[00:00:02]
ALL RIGHT, WE'RE GONNA GO AHEAD AND GET STARTED WITH THE MAY 31ST SPECIAL TECH MEETING.
UH, JUST IN MEETING REMINDERS FOR THIS WEBEX MEETING.
WE'RE GOING TO BE USING THE CHAT FUNCTION TO QUEUE FOR DISCUSSION OR MOTIONS.
PLEASE REMAIN ON MUTE AND WAIT FOR THE CHAIR TO RECOGNIZE YOU.
AND THEN AS WE GO TO THE BALLOTING PROCESS, PLEASE REMEMBER, UH, GIVE US JUST, YOU KNOW, AS WE APPROACH YOUR SEGMENT, MAKE SURE THAT YOU ARE UNMUTING YOURSELF IF YOU ARE GOING TO BE A SEATED REPRESENTATIVE AND VOTING.
AND THEN AFTER YOU CAST YOUR VOTE, PLEASE GO BACK TO THE MUTE FUNCTION THAT'LL HELP US GO A LITTLE, UH, SMOOTHER WITH THAT PROCESS.
AND THEN IF THE WEBEX ENDS FOR ANY REASON, GIVE US JUST A FEW MOMENTS AND, UH, WE SHOULD RESTART THE WEBEX ISSUE.
SO, AND FOR THAT, WITH THAT, CAITLIN, I DO HAVE A QUORUM AND WE'RE READY TO GET STARTED.
I THINK, SUSIE, YOU WERE CUTTING OUT A LITTLE BIT.
I DON'T KNOW IF IT WAS ME OR YOU, BUT CAN SOMEBODY CONFIRM THEY CAN HEAR ME? YOU NEED TO BE A LITTLE LOUDER.
THIS IS ONE OF OUR SPECIAL TECH MEETINGS.
WE HAD THE REGULAR MAY MEETING LAST, LAST WEEK.
UM, WE HAVE A SHORT AGENDA WITH THE HOPES OF GETTING THESE VOTING ITEMS TO THE JUNE BOARD.
ON THE SCREEN IS THE ANTITRUST
[1. Antitrust Admonition ]
THAT WE'RE ALL FAMILIAR WITH TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY PARTICIPANTS AND OR CONDUCTIVITY SHOULD REFRAIN FROM PROPOSING ANY ACTION OR MEASURE THAT WOULD EXCEED OUR CUTS AUTHORITY AGAINST FEDERAL OR STATE LAW.THERE IS MORE INFORMATION ON THE WEBSITE, UM, FOR PROXIES AND ALT REPS TODAY, UM, IN THE CONSUMER SEGMENT, UH, IN THE RESIDENTIAL CONSUMER SEGMENT.
ERIC GOFF, RESIDENTIAL CONSUMER PROXY TO MARK DREYFUS FOR NOER 2 45 ONLY.
UM, NAVA FROM OPAC HAS A PROXY TO ERIC GOFF EXCEPT FOR, FOR NORE 2 45.
AND IN THAT CASE, THE, HIS NO PROXY WILL ALSO GO TO MARKUS IN THE IPM SEGMENT.
REMI HAS AL REP SHANE THOMAS UNTIL 11:00 AM AND THE MUNICIPALLY OWNED UTILITY SEGMENT.
DAVID KEY HAS ALT REP DIANA COLEMAN.
UM, ALICIA LOVING HAS HER PROXY TO DIANA COLEMAN.
AND RUSSELL FRANKLIN FROM GARLAND POWER AND LIGHT HAS ALT REP CURTIS CAMPO.
AND YOU CAN SEE FROM WHAT JORDAN HAS DONE ON THE SCREEN.
WE ARE GOING TO DO ROLES A LITTLE BIT DIFFERENTLY TODAY.
UM, THIS IS MOSTLY FOR, FOR THE PURPOSE OF NO G 2 45, BUT WE'LL JUST INSTITUTE IT FOR THE WHOLE MEETING.
WE DO HAVE A, A SHORT AGENDA TODAY.
IT'S JUST NPRR 1230 AND MP AND NO G 2 45.
I, I'M NOT SURE WE ANTICIPATE A VOTE ON NOUR 2 45 TODAY.
UM, BUT WHAT WE ARE GONNA DO FOR KIND OF EASE OF RUNNING THE QUEUE AND HOPEFULLY TO STREAMLINE CONVERSATION ON NOUR 2 45, IS WE'RE GONNA RUN TWO QUEUES.
SO AS YOU CAN SEE HOW JORDAN'S LAID OUT, WE WILL HAVE THE ATTACK REP QUEUE, AND WE'LL GIVE PRIORITY TO, TO THAT ONE.
AND THEN WE HAVE THE, THE OTHERS QUEUE, WHICH IS, UM, CONSULTANTS, OTHER INTERESTED PARTIES AND, AND ERCOT.
AND SO WE'RE TRYING TO KIND OF CUT DOWN ON, ON THE BACK AND FORTH WHEN ONE PARTY'S PRESENTING AND MAKE SURE THAT WE GET THE, THE QUESTIONS AND COMMENTS FROM TECH REPRESENTATIVES THAT ARE REALLY NEEDED TO VOTE ON NO, 2 45 NEXT WEEK.
AND SO THAT'S, THAT'S THE PURPOSE THERE.
AND, AND THEN ANY QUESTIONS OR CONCERNS, I, I WILL TAKE THOSE.
[2. NPRR1230, Methodology for Setting Transmission Shadow Price Caps for an IROL in SCED (Vote) ]
GO AHEAD AND GET STARTED WITH NPRR 1230.AND THERE WERE
FREDDY, ARE, ARE YOU GONNA SPEAK TO THESE? SURE.
AND SO, UH, MORNING EVERYONE FOR THEIR OPERATIONS, UH, AT THE
[00:05:02]
AREI'M SORRY, FREDDY, WE ARE, YOU'RE CUTTING OUT.
IT SOUNDS LIKE WE CAN'T HEAR FREDDY.
SORRY, I'M TRYING TO SWITCH MY OFF.
SO IS IT STILL WORDS MATTER? UH, YES MA'AM.
YOU PICKED UP ON THAT REALLY GOOD THAT THE MONTH 31 DAYS, I CAN, I CAN COUNT TO 31, WHICH IS, YOU KNOW, A RECENT ACCOMPLISHMENT.
DO YOU STILL DO THAT ON YOUR KNUCKLES LIKE I DO.
I THINK WE'RE STILL HAVING FREDDY CUT OUT.
UM, I HATE TO MOVE THIS ONE TO AFTER 2 45 'CAUSE I'D LIKE TO, TO GET THIS DONE IF THERE'S A, A VOTE THAT WE CAN TAKE ON IT.
WELL, WE THINK WE CAN HEAR YOU.
YOU NEED TO TALK A LITTLE MORE THAN THAT.
PUT THE, PUT THE CELL PHONE ON THE OTHER SIDE OF YOUR HEAD.
HEY, CAITLIN, THIS IS DAVE GIO.
CAN YOU ALL HEAR ME? WE CAN HEAR YOU WELL.
WELL, MAYBE I CAN AT LEAST, UM, HIGHLIGHT THE COUPLE OF CHANGES THAT ARE INCLUDED IN THESE COMMENTS AND, AND FREDDY CAN KEEP TRYING SWITCHING THE PHONE OR, OR WHATEVER HE CAN DO.
UM, I THINK THERE WAS TWO THAT WOULD BE GREAT.
AND SO THERE'S TWO PARTS THAT WERE INCLUDED IN THE COMMENTS.
AND, AND THANK YOU COREY, FOR PULLING IT UP AND, AND HIGHLIGHTING THEM.
FIRST WAS THERE WAS SOME FEEDBACK DURING THE LAST PAC MEETING OF WHETHER OR NOT IT WOULD BE A GOOD IDEA TO HAVE SOME FORM OF SHIFT FACTOR CUTOFF FOR PERFORMING THESE CALCULATIONS.
UM, OBVIOUSLY FREDDY HAD WALKED THROUGH SOME OF THE PRESENTATIONS, SORT OF THE METHODOLOGY THAT, THAT WE WERE INTENDING TO USE TO COME UP WITH WHAT THE SHADOW PRICE CAP COULD BE.
BUT, BUT AS, UM, WRITTEN PREVIOUSLY, THERE WAS NO NECESSARILY SHIFT FACTOR, UM, LIMIT IN TERMS OF WHEN WE WOULD STOP LOOKING AT SHIFT FACTORS.
AND THAT MEANS THAT THE, OF COURSE, THE, THE SHADOW PRICE COULD, COULD GET E EVEN HIGHER THAN SOME OF THE NUMBERS THAT WE HAD BEEN TALKING.
SO, UH, WHAT WE HAD PROPOSED AND HAD SOME, SOME DISCUSSIONS WITH SOME FOLKS WHO HAD RAISED THE CONCERN WAS TO PUT A SHIFT FACTOR CUTOFF IN TERMS OF PERFORMING THESE CALCULATIONS OF, OF 10%.
UH, SO THAT'S ONE OF THE CHANGES.
AND THEN, COREY, IF YOU CAN SCROLL DOWN A LITTLE BIT FURTHER,
[00:10:02]
UM, I THINK THERE'S A, UM, I THINK THERE'S A COUPLE OF MINOR CHANGES.FIRST IS IN, THERE'S THE, THE GRAY BOX LANGUAGE.
IT'S A, IT'S A VERY MINOR CHANGE, BUT THE, THE ONLY ADDITION THERE WAS TO ADD ALL APPLICABLE IOLS.
AND THE REASONING FOR ADDING THE WORD APPLICABLE IS, UH, AS WE HAD NOTED IN SOME OF THE PREVIOUS DISCUSSIONS, THAT WE WOULD NOT NECESSARILY MOVE AWAY FROM THE GENERIC VALUE FOR ALL IOLS.
IT WOULD ONLY BE APPLICABLE TO SOME.
AND SO WE'RE JUST, UH, SIMPLY SAYING THAT, UM, FOR THIS CALCULATION AND, AND THIS, UM, UH, AND THIS NOTIFICATION REQUIREMENT THAT WOULD ONLY APPLY TO THE APPLICABLE IOLS, WE'RE WE'RE ACTUALLY USING THIS ALTERNATIVE METHODOLOGY.
UM, LASTLY IS KIND OF THAT, THAT LAST PIECE, THERE WAS SOME QUESTIONS OF, UM, THIS POTENTIAL OVERLAPPING BETWEEN WHAT WE'RE TALKING ABOUT WITH THE IOLS, WHERE THERE'S THIS POTENTIAL NEED TO INCREASE IT BEYOND THE GENERIC VALUE WITH THE, UM, UH, RULES WE HAVE IN PLACE IN THE SECTION BEFORE THIS IN SECTION 3.6, WHERE IF WE SEE A CONSTRAINT IS IRRESOLVABLE AND SCED FOR A SIGNIFICANT PERIOD OF TIME, AND, AND THERE'S SOME TRIGGERS FOR THAT, UH, THAT WE COULD POTENTIALLY LOWER IT, UM, BASED ON SOME OF THE CONVERSATION TO AVOID THAT OVERLAP OR TO FIGURE OUT HOW WE WOULD HANDLE THAT OVERLAP.
WHAT WE ARE, UH, ADDING HERE IS LANGUAGE TO SAY THAT, UM, IF WE'VE APPLIED THIS, UH, ALTERNATE PROCESS FOR THE IROL, THEN, UM, THE METHODOLOGY AND THE, AND THE ADDITIONAL LANGUAGE IN SECTION 3.6 DOES, DOES NOT APPLY FOR THAT IROL.
SO THOSE ARE, ARE REALLY THE, THE LANGUAGE CHANGES THAT WE'VE ADDED BASED ON, UH, FEEDBACK, UH, THAT WE RECEIVED ATTAC AND, AND OVER THE, THE LAST, UH, WEEK OR SO.
SO HOPEFULLY THAT'S HELPFUL JUST TO KIND OF HIGHLIGHT AT LEAST THE, THE LANGUAGE DIFFERENCES, UH, SINCE, SINCE THE LAST DISCUSSION.
I DON'T KNOW IF FREDDY HAS AUDIO AND WANTS TO ADD ANYTHING RIGHT NOW.
IS THIS BETTER? IT'S, IT'S MUCH BETTER.
THAT'S, I DON'T KNOW, I'M USING MY PHONE FOR WHATEVER REASON.
I'M NOT SURE WHAT WAS GOING ON, BUT, BUT APOLOGIZE FOR THAT.
UM, YEAH, I, I HEARD THE TAIL END OF WHAT DAVE SAID.
AND DAVE, THANKS FOR, THANKS FOR FILLING IN THERE.
UM, UH, BUT REALLY, I GUESS AT THE END OF THE DAY, UM, THE INTENT OF THIS NPR IS, IS REALLY TARGETED AT PROVIDING THE ERCOT CONTROL ROOM, THE ABILITY TO, TO, TO CONTINUE TO USE SCAD TO MANAGE OUR WELLS AND, AND SCARCITY CONDITIONS.
UM, YOU KNOW, AND I'VE, I'VE, I'VE SAID THIS A FEW TIMES BEFORE AND PROBABLY SOUND LIKE A BROKEN RECORD NOW, BUT I, I JUST WANNA MAKE SURE EVERYONE UNDERSTANDS, IS THAT, UM, IN, IN PLACE OF DOING THIS OR UTILIZING THIS NPRR, WE WILL CONTINUE TO DO HDL OVERRIDES SIMILAR TO WHAT WE DID LAST SUMMER FOR, FOR IOLS IF, IF NEEDED.
SO, UM, REALLY, UH, LEAVING IT TO TAC TO DECIDE ON, ON HOW WE MOVE FORWARD WITH THIS.
UM, LIKE I SAID, WE DO, WE DO HAVE AN ALTERNATIVE.
UM, AND, AND JUST RE LEAVING IT TO THE GROUP TO, TO, TO DECIDE.
SO I SEE BLAKE HOLT IN THE QUEUE.
CAN, CAN YOU HEAR ME? I CAN HEAR YOU.
THANK, THANK YOU FOR THE COMMENTS, DAVE AND FREDDY.
UM, THESE WERE, WHAT I, WHAT I'M GONNA DISCUSS ARE MORE GENERAL, NOT SPECIFIC TO, UH, THE RECENT COMMENTS.
I'LL SAY THAT INITIALLY WE WERE SUPPORTIVE OF THIS NPRR, BUT WE HAVE SOME SIMILAR CONCERNS THAT CPS AND AUSTIN ENERGY BROUGHT UP LAST MEETING.
IT, IT APPEARS TO US THAT THE MECHANICS OF THIS WILL GENERALLY INCREASE THE COST TO LOAD ACROSS THE BOARD.
AND SO WHAT I'M CURIOUS ABOUT IS THIS WOULD, WOULD THE COST OF THE COST, THE TOTAL COST OF THE MARKET BE HIGHER UNDER NPR 1230 OR UNDER THE CURRENT PRACTICE, EVEN WHEN CONSIDERING THE HDL OVERRIDE PAYMENTS? I PERSONALLY THINK THAT TAC NEEDS A MORE COMPLETE PICTURE OF THE IMPACT TO MAKE AN INFORMED DECISION.
DO WE REALLY WANT TO PUSH THIS THROUGH WITHOUT CONSIDERATION OF THE FULL COST? AND TO FREDDY'S POINT, WHAT, WHAT WE'D REALLY BE DOING IN THE ALTERNATIVE OR ABSENT THE ALTERNATIVE IS PURCHASING EFFICIENCY FOR THE ERCOT OPERATORS WITHOUT KNOWING THE FULL PRICE TAG IN THE PAST, I THINK THAT THIS GROUP HAS MADE DECISIONS TO MOVE FORWARD WITH LESS EFFICIENT MANUAL SOLUTIONS BECAUSE THE PRICE TAG FOR THE ALTERNATIVE MAY HAVE BEEN TOO LARGE TO JUSTIFY THE BENEFITS AND PERHAPS THERE WAS AN ULTIMATE SOLUTION WITH INSIGHT.
AND THIS PARTICULAR ISSUE WILL BE SOLVED WITH TRANSMISSION BUILD OUT.
[00:15:01]
I THINK IT'LL BE TOUGH FOR LCRA TO SUPPORT THIS WITHOUT GREATER CONTEXT TO WEIGH THE COST VERSUS THE BENEFITS.UH, RECENTLY WE'VE BEEN VOCAL ON HDL OVERRIDES, BUT AT THE SAME TIME WE HAVE RECOGNIZED THAT THEY ARE A TOOL THAT THE OPERATORS NEED IN CERTAIN SITUATIONS, UH, TO, TO ENSURE RELIABILITY.
SO I GUESS MY ULTIMATE QUESTION IS, ARE HDL OVERRIDES A CHEAPER SOLUTION? AND IF SO, DOES THIS GROUP THINK THAT IT COULD POTENTIALLY BE WORTH IT TO CONTINUE WITH THAT CURRENT PRACTICE? UH, INSTEAD OF THIS, UH, THANK YOU.
YES, BLAKE, UH, BILL BARNES, I HAD A QUESTION ABOUT THE SHIFT FACTOR OVERRIDE 10%.
UM, ERCOT DID SOME ANALYSIS SHOWING US THE KIND OF LOAD ZONE PRICE IMPACT OF IMPLEMENTING THIS.
I'M WONDERING IF YOU GUYS WERE ABLE TO REFRESH THAT WITH THE SHIFT FACTOR CUTOFF AND HOW THAT CHANGES THE RESULTS, POTENTIALLY MAYBE EVEN ADDRESSING BLAKE'S CONCERN, UM, ABOUT THE HIGHER COST FOR THEIR LOAD ZONES, UM, THAT THAT MAY HELP WITH THAT.
I'M JUST CURIOUS IF THERE'S, IF ERCOT HAS UPDATED THE ANALYSIS FOR THAT FOR US TO LOOK AT SOMEONE FROM ERCOT WANNA GO AHEAD.
UM, SO I WOULDN'T EXPECT THAT ANALYSIS THAT WE DID OR PRESENTED LAST TIME TO CHANGE THAT THAT WAS SPECIFIC TO THE SOUTH TEXAS IOL AND THAT, UH, SHADOW PRICE CAP VALUE THAT WAS PRESENTED THERE SHOULD, SHOULD STILL BE CONSISTENT.
THAT'S, THAT'S REALLY LOOKING FORWARD.
IF, UM, THERE IS ANOTHER IO WELL THAT, THAT HAS SIMILAR CHARACTERISTICS, UH, DURING SCARCITY CONDITION SIMILAR TO, TO THE SOFT TEXAS IRO, WELL, IT IS JUST TO LIMIT THE, UH, HOW HIGH THE SHADOW PRICE CAP COULD GO.
SO, UM, IF, IF YOU'RE LOOKING AT A A A 10%, I'LL SAY FLOOR ON THE SHIFT FACTORS, THAT THAT WOULD RESULT IN ROUGHLY A, A A $50,000 SHADOW PRICE CAP.
BUT FOR, FOR THE SOUTH TEXAS R WELL THE $19,700 AND CHANGE SHOULD, SHOULD STILL BE CONSISTENT.
UM, JUST TRYING TO GET SOME CLARITY ON THE EXPECTED EFFECTIVE DATE OF THIS, IF IT WERE TO GO THROUGH, I ALSO SUPPORT THE COMMENTS THAT LCRA MADE JUST NOW ABOUT HAVING ADDITIONAL ANALYSIS.
UM, BUT LET'S JUST SAY FOR ARGUMENT'S SAKE THIS, UH, PROGRESSES.
UH, I, I SEE A, UH, AUGUST 2ND DATE FOR THE GRAY BOX.
OR IS ERCOT TRYING TO TELL THE MARKET THAT WE SHOULD EXPECT THIS CHANGE ON TO BE IMPLEMENTED AUGUST 1ST? YES, THAT, THAT, THAT'S EXACT EXACTLY IT.
SO THE, THE SHADOW PRICE INCREASE FOR THE SOUTH TEXAS, IOWA WOULD, WOULD TAKE EFFECT AUGUST 1ST AND THEN, UM, AUGUST AT SECOND AND FORWARD, UH, WOULD REQUIRE THE 30 DAY, UH, NOTICE FOR ANY OTHER CHANGES.
I, I APPRECIATE THE CLARIFICATION AND, AND JUST AGAIN, TO REITERATE, UH, SUPPORT THE COMMENTS THAT LCRA WAS MAKING ABOUT JUST HAVING ADDITIONAL ANALYSIS TO DETERMINE IF, UH, THIS IS THE RIGHT DIRECTION.
COULD YOU CONFIRM, UM, WHETHER, UH, SECTION 3.6 0.2 MIGHT APPLY TO THE SHADOW PRICE CAP? AND IF YOU EXPECT THAT IT, IT, IT WOULD AT ALL IF IT MET THE CIRCUMSTANCES IN THREE 6.1? AND THAT'S IN THIS, IF YOU WANNA SCROLL TO IT, COREY, AND THAT'S, THAT'S REFERRING TO THE CURRENT, UH, THERE IS CRITERIA YES.
AND THEN HOW IT DROPS IF YOU GET TO THE REVENUE LEVEL.
SO I, THAT'S PART OF WHAT WE WERE TRYING TO CLARIFY IN THESE COMMENTS.
IF, IF I'M UNDERSTANDING THE QUESTION RIGHT, IS, UH, ONCE WE INCREASE THE, THE SHADOW PRICE CAP FOR AN IO WELL, AND IT STILL MEETS THE IRRESOLVABLE CRITERIA
[00:20:02]
AND, AND THE SECTION COREY HAS, UH, UP IT, IT, IT, IT WOULDN'T QUALIFY.AND, AND THAT'S WHAT THE, THE LANGUAGE WAS REALLY TRYING TO, OR THE COMMENTS WERE TRYING TO, UM, PROVIDE CLARITY ON IS FOR AN IRL THAT WHERE IT'S SHADOW PRICE CAP HAS INCREASED, IT WOULDN'T MEET OR IT WOULDN'T MEET THE CRITERIA OR IT COULDN'T BE CHANGED BASED ON THE CRITERIA IN THIS SECTION.
OKAY, TED, SO HEAR HEARING THE, THERE'S INTEREST FROM SEVERAL FOLKS IN HAVING ADDITIONAL ANALYSIS, BUT UNDERSTANDING THAT THIS IS, YOU KNOW, INTENDED TO, TO, TO BE A TOOL TO HELP MANAGE, UH, CONSTRAINTS LIKE THE SOUTH TEXAS EXPORT, WHICH I, I THINK, WHICH WE'VE ALL BEEN GIVEN, THE EXPECTATION IS, IS GOING TO BE, UM, YOU KNOW, SOMETHING CLOSELY WATCHED OVER THE COMING MONTHS.
UM, YOU KNOW, IT, IS THERE ANY LIKELIHOOD THAT WE'LL HAVE THAT ADDITIONAL ANALYSIS IN TIME TO, FOR TACT TO WEIGH IN, SAY, AT NEXT WEEK'S MEETING? SO WE, WE ARE WORKING ON SOME AMOUNT OF ANALYSIS TO LOOK AT DIFFERENT DATES OTHER THAN SEPTEMBER 6TH, UM, FOR, FOR A VARIETY OF REASONS.
UNFORTUNATELY, WE WEREN'T ABLE TO HAVE THAT READY FOR TODAY.
UM, WE ARE CONTINUING TO WORK ON THAT.
UM, I, I DON'T KNOW IF I CAN GUARANTEE THAT IT WOULD BE READY FOR THE NEXT MEETING, BUT, UM, UH, DAVE, I DON'T KNOW IF YOU HAVE ANY INSIGHT ON, ON WHETHER YOU THINK THAT MIGHT BE READY OR NOT.
UH, I MEAN, I I I THINK FREDDY, YOU SORT OF, RIGHT? I MEAN OBVIOUSLY WE ARE WORKING OUT IT AND PLUGGING AWAY.
UM, THE, I MEAN, I I WILL SAY THE, THE INITIAL DATA THAT WE HAVE, I WOULD SAY IS LARGELY IN ALIGNMENT WITH, WITH WHAT WE'VE ALREADY SHARED IN TERMS OF OVERALL IMPACT.
UM, SO, YOU KNOW, I DON'T NECESSARILY EXPECT SOMETHING NECESSARILY NEW KIND OF FOCUSED ON THAT MORE EXTREME CASE LIKE WE SAW BACK WITH SEPTEMBER 6TH OF LAST YEAR, AND WE'RE ALSO TRYING TO LOOK AT SOME, SOME MILDER DAYS TOO AND JUST SORT OF SEE HOW, HOW THOSE WOULD PLAY OUT.
BUT, UM, BUT ANYWAYS, BUT WE'LL, WE'LL CERTAINLY KEEP WORKING OUT AND SEE WHAT WE CAN BRING.
AND YOU KNOW, AND I'M THINKING HERE, YOU KNOW, I HEARD, I HEARD BLAKE MENTION WANTING TO SEE COMPARISON OF, UH, YOU KNOW, THIS SOLUTION VERSUS HDL OVERRIDES.
UM, YOU KNOW, I I WOULD ALSO, YOU KNOW, CURIOUS FOR, YOU KNOW, TO HEAR Y'ALL'S THOUGHTS ON HOW, YOU KNOW, THE QUALITATIVE DIFFERENCE BETWEEN THIS APPROACH AND THE HDL OVERRIDE, UM, TOOL.
'CAUSE I MEAN, RECOGNIZE BOTH, BOTH OF THESE ARE TOOLS.
UM, IT, THE VALUE TO THIS SEEMS TO BE THAT IT LETS SCAD MORE SMOOTHLY ADDRESS A CONSTRAINT, UM, VERSUS, YOU KNOW, THE POTENTIALLY HAVING A A, I'M GONNA CALL IT CHUNKIER, UM, YOU KNOW, APPROACH FROM USING HDL OVERRIDES, WHICH, YOU KNOW, WE, WE, WE SAW IN SEPTEMBER 6TH.
IF I CAN, MAYBE IF IT'S HELPFUL THEN, YOU KNOW, I THINK THERE WAS THE QUESTION BACK AND I'M, WE DIDN'T REALLY SPEAK TO IT THAT, THAT BLAKE HAD AS IN TERMS OF COST OF OVERRIDES VERSUS IN, YOU KNOW, IMPACT OF COST OF THIS, I MEAN, MEAN TO SOME DEGREE THAT THAT WOULD DEPEND ON WHERE YOU ARE.
OBVIOUSLY, AS WE'VE SHOWED WITH SOME OF THE ANALYSIS AND, AND I THINK FOLKS ARE AWARE, YOU'D SEE PRICES INCREASE IN SOME AREAS AND PRICES DECREASE IN OTHERS, BUT AS OPPOSED TO, UM, HOW THE COST OF OF OVERRIDES ARE ALLOCATED, THAT THAT'S A LITTLE BIT MORE LIKE MY UNDERSTANDING IS TO SORT OF SPREAD ACROSS.
UM, IN GENERAL, I WOULD EXPECT, YOU KNOW, TO SOME DEGREE THE COST, THE, THE, THE COST OF THIS TO BE GENERALLY GREATER.
UM, I THINK THE VALUE OF THAT IS THAT IT IS A MARKET SOLUTION THAT WE'RE, WE'RE TRYING TO USE.
AND, AND SO THAT IN ITSELF IS VALUABLE.
YOU KNOW, THE OTHER CONCERN, AND I THINK THIS IS PART OF WHAT WHAT FREDDY HAS SHARED IS, YOU KNOW, WE DO HAVE THE TOOL OF HDL OVERRIDES.
IT'S A LITTLE, UH, IT, IT, IT IS VERY MANUAL IN, ITS IN ITS SIMPLE NATURE.
UH, AND SO, YOU KNOW, THAT THAT HAS SOME CONCERN AS WELL WHEN IT, IT'S NOT AUTOMATED AND THINGS LIKE THAT, THAT, TO MAKE SURE WE'RE, WE'RE TRULY TRYING TO, UM, UH, MANAGE IT AS WELL AS WE CAN.
SO I, THAT IS JUST SORT OF A RISK.
BUT, YOU KNOW, MY INTUITION IS, YOU KNOW, FROM AN OVERALL COST PERSPECTIVE, UM, THIS WOULD, YOU KNOW, HAVING THE MARKET SOLUTION IS GONNA BE A HIGHER COST
[00:25:03]
AND, YOU KNOW, UNDER UNDERSTAND THAT THERE'S, THAT THERE'S A COST DELTA.AND REALLY WHAT I WAS TRYING TO GET AT, I THINK IS THAT LAST POINT THAT YOU WERE MAKING DAVE, WHICH IS, YOU KNOW, A MANUAL INTERVENTION VERSUS A A, YOU KNOW, PROGRAMMATIC MARKET DRIVEN ONE HAS ADDITIONAL VALUE THAT PROBABLY OFFSETS SOME, SOME COST CONSIDERATION, ESPECIALLY IF, UM, YOU KNOW, SOME, IF, YOU KNOW, FOLKS ARE, ARE HEDGED GOING INTO THE, INTO THE NEAR TERM.
RICHARD ROSS, UH, YOU CAN TAKE, UH, THEY HIT MY ISSUE THAT IT'S REALLY A MANUAL VERSUS AUTOMATED ADDRESSING OF THE RELIABILITY ISSUE THEY'RE DEALING WITH.
AND BOB HILTON, I, THE SOUND STILL WORKING FOR ME? I THINK IT IS FOR MOST, I, I DON'T KNOW, UM, IF WE'VE RESOLVED THE ISSUE FOR YOU AND, AND WHOEVER ELSE, LET'S GO AHEAD.
APPRECIATE OR PUTTING THIS TOGETHER.
UM, I MEAN THIS IS A MORE EFFICIENT, LONG-TERM, LONGER TERM SOLUTION BECAUSE IT'S IN MARKET, RIGHT? IT'S ALLOWING MARKET PRICES TO SOLVE THE, THE PROBLEM.
SO I MEAN, WE'RE SUPPORTIVE OF, OF IMPLEMENTING THIS AT SOME POINT, BUT ALSO COMPLETELY UNDERSTAND THE CONCERNS OF THOSE THAT ARE IMPACTED IN THE NEAR TERM, UH, BY A MARKET CHANGE THAT WAS NOT ANTICIPATED.
UM, AND SO I JUST, I'M KIND OF THINKING OUT LOUD, WONDERING IF A POTENTIAL COMPROMISE HERE IS TO CONTINUE THE HDL OVERRIDE PROCESS FOR THIS SUMMER AND HAVE THIS, I IMPLEMENTED AT SOME POINT AFTER THAT, UH, TO LESSEN THE IMPACT OF THOSE THAT, UM, THAT WEREN'T ABLE TO REASONABLY ANTICIPATE THIS CHANGE, BUT, UH, HAVE IT IN PLACE FOR A LONGER TERM UNTIL THE TRANSMISSION'S BUILT.
