, UH, TO SEE IF THERE ARE WAYS WE CAN, UH, BETTER ACCOMMODATE NEED TO ON THIS FRIDAY, NEXT FRIDAY. OKAY, THANKS. UM, SO ONCE AGAIN, THANK YOU FOR INCLUDING THESE, AND ERIC, I APPRECIATE YOUR, YOUR COMMENTS OF, OF SUPPORT FOR THE CONCEPTS. UH, I WAS CURIOUS, YOU KNOW, THAT'S OKAY. AS YOU, AS YOU WENT THROUGH THIS, YOU KNOW, YOU HIGHLIGHTED THAT, UH, Y'ALL'S EFFORTS ARE GONNA BE FOCUSED ON THE THINGS ON THE FIRST PAGE. UM, SO IS THE RIGHT PATH FORWARD FOR TCPA AND ANY ANYONE ELSE THAT'S INTERESTED TO GET TOGETHER AND, AND SUBMIT AN NPRR TO, UH, TO MOVE THIS FORWARD OR MAYBE HAVE SOME OFFLINE DISCUSSIONS? YEAH, I THINK WHAT I CAN DO TOO, MAYBE FINISH THIS LAST ONE AND THEN I'LL KIND OF TALK NEXT STEPS OF, OF WHAT WE'RE CONSIDERING. BUT I WAS LOOKING FOR FEEDBACK TOO, FROM TECH ON THAT AS WELL. OKAY, FANTASTIC. OKAY. ANY OTHER QUESTIONS OR COLIN? YEAH, I WAS KIND OF FOLLOWING UP ON ERIC'S QUESTION, UH, FROM JUST A SECOND AGO. I MEAN, SO ON THE, ON THE SCOPE FROM THE, FROM THE FIRST SLIDE, I MEAN, IT IS THE ERCOT ASSESSMENT GOING TO ASSESS THE POTENTIAL IMPACTS OF THE M-D-R-M-D-R-P-O-C TO FORCED OUTAGES THAT WE HAVE SEEN. I THINK, UM, YOU, YOU MAY, THAT MAY BE COVERED SOMEWHAT [03:25:01] IN THAT THIRD POINT, BUT, UM, IT MAY BE GOOD TO CLARIFY THAT SPECIFIC POINT AS A, AS A FORMAL REQUEST AS WELL. UM, AND SOMETHING THAT WE PLAN TO PRESENT, I THINK THAT'S KIND OF GENERALLY, LIKE FRED WAS POINTING TO A, AN OUTAGE, NOT NECESSARILY JUST M-D-R-P-O-C, ALTHOUGH IT DOES SEEM LIKE IT COULD BE RELATED. BUT, UM, RIGHT NOW WE'RE FOCUSING ON KIND OF THIS SPECIFIC POINT, BUT I THINK WE COULD ALSO JUST KIND OF BE A LITTLE MORE DETAILED AND, AND CALLED OUT ITS IMPACT TO FORCE OUTAGES AS WELL. UM, IF THAT'S THE REQUEST, WE CAN, WE CAN PLAN TO DO THAT. OKAY, THANKS. JUST QUICK THOUGHT. SO RIGHT NOW WE'RE PLANNING ON 2030 BEING A MINIMUM LOAD OF 89 GIGAWATTS. BASED ON WHAT WE'RE SEEING WHEN WE APPROACH THIS NEW WORLD OF 89 GIGAWATTS, A LOAD IS OUR FLOOR FOR MINIMUM FOR THE YEAR, ARE WE GONNA BE ABLE TO TAKE OUTAGES? YEAH, I'LL LET FRED JUMP IN ON THAT ONE. FRED, THANK YOU. SO THIS FRED , I, I THINK OUR PLAN RIGHT NOW, AND THIS KIND OF COMMENT HAS BEEN KIND OF DISCUSSED IN THE BEGINNING WHEN WE PROPOSED THE WHOLE KIND OF FRAMEWORK OF M-D-R-P-O-C. SO OUR PLAN RIGHT NOW IS WE PLAN, CONTINUE TO USE THE, UM, BASED ON OUR CURRENT METHODOLOGY, BASED ON OUR LONG-TERM FORECAST, UH, ABOUT THE NUMBERS AND REFLECTED IN THE M-D-I-P-O-C, BUT ON TOP OF IT, A SIMILAR, LIKE THE THIRD ITEM HERE, WE CAN CERTAINLY, AS, AS PART OF THE METHODOLOGY REVIEW PROCESS, WE CAN, UH, PLUG IN DIFFERENT SENSITIVITIES TO SHOW WHAT'S THE IMPACT ABOUT THE DIFFERENT UNCERTAINTY OF FOR THE FUTURE AND HOW, HOW THAT AFFECT THE M-D-R-P-O-C. I THINK ULTIMATELY THE GOAL IS TO HAVE A METHODOLOGY PROCESS TO PROVIDE A SUFFICIENT WINDOW FOR THE OUTAGES NEEDED, BUT AT THE SAME TIME, THIS PROCESS MAY HELP US TO IDENTIFY THE ISSUES BEYOND THE OUTAGES. SO, BUT WE DO PLAN TO DO THAT ONE AND HOPEFULLY WE'LL COME BACK WITH THE, UH, INFORMATION TO SHARE WITH THE GROUP. DAN? YEAH, I MEAN, I'LL RISE TO THE BAIT A LITTLE BIT. UH, KEVIN'S QUESTION IS REALLY ABOUT RESOURCE ADEQUACY, RIGHT? I MEAN, AND COMING UP WITH THE CRITERIA AND EVERYTHING THAT'S BEEN BEING WORKED ON, YOU'VE GOTTA HAVE ENOUGH CAPACITY TO BE ABLE TO TAKE OUTAGES, RIGHT? SO THAT'S REALLY, THAT'S NOT A-M-D-R-P-O-C QUESTION ALL. IT'S MORE THE OUTCOME RATHER THAN THE THE PROBLEM. YOU GOOD? YEAH, I'M GOOD. I'M JUST CURIOUS IF WE'RE, YOU KNOW, IF WE'RE REALLY, IF WE'RE REALLY EXPECTING THAT MINIMUM LOAD OF V NINE GIGAWATTS BY 2030, WE SHOULD REALLY BE GETTING AN ANSWER TO AS WE'RE WALKING INTO THE BIGGER SLOPE, WE'RE LESS THAN SIX YEARS AWAY. THANKS, KEVIN, NED. UM, DAN, I APPRECIATE THE COMMENT ABOUT THAT. YOU KNOW, THE, THE QUESTION REALLY BEING A RESOURCE ADVOCACY ONE, I LIKE TO TAKE ANY CHANCE I CAN TO SAY M-D-R-P-O-C IS THE CANARY IN THE COAL MINE FOR RESOURCE ADEQUACY. SO, UH, I'LL DROP THAT HERE. BUT, UM, ALSO, ERIC, TO, TO YOUR QUESTION ABOUT SEEING SOME EXTENDED OUTAGES, ONE THING THAT, UH, WE'VE NOTICED IS THAT, UM, IT SEEMS LIKE MAYBE THERE ARE SOME EXTENSIONS THAT ARE, UH, DUE TO A A N SO OUTAGES THAT MIGHT BE DELAYED THAT THEN ARE BEING COUNTED AS EXTENDED. AND SO THAT MAY BE SOMETHING TO, TO LOOK AT IS HOW THOSE ARE CLASSIFIED AND IF THAT CAN BE, UH, SHARPENED UP TO, SO THAT IT'S NOT APPEARING LIKE IT'S A, A, LIKE A FALSE, A FALSE INDICATOR WHEN IT'S REALLY JUST TRYING TO MOVE TO, TO REFLECT, UH, ERCOT REQUESTS. DID YOU WANT TO, FRED? YEAH, JUST ONE AGAIN. YEAH, WE CAN TAKE IT AT ONE PICK, BUT I THINK IT JUST, UH, HIGH LABEL OVERVIEW. SO FOR THE PROCESS, TYPICALLY DURING THE AMAM PROCESS, IF WE DO GET A RESOURCE TO HELP US, UH, KIND OF MOVE THE OUTAGES AROUND, SO PUT A PROTOCOL AND THE PROCESS, WE KIND OF, WE WORK WITH YOU AND, UH, TO IDENTIFY THE WINDOW REALLY CAN SUPPORT YOU AS A P AND I CAN DEFINITELY GO BACK TO SEE HOW WE CATEGORIZE IT, BUT IF THE PRINTOUT, WE TENDED TO KEEP IT AS A PRINTOUTS, BUT IF NOT, WE, WE CAN CODIFY. THANK YOU. THANKS FRED. OKAY. UH, SO JUST KIND OF GETTING TO NEXT QUESTION ABOUT LIKE SCHEDULING AND HOW DO WE THINK WE WANT TO APPROACH THIS? SO LOOKING FOR SOME FEEDBACK ON THIS AS WELL, BUT RIGHT NOW THE CURRENT PLAN IS TO SOMETIME KIND OF LATE SUMMER, MAYBE EARLY FALL, COME BACK TO TECH [03:30:01] AND BE ABLE TO WALK THROUGH EACH ONE OF THESE RECOMMENDATIONS AND EITHER SHOW SOME DATA, UM, WITH EITHER SAYING WHY WE AGREE OR WHY WE DON'T AGREE ON EACH BULLET POINT. UM, AND, AND THEN MAYBE AT THAT SAME TIME WE'D BE PRESENTING, UM, A DRAFT OF SOME CHANGES THAT WE ARE ALSO THINKING OF PROPOSING ON THE METHODOLOGY AS WELL. SO SOME OF THESE MAY BE MAKING INTO THAT, BUT I THINK THAT'D BE THE SAME TIME WE'D KIND OF LIKE TO SHOW THE FIRST DRAFT OF A REVISED METHODOLOGY WITH TAC AS WELL. SO, UM, IDEALLY WE CAN GO THROUGH ALL OF THESE AT THAT TIME, BUT MAYBE WE'RE ONLY PARTIALLY DONE. SO I GUESS THE, THE QUESTION I WOULD HAVE IS IF MAYBE THAT'S SOMETHING TO CONSIDER IS WE CAN KIND OF KEEP THIS GOING, UM, THROUGHOUT THE YEAR, MAYBE DO SOME CHECK-INS ON THIS TO SEE. UM, BUT THAT'S CURRENTLY THE PLAN RIGHT NOW IS LATE SUMMER, EARLY FALL, COME BACK AND GIVE A, A REVIEW OF THESE RECOMMENDATIONS AND OUR THOUGHTS ON THEM. ANY COMMENTS ON THAT PLAN? I, I SAW AT LEAST ONE THUMBS UP. ARE THERE COMMENTS ON THAT? OKAY. I THINK WE'LL GO WITH THAT PLAN. OKAY. OKAY. THAT'S ALL I HAD. GREAT. THANKS LUKE. WE ARE ONTO OTHER BUSINESS. [14. Other Business] ANN, WE HAVE A 2025 BLOCK CALENDAR. YES, THANK YOU. SO WE REVIEWED THIS, THE LAST TAC MEETING, UM, BASED ON THE BOARD REDUCING THEIR MEETINGS TO FIVE MEETINGS NEXT YEAR. UM, AND WE DISCUSSED LAST MONTH REDUCING THE AMOUNT OF TAC MEETINGS FROM 11 TO NINE DUE TO THE BOARD TIMING. AND WE WOULD HAVE THREE TAC MEETINGS, UM, BETWEEN BOARDS. SO WE SUGGESTED TAKING OUT THE JUNE 25TH AND SEPTEMBER 24TH TAC MEETINGS TO REDUCE IT DOWN TO NINE TAC MEETINGS. COREY WENT BACK AND DREW UP A TIMELINE OF HOW THIS WOULD AFFECT REVISION REQUESTS AND WHAT BOARD THEY WOULD HIT. AND TAKING THOSE TWO MEETING OUT, UH, MEETINGS OUT WOULDN'T CHANGE ANYTHING. SO BASICALLY A REVISION REQUEST GOING TO THE JUNE TAC MEETING VERSUS JULY TAC MEETING WOULD ALL GET TO THE SEPTEMBER BOARD. AND THEN SAME WITH SEPTEMBER AND OCTOBER, THEY WERE BOTH STILL GET THE DECEMBER BOARD. SO IT'S REALLY UP TO TAC WHAT THEY WANNA DO. YOU KNOW, WE CAN ALWAYS SCHEDULE MORE TAC MEETINGS AS WE HAVE DONE THIS YEAR OR WE CAN KEEP THE 11 TAC MEETING TIMELINE. GO AHEAD, BOB, FOR PLANNING PURSES, UH, FOR PLANNING REASONS AND TRAVEL REASONS, I WOULD SUGGEST LEAVING IT THE WAY IT IS. AND I MEAN, THIS IS JUST MY THOUGHTS, BUT UNDERSTANDING THAT YOU TWO OR WHOMEVER IS GOING TO UNDERSTAND IF THAT AGENDA IS NOT FULL, CANCEL IT WITH A NOTICE. THAT'S MY ONLY, THAT, THAT'S MY THOUGHT. I'D RATHER HAVE IT ON AND PULL IT OFF RATHER THAN NOT HAVE IT ON AND PUT IT ON. 'CAUSE WE HAVE A PROBLEM WHENEVER WE TRY TO DO THAT. THAT'S JUST MY THOUGHTS. ANN'S GIVING ME A DIRTY LOOK. SO ANN WOULD NEVER DO THAT. CAN WE SCRUB DOWN A LITTLE BIT? OH, TRUST ME, I HAD A BAD ANKLE BECAUSE SHE KICKED ME SO MANY TIMES. SO THIS ONE IS JUST WITH THE NINE MEETINGS. SO WITH BOB'S SUGGESTION, WE WOULD PUT BACK IN THE NINE 20 OR 6 25 JUNE MEETING, WHICH IS RIGHT AFTER THE BOARD, AND THEN ALSO THIS SEPTEMBER 24TH TECH MEETING, WHICH IS RIGHT AFTER THE BOARD. CAN WE MOVE THOSE EITHER WAY A WEEK UP TO JUNE 18TH AND SEPTEMBER 17TH AND HAVE PLACEHOLDERS FOR THOSE MONTHS? OKAY. EITHER ONE WAY WILL WORK, YOU KNOW, THAT WAS JUST MY SUGGESTION, BUT I'M OKAY WITH EITHER WAY. I'M JUST THROWING THIS OUT AS A THOUGHT. WE, WE COULD DO THAT UNDERSTANDING THAT THOSE PRS MEETINGS, THOSE ITEMS WOULD NOT GET TO THAT WOULD NOT GO TO THE BOARD. YEAH, BECAUSE THAT SOMETIMES CONFUSES PEOPLE THAT, OH, THIS WILL GO TO THE NEXT TAX MEETING AND THAT WOULDN'T BE THE CASE. YEAH, WE'VE DONE THAT AT LEAST ONCE THIS YEAR THOUGH, RIGHT? YEAH, THAT WOULD BE MY SUGGESTION. UNLESS SOMEBODY HAS BETTER DIFFERENT IDEA. OKAY, SO WE'LL MAINTAIN THE 11 TAC MEETINGS AND HAVE THE JUNE ONE ON THE 18TH AND THE SEPTEMBER ONE ON THE SEVEN 17TH, COLIN SAYS IT'S FINE. OKAY. OKAY. THANK HOPEFULLY WE'LL CANCEL. YEP. JUST, JUST ASKING I TO GET IT ONTO THE BOARD. DO WE NEED A WEEK? DO WE NEED TO HAVE SEVEN DAYS? WE DO. SO THOSE WOULD NOT GO TO THE BOARD. THOSE WOULD NOT GO TO THE NEXT BOARD. OKAY. THAT'S WHAT WE'RE SAYING. SO WHY, WHY WOULD WE SCHEDULE THAT? YOU KNOW, SO WE WANT TO SEE EACH OTHER AND TALK. WE'VE, WE'VE DONE THAT. I MEAN WE, I THINK JUST DID THAT IN APRIL. WE COULD SCHEDULE THEM FOR THE DAY IMMEDIATELY FOLLOWING THE BOARD, [03:35:01] BUT I THINK THAT'S A LONG WEEK FOR SOME OF US. I, I THINK JUST TO HAVE A PLACEHOLDER ON THERE. GO AHEAD, BRIAN. I, I'M OF THE MIND THAT IF IT'S NOT GONNA MATTER FOR US BEING ABLE TO GET SOMETHING TO THE BOARD, THEN THERE'S NOT AN ADDITIONAL BENEFIT. UM, MY OPINION. SO ARE YOU SUGGESTING MONDAY INSTEAD OF WEDNESDAY SO YOU CAN GET TO THE BOARD? I I WAS FINE WITH WHAT ANNE HAD. OKAY. SUGGESTED INITIALLY OR COREY, WHOEVER DRAFTED THIS WITH BENIGN. I THINK THE PROBLEM WE, BECAUSE I FEEL LIKE WE HAD THIS DISCUSSION ALREADY, AND THE PROBLEM YOU RUN INTO IS THEN YOU'RE NOT PUTTING A LOT OF TIME BETWEEN PRS AND TCC. AND SO, RIGHT. SO THE JUNE, FOR JUNE, IF WE DID SCHEDULE ON THE 18TH, THE JUNE 12TH PRS, WE WOULD NOT INTEND FOR THEM TO GO TO THE JUNE TAC MEETING. THEY WOULD GO TO THE NEXT TAC MEETING, THE JULY. OKAY. SO, BECAUSE IT WOULDN'T GET TO THE BOARD ANYWAY. SO BOB, ARE YOU FINE WITH US GOING TO THE NINE MEETINGS? I, I'M FINE WITH THAT AS LAID OUT. I WAS JUST THROWING THAT OUT AS AS, AND WE'LL JUST A REASON, REASON YOU WOULD KEEP IT 11, BUT I'M FINE WITH NINE. WE'LL PLAN TO SCHEDULE A BUNCH OF SPECIAL MEETINGS DEPENDING ON WHAT ISSUES COME UP. WELL I THINK, YOU KNOW, IF WE'RE STILL TALKING ABOUT 2 45 BY THEN NEXT JUNE, I SAID THAT FOR DANS. AND THEN WITH TRAVEL AND PLANNING PURPOSES, IF WE DO HAVE SPECIAL ATTACK MEETINGS LIKE WE ARE DOING THIS TIME, WE CAN ALWAYS HAVE THEM WEBEX ONLY AS WELL. THERE'S ALWAYS THAT OPTION. SO DAN, YOU DON'T HAVE TO CANCEL YOUR NEXT JUNE VACATION YET. . OKAY. OKAY. SO WE'LL KEEP IT AT NINE AND THEN WE'LL SEND THIS AROUND TO THE SUBCOMMITTEES NEXT MONTH AND SEE WHAT YOU GUYS WANNA DO. ERIC, DID WE GET TO YOUR COMMENT? UM, THERE'S NO NEED TO ADD ANYTHING TO WHAT YOU'RE TO OKAY. DISCUSSED. SO ANNE WAS RIGHT TO START WITH, BUT THEN THANKS ANNE. . ALL RIGHT. AND KAITLYN, DO YOU WANNA TALK ABOUT THE ANNUAL MEMBERSHIP MEETING QUICKLY, JOHN? UM, SO WE, WE BROUGHT THIS TO TECH LAST YEAR. WE, THE BOARD ASKED TO HAVE TECH MEMBER, OR I THINK THEY COULD BE ERCOT MEMBERS, SPEAKERS AT THE ANNUAL MEETING. AND WE HAD TALKED ABOUT HAVING SOME KIND OF PROCESS TO CHOOSE WHO THOSE SPEAKERS ARE. CLIFF AND I DID THAT JUST ON BEHALF OF LEADERSHIP, WELL, ON BEHALF OF OUR COMPANIES. BUT AS, AS LEADERSHIP LAST YEAR, UM, I THINK THE SLIGHT CHANGE THIS YEAR FOR THE OVERALL AGENDA AS I UNDERSTAND IT, IS TO KIND OF SHORTEN THE LENGTH OF TIME WE HAVE BOTH MEMBER AND OUTSIDE SPEAKERS. SO FOR, FOR TAX SPEAKERS, I THINK WE'D HAVE A TOTAL OF MAYBE 15 MINUTES, SLIGHT PREFERENCE FOR ONE SPEAKER. BUT IF WE WANTED TO PUT TWO SPEAKERS AND FOR, FOR SHORTER SPEECHES ADDING UP TO THE 15 MINUTES, WE COULD DO THAT. BUT I, I THINK WE WANTED TO TALK ABOUT A PROCESS FOR SELECTING THOSE PEOPLE OR VOLUNTOLD THEM OR, OR WHATEVER. UM, ONE THOUGHT I HAD WAS TRYING TO ROTATE THROUGH SEGMENTS. SO WE, WE HAD THE GENERATOR AND THE, THE COOPERATIVE SEGMENT LAST YEAR AND I'M, I'M TOTALLY OPEN TO, TO OTHER THOUGHTS. COLIN MAY HAVE THOUGHTS AS WELL. ERIC, DID YOU WANNA GO FIRST? OH, NO, THAT WAS A JOKE. I, I PUT DETERMINATION BY LOTTERY. THAT UH, THAT'S FINE. JOHN, DID YOU WANNA ADD ANYTHING? UM, NOT REALLY. I GUESS, UH, YOU KNOW, WE DON'T, WE DON'T WANT TO SELECT WHO THE MEMBER SPEAKERS ARE, SO WE WANTED TO KIND OF LEAVE THAT TO YOU. IT'S OBVIOUSLY STILL EARLY IN THE YEAR, SO THERE'S TIME TO FIGURE THIS OUT. BUT, UM, WE THOUGHT IT WOULD BE GOOD TO BRING UP NOW SO THAT WE DON'T RUN OUTTA TIME. BUT, UH, YEAH, NOT, NOT MUCH TO ADD ANY IDEAS OR COMMENTS? NO, BOB, I'M JUST SITTING HERE THINKING, AND WE NEED TO DEFINE WHAT WE'RE TRYING TO DO WITH THIS AND, AND GET THROUGH, UH, AND THEN MAKE A DECISION ON WHETHER THIS IS JUST WHERE WE HAVE SOMEONE COME IN AND WE KIND OF DO LIKE A 15 MINUTE EDUCATIONAL THING OR IF IT'S INFORMATIONAL OR IF IT'S, UH, IF WE SELECT IT BY DEPENDING ON WHAT'S ON THE AGENDA. MM-HMM. AND WHAT SOMEONE WOULD LIKE TO SAY ABOUT THAT ON THE AGENDA THAT THEY, YOU KNOW, R AND M AND ARE, ARE DEALING WITH. SO THERE'S SEVERAL WAYS TO GO. I THINK WE JUST NEED TO CLARIFY WHAT WE'RE REALLY TRYING TO ACCOMPLISH. SO THIS IS THE ANNUAL MEETING AT THE END OF THE YEAR. OH YEAH, SORRY. WHERE THERE'S COCKTAILS [03:40:01] AND NEVER MIND BREAD SHAPED GINGER BREAD, MEN SHAPED HAM YOU'VE GOT. SO, UM, I EDUCATIONAL COULD BE GREAT, BUT I, YOU KNOW, I, I THINK LAST YEAR WAS AT 7:00 PM JUST ONE THOUGHT. IT'S SORT OF LIKE THE RIGHT AND PRIVILEGE OF BEING ATTACKED. LEADERSHIP . HE, HE KNEW THAT WAS COMING SO , I'M HAPPY TO DO IT. THE, THE OTHER THOUGHT I HAD, IF, YOU KNOW, BASED ON SEGMENTS, I, I THOUGHT IT MIGHT BE GOOD TO HEAR FROM A CONSUMER, BUT I, I DON'T, YOU KNOW, INTEND TO PUT ANYBODY ON THE SPOT. SO I, I THINK THAT WOULD BE A GOOD MIX TOO. SINCE LAST YEAR WE HAD A GENERATOR AND A CO-OP IF WE WANTED TO DO A UTILITY AND A CONSUMER, SOMETHING LIKE THAT. OR HAVE COLIN SPEAK THE WHOLE 15 MINUTES. SO ROY YEAH, I WAS JUST SAYING I THINK CONSUMER WOULD BE A, A GOOD, UH, REPRESENTATIVE TO PROVIDE SOME FEEDBACK TO SHARED. I THINK THAT'S RICK DOWN THERE. NO, GARY CAN, CAN WE THANK ON IT AND SEND AN EMAIL TO STAKEHOLDER SERVICES AFTER WE TALK A COUPLE OF FOLKS INTERNALLY? YES. I THINK WE WOULD PROBABLY WANNA KEEP IT HERE FOR A LITTLE BIT. RIGHT JOHN? AND I THINK, YOU KNOW, WE DON'T NEED TO DECIDE ON A PERSON. I THINK WE WANTED TO KIND OF DECIDE ON A PROCESS AND IF, IF THE PROCESS IS EVERY YEAR LEADERSHIP HAS TO DO IT, I THINK THAT'S ONE IDEA OR KIND OF ROTATING THROUGH SEGMENTS OR, OR ANYTHING ELSE. OKAY. CAITLIN, MAYBE ONE THOUGHT WOULD BE TO HAVE A COMBO OF A, A REGULATED ENTITY TYPE AND A COMPETITIVE MARKET ENTITY TYPE EVERY YEAR AND THEN YOU CAN KIND OF SET THE SCHEDULE. YEAH, I THINK THAT WOULD BE GOOD. OKAY. ANY OTHER THOUGHTS ON THAT? SO WE WILL, WHAT SHOULD WE DO? JOHN RE REVISIT THIS IN A COUPLE MONTHS, MAYBE BRING IT BACK TO JULY TECH, GIVE EVERYONE A LITTLE BIT TO THINK ABOUT IT. THAT'S OKAY WITH, THAT'S OKAY WITH ME. OKAY. I ASSUME YOU DON'T WANT ME TO READ THAT JOKE. A GOOD IDEA AS THE NEWEST MEMBER GIVE IT TO LUBBOCK. OKAY. . . OKAY. UM, ANY OTHER, OTHER BUSINESS? SO LET'S, IT'S 1 27. LET'S BREAK UNTIL, OH, WE HAVE A COMBO BALLOT. [15. Combo Ballot (Vote)] COREY. WELL I JUST THOUGHT WE WERE GONNA PUT NOER 2 45, UM, THE COMBO BALLOT. UM, SO BOB HILTON, IS THAT A MOTION? SECOND. KEVIN HANSEN. ALRIGHT, THESE THINGS ON THE COMBO BALLOT ARE ON THE SCREEN. ALRIGHT. ON THE MOTION TO APPROVE THE COMBO BALLOT. WE WILL START UP WITH THE CONSUMERS. WITH ERIC. YES. THANK YOU. NA BARRAGE. THANK YOU. THANK YOU GARRETT. YES, SIR. THANK YOU ERIC. YES, THANK YOU. THANK YOU RICK FOR MARK. YES, THANK YOU. AND RICK FOR NICK? YES. THANK YOU. UH, MIKE MIKE'S LEFT US A BLAKE FOR MIKE. YES, THANK YOU. AND THEN BLAKE? YES. THANK YOU ERIC. YES. THANK YOU LUCAS FOR JOHN? YES. THANK YOU. ONTO OUR INDEPENDENT GENERATORS. BRIAN? YES, THANK YOU, KAITLIN. YES, THANK YOU. BOB HILTON. YES, SIR. THANK YOU SIR. NED? YES. THANK YOU COREY. THANK YOU. ONTO OUR IPMS. RASHMI. YES. THANK YOU. THANK YOU, JEREMY. YES. THANK YOU. THANK YOU, IAN. YES. THANK YOU COREY. THANK YOU KEVIN. YES, THANK YOU. THANK YOU. AND BILL LEFT HIS VOTE TO CHRIS. YES. CHRIS YESS. THREE YESS. IAN HAILEY, A LEVEL OF CONTROL. YES. FOR JENNIFER? YES, FOR JENNIFER. THANK YOU. AND OUR IOUS STACEY FOR KEITH? YES. THANK YOU, DAVID. YES, THANK YOU COLIN? YES, THANK YOU, UH, DAVID FOR RICHARD? YES, THANK YOU. ONTO OUR MUNIS RUSSELL. YES, THANK YOU JOSE. YES, THANK YOU DAVID. YES, THANK YOU COREY, YOU AND ALICIA. YES. THANK MOTION CARRIES UNANIMOUSLY. OKAY, SO NOW WE CAN TAKE A BREAK UNTIL TWO AND WE WILL RESUME AND TALK ABOUT NOER 2 45. [03:45:02] THIS IS NOTICED FOR A VOTE, BUT I DON'T THINK WE'D IMAGINE A, A VOTE, BUT WE MIGHT DO STRAW POLLS AND THINGS LIKE THAT. NOBODY CARES. OKAY. GO EAT LUNCH. OKAY, I THINK WE'RE GONNA GO AHEAD AND GET STARTED. SO WE ARE ON [16. NOGRR245, Inverter-Based Resource (IBR) Ride-Through Requirements (Vote)] NOUR 2 45. WE HAD A ROBUST AND LENGTHY WORKSHOP LAST WEEK, TWO WEEKS AGO, MAY 10TH. UM, AND, AND WE ARE GONNA FOLLOW THAT UP TODAY. AND SO AS PROMISED, ERCOT WILL BE PRESENTING IN A LITTLE BIT THE, THEIR COMMENTS ON THE TAC DISCUSSION, AND THOSE WILL REFER BACK TO THE NUMBERED ISSUES THAT THEY HAD IN THEIR PRESENTATION. I THINK COLIN AND I WOULD REALLY LIKE TO GET AGREEMENT ON CONCEPTS WHERE WE CAN TODAY. AND SO I, I THINK, YOU KNOW, WE ARE HOPING TO GET AGREEMENT ON, I THINK WE WERE PRETTY CLOSE ON, UM, MAKING IMPROVEMENTS TO THE MAX EQUIPMENT CAPABILITY DE DEPENDING ON THE, THE DEFINITION THERE, UM, MITIGATION OF FAILURE REQUIRED FOR NEW IBR AND THEN, UM, SOME, SOME KIND OF ALLOWANCE FOR ERCOT TO DENY EXEMPTION FOR AN ACCEPTABLE RE RELIABILITY. UM, AND THEN WE NEED MORE DISCUSSION ON SEVERAL ITEMS. SO WE WANNA MAKE SURE WE SPEND A LOT OF TIME ON THAT EXEMPTION PROCESS AND PERHAPS SEE IF WE CAN GET CLOSER ON THE EFFECTIVE DATE FOR NEW RESOURCES. THE WAY I THOUGHT WE WOULD START WAS WITH RYAN QUINT, WHO WAS UNABLE TO PRESENT AT THE LAST MEETING. BUT RYAN, I WAS HOPING WE COULD REALLY FOCUS AND SPEND THE BULK OF THIS ON YOUR COMMENTS ON, ON THE, UM, DEFENSE IN DEPTH METHOD METHOD FOR THAT, UM, THAT, THAT DAY FOR NEW RESOURCES. I THINK SOME OF THESE SLIDES KIND OF GO OVER THINGS WE, WE DISCUSSED AT THE LAST WORKSHOP. UM, I, I THINK SLIDES ONE THROUGH NINE ARE, ARE KIND OF INTRO AND AND BACKGROUND. AND THEN THE LAST FEW SLIDES, 24 THROUGH 27 ARE, ARE MODELING. SO IF WE COULD KIND OF FOCUS ON THE EXPLANATION OF YOUR COMMENTS AND IN PARTICULAR THAT DEFENSE IN DEPTH, UM, METHODOLOGY. SURE. AND SO IT'S 2 0 5, UM, HOPEFULLY WRAP THIS UP, YOU KNOW, CLOSER TO FOUR THAN FIVE. SO MAYBE SPEND HALF AN HOUR ON RYAN'S PART AND THEN REALLY TRY TO SPEND THE, THE REST OF THE MEETING TRYING TO GET SOME, GOING THROUGH ERCOT COMMENTS AND TRYING TO GET SOME AGREEMENT ON THE CONCEPTS AS DISCUSSED. GREAT. ALRIGHT, I WILL DO THAT. UM, CAITLIN, WOULD IT BE ALL RIGHT IF I BRIEFLY BREEZE THROUGH SOME OF THE INTRO SLIDES? WOULD IT BE OKAY IF I BRIEFLY, BRIEFLY, YEAH, GO THROUGH IT. OKAY. I'LL BE QUICK THOUGH. YEAH, BECAUSE I, I, I DO THINK SOME OF THIS HAS BEEN CO COVERED. SO, UH, THANK YOU FOR THE OPPORTUNITY TO BE HERE. UM, MY NAME'S RYAN QUINT, I'M THE FOUNDER AND CEO OF ELEVATE ENERGY CONSULTING. UH, PRIOR TO THIS WAS THE, UH, DIRECTOR OF ENGINEERING AND SECURITY INTEGRATION AT, AT NERC AND, UH, LED ALL OF NERS INVERTER BASE RESOURCE EVENT ANALYSIS EFFORTS, UH, THE DISTURBANCE MONITORING, UH, THE DISTURBANCE REPORTS, UM, THE GUIDELINES, THE ALERTS, UH, THOSE ARE ALL PUBLISHED BY MYSELF AND OR MY TEAM. AND I HAD THE GREAT PLEASURE OF WORKING WITH, UH, ERCOT STAFF ON THIS, SO I'LL JUMP RIGHT TO IT, I GUESS. UM, I WANTED TO PROVIDE A LITTLE BIT OF BACKGROUND BECAUSE I THINK THAT BACKGROUND IS IMPORTANT AND I THINK SOME OF THE CONCEPTS, UH, OFTEN GET OVERLOOKED WHEN WE START GETTING INTO THE MEAT OF SOME OF THE, THE, THE DISCUSSION. SO WHAT I WANTED TO DO HERE WAS TRY TO LEVEL SET, IF YOU WILL, RIGHT, AND, AND SHARE SOME OF MY UNIQUE PERSPECTIVES. UM, I'M, I'M WORKING WITH THE JOINT COMMENTERS AND SUPPORTING CLEARWAY, BUT PROVIDED INDEPENDENT COMMENTS, UH, ON THIS NOER. UH, I WANTED TO MAKE SURE THAT SOME OF THE, THE TOPICS, UH, THE, THE UNDERLYING FUNDAMENTALS ARE ADDRESSED AS WE'RE LOOKING TO MAKE CHANGE, UH, SOME OF THESE REGULATIONS. SO WHAT I WANT TO COVER ARE THE THINGS THAT ARE ON THE LEFT. AND WHAT I DON'T WANNA COVER ARE THE THINGS THAT ARE ON THE RIGHT. SO, FUNDAMENTALS, EDUCATION, BACKGROUND, UM, HOPEFULLY STUFF THAT HASN'T BEEN COVERED OR AT LEAST COVERED IN A DIFFERENT WAY. WHAT I'M NOT LOOKING TO DO IS GET INTO THE HISTORICAL BACK AND FORTH OF NOGA 2 45 OR ECONOMICS OR, UH, ADVOCATING FOR EXEMPTIONS. SO I WANNA HIGHLIGHT, WE'VE LAID ALL THE CURVES. SO WE START TALKING ABOUT ALL THE CURVES, RIGHT? THE CURVES ARE SCATTERED THROUGHOUT THE VARIOUS DOCUMENTS THAT WE'VE SEEN, [03:50:01] BUT THE, THE, THE KEY POINTS I WANNA MAKE ARE A COUPLE THINGS, RIGHT? SO NO 2 45 FROM A FREQUENCY PERSPECTIVE MOVES IT FROM A RELAY SETTING STANDARD TO A COMPREHENSIVE PERFORMANCE BASED STANDARD, RIGHT? WHICH IS A JUMP, RIGHT? IT'S NO LONGER SET YOUR RELAYS AT THESE LEVELS. IT'S RIDE THROUGH ALL EVENTS FROM A FREQUENCY PERSPECTIVE, LET'S FORGET NERC PRC 29. THAT'S COME UP IN A NUMBER OF DISCUSSIONS. THAT'S