* This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting. THANK YOU FOR COMMENTS AND [00:00:01] DISCUSSIONS. ALL RIGHT. ALL RIGHT, WELL, GOOD MORNING. THIS IS MATT MAR ERCOT. WELCOME TO WORKSHOP NUMBER FIVE. YES, NUMBER FIVE IS ALREADY HERE. AND WE SEE THE WEAKLINGS HAVE FALLEN OUTTA THE CROWD, THAT IT'S THE DEDICATED THAT ARE HERE IN PERSON, SO THEREFORE THE BE, NO, I WON'T EVEN CONNECT THE DOTS ON THAT ONE. UH, THANK YOU FOR YOUR CONTINUED SUPPORT AND INTEREST IN THIS IMPORTANT TOPIC, ERCOT. IT IS A STRATEGIC AND RELIABILITY, UH, KEY FOR US RIGHT NOW. SO, UH, LEMME GO AHEAD [1. Antitrust Admonition] AND START US WITH THE ANTITRUST ADMONITION. UH, JUST A REMINDER TO AVOID RAISING CONCERNS ABOUT ANTITRUST LIABILITY, THERE IS THE REST OF THE VERBIAGE ON THE SCREEN, AND SO BE ADVISED. ALL RIGHT. AND THEN TODAY, THE WAY, JUST A REMINDER, SO IF YOU HAVE COMMENTS AND QUESTIONS, WE'LL BE RUNNING THE QUEUE IN THE SAME WAY, WHICH IS, YOU CAN TYPE YOUR QUESTION OR SAY YOU HAVE A QUESTION IN THE WEBEX, UM, CHAT. AND THAT'LL BE HOW WE RUN THROUGH, UH, THE QUEUE. THERE WILL BE TIMES TODAY, AS I'VE USED IN THE PAST WHEN WE HAVE, UM, YOU KNOW, HUNDREDS OF PEOPLE IN THIS FORM. AT SOME POINTS, UH, THERE WILL BE TIMES THAT WE SAY THERE ARE NO QUESTIONS BEING ACCEPTED RIGHT NOW. SO ESSENTIALLY THERE WILL BE NO QUEUE, AND THEN WE WILL OPEN THE QUEUE FOR CERTAIN TIMES. UH, WHAT I SEE TODAY LOOKING LIKE IS JUST A FIVE MINUTE RECAP OF WHAT WE'RE DOING. JUST IF THIS IS YOUR FIRST MEETING, YOU'LL KNOW THE WHAT'S AND THE WHYS. UH, THEN WE'LL GO INTO THE BATCH ZERO PIGGER WALKTHROUGH. SO, ERCOT FILED COMMENTS, LAST ERCOT FILED COMMENTS LAST WEEK. OKAY. UH, AND THIS WILL BE A CHANCE FOR ERCOT TO EXPLAIN THE THOUGHTS BEHIND IT. A LOT OF THAT WAS CONNECTED TO CONCEPTS THAT WERE SHARED AT THE PREVIOUS WORKSHOP. SO THE RED LINES AND COMMENT FORM WILL BE WHAT'S WALKED DOWN. I PREDICT THAT THAT WILL BE DONE BY 11 O'CLOCK, IS MY HOPE. SO WE'LL ALSO TAKE QUESTIONS ALONG THE WAY. AND THEN WHEN IT COMES TO THE, UH, MARKET PARTICIPANTS, I JUST POSTED A NEW FILE. UH, IT IS A WORKSHOP, SPEAKER'S POWERPOINT. WE HAVE 21 SPEAKERS. I ASK THEM IN AN INDIVIDUAL E OH, SORRY, EMAILS TO THEM TO LIMIT IT TO FIVE TO SEVEN MINUTES EACH. YOU DO THE MATH IF IT'S 20 COMMENTS TIMES 10 MINUTES EACH. WE'RE GONNA BE HERE A VERY LONG TIME. SO BRIEF AND AMAZING IS WHAT WE WANT. UH, BUT YOU'LL HAVE THE STAGE FOR AT LEAST FIVE TO SEVEN MINUTES. UH, AND AT SEVEN MINUTES, WE WILL PRETTY MUCH UNPLUG THE MICROPHONE. WE'LL NEED TO MOVE ON, UH, AND GO ALONG. UH, AND THEN AT THAT POINT, I THINK THAT'LL TAKE US THE FIRST HALF OF THE COMMENTERS TO LUNCH, AND THEN THE SECOND HALF OF THE COMMENTERS AFTER LUNCH. AND THEN I'M HOPING WE HAVE AN HOUR AND A HALF TO TALK ABOUT BYOG. UH, ERCOT BELIEVES IT HAS A LINE OF SIGHT TO THE CONTROLLABLE LOAD RESOURCE AND THE TYPE OF LANGUAGE WE NEED. THE BYOG IS WHAT WE WANNA DIVE INTO TODAY AND, UH, ROLL UP OUR SLEEVES AND GET IN. SO, UH, THERE'S A NEW SLIDE THAT WAS POSTED. A LOT OF IT'S RECYCLED, BUT THE LAST SLIDE HAS THREE THINGS THAT WE'RE CONSIDERING, UH, AND JEFF WILL DO A DEEP DIVE ON THAT LATER. SO, WITHOUT FURTHER ADO, LEMME GO AHEAD AHEAD AND GET US ROLLING INTO OUR SLIDES HERE. UH, WE DID POST A FRIDAY VERSION, WHICH IS, UM, WAS UPDATED ONCE YESTERDAY EVENING AT FIVE O'CLOCK. AND THESE ARE THE THINGS THAT CHANGE. AND THEN AGAIN, UM, THIS MORNING AT PROBABLY 20 MINUTES AGO. SO IF YOU WANNA REFRESH YOUR BROWSER AND DOWNLOAD, THAT IS THE CURRENT SLIDES WE'LL BE WORKING FROM TODAY. HOPEFULLY THAT'S THE RIGHT BALANCE OF GIVING YOU SOMETHING EARLY ON. AND THEN JUST SOME LIGHT, UH, REFINING AS WE GET CLOSER. UH, [2. Timeline and governance recap (10 mins)] SO TIMELINE AND GOVERNMENTS RECAP. SO IF YOU'RE LOOKING AT YOUR CALENDAR EVERY WEEK IN APRIL, WE'LL BE MEETING TOGETHER. UH, IT WILL HAPPEN IN DIFFERENT WAYS. SO WE'RE AT WORKSHOP NUMBER FIVE AT THE END OF MARCH HERE, SORRY, IT'S NOT EVEN THE END OF MARCH. WE HAVE ANOTHER MARCH NEXT MONDAY, SIX DAYS AWAY, WE WILL BE HERE AGAIN ON WORKSHOP NUMBER SIX. AND THEN WE HIT WORKSHOP NUMBER SEVEN IS THE FOLLOWING WEEK ON APRIL 9TH. AND THEN AFTER APRIL 9TH IS, WE'RE GONNA JUMP DOWN AND TRANSITION, WE BELIEVE TO ROS. SO APRIL 14TH WILL BE THAT SPECIAL ROS MEETING, FOLLOWED BY ANOTHER ROS MEETING ON THE 14TH. AND AT THAT POINT, WE'RE HOPING THAT WHETHER WE'RE GETTING A VOTE AT THE 14TH OR THE 4 23, I'M SORRY, HOLD ON. APRIL 9TH, WORKSHOP SEVEN, APRIL 14TH, ROS, APRIL 23RD, ROS. THOSE ARE BOTH SPECIAL MEETINGS FOR US. AND THEN THE ULTIMATE VOTE WOULD BE ON MAY 7TH. AND SO IF YOU'RE LOOKING AT YOUR CALENDAR, WE'RE ON A TIGHT, TIGHT WHIP, AND ALL THIS IS LEADING UP TO THE BOARD VOTE ON JUNE 1ST. SO YOU'RE ALSO GONNA HEAR SOME, UM, YOU MAY START TO HEAR MY TENSION AS WE START TO WANDER OFF. AND, GEE, WOULDN'T THIS BE NICE? THOSE DAYS ARE OVER. WE ARE HONING IN ON THE FINAL RUN OF WHAT GOES TO THE BOARD IN DAYS, NOT MONTHS. AND SO WE REALLY HAVE TO GET THE LIST SHORTENED. UH, WE'RE GONNA BE CHALLENGING, UH, COMMENTS. WE'RE GONNA BE ASKING FOR OTHER [00:05:01] PEOPLE IN THE ROOM TO CHALLENGE COMMENTS OR MAYBE TAKE A STRAW POLL AROUND THE, ALONG THE WAY, WE CAN'T KEEP OPENING DOORS. WE NEED TO START CLOSING DOORS ON THE ISSUES TO GET TO THE END RUN. SO, UM, WE'LL SEE HOW TODAY GOES. AGAIN, WE DO HAVE THIS GOAL OF APRIL 8TH OF FILING, WHETHER IT'S COMMENTS OR A SEPARATE NPR AND PICKER ON THE CLR. WE'RE WELL ON OUR WAY FOR THAT ONE. THE BYOG IS THE HARDER ONE TO TACKLE, BUT WE'RE STILL WORKING TOWARDS THAT, UH, GOAL. UH, IF YOU WANT TO PROVIDE COMMENTS, THIS IS JUST A REMINDER OF HOW THOSE COMMENTS ARE FORMALLY FILED WITH ERCOT, UH, WHICH BODIES APPROVE THESE. ROS IS THE APPROVAL, UH, CHANNEL TO THE BIGGER TO GET TO THE PLANNING GUIDE REVISIONS. THAT IS TO GET TO TACK ON THE BOARD. AND PRS WILL HAVE THE NPR. THE NPR IS LIGHT RIGHT NOW. AS WE ADD IN CLRS AND BRING YOUR OWN GEN, THAT WILL BECOME A LARGER NPRR. SO JUST KEEP THAT IN MIND THAT PRS IS NOT ON THE EASY STREET FOREVER NECESSARILY. OKAY. AND SO THEN WHILE WE'VE BEEN GONE, THE COMMISSION WEIGHED IN ON THE 5 8, 4 8 1 OF WHAT WAS FILED ON MARCH 12TH. YOU'LL SEE SOME UPDATED RED LINES OF THINGS THAT CHANGED THE A HUNDRED THOUSAND PER MEGAWATT CHANGE TO 50,000. UM, AND I'LL JUST PUT THIS ON THE SCREEN FOR A MINUTE. I DON'T PLAN TO WALK DOWN THIS. HOPEFULLY THIS IS, UM, PEOPLE HAVE STAYED TUNED WITH THIS, BUT THESE TYPES OF CRITERIA HAVE BEEN MODIFIED. AND AS SUCH, WE'VE MODIFIED OUR LANGUAGE TO MATCH THOSE. SO THIS IS THE IDEA AS ERCOT IS RUNNING IN PARALLEL ON THESE CRITERIA INTO OUR, UH, PLANNING GUIDE REVISIONS. UH, AND THEN JUST THE LAST THING AS A REMINDER. SO WE FILED OUR COMMENTS. UH, WE ARE HERE TODAY TO TALK ABOUT YOUR COMMENTS TO OUR COMMENTS AND SEE WHERE WE ARE. AND THEN, UM, WE'RE ON TARGET WITH CLR AND BYOG TO BE IN SCOPE. YOU KNOW, THAT'S WHAT THE COMMISSION WANTED. THAT'S WHAT WE WANT. ERCOT LIKES MORE ENERGY ON THE SYSTEM. SO WE'RE ALL ABOUT GETTING GENERATION IN. UH, AND THEN THE LONG TERM BATCH PROCESS REVISIONS A REMINDER, THIS IS A BATCH ZERO FOCUS RIGHT NOW, NOT THE LONGER TERM. HOW DOES THIS ALL WORK FOREVER? AND SO WE, WE DID FIND OUT IN OUR RUSH TO GET THINGS OUT AS QUICKLY AS WE COULD. WE STILL HAD SOME OOPSES ALONG THE WAY. THESE ARE THE TYPOS THAT YOU MAY HAVE FOUND, AND WE'RE NOT GONNA TRY TO FIX THEM TODAY. WE DIDN'T WANT TO THROW YET ANOTHER SET OF COMMENTS IN THE STACK FOR YOU GUYS. SO WE WILL BE, AND WE MAY POINT BACK TO THIS SLIDE IF THERE'S CONFUSION. THESE ARE THINGS THAT WE ALREADY SEE NEED TO BE CORRECTED. MOST OF ARE TYPOGRAPHICAL IN NATURE. THEY'RE NOT NEW CONCEPTS. THEY'RE TYING, TICKING, AND TYING THINGS MORE ACCURATELY. OKAY? SO IF YOU WANNA PUT THAT IN YOUR MIND, SLIDE EIGHT, HAVE THOSE CORRECTIONS. THAT WAY IS WHAT YOU CAN FLIP BACK TO. AND AT THIS POINT, AGAIN, WHAT WE'RE GONNA DO IS SPEND THE NEXT HOUR AND 15 MINUTES IS ERCOT IS GONNA RUN THROUGH, UM, THE CHANGES. UH, WE CAN START TO BUILD A QUEUE AS WE WANT. I REALLY ENCOURAGE YOU TO LET AG AND JEFF GET THROUGH THEIR PIECE. UH, BUT THEN WE'LL START TO TAKE ANY CLARIFYING QUESTIONS ALONG THE WAY. AND THEN AGAIN, KIND OF A HARD STOP AT 11 IS TO TRANSITION TO THE MARKET STAKEHOLDER FEEDBACK. SO [3. Batch Zero PGRR walk-through of ERCOT comments and concepts] WITH THAT, I WILL TURN IT OVER TO AG. THANK YOU. ALRIGHT, GOOD MORNING. UH, AG SPRINGER ERCOT. UM, SO I'M ACTUALLY GOING TO PROBABLY NOT USE THESE SLIDES TOO EXTENSIVELY. UM, RATHER, UH, I'M GONNA PULL UP OUR, IT'S IN THE BACKGROUND. IT'S IN THE BACKGROUND. NO, THAT'S FINE. UM, SO I'M GONNA PULL UP OUR, OUR COMMENTS. UM, JUST TALK THROUGH THE HIGH LEVEL, UH, THE PREAMBLE AND THEN LOOK AT SOME LANGUAGE, UM, YEAH, YEAH. UM, AND THEN, THEN WE WILL REFER, I WILL REFER BACK TO THE SLIDES AT A COUPLE POINTS. UM, BUT THE SLIDES ARE THERE FOR, FOR EVERYONE'S REFERENCE AS, YOU KNOW, JUST AN OVERVIEW OF WHAT WAS CHANGED. BUT NOW THAT WE HAVE LANGUAGE, UM, POSTED IT, IT SEEMS TO MAKE MORE SENSE THAT WE CAN, UH, KIND OF FOCUS IN ON WHAT THE WORDS IN THE PLANNING GUIDE ACTUALLY SAY. UM, SO AT A VERY HIGH LEVEL, UM, I THINK THAT THE BIGGEST SUBSTANTIVE CHANGE THAT WE ADDRESS THROUGH THESE COMMENTS IS THE ENTRANCE INTO BATCH ZERO AND THE PATH TO BEING, UM, UH, BASE LOAD IN BATCH ZERO. I THINK, YOU KNOW, THE, THE COMMENTS THAT WERE RECEIVED, UH, BEFORE MARCH, THE MARCH 10TH WORKSHOP, REALLY FOCUSED IN ON THE ORIGINAL STRUCTURE OF EVALUATING THE VALIDITY OF PREVIOUS INTERCONNECTION STUDIES THAT WAS DESCRIBED IN THE ORIGINAL NINE POINT. UM, CREATED RISK FOR DEVELOPERS OF COMPLETED STUDIES AND POTENTIALLY PROJECTS THAT HAVE ALREADY MADE INVESTMENT DECISIONS, [00:10:01] UM, YOU KNOW, REALLY SUDDENLY FINDING THEMSELVES UNDER UD AGAIN. AND, UM, YOU KNOW, THE, THE PREVIOUS LANGUAGE HAD A FORWARD LOOKING CUTOFF DATE FOR, UM, ENTRANCE INTO THE BATCH. AND SO THAT, THAT WAS THE REASON THAT WE HAD, WE WANTED THIS. UM, WE FELT WE NEEDED THIS ASSESSMENT PROCESS, UM, ESPECIALLY EXPECTING THAT THERE WILL BE A PRETTY STRONG PUSH TO MEET THESE REQUIREMENTS PRIOR TO JULY OF THIS YEAR. UM, SO, UH, WE DID PROPOSE SOME RED LINES. I'M GONNA GO THROUGH THOSE, UH, HERE IN A MOMENT. UM, TO TRY AND BALANCE THE NEED FOR, UM, YOU KNOW, THE PROJECTS THAT HAVE ALREADY MADE INVESTMENT DECISIONS TO HAVE THAT CLEAR PATH FORWARD WITH THE FACT THAT, YOU KNOW, WE, WE DO EXPECT TO RECEIVE A LOT OF STUDIES COMING IN VERY QUICKLY TOWARD THE END OF THIS, UH, THE END OF THE FIRST HALF OF THIS YEAR. UM, SO WHAT I'M GONNA DO IS I'M GONNA GO DOWN TO THE RED LINES, UH, AND THEN WE'LL COME BACK TO THE PREAMBLE AND TALK THROUGH THE OTHER CHANGES IN THE DOCUMENT. THIS IS KIND OF THE ONLY PLACE THAT I'M GONNA GO THROUGH THE RED LINES UPFRONT, BUT I'M HAPPY TO, YOU KNOW, AS WE TAKE QUESTIONS, HAPPY TO LOOK AT ANY OF THE OTHER ONES. UM, SO CONCEPTUALLY, WHAT, WHAT WE CHANGED IS THAT PROJECTS THAT HAVE MET THE, UH, THE CRITERIA TO HAVE BE CONSIDERED FOR VALID STUDIES PRIOR TO MARCH 4TH. SO THAT'S EITHER A PROJECT THAT WAS SUBMITTED AS PART OF AN RPG THAT'S, UH, WAS SUBMITTED ON OR BEFORE DECEMBER 15TH, AND IS APPROVED BY MARCH 4TH, OR PROJECTS THAT HAVE LILI STUDIES THAT WERE APPROVED AND MET 9.5 AS WELL. UH, PRIOR TO MARCH 4TH, THERE'S GONNA GONNA BE THAT MARCH 4TH CUTOFF DATE, WHICH WAS THE DATE THE PIGGER WAS SUBMITTED. THOSE PROJECTS WILL, UH, BE CONSIDERED TO HAVE VALID INTERCONNECTION STUDIES WITHOUT FURTHER EVALUATION. AND THEN THE LATTER WILL BE USED FOR, UM, SORRY, I SHOULD PROBABLY JUST SHOULD HAVE GONE DOWN HERE, UH, TOO FAR. OKAY. UM, THEN FOR PROJECTS THAT MEET THOSE ELIGIBILITY CRITERIA, UH, AFTER MARCH 4TH, THOSE PROJECTS WILL STILL BE EVALUATED PRIOR TO THE START OF BATCH ZERO. AND THAT, AGAIN, IS TO, UH, CORRECT FOR THE, THE CONCERN THAT, YOU KNOW, WE EXPECT THAT THERE MAY BE MULTIPLE PROJECTS MEETING THESE, UH, MILESTONES VERY IN VARIOUS QUICK SUCCESSION HERE IN THE NEXT MONTH OR TWO. UM, SO THERE'S A NEW PARAGRAPH THREE IN SECTION. WE'RE IN SECTION, UH, 9 2 1 4. AS A REMINDER, THIS SECTION ONLY DESCRIBES HOW STUDIES ARE DETERMINED TO BE COMPLETE AND VALID. IT DOESN'T SAY AUTOMATICALLY YOU GET INTO BATCH ZERO AS BASE LOAD, YOU STILL NEED TO MEET THE FULL INTERCONNECTION AGREEMENT REQUIREMENTS. AND IF YOU'RE, UH, CONNECTING WITHIN BY THE END OF 27, YOU ALSO NEED TO DEMONSTRATE THE DEVELOPMENT ACTIVITY. AND THAT'S ALL COVERED, UH, ABOVE IN 9 2 1 1. SO THIS ONLY DESCRIBES HOW WE DETERMINE IF STUDIES ARE VALID. UM, SO NEW PARAGRAPH THREE THAT DESCRIBES, UH, IF YOU KNOW THOSE TWO MILESTONES, I MET EITHER RPG ENDORSEMENT, UH, ACCEPTANCE AND ERCOT ENDORSEMENT, UM, ON OR BEFORE MARCH 4TH, UH, OR MEETING, UH, WHAT IS LEGACY NINE NINE AND LEGACY, UH, OR NINE NINE AND NINE 10, WHICH ARE THE LEGACY, UH, CURRENT NINE FOUR AND NINE FIVE, UH, ON OR BEFORE MARCH 4TH. UH, YOUR STUDIES ARE CONSIDERED TO BE VALID. AND THEN, UH, FROM THERE WE MODIFIED WHAT IS NOW PARAGRAPH FOUR, UM, TO DESCRIBE WHAT HAPPENS FOR PROJECTS THAT MEET THOSE MILESTONES, UH, BETWEEN, UM, UH, MARCH 4TH AND JULY 10TH, WHICH IS THE NEW CUTOFF DATE. UM, AND I'LL TALK MORE ABOUT CUTOFF DATES IN A MOMENT. UM, AND SO EFFECTIVELY IT JUST MODIFIES TO SAY, OKAY, THE LATTER CONCEPT, UM, ONLY APPLIES TO THESE PROJECTS NOW. ALL RIGHT, THIS IS GONNA BE ONE OF THE POINTS WHERE I JUMP BACK TO THE POWERPOINT HERE FOR A MOMENT. UM, THIS IS THE GRAPHIC THAT WE PROBABLY SHOULD HAVE HAD FOR THE LAST WORKSHOP, BUT, UM, THIS KIND OF ILLUSTRATES HOW THAT LADDER CONCEPT WORKS. UM, SO WE'RE GOING TO LOOK AT THOSE PROJECTS THAT MEET, UH, THAT QUALIFY AFTER MARCH 4TH. WE'RE GOING TO ORDER THEM IN ORDER OF THE DATE THAT THEY MET THOSE MILESTONES. AND YOU CAN SEE HERE ON THE LEFT COLUMN, UM, IF TWO PROJECTS MEET ON THE SAME DAY, WE HAVE A NUMBER OF TIEBREAKER RULES FOR THE [00:15:01] PURPOSES OF THE SLIDE, WE JUST USED ONE THAT WAS IN AN RPG AND ONE THAT MET THE LOWEST REQUIREMENTS ON THE SAME DATE. UM, FOR THAT PARTICULAR SCENARIO, THE, THE, THE TIEBREAKER WOULD GO TO THE RPG PROJECT. HOWEVER, THERE, THERE ARE A NUMBER OF OTHER SCENARIOS THAT ARE CONTEMPLATED IN THE PIGGER THAT, THAT DIDN'T MAKE IT ONTO THIS SLIDE. AND THEN ONCE WE HAVE THAT LIST, WE'RE GONNA START FROM THE TOP. SO THE FIRST ONE WILL BE CONSIDERED TO BE VALID RIGHT OFF THE BAT, AND THEN WE'LL GO DOWN FOR EACH OF THEM AND LOOK AT, UH, WHETHER OR NOT THE PREVIOUSLY VALIDATED LOADS ON THE LIST WERE EITHER NOT IN THE STUDY AREA OR WERE INCLUDED IN THE, THE LOAD UNDER EVALUATION STUDY. AND SO THERE MAY BE SOME THAT CAME IN LATE THAT MAY NOT HAVE VALID STUDIES BECAUSE THEY DIDN'T INCLUDE OTHERS THAT CAME IN, YOU KNOW, WITHIN THAT SAME TIME PERIOD. BUT I DO WANT TO EMPHASIZE THAT JUST BECAUSE THE LOAD ABOVE ONE, ONE LOAD ABOVE ON THE LIST WAS DETERMINED TO NOT HAVE VALID INTERCONNECTION STUDIES, THAT DOESN'T INVALIDATE EVERYTHING BELOW. IT DEPENDS ON WHERE THESE LOADS ARE LOCATED. UM, THERE MAY BE SOME IN OTHER AREAS OF THE SYSTEM THAT ARE FUR FURTHER DOWN THE LIST WHERE, UM, THE STUDIES ARE STILL VALID. UM, THE LAST THING I'LL JUST SAY VERBALLY, THIS ISN'T IN THE SLIDES OR UM, UH, IN THE, THE COMMENTS THEMSELVES IS WE ARE LOOKING AT SOME OPTIONS FOR, UM, DOING THIS EVALUATION ON A ROLLING BASIS OVER THE NEXT COUPLE MONTHS. I DON'T REALLY HAVE ANYTHING MORE DEFINITIVE TO SAY ON THAT, BUT, UM, WE ARE LOOKING AT HOW WE CAN PROVIDE THE TSPS THE VISIBILITY ON THIS, UH, SO THAT IT'S NOT A SURPRISE WHEN WE GET TO JULY 10TH. UM, THAT'S, UH, UH, WE'RE, WE'RE HOPING TO GIVE THAT VISIBILITY AS WELL A CAN I JUST, SINCE IT'S THE FIRST TIME YOU'VE SHOWN THE SLIDE AND I THINK IT'S A CRITICAL SLIDE, DOES ANYONE HAVE CLARIFYING QUESTIONS IN THE ROOM AS TO MECHANICALLY WHAT'S GOING ON? YEAH, GO AHEAD, BROTH. SORRY, I KNOW I'M SKIPPING THE QUEUE, BUT I JUST WANT TO HIT THE PEOPLE IN THE ROOM FOR IF THIS IS THE FIRST TIME TO LAY EYES ON IT, YOU'RE TRYING TO UH, SAY ORIENT YOURSELF TO IT. THESE ARE ORIENTATION TYPE QUESTIONS. GO AHEAD. HEY AG, UH, CAN WE DO THIS NOW? RIGHT? YOU HAVE AN LLI THAT MEETS 9.4 9.5 TODAY, RIGHT? YOU CAN CHECK THE RPG IN THAT AREA AND PROVIDE CONFIRMATION TO THAT LLI THAT IT'S GOOD IF IT IS. AND THAT WAY THAT LLI DOESN'T NEED TO WAIT TILL JULY 10TH. RIGHT. AND YOU'RE ALREADY GIVING IT CERTAINTY, WHICH IS EXACTLY WHAT THE LOADS NEED. SO, YEAH. YEAH. SO YEAH, AS I WAS SAYING A MOMENT AGO, WE ARE LOOKING AT, UM, A COUPLE POSSIBLE WAYS THAT WE CAN PROVIDE THIS VISIBILITY ON AN ONGOING BASIS. I DON'T HAVE ANYTHING TO, TO SHARE ON THAT TODAY, BUT, UH, WE RECOGNIZE THAT THAT WOULD BE HELPFUL. ONE, ONE OTHER FOLLOW UP. SO WHEN YOU SAY AREA, ARE YOU LOOK LOOKING AT LIKE CERTAIN ELECTRICAL BUSES IN THAT AREA? HOW ARE YOU LOOKING AT? DEPENDS ON THE PROJECT. UH, EACH OF THESE INTERCONNECTION STUDIES SHOULD HAVE A DEFINED STUDY AREA THAT'S IN SCOPE OF THE STUDY. AND SO THAT'S WHAT WE BE LOOKING AT. BUT IT DEPENDS ON WHERE IN THE SYSTEM AS TO HOW LARGE THAT AREA IS. OKAY. ALRIGHT. THEN YOU HAD YOUR HAND UP, SIR. GO AHEAD. YEP. ENCORE, UM, AG DO YOU HAVE TO MEET NINE FOUR AND NINE FIVE TO UH, EVALUATE THESE LOADS? WHAT IF A LOAD HAS A NINE FOUR MAT, MEANING THEY HAVE, THEY HAVE SUBMITTED ALL STUDIES AND EVEN GOT AN APPROVAL, BUT THEY DON'T HAVE THE CONTRACT. WHAT HAPPENS TO THOSE LOADS? HOW DO YOU EVALUATE THEIR VALIDITY? THE THEY UNDER THE CURRENT PROCESS, THOSE LOADS ARE STILL AT RISK OF TUDY. IF THERE'S A, A CHANGE TO STUDY ASSUMPTIONS, THAT'S, UH, THE CURRENT PLANNING GUIDE 9.4, I THINK IT'S PARAGRAPH EIGHT. UM, SO I MEAN THAT, THAT'S ONE OF THE DRIVERS OF THE UD LOOPS IN THE CURRENT PROCESS IS IF ANOTHER LOAD MEETS NINE FOUR AND NINE FIVE BEFORE A LOAD THAT'S COMPLETED, NINE FOUR SIGNS THEIR AGREEMENTS, THEY POTENTIALLY MAY NEED TO BE RESTUDIED. AND SO THAT'S ALSO WHY WE CAN'T GIVE THEM A FIRM PLACEMENT ON THE LIST. THEY NEED TO MEET NINE FOUR AND NINE FIVE, UH, TO, TO GET ON HERE. 'CAUSE THAT'S EFFECTIVELY WHAT LOCKS THE STUDIES. SO I AGREE WITH THAT, THAT THERE IS A RISK, BUT COULDN'T YOU JUST PUT 'EM AT THE BOTTOM IN TERMS OF HER PRIORITY AND SEE IF THERE'S A WAY YOU CAN, BECAUSE THERE, THERE IT MAY BE THAT THERE ARE NO OTHER LOADS IN THAT REGION AND YOU MAY BE ABLE TO CALL THAT STUDY A VALID STUDY. I I THINK WE'D HAVE TO DISCUSS IT. I, I DON'T HAVE AN ANSWER TODAY, BUT YOU KNOW, IN GENERAL, UM, I, I THINK WE ARE LOOKING AT, FOR INCLUSION AS BASE LOAD IN BATCH ZERO. SO A LOAD WITH 9 4 9, UH, COMPLETE, BUT NO AGREEMENT SIGNED, THAT'S ALREADY ELIGIBLE TO BE REASSESSED IN THE BATCH. UM, PROVIDED THEY MEET THE INTERMEDIATE AGREEMENT CRITERIA. UM, I, AND I THINK, YOU KNOW, ONE OF THE SORT OF [00:20:01] FUNDAMENTAL UNDERPINNINGS OF THIS, UH, WHOLE STRUCTURE IN WHO GETS IN AS BASE LOAD IN BATCH ZERO IS LOOKING AT WHETHER OR NOT THEY HAVE COMPLETED AGREEMENTS. AND SO, UM, I I DON'T, WE, WE CAN DISCUSS IT INTERNALLY, BUT I I DON'T HAVE, UH, UH, MORE OF AN ANSWER THERE. THANK YOU. MM-HMM . OKAY, HAYNES, GO AHEAD. THANK YOU. UH, QUICK QUESTION. HAYNES STRADER WITH SKYBOX. SO CAN YOU, AND SORRY IF THIS IS REDUNDANT, BUT IF YOU'VE GOT A SIGNED VALID STUDY, YOU'VE GOT YOUR FINANCIAL SECURITY POSTED, YOUR KAYAK POSTED, AND THAT WAS DONE ON, OR THAT WAS DONE ON OR BEFORE, UH, DECEMBER 15TH OF 25. BUT YOU'VE BEEN IN A RE-STUDY LOOP WITH ERCOT, PARTICULARLY ON THE STEADY STATE FOR SEVERAL CYCLES. UH, I'M UNDERSTANDING THAT THAT WON'T QUALIFY UNDER THE MARCH 4TH, CORRECT? IS THAT, THAT'S CORRECT. AND SO WHERE DOES THAT FALL HERE AND WHAT DO THE XS MEAN NEXT TO THE LLIS LOADS IF IT'S NOT ON AN RPG? YEAH, SO, UM, I SHOULD HAVE PROBABLY CLARIFIED. SO THE ID, THE, THE, THE SECOND COLUMN WAS TRYING TO ILLUSTRATE HOW WE'RE GOING DOWN THE LIST. THESE ARE COMPLETELY FICTIONAL MADE UP EXAMPLE LOADS OF HOW WE WOULD EVALUATE. WE START FROM THE TOP, WE GO TO THE NEXT ONE, GO TO THE NEXT ONE, AND WE KEEP GOING AND, AND EVALUATE EACH LOAD DOWN THE LIST IN CONTEXT OF THE ONE ABOVE, OF THE ONES ABOVE. UM, AND SO, UH, THE X'S ARE JUST EXAMPLES WHERE WE MIGHT HAVE FOUND THAT THE PROJECT, UM, GOT IT. IT IS JUST ILLUSTRATIVE. YES. OKAY. UM, AND SORRY, JUST TO, SO THE, THE THI CAN, CAN, CAN YOU EX UH, WHY WAS THE MARCH 4TH DATE SELECTED? THAT JUST MAY HELP. THAT WAS THE DATE THAT PGA 1 45 WAS FILED. GOT IT. ALL RIGHT. AGAIN, JUST KIND OF LIMITING TO THE SLIDE HERE. UM, DURGA, WAS THIS TO THE SLIDE ON THE SCREEN? THEN WE'LL DO EVAN AND CHRIS AND THEN TRY TO WRAP THIS PIECE UP. NO, IT'S, IT'S, UM, SO I TOOK TWO QUESTIONS HERE. AG. OKAY. IS IT ABOUT CLARIFYING THE MECHANICS OF THE SLIDE? 'CAUSE WE'RE KEEPING EVERYONE IN THE BOX RIGHT NOW ON YEAH, IT'S, IT'S, IT'S RELATED TO THIS, THIS SLIDE. GO FOR IT. SO, UM, SO, SO ONE FUNDAMENTAL QUESTION IS, SO, SO 9.5, DOES IT MEAN THAT THE AGREEMENT HAS BEEN SIGNED OR A COURT HAS CONFIRMED THAT YOU HAVE MADE 9.5? SOMETIMES IT GETS STUCK IN THE LOOP, BUT THE TSP SENT IT TO A COURT AND OUR COURT HAS NOT CONFIRMED. MAYBE THEY'RE LOOKING AT STUFF. SO WHAT'S THE DEFINITION OF 9.5? MEETING THE EXISTING SECTION 9.5 REQUIRES THE TSP TO NOTIFY ERCOT WHEN THE CUSTOMER HAS, UH, SIGNED ALL REQUIRED AGREEMENTS, POSTED FINANCIAL SECURITY GIVEN NOTICE TO PROCEED WITH CONSTRUCTION AND WHAT, UM, AND SO IT WOULD BE THE DATE THAT, THAT WE RECEIVED THAT CONFIRMATION. SO IT'S THE TSP, JUST CONFIRMING THAT'S THE DEFINITION OF MEETING 9.5 UNDER THE CURRENT PLANNING GUIDE? YES. OKAY. AND THE SECOND QUESTION IS, SOME PROJECTS, LET'S SAY IT'S A BEHIND THE METER PROJECT, UH, WHERE ALL THE REQUIREMENTS ON KAYAK AND ALL THAT STUFF IS MET, BUT IT'S STUCK IN THE, IN THE, IN THE, IN THE, IN THE PROCESS FOR A WHILE AND THEY HAVE BEEN STUCK LIKE FOR A YEAR, LET'S SAY. WOULD THAT BE GRANDFATHERED OR THAT STILL BE, UH, NOT MEETING THIS MARCH FOUR DEADLINE? LIKE STUDIES ARE COMPLETE, EVERYTHING IS DONE, BUT BECAUSE OF THE PROCESS DELAY HAS BEEN THERE FOR A WHILE GETTING NEGOTIATED. SO THE, THE DATE THAT THE, THE, THE CURRENT LANGUAGE THAT IS, UH, IN OUR MARCH 17TH COMMENTS WOULD LOOK AT THE DATE THAT THE PROJECT HAS COMPLETE, UH, STUDIES PER SEC, THE CURRENT SECTION 9.4 AND HAS MET ALL THE REQUIREMENTS OF THE CURRENT 9.5. OKAY. YEAH. THANK YOU. THANK YOU. ALRIGHT, EVAN, CHRIS, THEN BOB, AND LET'S TRY TO WRAP THAT UP AT THAT POINT. OKAY. JUST REAL FAST. UM, SO IT'S FOR RPGS, IT'S FOR THE DATE OF ENDORSEMENT. ARE WE THINKING THAT THERE'S ANY, UM, LIKE RECONCILIATION CONSIDERING THAT SOME OF THESE HAVE BEEN IN INDEPENDENT REVIEW FOR OVER A YEAR, AND SO ASSUMING ANY LARGE LOAD LIKE LILLIS 9 4 9 5 GOT COMPLETED WITHIN THE LAST YEAR, LIKE ALL THOSE RPGS ARE AUTOMATICALLY INVALID BASED OFF OF THIS CRITERIA? YEAH, I, I'M, I'M NOT ABLE TO SAY DEFINITIVELY THAT THAT WOULD COMPLETELY INVALIDATE THE RRP GI THINK WE'LL HAVE TO LOOK AT WHAT IS APPROVED IN THIS WINDOW AND EVALUATE THOSE. UH, YOU KNOW, I THINK THERE, UH, YEAH, IT'S JUST HARD TO SAY WITHOUT SPECIFICS OF WHAT WAS OR WAS NOT INCLUDED IN THOSE SPECIFIC. OKAY. YEAH. AND, AND IF I COULD JUST ADD, JUST TO CLARIFY, IT'S NOT INVALIDATING THE RPG, THE, THE PROJECT MAY STILL BE NEEDED, BUT IT IS, HAVE THE, THE LOADS THAT ARE INCLUDED, DO WE HAVE A STUDY THAT SHOWS CAN WE RELIABLY SERVE [00:25:01] ALL OF THOSE LOADS? THAT SO THAT THAT'S THE, THAT'S THE FUNDAMENTAL THING. SO IF THERE ARE OTHER PROJECTS THAT HAVE COME IN THAT WEREN'T INCLUDED IN THAT STUDY, THEN WE DON'T HAVE A STUDY THAT WE CAN POINT TO TO SAY, OKAY, WE, WE KNOW WE CAN RELIABLY SERVE ALL OF THESE LOADS. SO IT'S THAT THE, IT IT'S LIKELY THE PROJECT IS STILL NEEDED. THE PROJECT IS STILL VALID. IT, IT IS JUST, WHICH LOADS THAT WERE INCLUDED IN THAT STUDY NEED NEED TO BE EDI. OKAY. I THINK I KNOW WHAT YOU'RE SAYING. UM, I HAVE FURTHER CONCERNS WITH THAT, BUT WE CAN KEEP GOING. I'LL BRING UP LATER. THANK YOU. ALRIGHT. UH, CHRIS? OKAY, DROP. AND UH, KEVIN, YOU'RE RIGHT. IF I SAW NET METERING, I THOUGHT IT WAS DIFFERENT. GO AHEAD. YEAH. UM, MY QUESTION IS, DO INTERIM NET METERING PROJECTS HAVE TO GO THROUGH BATCH ZERO? UH, CHRISTINA, DO YOU WANNA TAKE THAT ONE BY NET METERING PROJECTS, DO YOU MEAN THE SB SIX NET? SB SIX? YEAH. DO THEY HAVE TO GO THROUGH BATCH ZERO? THEY WOULD HAVE TO GO THROUGH BATCH ZERO ONE WAY OR THE OTHER? YES. EITHER AS BASE LOAD OR AS STUDIED LOAD, ASSUMING THEY MEET THOSE REQUIREMENTS, UM, AS SET FORTH IN PGA 1 45. OKAY. THANK YOU. ALRIGHT, SO AT THIS POINT Q IS CLEAR AND GO BACK TO REGULARLY SCHEDULED PODCAST. ALRIGHT. UM, SO I'M JUST GONNA KIND OF WALK THROUGH THE OTHER CHANGES THAT WAS THE MOST SIGNIFICANT CHANGE IN THESE COMMENTS. UM, AND THEN, UH, LET'S SEE HERE. SO, UM, YEAH, AT THE, AT THE MARCH 10TH WORKSHOP, THERE WAS A KIND OF CLEAR DESIRE FROM STAKEHOLDERS TO SEE THE STUDY CASES POSTED ON THE MIS SECURE. AND SO, UH, WE'VE AGREED WITH THAT CHANGE AND HAVE MADE IT IN THE RED LINES. UM, THERE WAS CONCERN FROM SOME STAKEHOLDERS REGARDING THE ORIGINAL LANGUAGE AROUND, UH, THE INTERCONNECTING DSP OR INTERCONNECTING TSP TO ASSESS, UM, WHETHER THE DYNAMIC DATA WAS CONSISTENT WITH THE DATA USED IN THE STABILITY STUDY. UM, SO ERCOT HAS PROPOSED SOME CHANGES TO THAT LANGUAGE, UH, IN THE RED LINES THAT WOULD, UH, REQUIRE, UH, ASSESSMENT OF WHETHER OR NOT THE UPDATED DATA WOULD HAVE AN ADVERSE IMPACT ON THE PREVIOUS STABILITY STUDIES. UM, AND SO, YOU KNOW, I THINK WE, WE KINDA LOOK AT THIS AS ACTUALLY A, PROBABLY A BETTER STANDARD ANYWAY, UM, BECAUSE REALLY WHAT WE'RE TRYING TO DO IS FIGURE OUT IF THE PREVIOUS STUDIES ARE STILL VALID. UM, SO HOPEFULLY THAT WILL, UH, RESOLVE THE CONCERN. UH, AND IT ALLOWS FOR, YOU KNOW, KIND OF ENGINEERING JUDGMENT FROM THE, THE INTERCONNECTING DSP OR TSP, UH, TO, TO MAKE THAT ASSESSMENT. UM, WE HAD, UH, WE DID REMOVE, UH, SECTION 9.7 0.4, WHICH WAS NON UTILIZED CAPACITY. UM, UH, THIS WAS ORIGINALLY INCLUDED, UH, TO REFLECT, UH, THE FEBRUARY 13TH, UH, RECOMMENDED PROPOSAL FOR PUBLICATION FOR 58 41. UM, UH, AND WE ULTIMATELY, UH, DETERMINED THAT THAT WAS, UH, UH, NOT APPROPRIATE FOR LARGE LOADS AND, UH, NEEDED TO BE REMOVED. UM, SO, UH, IN ADDITION, UM, REFERENCES TO 9 7 4 WERE UPDATED. UM, UH, AND WE ALSO MADE THE CORRESPONDING, UH, THOSE, THOSE REFERENCES WERE REMOVED AND WE ALSO UPDATED THE NUMBERING, UH, ACCORDINGLY IN, IN 9 7 1 AND 9 7 2. UM, ADDITIONALLY, UH, THE MARCH 12TH OPEN MEETING, THERE WERE UPDATED PROPOSALS FOR PUBLIC, UH, THE UPDATED PROPOSAL FOR PUBLICATION, UM, FOR 58 41, UH, DID REQUIRE US TO MAKE SOME CHANGES TO SECTIONS 9 7 1 AND 9 7 2. UM, SO THOSE CHANGES WERE MADE TO ALIGN WITH WHAT WAS, UH, ULTIMATELY, UH, PUBLISHED. AND THEN, LET'S SEE HERE, DATE CHANGES, UH, THIS IS PROBABLY THE OTHER BIG CHANGE. UM, SO MULTIPLE STAKEHOLDERS AND THE DISCUSSION AT THE MARCH 10TH MEETING, UH, MARCH 10TH WORKSHOP, SORRY, UH, POINTED OUT THAT THERE WERE A LOT OF THINGS HAPPENING ON THE ORIGINAL JULY 15TH DATE THAT WAS PROPOSED IN P 1 45. AND MANY OF THOSE THINGS REQUIRED, SOME OF THE THINGS THAT WERE SUPPOSED TO ALL HAPPEN ON THAT DATE NEEDED TO HAPPEN FIRST BEFORE THE OTHERS COULD HAPPEN. AND SO, UH, WE AGREE, WE RECOGNIZE THAT. SO, UM, WHAT WE DID IS WE MADE, WE KINDA SPREAD THINGS OUT ACROSS THREE DATES. SO THERE IS THE JULY 10TH DATE WILL BE THE, UH, NEW CUTOFF TO MEET A LOT OF THE APPLICABILITY REQUIREMENTS. T INTERCONNECTING, TSPS AND DSPS WILL THEN [00:30:01] HAVE TWO WEEKS TO JULY 24TH TO, UM, PROVIDE INFORMATION TO ERCOT NEEDED FOR PERFORMING THE BATCH STUDY. AND THEN ERCOT WILL HAVE TWO WEEKS TO REVIEW AND GET EVERY, YOU KNOW, DETERMINE THINGS LIKE THE FINAL PLACEMENTS ON THE LIST, THE, THE, UM, THE LATTER, UH, AND PROVIDE FEEDBACK TO ALL TSPS TWO WEEKS LATER, TSPS AND DSPS ABOUT WHICH CUSTOMERS WERE TREATED IN WHAT, WHAT WAY, UH, FOR PATCH ZEROS. SO, UM, JULY 10TH, THE NEW CUTOFF, TWO WEEKS TO GET INFORMATION TO ERCOT, TWO WEEKS FOR ERCOT TO DE, YOU KNOW, MAKE THE FINAL DETERMINATIONS OF, UH, THE STRUCTURE OF INCLUSION FOR BATCH ZERO. UM, AND THEN FINALLY, UH, A NUMBER OF TYPOS AND, UH, THINGS LIKE COMMAS OUTTA PLACE AND THINGS LIKE THAT THAT, UM, NEEDED TO BE CORRECTED. UH, THERE WAS ONE SECTION WHERE, UH, THE CRITERIA HAD INCORRECTLY, UH, LISTED AN OR, AND IT SHOULD HAVE BEEN AN AND. UM, AND SO THOSE SORTS OF THINGS WERE CORRECTED. UH, AND THEN BEFORE I OPEN IT UP FOR QUESTIONS, YOU KNOW, I'LL JUST GO BACK UP TO, UH, SINCE THE, UH, LAST WORKSHOP WE'VE IDENTIFIED AND I THINK, UH, COMMENTERS, SOME COMMENTERS HAVE IDENTIFIED, UH, A NUMBER OF OTHER TYPOS AND SMALL CORRECTIONS THAT NEED TO BE ADDRESSED. UM, SO IF IT'S ON THIS LIST, WE, WE ARE AWARE OF IT, UH, AND THEY'LL BE ADDRESSED IN THE NEXT SET OF, UH, COMMENTS THAT WE FILE. OKAY, I THINK THAT'S, THAT'S WHAT I'VE GOT TO PRESENT THE COMMENTS. AGAIN, I'M HAPPY TO, YOU KNOW, WE DIDN'T LOOK AT MANY RED LINES, SO CERTAINLY HAPPY TO, IF YOU HAVE QUESTIONS ON SPECIFIC RED LINES, CERTAINLY HAPPY TO GO THROUGH THOSE. UM, SO MATT, UH, WHO'S IN THE QUEUE? YEAH, SO REAL QUICK, IT'S JUST BOB RIGHT NOW. BUT AS YOU THINK ABOUT QUESTIONS, SO AGAIN, WE HAVE THE RED LINE LANGUAGE ITSELF, WE ALSO HAVE THE CONCEPT SLIDES, WHICH WERE UPDATED TO SHOW THOSE RED LINES. SO IF YOU'RE LOOKING AT THAT FOR DELTA VIEW, BUT REALLY THIS IS OUR CUTS KIND OF A, LET'S PUT IT OUT THERE REALLY. I DON'T THINK THIS SHOULD BE A DEEP DIVE WITH A LOT OF QUESTIONS. SO MUCH HAS LED ALL THE PEOPLE THAT FILED COMMENTS FORMALLY AGAINST THIS, NOT AGAINST IT, YOU KNOW, SHARPENING IT, UH, TO GET THAT OUT INTO THE FIELD TO PLAY. SO WE DON'T WANNA STAY HERE LONG, BUT, UH, LET'S TAKE ANY QUESTIONS YOU MAY HAVE. SO BOB, BOB HILTON. YEAH, JUST REAL QUICKLY, ONE COMMENT, IT'S BACK ON, IT WAS A QUESTION THAT WAS ASKED EARLIER ABOUT WHERE DID THE MARCH 4TH DATE COME FROM? AND YOU'D INDICATE ON THE DAY THAT PICKER 1 45 WAS, WAS UH, POSTED. WE STILL HAVE AN ISSUE WITH THAT BECAUSE THAT'S STILL IN OUR MIND. IT'S BEING RETROACTIVE. IT SHOULD BE LOOKING AT THE DATE IT'S APPROVED RATHER THAN WHEN IT WAS FILED. SO I JUST WANTED TO SAY THAT WE STILL HAVE SOME ISSUES WITH RETROACTIVE DATES. THANK YOU. ALRIGHT. PRETTY GOOD. CHRIS, CHRIS MATHIS, I WANNA BE SURE I'M ASKING AT THE RIGHT POINT 'CAUSE MINE IS MORE ON LIKE THE AGREEMENTS AND STRUCTURE GENERALLY AS A CONCEPT FOR THIS OR THIS CAN BE ANYTHING RIGHT NOW. OKAY. YEP. COOL. UM, SO I NOTICED IN THE BATCH ZERO BASE, IT'S NOW PRETTY STRICT ON INTERCONNECTION AGREEMENT VERSUS INTERMEDIARY OR, HEY CHRIS, I'M SORRY, I'M HAVING A HARD TIME HEARING YOU. CAN YOU SPEAK IN YOUR MIND? YEAH, SO I NOTICED ON THE, UM, CHRIS MONTE WITH GOOGLE AND THE SLIDES FOR BATCH ZERO BASE, IT'S NOW INTERCONNECTION AGREEMENT AND, AND INTERMEDIATE AGREEMENTS ARE PRETTY MUCH IN BATCH ZERO, BATCH ZERO ALLOCATED, OR AT LEAST THIS WAS WHEN I LOOKED AT THE, THE SLIDE DECK LAST TIME, UH, CONTRACTING IS, IS A BIT OF A MESS RIGHT NOW. AND SO WHAT I'M TRYING TO FIGURE OUT TOO IS WHAT IS THE RELATIONSHIP IN THAT CONTRACTING ARRANGEMENT WHERE YOU HAVE A DSP WITH A TARIFF AND WE ENTER INTO A TARIFF AGREEMENT WITH THEM. AND THEN YOU ALSO HAVE THE ASSOCIATED RELATIONSHIP WITH THE TSP. LIKE WHAT IS THE OVERARCHING GOVERNING CONTRACT IN THAT SCENARIO? I, YEAH, CHRISTINA SWITZER OR COT SENIOR REGULATORY COUNCIL. UM, THIS IS WHERE WE, YOU KNOW, WE RELY ON THE PFP AND 58 41, WHICH ADDRESSES THE D-S-P-T-S-P SITUATION, UM, AND ALLOWS THE DSP AND TSP TO, UH, BETWEEN THEMSELVES DECIDE WHO WILL TAKE WHAT ROLE IN THE AGREEMENT. SO A BIT OF THE FEEDBACK ON THAT HAS BEEN, I THINK IT'S BETWEEN THEM, IT'S STILL VERY UNCLEAR TO THEM WHICH CONTRACT IS LIKE GOVERNING THAT WILL BE APPROVED BY ERCOT. AND SO, AND MAYBE THIS IS SOMETHING WE CAN JUST APPROACH ALL BILATERALLY ON AND FIGURE OUT THE APPROPRIATE CONTRACTING STRUCTURE. 'CAUSE THERE'S A BUNCH OF DIFFERING EXECUTED AGREEMENTS AND SOME OF THEM SAY INTERMEDIATE OR INTERMEDIARY, BUT IT'S ACTUALLY UNDER A TARIFF WITH THE DSP. AND THEN SIMILARLY WITH THE TSP, WE'RE TRYING TO NAVIGATE [00:35:01] VARIOUS LEVELS OF INTERMEDIARY AGREEMENTS THAT ARE TRYING TO BE COMPLIANT WITH WHAT'S ULTIMATELY DEEMED TO BE AN INTERCONNECTION AGREEMENT HERE. AND SO I THINK THIS IS ACTUALLY MORE FEEDBACK FOR, FOR THE TSPS IN THIS SCENARIO THAT WE, YOU KNOW, THE LOADS WOULD APPRECIATE Y'ALL WORKING WITH ERCOT TO FIND WHAT IS AN APPROPRIATE BATCH ZERO BASE AGREEMENT SO THAT WAY WE CAN JUST MOVE FORWARD QUITE CLEARLY 'CAUSE THE CONTRACTING HAS BEEN A NIGHTMARE IN THE LAST TWO WEEKS. THAT'S ALL. THANK YOU. ALL RIGHT. UM, UH, OR G HI, THIS IS OR ALWOOD TRACKED, UM, ON BADGE ZERO BASE SUB PARTS D AND E. UH, THOSE ARE THE FOLKS THAT ARE REQUIRED TO SIGN AN INTERCONNECTION AGREEMENT WITH THE NON-REFUNDABLE FEE IN JU BY JULY 10TH. BUT IT'S POSSIBLE THAT BY AUGUST THEY'LL BE TOLD THAT THEIR STUDIES ARE INVALID AND IT'S POSSIBLE THAT THEY'RE PUSHED TO THE BAD ZERO ALLOCATED THAT THEY COULD GET ZERO MEGAWATTS. SO IS THE, IS THE INTENT TO REQUIRE THE NON-REFUNDABLE FEE IN JULY, EVEN FOR THOSE PROJECTS WHOSE STUDIES ARE DEEMED INVALID IN AUGUST? I CAN TAKE THAT ONE AGAIN, AG, UM, THAT IS SOMETHING WE ARE TALKING ABOUT INTERNALLY RIGHT NOW, HOW TO HANDLE THAT SITUATION. UM, AND APPRECIATE ANY FEEDBACK ON THAT. THANKS. ALRIGHT, WELL AT THIS POINT THE QUEUE IS CLEAR, AMAZINGLY, UH, SO WHAT [4. Batch Zero comments filed by Stakeholders] I'D LIKE TO DO IS GO AHEAD AND PIVOT OVER TO OUR SPEAKERS. SO WHAT WE'RE GONNA HAVE SPEAKERS, UH, COMMENTERS IS THE RIGHT WAY TO SAY IT. SO, UM, AJ I GUESS I'LL RUN UP THERE. SO ANYONE THAT'S IN THE ROOM. SO AGAIN, IF YOU LOOK AT THE, I'M GONNA SWITCH SPOTS WITH YOU. GIMME 30 SECONDS TO GET TO THE PODIUM. ALRIGHT, SO WHAT I'M GONNA DO IS OPEN THE POWERPOINT THAT WE FILED ON THE WEB PAGE AT THE BOTTOM AND THE SPEAKERS. SO WHAT I CAN DO IS WE'RE GONNA GO IN ORDER. I DO HAVE, UM, TWO PEOPLE, UH, WE HAVE, UH, NED FROM RA, AARON FROM A P THAT BOTH HAVE AFTERNOON APPOINTMENTS. SO WE'LL WORK THIS ORDER, BUT WHEN WE GET CLOSER TO NOON, I'LL PROBABLY PAUSE AND TRY TO GET THOSE TWO IN TO GET THEIR PIECE IN AND THEN OFF THEY GO. AND THEN FORM WISE, I'M HOPING, LET'S JUST SEE HOW THIS GOES. WHAT WE CAN'T DO IS HAVE A FIVE MINUTE TOPIC AND THEN TALK ABOUT FOR 10 MINUTES AND THEN GO ON THE NEXT PERSON. SO WE'LL TRY TO FIND THE BALANCE OF WHEN DOES SOMETHING REALLY KEEN HIT, UM, BRIEF AND AMAZING AS PART OF IT. ALSO, IF SOMEBODY PRETTY MUCH SAID THE SAME THING BEFORE, IT REALLY HELPS ERCOT TO SAY WE'RE WITH THEM. WE HAVE THE SAME CONCERN AND YOU DON'T HAVE TO NECESSARILY REHASH IT. THAT'LL HELP US CONNECT THE DOTS ON WHERE THE COMMUNITY IS ON THESE ISSUES. SO, UM, AND AFTER WE GO THROUGH THIS, OUR, WE DO HAVE SOME SLIDES THAT GIVE, UH, KIND OF A BREAKDOWN OF WHAT ERCOT HAS SEEN OR HEARD THROUGH THE PATTERN OF ALL THIS THAT WE CAN WALK EVERYONE THROUGH. SO, UM, SO LET'S JUST BUCKLE IN TO GET TO LEARN FROM A LOT OF PEOPLE HERE. SO ANDREW CHAPAR, ARE YOU ONLINE? OH, THERE YOU'RE, AND THEN I'LL, LET ME OPEN YOUR COMMENTS. SORRY. 1, 4, 5. OH, THAT'S RIGHT. YOU HAVE MORE THAN ONE TO CHOOSE FROM. SO YEAH, I MAY NOT ACTUALLY SPEAK DIRECTLY FROM THE COMMENTS HERE. OH YEAH, THERE WE GO. NO, I DON'T HAVE TO LOOK STRAIGHT AT THE SCREEN THERE. AND IT'S GONNA SHOW US DOWNLOADED TO THE TOP RIGHT? YEP. UM, SORRY, IT'S BETTER THAT DROP DOWN. SHOW YOUR, YEAH, SORRY. OKAY. SO, UH, DID NOT REALIZE THERE WAS GONNA BE A LEADERBOARD FOR COMMENTS, UH, THAT I MADE MY WAY TO THE TOP OF. SO THERE WERE JUST A COUPLE THINGS. AND FIRST THANK YOU ERCOT FOR, UM, TAKING THE FEEDBACK AND THEN INCORPORATING THAT INTO THE LATEST, UH, SET OF COMMENTS THAT YOU GUYS PUT OUT THERE. I THINK AS YOU NOTED IN THE PRESENTATION, UH, THESE COMMENTS ARE PARTIALLY ADDRESSED. UM, AND, AND I THINK WE STILL HAVE SOME RESERVATIONS ABOUT THE MARCH 4TH DATE. UH, THOSE REALLY CENTER, AND I'M GONNA START WITH THAT POINT [00:40:01] AND THEN WE'LL HIT THE OTHER POINT. UM, BUT THE, HMM, LET'S SEE IF THIS IS THE CORRECT ONE. I'M NOT SURE IF IT IS OR NOT. SO I'M JUST GONNA BE BRIEF WITH THE COMMENTS. UM, THE, WHAT WE CALLED AN AIR GAP, RIGHT BETWEEN MARCH 4TH AND THE DATE, UH, THAT THE, THAT THE LARGE LOAD CUSTOMER HAS TO ABIDE BY THESE PROVISIONS IN, IN JULY, ON JULY 10TH IS CREATING A COUPLE PROBLEMS. ONE, PROCUREMENT AND CONSTRUCTION ALSO HAS TO BE ATTESTED TO, AND I KNOW THAT WAS A STAKEHOLDER COMMENT THAT CAME IN AND, AND SO THE REASON IT GOT INCORPORATED HERE WAS BECAUSE OF THE STAKEHOLDERS. BUT YOU, YOU CAN'T AT THE SAME TIME, UH, BE PLACED IN A POSITION TO MAKE IRREVOCABLE FINANCIAL COMMITMENTS AND NOT KNOW IF YOUR STUDIES ARE VALID. SO THAT'S NOT GONNA BE A WORKABLE CONSTRUCT. SO EITHER THE DATE IS MOVED FORWARD TO THE EFFECTIVENESS OF THE PIGGER OR THOSE THAT ARE BETWEEN IN THE AIR GAP BASICALLY ARE NOT ABLE TO, UM, MAKE THOSE ATTESTATIONS. AND I THINK REMEMBERING TOO, THAT IF YOU'RE IN THAT QUOTE UNQUOTE, UM, BATCH ZERO BASE LOAD, YOU ALSO HAVE ALREADY MADE AN IRREVOCABLE COMMITMENT TO THE UTILITY BY GIVING THEM A NOTICE TO PROCEED AND PUTTING CAPITAL AT RISK. SO I WOULD JUST ASK ERCOT TO CONSIDER THAT THANK YOU AG ALSO FOR ACKNOWLEDGING THE NEED FOR ONGOING COMMUNICATION OF HAVING MET 9 4 9 5. I THINK THAT'S GONNA BE VALUABLE TO THE LARGE LOAD DEVELOPER COMMUNITY. AND THEN ON THE CONTRACTING POINT, I THINK, UM, THIS IS REALLY IMPORTANT BECAUSE POST, UM, YOU KNOW, THE, THE DEADLINES FOR THIS POST JULY 10TH, THE CUSTOMERS ARE GOING TO HAVE ENTERED INTO NEED TO HAVE ENTERED INTO AN INTERCONNECTION AGREEMENT THAT ABIDES BASED ON THE RULES AS THEY'RE DRAFTED TODAY BY THE NEW 58 4 81 GUIDELINES. THE PROBLEM IS THAT ANYBODY THAT'S IN BASELOAD FIRM HAS ALREADY SIGNED AN INTERCONNECTION AGREEMENT, HAS ALREADY PROVIDED SECURITY TO THE UTILITIES. SO THE QUESTION, I GUESS, AND PART OF OUR COMMENTS IS WHY WOULD WE NOT JUST ASSUME THAT, CONSIDER THAT TO BE AN APPLICABLE INTERCONNECTION AGREEMENT UNDER THIS GUIDELINE. WE'RE GONNA MAKE PARALLEL COMMENTS IN 58 4 81 TO THIS EFFECT, WHICH ARE THE APPLICABILITY OF THOSE RULES. SO UNDERSTANDING THAT ERCOT IS TAKING GUIDANCE FROM THE PUC ON THIS, WHAT, WHAT I THINK BACK TO CHRIS'S POINT TOO, IT'S GONNA CREATE A COMPLIANCE CONTRACTING PROBLEM AND IT'S NOT THE LOAD CUSTOMERS THAT ARE GONNA CREATE IT, IT'S THE TSPS THAT ARE NOT GONNA BE ABLE TO CONFORM TO THE RULES FAST ENOUGH. YOU'RE GONNA BE DEALING WITH A VERY FINITE AMOUNT OF, UH, LEGAL, UH, PERSONNEL. AND SO JUST, JUST CONSIDER THAT FROM THE TIME THESE GO EFFECTIVE TO THE TIME THAT THE LOAD CUSTOMER'S GONNA HAVE TO ADOPT THEIR STANCE ON THAT. WE STILL DON'T KNOW WHAT 58 4 80 ONE'S GONNA LOOK LIKE IN FINAL DRAFT. SO THAT MEANS THAT NECESSARILY THE TSPS ALSO DON'T KNOW. SO I WOULD JUST CONSIDER THAT, YOU KNOW, ANYBODY THAT'S CONSIDERED BASE LOAD FIRM, I GUESS IN, IN THIS, I DON'T KNOW WHAT THE EXACT WORDING IS, BUT IF YOU'VE MET NINE FOUR AND NINE FIVE LEGACY, THERE'S NO REASON YOU SHOULDN'T BE ABLE TO CONTINUE ON INTO BATCH ZERO AS A FIRM BASE LOAD PROVIDED YOU MEET THE OTHER ATTESTATION REQUIREMENTS AND PROVIDED YOU HAVE THAT VISIBILITY NOW. RIGHT? SO THAT'S, I THINK THAT'S OUR MAIN POINTS AND THE CONTRACTING PIECE OF THIS IS SOMETHING THAT ONLY CAME UP IN THE LATER COMMENTS. SO I'LL DEFER THE REST OF MY TIME. THANKS EVERYBODY. YEP. HEY ANDREW, DO YOU MIND IF I ASK A COUPLE QUESTIONS? OF COURSE. UM, GO AHEAD. SO I THINK I UNDERSTAND YOUR, YOUR POINT ABOUT THE, UM, YOU KNOW THAT THE AFTER MARCH 4TH AND, AND AND THAT RISK, SO IF, IF ERCOT WERE TO PROVIDE AS A, YOU MENTIONED THE, THE KIND OF ONGOING UPDATES. WOULD, WOULD THAT, DOES THAT SOLVE, I THINK THAT WOULD GO A LONG WAY TO SATISFYING THE, THE CONCERNS. THAT'S RIGHT. THE ISSUE IS THAT LOAD CUSTOMERS NEED SOMETHING DEFINITIVE. THEY CAN'T HAVE A 97% ANSWER AND A POSSIBLE LOOK BACK, RIGHT? SO IF YOU CAN PROVIDE THE CERTAINTY TO THE LOAD CUSTOMER, THEN THE LOAD CUSTOMER CAN UNEQUIVOCALLY MOVE FORWARD AND COMMIT PROCUREMENT DOLLARS, CONSTRUCTION DOLLARS AND DO ALL THE OTHER ATTESTATIONS THAT ARE BEING REQUIRED. SO THAT, THAT'S REALLY, THERE JUST NEEDS TO BE KIND OF THAT MUTUAL UNDERSTANDING. GOT IT. OKAY. AND, AND THEN THE OTHER IS, IS KIND OF A COMMENT THAT MAY BE A QUESTION, AND I THINK OTHERS HAVE THIS COMMENT AS WELL, IS, UM, SO YOU KNOW, I'VE HEARD THE COMMENT, HEY, YOU KNOW, IF THEY MET 9 4, 9 5 PREVIOUSLY, THEN THEY OUGHT TO BE GOOD FOR ABOUT ZERO. WHAT I THINK I HEARD WHEN WE DID THE INTERVIEWS IN JANUARY WAS A LOT OF PEOPLE SAID, SAID, HEY, THE, THE WHAT IS CURRENTLY REQUIRED IN NINE FIVE, IT IS NOT NOT THAT ONEROUS. AND, AND SO WE, I HEARD A LOT OF DEVELOPERS [00:45:01] SAY WE BELIEVE THAT THERE ARE A LOT OF LOADS OUT THERE THAT ARE MEETING NINE FIVE THAT WON'T ACTUALLY GET BUILT BECAUSE IT'S, IT'S NOT A HIGH ENOUGH THRESHOLD. AND, AND SO WE THINK THAT THERE'S A LOT OF LOADS THAT ARE CLOGGING UP THE QUEUE THAT AREN'T, AREN'T REAL LOADS. I, YEAH, I, I DON'T HAVE THAT SAME PERSPECTIVE AND I THINK THE MAIN REASON IS BECAUSE UNDER NINE FIVE IS IT'S CURRENTLY DRAFTED, YOU HAVE TO PROVIDE SECURITY TO THE UTILITY FOR THE INTERCONNECTION FACILITIES THAT ARE GONNA BE BUILT AND YOU HAVE TO ISSUE A NOTICE TO PROCEED TO THEM. SO I MEAN, FOR MANY OF OUR PROJECTS THAT'S TENS OF MILLIONS OF DOLLARS THAT WE SAY GO FORTH AND BUILD YOUR PROJECT. OKAY. SO I, IF SOMEONE HAS A, A PROJECT AND I, I DON'T KNOW HOW THEY WOULD BE MEETING NINE FIVE UNDER THOSE CONDITIONS, BUT YEAH, IT'S, I I HAVEN'T HEARD THAT CONCERN. OKAY. OKAY. THANK YOU. YEP. ALRIGHT, EVAN, YOU'RE NEXT. IF YOU WANT ME TO OPEN YOUR DO PEOPLE, IF YOU WANT YOUR COMMENTS OPEN, PLEASE LET ME KNOW. I'D BE HAPPY TO OPEN THEM. UM, I CAN JUST SPEAK TO MINE REALLY QUICK, MATT, I CAN JUST FROM HERE IT'S FINE, BUT THANKS. UM, SO LANCEY SUBMITTED COMMENTS AS WELL, ECHOED A LOT OF THE STUFF THAT ANDREW JUST MENTIONED AS WELL AND, AND AGREED WITH SOME OF THE CHANGES THAT ERCOT MADE. UM, AND THEN WE JUST SUGGESTED TWO, UM, RATHER SURGICAL CHANGES TO THE LANGUAGE. SO THE FIRST OF WHICH WAS, UM, TALKING ABOUT MODELING ALREADY APPROVED AND OPERATIONAL LOADS OF JUST BASICALLY TAKING THE LCP RATHER THAN DOING THE RTP PLUS THE LCP. 