YEAH, THIS IS VERY, UH, AND, AND, AND I UNDERSTAND AND I, UM, YOU KNOW, THE CONCERNS HERE AND THE SHORT TIMING, AND I APOLOGIZE FOR THE SHORT TIMING AND THAT'S SOMETHING DEFINITELY THAT RE T'S WILLING TO SUPPORT TOO, IF, IF FOLKS NEED MORE TIME.
SO WHAT DOES THAT LOOK LIKE? UM, ARE WE TRYING TO MAKE A CHANGE TO THE EFFECTIVE DATE OR ARE WE WAITING ON THIS WAITING ON A VOTE FURTHER? UM, WHAT'S THE WILL OF THE GROUP? I DON'T SEE ANYBODY WANTING TO MAKE A MOTION.
SAM SAYS TEN ONE EFFECTIVE DATE.
THERE'S A STRONG MAN, I, I, I DON'T HAVE A STRONG FEELING ON TEN ONE, JUST THROWING SOMETHING OUT THERE TO TRY AND BE CONSTRUCTIVE.
SO I GUESS THIS PROBABLY GETS BACK TO THE, YOUR QUESTION I HAD EARLIER.
IS THIS SOMETHING WHERE YOU, WE, WE WOULD BE BENEFITED BY HAVING MAYBE NOT SIGNIFICANTLY MORE DISCUSSION AT OUR NEXT REGULARLY SCHEDULED GET TOGETHER, BUT, YOU KNOW, TO TRY TO GET SOMETHING TO THE BOARD AND GIVE FOLKS MORE TIME TO DIGEST? YOU KNOW, I UNDERSTAND THAT THERE MAY NEED TO BE, UM, SOME CONSIDERATION ON EFFECTIVE DATE TO GET TO, UM, YOU KNOW, EVERYONE ALIGNED ON, ON WHAT I THINK IS THE MORE EFFICIENT LONG-TERM SOLUTION.
UM, YOU KNOW, I, I COULD MAKE A MOTION NOW OR, BUT I'D ALSO DON'T WANT TO, YOU KNOW, IF WE HAVE ANOTHER CHANCE, I DON'T WANNA PREJUDICE FOLKS, YOU KNOW, DESIRE FOR MORE, A LITTLE BIT MORE.
'CAUSE TO THE POINT THAT'S MADE, THIS HAS COME UP WHILE WE'VE DISCUSSED IT, YOU KNOW, SEVERAL TIMES IN DIFFERENT FORMS OVER THE LAST YEAR.
T HAS ONLY HAD THIS FOR A PRETTY SHORT PERIOD OF TIME.
BLAKE, BLAKE HOLT, L-C-R-A-I, I APPRECIATE THE,
[00:30:02]
THE, UH, EFFICIENCY OF, OF 1230.UM, AND I APPRECIATE YOUR COMMENTS, BILL.
UH, I THINK WE JUST NEED GREATER CONTEXT BEFORE WE COULD COMMIT TO A DATE.
UM, JUST WANTED TO PUT THAT OUT THERE.
THIS IS SOMETHING THAT WE STILL WANT FOR JUNE BOARD, IS THAT CORRECT? OR IF, IF WE'RE GONNA GO WITH A LATER IMPLEMENTATION DATE, THIS IS SOMETHING THAT WE COULD PUSH.
WE LIKELY WILL HAVE ONE MORE TAX MEETING BEFORE JUNE BOARD, BUT THAT THE TECH MEETING NEXT FRIDAY WOULD, WOULD BE A VERY KIND OF QUICK TURNAROUND.
SO WE'RE TRYING TO HAVE AS LITTLE VOTING ITEMS AS POSSIBLE AT THAT, AT THAT MEETING.
SOMEBODY FROM
SO CAITLYN, ARE YOU, ARE YOU SPEAKING TOWARDS OUR DESIRE TO GET IT TO THE BOARD OR AS FAR AS JUST THE, YEAH.
DOES THIS NEED TO GO TO JUNE BOARD, IS WHAT I'M WONDERING.
AND I, I GUESS THE EFFECTIVE DATE GOES INTO THAT, BUT IF WE'RE TALKING ABOUT A OCTOBER ONE OR LATER EFFECTIVE DATE, DOES IT, DOES THIS NEED TO GET TO THE JUNE BOARD? IF, IF WE'RE TALKING ABOUT AN OCTOBER EFFECTIVE DATE, THEN I, I DON'T THINK IT NECESSARILY NEEDS TO BE AT THE JUNE BOARD.
UM, AT LEAST IN MY OPINION, UM, I DON'T KNOW WHAT THE TIMING IS FROM HAVING THIS PASSED AT A LATER TAC MEETING AND TO MAKE IT TO FOR A, A, AN OCTOBER EFFECTIVE DATE.
BUT I THINK OKAY,
SO WE DO, WE WILL LIKELY HAVE A MEETING NEXT FRIDAY FOR, FOR NO GOOD 2 45 THAT CAN STILL GET TO THE JUNE BOARD, BUT IT, THAT'S A PRETTY TIGHT TURNAROUND, UM, FOR, FOR ANN AND, AND OTHER PREP STAFF TO GET VOTING ITEMS TO THE BOARD.
SO WE'RE TRYING TO AVOID THAT IF POSSIBLE.
UM, AND THEN I, I BELIEVE THE NEXT REGULAR JUNE TECH MEETING WOULD GO TO AUGUST FOUR, AS COREY SAID, AND, AND SEPTEMBER PUC.
UM, SO I JUST WANTED TO GET HER'S TAKE ON THAT AND IT SOUNDS LIKE THAT WOULD BE OKAY.
ALRIGHT, LET'S GO TO, OKAY, THANKS FREDDY.
WELL, I JUST WAS WONDERING IF, UH, PERHAPS PROVIDING, UM, THOSE THAT ARE CONCERNED ABOUT THIS, UH, TILL THE NEXT TAC MEETING SOME TIME TO THINK ABOUT A, A IMPLEMENTATION DATE IN THE FUTURE, LIKE OCTOBER 1ST, UM, THAT WONDER IF THAT MIGHT HELP THE DECISION MAKING ON THIS.
IS THERE A NOW MARKET BASED SOLUTION, UH, THAT'S IN PLACE AND PEOPLE UNDERSTAND IN THE LONG RUN WILL BE MUCH BETTER FOR THE MARKET? THANK YOU.
I THINK COREY, UH, MAY HAVE ANSWERED THE QUESTION I HAD IN THE CHAT, BUT JUST TO, TO VOICE IT, IF, IF IT GOES TO THE AUGUST BOARD MEETING INSTEAD OF JUNE, THAT WOULD BE, UM, THAT WOULD BE ON THE, THE 20TH OF AUGUST.
SO IT WOULD NEED TO BE TAKEN UP BY THE PUC ON SEPTEMBER 26TH AND, UH, IT COULD BE IMPLEMENTED.
WHAT I'M HEARING THEN IS OG COULD IMPLEMENT IT PRETTY QUICKLY THEREAFTER.
IT WOULDN'T NEED, YOU KNOW, MORE THAN FOUR OR FIVE DAYS JUST RIGHT.
IT, IT'S, IT'S NOT, NO SYSTEM CHANGES ARE REQUIRED.
IT'S, IT'S BASICALLY A NUMBER CHANGE IN OUR SYSTEMS. OKAY.
THIS IS DAVID AT LET'S CPS SAN YOU.
SO IF THIS IS, UH, NOT IMPLEMENTED TILL, UH, OCTOBER UNTIL YOU UTILIZE THE HDL OVERRID CONTROL FOR THE SUMMER, DOES THAT, UM, I GUESS DOES THAT CONTROL HAVE TO BE IMPLEMENTED LIKE SOONER IN THE DAY AT LOWER LEVELS AND THEREFORE, YOU KNOW, THE CONSTRAINT WILL BE KIND ABOUT A LOWER LEVEL THAN IT WOULD'VE BEEN UNDER THE, UH, UNDER NPR 1230 BECAUSE OF THE MANUAL NATURE? ARE ARE, ARE YOU REFERRING TO WHEN THE HD OVERRIDES WOULD BE IMPLEMENTED OR GO INTO EFFECT? RIGHT, SO THE, YEAH, THE WAY YOU'RE, SO IF THIS
[00:35:01]
NPR IS NOT IN PLACE FOR THE SUMMER, THEN YOU HAVE TO CONTROL IT, YOU KNOW, SIMILAR TO LAST YEAR.UH, DOES THAT, UH, EFFECTIVELY LOWER THE RATING OF THE, OF THE GTCS BECAUSE OF THE, UH, TIME NEEDED TO FROM THE MANUAL CONTROL? I, I WOULDN'T SAY IT LOWERS THE RATING, BUT IF, IF YOU LOOK AT THE TRANSMISSION DESK PROCEDURE THAT'S POSTED, UM, AT 90% THE, THEY WILL START UTILIZING HDO OVERRIDES.
IF, IF THAT, THAT ANSWERS YOUR QUESTION ON, ON WHEN WE WOULD START DOING THAT.
SO ONCE THE FLOW IS 90% OF THE LIMIT AND IT'S CONTINUED TO INCREASE THE FLOWS, CONTINUED TO INCREASE BEYOND 90% OF THE LIMIT, THEN THE CONTROL ROOM WOULD START USING, UTILIZING HD OVERRIDES IF SKID IS UNABLE TO, TO, TO MANAGE.
THAT'S 90% OF THE, UH, REDUCED LIMIT BECAUSE IT'S REDUCED BECAUSE OF THE, UH, TO, TO MAKE SURE THAT YOU DON'T EXCEED IT WITH, UH, IRRS GOING OVER THE BASE POINT.
90% OF THE ACTUAL, OF THE TOTAL OH, OKAY.
UM, I DON'T THIS TABLED, SO I DON'T BELIEVE WE NEED A, A MOTION.
AND WHAT I'M HEARING IS WE CAN PROBABLY KEEP THIS TABLED AND TAKE IT UP AT OUR REGULAR JUNE MEETING, WHICH IS JUNE 24TH, AND THAT WOULD SET IT UP FOR AUGUST BOARD.
IS THAT PLAN OKAY WITH EVERYBODY? I WILL TAKE SILENCE AS A YES.
I THINK IF THERE'S NO OTHER QUESTIONS OR COMMENTS THERE, I THINK WE CAN GO TO
[3. NOGRR245, Inverter-Based Resource (IBR) Ride-Through Requirements (Vote) ]
NO GEAR 2 45.SO FOR, JUST TO RECAP FOR NPR 1230, UM, WE WILL PLAN TO TAKE THAT UP NOT NEXT WEEK, BUT AT THE REGULAR JUNE TAX MEETING, WHICH IS ON JUNE 24TH.
SO FOR NO 2 45 AS WE ALREADY DISCUSSED.
UM, AND AS WE'RE ALREADY DEMONSTRATING, WE ARE ARE RUNNING THE TWO SEPARATE QUEUES, ONE FOR TAC REPS AND ONE FOR OTHER, WHICH IS KIND OF, YOU KNOW, OTHER INTERESTED PARTIES AND ERCOT.
UM, FOR TODAY, FOR 2 45, WE HAVE A COUPLE OF DOCUMENTS THAT WERE POSTED.
WE HAVE THE UPDATED TECH APPROVED VERSIONS THAT ERCOT ADDED COMMENTS TO, AND I BELIEVE THEY HAVE SOME LANGUAGE FOR US TODAY.
AND THEN WE HAVE A SLIDE FROM JOINT COMMENTERS.
AND WHAT I AM GOING TO PROPOSE ALSO TO KIND OF CUT DOWN ON THE BACK AND FORTH IS FOR ER'S PRESENTATION, UM, YOU KNOW, AND ANY DISPUTES ON, ON FACTS FROM FROM JOINT COMMENTERS AND THEN THE VICE VERSA WHEN JOINT COMMENTERS PRESENT ANY DISPUTES ON FACTS FROM FROM ICA, I'M GONNA PROPOSE WE KIND OF HOLD THOSE TO THE END INSTEAD OF ADDRESSING THEM, YOU KNOW, EVERY SENTENCE OR OR EVERY BULLET POINT AND THEN GIVE THE THE OTHER PARTY DRUNK COMMENTERS ER OR ERCO, UM, A FEW MINUTES AFTER WE'VE GONE THROUGH THE TECH QUEUE TO, TO ADDRESS ANYTHING THEY NEED TO ADDRESS AS FAR AS AREAS OF DISPUTE.
AND SO WE WOULD START WITH ERCOT COMMENTS, WE'LL, WE'LL WORK THROUGH THE TECH REP QUEUE AFTER THAT, IF JOINT COMMENTERS WANT A COUPLE OF MINUTES TO, TO GO THROUGH ANY ISSUES THEY HAVE WITH WITH THE ERCOT COMMENTS, WE WOULD DO THAT.
AND THEN WE WILL MOVE ON TO JOINT COMMENTER SLIDE WORK THROUGH THE TECH REP QUEUE.
AND AFTER THAT, IF ERCOT WANTS TO WORK THROUGH ANY DISPUTES THEY HAVE ON JOINT COMMENT SLIDE, WE'LL ADDRESS IT THAT WAY.
I DON'T SEE ANY DISAGREEMENT WITH THAT PLAN.
SO LET'S START WITH THE, THE ERCOT DRAFT PROVISIONS THAT WERE POSTED.
DO WE HAVE SOMEONE FROM ERCOT READY TO SPEAK TO THIS? YEAH, SO THIS IS DAN.
UM, CAN YOU HEAR ME? I CAN HEAR YOU.
SO WHAT, WHAT I THOUGHT MIGHT BE HELPFUL AT FIRST IS JUST KIND OF VERBALLY
[00:40:01]
GO THROUGH, UH, CONCEPTUALLY WHAT WE WERE TRYING TO DO BEFORE WE DIG INTO THE LANGUAGE BECAUSE IT SEEMS LIKE THAT'S BEEN PART OF THE PROBLEM ON THIS IS THAT WE DIVE INTO LANGUAGE WITHOUT KIND OF TALKING AT A HIGH LEVEL.SO SOME OF THIS IS REALLY WHAT WE WERE TRYING TO DO WITH THIS IS, UH, IMPLEMENT SOME OF THE DISCUSSION THAT HAPPENED AT T UH, CULLEN'S IDEA ABOUT MAXIMIZING AND, AND SO FORTH AND, AND TRY TO TRY TO IMPLEMENT THAT, UH, AS MUCH AS POSSIBLE AND THEN, UH, UH, KIND OF WORK AROUND IT.
UM, I THINK WHAT WILL BE HELPFUL IS, IS IS KIND OF GO, LIKE I SAID, GOING THROUGH SOME OF THE CONCEPTS AND THEN I THINK WE, UH, SPECIFICALLY THEN WE WILL NEED TO LOOK AT THE SECTIONS RELATED TO THE EXCEPTION PROCESS BECAUSE WE DIDN'T REALLY GET TO THAT PART LAST TIME, IF THAT, IF THAT MAKES SENSE.
SO I GUESS, UM, CONCEPTUALLY, UH, WHERE WE WERE TRYING TO GO IS THAT ALL UNITS KINDA, REGARDLESS OF THEIR VINTAGE NEED TO MAXIMIZE TO THEIR, THEIR EQUIPMENT CAPABILITIES USING SOFTWARE, FIRMWARE SETTING IMPROVEMENTS, ALL THOSE KIND OF THINGS.
AND THAT, THERE'S A LIST DOWN BELOW, AND THAT WOULD INCLUDE THE IEEE 2,800 ANCILLARY KINDA REQUIREMENTS, UH, THAT WERE LISTED IN OUR PRESENTATION HERE A FEW WEEKS AGO, UH, AS PART OF THAT MAXIMIZATION.
SO BASICALLY WE GO AS, AS FAR AS YOU CAN NOT JUST ON FREQUENCY AND, AND, AND VOLTAGE RIDE THROUGH, BUT, BUT, UM, OTHERS, REGARDLESS OF HOW OLD IT IS.
UM, AND THEN ALL THOSE CHANGES WOULD NEED TO BE MADE BY, BY SOME DATE.
I THINK WHAT'S IN THE COMMENTS IS THE END OF 2025, UH, AND THEN PROVIDE MODELS TO MATCH THAT ACTUAL EQUIPMENT.
UM, AND SO THEN, UH, FROM A PERFORMANCE PERSPECTIVE, THE PERFORMANCE REQUIREMENTS WOULD BE THE HIGHER OF THAT DOCUMENTED MAXIMIZED CAPABILITY OR FOR UNITS WITH, UH, THAT, THAT WERE HAD AN SGIA BEFORE WHATEVER DATE WE WIND UP USING.
AND THERE'S STILL DEBATE ON, YOU KNOW, SHOULD THAT BE 6 23 OR, OR 6 24, BUT ANYTHING BEFORE THAT DATE IT.
SO THE, THE REQUIREMENTS WOULD BE THE MAXIMUM OF THE, THE, OR WOULD BE THE, THE PERFORMANCE REQUIREMENTS WOULD BE THE HIGHER OF THEIR DOCUMENTED MAXIMIZED CAPABILITY OR THE LEGACY REQUIREMENTS.
AND THEN FOR THE ONES AFTER THAT DATE, UH, THE, THEIR, UH, PERFORMANCE REQUIREMENT WILL BE THE EITHER THE DOCUMENTED MAXIMIZED CAPABILITY OR THE PREFERRED REQUIREMENTS.
UM, AND THEN, UM, ANY RESOURCES THAT THAT CAN'T MEET, THEY HAVE, CAN'T MEET THOSE, THEIR, AT LEAST THE DEFAULT PERFORMANCE REQUIREMENTS, YOU KNOW, DEPENDING ON THE AGE, THE LEGACY OR THE PREFERRED, WE STILL HAVE TO MAXIMIZE.
AND, UH, THEN THERE WOULD BE THE WHOLE, YOU KNOW, EX EXCEPTION PROCESS THAT WE WILL TALK ABOUT MORE IN A FEW MINUTES.
UM, AND THEY WOULD HAVE TO PROVIDE MODELS THAT REFLECTED, UH, ANY, ANY, UH, SHORTAGE IN, IN MEETING THOSE REQUIREMENTS.
UM, AND WE COMMITTED IN, IN THIS, UH, THIS DRAFT, UH, SET OF, UH, COMMENTS THAT THEY'RE NOT REALLY COMMENTS, BUT THE DRAFT LANGUAGE THAT WE WOULD, IF, IF FOLKS TELL US WE CAN'T MEET THE LEGACY REQUIREMENTS, UH, THAT, UM, IF, IF, IF, IF THEY REPORT THAT AS PART OF THIS EXCEPTION PROCESS, WE, WE WOULDN'T, UH, SEND THOSE TO THE ERM JUST BECAUSE OF THE, THEY REPORTED 'EM THERE.
UM, THE, UM, WE WOULD THEN, WHEN IT COMES TO THE EXCEPTION PROCESS, WE WOULD LOOK AT THE, THEY WOULD ALL HAVE TO HAVE THOSE IN DEFICIENCIES REPORTED BY 2025 IN FEBRUARY.
AND THEN WE WOULD LOOK AT THE AGGREGATE DEFICIENCIES, UH, KIND OF THE IMPACTS OF THOSE ON RELIABILITY AND EITHER, UH, APPROVE EXCEPTIONS.
AND IF WE APPROVE EXCEPTIONS, WE'RE GONNA HAVE TO COME UP WITH SOME WAY TO MITIGATE THE RELIABILITY IMPACT OF THOSE IN THE AGGREGATE.
UH, IF THERE IS, UH, YOU KNOW, NOT, UH, ACCEPTABLE LEVEL THERE AND THEN, AND THEN DENY OR, OR WE WOULD DENY THE EXCEPTIONS, WE'LL GO THROUGH THIS EXCEPTION PROCESS MORE IN A FEW MINUTES WHEN WE GET IN.
I THINK THAT'S ONE OF THOSE PLACES WHERE LANGUAGE REALLY MATTERS.
AND SO WE'LL, UH, GO INTO IT THERE.
UM, ONCE APPROVED, THAT EXCEPTION WOULD BE THE ONGOING PERFORMANCE STANDARD FOR THE RESOURCE, UH, SUBJECT TO COMPLIANCE IF IT'S NOT MET.
AND IT WOULD BE A ONE-TIME EXCEPTION PROCESS.
SO THERE WOULDN'T BE THIS ONGOING EXCEPT, UH, EXCEPTION PROCESS THAT LED TO DEGRADATE DEGRADATION OF REQUIREMENTS OVER TIME.
[00:45:01]
2026 OR 2028 WITH EXTENSIONS, ALL NEW INTERCONNECTION AGREEMENTS WOULD HAVE TO MEET 2,800, THE PREFERRED REQUIREMENTS, UH, WITH NO EXCEPTIONS, AND THEN PERFORMANCE WOULD HAVE TO BE TO THE STANDARD.UM, SO THE, THE, THE NEXT ISSUE THEN IS, WELL, WHAT'S COST EFFECTIVE? WHAT WOULD IN, IN HAVING TO MAKE THOSE UPGRADES, WE, WHEN, SO WE PUT SOME LANGUAGE IN THERE AND WE'LL GO, WE'LL GO LOOK AT THAT.
BUT ULTIMATELY ONE OF THE KEY THINGS IS IT TIES BACK TO A, A, UM, TAC APPROVED PERCENTAGE LIMIT.
SO YOU, YOU GUYS WILL HAVE TO, TO THINK THROUGH WHAT'S THE RIGHT PERCENTAGE.
WE HAD PUT A BOGEY IN THERE LAST TIME WE LEARNED OUR LESSON.
WE'VE GOT A A BLANK IN THERE AT THE, AT THIS POINT.
UM, THE, UM, IF YOU HAVE A PERFORMANCE FAILURE, UM, IF YOU'VE MAXIMIZED YOUR CAPABILITY AND YOU REQUIRE AN EXCEPTION BECAUSE YOU CAN'T MEET THE DEFAULT FOR THAT, AND YOU HAVE AN EXCEPTION BECAUSE YOU CAN'T MEET THE DEFAULT FOR YOUR VINTAGE AND YOU DON'T PERFORM TO THAT EXCEPTION, THEN THERE'D BE A COMPLIANCE, UH, ISSUE.
AND YOU'D HAVE TO MITIGATE BACK TO THAT, WHERE WHEREVER YOUR EXCEPTION SAID YOU COULD DO, UM, IF YOU HAVE MAXIMIZED YOUR CAPABILITY AND, AND THAT EX AND YOUR MAXIMUM CAPABILITY EXCEEDS YOUR VINTAGE, THEN YOU STILL HAVE TO MITIGATE BACK TO THAT MAXIMIZED CAPABILITY BECAUSE WE PLANNED THE SYSTEM AROUND, UH, THE FACT THAT YOU SAID YOU COULD MEET THIS, THIS LEVEL.
UM, BUT IF YOU, AND, AND, AND THIS IS A GIVE, IF YOU, UM, IF YOU AT LEAST MET THE DEFAULT REQUIREMENTS FOR YOUR VINTAGE, THEN THERE WOULDN'T BE ANY COMPLIANCE, UH, UH, PROBLEM THERE.
IF YOU DIDN'T MEET AT LEAST THE, IF YOU TRY MAXIMIZED AND YOU WERE HIGHER THAN THEN WHAT IT TAKES FOR YOUR VINTAGE, BUT YOU DIDN'T EVEN MEET THE, UH, DURING THIS PERFORMANCE FAILURE, YOU DIDN'T EVEN MEET THE REQUIREMENTS FOR THE VINTAGE, THEN THERE WOULD BE A COMPLIANCE.
SO THERE'S NO, UH, COMPLIANCE, UH, RISK TO MAXIMIZING YOUR CAPABILITY EVEN ABOVE THE, UH, VINTAGE REQUIREMENTS.
UM, AND THEN, UM, YOU KNOW, WE, WE MADE OTHER LANGUAGE ABOUT WHAT, WHAT, LIKE I SAID, WE TALKED ABOUT THE EXEMPTION PROCESS AND THEN, UM, WE'VE ALSO MADE SOME CHANGES TO THE TAC APPROVED VERSION, UH, GIVING US, UH, SUFFICIENT TIME TO ACTUALLY REVIEW WHAT WE EXPECT TO BE, UM, UM, MORE EXCEPTIONS THAN WHAT WE'D BE ABLE TO PROCESS IN A VERY SHORT PERIOD OF TIME.
AND SO THAT HOPEFULLY THAT IS, WAS HELPFUL TO KIND OF GIVE YOU THE OVERVIEW OF WHERE WE'RE GOING AND THEN WE CAN DIVE INTO THE LANGUAGE.
BUT, UH, MAYBE I SHOULD STOP AND SEE IF THERE'S ANYBODY IN THE QUEUE.
UM, I DON'T SEE ANYONE IN THE QUEUE.
DAN, I WAS GONNA SAY, I DO THINK WE SHOULD SPEND MORE OF THIS MEETING ON THE EXEMPTION PROCESS, BUT I WAS WONDERING IF YOU COULD RUN THROUGH THE LANGUAGE HAVING TO DO WITH MAXIMIZING CAPABILITIES AND THEN WE COULD PULL UP THE P PAUSE THERE FOR ERCOT AND THEN WE CAN PULL UP THE JOINT
IF YOU CAN GO DOWN TO KIND OF THE, THE, THE, THERE'S A PURPLE PARAGRAPH DOWN A LITTLE FURTHER THERE.
AND SO THIS IS REALLY THE, THE, THE, THE, THE FIRST PART OF THAT MAXIMIZE CAPABILITY, UH, THAT BASICALLY SAYS YOU SHOULD MAXIMIZE UP TO THOSE SECTIONS OF IEEE 2,800, REGARDLESS OF WHEN YOUR, WHEN YOUR DATE IS.
UM, IF YOU, UM, IF AN I IF IT, IF, IF YOUR SGIA DATE CAN'T MEET THOSE REQUIREMENTS, THEN YOU SHOULD STILL MAXIMIZE YOUR, UH, CAPABILITY AT LEAST UP TO THE, THE, THE LEGACY REQUIREMENTS.
I'M SORRY, THIS ONE IS, SORRY, I DON'T, I DON'T HAVE ENOUGH SCREENS HERE TO LOOK AT EVERYTHING.
[00:50:02]
BASICALLY SAYING THAT YOU SHOULD, THIS, THIS ONE WAS REALLY SAYING THAT, THAT TO THE EXTENT YOU CAN, YOU SHOULD TRY TO MAXIMIZE UP TO THE 2,800, WHICH I THINK EVERYBODY WAS OKAY WITH, UH, AT THE LAST MEETING.SO THIS PARAGRAPH EIGHT IS THE RELEVANT PARAGRAPH, RIGHT? CORRECT.
IS THIS THE ONLY ONE? AND THEN, UH, IF YOU GO DOWN A LITTLE FURTHER, UH, IN FACT, I THINK WE SHOULD PROBABLY JUST GO THROUGH AND LOOK AT ALL THE, THE LARGE SECTIONS AROUND, UM, THAT HAVE IN THE PURPLE LANGUAGE.
I, I GUESS ONE OF THE THINGS I FORGOT TO MENTION IS, IS OKAY.
THE, UM, SO YOU SHOULD, UM, THIS IS REALLY THE, THE DATE THAT YOU SHOULD, WELL, THIS IS NOT WORKING WELL.
SCROLL UP TO THE, THE HEADER FOR THIS SECTION PLEASE.
SO EVERYBODY CAN SEE WHAT, WHAT, WHERE WE'RE AT.
OKAY, SO THIS IS FOR THE LEGACY REQUIREMENTS.
UM, OKAY, SO NOW GO DOWN TO THAT, THAT'S THE RIGHT WAY TO WALK THROUGH IT.
SO IF YOU'RE FOR THE LEGACY REQUIREMENTS, UM, ON, UH, PARAGRAPH EIGHT THERE, YOU SHOULD MAXIMIZE YOUR PERFORMANCE PERIOD, UM, AND TO MEET OR EXCEED THOSE LEGACY REQUIREMENTS, WHICH ARE THE ONES UP, UH, PARAGRAPH ONE THROUGH SEVEN, AND YOU SHOULD DO THAT BY THE END OF 2020 END.
SO THEN GO DOWN TO THE NEXT PURPLE SECTION, UNLESS WE WANT, IT LOOKS LIKE NED'S GOT A QUESTION THERE IN THE QUEUE.
UM, I'M READING THROUGH THE, THE REVISED LANGUAGE YOU HAVE AND I APPRECIATE THE, YOU KNOW, THE, THE PARENTHETICAL, YOU KNOW, WITHIN EQUIPMENT LIMITATIONS.
I THINK WE DISCUSSED THIS SOME LAST TIME, UM, YOU KNOW, ABOUT NOT WANTING FOLKS TO, YOU KNOW, NECESSARILY MAXIMIZE TO LIKE A THEORETICAL, UH, LAB, LAB-BASED MAXIMUM THAT THAT COULD RISK DAMAGING EQUIPMENT, UM, THAT'S ACTUALLY OPERATING IN THE FIELD.
SO, AM I READING THAT PARENTHETICAL? IS IS HAVING THAT IMPLICATION? YEAH, SO I GUESS THE, THE ANSWER IS THAT, THAT IF YOU, UM, IF YOU'RE GOING, IF YOU CAN ONLY GET, THERE'S KIND OF THREE CATEGORIES.
THERE'S THAT, LET'S SAY YOU'RE A LEGACY, UH, VINTAGE UNIT, YOU SHOULD MAXIMIZE ABOVE THOSE LEGACY REQUIREMENTS IF YOU CAN, TO THE EXTENT THAT, YOU KNOW, YOU DON'T, UH, HAVE DAMAGE OR ANYTHING LIKE THAT.
YOU SHOULD AT LEAST TRY TO MEET THE, UH, THE LEGACY, THE REQUIREMENTS IN PARAGRAPH ONE THROUGH THROUGH SEVEN THERE.
AND IF YOU CAN'T, THEN YOU HAVE TO GO THROUGH A EXCEPTION PROCESS.
DOES THAT MAKE SENSE? AND SO, UM, YOU KNOW, WE, WE, WE, WE WANT PEOPLE TO GO AS FAR AS THEY CAN, BUT THERE'S KIND OF THOSE THREE BUCKETS.
THERE'S THE, YOU'VE MAXIMIZED A ABOVE THE, THE WHAT YOU'RE REQUIRED TO DO.
THEN THERE'S THE, CAN YOU DO IT LEAST WHAT'S IN PARAGRAPH ONE THROUGH SEVEN THERE, THE, THE LEGACY REQUIREMENTS, OR IF YOU WERE, UM, UM, AT, UM, CAN'T DO AT LEAST UP TO THE LEGACY REQUIREMENTS, THEN YOU STILL NEED TO MAXIMIZE, BUT ONLY UP TO THE, UM, YOU KNOW, TO WHAT YOU, AND, AND THAT'S WHERE THE EXCEPTION.