IN A VERY EARLY STAGE BALLOT AND IT'S RECEIVING EXTREMELY POOR BALLOTING. UM, AND YOU CAN SORT OF SEE THE REASONS WHY, BECAUSE IF WE ADOPT IEE 2,800, NO ONE'S GONNA BE CONFORMING TO THE NERC STANDARD, WHICH DOESN'T SEEM LOGICAL. SO THERE'S A LONG WAYS TO GO THERE. SO I WOULDN'T GET TOO HUNG UP ON THAT. AND I WANNA HIGHLIGHT ONE, I THINK AN IMPORTANT POINT OF ALL THE FREQUENCY RELATED TRIPPING WE'VE SEEN, IT'S ALL INSTANTANEOUS FREQUENCY TRIPPING, WHICH MEANS IT'S NOT REALLY FOCUSED ON FREQUENCY. NONE OF THE CURVE MATTERS IN ANY WAY, SHAPE OR FORM IN ANY OF THE NERC EVENTS WE'VE EVER SEEN. IT'S THE INSTANTANEOUS FREQUENCY CALCULATION, WHICH INVERTERS HAVE USED HISTORICALLY AND PROTECTIVE. UH, FEEDER PROTECTION WAS ALSO CAUGHT USING WHERE IT'S SET WITH A ZERO MILLISECOND TIME DELAY AND THAT ULTIMATELY TRIPS THE INVERTERS. AND SO I JUST, THE CURVES ARE VALUABLE, THEY'RE IMPORTANT, UM, THEY'RE GOOD TO CONSIDER, BUT WHAT'S CAUSED ACTUAL TRIPPING IN THE PAST IS NOT THE CURVES SIMILAR CONCEPT WITH VOLTAGE RIDE THROUGH. THERE'S DIFFERING OPINIONS ON WHAT THE CURRENT NO OPERATING GUIDE VOLTAGE REQUIREMENTS ARE. I WOULD SAY THEY'RE CONFUSING AT BEST. SOME IS RELAY SETTING, SOME SEEMS PERFORMANCE BASED. HOW THEY LINK TOGETHER IS, IS A, A TECHNICALLY A LITTLE CHALLENGING REGARDLESS, THE CURRENT TAG APPROVED NOER 2 45 ELIMINATES THAT CONFUSION AND MOVES IT TO A COMPREHENSIVE PERFORMANCE-BASED VOLTAGE REQUIREMENT. AND AGAIN, THE VOLTAGE TRIPPING TO DATE, WE'VE SEEN INSTANTANEOUS VOLTAGE AC OVERVOLTAGE CONDITIONS AND AN AC UNDERVOLT CONDITION FOR A NON VOLTAGE ELECTRIC SYSTEM, UH, RESOURCE. SO AGAIN, BOTH ESSENTIALLY UNRELATED TO AT LEAST THE PRC CURVES AT NERC. UM, BUT I WOULD SAY OVERALL THE NERC OR THE, THE RIDE THROUGH CURVES. SO WHAT'S IN THE CURRENT VERSION THAT IS ADDRESSING ALL OF THAT CAUSE OF TRIPPING THAT WE'VE SEEN TO DATE THERE ON THE RIGHT IS EVERY CAUSE OF TRIPPING IN THE NERC REPORTS AND COMBINED ALL OF THEM TOGETHER, THE CURRENT NO RT PROOF NOER ADDRESSES EVERYTHING WITH A GREEN CHECK MARK NEXT TO IT WITH SOME LANGUAGE. AND IT'S NOT THE CURVES, IT'S ALL OF THOSE CLAUSES THEREAFTER, CLAUSE THREE THROUGH CLAUSE EIGHT OR WHATEVER IN THE FREQUENCY AND THE VOLTAGE, RIGHT THROUGH SECTIONS THAT ADDRESS ALL THOSE OTHER ISSUES. THE DC SIDE PROBLEMS PHASE, JUMP, SLOW, ACTIVE POWER RECOVERY, UM, AC OVER AND CURRENT TRIPPING, ET CETERA. THE LANGUAGE IS IN THERE THAT SAYS ALL OF THAT STUFF ON THE RIGHT IS IS NOT ALLOWED, RIGHT? I PUT TWO YELLOW QUESTION MARKS NEXT TO TWO OF THE ISSUES WE'VE SEEN SUB SYNCHRONOUS OSCILLATIONS, THAT WAS A WIND PLANT. THE OEM WAS A LITTLE UNSURE AT THE TIME OF PUBLICATION WHAT THAT, WHAT WAS CAUSING THAT THEY WERE WORKING ON IT. AND THEN PITCH CONTROLLERS FOR THE, UH, AUXILIARY EQUIPMENT. AGAIN, THE OEMS WERE, IT WAS A WORK IN PROGRESS. ONE THING I DID WANNA HIGHLIGHT AGAIN, BECAUSE PRC 29 COMES UP REGULARLY IS THAT PRC 29 ALLOWS FOR EXEMPTIONS, PARTICULARLY FOR VOLTAGE RIDE THROUGH. AGAIN, IT'S RECEIVING RELATIVELY LOW BALLOT AND THERE'S CONFUSION OF WHY FREQUENCY RIDE THROUGH WASN'T INCLUDED, UM, FOR, FOR LEGACY EQUIPMENT. UM, BUT WHEN YOU LOOK AT THE STANDARD, AT LEAST AS DRAFTED, THERE'S, THERE'S NO NEGOTIATION OF EXEMPTIONS. IT'S JUST THE GENERATOR OWNER DOCUMENTS AND COMMUNICATES THOSE EXEMPTIONS. THIS IS A PARTICULARLY APPLICABLE FOR LEGACY RESOURCES THAT EXIST OUT THERE TODAY. SO I'M GONNA COME BACK TO EACH OF THOSE POINTS BECAUSE I THINK THEY'RE RELEVANT TO THE COMMENTS THAT WE PROVIDED. SO CAN WE PAUSE YOU FOR A SECOND? STEVEN, DO YOU WANNA ASK YOUR QUESTION? I, I HAVE A COUPLE OF COMMENTS AND A QUESTION IF WE CAN GO BACK JUST A FEW SLIDES. AND THIS IS JUST IMPORTANT AS YOU GO THROUGH THE DISCUSSION. I'LL BE BRIEF IF YOU GO BACK TO THE FREQUENCY RIDE THROUGH. SO REAL QUICK, UM, SO THAT EVERYBODY UNDERSTANDS, ERCOT HAS STATED, WE PROVIDED ALL THE REFERENCES THAT THE CURRENT REQUIREMENTS AND THE NOAL OPERATING GUIDES ARE NOT, UH, SETTINGS BASED. THEY ARE PERFORMANCE BASED TODAY. AND THAT'S ERCOT, YOU KNOW, THAT'S HOW THINGS HAVE BEEN ENFORCED UP TO THIS POINT IS EVEN WITH THE ODESSA EVENT. SO WE WANT TO BE VERY CLEAR, WE'RE NOT MOVING TO A PERFORMANCE BASED REQUIREMENTS. WE'RE JUST, UH, CLARIFYING THESE ARE THE THINGS THAT YOU NEED TO DO TO COORDINATE, TO MEET THE PERFORMANCE REQUIREMENTS. THAT'S BOTH FOR FREQUENCY AND VOLTAGE. IF YOU CAN GO TO THE NEXT SLIDE REAL QUICK, PLEASE, RYAN. UM, AT SOME POINT, IF YOU CAN EXPLAIN THE SECOND BULLET, WE'D, WE'D JUST LIKE TO UNDERSTAND [03:55:01] THAT STATEMENT BECAUSE WE TRY TO ALIGN VERY CLOSELY WITH IEE 2,800 ON THE PREFERRED REQUIREMENT. SO IF YOU COULD ELABORATE ON THAT WHEN IT'S APPROPRIATE, WE'D APPRECIATE IT ON THE EXCEEDS PART. YEAH, YEAH, YEAH. I THINK IT'S THAT PORTION OF THE CURVE THAT YOU ADDED, WHICH GOES BEYOND I 2,800. I PUT THAT IN A GREEN , WHICH, WHICH PORTION IS THAT? UH, IT'S NOT ON THIS GRAPH, IT'S IN HERE, RIGHT? IT'S THAT BOTTOM PORTION, RIGHT? AND I 2,800 DOESN'T HAVE THAT. SO THE, YOU GUYS DO THE RAMP, THE TECH VERSION THAT GOT APPROVED DOES NOT HAVE THAT ERCOT HAS PROPOSED THAT WE INCLUDED. OH, YES. AND, AND UP AT THE TOP, THERE'S SOME DIFFERENCES ON THE HVRT FROM IEE 2,800, WHAT I UNDERSTAND. YES, WE CAN GO THROUGH IT LIKE, YEAH, BECAUSE IT WAS INTENDED TO BE A POSITIVE, BUT I, I DON'T THINK THERE'S A LOT OF CON CONCERN WITH THE CURVES, FRANKLY. OKAY. CONCEPTUALLY, WE WANNA ALIGN. AND SO IF WE ARE, IF WE ARE OFF, WE'D LIKE TO UNDERSTAND. I'M NOT GONNA SPEAK FOR THE JOINT CONFERENCES AT ALL, BUT I THINK CONCEPTUALLY THE CURVE SHAPES, PARTICULARLY FOR THE PREFERRED, EVERYONE'S IN GENERAL AGREEMENT ON NOW, THERE IS THAT CARVE OUT. UM, BUT I THINK IT'S, IT'S ALL VERY POSITIVE. OKAY. THANK YOU. THOSE ARE THE QUESTIONS I HAVE FOR RIGHT NOW. I APPRECIATE IT. YEAH, THANKS STEVEN. YEAH, MY GOAL IS NOT TO SORT OF ARGUE ONE WAY OR THE OTHER, I'M JUST SHARING SOME PERSPECTIVES. HOPEFULLY THEY, THEY'RE THOUGHT PROVOKING AND LEAD TO USEFUL CONVERSATION. I APPRECIATE THE CLARIFICATIONS. UM, YOU KNOW, I, I'VE READ THESE NOT ALL OPERATING GUYS AND NO GOODS, ET CETERA. UM, I, I DEFINITELY DON'T READ IT THAT WAY. SO I'M NOT A LAWYER, I'M NOT GONNA ARGUE WHETHER ONE WAY OR THE OTHER, BUT I, I DON'T READ THE CURRENT FREQUENCY WRITE THROUGH, ESPECIALLY AS A COMPREHENSIVE WRITE THROUGH. IT'S FOCUSED SPECIFICALLY ON RELAY SETTINGS. SO I'M GONNA GO THROUGH MY COMMENTS REALLY, REALLY QUICKLY. UM, HEY, LET, LET'S GO TO ERIC GOFF REALLY QUICK. SORRY RYAN. SO JUST ON THE TOPIC OF THE REQUIREMENTS OF THE EXISTING GUIDES, I THINK THE JCS AND ERCOT HAVE SOME DISAGREEMENT ON THERE. SO SINCE YOU NOTED THAT, I JUST WANTED TO KIND OF EXPLAIN THAT A LITTLE BIT. I DON'T KNOW THAT WE NEED TO LITIGATE THAT. UM, BUT, UM, THERE IS LANGUAGE IN THE OPERATING GUIDES THAT WAS ADDED IN COMMENTS ORIGINALLY FROM OGRE 2 0 8, UM, IN COMMENTS BY THE WIND COALITION, WHICH IS NOW THE ADVANCED POWER ALLIANCE THAT WAS SPECIFICALLY NOTED TO MAKE THESE SETTINGS BASED REQUIREMENTS. AND THAT LANGUAGE CONTINUES TO EXIST IN THE OPERATING GUIDES TODAY. SO WHILE THERE IS LANGUAGE THAT TALKS ABOUT, YOU KNOW, A VARIETY OF WAYS TO MEASURE PERFORMANCE, THAT ORIGINAL INTENT FROM OGO 2 0 8 CONTINUES TO BE IN THE OPERATING GUIDES. AND I THINK IT'S JUST IMPORTANT TO NOTE. YEAH, I THINK JUST TO SUMMARIZE TO YOUR POINT, IT THAT WHAT'S STATED THERE IS NOT A FACT WHAT'S UP ON THE SLIDE? THERE'S A DISAGREEMENT, UH, BETWEEN ERCOT AND THE JOINT COMMENTER'S VIEW OF THE CURRENT REQUIREMENTS, IF THAT'S ACCURATE. OKAY, SO WE SUB, WE SUBMITTED SEVEN COMMENTS, AND I WAS GONNA RUN THROUGH THEM HERE REALLY QUICKLY. THE FIRST ONE IS TO RECOGNIZE THAT ERCOT HAS, IN MY OPINION, BY FAR, THE BEST EVENT ANALYSIS PROGRAM, UH, OF THE ISOS. UM, NOT THAT THE OTHERS ARE DOING POORLY, BUT, UM, IT'S BEEN VERY IMPRESSIVE TO SEE THE EXTENT OF UNCOVERING THE TECHNICAL, UH, DETAILS ASSOCIATED WITH THESE EVENTS. SO NERC TEXAS RE SHOWS UP, WE DO THE EVENT ANALYSIS. ERCOT, UH, TAKES LEAD ON THAT, TYPICALLY, UM, THAT'S NOT THE SAME FOR OTHER ISO RTOS. UM, AND THEY HAVE THAT SORT OF FEEDBACK LOOP, WHICH IS REALLY VALUABLE TO SAY, WE'RE GOING TO TRY TO CORRECT THESE ISSUES AND MINIMIZE THESE RISKS GOING FORWARD. SO I KNOW IN THE LAST WORKSHOP, I THINK THERE WAS SOME DISCUSSION AT LEAST AROUND COMPARISONS OF THIS WITH CALIFORNIA. I DON'T THINK THAT'S FAIR. THERE'S A LOT OF LEGACY EQUIPMENT IN CALIFORNIA AND THEY'VE CHOSEN TO DO VERY LITTLE TO ADDRESS SOME OF THOSE LEGACY EQUIPMENT RISKS, WHEREAS, UH, HERE IN TEXAS, THEY'RE BEING ADDRESSED PRETTY PROACTIVELY. SO KUDOS, UH, THAT PIE CHART THAT'S BEEN CHAIRED IN THE PAST. UH, MUSLIM ANALYSIS WE DID, UH, LOOKING AT AGAIN THERE, THE CAUSES OF TRIPPING THERE ON THE RIGHT SPECIFICALLY FOR, UM, THE ERCOT EVENTS AND LOOKING AT HOW MUCH OF THIS IS SOFTWARE FIXABLE, RIGHT? AND SO THESE NUMBERS ARE BASED ON A CURSORY REVIEW OF THE REPORTS AND WHAT WAS PUBLICLY AVAILABLE AT THE TIME. AND SO YOU SEE A SLIVER OF, OF THE RESOURCES THAT HAD A PERFORMANCE ISSUE WERE NOT ANALYZED. THE GRAY A SLIVER SAID, WE CAN'T HELP YOU, WE DON'T HAVE ANY DATA, WE DON'T KNOW WHAT HAPPENED. THAT'S NOT GOOD. EVERYONE AGREES WITH THAT. THE FIXED TBD WAS THAT THE OEMS WERE STILL WORKING ON DEVELOPING THEIR SOLUTIONS. SO THOSE ARE THE THINGS LIKE THE SSO, UH, CHALLENGE, ET CETERA. AND IN MOST CASES, WE NOW KNOW THAT THERE'S A SOFTWARE FIRMWARE UPGRADE THAT FIXES THE MAJORITY OF THESE ISSUES. [04:00:01] THE DC UH, THE DC SIDE ISSUES, THE AC OVER CURRENT ISSUES, THE PLO LOSS OF SYNC PHASE JUMP ISSUES, PROTECTIVE RELAYS THAT WERE SET WRONG OR MISCONFIGURED, UH, INVERTERS, ET CETERA. AND NOW THAT NUMBER, THAT 85% HAS BEEN USED IN DIFFERENT WAYS, BUT WHAT IT'S REALLY REFERRING TO IS THAT'S 85% OF THE AFFECTED CAPACITY FROM THE PASS AND NERC ANALYZED EVENTS CAN BE FIXED. THAT NUMBER REALLY IS NOT INTENDED TO BE USED OR EXTRAPOLATED OUTWARD. SO WHAT DOES THAT LEAVE US WITH? EVERYTHING IN THE GREEN IN TERMS OF, UH, UH, CAUSES OF TRIPPING GOES AWAY. AND SO WE GET THE REMAINING CURVES THERE OR THE REMAINING PLOTS THERE ON THE RIGHT. AND SO WHAT DO WE HAVE? WE HAVE A RESIDUAL RISK OF SOMETHING ON THE ORDER OF A HUNDRED MEGAWATTS OR SO. AND SO WHEN WE HEAR, YOU KNOW, WIDESPREAD CASCADING ON ITS OWN, I DON'T, I DON'T SEE THAT AS A RISK. I DO SEE THAT AS ONE CONTRIBUTING FACTOR THAT SHOULD BE MINIMIZED TO THE EXTENT POSSIBLE FROM A RELIABILITY PERSPECTIVE. SO, UM, AGAIN, THOSE NUMBERS COULD BE LOWER. I PROVIDED A CONSERVATIVE AND AN OPTIMISTIC ONLY BECAUSE MULTIPLE OF THOSE CAUSES OF REDUCTION WERE, UH, STILL A WORK IN PROGRESS. STEVEN, ON THIS TOPIC, I'LL JUST FINISH THIS SLIDE BEFORE I GO ONTO THE NEXT COMMENT CAN, OKAY, WE'RE NOT GONNA FINISH IN 30 MINUTES IF , IF WE KEEP DOING THIS SOFTWARE. FIX IS MOSTLY DEPLOYED AT ALL APPLICABLE, EXISTING IBR FACILITIES. I THINK THAT'S AN IMPORTANT POINT. THIS IS, THIS IS ALL TIED UP INTO THE SAME COMMENT, SO I WANNA MAKE SURE TO COVER THIS COMPREHENSIVELY. AND I, AGAIN, IT GOES BACK TO ERCOT EVENT ANALYSIS OF THE EXISTING FACILITIES HAVE DEPLOYED, SO DEPLOYED OR IN THE PROCESS OF DEPLOYING SOFTWARE UPDATES, I WON'T SAY THAT COMPREHENSIVELY, BUT THE MA VAST MAJORITY. AND THAT NEW EQUIPMENT ALSO HAS THAT SOFTWARE UPDATE DEPLOYED. SO WHEN I'M BUYING A TEAM, MY CONVERTER OR POWER ELECTRONICS INVERTER OFF THE SHELF, IT'S GOING TO HAVE THESE SOLUTIONS IMPLEMENTED. AND SO WHEN YOU LOOK AT THE COMMENTARY ON BOTH SIDES, YOU SEE A VERY POSITIVE MESSAGE THAT WE'VE DRAMATICALLY MINIMIZED THE RISK WITH IMPLEMENTING SOFTWARE UPDATES. STEVEN, GO AHEAD. YEAH, AND RYAN, WE, WE CAN, IF YOU PREFER TO WAIT A COUPLE SLIDES TO TAKE COMMENTS, BUT I, I, YOU KNOW, THE PURPOSE OF THESE MEETINGS IS TO TAKE QUESTIONS AND COMMENTS. WE WON'T MINUTES, IT'LL GO MORE THAN 30 MINUTES, LOCK IT OFF HARD. THAT'S ALL UNDERSTOOD. BUT AS I EXPLAINED TO YOU IN EMAIL, WE, WE DON'T CUT IT OFF AT A HARD TIME BECAUSE WE ANTICIPATE QUESTIONS AND COMMENTS FROM FOLKS AND TRY TO ACCOMMODATE THAT IN THE DISCUSSION. I, ONCE AGAIN, THE GOAL HERE IS TO INFORM TAC MEMBERS TO MAKE SURE THAT WE GET A COMPREHENSIVE PICTURE. AND SO WHEN YOU MAKE STATEMENTS ABOUT THE RESIDUAL RISK, IT'S REALLY IMPORTANT FOR EVERYBODY TO UNDERSTAND THAT YOUR GRAPHS AND YOUR INFORMATION FOCUSES ON A SUBSET OF THE EVENTS THAT HAVE HAPPENED AT ERCOT, THAT NERC WAS INVOLVED WITH. AND, AND THOSE WERE, THOSE WERE THE MORE MAJOR EVENTS. AND, AND YOUR POINT IS WELL TAKEN THAT SOFTWARE HA FIXES ARE A GREAT IMPROVEMENT TO IT. BUT WE ALL HAVE TO REMEMBER THAT WHERE THE FAULT IS MATTERS AND THE FIXES THAT WERE DEPLOYED SO FAR, WERE ONLY ON THOSE UNITS THAT WERE AFFECTED FROM THAT EVENT. A FAULT IN A DIFFERENT PART OF THE STATE WILL AFFECT A DIFFERENT SET OF UNITS. AND SO IT'S, IT'S NOT CORRECT IN ERCOT OPINION TO SAY THAT THAT IS THE RESIDUAL RISK. WHEN THERE ARE SYSTEMIC ISSUES THAT EXIST, SOFTWARE WILL DEFINITELY HELP. BUT WE NEED TO UNDERSTAND THAT THIS IS ALL ACROSS ERCOT, ALL OF THE INVERTERS, INCLUDING WIND GENERATION RESOURCES THAT WERE NOT PRIMARILY AFFECTED WITH THE ODESSA EVENT AND THE ISSUES THAT YOU RAISED THAT HAVE HAD SYSTEMIC ISSUES OVER THE YEARS. SO JUST WANT TO MAKE SURE EVERYBODY KIND OF UNDERSTANDS, UH, THAT COMPREHENSIVE. SO THE SOFTWARE UPDATES WERE ONLY DEPLOYED AT THE AFFECTED FACILITIES. THEY WERE DEPLOYED AT THE EFFECTIVE FACILITIES. AND IF WE KNEW THAT, UH, CERTAIN ELEMENTS WERE OF A PARTICULAR MODEL, WE ISSUED A MARKET NOTICE FOR A SUBSET OF THOSE ISSUES TO BE DEPLOYED ON ADDITIONAL UNITS. BUT WE CAN, LIKE T MIC FOR EXAMPLE, AND I'LL BRING THEM UP, YOU'RE VERY FAMILIAR WITH THEM. UH, T MIKE HAS OPENLY STATED THAT IF I TAKE OFF ANTI ISLANDING, FOR EXAMPLE, THE NEXT, WHAT'S THE NEXT THING THAT'S GONNA GET? SO CONTROLS AND, AND OTHER SOFTWARE HAVE TO ALL BE COORDINATED EVEN WHEN YOU TAKE OFF CERTAIN PROTECTIONS. AND THAT'S PART OF THE BIGGER PICTURE THAT I WANT TO MAKE SURE EVERYBODY UNDERSTANDS. YEAH, THAT'S A GOOD COMMENT STATEMENT. AND I THINK THAT'S [04:05:02] GOING BACK TO THIS SLIDE, WHY MANY OF THOSE PARAGRAPHS ARE ACTUALLY CRITICALLY IMPORTANT, RIGHT? WHEN TEAM, WHEN TEAM, I TRIPPED ON PLL LOSS OF SINK, RIGHT? NOT TO PUT 'EM ON THE SPOT, BUT THEY'VE BEEN IN ENOUGH EVENTS, WE CAN TALK ABOUT 'EM, RIGHT? WE TOLD THEM FLAT OUT, YOU'RE GONNA TRIP ON THE NEXT THING, THE NEXT LAYER OF THE ONION, RIGHT? WE, WE TOLD THEM THAT AHEAD OF TIME OR CAUGHT TEXAS ALREADY, AND NER NERC ALL TOLD THEM THAT, RIGHT? WHAT HAPPENED THEN ODESSA NUMBER TWO EVENT HAPPENED AND THEY TRIPPED ON SOMETHING ELSE, RIGHT? THESE CLAUSES ELIMINATE THAT FROM BEING ALLOWABLE, PARTICULARLY CLAUSE NUMBER THREE IN THE FRT AND THE VRT. I THINK IT'S THE MOST VALUABLE CLAUSE, WHICH I'LL COME TO LATER IN THE COMMENTS. UM, SO AGAIN, I KNOW THESE, THESE CARDS. DO YOU WANNA TAKE A COMMENT FROM DAVE RI OR DO YOU WANNA WAIT UNTIL A CERTAIN SLIDE? UH, NO, THAT'S, I'M, I'M DONE WITH NUMBER TWO. OKAY, GO AHEAD DAVE. OKAY, THANKS. CAN YOU HEAR ME OKAY? YES. YEP. THIS IS DAVE RI WITH ENERGY. UM, I JUST WANTED TO RESPOND AND MAYBE CLARIFY, UM, TO MAKE SURE THAT I UNDERSTOOD ERCOT COMMENT HERE. I MEAN, I THINK THERE'S TWO THINGS, RIGHT? THE DEPLOYED SOLUTIONS IN THIS TABLE FROM THE ODESSA EVENTS, WHICH IS DERIVED FROM ERCOT PRESENTATION ON THE TOPIC, I THINK PRETTY CLEARLY INDICATES THAT THERE'S, YOU KNOW, UP MODIFICATIONS THAT ARE BEING MADE TO EQUIPMENT OUTSIDE OF JUST THOSE PROJECTS THAT WERE AFFECTED DIRECTLY BY ODESSA, RIGHT? IT'S ALSO SIMILAR EQUIPMENT. SO I JUST WANNA CLARIFY THAT. AND I'D SAY THE OTHER, THE OTHER ELEMENT WHICH I THINK MAYBE IS NOT INTENDED TO BE IMPLIED THIS WAY, BUT SOUNDED THIS WAY, AND I WANTED TO MAKE SURE THAT THAT WE CLARIFIED IT, IS THAT I DON'T THINK IT'S ERCOT CONTENTION, AND I CAN TELL ME IF I'M INCORRECT, THAT ALL 70 GIGAWATTS OF IBR IN, UH, ERCOT HAVE, UH, HAD A FAILURE AND THAT SOMEHOW THESE FOUR N REPORTS ARE NOT AT LEAST REASONABLY REPRESENTATIVE OF, UM, THE TYPES OF IMPROVEMENTS THAT WE MIGHT EXPECT TO SEE. SO IF THEY SEE THAT DIFFERENTLY, I GUESS WE'D WANT TO GET THAT KIND OF CLEARLY DEFINED, BUT IT, IT JUST OUT OF NECESSITY, RIGHT? THERE'S A SUBSET OF IBR THAT HAVE EXPERIENCED PERFORMANCE FAILURES THAT ERCOT HAS SUMMARIZED OF THOSE, THE MOST MAJOR FAILURES HAD ERCOT OR HAD NERC REPORTS. AND, AND THIS IS A SUMMARY OF THOSE REPORTS. AND SO THIS IS, I MEAN, WE ARE TRYING TO PROVIDE EVIDENCE WITH THE DATA THAT'S AVAILABLE. UM, IF THERE IS OTHER EVIDENCE WITH OTHER DATA THAT POINTS IN A DIFFERENT DIRECTION, WE'RE HAPPY TO SEE IT, BUT WE HAVEN'T. YEAH. AND THAT, THAT GOES TO THE, TO THIS SLIDE, AND THIS IS AGAIN, CONTENTIOUS. I'M HAPPY TO TAKE COMMENTS ON IT. UM, I'M NOT, NOT REALLY INTENDING TO BE CONTENTIOUS, BUT YOU KNOW, I I I'VE SEEN THE DISCUSSION AROUND, WELL, THIS IS OUR FUTURE IF WE DO NOTHING, RIGHT? BUT I DON'T THINK THERE'S A DO NOTHING OPTION BECAUSE WE HAVE A PRETTY SOLID NOER ON THE TABLE AS IS AND MAYBE EVEN SOME FURTHER REFINEMENT. SO I DO SEE A DOWNWARD TRAJECTORY TO AT LEAST THE NUMBER OF EVENTS, BUT WE ALSO HAVE TO RECOGNIZE THE, THE IBR PENETRATION IS INCREASING, YOU KNOW, EXPONENTIALLY AT THIS POINT. SO THE NUMBER OF EVENTS IS LIKELY TO INCREASE JUST FROM THAT FACT ALONE, RIGHT? SO IT COMES DOWN TO THE MAGNITUDE, THE SIZE OF THE EVENTS, ALL OF THAT TAKEN INTO CONSIDERATION. UM, AND FORECASTING THE NUMBER OF EVENTS OUT 10 PLUS YEARS FROM NOW IS, YOU KNOW, I, I DON'T KNOW ABOUT THAT, BUT YES, IF YOU COULD GO THE PREVIOUS SLIDE JUST BRIEFLY, UH, I'M, I'M A LITTLE CONFUSED LOOKING AT THIS CHART BECAUSE WE ARE DOING SOME THINGS NOW, WE'VE COME TO SOME CONSENSUS. YOU'VE SAID THE SOFTWARE FIX IS PRETTY GOOD. UM, WHY SUCH A SHARP INCREASE IF WE DO NOTHING VERSUS THE DOWNWARD TRAJECTORY? IF THE NEW EQUIPMENT IS MEETING A HIGHER STANDARD AND EVERYONE'S MEETING THE SOFTWARE REQUIREMENTS, AND ASSUMING THAT WE'LL EVENTUALLY AGREE THAT WE SHOULD HAVE THE SETTINGS, THE MAXIMUM, WHATEVER'S EXISTING AT A MINIMUM, WHY ARE YOU SEEING SUCH AN INCREASE? TO CLARIFY? THAT'S A GOOD QUESTION, UH, ERIC, TO CLARIFY THAT, THAT'S A, UM, THAT'S THE ERCOT GRAPHIC, AND I FRANKLY DON'T AGREE WITH THE GRAPHIC. I THINK WE ARE ON A DOWNWARD TRAJECTORY. UM, AND I THINK THE, YOU KNOW, I PUT ON A SIDE THERE, I THINK THE TAC APPROVED VERSION OF NOCA 2 45 SENDS US ON A DOWNWARD TRAJECTORY. UH, YOU KNOW, I THINK THAT THE POINT AT THE, ON THE LAST SLIDE HERE IS THAT IT DOES FORCE MAXIMIZING WITH THE CURRENT DRAFT, WHICH WOULD ELIMINATE NEARLY EVERY CAUSE OF TRIPPING. WE'VE SEEN, UM, MAYBE NOT SOME NUANCED, UH, PHYSICAL MODIFICATIONS, BUT WITH A VAST MAJORITY OF THESE ISSUES GO AWAY WITH SOFTWARE RELATED FIXES AND MAXIMIZATION. I, I PERSONALLY BELIEVE, I KNOW THAT CAN BE A CONTENTIOUS TOPIC [04:10:01] THERE, BUT I DO THINK WE'RE ON A DOWNWARD TRAJECTORY. IF YOU WERE TO TAKE THAT SAME GRAPH THERE AND DO A CURVE FIT BETWEEN 2019 TO 2023, DO AN EXPONENTIAL AND IT'S GONNA LOOK LIKE IT'S GOING UP TO THE ROOF, DO A LINEAR, AND YOU'RE GONNA GET A PRETTY FLAT LINE. SO IT'S, TO ME, THIS IS A CURB FITTING EXERCISE HERE ON PROJECTING OUT 10 PLUS YEARS WORTH OF RISK WITH JUST BASED NUMBER OF EVENTS, NOT SIZE OF EVENTS, NOT CAUSE OF EVENT, NOT WHAT HAS BEEN MITIGATED OR WHAT COULD BE MITIGATED. WE'RE MISSING A LOT OF FACTORS HERE THAT NEED TO BE EXPLAINED COMPREHENSIVELY. I I HAD A, UH, JUST A QUESTION ON THE CURVE I, I SEE ON THE Y AXIS NUMBER OF EVENTS, BUT THEN AS I'M LOOKING AT THE DOWNWARD TRAJECTORY, I SEE IT HAS A TARGET OF BOTH, UH, YOU KNOW, FREQUENCY LESS THAN ONE EVENT PER YEAR AND A TARGET OF LESS THAN 500 MEGAWATTS. UM, IS THAT, IS THE 500 MEGAWATTS, UM, IS THAT CHARACTERIZED IN ANY OF THE, I GUESS WE'D HAVE TO GO BACK AND LOOK AT ALL THE REPORTS, BUT CAN YOU GIVE SOME CONTEXT FOR HOW THE, THE PREVIOUS EVENTS HAVE BEEN RELATIVE TO THAT? AND, UM, AND, AND YEAH, THESE ARE, THESE ARE NOT MY, MY TARGET, SO I'LL BE VERY CLEAR ABOUT THAT. I THINK THE 500 MEGAWATTS IS LINKED TO THE NERC EVENT ANALYSIS AND MAYBE TO SOME ERCOT REQUIREMENTS AS WELL. THE 500 IS THE CATEGORY ONE I EVENT ANALYSIS PROGRAM REQUIREMENT, IF YOU WILL. IT'S A VOLUNTARY PROCESS, BUT ALL THE MAJOR RCS PARTICIPATE, UM, THEY DO AN EVENT, THEY, THEY IDENTIFY AND EXPLAIN TO THE EURO ENTERPRISE WHAT HAS BEEN DONE, AND THEN THE EURO ENTERPRISE DECIDES IF THEY WANNA DO AN EVENT ANALYSIS, A DEEPER EVENT ANALYSIS ON IT. SO THOSE ARE DISTURBANCE REPORTS ARE THE, THE, YES, WE WANT TO DO A, A DEEPER FORENSIC ANALYSIS AND UNCOVER WHAT HAPPENED, AND THEN SHARE THAT BROADLY WITH THE INDUSTRY. FROM MY VANTAGE POINT, THAT'S MAYBE WHERE THE 500 MEGAWATTS COMES FROM. I DON'T HAVE ANY ADDITIONAL CONTEXT ON THE, THE ONE EVENT PER YEAR, PARTICULARLY IF YOU'RE SORT OF CATEGORIZING IT AS, YOU KNOW, AN EVENT IS FIVE MEGAWATTS OF, OF AN EXPECTED TRIPPING. I DON'T SEE HOW IT'S FEASIBLE TO MEET THAT. IT'S JUST IAA 2,800 EVEN SAYS THAT IF YOU, IF 10% OF YOUR APPARENT, I'M GONNA GET TECHNICAL HERE, 10% OF YOUR, OF YOUR APPARENT GREATER THAN 10% OF YOUR, LESS THAN 10% OF YOUR APPARENT CURRENT AFTER AN EVENT, UH, IS STILL THERE, THEN YOU ARE COMPLIANT WITH THE RIDE THROUGH REQUIREMENTS, RIGHT? SO EVEN 2,800 GIVES QUITE A BIT OF LEEWAY AROUND LARGER PLANTS AND PARTIAL TRIPPING AND THINGS LIKE THAT WITHOUT EXPLICITLY STAYING SAYING IT. THOSE, THOSE REQUIREMENTS ARE IN 2,800 FOR THAT REASON. OKAY, THANK YOU STEVEN. AND THEN KEVIN? YEAH, THIS IS STEVEN ALI WITH ERCOT. I THINK I CAN SHED A LITTLE BIT OF LIGHT ON THIS GRAPH, WHICH IS IN OUR PRESENTATION FROM THE WORKSHOP THAT WE DIDN'T GET AN OPPORTUNITY TO GET TO. SO JUST TO GIVE SOME CONTEXT HERE, ONE OF THE THINGS THAT HAS BEEN ASKED, UH, IS WHAT IS OUR TARGET? WHAT ARE WE TRYING TO GET TO WITH NORE 2 45 TO A NEW STEADY STATE? AND SO THIS WAS JUST AN ATTEMPT OF CLEARLY PUTTING SOMETHING OUT THERE AND SAYING, WE THINK WE SHOULD HAVE A RULE SET THAT DRIVES US DOWN TO THIS TARGET. IT'S UNREASONABLE TO THINK WE'RE NEVER EVER GONNA HAVE ANOTHER IBR RIDE THROUGH FAILURE EVENT. IT'S IT THAT THERE'S TOO MUCH HUMAN ERROR AND SYSTEMS