'CAUSE WE SEE THAT AS KIND OF TWO SEPARATE DATA SOURCES AND IT JUST, YOU KNOW, IF THE GOAL IS JUST TO GET SOMETHING ACCURATE, WE FEEL LIKE THE LCP IS PROBABLY THE BEST WAY TO DO THAT. I UNDERSTAND YOU HAVE LOADS THAT DON'T HAVE LCPS, SO WE KIND OF STRUCTURED IT TO DEFAULT TO THE RTP VALUE FOR THOSE, BUT THEN THE LCP VALUE FOR THE ONES THAT DO HAVE THE LCPS. UM, AND THEN THE SECOND BIG POINT THAT I WANT TO MAKE, WHICH THE REST OF THE COMMENTS KIND OF TALKS TO AND WOULD APPRECIATE IF IF THERE'S DISCUSSION AROUND THIS AND JUST HEAR PEOPLE'S PERSPECTIVES IS WE KIND OF VIEW THERE TO BE A, A GAP CURRENTLY WITH THE RPG PROJECT SPECIFICALLY. SO THE LANGUAGE IN HERE TALKS ABOUT THAT DECEMBER 15TH DATE AND THEN IF AN RPG WAS NOT SUBMITTED BEFORE THAT DATE, THEN IT'S LOADS THAT WERE INCLUDED IN THAT RPG CANNOT BE CONSIDERED VALID STUDIES FOR, FOR ANY PATH. UM, WE FEEL LIKE THAT IS A BIT IN CONFLICT WITH THE COMMENTS THAT ERCOT PROVIDED TO CENTERPOINT'S, UH, BAYTOWN RPG PROJECT THAT SAYS THAT ALL RPGS SUBMITTED PRIOR TO APRIL 1ST WILL USE THE OLD DEFINITION OF SUBSTANTIATED LOAD TO JUSTIFY THOSE RPG PROJECTS AND EVERYTHING AFTER APRIL 1ST TO USE THE 5 8 4 8 0. AND SO WE FEEL LIKE WE'VE KIND OF WALKED INTO A POSITION WHERE, UM, WE HAVE TENS OF BILLIONS OF DOLLARS IN PROPOSED TRANSMISSION THAT WE ARE SAYING YES WE CAN APPROVE THIS BASED ON THE RPGS THAT ARE SUBMITTED NOW, BUT WE WILL NOT INCLUDE THE LOADS THAT JUSTIFYING THOSE RPG PROJECTS IN BATCH ZERO AS HAVING VALID STUDIES OR, OR IN SOME CASES CONSIDERED AT ALL. AND SO WE ARE TALKING ABOUT APPROVING TENS OF BILLION DOLLARS IN TRANSMISSION BUT THEN NOT ALLOWING THE LOADS AND PATH TO, TO COME ONLINE THAT ARE JUSTIFYING THOSE. UH, AND JUST ESPECIALLY CONSIDERING THAT BATCH ZERO IS JUST ONE STUDY AND THERE IS NO LINE OF SIGHT TO A FUTURE BATCH PROCESS, I UNDERSTAND THAT'S GONNA BE IN THE WORKS AND IT'S GONNA COME, IT IS TOUGH TO, TO SWALLOW THAT, THAT WE'RE GONNA APPROVE ALL THAT TRANSMISSION AND NOT LET THE LOADS COME ONLINE. UM, SO I THINK, YOU KNOW, THE ELOQUENT WAY WOULD JUST BE TO CLOSE THAT GAP AND TO, IF WE'RE GONNA, YOU KNOW, USE THAT APRIL 1ST DATE BASED ON THE, UH, 5 8 4 8 0 LANGUAGE, THEN WE SHOULD PROBABLY BE CONSISTENT WITH THAT HERE IN BATCH ZERO JUST SO WE DON'T CREATE THAT MISMATCH. ALRIGHT, ANY QUESTIONS? ALRIGHT, THANK YOU EVAN ONTO HANE, STRADER HAYNES, IF YOU'D LIKE TO COME UP OR DO IT FROM THERE, WHATEVER WORKS, I'LL DO IT FROM HERE. THAT'S OKAY. AND I, I, I DON'T, WE DON'T, UH, NEED TO RUN THROUGH IT. ONE, JUST CLARIFICATION, IF YOU WERE TO GO BACK TO THE SLIDES OF THE, UM, THE TYPOS, UM, SO ON 9.3 0.12 B, I THINK I, I THINK THAT'S AT LEAST OUR OPINION AS THAT SAME ISSUE EXISTS IN UM, 9.2. SORRY, LEMME GO BACK TO MY NOTES HERE. UM, IN, UH, 9.21, D TWO AND E TWO. IS THAT [00:50:04] ALL RIGHT? SORRY, WHAT SECTION AGAIN? SO 9.1 0.1, 9.1 POINT, I'M SORRY, 9.2 0.1 0.1 1D 9.2 0.1 0.2. IS THIS ABOUT THE RIGHT AREA? UH, 1.1, ONE SECTION ABOVE THIS. OKAY. UH, AND THEN IT'S 1D TWO TWO? YES. SHOULD THAT NOT ALSO HAVE TSP? IS THERE A REASON THAT'S ONLY DSP? HEY MATT, I CAN HELP ANSWER THAT ONE. SO LOOKING AT TWO, THIS IS THE ATTESTATION FOR THE INTERCONNECTION AGREEMENT AND WE LIMITED IT TO INTERCONNECTING DSP HERE TO, UM, TO PARALLEL WHAT IS IN 25, UH, THREE 90 THE LOAD FORECASTING RULE. IT'S THE INTERCONNECTING DSP THAT MUST PROVIDE THIS INFORMATION FOR THE LARGE LOAD FORECAST TO ERCOT. AND SO WE WERE PARALLELING THAT STRUCTURE HERE AND IF THE TSP AND DSP ARE THE SAME ENTITY, DOES IT, IT DOESN'T MATTER. THAT'S FINE. YEAH, IT DOESN'T MATTER IN THAT CASE. OKAY. ALRIGHT THEN MAYBE IGNORE THAT COMMENT IN OUR, OKAY. THAT WAS THE ONLY CLARIFICATION. SO THE ONLY OTHER COMMENTS I'D MAKE, AND I'LL BE QUICK, I COMPLETELY AGREE WITH ANDREW'S COMMENTS ABOUT, UM, MARK THE MARCH 4TH DATE AND THE CHALLENGES THAT THAT CREATES. I THINK THAT IS A REAL, UM, ISSUE. I THINK IF YOU'RE LOOKING TO JEFF'S COMMENTS ABOUT LIMITING WHAT'S REAL AND NOT REAL AND YOU'RE TRYING TO WORK WITHIN THAT FRAMEWORK, I WOULD JUST STRONGLY SUGGEST THAT YOU LOOK AT, IS THERE AN EXISTING INTERCONNECTION AGREEMENT OR FEA OR WHATEVER THE, THE, THE RIGHT TERM IS, HAS SIGNIFICANT FINANCIAL SECURITY BEEN POSTED AND IS THE PROJECT, DOES IT MEET KIND OF THE MATURITY INDICATORS THAT WE'VE TALKED ABOUT FROM A CONSTRUCTABILITY STANDPOINT? HAVE THEY MADE THOSE ATTESTATIONS? IF IT QUALIFIES FOR ALL OF THAT. AND THE ISSUE IS THAT IT'S BEEN IN THE ERCOT RE STUDY LOOP, THOSE PROJECTS SHOULD STILL BE ABLE TO GET THROUGH THAT PROCESS OVER THE NEXT COUPLE OF MONTHS AND BE CONSIDERED IN MY, IN MY OPINION. I JUST, I THINK WE HAVE A LOT OF PROJECTS THAT ARE, I MEAN MORE, WE'VE HAD A SIGNED INTERCONNECTION AGREEMENT FOR MORE THAN A YEAR THAT, UH, YOU KNOW, WE, WE HAVE A SUBSTATION UNDER CONSTRUCTION RIGHT NOW IN BUILDINGS THAT ARE ABOUT TO BREAK GROUND. AND SO THE, UH, IN SOME CASES BUILDINGS ARE ALREADY WELL UNDERWAY AND SO I THINK IT'S JUST IMPORTANT TO MAKE SURE WE'RE LOOKING AT WHAT IS, WHAT HAS ACTUALLY BEEN POSTED AND WHAT'S ACTUALLY UNDERWAY AND HAPPY TO MAKE WHATEVER ATEST STATIONS ARE NEEDED. AND THERE ARE PLENTY OF PROJECTS THAT WE HAVE WHERE I CAN'T MAKE THOSE ATTESTATIONS AND THAT THAT WOULDN'T BE QUALIFIED YET. AND I UNDERSTAND THAT AND THAT WE'RE TOTALLY FINE WITH THAT BEING PUSHED OUT. BUT THERE, THERE ARE SEVERAL THAT, UM, ARE QUITE ADVANCED AND I THINK GOING BACK IN TIME BECAUSE OF, AND YOU KNOW, IF YOU LOOK AT 9.5, ERCOT DIDN'T MEET ANY OF THE TIMELINES THAT ARE OUTLINED IN IN THAT PROCESS IN OUR STUDIES. YOU KNOW, IT'S, IT'S, THERE WAS NO 10 DAY RESPONSES OR ANYTHING LIKE THAT. SO I I THINK WE JUST, WE'D LIKE TO BE TREATED FAIRLY IN, IN THAT REGARD. UM, IF YOU GO TO, I THINK, UH, WHERE THERE ARE REFERENCES TO THE $50,000 PER MEGAWATT, MY ONLY SUGGESTION THERE WOULD JUST BE TO REFERENCE, UM, UH, 58,481 AS WHATEVER THAT ENDS UP BEING SO THAT, UM, THAT COULD BE FUNGIBLE. 'CAUSE THE REALITY IS, UNTIL THAT RULE MAKING IS CORRECT, WE HAVE NO WAY OF PAYING THAT. SO EVEN IF WE HAD IT READY TO GO TODAY, THERE'S, THERE'S NO PROCESS OR MECHANISM FOR US TO SUBMIT THAT FUNDING. UM, I THINK THOSE ARE PROBABLY MY, THAT'S PROBABLY MY MAIN COMMENT FOR TODAY. UM, LEMME JUST CHECK REAL QUICK. HEY, MATT, CAN I, UM, RESPOND TO HANES REAL QUICK? THIS IS BARKSDALE WITH THE PUC UH, HANES. WITH REGARD TO YOUR LAST COMMENT. I THINK THE REASON WHY IT'S, UM, HARD CODED IN HERE IS BECAUSE THE RULE FOR 5 8 4 8 1 IS NOT GONNA BE COMPLETE BY THE TIME THESE REVISION REQUESTS NEED TO GO TO THE JUNE BOARD. AND SO WHILE WE'RE STILL WORKING OUT WHAT THE LEGAL PROCEDURES ARE GONNA BE TO CODIFY THE REVISION REQUESTS THAT WILL ENACT BATCH ZERO, BATCH ZERO WILL HAVE TO EXPLICITLY STATE WHAT THOSE REQUIREMENTS ARE AND NOT POINT TO THE RULE THAT WILL ULTIMATELY BE ADOPTED UNDER PROJECT 5 8 4 81. DOES THAT MAKE SENSE? YES. UM, AND SORRY, MY, MY ONLY OTHER COMMENT I WAS GONNA MAKE IS, UH, 9.7 0.21 F AND G IS JUST AS WE'RE LOOKING AT FINANCIAL COMMITMENTS, I THINK IT'S IMPORTANT TO TAKE IN CONSIDERATION FINANCIAL COMMITMENTS THAT HAVE ALREADY BEEN PAID OR POSTED. SO IN SOME CASES, YOU KNOW, WE MAY HAVE 10, 15, 20, $30 MILLION ALREADY POSTED. UM, IF THAT'S, AGAIN, I THINK IF THAT WAS, IF THAT AGREEMENT WAS SIGNED PRIOR TO DECEMBER 15TH, 2025 [00:55:02] TO THEN REQUIRE ADDITIONAL FUNDING FOR PROJECTS THAT ARE ALREADY SIGNED AND FUNDED IS A, IS A PRETTY BIG TALL ORDER, UH, LATE IN THE FINANCIAL PROCESS. AND SO I, I THINK FROM OUR PERSPECTIVE, IF YOU'RE, IF YOU HAD YOUR SIGNED AGREEMENT PRIOR TO DECEMBER 15TH, 2025 AND YOU SUBMITTED FINANCIAL, UH, SECURITY AS, AS REQUIRED BY THE, THE INTERCONNECTING TSP, THOSE FINANCIAL COMMITMENTS SHOULD BE GRANDFATHERED IN AND SHOULD NOT BE SUBJECT TO THESE NEW FEES. THERE ARE A COUPLE QUESTIONS IN THE QUEUE PERHAPS FOR YOU, UH, YANG AND THEN DURKA THERE. UH, THIS IS YANG FROM WHITE. UH, I GOT A QUESTION RELATED TO THE LAST QUESTION ASKED, UM, ABOUT THE ATTESTATION FROM THE INTERCONNECTING DSP ACTUALLY FOR THE LOAD FORECAST. LOAD FORECAST PURPOSE IS NOT JUST THE DSP, IT'S ALSO THE AUTHORIZED TSP BY THE DSP. SO IN REALITY, WE, WE DO BOTH, RIGHT? IT'S THE MAJOR PART IS THE DSP, BUT SOME, SOME TSP ALSO BY THE, BY THE DSP ALSO IT'S ALLOWED, IT'S ALSO ALLOWED TO SUBMIT THE LOAD FOR, UH, LOG LOAD REQUEST, UH, TO OUR FOR THE 2026 RTP. SO IN THIS CASE, CAN WE CHANGE THIS LANGUAGE HERE THAT IS NOT JUST THE DSP BUT ALSO THE AUTHORIZED TSP FOR THE ATTESTATION? YEAH, I APPRECIATE THE QUESTION. WE WERE LOOKING AT 25 3 70 C, WHICH IS THE ONGOING PROCESS, AND THAT IS LIMITED TO THE INTERCONNECTING DSP, ALTHOUGH THE INTERCONNECTING TSP CAN PROVIDE INFORMATION TO THE INTERCONNECTING DSP TO INCLUDE IN THE LOAD FORECAST. WE WERE NOT, UM, WE WERE NOT USING WHAT IS IN THE 2026 RTP COMPLIANCE PLAN FOR THE GOING FORWARD PROCESS HERE IN PICK 1 45. WE THINK IT'S APPROPRIATE TO USE WHAT'S IN SECTION C. ALRIGHT, THANKS. ALRIGHT, DURGA, UM, THIS IS DURGA FROM SOFTBANK ENERGY. UM, AS A QUESTION, UH, ON THE SAME LINES AS WHAT YANG ASKED, UH, FROM, WE, UH, IF, IF A, IF A GENERAL, IF A DSP IS WILLING TO ATTEST TO THE FACT THAT ALL THE REQUIREMENTS HAVE BEEN MET TO, UM, BRING A PROJECT ONLINE, UM, AND FINANCIAL, SIGNIFICANT FINANCIAL COMMITMENTS CAN BE SHOWN, UM, AND ATTESTATIONS CAN BE SIGNED ON THE ILE SIDE, ON THE DSP ON THE P SIDE, BUT STILL THE AGREEMENTS ARE NOT SIGNED. WOULD A COURT, UM, BE WILLING TO, UM, ACCOMMODATE THOSE KIND OF PROJECTS AS BASELOAD IN THE, IN THE, IN THE COMING BATCH PROCESS OR THERE'S A ROOM FOR THAT KINDA EXCEPTION? NOT AS WRITTEN. WE ARE FOLLOWING WHAT IS IN 58 4 81 PFP. UNDERSTOOD. CHRISTINA, THE ONLY, ONLY THING IS THAT ONE THING THAT'S, THAT'S MISSING IS THAT FOR A LONG TIME WHEN WE WERE INTERACTING WITH THE DSPS, THEY WERE, THEY WERE HAVING A HARD TIME TO FIGURE OUT WHAT THE FORMAT IS FOR THE, FOR THE INTERCONNECTION AGREEMENT. AND THEY HAVE BEEN NEGOTIATING WITH THE, WITH THEIR COURT. SO THAT TOOK A BUNCH OF TIME OUT OF THE NEGO FOR, UH, THAT TOOK A BUNCH OF, UM, MAJOR PORTION OF THE, OF THE, OF THE NEGOTIATION THAT IIES USED TO HAVE WITH THE DSP. SO THAT'S THE REASON, UH, I'M ASKING FOR AN EXCEPTION IN THE SENSE THAT BECAUSE THAT WAS NOT DECIDED, THAT WAS THE REASON A LOT OF IIES COULD NOT SIGN THE AGREEMENTS. SO, UM, SOME KIND OF ROOM HAS TO BE CREATED FOR THOSE KIND OF PROJECTS, WHICH WAS STUCK IN THE NEGOTIATION FOR A LONG TIME BECAUSE THERE WAS NO AGREEMENT IN PLACE OR STRUCTURE IN PLACE. UM, SO YEAH, THAT WAS THE REQUEST. ALL RIGHT, THANK YOU. THANK YOU. UH, THEN BOB, THEN TYLER, THEN WE'RE GONNA TRY TO MOVE ON. HI BOB KING HERE FOR TRACK TODAY, SINCE WE'RE TALKING ABOUT THIS SECURITY, IT SEEMS LIKE THERE'S ONE OTHER GAP OR WHATEVER YOU WANNA CALL OR MISTAKE HERE, WHICH IS THAT IF YOU SIGN AN INTERMEDIATE AGREEMENT, YOU PUT 50,000 PER MEGAWATT SECURITY DOWN, WHICH IS FINE, BUT IF YOU GET THROUGH THE BATCH STUDY AND GET ALLOCATED NOTHING AND WITHDRAW, YOU STILL LOSE 80%. WE CAN'T MEAN THAT YOU WOULD BE COLLECTING LITERALLY BILLIONS OF DOLLARS FOR ALL THE PEOPLE THAT ARE GONNA GET NO OR TOO LITTLE. IS THAT INTENTIONAL , UH, THAT IS WHAT IS IN 58 4 81. SO I THINK IF YOU HAVE A CONCERN ABOUT THAT, THAT'S BETTER ADDRESSED AT THE PUC. WELL, BUT YOU JUST HEARD THAT THE P C'S NOT ON THE SAME SCHEDULE. SO WE'RE GONNA ADDRESS THIS IN COMMENTS TO [01:00:01] THE PUC, BUT THEY NEED, WE WILL ADDRESS IT HERE THIS COMING WEEK AS WELL. 'CAUSE THIS IS SOMETHING THAT'S JUST A MISMATCH IT FEELS LIKE. RIGHT? HEY, BOB? YEAH. UM, FILE YOUR COMMENTS IN 5 8 4 8 1. AND, UM, WE ALL KNOW THAT AS THE LANDSCAPE OF THAT RULEMAKING STARTS TO EVOLVE BASED ON STAKEHOLDER COMMENTS, ERCOT AND THE PUC WILL BE HAVING TONS AND TONS AND TONS OF CONVERSATIONS ABOUT HOW TO START ADAPTING THE BATCH ZERO REVISION REQUESTS TO MAKE SURE THAT THESE ARE SIMILARLY EVOLVING. MM-HMM . AT SOME POINT IN THE NEAR FUTURE, MAYBE IT'S A MONTH FROM NOW, THERE'S GONNA BE A SPLIT IN THAT PATHWAY. THERE'S GONNA BE A DIVERGENCE, AND, YOU KNOW, PERHAPS IT'S THE END OF APRIL WHEN WE NEED TO START NAILING DOWN ALL OF THE PROVISIONS IN P 1 45 AND ALL THE ASSOCIATED REVISION REQUESTS WHILE THE RULEMAKING CONTINUES TO EVOLVE. OKAY? SO, OKAY. THE BEST WAY TO PROVIDE THAT FEEDBACK IS IN 5 8 4 8 1, BECAUSE WE'RE ALL TALKING ABOUT IT TOGETHER, RIGHT? THAT'S IN PROCESS. I JUST WANNA MAKE SURE THAT WAS HIGHLIGHTED HERE. THANK YOU. WE UNDERSTAND THE CONCERN. THANKS. ALL RIGHT. TYLER, YOUR NEXT UP. TYLER, ALLIE. YEP. TYLER, ALLIE, ROSE, CITY PARTNERS. UM, I JUST THANK YOU AGAIN FOR, UM, TAKING INTO ACCOUNT ALL OF OUR FEEDBACK AND, UH, HEARING THAT YOU GUYS ARE CONSIDERING THAT ROLLING. UM, UH, YOU KNOW, COMMUNICATION TO US, I THINK IS REALLY HELPFUL AS WE THINK ABOUT THE FINANCIAL PIECES OF THIS AND CONSTRUCTION AND ALL THOSE OTHER THINGS. UM, THE SOONER WE CAN KNOW, UH, THAT WE'RE GOOD, THE SOONER WE CAN OBVIOUSLY SPEND MONEY. UM, BUT JUST, UH, ON THAT COMMUNICATION, JUST WANNA POINT OUT THAT THE MORE DEFINITIVE YOU GUYS CAN BE WITH THAT COMMUNICATION, AND THE MORE, LIKE, IF, IF YOU THINK ABOUT WHAT WE'RE GONNA DO WITH THAT COMMUNICATION IS WE'LL EITHER BE TAKING, MANY OF US WILL BE TAKING IT TO INVESTORS, TAKE IT TO THEIR BOARD, TAKE IT TO THEIR BOSS, TAKE IT TO THEIR LENDER, WHOEVER IT MAY BE, THAT THAT, AND SO THE FORMAT OF THAT COMMUNICATION, JUST THE MORE, I DON'T EVEN KNOW, MORE FORMAL OR THE MORE CLEAR IT IS, UM, IS HELPFUL. AND THEN, YOU KNOW, AND THE, THE MORE CLEAR THAT IS, I THINK THE EASIER IT IS FOR US TO COMPLY WITH ALL THESE OTHER, UM, ALL THESE OTHER, UH, ASKS. UM, BUT THAT WAS JUST A, JUST, IT MIGHT SEEM LIKE A SMALL DETAIL, BUT IT REALLY GOES A LONG WAY IF THAT COMMUNICATION IS, IS, IS, IS VERY, IS IS MORE FORMAL IN NATURE. THANKS. ALL RIGHT. THANKS TYLER. ALRIGHT, SO AT THIS POINT, UH, WE ARE READY TO MOVE ON TO, I I DO I HAVE THE ORDER RIGHT? YEAH. JASON DATE? YEAH, YOU'VE GOT JASON DATE HERE ON THE LINE FROM IRON. CAN, CAN YOU HEAR ME ALL RIGHT? WE CAN. LOUD, CLEAR. PERFECT. UM, YEAH, SO FIRSTLY, THANKS TO ERCOT FOR ALL THE TIME AND EFFORT THAT'S GONE INTO THE, THE BATCH PROCESS THUS FAR. UM, OUR MAIN COMMENT AS IT RELATES TO, TO BIGGER 1 4 5 IS THE FACT THAT THERE'S NO QUEUE SYSTEM FOR PROJECTS THAT ARE WITHIN BATCH ZERO, EITHER BASE LOAD OR, OR TO BE STUDIED. UM, AND, AND SO THIS MAY LEAD TO UNINTENDED CONSEQUENCES WHEREBY LOADS THAT BEEN, YOU KNOW, DEVELOPING PROJECTS FOR SEVERAL YEARS RECEIVED THE SAME MEGAWATT ALLOCATION IN A STUDY YEAR AS THOSE THAT HAVE SUBMITTED LOAD REQUESTS MORE RECENTLY. UM, SO OUR RECOMMENDATION IS TO PRIORITIZE MEGAWATT ALLOCATION EACH STUDY YEAR BASED ON THE PROJECT'S INITIAL LOAD REQUEST DATE, UH, THEREBY ESTABLISHING I GUESS MORE OF WHAT IS A QUEUE SYSTEM, WHICH IS, IS I GUESS COMMON FOR LOAD AND GENERATION INTERCONNECTION PROCESSES. UM, LOAD REQUEST DATE SEEMED LIKE A MORE FAIR AND TRANSPARENT DATE THAN AN LLI NUMBER. UM, OR OTHER METRICS, UH, BECAUSE DIFFERENT TSPS AS WE KNOW, REQUEST LLI NUMBERS AT DIFFERENT STAGES OF, OF PROJECTS DEVELOPMENT. UM, SO AFTER SOME KIND OF BACK AND FORTH BILATERAL DISCUSSIONS WITH ERCOT, IT, IT SEEMED LIKE RUNNING STUDIES ON A PER LOAD BASIS IS GONNA BE PROBLEMATIC AS IT'S JUST GONNA BLOW OUT THE STUDY PROCESS AND IT'S GONNA TAKE TOO LONG TO RUN THE STUDIES FOR BATCH ZERO. UH, SO WHAT WE LOOKED AT WAS COULD YOU GROUP PROJECTS INTO LOAD REQUEST DATE VINTAGE YEAR AS ANOTHER EXAMPLE. SO, YOU KNOW, 20, 22, 23, AND SO ON AND SO FORTH. BUT THAT ALSO MIGHT BE TOO SLOW FROM A STUDY PROCESS PERSPECTIVE. UH, SO WHAT, WHAT WE ULTIMATELY RECOMMENDED AS PART OF OUR COMMENTS WAS A TWO STEP PROCESS, UM, WHEREBY FIRSTLY LOADS WITH THE LOAD REQUEST DATE OF PRIOR TO MARCH 25TH, 2022, UH, THAT MEET THE BATCH ZERO CRITERIA FIRST ALLOCATED MEGAWATTS UP TO THEIR REQUESTED RAMP SCHEDULE IN A GIVEN CALENDAR YEAR. AND THEN THERE'S A SECOND, UH, STUDY PROCESS FOR ALL LOADS, UM, WITH LOAD REQUEST DATES AFTER THAT [01:05:01] DATE. UM, NOW WHY, WHY USE THAT DATE? UM, YOU KNOW, IT'S CERTAINLY OPEN TO, TO FEEDBACK ON, ON WHAT SPECIFIC DATE SHOULD BE USED. WE, WE SELECTED THAT DATE BECAUSE THAT WAS WHEN ERCOT FIRST IMPLEMENTED THE INTERIM LARGE LOAD INTERCONNECTION PROCESS. SO IT SEEMED LIKE A PIVOTAL MOMENT IN THIS WHOLE EVOLUTION OF THE, THE ERCOT LARGE LOAD CONNECTION PROCESS. UM, WE, WE THINK THAT THE CONCEPT IS, IS IMPORTANT TO INCLUDE, BUT YOU KNOW, AS I SAID, OPEN TO FEEDBACK AS AS TO WHAT THE, THE MOST SUITABLE DATE IS TO, TO USE THE VERY GOOD. IS THERE A TABLE OR SOMETHING THAT WOULD HELP TO SHOW HOW THIS WORKS? YEAH, THERE WE GO. YEAH, THERE'S A TABLE THERE. EXACTLY. SO YEAH, IF, IF HAPPY TO RUN THROUGH IT, IT'S RELATIVELY STRAIGHTFORWARD, BUT YEAH, I GUESS THIS IS JUST SHOWING IF YOU'VE, YOU KNOW, GONE THROUGH THE CONNECTION PROCESS SINCE, YOU KNOW, 2021 OR 2022, UM, YOU MIGHT RECEIVE THE SAME ALLOCATION AS A LOAD THAT'S SUBMITTED A REQUEST IN 2025 UNDER THE CURRENT DRAFTING OF THE, THE RULE. UH, WHAT WE'RE PROPOSING HERE IS TO HAVE A TWO STEP PROCESS THAT GIVES SOME LEVEL OF PRIORITY TO, UH, LOADS THAT HAVE BEEN DEVELOPING PROJECTS AND FOLLOWING THE DEFINED CONNECTION PROCESS FOR A LONGER PERIOD OF TIME. ALRIGHT, SO INITIAL FEEDBACK FROM THE GROUP OR QUESTIONS. ALL RIGHT, JASON, I HAVE A PRETTY QUIET AUDIENCE HERE. SO YOU'VE PUT OUT A PROPOSAL GROUP'S. QUIET. ALRIGHT, WELL THANK YOU. IS THERE ANYTHING ELSE YOU WANNA SHARE? UM, I THINK THAT WAS OUR MAIN COMMENT. WE ADDED SOME OTHER COMMENTS THERE JUST AROUND TRYING TO STANDARDIZE AGREEMENTS FOR, YOU KNOW, THE INTERMEDIATE AGREEMENT AND INTERCONNECTION AGREEMENT JUST TO STREAMLINE PROCESSES. BUT, UM, I, I, I'LL, UH, I'LL PAUSE THERE 'CAUSE I KNOW WE'RE ON A TIGHT SCHEDULE. ALL RIGHT. THANK YEAH, WE HAVE ONE QUESTION, ANDREW, GO AHEAD. YOU KNOW, ONE POINT ON THE AGREEMENTS, THIS ACTUALLY GOES BACK TO SOMETHING CHRIS SAID A MINUTE AGO IS, UM, IN 58 4 81, THEY DEFINE INTERMEDIATE AGREEMENT AND INTERCONNECTION AGREEMENT. THERE PROBABLY NEEDS TO BE A DEFINITION FOR ALL OTHER AGREEMENTS THAT DON'T MEET EITHER OF THOSE TWO. AND THERE'S A BUNCH OF THOSE OUT THERE. A LOT OF THE TSPS ARE DOING THIS. SO, UM, THAT'S SOMETHING THAT WE'RE GONNA TRY TO ADDRESS WITH THAT RULE MAKING, BUT MAYBE SOMETHING ERCOT MIGHT WANT TO CONSIDER AS WELL IS JUST LIKE A BLANKET CATCHALL FOR ANY OF THOSE NON-CONFORMING AGREEMENTS AND THEN AN EFFORT TO MAKE THOSE CONFORMING OVER SOME TIMEFRAME. YEAH. VERY GOOD. AND THEN, UH, PRASHAN, UH, YES, UH, THIS IS P CAN YOU SPEAK UP A LITTLE BIT? CAN YOU HEAR ME NOW? THAT'S BETTER. THANK YOU. OKAY. UH, JUST A QUICK CLARIFICATION ON THE MEGAWATT ALLOCATION. SO, IS THE RECOMMENDATION TO BASICALLY ALLOCATE BASED ON WHEN A PROJECT WAS SUBMITTED RATHER THAN WHAT THE IMPACT OF THE PROJECT ON A CERTAIN OVERLOAD IS? YEAH. THAT, THAT, THAT'S EFFECTIVELY CORRECT. UM, NOW IDEALLY YOU COULD DO IT ON A PER LOAD BASIS, BUT AF AFTER FEEDBACK FROM ERCOT, THAT WOULD JUST TAKE TOO LONG. SO HAVING SOME LINE IN THE SAND DATE WHERE YOU STUDY PROJECTS WITH LOAD REQUESTS, LOAD REQUEST DATES BEFORE THAT DATE, ALLOCATE MEGAWATTS UP TO, UM, THE REQUESTED RAMP SCHEDULE, AND THEN YOU RUN A SECOND, UH, STUDY FOR PROJECTS THAT SUBMITTED REQUESTS AFTER THAT DATE, UH, SEEM TO MAKE THE MOST SENSE. OKAY. UH, I DON'T KNOW IF, UH, JUST TO, IF INSTEAD OF 33, 33 33, WE, IF WE DO 50, 25, 25, DOES THAT SOLVE THE ISSUE? UH, THAT'S ONLY CONCERN, BUT THANKS. ALL RIGHT. THANK YOU. AND KEVIN HANSON? YEAH, KEVIN HANSON AND JE MATT, I KNOW I BROUGHT THIS UP BEFORE, BUT SORT OF TIED BACK TO THIS IN TERMS OF RIGHT NOW WE'RE USING PIGGER 1 27 TO SOLVE THE LACK OF GENERATION QUESTION. AND IF WE HIT REALITY DOWN THE ROAD 2028 AND THERE'S INSUFFICIENT GENERATION TO SERVE ALL THE LOAD, DO WE, ARE WE PLANNING ON THEN ADDING IN LANGUAGE TO IDENTIFY THE CURTAILMENT OF LARGE LOADS IN FUTURE TO DEAL WITH THAT ISSUE BEYOND SENATE BILL SIX? YEAH, DO, SO WE GOT THE, SO RIGHT NOW WE'RE GONNA SAY WE'RE JUST GONNA, IF WE'RE SHORT, IF WE ADD, [01:10:01] LET'S SAY 30 GIGAWATTS, WE ARE SHORT 10 GIGAWATTS, ARE WE JUST GONNA KILL, SWITCH EVERYBODY SIMULTANEOUSLY? IS THAT THE PLAN RIGHT NOW? I DUNNO, JEFF, I'LL SAY YEAH, WE, WE, WE HAVE OPERATING PROCEDURES. WE, WE ARE DEVELOPING NEW OP OPERATING PROCEDURES BASED ON SENATE BILL SIX AS AS WELL AS LANGUAGE. AND SO WE WON'T YEAH. USE THAT. I'M JUST SAYING THERE'S GONNA BE A PARATA, PROTA ATU. YEAH. ALL BATCH ZERO. SO IS THE BATCH ZERO YOU'RE AFRAID OF WHAT'S BEING APPROVED IS GONNA BE TOO MUCH OR WHAT'S YEAH, THAT'S MY CONCERN. 'CAUSE RIGHT NOW WE'RE USING P 1 27 2, WE HAVE INFINITE GENERATION TO SOLVE THE CASES. OKAY. I GUESS WE'VE SEEN MORE OF THE TRANSMISSION SIDE OF THAT THAN, UH, CAPACITY LIMITATIONS RIGHT NOW. SO I THINK THAT'S, AS WE STEPPED INTO THIS, I THINK WE PURPOSELY HAVE SIDESTEPPED OKAY. ADEQUACY FOR NOW. OKAY, THANKS. NOT THAT IT'S NOT COMING, BUT NOT TODAY. OKAY. ALRIGHT. AT THIS POINT, Q'S CLEAR. SO WE'RE GONNA GO AHEAD AND MARTHA, YOU HAD A PRESENTATION FOR ENCORE. WOULD YOU LIKE ME TO OPEN THAT? YEAH, THAT'D BE GREAT. THANK YOU. MATT. UM, MARTHA HENSON WITH ENCORE, IT'S MORE OF JUST A ONE PAGE DISTILLATION OF OUR COMMENTS FOR ANYBODY THAT, YOU KNOW, HASN'T HAD TIME TO READ ALL THE WAY THROUGH 'EM. UM, THE, THE WAY WE STRUCTURED OUR COMMENTS IS THAT THEY'RE MORE OR LESS IN ORDER SEQUENTIALLY WITH THE SECTIONS OF THE PLANNING GUIDE THAT WE'RE TRYING TO ADDRESS IN OUR COMMENTS. HOWEVER, THAT DOESN'T REALLY GIVE ERCOT OR ANYBODY ELSE A GOOD SENSE OF WHAT THE BIGGEST PRIORITIES ARE TO ENCORE. SO I KIND OF WANTED TO START A LITTLE BIT OUT OF, A LITTLE BIT OUT OF ORDER ON THIS LIST AND TALK ABOUT TWO OF THEM FIRST. UM, SO NUMBER SEVEN ON THIS LIST IS ADDRESSING THE APPROACH IN THE PLANNING GUIDE REVISION WHERE THE REMAINING LOAD THAT ISN'T SERVED BY TRANSMISSION IMPROVEMENTS IN YEARS ONE THROUGH FIVE OF THE BATCH STUDY IS PUT INTO YEAR SIX. UM, WE THINK THAT THE STUDY IS DESERVING OF EXTRA TIME TO ENABLE THE FULL TRANSMISSION PLAN TO BE IDENTIFIED WITHIN THE BATCH STUDY. UM, THERE WAS A, A QUESTION ON THE SURVEY, THE LAST SURVEY WE TOOK THAT WAS LIKE A TRADE OFF BETWEEN THE SIX MONTH BATCH STUDY THAT DOES WHAT THE PIGGER SAYS, VERSUS A FULL YEAR THAT IDENTIFIES THE FULL T PLAN. BUT WE DON'T THINK IT'S NECESSARILY A DOUBLING OF THE AMOUNT OF TIME TO IDENTIFY THE FULL T PLAN. UM, WE THINK IT MIGHT BE WEEKS, COUPLE MONTHS, UH, TO DO THAT IF OUR COTS OPEN TO DOING THAT IN COLLABORATION WITH TS P. SO THAT'S PROBABLY THE BIGGEST THING WE'D LIKE TO SEE CHANGED IN THE NEXT ITERATION. AND THEN THE OTHER ONE IS GONNA BE NUMBER FOUR ON THIS LIST WHERE THERE, THERE WERE SOME IMPROVEMENTS MADE IN THE ERCOT COMMENTS LAST WEEK WHERE RPG PROJECTS SUBMITTED BY DECEMBER 15TH OF LAST YEAR AND ACCEPTED OR ENDORSED BY MARCH 4TH, THE DATE OF 1 45 SUBMITTAL WOULD BE CONSIDERED TO HAVE VALID STUDIES WITHOUT ADDITIONAL REVIEW. UM, THERE'S NO OBVIOUS BASIS TO US THAT THO THAT SHOULD BE TIED TO THE DATE THE PLANNING GUIDE REVISION WAS FILED. SO WE WOULD SUGGEST, UH, YOU KNOW, MOVING THAT DATE TO OF RPG ACCEPTANCE OR ENDORSEMENT TO, UH, JULY 10TH, 2026. UM, PROJECTS THAT ARE ENDORSED BY JULY 10TH WILL LOOK EXACTLY THE SAME AS THOSE ENDORSED BY MARCH 4TH OF THIS YEAR. AND, UM, ENCORE ACTUALLY HAS HAD, UH, ELITE MULTIPLE RPG SUBMITTALS THAT MEET THIS QUALIFICATION. ONE ACTUALLY WILL BE ON THE TAC AGENDA TOMORROW. UH, THE SOUTH DFW PROJECT, IT WAS SUBMITTED OVER A YEAR AGO. IT'S BEEN IN THE EIR, UH, FOR 13, 14 MONTHS NOW. AND SO THOSE ARE ADDRESSING OLDER LOAD REQUESTS THAT WE THINK SHOULD BE ALLOWED TO MOVE TO COMPLETION SO THAT THAT STUDY CAN BE VALID. AND THOSE LOAD REQUESTS WOULD BE BASE LOAD AND BATCH ZERO. I'M GONNA GO BACK TO THE TOP AND HIT THE OTHER ONES MORE SEQUENTIALLY HERE. UM, YOU KNOW, A NUMBER OF PEOPLE HAVE NOTED THE, THE TIE IN OF THE BATCH ZERO ENTRY REQUIREMENTS TO 5 8 4 8 1. THAT COULD MEAN THAT THE, THE BATCH ZERO LOADS HAVE TO MEET A HIGHER HURDLE, UH, THAN WHAT THE COMMISSION RULE ULTIMATELY REQUIRES LONG TERM. UH, ONE WAY TO ADDRESS THAT IS TO CREATE A TRUE UP MECHANISM SOMETIME LATER AFTER THE RULE IS FINALIZED TO WHERE, YOU KNOW, NON NON-REFUNDABLE SECURITY THAT LATER BECOMES REFUNDABLE COULD BE MANAGED ACCORDING TO THE FINAL RULE PROVISIONS OR, YOU KNOW, SECURITY THAT RIGHT NOW IS SET AT A CERTAIN DOLLAR PER MEGAWATT AMOUNT THAT CHANGES TO SOMETHING LOWER LATER, COULD BE TRUED UP THAT THAT'S PROBABLY NOT SOMETHING WE WOULD EXPECT THE PIGGER TO ADDRESS. AND WE RECOGNIZE THERE'S STILL THE, THE OPEN RULE MAKING WHERE, UM, YOU KNOW, SOMETHING LIKE THAT IS PROBABLY [01:15:01] THE RIGHT PLACE TO ADDRESS IN COMMENTS. UM, WE SPENT SOME TIME, THIS IS NUMBER TWO, UH, LOOKING AT THE TSP AND DSP ROLES IN THE PIGGER AND TRIED TO CLARIFY WHERE WE COULD, WHICH OF THOSE TWO ENTITIES SHOULD BE RESPONSIBLE FOR EACH OF THE ATTESTATIONS. AND ALSO IT WOULD BE EXTREMELY HELPFUL IF ERCOT WOULD CREATE A STANDARD ATTESTATION FORM THAT WE COULD USE. I THINK THE MODEL THAT WAS USED FOR THE COMPLIANCE PLAN IS SOMETHING WE'RE OPEN TO. UM, POTENTIALLY IT WOULD BE, YOU KNOW, YOU, YOU CHECK THE BOX AT THE TOP OF THE FORM, WHETHER YOU'RE BOTH ENTITIES OR WHETHER YOU'RE ONE OR THE OTHER, THE DSP OR THE TSP, AND THEN YOU CHECK THE RELEVANT BOXES BELOW THAT ACCORDING TO THE WAY THE, THE, THE ATTESTATION ROLLS ARE ASSIGNED IN THE PLANNING GUIDE REVISION. AND THEN, YOU KNOW, IN THE CASE WHERE THOSE TWO ARE DIFFERENT, THERE'S JUST A SMALL TRUE UP THAT ERCO ERCOT WOULD HAVE TO DO SOMETIME LATER IN THE PROCESS TO TIE EACH FORM TO THE SAME LOAD REQUEST. UM, WE ALSO REMOVED THE ILE HAVING TO PROVIDE EVIDENCE TO THE TDSP OF, UH, SITE PREP AND CONSTRUCTION ACTIVITIES. WE WEREN'T REALLY SURE WHAT THAT SHOULD LOOK LIKE AND DON'T NECESSARILY WANNA BE IN THE POSITION OF HAVING TO JUDGE WHAT EVIDENCE IS SUFFICIENT UNDER THAT LANGUAGE. SO WE DID REMOVE THAT IN OUR COMMENTS. UH, NUMBER THREE HERE, PGA ONE 15 GENERALLY ASSIGNED A LEAD TSP ROLE, UH, IN THE ROLES THAT RELATE TO THE VARIOUS, UH, YOU KNOW, MODELS AND STUDY PROVISIONS AND THINGS LIKE THAT. AND IT LOOKED LIKE 1 45 IS MAKING THAT A DSP OR TSP. IT'S HELPFUL TO HAVE THE CLARITY, I THINK THAT WE HAD IN PGA ONE 15 WHERE THE LEAD TSP IS TYPICALLY PERFORMING, YOU KNOW, THEY'RE COLLECTING THE MODELS FROM THE CUSTOMER, THEY'RE PERFORMING, UH, SHORT CIRCUIT STUDIES, UM, AND OTHER SYSTEM STUDIES AND TRANSMITTING INFORMATION TO ERCOT ON BEHALF OF THE CUSTOMER. SO WE, WE TRIED TO RESTORE THE PICKER ONE 15 TSP ROLES WHERE WE COULD, ALTHOUGH THERE'S SOME AREAS WHERE AFTER THINKING THROUGH IT MORE, IT PROBABLY DOES MAKE SENSE FOR IT TO BE A DSP AND A TSP, PARTICULARLY AFTER THE CUSTOMER IS ENERGIZED AND MAYBE IT NEEDS TO PROVIDE UPDATED INFORMATION. IT'S GONNA HAVE THE RELATIONSHIP WITH THE CERTIFICATED UTILITY PRIMARILY AT THAT POINT, WHICH HAS METERED AND IS SERVING THE CUSTOMER. SO IN, IN CASES LIKE THAT, IT SEEMED FINE TO HAVE BOTH. UM, WE TALKED ABOUT NUMBER FOUR ALREADY. NUMBER FIVE IS, UH, A QUESTION THAT WE HAD ABOUT THE DYNAMIC DATA REQUIREMENTS IN SECTION 9 2 2. UH, IT WASN'T CLEAR TO US WHETHER THE DYNAMIC DATA THAT'S DUE BY JULY 10TH IS REQUIRED FROM LOADS THAT ARE GOING TO BE ASSESSED AS WELL AS BASE LOADS. AND IF IT'S FROM BASE LOADS, YOU KNOW, WHAT, WHAT ARE WE SUPPOSED TO BE LOOKING FOR THERE? UM, AND NUMBER SIX, THERE WERE SOME SORT OF A CURSORY, A MENTION IN THE STUDY METHODOLOGY SECTION THAT TALKED ABOUT THE TSPS BEING CONSULTED AND WE'D APPRECIATE MAYBE A LITTLE MORE MEAT ON THE BONE THERE IN THOSE SECTIONS. SO WE HAVE INTRODUCED, I THINK, A FIVE BUSINESS DAY REVIEW OF THE STUDY SCOPE AT THE OUTSET, AND THEN ALSO TRIED TO INTRODUCE SOME ADDITIONAL TIMELINES WHERE IT STILL ALLOWS FOR THE, LIKE INFORMAL COLLABORATION AND DISCUSSION OF PROJECT ALTERNATIVES BETWEEN ERCOT AND TSPS. BUT ALSO ONCE A LIST OF TRANSMISSION FACILITY IMPROVEMENTS IS IDENTIFIED, WE'RE RECOMMENDING A 15 BUSINESS DAY COMMENT OPPORTUNITY FROM TSPS THAT WOULD PROVIDE THE FEASIBILITY FOR US TO ACTUALLY CONSTRUCT THOSE PROJECTS BACK TO ERCOT. SO THERE'S A LITTLE BIT MORE OF A PAPER TRAIL THERE. UH, WE TALKED ABOUT NUMBER SEVEN ALREADY EXTENDING THE BATCH STUDY INTO A SIX YEAR TO IDENTIFY THE FULL T PLAN. NUMBER EIGHT IS THE, THE 30 DAY CURRENTLY 30 DAY COMMITMENT WINDOW FOR LOADS TO EXECUTE INTERCONNECTION AGREEMENTS. THAT, THAT'S GONNA BE DIFFICULT WITHOUT A STANDARD INTERCONNECTION AGREEMENT FORM, WHICH WE DON'T HAVE RIGHT NOW. UM, SO UNTIL A FORM LIKE THAT IS DEVELOPED, WE WOULD SUGGEST THAT THAT BE 60 DAYS INSTEAD OF 30. AND THEN, UM, NUMBER NINE, THE SHORT CIRCUIT STUDY TIMELINE. IT'S, IT'S SUPPOSED TO RUN SOMEWHAT IN PARALLEL WITH THE COMMITMENT PERIOD AND THE REFINEMENT STUDY. UH, WE, WE CAN DO IT IN THAT AMOUNT OF TIME, BUT WE HAVE TO HAVE A USABLE CASE TO START WITH. AND WE'RE CONCERNED THAT THE CASE THAT THE, THE BATCH PLAN WOULD DELIVER AFTER THE INITIAL, UH, SIX MONTH STUDY RUN IS NOT GONNA BE USABLE FOR SHORT CIRCUIT ANALYSIS. SO LIKE TO HAVE SOME MORE DISCUSSIONS WITH ERCOT ABOUT WHETHER THEY'RE ABLE TO PREPARE A CASE FOR US THAT WE COULD RUN SHORT CIRCUIT ON. AND WE ALSO [01:20:01] MADE SOME OTHER, UM, RECOMMENDED CHANGES TO THAT SECTION. AND THEN THE LAST THING I WOULD SAY IS WE'RE LIKING THE WAY THE RPG REVIEW PROCESS TURNED OUT IN THE PIGGER. UM, THE REFINEMENT STUDY SEEMS LIKE TIME WELL SPENT SO THAT THE END PRODUCT OF THE REFINEMENT STUDY CAN BE DELIVERED STRAIGHT INTO RPG. AND IT'S, UH, YOU KNOW, IN A, A COMMENT PERIOD WHERE THE FINAL REPORT MIGHT BE ADJUSTED BASED ON COMMENTS RECEIVED, BUT IT'S NOT GONNA RECEIVE AN ADDITIONAL ERCOT INDEPENDENT REVIEW. SO WE, WE THINK THOSE ARE GOOD WAYS TO, UM, STRUCTURE THAT. AND, UM, IF YOU WANT MORE DETAILS ON ANY OF THESE, THERE'S A MORE COMPREHENSIVE SURVEY IN THE CON SORRY SUMMARY IN THE COMMENTS THAT WE SUBMITTED LAST WEEK. VERY GOOD. THAT'S ALL I HAVE. UM, YEAH, COULD, IF I MAY, AND MARTHA, I APPRECIATE THE WAY YOU'VE SUMMARIZED THE, THE COMMENTS HERE. UM, IT JUST ONE QUICK QUESTION. SO ON THE, THE COMMENT ON THE TRUE UP FOR WITH 58 41, UM, CAN YOU HELP ME UNDERSTAND THAT BETTER? SO, SO AS IT IS WRITTEN JULY 10TH, A UH, ILE WOULD HAVE TO MEET THE WHAT, WHATEVER THE REQUIREMENTS ARE, UH, THAT, THAT ARE IN THE PICKER, WHICH AS MARKDALE NOTED, COULD DIVERGE AT AT SOME POINT. UM, SO MAYBE AS AN EXAMPLE, IF THE FINANCIAL COMMITMENT REQUIREMENT IS $50,000 PER MEGAWATT IN THE PIGER, YOU KNOW, JUST MAKING SOMETHING UP, MAYBE IT'S 40,000 IN THE FINAL 58 41, UH, BUT THAT WE MAY NOT GET THAT TILL SEPTEMBER, BUT AT THAT POINT WE WILL HAVE ALREADY STARTED THE STUDY. AND SO WE WILL ALREADY KNOW WHICH LOADS ARE IN. SO, SO MAYBE A LOAD COULD HAVE MET THE 40,000, BUT IT THAT, YOU KNOW, THEY DIDN'T MEET THE 50,000. HOW WOULD THAT WORK IN THE STUDY? THAT, I DON'T THINK THAT WE WOULD WANT TO GO BACK AND NEW STUDY. NO, WE'RE, WE'RE NOT SU SUGGESTING ANYTHING CHANGE IN THE STUDY OR IN THE ERCOT PROCESS AT ALL. YOU KNOW, THE TSPS ARE RESPONSIBLE FOR COLLECTING SECURITY UNDER THE RULE, WHATEVER THOSE PROVISIONS LOOK LIKE AT THE END. SO IN YOUR EXAMPLE, IT WOULD JUST BE A MATTER OF IF, IF THEY, YOU KNOW, PAID 50 K PER MEGAWATT TO BE IN BATCH ZERO. AND THE FINAL RULE LATER SAYS THAT, SAY IN THE INTERCONNECTION AGREEMENT PHASE, THE SECURITY IS 20 5K PER MEGAWATT, THAT WE WOULD TRUE UP THE BATCH ZERO CUSTOMERS FINANCIALLY. IT'S NOT ABOUT CHANGING ANYTHING IN THIS STUDY PROCESS. GOT IT. OKAY. AND, YOU KNOW, AGAIN, WE'RE NOT ASKING OR CUT TO REALLY DO ANYTHING WITH THAT. IT'S JUST A CONCEPT WE'RE LAYING OUT THAT THERE'S A, A POTENTIALLY A HIGHER HURDLE FOR BATCH ZERO THAN, YOU KNOW, FUTURE REQUIREMENTS FOR, FOR ADDITIONAL BATCHES. SO I THINK IF, IF THAT'S SOMETHING WE FEEL STRONGLY ABOUT, I SUSPECT WE'LL FILE IT IN COMMENTS TO THE RULE. OKAY, THANK YOU. YEAH. ALRIGHT, SO WE HAVE FIVE PEOPLE IN THE QUEUE, SO LET'S START WITH CLAYTON. YEAH. SO ON, UM, A GO, GO IN ORDER. UM, I, I'M NOT SURE, UH, LIKE JEFF, I'M NOT REAL SURE HOW THAT TRUE UP WORKS, BECAUSE I THINK YOU HAD MENTIONED THE, THE, THE 80% NON-REFUNDABLE PART OF IT. NOW THAT'S IN THE RULE THAT THAT ERCOT WOULD BE ADOPTING IF THAT BECOMES REFUNDABLE. I'M NOT SURE HOW THAT'S TRUED UP BECAUSE YOU'VE ALREADY KIND OF DONE THE DAMAGE, THE REAL RISK IS IN GOING INTO IT, NOT COMING OUT OF IT WITH, WITH A LITTLE BIT MORE MONEY THAN YOU WERE NOT COUNTING ON. UM, SO WE'RE, WE'RE GONNA ALSO FILE COMMENTS ON THE RULE, UM, BECAUSE IT'S, UH, A FAIRLY EGREGIOUS PROJECT PROCESS IS WHAT IS BEING RECOMMENDED ON TWO. UM, I WANNA ALSO SUPPORT REMOVAL OF THE ILLE EVIDENCE OF CONSTRUCTION. THE WAY THE, UH, THE PIGGER IS WRITTEN. UM, YOU'RE, YOU'RE BASING IT OFF OF WHEN, UH, POWER WAS REQUESTED. A LOT OF TIMES THE TSP HAS ALREADY NOTIFIED THE LOAD THAT THAT IS NOT GOING TO BE MET. SO THERE'S NO NEED TO CONSTRUCT WHENEVER YOU KNOW, THAT YOU'RE IN SERVICE DATE IS MAYBE FOUR YEARS OFF. BUT THERE'S NO ALLOWANCE FOR THAT IN THE WAY THAT THIS IS STRUCTURED TODAY. SO, SO THAT I WOULD AGREE THAT, YOU KNOW, THERE'S, UM, THERE NEEDS TO BE EVIDENCE WHERE IT MAKES SENSE, UM, WHERE IT DOESN'T MAKE SENSE. I DON'T KNOW THAT THERE NEEDS TO BE ANY EVIDENCE, UH, BECAUSE, UH, YOU, YOU CERTAINLY DON'T WANT TO JUST GO OUT THERE AND, AND RUN A BACKHOE JUST TO, TO, YOU KNOW, SHOW YOU'RE DOING SOMETHING. UM, AND, AND I, I, I SPEAK TO THAT SPECIFICALLY IN ONE PROJECT THAT WE HAVE WHERE WE REQUESTED A, A, UH, 26 IN SERVICE DATE, WE FILED IT IN 23, REQUESTED A 26 IN SERVICE DATE, AND HAVE BEEN INFORMED THAT IT'S NOT GONNA BE IN SERVICE UNTIL 28. SO WE HAVE NOT YET STARTED CONSTRUCTION OUT THERE. UM, SO ON, UH, THERE WAS ONE MORE, UM, ON THE, ON THE, UH, THE SIXTH YEAR. UM, AND THEN KIND OF IN THIS WHOLE STUDY PROCESS, THE BACK AND FORTH BETWEEN THE TSPS, UM, IS, ARE WE TAKING INTO ACCOUNT OUTAGES, [01:25:01] TIMELINES, UH, CONSTRUCTION TIMELINES AND THINGS LIKE THAT? BECAUSE I, I DON'T KNOW, YOU KNOW, IF WE, IF WE'RE APPROVING, YOU KNOW, 200 MILES OF 3 45 KV UPGRADES, WE CAN'T DO THAT IN ONE YEAR, I DON'T THINK. UM, I'D BE REALLY SHOCKED IF WE WERE ABLE TO DO SOMETHING LIKE THAT. BUT IT LOOKS LIKE WHENEVER THIS GOES OUT TO THE VARIOUS TSPS, I DON'T THINK THAT THERE'S ANY COORDINATION BEING GIVEN TO HOW THAT'S GONNA WORK IN REAL LIFE. UM, SO IS THERE, AND, AND THERE WASN'T VERY MUCH STRUCTURE IN THE PIGGER FOR THAT EITHER AS FAR AS TRYING TO DETERMINE, UH, NOT ONLY, YOU KNOW, CONSTRUCTABILITY, BUT ALSO THE TIMELINES THAT THAT WOULD BE DONE ON. UM, SO WHILE WE'RE THINKING THAT WE CAN DO THINGS MAYBE A LITTLE FASTER THAN WE CAN DO THEM, UM, I THINK THAT WE NEED TO HAVE A, A PRETTY GOOD, UH, STRUCTURE AROUND HOW THAT FEEDBACK WORKS BETWEEN ERCOT AND THE VARIOUS TSPS. NOT, YOU KNOW, IT'S NOT JUST ONE BACK AND FORTH, THIS IS TO, YOU KNOW, 10 OR MORE TSPS THAT, THAT THEY'LL BE PROVIDING FEEDBACK AND NEEDING TO GET FEEDBACK FROM. AND IT ALL HAS TO COORDINATE. SO, UM, I THINK THAT WE DO NEED TO FLESH THAT SIDE OF IT OUT A LOT MORE AND IN THE SIXTH YEAR, YOU KNOW, TO, TO PUT INFINITY, UH, MEGAWATTS OUT THERE, I'VE MADE THESE COMMENTS BEFORE AS WELL THAT IT DOESN'T MAKE ANY SENSE UNLESS WE HAVE SOME SORT OF VALID PLAN TO, TO SAY THAT WE CAN ACTUALLY SERVE ALL THAT. THANKS ALL. THANK CLAYTON, BILL BARNES. THANKS. BILL BARNES, NRG. MATT, YOU ASKED FOR SOME ME TOOS. UM, SO SUPPORT NUMBER SEVEN. CLAYTON JUST MENTIONED IT AS WELL. WE DON'T, I THINK THAT'S A PROBLEM TO HAVE, ASSUME UNLIMITED TRANSMISSION CAPACITY IN YEAR SIX. SO EXTENDING THE BATCH STUDY HORIZON MAKES A LOT OF SENSE TO US. AND THEN NUMBER EIGHT AS WELL, WHICH WE'LL BE FILING COMMENTS, UH, IN 58, 4 8 1 AS WELL. WE THINK A 60 DAY COMMITMENT WINDOW IS MORE REALISTIC THAN THIRTIES, 30 DAYS. THANKS. ALRIGHT, NEXT IS VJ VIJAY, IF YOU'RE TALKING, WE DON'T HEAR YOU YET. ALL RIGHT. WE'LL COME BACK TO YOU IN A SECOND. ANDRES, HI, GOOD MORNING. ANDRES WITH CYPRESS CREEK. UM, DOES ENCORE ANTICIPATE THE REFINEMENT STUDY TO IDENTIFY NEW UPGRADES CAUSED BY LARGE LOADS DROPPING OUT? SO LIKE IF A NEW OVERLOAD SHOWS UP DURING THE REFINEMENT STUDY AFTER THE 30 DAY COMMITMENT OR 60 DAY COMMITMENT THAT WAS NOT IN THE ORIGINAL BATCH? I GUESS THE QUESTION IS, WILL ENCORE PROPOSE A NEW PROJECT, UM, TO SOLVE THIS OVERLOAD? LIZ IS COMING TO THE TABLE. GOOD MORNING, LIZ JONES, ENCORE. UM, THIS HASN'T BEEN FULLY WORKED OUT, BUT IT WOULD BE OUR HOPE THAT AS WE CONTINUE TO REFINE THIS PROCESS, THERE IS AN OPPORTUNITY FOR BATCH ZERO ONLY TO GO AHEAD AND MOVE FORWARD WITH ALL OF THE PROPOSED UPGRADES, IRRESPECTIVE OF WHETHER ALL OF THE END USE CUSTOMERS EXECUTE INTERCONNECTION AGREEMENTS. THE REASON WE THINK IT IS VALUABLE TO DO SO IS WE THINK THAT THAT CAPACITY WILL IMMEDIATELY BE TURNED AROUND AND USED IN BATCH ONE. UM, IF THAT PROPOSAL IS NOT ACCEPTED, OUR SECONDARY PROPOSAL WOULD BE THAT WE DO NOT HAVE TO RERUN ALL THE STUDIES BECAUSE SOME NUMBER OF CUSTOMERS HAVE NOT CARRIED THROUGH THE INTERCONNECTION AGREEMENT STEP. BECAUSE IF THEY, IF WE DO HAVE TO REFINE THE STUDIES TO ACCOUNT FOR THOSE CUSTOMERS THAT HAVE DROPPED OUT, I AM VERY CONCERNED THAT WE WILL BE IN A DO LOOP FROM WHICH WE CANNOT SUCCESSFULLY ESCAPE. OKAY. I, I GUESS A FOLLOW UP QUESTION ON THAT, UM, I MEAN I I I FULLY SUPPORT LIKE, SO BASICALLY YOU'RE SAYING SCENARIO ONE IS WE MOVE FORWARD WITH ALL THE UPGRADES REGARDLESS OF PEOPLE DROP OR NOT DROP, RIGHT? THAT WOULD BE ON COURSE PROPOSAL, YES. AND WE WOULD NOT, WE'RE NOT SUGGESTING THAT THAT CARRIES FORWARD THROUGH ALL BATCH STUDIES. WE ARE ASKING THAT IT BE USED FOR THE FIRST BATCH STUDY. OKAY. SO FOLLOW UP QUESTION ON THAT. IF THERE'S A NEW OVERLOAD THAT SHOWS UP IN THE REFINEMENT STUDY THAT WAS NOT CAPTURED ON THE ORIGINAL BATCH, WHAT IS ENCORE PLANNING ON DOING THIS? BECAUSE THE MOMENT ONE LOAD DROPS IS GONNA IMPACT THE, THE ALLOCATION FOR THE ALREADY APPROVED LOAD AND IT'S GONNA IMPACT THE T PLAN THAT WAS ORIGINALLY DISCUSSED. SO I UNDERSTAND THAT IS A POSSIBILITY. I DO NOT THINK [01:30:01] THAT WE NEED TO FIX THAT PROBLEM INSIDE BATCH. I THINK WE NEED TO FIX THAT PROBLEM SUBSEQUENT TO BATCH WITH AN ADDITIONAL PROJECT SUBMITTAL. DEPENDING ON THE SIZE OF THE PROJECT, IT MAY HAVE TO GO THROUGH CONVENTIONAL RPG OR OTHERWISE. BUT WHAT WE DON'T WANT TO DO AGAIN, IS GO INTO ITERATIVE REFINEMENT STUDIES BECAUSE THE CUSTOMER POPULATION HAS CHANGED. I, I THINK WE HAVE TO, BECAUSE THE, THE ALREADY APPROVED LOAD WILL NO LONGER BE VALID LIKE THE LCP FOR THAT LOAD. IF, IF THERE'S A NEW PROJECT THAT NEEDS TO HAPPEN, IT'S GONNA TAKE YEARS. SO THE LCP THAT WAS ORIGINALLY GIVEN TO THAT LOAD WHEN IT SIGNED THE IA, IT WILL NO LONGER BE VALID. I DON'T THINK THE BATCH PROCESS IS SUSTAINABLE IF WE KEEP REITERATING DURING THE REFINEMENT PROCESS TO REFLECT THE CHANGING CUSTOMER POPULATION. I THINK IT'S THAT FUNDAMENTAL. NOW I AGREE WITH THAT. DO WE NEED TO BACK CLEANUP? ABSOLUTELY. IS THERE A POSSIBILITY THAT THAT WILL NEED TO BE UNDERTAKEN IN SHORT ORDER IN AN RPG PROCESS? ABSOLUTELY. BUT WHAT WE CAN'T DO IS KEEP TINKERING OR WE, OR, OR WHY ARE WE DOING BATCH TO BEGIN WITH? 