SO, SO BASICALLY IF YOU'RE IN THAT FIRST CATEGORY WHERE YOU'RE MAXIMIZING ABOVE THE, THE, THE WHAT'S ABSOLUTELY REQUIRED, YOU WOULD ONLY HAVE TO DO THAT THROUGH KIND OF SOFTWARE AND FIRMWARE AND THOSE KIND OF THINGS.
IF YOU'RE MAXIMIZING IN THE, UH, TO, TO TRY TO GET TO THE LEGACY REQUIREMENT, THEN THAT'S WHERE THE, THE, AND YOU SEEK AN EXCEPTION, YOU SHOULD STILL MAXIMIZE.
BUT THAT'S WHERE WE HAVE TO LOOK AT KIND OF FOR THE EXCEPTION PROCESS, YOU MAY HAVE TO DO MORE THAN JUST SOFTWARE AND, AND FIRMWARE AND SO FORTH.
AND, AND THAT'S WHERE THE COST, YOU KNOW, WHAT'S COST EFFECTIVE OR NOT
[00:55:01]
COMES IN AND WHAT, WHAT THE RELIABILITY IMPACTS IS.AND THAT'S, UH, DOWN A LOT FURTHER AND WE'LL GET THERE.
UM, JUST TWO, TWO QUICK POINTS OF, UM, FEEDBACK, UH, ON, ON THESE CONCEPTS.
AND I REALIZE THIS LANG, YOU KNOW, THE SAME KIND OF LANGUAGE SHOWS UP IN MULTIPLE PLACES.
UM, UH, ONE IS ON THE, UH, YOU KNOW, WITHIN EQUIPMENT LIMITATIONS, I THINK WE WOULD APPRECIATE IF THERE WAS SOME RECOGNITION FOR NEEDING TO USE SOME REASONABLE, UH, ENGINEERING JUDGMENT OR SOME OTHER LANGUAGE THAT, YOU KNOW, RECOGNIZES THAT, YOU KNOW, THE, THE EQUIPMENT LIMITATIONS AND, UM, OEM SPECIFICATIONS, WARRANTY, UH, LIMITS, ET CETERA.
PLUS JUST, YOU KNOW, A AN ENGINEERING, AN ENGINEER LOOKING AT, YOU KNOW, HOW TO, UH, HOW TO CONFIGURE ALL OF THE SETTINGS, UH, IS, IS THE RIGHT BALANCE, UH, RECOGNIZING THAT THERE'S MAYBE NOT A, A CLEAR BLACK AND WHITE, UM, YOU KNOW, BUT AS LONG AS IT'S, YOU KNOW, REASONABLE FROM AN ENGINEERING STANDPOINT OR GOOD UTILITY PRACTICE, THERE'S PROBABLY SOME, SOME OTHER LANGUAGE, UH, THAT WE CAN, UH, CRAFT, BUT CONCEPTUALLY WANTED TO MAKE SURE THAT'S, THAT'S CAPTURED IN THERE.
UM, AND THEN ON THE, THE DECEMBER 31ST, 2025 DATE, UM, AS WE, AS WE'VE BEEN THINKING ABOUT THAT TIMELINE, AND I THINK, UM, BOB AND OTHERS BROUGHT THIS UP LAST TIME, YOU KNOW, IT DEPENDS ON FRANKLY, WHETHER OR NOT THERE NEED TO BE DYNAMIC MODEL UPDATES DONE BEFORE THAT TIME, WHICH PROBABLY, UH, IM IMPLIES WHETHER THAT DATE IS IS DOABLE, UM, GIVEN THE BIGGER ONE.
IS IT 1 0 9? UM, UH, ADDITIONAL REQUIREMENTS, UH, IT SEEMS LIKE THAT MIGHT BE A VERY TIGHT DEADLINE.
SO WE'VE TALKED ABOUT POSSIBLY A JUNE OF 2026 BEING A LITTLE BIT ADDITIONAL BUFFER IF, UH, IF THERE NEED TO BE ADDITIONAL DYNAMIC MODEL UPDATES, UM, JUST KIND OF GIVEN WHERE WE ARE IN 2024 AND, UM, YOU KNOW, HOW, HOW, HOW LONG IT CAN TAKE TO ACTUALLY IMPLEMENT THE UPDATES IN THE FIELD AND THEN GO THROUGH THE MODELING EXERCISE AND THEN ADDING ON THE ERCOT APPROVAL PROCESS.
UM, SO ONE TO ONE TO LAY THOSE OUT CONCEPTUALLY.
SO LIKE THIS, YEAH, GO AHEAD, IAN.
I, I WAS GOING TO PAUSE HERE ON THE MAXIMIZING CAPABILITIES AND GO TO JOINT COMMENTER SLIDE.
PLACE TO PAUSE? YEAH, IT SEEMS LIKE THAT'S THE, THAT'S THE ISSUE.
SO YEAH, AND I THINK NED'S LANGUAGE WAS, UH, SIMILAR TO WHAT'S IN THE SLIDE.
ERIC, DO YOU WANNA GO THROUGH THIS? SURE.
AND JUST FOR THE RECORD, UM, FOR 2 45, AS YOU MENTIONED EARLIER, I'LL BE REPRESENTING NEXTERA, UM, OKAY.
AS I HAVE BEEN IN THE PAST ON THIS TOPIC.
UM, SO I THINK THERE'S A LOT OF SIMILARITIES, UH, ON THIS AREA BETWEEN, UM, WHAT DAN SAID AND WHAT WE HAVE HERE, WHICH WE THINK IS, IS GOOD AND IT'S MAYBE WORTH SPENDING SOME TIME ON.
WE TRIED TO BASE THIS ON, UM, YOU KNOW, THE WRAP UP THAT COLIN GAVE AT THE LAST MEETING.
UM, AND, AND THINK THAT THIS COULD BE AN APPROACH THAT, UM, YOU KNOW, COULD BE INCORPORATED INTO THE REVISION.
SO HERE WE HAVE SIMILAR LANGUAGE TO WHAT
UM, BUT LIKE NED SUGGESTED, WE, WE NEED TO HAVE SOME SORT OF, UM, YOU KNOW, ADDITIONAL LANGUAGE TO CLARIFY THAT, UM, YOU KNOW, THEORETICAL APPS OR MAXIMIZATION IS NOT WHAT WE'RE LOOKING FOR BECAUSE WE, YOU KNOW, NO ONE WAS TRYING TO DAMAGE OR DEGRADE, UH, THE EQUIPMENT.
AND I THINK ERCOT SAID THERE LAST TIME, TELL ME IF I'M WRONG, DAN, BUT THAT YOU, YOU KNOW, GENERAL COMFORT WITH SOMETHING LIKE THAT, WE'VE GOTTA WORK ON EXACTLY WHAT IT IS.
UM, AND, UM, WE WANTED TO POINT OUT THIS QUOTE FROM THE IBR ISSUES ALERT, UM, ABOUT MAXIMIZATION.
UH, THIS IS JUST A DIRECT QUOTE AND I'LL READ IT.
ALL PROTECTION SETTINGS SHOULD BE SET TO THE MAXIMIZE WRITE THROUGH PERFORMANCE WHILE
[01:00:01]
STILL PREVENTING DAMAGE TO A DEGRADATION OF THE EQUIPMENT.SO THIS IS, AGAIN, SIMILAR TO THIS GUIDANCE, UM, WE SUGGEST YOU HAVE TO MAXIMIZE WRITE THE CAPABILITY WITHIN A SET TIMEFRAME.
UM, AND WE LEFT THAT SET TIMEFRAME BLANK FOR, YOU KNOW, THE REASONS THAT NED DESCRIBED.
WE JUST NEED TO WORK THROUGH WHAT IS THE PRACTICAL TIMELINE TO UPDATE ALL THE MODELS AND EVERYTHING ELSE.
UM, AND WE THINK IT'S JUST IMPORTANT TO NOTE, GIVEN THE DISCUSSION WE HAD AT THE LAST, UH, MEETING ABOUT, UM, ACCURATE MODELS THAT A SIDE EFFECT OF MAXIMIZATION WILL REQUIRE, UM, UPDATES, UH, TO ALL THE MODELS, UM, AND WOULD REQUIRE ALL IBR, UM, THAT ARE GOING THROUGH THIS MAXIMIZING PROCESS TO, UM, YOU KNOW, UPDATE THOSE MODELS.
SO IT'S, IT'S A HOOK FOR ERCOT, THE ERM, ET CETERA, TO REQUIRE THE, THESE CHANGES.
AND, UM, I THINK THIS IS A DIFFERENCE, BUT EXCEEDS WHAT DAN SUGGESTED, WHICH IS THE DOCUMENTED MAXIMUM CAPABILITIES WE SUGGEST COULD BECOME THE PERFORMANCE REQUIREMENT.
SO I THINK, YOU KNOW, THIS IS, YOU KNOW, HOPEFULLY I'M, I'M NOT MISINTERPRETING THINGS, BUT YOU KNOW, THERE'S A LOT OF COMMONALITY AND MAXIMIZATION HERE AND IT'S WORTH POINTING OUT.
UM, AND I'M HAPPY TO TAKE QUESTIONS OR COMMENTS.
I SEE A QUESTION FROM NED AND THEN, UM, AT SOME POINT, IF THEY WEREN'T GONNA DO IT ANYWAYS, I, I WOULD LIKE TO HEAR FROM ERCOT ON WHAT THEY THINK ON THIS.
I I WAS PROBABLY GONNA ASK A SIMILAR, UH, A SIMILAR PIVOTING QUESTION, UH, CAITLIN, AND YOU KNOW, DAN, THIS IS, UM, KIND OF A TRADE OFF QUESTION TO THE, YOU KNOW, TO THE QUESTION, WHAT'S WHAT'S THE PRIORITIZATION, UH, YOU KNOW, GETTING THE MAXIMIZATION, UH, CHANGES DONE VERSUS HAVING THE MODELS UPDATED? AND SO, YOU KNOW, I, WE HAVE THOUGHT THAT IF THE DECEMBER 31ST, 20, 25 DATE IS JUST FOR IMPLEMENTING THE CHANGES, THE PHYSICAL CHANGES OR THE SOFTWARE UPDATES, UM, THAT'S PERHAPS MORE DOABLE, BUT IT'S, IT REALLY IS ADDING ON THE, THE MODELING REQUIREMENT THAT THAT MAKES IT, YOU KNOW, HIGHLY LIKELY THAT WE'D BE JUST SETTING UP A LOT OF FOOTFALLS, UM, AGAINST THAT DATE.
SO, WANTED TO SEE IF THERE'S A, IF THERE'S A PRIORITIZATION IN Y'ALL'S MIND.
IS IT OKAY IF I TALK, CAITLIN? YEAH, PLEASE GO AHEAD.
I WANNA GET INTO A BACK AND FORTH
IF YOU GET ASKED A DIRECT QUESTION, PLEASE, PLEASE GO AHEAD AND ANSWER, ANSWER IT.
AND I'LL JUST HOPE THAT NED DOESN'T CIRCUMVENT THE, THE INTENT OF MY GUIDELINES, BUT I DON'T THINK HE IS SO, SO TRY, TRY NOT TO.
YEAH, I, I MEAN, I THINK WE, I I, I, I UNDERSTAND THE ISSUE ON THE DAY.
I THINK WE PROBABLY NEED TO SOMETIME BETWEEN NOW AND, AND, UH, MAYBE THE MEETING NEXT WEEK, WE'LL HAVE TO HAVE AN INTERNAL DISCUSSION ABOUT THAT.
UM, ON THE, UM, ERIC'S, YOU KNOW, BROAD, UM, STATEMENT ABOUT NOT, I MEAN, I THINK WE'RE OKAY WITH THE LANGUAGE IN THOSE TWO SUB BULLETS TO START, START DEFINITION OF MAXIMIZE WILL INCLUDE, AND THIS IS CONSISTENT WITH, I MEAN, I THINK THOSE ARE OKAY.
UM, I, I GUESS ONE, UH, ISSUE THAT I, UM, I TALKED ABOUT WHILE AGO THAT THERE'S KIND OF TWO BUCKETS OF MAXIMIZATION.
THERE'S THE BUCKET OF MAXIMIZE ABOVE THE, KIND OF THE LEGACY REQUIREMENTS.
IF YOU'RE IN THAT, THAT CAPABILITY OR IF YOU'RE, UH, IN THE, UM, THE PREFERRED TIMEFRAME AFTER WHATEVER DATE, WE ULTIMATELY DECIDE IF YOU'RE STILL TRYING TO MAXIMIZE IT AS MUCH AS YOU CAN, BUT YOU'RE NOT, YOU'RE, YOU'RE EXCEEDING THE REQUIREMENT FOR YOUR VINTAGE OF SGIA.
I THINK THIS, THIS IS ABS IS, IS A HUNDRED PERCENT CORRECT.
UM, IF YOU'RE MAXIMIZING AND YOU'RE MAXIMIZING OF, UH, UM, ISN'T GOING TO GET YOU TO THE, SAY THE LEGACY IF YOU'RE ON A 2015 VINTAGE UNIT AND IT DOESN'T GET YOU TO THE, UH, YOUR LEGACY REQUIREMENT BY JUST DOING SOFTWARE SETTINGS, FIRMWARE, AND PARAMETERIZATION, I THINK THERE'S STILL, MAXIMIZING STILL HAS TO GO THROUGH THAT OTHER PROCESS.
[01:05:01]
AND SO, UH, TO, TO SEE IF THERE ARE, UH, IS ANY, UH, COST EFFECTIVE HARDWARE SOLUTIONS THAT MIGHT, UM, FIX THE PROBLEM AND TO GET YOU UP TO AT LEAST THE, THE, THE DEFAULT REQUIREMENTS FOR YOUR VINTAGE.AND SO, UM, I, I THINK THAT'S PROBABLY THE ONLY ISSUE I HAVE HERE, BUT THAT, THAT WE STILL NEED TO ADDRESS.
BUT OTHERWISE, I THINK THIS IS GOOD.
AND, AND CERTAINLY WE DIDN'T INTEND TO SAY THAT IF, IF YOUR MAXIMIZATION IS GONNA CAUSE A, A PROBLEM, UM, UM, YOU KNOW, EQUIPMENT DAMAGE OR SOMETHING LIKE THAT, WE, WE DON'T WANT, I THINK THAT'S A, THAT'S A REASONABLE OUT AND, UM, YOU KNOW, GOOD UTILITY PRACTICE HAS BEEN BEAT OVER MY HEAD WHEN WE'VE TRIED TO USE IT IN THE PAST
BUT, UH, I, I THINK WE'LL JUST HAVE TO DEAL WITH THAT.
'CAUSE THIS WHOLE CONCEPT OF MAXIMIZING HAS SOME WIGGLE ROOM BUILT INTO IT, I GUESS.
SO DAN, CAN YOU WE'RE MOSTLY IN AGREEMENT EXCEPT FOR YOU HAD ONE ISSUE WITH THE LANGUAGE POSSIBLY.
YEAH, JUST, JUST, JUST THAT MAXIMIZING CAPABILITIES, I THINK THIS IS FINE WHEN YOU'RE MAXIMIZING AND YOU EXCEED THE CAPABILITY FOR YOUR, UM, YOUR VINTAGE OF YOU MM-HMM,
BUT IF MAXIMIZING DOESN'T GET YOU UP TO THE DEFAULT FOR YOUR VINTAGE UNIT, THEN THERE MAY BE MORE THAT NEEDS TO BE CONSIDERED INCLUDING, YOU KNOW, SOME COST-EFFECTIVE HARDWARE UPGRADES THAT WOULD THEN GO THROUGH THE, THE, THAT EXCEPTION PROCESS.
BECAUSE BASICALLY WHAT YOU'RE DOING IS SAYING, WE'VE MAXIMIZED, WE CAN'T GET UP TO OUR REQUIREMENT, WE NEED AN EXCEPTION.
AND SO WHAT, YOU KNOW, WHAT, WHAT, WHAT THE, IT GETS INTO THE WHOLE EXCEPTION PROCESS.
ERIC, DO YOU WANT TO RESPOND TO THAT OR ADD ANYTHING ELSE TO THIS SLIDE? UM, I HAVE GENERAL COMMENTS ABOUT, UM, YOU KNOW, THE, THE LATEST LANGUAGE, BUT I WANT AVOID THE BACK AND FORTH, SO I'D BE HAPPY TO WAIT UNTIL DAN IS CONCLUDED HIS REMARKS.
IF YOU WANNA WRAP UP THIS SLIDE, UM, YEAH, IF THERE'S A WAY, WITHOUT GETTING INTO GENERAL COMMENTS TO ADDRESS HIS QUESTION OF IF WE CAN SURE.
IN DEFINING MAXIMUM CAPABILITIES NOT HAVE TO GET INTO THAT EXEMPTION AREA.
BUT IF THERE'S NOT A WAY TO DO THAT, THEN LET'S GO BACK TO, TO ERIKA'S COMMENT.
SO JUST, UH, AT A HIGH, HIGH LEVEL, UM, YOU KNOW, WE WANTED TO KINDA WRITE DOWN AN APPROACH TO MAXIMIZATION THAT COULD GUIDE WRITING LANGUAGE.
UM, I, I JUST THINK IT'S, YOU KNOW, NOTABLE, UM, YOU KNOW, THAT WE, WE PROBABLY STILL DISAGREE ABOUT THE THINGS THAT AREN'T ON THIS SLIDE, UH, BUT WE WANTED TO HIGHLIGHT AN AREA OF AGREEMENT.
UM, AND WE HOPE THAT THIS MAXIMIZATION, UM, PROCEDURE WILL LEAD TO MORE AGREEMENT ABOUT THE EFFECTIVE DATE FOR NEW RESOURCES.
BUT, YOU KNOW, ON THE HARDWARE OR, UH, PHYSICAL MODIFICATIONS, I, I THINK THERE'S STILL DISAGREEMENT AT, AT THE PRESENT TIME THAT I'D BE HAPPY TO GET INTO WHEN YOU WANT ME TO.
UM, WHY DON'T WE GO BACK TO
IF YOU'LL GO DOWN TO THE NEXT SECTION HEADER.
SO THIS IS FOR, UM, TH THESE ARE APPLICABLE TO EVERYBODY ALL, UM, IBR AND WGS.
UM, I THINK IT'S SECTION, OH, I'M SORRY.
[01:10:07]
OH, I GUESS STOP RIGHT THERE A MINUTE.UH, AND I DON'T KNOW IF THIS IS THE RIGHT LANGUAGE, BUT IN THIS, UM, ACTUALLY GO UP TO THE BEGINNING OF THE SECTION.
THIS IS THE SECTION WE NEED TO TALK ABOUT.
SO THIS, THIS IS THE EXEMPTIONS AND, AND EXTENSIONS PROCESS.
AND SO BASICALLY THIS IS, IF YOU'VE MAXIMIZED, BUT YOU CAN'T GET UP TO THE, UH, THE, UH, LEVEL OF PERFORMANCE REQUIRED UNDER THE LEGACY, UH, OR THE, UH, PREFERRED REQUIREMENT FOR YOUR VINTAGE RESOURCE, THEN WHAT'S THE PROCESS? YOU, YOU MAXIMIZED? YOU CAN'T GET THERE.
UM, WHAT IS THE PROCESS FOR, UH, DETERMINING EXCEPTIONS? AND SO, UM, BASICALLY THE IDEA IS THAT BY FEBRUARY 1ST, 2025.
AND SO I GUESS THAT DATE, UH, PROBABLY, YOU KNOW, DEPENDING ON WHAT, WITH NED'S COMMENT WHILE I GO, DEPENDING ON WHAT HAPPENS THE OTHER DAY, IT MAY NEED TO, UH, CHANGE TOO.
BUT THE SOONER OR THE BETTER THAT THE RESOURCE ENTITY THAT NEEDS AN EXCEPTION 'CAUSE THEY CAN'T GET TO THE, THE REQUIREMENT FOR THEIR VINTAGE, THEN UH, THEY WOULD PROVIDE INFORMATION TO US.
AND I THINK THAT'S BEEN IN THE, UH, EARLIER VERSION OF THE COMMENTS, THIS IS NOT A RECENT THING.
UM, AND INCLUDING KIND OF THE TECHNICAL CAPABILITIES, THE, THE COST TO IMPLEMENT WHAT IT WOULD TAKE TO GET UP TO THE, UM, UM, THOSE CAPABILITIES.
UM, AND THEN WE WOULD CONSIDER, UH, THAT AND THE RISK TO THE ERCOT SYSTEM OVERALL RELIABILITY.
AND WE'VE TRIED TO SAY WE WOULD, WE WOULD GRANT THE EXCEPTION AS LONG AS THERE, UM, AREN'T, UM, CERTAIN PROBLEMS. AND ONE OF 'EM IS THE, THIS OVERALL RISK TO THE, THE RELIABILITY OF THE SYSTEM.
AND WE'VE TRIED TO LIST OUT WHAT THE, UH, WHAT THAT, THAT, UM, THOSE REQUIREMENTS ARE.
UM, AND ONE OF THE THINGS TO POINT OUT THERE IS THAT, THAT, THAT THOSE REQUIREMENTS, THE 500 MEGAWATTS OR, UH, THAT'S NOT, YOU KNOW, IF IT, IF IT CAUSES, IF NONE OF THE UNITS ARE OVER 500 MEGAWATTS, BUT THE IN THE AGGREGATE, ALL THE UNITS THAT TRIP UNDER SOME, UH, SIMULATION, UH, SHOW WOULD BE OVER 500 MEGAWATTS, THEN THAT, THAT, THAT'S THE CRITERIA.
SO IT'S NOT JUST FROM ONE RESOURCE, WE WOULD CLARIFY THAT.
UM, OR IF THEY HAVEN'T IMPLEMENTED IN SECTION B DOWN THERE.
SO IF IT CAUSES A RELIABILITY PROBLEM, IF THE, UM, THEY HAVEN'T IMPLEMENTED ALL OF THE, UM, UM, THE, THIS SET OF REQUIREMENTS, UM, AND THIS IS THE SET THAT STEVEN TALKED ABOUT LAST TIME, I THINK.
AND, UM, THEN GO DOWN, SEE, AND THEN THIS IS, THIS IS THE PIECE WHERE IT'S WHERE, UH, THAT BASICALLY YOU HAVE TO, UM, THERE WOULD BE SOME CRITERIA THAT SAYS, OKAY, ALL, ALL THESE THINGS IN SECTION B ARE, ARE, ARE RELATIVELY LOW COST, BUT SECTION C IF, IF THERE WAS HARDWARE UPGRADES THAT COULD BE DONE THAT DON'T EXCEED SOME PERCENT OF THE COST OF, UH, UH, THEN THAT WOULD BE, UM, UH, NEED TO BE DONE.
AND SO BASICALLY THAT DEFINES THE, WHAT, WHAT'S A COST EFFECTIVE, UH, SOLUTION AND WHAT'S NOT.
UM, AND SO THAT'S, THAT'S KIND OF LAYS OUT THE EXCEPTION PROCESS FOR THOSE PEOPLE THAT, UM, THAT CAN'T MEET THE VINTAGE REQUIREMENTS.
SO IF THEY'RE AN OLDER UNIT, UH, OR A, YOU KNOW, A 2021 VINTAGE UNIT, UM, BUT THEY CAN'T MEET THE LEGACY REQUIREMENTS, HOW FAR WOULD THEY HAVE TO GO TO, UH, TRY TO CORRECT THAT PROBLEM? AND THEN IF THEY CAN'T, OKAY, CAN'T DO IT, BUT FOR LESS THAN THAT PERCENTAGE, UH, CAN, OR THROUGH ANY OF THESE OTHER MEANS, THEY STILL CAN'T GET UP TO THE LEGACY REQUIREMENT, THEN WE WOULD GRANT THEM, UM, AN EXCEPTION, BUT THEN WE MIGHT DO MITIGATION.
[01:15:02]
THIS IS NEW LANGUAGE THIS TIME, RIGHT? WELL, ONLY THE FROM MULTIPLE RESOURCES, THE, THE 500 MEGAWATTS WAS IN LAST WEEK.DO WE NEED A, LIKE GEOGRAPHICAL QUALIFIER THERE, OR IS THAT 500 MEGAWATTS FOR MULTIPLE RESOURCES ANYWHERE? IT'S STILL A CONCERN.
UH, I, I THINK THAT THE, AND MAYBE THIS ISN'T UNDERSTOOD, BUT IT WOULD BE AS A RESULT OF, OF WHATEVER THE SIMULATION IS, UH, JUDGE MUL.
I MAY HAVE TO PHONE A FRIEND TO MAKE SURE I'M SAYING IT RIGHT, BUT OKAY.
I MEAN, I DON'T, YOU KNOW, AND I, AND I THINK AS STEVEN KIND OF MENTIONED, I THINK THIS 500 MEGAWATT THRESHOLD ULTIMATELY COMES FROM A NERC REPORTABLE REQUIREMENT.
SO I DON'T KNOW THAT THERE'S ANY RESTRICTION ON WHERE IT IS.
I THINK IT'S, YOU KNOW, IF IT'S A RESULT OF THE EVENT, THEN THAT'S PART OF THE, YOU KNOW, LIMITATION CRITERIA.
IT'S JUST, UH, THE CRITERIA AROUND THE EVENT.
AND THEN I HAVE A BROADER QUESTION, UM, YOU KNOW, GOING AGAINST MY OWN RULES FOR, FOR ERIC.
SO ON THE, THE MAXIMUM CAPABILITIES, WHAT JOINT COMMENTERS ARE PROPOSING IS THE, THE DOCUMENTED MAXIMUM CAPABILITIES WOULD BECOME THE PERFORMANCE REQUIREMENTS FOR SOMEBODY THAT AN ERCO VERSION WOULD NEED, THE, THE QUOTE UNQUOTE EXEMPTION, RIGHT? AND, AND THE MAXIMIZATION PROCESS WOULD ALSO REQUIRE ACCURATE MODELS AND ONGOING COORDINATION.
I'M READING THAT FROM THE SLIDE.
SO ERIC, I JUST WANT TO GET AT WHERE WE'RE EXACTLY, WHERE WE'RE DIVERGING SURE.
SO, UH, THE, WE HAVE A NUMBER OF CONCERNS WITH THE, UM, MODIFICATIONS TO THE TAC REPORT, UM, THAT ER COUNTY HAS PROPOSED THE, IN THE, UM, EXEMPTION PROCESS.
ONE IS AROUND THE STANDARD FOR REVIEW.
UM, ANOTHER ONE IS THAT THIS LIST OF RELIABILITY ISSUES, UM, YOU KNOW, COULD BE, UM, YOU KNOW, POTENTIALLY ARBITRARY.
UM, SO, UM, THE TAC REPORT ALREADY SAYS THE IBR, UM, CAN'T REDUCE THEIR RIDES OF CAPABILITY.
UM, IT'S NOT CLEAR, UM, WHETHER OR NOT THERE'S ANY ADDITIONAL MODELING THAT, UM, COULD BE BENEFICIAL.
UM, WE'RE NOT, IT'S NOT CLEAR, UM, HOW ERCOT WOULD DETERMINE WHETHER OR NOT YOU COULD DAMAGE NAVY NEIGHBOR EQUIPMENT.
WE DON'T KNOW HOW TO INTERPRET UNKNOWN OR UNVERIFIED LIMITATIONS, UM, ET CETERA.
SO WE'VE GOT A NUMBER OF CONCERNS, UM, WITH THE MODIFICATIONS HERE THAT, UM, YOU KNOW, COULD LEAD TO A REQUIREMENT FOR A, A GENERATOR TO, TO DO SOMETHING THAT YOU KNOW, ISN'T NECESSARILY, UH, APPROPRIATE.
I'M, I'M HAPPY TO TALK THROUGH THOSE IN MORE DETAIL IF I'VE GOT QUESTIONS ABOUT IT, BUT WE, WE DO HAVE A NUMBER OF OUTSTANDING CONCERNS ABOUT THESE PROPOSED CHANGES.
HI, CAN YOU HEAR ME? YES, I CAN.
UH, FIRST I WANNA THANK YOU FOR THE PRESENTATION TODAY.
I THINK IT'S BEEN VERY HELPFUL FOR ME TO UNDERSTAND, UH, CHANGES AND, AND WHERE THE DIFFERENCES ARE IN THE, THE TWO POSITIONS.
AND, UM, UH, I, THAT'S REALLY BEEN HELPFUL.
I, I, I AM STUCK ON AN ISSUE THAT WE DISCUSSED TWO MEETINGS AGO ABOUT MODELING ACCURACY AND, AND THE EXCEPTIONS LANGUAGE HEREIN, I THINK 12.2 0.1, PARAGRAPH FOUR RAISES THIS FOR ME, WHERE IT SAYS, UM, WHEN DETERMINING WHETHER TO GRANT AN EXEMPTION OR WILL USE ITS SOLE AND REASONABLE DISCRETION, UM, AND WILL DETERMINE WHETHER THERE IS UNACCEPTABLE RELIABILITY RISK RELATED TO THE ITEMS IN THIS
[01:20:01]
LIST.AND SO I WANT TO GO BACK TO MODELING.
AND MY QUESTION FOR DAN IS WHETHER THE DATA AND MODELS TODAY IS, OR, AND, AND BY THIS DATE THAT WE'RE TALKING ABOUT, WILL BE SUFFICIENT FOR ERCOT TO ASSESS WHETHER THERE IS UNACCEPTABLE RELIABILITY RISK.
UM, AND WE WENT THROUGH WITH THAT MEETING TWO MEETINGS AGO, A A NUMBER OF REASONS WHY MODELS AND DATA ARE, ARE NOT SUFFICIENT TODAY.
SO MY QUESTION IS WHETHER MODELS AND DATA WILL BE SUFFICIENT AT THIS DATE FOR ERCOT TO MAKE THIS ASSESSMENT.
AND IF IT'S NOT, ARE WE MISSING A STEP HERE WHERE FIRST WE HAVE TO DO A COMPREHENSIVE, LET'S VALIDATE MODELS ACROSS THE BOARD.
I MEAN, WE DO INSPECTIONS OF RESOURCE CAPABILITIES FOR SUMMER AND WINTER.
NOW, ISN'T THIS SUFFICIENT IMPORT THAT WE MIGHT DO A COMPREHENSIVE REVIEW OF WHETHER WE HAVE DATA AND MODELS FROM ALL THESE RESOURCES? THANKS, DAN, DO YOU WANNA RESPOND TO THAT? YEAH, SO I THINK THE, THE, THE PROBLEM TODAY IS THAT THE MODELS DON'T EITHER, EITHER HAVE INCORRECT, UH, INPUTS OR DON'T, UM, COMPLETELY MODEL ALL OF THE, UH, THE CAPABILITY OR THE, THE, THE PROTECTION SYSTEMS AND THE, THE OTHER THINGS THAT WOULD CAUSE UNITS NOT TO RIDE THROUGH.
SO, SO RIGHT NOW, THE PROBLEM IS NOT THAT, UM, WE'RE SEEING WE'RE THE MODELS ARE SHOWING A RELIABILITY PROBLEM, THAT THAT MAYBE DOESN'T EXIST IN THE REAL WORLD.
IT'S EXACTLY THE OPPOSITE OF THAT.
IT DOESN'T SHOW THE RISK THAT, UH, ARE IN THE REAL WORLD BECAUSE THE, THE, THE MODELS DON'T SHOW ALL THE PROTECTION SYSTEMS AND ALL THE, THE, THE DETAIL TO SOME EXTENT.
AND SO I WOULD AS ASSUME, I WOULD HOPE THAT THE, UH, IMPROVEMENT TO THOSE MODELS IS GOING TO MORE ACCURATELY REFLECT, UM, FUTURE, UM, OR IN THE FUTURE IT WILL MORE ACCURATELY REPRESENT THE, UH, ALL OF THE THINGS THAT COULD CAUSE A RELIABILITY PROBLEM, UM, THAT WE'RE NOT SEEING TODAY.
AND, UH, I'D LIKE TO ASK JOHN SCHMALL TO THAT, HELP ME WITH THAT FEE.
HAS ANYTHING ELSE TO ADD? YEAH, THANKS, DAN.
AND I, AND I THINK PART OF THE, I MEAN, I THINK IT'S PART OF THE EXEMPTION PROCESS, AND IT'S UNDER, I BELIEVE, THINK OF IT
AND THAT'S WHAT I THINK THAT'S ESSENTIAL TO MAKING THAT DETERMINATION OF, IS IT, IS, IS IT CAUSING RELIABILITY RISK OR NOT.
MARK, ARE YOU GOOD? SORRY, DOUBLE MUTED.
UM, YEAH, I'M JUST STILL A LITTLE CONFUSED ON WHETHER WE HAVE THE TIMING RIGHT AND THE STAGES, RIGHT WHERE THAT DATA WILL BE AVAILABLE TO ERCOT IN ADVANCE OF NEEDING IT FOR THIS MODELING PROCESS.
IT'S GONNA LOOK KIND OF COMPREHENSIVELY AT ALL THE RESOURCES THAT ARE BEING MODELED OR THAT ARE, UH, SEEKING EXEMPTION.
SO THE QUESTION IS IF THE MODELS WILL BE ACCURATE INPUTS TO THE EXEMPTION PROCESS? YES, THAT'S THE QUESTION.
ANY LAST THOUGHTS ON THAT? I MEAN, I, I, I THINK WHAT I WAS TRYING TO SAY, MAYBE I CAN SAY IT MORE SUCCINCTLY NOW, THAT, THAT TO THE EXTENT THAT THE MODELS ARE NOT ACCURATE, IT'S MUCH LESS, IT'S, IT'S, IT'S MORE OF A RELIABILITY PROBLEM THAN IT IS A, A CAUSING UNITS TO HAVE TO, UM, DO UPGRADES THAT THEY WOULDN'T OTHERWISE HAVE TO DO, BECAUSE OKAY.
I, I, I GUESS SOME OF THE, THAT, THAT DISCUSSION, UM, MARK'S COMMENTS AND, UM, MAYBE KEYS INTO THE, THE, THE NEED TO TIME, THE, THE TIMING
[01:25:01]
TO UPDATE, UM, MODELS I WAS BRINGING UP EARLIER.UM, BUT THE, UM, HERE, WHILE WE'RE TALKING RIGHT NOW, THE, UM, THE, THE COMMENT I, I WANTED TO MAKE THOUGH IS THAT IN, IN THIS SECTION, UM, WHERE WE'RE, UM, WHERE WE'RE LOOKING AT THE, THE TECHNICALLY FEASIBLE UPGRADES AND TRYING TO COMPARE THAT TO A CERTAIN, YOU KNOW, PERCENTAGE COST, IT, IT'S GOOD.
I STILL THINK IT'S GONNA BE REALLY DIFFICULT TO TRY TO PUT THAT IN BLACK AND WHITE TERMS, GIVEN HOW, UM, YOU KNOW, THAT'LL INTERPLAY WITH THE USEFUL LIFE REMAINING ON THE, ON THE EQUIPMENT.
AND, UM, I MEAN, EVEN, EVEN SOFTWARE AND WARE SETTINGS OR IN PARAMETERIZATION CHANGES CAN HAVE COSTS ASSOCIATED WITH IT, RIGHT? IT'S NOT ALL LIKE, IT'S JUST FREE, YOU KNOW, FREE OPTIONS.
BUT, YOU KNOW, WE'RE, I THINK WE'RE ALL, ALL IN AGREEMENT THAT THOSE ARE THE, THAT'S THE LOW HANGING FRUIT, BUT LIKE, SYSTEM PROTECTION, UPGRADES, REPLACEMENTS, COMMUNICATION UPGRADES, CONTROLLER AND UPGRADE KITS, COMPONENT UPGRADES, THOSE ALL ACTUALLY HAVE, YOU KNOW, REAL COST ASSOCIATED WITH THEM.
SO I DON'T KNOW HOW TO, HOW TO INCORPORATE THAT INTO THIS LANGUAGE.
UM, BUT IT, IT'S, IT'S SOMETHING THAT I'M STILL STUCK ON.
SHOULD WE MOVE ON TO BOB HILTON? OKAY.
ACTUALLY, UH, UH, NED KIND OF HIT ON EXACTLY WHERE I WAS TRYING TO GO, IS THAT, AND I'M LOOKING AT THE INTERPLAY BETWEEN B AND C, I THINK IT IS BELOW ON THE HARDWARE SIDE, AND, YOU KNOW, THE B ALL THAT HAS A COST ASSOCIATED WITH IT, AND THAT HAS TO BE FIGURED IN, UH, AND I THINK DOES, AND I PROBABLY ALREADY KNOW THE ANSWER TO THIS, BUT WHEN YOU GET DOWN TO WHATEVER PERCENTAGE IS SET DOWN AT THE BOTTOM, SHOULD THAT INCLUDE THE COSTS OF WHAT YOU DID UNDER B? BECAUSE THAT REALLY PLAYS INTO WHETHER YOU'RE GONNA GO AND DO SEE BASED ON THE COST, AGE OF THE PLANT AND THOSE TYPES OF ISSUES, LIFETIME OF THE PLANT.
SO I GOT THAT KIND OF THE SAME ISSUE THAT NED H IS ON THAT.
UH, BUT MORE SPECIFICALLY ON SECTION C, UH, I WANNA SEE IF I'M READING THIS RIGHT OR IF I'M MESSED UP.
UH, YOU KNOW, IT SAYS UPGRADING OR MODIFYING THE RESOURCE IS LESS THAN X PERCENT OF THE COST ON A PER INVERTER TURBINE BASIS TO REPLACE IT WITH NEW IN, NEW IN KIND, INVERTER OR TURBINE.
SO MY QUESTION IS, IS THAT MEANT TO SAY THAT IF I HAVE FOUR, I'M JUST THROWING OUT NUMBERS HERE, THIS IS NOT REALITY.
UH, IF I'VE GOT FOUR INVERTERS, THEN THE TOTAL COST OF WHAT I HAVE IS X PERCENT TIMES FOUR.
IS THAT WHAT THAT MEANS? 'CAUSE A NEW INVERTER IS ABOUT BETWEEN 250 TO $350,000, UH, IS WHAT I'M UNDERSTANDING, DEPENDING ON THE INVERTER.
UH, SO I'M TRYING TO SEE IF THAT IS A, THAT'S THE, THE LIMIT, THAT NUMBER RIGHT THERE, 50% OF THAT, OR IF IT IS, IF I'VE GOT FOUR INVERTERS, IS IT THAT PERCENTAGE TIMES FOUR? AND I'M TRYING TO MAKE SURE I UNDERSTAND THAT THAT'S ALL.
IS THAT A QUESTION FOR OR CAUGHT ON THE PERCENTAGE? YEAH.
WELL, IT'S, IT'S ON THE WHOLE PARAGRAPH IS IF NOT THE PERCENTAGE, YOU KNOW, WE'RE NOT DECIDING THAT RIGHT NOW.
UH, MY QUESTION IS, IS THAT, IS THAT THE NUMBER OR IS IT IF I HAVE FOUR INVERTERS, IT'S THAT NUMBER TIMES FOUR, OR, OKAY.
IF IT'S THEN THERE COULD BE, YOU KNOW, 50
SO THAT'S WHAT I'M TRYING TO FIGURE.
DAN OR JOHN, DO YOU HAVE AN ANSWER TO THAT OR ANY INSIGHT? YEAH, I, I GUESS THE WAY I HAD BEEN THINKING ABOUT IT, BUT I I, I'M NOT THE ONE THAT HAS BEEN THINKING ABOUT THIS THE MOST, THE, UH, WAS THAT THE, THE, THE FIX, I MEAN, THE ULTIMATE FIX WOULD BE TO, UH, REPLACE A, A INVERTER OR TURBINE OR, OR WHATEVER.
[01:30:01]
BE 10% OF THE COST OF THAT FOR, FOR, FOR THAT TERM.THE, THE COST OF UPGRADES TO THAT, UH, TURBINE, WHATEVER IT IS.
UM, THAT IT WOULD BE, IF I THINK YOU SAID $250,000, IF IT'S 10% OF IT WAS 10%, THAT'D BE, UM, $25,000 PER TURBINE, UM, THAT YOU WOULD SPEND.
AND I GUESS IF THERE'S, YOU KNOW, A HUNDRED TURBINES THAT NEEDED THAT IT WOULD BE BACK UP TO, YOU KNOW, 25 MILLION, SOMETHING LIKE THAT.
UM, BUT, BUT YOU KNOW, I, I GUESS THAT THAT BOB BRINGS UP A GOOD POINT BECAUSE IF IT'S SOMETHING LIKE A, A OVERALL PLANT CONTROLLER OR SOMETHING LIKE THAT, WHAT'S THE, WHAT'S THE COST LIMIT THERE? UH, SO, UH, YOU KNOW, THERE PROBABLY DOES NEED TO BE MORE CLARITY.
AND, AND I GUESS WHAT I'M THINKING ABOUT IS IF, IF THERE'S SOME BETTER WAY TO PROVIDE WHAT THE, UH, A, A WELL UNDERSTOOD, UM, CLEAR, UM, QUANTITATIVE, UH, ON, UH, WAY OF, OF DECIDING WHAT THE, WHAT THAT, HOW MUCH, HOW FAR SHOULD YOU GO IN, IN, UH, MEETING THE LEGACY REQUIREMENTS, UM, OTHER THAN JUST A STRAIGHT PERCENTAGE LIKE THIS, THEN I THINK WE'RE OPEN TO THAT.
BUT THE COMMISSION DEFINITELY DIDN'T WANT IT TO BE, YOU KNOW, KIND OF WHAT I'D CALL LOOSE.
UM, UH, IT NEEDS TO BE REPRODUCIBLE AND CLEAR AND CONSISTENT ACROSS ALL PLANTS AND, AND THOSE KIND OF THINGS, ALL THE, ALL THOSE, UH, BULLETS THAT WE PUT IN THERE.
SO, UM, IF THERE'S A BETTER WAY TO DO THAT AND, YOU KNOW, CLARIFY OPS, UM, QUESTION.
LET'S, LET'S MOVE ON FOR, FOR NOW OR MOVE TO THE NEXT QUESTION.
AND I, I THINK WE'LL PROBABLY CIRCLE BACK TO, TO THE CONCEPT OF THE PERCENTAGE OF COSTS.
THIS GOES BACK TO MARK DREYFUS QUESTION.
SO I THINK IT'S FOR ERCOT, BUT DO, DOES ERCOT STUDY THE INSTABILITY OUTSIDE OF THE QUARTERLY STABILITY ASSESSMENT PERIODS? WELL, I, I THINK OUR, UM, UH, INTENT HERE WOULD BE THAT IF WE, IF WE GET IN ALL THE EXCEPTIONS BY FEBRUARY 1ST, 2025 OR WHAT, YOU KNOW, THE, AND, AND ALL THE NEW MODELS, AND, AND YOU KNOW, I, I DON'T DISAGREE WITH WHAT, UM, UH, NED SAID EARLIER ABOUT, GIVEN WHAT THE DIFFICULT WE'VE HAD AT GETTING TSAT MODELS, UM, IT, IT MAY BE DIFFICULT TO GET THOSE IN, BUT ONCE WE'VE GOT THOSE IN WHATEVER THAT TIME IS, THEN WE WOULD DO A SPECIAL ANALYSIS TO EVALUATE KIND OF THE AGGREGATE, UM, UM, RISK OF ALL THESE EXCEPTIONS UNDER, YOU KNOW, ALL THE DIFFERENT FAULTS THAT COULD HAPPEN AND, AND SO FORTH.
AND MAYBE I SHOULD PAUSE AND LET JOHN SEE IF JOHN HAS ANY MORE CLARIFICATION ON THAT.
NO, I, I THINK THAT'S, I THINK THAT'S THE INTENTION OF THIS, AND I'M NOT SURE WHAT THE ORIGINAL, I MEAN, IF THE ORIGINAL QUESTION WAS MORE ABOUT IS, IS IT DOES A SPECIFIC EVALUATION OR WAS IT MORE GENERAL? 'CAUSE I THINK YOU TURNED, YOU TALKED ABOUT LIKE THE QSA, ARE WE DOING STUDIES IN ADDITION TO THE QSA? I MEAN, I THINK THIS EVALUATION IS SPECIFIC SEPARATE FROM A QSA, BUT YOU KNOW, THEY'RE OBVIOUSLY PLANNING ASSESSMENTS THAT GO ON ANNUALLY ALL THE TIME.
YEAH, I GUESS REALLY KIND OF THE QUESTION COMES DOWN TO IF, IF THERE'S MULTIPLE, YOU KNOW, UNITS THAT THEN, YOU KNOW, IF TWO UNITS ARE OKAY, AND THEN THE THIRD OR FOURTH ONE KICKS IT OVER, HOW DO YOU, HOW DO YOU DECIDE WHEN IT GETS TOO HIGH AND WHO GETS THE EXEMPTION IF YOU'RE GONNA RUN IT ALL AT THE SAME TIME? YEAH, AND I, I, I, I'LL TRY TO ANSWER THAT QUESTION.
I THINK THE INTENTION, AND, AND I THINK THIS IS WHERE WE GOT INTO SOME QUESTIONS ABOUT, YOU KNOW, WHEN, WHEN THERE'S A DEADLINE FOR GRANTING AN EXEMPTION OR NOT.
I THINK ULTIMATELY AT THE END OF THE DAY, IN ORDER TO ACTUALLY EFFECTIVELY GRANT AN EXEMPTION AND KNOW IF THERE'S RELIABILITY OR ISSUE OR NOT, YOU NEED BASICALLY ALL THE RESOURCES OR ALL THE IDRS IN A PARTICULAR AREA THAT COULD BE IMPACTED BY A, YOU KNOW, A SINGLE DISTURBANCE.
AND I THINK, I GUESS WHAT WE'VE LEARNED FROM ODESSA IS THAT CAN BE A FAIRLY WIDE AREA, YOU KNOW, IT, IT CAN'T BE DONE ON INDIVIDUAL BASIS.
AND I THINK THERE WAS, I THINK SOME OF THE ORIGINAL PROPOSALS WERE, YOU KNOW, YOU KNOW, OR ACCOUNT CAN GIVE US THIS EVALUATION WITHIN 10 DAYS, WHETHER WE GET AN EXEMPT EXEMPTION OR NOT.
AND I DON'T THINK THAT'S NECESSARILY FEASIBLE.
[01:35:01]
I MEAN, I, YOU KNOW, IF I KNOW THAT YOU'RE THE ONLY UNIT IN THAT AREA, THAT MIGHT BE FEASIBLE AND, BUT IF IT HAS THE POTENTIAL IMPACT, LIKE I SAY, A WIDER AREA AND I COULD POTENTIALLY LOSE MULTIPLE UNITS BASED ON, ON GRANTING EXEMPTIONS, I THINK YOU NEED TO HAVE ALL OF THAT INFORMATION BEFORE YOU RUN THAT KIND OF EVALUATION.ALL GOOD? OKAY, IAN, THANK YOU, UM, THAT THOSE QUESTIONS KIND OF, UH, STARTED GOING DOWN THE PATH I WAS GOING DOWN TO.
UM, SO PUTTING MY FORMER ROLE TAP BACK ON AND THINKING THROUGH THIS, IF THERE ARE TWO RESOURCES THAT WERE BUILT ALMOST IDENTICALLY AND NEED THE EXACT SAME EXCEPTION AND APPLIED FOR THE EXCEPTION AT THE EXACT SAME TIME, AND ERCOT CAN ONLY GRANT IT TO ONE, BUT BEING RELIABILITY, BUT RE RETAIN RELIABILITY IN THE SYSTEM DUE TO A LOCAL ISSUE THERE, HAS ERCOT THOUGHT THROUGH HOW THEY WOULD OR WOULD NOT GRANT THOSE APPROVALS? YEAH, I'LL TRY TO ANSWER AGAIN, AND DAN CAN JUMP IN IF HE HAS ANYTHING FURTHER TO ADD, BUT I, I THINK THE, LIKE I SAID, I THINK THE INTENTION IS, YOU KNOW, I THINK THAT'S WHY YOU NEED TO EVALUATE, UH, KIND OF HOLISTICALLY.
AND I THINK THAT THAT'S WHY IT'LL BE CHALLENGING TO TRY TO SAY, I HAVE TO GRANT AN EXEMPTION INDIVIDUALLY BASED ON EACH ENTITY.
I MEAN, I THINK IN TOTALITY, IN THE, IN THE SCENARIO YOU PRESENT, YOU KNOW, IF I HAVE, AND MAYBE IT'S FOUR UNITS THAT ALL ARE GRANTED ASKING AN EXEMPTION AND I HAVE AN ISSUE THAT LEADS TO A RELIABILITY ISSUE, ONE OF THESE, YOU KNOW, UH, ONE OF THESE ITEMS IN, IN THE RELIABILITY ISSUE IS LIST, I THINK THE END RESULT IS NONE OF THEM WOULD GET GRANTED AN EXEMPTION.
MATT, I THINK WE MAY NEED SOME, SORRY, I'M JUST TRYING TO THINK THROUGH IF ERCOT IS OPENING THEMSELF UP TO LITIGATION WHERE SOMEONE COULD TAKE THE ROLES AND IN COURT PUSHED THEM BECAUSE THE FACT THAT IF THEY HAD RECEIVED THEIR EXCEPTION, IT WOULD NOT HAVE TRIGGERED A RELIABILITY, UM, ISSUE BECAUSE THEY GOT IN FIRST.
OR, UM, IF, IF IN YOUR EXAMPLE OF FOUR, IF THREE OF THE FOUR COULD HAVE GOTTEN IT, UM, ET CETERA.
SO I'M, I'M JUST A LITTLE AFRAID OF ERCOT OPENING THEMSELVES UP IF THIS HASN'T CLEARLY BEEN WRITTEN OUT EXACTLY HOW AND WHO AND WHAT THE PROCESS WOULD BE FOR DETERMINING WHO DID AND WHO DID NOT RECEIVE THIS.
UM, ESPECIALLY IN A CASE WHERE SOMEONE WOULD BE ARGUING THE FACT THAT THE, THE REQUIRED UPGRADES WOULD MAKE THEM UNECONOMIC.
UM, SO I'M JUST, SORRY, JUST TRYING TO THINK THROUGH, UH, THE, WHAT
THANK YOU VERY MUCH FOR, UM, ANSWERING THAT UP.
AND IT SEEMS, I MEAN, IT SEEMS TO ME THERE NEEDS TO BE A LOT MORE THOUGHT PUT INTO THAT, AND THAT MIGHT NOT BE, YOU KNOW, IT SOUNDS LIKE WHAT WE WERE LOOKING FOR OR WHETHER WAS LOOKING FOR IS A REPEATABLE PROCESS, AND IT SEEMS LIKE THAT MIGHT NOT BE A CLEAR, REPEATABLE PROCESS, UM, WHICH I THINK IS FINE, BUT I, I THINK WHAT I'D LIKE TO SEE IS WHERE WE HAVE AGREEMENT AROUND THE MAXIMUM CAPABILITIES, IT, IT SEEMS LIKE MAXIMUM CAPABILITY IS SOMETHING DIFFERENT THAN SAYING GET TO X STANDARD BASED ON A CERTAIN PERCENTAGE, THAT THAT MIGHT NOT BE APPLIED THE SAME WAY BASED ON WHERE WE ARE ON, ON STUDIES.
SO I'M JUST REALLY HOPING THAT WE CAN, YOU KNOW, DECOUPLE WHERE WE DON'T HAVE AGREEMENT FROM WHERE WE DO HAVE AGREEMENT.
AND IN MY MIND, IF IT'S A REALLY SUFFICIENTLY NARROW AMOUNT OF MEGAWATTS, WHICH I, I THINK AND HOPE IT IS, THEN MAYBE WE DON'T NEED A REPEATABLE PROCESS.
[01:40:01]
SOME KIND OF EXEMPTION PROCESS, UM, THAT, THAT GOES THROUGH THE COMMISSION OR DECIDED BY ENGINEERS AND, AND THROUGH MODELING FOR THAT, THAT NARROW AMOUNT OF MEGAWATTS.BUT LET'S, LET'S GO TO BILL BAR AND THEN WE CAN FINISH UP THE, THE QUEUE.
SORRY, DAN, APOLOGIES IF YOU COVERED THIS ALREADY, BUT CAN YOU EXPLAIN THE, THE BASIS FOR THE 500 MEGAWATT? ACTUALLY, I'M GONNA LET JOHN, YEAH, NO, I THINK, I THINK THAT'S BASICALLY THE THRESHOLD.
THAT IS A NERC REPORTABLE EVENT.
SO IF THERE'S AN EVENT THAT LOSES 500 MEGAWATTS OF GENERATION, THAT EVENT NEEDS TO BE, YOU KNOW, REPORTED, REPORTED TO, TO MECK AND, YOU KNOW, YOU KNOW, INVESTIGATIONS OCCUR AT THAT POINT.
SO I THINK THE INTENTION, IT WOULD BE THAT WE DON'T WANT TO INTENTIONALLY HAVE TO, YOU KNOW, PLAN AND, AND, AND EXPECT THAT WE'RE GOING TO HAVE MECK REPORTABLE EVENTS.
I GUESS THAT'S THE, THE SHORT OF IT IN MY VIEW.
WHAT ABOUT, UM, I, I'M JUST TRYING TO THINK OF A MORE, UM, FIRM REQUIREMENT.
I MEAN, HAVING TO REPORT TO NERC IS, I UNDERSTAND WHY YOU GUYS DON'T WANT TO DO THAT, BUT I, I DON'T KNOW IF THAT'S NECESSARILY SUFFICIENT FOR THIS.
MAYBE TYING IT TO, UM, LIKE THE SINGLE LARGEST CONTINGENCY OR SOME AMOUNT BELOW THAT THAT'S REALLY MORE, HAS MORE TEETH IN TERMS OF, UM, OF RELIABILITY ISSUE THAT WE USE FOR OTHER PURPOSES.
JUST CURIOUS WHAT YOUR THOUGHTS ARE THERE.
YEAH, I DON'T, LIKE I SAID, I THINK THE, I DON'T, YOU KNOW, I THINK THAT'S SOMETHING THAT TECH CAN CERTAINLY DECIDE.
I THINK THAT, LIKE I SAID, I THINK THAT'S THE RATIONALE IT SEEMS ON THE SURFACE, I THINK SURFACE IT, SURFACE SURFACE IT, IT SEEMS REASONABLE THAT WE SHOULDN'T, YOU KNOW, PLAN TO HAVE WORK REPORTABLE EVENTS ON THE SURFACE.
I DON'T KNOW IF DAN OR HAS ANYTHING FURTHER TO ADD.
YEAH, AND I THINK, I THINK PART OF THE ISSUE THERE IS THAT, UM, UM, AND THIS GETS BACK TO THE, THE MODELING THING IS THAT SOMETIMES WE HAVE, UH, UM, TODAY MORE UNITS TRIP THAN WHAT WE THINK, UM, SHOULD TRIP FOR A, FOR A PARTICULAR EVENT.
AND SO, UM, WE KIND OF, YOU KNOW, IF WE SAY 500 AND WE ARE, THE MODELS SHOW THAT 500 IS GONNA TRIP, WE MAY ACTUALLY GET 1500 THE TRIP.
AND, UM, YOU KNOW, AS WE IMPROVE THE MODELING, WE MIGHT BE, UM, WILLING TO GET CLOSER TO THE, UM, MSSC TYPE LEVEL IF, IF WE COULD BE SURE THAT THAT'S ALL THAT WAS GOING TO GENERALLY TRIP, WHICH IS KIND OF, WE'RE, WE'RE DEFINITELY HOPING THROUGH THIS PROCESS AND THROUGH A PERIOD, UH, 1 0 9 THAT WE START GETTING MUCH BETTER, UM, MODEL PERFORMANCE.
UH, I, I DON'T MEAN TO SIMPLIFY THIS ISSUE AT ALL.
I, I REALIZE IT'S VERY COMPLICATED, BUT I DID WANT TO EXPLORE KAITLIN'S COMMENT A BIT 'CAUSE IT SOUNDED LIKE ME, TO ME, LIKE REASONABLE PROGRESS.
UM, I'M CURIOUS IF ERCOT OR THE JOINT COMMENTERS CAN GIVE, UH, THEIR THOUGHTS ON, YOU KNOW, AN, AN OPPORTUNITY FOR DIVIDING THE ISSUE AS KAITLYN OUTLINED.
AND IS THAT POSSIBLE? UH, AT LEAST AT A HIGH LEVEL RIGHT NOW? THANKS.
WELL, I, I GUESS I'LL ANSWER FIRST AND THEN ERIC CAN ANSWER IT.
THE, UM, UM, THE, FROM, FROM A, IT, IT GETS BACK TO THOSE TWO, TWO BUCKETS, RIGHT? IT'S, UM, FOR IF YOU'RE MAXIMIZING, UM, ABOVE YOUR KIND OF MINIMAL RE MINIMUM REQUIREMENTS, UM, WHETHER YOU'RE A LEGACY ONE OR, UH, IN THE PREFERRED TIMEFRAME, WHAT WHATEVER THAT CUTOFF AND THE DATE IS, UM, THEN, YOU KNOW, I, I THINK WE COULD AGREE WITH, YOU KNOW, THE LANGUAGE THAT, THAT ERIC, UM, PROPOSED EARLIER.
UM, IF, IF YOU CAN'T MEET THE MINIMUM REQUIREMENTS FOR, FOR YOUR VINTAGE UNIT, AND SO NOW MAXIMIZING MEANS GETTING AS FAR AS YOU CAN.
[01:45:02]
THE QUESTION IS HOW FAR DO YOU HAVE TO GO? UM, IS IT ONLY UP TO THE, UH, THE, WHAT YOU CAN DO THROUGH SOFTWARE AND THE THINGS THAT WERE ON THE SLIDE? OR DO YOU NEED TO GO FURTHER TO TRY BECAUSE IT'S, UH, YOU KNOW, REALLY THERE, WE, WE CAN'T JUST LET THE RELIABILITY PROBLEM EXIST.SO WE'VE SAID THERE'S A RELIABILITY PROBLEM, OR AT THAT POINT, WE, IF WE SEE THAT THERE'S A RELIABILITY PROBLEM, THEN WE GOTTA FIX IT SOMEHOW, EITHER BY CURTAILING THE PLANTS OR IF THERE'S A TRANSMISSION SOLUTION, THEN WE CAN PUT THAT IN AND CONSUMERS CAN PAY FOR IT, OR THE PLANT CAN, UH, DO, UH, UPGRADES, UH, FURTHER THAN JUST SOFTWARE AND FIRMWARE AND SO FORTH.
AND, UM, AND I DON'T EVEN KNOW, I'M, I'M SAYING THOSE THINGS LIKE THEY'RE FEASIBLE, BUT, YOU KNOW, IT WOULD BE A CASE BY CASE BASIS.
UM, SO THEN THE, THE QUESTION IS HOW FAR SHOULD THE PLANT HAVE TO GO TO TRY TO SOLVE THOSE PROBLEMS? HOW MUCH MORE SHOULD, UH, THEY SPEND THAN JUST THOSE, UH, RELATIVELY, I, I, I AGREE WITH WHAT SOMEBODY SAID EARLIER THAT THEY'RE, THEY'RE, THEY'RE NOT ZERO COST, BUT THEY'RE, THEY'RE RELATIVELY LOW COST, UH, UPGRADES.
HOW, HOW MUCH FURTHER SHOULD THEY GO? AND THAT'S WHERE WE WERE TRYING TO GET TO WITH THE, UH, SOME COST BASIS FOR, UH, HOW MUCH YOU MORE SHOULD YOU HAVE TO SPEND.
I MEAN, THERE'S GOTTA BE SOMETHING THERE TO SAY, HERE, HERE'S HOW FAR YOU SHOULD GO.
AND, UM, IF THAT'S JUST THE, UM, UP TO THE, THE ONLY THING YOU'RE REQUIRED TO DO OR SOFTWARE AND, UH, UM, FIRMWARE AND, AND, AND PARAMETERS, UPGRADES AND THOSE KIND OF THINGS, THEN YOU KNOW, SOME, SOMEHOW WE'VE GOTTA SOLVE THE RELIABILITY PROBLEM IF ONE'S IDENTIFIED.
SO THAT, THAT'S THE, THAT'S THE QUESTION.
WHAT, HOW, HOW, HOW FAR DO YOU HAVE TO, HOW FAR VERSUS THE PLANT HAVE TO GO VERSUS, UM, HOW FAR SHOULD, YOU KNOW, ERCOT HAVE TO GO TO IMPLEMENT THESE OTHER SOLUTIONS IN THOSE PLACES WHERE WE IDENTIFY A RELIABILITY PROBLEM? OKAY, I THINK I HAVE TWO QUICK FOLLOW UPS THERE.
SO THIS HAS BEEN ASKED A BUNCH OF TIMES, BUT DO WE HAVE A QUANTIFICATION OF HOW MANY MEGAWATTS WHERE WE'RE THINKING WE NEED THAT? YOU KNOW, I DON'T KNOW IF, I THINK IT'S AN EXEMPTION, BUT THE, THE, WHAT WE'RE CALLING AN EXEMPTION, UM, DO, DO WE KNOW, ESPECIALLY NOW THAT WE HAVE A 500 THRESHOLD SOMEWHERE ELSE, LIKE DO, DO WE KNOW HOW MANY MEGAWATTS ARE OR GIGAWATTS THERE? UM, AND THEN I, I GUESS THE THRESHOLD IS, TO ME, MAXIMUM CAPABILITIES MEANS, YOU KNOW, MAXIMUM WHAT THE PLANT'S CAPABLE OF.
SO IS THERE AN EXAMPLE FROM ERCOT OF WHAT KIND OF HARDWARE YOU'D BE TALKING ABOUT THAT THAT GOT THE CAPABILITY HIGHER WITHOUT REPLACING THE RESOURCE TO ME, WHICH IS NOT MAXIMIZING CAPABILITIES, BUT IT, IT IS SOMETHING ELSE.
IT'S KIND OF EXCHANGING THE RESOURCE FOR SOMETHING ELSE.
AND I, I SEE ERIC IN THE QUEUE TOO, AND, UM, SO SORRY BLAKE, I KIND OF INTERRUPTED YOUR QUESTIONING.
SO I'LL, I'LL GO BACK TO WOODY AND TO, TO BLAKE AND TO ERIC.
SO I GUESS I, I NEED JOHN TO HELP ME.
JOHN, YOU WOULDN'T BE THE FIRST ONE TO CONFUSE US
SO CAITLYN, IF YOU, IF YOU'RE WAITING ON ME, THIS IS BLAKE, I'D, I'D BE HAPPY TO HEAR FROM ERIC ON THOUGHTS OF, OF SPLITTING THE ISSUE UP.
I THINK WE WERE SEEING IF JOHN HAD SOME ANSWERS TO YOUR QUESTIONS IN MIND, AND THEN, UM, IF HE DOESN'T KNOW, WE CAN GO TO ERIC.
JOHN, DID YOU WANNA WEIGH IN ON ANYTHING? YEAH, WELL, I, I THINK YOUR, I JUST TOUCH A LITTLE BIT.
I THINK YOUR QUESTION WAS KIND OF WHAT UPGRADES BEYOND SOFTWARE WOULD BE THOUGHT OF.
IS THAT ESSENTIALLY YOUR QUESTION? I THINK SO, BECAUSE TO ME, RIGHT, MAXIMUM CAPABILITIES MEANS WHAT IS THE RESOURCE CAPABLE OF? SO I, I THINK, AND I THINK WE'VE, WE TRIED TO LIST, THAT'S AN EXAMPLE OF SOMETHING THAT
THAT'S WHAT WE'VE TRIED TO LIST IN THAT ITEM, IN THAT PARAGRAPH BI MEAN, ON TOP OF THE SOFTWARE FIRMWARE, I MEAN, THERE ARE, AND I THINK WE'VE HEARD FROM OEMS, YOU KNOW, THEY WILL HAVE CERTAIN CONTROLLER CARDS OR UPGRADE KITS THAT
[01:50:01]
CAN BE, YOU KNOW, UM, PLUGGED IN OR, OR, YOU KNOW, I THINK IN, IN COMMUNICATION UPGRADES CAN POTENTIALLY, YOU KNOW, ELIMINATE DELAYS AND, AND YOU KNOW, THINGS LIKE THAT.I THINK THESE ARE THE KINDS OF THINGS THAT WE'VE, YOU KNOW, IN OUR INTERACTIONS WITH OEMS HAVE, YOU KNOW, HEARD OF THAT THAT COULD POTENTIALLY, YOU KNOW, CAPABILITIES WITHOUT DOING WHOLESALE REPLACEMENTS.
SO I THINK ALL THOSE ITEMS UNDER THE PARAGRAPH B ARE WHAT WE'VE IDENTIFIED SO FAR.
SO WE AREN'T, AND, AND THE QUESTION AND EXAMPLES BOB HALTON HAD EARLIER, WE, WE WOULDN'T BE TALKING ABOUT A REPLACEMENT OF AN INVERTER OR ANYTHING LIKE THAT.
AND, AND I WOULD JUST, I THINK THAT'S WHAT PARAGRAPH C IS ABOUT, IS KIND OF, IF, I THINK THE EXPECTATION IS KIND OF THE B THE ITEMS IN B ARE, ARE KIND OF THE BEYOND SOFTWARE CHANGES THAT WE THINK WOULD LIKELY BE TECHNICALLY FEASIBLE.
I THINK IN TERMS OF THIS, THE C IS WHERE YOU PUT THAT COST THRESHOLD, YOU KNOW, WHATEVER THAT PERCENTAGE OF FULL REPLACEMENT COST COULD BE.
YOU KNOW, ARE THERE, ARE THERE OTHER THINGS THAT COULD MEET THAT KIND OF PRICE THRESHOLD? IS, IS KIND OF, WAS KIND OF THE INTENT OR THE THOUGHT BEHIND THAT.
UM, ERIC, DID YOU WANT TO TRY TO RESPOND QUICKLY TO BLAKE'S QUESTION AND THEN WE'LL GO BACK TO THE QUEUE? UH, I'D BE HAPPY TO.
UM, I, UM, I THINK THE SUGGESTION AROUND, YOU KNOW, FOCUSING ON WHAT WE DO AGREE ABOUT IS HELPFUL.
UM, YOU KNOW, THIS CONVERSATION IS EVIDENT THAT, UM, YOU KNOW, ER RCAT IS, UH, NOT SATISFIED WITH THE PAST TAX PROPOSAL AND, YOU KNOW, THERE ARE SIGNIFICANT CHANGES TO, TO TALK THROUGH IN ORDER TO POTENTIALLY GET THEM SATISFIED THAT, YOU KNOW, MAKE THE JCS UNCOMFORTABLE.
I THINK THE WAY DAN SAID IT EARLIER IS, UM, WHAT, WHAT DO YOU GET FROM THE EXTRA RELIABILITY, UM, UPGRADE OR, YOU KNOW, YOU KNOW, INCREASE IN CAPABILITIES UPGRADE, UM, IS IS KIND OF AN, AN UNKNOWN AT THIS POINT.
AND, UH, THAT'S THE QUESTION WE'VE BEEN TRYING TO ASK FOR A WHILE, IS TO DEFINE THE LEVEL OF REMAINING RISK THAT WE, WE DON'T THINK WE SEE A GOOD ANSWER TO.
SO I, I THINK IT'S A PRODUCTIVE, UH, RECOMMENDATION AND I APPRECIATE IT.
HI CALIN, CAN YOU HEAR ME? YES.
UH, JUST WANTED TO ADD, I AGREED WITH BLAKE, UH, IN HIS QUESTION.
I, I HAVE, UH, OBVIOUSLY BEEN PAYING CLOSE ATTENTION TO THIS DISCUSSION, UH, OUR CUTS, RELIABILITY CONCERNS, YOU KNOW, WERE VERY STRONG AND, AND SO OBVIOUSLY, UH, WE DO NOT WANNA SEE ANY, ANYTHING HAPPEN TO THE GRID LIKE THEY, LIKE THEY SAID COULD HAPPEN.
AND SO, BUT I HAVE TO SAY, WHEN I'VE, WHEN I'VE HEARD, UH, THE LAST COUPLE OF WORKSHOPS AND TODAY IT SOUNDS LIKE MOVING, YOU KNOW, THESE REQUIREMENTS UP TO MAXIMUM AND, AND DOING SOME OF THESE OTHER THINGS THAT, THAT THERE'LL STILL BE SOME SUBSET OF EQUIPMENT THAT WOULD BE OLD AND VINTAGE THAT NEEDS TO BE UPDATED.
BUT I, I CAN'T GET A TRUE SENSE OF THE MAGNITUDE.
AND I'M JUST WONDERING FROM ERCOT, IF, IF WE WERE TO PULL THAT PIECE OUT, THIS, THIS, THIS PIECE WE'RE TALKING ABOUT AND WE JUST APPROVE THE PART OF THE NPR ABOUT THE MAXIMUM AND SOME OF THESE OTHER THINGS WE AGREE ON, AND WE PULL THAT INTO A DIFFERENT NPR AND WE TRY TO FIGURE OUT, YOU KNOW, JUST HOW TO ADDRESS THAT.
I, I'M, I'M WONDERING DOES THAT, DOES THAT LEAVE A SMALL ENOUGH PIECE OR ARE THERE STILL LOCAL ISSUES? BECAUSE I HEARD SOMEONE SAY SOMETHING ABOUT, YOU KNOW, LOCAL RELIABILITY ISSUES COULD STILL BE THERE.
SO I'M JUST TRYING TO UNDERSTAND IF WE WENT FORWARD WITH WHAT WE AGREE ON AND PULL OUT SOME OF THESE THINGS THAT, THAT WE, WE GET BOGGED DOWN ON.
YOU KNOW, COULD WE, COULD WE DO THAT AND STILL HAVE, UH, THE RELIABILITY THAT WE NEED? I THIS, COLIN, I'M TAKING OVER FOR KAITLYN FOR A FEW MINUTES.
NAN, WOULD YOU LIKE TO RESPOND TO THAT? YEAH, SO I, I I THINK IT DEPENDS.
[01:55:01]
I I, I'M GONNA GET MYSELF IN TROUBLE HERE BECAUSE I DON'T HAVE THOSE NUMBERS IN FRONT OF ME, LIKE HE IS HEADED OFF THE TOP OF HIS HEAD, BUT, UM, HE'S UNAVAILABLE TODAY IN CASE YOU HAVEN'T FIGURED THAT OUT.BUT, UM, THE, UM, YOU KNOW, IT WAS IN THE, UH, FOUR DIGIT THOUSANDS OF, UM, UH, MEGAWATTS.
I THINK THAT BASED ON THE OEM INFORMATION, NOW THERE MAY BE THAT, THAT, THAT ARE AT RISK.
SO IT, IT'S, IT'S, UM, BIGGER THAN A BREAD BOX.
I MEAN, IT'S, IT'S ENOUGH THAT IF, UH, EVEN IF, SO THAT'S THAT, MAKE SURE I'M CLEAR ON WHAT QUESTION I'M ANSWERING THAT, UM, IF, IF WE JUST DID THE SOFTWARE AND FIRMWARE AND, AND, UH, THOSE KIND OF UPGRADES, THERE'D BE, YOU KNOW, AND I DON'T REMEMBER EXACTLY WHAT THE NUMBER WAS, BUT, BUT I THINK IT WAS IN THE FOUR DIGIT, UH, RANGE.
SO IT'S BIG ENOUGH THAT IF A SINGLE FAULT CAUSED, YOU KNOW, A LOT OF THOSE TO TRIP OFF, IT WOULD BE SIGNIFICANTLY MORE THAN E-M-S-S-C IF, IF THEY WERE AT, AT HIGH OUTPUT.
AND SO THAT'S, THAT'S, YOU KNOW, THE EXACT NUMBER DOESN'T MATTER IF IT'S GONNA CAUSE A PROBLEM.
UM, AND SO, YOU KNOW, THAT, THAT, THAT'S WHERE WE WOULD HAVE TO DO THE, UH, TO ANSWER THAT QUESTION.
WE, IF WE GO THROUGH THE PROCESS OF GETTING, UH, EXCEPTIONS, UH, REQUESTED, SET, SET THE REQUIREMENTS, FINISH THIS OUT, GET THE EXCEPTIONS REQUESTED, THEN WE KNOW WHERE THE ONE THE UNITS ARE THAT HAVE THE PROBLEMS THAT IF THEY MAXIMIZE USING SOFTWARE AND THOSE KIND OF THINGS, THAT'S NOT ENOUGH BECAUSE THERE'S A RELIABILITY PROBLEM IN, IN A, UH, FOR A BROAD ENOUGH SET OF UNITS THAT IT WOULD CAUSE A PROBLEM.
THEN WE DECIDE, OKAY, IS THE COST OF FIXING THOSE UNITS THROUGH THE SET OF UPGRADES THAT ARE IN, IN B THERE OR OTHER THINGS THAT MAYBE WE DON'T KNOW ABOUT THAT DON'T MAKE THAT ARE UNDER THE COST CRITERIA.
THEN, YOU KNOW, IF IF THEY'RE COST EFFECTIVE THEN AND THEY SOLVE THE RELIABILITY PROBLEM, THEN WE DO THEM, UM, OR WOULD WOULD REQUIRE THEM, OR WE HAVE TO, YOU KNOW, PUT IN OTHER MITIGATIONS IF THEY'RE NOT COST EFFECTIVE.
UM, IT SEEMS LIKE THAT'S THE, I'M NOT SURE I'M ANSWERING YOUR QUESTION, BUT IT SEEMS LIKE THAT'S THE WHERE WE'RE AT.
SOMEHOW WE'VE GOTTA SOLVE THE PROBLEM AND, AND, AND THAT'S HELPFUL.
I, I GUESS I, I RECOGNIZE THERE STILL COULD BE A PROBLEM.
I'M JUST WONDERING IF, IF WE BIFURCATE THAT AND PULL IT INTO A SEPARATE PROCEEDING AND TAKE, YOU KNOW, SIX MONTHS OR WHATEVER TO ADDRESS THAT PART, YOU STILL ADDRESS IT.
UM, BUT YOU, BUT YOU GET SOME, SOME MOVEMENT ON THE, ON THE BIGGER PART, AND I JUST WONDERED IF ERCOT HAD CONCERNS WITH THAT APPROACH, IF THAT'S STILL GONNA ADVERSELY AFFECT RELIABILITY OR IS THAT SOMETHING THAT Y'ALL WOULD SUPPORT? YEAH, THE, THE, I I GUESS WHAT I WAS TRYING TO SAY IS THAT THE PROBLEM IS WE DON'T KNOW.
WHAT WE'VE TRIED TO DO IS PUT IN HERE THE PROCESS FOR HOW WE WOULD GET TO KNOWLEDGE.
WE COLLECTIVELY GET TO KNOWLEDGE ON THAT AND THEN ONLY REQUIRE GOING TO THAT NEXT STEP IN PLACES WHERE THERE IS A RELIABILITY PROBLEM AND IT'S COST EFFECTIVE TO, TO GO FURTHER TO FIX IT.
AND SO THAT'S KIND OF WHAT'S BAKED INTO THIS LANGUAGE AS IT EXISTS RIGHT NOW.
SO IT, IT IS NOT BIFURCATING IT AND PUTTING IT OFF THE LATER IT'S, IT'S, OR IT'S NOT BIFURCATING IT AND PUTTING IT OFF THE LATER, IT'S PUTTING IT IN THE PROCESS THAT RATIONALLY, UH, ALLOWS YOU TO, TO, TO ASK THAT QUESTION AND THEN SOLVE IT IF NECESSARY.
I, I THINK I AM, I'M HEARING WHAT SOUNDS LIKE TO ME A LOGICAL PATH FROM TODAY'S DISCUSSION, WHICH IS TO, YOU KNOW, DECOUPLE AND FOCUS ON THE, THE MAXIMIZATION OF, YOU KNOW, GETTING TO AGREEMENT ON WHAT MAXIMIZATION MEANS, SETTING THE, THE DATE, UM, WITH, YOU KNOW, FOR THAT CUTOFF AND TRYING TO MOVE THAT FORWARD, UH, YOU KNOW, TRY TO GET THAT TO BACK TO THE ERCOT BOARD THIS MONTH OR NEXT MONTH, THIS MONTH, YOU KNOW, AS OF TOMORROW.
UM, AND, AND, YOU KNOW, I DON'T THINK WE'RE GONNA SOLVE THE, IT, IT SOUNDS LIKE WE'RE NOT GOING TO SOLVE THE, HOLD ON, BUDDY.
IT SOUNDS LIKE WE'RE NOT GONNA SOLVE THE, UM, YOU KNOW, THE, THE HARDWARE
[02:00:01]
UPDATE ISSUE IN IN THE NEXT WEEK, BUT WE CAN AT LEAST GET THE BALL MOVING AND TO THE COMMENT ABOUT, YOU KNOW, HOW LONG IT'LL TAKE TO GET MODELS UPDATED IN ORDER TO HAVE, YOU KNOW, GIVE OUR CO THE, ALL THE TOOLS THEY NEED TO BE ABLE TO, TO EVALUATE, UM, YOU KNOW, OUTSTANDING RELIABILITY RISK.WE GET THE BALL MOVING ON THAT AND, UM, YOU KNOW, TRY TO COMMIT TO, TO HAVING SOME EXPEDITIOUS RESOLUTION OF THE, THE, THE MORE COSTLY UPGRADE REQUIREMENTS.
UM, BUT IT, IT, THAT SOUNDS LIKE A REASONABLE PATH FORWARD TO ME.
UH, STILL IN THE SAME SUBJECT ON, ON C UH, AND THIS WAS SOMETHING DAN THAT YOU SAID IN THE LAST WORKSHOP, AND I'M SEEING, WANT TO CHECK TO SEE HOW THIS PLAYS WITH OUR EARLIER CONVERSATION IS, YOU KNOW, YOU'RE LOOKING AT THIS FROM A PLANT LEVEL, NOT NECESSARILY AN INDIVIDUAL INVERTER BASIS.
I'M NOT TRYING TO DO IT BACK AND FORTH.
SO WHEN WE LOOK AT THAT, AND GOING BACK TO THE EXAMPLE WE SAID, IF YOU'VE GOT, YOU KNOW, FOUR INVERTERS OR 10 INVERTERS, WHATEVER THAT IS, DO YOU MULTIPLY THAT, SAY IT ENDS, ENDS UP BEING $500,000.
I'M JUST THROWING OUT SOME, SOME, SOME STUFF OUT THERE.
NOW, THE LIMITING FACTOR THOUGH IS, IS SAY, AND I THINK YOU SAID THIS IN THE LAST WORKSHOP, YOU KNOW, A HIGH IMPEDANCE, UH, UH, TRANSFORMER, SO DOES THIS PUT UP THAT TO WHERE IF THAT PIECE OF EQUIPMENT, THAT TRANSFORMER IS $400,000, YOU WOULD NEED TO MAKE THAT UPGRADE.
SEE, SEE WHERE I'M GOING? BECAUSE IT'S, IT'S, THIS IS C IS SET ON PER, OR, YOU KNOW, PER INVERTER, PER TURBINE, BUT THERE'S OTHER PIECES OF EQUIPMENT OUT THERE THAT MAY BE LIMITING.
SO DOES THAT MAKE ANY SENSE? NO, IT, IT DOES.
AND IN FACT, THIS PARAGRAPH MADE A LOT OF SENSE TO ME, THOUGH.
YOU STARTED ASKING QUESTIONS TODAY AND NOW I'M, UM, DOUBTING MY, UM, PREVIOUS, I, I'M HAVING TROUBLE GETTING BACK TO MY PREVIOUS UNDERSTANDING OF IT.
I JUST WANTED TO THROW THAT OUT THERE FIRST TO THINK ABOUT.
UH, I'VE GOT A QUESTION, UM, WHERE MY NOTES.
SO FOR DAN OR FOR, FOR JOHN SCH SMALL, JUST THINKING THROUGH THIS NOW, I'M UP ON PARAGRAPH A AND THIS TIES BACK IN WITH EVERYTHING THAT WE'VE BEEN TALKING ABOUT HERE IN THE LAST COUPLE OF MINUTES.
UM, ON THE LOSS OF GENERATION CAPACITY, AND THIS TIES BACK TO THE FREQUENCY AND VOLTAGE RIDE THROUGH OR THE LEGACY, YOU KNOW, TYPE REQUIREMENTS.
AND IN MY MIND THOSE ARE TWO DIFFERENT THINGS.
YOU KNOW, FREQUENCY IS A, YOU KNOW, SYSTEM WIDE TYPE PARAMETER THAT'S SEEN BY EVERY, BY ALL BY ALL UNITS.
AND VOLTAGE IS MORE OF A, A, A LOCAL OR REGIONAL CONCERN.
UM, SO QUESTION IS ON A TWO, WOULD IT MAKE SENSE TO HAVE A DIFFERENT THRESHOLD OR PARAMETER BASED ON THE VOLTAGE AND FREQUENCY CONCERNS? GO AHEAD, JOHN.
YEAH, I MIGHT NEED A CLARIFICATION ON WHAT, SO YOU WANT A DIFFERENT THRESHOLD FOR IF IT'S A FREQUENCY EVENT VERSUS A VOLTAGE EVENT? I'M JUST QUESTIONING IT.
DOES IT, DOES IT MAKE SENSE TO HAVE A DIFFERENT THRESHOLD GIVEN THAT VOLTAGE IS MUCH MORE LOCAL TYPE EVENT AS OPPOSED TO FREQUENCY, WHICH IS SYSTEM WIDE? YEAH, I'LL, I, I DON'T KNOW THAT I HAVE AN ANSWER FOR THAT OTHER THAN TO SAY, I MEAN, I, I THINK WE CAN LOOK AT THE EXAMPLES OF, YOU KNOW, YOU SAY VOLTAGE IS A LOCAL EVENT IN ODESSA, THERE WERE VOLTAGE IMPACTS THAT WERE FAIRLY WIDESPREAD.
SO I THINK THAT'S THE, I THINK ONE OF THE CHALLENGES OF, OF, OF, OF THE CONTROLS IN, IN, IN I VS.
AND THAT THAT THAT THE EXTENT, YOU KNOW, GOING INTO A VOLTAGE CONTROL MODE OR A VOLTAGE RIGHT THROUGH MODE ISN'T NECESSARILY, YOU KNOW, A DEEP VOLTAGE OR YOU KNOW, NECESSARILY A VAULT, BUT YOU KNOW, SOMETHING THAT WENT TO 0.8 PER UNIT, YOU KNOW, A HUNDRED MILES AWAY FROM THE, UH, FROM THE ACTUAL DISTURBANCE WENT INTO VOLTAGE RIGHT THROUGH MODE.
SO I DON'T KNOW TO THAT EXTENT, I, YOU KNOW, AND I, FROM A NERC PERSPECTIVE,
[02:05:01]
I DON'T THINK THEY HAVE ANY DISTINCTION.AN EVENT AS AN EVENT, AND IF YOU LOSE X MEGAWATTS IT DOESN'T REALLY MATTER WHAT WAS THE CAUSE OF THAT EVENT.
I, I THINK THAT IT MAKES SENSE, BUT IT KIND OF GETS TO KIND OF PART OF THE CORE SENSITIVITY ON HOW THAT RELIABILITY ASSESSMENT IS DONE AND, AND WHAT CASES ARE LOOKED AT AND HOW IT'S, HOW IT'S MEASURED.
THERE MIGHT BE SOMETHING TO LOOK AT THERE.
YOU MUTED IF YOU'RE TALKING, SORRY ABOUT THAT.
ON THIS, UH, LOSS OF GENERATION CAPACITY, IS IT THE 500 MEGAWATT AMOUNT THAT'S IMPORTANT OR IS IT THE MULTIPLE RESOURCES? YEAH, I'LL TRY THAT.
I MEAN, I THINK IT WAS, I THINK THE AMOUNT IS, IS THE IMPORTANT VALUE.
UM, I THINK THE KIND OF THE QUESTION CAME UP, I THINK THIS CAME OUT FROM THE LAST TECH MEETING OF, YOU KNOW, IF I HAVE A SINGLE UNIT, I MEAN GENERALLY, YOU KNOW, A SINGLE UNIT IS PART OF MOST, YOU KNOW, PLANNING AND, AND OPERATIONAL ASSESSMENTS ANYWAYS.
SO IF I, IF I, IF I HAVE A SINGLE UNIT THAT'S GREATER THAN 500, THAT SHOULD BE NORMALLY STUDIED AS PART OF THE CONTINGENCY ANALYSIS, BUT YOU DON'T NECESSARILY WILL, YOU DON'T NECESSARILY STUDY MULTIPLE UNITS THAT AGGREGATE TO 500.
SO I THINK THAT WAS THE ONLY THING THAT WE REALLY, I THINK IT CAME OUT OF A QUESTION FROM THE LAST TECH MEETING AND WE ADDED THAT THE IDEA OF THAT 500 MEGAWATT THRESHOLD SHOULD HAVE, YOU KNOW, MULTIPLE, YOU KNOW, IT SHOULD BE INFECTING MULTIPLE RESOURCES AND NOT JUST A SINGLE RESOURCE.
YEAH, I'M JUST THINKING, YOU KNOW, IF A 500 MEGAWATT UNIT IS THAT REPORTABLE TO NERC JUST ONE UNIT VERSUS THE MULTIPLE? THAT'S WHAT I'M TRYING TO GET DOWN TO.
YEAH, YOU'RE GETTING A BIT OUT OF MY EXPERTISE 'CAUSE I'M NOT RESPONSIBLE FOR THE NERC REPORTING, BUT I BELIEVE IT PROBABLY IS.
BUT AGAIN, I THINK NORMALLY AS A SINGLE UNIT THAT'S ALSO PART OF, YOU KNOW, MERCK CONTINGENCY REQUIREMENTS TO, YOU KNOW, EVALUATE SYSTEMS BASED ON THE LOSS OF A SINGLE UNIT.
ONE OTHER SUGGESTION, JOHN AND DAN, UM, BEEN FIELDING A LOT OF QUESTIONS ABOUT MODELS SINCE THE LAST TECH MEETING, AND I'M JUST WONDERING IF YOU GUYS HAVE CONSIDERED HAVING A SEPARATE WORKSHOP JUST AROUND MODELS AND KIND OF GO OVER WHAT'S EXPECTED, KIND OF THE TIMEFRAME.
I KNOW WE JUST HAD PICKER 1 0 9 GO INTO EFFECT, BUT I THINK IT MIGHT BE GOOD TO HELP PROVIDE A LITTLE BIT MORE BACKGROUND OF WHAT THE EXPECTATIONS ARE, WHAT THE MODELS ARE AND SO ON.
AND THEN I THINK THERE'S A LOT OF CONCERN ABOUT, AGAIN, THE QUALIFICATION PROCESS OF THAT, BUT THAT'S JUST A COMMENT I'VE GOT.
YEAH, SO I, I WANTED TO GO BACK TO THE QUESTION ABOUT BIFURCATING.
THE, UM, UM, KIND OF THE GOING AHEAD AND PUTTING IN THE REQUIREMENTS NOW FOR, UM, JUST DOING THE SOFTWARE AND, AND SO FORTH UPGRADES, UM, AND PUTTING OFF GOING BEYOND THAT TILL LATER.
I GUESS WHAT HAPPENS IF A UNIT MAXIMIZES AND THEY CAN'T GET TO THE REQUIREMENT FOR THEIR, UM, THEIR VINTAGE OF UNITS.
SO THEY'RE, IT'S A 2022 VINTAGE UNIT AND THEY CAN'T MEET THE, THE LEGACY REQUIREMENTS.
UM, HOW, UM, WHAT, YOU KNOW, HOW, HOW WOULD THOSE BE TREATED IN THE INTERIM PERIOD? I MEAN, I THINK THAT'S THE, THAT'S THE QUESTION THAT, THAT WE, THAT THAT, AND WHY WE'VE BEEN TRYING TO KEEP THIS AS KIND OF A COMPREHENSIVE PACKAGE BECAUSE ESSENTIALLY IT'S, IT'S, IT, IT BECOMES A COMPLIANCE PROBLEM OR WHAT YOU MEAN EFFECTIVELY WHAT YOU'VE DONE.
IF YOU SAY, WELL, IT'S NOT A COMPLIANCE PROBLEM, THEN, UM, UM, HOW DO WE, UM, HOW DO WE, UM, YOU KNOW, EFFECTIVELY WHAT YOU'VE DONE IS, IS GRANTED ALL EXCEPTIONS WITHOUT ANY CRITERIA, I GUESS, UM, IS, IS EFFECTIVELY WHAT'S HAPPENED.
SO I GUESS, I GUESS THAT'S A QUESTION FOR NED, UH, OR WHOEVER ASKED THAT SUGGESTED THAT IS WHAT HAPPENS TO THOSE, BECAUSE I'M TRYING TO UNDERSTAND IT.
[02:10:01]
A CRACK AT IT? YOU WANT ME TO GO TO ERIC? SO, DAN, IF I'M UNDERSTANDING THE, THE, THE QUESTION IS, YOU KNOW, THERE'S STILL GONNA BE, THERE'S STILL GONNA BE SOME THAT ARE, ARE STRUGGLING TO, TO MEET THE, THE LEGACY REQUIREMENTS.UM, I, I DON'T HAVE, I DON'T HAVE A A A, A CANNED ANSWER FOR YOU.
MY, YOU KNOW, WE COULD TRY, YOU KNOW, WE COULD TRY TO RESOLVE IT ON, ON AN EXPEDITED BASIS AND, AND, UM, OR JUST, YOU KNOW, LEAVE THE, AND AT THIS POINT JUST LEAVE IT TO, YOU KNOW, MAXIMIZING WITHIN THEIR CAPABILITIES, UM, EVEN IF IT'S NOT TO THAT LEVEL WITH AN UNDERSTANDING THAT THERE MAY BE SOME REVISION TO THAT.
UM, I, I, I'D LOVE TO HEAR OTHERS' THOUGHTS.
UM, WELL, IF I CAN JUMP IN OUTTA ORDER, 'CAUSE I, MM-HMM.
UM, I, AND I MAY BE OUTTA SYNC WITH THE WHOLE DISCUSSION HERE, BUT IF, IF YOU'RE, IT'S NOT GONNA BE A COMPLIANCE ISSUE FOR YOU, DAN, MY MIND, IF THAT'S WHAT YOU'RE WORRIED ABOUT.
BECAUSE IF THE RESOURCES DON'T GIVE YOU WHAT YOU NEED, THEN YOU'RE GONNA, UNTIL SOMETHING IS DONE, YOU'RE GONNA HAVE TO TAKE SOME KIND OF ACTION TO MITIGATE THE PROBLEM AND IT MAY BE CURTAILMENT, RIGHT? AND IF THEY CAN'T COMPLY AND YOU'VE GOTTA INSTRUCT A TRANSMISSION SOLUTION, THEN THAT KIND OF BEHAVIOR MAY HAP MAY STAY IN PLACE UNTIL SOME KIND OF TRANSMISSION SOLUTION, IF IT EXISTS, IT GETS PUT IN PLACE.
AND I'M PROBABLY MAKING AN IDIOT OUTTA MYSELF FOR NOT LISTENING TO THE WHOLE DISCUSSION THIS MORNING.
BUT YOU GOT MY ATTENTION WHEN YOU SAID COMPLIANCE ISSUE.
THANK YOU LITTLE BOB AND THEN ERIC.
UH, THIS IS JUST A, A COMMENT, I DON'T WANNA TAKE US DOWN A RABBIT TRAIL, BUT, UH, SINCE KID DONAHUE BROUGHT IT UP A LITTLE BIT AND HOW 2 45 WILL DOVETAIL IN WITH 1 0 9, UH, TO GET ALL THESE MODELS CORRECT AND EVERYTHING, UH, I, I'D LIKE TO SAY, DAN, LET, LET'S DO CONSIDER A WORKSHOP ON 1 0 9 SO THAT EVERYBODY'S GOT THE RIGHT EXPECTATIONS FOR THAT.
SO I JUST WANTED TO THROW THAT OUT THERE.
YEAH, I I WILL DEFINITELY TAKE THAT BACK THERE.
UM, SO I THINK PART OF THE ANSWER IS IT DEPENDS ON, ON WHAT WE WRITE, YOU KNOW, IF WE WERE TO WRITE THIS FOR NEXT WEEK, BUT THERE'S A FEW THINGS THAT ARE HOOKS FOR COMPLIANCE.
I THINK ONE IS, UM, YOU KNOW, IF THEY, IF THEY FAILED ON ANY EVENT IN THE PAST, THEY'RE GOING CONTINUE TO GO THROUGH THE COMPLIANCE EFFORTS RELATED TO THAT PAST EVENT.
AND, YOU KNOW, I THINK IT'S COMMON KNOWLEDGE THAT THERE'S SOME ENFORCEMENT ACTIVITY THAT'S ONGOING FOR PAST EVENTS.
TWO IS THERE WILL BE A NEW REQUIREMENT TO MAXIMIZE BY THIS CERTAIN DATE.
UM, AND, UM, ERCOT WILL RECEIVE ALL THE MAXIMIZATION IN THAT SAME TIMEFRAME.
SO IF SOMEONE DOESN'T DO IT, IT'S, IT'S OBVIOUS THAT THEY DIDN'T DO IT.
AND IF, YOU KNOW, THERE'S ONE, UM, OPERATOR OF EQUIPMENT THAT SAYS THEY CAN'T MAXIMIZE, BUT THREE OTHER OPERATORS THAT SAME EQUIPMENT DO MAXIMIZE, THEN MAYBE THERE'S A COMPLIANCE ISSUE THERE TOO.
AND THEN, UH, THREE IS THIS REQUIREMENT TO UPDATE THE MODELS, UM, THAT WOULD COME ALONG WITH THAT MAXIMIZATION, WHICH IS ALSO A, A COMPLIANCE HOOK.
UM, AND THEN I THINK I AGREE WITH NED THAT, YOU KNOW, WE CAN TRY TO EXPEDITE THIS BECAUSE WE MIGHT BE RELATIVELY CLOSE TO, YOU KNOW, SOMETHING TO DO ABOUT THIS POTENTIALLY, UM, BUT JUST NOT NECESSARILY WITHIN A WEEK'S TIMEFRAME.
AND SO LET'S JUST CHECK THE BOXES FOR THINGS WE CAN DO AND KEEP TALKING, UM, YOU KNOW, TO TRY TO GET TO AGREEMENT.
'CAUSE THE ALTERNATIVE, YOU KNOW, I I DON'T THINK IT'S HELPFUL TO TRY TO FORCE SOMETHING THROUGH ONE WAY OR THE OTHER.
[02:15:11]
OKAY.UH, JASON COX, UM, DAN, YOU'VE MENTIONED SEVERAL TIMES, SOME RELATIVELY LATE VINTAGE GIA UNITS THAT MAY NOT BE COMPLIANT WITH THE LEGACY REQUIREMENTS.
IS ARE THOSE HYPOTHETICALS OR ARE THOSE ACTUALS? 'CAUSE MY UNDERSTANDING WAS MOST OF THE LATEST VINTAGE EQUIPMENT COULD MEET OR EXCEED THE LEGACY REQUIREMENTS, YOU KNOW, WITH NOTHING MORE THAN THAN SOFTWARE FIRMWARE AND POTENTIALLY EVEN GET UP TO THE 2,800 OR CLOSE TO 2,800 WITH JUST SOFTWARE AND FIRMWARE.
I I WAS JUST SAYING IT, IT, THERE IS A DATE THAT, YOU KNOW, YOU'RE NOT REQUIRED IF WHAT, WHAT WE REALLY HADN'T SETTLED ON THE DATE YET, BUT IF IT, IF YOU'RE FAIRLY CLOSE TO THE DATE AND YOU CAN'T MEET IT, THERE WOULD STILL NOT BE ANY REQUIREMENT TO DO SO.
AND I THINK JOHN'S GOT A COMMENT THERE THAT HE CAN CLARIFY.
YEAH, AND IT'S KIND OF, AND IT MIGHT BE KIND GOING BACK TO ERIC'S STATEMENT AND YOU KNOW, I THINK I WOULD JUST LIKE TO STATE ONE THING KIND OF AROUND THIS MAXIMIZATION REQUIREMENT, AND I THINK IT WAS IN THE, YOU KNOW, THE DRUNK COMMANDERS SLIDE.
THERE'S A LOT OF WIGGLE ROOM AND YOU KNOW, I PERSONALLY, UM, YOU KNOW, I THINK IT'S MORE OF AN ASPIRATIONAL THING AS OPPOSED TO SOMETHING THAT'S REALLY ENFORCEABLE BECAUSE AT THE END OF THE DAY, YOU KNOW, IT IT, OR IT KIND OF SUGGESTED, WELL IF THERE'S THREE, YOU KNOW, PLANTS THAT ALL HAVE SIMILAR VINTAGE, YOU KNOW, AND TWO OF THEM HAVE HIGHER CAPABILITIES AND ONE DOESN'T, I THINK THERE'S ALL KINDS OF REASONS WHY THAT COULD BE VALID.
AND I DON'T THINK THAT GROUT IS GOING TO BE CHASING DOWN EVERY LAST, YOU KNOW, DID YOU SQUEEZE EVERY LAST, YOU KNOW, BIT OF CAPABILITY OUT OF THIS RESOURCE BASED ON, YOU KNOW, CONTROL, YOU KNOW, DIFFERENT CONTROL STRATEGIES AND CONTROL PARAMETERIZATIONS AND DIFFERENT EQUIPMENTS AND COLLECTOR SYSTEM EQUIPMENT.
AND I MEAN, I THINK THERE'S ALL KINDS OF DIFFERENT IMPACTS THAT, YOU KNOW, THAT CAN IMPACT WHAT THAT MAXIMIZATION LEVEL ACTUALLY IS.
AND AT THE END OF THE DAY, YOU KNOW, I THINK AS A PRACTICAL MATTER, WHEN A RESOURCE SAYS, THIS IS MY MAXIMIZED CAPABILITY, AND I DON'T KNOW IF THERE NEEDS TO BE SOME ATTESTATION TO THAT OR SOMETHING, I DON'T THINK THAT THERE'S GONNA BE ANY, ANYTHING THAT, THAT ERCOT CAN REALLY ENFORCE OTHER THAN SAY, OKAY, YOU'VE MAXIMIZED IT AND DOES YOUR MODEL REFLECT THAT? AND THAT'S ABOUT THE EXTENT OF IT.
SO I THINK, YOU KNOW, AND IT KIND OF COMES TO THE, I I, I THINK THE LAST QUESTION KIND OF ON, I THINK THERE'S BEEN A EXPECTATION THAT, YOU KNOW, IF WE JUST GO TO THIS MAXIMIZATION, WE'RE GOOD AND WE DON'T, YOU KNOW, WE CAN PUSH OUT, YOU KNOW, THE IEE 2,800 DATE.
AND I, I'M A LITTLE CONCERNED IN THAT THERE'S, I GUESS I, I DON'T THINK IT NECESSARILY ENSURES OR GUARANTEES THAT WE GET ANY MORE CAPABILITY IN A, IN A PERFECT WORLD.
AND IF, YOU KNOW, MAYBE IT WOULD AND, AND IF EVERYONE WAS JUST ALTRUISTIC AND, AND, AND, AND, AND IN MAXIMIZING THAT, THAT KIND OF CAPABILITY.
BUT AT THE END OF THE DAY, FROM AN ENFORCEABILITY PERSPECTIVE, IF SOMEBODY SAYS, YOU KNOW, EVEN THOUGH, YOU KNOW, THERE'S BEEN THIS ASSERTION THAT, YOU KNOW, PUSHING THAT DATA OUT FOR THE, FOR THE, FROM 2020 TO 24, YOU KNOW, A LOT OF IT, A LOT OF, AND THE VAST MAJORITY OF THE, YOU KNOW, SOLAR AND BATTERY RESOURCES CAN ALREADY MEET 2,800.
I GUESS IT DOESN'T MAKE A WHOLE LOT OF SENSE TO ME WHY NOT JUST ENFORCE THE REQUIREMENT AT A HIGHER BAR AND, YOU KNOW, WE HAVE THAT EXCEPTION PROCESS FOR THE FEW INSTEAD OF PUSHING EVERYTHING BACK OUT SAYING MAXIMIZE, WHICH MAY OR MAY NOT ACTUALLY GIVE YOU THAT CAPABILITY.
AND, YOU KNOW, I THINK THAT'S JUST, I THINK SOMETHING FOR TECH MEMBERS TO CONSIDER IN, IN REALLY JUST THAT ENFORCEABILITY OF MA OF MAXIMIZATION AND DOESN'T REALLY GONNA GIVE YOU EVERYTHING THAT YOU THINK IT WOULD OR SHOULD.
I SEE NED, SO THE QUEUE IS NOT EMPTY.
SO I THINK WE CAN TALK ABOUT NEXT
[02:20:01]
STEPS, HOPEFULLY, BUT GO AHEAD.YEAH, JUST ON THE, ON THE, THE DATE COMMENT, UH, YOU KNOW, SOME OF THAT COMES DOWN TO JUST GOOD, YOU KNOW, GOOD POLICY DEVELOPMENT AND, YOU KNOW, HAVING THINGS APPLY ON A, ON A GO FORWARD BASIS AFTER THEY'RE, THEY'RE APPROVED AS OPPOSED TO, UM, TO REACHING BACK, YOU KNOW, UNDERSTANDING THAT THERE, THERE MAY BE CAPABILITIES THAT, THAT ARE CLOSER TO, UM, YOU KNOW, CLOSER TO THE NEW REQUIREMENTS ON EXISTING EQUIPMENT.
I THINK THE, THE, THE MAXIMIZATION APPROACH HELPS TO BRIDGE THAT GAP.
UM, SO THAT'S, THAT'S WHY I THINK THAT'S, THAT'S GOOD TO SUPPORT AS A, UH, YOU KNOW, GETTING, GETTING THE MOST OUT OF WHAT WE'VE GOT WITHOUT, YOU KNOW, UM, I'LL SAY VIOLATING GOOD POLICY DEVELOPMENT PRINCIPLES.
UM, I DID HAVE, IF, IF WE'RE DONE WITH THIS TOPIC OF REMOVING OFF OF IT, THERE WAS ONE THING THAT, UH, CAME TO MIND.
I, I THINK BOB HAD HAD MENTIONED, UH, YOU KNOW, THAT THE GENERAL FOCUS OF, UM, OF IEEE 2,800 AND THE, AND, AND THIS, THESE CHANGES IS TO FOCUS ON, UH, PERFORMANCE AT THE POINT OF INTERCONNECTION.
AND AS, AS OUR TEAM WAS REVIEWING THE CONSOLIDATED RED LINES, WHICH, UM, AGAIN, WERE, HAVE BEEN VERY HELPFUL IN, IN, UH, KEEP BEING ABLE TO SEE THIS IN A, IN A MUCH MORE CONSOLIDATED LIGHT.
UM, THERE WAS 1.1 PLACE IN SECTION 2.9 0.1, PARAGRAPH THREE THAT STOOD OUT TO US, AND I WANTED TO FLAG THAT FOR FOLKS, UM, WHERE IT SAYS THAT THE IEE 2,800 DASH 22 STANDARD APPLY AT THE POINT OF INTERCONNECTION BUS AND THE INDIVIDUAL IBR UNIT TERMINAL RESPECTIVELY.
AND I, I THINK THAT THE INDIVIDUAL IBR UNIT TERMINAL ADDITION THERE IS, UM, THAT, THAT MIGHT BE, UM, INCONSISTENT WITH THE, THE, THE REST OF, I THINK WHERE THIS IS, IS POINTED AT THE POINT OF INTERCONNECTION BUS.
SO WANTED TO FLAG THAT AS, AS SOMETHING THAT WE MIGHT WANT TO, UH, STRIKE OUT.
BUT FIGURED I'D RAISE IT AND SEE IF, UH, IF THAT HAD COME UP PREVIOUSLY.
I JUST MISSED THE DISCUSSION ABOUT IT.
UM, YEAH, IT'S ON THE SECOND AND THIRD LINE OF THAT, THAT PARAGRAPH.
WE HAVE THAT PULLED UP ON THE SCREEN, OR CUT.
DO YOU WANNA WEIGH IN ON THAT? YEAH, THE ONLY THING THAT I CAN SAY IS THAT I THINK THERE ARE WITHIN SECTION 2.91 AND 2.911 AND 2.912, UH, THOSE REQUIREMENTS ARE AT THE, YOU KNOW, P-O-I-V-I THINK THAT'S STATED.
I THINK THE, UH, THE ISSUE IS THAT THERE ARE COMPONENTS OF IEEE 2805, 7, AND NINE THAT IN IEEE 2,800, UH, REFER TO LIKE INDIVIDUAL UNIT, UH, TERMINALS.
AND I THINK THE EXPECTATION IS THAT THOSE WOULD BE FOLLOWED IF THEY AREN'T, UH, CONFLICTING WITH OTHER, YOU KNOW,
I THINK THAT'S THE INTENTION OF THAT IS TO MIRROR THOSE 2,800 REQUIREMENTS THAT AREN'T, UH, NECESSARILY AT THE PYB.
SO FOCUS ON FIVE, SEVEN, AND NINE.
WE'LL, WE'LL GO BACK AND LOOK AT THAT.
UM, JUST AND CONFIRM OUR, OUR UNDERSTANDING WAS THAT IT WAS ALL FOCUSED AT THE, UH, THE POIB, BUT, UM, WELL, WE'LL GO BACK AND TAKE A LOOK.
UM, BUT I AT LEAST WANTED TO MENTION IT NOW SINCE WE'RE IN THE, MAYBE THE FINAL.
YEAH, AND I, I THINK THE, THE, THE DIFFERENCE, I THINK IN A EE 2,800, THEY TALK ABOUT POM OR POINT OF MEASUREMENT.
I THINK THAT'S NECESSARILY TRANSLATABLE TO OUR POIB.
AND THEN IF THEY HAVE INDIVIDUAL, LIKE I SAY IN 2,800, THERE MAY BE CERTAIN, UH, REQUIREMENTS THAT ARE APPLICABLE AT A, AT A UNIT TERMINAL, AND THOSE WOULD BE SEPARATE, LIKE, LIKE I SAY FROM THE 2.911 OR 2.912.
WE'LL TAKE A WE'LL TAKE A CLOSER LOOK.
UM, AND IF, IF, IF THAT IS SOMETHING WE'RE, IF THAT MAKES SENSE, THEN, THEN SO BE IT.
IF, IF NOT THAT, I JUST WANTED TO FLAG IT TO SOMETHING WE MIGHT SUBMIT COMMENTS ON.
UM, MR. DONALD ROGER, WHO WAS TRYING TO GET IN THE QUEUE.
[02:25:01]
I DIDN'T KNOW IF I WAS PROPERLY FOLLOWING THE PROCEDURE TO, TO GET INTO THE QUEUE OR NOT.I, I GUESS BE, BEFORE WE JUMP ONTO THIS TOPIC HERE ABOUT THE, UH, THE INVERTER TERMINAL LOT, I DID WANNA JUST ASK A QUESTION REALLY TO THE GROUP.
I'M FROM, UH, AVAN GRID RENEWABLES, BY THE WAY.
UM, AND IT REALLY CAME BACK TO, YOU KNOW, DAN'S QUESTION BEFORE, UH, REGARDING WHAT TO DO WITH, YOU KNOW, ARE WE SORT OF PUTTING, UH, ALLOWING EXCEPTIONS TO EXIST, UM, WITHOUT ANY SORT OF CONSEQUENCES.
I THINK IT JUST, UH, YOU KNOW, IN TERMS OF THIS QUESTION OF MAXIMIZING CAPABILITY, I GUESS I'M HEARING A LOT OF DISCUSSION ABOUT, YOU KNOW, TRYING TO BRING THINGS UP TO THE, TO THE LEGACY STANDARD, WHICH I UNDERSTAND.
I GUESS FROM MY QUESTION TO THE GROUP THOUGH, IS IN, IN THIS PREVIOUS DISCUSSIONS AROUND THIS, WHEN WE TALK ABOUT MAXIMIZING, YOU KNOW, JUST GOING UP TO WHAT WE THINK THE CURRENT OR THE BEST EQUIPMENT CAPABILITY, UH, IS, SHOULD THAT NOT REFER BACK TO THE, THE STANDARDS THAT WERE IN PLACE AT THE TIME THE MACHINES WERE, WERE BUILT, OR WHEN THEIR LGI OR SGIS WERE, WERE SIGNED? I MEAN, SHOULDN'T THERE BE A DISTINCTION BETWEEN THE MACHINES THAT WERE PUT IN PLACE BEFORE THE LEGACY STANDARDS WERE, WERE DEFINED? UH, AND THE MACHINES THAT WERE PUT IN PLACE AFTER THE LEGACY STANDARDS WERE DEFINED? BECAUSE I, I UNDERSTAND DAN'S QUESTION WITH, WITH THOSE MACHINES THAT WERE PUT IN PLACE AFTER THE LEGACY STANDARDS WERE PUT IN PLACE, IF THEY'RE NOT MEETING THOSE REQUIREMENTS.
OKAY, THAT'S, THAT'S A QUESTION I THINK WE ALL NEED TO ANSWER, RIGHT? BUT REALLY SHOULDN'T, IN TERMS OF OPTIMIZING THE MACHINES, HOW COME WE DON'T DISTINGUISH BETWEEN THOSE MACHINES THAT WERE BUILT BEFORE THE LEGACY STANDARDS WERE PUT IN PLACE AND THE MACHINES THAT ARE PUT IN PLACE AFTER THE LEGACY STANDARDS? SO I GUESS THAT'S REALLY THE FIRST PART OF MY QUESTION.
I MIGHT HAVE A FOLLOW UP, BUT I WANTED TO ASK THAT FIRST.
IS THAT A QUESTION FOR ERCOT? UH, WELL MAYBE IT'S A, YEAH, I GUESS SO IT'S A QUESTION FOR THE GROUP BECAUSE MAYBE I HAVEN'T HEARD THIS.
YOU KNOW, WE, WE DON'T, I HAVEN'T HEARD ANYONE DISCUSSING THAT DISTINCTION, AND I JUST MAYBE DON'T KNOW THE HISTORY IS WHY THAT DISTINCTION IS NOT ON THE TABLE.
THE QUESTION WOULD BE IF RESOURCES BUILT BEFORE THE LEGACY DATE OR A LEGACY DATE REQUIREMENT COULD BE GRANDFATHERED TO STANDARDS FROM WHEN THEY WERE BUILT? UH, NO, NOT EXACTLY.
I GUESS JUST IN TERMS OF LIKE, FOR THE STARTING POINT OF THE DISCUSSION, SHOULD AN OPTIMIZATION, UH, IT SEEMS TO ME THAT THE FIRST STEP HERE IS MAKING SURE THE EQUIPMENTS ARE OPTIMIZED UP TO THE STANDARDS AT WHICH THEY WERE WERE BUILT, RIGHT? AND, UH, JUST SO WE'RE NOT MAKING, WE HAVEN'T MADE THAT DISTINCTION BECAUSE THERE'S, IT'S, IT'S A BIG CHANGE FOR OLDER MACHINES, RIGHT? TO REALLY BE ABLE TO MEET EVEN THOSE, THOSE LEGACY STANDARDS.
SO, MM-HMM,
I THINK THAT'S WHERE THE DEBATE ON THE EXEMPTION PROCESS HAS, HAS COME INTO PLAY.
I'LL, I'LL LET CRO WEIGH IN, UM, AND, AND THEN SEE IF THAT THAT HELPS YOU OUT.
YEAH, SO I, I THINK THAT'S THE, UM, UM, THAT'S BEEN THE, THE, THE REAL QUESTION IS ABOUT EXEMPTIONS, LIKE CAITLYN SAID, IS THAT, THAT WE HAVE EXISTING STANDARDS IN THE PROTOCOLS TODAY, EVEN BEFORE NO, 2 45 HERE.
AND, UM, WHAT, WHAT WE FOUND OUT THROUGH THE ODESSA EVENTS AND NUMEROUS SMALLER EVENTS IS THAT, UM, THE, THERE ARE A SET OF UNITS OUT THERE THAT PROBABLY AREN'T CAPABLE OF MEETING THOSE CURRENT REQUIREMENTS.
UM, AND SO THE QUESTION, AND SO WHICH WE'VE NOW ARE CALLING THE LEGACY REQUIREMENTS WITH, WITH, UH, MORE CLARIFICATION.
AND SO IF, IF A UNIT, AND THAT'S REALLY THE QUESTION WE'RE TALKING ABOUT RIGHT NOW, IS IF WE HAVE A UNIT THAT CAN'T MEET THOSE LEGACY REQUIREMENTS AND YET, UM, AND, AND, AND IF THEY MAXIMIZE UP TO THEIR SOFTWARE, YOU KNOW, BY SOFTWARE AND FIRMWARE AND, AND THOSE PARAMETER CHANGES, UM, TO MAXIMIZE THEIR CAPABILITY UP TO WHAT THEIR EQUIPMENT CAN DO, AND THEY STILL CAN'T GET UP TO THOSE LEGACY REQUIREMENTS, THEN HOW MUCH FURTHER SHOULD THEY HAVE TO GO? HOW MUCH MONEY SHOULD THEY SPEND TO DO OTHER UPGRADES LIKE CONTROL CARDS AND, AND, UH, THOSE KIND OF THINGS.
AND SO THAT'S REALLY THE DEBATE.
UM, BUT OTHERWISE, YOU KNOW, WE'RE REFLECTING IN THAT, YOU KNOW, THERE IS AN
[02:30:01]
EXCEPTION.THE INTENT IS TO HAVE AN EXCEPTION PROCESS, BUT THAT THERE NEEDS TO BE SOME CRITERIA ABOUT HOW, WHICH ONES DO WE GRANT AN EXCEPTION TO? BECAUSE THERE REALLY OLD, AND BASICALLY THE ONLY WAY TO FIX THEM IS TO CHANGE OUT THE INVERTERS VERSUS THE ONES WHERE, YOU KNOW, THEY'RE MAYBE, UH, MAYBE THEY'RE OLD, MAYBE THEY'RE NEW, BUT THEY NEED A CONTROL CARD UPGRADE, AND THAT WOULD COST SOME PERCENT OF THE OVERALL COST OF JUST REPLACING THE INVERTER SHOULD THEY DO IT OR NOT.
AND TRYING TO COME UP WITH THAT CRITERIA IS REALLY THE, THE, IT SEEMS TO ME IS THE, THE DEBATE AT THIS POINT.
I MEAN, I, I, I THINK IT, TO ME, I, IT MAKES A LOT OF SENSE TO TRY AND, AS WE SAY, SORT OF RESET THE, THE CLOCK HERE IN TERMS OF UNDERSTANDING WHAT ALL THE EQUIPMENT CAPABILITY IS TRYING TO FIGURE OUT, MAKE SURE THAT WE GET OUR MODELS UPDATED IN SUCH A WAY THAT WE DO FEEL LIKE THEY ACCURATELY REFLECT, REFLECT THE, THE SITUATION.
BECAUSE I THINK WE PROBABLY, AT THIS POINT, WITHOUT TOO MUCH WORK, PROBABLY HAVE A LOT OF INSIGHT INTO WHICH MACHINES CAN AND CANNOT MEET THOSE LEGACY, UH, REQUIREMENTS.
DAN, WAS THERE OTHER LANGUAGE OR ANYTHING ELSE YOU WANTED TO GO THROUGH ON, ON THE SET OF, UM, YEAH, LET'S GO
LET'S GO DOWN TO THE, WHERE WE WERE AND EVERYWHERE.
ANOTHER, THERE'S AT LEAST ONE PARAGRAPH THAT I WANNA TALK ABOUT.
YEAH, I THINK, I THINK THIS IS ALL KIND OF WHAT WE TALKED ABOUT LAST TIME.
UM, AND SO THE, THE, THAT PART THAT SHE JUST WENT BY THERE, UH, REALLY IT, I, I DON'T WANT TO GO INTO DETAIL OF IT, BUT BASICALLY IT, IT TRIES TO GIVE US MORE TIME TO DO THE REVIEW SO THAT IT, IT, GIVEN THAT WE'RE HAVING ALL THE, THE EXCEPTIONS REQUESTED AT, AT ROUGHLY THE SAME TIME, WE WOULD NEED MORE TIME TO EVALUATE THOSE.
AND SO, UM, WE'VE TRIED TO PUT THAT IN, IN THERE.
UM, YEAH, SO HERE, UM, SO THIS IS IF YOU HAVE A FAILURE, OKAY, THEN, UM, IF, AND I THINK THIS IS SOMETHING WE HAVEN'T TALKED ABOUT, THAT IF YOU HAVE, UM, HAVE AN EXEMPTION, THEN THAT EXEMPTION BECOMES YOUR, YOUR REQUIREMENT.
IF YOU, UM, DIDN'T YOU, IF YOU HAVE THIS FAILURE, THEN YOU, UH, IF YOU'RE, IF YOU'RE LESS THAN THE REQUIRED, IF, IF YOU'RE, YOU'RE MAXIMIZING YOUR CAPABILITY AND YOU'RE LESS THAN SAY THE LEGACY REQUIREMENT, THEN YOU HAVE TO MITIGATE BACK UP TO THAT LEGACY REQUIREMENT.
IF YOU'RE, UH, THE PART THAT'S HIGHLIGHTED HERE, IF ANY I, ANY IBR WITH DOCUMENTED MAXIMUM, RIGHT? THROUGH CAPABILITIES THAT EXCEED THE APPLICABLE REQUIRED CRITERIA AND DON'T WRITE THROUGH THE DISTURBANCE, THEN, UH, YOU KNOW, BASICALLY WE PLAN THE SYSTEM AROUND YOUR, UH, WHAT YOU SAID YOU COULD MAXIMIZE.
AND SO THEN YOU'D GO THROUGH THIS, THIS, UH, COMPLIANCE, UH, ISSUE AS WELL.
AND THEN GOING DOWN A LITTLE FURTHER, AND I THINK WE'VE TALKED ABOUT WHAT WE HAVE THERE, BUT, UH, I WANNA GET DOWN TO THE VERY KIND OF LAST PARAGRAPH, I THINK.
[02:35:01]
YEAH.AND SO, SO FOR, FOR THE UNITS THAT MAXIMIZE AND GO FURTHER THAN WHERE THEY'RE BY, BY MAXIMIZING THROUGH, AND, AND THESE ARE THE ONES THAT ARE MAXIMIZING JUST USING SOFTWARE FIRMWARE AND WHATEVER, BECAUSE THEY'RE EXCEEDING THE, THEIR REQUIREMENTS, THEN IF THEY, UM, UM, HAVE A, HAVE A PERFORMANCE FAILURE AND THEY DON'T ACTUALLY MEET THEIR, UH, WHAT, WHAT THEY SAID THEIR CAPABILITY WAS, THEN AS LONG AS THEY, UH, TAKE ACTIONS TO THAT ARE LISTED ABOVE TO TRY TO GET UP BACK UP TO THE, UH, THAT MAXIMIZED REQUIREMENT, THEN THEY WOULD NOT HAVE A COMPLIANCE ISSUE, IF THAT MAKES SENSE.
UM, AS LONG AS THEY MET, AT LEAST MET THEIR, UM, UM, YOU KNOW, IF THEY'RE, IF THEY'RE A LEGACY UNIT AND THEY, THEY MAXIMIZED THEIR CAPABILITY THROUGH SOFTWARE AND WHATEVER, AND, AND IN THEORY EXCEEDED THAT LEGACY REQUIREMENT, THEN AS LONG AS THEY, UH, AS LONG AS THE, THE FAULT WASN'T SOMETHING THAT THEY SHOULD HAVE RIDDEN THROUGH BY MEETING THE LEGACY REQUIREMENTS THEY JUST DID, DID NOT MEET THEIR, WHAT THEY SAID THEIR CAPABILITY WAS FOR MAXIMIZE, THEN AS LONG AS THEY TAKE THAT, TAKE CERTAIN ACTIONS THAT ARE LISTED UP ABOVE, UH, TO GET BACK TO THAT MAXIMIZED CAPABILITY TO ACTUALLY GET TO THAT MAXIMIZED CAPABILITY, THEN THEY WOULDN'T BE SUBJECT TO PERFORMANCE FAILURE FOR TRYING TO GO BEYOND THE, THE STANDARD, IF THAT MAKES SENSE.
AND SO THAT'S KIND OF AN A, AN ENCOURAGEMENT TO, UH, UM, GO AHEAD AND MAXIMIZE IT.
IT IS NOT GONNA HURT YOU TO GO ABOVE THE, UM, THE STANDARD OR YOUR VINTAGE.
UM, WHY DON'T WE, AND I THINK MAYBE WE CAN DO THIS BY STRAW POLLS, WHICH I THINK WE WOULD DO BY EMAIL.
UM, WE, WE, IF WE NEED TO HAVE A DISCUSSION ON THE DATE, LET'S DO THAT.
I THINK WE'VE TOUCHED ON IT, BUT NOT DEDICATED, BUT I'M HOPING MAYBE WE COULD DO STRAW POLLS ON THE DATE AND THEN SOME VERSION OF MAXIMUM CAPABILITY, UM, E EITHER KIND OF DECOUPLING THAT FROM A NEED TO FLUSH OUT EXEMPTION PROCESS OR, I'M, I'M OPEN TO OTHER IDEAS AND I JUST KIND OF, WE DISCUSSED DROP POLLS KIND OF IN THEORY WITH ANN BEFORE, BUT I SORT OF RUNG THIS ON ANN AND COREY AS WELL.
UM, SO LET ME OPEN THAT UP FOR THE GROUP, BUT THAT WOULD BE MY IDEA IS TO DO A STRAW POLL OF TALK TECH MEMBERS ON THE, THE DATE.
UM, AND WHETHER THAT SHOULD BE KIND OF A, A FORWARD LOOKING AND THEN I, I'D BE WILLING TO ENTERTAIN IDEAS FOR, FOR EXACTLY WHAT THE CONCEPT IS, BUT SOME VERSION OF THE MAXIMIZE CAPABILITIES, UM, AND ACCOUNTING FOR THE, THE EXEMPTION PROCESS TO BE HOPEFULLY NARROWED AND KINDA DECOUPLED FROM THAT.
ARE YOU GONNA SAVE ME? GO AHEAD.
UM, UH, MADAM CHAIR, UH, AS, AS A MAYBE A DIFFERENT ROUTE, UM, HEARING SOME OF THE, WE'LL CALL IT KUMBAYA WE HEARD EARLIER.
UM, I WOULD LIKE TO SEE IF THERE IS APPETITE INTACT FOR A DECOUPLING, AND THEREFORE, UM, SINCE WE'RE JUST GOING WITH MAXIMIZATION, THERE WOULDN'T ACTUALLY NEED TO BE ANY DISCUSSION ON A DATE OR DECISION ON A DATE.
UM, AND THEN, UM, JUST TO CLARIFY WITH OUR CUT, UM, I DO NOT MEAN TO PUSH OFF THE, THE, THE SECONDARY PART OF THE DECOUPLING OF UM, UH, BUT RATHER JUST TO GET THIS FIRST PART THROUGH NOW AND THEN, UH, COME BACK AND CONTINUE TO WORK ON THIS OTHER PART, UM, YOU KNOW, AT THE VERY NEXT, UH, APPROPRIATE MEETING.
I THINK WE MAY HAVE CONFUSED, UM, I THINK WE NEED THE DATES THOUGH
[02:40:01]
FOR, UH, TWO SEPARATE ISSUES.AND I, I THINK WE MAY HAVE CONFUSED IT 'CAUSE WE WERE TALKING ABOUT A DATE WITHIN THE MAXIMUM CAPABILITIES.
I THINK WE'D STILL, I THINK WE ARE PROBABLY PRETTY CLOSE TO AGREEMENT ON THE DATE TO WHICH THIS WOULD APPLY TO NEW RESOURCES AND WHETHER IT'S THE 23 OR 24 DATE.
AND SO MAYBE I WOULD AMEND YOUR KUMBAYA MOTION.
UM, BUT LET'S, LET'S GO TO NED IN THE QUEUE.
SO LAST, UH, THE LAST TIME WE GOT TOGETHER, I BELIEVE, UM, CHRIS HENDRICKS HAD A RECOMMENDATION ON THE DATE TO BE 30 DAYS AFTER PUC APPROVAL.
I, I THINK THAT IS PROBABLY THE MOST SENSIBLE ONE FROM A PROCEDURAL STANDPOINT.
UM, SO MAYBE WE CAN START WITH THAT.
I DON'T KNOW HOW WELL THAT FITS WITHIN THE, THE TEXT THOUGH.
SO IF WE NEED TO JUST CHOOSE A DATE CERTAIN, UM, AND MAYBE AN ALTERNATIVE WOULD BE AUGUST, AUGUST ONE OR SEPTEMBER 1ST, 2024.
YEAH, I WAS GONNA PROPOSE SEPTEMBER ONE, BUT I THINK AUGUST ONE WORKS IF WE ARE GETTING THIS TO JUNE BOARD, RIGHT? UM, BUT GENERALLY, AGAIN, I, I AGREE WITH YOU.
THE, THE, THE KUMBAYA COMBO SEEMS TO BE MA YOU KNOW, SUPPORT MAXIMIZATION, UM, CONCEPTUALLY REALIZING THERE'S, WE NEED TO PUT SOME, UM, WE NEED TO PUT SOME TEXT AROUND THAT, UM, OR SOME ADDITIONAL TEXT AROUND THAT.
WE'LL CALL IT AUGUST ONE FOR THE DATE AND, AND THEN THEN MOVE FORWARD ON THE, ON THE, THE, THE REQUIREMENTS FOR ANYTHING NEW.
UH, SO THE, THE DECOUPLING APPROACH, OKAY, I THINK I'M OPEN TO FEEDBACK.
I, I THINK I WOULD APPROACH THAT AS TWO DIFFERENT POLLS, ONE ON THE DATE AND THEN ONE ON MAXIMIZE PLUS DECOUPLE EXEMPTIONS.
UM, SO THAT'S, THAT'S HOW I WOULD ENVISION IT RIGHT NOW.
AND THEN LET ME, LET ME GO TO BOB HILTON IN THE QUEUE.
YEAH, THE ONLY THING I WAS THROWING OUT THERE, UH, WAS THE DATE ON WHEN WE HAVE TO BE, HAVE TO MAXIMIZE EVERYTHING THAT WAS OUT THERE.
AND I THINK, UH, I THINK IT WAS NED THAT BROUGHT UP THE POINT WITH THE MODELS AND EVERYTHING ELSE.
DO WE NEED TO HAVE THAT DATE SET? AND I FORGOT WHAT YOU SAID, NED, BUT I THINK THAT OUGHT TO BE PART OF THE STRAW POLL TOO, BECAUSE I THINK WE WERE KIND OF IN AGREEMENT WITH THAT AND I DIDN'T SEE A LOT OF PUSHBACK FROM DAN, BUT DAN MAY CORRECT ME ON THAT, BOB.
I CAN, I CAN GIVE SOME, I CAN REPEAT THAT IF THAT'S HELPFUL.
YEAH, I, I JUST THINK THAT WOULD BE PART, WE, I THINK WE COULD PROBABLY COME TO A STRAW POLL AGREEMENT ON THAT ONE TOO.
WE HAD, WE HAD, WE HAD THROWN OUT JUNE OF 2020, UH, 26 INSTEAD OF DECEMBER 31ST, 2025 IN ORDER TO GIVE IT, YOU KNOW, THE TIME TO GET MODELS UPDATED IN ADDITION TO MAKING THE, THE CHANGES.
CAN, CAN YOU KINDA WALK THROUGH WHAT THAT REAL CHALLENGE IS? I MEAN, OH MY GOSH.
WHAT, WHAT'S THE NEED FOR THE ACTUAL SIX MONTHS ON THE MODELS? SO THE, I DON'T WANNA SPEAK IN ABSOLUTES, BUT IN GENERAL, UM, YOU KNOW, THE UNDERSTANDING I HAVE IS THAT IT CAN TAKE, YOU KNOW, EASILY SIX TO NINE MONTHS TO SOMETIMES IMPLEMENT UPDATES, ESPECIALLY IF YOU HAVE LIMITED OEM SUPPORT.
[02:45:01]
UM, AND THEN IT CAN ALSO TAKE SOMETIMES, YOU KNOW, SIX TO NINE MONTHS TO GET SUPPORT FOR MODELING UPDATES.AND IF WE'RE LAYERING IN ADDITIONAL APPROVALS, UH, THROUGH THE BIGGER 1 0 9 PROCESS, UM, YOU KNOW, FROM WHERE WE ARE TODAY, LIKE IF YOU, IF YOU TAKE THE UPPER END OF BOTH OF THOSE BOUNDS, THAT GETS YOU RIGHT UP TO, UH, PRETTY MUCH RIGHT UP TO THE DECEMBER 31ST, 20, 25 DATE.
SO ASSUME NINE MONTHS AND NINE MONTHS AND YOU'RE, YOU'RE THERE.
SO IF THERE'S ANY DELAY IN THAT PROCESS, THE CONCERN IS THAT WE JUST, WE'RE CREATING FOOTFALL RISK, YOU KNOW, OF NONCOMPLIANCE WITH THAT DATE WHEN WE ALREADY KNOW THAT THERE'S, YOU KNOW, THE, THE CONSULTANT THAT DO THE MODELING ARE IN HIGH DEMAND.
UM, AND SO, YOU KNOW, WE WANT, WE WANNA HAVE A, YOU KNOW, A, AN AGGRESSIVE DATE, RIGHT? WE WANT TO GET IT DONE.
JUST DON'T WANT TO PUT FOLKS IN A, IN A POSITION WHERE THERE'S, YOU KNOW, IT, IT'S JUST GONNA BE UNNECESSARILY DIFFICULT TO GET THERE.
SO THAT'S WHY WE, WE THROUGHOUT JUNE.
SO YOU'RE SAYING THAT THOSE, THOSE TASKS ARE SEQUENTIAL TYPICALLY? YEAH.
SO THAT'S, Y'ALL CAN CORRECT ME IF I'M WRONG, BUT THE, THE BIGGER 1 0 9 PROCESS I THINK REQUIRES THAT ERCOT APPROVE, PRE-APPROVE, UH, CHANGES THAT ARE MADE TO THE EQUIPMENT AND THAT HAS TO BE DONE THROUGH, UM, THROUGH THE MODEL SUBMISSION.
SO IT SEEMS LIKE THERE'S A LITTLE BIT OF A, A DO LOOP THERE.
SO I, I AGREE WITH THE COMMENT THAT I DON'T KNOW WHO REMEMBER WHO SAID IT, BUT, YOU KNOW, TALK, HAVING A WORKSHOP TO WALK THROUGH HOW THESE THESE THINGS RELATE, UM, WOULD BE HELPFUL.
BUT THAT WAS OUR, OUR, OUR READ OF IT WAS IT, IT ADDS, IT'S GONNA ADD SOME TIME TO IT.
I'M, I'M JUST INTERESTED IN SEEING AS QUICK AS WE CAN.
UM, IT, IT REALLY, IT'S JUST A MATTER OF NOT, NOT SETTING THIS OURSELVES UP TO JUST BE NON-COMPLIANT WITH THE DATE.
UM, IF WE KNOW THAT, THAT WE'RE GONNA BE HARD PRESSED TO GET THERE.
OKAY, JOHN? YEAH, AND JUST A THOUGHT ON THE LAST, YOU KNOW, PUSHING THE DATE AND SOMETHING T MIGHT WANNA CONSIDER IS IF, IF THERE'S A WAY TO STAGE IT, YOU KNOW, MAYBE A CERTAIN PERCENTAGE ON A RESOURCE ENTITY BASIS CAN BE, CAN MEET THE DECEMBER DATE AND THE, AND THE REST THE JUNE DATE, BUT JUST A THOUGHT INSTEAD OF BILLING EVERYTHING BACK TO THE JUNE DATE.
SO JUST NOT HAVING EVERYTHING BE ABOUT LATE.
YEAH, AND I DUNNO THE, THE FEASIBILITY OF THAT IN THE LANGUAGE, BUT YOU KNOW, IS THERE, IS THERE SOMETHING, YOU KNOW, 50% OF OUR UNITS CAN MEET THE DECEMBER DATE AND THEIR OTHER 50% MEET THE JUNE DATE OF 2026.
LET'S GO TO DAN WOODFIN AND THEN BOB PELTON.
I MEAN, I, I THINK I'LL, I'D PROBABLY LIKE IF, IF FOLKS WOULD GO ALONG WITH IT, I'D PROBABLY LIKE JOHN'S IDEA BETTER, BUT WHAT I WAS THINKING WAS AS SOON AS PRACTICABLE, BUT NO LATER THAN JUNE.
AND SO IF PEOPLE, UM, WILL ASSUME THEY'RE ALTRUISTIC AND UM, WE'LL TRY TO GET IT DONE FASTER, TO THE EXTENT THAT, YOU KNOW, YOU, YOU'VE GOT, YOU DON'T ASK YOUR VENDOR DO A, A, A HUGE DUMP, YOU GET THEM THEM TO GIVE YOU THE NEW MODELS AS SOON AS THEY CAN GET THEM TO YOU, AND THEN YOU SEND THOSE TO US AND WE KIND OF WORK THROUGH THE PROCESS IN, UM, AS QUICKLY AS WE CAN, RATHER THAN WAITING AND DUMPING 'EM ALL ON US IN JUNE.
THE, THE BIGGER ONE, ACTUALLY, I WAS GONNA SUGGEST THAT EXACT LANGUAGE.
SO NOW I FEEL LIKE WE REALLY ACCOMPLISHED A LOT
UM, I, I, I THINK, YOU KNOW, MAYBE THE 50% WOULD IF MORE CONCRETE, BUT I, I THINK THAT'S HARDER
[02:50:01]
TO COMPLY WITH.SO LET'S GO TO BOB HILTON AND NED.
UH, ACTUALLY I WAS GOING TO SAY PRETTY MUCH THE SAME THING THAT DAN SAID, BECAUSE THE WAY, YOU KNOW, WE WOULD BE DOING THAT IS WE'D BE GOING THROUGH PLANT BY PLANT, DOING THOSE, DOING THE UPDATES, DOING THE AS BUILDS EVERYTHING ELSE.
AND WE'LL BE TURNING 'EM IN AS SOON AS THEY'RE DONE.
SO I WOULD EXPECT SOME OF THOSE WILL BE IN QUITE A BIT BEFORE DECEMBER.
I DON'T KNOW THE ANSWER TO THAT, BUT I, I DON'T SEE US WAITING UNTIL WE DUMP EVERYTHING IN IN JUNE.
YEAH, THAT TO ME DOESN'T MAKE ANY SENSE ANYONE WOULD WANT TO DO THAT.
I THINK THE 50% ISSUE, I UNDERSTAND WHERE YOU'RE COMING FROM, BUT I, MY FIRST QUESTION WOULD BE IS THAT 50%, I HAVE TO HAVE 50% OF MY FLEET? DO I HAVE TO HAVE 50% OF THE OVERALL FLEET? I THINK WE GET INTO SOME QUESTIONS THERE, AND I, THAT'S WHY I WOULD RATHER DO IT THIS WAY.
OKAY, NED? UH, I WAS JUST GONNA SAY, I, I, I THINK THOSE ARE BOTH REASONABLE APPROACHES.
UM, YOU KNOW, BOB, YOU, YOU DO RAISE A GOOD, GOOD POINT ABOUT THE, THE PRACTICALITY OF MEASURING 50%, BUT, UM, DAN, YOU'RE RECOMMENDED LANGUAGE I THINK IS, IS TOTALLY FINE.
AND, AND TO BE CLEAR, WE, WE, UH, NOT EXPECT, NOR NOR WANT FOLKS TO DUMP THEM ALL ON YOU ON JUNE, IN JUNE, 2026, WE WOULDN'T BE EXPECTING THEM TO COME IN AND, AND WORK THROUGH THE, AND JUST WORK THROUGH THE, THE, THE BACKLOG EFFECTIVELY.
WHERE SHOULD WE GO FROM HERE? WE CAN, SO WE CAN, UM, TAKE A STRAW POLL, STRAW POLL WOULDN'T BE BINDING, YOU KNOW, YOU CAN VOTE HOWEVER YOU WANT WHEN WE TAKE A REAL VOTE.
UM, AND I THINK WE COULD DO IT ONE OF TWO WAYS.
WE COULD HAVE EVERYONE REALLY SEPARATELY ANSWER VIA EMAIL OR WE COULD SORT OF POSE A QUESTION AND ASK IF THERE'S ANY OBJECTIONS OR CONCERNS OR OTHER SUGGESTIONS.
UM, I THINK THE SECOND WAY MIGHT BE EASIER, AND MY PROPOSALS WOULD BE ONE STRAW POLL ON THE DATE, NOT THE DATE WE WERE JUST DISCUSSING, BUT THE, THE DATE TO WHICH THIS WOULD APPLY TO NEW RESOURCES.
UM, THE SIGNED INTERCONNECT AGREEMENT, I BELIEVE.
AND WE WOULD PROPOSE THAT TO BE AUGUST 1ST, 2024.
AND THEN THE SECOND POLL WOULD BE THE MAXIMIZE CAPABILITY WITH DECOUPLING THE, UM, EXEMPTION PROCESS.
AND THE, THE DATE RELEVANT TO THAT MAXIMIZED CAPABILITY WOULD BE JUNE 1ST, 2026.
IS THAT CORRECT, NED? THAT SOUNDS GOOD.
NOW I SEE A QUESTION FROM IAN.
UM, MY VOTE WILL, WILL DEPEND UPON ERCOT THOUGHTS ON THIS.
UM, AND I THINK, I THINK TACK AND ERCOT HAVE, HAVE NOT AGREED ON THE WAY TO MOVE FORWARD ON THIS.
SO I DON'T WANNA PUT SOMETHING ELSE TO THE BOARD, UH, THAT, THAT ERCOT IS VERY OPPOSED TO.
SO ERCOT, DAN, DO YOU WANNA SPEAK TO THIS? YEAH, SO, UM, I GUESS OUR, OUR STRONG PREFERENCE WOULD BE TO GO AHEAD AND RESOLVE THE, UH, HOW MUCH FOR, FOR THOSE FOLKS THAT AREN'T MEETING THE LEGACY REQUIREMENTS TODAY, HOW FAR DO THEY HAVE TO GO AND WHAT, AND I THINK THE DISCUSSION HAS BEEN THAT THEY PROBABLY WOULD NEED TO GO FURTHER THAN JUST THE, UH, SOFTWARE FIRMWARE AND PARAMETERIZATION.
UM, BUT WE WOULD ADDRESS THAT LATER.
UM, I THINK IT WOULD BE BETTER TO JUST GO AHEAD AND RESOLVE THAT NOW RATHER THAN, I, I GUESS I GOT A QUESTION FOR ANN IN A MINUTE, IF SHE'S, UM, UM, TUNED IN.
UM, BUT THE, UM, IT WOULD BE OUR STRONG PREFERENCE TO GO AHEAD AND RESOLVE THAT NOW.
'CAUSE I THINK WE, WE'VE HAD ALL THE DISCUSSIONS, WE UNDERSTAND THE, THE, THE ISSUES.
UM, EFFECTIVELY WHAT YOU, WHAT YOU WOULD BE DOING BY DOING, UH, DOING THAT IS, IS THE EXCEPTION PROCESS.
UM, YOU, YOU'D BE GRANTING ALL, YOU'D, YOU'D BE BASICALLY BE MANDATING THAT YOU GRANT ALL THE EXCEPTIONS, UM, TO THE MEETING, THE, THE KIND OF THE LEGACY
[02:55:01]
STANDARDS.UM, AND SO, YOU KNOW, UNTIL WHICH TIME SOME FUTURE NPR IS DONE.
AND I GUESS THAT'S MY QUESTION FOR ANN IS, IS I THINK, IS THERE, IS THERE ANOTHER PROCESS THAT WOULD ALLOW THIS NPR OR THIS NOTE, UH, UH, NORE TO BE APPROVED? AND THEN WOULD WE HAVE TO FILE A COMPLETELY NEW NOER TO, UM, IMPLEMENT CHANGES TO THIS ONCE? BECAUSE OTHERWISE I DON'T UNDERSTAND HOW THE BOARD WOULD APPROVE IT WITH, UH, JUST THE MAXIMIZE TO SOFTWARE, FIRMWARE AND, UM, PARAMETERS AND THEN HAVE, YOU KNOW, WE, WE HAVE TO COME BACK AND DO ANOTHER NOER.
YEAH, YOU WOULD HAVE TO, IF THIS ONE'S APPROVED TO CHANGE THE LANGUAGE IN THE OPERATING LINE, YOU HAVE TO COME BACK WITH ANOTHER NOER, UNLESS YOU KNOW WHAT YOU'RE CHANGING THAT TO NOW.
AND THEN YOU COULD PUT IN GRAY BOXES TO THIS NUMBER SAYING THIS DATE, THIS, THIS IS THE LANGUAGE THAT WOULD BE EFFECTIVE, KIND OF LIKE WHAT WE WERE DOING WITH 1230.
UM, BUT IF YOU DON'T KNOW WHAT THAT LANGUAGE IS NOW, YOU WOULD NEED ANOTHER NUMBER.
NO, GO AHEAD AND ASK YOUR WHATEVER FOLLOW UP YOU GOT.
UM, SO MY THOUGHT, DAN, IS THAT WE CAN AT LEAST GET THIS LANGUAGE THROUGH TO THIS CURRENT BOARD.
UM, I, I STILL HAVE, UM, THOSE CONCERNS I HAD EARLIER ABOUT HOW ERCOT WOULD, UH, APPROVE OR DENY RESOURCES IN VERY SIMILAR CIRCUMSTANCES WHERE, UH, ALLOWING ONE'S APPROVAL, UH, WOULD BE FINE, BUT ALLOWING BOTH APPROVAL WOULDN'T BE FINE OR, YOU KNOW, SOME, SOME ITERATION OF THAT.
UM, SO THAT'S WHERE I AM OF HOPING WE CAN MOVE THIS FORWARD AND THEN, UM, GET ERCOT THE MAXIMIZATION, GET ERCOT THE, THE DATE FOR GO FORWARD AND THEN, UM, CONTINUE TO WORK ON THE OTHER PART BUT NOT HOLD UP, UM, THOSE TWO, THOSE TWO IMPORTANT PARTS.
IS THAT A QUESTION FOR DAN? I, I WAS JUST TRYING, IT WASN'T A QUESTION, IT WAS JUST TRYING TO HELP, OR SORRY, I SHOULDN'T SAY THAT.
I WAS TRYING TO EXPLAIN TO DAN WHY I THOUGHT THIS MIGHT BE A WAY FORWARD.
UM, BECAUSE PERSONALLY MY VOTE, I'M NOT SURE I'M WITH ERCOT ON THE EXCEPTION PROCESS AT THIS POINT, AND THEREFORE I DON'T KNOW IF AS A TAC MEMBER, I COULD VOTE OUT THAT PART AS ERCOT WOULD LOVE IT, UH, FOR THE JUNE BOARD MEETING.
WELL, SO WE HAVE ONE MORE MEETING STILL, WHICH IS NOT A LOT OF TIME.
UM, SO THE STROKE POLL IS JUST AN IDEA.
WE DON'T HAVE TO DO IT, AND WE CAN CERTAINLY TAKE AWAY THINGS THAT NEED TO BE WORKED ON AND CAN BE WORKED ON IN THE NEXT WEEK.
UM, SO LET, LET'S GO TO BOB HILTON.
I WANNA MAKE SURE I UNDERSTAND WHAT WE'RE TALKING ABOUT ON THE, THAT WHAT WE'RE GONNA BIFURCATE.
ARE WE GOING TO BIFURCATE THE ENTIRE EXEMPTION PROCESS OR ARE WE GOING TO JUST BIFURCATE SECTION C ON THE HARDWARE STUFF AND WHAT THAT THRESHOLD WOULD BE? AND, AND THEN THE QUESTION I WOULD ASK DAN IS WOULD THAT MAKE YOU MORE COMFORTABLE IF WE PULLED OUT THE SECTION C AND PUT THAT INTO ANOTHER NOER SO WE COULD TRY TO WORK THROUGH THAT? 'CAUSE I THINK BOTH OF US HAVE QUESTIONS ON THAT NOW, UNLESS YOU COULD COME UP SOMETHING AND I'M, I'M TRYING TO FIGURE IT OUT MYSELF BETWEEN NOW AND THE SEVENTH.
SO THAT'S A QUESTION TO ERCOT ON IF THEY'D BE MORE COMFORTABLE WITH JUST REMOVING THE C ON HARDWARE AND TAKING THAT, CARVING THAT PART OUT.
YEAH, I'M NOT SURE THEY'LL BE AMENABLE TO THAT, BUT IT WAS JUST A SUGGESTION THAT THAT
[03:00:01]
SEEMS TO BE ONE OF THE FINAL BIG STICKING POINTS THAT, UH, WE NEED TO PAY ATTENTION TO AND EXACTLY WHAT THIS PARAGRAPH MEANS, THE WAY IT'S WRITTEN AND IS IT THE RIGHT FORMULA ANYWAY.SO I THINK THAT'S SOMETHING THAT WE COULD LOOK AT.
ERIC, DO YOU WANT TO YEAH, GO AHEAD.
UM, I THINK IF YOU WERE GOING TO DO THIS DECOUPLING APPROACH, UM, AS I, AS I UNDERSTAND, THE CLEANEST WAY TO DO IT WOULD BE TO HAVE THE REQUIREMENTS THAT ARE CHANGED BY THE NOER TO BE REQUIREMENTS THAT REQUIRE MAXIMIZATION BY THE DATE WE DISCUSSED AND HAVE NEW RESOURCES, UM, HAVE THE NEW, UH, RIDE THROUGH REQUIREMENTS, UM, BY THE DATE WE DISCUSSED.
AND THEN IT JUST WOULDN'T CHANGE ANYTHING FOR THE EXISTING RESOURCES AS IT RELATES TO THINGS THAT AREN'T MAXIMIZATION.
SO THEY WOULD HAVE THEIR EXISTING REQUIREMENTS, THEY WOULDN'T HAVE AN EXEMPTION, BUT THEY WOULD HAVE TO MEET, YOU KNOW, THEIR EXISTING REQUIREMENTS AND THE MAXIMIZATION REQUIREMENTS.
SO IF THEY HAD, IF WE KEPT THE EXISTING REQUIREMENTS AND, YOU KNOW, ERCOT FELT THEY WEREN'T MEETING THE EXISTING REQUIREMENTS, THEN ERCOT COULD CONTINUE TO PURSUE THEM FOR THAT AS THEY ARE FOR, FOR SOME OR NOT AS ERCOT IS, BUT AS THE ERM IS FOR SOME RESOURCES.
SO THEREFORE WE WOULDN'T NEED THE EXEMPTION PROCESS YET BECAUSE THERE WOULDN'T BE A REQUEST TO GET AN EXEMPTION.
YOU'D HAVE TO MEET YOUR EXISTING REQUIREMENTS AND MEET THE MAXIMIZATION REQUIREMENTS.
AND I THINK THAT'S THE CLEANEST WAY TO DO THE DECOUPLING, UM, IF, IF YOU TAC IS GONNA PURSUE IT.
WELL, SO NOT SURPRISINGLY, I DON'T LIKE ERIC'S IDEA AS WELL AS IT DID BOB'S THE, UH, BECAUSE IT SEEMS LIKE THAT THAT WOULD REQUIRE TAKING OUT A LOT OF THE THINGS THAT WE'VE, UM, COME TO MORE AGREEMENT ON.
UM, I MEAN, ESSENTIALLY THE, IF, IF, IF YOU'RE GONNA GO DOWN, IF, IF, IF TECH WANTS TO GO DOWN THIS PATH, THEN I THINK IT WOULD BE BETTER JUST TO, UM, YOU KNOW, I, I KEEP TALKING ABOUT THAT.
THERE'S, THERE'S A QUESTION OF HOW FAR DO YOU HAVE TO GO TO MEET, GET UP TO THE LEGACY REQUIREMENTS.
SO STRIPPING OUT ALL THE, THE DISTINCTION BETWEEN THE PREFERRED REQUIREMENTS AND THE LEGACY REQUIREMENTS, ALL THAT LANGUAGE, I THINK THAT'S MAYBE GOING TOO FAR FOR THAT.
UM, BUT SOMETHING THAT, UM, UM, IF YOU CAN GO UP JUST A LITTLE BIT HERE.
UM, I MEAN, I, I GUESS, YEAH, STOP THERE THEN.
THE, UM, SO IT SEEMS LIKE YOU STILL NEED AN EXEMPTION PROCESS AND, AND THOSE KIND OF THINGS, BUT IT WOULD REALLY JUST BE THE, UM, HOW FAR DO YOU, IT'S, IT IS MORE A QUESTION OF HOW FAR DO YOU HAVE TO GO TO TRY TO MEET THOSE AND DOES IT INCLUDE JUST THE SOFTWARE UPGRADES OR NOT? IF, IF YOU, UH, CAN'T MEET THE EXISTING, THE LEGACY REQUIREMENTS WITH THE SOFTWARE UPGRADES, THEN YOU SHOULD STILL, UH, DO A, UH, HAVE TO DO AN EXCEPTION, SORRY, EXEMPTION.
UH, IT IS LIKE DOING SURGERY AND TRYING NOT TO, UM, TAKE OUT THE PARTS THAT MATTER AND JUST TAKE OUT THE APPENDIX.
GO, GO AHEAD AND GO TO ERIC AND I'LL, WE'LL WORK ON IT.
YEAH, I, I THINK, ALL RIGHT, CAN YOU HEAR ME? YEP.
I, I THINK WHAT THIS IS HIGHLIGHTING TO ME IS THAT WE NEED ANOTHER WEEK BEFORE EVEN A STRAW POLL BECAUSE THERE SEEMS TO BE, BUT IFS THEN THERE'S SO MUCH INTRICATE RELATIONSHIP ON ALL THIS PROCESS THAT, UH, I THINK I WOULD BE BETTER OFF WITH A LITTLE MORE TIME TO THINK THROUGH IT.
[03:05:01]
I KNOW IT'S FRUSTRATING, BUT WE'D LIKE TO GET THIS RIGHT.WHAT I'VE BEEN IMPRESSED WITH THE LAST COUPLE WEEKS IS HOW MUCH CLOSER, UH, ERCOT HAS BEEN WITH THE OTHER PARTIES AND THAT WE'RE MAKING STRONG PROGRESS.
I JUST DON'T WANT TO DERAIL SOMETHING IF THERE'S NOT A CLEAN BREAK AT THIS POINT WHERE WE CAN, WE CAN SEPARATE.
SO IF ANOTHER WEEK HELPS ON THAT, I THINK IT'D BE A GOOD IDEA.
BUT WE, IN ORDER TO GET THIS TO THE JUNE BOARD, WE WILL NEED TO TAKE A LANGUAGE VOTE AT NEXT WEEK.
SO I, I WANNA MAKE SURE, YOU KNOW, I, I UNDERSTAND IT'S A COMPRESSED TIMELINE, BUT WE WILL NEED PEOPLE TO BE READY TO MAKE A LANGUAGE VOTE A WEEK FROM TODAY.
UM, AND SO I, I THINK IT WOULD BE WORTH SEEING LANGUAGE OPTIONS OF, OF BOTH, UM, WHAT BOB PROPOSED WITH, WITH JUST THE SEAT TAKEN OUT AND WITH WHAT ERIC PROPOSED.
BUT I, I DO WANNA MAKE SURE PEOPLE HAVE A CHANCE TO REVIEW THOSE OPTIONS AND COME TO OPINIONS TO, TO MAKE, YOU KNOW, THE, THE REAL VOTE ON THE, THE LANGUAGE HAS TO BE NEXT FRIDAY IF WE'RE GONNA GET THIS TO THE JUNE BOARD.
I, I DUNNO IF THIS WORKS OR, OR MAKES SENSE OR NOT, BUT JUST ANOTHER ALTERNATE PATH ON, ON PARAGRAPH C AND THE EXEMPTION PART THERE.
I MEAN, ONE PATH COULD BE TO GRAY BOX THAT WITH SOME DATE CERTAIN OUT IN THE FUTURE THAT WOULD ALLOW US TO, OR ALLOW ORCO TO GATHER ALL THE MODELS, DO THE RELIABILITY ASSESSMENT, AND IN, IN THE MEANTIME, WHATEVER THAT IS, EIGHT, 18 MONTHS, TWO YEARS, UH, POTENTIALLY CHANGE THAT OR THE ALTERNATIVE THERE UNDERSEA HAVE SOMETHING THAT, UH, MORE SPECIFICALLY ON AN INTERIM BASIS CARVES OUT, YOU KNOW, A VERY SPECIFIC SEGMENT FOR THE TYPE ONE TYPE TWO WG UNTIL THIS RELIABILITY ASSESSMENT IS DONE.
JUST A SLIGHTLY DIFFERENT PATH TO KEEP THE, KEEP THE STRUCTURE THERE.
UM, DAN, ARE YOU SAYING THAT THERE WERE RESOURCES THAT WENT IN AND COULDN'T EVEN, THAT THEY BUILT THEIR RESOURCE WITH SOFTWARE AND HARDWARE THAT COULDN'T EVEN MEET THE REQUIREMENTS AT THE TIME? I THINK WHAT WE FOUND IS THAT, UM, AND OF COURSE I HAVEN'T BEEN DIRECTLY INVOLVED IN DOING THIS ANALYSIS, BUT WHAT I'VE HEARD IS THAT AS PART OF THE EVENT INVESTIGATION OF SOME OF THE, NOT ONLY THE ODESSA EVENTS, BUT SOME OF THE SMALLER ONES IS THAT THERE ARE, UH, UNITS THAT DON'T MEET THE CURRENT PROTOCOL REQUIREMENTS.
I THINK ERIC HAS ALLUDED TO THIS SEVERAL TIMES, THAT THERE WERE ARE PEOPLE THAT ARE GOING THROUGH THE, THE, UH, COMPLIANCE PROCESS RIGHT NOW AND BY REQUIREMENTS RIGHT NOW.
DO YOU MEAN THE REQUIREMENTS OF WHEN THEY WENT OPERATIONAL AND THOSE REQUIREMENTS HAVE CHANGED AND THEIR, AND THEY MET 'EM WHEN THEY WENT OPERATIONAL, BUT THEY'RE NOT MEETING THEM NOW OR THEY NEVER MET THEM? I DON'T KNOW THE ANSWER TO THAT, BUT THEY DON'T MEET THE CURRENT REQUIREMENTS WHICH ARE APPLICABLE TO THEM.
NOW WHETHER THOSE ARE FIXABLE BY SOFTWARE UPGRADES OR NOT, I DON'T KNOW THE ANSWER TO THAT.
I APPRECIATE YOU HELPING ME UNDERSTAND THAT.
SO I THINK THE QUEUE IS CLEAR.
HOW DO WE WANT TO GO FORWARD? DO WE WANT TO SEE SOME OPTIONS OF LANGUAGE FOR DIFFERENT WAYS OF A, A CARVE OUT FOR THE EXEMPTION PROCESS OR, OR A NARROW VERSION OF THAT? UM, DO WE WANT TO TRY TAKING A, A STRAW POLL HERE AND IF WE, IF WE NEED TO SEE LANGUAGE OPTIONS, DO WE WANT THOSE FILED BY A CERTAIN DATE SO THAT WE ARE ABLE TO TAKE A LANGUAGE VOTE NEXT
[03:10:01]
FRIDAY? GO AHEAD, ERIC.UH, MAYBE I'M THINKING OUTTA THE BOX ON THIS.
I AGREE WITH THE, THE LANGUAGE IS LANGUAGE NEEDED AND SO FORTH, BUT WHAT I'D LIKE TO SEE IS LIKE ERIC GOFF AND BOB HILTON AND DAN WOODFIN GET TOGETHER, UH, ONE MORE TIME AND SEE IF THEY CAN NARROW DOWN THEIR DIFFERENCES EVEN FURTHER BEFORE WE GET SOME LANGUAGE.
UH, 'CAUSE THERE'S SOME GOOD CONVERSATIONS HERE, BUT THERE'S SO MUCH INTRICACY INVOLVED.
IS THAT A FEASIBILITY OR SECONDLY, IF PARTIES CAN FILE SOME LANGUAGE AND DAN OR OR OTHER PER STAFF CAN COMMENT ON THEM BEFORE WE VOTE, THAT WOULD BE HELPFUL AS WELL.
SO ARE YOU SUGGESTING AN ADDITIONAL MEETING BEFORE NEXT FRIDAY? UH, WHAT I WOULD, WHAT I WOULD LIKE IS, IS A, IS SOME WORK FURTHER WORK ON LANGUAGE SENDING IT A BIT LATER IN THE WEEK THAN PERHAPS BY MIDWEEK.
SO WE AT LEAST HAVE SOME, SOME TIME FOR GIVE AND TAKE TO UNDERSTAND SOME OF THIS AT THIS POINT.
SO I SAID IT'S KIND OF OUT THERE, BUT I'LL, I'LL, I'LL POST IT.
UM, I, I'M HAPPY TO GET SOME LANGUAGE DRAFTED AS QUICKLY AS POSSIBLE TO IMPLEMENT WHAT I THINK PEOPLE WERE TALKING ABOUT.
UM, AND, UM, YOU KNOW, OBVIOUSLY THERE'S A LOT OF WORK, BUT DO IT WITH ENOUGH TIME THAT WE CAN GET PEOPLE TO HAVE SOME TIME TO REVIEW IT AND OFFER FEEDBACK BEFORE THE MEETING TO TRY TO ACCOMPLISH WHAT ERIC SCHUBERT WAS JUST ASKING FOR.
UM, YOU KNOW, TIME IS OF THE ESSENCE, BUT WE, WE CAN MAKE IT A PRIORITY TO GET DRAFT LANGUAGE FILED AS QUICKLY AS POSSIBLE THAT PEOPLE COULD REACT TO IN ADVANCE OF THE MEETING.
SO I, I GUESS, UM, I'M TRYING TO, I'M TRYING TO AVOID, UH, COMPETING, UM, SETS OF LANGUAGE THAT ARE, YOU KNOW, SIGNIFICANTLY DIFFERENT.
UM, THAT'S BEEN THE PROBLEM ON THIS ALL ALONG, THAT, YOU KNOW, IT'S HARD TO SEE WHAT ALL THE DIFFERENCES ARE AND WHICH ONES MATTER AND SO FORTH.
I MEAN, IF WE COULD, IF WE COULD TAKE THE VERSION THAT THAT IS BEFORE US TODAY AND KIND OF MAKE THE, THE MINIMAL, UH, CHANGES TO THAT TO IMPLEMENT THE TWO DAY DIFFERENCES THAT WE TALKED ABOUT, AND THEN THE, UH, WHERE, UM, PEOPLE DIDN'T GO BEYOND THE, UM, UM, DIDN'T HAVE, WEREN'T REQUIRED TO GO BEYOND THE, UM, THE SOFTWARE PARAMETER AND, UM, UM, FIRMWARE UPGRADES OR AT LEAST THE, MAYBE THE, THE LIST OF THINGS THAT ARE IN B THERE, UM, THEN I, I THINK THAT WOULD BE HELPFUL.
WHAT'S THE, WHAT'S THE MINIMUM CHANGES TO THIS VERSION THAT COULD GET THERE? NOW? I DON'T KNOW THAT I WANT ERCOT TO BE THE ONE THAT FILES THOSE COMMENTS BECAUSE I THINK WE'D STILL, UH, STRONGLY PREFER TO GO AHEAD AND GET THE, THAT OTHER ISSUE RESOLVED NOW AS WELL, AS OPPOSED TO HAVING DO A SEPARATE NOTE OR, BUT WE CAN WORK WITH FOLKS TO MAKE SURE THAT, UM, THAT'S KIND OF THE, THE MINIMAL SET OF CHANGES, BECAUSE I THINK THAT'LL MAKE IT EASIER FOR DAC.
I, I, I HAVE TO TALK TO, UM, PEOPLE, UH, I UNDERSTAND THE DESIRE FOR THAT.
SO I THINK WHAT WE CAN DO IS, UM, EITHER WORK FROM THIS OR COPY IN THE THINGS THAT YOU'VE CHANGED.
LIKE, SO FOR EXAMPLE, THERE ARE THINGS THAT AREN'T NECESSARY THAT YOU ADDED TO HARDWARE THAT'S JUST A BASELINE.
WE JUST WOULDN'T HAVE THAT AS A RED LINE.
IT JUST WOULDN'T BE INCLUDED IN THE RED LINE.
SINCE YOU, YOU DON'T HAVE FORMAL COMMENTS THAT ADD THIS, BUT WE CAN ADD THE LANGUAGE AND THAT YOU'VE ADDED HERE THAT IS STILL WITHIN THE FRAMEWORK.
DOES THAT MAKE SENSE? SINCE THESE AREN'T FORMALLY FILED COMMENTS TO, TO RED LINE ON TOP OF OH, RIGHT, RIGHT.
I MEAN, ULTI ULTIMATELY THERE WOULD HAVE TO, I MEAN, I GUESS THE IDEA IS THAT WE, WE, UH, LET'S SAY TAC TODAY HAD BOUGHT INTO A HUNDRED PERCENT OF WHAT'S IN THESE SET OF THIS SET OF, OF DRAFT, UH, WELL, I DON'T EVEN KNOW WHAT TO CALL IT.
TH THIS, THIS DOCUMENT IF TAG IT HAD BOUGHT INTO EVERYTHING THERE, OUR INTENT WAS TO TAKE THAT WORK WITH MARKET RULES TO PUT IT BACK INTO A NORMAL SET OF
[03:15:01]
COMMENTS, UH, THAT HAS ALL THE BREAKOUT OF WHO FILED WHAT AND SO FORTH BACK THROUGH HISTORY AND THEN FILE THAT.AND SO WE WERE INTENDING TO DO THAT ANYWAY.
WE CAN, WE CAN DO THAT AND THEN, UM, AND THAT WE WOULD BE HAPPY TO FILE AND THEN ON TOP OF THAT, UM, MAKE THE MINIMAL CHANGES.
MAYBE THAT'S THE RIGHT, UH, I DON'T KNOW WHAT YOU THINK, ANNE.
YEAH, EVENTUALLY, LIKE YOU GUYS SAID, WE'RE GONNA NEED THESE ON TOP OF THE BOARD REPORT, BUT IF ERIC WANTS TO MAKE THE CHANGES ON TOP OF THIS ONE FOR NOW, THAT'S FINE.
BUT YOU KNOW WHAT, WHAT WE APPROVE AND WHAT WE LOOK AT AT THE NEXT TECH MEETING WILL BE THE COMPLETE SET OF RED LINES.
SO I, I'M HAPPY TO COORDINATE WITH ERCOT ABOUT THE DETAILS OF, OF HOW TO GET THAT DONE.
UM, AND I THINK WHAT WE WOULD HA, I THINK THIS IS ON TOP OF THE TAC REPORT AND THAT'S WHAT'S BEFORE TAC IS THE TAC REPORT.
SO I THINK THERE'S A WAY TO MODIFY THE TAC REPORT TO ACCOMPLISH THIS AND INCLUDE THE THINGS THAT ARE STILL RELEVANT IN THE LANGUAGE THAT'S ON THE SCREEN RIGHT NOW.
AND I'M, I'M HAPPY TO, TO SHARE WORKS IN PROGRESS WITH
I'M GETTING MORE AND MORE CONCERNED THE, THIS SOUNDS MORE AND MORE LIKE TWO COMPLETELY DIFFERENT VERSIONS.
UM, LET'S, LET'S GO TO ERIC BLAKEY AND MAYBE, I, HOPEFULLY THERE'S, I'M MISTAKEN AND MY CONCERN.
NO, I, I THINK I SHARE YOUR CONCERN.
I'M, I'M TRYING TO UNDERSTAND FROM DAN.
I, I, I HEAR HIM, HE'S, HE HE'S HOLDING OUT, YOU KNOW, THAT WE'LL STILL GET RESOLUTION OF, OF THESE, THESE, ALL OF THESE ISSUES.
NOW, UM, I GUESS I'M WONDERING, IS THAT BECAUSE THERE'S A RELIABILITY CONCERN OR BECAUSE I, I GUESS WHAT I'M AFRAID IS GONNA HAPPEN IS WE'RE GONNA GO DOWN THIS PATH, WE'RE GONNA PULL OUT WHAT WE AGREED TO AND IT'S GONNA GO TO THE BOARD AND Y'ALL ARE GONNA APPEAL THAT TO THE BOARD.
AND I THINK IT WOULD HELP THE DYNAMIC IF WE COULD GET, PULL OUT WHAT WE AGREED TO AND THEN ADDRESS THOSE OTHER ISSUES IN A NO, BECAUSE IT SOUNDS LIKE THERE'S A LOT OF ISSUES, A LOT OF QUESTIONS ABOUT THAT, THAT I DON'T THINK WE CAN GET RESOLVED IN A WEEK.
SO ANYWAY, I JUST WANTED TO UNDERSTAND, ARE YOU, ARE YOU HOLDING THAT OUT BECAUSE OF YOUR STRONG RELIABILITY CONCERNS OR JUST THE CONVENIENCE OF GETTING IT ADDRESSED? NOW? I, I, I THINK THE, THE, THE BASIC CONCEPT THAT, THAT WAS DISCUSSED WHILE AGO WAS THAT WE WOULD, UM, THAT TECH WOULD PASS THIS, RECOMMEND, RECOMMEND THIS TO THE BOARD WITHOUT THE, UH, RESOLUTION ON HOW FAR DO PEOPLE HAVE TO GO IF BEYOND, OR DO THEY HAVE TO GO BEYOND, UH, JUST SOFTWARE, ET CETERA, UPGRADES, UM, IF THEY'RE NOT MEETING THE LEGACY STANDARDS AND, UM, OR, OR, OR IF, IF THE TIMING IS RIGHT THAT THEY'RE NOT BEING THE, UM, UM, PREFERRED STANDARDS.
AND SO IF, HOW DO I SAY IT? AND, AND THEN WE WOULD FOLLOW UP WITH A, AN ANOTHER NOER TO RESOLVE THOSE ISSUES.
UM, AND SO IF THAT, IF THAT'S THE PLAN, I MEAN, I THINK WE'D RATHER GO AHEAD AND GET 'EM RESOLVED HERE.
I'M NOT SURE THAT'S, DOESN'T SOUND LIKE THAT CAN HAPPEN IN THE NEXT WEEK, BUT WE DO WANT TO NOT, UH, JUST RESOLVE THIS SET OF PRO THE, THE, THE, THE MAXIMIZE USING SOFTWARE ISSUES AND THEN NOT HAVE SOME MANDATE TO COME BACK AND, UM, RESOLVE THE REST OF IT, IF THAT MAKES SENSE.
NOT, NOT TO CONSIDER AT LEAST CONSIDER THAT FOLLOW UP NOTE.
SO THAT'S WHAT REALLY WHAT I'M TRYING TO PRESERVE HERE IS THE, UM, MANDATE TO, UM, WELL, THE, THE PREFERENCE TO, UH, GET IT RESOLVED NOW, AND THEN THE, UH, IF THAT FAILS, THEN THE MANDATE TO, UH, DO A FOLLOW UP NOTE.
[03:20:01]
LET'S GO TO COLIN.I'M STILL TRYING TO WRAP MY HEAD AROUND HOW WE'RE GONNA TWEAK THIS SECTION HERE AND, AND I'VE HEARD I THINK TWO DIFFERENT VERSIONS, BUT DAN, WHAT WHAT I, WHAT I THINK I HEARD YOU SAY, KIND OF REPRESENTING ERCOT IS THAT WE, WE NEED TO KEEP THE EXCEPTION PROCESS IN PLACE.
IS THAT RIGHT? AS KIND OF THE MINIMUM BASELINE? YES.
AND, AND ERIC, WHATEVER, YOU KNOW, MINOR TWEAK Y'ALL BE LOOKING AT WOULD BE BASED ON, ON KEEPING THAT STRUCTURE IN PLACE, RIGHT? UM, AS I UNDERSTOOD IT, THE EXCEPTION PROCESS APPLIED WHEN YOU, OR THINGS WHEN YOU COULDN'T MEET THE, THE NEW REQUIREMENT THAT WE WERE SETTING.
AND IF WE'RE NOT SETTING THE NEW REQUIREMENT, THEN THE LEGACY REQUIREMENT, UM, EXCUSE NOT THE LEGACY REQUIREMENT, THE EXISTING REQUIREMENT IS STILL IN PLACE.
SO I, MAYBE I'M MISUNDERSTANDING WHAT DAN IS SAYING, BUT I DON'T KNOW WHY WE WOULD NEED THE EXEMPTION PROCESS IF ALL WE WERE DOING WAS MAXIMIZING BECAUSE EVERYONE WOULD DO WHAT THEY CAN WHILE WE CONTINUE TO WORK OUT WHAT EXEMPTION AND HARDWARE PROCESS WE NEED.
UM, SO I, IT SEEMS TO ME LIKE THOSE, THOSE ISSUES ARE PAIRED TOGETHER.
UM, IF WE KEPT THE EXEMPTION PROCESS IN PLACE, UH, FOR THIS NOER, WE WOULD ALSO NEED TO RESOLVE THE RELIABILITY, UM, PIECE THAT WE, WE SPENT TIME TALKING ABOUT, ABOUT SHOULD IT BE 500 MEGAWATTS OR, YOU KNOW, SOMETHING ELSE, OR, YOU KNOW, HOW IS INSTABILITY STUDIED? SO IT SEEMS LIKE WE'D BE ADDING EXTRA WORK THAT WE HAVEN'T YET RESOLVED, WHICH, AND I THOUGHT THE, THE PURPOSE OF THE DECOUPLING WAS TO MOVE FORWARD IN THE THINGS THAT THERE WAS RESOLUTION ON.
UM, SO THAT, THAT'S HOW I SEE IT IS THAT THOSE, THOSE PIECES GO TOGETHER.
BUT I UNDERSTAND DAN'S POINT ABOUT WANTING TO KNOW WHAT THE REQUIREMENT IS FOR THE EXISTING FACILITIES, AND, AND I'M REPEATING MYSELF AND I KNOW YOU DON'T WANNA DO THAT, BUT JUST TO BE, TO BE BRIEF ON THAT, I THINK THE REQUIREMENT IS THEY WOULD HAVE THE EXISTING RULES THEY HAVE TODAY AND THEY WOULD HAVE TO MAXIMIZE, AND THE MAXIMIZING COULD BE ABOVE THE EXISTING.
UM, AND IF IT CAN'T BE ABOVE THE EXISTING, IN ALL LIKELIHOOD, THAT'S BECAUSE THERE'S A HARDWARE ISSUE THAT'S STOPPING THEM FROM DOING THAT, WHICH GETS BACK TO THE, THE POINT ABOUT DECOUPLING.
SO I THINK IT ALL COMES BACK TO HARDWARE AND HOW TO ADDRESS IT.
I, I'LL LET DAN TELL ME WHAT, WHAT HE WAS REALLY SAYING, BUT I, I DIDN'T THINK I HEARD THAT OR CAUGHT POST THAT APPROACH, BUT THAT THEY MAYBE WOULD PREFER TO GET IT ALL DONE IN ONE EXCEPT RATHER THAN CARVING OUT A SEPARATE NOER.
BUT I, I THINK WHAT SOME OF THE MEMBERS WERE TRYING TO GET AT WAS THEY, WOULD THEY OPPOSE THAT APPROACH AT THE BOARD FOR A RELIABILITY REASON? YEAH.
DAN, IF, IF THAT'S PUTTING YOU ON THE SPOT TOO MUCH, YOU DON'T HAVE TO ANSWER RIGHT NOW, BUT I'M, I JUST WOULD AT LEAST LIKE TO LAY UP THE STEP BECAUSE I BELIEVE THIS, I GUESS THAT'S ULTIMATELY AN ERCOT QUESTION TOO, IF THIS DOES NEED TO GO TO, TO JUNE BOARD.
UM, BUT WE, WE NEED THE STEPS TO GET IT THERE.
I THINK BEFORE WE ADJOURN TODAY.
WELL, MY, MY VOTE COUNTING IS THAT WE ARE, WE, WE NEED TO GET IT DONE AS SOMETHING TO THE, IN ORDER TO GET THAT DATE IN WHICH, UH, FOLKS HAVE TO START MEETING THE PREFERRED REQUIREMENTS, UH, LOCKED DOWN, UM, FOR FUTURE UNITS, WE NEED TO GET THIS DONE
[03:25:02]
AS SOON AS POSSIBLE BECAUSE EVERY TIME WE DELAY IT, FOLKS PUSH THOSE DATES OUT, WHICH IS VERY FRUSTRATING.BUT, UM, FIRST STOP THE BLEEDING.
I, I, I GUESS ONE OF THE THINGS WE CAN DO, UM, JUST TO, WHILE I'M TALKING TO THE, WE CAN, WE CAN FILE THE CURRENT, 'CAUSE I, I DIDN'T, I MEAN PEOPLE DON'T AGREE WITH EVERYTHING THAT'S IN THESE COMMENTS, BUT I DIDN'T SEE HEAR THAT MUCH THAT FOLKS THINK WE, UH, NEED TO CHANGE OTHER THAN THE POLICY QUESTIONS THAT WE JUST TALKED ABOUT.
AND SO, UM, WE CAN GO AHEAD AND FILE AS OFFICIAL COMMENTS THESE, UM, BASICALLY WHAT'S ON THE SCREEN IN FRONT OF US HERE AND THEN THAT, THAT WOULD THEN FORM THE BASIS FOR, UM, EDITS.
YOU'D, YOU'D HAVE THAT OFFICIALLY IN ORDER TO BE ABLE TO MAKE KIND OF THE MINIMUM EDITS TO GET TO WHAT TECH WANTS TO DO IN TERMS OF POLICY QUESTIONS.
SO FROM A PRACTICAL, COMPLETELY A PRACTICAL STANDPOINT, THAT'S WHAT WE CAN DO.
AND WHEN COULD WE DO, BECAUSE WE WOULD WANT THAT FAIRLY EARLY NEXT WEEK, I THINK, TO GET THE REST OF THE LANGUAGE CHANGES THE HEAD OF A FRIDAY VOTE.
YEAH, THAT, THAT'S REALLY A MARKET ROLLS QUESTION.
ANN COREY, IF WE'RE JUST TRANSFERRING WHAT'S EXACTLY ON THE SCREEN AT THAT DOCUMENT? UM, YOU KNOW, WE COULD TRY TO GET IT BEGINNING OF NEXT WEEK.
AND THEN, SO FIRST WE WILL GET THE LANGUAGE IN FRONT OF US TODAY ON TO THE LAST TECH APPROVED VERSION WITH ALL THE RED LINES UNTIL COREY AND I GET THE NPRR THAT SAYS AFTER PRS APPROVES THAT WE DON'T HAVE TO HAVE RED LINES, UM, AND, AND OR, AND DOES THE TUTORIAL AND WORD FOR EVERYBODY.
SO WE'LL, WE'LL GET THAT EARLY NEXT WEEK AND THEN ERICA, SEE YOU IN THE QUEUE.
UM, BUT ARE WE LOOKING AT A COUPLE OF DIFFERENT OPTIONS FOR LANGUAGE, UM, OR POSSIBLY JOINT COMMENTERS WORKING WITH ERCO TO JUST MAKE SURE WE ARE NOT GOING REALLY FAR ASTRAY ON LANGUAGE? GO AHEAD, ERIC.
I DOUBLE MUTED AS MUCH AS POSSIBLE.
I WANNA INCORPORATE, UM, THIS LANGUAGE, BUT IN ORDER TO GET SOMETHING TO, IN A TIMELY FASHION TO T I'M GONNA HAVE TO START WORKING, YOU KNOW, IN 30 MINUTES FROM NOW.
UM, SO I'M HAPPY TO, YOU KNOW, TALK TO ANYONE AT ERCOT THIS WEEKEND THAT IS ALSO WORKING THIS WEEKEND IN ORDER TO MINIMIZE DIFFERENCES.
BUT I'M JUST GONNA HAVE TO MOVE QUICKLY.
I THINK SOME, ALTHOUGH I WANNA MAKE AS FEW CHANGES AS POSSIBLE TO THIS, I'M NOT SURE THAT IT'S NECESSARILY MINIMAL TO THIS.
SO, LIKE FOR EXAMPLE, THE STUFF THAT'S ON THE SCREEN RIGHT NOW, I DON'T KNOW WOULD BE IN THERE BECAUSE, EXCEPT FOR THE SOFTWARE PIECE, RIGHT? SO THERE, THERE MIGHT BE THINGS TO REMOVE IF THIS STUFF IS ADDED AND THAT WOULD ADD TO, RATHER THAN TAKE AWAY FROM THE CHANGES TO THE TAC REPORT.
BUT THAT SAID, I THINK I HAVE THE EXACT SAME GOAL AS EVERYONE ELSE, WHICH IS TO MAKE IT AS EASY AS POSSIBLE TO COMPARE THESE DOCUMENTS.
AND THAT WOULD BE MY OBJECTIVE.
SO THAT COULD INCLUDE ADDING COMMENT BOXES AND THINGS TO POINT THINGS OUT.
AND I ALSO SEE, RICHARD, YOU'VE GOT YOUR HAND UP.
I DID, BUT I WANT YOU TO FINISH FIRST.
I, I THINK I FINISHED WHAT I WAS SAYING.
UM, I, YOU KNOW, IT'S A LOT OF MOVING PIECES HERE AND, UH, I WOULD'VE FAILED IN MY JOB IF I DON'T MAKE IT AS EASY FOR TAC AND ERCOT TO UNDERSTAND THE CHANGES.
SO WE NEED TO GET AS CLOSE AS WE CAN AND I'M, I'M HAPPY TO TALK TO ANYONE AT ANY TIME THIS WEEKEND AS, AS WE WORK, UM, ON GETTING THINGS WRITTEN IN ORDER TO MINIMIZE THE CONFUSION FOR NEXT WEEK AND MAKE IT AS EASY AS POSSIBLE TO UNDERSTAND THE CHANGES.
[03:30:03]
OKAY.LET'S, LET'S HEAR FROM RICHARD.
SORRY, I DIDN'T REALIZE YOU HAD YOUR HAND UP.
OR RICHARD, YOU KNOW WHAT, IT'S OKAY.
I KEEP THINKING I'M GONNA HAVE A GOOD QUESTION, BUT IT'S JUST GONNA DRAG IT OUT,
WELL YOU ALWAYS HAVE GOOD QUESTIONS AND COMMENTS, SO, UM, I HOPE, YOU KNOW, YOU CAN ASK.
SO ER, I I THINK I'D LIKE TO HEAR FROM ERCOT, UM, AND JUST TO MAKE SURE WE WERE ALL COMFORTABLE WITH WHAT WE'RE DECIDING TO MOVE FORWARD BECAUSE I, YOU KNOW, AS I'VE SAID A LOT OF TIMES WE'RE, WE'RE LOOKING TO TAKE A VOTE NEXT FRIDAY.
DAN, ANY FINAL THOUGHTS ON, ON WHAT YOU'D LIKE TO, TO SEE GOING FORWARD? YEAH, SO I, I GUESS, UM, THE, UM, WHEN WE, UM, I MEAN YOU CAN I GUESS LOOK AT, LOOK AT B LITTLE, I, LITTLE THREE I, SO FORTH, THOSE THINGS.
UM, I MEAN THOSE ARE, THOSE ARE REALLY THE THINGS THAT WE'RE TALKING ABOUT, UH, INCREMENTALLY, UM, THERE, WHICH CAN MAKE A BIG DIFFERENCE IN WHETHER IT TRIPS OR NOT, BUT NOT, UM, YOU KNOW, THEY'RE NOT THE CO EQUAL TO THE COST OF PUTTING IN A WHOLE INVERTER.
SO, UM, IF, IF DAC DECIDES TO GO DOWN THIS PATH, I'M THINKING WHAT WILL PROBABLY HAPPEN IS THAT, AND, AND, AND I, I, YOU KNOW, UM, THIS IS SUBJECT TO CHANGE, BUT I SUSPECT WE WOULD STILL BE OPPOSED TO IT, BUT IT, BECAUSE WE'D RATHER GO AHEAD AND RESOLVE IT WHERE THE, IT'S, IT'S CLEAR WHERE WHETHER FOLKS HAVE TO DO THOSE THINGS OR NOT, WHERE WE IDENTIFY A RELIABILITY PROBLEM, UH, IN THIS, IN THIS NOTE OR WITHOUT HAVING TO START A NEW ONE.
BUT, SO I SUSPECT WHAT WE WOULD DO, AND THIS IS, YOU KNOW, I HAVEN'T TALKED TO LEGAL OR ANYTHING LIKE THAT, BUT WE WOULD, UM, WANT TO, UM, IF, IF, IF, IF TECH ENDORSES THIS AND IF THE W WOULD ASK THE BOARD AS A MINIMUM TO DO IS, UM, REQUIRE A FOLLOW UP, UM, NOER TO RESOLVE HOW TO TREAT THOSE, UH, THOSE ISSUES THAT WOULD REQUIRE THE EXCEPTION PROCESS, THAT WOULD REQUIRE THE, UM, THOSE KIND OF, UM, COST EFFECTIVE SOLUTIONS TO A RELIABILITY PROBLEM, YOU KNOW, AND DECIDE HOW WE WOULD'VE TO DO THOSE.
AND SO I, YOU KNOW, I, THERE'S A LOT OF IFS IN THAT, WHAT I JUST SAID, BUT I, I THINK THAT WOULD BE THE PATH WE PROBABLY GO DOWN.
COULD WE ATTACK, DECOUPLE OR CARVE THAT OUT AND THEN, YOU KNOW, AS, AS PART OF IN THE PREAMBLE OF THE OTHERWISE INDICATE THAT WE WOULD BE FILING AN URGENT NOER TO FOLLOW THAT.
I DON'T SEE ANY COMMENTS ON THAT SUGGESTION.
UM, ALRIGHT, SO WHERE, SORRY, KATE, ONE MORE, GO AHEAD.
ONE MORE THING, JUST FOR FULL TRANSPARENCY.
I MEAN, IT MAY BE THAT WE GO BACK AND, AND TALK ABOUT THIS AND DECIDE THAT WE ARE, WE WOULD, UM, UM, ASK THE BOARD TO DO SOMETHING DIFFERENT THAN WHAT I JUST SAID.
FULLY TRANSPARENT THAT THIS IS JUST ME THINKING ON THE FLY AND WE'LL, WE'LL NEED TO TALK ABOUT IT INTERNALLY.
SO, SO WE DON'T KNOW HOW ERCO FEELS ABOUT THAT APPROACH YET.
WHAT DO, WHAT WOULD TECH MEMBERS LIKE TO SEE LAST CALL? UM, WHAT, WHAT WOULD WE LIKE TO SEE MOVING FORWARD FOR FRIDAY?
[03:35:03]
THE PLAN IS THAT ERCOT WILL FILE WHAT'S IN FRONT OF US IS KIND OF A CLEAN EDIT ON, ON TOP OF EVERYTHING THAT WAS REDLINED FOR THE ATTACK APPROVED VERSION.UM, JOINT COMMENTERS WILL WORK ON SOMETHING SIMULTANEOUSLY WITH THE PROMISE TO, TO MAKE THE CHANGES AS SIMPLE AS POSSIBLE.
UM, WHERE IT SEEMS LIKE THERE'S SOME AMOUNT OF TAX SUPPORT FOR THE, FOR, FOR THE DATE TO WHICH THIS AFFECTS NEW RESOURCES TO BE AUGUST ONE OF THIS YEAR.
AND THEN SOME CONCEPT AROUND MAXIMIZE CAPABILITIES, BUT DECOUPLE THE EXEMPTION PROCESS.
AND THEN THE DATE RELATED TO THAT MAXIMIZED CAPABILITIES WOULD BE JUNE 1 26.
UM, BUT WE WE'RE NOT SURE FOR WHAT OUR COS POSITION ON THAT APPROACH IS YET.
UM, IF WE DO WANT THIS TO THE JUNE BOARD, WE DO HAVE TO HAVE A LANGUAGE VOTE NEXT FRIDAY.
I, THE QUEUE IS EMPTY, SO I, I THINK WE CAN WRAP UP THERE UNLESS THERE'S, THERE'S ANY FINAL THOUGHTS.
ALL RIGHT, WELL THANK YOU EVERYBODY FOR ALL THE TIME WE'VE SPENT ON, ON THIS.
AND WE WILL LOOK FOR, UM, THAT FILING FROM ERCOT AND THEN A SUBSEQUENT FILING FROM WHITE COMMENTERS, I BELIEVE.