ERROR THAT'S GONNA BE OUT THERE, BUT 500 MEGAWATTS, ANYTHING ABOVE THAT, WE HAVE TO ISSUE A REPORT TO NERC. THAT'S PART OF THE NEW RULE. SO WE THINK IT'S A REASONABLE TARGET TO TARGET HAVING ONE EVENT PER YEAR, LESS THAN A HUN LESS THAN 500 MEGAWATTS. SO WHATEVER WE DO WITH NORE 2 45 IS GOING TO TAKE A TRAJECTORY. AND IF WE ALLOW MORE, YOU KNOW, EXEMPTIONS, IT WILL ALTER THE TRAJECTORY. BUT ULTIMATELY WE WANT TAC TO DECIDE, YOU KNOW, WHAT DO WE WANT TO GET TO FOR A NEW STEADY STATE? THE DO NOTHING CONTEMPLATES, NO NOER 2 45, THAT'S THE CURRENT SET OF RULES. SO EVEN THE TAC APPROVED VERSION WILL BE LESS THAN THE DO NOTHING. ERCOT DOES NOT BELIEVE THAT IT WILL REACH THAT TARGET BECAUSE WE HAVE EXEMPTION PROCESSES THAT AREN'T FACTORING INTO RELIABILITY AND THAT THE PERFORMANCE FAILURES CAN ALLOW ADDITIONAL EXEMPTIONS. SO SOME OF THOSE CORE ISSUES THAT WE'RE GONNA TALK ABOUT, WE THINK AREN'T GOING TO ACHIEVE THAT TARGET. SO WE'RE GONNA HAVE TO FIGURE OUT WHAT TARGET WE WANT TO GET TO. UH, LOOKING INTO THE FUTURE, THAT IS A STRAIGHT UP EXCEL EXPONENTIAL CURVE THAT'S APPLIED. AS RYAN'S MENTIONING. THERE'S NO OTHER ANALYTICS BEHIND THAT, BUT IT DOES REFLECT THE FACT, THE FACT, AS I, AS RYAN IS MENTIONING, THAT WE HAVE A LOT OF ADDITIONAL IBR PENETRATION COMING. AND SO YOU EXPECT THE NUMBER [04:15:01] OF EVENTS IF YOU DON'T DO ANYTHING TO CONTINUE TO INCREASE WHETHER LINEAR OR EXPONENTIAL. THAT'S THE POINT. AND WHAT DO WE WANT AS AN INTERCONNECT TO GET TO AS A NEW STEADY STATE MOVING FORWARD WHEN WE ARE IN AN IVR DOMINATED GRID? OKAY, GO AHEAD KEVIN. YEAH, QUICK QUESTION. UM, IF WE ONLY DID THE SOFTWARE UPGRADE, WHAT DO YOU THINK THAT CHART LOOKS LIKE IN TERMS OF, ARE WE SITTING AT ONE TO TWO OR ARE WE AT ONE TO FIVE WHERE YOU, WHERE YOU SAY WE'RE AT FOR NUMBER OF EVENTS, JUST THE SOFTWARE? I THINK IT'S A, IT'S A SPECULATIVE ANSWER, RIGHT? SO I DON'T HAVE A CRYSTAL BALL. I'M NOT GONNA PRETEND TO, UH, BE ABLE TO PREDICT THE FUTURE. UM, I THINK THE, SO I THINK THE SOFTWARE UPDATE'S GONNA VARY LONG WAY. WHEN I LOOK AT ALL THE ODESSA EVENTS, WELL OVER HALF OF THE WIND, YOU KNOW, HALF OF THE MEGAWATT CAPACITY REDUCTION IN THE WIND EVENTS THAT ARE PUBLICLY AVAILABLE IN WHICH WE CAN DO ANALYSIS ON, WE'RE TAKING THE DATA WE HAVE, WE DON'T HAVE AS MUCH ALL THE DATA, RIGHT? SO TAKING THE PUBLIC REPORTS AND ALL THAT STUFF, UH, SOFTWARE FIXES THE VAST MAJORITY OF THOSE. UM, AND I, I HAVE THIS KIND OF POINT ON A LATER SLIDE ONE EVENT, TWO EVENT, I DON'T KNOW, HOPEFULLY NO EVENTS, RIGHT? UM, THE SOFTWARE FIXES FIX THE ODESSA TYPE EVENTS. I THINK THE, THE NUMBER, I THINK WHERE I'M GETTING HUNG UP IS THE NUMBER OF EVENTS IS SORT OF IRRELEVANT, RIGHT? WE HAVE THOUSANDS AND THOUSANDS AND THOUSANDS AND THOUSANDS AND THOUSANDS OF RELAY MISS OPERATIONS EVERY YEAR. HOW MANY BLACKOUTS DO WE HAVE? NOT A LOT, RIGHT? BECAUSE THEY'RE REQUIRED TO GO IN, FIGURE OUT WHAT HAPPENED AND FIX IT, RIGHT? UH, BECAUSE THEY'RE TYPICALLY A SOFTWARE PROBLEM. IT'S A MISCONFIGURED RELAY, IT'S A OVER SETTING, IT'S OVERREACH, RIGHT? SO ALL THESE PROBLEMS THEY GO IN, THEY ADDRESS WITH SOFTWARE FIXES. SO WHILE WE CONTINUE TO HAVE LOTS OF RELAY OPS AND WE OR MISS OPS, AND WE TRY TO MINIMIZE THE AMOUNT OF RELAY MISS OPS, THEY JUST HAPPEN RIGHT NOW, IF THEY HAPPEN AND THEY CAUSE BLACKOUTS, WE'RE GONNA TAKE STRONGER ACTION TO ADDRESS THEM, RIGHT? SO EVEN IF WE DID THE SOFTWARE FIXES REPLACED ALL THE EQUIPMENT, WE'D STILL BE 2016 THROUGH 2018. THAT ONE TO TWO EVENTS WOULD STILL BE SHOWING UP. YOU'RE THINKING 2016 THROUGH 20, THAT I DON'T KNOW, I DON'T HAVE THE DATA BEHIND THIS GRAPHIC. HOW MANY OF THESE ARE GREATER THAN 500 MEGAWATTS AND UNRELATED TO SOFTWARE? OKAY. I THINK GREATER THAN 500 MEGAWATTS AND, AND CAN'T BE FIXED BY SOFTWARE. I WOULD THINK THE ANSWER'S ZERO. I DON'T WANNA SPEAK FOR A COP, BUT I THINK THE ANSWER'S ZERO ACROSS THE BOARD IF WE USE THOSE TWO FACTORS COMBINED. OKAY. SO I WOULD JUST FOR THE RECORD, THE ANSWER WOULD NOT BE ZERO. THERE ARE SOME THAT ARE OVER 500 AND HOW MUCH YOU LOSE DEPENDS ON HOW MUCH WIND IS BLOWING AT THE TIME AND HOW MUCH, WHAT TIME OF THE DAY. SO THE POTENTIAL CAPACITY, UH, COULD BE MORE. AND ALL OF THAT IS REFLECTED IN THE APPENDIX SLIDE THAT WE SHOWED IN THE PRESENTATION FROM THE LAST TECH MEETING THAT WE DIDN'T GET. WE DIDN'T HAVE ENOUGH TIME TO GET TO, BUT IT IS IN THE APPENDIX. THANKS, STEVEN. SO WE, KEVIN, ARE YOU GOOD? I'M GOOD. YEAH. WE HAVE DAVE AND THEN I THINK WE HAVE ERIC AFTER THAT. SO DAVE ON THE PHONE. YES. THANKS DAVE. RE WITHIN ENERGY, I, I HAD A COUPLE OF MORE QUESTIONS FOR ERCOT RELATED TO THIS BECAUSE I THINK IT GETS TO ONE OF THE CORE QUESTIONS HERE, WHICH IS WHY IS MORE NEEDED TO MEET THIS RELIABILITY CONCERN THAT THAT ERCOT HAS? SO, YOU KNOW, THE TARGET OF ONE EVENT PER YEAR AND LESS THAN 500 MEGAWATTS. I GUESS MY QUESTION FOR ERCOT IS HOW DOES THAT RELATE TO THE RELIABILITY RISK THAT ERCOT HAS BEEN TALKING ABOUT IN THESE MEETINGS? SPECIFICALLY THE RISK OF UNDER FREQUENCY LOAD SHED CASCADING EVENTS, OUTAGES? I'M, I'M TRYING TO UNDERSTAND HOW, HOW THIS TARGET RELATES TO THOSE CONCERNS. SO THAT, THAT'S THE FIRST QUESTION. YEAH, I THINK THIS STEVEN SLEE WITH ERCOT IS, RYAN ALLUDED TO PREVIOUSLY, THERE'S AN ONION EFFECT. THERE'S LAYERS. SO EVEN WHEN YOU MAKE CHANGES, THERE'S GOING TO BE OTHER ADDITIONAL ISSUES THAT SHOW UP. AND WE RECOGNIZE THAT. AND SO WE WANT TO TARGET, UH, WHERE WHATEVER WE DISCOVER IS MANAGEABLE AND DOESN'T ENTER INTO THE CASCADING RISK, DOESN'T ENTER INTO THE UNDER FREQUENCY LOAD SHED REALM. AND IT GIVES US ENOUGH TIME TO ACTUALLY ANALYZE AND CORRECT IF WE DON'T DO THAT PROACTIVELY. UM, AND IF OUR MODELS DON'T REFLECT THINGS, WE'RE GONNA HAVE SURPRISES [04:20:01] THAT SHOW UP THAT ULTIMATELY IT MAY BE TOO LATE. AND THAT'S WHAT WE'RE TRYING TO AVOID BY HAVING, UH, ENOUGH REQUIREMENTS BALANCING, YOU KNOW, THE COST AND IMPACT TO THE GENERATORS, BUT MAKING SURE WE HAVE A RELIABILITY ASSESSMENT. AND IF WE CAN DO THAT, WE THINK WE CAN GET TO A POINT, DAVID, THAT, UH, WE'RE ABLE TO HAVE THE EVENT MAGNITUDE BE LOW ENOUGH TO FIX IT BEFORE IT JUST ESCALATES ON. ALL OF THIS IS REMEMBER BEING CHALLENGED BECAUSE YOU HAVE A LOT MORE GENERATION INVERTER BASE RESOURCES COMING IN, INTERCONNECTING, AND THOSE CONTROLS, THEY COMPETE, THEY COORDINATE, THEY HAVE TO COORDINATE WITH EACH OTHER, EVEN PLANT TO PLANT. WE HAVE EXTREME WEATHER THAT'S, THAT'S HITTING OUR REGION. AND ALL OF THESE FACTORS ARE COMPOUNDING EFFECTS THAT WE HAVE TO TAKE INTO CONSIDERATION, UH, TO MAKING SURE WE CAN GET TO A STEADY STATE AND STAY THERE EVEN AS THE AMOUNT OF IBR PENETRATION CONTINUES. OKAY. SO JUST TO FOLLOW UP ON THAT, BEFORE I GO TO MY SECOND QUESTION, WHICH IS DIRECTLY RELATED, I THINK TO THAT RESPONSE, I, I'D LIKE TO JUST UNDERSTAND, I I GUESS THE, THE MORE SPECIFIC QUESTION IS WHY IS IT ONE EVENT AT 500 MEGAWATTS, NOT THREE EVENTS AT 700 MEGAWATTS OR 10 EVENTS AT 250 MEGAWATTS? I, I THINK ERCOT HAS MADE SOME CLAIMS ABOUT THE RELIABILITY RISK THAT, YOU KNOW, WOULD BE CONCERNING RIGHT? TO, TO OBSERVERS. AND I'M TRYING TO UNDERSTAND HOW THIS TARGET RELATES TO THOSE CLAIMS. AND IT SOUNDS LIKE IT'S A LITTLE BIT MORE BY FEEL AND NOT, I'M NOT SURE HOW IT TIED IN IT IS ANALYTICALLY. AND I GUESS IF THAT'S, IF I'M MISSING AN ANALYSIS BEHIND THAT, I'M TRYING TO UNDERSTAND THIS, WHAT THAT IS. WELL, I, IN A PERFECT WORLD, RIGHT, YOU WOULDN'T HAVE ANY EVENTS, BUT WE DON'T THINK THAT THAT'S REALISTIC WITH WHAT WE'VE OBSERVED SO FAR. SO PICKING ONE TAKES INTO ACCOUNT THAT EVERY EVENT WE HAVE IMPACTS A LOT OF RESOURCES. EVERYBODY, THE TRANSMISSION COMPANIES, THE GENERATION COMPANIES, THEY ALL HAVE TO SPEND SIGNIFICANT TIME IN DOING THIS. AND IT COMPROMISES THE, THE SYSTEM BECAUSE YOU MAY HAVE SOMETHING THAT'S 500, BUT IF THE SUN WAS AT THE PEAK AND WIND WAS BLOWING AT THE SAME DAY, IT COULD HAVE BEEN 1500. SO WE GOTTA HAVE A LITTLE BIT OF ROOM SO THAT WE CAN CATCH THOSE THINGS AND FIX THEM. SO IF ONE ISN'T THE RIGHT NUMBER AND TAC WANTS TO SAY, WELL, WE THINK WE SHOULD TAKE ON MORE RISK ONTO THE ERCOT SYSTEM AND WE SHOULD HAVE MORE EVENTS, AND WE ALL UNDERSTAND AND WE ALL ACCEPT THAT, THAT THAT'S THE IMPACT, WELL THEN THAT'S THE DECISION THAT THE TAC MEMBERS CAN MAKE. BUT WE WANT TO SAY, WE THINK ERCO T'S OPINION IS, THAT'S A GOOD TARGET FOR US TO HAVE, BUT WE'LL LISTEN TO TAX FEEDBACK IF YOU WANT TO TAKE ON MORE RISK. ERIC? UM, YES, A COUPLE THINGS. FIRST IS, UM, WE HAVE GENERIC TRANSMISSION CONSTRAINTS ON TRANSMISSION RIGHT NOW BASED ON WEATHER. UM, IF SOME OF THESE EVENTS ARE WEATHER RELATED, WHETHER IT'S THUNDERSTORMS, WHATEVER IT SEEMS THAT IS AN EXPEDIENT IN THE SHORT TERM, OTHER THAN THE THINGS THAT EVERYONE'S AGREED ON, YOU COULD MANAGE SOME OF THE RISK BY SAYING, OKAY, THESE PARTICULAR UNITS HAVE TO HAVE TO BE CURTAILED DOWN FOR THE PERIOD OF TIME THAT THERE'S SOME SOME RISK. AND SECONDLY, I THINK YOU'RE MISCHARACTERIZING RISK IN ANOTHER WAY BECAUSE WITH ALL DUE RESPECT, WE HAVE HAD DURING FREEZES, A LOT OF THINGS GO WRONG, NOT ONLY WITH THE, UM, NATURAL GAS SYSTEM, WHICH WE HAVE WE'RE TRYING TO FIX AND WEATHERIZATION, BUT THERE IS HUMAN ERROR AS WELL INVOLVED. SO EVEN IN THE DISPATCHABLE UNITS THAT WE'VE HAD A CENTURY OF EXPERIENCE, THERE ARE UNEXPECTED ISSUES THAT COME UP AND, YOU KNOW, THERE IS A LI THERE IS AT SOME POINT A TRADE OFF ON THAT. AND SO I THINK, TO BE HONEST, THIS TYPE OF CURVE IS NOT HELPFUL BECAUSE IT, IT SETS A, A TONE THAT DOESN'T REALLY HELP CONVERSATION AS OPPOSED TO SAY, OKAY, IF WE DO THIS, HERE'S THE RISK. WE DO THIS HERE, RISK, BUT THERE IS ALWAYS GONNA BE RISK ON THE GRID FOR ANY TYPE OF RESOURCE BECAUSE OF HUMAN ERROR. AND SO WHEN WE, YOU TALK ABOUT, WELL, WE'RE GONNA BE SO MUCH OVER ADDED RISK, WELL, YOU KNOW, YOU PUT IN THERMAL UNITS, THERE'LL BE OTHER RISKS AS WELL. SO IF WE CAN GET A BETTER SENSE OF THE QUANTIFICATION OF THOSE RISKS AND THE PROBABILITY OF THOSE RISKS, THAT WOULD HELP US [04:25:01] IN OUR DECISION MAKING HERE. SO, UH, I DON'T HAVE ANYTHING ELSE TO ADD. THANK YOU. AND I THINK THE QUANTIFICATION OF RISK, THE QUANTIFICATION OF SOFTWARE RISK IS EASY, RIGHT? WE CAN ELIMINATE IT. WE KNOW WE CAN ELIMINATE THE, THE QUANTIFICATION OF THE PHYSICAL MODIFICATIONS, WHICH ARE STILL SORT OF TBD AND NEBULOUS IS I THINK WHERE WE, WE STRUGGLE TO QUANTIFY, RIGHT? WE, ONE, WE DON'T HAVE AS MUCH AS MUCH PUBLICLY AVAILABLE DATA. THAT'S NOT A BAD THING, IT'S JUST OBJECTIVE FACT ON THOSE EVENTS. WE HAVEN'T TALKED ABOUT THOSE AS MUCH. THEY'RE SMALLER EVENTS, THEY'RE TYPICALLY MORE WIND RELATED EVENTS IN SOME CASES. UM, AND SO THERE'S A LOT MORE DATA THAT WOULD BE NEEDED TO COME UP WITH REALLY HARD FACTS BEHIND IT. THE HARD FACTS ON THE SOFTWARE SIDE ARE PRETTY STRAIGHTFORWARD. LIKE FOR ME PERSONALLY, I FEEL VERY COMFORTABLE TALKING ABOUT THIS. OKAY, CHRIS, SO I HAVE A ONE QUESTION FOR RYAN AND ONE QUESTION FOR STEVEN. SO RYAN, ARE, ARE THERE ANY OTHER MARKETS THAT HAVE A TARGET LIKE THAT OF ONE IN 500 MEGAWATTS ACROSS THE US OR INTERNATIONALLY? I, I DON'T KNOW. I, I, OKAY, I DON'T WANNA SPEAK OUTTA TURN. UM, I THINK WHAT I, YOU KNOW, I GUESS TO ME AS I'M LISTENING TO THE CONVERSATION OF ALL I'M, I'M WONDERING IS A TARGET OR A GOAL, SOMETHING THAT JUSTIFIES SORT OF A MANDATORY REGULATION THAT REQUIRES A SIGNIFICANT AMOUNT OF MONEY TO BE SPENT, RIGHT? WHEN WE, WE REALLY DON'T KNOW, RIGHT? THERE'S A CURVE THAT GOES DOWN, THERE'S A CURVE THAT GOES UP, BOTH ARE MADE UP, RIGHT? ONE'S A, ONE'S A GOAL, ONE'S A TARGET, ONE'S A CURVE FIT EXERCISE, RIGHT? SO WHERE ARE WE IN THERE? WE DON'T KNOW. SO WE REALLY SHOULDN'T BE LOOKING FORWARD INTO THIS MAKE-BELIEVE FUTURE. WE SHOULD BE LOOKING AT WHAT HAS HAPPENED IN THE PAST AND HOW DO WE BUILD THE REQUIREMENTS TO MITIGATE THAT RISK MOVING FORWARD AND THEN CONTINUE TO UPDATE THOSE REQUIREMENTS AS NEW ISSUES EVOLVE. RIGHT. OKAY. SO I SPIN IT BACK. I, MY ANSWER TO YOUR QUESTION, FRANKLY IS, I DON'T KNOW. FAIR ENOUGH. AND THEN FOR STEVEN, I GUESS FOR THE NON IBR RESOURCES, DO WE HAVE A SIMILAR TARGET AND HAS THERE BEEN ANY LOOK AT HOW MUCH, HOW MANY EVENTS HAVE HAPPENED OVER THOSE OVER THE YEARS? SO WITH THE NON IBR UNITS, UH, THERE'S A COUPLE OF DISTINGUISHING FACTORS WITH THEM. SO WHEN WE DO HAVE REPETITIVE TRIPS, WE DO FOLLOW UP WITH THEM ON AN EVENT ANALYSIS PERSPECTIVE AND TRY TO UNDERSTAND THEY ARE FINANCIALLY INCENTED TO FIX THOSE. BECAUSE WHEN THEY TRIP OFF, THEY HAVE STARTUP COSTS AND LOST REVENUE DURING THAT TIMEFRAME. SO THEY'RE, THEY'RE USUALLY ON IT QUICKLY TELLING US, THIS IS THE REASON WHY WE TRIPPED AND IT'S FIXED WITH INVERTER BASED RESOURCES. THEY'RE MUCH MORE COMPLEX AND THE TRIPS THAT ARE HAPPENING, THEY'LL TRIP OFF FOR JUST A FEW SECONDS TO A FEW MINUTES AND THEN THEY COME BACK. SO THEY HAVE NO INCENTIVE TO FIX THESE, THESE ISSUES TO THEM. SOMETIMES THEY DIDN'T EVEN KNOW ANYTHING HAPPENED, THEY JUST HAD A LITTLE BLIP AND THEN THEY RESTARTED THE TURBINES OR THEY RESTARTED THE INVERTERS AND THEY'RE BACK ON. BUT FROM A SYSTEM PERSPECTIVE, THIS IS A VERY BIG IMPACT DURING THAT WINDOW. UH, SO WE DO FOLLOW UP, BUT THIS IS A UNIQUE ISSUE AND THAT'S WHY IT'S RISEN ALL THE WAY UP TO THE FEDERAL GOVERNMENT WHERE THEY ISSUED 9 0 1. THIS IS, THIS HAS THAT KIND OF RISK BECAUSE THAT LITTLE WINDOW, UH, IF IT ALL SHUTS DOWN AT THE SAME TIME, CAN CREATE THE REALLY NEGATIVE CONSEQUENCES. I, I DON'T KNOW IF IT'S REALLY HELPFUL TO SAY NO INCENTIVE, BECAUSE I THINK THEY PROBABLY DO HAVE SOME INCENTIVE. I MEAN, THERE MIGHT BE A LITTLE BLIP, BUT THEY, I WOULD THINK THE SOLAR AND THE WIND GUYS WOULD SAY THAT THEY PROBABLY HAVE AN INCENTIVE. I, I, I THINK THAT'S APPROPRIATE. AND LET, LET ME CORRECT MY WORDS, BUT WHEN WE, AND, AND RYAN'S BEEN INVOLVED WITH THE EVENT ANALYSIS ON THIS, WHEN WE'VE ENGAGED THEM, UH, A LOT OF TIMES THEY'RE, THEY HAD NO PLANS ON DOING ANYTHING ABOUT THE TRIPPING OFF AND COMING BACK ON. AND IT WAS ONLY BECAUSE WE DID EVENT ANALYSIS AND WE ENFORCED THE CURRENT PERFORMANCE REQUIREMENTS THAT WE HAVE TODAY THAT THEY ACTUALLY GOT INVOLVED AND STARTED FIXING SOME OF THE ISSUES. A TECHNICAL CLARIFICATION THAT I KNOW STEVEN WILL AGREE WITH. I'M NOT GETTING INTO THE, THE ABSOLUTES, BUT THERE IS A LITTLE BIT MORE INCENTIVE FOR SYNCHRONOUS GENERATOR NOT TO TRIP IT BECAUSE THE COST, THE OUTAGE COSTS TO STARTUP COSTS ARE HIGHER, RIGHT? SO IT'S NOT THAT ONE HAS IT, ONE DOESN'T, IT'S THAT I TRIP A GEN SYNCHRONOUS GENERATOR TAKES ME HOURS OR DAYS TO BRING IT BACK ON. I TRIP A INVERTER BASED RESOURCE THAT COMES BACK AUTOMATICALLY IN FIVE MINUTES. THAT'S, THAT'S JUST OBJECTIVE FACT, RIGHT? ON MOST OF THE SETTINGS OUT THERE OR FASTER. [04:30:01] SO I THINK THAT'S WHAT YOU WERE GETTING AT STEVEN, BUT YEAH, AND, AND IT'S THE VOLUME TOO. WHEN YOU HAVE A SYNCHRONOUS MOP, YOU, YOU MAY HAVE A COUPLE UNITS IN THE SAME PLANT OR MAYBE ONE NEARBY, UH, WHEN YOU HAVE 20, 30 INVERTER BASED RESOURCES ALL TRIP OFF OR HAVE A SHARP, WE DON'T PLAN FOR THAT. THAT IS SO BEYOND OUR PLANNING THAT THAT'S THE REAL SCARY PART, UM, IS WE DIDN'T ANTICIPATE IT, WE DIDN'T PLAN ON IT AND BOOM, YOU KNOW, THAT HAPPENS. OKAY. KEVIN? YEAH, JUST THINKING ABOUT THIS CHART REAL QUICK, UM, HOW MANY EVENTS HAVE WE, OH, I SKIPPED COL COLIN, SORRY. YOU GO, GO AHEAD AND THEN I'LL, I'LL GO BACK TO THE VICE CHAIR. UM, HOW MANY EVENTS HAVE WE HAD SO FAR THIS YEAR FOR 2024? THAT WAS A QUESTION I HAD . HUH? THAT WAS A QUESTION I HAD. YEAH. UM, I GOTTA GO FIND OUT. I, I'M NOT SURE IF THAT NUMBER IS THAT NUMBER, BUT IT'S THREE OR FOUR SO FAR THIS YEAR. I THINK GREATER THAN 500 MEGAWATTS. I HAVE TO GO BACK, RYAN. I, I'M THINKING THEY'RE NOT RIGHT. I THINK THEY'RE UNDER 500. UM, MAYBE ONE IS RIGHT THERE. UM, AND THEN WE'VE HAD A COUPLE OF OTHER, NOT TRIPS, BUT LIKE A SHARP REDUCTION FOR A FEW CYCLES AND THEN CAME BACK TYPE ISSUES. UH, THAT ONE I KNOW WAS GREATER THAN 500, THAT SHARP IMPACT, BUT IT WAS BACK WITHIN A SECOND. YEAH. WHICH WE WOULD EXPECT, RIGHT? JUST, JUST TO BE, TO BE FAIR, UM, IT WAS NOT MODELED TO HAVE THAT SHARPER REDUCTION. THAT'S THE ACTIVE CURRENT REDUCTION ISSUED THAT WE'RE ALL AWARE OF. AND WE'LL GET TO THE MODELING HERE, HOPEFULLY. OKAY, COLIN? YEAH, SO I MEAN, THE ASSESSMENT OF RISK, I MEAN, THIS IS AN IMPORTANT TOPIC AND WHEN WE MET BACK ON THE 10TH, WE SPENT A LOT OF TIME TALKING ABOUT THE RISK TOPIC, HOW IT'S TIED TO MODELS. HOW DO YOU, HOW DO YOU ACTUALLY FIGURE OUT WHAT THAT IS? I DON'T, I DON'T THINK WE'RE GONNA SOLVE THIS TODAY. UM, BUT ONE OBSERVATION I WANT TO JUST KIND OF THROW OUT THERE, BASED ON THE PREVIOUS ISSUE, NUMBER ONE ON THE, THE EXCHANGE THAT WE HAD ON RELAY SETTINGS VERSUS PERFORMING EXPECTATIONS. I MEAN, IT, IT GIVES ME PAUSE IF, IF I'M HEARING THAT, THAT THERE'S A INTERPRETATION OR OPINION OUT THERE THAT, YOU KNOW, JUST 'CAUSE I'VE GOT MY RELAY SET A CERTAIN WAY THAT MAYBE I DON'T HAVE THIS OBLIGATION TO RIDE THROUGH BASED ON SOME OTHER ISSUE WITHIN MY FACILITY. AND I DON'T KNOW IF I'M INTERPRETING THAT CORRECTLY OR NOT, BUT THAT, THAT'S, THAT'S WHAT I HEARD. UM, SO THAT TO ME INDICATES THERE'S MORE RISK THAT THAT'S REALLY GOTTA BE ASSESSED. OKAY. THANKS COLIN. ERIC? YEAH, I THINK IT'D BE GOOD TO KEEP MOVING, BUT, UH, IN REGARDS TO WHAT THE CURRENT REQUIREMENTS ARE, RE REGARDLESS OF WHETHER THEY'RE PERFORMANCE BASED OR SETTINGS BASED, I THINK WE AGREE THAT NO GOOD 2 45 IS CLEARLY PERFORMANCE BASED AND THAT'S A GOOD THING. AND SO IT'S ONE MORE REASON TO MOVE, MOVE FORWARD WITH THAT. OKAY. YEAH, THANK YOU FOR BOTH OF THOSE COMMENTS. I WAS GONNA SAY THAT TOO. I THINK, YOU KNOW, I, I WANT EVERYBODY TO GET THE INFORMATION THAT THEY NEED, ESPECIALLY THE, THE TECH VOTING MEMBERS. WE DID SPEND ABOUT SEVEN HOURS ON RISK AND MODELS, YOU KNOW, 12 DAYS AGO, AND WE DO HAVE TO GET SOMETHING TO THE BOARD IN LESS THAN A MONTH. UM, SO I WOULD KIND OF, YOU KNOW, I THINK WE'RE GETTING INTO SOME AREAS OF SPECULATION. I THINK WE'RE GETTING SOME GOOD QUESTIONS THAT COULD MAYBE BE ANSWERED BY ERCOT OFFLINE. UM, MAYBE THINGS WE'VE COVERED ALREADY. AND SO FOR TODAY, I, I'D LIKE TO KIND OF MOVE FORWARD AS BOTH THE LAST SPEAKER SAID, AND, AND TRY TO FOCUS ON WHAT WE CAN GET TO AGREEMENT ON. AND, AND MAYBE IF TAC MEMBERS NEED MORE INFORMATION FROM ERCOT ABOUT, YOU KNOW, NUMBER AND NATURE OF EVENTS AND THINGS LIKE THAT, WE, WE CAN GET THAT OFFLINE IN BETWEEN NOW AND THE NEXT TAC MEETING. AND TO ERIC'S POINT, I THINK THERE'S A NUMBER OF THINGS WHERE JOINT COMMENTARIES AND, AND ERCOT JUST DON'T AGREE ON THE FACTS. AND SO I, I THINK IF YOU'RE A VOTING TAC MEMBER, IT'S JUST SORT OF UP TO YOU TO, TO MAKE THE DECISION AND, AND WE, I DON'T THINK TIME SPENT ON THE, THE BACK AND FORTH IS ALL THAT PRODUCTIVE AT THIS POINT. RYAN, THE SUGGESTION I WOULD MAKE FOR YOU IS, UM, MAYBE SKIP NUMBER FIVE FOR NOW, BUT, BUT GO, GO, KEEP GOING THROUGH IT. BUT I THINK THREE THROUGH THREE AND FOUR AND SIX AND SEVEN ARE ALL KIND OF ABOUT THE DATE. AND SO IF WE COULD SKIP THE COMMERCIAL REASONABILITY FOR, FOR NOW AND, AND FOCUS ON THE DATE. AND MY UNDERSTANDING IS YOU'LL, YOU'LL BE AROUND FOR THE REST OF THE MEETINGS. SO IF IN THE DISCUSSION LATER WE GET BACK TO COMMERCIAL REASONABILITY, THEN WE'D, [04:35:01] WE'D GET YOUR INPUT THEN. DOES THAT SOUND OKAY? YEAH, YEAH. THERE'S A COUPLE POINTS THAT ARE ALL INTERRELATED THAT I WANTED TO HIGHLIGHT. SO YEAH, IT'S, IT'S, IT'S, UH, I'LL, I'LL STICK TO THAT. SO I THINK ANY DATE YOU PICK, 'CAUSE ESPECIALLY IF YOU'RE GOING OFF OF THE PRECEDENT OF, WELL, IT'S GONNA BE WHATEVER THE NEXT FORWARD LOOKING DATE CAN BE, BOARD APPROVAL DATE, ET CETERA, YOU'RE, YOU'RE GETTING INTO AN ARBITRARY VALUE. ONE THING I DO WANNA HIGHLIGHT THOUGH IS WHEN YOU APPLY A RETROACTIVE DATE TO RELATIVELY NEW EQUIPMENT AND YOU'RE REMOVING THE EXISTING EXEMPTION, SO I SKIPPED THE LAST SLIDE, BUT I REALLY WANTED TO HIGHLIGHT THAT AT LEAST MY UNDERSTANDING OF THE CURRENT NORE 2 45 IS THAT ALL PAST EXEMPTIONS ARE REMOVED OR SORT OF DISQUALIFIED AND YOU CAN SEEK NEW EXEMPTIONS ON A LIMITED BASIS FOR CERTAIN ITEMS, RIGHT? AND SO WE KNOW THAT THERE, AND, AND, AND THE CURRENT NODAL OPERATING GUIDE ALLOWS FOR EXEMPTIONS TO SOME DEGREE, AND THERE'S LANGUAGE IN THERE EXPLICIT FOR VOLTAGE AND SORT OF PSEUDO IMPLICIT FOR, FOR FREQUENCY. WE KNOW THERE ARE FREQUENCY RELATED EXEMPTIONS THAT HAVE BEEN GRANTED OVER THE YEARS. WE KNOW OLD LEGACY WIND TURBINES HAVE FREQUENCY RELATED PROBLEMS. AND SO WHEN WE GET RID OF ALL THE EXEMPTIONS FOR LEGACY FREQUENCY RIDE THROUGH, WE'VE NOW GOT OURSELVES SET UP FOR EQUIPMENT THAT IS INSTALLED IN THE FIELD THAT WE KNOW WILL NO LONGER BE ABLE TO COMPLY WITH THE REQUIREMENTS. SO TAKE ALL THE MESS OF 2 45 AWAY LOGICALLY, WHY WOULD YOU NOT GRANT THAT RESOURCE THE EXEMPTION THAT IT HAD PREVIOUSLY, RIGHT? NOTHING'S CHANGED IN THE FACILITY. THAT WIND TURBINE FROM 2008 HAS A RIDE THROUGH CAPABILITY. AND AS LONG AS WE'VE MAXIMIZED THAT TO THE GREATEST EXTENT POSSIBLE, I WOULD THINK THAT WOULD BE LOGICALLY SUFFICIENT UNLESS THERE WAS A CATASTROPHIC RISK, IN WHICH CASE MAYBE AN ACTION WOULD HAVE TO BE TAKEN, RIGHT? SO WHEN YOU START COMBINING THESE DIFFERENT CONCEPTS THAT OFTEN WILL GET TALKED ABOUT IN SILOS, WE RUN INTO SOME CHALLENGES WHEN YOU, WHEN YOU PUT ALL THE DOTS TOGETHER, IT DOESN'T REALLY, AT LEAST IN MY OPINION, IT DOESN'T NECESSARILY CLICK FOR ME. SO WE NEED TO RUN MORE STUDIES, WE NEED TO UNDERSTAND THAT RISK. WE'LL GET TO THAT HERE IN A MINUTE. UM, TALKED ABOUT, YOU KNOW, THIS, THIS 20 TO 30 GIGAWATT NUMBER HAS COME OUT OF THAT DIFFERENCE BETWEEN THE JUNE, 2023, JUNE, 2024. IT'S MOSTLY, YOU KNOW, SOLAR PV BATTERIES, BRAND NEW OFF THE SHELF WITH THE LATEST FIRMWARE UPGRADES. THEY WON'T HAVE THE ISSUES THAT THE ODESSA FACILITIES HAD IN THE PAST. THOSE ISSUES HAVE BEEN FIXED, HOPEFULLY. UM, AND THE CURRENT ATTACK APPROVED VERSION OF, OF THE NOIR REQUIRES MAXIMIZATION MAXIMIZATION TO THE GREATEST EXTENT POSSIBLE. SO WE GET INTO THIS DISCUSSION OF, WELL, CAN THEY MEET THE LEGACY? YES, I THINK WE WOULD ALL AGREE. LIKE ESPECIALLY NEW EQUIPMENT CAN, YOU KNOW, ESPECIALLY SOLAR AND BATTERIES CAN MEET THE LEGACY REQUIREMENTS. ABSOLUTELY. CAN THEY MEET THE PREFERRED REQUIREMENTS? THIS GETS REALLY NUANCED AND TECHNICAL VERY QUICKLY. CAN A NEW RESOURCE CAN A RESOURCE THAT HAS A SIGNED INTERCONNECTION AGREEMENT FROM JULY, 2023 MEET IEE 2,800? THE OEM IS GOING TO TELL YOU, I DON'T KNOW, BECAUSE THERE'S NO DOT TWO TEST AND VERIFICATION PROCEDURES YET PUBLISHED, IT'S STILL IN THE WORKS. THE EXPERTS OF FOUR OR 500 PEOPLE ARE STILL ARGUING ABOUT THIS THREE TIMES A WEEK. AND SO HOW IS AN OEM EXPECTED TO COMPLY WITH, REQUIRE WITH THE TEST PROCEDURES THAT AREN'T PUBLISHED YET? SO IF I WAS A GENERATOR OWNER PERSONALLY, I WOULD SUBMIT MY EXEMPTION THE MOMENT ANYTHING GOT APPROVED SAYING I, I CAN'T TELL YOU WHETHER I COMPLY WITH 2,800 OR NOT, BECAUSE I'M GOT A PRODUCT OFF THE SHELF THAT THE OEM DOES NOT JUSTIFY, CAN BE 2,800 COMPLIANT NOW, IF THEY CAN, AWESOME, RIGHT? MAYBE A GOOD OEM, RIGHT? BUT NOT ALL OEMS, RIGHT? AND SO THAT'S A, THAT'S JUST A LEGITIMATE CHALLENGE WE'RE GOING TO HAVE TO DEAL WITH FOR THE NEXT TWO TO FOUR YEARS AS DOT TWO COMES OUT. AND AS WE IMPLEMENT, DO TWO AND LEARN HOW TO IMPLEMENT DOT TWO AS AN INDUSTRY, SOME FLEXIBILITY WILL NEED TO BE GRANTED. AND HOPEFULLY THE REQUIREMENTS WOULD REFLECT THAT TO, TO SOME EXTENT. AND AGAIN, IT'S A VERY NUANCED, UH, TOPIC AND A VERY TECHNICAL TOPIC AROUND CERTIFICATIONS FROM OEMS, HOW YOU'RE CERTIFYING AND, AND CONFORMING TO THE REQUIREMENTS FOR THE PLANT ITSELF, ET CETERA. BUT THERE IS A, A BIG HICCUP IN THERE WITH THE OEMS IN PARTICULAR, ALL THAT TO SAY IT'S 97% SOLAR AND BATTERIES THAT HAVE THE FIXES THAT FIX THE SOFTWARE, FIXES THAT FIX THE PROBLEMS OF YESTERDAY OF THE ODESSA EVENTS, RIGHT? SO I'VE SORT OF HIGHLIGHTED ALL OF THIS. SO, SO WHAT'S LEFT IN TERMS OF BEING ALLOWED WITH THE APPROVED VERSION OF NOGA 2 45? THE ANSWER IS NONE OF IT, RIGHT? IT'S, IT'S ALL ELIMINATED. I SEE STEVEN SHAKING HIS HEAD, LIKE I'M LOOKING AT THE TECHNICAL DETAILS OF THE REQUIREMENTS [04:40:01] IN TERMS OF MAXIMIZATION, ELIMINATING THE, THE, ALL THE THINGS THAT AREN'T FREQUENCY AND VOLTAGE RIDE THROUGH, UH, ET CETERA, ET CETERA. LIKE THOSE THINGS MITIGATE THE RISKS WE'VE AT LEAST SEEN TO DATE AND SHOULD SIGNIFICANTLY MITIGATE, UH, SYSTEM-WIDE RISK. OKAY, SO I'LL SKIP THIS. YEAH, I THINK DAN HAD A QUESTION. YEAH. GO BACK TO 18, I THINK. YEAH. YEAH. DO YOU THINK THEY SHOULD, MAX, YOU SAID IT WAS GOOD IF THEY WOULD MAX, THEY WOULD ALL HAVE LOTS OF CAPABILITY AND THEY COULD MAXIMIZE UP TO THEIR EQUIPMENT CAPABILITY, BUT IS THAT UP TO THEIR, THE LEGACY REQUIREMENTS OR IS IT UP TO THEIR EQUIPMENT CAPABILITY? CAN I COME BACK TO THAT? DAN'S A GOOD QUESTION. CAN I COME BACK TO THAT ON SLIDE SEVEN? ON THE NUMBER SEVEN? I'M ALMOST THERE. OKAY. UM, BUT YOU JUST KIND OF BLEW, BLEW PAST IT. LIKE THEY'RE, THEY'RE GONNA MAXIMIZE, BUT THERE'S, I'VE GOT A SLIDE, BIG DISTINCTION. I'VE GOT A SLIDE. YEAH, WELL WE DID ASK HIM TO SPEED IT UP AND I THINK 3, 4, 6, AND SEVEN ALL KIND OF GO TOGETHER WITH THE, THE REQUIREMENTS FOR THE, THE NEW. SO, SO, YEAH. SO MY, MY MY POINT ON THIS SLIDE, AND I WON'T GO INTO COMMERCIAL REASONABILITY. MY, MY GOAL IS NOT TO GET INTO THAT DISCUSSION, BUT IT'S TO ACKNOWLEDGE THAT WE'RE MOVING TO BETTER REQUIREMENTS, I'LL CALL IT THAT, RIGHT? WE WON'T GET INTO RELAY VERSUS PERFORMANCE BASE, ET CETERA. THEY'RE BETTER REQUIREMENTS. ONE THING THEY DO INCLUDE IS A, A, A DYNAMIC PERFORMANCE REQUIREMENT THAT DOESN'T EXIST IN THE EXISTING REQUIREMENTS. THAT ALONE CAN BE EXTREMELY DIFFICULT TO MEET, PARTICULARLY FOR WIND, LEGACY WIND, AS STEVEN MENTIONED, LEGACY WIND IS PROGRAMMED TO DO A BIG DIP WHEN A BOAT, WHEN AN EVENT OCCURS AND TO COME BACK RELATIVELY QUICKLY. AND WE'VE RUN STUDIES, I LED A BUNCH OF STUDIES AT NERC WHEN I WAS THERE THAT SAID, AS LONG AS WE COME BACK BACK WITHIN ONE SECOND, WE SHOULD BE, OKAY. SO WHERE DOES THE ONE SECOND COME FROM? IT COMES FROM THAT GENERAL CONCEPT, RIGHT? WE CAN RUN STUDIES TO QUANTIFY THAT RISK AND SET A VALUE BASED ON THE ACCEPTABLE AMOUNT OF RISK, RIGHT? SO THE SPEED OF RESPONSE IS IN THERE, BUT WHEN WE'RE JUMPING, AGAIN, WE'RE ELIMINATING ALL PAST EXEMPTIONS. AND SO, SO IN ESSENCE, COMMERCIAL REASONABILITY COULD BE LOOKED AT AS AN EXEMPTION PROCESS, BUT ONE THAT DOESN'T JUST SAY YOU GET YOUR EXEMPTION LIKE NERC, PRC 29, IT'S, YOU GOTTA PROVE YOUR WORK. YOU'VE GOTTA SHOW THE REASON AND THE JUSTIFICATION AND THE TECHNICAL COMMERCIAL REASONABILITY OF THAT. SO THAT WAS THE ONE THING I WANTED TO HIGHLIGHT HERE. SIX IS BLUNT, BUT I THINK MOST IMPORTANT IS WE ALL AGREE WE NEED NEW REQUIREMENTS FOR NEW RESOURCES. WE NEED IEEE 2,800, UH, REQUIREMENTS PLACED ON THOSE RESOURCES. THE PREFERRED REQUIREMENTS, AT LEAST IN TERMS OF THE SHAPES OF THE CURVES, ET CETERA, WE ALL RELATIVELY AGREE WITH, UM, WE AGREE WITH LOTS OF THE TECHNICAL LANGUAGE IN THE, EVEN FOR THE EX UH, THE LEGACY STUFF. SO I, YOU KNOW, I KEEP THINKING, CAN WE JUST SIMPLY BIFURCATE THIS AND WRITE A SIMPLIFIED NOER THAT INCLUDES ALL SOFTWARE REQUIREMENTS INCLUDES IEE 2,800 AND INCLUDES ALL THE THINGS THAT WE AGREE ON AND GET THAT THROUGH AND THEN CONTINUE THE ARGUING. AND WE PROBABLY COULD HAVE DONE THAT IN EARLY 2023. SO I JUST POSED THAT AS ARE WE LETTING THE PERFECT BE THE ENEMY OF THE GOOD HERE FOR THE LEGACY STUFF, WHICH IS ALL WE'RE ARGUING ABOUT, ESSENTIALLY, WHICH IS HOLDING UP THE APPLICATION OR AT LEAST THE FIRMING UP OF UNDERSTANDING WHEN THE APPLICATION FOR NEW RESOURCES WOULD BE. SO TO DAN'S POINT, UM, WE PROPOSED THIS CONCEPT OF DEFENSE IN DEPTH, WHICH WAS MAXIMIZE FOR THE 20 TO 30 GIGAWATTS. IF WE HAVE SO MUCH CONCERN ABOUT THE RISK THAT THOSE POSE, LET'S MAXIMIZE. SO AFTER THAT, I WENT THROUGH AND I, I LOOKED AT THE APPROVED VERSION OF THE NOER AND I PULLED UP THE LANGUAGE AND I'VE GOT THE FOUR DISTINCT CLAUSES, THE TWO FRT, THE TWO VRT, AND IN EACH CLAUSE THERE'S A, THERE'S A, THERE'S A PARAGRAPH THAT SAYS YOU MUST MAXIMIZE TO THE GREATEST EXTENT POSSIBLE, IF PROTECTION SYSTEMS ARE INSTALLED AND ACTIVATED TO TRIP THE IVR, THEY SHALL ENABLE THE RESOURCE TO RIDE THROUGH FREQUENCY SLASH VOLTAGE CONDITIONS BEYOND THOSE DEFINED IN PARAGRAPH ONE, WHICH ARE THE CURVES ABOVE TO THE MAXIMUM EXTENT EQUIPMENT ALLOWS NOT UP TO THE MA NOT UP TO THE REQUIREMENT, UH, UP TO THE MAXIMUM EXTENT THE EQUIPMENT ALLOWS. AND SO THAT'S CARRIED THROUGH IN ALL OF THE REQUIREMENTS AND CARRIED THROUGH IN THE COMMERCIAL REASONABILITY CLAUSE. SO IF YOU'VE, YOU'VE GONE AND YOU'VE MAXIMIZED ALL YOUR EQUIPMENT AND YOU STILL HAVE A CHALLENGE MEETING, MEETING THE REQUIREMENTS, YOU SEEK AN EXEMPTION AND THEN YOU'RE ALSO REQUIRED TO MAXIMIZE TO THE GREATEST EXTENT THE EQUIPMENT ALLOWS FOR YOUR EXEMPTION, RIGHT? SO THROUGH AND THROUGH, I READ THIS AS EVERY PIECE OF EQUIPMENT OUT THERE IS GOING TO BE MAXIMIZED TO THE GREATEST EXTENT THE EQUIPMENT ALLOWS. THAT'S WHAT'S WRITTEN IN THE FOUR AND THEN IN THE COMMERCIAL REASONABILITY SECTION. SO ARGUE WITH ME, BUT I DON'T, I DON'T KNOW HOW YOU WOULD READ THAT OTHERWISE, WHICH IS BY FAR THE, BY FAR [04:45:01] THE MOST STRINGENT STANDARD IN THE WORLD, I WOULD SAY, BECAUSE NO OTHER STANDARD REQUIRES EVERY PIECE OF EQUIPMENT TO MAXIMIZE TO THE GREATEST EXTENT THE EQUIPMENT ALLOWS MAXIMIZE TO THE REQUIREMENT. BUT BEYOND THE REQUIREMENT, YOU CAN DO WHAT YOU WANT, RIGHT? THIS SAYS YOU'RE NOT ALLOWED TO, YOU HAVE TO MAXIMIZE, OKAY. RIGHT? SO I THINK THAT'S GOING TO, THAT, THAT POTENTIALLY IS, IS SOMETHING THAT IS NOT TALKED ABOUT ENOUGH AND I THINK COVERS A LOT OF THE RISK CONCERN, RIGHT? SO I JUST THROW THAT OUT THERE. GO AHEAD STEVEN. I DO WANNA HEAR WHAT, WHAT ERCOT THINKS BECAUSE I THINK THIS IS AN AREA WHERE WE ARE YEAH. BIND IN CONCEPT. I THINK CONCEPTUALLY WE ALL AGREE, I THINK THE LANGUAGE THERE IN TWO POINT 11 IS THE PROBLEM THERE, WHERE IN THAT PARTICULAR REFERENCE, IT ONLY REFERS TO COMMERCIALLY REASONABLE THINGS AND IT SAYS TO MAXIMIZE UP TO THE REQUIREMENTS. AND SO I THINK IF WE MAKE SOME ADJUSTMENTS TO THE LANGUAGE SO THAT IT ALIGNS WITH ALL THE OTHER REFERENCES, I THINK WE'LL BE ON THE SAME PAGE. I THINK WE WILL AGREE THAT WE SHOULD MAXIMIZE TO THE EQUIPMENT CAPABILITY. I THINK JUST REAL QUICK, I MEAN WHEN WE LOOK AT GRID CODES AROUND THE WORLD TOO, RYAN, THERE'S DEFINITELY MORE STRINGENT GRID CODES IN IN OTHER REGIONS AND WHERE WE'RE TRYING TO GET TO WHERE WE NEED TO, WE DON'T NECESSARILY WANT TO GO TO THE EXTENT THAT SOME OTHERS, UM, ARE, BUT WE THINK THIS IS A REASONABLE APPROACH. YEAH, I MEAN, I'M, I'M GONNA STICK TO THE, I THINK THIS IS THE MOST STRINGENT IN THE WORLD FROM THE PERSPECTIVE OF NO OTHER REQUIREMENT THAT I'VE EVER SEEN REQUIRES EVERY SINGLE IBR ON THE SYSTEM TO MAXIMIZE EQUIPMENT CAPABILITY TO THE MAXIMUM EXTENT POSSIBLE AND THEN HELD TO THAT REQUIREMENT AT ALL TIMES, RIGHT? WE, WE, WE HAVE PERFORMANCE BASED CURVES OR RIDE THROUGH REQUIREMENTS, ET CETERA, THAT SETS A MINIMUM ADEQUATE LEVEL OF RELIABILITY BAR. AND THEN ABOVE THAT YOU GET SOME LEEWAY AND FLEXIBILITY ON, ON HOW YOU MAKE SETTING CHANGES OR, OR SETTING, UH, DECISIONS, RIGHT? THAT WHOLE CONCEPT OF SOME LEEWAY OF MAKING SETTING DECISIONS IS ELIMINATED WITH THE REQUIREMENTS THAT ARE WRITTEN HERE. I DO THINK THAT IF YOU'RE APPLYING FOR, UH, COMMERCIAL REASONABILITY EXEMPTION IN THE FIRST PLACE, YOU HAVEN'T MET THE REQUIREMENTS. AND SO WHETHER OR NOT IT SAYS MEET THE REQUIREMENTS OR MEET THE MAXIMUM EXTENT EQUIPMENT LAO, IT'S THE SAME THING BECAUSE THE ONLY REASON I WOULD EVER APPLY FOR THE EXEMPTION IS 'CAUSE I DON'T MEET THE REQUIREMENTS, RIGHT? SO I THINK WE'RE, WE'RE ARGUING THAT APPLE'S AND ORANGES, I DON'T THINK IT'S REALLY RELEVANT OPEN FOR DISCUSSION, BUT I'VE BEEN STARING AT THIS FOR THE LAST FEW DAYS PRETTY EXCESSIVELY. OKAY, CHASE, THANKS KAITLIN. UH, CAN YOU CONFIRM? YOU CAN HEAR ME? WE CAN HEAR YOU. THANK YOU. THIS IS CHASE MS. SOUTHERN POWER. UM, I JUST WANT A QUICK COMMENT. I THINK, UM, THE JOINT COMMENTERS, I THINK COLLECTIVELY AGREE, UM, WITH THE MAX THIS MAXIMIZATION, UM, OF, OF CAPABILITIES VIA SOFTWARE AND AND SETTINGS. UM, I THINK TO RYAN'S POINT, THERE IS SOME MAXIMIZATION LANGUAGE ALREADY IN THE TECH REPORT. UM, I ALSO AGREE WITH STEVEN THAT THERE'S SOME LANGUAGE, YOU KNOW, FOR EXAMPLE, THE TWO 11 LANGUAGE OF THE UP TWO REQUIREMENTS THAT WE NEED TO CHANGE. AND I THINK WE MAY HAVE IDENTIFIED, YOU KNOW, WE'RE JOINT S ARE STILL REVIEWING THE TAC REPORT JUST TO, THIS IS, UH, OBVIOUSLY A A LOT OF COMPLICATED LANGUAGE TO, FOR THE OVERALL FRAMEWORK THAT THERE MAY BE A FEW OTHER REVISIONS THAT MIGHT BE NEEDED TO MORE FULLY INCORPORATE THE MAXIMIZATION, UH, VIA SOFTWARE AND SETTINGS CONCEPT. UM, SO I JUST WANTED TO CLARIFY THAT I THINK THERE JOINT COMMERCE ARE REVIEWING THAT AND, UM, THERE MAY BE SOME OTHER, YOU KNOW, FURTHER EDITS THAT WOULD BE NEEDED TO, TO FULLY INCORPORATE THE CONCEPT. THANKS. THANKS CHASE. AND I THINK WE'RE, WE'RE SHORTLY ABOUT TO GET TO THE, THE LANGUAGE, SO HOPEFULLY WE CAN START TO AGREE THERE. WOODY? YEAH, I WAS GOOD. I WAS JUST GONNA AGREE THAT, UH, WE KIND OF AGREED IN PRINCIPLE LAST TIME THAT MAXIMIZE UP TO THE FULL CAPABILITY OF THE EQUIPMENT. THAT WAS SOMETHING WE TENTATIVELY AGREED TO LAST TIME. YES. AND THAT'S REFLECTED IN THE RED LINES. WE OUGHT LOOK AT THE RED LINES AT SOME POINT. YEP. I I THINK WE CAN GO PROBABLY AFTER THIS NEXT QUESTION TO THE RED LINES TO NET THE, THE PRESSURE'S ON. ALRIGHT. UM, SO I AGREE THAT, YOU KNOW, I THINK WE, WE'VE ALL STACKED HANDS TO USE BRIAN SAM'S FAVORITE TERM ON, UM, MAXIMIZATION BEING A, A, YOU KNOW, A A THROUGH SOFTWARE BEING A, A RELATIVELY LOW, LOW-HANGING FRUIT AND CHASE. THIS MAY BE ALONG THE LINES OF, OF WHAT Y'ALL WERE THINKING ABOUT, BUT AS WE'VE, UH, LOOKED AT THIS [04:50:01] A LITTLE BIT MORE CLOSELY IN THE, UH, IN THE LAST WEEK OR TWO, UH, ONE THING WE'VE THOUGHT ABOUT IS, YOU KNOW, WITH MAXIMIZATION, YOU'RE, YOU'RE ALSO BALANCING THE RISKS OF DAMAGE TO THE EQUIPMENT IF YOU GO ALL THE WAY UP TO THE LIMIT AND YOU DON'T WANT TO DO THAT 'CAUSE THAT, THAT CREATES AN UNINTENDED CONSEQUENCE. SO, YOU KNOW, TO SAY WHEN WE SAY THAT THERE IS NO, YOU KNOW, NO DISCRETION, I THINK WE WANNA LEAVE SOME ROOM FOR REASONABLE, UH, REASONABLE ENGINEERING DECISIONS TO, TO, YEAH, I SEE A THUMBS UP. SO JUST WANTED TO MAKE SURE THAT WE'VE SAID THAT AND, AND WE'RE ALL THINKING ABOUT THAT AS THE SAME WAY. AND I DO HAVE A, UH, LIKE A, IT'S LIKE A FOOTNOTE EXPLAINER ON MAXIMIZE IF WE DO NEED IT, UM, THAT I'VE BEEN JUST THINKING ABOUT FOR THE BETTERMENT OF ALL, ALL SIDES, I THINK, RIGHT? JUST LIKE CAN WE EXPLAIN THAT? BECAUSE I THINK IN PRINCIPLE WE ALL AGREE WITH THAT. WE'RE NOT SEEKING TO PUT IT AT THE CURVE AND THEN LET THE EQUIPMENT EVER BLOW UP YOU BACK OFF THAT CURVE. SO WE NEED USING ENGINEERING JUDGMENT, USING DIRECTIVE BY THE OEM, WHATEVER IT MIGHT BE. AND THAT NEEDS TO BE ARTICULATED AT LEAST IN A FOOTNOTE. , RYAN, CAN YOU, UM, IF YOU HAVEN'T ALREADY, CAN YOU WRAP UP THIS NUMBER SEVEN AND THEN WE'LL MOVE TO ERCOT COMMENTS? YEAH, THAT, THAT WAS ALL I HAD. I HAD, UH, THREE SLIDES ON MODELING, WHICH I THINK ARE RELEVANT, BUT I, WE CAN SKIP 'EM IF YOU'D LIKE. WE, I'LL DEFER TO THE GROUP, BUT WE, WE SPENT ABOUT THREE OR FOUR HOURS ON MODELING AT THE LAST MEETING. I GUESS I'LL, I'LL SIMPLY SAY THAT THERE'S THIS QUESTION OF, YOU KNOW, AND EVERY, EVERYTHING THAT ERCOT HAS SAID ABOUT THE MODELS IS, IS, IS OBJECTIVELY TRUE? LIKE THERE ARE SOME LIMITATIONS IN THE MODELS. I THINK WHEN YOU, WHEN YOU LOOK, I PUT THIS TOGETHER. WHEN YOU GO ON, WHEN YOU LOOK AT SHOULD I UPDATE THE MODEL OR SHOULD I FIX THE ISSUE? THE VAST MAJORITY OF PROBLEMS, IT'S FIX THE ISSUE AND YOU CAN'T MODEL IT ANYWAYS. SO IF WE GET TOO DOWN THE ROAD OF THE MODELING DISCUSSION IN THE FIRST PLACE, WE'RE, WE'RE KIND OF MISSING THE POINT OF YOU DON'T MODEL A LOT OF THESE THINGS AND SO ELIMINATE THE ISSUE, ELIMINATES THE NEED TO DO THE MODELING. AND WHAT YOU'RE LEFT WITH AGAIN, ARE THESE SORT OF NEBULOUS PHYSICAL LIMITATION UNCERTAINTIES THAT WE DON'T QUITE UNDERSTAND, OR AT LEAST THERE HASN'T BEEN ENOUGH DOCUMENTATION PUBLICLY OF THOSE CONCERNS. BUT IN MOST CASES, IF I DO THE FIRMWARE UPGRADES AND I DO ALL THIS STUFF, WE MAY BE OKAY WITH SOME OF THE MODELING DEFICIENCIES THAT WE HAVE TODAY. YOU KNOW, CAN I DO A, CAN I DO A, A SIMULATION AND SHOW THAT I'M GONNA TRIP ON DC HIGH VOLTAGE OR LOW VOLTAGE? MOST, SOME, SOME OF THE OEMS DON'T MODEL THE DC BUS AND THE PROTECTIONS ON THE DC SIDE. SO WHAT YOU'RE, WHAT THAT'S GONNA REQUIRE IF WE SAY, OH, LET'S GO BACK AND UPDATE ALL THESE MODELS, HUNDREDS OF THOUSANDS OF DOLLARS PER FACILITY TO GO WORK WITH THE OEM TO GET THOSE MODELS UPDATED, WHEN IN REALITY JUST DO THE FIRMWARE UPGRADE AND THE PROBLEM GOES AWAY AND WE CAN LIVE WITH THE, NOT, WITH THE LACK OF MODELING. LIKE THAT NEEDS TO BE TAKEN INTO DO CONSIDERATION WHEN WE TALK ABOUT MODELING OF, WE'RE CONCERNED WITH A LIMITED SUBSET OF THINGS THAT WE MAY NOT EVEN BE ABLE TO MODEL IN THE FIRST PLACE BECAUSE THEY'RE PHYSICAL LIMITATIONS. THE SOFTWARE LIMITATIONS ADDRESS THE, A LOT OF THE MODELING PROBLEMS. SO I'LL LEAVE IT AT THAT. OKAY. OKAY. UM, BEFORE WE GET TO ERCO, I DO WANNA TAKE SOMETHING UP BECAUSE I SAW PEOPLE PACKING AND HOPEFULLY YOU WON'T. 'CAUSE I THINK WE, WE NEED TO GET INTO THE BULK OF THE WORK. WE DO HAVE TO TAKE AN ACTION ON THIS TODAY BECAUSE THE LAST MEETING WE HAD WAS A WORKSHOP. IT WASN'T A NOTICE VOTE VOTING MEETING. AND SO THIS IS THE FIRST NOTICE VOTING MEETING SINCE THE REMAND. I'M, YOU KNOW, EVEN THOUGH I'M CHAIR, I'M COMFORTABLE MAKING THE MOTION TO TABLE AND I, I THINK THAT'S FINE WITH EVERYBODY. UM, BUT WE PROBABLY NEED TO RUN THROUGH THAT BALLOT SINCE WE ALREADY DID THE COMBO BALLOT. I DON'T KNOW IF SOMEBODY WILL SECOND MY MOTION. ANYBODY KEVIN? YEAH. SO, SO COREY, IF YOU WANNA GO AHEAD AND RUN THROUGH THAT BALLOT, I HAVE A FEELING WE'RE ALL IN AGREEMENT, BUT OKAY, LET ME HEAR THIS. OKAY. OKAY. WE GOOD TO GO? [04:55:01] YEP. SO THE MOTION IS TO TABLE, NO, GO 2 45, NO AMENDMENTS. ALL RIGHT. GRAB MY CHEAT SHEET OF, OKAY. UH, SO FOR KEEP ME HONEST SUSIE, SO FOR NOGA 2 45, ERIC'S VOTE GOES TO NA BARRAGE. THAT IS CORRECT. HE IS REPRESENTING NEXTERA THERE. OKAY, I THINK WE SHOULD BE OKAY ON THAT ONE. LET'S GO AHEAD AND START UP WITH THE CONSUMERS WITH NARAJ. YES. THANK YOU FOR BOTH. YES, THANK YOU. AND THEN GARRETT GAVE HIS TO ERIC SCHUBERT? UH, YES SIR. AND SO FOR YOUR TWO VOTES, ERIC? YES, YES FOR BOTH. THANK YOU. YES, THANK YOU. AND THEN RICK FOR MARK? YES, THANK YOU. AND RICK FOR NICK? YES, THANK YOU. ONTO OUR CO-OPS, UH, BLAKE, FOR YOURSELF AND FOR MIKE. YES. AND YES, THANK YOU SO MUCH. AND THEN ERIC? YES, THANK YOU. AND LUCAS FOR JOHN? YES, THANK YOU. THANK YOU. ONTO OUR INDEPENDENT GENERATORS. BRIAN, BRIAN AMPS IS GONE. HOW ABOUT KAITLYN? YES, THANK YOU. BOB HELTON? YES SIR. THANK YOU SIR. NED? YES, THANK YOU CORY, THANK YOU. UNDER IPMS. RASHMI? YES. THANK YOU. JEREMY. YES, THANK YOU. THANK YOU. IAN, YOU WITH US REMOTELY? HE SAID ON HIS WAY OUT, WE COULD JUST SKIP HIM IF HE WASN'T AROUND. UH, KEVIN? YES, THANK YOU. THANK YOU. ONTO OUR I REPS. CHRIS FOR YOUR TRIO. YES, THANK YOU JENNIFER. SORRY. YES. OH, THANK YOU. AND I SEE YOU IN CHAT. IAN, YOU'RE, YOU ARE ALWAYS NEEDED. NO, 2 45 DOES NOT CHANGE THAT. AND WE'LL MOVE ON TO THE IOUS. STACY, FOR KEITH, I WILL COME BACK TO YOU. STACY. UH, DAVID, UH, HOW ABOUT COLIN? YES, THANK YOU DAVID FOR RICHARD. HEY, THIS IS STACY WITH TINA. I WAS ON MUTE. SORRY ABOUT THAT. YES. OH, NO WORRIES. I GOT YOU STACY. THANK YOU. LAST CALL FOR EITHER OF OUR DAVID'S MERCADO OR WITHROW. ALL RIGHT. ONTO OUR MUNIS. RUSSELL, YOU STILL WITH US? RUSSELL, HOW ABOUT JOSE? YES, THANK YOU DAVID. YES, THANK YOU. THANK YOU, ALICIA. YES, THANK YOU. ALL RIGHT ABOUT THAT. UNANIMOUS. THANK Y'ALL. OKAY, GREAT JOB EVERYONE. SO STEVEN, THESE WERE POSTED I, I THINK YESTERDAY, WHICH, WHICH IS FINE. WE, WE WANTED TO WORK THROUGH THEM TODAY, BUT, SO I HAVEN'T HAD A CHANCE TO THOROUGHLY REVIEW AND I'LL DEFER TO OR CUT A LITTLE BIT ON HOW TO, THE ORDER TO GO THROUGH THESE AND, AND TO TACK AS WELL. I THINK WE KIND OF FOCUSED AREAS OF LANGUAGE TYING BACK TO ISSUES OR QUESTIONS FROM THE LAST MEETING. AND SO I, I THINK WE'RE, IT'S NOT MAKING SENSE TO GO THROUGH LIKE IN LANGUAGE ORDER BUT BY ISSUE. IS THAT CORRECT? YEAH. OUR, OUR THOUGHTS WERE TO LOOK AT THE EXEMPTION SECTION. OKAY. TOWARDS THE END, SINCE THAT IS THE MAJORITY OF THE ISSUES OR WITHIN THESE LAST SECTIONS. AND IF WE COULD FOCUS THERE, WE FEEL LIKE WE COULD PROBABLY GET TO WHERE AT CONCEPT LEVEL WE CAN AT LEAST, UH, GET THE FEELING FOR THE TAC MEMBERSHIP. THAT I THINK THAT IS FINE WITH ME. SO, OR DO YOU WANT TO, COLIN, SHOULD WE, 'CAUSE WE, WE WERE JUST TALKING ABOUT THE EFFECTIVE DATE OR DO YOU JUST WANNA WAIT AND SEE HOW THAT RELATES BACK? I WAS WONDERING SHOULD WE TRY TO KNOCK OUT FOUR OR START WITH THE EXEMPTIONS? FROM THE LANGUAGE STANDPOINT, IT'S VERY EASY RELATED TO CHANGE JUST THE 6 1 23 TO 6 1 24. I THINK TO GET TAC MEMBERSHIP TO GET TO A CONSISTENT [05:00:01] OPINION ON THAT, WE WOULD PULL UP THE PRESENTATION AND, AND GO THROUGH IT THAT WAY. OKAY. OKAY. THEN LET'S, LET'S DO WHAT YOU WERE GONNA DO WITH THE EXEMPTIONS. OKAY, SO THIS IS STEVEN SLI WITH ERCOT. UM, I'M GONNA BE PRESENTING THE PROPOSED RED LINES THAT ERCOT MADE TO DRAFT, UH, WHAT CHANGES WE FEEL LIKE COULD BE MADE TO THE TAC APPROVED VERSION THAT, UH, WOULD ADDRESS COTS ISSUES. WHAT WE ATTEMPTED TO DO IS, IN EACH INSTANCE WHERE WE MADE SUBSTANTIVE CHANGES, WE TRIED TO PUT COMMENTS AND IN THE COMMENTS IDENTIFY WHAT KEY ISSUE IT WAS RELATED TO. SO JUST BEGINNING WITH SECTION TWO 11, UH, BECAUSE OF THE CONCERNS THAT WERE RAISED BY THE COMMISSION COMMISSIONERS THAT COMMENTED AT THE RELIABILITY OF MARKETS, UH, BOARD MEETING AS WELL AS UM, SOME OF THE COM THE BOARD DIRECTORS, UH, THE BOARD MEMBERS, WE STRUCK OUT ALL OF THE COMMERCIALLY REASONABLE EFFORT SECTION AND TRY TO PUT THE CONCEPTS WITHIN THAT IN OTHER SECTIONS RELATED TO THE EXEMPTIONS. SO PARAGRAPH ONE REALLY JUST FOCUSED ON THE APPLICABILITY OF THAT SECTION. UH, PARAGRAPH A HERE REALLY TALKS ABOUT SOFTWARE FIRMWARE, THOSE TYPES OF THINGS BEING INCLUDED AS COMMERCIALLY REASONABLE. AND THEN IF THERE ARE PHYSICAL MODIFICATIONS, WHAT THOSE TIMELINES WOULD BE, WHAT THE ENTITIES WOULD CONSIDER IN MAKING THAT DETERMINATION FOR COMMERCIAL REASONABLENESS. AND THEN IF ERCOT FELT LIKE THERE WAS OTHER THINGS. SO AS I GO THROUGH HERE, WE'RE GONNA TALK ABOUT WHERE WE'VE RELOCATED SOME OF THOSE CONCEPTS WITHIN THE LANGUAGE. SO EVERYTHING THAT WAS TWO 12 WOULD SHIFT TO TWO 11. UH, THIS LANGUAGE PRIMARILY IS TALKING ABOUT IF YOU CANNOT MEET THE DECEMBER 31ST, 2025 DEADLINE, YOU WOULD HAVE UNTIL FEBRUARY 1ST OF NEXT YEAR TO SUBMIT THIS, UH, INFORMATION WHICH WOULD ALIGN WITH AN EXEMPTION REQUEST. UH, TO NOTE THE NERC LEVEL PRC 29, THEY'RE TAKING A VERY SIMILAR APPROACH, WHICH IS THERE'S THIS ONE TIME EXEMPTION OR LIMITATIONS COME FORWARD, SAY WHAT YOU CAN DO AND, AND THEN THAT GETS TAKEN INTO CONSIDERATION. SO FOR THOSE WINDOWS, ANYTHING WITH FREQUENCY AND VOLTAGE, THEY HAVE TO SUBMIT THAT INFORMATION TO ERCOT. SO SOME OF THE CHANGES IN THIS SECTION IS JUST REMOVING THE TERMS COMMERCIALLY UNREASONABLE OR REASONABLE AND PUTTING IN SUBSEQUENT LANGUAGE THAT TIES TO THE SECTIONS WHERE WE TAKE THAT INTO CONSIDERATION. WE ALSO REMOVE THIS ANNUAL CHECK PROCESS. UH, WE THINK THAT WE COULD REPLACE THAT WITH A MORE EFFICIENT, AS YOU FIND OUT, THEN IT GETS RELOOKED AT INSTEAD OF EVERY YEAR JUST RELOOKING AND RELOOKING AND, AND KIND OF HAVING A SOMEWHAT ADMINISTRATIVE PROCESS THAT COULD BE HANDLED ON A AS NEEDED BASIS. SO WE'LL TALK ABOUT WHERE THAT GOT RELOCATED. SO NOW WE'RE IN THE EXEMPTION SECTION AND IF YOU LOOK AT THE LANGUAGE HERE, WE TRIED WHAT'S IN RED IS WHAT IS THE TAC APPROVED VERSION LANGUAGE AND WHAT'S BLUE ARE THE EDITS. SO A LOT OF THIS WHERE WE DIDN'T COMMENT ON IT OR JUST KIND OF TITLE CHANGES AND THINGS LIKE THAT THAT HAVE TO BE DONE, UH, SOME CLARIFICATIONS, UH, WHERE WE NEEDED TO MAKE SURE THERE WAS CONSISTENCY. BUT YOU'LL SEE HERE STARTING WITH PARAGRAPH TWO, IF YOU HAVE AN S-G-I-S-G-I-A DATED BEFORE WHATEVER DATE TAC MEMBERSHIP DECIDES ON, WE PROPOSE JUNE 1ST, 2023, YOU HAVE UNTIL FEBRUARY 1ST, 2025 TO SUBMIT THAT EXEMPTION REQUEST. SO THAT'S YOUR WINDOW OF TIME. IF YOU'RE PAST JUNE 1ST, 2023, MEANING YOU SIGNED AN SGIA, BUT YOU'RE, YOU HAVE NOT YET INTERCONNECTED, UH, THIS ALIGNS WITH OTHER LANGUAGE. YOU HAVE UNTIL THE END OF DECEMBER 31ST, 2026 TO SUBMIT THOSE EXEMPTIONS. SO WE GOT EXISTING AND NEW COMING ON WHAT THOSE WINDOWS OF TIME ARE FOR THEM TO SUBMIT THOSE REQUESTS. AND THAT IS AN IMPORTANT CONCEPT FOR EVERYBODY TO, TO REALIZE IS THAT EVEN THE NEW MEETING, [05:05:01] THE PREFERRED REQUIREMENTS IN IEEE 2,800 HAVE AN OPPORTUNITY TO SUBMIT AN EXEMPTION REQUEST WHEN SEEKING IT. THIS IS THE INFORMATION THAT THEY HAVE TO PROVIDE. SO IF YOU'LL LOOK THROUGH THIS DETAILED DESCRIPTION OF THE LIMITATION COMING FROM, UH, WITH A LETTER SIGNED BY AN OFFICER OR EXECUTIVE OF THE OEM SO THAT WE NEED SOME DOCUMENTATION, DO DOCUMENTING THAT IT ACTUALLY IS A LIMITATION DESCRIBING ANY MODIFICATIONS THAT THEY HAVE IMPLEMENTED OR WILL IMPLEMENT ANY FEE TECHNICALLY FEASIBLE MODIFICATIONS THEY WILL NOT IMPLEMENT DOING DUE TO BEING COST PROHIBITIVE MODELS THAT ACCURATELY REPRESENT EXPECTED PERFORMANCE, REFLECTING THE TECHNICAL LIMITATIONS BEFORE AND AFTER ANY MODIFICATIONS TO IMPROVE PERFORMANCE, THE COST OF IMPLEMENTING EACH TECHNICALLY FEASIBLE RESOURCE MODIFICATION OR UPGRADE TO MEET THE REQUIREMENTS ON A PER INVERTER TURBINE BASIS. AND THEN THE COST OF A FULL REPLACEMENT. FINALLY, ANY OTHER FINANCIAL INFORMATION THE RE BELIEVES ARCA SHOULD CONSIDER. SO WHAT THIS DOES, IF YOU CAN IMAGINE, IS FOR EACH UNIT YOU'RE GONNA GIVE A LIST. HERE'S ALL THE OPTIONS WE GOT, HERE'S WHAT WE CAN, WE CAN DO SOME OF THOSE THINGS. WE THINK, YEAH, WE'RE GONNA DO 'EM OTHERS WE'RE GONNA TELL YOU WE'RE NOT PLANNING ON DOING THESE BECAUSE THEY EITHER COST TOO MUCH OR WE DON'T THINK THAT THEY PROVIDE ANY, ANY REAL VALUE. AND SO THAT'S GONNA MAKE IT EASIER TO MAKE A CONSISTENT APPLICATION. AS YOU GO THROUGH AND LOOK AT EACH, EACH EXEMPTION, YOU'RE GONNA HAVE A LIST, HERE'S THE CUT LINE THAT THEY DREW AND HERE'S WHY THEY DREW THAT CUT LINE. SO ONCE HER CUT GETS THAT INFORMATION, STEVEN, YOU WANNA PAUSE CHRIS, THE QUESTION? SURE PLEASE. YOU WANT TO COVER COMMENTS TO THE RED LINES NOW OR YOU WANT ME TO WAIT TO HOLD THEM? STEVEN, WHAT'S THE BEST CHUNK TO HANDLE THIS IN? I THINK IF WE CAN GET PAST THIS NEXT LEVEL FOUR, OKAY, IT'D PROBABLY BE A GOOD STOPPING POINT FOR LET'S DO THAT. SO WE DID TAKE OUT THE LANGUAGE THAT WAS PREVIOUSLY THERE THAT UH, ONLY ALLOWED ERCOT TO MAKE EXEMPTIONS TO CERTAIN BASED ON CERTAIN ASPECTS OF COMMERCIAL REASONABLE MODIFICATIONS AND MODELING. AND IF YOU REMEMBER OUR CONDITIONS THAT UH, WE KIND OF WERE GONNA CONSIDER, WE PUT THOSE CONDITIONS AS SUB-BULLETS HERE FROM A RELIABILITY RISK STANDPOINT. SO THERE NEEDS TO BE A BALANCED ASSESSMENT. HERE'S THE COST IMPACT, HERE'S THE IMPACT ON RELIABILITY. SO WHEN DETERMINING WHETHER TO GRANT AN EXEMPTION, ERCOT WILL IN ITS SOLE AND REASONABLE DISCRETION GRANT THE EXEMPTION UNLESS ONE OR MORE OF THE CONDITIONS BELOW EXISTS. SO THE RISK POSED BY THE INDIVIDUALLY REQUESTED EXEMPTION AND OR IN AGGREGATE SHOW AN UNACCEPTABLE RELIABILITY RISK. AND VERY SIMILAR TO OUR PRESENTATION, THESE ARE THE ITEMS, INSTABILITY, CASCADING OUTAGES, UNCONTROLLED SEPARATION, LOSS OF GENERATION CAPACITY EQUAL TO OR GREATER THAN 500 LOSS OF LOAD EQUAL TO OR GREATER THAN 75 SAFETY OR DAMAGE TO NEIGHBORING EQUIPMENT, UNKNOWN OR UNVERIFIED LIMITATIONS PHASING WILL JUMP A RATE OF CHANGE OF FREQUENCY TRIP DURING FAULTS. SO WE THINK THAT'S A FRAMEWORK THAT HOPEFULLY PROVIDES SOME TRANSPARENCY ON WHAT ERCOT WOULD CONSIDER ACCEPTABLE OR UNACCEPTABLE. AND IF TAC MEMBERS THINK THOSE NUMBERS NEED TO BE DIFFERENT, WE NEED TO TAKE ON MORE RISK. THAT'S WHAT ERCOT BELIEVES WE WOULD DO IN OUR ASSESSMENT AS FAR AS WHEN IT'S TOO RISKY FOR B, THEY HAD TO HAVE IMPLEMENTED ALL THE FOLLOWING TECHNICALLY FEASIBLE MODIFICATIONS, SOFTWARE FIRMWARE SETTINGS OR PARAMETERIZATION, UH, CHANGES PROTECTION SYSTEM UPGRADES OR REPLACEMENTS, COMMUNICATION UPGRADES, CONTROLLER CARD UPGRADE KITS OR COMPONENT UPGRADES. NOW IF THIS ISN'T THE RIGHT LIST, LET'S DISCUSS IF THAT LIST NEEDS TO CHANGE, BUT WE'RE TRYING TO FIND SOMETHING THAT IT MAKES IT EASIER TO DETERMINE, OKAY, I'VE DONE REASONABLE LEVEL OF LOW COST UPGRADES TO THE EQUIPMENT, THAT GIVES ME SOME SUB SUBSTANTIAL IMPROVEMENT TO BEING ABLE TO RIDE THROUGH. AND FINALLY, IF THEY HAVE NOT IMPLEMENTED A TECHNICALLY [05:10:01] FEASIBLE MODIFICATION WHERE THE COST IS LESS THAN 50% OF THE COST ON A PER INVERTER TURBINE CONVERTER BASIS TO REPLACE IT WITH THE NEW IN KIND. SO ONCE WE GOT THAT LIST, HERE'S THE CRITERIA WE APPLY. SO IF WE SEE SOMETHING THAT WAS ON THAT LIST THAT WAS AVAILABLE AND THEY SHOULD HAVE APPLIED IT BUT THEY DIDN'T, WELL THEN THAT FLAGS IT IF IT'S TOO COSTLY. UM, BUT THEY, IF IT'S UNDER WHATEVER COST THRESHOLD TAX DETERMINES IT'S ON THAT LIST AND THEY DIDN'T IMPLEMENT IT, WE'RE GONNA, IT'S GONNA RAISE THAT FLAG AND WE PUT 50% HERE AND AND LET'S DISCUSS THIS TECH. WHAT DO WE THINK THAT COST THRESHOLD SHOULD BE? I THINK WE ALL AGREE IT SHOULDN'T BE A HUNDRED PERCENT. WE ALL AGREE IT SHOULDN'T BE VERY EXPENSIVE, BUT AT WHAT LEVEL IS THERE A REASONABLE UH, AMOUNT OF PHYSICAL MODIFICATIONS THAT MAYBE ISN'T CONTEMPLATED IN THESE COMMON THINGS BECOMES AVAILABLE BUT IT'S STILL LOW COST AND PROVIDES A LOT OF VALUE. THAT'S WHAT OUR FRAMEWORK APPROACHES AND THIS IS FOR EXEMPTIONS. I'LL PAUSE THERE FOR FOR QUESTIONS. THANKS STEVEN. GO AHEAD CHRIS. SO MY QUESTION WAS ABOVE THAT, AROUND THE DATE, BUT NOT REALLY THE DATE BUT THIS, THE TYPE ONE AND TYPE TWO GENERATORS. YEAH, RIGHT THERE. I GUESS NUMBER TWO. SO I GUESS REMIND ME KIND OF THE VINTAGE YEAR CUTOFFS FOR TYPE ONE AND TYPE TWO WIND GENERATORS. I'M SORRY, CAN YOU SAY THE QUESTION AGAIN? THE VINTAGE, I GUESS WHAT WHAT VINTAGE ARE THOSE? TYPE ONE AND TYPE TWO WIND GENERATORS. SO A TYPE ONE AND A TYPE TWO WIND GENERATION RESOURCE ARE TECHNICALLY NOT INVERTER BASE RESOURCES. THEY ARE ASYNCHRONOUS MACHINES BUT THEY'RE NOT INVERTER BASE. THEY HAVE LIMITATIONS ON WHAT THEY CAN DO AS FAR AS RIDING THROUGH AND AS FAR AS UH, THEIR ABILITY TO CONTROL VOLTAGE AND FREQUENCY. SO THEY ARE PROBABLY THE MOST LIMITED OF ALL TYPES AND MOST LIKELY ALL I WOULD IMAGINE ALL OF THE TYPE ONES AND TYPE TWOS, WHICH IS ABOUT TWO GIGAWATTS WOULD BE APPLYING FOR SOME TYPE OF EXEMPTION. AND, AND SO THEIR INTERCONNECTION AGREEMENT WOULD'VE BEEN BACK IN TIME WAY BACK BEFORE JUNE 1ST, 2023? YEAH, THEY PROBABLY EARLY TWO THOUSANDS. OKAY. WOULD YOU, I GUESS MY THOUGHT WOULD BE TO MAKE IT ADMINISTRATIVELY EASIER INSTEAD OF HAVING THEM APPLY FOR AN EXEMPTION, JUST GIVE THEM AN EXEMPTION IN THE PROTOCOLS. I, I THINK WE'RE, HERE'S THE THING, I THINK WE'RE IN THAT DIRECTION. I THINK WHAT WE'RE TRYING TO FORCE THEM TO DO IS TO MODEL WHAT THEY CAN DO, MAKE SURE THAT THEY HAVE MODELS THAT SAY, OKAY, THIS IS WHAT WE CAN DO AND WHATEVER THEY SAY THEY CAN DO, WE HOLD THEM TO JUST THAT. SO THAT'S WHAT THE PROCESS DOES IF YOU JUST GIVE THEM A BLANKET EXEMPTION WITHOUT THE MODELS AND WITHOUT THAT PIECE WE KIND OF HAVE TO ASSUME WORST CASE THEY'RE JUST GONNA TRIP AND IF WE JUST ASSUME THEY'RE GOING TO, WORST CASE THEY'RE GONNA TRIP, WE MAY BE OVERCONSERVATIVE ON AND MAKE DECISIONS FOR PLANNING AND OPERATIONS THAT MAY NOT REFLECT SOME OF THEIR CAPABILITIES THAT THEY DO HAVE. OKAY. AND THEN ONE FINAL QUESTION. SO, AND THIS MIGHT GET BACK TO THE DISAGREEMENT AND THE CURRENT LANGUAGE WITHOUT THE NORE 2 45, THESE ARE THE ONES THAT WE CALL THAT THEY GOT THE SPECIAL GRANDFATHERING IN PREVIOUSLY IS THAT TO THINK ABOUT IT TYPE ONES AND TYPE TWOS WERE DEFINITELY IN THE FIRST BUCKET OF PRE 2008, BUT THEN THERE'S A LOT OF ADDITIONAL TYPE THREE OLDER WIND TURBINES AND PROBABLY HALF OF THOSE ARE GOING TO NEED SOME TYPE OF EXEMPTION, WHETHER FREQUENCY OR VOLTAGE. BUT TODAY WHERE THEY MAY ARGUE THEY HAVE A FULL EXEMPTION, WHICH MEANS THEY DON'T HAVE TO DO ANYTHING, WHAT WE WOULD DO IN THE FUTURE IS WHAT THEY TELL US THEIR CAPABILITIES ARE, WE WOULD ASK THEM TO MEET THEIR CAPABILITIES. THAT WAY IF THERE'S AN EVENT, THEY HAVE TO RECTIFY IT BACK TO WHAT THEY SAID. AND THAT MAKE MAKES SENSE BECAUSE WE'VE MADE DECISIONS ON WHETHER TO BUILD TRANSMISSION, WE'VE MADE DECISIONS ON LIMITS ALL BASED ON THOSE LIMITATIONS THAT THEY TOLD US. SO IF FOR EXAMPLE, [05:15:01] THEY JUST HAD A FAILURE AND JUST STOPPED, UM, WE MAY HAVE TO BUILD TRANSMISSION THAT TAKES TWO TO THREE YEARS OUT TO COME TO ADDRESS THE DEFICIENCY THAT WE JUST FOUND OUT ABOUT. SO IT'S REALLY IMPORTANT THAT WE GET THE MODELS AND IT'S REALLY IMPORTANT THAT WE HAVE VERIFIED CAPABILITY THAT THEY'RE TELLING US. AND I'LL HOLD JUDGMENT ON THE 50% COST RANGE UNTIL I HEAR FROM SOME OF THE GENERATORS OF WHAT THEY THINK. OKAY. DAVE, THANKS. THIS IS DAVE RY WITHIN GY. UM, JUST A QUICK COMMENT AND THEN, UM, A COUPLE OF QUESTIONS ACTUALLY THAT'S A GOOD FOLLOW UP ON THE KIND OF REPLACEMENT OF THE COMMERCIAL REASONABILITY SECTION. SO I THINK THE COMMENT, YOU KNOW, FROM MY PERSPECTIVE, OUR GOAL HERE IS TO JUST UNDERSTAND WHAT ERCOT IS PROPOSING. I DON'T THINK WE'RE READY TO KIND OF REACT TO RED LINES THAT, YOU KNOW, WE SAW LAST NIGHT. UH, BUT I DO KNOW THAT WE WILL BE WORKING ON RED LINES TO, TO BRING, UM, FOR THE NEXT TAC MEETING. SO I GUESS WITH THAT AGAINST THAT BACKDROP. THE QUESTIONS ON THE KIND OF EXEMPTIONS RELATED TO COMMERCIAL REASONABILITY. THE, THE FIRST GETS RIGHT TO THE COMMENT CHRIS JUST MADE, I GUESS I'M, I'D LIKE TO BETTER UNDERSTAND IF ERCOT COULD EXPLAIN WHAT THE BASIS IS FOR THAT 50% COST THRESHOLD, WHY 50% COST OF A PER TURBINE CONVERTER INVERTER REPLACEMENT. HOW, HOW IS THAT DERIVED IT? IT'S MERELY DRAWING A LINE IN THE MIDDLE OF HIGH AND LOW. SO 50% WAS A STARTING PLACE, UH, FOR DISCUSSIONS AND WE TOTALLY, UH, WOULD LIKE TO HEAR E EVERYBODY'S OPINIONS ON WHAT Y'ALL THINK IS THE APPROPRIATE COST THRESHOLD. AND Y Y'ALL FEEL LIKE THAT'S THE APPROPRIATE THRESHOLD. WHAT DO YOU WANNA JUMP IN? YEAH, IN RETROSPECT, UH, WE SHOULD HAVE PUT X IN THERE INSTEAD OF 50%. IT'S MEANT AS A PLACEHOLDER. SO DON'T GET HUNG UP ON THE 50% RYAN. IT'S NOT MEANT AS A NUMBER. IT'S MEANT AS A PLACEHOLDER FOR A NUMBER FOR T TO DECIDE. ONE THING I'D LIKE TO JUST KIND OF JUMP IN AND, I MEAN, WE'RE TALKING ABOUT HIGH LEVEL RIGHT NOW, AND I KNOW THIS IS STUFF THAT HASN'T BEEN OUT FOR, IT'S BEEN OUT FOR LESS THAN 24 HOURS. BUT I I, TO THE EXTENT WE CAN ALIGN ON, YOU KNOW, EVEN THE STRUCTURE OF WHAT WE'VE GOT IN THE NORE AND IF THE, YOU KNOW, THE CONTENT UNDER HERE FOR, FOR WHAT POSES A RELIABILITY RISK OR WHAT, WHAT QUALIFIES FOR AN EXCEPTION, IF WE NEED TO REALLY WORK ON THOSE FROM A, FROM A WORDSMITHING STANDPOINT, IF WE CAN ALIGN ON STRUCTURE SO THAT WE DON'T GET INTO ANOTHER SITUATION WHERE WE'VE GOT TOTALLY, YOU KNOW, FOREIGN LANGUAGES THAT WE'RE TRYING TO RECONCILE A WEEK FROM NOW, FROM A COMMENT STANDPOINT, I'D, I'D LIKE TO AVOID THAT. SO, SORRY DAVE, GO AHEAD. NO, THAT, THANKS COLIN. TWO FOLLOW UP QUESTIONS ON THAT, AND I APPRECIATE THE CLARIFICATION. I GUESS STRUCTURALLY, RIGHT? ERCOT NOW IS, AND THIS IS A LITTLE DIFFERENT THAN I UNDERSTOOD IT IN THEIR SLIDES. THEY HAVE, UM, CAN YOU GO BACK UP, SORRY, TO THE, OR I SUPPOSE IT'S DOWN TO B AND C ON THE SCREEN. SO NOW THERE'S A SECTION THAT SAYS, WELL, YOU NEED TO DO THIS IRRESPECTIVE OF COST, RIGHT? WHICH INCLUDES THINGS LIKE COMMUNICATION UPGRADES, WHICH DEPENDING ON WHAT THAT MEANS COULD BE ENORMOUSLY EXPENSIVE. UM, AND THEN THERE'S A SECTION C, WHICH HAS RIGHT X PERCENT COST CAP. AND SO THE, MY SECOND QUESTION OF THE THREE IS, IS IT REALLY ERCOT? I GUESS WHY, WHY IS ERCOT NOT SUBJECTING EVERYTHING OTHER THAN SOFTWARE FIRMWARE SETTINGS AND PARAMETERIZATION TO THE COST CAP? WHY HAVE AN ENUMERATED SET OF THINGS THAT HAVE TO HAPPEN KIND OF IRRESPECTIVE OF COST? I THINK WE WANTED TRANSPARENCY FOR TECH MEMBERSHIP IN THAT THESE ARE THE TYPES OF THINGS THAT WE HAVE HEARD, UH, COULD BE SOLUTIONS WHERE THERE ARE CHALLENGES OR THAT HAVE BEEN DONE, UH, BY SOME ENTITIES TO COME INTO COMPLIANCE. AND SO, UH, IF THERE THIS, IF SOME OF THESE ITEMS NEED TO BE UNDER A COST THRESHOLD, I THINK LET'S DISCUSS THAT AND LET'S TALK ABOUT THAT. IF SOME OF THESE ITEMS SHOULD ALWAYS, AND EVERYBODY AGREES THEY'RE LOW COST ENOUGH THAT YOU SHOULD BE ABLE TO CHANGE OUT A, A MULTIFUNCTION DIGITAL RELAY, THEN LET'S INCLUDE THAT. AND THEN IT TAKES OUT LESS ISSUES WHERE WE MAY BE CONTESTING AND, AND SENDING IT ON TO THE COMMISSION AS WHAT WE TOOK AWAY FROM SOME OF THEIR FEEDBACK IS THAT THEY DIDN'T WANT A LOT OF THAT. SO WHERE WE CAN PUT CLARITY, WE WANT TO DO THAT WHERE IT'S APPROPRIATE TO PUT IT UNDER A COST THRESHOLD. I THINK WE'RE OPEN TO DISCUSSING THAT FOR SURE. OKAY. AND, AND AS I SAID, I MEAN WHEN I'M NOT READY TO COMMIT TO TO THAT STRUCTURE, BUT I GUESS I'M TRYING YOU, IF [05:20:01] YOU HAVE A COST CAP, THEN IT WOULD SEEM THAT EVERYTHING WOULD FALL UNDER THE COST CAP. I GUESS I, I DON'T SEE ANY KIND OF ADDITIONAL BENEFIT FROM LISTING THINGS OUT THAT COULD CONCEIVABLY PIERCE THAT CAP. IF IT'S TRULY INEXPENSIVE, UM, AS RK IS SAYING IT IS, THEN IT WOULD BE PRESUMABLY UNDER THE CAP, I GUESS. AND THAT BRINGS ME TO MY LAST QUESTION, WHICH I DID HEAR, RIGHT? IT'S MAYBE IT'S NOT 50%, IT'S X AND YOU'RE LOOKING FOR TAX INPUT. I GUESS IT'S A HYPOTHETICAL, IF PAC SAID WE THINK 5% IS THE RIGHT NUMBER, IS ERCOT GOING TO OPPOSE THAT OR WOULD THEY GO WITH WHATEVER TAX RECOMMENDATION IS? I THINK WE'D HAVE TO SEE WHAT Y'ALL END UP KIND OF EQUATING THE 5% AND THEN WHAT Y'ALL THINK WOULD BE INCLUDED OR NOT INCLUDED, UH, TO MAKE THAT KIND OF DETERMINATION. AND THEN I THINK OBVIOUSLY IF TAC DECIDED TO GO WITH, UH, A VALUE THAT DIDN'T INCLUDE CERTAIN THINGS THAT PROVIDED A LOT OF RELIABILITY BENEFIT, I THINK TAC WOULD JUST NEED TO KIND OF DISCUSS THAT IN THEIR COMMENTS TO THE BOARD POSTING. UH, BUT LET'S UNDERSTAND WHERE Y'ALL THINK THAT IS, WHAT TYPES OF PHYSICAL IMPROVEMENTS Y'ALL THINK WOULD BE INCLUDED UNDER WHATEVER NUMBER IS PROPOSED. AND I THINK THAT'LL GIVE MORE CLARITY. RIGHT, AND I, LIKE I SAID, WE'RE LOOKING JUST TO UNDERSTAND THE PROPOSAL, NOT NECESSARILY TO REACT TO IT OR AGREE TO TO STRUCTURE HERE. JUST CLARIFICATION. I SEE THERE'S A BUNCH OF PEOPLE IN THE COMMENT QUEUE, SO I WILL WAIT FOR SOME OF THE OTHER QUESTIONS ON SOME OF THE OTHER ITEMS YOU HAVE UNDER THIS SECTION AND COME BACK AFTER. OTHER FOLKS HAVE HAD A CHANCE. THANKS ERIC. UM, JUST TO GET TO THE POINT EARLIER OF, UH, 50% VERSUS 5% VERSUS SOMETHING ELSE, I UNDERSTAND THAT ER HAD, HAS STATED THAT, YOU KNOW, THIS IS NOT NECESSARILY TO NEGOTIATE WITH THE JOINT COMMENTERS, BUT TO GIVE, MAKE TACK EXPRESS AN OPINION. AND THE, THE FACT THAT IT'S SO DIFFICULT TO DETERMINE, YOU KNOW, WHAT IS AN APPROPRIATE LEVEL OF SPEND IS WHY THE COMMERCIAL REASONABILITY APPROACH WAS INITIALLY SUGGESTED. UM, AND TO GET RID OF IT AND, AND CREATE, YOU KNOW, SOMETHING THAT IS INHERENTLY ARBITRARY WILL, UM, NOT NECESSARILY BE LESS COMPLICATED. IT'LL LEAD TO MORE DISPUTES WHEN SOMETHING THAT DOESN'T CROSS THAT THRESHOLD BUT IS IN REALITY TOO EXPENSIVE, IS DISPUTED AT THE COMMISSION. SO IT WON'T, IT WON'T LEAD TO FEWER DISPUTES, IT JUST WILL LEAD TO ARBITRARY OUTCOMES. SO THE COMMERCIAL REASONABILITY APPROACH, IT SAYS YOU HAVE TO JUSTIFY WHY YOU THINK SOMETHING IS OR IS NOT COST EFFECTIVE. AND IF ERCOT FEELS THAT YOU DON'T HAVE SUFFICIENT EVIDENCE FOR THAT, THEN YOU END UP AT THE COMMISSION WITH A DENIED, UM, A DENIED EXEMPTION. SO I HOPE THAT TAC IS REMINDED OF WHY, UH, THAT WAS INITIALLY IN THE TAC RECOMMENDATION AND THINK THROUGH THE IMPLICATIONS OF AN ARBITRARY CUTOFF HERE. THANKS, BOB. ACTUALLY EVERYTHING HAS BEEN SAID THAT I WAS GONNA SAY, SO I'LL SAVE US SOME TIME. THANK YOU, ROBERT. HEY, THIS IS ROBERT. I JUST WANTED TO KNOW HOW LONG WERE THE EXEMPTIONS GONNA LAST, UH, FOR A TYPE TWO GENERATOR? YEAH, SO, UH, I THINK THAT'S A GOOD SEGUE INTO ANOTHER SECTION, UM, WHERE AT LEAST CONCEPTUALLY ERCOT IS PROPOSING A REVIEW CONCEPT. SO, UH, FOR, FOR TYPE ONE AND TYPE TWO, FIRST AND FOREMOST, IF YOU GET AN EXEMPTION SO LONG AS SOMETHING DOESN'T CHANGE TO WHERE NOW THERE IS A RELIABILITY RISK THAT WAS PREVIOUSLY UNDISCLOSED OR NOT MODELED APPROPRIATELY, UM, YOU WOULD CONTINUE TO HAVE THAT EXEMPTION UNTIL YOU DECIDED TO CEASE OPERATIONS. UH, I'M NOT AWARE OF ANY KIND OF RETROFIT OR REPOWERS FOR THOSE, BUT UH, EVEN THE LANGUAGE THAT'S PROPOSED, UH, DOESN'T CONTEMPLATE FOR TYPE ONES AND TYPE TWOS TO EVER HAVE TO MEET THE PREFERRED VOLTAGE REQUIREMENTS OR IEEE 2,800 JULIANA. THANK YOU. UM, STEVEN, UNDER ERCO T'S PROPOSAL, UH, WHAT WOULD HAPPEN IF A TYPE TWO WGR CANNOT MEET CERTAIN REQUIREMENTS PROPERLY IDENTIFIES THE LIMITATIONS IN A MODEL, MAKES HARDWARE UPGRADES UNDER A COST THRESHOLD, AND THEN ERCOT DOES A RELIABILITY ASSESSMENT AND DETERMINES THAT THE IBR [05:25:01] POSES AN UNREASONABLE RISK OF RELIABILITY. SO I'M GONNA TRY TO REPEAT BACK AND CORRECT ME WHERE I WENT. WHERE IF I, IF I'M WRONG, SO A TYPE TWO, SO THIS IS HYPOTHETICAL, RIGHT? 'CAUSE THERE'S NO TYPE TWO RETROFIT REPOWER, ANYTHING THAT I KNOW OF, RIGHT? AND IT WOULD BE IMPRACTICAL FOR ANYBODY TO REPOWER OR RETROFIT A TYPE TWO, UM, I'M ASSUMING, RIGHT? OKAY. SO A HYPOTHETICAL TYPE TWO DOES SOME TYPE OF REINVESTMENT TO TRY TO IMPROVE PERFORMANCE THAT IS NOT COST PROHIBITIVE, RIGHT? WELL, THE UNDER THE THRESHOLD, WHATEVER THE THRESHOLD TAX DETERMINES IT, I GUESS I THINK IT WOULD BE ARGUABLE WHETHER IT'S OKAY AND, AND YOU COME AND THEN ALL OF A SUDDEN IT MEETS ONE OF THESE CRITERIA THAT IT IS, UM, SHOWING TO BE PART OF AN UNRELIABLE, UM, OUTCOME FOR THE ERCOT INTERCONNECTION. YES, WE WOULD, WE WOULD DENY THAT EXEMPTION REQUEST. SO IS, ISN'T THAT POSSIBLY PUTTING THE CART BEFORE THE HORSE FOR, FOR THOSE IVRS THAT NEED WOULD NEED TO MAKE HARDWARE UPGRADES? PERHAPS ERCOT SHOULD DO THE RE RELIABILITY ANALYSIS PRIOR TO REQUIRING THOSE IBR TO DO THOSE UPGRADES. SO PART OF THE SOFTWARE MAXIMIZATION IS GETTING THE MODELS CORRECTED AND UPDATED. AND THAT'S WHY ERCOT HAS SUPPORTED THAT, IS BECAUSE WHEN WE GET THOSE MODELS UPDATED AND CAN DO AN ACCURATE ASSESSMENT, THEN WE'RE ABLE TO DO THAT TYPE OF IMPACT, THAT RELIABILITY IMPACT PRIOR TO THAT THEY'RE UNRELIABLE MODELS AND WE CAN'T, WE CAN'T GIVE YOU ANY KIND OF, UH, ACCURATE REPRESENTATION OF THE IMPACT ON THE SYSTEM. BUT AT AT LEAST FOR THOSE VINTAGE IBR, GIVEN THE THE PROPOSED DEADLINE TO REQUEST AN EXEMPTION, IT SEEMS THAT IT MIGHT BE POSSIBLE THAT THE IBR WON'T KNOW IF IT NEEDS TO REQUEST ONE. SO THE, FOR A TYPE TWO, I'M PRETTY SURE, AND, AND MAYBE I'M MISSING SOMETHING, YOU'RE GONNA NOT BE ABLE TO MEET THE LEGACY REQUIREMENTS. AND SO FOR A TYPE TWO, I'M ASSUMING YOU'RE GOING TO APPLY FOR AN EXEMPTION AND YOU'RE VERY FAVORABLE TO GET ONE BECAUSE THERE'S PROBABLY NOT MANY, IF ANY TECHNICALLY FEASIBLE UPGRADES THAT YOU CAN MAKE. AND SO WHEN YOU APPLY THAT TO A TYPE TWO, THE ONLY WAY WE'RE GOING TO DENY IT IS IF WE SEE THAT THERE IS AN UNACCEPTABLE RELIABILITY RISK TO ERCOT AND WE, WE, WE CAN'T ACCEPT THAT. YEAH, AND THIS IS CHAD. I JUST WANT, I MEAN, THERE'S A LOT OF HYPOTHETICALS THAT YOU CAN ASK STEVEN, AND WE CAN GIVE KINDA INITIAL THOUGHTS ON THAT, BUT REALLY THE FOCUS HERE IS CONSISTENT WITH THE WORKSHOP DISCUSSION ON THE FRAMEWORK OF HOW WE SEE THE EXEMPTION PROCESS. SO I THINK TO ME, THE, THE VALUE TO TAC IS LOOKING AT THE FRAMEWORK AND, AND MAKING SURE THAT YOU ASK ALL THE QUESTIONS YOU NEED TO UNDERSTAND THE FRAMEWORK BECAUSE THIS IS WHERE THE WORKSHOP WAS WHERE WE LAID OUT, YOU KNOW, THE SCENARIOS THAT WE SEE WHERE WE WOULD NOT BE ABLE TO, UH, GIVE AN EXEMPTION WHEN IT HAS THESE SIGNIFICANT RELIABILITY ISSUES. STEVEN'S KIND OF WALKED THROUGH SOME OF THE OTHER THINGS THAT WE WELCOME TAX FEEDBACK TO, UM, ROLL THAT INTO THE OVERALL EXEMPTION FRAMEWORK, BUT ASKING KIND OF WHAT IF HYPOTHETICALS AND ALL THAT UNTIL WE KNOW ALL THE EXEMPTIONS COME IN AND LOOK AT IT FROM A SYSTEM PERSPECTIVE AND APPLY THE RELIABILITY ASSESSMENT. THEY'RE ALL JUST HYPOTHETICALS AT THIS POINT. SO IT'S MORE ABOUT THE POLICY AND THE FRAMEWORK AND IS IS THIS HIT THE MARK FOR WHAT ERCOT WAS TALKING TO TACK ABOUT AT THE LAST WORKSHOP AND WHERE CAN WE IMPROVE ON THIS FRAMEWORK? THANKS, CHAD. ARE WE GOOD ON THAT QUESTION? YEAH, I'M GOOD. THANKS. OKAY, RYAN? YEAH, I JUST HAD A COUPLE QUESTIONS. UM, FIRST IS STRAIGHTFORWARD. I'M, YOU KNOW, THERE'S A, A SET OF OBJECTIVE CRITERIA LISTED OUT IN ALL THE SECTIONS THERE, SO KIND OF CURIOUS WHY THE, YOU KNOW, THE, THE, YOU KNOW, I DON'T HAVE A BETTER CHOICE OF WORDS. SO WHY THE SORT OF INFLAMMATORY LANGUAGE OF IN THE SOLE DISCRETION OF ERCOT IS USED WHEN IT'S BASED ON AN OBJECTIVE SET OF CRITERIA EXCEPT FOR THE COST PIECE, RIGHT? SO JUST [05:30:01] WOULD LOVE TO GET YOUR THOUGHTS ON LIKE, YOU KNOW, THAT STANDS OUT VERY BLATANTLY WHEN YOU READ IT IN THE FIRST PASS GOING, OKAY, YOU'VE GOT BULLETS HERE OF A SET OF CRITERIA I NEED TO CONSIDER, BUT THEN YOU'VE GOT, BUT IT'S SOLELY UP TO ERCOT TO MAKE THEIR OWN DECISIONS. WELL, I WOULD JUST SAY IN LEGAL, Y'ALL CAN, MY LEGAL TEAM PLEASE CHAD, UH, OR ANDY SPEAK UP. BUT ESSENTIALLY THAT'S LANGUAGE THAT'S USED THROUGHOUT THE PROTOCOLS AND OPERATING GUIDES. IT'S COMMON LANGUAGE WHERE ERCOT IS TO MAKE THE DETERMINATION AND THE DECISION AND THE SOLE AND REASONABLE IS TO PUT SOME TYPE OF REASONABILITY CONSTRAINTS ON ERCOT SO THAT THEY CAN'T BE UNREASONABLE IN ANY TYPE OF DECISION MAKING. OKAY. YEAH, IT'S SEEMS LIKE IT'S REGULATORY UNCERTAINTY LIKE THAT LANGUAGE IS THE TYPE OF LANGUAGE IS NOT USED IN, IF WE CAN JUST FOCUS ON THAT. I I SOME OF OUR CONCERN THAT WE EXPRESSED AT THE BOARD MEETING SPECIFICALLY AROUND THAT PHRASE IS IF IT'S THE STANDARD OF REVIEW IS ERCO T'S SOLE AND REASONABLE JUDGMENT, WHAT STANDARD OF EVIDENCE WOULD THE COMMISSION BE ABLE TO APPLY TO OVERTURN ERCO T'S SOLE JUDGMENT? SO WE THINK THAT'S A PROBLEM. SO I MEAN, THE COMMISSION HAS COMPLETE AUTHORITY OVER ERCOT AND WE DO USE THIS PHRASE SOLE DISCRETION THROUGHOUT THE PROTOCOLS IN MANY PLACES, UHHUH, AND THE COMMISSION AT ANY POINT THROUGH A CONTESTED CASE OR RULEMAKING OR OTHERWISE CAN CHANGE THAT OUTCOME. I THINK WE ALL KNOW THAT. SO, SO AND SO, I GUESS MY CONCERN IS WHAT IS THE CONCERN WITH USING THE WORD SOLE DIS DISCRETION OF ERCOT WHERE WE'VE USED IT IN MANY OTHER SCENARIOS? ARE YOU FROM, ARE YOU AWARE OF A CASE WHERE THE COMMISSION HAS OVERTURNED SOMETHING THAT WAS ERCOT SOLE JUDGMENT? WHEN WHEN INDIVIDUALS FILE COMPLAINTS AGAINST ERCOT FROM THE A DR PROCESS, WE MAKE A DETERMINATION ON OUR SOLE JUDGMENT ON WHETHER WE BELIEVE WE APPLIED THE PROTOCOLS CORRECTLY OR NOT. AND THE COMMISSION THEN HAS THE RIGHT TO DECIDE WHETHER THAT WAS CORRECT OR NOT. EVERYTHING IS THAT WAY. AND IN THE, UM, AND I GUESS, YOU KNOW, I THINK A OR I THINK IT'S FOUR A IS VERY CONSISTENT WITH WHAT WE LAID OUT IN THE PRESENTATION AND STEVEN'S KIND OF ALREADY HIGHLIGHTED FOUR B AND FOUR C WHERE I THINK WE'RE OPEN TO HOWEVER TAC WANTS TO FRAME THOSE ISSUES UP TO GIVE ERCOT MORE GUIDANCE ON HOW IT SHOULD DO ITS OVERALL RELIABILITY ASSESSMENT. OKAY. THAT WAS PART OF MY FOLLOW UP QUESTION ON, ON THE A SECTION WHERE YOU'VE GOT THESE THRESHOLDS OF, YOU KNOW, SO JUST TAKE A, I I, FOR EXAMPLE, THE 500 MEGAWATTS NOT GONNA GET INTO THE, THE MEGAWATT QUANTITY ITSELF. STEVEN, CAN YOU TALK TO HOW YOU WOULD QUANTIFY THAT? SO SAY, SAY I'M A A, A LEGACY RESOURCE WITH AN EXEMPTION TODAY TO A PORTION OF THE CURVE, RIGHT? I, MY TURBINE DOESN'T MEET THE FREQUENCY RIDE THROUGH CURVE OUT AT 500 SECONDS, BUT I MEET EVERYTHING ELSE. ARE YOU GONNA RUN A SIMULATION OUT TO 500 SECONDS AND THEN LOOK AT THE RISK, OR ARE YOU JUST GONNA ADD UP THAT QUANTITY AND SAY, THAT'S PART OF THE BUCKET OF 500? HOW ARE YOU GONNA ASSESS EACH OF THE NUANCED CASES OF EXEMPTIONS? WE'RE, WE'RE GONNA APPLY THE SAME TYPE OF, UH, STUDY CRITERIA THAT WE DO FOR PLANNING ASSESSMENTS AND ALL OTHER SOL EXCEEDANCE G-R-Q-S-A ASSESSMENTS, WE DON'T GO OUT TO 500 SECONDS. I MEAN, THAT'S UNREASONABLE AND THAT'S BEYOND THE CURVES OF COURSE. SO YOU'RE NOT GONNA APPLY THE M THE MQT TYPE STUDIES. UM, WE'RE GONNA DO SOME LEVEL OF MQT TO MAKE SURE THAT THE MODELING IS ACCURATE, YOU KNOW, WE'LL DO WELL YEAH, NO, MAKE, SAY THE MODELS ARE GOOD. YEAH. BUT IF I RUN AN FRT STUDY AND I'VE GOT A 502ND, I NEED AN EXEMPTION FOR OUT AT 300 SECONDS, 200 SECONDS, 500 SECONDS, WHATEVER, I'M WAY OUTSIDE THE SCOPE OF ANY ACTUAL RELIABILITY STUDY. I MEAN, AM I GONNA BE BUCKETED IN THE 500 THERE FOR, FOR FREQUENCY, RIGHT? THAT'S GONNA BE A DIFFERENT ASSESSMENT AND FREQUENCIES. IT'S PROBABLY GONNA GO THROUGH FINE. 'CAUSE THE ONLY ISSUES WE'VE BEEN MADE AWARE FROM IS ONE PARTICULAR OEM THAT CAN ONLY GO TO 10 INSTEAD OF 30 SECONDS. AND WE'VE ALLOWED EXEMPTIONS, EVEN THOUGH FERC ORDER 9 0 1 ISN'T ALLOWING IT, EVEN THOUGH NERC SO FAR IN PRC 29 IS NOT ALLOWING IT. WE HAVE LISTENED TO STAKEHOLDER FEEDBACK AND OEM FEEDBACK HERE AND WE HAVE AT LEAST PROPOSED TO ALLOW EXEMPTIONS FOR FREQUENCY RIDE THROUGH SHORTCOMINGS FOR THE OLDEST TYPE THREE WGS ON, ON THAT QUESTION. SO OLD, YOU KNOW, LEGACY WT YOU KNOW, [05:35:02] THERE'S THAT CONCERN THOUGH. OKAY, IF I'VE GOT A RESOURCE AND I'M, I, DO WE ALLOW LEG, DO WE ALLOW EXEMPTIONS FOR LEGACY FRT IN HERE? I THOUGHT IT WASN'T INCLUDED. YES. OKAY. SO WHAT HAPPENS IF I REPOWER MY LEGACY RESOURCE, BUT I'M ONLY CHANGING BLADES IF THEY MAKE THAT CHANGE BEFORE 2028? THEY ARE NOT SUBJECT TO THE HIGHER REQUIREMENTS FROM A VOLTAGE STANDPOINT TODAY, LEGACY OR NEW? IT'S ALL THE SAME FRT CURVES FROM, FROM A VOLTAGE STANDPOINT. SO THEY GET THE, THEY GET THE EXISTING LEGACY FRT EXEMPTION IF THEY GO FORWARD TO THE NEW YEAH, THEY, THEY WOULD STILL KEEP THEIR EXEMPTION IF COULD BECAUSE IT'S VOLTAGE THAT THEY HAVE THE 2 9 1 1 AND IEEE 2,800. OKAY. OKAY. THANK YOU. WE'RE HOPING, YOU KNOW, ALONG THE LINES WITH WHAT CHAD SAID, WHO I DO AGREE WITH, I HOPING TO MOVE AROUND, MOVE KIND OF POLICY DECISIONS ALONG AND AND DISCUSS POLICY. YOU KNOW, I, I UNDERSTAND THE CONSEQUENCES ARE VERY IMPORTANT, BUT I THINK LEGAL HYPOTHETICALS THAT, THAT, YOU KNOW, CAUSE SPECULATION THAT COULD BE USED IN LEGAL CASES IS NOT PRODUCTIVE WHEN WE HAVEN'T MADE DECISIONS AMONG TAC MEMBERS. UM, YOU KNOW, WE DO HAVE THE ABILITY TO TAKE STRAW HOLES, SO IF A ATTACK MEMBER WANTS TO MAKE A MOTION TO SEE HOW WE FEEL ON A SET OF WORDS OR A CONCEPT THAT, THAT'S KIND OF HOW I WOULD SUGGEST RESOLVING SOME OF THIS AT THIS POINT. BUT I, I REALLY WANT US TO MOVE FORWARD WITH POLICY DECISIONS BECAUSE WE, WE DO HAVE LIMITED TIME. YOU KNOW, WE, WE'VE SPENT TWO AND A HALF HOURS TODAY, SEVEN HOURS AT THE LAST MEETING AND, AND I, I DON'T KNOW IF WE HAVE ANOTHER NINE HOURS BEFORE THE THE JUNE BOARD MEETING. SO I'D LIKE TO ADVANCE KIND OF THE POLICY, SAVE THE, THE LEGAL SPECULATION AND, AND YOU KNOW, SEE WHAT MEMBERS WANT TO, TO VOTE ON OR PULL ON TODAY. DAVE. THANKS CAITLIN. UM, SO RETURNING TO SOME OF THE MAJOR ISSUES THAT ERCOT FLAG THAT I THINK ARE BEFORE TAC, THERE'S THE QUESTION OF WHEN THE, WHAT THE RIGHT KIND OF SGIA DATE IS FOR NEW RIGHT NARCOS PROPOSING THE 6 1 23. MY QUESTION, UH, THE GENERAL QUESTION, AND THEN THERE'S A SLIGHTLY MORE SPECIFIC ONE IS I BELIEVE ERCOT WAS JUST REFERRING TO A CASE WHERE SGIS AFTER THAT DATE WOULD STILL QUALIFY FOR EXEMPTIONS. AND I GUESS MY QUESTION IS, CAN YOU ELABORATE ON, UM, I GUESS THE, UH, LIMIT TO THOSE EXEMPTIONS BEYOND SOME OF THE THINGS WE'VE ALREADY DISCUSSED? BECAUSE MY UNDERSTANDING FROM, AGAIN, READING THIS LAST NIGHT WAS THAT YOU CAN ONLY GET AN EXEMPTION AFTER THAT DATE FROM PORTIONS OF THE IEE REQUIREMENTS. ANYTHING ELSE WOULD BE AN EXTENSION. AND IF I AM MISUNDERSTANDING T'S PROPOSAL, I GUESS I'D LIKE CLARIFICATION THERE. THIS IS STEVEN SLE WITH ERCOT. I'M, I'M A LITTLE CONFUSED DAVE, SO PLEASE HELP, HELP GUIDE ME. BUT, UM, THE CONCEPT AND THE STRUCTURE HAS NOT CHANGED IN THAT YOU HAVE TO MAKE ALL OF YOUR, UH, SOFTWARE CHANGES. YOU HAVE TO MAXIMIZE BY 2025 FOR, FOR LEGACY, LEGACY BEING DEFINED BY WHATEVER DATE TACK ULTIMATELY DECIDES TO ENDORSE AS THE CUTOFF BETWEEN LEGACY AND NEW. AND IF YOU CANNOT MAKE THE 2025 DATE, BUT YOU JUST NEED AN EXTENSION, YOU CAN GET AN EXTENSION UP TO THE END OF 2027. IF YOU KNOW THAT AN EXTENSION DOESN'T DO ANYTHING FOR YOU, IT'S NOT A MATTER OF TIME, YOU JUST DON'T HAVE ANY OPTIONS, THEN YOU HAVE TO APPLY FOR THE EXEMPTION BY FEBRUARY 1ST, 2025 BECAUSE YOU HAVE ALREADY EVALUATED AND YOU KNOW THAT THERE'S NOTHING FOR YOU TO BE ABLE TO DO. DOES THAT ANSWER YOUR QUESTION, DAVE? LET, LET ME BE MORE SPECIFIC. SO I'M LOOKING ON THE SCREEN AT ITEM NUMBER TWO, THE SECOND SENTENCE, RIGHT? SGIA DATED ON OR AFTER ERCOT PROPOSED DATE, COD BEFORE THE END OF 26, EXEMPTION REQUESTS MUST BE SUBMITTED TO ERCOT ON OR BEFORE THAT DATE. IS THAT AN EXEMPTION FOR THE FULL RANGE OF THE REQUIREMENTS OR IS IT ONLY EX MEANING THE PREFERRED VRT REQUIREMENTS, UM, AND FRT? OR IS IT ONLY FOR A SUBSET OF THOSE REQUIREMENTS THAT ARE COS CONSIDERING AN EXEMPTION FOR? SO FOR JUNE 1ST, UH, IF, IF YOU HAVE AN SGIA AFTER JUNE 1ST, 2023, WE'RE ASSUMING THAT'S THE [05:40:01] NEW VERSUS LEGACY CUTOFF. THEN THERE'S OTHER LANGUAGE THAT IS ALREADY IN THE TAC APPROVED VERSION THAT YOU CAN GET AN EXEMPTION SO LONG AS YOUR COMMERCIAL OPERATIONS DATE IS BEFORE DECEMBER 31ST, 2026. SO FOR NEW IBR COMING IN THAT ARE NOT YET COMMERCIAL OR HAVE AN SGIA AFTER 6 1 23, THAT IS THE PROVISION OR WINDOW FOR THEM. THEY HAVE A LONGER WINDOW BECAUSE SOME OF THEM ARE GOING TO BE CONNECTING THROUGHOUT 2025 INTO 2026. OKAY. AND THEN THE LAST ITEM RELATED TO THIS IS THERE, THERE'S A PROVISION IN 2 9 1 7 THAT RESTRICTS CERTAIN EXEMPTIONS FOR LET'S SAY NEW IBR, WHEREVER THAT DATE IS DRAWN, UH, FOR THE EXEMPTION ONLY TO APPLY TO THE IEEE SECTIONS FIVE, SEVEN, AND NINE AND NOTHING ELSE. IS IT YOUR UNDERSTANDING THAT THAT'S NOT A LIMITING FACTOR HERE YOU CAN APPLY FOR AN EXEMPTION FOR ANYTHING IN OUR COS PROPOSAL? I, I NEED TO GO THROUGH AND LOOK AT THAT LANGUAGE. DO Y'ALL WANT ME TO GO REVISIT THAT LANGUAGE? I DON'T, WE DON'T NEED TO SIDETRACK. UH, I MEAN I'M, WE'RE HAPPY TO TAKE THAT OFFLINE, BUT I THINK IT'S A CRITICAL POINT AS WE CONSIDER, YOU KNOW, I MEAN, I GUESS TAC CONSIDERS THE DATE HERE. I'M MORE THAN WILLING TO INVESTIGATE THAT. I JUST WANT TO MAKE SURE THAT'S APPROPRIATE USE OF TIME. OKAY, THANKS. OKAY, CHRIS, I HAVE ONE QUESTION AND I'LL TRY TO, OOPS, I HAVE ONE QUESTION AND THEN I'LL TRY TO MOVE YOU ALONG AND SEE IF WE COULD DO A STRAW POLL. SO IN FOUR A IN THE UNACCEPTABLE PORTION, THERE'S A, SOME CLAUSE IN THERE IT SAYS R IN AGGREGATE. SO EXPLAIN TO ME A LITTLE BIT WHAT YOU MEAN BY THAT. SO WHEN WE GET AN INDIVIDUAL EXEMPTION REQUEST, IN OUR MINDS WE'RE THINKING WE'RE GONNA DO A VERY SIMPLISTIC ASSESSMENT FIRST, WHICH IS, I TAKE THEIR MODEL, I APPLY A FAULT NEARBY, WHAT HAPPENS TO THE SYSTEM WITH JUST THAT ONE UNIT RIGHT NOW, IMAGINE WE GET A HUNDRED EXEMPTION REQUESTS, ALL WITH NEW MODELS AND WE GET, WE'RE GETTING ANOTHER THREE TO 400 NEW MODELS OF ENTITIES MAXIMIZING THEIR CAPABILITY. WE NEED TO THEN GET ALL OF THOSE MODELS TOGETHER AND RUN AN ASSESSMENT OF IF I APPLY A FAULT, HOW, WHAT DOES IT LOOK LIKE NOW WITH EVERYBODY'S UPDATED MODELS? SO THAT'S THE INDIVIDUAL LOOK FIRST AND THEN THE AGGREGATE SYSTEM IMPACT STUDY. OKAY. IT'S BEEN A LONG TIME SINCE WE'VE DONE A STRAW POLL. SO I GUESS WHAT IS, HOW ARE WE GONNA DO ABOUT THIS PROCESS? HOW DOES IT WORK? ANN HAS INSTRUCTIONS. GOOD, BUT YOU, YOU ARE, YOU HAVE TO COME UP WITH THE STRAW POLL QUESTION. OH, SO THE STRAW POLL QUESTION IS FOR THE IMPLEMENTATION DATE, HAVE IT BE 30 DAYS AFTER APPROVAL BY THE PUC. WOULD YOU LIKE TO ADD ON TO THE STRAW POLL THAT WE ARE NOW EXPECTING TO INCLUDE MAXIMUM REQUIREMENTS UP TO YOUR MAXIMUM CAPABILITIES? SURE. OKAY. ARE YOU READY FOR ANN ANN'S IN CHARGE? SO FOR STROP ONLY, WE'RE ONLY GONNA TAKE OPPOSING VOTES AND IF YOU DON'T RAISE YOUR CARD OR PUT IN THE CHAT THAT YOU'RE OPPOSED, DON'T DO BOTH. IF YOU'RE , SO EITHER PUT IN THE CHAT AND ONLY TACK VOTING MEMBERS PLEASE IF YOU'RE OPPOSED TO IT OR RAISE YOUR CARD IF YOU'RE OPPOSED TO IT. IF SOMEBODY COULD RESTATE WHAT THE STRAW POLL IS. I GOT THE 30 DAYS IMPLEMENTATION, 30 DAYS AFTER PC APPROVAL AND THE MAXIMUM CAPABILITIES PIECE, CHRIS, ON THE MAXIMUM CAPABILITIES, I MEAN, DOES THAT, THAT APPLIES TO EVERYTHING HISTORICAL. SO FOR, FOR CLARITY, DO YOU WANT TO MAYBE CONSIDER BREAKING IT APART? BECAUSE I THINK, I THINK THE MORE, IT SEEMED LIKE MAXIMUM EQUIPMENT CAPABILITIES WE WERE MORE IN CONSENSUS ON, BUT IF THE ISSUE THAT'S AT HAND IS DO WE WANT THE PREFERRED REQUIREMENTS AND IEEE 2,800 REQUIREMENTS TO BECOME, UH, EFFECTIVE FOR S GIA 30 DAYS AFTER PUCT APPROVAL? IF THAT'S THE, THE QUESTION MAY BE GOOD TO CLARIFY. OKAY. WE, WE CAN BREAK 'EM APART. LET'S DO THE MAXIMUM CAPABILITIES PULLED THOUGH FIRST. SORRY, CHRIS. OKAY. I GUESS I, DO YOU WANNA WRAP UP THE QUEUE FIRST OR, I HAD A QUESTION ON PROCESS [05:45:01] OF THIS. SURE, DAVID. SO WE ARE GONNA TAKE A STRAW POLL TO FIGURE OUT, IT'S NOT BINDING, IT'S JUST, WELL WHAT IS IT? I MEAN, IF WE'RE SAYING WE AGREE WITH THIS CONCEPT, WHAT IF IT CONFLICTS WITH ANOTHER ONE, THE LANGUAGE COMES BACK AND YOU DON'T AGREE WITH IT. THAT'S A, THAT'S A DIFFERENT VOTE. THAT'S JUST WE TO SAY LAST TIME WE GOT IN A SITUATION WHERE WE HAD TWO VERSIONS OF COMMENTS KIND OF TOTALLY DIFFERENT LANGUAGE, WE'RE HOPING AGREEMENT ON CONCEPTS WILL DRIVE US TO HOPEFULLY SOMETHING CLOSER. OKAY. JEREMY, I THINK THAT MAY HAVE ANSWERED MY QUESTION, BUT WOULD, WITH REGARDS TO WHAT YOU JUST SAID, IT, IT WILL BE DIFFICULT OR MORE DIFFICULT TO VOTE IN A STRAW POLL WITHOUT HEARING THE OTHER SIDE OR THE COMMENTS THAT MIGHT COME OUT. DOES THAT MAKE SENSE OR THAT, IS THAT WHAT THIS FORUM'S FOR NOW? Y YEAH, WE ARE TRYING AS TACK TO DRIVE FORWARD A SOLUTION BECAUSE I THINK THE FEAR IS WE GET TO ANOTHER SITUATION LIKE WE DID IN FEBRUARY AND WE'RE RIGHT BACK HERE, RIGHT? I I THINK WHAT WE DID WHERE WE GOT TWO VERSIONS THAT WERE KIND OF WRITTEN IN DIFFERENT LANGUAGES DID, DIDN'T WORK. AND SO I, I THINK WE'D LIKE TO SEE IF WE HAVE CONSENSUS ON THE POLICY ISSUES AND THE CONCEPTS AND THEN AT LEAST AGREE ON THAT AS A BETTER STARTING POINT FOR ONE VERSION WE CAN ALL GET BEHIND. OKAY. SO ANY ADDITIONAL COMMENTS THAT COME OUT? WE'LL JUST BE ON TOP OF ANYTHING THAT WE'VE TALKED ABOUT HERE. I I THINK IT'S JUST A STARTING POINT FOR ANYBODY WRITING COMMENTS TO KNOW, I'LL HAVE HOWEVER MANY PEOPLE AGREEING WITH THIS, BUT THEY, THEY DON'T HAVE TO DO THAT, RIGHT? I COULD WRITE COMMENTS THAT ARE TOTALLY OPPOSING. I THINK IT JUST GIVES US INFORMATION THAT WILL HOPEFULLY MAKE PROGRESS. THANKS STEVEN. SO I'M JUST GOING TO, I GUESS, STATE MY OPINION HERE AND PLEASE TAKE IT FOR WHAT IT'S WORTH, WE JUST SPENT A GOOD PORTION OF OUR TIME TALKING ABOUT EXEMPTIONS. OKAY. AND THEN, AND ERCOT HASN'T REALLY FULLY PRESENTED ON THE 6 1 23 DATE, BUT THAT'S WHAT TAC IS DECIDING ON. SO IT SEEMS LIKE MAYBE WE SHOULD BE CONSIDERING TAKING THE STRAW POLL ON THE SECTION THAT WE JUST COVERED INSTEAD OF A SECTION THAT WE REALLY DIDN'T SPEAK ABOUT. OKAY. LET ME JUST GO BACK TO THE QUEUE BECAUSE NED'S BEEN THERE A WHILE 'CAUSE I DON'T THINK THE STRAW POLL IS HAPPENING IMMINENTLY NOW. SO NED, THANK YOU. UM, WELL, FOR FOR WHAT? FOR THE RECORD, ONE OF THE THINGS I WAS GONNA SAY WAS ALONG THE LINES OF WHAT CHRIS HAD PROPOSED IS, YOU KNOW, IF WE HAVE IT EFFECTIVE AT SOME, YOU KNOW, EITHER WITH OR AFTER PUC APPROVAL OR DATE CERTAIN, THAT'S KIND OF TIED TO WHEN WE EXPECT IT TO GO THROUGH THE PUC, I THINK THAT'S THE RIGHT WAY. I WOULD VOTE AGAINST ANYTHING ELSE. SO, UM, AND I DON'T, WON'T, I WON'T BELABOR GOING BACK OVER THAT. UM, I DID HAVE A QUESTION ON THE, THE EVALUATION THOUGH. SO IF, IF, IF IT'S STILL GERMANE, I'D LIKE TO ASK THAT. IS THAT OKAY TO GO BACK TO THAT TOPIC? OKAY. SO STEVEN, WHEN UM, WHEN ERCOT IS EVALUATING THE SYSTEM IMPACTS AND, AND WORKING THAT INTO HOW TO WHETHER TO, UM, GRANT AN EXEMPT, UH, EX EXEMPTION , UH, I'M, I'M GUESSING THERE ARE, IF YOU'RE, IF IT'S A SYSTEM ISSUE, THERE'S PROBABLY MULTIPLE RESOURCES THAT ARE CONTRIBUTING TO IT. AND, AND SO THERE'S, THERE'S PROBABLY MULTIPLE RESOURCES THAT ARE LOOKING FOR EXCEPTIONS. I'M CURIOUS, AND THIS PROBABLY MAYBE GETS TO THE QUESTION JULIANA THAT YOU HAD, IS, WOULD ERCOT BE LOOKING AT THAT FROM A STANDPOINT OF PHYSICAL CAPABILITY? LIKE WOULD THERE BE SOME PRIORITIZATION, UH, FOR RESOURCES THAT HAVE NO PHYSICAL CAPABILITY TO, UH, TO MAKE MODIFICATIONS TO RECEIVE AN EXCEPTION VERSUS OTHERS THAT ARE, SAY IN THE SAME AREA BUT MAY HAVE LOWER BAR FOR, UH, FOR MEETING IT? SO I, I THINK UNTIL WE GET THE INFORMATION, IT'S REALLY DIFFICULT TO, TO TRY TO HANDLE THAT WHAT IF SCENARIO. OKAY. BUT THE BEST I COULD TELL YOU IS THAT WHEN WE SEE AN UNACCEPTABLE RELIABILITY RISK, WE, WE, WE JUST CAN'T ALLOW IT. AND SO WE WOULD DENY THE EXEMPTION. WE WOULD, BECAUSE WE'RE, ONCE WE'RE AWARE OF A LIMITATION, WE ARE OBLIGATED BY NERC TO RESPECT THAT IN OUR ANALYSIS AND IN OUR REAL TIME ASSESSMENTS. AND SO THEN WE HAVE TO PUT IN OPERATIONAL MEASURES TO PROTECT THE SYSTEM FROM THAT RISK UNTIL SUCH TIME IT CAN GET MITIGATED BY WHATEVER OTHER MEANS THAT IS THE PROCESS THAT [05:50:01] WE HAVE TO GO BY TODAY. SO, SO DO I TAKE THAT TO MEAN THAT IF, IF THERE ARE FIVE RESOURCES IN AN AREA CONTRIBUTING TO A, AN IDENTIFIED RISK, TWO OF THEM CANNOT PHYSICALLY MAKE MODIFICATIONS AND BUT THE OTHER THREE, IF THEY COULD MAKE MODIFICATIONS AND ADDRESS THAT RISK, THEN UM, THE, THE RISK GOES AWAY. Y'ALL WOULD NOT BE ABLE TO, TO MAKE THAT A ASSESSMENT AND SAY, GIVE THE EXEMPTION TO THE TWO THAT HAVE NO, NO RECOURSE VERSUS THE THREE THAT MIGHT HAVE A A, SOME CAPABILITY. I WOULD SAY THAT OUR LANGUAGE TODAY DOESN'T HAVE ANY TYPE OF FRAMEWORK FOR US TO PRIORITIZE ONE COMPANY OVER ANOTHER OR ONE UNIT OVER ANOTHER. IF THAT'S WHAT TAC DESIRES, THEN WE, WE WOULD NEED TO MODIFY THE LANGUAGE TO PUT IN SUCH A FRAMEWORK TO GIVE PRIORITIZATION BASED ON AGE OR CAPACITY OR WHATEVER T WOULD THINK WAS APPROPRIATE. OKAY. WANTED TO UNDERSTAND WHAT THE, WHAT THE BASELINE WAS IN HERE. THANK YOU BOB HILTON. YEAH, REAL QUICKLY ON THE STRAW POLL, I DON'T THINK THE POLICY ISSUE OF PUTTING A DATE ON IT MM-HMM, IS A POLICY. THE POLICY IS, AND I THINK THE THING WE NEED TO THINK ABOUT IS SHOULD THIS BE RETROACTIVE OR NOT FOR IMPLEMENTATION? AND I THINK THAT WOULD BE MORE OF THE POLICY CALL AND THAT WE WOULD KNOW WHERE TO START SETTING A DATE. THAT'S JUST MY THOUGHTS ON, ON THAT PIECE. ON THE OTHER ONE, I, I JUST WANTED TO ASK A QUESTION, STEVE. 'CAUSE YOU KNOW, KEEP HEARING AND I'M THAT THE DIFFERENCE BETWEEN THE DATES, AND THIS MAY BE WHAT YOU WERE GONNA DISCUSS LATER, THAT YOU FEEL THAT, THAT WE'RE GOING TO CONTINUALLY GET WORSE AND WORSE AND WORSE AND WORSE. AND THAT'S TAKEN IN MY MIND CONSIDERATION THAT THE CURRENT NEW FACILITIES THAT ARE COMING ONLINE ARE NOT DOING ANYTHING AND THEY'RE ALL OLDER VINTAGE AND THEY'RE NOT, NOT OPERATING IN A HIGHER OR AT LEAST ABOVE THE, THE LEGACY PIECE. SO I'M TRYING TO DETERMINE FROM THOSE DATES HOW MUCH REAL RISK THERE REALLY IS IN PRACTICALITY. AND I DON'T KNOW THE ANSWER TO THAT. SO I WOULD LOOK TO YOU AND MAYBE EVEN QUINTA TO COMMENT ON THAT, ON HOW FAR THAT RISK WOULD BE. 'CAUSE I'M NOT SURE THAT IT IS AS BAD. SO I, I THINK THIS SLIDE WILL HELP KIND OF VISUALIZE THAT IMPACT. UM, SO I, WE ALL HAVE AGREEMENT THAT THE NEW RESOURCES THAT COME IN THAT ARE COMING ONLINE IN THE COMING YEARS SHOULD HAVE MORE CAPABILITY. IF WE HAVE REQUIREMENTS THAT REQUIRES THEM TO MAXIMIZE THEIR CAPABILITY, THEN THAT SHOULD BE A NET BENEFIT FOR ERCOT. NOW WE ALL HAVE TO UNDERSTAND, AND I DON'T WANT TO GET TOO TECHNICAL, BUT THE MORE PENETRATION YOU GET, THERE'S MORE OPPORTUNITIES FOR MIS COORDINATION. THERE'S SYSTEM STRENGTH ISSUES, THERE'S DIFFERENT THINGS THERE THAT MAGNIFY THE POTENTIAL RISK, BUT CAPABILITY WISE, THEY SHOULD BE BETTER. NOW HERE'S THE NET EFFECT. AND THIS IS IMPORTANT JUST FOR EVERYBODY TO UNDERSTAND THE DECISION. IF THERE IS A, A PARTICULAR RESOURCE AND IT HAS CAPABILITIES BEYOND THE LEGACY REQUIREMENTS AND THEY MAXIMIZE, THAT'S WHAT THEY SHOULD OPERATE TO. THAT'S WHAT WE GET IN OUR MODELS. WE MAKE PLANNING DECISIONS, WE MAKE OPERATIONAL DECISIONS ON THAT CAPABILITY THAT'S GIVEN TO US. SO THE BIG DIFFERENCE IS, IS WE ARE JUST ASKING WHATEVER YOU'RE CAPABLE OF, WE WANT YOU TO STICK TO THAT SO THAT IF YOU HAVE A PERFORMANCE FAILURE, YOU'RE OBLIGATED TO RETURN BACK TO WHAT YOU TOLD US YOU COULD DO. THE OTHER ASPECT IS IF YOU EXCEED THE REQUIREMENTS WITH YOUR CAPABILITY, THEN WE'RE NOT GONNA ASK YOU TO HAVE TO COME BACK TO HERE. YOU JUST HAVE TO COME BACK TO YOUR REQUIREMENTS, WHICH IS CLOSER TO WHAT YOU TOLD US YOU COULD DO. SO THAT OUR PLANNING, OUR OPERATIONS ARE BASED ON SOLID FOOTING. OTHERWISE, EVEN IF YOU MAXIMIZE [05:55:01] YOU HAVE AN EVENT, ALL YOU HAVE TO DO IS GO HERE. IF YOU LOOK AT THE NERC ALERT FROM LAST YEAR, THERE'S SO MANY RESOURCES THAT PLUG THEIR PROTECTION SETTINGS RIGHT HERE ON THAT CURVE, EVEN THOUGH THEY'RE CAPABLE. SO WE'RE TRYING TO MAKE SURE THAT BECAUSE THEY'RE CAPABLE, WE WANT THEM TO MAKE SURE THEY CONTINUE TO BE CAPABLE MOVING FORWARD. THAT'S WHAT OUR REQUIREMENTS PROPOSING THAT 6 1 23 DATE DOES. I'LL, I'LL JUMP IN SINCE MY NAME WAS BROUGHT UP. UH, RYAN CLIN WITH ELEVATE, I THINK BOTH POINTS ARE, ARE REALLY IMPORTANT TO TRY TO FIND SOME UNIFORMITY HERE. THE T VERSION OF NOGA 2 45 INCLUDES THE MAXIMIZE REQUIREMENTS AS I SHOWED EARLIER, RIGHT? SO ON STEVEN'S GRAPH THERE, YOU HAVE TO PUSH YOUR REQUIREMENT OUT. YOU HAVE TO PUSH YOUR CAPABILITY OUT TO THE RIGHT, WHETHER YOU'RE LEGACY OR A NEW RESOURCE. AND SO YES, EVERYONE WILL BE ABLE TO GO MUCH FURTHER THAN THE BLUE CURVE. AND AGAIN, NONE OF THESE CURVES ARE EVEN RELEVANT TO THE TRIPPING THAT HAS OCCURRED IN ANY OF THE PAST DISTURBANCES. IT'S THE OTHER PARAGRAPHS THAT KEEP US SAFE FROM THAT PERSPECTIVE. RIGHT? BUT THE MAXIMIZATION IS THERE. SO WITH THE MAXIMIZATION, AS WAS JUST STATED, THE NEED TO GO BACKWARDS IN TIME IS WE WOULD NEED A STUDY TO PROVE THAT WE HAVEN'T SEEN THAT STUDY, RIGHT? ALL RESOURCES ARE REQUIRED TO MAXIMIZE. AND SO THAT WINDOW OF 2023 TO 2024 WILL PROBABLY BE ABLE TO EXCEED THE PURPLE CURVE UP THERE BY FAR REGARDLESS. AND THEY'RE REQUIRED TO MAXIMIZE ANYWAYS. SO AGAIN, IT COMES BACK TO WHAT WE'RE ARGUING OVER SOMETHING THAT DOESN'T REALLY EVEN NEED TO BE ARGUED RIGHT NOW, I DID WANNA HIGHLIGHT SOMETHING BECAUSE I'VE SORT OF UNCOVERED THIS OVER THE, OVER A WHILE AND I THINK IT'S INFORMATIVE FOR ALL PARTIES. THE PROJECT, THE PROJECT DEVELOPERS, THE OWNER OPERATORS, WHAT HAVE YOU, THEY GET THE EQUIPMENT FROM THE OEM WITH THE DEFAULT SETTINGS AND THEY ASK, IS THIS COMPLIANT WITH THE RULES? IF IT IS, I'M GOOD. RIGHT? AND THE DEFAULT SETTINGS THAT THE OEMS PROVIDE ARE THE RULES, RIGHT? AND SO I I ACTUALLY, YOU KNOW, THAT'S WHAT I'VE HEARD, RIGHT? IS THAT YOU BUY A TEAM I CONVERTER, YOU'RE GONNA GET THE DEFAULT SETTINGS, WHICH ARE GONNA MATCH THE CURVE, MAYBE THE WRONG RULES. SOMETIMES THEY SET 'EM TO 1547 INTO THE SURE. YEAH. AND WHEN YOU PULL UP A CERTAIN OEM'S SPEC SHEET, IT'S GOT THE SETTING RIGHT AT THE FRONT, 1547 SETTINGS, RIGHT? SO THE, THE MAXIMIZE REQUIREMENT, ALTHOUGH QUITE AGGRESSIVE, MINIMIZES RISK TREMENDOUSLY BECAUSE IT KEEPS THAT TYPE OF THING FROM HAPPENING IN THE FIRST PLACE, RIGHT? WHICH IS SHOWN IN THE NERC ALERT THAT 30% OR WHATEVER THE FACILITIES ARE SETTING IT RIGHT ON THE CURVE, HAVE A HUNCH. THAT'S BECAUSE THAT'S BEING DRIVEN BY THE OEMS, NOT BY THE GENERATOR OWNERS ACTUALLY. SO, OKAY. CAN CAN I JUST ASK FOLLOW UP WITH JUST ONE MORE SURE. QUESTION BECAUSE I'M STILL TRYING TO RECONCILE A FEW THINGS. OKAY. UM, SO I'M TRYING TO FIGURE OUT WHY THE DATE, AND ACTUALLY YOU KIND OF SAID, I'M TRYING TO FIGURE OUT WHAT THE DATE MEANS, WHETHER IT'S 23 OR 24 OR WHATEVER. UH, BUT IF WE'RE MAXIMIZING, YOU HAVE TO MAXIMIZE AND I GET THAT IF, IF YOU HAVE A, AN EVENT THAT HAPPENS MM-HMM, , YOU'RE NOT GONNA COME BACK UP TO THERE BECAUSE YOU HAVE TO MAXIMIZE AGAIN. SO YOU SHOULD BE GOING BACK UP TO WHERE YOU SHOULD BE AFTER AN EVENT, WHATEVER YOU NEED TO DO. THE WAY I SEE IT, SOMEBODY TELL ME IF I'M WRONG NOW, THERE'S NO REQUIREMENT FOR THAT. YEAH, THERE'S A REQUIREMENT TO MAXIMIZE BY A CERTAIN DATE. THERE'S A REQUIREMENT TO MAXIMIZE, BUT IT, THERE'S NO PERFORMANCE FAILURE AND THUS THERE'S NO REQUIREMENT TO MITIGATE BECAUSE THERE WASN'T A PERFORMANCE FAILURE BECAUSE THE REQUIREMENT IS SET AT THE LEGACY CURVE. IF YOU PUSH IT OUT, STILL DON'T BUYING THAT BECAUSE IT, IT SAYS YOU HAVE TO MAXIMIZE. SO IF I, TO ME, I'M, I'M, I'M MAYBE GETTING THIS TOTALLY WRONG. IF, IF I HAVE A UNIT OUT THERE THAT IS MAXIMIZING AND THEY, SOMETHING HAPPENS AND THEY DON'T RIDE THROUGH, I'M GONNA HAVE TO DO A ROOT CAUSE I'M GONNA HAVE TO BRING IT BACK UP AND THEN I'M GOING TO HAVE TO COMPLY WITH 2 45, WHICH SAYS I HAVE TO MAXIMIZE. SO I'M GONNA HAVE TO GO ALL THE WAY AND MAKE SURE THAT I'M DOING THE FULL CAPABILITY OF THE UNIT, NOT JUST THE REC, JUST THE LEGACY. I HAVE TO GO BACK TO WHERE I WAS. THAT'S THE WAY, AT LEAST I UNDERSTAND THE WAY THE NPRR IS DESIGNED. UH, MY OTHER PIECE IS, AND I THINK YOU'RE, YOU'RE, YOU'RE GONNA HIT THAT WHENEVER HE SAID MODEL, YOU CAME OUTTA THE CHAIR . 'CAUSE WE HAVE ISSUES WITH MODELS. UH, IS THAT ALSO, I THINK WE GOTTA LOOK AT THIS WITH PIGGER 1 0 9 AND PIGGER 1 0 9 PRETTY MUCH SAYS ANY SETTING CHANGES, ANY OF THIS STUFF THAT WE DO IS GOING TO HAVE TO GO THROUGH PICK 1 0 9. AND IF WE DO THAT THROUGH [06:00:01] 1 0 9, THEN YOU'RE GONNA LOOK AT IT BEFORE WE DO IT. YOU'RE GONNA APPROVE IT BEFORE WE DO IT. AND THEN WHEN WE'RE DONE WITH IT, YOU'RE GONNA GET AN ACCURATE MODEL. THAT'S THE WAY I READ 1 0 9. SO HOPEFULLY THAT WHOLE ITERATIVE PROCESS IS GOING TO GET US, I THINK IN A PRETTY GOOD PLACE. I I JUST WANNA SAY, BOB, WHAT YOU JUST SAID CONCEPTUALLY, IF WE CAN GET THE LANGUAGE TO DO OR SAY JUST WHAT YOU SAID, I THINK WE'D BE PRETTY CLOSE TO AGREEMENT. OKAY. AND WE WOULDN'T HAVE AS MUCH CONSTERNATION ABOUT THE DATE MOVING IF THOSE ENTITIES WERE ABSOLUTELY REQUIRED, IF THEY HAVE A PERFORMANCE FAILURE TO MITIGATE AND GO BACK TO WHAT THEY TOLD US THEY COULD DO IN THE FIRST PLACE. ALL RIGHT. LET THINK ABOUT THAT. SOUNDS LIKE AN IMPORTANT POINT. THAT'S WHAT IT IS. , WOODY, YOU WANNA JUMP IN? OKAY, SO, SO AS TAC LET, LET'S LET, LET'S PAUSE ON ON THIS POINT. DOES IT, DOES EVERYBODY KIND UNDERSTAND THE DISCUSSION THAT WE JUST HAD AND WHAT STEVEN SAID? CHRIS, I THINK I UNDERSTAND BECAUSE I THINK THE LANGUAGE THAT THE WAY I SEE IT OUT THERE IS IF IT, I MEAN, NO MATTER WHAT THE DATE IS, THE UNITS HAVE TO GO BACK AND GO TO THEIR MAXIMUM CAPABILITY OF THE UNIT ITSELF. I'LL HAVE THAT WRONG. DAN'S SHAKING HIS HEAD. I THINK GO AHEAD. I I JUST WANNA MAKE SURE THAT IT APPEARS THAT EVERYBODY RIGHT NOW IS UNDER THE IMPRESSION THAT THE CURRENT VERSION APPROVED BY TAC REQUIRES UNITS TO MAXIMIZE. AND THAT ISN'T WHAT THE LANGUAGE SAYS. IT SAYS THEY HAVE TO MAXIMIZE IF IT'S COMMERCIALLY REASONABLE. SO JUST WANNA MAKE SURE THAT'S, THAT WE'RE CLEAR ON THAT, BUT SOFTWARE IS COMMERCIALLY REASONABLE. YES, ABSOLUTELY. WHICH IS WHAT WE'RE TALKING ABOUT MAXIMIZING. SO IT DOES SAY THAT EVEN, EVEN, I THOUGHT WE WERE TALKING ABOUT MAXIMIZING MORE FOR ERCOT. WHAT YOU HAVE UP THERE SAYS THE SAME THING EXCEPT IT JUST SAYS 50%. TO ME, THAT'S THE ONLY DIFFERENCE IS THAT, IS THAT WHO'S DECIDING WHAT'S COMMERCIALLY REASONABLE AND OR PUTTING A NUMBER ON IT THAT HAS TO BE EVALUATED AND THAT'S THE END OF IT. SO THAT'S WHERE I SEE THE DIFFERENCE IN THAT. SO I STILL SAY THEY BOTH HAVE COMMERCIALLY REASONABLE TO DO WHAT YOU CAN DO. WELL, I, I THINK MATTERS THE DIFFERENCE OF WHERE IT'S AT. WHAT WE TRIED TO DO IS COME UP WITH SOME CRITERIA SO THAT IT WAS MORE OBJECTIVE ON THE KINDS OF THINGS THAT HAD TO BE DONE, BUT BECAUSE WE THOUGHT THAT'S WHAT THE BOARD TOLD US TO DO WAS RIGHT. COME BACK WITH OBJECTIVE CRITERIA. SO TRY AND I DON'T DISAGREE WITH THAT. YEAH, I I DON'T DISAGREE WITH THAT. I THINK WHAT I DID DISAGREE WITH AS YOU SAYING THAT WE SAID COME, YOU KNOW, THAT THE, THE TAC COMMENTS SAY COMMERCIALLY REASONABLE, UH, THE ONLY IN IN YOURS JUST PUTS CRITERIA TO THE WHAT COMMERCIALLY REASONABLE IS. AND SO THEY BOTH HAVE COMMERCIALLY REASONABLE PIECES IN THERE. SO IT'S NOT LIKE WE HAVE IT, YOU DON'T, IT'S JUST IN THERE IN DIFFERENT WAYS. AND MAYBE THERE'S A WAY WE COULD COME TO AN AGREEMENT OF WHAT THAT ACTUALLY MEANS. , I I THINK THAT IT'S, IT WE, WE WE WERE VERY CAREFUL TO NOT SAY COMMERCIALLY REASONABLE IN WHAT, IN WHAT WE'VE WRITTEN AND RIGHT. WHAT WE'VE SAID IS WE WOULD TAKE INTO ACCOUNT THE FINANCIAL IMPACT ON THE RESOURCE ENTITY AND WE PUT SOME PRO, WE TRIED TO PUT SOME OBJECTIVE CRITERIA INTO THAT. BUT, BUT IT'S NOT, IT'S NOT A COMMERCIALLY REASONABLE ANALYSIS. IT'S HERE'S THE RISK TO THE SYSTEM AND HERE'S THE COST TO THE RE AND DOES THE RISK TO THE SYSTEM. I THINK WE'RE JUST SAYING JUSTIFY AN EXPENSE. I THINK IT'S JUST SEMANTICS IS REALLY WHERE WE'RE AT. WELL, AND, AND THEN THE, UM, NO, YOU'RE PROMISE. THE OTHER THING I WAS GONNA JUST SAY FOR YOU, BOB, IS THAT IF YOU HAVE A PERFORMANCE FAILURE, IT, IT, THE, THE COMPLIANCE MEASURE IS WHEN YOU TELL US I'VE MAXIMIZED MY UNIT AND HERE'S WHAT IT CAN DO, THAT'S NOW YOUR, THAT'S NOW YOUR COMPLIANCE HURDLE. SO IF YOU, IF YOU DON'T MEET THAT, THEN YEAH, YOU'RE GONNA HAVE TO COME BACK IN AND MITIGATE TO GET TO WHAT YOU SAID, RIGHT? WHAT YOU ORIGINALLY TOLD US YOU COULD DO. YEAH. YEAH. AND THAT'S WHAT I THOUGHT I SAID WAS EVEN WITHOUT ALL OF THIS, IF I HAVE A TRIP, SOMETHING HAPPENS, I DON'T RIDE THROUGH, I'VE GOTTA GO BACK UP TO WHERE I WAS TO, TO MY MAXIMUM CAPABILITY, YOU KNOW, AND, AND 'CAUSE I THAT, THE ONLY REASON I SAID THAT IS 'CAUSE STEVE SAYS, WELL ALL YOU HAVE TO DO IS GO TO THE LEGACY. NO, YOU'VE GOTTA GO ALL THE WAY UP TO YOUR, YOUR MAXIMUM CAPABILITY, WHICH IS GOOD. I, I'LL SHUT UP. I'VE TALKED ENOUGH WOODY. OKAY, SO TRUE OR FALSE, THE TACK LANGUAGE DOES NOT REQUIRE UNITS TO MAXIMIZE TO THEIR FULL [06:05:01] SYSTEM CAPABILITY. I THINK THAT IS A TRUE STATEMENT. IT DOESN'T, ERCOT WANTS UNITS TO ACTUALLY MAXIMIZE TO THEIR, THEIR FULL EQUIPMENT CAPABILITY. SO THAT'S A DIFFERENCE BETWEEN THE TWO. AND I THINK WE'RE, WE'RE BLURRING THAT. SO FIRST QUESTION, DOES THE TAC VERSION REQUIRE UNITS TO MAXIMIZE ALL THEIR CASES TO THE FULL EQUIPMENT CAPABILITY? TRUE OR FALSE? I PUT IT ON THE SCREEN EARLIER 'CAUSE I KNEW IT WAS GONNA COME UP. YEAH, THAT'S TWO 11. AND IT DOESN'T SAY THAT. I MEAN I READ IT. YOU READ IT. DO I ONLY READ TWO 11 AFTER? DO I READ THAT FIRST BEFORE I READ TWO SIX AND TWO NINE THE Q SO LET'S JUST GET THAT STRAIGHT THOUGH. TWO DOES WHAT DOES THE TECH LANGUAGE DO? I THINK THAT'S KEY TO WHAT WE'RE TRYING TO DO HERE. WOULD IT, WOULD IT BE BETTER, COLIN TO SAY WHAT DOES TAC WANT IT TO DO? DOES TECH WANT UNITS TO HAVE TO MAXIMIZE THEIR CAPABILITY TO WHATEVER THE EQUIPMENT CAN DO? AND AND THAT'S LIKE YOUR STRAW POLL MEETING. LET'S DO THAT. I HAVE TO LEAVE THE BABY WANTED TO SAY HI AND THANK YOU FOR YOUR HARD WORK. WE HAVE TO GO BACK TO HOUSTON. UH, WE'VE BEEN GONE SINCE OUR POWER'S BEEN OUT, BUT WE ARE GOING BACK TODAY AND SHE WANTED TO SAY HI AND THANK YOU, BUT COLLIN'S GOT IT. DID YOU SAY GOOD INPUT THE ANSWER? NO. I THINK THERE YOU'VE GOT, YOU DON'T HAVE TO DO ANYTHING THAT HAS GREATER THAN 50, YOU KNOW, GREATER THAN 50%. IT STARTS THERE. ALLOWS YOU TO GO DO, IT STARTS, I THINK CHASE IS IN THE QUEUE. IT THINK CHASE HAS BEEN THE CASE SINCE I LEFT TO ALL RIGHT. CHASE, GO AHEAD. 50% OF AN I. THANK YOU. COLIN, CAN YOU CONFIRM? YOU CAN HEAR ME GOOD? YES SIR. OKAY. YOU KNOW, UH, THANKS CHASE THE SOUTHERN POWER. UM, I AS JUST TO RESPOND TO WHAT HE'S QUESTION, I, I THINK THERE'S, MY, MY OPINION IS THERE'S CONFLICTING LANGUAGE. I THINK THERE'S SOME LANGUAGE IN THE TAC REPORT THAT DOES REQUIRE MAXIMIZATION BEYOND THE LEGACY REQUIREMENTS AND SUCH AS, YOU KNOW, 2 6, 2 1, PARAGRAPH THREE, THE PROTECTION SYSTEM LANGUAGE HAS MAX, YOU KNOW, MAXIMIZED TO MEET OR EXCEED THE ABOVE UH, CURVE. UM, USING THE MAXIMUM SEND EQUIPMENT ALLOWS. THERE'S ALSO MAXIMIZATION LANGUAGE TO METER EXCEED IN REFERENCE TO SECTION TWO 11. BUT THERE'S ALSO THIS LANGUAGE IN TWO 11 THAT TALKS ABOUT UP TO, UM, THE REQUIREMENTS IN THE FREQUENCY RIDE THROUGH SECTION AND THE LEGACY SECTION THAT I, I THINK IS CONFLICTING, RIGHT? THAT THAT KIND OF SAYS GO UP TO THE REQUIREMENT. SO I THINK THERE ARE SOME EXISTING MAXIMIZATION LANGUAGE, SOME THINGS THAT KIND OF CONFLICTS WITH THAT, THAT WOULD NEED UPDATING, UM, TO FULLY INCORPORATE THIS AS A CONCEPT. UM, SO THAT'S JUST, I THINK THE ANSWER IS THERE'S PROBABLY TRUE SOME TRUTH TO YES, THERE IS MAXIMIZATION LANGUAGE, BUT ALSO IT'S, UM, PROBABLY NOT FULLY INCORPORATED IN THE LANGUAGE TO, UM, ADDRESS THIS CONCEPT, YOU KNOW, TO, TO FULLY INCORPORATE THE CONCEPT. UM, SO THAT, YOU KNOW, THAT THAT WAS, THAT WAS ONE PART. AND THE OTHER PART IS, YOU KNOW, CURRENTLY THE ATTACK REPORT, YOU KNOW, IT REFERENCES THIS MAXIMIZATION TO COMMERCIALLY REASONABLE EFFORTS AND THEN THERE'S BOTH SOFTWARE AND SETTINGS, WHICH IS REALLY WHAT WE HAVE BEEN FOCUSED ON AND TALKING ABOUT. BUT THAT ALSO THERE IS THE OTHER SECTION ABOUT COMMERCIAL REASONABLE PHYSICAL MODIFICATIONS. SO THAT WOULD NEED TO BE CHANGED AND THAT, THAT, THAT'S ANOTHER PART THAT I THINK WE WOULD LOOK TO BE REMOVING. THAT'S AT LEAST OUTSIDE THE SCOPE OF WHAT TECH HAS BEEN TALKING ABOUT THIS POINT. UH, THIS IS A, A CONCEPT THIS MAXIMIZATION VIA SOFTWARE AND SETTINGS. UM, SO THAT'S MY INITIAL COMMENT ON THAT. UM, COLIN, I DO HAVE MAYBE ANOTHER COMMENT OR QUESTION ON SOME OF THE THINGS, BUT UM, IF WE WANNA KEEP THE FOCUS ON THIS SPECIFIC TOPIC, I CAN HOLD OFF ON A SECOND IF THERE'S ANY DIRECT RESPONSE OR QUESTION TO THAT, UH, SPECIFIC ITEM AND THEN I CAN MAYBE COME BACK TO MY NEXT COMMENT IF THAT WORKS. UH, I'D APPRECIATE THAT. LET'S KEEP IT, KEEP IT TO THIS. OKAY. AND, AND T MEMBERS, ERIC, HAVE TO GO TO YOU, BUT ON THIS SPECIFIC TOPIC, I'VE GOT A COUPLE OF QUESTIONS WRITTEN DOWN ONCE WE GET THROUGH THIS QUEUE THAT I WANT TO ASK IF, IF ANYBODY ELSE HAS QUESTIONS BE THINKING ABOUT THOSE SPECIFICALLY ON THIS MAXIMIZATION CAPABILITIES IN RELATION TO THE DATE, ERIC? SO, UM, I THINK THAT THE COMPLEXITY OF THIS CONVERSATION DEMONSTRATES WHY IT'S DIFFICULT TO TRY TO DO A STRAW POLL, EVEN IF IT SOUNDS LIKE IT'D BE HELPFUL, UM, BECAUSE THERE ARE OVERLAPPING IFS THENS IN ANY COMPLEX ISSUE, ESPECIALLY THIS ONE. SO, UM, [06:10:01] I I THINK IT WOULD BE BETTER FOR TAC MEMBERS AS THEY SPEAK TO STATE THEIR OPINION ABOUT THIS STUFF. BUT, UM, TRYING TO NAIL THINGS DOWN IN A A STRAW POLL COULD JUST BE A SLIPPERY SLOPE THAT COULD HAVE UNINTENDED CONSEQUENCES EVEN IF I MIGHT LIKE THE OUTCOME OF A PARTICULAR POLL. UM, SO I, I JUST CAUTION AGAINST OVERSIMPLIFYING WHETHER THIS STRAW POLL. THANKS. GOOD, DAVID? YEAH, THAT, THAT'S REALLY WHAT I WAS TRYING TO GET TO, I GUESS SUGGEST, AND THAT WAS THE QUESTION I HAD AROUND THE PROCESS IS WE'RE TALKING ABOUT ONE PART OF A REALLY COMPLEX SYSTEM HERE. SO I I, I DO APPRECIATE THE CONVERSATION, IT'S VERY HELPFUL. IT'S HELPING ME TO KIND OF FIGURE OUT WHERE I'M GONNA LAND ON THESE, BUT I THINK TAKING A SINGLE PIECE MIGHT NOT, YOU KNOW, RESULT IN, YOU KNOW, AN OUTCOME THAT WE WANT. SO I PREFER TO SEE, YOU KNOW, HEAR DISCUSSION, GET LANGUAGE THAT REFLECTS WHAT WE THINK WE'VE HEARD, WHAT WE THINK WE AGREE ON, AND THEN WE CAN VOTE ON THE LANGUAGE, BUT TAKING PART IN THE PIECE MIGHT NOT GIVE US THE BEST RESULT. AND THAT'S JUST, YOU KNOW, HOW I'M LOOKING AT THIS. BUT I DO APPRECIATE THE DISCUSSION ON IT. ALRIGHT, BOB STEPPED OUT CHRIS. SO I GUESS TO ERIC AND DAVID'S POINT, THAT'S WHY I STARTED TRYING TO DO THE STRAW POLL ON THE DATE. 'CAUSE I THOUGHT THAT WAS THE EASIEST ISSUE TO COVER AS OPPOSED TO ALL THE OTHER ONES. BUT, UM, THIS ONE, THE WAY I READ IT IS THE VERSION THAT TAC APPROVED IS REQUIRING THE MAXIMIZING FOR THE SOFTWARE FIRMWARE SETTINGS AND CHANGES TO, TO BE MADE. UM, AND IT KIND OF, I, REGARDLESS OF HOW MUCH IT COSTS, BECAUSE IT, IT KIND OF THROWS OUT THE COMMERCIALLY REASONABLE PART OF IT 'CAUSE IT'S PRESUMED TO BE COMMERCIALLY REASONABLE. SO THE WAY I READ IT BACK THEN, AND THE WAY I STILL READ IT IS THAT'S REQUIRED OF ALL UNITS. OKAY. RYAN, I UP? YEAH, SORRY, YOU WANNA GO? UM, YEAH, I MEAN MY, JUST PUT MY NAME IN THE QUEUE REGARDING THE, YOU KNOW, WHAT, WHAT I PUT OUT EARLIER IN TERMS OF THOSE FOUR CLAUSES AND I'M JUST KIND OF CURIOUS HOW THOSE FOUR CLAUSES GET READ IN THE CONTEXT OF COMMERCIAL REASONABILITY AND MAYBE THERE'S SOME CONFUSION THERE REGARDING, YOU KNOW, IF WE JUMP ONLY DOWN TO CLAUSE TWO 11 AND JUST READ THAT AT FACE VALUE, THEN, THEN YEAH, ONE COULD ARGUE, WELL I'M GOING TO ONLY MAXIMIZE UP TO THE REQUIREMENT, BUT WHEN YOU READ THE OTHER SECTIONS, THEY REQUIRE YOU TO MAXIMIZE TO YOUR EQUIPMENT CAPABILITY. HEY, I, I DON'T MEAN TO INTERRUPT, BUT WHAT, WHAT DID I, WERE JUST HAVING THE SAME CONVERSATION A FEW SECONDS AGO AND REGARDLESS OF WHAT'S IN THE CURRENT LANGUAGE, IT CAN'T HURT TO CLARIFY OUR INTENTION HERE. AND SO IT MIGHT BE PRODUCTIVE FOR US TO, UM, AGREE THAT WHAT WE WANT TO DO IS TO, YOU KNOW, I THINK WE'VE ALL SAID WE WANNA FIGURE HOW TO MAXIMIZE. AND SO IF WE NEED TO ADD CLARIFYING LANGUAGE, YOU KNOW, AT THE NEXT TAC MEETING, GREAT. RATHER THAN DISPUTE THE SPECIFICS THAT MAY OR MAY NOT BE IN HERE. UM, IF, IF THAT'S OKAY. YOU GOOD CHASE? NO, RYAN, I'M GOOD. OKAY. I NEXT BOB'S NOT BACK. KATHY, I ACTUALLY HAD A DIFFERENT TOPIC, SO I DON'T KNOW IF WE'RE THROUGH THIS MAXIMIZATION. IT SOUNDED LIKE THAT WAS A TABLING OF THAT DISCUSSION. SO, SO ON THE, YOUR COMMENTS ON SOMETHING SEPARATE FROM MAXIMIZATION? YEAH, IT'S ON, UM, IT'S ON THE ERCOT LANGUAGE ABOUT THE UNACCEPTABLE RELIABILITY RISK. LET'S HOLD THAT FOR JUST A SECOND. OKAY. SO WHAT YOU'RE SAYING, YOU WANT TO TABLE THIS DISCUSSION FROM A MAXIMIZATION IN THE DATE ERIC, ERIC SAID THAT'S WHAT Y'ALL TALKED ABOUT. , I THINK WE ALL AGREE THAT UNITS WILL MAXIMIZE TO THEIR EQUIPMENT CAPABILITY. I THINK WE DISAGREE ABOUT WHAT THE LANGUAGE SAYS, WHATEVER VERSION WE'RE TALKING ABOUT, BUT I THINK WE ALL AGREE THAT YOU'RE GONNA MAXIMIZE CONCEPTUALLY TO THE EQUIPMENT CAPABILITY AND IF THAT'S TRUE, YEAH, WE'RE DONE WITH THAT. LET'S MOVE ON . SO CONCEPTUALLY WE WANNA MAXIMIZE TO EQUIPMENT CAPABILITY. THAT'S GOOD. WHERE THERE'S A DIFFERENCE BETWEEN WHAT THE LEGACY REQUIREMENT IS AND WHAT THAT MAXIMUM CAPABILITY THAT THAT BECOMES STATED BY THE UNIT AND GETS MODELED AND SUBMITTED TO ERCOT. IF, IF THERE'S A RIDE THROUGH EVENT THAT OCCURS AND THE, AND THE UNIT IS [06:15:01] UNABLE TO RIDE THROUGH, I MEAN THAT AT THAT POINT IN, IN MY MIND, THAT DOESN'T BECOME A PERFORMANCE FAILURE. BUT THAT BECOMES AN OPPORTUNITY FOR THAT UNIT TO DO A, AN ASSESSMENT, PUT TOGETHER A MITIGATION PLAN AND IMPLEMENT THAT MITIGATION PLAN WITH A DATE CERTAIN TO RESOLVE THE ISSUE. WE WE'RE SAYING THE SAME THING THERE. RESOLVE IT TO WHAT? RE RESOLVE IT COMPLETELY AND IF IT CAN'T BE RESOLVED COMPLETELY MODIFY THEIR CAPABILITIES, UPDATE THEIR MODEL AND PROVIDE THAT TO ERCOT. YES. AND, AND WRITING THOSE WORDS DOWN WILL BE IMPORTANT, BUT I THINK WE ALL A CON CONCEPT, THAT CONCEPT AND IF WE DID THAT A DATE 30 DAYS AFTER PUC APPROVAL IS MORE AMENABLE FROM A GROUP, FROM AN ERCOT STANDPOINT. IS THAT A YEAH, AND, AND I'M ASKING ERCOT. WELL, I THINK YOU HAVE TO THINK ABOUT THE OTHER THINGS THAT GO WITH THAT REQUIREMENT. I MEAN, ONE OF THE THINGS ENCORE EVEN BROUGHT UP ABOUT THE NEGATIVE SEQUENCE, UH, CURRENT. BUT, SO I THINK THAT IS A, SOMETHING THAT NEEDS TO BE DISCUSSED, BUT IT WOULD MAKE IT LESS RISKY. SO IT'S GOTTA, OBVIOUSLY ALL THIS HAS GOTTA BE CONSIDERED AS A WHOLE. BUT WHILE WE'RE TALKING ABOUT BROAD STUFF, I THINK THAT THE, THE, THE THING THAT I WAS ASKING ABOUT IS DO YOU HAVE TO, IF YOU HAVE A FAILURE, YOU'VE, YOU'VE GONE UP TO YOUR EQUIPMENT CAPABILITY. IN THEORY YOU HAVE A FAILURE, YOU DON'T MEET THAT, WHAT DO YOU HAVE TO REMEDIATE BACK TO? IT'S THE, DO YOU HAVE TO GO BACK TO WHERE YOU, WHERE YOU TOLD US YOU COULD GET TO OR DO YOU'D TO GO BACK TO THE LEGACY REQUIREMENT? OR WHERE DO YOU GO BACK TO IT'S THAT CURVE THAT STEVEN WAS SHOWING UP THERE EARLIER? I DON'T THINK THAT WAS CLEAR IN WHAT YOU JUST SAID. I'LL, I'LL, I'LL TAKE A STAB AT THIS AND TACK MEMBERS. IF, IF ANYBODY WANTS TO CORRECT OR JUMP IN, PLEASE DO. MY THOUGHT IS, I MEAN, IF, IF A UNIT HAS MAXIMIZED THEIR CAPABILITY AND HAS DETERMINED WHAT THAT IS, HAS MODELED IT AND TOLD WORK OUT WHAT THAT IS, IF AN EVENT OCCURS, THEY CAN'T WRITE THROUGH IT. THEY DO THE ASSESSMENT, THEY COME UP WITH A MITIGATION PLAN. IF THAT MITIGATION PLAN IS A, A SOFTWARE PARAMETER ISSUE THAT CAN BE ADDRESSED, YOU KNOW, THE EXPECTATION IS THAT THEY IMPLEMENT THAT AND MITIGATE IT. IF THAT TAKES THEM BACK UP TO THAT PREVIOUSLY STATED CAPABILITY, I MEAN THAT AT THAT POINT THE ISSUE'S CLOSED, RIGHT? IF IT DOESN'T QUITE GET BACK UP TO THAT MAXIMUM CAPABILITY AND THERE'S SOME OTHER NEW LIMITATION THERE THAT THAT'S DISCOVERED, THEN IT WOULD ALWAYS BE THEIR OBLIGATION TO UPDATE THAT CAPABILITY AND SUBMIT A REVISED MODEL. THIS IS, LET HIM POINT TO THINGS THAT THE ARABIA AND LET HIM, SO I THINK THERE'S TWO KEY ASPECTS TO, TO FLUSH THAT OUT FULLY. NUMBER ONE, WHEN THAT HAPPENS, IS IT A VIOLATION THAT THAT IS THAT PERFORMANCE FAILURE VIOLATION THAT THAT NEEDS TO BE CLEAR IN THAT MITIGATION PROCESS. I THINK THE OTHER THING IS, IS IF IT'S NOT SOFTWARE FIRMWARE, MEANING THEY HAVE A DESIGN FLAW, THE OEM IS CAPABLE, THE INVERTER'S CAPABLE, BUT THEY PUT IN A TRANSFORMER WITH HIGH IMPEDANCE AND THAT TRANSFORMER IS A LIMITATION. NOW ARE THEY REQUIRED TO FIX THAT DESIGN FLAW EVEN IF NOW IT LOWERS THAT CAPABILITY? THAT'S THE PLANT LEVEL REQUIREMENTS THAT WE'RE DEALING WITH. THAT IS A LITTLE BIT OF A COMPLICATION. YOU WENT A DIFFERENT PLACE THAN I DID. SO IF YOU, IF YOU, IF YOU TOLD US YOU WERE THE TOP KIND OF LITTLE L IN THE PURPLE AREA THERE, THAT WAS YOUR EQUIPMENT CAPABILITY, UM, AND THEN YOU HAVE A FAILURE, YOU CAN'T DO THAT IN, IN ACTUALITY THEN YOU HAVE TO MITIGATE. BUT WHAT DO YOU HAVE TO MITIGATE? DO YOU MITIGATE BACK UP TO THAT SAME PLACE WHERE YOU CAN RIDE THROUGH THAT AGAIN? OR DO YOU ONLY HAVE TO GO TO THE L THAT'S IN THE GREEN? YOU MITIGATE TO YOUR MAXIMUM CAPABILITY. IF YOU'VE IDENTIFIED A NEW ISSUE THAT LIMITS YOUR CAPABILITY, THEN OKAY, THAT IS WHAT IT IS. SO YOU'D GO TO THE GREEN AND, AND STEVEN, YOUR QUESTION ON IS IT A VIOLATION OR THAT'S WHAT I'M THINKING ABOUT IN MY HEAD TAG. PLEASE JUMP IN IT. TO ME IT IS NOT A PERFORMANCE VIOLATION IF IT IS SOMEWHERE BE, IF WE'RE LOOKING BETWEEN THE BLUE AND THE GREEN LINE, [06:20:01] I MEAN, IF IT DROPS BELOW THE LEGACY, YEAH, THAT'S A VI VIOLATION. IF IT'S A RESULT OF, I, I MAXIMIZED, BUT I, BUT I STILL MET THIS LEGACY REQUIREMENT, YOU KNOW, THAT'S A, THAT'S AN ASSESS, PUT TOGETHER MITIGATION PLAN AND FIX IT. NOW, IF, IF, IF THE UNIT FAILS TO DO THAT MITIGATION AND ASSESSMENT ACTION, I MEAN, AND TO ME THAT THAT'S JUST DAY-TO-DAY BUSINESS THAT FOLKS OUGHT TO BE DOING, THAT'S VERY SIMILAR TO WHAT WE SEE IN NRC STANDARDS, COLD WEATHER REQUIREMENTS, ALL THAT KINDA STUFF. I MEAN, YEAH, TO ME IN MY MIND THAT'S A, THAT'S A VIOLATION TYPE MATERIAL. SO JUST TO REPEAT BACK, WHAT I THINK I HEARD YOU SAY IS THAT THE, THE INITIAL PERFORMANCE FAILURE WOULD NOT BE A VIOLATION, BUT IF THEY FAILED TO MITIGATE TO GET BACK TO THEIR, UH, STATED PERFORMANCE CAPABILITY, THAT WOULD BE A VIOLATION. CORRECT. OKAY. OKAY. SO CAN WE WRAP THIS TOPIC UP? WE'VE GOT A QUEUE. I WANT KATHY AND CHASE ARE ON A SEPARATE TOPIC. NED, BOB, ARE Y'ALL ON A SEPARATE TOPIC OR ARE YOU TIED TO THIS ONE? YEAH, PRETTY KIND OF SORT. OKAY. UH, ALRIGHT, WE'RE GONNA CHANGE TOPICS. KATHY. THANK YOU COLIN. UM, STEVEN, ON THE PROPOSED LANGUAGE FROM ERCOT IN THE SECTION THAT TAKES OUT THE RELIABILITY ASSESSMENT THAT'S IN COMMERCIALLY REASONABLE AND INSTEAD PUTS THIS UNACCEPTABLE TO ERCOT RISK. UM, YOU HAD MENTIONED THAT THIS WAS, YOU KNOW, THAT YOUR GENERAL APPROACH WAS MODELED AFTER PRC 29, BUT IN 29, I'M NOT FAMILIAR WITH ANYTHING THAT WOULD BE CLOSE TO THIS KIND OF A STANDARD IN 29. THE, FOR THE LEGACY RESOURCES, THEY SUBMIT THEIR REQUIREMENTS DOCUMENT AT ALL. IT'S PROPERLY MODELED AND THAT'S IT. RIGHT? I I, I THINK, UM, I'M NOT SURE WHERE THE STATEMENT GOT THAT MISUNDERSTOOD THAT WE'RE MODELING AFTER PRC 29. NO, 2 45 WAS PRIOR TO PRC 29. I THINK THAT OUR APPROACH TO GIVING A ONE-TIME EXEMPTION DOES HAPPEN TO ALIGN WITH WHERE THE NERC DRAFTING TEAM IS GOING. BUT AS FAR AS THESE REQUIREMENTS HERE, THEY'RE, THEY'RE NOT WITH, UH, PRC 29. I DON'T MEAN TO SAY MODEL, MAYBE I SAID MODEL. I THINK YOU, YOU SAID THE WORDS, IT'S A SIMILAR APPROACH TO 29 AND IN 29, ARE YOU FAMILIAR WITH AN APPROACH LIKE THIS THAT WOULD HAVE A SUBJECTIVE UNACCEPTABLE RELIABILITY RISK EVALUATION AFTER THE UNIT HAS DEMONSTRATED TO YOU? THEY'VE DONE EVERYTHING THEY'RE PHYSICALLY CAPABLE OF DOING. SO THE NERC APPROACH AND WHAT THE DRAFTING TEAM IS WORKING ON RIGHT NOW, AND I'VE ONLY SAT IN ON A, ON A COUPLE OF THE RECENT MEETINGS, NOT ALL OF THEM, BUT WHEN WE TALKED ABOUT THIS TOPIC, THEIR APPROACH IS A LITTLE BIT SIMILAR TO THE ROSS APPROVED VERSION, I WOULD SAY, IN THAT IT WENT IN HERE IS YOUR LIMITATIONS, RCS PLANNING COORDINATORS DEAL WITH IT. BUT THE ASSUMPTION IS THAT THE RCS, IF THEY HAVE A RELIABILITY ISSUE, ARE GOING TO RESTRICT GENERATION HOWEVER THEY NEED TO, TO ENSURE RELIABILITY. SO WHAT WE HAVE COMMENTED TO THE DRAFTING TEAM IS IF YOU