'CAUSE WE'VE SPENT THE LAST TWO YEARS TINKERING. YEAH, I AGREE WITH THAT. I I'M JUST CONCERNED AT SOME POINT IT'S GONNA SHOW UP EITHER IN OPERATIONS OR QSA ON RPG AT SOME POINT, GIVEN THE FACT THAT PEOPLE ARE DROPPING, IMPACTING, ALREADY APPROVAL LOADS, AT SOME POINT IT'S GONNA GET UP WITH OPERATIONS OR LIKE RPG OR SOME OTHER PROCESS. WHAT DO YOU WANT TO DO INSTEAD? I PROPOSE THAT THERE'S ANOTHER, LIKE THE, THE COMMITMENT HAPPENS AFTER THE, THE REFINEMENT PERIOD. SO ADDING ANOTHER, I GUESS NOT DECISION POINT, BUT LIKE RIGHT NOW, PEOPLE ARE SIGNING IAS BASED ON JUST ONE RUN OF THE STUDY. AND THE MOMENT PEOPLE MAKE FINANCIAL COMMITMENTS AND POST A NON-REFUNDABLE FEE AND THEY THINK THEY HAVE A SECURED SCHEDULE, THEY DON'T BECAUSE THE MOMENT SOMEBODY ELSE DROPS, EVEN THOUGH ONCOR EARTH CODE WILL PROPOSE A PROJECT VIA RPG OR SOMETHING LATER ON, IT WILL IMPACT THE COMMITMENT THAT THAT LOAD DID BASED ON THE INFORMATION IT KNEW AT, AT, AT THAT INITIAL POINT. SO I JUST RECOMMEND MOVING THE INTERCONNECTION AGREEMENT AND THE DECISION AFTER THEIR CERTAINTY ON, ON, ON, ON THE SCHEDULE BECAUSE THE MOMENT WE UD SOMETHING, THE ALLOCATIONS COULD CHANGE SORE. JUST TO CLARIFY, I DON'T THINK THE ALLOCATIONS WOULD CHANGE AT, AT THAT POINT. AND, AND ALSO I THINK THEORETICALLY YOU, YOU SHOULD NOT INTRODUCE ANY NEW OVERLOADS IF LOADS DROP OUT. I I THINK THAT IS THEORETICAL, THEORETICALLY NOT POSSIBLE. I, I, I THINK I DISAGREE WITH THAT AND I DON'T WANNA TAKE MORE TIME. I, I'VE ALREADY SENT A, AN EMAIL, UH, WITH, WITH MATH, UH, SHOWING A, A CASE STUDY I DID WITH SSWG THAT PROVES THAT, UM, THAT IF IF YOU TAKE ONE LOAD OUT OF THE STUDY, IT CAN CAUSE AN ANOTHER OVERLOAD. BUT WE CAN MOVE ON. WE CAN SAY THAT NOT SEPARATELY. 'CAUSE I'VE ALREADY RAISED THAT ISSUE WITH, WITH MATT. YEAH. AND, AND I'LL TAKE OWNERSHIP OF THAT ISSUE FOR THE NEXT MEETING. THANKS, ANDRES. THANK YOU. YOU BET. ALL RIGHT. UH, SCREEN JUST MOVED. UH, VIJ, DID YOU REJOIN US? YES. CAN YOU, CAN YOU, UH, THERE YOU'RE SPEAK UP THOUGH PLEASE. YEAH. HEY, UH, THANK YOU. UH, JUST WANTED TO VOICE MY STRONG SUPPORT TO NUMBER FOUR ON THIS, UH, SLIDE HERE ON COURT PROPOSAL, UH, TO SHIFT THE CUTOFF FOR RRP G ACCEPTANCE ENDORSEMENT TO JULY 10TH. UM, GIVEN THE, SOME OF THESE RPGS HAVE BEEN IN, UH, , UH, INDEPENDENT REVIEW FOR MORE THAN A YEAR. ALRIGHT, THANKS VIJ. ALL RIGHT. CHRIS. MATT, CHRIS MONTOSS, GOOGLE. UM, THE SECOND BULLET IN ONE HIGHLIGHTS MY CONCERN ABOUT THE ROLE OF INTERMEDIATE AGREEMENTS FOR BASELOAD VERSUS NOT BASELOAD AND BATCH ZERO, AND JUST THE LACK OF CERTAINTY IN THE CONTRACTING PROCESS FOR WHAT ERCOT IS OR IS NOT GOING TO TAKE IN THAT SCENARIO. AS WE GO THROUGH THIS, THERE ARE MANY, AND, AND FOR THE RECORD, I AM TRYING NOT TO BE CRITICAL OF ANY PARTICULAR TSB OR ERCOT PROCESS HERE. IT'S JUST HOW THINGS ARE, THE DIFFERENCES IN WHICH THE TSPS HAVE CONTRACTED HAVE DIFFERENT QUOTATION MARKS, CONTRACT NAMES. PLUS WE HAVE THE ONGOING 5 8 4 8 1 INTERMEDIATE AGREEMENT DISCUSSION. THAT, [01:35:02] AND I, I DON'T HAVE AN IMMEDIATE SOLUTION OTHER THAN TO SAY TSPS AND ERCOT. Y'ALL NEED TO IDENTIFY WHAT CONTRACTS WORK IN ADVANCE SO THAT WE CAN EXECUTE THESE ON TIME, BECAUSE THERE ARE STEEL IN THE GROUND PROJECTS BASED ON INTERMEDIATE AGREEMENTS RIGHT NOW THAT ARE SUPPOSED TO BE ABLE TO MEET THE BASE LOAD REQUIREMENT. BUT IT IS AS, AS THE CONTRACTING CRITERIA CONTINUES TO SHIFT. THIS IS ONE OF THE LONGEST AND THE MOST IMPORTANT PIECES OF, OF DATA CENTER AND, AND, AND JUST LOW DEVELOPMENT THAT IT'S GOING TO CAU IT IS CAUSING A LOT OF HAVOC. AND I WANNA REITERATE ENCORE'S POSITION TWO ON THE RELATIONSHIP BETWEEN DSP AND TSP ON WHO'S RESPONSIBLE FOR WHAT AND WHAT CONTRACTS ARE GOVERNING IN THAT SCENARIO. I, AGAIN KNOW THERE WAS A, THERE'S REFERENCE TO 5 8 4 8 0 AND ALLOWING THEM TO DECIDE. THIS HAS CREATED A LOT OF CONFUSION IN THE CONTRACTING PROCESS BECAUSE NOW WE ARE EXECUTING MULTIPLE DIFFERENT TYPES OF QUOTATION MARKS, INTERMEDIARY AND INTERMEDIATE AGREEMENTS, BECAUSE WE ARE ALSO TRYING NOT TO SUPERSEDE THE RETAIL AGREEMENT WITH THE DSP. AND SO WE'RE IN A REAL CHALLENGE IN THIS CONTRACTING ADMINISTRATIVE POSITION WHERE A SITE MIGHT MEET EVERY OTHER COMPONENT OF THIS. BUT BECAUSE WE DO NOT KNOW WHAT CONTRACTS ARE GOING TO BE ACCEPTABLE IN THAT SCENARIO, I WORRY WE'RE GOING TO LOSE LOADS WILL GET LOST THAT ARE READY IN AN ADMINISTRATIVE PROCESS HERE. SO I JUST, I'M ASKING TSPS AND ERCOT TO WORK PROACTIVELY AT CLARIFYING THOSE IN ADVANCE AS QUICKLY AS POSSIBLE. THANK YOU. CHRIS. EIL, EIL WITH LANCIA, JUST REAL QUICK, JUST ECHO WHAT CHRIS SAID, AGREE WITH THAT. AND THEN TO GO TO LIZ'S POINT WHERE SHE WAS TALKING ABOUT THE REFINEMENT STUDY, I JUST WANNA ALSO STATE THAT, UM, YOU KNOW, WE ALSO HAVE CONCERNS WITH HOW THINGS ARE DRAFTED. RIGHT NOW. WE'RE WORRIED THAT THE REFINEMENT STUDY MIGHT NOT ACTUALLY LOOK A, LIKE A REFINEMENT STUDY AND LOOKS LIKE BEING RISKED A FULL-BLOWN RE STUDY JUST CONSIDERING THE LACK OF SCREENING POSSIBILITIES PRIOR TO THAT POINT IN TIME OF HAVING TO POST FIRM COMMITMENTS. AND SO TO SOME CONCERNS WE'VE RAISED AT PREVIOUS MEETINGS, UM, YOU KNOW, WE AGREE THAT MAYBE FOR BATCH ZERO IT SHOULD BE CONSIDERED THAT THAT IS WAIVED, BUT WE DO THINK IT'S IMPORTANT FOR THE BATCHES GOING ON. UM, SO JUST WANTED TO ECHO SUPPORT FOR THAT POINT THAT LIZ MADE. UM, AND THEN JUST LASTLY, REAL HERE, JUST TO CIRCLE BACK ON WHAT WE TALKED EARLIER, THE, THE 1215 DATE THAT ENCORE HAS HERE, WE WOULD RECOMMEND THAT THAT'S A APRIL 1ST DATE OF 2026, JUST TO RECONCILE THAT, UM, UH, ISSUE WE RAISED IN OUR COMMENTS EARLIER AND THE RISK THAT PROVIDES TO REPAIRS. THANKS. AND ANDREW SHOPPER, AND THEN WE'RE GONNA STOP. AH, OKAY. YEAH, SO ANDREW, NOT ROTH. GOT IT. YEAH, I JUST WANT TO VOICE SOME ADDITIONAL SUPPORT BEHIND ONE BULLET POINTS, REALLY ONE AND TWO. UM, THIS IS SOMETHING WE BROUGHT UP ALREADY. I, I THINK FROM A COMPLIANCE PERSPECTIVE, IT'S GONNA BE ALMOST IMPOSSIBLE FOR THE LARGE LOAD CUSTOMERS TO MEET A NEW STANDARD THAT'S AS YET NOT ADOPTED. I THINK THAT WHERE THIS NEEDS TO END UP BASED ON ALL THE COMMENTS I'M HEARING IS THAT IF, IF A LOAD CUSTOMER HAS MET 9.5 GOING INTO BATCH ZERO AS A FIRM LOAD, THEN THEY'RE DONE. UM, THAT'S, THAT'S SORT OF THE WAY THAT I THINK WE FEEL ABOUT THIS. I DON'T THINK THAT, ESPECIALLY GIVEN THE COMMENTS THAT WE JUST HEARD ABOUT HOW THIS PROCESS WILL DIVERGE AND 58 4 81 WILL NOT BE THE STANDARD THAT'S ULTIMATELY USED. IT'LL BE WHATEVER THE SNAPSHOT IN TIME IS THAT ERCOT ENDS UP WITH AT SOME FUTURE POINT THAT WE'RE NOT SURE ABOUT. IT'S GONNA BE IMPOSSIBLE TO ADMINISTER THESE CONTRACTS IN A WAY THAT'S TIMELY AND IN A WAY THAT THE BASE LOAD CAN ACTUALLY MEET THESE REQUIREMENTS. SO YOU'RE GONNA WIND UP FOOT FAULTING A BUNCH OF CUSTOMERS ON THIS, UM, YOU KNOW, UNINTENTIONALLY. SO I WOULD JUST ENCOURAGE, MAYBE JUST LOOK AT THE LEGACY REQUIREMENTS UNDER 9.5 AND IF THEY MEET THAT, THEN THEY'RE GOOD. SO, HEY MATT, CAN I JUMP IN? YES, PLEASE. MARK SEAL. THANKS. I KNOW YOU WANT TO GET WRAPPED UP. UM, I'VE HEARD A LOT OF COMMENTS IN, IN THE LAST HALF HOUR ABOUT FINANCIAL COMMITMENTS NON-REFUNDABLE, UM, THE EGREGIOUSNESS OF THE PROPOSED RULE. UM, AND ALL OF THOSE COMMENTS AND CRITIQUES ARE, ARE WELCOME. AND, AND YOU KNOW, WE HEAR THEM LOUD AND CLEAR. I HOPE THAT STAKEHOLDERS WHO CHOOSE TO FILE COMMENTS IN PROJECT NUMBER 5 8 4 8 1 WITH REGARD TO THE NON-REFUNDABLE OF ANY FINANCIAL SECURITY DOESN'T JUST SAY, UM, THIS SUCKS, RIGHT? LIKE I, WE, WE NEED TO HAVE PRODUCTIVE, UM, ALTERNATIVES THAT MEET THE PRINCIPLES THAT THE LEGISLATURE HAS PUT OUT BEFORE US. ONE OF THOSE REALLY IMPORTANT PRINCIPLES IS THAT THE LARGE LOADS Y'ALL SITTING IN THIS ROOM AND ON THE PHONE, YOU HAVE TO BE RESPONSIBLE [01:40:01] FOR THE FINANCIAL COSTS TO BUILD THE STUFF THAT IS NEEDED TO CONNECT YOUR LOADS TO THE SYSTEM. WE'VE PROPOSED ONE WAY. NOW, THERE ARE PROBABLY A HUNDRED THOUSAND OTHER WAYS TO, TO SLICE UP THAT CAT. UM, SO COME WITH GOOD PROPOSALS THAT HELP PROTECT THE REST OF THE CUSTOMERS ON THE SYSTEM, UM, FROM ANY INFRASTRUCTURE IMPROVEMENT COSTS, UM, THAT ARE REQUIRED IN CASE A LOAD SHOULD, SHOULD NOT ACTUALLY END UP SHOWING UP. THE OTHER PIECE HERE, EXCUSE ME FOR ONE SECOND, THE OTHER PIECE HERE IS THAT PART OF THE, THE IDEA BEHIND NON-REFUNDABLE IN THE INTERMEDIATE AGREEMENT PHASE IS TO CREATE A HURDLE TO GET INTO BATCH. WE, WE NEED TO HAVE IT BECAUSE SO MANY OF YOU ALL SITTING IN THIS ROOM AND ON THE PHONE HAVE SAID THERE'S A LOT OF GHOST LOAD IN THERE. THERE'S A LOT OF SPECULATIVE, UM, PROJECT DEVELOPMENT THAT IS CURRENTLY OCCUPYING ERCOT TIME, WHICH IS MAKING AN IMPOSSIBLE TO MOVE FORWARD THOSE PROJECTS THAT ARE MOVING FORWARD THAT REALLY ARE THERE AND ARE READY TO MOVE FORWARD. SO IF THE HURDLE, THE NON-REFUNDABLE THE DOLLAR AMOUNT, THAT'S THE HURDLE. IF THAT'S NOT THE RIGHT HURDLE TO WEED OUT THE SPECULATIVE LOAD, WHAT IS, FILE THAT IN YOUR COMMENTS AS WELL. PLEASE REALLY APPRECIATE IT. THANKS. THANK YOU, MARK SALE. ALRIGHT, THANK YOU MARTHA. ALRIGHT, SO WE ARE GOING TO GO OVER TO, UH, BROTH IS NEXT WITH CRUSO AND BROTH. I CAN OPEN UP YOUR SLIDES. I'M SORRY, YOUR COMMENTS IF NEEDED. I'LL GIVE YOU THE PODIUM EVEN BETTER. ALL RIGHT. OH, YOU KNOW, YOU WANT ME TO COME HERE? IT'S WHATEVER YOU WANT. THERE YOU GO. GOOD MORNING. SO FIRST OF ALL, I WANT TO THANK FOR ALL EFFORT THAT THEY'RE PUTTING TO DEFINE THIS FIGURE 1 45 AND ACCELERATE THE PROCESS. I THINK, AS MATT SAID, WE ARE MAKING REALLY GOOD PROGRESS HERE. UM, AND I APPRECIATE OUR COS UH, COMMENTS WITH RESPECT TO DYNAMIC DATA, UM, AND, YOU KNOW, PROVIDING THE MIS UH, UH, SECURE VERSUS CERTIFIED AND IN A SEPARATION OF MILESTONE DETAILS. I GUESS I HAD ONE BIG COMMENT HERE ABOUT, UH, RETROACTIVE CUTOFF DATE. I THINK IT'S NEVER GOOD FOR A PROJECT, ANY PROJECT THAT IS GOING THROUGH THIS PROCESS TO HAVE A RETROACTIVE CUTOFF DATE. I MEAN, UM, THINK ABOUT THIS. WE ARE WORKING WITH THE TSPS TO SECURE AND FIRM UP THE LOAD ON. NOW THERE IS A, THERE IS A LINE DRAWN AND WE MISSED IT BY ONE DAY, FOR EXAMPLE. SO NOW THAT PUTS THE ENTIRE BILLIONS OF DOLLARS OF PROJECTS IN, IN A, IN A SITUATION WHERE WE DON'T KNOW WHAT'S GOING TO HAPPEN FOR THE NEXT FEW MONTHS. SO WE ARE NOT GOING TO FINANCE IT. WE ARE NOT GOING TO HAVE A TENANT IN THERE. SO MY REQUEST PRIMARILY TO ERCOT WAS, YOU KNOW, FOLLOW THE BIGGER ONE 15 PROCESS. AND THIS IS KIND OF GOING BACK TO MY QUESTION TO AG ESSENTIALLY, WAS IF YOU CAN DRAW ADDITIONAL GUARDRAILS WHEN YOU'RE APPROVING THIS, WHEN YOU ARE ACTUALLY SAYING, OKAY, THIS PROJECT MEETS 9.4 AND 9.5, YOU CAN ALSO DO THAT ADDITIONAL CHECK FOR THAT RPG AND LET US KNOW, UH, IMMEDIATELY AS IN WHEN YOU, UH, SAY THAT THIS IS FIRM RATHER THAN WAITING TILL JULY 10TH, I THINK THAT COMMUNICATION REALLY, REALLY HELPS US TO GO AND MAKE SURE THAT THE LOAD IS NOW FIRM AND MAKE SURE THAT WE HAVE START THE LENDING PROCESS AND, AND GET A TENANT IN THERE RATHER THAN NOT KNOWING THIS FOR THE NEXT THREE TO FOUR MONTHS. SO THAT IS SUPER IMPORTANT FOR US. I THINK YOU, YEAH, THAT'S KIND OF WHAT I WAS ALLUDING TO HERE. I MEAN, AND, AND MAKE SURE THAT WE ARE PROGRESSING IN THE RIGHT DIRECTION. SO IN THAT NOTE, I WANT THE DATE TO BE JUNE 1ST WHERE, YOU KNOW, YOU ARE STILL APPROVING THE LOADS WITH PROBABLY THESE ADDITIONAL GUARDRAILS. AND THEN, AND, AND COME JUNE 1ST YOU HAVE A SET OF LOADS THAT YOU ALREADY KNOW ARE FIRM. YOU ALREADY KNOW THAT THEY ALREADY MET THIS CRITERIA THAT YOU LAID OUT. UH, AND NOW YOU CAN TAKE THAT BACK TO THE BOARD AND GET APPROVAL AND GO FORWARD. SO THAT'S MY PRIMARY REQUEST HERE, UH, ON THESE COMMENTS. UM, I ALSO HAD ANOTHER SET OF, UH, I MEAN I FILED FOR COMMENTS THE FIRST TIME [01:45:01] WHERE I THINK ANDREW LAID IT OUT AND B STILL SPOKE ABOUT IT. I THINK IT'S IMPORTANT TO, UH, UNDERSTAND THAT THE LEGACY LOADS THAT MET THE KAYAK AND OTHER SECURITY REQUIREMENTS AND ALSO OUR FIRM YET NEED TO GO BACK AND POST THESE DOLLARS IN THE 30 DAY PERIOD FOR THE ILE. I THINK THAT'S, THAT DOESN'T MAKE, UH, YOU KNOW, BECAUSE THE, THOSE LOADS ARE ALREADY SERIOUS. YOU KNOW, THOSE LOADS HAVE SIGNED INTERCONNECTION AGREEMENTS POSTED, YOU KNOW, DOLLARS. SO WHAT MORE DO YOU WANT FROM THOSE LOADS TO SHOW THAT THEY ARE SERIOUS LOADS AND NOT GHOST LOADS, RIGHT? SO I THINK THEY NEED TO BE GRANDFATHERED IN. UH, AND IT IS MY UNDERSTANDING, AND I SPOKE ABOUT IT LAST TIME AS WELL, THAT FIGHT 4 8 1 IS INTENDED TO BE FOR NEW LOADS. AND THESE ARE NOT NEW LOADS. THESE ARE LOAD, THESE ARE LOADS THAT HAVE, YOU KNOW, PUT DOWN REAL MONEY AND HAVE STUDIES APPROVED IN MANY WAYS. SO, UH, THOSE LOADS SHOULD BE GRANDFATHERED IN, IN MY OPINION. UM, YEAH, I THINK THAT'S, THAT'S ABOUT IT. MATT. THANK YOU. I GUESS, HEY MATT, I JUST WANT TO, YOU KNOW, WE TALKED ABOUT WHETHER 5 8, 4 A ONE IS IS FOR NEW LOADS AND I, I MEAN I THINK SUPER TECHNICALLY THAT'S PROBABLY RIGHT. UM, BUT IT IS SERVING AS THE INSPIRATION FOR THIS CONVERSATION. I DON'T KNOW WHERE YOU SAT DOWN, BUT, UM, OH, YOU'RE STILL UP THERE. SORRY, . UM, SO JUST FROM LIKE A, A CONCEPTUAL STANDPOINT, I THINK THE CONCEPTS, UM, THAT ARE SHOWING UP IN THAT RULEMAKING OBVIOUSLY ARE INFLUENCING THE CONVERSATIONS THAT WE'RE HAVING HERE. SO TO THAT EXTENT, I JUST WANT TO MAKE SURE THAT FOLKS UNDERSTAND THAT WHATEVER HAPPENS IN 5 8, 4 8 1, UM, IT IS, IS INFLUENCING THE CONVERSATION HERE. IT'S NOT STRICTLY FOR THE NEW STUFF. YEAH, I UNDERSTAND THAT AND I THINK THAT SHOULDN'T BE THE CASE THAT WE SHOULD HAVE A SEPARATE CRITERIA FOR BAD ZERO BECAUSE FIVE FOR IT WHEN IT'S STILL IN FLUX AND COMMENTS ARE COMING IN. SO MY OPINION IS THAT THIS SHOULD BE MORE NUANCED FOR BAD ZERO, WHERE YOU CONSIDER THREE TIERS OF LOADS, WHERE LOADS THAT HAVE MET AGREEMENTS THAT ARE FIRM ALREADY SHOULD BE GRANDFATHERED IN AND LOADS THAT JUST PROBABLY HAVE AN LLI THAT ARE, THAT ARE QUALIFIED TO BE STUDIED MAY GO THROUGH THIS ILLE PROCESS BECAUSE THEY HAVEN'T SIGNED ANY AGREEMENTS OR POSTED ANY KAYAK. SO THAT'S HOW I SEE IT. AND I'LL PROBABLY FILE, I THINK I FILE THAT IN MY COMMENTS, I'LL PROBABLY BE MORE CLEAR NEXT TIME. RIGHT? I THINK THAT'S A FAIR, FAIR PERSPECTIVE TO HAVE. THANK YOU. ALRIGHT, UM, SO ONTO MICHAEL JEWEL JOINT COMMENTERS FOR STREAM DATA AND PROVIDENCE. MATT? YES, THERE YOU'RE JUST IN THE INTEREST OF TIME, I CAN CHAT FROM RIGHT HERE. YOU BE, UM, IN BRIEF, UH, STREAM DATA CENTERS AND PROVIDENCE, UH, STRONGLY ENDORSED POINT NUMBER FOUR THAT ENCORE MADE WITH REGARD TO EXTENDING THE, UH, DEADLINE BY WHICH RPG PROJECTS, UH, CAN BE APPROVED AND ENDORSED, UM, AND BE INCLUDED IN BATCH ZERO. THERE'S A LOT OF FINANCIAL COMMITMENTS THAT HAVE BEEN MADE, THE MONEY THAT HAS BEEN PAID, CONTRACTS THAT HAVE BEEN SIGNED THAT ARE THE RESULT OF THAT PROCESS. AND SO WE THINK IT'S REALLY, IM IMPERATIVE FOR THOSE TO BE RESPECTED. SO THANK YOU. ALL RIGHT. A WINNER FOR SHORTEST. THANK YOU. BRIEF AND AMAZING. ALL RIGHT. UH, JIM LEE, CENTER POINT. THANKS MATT. UH, JIM LEE, CENTER POINT, I'M ACTUALLY GOING TO HAND IT OVER TO MY SMART GUY IN THE ROOM, UM, TO GO OVER SOME OF OUR COMMENTS. UH, WES WHITE CENTER POINT ENERGY. UH, SO, UH, FIRST COMMENT IS THAT, I MEAN, WE, WE THINK THE PICKER 1 45 IS DEFINITELY MOVING IN THE RIGHT DIRECTION. THERE WERE A LOT OF ADDITIONS FROM ERCOT. WE REALLY APPRECIATED, UM, PARTICULARLY, YOU KNOW, THE IDEA OF THE BATCH STUDY FOLLOWED BY THE REFINEMENT AND HOW TO DO THE, UH, THE PROJECTS OR THE, UH, RPG PROCESS WAS A, WAS A HUGE IMPROVEMENT. UM, SO LET ME JUST KIND OF HIT THE HIGH LEVEL, UH, COMMENTS THAT WE HAD. UM, SO, UH, 9 2 1 2, UM, PARAGRAPH ONE A AND B, WE MADE SOME, UM, EDITS HERE THAT WE THINK KIND OF CLARIFY. THERE WAS SORT OF MISSING BUCKETS IN HERE. WE FELT LIKE THAT WERE NOT COVERED. UM, AND SO WE MADE A COUPLE EDITS THERE TO, TO MAKE SURE THAT WE COVERED THOSE. UH, WE ALSO ADDED, UH, AT THE END OF ONE A IN THAT SECTION, UM, 'CAUSE WE ARE SORT OF HAVING THIS DEBATE [01:50:01] INTERNALLY AS TO A LOAD THAT WE THINK MAY MAKE BATCH ZERO BASE OR ALLOCATED LOAD. BUT ONE REQUIRES, UM, INTERCONNECTION AGREEMENT. ONE REQUIRES AN INTERMEDIATE AGREEMENT. AND SO WE ADDED THIS SORT OF STATEMENT THAT SAID IF YOU GO STRAIGHT TO AN INTERCONNECTION AGREEMENT, THAT ALSO QUALIFIES AS AN INTERMEDIATE AGREEMENT. AND THAT'S A, THAT WOULD BE A, A, A BENEFICIAL ADDITION TO THIS SECTION. UM, ONE B, UH, THERE WAS A DATE IN THERE OF JANUARY 1ST, 2028. WE DIDN'T THINK THAT WAS NECESSARY BECAUSE THERE ACTUALLY ARE GONNA BE SOME LOADS OUT THERE THAT HAVE, UH, A 2027 ENERGIZATION. AT LEAST THEY REQUESTED IT A 2027 ENERGIZATION DATE, UH, IF THEY'RE IN IS ALLOCATED. YOU'VE MADE IT CLEAR THAT THEY'RE NOT GONNA BE ALLOCATED UNTIL 28. BUT, UM, SO, SO THAT'S ALREADY COVERED. SO WE JUST DIDN'T THINK THE DATE WAS NECESSARY TO INCLUDE THERE. SO WE STRUCK THAT, UH, IN, NOT IN, IN SEVERAL SECTIONS, 9, 2, 1 4 AND SOME OTHERS. THERE WAS SOME VERY SORT OF FIRM, UM, STATEMENTS ABOUT ERCOT HAVING SOLE AUTHORITY. WE MODIFIED SOME OF THAT TO SORT OF HAVE SOME MORE COLLABORATIVE LANGUAGE IN THERE. UM, YOU KNOW, THAT SAYS ERCOT ISS GOING TO COLLABORATE AND DISCUSS WITH TSPS, UM, AS TO, YOU KNOW, DIFFERENT, UM, YOU KNOW, STUDY VALIDITY AND THINGS LIKE THAT. SO YOU'LL NOTICE THAT IN SEVERAL SECTIONS. 9, 2 1 4. UM, WE ALSO HAD IN, UH, PARAGRAPH, UM, E UH, YOU KNOW, ONE OF OUR CONCERNS IS THE STUDY AREA. THAT WHAT IS A VALID AND COMPLETE STUDY IS VERY MUCH DETERMINED ON THINGS IN THE STUDY AREA, BUT THAT'S NOT DEFINED. SO WE ADDED A STATEMENT IN THERE TO TRY TO GET A, A SHIFT FACTOR, UM, DEFINITION OUT THERE SO IT'S AT LEAST CLEAR TO EVERYONE WHAT IS AND ISN'T IN A STUDY AREA. UM, LET'S SEE, SECTION 9, 2 2. UM, SE UH, PARAGRAPH C, WE SAW THAT IT WAS UNCLEAR AND ILLE IS DOING A WRITTEN ACKNOWLEDGEMENT, BUT IT DIDN'T REALLY SAY WHO THAT WAS GOING TO. SO WE ADDED THAT STATEMENT THAT IT WAS GOING TO THE DSP OR TSP IN PARAGRAPH THREE. UM, THIS IS DISCUSSING THE DYNAMIC DATA AND UM, I THINK, UH, ERCOT ATTEMPTED TO HELP IN THIS AND I THINK THEY DID, BUT AT THE SAME TIME YOU KIND OF ADDED THIS STATEMENT, YOU KNOW, UM, THE DYNAMIC DATA IS EXPECTED TO ADVERSELY IMPACT THE RESULTS OR NOT, YOU KNOW, ADVERSELY IMPACT THE RESULTS. UM, OBVIOUSLY WE'RE GONNA HAVE TO WORK WITH ERCOT TO MAKE THAT DETERMINATION. HOWEVER, WE THINK THE FINAL DETERMINATION SHOULD COME FROM ERCOT, NOT THE TSP, THEY'RE IN A BETTER ERCOT IS IN A BETTER POSITION TO ACTUALLY MAKE THAT MAKE THAT STATEMENT. IF YOU GO TO PARA PARAGRAPH, UM, EXCUSE ME, SECTION 9, 2 4 LOAD COMMISSIONING PLAN, YOU'LL SEE SOME EDITS THERE. UM, REALLY MORE TO CAPTURE THE SEQUENCING, UM, OF CHANGES. UH, SO YOU'LL SEE, I THINK WE MOVED ESSENTIALLY WHAT WAS IN PARAGRAPH, UH, ORIGINAL THREE UP TO TWO, UM, TO REALLY SEQUENCE IT BETTER THAT ONCE THE UH, UH, INTERCONNECTION AGREEMENT IS SIGNED, WE WOULD DO A FINAL LCP BEFORE. THEN IT KIND OF GETS TURNED OVER TO ERCOT, UH, LATER ON TO UPDATE. UH, THEN I THINK WE CAN GO TO SECTION 9 3 1. UM, HERE WE JUST AGREE WITH ENCORE, UH, ABOUT THE, UH, 30 DAY, UM, COMMITMENT TIME PERIOD AND UH, EXTENDING THAT OUT TO 60. UM, AGAIN, WE'RE HEARING A LOT OF, YOU KNOW, CONVERSATIONS THAT'S GONNA BE VERY DIFFICULT TO DO IN 30 DAYS. UM, 9, 3 2, UM, WE HAD SIMILAR COMMENTS TO ENCORE, SO I WON'T GO IN DEPTH ON ANY OF THESE EXCEPT I WILL SAY WE, WE ADDED ONE, UH, ADDITIONAL ITEM UNDER PARAGRAPH THREE. UM, WE NOTICED THAT, YOU KNOW, THIS IS DURING THE BATCH STUDY PROCESS. ERCOT HAD NOT ACTUALLY INCLUDED ANY LANGUAGE ABOUT, UM, ADDING, UH, OR REQUESTING UM, COST ESTIMATES FROM TSPS. AND SO WE INCLUDED THAT AS WELL 'CAUSE WE FELT LIKE THAT AT THAT POINT IS, IS DEFINITELY GONNA BE NEEDED. AND I THINK ERCOT MAY HAVE HAVE LEFT THAT OUT INADVERTENTLY, UM, BECAUSE IT WAS INCLUDED IN THE REFINEMENT PROCESS BUT WAS NOT INCLUDED IN THE ORIGINAL BATCH STUDY PROCESS. AND LET'S SEE, NINE FOUR. UM, SO WE JUST ADDED A COUPLE CLARIFYING STATEMENTS IN HERE THAT WE THINK IS IMPORTANT FOR [01:55:01] ERCOT TO, IN ADDITION TO ALL THE OTHER THINGS THAT ARE INCLUDING IN THE REPORT, BUT ALSO TO TO CLARIFY WHO THE, UH, UM, YOU KNOW, PROPOSED TRANSMISSION FACILITY UPGRADE, YOU KNOW, WHICH TSP IS ACTUALLY RESPONSIBLE FOR THAT. AND SO THAT WAS ADDED IN THAT SECTION AS WELL AS I THINK THE REFINEMENT SECTION ALSO, UH, IN 9 5 1, UM, YOU'LL ALSO SEE THAT WE UM, THERE'S BEEN LOTS OF COMMENTS ABOUT THE, THE SIX YEAR AND GOING AHEAD AND DOING THE EVALUATION FOR THE FULL SIX YEARS AS OPPOSED TO LEAVING THE SIX YEAR OUT AND JUST ALLOCATING FULL LOAD. SO WE AGREE WITH ALL THE OTHER COMMENTS THAT HAVE BEEN STATED HERE THAT THAT NEEDS TO BE INCLUDED AS WELL. 9 5 2, AGAIN, WE AGREE WITH A LOT OF WHAT ENCORE SAID. UM, I THINK THE ONE THING I'LL NOTE HERE IS THAT WE HAD, UH, YOU KNOW, SPECIFICALLY ON 9 5 2 PARAGRAPH TWO NOTED THAT, UM, YOU KNOW, THE SHORT CIRCUIT CASES THAT WERE DEVELOPED OR THAT THEY'RE REALLY NOT SHORT CIRCUIT CASES. SO WE ADDED SOME ADDITIONAL LANGUAGE IN HERE MAYBE TO HELP CLARIFY. BUT, BUT WE DO AGREE WITH ENCORE'S POSITION THAT, YOU KNOW, ERCOT SHOULD ULTIMATELY CREATE THOSE AND THEN WE WILL BE THE ONES TO RUN THOSE SHORT CIRCUIT STUDIES. AND I THINK THE REST OF OUR COMMENTS ARE IN 9 7 1 9 7 2 AND 9 7 3. YOU WILL SEE THAT, YOU KNOW, THERE ARE MANY OF THESE PARAGRAPHS IN HERE THAT DISCUSS, YOU KNOW, WHAT THE TSP DOES WITH FINANCIAL SECURITY AND REFUNDS AND THINGS LIKE THAT. AND OF COURSE THIS WAS COPIED AND PASTED OVER FROM 58 4 81 I I BELIEVE. BUT THAT, YOU KNOW, THE PIGGER 1 45 IS REALLY IN THE MECHANICS OF HOW TO RUN THE ACTUAL BATCH STUDY PROCESS. AND SO THAT THOSE PARAGRAPHS JUST REALLY DON'T NECESSARILY NEED TO BE IN THE PIGGER. AND SO WE WOULD SUGGESTED REMOVING, UM, SEVERAL DIFFERENT, UM, PARAGRAPHS IN HERE AND THOSE THREE SECTIONS THAT WE'RE DEALING WITH WHAT TO DO WITH FINANCIAL SECURITY AND REFUNDS AND THINGS LIKE THAT, THAT WILL ULTIMATELY BE DECIDED IN 58 41 BUT DIDN'T NECESSARILY NEED TO BE IN HERE. SO I THINK THAT COVERS THE HIGH POINTS THERE, MATT. ALRIGHT, THANK YOU. WE, UH, QUESTION SHANNON CARAWAY, CAN WE GO BACK TO WHERE THE CENTER POINT RECOMMENDED THE SHIFT FACTOR CUTOFF, WHEREVER THAT WAS THE ONLY NUANCE, FIRST OF ALL, WE THINK THAT'S A GREAT IDEA, UM, THAT THAT'S INCLUDED. AND THEN SECOND TO TAKE IT FURTHER, I THINK THAT SHOULD BE A DISTRIBUTED SLACK BUS, UM, SHIFT FACTOR ANALYSIS. UH, YOU KNOW, OTHERWISE YOU WIND UP WITH WHEREVER YOUR STUDY IS. IF YOU JUST KEEP IT THE SYSTEM SLACK BUS AT WA PARISH, IF YOU'RE DOING A STUDY RIGHT BY WA PARISH, YOU MAY HAVE WAY MORE IMPACT THAN THAT OR CONVERSELY WAY LESS OR IT, IT'S JUST THE PROPER WAY TO DO THAT IS A DISTRIBUTED SLACK BUS. THEN YOU CAN USE THE 3% RULE AS IS. YOU DON'T NEED TO APPLY ANY OTHER BANDAIDS OF, YOU KNOW, HOW MUCH IMPACT IT HAS ON THE LINE OR SOMETHING ELSE. SO I'D LIKE TO ADD THAT. JUST SMALL COMMENT, REF, UH, REFINEMENT THERE. OTHERWISE I THINK IT'S A GREAT IDEA. I THINK SHANNON, ANDREW? YEAH, I THINK ON THE SAME POINT WITH RESPECT TO THE STUDY AREA, I THINK WE HAVE TO REMEMBER TOO THAT FOR THE SERIAL WILLIS STUDIES, THE STUDY AREA WAS DEFINED BY ER COTTON COORDINATION WITH THE TSPS. SO EACH INDIVIDUAL STUDY IN THAT CASE HAS A STUDY AREA THAT WAS DEFINED AND THAT STUDY AREA SHOULD BE HONORED IF IT WAS THE ONE THAT WAS IN THE ORIGINAL STUDY. SO GOING FORWARD, SURE, I HAVE NO ISSUE SETTING SOMETHING LIKE THIS, BUT THE INDIVIDUAL LILI STUDIES DESIGNATE THE STUDY AREA FOR EACH LARGE LOAD INTERCONNECTION STUDY. SO JUST SOMETHING I WANTED TO POINT OUT. VERY GOOD. ALRIGHT, Q IS CLEAR. SO MOVE ON TO SAM, SAM, BRANDON. HEY, CAN I ACTUALLY, OH YEAH, PLEASE. I WANNA JUMP IN ON SOMETHING REAL QUICK. UM, SO I, I APPRECIATE THE ADDED DETAIL. I, I THINK, UM, UH, I'M NOT OPPOSED TO THE ADDED DETAIL FOR BATCH ZERO, BUT I, I THINK LONGER TERM THERE MAY BE REASONS WHY WE DON'T WANT TO BE SO PRESCRIPTIVE ON ONGOING BATCH. AND, AND SO I THINK WE INTENTIONALLY LEFT OUT SOME OF THOSE DETAILS OUT OF THIS TO AS SO AS TO NOT SET THE PRECEDENT. UH, BECAUSE THERE ARE THINGS THAT I, I THINK MAYBE OVER TIME THEY EVOLVE. SO I THINK SIMILAR TO RTP, WERE, WERE A LOT OF THOSE DETAILS AREN'T SPELLED OUT IN THE PLANNING GUIDE. WE, WE PRESENT THOSE TO STAKEHOLDERS. I THINK THAT THAT'S THE APPROACH THAT WE WOULD, UM, [02:00:01] PREFER. UH, 'CAUSE I I JUST THINK IT'S, IT'S MORE EFFICIENT IN THE LONG RUN. UM, AGAIN, I I'M NOT OPPOSED TO THAT. I JUST, I'M CONCERNED ABOUT THE PRECEDENT. SO YEAH, I, I THINK WE WERE PRIMARILY CONCERNED WITH BATCH ZERO AND THE QUESTIONS ABOUT WHAT IS AND ISN'T IN AND, AND SORT OF IN SOMEWHERE IN THE BACK BACKWARD LOOKING POSSIBILITIES AS WELL. BUT FAIR POINT GOING FORWARD. ALL RIGHT, DURGA, UM, THANK YOU FOR THIS. UM, UM, I THINK BECAUSE WE ARE MOVING FROM MORE OF A SERIAL TO A CLUSTER KIND OF STUDY, I THINK WE SHOULD ALSO CONSIDER APART FROM JUST 3% SHIFT FACTOR. UM, IT SHOULD BE VOLTAGE LEVEL BASED LIKE FOR 3 45, 1 38 AND LOWER AND LOWER FOR DIFFERENT VOLTAGE LEVELS, THE MEGAWATT IMPACT ON THE LINE AND THE PERCENTAGE OF THE NET LINE, UH, NET RATING OF THE LINE. RIGHT? SO IT SHOULD BE MORE NUANCED THAN JUST A 3% RULE FOR IDENTIFYING A PROBLEM. 'CAUSE IT'S, AT TIMES WE HAVE SEEN A STUDY, IF IT'S A 30 MVA LINE AND THERE'S A 3% SHIFT FACTOR, THE IMPACT IS NOT MUCH. IT CAN BE, IT CAN BE MANAGED, UH, OPERATIONALLY, RIGHT? BUT IT DOES, IT'S NOT THE SAME THING FOR A 3 45 KV LINE, RIGHT? IT'S, IT'S A VERY DIFFERENT KIND OF STORY THERE. SO I THINK THE, THE DESCRIPTION SHOULD BE MORE NUANCED AND, AND I THINK THERE ARE ALREADY EXISTING, UM, UM, LITERATURE FOR THAT IN OTHER ISOS. UM, MAYBE A SIMILAR PART PATTERN FOLLOWED WOULD BE MORE, MORE EFFICIENT IN MY POINT OF VIEW. ALRIGHT, THANK YOU. ALRIGHT. OKAY. AT THIS POINT WE'LL TURN OVER TO SAM BRANDON WITH THE NEXT SET OF COMMENTS. SAM, I CAN OPEN YOURS UP HERE. THANKS. AND I'M HAPPY TO JUST DO IT FROM MY SEAT RIGHT HERE. THAT WORKS. GIMME A SECOND HERE. AND THESE ARE FOR JOINT COMMENTS FILED ON BEHALF OF BOTH AG AGENTIC INFRASTRUCTURE AND RELIANCE. SO BILL, FEEL FREE TO FEEL FREE TO JUMP IN AFTER I COMPLETE MY STATEMENTS HERE. AND SO, YEAH, I THINK IT'S, OUR COMMENTS ARE, ARE VERY SUCCINCT. IT'S JUST 9.2 0.12. UM, WANT ME TO GO SCROLL DOWN THERE? YEAH, IF YOU DON'T MIND. UM, YEAH, 9.2 0.1 0.21 B ROMAN AT TWO, 2.1 0.2. I THINK I'M IN THERE. OKAY. SORRY. REPEAT THE LAST THREE, UH, PARTS OF THE ZIP CODE THERE. PLUS FOUR NUMBERS THAT WE NEVER USE. YEAH. ONE B ROMAN AT TWO, THANK. AND THEN WE ADDED C AND D. GOT IT. THANK YOU. OKAY, SO I'LL JUST QUICKLY SUMMARIZE WHAT IS OTHERWISE WRITTEN IN THE DESCRIPTION UP TOP, WHICH I'M SURE EVERYBODY READ. UM, SO ULTIMATELY WE ARE JUST ADDING TWO ADDITIONS TO THE, UM, CRITERIA FOR ELIGIBILITY FOR INCLUSION AS LOAD TO BE STUDIED AND ALLOCATED IN BATCH ZERO. SO THE FIRST CRITERIA BEING PROPOSED IS THE LARGE LOAD HAS RECEIVED AN ERCOT LLI NUMBER AND HAS SATISFIED THE CRITERIA TO BE INCLUDED IN THE ERCOT 2026 RTP. AND SO THE RATIONALE THERE IS JUST THAT STAKEHOLDERS RELY ON CLEAR MARKET PLANNING, UM, INFORMATION TO ULTIMATELY INFORM DECISIONS THAT IMPACT BOTH RELIABILITY AND ECONOMIC EFFICIENCY OF THE MARKETPLACE. SO THAT IMPACTS HOW LOAD IS SERVED TODAY, AS WELL AS, YOU KNOW, HOW THE SYSTEM IS ULTIMATELY GONNA BE EXPANDED. UM, AND YOU KNOW, THERE'S VARIOUS ENTITIES THAT LOOK TOWARDS THE RTP TO INFORM HOW THEY ASSESS THE ERCOT MARKET. AND SO THAT'S NERC WITH RELIABILITY ASSESSMENTS. UM, THERE'S FINANCIAL INTEREST PARTICIPATING IN CONGESTION MANAGEMENT, UM, THAT HELP HELP WITH THE EFFICIENCY OF, OF CONGESTION PRICING. UM, AND THEN ALSO DEVELOPERS ARE ULTIMATELY INFORMED WHERE TO CITE NEW STANDALONE PROJECTS, UM, BASED OFF OF, OF TRANSMISSION PLANNING ANALYSES. AND SO ULTIMATELY IT SEEMS, UH, REASONABLE TO ALIGN THE BATCH PROCESS WITH THE 2026 RTP, UM, ACKNOWLEDGING THAT IT'S, YOU KNOW, CUMBERSOME TO DO SO. UM, WE ULTIMATELY NEED TO BE SENDING CLEAR PRICE SIGNALS TO THE MARKET FOR FUTURE PLANNING. AND THEN ADDITIONALLY, THE PROJECTS THAT HAVE BEEN, UH, INCLUDED IN THE 2026 RTP WILL HAVE SATISFIED A HIGHER BURDEN OF PROOF FOR THE SUBSTANTIATION OF THAT PROJECT COMPARED TO 5 8 4 8 1, BECAUSE THEY'RE MEETING THE STANDARDS, UH, UNDER 5 8 4 8 0. SO FROM THAT STANDPOINT, IT WOULD SEEM RATIONAL TO INCLUDE THAT LOAD, UM, IN THE ALLOCATED PORTION, UM, ASSUMING THAT IT, IT DOES NOT OTHERWISE SATISFY THE FIRM ALLOCATION, UM, FROM THE PREVIOUS SECTION. [02:05:02] SO THE SECOND, UM, UH, ADDITION HERE IS LARGE LOAD HAS RECEIVED AN ERCOT LLI NUMBER AND HAS INDICATED IN ITS INTERMEDIATE AGREEMENT THAT IT CAN BE STUDIED AS A CLR OR AS A, OR PLANNED WITH CO-LOCATED GENERATION RESOURCES FOR THE PURPOSES OF PARTICIPATION IN BATCH ZERO. AND SO THE IMPORTANT THING TO HIGHLIGHT ABOUT THESE PROJECTS IS THAT THESE PROJECTS, UM, WHICH ARE PLANNING TO PURSUE BYOG OR CLR STRUCTURES, THEY ARE GATED BY THE PROCESS ITSELF. THEIR TIME TO MARKET IS NOT GATED BY THE ULTIMATE NECESS NECESSARY NETWORK UPGRADES TO DELIVER THESE PROJECTS. AND SO IN ADDITION TO THAT KIND OF, UM, DIFFERENCE IN WHAT IS ACTUALLY GATING THIS, THE, THE ACTION OF THE PROJECT, THESE PROJECTS ARE WILLING TO ADD PHYSICAL CAPACITY, UH, CONTRIBUTIONS AND PRIVATELY MANAGE RISK UNTIL NETWORK UPGRADES ARE DELIVERED. UM, AND THAT BECOMES A MATERIAL PIECE OF THE SOLUTION TO SYSTEM WIDE CHALLENGES THAT LOAD INTEGRATION IS CURRENTLY PLACING ON THE SYSTEM. UM, ULTIMATELY ALLOWING THESE LOADS TO ADVANCE WITH PRIVATELY MANAGED SOLUTIONS IS QUITE FRANKLY THE SINGLE GREATEST TOOL THAT ERCOT AND THE PUCT HAVE FOR ULTIMATELY MEETING THE OBJECTIVES OF SENATE BILL SIX, WHICH IS TO MAXIMIZE ECONOMIC ACTIVITY, MINIMIZE STRANDED COST RISK, AND PRESERVE RELIABILITY. UM, AND THE, THE PIECE THAT'S, YOU KNOW, IMPLICIT, IT'S NOT EXPLICIT. THERE IS ALSO THIS NOTION OF MAKING SURE THAT ONCE WE DECIDE WHAT TO ACTUALLY BUILD FOR THE TRANSMISSION SYSTEM, WE'RE BUILDING THE TRANSMISSION IN A, UM, ECONOMICALLY REASONABLE MANNER. AND SO BY ALLOWING PROJECTS TO PURSUE OPPORTUNITIES TO PRIVATELY ASSUME RISK, THOSE PROJECTS ARE GOING ABOVE AND BEYOND, UM, WHAT IS TRADITIONALLY OBLIGATED OF THEM IN THE FIRM PROCESS TO NOT ONLY CITE, UM, YOU KNOW, WHERE THEY FEEL THE LOAD OUGHT TO BE, BUT THEN THEY'RE ALSO BRINGING THE CAPACITY SOLUTIONS TO MAKE SURE THAT THE SYSTEM CAN SERVE THEM AS FAST AS POSSIBLE. SO WITH THAT IN MIND, LIKE I SAID, BILL, FEEL FREE TO ADD ANYTHING THERE ION I THINK IT'S STILL, THE BATTERY STILL WORKS. YES. UM, JUST WANNA JUMP IN HERE AND SUPPORT SAM ON, ON HIS COMMENTS ON BOTH A, C AND D, BUT IN PARTICULAR, D IT WOULD BE HARD TO OVERSTATE THE WINDOW OF OPPORTUNITY THAT WE HAVE RIGHT NOW IN TERMS OF LARGE LOAD CUSTOMERS THAT ARE WILLING TO INVEST IN FLEXIBLE ARRANGEMENTS, ADDITIONAL SUPPLY GRID FRIENDLY SITES THAT WILL NOT ONLY CONTRIBUTE TO TRANSMISSION SECURITY, BUT ALSO RESOURCE ADEQUACY. WE HAVE TO GIVE 'EM A REASON TO DO THAT THOUGH. AND SO THIS, WE USED A KEY WORD IN OUR COMMENTS, WHICH I REALLY LIKE, I'M GONNA EMPHASIZE, AND I KNOW THE FOCUS RIGHT NOW IS ON BATCH ZERO AND HOW DO WE SORT THROUGH THE, THE LOG JAM THAT WE HAVE. BUT FROM OUR VIEW, THE SINGLE MOST CONSEQUENTIAL POLICY DECISION THAT WE'RE GONNA MAKE THROUGH ALL THIS IS THIS RIGHT HERE. HOW DO WE MAKE SURE THAT WE ENCOURAGE DEVELOPMENT TO BE GRID FRIENDLY? AND SO THIS IS A START AND I KNOW ERCOT HAS PUT A LOT OF TIME INTO THE CLR AND THE BYOG CONCEPTS. I LOOK FORWARD TO DISCUSSING THAT LATER. BUT I JUST WANT TO EMPHASIZE HOW IMPORTANT THIS POLICY DECISION IS RIGHT NOW AND FOR WHAT WE'RE GONNA CONSIDER WITH THE ONGOING BATCH PROCESSES AS WELL. SO APPRECIATE THE CONSIDERATION OF THIS, UH, IDEA. VERY GOOD. SO WE HAVE BROTH AND THEN SHANNON, GO AHEAD, BROTH. HEY, MY COMMENTS ARE NOT PARTICULARLY REGARDING THIS. IF YOU WANT ME TO HOLD OFF, I CAN HOLD OFF AND COME BACK, BUT I, I HAD A COMMENT ON SLIDE 28, SO IF YOU WANT ME TO HOLD OFF, I CAN GO BACK AND CAN YOU HOLD THAT? YEAH, I'M REALLY THAT'S FINE. KEEP AN EYE ON LUNCH HERE AT THIS POINT. IT SOUNDS SELFISH, BUT, OKAY. UH, SHANNON MAN IS ON THIS, UH, WITH REGARD TO ONE DI WANTED TO ECHO THAT WE STRONGLY AGREE WITH, UM, WHAT NRG WAS JUST SAYING AS WELL AS, UH, YOU KNOW, SAM'S PROPOSAL TO PUT IT HERE, SO IT'S HARD TO OVERSTATE THE BENEFIT THAT THIS CAN BRING. VERY GOOD. ALRIGHT, EVAN? YEAH, I, I GUESS JUST LIKE A CLARIFYING QUESTION ON, ON THIS CONCEPT, AND I MEAN, I DON'T DISAGREE WITH WHAT SAM, WHAT YOU AND BILL WERE TALKING ABOUT HIGH LEVEL, I'M JUST KIND OF CURIOUS WHY IT NEEDS TO BE HERE IN THIS LANGUAGE. LIKE, I JUST, I'M JUST STRUGGLING TO GRASP LIKE EXACTLY WHAT, WHAT THIS IS CHANGING. LIKE IF, IF IF THE, IF THE, WHAT BATCH ZERO IS GONNA ACHIEVE IS GONNA BE TO PLAN A TRANSMISSION SYSTEM TO SERVE THAT LOAD, I I DON'T REALLY UNDERSTAND HOW THIS CHANGES ANY OF THAT. YEAH, SO I GUESS THE [02:10:02] EXPLICIT NUANCE IS IT ALLOWS PROJECTS WHICH OTHERWISE DO NOT MEET THE CRITERIA OF, UH, ROMAN TWO B TO BE INCLUDED. BECAUSE ULTIMATELY, UM, YOU KNOW, TO GET TO THE STAGE WHERE YOU HAVE A APPROVED STEADY STATE STUDY, UH, ULTIMATELY HAS UTILITY TSP DISCRETION TO, UH, IN DETERMINING, YOU KNOW, IF YOUR PROJECT REACHES THAT STAGE. AND FRANKLY, IF ALL THESE PROJECTS ARE GOING TO BE GOING INTO BATCH ZERO, WHICH ULTIMATELY DETERMINES THE STEADY STATE OUTCOMES AND THE TRANSMISSION PLANNING, THEN THAT'S MORE OF A TOOL TO GATE PROJECTS INCLUDED IN THE ALLOCATED PORTION OF BATCH ZERO RATHER THAN ANY SORT OF, UM, TECHNICAL NEED TO BE AT THAT STAGE IN THE, IN THE STUDY PROCESS. OKAY. SO THEN I READ THIS AS EVERY SINGLE LOAD WHO WANTS TO BE INCLUDED IN BATCH ZERO SHOULD SAY THAT THERE'RE GONNA BE A CLR UPFRONT TO AN AGREEMENT THAT'S NOT BINDING AT ALL IN THE ACTUAL, YOU KNOW, WHETHER WHEN THE RUBBER MEETS THE ROAD, IF I'M GONNA BE A CLR COMES ON A QUALIFICATION WHEN I'M OPERATIONAL. AND SO THIS JUST SEEMS TO ME AN, UH, INCENTIVE FOR EVERYBODY TO SAY, YES, I'LL BE A CLR SO THAT I AM NOW IN BATCH ZERO AND THE ENTIRE ERCOT LLIQ OF 200 AND SOMETHING GIGAWATTS WILL GET IN. YEAH. IN SHORT, I DON'T NECESSARILY THINK THAT THAT IS A BAD WAY FOR THE MARKET TO THINK ABOUT LOAD INTEGRATION. UM, BUT OTHERWISE IT'S WORTH MENTIONING THAT YOU WOULD STILL NEED TO MEET THE INTERMEDIATE AGREEMENT OBLIGATIONS IN ORDER TO BE IN BATCH ZERO. SO THE INTERMEDIATE AGREEMENT OBLIGATIONS WILL ULTIMATELY GATE WHICH PROJECTS ARE MATERIAL ENOUGH TO ACTUALLY WANT TO WEAR THE RISK OF TAKING IT ALL THE WAY TO OPERATIONS. YEAH, I THINK THERE'S A, A LITTLE LEGAL, UH, ISSUE THERE. IF YOU'RE JUST GONNA MAKE IT UP. THERE'S AN ATTESTATION REQUIRED AS PART OF THE INTERMEDIATE AGREEMENT AND THE FINANCIAL SECURITY THAT WOULD, UH, THE CAPITAL THAT YOU'RE OUTLAYING FOR, UM, TO BE A CLR AND TO HAVE GENERATION IS SIGNIFICANT, IF NOT GREATER THAN THE FINANCIAL REQUIREMENTS IN INTERMEDIATE AGREEMENT. BUT THE PART OF THE, THE COMMENTARY HERE IS THAT YOU ARE DISCLOSING THAT IN THE INTERMEDIATE AGREEMENT, WHICH IS A LEGALLY BINDING DOCUMENT. OKAY. SO WHAT HAPPENS THEN WHEN YOU TRY TO ENERGIZE AND YOU CANNOT QUALIFY AS ACL R, THEN YOU'D BE WAITING FOR FIRM SERVICE, RIGHT? YEP. SO EVERY SINGLE LOAD IS INCENTIVIZED TO PUT THAT THEY'RE A CLR WITH FAIR INTENTION THAT THEY'RE GONNA TRY TO BE A CLR AND GO THROUGH THE QUALIFICATION PROCESS AND THEN IF THEY FAIL IT, THERE IS NO DOWNSIDE TO THEM BECAUSE THEY'VE STILL NOW GONE THROUGH BATCH ZERO AND HAD TRANSMISSION PLANNED FOR THEM FOR THEIR FIRM SERVICE. SO ANYBODY THAT'S WILLING TO MEET INTERMEDIATE AGREEMENT AND HAS AN LLI NUMBER, WHICH IS A POOL OF 200 PLUS GIGAWATTS IS NOW GOING TO SAY THAT. YEAH. I GUESS DO YOU THINK THAT THE ENTIRE BATCH IS GOING TO BE WILLING TO POST THE FINANCIAL OBLIGATIONS UNDER THE INTERMEDIATE AGREEMENT? I THINK IF YOU ASK EACH OF THEM, THEY WILL ALL SAY YES, BUT WE ALL COLLECTIVELY KNOW THAT IT'S NOT THAT. RIGHT. I MEAN, I'M JUST TRYING TO SAY THAT THE INCENTIVES WE'RE SETTING UP I DON'T THINK ALIGN WITH WHAT THE PRINCIPLES OF BATCH ZERO ARE OR LIKE, I GUESS I JUST DISAGREE WITH THE STATEMENT THAT THE INCENTIVES WE'RE LAYING OUT IS HOW WE SHOULD BE CONSIDERING LOAD INTERCONNECTION. YEAH, I GUESS THE LAST THING I'LL SAY ON THIS IS THAT ULTIMATELY IF PARTIES ARE WILLING TO POST THE FINANCIAL OBLIGATIONS AND THEN WILLING TO ATTEST TO PURSUING EITHER THE BYOG CONCEPTS OR CLR, THEN IF THEY FAIL TO DELIVER THAT CAPABILITY ON THE SCHEDULE THAT THEY ARE ADVANCING THEIR PROJECT ON, WHICH IS A MULTI-BILLION DOLLAR PROJECT, THE CONSEQUENCE IS THAT THEN THEY ARE JUST TREATED LIKE EVERY OTHER LOAD TO BE ALLOCATED IN THE PROCESS. AND SO, YOU KNOW, THIS IS NOT IMPACTING THE FIRM POSITIONS IN BATCH ZERO, IT IS THIS SUBSET OF ALLOCATION, WHICH, UM, I DON'T NECESSARILY SEE AN ISSUE WITH ALL THE PROJECTS WHICH ARE CAPABLE OF POSTING THE INTERMEDIATE AGREEMENT AND SATISFYING THOSE LANGUAGE TO BE ALLOCATED AS PART OF THIS PROCESS GIVEN, YOU KNOW, THERE'S BASICALLY THE YEAR SIX RELEASE VALVE, WHICH WILL, UM, ALLOW FOR ITERATIONS ON THE TRANSMISSION PLANNING AS WE ARE ON ROUTE TO THAT COD TIMELINE. SO I THINK THAT PURSUING A CLR FAILING TO DELIVER AND THEN SITTING, YOU KNOW, A $10 BILLION PROJECT LIKE A PAPERWEIGHT FOR FIVE YEARS, UM, THAT IS A MATERIAL CONSEQUENCE FOR CAPITAL PLANNING THAT WILL PREVENT THAT SORT OF SITUATION FROM MANIFESTING IN MY OPINION. THE VERY LAST THING I'LL [02:15:01] SAY IS THAT BASED OFF THE C, THE BCLR AND BYOG CON, UH, CONVERSATION WE'LL HAVE THIS EVENING, I ACTUALLY THINK THAT NOW THE BYOG PUN PLUS STRUCTURE, UM, COULD BE A MORE ATTRACTIVE PATHWAY FOR A LOT OF THESE PROJECTS. AND SO THEREFORE, UM, YOU KNOW, THIS, THE CLR HANGUP MIGHT BE LESS OF THE FOCAL POINT FOR THIS CONVERSATION. YEAH, I, I MEAN I THINK WE'RE GETTING TO A POINT WHERE MAYBE WE'RE TALKING THIS IN CIRCLES. UH, I THINK WE CAN MOVE ON 'CAUSE THERE'S A BUNCH OF OTHER PEOPLE IN THE QUEUE, BUT I GUESS I'M JUST TRYING TO SAY IS I, WHAT I'M HEARING YOU SAY IS THAT'S THE SAME THING IS JUST SAYING ANYBODY WHO HAS AN LLI NUMBER AND MEETS THE INTERMEDIATE AGREEMENT SHOULD BE INCLUDED IN HERE THAT CLR ASPECT YOU'RE SAYING IF IT CAN'T BE DELIVERED, WELL THAT'S JUST A CONSEQUENCE OF HOW IT'S WRITTEN, BUT YOU KNOW, I THINK WE ARE THEN VASTLY EXPANDING THE AMOUNT OF LOAD THAT'S CONSIDERED AND IF THIS IS JUST GONNA BE A, EVERYTHING GOES IN YEAR SIX, YOU KNOW, I JUST THINK THIS IS INTRODUCING A LOT OF, A LOT OF HOLES AND KIND OF BLOWING THE THING WIDE OPEN FOR WHAT'S INCLUDED. SO. ALRIGHT. THANK YOU. YEAH. ALRIGHT, MICHAEL, AND THEN JOEL MICHAEL JEWEL. THANK YOU. UH, MICHAEL JEWEL ON BEHALF OF WISE ENERGY RESOURCES AND SUPPORTS THE, UH, INCLUSION OF THE GENERATION, UH, RESOURCE LOADS CO-LOCATED WITH THE GENERATION RESOURCES. VERY GOOD. UH, JOEL DAVIS? YEAH, UH, JOEL DAVIS MALCO, UH, JUST WANNA SUPPORT, UM, THE COMMENTS HERE ON, UH, C AND D. UM, JUST ONE QUICK QUESTION. UM, WOULD, WOULD YOU GUYS BE OPEN TO THE IDEA OF THIS DECLARATION OF BEING A CLR BEING IRREVOCABLE FOR WHAT IT'S WORTH? I THINK THAT'S THE EXPECTATION. SO THEREFORE, YES, YOU KNOW, LOADS CAN ALL THIS LOAD CAN, THAT HAS AN LLI NUMBER CAN GO AND DECLARE AS ACL R, BUT ALL THAT MEANS IS THEY WEAR THE PRIVATE TRANSMISSION RISK FOR, FOR ONE EXTRA YEAR BECAUSE IF THEY'RE WILLING TO MEET THE INTERMEDIATE AGREEMENT FOR BATCH ZERO, THEY'RE PROBABLY GONNA BE WILLING TO MEET IT FOR BATCH ONE, AT WHICH POINT THEY END UP IN YEAR SIX ONE YEAR LATER THAN THEY WILL. ANYWAY. THANK YOU FOR THE COMMENT. UH, BILL BARNES AND AUSSI JUST EMPHASIZING THE LEGAL RAMIFICATIONS OF THE INTERMEDIATE AGREEMENT, I'M JUST GONNA LEAVE THAT THERE. I ACTUALLY HAD A SECOND POINT, UM, MY FAULT COMMENTS ON MARCH 9TH AS WELL. THAT WAS, UM, PRESERVING THE ABILITY FOR A LARGE LOAD THAT'S, UH, CO-LOCATED WITH GENERATION THAT IS BEING STUDIED UNDER A GENERATOR FIS TO PRESERVE THE ABILITY THAT, FOR THAT TO ACT IN LIEU OF A BATCH STUDY. I HAVEN'T SEEN ANY RESPONSE FROM ERCOT YET, AND I'M SURE YOU'RE NOT IGNORING ME, BUT I'M WONDERING IF THAT'S GONNA COME AT SOME OTHER TIME. YEAH, BILL, WE ARE NOT IGNORING YOU. WE'RE, WE'RE THINKING ABOUT THAT, THINKING ABOUT THAT IN THE CON IN THE CONTEXT OF THE BYOG, UH, THE LANGUAGE THAT WE'RE, UM, ABOUT TO WRITE ON THAT. FANTASTIC. THANK YOU. VERY GOOD AHI. MATT, I'M SORRY TO INTERRUPT, BUT IF I COULD JUST MAKE ONE OTHER COMMENT. YOU KNOW, THAT, UM, I JUST WANT TO EMPHASIZE THAT THE LANGUAGE AND CURRENT PLANNING GUIDE SECTION NINE THAT ALLOWS FOR THE FIS TO BE USED IN PLACE OF THE LILLI STUDIES IS DEPENDENT ON IT MEETING ALL THE REQUIREMENTS OF THE LILLI STUDIES AND IS NOT INTENDED TO ALLOW A LOAD TO BYPASS THE LILLIS PROCESS. IT'S ONLY INTENDED TO PREVENT THE TSP FROM HAVING TO DO ESSENTIALLY THE SAME SET OF STUDIES TWICE. UM, AND SO THE LANGUAGE IN PICKER 1 45 THAT REFERENCES PLANNING GUIDE 9.4 AND 9.5 WAS INTENDED TO CAPTURE THAT SCENARIO, UM, ALREADY, BECAUSE THOSE LOADS STILL HAVE TO MEET THOSE REQUIREMENTS IN PLANNING GUIDE NINE. UM, WE'RE OPEN TO LANGUAGE CLARIFYING THAT FURTHER, BUT WE DON'T SEE THAT AS A SEPARATE LANE. IT'S A LOAD THAT WE, THROUGH LILI THAT IS EFFECTIVELY UTILIZING THAT ONE PROVISION IN 9.3 SOMEWHERE THAT ALLOWS THE TSP NOT TO HAVE TO DO THE SAME STUDIES TWICE. SO I JUST WANNA CLARIFY THAT. YEAH. OKAY. THAT'S GOOD TO HEAR. THANKS. ALL RIGHT. AHI OKAY, GO AHEAD BACK TO ME. THANK YOU. OKAY. SO, UM, JUST TO, UH, MAYBE GIVE A PATH FORWARD ON HELPING ENSURE THAT THE MARKET UNDERSTANDS THE, THE NATURE OF THE BINDING OR REVOCABILITY THAT ERCOT MAY INTEND, UM, AROUND THESE ELECTIONS. UM, THE 5 8 4 8 1 PFP CURRENTLY IN, I THINK THE LAST DRAFT FROM STAFF, AND CORRECT ME IF THEY'VE MODIFIED SINCE, HAS JUST THE, THE WORD CLR IN THEIR PROPOSAL AROUND [02:20:01] WHAT, UM, WHAT BOXES WILL BE TICKED OFF. BUT FROM EVERY CONVERSATION WE'VE HAD ON PIGGER 1, 3, 4 BEFORE BATCH AND EVEN DURING THIS PROCESS, THERE'S BEEN A DESIRE A G AND TEAM THAT I'VE HEARD TO KIND OF CREATE LIKE A BINDING CONTRACT OR ATTESTATION FORM. AND, UM, WONDERING, WE, I THINK THAT ERCOT PROBABLY OR WILL, HAS TO HAVE THE, THOSE TERMS SPELLED OUT IN A WAY THAT THE MARKET CAN CONSUME AND UNDERSTAND. AND THAT ALL NEEDS TO BE WRITTEN ANYWAY BEFORE WE WOULD SEE A FINAL RULE IN 5 8 4 8 1. SO QUESTION IS REALLY TO ERCOT WHERE, WHERE AND HOW OR WHERE CAN WE START NOW SINCE WE HAVE A GENERAL IDEA OF WHAT THOSE, YOU KNOW, ENERGIZATION ELECTIONS WILL LOOK LIKE, START TO REALLY JUST HAMMER OUT A SAMPLE CONTRACT. I'VE TALKED TO OTHERS ABOUT IT, AND I HAVE BEEN TALKING ABOUT HIS NPRR. IT HAS A, YOU KNOW, A DRAFT CONTRACT IN THERE AS WELL. HOW DO WE BE HELPFUL AND ACCELERATE THAT? BECAUSE I DON'T THINK THERE'S A SOUL IN SUPPORT OF THIS PROVISION THAT YOU'RE LOOKING AT ON THE SCREEN WHO THINKS THAT THIS IS AN OPEN GATEWAY TO A BUNCH OF, YOU KNOW, NONSENSE COMMITMENTS INTO THE ER ARCHIVE PROCESS. IN FACT, IT'S QUITE THE OPPOSITE. SO I, I WANNA BE HELPFUL AS THE ORIGINAL SPONSOR OF 1 34 TO CLARIFY ANY OF THAT AT, HEY RUHI, THIS IS A SPRINGER. UM, IT, WE, WE'VE STARTED DRAFTING LANGUAGE FOR THE CLR PIGGER. WE'RE HOPING TO HAVE SOME, SOME OF IT TO SHARE BY MONDAY'S WORKSHOP. UM, AND IT, IT, WE DO INTEND FOR IT TO INCLUDE, UH, AGREEMENTS AS WELL. OKAY. AND, UH, UH, CLAYTON DID DROP A COMMENT, THAT'S ACTUALLY THE END OF MY COMMENT. THANK YOU FOR THAT CLARIFICATION. IN 1 34, JUST REMEMBER THE STRUCTURE OF THAT ORIGINALLY JUST FOR CLRS AND FOR ALL OF THIS WAS THAT YOUR TSP NEEDS TWO BE ACTUALLY VALIDATE THAT NO SPECIAL PROJECTS, VOLTAGE RESOLUTION OR OTHER ISSUES ARE GATING THE SIMPLE ACT OF ENERGIZATION AND MEETING THE 9.5 9.6 REQUIREMENTS. AND ERCOT NEEDS TO BE OKAY WITH THE INTENT TO ENERGIZE THE CLR AND A BINDING CONTRACT. IE SIGNING YOUR NAME ON THE DOTTED LINE NEEDS TO BE AN EXISTING PROVISION OF COMMITMENT. AND THAT COMMITMENT NEEDS TO LAST AT LEAST AS LONG AS THE PERIOD IN THE ORIGINAL LCP THAT WOULD HAVE GRANTED THAT LOAD FULL FIRM SERVICE. SO THERE HAS NEVER BEEN ANY PART OF THIS THAT HAS INTENDED FROM THE DATE OF FILING TO SORT OF JUMP OVER THE NORMAL PROCESSES THAT FIRM LOADS HAVE TO GO THROUGH, INCLUDING THE FINANCIAL AND INTERCONNECTING POSTING REQUIREMENTS. SO ALL OF THAT IS, I THINK, ELABORATING ON, UM, THE ORIGINAL POINT. BUT ABSOLUTELY THESE WILL NOT BE NORMAL CLRS, NONE OF THESE WILL BE NORMAL CONFIGURATIONS AT 1180 EIGHTS IMPLEMENTATION GATES, THE KIND OF CLRS THAT WOULD EVEN BE ALLOWED INTO THIS PROGRAM. POINT BEING, THERE'S A LOT OF COMPLIANCE THAT NEEDS TO HAPPEN IN ADVANCE JUST FOR A PROJECT TO SAY OUT LOUD, WE WOULD LIKE TO BE ACL R. OKAY, THAT'S MY COMMENT. THANK YOU. THANK YOU RUHI. UH, SAM? YEAH, THE LAST THING I'LL SAY HERE ON THIS POINT IS JUST THAT AGENT IS GOING TO FILE PRETTY EXTENSIVE COMMENTS, UM, TO 5 8 4 8 1 ON THIS TOPIC. SO TO THE EXTENT ANYBODY'S INTERESTED IN UNDERSTANDING MORE ABOUT OUR PERSPECTIVE, UM, JUST BE ON THE LOOKOUT FOR THAT FILING. GOOD PUBLIC SERVICE ANNOUNCEMENT. ALRIGHT, SO WHAT I'M GONNA TRY TO DO IS, UM, SO WE'RE GOING THROUGH 21 PEOPLE, NED IS NUMBER 10, AND THEN AARON, I'M GONNA HAVE YOU GO AFTER HIM SINCE WE LOSE YOU FOR PART OF THE AFTERNOON. SO NED, I'LL SEE IF YOUR PRESENTATION POSTED. IT SHOULD BE OUT THERE. YEAH, IT IS POSTED. THANK YOU FOR THAT AS WELL. LET'S SEE. MAGIC. THERE WE GO. ALRIGHT, I TRIED TO GET IT ALL IN ONE SLIDE. I, UH, APPRECIATED ENCORE'S, UH, LEADERSHIP ON THAT. I THOUGHT THAT WAS A GOOD IDEA. SO, UH, APOLOGIES THAT WAS JUST FILED THIS MORNING, BUT, UM, IT'S THERE FOR YOUR PERUSAL. SO, UM, FIRST OF ALL, UH, THANK YOU, UH, ALL FOR FIRST ERCOT FOR PUTTING THIS TOGETHER AND FOR, UH, YOU KNOW, HOLDING THE SPACE FOR THIS DISCUSSION. UM, WE HAD BASICALLY TWO LARGER SUBSTANTIVE ISSUES. ONE IS MORE PROCEDURAL AND THEN A HANDFUL OF OF OTHERS THAT WE WANTED TO FLAG IN OUR COMMENTS. UH, BEFORE I JUMP INTO THAT THOUGH, JUST TO KIND OF KEY OFF THE LAST DISCUSSION WE'RE HAVING, I, I DID LIKE SOME OF WHAT I SAW IN THE ENT RELIANT COMMENTS, UM, SOME OF THE DISCUSSION ABOUT, YOU KNOW, B-B-Y-O-G VERSUS CLR HIGHLIGHTS, UH, YOU KNOW, SOME NUANCES FROM THAT. AND I THINK THE COMMISSION HAD DISCUSSED THAT AT A PRIOR OPEN MEETING AND, AND THAT BYOG IS A SIMPLER SOLUTION IN THAT, UH, IN THAT APPROACH. UM, BUT YOU KNOW, ALSO THINKING ABOUT BARKSDALE'S COMMENTS EARLIER ABOUT, YOU KNOW, IF YOU HAVE SUFFICIENT FINANCIAL REQUIREMENTS, THEN THAT SHOULD REDUCE THE RISK OF COST SHIFTING TO OTHER LOADS. AND SO THAT'S PERHAPS A, A, A COUNTERBALANCE THERE. UM, BUT ANYWAY, JUMPING MORE INTO THE, UH, INTO THESE COMMENTS. [02:25:01] UM, ACTUALLY NO, ONE, ONE OTHER THING THAT I HEARD THERE THAT I WANTED TO POINT OUT AND THAT WAS, UM, YOU KNOW, I WANTED TO EMPHASIZE THAT CONDITIONS ON ELIGIBILITY FOR BATCH ZERO BASED ON PROGRESS UNDER THE CURRENT STUDIES IS A LITTLE CURIOUS SINCE BATCH ZERO ESSENTIALLY IS GONNA BE THROWING OUT STEADY STATE AND STABILITY STUDIES ANYHOW. AND, AND WHAT WE HEARD FROM, I THINK MARTHA SAID EARLIER THIS MORNING WAS THAT THAT WOULD ALSO HAVE IMPLICATIONS FOR THE, THE SYSTEM PROTECTION STUDY. SO, UM, THAT, THAT ONE STOOD OUT TO ME AS WELL AND WANTED TO EMPHASIZE THAT. SO ANYWAY, GETTING TO THESE COMMENTS, UM, FIRST AND FOREMOST, UH, WHAT WE WANTED TO DO WAS HIGHLIGHT THAT THE BATCH FRAMEWORK AND THEN THE, THE RULES THAT HAVE BEEN, THAT HAVE BEEN PROPOSED TO DATE, UM, THEY SEEM LIKE THEY'VE LARGELY FOCUSED ON THE, WHAT WE CALL THE FRONT OF THE METER LOADS, RIGHT? IT'S THE LARGE LOADS THAT ARE CONNECTING DIRECTLY INTO THE TRANSMISSION SYSTEM, WHICH MAKES SENSE GIVEN THAT THAT'S MORE THAN 85% OF THE LARGE LOAD QUEUE. AND WHEN WE TALKED ABOUT THE LOAD FORECASTING RULE, WHICH WAS FIRST UP IN THE PROCESS, WE'RE TALKING ABOUT SYSTEM LOAD THAT SHOWS UP IN THE LOAD FORECAST, NOT OTHER LARGE LOADS THAT ARE STILL INTERCONNECTED BUT NOT NECESSARILY PART OF THE LOAD FORECAST. SO WANTED TO HIGHLIGHT THAT THERE'S PROBABLY A FRAMEWORK THERE THAT MAY HAVE BEEN EXTENDED INTO 5 8 4 8 1 AND INTO BY EXTENSION INTO BIGGER 1 45 THAT, UM, WON'T BE APPLICABLE IN EVERY LARGE LOAD SCENARIO. SO WANTED TO TO HIGHLIGHT THAT DIFFERENCE 'CAUSE THAT IS SOMETHING THAT WE TRY TO ADDRESS IN OUR COMMENTS AND, AND WANNA FLAG. AND WE'LL ALSO HAVE THESE COMMENTS IN IN 5 8, 4 8 1 AS WELL. UM, SO NOW THAT WE'RE, WE'RE EXPANDING INTO THAT, THAT BROADER AREA, UM, OR THAT BROADER APPLICABILITY SET, UM, WE WANTED TO HIGHLIGHT THAT, UH, OR AT LEAST ADDRESS THE PRO, THE P 39, 1 69 APPLICABLE PROJECTS AND OTHER PUN LOADS. UM, AND THE TIMELINES THAT ARE ASSOCIATED WITH THOSE RELATIVE TO WHAT'S IN THE BATCH. AND THEN ALSO SOME FLEXIBILITY AROUND THE TSP AND DSP ROLES, UM, THAT, THAT, UM, SHOW UP IN THERE. SO ON THE 39 1 6 9 TIMELINE, UH, EARLIER KEVIN HAD ASKED WHETHER THE BATCH PROCESS APPLIES TO THOSE AND CHRISTINA, I YOU'D SAID YES. UM, AND THAT'S EXACTLY PART OF THE PROBLEM THAT WE'VE, WE'VE IDENTIFIED IS THERE IS A TIMING ISSUE THERE AND, AND WE TRIED TO THROW TOGETHER A A, IT'S A VERY HIGH LEVEL AND I WANT TO EMPHASIZE VERY SIMPLIFIED, UH, TIMELINE HERE, UM, WHICH IS EVEN STILL SMALL ON THE SLIDE. BUT, UM, WHAT WE'RE TRYING TO HIGHLIGHT IS, YOU KNOW, IN YOUR FIRST, FIRST EXAMPLE, WHICH IS NET METERING ARRANGEMENT, LARGE LOAD ONE, YOU COULD HAVE THE STUDIES COMPLETE AND THEN KICK OFF THE, UM, THE PROCESS AT THE PUC WITH STUDY THERE. AND UM, THEN POTENTIALLY IF YOU'RE ALSO LAYERING ON TOP OF THAT YOUR QSA QUALIFICATION, YOU MIGHT BE ABLE TO GET ENERGIZATION WINDOW, YOU KNOW, PRETTY SHORTLY THEREAFTER. UM, WHICH AGAIN, IF YOU'RE TALKING REAL WORLD, THERE'S USUALLY SOME STEPS IN BETWEEN. IT MAY NOT ALWAYS LINE UP EXACTLY PERFECTLY LIKE THAT. THIS IS JUST TO TRY TO MAKE IT AS VISIBLE ON A SLIDE AS POSSIBLE. UH, THEN SECOND SCENARIO, SAY IT'S A MONTH LATER AND YOU HAPPEN TO FALL INTO THE JULY TIMEFRAME. WELL THERE YOU COULD HAVE THE STUDIES COMPLETE AND THEN STILL KICK OFF THE NET METER ARRANGEMENT STUDIES THROUGH THE, THE CURRENT PROCESS. AND THAT WOULD THEN, UH, POSSIBLY ALLOW, YOU KNOW, EVEN THOUGH IT'S JUST ONE MONTH DELAY IN THE COMPLETION OF THE STUDY, YOU PROBABLY END UP KICKING THE ENERGIZATION WINDOW BACK BY THREE MONTHS TO THE NEXT QUARTER. UM, SO THERE'S ALREADY SOME BLOCKINESS IN IN THE PROCESS BECAUSE OF THAT. AND THEN WE GET TO NUMBER THREE ON THAT EXAMPLE. AND THIS IS, LET'S SAY FOR WHATEVER REASON THAT LARGE LOAD INTERCONNECTION STUDY HAS BEEN, UM, IS NOT INCLUDED IN THE BASE. YOU KNOW, IT'S, IT'S EITHER CONSIDERED INVALID OR IT'S PARTIALLY COMPLETE OR, UH, SOME OTHER, FOR SOME OTHER REASON, IT'S, IT IS FORCED INTO THE BATCH ZERO PROCESS. EVEN THE ERCOT ALREADY HAS ALL OF THE INFORMATION IT NEEDS TO, YOU KNOW, CONDUCT THAT STUDY. WELL THEN YOU'RE GOING THROUGH THE BATCH ZERO ALLOCATION PROCESS AND THEN ALSO THROUGH THE REFINEMENT PROCESS BECAUSE THE WAY THE PIGGER 1 45 STRUCTURES THAT TIMELINE, THE STABILITY STUDY, WHICH IS A LARGE LOAD INTERCONNECTION STUDY ELEMENT UNDER, AT LEAST UNDER THE CURRENT RULES, AND I, I'M PRESUMING HERE, THIS, THIS IS PROBABLY SOMETHING SUBJECT TO TO CLARIFICATION, YOU KNOW, WOULD ERCOT STILL REQUIRE THAT AS PART OF A PRECEDENT, UH, YOU KNOW, CONDITION PRECEDENT FOR A NET METERING ARRANGEMENT APPLICATION OR NOTICE? UM, BUT THAT'S NOT UNTIL 30 DAYS PRIOR TO THE, IT'S KIND OF CONVOLUTED THE WAY IT'S WRITTEN. IT'S LIKE 30 DAYS PRIOR TO THE DATE IN WHATEVER SECTION IT ENDS UP WORKING OUT TO US. BUT THE BEGINNING OF MAY IS, IS, IS ESSENTIALLY WHAT IT SAYS. SO YOU'RE GETTING SEVERAL MONTHS BEYOND THE BATCH ZERO ALLOCATION STUDY BEFORE THAT COMES IN, LET ALONE GETS APPROVED. AND SO IF THAT'S A CONDITION PRECEDENT, THEN YOU CAN'T EVEN START YOUR NET METERING APPLICATION OR, UH, ARRANGEMENT NOTICE IN ERCOT SUBSEQUENT [02:30:01] STUDY UNDER P 39 1 69 UNTIL SIGNIFICANTLY LATER. AND SO WE'RE JUST KIND OF LAYERING ON POTENTIAL DELAYS OR, UH, IN THAT PROCESS, EVEN ASSUMING THE BEST AND MOST EFFICIENT TIMELINE. SO I WANTED TO FLAG THAT AS A CONCERN 'CAUSE WE'VE BEEN TRYING TO, TO RAISE THAT FLAG AND I THINK GIVEN THE FOCUS BEING PRIMARILY ON THESE, YOU KNOW, FRONT OF THE METER, UM, LARGE LOAD INTERCONNECTIONS, IT'S, YOU KNOW, PERHAPS NOT THE THE FRONT FRONT FOCUS, BUT, UM, WANNA WANNA HIGHLIGHT THAT. AND, AND WHY WE FOCUSED ON THAT IS THE, YOU KNOW, THE, THE BIG AREA IN, IN OUR COMMENTS. SO, UM, NOT TRYING TO JUST SAY THIS SUCKS, BUT ALSO HAVE SOMETHING, UH, CONSTRUCTIVE TO, TO PUT FORWARD AS AN ALTERNATIVE. UH, OUR PROPOSED SOLUTION IS THAT, YOU KNOW, WE STILL HAVE THE LEGACY PROCESS IN BIGGER 1 45, IT'S JUST MOVED BACK. AND SO YOU CAN STILL HAVE SOME ANCHOR TO THAT AND, AND USE THAT FOR THE 39 1 6 9 APPLICABLE PROJECTS. UM, WE ALSO THINK IT'S IMPORTANT TO GIVE THE OPTION FOR 39 1 6 9 APPLICABLE PROJECTS TO GO THROUGH THE BATCH PROCESS BECAUSE YOU COULD ALSO HAVE A SCENARIO WHERE ONE OF THOSE IS STUCK IN ONE OF THOSE RE-STUDY DO LOOPS, AND IT MAY ACTUALLY BE MORE EFFICIENT AND AND FASTER FOR THEM TO GO THROUGH THE BATCH PROCESS, GIVE 'EM THE OPTION, BUT NOT THE REQUIREMENT. UH, THAT'S, THAT'S OUR PROPOSED SOLUTION THERE. UM, ON, JUST TO LAYER ON TOP, I HAD THIS IN THE FIRST BULLET AND KIND OF SKIPPED OVER IT, BUT AS WE'RE TALKING ABOUT THE WAY THAT ALL OF THE FINANCIAL SECURITY REQUIREMENTS LAYER UP IN THE PROPOSED RULE, THAT IS THEN PROPOSED, UH, COPIED INTO PICKER 1 45. WE ALSO GET INTO PERHAPS SOME, UH, CALL IT INEQUITY IN THE SCALING UP OF THE FINANCIAL SECURITY REQUIREMENTS RELATIVE TO WHEN THE, UM, YOU KNOW, WHEN THE LARGE LOAD IN A NET METERING ARRANGEMENT SCENARIO 39 1 6 9 NET METERING ARRANGEMENT SCENARIO IS GETTING CLOSER TO ENERGIZATION. THAT'S BECAUSE YOU HAVE THE PUC APPROVAL REQUIREMENT AT THE BACK END. AND SO THERE IS STILL THE ABILITY, I MEAN, YOU COULD TECHNICALLY HAVE THE COMMISSION DENY THE APPLICATION AND THEN YOU'VE, YOU KNOW, PUT UP YOUR FINANCIAL SECURITY, UM, YOU'VE GONE THROUGH THE INTERMEDIATE AND INTERCONNECTION AGREEMENT STEPS AND ALL OF THAT BECOMES NON, OR A LOT OF IT BECOMES NON-REFUNDABLE. WELL, THAT COULD THEN RESULT IN, YOU KNOW, EVEN MORE FINANCIAL OUTLAY THAT'S ESSENTIALLY LOST BECAUSE YOU GET TO THE BACK END OF THE PROCESS. AND SO WANTED TO HIGHLIGHT THAT THERE, YOU KNOW, WHAT MIGHT MAKE SENSE FOR A FRONT OF THE METER PROJECT WHERE IT'S, YOU KNOW, IT'S RATCHETING UP AT THE SAME, YOU KNOW, WITH THE PROCESS IN THESE 39 1 6 9 PROJECTS, THERE'S AN ADDITIONAL STEP AT THE BACK END. AND SO HAVING THE SAME LEVEL OF FINANCIAL SECURITY AT THE, AT THE FRONT END MAY NOT MAKE AS MUCH SENSE, WHICH, YOU KNOW, CONSIDERING THAT THE, THE CO-LOCATED LARGE LOADS WITH EXISTING GENERATION ARE LIKELY NOT GOING TO NEED NEARLY AS MUCH, UH, IF ANY TRANSMISSION UPGRADES, THEN YOU MAY HAVE DIFFERENT RISK PROFILES, UH, RELATIVE TO THE PURELY FRONT OF THE METER, INTERCONNECTING DIRECTLY TO THE TRANSMISSION SYSTEM LOADS. UM, SO THAT'S, UH, WELL, AND ON TOP OF THAT, TO THE EXTENT THAT THOSE FINANCIAL REQUIREMENTS ARE INTENDED TO BE A SIGNAL OF QUALITY LIKELIHOOD TO ENERGIZE, IF YOU'RE TALKING ABOUT INTERCONNECTING BEHIND THE POINT OF, UH, POINT OF INTERCONNECTION WITH AN EXISTING GENERATOR, THAT'S A, THERE'S A FINITE NUMBER OF THOSE. YOU'RE TALKING ABOUT A LONG-TERM RELATIONSHIP. THERE'S A LOT OF VETTING THAT GOES ON ON THE FRONT END WHEN A LAR WHEN AN EXISTING GENERATOR, UM, IS WILLING TO ENTER INTO THAT KIND OF ARRANGEMENT WITH A NEW LARGE LOAD. SO, UM, ONCE THOSE ARE IN THE QUEUE, I THINK YOU CAN GIVE THEM A, A VERY HIGH LIKELIHOOD OF, UH, OF ENERGIZATION AND YOU DON'T NECESSARILY NEED QUITE THE SAME LEVEL OF, UM, CALL IT FINANCIAL DISCIPLINE IN ORDER TO, UH, WEED THAT OUT EARLIER IN THE PROCESS. SO, UM, THAT'S THAT ITEM. UM, NOW ONE LAST POINT ON THAT, WHICH IS, UM, IN ORDER TO CREATE THE SPACE FOR THOSE TO GO THROUGH THE, UH, THE LEGACY PROCESS WHILE STILL REFLECTING THOSE IN THE BATCH, WE PROPOSED ALSO ALLOWING THE, UM, ALLOWING THEM TO BE INCLUDED IN THE BASE LOAD FOR THE BATCH STUDY. SO THAT WAY IT'S ACCOUNTED FOR IN THE STUDY. UM, AND IT'LL GO THROUGH THE APPROVAL PROCESS, UH, THROUGH THE LEGACY STEPS, THE CURRENT, THE BIGGER ONE 15 PROCESS. ALL RIGHT, FROM THERE, NEXT MAIN POINT IS FLEXIBILITY FOR THE FULL DIVERSITY OF LARGE, LARGE LOAD, UH, UH, ARRANGEMENTS AND SPECIF SPECIFICALLY GIVING MORE FLEXIBILITY TO THE DSP AND TSP ROLES. WE DIDN'T TRY TO GET AS SPECIFIC AS, UM, YOU KNOW, ENCORE MIGHT HAVE, BUT WE [02:35:01] JUST TRIED TO LOOK, GO VERY BROADLY AND SAY, LOOK, AS YOU CAN PUT AN AS APPLICABLE IN A LOT OF THESE, AND THAT GIVES YOU LOTS OF ROOM TO ADDRESS THE SPECIFIC, UM, SCENARIOS THAT APPLY DEPENDING ON WHETHER, YOU KNOW, IF IT'S A-B-Y-O-G AND IT'S NEVER, IT'S ALWAYS GOING TO BE A NET EXPORTER. UM, YOU KNOW, THAT'S A SCENARIO WHERE THAT LOAD ISN'T GOING TO BE TAKING, UH, GRID POWER, RIGHT? AND THAT COULD BE WITH AN EXISTING OR A NEW GENERATOR. UH, YOU COULD HAVE, UM, THE, UM, UH, SORRY, LOST MY TRAIN OF THOUGHT. UH, YEAH, YOU COULD HAVE SELF-SERVICE, YOU COULD HAVE SELF GENERATORS, YOU COULD HAVE INCIDENT OF TENDENCY. YOU COULD HAVE AN ELECTRIC GENERATION EQUIPMENT LESSOR OR OPERATOR WHERE IT'S BEING, UH, LEASED IF THERE'S NOT SUFFICIENT, UH, SUFFICIENT INFRASTRUCTURE TO SUPPORT THE LOAD. UH, WE'VE TALKED ABOUT NON SET, THERE'S A NON SETTLED GENERATOR CONCEPT, AND THEN THE EXPORT ONLY BYOG CONCEPT THAT WE'LL PROBABLY GET INTO MORE THIS AFTERNOON. ALL OF THOSE ARE AREAS WHERE YOU MAY NOT HAVE A NET LOAD CONDITION THAT WOULD NECESSITATE A DSP. SO I WANTED TO FLAG THAT IN PARTICULAR. AND, UM, THAT SHOWS UP IN PARTICULAR IN OUR COMMENTS IN SECTIONS 9.71 AND 9.72 BECAUSE THAT HAS IMPLICATIONS FOR THE INTERMEDIATE AND INTERCONNECTION AGREEMENT STEPS. LAST TWO, I'LL BE REALLY FAST ON THESE. UH, THE, THE FIRST ONE IS THE LIMITS ON WHAT WE CAN INCLUDE IN THE PLANNING GUIDES VERSUS WHAT HAS TO GO IN THE PC'S RULE. UM, UNDERSTAND JUST TO BE, YOU KNOW, EFFICIENT AND GET THE WHOLE PFP IN. THERE ARE SOME THINGS IN THERE THAT ARE, UM, YOU KNOW, WERE COPY PASTED. UH, WE DIDN'T TRY TO TO GO THROUGH AND REDLINE THOSE BECAUSE WE DO WANT TO ACTUALLY HAVE TIME TO, TO PUT TOGETHER MORE SUBSTANTIVE COMMENTS ON THE PROPOSED RULE. UM, BUT FOR THE PURPOSES OF THE PIGGER, THINGS LIKE, YOU KNOW, WHAT DO YOU DO WITH THE, UM, WITH THE NON-REFUNDABLE FINANCIAL SECURITY FOR INSTANCE, LIKE THAT, THE RULE PROPOSES THAT GOES AS AN OFFSET TO THE TRANSMISSION COST OF SERVICE FOR THE INTERCONNECTING TSP. THAT'S NOT SOMETHING WE CAN DO IN THE, IN THE PLANNING GUIDES. THAT SEEMS LIKE SOMETHING THAT WOULD BE IN THE, IN THE COMMISSION'S RULES IF, UM, BUT NOT IN THE, IN THE PLANNING GUIDE. SO THAT'S ONE EXAMPLE OF JUST SOMETHING THAT WE'LL NEED TO WORK THROUGH AS A GROUP AND WANTED TO FLAG THAT. SO WE HAVE SPACE TO TALK ABOUT THAT. UM, NOT AT THIS WORKSHOP, BUT PROBABLY IN SUBSEQUENT ONES. AND THEN, UH, BUT WE DID HAVE A COUPLE OF VERY LOW HANGING FRUIT ITEMS THAT WE, WE, WE DID INCLUDE IN THERE. ONE WAS, UM, SENATE BILL SIX IS VERY SPECIFIC IN, UH, SAYING THAT LARGE LOADS HAVE TO, UM, YOU KNOW, PROVIDE NOTICE OF OTHER INTERCONNECTION PROJECTS IN THE STATE THAT IF MOVING FORWARD WOULD RESULT IN THEM PULLING BACK. I, THAT'S ONE THAT I KNOW WAS A SUBSTANTIVE, UH, POINT OF DISCUSSION AND SENATE BILL SIX. AND SO THAT'S ONE WHERE IT SEEMS LIKE THERE'S PROBABLY GOING TO BE A LOT OF, UH, INTEREST IN KE, YOU KNOW, KEEPING THAT LANGUAGE PURE IN WHAT'S ULTIMATELY IMPLEMENTED. UM, SO PUT THAT OUT AS AN EXAMPLE OF JUST TRYING TO LIMIT THE AMOUNT OF EXPANSION ON SENATE BILL SIX REQUIREMENTS. UM, THE OTHER ONE WAS JUST A CLARIFICATION WHERE THE LANGUAGE SAYS THAT THE INTERCONNECTING LARGE IDENTITY WOULD BE GIVING A PROPERTY INTEREST TO THE TSP OR DSP, AND REALLY THAT'S JUST AN EVIDENTIARY ONE. SO WE ADDED IN EVIDENCE OF A PROPERTY INTEREST FOR PURPOSES OF SITE CONTROL. AND THEN THE LAST LIST OF THINGS HERE, THERE'S A, A NUMBER OF MISCELLANEOUS CLEANUPS AND CLARIFICATIONS. ONE, UM, ONE TO HIGHLIGHT IS IN 5.3 0.5, PARAGRAPH FIVE FOR THE QSA DEADLINES AS DRAFTED. IT LOOKED TO US LIKE THAT WOULD PUSH SOME OF THE, THE QSA LOADS THAT ARE ELIGIBLE FOR 2027 ENERGIZATION INTO BATCH ZERO. AND FROM OUR PRIOR DISCUSSIONS, MY UNDERSTANDING IS BATCH ZERO IS FOR 2028 AND GOING FORWARD ONLY. SO WE MOVED ONE OF THE DEADLINES FROM ONE PARAGRAPH TO THE OTHER JUST TO, UH, TRY TO ALIGN FOR THAT, TO ALLOW ALL OF THE 2027 ENERGIZATION LOADS TO BE CONSIDERED IS, UH, BASE LOAD VERSUS, UM, FORCING THE, I THINK IT WOULD'VE BEEN THE FOURTH QUARTER, 2027 LOADS INTO BATCH ZERO. SO TRIED TO ALIGN THAT. UM, ASIDE FROM THAT, THERE WAS ONE AREA WHERE IT LOOKED LIKE TDSP WAS USED INSTEAD OF TSP AND DSP, SO WE JUST TRIED TO MAKE THAT CONSISTENT WITH THE WAY IT'S DONE ELSEWHERE. AND THEN THE LAST ITEM ON HERE WAS, UM, GIVING ERCOT THE OPTION TO SUBMIT THE BATCH ZERO RPG PROJECTS AS EITHER ONE BIG COMBINED, UH, ONE BIG BEAUTIFUL BATCH RPG PROJECT , I LOVE IT, I LOVE IT. STUCK OR, YOU KNOW, JUST A HANDFUL, LIKE TWO OR THREE SUB-REGIONAL ONES. JUST IF THERE WAS, YOU KNOW, YOU GET A LOT OF COMMENTS AND THAT SLOWS THE PROCESS DOWN, MAYBE IT'S EASIER TO SAY, WELL, ALRIGHT, WE KNOW THIS ONE AREA IS GONNA BE FASTER TO RUN THROUGH VERSUS, YOU KNOW, THIS OTHER AREA OR THAT OTHER AREA. THAT WAS IT NOT A REQUIREMENT, JUST TRYING TO GIVE SOME FLEXIBILITY AND, AND MOVE IT FORWARD. SO, UM, [02:40:01] WITH THAT, I THINK IF THERE'S ANY QUESTIONS, HAPPY TO TAKE 'EM. YEAH, ANY QUESTIONS FOR NED? ALRIGHT, Q IS CLEAR. ALRIGHT, THANKS Y'ALL. THANK YOU. ALRIGHT, AARON, A EP. OKAY. HEY GUYS. AARON RASMUSSEN WITH A EP I'M GONNA TOUCH KIND OF ON OUR THREE MAJOR PRIORITY POINTS HERE. THANKFULLY, I THINK MOST PEOPLE HAVE HAVE TALKED ABOUT THESE, UH, THROUGHOUT THEIR COMMENTS, BUT THE FIRST ONE IS JUST AROUND THAT YEAR SIX ASSUMPTION, NOT TO BELABOR THE POINT, BUT JUST THE IDEA THAT RIGHT NOW WE'RE CURRENTLY SUGGESTING BY YEAR SIX AND 2033, THE LOADS WILL BE SET TO THEIR FULL REQUESTED AMOUNTS. IT'S, IT'S UNCLEAR THOUGH, CURRENTLY HOW THE NECESSARY TRANSMISSION UPGRADES TO SERVE YEAR SIX WILL BE DETERMINED AND HOW THOSE UPGRADES WILL BE APPROVED AND INCORPORATED INTO FUTURE BATCH STUDIES. RELYING ON THE EXISTING PROCESS OF THE RTP AND THE RPG FOR IDENTIFICATION AND ENDORSEMENT, UM, OF THESE LARGER, MORE COMPLEX TRANSMISSION PLANS DOES NOT PROVIDE THE CLARITY AND CERTAINTY THAT IS NEEDED FOR THE LOADS TO MAKE FINANCIAL COMMITMENTS. DEFERRAL OF THESE STUDIES AND PLAN DEVELOPMENTS TO FUTURE RTPS OR RPG STUDIES WILL PERPETUATE MANY OF THE ISSUES WE'RE ALREADY FACING TODAY. WE CONTINUE TO BELIEVE THAT THE BATCH STUDY PROCESS SHOULD BE UTILIZED TO DEVELOP A COMPREHENSIVE HOLISTIC TRANSMISSION PLAN THAT WILL ENABLE ALL OF THE REQUESTED LOAD TO BE SERVED IN A RELIABLE MANNER AND THAT THESE PLANS SHOULD BE ACTIONABLE. UM, SO KI KIND OF TAGGING INTO THE END OF THAT ONE. I, I WILL NOTE TOO, THE BATCH REFINEMENT OVERLAPPING WITH SUBSEQUENT BATCHES, UM, IS A BIT OF A CONCERN JUST IN HOW WE BUILD THE NEXT CASE. IF WE'RE ADJUSTING THE CASE BEFORE I, I KNOW ENCORE COMMENTS FOR POTENTIALLY HOW BADGE ZERO COULD BE HANDLED WOULD ADDRESS AT LEAST THE FIRST ITERATION OF THIS. UM, BUT JUST SOMETHING TO KEEP IN MIND POTENTIALLY IF ERCOT COULD GIVE ANY DETAILS ON HOW THEY COULD START BUILDING THE NEXT CASE, UM, DURING A REFINEMENT PERIOD. THE SECOND MAIN POINT, AGAIN, I THINK A LOT OF FOLKS HAVE TOUCHED ON THIS ONE, BUT JUST THE RPG ASPECT. UM, I, I KNOW A EP HAS TWO OUT THERE THAT TOOK A GREAT DEAL OF TIME, UM, TO, TO STUDY AND, AND GET, AND WE, WE DO WANT THOSE TO BE CONSIDERED. UM, WE, WE ADJUSTED THE LANGUAGE FOR THAT JULY 10TH TO BE IN LINE WITH, WITH THE OTHER DATES FOR THINGS TO BE SUBMITTED ON ENCORE ALSO MADE SOME POINTS FOR THAT, THE, THE DIFFERING TIME BETWEEN SUBMITTAL BY MARCH 4TH VERSUS THERE. UM, BUT RPG STUDIES DO IDENTIFY AND EVEN AT TIMES GO BEYOND WHAT LILLI WOULD FOR LOOKING AT THE DIFFERENT LOADS. THE, THE LAST PIECE, UH, WE KIND OF HIT A BIT ON THAT RATE LANGUAGE. AGAIN, I KNOW THAT WAS TOUCHED UPON, UM, BY SOME OF THE DIFFERENT, UH, FOLKS IN HERE. AND SO I, I THINK THERE IS SOME VALIDITY JUST THAT RATE LANGUAGE SHOULD NOT BE IN A PLANNING GUIDE REVISION. UH, UNDERSTAND THAT THAT'S PARTIALLY JUST BECAUSE THE RULE, THE RULEMAKING ISN'T GONNA BE COMPLETED IN TIME. UM, AND THEY, WE NEED SOMETHING TO POINT TO. UH, IT'S JUST NOT GOVERNED BY ERCOT. WE HISTORICALLY HAVE LEFT THOSE OUT. IT, IT COULD BE LESS OF AN ISSUE, ESPECIALLY IF WE, WE KIND OF WORK CLEAN INTO ENCORE'S PROPOSED TRUEUP OF THE BATCH ZERO CUSTOMERS AND, AND ALSO UNDERSTANDING THIS PLANNING GUIDE REVISION IS REALLY JUST FOR BATCH ZERO. AND SO THERE IS NO LASTING, UM, TIMELINE FOR THIS. IT, IT ALMOST SUN SETS ITSELF ONCE THE BATCH ZERO IS COMPLETE. UM, BUT WE DID HAVE SOME DISCOMFORT WITH SEEING KIND OF SOME OF THESE RATE IMPLICATIONS AND OR FINANCIAL TOPICS THAT ARE NOT USUALLY DISCUSSED. UM, JUST ONE, THE ONE OTHER THING THAT I THINK NED TOUCHED ON AND IS REALLY IMPORTANT AND I THINK WE'RE SEEING, UM, AS WELL IS JUST THE DIFFERING, UM, PROCESSES FOR BEHIND THE METER LOADS. I THINK THE RTP IS A GREAT EXAMPLE OF THAT AS WE'RE TRYING TO NAVIGATE IT. UM, WHEN WE [02:45:01] LOOK AT THE FINANCIAL COMMITMENTS AND OR THE DIFFERENT AGREEMENTS THAT WE'RE ASKING TO BE IN PLACE, THOSE VARY GREATLY BETWEEN STANDALONE LOADS AND AND BEHIND THE METER. AND SO ANY CLARITY THAT CAN BE PROVIDED THROUGHOUT THE PROCESS OF WHERE THERE MAY BE DEVIATION, UM, THAT THAT'S ANOTHER GOOD ONE THAT THAT'S NOT IN THERE, MATT, THAT'S JUST SAY AFTER LISTENING TO NED TALK. I KNOW, I KNOW IT'S SOMETHING I WANTED TO POINT OUT, UM, THAT, THAT WE'RE SEEING AS WELL AND, AND STRUGGLING WITH AT TIMES. THAT'S HIGH LEVEL. IT'S ALMOST LUNCH. WE'RE GOOD. VERY GOOD. WE'LL START GETTING FASTER AND FASTER. UM, OKAY. I THINK YOU HAD A QUESTION FROM SHANNON AND THEN BROTH. YEAH, MINE'S REALLY MORE OF A COMMENT, UM, WITH REGARD TO THEIR PROPOSAL ABOUT HOW TO TREAT RPG PROJECTS. FIRST OF ALL, IT'S A LITTLE DIFFERENT THAN WHAT WE SUBMITTED, BUT WE HIGHLY AGREE WITH WHAT AEPS RECOMMENDING HERE AND YOU KNOW, OTHER TSPS LIKE ENCORE MADE SIMILAR THOUGH YET DIFFERENT RECOMMENDATIONS HERE AS WELL. BUT IN OUR PRESENTATION WE'LL COVER AFTER LUNCH, WE THINK THERE'S A EXTREMELY COMPELLING CASE THAT WHAT ENCORE AND A EP ARE RECOMMENDING HERE, UH, NEEDS TO BE UH, IMPLEMENTED. EXCELLENT. ALRIGHT, BROTH. YEAH, I JUST WANNA SUPPORT ERIN'S COMMENTS ABOUT BEHIND THE MIDDLE LOADS AND I THINK IT'S, THESE LOADS GOT APPROVAL WITHOUT ANY UPGRADES AND WE ARE HAVING TOUGH TIME FIGURING OUT HOW TO GET THEM INTO RTP TO SATISFY THE FINANCIAL CRITERIA. SO JUST TO CONNECT BACK TO MY EARLIER POINT, THERE IS TEXT IN THE, IN IN THE BIGGER DRAFT THAT SAYS WILL CONSIDER MINIMUM OF RTP 26 RTP OR THE LCP VALUE SUBMITTED. I THINK IF YOU CONSIDER THESE LOADS, THAT WILL BE ZERO, RIGHT? BECAUSE WE ARE NOT ABLE TO GET THEM INTO 26 RTP. SO I THINK THAT NEEDS TO BE EDITED TO WHATEVER THE CUSTOMER SUBMITS AS AN LCP, SO THAT WAY YOU KNOW THAT THE UPDATED INFORMATION IS THERE. ALRIGHT, THANK YOU, UH, CONSTANCE AND THEN JOEL. GOOD MORNING EVERYBODY. ALMOST LUNCH. UM, CONSTANCE MCDANIEL WYMAN ON BEHALF OF E-T-T-A-P-S-C, UM, JUST I WANT TO JUST TOUCH ON SOMETHING THAT ERIN JUST SPOKE ABOUT AND MAYBE ASK A CLUMSY QUESTION OF BARKSDALE AND CHRISTINA. UM, YOU KNOW, THERE'S A LOT OF DISCUSSION GOING ON ABOUT HOW 5 8 4 8 1 BLENDS TOGETHER WITH PICKER 1 45 AND AS AARON JUST TOUCHED ON, YOU KNOW, BATCH ZERO OR PICKER 1 45 IS ACTUALLY LABELED BATCH ZERO INTERCONNECTION PROCESS. AND SO, YOU KNOW, IS LISTENING TO THE DISCUSSION, I ACTUALLY THOUGHT, WELL IF THIS, IF THIS LANGUAGE IS INTENDED TO SUNSET, DOES IT HAVE ANY EFFECT AFTER BATCH ZERO IS COMPLETE BECAUSE 5 8 4 8 1 IS THE PROCESS MOVING FORWARD THROUGH TIME, AS I UNDERSTAND IT, THE RULE MAKING, RIGHT? BUT IS THIS PIG, ONCE BATCH ZERO IS COMPLETE, DOES IT, DOES THE LANGUAGE CONTINUE TO EFFECTUATE ANYTHING? AND I, I DON'T MEAN THAT TO, TO MAKE IT SOUND LIKE A, YOU KNOW, A LAME DUCK, BUT IT'S A SNAPSHOT IN TIME THAT WE'RE TRYING TO DO, RIGHT? 'CAUSE WE'RE TO USE Y'S EXPRESSION BUILDING THE PLANE AS WE'RE FLYING IT. SO I JUST WANNA KIND OF VERIFY THAT IN CONCEPTUALIZING HOW WE COMMENT HERE ON THIS REVISION AND HOW WE COMMENT AT THE PUC ON THE RULEMAKING, UH, THIS IS BARK SHELL. UM, SO I THINK, I THINK THE SHORT ANSWER TO YOUR QUESTION, WHICH WON'T BE SHORT, UM, IS, UM, THAT YES, THE CONCEPTS THAT WE'RE DEBATING HERE IN THE BATCH ZERO REVISION REQUESTS, UM, AND MAYBE IN BYOG OR CLR STUFF, THEY'RE INTENDED TO SURVIVE CONCEPTUALLY, RIGHT? WE ARE, WE ARE TRYING TO CODIFY A TRANSITION IN A MAJOR PROCESS THAT ERCOT IS CURRENTLY UNDERTAKING AND HAS FOR, SINCE ITS INCEPTION. UM, FOR 30 YEARS ERCOT HAS DONE SERIALIZED TRANSMISSION PLANNING OF PROJECTS. NOW WE'RE TRYING TO TRANSITION INTO BATCH STUDY PROCESS. AND THE RULES THAT ARE BEING DEBATED HERE ARE ABOUT HOW DO WE MAKE THAT TRANSITION WORK. AND SO THE RULEMAKING AT THE PUC IN 5 8 4 8 1 IS SUPPOSED TO HELP ESTABLISH WHAT THOSE PRINCIPLES AND CONCEPTS ARE THAT SHOULD INFORM [02:50:02] THE SPECIFIC PROCESSES THAT GET CODIFIED HERE THROUGH PLANNING GUIDE AND, UH, AND NOTAL PROTOCOL REVISION REQUESTS. THAT BEING SAID, PIGGER 1 45 MAY SUNSET, BUT WE SHOULD USE THAT, THE ARGUMENTS THAT WE'VE HAD HERE, THE RESOLUTIONS THAT WE'VE COME TO AND BUILD ON THAT. BECAUSE IF YOU JUST END UP BAWLING IT UP AND THROWING IT IN THE, IN THE TRASH CAN, LIKE GOOD LORD, WE'RE GONNA HAVE TO DO THIS AGAIN IN, IN THREE MONTHS. PLEASE KNOW. FAIR. THANK YOU. ALRIGHT. UM, JOEL DAVIS AND THEN CHRIS? YEAH, UH, JOEL DAVIS. JUST, UH, MY QUESTION IS PROBABLY MORE FOR ERCOT THAN AARON, BUT IT'S TO THE, TO THE YEAR SIX POINT. SO THE QUESTION IS, ARE THE LOADS THAT ARE ALLOCATED IN BATCH ZERO OR ANY OF THE FOLLOW ON BATCHES IN YEAR SIX, DO THEY GO INTO THE NEXT BATCH AS FIRM? AND IF SO, HOW DO WE HANDLE THAT WHEN THERE WILL BE NO TRANSMISSION PLAN TO SERVE THAT LOAD AND ALL OF A SUDDEN IT'S IN, IT'S IN YEAR FIVE OF THE NEXT BATCH, OR YEAR FOUR, YEAR THREE AS WE MOVE FORWARD IN THIS PROCESS? YEAH, SO THIS, JEFF, YEAH, SO THE, THE PLAN IS, UM, AS, AS DRAFTED, THE, THE PLAN IS THAT, UH, IF THEY MAKE THEIR FINANCIAL COMMITMENT, THEY, THEY WILL BE CONSIDERED FIRM FOR YEAR SIX, UH, WHICH MEANS THAT THEY'RE BASE LOAD FOR, UH, THE, THE UPCOMING BATCHES. THEN WE WOULD DEVELOP TRANSMISSION PROJECTS SIMILAR TO HOW WE DO TODAY. WE WOULD DEVELOP TRANSMISSION PROJECTS TO SERVE THAT LOAD THAT THAT WOULD BE CONSIDERED FIRM LOAD, THAT TRANSMISSION PLANNING IN, IN ITS PROCESSES WOULD DEVELOP TRANSMISSION PROJECTS FOR, RIGHT? BUT I MEAN, IF WE, IF WE JUST LOOK AT BATCH ZERO AND WE USE SOME ROUND NUMBERS, I THINK WE'RE TALKING ABOUT A HUNDRED AND SOMETHING GIGAWATTS, MAYBE HALF OF THAT FALLS INTO YOUR, YOU KNOW, 2032 OR 2033, WHEREVER THAT DROPS. DO WE REALLY THINK WE'RE GONNA DEVELOP A HUNDRED GIGAWATTS WORTH OF TRANSMISSION BEFORE 2033? UM, I, I, I DON'T KNOW THAT I WANT TO DEBATE THE NUMBERS TODAY. UM, BUT WE, WE WILL DEVELOP WHATEVER TRANSMISSION IS NECESSARY TO SERVE THAT LOAD. OKAY. THANK YOU. ALL RIGHT. THANK YOU JOEL AND CHRIS, CHRIS MATOS, GOOGLE, AND THIS DOESN'T FIT NEATLY WITHIN THE COMMENTS ON AEPS, BUT SOMETHING THAT, UH, CONSTANCE HAS IN MY HEAD IS, YOU KNOW, WE DO, WE ARE STARTING TO SEE THE QUESTIONS APPEAR ABOUT WHAT'S AFTER BATCH ZERO IN TERMS OF THE EXPECTATIONS BOTH FROM A 5 8, 4 8 1 PERSPECTIVE, BUT BROADER PROCESS, RIGHT? AND I, AND I UNDERSTAND LIKE THERE IS A WEIRD ONE THING AT A TIME BATCH ZERO FIRST AND THEN WHAT'S THE NEXT AND SUBSEQUENT PROCESS. BUT IT MIGHT BE HELPFUL TO GET GUIDANCE ON WHAT IS THE BATCH PROCESS THAT COMES NEXT AFTER BATCH ZERO, JUST FROM AN ADMINISTRATIVE PERSPECTIVE. BECAUSE MANY OF THE THINGS THAT ARE GOING TO HAPPEN TOO, IN THE LOADS IN THE, IN THE CONVERSATIONS ABOUT, UM, THE REFINEMENT STUDIES AND REALLOCATION, WHICH FOR THE RECORD I'M IN LIZ'S CAMP, THAT THAT NEEDS TO JUST BE LEFT WHERE IT IS. THE ABILITY THEN TO REVISIT THAT CAPACITY IN THE NEXT BATCH IS GOING TO BE THE NEXT QUESTION. AND WHAT ARE THE NEXT ITERATIVE SETS OF BATCHES? AND SO I DON'T THINK WE NEED OBVIOUSLY AN NPRR OR BIGGER TODAY ON THIS, BUT WE MAY NEED TO START HAVING THE DISCUSSION, YOU KNOW, BASED ON ERCOT OWN PRESENTATION, WE KIND OF WANNA START THIS LOOSELY AGAIN SIX MONTHS AFTER WE COMPLETE BATCH ZERO, YOU KNOW, WHAT CAN, WHAT IS THE, LET'S CALL IT BATCH PROCESS 2.0 FOR, FOR FROM AN ADMINISTRATIVE PERSPECTIVE THAT LOOKS AT THE PERPETUITY OF IT. SO I THINK THE TEAM HAS TALKED ABOUT THAT. AS SOON AS WE GET ACROSS THE FINISH LINE WITH THIS, WE KNOW WE HAVE TO TURN RIGHT BACK AROUND AND HIT INTO THIS AND HOW MUCH OF IT WE CAN SALVAGE TO JET, YOU KNOW, IS IT A CARPET COPY OR IS IT CHANGE? AND SO I THINK WE'RE ALL AWARE OF IT AND THAT THIS IS A, A RUSH TO THE JUNE 1ST, BUT THERE'S A LOT OF WORK AFTER THAT FOR THE NEXT BATCH. AND JUST TO BUILD ON THAT, MATT, I THINK WE'VE STARTED WITH A PRESUMPTION, AND I SHOULDN'T SAY WE, IT'S, YOU KNOW, YOU GUYS AT ERCOT ARE THE ONES WHO ARE DOING THE HOVER LIFTING ON THE REVISION REQUEST RATING. BUT, UM, CONCEPTUALLY WE STARTED WITH THIS IDEA THAT, THAT THIS PICKER WAS GOING TO BE BATCH FOREVERMORE, UNDERSTANDING THAT THROUGH THE COURSE OF THESE CONVERSATIONS WE WERE GOING TO LEARN ABOUT ITS FAULTS, POKE HOLES IN IT, FIGURE OUT WHAT WE NEED TO ADJUST FOR THE SHORT TERM AND HOW TO CHANGE THOSE THINGS FOR THE LONG TERM. SO LIKE I SAID [02:55:01] TO CONSTANCE, WE ARE IN THAT PROCESS OF WRITING THE TRANSITION AS WE'RE GOING THROUGH THE TRANSITION. UH, KEVIN, YEAH, JUST QUICK COMMENT BASED ON THE, UH, SLIDE AT LLWG THAT WE SAW WITH THE INCREMENTAL, I GUESS ABOUT 140 GIGAWATTS THAT AG ROLLED OUT. SO THEORETICALLY WE GOT THIS MAGIC HERE THAT WE COULD HAVE YEAR FIVE, UH, SERVING A HUNDRED GIGAWATTS YEAR 6, 250 GIGAWATTS FROM THIS PROCESS. SO AGAIN, BACK TO THAT THING I KEEP ON HARPING ON THE P 1 27 SAWS, ALL 'CAUSE WE HAVE INFANT GENERATION, AGAIN, IT'S THE QUESTION THAT REALITY OF WHAT CAN WE ACTUALLY DO? SO THAT'S ALL. THANK. THANK YOU. ALRIGHT, SO WE ARE GONNA TAKE LUNCH, UH, BACK HERE AT ONE 30 AND WE WILL RESUME, ERIC GOFF WILL BE NEXT UP AND THEN SHANNON CARAWAY IN THE BALANCE OF THE CAST, UH, LEADING UP TO THE BYOG. SO WE HOPE IT'S AN HOUR AND A HALF OF THOSE TO GET INTO THE, THE MEAT OF THE OTHER SIDE. SO WE STAND ADJOURNED UNTIL ONE 30. ALRIGHT, WE WILL GET BACK SORT OF ON TIME, MYSELF INCLUDED. ALL RIGHT, SO ERIC GOFF, IF YOU'RE IN THE ROOM, ERIC GOFF, ARE YOU READY TO, UH, PRESENT YOUR COMMENTS? I'VE NEVER BEEN MORE READY TO PRESENT MY COMMENTS. OKAY. MATT, CAN YOU MAKE SURE, HERE HOLD OFF. I REALIZE I WAS MUTED THERE. SO, UM, I, LET ME CLOSE THIS. ALL RIGHT, FOR THOSE OF YOU JOINING US, WE'RE GETTING READY TO START AGAIN. AND WE'RE GONNA START, UM, IF YOU'RE MONITORING THE DANCE CARD, WE HAVE THE 21 PEOPLE AND WE'RE ON DOWN HERE TO ERIC. THAT'LL BE FOLLOWED BY SHANNON, ANGELA, AND THE BALANCE OF THE CAST THERE. SO GREAT. UM, SO ERIC GOFF ON BEHALF OF THE TEXAS ENERGY BUYERS ALLIANCE, AND WE ACTUALLY FILED TWO SETS OF COMMENTS AND IT WAS A LITTLE BIT OF INTENTIONAL. ONE WAS JUST TO FOCUS ON THE MESSAGING AROUND THE RRP G PROCESS TO MAKE IT EASIER FOR PEOPLE TO JUST LOOK AT THAT ARGUMENT BECAUSE WE THINK IT'S SO IMPORTANT. UM, SO WE TRIED TO ESTABLISH A CORE PRINCIPLE IN THOSE COMMENTS THAT WE CAN APPLY TO DECISIONS AROUND THE BATCH. UM, AND WE ASSERTED THAT CORE PRINCIPLE IS THAT THERE'S A BIT OF AN ECHO. UM, THE, OKAY, GREAT. THE, THE ENTIRE PROCESS NEEDS TO BE THAT THE STATE'S INTEREST IS TO CONNECT LOADS QUICKLY AND RELIABLY AND WITH REGULATORY CERTAINTY. AND THAT, UM, OPPORTUNITY, UM, IS, YOU KNOW, ABSOLUTELY ESSENTIAL. UM, AND WE THINK IT BALANCES EVERYTHING. BUT, UM, THERE'S, THERE'S TONS OF INTEREST IN TONS OF INTEREST IN DATA CENTER DEVELOPMENT AND ECONOMIC DEVELOPMENT, AND WE SHOULD PURSUE THAT AS A STATE. SO THEREFORE, UM, WE THINK THAT ERCOT SHOULD APPROVE THE RPG FILINGS THAT HAVE BEEN MADE, UM, QUICKLY, UM, THAT ARE ALSO SERVING LARGE LOADS. AND I THINK THERE'S ROOM TO FILE, YOU KNOW, POTENTIALLY MORE RPG, UM, STUDIES, UM, AND STILL HAVE THEM PROCEED ON A TIMELIER FASHION THAN THE PROPOSAL THAT'S IN THE BAT ZERO TIMELINE. UM, AND, AND THAT OPPORTUNITY TO APPROVE THOSE RPG PROJECTS AND APPROVE THE, THE LOADS THAT ARE IN THEM BECAUSE THEY'VE GONE THROUGH A THOROUGH STUDY, WE THINK IS, UH, A GREAT ALTERNATIVE, UM, AND SHOULD BE DONE IN PARALLEL. AND THEN SECONDLY, YOU KNOW, OUR MEMBERS ARE ALSO WORKING ON CO-LOCATION AND IN THEIR EXPERIENCE, MANY OF THE SITES THAT ARE DOING CO-LOCATED GENERATION DON'T REQUIRE TRANSMISSION IN THE STUDIES THAT COME BACK FROM ERCOT OR THE UTILITY AND, UM, YOU KNOW, ARE SERVED BY THAT CO-LOCATED GENERATION. SO WE THINK IT'D BE GREAT FOR UTILITIES TO BE ABLE TO IDENTIFY THESE SITES THAT DON'T REQUIRE SIGNIFICANT MAPS OF TRANSMISSION AND, UM, MOVE THEM FORWARD WITH APPROVAL TO ENERGIZATION AGAIN OUTSIDE THE BATCH IN A TIMELIER FASHION BECAUSE OF THAT PRINCIPLE WE'RE APPLYING. SO THAT'S COMMENT ONE, COMMENT TWO IS THE ONE YOU HAVE UP NOW, UM, WHICH IS, UH, FAIRLY LENGTHY, BUT I'LL TRY TO MOVE QUICKLY. UM, SO WE WOULD REALLY LIKE CLARITY FOR WHAT HAPPENS TO LOADS AFTER BAT ZERO. UM, THERE'S [03:00:01] A SIGNIFICANT AMOUNT OF LOADS, UM, SOME OF WHICH YOU KNOW, ARE OUR, UH, MEMBERS LOADS THAT, UM, DIDN'T MAKE THE CUT IN THESE DRAFT RULES AND THE DRAFT RULES ARE SO TO CHANGE. SO THEY MAY, WE WILL SEE WHAT HAPPENS, BUT HAVING A CLEAR SENSE OF WHAT LOADS CAN EXPECT AND GIVING THOSE LOADS SOME DEGREE OF REGULATORY CERTAINTY MIGHT MAKE THEM, UM, YOU KNOW, SATISFIED WITH KNOWING THAT THEY CAN WAIT AND NOT HAVE TO TRY TO CHANGE THE BATCH ZERO PROCESS BECAUSE THEY DON'T KNOW WHAT WILL HAPPEN TO THEM IF THEY DON'T MAKE IT. SO WE HOPE THAT THAT SOME CLARITY AROUND LIKE PRINCIPLES TO APPLY. OBVIOUSLY CREATING BATCH ONE AT THE SAME TIME IS CREATING BATCH ZERO WILL BE DIFFICULT, YOU KNOW, BUT ANY LEVEL OF REGULATORY CERTAINTY I THINK WOULD BE HELPFUL TO HAVE PEOPLE ACCEPT WHAT'S IN BAT ZERO. UM, AND UM, WE ALSO THINK THAT THE BATS THE OCEAN INCORPORATE SOME, SOME OF THESE CURRENT RPG PLANS AS BASE LOAD. THAT TIES INTO OUR EARLIER COMMENTS. UM, BUT THE SOONER THOSE ARE APPROVED, YOU KNOW, THEN THEY CAN BE CONFIDENT THEY'D BE INCLUDED IN BASE CASES. UM, WE'RE CONCERNED ABOUT SOME OF THE LANGUAGE AROUND THE LESSER OF RTP WITH SLOW COMMISSIONING PLAN. UM, IF THE LOAD COMMISSIONING PLAN IS LARGER AND THEY POST FINANCIAL SECURITY IN THE BATCH THEN, YOU KNOW, THAT SHOULD BE AN ALTERNATIVE TO THE RTP REQUIREMENTS, AND WE SHOULD STUDY THE AMOUNT THAT COULD, YOU KNOW, RELIABLY BE SERVED AND MEET THE BATCH, UH, FINANCIAL REQUIREMENTS. UM, I KNOW THERE'S BEEN SOME CHANGE RECENTLY DISCUSSED TO THIS SECTION, UM, BUT YOU KNOW, IN SOME DRAFTS, 9.2 0.1 0.4, PARAGRAPH THREE, SUBPARAGRAPH B WOULD ALLOW ERCOT TO INVALIDATE STUDIES BASED ON LIKE THE LIST. AND IF YOU'VE IMPACTED LOADS THAT ARE CHRONOLOGICALLY BEFORE YOU IN THAT LIST, AND, AND EVEN WITH SOME OF THE REFORMS, I THINK THAT IS STILL, UM, IN PLACE, WE WOULD PROPOSE AN ALTERNATIVE, WHICH IS TO CLEAR UP ANY NEED FOR UD OF THOSE LOADS THAT COULD INVALIDATE THEM BY INSTEAD JUST PUTTING THEM THROUGH THE BATCH PROCESS WITH ALL THOSE LOADS. UM, AND, UM, AND INVALID STUDY HAS AN OPPORTUNITY TO BE CURED IF IT MEETS ALL THE OTHER CRITERIA IN THE BATCH PROCESS. AND THAT IN INVALIDATION COULD POTENTIALLY LEAD TO KIND OF UNCERTAIN OUTCOMES, WHICH WE HAVEN'T DONE IT YET, AND WE DON'T KNOW HOW MANY LOADS IT WOULD INVALIDATE. UM, SO IN OTHER WORDS, THAT CREATES A HIGH DEGREE OF UNCERTAINTY AROUND WHAT'S IN THE BATCH PROCESS BECAUSE WE DON'T KNOW HOW PEOPLE, PEOPLE'S PROJECTS WILL FALL OUT OF THAT CRITERIA. SO EVEN IF YOU THINK YOU UNDERSTAND EVERYTHING ELSE IN THE BATCH PROCESS, NOT UNDERSTANDING THAT IS A, A KEY RISK. UM, SO THERE ARE SEVERAL SECTIONS THAT, OR PROVISIONS THAT GRANT ERCOT SOLE DISCRETION. AND, YOU KNOW, I UNDERSTAND THAT SOLE DISCRETION IS, UM, YOU KNOW, A TERM OF ART THAT'S USED, YOU KNOW, WITH SOME REGULARITY, THE ERCOT PROTOCOLS AND PLANNING GUIDES. UM, WE'D PREFER FOR WHERE POSSIBLE WE REPLACE THAT SOLE DISCRETION IN THIS PIGGER WITH CLEARLY DEFINED CRITERIA FOR HOW ERCOT WOULD ACTUALLY MAKE THE CUT. JUST AGAIN, BECAUSE THERE WAS, YOU KNOW, SUBSTANTIAL POTENTIAL IMPACT TO PROJECTS THAT, UM, YOU MIGHT THINK YOU MAY MEET THE CRITERIA AND DUE TO THIS WHOLE DISCRETION LANGUAGE, YOU MIGHT NOT. BUT IF WE COULD REPLACE IT WITH CLEAR CRITERIA THAT WOULD, IT WOULD BE A BLACK AND WHITE UNDERSTANDING AS TO WHY YOU DID OR DID NOT MAKE THE CUT. UM, THERE'S ALSO A MENTION OF A REQUIREMENT TO, UM, HAVE THE INTERCONNECTING LOAD, UM, PROVIDE INFORMATION ABOUT THEIR POWER PROCUREMENT, UM, AS YOU KNOW, POTENTIAL FOR INCLUSION IN THE BATCH, UM, TBA. AND, YOU KNOW, HISTORICALLY OTHER CUSTOMER GROUPS ARE JUST FUNDAMENTALLY OPPOSED TO REQUIREMENTS TO SHOW CONTRACTS AS PART OF THE INTERCONNECTION PROCESS FOR MANY OF THE SAME REASONS THAT, YOU KNOW, THOSE SIMILAR GROUPS WERE OPPOSED TO THE LSE OBLIGATION. UM, IT HITS THE, THE SAME CORE PRINCIPLES. UM, THE COMPETITIVE RETAIL AND WHOLESALE MARKETS ARE ABSOLUTELY CRITICAL TO TEXAS SUCCESS. AND, YOU KNOW, IMPOSING CONTRACTOR REQUIREMENTS ON CUSTOMERS, UM, GOES AGAINST THE MARKET DESIGN. UM, [03:05:01] LOTS OF PEOPLE HAVE ALREADY REFERENCED THE FACT THAT TBA, I MEAN, EXCUSE ME, THE, THE PIGGER 1 45 AND THE PROJECT 5 8 4 8 1 OVERLAP. SO I'M GONNA CUT SOME OF MY COMMENTS SHORT AND INSTEAD JUST FOCUS PRIMARILY ON IF THERE'S ANY POTENTIAL UNINTENDED CONSEQUENCES FROM RELYING ON THAT, WHERE IT COULD BE POINTED TO IN THE FUTURE AS A PRECEDENT. UM, YOU KNOW, IF THE, YOU KNOW, IF IN THE FUTURE THE ERCOT PROTOCOLS, UM, WERE UPDATED WITH LANGUAGE THAT IS ABOUT A SECTION OF REGULATIONS THAT THE COMMISSION HOLDS NEAR AND DEAR, WE COULD, SOMEONE COULD POINT TO THIS IN THE FUTURE TO SAY THAT IT'S, IT WOULD BE ALLOWABLE TO TO DO SO, UM, POTENTIALLY. AND SO WE JUST, I THINK, SHOULD BE THOUGHTFUL ABOUT THIS. I UNDERSTAND THE TIMING OF ISSUES AND WHY IT'S BEING DONE. UM, TO REFERENCE, UM, ONE OF THE TOP THREE COMMENTS FROM THIS MORNING, I HAVE A SUGGESTION ON HOW TO SLICE CATS BARKSDALE, UM, WHICH IS, UM, UM, , UH, W WE, UH, DO THINK THAT, UH, A MINIMUM TRANSMISSION CHARGE, UH, ALLEVIATES A LOT OF THE CONCERNS AROUND FINANCIAL SECURITY BECAUSE YOU'LL BE COLLECTING, UH, TRANSMISSION DOLLARS OVER TIME IN THE SAME WAY THAT WE'VE ALWAYS COLLECTED TRANSMISSION COST DOLLARS AND WE DON'T HAVE TO REINVENT THE WHEEL OR, YOU KNOW, HAVE ARGUMENTS ABOUT WHAT YOU KNOW IS, UH, A QUALIFYING, UM, TRANSMISSION LINE, YOU KNOW, THAT SHOULD GO IN KAYAK VERSUS NOT. IT'S ALL PAID FOR IN TRANSMISSION COSTS. AND IT ALSO, UM, PAYS, YOU KNOW, THE RATE BASE COSTS AS WELL THROUGH TRANSMISSION COSTS IN THE SAME WAY THAT IT'S ALWAYS HAPPENED THAT WAY. SO FOR THIS AND MANY OTHER REASONS, WE DO THINK THAT THIS MINIMUM TRANSMISSION CHARGE, UM, IN FOUR CP OR WHATEVER REPLACES FOUR CCP IS, UM, AN ELEGANT WAY TO DEAL WITH SOME OF THE FINANCIAL ISSUES THROUGHOUT SB SIX LIMITATION. UM, AND, UH, FINALLY, TIBA BELIEVES THAT THE QUALIFYING CRITERIA FOR INCLUSION, THE BASE LOAD WITH LARGE LOAD TO THEIR REQUEST ORGANIZATION DATE ON OF AVOID DECEMBER 31ST, 2027, SHOULD BE REVISED TO PROCURING LONG LEAD TIME, HIGH VOLTAGE EQUIPMENT, EG TRANSFORMERS, AND RATHER THAN ALL NECESSARY HIGH VOLTAGE EQUIPMENT, UM, BECAUSE I THINK THE FOCUS OF SB SIX WAS ON LONG LEAD TIME AND NOT ALL NECESSARY, UM, AND THE REQUIRE THAT THE CUSTOMERS INITIATED SITE PREPARATION RATHER THAN HAVING BEGUN SITE PREPARATION AND CONSTRUCTION, UM, THE CONSTRUCTION ELEMENTS, YOU KNOW, COULD BE BETTER DEFINED. AND I HAVE, I HATE TO CREATE A WEIRD INCENTIVE TO CREATE A SHORTAGE ON EARTH MOVERS AS THE NEXT THING THAT WE HAVE IN OUR SUPPLY CHAIN BECAUSE THESE REQUIREMENTS, AND THAT WAS A JOKE JUST TO END THINGS. UM, ALL RIGHT. I APPRECIATE, UH, THE OPPORTUNITY TO SPEAK AND, UM, WOULD WELCOME ANY THOUGHTS OR, YOU KNOW, FOLLOW UP DISCUSSION WITH PEOPLE. THANK YOU. THANKS, ERIC. ANY QUESTIONS FOR ERIC? SO, UM, ERIC, ERIC DOES JEFF, JUST ON THE 0.4, UM, WHAT, WHAT YOU PROPOSE THERE, I FEEL LIKE WE'VE DONE IN THAT IF YOU'RE, I, I THINK IF YOUR STUDIES ARE INVALID, THEN THAT MEANS YOU'RE NOT, YOU DON'T GO IN AS BASE LOAD, BUT YOU, YOU, YOU CAN QUALIFY TO BE STUDIED, RIGHT? WHICH SEEMS LIKE THAT'S MEET WHAT YOU'RE ASKING FOR HERE, BUT I I, WELL, IF, UH, IF THE LOAD, UM, ISN'T FIRM, YOU KNOW, AND IS, YOU KNOW, REAPPORTIONED, THEN YOU COULD GET LESS THAN WHAT YOU ASKED FOR. AND SO IF THROUGH NO FAULT OF YOUR OWN A LOAD WASN'T STUDIED PREVIOUSLY, UM, YOU KNOW, THAT MAY HAVE HAPPENED TO SOME UNCERTAIN DEGREE OF TIME, YOU KNOW, OF TIMES, EXCUSE ME. UM, I DON'T MAYBE OFTEN AN ANALYSIS ABOUT HOW OFTEN THIS WOULD TRIGGER, BUT THIS COULD BE SOMETHING THAT REDUCES PEOPLE'S EXPECTED, UM, YOU KNOW, APPROVAL AMOUNTS. AND, UM, BECAUSE WE'RE DOING A BATCH STUDY, IT SEEMS UNNECESSARY TO DO BECAUSE YOU CAN STUDY IT WITH ALL OF THE OTHER LOADS THAT YOU KNOW OR ALSO INCLUDED. AND SO THERE'S NO NEED TO INVALIDATE STUDIES BECAUSE YOU CAN STUDY ALL THE, THE RELEVANT LOADS IN THE BATCH TOGETHER. YEAH. BUT, BUT IT'S, WELL, BUT YOU'RE, IF YOU'RE DOING THAT STUDY THEN, THEN YOU ARE, [03:10:01] SO, SO WHAT I THINK I HEAR YOU SAYING IS, OKAY, YOU, YOU HAD A STUDY AND NOW WE'VE DETERMINED THAT IT'S NO LONGER VALID BECAUSE THE STUDY DIDN'T INCLUDE SOME OTHER LOADS, RIGHT? SO TO ASSESS THAT, WE, WE HAVE TO SEE, OKAY, WELL HOW MUCH CAN WE SERVE? AND SO MAYBE YOUR PREVIOUS STUDY SAID 500, BUT NOW IT'S DOWN TO 400 BECAUSE THERE'S OTHER LOADS. I THINK THAT IS WHAT THE BATCH STUDY WILL DO FOR THOSE LOADS AS, AS DRAFTED AND INCLUDING CREATE A, CREATING A TRANSMISSION PLAN TO SERVE THAT LOAD, RIGHT? YES. UM, MAYBE I SHOULD ASK A FOLLOW UP QUESTION LATER, BUT IF THAT'S THE CASE, THEN I'M NOT SURE I UNDERSTAND THE POINT OF THIS STILL SINCE IT, THE BATCH PROCESS WILL DO THAT. WHY, WHY DO YOU NEED TO INVALIDATE STUDIES? IT'S, UM, SO THE, THE PURPOSE IS IF I WANT TO COUNT A LOAD AS BASE LOADS MM-HMM . IT'S FIRM, I, I NEED TO KNOW THAT I CAN RELIABLY SERVE THAT LOAD, RIGHT? AND, AND SO THAT IF I CAN, IF I HAVE A STUDY THAT SHOWS, YEAH, WE, WE, WE CAN RELIABLY SERVE THIS LOAD, THEN THAT SUING TO MEET THE OTHER CRITERIA THAT THAT LOAD CAN GO INTO THE BASE LOAD. IF IT WAS STUDY PREVIOUSLY AT 500 AND THAT WAS OKAY, THEN YOU, YOU'RE 500. BUT IF I CAN'T RELY, IF, I DON'T KNOW BECAUSE I'VE HAD SOME OTHER CHANGES, AND SO I DON'T KNOW IF THAT STUDY'S STILL VALID, THEN I NEED TO GO INTO BATCH ZERO AS POTENTIALLY REALLOCATED. UM, I GUESS DEPENDING ON WHAT ACTIVITY THE LOADS HAVE TAKEN BASED ON THEIR PRIOR BELIEF THAT THEY WERE, YOU KNOW, HAD APPROVED STUDIES, THAT THAT COULD BE POTENTIALLY PROBLEMATIC. AND THAT'S KIND OF ONE OF THE REASONS WE'RE PUSHING BACK IS IT'S POSSIBLE THAT SOME PEOPLE HAVE STARTED TO, YOU KNOW, TAKE ACT, DO ACT ACTIVITIES BASED ON WHAT THEY BELIEVE WAS AN APPROVED LOAD. AND THAT GETS BACK TO THE SAME POINT I BROUGHT UP IN OTHER CONTEXTS. OH, I UNDERSTAND. OKAY. YEAH. ALL RIGHT. ANY OTHER QUESTIONS FOR ERIC? NO. ALRIGHT. THANK YOU ERIC. SO DID THAT ADDRESS TBA B ALSO? YEAH, I, YEAH. ALRIGHT, I MOVED QUICKLY. YEAH, THERE WE GO. ALRIGHT, SO WHEN ANGELA, OH, I'M SORRY, SHANNON WAS NEXT HERE. THIS IS, CAN WE PULL UP THE PRESENTATION? YEAH, GIMME A SECOND HERE. AND A PRESENTATION WAS POSTED THIS MORNING THAT WE WILL FLIP OVER TO AND SURE. THERE YOU GO BUD. AND YOU HIT THE, HIT THE THREE. THERE YOU GO. WHAT DO I, SHOULD I GO LIKE YEAH. ARROW DOWN. ARROW DOWN. ALRIGHT, VERY GOOD. I WANNA START OFF BY SAYING WHAT SEVERAL OTHERS HAVE SAID, BUT I DEFINITELY MEAN IT. WE REALLY APPRECIATE HOW HARD ERCOT HAS WORKED ON WHAT'S QUITE HONESTLY A CRAZY CHALLENGING PROBLEM. SO PLEASE KNOW THAT AT LEAST FROM OUR PERSPECTIVE, WE MEAN THAT, AND WE APPRECIATE ALL THE HARD WORK YOU'VE DONE ON THIS. SO IF THERE'S THINGS WE'RE GONNA COVER THAT ARE CRITIQUES OF IT, IT'S NOT THAT WE'RE LESS THAN TOTALLY APPRECIATIVE OF ALL THE HARD WORK. SO IN OUR LARGE LOAD WORKING GROUP MEETING THAT WE HAD A COUPLE OF, UH, WEEKS AGO OR A WEEK AGO THIS PAST FRIDAY, YOU KNOW, ONE OF THE SLIDES THAT, UH, AG HAD SHARED THAT, AND I MADE SOME COMMENTS ON THAT DAY, IS THIS WAS FROM THE MARCH T REPORT AND I'VE TITLED THIS DIMENSIONALIZING THE SCOPE OF THE CONCERN, OR AT LEAST OUR CONCERN. YOU KNOW, OVER THE 11 MONTHS THAT WE'VE HAD THE P ONE 15 PROCESS IN PLACE, WE'VE ONLY REALLY HAD 3,710 MEGAWATTS MOVE THROUGH THE PLANNING STUDIES APPROVED PROCESS. AND AS SOME, AS REPRESENTING ONE OF THE LARGE ILES THAT MOVE THROUGH THAT PROCESS. IT WAS 10 GRUELING MONTHS FOR US WITH SO MANY, WE NOW UNDERSTAND A LOT OF ERCOT CONCERNS THAT WE, IN WAYS WE DIDN'T. AND THEN QUITE HONESTLY, WE JUST HAPPENED TO BE DUMB LUCKY, FORTUNATE WE WERE OFF OVER BY OURSELF AND IT WAS STILL TOOK THAT LONG TO GET, GET THROUGH THERE. SO THAT'S, YOU KNOW, ONLY AVERAGING 337 MEGAWATTS A MONTH OVER THAT PERIOD. AND IF YOU TAKE THAT AND PROJECT IT OUT ANOTHER FOUR OR FIVE MONTHS TILL JULY, VERY LITTLE, NOT MORE THAN FIVE GIGS IS GONNA GET THROUGH THIS. UH, AT LEAST BASED ON WHAT WE'VE BEEN SEEING. AND THE [03:15:01] APPROVED ENERGIZED PIECE WAS ONLY ABOUT 2,168. SO I'VE SAID HERE, THE KIND OF TAKEAWAY ON THIS, THIS SLIDE ILLUSTRATES FOR US AT LEAST HOW WOEFULLY INEFFECTIVE OUR CURRENT BIGGER ONE 15 PROCESS IS. IT'S NOT TRYING TO BE DISRESPECTFUL OF IT, IT IS WHAT WE HAVE AND IT'S NOT MOVING MEANINGFULLY ANYTHING THROUGH. IF YOU LOOK AT ANOTHER SLIDE FROM THAT SAME PRESENTATION, AND THIS IS ONE THAT WAS SLIDE 11 IN THE MARCH TAC REPORT, AND LOOK AT JUST THE NOTICE, YOU KNOW, THE NO STUDIES SUBMITTED PIECE, ONE OF THE QUESTIONS I ASK AT THE LARGE LOAD WORKING GROUP MEETING IS HOW ABOUT ALL THE RPG PROJECTS? ARE ANY OF THAT, THAT LOAD INCLUDED IN HERE? AND MY UNDERSTANDING WAS NOT UNLESS THEY'RE MOVING THROUGH THE PIER ONE 15 PROCESS. SO IF I'VE MISUNDERSTOOD THAT, WHICH I'M PRETTY SURE I'VE NOT, THEN IT'S FUNDAMENTALLY ONE OF THE REAL KEY ISSUES HERE. 'CAUSE YOU CAN SEE WE'VE GOT 30 GIGAWATTS JUST BETWEEN NOW AND END OF 27 THAT, THAT ARE IN THIS NO STUDY SUBMITTED. BUT IF WE GO, AND I GUARANTEE IF WE COULD GO AND DISSECT THIS, AN AN EXTREMELY LARGE AMOUNT OF THIS TYPE OF THING IS OVER IN RPG PROJECTS THAT HAVE BEEN SUBMITTED. AND THAT GETS WORSE IN 28TH OR 60 GIG. YOU CAN READ IT. BUT THE KEY THING HERE IS THERE'S A LOT OF CAPACITY, A LOT, OR A LOT OF INTERCONNECT REQUESTS, AND THERE ARE MANY OF THEM VERY NEAR TERM THAT IF WE HAVE TO WAIT ANOTHER 10, 11 MONTHS TO GET TO THE BACK END OF BATCH ZERO, IT'S IT'S NOT, AND ESPECIALLY IF THEY ARE IN RPG PROJECTS, UH, THAT ARE OUTSTANDING, THAT'S, THAT'S 10, THAT'S A BIG PROBLEM. SO WITH THIS KIND OF THOUGHT IN MIND, I SPENT ABOUT FOUR OR FIVE HOURS YESTERDAY, I WENT THROUGH EVERY RPG PROJECT THAT I COULD, UH, REVIEW OVER THE LAST, SINCE JANUARY OF LAST YEAR. AND I TRIED TO LOOK AT WHICH ONE OF THEM HAD LARGE LOADS AS THE PRINCIPAL DRIVING FACTOR. I PRETTY MUCH ALWAYS IGNORED TIER THREE, TIER FOUR STUFF REALLY FOCUSED ON TIER ONE AND TWO. SO FOR THAT REASON, I PROBABLY HAVE MISSED SOME THINGS. AND TO THE DEGREE, THIS ISN'T PRECISELY RIGHT, IT WAS THE BEST I COULD DO WITH THE DATA THAT WAS OUT THERE. BUT WHAT I SEE SAW OUT OF ALL THIS IS THERE'S SIX TSPS THAT HAVE 14 RRP G PROJECTS THAT TOGETHER IS ALMOST 51,000 MEGAWATTS OF LARGE LOAD THAT AS I READ PICKER 1 45 AND I LOOK AT THE DATES THEY WERE APPROVED OR SUBMITTED, THEY'RE IGNORED RIGHT NOW. THEY'RE ALL 51 GIGAWATTS WORTH OF LOAD THAT'S IN RPG PROJECTS IS ABOUT TO BE TOSSED. AND YOU GOTTA GO BACK TOO BAD. SO SAD, UH, YOU'RE ABOUT TO GO TO THE BACK OF THE LINE OR GO BACK IN THE LINE, EVEN IF YOU WERE THE LOADS THIS WAS SUBMITTED FOR THAT JUSTIFIED THE VERY TRANSMISSION THAT, UH, THESE TSPS HAVE PUT FORTH. AND YOU CAN KINDA READ THESE, UH, GO LOOK AT 'EM YOURSELF, BUT, UH, I, I REALLY DID MY BEST TO BE HONEST ABOUT WHAT I READ IN THEM. AND IF I'VE MISSED SOMETHING, YOU'RE ONE OF THE TSPS, YOU THINK I'VE MISUNDERSTOOD EXACTLY WHAT YOU HAD, APOLOGIZE FOR THAT. OKAY. WHEN I TOOK THAT 51 GIGAWATTS OF LOAD, I TOOK ANOTHER SLIDE, SLIDE NINE OUTTA THAT SAME MARCH T REPORT, AND I WENT AND LAID IT UP, UH, THE BEST I COULD BESIDES THE, THE TSP LAYOUT HERE, YOU KNOW, UH, CPS AP AND ENCORE, TOGETHER, THOSE THREE REPRESENT 91% OF THE 51 GIGAWATTS TOTAL AND 82% OF THEIR NO STUDIES SUBMITTED IN ERCOT UNDER REVIEW CATEGORIES. NOW, IS IT FOR SURE THAT THESE RPG PROJECTS COVER ALL THAT STUFF? I DON'T KNOW THAT, CAN'T KNOW FOR SURE, BUT WHAT I CAN KNOW IS THERE'S 51 GIGAWATTS OF IT THAT AS P 1 45 IS WRITTEN TODAY IS ABOUT TO BE JUST COMPLETELY IGNORED. AND FOR US, WE FIND THAT TO BE REALLY PROBLEMATIC. SO WHEN WE WROTE OUR COMMENTS, UH, LAST FRIDAY, I DIDN'T HAVE THE BENEFIT OF SEEING EVERYBODY ELSE'S COMMENTS THAT CAME IN LATER. SO I'M GONNA, THESE TWO SLIDES, I'LL TALK ABOUT WHAT WE OBSERVED AND SUGGESTED, BUT THEN I WANNA MODIFY THAT WITH SOME OF THE BETTER IDEAS THAT I THINK COME OUT OF SOME OF THE TSP COMMENTS AND OTHER ILLE COMMENTS. SO CONCERN NUMBER ONE TO US, IF YOU HADN'T PICKED UP ON IT, BUT NOW IT'S EXTREMELY IMPORTANT TO RESPECT AND LEVERAGE THE TREMENDOUS [03:20:01] AMOUNT OF WORK THAT THE TSPS HAVE INVESTED IN DEVELOPING RPG PROPOSALS FOR THESE LARGE LOAD INTEGRATIONS. MOST OF THESE RPG PROPOSALS WERE WORKED ON WELL BEFORE ERCOT ANNOUNCEMENT OF BIGGER ONE 15 EFFECTIVE DATE. YOU SAW A EP MAKE THAT POINT LOUD AND CLEAR IN THEIR COMMENTS, AND I DON'T REMEMBER IF ENCORE DID, BUT IT'S, IT'S ABSOLUTELY THE CASE. YOU CAN JUST LOOK AT WHEN THEY WERE SUBMITTED. AND ON THE CURRENT, UH, PATH WE'RE ON WITH PICKER 1 45, ALL OF THAT'S ABOUT TO BE WASTED. EACH OF THE TSPS WHO COMMENTED, UH, AT LEAST CENTER POINT ENCORE AND A EP, THERE WAS TWO KEY THEMES CENTER POINTS WAS REPLACE THE ERCOT SOLE DISCRETION WITH ONE OF COLLABORATION WITH THE T-S-P-D-S-P ENCORE. THEIRS WAS FOCUSED ON EXTENDING THE RPG ACCEPTANCE AND ERCOT ENDORSEMENT OUT TO JULY 10TH, 2026, WHICH I THINK COULD BE HELPFUL. BUT GIVEN IT TOOK ERCOT 15 OR 13 PLUS MONTHS TO GET THROUGH 25 RPG 0 0 4, IT'S KIND OF DOUBTFUL THAT THAT THAT ALONE THAT ASK ALONE'S ENOUGH A EP, THEY EMPHASIZED ERCOT COLLABORATION MUCH LIKE CENTERPOINT AND WITH INTER, UH, WITH THE ERCOT COLLABORATING WITH THE INTERCONNECTING TSPS DSPS AND EXTENDING THE WINDOW FOR RPG SUBMISSION OUT TO JULY 10TH. SO FOR THIS REASON, OUR RECOMMENDATION WAS NOT BECAUSE THEY MADE IT, BUT WHEN WE MADE IT ORIGINALLY, WE SUGGESTED THAT AT A MINIMUM, AND THIS IS REALLY LESS OF AN ASK THAN EACH OF THE TSPS ASKED FOR, IS THAT WE THINK ANY RPG SUBMITTED BEFORE MARCH 4TH, THIS IS THE MOST CONSERVATIVE WE COULD COME UP WITH. AND EVEN THAT'S MORE CONSERVATIVE THAN I'VE EVER SEEN US BE BEFORE ON ANYTHING. A LARGE LOAD THAT CONTRIBUTES, UH, CONTRIBUTED TO ESTABLISHING THE RELIABILITY FOR THESE. AND THEN I PUT AN AND IN HERE TRYING TO BE RESPONSIVE TO ERCOT, THE PUC STAFF, ANYONE ELSE WHO THINKS THERE'S POTENTIALLY NOT REAL LOADS IN THERE, THEN FINE GO, GO APPLY ANOTHER SCREEN AND AT LEAST LOOK AT DID THEY MEET THE 56,480 REQUIREMENTS AND GOT INCLUDED IN THE 2026 RTP. WE'RE NOT EMOTIONALLY MARRIED TO THAT, BUT WE'RE TRYING TO PUT THAT ON THE TABLE AS A WAY TO ADDRESS THOSE CONCERNS. TO THE DEGREE THE ONES THAT ARE REQUIRED, THE PC STAFF NEEDS TO BE, THINK, NEED TO BE ADDRESSED. OUR SECOND CONCERN, UM, AND IT'S REALLY KIND OF ONE A ONE B, UH, IT'S, WE THINK IT'S HIGHLY BENEFICIAL TO LEVERAGE THE UPCOMING 2026 RTP AS A WAY TO ACCELERATE THE INTEGRATION OF LARGE LOADS THAT CONTRIBUTE TO ESTABLISH IN THE RELIABILITY NEED FOR THESE RTP PROJECTS. ALL THE LARGE LOADS IN THE 2026 RTP THAT'S ABOUT TO KICK OFF, THEY MEET THE HIGHER STANDARD OF PUC 54, 4 80 HAS MUCH HIGHER REQUIREMENTS THAN WHAT'S EXISTED BEFORE THAT. AND IT'S MEANT TO BE AS COMPLIANT AS POSSIBLE WITH 58 41 AT LEAST AS IT WAS IN THAT RULE 20. THE 2026 RTP IS CALENDARED SUFFICIENTLY AHEAD OF THE START OF BATCH ZERO THAT IT WILL IDENTIFY ALL NEEDED TRANSMISSION UPGRADES REQUIRED TO SERVE 58 480 COMPLIANT LARGE LOADS. UM, I MEAN THAT'S JUST BY DEFINITION WHAT IT HAS TO DO. AND FOR ANY LEGACY INTERCONNECTION AGREEMENTS THAT HAVE MET THE REQUIREMENTS OF SECTION NINE 10, UH, WHICH WAS THE OLD 9.5 AND HAVEN'T SIGNED INTERCONNECT AGREEMENT, AND THIS HERE AGAIN, US LAYING SOMETHING OUT TRYING TO BE AS RESPONSIVE TO ERCOT AND PC STAFF CONCERNS AND ALSO MET THE 2026 RTP, THERE SHOULD BE NO REASON NOT TO INCLUDE THOSE AS BASE LOAD IN BATCH ZERO. ERCOT PREVIOUSLY THEMSELVES RECOGNIZED THE VALUE OF UTILIZING THE RTP BACK IN THEIR FEBRUARY 3RD PRESENTATION. YOU KNOW, LATER THAT WAS WHEN THERE WAS A BATCH ZERO, A ZERO B, AND UH, SINCE THEN THAT'S BEEN REMOVED. BUT ERCOT HAS PREVIOUSLY SEEN THE VALUE OF RELYING ON RTPS. SO FOR THIS REASON, OUR SECOND COMPONENT OF, UH, RECOMMENDATION IN OUR COMMENTS IS THAT INCLUDE BASE LOAD IN SECTION 9.2 0.1 0.4 LOADS THAT MEET THE SECTION NINE POINT 10 REQUIREMENT. SO THEY HAVE A FULL SIGNED INTERCONNECT, THEY ARE COMPLIANT WITH THAT AND THEY WERE INCLUDED IN THE 2026 RTP. SO THEY'VE MET THE HIGHER 58 4 80 REQUIREMENT. [03:25:01] WE'RE NOT EMOTIONALLY MARRIED TO THAT LAST ONE, BUT IF, IF YOU THINK THAT'S A CONCERN, THAT'S THE WAY TO ADDRESS THAT. SO OUR CONCLUDING ASK AND TRYING TO ADDRESS ERCOT CONCERNS BECAUSE WE'VE HAD, YOU KNOW, ONE-ON-ONE OR NOT ONLY GROUP MEETINGS, BUT ONE-ON-ONE CONVERSATIONS WITH ERCOT ABOUT THIS. AND THE CONCERN, THE ONE AND ONLY CONCERN THAT WE'VE UNDERSTOOD PREVIOUSLY THAT SEEMED VALID, UH, THAT DEFINITELY DID NEED TO HAVE A WAY TO BE RESOLVED, IS THAT LARGE LOAD RPG, THESE PROPOSALS, THEY DETERMINED AN END STATE, UH, YEAR 20 30, 20 31, WHATEVER THE END STATE YEAR IS THAT WAS STUDIED. BUT THEY DON'T INCLUDE ALL THE INTERMEDIATE QUARTER SLASH YEAR LOAD SERVING CAPABILITY. THEY DON'T INCLUDE THE RAMP THAT WENT IN BETWEEN THAT WHERE YOU ARE TODAY. AND THE END STATE SAID DIFFERENTLY, THERE'S STILL A NEED FOR A LOAD COMMISSIONING PLAN FOR THESE LARGE LOAD, UH, RPG PROJECTS. WITHOUT IT, YOU DON'T HAVE THAT. BUT YOU KNOW, THIS FLAW EXISTS EVEN IN THE ONES THAT ERCOT SAYING ALREADY THAT THEY ARE GOING TO TAKE, UH, AND COUNT AS BASE LOAD IRRESPECTIVE OF DATES. SO THIS IS A PROBLEM YOU ALREADY HAVE TODAY, BUT I AGREE WITH YOU, YOU DO DO NEED A WAY TO SOLVE IT. AND IF WE TAKE THE TSP FEEDBACK, THE A COUPLE OF THEMES WE SAW A WHILE AGO, UH, BOTH CENTERPOINT AND A EP FOCUSED ON ERCOT COLLABORATING WITH 'EM ON RPGS, AND I'M SURE I, I DOUBT IF ENCORE WOULD FEEL DIFFERENTLY EVEN IN THEIR COMMENTS OR ANY OTHER TSPS COLLABORATION BETWEEN ERCOT AND TSPS HAS LONG HAPPENED. DOESN'T MEAN THEY ALWAYS AGREE, BUT THERE'S, THERE'S A LOT OF VALUE IN THAT COLLABORATION. AND THEN TSP COMMENTS HAVE REQUESTED THAT ERCOT EXTEND THE DATE BEYOND MARCH 4TH FOR ALL FOR LARGE LOAD RPGS TO BE INCLUDED FOR BATCH ZERO BASE LOAD. SO OUR CONCLUDING ASKS NOW THAT WE'VE HAD THE BENEFIT OF SEEING THEIR, THE TSP COMMENTS AS WELL AS A NUMBER OF OTHER COMPELLING LIE COMMENTS IS THAT ERCOT SHOULD EXTEND THE BACKEND DATE, UH, FOR THESE LARGE LOAD RPGS TO EARLY JULY. JUST LIKE SOME OF THE TSPS REQUESTED, ERCOT SHOULD COLLABORATE WITH THE TSPS BETWEEN NOW AND EARLY JULY TO DEVELOP AN AGREED UPON LOAD COMMISSIONING PLAN FOR THESE LARGE LOAD, UM, RPGS. SO IT, IT'S TAKING AND TRYING TO ADDRESS THE PROBLEM THAT ERCOT HAS IDENTIFIED, EVEN THOUGH IT'S A PROBLEM YOU ALREADY HAVE, UH, AND YOUR OTHER RPGS YOU'VE APPROVED. AND THEN WE SAID FINALLY TO THE DEGREE THAT COLLABORATIVE ERCOT TSP LARGE LOAD RPG LOAD COMMISSIONING PLANS CAN BE DEVELOPED BY EARLY JULY, 2026. THEN INCLUDE THESE LARGE LOAD RPGS AS BASE LOAD IN SECTION 9.2, 0.1 0.4, AND TO KIND OF PUT A BOW AROUND ALL THAT, IF ERCOT WILL COLLABORATE WITH THE TSPS AS THEY'RE REQUESTING THEN ALL THE HARD WORK OF THEIR LARGE LOAD RPGS 51 GIGAWATTS WORTH. AND IF ANYTHING, THAT NUMBER'S PROBABLY BIGGER, I PROBABLY MISS SOME THAT 10 X IS THE AMOUNT OF THINGS THAT WILL ACTUALLY BE ABLE TO MOVE FORWARD WITH A YEAR, YEAR AND A HALF EARLIER THAN WERE OTHERWISE GOING TO BE ON THE PROCESS OF, OF ACCOMPLISHING IF WE DON'T, DON'T RECOGNIZE THE HARD WORK THAT WENT INTO PUTTING ALL THESE TOGETHER. AND AS A EP SAID IN THE COM THEIR COMMENTS, FRANKLY, THE QUALITY OF THE RRP G THE LARGE LOAD WORKING GROUP RPGS, THAT QUALITY IS DRAMATICALLY HIGHER THAN WHAT YOU GET OUT OF THE BIGGER ONE 15 PROCESS BECAUSE YOUR WHOLE INVALIDATING CONCERNS OR SOMEBODY CAME ALONG LIKE IT'S, IT'S LIKE RAGU, IT'S ALL IN THERE AND IT'S ALL COVERED AT LEAST FOR WHAT WAS PUT FORWARD. SO THE QUALITY OF THESE ARE MUCH HIGHER THAN WHAT YOU GET WITH THE CURRENT JUST REMAINING FOUR OR FIVE MONTHS OF, UH, P ONE 15. WITH THAT, I'LL CONCLUDE AND ANSWER ANY QUESTIONS. OKAY. ALRIGHT. DO WE HAVE BREATH? OH, SORRY, IS CHRISTINA, UH, SWITZER WITH ERCOT? SORRY TO INTERRUPT , I JUST WANTED TO MAKE ONE COMMENT AND I THINK I'VE HEARD THIS A COUPLE OF TIMES TODAY. THE SUGGESTION THAT WHAT IS IN THE, THE REQUIREMENTS FOR THE 2026 RTP COMPLIANCE PLAN ARE SOMEHOW EQUIVALENT TO OR BETTER THAN WHAT'S IN THE PFP FOR 58 4 81. AND I JUST WANNA BE CLEAR, I I DON'T THINK THAT'S THE CASE. THE FINANCIAL SECURITY [03:30:01] REQUIREMENTS ARE MUCH HIGHER IN THE INTER FOR AN INTERCONNECTION AGREEMENT IN 58 41. AND I DO NOT THINK THOSE ARE EQUIVALENT. I DID NOT MEAN TO INDICATE THAT IT WAS BETTER IN ANY WAY AND I DIDN'T SAY IT WAS EQUIVALENT OR I DIDN'T MEAN TO SAY IT WAS EQUIVALENT. I SAID THE PORTIONS OF IT. I MEAN, JUST READING THE CONCLUDING COMMENTS IN THE ROUTE 58 4 80 RULE, IT'S, IT'S THE PUC TRYING TO BE AS, AS ALIGNED AS THEY COULD POSSIBLY BE. THAT ERCOT FOR RTP AND RPG WOULD USE THE HIGHER SITE CONTROL THRESHOLDS. AND A NUMBER OF THRESHOLDS IS THEY'RE NOT ALL THE SAME, BUT THEY'RE HIGHER THAN HAS EXISTED BEFORE. SO BACK TO OTHER COMMENTS FROM TSPS THIS MORNING. IF THOSE ARE GONNA BE USED TO JUSTIFY BILLIONS OF DOLLARS OF TRANSMISSION, THEN THE ILES THAT HAVE LOAD IN THERE, THAT IS THE LOAD THAT'S JUSTIFYING THAT TRANSMISSION. THEY SHOULDN'T BE PLACED AT A, AT A POINT TO WHERE WHEN THEIR LOAD DROVE THAT THEY'RE NOT THE ONES WHO, WHO HAVE THAT AS BASE LOAD CAPACITY COMING OUT OF THE BACKSIDE OF IT. THAT'S JUST, THAT SEEMS TO MAKE NO SENSE BECAUSE IF THAT'S THE CASE, HOW DO YOU, HOW ARE YOU EVEN GONNA TAKE ACTION WITH THE 2026 RTP? I'M BEING SARCASTIC WITH THAT. I THINK YOU'LL TAKE PLENTY OF ACTION. 'CAUSE I, I AGREE WITH WHAT ENOR SAID THIS MORNING. THERE WILL BE SIGNIFICANTLY MORE DEMAND THAT WILL COME ALONG. IT'S JUST THE, THE LOADS THAT DROVE THAT WERE THE ORIGINAL DEMAND THAT JUSTIFIED THAT TRANSMISSION. THEY SHOULDN'T BE PLACED AT A DISADVANTAGE RELATIVE THE ONES WHO CAME ALONG LATER AND WERE NOT PART OF THAT RPG FOR, FOR GAINING THE BENEFITS OF THE TRANSMISSION THEY HELPED JUSTIFY. ALL RIGHT. EXCELLENT QUEUE ROTH? YES. HI, UH, GOING BACK TO SHANNON'S SLIDE ON THE BAR CHARTS FOR STUDIES APPROVED AND THE RPG PROJECTS, I THINK IT WOULD BE GREAT, AND I MEANT TO PUBLISH THIS IN COMMENTS, BUT I WASN'T SURE, CAN WE GET SOME DATA FROM ERCOT, UH, TO GIVE TRANSPARENCY INTO LIKE THE MEGA OF LARGE LOAD THAT IS APPROVED AND MEETS SECTION 9.4 AND 9.5 TO DATE ON, YOU KNOW, SO THAT WE GET TO KNOW HOW MUCH OF THIS WILL BE, YOU KNOW, BASE LOAD IN BATCH ZERO OR YOU KNOW, AT LEAST STILL LIKE MARCH 4TH. AND THE SECOND REQUEST WAS, YOU KNOW, HOW MANY MEGAWATTS OF LARGE LOADS ARE APPROVED FROM MARCH 4TH TO YEAR TO DATE? AND THEN WHAT ARE THE RPG PROJECTS THAT WE ARE SEEING THAT ARE QUALIFIED TO BE IN BADGE ZERO BASED ON THE CURRENT DRAFT? I THINK IT WOULD BE REALLY HELPFUL IN US ASSESSING THE PROJECTS AND GETTING TRANSPARENCY INTO THIS DRAFT HERE. I THINK YOUR FIRST QUESTION'S ADDRESSED BY THE, BY THIS SLIDE ITSELF, IS IT NOT? NO, THAT'S WHAT I THINK I WAS ASKING AG IN THE LLWG WORKING GROUP AS WELL. I THINK THIS IS JUST PLANNING STUDIES APPROVED NOT 9.4 AND 9.5, RIGHT? YES, THAT'S CORRECT. UM, SO YEAH, THE, UH, WE WOULD HAVE TO MODIFY OUR REPORTING TO, TO BREAK DOWN WHAT IS 9.4. 9.5. YEAH, THAT WOULD BE SUPER HELPFUL TO UNDERSTAND THE MEGAWATT AMOUNT THAT IS APPROVED SO FAR UNTIL MARCH 4TH TO KNOW THAT. AND THEN IN SIMILAR WAY, CAN WE GET DETAILS ON THE RPG PROJECTS THAT HAVE THE ASSOCIATED LOAD THAT IS BEING REFERENCED REFERENCING IN SECTION 9 4 3 A? WE CAN LOOK INTO THAT. I CAN'T COMMIT ANY TO ANYTHING RIGHT NOW. OKAY. EQUALLY IMPORTANT WOULD BE THE RPG LOADS THAT VALIDATING IF I'M MIS OR IF I'M MISSTATING SOMETHING HERE OR HAVE I MISSED SOME? HOW MUCH I, IF THIS ISN'T THE RIGHT NUMBER AND IT'S PROBABLY NOT EXACTLY THE RIGHT NUMBER, HOPEFULLY IT'S CLOSE. WHAT DOES ERCOT BELIEVE? HOW MUCH DO YOU BELIEVE THAT YOU'RE ABOUT TO DIS DISREGARD OUT OF THESE LARGE LOAD RPG PROJECTS? BECAUSE, AND THEN HOW MUCH, HOW WOULD THAT HAVE ANSWERED A WHOLE LOT OF THIS BOTH, YOU KNOW, HERE AND OVER HERE ON THIS OTHER SLIDE, YOU KNOW, IF YOU MAKE SOME ASSUMPTIONS, IT'S ALMOST LIKE SOME OF THE TSPS, IT IS ALL OF THEIR LOAD, THEY TOOK THE RPG EXTREMELY SERIOUSLY AND 80 PLUS 90% OF THEIR LOAD IS COVERED THROUGH RPGS, WHICH [03:35:01] ARE A HIGHER QUALITY AS A EP POINTED OUT THAN, UH, P ONE 15 STUDIES. YEAH, THIS IS AG. I I DO WANT TO CLARIFY THAT, UM, AS I STATED AT THE LLWG UH, WEEK BEFORE LAST, THAT THERE IS NO INDICATION THAT THESE LLI NUMBERS WITH NO STUDY SUBMIT IS CORRESPOND TO RPG PROJECTS. THE ONLY LINK THAT YOU HAVE DRAWN HERE IS THAT THE TOTAL MEGAWATTS FROM THE TSPS THAT YOU'VE PICKED HERE HAPPENED TO BE ROUGHLY WHAT THE NUMBER YOU SHOWED ON THE OTHER SLIDE. AND SO I JUST WANNA BE VERY CLEAR THAT , WE WOULD INVITE YOU TO ACTUALLY PUT TOGETHER THE RIGHT, THE RIGHT COMPARISON BECAUSE IT'LL BE A LARGE NUMBER. I KNOW FOR A FACT WE HAVE PROJECTS THAT ARE PART OF SOME OF THESE TSPS NO STUDIES SUBMITTED BECAUSE THE TSP FOUND IT BRUTALLY PAINFUL TO GO THROUGH THE PIER ONE 15 PROCESS AND THEY FELT AN RPG WAS A MUCH HIGHER QUALITY AND ONE THAT WOULD ACTUALLY STAND THE TEST OF TIME. AND THEY FOCUSED ON THAT. AND I KNOW FOR A FACT OF JUST WITH OUR OWN PROJECTS, WE'VE GOT ONES THAT THERE'S QUITE A BIT OF OVERLAP. NOW I, IT MAY NOT BE THIS AMOUNT, BUT WE WOULD LOVE TO SEE WHAT YOU THINK THE REAL NUMBER IS. YEAH, AGAIN, I I, WE CAN LOOK AT, UH, TRYING TO PROVIDE THAT IN THE FUTURE, UH, BUT I CAN'T COMMIT ANYTHING RIGHT NOW IN THE ABSENCE OF, UH, SOMETHING DIFFERENT. THIS STANDS OUT THERE THEN AS SOMETHING THAT IT'S, IT'S CLEAR. I MEAN, ENCORE LOANS GOT LIKE SIX OF THESE RPGS, EVEN THE 25 RPG 0 0 4, Y'ALL JUST SUBMITTED YOUR INDEPENDENT REVIEW ON LAST WEEK UNDER YOUR CURRENT, YOU KNOW, AND THAT GOT TURNED IN FEBRUARY, EARLY FEBRUARY OF LAST YEAR. EVEN. IT WILL NOT BE USED UNDER YOUR CURRENT PIGGER 1 45 LANGUAGE. THAT'S, AND THAT WAS BEFORE THEY TURNED THAT IN, BEFORE PIGGER ONE 15 EVER EXISTED. SO IS THIS TRYING TO JUST POINT OUT, THERE'S WAY TOO FREAKING MUCH WORK THAT'S WENT INTO THIS BY THE TSPS AND FRANKLY THE ILES THAT WERE A PART OF IT FOR US TO NOT USE THAT JUST ARBITRARILY AT THIS POINT. SEE, JUMPED IN, TELL YOU WHAT, JUGGLE IT THIS WAY. ALRIGHT, THAT'LL WORK. SO WE HAVE THREE IN THE QUEUE, SO PRAIL, YOU MAY BE ABLE TO HELP OFFER SOME INSIGHT ON THAT. YEAH. UH, GOOD AFTERNOON. THIS IS, UH, P MECO SHANNON. THANKS. THANKS FOR THE PRESENTATION. SO I, I I THINK I LIKE TO POINT OUT SOMETHING ON THIS 50 GIGAWATTS. SO WHAT, WHAT YOU'RE TALKING, OR THE NUMBER YOU'RE MENTIONING IS YES, THERE ARE LOADS THAT'S SUBMITTED AS PART OF THE RPG REVIEW. WHAT THE TSP PROPOSES A PROJECT, THEY WANT US TO CONSIDER THIS LOAD. BUT YOU KNOW, WHEN YOU, WHEN YOU LOOK AT THE INDEPENDENT, DURING THE INDEPENDENT REVIEW, WE DO IDENTIFY THE NEED BASED ON A SUBSET OF THE LOAD OR PORTION OF THE LOAD THAT'S DRIVING THE RELIABILITY NEED OF THE PROJECT. SO THE WAY WE PROPOSE THE LANGUAGE IN THE, IN THE BIGGER, UM, 1 45 IS TO IDENTIFY THOSE LOADS THAT'S DRIVING THE NEED OF THE PROJECT. SO THAT'S, THAT'S GOING TO BE A SUBSET OF ALL THE LOADS THAT GO INTO ANY RPG STUDY. SO I JUST WANTED TO POINT OUT THAT. RIGHT. THAT'S, THAT'S FAIR. UH, BUT IT'S ALSO, LIKE I SAID, I KNOW WITH OUR OWN PROJECTS THAT ARE IN SOME OF THESE RS, UH, TSP RPGS, I KNOW WITH HIGH DEGREE OF CONFIDENCE THAT A LOT OF WHAT WE'RE SAYING HERE IS TRUE, AT LEAST FOR THAT, UH, TSP. I'M NOT SAYING THAT'S CATEGORICALLY TRUE FOR EVERY TSP, BUT IT'S QUITE LARGE. IT'S A VERY LARGE IMPACT. I AGREE. ALL RIGHT, SO LET'S WORK THROUGH THE QUEUE HERE. UH, SAM JUNG, THEN EVAN, THEN WAYMAN, AND THEN WE'RE TRYING TO MOVE ON TO THE NEXT COMMENTER. REMEMBER WE'VE BEEN STUCK ON THIS ONE FOR 20 MINUTES HERE. ALL RIGHT. SAM JUNG FROM EP. CAN YOU GUYS HEAR ME? YES, GO AHEAD. UH, HEY, UM, THANKS SHANNON. UM, I JUST HAVE A QUESTION. SO ARE YOU ASKING THAT THESE, UH, RPG LOAD THESE LOADS THAT WENT THROUGH RPG INSTEAD OF STUDYING THEM AS AN ALLOCATION LOAD IN BATCH ZERO, ARE YOU PROPOSING THAT WE INCLUDE THEM AS A BASE LOAD? Y UH, YES, AS THE TSPS THEMSELVES ARE AND THEIR COMMENTS THAT THEY SUBMITTED, UM, LAST FRIDAY FOR THE REASONS, NOT ONLY THE ONES THEY OUTLINED, BUT THE ONES WE'VE OUTLINED HERE AND MANY OTHER SPEAKERS HAVE. SO REALLY THE, UM, THE AMOUNT OF LOAD THAT'S BEING INCLUDED IN THE BACTERIAL CASES WILL STAY THE SAME. YOU'RE JUST INCREASING THE AMOUNT OF BASE LOADS AND THEN I GUESS SORT OF DECREASING THE AMOUNT OF [03:40:01] ALLOCATED OR THE STUDY TO BE ALLOCATED LOADS. IS THAT, IS THAT CORRECT? THAT'S CORRECT. WITH ONE REFINEMENT. YOU KNOW, IF YOU LOOK AT THE LAST PAGE OF OURS, I DON'T KNOW IF YOU CAN FLIP TO IT, WE'RE TRYING TO ADDRESS WHAT IN DISCUSSIONS WITH ERCOT THEMSELVES, THEY'VE IDENTIFIED IS THEY'RE NOT BEING THE, UM, KIND OF THE EFFECTIVE LOAD, YOU KNOW, RPGS ARE THE END STATE, AND SO YOU DO NEED THE RAMP, THE LOAD COMMISSIONING PLAN THAT WOULD COME WITH THESE LOADS THAT WERE IN THERE. WE AGREE THAT IS SOMETHING NEEDED, AND THEN WE'RE SAYING, PLEASE TAKE THE TSPS UP ON THEIR OFFER TO COLLABORATE WITH YOU ON THIS, AND IF THEY CAN HELP YOU SOLVE THIS PROBLEM BETWEEN NOW AND JULY, THERE'S NO REMAINING REASON TO NOT UTILIZE THOSE FOR BASE LOAD. GOTCHA. I, I GUESS I THINK THE, THE, THE ONE OF THE POINT OF BATCH ZERO STUDY IS THAT THE ER HUB WANTS TO INCLUDE ALL OF THE, I GUESS RPG LOADS, THE LOADS THAT WENT THROUGH RPG AND THE ONES THAT ARE, I GUESS WITHOUT RPG, UM, WAITING TO BE STUDIED TO BE ALLOCATED. I, I THINK, UH, ER CUT'S MAYBE, UH, INTENTION IS TO IDENTIFY MAYBE, YOU KNOW, WITH, EVEN WITH THESE RPGS AND WITH THESE, UH, ADDITIONAL LOADS THAT ARE TO BE STUDIED, UM, THE RPGS MAY NOT BE ENOUGH AND YOU NEED TO MAKE, YOU KNOW, UH, MAKE A REVISIONS TO THOSE RPG TO, YOU KNOW, PERHAPS A BIGGER SCALE. SO, UH, I THINK THAT THAT MIGHT BE, I, I DON'T DISAGREE. A BIGGER SCALE MAY BE NEEDED, BUT WE SHOULDN'T THROW OUT THE, THE, YOU KNOW, WE SHOULDN'T LET PERFECT BE THE ENEMY OF SOMETHING THAT'S MUCH BETTER THAN NOTHING, WHICH IS WHAT THE CURRENT RPG PROPOSALS ARE. GOTCHA. YEAH, I GUESS, YEAH, I JUST THAT IN THE END, THE, ALL OF THESE LOADS WILL BE STUDIED REGARDLESS, UM, JUST DEPENDING ON WHAT PROJECTS ARE NEEDED AFTER IT'S THE 26, 27 AND 28 ONES, THOUGH THEY MAY GET STUDIED, BUT THERE'S YEARS OF LOST, YOU KNOW, THERE'S YEAR PLUS YEAR AND A HALF PLUS OF LOST OPPORTUNITY, UH, PERHAPS LIKE A LA UH, POTENTIAL LATER IN-SERVICE STATE. RIGHT, RIGHT. THE LOST OPPORTUNITY. GOTCHA. ALL RIGHT. THANK YOU. ALRIGHT, UH, EVAN, UM, FIRST JUST THANKS SHANNON FOR PUTTING THIS TOGETHER. THERE'S A LOT OF NUMBERS HERE. I'VE TRIED TO CRUNCH THIS MYSELF, BUT THIS IS JUST GREAT TO HAVE IT ALL IN ONE PLACE AND I THINK IT LAYS OUT THE PIECES GREAT. AND JUST TOTALLY SUPPORT WHAT YOU'RE, WHAT YOU'RE SHOWING HERE. I MEAN, I THINK YOU'RE REALLY SAYING THAT, LOOK, ALL THE PUZZLE PIECES ARE THERE IN FRONT OF US AND BATCH SERVICE OPPORTUNITY TO SIMPLY JUST PUT THEM ALL TOGETHER AND MAKE IT FIT. AND THAT SEEMS LIKE THE BEST, FASTEST WAY TO ACHIEVE EVERYBODY'S GOALS OF CONNECTING A BUNCH OF LOAD AND HAVE A CONSTRUCTIVE TRANSMISSION PLAN TO SERVE IT WHILE PROTECTING THE RATE PAYERS. SO I JUST WANTED TO SAY THAT FIRST. UH, AND THEN JUST LAST IS A SMALL POINT, BUT JUST ON WHAT YOU WERE SAYING ABOUT WITH, WITH AG ABOUT PROVING YOUR POINT ABOUT HOW SOME TSPS HAVE INCLUDED SOME LOADS THAT WE KNOW ARE IN THAT BAR CHART. I, I THINK THERE ARE SOME RPGS OUT THERE THAT EXPLICITLY LAY OUT THE LLI NUMBERS AND THE AMOUNT OF MEGAWATTS. YEAH. AND I THINK YOU CAN PRETTY QUICKLY DO THE MATH AND SEE THAT YOUR STATEMENT HOLDS TRUE. AND SO I JUST ENCOURAG ANYONE WHO'S SKEPTICAL TO GO LOOK AT THAT. ALL RIGHT. AND THEN WAYMAN SMITH. HELLO. THERE YOU ARE. GO AHEAD WAYMAN. ALRIGHT. UM, YEAH, I JUST WANTED TO PICK, PICK UP ON A COUPLE OF COMMENTS THAT, THAT SHANNON MADE. UM, AND IN PARTICULAR, ONE, I THINK, YOU KNOW, AND AGAIN, I'M NOT JUST TRYING TO PILE ON THE LLIS PROCESS, BUT I THINK WE CAN ALL AGREE AND, YOU KNOW, HIS CHART SHOWING HOW MUCH LOAD ACTUALLY MADE IT THROUGH LLIS IN 11 MONTH PERIOD, UM, KINDA SPEAKS TO HOW PAINFUL, UM, THAT PROCESS WAS TRYING TO GET THROUGH IT. UH, AND IT, YOU KNOW, TOOK A VERY, VERY LONG TIME. AND THE FACT OF THE MATTER IS THAT THE RESULTS OF THE LLIS, THE LOAD COMMISSIONING PLAN, WERE NOT ACTIONABLE. SO ANY, ANY UPGRADES IDENTIFIED, YOU STILL HAVE TO FILE AN RPG TO GET ENDORSEMENT TO GO BUILD ANYTHING. AND SO THE RESULTS OF THE PROCESS WERE, WERE QUESTIONABLE. I THINK THE OTHER ISSUE WAS, YOU KNOW, TO, TO THE EXTENT YOU'RE DOING THESE ONE AT A TIME AND IDENTIFYING LOAD COMMISSIONING PLANS, WHEN IF YOU LOOKED AT ALL OF THE LOADS IN A REGION HOLISTICALLY, THE SOLUTION, UM, THAT WAS, WOULD, WOULD BE THE MOST ADVANTAGEOUS, IS NOT NECESSARILY THE SUM OF ALL THOSE INDIVIDUAL LOAD COMMISSIONING PLANS. AMEN. IN OTHER WORDS, YOU REALLY NEEDED TO LOOK AT THOSE LOADS HOLISTICALLY IN ORDER TO [03:45:01] DEVELOP A GOOD TRANSMISSION PLAN. AND, AND THEN AGAIN, AS I SAID, THE RESULTS OF IT WEREN'T ACTIONABLE. AND SO THERE WERE SOME OF THESE RPGS THAT WERE STARTED WELL BEFORE, UH, PIGGER ONE 15 WAS UN UN GRAY BOXED AT THAT TIME. THERE WAS A LOT OF DISCUSSION ABOUT WHETHER OR NOT, YOU KNOW, RPGS MIGHT BE A SUBSTITUTE FOR LLIS. AND I REALIZED THAT NEVER MADE IT ALL THE WAY THROUGH THE PROCESS, BUT BOTTOM LINE IS THE LLIS REQUIRED A WHOLE LOT OF TIME AND EFFORT. UM, THE, THE RESULTS IN, IN MY VIEW WERE NOT THAT MEANINGFUL BECAUSE YOU COULDN'T DO ANYTHING WITH THEM. THEY WEREN'T ACTIONABLE. YOU STILL HAD TO FILE AN RPG. AND SO PART OF THE THINKING WAS LET'S JUST GO AHEAD AND DO THE RPG WHERE WE EVALUATE ALL OF THE LOADS HOLISTICALLY, COME UP WITH A, YOU KNOW, OPTIMAL PLAN AND SUBMIT IT. UM, AND, AND SO, YOU KNOW, TO SHANNON'S POINT FOR, FOR THERE TO BE A GATING REQUIREMENT, UM, THAT WE CURRENTLY HAVE IN THE PROPOSAL WOULD EXCLUDE A WHOLE BUNCH OF THOSE LOADS, A WHOLE BUNCH OF THE ANALYSIS AND THE UPGRADES THAT HAD BEEN IDENTIFIED AND, AND THAT, THAT SEEMS LIKE A SHAME TO ME TO DO THAT, NUMBER ONE. AND, AND NUMBER TWO, WOULDN'T YOU WANNA CONSIDER THOSE LOADS IN THE BATCH STUDY SO THAT YOU CAN OPTIMIZE A HOLISTIC PLAN AND, AND JUST EXCLUDING THOSE LOADS, AND FRANKLY, SOME OF THOSE LOADS ARE PROBABLY GONNA BE IN THIS YEAR SIX BUCKET, WHICH IS GONNA REQUIRE AN RPG ANYWAY. WELL, YOU, YOU'VE ALREADY GOT AN RPG, WE'VE ALREADY DONE THAT AND FILED IT. SO I THINK TO JUST DISREGARD THOSE RPGS, DISREGARD THOSE LOADS, UM, WOULD, WOULD BE A SHAME. SO, SO, UH, I NEED TO JUMP IN HERE. SO A COUPLE THOUGHTS HERE. UM, I, I DISAGREE WITH THE, THE CHARACTERIZATION THAT WE ARE DISREGARDING THE RPG. SO REMEMBER THE RPG PROCESS IS ABOUT APPROVING TRANSMISSION PROJECTS. IT, IT IS NOT AN ALTERNATIVE PATH TO THE LARGE LOW INTERCONNECTION STUDY PROCESS. AND WE RECOGNIZE THAT AS A STAKEHOLDER BODY. AND WE ATTEMPTED TO CLOSE THAT DOOR WITH PICKER ONE 15 BECAUSE WE REALIZED THAT THAT JUST CREATES MORE PROBLEMS. SO WE NEED TO KEEP RPG IN ITS LANE OF APPROVING TRANSMISSION PROJECTS, NOT AS A GATEWAY FOR, FOR LARGE LOAD PROJECTS TO, TO GET THROUGH THE STUDY PROCESS. THE, THE, THE OTHER THING THAT I THINK WE'VE HEARD A LOT IN THE COMMENTS IS WE, THIS IDEA THAT WE NEED TO LET MORE PROJECTS AND AS BASE LOAD, I, I, I DON'T KNOW THAT I HAVE HEARD ANYONE REALLY ADDRESS THE RELIABILITY IMPLICATIONS OF THAT OR, OR THAT PEOPLE UNDERSTAND WHAT THE RELIABILITY IMPLICATION IS. SO WE, THE, THE REASON WHY WE HAVE CRAFTED THE, UH, DRAFT PICKER 1 45 IS WE HAVE IS BECAUSE WE NEED TO MAKE SURE THAT WHATEVER LOADS WE ARE COUNTING AS BASE LOAD, THAT WE KNOW THAT WE CAN RELIABLY SERVE THOSE, THOSE LOADS WHEN, WHEN THEY COME, WE, WE, UM, WE, WE NEED TO HAVE STUDIES THAT WE CAN POINT TO TO SHOW THAT THIS EVERY LOAD THAT WE HAVE COUNTED AS BASE LOAD, WE, WE KNOW WE HAVE THE STUDY THAT SHOWS WE CAN RELIABLY SERVE THAT LOAD. IT IT, IF WE OPEN THE DOOR FOR MORE LOADS TO COME IN AS BASE LOAD AND WE DON'T HAVE STUDIES TO, TO, WE KNOW THAT WE CAN RELIABLY SERVE THOSE TO, TO USE, UH, PABLO'S ANALOGY FROM THE DECEMBER PUC OPEN MEETING THAT WE'RE ESSENTIALLY YOU'RE, WE'RE JUST LETTING MORE PEOPLE IN THE RESTAURANT WHEN WE DON'T HAVE SEATS FOR THEM AND WE DON'T HAVE FOOD FOR THEM. SO WHEN WE GET TO REAL TIME, THE, THE IMPLICATION THERE IS WE'RE GOING TO HAVE TO MANAGE THAT RELIABILITY PROBLEM WITH THE OPERATORS DOING ROTATING OUTAGES OR, OR WHATEVER. AND I, I DON'T THINK THAT'S WHAT EVERYBODY WANTS. AND SO WE NEED TO UNDERSTAND IF WE ARE PUSHING THIS IDEA THAT WE NEED TO HAVE MORE AS BASE LOAD, EVEN IF WE DON'T HAVE STUDIES THAT SHOW THAT WE CAN RELIABLY SERVE IT, THAT THAT IS THE IMPLICATION IS THAT YOU'RE JUST PUSHING THIS TO A REALTIME PROBLEM AND, AND THEN THAT THAT'S GOING TO BE NOT GOOD FOR EVERYBODY. I, I APPRECIATE YOU SHARING THAT. TO ANSWER THAT, I WOULD SAY THIS, PLEASE DO NOT HEAR ANYTHING I SAID HERE TO, TO BE ASKING FOR WHAT YOU JUST CHARACTERIZED, BECAUSE IF YOU GO, GO TO THE LAST SLIDE, PLEASE, IF YOU WOULD, UH, MATT, WHAT I'VE SAID [03:50:01] IS TAKE THE RPG PROJECTS OR PROPOSALS THAT, UH, HAVE THAT COVER THESE LARGE LOADS THAT THE TSPS HAVE SUBMITTED TO YOU, THEY'VE SUBMITTED TO YOU A RELIABLE WAY TO SERVE THESE AT THE END STATE. AND THEN I'M ASKING YOU ALL TO COLLABORATE WITH THEM AS THEY'RE ASKING YOU TO COLLABORATE WITH THEM AND DEVELOP THE INTERMEDIATE, UH, LET THEM COLLABORATE WITH YOU AND DEVELOP THE LOAD COMMISSIONING PLAN THAT GOES WITH IT. SO YOU WILL THEN HAVE ALL THE ELEMENTS THAT YOU HAVE IN FIGURE ONE 15 TODAY. YOU HAVE A LOAD COMMISSIONING PLAN AND AN END STATE, EXCEPT LIKE WAYMAN SAID, IT'S A MUCH HIGHER QUALITY THAN WHAT YOU HAVE WITH A BUNCH OF SEQUENTIAL THINGS. WHEN YOU TRY TO ADD UP ALL THE SEQUENTIALS, THE SUM OF THE PARTS IS VERY DIFFERENT THAN WHAT THE WHOLE ANSWER IS. AND THE ONE ANSWER THAT'S ACTUALLY RELIABLE IS THE, THE RPG ONE, NOT THE SUM OF THE INDIVIDUAL PICKER ONE FIFTEENS. YEAH. AND, AND I, I WOULD SAY THAT THAT IS THE BATCH ZERO STUDY, BUT THAT LOAD COMMISSIONING PLAN IS THAT ALLOCATION IN THAT COMES OUT OF THE BATCH ZERO STUDY. BUT IF THEY WILL COLLABORATE WITH YOU AND DEVELOP THE MISSING PIECE THAT YOU HAVE FOR, UH, CURRENTLY EVEN WITH THE ONES YOU'VE ACCEPTED, YOU HAVE THIS, IF THEY'LL DEVELOP THE COURT COLLABORATIVELY WITH YOU AND DEVELOP THAT FOR YOU BY JULY, WE DON'T NEED TO WAIT A WHOLE NOTHER YEAR TO GET THE RESULTS THAT WE WOULD KNOW BY THAT TIME OR TILL FEBRUARY OR MARCH OF NEXT YEAR BECAUSE THEY'VE ALREADY DONE THE IN-STATE WORK. THE HARD PART DISAGGREGATING IT AND GETTING THE INTERMEDIATE STEPS IS MUCH SIMPLER THAN GETTING THE ORIGINAL RPG PROPOSAL TOGETHER. ALRIGHT, EVAN, LAST QUESTION. WE'RE GONNA MOVE ON TO ANGELA. THANKS. APPRECIATE YOU LETTING ME ASK THIS QUESTION. UM, I, JEFF, SO IT WAS JUST SOMETHING YOU SAID AND PUT ALL THE PIECES TOGETHER. I, I UNDERSTAND WHERE YOU'RE COMING FROM. I'M JUST TRYING TO FIGURE OUT HOW IT ALL FITS TOGETHER. AND SO FORGIVE ME IF WE'VE GONE OVER THIS, BUT JUST TRYING TO GET CLARITY SO I UNDERSTAND KEEPING THE RPGS IN THEIR OWN LANE LOAD APPROVAL SEPARATE FROM THAT. I UNDERSTAND WHERE YOU'RE COMING FROM, BUT I'M JUST TRYING TO FIGURE OUT DOES THAT MEAN THAT ERCOT WILL ENDORSE RPG PROJECTS? SOME OF THESE, WHICH SHANNON WAS TALKING ABOUT WITHOUT THE LOADS BEING APPROVED THAT ARE JUSTIFYING THOSE TRANSMISSION PROJECTS. SO I'M GONNA GENERICALLY SAY THE RPG PROCESS WILL FOLLOW THE, THE, THE STUDIES WILL FOLLOW THE RPG PROCESS AS, AS LAID OUT. AND, AND SO THE, THE LOADS THAT GO INTO THAT WILL BE WHAT WHATEVER LOADS ARE, YOU KNOW, DEEMED APPROPRIATE BASED ON THE RULES AT THAT TIME, RIGHT? SO WE CUT THROUGH THE LINE IN THE SAND WITH THOSE COMMENTS ON THE CENTER POINT RPG SAYING THINGS FILED BEFORE APRIL 1ST WILL BE THE OLD SUBSTANTIATED, UH, LOAD DEFINITION. AND SO THAT'S A LOT OF THE RPGS THAT SHANNON'S TALKING ABOUT. AND SO THOSE ERCOT WILL ENDORSE BASED ON THAT CRITERIA, BUT WILL AT THE SAME TIME SAY NO, YOU'RE NOT INCLUDED IN BATCH ZERO. AND SO WHEN WE ENDORSE THOSE PROJECTS, WHEN ERCOT ENDORSES THOSE PROJECTS, THERE WILL BE NO LINE OF SIGHT ON WHETHER THE LOADS INCLUDED THAT JUSTIFY THAT ENDORSEMENT WILL BE ABLE TO COME ONLINE ON THE SCHEDULE THAT'S CONTEMPLATED IN THE RPG, EVEN THOUGH THEY MAY HAVE SIGNED INTERCONNECTED AGREEMENTS AND HAVE POSTED A LOT OF MONEY TO MAKE THOSE PROJECTS VIABLE. AND IF YOU DON'T CONNECT THOSE LOADS, THEN CUSTOMERS HAVE TO PAY FOR THE TRANSMISSION LINES STILL AND TRANSMISSION COSTS WILL GO UP 'CAUSE YOU'RE NOT INCREASING THE THE PAYERS AT THE SAME TIME. OKAY. BUT, BUT BATCH ZERO, YOU'RE GOING TO POTENTIALLY, SO LET'S SAY WE'RE NOT COUNTING THOSE AS BASE LOAD. I'M WALKING DOWN YOUR HYPOTHETICAL HERE. IT, IT'S THOSE LOADS THEN GO INTO BATCH ZERO AND STUDIED. SO THOSE LOADS THEN IF THAT TRANSMISSION IS NEEDED TO SERVE THOSE LOADS, THEY'LL GET ALLOCATED THOSE MEGAWATTS AND THAT TRANSMISSION WILL GET CONSTRUCTED TO SERVE THAT LOAD. THE TRANSMISSION WILL GET CONSTRUCTED. THOSE LOADS MAY OR MAY NOT GET ALLOCATED THAT TRANSMISSION BECAUSE THE RULES THAT YOU'VE GOT, LIKE SEVERAL PEOPLE HAVE POINTED OUT, ALLOW LOADS THAT CAME LATER THAT WERE NOT THE ONES THAT JUSTIFIED THE TRANSMISSION IN THE FIRST PLACE TO POTENTIALLY GET WHAT YOU'VE SIGNED AN INTERCONNECT AGREEMENT FOR AND POSTED ALL THIS MONEY FOR IT. THAT'S THE PROBLEM. WE'RE NOT TRYING TO GET MORE IN THAN CAN RELIABLY BE SERVED. WE'RE TRYING TO GET THE AMOUNT IN AND THE SPECIFIC ONES IN THAT THE RPGS COVER THAT THAT'S WHAT WE'RE AFTER, NOT TRYING TO GET ANYTHING IN THAT CAN'T RELIABLY BE SERVED. YEAH. SO, SO I [03:55:01] WOULD SAY THAT'S THAT. UM, I UNDERSTAND THAT CONCERN. I I THINK BUT IF, IF I STAY IN THE RPG LANE, THERE WILL BE SOME LOAD THAT WILL BE THERE TO JUSTIFY THAT, THAT PROJECT, IT MAY NOT BE THE LOAD THAT WAS ORIGINALLY SUBMITTED, BUT THERE WILL BE A LOAD OR SOME LOADS THAT WILL, IF I'M, IF I STAY IN THE RPG LINE, I THINK THAT'S, SO THAT'S TRUE FOR THE RRP G THAT'S THE OUTCOME OF THE BATCH ZERO. RIGHT. BUT HAS ALREADY COMMITTED THAT THERE ARE RPGS THAT ARE SUBMITTED TWO TODAY THAT IF FOLLOWING THE SCHEDULE WILL GET ENDORSEMENT PRIOR TO BATCH ZERO'S RESULTS COMING OUT. AND THE CURRENT POSITION AS IT SEEMS IS THAT THOSE WILL GET ENDORSED, THE TRANSMISSION WILL GET ENDORSED AND THE LOADS JUSTIFYING THEM WILL NOT. I THINK YOU'RE RIGHT. I THINK THAT IS A POTENTIAL OUTCOME, BUT THAT, THAT DOES NOT MEAN THAT THAT TRANSMISSION IS NOT NEEDED BECAUSE O OTHER LOADS, YEAH, IF, IF THAT LOAD DOESN'T GET ALLOCATED, THAT MEANS SOME OTHER LOAD IS THERE TO GET THE, OUT THAT ALLOCATION. WELL, MY POINTS WOULD BE THEN THAT'S A REALLY INEFFICIENT WAY OF PLANNING TRANSMISSION. AND TO SHANNON'S POINT, THERE ARE PEOPLE WHO'VE PAID THE, THE SECURITY DEPOSITS FOR THAT TRANSMISSION AND YOU ARE SUGGESTING, UM, SOMEONE ELSE GET THE TRANSMISSION THAT THEY'VE PAID FOR AND SECURITIZED. YEAH, THAT'S THE, THE VERY HEART OF THE PROBLEM AND THE WHOLE PURPOSE, THE DEVELOPING BIGGER 1 45 IS WE'RE TRYING TO DEVELOP A SET OF RULES FOR HOW TO RELIABLY SERVE THIS. IT'S NOT TRYING TO BYPASS AND SNEAK SOME MORE IN IT'S TRYING TO, TO GET IN THE AMOUNT THAT THE TSPS HAVE DONE ALL THIS DARN WORK FOR AND, AND THE LOADS THAT HAVE COMMITTED THE MONEY TO MAKE THAT POSSIBLE FOR THEM TO BE ALIGNED WITH THE TRANSMISSION THAT'S GONNA GET BUILT. ALRIGHT, WELL WE GOT THAT ONE. HIT THAT ONE PRETTY HARD, SO WE'RE GONNA MOVE ON. SO WHAT WE HAVE IS, JUST SO YOU KNOW, I WAS HOPING TO AT LEAST HAVE AN HOUR ON BYOG STUFF AT THIS POINT. WE HAVE AN HOUR TO THREE 30. WE HAVE EIGHT PEOPLE TO SPEAK. AND SO IF WE GET INTO BACK INTO THAT SEVEN MINUTE ZONE ON THESE TOPICS, IF WE HAVE TO PULL A THREAD, WE'LL PULL A THREAD. AND THAT WAS A VALID THREAD THAT WE PULLED. UH, BUT ON WE GO. SO I'M GONNA MARCH DOWN AND NEXT UP IS ANGELA. HI EVERYONE. UH, ANGELA CHEN FROM SATOSHI ENERGY. UH, REALLY APPRECIATE THIS OPPORTUNITY TO PROVIDE COMMENT TODAY AND FOR ALL THE HARD WORK THAT ERCOT STAFF HAVE, UH, DONE FILING THE REVISION REQUESTS AND INCORPORATING STAKEHOLDER FEEDBACK. AND I HAVE THREE MORE MAIN THINGS TO HIT TODAY, UH, THAT HAVE BEEN DISCUSSED, UH, THROUGHOUT, UH, TODAY. AND SO HOPE I'LL BE BRIEF HERE. SO OUR FIRST POINT IS THAT PROJECTS THAT QUALIFY FOR BASE LOAD, UH, THAT HAVE SATISFY 9.4 9.5 SHOULD NOT BE REQUIRED TO EXECUTE A NEW INTERCONNECTION AGREEMENT. THIS FEELS LIKE A DUPLICATIVE REQUIREMENT, UH, FOR BASE LOADS AT HARVEY COMPLETED THE FULL INTERIM L LO S PROCESS. UM, THEY'VE DEMONSTRATED THE HIGHEST LEVEL COMMITMENT AVAILABLE IN ERCOT DURING THIS INTERIM PROCESS AS BARTH AND, UH, OTHERS HAVE POINTED OUT THIS MORNING BY SIGNING, BY ANY AGREEMENTS POSTING KAYAK AND FINANCIAL SECURITIES. WE AND TSPS AND ERCOT SEE THESE LOADS AS FIRM AND IT'S NOT REALLY APPARENT WHAT AN ADDITIONAL RISK THIS BLANKET, UH, DOLLARS PER MEGAWATT FEE WOULD BE ADDRESSING WHEN ACTUAL INTERCONNECTION COSTS HAVE BEEN, UH, DETERMINED AND POSTED ALREADY. OUR SECOND POINT OF FEEDBACK HERE IS THAT, UH, THE INTERCONNECT INTERMEDIATE AGREEMENT SECURITY POSTED FOR BATCH ZERO SHOULD BE FULLY REFUNDABLE, UM, FOR PURPOSES OF BIGGER 1 45. AND THE INTERCONNECTION FEE FOR THE INTERCONNECTION AGREEMENT SHOULD BE SCALED TO ACTUAL KAYAK. AND THIS CAN BE NON-REFUNDABLE. SO UNDERSTAND, UH, THAT THE LANGUAGE OF THIS AGREEMENT DRAWS FROM 5 8 4 8 1, AND WE'LL BE SUBMITTING COMMENTS THERE. BUT IF, UH, AS POINTED OUT TODAY, THERE'S GOING TO BE A FORK IN THE ROAD FROM WHEN WE HAVE TO FINALIZE SOME REQUIREMENTS FOR PGA 1 45 AND, UM, 5 8 4 1 CONTINUES THROUGH THEIR STAKEHOLDER PROCESS. WE BELIEVE THE FOLLOWING ADJUSTMENTS TO THE PIGGER ARE NECESSARY. SO ONE, UM, AT THE INTERMEDIATE AGREEMENT STAGE, THE ANY DEPOSIT SHOULD BE FULLY REFUNDABLE, UH, LOCKING IN NON-REFUNDABLE. NOW WHEN A, THE RULEMAKING IS PENDING AND B, BEFORE TSPS HAVE FULLY NEEDED TO START PROCURING EQUIPMENT PLANNING FOR CONSTRUCTION CREATES REAL, UH, STRANDED COST RISK FOR DEVELOPERS WHO MUST MAKE DECISIONS AND GET FINANCING TODAY. UH, BUT THEIR STUDIES MAY STILL BE DEEMED A VALID, THEY MAY NOT, MAY GET ZERO MEGAWATTS ALLOCATED. SO I THINK IN FOR THE PURPOSES OF THIS, IT MAKES A LOT OF SENSE FOR THIS FIRST PAY TO PLAY DEPOSIT TO [04:00:01] BE FULLY REFUNDABLE AT THE INTERCONNECTION AGREEMENT STAGE. WE SUGGEST THE NON-REFUNDABLE FEE BE CALIBRATED TO THE ACTUAL KAYAK OBLIGATION, UH, RATHER THAN A BLANKET AMOUNT. SO ONCE THIS IS DETERMINED AND PAID, THE ACTUAL COST OF INTERCONNECTION IS FULLY COVERED. SO, UH, WE THINK THAT ANY SECURITY BEYOND THAT SERVES NO RESIDUAL RISK MITIGATION FUNCTION. AND LASTLY, UM, THE STUDY VALIDITY CUTOFF IN, UH, SECTION 9.2 0.4 WE BELIEVE SHOULD BE EXTENDED TO JULY 10TH. UM, AND WE APPRECIATE THIS CHANGE TO MARCH 4TH AS A MEANINGFUL IMPROVEMENT THAT'S ALREADY BEEN AT THE CORE OF STAKEHOLDER FEEDBACK. UH, BUT RESPECTFULLY THIS SUGGESTS IT SHOULD GO ONE STEP FURTHER TO JULY 10TH AND MAKING A COLLABORATIVE, UH, PROCESS WORKING WITH CUSTOMERS AND TSPS TO MAKE THIS DETERMINATION, UH, IDENTIFYING WHEN, WHERE THERE ARE DISCREPANCIES AND, AND A CURATIVE PROCESS THERE. UM, AS MANY STAKEHOLDERS HAVE HIGHLIGHTED TODAY, UM, BACKDATING AND INVALIDATING STUDIES POSES MAJOR CHALLENGES FOR CUSTOMERS. WE PROJECTS THAT HAVE STARTED CONSTRUCTION, UM, AND HAVE, UH, BEEN WAITING FOR T-S-P-N-R CALL CONFIRMATION FOR MONTHS THAT WE'VE MET 9.4, 9.5 FOR MONTHS WITH WHAT WE'VE REALLY PREVIOUSLY, UH, UNDERSTOOD TO BE, UH, APPROVED AND FIRM AND READY TO GO. SO WE SUGGEST MAKING THE STATE CONSISTENT WITH THE JULY 10TH CUTOFF, UH, WITH ALL THE OTHER EVIDENCE, UH, AND, UH, ALLOWING, HAVING PROCESSES, ALLOWING CUSTOMERS TO WORK WITH TSVS AND ERCOT, UH, FOR MAKING THE DETERMINATION AS A, A PATH TO RESOLUTION. AGAIN, APPRECIATE THE OPPORTUNITY TO COMMENT HERE TODAY, UH, AND THANK YOU VERY MUCH. ALRIGHT, THANK YOU ANGELA. ANY QUESTIONS FOR ANGELA? ALRIGHT, WE'LL MOVE ON TO PRASHANT. PRASHANT, ARE YOU ON? YES. ALRIGHT, LET ME OPEN YOUR COMMENTS. YOU CAN GO AHEAD AND START WHEN YOU'RE READY. YEAH, YEAH. UM, I'M GONNA SPEAK IN GENERAL. UM, SO FIRST OF ALL, UH, THANKS FOR, UM, AND ALL THE STAKEHOLDERS FOR THE FEEDBACK SO FAR. UH, UH, OUR COMMENT IS MAINLY, UH, ON THE MARCH FOR, UH, CUTOFF TIMELINE, UM, THAT PUT IN THEIR RE UH, COMMENTS. UM, SO ONE MAIN CONCERN WITH THAT, ONE, JUST PUTTING THE, UH, BASICALLY CATEGORIZING AS BASE LOAD PROJECTS BASED ON CUT UPDATES, UM, RATHER THAN BASICALLY, UH, UH, YOU KNOW, UH, ADVANCED PROJECTS OR EXECUTION READY PROJECTS. UH, THE, I'M MAINLY REFERRING TO PROJECTS THAT ARE, UM, UH, ENERGIZING IN 2027. UH, UH, WE BELIEVE THAT ANY PROJECT SUCH COMING IN 2027 AS OF THE CURRENT BA ZERO CRITERIA, THEY ARE, UH, SUBJECT TO ADDITIONAL REQUIREMENTS. THEY HAVE TO, UH, BASICALLY DEMONSTRATE, UH, ADDITIONAL DEVELOPMENT MILESTONES THAT ARE NOT APPLICABLE TO PROJECTS COMING IN 2028 OR 2029, UH, WHICH IS VERY SIGNIFICANT AMOUNT OF, UH, I MEAN THEY'RE VERY SIGNIFICANT. UH, BASICALLY ALL THE EQUIPMENT PROCURE, SITE REPAIR READY. SO ADDING ONE MORE HURDLE TO THE 2027 PROJECTS IS, UH, I MEAN IT'S JUST, UH, I I WOULD SAY THE ADDITIONAL PAIN. UH, SO RIGHT NOW, SO WHAT WE ARE BASICALLY ASKING WE'VE GOT HERE IS ANY PROJECTS SUCH REQUESTING ENERGIZATION IN 2027. SORRY, YOU'RE STARTING TO CUT OUT. CAN YOU GET A LITTLE CLOSER TO THE MIC? YES, CAN YOU HEAR ME? YEP, THAT'S BETTER. WE JUST LOST LAST FIVE SECONDS SO YOU CAN KEEP GOING. OKAY. YEAH, SO OUR ASK SQUARE COURT IS TO BASICALLY INCLUDE ALL THE PROJECTS THAT ARE REQUESTING ENERGIZATION IN 2027 AS PART OF THE BASE LOAD AND ALLOW THEM TO BASICALLY FORM UP THE LOAD AND ARE SUBJECT TO THE MARCH FOUR CRITERIA. UM, SINCE THOSE PROJECTS ALSO NEED TO DEMONSTRATE ADDITIONAL MILESTONES, DEVELOPMENT MILESTONES, UM, BASICALLY GOING BACK AND FORTH ON A ROLLING BASIS BETWEEN BASICALLY CON MAY NOT WORK BECAUSE, UH, THESE PROJECTS NEED EVERY, EVERY DAY, EVERY HOUR TO BASICALLY DEMONSTRATE THOSE MILESTONES. SO WE REQUEST BASICALLY TO, UH, EXCLUDE PROJECTS THAT ARE REQUESTING ENERGIZATION IN 2027 FROM, UH, FROM THE MARCH FOR, UH, CUTOFF CRITERIA. AND THAT'S ONE REQUEST. UH, ANY QUESTIONS FROM THAT ONE? ALRIGHT, THANK YOU. YES. ANY QUESTIONS FROM THE GROUP? UM, IF NO QUESTIONS, UM, ONE OTHER COMMENT WHICH WE DID NOT INCLUDE HERE IS BASICALLY, UM, ON [04:05:01] THE 50TH, UH, AGAIN, AND I'M JUST GONNA, UH, PUT IT HERE. UM, THIS IS A RESPONSE TO, UH, QUIET FOR IT ONE, BUT, UH, UH, HAVING THE $50,000 REQUIREMENT, LIKE CRUSO SAID, I MEAN, ANYTHING THAT'S FORMED UP SHOULD BE, UH, AUTOMATICALLY, UH, GRANDFATHERED. I WOULD SAY. UM, UM, THE REASON BEING YOU KNOW, IF THERE, IF WE ARE, I MEAN WE BASICALLY ASK THIS ONE IN THE FIRST LLW MEETING ITSELF, THAT ANY LAWS THAT ARE FORMED UP SHOULD NOT BE ADDITIONALLY AS SUBJECT TO THE 50 OR AT THE TIME A HUNDRED THOUSAND DOLLARS PER MEGAWATT CRITERIA. THE REASON BEING, LET'S SAY IF A LOAD IS IN DUAL TERRITORIES, FOR EXAMPLE, THERE IS A TSP, IT'S NOT A LOAD SERVING ENTITY, BUT WE HAVE TO DEAL WITH ANOTHER, UH, TSP. WE ARE BASICALLY POSTING SOMETHING TO 80, NEARLY 80 MILLION IN JUST FOR THE SUB BUILDING TWO SUBSTATIONS. SO THAT IS A VERY SIGNIFICANT AMOUNT. AND ADDING 50, UH, THOUSAND DOLLARS PER MEGAWATT ON TOP OF THAT IS BASICALLY DUPLICATED. SO WE REQUEST, UH, AIR CODE OF ITY TO CONSIDER THIS AND AT LEAST PUT A LIMIT ON WHAT IS THE MAXIMUM UH, YOU NEED TO POST AT BASICALLY TAKING INTO ACCOUNT HOME SECURITIES YOU HAVE POSTED FOR BOTH PER AS PART OF YOUR AGREEMENT. AND THEN MAYBE, YOU KNOW, IF IT'S LESS THAN WHATEVER THE MAX THAT IS DETERMINED, JUST POST THAT ADDITIONAL AMOUNT. SO THANK YOU. ALRIGHT, THANK YOU. ALRIGHT, THEN NEXT UP IS, UH, CHRISTINA AKA UH, THREE WATER TECHNICAL SERVICES. CHRISTINA, ARE YOU ONLINE? CHRISTINA? ONE MORE TIME. I'LL COME BACK TO YOU. NED, I SAW YOU IN THE ROOM. YES, THERE WE GO. THANK YOU MATT. UH, NED ROSS WAS SANDOW. I'M GONNA GO VERY QUICKLY. I'LL GIVE YOU FIVE MINUTES BACK, MATT. HEY, UH, THREE, THREE QUICK POINTS. A A EP ALREADY HIT ON THIS EARLIER. UH, THANK YOU FOR THAT. THE FIRST ONE BEING, RATHER THAN GETTING TIED UP IN THE LOG JAM HERE AT ERCOT AND AWAITING INTERCONNECTION AGREEMENT, WE SHOULD BE LOOKING AT US HAVING DONE OUR JOBS, THE TSPS HAVING DONE THEIR JOBS AND SUBMITTED IT TO ERCOT. AND THAT THAT SHOULD BE THE TRIGGER THAT GETS US INTO BATCH ZERO. UH, ANY OTHER OUTCOME IS GOING TO TIE UP. WHAT I AM SEEING IS NORTH OF A HUNDRED BILLION DOLLARS IN CAPITAL INVESTMENT IN THE STATE. AND I JUST DON'T FIND ERCOT WANTING TO BE IN A POSITION OF BEING THE LINCHPIN FOR THAT EITHER. SECOND POINT RELIANT, HIT ON THIS EARLIER A BIT DIFFERENTLY. UM, AND THAT IS WE SHOULD HAVE INCENTIVES FOR THESE PROJECTS TO BRING THEIR OWN GENERATION. ERCOT SHOULD HAVE AN INCENTIVE, AND THAT IS ELEVATING THE PRIORITY IN THE QUEUE FOR THOSE PROJECTS THAT BRING SOMETHING LIKE 80% OR MORE OF THE GENERATION TO THE TABLE. OKAY? I THINK THAT'S CRITICAL 'CAUSE WE'RE SIMPLY NOT GONNA HAVE ENOUGH GENERATION TO MEET ALL THIS DEMAND. THIRD, AND, AND I DON'T THINK THIS HAS BEEN ADDRESSED AND, AND A LOT OF YOU GUYS HAVE MADE YOUR LIVING HERE AT ERCOT, UH, I HAVEN'T DUG THROUGH ALL THE PROTOCOLS, BUT THERE'S NOTHING IN HERE ABOUT THE FEDERAL GOVERNMENT CONTACTING ERCOT AND SAYING, WE NEED YOU TO GET THIS INTERCONNECTED, THIS NATIONAL SECURITY, NATIONAL DEFENSE, NATIONAL INTEREST, INTERCONNECTED TO THE GRID RAPIDLY. AND I THINK RATHER THAN HAVE A, A SITUATION WHERE YOU MAY HAVE TO SUSPEND THIS PROCESS TO DEAL WITH IT, YOU SHOULD INCLUDE SOMETHING IN HERE THAT SAYS THERE IS A NATIONAL INTEREST AT STAKE AND WE'LL WEAVE IT INTO THIS PROCESS IN THIS WAY. DOES THAT MAKE SENSE? SO I JUST TOSS THAT OUT FOR YOUR CONSIDERATION AND YOU GET YOUR FIVE MINUTES BACK. ALRIGHT, THANK YOU NED. ALRIGHT, ANY QUESTIONS FOR NED? ALRIGHT, THANKS SIR. ON IS UH, MICHAEL PAN, FILL WITH EMERALD DAY. I MICHAEL PAN. BILL, ARE YOU ONLINE? ALRIGHT, I'LL GO BACK TO CHRISTINA GARCA OR GARA. OKAY. I HAD NOT HEARD FROM EITHER OF THEM. SO THOSE WERE MAYBE'S. AARON DID HER PART. SO MICHAEL JULES, WE'RE DOWN TO THREE. THAT GOT QUICK, FAST. WELL, I SAY THAT WE STILL HAVE THREE MORE. OKAY. MICHAEL, I WILL OPEN THE MONARCH ENERGY COMMENTS FOR YOU, SIR. SO, THANK YOU, UH, MICHAEL JEWEL ON BEHALF OF MONARCH ENERGY, UH, AND DEFINITELY, UH, APPRECIATE ALL THE WORK THAT'S GONE INTO DEVELOPING, UH, THIS PROCESS THUS FAR. ONE OF THE KEY THINGS FROM MONARCH'S PERSPECTIVE IS THAT DEMONSTRATED FINANCIAL COMMITMENT TO SYSTEM INFRASTRUCTURE IS A KEY INDICATOR OF PRODUCT PROJECT READINESS. AND SO IF, UH, IF A, UH, UH, LLIS HAS GONE THROUGH, THEY'VE BEEN DOING THEIR STUDIES, THEY'VE MET THE REQUIREMENTS OF [04:10:01] PLANNING GUIDE 9.4, 9.5, THEY PAID THEIR FINANCIAL COMMITMENTS THROUGH KAYAK, THAT THAT SHOULD BE RECOGNIZED AND, UM, THAT THEY SHOULD BE ELIGIBLE TO BE ABLE TO MOVE FORWARD IN THIS PROCESS. UM, ONE OF THE, UH, ANOTHER ISSUE THAT, THAT WE ADDRESS IN THESE COMMENTS IS THE REQUIREMENT FOR HAVING AN INTERCONNECTION AGREEMENT THAT COMPLIES WITH THREE REQUIREMENTS OF SECTION 9.7 0.2. UM, AS ER IS ALREADY RECOGNIZED IN PLANNING GUIDE 9.5, THERE ARE EQUIVALENT SERVICE EXTENSION AND OTHER AGREEMENTS OTHER THAN AN INTERCONNECTION AGREEMENT THAT SUPPORT THE ENERGIZATION OF A LARGE LOAD TODAY. AND SO THAT THOSE SHOULD BE RECOGNIZED AS WELL. THE OTHER RE THE OTHER ISSUE IS RELYING ON AN INTERCONNECTION AGREEMENT THAT, UH, COMPLIES WITH THE REQUIREMENTS OF 9.7 0.2 IS IMPOSSIBLE TODAY BECAUSE ONE OF THE KEY ELEMENTS OF THAT INTERCONNECTION AGREEMENT WILL NOT BE DECIDED UNTIL AFTER THE BATCH LOAD STUDY IS DONE. SO YOU CANNOT MEET THAT TODAY. SO A LITTLE BIT OF FLEXIBILITY WITH REGARD TO THAT LANGUAGE, FRANKLY, IS, IS, IS UH, IMPORTANT. UH, FINALLY, WITH REGARD TO, UH, BATCH ZERO AND THE 2026 RTP, THE, UM, THERE'S VARIOUS PROCESSES THAT, UH, HAVE BEEN MOVING FORWARD WITH REGARD TO LARGE LOAD FORECASTING, LARGE LOAD INTERCONNECTION, ERCOT COMPLIANCE PLAN, AS WELL AS P 1 45. AND THE, UM, YOU KNOW, AS THE 2026 RTP AND THE ERCOT COMPLIANCE PLAN WERE PRESENTED INITIALLY, THE, UM, YOU KNOW, ONE OF THE QUICK, ONE OF THE KEY QUESTIONS THAT CAME UP IS, DOES A LOAD NEED TO BE IN THE 2026 RTP IN ORDER TO BE ELIGIBLE TO BATCH ZERO? AND THE FEEDBACK HAS ALWAYS BEEN NO, THAT THESE ARE INDEPENDENT. AND SO ONE OF THE CONCERNS IS, IS THAT LOADS THAT HAVE, UH, BEEN RELYING ON THAT GUIDANCE THUS FAR, AND ESPECIALLY WHEN WE'RE COMING UP TO LESS THAN ONE WEEK BEFORE ERCOT IS, IS ASKED THE, UH, TDS PS TO PROVIDE ALL THE INFORMATION WITH REGARD TO THE 2026 RTP. UM, THOSE LOADS NOW WILL BE SIGNIFICANTLY, UH, DISADVANTAGED FOR HAVING LISTENED TO THE GUIDANCE THAT THEY'VE BEEN RECEIVING. UM, THE OTHER THING IS THE ERCOT COMPLIANCE PLAN HAS ELEMENTS IN THERE THAT THE COMMISSION HAS ALREADY REJECTED AND REJECTED FOR, AND ALLOWED ADDITIONAL OPTIONS LIKE SITE CONTROL FOR REASONABLE PURPOSES THAT WERE A PROBLEM. SO HERE AGAIN, RELYING ON THE 2026 RTP COULD BE PROBLEMATIC. UM, SO ANYWAY, WE PROPOSED THAT IT'S, UH, IN OUR COMMENTS WITH REGARD TO ALL OF THAT AND BE HAPPY TO ANSWER ANY QUESTIONS. ALRIGHT, THANK YOU MICHAEL. ANY QUESTIONS FOR MICHAEL? HEY, MATT, THIS IS BARK SALE. UM, I, I THINK WITH REGARD TO THE 2026 RTP COMPLIANCE PLAN THAT'S DONE, IT'S DUSTED. WE'RE NOT GONNA GO BACK AND REDO IT, UH, BECAUSE THAT WOULD REQUIRE A WHOLE NEW, UH, PROBABLY RULEMAKING TO ADDRESS THAT. SO I THINK WE WERE CLEAR WHEN WE SAID THAT IF YOU'RE INCLUDED IN THE 26 RTP, THAT DOESN'T NECESSARILY MEAN THAT YOU'RE INCLUDED IN BATCH. AND WE'VE BEEN SAYING THAT SINCE JANUARY. UM, AND THE REQUIREMENTS TO GET INTO AN RTP FOR THAT COMPLIANCE PLAN WERE BUILT, UH, PRIOR TO THE CONCEPT TO THE ADVENT OF THIS BATCH PROCESS. AND SO, AS HAS BEEN THE THEME OF THE DAY, WE ARE IN THE MIDDLE OF THE MESSY TRANSITION BETWEEN SERIALIZED TRANSMISSION, TRANSMISSION PROJECT PLANNING, GOING INTO A BATCH PROCESS PLANNING PLANNING PROCESS. UM, IT'S NOT GONNA BE CLEAN, IT'S NOT GONNA BE EASY, BUT WE NEED TO MOVE THROUGH IT. THE COMPLIANCE PLAN IS THE COMPLIANCE PLAN FOR 2026 OR TP P. CAN I FOLLOW UP ON THAT PLEASE? YEAH, BARKSDALE, MY, MY THOUGHT WAS NOT TO REDO THE COMPLIANCE PLAN. YOU'RE RIGHT, IT IS WHAT IT IS. I THINK THE QUESTION IS SHOULD BEING IN THE, UH, 2026 RTP BE A CONDITION PRECEDENT FOR BEING IN BATCH ZERO? AND THE GUIDANCE TO DATE HAS BEEN NO. AND SO THAT'S REALLY THE CONCERN IS TO THE EXTENT THAT PROVISIONS IN P 1 45 DIRECTLY OR INDIRECTLY REQUIRE YOU TO BE IN THE 2026 RTP, THAT'S WHERE THE ISSUE [04:15:01] IS, NOT IN WHAT THE COMPLIANCE PLAN IS, BECAUSE IT IS WHAT IT IS. ALL RIGHT. THANK YOU. YOU'RE WELCOME. ALL RIGHT, NEXT UP IS KEVIN MCMEAN. I SEE YOU ON THE WEB WEBEX. I, I CAN SPEAK ON BEHALF OF KEVIN, UH, FROM CROW HOLDINGS. UM, GREAT. CAN YOU INTRODUCE YOURSELF REAL QUICK? YEAH. DYLAN SMITH FROM CROW HOLDINGS. EXCELLENT, THANK YOU. UM, THE, WE JUST HAVE ONE POINT, WE CAN BE QUICK. UH, IT'S BEEN MADE, UH, A NUMBER OF TIMES, I JUST WANNA BE REDUNDANT BECAUSE WE THINK IT IS, UH, PARAMOUNT IMPORTANCE, BUT WE WANT TO BE SURE THAT LEGACY LARGE LOAD INTERCONNECTION STUDIES, UM, WITH SIGNED AGREEMENTS AND POSTED FINANCIAL SECURITIES, UH, BE TREATED AS FIRM LOAD, UM, IN THE, IN THE NEW BATCH STUDY. UM, WE HAVE ALSO, UM, A, A AGREEING WITH ENCORE'S. I I THINK IT WAS POINT NUMBER TWO, UH, REMOVED THE T-S-P-D-S-P SITE CONSTRUCTION ATTEST STATION, UM, AGREED THAT IT, UH, IS, IS POTENTIALLY PROBLEMATIC AND, AND DIFFICULT. UM, THOSE ARE OUR TWO POINTS. UH, AND AGAIN, ACKNOWLEDGE THAT THEY'VE BEEN MADE A NUMBER OF TIMES, BUT WE JUST THINK THEY'RE, THEY'RE IMPORTANT. ALRIGHT, THANK YOU KEVIN. ANY QUESTIONS FOR KEVIN? ALRIGHT. AND THEN MIKE TABI, ARE YOU ONLINE? HEY, THIS IS DYLAN NOAD WITH ZERO MISSION GRID. I'M GONNA BE RESPONDING ON BEHALF OF MIKE. ALRIGHT, LEMME OPEN IT UP. AND I THINK THIS ONE WILL ALSO BE PRETTY BRIEF. GO AHEAD. SO FIRST, UM, JUST WANT TO ALSO THANK KO, UM, FOR, SORRY, IF YOU CAN SPEAK UP A LITTLE BIT, THAT'D BE GREAT. CAN YOU HEAR ME OKAY? THAT'S A LITTLE BETTER. OKAY. IF YOU'RE, SO FIRST JUST WANT TO THANK KOT FOR INCORPORATING THE COMMENTS AROUND THE DYNAMIC MODELING LANGUAGE AND FOR ALSO ADDING THE CLARITY AROUND THE FOUR BATCH ZERO BASE CASES BEING UPLOADED TO THE MIS SECURE, UM, AS OPPOSED TO THE MIS CERTIFIED. UM, JUST TWO POINTS WE WANTED TO BRING UP TODAY. FIRST, UM, IS A REQUEST IN ADDITION TO THE, THE FOUR BATCH ZERO BASE CASES. UM, IF ERCOT COULD ALSO INCLUDE ANY OF THE AUXILIARY FILES SUCH AS LIKE THE CONTINGENCY DEFINITIONS OR CONTINGENCY FILES THAT ARE USED DURING THOSE BASE CASE BUILDS. UM, AND ALSO UPLOADING THOSE TO MIS S SECURE, UH, HAVING THE FULL SET OF THOSE FILES WILL GIVE ILES, UM, THE OPPORTUNITY TO PERFORM SOME OF THE TECHNICAL DUE DILIGENCE BEFORE COMMITTING THE PROCESS. SO THAT'S ONE. AND THEN SECONDLY, AND APOLOGIES IF THIS HAS ALREADY BEEN ANSWERED EARLIER TODAY, UM, BUT WE JUST WANT TO, UH, LOOKING FOR A BIT MORE CLARITY ON THE DEFINITION OF THE INITIAL ENERGIZATION FOR LARGE LOADS. UM, RIGHT NOW HOW IT'S CURRENTLY WRITTEN IN SECTION TWO OF THE NOAL PROTOCOLS, IT'S NOT ENTIRELY CLEAR WHETHER IT'S THE POINT WHEN THE SUBSTATION ITSELF IS ENERGIZED, WHICH COULD MAYBE ALREADY INCLUDE SOME AUXILIARY LOAD OR WHEN THE ACTUAL END USE EQUIPMENT LIKE GPUS COME ONLINE. SO, WHICH COULD ALSO BE MUCH, MUCH LATER, UM, DOWN THE ROAD. SO YEAH, THAT'S ALL OF OUR COMMENTS. ALRIGHT, THANK YOU VERY MUCH. ANY QUESTIONS OR COMMENTS FROM THE GROUP? EXCELLENT. ALRIGHT, WELL WE HAVE IS BEFORE WE JUMP INTO THE BRING YOUR OWN GEN, I'M SORRY, UM, BROTH, DID YOU STILL WANNA ASK YOUR QUE OH, YOU GOT IT COVERED? AWESOME. THE QUESTION FROM TWO HOURS AGO. VERY PATIENT MAN. ALRIGHT, SO WHAT I WANTED TO DO IS, UM, WE HAVE A COUPLE SLIDES TO KIND OF SUMMARIZE, SLICE AND DICE EVERYTHING THAT CAME IN THE DOOR. IF YOU DIDN'T, IT'S LIKE IF YOU'RE TRYING TO GET YOUR HEAD AROUND WHERE ALL THE COMMENTS WERE FOCUSED, UM, WE HAVE SOME ANALYSIS AROUND THAT JUST ON A COUPLE SLIDES. AND THEN WE'LL PIVOT QUICKLY INTO THE CLR AND BYOG INFORMATION. SO LET ME GET THE, GOING BACK TO THE MAIN SLIDE DECK. ALL RIGHT, GOING DOWN TO, OKAY, THERE'S PRETTY PICTURES OF ALL YOUR COMPANIES. ISN'T THAT NICE? THAT'S, SO HERE'S A KIND OF A FEEDBACK RECEIVED AND THEN WHAT, UM, WE HAD SOME HELP DOING WAS WHAT ARE SOME OF THE RECURRING FEEDBACK THEMES, UH, THAT WE FOCUS ON? AND I'LL PROBABLY LIFT A COUPLE OF THESE TO TAKE TO TACK TOMORROW. NOT 'CAUSE WE'RE GONNA SOLVE ANYTHING AT TAC OR ROS YET, BUT IT'S [04:20:01] THE, WHERE ARE WE AT? UM, I'M NOT GONNA READ ALL THESE UNLESS YOU WANT TO COME BACK TO THEM BECAUSE THEY'VE BEEN POSTED. BUT HERE'S THE INTERESTING ONE. THIS IS WHERE, HOW MANY OF THE COMMENTS HAVE BEEN ON ELIGIBILITY AND MAIN STAKEHOLDER FEEDBACK? UH, HOW ABOUT THIS CROSS CUTTING, UM, STANDARDIZATION ACROSS DIFFERENT COMPANIES, COMMITMENT CRITERIA AGREEMENTS, BATCH STUDY METHODOLOGY, QUARTERLY STABILITY. AND WHAT ERCOT IS GONNA DO IS TRY TO DECONSTRUCT THE COMMENTS INTO SOME SORT OF SPREADSHEET AND MAY ROLL IT UP A BIT TO ADDRESS THESE ELEMENT BY ELEMENT IN A WAY. SO THAT'S OUR WAY OF GIVING THE FEEDBACK TO YOU OF, YES, WE AGREE AND HERE'S WHAT WE'VE CHANGED, OR THIS IS A MESS EVERYONE'S OVER, YOU KNOW, THERE'S NO WINNERS OR LOSERS ON THIS, BUT WE STILL THINK THIS IS THE RIGHT ANSWER JUST TO START TO GIVE A DISPOSITION OF THOSE. IT'S GONNA BE A STRETCH TO MAKE THE NEXT MEETING SIX DAYS FROM NOW WITH ALL OF THAT. BUT THAT IS WHERE WE DEFINITELY WANNA START FINDING WHERE THE HOT BUTTON ISSUES ARE AND GETTING INTO SOLVING THEM. UM, AND AGAIN, IT IS INTERESTING, THE COMMITMENT WINDOW IS KIND OF A LOW THING, BUT I'VE HEARD MORE THAN ONCE TODAY, 30 DAYS IS NOT ENOUGH. IT SHOULD BE 60 ERCOT IS REALLY HANGING ITS HAT ON THAT. SO THAT'S A BIT OF A SURPRISE TO SEE IF WE'RE TRYING TO GO BACK ON THAT ONE AND LENGTHEN THE PROCESS BY GETTING THOSE EXTRA 30 DAYS. BUT AGAIN, WE'LL KIND OF, THAT MAY BE SOMETHING WE'LL PUT OUT THERE ON A SURVEY TO SEE IF THIS IS A, SOMETHING THAT EVERYBODY NEEDS AND IT'S THE RIGHT THING TO DO EVEN IF IT SHIFTS THE TIMELINE OUT. SO, UM, BUT LET ME GO AHEAD AND AGAIN, THOSE SLIDES ARE OUT THERE FOR YOU TO GO BACK AND CHEW ON. WE'RE CHEWING ON THEM AND TRYING TO FIGURE OUT WHERE, WHAT THE NEXT STEPS ARE IN TERMS OF MOVING FORWARD. [5. Discussion of CLR and BYOG concepts] SO WE HAVE AN HOUR AND A HALF TO TALK ABOUT BRINGING YOUR OWN GEN IN CONTROL LOAD RESOURCES. AGAIN, ECHOING BACK, THIS IS THE SAME SLIDES FROM LAST TIME, WHICH IS WHAT DID YOU THE STAKEHOLDER COMMITTEE SAY NEED TO HAVE? AND WE HEARD, YOU KNOW, A LOT ABOUT THE BYOG SELF LIVING FACILITY. WE'LL USE IT IF WE HAVE TO. LEMME JUST KIND OF FLIP THROUGH FOR CLR AND BYOG, WHICH CO-LOCATION CONFIGURATIONS DO YOU WANT? WHICH TECHNOLOGIES AND YES, MOSTLY WAS DISPATCHABLE, BUT ALL THE OTHER STUFF TOO FOR BYOG IS SELF-LIMITING GOOD ENOUGH? REMEMBER THIS IS ONE THAT YOU KIND OF SET IT AND FORGET IT FOR A WHOLE YEAR. IT'S A VERY LIMITING CONSTRUCT. STILL GOT AN 80% THUMBS UP SAYING, HEY, IT'S BETTER THAN NOTHING. MAYBE WHAT'S BEHIND THAT? IF I HAD TO GUESS, UM, IF BATCH ZERO PROVIDES LESS THAN FIRM CAPACITY, WOULD YOU CONSIDER CLING THE REST, BE FLEXIBLE ON YOUR HEADROOM AND BIG 80%? YES. LET'S DO THAT. OOPS. UH, WHEN DEFINING BYOG RULES SHOULD CONTROL LOAD CONCEPTS BE EXPANDED TO BE EXPLICITLY INCLUDED AS A CO-LOCATION? UM, PEOPLE SAID YES, THAT FLEXIBILITY IS GREAT. WE'RE KIND OF KEEPING THE DOOR CLOSED ON THAT A BIT, BUT WE'LL TALK ABOUT THAT ON THE NEXT SLIDES. UM, AND THEN RATHER NOT TO PRE-REGISTER AHEAD OF ERCOT RUNNING THE BATCH, DO YOU NEED TO DECLARE WHAT YOU PLAN TO DO IF YOU PLAN TO BE ACL R? UM, OR IS IT SOMETHING YOU HAVE THE OPTION AFTER THE RESULTS ARE RELEASED THAT THAT'S SOMETHING YOU MAKE A DECISION ON? AND SO SAME SLIDE AS BEFORE. SO WE TALKED ABOUT THE LOAD ONLY CLR, SORRY ABOUT THE SPACING. SO I DID CLEAN THIS UP. I KNOW I MADE A MESS LAST TIME. PEOPLE ARE LIKE, THIS IS CRAZY. YOU'RE GONNA HAVE A LOAD ONLY CLR AND NOT ALLOW ANY OTHER GEN ON THE SITE. AND THAT'S NOT WHAT WE IMPLIED. SO WE CLEANED THAT UP A LITTLE BIT. THEN THERE'S ALSO THE CLR WITH A NON SYNCHRONOUS BACKUP. SO A, YOU KNOW, DISCONNECTED BATTERY OR DC TIDE BATTERY BEHIND THE FENCE. AND THEN THE IDEA OF A-B-Y-O-G SELF-LIMITING FACILITY. AND THEN THE, UH, NETTED NETWORK WE SAID WAS NOT FEASIBLE FOR BATCH ZERO. SO THIS IS THE SAME EXAMPLE YOU'VE HAD, UH, WHICH WAS A THOUSAND MEGAWATT LOAD. AND WHETHER OR NOT IN THE STUDY YOU ARE GRANTED A LOAD COMMISSIONING ALLOCATION THAT'S LESS THAN YOU WANTED, THAT'S THE A HUNDRED, A HUNDRED, 300, 300. AND THEN WHETHER OR NOT YOU WOULD BE A CLR FOR THE REMAINING AMOUNT ERCOT THINKS WE HAVE. WHAT WE NEED TO DO THIS. UM, AGAIN, I WON'T READ ALL THESE THINGS. THE KEY ELEMENT IS THIS IS NOT JUST ANOTHER CLR, THIS IS NOT ANOTHER BITCOIN CLR. THIS WILL BE BOXED IN BY TRANSMISSION CONSTRAINTS. THAT WILL BE SOME SORT OF MAGIC THAT CY MORTY HELPS TO DETERMINE, WHICH IS WHAT IS THAT SC STEP TWO CALCULATION BASED ON SHIFT FACTORS, TRANSMISSION CONSTRAINTS, THOSE PENALTY FACTORS TO DRIVE YOUR OFFER TO CONSUME AT HUNDREDS OF DOLLARS DOWN TO $70 IF THERE'S CONGESTION. AND THEN YOU WON'T PRODUCE AND YOU'LL BACK DOWN. SO SC EVERY FIVE MINUTES WILL PUT YOU BACK IN THE BOX TO BE IN A SAFE SPOT AND THEN LET YOU BACK OUT AGAIN WHEN THE TRANSMISSION CONSTRAINTS ARE RELIEVED. SO THAT'S THE FLEX THAT WE'RE LOOKING AT. THAT'S EVERY FIVE MINUTES. IT'S NOT EASY STUFF, BUT IF PEOPLE WANNA SIGN UP FOR THAT, THAT'S SOMETHING THAT CAN BE DONE. SO ERCOT HAS THE ACTION ITEM TO COME BACK WITH LANGUAGE AS SOON AS POSSIBLE ON THAT ONE. NOW WITH REGARDS TO, WE ALSO DESCRIBED CLRS AND IN TERMS OF CO-LOCATION, [04:25:01] WE CANNOT HAVE A LOAD THAT CO-MINGLES WITH A BIG BATTERY OR A BUNCH OF DIESELS AT 10 MEGAWATTS, 20 MEGAWATTS AND PRETEND THAT'S A PUT A CIRCLE AROUND IT, CONTROL BELOW, WE WON'T LET THAT HYBRID OR THAT AMALGAMATION BE A THING. IT'S ALWAYS GONNA HAVE TO BE ONE THING AND THE OTHER. AND THAT BECOMES A CO-LOCATION SCENARIO. NOT THIS. HOWEVER, AGAIN, IF THERE'S NO, YOU KNOW, A SYNCHRONIZED PATH TO THAT, THAT THAT COULD BE SOMETHING THAT'S A BACKUP GENERATION IN THE BACKYARD THAT ERCOT IN SOME WAYS DOESN'T EVEN SEE THAT WHEN WE SEE THE LOAD NEEDS TO GO DOWN, IT GOES DOWN. THE FACT THAT IT'S BEING BACK FED IS A YOU THING. ERCOT IS SEEING IT LOAD GO DOWN. BUT AGAIN, ANYTHING THAT IS BIG ENOUGH HAS TO BE A REGISTERED LOAD PER ERCOT RULES. AND THAT'S WHAT TAKES YOU INTO THIS CONFIGURATION, WHICH IS HAVING LOAD AND GEN AT A SITE. AND HOW DO WE WANT TO, UM, BE ABLE TO ALLOW THIS CONFIGURATION? HERE'S THE THING THAT KEEPS COMING. PEOPLE KNOCK ON OUR DOOR, WE WANNA DO THIS, BUT WE CAN'T BECAUSE THE G MINUS ONE SAYS WE STILL HAVE, WE ARE NOT APPROVED AS A LOAD WITH G MINUS ONE BECAUSE OF IT'S GONE. THERE'S NO WAY TO SERVE THAT LOAD. AND SO IT DOESN'T SURVIVE THE PLANNING CRITERIA WHICH WE'RE WILLING TO REVISIT FOR BATCH ZERO. SO WE STILL DON'T HAVE THE LANGUAGE YET ON THIS CONCEPT, BUT IT'S THE IDEA OF WHAT DOES A SELF-LIMITING FACILITY LOOK LIKE TO WHERE IF YOU ARE A LOAD WITH A GEN OR TWO OR THREE OR FOUR GENERATORS, THAT WE CAN PUT A CIRCLE AROUND THAT AND YOU CAN AGREE TO SOME SORT OF SELF LIMIT, WHICH IS TO SAY, I WILL NEVER WITHDRAW MORE THAN A HUNDRED MEGAWATTS EVEN IF I'M CONSUMING A THOUSAND MEGAWATTS BECAUSE I HAVE A GIN ON SITE. BUT WE'RE GONNA NEED AN OPERATING AGREEMENT AROUND THAT THAT SAYS IF THE GEN'S DOWN, I'M DOWN, THERE'S NO LEANING ON THE GRID. AND TO THAT END, WE'RE TALKING ABOUT WHETHER OR NOT WE MAY EVEN WANT YOU TO HAVE EQUIPMENT THAT TAKES YOU OFF THE GRID BEFORE YOU OVERLOAD THAT. UM, SO ANYWAYS, WE COVERED ALL THIS THIS BEFORE, BUT WHAT I WANTED TO DO WAS MAKE ROOM FOR, I'M SORRY, HERE'S THE LAST ONE ON THE NETTED NETWORK. OKAY, I'M LOOKING AT CHRIS MATOS AS I READ THIS ONE. LISTEN PAL, I I THINK WE'RE STARE AT ME IN THE EYE, LOOKING IN THE EYE AS I SAY THIS ONE. UM, I'VE TALKED WITH S QUITE ABOUT, QUITE A BIT ABOUT THIS. THE NETTED NETWORK, STRICTLY SPEAKING IS A WAY OF A NETWORK LIKE THIS TO THEN ALLOW DIFFERENT ANCILLARY SERVICES TO BE UNIT SPECIFIC, LOAD SPECIFIC BEHIND THE FENCE AND OPTIMIZE WHAT'S THERE. WHATEVER IS APPROVED IN THE BATCH PROCESS, IRRESPECTIVE OF NETTED NETWORK OR PRIVATE USE NETWORK, WHATEVER THIS IS, DOES NOT CHANGE OR GET YOU ANYTHING IN THE BATCH PROCESS. NOW COMMERCIALLY YOU MAY BE PENCILING SOMETHING TO SAY, I WONDER IF I CAN COUNT ON ANCILLARY SERVICES. IF YOU PURSUE CONNECTING THE SYSTEM, THE NETTED NETWORK SYSTEM CAN STILL EVOLVE AS A MARKET DESIGN AND BE IMPLEMENTED AND THEN YOU CAN TAKE ADVANTAGE OF THAT MARKET IN OPERATIONAL EFFICIENCY WHEN IT'S THERE. BUT IN TERMS OF THE BATCH PROCESS, THAT'S WHY WE KIND OF DISTANCE OURSELVES TO SAY WE CAN'T SOLVE THIS. IT'S NOT EVEN ON PAPER YET. AND THAT'S THE IDEA AROUND THIS. WE KNOW I'M GONNA DISAGREE, SO, OKAY. YES, WE'LL CONTINUE. NO SURPRISE. OKAY, WE TRIED, WE LOOKED AT EACH OTHER IN THE EYE. OKAY, SO, UM, ARE THERE ANY CLARIFY, SO HERE'S THE SLIDE I WANTED TO MAKE ROOM FOR JEFF TO DO A DEEP DIVE ON THE BYOG COMBINATIONS AND PERMUTATIONS WE'RE TRYING TO VET, DID ANYONE WANT TO GO BACK ON THE CLR OR ANYTHING? OH, THERE'S THIS QUEUE. OKAY, LEMME WORK THE QUEUE AND THEN TURN, TURN TO THIS. OKAY. CHRIS MATZOS. I THOUGHT THERE WAS ONE BEFORE ME, BUT I GUESS I HAVE TWO QUESTIONS. UM, SO THE CLR WITH NON SYNCHRONOUS BACKUP GENERATION, I GUESS I'M STRUGGLING WITH THIS ONE BECAUSE IN THEORY THEN THE LOAD ENTIRELY CAN JUST MANAGE THAT BEHIND THE METER WITH SOME SORT OF DISPATCH. BUT ONE DON'T, I OVER A CERTAIN SIZE OF OF GENERATOR HAVE TO REGISTER THAT IN SOME WAY FORM OR FASHION WITH ERCOT ANYWAY, WHEN IT'S BEHIND A SINGLE POI, NOT IF YOU'RE NOT SYNCHRONIZED, IT'S MY UNDERSTANDING, I WANNA TALK QUIETLY AND LOOK AROUND THE ROOM AT PEOPLE THAT, WELL YOU DON'T COUNT. UM, SO LEGAL AND OUR, OKAY, SO YOU CAN'T, IF IT'S NOT SYNCHRONIZED. SO EITHER THE BREAKER'S ALWAYS OPEN OR IT'S A DC CONNECTION, BUT EITHER WAY IT'S THE, YOU DON'T HAVE TO REGISTER AS A RESOURCE IF YOU'RE NOT SYNCHRONOUSLY CONNECTED TO THE ERCOT GRID AT ANY GIVEN TIME. OKAY. SO I GUESS THE NEXT QUESTION IS, WHEN YOU THINK ABOUT THIS FROM A STORAGE PERSPECTIVE AND TRYING TO DO IT, WHICH I KNOW SAM IS OVER THERE JUST STARING AT ME. ITCHING, ITCHING, [04:30:01] BIG CHILD, UM, ITCHING. YEAH. BUT THAT NET DRAW AT THE POI WOULD THEN BE VIEWED AS LIKE THE STORAGE PLUS THE LOAD OR HOW WOULD THAT WORK? IT WOULD ALMOST BE KOS LOOKING AT YOUR LOAD AND IT, WE EVEN TALK ABOUT THIS, WHETHER OR NOT IT'S SEGMENTED OFF EVEN BY BUILDINGS. IF YOU HAVE FIVE BUILDINGS, YOU'RE GONNA SET ONE BUILDING OFF ONTO THE BATTERY, YOU'RE GONNA DISCONNECT IT, SEND IT OFF TO THAT, AND ALL OF A SUDDEN ERCOT SEES THE THOUSAND GO DOWN TO 400 AND THEY SYNCHRONIZE THE OTHER ONE OFF. 'CAUSE IN A CLR BID, YOU COULD ACTUALLY STRUCTURE IT WITH BREAK POINTS AT WHICH IT'S KIND OF AN ALL OR NOTHING TYPE SHIFT TO THEN DROP THAT WHOLE NEXT A HUNDRED MEGAWATTS OR WHATEVER IT MAY BE. ERHART REALLY HATES IT WHEN I DROP SIGNIFICANT AMOUNTS OF LOAD OF BLOCKS. SO THIS IS PARTLY, YEP. SOME OF MY ISSUE WITH HOW THIS IS, I'M TRYING TO UNDERSTAND THE BACKUP GENERATION OTHER THINGS ABOUT BEYOND THIS, BECAUSE THAT GENERATION HONESTLY, OR BACKUP RESOURCE, HONESTLY ANY SITUATION WOULD BE BETTER AS A SCED DISPATCHED RESOURCE THAT CAN RESPOND TO THE THE FIVE MINUTE INTERVALS, WHICH AGAIN, WE'RE ABOUT TO HEAR ME REPEAT IN A NETWORK STUFF AND I'M NOT GONNA GO THAT FAR DOWN THE LINE, BUT I DON'T KNOW THAT YOU'RE GOING, LIKE, I'M HAVING A HARD TIME UNDERSTANDING THE SEAMLESS SORT OF COMMAND STRUCTURE THAT YOU'RE WANTING WITH THAT WOULD REALLY ISOLATE THE LOAD FROM UM, ACTUALLY HAVING TO RESPOND AND USING THE BACKUP RESOURCES. SO I DON'T KNOW HOW TO PHYSICALLY INTEGRATE LIKE A DIESEL GEN SET IN A, IN A MANNER THAT WOULD WORK WITH THIS AS AN EXAMPLE. I DON'T THINK ANYONE AT ERCOT LIKES THIS, BUT THE RULES ARE CONSTRUCTED IN A WAY WHERE THIS MAY WORK. I SEE. SO WE'RE TRYING TO KEEP THE DOORS OPEN ON IF YOU GOT A WAY TO DO IT, YOU CAN. I SEE. AND THEN, OKAY, CAN I JUST COMMENT ON THAT REAL FAST? GO AHEAD. YEAH, GO AHEAD. YEAH, SO TO CLARIFY, UM, AND I GUESS YOU CAN TAKE THIS AS AN UN UNQUALIFIED OPINION, BUT FOR THE STANDARD DATA CENTER THAT EXISTS OUT THERE TODAY, THEY HAVE SIGNIFICANT BACKUP DIESEL CAPACITY ON SITE THAT'S UNSYNCHRONIZED FROM THE GRID. THE ONLY INSTANCES IN WHICH THOSE ARE REGISTERED TODAY IS IF THEY'RE PARTICIPATING TO AN ERS SERVICE. AND SO, UM, ON THE REGISTRATION PIECE, EVEN THOUGH I'M, I'M UNQUALIFIED AND I'M COMPLETELY SUBORDINATING MYSELF TO ERCOT, UM, THAT IS NOT A REGISTRATION REQUIREMENT TODAY. SEPARATELY, UM, THE DISPATCH COMPLIANCE WILL BE, I GUESS AT LEAST THIS IS MY PERSPECTIVE FROM ERCO T'S POINT OF VIEW. THEY'LL BE LOOKING AT THEIR QUEASY TO ULTIMATELY SEND THE DISPATCH INSTRUCTION TO THE RIGHT RESOURCES THAT PRODUCE THE DISPATCH, THE, THE RESPONSE PROFILE THAT COMPLIES WITH SC. AND SO AS LONG AS YOU'RE MEETING THE OBLIGATIONS OF DISPATCH FOLLOWING YOUR BASE POINT SCED, UM, I DON'T THINK, YOU KNOW, ERCOT REALLY CARES TO EVEN KNOW HOW THAT LOAD IS ACTUALLY SERVING IT SO LONG AS IT'S, YOU KNOW, FROM THE ERCOT POINT OF VIEW IT'S BEING CURTAILED AND YOU MAY USE UNSYNCHRONIZED RESOURCES BUT THEY DON'T REALLY CARE TO EVEN KNOW THAT. UM, SO I BELIEVE THAT'S THE CURRENT STATE OF PLAY AND FOR WHAT IT'S WORTH FOR, FOR FOLKS WHO MAY BE OUT THERE THINKING ABOUT CO-LOCATED ARRANGEMENTS WITH, WITH BATTERIES, THE BATTERY IS NOT THE MEAN, OR SORRY FOR SPECIFIC INSTANCES OF PEOPLE WHO MAY BE PLANNING CO-LOCATED RESOURCES WITH BATTERIES. THOSE BATTERIES ARE NOT INTENDED TO BE THE MECHANISM BY WHICH THE LOAD ACTUALLY FOLLOWS ITS SC INSTRUCTIONS AS ACL R. THOSE BATTERIES JUST HAPPEN TO BE CO-LOCATED ON THE SITE AND JUST HAPPEN TO BE IN A LOCATION WHERE IT COULD THEORETICALLY ALLEVIATE CONGESTION ON THE TRANSMISSION SYSTEM. SO IT'S MUCH MORE LIKE A PUN OR A-B-Y-O-G STRUCTURE. GOT IT. WHERE, YOU KNOW, THIS IS THE MECHANISM BY WHICH A A LOAD NEEDS TO BE ACL R. YEAH. OKAY. UM, I'M STRUGGLING WITH THIS ONE ON HOW, HOW WE CAN OPERATIONALIZE IT, BUT IF SOMEONE'S OUT THERE THAT CAN DO THAT WITH GENERATORS BEHIND THE METER, I STILL THINK WE'RE BEING A LITTLE BIT INEFFICIENT ABOUT THESE RESOURCES. THANK YOU. YOU BET. UH, WORK THE QUEUE REAL QUICK. SO WE HAVE FOUR UH, JOEL DAVIS. GO AHEAD. YEAH, SO, UM, TWO THINGS. ONE ON THE, THE, UM, QUESTION OF CLRS DECLARING BEFORE THE BATCH OR, OR LOADS GENERICALLY DECLARING BEFORE THE BATCH THAT THEY ARE, THAT THEY ARE CLRS. I THINK WHAT YOU WOULD GET A LOT MORE RESPONS OF IS I'M WILLING TO BE A CL R AH, BUT YOU'RE GOING TO HAVE TO GUARANTEE ME THAT MY WILLINGNESS TO BE A CLR WILL NOT IN ANY WAY IMPACT MY FIRM ALLOCATION IN THE BATCH. GOTCHA. YEP. RIGHT. YOU'RE NOT SAYING I'LL COME IN AS ACL R, PUT ME AS ZERO. [04:35:01] IT'S AS, AS YOU ARE ALLOCATED ENERGY. THEN THERE'S THE IDEA OF THAT OTHER ENERGY ON TOP FLEXIBLE ENERGY. I KNOW, I KNOW WE'VE TALKED ABOUT HOW THE MOUNT, THE MEGAWATT ALLOCATION IN THE BATCH IS GONNA WORK AND WE'RE GONNA TRY AND MAXIMIZE MEGAWATTS TO SOME EXTENT. YOU'RE GOING TO HAVE LOADS THAT HAVE SAID THEY'RE WILLING TO BE AS A CLR AND IF YOU ALLOCATE A BUNCH OF THOSE LOADS DOWN, YOU MIGHT GET MORE TOTAL MEGAWATTS. 'CAUSE YOU'LL HAVE THAT CLR FLEX IN THERE, BUT YOU'RE LOWERING THE FIRM ALLOCATION OF SOME OF THOSE LOADS AND THEY'RE NOT GONNA BE WILLING TO TAKE THAT TRADE OFF. THEY'LL WAIT UNTIL YOU TELL YOU I'LL BE A CLR LATER. YEAH. THIS IS AG SPRINGER. RIGHT. TO MAXIMIZE THEIR, THEIR FIRM ALLOCATION. YEAH. THIS IS AG SPRINGER OR COT. UH, I JUST WANTED TO CHIME IN HERE THAT, UM, WHILE WE ARE STILL WORKING ON THE LANGUAGE THAT IS THE CONCEPT THAT WE ARE WORKING FROM IN DEVELOPING THE LANGUAGE IS THAT WILLINGNESS TO REGISTER AS A CLR WILL NOT IMPACT THE OPTIMIZATION THAT WOULD ALLOCATE THE FIRM MEGAWATTS AND THE TIMELINE OF THAT. IT'S UH, UH, WOULD SIMPLY BE A, A PATHWAY TO POTENTIALLY CONNECT ADDITIONAL MEGAWATTS SOONER PROVIDED THEY QUALIFY AS ACL R. YEAH. AND THEN THE SECOND POINT I'LL BRING UP AND IT, IT KIND OF ECHOES SOME OF CHRIS'S STUFF, IS ONE OF THE PILLARS OF BYOG SHOULD BE THAT A LOAD THAT IT IS BRINGING THEIR OWN GENERATION, BE IT SYNCHRONIZED OR UNSYNCHRONIZED, SHOULD NEVER BE IN A WORSE POSITION THAN IF THAT SAME GENERATION WAS CONNECTED BY A THIRD PARTY TO THE SAME BUS. SO IN OTHER WORDS, IF YOU, IF YOU ARE BRINGING GENERATION TO THE SYSTEM, YOU SHOULD NEVER GET A LOWER LOAD ALLOCATION THAN YOU WOULD IF THAT SAME GENERATION WAS COMING TO THE SYSTEM TO THE SAME BUS YOU HAPPEN, HAPPEN TO BE ON THE SAME BUS. I GUESS IT DEPENDS. I I WAS GONNA REBUT, BUT WHAT WE'RE ASKING FOR IS AN OPERATING AGREEMENT. SO IF THAT LOAD IS SIT, SO IF WE'RE ON THE SLIDE 53 AND WE HAVE THIS LOAD THAT'S SHOWING UP, IF THAT DID NOT HAVE A GEN THAT WAS NOT ASSOCIATED WITH IT, THAT DID NOT HAVE AN OPERATING AGREEMENT, WE WOULD NOT GRANT IT AUTHORIZATION TO ENERGIZE AT A THOUSAND MEGAWATTS UNLESS THAT GENERATOR IS THERE. SO WHEN IT'S UNDER TWO DIFFERENT PARTIES, IT CAN'T EXIST IN THAT REALM. SO THAT'S RIGHT. EXCEPT THAT YOU'RE GONNA LIMIT THAT LOAD WITH AN SLF. YES. WHEN IF THAT GENERATOR WAS AN UNRELATED THIRD PARTY, THAT LOAD WOULD GET ITS FULL ALLOCATION IN THAT RENT THAT JEN WOULD GET ROCKED. YEAH. SO WE DO THINK THAT THERE MAY BE A WAY TO GET AROUND THIS CONSTRAINT. SO THAT'S ANOTHER SLIDE HERE ON THAT PUN. PLUS IF SOME OF Y'ALL ARE READING AHEAD. SO WILL THAT NOT HELP? I'M SORRY I GET A HITCH THAT, THAT DOES HELP. I DON'T THINK THANK YOU. YOU DON'T THINK THEY GET THEIR LOAD? YEAH, I I, I COME BACK TO IT. YEAH. UH, I I DON'T WANNA STEP ON JEFF'S TOES WITH HIS UPCOMING SLIDE, BUT I'M NOT SURE I AGREE WITH THAT CHARACTERIZATION THAT, UH, THE LOAD, IF THE, THE LOAD AND JEN ARE CONNECTED AT THE SAME POINT BUT ARE NOT RELATED IN ANY WAY THAT UNDER THE CURRENT METHODOLOGY, I DON'T THINK THAT IS A TRUE STATEMENT. THAT THE LOAD WOULD BE FULLY APPROVED. YEAH. SO LET US WALK THAT DOWN. LET'S GET TO THE END OF THE STORY ON THIS PART. TO SERVE IT. WHY WOULD IT NOT BE APPROVED? SO IT WOULDN'T BE APPROVED UNTIL THE CONSTRUCTION PROJECT IS DONE? THE TRANSMISSION RIGHT IS OUT THERE, BUT, BUT IF THERE'S GEN THERE TO SERVE IT, THEN THERE'S NO TRANSMISSION PROJECT NEEDED. THERE'S GEN THERE TO SERVE IT. OKAY. AND YEAH, YOU HAVE TO DO THE G MINUS ONE. YEAH. BUT YOU KNOW, IF YOU'VE GOT 10 UNITS AND IT ONLY TAKES NINE TO SERVE IT, YOU'LL DO THE G MINUS ONE. YOU'LL GO, THERE'S NO TRANSMISSION PROJECT HERE NEEDED HERE. THERE'S GEN TO SERVE IT. OKAY. WE'RE GONNA GET TO THAT EXAMPLE IN A MINUTE AND I MAY PULL THE PLUG ON THE QUEUE AND JUST GET JEFF UP HERE TO TELL THE REST OF THE STORY. BUT, UH, UM, SO ANYWAYS, UH, SO, SO SORRY. SO I'M GONNA GO AHEAD AND MOVE ON TO BROTH REAL QUICK. YEAH, MY QUESTION WAS EXACTLY THE SAME. ALRIGHT, GOOD CHECK. UH, BILL, SORRY, IT'S STILL AN OPEN QUEUE ON THOSE. UM, BILL BARNES. YES. I HAVE CLR QUESTIONS. SO CAN WE GO BACK TO ONE A? YES. TRYING THE, THE, THERE'S THE COMMENT ABOUT UM, BEING LIMITED TEMPORARILY. I THINK IT WOULD MAKE THE MOST SENSE FOR ONE A IS TO HAVE TWO OPTIONS. 'CAUSE I DO THINK WE'RE GONNA SEE SOME PERMANENT C LRS AS WELL. THERE MAY NOT BE A LOT, BUT THERE MAY BE A LOAD THAT SAYS I'M WILLING TO, TO OPERATE AS A CLR FROM NOW UNTIL ETERNITY. SO I WANT, SO THERE'S A CHECKBOX, ARE YOU A PERMANENT CLR OR ARE YOU ONE THAT'S WILLING TO ACT AS A CLR TEMPORARILY UNTIL YOU GET YOUR FULL INTERCONNECTION FACILITY CONSTRUCTED FIVE YEARS FROM NOW, BUT A NORMAL CLR FOREVER IS FIRM LOAD IN HOW WE STUDY A BITCOIN MINE FIRM LOAD. OKAY. OH, SO IT'S JUST THE ATTRIBUTES MAKING SURE WE'RE NOT LIKE PREVENTING [04:40:01] THE, THE TRADITIONAL CLR FROM PARTICIPATING IN THESE STUDIES IS THAT WE'RE CONTEMPLATING ALL THE DIFFERENT FLAVORS OF WHAT A CLR COULD BE. BILL, UH, THIS IS AG I THINK TO WHAT MATT WAS TRYING TO SAY IS THAT RIGHT NOW THERE IS NO PATHWAY AT ALL FOR A CLR TO BE STUDIED AS ANYTHING OTHER THAN FIRM LOAD IN A PLANNING ASSESSMENT. IT'S, UH, A FIRM LOAD THAT IS CONNECTED TO THE GRID AND THEN AFTER CONNECTING ELECTS TO REGISTER AS A CONTROLLABLE LOAD RESOURCE. AND SO THE, THE FEEDBACK THAT WE'VE HEARD IN THESE WORKSHOPS HAS BEEN THAT ANY LOADS THAT WOULD WANT TO BE STUDIED AS A CLR CONNECT MORE MEGAWATTS WOULD WANT TRANSMISSION TO BE BUILT TOWARDS THEM. AND SO THAT HAS BEEN THE ASSUMPTION THAT WE'VE BEEN WORKING ON. UM, I THINK ONE OF THE OTHER COMMENTS THAT I HEARD A FEW MINUTES AGO, UM, WAS TALKING ABOUT HOW WE SHOULD NOT USE THE LOAD FLEXIBILITY OFFERED BY CLR TO IMPACT THE FIRM MEGAWATT UH, ALLOCATIONS. AND I THINK IF WE HAVE THIS CHECKBOX THAT WOULD ALSO IN IMMEDIATELY IMPLY IN MY MIND THAT WE WOULD NOT BUILD TRANSMISSION IF IT'S GOING TO BE A CLR FOREVER. AND WE WOULD ALWAYS BE ABLE TO DISPATCH THAT LOAD DOWN IN A PLAN ASSESSMENT. UM, AND SO THAT, THAT TO ME IS A LITTLE BIT BEYOND WHAT WE THOUGHT WE'VE HEARD SO FAR. AND SO, OKAY. YOU KNOW, TO THE LANGUAGE WE'RE DEVELOPING SO FAR IT'S REALLY BEEN GEARED MORE TOWARDS WHAT'S ON THE SCREEN HERE OF A LOAD THAT WANTS CLR TEMPORARILY AS A PATHWAY TO CONNECT SOONER. OKAY. UM, NOT SAYING NECESSARILY WE'RE OPPOSED THAT, BUT I HAD, AT LEAST I HAVE NOT HEARD THAT IN THE FEEDBACK WE RECEIVED UP TO THIS POINT. OKAY. AND THEN, UH, ONE B SIMILAR QUESTIONS THAT I HEARD FROM CHRIS. I'M, I'M STILL NOT FOLLOWING WHAT THIS IS. 'CAUSE THE, THE WAY THAT IT'S BEEN DESCRIBED SO FAR, IT SOUNDS LIKE THE BACKUP GEN WOULD BE SOME TYPE OF SETTLEMENT ONLY RESOURCE. IT'S NOT EVEN THAT. WHAT I HEARD YOU SAY IS THAT THAT'S NOT THE CASE. THIS WOULD BE COMPLETELY ISLANDED GENERATION, WHICH MEANS, I'M JUST THINKING ABOUT HOW THIS WOULD ACTUALLY WORK IN OPERATIONS. SO WHEN THIS TYPE OF CLR IS GETTING DISPATCHED, YOU'RE ACTUALLY OPENING THE BREAKER BETWEEN THE INTERCONNECTION OF THE LOAD IN THE SYSTEM SO IT'S NOT IN PARALLEL ANYMORE. WELL, IT MAY BE WHERE THIS LOAD IS IN FIVE FIVE BUILDINGS. SO ONE BUILDING IS OPENING A BREAKER AND CLOSING INTO THE BATTERY ON THE BACKSIDE. SO IT'S LIKE 20% OF IT DISAPPEARS AT A TIME. AGAIN, ERCOT DOESN'T KNOW IF THIS IS FEASIBLE, BUT WE'RE GETTING AROUND THAT. I WANT TO HAVE A BATTERY AND LOAD AT THE SAME SPOT. HOW CAN I DO IT AND CALL IT ACL R? THIS IS HOW TO DO IT. I DON'T SEE HOW IT WORKS. OKAY. SO IF SOMEBODY WANTS TO COME WITH A MILLION DOLLAR IDEA AND I WAS, I THOUGHT WE WERE KIND OF HEADED TOWARDS A PATH WHERE THIS WOULD BE LIKE A SETTLEMENT ONLY TRANSMISSION SELF GENERATOR THAT'S PARKED BACK BEHIND THE LOAD SO THAT IT YOU'RE YOU'RE GETTING ALL THE NETTING AND SETTLEMENT EVERYTHING THAT YOU WANT. UM, THE ONLY GENERATION I'M AWARE OF THAT, THAT YOU DON'T HAVE TO REGISTER WITH ERCOT AT ALL IS ONE THAT IS ALWAYS ISLANDED AND ONLY OPERATES WHEN THE THE SITE HAS BEEN DISCONNECTED. AND SO IF THAT'S HOW THIS IS GOING TO WORK, THEN THAT, I THINK THAT CHANGES HOW WE THINK ABOUT HOW WE WOULD OPERATIONALIZE THIS. 'CAUSE NOW YOU'RE, YOU'RE CONSTANTLY OPENING AND CLOSING THE BREAKER BASED ON THE CLR DISPATCH FROM SKID. I DON'T, I THAT SOUNDS PROBLEMATIC. WELL LET ME JUST SAY SOMETHING. ERCOT IS NOT NECESSARILY GONNA WRITE THE LANGUAGE ON THIS ONE. WE'RE WRITING LANGUAGE ON THIS ONE. THAT'S THE ONLY ONE WE CAN FIGURE OUT RIGHT NOW. SO I'M JUST SAYING THIS WAS A YES NO MAYBE. AND SO THIS IS AGAIN, THESE ARE THE THREE MAYBES AND SO I'M SORRY I COULD HAVE UPDATED THIS. WE THINK THE TOP ONE A IS YES, FEASIBLE AND OR COST TAKING OWNERSHIP OF WRITING THE LANGUAGE TO GET IT IN THE NEXT ONE MAY BE FEASIBLE. WE DON'T SEE IT YET. BYOG BASED ON TODAY. WE'RE HOPING TO SEE THERE'S A FEASIBLE WAY TO GET TO ONE OF THOSE OPTIONS. THANKS. I'M GLAD. THAT WAS A GOOD QUESTION TO KIND OF SNAP BACK TO WHAT ARE WE TRYING TO ACCOMPLISH TODAY? AND IT'S THE MOST BANG FOR THE BUCK IS WHAT WE'RE LOOKING FOR RIGHT NOW. AND THIS ONE DOES NOT FEEL LIKE IT. OKAY. WELL WITH EACH ONE OF THESE OPTIONS, I THINK IT'S IMPORTANT. IT, IT WOULD BE GOOD FEEDBACK FOR US AS STAKEHOLDERS TO KNOW HOW ERCOT WOULD EXPECT THIS TO BE REGISTERED AND HOW YOU WOULD OPERATE IT. 'CAUSE FOR US TO ACTUALLY BE WILLING TO DO THESE, WE NEED TO KNOW THAT ANSWER BEFORE WE WOULD COMMIT TO IT IN A BATCH STUDY. SO YEAH. VERY GOOD. ALRIGHT, THANK YOU. CAN I COMMENT ON THAT REALLY QUICK? YES, SORRY. YEAH. SO THIS ALREADY HAPPENS TODAY. LIKE THIS IS HOW A TRADITIONAL DATA CENTER OPERATES. THERE IS A UPS AND THEN WHAT IS CALLED AN A TS OR AN AUTOMATIC TRANSFER SWITCH. SO WHEN THERE IS INSUFFICIENT POWER QUALITY FROM THE GRID, THE BATTERY SELF SERVES THE RACK AND THEN THE AT S SWITCHES OVER TO UNSYNCHRONIZED BACKUP GENERATION TO THEN PICK UP THE SERVICE THAT IS OTHERWISE PROVIDED FROM THE GRID. AND SO THE TECHNICAL FEASIBILITY OF [04:45:01] THIS IS COMPLETELY COMMONPLACE TODAY. UM, THIS IS LIKE THE STANDARD WAY THAT DATA CENTERS OPERATE. UM, NOW TO MAKE AN AUTOMATIC TRANSFER SWITCH THAT IS, HAS A CONTROL PHILOSOPHY THAT CAN RESPOND TO SCAD DISPATCH IS WHERE THERE ARE A NUMBER OF INNOVATIVE SOLUTIONS BEING WORKED ON FOR VARIOUS REASONS. BUT I GUESS MY POINT IS THAT THIS IS ALREADY AN EXISTING PRACTICE. UM, SO I GUESS LASTLY I WOULD SAY I BELIEVE THAT ONE B WOULD REALLY JUST FALL UNDER THE SAME COMPLIANCE CRITERIA AS ONE A. LIKE THEY'RE NOT ACTUALLY TWO DISTINCT CONCEPTS, IT'S JUST B-A-C-L-R AND THEN ERCO T'S LIKE, PLEASE DON'T EVEN TELL ME ANYMORE. LIKE I DON'T NEED TO KNOW IT. I I DON'T THINK I AGREE WITH THAT IN PART BECAUSE THE FIVE MINUTE SCED DISPATCH SIGNAL IS VERY EXACT AND THAT BACKUP GENERATOR IS NOT EXACT. AND SO WHILE I DON'T THINK IT'S AN ACCURATE CHARACTERIZATION TO SAY THEY'RE DOING THIS TODAY, THEY'RE NOT DOING THIS TODAY, THAT THAT BACKUP GENERATOR IS ALSO NOT A GOOD GRID QUALITY GENERATOR. IT'S A HAIL MARY. RIGHT? THE FAIL RATE ON THEM IS VERY HIGH AND THE REPEATED USE OF THEM IS VERY HIGH. SO I DON'T WANT TO, I DON'T WANNA GET INTO LIKE THE DEBATE ON LIKE WHAT A DATA CENTER IS OR ISN'T DOING TODAY IS LIKE REFLECTIVE OF THIS AS A MARKET PRODUCT. IT'S A ENTIRELY HAIL MARY RELIABILITY SERVICE THAT DOES NOT MEET THE CRITERIA OF WHAT I THINK CL R'S EXPECTATION WOULD BE. SORRY, I'M JUST SAYING IT'S NOT OPENING A BREAKER, BUT YEAH, I AGREE. NO, IT'S GOOD YOU OPEN THE DOOR THAT THERE MAY BE A WAY 'CAUSE THE REST OF US ARE FEELING LIKE THERE WASN'T A WAY. UM, SO I'M GONNA DO SOMETHING A LITTLE HARSH. I'M GONNA STOP THE QUEUE AND WE'RE GONNA PUT JEFF UP HERE TO FINISH THE STORY 'CAUSE I THINK YOU'RE GONNA BE A LOT MORE INTERESTED IN THE BRING YOUR OWN JEN THAN THIS THING. UM, BUT YOU CAN COME BACK TO IT AND TALK ABOUT ALL YOU WANT. SO LET ME GET JEFF TO WALK THROUGH THIS DENT SLIDE. ALRIGHT, YEAH. SO WE'LL DO A, A DEEP DIVE HERE. UM, SO, SO UH, WHAT WE'LL START OFF WITH ON, ON THE LEFT IS WHAT WE THINK IS BUSINESS AS USUAL, WHICH IS YOU HAVE A LOAD AND GENERATION AND TODAY THOSE GO THROUGH WHETHER THEY'RE LOCATED BEHIND THE SAME POI OR WHETHER THEY ARE NOT. THEY, THEY GO THROUGH THE INTERCONNECTION PROCESS SEPARATELY. SO THEY ARE TREATED COMPLETELY SEPARATE AND, AND THEY, THEY GO THROUGH THE, THE PROCESS SEPARATELY. AND, AND SO, UM, UH, WHAT THAT MEANS IS THAT, UM, THE ULTIMATELY IF THEY ARE SEPARATE, UH, THEN, THEN, THEN THEY'RE STUDIED, UH, FULL LOAD, FULL GEN, UH, OR FULL LOAD, NO GEN, FULL GEN, NO LOAD. UM, BUT ULTIMATELY FROM A PLANNING PERSPECTIVE THAT THAT GENERATION IS ONLY INCLUDED IF IT MEETS THE, UH, PLANNING GUIDE 6.9 CRITERIA. UM, THE UM, UH, OTHER THING IS THAT, THAT THE, THE LOW DELIVERABILITY REALLY DEPENDS ON THE TRANSMISSION CAPABILITY. UH, SO AS WE GO THROUGH THE STUDY PROCESS, UM, IF, IF, UH, AS, AS WE THINK ABOUT TRANSITIONING TO THE BATCH STUDY IS, UH, IF THERE ARE CONSTRAINTS IN, IN THIS SITUATION, THEN THE LOAD IS NOT GETTING ANY CREDIT FOR THAT GENERATION IF IT IS BRINGING THAT GENERATION. SO IF THERE ARE CONSTRAINTS AND, AND THERE ARE TWO LOADS SIDE BY SIDE, ONE IS BRINGING GENERATION ONE, ONE IS NOT, IF, IF WE DO NOT CHANGE ANY RULES TODAY, UH, AS AS P 1 45 IS LAID OUT, THEN THE LOAD THAT IS BRINGING GENERATION IS NOT GETTING ANY CREDIT FOR BRINGING THAT GENERATION. IT'S JUST GONNA GET ALLOCATED LOAD, UH, BASED ON WHAT WHATEVER THE CONSTRAINTS ARE AND ITS IMPACT ON, ON THOSE CONSTRAINTS. UH, SO THAT, THAT IS TODAY IF WE DID NOT CHANGE ANYTHING GOING FORWARD. UH, SO, UH, I THINK WHAT WE HAVE HEARD, UH, ACTUALLY I I SHOULD SAY WE'VE HEARD LOTS OF DIFFERENT IDEAS AND CONCEPTS, UH, IN THE, UH, THE INTERVIEWS THAT WE'VE HAD AND, AND IN THE, THE PREVIOUS, UH, WORKSHOPS. I, I THINK WHERE WE HAVE TRIED TO NARROW DOWN IT TO IS WHAT CAN, WHAT DO WE THINK IS POTENTIALLY TO USE MATT'S PHRASE POTENTIALLY FEASIBLE TO GET INTO BATCH ZERO. AND WE HAVE NARROWED DOWN TO THESE, UH, SORT OF TWO IDEAS WHICH, UH, KEEP COMING UP. UH, ONE IS, UM, MAYBE, UH, NOT ENTIRELY A A NEW IDEA, BUT MAYBE NEW BRANDING IS WHAT WE'RE CALLING IT, UH, PUN PLUS. UH, AND AND LEMME WALK THROUGH WHAT THAT IS. SO IN, IN THE PUN PLUS CONCEPT, UH, THE LOAD, UH, IS SUPPORTED BY DISPATCHABLE ONSITE GENERATION THAT IS BEHIND THE SAME POI AS THE LOAD. UM, AND THAT GENERATION IS SUCH THAT THE, UH, IF YOU LOSE THE LARGEST GENERATOR, LARGEST [04:50:01] DISPATCHABLE GENERATOR, THEN THERE IS ENOUGH REMAINING DISPATCHABLE GENERATION TO MEET THAT LOAD. UH, SO IT, UH, I THINK WE HAD A PREVIOUS EX EXAMPLE. IF, IF YOU HAD, UH, A THOUSAND MEGAWATT LOAD AND YOU HAD FIVE, 250 MEGAWATT GENERATORS, THEN THE LOSS OF ONE OF THOSE 250 MEGAWATT GENERATORS, YOU STILL HAVE A THOUSAND MEGAWATTS OF GENERATION. AND SO THAT WOULD QUALIFY AS PUN. PLUS IF YOU JUST HAD 4, 250 MEGAWATT GENERATORS, THEN YOUR G MINUS ONE, NOW YOU ONLY HAVE 750 MEGAWATTS. THAT DOES, THAT WILL NOT QUALIFY IN THIS CONCEPT OF PUN PLUS. UH, AND, AND LET ME ALSO CLARIFY THAT WE, WE ARE ONLY TALKING ABOUT BATCH ZERO. THAT DOESN'T MEAN THAT IN FUTURE, UH, ITERATIONS OF BATCH THAT WE CAN'T COME UP WITH OTHER RULES FOR THAT SITUATION. BUT FOR THIS CONCEPT OF WHAT WE ARE CALLING PUN PLUS, IT IS ONLY I HAVE G MINUS ONE WORTH OF GENERATION THAT IS AT LEAST EQUAL TO THE LOAD CAN BE MORE, BUT IS IT, IT IS AT LEAST EQUAL TO THE, UH, AMOUNT OF LOAD AND THAT GENERATION HAS TO BE, UH, DISPATCHABLE AND WE ARE NOT COUNTING BATTERIES IN THIS CASE AS DISPATCHABLE. IT HAS HAS TO BE, UH, GAS OR, UH, YOU KNOW, SOME SOMETHING ELSE THAT, THAT YOU WOULD CALL A DISPATCHABLE. UM, SO THE IDEA HERE IS THAT, UH, IF A LOAD IS BRINGING THAT MUCH GENERATION, THEN WE WOULD TREAT THAT LOAD AS FIRM SO THAT LOAD WOULD GET THE ENTIRE ALLOCATION OF WHAT THEY'RE REQUESTING. SO AGAIN, THE EXAMPLE A THOUSAND MEGAWATTS OF GENERATION 5, 250 MEGAWATT GENERATORS THAT LOAD TO BE ALLOCATED THAT ENTIRE 1000 MEGAWATTS OF GENERATIONS, WE ARE GIVING CREDIT TO THAT LOAD FOR BRINGING THAT GENERATION WITH IT. UM, UH, YEAH, SO THAT'S, UH, YEAH, SO, SO YOU GET CREDIT. SO IF THERE IS, YOU KNOW, TWO LOADS THAT ARE, UH, RIGHT NEXT DOOR TO EACH OTHER, UH, AND THERE ARE TRANSMISSION CONSTRAINTS, THE ONE THAT IS BRINGING THAT G MINUS ONE PLUS GENERATION, THEN THEY ARE GETTING ENTIRE CREDIT. THEY'RE GETTING THAT ENTIRE ALLOCATION FOR THAT GENERATION THAT THEY'RE BRINGING. UM, WE WOULD NOT SET AS OPPOSED TO THE SELF-LIMITING FACILITY CONCEPT. UH, WE WOULD NOT SET ANY SORT OF LIMIT ON AT, AT THE POI. SO THERE MAY BE DAYS WHERE THAT, UH, MAYBE IT'S NOT ECONOMIC TO RUN THAT GENERATION AND, AND THE LOAD WOULD RATHER PULL FROM THE GRID. UH, WE WOULD NOT ADMINISTRATIVELY SET THAT WE WOULD USE OUR EXISTING RELIABILITY TOOLS THAT THE OPERATORS HAVE TO MANAGE THAT. SO THAT MAY MEAN THAT WE, WE MAY DENY OUTAGES OF THAT GENERATION IF WE THINK THAT WE NEED THAT, THAT GENERATION THERE TO SUPPORT THE LOAD. IT MAY MEAN THAT WE RUCK THAT GENERATION ON, UH, BUT THERE MAY BE DAYS WHERE, YOU KNOW, MAYBE WE DON'T NEED THAT GENERATION TO SERVE THAT LOAD. MAYBE IT'S NOT, UH, ECONOMIC. AND SO THE OWNER DECIDES NOT TO THE, THE, UM, THE, THE BENEFIT HERE IS THAT THEY, THEY CAN, YOU KNOW, MA MANAGE THAT AND, AND THEY CAN RUN THAT. SO THERE'S NOT A, THIS I IDEA LIKE IN THE SELF-LIMITING FACILITY CONCEPT WHERE THEY WOULD, UH, WE WOULD HAVE SOME SORT OF ADMINISTRATIVE LIMIT. UM, ONE THING THAT UH, I THINK IS IMPORTANT TO POINT OUT IS WE, WE WOULD THEN TREAT THESE GEN, THIS GENERATION AND THIS LOAD, UH, IN TRANSMISSION PLANNING STUDIES AS WE WOULD TREAT ANY OTHER LOAD AND GENERATION. UH, THAT MEANS THAT IF, IF YOU HAVE THIS, UH, G MINUS ONE PLUS UH, CONCEPT WORTH OF GENERATION, THAT MAY, THAT LIKELY MEANS THAT THERE IS NOT A RELIABILITY NEED TO BUILD TRANSMISSION TO BE ABLE TO SERVE THAT LOAD WITHOUT THAT GENERATION. UH, WE WOULD FOLLOW NORMAL TRANSMISSION PLANNING RULES ON THAT. IT MAY MEAN THAT THERE MAY BE ECONOMIC JUSTIFICATION FOR BILLING TRANSMISSION BECAUSE IF YOU ALWAYS NEED THAT GENERATION AND MAYBE IT'S, YOU KNOW, CTS OR, OR SOMETHING LIKE THAT, MAYBE IT'S NOT EFFICIENT TO RUN THOSE ALL THE TIME. THERE MAY BE AN ECONOMIC TRANSMISSION PLANNING PROJECT THAT THAT THAT COMES ABOUT. BUT UH, BUT THEORETICALLY THERE'S NOT A RELIABILITY NEED TO, UH, TO, TO BUILD A TRANSMISSION UPGRADE FOR THAT, THAT SCENARIO. UM, I THINK THAT IS ALL MY POINTS ON THAT ONE. UM, AND BEFORE I TAKE QUESTIONS, I WANT TO DESCRIBE THE SELF-LIMITING FACILITY. 'CAUSE I, I IMAGINE SOME OF THESE QUESTIONS WILL BE ANSWERED WHEN WE DESCRIBE IT SELF-LIMITING. SO, SO, SO THAT IS PUNT PLUS AGAIN, THAT IS A DIFFERENT CONCEPT FROM THE SELF-LIMITING FACILITY CONCEPT. UH, THE SELF-LIMITING FACILITY CONCEPT IS MORE RARE. THROUGH THE BATCH STUDY PROCESS, WE WILL IDENTIFY IF THERE IS A LIMIT, UH, AND THAT LIMIT WILL BE SET BASED ON THE, UH, THE WORST, UH, WORST CASE SCENARIO. AND THAT THAT IS A LIMIT THAT IS NOT [04:55:01] GOING TO CHANGE BY HOUR OR BY DAY OR BY SEASON. THAT WILL BE A LIMIT THAT WILL BE, UH, LIKELY AN ANNUAL LIMIT. UH, UH, SO IT'LL BE BASED ON THAT WORST CASE. AND, AND SO THE EXAMPLE THAT WE HAVE HERE IS, UH, WE IDENTIFY THAT WE CAN SERVE UNDER THOSE WORST CASE CONDITIONS A A HUNDRED MEGAWATTS OF THAT LOAD AT THAT SELF-LIMITING FACILITY. UH, THE, THE IDEA IS THAT WE WILL ALWAYS, OR AT LEAST FOR THAT YEAR, YOU WILL HAVE THAT 100 MEGAWATT LIMIT. EVEN IF THERE ARE DAYS WHERE IT'S NOT ECONOMICS TO RUN THE GENERATION AND MAY MAYBE THERE'S ADDITIONAL TRANSMISSION CAPACITY. WE'RE NOT ANALYZING THAT ON A DAILY OR REALTIME BASIS THAT THAT WILL GET SET ONE TIME. UH, BUT THE, UH, MAYBE THE DIFFERENCE HERE BETWEEN THIS AND AND PUN PLUS IS THAT, UM, I THINK SIMILAR TO HOW WE WERE DESCRIBING, UH, SOME OF THE SCHOLARS, ERCOT DOESN'T, UM, IT DOESN'T MATTER TO ERCOT WHAT GENERATION IS BEHIND THAT, IT IS UP TO THE FACILITY OWNER TO MANAGE THAT LIMIT, TO MANAGE THAT LIMIT. SO IF YOU HAVE SOLAR GENERATION AND, AND GAS AND, AND YOU KNOW, THE SUN GOES DOWN, THEN IT IS UP TO YOU TO TURN ON YOUR GAS GENERATION AND MANAGE THAT LIMIT. ERCOT IS NOT BRINGING THAT GENERATION ON FOR YOU WHEN THE SUN SETS OR, OR IF YOU HAVE A BATTERY OR WHATEVER IT IS, YOU ARE MANAGING THAT LIMIT. UH, AND SO WE ARE GIVING YOU THAT, THAT LIMIT AND YOU ARE GOING TO MANAGE THAT. AND SO YOU COULD HAVE SOME COMBINATION OF, OF DIFFERENT GENERATION BEHIND THERE, UH, YOU KNOW, MAY, BUT IF YOU HAVE SOME OUTAGE ON YOUR GENERATION, THEN, THEN YOU'RE GOING TO HAVE TO TURN YOUR LOAD DOWN. UM, SO, UH, I THINK OUR, OUR DRAFT CONCEPT AND WE'RE, AGAIN, THIS IS ALL I'LL DRAFT THAT I NEED TO POINT OUT THAT THE, UH, THE PRELIMINARY, UH, WATERMARK ON THERE IS THERE FOR A REASON. WE'RE, WE'RE STILL DISCUSSING OKAY, DOES THAT THAT MEAN THAT WE WON'T RUCK? BUT I THINK IN, IN CONCEPT WE'RE THINKING THAT, UH, YOU KNOW, ERCOT WOULD NOT RUCK, UH, THAT GENERATION, IT, IT, IT'S UP TO THE, THE LOAD AND THE GENERATION OWNERS TO COORDINATE THAT. UM, ALSO ANOTHER DISTINCT DIFFERENCE HERE IS THAT YOU, UH, IN THIS CASE, YOU DO NOT HAVE TO HAVE G MINUS ONE MORE THAN YOUR, UH, LOAD. UH, YOU, YOU DON'T HAVE TO HAVE THAT EXTRA GENERATION, BUT YOU, YOU JUST HAVE TO MANAGE YOUR LOAD TO KEEP, UH, BELOW THAT LIMIT. IF YOU HAVE, UM, UH, GENERATION OUTAGES, UM, WE, WE THINK THAT WE WOULD LIKE LIKELY WOULD REQUIRE SOME SORT OF REVERSE POWER RELAY OR, OR SOMETHING LIKE THAT, UH, OR, OR SOME RELAY THAT, UM, WOULD PREVENT YOU FROM DRAWING TOO MUCH POWER, UH, FROM THE GRID. UH, WE DO NOT WANT A RAZ. UH, SO ANYTHING THAT WOULD QUALIFY AS A RAZ, I THINK WE WOULD SAY NO. UH, BUT IT WOULD NEED TO BE SOMETHING THAT'S MORE, UM, YOU KNOW, DIRECTLY, UH, YOU KNOW, MEASURING THAT FLOW. UM, AND THEN, UM, WE WOULD, UH, I THINK WE WOULD PLAN TRANSMISSION, UH, AS IF, UH, WE WE WILL EVENTUALLY EXIT THIS, UH, CONFIGURATION. UM, BUT I THINK WE'RE, WE'RE STILL THINKING ABOUT THAT AND HOW, HOW THAT WOULD WORK. UM, BUT UH, BUT YEAH, I THINK THERE'S, THERE'S AN IDEA THERE THAT THERE WE WANT WOULD WANT TO GET OUT OF THE SITUATION WHERE, UH, WE ARE HAVING THIS, UM, UH, THIS LIMIT ALL THE TIME, UH, ON THE FACILITY WE'RE, I THINK WHAT WE HEARD IS THAT THIS SHOULD BE A TEMPORARY THING AND SO WE WOULD ALLOCATE THE LOAD BASED ON WHAT WHATEVER IT IS THE BATCH STUDY SAYS WE COULD ALLOCATE RELIABLY, UH, THROUGH, THROUGH THE YEARS. AND THEN AS BIGGER 1 45 IS CURRENTLY DRAFTED, THAT CONCEPT IS YEAR SIX, THEY WOULD GET THE, THE FULL AMOUNT AND WE WOULD REMOVE THE LIMIT. UH, SO LET ME UH, PAUSE THERE AND SEE WHAT QUESTIONS FOLKS HAVE. YEAH. AWESOME. OKAY, SO WE'LL START WITH BROTH. GO AHEAD SIR. HEY JEFF, UH, IN THE PUN PLUS CONFIGURATION, YOU ARE NOT GOING TO PLAN FOR ANY TRANSMISSION UPGRADES FOREVER, IS THAT RIGHT? I LEMME SAY IT'S SLIGHTLY DIFFERENT IS WE WILL USE THE EXISTING TRANSMISSION PLANNING RULES, UH, BUT UNDER THOSE RULES WOULD NOT ASSUME THAT YOU WOULD IDENTIFY A, A RELIABILITY NEED FOR TRANSMISSION UPGRADES. IT, IT MAY BE ECONOMIC NEED, BUT WE WOULD NOT ASSUME, UH, THAT THERE WOULD BE A, A RELIABILITY NEED FOR UPGRADES. SO IF I'M A LOAD, I'M GETTING ONE GIGAWATT OF LOAD AND I, I'M BRINGING ONE OF GENERATION AND EVENTUALLY I WANT TO FIRM UP RIGHT IN YEAR SIX, SO THAT WILL PROBABLY FALL UNDER BATCH SELF-LIMITING FACILITY RULE WHERE I GET ONE GIGAWATT APPROVAL AND I CONNECT MY GENERATION BEHIND THE METER AND THEN I WAIT FOR PHONE TRANSMISSION IN A SIX YEAR RAMP. IS THAT ACCURATE? YEAH, I, I THINK IT IS. UM, YEAH, SO, SO, AND I SHOULD STATE, I THINK UPFRONT YOU [05:00:01] WILL HAVE TO TELL US WHICH OF THESE OPTIONS YOU, YOU WANT TO SELECT, EITHER PUN PLUS OR SELF-LIMITING FACILITY. UM, I, I THINK ON THE TRANSMISSION PLANNING SIDE, I THINK IT WOULD BE, WE WOULD, UH, PLAN SUCH THAT YOU WOULD EXIT THE SLF, BUT THAT DOESN'T MEAN THAT WE'RE, WE'RE GOING TO IGNORE WHATEVER GENERATION IS THERE. SO WE, WE WILL STILL, IT WOULD BE FOLLOWING THE NORMAL TRANSMISSION PLANNING RULES ASSUMING WHATEVER, YOU KNOW, GENERATION IS IS THERE ON SITE. SO I GUESS WHERE I'M GOING IS IF I, LET'S SAY IF I BRING IN 1200 MEGAWATTS OF LOAD AND 1200 MEGAWATTS OF GENERATION EVERY YEAR, I GET 200 MEGAWATTS OF FIRM TRANSMISSION FOR THAT FOR SIX YEAR RAMP, RIGHT? IN BAD ZERO ALLOCATION, IF YOU'RE, UM, IF I'M APPLYING, IF YOU'RE DOING LIKE SLF, YES, IT, IT WOULD BE, UH, YOU WOULD BE ALLOCATED, UM, WHATEVER THE SYSTEM CAN RELIABLY SERVE, UM, YOU WOULD BE ALLOCATED THAT AS YOUR, YOUR YOUR SLF UM, ALLOCATION, SO TO SPEAK. IT'S, IT'S ALMOST LIKE, NOT, NOT A LOAD ALLOCATION, BUT AN SLF ALLOCATION IF YOU WILL. SO EVENTUALLY I'LL GET FOAM BY YEAR SIX RIGHT FOAM TRANSMISSION FOR FULL 1200 MEGAWATTS. UH, YES. WITH THE ASTERISK THAT WE'RE, WE WOULD NOT IGNORE THE GENERATION THAT IS THERE. THAT'S EXACTLY WHAT I WAS DOING. SO WHAT DOES IT MEAN? BECAUSE AS I GET FIRM TRANSMISSION SERVICE, I MAY RAMP DOWN MY GENERATION OR I MAY CONNECT THAT FRONT OF THE METER, PARTICIPATE IN THE MARKET FOR RELIABILITY OR OTHER REASONS. SO THERE ARE COMMERCIAL ASPECTS TO THIS, RIGHT? YEP. SO I JUST WANT TO UNDERSTAND THAT IF I'M GETTING FROM TRANSMISSION SERVICE, UH, IT MAKES COMMERCIAL SENSE FOR THE GENERATOR TO DO OTHER THINGS THAN JUST TO SERVE THE LOAD. SO HOW IS, HOW IS ARE CUTS SEEING THAT? YEAH, SO WE WOULD ASSUME, SO LET'S TAKE LIKE YOUR YEAR SIX EXAMPLE. UH, WE WOULD ASSUME, BUT WE'RE NOT GONNA IGNORE THAT THAT GENERATION IS THERE. SO IF YOU'RE BRINGING 1200 MEGAWATTS OF GENERATION, WE'RE, WE'RE GOING TO SEE THAT IN THE STUDY. UH, BUT I THINK WHAT IS, UH, MAYBE SLIGHTLY DIFFERENT IS THAT IT WOULD BE, WE, WE WOULD LOOK AT THE G MINUS ONE AND MINUS ONE ASPECT OF THAT, AND TO THE EXTENT THAT THAT DROVE MORE TRANSMISSION, THEN WE WOULD, UM, UH, YOU, YOU KNOW, WE, WE WOULD UH, YOU KNOW, BUILD, YOU KNOW, RECOMMEND THOSE TRANSMISSION PROJECTS, BUT I'M ALREADY REQUESTING TRANSMISSION IN BAD ZERO BECAUSE I NEED TO GET FROM TRANSMISSION, SO IT'S ALREADY BEING STUDIED IN BAD ZERO SO THAT I COULD GET FULL TRANSMISSION, RIGHT? SO I'M JUST TRYING TO UNDERSTAND HOW YOU WILL STUDY THEM. IS IT G MINUS ONE PLUS AND MINUS ONE IN BATCH ZERO THAT YOU'RE GOOD? YEAH. SO IN, IN BATCH ZERO, UM, UH, AND, AND I MAY NEED HELP ON THIS GUYS, BUT I, I THINK IT IS, IS THE CONCEPT THAT WE DESCRIBED, IT'S, IT'S, WE'RE, WE'RE ALMOST ASSUMING WE'RE ALMOST KIND OF DRAWING A BOX AROUND THAT AND, AND WE'RE, WE'RE SORT OF IGNORING THE, THE GENERATION LOAD ASPECT OF THAT. AND WE'RE JUST LOOKING AT YEAH, HOW MUCH NET P EIGHT MEGAWATTS YEAH. NET CAN THE LOAD OR, OR CAN THE SYSTEM SUPPORT HOW MUCH NET NET LOAD THERE CAN THE SYSTEM SUPPORT? AND THAT IS WHAT YOU WERE ALLOCATED. SO YOU'RE THAT THAT'S YOUR SLF ALLOCATION. BUT WHEN IT COMES TO PLANNING TRANSMISSION. WE ARE PLANNING, UH, SORT OF THINKING OF THE GENERATION, THE LOAD, UH, SEPARATE REALLY AS, AS IF THEY'RE BOTH THERE. YEAH. YEAH. JEFF, IF, IF I CAN, THIS IS A SPRINGER. UM, SO I THINK WHAT WE HAVE UP ON THIS SLIDE REALLY HAS CONTEMPLATED THE BRING YOUR OWN GENERATION CONCEPT AS BEING LOADS THAT WANTED TO BRING GENERATION ON A PERMANENT BASIS TO THE SYSTEM. UM, I HESITATE TO SAY THAT THAT'S ENTIRELY WHAT WE HEARD FROM THE FEEDBACK, BUT THAT WAS SORT OF MY TAKEAWAY, UM, FROM THE FEEDBACK THAT WE HEARD IN. SO IT WAS A LITTLE BIT DIFFERENT IN MY MIND FROM THE CLR CONSTRUCT WHERE THE LOAD WAS WILLING TO BE FLEXIBLE IN ORDER TO CONNECT MEGAWATTS SOONER. MY TAKEAWAY FROM THE DESIRE TO BRING GENERATION WAS BASICALLY TO BRING DEDICATED GENERATION TO SERVE THAT LOAD. AND SO THAT'S, UH, I THINK THAT DRIVES A LITTLE BIT WHAT'S DIFFERENT AND HOW JEFF'S DESCRIBING THE TRANSMISSION PLANNING ASPECT OF IT IS THAT AT LEAST TO THIS POINT IN THE DEVELOPMENT OF THIS CONCEPT, WE'RE THINKING ABOUT THIS GENERATION AS BEING THERE TO SERVE THAT LOAD AND NOT A TEMPORARY [05:05:01] SOLUTION. THE WAY CLR HAS KIND OF BEEN DESCRIBED, SO I SEE THIS AS A BRIDGE SOLUTION TO GET FOAM TRANSMISSION POWER, RIGHT? AND THEN ONCE I GET FOAM TRANSMISSION POWER FOR THE LOAD, I CAN CONNECT MY GENERATOR TO THE GRID, UH, FRONT OF THE METER, RIGHT? BECAUSE RIGHT NOW THE GENERATOR IS SERVING THE LOAD AND ERCOT IS NOT SEEING ANYTHING AT THE POI BECAUSE WE ARE MATCHING THE LOAD WITH GENERATOR, RIGHT? YEAR ONE, AS THIS RAMPS UP AS I GET FROM TRANSMISSION, THE AMOUNT OF LOAD THAT I GET FROM THE TRANSMISSION IS REDUCING THE NEED FOR THE GENERATION BEHIND THE METER, RIGHT? SO THAT AMOUNT OF GENERATOR CAN BE CONNECTED TO THE GRID FRONT OF THE METER. SO, SO YEAH. SO I, I THINK THAT INTRODUCES ADDITIONAL COMPLEXITY POTENTIALLY INTO THE DESIGN. UM, I DON'T KNOW IF WE'RE REALLY, I I I THINK WE'D HAVE TO TAKE THAT BACK INTERNALLY AND, AND FIGURE OUT HOW DO YOU STRUCTURE IT WITH AN EXIT DATE AND, UM, NOT SAYING IT'S IMPOSSIBLE, JUST IT'S NOT CONTEMPLATED ON WHAT WE HAVE TODAY. SO YOU ARE SEEING THIS AS STAYING THE GENERATOR IS THERE FOREVER AND YOU STILL GET THE TRANSMISSION TO SERVE THE LOAD. IS THAT HOW YOU'RE SEEING THIS? I THINK THE WAY IT IS STRUCTURED ON THE SLIDE IS THE GENERATION WAS IDENTIFIED AS BEING SERV SERVING THE LOAD. THAT'S, THAT'S THE, THE IDEA BEHIND BRING YOUR OWN GENERATION AND THEREFORE THAT IS ALSO ACCOUNT, THE EXISTENCE OF THAT GENERATION SERVING THE LOAD WOULD ALSO BE ACCOUNTED FOR IN THE TRANSMISSION PLANNING. AND SO, YOU KNOW, ESPECIALLY IN THE CASE OF PUN PLUS, THAT WOULD LIKELY NOT RESULT IN NEW TRANSMISSION BEING PLANNED BECAUSE THERE'S THAT MUCH GENERATION THERE SERVING THE LOAD. AND SO IT, WHAT I'M REALLY TRYING TO SAY IS NOT NECESSARILY THAT ERCOT IS OPPOSED TO GENERATION AS A BRIDGING SOLUTION, BUT IT IS NOT REFLECTED IN THE DESIGN THAT WE HAVE BEEN WORKING ON SO FAR. OKAY, THANKS. SORRY, I NEED TO RUN THE QUEUE. UM, WHAT AM I DOING? BOB KING COMING BACK TO YOU SIR. THANKS FOR BEING PATIENT. HI, THANK YOU. UM, SO JEFF, YOU MENTIONED THAT THE PUN PLUS HAS, UM, A SINGLE POI BUT A PUN WOULD ALSO ALLOW INTERCONNECTION OF TWO POIS AT THE SAME SUBSTATION, THE SAME VOLTAGE. IS THAT NOT POSSIBLE IN THIS CASE? IT'S, I NEED TO, I'M NOT SURE I NEED TO PHONE A FRIEND ON THAT. YEAH, I THINK WE'RE JUST TRYING TO BE REAL CONCEPTUAL RIGHT NOW RATHER THAN GET INTO ALL THE TWO GETAWAYS, THREE GETAWAYS, N MINUS ONE G MINUS ONE TRANSFORMER MINUS ONE. WE ARE JUST TRYING TO SEE IS THIS WHERE YOU WANT US TO GO? SO, SO THEN THE FEEDBACK IS, YES, I LOVE THE PUN PLUS, BUT THERE SHOULDN'T BE A CONCEPTUAL EVEN DIFFERENCE. THERE'S CERTAINLY NOT MUCH TECHNICAL DIFFERENCE AND HAVING TWO POIS IN THE SAME SUBSTATION AT THE SAME VOLTAGE, WHICH IS YOUR PUN REQUIREMENT, AND THERE'S A NUMBER OF CASES WHERE THAT WOULD MAKE SENSE. UM, AND YOU SAID TAKING CREDIT FOR THE GENERATION, I WANNA MAKE SURE THE DIFFERENCE BETWEEN THIS AND JUST PROPOSING UPON DESIGNATING SOME LOAD BEHIND IT IS THAT EVEN IF THEY'RE NOT YET BUILT, YOU CAN BUILD THEM BOTH AT THE SAME TIME AND SORT OF IN PARALLEL RAMP THEM UP, RIGHT? SO YOUR CREDIT AND IN ADVANCE IS THE BENEFIT YOU'RE TALKING ABOUT, SO I LIKE THAT. YES. UM, ON, UM, I DON'T WANNA STIR CHRIS, BUT I DON'T QUITE SEE THE DIFFERENCE BETWEEN THAT AND WHAT HE WAS ARGUING FOR. CAN YOU ANSWER THAT REAL SIMPLY OR, I, I DON'T REMEMBER WHAT HE WAS ARGUING FOR NOW. I WAS JUST GONE, SO IT'S SAFE. OKAY. WELL LET ME ASK THE LAST QUESTION REAL QUICK AND WE, I'LL PIN YOU DOWN SOME OTHER TIME. UM, ON THE THIRD ONE, THE SELF-LIMITING, IF I ASKED FOR 500 MEGAWATTS, WOULD I ALSO AT THE SAME TIME SAY HOWEVER I'M WILLING TO BE SELF-LIMITED DOWN TO AS LITTLE AS A HUNDRED OR SOMETHING LIKE THAT? SO YOU WOULD KNOW, OKAY, WELL WE'VE GOT A HUNDRED SO WE CAN INCLUDE HIM, AND THEN I WOULD HAVE SOME PERIOD OF TIME, MAYBE EVEN TO THE SIXTH YEAR THAT I WOULD HAVE TO BE SELF-LIMITED, BUT YOU'RE GONNA NEED TO KNOW WHAT MY MINIMUM IS, RIGHT? [05:10:02] SEEMS LIKE THERE'S, THAT'S A PIECE THAT NEEDS TO BE INCLUDED. YEAH, THIS IS AG. SO, UH, I'LL JUST DESCRIBE HOW THE CURRENT SELF-LIMITING CONSTRUCT WORKS, WHICH IS THAT THE INTERCONNECTING ENTITY DEFINES PRIOR TO THE INTERCONNECTION STUDIES WHAT THEIR DESIRED INTER UH, INJECTION AND WITHDRAWAL LIMITS ARE. AND WITHDRAWAL LIMIT WOULD ONLY BE FOR A ENERGY STORAGE. UM, AND THEN THAT IS WHAT IS STUDIED. I THINK IT, WE ARE STILL NOT SURE. YOU MAY NOTICE THERE'S A FOOTNOTE DOWN HERE SAYING THIS IS ALL CONCEPTUAL AND WE'RE STILL VETTING SOME OF THESE CONCEPTS INTERNALLY. UM, WHETHER OR NOT WE WOULD CHANGE THAT, THAT FLOW FOR A SELF-LIMITING FACILITY THAT INCLUDES LOAD. UM, BUT I, I THINK IN IN, IF THE INTERCONNECTING LARGE LOAD ENTITY WOULD LIKE TO, YOU KNOW, COMES TO US AND SAYS, I WANT A SELF-LIMITING FACILITY, A 500 MEGAWATTS AND THAT CANNOT BE ACCOMMODATED, UM, I DON'T KNOW RIGHT NOW IF, IF IT WOULD BE LIKE OTHER FIRM LOAD WHERE WE WOULD OFFER A LOWER AMOUNT OR NOT. WELL FOR THE CLR YOU'RE CONSIDERING, OKAY, I'M WILLING TO BE CLR DOWN TO A LIMIT, RIGHT? 'CAUSE THERE'S PROBABLY SOME, BUT THAT LIMIT IS DEFINED BEFOREHAND AND SO, RIGHT. YEAH, WELL THAT'S WHAT I'M SAYING. I WOULD DEFINE IT AHEAD OF TIME. I MEAN, SO FOR THE RECORD, I THINK I DID MAYBE ONE OF THE FIRST SELF-LIMITING FACILITIES ON THE GENERATION SIDE WHERE WE JUST KNEW WHAT THE LIMIT WAS AHEAD OF TIME. SO WE SAID WE WANTED TO ADD SOME STORAGE BEHIND THIS THING, BUT WE'RE WILLING TO MAKE SURE THAT IT DOESN'T COME ON AT THE SAME TIME AS THE GENERATOR. SO WE SIGNED A SELF-LIMITING AGREEMENT. I'M THINKING IT OF IT KIND OF LIKE THAT, BUT, SO I MIGHT APPLY TO BE A 500 MEGAWATT LOAD, BUT I WOULD AGREE, UH, IF THAT'S NOT AVAILABLE, THAT I WOULD BE WILLING TO BE INCLUDED DOWN TO A HUNDRED SELF-LIMITING KNOWING THAT I COULD PROVIDE MOST OF THE TIME OTHERS ON SITE OR SOMETHING LIKE THAT. YEAH, I THINK THAT'S, ANYWAY, LET'S, THAT'S, LET'S ABOUT THAT'S POTENTIALLY, YOU KNOW, I THINK WE'RE, WE'RE THINKING ALONG THOSE LINES FOR HOW WE DESIGN THIS, BUT YOU KNOW, WE'RE STILL KIND OF IN THE CONCEPTUAL STAGE. RIGHT. THANKS. UH, NEXT IN THE QUEUE IS SHANNON, THANK Y'ALL FOR WORKING HARD TO TRY TO PUT SOMETHING TOGETHER ON THIS AND ENTERTAINING ALL OF OUR QUESTIONS AND TRYING TO UNDERSTAND IT WITH YOU. I'VE GOT A QUICK QUESTION ON THE, THE SLF APPROACH. IF YOU COME IN AS SLF, ARE YOU BEING STUDIED IN EACH SUBSEQUENT YEAR AS IF YOU WERE A PUN PLUS, SO THAT WHAT TRANSMISSION CAN COME WILL COME AS IT CAN COME UNDER THE TRADITIONAL RELIABILITY PLANNING PROCESS WITHOUT WAITING TO YEAR SIX? SO I'LL STOP THERE AND LET YOU ANSWER THAT FIRST. YEAH, GO AHEAD. AG. YEAH. HEY SHANNON. UM, SO I, I'LL REITERATE WHAT I SAID TO BROTH, WHICH IS AS, AS IT APPEARS ON THE SLIDE, WE REALLY HAVE BEEN THINKING ABOUT BOTH OF THESE STRUCTURES AS MORE OF A PERMANENT CONFIGURATION THAT THE LOAD IS BRINGING ITS OWN GENERATION WITH IT. AND SO IT SHOULD BE STUDIED ACCORDINGLY. I THINK WE'RE HEARING THIS FEEDBACK NOW THAT THERE'S ALSO A DESIRE TO HAVE A, WHAT I WOULD CALL A TEMPORARY SELF-LIMITING FACILITY WITH A PATH TO FIRM TRANSMISSION SERVICE. I THINK THAT'S SOMETHING WE CAN TAKE BACK AND AND DISCUSS, BUT I HA HAVING NOT BROUGHT THAT TO THE MEETING TODAY, I DON'T REALLY HAVE A FIRM ANSWER FOR HOW THAT WOULD WORK. BUT, UM, YOU KNOW, FOR THE SELF-LIMITING FACILITY, EFFECTIVELY IT WOULD BE STUDIED AS A, THAT IS THE PROPOSED LIMIT ON THE WITHDRAWAL FROM THE SYSTEM. SO IT WOULD ENTER, YOU KNOW, IF THE, IF THE INTERCONNECTING LARGE LOAD ENTITY IS BRINGING, UH, ENOUGH GENERATIONS SO THAT THEIR WITHDRAWAL LIMIT IS 300 MEGAWATTS, THEN THAT'S WHAT WOULD BE ASSESSED AS THE REQUEST. UM, AND THE GENERATION WOULD ALSO HAVE TO BE, GO THROUGH THE I AND R PROCESS, WHATEVER GENERATION'S BEING BROUGHT TO FACILITATE THAT. OKAY. IT SEEMS TO MAKE SENSE OR THANKS FOR THAT EXPLANATION ON THIS SELF-LIMITING FACILITY THING. THE WAY I'VE BEEN THINKING ABOUT IT, AND WE DO HAVE A PROJECT THAT FITS INTO THIS AND SO I'VE BEEN TRYING TO ABSORB WHAT Y'ALL ARE SAYING AND THINK ABOUT HOW IT FITS TOGETHER. THE WAY I'VE BEEN THINKING ABOUT IT IS I'M NOT OPPOSED TO SHOWING UP AS A SELF-LIMITING FACILITY AT FIRST, THOUGH. I WANT ALL THE FIRM THAT CAN, THAT INHERENTLY EXISTS AND THEN I'LL SELF LIMIT ON A G MINUS ONE BASIS FOR THE REST AT, AT FIRST. [05:15:01] BUT I WANT TO BE ON A PATH TO PUN PLUS. IN OTHER WORDS, I SHOULD NEVER BE WORSE OFF THAT I SHOWED UP THIS WAY. I, IF I'M WILLING TO ACCEPT OR, AND OUR CUSTOMERS ARE THE LIMITS THAT GO WITH SELF ING FACILITY ON THE PATH TO PUN PLUS UNDER A TRADITIONAL PLANNING APPROACH, TO ME THAT'S THE, THE GOAL WE SHOULD ALL BE LOOKING FOR. JUST BECAUSE IT'S SO MUCH MORE ECONOMICALLY EFFICIENT. EVEN IF WE'RE BRINGING SIX AND A HALF HEAT RATE COMBINED CYCLES. I MEAN THE MOST EFFICIENT GAS GENERATION YOU CAN BRING STILL PROBABLY HAS LESS THAN A 50%, UH, CAPACITY FACTOR. SO WE SHOULD WANT IT FROM A SYSTEM EFFICIENCY PERSPECTIVE TO BE ON A PATH TO PUN, PUN PLUS. ALRIGHT, SO THERE'S ONE POINT. THE OTHER QUESTION I'D HAVE FOR YOU IS ON THE, UM, THE MONITORING OR THE RELAY EQUIPMENT HERE. A QUESTION FOR YOU I WOULD HAVE IS IF YOU HAVE THAT JUST SIMPLY ON THE IMPORT PATH, UM, YOU KNOW, THAT'S ONE THING THAT'S REAL SIMPLE TO THINK ABOUT, BUT UNDER MANY, MANY, MANY OF THESE, UH, G MINUS ONE N MINUS ONE PROBLEMS, THE N MINUS ONE, THAT'S ACTUALLY THE PROBLEM IS THE OTHER PATH IN THE ONE THAT YOU'VE GOT HERE. AND SO IT WOULD JUST, YOU KNOW, HISTORICALLY THIS WOULD BE LIKE 20 PLUS YEARS AGO, ENCORE HAD PUT THROUGH ENCORE OPERATIONS, ELLIS RANKIN WAS THE ONE WHO PUSHED IT THROUGH AN APPROACH WHERE WHEN IT WAS PURE LOCAL MONITORING THAT IT WAS NOT TREATED AS RAZ. I DON'T KNOW WHERE THAT STANDS TODAY. I HAVEN'T KEPT UP WITH IT EVERY YEAR SINCE THEN. BUT I THINK IT WAS WISE THEN, AND COULD BE WISE HERE TO THINK ABOUT IT BECAUSE WE COULD, I MEAN THE G MINUS ONE N MINUS ONE IS INFINITELY LESS PROBABLE. I MEAN IT'S NOT INFINITE, BUT IT'S SUBSTANTIALLY LESS PROBABLE TO OCCUR THAN THE N MINUS ONE. AND THIS WOULD JUST GIVE YOU LOCAL MONITORING TO BE ABLE TO USE IN THIS SELF-LIMITING THAT IF THE TSP CAN DEVISE IT, THE KEY N MINUS ONES ARE THE LOCAL ONES. TO ME THAT WOULD BE MORE SYSTEM EFFICIENT IF, IF THAT COULD BE CONSIDERED. I THINK SHANNON, WOW, WE HAVE A LOT, LOT OF PEOPLE IN THE QUEUE. SO HERE WE GO, SAM, BRANDON. HEY, THANKS FOR ALL THIS. UM, SO TWO QUESTIONS ON THE PUN, PUN PLUS STRUCTURE. UM, SO ONE, HISTORICALLY SPEAKING PRIVATE USE NETWORKS ARE, UM, A LOAD THAT IS NETTED BEHIND THE SAME METER WITH A GENERATION RESOURCE. SO I DON'T THINK THAT'S WHAT ERCOT MEANS TO IMPLY WITH THIS PUN PLUS TERMINOLOGY. BUT I JUST WANTED TO, I GUESS, ASK THE QUESTION EXPLICITLY IF YOU HAVE SEPARATELY REGISTERED RESOURCES. ONE IS GENERATOR, ONE IS A LOAD BEHIND THE SAME POI THAT WOULD UM, BE CAPTURED WITHIN THIS PUN PLUS CONCEPT. LET ME KNOW IF THAT'S THE THINKING. KENNETH, CAN YOU HELP ON THAT ONE? POSSIBLY? YEAH, I WOULD, I WOULD SAY TODAY AT OUR PRIVATE USE NETWORKS, WE DO HAVE ALL THE GENERATORS BACK THERE REGISTERED AND THERE COULD BE A LOAD RESOURCE BACK THERE. SO WE DO SEE EACH OF THE, EACH OF THOSE RESOURCES. AND I WOULD SAY WE, THAT WE WOULD STILL DO THAT HERE. OKAY. SO I GUESS THAT'S, IT'S REALLY MORE OF A COMMENT ABOUT SETTLEMENTS THEN. 'CAUSE USUALLY WITH A PUN, YOU'RE NETTING THE GEN IN THE LOAD. BUT UM, IN THE EXAMPLE THAT I'M REFERENCING, YOU'D HAVE SEPARATELY REGISTERED OR SETTLED IN AND NET IN REGISTERED LOAD AND THEN SEPARATELY SETTLED AND REGISTERED GENERATION THAT SHARE A POI. BUT THEY'RE SEPARATELY SETTLED RESOURCES. SO I, I THINK PHYSICALLY THAT'S THE EXACT SAME ARRANGEMENT. IT'S JUST A METERING QUESTION DUE TO THE LEGACY NATURE OF PRIVATE USE NETWORKS. I DON'T, SO I'LL PASS ON THE METERING QUESTION. WE CAN GO TO BILL BARNES. HE'S A METERING EXPERT . YEAH. UH, NO, MAYBE WE CAN LOOK INTO THAT, BUT THAT'S NOT WHAT I WOULD'VE EXPECTED WITH THIS PICTURE. YEAH, I CAN SAY SOMETHING ABOUT THAT. THAT THE ISSUE IS IF YOU'RE A PUN, THAT YOU HAVE TO DESIGNATE THE LOAD SPECIFICALLY IN RIO THAT YOU'RE SERVING FROM THAT GENERATOR. RIGHT. SO IF YOU WANT MAKE IT A PUN, YOU REGISTERS A PUN AND YOU DESIGNATE SPECIFIC LOAD TO BE ASSOCIATED WITH THAT GENERATOR IN ADVANCE AND IT'S MODELED THAT WAY. YEAH, IT'S, IT'S THE SITE THAT'S DESIGNATED AS A PUN. THE SITE IS A PUN. AND THEN, RIGHT, THERE'S A CONNECTION. THERE'S FIVE GENERATORS BACK THERE, THERE'S THESE LOADS BACK THERE, THEY ARE IN THE PUN AND METERING TODAY. TYPICALLY ALL THE PUNS HAVE, YOU KNOW, A [05:20:01] METER THERE AT THAT POINT OF INTERCONNECT. GOTCHA. I THINK WE'RE, I THINK WE'RE SAYING THE SAME THING TO BE HONEST. UM, BUT MAYBE MY NEXT QUESTION WILL HELP ELIMINATE WHY I'M ASKING THAT QUESTION. SO THE NEXT QUESTION IS FOR A PUN PLUS STRUCTURE. YOU KNOW, WE'RE USING THE TERM GENERATION. IS THAT A-P-U-C-T DEFINITION GENERATOR OR IS IT ERCOT DEFINITION GENERATION? BECAUSE DOES THIS APPLY TO RESOURCES THAT CO-LOCATE WITH ENERGY STORAGE RESOURCES AND I GUESS TO, YOU KNOW, LEAD THE WITNESS? I CERTAINLY THINK IT'S RATIONAL TO INCLUDE THIS CONCEPT WITH ENERGY STORAGE RESOURCES AS WELL BECAUSE, UM, AT LEAST THE POINT THAT WAS TRYING TO BE MADE AT LARGE LOAD WORKING GROUP WAS THAT WE SHOULD HOLD HARMLESS THE TREATMENT OF CO-LOCATED GENERATION AND LOAD. WHERE IF THOSE WERE SEPARATE RE IF THOSE WERE SEPARATE UNAFFILIATED RESOURCES, THEY WOULD HAVE THIS DYNAMIC THAT'S BEEN DESCRIBED AS BUSINESS AS USUAL. AND SO THE SAME CONCEPT APPLIES TO LOAD THAT IS CO-LOCATED WITH ENERGY STORAGE. YOU WOULD JUST NEED TO ACCOUNT FOR THE FACT THAT THE ENERGY STORAGE NEEDS TO FOLLOW THE TREATMENT THAT'S LAID OUT IN THE STEADY STATE, UH, MANUAL WITH ELCC ACCOUNTING FOR. SO THAT'S A LONG-WINDED WAY OF SAYING I'M INTERESTED TO GET KOS THOUGHTS ON, ARE YOU CONSIDERING ENERGY STORAGE AS DISPATCHABLE ONSITE GENERATION UNDER PUN PLUS I I THINK NOT FOR BATCH ZERO. UH, I THINK LONG TERM I THINK WE'RE INTERESTED IN THAT. BUT YEAH, I THINK THERE ARE SOME STUDY CONSIDERATIONS THAT WE'D HAVE TO THINK THROUGH AND, AND I JUST, I DON'T THINK THAT WE'RE GONNA GET THERE FOR BATCH ZERO. AND I GUESS IS THAT LIKE ADDITIONAL STEADY STATE CASES? BECAUSE IF IT'S THE SAME STEADY STATE CASES, THERE'S ALREADY A WELL DOCUMENTED FRAMEWORK FOR STUDYING THOSE ENERGY STORAGE RESOURCES. I, I THINK TBD. OKAY. ALL RIGHT. BILL BARNES, WELL POSITIVE FEEDBACK. YOU'RE LOOKING FOR THE SENTIMENT. GREAT. LIKE WE'RE HEADING IN THE RIGHT DIRECTION. I REALLY APPRECIATE , UH, AND SIMPLE WOULD BE EVEN BETTER. , I DON'T HAVE ANYTHING TO SAY SIMPLE. I'M SORRY. COME ON. ALRIGHT. UM, YES, UH, APPRECIATE THE CONSIDERATION OF THESE ARRANGEMENTS AND UH, ACCOMMODATING DIFFERENT OPTIONS. SO THE BUSINESS AS USUAL, THE WAY THAT I'M SEEING THAT, WHICH IS I THINK WE CAME, CAME UP LAST DISCUSSION IS UM, RIGHT NOW YOU CAN NET MULTIPLE POIS UNDER UM, SECTION 10.3 OF THE PROTOCOLS IF THEY'RE THE POIS ARE ALL WITHIN A COMMON SWITCH YARD, WHICH IS YOUR 400 YARD RULE. UH, THAT I UNDERSTAND WHY THAT DOESN'T WORK FOR A SELF-LIMITING FACILITY. 'CAUSE YOU NEED A SINGLE POI TO TO LIMIT IT. UM, BUT IF YOU'RE DOING PUN PLUS, UM, WELL ANYHOW, I GET, I GET WHY WE, THE NETTING RULES DON'T APPLY TO WHAT YOU NEED TO APPLY HERE FOR PUN PLUS AND SLF UM, ON, AND WE'VE, I THINK WE'VE COVERED THIS, BUT TWO MAIN QUESTIONS FOR BOTH. ONE IS SAYING THAT AS I HAD WITH THE CLRS, WHAT DO YOU NEED TO REGISTER TO GET THESE, THIS TREATMENT? IT SOUNDS LIKE CAPITAL G, CAPITAL R PARTICULARLY BECAUSE I SEE IN OPERATIONS ERCOT MAY REJECT OUTAGES, WHICH THOSE AREN'T SUBMITTED FOR SETTLEMENT ONLY GENERATORS AND THEN RUCK RESOURCES, THE WAY I AM INTERPRETING WHAT THAT MEANS IS, AS A PUN, LET'S SAY I HAVE A THOUSAND MEGAWATTS OF GEN AND 500 MEGAWATTS OF LOAD, I AM TELEMETRY AN H OF LHSL OF 500 TO THE ERCOT SYSTEM. SO WHAT'S AVAILABLE FOR R WOULD BE THE EX EXCESS GENERATION CAPACITY. IS THAT WHAT WE'RE THINKING ON THAT ONE? ACTUALLY IT'S KIND THE REVERSE. IT'S IF IT'S A THOUSAND MEGAWATT LOAD AND IN THE COP THE ONLY PLAN TO RUN 500 MEGAWATTS THAT HOUR, WE'RE GONNA WANNA R TO FIND THE DIFFERENCE. OKAY. SO WE'RE GONNA TURN THE OTHER STUFF BACK ON. OKAY. AS LONG AS IT'S KIND OF NETTED. THAT MAKES SENSE. UM, AND THEN SPECIFICALLY WHAT WILL WILL ERCOT, WHAT DO YOU THINK ERCOT WILL NEED TO SEE IN TERMS OF INTERCONNECTION STUDIES NEEDING TO BE COMPLETE FOR BOTH PUN PLUS AND THE SELF-LIMITING FACILITY? SO STARTING WITH PUN PLUS TO BE INCLUDED IN BATCH ZERO TO BE COUNTED AS PUN PLUS, WHAT DO YOU NEED TO SEE THAT WE HAVE DONE? AND THIS KIND OF IS RELATED TO THE COMMENTS THAT WE FILED ON MARCH 9TH, WHICH WAS DO YOU NEED A-A-G-I-N-R-F-F-I-S COMPLETED? DO YOU NEED AN LLIS AS WELL? WHAT, LIKE WHAT ARE YOU THINKING ON THAT? WHAT STUDIES NEED TO BE DONE TO BE INCLUDED BY, I I THINK, UM, WE WILL LIKELY HAVE THE ANSWER TO THIS AT THE NEXT WORKSHOP. UH, WE'RE STILL DISCUSSING THIS, BUT I WILL SAY CONCEPTUALLY WHAT WE ARE WORKING [05:25:01] ON FOR THE GENERATION SIDE IS IT WOULD BE, WE WOULD ALLOW FOR THE INCLUSION OF THE GENERATION PRIOR TO IT MEETING PLANNING GUIDE 6.9 CRITERIA. UM, BUT HOW MUCH EARLIER WE'RE STILL DISCUSSING. OKAY. UM, FOR THE LOADS, THE LOAD PIECE THAT WOULD NEED TO MEET ACCORDING TO THE CURRENT, WHAT WE'VE GOT IN THE PIGGER RIGHT NOW, I DON'T THINK AT THE MOMENT WE'RE DISCUSSING ALLOWING FOR EARLIER STAGE LOADS TO BE INCLUDED IN, IN THE STUDY BEYOND WHAT WE'VE ALREADY GOTTEN PICKER 1 45. OKAY. UM, YEAH, I THINK THAT THAT'S, AND THAT, IS THAT THE SAME ANSWER FOR THE SELF-LIMITING FACILITY AS WELL? LIKELY, YES. OKAY. BUT AGAIN, I, I WOULD SAY WE HOPE TO HAVE MORE ON THAT THE NEXT WORKSHOP. OKAY, THANK YOU. AND THEN THIS IS WHERE I MAKE IT COMPLICATED. TWO ADDITIONAL THOUGHTS TO CONSIDER ON PUMP PLUS AND SELF LIVING FACILITY. 'CAUSE WE'RE THOSE BOTH WORK GREAT. WE ARE ALSO SEEING KIND OF A HYBRID BETWEEN THOSE TWO WHERE, I DON'T KNOW WHAT YOU WANNA CALL IT, PUN MINUS OR A SELF-LIMITING FACILITY, PUN PLUS WHERE YOUR G MINUS ONE DOESN'T COVER THE PEAK LOAD, BUT YOU STILL HAVE OVERSIZED THE GENERATION. SO EXAMPLE TWO 500 MEGAWATT BLOCKS OF GENERATION SERVING AN 800 MEGAWATT LOAD. SO YOU'RE NOT G MINUS ONE SECURE, BUT YOUR INTERCONNECTION STUDIES IS DESIGNING A INTERCONNECTION FACILITY THAT, THAT EXCEEDS THE LOAD. SO YOU PRESUMABLY YOU'RE NOT GONNA HAVE THE, THE ISSUES ON THE LOAD INTERCONNECTION STUDY SIDE. SO IT'S KIND OF IN BETWEEN THOSE TWO. THAT'S ONE, UH, ARRANGEMENT I WOULD OFFER THAT YOU CONSIDER. AND THEN THE SECOND IS, I THINK SHANNON WAS KIND OF TOUCHING ON THIS FOR A SELF-LIMITING FACILITY. SO GOING BACK TO THE TWO 500 MEGAWATT BOX FOR 800 MEGAWATT LOAD RIGHT NOW UNDER THEIR SLF, WE WOULD BE LIMITED AT A 500 MEGAWATT WITHDRAWAL FROM THE SYSTEM. BUT I, I'VE, I THINK IT MAKES SENSE IF THERE IS A POTENTIAL PROCESS HERE, AND I'M GONNA TIE THIS TO THE VECL CONCEPT WHERE WE SAY WE'RE WILLING TO MAKE SURE THAT THE LOAD FOR THAT SELF LIVING FACILITY, IT GOES TO ZERO BECAUSE WE HAVE OVERSIZED DEGENERATION DURING AN ERCOT DISPATCH OF A-V-E-C-L, WHICH IS PRIOR TO AN DEA OR DURING A TRANSMISSION EMERGENCY. AND IN THAT CASE, I THINK WOULD MAKE SENSE TO LIFT THE, THE LIMIT ON WHAT YOUR WITHDRAWAL IS. SO YOU COULD CONSUME MORE, LIKE WHEN IT'S, WE HAVE 40 GIGS OF SOLAR OPERATING AND PRICES ARE ZERO, YOU SHUT DOWN BOTH BLOCKS AND YOU'RE CONSUMING THE FULL 800 MEGAWATTS FROM THE GRID. AND IF THE SYSTEM GETS TIGHT DURING PEAK LOAD, YOU'VE ALREADY COMMITTED THAT ERCOT WILL BE ABLE TO, UH, HAVE, HAVE DISPATCH RIGHTS OVER BOTH THOSE GENERATION RESOURCES TO COVER THE LOAD TO MAKE SURE IT'S CONSUMING ZERO DURING THOSE EVENTS. SO THAT'S ANOTHER WRINKLE OR VARIATION OF S-L-F-S-L-F PLUS, I DON'T KNOW. UM, SO THOSE ARE DIFFERENT VARIATIONS THAT ARE, THAT I SEE RIGHT NOW THAT ARE BEING DISCUSSED IN THE MARKET. BUT I MEAN BOTH OF THESE WOULD WORK WELL NOW I JUST THINK THEY, THERE IS POSSIBLE MODIFICATIONS TO MAKE THEM, UH, MORE FLEXIBLE AND YEAH, BILL, REAL QUICK ON THOSE. SO, UH, I THINK WE'RE NOT OPPOSED TO THOSE, BUT THERE ARE ADDITIONAL STUDY COMPLICATIONS. WE, WE DON'T THINK THAT WE'RE GONNA BE ABLE TO ADDRESS THAT FOR BATCH ZERO. OKAY. SO MAYBE FOR THE LATER BATCH STUDIES. TOTALLY OPEN FOR ONGOING AWESOME. ADDRESSING THIS. AND THEN I JUST CONFIRMING WHAT I HEARD I THINK IS FOR BOTH PUN PLUS AND UH, THE SELF-LIMITING FACILITY FOR BATCH ZERO, THIS WOULD ALSO REQUIRE SOME TYPE OF, UH, ATTESTATION OR A, AN AGREEMENT OR A COMMITMENT TO SAY WE'RE GONNA DO THIS ARRANGEMENT. STILL THINKING ABOUT, OKAY, THAT SOUNDS GOOD. THANKS. YOU BET. ANDRES, ANDRES, I WANNA GET SOME CLARIFICATION ON THE GEN NETTING GENERATION NETTING. I KNOW SOME PEOPLE HAVE BROUGHT THIS UP. JUST WANT TO CLARIFY LIKE, DO ALL THESE CONFIGURATIONS QUALIFY FOR ENDPOINT 3.2 0.3? 'CAUSE IT LOOKS LIKE THAT DOES ALLOW FOR MULTIPLE POIS THAT SHARE A COMMON SWITCH ARE AS LONG AS THEY'RE LIKE WITHIN 400 YARDS AND SAME VOLTAGE LEVEL. SO I, I JUST WANT TO GET SOME CLARITY ON THAT. I, I THINK I'M, I'M NOT OPPOSED TO THAT CONCEPTUALLY, BUT WE MAY NEED TO GO BACK AND RUN, RUN THAT THROUGH TRAPS INTERNALLY TO SEE WHAT, WHAT THE POTEN IF THERE ARE ANY POTENTIAL ISSUES WITH THAT. OKAY. UH, I GUESS NEXT QUESTION, IT'S ON THE SLF CONCEPTS. UM, IF WE WANT TO DO SLF AND WE WANNA GO BELOW 75 MEGAWATTS, WOULD WE STILL HAVE TO GO THROUGH THE BACKSTORY PROCESS? SO YOU'RE SAYING CAN YOU USE [05:30:01] THE SELF-LIMITING FACILITY? I HAVE A THOUSAND MEGAWATT UNIT THAT'S ISLANDED A ZERO TO NOT BE A, TO AVOID GOING THROUGH THE LARGE LI OR I THINK HE'S SAYING 74, HE SAYS HE GETS A DOWN OF 74 OR LESS THAN 75. WELL THAT'S, I WAS EXAGGERATING AND SAY, WELL, IF IT WASN'T 74, IF IT WAS ZERO, WHAT ARE WE TALKING ABOUT? IS THIS, SORRY, CAN YOU ASK YOUR QUESTION, DEAN? YEAH, I, AND SO I THINK THE ANSWER IS NO BECAUSE I THINK THERE ARE SOME STABILITY STUDY IMPLICATIONS THERE, BUT WE WE MAY NEED TO CLARIFY THAT. YEAH, I THINK THERE'S ALSO A PRETTY CLEAR, UM, STANDARD THAT A LARGE LOAD IS DEFINED AS A 75 MEGAWATT LOAD AND WE'RE NOT TALKING ABOUT ACUTE, UM, METERING ARRANGEMENTS TO SAY IT'S A 76 LOAD AND NOW I HAVE A TWO MEGAWATT LIMIT. NO, IT'S A 75 MEGAWATT LOAD. ALL RIGHT, SO IF I'VE GOT THIS RIGHT, EVEN IF WE SELF LIMIT AND WE TARGET SOMETHING BELOW 75, WE WOULD STILL BE SUBJECT TO GO THROUGH BATCH. YES. JUST BECAUSE YES, IF THAT TRIANGLE ON THE DIAGRAM IS BIGGER THAN 75 MEGAWATTS, YOU HAVE TO GO THROUGH THE BATCH. THIS NETTING CONCEPT DOESN'T CHANGE THAT TRIANGLE IS WHAT'S REGISTERING. UNDERSTOOD. YEAH. AND I WOULD ALSO ADD THAT AS CONSISTENT WITH SECTION 9 2 1 IN BOTH THE CURRENT PLANNING GUIDE AND BIGGER 1 45. YEP. SUPER HELPFUL. THANK YOU. YOU BET. KEVIN HANSON. YEAH. HONESTLY, AND WE'RE NOT GONNA GET TO THE END OF THE QUEUE POSSIBLY JUST TO BRACE FOR THAT DISAPPOINTMENT. YEAH. JUST QUICK QUESTION. UM, WOULD THE PUN PLUS GENERATION FALL UNDER THE MURDER PLAQUE LIMITATIONS WE HAVE IN PLACE? DON'T HAVE OPERATIONS HERE, BUT I THINK, YES. OKAY. SO THERE, NED YOU CAN CORRECT ME IF I'M WRONG, BUT I THINK WE HAVE AN ANNUAL OLD CAP OF WHAT, 30 ISH GIGAWATTS RIGHT NOW. ROUGHLY. WE HIT THE, THE HIGHEST POINT OF THE YEAR FOR LIMITATIONS WITH MOTOR PARK RIGHT NOW. IF WE ADD ANOTHER 50 GIGAWATT GIGAWATTS OF PUN PLUS GENERATION, WE'RE GONNA BE SORT OF HOSED IN TERMS OF OPERATIONS WISE CALCULATION. THAT IS A CALCULATION, SO IT SHOULD NOT BE AN ISSUE. AND DR POCS, UM, HAVE A CALCULATION AND I FORGET ALL THE INPUTS NOW, BUT IT'S, IT HAS TO DO WITH, UM, UH, RENEWABLE LOAD, THERMAL GEN, UM, AND SOME OTHER ASPECTS. SO, SO IT SHOULD NOT BE AN ISSUE TO WORRY ABOUT. WE MAY NEED TO REDO THE CALCULATION SLIGHTLY JUST IF WE HAVE A VERY DIFFERENT WORLD AHEAD, BUT NO, IT, IT WOULDN'T, IT'S NOT LIKE A HARD AND FAST. OKAY. GREAT. ALL RIGHT. UH, JOEL DAVIS. AH, THERE WE GO. SORRY. YEP, GO AHEAD. UM, I'M A, I HAVE A SETTLEMENT QUESTION, SO WE MAY NOT HAVE THE RIGHT FOLKS HERE, BUT ON I CAN IMAGINE MANY OF THESE PUN PLUS CONFIGURATIONS FAILING THE MARKET POWER TEST. WHAT IS THE PLAN FOR HANDLING THAT? YEAH, WE HAVEN'T GOTTEN TO THAT POINT, SORRY. OKAY. ALL RIGHT. NEXT ONE. UM, MONICA, YEAH, I THINK IS WRITING THAT DOWN. SO WE'LL, WE'LL TAKE THAT BACK. YEP. OKAY. MONICA RADER. HI MONICA WITH ENCHANTED ROCK. UM, QUICK FOLLOW UP TO BILL'S ROCK QUESTION. I WAS WONDERING IF THERE IS A PRE EMERGENCY OR EMERGENCY SCENARIO WHERE ERCOT WOULD WANT TO BOTH CURTAIL THE LOAD AND DISPATCH THE GENERATION IN THIS PUN PLUS ARRANGEMENT? SORRY, ASK IT AGAIN. JUST SLOWING DOWN TO THINK THROUGH THAT. GO AHEAD. IS, IS THERE A SCENARIO LIKE A PRE EMER IN A PRE EMERGENCY OR EMERGENCY EVENT WHERE ERCOT WOULD WANT TO BOTH CURTAIL THE LOAD AND DISPATCH THE GEN FOR RELIABILITY IF IT'S A BAD SPOT? I THINK THE LAST BULLET ON THAT ONE IN THE MIDDLE SAYS IN REALTIME MITIGATION PLANS OR LOCAL LOAD SHED MAY BE USED. SO I THINK THE ANSWER IS YES. OKAY. YEAH. BUT, BUT NOT, I DON'T THINK THAT WE'VE CONTEMPLATED LIKE IN IN OUR EEA RULES AS WE'RE THINKING THROUGH LIKE THE SENATE BILL SIX, I DON'T THINK WE'RE THINKING ABOUT DOING ANYTHING DIFFERENT OR SPECIAL WITH THE PUN PLUS OKAY. PARAMETERS WOULD BE HELPFUL, I GUESS FOR THAT SITUATION. THANKS. THANKS MONICA. UM, HARSH, HARSH NACK ENCORE, JEFF, THE POINT ABOUT NO TRANSMISSION UPGRADES WOULD BE NEEDED IN PUN PLUS CONFIGURATION. UM, I WAS THINKING ABOUT G MINUS ONE PLUS N MINUS ONE CONTINGENCY [05:35:01] WHERE THAT SECOND N MINUS ONE COULD BE THE SECOND UNIT AT THE SAME PLANT. YEAH, YEAH, YEAH, THAT'S A GOOD POINT. AND UH, GOLD STAR FOR YOU, WE, WE'VE TALKED ABOUT THAT. UM, AND I THINK WE'RE, WE'RE STILL THINKING THROUGH THAT INTERNALLY THAT THAT SITUATION. OKAY. AND THE SECOND CONTINGENCY THAT COULD ALSO BE A CONCERN IS LOSS OF LOAD. SO THAT'S A NEW CONTINGENCY THAT WAS ADDED PART OF BIGGER ONE 15. AND IF IT'S A DISPATCHABLE GENERATION, THEN BASED ON BIGGER 95, YOU HAVE TO MAKE SURE YOU CAN DISPATCH THAT GENERATION WITHOUT THE LOAD. RIGHT. THAT COULD TRIGGER MORE UPGRADES. THANK YOU. YEP. EXCELLENT. ANGELA CHEN? HEY, JUST A QUICK CLARIFICATION QUESTION. UM, UNDER, UH, PRIOR SLIDES I THINK HAVE INDICATED THAT IF YOU'RE NET METERED WITH INTERMITTENT GENERATION, EITHER BROWNFIELD OR GREENFIELD GEN, UM, RENEWABLES IN NO TRADITIONAL PUN SETTING, THERE ARE NO ADDITIONAL RULES. IT JUST GOES INTO BATCH ZERO AS ASSUMED TO BE FIRM. JUST WANNA CONFIRM THAT'S STILL THE CASE CONTEMPLATED HERE. YOU, UM, LET ME, UH, YOU, YOU'VE HAD ME UNTIL THE, UH, THE LAST PART ASSUMED TO BE FIRM. I, I THINK IT IS WHAT THERE ARE, UH, I THINK THE SHORTER VERSION OF JUST SAY THERE, THERE ARE NO SPECIAL ROLES FOR THOSE. IT WOULD BE WHATEVER THE ASSUMPTIONS ARE THAT THERE ARE NO SPECIAL WALLS FOR THAT. GOT IT. THANK YOU. ALRIGHT. AND AS WE KEEP WORKING THROUGH THE, UM, LEMME GIVE YOU A HOMEWORK ASSIGNMENT THAT'S GOING TO LAST 10 MINUTES. BE THINKING ABOUT WHAT QUESTIONS COULD WE ASK IN TERMS OF A SURVEY THAT WOULD HELP NARROW THIS DOWN. SO I'LL, I'LL ASK THAT QUESTION HERE AT UH, 4 28. ALRIGHT, THANK YOU. UM, LUKE HANSON, LUKE, ARE YOU ABLE TO HEAR US? 'CAUSE WE CAN'T HEAR YOU YET. ALRIGHT, MOVE ON TO HANES. THANKS. UH, QUICKLY, AND I THINK THIS IS JUST FOLLOWING UP WITH BREATH'S LAST QUESTION. SO THIS MAY BE A LITTLE REDUNDANT, BUT I JUST WANNA MAKE SURE I UNDERSTAND. SO THE WAY I'M VIEWING THIS, IF YOU'RE DEVELOPING AN ASSET AND WANT TO SUPPLEMENT YOUR OVERALL POWER UNTIL ERCOT CAN APPROVE AND TRANSMISSION CAN RELIABLY BE SERVED TO THE SITE, YOU'RE, YOU'RE GONNA MOST LIKELY BE IN THE SELF-LIMITING FACILITY CONFIGURATION WHERE YOU'RE AGREEING THAT YOU'RE ONLY GONNA TAKE THE AMOUNT OF CAPACITY THAT'S PROVIDED TO YOU IN ANY SUPPLEMENTAL NON INTERCONNECTED LOAD, MAYBE ACTING SYNCHRONOUSLY, BUT IT'S NOT, YOU'RE NOT SELLING THAT BACK INTO THE GRID OR INTERCONNECTING THAT BACK IN THE GRID. IT'S SOLELY SERVING AS SUPPLEMENTAL POWER FOR THE THE LOAD OFFTAKER. AM I UNDERSTANDING THAT IS HOW THAT CATEGORY WORKS CORRECTLY? I I THINK, UM, YES, TO THE EXTENT THAT YOU'RE, YOU'RE NOT SELLING THAT BACK CORRECT IN TERMS OF YOU'RE, YOU'RE NOT, YOU'RE NOT TALKING TO SCED, YOU'RE, YOU'RE NOT NOT GETTING A SCED DISPATCH SIGNAL. IT'S SOLELY FOR THE USE OF THE LOAD ON THAT SITE. YEAH. YEAH. I I THINK YOU UM, UH, POTENTIALLY YOU COULD HAVE SOME BILATERAL THAT ERCOT ISS NOT AWARE OF WHERE WE'RE, YOU KNOW, YOU GET A CALL AND YOU'RE MAKING THAT, YOU'RE, YOU'RE, YOU'RE NOT GONNA PULL THAT A HUNDRED MEGAWATTS ANYMORE. BUT I THINK THAT'S, THAT'S A SIDE DEAL THAT YOU'RE DOING THAT ER CUT'S NOT INVOLVED WITH THAT. OKAY. THAT, THAT, THAT'S HELPFUL. AND THEN I GUESS MY SECOND QUESTION, MORE TO WHAT BRAD WAS ASKING, IF THE GOAL IS TO ULTIMATELY BE ABLE TO INTERCONNECT THAT LOAD AS A GENERATION RESOURCE LATER DOWN THE LINE, IS THERE A WAY TO PHASE THIS? AND MAYBE THIS IS A SUBSEQUENT MEETING WHERE THAT'S THE SECOND STEP. YOU, YOU GET YOUR, YOUR GRID CAPACITY, BUT THERE'S A PATH WITHOUT HAVING TO GO THROUGH A BUNCH OF RESTUDIES TO ULTIMATELY INTERCONNECT INTO THE GRID. 'CAUSE I THINK WHAT'S GONNA HAPPEN IS YOU'RE GONNA BUILD ALL THESE GENERATION RESOURCES THAT ARE EXTREMELY VALUABLE AND WOULD BE HELPFUL TO HAVE ON THE GRID, BUT YOU'RE BUILDING THEM FOR YOURSELVES FIRST IN ORDER TO ENSURE THAT YOU HAVE CAPACITY FOR YOUR LOAD. BUT THEN THERE'S THIS GREAT ECONOMIC BENEFIT TO BOTH THE, THE END USERS WELL AS, AS WELL AS THE GRID LONG TERM AND TEXANS IF THOSE ASSETS ARE MADE MORE WIDELY AVAILABLE. I GUESS THAT'S, I THINK, AT LEAST FOR ME, THAT'S THE PATH YEAH. A LOT OF THE OPERATORS AND END USERS ARE LOOKING FOR. YEAH, I, I HEAR THAT. I I THINK, UM, CONCEPTUALLY AND UNLESS YOU ARE PHYSICALLY CHANGING THE CONNECTION, I, I I'LL SAY, UH, AND I'M LOOKING AT AGING TO PULL ME BACK IF I NEED TO, BUT I THINK CONCEPTUALLY, I, I THINK WE'RE OKAY WITH, OR I'M OKAY WITH THE IDEA THAT YOU'RE, YOU DON'T NEED TO GO THROUGH A DIFFERENT GENERATION INTERCONNECTION STUDY PROCESS, BUT THERE MAY BE, UH, WE, WE MAY NEED TO THINK ABOUT THAT DIFFERENTLY FROM A TRANSMISSION PLANNING PERSPECTIVE. UH, AND, AND I THINK WE NEED TO GO BACK AND TALK ABOUT THAT A A BIT MORE. OKAY. ALRIGHT. UH, CHRIS MOTTOS, UH, UM, BY AND LARGE, I THINK ONE THING IN PUN PLUS OR ANY OF THESE STRUCTURES IS BEING RESOURCE AGNOSTIC IN ALL OF THIS AND TRYING TO LEAN ON THEIR 87 SIXTIES [05:40:01] AND GENERATION PROFILES IS THEY'RE PUT OUT, I THINK WHILE I UNDERSTAND, YOU KNOW, ERCOT, SKEPTICISMS ON BATTERIES AS A CAPACITY RESOURCE, YOU KNOW, WHEN YOU CO-LOCATE THOSE WITH THERMAL GENERATION, IT DOES PROVIDE ADDITIONAL REDUNDANCY TO THAT AREA. WHEN YOU PUT IT WITH, YOU KNOW, COMPLEX, I'M GONNA CALL THEM COMPLEX GENERATION SITES, THEY ARE NOT, I THINK INHERENTLY THE SELF-LIMITING MODEL THAT IS NEATLY CAPTURED HERE OR THAT YOU'VE SORT OF CAPTURED HERE WHERE YOU'VE PUT EVERYTHING ELSE, YOU'VE JUST SORT OF SAID PUN PLUS IS THERMAL AND NOTHING ELSE IN, IN REALITY, YOU CAN OPERATE A COMPLEX SYSTEM THAT IS SUPPORTED BY THERMAL GENERATION AND I THINK THAT SHOULD PROBABLY BE RECOGNIZED IN THE PUN PLUS AND FLEXIBLE STRUCTURES. I DON'T HAVE OBVIOUSLY IMMEDIATE GUIDANCE BECAUSE Y'ALL ARE THE RELIABILITY ENTITIES ON THIS, BUT I THINK AT LEAST OPENING THAT UP TO WHAT AN 87 60 MODEL AND, AND ADDING SOME CRITERIA THAT WOULD SUPPORT, UM, MULTI RESOURCE CONFIGURATIONS WHICH PROVIDE THE GREATEST AMOUNT OF RELIABILITY WOULD BE BENEFICIAL FOR EVERYBODY. YEAH. AND, AND UM, ONE THING THAT WE ARE TALKING THROUGH IS IN THAT PUN PLUS, UH, COULD YOU HAVE, LET'S USE OUR EXAMPLE AGAIN, THE, THE THOUSAND MEGAWATTS OF GENERATION 5, 250 MEGAWATT GUESTS UNITS. COULD YOU ALSO HAVE A THOUSAND MEGAWATTS OF SOLAR, A THOUSAND MEGAWATTS OF BATTERY AT THAT SAME SITE? WHATEVER IT IS THAT YOU WANT. AND, AND THAT'D STILL BE PUN PLUS. UM, WE ARE LOOKING AT THAT AS IF CONCEPTUALLY AS LONG AS YOU HAVE AT LEAST THE 5, 2 50 IS IN THAT EXAMPLE, I, I THINK THAT THAT MAY BE OKAY, BUT WE, WE HAVE, WE HAVE TO TALK THROUGH THAT. UH, BUT I, I THINK LONG TERM, LIKE YES, THAT'S WHERE WE WANT TO GET TO IS, IS EVERYTHING THAT YOU DESCRIBED, WE WANT TO BE ABLE TO DO THAT. BUT, BUT THERE MAY BE SOME, UH, THERE ARE SOME COMPLEXITIES IN THE STUDY THAT WE JUST DON'T THINK WE CAN DO THAT IN THE NEXT TWO MONTHS TO, TO GET ALL THAT NAILED DOWN. AND, AND I THINK LIKE THAT IS THE ULTIMATE ULTRA CONSERVATIVE APPROACH. BUT, YOU KNOW, IF I'M ABLE TO, IN, IN THIS SCENARIO, RIGHT, LET'S TAKE AWAY JUST ONE OF THOSE TURBINES AND REALLY OVERSIZE THE WIND AND SOLAR COMPONENT AND COUPLE IT WITH LONG DURATION ENERGY STORAGE THAT YOU ACHIEVE THE SAME IF NOT BETTER FIRMNESS OF POWER IN THAT, IN THAT SCENARIO. BUT I HEAR YOU THAT TIME IS OF THE ESSENCE. YEP. VERY GOOD. UH, WE DON'T, LUKE, LUKE HANSON, LUKE HANSON, AGAIN, WE'LL TRY LUKE. CAN YOU HEAR US? SO, ALL RIGHT, SO HE PUT, HE PUT A QUESTION IN HERE. OH, I'M SORRY. LEMME READ LUKE'S QUESTION. UM, FOR SOME REASON THE GROUP DO EITHER A PUN PLUS OR B BATCH SELFING FACILITY ALLOW PARTIALLY FIRM AND PARTIALLY NON FIRM CAPACITY. FOR EXAMPLE, 500 MEGAWATT LOAD WITH A HUNDRED MEGAWATT OF FIRM BASE LOAD GRID POWER AND 400 MEGAWATTS OF NON FIRM. SO I GUESS THAT'S THE CASE WHERE ERCOT RUNS THE BATCH PROCESS. YOU CAN GET A HUNDRED MEGAWATTS OUT TO THAT SELF-LIMITING FACILITY, AND THEN THE 400 NON FIRM WOULD BE WAS WHAT THEY DISPATCHED FOR THEMSELVES. THAT'S THE DOTTED BOX. I, I, YEAH, I THINK FOR PUN PLUS, I, I THINK IT'S AS LONG AS YOU HAVE YOUR, YOUR G MINUS ONE, AS LONG AS YOU HAVE 500 MEGAWATTS, THEN YOU ARE GETTING 500 MEGAWATTS. AND SLFI THINK IN THIS EXAMPLE IS YOU ARE GETTING 100 MEGAWATTS AS YOUR, YOUR SLF LIMIT AND YOU MAY HAVE ADDITIONAL GENERATION, SO YOU CAN PUT 500 MEGAWATTS OF LOAD THERE. IT'S JUST, YOU CAN NEVER DRAW MORE THAN 100 MEGAWATTS. SO WHATEVER YOU'RE DOING, WHATEVER GENERATION THAT YOU'RE USING BEHIND THE METER, I, I THINK, UH, YOU KNOW, THAT'S, THAT'S UP TO YOU HOWEVER YOU WANT TO MEET THAT REQUIREMENT. ALL RIGHT, HOPE THAT HELPS LUKE, UH, BROTH. YEAH, TWO QUICK COMMENTS IN POND PLUS IT'S COMPLETELY BEHIND THE METER. SO WHY SHOULD EVEN APPROVE THIS, RIGHT? I CAN GO BUILD DATA CENTERS AND BRING IN GENERATION BEHIND, BEHIND THE METER AND RUN IT BECAUSE EVENTUALLY, AND I THINK OTHER DATA CENTER OPERATORS WILL AGREE, THE FACT THAT I'M INTERFACING WITH ERCOT IS BECAUSE I WANT FROM TRANSMISSION, I WANT, BECAUSE THAT'S GRID POWER IS THE MOST RELIABLE POWER, RIGHT? SO WE WOULD LIKE TO GET TRANSMISSION AT SOME POINT AND HENCE WE ARE INTERACTING WITH OUR CAR, BRINGING THIS GENERATION AND MATCHING WITH THE LOAD. SO YEAH, THAT'S WHAT I WANTED TO KIND OF CONVEY SO THAT EVENTUALLY WE HAVE TO STUDY FOR LOAD TO BE SERVED WITH FIRM TRANSMISSION AT YEAR FIVE [05:45:01] OR YEAR SIX. IT, I WOULD SAY, BUT WE'RE NOT GOING TO IGNORE THAT THAT GENERATION IS THERE. SO, SO THAT, THAT GENERATION WHEN WE'RE PLANNING THE TRANSMISSION SYSTEM, WE'RE, WE'RE GOING TO ASSUME THAT THAT GENERATION IS THERE. SURE, THAT'S FINE. AND WE CAN, AS I SAID, I THINK THERE ARE DIFFERENT COMMERCIAL ASPECTS WE CAN LOOK INTO HOW THE GENERATION CAN INTERACT WITH THE GRID, BUT YEAH, I DON'T SEE A USE CASE FOR PUN PLUS TO BE JUST IN THIS CONFIGURATION AND SOMEBODY IS RUNNING THIS AT ALL, LIKE THROUGHOUT ITS USEFUL LIFE IS WHAT I'M TRYING TO GET, THAT'S ALL. OKAY. ALL RIGHT. NEXT QUESTION. UH, BERNARDO? YES, BERNARDO FROM SERNA. UM, IT'S RELATED TO THE UH, LAST COMMENTS. IT SEEMS TO ME THAT WE WANT TO SOLVE TWO, TWO PROBLEMS HERE. PROBLEM NUMBER ONE IS TIME TO MAR TYPE TO MARKET PROBLEM NUMBER TWO IS HOW WE CAN REDUCE TRANSMISSION COSTS AND THERE IS A BONUS, WHICH IS HOW WE CAN PROMOTE RESOURCE ADVOCACY. ALSO IN THIS PROCESS. IT SEEMS TO ME THAT CLR WE ARE SOLVING MORE A TIME TO MARKET PROBLEM SINCE WE ARE NOT, UH, CONSIDERING THAT WE'LL HAVE CLR FOR THE USER FOR LIFE OF THE DATA CENTER. SO WE'LL NEED TO BRING A NEW TRANSMISSION. UH, PLEASE CONFIRM TO ME THAT IN THE CASE OF PLUM PLUS AND SELF-LIMITING THAT WE ARE IN, IN THE END OF THE DAY, UH, REDUCING TRANSMISSION REINFORCEMENTS OR THIS WILL ALSO BE ONLY A TIME TO MARKET SOLUTION. THIS WAS NOT, UH, HUNDRED PERCENT CLEAR TO ME. AND THE BONUS IS HOW WE INCENTIVIZE THAT PUMP PLUS AND SELF-LIMITING AT THE END OF THE DAY WILL BE A PROCEDURE THAT WILL BRING A NEW GENERATION AND WILL NOT BE ONLY A TIME TO MARKET PROCESS AND WILL NOT HAVE THIS, UH, AVAILABLE CAPACITY AFTER THE YEAR FIVE. YEAH. UM, I'M NOT SURE I COMPLETELY GOT ALL THAT, BUT I, I, I THINK THE ANSWER IS, UM, I THINK IT IS THE, THE BENEFITS ARE BOTH, IT IS UH, TIME TO MARKET BECAUSE IF YOU ARE BRINGING YOUR OWN GENERATION, THEN YOU, YOU DON'T HAVE TO WAIT FOR TRANSMISSION UPGRADES. YOU, YOU CAN CONNECT AND START CONSUMING AS SOON AS THAT GENERATION IS THERE. UH, AND I THINK IT IS POTENTIALLY BE BECAUSE THAT GENERATION IS THERE, POTENTIALLY WE NEED TO BUILD LESS TRANSMISSION AS OPPOSED TO IF THERE WAS SOME OTHER GENERATOR 200 MILES AWAY THAT WAS SERVING THAT LOAD, THEN, THEN, YOU KNOW, CONCEPTUALLY YOU NEED TO BUILD TRANSMISSION BETWEEN THAT GENERATOR AND THAT LOAD. BUT IF THAT GENERATION IS RIGHT THERE SERVING THE LOAD, THEN I, I, I THINK THERE IS SOME BENEFITS TO THE SYSTEM AND HAVING THAT GENERATION THERE. SO IN THE CASE OF PUMP PLUS AND SELF-LIMITING, UH, NO NEW TRANSMISSION BE BUILT AND ORDER FOR, FOR ME, IF I DO NOT WANT TO HAVE, IF, IF I WANT TO PUSH AN ENERGY FROM THE GRID AFTER YEAR FIVE, I, I, I THINK IT'S UM, UH, YOU CAN'T SAY THAT THERE WOULD NOT BE ANY NEW TRANSMISSION. IT, IT MAY BE THAT IT'S, UH, MAYBE NOT FROM A RELIABILITY PUN, PUN PLUS IS PROBABLY EASIER ONE TO, TO ILLUSTRATE. BUT IT'S FROM A RELIABILITY PERSPECTIVE BECAUSE YOU HAVE ENOUGH GENERATION, YOUR G MINUS ONE ABLE TO SERVE THAT LOAD, THEN YOU, YOU PROBABLY DON'T NEED TRANSMISSION FROM A RELIABILITY STANDPOINT. BUT YOU MAY, IF THAT AREA IS CONSTRAINED, THAT GENERATION MAY NOT BE ECONOMICS RUN ALL THE TIME. SO THAT, THAT MAY INTRODUCE SOME ECONOMIC TRANSMISSION UPGRADES THAT THAT WOULD BE NECESSARY. OKAY. AND LAST QUESTION WILL BE, WILL BE, UM, THE ALTERNATIVE OF NOT USING THE, THE PUMP PLUS IN SELF LIMIT INFORMATION BEFOREHAND AND AFTER THE LOCATION. I CAN USE PUMP PLUS AND SELF-LIMITING BASED ON MY LOCATION. SO TRANSMISSION WILL BE, UH, CONSTRUCTED FOR, FOR ME AFTER YEAR FIVE. UH, BUT DURING THIS TIME I WILL USE OR PUMP PLUS OR SELF-LIMITING. YEAH, I THINK SELF-LIMITING, I THINK WE NEED TO DISCUSS THAT A LITTLE BIT MORE IN INTERNALLY. UH, I THINK PUN PLUS IS WE'RE GOING TO FOLLOW THE TRANSMISSION PLANNING CRITERIA, UM, AS LAID OUT IN TPL STANDARD AND PLANNING GUIDE SECTION FOUR, WE, WE, WE'LL FOLLOW THAT CRITERIA AND WHATEVER THAT IS DETERMINED NEEDS TO BE CONSTRUCTED FOR THAT, THAT THAT'S WHAT WILL WILL FOLLOW. OKAY, THANK YOU. [05:50:01] ALRIGHT. AND THEN ON LUKE'S QUESTION, IT LOOKS LIKE MONICA IS GONNA READ IT FOR US. YEP. I, I CAN TAKE THE REINS FOR FROM LUKE. UM, SO SPECIFICALLY IN THE PUN PLUS FRAMEWORK, IF YOU HAVE A 500 MEGAWATT LOAD AND 400 MEGAWATTS OF GEN, UM, COULD YOU HAVE A HUNDRED MEGAWATTS OF FIRM POWER AND THEN 400 MEGAWATTS OF PUN PLUS, IF THAT MAKES SENSE ESSENTIALLY. YEAH. THERE STILL WOULD NOT BE ENOUGH THAT THAT WOULD NOT QUALIFY FOR PUN PLUS. 'CAUSE YOU, YOU DON'T HAVE ENOUGH GENERATION SUCH THAT YOU'RE A G ONE, UH, YOU'RE, YOU KNOW, HAVE AT LEAST G MINUS ONE OF YOUR LOAD. BUT IS THERE A SITUATION WHERE YOU COULD HAVE A SORT OF NON FIRM PORTION OF YOUR LOAD ACT AS A-C-L-R-I? I THINK NOT BEHIND THE SAME POI YOU, YOU COULD SPLIT IT INTO MULTIPLE POIS IF YOU WANT SOME, SOME OF THAT LOAD JUST TO BE A STANDALONE LOAD AND SOME OF IT TO BE CO-LOCATED. MM-HMM . I THINK THAT'S, THAT THAT WOULD BE A POSSIBILITY. BUT I, I THINK THAT WOULD HAVE TO BE DIFFERENT POIS FOR THAT. YEAH, I THINK WE'D HAVE TO DISCUSS THEM MORE. I THINK IT MAY BE POSSIBLE, BUT UM, YOU KNOW, I THINK AS A, A GENERAL COMMENT HERE YEAH, THAT SOME OF THE, THE DISCUSSION THAT IS BEING HAD IS INTRODUCING GREATER AND GREATER AND GREATER LEVELS OF COMPLEXITY INTO THIS AND AT, AT SOME POINT WE HAVE TO FOCUS ON WHAT IS ACHIEVABLE FOR BATCH ZERO AS WELL. SO JUST WANT TO KIND OF ADD THAT AS A COMMENT. OKAY, THANK YOU. ALRIGHT. UH, JOEL DAVIS? YEAH, JUST A QUICK ONE, UM, JUST CONFIRMING THAT NOTHING HERE WOULD PREVENT AN ENTITY FROM DOING A SEPARATE INMR FOR SOME SORT OF RENEWABLE RESOURCE BEHIND THAT POI. CORRECT. SO IN OTHER WORDS, YEAH, IT WOULD JUST FALL UNDER THE BUSINESS AS USUAL SEPARATE. YEAH. IF YOU DO IT WELL, I'M SAYING IF YOU HAVE A PUN PLUS THAT YOU'RE DOING THROUGH THE BATCH PROCESS AND YOU DO A SEPARATE I AND RFIS FOR A RENEWABLE OR AN ESR BACK THERE, OBVIOUSLY THAT'S ALL GONNA KIND OF GET STUDIED TOGETHER IN THE FIS FOR THAT SEPARATE INR BUT IT WON'T AFFECT YOUR, YOUR BATCH POSITION. CORRECT. AND THEN KIND OF POINTING BACK TO WHAT MONICA WAS ASKING, SO LET'S SAY YOU COME OUT OF BATCH ZERO WITH AN IFICATION OF 400 OR 500 MEGAWATTS AND YOU REALLY WANTED A THOUSAND. SO IF YOU BUILD 600 MEGAWATT UNITS NOW YOUR G MINUS ONE SECURE AGAINST WHAT WAS NON FIRM IN THE BATCH, THAT'S NOT GONNA BE ALLOWED OR IS THAT'S THE QUESTION JOEL. JUST TO CLARIFY, IS THE QUESTION REALLY, DO YOU HAVE TO DEFINE THE ENTIRETY OF PUMP PLUS BEFORE THE BATCH STARTS OR YES, THE ANSWER YES IS YES. 'CAUSE WE'LL NEED TO STUDY THE GENERATION AS PART OF, UH, WE NEED TO HAVE THAT GENERATION IN THE CASES AND REPRESENTED. UM, SO YOU WON'T BE ALLOWED LIKE DURING REFINEMENT TO SAY, OH, I ONLY GOT 400 MEGAWATTS, LET ME SLAP SIX, 600 MEGAWATTS OF GIN ON THIS TO GET UP TO WHAT I ACTUALLY WANTED. CORRECT. NOT AS WE'RE, WE'RE CURRENTLY CONTEMPLATING IT. OKAY. JUST CLARIFYING. THANK YOU. ALL RIGHT. AND LAST QUESTION OF THE DAY, MONICA, I ALREADY ASKED MY QUESTION. THANK YOU. BONUS FRY. OKAY, WELL THANK YOU ALL EVERYBODY WE MADE IT. UM, SO MY HOMEWORK QUESTION WAS ARE THERE QUESTION AND WE'RE GONNA MEET AGAIN IN SIX DAYS SO WE CAN MAYBE WE CAN ASK SMARTER QUESTIONS SIX DAYS FROM NOW, BUT IS THERE SOMETHING THAT WE SHOULD BE ASKING? FOR EXAMPLE, ERCOT, I, I KNOW THERE'S SOME UNSETTLEMENT AROUND, THERE'S A LOT OF DETAILS BEHIND PUN PLUS AND SELF-LIMITING. WE STARTED SELF-LIMITING. IT'S A SMALL LITTLE BOX, EVERYONE STAYS IN IT PUN STRETCHES US INTO SOME AREAS. METERING STARTS TO GET, YOU KNOW, DIFFERENT THE COMPLEXITY START TO LAYER IN. IF WE CAN ONLY GET ONE OF THESE, WHICH ONE SHOULD WE NAIL DOWN FOR BATCH ZERO IS ALMOST THE QUESTION I WANT TO ASK, BUT I DON'T KNOW IF THAT'S THE RIGHT QUESTION. IF CAN ONLY ONLY HAS THE, 'CAUSE WE'RE TALKING ABOUT DAYS TO GET THIS TURNED AROUND. IS THERE, IS THERE A STRAW POLE IN THE ROOM THAT I COULD SAY RAISE YOUR HAND IF SELF-LIMITING WORKS OR WOULD YOU PREFER SELF-LIMITING OR WOULD YOU PREFER PUN? SO LET'S GO PUN FIRST. RAISE YOUR HAND THE PUN. PLUS I THINK EVENTUALLY WE WANT BRING YOUR OWN GENERATION FIRM TRANSMISSION COMING. OKAY. THAT'S HOW I SEE IT. FIRM TRANS. OKAY, WELL TRANSMISSION PROJECT SELF-LIMITING WITH A PROJECT TO FOLLOW AND THEN RELEASED SELF-LIMITING BECAUSE IT'S SELF-LIMITING THAT EVENTUALLY IS [05:55:01] NO LONGER SELF-LIMITING. YES. IS WHAT THAT WOULD LOOK LIKE. OKAY. OKAY. WELL LET US GO. MAYBE LET'S, LET'S DEFER THE QUESTION FOR SIX MORE DAYS. T I'LL KIND RUN THIS DOWN ANOTHER LEVEL AND THEN MAYBE WE'LL HAVE SOME QUESTIONS. LET'S TALK ABOUT THE EXITING AND OTHER PIECES LIKE THAT. UM, OKAY. IS THERE ANYTHING, SO I'M WITHDRAWING THAT OFFER FOR A SURVEY RIGHT NOW OR I'S GONNA CHEW ON A BUNCH OF COMMENTS AND TRY TO BRING THAT BACK SIX DAYS FROM NOW. WE'RE GONNA CHEW ON THE B-A-Y-O-G AND BRING THAT BACK SIX DAYS FROM NOW AND WE HAVE MORE THAN ENOUGH TO SAY GRACE OVER. UM, IS THERE ANYTHING ELSE I SHOULD BE AWARE OF FROM THE MARKET STAKEHOLDERS HERE? ALRIGHT, WELL THANK YOU. I WILL SHOW YOU YOUR SUGGESTIONS ARE WHAT KIND OF BROUGHT SOME OF THESE NEW IDEAS TO THE TABLE. AND UH, OTHERWISE WE NOW STAND ADJOURNED AND WE WILL MEET AGAIN NEXT MONDAY. THANK YOU VERY MUCH. * This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting.