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[00:00:04]

OKAY, I THINK WE CAN GO AHEAD AND GET STARTED.

UM, IT'S JANUARY 7TH.

THIS IS A SPECIAL TECH WORKSHOP.

IT'S NOT A MEETING.

SO WE'RE, WE'RE NOT VOTING.

UM, AND IT'S A STAKEHOLDER LED WORKSHOP ON THE DRRS DISPATCHABLE RELIABILITY RESERVE SERVICE.

CAN WE

[Antitrust Admonition]

GET THE ANTITRUST? ALRIGHT, TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY, PARTICIPANTS IN ACTIVITIES SHOULD REFRAIN FROM PROPOSING ANY ACTION OR MEASURE THAT WOULD EXCEED OR CUTS AUTHORITY UNDER FEDERAL OR STATE LAW.

AND THERE IS MORE INFORMATION ON THE WEBSITE.

SO WE ARE GOING TO START, UM, WITH A, A TIMELINE THAT, THAT TAC LEADERSHIP AND ANN'S GROUP PUT TOGETHER.

AND THEN WE WILL GO TO ERCOT PRESENTATIONS.

UH, THE, THE AGENDA HAS SORT OF THE DIFFERENT SECTIONS OF THE PRESENTATIONS.

I'M HOPING TO WRAP THIS UP AROUND 4, 4 15, BUT MAYBE WE CAN CHECK IN AT 3 45 OR SO AND, AND SEE WHERE WE ARE.

I KNOW IT'S A LONG DAY FOR PEOPLE TOO, AFTER WMS, UM, AND THEN I REALLY WANNA MAKE SURE AT THAT TIME THAT WE NAIL DOWN NEXT STEPS.

SO, ON THIS SLIDE, WE JUST WANTED TO PUT TOGETHER THE, THE TIMELINES SO EVERYBODY KNOWS WHAT WE ARE WORKING WITH.

UM, AND I THINK WE CAN FILL THIS OUT WITH MORE DETAILED GOALS IF WE WOULD LIKE.

UM, BUT WE, WE ARE LOOKING AT A COUPLE OF TIGHT TIMELINES.

THE BOARD HAS DESIGNATED THIS AS A BOARD PRIORITY, MEANING THEY WILL WANT TO VOTE ON IT IN JUNE, AND THEY WILL EXPECT UPDATES AT THE FEBRUARY 9TH AND APRIL 20TH MEETING.

THAT IS PART OF WHY WE ARE DOING THIS WORKSHOP SO EARLY, IS BECAUSE AN UPDATE WILL BE EXPECTED IN LESS THAN A MONTH.

SO, SO TODAY'S WORKSHOP ONE.

UM, WHEN, WHEN WE SAY WORKSHOP, IT'S, UH, SAME AS IT IS TODAY.

TAC WORKSHOP, NON-VOTING.

TODAY WE'RE GONNA FOCUS ON ERCOT REVIEWING THE NPR.

AT THE END OF THE DAY, I THINK WE'LL HAVE SOME QUOTE UNQUOTE HOMEWORK.

UM, PROBABLY THINGS FOR ERCOT TO TAKE BACK.

I THINK AT THAT TIME, WE WILL WANT INTERESTED STAKEHOLDERS WITH A, A POINT OF VIEW TO, TO PLAN ON FILING COMMENTS BEFORE THE NEXT WORKSHOP.

UM, NEXT WORKSHOP IN, IN ABOUT A MONTH.

UH, REVIEW THOSE COMMENTS FROM, FROM OUR KIND OF STAKEHOLDERS.

AND I SHOULD NOTE, I BELIEVE WE DID GO AHEAD AND SCHEDULE THESE WORKSHOPS, UM, FOR, FOR THE TIME WE'RE MEETING TODAY.

SO FEBRUARY THROUGH MAY, WE HAVE WORKSHOPS SCHEDULED FOR AFTER WMS. I KNOW THAT'S A LONG DAY, BUT IT WAS SORT OF THE, THE BEST WE COULD DO.

UH, THEN WE WOULD HAVE A BOARD UPDATE AT THE FEBRUARY BOARD WORKSHOP THREE.

I THINK AFTER WORKSHOP ONE AND TWO, WE'LL HAVE A BETTER IDEA OF MORE CONCRETE GOALS.

UM, WORKSHOP FOUR IN APRIL.

I THINK WE WILL NEED TO START THINKING ABOUT, UM, WHETHER WE NEED EXTRA VOTING MEETINGS ON THIS.

UM, I, I WOULD NOTE THAT THE, THE WAY THE SCHEDULE IS RIGHT NOW TO GET IT TO JUNE BOARD, WE'D BE LOOKING AT, AT THE LATEST, THE MAY 20TH TAC MEETING AND THE MAY 13TH PRS MEETING.

THE ISSUE THERE IS, THERE'S ONLY A WEEK IN BETWEEN THOSE.

SO IF FOR SOME REASON AT THE, THE FIRST PRS MEETING, THIS IS A SUBSTANTIVE VOTE IS ATTEMPTED, IT CAN'T BE WORKED OUT.

WE DON'T HAVE TIME FOR AN EXTRA PRS.

SO THAT'S WHY I THINK PEOPLE SHOULD BE THINKING ABOUT, UH, PERHAPS A VOTE ON THE, THE APRIL PRS.

SO I'LL LET PEOPLE TAKE THIS IN.

UM, WE CAN TAKE ANY QUESTIONS ON, ON THIS IF THERE ARE ANY OR, OR COMMENTS.

MARTHA IS NODDING AT ME, SO I SHOULDN'T, THAT MEANS I'M CALLED ON.

UH, I WAS TRYING TO PULL UP THE QUEUE AND I DIDN'T SEE ANYTHING IN IT, AND I DIDN'T USE MY OWN EYES TO LOOK AT YOU.

UH, THANK YOU.

MARK DREYFUS FOR THE CITY OF EASTLAND.

I'M, I'M JUST THINKING THAT MAYBE WE NEED TWO TIMELINES FOR CONSIDERATION.

UM, I THINK THIS IS A PERFECTLY ADEQUATE TIMELINE FOR NPRR 1309.

I, I DON'T SEE THAT AS BEING PARTICULARLY CONTROVERSIAL.

AND, AND IT SHOULD BE A STRAIGHTFORWARD TO GET OUT ON THIS SCHEDULE.

UH, 1310 MAY BE A DIFFERENT ISSUE AND MAYBE A, A SECOND TIMELINE THAT WOULD GET THAT OUT AROUND LATE FALL OR THE END OF THE YEAR, KIND OF CONSISTENT WITH SOME ACTIVITIES THE COMMISSION HAS UNDERWAY THAT, THAT IT MIGHT FIT WITH.

THANKS.

YEP.

I THINK, YOU KNOW, MY PLAN THAT I KNOW I LAID OUT MAYBE AT A PREVIOUS, ACTUALLY AT THE PRS WAS TO, TO START WITH DISCUSSING BOTH OF THESE, BUT TO SEPARATE, IF, IF 1310 BOGS US DOWN, I WOULD CONSIDER, YOU KNOW, IF, IF WE DON'T WANT 1310

[00:05:01]

ON THIS TIMELINE, THAT WE CONSIDER GOING BACK TO PRS BECAUSE WHAT, WHAT PRS DID WAS REF OR TABLE BOTH OF THESE AT PRS.

SO IF WE THINK 1310 IS GOING TO TAKE, YOU KNOW, NINE MONTHS OR, OR A YEAR, 18 MONTHS, WE CONSIDER HAVING PRS SEND THAT TO WMS AND DO THE NORMAL STAKEHOLDER PROCESS.

UNLESS WE WOULD LIKE TO KEEP HAVING TECH WORKSHOPS ON 1310 FOR THE NEXT NINE OR 18 OR HOWEVER MANY MONTHS.

UM, I'M, I'M CERTAINLY OPEN TO THAT, BUT SORT OF THE, THE TECH WORKSHOP APPROACH, I THINK WAS BECAUSE OF THE EXPEDITED TIMELINE.

SO I, I THINK IF WE GET TO THAT DECISION POINT, I THINK WE BRING PRS INTO THAT DISCUSSION AND SEE IF THEY'D RATHER HAVE 13, 10 STAY KIND OF IN THE WORKSHOP APPROACH, BUT SLOWER, BUT, OR, OR GO TO THE NORMAL KIND OF WMS AND WIM AND SO ROUTE.

I THINK, I THINK THAT APPROACH SOUNDS FINE DOWN HERE AT THE END OF THE TABLE.

THANK YOU, MARK.

DIANA, THANK YOU CAITLYN.

DIANA COLEMAN WITH CPS ENERGY.

SO, JUST WANTED TO ADD A NOTE.

AT THE DECEMBER PRS, WE VOTED URGENCY ON BOTH 1309 AND 1310, AND THE THINKING BEHIND THAT VOTE WAS THE, THE IMPORTANCE OF THIS INITIATIVE AND THIS PRODUCT THAT WE'RE LOOKING AT.

IT WASN'T THAT IT SHOULD BE AN EITHER OR, OR THAT THEY SHOULD BE ON THE SAME TIMELINE.

WE KNOW THAT THERE'S STATUTORY REQUIREMENTS FOR THIS THAT WE ARE TRYING TO MEET.

AND SO JUST WANTED TO CLARIFY THAT 1309 AND 1310 DOESN'T HAVE TO BE ON THE SAME TIMELINE, AND THAT'S NOT WHAT THE VOTE FOR URGENCY ON BOTH OF THOSE ITEMS WERE FOR DECEMBER.

THANKS, DIANA.

UM, GO AHEAD, BOB HILTON.

YEAH, JUST AS A NOTE, I THINK YOU'RE RIGHT.

THE END GAME MAY NOT BE THE SAME, BUT WE NEED TO TREAT THE BEGINNING THE SAME.

'CAUSE THEY'RE BOTH BOARD PRIORITY.

UH, THEY DIDN'T SEPARATE THAT.

AT LEAST THAT'S WHAT IT'S SHOWING HERE.

IT'S ONLY 1309 IS BOARD PRIORITY.

RIGHT.

THEN ERCOT NEEDS TO FIX THEIR WEBSITE 'CAUSE THEY'VE GOT 13 0 8, 13 0 9 BOTH LISTED AS BOARD PRIORITY.

I'M TALKING LIKE 1308.

SORRY.

SORRY.

YEAH, I, I THINK, UM, THE URGENCY VOTE.

YEAH, 10 10 ISN'T, YEAH.

YEAH.

SORRY.

10 IS NOT A BOARD PRIORITY.

I THINK THE URGENCY VOTE, DIANA, I WAS OFF ONE.

SPEAKING ABOUT, MAY HAVE BEEN LIKE SYMBOLICALLY, SOME STAKEHOLDERS WOULD LIKE IT TO BE ON THE SAME LEVEL OF PRIORITY.

AND I THINK THAT'S WHY I WOULD SUGGEST IF WE GET TO THAT DECISION POINT, TAKE TAKING IT TO PRS, TAKING IT TO A VOTING MEETING SO PEOPLE CAN VOTE ON WHETHER THEY, YOU KNOW, WANT TO REFER THAT TO WMS KNOWING THAT THAT WOULD TAKE SOME LONGER AMOUNT OF TIME.

THANKS, BOB.

IT'S OKAY.

AS LONG AS YOU KEEP LISTENING TO ANNE .

THAT'S OKAY.

ALL RIGHT.

ANY OTHER QUESTIONS OR COMMENTS ON THE TIMELINE? OKAY.

I'M, I'M, WE'RE BEING A LITTLE BIT MORE PROACTIVE ABOUT THIS.

UM, I'M, I'M HAPPY FOR, FOR FEEDBACK ON IT.

YOU KNOW, AS, AS BOB NOTED, 1308 IS ANOTHER BOARD PRIORITY.

WE HAVE SET FOR JUNE.

WE ARE, WE'RE NOT DOING THIS APPROACH.

'CAUSE I THINK, UM, YOU KNOW, MAY MAYBE THAT THAT'S BETTER SUITED FOR THE, THE NORMAL APPROACH FOR THE TECHNICAL EXPERTS.

BUT, YOU KNOW, WE'RE, WE'RE OPEN TO FEEDBACK ON THE APPROACH FOR HOW WE'RE TREATING THIS BOARD PRIORITY AND PRR.

OKAY.

SO I, I WILL HAND IT OVER TO GORD, WHO I THINK WILL HAND IT OVER TO RYAN.

UM, I DON'T THINK I'LL INTERVENE AS ERCOT HANDS IT OFF TO DIFFERENT SUBRU MATTER EXPERTS, BUT I, I THINK IT'LL WORK BETTER IF I CALL THE QUEUE IF IT'S OKAY WITH YOU GUYS.

I THINK THE, THE PEOPLE PRESENTING WILL BE, YOU KNOW, DOING THE ARROWS THEMSELVES.

UM, SO I THINK WE CAN JUST GO AHEAD AND GET STARTED.

YEAH, THAT WORKS.

THANKS VERY MUCH, CAITLIN.

GOOD AFTERNOON.

THIS IS GORDON DRAKE FROM ERCOT.

WANTED TO WELCOME EVERYBODY TO THE WORKSHOP TODAY.

THIS IS, UH, I AM NOT SURE THAT I HAVE ACCOUNT ON HOW MANY DRS WORKSHOPS WE'VE HAD, BUT THIS IS ONE IN A, IN A SERIES, BUT PERHAPS A, UH, A NEW CHAPTER IN OUR, IN OUR CONVERSATIONS AROUND DRS THAT THE LAST TIME THAT WE SPOKE ABOUT DRS WOULD'VE BEEN AT THE DECEMBER 17TH WORKSHOP, WHERE WE WERE FOCUSED MORE ON THE, UH, AURORA ENERGY RESEARCH REPORT AND THEIR, THEIR MODELING, WHICH INCLUDED VARIATIONS

[00:10:01]

OF, OF DR.

S.

AND SO, AS WE, AS WE PIVOT TODAY TO BE FOCUSING ON NPRS 1309 AND 1310, UH, IT'S AN OPPORTUNITY FOR US TO DELVE INTO THE, THE MECHANICS OF, OF HOW THIS WOULD WORK IN, IN PROTOCOL, UH, AND, AND WHAT ERCOT IS, IS PROPOSING, UH, IN THE SPECIFIC LANGUAGE THAT, THAT WE PUT FORWARD.

THERE'LL BE A FEW THINGS THAT, THAT WE WANT TO, TO COVER TODAY.

UM, AND IN PARTICULAR FOR, FOR THOSE WHO, UH, HAVE NOT PARTICIPATED IN ALL OF OUR PAST WORKSHOPS, A BIT OF A, A RECAP AS TO WHAT BROUGHT US TO HERE.

AND, UM, SO THE, THE BACKGROUND AND THE LEGISLATIVE IMPERATIVE AND, AND THE WORK THAT WE'VE DONE, UH, THAT HAS, HAS BROUGHT US TO, UH, NPRS 1309 AND 1310.

UM, AND, AND THEN WE'LL, WE'LL BEGIN A, A, A DEEP DIVE INTO THE, UH, THE MECHANICS IN 1309 AND 1310.

TALK ABOUT THE, SOME, SOME EXAMPLES AND HAVE A, A CHANCE TO, TO WORK THROUGH SOME OF THAT TO HOPEFULLY BRING SOME UNDERSTANDING TO, TO WHAT WE'VE, UH, TO WHAT WE'VE LAID OUT IN THE END.

PRRS, UM, CERTAINLY WELCOME, UH, QUESTIONS, UH, HELPING TO, TO UNDERSTAND AND CLARIFY.

AND, UH, AND, UH, THOUGH WE'RE, WE'RE HERE SHARING INFORMATION, WE'RE ALSO HERE TO, UH, TO HEAR INFORMATION AND HEAR INPUT AS WELL.

UM, SO WITH THAT, UH, WANTED TO THANK YOU AGAIN FOR, UH, FOR YOUR PARTICIPATION IN THE WORKSHOP.

AND I'LL TURN IT OVER TO RYAN KING FROM ERCOT TO, TO STEP US THROUGH THE, UH, UH, CONTENT IN THE PRESENTATION.

THANK YOU VERY MUCH, GORD.

IF WE CAN GO TO THE NEXT SLIDE.

SO I'LL BRIEFLY COVER THE, UH, THE SCOPE OF THE AGENDA TODAY.

SO WE'LL TALK A LITTLE BIT ABOUT THE, UH, THE PURPOSE FOR WHY WE'RE HERE TODAY.

UM, REALLY FOCUSING IN, AS GORD MENTIONED ON THE, THE MECHANICS OF THESE NPRS UNDERSTANDING, UM, WHAT THEY SHARE IN COMMON, HOW THEY WORK, UH, AS WELL AS SOME OF THE, UM, SPECIFIC DIFFERENCES BETWEEN NPRS 1309 AND 1310.

UM, JUST FOR CONTEXT THAT I THINK IT IS IMPORTANT TO ALWAYS REFER BACK TO THE STATUTORY, UH, GUIDANCE ARE THE REQUIREMENTS THAT, THAT INFORMS THESE NRS A LITTLE BIT ABOUT THE DESIGN EVOLUTION, AND THEN WE'LL GET INTO THE REVISION REQUESTS THEMSELVES.

FOCUS IN ON SOME OF THE FEATURES OF OH NINE AND 10, UH, SOME OF THE UNIQUE DESIGN FEATURES RESPECTIVE TO EACH OF THOSE NRS.

UM, THERE WILL ALSO BE AN OPPORTUNITY FOR A COMPARISON OF AURORA'S D-R-S-A-S PLUS AND NPR 1310, AND THEN WE'LL WANT TO MAKE SURE THAT WE HAVE TIME FOR ADDITIONAL DESIGN CONSIDERATIONS AND NEXT STEPS, OF COURSE, SLIDE.

SO AGAIN, UM,

[Purpose]

JUST REITERATING THE, THE, THE PURPOSE OF THIS SERIES OF WORKSHOPS.

UH, I, WE EXPECT THAT THEY WILL COVER A NUMBER OF ISSUES IN SOME LEVEL OF DETAIL, AND THEY'LL BE INFORMED BY SOME OF THE DISCUSSION TODAY.

BUT THE FOCUS OF THIS WORKSHOP IS REALLY ON, UH, GETTING THROUGH THE DRS CORE DESIGN AND OPTIONALITY THAT'S REFLECTED IN THESE TWO NRR.

SO WE'LL SPEND A LITTLE BIT OF TIME GOING THROUGH SOME OF THE, THE COMMON FEATURES OF THE NPRS THAT IS LOOKING AT, UM, HOW THEY, UH, HOW DRS IS AWARDED IN DAM AND REAL TIME, THE, UH, RELIABILITY UNIT COMMITMENT, UH, DEPLOYMENT AND AVAILABILITY CHECK, UH, SOME OF THE CONSTRAINTS, UH, THE DEMAND CURVE FOR, UH, BOTH NPR R AS WELL AS THE SETTLEMENT.

UM, AND THEN WE'LL GET INTO SOME MORE OF THE UNIQUE FEATURES OF THESE TWO NPR R AS NOTED, WE'LL HAVE SOME TIME ALSO TO ENGAGE IN THE, UH, UH, AURORA ENERGY RESEARCHES, DRS AN ANCILLARY SERVICE PLUS AND NPR 1310.

ALRIGHT, SO

[DRRS Statutory Requirements]

I DO THINK IT IS IMPORTANT, UH, TO REITERATE THAT THIS IS AN ANCILLARY SERVICE, SOMEWHAT UNLIKE THE OTHERS, IN THE FACT THAT IT IS ACTUALLY, UM, UH, GOVERNED BY A, A STATUTORY REQUIREMENT.

AND SO IT'S ALWAYS IMPORTANT TO TAKE HEAT OF THAT AND MAKE SURE THAT AS WE'RE GOING THROUGH THIS DESIGN PROCESS, UM, THAT WE'RE REFLECTING THOSE REQUIREMENTS AND, AND DOING EVERYTHING WE CAN TO MAKE SURE THAT THAT DESIGN REALIZES THAT.

UM, SO IF YOU'VE BEEN IN ONE OF OUR MANY WORKSHOPS, THIS IS CERTAINLY NOT A NEW SLIDE TO YOU, BUT, UM, I'LL JUST HIGHLIGHT SOME OF THE KEY REQUIREMENTS AT LEAST AS IT PERTAINS TO THE NPRR.

UH, FIRST AND FOREMOST, THIS IS AN ANCILLARY SERVICE.

UM, IT IS, UH, UH, SOMETHING THAT IN SERVICE THAT IS PROCURED IN BOTH THE DAY AHEAD AND REAL TIME.

AND IT IS MEANT TO ACCOUNT FOR MARKET UNCERTAINTY.

UM, IN TERMS OF SOME OF THE CRITERIA OF THIS SERVICE, THERE IS A, A TWO HOUR RAMP AND A FOUR HOUR DURATION THAT IS REFLECTED IN BOTH OF THE NRS, UM, THE ABILITY TO ADDRESS, UH, IN THE WORDS OF THE, OF THE STATUTE, THE INTER HOUR OPERATIONAL CHALLENGES.

AND THEN, UH, CRITICALLY THERE IS THIS UNIQUE FEATURE

[00:15:01]

THAT THE, UH, AMOUNT OF DRS IS MEANT TO KIND OF OFFSET THE NEED FOR RELIABILITY UNIT COMMITMENT.

AND WE HAVE, UH, FOUND A WAY TO REALIZE THAT AS PART OF THE DESIGN OF NPRS 13 NINE AND 1310.

ALRIGHT,

[DRRS Design Evolution]

UH, CONTEXT ALSO IMPORTANT HERE.

SO THIS HAS UNDERGONE SOME DESIGN EVOLUTION OVER TIME.

UM, INITIALLY, AND I'M, I'M KIND OF STARTING, UH, AT THE POINT WHERE WE DE DESIGNED DRS AS A STANDALONE ANCILLARY SERVICE.

THERE WERE SOME ANTECEDENT, UH, DISCUSSIONS PRIOR TO THAT, BUT I'LL KIND OF FOCUS ON THAT.

OUR INITIAL OFFERING IN NPRR 1235 WAS REALLY FOCUSED ON, UH, A MEANS OF ENSURING THAT, UH, WE COULD GET THIS, THIS, THIS RUCK, UH, OFFSET REALIZED.

SO THE ORIGINAL OFFERING UNDER 1235 ENVISIONED THIS BEING AN OFFLINE SERVICE ONLY AND DEVELOPED A FRAMEWORK THAT IT COULD BE DEPLOYED VIA THE RUCK ENGINE.

UM, AND IT WAS REALLY FOCUSED SOLELY ON THE, THE, WHAT I WOULD SAY IS THE OPERATIONAL UNCERTAINTY MANDATE OF THE, OF THE STATUTE.

UM, FAST FORWARD TO SIX MONTHS OR SO, THE, UH, PUBLIC UTILITY COMMISSION PROVIDED GUIDANCE TO ERCOT, UM, SPECIFICALLY TO DESIGN DRS WITH FLEXIBILITY TO MEET SOMETHING BEYOND, UH, JUST AN OPERATIONAL FORECAST UNCERTAINTY SHOULD SUCH A DECISION BE MADE IN THE FUTURE.

AND SO THAT BECAME THE FOCUS OF A NUMBER OF DISCUSSIONS AT THE SAWG, AT WMS AND THROUGH A SERIES OF WORKSHOPS, UM, WE KIND OF WENT THROUGH, UH, SOME OF THE DESIGN CONCEPTS LOOKING AT, UH, WHICH RESOURCES BE ELIGIBLE FOR THIS.

UM, THINKING THROUGH THE MECHANICS OF HOW COULD WE PROCURE SOMETHING LIKE THIS IN REAL TIME WHILE STILL RESPECTING THE, THE RUCK DEPLOYMENT NATURE OF THE FRAMEWORK.

UM, WE ALSO LOOKED AT, UH, SOME POTENTIAL, UH, ADDITIONAL CONCEPTUAL DESIGNS THAT WERE RAISED WITH THE, UH, MARKET MONITOR AND HUNT ENERGY NETWORK.

THE KIND OF FINAL OUTCOME, IF YOU WILL, OF THOSE DISCUSSIONS IS REFLECTED IN THE TWO NPR THAT WERE FILED IN NOVEMBER OF LAST YEAR.

THAT'S EMBODIED IN 1309 AND 1310.

UM, BOTH OF THESE MEET ALL THE STATUTORY STATUTORY REQUIREMENTS, UH, UNDER PIRA.

AND FINALLY IN DECEMBER, 2025, UH, AURORA ENERGY DID, UH, DEVOTE, UH, SOME TIME AT A WORKSHOP TO, UH, PRESENT ITS ASSESSMENT OF MARKET DESIGN IMPACTS UNDER DIFFERENT LOAD GROWTH SCENARIOS.

AND, UH, I WON'T SPEND TOO MUCH TIME ON THAT, AS I KNOW WE DO HAVE SOME TIME ALLOTTED TO, TO KIND OF ENGAGE IN THAT FURTHER.

OKAY.

WHY DON'T WE TAKE THE COMMENTS HERE? 'CAUSE I THINK THE SLIDES IN THIS SECTION ARE SORT OF TOPICALLY DIFFERENT.

UM, SLIDE TO SLIDE.

KATIE.

THANKS.

AND RYAN, THANK YOU FOR THE LAYOUT SO FAR.

UM, I'M SORRY I DIDN'T CATCH YOU RIGHT DURING, WHEN YOU WERE TALKING ABOUT THE STATUTORY LANGUAGE, BUT YOU REFERRED TO 39 1 59 C AND E, BUT I FEEL LIKE THAT WHOLE SECTION SHOULD BE READ IN CONCERT TOGETHER JUST SO FOLKS AREN'T LEFT WITH THE IMPRESSION THAT THERE'S NO STATUTORY BACKUP FOR 1310.

THERE IS, IF YOU GO BACK INTO B WHERE IT TALKS ABOUT, UM, YOU KNOW, ESTABLISHING ANCILLARY OR RELIABILITY SERVICES NECESSARY TO, UM, ENSURE APPROPRIATE RELIABILITY DURING STREAM HEAT AND COLD WEATHER CONDITIONS, UM, TIMES WHERE THERE'S LOW NON DISPATCHABLE POWER PRODUCTION.

I MEAN, THAT'S JUST THROUGHOUT HERE.

AND THEN THE OTHER SECTION THAT TALKS ABOUT THAT PERIODIC RELIABLE STANDARD.

SO IT ALL TIES TOGETHER HOLISTICALLY TO BACK UP WHY WE HAVE 1310 FOR THE RESOURCE ADEQUACY PIECE.

THANKS, KATIE.

MATT, DID YOU WANT TO RESPOND TO THAT? HEY, YES, MATT ARTHUR FOR ERCOT.

UM, WE APPRECIATE THOSE COMMENTS AND, UM, DO AGREE THAT, YOU KNOW, THE TWO SUBSECTIONS OF PUR 3 9 1 59, THAT ADDRESS TRS ARE THOSE SUBSECTIONS, DNE, AND OF COURSE, UH, FALL WITHIN THE SAME OVERARCHING SECTION OF 39.159.

BUT I THINK WHAT WE DO HAVE, UH, WE, WE DO WANT TO FOCUS ON THINKING ABOUT THOSE A LITTLE BIT SEPARATELY.

I THINK WE'VE RAISED BEFORE THAT C TALKS ABOUT, YOU KNOW, BASICALLY FIRM FUEL IN THERE, UH, THAT THEY COMMISSION SHALL ENSURE THAT THE, THE SERVICES PROVIDED UNDER B HAVE, UH, DUAL FUEL CAPABILITY OR FUEL SUPPLY ARRANGEMENTS, UH, ONSITE FUEL STORAGE.

SO THAT'S OBVIOUSLY JUST ONE OF THE SUBSECTIONS, BUT I THINK WE WANNA BE CAREFUL ABOUT, UM, UH, VIEWING THOSE COMPLETELY SYNONYMOUSLY AND, AND WOULD, UH, VIEW THE SUBSECTIONS.

D AND E IS KIND OF FALLING INTO THEIR OWN SUBSET.

SO JUST WANTED TO MAKE THAT, UH, CLEAR FROM OUR COST PERSPECTIVE ANYWAY.

OKAY.

I, I WOULD JUST ARGUE THAT EITHER WAY WE ARE, WE'RE GONNA HAVE TO CONSIDER THIS IN THE RELIABILITY STANDARD AND WHETHER OR NOT IT HELPS MAKE SURE THAT WE HAVE ADEQUATE SUPPLY.

SO WHETHER YOU BELIEVE THAT IT SHOULD BE DNE OR B THROUGH

[00:20:01]

E STILL GETS YOU TO THE SAME GOAL.

AND THAT'S WHY WE WANTED TO HAVE 13, 10, AND 1309 ON THE SAME LEVEL.

THANKS, KATIE.

THAT'S BOB HILTON.

YEAH, MINE'S ON THIS SLIDE.

JUST A I'LL, I'LL START THE ARGUMENTS HERE.

OKAY.

.

OKAY.

NOT REALLY AN ARGUMENT.

THAT'S, UH, ON, UH, THE, THE NOVEMBER, 2025, YOU SAID ERCOT SUBMITTED TWO NPRS 13 0 9, 13, AND 10 THAT MEET ALL THE REQUIREMENTS OF PURE 39 1 58 OR 1 59 DI DON'T THINK IT DOES BECAUSE IT EXCLUDES STORAGE WHAT 1309 DOES.

SO I'M NOT SURE THAT WE CAN SAY THAT.

I KNOW THERE'S REASONS IT'S NOT IN THERE, BUT I DON'T THINK THEY'RE STATUTORILY BECAUSE OF THE WAY THE WORDING, IF YOU GO BACK TO YOUR, YOUR, YOUR QUOTES BEFORE ON THE, THE, UH, SLIDE BEFORE IT JUST TALKS ABOUT DURATIONS.

IT DOESN'T TALK ABOUT TECHNOLOGIES.

AND I KNOW THAT 1309 IS EXCLUDING A TECHNOLOGY, SO THEREFORE I'M NOT SURE THAT'S AN ACCURATE STATEMENT.

SO I'LL LEAVE IT AT THAT.

UH, I KNOW THERE'S REASONS THAT IT'S NOT THERE THAT ARE THERE, AND WE'LL EVALUATE THAT AS WE MOVE THROUGH, BUT I JUST WANTED TO MAKE SURE THAT TO ME IS NOT AN ACCURATE STATEMENT.

OKAY.

AND NOW I SEE WE HAVE THE LANGUAGE ON THE SCREEN, WHICH IS HELPFUL.

OKAY.

ANDREW? YEAH.

ANDREW AMERS.

IMM UH, I HAVE A QUESTION THAT I SHOULD HAVE ASKED EARLIER ON THE TIMELINE STUFF.

SO BOTH OF THESE NPRS HAVE URGENCY.

DOES THAT MEAN THAT THEY COULD BE VOTED ON AT PRS NEXT WEEK AND THEN BEYOND THAT THEY WOULD GO TO? IS THAT THE FEBRUARY TAC? IN THEORY, YES.

BUT THAT COULD HAPPEN WITHOUT URGENCY.

WHAT THE URGENCY IS GETTING YOU AT PRS IS THE ABILITY TO SKIP THE, UM, IMPACT ANALYSIS.

SO WE, WE WON'T HAVE TO SEND IT TO APRIL PRS AND MAY PRS, IT CAN JUST GO TO MAY WITH, WITH LANGUAGE AND IMPACT ANALYSIS.

I'M SURE COREY OR ANN WILL STOP ME AT SOME POINT.

BUT MY, MY UNDERSTANDING OF THE PROCESS IS RIGHT, EVEN IF YOU REFER IT TO A SUBCOMMITTEE OR WORKING GROUP, SOMEBODY AT PRS CAN ALWAYS MAKE THE MOTION TO, TO VOTE ON SOMETHING.

SO REGARDLESS OF URGENCY, SOMEONE AT PRS IN FEBRUARY COULD MAKE THE MOTION TO VOTE ON IT.

I, I HOPE NOT, BUT , BUT THAT, THAT'S A THING THAT COULD HAPPEN.

OKAY.

UH, MAYBE A BETTER WAY TO ASK MY QUESTION FOR THIS TO BE AT THE JUNE BOARD.

WHAT IS THE LAST PRS MEETING AT WHICH IT WOULD NEED TO BE VOTED ON? DO YOU WANNA THROW THE, HOW HARD IS IT TO THROW THE TIMELINE BACK UP THERE? SORRY, I SHOULD HAVE ASKED THAT EARLIER, BUT IT'S A SECOND.

THE LAST PRS IS, IS MAY PRS.

BUT I DID WANNA NOTE WHY, WHY I'M ASKING TO BRING IT BACK UP IS THE, THE LAST PRS IS MAY PRS, AND THE LAST T IS MAY TAC.

THERE'S EXACTLY A WEEK IN BETWEEN THOSE.

SO IF WE WAIT UNTIL THAT MAY PRS, WE CAN'T DO THE THING WHERE WE SAY, OH, WE'LL HAVE AN EXTRA PRS OR AN EMAIL VOTE OR WHATEVER.

IT HAS TO BE THAT DAY.

OKAY.

AND SO IF WE START, LET'S SAY APRIL PRS IS PROBABLY THE SAFER GOAL FOR, FROM THE PERSPECTIVE OF GETTING IT DONE BY JUNE OR, OR WE START TALKING IN APRIL ABOUT, DO WE SCHEDULE A SPECIAL PRS IN BETWEEN? OKAY.

REGULAR APRIL AND MAY PRS.

OKAY.

I THINK THAT ANSWERS MY QUESTION.

DID I GET ANYTHING WRONG? COREY, IF YOU'RE OUT THERE, AWESOME.

THUMBS UP FROM COREY.

ALL RIGHT, THANK YOU.

OKAY.

OKAY.

AND SORRY, MATT, AGAIN, I JUST FELT NEEDED TO RESPOND TO, TO BOB, UH, ABOUT ESR PARTICIPATION.

AND WE, AND WE DO HEAR WHAT YOU'RE SAYING, I THINK, UH, WE UNDERSTAND THAT, UH, SOME FOLKS, UH, INTERPRET THE STATUTE TO REQUIRE ESRS AND SOME FOLKS REQUIRE, UH, INTERPRET THE STATUTE TO EXCLUDE ESRS.

IT'S OBVIOUSLY A LITTLE BIT OF A, OF A DIFFICULT ONE TO PARSE, BUT KOTS INTENT IS, IS NOT TO TAKE A POSITION ON THAT ONE WAY OR ANOTHER.

THAT WAS NOT OUR GOAL.

AND, UM, AND SAYING THIS, I THINK OUR, WHAT WE'RE TRYING TO SAY FOR 1309 IS THAT THE PIECES OF 1309 ARE UNDOUBTEDLY REQUIRED BY THE STATUTE.

UM, AND SO, UM, WHETHER OR NOT ESRS ARE, ARE REQUIRED OR PERMITTED BY THE STATUTE, I THINK IS, UM, O OPEN TO INTERPRETATION.

BUT, UM, REGARDLESS, THEY ARE INCLUDED IN 1310.

SO, BUT UNDERSTAND WHERE YOU'RE COMING FROM ON THAT.

OKAY.

RYAN, I THINK YOU CAN KEEP GOING.

SOUNDS GOOD.

I THINK WE CAN MOVE ALONG TO THE NEXT SLIDE.

[Revision Request Overview]

ALRIGHT.

SO, UH, THIS WILL BE MY FINAL SLIDE, AND THEN I'M GONNA TURN THINGS OVER TO A ATE WHO'S GOING TO GO THROUGH THE, THE MECHANICS IN A LITTLE BIT MORE DETAIL.

UM, BUT,

[00:25:01]

UH, JUST TO KIND OF HIGHLIGHT AT A HIGH LEVEL, UM, YOU CAN THINK OF NPRR 1309 AS A TRADITIONAL ANCILLARY SERVICE TO ADDRESS OPERATIONAL NEEDS.

UM, ONE OF THE THINGS THAT DISTINGUISHES IT BETWEEN THE EARLIER ITERATION IS THAT THIS SERVICE IS, UH, AVAILABLE OR OPEN TO BOTH OFFLINE AND ONLINE GENERATION.

IT IS PROCURED IN DAY AHEAD AND REAL TIME.

UM, SO IT, UH, WE WOULD SAY THAT, UH, IT MORE FULLY MEETS THE REQUIREMENTS OF THE STATUTE, WHICH, WHICH HAVE AN EXPLICIT REFERENCE TO BOTH DAY AHEAD AND REAL TIME.

SO THAT TOOK A LITTLE BIT OF ITERATION.

WE APPRECIATE THE, UH, THE DISCUSSION, THE INPUT FROM STAKEHOLDERS TO HELP INFORM THAT.

AND THEN NPR 1310, YOU CAN THINK OF THAT AS THE NPR THAT IS REALLY MORE RESPONSIVE TO THAT OPTIONALITY GUIDANCE FROM THE PUBLIC UTILITY COMMISSION.

UM, THERE, UH, IS A, UH, CONTEMPLATION FOR ENERGY STORAGE RESOURCE TO PARTICIPATE IN THIS SERVICE.

AND CONSISTENT WITH THE GUIDANCE, WE, WE INTRODUCE THIS, THIS CONCEPT OF A AT LEAST FACTOR.

AND, UM, I, I WON'T GO INTO THAT IN TOO MUCH DETAIL, BUT ESSENTIALLY IT ALLOWS FOR, UH, DRS TO BE PROCURED, UM, AT A QUANTITY THAT IS GREATER THAN, THAN IS NECESS STRICTLY NECESSARY FOR OPERATIONAL UNCERTAINTY? AND COULD IT MEET, UH, SOME OF THESE MORE EXPANSIVE MANDATES THAT HAVE BEEN CONTEMPLATED.

UH, ALSO JUST TO NOTE THAT NPR 1235 HAS BEEN WITHDRAWN AND, UH, I GUESS THIS IS MORE, UH, ITERATION, A REITERATION OF WHAT WAS NOTED BEFORE IS THAT THE, THAT, UM, DRS DESIGNATED AS A KEY PUCT PRIORITY FOR ERCOT.

AND, UH, NPR 1310 WAS ALSO GRANTED URGENT STATUS BY STAKEHOLDERS AT THE DECEMBER, 2025 PRS.

AND THEN A FINAL NOTE HERE IS THAT, AS WAS NOTED PREVIOUSLY, IS THAT NPR 1309 WAS GRANTED BOARD PRIORITY STATUS TO SUPPORT CONSIDERATION AT THE JUNE, 2026 BOARD MEETING.

SO AN IMPORTANT TIMELINE CONSIDERATION THERE.

SO AT THIS POINT, I'M GONNA TURN THINGS OVER TO ANUPAM, WHO'S GOING TO ENGAGE A LITTLE BIT MORE FULLY IN SOME OF THE MECHANICS OF THESE TWO NPRS.

THANKS

[Common Features of NPRR 1309 and NPRR 1310]

RYAN.

UH, THE, AN MARKET DESIGN.

SO WE'LL START WITH LOOKING AT, UH, SOME OF THE CORE, UH, DESIGN FEATURES, UH, THAT I INCLUDED IN BOTH, UH, NPS 1309 AND 1310.

UM, SO AS, UH, RYAN MENTIONED BEFORE, UM, TRS, UM, WOULD BE AN ANCILLARY SERVICES, WHICH WILL BASICALLY PROVIDE OPERATING RESERVES TO MANAGE, UH, MARKET UNCERTAINTY.

UM, IT ALSO, UH, IS EXPECTED TO MITIGATE THE NEED FOR, UH, ROCK INSTRUCTIONS.

UM, AND BOTH OF THESE, UH, FEATURES ARE BASED ON THE STATUTORY REQUIREMENTS.

UM, DRS WILL BE, UM, OFFERED, AWARDED, AND PAID, UM, IN BOTH, UH, DAY, HEAD MARKET AND REALTIME MARKET.

UH, LIKE ANY OTHER ANCILLARY SERVICE, UM, IN ORDER TO BE AWARDED DRS RESOURCES MUST OFFER, UH, DRRS.

UM, WE WILL, UH, LATER IN FEW, UH, AFTER A FEW SLIDES, WE WILL TALK ABOUT THE DRS DEMAND CURVE AND THE DRS CONSTRAINTS.

UH, BOTH OF THESE WILL BE, UH, COMMON FOR BOTH, UH, THE DAY MARKET, UH, AND, UH, THE REALTIME MARKET.

UM, ANOTHER ELEMENT, UH, OF THIS IS THAT, UH, QCS CAN, UH, SELF ARRANGE, UH, DRS, UH, AS WELL AS, UH, THEY CAN TRADE THEIR, UH, DRRS UH, POSITIONS.

UM, ALSO, UM, VIRTUAL, UH, DRS OFFERS CAN BE SUBMITTED, UH, INTO THE D UM, DRRS CAN BE PROVIDED, UH, BY ELIGIBLE, UH, OFFLINE AND, UH, ONLINE GENERATION RESOURCES.

UM, THIS IS, UH, ONE OF THE CHANGE FROM THE EARLIER VERSIONS.

UM, THE WAY THIS WILL BE DONE IS, UH, WE WILL DEVELOP A, A NEW RE UH, SO WE WILL DEVELOP A NEW RESOURCE STATUS QUO, UH, DRS, UH, FOR THE DEPLOYMENT OF, UH, OFFLINE GENERATION RESOURCES THAT ARE PROVIDING DRRS.

UM, I HAVE A FEW SLIDES LATER, WHICH WILL, UH, GO INTO THE DETAILS, UH, OF THAT MECHANISM.

UM, RESOURCES ARE REQUIRED TO UNDERGO, UH, QUALIFICATION TESTS.

UM, THESE TESTS ARE SPECIFIED, UH, IN THE DRAFT NPRS, UM, AND THEY ARE, UH, WELL ALIGNED WITH THE ELIGIBILITY CRITERIA, UM, MENTIONED IN THE STATUTORY REQUIREMENTS.

SO, NAMELY, UH, RESOURCES MUST BE CAPABLE OF OPERATING AT THEIR HIGH SUSTAINED LIMIT FOR, UH, AT LEAST FOUR CONSECUTIVE HOURS.

UM, AND THE SECOND IS THAT THE AMOUNT OF DRS, UH, FOR WHICH RESOURCES WILL BE QUALIFIED, UH, THOSE AMOUNTS ARE LIMITED TO THE CAPACITY THAT CAN BE RAMPED UP, UH, WITHIN TWO HOURS.

SO,

[00:30:01]

NEXT, WANT TO REVIEW, UM, THE R MECHANISM.

SO R WILL BE HOW, UM, DRRS OFF FROM OFFLINE RESOURCES IS DEPLOYED.

UH, THERE'LL BE NO PROCUREMENT, UH, IN R BUT THIS IS, UH, TALKING ABOUT THE DEPLOYMENT.

SO, UH, ROCK WILL PRIORITIZE, UH, OFFLINE GENERATION RESOURCES THAT ARE PROVIDING DRRS.

THE WAY THIS WILL BE DONE IS BY SCALING DOWN THE STARTUP AND MINIMUM ENERGY COSTS RELATIVE TO, UH, THE OTHER OFFLINE GENERATION RESOURCES.

UM, AS NOTED DOWN THERE, THE CURRENT VALUE THAT WE ARE STARTING WITH IS, UH, OF THE SCALING FACTOR IS, UH, 20%, UH, TRS DEPLOYMENTS, UH, OF OFFLINE GENERATION RESOURCES WILL BE INCLUDED IN THE RELIABILITY DEPLOYMENT PRICE ADDERS FOR, UH, ENERGY AND ANCILLARY SERVICES.

UM, THIS IS SIMILAR TO, UH, WHAT'S CURRENTLY IN THE PROTOCOLS NOW.

UH, IN ADDITION TO THIS, UH, QSCS, UH, R CAPACITY SHORT CHARGES, UH, WILL CONSIDER THE DRS POSITIONS AND AS WELL AS DRS ELIGIBLE CAPACITY, UH, IN THE RESOURCE, IN THEIR RESOURCE PORTFOLIOS TO COVER THE Q'S DR.

S POSITION.

DO YOU WANT TO TAKE QUESTIONS AND COMMENTS AS WE GET 'EM, OR DO YOU WANNA GO AT THE END OF YOUR SECTION? YEAH, WE, WE CAN TAKE QUESTIONS.

STEVE REY.

YEAH, THANKS.

UM, WELL, IN GENERAL, I'M A, A BIG FAN OF VIRTUAL OFFERS.

UH, I'M CURIOUS AS TO HOW A VIRTUAL OFFER FOR THIS PRODUCT WOULD, UH, MEET THE STATUTORY REQUIREMENT TO OFFSET RUCK.

SO, YEAH, YOU WANT GO AHEAD, .

SO, UM, I THINK THE WAY THAT WE HAVE, UM, TRIED TO FULFILL THAT REQUIREMENT, IF I CAN PUT IT THAT WAY, IS THAT THE RUCK ENGINE, AND MAYBE YOU CAN GO BACK TO THE, THE PREVIOUS SLIDE.

UH, SO IN ORDER TO MEET THAT REQUIREMENT, WHAT WE'RE PROPOSING TO DO UNDER, UNDER BOTH NPRS IS TO MAKE THE DRRS CAPACITY APPEAR, UH, BASICALLY MORE ECONOMIC TO THE RUCK ENGINE, SO THAT AT LEAST FOR CAPACITY REASONS, RUCK WILL DEPLOY THAT, UH, THAT FIRST.

SO, UH, I SUPPOSE IT'S, UH, IT'S THE WAY THAT I THINK WE HAVE AGREED THAT IS BEST MEETS THE, UM, THE, THE REQUIREMENTS.

BUT, UH, MAYBE, MAYBE I'LL PAUSE STEVE TO SEE IF I'VE, IF I ANSWERED THAT, OR IT'S A SEPARATE QUESTION.

YEAH, I MEAN, I, VERY SENSITIVE MICS TODAY.

UM, I, I, NO, I, I THINK, AND THAT, THAT SEEMS A FAIR WAY TO DO IT, BUT THAT ONLY IS THE DRR CAPACITY BEING ACTUALLY CARRIED BY RESOURCES, RIGHT? SO THE, IF IF YOU HAD A 1309 CASE WHERE, UH, ALL OF THE DRRS AWARDS WENT TO VIRTUALS, UH, THERE WOULD BE, YOU KNOW, FULL AWARDING OF DRRS CAPACITY, BUT, UH, ABSOLUTELY NO OFFSET, UH, FOR THE R ENGINE, IF I UNDERSTAND IT CORRECTLY, BECAUSE THERE IS NO DRRS CAPACITY THAT THE R ENGINE CAN SEE.

SO, UM, AND THEN, I MEAN, AND, AND IT JUST, AND, AND I'LL, I'LL, I'LL LEAVE IT AT THIS.

I MEAN, JUST, UH, THE, THE OTHER THING IS, IS THAT, YOU KNOW, THE REASON WE DIDN'T HAVE VIRTUAL ANCILLARY SERVICE OFFERS FOR, UH, PRIOR TO RTC WAS BECAUSE THERE WAS A PHYSICAL RESPONSIBILITY CARRIED BY, UH, UH, ANCILLARY SERVICE DAM AWARD.

AND, AND, UM, AND, AND NOW THAT PHYSICAL RESPONSIBILITY IS REALLY IN THE REAL TIME.

BUT FOR THIS ANCILLARY SERVICE, THE ONLY PHYSICAL RESPONSIBILITY THAT I CAN SEE IS, IS THE ROCK THING.

AND SO THERE, THERE IS NO, UH, PHYSICAL RESPONSIBILITY, UH, FOR A REAL TIME, UH, DRRS AWARD.

IT'S ONLY FOR THE, THE, UM, IT'S ONLY FOR THE, THE, THE DAM AWARD.

SO I, I, SINCE IT SEEMS TO CARRY A PHYSICAL RESPONSIBILITY, I'M NOT SURE THAT THAT, THAT VIRTUALS ARE APPROPRIATE IN THIS CASE.

UH, UH, THERE MAY BE SOME OTHER COMMENTS HERE, BUT MAYBE JUST THE ONE THING I, I, I SHOULD NOTE, AND I THINK WE GET INTO THIS IN SOME OF THE OTHER SLIDES, IS THAT, UM, STRICTLY SPEAKING,

[00:35:01]

IF YOU WANT TO OFFER, UH, DRS IN REAL TIME, THERE ACTUALLY ARE CERTAIN AVAILABILITY REQUIREMENTS THAT YOU NEED TO MEET PRECISELY TO MAKE SURE THAT YOU'RE, YOU, YOU WERE AVAILABLE TO THE RUCK ENGINE.

SO I DON'T KNOW IF THAT COMPLETELY ALLAYS THE CONCERN THERE, BUT SUFFICE TO SAY, YOU DO NOT NEED TO HAVE A DAY, LIKE, UM, IF YOU WISH TO OFFER DRS IN REAL TIME, THERE ARE, THERE ARE ACTUALLY SOME OBLIGATIONS THAT YOU NEED TO FULFILL FOR A GIVEN HOUR, AND IT'S AN AVAILABILITY REQUIREMENT, AND IT'S REFLECTED IN THE, THE CURRENT OPERATING PLAN.

AND I THINK WE'LL GET INTO THAT.

IT ACTUALLY MIGHT EVEN BE THE NEXT SLIDE.

UM, I, I DON'T KNOW IF THAT NECESSARILY LAYS THINGS COMPLETELY, BUT, UM, IT'S NOT SIMPLY OF A QUESTION.

YOU CAN, YOU CAN WAIT UNTIL REAL TIME IF YOU TO, TO KIND OF MEET PRECISELY THAT SORT OF INTERTEMPORAL REQUIREMENT OF, OF MAKING YOURSELF AVAILABLE TO R WE HAVE THIS ADDITIONAL KIND OF, UH, AVAILABILITY REQUIREMENT.

I SEE SIZE ON MY SHOULDER HERE, SO WE MAY HAVE SOMETHING TO ADD.

YEAH.

UM, SO LET, LET'S COME UP WITH A SCENARIO THAT EVERYONE OFFERS VIRTUAL DRRS AND THEY'RE ALL CLEARED AND THE QSCS DON'T UPDATE THEIR COPS, OR THEY DON'T EVEN HAVE ANY RESOURCES.

SO COME REAL TIME.

SO RUCK CANNOT SEE ANYTHING.

THERE IS NO DRS, UM, OFFLINE RESOURCE FOR DEPLOYMENT.

SO NOTHING HAPPENS IN R COME REAL TIME.

UM, THESE GUYS, LET'S SAY THAT THEY, THEY HAD RESOURCES, LET'S, IF THEY DON'T HAVE RESOURCES, THEY'LL BE HIT WITH AN ACE IMBALANCE CHARGE, RIGHT? BUT IF THEY HAD RESOURCES AND THEY JUST DIDN'T BOTHER TO UPDATE THEIR COP, THEY WILL NOT BE ELIGIBLE TO RECEIVE DRRS AWARDS BECAUSE WE DO SOME BOOKKEEPING FOR ALL THE R THAT HAPPENED BETWEEN, THEY HAD AFTER DR AND ALL THE H TRUCKS CONSECUTIVELY.

SO YEAH, YOU RAC WILL NOT BE ABLE TO DEPLOY DRRS BECAUSE THERE'S NOTHING THERE FOR OFFLINE.

UH, BUT THESE GUYS WILL BE HIT WITH, UH, UM, REAL TIME IMBALANCE BECAUSE THEY WILL NOT BE ABLE TO RECEIVE OFFLINE DRRS AWARDS.

OKAY.

I, I, I STILL HAVE SOME CONCERNS, BUT I'M HAPPY TO TAKE THOSE OFFLINE.

I MEAN, WE COULD PROBABLY MAKE SOME CHANGES IN THE PROTOCOL IF, IF YOU WANT TO REMOVE VIRTUAL, BUT WE JUST WANTED TO KEEP IT IN LINE WITH ALL THE OTHER AREAS.

OKAY.

DAVE, WERE YOU TRYING TO JUMP IN THERE? YEAH, ACTUALLY, I'LL SAY RYAN AND SAI COVERED ABOUT 98% OF WHAT I WAS PLANNING TO SAY.

I, I GUESS JUST THE ONE LAST PETE, I WANT TO POINT, RYAN, YOU MENTIONED THIS VERY BRIEFLY, BUT JUST ALSO TO BE VERY CLEAR IN THE EXAMPLES THAT WE'LL WALK THROUGH AND, AND WHAT CY WAS WALKING THROUGH A RESOURCE SHOWING A STATUS OF DRS IN THEIR COP IS NOT DIRECTLY A FUNCTION OF OR RELATED TO WHETHER OR NOT THEY RECEIVED DRS AWARDS IN THE DAY AHEAD MARKET.

SO I THINK, STEVE, THAT'S A, A LITTLE BIT OF DISTINCTION.

AGAIN, MAYBE THERE'S SOME DEBATE ON WHETHER OR NOT, UH, UH, VIRTUAL OFFERS ARE APPROPRIATE IN THIS CASE, BUT AS THE TOP BEHAVIOR IS NOT DIRECTLY A FUNCTION OF DAM AWARDS AND MORE A FUNCTION OF HOW THE QC WANTS THE RESOURCE TO LOOK ELIGIBLE FOR REAL TIME PRICE FORMATION, THAT THAT'S WHY WE FELT COMFORTABLE INCLUDING IT IN THE NPRS DRAFTED.

THANK YOU.

OKAY.

I THINK YOU CAN KEEP GOING.

OKAY.

THANK YOU.

I THINK WE CAN MOVE AHEAD.

SO AS, UH, RYAN WAS TALKING, UH, EARLIER HE JUST MENTIONED, UH, THIS VALIDATION, UM, THAT WILL BE DONE BASICALLY, UH, TO MAINTAIN THIS ELIGIBILITY CHECK, UH, TO SEE THAT, UH, WHETHER THE RESOURCE, UH, MAINTAINED THE COP STATUS OF, UH, DRS, UH, OR ON, UM, AND WE HAVE SOME EXAMPLES ABOUT THIS, UM, BUT BASICALLY, UH, IT NEEDS TO MAINTAIN THIS THROUGH DR AS WELL AS, UH, UH, EACH SUBSEQUENT EDGE TRUCK FOR A GIVEN OPERATING HOUR, UM, SO THAT IT'LL ACTUALLY, UH, SHOW UP TO, UH, THE ROCK ENGINE.

UM, BASICALLY THIS IS, UH, TO ENSURE THAT THERE'S NO, YOU KNOW, STRATEGIC BEHAVIOR TO AVOID THE ROCK.

UM, NOTE THAT AN OFFLINE RESOURCE CAN, THAT IS SCANNING DRS MAY CHOOSE TO SELF COMMIT BY SHOWING HIS ON AND COP.

UM, AND AS MENTIONED BEFORE, UM, THE DRS RESOURCES THAT DID NOT RECEIVE A DAMN AWARD, UH, IF THEY WISH TO, THEY CAN OFFER, UH, INTO REAL TIME MARKET, UH, PROVIDED THAT THEY MEET THIS, UH, ELIGIBILITY CHECK.

SO HOPEFULLY THIS, UH, ADDRESSES AT LEAST SOME, SOME OF THE COMMENTS.

UM, SO NEXT FEW SLIDES I'LL COVER, UH, SOME EXAMPLES, UM, JUST ILLUSTRATIVE EXAMPLES OF HOW THIS WOULD WORK.

UH, GUESS WE HAVE,

[00:40:02]

HOW ABOUT A DUMB QUESTION TO START WITH.

GO BACK TO THAT SLIDE.

THIS ONE HERE WHERE YOU'RE TALKING ABOUT OFFLINE RESOURCES CARRYING DRS MAY CHOOSE TO SELF COMMIT AND YOU JUST SHOW HIS ON.

NOW IF I'M GOING FROM AN OFFLINE TO AN ONLINE AND I COME ONLINE, DO I STILL NEED TO RESERVE THE CAPACITY, LIKE A HASSLE FOR THAT, OR HOW'S THAT? I'M JUST CURIOUS ABOUT THAT.

TO MAKE SURE THAT THE CAPACITY'S AVAILABLE FOR A TRUE DEPLOYMENT OF DRRS.

I MEAN AFTER RTC RUCK RUCK IS CO-OP OPTIMIZING AS ALSO YES, BUT DRRS IS NOT ONE OF THOSE PRODUCTS BECAUSE WE ARE DEPLOYING DRRS IN RUCK.

SO THE R CO-OP OPTIMIZATION WILL CO-OP OPTIMIZE ENERGY AND ALL THE OTHER AREAS EXCEPT THIS ONE.

OKAY.

SO, AND THERE IS NO HASSLE CONCEPT FOR THIS.

OKAY.

ALRIGHT.

OKAY.

THANK YOU.

UM, SO MOVING ON.

UM, SO JUST ONE, UH, SIMPLE EXAMPLE.

UH, IF WE CONSIDER, UH, GENERATION RESOURCE, UM, THAT IS OFFLINE.

UM, SO LET'S SAY THE RESOURCE IS AWARDED, UH, DRRS IN THE DAM.

UM, AND, UM, ASSUMING THERE IS NO, UH, DEPLOYMENT, UM, IT WOULD HAVE TO, UM, CHANGE ITS TER STATUS TO DRRS AND IT SHOULD MAINTAIN THAT, UH, STATUS, UM, THROUGH, UH, ROC, AS I MENTIONED, AND ALL SUBSEQUENT H ROCKS.

IF IT DOES THAT, UH, THEN, UH, IN SUCH CASE IT WOULD BE ELIGIBLE FOR, UH, REALTIME DRS AWARD.

UM, NEXT IS A SIMILAR EXAMPLE.

UM, HERE AGAIN, THE REAL RESOURCE WAS, UH, AWARDED DRS IN DAM.

UM, AND, UM, SO THIS IS, UH, AVAILABLE TO R UM, AND THIS TIME IT WAS, UH, ACTUALLY DEPLOYED, UH, VIA R UM, AND SO IT REMAINS ON, UM, AND THIS AGAIN, MAINTAIN, UH, AGAIN, IT, UH, MAINTAINS THAT ELIGIBILITY STATUS, UH, THROUGH DO AND ALL SUBSEQUENT H TRUCKS.

AND SO THEREFORE IS ELIGIBLE FOR THE REALTIME PRS AWARD.

UH, I BELIEVE WE HAVE SOME QUESTIONS OR COMMENTS.

OH, SORRY.

YEAH.

UM, AGAIN, THIS IS, UH, SIMILAR EXAMPLE, BUT, UH, IN THIS CASE, UH, WE HAVE A SITUATION WHERE THE, UH, RESOURCE, UH, CHANGED ITS, UH, STATUS TO ON INDICATING THAT IT PLANNED TO SELF COMMIT FOR THAT GIVEN HOUR, BUT THEN AFTER SOME TIME, IT, UH, CHANGED THAT PLAN.

UM, AND AGAIN, SO IT MAINTAINED A STATUS OF EITHER DRRS OR ON, UH, FOR THIS ELIGIBILITY CHECK.

AND SO AGAIN, IT, UH, REMAINS ELIGIBLE FOR THE REALTIME DRS AWARD.

AND THE FINAL EXAMPLE IS JUST A VARIATION OF THE PREVIOUS ONE.

UH, THIS IS WHERE, UH, THE RESOURCE, UH, INDICATES, UH, PLAN TO SELF COMMIT.

UM, AND IT DOES NOT, UH, CHANGE THAT.

SO AGAIN, IT MAINTAINS THE ELIGIBILITY FOR THE REAL TIME DRS AWARD.

GO AHEAD, KATIE.

THANK YOU.

SO I MIGHT NOT BE AS BIG A FAN OF EXAMPLES AS IAN IS, UM, BUT I DO APPRECIATE THESE, BUT I WAS WONDERING IF FOR WORKSHOP TWO, IF WE COULD BRING BACK EXAMPLES WHERE, UM, RESOURCES WOULD NOT BE ELIGIBLE JUST TO BE ABLE TO MAKE THAT COMPARISON.

YEAH, APPRECIATE THAT FEEDBACK.

THANKS.

THAT'S A GOOD IDEA IS SOMEBODY, OR MULTIPLE PEOPLE KEEPING TRACK OF WHAT THEY'RE BRINGING BACK.

OKAY.

OKAY.

STEVE REY, SORRY.

YEAH, I JUST WANT TO, UM, UH, MAYBE APOLOGIZE.

SO, UH, THE, LOOKING AT THESE EXAMPLES, YOU HAVE FOUR SORT OF HAPPY PATH EXAMPLES IN THE CASE THAT A RESOURCE DID SOMETHING THAT MADE IT INELIGIBLE, UH, TO PARTICIPATE IN THE REAL TIME.

THAT, IN OTHER WORDS, IT GOT A DRS AWARD AND IT, SO LET'S SAY IT'S A THERMAL RESOURCE THAT NEEDS TO BE ONLINE TO, TO CARRY DRRS, UH, AND IT GETS A-D-R-R-S AWARD IN THE DAM, BUT THEN IT PUTS OFF IN THE, UH, IN THE COP.

UH, I ASSUME THAT WOULD MAKE IT, UM, INELIGIBLE, UH, EVEN IF IT, IF IT TURNED BACK ON AT SOME POINT, IT WOULD SORT OF BREAK THE CHAIN.

UM, AND THEN, SO IF IT WERE REAL TIME INELIGIBLE IS THE ONLY CONSEQUENCE FOR THAT RESOURCE THAT RECEIVED A-D-R-R-S AWARD BUT DID NOT

[00:45:01]

PROVIDE IT, UH, WOULD BE THAT IT WOULD HAVE TO BUY BACK THE DRS AND IN REAL TIME THERE'D BE NO COMPLIANCE OR ANYTHING LIKE THAT? THAT IS CORRECT.

AND, AND IF EVEN IF THEY'RE OFF, THERE ARE CERTAIN UNITS THAT WE DON'T, UM, LIKE THE QUICK START MONTHS.

YEAH.

YEAH.

I'M TALKING ABOUT A LONGER START LONGER, YEAH.

YEAH, YEAH.

MORE THAN TWO HOURS START THERMAL.

YEAH, THAT'S RIGHT.

OKAY.

OKAY.

WELL THEN, THEN NO PROBLEM WITH VIRTUALS WHATSOEVER.

SORRY ABOUT THE MUD.

OKAY, BOB.

GOOD.

YOU'RE GOOD, KEVIN.

I GUESS PROBABLY ADDING STEVE'S COMMENT THERE.

I GUESS THE QUESTION, WHEN THE UNIT MOVES, LET'S SAY IT'S, HAS A FORCED OUTAGE MOVES FROM OFF TO OUT, WE'RE NOT REPROCURING ANYTHING, RIGHT? OKAY.

WE ARE NOT, I MEAN, R DOES NOT PROCURE DRRS BECAUSE R IS THE TOOL TO DEPLOY DRRS.

YEAH, WE'RE JUST NOT DOING A SM FOR DRS IS ALL I'M SAYING.

WE ARE NOT.

OKAY.

OKAY.

UM, SO JUST WANTED TO COVER, UM, SOME OF THE OTHER FEATURES, WHICH IS, UH, CONSTRAINTS, UM, THAT WILL BE THERE FOR DRS IN BOTH DATA MARKET AND REAL TIME MARKET.

UM, SO, UH, APART FROM SYSTEM LEVEL CONSTRAINTS, WE'LL ALSO HAVE, UH, RESOURCE LEVEL CONSTRAINTS.

UM, SO BASICALLY, UH, FOR THE RESOURCE LEVEL CONSTRAINTS, UH, THE DRS UH, AWARDS ARE CAPPED, UH, BY THE HSL, UH, OF THE RESOURCE.

UM, AND, UM, THE NEXT IS IF YOU HAVE, UH, AN ONLINE, UH, GENERATION RESOURCE, UM, THEN IN A PARTICULAR, UH, HOUR, UM, THE SUM OF ITS, UH, AWARDS FOR ENERGY, OTHER ANCILLARY SERVICES AND THE NON-OVERLAPPING PORTION, UH, WHICH IS THAT, UH, TERM INDICATED BY ONE MINUS RELEASE FACTOR TIMES DRRS.

UM, SO THAT, UH, ALL OF THOSE TOGETHER, UH, SHOULD, UH, BE LESS THAN THE HSL.

UM, IF YOU HAVE AN OFFLINE RESOURCE THAT IS A DRS, UH, ELIGIBLE AND HAS SUBMITTED, UH, DRS, UH, OFFER, THEN, UM, IN THIS CASE, UH, THE SUM OF, UH, ECRS, NONS SPIN AND NON OVERLAPPING DRS AWARDS, UH, A CA BY THE HSL.

UM, SO THIS, UH, UH, IS ANOTHER FEATURE, WHICH IS THE ANCILLARY SERVICE DEMAND CURVE FOR DRS, UH, COMPARED TO WHAT WE HAD, UH, IN AN EARLIER VERSION IN THIS CASE, UH, UH, WE NOW HAVE A SLOPE DEMAND CURVE.

UM, AND, UH, BASICALLY IT'S, UH, A LINEAR LINE, UH, WITH A STARTING POINT OF, UH, $150, UH, AT ZERO MEGAWATT, UM, AND SWOOPING DOWN TO, UM, I BELIEVE THAT'S A, UH, TYPO, UH, SORRY FOR THAT.

UH, SO IT SHOULD BE, UH, $10, UH, AT THE, UH, ANCILLARY SERVICE PLAN FOR DRS, UH, FOR THE GIVEN OPERATING HOUR.

UM, I'LL ALSO NOTE THAT, UH, THIS IS, UH, ASSUMING A RELEASE FACTOR OF, UH, ZERO, UM, IF THE PUCT APPROVES, UH, SETTING DRS TO A NON-ZERO, UH, THE RELEASE FACTOR TO A NON-ZERO VALUE, THEN THE PORTION BEYOND, UH, THE OPERATING RESERVE, UH, WOULD BE, UH, BEYOND THE OPERATING RESERVE REQUIREMENT, WOULD BE A FLAT, UH, $10, UH, TILL THE POINT AT WHICH THE RESOURCE ADEQUACY REQUIREMENT IS, UH, QUESTIONS.

OKAY.

KATIE, THANKS.

SO IT'S, UH, JUST NOT INTUITIVE TO ME HOW THAT $10 FLAT CURVE TIES IN.

IS THERE ANY WAY FOR THE NEXT WORKSHOP TO SEE HOW THOSE TWO WOULD FIT TOGETHER? UM, YEAH, SURE.

WE CAN SHOW SOME ILLUSTRATION.

OKAY.

TREVOR, HEY, UH, TREVOR KO, LCA, UH, JUST A QUICK QUESTION.

SO, UH, YOU, YOU MENTIONED, UH, DEMAND CURVE SLOPED, WHICH HELPS WITH MORE EFFICIENT PRICE FORMATION, BUT I THINK KIND OF TYING TO KATIE'S QUESTION, I'M WONDERING WOULDN'T A, WOULDN'T A SLOPED VERSION OF KIND OF THE, THE RESOURCE ADEQUACY PORTION, ALSO, COULD YOU MAKE THE SAME ARGUMENT AROUND PRICE FORMATION THERE RATHER THAN JUST HOLDING IT FLAT AT $10? WELL, I THINK RIGHT NOW, THIS IS OUR INITIAL PROPOSAL.

UM, WE WOULD LIKE TO HEAR,

[00:50:01]

UH, COMMENTS FROM STAKEHOLDERS, UM, IF THERE ARE ANY, UH, DIFFERENT ATIONS.

YEAH, I WILL, I GUESS MY, MY THOUGHT WOULD JUST BE, IT, IT WOULD PROBABLY HELP, UH, TO HAVE SOME DIFFERENCE BETWEEN THAT OPERATIONAL FLOOR AND THE RESOURCE ADEQUACY FLOOR.

THAT'S HOW I'M KIND OF DIVIDING IT UP.

OKAY.

YEAH, NOTED.

UH, OKAY.

SORRY, I SKIPPED ONE, KYLE.

IT IS KYLE.

OVER AT, UH, RA QUESTION I HAD WAS, WHEN IT COMES TO REAL-TIME DEPLOYMENT, SINCE THIS IS A R PRODUCT OR DESIGNED TO HELP REDUCE R HOW EXACTLY IS THE PRODUCT DEPLOYED? IS THERE A POINT WHERE THE OBLIGATION IS RELEASED WHEN IT'S CLOSE TO REAL TIME, SAY INSTANTANEOUSLY? WELL, I THINK IT WAS MENTIONED IN THE PREVIOUS SLIDE.

UH, BASICALLY, UM, RESOURCES THAT, UH, OFFER, UM, LET'S SAY IF YOU HAVE A RESOURCE GENERATION RESOURCE THAT OFFERS, UH, IN THE DAM, THEN THEY NEED TO, UM, CHANGE THE COMP STATUS TO THIS NEW, UH, DRI STATUS, UH, THAT MAKES IT AVAILABLE TO THE ROCK ENGINE.

SO NOW A ROCK ENGINE CAN LOOK AT IT, UM, IT WILL, UH, PRIORITIZE THOSE RESOURCES, UH, BECAUSE OF THE SCALING, UH, OF THE COST THAT WAS MENTIONED BEFORE.

UM, AND, UM, THEN THE ROCK WILL SOLVE ACCORDINGLY AND MAKE SUGGESTIONS FOR A COMMITMENT.

I WANNA SEE IF RYAN SIAH HAVE ANY ADDITIONAL COMMENTS.

MAYBE JUST ONE THING TO ADD, AND I KNOW WE HAD DISCUSSED THIS IN SOME PREVIOUS WORKSHOPS, BUT IT'S PROBABLY A GOOD TIME TO, TO REITERATE, THIS IS NOT LIKE A, A NONS SPIN TYPE OF, UH, ANCILLARY SERVICE WHERE THERE IS A REAL TIME DEPLOYMENT FOR ALL INTENTS AND PURPOSES, THERE IS NO REAL TIME DEPLOYMENT.

IT IS DEPLOYED VIA THE R ENGINE AND IT KIND OF TO MEET THAT STATUTORY REQUIREMENT, ALL OF THOSE, UH, COP REQUIREMENTS THAT NEW HIGHLIGHTED ARE NOTED THERE.

THERE IS A REAL TIME AWARDING, AND THAT IS REALLY TO SUPPORT PRICE FORMATION TO MAKE SURE THAT WE'RE NOT HAVING A, A KIND OF BIG DIFFERENTIATION BETWEEN SOMETHING THAT'S PROCURED DAY AHEAD AND, AND THEN NOT, NOT AGAIN IN REAL TIME.

GO AHEAD.

I'LL JUST LIKE TO ADD ON TO WHAT TRI SAID.

UM, IF YOU COMPARE THIS WITH NONS SPIN, WE DON'T DO ANYTHING WITH ONLINE NONS SPIN AWARDS.

IT'S, IT'S JUST THERE.

WE PROCURE IT, IT FIGURE SHORT IT JUST FOR A PRICE FORMATION TOOL.

SO ONLINE DRRS AWARDS ARE, ARE BEHAVED SIMILARLY, OFFLINE DRRS AWARDS HAVE TO BE DEPLOYED OUTSIDE, AND THAT DEPLOYMENT IS DONE THROUGH RUCK FOR NONS SPIN, OFFLINE NONS SPIN, WHETHER THEY'RE OFFLINE OR ON DUCT BURNERS ARE DEPLOYED THROUGH THE AS MANAGER IN REAL TIME, LIKE WHAT RYAN WAS SAYING.

SO THAT'S WHERE THE DIFFERENCE COMES IN WHEN WE TALK ABOUT DEPLOYMENT, IT'S ONLY THROUGH THE PROCESS AND THAT'S WHERE WE NEED TO SATISFY THE STATUTORY REQUIREMENTS OF REDUCING R ONE IS TO ONE.

OKAY.

SHAMS ON THE DEMAND CURVE.

UM, YOU KNOW, IF YOU GO BACK TO WHAT, UM, I GUESS AURORA PRESENTED AS WELL, IT WAS TIED TO RELIABILITY.

YOU KNOW, HOW MUCH YOU NEEDED WHEN YOU GO TO THE RESOURCE ADEQUACY PIECE, THE 10 MEGAWATT FLAT, AND THAT WAS TIED TO, UM, YOU KNOW, WHEN YOU NEEDED IT IN THE YEAR, UH, DURING TIMES OF SCARCITY AND, AND, YOU KNOW, PROJECTED SCARCITY AND STUFF AS WELL AS IT WAS TIED TO, UH, YOU KNOW, CO NET CONE FROM THE PREVIOUS YEAR SO THAT IT SEEMS LIKE THE $10 FLAT VALUE WOULDN'T MEET THOSE KIND OF REQUIREMENTS.

UNDERSTAND THAT THE INITIAL SLOPE CAN STILL BE THIS BECAUSE THE QUANTITY IS GONNA BE SO MUCH LARGER THAT IT DOESN'T MATTER THAT THESE FEW THOUSAND MEGAWATTS ARE AT $150 OR SOMETHING.

BUT BEYOND THE AS PLAN AMOUNT, I THINK THAT WOULD HAVE TO BE, UH, DETERMINED EACH YEAR AND WOULD VERY DYNAMIC BASED ON NET CORN VALUES FROM THE PREVIOUS YEAR AND, UH, THE RESOURCE ADEQUACY NEEDS AT DIFFERENT TIMES OF THE YEAR.

DOES ERCOT HAVE ANY THOUGHTS ON THAT? SO I GUESS I'LL HAVE A, A COMMENT ON THAT.

SO I THINK I DON'T WANT TO MIX AND MATCH THE AURORA DISCUSSION WITH WHAT WE HAD PROPOSED HERE.

I THINK THE WAY, AT LEAST OUR INITIAL CONCEPT WAS THIS, HAVING THIS FLAT DAILY $10 REQUIREMENT.

IF YOU KIND OF THINK ABOUT IT IN TERMS OF, UH, HOURS PER DAY

[00:55:01]

AND, AND BRING IT UP TO A YEARLY TOTAL, YOU'RE PROBABLY GETTING AT SOMETHING THAT THAT IS REFLECTIVE OF LIKE A RESOURCE ADEQUACY SUPPORT.

UM, I DON'T WANT TO SAY IT'S, IT'S EXACTLY CONE.

I DON'T THINK WE NECESSARILY DID IT THAT WAY, BUT I THINK AT LEAST CONCEPTUALLY, THE IDEA OF HAVING THIS FLAT PAYMENT FOR EVERY HOUR OF EVERY YEAR WAS MEANT TO, UH, AGAIN, IF THE, IF THE RESOURCE FACTOR IS A NON-ZERO NUMBER, THEN TO THE EXTENT THAT THAT IS THERE, UM, THOSE MEGAWATTS WOULD SORT OF BE SUMMED UP ON AN ANNUAL BASIS TO SOMETHING ACHIEVING SOMETHING DESIGNED TO AT LEAST SUPPORT SOMETHING BEYOND JUST THE OPERATIONAL UNCERTAINTY.

IS THIS A VALUE ALREADY SPECIFIED IN 13, 10, $10 EXTENSION? YES.

N-P-R-I-I, IT'S, UH, IT'S IN THAT NPR.

OKAY.

SO WE WOULD HAVE TO COMMENT ON THAT, UH, TO MAKE IT MORE DYNAMIC, MORE CONSISTENT WITH WHAT I GUESS, UH, THE WAY AURORA WAS CONTEMPLATING IT AND BEING IMPACTED, ESPECIALLY, YOU KNOW, IT SEEMS LIKE $10 FLAT, UH, WHEN WE REALLY KNOW DRS IS HIGHLY VALUABLE DURING WINTER OR THOSE KIND OF, UH, WINTER STORM EVENTS, UH, AND MAYBE SOME IN THE SUMMER.

UH, BUT REALLY THE, THE, THE REAL VALUES IN THE WINTER, I WAS THINKING THAT WE WOULD ACTUALLY SHAPE IT WHERE MOST OF THE DRS MONEY WOULD BE IN THE WINTER MONTHS AND SO ON.

BUT, UH, I GUESS WE'D HAVE TO COMMENT ON THAT IF IT'S JUST A FLAT $10 VALUE AND CERTAINLY WELCOME.

SORRY, THIS GORDON DRAKE FROM MECO CERTAINLY WELCOME COMMENTS SHAMS, BUT I I JUST WANT TO REITERATE THE, UH, THE INTENT IS NOT TO SHAPE THE PARAMETERS IN NPR 1310 TO MATCH HOW AURORA PERFORMED THEIR STUDY AND ASSUMPTIONS THAT, THAT THEY MADE.

THAT'S NOT THE GOAL OF THE EXERCISE.

UH, THEY TOOK A, A PARTICULAR MODELING APPROACH THAT, UM, WAS, WAS SUITED TO WHAT THEY WERE, WHAT THEY WERE TRYING TO REPRESENT.

BUT IN, IN 1310, THIS IS WHAT WE, THIS IS WHAT WE AS, AS ERCOT ARE ADVANCING AS THE, UM, AS THE DESIGN FOR A POTENTIAL DESIGN FOR DRS AS AN ANCI ANCILLARY SERVICE, PLUS THAT RESOURCE ADEQUACY MANDATE.

AND SO IT MAY, MAY BE END UP BEING INDEPENDENT OF THE, UM, THE APPROACH THAT AURORA WAS TAKING THOUGH.

WE, I THINK AS, AS RYAN MENTIONED, WE THINK THAT THIS STILL CAN PROVIDE MEANINGFUL SUPPORT FOR A RESOURCE ADVOCACY MANDATE WITH THE, WITH, WITH A $10, UM, FLAT PORTION OF THE, THE DEMAND CURVE.

SO WELCOME THE, THE COMMENTS CERTAINLY, BUT I JUST WANTED TO, TO REITERATE THAT THE POINT IS NOT TO TRY TO GET 1310 TO MATCH AURORA.

THIS IS WHAT WE ARE PROCEEDING WITH INDEPENDENTLY.

WELCOME.

CAN I, CAN I ASK A FOLLOW UP REAL QUICK BACK HERE, DAN JONES? UM, I THINK THOSE WERE, THAT WAS A GOOD QUESTION THAT SEAN'S HAD AND, UM, I'M CONFUSED ABOUT THE QUANTITY THOUGH.

UM, THE HOURLY QUANTITIES, LIKE WHAT I THINK IT WAS, UM, RELEGATED TO THE A AS PLAN, THE METHODOLOGIES TO DETERMINE THE QUANTITIES.

YEAH.

UM, AND I DIDN'T REALLY HEAR THAT.

SO IT, WHAT, WHAT'S THE RELIABILITY OBJECTIVE IN DETERMINING THE HOURLY AS QUANTITIES WITH THE RELEASE FACTOR THAT IS, UM, INTENDED TO MEET THE, THE RA OBJECTIVE? BECAUSE IF IT'S FLAT, $10, IT HAS TO BIND TO GET THE $10.

IF YOU HAVE A SURPLUS, IT'S ZERO.

SO IT'S REALLY DEPENDENT ON THE QUANTITY AND HOW THAT VARIES THROUGHOUT THE YEAR.

IS THE OBJECTIVE THE RESOURCE ADEQUACY STANDARD, OR IS IT SOMETHING DIRECTIONALLY TRYING TO GET THERE, OR WHAT, WHAT, THAT'S JUST REALLY NOT DEFINED.

IT JUST SAYS THERE'LL BE A DOCUMENT, YOU KNOW, A METHODOLOGIES DOCUMENT THAT DOES THAT SOMETIME DOWN THE ROAD.

AND, AND, AND THAT'S, I THINK THAT THAT DIFFERENTIATION IS, UH, IS WORTHWHILE TO MAKE THAT THE, THE NPR AS THEY ARE DRAFTED, PRESUME THAT A PROCUREMENT QUANTITY HAS BEEN, HAS BEEN DEFINED IT, THAT METHOD, UH, IT WAS NOT INTENDED TO BE REPRESENTED IN, IN THESE NPRS THERE WILL BE A, A, A SEPARATE PROCESS THAT WILL, UH, LIKELY INVOLVE LOOKING AT WHERE ARE WE AGAINST A RELIABILITY STANDARD, WHAT'S THE INCREMENTAL CAPACITY THAT'S THAT'S REQUIRED, AND SORT OF USING THAT TO, TO HELP US TO UNDERSTAND THE PROCUREMENT AMOUNTS THAT WOULD BE REQUIRED TO SUPPORT THAT RESOURCE ADEQUACY OUTCOME.

UH, BUT WE HAVE NOT YET DEFINED WHAT THAT STUDY OR APPROACH WOULD, WOULD LOOK LIKE.

AND THE, UH, THE WHAT'S IN THE NPR R IS, UH, LARGELY INDIFFERENT TO WHAT THAT METHODOLOGY IS, BUT PRESUMES THAT IT'S ALREADY BEEN PREDETERMINED THROUGH THE AS METHODOLOGY AND THE AS PLAN.

[01:00:01]

SO I, YOU DON'T SEE THOSE DETAILS IN THE, IN THE NPR.

THAT'S, THAT'S INTENTIONAL.

THERE WILL BE FURTHER CONSULTATION ON WHAT THAT, UH, WHAT THAT APPROACH WOULD BE TO SET THE, UH, THE PROCUREMENT QUANTITIES, UH, UNDER, UH, IF 1310 WERE ADOPTED AND THE RELEASE FACTOR AND RESOURCE MANDATE WERE RESOURCE ADVOCACY MANDATE WERE ENABLED.

OKAY.

YEAH, UH, THAT'S WHAT I WAS UNDERSTANDING.

SO, UM, THAT POTENTIALLY COULD BE A, A, AN ANNUAL PROCESS.

LIKE IT IS, IT COULD HAVE QUANTITIES THAT VARY BY HOUR BY SEASON.

UM, BUT, BUT IT SEEMS, UH, UNDERSTANDING THAT IT SEEMED LIKE THERE SHOULD BE SOME ACKNOWLEDGEMENT OR DECLARATION OR THAT, YOU KNOW, WHAT, WHAT THE OBJECTIVE IS WHEN YOU GET THERE.

YOU KNOW, IS IT JUST LIKE, YOU KNOW, WE LIKE TO TURN THE FAUCET 60% ON BECAUSE, BECAUSE, OR IS THERE A RELIABILITY OBJECTIVE? SO MAYBE AT SOME POINT THAT, THAT MIGHT BE SOMETHING TO ADD IN, AT LEAST TO THE FRAMEWORK, UM, TO KNOW WHAT'S, YOU KNOW, GONNA BE DICTATING, YOU KNOW, THE, WHENEVER YOU DO THAT ANALYSIS, WHAT'S GONNA DRIVE, YOU KNOW, THE RESULT.

OF COURSE.

I APPRECIATE THAT, DAN.

OKAY.

THANKS DAN.

UM, SHAS, WERE WE GOOD? YEAH, NO, UH, JUST, UM, YOU KNOW, SORT OF FOLLOWING UP WITH WHAT DAN, I'LL JUST, YOU KNOW, I THINK WE SHOULD TO GET 13, 10 APPROVED IN TIME, I THINK WE SHOULD LEAVE BOTH THE DEMAND CURVE AND THE QUANTITIES, UH, YOU KNOW, PUSH THAT TO THE AS ANNUAL AS UH, METHODOLOGY DOCUMENT.

'CAUSE OTHERWISE THIS I DON'T THINK WE GET, UH, UM, SOMETHING THAT WE CAN AGREE TO WITHOUT KNOWING WHAT THE EXACT QUANTITIES AND THE DEMAND CURVES LOOKS LIKE.

AS AN EXAMPLE, YOU KNOW, IF YOU HAVE JUST A FLAT $10 DEMAND CURVE AND YOU PAY A WHOLE BUNCH OF MONEY DURING, UM, YOU KNOW, OFF PEAK HOURS TO RESOURCES THAT REALLY AREN'T NEEDED AT THAT TIME, AND YOU REALLY HAVEN'T, UH, RESULTED IN ANY DISPATCHABLE RESOURCES BEING BUILT FOR THE WINTER, WINTER STORM EVENT, AND HAVE WE REALLY ACHIEVED MUCH OUT OF DRS.

SO I WOULD JUST SAY THAT, YOU KNOW, IN ORDER TO GET THESE APPROVED IN TIME, MAYBE WE PUNT BOTH THE DEMAND CURVE, THE, THE RESOURCE ADEQUACY, DEMAND CURVE AND QUANTITY TO THE AS PLAN AMOUNT AS PLAN PROCESS.

THANKS.

OKAY.

UM, AND SHAMS, I KNOW YOU MENTIONED FILING COMMENTS.

I THINK THIS TOPIC WOULD BE GOOD TO BRING BACK NEXT TIME, BUT I THINK, YOU KNOW, IF THAT GETS INTO A, A BIG SUBSTANTIVE POLICY DISCUSSION NEXT TIME, THAT THAT MIGHT BE A PLACE WHERE WE CONSIDER, YOU KNOW, A, A LONGER PATH FOR DISCUSSION ON THIS.

BUT I THINK FOR THE NEXT WORKSHOP THAT'S A, THIS IS AN APPROPRIATE TOPIC TO, TO HAVE COMMENTS ON.

UM, I LOOKED AT KATIE TO SEE IF SHE WOULD CONFIRM WITH ME, BUT SHE JUST WAS CONFUSED AS TO WHY I WAS LOOKING AT HER .

SO, UM, OKAY.

LET'S GO TO, THANK YOU TREVOR.

THAT WAS HELPFUL.

I THINK YOU SAID YOUR COMMENT IS A FOLLOW UP ON THIS.

SO WHY DON'T WE TAKE YOUR QUESTION AND THEN GO TO THE Q IN ORDER.

THANKS, RYAN.

DID YOU HAVE MORE HERE THOUGH? SORRY, TREVOR.

UH, SORRY TO KIND OF, UM, JUMBLE THINGS UP A LITTLE BIT, BUT I, I JUST WANTED TO DOUBLE CHECK THE, THE, THE COMMENT THAT SHAMS YOU HAD MADE ON THE, THE DEMAND CURVE THAT WAS WITH RESPECT TO THE, TO NPRR 1310, IS THAT RIGHT? IT SEEMED LIKE, I DON'T WANNA PUT WORDS IN, BUT THERE'S LESS CONCERN, AT LEAST CONCEPTUALLY WITH THE, THE DEMAND CURVE FOR, LET'S CALL IT THE OPERATIONAL MEGAWATTS OR THE RF TO ZERO MEGAWATTS.

IS THAT RIGHT? I THINK THAT'S RIGHT.

OKAY.

THAT WAS MY UNDERSTANDING WAS 1310, WHICH IS WHY I SORT OF SAID 13, 10.

UNDERSTOOD.

OKAY.

APPROPRIATE TO HAVE ONE MORE CONVERSATION ON, BUT, YOU KNOW, IF THAT SEEMS UNWIELDY, THEN LET'S SEND IT ON A DIFFERENT PATH.

OKAY.

SORRY.

SORRY, TREVOR.

NOW LET'S GO TO YOU.

COOL.

UH, THANKS.

YEAH.

SO, UH, TO, UH, APPRECIATE THAT THIS IS 1310 IS, IS A DIFFERENT DESIGN THAN THE AURORA STUDY AND, UM, ARE, ARE HOPING TO ACHIEVE A RESOURCE ADEQUACY OUTCOME, UH, A SIMILAR RESOURCE ADEQUACY OUTCOME BY A DIFFERENT MEANS.

AND THAT THIS $10 FLOOR THAT'S INITIALLY PROPOSED IS KIND OF A, A STARTING POINT.

AND, AND WE CAN ITERATE ON THAT, UH, THROUGH THESE TYPES OF CONVERSATIONS AND THROUGH COMMENTS.

UM, I THINK, YOU KNOW, FOR A RESOURCE ADEQUACY SIGNAL TO, TO, TO REALLY HIT THE TARGET, IT'S GONNA HAVE TO BE PREDICTABLE, DURABLE, AND, AND

[01:05:01]

CALIBRATED.

I THINK AS, AS OTHER COMMENTERS WE'RE, WE'RE, WE'RE NOTING.

SO, UM, I'M, I THINK IT'S POSSIBLE THAT A $10 FLOOR EXTENDING TO SOME LARGE AS PLAN SIZE WITH A RELEASE FACTOR OF A HIGH ENOUGH RELEASE FACTOR COULD INJECT AN, A SIMILAR AMOUNT OF REVENUE THAT WE SAW IN, IN THE AURORA STUDY AND, AND POSSIBLY, YOU KNOW, BRING IN, INCENTIVIZE A CERTAIN NUMBER OF MEGAWATTS.

THERE'S JUST NOT, THERE'S NO GUARANTEE THAT IT WILL.

AND, UH, WITHOUT EXPLICITLY TETHERING THE, EITHER THE DEMAND CURVE, THE AS PLAN SIZE, THE RELEASE FACTOR, THE COMBINATION KIND OF, OF ALL THREE OF THOSE IS TWO, UH, THE RELIABILITY ASSESSMENT, WHICH WE HAVEN'T COMPLETED YET.

SO I THINK I UNDERSTAND THAT THERE'S A LOT OF COMPLEXITY HERE, BUT THAT, I GUESS, LEADS TO MY REQUEST, WHICH I THINK WHEN WE GET TO THE, THE HOMEWORK STAGE, I THINK IT'D BE REALLY HELPFUL TO THINK THROUGH OR TO SEE SOME ANALYSIS OR SOME, SOME QUANTITATIVE DATA SHOWING DIFFERENT COMBINATIONS OF PLAN SIZE, RELEASE FACTORS AND ADCS, UH, IN ORDER TO SHOW HOW THESE COULD IMPACT PRICE FORMATION TO SHOW WHAT TYPES OF, WHAT LEVELS OF REVENUE THIS COULD INJECT INTO THE MARKET.

AND, UM, WITHOUT THAT, THIS IS KIND OF BLACK BOX AND, AND I'M, I'M WORRIED IS JUST INCREASING UNCERTAINTY AND COULD INCREASE COST AS WELL WITHOUT, YOU KNOW, ACTUALLY COUPLING THAT TO THE, TO THE RELIABILITY STANDARD.

UM, SO THAT'S MY COMMENT.

ANY FOLLOW UP OR CUT? THANK YOU FOR THE COMMENT.

WE JOTTED DOWN SOME OF THOSE REQUESTS TO SEE HOW WE CAN INCORPORATE IT INTO WHAT WE BRING BACK FOR THE, FOR THE NEXT MEETING.

OKAY.

LET'S GO TO ANDREW.

YEAH.

UH, I THINK ANDREW, THE I, IMS AND FORMER IMS DON'T HAVE TO GET IN THE QUEUE THOUGH, AS, AS BETH AND DAN HAVE DEMONSTRATED FOR US .

I, I'M IN THE QUEUE.

I'M JUST TELLING YOU, YOU DON'T HAVE TO.

OH, OKAY.

UH, GOOD TO KNOW.

UH, YOU CAN JUST JUMP IN.

WELL, AS IT HAPPENS, SHAMS, DAN, AND, UH, BECAUSE WE'RE SPECIAL, TREVOR MORE OR LESS SAID LIKE 95% OF WHAT I WANTED TO SAY, AND THEY SAID IT VERY WELL, SO I WON'T REPEAT ALL OF IT.

UH, AND I WAS GOING TO SAVE SOME OF THE, UM, COMPARISONS BETWEEN AURORA AND 1310 FOR LATER, WHERE IT COMES UP IN THIS PRESENTATION, BUT AT LEAST THE TOPIC HAS BEEN BROUGHT UP NOW.

SO SEEING AS I WAS ALREADY IN LINE, UH, I DON'T KNOW HOW ANYONE CAN BE EXPECTED TO MAKE ANY SENSE OF 1310, GIVEN THAT THE ONLY ANALYSIS THAT'S BEEN DONE IS, AS YOU'VE ALREADY ADMITTED, NOT REPRESENTATIVE OF HOW 1310 IS DESIGNED.

AND SO I, I DON'T REALLY KNOW WHAT THE PURPOSE OF THE AURORA DRS PLUS STUDY WAS, GIVEN THAT IT DOESN'T RESEMBLE 1310 AT ALL.

I MEAN, IT'S JUST COMPLETELY DIFFERENT MECHANISMS FOR PRODUCING THE REVENUE.

THE REVENUE'S GOING TO BE DISTRIBUTED DIFFERENTLY.

THERE'S NO DEMAND CURVE.

THE, THE PROCUREMENT VOLUMES ARE REALLY SCALERS AROUND DECIDING WHEN TO PUT HOW MUCH REVENUE WHERE, AND NOW WE'RE TALKING ABOUT A FLAT $10 DEMAND CURVE THAT PRESUMABLY WOULD BE BINDING A LOT OF THE TIME.

MOST OF THE TIME, HOW OFTEN IT'S BINDING IS MAINLY A FUNCTION OF HOW MUCH REVENUE YOU WANT TO GENERATE.

SO IT'S REALLY JUST A REVENUE SPIGOT.

I I DON'T KNOW HOW ANYONE'S SUPPOSED TO MAKE ANY SENSE OF THIS TO APPROVE IT, GIVEN THAT WE DON'T HAVE ANY ANALYSIS OF HOW IT WOULD BE EXPECTED TO WORK, UH, ALONG THE LINES THAT THE LAST THREE QUESTIONERS WE'RE KIND OF BRINGING UP.

SO THAT'S MORE OR LESS WHAT I HAVE TO SAY AT THIS POINT.

ARE YOU VOLUNTEERING TO DO ANY ANALYSIS? NO.

OKAY.

OKAY.

LET'S GO TO JOHN RU HUBBARD.

JOHN RU HUBBERT WITH TIC.

UH, THIS IS KIND OF IN LINE WITH SOME OF THE OTHER QUESTIONERS, BUT I WAS HOPING YOU COULD MAYBE EXPLAIN A LITTLE MORE HOW THE $10 FLOOR WAS SET AND, AND WHY.

YEAH.

UH, SO, OH, I SHOULD HAVE, I DIDN'T EVEN JUMP IN THE QUEUE.

MY APOLOGIES.

UH, BUT I THINK, AGAIN, WE HAD ALWAYS THOUGHT THAT THIS WOULD BE THE BEGINNING OF A CONVERSATION RATHER THAN THE END OF A CONVERSATION.

SO I WANT TO KIND OF PUT THAT FORWARD AT THE OUTSET.

BUT THE IDEA BEHIND THIS IS THAT IF WE JUST TOOK A, A VERY SIMPLIFIED EXAMPLE WHERE WE WERE PROCURING, UM, YOU KNOW, LET'S JUST SAY ONE MEGAWATT FOR EVERY HOUR AT $10, IF WE KIND OF SUM THAT UP FOR ALL THE HOURS OF THE YEAR, THAT WOULD GET YOU AT SOMETHING APPROXIMATING A, UM, UH, UH, SOMETHING THAT WOULD SUPPORT RESOURCE ADEQUACY.

LET'S PUT IT THAT WAY.

I WANT TO MAKE, BE VERY CAREFUL IN THE WAY THAT I'M DESCRIBING THIS, BECAUSE THIS IS AN ANCILLARY SERVICE.

THIS IS PROCURED EVERY HOUR.

BUT THE IDEA BEHIND THIS IS THAT THIS WOULD SUPPORT SOMETHING BEYOND SIMPLY WHAT WOULD BE REQUIRED FOR OPERATIONAL UNCERTAINTY.

AND IF YOU, IF YOU

[01:10:01]

STRETCH IT TO 100%, THEN YOU COULD THINK OF A RESOURCE RECEIVING THAT PAYMENT AS A FUNCTION OF IT, UH, WHAT IT HAS AVAILABLE EVERY HOUR OF EVERY DAY.

AND THEN THAT WOULD SUPPORT, UH, SOMETHING APPROACHING RESOURCE ADEQUACY OR RELIABILITY STANDARD, HOWEVER YOU WANT TO KIND OF DEFINE THOSE.

BUT THAT IS KIND OF THE THINKING BEHIND THIS, AND THAT'S KIND OF WHERE THE, IF YOU WANT TO EXTRAPOLATE, YOU TAKE THE $10, THINK OF HOW MANY HOURS THERE ARE PER YEAR, AND THEN THAT, THAT KIND OF GETS YOU INTO SOMETHING THAT, THAT IS, THAT IS IN THAT RANGE.

SO I GUESS TO PUT A FINER POINT ON THAT, WAS THAT HOW THE ANALYSIS WAS DONE IS THAT IT WAS ASSUMING THAT IT WOULD, THE FLOOR WOULD BE IN PLACE FOR EVERY HOUR OF EVERY DAY OVER THE COURSE OF A YEAR, MULTIPLYING THAT UP AND TRYING TO REACH A, A CERTAIN NUMBER, OR WAS THERE ANALYSIS SO THAT, THAT, THAT, THAT GIVES A, A FLAVOR OF IT.

UH, I'M THAT WE BASICALLY TRIED TO THINK OF IF, IF THIS WAS PAID FOR EVERY HOUR OF EVERY DAY, UH, OF EVERY MONTH OF EVERY YEAR, WHAT WOULD THAT APPROXIMATE? AND THEN IF WE ASSUME THAT THERE'S A, A GO TO THE EXTREME AND THERE'S A RELEASE FACTOR OF, UH, THAT, THAT FULLY, LIKE A FULLY OVERLAPPING RELEASE FACTOR, THEN WE COULD THINK OF THAT PAYMENT AS A, AS A PAYMENT THAT APPROXIMATES SOMETHING TO SUPPORT RESOURCE ADEQUACY.

OKAY.

THANK YOU.

OKAY, LET'S GO TO NED.

ALL RIGHT.

UM, I'LL, I'LL ALSO SAY THAT, UH, I APPRECIATE THE, UM, YOU KNOW, APPRECIATE Y'ALL PUTTING THIS TOGETHER AND, AND HAVING THIS DISCUSSION.

IT HELPS GIVES US, UH, CONTEXT AND IDENTIFY NEW AREAS.

UM, I WANTED TO SECOND SOME OF THE REQUESTS THAT TREVOR HAD FOR, YOU KNOW, SOME OF, SOME OF THE ADDITIONAL, UH, YOU KNOW, NUANCES, UH, IN VIEW IF, UH, KINDA HELP US UNDERSTAND.

I THINK THOSE ARE SOME GOOD THINGS TO ASK.

AND I AGREE, RYAN, THIS IS, UH, THIS IS DEFINITELY THE BEGINNING OF A DISCUSSION, SO I, I THINK IT'S HELPFUL TO HAVE THIS HERE AND, AND SET EXPECTATIONS ACCORDINGLY.

UM, I, I, I HAD GOTTEN THE QUEUE THOUGH.

UM, I WANTED TO RESPOND TO ONE COMMENT SHAMS HAD HAD, UM, NOT OPPOSED TO LOOKING AT THE DEMAND CURVES FROM A SEASONAL BASIS TO SEE IF THERE'S, YOU KNOW, THAT'S THE RIGHT WAY TO, UM, YOU KNOW, ALLOCATE, YOU KNOW, VALUE AND INCENTIVES.

BUT, UM, THE COMMENT ABOUT POSSIBLY DEFINING THE DEMAND CURVES DURING THE ANNUAL ANCILLARY SERVICE METHODOLOGY, UH, MADE THE HAIR ON THE BACK OF MY NECK, UH, STAND UP A LITTLE BIT.

AND I, TO THE COMMENT ABOUT HAVING MORE CERTAINTY IN WHAT THE MARKET DESIGN LOOKS LIKE, AND HAVING THAT BE THERE TO LET FOLKS SET EXPECTATIONS AND, AND MANAGE THEIR, THEIR COSTS AND RISKS ACCORDINGLY.

UM, I WOULD MUCH PREFER TO HAVE THAT BE SOMETHING THAT IS SET AND THEN WE, WE EVALUATE THE QUANTITIES AND, AND, UH, YOU KNOW, PERHAPS QUALIFICATIONS AND THINGS LIKE THAT ON A MORE REGULAR BASIS, BUT HAVE, UH, A LITTLE BIT MORE CERTAINTY ABOUT THE DEMAND CURVES LOOK LIKE, RATHER THAN TRYING TO SQUEEZE THAT INTO, UH, YOU KNOW, A, A MARCH THROUGH SEPTEMBER, I THINK IS NOW OUR, OUR OPERATING, UH, WINDOW FOR, FOR LOOKING AT THAT.

SO THAT'S THE COMMENT.

AND I, AND I THINK NOTIONALLY, WE WOULD EXPECT TO BE SETTING THE PROCUREMENT QUANTITIES THAT MAY INFLUENCE SORT OF THAT POINT ON THE, THE DEMAND CURVE AS PART OF THE, THE AS METHODOLOGY THAT, THAT WAS PART OF OUR INTENT JUST AS WE'RE SETTING THOSE, UH, HOURLY AND SEASONAL AND, AND, AND MONTHLY REQUIREMENTS FOR OTHER ANCILLARY SERVICES.

UM, AND WE HAD, WE HAD NOT YET CONTEMPLATED MUCH MORE AROUND DESIGN OF DEMAND CURVES BEING AN ANNUAL PROCESS RATHER THE, THE, THE COMPONENTS, MAYBE PARAMETERS THAT, THAT SHAPE THAT CURVE IN, IN A GIVEN HOUR A MONTH.

YEAH.

AND PARAMETERS IS A VERY DIFFERENT THING THAN THE, YOU KNOW, THE, THE STRUCTURE THAT CONNECTS THEM ALL.

SO, APPRECIATE THAT.

GO AHEAD, RYAN.

MAYBE JUST ONE THING I, I NEGLECTED TO NOTE IS THAT EVEN IF WE TAKE, AND I DO WANNA NOTE THAT THE, THAT THIS IS A CONCEPTUAL PROPOSAL, IT'S CERTAINLY OPEN TO FEEDBACK, BUT EVEN IF YOU WERE TO TAKE, JUST STRICTLY SPEAKING, OUR, OUR SIMPLIFIED EXAMPLE OF THE, LET'S SAY, A HUNDRED MEGAWATT RESOURCE, FOR EXAMPLE, UM, IF THE PAYMENT IS PAID EVERY DAY AND THE YOU HAVE TO BE, UM, EITHER ONLINE OR AVAILABLE, THEN NATURALLY, UM, THE RESOURCES THAT ARE MORE AVAILABLE, MORE OF THE HOURS OF THE YEAR ARE GOING TO RECEIVE MORE OF THE, YOU KNOW, THEY WILL BE ABLE TO RECEIVE MORE OF THAT ANCILLARY SERVICE AWARD.

SO THAT IS NOT, UH, COM COMPLETELY, UH, UH, MEANT TO ADDRESS SOME OF THE CONCERNS THERE.

BUT IF YOU WANT TO THINK ABOUT, UH, YOU HAVE TO REMEMBER THIS IS, THIS IS ONLY FOR A RESOURCE THAT THIS IS AN ANCILLARY SERVICE.

SO THE RESOURCE HAS TO BE AVAILABLE EVEN IF IT'S A FULLY OVERLAPPING, UH, UH, AWARD.

THANKS.

OKAY, TREVOR, SORRY, SORRY, THIS WILL PROBABLY BE MY LAST ONE.

UM, SO, UH, JUST, JUST WANT TO REITERATE ONE POINT ON THE, THE NEED FOR, FOR ADDITIONAL QUANTITATIVE ANALYSIS HERE AND, AND SOME OF THESE, THESE COMPLICATED DYNAMICS, PARTICULARLY WITH THE RELEASE FACTORS.

UM, AS WE THINK ABOUT THE RELEASE FACTOR, YOU KNOW, UM,

[01:15:01]

THAT COULD HAVE JUST A, AS LARGE AN IMPACT ON, ON THE PRICE AS SOME, AS THE, AS SDCS THAT CAN IMAGINE GETTING TO THE SAME LEVELS OF REVENUE INJECTION INTO THE MARKET BY SETTING A VERY LOW RELEASE FACTOR WITH A VERY LARGE PLAN REQUIRING A NU LARGE NUMBER OF UNITS TO RESERVE, YOU KNOW, LARGE PORTIONS OF THEIR HEADROOM AND, UH, KIND OF KEEP THEM OFF TO THE SIDE.

UM, CONVERSELY, YOU COULD HAVE, UH, A VERY HIGH RELEASE FACTOR AND A, AND MAYBE A THE SAME SIZE PLAN AND, UM, WITH A DIFFERENT A SDC AND GET THE SAME DOLLAR AMOUNT, BUT IT'S GOING TO DIFFERENT RESOURCES OR IT'S GOING IN DIFFERENT, IT'S, YOU KNOW, UH, BEING ALLOCATED TO DIFFERENT HOURS.

SO SOME OF THESE DYNAMICS ARE, I THINK ARE, ARE REALLY IMPORTANT TO LOCK DOWN, UH, IF WE'RE PUTTING ALL OF OUR RELIABILITY STANDARD EGGS IN THIS BASKET.

THAT'S ALL.

DO YOU GUYS WANNA RESPOND, RYAN? YOU DON'T HAVE TO GET IN THE QUEUE EITHER TO RESPOND.

YEAH, UM, I THINK WE HAD A DISCRETION ON THAT.

UM, SO LET'S ASSUME THAT THERE IS NO RELEASE FACTOR.

WE JUST, I MEAN, IKA SAYS FOR SOME HOURS I NEED 2000 MEGAWATTS OF DRS TO ADDRESS THAT UNCERTAINTY, BUT WE PUT IT AT 10,000 MEGAWATTS, RIGHT? AND WHAT THAT WILL DO IS IT'LL GOOSE UP THE PRICES FOR EVERYTHING AND FOR EVERYBODY.

THAT'S THE MORE IMPORTANT ONE, RIGHT? SO, UM, WHAT THIS DOES WITH THE NON-ZERO RELEASE FACTOR, IF WE INCREASE THE, UM, THE DRS PAYMENT IS ONLY THE AS PART IS ONLY PAID TO THE RESOURCES THAT ARE ELIGIBLE, RIGHT? AND IF THE POWERS THAT BE SAY THAT THE ONLY GUYS WHO ARE ELIGIBLE ARE DISPATCHABLE RESOURCES, THE WIND DOESN'T GET IT.

NOW, THERE IS, IF WE KEEP THE OPERATIONAL RESERVE COMPONENT THE SAME AS WHAT IKA SAYS IT IS, THAT SHE NEEDS, THERE WILL BE A LITTLE BIT OF AN INCREASE IN OVERALL PRICES UNLESS WE CANNIBALIZE SOME OF NONS SPIN TO MEET THAT.

BUT THERE WILL BE SOME INCREASE, ASSUMING THAT SHE DOESN'T, RIGHT? BUT THAT DELTA INCREASE IN PRICES IS NOT AS MUCH AS IF YOU MADE IT 10,000 MEGAWATTS.

SO THAT, THAT'S, THAT'S THE THOUGHT PROCESS.

YEAH, THAT MAKES SENSE.

THANKS.

OKAY, ANDREW, I THINK USE YOUR BEST JUDGMENT BECAUSE I WAS GONNA PROPOSE A BREAK SOON ANYWAY, SO IF YOU WANT TO SAY SOMETHING ABOUT THE RELEASE FACTOR.

YEAH, I THINK PEOPLE WILL APPRECIATE A BREAK AFTER I GET DONE, UH, IS WHAT I HAVE TO SAY, .

UH, SO, UH, I'LL, I'LL PUSH THE RELEASE FACTOR TO MY SECOND POINT.

UH, IF RYAN, IF IT IS AS RYAN IS SAYING THAT WE'RE PLANNING ON SETTING THE PROCUREMENT VOLUME SUCH THAT WE'LL GET A BINDING $10 AN HOUR OUTPUT FROM THIS, THAT, THAT HARDLY SOUNDS LIKE A MARKET.

I MEAN, WE'RE JUST INJECTING $10 AROUND THE CLOCK KIND OF ARBITRARILY, AND IT HARDLY SOUNDS LIKE AN ANCILLARY SERVICE IF THERE ISN'T A RELIABILITY BASED METHODOLOGY TO DETERMINE WHAT THAT VOLUME IS.

IF YOU'RE JUST DETERMINING THE VOLUME SO THAT YOU CAN GET A BINDING CONSTRAINT SO THAT YOU CAN PUT $10 INTO THE MARKET EVERY HOUR, I DON'T KNOW WHAT THAT IS, BUT IT ISN'T THE MARKET.

AND AS FOR THE RELEASE FACTOR, I THINK IT WOULD BE HELPFUL FOR EVERYONE TO STOP INTERPRETING THAT CONCEPT AS IF IT'S AN INDEPENDENT VARIABLE.

THE, THE RELEASE FACTOR IS EITHER ZERO, IN WHICH CASE WE ONLY HAVE AN OPERATING RESERVE PRODUCT, OR IT IS VERY CLOSE TO ONE AND ALMOST ALL OF IT.

IT HAS TO BE VERY BIG TO BE A BINDING CONSTRAINT.

AND YOU HAVE TO HAVE ALMOST ALL OF IT RELEASED.

AND IF YOU IMAGINE WHAT THOSE QUANTITIES WOULD BE, IMAGINE YOU HAVE A HUNDRED THOUSAND MEGAWATTS OF DRS PLUS AND YOU HAVE A TWO A 98% RELEASE FACTOR, THE IDEA THAT YOU WOULD EVER TOGGLE THAT RELEASE FACTOR, IT, IT DOESN'T MAKE ANY SENSE.

YOU'RE DECIDING INDEPENDENTLY HOW MUCH OF THIS YOU WANT IS AN OPERATING RESERVE, AND HOW MUCH OF THIS YOU NEED TO GET THE $10 PER MEGAWATT HOUR BINDING CONSTRAINT.

AND THEN THE RELEASE FACTOR IS JUST A NUMBER YOU CALCULATE BASED ON THOSE TWO INDEPENDENTLY DERIVED QUANTITIES.

SO, I MEAN, IT'S EVEN IN THE TITLE OF THE NPRR AS IF THIS IS SOME FLEXIBILITY TO MOVE THIS RELEASE FACTOR AROUND, I, IT JUST DOESN'T REALLY WORK LIKE THAT.

I, I THINK THAT'S, YOU KNOW, KIND OF A MISCHARACTERIZATION OF WHAT THE RELEASE FACTOR IS.

OKAY.

DO YOU WANNA RESPOND OR DO YOU WANNA MOVE ON? MOVE ON.

OKAY.

SO I WAS GONNA PROPOSE THANK YOU ANDREW.

UM, WE ARE KIND OF GOING TO A NEW SUBSECTION ON STILL IN THE COMMON DESIGN FEATURES ON SETTLEMENT.

SO I THINK WE COULD TAKE A BREAK HERE OR WE COULD TAKE A BREAK AFTER THOSE TWO SLIDES, FINISH THIS SECTION.

SO WE'LL DO THE TWO SETTLEMENT SLIDES.

I THINK WE CAN FINISH THIS SECTION

[01:20:01]

AND THEN TAKE A BREAK BEFORE THE UNIQUE DESIGN FEATURE SECTION WOULD.

ALRIGHT, UM, LIKE TO HAND IT TO, UH, MAGGIE SHANG FROM ACROSS SETTLEMENTS TEAM TO COVER THE NEXT FEW SLIDES.

HI, THIS IS MAGGIE.

CAN YOU HEAR ME? YEAH.

PERFECT.

OKAY.

SO YEAH, THESE NEXT TWO SLIDES REFER TO THE COMMON DESIGN FEATURES FOR SETTLEMENTS FOR BOTH OF THESE NPRS.

SO SINCE DRRS IS GOING TO BE TREATED LIKE ANY OTHER ANCILLARY SERVICE TECH THAT WE HAVE, YOU'LL SEE THAT, UM, ALL OF THE SETTLEMENTS ARE ESSENTIALLY DUPLICATED FOR THIS NEW DRRS, UM, FOR DAM AND REAL TIME.

SO THE FIRST ONE FOR THE DAY AHEAD MARKET, ALL OF THE RESOURCE SPECIFIC DRS AWARDS AND DRS ONLY AWARDS WILL BE PAID IN DAM THE DAM MARKET CLEARING PRICE.

AND THOSE CHARGES WILL BE ALLOCATED ON A LOAD RATIO SHARE BASIS THE SAME WAY ALL OF THE OTHER AS PRODUCTS ARE DONE FOR R QUALIFY FOR RUCK MAY COOL PAYMENTS OR R CLAWBACK CHARGES.

SO WE'LL EXCLUDE THOSE FROM THOSE SETTLEMENTS.

AND FOR ANY DRS DEPLOYMENTS THAT ARE CONTIGUOUS WITH A, UM, REAL RUCK, ESSENTIALLY A R THAT WAS FOR CAPACITY, THAT'S NOT A DRS DEPLOYMENT FOR THOSE CONTIGUOUS BLOCKS, WE, THEY WILL NOT RECEIVE STARTUP COSTS AND WE WILL ONLY, UM, USE THE MINIMUM ENERGY COSTS FOR THE R GUARANTEES FOR THOSE R HOURS.

FOR THE R MAKE HOLD CALCULATION FOR THE R CAPACITY SHORT CALCULATION, THE QSCS DRS POSITION WILL BE INCLUDED IN THE CALCULATION.

SAME AS ALL OF THE OTHER ANCILLARY SERVICE POSITIONS.

WE'RE ALSO GONNA ADD A NEW ANCILLARY SERVICE AND BALANCE SETTLEMENT THAT'S, UM, GONNA MIMIC HOW THE OTHER ANCILLARY SERVICES ARE DONE FOR DRRS.

SO ESSENTIALLY IT'LL TAKE YOUR DRS REAL-TIME REVENUES AND COMPARE THOSE TO THE REVENUES RECEIVED, UM, FOR, UM, DAM AWARDS, SELF ARRANGED AWARDS, AND THE DELTAS OF YOUR TRADES.

AND I CAN TAKE SHAMS QUESTIONS IF YOU WANT NOW OR AT THE END OF THE NEXT SLIDE.

EITHER ONE.

GO, GO AHEAD.

NOW IF YOU'RE, YOU'RE WILLING, SHAM? YES.

SO YOU SAY THAT, UM, DRS DO NOT QUALIFY FOR R MAYLE AND THEN IN THE NEXT BULLET YOU SAY THAT, YOU KNOW, ONLY MINIMUM ENERGY COSTS FOR ROCK CARS WILL BE INCLUDED IN THE RUG GUARANTEE.

SO IF THERE IS A RUG GUARANTEE, THAT MEANS THERE IS A RUG MAYLE.

SO FOR THE, THE SECOND BULLET, IF THERE IS A DRS DEPLOYMENT THAT IS CONTIGUOUS WITH A R DEPLOYMENT, SO IF THOSE TWO BLOCKS ARE TOUCHING, WHENEVER WE'RE DOING THE ANALYSIS FOR THE RUCK WILL MAKE WHOLE PAYMENT ONLY THOSE R HOURS THAT WERE FOR THE TRUE RUCK HOURS, WE WILL HAVE THE MINIMUM ENERGY COSTS INCLUDED IN THE R GUARANTEE.

SO WE'RE NOT GONNA INCLUDE THE MINIMUM ENERGY COSTS OR STARTUP COSTS FOR THE DRS DEPLOYMENT PORTION.

IF THOSE TWO BLOCKS ARE TOUCHING, IF IT WAS, IF IT GOT A DRS OR THEN IT WOULD NO LONGER BE A R HOUR.

SO IT WOULDN'T, THERE WOULDN'T BE ANY GUARANTEE WITH THAT.

FOR MEAN ENERGY.

YEAH, SO LET'S SAY HOURS, LIKE LET'S SAY HOURS ONE THROUGH FOUR IS A DRS DEPLOYMENT AND THEN LATER ON RUCK CAME AND GAVE THEM, UH, LIKE A ACTUAL R DEPLOYMENT FOR HOURS FIVE THROUGH 10.

SO HOURS ONE THROUGH, I GUESS, I DUNNO IF I SAID ONE THROUGH FIVE.

SO ONE THROUGH FIVE IS DRRS.

THOSE HOURS WILL NOT BE INCLUDED IN THE RUT GUARANTEE FOR STARTUP OR MINIMUM ENERGY, BUT THOSE HOURS FIVE THROUGH 10, WE'RE ONLY GONNA INCLUDE THE MINIMUM ENERGY COSTS IN THE RUT GUARANTEE.

WE'RE NOT GONNA INCLUDE STARTUP COSTS FOR THEM, SO WE'RE NOT GONNA CONSIDER THEM FOR STARTUP COSTS.

OKAY.

THAT MAKES SENSE.

THANKS JEFF.

YEAH, SO, UH, MY QUESTION IS RELATED TO THE DIFFERENCE BETWEEN A DRS DEPLOYMENT AND A NORMAL R WHAT DETERMINES WHETHER IT'S A NORMAL R OR A DRS DEPLOYMENT? SO FOR THE D SO THAT INFORMATION WILL BE GIVEN TO US WHETHER THE R ENGINE, UH, DEPLOYED THEM FOR DRS DEPLOYMENT OR IF THEY DEPLOYED THEM FOR A REAL R SO, SO DOES A DRS DEPLOYMENT MEAN I HAD A DRS AWARD OR DOES IT JUST MEAN MY COP STATUS OR DRS? 'CAUSE I WAS TRYING TO GET A REAL TIME AWARD, I BELIEVE.

SO I'M GONNA GO AHEAD AND SEE IF, UH, I CAN ASK FOR HELP FROM SOMEONE TO HELP ANSWER THAT QUESTION AS WELL.

RYAN'S READY? SURE.

SO

[01:25:01]

IT'S, IT'S BASED ON THE COP STATUS.

SO IF YOU'RE AN OFFLINE RESOURCE, UM, YOU'LL NEED TO HAVE A STATUS OF DRRS IN THAT, THAT'LL BE YOUR RESOURCE.

SO DID I SAY OFF? YEAH.

OKAY.

UM, HAVE A STATUS OF DRRS.

IF, IF YOU'RE INTENDING TO, YOU KNOW, SUBJECT TO ALL WHAT WE TALKED ABOUT, IF IT WAS AWARDED IN DAM OR YOU WANT TO, UM, UH, BE AWARDED IN REAL TIME, YOU HAVE THAT STATUS OF DRS THAT INDICATES YOU'RE OFFLINE AND AVAILABLE FOR A-A-D-R-S DEPLOYMENT, BUT IT IS VIA THE R ENGINE.

SO I KNOW THAT'S A BIT OF A FINE DISTINCTION.

IT IT, IT LEANS BACK TO MY COP STATUS, RIGHT? IF MY COP IS DRS YES, THEN I IT WOULD BE A DRS DEPLOYMENT.

THAT'S CORRECT.

NOT NECESSARILY TIED TO WHETHER I GOT AN AWARD, AN AWARD PAYMENT OR NOT.

THAT'S CORRECT.

YEAH.

OKAY.

THANK YOU.

SHANE.

YEAH, SHANE, THOMAS, MICHELLE, THANK YOU.

I'M BE, I MIGHT BE MUDDYING THE WATERS MORE, BUT I, IT'S MAKING ME THINK IF, SO IN, IN RUCK IT SEEMS LIKE ALL OF YOUR CAPACITY IS EITHER AS, IT CAN ONLY HAVE ONE STATUS, IS THAT RIGHT? SO IN LIKE RUCK YOU WOULD, YOU HAVE BETTER COP STATUS OR DRS AND YOUR, YOUR ENTIRE IS SEEN AS THAT, UM, TYPE OF RESOURCE.

BUT IS IT POSSIBLE TO SAY THERE'S A 200 MEGAWATT RESOURCE THAT HAS A HUNDRED MEGAWATTS OF DRRS? COULD, IT COULD RUCK, IS RUCK GONNA DEPLOY YOU AS DRS FOR 200 MEGAWATTS? OR IS IT, IS THERE A SPLIT OF THE TWO? COULD YOU GET DRS FOR HALF AND RUED FOR HALF? YOU KNOW, R DOES NOT AWARD DRRS.

IT DOES AWARD FOR THE OTHER AS, SO IT'S JUST A COMMITMENT INSTRUCTION.

YEAH, THE COMMITMENT INSTRUCTION.

SO THAT'S COMPLETELY, IF WE HAVE A ONE MEGAWATT, I MEAN, WE DON'T EVEN LOOK AT YOUR DAY HEAD POSITION OR YOUR TRADES OR ANYTHING.

IF YOU SAY YOUR STATUS IS DRRS, IF WE, IF R COMMITS THAT RESOURCE WITH A-D-R-R-S STATUS, IT'S A-D-R-R-S DEPLOYMENT, WHETHER IT'S FOR ONE MEGAWATT OR 300 MEGAWATTS, WHATEVER IT IS, RIGHT.

THAT THAT'S ALL IT IS.

OKAY.

SO BY HAVING THAT STATUS, THE SAME THING WITH AN OFFLINE STATUS, UM, WE DON'T LOOK AT YOUR POSITION FOR, YOU KNOW, WHAT YOU HAVE THERE.

I MEAN, IF R REQUIRES THAT RE RESOURCE FOR CONGESTION OR WHATEVER IT IS, IT'LL COMMIT THAT RESOURCE.

OKAY.

SO YEAH, IF YOU'RE, I MEAN THE DEPLOYMENT PROCESS IS REALLY JUST TO SAY FOR DRRS IT IS RE WHEN YOU TALK ABOUT DEPLOYMENT, I, WE ARE JUST TALKING ABOUT DOES R COMMIT A RESOURCE WITH THE STATUS OF DRRS DOESN'T TAKE ANYTHING ELSE INTO CONSIDERATION.

AND THAT RESOURCE, OF COURSE DRS MEANS THAT IT IS, IF THE COP STATUS IS DRRS, THAT MEANS IT'S OFFLINE.

OKAY.

BUT THEN YEAH, RUCK WILL SEE THE FULL CAPACITY OF THE UNIT AS AVAILABLE.

YEAH.

YEAH.

WHETHER OR NOT ALL OF THAT CAPACITY WAS AWARDED DRS.

THANK YOU.

ALRIGHT, RORY.

TRUE.

UH, JUST A, A FOLLOW UP, I, I GUESS I'M STRUGGLING A LITTLE BIT WITH THE DISTINCTION BETWEEN THE DRRS AND THE RUCK.

ARE WE SAYING THAT THE, THE RUCK IS ONLY GONNA BE UTILIZED WHEN THE DRS IS GONE OR IF IT'S RUCK IS CALLED A AS THE BASIS, UH, FOR THE, THE UNIT BEING BROUGHT ON BECAUSE OF A, A REGIONAL OR LOCAL, UH, ISSUE? UH, I'M JUST TRYING TO UNDERSTAND.

'CAUSE I, I THOUGHT THE WAY THAT THE, THE, UH, LEGISLATURE HAD LEFT IT WAS, IT WAS A ONE FOR ONE, UH, DISPLACEMENT OF RUCK UTILIZING DRRS.

SO I'M STRUGGLING WITH WHAT THE DECISION IS ON WHETHER SOMETHING IS RT OR IT'S DRRS.

GO AHEAD, RYAN.

SO AGAIN, YOU DID MENTION THE STATUTE, SO WE HAD TO KIND OF TAKE THAT AND FIGURE OUT A WAY TO TRANSLATE THAT INTO, UH, HOW OUR MARKETS WORK.

AND THE APPROACH THAT WE TOOK WAS THAT, UM, IT WILL BE DEPLOYED VIA THE, THE RUCK ENGINE AND TO SATISFY THAT KIND OF OFFSET, IF YOU WILL, UM, AS, AS A NIN POINTED OUT, THE, THE, THE COSTS.

IF, IF A RESOURCE IS, UM, HAS A-A-D-R-S STATUS IN ITS COP, IT'S UM, ITS STARTUP COSTS WILL BE SCALED TO, I THINK IT WAS 20%.

20%.

SO IN OTHER WORDS, IT WILL APPEAR CHEAPER THAN THE OTHER, UH, THAN THE STARTUP COSTS OF, OF OTHER NON DRS UNITS.

AND SO R WILL, AS AN OPTIMIZATION ENGINE, IT WILL AWARD OR IT WILL DEPLOY THAT RESOURCE FIRST BEFORE IT DEPLOYS

[01:30:01]

OTHER RESOURCES FOR RUCK.

AND SO THAT'S THE WAY THAT WE'VE, WE'VE KIND OF SAID WE HAVE THE, THESE DRS MEGAWATTS, UM, RUCK ENGINE IS GOING TO DEPLOY THEM FIRST ON THE BASIS OF THEM HAVING LOWER STARTUP COSTS, UH, TO RESOLVE A CAPACITY ISSUE.

AND THAT'S, THAT'S KIND OF THE BASIS THAT WE'VE, WE'VE REALIZED THAT THAT STATUTE, BUT I'LL, I'LL PAUSE THERE JUST TO MAKE SURE I, I ANSWERED THE QUESTION.

IF THERE WAS ANOTHER PIECE TO THAT.

WELL, WHAT, WHAT I'M TRYING TO UNDERSTAND IS ARE ARE YOU GOING TO UTILIZE ALL THE DRRS BEFORE YOU CALL A RUCK? OR IS IT BECAUSE THERE'S A LOCAL ISSUE THAT YOU HAVE TO CALL A RUCK BECAUSE THERE'S NOT A-D-R-R-S AVAILABLE.

UH, I'M JUST SPIT BALLING HERE, TRYING TO UNDERSTAND HOW YOU DISTINGUISH BETWEEN THE TWO.

SO I THINK THE, THE ENGINE WILL TRY TO DO THAT.

I, I DON'T KNOW IF WE CAN ALWAYS GUARANTEE IN EVERY CIRCUMSTANCE.

'CAUSE 'CAUSE R RUCK OPTIM, UH, ULTIMATELY IS AN OPTIMIZATION ENGINE THAT'S SOLVING FOR A NUMBER OF THINGS, NOT, NOT NECESSARILY JUST CAPACITY.

SO THERE MAY BE A, FOR INSTANCE, A CONGESTION ISSUE THAT IS NOT, THAT REALLY LIMITS THE, THE, THE TYPE OF RESOURCES THAT, THAT CAN RESOLVE THAT.

AND SO RUCK WILL CONTINUE TO MAKE THOSE, THOSE DECISIONS.

SO THERE IS NO CHANGE TO THE RUCK ENGINE IN THAT SENSE.

BUT WHAT WE ARE DOING IS MAKING THE, THE DRS AWARDED MEGAWATTS APPEAR LESS EXPENSIVE SO THAT RUCK WILL SELECT THEM FIRST BEFORE OTHER RESOURCES, MAYBE ALL OTHER THINGS BEING EQUAL.

MAYBE THAT'S THE BEST WAY TO PUT IT.

OKAY.

THAT'S WHAT I WAS LOOKING FOR.

THANK YOU.

OKAY, KYLE? YEAH.

SO FOR THE SETTLEMENT, THE QUESTION I HAD WAS KIND OF TO FOLLOW UP ON SHANE'S POINT.

YOU KNOW, IF YOU GET AWARDED, IF YOU'RE HAVE A 200 MEGA UNIT AND YOU GET AWARDED A HUNDRED MEGAWATTS AND YOU GET DEPLOYED ON A, IS THE ENTIRE UNIT NOW NOT AVAILABLE FOR RUCK MAKE WHOLE PAYMENT OR JUST THE 100 MEGAWATTS THAT WERE AWARDED DRS? LIKE, IS IT SCALED IN A WAY? OR IS IT, IF YOU GET ANY PARTIAL AWARD WHATSOEVER, YOU ARE NOT AVAILABLE FOR RUCK MAKE PAYMENT OR CLAWBACK? I BELIEVE WHENEVER YOU GET A-R-D-A-D-R-S DEPLOYMENT THROUGH THE RUCK ENGINE, THAT ENTIRE HOUR WOULD LOOK LIKE A DRS DEPLOYMENT FOR HOWEVER MANY MEGAWATTS IT WAS DEPLOYED FOR.

SO WE WOULD NOT GIVE YOU A RUCK MAKE PAYMENT FOR THAT HOUR OR FOR THAT BLOCK OF DEPLOYMENT.

OKAY.

SO YOU, THE, THE SYSTEM COULD PAY FOR FIVE MEGAWATTS, BUT IN REALITY THEY GET MY ENTIRE UNIT AND NEVER HAVE TO DO A MAKE R MAKE PAYMENT.

IS THAT CORRECT? LIKE ANY PARTIAL AWARD AUTOMATICALLY LOCKS YOU INTO NO R MAKE PAYMENT.

CY, WOULD YOU BE ABLE TO HELP WITH THAT QUESTION? UM, THERE IS NO IF, IF, IT DOESN'T MATTER WHAT YOUR AWARD ON THAT RESOURCE IN THE DAY HEAD MARKET OR THROUGH TRADES OR WHATEVER YOU'RE PLANNING TO PUT ON THAT RESOURCE, IF THAT RESOURCE IS COMMITTED BY RUCK, UH, AND THE COP STATUS IS DRRS, IT'LL NOT BE MADE WHOLE TO ANYTHING.

OKAY.

THAT ANSWERS MY QUESTION.

OKAY, CAROLYN, THANK YOU.

UH, JUST A QUICK QUESTION.

IS RUCK EVER GONNA DEPLOY OFFLINE DRS IF THE RELEASE FACTOR IS ONE? SO MAYBE I'M, I'M, OKAY.

SO LET'S SAY THAT THE RELEASE FACTOR IS ONE THAT MEANS WE ARE DOING A HUNDRED PERCENT, UM, OVERLAPPING.

RIGHT? UM, IN THAT CASE, IF, IF THERE'S A WHOLE BUNCH OF DRRS AWARDS, THEN I WOULD EXPECT A LOT OF THE OFFLINE UNITS IN THE COP, UH, WILL PUT A STATUS OF DRRS SO THAT THEY DON'T GET HIT WITH THAT AS IMBALANCE CHARGE.

SO THEN THEY WILL BE ANY, ANY TIME R COMMITS A UNIT, IT'LL PROBABLY BE ONE OF THESE DRRS UNITS.

RIGHT.

SO, SO I MEAN, IF WE GO WITH THE RESOURCE ADEQUACY CONSTRUCT, WE MAY NOT SEE ANY UNIT THAT'S HAVE A COP STATUS OF OFFLINE AVAILABLE.

MAYBE MOST OF THEM WILL BE DRS.

SO EVERYTHING IS A DRS DEPLOYMENT.

UM, I DON'T KNOW IF THAT ANSWERS YOUR QUESTION.

I THINK SO.

THANK YOU.

OKAY.

DAVE, DID YOU WANNA ADD SOMETHING

[01:35:01]

TO THAT ANSWER? YEAH, IF I CAN, JUST REAL QUICKLY, I, IS HAD KIND OF WALKED ON TO SORT OF A HYPOTHETICAL OF HOW THINGS MAY PLAY OUT IF WE'RE PROCURING MORE.

I GUESS THAT'S ONE THING I WANTED TO MAKE CLEAR BASED ON CARE'S QUESTION IS THE RELEASE FACTOR IS REALLY ABOUT HOW DRS GETS CLEARED IN THE DAY AHEAD IN REAL TIME MARKET.

IT'S KIND OF PART OF THE, THE PRICE FORMATION, HOW MUCH OVERLAP WE SEE ACROSS PRODUCTS.

I GUESS THE ONE THING I, I WANTED TO MAKE SURE WAS CLEAR, THE RELEASE FACTOR ITSELF HAS NO EXPLICIT OR DIRECT BEARING IN TERMS OF HOW R IS LOOKING AT IT.

AND I THINK THIS HAS BEEN, I THINK PART THAT IS A LITTLE BIT, UM, CONFUSING FOR FOLKS IS THE DRS AND THE DEPLOYMENT OF DRS THROUGH THE R PROCESS IS A FUNCTION OF THE COP STATUS NOT OF AWARDS.

AND THE RELEASE FACTOR ITSELF HAS NO SPECIFIC ROLE IN TERMS OF WHAT RUCK IS DOING.

IT MAY AFFECT JUST SORT OF HOW PEOPLE ARE SHOWING THEIR STATUS IN THE COP AND HOW, YOU KNOW, BEHAVIOR OVERALL.

BUT IT'S, IT'S NOT DIRECTLY AFFECTING WHAT RUCK IS DOING.

THANK YOU.

OKAY, ANDREW? YEAH, SO RELATED TO THERE, THERE ARE A FEW THINGS THAT ARE KIND OF CONFUSING ABOUT THIS.

UH, SO AS FAR AS THE RUCK OFFSET PROVISO, THE WAY I READ THE HOUSE BILL, IT SAYS THAT THE VOLUME OF RUCK PROCURED HAS TO OFFSET THE, OR THE AMOUNT OF DRS PROCURED HAS TO OFFSET THE AMOUNT OF R DEPLOYED.

HOW DOES THAT WORK? IF WE'RE PROCURING, YOU KNOW, 50,000 TO A HUNDRED THOUSAND MEGAWATTS OF RUCK AROUND THE CLOCK OR OF DRS AROUND THE CLOCK, THAT THAT'S MUCH BIGGER THAN THE VOLUME OF, OF RUCK CONSTRUCTIONS THAT WE HAVE.

THAT'S KIND OF A BIG ONE CONSIDERING THAT A LOT OF THE DESIGN, I THINK, THINK YOU COULD, COULD CUT TO MATT IF YOU WANTED TO, BUT GO, GO AHEAD.

WELL, I, I MEAN MATT MAY HAVE, UH, MAY WANT TO COMMENT ON THE LANGUAGE, BUT I THINK WHAT WE HAD SAID AT, AT THE OUTSET IS WE'VE BEEN GIVEN THIS, THESE, THIS SET OF STATUTORY REQUIREMENTS AND WE HAVE TO FIND SOME WAY TO TRANSLATE THAT INTO HOW OUR MARKETS WORK.

AND SO WHAT WE HAVE DONE IS THIS, THIS DESIGN PROPOSAL OF THE ROCK OFFSET IS THAT WHAT WE HAVE PROPOSED IS WE WILL USE, WE WILL DEPLOY DRRS MEGAWATTS THAT HAVE BEEN PROCURED MM-HMM .

BEFORE WE, UM, INITIATE ANOTHER RUCK.

AND TO DO THAT, IT'S THE FRAMEWORK THAT, THAT ANUP HAS OUTLINED HERE.

I THINK WE, WE'VE TALKED ABOUT THIS, THIS IS MORE IN THE OPERATIONAL SPHERE OF, OF HOW WE'RE TREATING THESE MEGAWATTS, BUT THAT'S THE WAY WE, WE'VE ATTEMPTED TO, TO REALIZE THE, UH, TO MEET THE REQUIREMENTS OF THAT STATUTE.

BUT, UH, MATTHEW MAY HAVE OTHER COMMENTS.

YEAH, I DON'T THINK I HAVE MUCH TO ADD TO THAT.

I THINK THAT THAT THERE'S, THERE'S NO WAY TO KNOW FOR SURE, UM, HOW MUCH RUCK IS BEING OFFSET.

SO WE ARE, AS THEY'VE, THE TEAM HAS SAID SINCE DRS IS BEING PRICED TO BE PROCURED BEFORE SOMETHING SOME OTHER UNIT WOULD BE RUCKED ON, UM, WE'RE, WE'RE ASSUMING THAT IT IS IN LIEU OF A RUCK.

SO IF IT'S A GIANT QUANTITY, THEN WE'RE GOING TO HAVE TO MAKE THAT ASSUMPTION THAT IT'S IN LIEU OF A ROCK.

MAY MAYBE ONE OTHER THING TO NOTE IS THAT TO THE DEGREE THAT, UM, IF WE HAD A DRS ANCILLARY SERVICE TO THE DEGREE THAT THAT INCENSE SELF-COMMITMENT, WHICH IS AGAIN, A LITTLE BIT OF A DIFFICULT THING TO, TO DISCERN THAT ALSO WOULD OFFSET R SO THERE IS AN OFFSET FOR THE OFFLINE DEPLOYMENT AND THERE WOULD BE A KIND OF OFFSET IMPLICITLY THROUGH THE, YOU KNOW, THE MARGINAL INCENTIVE TO, TO PROVIDE TO, TO SELF COMMIT AS A RESULT OF, OF DRS.

OKAY.

WELL THAT LAST COMMENT IS ACTUALLY, UH, HELPFUL BECAUSE I THINK IT RELATES TO ANOTHER CONCERN THAT WE HAVE, WHICH IS THAT FOR A LOT OF, YOU KNOW, IF YOU'RE GONNA SET THE CONSTRAINT HIGH ENOUGH TO BE BINDING IT, IT'S GOING TO GET AWARDED TO A LOT OF UNITS THAT WOULDN'T BE ABLE TO PROVIDE OFFLINE DRS.

SO YOU'LL, YOU'LL BE GIVING DRS TO A LOT OF ONLINE HEADROOM OF SLOWER UNITS, AND I THINK YOU'RE GOING TO BE INCENTIVIZING A LOT OF INEFFICIENT SELF COMMITMENTS.

AND SO ONE BENEFIT OF THAT IS THERE'S LESS NECESSITY TO R BECAUSE YOU JUST HAVE A LOT OF EXTRA CAPACITY ONLINE TO CAPTURE DRS PAYMENTS.

AND SO THAT'S MAYBE NOT A GREAT OUTCOME FROM A MARKET PERFORMANCE STANDPOINT, BUT, BUT WOULD POTENTIALLY RESULT IN FEWER ROCKS AND, AND I GUESS THE ECONOMIC, UH, BREAKOVER POINT IS REALLY SET BY THE DEMAND CURVE.

SO THAT'S, THAT'S WHERE SOME OF THE DISCUSSIONS NEED TO BE MADE.

AND GOOSING UP THE ODC ALSO HAS THE SAME ISSUE.

UM, YEAH, I REMEMBER YOU MADE THAT POINT DURING THE WORKSHOP AND I THINK IT'S, IT'S A LITTLE DIFFERENT JUST GIVEN, YOU KNOW, WE'RE TALKING ABOUT A BIG PROCUREMENT VOLUME OF SOMETHING LIKE 60,000 MEGAWATTS OR SOMETHING LIKE THAT.

NOT

[01:40:01]

10,000 MEGAWATTS OF, OF RESERVE PRICING.

SO IT'S, IT'S JUST A DIFFERENT, THE MAGNITUDES OF HOW MANY RESOURCES COULD BE GETTING PAID THIS BASED ON THIS DEMAND CURVE.

IT'S A LOT BIGGER THAN, YOU KNOW, IF WE'RE GETTING SHORT INTO THE, YOU KNOW, 5,000 MEGAWATTS OF RTL CAP OR SOMETHING LIKE THAT.

OKAY.

BOB PELTON.

YEAH.

UH, JUST TRYING TO GET THIS ALL CLEAR IN MY HEAD, WHICH ISN'T EASY BY THE WAY, BASED ON WHAT YOU'RE TALKING ABOUT WITH THE RA PIECE IN THERE ALONG WITH THE ANCILLARY SERVICE.

IF YOU'RE PROCURING 60,000 MEGAWATTS, YOU KNOW, 60 GIGS OF, OF DRRS 'CAUSE THE RA YOU'VE STARTED THE, THE, YOU KNOW, THE FACTOR, THEN YOU WOULD EXPECT, POTENTIALLY YOU WOULD NEVER HAVE A RUCK, RIGHT? 'CAUSE ALL OF THOSE MEGAWATTS WOULD BE AVAILABLE FOR A-D-R-R-S RUCK.

I MEAN, WHETHER YOU'RE PART OF THE, YOU KNOW, YOU'VE GOT TWO PIECES OF THIS.

YOU'VE GOT THE ASS DRRS, AND THEN YOU'VE GOT THE OTHER RA DRRS.

OKAY.

AND THERE'S AN OVERLAP RIGHT NOW.

THE QUESTION IS IF YOU PROCURE 10,000 MEGAWATTS OF, OF THE ANCILLARY SERVICE, BASICALLY, BUT YOU'RE PROCURING 60,000 MEGAWATTS OF TOTAL DRRS WILL THAT 50 GIGS OF DRRS BE AVAILABLE TO THE RUCK ENGINE FOR A-D-R-R-S RUCK? JUST LIKE THE OTHER 10,000 MEGAWATTS, EVERYTHING IS AVAILABLE TO THAT.

THAT'S WHAT I WANNA MAKE SURE OF.

SO THERE IS NO DISTINCTION.

SO THERE BASICALLY WON'T BE, THERE IS NO DISTINCTION IN SITE CHANCE RUCK WILL BE BASICALLY CLOSER TO ZERO, THE MORE YOU BUY ON THAT PIECE THEN, RIGHT.

OKAY.

ALRIGHT.

YEAH.

BRIAN, DID YOU WANNA ADD SOMETHING? OKAY, KEVIN? YEAH, I JUST GOT A QUICK OPERATIONAL QUESTION.

MAYBE THIS MIGHT BE WAY INTO THE WEEDS, BUT WE'LL SEE.

SO WHEN YOU PROCURE, LET'S SAY A FOUR BY TWO COMBINED CYCLE, ARE YOU AUTOMATICALLY IN THE RIGHT DECISION GONNA GO STRAIGHT TO THE FOUR BY TWO OR YOU'RE GONNA WALK IT UP FROM 1.1, ONE BY ONE ALL THE WAY UP? YOU GUYS START THINKING ABOUT, I MEAN, R AGAIN, DOESN'T LOOK AT WHAT AWARDS YOU HAD PREVIOUSLY.

RIGHT.

AND IT'LL LOOK AT YOUR STATUS.

SO IF, IF THE, I'M JUST, I'M JUST THINKING THROUGH IN TERMS OF YOU SELECTION, WHICH RESOURCES OF THE DRS, IT'LL, IT'LL, IT'LL CYCLE THROUGH.

IT'LL, IT'LL, IT WILL CYCLE THROUGH IT RESPECT THE TEMPORAL CONSTRAINTS AND THE TRANSITION METRICS AND ALL THAT STUFF.

WE'LL DO ALL THAT STILL.

YEAH.

SO IF, IF THE COP STATUS, THE WHOLE TRAIN IS OFFLINE.

YEAH.

AND THE STATUS FOR THE ENTIRE CONFIG, IT'S DS ARE DS IT'LL JUST, IT'LL TREAT IT AS A LONG, IT'LL CYCLE THROUGH, IT'LL JUST CYCLE UP.

OKAY.

I'M JUST TRYING TO THINK THROUGH FOR SELECTION OF WHAT, WHAT RESOURCES IN THE TRS BUCKETS GET SELECTED AND HOW THEY GET SELECTED.

NO, IT, IT, IT, WHAT ALL THAT TRUCK SEES IS A LOWER COST AND THE STARTUP AND MINIMUM ENERGY.

YEAH.

THAT'S ALL IT SEES WHEN IT SEES A-D-R-R-S-I GUESS I'M TRYING TO THINK THROUGH, WHEN YOU SELECT THROUGH, LET'S SAY, LET'S KEEP IT SIMPLE.

LET'S SAY, YOU KNOW, YOU GOT FIVE RESOURCES THAT HAVE DRS OPTIONALITY ONE RESOURCE.

COULD IT BE ANYWHERE FROM 200 MEGAWATTS TO A THOUSAND MEGAWATTS? WHAT DO YOU MINIMUM COST? IT'S GONNA BE MINIMUM COST DRIVING THE ENTIRE DECISION THERE.

YEAH.

AND, AND OF COURSE IF THERE'S ANY OTHER CONSTRAINTS LIKE, UM, TRANSMISSION CONSTRAINTS OR ANYTHING ELSE, WE'LL BE RIGHT IN THERE AS WELL.

YEAH.

OKAY.

OKAY.

UM, WE'RE GETTING FARTHER AND FARTHER AWAY FROM ANDREW'S PRE-B BREAK COMMENTS.

, UM, I THINK, YOU KNOW, LET'S, WE, WE'VE HAD A LOT OF QUESTIONS ON RUCK.

I THINK SOME VARIATIONS OF THE SAME QUESTION.

I'VE TALKED TO GORD, I THINK, OR COLL, BRING BACK A TIMELINE AND MAYBE, MAYBE VARIOUS, YOU KNOW, AMOUNTS THAT YOU OFFERED OR AWARDED VERSUS WHAT CAN BE ROCKED.

THAT SEEMS TO BE THE QUESTION THAT'S COMING UP, BUT I, I THINK WE WERE TALKING ABOUT A, A TIMELINE OF DAY AHEAD AWARDS AND THEN REAL TIME DEPLOYMENTS AND HOW THE, THE ROCK WOULD INTERACT THERE.

YEAH, I I THINK WE CAN, WE CAN REPRESENT THAT, UH, KIND OF A DAY IN THE LIFE OF THOSE EXAMPLES THAT WE'VE LISTED IN TABLES.

STEP THEM THROUGH WHAT'S HAPPENING IN, IN DAY AHEAD, WHAT'S HAPPENING IN IN ROCK, AND WHAT'S HAPPENING IN, IN REAL TIME.

AND, AND DO THAT IN A, IN ILLUSTRATIVE WAY TO HELP ADDRESS MAYBE SOME, SOMEWHERE THE, UH, THE CONFUSION IS, BUT HEARING WHERE THE, THE DIALOGUE HAS BEEN OVER THE LAST FEW MINUTES, THAT, THAT HELPS US TO FOCUS ON WHAT ARE WE, WHAT ARE WE SHOWING IN THAT, THAT DAY IN THE LIFE TYPE EXAMPLE.

AND MAYBE HAVE A, A FEW SCENARIOS THAT WE CAN WALK THROUGH

[01:45:01]

FOR THE NEXT MEETING.

AND GORD, YOU CAN LOOK AT THE QUESTION THERE.

I THINK I'VE MISSPOKE BECAUSE I GUESS THE, YOU HAVE THE STATUS OF DRS AND THEN THE, IT'S THE RUCK ENGINE THAT DEPLOYS YOU.

SO THE QUESTION IN THE CHAT.

THAT'S RIGHT.

SO DRS IS DEPLOYED VIA R BASED ON THE, THE COP STATUS.

SO, UH, SO THAT, THAT QUESTION, YOUR UNDERSTANDING IS CORRECT THAT, THAT RUCK DEPLOYS DRS RESOURCES.

UM, AND SO WHEN WE, WHEN WE INTERCHANGEABLY USE THE, THE PHRASE DRS DEPLOYMENT, IT'S BEING DONE THROUGH THE RUCK ENGINE.

OKAY.

LET'S, UH, SO WILL BRING THAT BACK FOR DISCUSSION AT THE NEXT WORKSHOP, AND LET'S SEE IF WE CAN LET, UH, MAGGIE FINISH UP ON THE, THE SETTLEMENTS.

THANK YOU.

UH, ANUM, CAN YOU GO TO THE NEXT SLIDE PLEASE? OKAY.

SO FOR THE REMAINING REALTIME UH, SETTLEMENTS, THERE IS GONNA BE A CHARGE FOR ANY DRS TRADE OVERAGES OR ANY DRS VIRTUAL AWARDS IN REAL TIME.

AND THOSE QUANTITIES WILL BE CHARGED THE REALTIME DRS MARKET CLEARING PRICE.

SO THE SUM OF THE A SM BALANCE CHARGE AND THE TWO CHARGES IN THE PREVIOUS BULLET WILL BE ALLOCATED ON A LOAD RATIO SHARE BASIS IN REAL TIME.

AND DRS REVENUES WILL ALSO BE CONSIDERED IN THE FOLLOWING SETTLEMENTS THE SAME AS ALL OF THE OTHER ANCILLARY SERVICE TYPES.

SO THOSE DRS REVENUES WILL BE USED TO OFFSET THE DAM GUARANTEE FOR DAM MAKE HOLE PAYMENTS.

UH, THE DRS REVENUES IN REAL TIME WILL BE USED TO OFFSET THE R GUARANTEE IN R MAKE HOLE PAYMENTS.

IT'LL BE USED IN THE EMERGENCY SETTLEMENTS WHENEVER YOU'RE BEING CONSIDERED FOR EMERGENCY PAYMENT THROUGH THOSE SCENARIOS FOR SWITCHABLE GENERATION, MAKE WHOLE PAYMENTS, REAL TIME ANCILLARY SERVICE DURATION PAYMENTS, AND, UH, DISPUTES FOR THE DAM SETTLEMENT FOR ANY MARKET PARTICIPANTS IMPACTED BY OMITTED PROCEDURES OR MANUAL ACTIONS TO RESOLVE THE DAM.

IN ADDITION TO THAT, THE DRRS ONLY AWARDS, WHICH ARE THOSE VIRTUAL AWARDS, WILL BE INCLUDED IN THE CALCULATION OF THE COUNTERPART'S MEGAWATT ACTIVITY IN THE DEFAULT UPLIFT CHARGES.

SO THOSE ARE MY, OKAY.

THE END OF THE SETTLEMENT SLIDES, UM, RANGING.

OKAY.

THE QUESTION WAS GRS DEPLOYMENT GETS PAID, UM, R-T-S-P-P QUESTION MARK, AND WHENEVER THE RESOURCE PROVIDES ENERGY IN REAL TIME, IT WILL GET PAID THE R-T-S-P-P AND ENERGY IMBALANCE.

OKAY.

OKAY.

SHAS? YEAH, I JUST WANTED TO, YOU KNOW, I'M SURE A LOT OF PEOPLE HAVE THE SAME QUESTION, BUT WHAT WE MEAN OUR R DEPLOYS DRS, IT'S ACTUALLY R COMMITS THE DRS RESOURCE.

IT DOESN'T DEPLOY THE ENERGY.

THE ENERGY IS DEPLOYED IN REAL TIME, YOU KNOW, BY SC AND IF IT DOES DEPLOY CAPACITY THAT'S BEING AWARDED DRS, THEN IT'LL BE AWARDED LESS DRS AND IT'LL BE AWARDED ENERGY, JUST LIKE ANY OTHER ANCILLARY SERVICE.

SO YOU'RE BASICALLY, UH, YOU KNOW, SUBSTITUTING, YOU'RE GOING UP THE ANCILLARY SERVICE DEMAND CURVE, AND YOU ARE AWARDING ENERGY.

UM, AND THAT'S WHAT THE DEPLOYMENT IN REAL TIME LOOKS LIKE FOR DRS CAPACITY AND .

UH, PLEASE FEEL FREE TO CORRECT ME ON THAT.

THAT'S FAIR SHAMS. AND, AND WHAT I WANT TO CLARIFY FROM MY EARLIER COMMENTS IS THAT THE, THE R UH, R ENGINE COMMITTING DRS RESOURCES AHEAD OF OTHER R RESOURCES, THAT'S FOR OFFLINE RESOURCES.

SO I, I HAD NOT MADE THAT DISTINCTION IN MY EARLIER COMMENT, SO I WANTED TO ADD THAT ON WHILE, UH, ADDRESSING THAT, THAT COMMENT SHAMS. OKAY.

OKAY.

ANY OTHER QUESTIONS OR COMMENTS? ALRIGHT, I THINK WE CAN TAKE A BREAK UNTIL THREE 10 AND RAISE YOUR EYEBROWS AT ME.

IS THAT TOO NOT ENOUGH TIME OR TOO MUCH TIME? IT'S FINE WITH ME BECAUSE IT'LL, IT WON'T REALLY BE THREE 10, IT'LL BE THREE 15.

LET'S GET BACK BY THREE 10 AND THEN SEE WHEN WE CAN START.

OKAY.

OKAY.

IF KOTS READY, I THINK WE CAN GO AHEAD AND GET STARTED.

[01:50:01]

OKAY.

UM,

[Unique Design Features of NPRR 1309 and NPRR 131O]

SO NEXT, UH, WE WILL LOOK AT, UH, COMPARISON OF, UH, 1309 AND 1310 NPRS, UH, BASICALLY AT VERY HIGH LEVEL LOOK AT THE DIFFERENCES BETWEEN THE TWO.

UM, SOME OF THIS MIGHT BE A RECAP OF THE DISCUSSION THAT'S ALREADY HAPPENED, UM, BUT 13, OH, UH, WITH 1309, UM, UH, BASICALLY DRS CAN BE, UH, PROVIDED BY ELIGIBLE OFFLINE AND ONLINE GENERATION RESOURCES.

UM, UH, THERE'S NO PARTICIPATION MODEL FOR ESRS IN 1309, AND, UH, ALSO, UH, THE RELEASE FACTOR IS NOT INCLUDED IN IT.

UM, WHEREAS IN 1310, UH, THERE IS A PROVISION FOR ESS TO PROVIDE A-D-R-R-S, UH, USING THEIR INJECTION CAPABILITY.

UM, THAT IS, UH, SUBJECT TO POCD APPROVAL.

AND, UH, THE DRS, UH, UH, AWARDS WOULD BE TO THE EXTENT, UM, THEY CAN MEET THE REQUIREMENTS, UH, NOTED BELOW FOR ESRS.

UM, THE OTHER, UH, DESIGN FEATURE IS THE OPTIONALITY TO SUPPORT RESOURCE ADEQUACY.

UM, AGAIN, THIS IS, UH, THROUGH THE DRRS RELEASE FACTOR CONCEPT.

SO WHERE YOU HAVE THIS NUMBER, WHICH, UH, CAN BE SET FROM ZERO TO ONE AS A FUNCTION OF, UM, THE REQUIREMENTS FOR OPERATING RESERVE AND IF THERE IS ANY FOR THE RESOURCE ADEQUACY COMPONENT.

UM, THE DRS RELEASE FACTOR, UH, HAS BEEN SET TO ZERO, UM, AND WILL NOT BE, UH, CHANGED UNTIL, UNLESS, UH, WE RECEIVE A-P-O-C-T APPROVAL.

UM, IN THE CASE THAT, UH, ESRS ARE ELIGIBLE TO PROVIDE DRS, UH, THEN, UH, IN THE ROUGH CAPACITY, SHORT CALCULATIONS FOR THE IRS, THE RELEASE FACTOR WILL BE PART OF THE ACCOUNTING FOR THE ESRS STATE OF CHARGE.

UH, JUST WANT TO QUICKLY SHOW THE SLIDE, UM, JUST FOR REFERENCE ONCE AGAIN.

UM, UH, THIS TALKS ABOUT THE RELEASE FACTOR CONCEPT, UH, WHICH, UH, IS WHERE YOU CAN HAVE A SHARING OF DRRS, UH, BETWEEN ENERGY AND OTHER ANCILLARY SERVICES, UM, SIMILAR TO THE RAM SHARING CONCEPT IN RTC, UH, BETWEEN ENERGY AND REGULATION.

UM, RELEASE FACTOR OF ZERO MEANS THAT, UH, THERE'S NO OVERLAPPING CAPACITY OF DRRS WITH THE ENERGY OR OTHER A PRODUCTS.

AND SO IT'S, UH, PURELY, UH, MEANT TO SUPPORT, UH, UM, UNCERTAINTY OR OPERATIONAL, UH, RESERVES.

AS A QUESTION, ROY, IT LOOKS LIKE SORT OF A ADMINISTRATIVE QUESTION.

UH, I WAS JUST GONNA ASK ON THAT, THAT PREVIOUS SLIDE, UH, AREN'T THE TOP TWO BULLETS EXACTLY THE SAME? I, I THOUGHT WE WERE TALKING ABOUT UNIQUE FEATURES OF EACH ONE OF 'EM.

UM, YEAH, I MEAN, IT'S JUST TO RECAP, UH, 13, 10, JUST TO SHOW THE DIFFERENCE TO HIGHLIGHT IT.

THANKS.

OH, YEAH.

I DON'T SEE A DIFFERENCE BETWEEN THE TOP BULLETS.

NO, THEY ARE, THEY ARE THE SAME.

YEAH.

OKAY.

THANK YOU.

OKAY.

UM, JUST WANTED TO GO THROUGH A SIMPLE EXAMPLE, UM, JUST TO SHOW HOW THIS WORKS.

UM, SO LET'S ASSUME WE HAVE A DRS QUALIFIED GENERATION RESOURCE, UM, AND WE ARE CONSIDERING, UM, A GIVEN, UH, OPERATING HOUR.

UM, LET'S SAY WE HAVE, UH, THE RESOURCE HAS AN HSL OF A HUNDRED MEGAWATTS AND LSL OF 10.

UM, ASSUME THAT THE, UH, RELEASE FACTOR CALCULATED, UH, ENDS UP BEING 0.8.

UM, SO NOW WE ARE LOOKING AT, UH, UH, BOTH THE DEADHEAD MARKET AND REALTIME MARKET, UM, AND ASSUME, UH, THAT THE GENERATION RESOURCE IS, UH, ONLINE IN BOTH, UM, WITH THE DIFFERENCE BEING, UH, THE REAL TIME CONDITIONS, UH, ARE TIGHTER THAN THOSE, UH, IN DAY AHEAD.

UH, NOTE THAT THESE, UH, VALUES SHOWN ARE JUST, UH, ILLUSTRATIVE.

SO ON THE LEFT, UM, THIS IS ONE, UH, POSSIBILITY, UH, FOR THE GENERATION RESOURCE IN DAY AHEAD.

UM, SO IT'S AWARDS COULD BE AS SHOWN WITH THE ENERGY BEING AWARDED, UH, 35 MEGAWATTS, UH, ALL THE OTHER ANCILLARY SERVICES, 45.

AND THEN THE NON-OVERLAPPING, UH, PORTION OF DRS, UH, WOULD BE 20 MEGAWATTS.

AND GIVEN THE RELEASE FACTOR OF 0.8, UH, TOTAL, DRS,

[01:55:01]

UH, IS A HUNDRED MEGAWATT, UM, ON THE RIGHT, UH, WE HAVE FOR THE SAME RESOURCE, UH, IN REAL TIME.

UM, SO ASSUME WE, UH, GO SHORT, UH, ON ANCILLARY SERVICES, UH, STARTING WITH DRS IN THE PRIORITY.

UM, THIS IS ONE POSSIBILITY FOR THE REAL TIME AWARDS.

UM, IN THIS CASE, UH, ENERGY HAS, UH, THE ENERGY AWARD HAS INCREASED TO 60 MEGAWATT.

UH, OTHER A S UH, BUMPED DOWN TO 35.

AND THE NON-OVERLAPPING, UH, PORTION OF DRS IS, UH, FIVE MEGAWATTS.

UM, AGAIN, WITH THE RELEASES IS FACTOR OF 0.8.

UH, YOU HAVE TOTAL DRS, UH, OF 25 MEGAWATT.

UM,

[Comparison of Aurora’s DRRS Ancillary Service (AS) Plus and NPRR 1310]

THIS SLIDE, UM, NEXT WE WANTED TO, UH, COMPARE, UM, THE AURORA REPORT, UH, TO, UH, NPRR 1310 AT A VERY HIGH LEVEL.

UM, AND SO WE ARE, UM, SPECIFICALLY WE ARE, UH, LOOKING AT THE, AT AURORA'S, UH, DRRS, UH, AS PLUS, UH, APPROACH.

UM, AND SO WE JUST WANTED TO POINT OUT THAT THERE ARE CERTAIN DIFFERENCES BETWEEN, UH, THE CONCEPTS, UH, THAT WERE PRESENTED BY AURORA IN A STUDY.

AND, UH, NPRR 1310.

SO AURORA'S APPROACH, UH, BASICALLY CONSIDERS AN HOURLY AVAILABILITY PAYMENT, UM, TO ELIGIBLE DISPATCHABLE RESOURCES TO ADDRESS LONG-TERM RESOURCE ADEQUACY NEEDS.

UM, AND THEY HAVE MODELED, UH, TWO CASES.

UH, IN THE FIRST CASE, UH, ONLY THE THERMAL OR DISPATCHABLE, UH, RESOURCES ARE ELIGIBLE.

AND THEN THEY MODELED A SECOND CASE IN WHICH THE LONGER DURATION AND THERE THE SPECIFIED FOUR R UH, BATTERIES THAT THOSE ARE ALSO, UH, ELIGIBLE.

UM, ON THE OTHER HAND, UH, NPR 1310, UH, CONSIDER, UH, CONSIDERS A RELEASE FACTOR OR CONTAINS A RELEASE FACTOR, UH, CONCEPT, UH, WHICH WILL BE SET TO ZERO UNTIL, UNLESS, UH, PUCD APPROVES OTHERWISE.

UM, THIS NPRR UH, ALLOWS ELIGIBLE ONLINE AND OFFLINE GENERATION RESOURCES, UH, TO PROVIDE DRRS.

UM, AND IT ALSO HAS AN OPTIONALITY, UH, TO ALLOW ESR PARTICIPATION, UH, FROM ESRS, UH, BY USING THEIR INJECTION CAPABILITY.

UH, NOTE THAT, UM, FOR RESOURCES, UH, TO BE AWARDED DRRS, UH, THEY HAVE TO OFFER DRS, UM, AND, UH, DRS UH, AWARDS ARE SUBJECT TO SYSTEM AND RESOURCE LEVEL CONSTRAINTS, UH, AS SHOWN IN THE EARLIER SLIDE.

UM, ANOTHER DIFFERENCE, UH, HERE IS, UH, AURORA HAS, UH, CONSIDERED, UH, IN ITS STUDY AN ANNUAL BUDGET, UH, FOR THE PAYMENT AMOUNTS, WHICH, UH, DEPENDS ON THE PRIOR YEARS, UH, P NET CONE VALUE, AND IS ALSO SUBJECT TO A CAP OF, UH, $5 BILLION.

UM, WHEREAS IN NPR 1310, UH, THERE'S CURRENTLY NO, UH, BUDGET CONSIDERED, UM, THE WAY AURORA CALCULATED.

ITS, UH, UH, UH, I GUESS, UH, JUST TO CLARIFY THERE, WHERE IT SAYS NO DEMAND CURVE, SO THEY HAVE, UH, AURORA HAS, UH, MODELED A PROCUREMENT CURVE.

UH, IF YOU REMEMBER, UH, IN THE PRESENTATION IS THIS S SHAPE CURVE, WHICH THEY CALL, UH, THE DEMAND CURVE, WHICH, UH, BASICALLY CONCENTRATES THE ALLOCATION OF, UH, EARLY PAYMENTS, UM, INTO PERIODS IN WHICH, UH, THEY ANTICIPATE, UH, HIGHER, UH, SYSTEM STRESS.

AND, UM, SO THEY HAVE, YOU KNOW, PROCUREMENT VOLUMES, UH, BASED ON, UH, ANTICIPATED SYSTEM STRESS.

WHEREAS, UH, WITH NPR 1310, UH, WE HAVE A SLOPED, UH, ANSWER SERVICE DEMAND CURVE.

UM, AS SHOWN BEFORE, UM, IN THIS CASE, A DRS IS, UH, PROCURED IN DATA MARKET AND REAL TIME MARKET LIKE ANY OTHER ANSWER SERVICE.

AND IN BOTH CASES, UH, WE HAVE THE SAME DEMAND CURVE.

OKAY.

UM, NOT SEEING ANY QUESTIONS? NO, NO QUESTIONS.

UM,

[Additional Design Considerations]

SO THERE ARE, UH, CERTAIN, UH, YOU KNOW, CERTAINLY PART OF, UH, TODAY'S DISCUSSION HAS BEEN, UH, ABOUT SOME OF THESE TOPICS.

UM, BUT I JUST WANTED TO HIGHLIGHT THAT, UM, THERE ARE CERTAIN, UH, ADDITIONAL, UH, DESIGN ASPECTS THAT NEED TO BE DISCUSSED AND CONSIDERED, UH, WHICH ARE NOT CURRENTLY PART OF, UH, THESE NPRS.

UM, SO I'LL POINT TO THE FIRST THING IS THE PROCUREMENT QUANTITIES.

[02:00:01]

UH, FOR DRS, UH, UH, IT'LL BE PART OF THE ANS ANNUAL, UH, METHODOLOGY FOR, UH, DETERMINING ANSWER SERVICE REQUIREMENTS.

UM, WE EXPECT, UM, THIS, UH, OPERATING RESERVE VALUE, IT COULD BE AN HOURLY, UH, VALUE, YOU KNOW, CHANGING, UH, UM, FROM OUT TO HOUR OVER THE YEAR.

UM, AND, UM, SO INITIALLY, UH, WE HAVE WITH, UH, EVEN WITH THE 1310, THE RELEASE FACTOR, UH, IS SET TO ZERO.

AND SO THEREFORE THERE IS, UH, NO OVERLAPPING, UH, COMPONENT OF DRRS.

AND THEREFORE THE DRS REQUIREMENT WILL BE, UH, SOLELY TO SUPPORT, UH, OPERATIONAL UNCERTAINTY.

UM, IF, UH, THE POCT DOES APPROVE, UH, MOVING TOWARDS A NON-ZERO, UH, VALUE OF RELEASE FACTOR, UH, DRS UH, MAY ALSO BE PROCURED TO SUPPORT A RESOURCE ADEQUACY.

UM, AND SO THEN THE COMBINATION OF, UH, THE OPERATIONAL UNCERTAINTY REQUIREMENT AND THE RESOURCE ADEQUACY REQUIREMENT, UH, TOGETHER WOULD GIVE YOU A RELEASE FACTOR.

UM, AND THIS RELEASE FACTOR WOULD BE A PARAMETER INPUT, UH, INTO BOTH THE, UH, DAY AHEAD AND, UH, REAL TIME, UH, CLEARING ENGINES.

UM, SO UNDER THE, UH, RELIABILITY STANDARD RULE, UH, UH, A COURT MASK, UH, CONDUCTOR TRIAL ASSESSMENT, UH, TO DETERMINE WHETHER THE COURT SYSTEM IS MEETING THE RELIABILITY STANDARD, UM, IN CASE THE, IF THE MODELING FINDS THAT A COURT IS NOT MEETING THE RELIABILITY STANDARD, UH, IN 2026 OR 2029, DRRS WILL BE CONSIDERED, UH, AS AMONG THE OPTIONS FOR MARKET DESIGN CHANGES.

SO CURRENTLY WE ARE ASSUMING THAT, UH, DRRS AS AN ANCILLARY SERVICE, UH, IS IMPLEMENTED, UH, UH, BY 2028, UH, AT LEAST.

UH, AND SO, UM, THE OPTION FOR A NON-ZERO RELEASE FACTOR IS EXPECTED TO BE CONSIDERED, UH, AMONG THE MARKET DESIGN OPTIONS IN THE, UH, 2029 RELIABILITY ASSESSMENT.

I'LL JUST TO BUILD ON WHAT AUP MENTIONED THERE, OBVIOUSLY WE'RE STILL GOING THROUGH THE, THE PROCESS OF, UH, OF WORKING WITH, UH, THROUGH THE, THE, THE PUC PROCESS TO, UH, ESTABLISH THOSE ASSUMPTIONS AND THE LIKE.

UM, AND I WANTED TO CLARIFY THAT, WHERE WE TALK ABOUT THE, THE OPTION FOR THE NON-ZERO RELEASE FACTOR THAT'S NOT EXPECTED TO BE IN THE, THE, THE BASE MODELING FOR A FUTURE YEAR, BUT WOULD, WOULD FACTOR IN IN SOME OF THE EVALUATION OF ALTERNATIVE MARKET DESIGN OPTIONS.

IN THE EVENT THAT THE RELIABILITY STANDARD ASSESSMENT SHOWS THAT THERE'S A GAP BETWEEN WHERE WE WOULD BE AND, AND WHERE IT WOULD NEED TO BE TO ACHIEVE THAT RELIABILITY STANDARD.

SO WHEN WE, WE TALK ABOUT INCLUDING, UH, INCLUDING THAT IN THE RELIABILITY ASSESSMENT, UM, AS, AS A NEW MENTIONED, IT'S, IT'S MORE IN THAT SORT OF MARKET DESIGN OPTIONS, UH, TO, TO CLOSE A GAP IF, IF ONE IS REVEALED TO EXIST AS OPPOSED TO BAKING THAT ASSUMPTION INTO THE, THE, THE MARKET DESIGN THAT'S, THAT'S MODELED TO TEST AGAINST THE RELIABILITY STANDARD.

OKAY.

UM, SO

[Next Steps]

TO CONCLUDE, UM, UH, WE WILL, WE EXPECT TO CONTINUE, UH, HAVING DISCUSSIONS, UH, IN, UH, FUTURE ATTACK, UH, WORKSHOPS.

UH, I THINK THE TIMELINE WAS SHOWN, UH, AT THE BEGINNING TODAY, UM, WHEN WE STARTED, UH, BASED ON, UH, TODAY'S DISCUSSION.

UH, I KNOW WE HAVE, UH, A FEW QUESTIONS, SOME ASKS, UH, WE'LL TRY TO, UH, CAPTURE AS MUCH AS, UH, OF THE ACTION ITEMS FROM THERE.

UM, AND TRY TO COME BACK, UH, WHEN WE COME BACK FOR THE NEXT WORKSHOP, TRY TO ANSWER AS MANY OF THEM AS WE CAN.

UM, A NOTE AGAIN, UH, AS SHOWN IN THE TIMELINE THAT THE BOARD HAS ASKED FOR UPDATES, UH, ON PROGRESS, UH, AT THE FEBRUARY AND APRIL BOARD MEETINGS.

UM, AND AGAIN, AS PER THE TIMELINE, UM, OT IS REQUESTING THAT TAC UH, SUBMIT A RECOMMENDATION, UM, FOR CONSIDERATION AT THE JUNE, UH, 2026, UH, BOARD MEETING.

UH, AGAIN, GIVEN THAT, UM, FOR EXAMPLE, 1309 IS BEEN DESIGNATED AS BOARD PRIORITY.

OKAY, WE HAVE A FEW QUESTIONS NOW.

KATIE, RICH, UM, I MIGHT BE PULLING AN ANDREW, BUT SINCE HE SAID TIMELINE, CAN I BRING UP WHAT WE DISCUSSED IN THE HALLWAY? SURE.

SO, UM, YOU KNOW, THIS IS VERY FOCUS INTENSIVE AND SO HAVING IT RIGHT AFTER WMS MAKES FOR A VERY LONG DAY.

UM, I HAVE TALKED TO THE CHAIR OF WMS AND HE WAS AMENABLE TO AT LEAST DOING A SWITCH, BUT IF YOU WERE ALSO OPENING TO ALTERNATIVE DATES

[02:05:01]

WHERE THIS COULD BE JUST THE ONLY THING THAT DAY, THAT WOULD ALSO BE GREAT.

SO, WANTED TO BROACH THAT AND SEE IF THERE WERE ANY THOUGHTS ON FLEXIBILITY ON THAT.

WHY DON'T, UM, I'LL, I'LL GET WITH ANNE AND, AND BLAKE MAYBE, AND WE CAN SEE OTHER DATES.

'CAUSE WE WERE, THE OTHER THING ANNE AND I HAD CONSIDERED WAS, YOU KNOW, WHAT IF WMS GOES LONG, RIGHT? IF YOU GO UNTIL TWO, OR EVEN IF YOU GO UNTIL ONE 20, DO YOU WANT TO START THIS 10 MINUTES LATER? UM, SO WHY DON'T, WHY DON'T WE TAKE A LOOK AT DATES? ARE WE OKAY WITH THE GENERAL TIMING OF ABOUT ONCE A MONTH? I THINK THAT WAS SOMETHING I WANTED TO GET INPUT TODAY.

WE DO HAVE SOME HOMEWORK, I THINK, UM, OR WE WILL COME BACK WITH A SORT OF TIMELINE.

SO WE CAN SEE HOW THE AWARDS OR DEPLOYMENTS ARE MADE, UM, AND DEPLOYMENTS.

UM, AND THEN I THINK, UM, WE WANTED SOME COMMENTS ON THE, A SDCS PROBABLY FROM ERCOT AND FROM STAKEHOLDERS.

I THINK WE'LL PROBABLY SEE SOME GENERAL COMMENTS ON 1310 FROM STAKEHOLDERS.

SO IF THERE'S, YOU KNOW, IF FOUR WEEKS ISN'T RIGHT FOR THAT, IF, IF THREE WEEKS IS BETTER OR SIX WEEKS IS BETTER, I'M, I'M OPEN TO THAT AS WELL.

BUT IF PEOPLE LIKE THE GENERAL KIND OF MONTHLY TIMELINE I WAS, I WAS AMENABLE TO THAT.

TO THE MONTHLY, YEAH.

OKAY.

YEAH, I JUST WANTED TO CHECK THAT WITH PEOPLE.

'CAUSE I THINK WE WOULD LIKE AND EXPECT COMMENTS FROM INTERESTED STAKEHOLDERS FOR NEXT TIME.

OKAY.

SO I'LL GET WITH ANN AND, UM, AND BLAKE AND, AND LOOK AT, AT ALTERNATE DATES.

OKAY.

THAT WAS EASY ENOUGH.

UH, SHAMS. YEAH, I WAS WONDERING IF, UH, ANYONE FROM ARD KNEW THE SOURCE FOR THAT $5 BILLION CAP, UH, FOR DRS IN AURORA'S PROPOSAL.

IT DOESN'T SEEM LIKE THE STATUTE OR ANYTHING HAS THAT CAP IN IT.

NO, I THINK THAT WAS A, UM, AND I, I WANNA AVOID GETTING BACK INTO THE, THE TYPE OF DISCUSSION THAT WE HAD ON DECEMBER 17TH.

'CAUSE AS THIS IS NOT INTENDED TO BE, UH, A, A FORUM FOCUSED ON AURORA'S ANALYSIS, BUT THAT WAS A, A, A LIMITING PARAMETER CHOSEN JUST TO ENSURE THAT THE MODELING DIDN'T SPIN OUT.

IT WAS NOT A, UM, IT WAS NOT A FIGURE THAT WAS TIED TO ANYTHING IN THE, IN THE STATUTE OR AN ASSUMPTION OF WHAT THE NUMBER SHOULD BE.

IT WAS A, UH, A MODELING PARAMETER TO HELP, UH, ENSURE THAT IT'S SOLVED OVER TIME.

OKAY.

YEAH, I THINK, UM, YOU KNOW, WHEN WE LOOK AT THE AS SDCS AND THE QUANTITIES AND STUFF, IT'D BE VERY IMPORTANT TO TIE IT TO, YOU KNOW, SYSTEM STRESS CONDITIONS JUST LIKE AURORA STUDY DID.

BECAUSE OTHERWISE YOU'LL JUST GET INEFFICIENT RESOURCES THAT AREN'T REALLY AVAILABLE WHEN YOU REALLY NEED THEM.

YOU KNOW, THERE'S NO INCENTIVE FOR RESOURCES TO BE AVAILABLE AT THE CRITICAL TIMES UNLESS ALL THE DOLLARS ARE THERE.

SO JUST LIKE WHEN WE LOOKED AT PCM OR EVEN THE AURORA STUDY, YOU KNOW, WE NEED TO REALLY TARGET THIS PAYMENT, UH, TO THE RIGHT TIMES.

OTHERWISE JUST SOME WHAT'S CALLED PAPER CAPACITY WILL SHOW UP, UM, THAT'S REALLY UNRELIABLE AND GETS ALL 90%, 95% OF THESE CAPACITY PAYMENTS.

SO I THINK, UM, FROM OUR PERSPECTIVE, I, I DON'T THINK WE CAN, UH, DO THE FULL ANALYSIS TO SAY HOW MUCH EXACTLY YOU SHOULD PUT INTO EVERY HOUR OF EVERY YEAR OF THE WHOLE YEAR.

UM, I THINK THAT'S BEYOND THE CAPABILITIES OF, UH, INDIVIDUAL MARKET PARTICIPANTS, BUT I THINK, UH, WHAT WE CAN HAVE AS COMMENTS IS, YOU KNOW, THE CONCEPT OF HOW YOU DISTRIBUTE IT AND TYING IT TO NET C AND ALL THAT STUFF.

THANKS.

THANKS FOR THE COMMENT SHAMS. ANDREW, DID YOU WANNA WEIGH IN OR GIVE A GOLD STAR WAY TO GO SHAMS? ALWAYS GLAD WHEN WE CAN AGREE WITH EACH OTHER.

OKAY.

LET'S GO TO STEVE REY.

HEY, THANKS STEVE.

RE, SIMBU CONSULTING.

HEY, UM, ON SLIDE 21, UH, I, I JUST NOTICED THAT WHEN TALKING ABOUT BATTERIES, UM, IT, THE ASTERISK IS, UH, OPERATING AT A SPECIFIED OUTPUT LEVEL FOR AT LEAST FOUR CONSECUTIVE HOURS.

AND I THINK THE, UH, LANGUAGE IN THE STATUTE IS HSL.

AND, UH, ERCOT HAS KIND OF, UH, VARIED ON THE INTERPRETATION OF THIS OVER TIME.

ORIGINALLY, I THINK THEY WERE SAYING, FOR EXAMPLE,

[02:10:02]

A HUNDRED MEGAWATT, A HUNDRED MEGAWATT HOUR RESO A BATTERY COULD PROVIDE 25 MEGAWATTS OF DSR TO THE EXTENT THAT THEY COULD ACT LIKE A 25 MEGAWATT FOUR HOUR BATTERY.

UM, BUT THEN I BELIEVE THE, THE MORE RECENT THAT I REMEMBER INTERPRETATION WAS THAT THEY REALLY NEEDED TO BE WHAT I WOULD CALL A FOUR HOUR NAMEPLATE BATTERY.

THAT A A HUNDRED MEGAWATT A HUNDRED MEGAWATT HOUR WOULD NOT BE ELIGIBLE EVEN IF BATTERIES WERE, WERE DEEMED ELIGIBLE.

UM, AND, AND I THOUGHT THAT'S WHERE IT STOOD RIGHT NOW.

BUT THEN THE LANGUAGE OF SPECIFIED OUTPUT LEVEL SEEMS A LITTLE VAGUE TO ME.

AND ARE YOU GIVING YOURSELF SOME WIGGLE ROOM ON, ON THAT SO THAT, THAT, THAT DETERMINATION IS STILL UP IN THE AIR AT THIS POINT, OR, OR AM I JUST OVERINTERPRETING THE LANGUAGE? WE'LL BE HAPPY TO, TO COME BACK WITH CLARIFICATION TO ELIMINATE THE CONFUSION IN A, IN A FUTURE ROUND OF THAT LANGUAGE SO THAT IT, UH, CLARIFIES THAT FOR YOU, STEVE.

THANKS.

UH, MATT ARTHUR, ALSO HAPPY TO SPEAK TO THAT.

SO, UM, I THINK WHERE WE LANDED IS THAT THE STATUTE DOES, UM, AS YOU MENTIONED, STEVE REFERRED TO, UM, HIGH SUSTAINED LIMIT.

SO IN 1310, UM, THE ESR WOULD HAVE TO CHANGE ITS HSL, UH, FOR QUALIFICATION PURPOSES, UM, BUT, UH, WOULD NOT HAVE TO CHANGE ITS HSL FOR, UM, SUBSEQUENT PERFORMANCE PURPOSES.

SO, UM, UH, NOT SURE IF I'M SAYING THAT QUITE ARTFULLY, BUT, UH, BUT GIVEN THAT THE STATUTE SAYS THAT IT'S DEVELOPING CRITERIA FOR RESOURCE PARTICIPATION AND THAT IT HAS THAT CAPABILITY OF RUNNING, UM, WE FELT THAT, UH, HAVING THE, THE ESR ADJUST ITS HSL ONLY DURING THE QUALIFICATION STAGE WOULD SATISFY THAT LANGUAGE.

SO, UH, THANKS.

SO I THINK WHAT I'M HEARING THEN IS THAT, UH, A HUNDRED MEGAWATT, A HUNDRED MEGAWATT HOUR BATTERY COULD ADJUST ITS HSL DOWN TO 25 MEGAWATTS DURING THE QUALIFICATION STAGE, ASSUMING THE FOUR HOUR STANDARD, AND THEN THUS QUALIFY TO PROVIDE 25 MEGAWATTS OF DRRS.

AND THEN DURING OPERATIONS, IT COULD, UH, ADJUST ITS HSL OR HAVE ITS HSL AT A HUNDRED MEGAWATTS WHILE STILL PROVIDING THAT 25 MEGAWATTS OF DRRS.

IS THAT? THAT'S RIGHT.

OKAY.

THANK YOU VERY MUCH.

OKAY.

JOHN RUSS HUBBARD.

JOHN RUS, TIEC.

UM, CAITLYN, THIS IS MORE OF A QUESTION FOR YOU FOR NEXT STEPS.

UM, IF WE'RE IN THE NEXT WORKSHOP DISCUSSING COMMENTS FROM STAKEHOLDERS, ARE WE WANTING THOSE COMMENTS TO BE FILED A WEEK BEFORE THE NEXT WORKSHOP? I'M, I'M NOT GONNA HOLD YOU TO A WEEK BEFORE I, BUT I, I DID ASK, UH, I ASKED ERCOT FOR THEIR OPINION.

RD SAID, PLEASE, I THINK, BUT I, I KNOW THAT THEY WOULD LIKE A COUPLE OF DAYS, YOU KNOW, A REASONABLE AMOUNT OF TIME TO, TO RESPOND, WOULD LOVE TO AIM FOR A WEEK, AND THEN CALIN CAN DECIDE HOW MUCH, UH, HOW MUCH LEEWAY TO GIVE AROUND THAT.

BUT JUST SO THAT WE HAVE AN OPPORTUNITY TO, TO DIGEST AND COME BACK WITH, UH, WITH MEANINGFUL AND, AND INTELLIGENT THOUGHTS ON, ON THOSE COMMENTS, I'M NOT GONNA CUT ANY COMMENTS OFF, BUT IF, IF THEY'RE THE DAY BEFORE, ARE WE GONNA HAVE, YOU KNOW, PRODUCTIVE CONVERSATION ABOUT THEM? PROB PROBABLY NOT.

RIGHT.

PERFECT.

THANKS.

YOU DON'T KNOW A COUPLE OF BUSINESS DAYS, RIGHT? YEAH, ENOUGH TIME FOR, FOR, YOU KNOW, JUST EXPECT THE RESPONSE TO BE COMMENSURATE WITH HOW LONG YOU GIVE US TO RESPOND.

OKAY.

UM, , THANKS.

UH, THE, YEAH, CONSTELLATION.

I JUST HAVE QUESTION ON SLIDE 24, THE, UH, RELEASE FACTOR EXAMPLE.

UM, SO, SO IN THEM, THE RELEASE FACTOR IS 0.8, AND I'M LOOKING AT THE REAL TIME.

UM, WHAT'S, UH, DO WE STILL NEED TO MAINTAIN THAT RELEASE FACTOR AT ALL, OR

[02:15:01]

IT'S NOT RESPECTED ANYMORE? UH, ? NO.

SO THE RELEASE FACTOR WILL STILL BE THERE.

IT'LL BE A INPUT TO BOTH DAM AND, UH, REALTIME ENGINES.

YEAH.

I SEE.

THAT'S, UH, MY NEXT QUESTION.

I SEE YOU HAVE A FORMULA HERE, UH, ONE MINUS 0.8 TIMES 25 EQUALS FIVE.

SO WHERE DOES THAT 25, UH, THE NUMBER COME FROM? YEAH, SO THE, I MEAN, YOU WOULD HAVE A NON-OVERLAPPING PORTION, WHICH IS FIVE MEGAWATT, UH, TO COVER OPERATIONAL UNCERTAINTY.

UM, AND THEN, YOU KNOW, YOU HAVE THE TOTAL AMOUNT, UM, ASSUMING POLICE FACTOR IS SET ON ZERO AGAIN, UM, TO COVER LIKE RESOURCE ADEQUACY.

SO IT DEPENDS ON, UM, I GUESS HOW MUCH IS PROCURED FROM THAT RESOURCE.

UM, WELL, I, I DON'T THE NUMBER YOU GIVE, I, I FEEL LIKE IT'S KIND OF BACKWARD, RIGHT? YOU COULD, YOU, YOU JUST, NOW YOU GIMME THE FIVE MEGAWATT FIRST AND THEN THAT'S HOW YOU GET THIS 25, THIS NUMBER I, BUT IF YOU ARE STILL RESPECTING THE RELEASE FACTOR, SHOULDN'T YOU HAVE THE FORMULA FIRST AND THEN THE NUMBER UP? YOU KNOW? SO, AND ALSO THAT, THAT'S ONE QUESTION.

THAT OTHER QUESTION IS, UM, UH, WHAT DO YOU MEAN, UH, ASSUME WE GO SHORT ON AS WHAT DOES IT MEAN? SO I THINK THAT'S ACTUALLY THE KEY TO THIS, UM, THIS SCENARIO THAT NEWCOMB HAS LAID OUT.

AND I THINK IT'S, IT'S ALSO IMPORTANT TO RECALL SOMETHING THAT WE HAD MENTIONED, I THINK IT WAS MAYBE DAVID MENTIONED EARLIER IN THE DISCUSSION, IS THAT THE, YOU KNOW, THE, THE RELE, THE, THE RELEASE FACTOR IS, IS AN INPUT, BUT WHAT'S ACTUALLY HAPPENING IS THE, THE ECONOMIC AWARDING OF, OF THIS ANCILLARY SERVICES A FUNCTION OF THE DEMAND CURVE AND THE REQUIREMENTS.

SO WHAT THIS IS ASSUMING IS THAT IN REAL TIME, UM, BECAUSE OF WHATEVER SITUATION, LET'S JUST SAY WE RUN INTO, UH, A PERIOD WHERE WE'RE, WE'RE, WE'RE, WE, WE ARE GOING SHORT ON, ON UH, DRRS, UM, THAT'S, YOU KNOW, THAT'S A FUNCTION OF THE, THE REAL TIME CO-OP OPTIMIZATION, THE ANCILLARY SURFACE DEMAND CURVE, ALL OF THAT.

SO AS A RESULT OF THAT, UM, WE HAVE PROCURED LESS DRS IN REAL TIME, OR WE'VE, PARDON ME, WE'VE AWARDED LESS DRS IN REAL TIME THAN WE DID IN DAM.

AND SO WHAT, UH, NPAS EXAMPLE HERE IS MEANT TO SHOW IS THAT THAT'S, UH, THAT'S FINE.

THAT'S, THAT'S AN EXPECTED OUTCOME.

WHAT DOESN'T CHANGE IS THE PROPORTION OF THE RELEASE FACTOR.

SO IN, IN THE DAM EXAMPLE, UM, I THINK THE AWARD WAS A HUNDRED MEGAWATTS, THE RELEASE FACTOR WOULD APPLY TO THAT TO DETERMINE THE, YOU KNOW, THE RATIO OF THE, THE OPERATIONAL RESERVE AND THE, THE, THE NON-OPERATIONAL RESERVE.

AND THAT EXACT SAME THING HAPPENS HERE.

THE WHAT CHANGES IS THE AMOUNT AWARDED BECAUSE IT'S A FUNCTION OF, OF, UM, REAL REALTIME ECONOMIC, UH, OPTIMIZATION.

DOES THAT ANSWER THE QUESTION ? THANKS.

YOU KNOW, THE, YOU KNOW, OKAY, SO LET'S HAVE A VERY SIM SIMPLIFIED EXAMPLE HERE.

JUST, YOU KNOW, THE DI UH, UM, DEMAND CURVE IS 400 MEGAWATT, AND WE ONLY HAVE THIS ONE RESOURCE.

IT'S VERY SIMPLIFIED, SO IT DOES NOT, UH, UH, WILL NOT PASS ANY, YOU KNOW, UM, CHECKS.

UH, ANYWAY, SO, SO THEN YOU AWARD THIS 100 BIS TO THIS ONE RESOURCE, RIGHT? AND THEN YOU GO TO OUR REAL TIME MARKET, AND I, YOU KNOW, I ONLY SEE D YOU KNOW, FIVE MEGAWATT OF DI AWARD.

UM, SO I JUST DON'T, DON'T UNDERSTAND THE SHRINKAGE.

I I THINK THE IMPORTANT POINT HERE, IF I CAN JUMP IN IS THAT WHEN WE GO SHORT ON THE NON-OVERLAPPING PART OF DRS, WE'RE GONNA HIT THE SLOPED PART OF THAT DEMAND CURVE.

AND SO NOW WE'RE GONNA CLEAR AT A PRICE HIGHER THAN $10.

AND SO WE'RE IN THIS EXAMPLE, WE ARE 15 MEGAWATTS SHORT OF THE NON-OVERLAPPING PORTION OF DRS AND THE WAY THE CONSTRAINTS ARE GOING TO BE WRITTEN IN SCED AND THE WAY THE DEMAND CURVE IS GONNA BE FORMULATED, YOU'LL START GETTING PRICES ABOVE $10 IN THAT SCENARIO.

OKAY.

SO THAT NOW GOES BACK TO MY ORIGINAL QUESTION.

THE FIRST QUESTION WAS, YOU KNOW, SO, UH, WHEN YOU, UM, THE, THE, THE RELEASE FACTOR

[02:20:02]

IS NOT REALLY RESPECT IT ANYMORE.

WELL, IT'S NOT .

I, I THINK WHAT'S INTERESTING IS THE REALTIME MARKET DOESN'T ACTUALLY DISTINGUISH BETWEEN THE RELEASED AND UNRELEASED DRS, IT'S JUST THAT WHEN THE QUANTITIES OF DRS GET SHORTER THAN THE RELEASED PART.

SO YOU WOULD HAVE TO GET SO SHORT THAT NOW YOU'VE BURNT THROUGH ALL OF THE RELEASED PART OF DRS, AND NOW THE ONLY DRS LEFT IS THE UNRELEASED DRS.

NOW THE PRICE IS GONNA START CLEARING HIGHER BECAUSE OF HOW THE DEMAND CURVE IS GOING TO OPERATE IN THE REAL TIME MARKET.

AND IF I'M TALKING OUTTA A SCHOOL, I SEE SI IS GONE, BUT MAYBE RYAN OR DAVE COULD CONFIRM THAT THAT'S THE RIGHT WAY TO UNDERSTAND IT.

NO, I THINK THAT'S A, THAT'S THE RIGHT WAY TO, TO UNDERSTAND IT.

I MEAN, MAYBE IN THIS EXAMPLE WE COULD PROVIDE A LITTLE BIT MORE, UM, CONTEXT.

I THINK THE IDEA WAS TO ILLUSTRATE THAT, THAT FOR ALL INTENTS AND PURPOSES, THIS IS A, THIS IS GONNA BE A, A SERVICE THAT'S CLEARED IN THE DAY AHEAD MARKET.

IT'S CLEARED IN THE REAL TIME MARKET.

UM, THE OUTCOMES OF THE, THE AWARDS ARE GONNA BE A FUNCTION OF WHATEVER IS HAPPENING, UM, IN THOSE MARKETS AT THAT TIME.

SO IT'S, IT'S, YOU KNOW, SUPPLY AND DEMAND, JUST LIKE ANY, ANY ANCILLARY SERVICE, THE ONLY UNIQUE FEATURE OF THIS IS THIS RELEASE FACTOR, WHICH IMPACTS THE TOTAL AMOUNT OF MEGAWATTS THAT CAN BE AWARDED THEORETICALLY BEYOND THE HSL OF A RESOURCE, THE OVERLAPPING.

UM, OKAY.

ONE LAST QUESTION JUST TO HELP ME UNDERSTAND AND I'LL, AND PLEASE BASIC, IT'S, UH, SO IN THE REAL TIME, THE, IN THIS CLEARING, WHAT'S OVERLAP DRS FOR THIS, UH, UH, GENERATION RESOURCE? YEAH, SO IN THIS CASE, UM, THE TOTAL DRS AWARD IS 25.

YOU HAVE A NON OVERLAPPING OF FIVE.

UM, AND THEN THE OVERLAPPING OF 20.

SO, OKAY, SO IT'S, UM, OKAY, SO BASICALLY IT'S JUST RELEASE FACTOR BASED ON, OKAY, SO IT'S 20.

OKAY.

SO THAT'S HOW YOU, SO, UM, UM, I WOULD ALSO SUGGEST IF NEXT TIME IF ARCHIVE CAN PROVIDE A, UM, EXAMPLE, THEN WE'RE NOT GOING SHORT ON AS LIKE HERE, YOU KNOW, JUST GIVE A NORMAL EXAMPLE, SO, SO WE DON'T GET DISTRACTED AND HAVE A BETTER, YOU KNOW, FULL, YOU KNOW, PROPER UNDERSTANDING OF THE RELEASE FACTOR, HOW IT WORKS.

UH, YEAH, NOT, IT WILL WORK ON THAT.

THANK YOU.

OKAY.

THANKS SO MUCH.

THANKS ANDREW.

YEAH, UH, MY COMMENT WASN'T GOING TO BE ABOUT THE RELEASE FACTOR, BUT I AGREE THAT THIS REPRESENTATION OF HOW IT WORKS IS CONFUSING AND SO MAYBE SOME CLARITY WOULD BE HELPFUL ON THAT.

UH, I JUST WANTED TO GIVE A SNEAK PREVIEW.

SO IN RESPONSE TO THE LAST SET OF COMMENTS ABOUT WHEN COMMENTS SHOULD BE FILED AND WHEN THE NEXT WORKSHOP IS GONNA BE IN EVERYTHING, UH, I THINK OUR OFFICE IS GOING TO TRY TO GET OUR COMMENTS OUT THIS MONTH.

UH, YOU CAN EXPECT QUALIFIED SUPPORT FOR 1309 AND MORE OF WHAT YOU'VE HEARD TODAY IN OUR COMMENTS FOR 1310.

SO WE'RE GONNA TRY TO GET THAT OUT THIS MONTH SO THAT, THAT'S ON THE SPLASH PAGE FOR THE MEETING IN FEBRUARY.

I DID GET THAT QUESTION WHETHER WE WANT THEM JUST FILED TO THE NPR OR FILED IN SOME OTHER WAY, WHICH I GUESS WOULD BE TO THE MEETING PAGE, BUT I, I MEAN WE HAVE NPR R SO FILE TO THE NPR.

OKAY.

ANYTHING ELSE? ANYTHING ELSE FROM ERCOT? SO WE WILL, ANN, AND I'LL TAKE A LOOK AT SCHEDULE A MEETING SCHEDULE.

WE'LL AIM FOR ABOUT A MONTH OUT, BUT WE WILL NOT DO IT POST W-M-F-W-M-S IF POSSIBLE.

UM, 'CAUSE THOSE ARE LONG DAYS.

OKAY.

REAL QUICK, THERE'S NOTHING SCHEDULED I'M SEEING ON THE 3RD OF FEBRUARY.

OKAY.

PC OR ACCOUNT RELATED, WHICH IS THE DAY BEFORE WMS, SO THAT MIGHT BE AN OPTION.

YEP.

WE'LL, WE'LL TAKE A LOOK.

UM, AND SO WE'LL WILL FOLLOW UP WITH THE TIMELINE THAT KIND OF HELPS US UNDERSTAND HOW THINGS GET DEPLOYED.

UM, AND THEN I THINK THE BIG TOPIC OF DISCUSSION IS THE,

[02:25:01]

UM, DEMAND CURVES.

AND SO WE'LL HEAR FROM STAKEHOLDERS AND ON THAT.

OKAY.

OH, WE HAVE TAC IN TWO WEEKS.

UM, IT'S GONNA BE THEMED.

IT IS.

I DECIDED WITH STAKEHOLDER SERVICES HELP, IT'S THE 30TH ANNIVERSARY OF TECH AND WE THINK IT'S 1996, WE'RE DECLARING IT.

UM, SO WE'RE GONNA HAVE, YOU KNOW, MAYBE DECORATIONS IF ERCOT WILL LET ME PUT BANNERS UP, UM, AND AND SOME SWEET TREATS.

AND THEN COREY AND ANN ALSO PUT TOGETHER, UM, A NICE LITTLE LIST.

SO WE'LL DO SOME SHOUT OUTS FOR, FOR PEOPLE WHO HAVE 5, 10, 15, 20 YEARS OF, OF TECH TENURE, INCLUDING PAST MEMBERS.

UM, AND SO IF YOU CAN DIAL IN OR IF YOU'RE LOCAL AND YOU WANNA BE HERE, COME HANG OUT WITH US AND NED'S GONNA HAVE A THEME.

HAPPY HOUR.

I'LL LET NED GO.

SHOULD, SHOULD WE COME DRESSED AS WE USED TO DRESS IN 1996 FOR THAT? THAT'S FINE WITH ME.

.

THAT'D BE FUN.

SAD PART IS, I REMEMBER THAT CRAP.

.

ALRIGHT.

YEAH, WE, THAT HAPPY HOUR WE'RE GONNA, THE PRE TACK MEETING THAT I USUALLY GET OUT TO AND NED'S, WE'RE GONNA COMBINE THOSE AND MM-HMM .

HAVE A THEMED CHEERS TO 30 YEARS.

30 YEARS FOR THAT.

SO LEMME JUST SHOW UP AT A BAR WITH GLITTER CONFETTI .

OKAY.

ALRIGHT.

UM, SHAMS, DID YOU HAVE A REAL QUESTION IN THE MIDDLE OF ALL THAT , SORRY, IT TOOK ME A WHILE TO THINK ABOUT THIS.

UH, BUT YOU KNOW, WHEN YOU'RE DOING THAT SHORT, IN THAT EXAMPLE, WHAT DEMAND CURVE, IS IT A BLENDED DEMAND CURVE OF THE AS PORTION AND THE RESOURCE ADEQUACY PORTION THAT YOU'RE, 'CAUSE IT SEEMS LIKE IT'S .

YEAH.

SHA IT'S ALL ONE DEMAND CURVE.

IT'S ALL ONE PRODUCT.

SO YOU'RE JUST GOING UP THE, YOU'RE JUST GOING UP.

YEP.

THAT MIGHT BE, UH, YEAH, I HAVE TO THINK WHAT, WHETHER THAT WORKS OR NOT.

OKAY.

THANKS.

OKAY.

ANY OTHER QUESTIONS? ALL RIGHT.

WE WILL SEE YOU ON JANUARY 21ST FOR TIER TO 30 YEARS.

AND WE, YOU'LL HEAR FROM US BEFORE THAT ON THE TIMING OF THIS NEXT WORKSHOP SOMEWHERE ABOUT A MONTH FROM NOW.

OKAY.

WE CAN ADJOURN.

THANKS EVERYONE.