LOOK AT FERC ORDER 9 0 1, THEY SAY THE PLANNERS AND THE COORDINATORS HAVE TO ADDRESS THE RELIABILITY RISK NER R'S APPROACH BECAUSE THEY PUT IN THEIR WORK PLAN TO DELAY THOSE REQUIREMENTS FOR IT IS THAT UNTIL THOSE REQUIREMENTS ARE CLARIFIED, THE RC WOULD RESTRICT GENERATION IF THEY ENDED UP SEEING AN UNACCEPTABLE RELIABILITY RISK, THAT WOULD BE THE LEVERAGE AS THEY CALLED IT, TO GET THE GENERATORS TO RETROFIT. AND SO WE'VE, WE'VE TAKEN A DIFFERENT APPROACH HERE WHERE WE'D LIKE TO PROACTIVELY LOOK AT THE IMPACT AND GIVE A FORWARD LOOKING SIGNAL ABOUT WHETHER OR NOT WE'RE GONNA HAVE TO TAKE SUCH ACTIONS SO THAT THE ENTITY CAN REEVALUATE. DO I WANT TO LOOK AT MY CUT LINE AGAIN, BEFORE I MOVE, I MOVE FORWARD. OKAY. I THINK, I THINK WE LOOK AT THAT DIFFERENTLY, BUT I APPRECIATE YOUR PERSPECTIVE, CHASE. THANK YOU COLIN. UH, CHASE MADE THE SOUTHERN POWER, UM, QUICK COMMENT ON THE DATE AND THEN THE QUESTION ON THE SAME TOPIC ON THE, THE EXEMPTION RELIABILITY CRITERIA. UM, I, I THINK FOR, YOU KNOW, THE DIFFERENCE BETWEEN THE [06:25:01] 23 DATE AND 24 DATE, I, I THINK THAT IS GOING TO BECOME LESS OF AN IMPORTANT DISTINCTION WITH THE MAXIMIZATION VIA SOFTWARE AND SETTINGS CONCEPT THAT WE HAVE BEEN TALKING ABOUT. UM, YOU KNOW, I THINK RYAN DID A GOOD JOB OF SUMMARIZING THIS IN HIS PRESENTATION EARLIER, BUT, YOU KNOW, 97% OF THE MEGAWATTS IN, IN THE QUEUE WITH IAS BETWEEN THOSE TWO DATES OR BATTERY AND SOLAR. AND YOU KNOW, I THINK WHAT OUR, THE KNOWLEDGE THAT WE HAVE AT THIS TIME IS THAT THOSE WILL HAVE VERY GOOD CAPABILITIES. I THINK, UM, A VAST MAJORITY, YOU KNOW, A, A GOOD AMOUNT, VAST MAJORITY OF THEM WILL BE ABLE TO HAVE THE CAPABILITIES TO MEET PREFERRED REQUIREMENTS. BUT, UM, JUST BECAUSE OF THE, SOME OF THE COMPLEXITY AND CHALLENGES OF THE LENGTH OF DESIGN AND DEVELOPMENT CYCLES AND THE FACT THAT I TRIPLE E 2000.2 IS NOT FINALIZED YET. YOU KNOW, THERE MAY BE SOME THAT ARE NOT ABLE TO, AND THAT'S KIND OF WHAT SOME OF THE, THE, THE LENIENCY THAT I THINK THE JOINT COMMERCE HAVE BEEN LOOKING FOR, FOR, UM, YOU KNOW, I IBR WITH IAS IN THAT, IN THAT BUCKET WHILE WE'VE BEEN SEEKING FOR THAT. BUT, YOU KNOW, THE MAXIMIZATION CONCEPT I THINK WILL DRIVE WHERE A LOT OF THOSE, THE VAST MAJORITY OF THOSE RESOURCES ARE GONNA BE ABLE TO IMPROVE THEIR CAPABILITIES APPROPRIATELY TO THE, YOU KNOW, TO MEET OR BE AT LEAST BE CLOSE TO THE PREFERRED REQUIREMENTS. THAT'S MY FIRST COMMENT. UM, QUESTION IF, UM, YOU CAN PULL UP PLEASE, THE RELIABILITY CRITERIA LANGUAGE THAT WE WERE JUST LOOKING AT IN THE RECENT ERCOT RED LINES, UM, THE INSTABILITY AND THE LOSS OF YES, THIS LANGUAGE. UM, STEVEN, I GOT A QUESTION FOR YOU. JUST CAN YOU HELP, UH, ELABORATE, UM, HOW ERCOT, YOU KNOW, JUST THE ERCOT PROCESS AND METHODOLOGY FOR COMING UP WITH THE CRITERIA. WHAT, WHAT WAS ERCOT THINKING ABOUT? ANY SORT OF ANALYSIS BEHIND COMING UP WITH, YOU KNOW, THE NUMBERS IN A LITTLE I AND LITTLE DO THREE, UM, YOU KNOW, IS IT TIED TO U-F-L-U-F-L-S, UH, TRIGGERING RISK, ANY OTHER BIG KIND OF ERCO, YOU KNOW, RELIABILITY RISK ITEMS THAT ERCOT IS THINKING ABOUT? YEAH, SO THE STEVEN LEASE WITH ERCOT, UH, I THINK I IS PRETTY WELL UNDERSTOOD INDUSTRYWIDE AS BEING, UH, AN IR WELL, UH, IT'S FEDERAL POWER ACT SECTION TWO 15 DEFINED. IT'S THE OPPOSITE OF WHAT'S DEFINED AS RELIABLE OPERATIONS. SO IF YOU SEE THOSE, THOSE ASPECTS, IT'S UNRELIABLE OPERATIONS. THE LOSS OF GENERATION CAPACITY EQUAL TO OR GREATER THAN 500 IS ALIGNED WITH THE REPORTING CRITERIA. WE HAVE TO REPORT ANYTHING THAT IS GREATER THAN THAT. SO IF WE'RE GOING TO LOOK AT AN ASSESSMENT, IT'S AS IF WE'RE PLANNING ON ALLOWING EVENTS TO OCCUR THAT WOULD EXCEED THE CRITERIA THAT WE HAVE TO REPORT AND MITIGATE TO NERC THE LOSS OF LOAD EQUAL OR GREATER TO THAN 75 MEGAWATTS IS FROM THE TRANSMISSION PLANNING STANDARD TPL 0 0 1, WHICH IS A PLANNING CRITERIA THAT FOR PARTICULAR CONTINGENCIES, YOU CANNOT ALLOW MORE THAN 75 MEGAWATTS OF NON-CONSEQUENTIAL LOAD LOSS AS A PLANNING CRITERIA. SO I'LL STOP THERE BECAUSE THOSE ARE THE THREE THAT YOU ASKED ABOUT. YEAH, THANKS STEVEN. I THINK I NEED A LITTLE BIT MORE TIME JUST TO FULLY DIGEST AND THINK ABOUT THIS SOME MORE, BUT I THINK JUST ONE INITIAL PIECE OF FEEDBACK IS UNDER UNDERSTAND THAT THIS 500 MEGAWATT THRESHOLD IS A, IS KIND OF THAT THRESHOLD FOR A NEWARK REPORTABLE EVENT. YOU KNOW, I THINK IT MAY NOT BE THE, MAY NOT BE THE BEST BAROMETER JUST GIVEN THAT, YOU KNOW, WHAT IS THE, WHAT, WHAT IS THE RISK POSED TO, UM, THE ERCOT SYSTEM, FOR EXAMPLE, THE UFLS KIND OF TRIGGER THAT. I KNOW I, I SAW AT SOME POINT IN, UM, PRIOR ERCOT PRESENTATIONS, UM, IN A, IN A GRAPH IS IS OBVIOUSLY HIGHER. AND I'M NOT SAYING WE GO FULLY TO THE UFLS LINE, I KNOW THERE NEEDS TO BE SOME MARGIN, BUT, UM, JUST, YOU KNOW, NOT SURE IF EXACTLY WHAT THE, THAT REPORTABLE THRESHOLD IS FOR THOSE NERC EVENTS, IF THAT IS THE EXACT RIGHT, UM, WAY TO DETERMINE THIS. AND I'M NOT GIVING YOU A ALTERNATE AT THE MOMENT, BUT, UM, SOME WILL THINK ABOUT SOME MORE, BUT THAT'S JUST AN INITIAL PIECE OF FEEDBACK. AND THEN HOW, HOW SHOULD I THINK ABOUT IF THERE IS A LEGACY IBR WHO IS 500 MEGAWATTS OR GREATER ARE, ARE THEY JUST AUTOMATICALLY CAN'T, YOU KNOW, AUTOMATICALLY DISQUALIFIED FROM [06:30:01] RECEIVING AN EXEMPTION OR HOW, HOW WOULD THAT, HOW WOULD ORCO, UM, APPROACH SUCH SITUATION? YEAH, I THINK FOR AN INDIVIDUAL UNIT THAT WOULD BE, UH, AN N MINUS ONE SCENARIO, WHICH WE DO PLAN FOR. SO THIS WOULD, I MEAN, A FURTHER CLARIFICATION WE COULD MAKE IS MULTIPLE UNIT LOSS OF GENERATION CAPABILITY SO THAT IT'S CLEAR IT'S NOT A SINGLE UNIT. OKAY. THANKS STEVEN. I THINK THAT'S ALL FOR ME FOR RIGHT NOW. OKAY. NED, I'M GONNA TAKE US BACKWARDS JUST TO MAKE SURE. 'CAUSE I'M, IT'S, IT'S LATE. I'M, I'M , I'M DRAGGING. BUT UH, COLIN, YOU WERE WALKING THROUGH THE, UM, THE FAILURE TO RIDE THROUGH STEPS AND I WANNA MAKE SURE I UNDERSTOOD THIS CORRECTLY. THE, THE, I I THINK KEY IN THERE IS IF YOU HAVE A FAILURE TO RIDE THROUGH, YOU HAVE TO DO, YOU, YOU'RE GONNA INVESTIGATE IT AND THE RESULTS OF THAT INVESTIGATION WILL DETERMINE WHETHER THERE IS ANY MODEL UPDATES THAT ARE NEEDED, RIGHT? THE MITIGATION WOULD BE, UH, WELL DETERMINATION ON, ON WHETHER OR NOT THERE'S MITIGATION TO BE HAD, WHETHER THERE'S A SOFTWARE THAT THAT NEEDS TO BE MADE OR SOMETHING LIKE THAT. THEN THAT WOULD DRIVE A MODEL CHANGE BECAUSE I THINK THAT GOES INTO THE BIGGER 1 0 9, UH, FRAMEWORK. SO THAT WOULD, THAT WOULD BE THE CLOSED LOOP, IS THAT, IS THAT THE WAY YOU WERE CAPTURING THAT? I BELIEVE THAT'S CORRECT. OKAY. I MEAN, SO, SO IT, IT, IT DEPENDS ON WHAT'S FOUND, RIGHT? I MEAN, YOU DO THE ASSESSMENT. IF IT WAS, YOU KNOW, WE JUST DID A FIRMWARE UPGRADE AND, AND IT LOST ITS BRAIN AND THE SETTING FELL OUT. I MEAN, TO ME THAT YOU GO, YOU GO RESTORE THE SETTINGS AND THERE'S NO MODEL CHANGE REQUIRED. YOU JUST IMMEDIATELY FIX THE ISSUE. OKAY. I I, I THINK THAT MAKES SENSE. AND THERE, THERE, JUST FOR CLARITY, THE REASON WHY I WANTED TO CLARIFY THAT IS BECAUSE THERE IS A BALANCE TO STRIKE BETWEEN, YOU KNOW, MAKING SURE THAT, YOU KNOW, WHEN THERE ARE ISSUES THAT WE'RE CORRECTING AND, AND GETTING ERCOT THE BEST MODELING DATA THAT WE REASONABLY CAN WITHOUT ALSO CONSTANTLY BEING IN A, IN A MODELING DO LOOP. AND, UH, YOU KNOW, A LOT OF, I THINK A LOT OF US ALREADY SPEND A LOT OF TIME AND, AND RESOURCES ON THAT. AND SO WANNA MAKE SURE THAT IF THERE'S AN ADDITIONAL STEP THAT COMES THERE THAT THAT'S WARRANTED. WOW. OKAY. TRYING TO SUM UP A LITTLE BIT HERE. TRYING TO FIGURE OUT WHERE WE'RE AT 'CAUSE I'M NOT SURE. UH, SO HERE'S WHAT I WAS THINKING AS A CONCEPT IS THAT ONCE THE PROTOCOL IS APPROVED, THEN ALL IBR, REGARDLESS OF WHAT DATE THEY'RE PUT IN, ARE GOING TO BE REQUIRED TO GO TO THEIR MAXIMUM CAPABILITY. SO THE DAY OF IMPLEMENTATION AND THEN WE COULD PUT SOME DATE OUT THERE IN THE FUTURE, YOU KNOW, OR EVEN ONE FOR A DROP DEAD DATE TO BE MAXIMIZED THAT ALL IBR ARE GONNA HAVE TO COME IN WITH THEIR PLAN. AND PART OF THAT PLAN WILL BE WHAT SETTING CHANGES NEED TO BE MADE, WHICH WILL GO THROUGH 1 0 9 AND THAT'LL GET THE MODELS UPDATED. BUT YOU SEE KIND OF WHERE I'M GOING. SO DAY ONE YOU GOTTA START LOOKING AT IT. SO WE SET OUT THERE AND SAY, OKAY, BY SUCH AND SUCH DATE, ALL IBR HAVE TO HAVE THEIR PLAN IN IF THEY'RE NOT ABOVE THAT. SO I, I THINK THE DATE THAT WE HAVE IN THERE IS IMPLEMENTATION DATE. AND SO I WANT TO BE CAREFUL IF YOU START SAYING YOU GOTTA HAVE A PLAN THAT WE NEED TO BE CLEAR ABOUT WHICH DATES ARE THE PLAN, WHICH DATES ARE IMPLEMENTATION. ABSOLUTELY AGREE WITH THAT. YEAH, THAT I AGREE. SO WE NEED TO, TO WORK THAT ON, YOU KNOW, 'CAUSE YOU, I THINK, LIKE I SAID, EITHER WAY YOU GOTTA HAVE YOUR PLAN IN AND THERE'S GOTTA BE A DROP DEAD DATE SO YOU KNOW, IT CAN'T DRAG ON FOREVER. AGREE WITH THAT. UH, YOU KNOW, WITHIN SOME REASON 'CAUSE WE'RE ALSO ALL GONNA BE HITTING THE SAME VENDORS AT THE SAME TIME, SO THERE'S GONNA BE SOME ISSUES THERE POTENTIALLY. SO THAT'S THE KIND OF WAY I'M LOOKING AT IT. SO I THINK IT TAKES, AND THEN IF YOU'RE AT YOUR MAXIMUM CAPABILITY, WHEREVER THAT IS, THEN IF YOU HAVE AN ISSUE, WE'VE ALREADY TALKED THROUGH WHAT YOU WOULD DO TO DO THAT. I'M STAYING AWAY FROM TWO THINGS. THE COMPLIANCE PIECE ON WHETHER IT'S COMPLIANCE OR NOT, AND WHAT MAXIMUM CAPABILITY ACTUALLY MEANS. UH, WE CAN HIT THOSE LATER. BUT TO ME THEN THERE'S TWO THINGS WE DON'T HAVE TO WORRY ABOUT IS THE BACKDATING OR FRONT DATING OR ANYTHING ELSE. THAT'S JUST THE WAY I SEE IT. THE SECOND THING WE DON'T HAVE TO REALLY WORRY ABOUT IS IF YOU'RE HAVING TO GO TO YOUR MAXIMUM CAPABILITY, IT'S GOOD TO KNOW WHERE THE, THE PREFERRED IS, UH, AND EVERYTHING. BUT IF YOU COULD DO BETTER THAN THAT, YOU'RE REQUIRED TO GO BETTER THAN THAT. IF YOU'RE, IF YOU CAN'T DO BETTER THAN [06:35:01] THAT, YOU'RE GONNA GO TO YOUR MAXIMUM CAPABILITY. SO REALLY THAT JUST BECOMES A NUMBER OUT THERE AND REALITY IS GONNA BE WHAT IT IS AND THEN WE'LL WE'LL GO FROM THERE. SO THAT'S KIND OF WHAT I'VE BOILED THIS THING DOWN TO. AND SOMEBODY TOLD ME HOW SCREWED UP I AM, NOT THAT YOU'RE SCREWED UP, BUT , THE UM, THE REASON I HAD THE FORWARD DATE IS I JUST THINK THAT SETS A GOOD PRECEDENT INSTEAD OF SETTING THE PRECEDENT THAT WE CAN ALWAYS GO BACKWARDS IN TIME. WELL, SO THAT'S THE ONLY REASON I PUT THAT THERE. KNOWING WHAT YOU SAID WOULD OCCUR, I THINK WE KIND OF SAID THE SAME THING. 'CAUSE I SAID WHENEVER THE NPRR COMES INTO EFFECT, THEN YOU'RE GONNA HAVE A CERTAIN TIME PERIOD TO COME WITH YOUR PLAN. AND EVEN IF YOU SAID, I, YOU KNOW, EVEN IF BACKDATED IT'S, I I THINK ONCE WE SAY MAXIMIZATION, ALL THAT KIND OF GOES AWAY. BUT THAT'S JUST MY THINKING IS LIKE I SAID, Y'ALL TELL ME WHERE I'M MESSED UP. I I JUST THINK IT'S IMPORTANT TO UNDERSTAND WHEN WE TAKE, WHEN WE SAY BACKDATING AND WE START, REMEMBER IF WE SET AN SGIA DATE FOR THE FUTURE, RIGHT? THEN THE UNITS THAT COME IN WITH THESE CAPABILITIES WILL BE 1, 2, 3 YEARS OUT FROM THAT TIMEFRAME. SO IF YOU SET IT AT LET'S SAY 30 DAYS AFTER PUCT APPROVAL, THEN IT'S SGI AFTER THAT, SO YOU'RE TALKING 20, 26, 20 27, 20 28 BEFORE THOSE UNITS START COMING ON WITH THOSE CAPABILITIES AND, AND THE PERFORMANCE REQUIREMENTS WHEN YOU DON'T REFERENCE IEEE 2,800, I JUST WANT EVERYBODY TO BE CLEAR. I WANT, I WANT EVERYBODY TO UNDERSTAND THESE ITEMS. YOU DON'T GET, SO THERE'S NO PERFORMANCE REQUIREMENT OR DESIGN REQUIREMENT FOR THEM TO LOOK AT TRANSIENT OVER VOLTAGE. THAT MEANS THAT BIG LOADS TRIPPING OFF. COME ON. IF YOU HAVE THOSE ISSUES, IF YOU HAVE THOSE LOADS IN YOUR AREA, THEY'RE GONNA BE MORE SUSCEPTIBLE TO TRIPPING IF YOU'RE HAVING MISSED OPERATIONS IN WHEAT GRID AREAS BECAUSE YOU DON'T HAVE NEGATIVE SEQUENCE CURRENT INJECTION, YOU'RE GOING TO BE LOOKING AT THAT. SO I JUST WANT EVERYBODY TO BE INFORMED THAT WHEN YOU PUSH OUT THAT DATE, THE 20 PLUS GIGAWATTS, YOU LOSE THAT. AND IF WE DECIDE THAT THAT'S OKAY, BUT JUST WANNA BE TRANSPARENT ABOUT IT. SO STEVEN, ARE YOU, CAN I, CAN I ADDRESS THAT SINCE I'M, AM I STILL IN OR GO AHEAD OR YOU WANT ME TO COME BACK? OKAY. MY, MY QUESTION IS, IS IF YOU SET IT AT 2023, YOU SAY, OKAY, 2023 IS THE DATE. WELL OBVIOUSLY THEY'RE NOT GONNA MEET IT. THEY'RE GONNA BE WHEREVER THEY ARE AND ALL YOU'RE GONNA GET IS EVERY, IS THOSE DURING THAT TIMEFRAME COMING IN AND THEY'RE GONNA GIVE YOU A PLAN ON WHEN THEY'RE GONNA BE ABLE TO GET THERE. YOU'RE NOT GONNA GIVE 'EM AN EXEMPTION, BUT YOU'RE GOOD. BUT THERE'LL BE A PLAN ON THEM TO GET TO THEIR MAXIMUM CAPABILITY. OKAY? BECAUSE WE KNOW THEY'RE NOT LIKELY NOT GONNA BE ABLE TO MAKE IT BECAUSE THOSE WERE, BUT MAXIMUM CAPABILITY IS TIED TO THE PERFORMANCE REQUIREMENTS WHICH DON'T REFERENCE THESE IEE 2,800 ELEMENTS. YEAH, THAT'S WHAT I'M TRYING TO BE CLEAR ON YOU. YOU MISS THAT IT IS A DIFFERENCE AND WE CAN DECIDE THAT THAT CAN BE A DECISION WE MAKE. I JUST WANT EVERYBODY TO UNDERSTAND IF WE START SEEING PROBLEMS LIKE THAT, WE MISS THE OPPORTUNITY TO GET THESE REQUIREMENTS IN ON THESE NEW RESOURCES THAT ARE NOT YET COMING. THEY'RE NOT YET ONLINE, BUT THEY, THEY HAVE CAPABILITIES. THEY'RE JUST NOT GONNA BE TURNED ON AND DESIGNED TO USE THOSE CAPABILITIES. DON'T THEY HAVE TO BECAUSE THEY'RE THE MAXIMIZATION REQUIREMENT. YEAH, THE MAXIMIZATION IS TIED TO THE PERFORMANCE REQUIREMENTS IN THE NODAL OPERATING GUIDE SECTIONS ABOVE WHICH DO NOT INCLUDE, IT'S IN A SUBSECTION INSTEAD OF THE SECTION ITSELF. YEAH, WE, THEY ONLY MAKE THE GENERAL REFERENCE FOR NEW PREFERRED. SO IF YOU MISS THAT WINDOW, YOU DON'T GET THESE REFERENCES FOR MAXIMIZATION AND THEY AREN'T INCORPORATED IN THE DESIGN OF THE PLANS. BUT YOU STILL HAVE TO MAXIMIZE, YOU MAXIMIZE YOUR CURVES, YOU MAXIMIZE THOSE OTHER ELEMENTS. BUT THESE ELEMENTS HERE IS WHAT YOU LOSE. DAMN, THAT'S NOT WHAT IT SAYS. UH, ONE OF THE POINTS I WAS GONNA MAKE WAS EXACTLY THAT. SO I MEAN, IF WE WANT TO FIX THESE THINGS, WE NEED TO SAY MAXIMIZE YOUR CAPABILITY INCLUDES THESE ITEMS, MEANING THESE ITEMS. THAT WOULD BE ONE WAY TO FIX THAT. UM, IS, IS THERE A REASON WE WOULDN'T DO THAT? I, I CAN'T THINK OF ANY RIGHT OFF THE TOP OF MY HEAD, BUT I'LL HAVE TO THINK THROUGH THAT. THERE'S STILL THE ISSUE OF WHAT MAXIMIZE MEANS. YEAH, IT'S STILL, YEAH, IT'S, THAT GETS BACK TO THE DEFINITION OF WHAT'S MAX MAX, IT'S BEEN HERE TOO LONG, WHAT THAT MEANS. [06:40:01] SO I I THINK I CAN SPEAK TO SOME OF THAT. WELL, IF YOU WANT ME TO LET, LET'S RUN THROUGH THE QUEUE. OKAY. YEAH. LET ME, LET ME FINISH THE OTHER POINT TOO. UH, THE, SO THE OTHER THING POPS SAID, UM, WE'RE YOU'RE GONNA MAXIMIZE YOUR CAPABILITY, UH, ALWAYS SO YOU DON'T EVEN NEED THE 2,800. SO THE FIRST ISSUE IS THE THIS THING, THE SECOND ISSUE IS AT SOME POINT WE WANT TO SAY, WELL YOUR MINIMUM CAPABILITY HAS TO BE 2,800. IT'S NOT JUST A MATTER BECAUSE YOU COULD ALWAYS JUST BE BUYING OLD JUNK. YOU KNOW THAT I I GET THAT. YEAH, YEAH. OKAY, I UNDERSTAND THAT. SO WE DO NEED TO HAVE THAT IN THERE SOMEWHERE. ERIC SCHUBERT NOW, UM, I'M GONNA SPEAK AS A NON-ENGINEER HERE, BUT WE TALK ABOUT MODELING AND PLANS AND SUBMITTING THEM TO ERCOT. ONE THING WE NEED TO CONSIDER, IT DOESN'T HAVE TO BE IN THIS STR OF TODAY, IS PROVISIONS. SO THERE ARE SUBSTANTIAL PENALTIES IF THEY MISREPRESENTED WHAT THEY COULD DO BECAUSE IF THEY SAID YES, WE CAN DO UP TO THE THIS MAX THAT YOU WANT. IT TURNS OUT THAT THEY CAN'T, IF YOU DON'T PROVIDE AN INCENTIVE FOR THEM TO BE TRUTHFUL, THEN THEY'RE GOING TO YOU, YOU MIGHT HAVE SOME PARTIES WHO MIS MISREPRESENT WHAT THEY CAN. SO I THINK THERE NEEDS TO BE A PENALTY ASSOCIATED WITH THAT SO THEY GET HONEST INFORMATION ON THE CA CAPABILITIES OF ANY PARTICULAR UNIT. ED, CAN I COMMENT ON THAT? YOU PUT ME IN THE QUEUE. ALRIGHT BOB. OKAY. I UNDERSTAND WHERE YOU'RE COMING FROM. UH, MY PROBLEM WITH THAT IS, IS THE WAY YOU DETERMINE THERE'S NO FINANCIAL BENEFIT TO TO, TO NOT PUT IN WHAT YOU PROPERLY HAVE AND WHAT YOU'RE DOING IS, IS IT'S NOT JUST THE, THE OWNER OF THAT ASSET COMING IN AND SAYING, OH, HERE'S WHAT I CAN DO THAT HAS TO BE WORKED OUT WITH THE OEM AND ALL OF THEM ON WHAT THE MAXIMUM CAPABILITY OF THAT CAN BE. AND THAT'S ALL GONNA BE DOCUMENTED ONE WAY OR ANOTHER. SO THAT'S WHY I HAVE A LITTLE PROBLEM WITH THAT. I UNDERSTAND WHAT YOU'RE TALKING ABOUT, BUT I'VE HEARD SEVERAL TIMES STEVEN SAY THAT THEY HAVE GONE BACK TO AN, AN OPERATOR AFTER AN EVENT AND THEY FELT THAT THEY HADN'T BEEN LE THAT, THAT THE PARTY HADN'T LEVELED WITH THEM AND YOU KNOW, YOU JUST WANNA MAKE SURE THAT THEY, IF YOU'RE RIGHT BOB, THEN THE PENALTIES, THE PENALTIES THAT ARE SET UP WON'T BE KICKED IN BECAUSE PEOPLE WILL PROVIDE IT HONESTLY. BUT YOU NEED TO MAKE SURE YOU HAVE SOME KIND OF INCENTIVE FOR ALL PARTIES TO BE UPFRONT AND HONEST WITH WHAT THEY CAN DO RATHER THAN TRYING TO TELL SOMEONE WHAT HE WANTS TO HEAR. RIGHT. ISN'T THAT GO BACK TO THE MODELING ISSUE REALLY IS WHAT THAT GOES BACK TO WHERE IT IT'S DESIGNED TO. OKAY. UM, IT IT THE OEMS AND THEY'LL TELL YOU I CAN MAKE MY EQUIPMENT COMPATIBLE, BUT THE DEVELOPERS COME IN AND EVERYTHING ELSE THAT'S BALANCED OF THE PLANT HAS TO BE COORDINATED WITH IT TO MAKE SURE THAT IT CAN WORK PROPERLY. IF THEY DON'T HAVE THOSE REQUIREMENTS, THEY WILL LOOK FOR THE LEAST COST OF THE LEAST COST WAY OF GETTING INTERCONNECTED. AND SO YOU NEED CLARITY SO THAT THEY FACTOR THOSE THINGS INTO THE DESIGN UPFRONT AND THEN IT'LL WORK. YEAH. OKAY. ALRIGHT, THANKS. GOOD QUESTION BOB. SO IT'S FIVE, I'D LIKE TO START TRYING TO WRAP THIS UP, BUT ON, ON THIS SPECIFIC TOPIC, DAN, STEVEN, IS THIS SOMETHING THAT Y'ALL COULD THINK ABOUT IN, IN THE TERMS OF MAXIMIZING CAPABILITIES, HOW TO INTEGRATE THE OVERALL I TRIPLE E 2,800 AS AS, AS THE TARGET AND NOT JUST THE, THE ABOVE REFERENCED SECTIONS AND BRING THAT BACK FOR FRIDAY NEXT WEEK? I, I THINK WHAT I'M HEARING IS THAT Y'ALL WOULD LIKE A CONCEPT THAT PRESERVES A FUTURE DATE. SO NOT, DOESN'T GO TO 6 1 23 BUT GOES TO 6 1 24 OR SOME FUTURE TIME DATE. BUT WE'LL PUT THE ASPECTS IN FOR EVEN THE LEGACY TO GO UP TO IEEE 2,800 UP TO THEIR MAXIMUM IS TO THE EXTENT THEY CAN AND, AND MAKE SURE THAT THAT CONSTRUCT IS PRESENTED IN LANGUAGE. YES. IS THAT CORRECT? BUT IS THAT WITH SOFTWARE SETTING PARAMETERS OR HARDWARE TOO? RIGHT? THAT'S THE RUB. WHY CAN'T IT BE EVERYTHING? EVERYTHING, MAXIMIZE EVERYTHING YOU CAN, BUT HAVE THAT TAC APPROVED COST CAP. THE THE COST CAP IS WHAT MAKES IT DIFFICULT. I KNOW, BUT IT'S GOING TO THE YEAH, THE, THE CHEAP STUFF WILL FLOAT TO THE TOP AND THE CHANGE IN TURBINE BLADES WILL NOT BE FEASIBLE. [06:45:01] RIGHT? I MEAN I IT SEEMS LIKE THAT'D BE EVEN SIMPLER IF YOU DID THAT. WELL WE, WE'VE STILL GOTTA ADDRESS WHERE WE DRAW THE LINE. YEAH. SO I THINK THAT'S KIND OF AGNOSTIC TO STATING THE REQUIREMENT. YEAH, WE, WE GOTTA FIGURE IT OUT, MAXIMIZE EVERYTHING THAT'S TECHNICALLY FEASIBLE AND THEN TAX SAYS, BUT YOU ONLY HAVE TO SPEND X PERCENT. SO I MEAN SINCE IT'S 5 0 3, THAT'S A POINT OF DISAGREEMENT. SOFTWARE SETTINGS, PARAMETERS, POINT OF AGREEMENT, HARDWARE CHANGES, POINT OF DISAGREEMENT, HOW TO ADDRESS THAT POINT OF DISAGREEMENT. SO IF Y'ALL, I THINK IF WE COULD GET IDEAS, WE'LL WE'LL BUILD THAT IN, BUT THEN WE'LL NEED HELP TO OFFER PROTECTION. SO THAT INTENTIONAL DESIGN TO LOWER STANDARD ON THE HARDWARE SIDE IS, IS NOT A LOOPHOLE. AS LONG AS WE CAN PROTECT AGAINST THAT. I THINK CONCEPTUALLY WE'RE PRETTY CLOSE. OKAY. DAVE IS ALREADY, UH, JUST GIVEN THE TIME, I'LL WITHDRAW MY COMMENT. THANKS. OKAY. STEVEN, ARE APPRECIATE YOU, YOU, YOU WALKING THROUGH THIS. ARE, ARE THERE ANY OTHER SUPER BIG ROCKS THAT WE JUST NEED TO INTRODUCE TO THE GROUP? I I THINK IT'S IMPORTANT. TWO, TWO QUICK THINGS. OKAY. FOR Y'ALL TO THINK ABOUT. UM, OR THREE THINGS, I'M SORRY, EXTENSION. WE HAVE A PARAGRAPH THAT HOPEFULLY Y'ALL CAN EVALUATE AND SEE IF Y'ALL AGREE. THIS IS WHEN WE WOULD ALLOW EXTENSIONS. I THINK THAT YOU'LL ALSO NEED TO PAY ATTENTION TO THE CONCEPT OF REVISITING A, UM, A, A PREVIOUS EXEMPTION. SO IF, IF WE ALLOW AN EXEMPTION BUT THEN ALL OF A SUDDEN WE GET A BUNCH OF MODEL CHANGES IN AND NOW THE AS ASSESSMENTS SHOW A RISK THAT WASN'T THERE PREVIOUS, WE HAVE A CONCEPT OF REVIEWING THAT EXEMPTION. SO I WOULD ASK Y'ALL TO PAY ATTENTION TO THAT ONE. AND THEN FINALLY IN THE BOTTOM SECTION, IF YOU LOOK AT THE PERFORMANCE FAILURES IN TWO POINT 13, I WOULD ASK THAT Y'ALL ALSO EVALUATE THOSE CHANGES. ESSENTIALLY WE'RE TRYING TO TREAT ALL IBR REGARDLESS OF DATE THE SAME, INVESTIGATE, MITIGATE, IMPLEMENT, AND KEEP IN THAT STRUCTURE THE SAME. SO THOSE ARE SOME KEY AREAS I WOULD ASK Y'ALL TO UH, REALLY FOCUS IN ON AND BRING SOME FEEDBACK. THANK YOU. THANKS STEVEN. OKAY, SO A COUPLE OF ACTIONS THAT I HAD JUST JOTTED DOWN HERE. I MEAN, SO ON THE, THE CONCEPT AROUND MAXIMIZING CAPABILITY, HAVING THE REQUIREMENT TO ASSESS AND MITIGATE, MAKING SURE THAT THAT KIND OF PERMEATES THROUGH THIS WHOLE, WHOLE PROCESS THAT ERCOT IT. IS THIS SOMETHING THAT YOU CAN TAKE BACK AND LOOK AT THAT THROUGH THAT LENS AND SEE WHAT ADDITIONAL CHANGES ARE NEEDED? AND THEN KIND OF PART TWO OF THAT IS, YOU KNOW, HOW, HOW, HOW AND WHERE IS IT APPROPRIATE TO EXTEND THAT BEYOND THE, YOU KNOW, THE ABOVE MENTIONED REQUIREMENTS AND EXTEND IT TO IEEE 2,800 FROM A, FROM A LOOKING BACK STANDPOINT? YES. SO THOSE, THOSE ARE THE TWO ERCOT HOMEWORK ITEMS. UH, WE, WE SPENT A GOOD BIT OF TIME RUNNING THROUGH THIS FOR, FOR TAC AND FOR EVERYBODY. I REALLY APPRECIATE ALL THE, YOU KNOW, THE GOOD DISCUSSION. UM, I MEAN I, THE STRUCTURE, I, IT SEEMS REASONABLE. THERE'S A LOT OF, A LOT OF DETAILS THAT WE TALKED ABOUT THAT, THAT NEED TO BE NAILED DOWN AND YOU KNOW, THAT TO WORK WORDS MEAN SOMETHING. WORDS MEAN SOMETHING. RICHARD'S NOT HERE ANYMORE. BUT YEAH, WORDS MATTER, RIGHT . SO PLEASE TAKE, TAKE WHATEVER TIME IS NEEDED OVER THE NEXT, NEXT COUPLE DAYS AND BE PREPARED TO COME BACK WITH TANGIBLE SUBSTANTIATED RECOMMENDATIONS IF WE NEED TO MAKE ADJUSTMENTS TO WHAT OUR CUTS PROPOSED. SO ANYBODY HAVE ANYTHING ELSE BEFORE WE WRAP UP? NO. MIC DROPPED. MIC DROPPED FROM, FROM BOB. ALL RIGHT. MEETING'S ADJOURNED. * This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting.