* This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting. [00:00:02] HEY, MATT. UM, WHILE, WHILE WE'RE, WHILE YOU'RE PULLING THAT UP, YOU KEEP GOING. UM, SO, UH, I HAD A REQUEST THAT I WANTED TO HONOR, UM, THOSE THAT, UM, UH, WERE AROUND BACK WHEN I USED TO, UH, RUN THE RPG MEETINGS, UH, KNOW THAT I USED TO, UH, I HAD THIS TRADITION, I WOULD START THE RPG MEETING WITH A DAD JOKE. I HAVE FIVE KIDS. AND, UM, SO I HAD A REQUEST TO BRING THAT BACK, UH, FOR THE WORKSHOP. SO, ALRIGHT, SO HERE IT GOES. SO, YOU KNOW, MANY OF YOU KNOW, SO MY WIFE AND I, EVERY MORNING, UH, WE, WE GO AND WE WALK, UH, DO A LITTLE WALK IN THE NEIGHBORHOOD, BUT HERE RECENTLY THERE HAS BEEN A, A BICYCLE THAT RUNS US OVER EVERY SINGLE MORNING. IT, IT IS SUCH A VICIOUS CYCLE. NOW, NEXT, UH, WELL PLAYED, SIR. THANK YOU. AND YOU SAY THAT FOR THE LAST WORKSHOP, MAN. WHERE HAVE YOU BEEN, BRO? ALRIGHT, WELL, GOOD MORNING. MY NAME'S MATT MARIA, IT'S A PLEASURE TO BE HERE. UM, ON BEHALF OF THE TEAM, WE WELCOME YOU. I, I WILL SAY I HAVE SEEN THIS TEAM, UH, PEOPLE WHEN WE GET TO TACK, THEY'RE LIKE, HEY, GOOD JOB, ERCOT. I JUST WANNA PUT NAMES WITH IT. JEFF BILLOW, AG SPRINGER, CHRISTINA SWITZER AND EVAN ROWE HAVE BEEN WORKING DAYS AND NIGHTS, UM, SACRIFICING A LOT, EVEN OVER EASTER WEEKEND TO GET STUFF DONE. SO I JUST WANTED TO ACKNOWLEDGE THE WORK THAT THEY'VE DONE AND, UH, WITHOUT THEM THIS WOULD BE NOWHERE. SO, UM, SO AS WE GET SET UP THIS MORNING, YEAH, THANK YOU. HERE, HERE. UM, [1. Antitrust Admonition] SO LEMME JUST START WITH OUR USUAL ANTITRUST ADMONITION, AND THEN I'LL START TO PIECE TOGETHER WHAT TODAY LOOKS LIKE. UH, JUST REMINDER TO AVOID RAISING CONCERNS ABOUT THE ANTITRUST LIABILITY, WE HAVE THE ADMONITION ON THE SCREEN THAT I'LL LET YOU READ FOR 10 SECONDS. ALL RIGHT. THANK YOU FOR YOUR ATTENTION TO THAT. [2. Timeline and Governance Recap (10 mins)] AND SO, THE WAY WE'RE GONNA WALK THROUGH TODAY, UH, I'LL GIVE THE USUAL RECAP OF WHERE WE'RE HEADED AND HOW WE'RE GETTING THERE. UH, THE NEXT PIECE WILL BE REVIEWING THE REVISION LANGUAGE FOR CONTROLLABLE LOAD RESOURCES WE HAVE BEEN TALKING ABOUT AND AG HAS BROUGHT FORWARD, BROUGHT FORWARD. IF SOMEONE IN THE ROOM IS WATCHING ON THE WEBEX, JUST MAKE SURE YOU MUTE THAT WAY AND I'LL SEE IF I CAN FIND IT. AND FOR THOSE OF YOU THAT ARE JOINING ONLINE, UH, YEAH, BY DEFAULT YOU'RE MUTED. BUT THEN USE THE WEBEX CHAT FEATURE TO GET INTO THE QUEUE FOR QUESTIONS. OKAY. SO I'LL COVER THE, A RECAP OF WHERE WE'RE AT IN GETTING TO THE PROCESS. AG WILL PROBABLY SPEND ABOUT AN HOUR AND A HALF WALKING THROUGH THE CLR. IT WAS JUST POSTED THIS MORNING. IT IS A LOT. SO IN A WORKSHOP, SPIRIT OF WORKSHOP, IT IS A WALKING THROUGH, HOW IT WAS DONE, WHY IT WAS DONE, AND HOW IT ALL FITS TOGETHER. AND I'M TRYING TO MULTITASK AND SEE WHERE THE ECHO IS COMING FROM. ALRIGHT, RIGHT. UM, THEN WE'LL TALK ABOUT THE BYOG. THIS IS THE CONCEPT OF BRING YOUR OWN GENERATION. I'LL REMIND KIND OF THE PILLARS OF WHY WE'RE DOING WHAT WE'RE DOING. WE ARE NOT THERE YET. WE'RE GONNA PIVOT FROM THE HEAVY LIFT FROM CLR INTO OUR OPERATIONS AND COMPLIANCE GROUP TO GET THE BYOG. OUR HOPE IS TO GET IT TO THE, UH, PRS AND ROS MEETINGS LATER THIS MONTH. UM, THE APRIL 22ND AND 23RD. SO THAT'LL BE A BRIEF DISCUSSION BECAUSE WE DON'T HAVE A LOT MORE INFORMATION TO SHARE. THEN WE'RE GONNA DO THE DEEP DIVE ON THE ERCOT COMMENT. SO AGI WILL PRESENT A SUMMARY OF KIND OF WHAT CAME IN, WHAT CHANGED, UH, THEN HE'LL OPEN UP THE COMMENTS FORMS THEMSELVES TO KIND OF WALK THROUGH HOW THINGS WERE MODIFIED. AND THEN AGAIN, AS WE'VE DONE IN PREVIOUS WORKSHOPS, I'LL MAKE SPACE FOR THE STAKEHOLDERS THAT FILED COMMENTS. AND WE HAVE A LIST OF THEM GET FIRST CRACK AT THE MICROPHONE TO SHARE FOR FIVE TO SEVEN MINUTES AND WALK THROUGH THEIR COMMENTS OF THE WISES AND WHAT, SO, UM, THAT'S AN OPTION, NOT AN OBLIGATION FROM THE COMMENTERS AT THAT POINT. AND IF YOU REMEMBER THE LAST MEETING, WE KIND OF WENT OFF THE PLAYBOOK AND SAID, HEY, WHO ELSE BESIDES ERCOT WANTS TO TALK ABOUT PUC PROJECT 5 8 4 8 1, AND TO START TO STITCH TOGETHER A SUMMARY OF THE LOGIC OF THE MONEY FLOW OR HOW THINGS FIT TOGETHER. UH, SO BROTH WAS KIND ENOUGH TO VOLUNTEER FOR THAT. UH, HE HAS PROVIDED A PRESENTATION WHICH WAS ALSO JUST POSTED, AND THAT WILL BE SOMETHING TO WALK THROUGH. AND AGAIN, JUST TO SET THE TONE FOR THE MEETING IS WE'RE GOING THROUGH ERCOT COMMENTS. IF WE CONTINUE TO GET STUCK ON 5 8 4 1 RELATED ELIGIBILITY, WE'RE GONNA DEFER THAT TO THE END OF THE MEETING TO BE, YOU KNOW, KIND OF THE CATCHALL FOR THAT 5 8 4 8 1. ALSO RECOGNIZING WE MAY RECEIVE GUIDANCE FROM THE PUC NEXT WEEK ON APRIL 17TH WITH REGARDS TO THOSE PARAMETERS. SO AGAIN, I KNOW BARKSDALE'S NOT HERE TODAY, HE'S DOWN AT THE LEDGE A ALONG WITH A LOT OF OUR BOSSES. AND, UH, BUT THAT IS BEING SHAPED BY THE PUC AND COMMENTS IN THROUGH THAT ROUTE. SO JUST A REMINDER OF HOW THAT ALL WORKS. AND THE OVER UNDER ON ADJOURNMENT IS FOUR 30. AND [00:05:01] WITH THAT, IS THERE ANY OTHER BUSINESS I SHOULD BE CONSIDERING FOR TODAY? ALRIGHT, HEARING [3. Review Revision Language for CLR] NONE, LET ME OPEN OUR FIRST DECK OF SLIDES. THIS IS VERSION TWO. SO IF YOU DOWNLOADED IT 30 MINUTES AGO, IT HAS CHANGED AND I FLAGGED WHAT'S CHANGED IN THE SLIDES. ALRIGHT, SO WE HAD INCREMENTAL CHANGES TO SLIDE NINE THROUGH 11. AND THEN, OH MY GOSH, MATT, UH, UPDATED STAKEHOLDER COMMENT, SLIDE 42 THAT JUST, SORRY, IT'S, YOU'LL SEE IT IN A MINUTE. WE ADDED RA TO A SLIDE. HOW'S THAT? THAT'S FOR YOU, NED. OKAY, SO IN TERMS OF THE AGENDA, I WALKED THROUGH IT ALREADY OF WHERE WE'RE HEADED IN TERMS OF THE TIMELINE AND GOVERNANCE RECAP. THIS IS OUR MARCH TO THE FINISH. UH, I LIKE BILL BARNES MARCH MADNESS ANALOGY, BUT IT SURE FEELS LIKE IT'S GONNA EXTEND INTO APRIL AND MAY. UM, WE'VE MADE THE DOTS RED, THIS IS OUR LAST WORKSHOP, AND YOU'RE LIKE, WELL, HOW DO WE TALK ABOUT THIS? WELL, HERE'S THE FUNNY PART. WE'RE GONNA HAVE REGULAR AND SPECIAL MEETINGS AS NEEDED WITH PRS AND ROS, THOSE LEADERSHIP TEAMS, SOME ARE REPRESENTED IN THE ROOM, THEY ARE ALSO AGILE IN A WAY OF KNOWING IF THEY NEED TO DO MORE, THEY'RE WILLING TO, UM, TAC IS WILLING TO DO MORE IF MORE RED DOTS ARE NEEDED ON THIS. THIS IS CREATING TWO WEEK MEETINGS IN SOME CASES. SO I DON'T KNOW HOW MUCH MORE WE CAN TALK ABOUT THIS STUFF. I WOULD ALSO ENCOURAGE, EVEN IF IT'S THE NPRR AT PRS, WE ALSO KNOW THE RELATED ISSUES TIED TO THE PIGGER ARE PART OF THAT. BUT, UM, WHAT WE ARE SEEING IS, AND YOU'LL SEE TODAY, THE VERY SHORT NPRR FOR NPR 1325 IS NOW LONG BECAUSE IT'S GONNA HAVE THE CLR COMMENTS BAKED INTO IT WHEN WE RELEASE THAT VERSION NEXT WEEK. AND SO, AGAIN, WE HAVE A SPECIAL PRS MEETING AND ROS MEETING NEXT WEEK. I'M SORRY, REGULAR PRS AND A SPECIAL ROS MEETING NEXT WEEK. SO ERCOT IS CONSIDERING THE FOCUS OF THOSE MEETINGS ON THE 14TH AND THE 15TH, AS MUCH EDUCATIONAL AS ANYTHING ELSE. UH, I, I WENT TO ROS LAST WEEK AND THERE ARE A LOT OF FOUNDATIONAL QUESTIONS ABOUT HOW THIS STUFF WORKS. UH, JEFF'S BEEN WORKING ON A, UM, EDUCATIONAL SLIDE DECK FOR POLICY MAKERS MANAGEMENT, WHOEVER NEEDS IT. WE WILL PURPOSELY GO THROUGH THE WHAT IS BATCH AND EDUCATE PEOPLE AND SPEND AN HOUR AND A HALF ON THAT IN THESE FORUMS TO RESET. NOT EVERYONE'S BEEN IN SEVEN SETS OF MEETINGS AND DONE THEIR 56 HOURS LIKE WE HAVE. THEY'RE, THEY'RE GONNA TAKE AN HOUR AND A HALF TO TRY AND IMPART WHY AND WHAT WE'RE DOING, AND THEN TO HIGHLIGHT WHAT THE KEY ISSUES ARE. NOW, WE'LL STILL HAVE THE RIGHT OF THOSE MEETINGS TO OPEN THEM UP AND START TO WALK THROUGH, BUT WE'RE NOT EXPECTING ANY VOTES NEXT WEEK. WE'RE ALSO BRINGING, YOU KNOW, AGAIN, CLR, WE'LL START TO HIT THE STREETS AT THAT POINT. UH, AND AGAIN, THIS IS KIND OF OUR ROAD TO THE FINISH AND I SEE THERE'S A COMMENT OR A QUESTION IN THE QUBIT. LET ME GET THROUGH THIS HOW WE'RE DOING THIS MOMENT AND THEN WE'LL COME BACK TO QUESTIONS. UM, A COMMON QUESTION I'VE BEEN GETTING IS I HAVE THE COMMENTS FORM, WHERE DO I SEND IT TO? REVISION REQUEST@ERCOT.COM IS HOW YOU FILE YOUR COMMENT TO THE PIGGER OR THE NPR COMMENTS. UM, I DID NOT ADD THIS TODAY, BUT YOU MAY WANT TO BECOME FAMILIAR WITH WHO ARE THE SEATED MEMBERS OF ROS. IF YOU GO TO THE ROS HOMEPAGE, UM, AS YOU GO INTO MARKETS AND OPEN THAT, YOU'LL SEE WHICH COMPANIES HAVE WHICH SEGMENTS FOR VOTING AT ROS AND PRS. AND THAT STARTS TO BECOME THE AUDIENCE FOR PASSAGE THROUGH, BECAUSE WE'RE ALL WORKING HARD TO GET THIS DONE, WHO'S GOING TO GATE IT TO THE NEXT ONE? THOSE ARE THE TWO FORUMS THAT WILL SO JUST BECOME FAMILIAR WITH THOSE GROUPS IF YOU'RE NOT ALREADY FAMILIAR. UH, IN TERMS OF THE PUC ACTIVITY, AGAIN, THERE'S A DEEPER DIVE PLANNED ON JUST KIND OF A LITTLE SUMMARY BELOW OF HOW 5 8 4 8 1 HAS FRAMED OUT THESE ELIGIBILITY CRITERIA AS IT APPLIES TO BATCH ZERO. AND THEN HERE'S WHERE I WANTED TO KIND OF UNPACK SOME NEW INFORMATION. UH, SO AGAIN, WE FILED BATCH ZERO IN PIGGER 1 45 AND 1325. ERCOT THEN FILED COMMENTS TO CHANGES. AND THEN ON APRIL 4TH, UH, WAS THE BIG DROP OF ALL OF YOUR COMMENTS, TOOK ALL Y'ALL'S INPUT, WENT THROUGH AND SAID, FOR THIS SUGGESTION, HERE'S WHY WE AGREE WITH IT, WHY WE DISAGREE WITH IT, AND HOW WE'VE CHANGED LANGUAGE. UH, THAT WAS A HEAVY LIFT, WE'RE PROBABLY NOT GONNA KEEP DOING THAT. THAT WAS MORE OF A ONE TIME CATCH UP THE ENTIRE FORM AND GET IT MEMORIALIZED TO REMEMBER , SOMEBODY SAID IT EARLIER, TWO YEARS FROM NOW, WHEN WE GO BACK AND SAY WHY, THAT'LL BE A GREAT ARTIFACT TO REMIND OURSELVES OF WHY THE DECISIONS WERE MADE THE WAY THAT THEY WERE. SO HERE'S WHERE I WANNA SLOW DOWN A LITTLE BIT. WE'VE BEEN CALLING THIS ADDITIONAL NRR FOR, UM, CONTROLLABLE LOAD RESOURCES OR BYOG. JUST A REMINDER, OUR MANDATE FROM THE PUC WAS TO DEVELOP THE REVISIONS NECESSARY FOR BATCH ZERO. THAT IS FIRST IN PRIORITY ONE. THAT IS THIS TOP BULLET. [00:10:01] AND THAT IS WE CANNOT FAIL AT THAT MISSION FOR THE JUNE 1ST BOARD. THEN THERE'S THE IDEA OF GUIDANCE WAS TO ALSO WORK AS HARD AS YOU CAN, AS EFFECTIVELY AS YOU CAN TO GET CONTROLLABLE LOAD RESOURCES AND BRING YOUR OWN GEN CONSTRUCTS IN ADDITION TO BATCH ZERO. RATHER THAN HAVE A SEPARATE THREAD OF REVISION REQUESTS FOR THOSE DIFFERENT PIECES, WE'RE GONNA BE USING THOSE WHERE YOU, WE FILE COMMENTS TO BIGGER 1 45 AND 1325 TO FOLD IN THAT SCOPE. NOW, YOU MAY BE SAYING, WELL, HOW IS THE BOARD GONNA BE ABLE TO VOTE ON SOMETHING IF WE'RE STUCK ON CLR? WELL, THEY'RE GONNA BE ABLE TO, AND THIS COULD BE TAC, THIS COULD BE PRS, THIS COULD BE ANYWHERE THAT YOU MAKE A MOTION ON A VERSION OF COMMENTS. SO, CORY PHILLIPS, OUR MASTER OF MARKET RULES IS GONNA HELP US REMEMBER AND MANAGE AS WE UPDATE BATCH ZERO, THAT THAT PERCOLATES THROUGH A SET OF COMMENTS THAT CAN AND WILL INCLUDE BYOG AND CLR. SO ANYTIME WE GO TO VOTE ON SOMETHING, THAT VERSION OF COMMENTS WILL REFLECT JUST BATCH ZERO OR BATCH ZERO PLUS CLR OR BATCH ZERO AND BYOG, ANY COMBINATION OF THOSE. SO THAT HEADACHE IS GONNA BE TAKEN CARE OF. AND THEN COREY WAS ALSO REMINDED ME THAT BASED ON EDITS AND COMMENTS, YOU CAN FILTER ON THOSE. SO YOU CAN SEE JUST THE CLR STUFF VERSUS THE OTHER STUFF. AND SO, AGAIN, WE CAN BRING, WE CAN BRING CORY UP HERE TO EXPLAIN HOW IT ALL WORKS OR YOU CAN TRUST HIM TO SAY, ERCOT MARKET RULES WILL HELP MANAGE THE PROCESS. SO THERE IS A LINE OF SIGHT TO THE LANGUAGE BASED ON SCOPE AND A LINE OF SIGHT TO, AS YOU'RE VOTING ON COMMENTS, WHAT'S CONTAINED IN THAT SET OF COMMENTS AND HOW THOSE MOVE FORWARD. AGAIN, IF WE GET STUCK ON BYOG AND IT'S THE DAY BEFORE ATTACK, THERE MAY BE A SET OF COMMENTS FILED BY ERCOT THAT IS JUST ZERO PLUS CLR, AND THAT'S HOW THEN MOTION CAN CARRY FORWARD ON THAT. SO WITH THAT, I'LL, I'LL PAUSE AND SEE IF THERE'S ANY QUESTIONS. AND IS THERE, I DON'T HAVE MY QUEUE UP YET. UH, HEY. HEY MATT, JUST REAL QUICK. YES. UM, GO BACK TO ROS UM, JUST WANTED TO NOTE FOR EVERYONE THAT ROS NEXT TUESDAY IS WEBEX ONLY. UH, SO WE'LL NOT BE MEETING IN PERSON HERE, SO, SO DON'T, DON'T SHOW UP OR YOU'LL BE BY YOURSELF. YES, WE'RE ALL TALKING ABOUT THAT. AND SANDEEP AND I TRIED AS HARD AS WE COULD TO FIND A ROOM, BUT WE COULD NOT, SO ONLINE IT IS. ALRIGHT, CAN SOMEONE HELP ME WITH THE QUEUE WHILE I'M GETTING THE CHAT BOX SET UP HERE? UH, CHRISTIE? YES, GO AHEAD. GOOD MORNING, MATT. UM, JUST A QUICK NOTE ABOUT THE SCHEDULE NEXT WEEK. UM, THE SPECIAL ROS MEETING WAS SCHEDULED OVER RMS. YES. AND I GET THAT THERE'S NOT A LOT OF BLEEDING OVER IN THE PEOPLE THAT ATTEND THOSE TWO MEETINGS, BUT TO HAVE A VOTING SUBCOMMITTEE SCHEDULED ON THE SAME DAY AT THE EXACT SAME TIME AS ANOTHER VOTING SUBCOMMITTEE WAS, IT'S, IT'S, UH, IT'S UNTENABLE FOR SOME, UM, THERE ARE THREE MEETINGS SCHEDULED ON MONDAY ALREADY THAT I THINK EVERYONE'S TRYING TO JUGGLE THE C-M-W-G-P-L-W-G AND RPG, BUT TO HAVE TWO VOTING SUBCOMMITTEES SCHEDULED AT THE SAME TIME ON THE SAME DAY, UM, MEANS SOMETHING HAS TO GIVE UNFORTUNATELY. UM, SO I WOULD JUST IMPLORE ERCOT AS YOU MOVE FORWARD ON SOME OF THESE OTHER PRIORITIES THAT EXIST TODAY AND THOSE THAT WE KNOW WILL BE COMING IN THE SECOND HALF OF THE YEAR WHERE WE'RE GONNA HAVE THIS SORT OF MEETING MADNESS, UM, PLEASE TRY TO NOT HAVE COMPETING VOTING SUBCOMMITTEES AT THE SAME TIME ON THE SAME DAY. YEP. VERY GOOD. AND IF IT DOES MAKE YOU FEEL BETTER OR WORSE, UH, WE HAVE BEEN TALKING TO THE OTHER SUBCOMMITTEES ACKNOWLEDGING THIS OVERLAP, SO IT'S NOT A SURPRISE TO ANYONE, UH, THAT WAS NEGOTIATING AND DISCUSSED WITH TAC LEADERSHIP RMS AND R OS. SO, UH, BUT I, I EMPATHIZE AND HOW CAN YOU BE IN THREE PLACES AT THE SAME TIME AND VOTE ON SOMETHING? SO THANK YOU CHRISTIE. ALRIGHT. AND I, I GUESS FOR EVERYBODY ELSE, IT'S JUST A REMINDER AS WE ARE JUGGLING ALL THE IMPORTANT THINGS IS REMEMBER AS YOU'RE TRYING TO GET SOMETHING TO THE TABLE, IT'S IMPORTANT, IT'S COMPETING WITH A LOT OF OTHER STUFF. SO WHETHER OR NOT OTHER THINGS NEED TO BE STOOD DOWN. ALRIGHT, NED, NEXT UP. THANKS MATT. UM, AS, AS I'M DIGESTING THE, THE, WHAT I THINK IS KIND OF THE PIVOTING APPROACH HERE TO HAVING THE BYOG AND CLR CONCEPTS AS COMMENTS ON, UH, 1 45 AND 1325 AS OPPOSED TO SEPARATE REVISION REQUESTS. UM, I, AND I THINK WHAT I HEARD YOU SAY IS THAT ERCOT MARKET RULES IS GONNA BE IN THE UNENVIABLE POSITION OF TRYING TO JUGGLE THOSE DIFFERENT, YOU KNOW, SIDE QUESTS, SO TO SPEAK, ON, ON THE, UH, ON THE MAIN REVISION REQUESTS. SO AS FOLKS ARE PUTTING COMMENTS IN, HOW SHOULD THEY FLAG IF THEY ARE PROVIDING GENERAL COMMENTS ON THE ENTIRE, UH, [00:15:01] IF, DO YOU PROVIDE COMMENTS ON JUST THE BYOG SIDE IF YOU WANT TO TOUCH BYOG? DO YOU ONLY FILE COMMENTS ON THE CLR SIDE? IF YOU WANT TO ONLY COMMENT THERE VERSUS IF YOU'RE TRYING TO JUST TALK MEAT AND POTATOES, BATCH ZERO. DO YOU FLAG IN YOUR COMMENTS THIS IS A MEAT AND POTATOES COMMENT? OR WHAT IF IT'S THE FULL BUFFET? YES. UH, I'M HUNGRY. YEAH, I WILL SAY WE TRIED TO SET UP THE VERBIAGE SO THAT THEY ARE DISCREET SECTIONS. SO THERE IS A CLR SECTION WITHIN THE BATCH ZERO SECTION. SO AS YOU TOUCH THAT, WE KNOW THAT'S IN THE CLR REALM. UM, BUT I'LL LET CORY SPEAK TO WHETHER OR NOT YOU CAN FILE A SINGLE SET OF COMMENTS ON ALL THREE CONCEPTS. WELL, I'LL, I'LL FIRST NOTE THAT NET IS NO STRANGER TO FILING MULTIPLE SETS OF COMMENTS IN MULTIPLE VENUES ON MULTIPLE THINGS. SO I, I DON'T DOUBT YOU'LL FIND A WAY TO DO IT HOWEVER YOU WANT. BUT, BUT THE QUESTION YOU'RE RAISING SPEAKS TO WHY I'VE BEEN SO STRICT WITH EVERYONE IN FILING THEIR SETS OF COMMENTS THAT EVERY SET OF FORMAL COMMENTS THAT'S POSTED UNDER BIGGER 1 45 IS A TOTALITY OF RED LINES SUCH THAT A MOTION COULD BE MADE BY SOMEONE TO MOVE THOSE THINGS FORWARD. SO IN SO MUCH AS ANYONE WANTS TO FILE ADDITIONAL RED LINES, THE ONLY QUESTION YOU'RE HAVING TO ASK YOURSELVES IS, WHAT DO I OR MY COMPANY, WHAT DO WE WANT PI 1 45 TO LOOK LIKE? THAT THEN BECOMES THE ANSWER TO WHICH SET OF COMMENTS DO I WANNA BASE MY RED LINES OFF OF IF I HATE ALL THE CLR STUFF, I'LL GO BACK TO THE ERCOT APRIL 4TH COMMENTS THAT LAST SET THAT MATT REFERENCED AS THE SORT OF GIANT AMALGAMATION OF COMPROMISE AND RESPONSE TO COMMENTS. I'LL USE THAT AS MY BASIS TO FILE MY VISTA A FOUR 12 COMMENTS IF I LIKE THE CLR STUFF, BUT I THINK IT COULD PROBABLY BE TWEAKED. I'LL TAKE WHATEVER IF, ASSUMING WE FILE THIS SET, YOU KNOW, WITHIN THE NEXT HOW MANY DAYS, I'LL USE THAT AS MY BASIS TO BUILD MY NEXT SET OF COMMENTS. SO ALL OF THOSE FORMAL SETS THAT ARE OUT THERE, THAT'S YOUR MENU TO CHOOSE FROM TO SAY, THIS IS THE CLOSEST TO WHAT I WANT FOR THIS REVISION REQUEST. WHEN IT CROSSES THE FINISH LINE, I WILL USE THAT AS MY BASIS. AND THAT'S WHY YOU'LL OFTEN NAME CHECK IT AT THE START OF YOUR PREAMBLE TO SAY, RA IS FILING COMMENTS ON TOP OF THE X, Y, Z COMMENTS. AND THAT SETS THE STAGE FOR THIS IS THE STUFF I'M GOOD WITH. AND THEN NOW HERE'S THE 12 PAGES OF PREAMBLE TO TELL YOU WHY IT'S NOT QUITE RIGHT. BUT THAT'S WHY EVERYTHING OUT THERE, ALL THOSE FORMAL COMMENTS, BECAUSE PRS HAS RECOMMENDED NO VERSION OF THE NPRR ROSS HAS RECOMMENDED NO VERSION OF THE PIGGER, ANYTHING OUT THERE WITH RED LINES IS AVAILABLE TO Y'ALL TO USE AS THE BASIS FOR NEW COMMENTS. SO THAT'S THE, THAT'S THE BENEFIT OF ME FORCING Y'ALL TO USE THE FULL SET OF RED LINES. MM-HMM . NOT PICTURES OF THE RED LINES, NOT AI SUMMARIES OF WHAT RED LINES COULD BE. SO THAT'S THE, THAT'S THE BENEFIT TO YOU NOW IS THAT AS WE'RE ON A VERY COMPRESSED TIMELINE, BUT YOU GUYS ALL HAVE PERFECTLY VIABLE SETS OF RED LINES OUT THERE TO BUILD YOUR VISION OF THE FUTURE ON. OKAY, PERFECT. THANK YOU COREY. I WANTED TO MAKE SURE WE, WE'D COVERED THAT SO IT'LL HELP MAKE, HOPEFULLY MAKE, MAKE YOUR LIFE AND EVERYONE ELSE'S LIVES A LITTLE BIT EASIER AS WE INCH FORWARD. I'M HERE TO SERVE . ALL RIGHT. UH, NEXT QUESTION WAS BLAKE KING. HEY, I JUST, I JUST PUT IN THE CHAT WHAT I BELIEVE TO BE THE SORT OF SUMMARY OF WHAT WE JUST DISCUSSED. I WAS JUST HOPING TO GET CONFIRMATION OF THE TIMELINE AND THE DIFFERENT WAYS TO THINK ABOUT IT. BUT I THINK AFTER THE CONVERSATION WITH NED, I THINK IT'S PRETTY CLEAR. YEP, VERY GOOD. AND, AND I WOULD JUST ADD TO PIGGER 1 45, THAT SAME LOGIC YOU'VE APPLIED FOR THESE FOUR ARTIFACTS WILL ALSO APPLY TO THE NPR 1325. CORRECT? YEP. UNDERSTOOD. THANKS. ALRIGHT, VERY GOOD. BILL BARNES. THANKS MAN. JUST TO CONFIRM, I SAW THE NOTE ON SLIDE FOUR, THE MEETINGS NEXT WEEK, ROSS IN PARTICULAR ON TUESDAY IS INTENDED TO BE EDUCATIONAL ONLY, SO ERCOT DOES NOT HAVE AN EXPECTATION THAT WE WOULD ACTUALLY BE VOTING ON ANYTHING THAT IS CORRECT, OR IF THE HEAVENS HAPPEN TO PART AND THERE'S SOME TYPE OF AGREEMENT, WOULD ERCOT BE CONCERNED IF THERE WAS A MOTION TO APPROVE OR WOULD YOU RATHER US NOT DO THAT? JEFF, THOUGHTS? I, I, I THINK WE'D RATHER NOT, I THINK THAT THERE ARE MORE CHANGES TO COME. UM, AND IN PARTICULAR, I THINK MATT NOTED THE, UM, COMMISSION HAS INDICATED THAT THEY, UM, MAY GIVE US SOME GUIDANCE ON SOME THINGS AT THE, UH, APRIL 17TH OPEN MEETING. SO I, I WOULD BE CONCERNED WITH MOVING ANYTHING FORWARD BEFORE THAT GUIDANCE. OKAY, SOUNDS GOOD. THANKS. THANK YOU JEFF. UH, PRASHANT, HEY, UM, BEFORE UM, WE GO INTO THIS PRESENTATION, CAN PROVIDE AN UPDATE ON THE STUDY VALIDITY PROCESS AND TIMELINES, UH, FOR THE LORDS THAT MAY HAVE MET SECTION 9.4, 9.5 AFTER MARCH 4TH? SO WHEN DO WE PLAN TO HEAR FROM [00:20:01] ON THOSE THINGS? IS THAT REGARDS TO THE UPDATED PUSH TO THE TSPS OF 9 4 9 5 SAAS? YEAH, WE HAVE A TEAM THAT'S WORKING ON A, UM, WE HAVE A RELATIVELY NEW TEAM BOLTED INTO THE LOI TEAM AND UH, MY TARGET IS I HELPED TO MANAGE THAT TEAM IS TO HAVE THE NEXT, UM, REFRESH OF THAT BY THE END OF NEXT WEEK, IF NOT SOONER. AND I WILL, WHEN WE DO THAT, PUSH A NOTE OUT TO THE SAME EXPLODES WE ALWAYS DO, WHICH IS R-O-S-L-L-W-G, UM, IN T THAT WE HAVE DONE. SO, AND AFTER THAT TIME, WE HOPE TO UPDATE IT AT LEAST EVERY TWO WEEKS, IF NOT EVERY WEEK. SO WE'RE TRYING TO BUILD THAT IN AS A NEW SLA SO THERE'S VISIBILITY OF YOUR 9 5, 9 4 9 5 COMPLETION GOING FORWARD. UNDERSTOOD. SO THAT'S THE FIRST LIST COMING UP END OF, TOWARDS THE END OF NEXT WEEK. YEP. ALRIGHT, THANKS. YOU BET. ALRIGHT, AT THIS POINT THE QUEUE IS CLEAR. ALRIGHT, SO WE'RE GONNA PIVOT OVER TO AG TO COME DO THE CONTROLLABLE LOAD RESOURCE AND AG. I'M GONNA OPEN UP THE LANGUAGE BEHIND THE SCENES ALSO, SO YOU HAVE IT ON THE DESKTOP HERE. ONE SECOND. AND I FORGOT ONE SERVICE ANNOUNCEMENT. UM, THE QSA FRED, DO YOU WANT TO GIVE A QUARTERLY THE DEADLINE ALONG AROUND THAT REMINDER? WAS THAT THE ASK TODAY? YEAH, MAYBE JUST KIND OF INFORMATION UPDATE, UM, AS PART OF THE 1 45 DISCUSSION AND THE, THE ONGOING QSA SCHEDULE, I JUST WANT TO KIND OF PROVIDE A REMINDER. SO FOR LARGE LOAD WITH INITIAL ENERGIZATION SCHEDULED IN OCTOBER, NOVEMBER, DECEMBER THIS YEAR, UH, THE PROJECT WILL NEED TO BE INCLUDED IN THE UPCOMING QSA, WHICH WILL STARTED ON MAY 1ST. SO THIS KIND OF TRY TO REMIND THE GROUPS, UH, TO REVIEW AND CONFIRM YOU HAVE MADE ALL THE REQUIRED PREREQUISITE AS DESCRIBED IN A PLANNING GUIDE 5, 3 5, PARAGRAPH FIVE, AND ESSENTIALLY JUST ENCOURAGE YOU BECAUSE IT'S ESSENTIAL TO HAVE ALL THIS INFORMATION TO BE AVAILABLE AND SUBMIT IT BY LETTER DATE. SO I JUST KIND OF WANT TO TAKE THIS OPPORTUNITY TO, UH, SAY IF YOU HAVE ANY QUESTIONS OR ANY KIND OF INFORMATION ABOUT YOUR PROJECT SCHEDULE, INITIAL ENERGIZATION, ANOTHER TIMEFRAME, PLEASE REACH OUT TO US, UH, AND UH, WE WILL DO OUR BEST TO SUPPORT YOU, UH, AS EARLY AS POSSIBLE. I THINK EVEN THE DEADLINE IS, I WOULD SAY APRIL 30TH, WE STARTED MAY 1ST. SO ANY LAST MINUTE SUBMITTAL, IF AS YOU KNOW, THERE A MODEL RELATED OR, OR ANY STUDY RELATED ONE. SO PLEASE REACH OUT TO US AND, UH, AS SOON AS POSSIBLE AND WE'LL WORK WITH YOU. AND, UH, WE DO KNOW THERE ARE SOME ALREADY ARE DOING THIS ONE, SO WE APPRECIATE YOUR HELP. SO JUST WANT TO MAKE THIS ONE AGAIN, THIS IS FOR THE LARGE LOAD WITH INITIAL ENERGIZATION SCHEDULED IN OCTOBER, NOVEMBER, DECEMBER THIS YEAR. THANK YOU. ALRIGHT, AND, AND FRED, THERE'S SOME FOUR QUESTIONS COMING IN ALREADY. SO, SO FOURTH QUARTER ENERGIZATION, HAVE YOUR STUFF IN BY MAY 1ST SNAPSHOT. UH, FIRST ONE, LEE BRATCHER. HEY LEE BRATCHER CIPHER DIGITAL. GIVEN THAT THIS IS, I THINK ONE OF THE FIRST TIMES THAT, OR, OR IT'S, IT'S AN EARLY PROCESS FOR THE TSPS AND THE LARGE LOADS TO FIGURE OUT HOW TO GET ALL THE INFORMATION TO ERCOT, UM, FOR THE QSA, IS IT POSSIBLE FOR ERCOT TO UPDATE LOADS DIRECTLY AS TO YES, WE, WE'LL CONFIRM THAT WE HAVE EVERYTHING WE NEED FOR THE MAKE QSA FOR THIS LOAD. UH, THE, FROM THE PROCESS PERSPECTIVE, THIS IS PROBABLY THE SECOND ONE. THE OFFICIAL QSA, THE LARGE LOAD MUST GO THROUGH ALREADY [00:25:01] STARTED IN THE, UM, ON FEBRUARY 1ST. SO THE ONGOING, THE QSA WE ARE DOING RIGHT NOW ALREADY EFFECTIVE SUCH, LIKE ALL THE LARGE LOAD TRY TO HAVE INITIALIZATION IN Q3, THEY IN OTHER PROCESS ALREADY. SO THIS IS NOT OUR THIS IS OUR SECOND TIME, NOT THE FIRST TIME, UM, TO YOUR SUGGESTION TO REACH OUT TO ALL THE PROJECTS. I THINK THAT YOU'LL BE, IT'S ONLY KIND OF THREE WEEKS LEFT. IT'D BE MORE DIFFICULT FOR US TO, AND YOU, WE BELIEVE THE OWNER DEVELOPER HAS LOT, ALL THE INFORMATION YOU HAVE, PLEASE CHECK IT AND, UH, IF YOU HAVE ANY QUESTION, PLEASE REACH OUT TO US. WE WANNA HELP YOU TO WORK WITH YOU. UH, IF WE CHECK IT, WE MAY, I'M NOT SURE HOW, HOW COMPREHENSIVE WE HAVE, BUT YOU CERTAINLY KNOW YOUR PROJECTS, SO CHECK IT PLEASE AND, UH, JUST HELPS. UH, AND THEN AGAIN, SEND EQUATION OR INFORMATION AS EARLY AS POSSIBLE, EVEN AS A DYNAMIC MODEL YOU ARE NOT CERTAIN IS, DOES THIS MATTER WHAT WE NEED? PLEASE REACH OUT TO US ALL. NEXT IN THE QUEUE IS EVAN. THANKS EINA WITH LANCIA. UM, QUICK QUESTION. I NOTED IN THE COMMENTS ERCOT FILED ON APRIL 3RD, THEY PROPOSE A CHANGE TO THE REQUIREMENTS TO BE INCLUDED IN THE QSA FOR LOADS. SO ARE WE GOING BY WHAT'S CURRENTLY IN ONE 15 OR ARE WE CONSIDERING THE NEW REQUIREMENTS FOR INCLUSION THAT'S PROPOSED? I THINK OTHER PEOPLE, OTHER PEOPLE CAN CORRECT ME. OUR PLAN IS TO FOLLOW EXISTING EFFECTIVE LANGUAGE. OKAY, GREAT. UM, AND THEN JUST ONE OTHER QUESTION. IS THERE, UH, A WAY THAT LOADS CAN GET LIKE WRITTEN CONFIRMATION THAT THEY'RE GOOD TO GO IN THE QSA? I MEAN, I, I UNDERSTAND REACHING OUT EARLY AND WORKING THROUGH ANY POTENTIAL MODELING ISSUES, BUT IS THERE A WAY FOR LOADS TO KNOW THAT, YOU KNOW, THOSE MODELS ARE ALL GOOD? IS THAT JUST LIKE AN EMAIL CONFIRMATION FROM STAFF? UM, I WILL CHECK WITH INTERNALLY TO SEE HOW WE CAN BETTER COMMUNICATE IT. UH, CERTAINLY WE WILL WORK WITH THE TSP, THAT'S FOR SURE. AND, UH, HOW TO CONVEY THAT MESSAGE TO THE PROPER ENTITY WITH OTHER PROJECTS. WE WILL MAKE SURE WE GET THE RIGHT NOTE. OKAY, THANKS FRED. APPRECIATE IT. OKAY, NEXT IN THE QUEUE IS BLAKE KING. HEY, JUST TO SORT OF REITERATE WHAT EVAN SAID, I GUESS A QUESTION WHICH IS, WHOSE, WHOSE JOB IS IT TO ACTUALLY SUBMIT THE QSA INFO TO ERCOT? IS IT THE LARGE LOAD OR IS IT THE UTILITY? I GUESS WHO, WHO WOULD ERCOT RECEIVE THE INFORMATION FROM AND CONSIDER IT VALID? UM, I, I ERCOT YOU PLEASE CORRECT ME. AS FAR AS I KNOW, FOR THE EXCEEDING PROCESS, OUR PRIMARY CONTACT IS TSP. GOT IT. OKAY. AND SO IF WE'VE, IF WE'VE SUBMITTED THE LCP AND THE LIF AND AND MODELS, SHOULD, SHOULD WE ASSUME THAT IT'S AUTOMATIC THAT WE WOULD BE INCORPORATED? BECAUSE ALL THIS DATA'S ALREADY BEEN GIVEN TO THE TSPS AND THE DATES ARE THERE, OR SHOULD WE FOLLOW UP? AND, AND I APPRECIATE THAT YOU KEEP SAYING REACH OUT TO US. I WOULD LOVE TO KNOW WHO SPECIFICALLY AT ERCO WOULD BE A GOOD, UH, PERSON THAT CAN LIKE, TELL US TO, TO EVAN'S POINT, LIKE THE WRITTEN CONFIRMATION THAT WE'RE IN, I THINK WE, WE ALL ARE SORT OF ALIGNING THAT WE NEED SOMEONE THAT CAN GIVE US THAT, THAT INFORMATION. YEAH. AGAIN, ED, YOU PLEASE FEEL FREE TO JUMP IN. I WOULD SAY CURRENT PROCESS IS WE WORK WITH THE TSP TO IDENTIFY THOSE PROJECT TO BE INCLUDED IN THE QSA, UH, FOR YOUR PROJECTS, PLEASE WORK WITH YOUR INTERCONNECTING TSPS AND ONCE WE RECEIVE THOSE INFORMATION, WE REVIEW IT, WE PROVIDE ALL OUR FEEDBACK BACK TO THE TSP, HOPEFULLY THAT THE RIGHT CHANNEL TO BACK TO YOU. OKAY. YEAH. AND THE, UH, YEAH, AS ALWAYS INQUIRIES, THIS IS AG SPRINGER. UM, INQUIRIES CAN ALSO BE SENT TO THE, THE LARGE LOAD INBOX, UH, IF, IF YOU HAVE QUESTIONS. BUT, UM, YOU KNOW, JUST TO, TO ADD THAT, UH, YOU KNOW, THIS, THIS QSA IS FOR FOURTH QUARTER ENERGIZATION. SO, UM, THAT IS ALSO A FACTOR IN, YOU KNOW, EVALUATING, UH, IF THE LOAD IS ELIGIBLE FOR INCLUSION OR NOT. MAKES SENSE. THANKS. ALL RIGHT. NEXT IN THE QUEUE IS SANDY KAR. THANKS JEFF. UH, SANDY KAR, CRA. JUST GOING BACK TO BLAKE'S QUESTION AGAIN. UH, FRED, YOU MENTIONED SEND IT TO US. UH, WOULD LIKE TO KNOW, IS IT THE LARGE LOAD TEAM OR IS IT, UH, THE ZI AND SUNO, OR WHICH, WHO, WHO'S THE, UH, THE, WHICH TEAM DOES IT, UH, [00:30:01] GO TO AND WHO WILL GIVE US THE ANSWER WHETHER IT'S MADE IT AND IT'S ALL CLEAR. SO THE, THE LIST OF WHO ULTIMATELY HAS MADE IT, THAT, THAT WILL COME FROM THE LARGE LOAD TEAM, UM, I QUESTIONS ABOUT THE DYNAMIC MODELS OR ANY OF THE OTHER DYNAMIC DATA THAT'S SUBMITTED THAT WILL, UH, BE SUPPORTED BY, UH, SYNEX TEAM. GOT IT. SO TO RETREAD THAT, UH, IF WE HAVE A PROJECT THAT NEEDS TO GET INTO THE MAKE USA, WE WILL WORK WITH THE LARGE LOAD TEAM AND PROVIDE ALL THE INFORMATION. THE DYNAMIC MODELS WILL BE VALIDATED BY THE STABILITY PLANNING TEAM, AND, UH, FINAL ANSWER WILL COME BACK FROM THE LARGE LOAD TEAM. OKAY, THANKS. OKAY, NEXT IN THE PERSON, DOUG GOLDEN. YEAH. NEXT IN THE QUEUE IS DOUG GOLDEN. HI. RIGHT, GOOD MORNING, DOUG. GOLDEN CORE SCIENTIFIC, UM, PROBABLY A WEIRD QUESTION TO ASK AT THIS STAGE IN THE GAME, BUT, UH, AS A, AS A PUBLICLY TRADE COMPANY, WE GET INQUIRIES LOTS AND LOTS OF TIMES FROM PEOPLE WHO READ LITTLE TIDBITS OF INFORMATION ONLINE, UH, TRANSCRIPTS OF STATE SENATE HEARINGS AND THINGS LIKE THAT. UH, IS IT SAFE TO ASSUME THAT AT THIS POINT IT IS A FOREGONE CONCLUSION THAT BADGE ZERO WILL ACTUALLY OCCUR AND AT THIS AND THE ONLY THING UP IN THE AIR IS WHAT THE RULES OF BADGE ZERO WILL BE? OR IS THERE STILL RISK THAT BADGE ZERO I IS NOT GOING TO BE A THING? UM, I, I'M NOT SURE HOW TO ANSWER THAT. THAT'S, UH, I, I THINK THAT WE, UM, HAVE BEEN GIVEN, UM, DIRECTION BY THE PEC TO, UM, UH, NOT DIRECTION BUT GUIDANCE BY THE PUC TO PURSUE, UH, A BATCH, SERIAL AND FILE THOSE REVISION REQUEST, UH, WHICH WE HAVE DONE. OUR INTENTION IS TO GET THOSE IN FRONT OF, UM, THE BOARD IN JUNE, WHICH WOULD GET IT TO, UH, JULY PUC. UM, AND THAT, THAT, YOU KNOW, THAT THAT IS THE GUIDANCE WE'VE BEEN GIVEN AND, AND WE ARE MARCHING TOWARDS THAT. I HAVE HAVE NOT BEEN TOLD THAT THAT MAY CHANGE. SO JUNE BOARD MEETING WOULD BE EFFECTIVELY WHEN THE MARKET IN GENERAL FINDS OUT IF THAT'S, IF THAT'S THE CASE OR NOT, RIGHT? WELL, YEAH, ULTIMATELY THE PUC, UM, SO THE, THE, THE PROCESS IS THAT THE, UM, UM, ANY RE REVISION REQUESTS WOULD NEED TO BE APPROVED BY, UH, THE BOARD OF DIRECTORS OR COTS BOARD OF DIRECTORS, AND THEN THE PUC HAS TO ADOPT, UM, THAT, UH, AND, AND THEY HAVE, UH, 30 DAYS TO CONSIDER THAT. UM, SO YEAH, SO UL ULTIMATELY IT'S NOT EFFECTIVE UNTIL THE, THE PUC ADOPTS IT. ALRIGHT, THANKS JUDGE. ALL RIGHT. Q IS CLEAR. I THINK WE'RE READY TO POP INTO CLRS. AND, UM, AND, AND IF I INTERPRETED THE MAD SCRAMBLING, UH, I THINK WE POSTED THE WRONG VERSION OF THE SLIDES PREVIOUSLY, AND SO YOU MAY NEED TO REFRESH, UH, TO GET THE CORRECT VERSION THAT, UH, I THINK AG G'S USING NOW. IT IS NOW VERSION THREE. THANK YOU. YEAH, AND THANKS, THANKS TO MATT AND, AND THE TEAM FOR SCRAMBLING BEHIND THE SCENES THERE AND, AND GETTING THAT PICKED SO QUICKLY. SO, UM, YEAH, AGAIN, UH, IF, IF YOU ARE LOOKING AT VERSION ONE OR VERSION TWO, IT IS OUT OF DATE, SO PLEASE REDOWNLOAD, UH, WITH VERSION THREE, WHICH CONTAINS CHANGES TO THE CLR SLIDES. OKAY. UM, SO AS MATT MENTIONED, WE'RE GOING TO LOOK AT THE DRAFT LANGUAGE THAT WE ARE INTENDING TO FILE AS COMMENTS ON PGA 1 45 AND 13 NPR 1325 NEXT WEEK. UM, WHAT WE'RE GONNA SEE IN MY SLIDES IS, UM, SOMEWHAT OF A REVIEW FROM LAST TIME, BUT WITH, WITH SOME CHANGES TO REFLECT WHAT'S ON THE PAPER NOW. UM, THERE'S GOING TO BE THREE KIND OF CORE PILLARS OF WHAT'S IN THESE COMMENTS. AND SO WHAT WE'RE GONNA DO IS WE'RE GONNA LOOK AT THE FIRST TWO, AND THEN WE'LL LOOK AT THE LANGUAGE AND WE'LL COME BACK TO THE THIRD PILLAR AND TALK THROUGH THAT AND LOOK AT LANGUAGE AGAIN. SO WE'RE GONNA KIND OF HOP BACK AND FORTH BETWEEN A COUPLE SLIDES AND THEN, UH, THE, THE DRAFT COMMENTS THEMSELVES, UH, DRAFT COMMENTS ARE ALSO POSTED ON THE MEETING PAGE IF YOU WANNA FOLLOW ALONG THERE. OKAY. SO, UM, THIS SET OF COMMENTS PROPOSES A NEW TYPE OF CLR, WHICH IS CALLED A PROVISIONAL CLR OR PCLR. UM, WHAT IS THAT? WELL, IT, IT'S SAME AS ACL R, EXCEPT THAT IT IS LOCKED IN FOR A DEFINED PERIOD OF TIME THAT WILL BE DETERMINED BY THE BATCH ZERO INTERCONNECTION STUDY. IN OTHER WORDS, IT WILL NOT BE ELIGIBLE TO CHANGE AND DEREGISTER AS ACL R. UM, AND THAT'S THE SORT OF MECHANISM THAT THAT LOAD WILL BE ABLE TO CONSUME MORE MEGAWATTS SOONER. UM, [00:35:01] THE OTHER DIFFERENCE IS THAT IT HAS A DEFINED LOW POWER CONSUMPTION LIMIT THAT IT CAN OFFER. UM, IT COULD GO LOWER THAN THAT. SO IF, IF, YOU KNOW, THE, THE STUDY DETERMINES THAT A HUNDRED MEGAWATTS HAS TO BE FIRM, UM, IF THE, UH, OWNER OF THAT PCLR ELECTS TO SAY, WELL, I'LL ACTUALLY BE FLEXIBLE DOWN TO 50 MEGAWATTS, THAT'S FINE, BUT IN REAL TIME IT CAN'T COME TO REAL TIME AND SAY 200 MEGAWATTS IS FIRM. UM, SO THAT THAT HAS THAT MAXIMUM LOW POWER CONSUMPTION LIMIT THAT'S DEFINED IN THE BACTERIA INTERCONNECTION STUDY. UM, JUST LIKE ACL R, IT'S GOING TO SUBMIT AN ENERGY BID CURVE. UH, SO IT HAS, YOU KNOW, BID TO BUY PRICES BETWEEN LOW POWER CONSUMPTION AND, AND MAXIMUM POWER CONSUMPTION, JUST LIKE ANY OTHER CLR, THE, THE KEY WAYS IN THE, WHICH IT'S DIFFERENT ASIDE FROM THE, UM, AND I SEE CHRISTIE'S, UH, QUESTION IS THE SLIDES NINE THROUGH 13 ARE, ARE EDITED BETWEEN VERSION TWO AND VERSION THREE, CHRISTIE. UM, SO WHAT IS DIFFERENT, UM, BECAUSE WE ARE USING THIS AS A RELIABILITY TOOL IN THE PLANNING ASSESSMENTS TO ASSURE THAT WE CAN RESOLVE TRANSMISSION CONSTRAINTS WHEN WE GET TO REAL TIME, WE NEED TO ENSURE THAT ED IS GOING TO DISPATCH THAT PCLR TO RESOLVE TRANSMISSION CONSTRAINTS THAT SHOW UP IN REAL TIME. AND SO WE WILL BE IN, WE'RE PROPOSING, UH, BID CAPPING METHODOLOGY, UM, THAT WE WILL, WILL, THAT'S GONNA BE THE PIECE WE COME TO AT THE END, UM, TO MITIGATE TRANSMISSION CONSTRAINTS THAT ARE IDENTIFIED AND ENSURE THAT THE CLR GETS DISPATCHED FOR THAT RATHER THAN SC ELECTING TO ALLOW THE CONSTRAINT TO VIOLATE. UM, WHAT WE HAVE DONE IS WE'VE INTRODUCED THAT DYNAMIC METHODOLOGY FOR THAT. THE IDEA IS THAT IT WOULD BE KIND OF PUT THE CLR LAST IN LINE TO ENSURE THAT IT'S NOT GETTING AHEAD OF, OF COMPETITIVE GENERATION OFFERS. UM, AND IT WILL JUST ALLOW THE SCED, UH, SCED DISPATCH TO RESOLVE THAT CONSTRAINT. UM, THE OTHER DIFFERENCE IS THAT PCR, UH, WILL NOT BE ELIGIBLE TO QUALIFY FOR ANCILLARY SERVICE, UH, TO PROVIDE ANCILLARY SERVICES. SO THAT'S WHAT WE'RE TALKING ABOUT WITH PCLR. IT'S LARGELY THE SAME AS A CLR WITH, WITH SOME, YOU KNOW, SMALL DIFFERENCES. OKAY. I THINK WE, WE'VE ALREADY COVERED THIS. SO, UM, UH, JUST GONNA QUICKLY REVIEW HERE. UM, WE'RE NOT, WE STATED LAST TIME THAT WE WOULD BE FILING SEPARATE REVISION REQUESTS. UH, THE INTENT IS NOW WE ARE GONNA FILE THESE AS COMMENTS ON P 1 45 AND 1325. THE MODULAR STRUCTURE CONCEPT REMAINS. SO WE ARE GOING TO ADD SUBSECTIONS TO EACH RELEVANT SECTION OF PICKER 1 45 THAT DEFINES HOW CLRS WILL BE TREATED AT EACH STEP OF THE BATCH PROCESS. AND THE REASON WE'RE DOING THAT IS THAT THE LANGUAGE BECOMES ADDITIVE. BUT IF WE HAVE ISSUES, UH, YOU KNOW, THE IDEA IS THAT THAT WOULD ALLOW EVERYTHING TO MOVE FORWARD IN TANDEM, BUT IN THE EVENT THAT THERE ARE UNRESOLVED ISSUES, BY THE TIME WE GET TO, YOU KNOW, MAY TAC, WE HAVE A WAY TO KIND OF EASILY REMOVE LANGUAGE THAT THAT IS NOT READY TO MOVE FORWARD. UM, SO IT, IT'S AN ADDITIVE STRUCTURE AND, UM, I, I THINK WE TALKED ABOUT THIS CONCEPT EARLY IN ONE OF THE EARLIER WORKSHOPS, BUT THE WAY WE HAVE STRUCTURED THIS ALSO IS THAT THE LANGUAGE THAT WOULD ALLOW THE PCLR TO ENERGIZE, SO THAT'S PLANNING GUIDE 9.6, AND THEN THE LANGUAGE AROUND THE, UH, BID CAPPING METHODOLOGY. THE INTENT IS THAT THOSE WOULD REMAIN GRAY BOX UNTIL SYSTEM CHANGES ARE DONE, BUT THE LANGUAGE OF INCLUSION IN BATCH ZERO AND STUDY IN BATCH ZERO, THAT THAT COULD BE UNBOXED IMMEDIATELY. SO, UM, WE, WE WROTE IT IN SUCH A WAY THAT WE CAN INCLUDE THESE LOADS IN THE STUDY AND ASSESS THEM, BUT THE ADDITIONAL MEGAWATTS THAT ARE PCLR DEPENDENT, THOSE WOULD, THAT LANGUAGE ALLOWING THEM TO ENERGIZE WOULD WAIT UNTIL THE SYSTEM CHANGES ARE DONE TO, UH, SUPPORT THAT. OKAY. SO I MENTIONED KIND OF THREE PILLARS HERE. I'M GONNA TALK THROUGH THOSE AND THEN, UH, I THINK I HAVE THE FLOW CHART SLIDE AND THEN WE'LL GO INTO LANGUAGE. SO THE, THE THREE PILLARS ARE, FIRST OF ALL, HOW DO WE, HOW DO WE ASSESS AND ALLOCATE THESE LOADS IN BATCH ZERO? SO THESE LOADS WILL BE, UH, PCR WILL BE ASSESSED IN BATCH ZERO IN THE STEADY STATE. THEY'LL BE TREATED EXACTLY LIKE, UH, A FIRM LOAD REQUEST. SO THERE'S NO CHANGE IN HOW THEY'RE ASSESSED. THE STUDY WILL WILL TREAT THEM EQUALLY WITH OTHER LOADS TO DETERMINE HOW MUCH CAN BE SERVED AS FIRM. THE LEVEL OF FIRM SERVICE BECOMES THE ALLOWED LOW POWER CONSUMPTION LIMITS. SO IF THE, YOU KNOW, IF YOU WERE A FIRM LOAD AND THE STUDY SAYS, WELL, BATCH ZERO SAYS YOU CAN GET 150 MEGAWATTS IN THE FIRST YEAR IF YOU'RE A-P-C-L-R, THAT [00:40:01] BECOMES THE, UH, UH, HIGHEST YOUR LOW POWER CONSUMPTION LIMIT CAN BE. UM, AND SO IT JUST KIND OF CONVERTS TO, OKAY, THAT'S YOUR FIRM PIECE OF YOUR PCLR. UM, THE DIFFERENCE IS THAT THEN THE PCLR COULD ENERGIZE ABOVE THAT ONCE IT REGISTERS AND QUALIFIES AS A-P-C-L-R INSTEAD OF THAT 150 BECOMING A FIRM LIMIT. UM, SO THE ASSESSMENT IS SIMILAR, UM, FOR STABILITY. THIS IS WHERE THE DIFFERENCE COMES IS THAT THE PCLR WILL BE STUDIED AS FULL REQUESTED AMOUNT FOR ALL YEARS OF THE STABILITY SCREENING STUDY BECAUSE IF THAT EXTRA LOAD ENERGIZES, THEN THE DISPATCH COULD BE HIGHER. AND SO WE NEED TO SCREEN THAT AGAINST, UH, THE HIGHER LOAD AMOUNT TO IDENTIFY STABILITY ISSUES. SO THE, THE COMMENTS INCLUDE LANGUAGE THAT ACCOMPLISHES THAT. THE SECOND PIECE IS THE REGISTRATION REQUIREMENTS. SO IF WE'RE STUDYING THESE LOADS AS CONTROLLABLE AND AS FLEXIBLE, THERE NEEDS TO BE REQUIREMENTS REQUIRING THAT REGISTRATION AND QUALIFICATION TO THEN HAPPEN BEFORE THE LOAD CAN ENERGIZE. SO THE WAY WE'VE STRUCTURED IT IS THAT THERE'S AN INTENT TO REGISTER AS A-P-C-L-R THAT'S DECLARED BEFORE BATCH ZERO. AND THAT'S SO THAT WE KNOW THAT WE NEED TO GO AND STUDY IT DIFFERENTLY FOR ABILITY STABILITY. ONCE ALLOCATED IN BATCH ZERO, THE LOAD THEN HAS AN OBLIGATION TO ACTUALLY REGISTER AND QUALIFY AS A-P-C-L-R BEFORE IT CAN CONSUME ABOVE ITS INITIAL FIRM LOAD LIMITS. UM, AND THEN LASTLY, WE CREATE A STRUCTURE WHERE, UH, EXCUSE ME, UM, WHERE, UH, THE PCLR IS ALSO OBLIGATED TO REMAIN A-P-C-L-R UNTIL AN EXIT DATE, OR IT HAS TO GO BACK DOWN TO ITS FIRM LOAD AMOUNTS IF IT, IF THE, THE CUSTOMER CHANGES ITS MIND. AND SO, UM, LASTLY, THERE'S ALSO AN OBLIGATION THAT THIS OBLIGATION WOULD TRANSFER IN THE EVENT THAT THE OWNERSHIP OF THE LARGE LOAD CHANGES. SO THAT'S THE SECOND KIND OF CORE PILLAR OF WHAT WE'VE WRITTEN HERE. AND THEN THE PIECE THAT WE'RE GONNA, WE'RE GONNA COME BACK TO AT THE END IS HOW DO WE ENSURE THE BID CAPPING METHODOLOGY IS STRUCTURED SO THAT, UM, UH, THE PCLR IS GOING TO BE DISPATCHED FOR TRANSMISSION CONSTRAINTS. SO JUST LIKE A TRADITIONAL C-L-R-P-C-L-R WILL WILL SUBMIT A BID, UH, AN ENERGY BID CURVE AND ALSO, UH, FO MUST FOLLOW SC BASE POINTS WHILE CONSUMING. UM, AND THAT OF COURSE IS ALSO ON IMPLEMENTATION OF NPR 1188, AND WE'VE ADDED WHAT'S KIND OF NOVEL IN OUR, UH, OUR COMMENTS HERE WILL BE THE DYNAMIC BID CAPPING LOGIC. AND THAT'S TO ENSURE THAT, UH, THAT C-L-R-P-C-L-R IS DISPATCHED. AND THIS IS JUST A QUICK REFRESHER BEFORE WE HOP OVER TO LANGUAGE. UM, YOU KNOW, FOR, FOR THE BATCH ZERO, THIS IS THE SAME SLIDE THAT WE SHOWED LAST WORKSHOP. UM, THERE'LL BE THAT SUBMISSION OF DECLARATION OF INTENT. WE'LL STUDY IT IN BATCH ZERO DURING THE COMMITMENT PERIOD. THE CUSTOMER WILL ACCEPT THE, UH, WILL SUBMIT THEIR UPDATED DECLARATION THAT ACCEPTS THEIR THEIR ALLOCATION AMOUNT AND CONFIRMS THEY'RE GONNA BE A-P-C-L-R. UH, AND THEN WE WILL STUDY THE FULL LOAD AMOUNT IN, IN REFINEMENT TO ENSURE THAT WE BUILD TRANSMISSION TO EVENTUALLY SERVE THAT LOAD. AND THEN AS WE GET CLOSER TO OPERATION, REGISTERING AS A RESOURCE ENTITY DESIGNATING A QSE, UH, MODELING THE CLR INFORMATION IN RIO AND PROVIDING ALL THE TELEMETRY, THOSE WILL ALL BE PREREQUISITES BEFORE THAT THE PCLR CAN ACTUALLY COME ONLINE. ALRIGHT, SO A WHAT I MAY DO IS, WHENEVER YOU'RE READY TO GO TO LANGUAGE, WE'LL PAUSE AND TAKE A, A FEW QUESTIONS. I'M READY RIGHT NOW. ALRIGHT, AND LEMME JUST KIND OF DO THE, A G LAID THIS OUT VERY WELL, BUT JUST KIND OF THE, THE ONE TWO THREES OF THIS IS CLRS EXIST TODAY. IF YOU'RE A DATA CENTER THAT WANTS TO USE THIS CONSTRUCT, YOU'RE GONNA HAVE TO GET A QUEASY TO HELP YOU OUT OPERATIONALLY DOWN THE ROAD. AND SO YOU'RE GONNA HAVE TO HAVE AN AGREEMENT TO SET THAT UP. YOU'LL HAVE TO BE QUALIFIED, TESTED AND DO EVERYTHING JUST LIKE A NORMAL CLR DOES TODAY. BUT WHAT'S HAPPENING BEHIND THE SCENES IS THAT SC WILL BE CHANGED IN PROTOCOLS WHERE AS SCED SEES THIS SPECIAL CLR, IT'S GONNA USE TRANSMISSION CONSTRAINTS TO DISPATCH YOU AND CAP YOUR BID AT A LOWER LEVEL SO THAT YOU DON'T OVER, THAT YOU DON'T VIOLATE THE CONSTRAINT AND KIND OF BACK TO THAT PUTS YOU IN LINE. UH, SO THAT'S THE OVERALL CONSTRUCT. UH, THERE'S A LOT OF LANGUAGE TO GO THROUGH, BUT I WILL PAUSE AND TAKE QUESTIONS, BUT WE MAY BE POINTING TO LANGUAGE AS THESE COME OUT. UH, ONE OF THE MOST IMPORTANT ONES IS THE CONTRACT THAT WE'RE, SORRY, CONTRACT, THE AGREEMENT THAT WE THINK NEEDS TO BE SIGNED GOING INTO THIS. SO, WOW, THE QUEUE'S GETTING ALONG. OKAY, WE'LL DO OUR BEST. I I MAY CUT IT OFF AT SOME POINT AND [00:45:01] SAY WE HAVE TO GET THROUGH ALL OF THIS BEFORE WE TAKE A BUNCH OF QUESTIONS THAT MAY BE ANSWERED, BUT WE'LL, WE'LL SEE HOW THIS GOES. SANDEEP, SHARMA. HEY, A SANDEEP SMA NEXTERA SLIDE NUMBER NINE. CAN WE GO THERE? WHAT IS THE REASON FOR EXCLUDING THEM FROM ANCILLARY SERVICE? JUST THE RATIONALE. YEAH. UM, AND YOU KNOW, I PROBABLY SHOULD HAVE, IN MY VOICEOVER ALSO STATED THAT WE'RE NOT NECESSARILY OPPOSED TO THIS CONCEPT FOREVER, BUT IT, IT ADDS MORE COMPLICATION IN GETTING THIS READY FOR BATCH ZERO. SO, UM, YOU KNOW, WE HAVE BEEN TARGETING TO HAVE THIS LANGUAGE FILED TODAY, AND YOU NOTICE WE WE'RE SHOWING A DRAFT TODAY. UM, ONE OF THE MOST DIFFICULT PIECES OF THIS WAS DEVELOPING THE BID CAPPING METHODOLOGY. IF WE HAVE TO EXPAND THAT TO ALL THE AS DEMAND, UH, OFFER CURVES, I, I JUST DON'T KNOW IF WE'RE GONNA BE ABLE TO DELIVER THIS ON TIME. AND SO, UM, THIS IS WHAT WE FEEL IS ACHIEVABLE RIGHT NOW. UH, AND UH, THAT'S THE REASON WHY WE'RE, WE'RE . OKAY. SO IN PRINCIPLE, YOU'RE NOT OPPOSED, IT'S JUST THE TIMING ISSUE AND THE OKAY. THANK YOU. YEAH. FEEL ANYBODY ELSE ABOUT BACK THERE, FEEL FREE TO DISAGREE WITH ME, BUT THAT, THAT'S VERY WELL SAID. IT'S JUST TOO MUCH SCOPE. WE CAN'T DO EVERYTHING RIGHT NOW. UH, BOB KING. THANKS MATT. COUPLE OF QUICK QUESTIONS. UH, BOB KING, GOOD COMPANY ASSOCIATES, CAN, UH, CLR CURTAIL COMPLETELY AT SOME POINT AND BE IN LINE WITH THIS, OR WOULD IT NEED TO FOLLOW BASE POINTS? IN OTHER WORDS, MAYBE BATTERY IS BEING USED, RUNS OUT OR SOMETHING HAPPENS, CAN THEY JUST CURTAIL SO AS LONG AS THEY'RE LOW OR IS THIS BEING, YOU SAY, CAN'T BE ANCILLARY SERVICES, BUT ARE YOU DEPENDING ON THEM FOLLOWING BASE POINTS IN BOTH DIRECTIONS OR YOU ARE YES. YES, THERE'S AN OBLIGATION TO FOLLOW BASE POINTS. ALL RIGHT. JUST WANT TO BE CLEAR. I JUST, I JUST WANT, CAN I ADD SOMETHING TO THAT? YEAH. UM, SO IF YOU'RE, IF YOU'RE TRYING TO COMBINE A BATTERY WITH A, A LOAD AND SAY THAT'S ACL R, I THINK HISTORICALLY WE HAVE NOT ALLOWED THAT. SO I JUST WANT TO CLARIFY THAT'S NUMBER ONE. NUMBER TWO, IF YOU ARE REALLY SWITCHING OFF THE LOAD, UM, YOU'LL HAVE TO OF COURSE CHUNK IT UP SO THAT YOU CAN FOLLOW THE FIVE MINUTE CURTAILMENT INSTRUCTIONS. BUT IF YOU SAY THAT YOU HAVE A PROBLEM COMING BACK, IF WE, IF WE DO THAT, YOU CAN CHANGE YOUR UP. SORRY. I THINK FOR CL LR IT'S THE DOWN RAMP RATE, RIGHT? THERE'S, WE, WE COMPUTE FOR ALL RESOURCES, WE COMPUTE DISPATCH LIMITS BASED ON THE TELEMETER RAMP RATES. SO ONCE CURTAILED, IF YOU SAID THAT, HEY, I CAN'T COME BACK IMMEDIATELY, RIGHT? YOU CAN CHANGE THE, I BELIEVE IT'S THE DOWN RAMP RATE FOR CLR SO THAT YOU CAN INCREASE YOUR CONSUMPTION, RIGHT? SO, SO YOU CAN, YOU CAN MANAGE SOME OF THOSE, UM, TEMPORAL CONSTRAINTS, SO TO SPEAK THROUGH YOUR TELEMETRY THAT THE QSC SUMMITS, I APPRECIATE THAT. SI UM, AND, AND SORRY TO PRIOR TO YOUR NEXT QUESTION, I ALSO WANT TO ADD, YOU KNOW, THAT TO YOUR, YOUR EARLIER QUESTION OF CAN A CLR CURTAIL ALL THE WAY, YOU KNOW, THAT IS ALSO INFORMATION THAT YOU WILL PROVIDE TO INSTEAD OF, YOU KNOW, I'M AVAILABLE TO CURTAIL ALL THE WAY DOWN AND UH, UH, SO ALL OF THAT IS DEFINED, BUT ONCE YOU KNOW, THAT'S IN, ALL THOSE ARE ALL INPUTS INTO SC AND THE OBLIGATION THEN IS TO FOLLOW THE OUTPUT, THE, THE INSTRUCTION FROM SC. AND I JUST WANT TO ADD ANOTHER THING IS WE USE THE MAP RAMP RATE UP TO CURTAIL THE CLR. SO YOU CAN'T JUST SAY THAT MY, MY RAMP RATE UP FOR CURTAILMENT IS ZERO MEGAWATTS PER MINUTE. THAT MEANS SCARED WILL NOT BE ABLE TO CURTAIL YOU THAT THAT'S A RED FLAG. SO YOU, WE HAVE TO COME UP WITH SOMETHING THAT YOU CAN GO ALL THE WAY DOWN TO THE LOW POWER CONSUMPTION WHEN WE INSTRUCT YOU. ALRIGHT. SA YOU SAID YOU CAN'T USE A BATTERY TO RESPOND, BUT IF IT'S BEHIND AND UNSYNCHRONIZED YOU CAN, RIGHT? THAT IS CORRECT. OKAY. UM, THE SECOND, WHICH I THOUGHT WAS ALSO GONNA BE A QUICK QUESTION, UM, WILL THERE BE A, A TOP FIXED CAP IF, IF A LINE IS IN NO CONDITION GOING TO HAVE CAPACITY ABOVE A CERTAIN POINT, IT'D BE REALLY HELPFUL FOR THE LOAD TO KNOW THAT, NOT JUST WAIT TO SEE THAT EVERY DAY THEY'RE BEING CURTAILED AT SOME LEVEL. 'CAUSE YOU KIND OF GIVE THE IMPRESSION THAT, OH, YOU'LL HAVE A LOW CAP OF A HUNDRED MEGAWATTS AND THEN THE SKY'S THE LIMIT. BUT I KNOW THAT'S NOT THE TRUTH. WILL WE GET A SECOND NUMBER [00:50:02] FOR A RANGE? HEY, HEY BOB, THIS IS JEFF. SO, UM, YEAH, I THINK THE ANSWER TO THAT IS NO. UM, AND, AND I THINK THE REASON IS THAT THAT WOULD ADD, UM, STUDY COMPLEXITY THAT WE JUST DON'T HAVE TIME TO ANALYZE IN THE BATCH. SO MY, I THINK OFF OFF THE RECORD RECOMMENDATION IS THAT YOU, UM, RUN THAT ANALYSIS YOURSELF IN HOUSE OR HIRE A CONSULTANT THAT CAN DO THAT FOR YOU. BUT I, I THINK ERCOT, WE, YOU KNOW, WE, WE CAN'T STUDY THAT, THAT THAT WOULD BE A DIFFERENT SCENARIO FOR US TO STUDY KIND OF BEST CASE CONDITIONS. SO, SO JUST TRYING TO THINK ABOUT THIS IN ADVANCE. WHEN WE GET TO THE COMMITMENT PERIOD, AND I KNOW WHAT MY MINIMUM COMMITMENT IS, I WILL HAVE 30 DAYS TO DO THAT STUDY. 'CAUSE THAT'S THE FIRST TIME I KNOW WHAT ALL THE, AND WILL I KNOW ON THAT DAY ALL THE OTHER COMMITMENTS ON THAT LINE? OR IN OTHER WORDS, WILL SOMEBODY EPE OR SOMEBODY HAVE THE DATA TO BE ABLE TO DO A STUDY TO GIVE ME THAT ESTIMATE? 'CAUSE I THINK THE ANSWER'S NO, IT IS JUST SOMETHING TO THINK ABOUT. I'M NOT TRYING TO BE DIFFICULT, BUT I, I'M SEEING A CHALLENGE HERE YEP. UM, FOR MAKING THAT 30 DAY COMMITMENT DECISION WHEN I CAN'T FIGURE OUT THE ECONOMICS OF WHAT MY CEILING IS, RIGHT, OR, OR HOW, WHAT PERCENTAGE OF THE TIME I'LL HIT A CEILING OR, YOU KNOW, SOMETHING THAT HELPS ME MAKE THE ECONOMIC CHOICE TO COMMIT. SO IF YOU GUYS WILL HELP US THINK ABOUT HOW WE COULD, HOW WE COULD DO THAT AND, AND THE, AND AND BOB, I WILL SAY, I MEAN THE, THE CASES ARE, THE CASES WILL BE POSTED. YOU THINK ABOUT , THE CASES WILL BE POSTED THIS FALL. SO IF SOMEBODY WANTED TO RUN THAT ANALYSIS, THEY COULD, BUT AGAIN, YOU KNOW, OUR, IT JUST, WE, WE, UM, HAVE NOT CONTEMPLATED AND I DON'T HAVE THE TIME TO, TO DO AN 87 60 TYPE OF ANALYSIS AS PART OF BATCH ZERO. THAT'S IT. OR, OR, OR YOU KNOW, FRANKLY PROBABLY ANY BATCH. SO I, I THINK IF YOU WANT TO USE THIS CONSTRUCT, I I THINK THAT YOU, THAT THAT IS THE RISK THAT YOU HAVE TO KIND OF TAKE, TAKE ON AS THE DEVELOPER. OKAY. I I, I REALLY APPRECIATE IT. THESE ARE ALL IMPORTANT THINGS. AND THE, AND THE FINAL THING REAL QUICKLY, I JUST WANT TO SAY, I'M REALLY GLAD TO HEAR YOU SAY YOU'RE GONNA TREAT EVERYTHING AS FIRM BECAUSE THE LAST THING WE WANT IS FOR ACL R, SOMEBODY THAT OFFERS TO REGISTER A CLR TO BE TREATED AS SECOND CLASS. BUT I WANT YOU TO BE SURE IN, IN THE OPTIMIZATION STAGE, IF I WAS AN ALGORITHM TRYING TO OPTIMIZE THE AMOUNT OF CAPACITY THAT I BROUGHT ON THE GRID, I WOULD BRING ALL THE CLRS DOWN TO THEIR MINIMUM AND THEN I COULD GIVE OUT A LOT MORE CAPACITY TO OTHER PEOPLE THAT CAN'T HAPPEN. OR THERE'S NO INCENTIVE TO SIGN UP ACL R. SO DOES THAT MAKE SENSE? IT, IT DOES. AND OKAY. UM, YOU KNOW, AGAIN, TO TO REITERATE THE, THE OPTIMIZATION IN BATCH ZERO IS INTENDED TO ESTABLISH THE AMOUNT OF FIRM LOAD OR THE LOW, THE LOW LEVEL OF THE CLR THAT CAN BE SERVED. SO, BUT IT HAS TO ARRIVE AT THAT BY TREATING IT ALL THE SAME, ALL AS AND, AND I THINK YOU SAID THAT, AND EVEN THOUGH THAT'S THE INTENTION, SOMETIMES YOU BUILD AN OPTIMIZATION ENGINE, IF IT'S NOT REAL CLEAR LAID OUT BY THAT MODEL HOW IT DOES THAT, IT COULD END UP PICKING THOSE LOW LEVELS AS A WAY TO BRING IN MORE FIRM LOAD. I'M JUST SAYING THAT WOULD BE A WAY TO OPTIMIZE IT, BUT IT WOULDN'T BE FAIR. IT WOULDN'T BE RIGHT. SO ANYWAY, I JUST WANNA GO ON RECORD. THANK YOU VERY MUCH. THANKS BOB. ALRIGHT, BILL BARNES, THANKS GUYS FOR MOVING THIS UP THE AGENDA. IT'S GOOD TO START FRESH WITH THESE CONCEPTS. REALLY APPRECIATE IT. WE'RE GONNA PAY FOR IT. BUT YEAH, GO AHEAD . AND ALSO THANKS FOR ALL THE WORK ON THIS. I KNOW YOU GUYS ARE PUTTING IN A LOT OF HOURS, UM, REGARDING THE KIND OF ANCILLARY SERVICE PARTICIPATION OR NOT, HAS HAD THE SAME COMMENT HERE THAT I WILL FOR BYOG FOR BATCH ZERO, SOMETHING'S BETTER THAN NOTHING. WE WOULD MUCH RATHER HAVE A MORE NARROW ARRANGEMENT THAN HAVE NOTHING. SO APPRECIATE THE FLEXIBILITY ON THIS AG SLIDE 11. UM, AND BECAUSE WE, WE'VE KEPT GOING BACK AND FORTH ON THIS, I'M JUST WONDERING IF THERE'S MORE SPECIFIC DETAIL ON THE USE OF NON SYNCHRONOUS GENERATION LIKE BATTERIES TO OPERATE A CLR IN TERMS OF WHAT ERCOT WILL ACCEPT AS A DESIGN FOR THAT NON SYNCHRONOUS GENERATION. WILL IT HAVE TO BE BEHIND A DIRECT CURRENT BUS TRANSFER CHIP RELAYS? LIKE THAT INFORMATION WOULD BE HELPFUL SO THAT WE DON'T GET DOWN THE ROAD AND YOU'RE LIKE, WELL THIS ISN'T THIS, THAT'S NOT ACL R. I'M SORRY. SO IF THERE'S A, SOME MORE MEAT ON [00:55:01] THAT BONE, THAT WOULD BE VERY HELPFUL. UH, 'CAUSE I THINK WHEN WE THINK NON SYNCHRONOUS GENERATION, WE ALL HAVE IDEAS ON WHAT THAT MIGHT LOOK LIKE. THAT MIGHT NOT BE WHAT YOU GUYS ARE THINKING. SO, AND THEN PROVISIONAL CLR DOES, SHOULD WE READ INTO THE PROVISIONAL CLR CONCEPT, WHICH I, THIS ALL MAKES A LOT OF SENSE AND I THINK WORKS PRETTY WELL, BUT IS THERE AN OBLIGATION TO EVENTUALLY CONVERT TO A CLR AND WE REMOVE THE PROVISIONAL AND I'M THINKING ABOUT THE CASE WHERE YOU'RE GONNA BE SETTLED AT A NODAL PRICE AS ACL R. IS ERCOT GOING TO ENTERTAIN THE POSSIBILITY TO ACTUALLY THEN GO TURN THAT INTO A FIRM LOAD AND THEN CHANGE THE SETTLEMENT TO LOAD ZONE? YOU ARE. IS THAT IT? YES, TO ME IT'S, YES. YEAH, I THINK, UH, TO ME IT'S, YES. YEAH, AND I, I AGREE WITH CY. THE, THE INTENT IS AT THE END OF THE, THE EXIT DATE THAT IS DEFINED, IT IS UP TO THE, THE OWNER. WHAT THE, WHAT WHAT, WHETHER THEY WANT TO CONTINUE WITH A REGISTER REGISTRATION AS A CLR OR TO BECOME A FIRM LOAD THERE, THERE'S NO MORE RESTRICTION THAT WOULD SAY THAT. SO ONCE YOU GET ALL OF YOUR TRANSMISSION, YOU HAVE TO WAIT A WHILE, YOU'RE OPERATING AS A CLR TEMPORARILY, THEN YOU CAN CONVERT TO, I'M NOW ON FIRM LOAD AND, UM, CHANGE MY SETTLEMENT TREATMENT AND I LOOK DIFFERENT. YEAH. UH, WE, WE MAY NEED TO HAVE, SORRY, I'M, I'M JUST KIND OF BUTTING IN HERE. UM, WE MAY NEED TO THINK ABOUT THE NOTIFICATION PERIOD WHEN YOU PLAN TO BECOME A REGULAR LOAD. UH, AND THAT'S BECAUSE WITH 1188, ALL OF THESE CLRS WILL HAVE A RESOURCE NOTE FOR HEDGING PURPOSES AND WE NEED TO BE ABLE TO RETIRE THEM FOR THE CR AUCTION WELL IN ADVANCE KIND OF THING, YOU KNOW, AND THAT THERE IS A TWO YEAR WAITING PERIOD WHERE THAT RESOURCE NOTE JUST HANGS AROUND. UH, SO WE NEED TO COORDINATE THAT. OKAY. AND I ASKED THIS QUESTION A FEW WORKSHOPS AGO AND I DIDN'T REALLY GET A GREAT RESPONSE AND MAYBE YOU GUYS HAVE HAD MORE TIME TO THINK ABOUT IT. UM, WHAT IN OPERATIONS, WHAT WOULD ERCOT EXPECT TO HAPPEN IF THE CLR DOESN'T RESPOND? IT SOUNDED LIKE THERE WAS SOME MANUAL ACTION THAT WOULD HAPPEN TO OPEN THE BREAKER THERE. AND I DON'T KNOW, I WASN'T JUST CURIOUS HOW YOU THINK THAT WOULD WORK. I THINK OUR CONTROL ROOM WOULD DO WHATEVER IT DOES WHEN THINGS ARE GOING WRONG, WHETHER, WHETHER IT'S A WIND FARM, A LOAD, IT'S A TSP OPEN THE BREAKER YEAH. TYPE SCENARIO. AND THEN WE MAY HAVE WORDS IN HERE OR MAY NOT, BUT IS WHETHER OR NOT WE WOULD THEN DISQUALIFY THEM FROM THIS UNTIL THEY PROVE THEY'RE WAY BACK IN. YEP. OKAY. AND THAT'S, THAT'S CONSISTENT WITH OTHER, YOU KNOW, CLRS ON THE SYSTEM. IT IS A-P-C-L-R IS A CAPITAL R RESOURCE AND SO IT INHERITS ALL THE OBLIGATIONS THAT GO ALONG WITH THAT. OKAY, GREAT. UH, AND THEN I DID NOTICE, UH, ONE OF THE MODIFICATIONS BETWEEN EITHER VERSION ONE OR TWO AND THREE IS THERE WAS A COMMENT, UH, ON SLIDE 13 ABOUT NO DISTORTION AND THAT THERE'S A STATEMENT IN A BOX THAT SAID THAT, UH, THE, THAT BID CAPPING PROCESS WILL ENSURE THAT IT DOESN'T, UM, GET BEHIND A, A GENERATION OFFER. AND IT LOOKS LIKE YOU GUYS REMOVED THAT JUST 'CAUSE YOU CAN'T GUARANTEE THAT WILL HAPPEN. RIGHT. WE, WE CAN'T GUARANTEE THAT. SO THAT, THAT REALLY COMES UP WHEN YOU HAVE MULTIPLE CONSTRAINTS. YEP. SO WE ARE GOING FOR THE WORST CASE SCENARIO. SO IN THAT ONE IT WILL BE LAST IN LINE, JUST IN TIME, BUT FOR THE OTHER ONES IT MAY NOT BE. YEP. THAT'S WHAT I, THANKS FOR CONFIRMING THAT. RIGHT. APPRECIATE THE WORK ON THIS GUYS. THANKS. ALRIGHT, NEXT UP, UH, HARSH AG ON THIS SLIDE, AS YOU TALKED ABOUT IDENTIFYING LPC, WHICH IS THE FIRM LIMIT, YOU CAN, UH, THE AMOUNT OF LOAD YOU CAN SERVE. UM, AND THEN YOU TALKED ABOUT LOOKING AT THE MAXIMUM LOAD IN THE STABILITY STUDY, AND I ASSUME YOU WOULD DO THE SAME THING IN THE STEADY STATE STUDY, BUT THE OUTCOME OF THAT STUDY WOULD BE THE CEILING, RIGHT? THAT YOU, YOU WOULD NEED TO IDENTIFY MPC BEYOND WHICH YOU HAVE EITHER STABILITY OR VOLTAGE ISSUES. CAN YOU CONFIRM THAT THERE MAY BE FRED, DO YOU WANT TO, DO YOU WANNA SPEAK TO THAT? I, I WILL TRY. I JUST NEED HELP. UM, I THINK THE CONCEPT HERE IS, UH, ONCE WE KNOW THE LCP OR LPC, ONCE WE KNOW THE BASE LOAD AMOUNT, UH, THE REST OF THE PART WE WILL STILL ASSESS, CONSIDER IS POTENTIAL INITIAL FULL REQUEST NUMBER TO SEE AT WHAT POINT NOT NECESSARY ONLY THAT THE LOAD ESSENTIALLY IS THE WHOLE REGION OR THE STUDY AREA. AT WHAT POINT WE COULD SEE THE INSTABILITY AS THE CONCEPT. FOR NOW, WE ARE THINKING [01:00:02] THAT, THAT THE OUTCOME IS GOING TO PROVIDE, UH, INFORMATION, UM, WHEN WE MAY ESTABLISH THAT AS A POTENTIAL CONSTRAINT OR OPERATION MEDICATION. CURRENT THINKING IS GO THROUGH THE QSA, SO THE PAGE ZERO WILL PROVIDE YOU A BASE LOAD ALLOCATED NUMBER AND UH, WILL PROVIDE INFORMATION ON AT WHAT POINT THAT THE COMPARABLE LOAD AMOUNT, IF EXCEEDED SOME LABEL LIKELY COULD SEE THE INSTABILITY. BUT WE ALSO TRY TO CONSIDER ALL THE TIMING, ALL THE, AND ALL THE KIND OF SEQUENCE. SO THE THINKING RIGHT NOW IS ONCE THE PROJECT ACTUALLY MOVE FORWARD, ANOTHER GATEKEEPER IS QSA, WHICH IS VERY, IS MUCH CLOSER TO THE ACTUAL IN INITIAL ENERGIZATION. THEN WE'LL TAKE A LOT OF OPPORTUNITY TO COLLECT ALL THE INFORMATION TOGETHER THROUGH THE QSA, IDENTIFY WHAT IS THE ACTUAL CONSTRAINT WE NEED TO IMPOSE. AND THEN THAT'S THE, AGAIN, IT'S A CONCEPT AND AGAIN, AS PART OF 1 45 RIGHT NOW, AND I DON'T KNOW IF OTHER PEOPLE WANT TO WEIGH IN THAT, I'LL JUST ADD YEAH, THAT, YEAH, I THINK THE, UM, THE, THE, UM, I AGREE WITH EVERYTHING, EVERYTHING THAT FRED SAID, UM, BUT WE WOULD HANDLE THAT BY IMPOSING A GTC AND, AND THAT WAY SC CAN MANAGE THAT. OKAY. SO THAT GTC THEN MA COULD ESSENTIALLY BE THE MPC, THE GTL OF THAT? IS THAT HOW YOU WOULD LOOK AT THAT? THE, THE OR THE LOAD WITH GT, THE GTC ESTABLISHES WHAT THE, UM, IT, IT, IT'S EFFECTIVELY A SYSTEM OPERATING LIMIT IN OPERATIONS. UM, SO IF THE LOAD, UM, GOES, UH, ABOVE THE, THE LPC, THEN IF, IF THERE'S A LIMIT THAT'S, YOU KNOW, SOMEWHERE ABOVE THAT, THEN WE'LL HAVE A GTC AND, AND SCHEDULE USE THAT TO, UM, MANAGE THAT. OKAY. AND, AND IN THE STEADY STATE STUDY, WOULD YOU IDENTIFY VOLTAGE ISSUES? AND I ASSUME YOU WOULD JUST IGNORE THOSE AND QSA WILL BE THE ONLY VENUE WHERE YOU IDENTIFY ANY KIND OF ISSUES WITH VOLTAGE, EVEN THOUGH IT MAY NOT BE A FULL BLOWN STABILITY ISSUE. IF IT'S PURELY JUST A VOLTAGE VIOLATION THAT SCAT CANNOT HANDLE, WOULD YOU STILL RELY ON QSA TO IDENTIFY THOSE KIND OF ISSUES? UM, AND AND WHERE I'M GOING FOR WITH THIS QUESTION IS THAT, I MEAN, I FEEL LIKE THERE HAS TO BE A CEILING. I MEAN, I HOPE IT CANNOT BE 2000 MEGAWATTS, YOU KNOW, LIKE THERE HAS TO BE A STUDY THAT SHOWS THAT THERE ARE NO VOLTAGE ISSUES OR STABILITY ISSUES BEFORE YOU JUST LET CLR CONSUME TO THAT AMOUNT. I UNDERSTAND QSA WILL BE A MEASURE, BUT I JUST WANNA MAKE SURE THAT YOU WOULD CAPTURE EE EVERYTHING THAT THAT LOAD MAIN POSE THE RISKS. YEAH, I, I WAS THANKFUL THE COMMENT, UM, TO YOUR FIRST QUESTION, UM, ALL THE RELIABILITY CRITERIA INCLUDING THERMAL AND THE VOLTAGE WILL STILL BE CONSIDERED IN A STEADY STATE ANALYSIS. IT JUST MAY NOT BE THE STABILITY CRITERIA, BUT ALL STEADY STATE VOLTAGE AND THE THERMAL APPLICABLE CRITERIA WILL STILL BE, UH, INCLUDED WHEN WE DO THE STATISTIC FOR THE DYNAMIC, THE EXPECTED OUTCOME OF OUT OF THE PAGE IS, ALTHOUGH WE MAY NOT CONSIDER THE SITTING AS YOUR POINT OUT THE PAGE ZERO, BUT WE WILL PROVIDE THE INFORMATION SO AS PART OF THE PAGE ZERO, SO YOU GET A BETTER IDEA TO USE YOUR POTENTIALLY STREAMING CASE, A COUPLE GIGAWATT LOAD, MAYBE GRANTED FOR I JUST SAY 100 MEGAWATT AS BASE LOAD, THE RISK OF CAN BE CONTROLLABLE LOAD AND THEN STABILITY MAY IDENTIFY WE TOUCH 500 MEGAWATT, THEN WE SEE THE INSTABILITY. LIKE THE 500 MEGAWATT INFORMATION WILL BE PROVIDED AS PART, PART OF THE PAGE ZERO AS INFORMATION KIND OF, UM, FOR, I WOULD SAY THE DEVELOPER TO UNDERSTAND EVEN YOU ARE PROPOSING COUPLE GIGAWATT, BUT LAYER IS A 500 MEGAWATT PER IDENTIFY IN THE PAGE ZERO AS A POTENTIAL INSTABILITY UH, CONSTRAINT. OKAY. JUST ONE LAST COMMENT I'LL MAKE IS, IF YOU ARE GOING TO LOOK AT ALL CONTINGENCIES AND LOOK AT ALL CRITERIA VIOLATIONS, THEN WOULD IT BE HARD TO JUST LOOK AT WHAT ARE THE VOLTAGE VIOLATIONS? AND IF YOU IDENTIFIED PROJECTS TO RESOLVE THE VOLTAGE VIOLATION, [01:05:01] YOU'LL ALSO KNOW WHAT, WHAT THAT NU MEGAWATT NUMBER IS, BEYOND WHICH YOU HAVE THE ISSUE AND MAKE THAT YOUR MPC. 'CAUSE THAT WAY THEY'LL AVOID THAT CONFUSION OF WHAT IS THE MPC, WHAT'S THE CEILING, AND, AND YOU'LL KNOW THAT WAY BEFORE QSA, BUT, UM, THAT, THAT'S ALL I HAVE. THANK YOU. YOU FOR THE STEADY STATE, I THINK WE, WE WILL STILL FOLLOW THE VOLTAGE CRITERIA AND SIMILARLY WE WILL IDENTIFY WHAT THE NEEDED TRANSMISSION FEASIBLE UPGRADE TO ADDRESS THAT ONE, TO BUMP TO THE ADDITIONAL NUMBER FOR THE BASE LOAD, MAYBE THE FUTURE YEARS. ALL THIS CAN BE JUST LIKE A WILL. THEY ARE LIKELY TREATED BY THE THERMAL CONSTRAINT AND IDENTIFY THE ASSOCIATED SYSTEM NEED Y YOU KNOW, I AGREE WITH THERMAL CONSTRAINTS, YOU'LL BUMP IT UP AS YOU BUILD THE PROJECTS, BUT, AND YOU CAN MANAGE THE IN REAL TIME, ANY THERMAL ISSUES, VOLTAGE, YOU CANNOT, SO I'M SAYING FOR VOLTAGE, YOU REALLY JUST HAVE TO CAP THEM TO WHATEVER THAT NUMBER IS. YOU CANNOT LET 'EM RUN LIKE THERMAL CONSTRAINTS. YOU COULD, YEAH. SO HARSH. I THINK THE CHALLENGE IS, YOU KNOW, WE'RE, WE'RE STUDYING A WORST CASE, SO YOUR VOLTAGE IS GONNA BE WORST CASE AT SUMMER PEAK. UM, IT, IT, IT MAY BE DAYS LIKE TODAY THAT, THAT THAT'S NOT A CONSTRAINT. AND, AND SO I, I THINK WHERE WE'RE TRYING TO GET TO IS OKAY, WOULDN'T, WOULDN'T WANT TO LIMIT IN ON, UH, YOU KNOW, IN APRIL DAY WHEN YOU KNOW THE LOAD'S NOT THAT HIGH AND, AND VOLTAGE ISSUES AREN'T THERE. AND SO THEY COULD CONSUME A LOT MORE. UM, I, I HEAR WHAT YOU'RE SAYING. UH, I I THINK WE WE'RE, WE, THE WAY THAT WE HAVE BEEN THINKING ABOUT THAT IS THAT THAT'S MAY BE GTC EVEN IF IT'S A STEADY STATE VOLTAGE ISSUE. UM, BUT WE ALSO ARE CONSCIOUS, YOU KNOW, OUR OPERATIONS, YOU KNOW, CONTROL ROOM DOESN'T WANT, YOU KNOW, 50 MORE GTCS TO HANDLE THOSE KINDS OF THINGS. AND SO WE'RE, WE ARE THINKING ABOUT THAT. THANK YOU. ALRIGHT, JIRGA, THANK YOU. UM, DURGA FROM SOFTBANK ENERGY, UM, MY FIRST QUESTION IS, I'M REFERRING TO THE LAST, UH, BATCH STUDY THAT, UM, BATCH MEETING THAT WE DID. SO THE CLRS, WHICH HAVE NEGATIVE SHIFT FACTORS, UM, THEY WOULD HAVE BIG CAPS, RIGHT? SO HOW WOULD THE CLRS, WHICH HAVE POSITIVE SHIFT FACTORS ON THE, ON THE CONSTRAINTS, HOW WOULD THEY BE HANDLED DYNAMICALLY IN OPERATION? SORRY, UH, THE, SO LET'S, LET'S TAKE A SCENARIO WHERE THERE'S ONLY ONE CONSTRAINT AND ONCE PROVISIONAL CLR HAS A NEGATIVE SHIFT FACTOR AND THE OTHER PROVISIONAL CLR HAS A POSITIVE SHIFT FACTOR FOR THE ONE WITH THE POSITIVE SHIFT FACTOR, THEY WILL NOT BE ANY BIT CAPPING PROCESS. THE ONE WITH THE NEGATIVE SHIFT FACTOR WILL HAVE A BIT CAPPING PROCESS. YEAH. THAT ALIGNS WITH MY UNDERSTANDING. BUT, UM, THE ONES WHICH ARE ACTUALLY AGGRAVATING THE SITUATION, UM, THEY'RE NOT BEING REPRIMANDED, RIGHT? THE ONES WHICH ARE ACTUALLY SOLVING THE SITUATION ARE BEING REPRIMANDED. UM, I THINK THERE SHOULD BE A MORE, UH, BALANCED APPROACH TO THIS AND WE SHOULD ALSO HAVE THE ONES WHICH POSITIVE FIT FACTORS BE REPRIMANDED AS WELL. SO IT'S MORE BALANCED. HOW WOULD WE DISPATCH A CLR UP? WE'RE GONNA LOOK AT THEIR ECONOMIC SIGNAL AND IF THE PRICE IS RIGHT, WE'LL TAKE 'EM ALL THE WAY TO THE TOP. SO I DON'T UNDERSTAND A REBALANCE. YEAH, I, I I DON'T, I DON'T UNDERSTAND THAT EITHER. A POSITIVE SHIFT FACTOR IS SAYING THAT THE MORE YOU CONSUME, THE BETTER IT IS FOR MANAGING THE CONSTRUCTION, UM, CONGESTION FOR ACL R. SO ARE YOU SAYING THAT WE PUT A, WE REDUCED THERE? YEAH, YEAH, THAT'S FINE. YEAH, I'M SAYING WE SHOULD HAVE, IF WE, YOU'RE CAPPING THE BIT BIT, UH, FOR THE NEGATIVE SHIFT FACTORS, THEN WE SHOULD ALSO BE ALLOWING REDUCTION OF THE DISPATCH FOR THE POSITIVE SHIFT FACTORS. ONE, IT'S NOT REDUCTION OF DISPATCH, I MEAN THE WHOLE PURPOSE IS CLRS. THEY'RE CURTAILING FOR THE ONES WITH THE NEGATIVE SHIP FACTORS. WHAT YOU'RE SAYING FOR THE CLRS WITH POSITIVE SHIP FACTORS IS YOU'RE ASKING THEM TO INCREASE CONSUMPTION, BUT GENERALLY IF THIS PROVISIONAL CLRS ARE, ARE CONSUMING AS MUCH AS THEY CAN, THEY'RE ALREADY AT THE TOP LEVEL. SO THERE IS NO POINT IN COMPLICATING THE SYSTEM. SO THE ONE WITH THE POSITIVES FACTOR, IF THEY DISPATCH, IT'S AGGRAVATING THE SITUATION, RIGHT? NO, IF THEY INCREASE THEIR CONSUMPTION, THEY'RE HELPING THE SITUATION AND OH, THAT'S THE DEFINITION. OKAY. YEAH. OKAY. OKAY. UNDERSTOOD. UM, UM, THE SECOND QUESTION IS ON THE IE SIGNED AMOUNT, UH, FOR THE CLS, UH, CAN, CAN SOMEONE EXPLAIN, HOW WOULD THAT WORK? LET'S SAY I'M APPLYING FOR A 500 MEGAWATT AND THEN ONLY A HUNDRED MEGAWATT GETS APPROVED, UH, AS A-P-C-L-R THEN GOING INTO [01:10:01] THE IA PHASE, DO I PROVIDE 500 TIMES 50 K OR, UH, A HUNDRED TIMES 50 K? HOW DOES THAT WORK? HEY, CHRISTINA, BEFORE YOU, BEFORE YOU ANSWER IT, LET ME JUST REITERATE. UM, THE, THE, I I REALIZE IT'S NOT CLEAR IN THE SLIDES, IT WAS CLEAR IN LAST WORKSHOP SLIDES, BUT I WANNA REITERATE THE STRUCTURE OF THE PCLR CONCEPT AND REVISION REQUESTS IS THAT TRANSMISSION IS ULTIMATELY BUILT TO SERVE THE FULL REQUESTED LOAD AMOUNT. STILL, THIS IS A MECHANISM TO ALLOW MORE OF THOSE MEGAWATTS TO CONNECT TO THE SYSTEM AND CONSUME IN MOST CASES SOONER. AND SO, UM, ULTIMATELY THOUGH THE, THE TRANSMISSION PLAN WOULD STILL BUILD THE FULL, SERVE, THE FULL 500 MEGAWATT REQUEST, AND THAT WOULD ALSO BE HOW WE WOULD DETERMINE THE EXIT DATE FOR THE PCLR. SO, UH, FROM THERE, I'LL LET CHRISTINA ANSWER THE REST OF THE QUESTION. CHRISTINA SWITZER COUNSEL FOR ERCOT, IT'S WHAT AGE YOU SAID, UH, THAT THAT'S THE RATIONALE THAT YOU WOULD USE THE CONTRACTED PEAK DEMAND IN YOUR IA TO DETERMINE THE AMOUNT FOR SECURITY. SO WHAT YOU, WHAT THE PCLR ATTESTATION THAT YOU SEE, UM, IN THE LANGUAGE IN THE REVISION, OR WHAT WILL BE COMMENTS THAT'S SEPARATE FROM WHAT YOU'RE DOING FOR YOUR IA, WHICH IS BASED ON YOUR ACTUAL CONTRACTED FOUR PEAK DEMAND? THANK YOU. UM, HOW WOULD THESE BIG GAPS BE CONVEYED IN REAL TIME? LIKE HOW FREQUENTLY? EVERY 15 MINUTES OR WHAT'S THE, EVERY SKID RUN EVERY 15 MINUTES, FIVE MINUTES? EVERY FIVE MINUTES. FIVE MINUTES, OKAY. AND, AND THE IAS THAT WE SIGN WOULD HAVE EXIT PLANS FOR THE CLRS. THAT'S, IS THAT IN THE CONTRACT PIECE? WE TALK ABOUT IT SAYING IN EFFECT UNTIL YOU'RE OUT OF THIS BRIDGE. SO THE IDEA OF PROVISION, I, I WOULD SAY MAYBE LET'S, LET'S HOLD THAT QUESTION TILL WE GO THROUGH THE ACTUAL AGREEMENT LANGUAGE. UM, I THINK THAT'LL BE ANSWERED THERE. OKAY. LAST TWO QUESTION. OKAY, LAST ONE. WE GOTTA A LOT TO GET THROUGH STILL. YEAH. SO WHAT'S THE RAMP RATE THAT IS EXPECTED OF THE C LRS AND HAS THIS BEEN DISCUSSED WITH THE CHIP MANUFACTURER AS IN WHAT THEY CAN DO OR CAN DO? SO, UM, I I I THINK WE'VE ALREADY, UH, ON THE SIDELINES HERE FLAGGED THIS AS A TOPIC THAT NEEDS ADDITIONAL INTERNAL DISCUSSION. CERTAINLY ERCOT, YOU KNOW, WOULD HAVE A CONCERN WITH A VERY, VERY LOW RAMP RATE THAT EFFECTIVELY DOES NOT ALLOW THE, THE PCLR TO REALLY BE MOVED IN ANY SERIOUS WAY BY SCED. SO, UM, AT THE MOMENT WE DON'T HAVE A DEFINED ANSWER ON WHAT WOULD BE, UH, YOU KNOW, REQUIRED RAMP RATE FOR FOR PCLR, BUT, UM, IT'S SOMETHING WE'LL BE DISCUSSING AND IT SOUNDS LIKE S HAS MORE TO ADD. THANK YOU. ALRIGHT, SO EVERY RESOURCE HAS GOT A RAMP RATE UP AND A RAMP RATE DOWN TELE TO ERCOT FOR ACL R. IT'S KIND OF THE, THE USAGE IS REVERSED THAN A GENERATION RESOURCE. A RAMP RATE UP MEANS HOW FAST CAN YOU INCREASE CONSUMPTION, THAT VALUE YOU ARE ABLE TO PLAY AROUND WITH IN REAL TIME TO MATCH HOW QUICKLY YOU CAN INCREASE YOUR CONSUMPTION, ESPECIALLY AFTER YOU'RE CURTAILED. BUT THE RAMP RATE DOWN, WHICH IS WHAT WE USED TO, UM, CURTAIL THE CLR, THAT CAN BE A VERY LOW NUMBER. I MEAN, IF YOU'RE, IF YOU'RE CONSUMING AT 500 MEGAWATTS AND YOUR LPC IS A HUNDRED, WE HAVEN'T DETERMINED THAT YET, BUT WE WOULD EXPECT THAT AT LEAST IN A COUPLE OF SCHEDULED RUNS, YOU SHOULD BE ABLE TO GO DOWN FROM 500 DOWN TO A HUNDRED MEGAWATTS. YOU CAN'T TAKE TWO HOURS TO GO DOWN THERE BECAUSE THEN WE ARE TO BURN DOWN THE LINE. SO THERE WILL BE SOME RESTRICTIONS. I MEAN, WE, WE NEED TO MAKE SURE THAT IF YOU WANT TO BE QUALIFIED, YOUR RAMP RATE DOWN HAS TO BE ABOVE A CERTAIN LEVEL. ALRIGHT. AND THIS MAY BE A GOOD TIME TO GO AHEAD AND DO A BIT OF A DEEP DIVE ON THIS SLIDE. YEAH, I, I WAS THINKING THAT WE COME BACK TO THIS LATER, BUT SOME OF THE QUESTIONS ARE HITTING IT. SO I'M GONNA, I'M GONNA TURN THE MIC OVER TO, TO RYAN WHO'S GONNA TALK US THROUGH THE, THE BID CAPPING PROCESS AND THEN WE'LL, WE'LL OPEN THE QUEUE BACK UP. CAN I ASK TWO QUICK QUESTIONS SINCE I'M NEXT TO THE QUEUE? COULD WE, I UNDERSTAND, BUT I WANT TO FINISH. THIS GOES TO RAMP RATES AND EVERYTHING ELSE, YOU'LL STILL BE NEXT IN THE QUEUE. OKAY, THANKS. WE'D LIKE TO TALK THROUGH IT. ALRIGHT, THANKS VERY MUCH. UH, RYAN KING WITH ERCOT. SO THIS IS PROBABLY A GOOD TIME TO JUST ILLUSTRATE HOW THIS, UH, PROCESS IS AN ENVISION TO WORK. SO THERE ARE REALLY, UH, THREE COMPONENTS OF THIS, UH, ADJUSTED BID CAP OR A BC, KIND OF LIKE THAT ACRONYM. UM, THERE IS WHAT HAPPENS IN THE PREVIOUS SCED RUN, AND THERE'S SOMETHING THAT HAPPENS IN THE CURRENT SCED RUN. SO THE FIRST COMPONENT IS THIS SHADOW PRICE THRESHOLD. SO AFTER EACH SCED RUN, THERE'S GOING TO BE A LIST OF CONSTRAINTS THAT MEET THIS SHADOW PRICE [01:15:01] THRESHOLD. AND SO WHAT YOU SEE IN THE FIRST COLUMN ON THE LEFT HERE IS THAT THE LIST WILL BE BASED ON CONSTRAINTS THROUGH SHADOW PRICE IS APPROACHING ITS MAX SHADOW PRICE, OR 90% OR GREATER OF ITS MAX SHADOW PRICE. SO THAT'S LIST ONE. THEN IN THE CURRENT SCED, THERE'S GOING TO BE A GENERATION OF, OF ACTIVE CONSTRAINTS IN SC AND WHERE THOSE TWO CONSTRAINTS MATCH. SO WHERE THEY ARE, ARE BOTH APPROACHING THEIR MAX IN THE PREVIOUS SC AND IN THE CURRENT SC THAT WILL NOW BE THE MATCH LIST OF CONSTRAINTS THAT WE WILL USE TO DETERMINE WHERE THE PROVISIONAL CLR CAN HELP RESOLVE THAT CONSTRAINT. AND SO BEFORE THE STEP TWO PROCESS, WE WILL LOOK AT, UH, ALL OF THOSE MATCHED CONSTRAINTS AND EVALUATE WHERE A PROVISIONAL CLR HAS A SHIFT FACTOR OF, UH, UH, HELPING SHIFT FACTOR OF 2% OR MORE. AND WHERE THEY DO HAVE THAT, THAT'S WHERE THIS BID CAP WILL BE APPLIED. AND THEN THE ADJUSTED BID CAP IS BASED ON THE FORMULA THAT'S AT THE BOTTOM HERE. WE WILL TAKE, UH, STEP ONE SYSTEM LAMBDA, AND THEN WE WILL EVALUATE ALL OF THOSE CONSTRAINTS. WE WILL TAKE THE, YOU HAVE TO THE, THE SIGNS KIND OF MOVE AROUND HERE, BUT BASICALLY WE'LL TAKE THE MINIMUM OF ALL THOSE CONSTRAINTS LESS, UH, PENNY. AND BASICALLY THAT IS THE, THE, THE HIGHEST BID THAT WILL JUST ALLOW, UH, SCED TO RESOLVE THAT CONSTRAINT. NOW I DO WANT TO BE JUST REITERATE SOMETHING THAT I BELIEVE BILL NOTED AND SAI EXPRESSED AS WELL. WE DID HAVE SOME COMMENTS HERE AROUND THIS ALWAYS BEING LAST IN LINE. IN A SENSE IT IS LAST IN LINE, BUT IT'S DEPENDENT ON THE INDIVIDUAL CONSTRAINT. SO WHERE THERE ARE MULTIPLE CONSTRAINTS WHERE ONE HAS A HIGHER SHADOW PRICE CAP THAN THE OTHER, WE'RE TAKING THE MINIMUM. AND SO WE, WE KIND OF WANTED TO BE A LITTLE BIT, UM, LESS DEFINITIVE ON THAT SENSE, BUT I THINK THE SPIRIT OF THAT DOES REFLECT THAT. SO IT, IT DOES ATTEMPT TO ENSURE THAT IF SOMETHING WASN'T RESOLVED IN THE PREVIOUS SC AND IS REMAINING IN THE CURRENT ONE, THEN WE WILL SAY, OKAY, WE'RE GOING TO EVALUATE THIS, THIS DYNAMIC BID CAPPING. SO I'LL PAUSE THERE AND SEE IF THERE ARE ANY, ANY QUESTIONS AROUND THAT. ALL RIGHT, THANKS RYAN FOR THE CLARIFICATION. ALL RIGHT, SO KEEP WORKING THROUGH. I WANNA GIVE THIS ABOUT 15 MORE MINUTES AND WE'RE GONNA NEED TO PIVOT INTO THE LANGUAGE AT SOME POINT. SO WE'LL SEE HOW FAR WE GET THROUGH THE QUEUE. SO KEVIN, AND THEN EIGHT MORE PEOPLE. THANK YOU. UH, KEVIN HANSEN AND VERJEE. MY QUESTION IS, IF I HAVE A BEHIND A METER GENERATOR, CAN I CHANGE MY LPC EVERY FIVE MINUTES? I'M SORRY, JUST TO CLARIFY, YOU, YOU SAID A I GOT A BEHIND MIRROR GENERATOR, RIGHT? YEAH. SO IT'S, I GOT 500 MEGAWATTS AND A THOUSAND MEGAWATT LOAD UHHUH , AND THE LOAD HAS REGISTERED AS A LOAD REGISTERS A THOUSAND MEGAWATTS PCLR, BUT SOMETIMES IT MIGHT HAVE THE GENERATOR ON 500 MEGAWATTS OR MAYBE ZERO. CAN I, OR SOME VARIATION. CAN I CHANGE MY LPC EVERY FIVE MINUTES? YEAH, NO, NO, YOU CAN'T BECAUSE WITH 1188, THIS IS NOT, THIS IS NOT LIKE A REGULAR LOAD THAT YOU NETTED OUT WITH THE GENERATION. THE CLR WILL BE METERED SEPARATELY AND IT'LL BE SETTLED AT A NOLE PRICE. SO IT'S KIND OF LOOKING LIKE FRONT OF THE METER. SO LPC, YOU CAN LOAD IT BEHIND BELOW YOUR FIRM LOAD ALLOCATION, BUT YOU CAN GO ABOVE YOUR FORMULA ALLOCATION AND YOU CANNOT NET IT WITH THE GENERATION. OKAY. IF IT'S REGISTER. YEAH. WHAT IF I HAVE A GENERATOR ONE BUSLE AWAY? IS THERE SOME WAY WE CAN THINK THROUGH THE LOGIC TO SAY NOPE? NOPE, NOPE. OKAY. THANK YOU. ALL RIGHT, THANK YOU. ALRIGHT, NEXT UP, UH, LEAD BRATCHER, LEAD BRANCHER CIPHER DIGITAL. UH, UM, FIRST OFF, I THINK THIS IS A GREAT CONCEPT, THANK YOU TO ERCOT FOR ALL THE WORK ON THIS. IT'S PERFECTLY REASONABLE TO EXPECT THE LOAD TO WEAR THE, UM, ECONOMIC RISK OF HOW MANY, YOU KNOW, CLR MEGAWATTS THEY'RE GONNA TRY TO PURSUE AT THAT SITE. SO I THINK THAT'S A PERSONAL PERFECTLY REASONABLE CONCEPT. AND JUST TO CONFIRM WHAT I HEARD EARLIER, UM, YOU, YOU WILL HAVE TO DETERMINE HOW MANY MEGAWATTS YOU'RE PURSUING FOR THE 5 8 4 8 1 SECURITY DEPOSIT. SO IF YOU GET A HUNDRED MEGAWATTS FIRM AND YOU PURSUE ANOTHER A HUNDRED MEGAWATTS, UM, AS A-P-C-L-R, THEN YOU HAVE OBLIGATIONS TO PAY $50,000 PER MEGAWATT FOR THAT ENTIRE SET. OKAY? SEEMS REASONABLE. OBJECTION. THAT'S THE TOTAL STUDY LOAD REQUESTED, WHICH IS THE BIG ONE, THE TOP NUMBER, YES. [01:20:01] NO DISCOUNTS FOR CLRS AT A LOWER LEVEL. I'M NOT A LAWYER. OKAY. NEXT, UH, IS, UH, NED ALL RIGHT, THIS IS GONNA BE A, UH, BEATING THE DEAD HORSE QUESTION, BUT I, I WANNA MAKE SURE THAT I, I'VE GOT THIS STRAIGHT AND I, I'LL TRY TO MAKE IT SIMPLE. UM, I THINK, YOU KNOW, JEFF, WHEN, WHEN YOU WERE UPDATING THE COMMISSION LAST WEEK, UH, THE TAKEAWAY WAS THAT THE PCLR WOULD BE A LOAD ONLY CLR, BUT I'M HEARING A LOT OF DISCUSSION NOW ABOUT POTENTIALLY HAVING BATTERIES OR GENERATION IN A NON SYNCHRONOUS, UH, UH, SUPPORT FUNCTION. AND BILL HAD SOME GOOD QUESTIONS ABOUT WHAT THAT LOOKS LIKE. SO I WANTED TO JUST ASK THE DUMB QUESTION, IS THAT IN SCOPE OR IS THAT, UH, TBD KIND OF AS WE WORK OUT WHAT SOME OF THOSE DETAILS LOOK LIKE? HOW, HOW LOAD ONLY IS LOAD ONLY? YEAH, I, I THINK IT IF, UM, YOUR, UM, MECHANISM FOR ACHIEVING THAT IS, UM, SOMETHING THAT ERCOT DOESN'T SEE, SO IF YOU FLIP OVER TO BACKUP GENERATION, UM, THEN I, I THINK THAT THAT'S OKAY. UH, IT, IT, IT'S, UH, WHERE, WHERE WE HAVE ISSUES IS WHEN IT SYNCHRONOUSLY OR CONNECTING THE BATTERY OR GENERATOR, THEN THAT HAS IMPACTS ON THE GRID. UM, AND, AND, AND SO WE HAVE TO ANALYZE THAT. AND I THINK THAT'S FOR BATCH ZERO, I THINK THAT'S OUT OF SCOPE. I, I THINK, YOU KNOW, AGAIN, ON ONGOING BATCH, WE ARE, WE'RE CERTAINLY OPEN TO THAT CONCEPT, BUT, UM, SO AS LONG AS IT IS SOMETHING THAT QUOTE UNQUOTE ERCOT DOESN'T SEE, THEN I THINK WE'RE THAT'S OKAY. UM, BUT I THINK WE, WE TOOK AN ACTION ITEM THAT WE NEED TO MAYBE COME BACK AND CLARIFY, YOU KNOW, WHAT, WHAT DOES THAT MEAN? AND, AND I'M NOT SURE IF, IF WE CAN DEFINE THAT ENTIRE UNIVERSE, IT, IT MAY BE THAT YOU HAVE TO COME TALK TO US AND, AND WE'LL TELL YOU. BUT YOU, WE'LL, WE'LL, WE'LL TAKE THAT BACK AND WE'LL THINK ABOUT THAT. OKAY. APPRECIATE THAT. THAT'S HELPFUL. IT SOUNDS LIKE MAYBE THERE'S SOME OTHER NUANCES TO WORK OUT, LIKE THE, THE QUESTION KEVIN HAD ON EXACTLY WHAT, WHAT THAT LOOKS LIKE IF IT'S NON SYNCHRONOUS, BUT STILL IMPACTS YOUR, YOUR LPC OR OTHER PARAMETERS. SO, UM, OKAY. I APPRECIATE THAT CLARITY. ALRIGHT, NEXT UP IS SHANE THOMAS. YEAH, THANK YOU. SHANE. THOMAS, MICHELLE, UM, WELL I SIGN, I I I'M GONNA GO AHEAD AND, AND SPEAK ON THIS A LITTLE BIT THAT THE CONCEPT WAS JUST, UH, A WE'LL BE A SHORT SPEECH. UH, OKAY. YEAH. OKAY. GO, GO AHEAD. LET'S GO. SO, UH, YOU KNOW, PREVIOUSLY I WAS, UH, YOU KNOW, INVOLVED IN THE, THE CLR PART AT A ERCOT. AND HISTORICALLY HOW THIS WOULD OPERATE IS THEY WOULD NOT ALLOW YOU, YOU KNOW, IF YOU'RE A CONTROLLABLE LOAD OR NON-CONTROLLABLE LOAD IN CLR OR CLR, YOU, THEY'RE ONLY EVALUATING THE RESPONSE OF THE LOAD. IF THAT LOAD GOES DOWN, YOU KNOW, MORE HISTORICALLY WITH N CLRS, WE, AND NOW IT'S IN AN ISLAND. ANYTHING, YOU CAN DO WHATEVER YOU WANT WITH IT AT THAT POINT, BRING UP A BACK GENERATOR OR WHATEVER HAPPENS A LOT IN THE, IN THE PROCESS. BUT IT HAS TO BE, THAT'S THE NUMBER YOU'RE GIVING FROM SC IN THIS POINT IS THE MAXIMUM AMOUNT OF SYNCHRONOUS LOAD YOU CAN HAVE AT THAT POINT, IF YOU WANNA THINK ABOUT IT THAT WAY. NOW, YOU KNOW, I'LL PUT THAT IN WITH THE CAVEAT THAT I WAS, YOU KNOW, LAST INVOLVED WITH CLRS MAYBE FOUR YEARS AGO. SO HISTORICALLY, THAT'S, THAT'S HOW THAT'S BEEN HANDLED. UM, I DID HAVE A QUESTION ON THE CLR CONCEPT HERE. UM, IN THAT IS THE, AND THEIR PARTICIPATION, THERE'S ANYTHING THAT I GUESS PRECLUDES THEM FROM SWITCHING FROM A-P-C-L-R TO A CLR AT ANY POINT IN THE PROCESS. BECAUSE I THINK IF YOU'RE GOING THROUGH AND LIKE MAYBE THEN THEY WANT TO TRY AND DO ANCILLARY SERVICES NOW THAT THEY'RE ALREADY HAVING TO GO WITH THIS PROCESS, THEY WOULDN'T BE ABLE TO SAY THEY ARE. BUT THEN ALSO ONCE YOU BECOME ACL R, THERE'S NO KIND OF, THE PROCESS FOR LEAVING A CLR IS A LOT DIFFERENT THAN LEAVING A-P-C-L-R. I THINK THAT'S KIND OF, YOU ARE HELD HOSTAGE IN THE PCLR CONSTRUCT UNTIL THERE'S ADEQUATE TRANSMISSION TO LET YOU FREE ROAM THROUGH THE WHOLE RANGE OF THE UNIT. OKAY. SO BECAUSE WE NEED SCD TO BE MANAGING THE CONSTRAINTS USING THE PCLR MECHANISM UNTIL THAT CONSTRAINT IS NO LONGER THERE. YEAH, AND I'LL JUST ADD TO THAT THE REASON FOR THAT IS FOR THE BID CAPPING METHODOLOGY THAT WE TALKED THROUGH, BUT ALSO, UM, I I DON'T BELIEVE WE CAN HAVE PART OF THE LOAD, YOU KNOW, IS WHAT YOU'RE REALLY ASKING. IF, YOU KNOW, HALF OF MY LOAD NOW HAS FIRM SERVICE IN YEAR THREE, FOR EXAMPLE, COULD THAT SOME OF THAT REMAIN A TRADITIONAL CLR? IS THAT, IS THAT WHAT YOU'RE ASKING? OR IS IT REALLY JUST COULD, COULD I DECIDE HALFWAY THROUGH I WANNA BE A CLR AND PROVIDE ANCILLARIES? YEAH, I GUESS MAYBE THAT'S A CONCEPT. NO, THE ANSWER TO THAT IS NO, BECAUSE WE'VE, WE'VE [01:25:01] STUDIED THIS LOAD AS A MECHANISM TO RESOLVE TRANSMISSION CONSTRAINTS AND THEREFORE IT HAS TO BE PART OF THIS BID CAPPING METHODOLOGY AS THIS PCLR. SO, OKAY. BECAUSE AS A CLR YOU WOULD THEN NOT HAVE, ERCOT WOULD LOSE CONTROL OVER THE LPC, I GUESS. RIGHT? I GUESS THAT'S, THAT'S THE ISSUE BECAUSE YOU'RE STILL, IF YOU REMAIN IN CONTROLLABLE LOAD, THEN YOU ERCOT STILL HAS CONTROL OVER IT. WELL, SO THIS, THIS WHOLE ANCILLARY SERVICE THING IS TOO MUCH SCOPE, WE CAN'T GET IT DONE FOR THE BOARD MEETING. YEAH. SO I'D LIKE TO LET THAT ONE DOWN. I'M NOT SAYING TO ADD, I'M JUST SAYING IS, IS THERE KIND OF THOUGHT AROUND THE PROCESS OF SWITCHING TO A CLR AT SOME POINT OR, AND I GUESS I'LL GO BACK TO WHAT WE SAID EARLY ON. THERE ARE ROOM FOR MARKET RULE CHANGES BEYOND THIS AND WE CAN START TO TALK ABOUT OFF RAMPING OR CONVERTING BACK TO FIRM LOAD AND ALL THOSE OPTIONS. WE'RE NOT GONNA SOLVE 'EM TODAY. OKAY. BUT, BUT YOU CAN ASK YOUR QUESTION, BUT I'M JUST GONNA, I DON'T WANNA SPEND TOO MUCH TIME ON THIS ONE. OKAY. AND THEN ON THE, THE BID CAPPING PROCESS, UM, THE, I THINK THE AUTOMATING IT IS POTENTIALLY, I KNOW THERE'S A, THERE'S AN NPRR 8 26 AROUND THE CAPPING OF 8 26 THAT HAS YET TO BE IMPLEMENTED. THAT WAS AROUND CAPPING THE BID PRO, CAPPING THE MITIGATED OFFER CAPS FOR RMR RESOURCES IN REAL TIME. UM, THAT'S YET TO BE IMPLEMENTED. AND I THINK THAT THAT HAS MAYBE AN IA OF EIGHT MONTHS, OF COURSE THAT WAS CREATED IN 2020, I DUNNO WHAT IT IS NOW, BUT THE, UH, UM, UH, IS THE THOUGHT, AND NOW WE'RE KIND OF GOING ON THE PROCESS DUE TO NPR 1315 THAT WE NEED TO HAVE A MANUAL PROCESS IN PLACE. IS THERE A THOUGHT THAT WE WOULD, MIGHT, IT MIGHT BE THAT A-A-A-P-C-L-R WOULDN'T BE ABLE TO BE IMPLEMENTED UNLESS WE HAVE THIS DYNAMIC MODELING OUR DYNAMIC MITIGATOR OFFER CAP PROCESS IN REAL TIME. OR IS THERE, CAN WE HAVE A MANUAL PROCESS THAT'S ESTABLISHED THAT WOULD MAYBE BE MORE CONSERVATIVE BECAUSE YOU'RE HAVING TO ACT AHEAD OF REAL TIME. UM, BUT A MANUAL PROCESS COULD BE IN PLACE, UM, TO MAKE SURE THAT THIS DOESN'T GET HELD UP BY A PROJECT TO IMPLEMENT TO CHANGE SCED SO THAT IT CAN DYNAMICALLY CHANGE THESE CAPS. I'M GOING TO UNPACK A LITTLE BIT, I'LL PASS IT BACK TO AG. WE HAVE A LINE OF SIGHT TO THIS SOLUTION THAT COULD BE IMPLEMENTED QUICKLY. 1180 EIGHTS COMING IN. WE HAVE THIS DRAFTED UP IN 1225. WE'RE GONNA LEVERAGE THAT AND LOCK AND LOAD ON IT. WE ALREADY HAVE A COST AS ESTIMATE, WE'RE READY. SO WE DON'T WANNA GO BACK AND REVISIT OR TALK ABOUT MANUAL ANYTHINGS AND WE'RE READY TO GO ON THIS. OKAY. SO WERE YOU EXPLORING AN OPTION IN CASE THIS DOESN'T WORK? YEAH, I JUST WANTED TO MAKE SURE THERE'S LINE OF SIGHT, LIKE YOU SAID, WE LIKE THIS TO GETTING THIS. OKAY. BECAUSE WITH THE OTHER ONE, YOU KNOW, IT NEVER MADE IT TO REAL TIME. SO I WAS A LITTLE WORRIED THAT WE DO ALL THIS WORK ON THIS CONCEPT AND THEN IT BE HELD UP BECAUSE ACTUALLY WE CAN'T PUT IT IN, WE DON'T HAVE THE OFFER CAP. YEAH, THAT NUMBER 8 26 SAYS IT'S HAD A COUPLE BIRTHDAYS OR PRE URI. OKAY, THANKS. UH, SO WE'RE GONNA TRY, WHERE ARE WE AT TIME CHECK. OKAY. WE'RE GONNA GIVE IT JUST A COUPLE MORE QUESTIONS AND WE'RE GONNA, MAY HAVE TO STOP THE QUEUE AND GET DIG IN. BLAKE KING. OKAY. I'VE, I'VE GOT A LITTLE SOAPBOX, BUT I'LL TRY TO BE QUICK. UM, SO, SO IT'S BEEN A WHILE SINCE MY ERCOT DAYS, BUT AS I RECALL, THERE WAS ALWAYS A PRETTY BIG BASIS BETWEEN PLANNING RELIABILITY AND OPS RELIABILITY IN THAT THEY DON'T REALLY TIE TOGETHER PERFECTLY. AND THERE'S SORT OF A RELIANCE ON THE MORE RESTRICTIVE PLANNING CRITERIA, UM, TO KIND OF HELP SPAN THE OPERATIONS MARGIN WHEN IT, WHEN IT GETS TIME TO REAL TIME. BUT MATERIAL DIFFERENCES STILL EXIST. AND LIKE, FOR EXAMPLE, CONSTRAINTS THAT BIND IN PLANNING MODELS, THEY AREN'T ALWAYS THE SAME CONSTRAINTS THAT ARE BINDING, BINDING IN REAL TIME. AND, YOU KNOW, I, I'VE KIND OF HAD LIKE A GROWING CONCERN ABOUT THIS. I GENERALLY LIKE THE CLR CONCEPT HERE AND WHAT YOU ALL HAVE PROVIDED, BUT THE CONVERSATION WITH HARSH THAT WAS HAD LIKE 20 MINUTES AGO TO 30 MINUTES AGO IS SORT OF, IT'S VERY INTERESTING TO ME. AND I, I ALSO SEE THIS AS A GAME THEORY THING WHERE YOU MAY HAVE A LOT OF BUYERS OF THIS PCLR CONCEPT, RIGHT? AND SO I HAVE A SORT OF GROWING CONCERN ABOUT THE COMBINATION OF THOSE FACTS, RIGHT? THAT A LOT OF FOLKS ARE INCENTIVIZED TO DO THIS AND THERE'S ALSO THIS SORT OF IMPLICIT BASIS OR BIAS THAT WE'VE ALWAYS HAD IN PLANNING. UH, SO I, I THINK THE SECURITY REQUIREMENTS SOLVE MY CONCERNS 'CAUSE INDUSTRY WILL HAVE TO DECIDE IF IT MAKES SENSE TO POST SECURITY FOR NON FIRM SERVICE THAT IS TIED TO SORT OF UNKNOWN OPERATIONAL CHARACTERISTICS. BUT DOES, DOES ERCOT HAVE A CONCERN THAT THE PLANNING MODELS ARE GONNA REWARD REAL-TIME CAPACITY THAT OPERATIONS JUST CAN'T HANDLE WITHOUT THE COMPLEXITY OF THIS GROWING EXPONENTIALLY? THAT'S SORT OF MY INTUITION. MY INTUITION IS THAT THERE NEEDS TO BE A BIG BUYER BEWARE ON THIS SERVICE FOR FOLKS THAT ARE, THAT ARE DOING IT. DO, DO YOU GUYS AGREE? LIKE, DOES ERCOT AGREE THAT [01:30:01] THIS HAS POTENTIAL TO GET COMPLEX FOR PEOPLE THAT ARE GOING DOWN THIS PATH? HEY BLAKE, THIS IS AG I'LL, I'LL, I'LL MAYBE MAKE TWO, TWO POINTS ON THIS. UM, SO THE FIRST IS, THIS IS NOT NON FIRM TRANSMISSION SERVICE. THIS IS A PATH FOR MORE MEGAWATTS TO CONNECT SOONER, BUT THE LANGUAGE IS STRUCTURED THAT THE BATCH ZERO REFINEMENT WILL HAVE A TRANSMISSION PLAN THAT SERVES THE ENTIRETY OF THE LOAD JUST AS IT WOULD FOR A FIRM SERVICE CUSTOMER. UM, WHAT IS DIFFERENT IS THAT AS A-P-C-L-R YOU, UH, WILL BE ALLOWED TO GO BEYOND THE AMOUNT THAT THE STUDY IS IDENTIFIED CAN BE SERVED AS FIRM IN EARLIER YEARS. UM, TO THAT SECOND POINT, UH, ERCOT, YOU, I KNOW WE'VE HEARD SOME COMMENTS HERE, YOU KNOW, ASKING IF ERCOT WILL BE ABLE TO GIVE ANY VISIBILITY INTO, UM, YOU KNOW, HOW MUCH IS REALISTIC FOR THAT PC TO ACTUALLY BE ABLE TO CONSUME IN REAL TIME. I THINK JEFF'S ALREADY ARTICULATED THE CHALLENGES WITH THAT IN, IN THE TIMEFRAME OF THE ZERO STUDY. UM, SO, SO I WOULD SAY, YOU KNOW, THAT ERCOT IS NOT MAKING ANY GUARANTEES THAT, UM, ANY ADDITIONAL MEGAWATTS WILL BE AVAILABLE FULL-TIME, UH, KIND OF BY IMPLICITLY, YOU KNOW, MAY MAY NOT BE FULL-TIME. BUT, UM, WE, WE JUST DON'T HAVE THE BANDWIDTH IN THAT STUDY TO BE ABLE TO GIVE THE CUSTOMER A VIEW ON WHAT THEY CAN EXPECT EVERY HOUR OF THE YEAR IN TERMS OF BEING WHAT THEY'RE ABLE TO CONSUME. SO, UM, MUCH LIKE GENERATION, THIS IS EFFECTIVELY SAYING THAT ADDITIONAL, UH, BEYOND THE FIRM SERVICE AMOUNT, THE REST IS EFFECTIVELY BEING CONVERTED TO CONNECT AND MANAGE AND ALL THE RISKS THAT GO ALONG WITH THAT. I, I COMPLETELY AGREE. THANKS AG. ALRIGHT, THANK YOU. SO LEMME DO THE LAST QUESTION ON JESSE, THEN WE'RE GONNA PAUSE THE QUEUE TO GET THROUGH THE REVISION LANGUAGE AND THEN WE'LL OPEN THE QUEUE UP STARTING AGAIN WITH EVAN NEIL AT THAT POINT. SO, JESSE, GO AHEAD. LAST QUESTION FOR NOW. ALRIGHT, THANKS MATT. UH, JESSE GOSSETT HERE, VWI. UM, I'LL TRY TO KEEP THE SOAPBOX, UH, TO THE SIDE. JUST A COUPLE OF QUICK CLARIFYING QUESTIONS AND THEN ONE GENERAL COMMENT. UH, THE FIRST WAS THE, UH, THE A B, C, UM, AS IT STEPS THROUGH THESE SC INTERVALS IS THE EXPECTATION THAT IT'S JUST BRINGING DOWN THE BID PRICE OF THOSE PCLR AND OTHER RESOURCES JUST OPERATING THE MARKET WILL STILL BE CONSIDERED IN EACH INTERVAL, RIGHT? IT'S NOT CREATING LIKE A WALLED GARDEN. BRIAN, YOU WANNA TAKE THAT ONE? I WANNA SAY CORRECT? YES, THAT THAT'S CORRECT. AND IF YOU LOOK AT THE, UH, I GUESS IT'S THE BOTTOM RIGHT. SORRY, MY COMPUTER'S NOT, I, MY JUST, JUST THE YES IS FINE, . YEAH, I KNOW, IT'S, I KNOW. YES. THERE WE GO. THERE WE GO. THAT'S, UH, PARDON ME. THE, THE, THE ONLY THING I WANTED TO ADD, AND, AND MY APOLOGIES, IS THAT, UM, YOU'LL SEE THAT THE, THE BID CAP IS, IS APPLIED DURING C STEP TWO MM-HMM . SO IT IS AN INPUT INTO THAT STEP TWO AND THE OUTPUT IS THE, UH, UM, BASE POINTS. SO THAT'S AN IMPORTANT DISTINCTION THAT, THAT WE'RE ADJUSTING THE BID CAP, BUT THE, THE DISPATCH IS ACTUALLY THE OUTPUT OF THAT ALGORITHM. YEP. AND, AND JUST A QUESTION ON UMS YOUR EARLIER COMMENT ON THE, UH, NEEDING TO FIGURE OUT THE, UH, THE, THE, THE DEVIATION ABILITY, THE ABILITY TO RAMP, OBVIOUSLY GOING DOWN, YOU KNOW, WE'RE GONNA HAVE TO HAVE PCLR THAT CAN VERY QUICKLY MEET SCS NEW LOW, LOW BASE POINTS. UM, BUT JUST IN NORMAL OPERATIONS, HOW ARE WE GONNA GET TO THE POINT OF UNDERSTANDING HOW THESE PCL R ARE OBLIGATED TO FOLLOW A BASE POINT, KNOWING THAT MANY OF THESE FUTURE LARGE ELECTRIC LOADS ARE GOING TO STRUGGLE TO, UM, TO PROVIDE THAT EFFECTIVELY, UH, WITHIN A TIGHT BAND OPERATIONAL LOAD, UH, THAT MIGHT END UP GETTING OBLIGATED. IS THERE SORT OF LIKE, WHY, WHY CAN'T IT JUST BE, UH, A CEILING, RIGHT? SORRY. SO YOU CAN USE YOUR BID STRUCTURE TO HELP NAVIGATE THE WIGGLE ROOM, LIKE HIGH PRICES AT A BREAK POINTED AT ANOTHER ONE TO KEEP FROM SEESAW EVERY FIVE MINUTES. BUT THAT'S A QUEASY ISSUE AND WE CAN'T SOLVE IT TODAY. HOW YOU CONFIGURE YOUR LOAD TO FOLLOW SC IS THE BUSINESS ISSUE THAT HAS TO BE ADDRESSED BY THE DIFFERENT MARKET PARTICIPANTS WITH VARIOUS TECHNOLOGIES OR HOWEVER THEY WANT TO DO, OR DIFFERENT BUILDINGS IN THEIR FACILITY. BUT WE, WE CAN'T SPEAK TO THAT TODAY. YEP. ACKNOWLEDGED. OKAY. UH, AND THEN, AND THEN MAYBE JUST ONE MORE ON THE, THE, THE ITEM THAT HARSH AND I THINK, UM, NED AND FRANK ALSO TALKED THROUGH IS, IS IT FEELS LIKE WE'RE OPENING UP A, A BIT OF A WILD, WILD WEST FOR PCR SAYING, YOU KNOW, YOU CAN GO UP TO CERTAIN POINTS, THERE MIGHT BE [01:35:01] SOME DYNAMIC LIMITS, BUT I THINK IT'S A, GAME THEORY IS A GOOD WORD FOR IT. I THINK TRAGEDY OF THE COMMONS IS ALSO GONNA HAPPEN WHERE YOU COULD HAVE POST YOUR BATCH RESOURCES THAT COME IN WITH MAYBE A DIFFERENT SHIFT FACTOR THAT TOTALLY CHANGED THE TOPOLOGY OF THE CONSTRAINTS AND WHAT YOU MAY HAVE DESIGNED AND BUILT. SO I ACKNOWLEDGE THAT THAT'S NOT KOTS JOB TO SOLVE AND YOU KNOW, OBVIOUSLY CAN'T GUARANTEE ANYTHING. BUT I WOULD JUST LIKE TO POINT OUT THAT THROUGH THIS PROCESS, I THINK AS A, AS A COLLECTIVE GROUP, IT'S OUR GOAL, OR IT SHOULD BE OUR DIRECT, IT SHOULD BE OUR INCENTIVE TO TRY TO FIGURE OUT HOW WE ENABLE THESE PCLR TO SOLVE THE PROBLEMS PROACTIVELY. WHETHER IT'S BUYING PRIVATE MITIGATION, WHETHER IT'S DESIGNING A, A NON SYNCHRONOUS BEHIND THE METER GENERATOR OR BATTERY, WHICH SEEMS LIKE IT MIGHT BE REALLY THE ONLY OPTION TODAY IS A TOTALLY NON SYNCHRONOUS BEHIND THE METER, WHICH I THINK HAS SOME PLANNING IMPACTS. AND THAT'S MAYBE THE LAST QUESTION IS JUST A QUICK ONE. HOW ARE WE, HOW ARE WE DEALING WITH THE, THE SORT OF GUESTS THAT WE'RE GONNA NEED TO, UH, PUT ON THESE LOADS WHERE THEY MAY ONLY GET 100 OUT OF 500 AND THAT 400 IS GONNA HAVE TO BE MATCHED WITH PRIVATE MITIGATION. THAT THEN IS A SOLUTION, A GENERATION TYPE SOLUTION THAT THEN GETS ADDED POST-STUDY, WHICH MAY REQUIRE MATERIAL MODIFICATION OR SOME OTHER CHALLENGE. OKAY. IN TERMS OF MANAGING THIS, AGAIN, I'LL JUST SHARE, WE CANNOT SOLVE HOW THAT WORKS FOR YOU TODAY. I'M GONNA RECHARACTERIZE SOMETHING YOU SAID, AND MAYBE IT'S NOT FAIR, BUT ERCOT IS APPROACHING THIS AS HOW TO LET YOU CONSUME MORE POWER OFF THE GRID. OUR JANUARY MEETING SAID IN OFF PEAK HOURS, I WANT TO CONSUME MORE POWER. PLEASE GIVE US A WAY TO GET THERE. WE'RE GIVING YOU A WAY TO GET THERE. WE DON'T KNOW IF YOU'LL GET TO THE TOP OR IF YOU'LL GET PARTWAY BECAUSE THERE'S A DYNAMIC ISSUE, OR IF ERCOT HAS TO COME UP WITH A GENERIC TRANSMISSION CONSTRAINT OR THERE'S VOLTAGE, THERE MAY BE BOUNDARIES THAT YOU'LL START TO HIT. AND THAT HAPPENS ALL THE TIME ON THE SYSTEM. SO WE'RE TRYING TO SOLVE, GETTING MORE POWER ONTO THE SYSTEM, UH, AND THAT'S ALL WE'RE DOING TODAY, BUT WE CAN'T GUARANTEE YOUR INVESTMENT, YOUR PROFILE, YOUR RISKS, THAT'S ON YOU. BUT WE'RE DOING EVERYTHING IN TERMS OF POSTING STUDIES AND PUBLISHING INFORMATION SO YOU CAN STUDY THAT RISK AT YOUR OWN FOR YOUR OWN SHOP. HERE'S MY STUMP SPEECH, SORRY, BUT I FEEL LIKE WE'RE KIND OF GETTING INTO THE, LET'S TRY AND TWIST AND PULL THIS. WE HAVE ONE THING WE CAN GET ACROSS THE FINISH LINE ON, ON JUNE 1ST. WE NEED TO FOCUS ON THE MECHANICS OF WHAT DOESN'T WORK ABOUT THIS AND MOVE THROUGH IT. SO THAT'S A GREAT SEGUE INTO LET'S GET THROUGH THE LANGUAGE TODAY AS WE PROPOSE. ERCO IS GONNA BE VERY INTERESTED IN PEOPLE'S COMMENTS ON THE LANGUAGE AND WHAT DOESN'T WORK ABOUT IT THAT IS MISSING. AJ, TURN IT. SO WE'RE GONNA PAUSE THE QUEUE, TURN IT OVER TO AG. I WILL SAY, JUST IN TERMS OF WHEN'S LUNCH, HOW ARE WE UNPACKING THIS? I STILL WANT TO GET TO AT LEAST 30 MINUTES OF BYOG BEFORE LUNCH. I'M GUESSING LUNCH IS AT 1230. SO THAT MEANS IS WE'RE GONNA GIVE THIS DISCUSSION UNTIL ABOUT NOON, PIVOT TO BYOG, TAKE LUNCH BREAK, AND THEN TALK ABOUT BATCH ZERO, UH, AND THEN WRAP UP WITH 58 41. SO AGAIN, WE KNEW THIS WAS NEW AND GET A LOT OF GOOD CONVERSATION, BUT WE HAVE ANOTHER MEETING NEXT WEEK TO TALK ABOUT CLRS. OKAY, GO AHEAD AG. THANKS MATT. UM, OKAY, SO I'M GONNA GO BACK TO THIS SLIDE VERY BRIEFLY, UM, TO THE THREE PILLARS. HOW DO WE ALLOCATE IT IN MATCH? WHAT ARE THE REGISTRATION REQUIREMENTS? UH, REALTIME DISPATCH, UH, THE, THE BID CAPPING THAT GOES ALONG WITH THAT? WE'RE GONNA START WITH ALLOCATION, AND THAT IS BASICALLY THE BIGGER COMMENTS THAT WERE, THE DRAFT BIGGER COMMENTS THAT WERE POSTED. UM, I, I'M GOING TO GONNA CAVEAT WITH THIS AGAIN, WITH THE BIG, UH, WATERMARK WE PUT ACROSS THIS. THIS IS A DISCUSSION DRAFT. IT IS NOT A FILED SET OF COMMENTS YET. UM, WE'VE ALREADY IDENTIFIED, I THINK A COUPLE AREAS WHERE WE NEED A LITTLE BIT MORE WORK JUST THROUGH THIS DISCUSSION. SO AGAIN, OUR TARGET IS TO FILE THESE NEXT WEEK AND WE WILL BE CONTINUING OUR, OUR NIGHTS AND WEEKENDS, UH, UP TILL THEN TO, TO GET IT IN THE BEST SHAPE POSSIBLE. OKAY, SO AS I MENTIONED IN ONE OF MY SLIDES, WHAT WE DID IS, THIS IS GONNA TAKE TOO LONG IF I DO WITH THE WHEEL, UH, WE ADDED SECTIONS TO SECTION NINE THAT ARE JUST PCLR SPECIFIC. SO PCL DO NOT IMPACT YOUR, UH, ELIGIBILITY TO BE INCLUDED IN BATCH THAT IS NOT BEING TOUCHED HERE. UM, ANYBODY WHO IS ELIGIBLE TO BE INCLUDED IN BATCH IS STILL ELIGIBLE AND ANYBODY WHO IS NOT IS, IS STILL NOT THE, THE LANGUAGE IN 9 2 1 AND ANY OF THE SUBSECTIONS HAS NOT BEEN TOUCHED. SO THEN WE GO TO 9 2 2, WHICH IS ALL THE INFORMATION YOU NEED TO GIVE TO ERCOT OR YOUR TS, YOUR INTERCONNECTING DSP OR INTERCONNECTING TSPS TO SUBMIT ON YOUR BEHALF. WHAT DO YOU NEED TO GIVE US IN ORDER TO ALSO BE CONSIDERED FOR PCLR? UM, AND THIS IS ACTUALLY PRETTY STRAIGHTFORWARD. UM, SO IT'S REALLY TWO THINGS. THE FIRST IS, UH, THERE'S A NEW FORM IN THE, IN THE PROTOCOLS. THAT'S OUR SECOND PILLAR WE'LL GET TO IN A FEW MINUTES. UM, THAT IS THE DECLARATION OF INTENT TO REGISTER AS A-P-C-L-R [01:40:01] THAT NEEDS TO BE SIGNED BY A OFFICER OFFICIAL OR AUTHORIZED REPRESENTATIVE, UM, AND NOTARIZED AND SUBMITTED TO US ON, ON OR BEFORE JULY 24TH. SO THAT'S, THAT'S YOUR DEC DECLARATION THAT YOU WANNA BE TREATED IN THIS WAY IN BATCH ZERO. UM, AND THEN, UM, WE HAVE A SECOND PARAGRAPH, WHICH IS IF WE MAY DEFINE SOME ADDITIONAL INFORMATION THAT IS NEEDED FOR THE BATCH ZERO STUDY. UH, WE ARE HAVING SOME INTERNAL DISCUSSIONS THAT WE MAY ACTUALLY HAVE EVERYTHING WE NEED FROM THE INITIAL SET OF INFORMATION. UM, SO IF, IF THIS PARAGRAPH IS GONE WHEN WE FILE, UH, SUBPARAGRAPH B HERE, THAT, THAT'S THE REASON WHY IS, UM, IF WE, WE FEEL WE ALREADY HAD WHAT WE NEEDED IN THE, THE BASE SET OF INFORMATION WE'RE REQUESTING. UM, SO THE BIG PIECE IS, UH, GIVE US THE DECLARATION, UH, BY THE, THE, THE JULY 24TH DATE WHERE WE'RE, WE'RE KIND OF CUTTING OFF SUBMISSIONS FOR THE STUDY. OKAY? SO THEN WE GO INTO THE STUDY ITSELF. AND SO THE STUDY ITSELF IS DEFINED IN SECTION 9 3 2 IN PIGGER 1 45. AND SO WHAT WE'VE DONE HERE IS, AGAIN, WE'VE TACKED ON AN EXTRAS SUBSECTION THAT'S 9 3 2 1, WHICH IS HOW DO WE TREAT PCR IN THE BATCH ZERO IN CONNECTION STUDY? UM, AND SO THIS OPERATIONALIZES WHAT I DESCRIBED, WHICH IS THAT FOR STEADY STATE, UH, WE WILL, WE WILL ASSESS AGAIN THE AMOUNT THAT CAN BE RELIABLY SERVED. UM, AND THEN, YOU KNOW, BECAUSE WE HAVE YOUR, YOUR KIND OF, UM, YOUR MINIMUM POWER CONSUMPTION AMOUNT WHERE, YOU KNOW, YOU'VE TOLD US TO, YOU KNOW, BELOW THIS, IT'S MY PROJECT IS, IS IT EITHER PHYSICALLY CAN'T GO BELOW THAT OR, UH, IT'S, IT'S NOT VIABLE. IF IT GOES BELOW THAT, THEN, THEN WE, WE ARE ABLE TO THEN SAY, OKAY, WELL, YOU KNOW, IF, IF YOU TOLD US YOU CAN'T GO BELOW A HUNDRED AND IN THIS YEAR THE STUDY SAYS ONLY 50 CAN BE RELIABLY SERVED, WELL THEN, UM, YOU KNOW, WE'RE, WE'RE, WE'RE ABLE TO IDENTIFY THAT, THAT THAT'S NOT FEASIBLE, UM, AND ALLOCATE IT, UH, UH, SAME AS WITH A, A FIRM LOAD. UM, OTHERWISE IF THE AMOUNT IS HIGHER. SO THERE'S ALSO THE POSSIBILITY THAT, WELL, I CAN'T GO BELOW A HUNDRED, UM, BUT THE STUDY IDENTIFIES ONE 50 CAN BE SERVED. WHAT WILL COME BACK AT THE END OF THE BATCH ZERO STUDY IS THAT THE, THE LPC CAN BE ONE 50 INSTEAD OF WHAT YOU TOLD US AS A HUNDRED. SO, SO THERE IS THAT MECHANISM TO ALLOW FOR MORE LOAD TO BE FIRM IF THE SYSTEM CAN SUPPORT IT. SO THAT'S DEFINED IN SECTION 9, 3, 2, 1. SO THEN WE GO, WELL, WHAT HAPPENS DURING THE COMMISSION, THE, UM, COMMITMENT PERIOD. AND SO THAT'S DEFINED IN CURRENTLY IN SECTION 9.4 IN THE PICKER 1 45 LANGUAGE. AND SO, WE'LL, AGAIN, WE'LL JUST ADD ON ANOTHER SECTION, WHICH IS 9 4 1. UM, AND SO WHAT WILL HAPPEN IS, UH, ERCOT, AS PART OF ITS OUTPUTS WILL, WILL GIVE, UM, THE VIEW ON, UH, THE AMOUNT OF LPC AMOUNTS THAT WERE IDENTIFIED IN THE STUDY. SO AGAIN, IF YOU TOLD US YOU NEEDED AT LEAST A HUNDRED AND WE SAID, WELL, WE CAN, YOU KNOW, A HUNDRED'S FINE, THEN THAT'S WHAT'LL COME BACK. IF IT TURNS OUT ONE 50 CAN BE SERVED FIRM, THEN THAT WOULD BE WHAT WOULD COME BACK FOR THAT YEAR. AND IF IT IS, YOU KNOW, LESS THAN YOUR, YOUR MINIMUM, THEN IT WOULD COME BACK AS A ZERO FOR THAT YEAR. UM, THAT WOULD BE PROVIDED, UH, AT THE START OF THE COMMITMENT PERIOD. THAT'S THE OUTPUT OF BATCH ZERO, UM, JUST LIKE, UH, IS DESCRIBED IN THE EXISTING PAYER 1 45. UM, AND THEN THE, UH, CUSTOMER, THE ILLE IN ORDER TO ACCEPT THOSE AMOUNTS HAS TO MEET ALL THE EXISTING COMMITMENT CRITERIA THAT'S DEFINED IN SECTION 9.4 AND NEEDS TO, UH, ALSO SUBMIT BACK THE SECOND PORTION OF FORM W, WHICH IS THE, THE NEW FORM WE'VE IDENTIFIED. UH, WE'VE, WE'VE ADDED TO THE PROTOCOLS TO AGREE TO BE A-C-P-C-L-R. SO THE FIRST PART IS THAT DECLARATION THAT YOU WANT TO BE TREATED THAT WAY IN BATCH ZERO. THE SECOND PIECE NOW, AND WE'RE IN COMMISSION, UH, I'M SORRY, COMMITMENT IS TO SIGN THAT SECOND PIECE, ACCEPT THE LPC NUMBERS THAT WERE GIVEN AND AGREE THAT IN ORDER TO, YOU KNOW, GET ABOVE THAT IN REAL TIME, YOU'RE GOING TO NEED TO REGISTER AND QUALIFY AS A-P-C-O-R. UM, AND, UH, THIS BECOMES A REQUIRED COMPONENT OF THE PACKAGE YOU HAVE TO GIVE BACK TO ERCOT WITHIN THE 30 DAY PERIOD, UM, OR TO YOUR TSP AND THE TSP SUBMITS IT BACK. UM, AND THEN, UH, YOU KNOW, AS WITH THE OTHER PROVISIONS IN 9.4, IF YOU DON'T MEET ALL THE MILESTONES, THEN WE'VE CONSIDERED THAT YOU'RE, YOU'RE DROPPING OUT OF THE STUDY, UM, 9.5 AND THE EXISTING PIGGER 1 45 DEFINES THE REFINEMENT STUDY. AND SO WE'VE JUST ADDED ANOTHER SECTION 9.5 0.3 OF HOW DO WE TREAT PCLR IN BACTERIA REFINEMENT. UM, AND THIS IS VERY STRAIGHTFORWARD. IT'S JUST AN AFFIRMATIVE STATEMENT THAT WE WILL, UH, STUDY THE FULL REQUESTED [01:45:01] AMOUNT TO ENSURE TRANSMISSION IS BUILT TO ULTIMATELY SERVE THE FULL REQUESTED AMOUNT AND ALLOW IT TO EXIT. UM, SO, UH, REALLY THAT IT IS JUST AN AFFIRMATIVE STATEMENT OF THAT IT'S GONNA BE TREATED ON EQUAL FOOTING WITH, UH, FIRM LOAD. UM, AND THEN 9.6 DEFINES ENERGIZATION AND, UH, ONGOING OBLIGATIONS FOR, UH, LARGE LOADS. AND SO WE'VE ADDED A 9.6 0.1 FOR PCL. UM, AND THIS IS THE SECTION THAT WOULD LIKELY REMAIN BOXED UNTIL WE HAVE THE SYSTEM CHANGES IN PLACE. SO KIND OF EVERYTHING THAT I'VE SHOWN SO FAR WOULD BE ABLE TO BE UNBOXED EARLY. UH, WE TREAT IT IN BATCH ZERO, BUT ACTUALLY COMING ON THE SYSTEM THAT'S GONNA BE DEPENDENT ON THE SYSTEM CHANGES. SO NPR 1188 IS IMPLEMENTED AND THE, UH, BID, UH, CAPPING, UH, LOGIC IS ALSO IN PLACE AS WELL. UM, AND THEN, SO THEN FROM THERE, UH, IT'S BASICALLY A SET OF STATEMENTS THAT YOU NEED TO, UM, IT DOES ALLOW FOR, ESPECIALLY IN THE CASE WHERE A CUSTOMER HAS TOLD US THEIR LOAD POWER CONSUMPTION AMOUNT IS ZERO. UM, IT DOES ALLOW FOR A SMALL AMOUNT OF LOAD TO COME ON THE SYSTEM FOR, UH, UH, QUALIFICATION AND TESTING SOMEWHERE. I THINK THAT MAY HAVE GOTTEN STRIPPED OUT. SORRY, UH, UH, BUT IT DID BASICALLY, IT REQUIRES THAT THE, THE ALL THE STEPS TO ROD REGISTER AS A, UH, PCLR. SO IN OTHER WORDS, YOU KNOW, THE ILE BECOMES A RESOURCE ENTITY DESIGNATES A QSE, ALL THE REGISTRATION INFORMATION IS ENTERED INTO RIO. SO WE'RE, YOU KNOW, THE MODELING STEPS WILL BE IDENTICAL TO THAT OF ACL R. UM, TELEMETRY IS IN PLACE, THE QUALIFICATION TESTING IS DONE, AND THEN WE PROVIDE WRITTEN CONFIRMATION THAT THE LOAD IS ABLE TO CONSUME ABOVE, UH, ITS LPC. SO, UM, FAIRLY STRAIGHTFORWARD STEPS, BUT THAT, THAT WOULD NEED TO BE BOXED UNTIL THE SYSTEM CHANGES ARE THERE. OKAY, SO THAT IS THE LANGUAGE THAT COVERS OUR FIRST PILLAR. HOW DO WE ALLOCATE IN BATCH ZERO? I'M GONNA TURN NOW TO THE NPRR AND WE'RE GONNA COVER THE OTHER TWO PILLARS. UH, SO THE, THE NPR COMMENTS, UH, FIRST OF ALL HAS A ADDED DEFINITION OF WHAT A PROVISIONAL CLR IS. IT'S A, UH, SUB DEFINITION OF CONTROLLABLE LOAD RESOURCE. SO, UH, I, I THINK WE'VE REALLY TALKED THROUGH IT. SO I'M GOING TO, UM, KEEP GOING. UM, AND WHAT WE'RE GONNA DO IS LET'S GO TO THE END AND WE'LL TALK ABOUT THE AGREEMENT. THIS IS A NEW FORM W THAT IS ADDED. AND SO FOR THOSE FOLLOWING ALONG, WE ARE NOW ON PAGE, UH, PAGE 38, UH, 34, SORRY, PAGE 34. SO, UM, THIS IS A NEW FORM THAT WOULD BE ADDED TO SECTION 23 OF THE PROTOCOLS. UH, IT HAS SOME EXPLANATORY TEXT THAT MIRRORS KIND OF THE, THE BIG POINTS IN THE BIGGER THAT I JUST SHOWED, UH, THE ACKNOWLEDGEMENT FROM THE ILE THAT THEY'RE MAKING COMMITMENT TO, UM, REGISTER AS A CL UH, PCLR, UH, UNDERSTANDS THAT THAT'S HOW WE'LL EVALUATE THE, THE LOAD IN THE BATCH ZERO STUDY, UH, UNDERSTANDS THAT THAT REGISTRATION THEN HAS TO BE ACTUALLY COMPLETED PRIOR TO ENERGIZING THOSE ADDITIONAL MEGAWATTS THAT IT WILL, WILL FOLLOW THE STEPS OF ACL R, UH, IN ORDER TO REGISTER. AND THAT IT MUST REMAIN A-P-C-L-R UNTIL THE EXIT DATE. THAT'LL BE DEFINED AT THE END OF THE BATCH ZERO STUDY IN PART B OF THIS FORM, UM, UNDERSTANDS OBLIGATION TO TO FOLLOW REALTIME DISPATCH INSTRUCTIONS, UH, AND THAT THE OBLIGATION IS TRANSFERABLE TO FUTURE OWNERS. UM, THE, THE, THE FILLING, THE, THE INFORMATION THAT'S PROVIDED IS FAIRLY STRAIGHTFORWARD. THE NAME, THE LI NUMBER, UH, ADDRESS AND MAXIMUM DEMAND THAT WAS, IS BEING REQUESTED ALONG WITH THE SORT OF MINIMUM NUMBERS, UH, WE ARE LOOKING AT WHETHER OR NOT WHAT WE'RE ALREADY REQUIRING FOR FIRM LOADS AND BATCH ZERO MEETS THE NEEDS OF THIS TABLE. SO THIS TABLE MAY, MAY DISAPPEAR FROM PART A AND THEN ASSIGN A NOTARIZATION, AND THEN WE MOVE ON TO PART B, WHICH IS VERY SIMILAR TO, UH, PART A. SO WHAT WILL HAPPEN IS ERCOT WILL RETURN AT THE END OF THE BATCH ZERO STUDY THE COMPLETED TABLE WITH HERE, HERE ARE THE, YOUR MINIMUM POWER, LOW POWER CONSUMPTIONS AMOUNTS, UM, I THINK I SHOULD SAY MAXIMUM ACTUALLY. UH, THOSE WILL BE DETERMINED BY THE BAT ZERO STUDY. SO ERCOT WILL PROVIDE THAT BACK WITH THIS TABLE PRE FILLED OUT. AND THEN THE ILE WILL REAFFIRM ALL THE O UH, THE OBLIGATIONS THAT ARE [01:50:01] ESTABLISHED ON PCL R AND SIGN THE FORM TO ACCEPT THOSE. AND AT THAT POINT, UH, THAT'S HOW IT'LL BE TREATED IN THE REFINEMENT. AND, UH, UH, WE'LL, UH, UH, LOOK FOR THAT REGISTRATION WHEN WE GET CLOSE TO REAL TIME. OKAY, SO LAST ITEM TO SHOW, UH, SORRY, I'M HAVING SOME ISSUES IN MY MOUSE HERE. UM, OKAY, SO RYAN, DO YOU WANT TO, DO YOU HAVE SPECIFIC POINTS YOU WANNA HIGHLIGHT? I KNOW THERE WAS, THERE'S QUITE A BIT OF LANGUAGE ON THE, THE BID CAPPING. SO RYAN, ANDS, I'LL KINDA LET Y'ALL DRIVE HERE. TELL ME WHERE YOU WANNA GO. YEAH, I THINK IF YOU WANT TO GO TO 4.4 0.7 0.40, SORRY, THAT'S NOT WHERE I THOUGHT YOU WERE GOING. SENDING ME FROM OH FOUR, THAT'S, NO, THAT'S, THAT'S RIGHT. OKAY. YOU WERE AHEAD OF ME. SO, UM, THIS IS THE NEW SECTION WHERE, UM, AGAIN, THE, WE'VE, WE'VE ADDED THIS, THIS NEW SECTION TO, TO 4.4 0.9 0.4. SO THIS 0.4, UM, ESSENTIALLY, UH, CODIFIES THE CONCEPT THAT WAS IN THE SLIDE PRESENTATION. UM, AND IT JUST, WE CAN KIND OF GO THROUGH IT, UH, STEP BY STEP, BUT THIS KIND OF EXPLAINS THE PROCESS HERE. SO, UM, IT DESCRIBES WHERE AND HOW THESE, UH, ABCS OR ADJUSTED BID CAPS APPLY. AND SO THE, THE FIRST STEP HERE IS THAT AFTER EACH SCED RUN WILL HAVE THE, THIS LIST OF TRANSMISSION CONSTRAINT IDENTIFIERS, AND THOSE IDENTIFIERS ARE BASED ON SHADOW PRICES THAT WERE EQUAL TO OR GREATER THAN THIS, THIS PREDEFINED THRESHOLD, THIS 90% THAT WE NOTED. AND SO IF YOU SCROLL DOWN A LITTLE BIT, WE'VE JUST KIND OF NOTED THAT THE 90% WILL APPLY TO ALL CONSTRAINTS IF YOU WANNA KEEP GOING. AND THEN WE TAKE THAT LIST AND DO A, THIS, THIS MATCHING THAT I NOTED. SO IN THE CURRENT SC WE'LL LOOK AT, UH, WHERE THE CONS, THE TWO CONSTRAINTS MATCHED, AND THEN THAT IS KIND OF OUR LIST OF CONSTRAINTS. AND THEN IN C THIS IS WHERE WE DO THE DYNAMIC, UH, BID CAPPING. SO FOR ANY, UH, FOR ANY OF THOSE MATCHING CON CONSTRAINTS WHERE THE, WE HAVE A-P-C-L-R THAT HAS THE HELPING SHIFT FACTOR THAT'S, UH, GREATER THAN THE, THE THRESHOLD ON THE LIST, THEN WE, UH, THEN WE KIND OF DO THIS STEPWISE PROCESS. SO IF YOU WANNA SCROLL DOWN A LITTLE BIT. ALRIGHT, SO IN, UH, A YOU CAN SEE THAT IF THAT, THAT, UM, THAT ISN'T MET, THEN THERE IS NO BID CAPPING. BUT FOR ANYTHING THAT CAN HELP MORE THAN 2%, WE TAKE THE, UH, UM, JUST SEE HERE. SO WE WILL, WE WILL TAKE THE MINIMUM OF THOSE CONSTRAINTS, UH, TAKE SYSTEM LAMBDA FROM THE FIRST STEP IN THE TWO STEP SC PROCESS, LESS A PENNY. AND THEN THAT WILL BE THE INPUT INTO SCED STEP TWO. AND THEN THE OUTPUT WILL BE UM, THE, WHAT EXISTS TODAY, THE BASE POINTS, THOSE TYPE OF THINGS. SO THE, THE DYNAMIC BID CAP IS THE INPUT INTO STEP TWO AND THEN THE BASE POINTS ARE THE OUTPUT. SO THAT, I THINK THAT IS THE BULK. THERE'S A FEW OTHER PLACES THAT WE PROBABLY DON'T NEED TO GO THROUGH TODAY. ONE THING I DID WANNA NOTE IS BECAUSE THIS IS A, OBVIOUSLY A NEW PROCESS, THERE'LL BE A NEW REPORT TO UNDERSTAND WHEN AND HOW THESE BID CAPS HAVE BEEN APPLIED. SO WE'VE MADE REFERENCE TO THAT AND UH, I THINK THAT IS THE BULK OF THE, OF THE DYNAMIC BID CAPPING. ALRIGHT, THANK YOU RYAN. UM, AND THANKS FOR, THANKS FOR THE WORK Y YOUR TEAM DID ON, ON DEVELOPING THAT PORTION. SO, UM, MATT, I THINK WE'RE READY TO OPEN THE QUEUE BACK UP. ALRIGHT, THANK YOU BOTH FOR GOING THROUGH THAT. AND SO WE HAVE ABOUT EIGHT PEOPLE, SO WE'RE GONNA GO TILL NOON ON CLRS, STARTING WITH EVAN NEIL. THANKS EVAN. NEIL LAN, UM, I'VE GOT A COUPLE QUESTIONS AND REALLY JUST UPS BROAD CLARIFICATION 'CAUSE I HEARD SOME STUFF EARLIER AND I JUST WANNA MAKE SURE IT GOT IT CLEAR. SO, UM, HAVING TO DO WITH WHAT HARSH WAS SAYING ABOUT SETTING THE MPC WAS THAT SAID THAT WE'RE NOT GOING TO BASE THAT OFF OF THE RESULTS OF THE STABILITY STUDY, CORRECT? RIGHT, RIGHT NOW AS DRAFTED YOUR MPC IS WHATEVER, WHATEVER MEGAWATTS YOU ASK FOR. OKAY. SO THEN THE ERCOT LANGUAGE IN THE COMMENTS FROM 9 3 2 SECTION FOUR ERCOT SHALL ENDEAVOR TO RESOLVE ALL TRANSMISSION VIOLATIONS SEEN IN THE STUDY. WE'RE NOT ENDEAVORING THAT FOR THIS, [01:55:01] FOR THOSE SETS OF VIOLATIONS. YOU LOST ME ON THAT, EVAN. OKAY. IT'S UH, SECTION 9.32. PARAGRAPH FOUR TALKS ABOUT WHAT THE STUDY IS FOR BATCH ZERO. SO MAYBE I CAN EXPLAIN IT THAT ONE. YEP. UM, SO THE ANSWER IS THE, ALL THE SAME TRANSMISSION CONSTRAINTS AND VIOLATIONS WOULD STILL BE CONSIDERED, BUT THAT IS USED IN DETERMINING THE AMOUNT OF FIRM LOAD THAT IS BEING SERVED. THIS STUDY DOES NOT PROVIDE A VIEW ON WHETHER THERE'S A LIMIT ON NON FIRM BEING SERVED. OKAY, THANKS, THAT'S HELPFUL. SO MY FOLLOW UP THEN WOULD BE WE'RE IDENTIFYING THAT WE'RE REALLY STUDYING THE IMPACT FROM A STABILITY STANDPOINT. WHEN WE GET TO THE QSA, WHICH IS A PRE ENERG ENERGIZATION THING, ARE WE ANTICIPATING THAT THE QSA WILL THEN CHANGE THE LIMIT OF THE LOAD AT ALL? NO, I, I, I THINK IT IS. UH, AND LEMME CLARIFY. SO WE ARE, UM, SO I THINK WHAT'S DIFFERENT ABOUT PCL R FROM JUST REGULAR LARGE LOADS IS THAT IN THE, UM, THE STEADY STATE PORTION OF THE BATCH STUDY, UM, WHEN WE, UM, GO TO ALLOCATE THE, THE LOAD, IT, IT'LL BE WHAT, WHATEVER, WHATEVER THE LIMIT IS. UM, AND, AND, AND THEN IN, IN THE STABILITY STUDY, UH, SO THAT, THAT'S THE SAME WHETHER IT'S, SO IN THE BATCH PROCESS IT'S THE SAME, UH, WHETHER IT'S A LARGE REGULAR, LARGE LOAD OR PCLR, UM, THE, UM, ALLOCATION IS THE SAME. UH, BUT WHEN WE GET TO THE, THE STABILITY STUDY, THE, UM, UH, A REGULAR LARGE LOAD WOULD BE STUDIED JUST AT WHATEVER THAT'S ALLOCATED. MEGAWATTS MEGAWATT LEVEL IS A-P-C-L-R WILL BE STUDIED AT ITS MAXIMUM MM-HMM . UM, AND SO THAT WHEN WE DO THAT STABILITY STUDY IN THE BATCH ANALYSIS, THEN WE WILL IDENTIFY ARE THERE STABILITY LIMITS THAT WE IDENTIFY THAT ARE ABOVE THAT, THAT, UM, THAT ALLOCATED, UH, THE, THE, THE LPC LIMIT, WHICH FOR P CLRS, IF THAT IS THE CASE, THAT WILL BE A FLAG THAT, UH, SO SIMILAR LIKE STABILITY STUDY TODAY FOR A LARGE LOAD THAT WHEN WE DO THE QSA, THE QSA TEAM KNOWS OKAY, SOME, A STABILITY LIMIT WAS IDENTIFIED IN THE INTERCONNECTION STUDY. UH, AND SO WE NEED TO, I, WE NEED TO STUDY THAT AS PART OF THE QSA TO SEE IF WE NEED TO IMPLEMENT A GTC TO MANAGE THAT LIMIT. RIGHT. SO BY NOT LIMITING THE LOAD TO THE RESULT OF THE STABILITY STUDY IN THE BATCH YEP. THEN WE'RE CONVERTING WHAT IF IT WAS A FIRM LOAD WOULD BE A LIMIT ON THE LOAD'S ABILITY TO CONNECT. WE'RE CONVERTING THAT LOCAL LIMITATION INTO A SYSTEM-WIDE LIMITATION THROUGH A GTC. RIGHT. IT, IT, IT, I THINK IT, IT DEPENDS ON THE SITUATION, RIGHT? IT, IT COULD BE LOCAL OR IT COULD BE SYSTEM. I THINK IT JUST DEPENDS THE, THE, THE, THE QSA TEAM WILL, AS THEY DO WITH EVERYTHING JUST SIMILAR TO A GENERATOR, RIGHT? IT'S, YEAH. YOU KNOW, SOMETIMES THOSE GENERATION LIMITS OR, OR JUST KIND OF, IT'S MOST APPROPRIATE TO CONTROL JUST A SMALL AREA, WHICH SOMETIMES IT'S JUST A SINGLE GENERATOR. SOMETIMES IT'S THE ENTIRE WEST TEXAS, RIGHT. IT IT, I THINK IT JUST DEPENDS ON THE NATURE OF THE STABILITY ISSUE AND, AND HOW THEY, AND THAT THAT TELLS THEM HOW TO DESIGN THE GTC FOR THAT. YEAH, I HEAR WHAT YOU'RE SAYING. I THINK MY OVERALL CONCERN, AND MAYBE COULD BE LIKE HIGHLIGHTED BY THIS EXAMPLE OF A FIRM LOAD AND A CLR OR PCLR, SORRY, SAY THE THERMAL LIMITATION IS A HUNDRED MEGAWATTS AND THE STABILITY LIMITATION IS 50 MEGAWATTS. I UNDERSTAND THAT'S USUALLY UNLIKELY, BUT SAY THAT'S THE CASE, THE FIRM LOAD WOULD BE LIMITED AT 50 MEGAWATTS OF THE STABILITY CONSTRAINT AND THE PCLR WOULD BE LIMITED ON A HUNDRED. THEY WOULDN'T FACE THAT STABILITY CONSTRAINT, BUT INSTEAD THEY WOULD CREATE A GTC TO MANAGE THAT. AND THAT SEEMS A STRANGE OUTCOME WITH A RELIABILITY FOCUS IN MIND. AND I GUESS LIKE THE OVERALL, YOU KNOW, THING I'M CONCERNED ABOUT, AND I WOULD LIKE CONFIRMATION FROM ERCOT IS, IS CAN WE CONFIRM THE CREATION OF ANY GTCS OR IOLS FROM THIS PROCESS, CONSIDERING THAT THIS COULD ADD A LOT OF LOAD RATHER QUICKLY, UH, WON'T IMPACT THE FIRM DELIVERABILITY OF ANY OTHER EXISTING LOADS RETAIL LOADS LIKE DISTRIBUTION LOADS, ANYTHING LIKE THAT. AND FRAMING IT IN THE DISCUSSION OF, YOU KNOW, THE ONGOING URGENCY OF 1315 IN FAR WEST TEXAS AND KNOWING THAT CREATING SOME [02:00:01] OF THESE LIMITS INVOLVES MITIGATION PLANS, WHICH GOES OUTSIDE THE SCOPE OF, OF SCED. CAN WE GET THAT CONFIRMATION THAT THAT'S BEEN THOUGHT THROUGH AND THERE WON'T BE ANY IMPACT THERE? SO, UM, LET, LET ME SAY IT LIKE THIS. SO ASSUMING THAT WE DESIGNED THE STUDIES CORRECTLY, UM, WHICH YOU COULD ARGUE MAYBE WE DIDN'T AND THAT'S HOW WE GOT INTO THE FAR WEST ISSUE. BUT ASSUMING THAT WE DESIGNED THE STUDIES CORRECTLY, THEN WE SHOULD, I SHOULD IDENTIFY THAT UPFRONT AS PART OF THE BATCH STUDY. AND, AND SO THIS IS WHY WE'RE LOOKING AT IN BATCH STUDY, THE, THE, THE SCOPE IS CONSIDERING THINGS LIKE NO SOLAR SCENARIOS SO THAT WE MAKE SURE THAT WE'RE CAPTURING THOSE ISSUES. YEAH, I, I APPRECIATE THAT. AND I AGREE WITH THAT SENTIMENT. I JUST WANNA FLAG THE WORD ASSUMING IS DOING SOME HEAVY LIFTING THERE AND THEY, YOU KNOW, TO SAY ABOUT ASSUMING, UM, YEP. AND SO I, I JUST WANNA HIGHLIGHT THAT, THAT THAT PROBABLY NEEDS TO BE FRONT AND CENTER. 'CAUSE THAT'S A, A HUGE CONCERN FOR US. UM, BECAUSE I, I AGREE WITH THE GENERAL CONCEPTS OF WHAT PCLR IS TRYING TO DO, BUT NOT THINKING THROUGH IT TO THAT EXTENT. I'M AFRAID WE COULD BE WALKING DOWN THE SAME PATH THAT WE'RE FACING RIGHT NOW. YEAH. I I THINK THE ISSUE IS NOT IN THE CONCEPT OF, OF THE PCLR, THE ISSUE IS IN THE STUDY SCOPE, WE, WE'VE GOT TO GET THE STUDY SCOPE CORRECT SO THAT WE ARE IDENTIFYING, UH, THOSE ISSUES. YEAH. IT'S ALL ABOUT THE ASSUMPTIONS THAT GO INTO THE STUDY. SO IF, IF WE, IF WE DON'T DO THE STUDY CORRECTLY, THEN YEAH, WE, WE, WE COULD MISS ISSUES IF, IF WE HAVE BAD ASSUMPTIONS THAT GO INTO THAT STUDY. BUT I, I THINK THAT'S MORE A STUDY ISSUE. IT'S, IT'S NOT IN THE FRAMEWORK OF WHAT A-P-C-L-R IS. YEAH. I TOTALLY AGREE WITH THAT STATEMENT. AND I THINK A CONCLUDING THOUGHT THEN FROM MY SIDE WOULD BE, AND IT'S SOMETHING I'VE SAID AT THESE MEETINGS BEFORE, KIND OF RECOGNIZING THAT, YOU KNOW, BESIDES IDENTIFYING SOMETHING THAT MAYBE NEEDS TO BE STUDIED IN THE QSA, INCLUDING THIS CONCEPT IN BATCH ZERO DOESN'T ACHIEVE ANYTHING NEW, RIGHT? IT'S NOT CHANGING THE TRANSMISSION PLAN THAT'S GONNA BE SENT TO RPG, IT'S NOT REALLY CHANGING THE LOAD COMMISSIONING PLAN, YOU KNOW, IF YOU STUDIED IT AS A FIRM LOAD, YOU'RE STILL GONNA GET THAT, THAT UH, UH, LPC VALUE AS WELL. AND WE SAID WE'RE GOING TO IGNORE THE MPC. UM, SO BUILDING OFF YOUR POINT, LIKE WE NEED TO TAKE, YOU KNOW, STUDY THIS VERY CAREFULLY AND THERE'S A LOT OF ASSUMPTIONS THAT WE NEED TO BE VERY CAREFUL ABOUT THE GO INTO IT. I THINK THAT THIS COULD BE BEST DEALT WITH AS SOMETHING THAT IS, UM, COMES AFTER THE BATCH ALLOCATION. SO YOU GET YOUR FIRM LOAD ALLOCATION AND THEN YOU'RE ABLE TO, UH, PERFORM THOSE STUDIES THAT NEED TO BE DONE AND A RELIABLE MANNER TO SAY, OH, WELL NOW I CAN COME ONLINE THIS MUCH EARLIER. AND I THINK YOU STILL MEET THE EXACT SAME TIMELINES THAT THE PCLR IS TRYING TO CONTEMPLATE TODAY. UM, THAT JUST SEEMS LIKE A BETTER WAY TO STUDY IT. MAYBE YOU NEED TO DO IT IN 87 60, MAYBE YOU NEED TO DO MAYBE EXTRA SNAPSHOTS. UM, THAT'S JUST SOMETHING I WANNA THROW OUT THERE. YEAH, I, SO, UM, I, I, I THINK THE ISSUE IS, IS, IS THE STEADY TIMELINE, UM, IT, IT, IT, BECAUSE IT'S EXTRA ANALYSIS LIKE I, I THINK WE WOULD NOT BE ABLE TO PROMISE THAT WE COULD GET THAT DONE IN THE SAME TIME PERIOD. WELL, THAT'S AN EXCELLENT POINT. AND I GUESS I WOULD ASK, RECOGNIZING HOW DIFFICULT THIS STUDY IS THAT WE'RE TOUCHING ON, HOW MUCH DOES IT ADD TO THE TIMELINE FOR BATCH ZERO? LIKE IF WE TOOK THIS OUT, WILL WE SHAVE BATCH ZERO STUDY TIMELINE BY THREE MONTHS, OR ARE WE APPROVING THIS IN ADDING ON THREE MONTHS? BECAUSE I THINK EVERYONE IN THE ROOM WOULD AGREE THE PRIORITY IS GETTING THAT PART DONE FASTEST. AND IF WE CAN TAKE, YOU KNOW, THAT THREE MONTH TIME THAT IT TAKES TO DO IT AND DO IT IN, WHAT WOULD IT BE LIKE Q3 OF 27? I MEAN, PEOPLE THAT STILL HAD A 28 ENERGIZATION DATE THAT'S PENDING 1188 WILL STILL MEET THEIR 28 ENERGIZATION DATE BECAUSE YOU CAN GET IT STUDIED IN THAT TIME. MAKE SURE I UNDERSTAND. SO YOU'RE, YOU'RE PROPOSING, UM, OR ARE, ARE YOU PROPOSING THAT WE EXTEND THE STUDY TIMELINE OF BACHELOR SO WE COULD DO THE EX, SO, SO INSTEAD OF FINISHING BATCH ZERO IN JANUARY, WE WOULD FINISH IT LATER IN THE YEAR SO WE COULD DO THE EXTRA ANALYSIS? NO. SO I GUESS IT'S TWO PARTS. MY QUESTION IS, THESE STUDIES WE'RE TALKING ABOUT TO IDENTIFY THE RISKS OF P CLRS ON A RELIABILITY STANDPOINT, HOW MUCH DOES THAT ADD TO THE BATCH ZERO TIMELINE THAT'S CURRENTLY BEEN PRESENTED AND TAKING THAT OUT, WOULD IT POTENTIALLY REDUCE IT? I'M JUST, I DON'T KNOW IF IT'S ALREADY BAKED IN OR NOT. AND THEN THE SECOND PART IS MY, I GUESS YOU COULD CALL IT A PROPOSAL, BUT [02:05:01] JUST KIND OF THINKING OUT LOUD, AN IDEA HERE IS THAT, YOU KNOW, RECOGNIZING YOU'RE NOT REALLY ACHIEVING MUCH MATERIAL DIFFERENCES BY INCLUDING IT IN BATCH ZERO. YOU COULD ACHIEVE THE SAME OUTCOME BY PERFORMING THIS STUDY AFTER BATCH ZERO, AND YOU COULD DISCONNECT IT FROM THIS PROCESS ALTOGETHER, AND THUS YOU WOULDN'T BE, YOU KNOW, SLOWING THINGS DOWN IF THAT IS WHAT THE OUTCOME COULD BE. AND I THINK YOU WOULD STILL ACHIEVE THE SAME RESULTS. AND I THINK, YOU KNOW, WE'D ALSO PROBABLY TAKE A LITTLE BIT OF PRESSURE OFF OURSELVES FOR REALLY TIGHT VOTING SCHEDULES AND VOTING ON THIS, YOU KNOW, KIND OF INDEPENDENT CONCEPT VIA COMMENTS WHEN IT COULD GO ITS OWN ROUTE. YEAH, I'M NOT SURE AND FOLLOWED ALL THAT. I, I'LL SAY THE, UM, FOR, FROM A STUDY PERSPECTIVE, IT, IT'S, NO, NO DIFFERENCE IN THE NUMBER OF STEPS RIGHT NOW TO, TO DO THIS IT, BUT IT'S MORE, UM, A, A DIFFERENCE IN THE ASSUMPTION IN THE STABILITY STUDY THAT I THINK THAT'S THE DIFFERENCE BETWEEN A PC FROM A STUDY PERSPECTIVE. THAT'S THE DIFFERENCE BETWEEN A-P-C-L-R AND NON JUST REGULAR KEEP USING THAT TERM, BUT REGULAR LARGE LOAD, UH, THAT THAT'S THE ONLY DIFFERENCE IS HOW WE STUDY THAT INSTABILITY. UM, YEAH. SO, BUT YEAH, ANY, SO, SO THE, THE MEAT OF THE STUDY, IF I'M UNDERSTANDING CORRECTLY, WOULD COME AT THE QSA, UH, NO, THE, THE, UM, SO, SO THE, UM, THE STABILITY STUDY, IS IT THAT'S STILL HAPPENING AS PART OF THE, UM, AS, AS PART OF THE BATCH STUDY? YEAH. IT'S JUST A DIFFERENT ASSUMPTION THAT WE'RE MAKING ON WHETHER WE'RE STUDYING THE ALLOCATED LOAD OR THE FULL REQUESTED LOAD. AND I, AND I UNDERSTAND WHY THAT DOESN'T TAKE MUCH TIME BECAUSE WE'RE BASICALLY, IT'S THE SAME STUDY IGNORING IT, RIGHT? WE'RE IGNORING THAT LIMIT IS KIND OF WHAT I HEARD, UM, FOR LACK OF BETTER WORDS. RIGHT. SO IF WE'RE GOING TO IDENTIFY THE REAL RELIABILITY IMPACT FROM A STABILITY STANDPOINT, YOU SAID WE'LL IMPLEMENT GTC. SO IT SOUNDS LIKE THE BULK OF THAT ANALYSIS WILL BE PERFORMED DURING THE QSA, THE, THE GTC IDENTIFICATION ITSELF IS DONE DURING THE QSA. YES. RIGHT. SO IT SEEMS LIKE WE'RE ASSESSING THE RELIABILITY IMPACTS FROM A STABILITY STANDPOINT OF THE PCLR, NOT IN BATCH ZERO, BUT AFTER THE FACT BEFORE ENERGIZATION, THE, THE BATCH, THE BATCH ZERO STUDY IDENTIFIES IT, IT, IT'S, UM, IT, IT IDENTIFIES IF THERE IS A STABILITY LIMITATION, DOES NOT IDENTIFY HOW, HOW ARE WE GONNA MANAGE THAT IN REAL TIME? YEAH, I THINK THAT'S THE, THE CLEAR THAT'S THE, THE, THE DELINEATION IS THAT I DO NOT AGREE WITH YOUR CHARACTERIZATION THAT WE ARE IGNORING LIMITS OR NOT ASSESSING LIMITS IN BATCH ZERO. HOWEVER, HOW WE WILL MANAGE THEM IS NOT DETERMINED UNTIL THE QSA, WELL, NO ONE'S SAYING THEY'RE NOT STUDIED. RIGHT. UM, YOU STUDY EVERY FIRM LOAD AT ITS MAXIMUM FOR STEADY STATE AND FOR STABILITY AND YOU GET TWO SETS OF LIMITS, RIGHT? SO I DON'T SEE WHY YOU DO ANYTHING DIFFERENT FROM PCLR. AND I'M NOT SAYING THAT YOU ARE DOING ANYTHING DIFFERENT FROM PCLR. AND I GUESS THAT'S MY POINT IS THAT THERE'S NOTHING UNIQUE BEING STUDIED FOR PCLR IN THE BATCH PROCESS, BUT THE RELIABILITY IMPACTS OF PCR ARE REALLY BEING ASSESSED IN THE QSA AND SO, NO, BUT I THINK THAT'S WHERE WE DISAGREE. OKAY. EVAN IS, I THINK WE WE'RE, UM, AND BY NRC FACT TWO, WE HAVE TO, UH, STUDY AS PART OF THE INTERCONNECTION STUDY, WE HAVE TO RE STUDY THE RELIABILITY IMPACTS. THE, THE QSA IS MORE HOW DO WE MANAGE THAT IN REAL TIME? IT'S, IT'S NOT IDENTIFYING THAT THE IMPACT IS IDENTIFIED IN THE BATCH STUDY. YEP. I TOTALLY UNDERSTAND. AND I, I DON'T WANNA BELABOR THIS, BUT THAT JUST CREATED A, A CLARITY QUESTION. SO THE PCLR AND A FIRM LOAD, IF I DIDN'T CHECK THE BOX TO SAY I'D BE A-P-C-L-R, HOW AM I BEING STUDIED ANY DIFFERENTLY? YOU, YOU, UM, WHEN YOU GET TO THE STABILITY PART OF THE BATCH STUDY MM-HMM . YOU'RE, UH, WE'RE ONLY STUDYING YOUR ALLOCATED MEGAWATTS. OKAY. ALLOCATED. SO, YEAH, SO YOU, YOU COME IN AT 500 AND WE, WE CAN ONLY SERVE A HUNDRED MEGAWATTS. SO IF YOU'RE NON P-P-C-L-R, THEN IN THE STABILITY ANALYSIS, WE'RE ONLY STUDYING YOU AT A HUNDRED MEGAWATTS. BUT IF YOU'RE A-P-C-L-R, WE'RE STUDYING YOU AT 500. 'CAUSE WE NEED TO IDENTIFY IF THERE'S A RELIABILITY IMPACT AT AT 400 MEGAWATTS AS AN EXAMPLE. OKAY. SO, SORRY, JUST TO BE CLEAR, THE FIRM LOAD LIMITED IN STEADY STATE AT A HUNDRED WOULD BE STUDIED IN [02:10:01] STABILITY AT A HUNDRED, BUT THE PCLR LIMITED IN STUDY STATE AT A HUNDRED WOULD BE STUDIED AT 500 INSTABILITY. YES. WHY ARE YOU, I GUESS, WHY ARE YOU DOING IT THAT WAY FOR FIRM LOAD? WHY WERE YOU NOT STUDYING WHAT WAS REQUESTED IN BOTH SETS OF STUDIES? UM, I THINK IT'S BECAUSE IF, UM, THE STABILITY ANALYSIS IS BY NATURE HARDER, UH, AND, AND SO IT WILL BE HARDER TO SOLVE THAT CASE IF IT HAS, UM, YOU KNOW, SO SAY, SAY I HAVE AN AREA WITH 10,000 MEGAWATTS OF REQUESTS, BUT THERMALLY, YOU KNOW, WE CAN ONLY SERVE 2000 MEGAWATTS IN THAT AREA. UH, IT, IT'S GONNA BE A LOT HARDER TO SOLVE THAT STABILITY CASE AT 10,000 MEGAWATTS THAN IT IS AT 2000. OKAY. AND SO IT'S JUST, IT'S A FUNCTION OF, YOU KNOW, BEING EFFICIENT AND BEING ABLE TO GET THAT STUDY DONE IN THAT TIMEFRAME THAT WE'RE SAYING WE CAN GET IT DONE FOR, FOR A BATCH. OKAY. I APPRECIATE THE EXTENDED DIALOGUE AND THANKS MATT FOR LETTING ME TAKE FIRST TIME. NO, I APPRECIATE, BECAUSE I THINK THERE'S A THEME EVOLVING, WHICH IS HOW DO WE MAKE SURE HOW ALL THIS STUFF IS TOGETHER. SO THANKS, UH, ONTO CRAIG SCHWAR. CRAIG, IF YOU'RE SPEAKING, WE DON'T HEAR YOU YET. ALRIGHT. WE'LL MOVE ON TO BOB KING. THANK YOU. UM, I WAS KIND OF HAD THE SAME QUESTION AS NEIL, UM, BUT I GUESS MY CONCERN IS IF, IF JEFF, IT'S EASIER TO STUDY THE 2000 THAN THE 10,000, BUT AGAIN, IF I'M PART OF THE 10,000 THINKING I'M GONNA GET AT LEAST SOME OF THE TIME TO GO TO MY PEAK, WHEN WILL I KNOW WHAT THE STABILITY, I GUESS YOU'RE SAYING THE STABILITY LIMIT WILL BE IDENTIFIED IN THE BATCH AND THAT WILL BE KNOWN TO ME. SO I'LL KNOW THAT THIS AREA IS LIMITED TO 5,000 BASED ON STABILITY OR SOMETHING. I, I, I DON'T THINK THAT WE'VE FIGURED OUT HOW WE'RE GOING TO COMMUNICATE THOSE RESULTS. UM, I I THINK THAT, UH, THAT THAT'LL BE IN THE REPORT, WHATEVER THE REPORT LOOKS LIKE. BUT, UM, JUST YEAH, BE FRANK, I I WE, WE HAVEN'T TALKED THROUGH WHAT, WHAT IS THE REPORT GOING TO SAY? UM, SO, SO THIS ENDS UP BEING IMPORTANT FOR ME, DECIDING WHETHER TO MAKE A FINANCIAL COMMITMENT, BECAUSE I DON'T KNOW IF I CAN ACTUALLY GET THIS FLEXIBLE AMOUNT, WHICH I AM HOPING THAT I CAN, BUT THERE'S MAYBE SOME HIDDEN INFORMATION THERE. BUT ALSO I'M, I HEARD EARLIER, I'M GONNA MAKE MY FINANCIAL COMMITMENT BASED ON THE TOTAL AMOUNT AND, UM, AS IT STANDS RIGHT NOW, THAT'S NOT RECOVERABLE IF REALLY THE TOTAL I'M ALLOCATED IS LESS THAN WHAT I ASKED FOR AND THOUGHT I HAD, UH, NO FAULT OF MY OWN. AND IN A SIMILAR WAY, EVEN IF I PUT DOWN SECURITY UP TO 80% OF THAT IS NON-REFUNDABLE, IF I DON'T REACH A HUNDRED PERCENT , AND AGAIN, IF I REACH A HUNDRED PERCENT, IT'S NOT EVEN MY PROBLEM. YOU KNOW, IT'S LIMITED BY ERCOT, NOT BY ME. I DON'T RECOVER. SO WHEN YOU'RE TALKING WITH PUC, I THINK WE NEED TO HAVE SOME RECOVERABILITY CONSIDERED FOR THINGS WHICH ARE NOT THE FAULT OF THESE LOADS AT THE VERY LEAST. AND TO THE EXTENT THAT WE CAN GET MORE INFORMATION ABOUT WHAT THE REAL LIMIT IS, THAT'S SO IMPORTANT. I MEAN, WE WERE BEGINNING WITH THE IDEA THAT AT THE END OF THE BATCH WE HAD A FIXED AMOUNT, EVEN IF THINGS CHANGE, PEOPLE DROP OUT, WHATEVER THE REFINEMENT IS TO STUDY HOW TO GET ME THAT. BUT NOW I'M HEARING IN SOMETIME IN THE REFINEMENT OR LATER THE QSA COULD PUT ANOTHER LIMIT, THEN AGAIN, FUNDING'S NOT RECOVERABLE THE DECISION TO CONSTRUCT MAYBE'S ALREADY BEEN MADE. SO THESE ARE IMPORTANT LITTLE FINE POINTS. BOB, I I WANT TO, I WANNA REITERATE SOMETHING THAT WE SAID, UH, A COUPLE TIMES. THE REFINEMENT, THE LOAD WILL HAVE TRANSMISSION TO BUILD BUILT TO SERVE IT AS IF IT WERE A FIRM LOAD. THAT IS THE, THE LANGUAGE WE SHOWED IN THE REFINEMENT STUDY IS THAT A-P-C-L-R WILL STILL HAVE ITS FULL REQUESTED LOAD EVENTUALLY SERVED BY TRANSMISSION. SO IT WILL HAVE, IT'LL BE TREATED IN THE REFINEMENT STUDY EXACTLY THE SAME AS, UH, A, A FIRM LOAD AND WILL ULTIMATELY HAVE TRANSMISSION BUILT TO SERVE. WHAT THE DISCUSSION HAS BEEN TALKING ABOUT HERE IS WHETHER OR NOT THE QSA AND A POTENTIAL GTC TO ADDRESS ANY STABILITY ISSUES MIGHT LIMIT HOW MUCH COULD GET ON EARLIER. BUT THERE IS NO DISCUSSION [02:15:01] HAPPENING OF SOME SORT OF PERMANENT LIMIT LATE IN THE GAME THAT WOULD LIMIT THE LOAD BELOW ITS FULL REQUESTED AMOUNT. WHAT WE ARE DISCUSSING IS THERE IS NOT ENOUGH BANDWIDTH AND NOT ENOUGH TIME IN THE STUDY TIMELINE TO BE ABLE TO DEFINITIVELY ANALYZE AND SAY, WELL, YOU KNOW, THIS PERCENTAGE OF THE YEAR YOU CAN CONSUME UP TO YOUR FULL AND THEN THIS PERCENTAGE YOU MAY BE LIMITED BY 20 PER, THAT'S JUST NOT POSSIBLE, UM, WITHIN THE, THE TIMELINE THAT'S BEEN ESTABLISHED FOR BATCH ZERO. SO, UM, BUT I REALLY DO WANT TO BE VERY CLEAR THAT THE, THE FINANCIAL SECURITY ASPECT OF THIS AND WHAT IS ULTIMATELY BUILT IS BASED ON THE FULL AMOUNT. AND THE REASON THOSE TWO ARE THE SAME IS BECAUSE WE WILL BUILD AND THE TRANSMISSION WILL REFLECT WHAT IS NEEDED TO SERVE THE FULL AMOUNT EVENTUALLY. OKAY. INCLUDING STABILITY ISSUES. CORRECT. THANK YOU FOR CLARIFYING THAT. ALL RIGHT, SO WE'RE IN RUSH TO THE FINISH HERE ON 14 MINUTES OF QUESTIONS. WE'RE BACK TO CRAIG, DO YOU GET OUR AUDIO RESOLVED? YEAH. CAN YOU GUYS HEAR ME OKAY? YEP. LOUD AND CLEAR. GO AHEAD. AWESOME. OH MY GOSH. ALL RIGHT. YEAH, CRAIG SQUARE ADVANCE POWER. UM, THANKS FOR, UH, CLARIFYING A FEW OF THESE QUESTIONS FOR, UM, I JUST HAD A COUPLE OF BASIC ONES ON, IF WE DO ELECT TO BECOME A-P-C-L-R, UNDERSTANDING THE, THE LAST POINT THERE ON THE STABILITY, YOU'RE, YOU'RE STUDYING THAT, UM, A LITTLE BIT DIFFERENTLY. SO I GUESS JUST LEMME READ IT BACK TO YOU, MAKE SURE I, I I UNDERSTOOD, UM, YOU KNOW, YOU'RE, YOU'RE SUBMITTING AN LPC AMOUNT RIGHT, FOR A-P-C-L-P-C-L-R ELECTION, AND AM I CORRECT IN ASSUMING THAT IT'S GOING TO BE FOR FIVE YEARS? SO FOR EXAMPLE, IF MY FIRM LOAD REQUEST IS A GIG AND I WANNA BE A-P-C-L-R, AM I SUBMITTING SAY, A HUNDRED MEGAWATTS IN YEAR ONE AS MY LPC AND THEN POTENTIALLY INCREASING THAT IF I THINK THE UPGRADES WILL BE, UM, IMPLEMENTED AND SAY YEARS FOUR AND FIVE AND I CAN MAYBE GET A HIGHER AMOUNT. I UNDERSTAND THAT THAT'S NOT WHAT ERCOT IS GONNA STUDY FOR, BUT IT'S SOMETHING THAT I CAN MAYBE TAKE A STANCE ON. UM, IS THAT, IS THAT GENERALLY CORRECT? I, I WOULD BE SUBMITTING LPC ALLOCATIONS FOR EACH OF THE FIVE STUDY YEARS IF I WAS AT PCLR. DO I GOT THAT RIGHT? HEY GREG, THIS IS AJI. UM, I, I WOULD CHARACTERIZE IT A LITTLE BIT DIFFERENTLY AND I'M SORRY I PULLED UP NOT WHAT I INTENDED TO PULL UP. SO BEAR WITH ME ONE SECOND. SO THE, THE IDEA HERE IS WE'RE WANTING YOU AS THE CUSTOMER TO TELL US BASED ON WHAT YOU'RE INTENDING TO BUILD THE AND YOUR DESIRED CONSTRUCTION SCHEDULE, WHAT IS THE MINIMUM AMOUNT OF FERN LOAD THAT IS NEEDED OR THAT IS PHYSICALLY POSSIBLE TO MAKE ALL THAT VIABLE? SO, UM, WE'RE NOT ASKING YOU TO TRY AND SAY, WELL, I THINK I CAN PROBABLY GET UPGRADES, YOU KNOW, FROM MY, MY, UH, WIRES COMPANY BY YEAR FOUR. SO I'M GONNA PUT A BIG JUMP THERE. 'CAUSE I THINK THAT'S WHEN I'M NO, IT, IT IS REALLY MORE, UM, WE NEED TO KNOW A VALUE BELOW WHICH, YOU KNOW, IF WE SAY, YOU KNOW, ONLY 50 MEGAWATTS IS AVAILABLE IN 2028 AND YOU KNOW BY YOUR DESIGN, THAT THAT IS NOT GOING TO WORK BECAUSE YOU NEED AT LEAST A HUNDRED AFFIRM TO MAKE THE WHOLE, YOU KNOW, WHAT YOU'RE CONSTRUCTING WORK. THAT'S WHAT WE'RE TRYING TO FIND OUT. THE STUDY WILL THEN TELL YOU WHAT IS ACTUALLY SERVABLE. SO AGAIN, AS I WAS SAYING IN MY VOICEOVER, UM, IF YOU SAY YOU NEED AT LEAST A HUNDRED AND WE IN BATCH ZERO DETERMINED THAT 150 IS AVAILABLE TO SERVICE FIRM, THEN YOU'LL BE ALLOWED TO HAVE FIRM SERVICE UP TO THAT ONE 50. SO THE STUDY WILL THEN TELL YOU KIND OF WHAT IS ACTUALLY FEASIBLE BASED ON CONSTRUCTION TIMELINES. RIGHT. AND IT'S ON ME, THE LLIE TO KIND OF PREPARE FOR ANY SHORTFALLS. SO IF I SUBMIT FOR A HUNDRED MEGAWATTS OF AN LPC, YOU SAY, HEY, THE GRID CAN PROVIDE ONE 50, SO THEN THAT ONE 50 WOULD BECOME MY NUMBER FOR THAT PARTICULAR STUDY YEAR. CORRECT. RIGHT. SO WHAT WE'RE SAYING IS, IS THAT EXTRA 50 MEGAWATTS WOULD NOT HAVE TO BE FLEXIBLE, IT COULD BE FIRM. RIGHT. AND THEN, UM, YOU KNOW, IF IT WAS BELOW, SAY IT WAS LIKE 99 WAS AVAILABLE, WHICH IS LESS THAN MY 100 MEGAWATTS THAT I ASKED FOR, YOU ERCOT ARE GONNA GIVE ME ZERO MEGAWATTS OF FIRMS. IS THAT CORRECT? IT'S LIKE PASS FAIL ALMOST TEST IS MY UNDERSTANDING. THAT'S THE CONCEPT THAT'S CURRENTLY DRAFT. OKAY, GOT IT. SO I GOTTA BE, THAT PROTECTS AGAINST AND PROTECTS YOU GUYS ON ME BEING OVERZEALOUS AND SAY, I'LL THROW OUT 700 MEGAWATTS AND IF IT'S 500, THEN WHATEVER, I TAKE 500. SO I UNDERSTAND THE IMPLICATION THERE, AND IT'S GONNA BE ON US TO KIND OF GO ABOUT THAT IN A RATIONAL WAY WHEN WE'RE FORECASTING HOW MUCH WE ACTUALLY NEED AND WHAT WE CAN EXPECT TO GET FROM, YOU KNOW, OTHER SOURCES OF POWER LIKE BRIDGE POWER. UM, AND THEN SECOND, SORRY, AS I WAS, I WAS MOVING POSITIONS, I, I DON'T KNOW IF THE PREVIOUS PERSON ASKED THIS QUESTION, I'M JUST LOOKING [02:20:01] AT FOR A TIMING CONFIRMATION. IT SOUNDS LIKE, UM, WITH THIS OFF RAMP DATE, UM, WHERE YOU WILL PRESUMABLY KNOW WHEN YOU'RE GONNA GET THE FULL FIRM POWER BECAUSE OF UPGRADES, REPLACE AND SERVICE, IS THAT DATE ROUGHLY GONNA BE KNOWN AFTER THE BATCH ZERO STUDY OR AFTER THE REFINEMENT STUDY? I KNOW, UM, YOU GUYS STILL TALKED ABOUT THAT BEFORE, BUT I, LIKE I SAID, I WAS MOVING DURING THAT CONVERSATION. YEAH. THE, THE INTENTION WOULD BE, IT WOULD BE AFTER THE BATCH ZERO INTERCONNECTION STUDY, IT WOULD BE KNOWN TO THE INTERCONNECTING LARGE LOAD ENTITY AT THE START OF THE COMMITMENT PERIOD. AND AT THAT POINT, UH, SO EFFECTIVELY WHAT'S GOING TO HAPPEN IS, UM, AT THE END OF BATCH YEAR IN CONNECTION STUDY, UH, WE WILL BE PROVIDING THESE, THIS AGREEMENT FORM BACK TO THE TA THE WIRES COMPANY IS WITH THE TOP HALF OF PART B FILLED IN. SO THE EXIT DATE, UM, YOU KNOW, THE, THE TOTAL LOW REQUEST IS KIND OF A DO OVER FROM, YOU KNOW, YOUR ORIGINAL REQUEST AND THEN THE LOW POWER CONSUMPTION VALUES FILLED IN. UM, AND SO AT THAT POINT IT COMES BACK TO THE CUSTOMER TO MAKE A COMMITMENT DECISION TO MOVE FORWARD OR NOT. OKAY. AND THEN LAST QUESTION I GOTTA ASK IT, I MEAN, SAY AGAIN, I TAKE A STANCE ON INCREASING IN, IN YEARS, SAY 20 31, 20 32, UM, AND I'M STEPPING UP FROM MY 100 MEGAWATTS TO LIKE 300, RIGHT? AND YOU GUYS ARE GOING TO EVALUATE IT. WELL, WHAT HAPPENS IF IN 20, 20 31 THE GRID CAPABILITY IS SAY, 200 MEGAWATTS AND I HAD REQUESTED 300, RIGHT? I WAS BEING OVERZEALOUS. ARE YOU GUYS JUST THAT, THAT CASE JUST AWARDING THE 200 MEGAWATTS OR, I MEAN, IT DOESN'T MAKE ANY SENSE FOR YOU TO SAY, HEY, YOU FAILED THIS TEST, YOU NOW GET ZERO FOR THAT YEAR. YOU SEE WHAT I'M SAYING? YES. UH, I, I DON'T HAVE A UH, D DEFINITIVE ANSWER ON THAT ONE, BUT I AGREE WITH YOU. IN PRINCIPLE, WE, WE WOULD NOT OFFER ANY ALLOCATIONS THAT WOULD MIDWAY THROUGH THE RAMP SUDDENLY DROP TO ZERO. RIGHT. THAT MAKES SENSE. I, I APPRECIATE, I JUST WANTED TO ASK THAT QUESTION. SO, UM, THAT'S ALL I GOT. I REALLY APPRECIATE YOU GUYS POPPING BACK TO ME IN THE QUEUE TOO. THAT WAS A NICE GESTURE. GREAT. AND FOR NEXT WEEK, WE'LL, UM, FOR ROS WE WILL START TO CREATE SOME GRAPHICS OF THIS. I CAN SEE WE'RE HAVING A TIMELINE HOW THIS CHANGES OVER TIME WOULD HELP PEOPLE SEE HOW THIS FITS TOGETHER. SO, UH, EIGHT MINUTES LEFT. SO AUSSI, YOU'RE UP, ANDI, IF YOU'RE SPEAKING, WE DON'T HEAR YOU YET, IT WILL CIRCLE BACK. EY SHEI IF YOU'RE SPEAKING, WE DON'T HEAR YOU ON TO JOHN RUSS. THANK YOU. JOHN. RUSS HOVERED WITH TIEC. UM, I WAS TRYING TO UNDERSTAND SOMETHING WHEN YOU, WHEN YOU WERE TALKING ABOUT THE ENERGIZATION LANGUAGE BEING GRAY BOXED, DOES THAT MEAN THAT THESE PCR WOULD NOT BE ABLE TO ENERGIZE UNTIL THAT LANGUAGE IS UN GRAY BOX? AND WHAT DOES THAT TIMING LOOK LIKE AND HOW DOES THAT AFFECT THEIR PROPOSED ENERGIZATION DATES? YEAH, SO LET ME, LET ME GIVE A CLARIFICATION THERE. 'CAUSE YOU'RE, YOU'RE ABSOLUTELY RIGHT. I WAS NOT CLEAR. UM, REALLY WHAT I, I I THINK I PROBABLY SHOULD HAVE SAID IS, UM, I'M SORRY, I'M GONNA, I'M GONNA TALK HERE WHILE I SCROLL DOWN TO THE SECTION THAT I WAS, THIS MOUSE IS REALLY, HERE WE GO. NO, OKAY. ALRIGHT. SO, UM, OH, I WENT TOO FAR. THAT'S WHY I WAS BEING DIFFICULT. OKAY. I APOLOGIZE. LET ME GET BACK TO THE RIGHT SECTION. UM, THERE WE GO. OKAY. SO, UM, THE INTENT IS A LITTLE BIT MORE NUANCED THAN WHAT I SAID BEFORE. IT'S THAT THE, UM, FIRM LOAD AMOUNT WOULD STILL BE ABLE TO COME ON AS SCHEDULED. SO EFFECTIVELY WHAT, UM, AND, AND THIS MIGHT NEED TO HAVE SOME TWEAKS TO WHAT WE'VE HAD ON THE PAPER, BUT THE IDEA IS BASICALLY, UM, THIS FIRST PARAGRAPH SAYS, OKAY, YOU CAN, YOU CAN BRING ON YOUR UP TO YOUR LOW POWER CONSUMPTION LEVEL BY MEETING THE, THE EXISTING LANGUAGE IN 9.6 PARAGRAPH ONE. AND SO THAT WOULD BE ABLE TO UNBOX FIRST. IT WOULD JUST BE EVERYTHING AFTER THAT. PERFECT. THANKS. ALL RIGHT, NEXT IS BROTH. HEY, UH, SO TWO QUESTIONS. SO FOR LOADS TO BE IN CLR, THEY STILL HAVE TO SATISFY THE EITHER 9.2 0.1 0.2, RIGHT? WHETHER THE STUDIES ARE INVALID DEEMED BY ERCOT OR ONE OF THOSE STUDIES NEED TO BE APPROVED. SO THEY NEED TO QUALIFY FOR BADGE ZERO AND THEN ONLY THEN THEY CAN, UH, BE OPTING IN AS ACL R. IS THAT ACCURATE? CORRECT. THERE, THERE IS NOTHING IN [02:25:01] THE COMMENTS THAT WE'VE DRAFTED THAT WOULD IMPACT ANYBODY'S ELIGIBILITY FOR BAP ZERO. OKAY. THE SECOND QUESTION IS, IF THERE IS A BASE LOAD, CAN THEY OPT IN FOR CLR FOR AN EXTENSION WITH THEIR LCP? I FORGOT THE LANGUAGE BEING THE BASE LOAD AMOUNT. UM, NOT AS CURRENTLY DRAFTED. UM, BUT I, I, I THINK THAT'S SOMETHING WE COULD DISCUSS MORE INTERNALLY. OKAY, THANKS. ALRIGHT. AND IF SOMEONE CAN LOOK AT SHE'S QUESTION AND ASK HER DIRECTLY OF WHETHER S OR RYAN MIGHT BE ABLE TO LOOK INTO THE CHAT. SO WE'LL KEEP GOING. UM, KEVIN HANSEN? YEAH, SO WE'RE DOWN. THE LAST THREE QUESTIONS. KEVIN, DURKA AND LEAD THEN WE'RE TAKING CAN MOVE YEAH. FOLLOWING THE TWO QUESTION RULE. UH, FIRST QUESTION IS TRANSMISSION SOLUTIONS THE ONLY WAY TO RESOLVE THE LOW GTC OR WILL NEW GENERATION AND ALSO BE PART OF THE SOLUTION? SO RK KOTT CANNOT, UM, RECOMMEND THAT THAT'S NOT WITHIN THE SCOPE OF THINGS THAT WE CAN RECOMMEND, BUT IF, IF A NEW GENERATOR WERE TO SHOW UP AND, AND, UM, EXIT THAT, THEN UM, YOU KNOW, OBVIOUSLY THE STUDY ASSUMPTIONS WOULD GET UPDATED AND WE WOULD, YOU KNOW, THAT THAT WOULD SHOW UP IN THE ANALYSIS. BUT, OR SIMILAR TO ANY OTHER TRANSMISSION PLANNING ANALYSIS, ERCOT DOESN'T RECOMMEND GENERATION. SO A SUB A TO THAT QUESTION THEN THAT RESPONSE, HOW, HOW FAST WOULD ERCOT LOOK AT RESOLVING THE GTC? WE, UM, WE HAVE 180 DAYS, UH, UNDER I THINK IT'S PLANNING GUIDE. IT MIGHT BE PROTOCOLS TO DO A GTC EXIT PLAN. SO IF THERE'S NEW GENERATION THAT COMES SHOWS UP WITH THE 980 DAYS, YOU'LL LOOK AT IT AND CONCERN THE SOLUTION. UH, I I THINK IT'S FROM WHEN THE GTC STARTS. UM, I I THINK IT WOULD BE N NEXT NEXT PLANNING CYCLE. OKAY. THANKS. MY SECOND QUESTION, UM, IN TERMS OF THE TIMELINE, WHICH YOU HAD THE, THE TABLE THERE, LIKE FROM 2028 TO 23 3, ASSUMING YOU GOT APPROVED IN 23 3 FOR A FULL GIGAWATT AND 2028, YOU'RE ONLY A HUNDRED MEGAWATTS, COULD YOU BRING YOUR OWN BEHIND THE METER GENERATION TO SERVE THE 900 MEGAWATT DIFFERENTIAL OR NOT AND THEN GRADUALLY REMOVE THAT GENERATION? NO. UH, THAT WE, I THINK WE SAID A COUPLE WORKSHOPS AGO THAT, UM, ANY SORT OF MIXING BETWEEN BRING YOUR OWN GIN AND CLR IS, IS OUT OF SCOPE FOR BATCH ZERO, BUT I CAN INCREMENTALLY ADD THE LOAD AND NOT PUT THE GENERATION EVER ON THE GRID IF I WANT TO CORRECT. THIS IS NON-REGISTERED. UH, YEAH, IF IT'S NOT CONNECTED TO THE GRID. NOT CONNECTED TO THE GRID, YEAH, YOU CAN DO WHATEVER YOU WANT BEHIND THE FENCE, BUT THEN YOU CAN ADD ON THE LOAD AS WE GET PERMISSION OVER TIME. YES. OKAY, THANKS. IT IT JUST, IF YOU'RE SAYING THAT THAT LOAD UNTIL IT IS ABLE TO BE SERVED FROM THE GRID IS FIRM LOAD IS, UM, COMPLETELY OFF GUARD. CORRECT? YEAH. WHAT I'M SAYING IS THEN YES, I AGREE WHILE THE LOAD, I BUILD A GIGAWATT LOAD, BUT ONLY A HUNDRED MEGAWATTS IS CURRENTLY ON THE SYSTEM, BUT I GOT 900 MEGAWATTS BEING SERVED BASICALLY OFF THE GRID, NOT CONNECTED ALL AND THEN GRADUALLY BRING ON THE LOAD. I CAN DO THAT. OKAY, THANKS. YES, BUT I WOULDN'T PUT THAT IN THIS PCLR BUCKET. THAT'S FAIR ENOUGH. JUST WANTED TO ASK THE QUESTION IN GENERAL. THANK YOU. ALL RIGHT, WELL DURGA AND THEN LEE AND THEN WE WILL TRANSITION DURGA. HE'S WALKING UP. THANK YOU. UM, SO, UM, FROM MY UNDERSTANDING, UH, FOR STUDIES IN STEADY STATE, THE THE CUTOFF SHIFT FACTOR WAS 3%, RIGHT? AND THE SHIFT FACTOR FOR THE SKETCH STUDIES 2%. UH, CAN SOMEONE EXPLAIN WHY THERE'S A GAP? SO WE'LL HAVE A MORE OPTIMISTIC VIEW IN THE STEADY STATE AND MORE PESSIMISTIC VIEW IN THE REAL TIME? IS THAT HOW IT IS? YEAH, THE, THE 2% IN THE, AND BRIAN FEEL FREE TO CORRECT ME HERE, IS, UH, THE 2% IN THE 3% BID CAPPING METHODOLOGY IS TO ALIGN WITH, UH, THE OPERATIONAL PROCEDURES FOR ACTIVATING CONSTRAINTS, UH, IN SCED AND THAT WE MANAGED IT TO, UH, BASED ON THAT 2%, SHOULD WE MAYBE, UM, MAKE IT MORE CONSISTENT AND KEEP IT 2% IN THE STEADY STATE AS WELL? STEADY OR KEEP IT 3% AND 2%. I JUST WANNA UNDERSTAND WHY THERE'S A YEAH, I THINK WE CAN TAKE THAT BACK FOR FURTHER DISCUSSION. I, I ANYTHING TO ADD ON THAT RIGHT NOW? UH, THE SECOND QUESTION I HAVE IS IF A LOAD RIGHT NOW IS BEHIND THE METER AND WANTS TO OFFER PCLR, UM, IS THERE A PROVISION FOR THAT? BECAUSE I HEARD IT HAS TO BE FRONT OF THE METER. IS THAT STILL TRUE? YEAH, SO I THINK, UH, AND S I'M GONNA LET YOU JUMP IN AND CORRECT [02:30:01] ME IF I'M, IF I'M WRONG HERE, BUT, UM, I THINK WHAT S WAS SAYING EARLIER IS THAT UNDER NPR 1188, IF YOU HAVE A BEHIND THE METER LOAD THAT ELECTS TO BE ACL R, IT WILL BE METERED SEPARATELY AND EFFECTIVELY BECOMES FRONT OF THE METER. SO, UM, IT IS NOT REALLY POSSIBLE TO HAVE A TRADITIONAL BEHIND THE METER NET METER LOAD THAT IS ALSO ACL R. OKAY. SO, UM, SO SUB TSPS DON'T ALLOW NPR 1197 AND ALLOW FOR AN EXCLUSION METER. SO IF I OPT FOR A-P-C-L-R, DO I AUTOMATICALLY GET A EXCLUSION METER? SEPARATE PS LOAD DPS METER? YOU WILL. THE METERING REQUIREMENTS FOR A-P-C-L-R IS SAME AS A CLR UNDER NPRR 1188 AND THE METERING SETUP REQUIRES APPROVAL OF THE TSP? NO, I, I'M, I'M TALKING ABOUT TRANSITIONING FROM A BTM TO IF I'M A BTM AND APPLYING FOR A-P-S-C-L-R, SO I HAVE, I WOULD HAVE A SEPARATE PETER IS THAT YEAH, BUT THERE IS AN APPROVAL PROCESS BECAUSE THE KNOW THAT ESP IS THE ONE THAT SUBMITS THE DESIGN METERING DESIGN PROPOSAL AND THEY WERE VERY CLEAR THAT THEY DON'T LIKE INSTALLING METERS BEHIND THE FENCE. AND SO THEY HAVE A SAY YES OR NO. SO YOU WILL HAVE TO MAKE SURE THAT YOUR, UM, YOU HAVE THEIR APPROVAL. I MEAN, THEY'RE THE ONES SUBMITTING IT. IF THEY DON'T SUBMIT IT, IT'S, IT'S, ERCOT CAN'T DO ANYTHING ABOUT IT. THAT'S HOW THE PROTOCOLS ARE WRITTEN. SO TO SUMMARIZE, IF I WANT TO GO INTO PCR, I NEED TO GET THE TSPS APPROVAL FOR THAT. IF THEY SAY NO, I CANNOT GO AS A PCR. YEAH. AND THAT IS NOT JUST A RULE FOR PCR, IT'S A RULE FOR CLRS PERIOD. OKAY. OKAY. UNDERSTOOD. THANK YOU. UH, THANK YOU. LAST QUESTION. UH, LEE CHER, JUST A COMMENT. NORMALLY, UM, IT'S MY DEFAULT TO AGREE WITH EVAN NEIL ON ALL THINGS, BUT IN THIS CASE SLIGHT DIVERGENCE. I, I THINK THIS IS IMPACTFUL FOR LOADS AND I THINK THIS SETS OUR CUT AT THE FOREFRONT OF, OF EFFICIENT GRIDS. WHAT A GREAT NOTE TO END ON. AND WE'RE NOT GIVING THEN THE COUNTERPOINT HE DID HAVE GET IN THE QUEUE. SO EVAN, AT THE END OF MY BYOG, AT THE END OF MY BYOG, WE WILL SAY, IS THERE ANYTHING ELSE TO WRAP UP THIS DISCUSSION ON BOTH TOPICS? YEAH. COOL. ALL RIGHT, I'M GONNA GO TO THE FRONT SWITCH OUT TO YOU MR. A, UH, ALRIGHT, WELL [4. Further discussion of BYOG approach] I DON'T HAVE A LOT OF NEW INFORMATION TO SHARE, BUT WE WERE INTERESTED IN FEEDBACK OR INPUT TODAY ON BYOG. IF PEOPLE HAVE HAD MORE TIME TO THINK ABOUT IT, I KNOW THIS IS KIND OF A SOAKING PROCESS OF NOW WE UNDERSTAND MORE. NOW WE UNDERSTAND MORE. SO I ONLY HAVE THREE SLIDES. I ALREADY TALKED TOO FAST, BUT I WILL TRY TO GO SLOWLY THROUGH THEM TO LET IT SINK IN A BIT. UM, SIMILAR TO WHAT A G DID, I WANTED TO REMIND PEOPLE OF KIND OF THE PILLARS OF WHERE AND WHAT BYOG IS IN THIS CASE. SO NUMBER ONE IS HOW DO WE ALLOCATE IT IN BATCH? SO LOAD WOULD STILL BE ASSESSED THROUGH BATCH STUDY PROCESS, UM, BUT IT WILL CONSIDER CO-LOCATION WITH GENERATION. WE'RE NOT GONNA BUILD WIRES OUT TO A SITE IF THAT LOAD WHICH IS BEING STUDIED IS ALSO GONNA HAVE SIX GENERATORS THAT ARE REDUNDANT AND READY TO GO. SO IT'S N MINUS ONE G MINUS ONE SECURE. SO WE WON'T STUDY IT FOR PLANNING IN NEW WIRES, WE WILL PLAN IT FOR NEW WIRES WITH THE GEN, BUT WHEN IT COMES TO THE ALLOCATION PIECE, THAT'S WHERE WE WOULD STILL, UM, BE STUDYING IT AS IF IT WOULD NOT BE SERVED. AND WHAT IS THAT MAX, UM, AMOUNT THAT THEY COULD CONSUME? WHAT IS THEIR FIRM LOAD THAT THEY COULD BE GRANTED? SO JUST WANTED TO, I FUMBLED THAT A BIT. THERE'S ANOTHER BULLET IN A MINUTE, BUT HOW DO WE STUDY BYOG? IT'S A LITTLE DIFFERENT BETWEEN THOSE TWO DIFFERENT TYPES OF STUDIES. NOW, WHEN IT COMES TO LOAD AND GENERATOR, THIS IS THE COORDINATION THAT ERCOT CAN'T DO IS WHAT HAPPENS BEHIND THE FENCE TO ENSURE THAT THERE'S NEVER MORE THAN A HUNDRED MEGAWATTS ON THE GETAWAY OR KIND OF COMING IN ON THE LOAD. SO THE ENTITIES ARE GONNA BE RESPONSIBLE FOR THAT SELF-LIMITED OPERATIONS AT THE SITE THAT ADHERES TO THOSE LIMITS WHERE LOAD AND GENERATION NEED TO COORDINATE AND ENSURE COMPLIANCE UNDER ALL CONDITIONS. SO IF GEN FAILS, LOAD GOES AWAY. SO ERCOT OPERATIONS, UM, WE'VE BEEN ENGAGED WITH THEM ON THE DETAILS OF THAT, THE TRANSIENT OF THAT, THE WHAT DOES THIS MEAN? AND WE'RE HAVING A LOT OF MEETINGS TO TRY AND FIND A SOLUTION INTO THIS ARENA OF THAT COORDINATION AND WHAT IT MEANS TO THE RELIABILITY OF THE GRID. AND THEN THE LAST PIECE IS THE OPERATING AGREEMENT IS WHERE THE LOAD AND GENERATOR ENTER INTO AN AGREEMENT THAT WE'RE TRYING TO DEFINE IN PROTOCOLS. AND THAT THAT AGREEMENT DEFINES [02:35:01] THE OBLIGATIONS FOR THAT SELF-LIMITING BEHAVIOR, INCLUDING THE LOAD REDUCTION UPON GENERATOR LAW. SO IT'S REALLY THESE KIND OF THREE AREAS OF HOW DO YOU STUDY IT IN BATCH WE'LL NEED PROTOCOLS SLASH PLANNING GUIDES FOR WHAT DOES THAT COORDINATION IN REAL TIME LOOK LIKE AND EXPECTED, AND THEN THE OPERATING AGREEMENT IN PLACE. SO YOU'VE SEEN THIS FIGURE A FEW TIMES, UM, AND WE TALKED ABOUT IT A LITTLE BIT, WHICH IS FOR THIS SELF-LIMITED, IT'S ALMOST A SELF-SERVING FACILITY IS WHAT I WANT TO CALL IT IN A WAY. BUT IT IS SELF-LIMITING IN THE IDEA THAT WE'RE STILL GONNA TRY TO FORKLIFT THE SELF-LIMITING CONCEPT THAT'S ALREADY IN PROTOCOLS TO SAY THAT IF THERE IS AN AREA THAT THE QUEASY OR THE GROUP IS AGREEING NOT TO EXCEED A LIMIT AT THAT POINT OF INTERCONNECT. SO THAT SELF-LIMITING IS STILL A GOOD CONSTRUCT TO START FROM AND THAT THE SITE OPERATION WOULD HAVE THAT FIXED TRANSMISSION WITHDRAWAL LIMIT. THAT MAY BE, YOU KNOW, YOUR BASE, UM, YOUR BATCH STUDY VALUE OR IT MAY BE ZERO IS WHAT ERCOT I TALKED ABOUT LAST TIME IS CONSIDERING, UH, THE GENERATION MIX IN THAT AREA COULD BE A MIX OF THERMAL RENEWABLES, BATTERIES, WHATEVER YOU WANT IT TO BE, BUT WHATEVER THOSE VARIABLE THINGS ARE DOING, YOUR LOAD IS GONNA HAVE TO MATCH OR STAY IN THE BOUNDS OF SO YOU DON'T EXCEED WHATEVER THAT LIMIT IS. AND THAT FIXED TRANSMISSION WITHDRAWAL LIMIT IS ESTABLISHED AT THE POINT OF INTERCONNECT AND IT DOES NOT CHANGE DURING THE YEAR. SO UNLIKE CONTROLLABLE LOAD RESOURCES, IF THERE'S ROOM ON THE SYSTEM, CONSUME MORE, THIS IS A FIXED LIMIT, SET IT AND FORGET IT TYPE SCENARIO, UH, THE LOAD AND GENERATION OWNERS MUST COORDINATE THOSE OPERATIONS TO ENSURE THAT THOSE GRID IMPORTS ARE THERE. SO IF YOU'RE ON OUTAGE, ERCOT IS NOT GONNA RUCK SOMETHING ELSE TO GET YOU ON. IT'S WHERE SOMEHOW YOU NEED TO MANAGE THAT AT YOUR FACILITY. UH, THE SITE WOULD BE EQUIPPED WITH A REVERSE POWER RELAY OR EQUIVALENT PROTECTION TO ENFORCE THE LIMIT. WE'RE NOT MARRIED TO THAT REVERSE POWER RELAY, BUT WHAT ERCOT NEEDS TO KNOW IS A THOUSAND MEGAWATT LOAD AND A THOUSAND MEGAWATT GENERATOR ON A 69 KV LINE. IF ONE GOES, THE OTHER ONE GOES QUICKLY ENOUGH THAT WE DON'T DAMAGE EQUIPMENT IN THE LOCAL AREA FOR EVERYBODY ELSE. UH, AND THEN THE TRANSMISSION UPGRADES THAT MAY BE REQUIRED WOULD STILL BE IDENTIFIED IN THAT BATCH STUDY TO MEET THE RELIABILITY CRITERIA. SO THAT IS THAT, UM, N MINUS ONE, G MINUS ONE. SO ERCOT IS BRINGING THIS TO YOU ON THE RIGHT IS NOT A MENU OF OPTIONS TO CHOOSE FROM. IT'S WE'RE TRYING TO GET TO WHERE WE THINK THE SWEET SPOT IS. SO THE FIRST RANGE OF OPERATIONS, WHAT DOES THAT MEAN FOR MY FACILITY? CAN WE BE MAX LOAD? CAN WE BE MAX GEN? WHERE DO WE LIVE IN THESE SCENARIOS? AND SO THE FIRST ONE IS THE IDEA OF A CONNECTED ISLAND WHERE THE OPERATING RANGE IS EFFECTIVELY A NET ZERO TYPE ISLAND. YOUR GENERATOR AND YOUR LOAD ARE ALWAYS COORDINATED IN GROWING UP TOGETHER TO GET YOUR MAX LOAD AND YOU'D EFFECTIVELY OPERATED A NET ZERO WITH ONLY OX LOAD FOR GENERATION, UM, TO THE SITE. SO THAT'S ONE THING WE MAY COME OUT WITH DESIGN FOR. UM, THE NEXT DESIGN THAT WE'RE LOOKING AT IS THE IDEA OF A NET GEN SITE WHERE THE OPERATING RANGE FOR LOAD WOULD NEVER BE CONSUMING, BUT THE GEN COULD MAX THEIR OUTPUT ONTO THE SYSTEM AND BE SKI DISPATCHABLE. SO IT'S THE IDEA OF LOAD STAYS THERE AND IF WE'VE STUDIED THE AREA, UM, THIS IS A, UM, I'LL, I'LL DESCRIBE THE THIRD ONE AND COME BACK TO THAT ONE. WHAT WE'D LIKE TO GET TO, THE IDEAL CASE THAT EVERYBODY WANTS AND WE DO TOO, WE JUST DON'T KNOW THAT WE CAN HANDLE IT, IS A BATCH LOAD LIMIT. SO IF YOU'RE A THOUSAND MEGAWATT LOAD, YOUR RAMP IS A HUNDRED MEGAWATTS AND YOU'RE GRANTED THAT A HUNDRED MEGAWATT FIRM LOAD, WHETHER OR NOT THAT BATCH LOAD IS YOUR MAX LOAD, SO YOUR NEGATIVE 100 AND YOU COULD GO ALL THE WAY UP TO A THOUSAND ON THE GEN SIZE. SO TO OPERATE THE OPERATING RANGE WOULD BE THE BATCH LIMIT TO THE MAX GEN LIMIT ON THE SYSTEM. SO YOU'D BE OPERATING FROM THAT GRID IMPORT LIMIT UP TO FULL GENERATION OUTPUT FOR SCED DISPATCH THAT'S NOT CONSUMED BY THE LOCAL LOAD. SO THOSE ARE KIND OF THE THREE ARENAS WE'RE WORKING IN. WE'RE WORKING IN THOSE ALL AT THE SAME TIME TO SEE WHAT SURVIVES TO GET OUT. BUT OBVIOUSLY WE WANT GENERATION AT ERCOT, WE HAVE A LOT OF LOAD COMING AND WE WANNA SERVE THE LOAD AND SO WE'RE TRYING TO GET TO IT, BUT WE'RE SHOWING THE AREAS WHERE WE MAY END UP. AND SO IN TERMS OF THE, UM, CONCEPTS, AGAIN THAT FRAMEWORK, I JUST DID A VOICEOVER OF THE DETAILS. SO AGAIN, GENERATION WOULD STILL FOLLOW THE STANDARD INTERCONNECTION PROCESS AND WOULD BE DISPATCHABLE FROM THE SITE IS WHAT WE'RE LOOKING TO DO WITH SC IS WHAT'S, UM, MANAGING THE EXPORT OF THAT. UH, LOAD IS STUDIED IN THE BATCH PROCESS AND LIMITED TO THE APPROVED IMPORT LEVEL AT THE POINT OF INTERCONNECT. AND THOSE IMPORT LIMITS WOULD ALWAYS APPLY REGARDLESS OF THE GENERATION. AN OPERATING AGREEMENT WOULD REQUIRE LOAD TO AUTOMATICALLY AND IMMEDIATELY REDUCE CONSUMPTION UPON GEN LOSS OR OUTAGE. THE BATCH ASSUMES GENERATION FOR PLANNING, BUT ALLOCATES CAPACITY IF GENERATION IS UNAVAILABLE. SO ENFORCING THAT SELF-LIMITING BEHAVIOR [02:40:01] AND ENABLES THE LOAD TO OPERATE ABOVE THE TRADITIONAL G MINUS ONE LIMIT. SO AGAIN, YOU COULD BE A BIG SITE WITH ONE GENERATOR AND OPERATE IN THAT RANGE IF YOU'VE SHOWN US HOW YOU COME DOWN. AND THEN, UH, ERCO IS ALREADY HAVING NUMEROUS MEETINGS WITH OPERATIONS, GEN INTERCONNECTION, PLANNING MARKETS, COMPLIANCE. I MEAN WE'VE GOT ALL THE DIRECTORS AND VPS IN A LOT OF THESE MEETINGS TRYING TO CRACK THIS NUT. WE KNOW IT'S IMPORTANT AND THE GOAL IS FOR REVISION LANGUAGE IN TWO WEEKS. THAT IS A STRETCH. UH, I'LL BE AMAZED IF WE GET IT, BUT WE ARE WORKING NIGHTS AND WEEKENDS TO GET THERE, UH, AND STILL A POTENTIAL FOR BATCH ZERO, BUT JUNE ONE IS 53 DAYS AWAY. WE HAVE A LOT OF PROBLEMS TO SOLVE, A LOT OF STAKEHOLDERS TO AGREE TO AND TO GET THAT ON THROUGH TACK AND THE BOARD. SO THAT SETS THE STAGE FOR WHAT WE'RE UP AGAINST. BUT AGAIN, WE WANTED TO MAKE SPACE TODAY FOR 20 MINUTES OF DISCUSSION ON, UH, QUESTIONS OR THOUGHTS. SO START TO RUN THE QUEUE. SO SAM, BRANDON, YOUR FIRST STEP? THANKS FOR THIS SAM BRANDON WITH AGENT INFRASTRUCTURE. UM, I, I'M NOT CONFIDENT IF I FULLY UNDERSTAND WHAT WAS LIKE PRESENTED AS THE THREE OPTIONS ON SLIDE 16, BUT I GUESS MY, MY HIGH LEVEL QUESTION IS, SO ASSUME YOU HAVE A A HUNDRED MEGAWATT GENERATOR AND AN A HUNDRED MEGAWATT LOAD AND THAT LOAD MAY OR MAY NOT BE ACL R, UM, OR A-P-C-L-R, UM, BUT IN EITHER CASE WITH THAT GENERATOR AND JUST ASSUME THAT THE GENERATOR IS ALREADY, YOU KNOW, PLANNING GUIDE 6.9, SO IT'S THAT FAR ADVANCED IN THE FIS PROCESS WHEN, SO THAT GENERATOR'S EXISTENCE, THE DELIVERABILITY VALUE THAT THAT GENERATOR CONTRIBUTES TO THE SYSTEM WOULD BE SOCIALIZED TO THE WHOLE SYSTEM RATHER THAN GIVING THAT LOAD AN INCREASE IN THEIR LCP. IS THAT RIGHT? YOU'RE CLARIFY. SO YOU'RE SAYING ABSENT ANY CHANGES TO LANGUAGE, SO ABSENT THE BYOG CONCEPT, UM, IF THAT GENERATOR MEETS 6.9, THEN IT WOULD BE ADDED TO THE MODELS AND THAT GENERATION, THOSE MEGAWATTS IS, ARE SOCIALIZED TO USE YOUR TERM. YEAH, I AGREE WITH THAT. YEAH. SO, SO THAT EXISTENCE OF THAT GENERATOR IS NOT GOING TO IMMEDIATELY BUMP UP THE LCP FOR THAT CO-LOCATED LOAD. IT WILL BE SHARED ACROSS ACROSS THE BATCH UNDER TODAY'S PARADIGM, YES. OKAY. AND I GUESS THIS IS WHERE I'M NOT QUITE SURE IF ANY OF THESE THREE CASES PRESENTED WAS INTENDED TO CAPTURE THIS, BUT ASSUMING THAT THAT GENERATOR WAS PREVIOUS TO PLANNING GUIDE 6.9 OR I GUESS IT DOESN'T REALLY MATTER WHERE YOU ARE IN THE PLANNING PROCESS, BUT ASSUMING THAT, YOU KNOW, IT JUST HAD THE INTERCONNECTION AGREEMENT SIGNED AND DIDN'T OTHERWISE SATISFY THE OTHER CRITERIA. SO UNDER PICKER 1 27, WE'RE GOING TO ULTIMATELY KIND OF, YOU KNOW, ELECT WHICH SUPPLY BE BEYOND THE TRADITIONAL CRITERIA IS GONNA BE INCLUDED IN THE MODELS. AND SO IF THAT, IF THAT GENERATOR IS BEING DEVELOPED SPECIFICALLY TO SUPPORT THE CO-LOCATED LOAD, I GUESS IF THEN ERCOT ELECTS TO STUDY THAT GENERATOR AS IF IT'S GOING TO EXIST AND THEN KIND OF SOCIALIZE THAT DELIVERABILITY VALUE, UM, I JUST, I FORESEE AN ISSUE WITH THAT BECAUSE THEN THE, THE DEVELOPER OF THAT GENERATOR IS, IS EXPLICITLY DOING SO TO SUPPORT THEIR OWN LOAD AND THEY'RE NOT GONNA ACTUALLY DEVELOP IT IF THEIR OWN LOAD IS NOT ADVANCING ON THE SAME TIMELINE. SO I'M NOT SURE IF, YEAH, SO SO I THINK THAT'S WHY WE'RE TRYING TO COME UP WITH A CONSTRUCT HERE WHERE, UM, AND, AND, AND THAT'S, THAT'S WHAT WE'RE TRYING TO PROPOSE HERE. MM-HMM . IS A CONSTRUCT WHERE THAT, THAT LOAD THEN GETS CREDIT FOR BRINGING THAT GENERATION. OKAY. SO IT'S THE EXISTING PARADIGM, YOU'RE ABSOLUTELY RIGHT, LIKE THERE'S NO CREDIT, BUT UNDER THIS PARADIGM WHAT WE'RE TRYING TO MOVE TO IS THIS PROPOSAL IS THAT THE LOAD DOES GET CREDIT FOR BRINGING THAT GENERATION. OKAY. AND I GUESS THE LAST CAVEAT THERE IS WHEN I SAY GENERATOR, I ALSO MEAN ENERGY STORAGE RESOURCE. SO I GUESS IS THAT INTENTION EXPECTED TO CAPTURE ENERGY STORAGE RESOURCES AS WELL UNDER THE SELF-LIMITING FACILITY CONSTRUCT THAT IT IT'S WHAT WHATEVER RESOURCE YOU WANT TO USE TO ACHIEVE THAT IS I, THERE'S, THERE ARE NO LIMITATIONS HERE, BUT THEN THE SEPARATELY REGISTERED ENERGY STORAGE RESOURCE WOULD BE EXPOSED TO THE SLF LIMIT. WELL, NOT SURE WHAT YOU MEAN BY SEPARATELY. IT'S, UH, YEAH, WHAT WHAT DO YOU MEAN BY SEPARATE? SO ASSUME THAT YOU HAVE [02:45:01] A SEPARATELY REGISTERED ENERGY STORAGE RESOURCE AND A SEPARATELY REGISTERED, UH, WHAT MAY BE A-P-C-L-R. OKAY. UH, OKAY. WILL THE GENER WILL, WILL THE EXPORT VALUE OF THAT ENERGY STORAGE RESOURCE BE, WILL, WILL YOU BE ABLE TO CREDIT THE LOW DELIVERABILITY WITH THE NOT IN BATCH ZERO. OKAY. UM, YEAH, OPEN TO OTHER IDEAS ONCE WE GET PAST JUNE ONE, BUT I, I THINK FOR BATCH ZERO, I THINK, I DON'T THINK THAT WE'RE ABLE TO DO THAT. OKAY. YEAH, I WOULD JUST CALL OUT THAT I THINK THAT CREATES A PRETTY SIGNIFICANT KIND OF DISCREPANCY IN TREATMENT, UM, THAT'S GONNA KIND OF HAVE PERVERSE CONSEQUENCES, BUT THAT'S MY OVERALL COMMENT. THANKS BILL BARNES. THANKS, MATT. LET'S, UH, START WITH SLIDE 16 AND I GUESS A COUPLE GENERAL STATEMENTS THAT I'VE REPEATED A FEW TIMES HERE. UM, ONE IS, UM, SOMETHING'S BETTER THAN NOTHING. SO WE'D BE WILLING TO TAKE A LOOK AT AND FIGURE OUT HOW TO WORK WITH A MORE NARROWER, RESTRICTIVE BYOG ARRANGEMENT IN BATCH ZERO THAN TO SCRAP EVERYTHING AND SAY, WELL WE WILL TRY, YOU KNOW, NEXT TIME FOR BATCH ONE, THAT WOULD AT LEAST GIVE US AN IDEA ON WHAT ERCOT IS TRYING TO SOLVE FOR AND WHAT YOU MAY BE CONCERNED WITH. UH, THAT'S 0.1. UM, AND EVEN, EVEN ON LIKE OPERATIONS RESTRICTIONS IN CERTAIN CONTINGENCIES, LIKE PUT THE REQUIREMENT ON US. SO, UM, AND I KNOW THERE'S PROBABLY REASONS TO BE CONCERNED ABOUT IF YOU'RE A-B-Y-O-G ARRANGEMENT IN IS A UNIT TRIP, WHAT HAPPENS? WELL, TELL US WHAT YOU WOULD NEED TO SEE, RIGHT? DO WE GOTTA CLEAR IT IN FOUR CYCLES? WHAT, I MEAN WE, WE CAN HAVE THE RELAY SYSTEMS PAIRED WITH BATTERIES THAT CAN REACT IN MILLISECONDS AND IT'S QUIET. SO I WOULD RATHER SEE THAT THAN JUST SAY, AH, WE'RE NOT GONNA BE ABLE TO FIGURE THIS OUT. UM, SO THAT'S COMMENT ONE. COMMENT TWO IS ALSO SIMILAR TO WHAT SAM'S ALLUDING TO, I THINK IS, I THINK THERE'S A LOT OF OPPORTUNITY TO GET A REQUIREMENT OR ARRANGEMENT IN BATCH ZERO THAT WE CAN THEN EVOLVE OVER TIME. LIKE WE WILL HAVE TIME TO FIGURE OUT ALL THREE OF THESE THINGS AND EVEN MORE SO, UH, FOR BATCH ONE AND BEYOND. SO LET'S SEE WHAT WE CAN START WITH AND THEN MOVE FORWARD WITH, UM, ON THE THREE OPTIONS HERE, WHICH THOSE ALL LOOK GREAT. IT WOULD BE AMAZING IF THOSE WERE ALL OPTIONS IN BATCH ZERO. I THINK THAT'S PROBABLY UNLIKELY FROM WHAT I'M HEARING TODAY. THE PREFERENCES OF THOSE OF US THAT ARE ACTUALLY DEVELOPING THESE SITES, AT LEAST RIGHT NOW CAN CHANGE NEXT WEEK. BUT THE PREFERENCE WOULD BE, UH, WE WOULD ACCEPT MORE RESTRICTIONS ON IMPORT LIMIT IF WE CAN B BRING THE DATA CENTER UP SOONER. LIKE IF YOU TELL US WE CAN'T SEE THE LARGE LOAD HIT THE ERCOT SYSTEM WHATSOEVER, BUT YOU CAN ENERGIZE THE DATA CENTER AFTER THE GENERATION RESOURCE HAS FULLY COMMISSIONED, WE WOULD TAKE THAT DEAL AND THEN WE WOULD OPERATE AND WE WOULD LOOK AT WHAT WE COULD DO LATER ON AFTER THE LOAD'S FINISHED ITS BATCH STUDY AND WE'VE GOT MORE RULES IN PLACE ON HOW WE CAN OPERATE THAT COMBINED, UH, FOR SITE. SO THAT'S ANOTHER POINT OF FEEDBACK IS, UM, UNDERSTANDING THE LIMITS AND, UH, TIMING LIMITS AND OPERATIONAL, UH, REQUIREMENTS TO TRY TO GET SOMETHING IN SOON IN THE NEXT FEW WEEKS. UM, TO SAM'S QUESTION, SIMILAR TO SAM'S QUESTION IS, AND THIS GOES TO THE, MAYBE WE CAN'T, WE'RE LIMITED NOW, BUT WHAT ABOUT LATER? ASSUMING WE DON'T, WE CAN'T DO ANYTHING IN BAT ZERO OR THE RULES THAT ER CAP PROPOSES DOESN'T REALLY MEET THE REQUIREMENTS. SO WE WOULD HAVE POTENTIALLY A SCENARIO WHERE A LOAD IS STUDIED IN BATCH ZERO SEPARATELY, THE GENERATION, UH, RESOURCE WHICH IS CO-LOCATED COMPLETES ITS, UH, YOU KNOW, FIS AND IS THROUGH THAT PROCESS THAT WE COULD MAYBE TIE THEM TOGETHER IN A LATER BATCH. UM, THAT'S ANOTHER KIND OF COMMENT 'CAUSE I THINK JUST BECAUSE WE DON'T HAVE RULES FOR BATCH ZERO DOESN'T MEAN YOU'RE GONNA, YOU'RE NOT GONNA HAVE CO-LOCATED SITES IN BATCH ZERO. THEY JUST WON'T BE, YOU WON'T TIE THEM TOGETHER IN BATCH ZERO. THAT MAY NEED TO HAPPEN LATER IF WE CAN FIGURE THAT PART OUT TOO. AND THEN MATT, ON SLIDE, THE NEXT SLIDE, THE GOAL FOR THE REVISION REQUESTS. UH, SO PRS AND ROSS, WE WILL GO THROUGH KIND OF A, WILL WE GET A DRAFT, UH, SET OF REVISION REQUESTS FILED KINDA LIKE WE DID TODAY? OR ARE WE THINKING THAT [02:50:01] YOU'LL ACTUALLY HAVE SOMETHING FORMALLY FILED AND THE PRS AND ROSS WILL DEDICATE TIME, KIND OF LIKE A LITTLE MINI WORKSHOP WITHIN THOSE MEETINGS TO GO THROUGH THOSE DETAILS? THAT'S THE HOPE. SO IT'S DEFINITELY TRY AND GET DRAFT LANGUAGE THERE. IF WE'VE DROPPED THE COMMENTS IN FORMALLY, THAT WOULD BE GREAT, BUT IT'S TRYING TO GET IT, IF WE HAVE A 90% FIT, LET'S TALK ABOUT IT IN DETAIL AT THOSE MEETINGS. OKAY, GREAT. THANKS FOR THE WORK ON THIS GUYS. REALLY APPRECIATE IT. ALL RIGHT, NEXT UP IS SANDY TRAUMA. HEY MATT. UM, MY QUESTION IS ON SLIDE NUMBER 16, AND I THINK THE FRAMEWORK THAT YOU HAVE PRESENTED IN MY, IN MY OPINION, I THINK IT WORKS REALLY WELL. ONE THING THAT I DON'T GET, UH, DID NOT GET CLARITY IS ARE YOU THINKING THE LOAD WILL BE REQUIRED TO REGISTER AS A LOAD RESOURCE? NO. OKAY. AND THAT'S WHY, YEAH, THE CLR AND ALL THAT STUFF, THAT'S DIFFERENT. THIS IS FIRM LOAD, RIGHT? NO, NO, NO. THE REASON I SAY LOAD RESOURCES, IT DOESN'T HAVE TO BE CLR, IT DOESN'T HAVE TO BE A-N-C-L-R, BUT IT COULD JUST BE A LOAD RESOURCE BECAUSE IF YOU REMEMBER, IF SLF IS CURRENTLY, I MEAN, WAS PRACTICED FEW MONTHS AGO BEFORE WE WENT INTO, UM, RTC PLUS B WHERE A SLF FACILITY HAD A BATTERY AND THE BATTERY WAS MODELED BOTH AS A LOAD AND A GENERATION, RIGHT? SO THAT FRAMEWORK ALREADY EXISTS IF YOU WRITE IT IN TERMS OF A, SO IN MY OPINION, I THINK THOUGH, IF I'M WEARING MY OLD HAT, YOU KNOW, I'M THINKING IT FITS BETTER IF YOU JUST REQUIRE THE LOAD REGISTRATION. IT DOESN'T HAVE TO BE A CLR OR NCLR, BUT I THINK IT OVERALL FITS INTO THE, THE, THE STRUCTURE THAT YOU ALREADY HAVE. VERY GOOD. YEAH, THAT CAME UP AS AN IDEA EARLIER THIS WEEK FROM SOMEONE INTERNAL ERCOT TOO. OKAY. OKAY. THANKS FOR THAT. EXPLORING IT. THAT MAKES IT EASIER. ALL RIGHT, NEXT, UH, HARSH, HARSH ENCORE, MATT, YOUR EXAMPLE OF THOUSAND T LOAD ON AND THOUSAND T GENERATION ON A SIX NINE KV LINE KIND OF SPOOKED ME. AND WHAT I GOT THINKING ABOUT WAS WHAT HAPPENS WHEN THE GENERATION TRIPS AND WHATEVER MECHANISM YOU HAVE IN PLACE TO MAKE SURE THAT THERE IS LEFT SELF LIMIT OF ZERO MEGAWATTS DOES NOT WORK. AND I, I GUESS THAT IS TO ASK, WOULD YOU ALL BE LOOKING AT THAT INSTABILITY TO MAKE SURE THAT THERE ARE NO SIGNIFICANT IMPACTS WHERE YOU CANNOT MANAGE THAT THROUGH YOUR OPERATION TOOLS AND MAKE SURE WE SORT OF DESIGN SUCH THAT WE CAN HANDLE THOSE KIND IMPACTS IF YOU LOSE THE GENERATION, I'LL SAY, I THINK OUR PRIMARY GOAL IS TO FIGURE OUT THAT CONFIGURATION THAT GUARANTEES IT DOESN'T BECOME THAT SCENARIO. THAT'S WHY WE PUT IN THINGS LIKE REVERSE POWER RELAYS OR THREE OF THEM ON TOP OF EACH OTHER OR WHATEVER BILL BARNES WANTS TO BUILD TO MAKE SURE THIS WILL NEVER, EVER, EVER SPILL OUT INTO THE LINE. OKAY, SO POINT OR YOU CAN'T DO THIS ON 69 KB. YEAH. AND, AND THAT'S HELPFUL, BUT I MEAN, WHEN YOU DESIGN THAT SYSTEM THOUGH, EVEN THE NUMBER OF CYCLES YOU HAVE TO TRIP THAT LOAD, IF THAT DOES HAPPEN, BECOMES VERY IMPORTANT, RIGHT? IT, IT JUST DEPENDS ON WHAT IS THE SIGNIFICANCE OF THE EVENT. SO JUST MAKING A POINT THAT IT'S WORTH THINKING ABOUT THAT THERE MAY BE A SIGNIFICANT IMPACT THAT YOU ALL NEED TO THINK ABOUT. THANKS. YEAH. THANK YOU. HARSH, UH, NED KEEPING WITH MY THEME OF ASKING THE, THE SIMPLE QUESTIONS. UH, SO THIS, THIS LIST OF THREE RIGHT HERE, IT WASN'T ENTIRELY CLEAR TO ME FROM YOUR VOICEOVER, ARE ALL THREE BEING CONSIDERED AS, UH, ARE THEY BEING CONSIDERED MUTUALLY EXCLUSIVELY FOR THE BACHELOR OR IS IT YOU'RE LOOKING AT MAYBE KIND OF A SCALING UP FROM ONE, TWO, AND THREE? YEAH, NUMBER THREE SATISFIES THE OTHER TWO. YES. GOTCHA. IT'S DEFINITELY SCALING UP AND I'D NEVER CIRCLED BACK TO NUMBER TWO. THE REASON WE MAY PUT THAT INSTEAD OF USING THE BATCH LOAD LIMIT OF A HUNDRED AND RAMP IT BACK TO ZERO AND SAY THAT'S WHAT WE HAVE TO LIVE WITH IS IF THE IDEA WE HAVE TO PUT A RAZ OR SOMETHING IN PLACE FOR THE BACKING DOWN OF THAT LOAD IN THE EVENT OF A GEN LAW. SO THAT WAS WHY ZERO IS EVEN IN THE, IS IN THAT MIDDLE PIECE THERE BECAUSE IT'S SOME OPERATIONAL CONCERNS AROUND IT. BUT YES, YOU'RE RIGHT. IF WE GET NUMBER THREE, THE OTHER TWO ARE ALL CUT, ARE TAKEN CARE OF. OKAY, GOT IT. THANK YOU. QUESTION I COULD ANSWER. ALRIGHT, UH, BROTH. HEY MATT. UH, SO RIGHT NOW YOU'RE ONLY LOOKING AT ONE SAME POI. IS IT ACCURATE OR CAN WE HAVE ELECTRICALLY SEPARATED? WE'RE KEEPING THIS VERY SIMPLE ONE. P-O-I-P-I. OKAY. SELF-LIMITED. YES. SECOND QUESTION IS THE OPTION THREE. HOW DO, WHEN SHOULD I TELL YOU ABOUT THE SIZE OF THE GEN? FOR EXAMPLE, BAD ZERO RESULTS COME OUT RIGHT AND I HAVE A 200 MEGAWATTS OF FOAM LOAD. CAN I THEN SIZE MY GENERATOR AT THAT POINT SO THAT I CAN SIZE IT TO 800 MEGAWATTS AT THAT POINT TO GET A THOUSAND MEGAWATTS OF LOAD APPROVAL? [02:55:01] SO, YEAH. SO, UM, THE, THE, I DON'T THINK THAT WE'VE TALKED ABOUT THIS, THIS MAY BE A GOOD POINT, IS, UM, WE ARE EXPECTING THAT YOU ALREADY HAVE A GI NR NUMBER GOING INTO BATCH ZERO. AND SO YOU, YOU HAVE BOTH GI NR, UM, AND A LLI NUMBER AND YOU TELL US THAT THOSE, THOSE TWO THINGS ARE CONNECTED. OH, OKAY. THAT'S A SUPER IMPORTANT CLARIFICATION. THANK YOU. SO YOU, WE NEED TO ESSENTIALLY ALREADY TELL YOU WHAT UH, SIZE OF GENERATOR IS BEFORE? YES. OKAY, THANKS. ALRIGHT. UH, CINDY BARKER. YEAH, JUST TO FOLLOW UP ON THAT SAME QUESTION, HOW, HOW FURTHER ALONG DOES THAT GEN NEEDS TO BE? UH, I I, I HEARD THAT YOU NEED AN A JAN R NUMBER, BUT DOES IT NEED A FIS APPLICATION FILED OR WHAT STATE SHOULD IT BE? YEAH, I, I THINK THAT'S TBD, UM, AND OF I THINK TBD ON HOW MUCH IT NEEDS TO HAVE PROGRESSED EARLY. I THINK THE, ON THE BACKEND, IF IT CANNOT HAVE ALREADY MET PLANNING GUIDE 6.9 FOR INCLUSION IN THE PLANNING MODEL, THOSE REQUIREMENTS, OTHERWISE WE ARE ALREADY PLANNING THE SYSTEM AS IF THAT GENERATOR IS THERE. SO YOU HAVEN'T REALLY BROUGHT ANYTHING NEW. THAT'S THE, THAT'S THE LOGIC. YEAH. THAT'S HELPFUL. UH, I THINK THAT WILL BE A, A HELPFUL CLARIFICATION AS WE WORK INTO THE PROCESS. 'CAUSE WE'LL HAVE QUESTIONS ON, HEY, CAN I INCLUDE MY GEN IN THIS BYOG OR SLF SCENARIO? THE SECOND QUESTION WAS, THE WAY THIS IS SHAPING UP, UH, IS I THINK YOU'LL BE LIMITED BY WHATEVER THAT SLF SCENARIO IS GOING INTO THE BATCH. IS THERE A EXIT RAMP FOR THESE LOADS OFF OF, TO GET OFF OF THE, THE GIN? UH, IN THE LONGER TERM, UH, CASES? YEAH, GENERALLY SPEAKING, THAT'S WHAT WE'RE ASSUMING. AGAIN, I TRIED TO GIVE THE EXAMPLE, AND MAYBE IT'S NOT VERY CLEAR IF IT IS, UH, FIVE GENERATORS SERVING ONE LOAD OUT IN AN AREA, IT MAY BE SELF-LIMITING AS IT'S GOING IN AND, BUT TRANSMISSION MAY NOT BE NEEDED THAT WE WOULD WANT TO BE ABLE TO HAVE A FINAL STUDY ON ALL THE GEN AND ALL THE LOAD TO SAY YES, IT IS NOW FULLY INTERCONNECTED. SO THERE'S KIND OF A WAY TO, IT'S ALMOST, I'VE SEEN IT, WE HAVEN'T TALKED THIS INTERNALLY, THIS IS ALMOST A TRANSIENT TYPE CONSTRUCT TO OPERATE AS THE LOAD'S GETTING AHEAD OF THE GEN NOW THE GEN'S AHEAD OF THE LOAD AND WE'VE HAD PEOPLE REALLY WORRIED ABOUT, WELL, WHAT IF THIS DOESN'T ALL MAGICALLY SHOW UP AT THE SAME TIME? SO THE SELF-LIMITING CIRCLE AROUND IT IS TO SAY, GROW WITH THE LOAD THAT IS SERVED IN THE AREA. AND IF YOU DON'T NEED A TRANSMISSION PROJECT AT THE END OF THIS ALL, THEN UM, MAYBE IT'S ALREADY THERE, BUT IF IT'S ONE GEN ONE LOAD, IT WON'T SATISFY G MINUS ONE. SO ERCOT, I BELIEVE IN THE PLANNING STUDY, WOULD SEE THAT SITE AND SAY, IT'S NOT SECURE. WE NEED A NEW TRANSMISSION OUT TO THAT FACILITY. SO AGAIN, IT KIND OF DEPENDS, BUT THOSE ARE THE TWO EXTREMES OF IS TRANSMISSION NEEDED AND HOW DO YOU EXIT OUTTA THAT? IT'S, WE HAVEN'T FINISHED ALL THOSE DETAILS. YEAH, BECAUSE IT'LL BE, I'LL BE CURIOUS TO KNOW IF, ARE YOU GOING TO STUDY THE FULL LOAD IN THE BATCH WITHOUT A JEN OR THAT WAS THE IDEA OF GETTING TO THAT LOAD ALLOCATION? YES. OKAY. OKAY. ALL RIGHT. NEXT WAS NED, THEN BILL AND BROTH. AND WE'LL HAVE TO WRAP IT UP AT THAT POINT JUST SO WE CAN GET TO LUNCH GUYS. UM, NED, THANK YOU MATT. BILL, THANK YOU FOR JUMPING IN. SO I'M NOT BETWEEN EVERYBODY AND LUNCH. THANK YOU FOR THAT. UM, I, I AGREE WITH BILL ON THE, ON THE BYOG UH, COMPONENT THAT WE KIND OF NEED TO KNOW WHAT ELSE WE NEED TO DO TO IMPROVE OUR LIE HERE. UM, NOT JUST GO TO ZERO WITH A TRIP. SO TO THE EXTENT ERCOT AND ITS MODELING CAN TELL US, WELL IF YOU'LL ADD THESE TYPES OF ASSETS, THAT WOULD BE HELPFUL. UM, MATT, I HEARD IN THE, UH, THE SLF LIMIT, IT WOULD BE SET IT AND FORGET IT. IS THAT CORRECT? WELL, FOR THE YEAR AT LEAST WHETHER OR NOT THERE'S CONSTRUCTION OR THINGS THAT CHANGE, BUT THIS IS NOT LIKE CLR THAT CAN MOVE INTO DIFFERENT SHOULDER HOURS OF THE DAY AND TAKE MORE POWER. CORRECT. AND NO SEASONAL, NO COMPONENT? NO. OKAY. AT LEAST AT THIS POINT FOR BATCH ZERO, I MEAN WE CAN KEEP TALKING FOR, BUT FOR STUDY, THIS IS THE IDEA OF A HAVING CONTROLS TIGHTLY, NOT A WALL, BUT A CONTROL SYSTEM THAT WE KNOW THAT'S GONNA BE SET AND MANAGED LIKE BREAKERS RATHER THAN KIND OF EASING IN AND OUT OF DIFFERENT PARTS OF THE DAY. I, I HADN'T THOUGHT ABOUT SEASONAL. OKAY. SLIDE 16 ON YOUR THREE RANGES OF OPERATION, UM, WE, WE HAVE ALREADY HEARD FROM ENCORE AND I THINK ERCOT, YOU GUYS NEED THIS 1200 MEGAWATT CCGT IN THE LOCATION WHERE IT'S BEING BUILT, IT'S NEEDED, [03:00:01] BUT I THOUGHT WHAT I WAS HEARING WAS THAT WE WERE BEING LIMITED ON WHAT WE CAN DELIVER FROM THAT UNIT TO THE GRID UNDER THIS SCENARIO. DID I MISHEAR THAT? IF WE END UP WITH OPTION ONE, WHICH IS YOU END UP IN A NET ARRANGEMENT NUMBER ONE WITH AN AGREEMENT THAT SAYS OUR BUSINESS CASE IS TO SERVE LOAD AND BECAUSE OF ERCOT CONCERNS, WE'RE GONNA HAVE TO JUST SERVE OUR LOAD. AND THAT'S ALL WE DO FOR NOW. YOU'RE ISLANDED. YEP, YOU'RE ISLANDED. OKAY. BUT YEAH, SO IF WE GO OPTION THREE, BUT OPTION IS OPTION THREE. YEP. OPTION THREE WOULD BE PREFERABLE, RIGHT? FOR Y'ALL? FROM MY PERSPECTIVE FOR EVERYBODY? YES. YES. YEAH. WOULD IT BE BEST FOR THE GRID TOO? YES. OKAY. THANK YOU. SO JUST THAT PROGRESSION, I THINK THE QUESTION CAME UP AGAIN, SO I'LL, I'LL ANSWER IT AGAIN TO SEE IF I HAVE IT RIGHT. OPTION ONE IS THE WORST CASE SCENARIO, GOOD NEWS YOU CAN CONNECT. BAD NEWS IS YOU CAN'T IMPORT OR EXPORT, YOU'RE LOCKED IN, YOU'RE AN ISLAND. NUMBER TWO IS GOOD NEWS. AS JEN COMES ONLINE THAT EXCEEDS YOUR LOAD, YOU CAN SPILL ONTO THE GRID, YOU CAN HELP ERCO RELIABILITY. SCARED WILL DISPATCH THE EXCESS GENERATION ONTO THE GRID UP TO AS MUCH AS YOU HAVE. AND THEN THE THIRD ONE IS WHAT EVERYONE WOULD LIKE IS CAN I USE AT LEAST MY BASE LOAD FROM THE ERCOT SYSTEM AND CAN I EXPORT GENERATION? CAN I DO BOTH? AND WE'D LOVE TO GET THERE. WE JUST DUNNO IF WE CAN FOR, I THINK WE CAN DO IT. MATT, I GOT CONFIDENCE IN YOU . MATT, CAN I, MATT, JUST TO CLARIFY, YOU SAID IN ONE YOU COULD HAVE AUXILIARY POWER THOUGH, RIGHT? WELL IF TO SATISFY THE GENERATION, IF WE CAN RELIABLY SERVE IT, YES. YEAH. AND, AND I APOLOGIZE FOR FOLKS ON WEBEX, SEE, BUT, BUT SOMEBODY, UH, WAVED THEIR HANDS, UH, WHEN WE WERE TALKING ABOUT THIS INTERNALLY AND I THOUGHT IT WAS HELPFUL FOR ME. SO I'M GONNA WAVE MY HANDS IN THERE. SO OPTION ONE IS YOU'RE JUST AT ZERO MEGAWATTS. OPTION TWO IS WE ALLOW, WE, YOU'RE, YOU'D HAVE TO BE AT ZERO MEGAWATTS ON THE LOAD SIDE, BUT WE ALLOW THE GIN TO GO ONTO THE GRID. THAT'S OPTION TWO. AND THEN OPTION THREE IS THAT WE ALL ALLOW, SORRY, WE ALSO ALLOW THE LOAD TO, UH, CONNECT, UH, OR TO, TO, UM, YOU KNOW, PULL FROM THE GRID SO THAT, THAT, THAT THAT'S THE RANGE OF OPTIONS. YEP. VERY GOOD. WAX ON, WAX OFF. ALRIGHT, AND THEN WHERE ARE WE AT? SO TO BILL BARNES AND THEN BROTH AND THEN LUNCH. YEAH, THANKS. JUST, UH, RESPOND TO HARSHEST CONCERN, WHICH IS SOMETHING THAT WE WOULD PROBABLY BE CONCERNED WITH AS WELL. THAT'S ONE OF THE LIKE EXAMPLES OF A, A RESTRICTION THAT WE MIGHT WANNA SEE IN NEED TO HAVE IN BATCH ZERO TEMPORARILY, WHICH IS YOU'RE LIMITED TO WHAT VOLTAGE LEVEL THAT YOU COULD DO THIS AT. THAT'S KIND OF ONE PART. AND THEN ALSO, LIKE BACK TO MY, THE, MY SUGGESTION IS WE WOULD RATHER SEE WHAT YOUR CONCERNS ARE AND TELL US WHAT TO DESIGN TOWARDS. SO IF WE GOT A CLEAR FAULT IN FOUR CYCLES OR WHATEVER, WE CAN FIGURE THAT OUT. WE CAN PUT BATTERIES BACK THERE. THERE'S OTHER THINGS WE CAN DO. UM, AND THEN JEFF, I'M JUST LOOKING AT THE, THE CHAT ON THE, UH, WHAT TO BE ON THE GENERATION SIDE, WHAT SHOULD BE CONS WOULD BE CONSIDERED AT SOME POINT EVERY GENERATION PROJECT IS GONNA END UP MEETING, YOU KNOW, 6.9. YEAH, SO LIKE WHAT'S THE CUTOFF? AND IT, IT'S AT THE BEGINNING OF THE BATCH STUDY. SO AT THE BEGINNING OF THE BATCH THEN IF THAT GENERATION ALREADY MEETS THE 6.9, WHATEVER, IT'S PARAGRAPH ONE, IF IT ALREADY MEETS THAT, IT WILL ALREADY BE INCLUDED IN THE MODELS, THE PLANNING MODELS. YES. AND, AND, AND SO IN ESSENCE, WE'RE ALREADY ASSUMING THAT THAT GENERATION IS THERE AND SO YOU'RE NOT, UH, WE'RE NOT GOING TO GIVE YOU CREDIT FOR SOMETHING WE WERE ALREADY ASSUMING IS THERE. UM, BUT YEAH, A AFTERWARDS IS, IS FINE AS LONG AS ON THE DAY THAT WE'D START THE BATCH STUDY THAT THAT DOESN'T ALREADY MEET 6.9, THEN I THINK THAT WE WOULD CONSIDER THAT AS BYOG GENERATION. SO IF YOU'VE MET 6.9 AND YOU AT YOU, THERE'S A CO-LOCATED LOAD THERE THAT IS BEING STUDIED IN THE BATCH. HOW WOULD THAT BE TREATED DIFFERENTLY THAN IN FRONT OF THE METER LOAD? UM, IT, IT'S, UH, YOU WOULD GET THIS, THIS TREATMENT. OH, OKAY. YEAH. THAT, YEAH, IT'S ESSENTIALLY THIS, THIS TREATMENT. OKAY, GREAT. THANKS. ALRIGHT, LAST QUESTION BROTH, JEFF. SO YOU NEED THE G-N-G-N-R NUMBER BY JULY 24TH? OR IS THAT IS I THINK THAT'S TBD, WHAT THAT DATE IS. OKAY, THANKS. ALRIGHT, SO WITH THAT WE STAND ADJOURN FOR LUNCH TO COME BACK AT ONE 30. AND WHEN WE GET BACK, IT'LL BE, THE ERCOT WILL WALK THROUGH THE COMMENT DISPOSITION, UH, THEN IT'LL BE THE MARKET STAKEHOLDER COMMENTS THAT WERE FILED. I'LL HAVE A CHANCE TO HIT THE PODIUM WITH ANY UPDATE WALKING THROUGH THE COMMENTS. AND THE LAST PIECE IS GONNA BE THE 5 8 4 8 1, UH, WALK DOWN WITH BROTH. SO THANK YOU MUCH. WE'LL STAND, UH, ON RECESS UNTIL ONE 30. ALRIGHT, SO AG, IF YOU WANNA START, I'M SORRY, WHO'S, [5. Detailed review of ERCOT Comments] WE'RE GONNA START WITH THE ERCOT COMMENTS FILED AND I KNOW WE HAD A PRIMER SLIDE TO KIND OF SET UP THAT DISCUSSION [03:05:01] HERE. SO THE IDEA, AGAIN, WE'RE GONNA DO THE REVIEW OF COMMENTS AND THEN WE WILL TURN THE MICROPHONE OVER TO THE STAKEHOLDERS THAT FILED COMMENTS. UH, AND THEN WE'LL DO THE 5 8 4 8 1 WITH BAR ROTH. ALRIGHT, THANKS. LET ME, THINGS OPENING THE FILES. SO I'M GONNA GO TO THE REVISION REQUEST SITE. SO THAT'LL BE KIND OF THE LAY OF THE LAND HERE OVER THE NEXT FEW MINUTES. IF YOU WANNA FOLLOW ALONG, WE DON'T POST THESE MATERIALS BECAUSE THEY'RE ALL PUBLICLY AVAILABLE AS PART OF THIS NINE. AND ALL RIGHT, SO WE'LL START OFF. WOW, WE'RE UP TO, WHAT ARE WE UP TO 44 SETS. ALL RIGHT. RAPID PACE, VERY EXCITING. ALRIGHT, THERE YOU GO, AG. THANK YOU. OKAY, UH, AG SPRINGER ERCOT AGAIN. UM, OKAY, SO WE'RE GONNA GO BACK TO THE SLIDES FOR ONE MOMENT. UM, SO, UH, JUST TO LEVEL SET HERE, SO, UM, I'M TALK THROUGH WHAT WE, AT A HIGH LEVEL, WHAT WE HAD IN OUR APRIL 4TH COMMENTS. UM, THESE IN GENERAL, THESE ADDRESSED COMMENTS THAT WERE FILED BY STAKEHOLDERS, UH, ON OR BEFORE MARCH 20TH. UM, THERE HAVE, THERE WERE SOME COMMENTS THAT CAME IN AFTER MARCH 20TH, BUT BEFORE, YOU KNOW, COMMENTS STARTED KIND OF FLOWN IN THE LAST FEW DAYS IN RESPONSE TO OUR APRIL 4TH COMMENTS. WE HAVE NOT FORGOTTEN ABOUT THOSE THAT CAME IN AFTER MARCH 20TH. WE WILL, UH, COVER THOSE IN SUBSEQUENT COMMENTS, UM, AS WELL AS SOME OF THE ISSUES THAT WERE NOT RESOLVED IN THESE COMMENTS. SO THERE WERE A NUMBER OF TOPICS THAT WE SAID, WELL, WE'RE STILL WORKING ON THIS, AND THOSE WILL BE IN THE FUTURE COMMENTS AS WELL. UM, SO WHAT'S IN THESE, UH, ADDITIONAL CLARIFICATIONS AND CORRECTIONS THAT, UH, UH, WERE INTENDED TO EITHER FIX, UM, TYPOS OR, UH, SMALL STRUCTURAL AMBIGUITIES OR THINGS ALONG THOSE LINES. A LOT OF THOSE WERE DISCUSSED AT THE LAST TWO WORKSHOPS. UM, ALSO IN RESPONSE TO SOME STAKEHOLDER FEEDBACK WHERE WE MIGHT NEED A LITTLE BIT MORE EXPLICIT LANGUAGE TO, UM, CLARIFY THAT A REQUIREMENT EXISTS, UH, THOSE WERE ADDED AS WELL. UM, WE DID MAKE SOME CHANGES TO THE, UH, WORLD OF VALID STUDIES, UM, ESPECIALLY ADDING THE PERMIAN BASIN RELIABILITY PLAN LOADS AS VALID. UM, AND, UH, THAT BROADENED THE, UH, UNIVERSE OF, OF STUDIES THAT HAVE REACHED THE, THE KIND OF SAFE HARBOR. UM, ONE OF THE THINGS THAT WE REALLY TRIED TO DO AS WELL IS, UM, CLARIFY ABOUT THE BATCH ZERO STUDY SCOPE. SO, UM, THERE HAD BEEN, UH, SOME SUGGESTIONS THAT THIS GO TO, UH, UH, TSPS FOR APPROVAL OR, UM, UH, SOME OTHER METHODOLOGY FOR IT, IT BEING KIND OF PRE-APPROVED. AND, UH, WE, WE SEARCHED FOR A MIDDLE GROUND THERE OF, UH, PRESENTING IT, UH, TO RPG AND INCORPORATING STAKEHOLDER FACT, UH, FEEDBACK FROM THAT BODY, UH, PRIOR TO THE COMMENCEMENT OF BATCH ZERO. SO, UH, THAT, THAT WAS THE, THE RESPONSE TO THOSE COMMENTS. UM, IN A FEW SECTIONS, UH, COMMENTERS NOTED AMBIGUITIES ON WHO WAS DOING WHAT. UM, AND SO WE SOUGHT TO CLARIFY THAT, ESPECIALLY AROUND THE, UH, LANGUAGE IN SECTION, UH, 9 3 2, WHICH DEFINES THE STUDY. UH, THERE WERE WERE COMMENTS THAT DID, YOU KNOW, WE THOUGHT A REALLY GOOD JOB OF CLARIFYING ROLES AND RESPONSIBILITIES. SO WE DID INCORPORATE THOSE, UM, NUMBER OF ALIGNMENTS AND CON INCONSISTENCIES, UH, BETWEEN DIFFERENT PROVISIONS WERE ADDRESSED, UH, AND, UH, TRIED TO ENSURE THAT, YOU KNOW, WE HAD, WERE CONTINUING TO ELIMINATE PLACES WHERE TWO DIFFERENT STEPS HAVE TO HAPPEN AT THE SAME TIME, EVEN THOUGH ONE DEPENDS ON THE OTHER. UM, AND SO I THINK, I THINK THERE'S POTENTIALLY [03:10:01] SOME MORE WORK TO DO THERE IN, IN THE NEXT ROUND OF COMMENTS, BUT WE ARE MAKING PROGRESS. UM, YEAH. AND THEN, UH, YOU KNOW, A COUPLE AREAS. SO THE, THE BIGGEST ONE THAT IT REMAINS UNADDRESSED IS THE YEAR SIX, UH, ALLOCATION ISSUE. UM, THAT, THAT REMAINS UNADDRESSED IN THESE COMMENTS. THAT IS NOT TO SAY THAT, THAT WE ARE DISMISSING STAKEHOLDER FEEDBACK OR WE HAVE HEARD THE FEEDBACK. IT JUST, WE WEREN'T ABLE TO, UM, REALLY IDENTIFY A PATH FORWARD BY, UH, OUR TARGET TO FILE THIS, UH, YOU KNOW, BY APRIL 3RD. SO, UM, THAT WILL BE A ISSUE THAT WE CONTINUE TO DISCUSS AND, AND WORK AHEAD OF THE NEXT ROUND OF COMMENTS. OKAY, SO LET'S SEE HERE. UH, OKAY, SO SWITCHING OVER TO THE COMMENTS ITSELF. SO THIS IS, UH, OUR APRIL 4TH COMMENTS. UM, YOU KNOW, I GUESS THAT I'M NOT GONNA, I, I DON'T, I DON'T THINK IT MAKES SENSE FOR ME TO READ THROUGH 'CAUSE THE THE SUMMARY SLIDE, UH, LARGELY GOT THAT. UM, BUT I WILL JUST NOTE THAT STARTING ON PAGE THREE AND ENDING ON, UH, PAGE 37, YOU'LL FIND A TABLE THAT ATTEMPTS TO ADDRESS BASICALLY EVERY INDIVIDUAL PIECE OF FEEDBACK, UH, THAT WE RECEIVED. UH, SO YOU, UH, WE'LL FIND THE SUBMITTING ENTITY, A SUMMARY OF THE COMMENT, UM, ANY RECOMMENDATIONS, AND THEN ERCOT RESPONSE. UH, WE ALSO TRY TO IDENTIFY IF THERE ARE RED LINES IN THE DOCUMENT THAT EXPLICITLY ADDRESS THIS COMMENT OR NOT. UM, SO, YOU KNOW, WE, WE, WE INCORPORATED OVER 20 DIFFERENT COMMENTS, UH, COMMENTERS WORTH OF FEEDBACK HERE. AND SO HOPEFULLY THIS GIVES YOU ALL SOME VISIBILITY INTO HOW WE, HOW WE REVIEWED AND UNDERSTOOD YOUR COMMENTS. OKAY. SO, UM, I'M GOING TO, I'M GONNA GO THROUGH RED LINES AND THEN, UH, WE'LL TURN IT BACK TO MATT TO KIND OF MC THE, UH, ADDITIONAL, UM, UH, THE, THE REVIEW OF THE, THE INDIVIDUAL COMMENTERS FROM THERE. SO, UM, WE'LL TRY NOT TO TAKE TOO MUCH, UH, TIME FROM THAT. SO LET'S SEE HERE. I THINK THE, THE FIRST SIGNIFICANT EDIT. SO, UM, SORRY, I'M TRYING TO FIGURE OUT WHICH. OKAY, SO, UM, WE'RE REALLY LOOKING AT OUR GREEN RED LINES HERE. SO, UM, BLUE IS THE ORIGINAL, UH, PINK WAS OUR MARCH 17TH COMMENTS. AND THEN GREEN IS THIS CURRENT SET OF COMMENTS. AND SO YOU'LL NOTICE HERE IN PARAGRAPH, SO WE'RE, UM, I APOLOGIZE, UM, UH, 9 2 1 4, WHICH IS THE EVALUATION OF VALIDITY OF STUDIES. UH, THE BIG ADDITION HERE WAS THE ADDITION OF THE LOADS INCLUDED IN THE PERMIAN BASIN RELIABILITY PLAN AS, UH, BEING CONSIDERED VALID STUDIES. THE, YOU KNOW, WE DID RECEIVE QUITE A FEW COMMENTS ON, UM, THE MARCH 4TH DATE EARLIER IN THIS PARAGRAPH, UH, THAT IS STILL UNDER REVIEW. UM, SO WE, WE WILL PROBABLY HAVE MORE TO SAY ON THAT IN A FUTURE SET OF COMMENTS. UM, JUST SOME CLEANUP IN 9 2 2, UH, THE, THE MAIN PARAGRAPH, UH, WE HAD AN OLD REFERENCE FROM THE ORIGINAL PLANNING GUIDE NINE THAT WE CLEANED UP. UH, AGAIN, SOME, JUST SOME CLARIFYING, UH, WORDING TO, TO MAKE CLEAR THAT, UH, CHANGES IN THE, THE PROJECT DEVELOPMENT SCHEDULE WOULD ALSO BE, UH, A CHANGE THAT NEEDS TO BE NOTIFIED TO BOTH THE TSPN OR ERCOT SO THAT WE ARE AWARE WHEN, WHEN THE DEVELOPMENT TIMELINE CHANGES, UM, CLAR IN MODIFICATION OF PROJECT INFORMATION 9 2 3, WE ADDED SOME CLARIFICATION, UH, CLARIFYING LANGUAGE, UM, ABOUT RESPONSIBILITIES, UH, RELATED TO THE NOTIFICATION OF DYNAMIC DATA CHANGING. UM, AND I, I KNOW WE, WE'VE GOT ONE IN THE QUEUE. I'M GONNA TRY AND GET THROUGH EVERYTHING. BUT, UM, MATT, AT ANY POINT IF YOU KNOW IT STARTS TO BUILD UP AND WE NEED TO PAUSE FOR A SECOND, WE CAN, WE CAN DEFINITELY DO THAT. OKAY. UM, YEAH, UH, JUST CLEAN THE, IN SECTION 9 2 5, WHICH IS REQUIRED INTERCONNECTION EQUIPMENT. UM, AGAIN, JUST SOME CLEANUP. UM, AND, UH, SAME THING FOR THE FIRST PART OF 9, 2 3, THESE, ALL THESE CLEANUPS ARE FROM PLACES WHERE IN THE EXISTING PLANNING GUIDE SECTION NINE, WE HAD REFERENCED SECTION 9.2 0.1, AND IN THE EXISTING PLANNING GUIDE NINE, THERE IS NO SUBSECTIONS, THERE ARE NO SUBSECTIONS OF THAT. UM, WE WANTED TO BE VERY CLEAR IN WHAT WE WERE [03:15:01] REFERENCING IN THE NEW BATCH ZERO FRAMEWORK. AND SO THAT'S WHY YOU SEE A LOT OF PLACES WHERE 9 2 1 IS CROSSED OUT, AND THEN 9 2 1 1 AND 9 2 1 2 ARE MORE EXPLICITLY ADDED. UM, BUT THEN AGAIN, THAT IS JUST INTENDED FOR CLARIFICATION PURPOSES. OKAY. UM, SO MOVING DOWN TO THE STUDY ITSELF. SO WE'RE IN SECTION 9.3 0.2. UH, YOU'LL FIND HERE THE EXPLICIT STATEMENT THAT WE'LL BRING THE STUDY SCOPE TO THE REGIONAL PLANNING GROUP. UM, AND THEN WE ALSO REPLACED THE EXISTING PARAGRAPH, WHAT BECAME WITH THAT ADDITION, THAT BECAME PARAGRAPH FOUR. BUT WE REPLACED THAT WITH, UH, LARGELY CONSISTENT WITH RED LINES SUBMITTED, I BELIEVE, BY CENTERPOINT, UM, THAT CREATE A MORE DEFINED SET OF RESPONSIBILITIES AND TIMELINES AROUND, UH, WITHIN THE STUDY AND ALSO, UH, WITH THE IDENTIFICATION OF TRANSMISSION UPGRADES. UM, AND THEN A MORE EXPLICIT STATEMENT WAS ALSO ADDED THAT IT WILL BE ERCO T'S RESPONSIBILITY TO DETERMINE THE AMOUNT OF LOAD THAT CAN BE SERVED RELIABLY FOR EACH YEAR, UM, AS PART OF THE, THE STUDY PROCESS. SO, UH, NOTHING IS CHANGING WITH WHAT WE HAD INTENDED TO HAPPEN, BUT THERE'S A LOT OF CLARIFYING LANGUAGE THAT GIVES, I THINK EVERYBODY VE BETTER VISIBILITY INTO WHAT WE ARE SAYING THERE. OKAY. MOVING NOW TO THE AGREEMENT, THE, THE COMMITMENT PHASE, UM, COUPLE OF, UH, SMALL TEXT EDITS. AND THEN, UM, ONE OF THE THINGS THAT WE REALIZED WAS AMBIGUOUS IS THAT, UM, IN THE EVENT THAT THE IA, UH, THE FULL INTERCONNECTION AGREEMENT IA THAT IS REQUIRED AS PART OF THIS SECTION, UM, ENDS UP BEING FOR LESS THAN THE ORIGINAL REQUESTED AMOUNT, THAT WE NEED THAT TO BE REFLECTED IN THE LOAD COMMISSIONING PLAN AS WELL TO MIRROR THAT. UM, AND SO THAT WAS A, I I BEST DESCRIBE THAT AS AN OVERSIGHT, AS IN THE EVENT THE CUSTOMER ELECTS TO MOVE FORWARD WITH A LOWER AMOUNT. UM, WE NEED TO HAVE THAT IDENTIFIED. UM, AND THEN SUBSEQUENT TO THAT, JUST A COUPLE OF, UH, UH, CLEANUP EDITS. OKAY. MOVING INTO THE REFINEMENT AGAIN, UH, CLEANING UP, UH, SOME OF THE INTERCONNECTING DSP INTERCONNECTING TSP LANGUAGE, UH, CLEANING UP SOME OF THE REFERENCES, UM, BUT NO OTHER MAJOR CHANGES HERE. AND THEN FINALLY IN, UM, 9.6, UH, JUST A COUPLE OF SMALL EDITS. AGAIN, THIS IS A, I WILL SAY THAT SECTION 9.6, YOU ALREADY SAW IT IN THE, UM, UH, CLR LANGUAGE I PRESENTED EARLIER. I, I, I THINK THERE, THERE ARE SOME EX EXISTING AMBIGUITIES THAT EXISTED IN THE BLACK LINE LANGUAGE, BUT ARE NOW KIND OF AMBIGUOUS WITH THE NEW BATCH ZERO PROCESS. SO THIS IS, UH, A SECTION I DO EXPECT WE'LL REVISIT IN OUR NEXT SET OF COMMENTS AS WELL. UH, CHRISTINA, HELP ME OUT HERE. WAS THERE ANYTHING IN 9.7 THAT WE NEED TO HIGHLIGHT? I, I THINK THERE WAS, UM, UH, A COUPLE DELETIONS, BUT I, I, UH, COULD USE, YOU COULD USE A HELP ON WHERE, WHERE EXACTLY I NEED TO, TO POINT TO. I DON'T THINK WE MADE ANY DELETIONS OKAY. FOR THIS ROUND. WE WERE SAVING THOSE FOR AFTER APRIL 17TH. UM, MAYBE YOU ALREADY COVERED IT, BUT BACK AT THE TOP TOWARDS THE BEGINNING WE ADDED A NEW SECTION OR NEW PARAGRAPH 9 2 1, I THINK, WHERE WE SAID THAT THE DSP CAN DESIGNATE AN ELECTRIC UTILITY OR, UM, THE MUNICIPAL OR COOPERATIVE TO SUBMIT THE LARGE LOADS REQUEST ON THEIR BEHALF. THANKS. YEAH, I, I, I, I STARTED TOO FAR DOWN, BUT YES, UH, YEAH, THAT WAS AGAIN, ANOTHER, UM, EDIT TO CLARIFY ROLES AND RESPONSIBILITIES. SO THANKS FOR REMINDING ME ON THAT. SO I THINK THAT IS ALL THE, THE SUBSTANTIVE EDITS IN OUR COMMENTS. I SEE THERE'S A COUPLE COMMENTS IN THE QUEUE, SO LET'S, THERE QUESTIONS IN QUEUE. SO WE'LL GO THERE AND THEN I'LL, I'LL YIELD THE FLOOR. EXCELLENT. THANKS AG. SO FIRST UP, MICHAEL JEWEL. YEAH, THANK YOU. UH, MICHAEL, JEWEL, JEWEL AND ASSOCIATES. JUST A, A COUPLE OF QUESTIONS. THAT FIRST SLIDE THAT YOU PUT UP THAT HAD THE, UH, SUMMARY, UM, ONE OF THE QUESTIONS WAS, UH, WITH REGARD TO THE YEAR SIX NOTE AT THE BOTTOM, UM, IN THE CONTEXT OF FIGURING OUT KIND OF THAT ALLOCATION QUESTION, WILL YOU ALSO BE WORKING, FIGURING OUT HOW FINANCIAL RESPONSIBILITY OF THE FINANCIAL SECURITY IS HANDLED? BECAUSE LIKE, IF YOU'VE GOT A POST OF A [03:20:01] HUNDRED PERCENT OF YOUR FINANCIAL SECURITY FOR ALL THAT YOU'VE REQUESTED, THE ASSUMPTION WAS THAT YOU WERE HAVE A HUNDRED PERCENT BY YEAR SIX. NOW WE'RE BACKING THAT OUT. WHAT HAPPENS WITH THE FINANCIAL SECURITY AT THE SAME TIME? YEAH. SO, UM, HARD TO ANSWER THAT QUESTION WITHOUT KNOWING HOW WE'RE GONNA POTENTIALLY ADDRESS THAT ISSUE. I DON'T, I, I DON'T THINK THERE'S ANYTHING I DEFINITIVE I CAN SAY ON HOW THIS WILL BE, UH, ADDRESSED YET. UM, BUT WE CAN KEEP THAT IN MIND AS, YEAH, I JUST WANTED TO RAISE IT AS, AS ONE OF THOSE THINGS TOO, UH, THAT MIGHT BE HELPFUL TO HAVE IN THERE. THE, UM, ON THE COMMENTS, UH, DOCUMENT THAT YOU, UM, TALKED ABOUT AT FIRST, ONE OF THE, UH, COMMENTS WAS, LET'S SEE, COMMENTS AT 21. ONE OF THE ONE, ONE OF THE QUESTIONS WAS, UM, OR, OR IN A NUMBER OF PLACES IN THE COMMENTS YOU SAID THAT THIS WILL BE ADDRESSED IN FUTURE COMMENTS. DO WE HAVE AN IDEA WHEN THOSE FUTURE COMMENTS ARE GOING TO BE COMING OUT, LIKE TO ADDRESS, YOU KNOW, UH, QUESTIONS WITH REGARD TO THE, UH, EFFECTIVENESS OF THE RPGS, HOW THOSE ARE GONNA BE HANDLED? I KNOW WE HAD SOME ADDITIONAL COMMENTS THAT JUST GOT FILED AS WELL ON THAT. ANY TIMELINE WITH REGARD TO THE NEXT ROUND OF, OF EDITS FROM ERCOT? YEAH. YEAH, SO, UM, MICHAEL, WE'RE STILL TALKING THROUGH THAT. UM, I THINK LIKELY ERCOT WOULD NOT FILE COMMENTS BESIDES THE, THE CLR COMMENTS. UH, THE, THE PCLR COMMENTS LIKELY AREN'T GONNA FILE ANY ADDITIONAL COMMENTS UNTIL AFTER THE, UH, PC OPEN MEETING ON THE 17TH. UM, AND, AND SO I THINK WE'RE, WE WOULD LOOK TOWARDS SOMETIME BETWEEN THEN AND THE APRIL 23RD ROS, UM, I'LL, I'LL SAY ROUGHLY THAT'S WHEN WE'RE TARGETING, BUT I DON'T THINK WE'VE MADE THAT DETERMINATION EXACTLY YET. OKAY. THAT, THAT MAKES SENSE. JUST KIND OF A FEELING FOR THE TIMELINE IS HELPFUL. UM, THE OTHER QUESTION WITH REGARD TO THE AMENDMENT IN, UM, NINE WHERE YOU ADDED THE PERMIAN BASIN, UH, AS ONE OF THE CONSIDERATIONS, ONE OF THE QUESTIONS THAT'S COME UP IN THIS SECTION AS WELL IS WHEN YOU LOOK AT, UH, IN GENERAL THE LOADS THAT ARE, OR THE STUDIES THAT ARE VALID, THEY'RE KIND OF TIED TO, DO THEY MEET PI ONE 15 REQUIREMENTS? WHAT HAPPENS WITH THE STUDIES THAT WERE COMPLETED BEFORE PI ONE 15? ARE THEY CONSIDERED TO BE VALID AS WELL? 'CAUSE WHEN PI ONE 15 WAS ADOPTED, IT SAID YOU DON'T HAVE TO STEP BACKWARDS IN THE PROCESS. SO THE WAY THAT THIS IS DRAFTED, IT DOESN'T PROVIDE THAT CLARITY ON HOW WE HANDLE THE PRE PIGGER ONE 15 STUDIES. SO, SO LET ME JUST ASK A QUESTION BACK AND MAKE SURE I UNDERSTOOD WHAT I HEARD THERE. SO, UM, IT WAS, THE QUESTION IS FOR FOR PROJECTS THAT, UM, FOR LARGE LOAD INTERCONNECTION REQUESTS THAT HAD SOME OR ALL STUDIES COMPLETED DURING THE INTERIM INTERCONNECTION PROCESS THAT EXISTED BETWEEN, UM, 2022 AND 2025, ARE THOSE STUDIES STILL CONSIDERED VALID UNDER THIS STRUCTURE? EFFECTIVELY? YES. YEAH, SO, SO THE ANSWER TO THAT IS THE INTENTION IS THAT THAT GETS CAPTURED IN, UM, B HERE. SO IN OTHER WORDS, UH, IF THOSE PROJECTS HAVE THO THOSE STUDIES ARE INTENDED TO FIT INTO THE EXISTING P ONE 15 PROCESS. SO, UM, THOSE STUDIES DON'T NEED TO BE REDONE. THAT'S CONSISTENT WITH WHAT WE'VE SAID IN THE PAST. AND AS LONG AS THE PROJECT MEETS THE 9.4 AND 9.5 MILESTONES, UM, THEN IT FALLS UNDER UNDER B. UM, I THINK IF, IF STAKEHOLDERS FEEL THAT THERE'S NEEDS TO BE CLARIFYING LANGUAGE TO MAKE THAT EXPLICIT, I THINK WE'D BE OPEN TO THAT. YEAH, NO, I THINK THE, JUST HAVING THAT CLARIFICATION HERE IS, IS VERY HELPFUL. COOL. THANK YOU. GOOD BREATH. HEY, THANK YOU SO MUCH. UM, AG, SO NOW THE SSO REQUIREMENT IS MOVED OUT TO PRIORITIZATION, RIGHT? SO IT'S NO LONGER REQUIRED TO GET INTO QSA? CORRECT. YEAH, SORRY, I GLOSSED OVER THAT ONE TOO, BUT, UH, NO, THANK YOU. SUPER HELPFUL. THE SECOND ONE IS, UH, REACTIVE POWER STUDY. I KNOW THERE WAS SOMETHING ABOUT IT AS WELL. UH, IS THAT REQUIRED BEFORE QSA OR THAT REMAINS REQUIRED FOR QSAQ? ONLY CHANGE WAS THE SSOQ. OKAY. THANK YOU. ALL RIGHT, NEXT CONSTANCE. CONSTANCE, ARE YOU THERE? ALL RIGHT, WE'LL CIRCLE BACK AROUND TO YOU SHANNON AG. COULD YOU GO BACK TO THE LANGUAGE THAT [03:25:01] YOU WERE REFERENCING WHEN YOU WERE ANSWERING MICHAEL JEWEL'S QUESTION ABOUT THE INTERIM PROJECTS? IT WAS LIKE A PARAGRAPH THREE. YEAH, HANG ON, HANG ON JUST ONE SECOND. OKAY. UH, THERE WE GO. HAD TO FIGURE OUT WHERE IT WAS THERE. OKAY. SO HIS QUESTION WAS IN THE CONTEXT OF THINGS THAT WENT THROUGH THE INTERIM PROCESS AND DID NOT NEED TO GO THROUGH, UH, THE PICKER ONE 15 PROCESS, TRYING TO MAKE SURE THERE WAS NOT A LOOK BACK ON THOSE. THE THING THAT'S LESS THAN CLEAR TO ME, IF YOU MAKE IT TO WHERE IT HAS TO BE SECTION NINE NINE AND SECTION NINE 10, IT'S NOT CLEAR TO ME THAT, UM, IT'S WHY THAT DOESN'T SUBJECT THEM TO BACK TO A LOOK BACK INSTEAD OF JUST MAKING IT TIED TO SECTION NINE 10. AM I MISSING SOMETHING THERE? SO, UM, I'M GONNA, BEFORE I ANSWER YOUR QUESTION, I WANNA CLARIFY THAT, MAKE SURE I UNDERSTOOD WHAT MICHAEL ASKED. SURE. UM, SO MICHAEL, MY UNDERSTANDING WAS WAS BASICALLY THAT YOU WERE ASKING IF THE STUDIES THAT WERE DONE UNDER THE INTERIM PROCESS REMAIN GOOD INTO THE PAPER ONE 15 PROCESS AND PROJECTS THAT WENT ALL THE WAY THROUGH TO, UM, APPROVED STUDIES AND, AND ENERGIZATION, EVEN IN THE INTERIM PROCESS STILL REMAIN VALID HERE. IS THAT, DID, DID I UNDERSTAND YOUR QUESTION CORRECTLY? YEAH. YOU'VE GOT, YOU'VE GOT SOME LOADS THAT, UH, HAD STUDIES BEFORE BIGGER ONE 15, YOU KNOW, WAS AROUND AT ALL. THEY'VE BEEN MOVING THROUGH THE PROCESS, THEY'VE BEEN WORKING WITH THEIR TSPS, THEY'VE SIGNED CONTRACTS, THEY'VE PAID KAYAK, THEY'VE GONE A LONG WAY DOWN THE ROAD. THEY'RE NOW GETTING CAUGHT UP INTO THE BATCH ZERO PROCESS. AND THE QUESTION IS, ARE MY STUDIES STILL GOOD? DO I QUALIFY UNDER THIS LANGUAGE BECAUSE I DIDN'T DO MY STUDIES UNDER 9.99, YOU KNOW, UNDER THE FIGURE ONE 15 PROCESS. SO IT'S REALLY JUST BEING SURE THAT THERE IS NOT A REQUIREMENT TO GO BACK BECAUSE NOBODY WAS EXPECTING THAT THEY WERE GOING TO HAVE TO. YEAH. AND SO, UM, I'M GOING TO, I'M GONNA RESTATE MY ANSWER AND THEN I'M HAPPY TO TAKE YOUR QUESTION AFTER THAT. UM, SO THE INTENTION, AND THIS IS WHAT WE COMMUNICATED AT PAST STAKEHOLDER MEETINGS, IS THAT ANYTHING FROM THE INTERIM PROCESS THAT WAS IN FLIGHT WHEN PICKER ONE 15 WAS UNBOXED, THAT STATUS WOULD TRANSFER INTO, YOU KNOW, EFFECTIVELY THE EQUIVALENT STATUS IN, IN THE PICKER ONE 15 FORMAL PROCESS THAT'S DEFINED IN PLANNING GUIDE NINE CURRENTLY. AND SO WHAT THAT MEANS IS IF YOU HAD, UM, STUDIES COMPLETED, THOSE STUDIES REMAIN VALID, BUT IF, YOU KNOW, THE AGREEMENTS WITH THE TSP WERE NOT SIGNED AT THAT POINT, JUST UNDER THE INTERIM PROCESS, THIS RISK EXISTS AS WELL AS IT DOES TODAY. THERE IS THE RISK THAT THE, THE STUDY ASSUMPTIONS MIGHT CHANGE AND THE STUDIES MIGHT NEED TO BE UPDATED. AND SO IT IS GETTING THROUGH COMPLETED STUDIES AS WELL AS THE AGREEMENTS THAT LOCKS IN THE STUDY. AND THAT WAS TRUE UNDER THE INTERIM PROCESS AS WELL AS NOW. WELL, AND JUST TO, TO FOLLOW UP ON THAT REAL FAST IS IF IT, IF THE LOAD SIGNED, YOU KNOW, DID THEIR STUDIES, THEY SIGNED AGREEMENTS WITH THE, WITH THE TSP, THEN KIND OF ONE OF THE OTHER RELATED QUESTIONS IS DO THEY HAVE TO EXECUTE A NEW AGREEMENT THAT, YOU KNOW, MATCHES UP WITH 9.71 OR 9.72 OR CAN THEY CONTINUE TO MOVE FORWARD WITH THE AGREEMENTS THAT THEY SIGNED EARLY ON EARLIER ON? CHRISTINA, YOU WANT THAT ONE? YEAH, CHRISTINA SWITZER OR CUT COUNSEL, UH, AS CURRENTLY DRAFTED PICKER 1 45 WOULD REQUIRE AN INTERCONNECTION AGREEMENT THAT MEETS THE REQUIREMENTS OF THE PROPOSAL FOR PUBLICATION AND PROJECT 5 8 4 8 1, WHICH IS MAKING THE POINT I WAS TRYING TO MAKE. THANKS FOR CLARIFYING THAT. SO WHAT YOU'RE SAYING AG HERE IS NOT AN ACCURATE ANSWER TO MICHAEL'S QUESTION FOR INTERCONNECT AGREEMENTS. LET'S JUST PICK ONE THAT WAS 2024 INTERCONNECT AGREEMENT WITH THE UTILITY. IT'S AT THAT POINT IT IS PRECI BILL SIX, IT'S PRE PICKER ONE 15. THE ONLY THING THAT APPLIED BACK THEN WAS THE INTERIM LARGE LOAD INTERCONNECT PROCESS. WOULD YOU AGREE THE INTERIM LARGE LOAD INTERCONNECTION TO PROCESS WAS IN EFFECT IN 2024? CORRECT. SO FOR YOU HERE, ERCOT IS YOU'VE CONSISTENTLY KEPT IT IN HERE. THIS WAY YOU'RE POINTING THEM BACK, YOU'RE MAKING, WITH THE WORDS YOU'VE GOT WHERE YOU POINT TO SECTION NINE NINE, YOU ARE SUBJECTING THESE TO GO BACK THROUGH THE BIGGER ONE 15 PROCESS. EVEN IF YOU SAY YOU'RE NOT, THAT'S NOT INTENTIONAL AND I HOPE IT'S NOT INTENTIONAL. YOUR WORDS ARE DOING THAT THOUGH, [03:30:01] AND, AND SHE'S CLARIFIED THAT'S WHAT THEY'RE DOING. SO WHAT IS THE RETICENCE OF GETTING RID OF THE SECTION NINE NINE PIECE ON THIS SO THAT YOU DON'T, YOU'RE NOT FORCING THEM TO, TO GO BACK, RIGHT? 'CAUSE IF YOU POINT TO NINE 10 THAT WILL HAVE MADE THEM HAVE A SIGNED INTERCONNECT AGREEMENT AND MEET THE REQUIREMENTS OF NINE 10, WHICH ONES THAT ARE IN THAT CATEGORY WILL HAVE MET? YEAH, SO I, I GUESS I, I DON'T AGREE WITH THE CHARACTERIZATION THAT WE'RE FORCING ANYBODY TO GO THROUGH RE STUDIES. UM, UH, THE INTENTION, AND THIS IS WHAT I WAS TRYING TO ARTICULATE TO MICHAEL, IS, UH, THAT IF THE STUDIES ARE VALID AND THERE'S NOT BEEN A CHANGE IN ASSUMPTIONS FROM WHEN IT WAS STUDIED IN THE INTERIM PROCESS, THEN THOSE STUDIES WILL CARRY OVER INTO THE CURRENT, THE CURRENT FORMALIZED PROCESS. SO, UM, YOU KNOW, WHEN WE UNBOXED THE LANGUAGE LAST YEAR, WE DID NOT, UH, REQUIRE EVERY LARGE LOAD AND WE DIDN'T REQUIRE ANY LARGE LOADS THAT WERE CURRENTLY IN THE QUEUE TO BE RESTUDIED UNLESS ANOTHER PROJECT HAD MOVED FORWARD AND THAT CREATED THAT NEED. SO, UM, WHAT I'M TRYING TO SAY IS THAT STUDIES THAT WERE CONDUCTED DURING THE INTERIM PERIOD REMAIN, UH, SATISFACTORY FOR SECTION 9.9. AND SO THAT'S THE, CAN YOU SHOW US THE LANGUAGE IN NINE NINE THAT SAYS THAT THEN, BECAUSE IT'S POINTING OR UNLESS I'M MISREADING IT AND THAT'S POSSIBLE. IT'S POINTING TO YOUR, UH, PICKER ONE 15 PROCESS. IT'S WALKING, I MEAN IT'S RIGHT FROM, IT'S RIGHT FROM PICKER ONE 15. IT'S THE OLD NINE FOUR AND NINE FOUR EXISTING NOWHERE BEFORE PICKER ONE 15. CORRECT. HOWEVER, THE REQUIREMENT TO DO THAT SET OF STUDIES DID EXIST UNDER THE INTERIM PROCESS. WHERE WHERE DID, WHERE WAS THAT AN ERCOT BINDING DOCUMENT THAT SAID THAT IN THE MARKET NOTICE IN MARCH OF 2022? I JUST RE-READ THE THING A SECOND AGO AND GOT IT UP HERE ON THE PHONE. SHOW US WHERE THAT'S IN THERE BECAUSE IT, I DO NOT SEE THAT IT, THERE'S NOT SOMETHING IN THAT MARKET NOTICE THAT WILL POINT TO THE REQUIREMENTS OF WHAT IS TODAY IS NINE FOUR BECOME NINE NINE UP HERE. THERE'S NOT IT. SO IF YOU THINK THEY'RE THERE, SHOW US WHERE THAT'S THERE, I DON'T THINK WE HAVE ALL THOSE MATERIALS IN PLACE TO GO THROUGH THAT PROOF. WAS THAT IN YOUR COMMENTS ALSO, SHANNON, OR, I'M TRYING TO, AND AND MAYBE I'LL JUST REITERATE WHAT I SAID TO THE END OF MICHAEL'S COMMENTS, WHICH IS IF STAKEHOLDERS FEEL THAT THERE NEEDS TO BE CLARIFYING LANGUAGE FOR PROJECTS THAT COMPLETED STUDIES DURING THE INTERIM PROCESS TO CLARIFY THAT THEY'RE TREATED ON AN EQUAL LEVEL, UH, TO SUBSEQUENT, I THINK WE'D BE OPEN TO THAT. AND TO ANSWER YOUR QUESTION, UH, MATT, YES, I, THIS POINTING TO NINE 10 INSTEAD OF NINE NINE AND NINE 10 WAS IN OUR LAST SET OF COMMENTS. OKAY, COOL. TO HAVE THEM EMAIL ALSO. I'M JUST, YOU'RE BUILDING AN ARGUMENT WHICH IS ENCOURAGED RIGHT DEBATE, BUT TRYING TO GET ALL THE ARTIFACTS IN ONE PLACE TO CONNECT THE DOTS. I SEE. IT'S HARD TO DO ON THE FLY, SO, OKAY, COOL. UH, JUST ONE PIECE THAT I, I THAT'S TRUE WE DON'T HAVE ALL THE DOCUMENTS HERE IN FRONT OF US. I WOULD ALSO POINT YOU TO THE FREQUENTLY ASKED QUESTIONS DOCUMENT THAT WE POSTED THAT DESCRIBED WHAT WAS THE INTERIM PROCESS AND THE TRANSITION TO THE PGA ONE 15 PROCESS THAT MIGHT HELP ANSWER SOME OF YOUR QUESTIONS HERE. ALRIGHT. CAN I ASK A QUICK FOLLOW UP ON THAT? SO IN THE, IN THE Q AND A, ONE OF THE THINGS THAT IT SAID IS THAT, UM, IN GENERAL THE, UH, THE PROCESS WILL IN GENERAL BE REQUIRED TO COMPLY WITH THE REMAINING STEPS IN PI ONE 15 PROCESS, BUT WILL NOT GENERALLY BE REQUIRED TO COMPLETE ANY NEW ONE 15 REQUIREMENTS THAT WOULD APPLY TO AN EARLIER STAGE OF THE INTERCONNECTION PROCESS. AND, AND SO WE'VE GOT THAT KIND OF IN THAT DOCUMENT THERE. CAN WE RELY ON THAT THEN? I THINK THIS WAS A DOCUMENT TO HELP EXPLAIN THE TRANSITION PROCESS. IT WAS NOT A BINDING DOCUMENT, IF THAT'S WHAT YOU'RE ASKING. YEAH. OKAY. THANKS. ALRIGHT. UM, SANDEEP AND SO I'M SORRY REAL QUICK, CONSTANCE, SOMEONE'S GONNA LOOK AT YOUR QUESTION ONLINE AND REPLY BACK TO YOU IN A FEW MINUTES, BUT WE'LL KEEP WORKING THE QUEUE HERE. SANDEEP AND THEN JOHN RUSS. YEAH, THANKS FOR THAT. AND I THINK MOST OF THAT GOT DISCUSSED IN THE PREVIOUS DISCUSSION AFTER SHANNON'S QUESTION. UH, JUST WANTED TO, [03:35:01] I GUESS, POINT OUT THAT THE INTERIM PROCESS WAS APPLICABLE TILL DECEMBER 15 WHEN PGA ONE 15 WAS ROLLED OUT AND AS PART OF THE INTERIM PROCESS, YOU HAD AN EXEMPTION FOR WHAT'S CONSIDERED AS A LARGE LOAD THAT NEEDS TO GO THROUGH THE STUDY. THE TWO YEAR EXEMPTION, WHICH MADE IT, WHICH, WHICH MADE THE DIFFERENCE IS SO TO, TO EXPECT THAT YOU'LL HAVE SECTION 9.9 BEING MET. YOU'RE EXPECTING A STUDY TO BE, I DON'T KNOW, KICKED OFF ON DECEMBER 15TH OR AROUND THAT TIME AND BE STUDIED AND APPROVED BY MARCH 4TH, WHICH, WHICH JUST WOULDN'T HAPPEN, UH, GIVEN THE, THE SCALE OF THE STUDY. SO I, I HEAR YOU THAT THERE WERE STUDY REQUIREMENTS DONE AND A LOT OF THE REQUIREMENTS WERE DISCUSSED VIA SLIDES AND WEEKLY MONTHLY PRESENTATIONS. AND THEY APP THEY WERE APPLICABLE FOR LOADS THAT WERE ENERGIZING FAST, LIKE, UH, CRYPTO LOAD OR SOMETHING LIKE THAT. SO WE, WE, WE DID THOSE AS WELL, BUT YOU DID HAVE THESE LARGE LOADS THAT WERE RAMPING UP IN THREE, FOUR YEARS THAT DIDN'T NECESSARILY GO THROUGH THAT ENTIRE PROCESS DURING THAT TIME. AND I THINK WE HAVE SOME COMMENTS TO THAT EFFECT. BUT WHAT I HEARD AG FROM YOU IS YOU MENTIONED THAT TIED BACK TO THE, THE PROJECTS THAT WERE INITIATED DURING THE INTERIM PROCESS. AND MAYBE THAT'S, THAT'S ONE WAY TO, TO LOOK AT THEM AS WELL IS, IS PROJECTS THAT CAME BEFORE DECEMBER 15 THAT WENT THROUGH THAT INTERIM PROCESS, MAYBE TREATED, UH, IN A SLIGHTLY DIFFERENT MANNER. I'LL STOP THERE. YEAH, AGAIN, I THINK WE'D BE OPEN TO ADDITIONAL CLARIFICATION THERE. UM, BUT I DO WANT TO JUST ALSO REITERATE THAT MY COMMENTS ARE REALLY JUST SPEAKING TO THE CONTINUITY BETWEEN THE INTERIM FOR PROJECTS THAT ARE IN FLIGHT IN THE INTERIM PROCESS WHEN PLANNING GUIDE NINE BECAME UNBOXED. SO, UM, I I I DON'T WANT TO IMPLY THAT, UM, YOU KNOW, WE'D NECESSARILY BE OPEN TO JUST A BLANKET GRANDFATHERING OF EVERYTHING THAT WAS STARTED IN THE INTERIM PROCESS BECAUSE SOME OF THOSE, AS YOU POINTED OUT, MAY HAVE BEEN INITIATED A FEW DAYS BEFORE THE LANGUAGE WAS UNBOXED AND HAD NO REAL PROGRESS BEHIND THEM. SO, BUT AGAIN, THE INTENTION IS THAT STUDIES THAT WERE DONE IN THE INTERIM PROCESS PROVIDED ANOTHER LOAD DID NOT, YOU KNOW, GO PAST THE POST SINCE, YOU KNOW, BEFORE THOSE REMAINED VALID ONCE WE CROSSED INTO THE, THE CURRENT PLANNING GUIDELINE PROCESS. UH, YEAH, I GUESS WOULD LIKE TO GET SOME CLARIFICATION ON WHAT THAT MEANS WHEN YOU SAY LOADS THAT WERE IN FLIGHT IN THE PROCESS, UH, BECAUSE TECHNICALLY YOU'RE TALKING ABOUT A THREE YEAR TIME PERIOD FROM 2022 TO 2025, AND IF, IF THERE WERE PROJECTS THAT WERE INITIATED IN 23 OR 24 THAT WENT INTO THE STUDY CYCLE AND UD CYCLE BASED ON THE CHANGING REQUIREMENTS THROUGH THOSE YEARS, DO THOSE FIT THE BILL THERE OR, OR, OR I I I HEARD YOU SAY THREE TO FOUR DAYS BEFORE DECEMBER PI AGREE. I THINK BY JULY OF 2025 IT WAS FAIRLY CLEAR THE BIGGER 15 LANGUAGE WAS OUT THERE, WASN'T APPROVED, BUT WAS OUT THERE FOR PEOPLE TO USE. UH, BUT STUFF THAT CAME SOME, BUT THE CHALLENGE THERE IS YOU CANNOT GIVE A DATE AND SAY THAT'S THE DATE YOU CAN FOLLOW. SO THERE IS SOME AMBIGUITY IN TERMS OF, UH, WHAT WOULD YOU CONSIDER AS IN-FLIGHT THAT QUALIFIES YOUR, I I THINK THE QUESTION IS LESS ABOUT WHAT IS IN FLIGHT AND MORE ABOUT MEETING THE REQUIREMENTS OF COMPLETED INVAL, UH, COMPLETED STUDIES AND ALL REQUIRED AGREEMENTS AND FINANCIAL SECURITY ARE, AND NOTICE TO PROCEED ARE IN PLACE. AND SO THOSE ARE THE METRICS THAT WE'RE USING TO DETERMINE ELIGIBILITY FOR THE BATCH STUDY. AND UM, YOU KNOW, I THINK TO THE EXTENT IF WE NEED CLARIFYING LANGUAGE ON HOW THAT WAS MET IN THE INTERIM PROCESS, WE'RE OPEN TO THAT, BUT THAT'S STILL THE STANDARD WE'RE TRYING TO USE. ALRIGHT, THANKS. UH, JOHN, RUSS, AND THEN BACK TO SHANNON. GO AHEAD. JOHN. JOHN GENRES WITH TIEC. UM, I, MY QUESTION IS IN A SLIGHTLY DIFFERENT VEIN ON SECTION 9.4, SO IF I NEED TO BE TAKEN LATER, THAT'S FINE TOO. I DON'T WANT TO MESS UP THE FLOW OF SOME OF THE CONVERSATIONS. WHY DON'T YOU GO AHEAD. OKAY. UM, SO ON ON SECTION 9.4, PARAGRAPH TWO, I, I GUESS I'M CURIOUS ON HOW THIS APPLIES OR IF IT APPLIES TO, [03:40:01] UM, LOADS THAT ARE ENERGIZED AND GOING THROUGH THE BATCH PROCESS AND, AND PART OF THE KIND OF THE BASE LOAD. UM, MY READING IS THAT IT, IT WOULDN'T BECAUSE IT'S ONLY TALKING ABOUT LOADS THAT ARE ALLOCATED MEGAWATTS. UM, SO THOSE LOADS THAT ARE ENERGIZED THEN WOULD NOT HAVE TO, UM, EXECUTE A NEW INTERCONNECTION AGREEMENT OR ADJUST THEIR INTERCONNECTION AGREEMENT. CORRECT. THIS IS INTENDED JUST TO APPLY TO ASSESS LOAD THAT RECEIVES ALLOCATION. OKAY. THANK YOU SHANNON. I WANTED TO FOLLOW UP ON THE SANDEEP'S COMMENTS, UM, ABOUT THESE, UM, LOADS THAT WERE PART OF THE INTERIM PROCESS. AND IT REALLY STILL TIES INTO THAT SAME SECTION I WAS TALKING ABOUT WILL AGO. THE, THE INTERIM, UH, PROCESS MARKET NOTICE. YOU KNOW, IT'S SAYING THE, IT SAYS THIS INTERIM PROCESS IS EFFECTIVE IMMEDIATELY APPLIES TO LOAD INTERCONNECTION REQUESTS THAT HAVE NOT BEEN MODELED AND STUDIED IN A COMPLETED ERCOT PLANNING ASSESSMENT EEG, THE RTPA FULL INTERCONNECTION STUDY OR RPG REVIEW AND MEET THE FOLLOWING APPLICABILITY REQUIREMENTS. AND I WON'T GO THROUGH ALL OF THEM, BUT THE ONE THAT'S MOST RELEVANT IS THE FIRST ONE. IT'S LOADS THAT ARE, UM, WITHIN THE NEXT TWO YEARS. SO IT WAS LIMITED IN TIME TO THOSE THINGS WITHIN THE NEXT TWO YEARS AND OVER 75 MEGAWATTS, ALL OF THE ONES THAT I'M FOCUSED ON AND CARE ABOUT THE MOST OF OURS, THEY DO NOT MEET THAT WITHIN TWO YEARS PIECE. AND SO TO, IN YOUR TREATMENT THAT YOU'VE GOT THEM NOW, YOU'RE FORCING 'EM TO GO BACK THROUGH THIS SECTION NINE NINE OR THE CURRENT NINE FOUR WITHOUT ANY RECOGNITION THAT IT DIDN'T APPLY, UM, NARROWLY TO THAT. AND SO TSPS HAVE BEEN RELYING ON YOUR MARKET NOTICE. UM, OUT OF THAT 50 GIGAWATTS OF STUFF I CAME UP WITH AND PRESENTED A COUPLE OF MEETINGS BACK, THE VAST MAJORITY OF THOSE HAVE NOT GONE THROUGH THE SEPARATE PROCESS. UM, THEY, A DIDN'T, THEY WERE NOT SUBJECT TO THE NINE NINE PIECE AND OR THE, EXCUSE ME, THE INTERIM PROCESS PIECE, THEY WERE JUST AN RPG IS HOW THEY WERE, UH, TREATED. AND THEN YOU TALK ABOUT THE UNBOXING OF, UM, SECTION NINE IN DECEMBER 15TH, BUT THAT WAS SIX MONTHS AFTER IT GOT, UH, PUC, YOU KNOW, THE PUC APPROVAL ON MAY 15TH. UM, SO OR FOR NO 1234 OR NPR 1234 THAT WENT, THAT WAS A COMPANION TO IT. SO IT WENT FOR A FULL SIX MONTH PERIOD WHERE Y'ALL DIDN'T UNBOX IT. AND IN YOUR IMPACT STATEMENT THAT WAS FILED, UM, AT T Y'ALL SAY THAT IT HAD AN IMPLEMENTATION DATE OF 2026 AND IT, IT WASN'T EVEN EARLY 2026. SO ANYONE READING Y'ALL'S IMPACT STATEMENT, WHAT YOU'RE PUTTING OUT THIS INTERIM MARKET NOTICE, IT'S NOT IN THE LEAST BIT CLEAR YOU INTENDED TO UNBOX THAT ON DECEMBER 15TH. THERE WAS NOT SOME MARKET NOTICE THAT SAYS IT'S COMING NOW. TOO BAD. SO SAD IF YOU'VE GOT THESE RT UH, RPG PROJECTS OR RTP FOR THESE LOADS. THAT'S THE PIECE THAT I HOPE YOU CAN UNDERSTAND WHY, WHY THERE'S FRUSTRATION AMONG ANY OF THE PARTIES THAT ARE A PART OF THESE THAT EFFECTIVELY ARE BEING THROWN OUT AND BEING FORCED BACK THROUGH BECAUSE OF YOUR NINE NINE LANGUAGE THROUGH PICKER ONE 15. DOES THAT MAKE SENSE? SO, UH, I GUESS JUST A COUPLE COMMENTS THERE. UM, FIRST OF ALL, UH, SUBPARAGRAPH B IS NOT THE ONLY PATH INTO, UH, BATCH ZEROS BASE LOAD. UM, SECOND OF ALL THE STATEMENT THAT THERE WERE NOT MARKET NOTICES AS WE UNBOXED, UH, BOTH NPR 12, UH, 1234 AND BIGGER ONE 15, UH, IS INCORRECT. WE ARE OBLIGATED TO PUT OUT MARKET NOTICES PRIOR TO UNBOXING AND WE DID. UM, AND SO I WOULD ALSO ADD THAT WE ATTENDED AND PRESENTED AT MULTIPLE STAKEHOLDER MEETINGS IDENTIFYING THAT THE UNBOXING WAS GOING TO HAPPEN, UM, UH, LATER IN 2025. I DON'T HAVE THE IMPACT STATEMENT UP IN FRONT OF ME, SO I DON'T KNOW WHAT WHAT, UH, THE EXACT VERBIAGE IS THERE. UM, BUT I JUST WANT TO CLARIFY THOSE POINTS. I AGREE YOU HAVE MARKETING THOSE AS THAT SAY THEY ARE BEING UNBOXED. WHAT'S NOT CLEAR, AND I'VE TALKED TO [03:45:01] SEVERAL OF THE TSPS AND CONFIRMED THIS, IS THAT RPG FILINGS THAT THEY'VE BEEN WORKING ON FOR MANY, MANY, MANY MONTHS, I, I DON'T KNOW IF YOU'VE EVER PREPARED AND SUBMITTED ONE OF THESE, BUT THERE'S A LOT OF WORK THAT GOES INTO THAT, UM, TO PREPARE AND SUBMIT THOSE. IT TAKES A LONG TIME TO PUT IT TOGETHER. AND THE, THE PIECE THAT WAS NOT CLEAR TO THEM IS THAT LOADS THAT WERE ALREADY PART OF AN RPG THEY WERE WORKING ON AND COMMUNICATING TO ERCOT PRIOR TO THAT THAT THEY WERE WORKING ON, WERE GOING TO BE SUBJECT TO PR ONE 15 ONCE YOU UN GRAY BOXED IT. I'VE HEARD THAT FROM MULTIPLE TSPS THAT THAT WAS NOT CLEAR TO THEM. THUS IT WASN'T CLEAR TO MARKET PARTICIPANTS WHO WERE WORKING WITH OUR TSPS BECAUSE THEY ARE WHO WE'RE RELYING ON AND THEY'RE WHO'S TALKING TO YOU TO ERCOT. YEAH, I'M CERTAINLY OPEN TO HEARING FROM THE TSPS ON THAT, BUT I DON'T AGREE WITH THAT CHARACTERIZATION. WE DID STATE PUBLICLY AT, UM, AT MULTIPLE STAKEHOLDER MEETINGS THAT WHEN THAT LANGUAGE WAS UNBOXED IT WOULD APPLY TO ALL LARGE LOADS. SO IF I TOOK THAT 50 GIGAWATTS WORTH OF, UH, LOADS THAT I PRESENTED RECENTLY OUT AND I GAVE THE RPG FILINGS, IF YOU TOLD THEM THAT, THEN WE WOULD, WE WOULD EXPECT TO SEE THAT EVERY ONE OF THOSE LOADS THAT WERE IN THOSE HAVE BEEN FILED WITH YOU HERE IN PIGGER ONE 15 AG. I KNOW FOR SURE THEY'VE NOT BECAUSE I'M, I'M HEARING IT AND I'M, I'VE HAD THESE CONVERSATIONS TODAY WITH THE TSPS THAT ARE TELLING ME THIS. SO SHANNON, LEMME ASK, SO ARE YOU ASKING FOR LIKE ANOTHER, LIKE SUBPARAGRAPH HERE? IS THAT WHAT YOU'RE LOOKING FOR? WHAT I'M SPECIFICALLY ASKING FOR IS, IS WHAT WAS IN OUR COMMENTS LAST FRIDAY. OKAY. IT'S THE, THE RPGS THAT HAVE BEEN FILED WITH THESE LARGE LOADS IN THEM THAT WERE FILED AT A VERY MINIMUM THAT WERE FILED BEFORE THIS RULE OR Y'ALL'S LANGUAGE HERE GOT PUT OUT ON MARCH 4TH. THAT'S THE VERY, VERY, VERY MINIMUM THAT I THINK IS REASONABLE, UM, THAT THOSE SERVE AS THE VALID LOAD, UH, OR THE VALID STUDY FOR THEIR RELIABILITY PIECE. I'VE, IN CONVERSATIONS WITH YOU, I'VE UNDERSTOOD AND AGREE WITH YOU, YOU DO NEED SOME LOAD RAMP PIECE AND WE TRIED TO, YOU KNOW, COMING OUT OF THAT BY THE TSP AND WE INCLUDED THAT IN THE LANGUAGE WE FILED LAST FRIDAY. THAT'S THE MAIN THAT AND THEN THE ELIGIBILITY PIECE, THE ELIGIBILITY PIECE IN 9.2 0.1 0.1, WE MADE IT POINT TO THE SECTION NINE 10 BECAUSE IF YOU HAVE SIGNED AGREEMENTS, YOU DON'T NEED FORCE BACK THROUGH THIS NINE NINE PIECE IF THAT'S NARROWLY THE ONLY ISSUES THERE THAT I'M TRYING TO ACCOMPLISH WITH THIS. OKAY. ALRIGHT. AND SO YOU'LL GET A CHANCE ALSO TO GO THROUGH YOUR COMMENTS HERE IN A FEW MINUTES. ALRIGHT, VERY GOOD. UH, JOHN RUSS. OH, I'M SORRY. MICHAEL JEWEL NOW. YEAH, THANK YOU. JUST ONE FOLLOW UP QUESTION AG. UM, WHEN YOU WERE TALKING ABOUT, UM, IF YOU HAD THOSE STUDIES PRE P ONE 15, UM, THAT THEY WOULD BE VALID AS LONG AS THERE HADN'T BEEN A CHANGE. WHAT I WAS WONDERING ABOUT IS WOULD THOSE STUDIES BE TREATED THIS LIKE UNDER THREE B THERE, AS LONG AS THEY HAD BEEN APPROVED BY ERCOT BEFORE MARCH 4TH, THEY WOULD COME IN AS FIRM, FIRM BASE LOAD. THAT'S NOT SUBJECT TO REALLOCATION. IS THAT MY UNDERSTANDING? UNDER THE CURRENT LANGUAGE PROVIDED THAT THEY DIDN'T HAVE TO BE RESTUDIED SUBSEQUENT, WHICH IS THE, THE ISSUE WITH THE CURRENT PROCESS? YES, THAT SO, SO IT, WHAT I WAS SAYING IS THAT IF THERE WAS A MATERIAL CHANGE THAT OCCURRED THAT REQUIRED THE TSP TO UPDATE THE STUDY, WHICH WAS A RISK IN THE INTERIM PROCESS AS IT IS TODAY, UM, BUT PROVIDED THAT THE STUDIES WERE COMPLETE DURING THE INTERIM PERIOD AND AGREEMENTS WERE SIGNED, THEN IT WOULD BE TREATED ACCORDING TO PARAGRAPH B THERE. OKAY. AND THEN LIKE IF THEY WERE, IF THE STUDIES HAVE BEEN, UH, BEEN COMPLETED, AGREEMENTS HAVE BEEN SIGNED AND THEY WENT INTO AN RPG PROJECT WHERE NOTHING ELSE WAS GOING TO BE CHANGING AROUND THEM, AT LEAST FROM THAT, I THINK THAT'S PART OF WHERE SOME OF THE CONFUSION IS COMING FROM. I SEE. YEAH, SO, SO IF THEY, IF THEY HAD INTERIM STUDIES AND THEN WERE SUBSEQUENTLY PLACED IN AN RPG PROCESS, THAT DOESN'T DO ANYTHING TO THE INTERIM STUDIES. OKAY. UM, AND THERE'S ALSO, I'LL ALSO POINT TO, [03:50:01] UM, UH, LET'S SEE IF I CAN FIND IT HERE. UM, YEAH, SO PARAGRAPH, SO THIS IS PARAGRAPH FOUR B ROMAN, I, UM, IN THE EVENT THAT THE LARGE LOAD MEETS MULTIPLE CRITERIA ABOVE, UM, THEN IT WOULD BE GIVEN THE PLACE THE MOST, WHATEVER THE DATE THAT GIVES IT THE BEST PLACE ON THE LIST IS HOW WE WOULD ORDER IT. SO IF IT WAS GONE, WENT THROUGH THE INTERIM LOWEST STUDIES AND THEN WAS PLACED IN THEN WAS INCLUDED IN RPG SUBMISSION, UH, THEN THE LOWEST STUDIES WOULD BE THE DATE THAT WE WOULD USE AND WHAT DATE WOULD QUALIFY THEM THERE. WOULD IT BE THE DATE THAT ERCOT ORIGINALLY APPROVED THE STUDIES? WOULD IT BE THE DATE THAT THEY WERE SUBMITTED IN THE RPG? UH, THE DATE IS EITHER FOR SUBPARAGRAPH A IS THE DATE OF RPG, UH, ACCEPTANCE OR OR COT ENDORSEMENT DEPENDING ON IF ERCOT ENDORSEMENT WAS REQUIRED. UH, FOR THE LILI STUDIES, IT'S THE DATE THAT, UH, BOTH ARE SIMULTANEOUSLY TRUE THAT THE STUDIES ARE APPROVED AND ALL REQUIRED AGREEMENTS ARE IN PLACE THAT, IN OTHER WORDS, THE SECTIONS NINE, FIVE AND NINE. SO IF THEY HAPPEN TO BE IN AN RPG STUDY THAT HAS BEEN UNDER CONSIDERATION BY ERCOT FOR A LONG TIME, LOOKS LIKE IT MAY BE ON A TRACK TO BE APPROVED BY THE BOARD IN APRIL. THEY'RE OUT OF THIS. THEY'RE THERE. YEAH, THEY'RE, THEY'RE ASSESSED ACCORDING TO THE ORDERING LADDER THAT IS IN PARAGRAPH FOUR, BUT THEY'RE STILL, THAT IS STILL A VALID PATH INTO THE, THE REVIEW AS FOR AS FIRM BASE LOAD POTENTIALLY AS FIRM BASE LOAD, IF AN APRIL 4TH APPROVAL WOULD PUT THEM AFTER MARCH 4TH, UH, BUT WOULD STILL BE, WE WOULD STILL CONSIDER AS POTENTIAL BASE LOAD DEPENDING ON, UH, IF THERE'S, UH, ACCORDING TO THE VALID STUDIES TEST THAT'S, UH, DESCRIBED IN PARAGRAPH FOUR. YEAH, IT'S THAT WORD POTENTIAL THAT IT REALLY HAS PEOPLE UNNERVED, UH, THAT I THINK WE RECEIVED MULTIPLE COMMENTS THAT EFFECT. SO GOOD. THANK YOU. [6. Review any new Stakeholder Comments received] ALL RIGHT. THANK YOU. AG DON'T GO TOO FAR. SO WE'RE GONNA DO SWITCH OVER, DO SOME VERY HIGH LEVEL MATH HERE. WE HAVE EIGHT COMMENTERS, SO IF EACH OF THEM TAKES SEVEN MINUTES, THAT'LL TAKE US AN HOUR. SO, SO WHAT I'M GONNA DO IS GO BACK TO, I HAVE NOT CONFIRMED WITH WHO WANTS TO SPEAK, I'M JUST GONNA ASSUME EVERYONE DOES. SO WHAT I'LL DO IS ON OUR SLIDES HERE, SO MEMENTO, OKAY, SO HERE'S THE LIST. SO WHAT I'LL DO IS, ANDREW, IF YOU'RE ONLINE, DID YOU WANNA GO THROUGH YOUR COMMENTS AND I'M HAPPY TO OPEN THEM HERE AT THE PODIUM. HEY MATT, YOU CAN GO AHEAD, UM, AND I'LL DEFER TO LATER ON IF I CAN GO AT THE END. SO I'M SORRY, YOU'RE SAYING YOU'RE GONNA YIELD YOUR POSITION TO LET THE NEXT PERSON SPEAK AND THEN YOU WANNA DO THE LAST ONE? JUST YEAH, JUST GO AHEAD MATT. YEAH, YOU CAN SKIP ME. OKAY, VERY GOOD. UH, I THINK THEN WE'RE ON TO SHANNON. YES, IF YOU'D PULL UP OUR COMMENTS THAT WE SUBMITTED ON FOUR THREE. THIS IS THE GO AHEAD. THANKS. UM, IF WE'LL SCROLL DOWN TO 9.2 0.1 0.1, THE ELIGIBILITY CRITERIA PIECE 9.2 0.2 9.2. YEP. 1.1 9.2. UM, AG MAKES THIS LOOK SO EASY. HE DOES. MM-HMM. , THERE YOU GO. YEP, THERE IT IS. SO, UM, IN PARAGRAPH D, SO IN 1D TWO, THIS IS ONE OF THOSE PLACES WHERE WE CHANGE THE CRITERIA PIECE. UH, AS I WAS TALKING ABOUT A WHILE AGO, RIGHT NOW, THE WAY YOU'VE GOT IT IS EVERYTHING GETS POINTED TO NINE POINT WHATEVER, 9.7 0.2, AND THAT'S THE LANGUAGE. IF YOU GO READ IT, IT HAS THE, ALL OF YOUR PROJECTED 58 4 81 REQUIREMENTS IN IT. SO LOADS, UH, I'LL TAKE BACK TO MY HYPOTHETICAL WHILE AGO, A 2024 SIGNED ENTER CONNECT THAT WAS SIGNED BEFORE SENATE BILL SIX. [03:55:01] IT WAS SIGNED BEFORE YOU, UM, HAD PICKER ONE 15 THAT REMAINED GRAY BOX FOR SIX MONTHS. IT'S NOW BEING FORCED WITHOUT MAKING THIS CHANGE THAT WE'VE GOT HERE. AND I, I'LL CREDIT ANDY SCHAFER AS THE ONE WHO DID THE BEST JOB, AND I ACTUALLY JUST COPIED WHAT THEY HAD PUT HERE. YOU'RE FORCING 'EM OVER TO GO THROUGH THE, THE NOT EVEN YET APPROVED 58 4 81 REQUIREMENTS AND EFFECTIVELY INVALIDATING THEIR EXISTING CONTRACT. AND SO THAT'S WHY THIS NEEDS TO BE CHANGED AND, UH, HERE TO BE TIED TO NINE POINT 10. DO YOU, AND SO LET ME PAUSE AND SEE IF THAT MAKES SENSE. DO YOU UNDERSTAND WHAT I'M, WHAT I'M SAYING HERE AND WHY? YEAH, IT, I NOT, NOT ENTIRELY SHANNON, UM, BUT I, I GUESS AS YOU KNOW, TO CONTINUE OUR EXCHANGE EARLIER, I, I, I STILL DON'T, I'M NOT IN AGREEMENT THAT THIS I FORCE BACK THROUGH NINE POINT 10. WELL, IF WE GO READ 9.7 0.2, IT HAS THE 50,000 MEGAWATTS STUDY FEE. AND I MEAN, I COULD RUN THROUGH ALL THE PIECES OF IT AG THAT IT HAS IN THERE, BUT HOW CAN YOU SAY YOU DON'T THINK THAT APPLIES WHEN THAT'S EXACTLY WHAT'S IN 9.7 0.2 AND, AND THIS WILL BE THE LOADS THAT LONG PREDATE SENATE BILL SIX, FIGURE ONE 15 ON THEIR INTERCONNECT AGREEMENTS. SURE. CHRISTINA SWITZER OR CO COUNSEL, I THINK AS WE HAVE EXPLAINED BEFORE, AND AS BARKSDALE HAS EXPLAINED IN PREVIOUS WORKSHOPS WITH THE INTRODUCTION OF SENATE BILL SIX THAT SET A NEW BAR FOR LARGE LOADS SEEKING INTERCONNECTION, THESE ARE, WE ARE TALKING ABOUT LARGE LOADS HERE THAT HAVE NOT ENERGIZED. THEY ARE SEEKING INTERCONNECTION. AND SO WE HAVE USED WHAT THE PUC PUT OUT AS THEIR BEST THINKING ON THE IMPLEMENTATION OF SENATE BILL SIX. AND FOR BASE LOADS THAT ARE GOING TO BE CONSIDERED FIRM GOING FORWARD THAT ARE BEING ALLOCATED CONFIRMED MEGAWATTS IN BATCH ZERO, THEY'RE EXPECTED TO MEET THE INTERCONNECTION AGREEMENT REQUIREMENTS THAT WE HAVE INCLUDED IN 9 7 2 THAT WE HAVE AGREED WE MAY CHANGE BASED ON COMMISSION GUIDANCE ON APRIL 17TH. SO THAT IS A DISCUSSION THAT WE WILL CONTINUE TO HAVE AS WE GET FURTHER GUIDANCE FROM THE COMMISSION. BUT THAT'S THE EXPLANATION IN 58 4 81, THERE'S THE GROWTH IMPACT STATEMENT. UH, I'VE QUOTED IT TO YOU IN RECENT MEETINGS. I'LL QUOTE IT HERE ONE MORE TIME. PARAGRAPH SIX SAYS, THIS PROPOSED RULE WILL NOT EXPAND, LIMIT OR REPEAL EXISTING REGULATION. EXISTING REGULATION WE HAVE TODAY DOES NOT HAVE THAT REQUIREMENT. IN OTHER WORDS, READING THAT IT APPLIES TO FUTURE WHEN THIS RULE BECOMES EFFECTIVE FOR FUTURE CONTRACTS, PARAGRAPH SEVEN SAYS THE ONE RIGHT BELOW IT, THE PROPOSED RULE WILL NOT CHANGE THE NUMBER OF INDIVIDUALS SUBJECT TO THE RULES APPLICABILITY BECAUSE ONCE IT'S APPLICABLE, IT'LL APPLY TO THOSE PEOPLE. BUT THESE TWO STATEMENTS RIGHT HERE, RIGHT OUT OF THE GROWTH IMPACT STATEMENT OF 58 41, ARE COMPLETELY INCONSISTENT WITH ERCOT TRYING TO APPLY IT HERE IN A RETROACTIVE WAY. SO, YEAH, SO LET ME MAYBE JUST CUT OFF BECAUSE I DON'T THINK WE'RE GONNA SOLVE THAT HERE TODAY BECAUSE I THINK ERCOT IS GOING TO TAKE THE DIRECTION THAT THE COMMISSION GIVES US ON, ON THIS PARTICULAR ISSUE. SO I, I THINK THAT IT'S, I I THINK, I THINK WE'RE, WE'RE JUST GONNA GO ROUND IN CIRCLES HERE TODAY, SO I, I THINK IT'S PROBABLY MORE, I APPRECIATE THAT JEFF. EFFICIENT DIDN'T THE COMMISSION HAD TOLD YOU TO PUT IT IN THERE THIS WAY BECAUSE THE COMMISSION RULE IF, IF THEY BELIEVE THE STATEMENTS THEY'VE QUOTED, AND I SURE SUSPECT THEY DO. IT'S ONLY APPLIES FORWARD FROM WHEN THAT'S PASSED. AND UNLESS THERE'S SOMEWHERE ELSE WRITTEN DOWN THAT THEY SAID WE WANT IT TO APPLY IN A RETROACTIVE WAY TO ALL THESE OTHERS, THAT'S THE PIECE WE'RE YEAH. STRUGGLING WITH. I, I THINK, UM, I DON'T WANT SPEAK FOR BARKSDALE 'CAUSE HE'S NOT HERE TODAY, BUT, YOU KNOW, I THINK HE'S IN THE PAST STATED THAT, THAT THEY'RE MAYBE READING THAT A LITTLE DIFFERENT THAN, THAN THE WAY YOU'RE READING IT. I, AND I, I DON'T KNOW, YOU KNOW, OR, OR CUT. WE'RE NOT IN A POSITION THAT WE'RE GONNA MAKE THAT INTERPRETATION. I, I THINK WE'RE GOING TO TAKE THE DIRECTION, UH, THE, THE GUIDANCE THAT THEY GIVE US AND, AND THAT'S WHAT WE'RE GONNA TRY TO FOLLOW FOR THIS. AND, AND SO [04:00:01] YEAH, IT, IT PROBABLY BEST TO LEAVE IT AT THAT. ALRIGHT, SO ON THAT, IT SOUNDS LIKE YOU NEED US TO TAKE THAT ISSUE UP WITH THE COMMISSIONERS AND, AND GET THEM TO DIRECT YOU TO MAKE THIS CHANGE. IS THAT WHAT YOU'RE SAYING? BECAUSE IF WE CAN'T THIS FORM, I THINK THAT'S CONSISTENT WITH WHAT OUR YEAH, WITH WHAT OUR COMMENTS SAID THAT WERE POSTED, THAT IF YOU HAVE A DIFFERENT OPINION ABOUT, ABOUT WHAT YOU WOULD LIKE TO SEE, FILE THOSE COMMENTS WITH THE PUC. OKAY. THE NEXT PIECE IS 9.2, 0.1 0.4, PARAGRAPH THREE. THIS WAS THE RPG PIECE. AND HERE WE, FOR THE REASONS I WAS LAYING OUT A WHILE AGO WHEN WE WERE HAVING THE PRIOR EXCHANGE, UM, RELATED TO MICHAEL JEWEL'S QUESTIONS AND SANDEEP'S THE DECEMBER 15TH, I AGREE THAT IS WHEN YOU UNBOXED PICKER ONE 15. COULDN'T AGREE MORE. THERE WAS A SIX MONTH PERIOD BETWEEN THE TIME THE COMMISSION LAST SAW IT IN MAY 15TH, AND Y'ALL UNBOXED IT ON THE 15, YOU KNOW, SIX MONTHS LATER, DECEMBER 15TH. DURING THAT TIME, THE INTERIM LANGUAGE THAT WE TALKED ABOUT IS WHAT WAS IN EFFECT. AND THE INTERIM LANGUAGE ONLY APPLIED TO LOADS THAT WERE TWO YEARS AND IN, AND YOU HAD RPG PROJECTS THAT WERE UNDERWAY THAT WERE BEING DEVELOPED BY THE TSPS. AND WE'VE ESTABLISHED HOW LONG THAT PROCESS IS. SO THE CHANGE HERE WE MADE IS, WHILE I HEAR AND CAN AGREE YOU DID UNBOX ON DECEMBER 15TH, IT IS NOT, UH, CLEAR FOR ALL THE REASONS WE TALKED ABOUT EARLIER, WHY THAT SHOULD BE RETROACTIVE AND COULD HAVE BEEN MARCH 4TH OR SOMETHING. BUT WE TIED IT TO APRIL 1ST FOR THE REASON THAT THE PC RULE IN 58 4 80, WHICH IS NOT A ONGOING RULE MAKING, IT'S ACTUALLY A PROPOSED RULE IS VERY CLEAR THAT FOR RPG STUDIES THAT ARE STUDIED, UH, PRIOR TO THE LOAD SUBMISSION FOR THE 2026, UH, RTP, WHICH WAS APRIL 1ST, WAS THE DEADLINE. THOSE ARE TO CONTINUE TO BE STUDIED WITH THE PREVIOUS METHODOLOGY FOR SUBMISSION FOR THOSE. SO WE'VE MADE THAT CHANGE FOR THAT REASON, BECAUSE AT LEAST IT'S ROOTED IN A P YOU KNOW, A ACTUAL PUC RULE THAT HAS, THAT'S NOT AN ONGOING RULE MAKING AND THAT'S THE LOGIC FOR MAKING THAT CHANGE. UH, THERE ALSO, WE ADDED LANGUAGE HERE, UM, IN THAT SAME PARAGRAPH, THIS WAS ME TRYING TO TAKE A STATED ISSUE THAT JEFF HAS TALKED ABOUT PREVIOUSLY AND WAS A SUBJECT IN OUR LAST BATCH PROCESS MEETING. I THINK SANDEEP HAD ASKED A QUESTION HOW IN THE LAST MEETING, HOW WILL YOU, FOR THE RPGS YOU ARE PLANNING TO COUNT IF, UM, YOU KNOW, THE RPGS, THE END STATE YEAR, UH, I'LL MAKE IT UP. IT'S 2030 IN A STUDY AND THERE MAY HAVE BEEN 5, 6, 7 LOADS IN THERE. TRUTHFULLY, THE SYSTEM HAS THE ABILITY TO SERVE. FIRST OF ALL, NOT ALL THOSE LOADS WANT POWER OF THIS, OF THE MAXIMUM AMOUNT IN YEAR ONE. UH, MANY OF THEM ARE SEQUENTIAL IN NATURE AND HAVE A RAMP TO THEM, BUT THE SYSTEM'S ABILITY TO SUPPORT SOME FAIR AMOUNT OF THAT EXISTS TODAY. UM, IN MANY CASES, NOT IN ALL CASES. SO I TRIED TO SUGGEST SOMETHING HERE THAT THE RPG SPONSOR THAT HAD SUBMITTED IT TO THE DEGREE THEY GET YOU A, UH, RAMP A SOMETHING THAT'S A MEETS THE FUNCTION. IT'S A LOAD COMMISSIONING PLAN, MEETING THE FUNCTIONAL REQUIREMENTS OF PARAGRAPH SEVEN OF, UH, 9, 9 9, THEN YOU WOULD HAVE A RAMP SCHEDULE YOU WOULD BE ABLE TO USE FOR THOSE AND YOU WOULDN'T DEFAULT TO WAITING AND GIVING THEM ZERO ALLOCATION WHEN THERE'S CLEARLY GRID CAPACITY OUT UNTIL THE YEAR THAT THE RPG UH, FULL SET OF UPGRADES WERE MADE. WE THINK THAT'S SUPER, SUPER IMPORTANT OR OTHERWISE YOU'RE GOING TO BE UNNECESSARILY RESTRICTING. YOU KNOW, IT'S NOT LIKE TEXAS IS FULLY OPEN FOR BUSINESS. IF WE, IF THERE'S CAPACITY THAT EXISTS AND YOU DON'T, UM, ALLOCATE IT OUT TO THE LOADS THAT WERE A PART OF THAT OR DON'T ALLOW THE TSPS TO HELP YOU SOLVE THAT PROBLEM. [04:05:01] SO THAT WAS A KEY PART OF THAT, UM, RECOMMENDATION THERE. SAME, UH, COMMENT ON THE APRIL 1ST DATE, THEN GO TO PARAGRAPH FOUR. IT'S REALLY THE SAME COMMENTS THAT I'D MADE BACK ON PARAGRAPH THREE, BUT WHAT I DID HERE WAS DREW A BRIGHT LINE OF THOSE THAT RPGS THAT WERE FILED AFTER FOUR ONE, THEY HAD TO GO THROUGH THE PRIORITIZATION PROCESS JUST LIKE ANY OTHER LOAD. I WAS TRYING TO MAKE THAT PIECE CLEAR, UM, IN WHAT I WAS CHANGING THERE. AND THEN LASTLY, IF YOU GO DOWN TO PARAGRAPH E OF THAT SECTION, IT WAS TRYING TO, UH, PUT IN THE COORDINATION PIECE WITH THE INTERCONNECTING T-S-P-D-S-P. IT'S JUST TAKING A PAGE OUT OF CENTER POINTS, PRIOR COMMENTS ON THAT THAT I THOUGHT WERE GOOD. AND THEN THE LAST PIECE YOU SCROLL DOWN SLIGHTLY FURTHER IS CENTER POINT IN THEIR COMMENTS. THEY HAD FILED PREVIOUSLY MENTIONED THE 3% SHIFT FACTOR CUTOFF. THAT IS WHAT ERCOT HAS USED FOR THE LONGEST TIME IN ALL OF YOUR STUDIES THEY HAD SUGGESTED PUTTING THAT IN HERE AND CODIFYING IT. I COMPLETELY AGREE. THEN YOU'VE GOT SOMETHING OBJECTIVE THAT EVERYBODY'S WORKING OFF OF. AND THEN THE ONLY MODIFICATION I MADE TO THAT WAS WHEN USING A DISTRIBUTED SLACK BUS METHODOLOGY INSTEAD OF, YOU KNOW, THE WA PARISH, UH, SLACK BUS THAT'S IN THE CASE, YOU NEED TO DO A DISTRIBUTED SLACK BUS APPROACH OR YOU GET ERRONEOUS, YOU KNOW, YOU GET INCONSISTENT NON MEANINGFUL OUTCOMES. UM, AND WHEN I MENTIONED THAT IN ONE OF THE PRIOR MEETINGS, I THOUGHT JEFF HAD HAD AGREED WITH OR, YOU KNOW, NODDED THAT THAT SEEMED TO MAKE SENSE. THAT'S THE NARROW SET OF COMMENTS WE HAVE. THEY'RE ONLY AROUND THE ELIGIBILITY PIECE, MAKING SURE EXISTING CONTRACTS AREN'T GETTING RETROACTIVELY UH, THROWN INTO A FUTURE SET OF REQUIREMENTS WHEN YOU HAVE BINDING LEGAL BINDING CONTRACTS THAT ARE OUT THERE TODAY AND THEY'RE IN STUDIES. AND THEN THE RPG PIECE. THANK YOU. VERY GOOD. AND SHANNON, THERE'S SOME PEOPLE THAT JUMPED IN THE QUEUE WHILE YOU'RE PRESENTING, SO WE'LL RUN THROUGH THREE. MICHAEL, ANDREW AND THEN JOHN, JOHN, RUSS, MICHAEL FIRST. THANKS MATT. IF YOU COULD GO TO, UH, PAGE 12 OF THE COMMENTS IS WHERE WE WERE FIRST TALKING ABOUT, UH, 9.2 0.1 0.1 D. YEAH, RIGHT THERE. UH, WITH REGARD TO D TWO, THERE'S NOT A, I DON'T HAVE A SOLUTION TO THIS YET, BUT I JUST WANTED TO BE SURE THAT IT WAS ON FOLKS' RADAR SCREEN WAS ABLE TO TALK TO, JUST GIVE A HEADS UP TO CHRISTINA AS WELL THAT THERE'S AN ISSUE. BUT THIS REFERENCE TO HAVING THE, UH, LOAD HAS EXECUTED AN INTERCONNECTION AGREEMENT THAT MEETS THE REQUIREMENTS DEFINED IN NINE POINT, UM, 1.7 0.2 OR 9.7 0.2, THERE'S KIND OF A CIRCULAR PROBLEM HERE BECAUSE ONE OF THE REQUIREMENTS IN 9.7 0.2 IS THAT YOU POST FINANCIAL SECURITY FOR SYSTEM UPGRADES THAT ARE NECESSARY TO RELIABLY SERVE THE ILLE. THAT IS AN OUTPUT OF THE BATCH STUDY PROCESS. SO AS A PRACTICAL MATTER, YOU CAN'T HAVE IT AS PART OF THE REQUIRED INPUTS. UM, SO THERE'S, THERE'S A CIRCULAR ISSUE HERE THAT I KNOW Y'ALL ARE WRESTLING WITH, BUT I JUST WANTED TO TO HIGHLIGHT THAT. ALRIGHT, THANKS MICHAEL. ALRIGHT, ANDREW. HEY GUYS. UH, ANDREW SHOPPER, SHOPPER ENERGY CONSULTING. THANKS FOR TAKING THE TIME AND RUNNING US TO THESE COMMENTS. THIS IS GREAT AND THANKS SHANNON FOR PRESENTING ON ON YOUR COMMENTS AS WELL. UM, THIS IS MAYBE BACK TO THE ISSUE THAT I THINK CHRISTINA AND, AND, UM, AND SHANNON WERE DISCUSSING A MINUTE AGO, BUT ON THE SAME PROVISION, WE'VE MADE COMMENTS TO THIS. I KNOW ERCOT IS WAITING ON GUIDANCE FROM THE COMMISSION ON THIS POINT IN WHICH I, YOU KNOW, FROM WHAT I'M HEARING IS GONNA BE DELIVERED ON OR BEFORE POTENTIALLY APRIL 17TH IF THE COMMISSION DOES NOT ISSUE GUIDANCE TO ERCOT AROUND THE RETROACTIVE APPLICATION OF INTERCONNECTION STANDARDS, WHICH AGAIN SHOULD NEVER BE THE ASSUMPTION. IT SHOULD ALWAYS BE SOMETHING THAT'S DIRECTED AND, AND, AND FRANKLY JUST AGAIN, THIS IS PRETTY UNSETTLING THAT FOLKS ARE GONNA BE ENTERING INTO THESE INTERCONNECTION AGREEMENTS THAT ARE GONNA BE SOMEHOW UNWOUND OR AMENDED WITH NO TIME, RIGHT? SO THAT, THAT'S ANOTHER THING I JUST WANNA HIGHLIGHT THAT IT'S, UH, THE TIMELINE ON THIS IS NOT GONNA WORK VERY WELL EITHER, BUT ERCOT IS GONNA BE PUT INTO THE UNENVIABLE POSITION OF IMPOSING RETROACTIVE INTERCONNECTION STANDARDS WITHOUT A COMPLETED COMMISSION [04:10:01] RULEMAKING. AND I DON'T SEE ANY OTHER WAY TO GET TO THAT END POINT HERE WITHOUT THAT BEING THE CASE. SO ABSENT THE GUIDANCE FROM THE COMMISSION ON THIS POINT, I WOULD JUST CONTINUE TO URGE ERCOT ON THIS POINT SPECIFICALLY THAT'S ON THE SCREEN TO REVERT TO LANGUAGE AS SHANNON INDICATED. UM, AND WE HAVE IN PAST COMMENTS WHICH WILL REINFORCE THAT THE CURRENT LAW IS BINDING UNTIL REPLACED AND THAT CHANGES TO THE INTERCONNECTION STANDARDS ARE PROSPECTIVE NOT RETROACTIVE. UM, AGAIN, I MEAN, NOT TO GET TOO FAR INTO THIS, WE POINTED IT OUT IN OUR LAST COMMENTS, BUT TEXAS LAW IS CLEAR ABOUT THE FACT THAT RETROACTIVITY OF A STATUTE IS NEVER ASSUMED. SO IT HAS TO BE STATED EXPLICITLY FOR THIS NOT TO WIND UP OPEN TO A LEGAL CHALLENGE. SO I JUST WANNA POINT THAT OUT, YOU KNOW, THAT'S GONNA BE SOME, THIS IS GONNA AFFECT A LOT OF PEOPLE'S INTERCONNECTION AGREEMENTS, SO I'LL YIELD THE REST OF MY TIME. I THANK YOU ANDREW, JOHN, RUSS, JOHN RUSS, HOWEVER, WITH TIEC, UM, ALSO CIRCLING BACK TO THE, THE CONVERSATION WITH CHRISTINA, UM, I, I I GUESS FOR LOADS THAT HAD NOT ENERGIZED BUT ARE INCLUDED IN BASE LOAD, MY READING OF 9.4 WAS THAT IT STILL ONLY APPLIED THE NEW INTERCONNECTION AGREEMENT REQUIREMENTS STILL ONLY APPLIED IF THE LOADS WERE SUBJECT TO AN ALLOCATION. AM I MISUNDERSTANDING SOMETHING THAT'S NOT THE WAY I READ IT, SORRY. CHRISTINA SWITZER COUNSEL LOADS THAT ARE CONSIDERED BASE LOADS THAT HAVE NOT ENERGIZED OR I DON'T HAVE IT RIGHT IN FRONT OF ME, BUT MET THE QSA REQUIREMENT. I THINK IT'S C UM, THEY HAVE ALL THE OTHER LOADS HAVE TO, UH, HAVE MET AND INTERCONNECT HAVE MET THE REQUIREMENTS FOR THE INTERCONNECTION AGREEMENT IN 58,481. SO THAT'S WHAT THE, IT, IT'S NINE SECTION 9 7 2 IN PI 1 45. IF YOU ARE A TWO B STUDY LOAD SUBJECT TO ALLOCATION, THEN YOU ENTER INTO THE INTERMEDIATE AGREEMENT AND 9 7 1, WHICH IS BASED ON THE INTERMEDIATE AGREEMENT REQUIREMENTS M 58,481 COMING OUT OF THE ALLOCATION. WHEN SHE RECEIVED THAT, THAT'S WHEN THOSE STUDY LOADS HAVE TO ENTER INTO A CONFORMING INTERCONNECTION AGREEMENT. UH, UNDERSTOOD. SO JUST TO BE CLEAR, IT'S, IT'S FOR LOADS THAT HAVEN'T ENERGIZED, THE GATING ITEM IS MEETING THE 9 7 2 REQUIREMENTS. SO EVEN THOUGH THEY ARE BASE LOAD, THEY, THEY DON'T HAVE TO MEET IT DURING THE COMMITMENT PHASE BECAUSE THEY'VE ALREADY MET IT AT THE PREVIOUS PHASE. OKAY, THANKS. CORRECT. ALRIGHT, SO WE'RE GONNA TRANSITION OVER THE QUEUE IS CLEAR. SO WE'LL GO OVER TO LEE. DO YOU WANT ME TO PULL UP CIPHER COMMENTS? THAT'S OKAY, MATT, I'VE JUST GOT A FEW SECONDS WORTH. YEP. UH, ESSENTIALLY MY COMMENTS WERE TO REQUEST THAT ERCOT AMEND AND FIX THE ISSUE AROUND THE INTERMEDIATE INTERCONNECTION AGREEMENT, THE POTENTIAL FOR SOMEONE TO HAVE PAID $50,000 PER MEGAWATT FOR MEGAWATTS THAT EVENTUALLY GET REALLOCATED. AND, UM, I'M HEARING THAT IN THE TESTIMONY THAT COMMISSIONER GLEASON GAVE TODAY IN THE TEXAS HOUSE, THAT HE INDICATED THAT THAT'S WHAT THEY'RE PLANNING ON DOING, PROBABLY COMING OUT ON APRIL 16TH OR WHENEVER THAT DATE WAS. SO, SEEMS LIKE THAT ISSUE IS, IS BEING CLEARED UP. THAT'S ALL I HAD. THANKS FOR THE REAL TIME UPDATE. ALL RIGHT, UH, ENGINE NUMBER ONE, ADAM TAYLOR, IF YOU'RE ONLINE, DID YOU WANNA PRESENT ANY QUESTIONS OR GO THROUGH YOUR COMMENTS? THIS, THIS IS, UH, BILL BORQUE. MATT, I, HEY, BILL, COVERING, I'M GONNA BE COVERING THE, THE COMMENTS BY ENGINE NUMBER ONE. EXCELLENT. WOULD YOU LIKE ME TO OPEN THE COMMENT FORM FOR THE, FOR THE INTRODUCTION ON THE, ON THE WEBPAGE? OOPS. ALRIGHT. MISSED IT. HOLD ON. THERE YOU GO. UP I GET GOING. THIS IS BILL BOHOR AGAIN, ON BEHALF OF ENGINE NUMBER ONE. UM, ERCOT AND STAKEHOLDERS HAVE EXPRESSED AN INTEREST IN THE BYOG TO BRING YOUR OWN GENERATION CO-LOCATION MODEL UNDER THE SELF-LIMITING FACILITIES. UM, THE TRANSMISSION PLANNING FOLKS DO NOT ASSUME THE SIMULTANEOUS FULL LOAD AT THE POI AS A RESULT OF THE CO-LOCATION. THIS HAS A LOT OF BENEFITS. NUMBER ONE, IT REDUCES GRID CONGESTION. NUMBER TWO, LOWERS TRANSMISSION COSTS FOR ALL CONSUMERS. THREE, IT CAN PROVIDE EXCESS GENERATION AND OPERATING RESERVES. AND NUMBER FOUR PROVIDES HIGH RELIABILITY AND CAN REDUCE UPWARD [04:15:01] PRESSURE ON POWER PRICES. THERE'S BEEN DISCUSSION TODAY ABOUT THE RANGE OF OPERATIONS, UM, FROM ZERO MEGAWATT IN INTAKE TO ALLOWING SOME LOAD AND FULL GENERATION OUTPUT, AND WE ARE IN SUPPORT OF THAT. BUT TO ADVANCE THE DISCUSSION, WE PROVIDED THESE COMMENTS, UM, TO FACILITATE B-Y-O-B-P-Y-O-G PARTICIPATION IN BATCH ZERO BY CREATING A PATH FOR BATCH ELIGIBILITY WHILE GETTING SOME CREDIT FOR BRINGING THE NEW GENERATION THAT IS NOT CURRENTLY CURRENTLY IN THE PLAN. WE, WE, WE AGREE THAT IT SHOULD NOT BE GENERATION THAT HAS MET SECTION 6.9. SO IF WE CAN GO TO THE SPECIFIC OPTIONS IN RED LINE. SO ENGINE ONE PROPOSE, DO YOU KNOW WHAT SECTION THAT WAS IN? BILL? SORRY, I OH, IT'S IN THE, IT'S GONNA BE IN THE, UH, BASE LOAD DESIGNATION. ANYBODY? 9 2 9 2 1 1. UH, THERE IT IS. OKAY. IS THIS WHERE YOU WANNA BE, BILL? YEAH. OKAY, GREAT. SO, SO THIS, WE, WE PROVIDE FOUR OPTIONS. THEY'RE INDEPENDENT, SO YOU DON'T HAVE TO, UH, AGREE TO ALL FOUR. ONLY ONE OF THESE OPTIONS SHOULD WORK. BUT, UM, OPTION ONE AND TWO ARE UNDER THE BASE LOAD ASSUMPTIONS OR DESIGNATION. AND WHAT WE WOULD RECOMMEND IS THAT THOSE THAT HAVE AN ENERGIZATION DATE ON OR AFTER JANUARY 1ST, 2028 AND THE, UH, GENERATOR HAS SUBMITTED OR IS UNDERGOING A FULL INTERCONNECTION STUDY, THEN, UM, WE COULD, UH, AGREE TO CO-LOCATE THAT LARGE LOAD. AND AS PART OF THE FIS AS LONG AS THEY, UH, WE MEET THE REQUIREMENTS IN THE, IN THE APPLICATION SECTIONS FOR THE FIS AND THEY'RE BEHIND A COMMON POI. SO THAT'S KIND OF OPTION ONE. OPTION TWO IS SIMILAR WHERE YOU HAVE SUBMITTED AN FIS BUT BECAUSE WE DIDN'T HAVE THIS BYOG CONCEPT BEFORE, SOME FOLKS HAVE DONE A LLI AND NFIS. SO OPTION TWO WOULD, WOULD RECOGNIZE THAT THOSE TWO MAY BE COMBINED AS LONG AS THEY'RE UNDER THE SAME POI OR POIB OR SERVE AS DELIVERY POINT. UM, AND AS LONG AS THEY ARE, UH, UNDER REVIEW, AGAIN, UNDER THE PROPER FIS AND LLI PROTOCOLS, SO THOSE ARE OPTIONS ONE AND TWO. OPTIONS THREE AND FOUR ARE THE SAME, BASICALLY OPTION ONE MIRRORS OPTION THREE, AND OPTION TWO IS EXACT SAME LANGUAGE AS OPTION TWO, EXCEPT THAT THEY WOULD BE SUBJECT TO LOAD ALLOCATIONS. SO THEY'RE IN THE LOAD ALLOCATION SECTIONS. THERE YOU GO OF, UM, OF FIGURE 1 45. SO I'LL STOP THERE AND OPEN IT FOR QUESTIONS. ALL RIGHT, THERE'S NO QUESTIONS IN THE ROOM. I WILL THANK YOU FOR THE LANGUAGE TO HELP US JUMPSTART THE BYOG DEVELOPMENT, BUT YEAH, OPEN IT UP FOR ANY COMMENTS OR QUESTIONS ON BILL'S APPROACH. ALRIGHT, THANK YOU MATT. ALRIGHT, THANK YOU BILL. ALL RIGHT, WE'LL PIVOT BACK TO THE PRESENTATION. I KEEP DOING THIS. DO I HAVE TWO VERSIONS OF THIS THING OPEN? APOLOGIES. HERE WE GO. ALRIGHT, LCRA. WILL THIS BE BLAKE OR SANDEEP? HEY MATT. BLAKE HOLT WITH LCRA. I'LL, I'LL COVER. UH, AND WHILE YOU'RE PULLING UP THE COMMENTS, JUST WANTED TO CONFIRM IF WE INTRODUCED RED LINES. Y'ALL ARE PLANNING ON PROVIDING FEEDBACK SIMILAR TO YOUR LAST SET OF COMMENTS. WE ARE HOPING TO WE'LL SEE IF WE DO THAT SAME GRANULARITY THE WAY WE DID, BUT YES. OKAY, WELL, I'LL INTRODUCE EVERYTHING AND PERHAPS WE CAN TAKE SOME FEEDBACK LIVE IF, IF THAT WORKS OUT AS WELL. UH, SO FOR OUR FIRST TWO POINTS, AND WE CAN JUST STAY IN THE PREAMBLE, I THINK TO GET THE CONCEPTS OUT, UH, THESE FIRST TWO POINTS POINT BACK TO SOME OF THE COMMENTS SANDEEP MADE EARLIER. UH, SO RECOGNIZE THAT WE MAY BE ABLE TO TAILOR OUR RED LINES TO POINT MORE SPECIFICALLY AT, UH, THE INTERIM SCENARIO THAT WAS DISCUSSED EARLIER. BUT WHAT WE ESSENTIALLY TRIED TO POINT OUT IS THERE ARE SOME LARGE LOADS THAT WERE EXEMPT FROM THE LILI PROCESS AND DID NOT MEET [04:20:01] CRITERIA FOR RPG. AND UNDER THE CURRENT PIGGER, THESE WOULD NOT BE TREATED AS HAVING VALID, UH, STUDIES. SO, UH, WE VIEW THESE LOADS THAT HAVE PERHAPS SIGNED AN INTERCONNECTION AGREEMENT, STARTED SITE SITE PREP, HAVE ORDERED, UH, EQUIPMENT AS, AS MEETING A HIGH BAR. AND SO WE WERE TRYING TO CREATE A PATH FOR THEM TO ACHIEVE A VALID STUDY. AND SO THE WAY WE SEPARATED THOSE BETWEEN POINTS ONE AND TWO IS WE CREATED SOME RED LINES FOR THOSE THAT WERE NOT CONSIDERED TO HAVE VALID STUDIES BUT HAD DONE EVERYTHING ELSE, UH, HAVE THEM TREATED AS BASE LOAD AND FOR, UH, THE ALLOCATED LOAD PIECE, IF THEY HAD DONE EVERYTHING BUT HAD NOT, WERE NOT CONSIDERED TO HAVE VALID STUDIES OR HAD NOT STARTED SITE PREP, UH, GAVE THEM A PATH TO BE TREATED AS ALLOCATED LOAD AND RECOGNIZED THAT WE, THIS COULD BE TIGHTENED UP, UH, PERHAPS TO POINT MORE AT THE INTERIM PROCESS, BUT THAT'S HOW WE ORIGINALLY, UM, ENVISIONED APPROACHING THAT. UM, AND WE COULD SCROLL DOWN TO 0.3, UH, JUST OFFERED UP SOME, SOME CLARIFICATION HERE. WE NOTICED ALL OTHER REQUIREMENTS UNDER 9 2 1 2 HAD A CUTOFF DATE, BUT, UH, PARAGRAPH ONE B DID NOT. WE JUST INSERTED, UH, JULY 24TH HERE TO KIND OF PROVIDE SOME SYMMETRY WITH THE OTHER REQUIREMENTS. UM, FOR POINT NUMBER FOUR, THIS IS MAYBE SOMETHING WE CAN GET SOME REAL TIME FEEDBACK ON. UH, IN THE ALLOCATION SECTION THERE IS A REFERENCE TO CONSIDER THE LCP. AND SO I THINK LCRA AGREES WITH THIS AS LONG AS IT'S THE LCP THAT ALIGNS WITH, UH, THE INTERMEDIATE OR INTERCONNECTION AGREED UPON AMOUNT. IF WE'RE GOING BACK TO LOOK AT A LCP THAT WAS AN OUTPUT FROM A PREVIOUS STUDY, WE MAY BE PRE LIMITING, UH, THE RESULTS THAT WE COULD GET. SO ESTABLISH A MORE APPROPRIATE BASELINE WITH AN LCP THAT LIES, UH, ALIGNS WITH AGREED UPON AMOUNT. UM, CURIOUS IF THAT'S WHAT THE APPROACH Y'ALL WERE EXPECTING TO UNDERTAKE AG OR CAN YOU GIMME CLARITY THERE? YEAH, UH, THIS IS AG SPRINGER WITH . YEAH, BLAKE, I, THIS I THINK HAS COME UP VERBALLY AT PAST WORKSHOPS AND, UM, IT, IT, IT IS ON OUR RADAR SCREEN TO NOT MAKE IT INTO THIS, THESE COMMENTS, BUT, UM, I I THINK THAT WE'RE, WE'RE OPEN TO THAT APPROACH. SO, UM, YEAH, WE'LL REVIEW THE SPECIFIC RED LINES AND, AND RESPOND FROM THERE. APPRECIATE THAT AG. UH, POINT NUMBER FIVE, UM, THIS IS THE SECTION, UH, EVALUATION OF EXISTING INTERCONNECTION SECTION 9 2 1 4. UH, WE ADDED SOME LANGUAGE TO TREAT LOADS THAT WERE INCLUDED IN THE STUDY AREA FOR RBT PROJECTS AS HAVING FULL, FULLY COMPLETE AND VALID STUDIES, SO ADDED SOME RED LINES IN THERE. UM, AND THEN SECONDLY, WITHIN THAT SAME SECTION WE, WE ECHO SUPPORT THAT WE'VE HEARD FROM OTHERS ABOUT, UH, EXTENDING THE MARCH 4TH DEADLINE FOR RPG ACCEPTANCE OUT TO JULY 10TH AND RECOGNIZE KOTS GIVEN FEEDBACK ON THAT, BUT WE WANTED TO REITERATE SUPPORT FOR THAT. UH, 0.6. UM, ALSO HAVING A ME TOO, WE, WE SUPPORT COMMENTS FROM ENCORE AND CENTER POINT TO EXTEND THE AGREEMENT TIMELINE TO 60 DAYS RECOGNIZE WE'RE IN A CART DRIVING THE HORSE SITUATION. SO WE'RE, WE'RE GONNA BE MAKING THAT POINT, UH, IN OUR RULE MAKING COMMENTS ON 5 8, 4 8 1. AND THEN 0.7 IS SOMETHING MAYBE WE CAN GET SOME REAL TIME FEEDBACK ON. UH, SO OUR UNDERSTANDING IS THAT THERE COULD BE A SCENARIO WHERE A BASE LOAD WOULDN'T GET FULL SERVICE AND WOULD BE SHIFTED INTO, UH, THE ALLOCATION PORTION OF THE, THE STUDY. AND IF THAT'S TRUE, WE THINK THERE SHOULD BE SOME PRIORITIZATION TO, TO ALLOCATE BASE LOADS AHEAD OF ORIGINALLY, UH, SET ALLOCATED LOADS THAT THOSE BASE LOADS HAVE MET A HIGHER BAR AND IT JUST SEEMS TO MAKE, IT STANDS TO REASON THAT THEY SHOULD GET MAYBE SOME MORE PRIORITY IN THE ALLOCATION, UH, SCHEME. SO, UH, ARE, ARE, AM I THINKING ABOUT THAT THE RIGHT WAY, JEFF? AND, AND WHAT, WHAT'S YOUR INITIAL REACTION? YEAH, SO, UM, I THINK [04:25:01] RIGHT NOW THERE'S NO WAY TO DEEM A BASE LOAD UNSERVICEABLE. SO IF YOU'RE BASE LOAD YOUR BASE LOAD, OKAY, THERE'S NEVER A SITUATION WHERE THEY WOULDN'T GET THEIR CAPACITY, NOT IN THE BATCH STUDY. AND, UM, YOU KNOW, OP OPERATIONS FOLKS WOULD APPRECIATE IF I, YOU KNOW, PUT THE DISCLAIMER IF ANYTHING CAN HAPPEN IN REAL TIME. BUT, UM, BUT FROM A, A BATCH STUDY, FROM A PLANNING STUDY PERSPECTIVE, ONE, ONCE YOU WEAR A BASE LOAD, YOU ARE A BASE LOAD. GOTCHA. AND I DO WANNA MAKE SURE SANDEEP, THAT I COMMUNICATE, UH, YOUR CONCERN CORRECTLY OR DO YOU HAVE ANY FOLLOW UPS? YEAH, I THINK, UH, THE COMMENT WAS REFERRING TO, YOU REMEMBER THAT ONE SLIDE WHERE YOU HAD TRIANGLES MOVING FROM BLUE TO GREEN, SO THIS IS REFERRING TO THAT YEP. UH, SLIDE. YEP. AND SO IF I HEARD YOU RIGHT, YOU'RE SAYING THAT THAT'S NOT A CONCERN ANYMORE BECAUSE ALL OF IT'LL BE TREATED BASE LOAD. OKAY. YEAH, THANK THANKS FOR THAT CLARITY. SO, UM, IF, IF WE MOVE THE, UM, SO IF WE MOVE EVERYTHING TO SAY JULY 10TH AS THE CUTOFF, AND THEN WE ALLOCATE MORE LOAD COUNT MORE, NOT ALLOCATE, BUT MORE LOAD IS COUNTED AS BASE LOAD THAN WHAT THE SYSTEM CAN HANDLE, UM, THAT IS AN ISSUE THAT WE WILL DEAL WITH IN REAL TIME. UH, I, I THINK IS, UH, I, I DON'T SEE ANY, ANY OTHER WAY TO DO THAT OTHER THAN, UM, D DEAL WITH THAT IN REAL TIME. UM, UN UNLESS WE INTRODUCE A DIFFERENT CONSTRUCT THAT WOULD, UH, BUT, BUT AT, AT THAT POINT YOU'RE JUST REALLOCATING LOAD. UM, SO I, I THINK THAT I, I THINK THE CHOICE IS EITHER I, I THINK IT'S EITHER A, WHERE YOU JUST COUNT IT ALL AS BASE LOAD AND THEN YOU CURTAIL PEOPLE IN REAL TIME, UM, OR B IN WHICH, YOU KNOW, WE, WE ONLY LET BASE LOAD UP TO THE AMOUNTS THAT WE CAN RELIABLY SERVE. AND, AND YOU ARE SAYING WE'LL BE TAKING A, THE APPROACH A RIGHT NOW WHERE IT'LL BE ADJUSTED IN REAL TIME, WE'RE TAKING FIGURE 1 45 IS DRAFTED, IS APPROACH B, UM, UH, YOU KNOW, A LOT OF FOLKS HAVE SUBMITTED COMMENTS IN INCLUDING YOURSELVES ON THIS. UM, I, I THINK, UM, THIS IS SOMETHING THAT, UH, I, I TEED UP FOR THE COMMISSIONERS AT THE LAST OPEN MEETING AND THEY MAY OR MAY NOT GIVE US GUIDANCE ON THIS ON APRIL 17TH. SO I THINK WE'RE KIND OF WAITING TO SEE IF, IF THEY GIVE US ANY GUIDANCE ON THAT, UM, UN UNDERSTAND THAT THERE'S BEEN A LOT OF COMMENTS FROM STAKEHOLDERS ON THAT ISSUE. AND, AND SO, YOU KNOW, WE, WE'LL HAVE TO SEE IN THE LANGUAGE IN, IN THE PIGGER IS REFERRING TO, YOU'RE REFERRING TO THE ONE WHERE YOU LIST ALL THE LOADS THAT MEET CERTAIN CRITERIA AND YOU PRIORITIZE THEM BASED ON HOW AND WHEN THEY MEET THEIR CRITERIA, RIGHT? YEP. OKAY. GOT IT. YEAH. AND, AND IF I COULD JUST, I WANT TO ADDRESS A COUPLE OF YOUR OTHER POINTS, UM, IN, IN YOUR COMMENTS. SO I THINK POINTS ONE AND TWO, I I THINK WE ALSO WANNA ACKNOWLEDGE THAT WE SEE THAT GAP AND SO WE'RE, WE'RE LOOKING AT THAT. AND THEN, UM, 0.6, MATT, IF YOU COULD, UM, UH, YEAH, GO BACK TO THAT. SO, UM, THIS HAS COME UP SEVERAL TIMES. UM, I THINK OUR INTENTION RIGHT NOW IS AGAIN, UNLESS WE'RE, UM, COMMISSION GIVES US DIFFERENT GUIDANCE ON THE 17TH, IS THAT WE WILL RETAIN THE 30 DAYS THAT IS LISTED IN 58 41. HOWEVER, THE, UH, THIS LANGUAGE IS NOT CONSEQUENTIAL UNTIL EARLY 2027. UH, WE EXPECT 58 41 TO BE DONE FALL OF 2026. SO WE WILL, IF THAT CHANGES IN 58 41, WE WILL COME BACK AND FILE A PIGGER TO UPDATE THE LANGUAGE. SO IF THE COMMISSION FOLLOWS THIS RECOMMENDATION AND CHANGES IT TO 60 DAYS BEFORE THIS LANGUAGE IS CONSEQUENTIAL, WE WILL FILE A PIGGER TO UPDATE THAT. ALRIGHT, VERY GOOD. HAD A COUPLE COMMENTS COME IN DURING THE CONVERSATION HERE, SHANNON. MINE'S ACTUALLY RELATED TO THE PRIOR, UH, COMMENT OR PRIOR DISCUSSION, SO JUST REMOVE ME FROM THE QUEUE. SORRY ABOUT THAT. THANK YOU. ALRIGHT, SHANE, THANK YOU, SHANE, THOMAS, MICHELLE, UM, THAT KIND OF CONVERSATION GIVES, MAKES ME, UH, OR, UH, LOOK FOR, I GUESS FOR A CLARIFICATION. SO WHEN DOES A LOAD, WHEN IS LIKE A, A LOAD GONNA BE GUARANTEED AT ENERGIZATION LEVEL, IF YOU WILL? IS IT, SO IF YOU'RE COMING THROUGH THE BATCH STUDY, YOU GET A NUMBER 200 MEGAWATTS, YOU STILL HAVE TO GO THROUGH THE QSA PROCESS. UH, AND WITHIN THAT PROCESS, COULD YOU BE FURTHER [04:30:01] LIMITED OR ARE YOU GONNA BE, IF SOME SOMETHING'S FOUND OUT OR THAT YOU'D STILL BE CONSIDERED AT 200 MEGAWATTS, BUT THEN IN REAL TIME THERE MIGHT BE A, THAT MIGHT TRIGGER A GTC AND THEY WOULD LOWER YOU DOWN, BUT YOU WOULD TECHNICALLY SILK IT 200 MEGAWATTS? YEAH, SO THE, THE, THE QSA ESTABLISHES GTCS, IT DOES NOT ESTABLISH, DOES NOT, YOU KNOW, CREATE A DIFFERENT, YOU CAN ONLY ENERGIZE AT, AT LEAST AS THE QSA IS CONSTRUCTED TODAY, DOES NOT SAY, HEY, WE, WE TOLD YOU 200 BEFORE, YOU'RE ONLY ALLOWED TO ENERGIZE 100. THAT, THAT, THAT'S NOT WITHIN HOW THE QSA WORKS, UNLESS FRED WANTS TO CORRECT ME ON THAT. UM, UH, YEAH, BUT IF WE, UH, ALLOW MORE LOAD TO BE CONSIDERED BASE LOAD THAN WHAT THE SYSTEM CAN RELIABLY HANDLE, THEN YEAH, THERE IS THAT RISK IN REAL TIME AND IT, IT'S A, YOU KNOW, SIMILAR RISK TO, YOU KNOW, I I, YOU KNOW, GO TO THE EXTREME EXAMPLE OF A TORNADO KNOCK DOWN THE TRANSMISSION LINE OUTSIDE YOUR FACILITY AND IT'S, YOU KNOW, TSP CAN'T REBUILD IT FOR THREE MONTHS. WELL, FOR THREE MONTHS YOU MAY BE, UH, CURTAILED OR LOAD SHED IS, IS HOW THE, YOU KNOW, THE, THE CONTROL ROOM WOULD LOOK AT THAT. I, I THINK THE, WHAT WE'VE TRIED TO COMMUNICATE, UM, WITH, WITH, AT, AT THE LAST WORKSHOP IS THAT, UM, YOU KNOW, ANYTHING CAN HAPPEN IN REAL TIME, BUT YOU KNOW, I I THINK OUR PREFERENCE, HOW WE HAVE CONSTRUCTED 1 45 IS WE DON'T WANT TO KNOWINGLY ALLOW MORE LOAD TO CONNECT TO THE SYSTEM THAN WHAT THE SYSTEM CAN RELIABLY HANDLE. AND, AND SO IF YOU MOVE THAT MARCH 4TH DATE, YOU'RE KIND OF, YOU'RE DOING THAT IS YOU'RE KNOWINGLY ALLOWING MORE LOAD ONTO THE SYSTEM THAN WHAT THE SYSTEM CAN RELIABLY SERVE. AND, AND SO THEN WE ARE KNOWINGLY GOING TO HAVE LOAD SHED IN REAL TIME. AND SO YOU, YOU MAY HAVE 200 MEGAWATTS, BUT IT MAY BE EVERY DAY YOU'RE ROTATING THAT YOU'RE, YOU'RE HAVING TO ROTATE THAT LOAD EVERY DAY IF YOU MOVE THAT MARCH 4TH DATE TO SOMETHING ELSE. OKAY, THAT MAKES SENSE THAT, YEAH, THE QSA IS NOT DESIGNED TO GIVE A RESULT OF A NEW LIMIT, I GUESS, FOR SPECIFIC LOAD. UM, YEP. YEAH. SO ON IN THE SAME, THAT SAME VEIN, IF YOU SAY, YOU KNOW, IN 2029 YOU COULD NOW GET, UH, 700 MEGAWATTS, YOU KNOW, BUT THAT LINE IS DELAYED OR WHATEVER HAPPENS, THEY WOULD TECHNICALLY STILL GET THEIR LIMIT ADJUSTED, BUT THERE WOULD POTENTIALLY BE A REALTIME DIFFERENCE. YEAH, I THINK WE'RE, UM, AGAIN, AS AS WRITTEN, IT WOULD BE, IF WE TOLD YOU 700 IN 2029, THEN WE WOULD ALLOW YOU TO CONNECT THAT. UM, BUT YEAH, IF THE TRANSMISSION PROJECT GOT DELAYED, THEN, THEN THERE IS RISK UNTIL THAT TRANSMISSION PROJECT GOT COMPLETED. THANK YOU. YEP. ALL RIGHT, BLAKE, AND THEN BROTH. BLAKE, WE CAN'T HEAR YOU. ALL RIGHT, WE'LL COME BACK TO YOU IN A SECOND BROTH. SO ONE OF THE POSSIBLE OUTCOMES OF THE QSA WAS IF IN ESPECIALLY WHEN UC WAS EXPLAINING ABOUT IN THE INTERIM RIDE THROUGH ASSESSMENT, THAT THE, THE LOAD MAY BE ASKED TO CURTAIL OR WAIT TILL A CERTAIN ELEMENT IS FIXED. I JUST WANTED TO MAKE SURE THAT THE OUTCOME OF QSA IS THE LOAD WILL NOT BE ASKED TO CURTAIL FOR ANY EVENT. CORRECT? UH, THIS FREIGHT FROM AMERICA CAR, I START TO SEE A PATENT WHEN TALK PEOPLE TALK ABOUT QSA, THEY ULTIMATELY TURN THEIR HEAD TO ME. SO I'M NOT SURE WHY , UM, I, I WOULD TRY TO KIND OF TRY TO CLARIFY, BUT OTHERS PLEASE HELP, UH, TO WEIGH IN THE QSA, AND I'LL JUST USE THE EXAMPLE, THE PAGE ZERO OUTCOME IS 200 MEGAWATT MM-HMM . THEN WE WILL STUDY A 200 MEGAWATT IN THE QSA, WE WILL ASSESS IF THAT THE HUNDRED, THAT THE ENTIRE 200 MEGAWATT IN THE CASE FOR THE REGION THEY CONNECT TO DO, DO WE IDENTIFY ANY STABILITY CONSTRAINT OR NOT. IF WE DO, THEN WE CERTAINLY NEED TO DEVELOP A MEDICATION PLAN SUCH AS POTENTIAL GTC AS NEEDED. BUT FOR THE 200 MEGAWATT, WE WILL STILL BE ALLOWED TO MOVE FORWARD TO BE ELIGIBLE FOR THE NEXT STEP, WHICH LIKELY IS THE INITIAL ENERGIZATION. SO COME TO REAL TIME, IF THE CONSTRAINT [04:35:01] WE DO SEE THE NEED, WE'LL DEVELOP AND IMPLEMENT IT UNLESS IT IS TRIGGER OTHERWISE, THE ENTIRE 200 MEGAWATT SHOULD BE SERVED AS A NORMAL CONDITION. SO I WAS REFERRING TO THE MITIGATION PLAN, ESSENTIALLY. SO THEN IN REAL TIME, IF IT TRIGGERS, YOU WILL IMPLEMENT THE MEDICATION PLAN AND THE RESULT OF THE MITIGATION PLAN MAY BE THAT THE LOAD MAY HAVE TO CURTAIL, I WOULD SAY LAB PROBABLY BASED ON THE CONDITIONS, AND I TRY NOT TO MIX THE, THIS MORNINGS DISCUSSION. NO. IF THEY ARE FLEXIBLE LOAD IN OTHER AREA, YEAH, NO, THEN SCHEDULE LIKELY WILL ACTIVATE IT. IF THEY ARE NOT, THERE ARE OTHER WAYS TO MANAGE THE CONSTRAINTS. OKAY, THANKS. ALL RIGHT. SO GO BACK TO BLAKE THEN, IAN, AND THEN KEVIN. GO AHEAD. BLAKE, CAN YOU HEAR ME? YES, THAT WORKS. OH, PERFECT. I, I WANTED TO JUST PROVIDE AN A COMMENT ON SHANE THOMAS'S QUESTION ABOUT THE CERTAINTY. SO I THINK, I THINK THE ANSWER IS PRE PRE IGAR ONE 15 WHEN IT WAS THE INTERIM PROCESS, IT WAS A COMBINATION OF THE STUDIES BEING COMPLETE AND APPROVED AND ASSIGNED INTERCONNECTION AGREEMENT. HOWEVER, THE WORD APPROVAL TO ENERGIZE HAS TAKEN ON A SORT OF A SORT OF LIFE OF ITS OWN AND SEEMS TO BE THE, THE, THE RIGHT GOALPOST FOR ENERGIZATION. UH, AND, AND I AGREE WITH WHAT TTA IS CHARACTERIZED, WHICH IS THAT YOU'RE, YOU'RE NOT SUPPOSED TO FACE ANY SORT OF LOSS OF KIND OF AWARDED CAPACITY BY THE APPROVAL TO ENERGIZATION, UM, EXCEPT FOR, YOU KNOW, THEY CAN IDENTIFY SYSTEM OPERATING LIMITS. BUT I WILL SAY THAT THE, THE WORD APPROVAL TO ENERGIZE HAS SORT OF BEEN A NEW TERM DEFINED IN PICKER ONE 15 THAT HAS REDUCED CERTAINTY AROUND WHAT USED TO BE CONSIDERED YOUR FIRM AWARDED CAPACITY. JUST WANTED TO LIKE, ADD THAT COLOR FROM MY PERSPECTIVE. ALL RIGHT, THANKS BLAKE. ALL RIGHT, IAN, THEN KEVIN, JEFF HAD A, UM, CLARIFYING QUESTION IN YOUR CONVERSATION WITH SHANE, WHEN YOU'RE SAYING, UH, RUN OUT CAPACITY, ARE YOU SAYING IN THE LOCAL TRANSMISSION SYSTEM OR IN THE GRID AS A WHOLE? UM, I, I THINK I WAS TALKING ABOUT THE LOCAL TRANSMISSION CAPACITY. OKAY. I WAS WONDERING IF YOU GOT, IF YOU WERE TRYING TO EXPLAIN THAT YOU HAD PICKED THAT DATE BECAUSE IT LINED UP, WHICH WITH, UH, RESOURCE ADEQUACY IN, IN LIKE SIX NINE. OKAY. THANK YOU. APPRECIATE THAT. ALRIGHT, KEVIN? YEAH, QUICK QUESTION. IF YOU ARE ASSIGNED A RAMPED LOAD, LET'S SAY A HUNDRED MEGAWATTS, 300 MEGAWATTS, 500 MEGAWATTS FOR EACH INCREMENT, DO YOU HAVE TO GO THROUGH A QSA OR IS ONE QSA AT THE FRONT APPROVED IN ALL THREE OF THOSE RAMPS? UM, SO THE, IF, IF THAT RAMP SCHEDULE WAS PROVIDED AND THERE WERE NO TRANSMISSION UPGRADES UNDER THE CURRENT PROCESS, THERE WERE NO TRANSMISSION UPGRADES THAT WOULD NEED TO BE IN PLACE BEFORE THAT NEXT LEVEL OF DEMAND COULD OCCUR, THEN THERE IS NO REQUIREMENT TO GO THROUGH SUBSEQUENT QSAS. THE QSA WILL REPRESENT THAT RAMP SCHEDULE IN, IN THOSE QSAS, BUT THE LOAD DOES NOT HAVE TO COME BACK. IF THERE IS A, UM, UPGRADE THAT NEEDS TO BE IN PLACE FIRST, THEN THAT'S A NEW APPROVAL TO ENERGIZE, UH, FOR THAT NEXT HIGHER LEVEL OF DEMAND. UM, I'M GONNA DO JUST WHAT FRED CALLED US OUT FOR , UH, UH, FRED, UM, FOR THE QSA, DID, DID THEY HAVE TO GO BACK THROUGH THE QSA IN, IN THAT ONE? I DON'T BELIEVE SO. IT'S JUST A NEW APPROVAL TO ENERGIZE REQUEST. LET'S GIVE IT TAKE IT IS ONE BID OR GIVE IT TWO TODAY. OKAY. ALRIGHT. YEAH, SO WE'LL, WE'LL CLARIFY THAT AND, UH, AND COME BACK. SO YOU MAY BE APPROVED LATE FOR A HUNDRED AND THEN THERE HAS TO BE AN RRP G PROJECT TO GET YOU TO THE 300 500 AND THAT'D BE SEPARATE. QSAS, ALSO . OKAY. THANKS. ALL RIGHT, THANK Y'ALL. ALL RIGHT. SO WE HAVE THREE SETS OF COMMENTS LEFT. SO ENCORE, HARSH. YEAH, SO THIS FRONT OF COMMENTS BY ENCORE FOCUSED ON ADDRESSING ONE ISSUE AND THAT'S HOW LARGE LOADS ARE TREATED IN THE, UH, BAT STUDY AND SPECIFICALLY THE LARGE LOADS THAT WERE PART OF AN RPG SUBMITTAL. SO THE CURRENT LANGUAGE STATES THAT IF AN RPG WAS APPROVED AND ENDORSED BY MARCH 4TH, UH, THEN THOSE LOADS BECOME PART OF THE BASE LOAD IN THE STUDY AND THERE IS NO FURTHER VALIDATION ON THOSE LOADS. SO THE RECOMMENDATION ON COURSE MAKING IT TO IS TO CHANGE THE LANGUAGE SUCH THAT IF AN RPG WAS SUBMITTED BEFORE DECEMBER 15TH AND APPROVED BY [04:40:01] JULY 15TH, THEN THOSE PROJECTS, UH, BECOME BASE LOAD WITHOUT ANY FURTHER VALIDATION. WE ALREADY TALKED ABOUT WHAT IT TAKES TO PUT TOGETHER AN RPG. THE RPGS WE ENCORE HAS FILED OVER THE LAST SEVERAL YEARS. UM, THEY WERE FILING IN ACCORDANCE WITH THE PROCESSES THAT WERE APPLICABLE AT THE TIME, SPECIFICALLY THE INTERIM MARKET NOTICE. AND IT REQUIRED A SIGNIFICANT AMOUNT OF WORK BY THE TSP LARGE LOADS. EVEN ERCOT, ERCOT HAS SPENT OVER A YEAR IN ONE INSTANCE COMPLETING THAT EIR. SO THOSE ARE THE REASONS WE HAVE FOR THAT RECOMMENDATION THAT WE ERCOT SINCE THROUGH EIR HAS ALREADY COMPLETED THE VALIDATION. THEY BECAME LARGE LOADS. IF ERCOT CHOOSES TO NOT ADOPT THIS RECOMMENDATION, THEN OUR ASK THEN WOULD BE WHEN YOU, SO THEN THERE'S A PATH THAT THE STUDY MAY STILL BECOME VALID WHEN YOU GO THROUGH THE VALIDATION REVIEW PROCESS. OUR ASK THEN WOULD BE TO USE THE SUBMISSION DATE AS YOU RANK THE RPGS AND, UM, AND THAT THAT IS IN, UM, 9 2 1 4, PARAGRAPH FOUR B. YOU ALREADY TALK ABOUT RANKING RPGS ANDIS. OUR RECOMMENDATION THEN WOULD BE TO USE THE R PG SUBMISSION DATE BECAUSE THAT IS THE DATE. THE TSP CONTROLS ER CT REVIEW TIMELINE THAT OFTENTIMES TAKES WAY BEYOND HUNDRED 50 DAYS OF EIR. THEY'RE NOT IN, UH, TSP CONTROL, SO OUR ASK WOULD BE TO USE THE SUBMISSION DATE. AND THAT'S ALL I HAVE. THANKS. ALRIGHT, ANY QUESTIONS OR COMMENTS FOR HARSH? ALRIGHT, ON TO CENTER POINT. THANKS MATT. UH, JIM LEE HERE WITH CENTER POINT ENERGY. UM, FIRST APPRECIATE THE OPPORTUNITY TO PROVIDE THESE, UH, FOLLOW UP COMMENTS, UM, APPRECIATE IT OR GOT PUTTING TOGETHER THAT THE MATRIX OF, UH, ALL THE, ALL THE COMMENTS THAT Y'ALL RECEIVED AND, UM, KIND OF SIFTED THROUGH. SO THAT WAS REALLY HELPFUL. UM, THERE ARE, UH, OUR COMMENTS THIS TIME KIND OF STILL REVOLVE AROUND ISSUES AND TOPICS THAT WE FEEL LIKE ARE STILL CRITICALLY IMPORTANT TO THE SUCCESS OF BATCH ZERO. UM, AND, AND I KNOW THAT THERE ARE A LOT OF, UH, MOVING PIECES AS FAR AS 5 8, 4 8 1 AT THE OPEN AT THE COMMISSION AND THINGS HAPPENING AT, UM, ON, ON THE 17TH HERE. SO STARTING OFF ON THE TOP, UM, WE, WE MAINTAIN OUR POSITION THAT, YOU KNOW, FINANCIAL SECURITY AND REFUND LANGUAGE REALLY DOES NOT BELONG IN THE PLANNING GUIDE. RIGHT. PLANNING GUIDE SHOULD DESCRIBE THE MECHANICS OF THE BATCH STUDY PROCESS ONLY, UM, AND REFERENCES TO HOW A-T-D-S-P NEEDS TO HANDLE THE FINANCIAL SECURITIES AND REFUNDS DON'T BELONG AT PAYROLL 1 45. AND SO, UM, WE APPRECIATE CHRISTINA'S COMMENTS EARLIER, UM, THAT 9 7 2 9 7 1 COULD CHANGE, UM, BASED ON GUIDANCE AT THE FOUR 17 OPEN MEETING. HOWEVER, WE FELT THAT IT WAS STILL APPROPRIATE TO REITERATE OUR CONCERNS. UM, THAT, YOU KNOW, THESE, THE SECTIONS THAT WE'VE LISTED HERE ARE, ARE ALL KIND OF, THEY HAVE REFUND LANGUAGE, HOW WE'RE SUPPOSED TO DRAW DOWN ON SECURITY AND THINGS LIKE THAT AND, UH, FULLY EXPECT THAT TO CHANGE. SO BECAUSE THERE MAY BE A GAP, UM, STILL POTENTIALLY BETWEEN WHEN PGA 1 45 GETS APPROVED AND WHEN 5 8 4 0 1 LANGUAGE MAY BE DECIDED, EVEN, YOU KNOW, I THINK IT WAS POINTED OUT THAT THE FOUR 17 OPEN MEETING MAY OR MAY NOT GIVE CLEAR GUIDANCE. SO IN THE EVENT THAT IT DOESN'T, AND THESE SECTIONS STAY IN THERE, THEY PROVIDE A, A, A HUGE PROBLEM, UM, WHERE A PLANNING GUY DICTATES HOW, UH, UTILITIES ARE SUPPOSED TO OPERATE AND DO A FINANCIAL SECURITY AND REFUNDS AND DRAW DOWNS. UM, AND SO THEN WE ALSO HEARD AT, AT LAST FEW WORKSHOPS, PARKSDALE ADVISED THAT IF ENTITIES DO HAVE, UH, CONCERNS ON, ON THIS PIECE TO FILE THOSE IN PARALLEL COMMENTS OF 5 8 4 8 1. AND, UH, CENTER POINT WILL BE FILING THOSE, UM, FOR, FOR THE 17TH DISCUSSION AT THE COMMISSION. OKAY. UM, MOVING ON, UH, EQUIPMENT PROCUREMENT LANGUAGE ALSO IN OUR ESTIMATION DOES NOT BELONG IN THE PLANNING GUIDE. AGAIN, WE RECOGNIZE THAT THIS WAS FORKLIFTED FROM 5 8 4 8 1. UM, BUT SOMETIMES FORKLIFTING AN ENTIRE RULE INTO A PLANNING GUIDE, UH, DOESN'T ALWAYS MAKE THE MOST SENSE. AND SO THE REMARKS ABOUT FINANCIAL SECURITY REFUNDS SIMILAR TO THAT. UM, AND THEN WHILE NOT REFERENCED HERE, I THINK THAT ERCOT SHOULD BE AWARE THAT 25 59, UM, LONG LEAD TIME EQUIPMENT WAS APPROVED IN 2025. AND THAT DOES HAVE LANGUAGE GUIDING, UM, TSPS ON, UM, PROCURING [04:45:01] EQUIPMENT LONG LEAD TIME EQUIPMENT. AND THE WAY THAT 9 7 1 1 AND 9 7 2 1 ARE WRITTEN, IT, IT SAYS THAT INTERCONNECTING TSP MUST NOT MAKE, MUST NOT PROCURE EQUIPMENT OR SERVICES BEFORE. UM, THAT THAT JUST DOES NOT COMPORT WITH 25 59. UM, IF THIS PARAGRAPH MUST STAY, UM, CENTERPOINT RECOMMENDS THAT WE CHANGE THAT FROM WHAT'S NOT TO A MAY, AND THAT KIND OF JUST OPENS IT BACK UP TO ALIGNING BACK WITH CURRENT LANGUAGE. UM, DON'T SEE PLANNING GUIDES TELLING US HOW WE MUST OR WHAT'S NOT PROCURE EQUIPMENT. UM, AND SO THAT, UM, IS THERE, IF, IF IT'S DECIDED THAT THIS PARAGRAPH OR THIS CONCEPT CAN BE STRUCK, UM, I THINK CENTERPOINT WOULD BE HAPPY TO SEE THAT AS WELL. MOVING ON, UM, FINANCIAL SECURITY POSTING TIMELINES. THERE'S A THEME HERE. FINANCIAL SECURITY, FINANCIAL SECURITY. UM, SO WE HAVE NOTICED, UM, OR IN OUR CONVERSATIONS WITH OUR CUSTOMERS, UM, THAT THERE IS A POTENTIAL, UM, THAT THE TIMINGS OF RELEASING FUNDS IS A HIGHLY COORDINATED EFFORT BETWEEN THE ILE AND THEIR FINANCIAL INSTITUTION, RIGHT? AND SO SECURITY MAY OR MAY NOT BE ISSUED AT THE TIME OF AN AGREEMENT EXECUTION WITH THE TDSP. SO IN ALL THOSE SECTIONS THAT WE'VE LISTED HERE, 9 7 1 1 I 9 7 2 IH, THERE ARE SENTENCES THAT SAY FINANCIAL SECURITY IS DUE AT THE TIME THE AGREEMENT IS EXECUTED WELL, THAT THAT INTRODUCES A TIMING ISSUE. A TIMING PROBLEM. SAME THING WITH 9 7 2 IH ONE H THERE, UM, YOU KNOW, MUST POST FINANCIAL SECURITY, NO LAYER THEN THE DATE THAT INTERCONNECTION AGREEMENT IS EXECUTED. THOSE ARE, THOSE ARE HARD THINGS TO, UM, TO MEET. AND THEN, YOU KNOW, FURTHER ON IN 9 7 2, ALSO JUST SAYING THAT IF THE TDSP REQUIRES ADDITIONAL FINANCIAL SECURITY, BECAUSE NOW WITH THE INTRODUCTION OF 5 8 4 A ONE LANGUAGE, YOU HAVE MULTIPLE FORMS OF FINANCIAL SECURITY INTENDED TO PERHAPS COVER SIMILAR ITEMS. BUT THOSE MECHANISMS ARE BEING CONFLATED. AND IF WE'RE COLLECTING FINANCIAL SECURITY, IT'S FOR LONG LEAD TIME EQUIPMENT, RIGHT? KAYAK IS COLLECTED FOR DRIVEWAY COSTS. SO, UM, ADDING IF THE TSP REQUIRES FINANCIAL SECURITY, JUST IT, IT'S ADDITIONAL CLARIFICATION THAT WE MAY NOT COLLECT IT IF IT'S WE'VE ALREADY SATISFIED ALL OF THE SECURITY REQUIREMENTS. UM, AND THEN KIND OF THE SAME IDEA FOR WHEN KAYAK IS PAID. AND SO I WON'T GO INTO THAT, BUT, UM, I'LL MOVE INTO THE NEXT SECTION. 9 2 1 2 FOR ELIGIBILITY CRITERIA. UM, THIS MAY HAVE BEEN OVERLOOKED. UM, THE REASON I I SAY THAT IS BECAUSE I, I THINK WE BROUGHT IT UP AT WORKSHOP FIVE TO WHERE IN THE SECTION 9 2 1 2 1 BI, UM, ERCOT DID, UM, ACCEPT THE, THE, OUR, OUR RECOMMENDED CHANGE TO REMOVE THE JANUARY 1ST DATE. BUT THEN THERE'S ALSO A SCENARIO POTENTIALLY, AND, AND MAYBE JEFF CAN HELP ME CLARIFY THIS, BUT, UM, YOU KNOW, A SITUATION WHERE A CUSTOMER HAS ALL INTENTIONS OF GOING INTO BASE LOAD, UH, BATCH ZERO BASE LOAD, RIGHT? AND SO THE REQUIREMENTS FOR BATCH ZERO BASE LOAD ARE THAT YOU HAVE TO ENTER INTO AN INTERCONNECTION AGREEMENT, RIGHT? SO WHAT HAPPENS WHEN, OR IF THAT ENTITY THINKS THAT THEY'RE GONNA BE INTO BASE LOAD FOR SOME REASON OR ANOTHER, GET BUMPED TO ALLOCATORS STUDIED? WELL, THE CURRENT PARAGRAPH RIGHT NOW JUST SAYS THAT THEY HAVE TO MEET 9 7 1 INTERMEDIATE, BUT IN THIS CASE, THEY'VE ALREADY EXECUTED 9 7 2 AND THAT 9 7 2 THRESHOLD IS HIGHER. AND SO THEREFORE THINKING THAT A 9 7 2 IN THIS INSTANCE SHOULD ALSO SATISFY FOR WHEN A 9 7 1 IS SUFFICIENT. IS THAT SO? YEAH. SO ON ON THAT, UM, WE, UM, STARTED WRITING LANGUAGE, UM, AND, AND JUST DIDN'T, DIDN'T GET IT DONE IN TIME. UM, AND SO WE END UP BACKING IT OUT OF OUR FOUR, FOUR COMMENTS, BUT WE, WE STARTED GOING DOWN A, UH, PATH THAT HAD A CONCEPT OF, UM, UH, THE, UM, SO LOADS, UH, GOING INTO, UH, JULY 10TH THAT THEY WOULD ONLY NEED TO MEET THE INTERMEDIATE AGREEMENT. [04:50:01] UM, AND THEN WE WOULD THEN, UM, UH, SO, SO JULY 10TH, YOU, YOU, UH, YOU, YOU, YOU KNOW THAT THAT'S KINDA THE CUTOFF FOR EVERYTHING. JULY 24TH, TSPS TELL US, OKAY, HERE, HERE'S EVERYBODY THAT HAS MET THESE REQUIREMENTS. WE THINK, UM, AND THEN AUGUST, UM, CAN'T REMEMBER DAY SEVENTH, UH, IS WHEN ERCOT TELLS PEOPLE, UH, WHAT, UM, OR TELLS TSPS WHAT WE THINK, OKAY, BASED ON ALL THIS, YOU KNOW, HERE'S, HERE'S THE ONES THAT ARE BASE LOAD AND HERE'S THE ONES THAT ARE STUDIED LOAD. UM, THE CONCEPT THAT WE WERE, UM, KICKING AROUND WAS, UM, SO, SO YOU WOULD ONLY HAVE TO MEET THE INTERMEDIATE AGREEMENT REQUIREMENTS, BUT THEN IF ON AUGUST 7TH WE TELL YOU THAT, UM, THAT THAT LOAD IS A BASE LOAD, UM, THEN, UH, OR IS ELIGIBLE TO BE BASE LOAD, THEN YOU WOULD HAVE, YOU KNOW, MAYBE TWO WEEKS TO, UH, UH, BUMP YOUR INTERMEDIATE AGREEMENT UP TO AN INTERCONNECTION AGREEMENT. I KNOW IT'S A FAST TURNAROUND, BUT YOU KNOW, WE NEED THAT TO, TO GO INTO THE STUDY. UM, AND, AND SO THAT WE WERE THINKING THAT MAY ADDRESS THAT ISSUE. SO I THINK WE RECOGNIZE THAT. UM, BUT WE WERE THINKING ABOUT THAT SLIGHTLY DIFFERENT WAY TO ADDRESS THAT. BUT WE, I THINK WE DIDN'T, I WOULD JUST SAY THAT THAT'S CONCEPTUAL IDEA THAT WE'RE THINKING OF RIGHT NOW. UM, AND YOU KNOW, AGAIN, DIDN'T GET THAT FLESHED OUT ENOUGH TO PUT THAT IN IN THE, UM, FOUR, FOUR COMMENTS. OKAY. AND THAT, AND THAT'S FAIR. AND, AND ON YOUR, UM, PIECE ABOUT, UH, FLIPPING FROM AN INTERMEDIATE TO INTERCONNECTION IN TWO WEEKS, I CAN TELL YOU RIGHT NOW THAT'S, UM, THAT'S GONNA BE A, I I, I'LL GET TO THAT IN A SECOND. UM, SECOND. , YOU SECONDED ME, NED, MY, MY BABBLING. OKAY. UM, SO YEAH, SO I, I THINK, I THINK A LOT OF TIMES WHAT WE, WHAT CENTERPOINT IS TRYING TO AVOID HERE IS HAVING, NOT KNOWING WHICH AGREEMENTS WILL QUALIFY CUSTOMERS INTO WHICH PARTS OF BATCH. AND RIGHT NOW THERE ARE, YOU KNOW, IF THEY ENTER INTERMEDIATE, THERE'S, THERE'S ONE SET OF, IT'S AN AGREEMENT, UM, BUT THEN ONCE YOU GO TO INTERCONNECTION, THEN YOU START TO HAVE ALL THE NON-REFUNDABLE INTERCONNECTION FEE AND STUFF LIKE THAT. AND SO THERE'S TWO VERY DIFFERENT THRESHOLDS, UM, FOR THAT. AND, UM, WHAT WE'RE TRYING TO AVOID IS GOING TO THESE, TO OUR CUSTOMERS AND SAYING, I NEED YOU TO SIGN BOTH BECAUSE WE DON'T KNOW WHICH ONE ERCOT IS GONNA ACCEPT TO ALLOW YOU INTO WHICH, WHICH PORTION OF BATCH. SO BOTH OF THOSE HAVE 50 50 KA MEGAWATT REQUIREMENTS, AND RIGHT NOW IF YOU'RE TAKING A GIG PROJECT, YOU'RE ASKING THEM TO GIVE ME LETTER OF CREDITS FOR BOTH AN INTERMEDIATE AND AN INTERCONNECTION THE WAY IT'S WRITTEN RIGHT NOW. SO WE'RE TRYING TO AVOID THAT. OKAY. UM, DYNAMIC MODEL IMPACTS. SO THIS ONE, UH, WE, WE, WE, WE'VE BEEN TRYING TO GO BACK AND FORTH. THIS HAS BEEN A, UH, LONGSTANDING ISSUE FOR THOSE THAT HAVE BEEN PLUGGED INTO DWG. UM, BUT IN THOSE TWO SECTIONS LISTED 2 1 4, 1, UH, 9 2 1 4, AND 9 2 2, ERCOT HAD MADE THE EDIT TO HAVE THE TDSP, INTERCONNECTING TDSP DETERMINE, UM, IF ANY NEW DYNAMIC MODEL DATA HAS ADVERSE IMPACTS, RIGHT? UM, WE, WE STILL BELIEVE THAT ERCOT IS THE BEST SITUATED TO MAKE THAT FINAL DETERMINATION WHILE THE T DSPS UNDERSTAND STILL, AND, UM, HARSH, IF THIS IS NOT A COMMON UNDERSTANDING, YOU CAN KICK ME UNDER THE TABLE, BUT THE, UM, T DSPS WOULD, WOULD STILL BE ABLE AND WILLING TO PERFORM THE STABILITY STUDY. IT'S JUST THAT THE FINAL DETERMINATION OF ADVERSE IMPACTS SHOULD STILL RESIDE WITH ERCOT, RIGHT? THEY HAVE THE, THEY HAVE THE VIEW OF THE, THE, THE HOLISTIC VIEW OF THE SYSTEM NEEDS. UM, AND THIS IS VERY SIMILAR TO THE RBG DECISIONS ON TRANSMISSION UPGRADES, RIGHT? WHERE ERCOT IS THE BEST SITUATED KIND OF TO MAKE THOSE DETERMINATIONS. SO WE WANTED TO REVERT THE LANGUAGE BACK TO BASICALLY COLLABORATIVE, YOU KNOW, TSPS DSPS, WE CAN RUN THE STABILITY STUDY, UM, BUT HAND OVER THOSE RESULTS TO ERCOT TO MAKE A DETERMINATION, I THINK HARSH. YEAH, AND JUST TO ADD, IF ERCOT DOES NOT DO THIS, YOU WILL HAVE TSPS, THEY'LL BE VERY LENIENT AND WILL ALLOW ANY LOAD AND I'LL SAY, DOES IT HAVE ANY ADVERSE IMPACT? AND THEN YOU WILL HAVE ON THE OTHER SIDE HAVE TSPS, THEY'LL BE SUPER CONSERVATIVE THAT WILL NOT ALLOW ANY LOADS TO GO THROUGH. SO I THINK IT'S ER CUTTS IN THE BEST POSITION TO HAVE A CRITERIA AND, AND CAN EVALUATE EVERYBODY ON THE SAME SCALE. YEAH. YEAH. [04:55:01] MAYBE I'LL RESPOND QUICK IN, IN, IN LATE. SO I'M, I APOLOGIZE, I MIGHT BE KIND OF BLUNT HERE, BUT I, I DON'T UNDERSTAND THIS COMMENT BECAUSE, UM, I, I THINK FOR ONGOING BATCH, I, I THINK THAT IS CORRECT, BUT FOR THESE STUDIES, YOU ALREADY HAVE THIS OBLIGATION TODAY. SO YOU HAVE ALREADY, THE TSP HAS PERFORMED THE STABILITY STUDY. YOU ALREADY HAVE THE OBLIGATION TODAY THAT IF, UH, AND I DON'T REMEMBER WHICH SECTION 9 9 2 SOMETHING WHERE IF THE DYNAMIC MODEL CHANGES, YOU HAVE TO MAKE THAT DETERMINATION BECAUSE YOU DID THE STABILITY STUDY. SO FOR BATCH ZERO, YOU WILL HAVE DONE THOSE STABILITY STUDIES ALREADY FOR, FOR LOADS THAT ARE GETTING IN. UM, SO YOU ALREADY HAVE THIS OBLIGATION THAT I DON'T KNOW WHAT IS DIFFERENT ABOUT BATCH ZERO THEN WHAT, BECAUSE YOU, YOU'VE ALREADY STUDIED IT, RIGHT? IT'S THE CONSISTENCY THOUGH, RIGHT? A-A-T-S-P MAY TAKE THE TWO SAME MODELS, COMPARE ONE WAY AND SAY THERE IS NO ADVERSE IMPACT. ANOTHER TSP MAY COME UP WITH A DIFFERENT ANSWER. THAT'S THE KEY DIFFERENCE WE'RE TALKING ABOUT. BUT YOU, WE ALREADY HAVE THAT PROBLEM TODAY, CORRECT. AND TRYING ADDRESS THAT. OKAY. OKAY. YEAH. AND WE JUST THINK IT'S A GOOD POLICY FOR THERE TO JUST BE A SINGLE ENTITY MAKING THAT FINAL DETERMINATION, RIGHT? LIKE TO HARGET'S POINT, IT'S UNDEFINED, UM, ADVERSE IMPACT IS, IS UNDEFINED AND EVEN WITHIN A UTILITY THERE MIGHT BE DIFFERENT DEFINITIONS OF ADVERSE IMPACT. SO IT'S JUST, I, I THINK HAVING THE, THE, THE FLOW STILL. AND THEN IN, IN 9, 2, 3, PARAGRAPH TWO, THIS WAS NEWLY ADDED LANGUAGE FROM ERCOT COMMENTS, AND IT SAYS, UPON SESSION NOTIFICATION, THE ILE SHOULD PROVIDE THE INTERCONNECTING DSP UPDATED DYNAMIC AUDIT DATA REFLECTING THE CHANGE AND THE INTERCONNECTING D-S-P-T-S-P SHALL PROMPTLY PROVIDE THE DI UPDATED DYNAMIC DATA TO ERCOT. AND SO THAT, THAT WAS LANGUAGE I ADDED INTO 9 2 3 2 SPECIFICALLY ABOUT DYNAMIC. SO I, I JUST THOUGHT THAT, THAT THAT WAS JUST A, A DOVETAIL INTO, INTO THAT LIKE, SO I MIGHT HAVE INTERPRETED THAT A LITTLE BIT TO MY BENEFIT, BUT YEAH. OKAY. HEY JIM, JUST AS YOU GET READY TO PIVOT TO THE NEXT TOPIC, UM, THERE'S A QUICK QUESTION FROM BLAKE KING AND HE HAS TO HOP OFF. BLAKE, DID YOU WANNA ASK YOUR QUESTION TO JIM? YES, YES. THANK, THANK YOU, MATT. I APPRECIATE IT. HEY, HEY JIM, I APPRECIATE YOUR COMMENTS. I, I HAVE A QUESTION. THE, YOU KNOW, WITH THE IDEA THAT THE, UH, THAT EXISTING LOADS THAT ARE TRYING TO QUALIFY AS BASE LOAD WOULD NEED TO AMEND THEIR INTERCONNECTION AGREEMENTS TO SATISFY THE 9 7 2 IN, IN, IN OUR EXPERIENCE, AND FROM WHAT I'VE HEARD FROM THE INDUSTRY, SOMETIMES IT CAN TAKE THREE TO FOUR MONTHS FOR A UTILITY TO EVEN PROVIDE AN INVOICE RELATED TO THE FINANCIAL SECURITY OR KAYAK IN AN EXECUTED AGREEMENT. AND THIS IS WITH A CUSTOMER BEGGING FOR AN INVOICE. DO YOU THINK IT'S POSSIBLE FOR UTILITIES TO EVEN SATISFY THIS ON THE TIMELINE THAT'S BEING PROPOSED? I LOADED QUESTION, BUT I WILL SAY THAT THERE ARE, FROM MY UNDERSTANDING, TWO PARTS OF THAT, RIGHT? YOU'RE, YOU'RE CORRECT. THERE, THERE ARE, UH, THERE ARE DEFINITELY WORKFLOWS ON THE, THE UTILITY SIDE, BUT THEN MY UNDERSTANDING IS THERE'S ALSO CHALLENGES ON THE ILE SIDE OF THE TIMING OF WHEN FINANCIAL SECURITY LETTERS OF CREDIT AND THINGS LIKE THAT ARE ISSUED, WHETHER IT'S BEFORE, DURING, OR AFTER A UTILITY HAS EXECUTED AN AGREEMENT. SO YEAH, THERE, THERE ARE, THERE ARE MULTIPLE, MULTIPLE IRONS IN THIS FIRE THAT A 30 DAY ILL COMMIT COMMITMENT PERIOD IS JUST VERY, VERY DIFFICULT TO, FOR EVERYBODY TO, TO, UM, TO MEET. YEAH. I JUST, I THINK, I THINK IT'S HELPFUL FOR ERCOT TO HEAR THAT FROM THE UTILITIES AS WELL, THAT IT'S JUST, IT'S, YOU KNOW WHAT I MEAN, LIKE DIRECTLY. YEAH. AND THEN THERE'S, THERE'S A LOT OF DIFFERENCE, RIGHT? SO YOU ENTER AN INTERMEDIATE AGREEMENT WITH A STATED REQUESTED AMOUNT AND YOU HAVE TO PUT UP SECURITY FOR THAT. AND THEN ONCE YOU GO THROUGH BATCH AND THEN YOU'RE IN THE ILE COMMITMENT PERIOD, YOU MAY OR MAY NOT BE ALLOCATED. AND SO THEN THERE ARE NOW DIFFERENT TRANSMISSION UPGRADES, DIFFERENT ESTIMATES, DIFFERENT LOAD THAT WE HAVE TO SERVE. AND SO THE INTERMEDIATE AGREEMENT NOW HAS TO GET RESTUDIED OR REDONE, RIGHT? AND YEAH, THAT, THAT, THAT GOES THROUGH MANY DEPARTMENTS, MANY GROUPS. SO I, I KNOW WHAT YOU'RE SAYING, I JUST DON'T KNOW HOW, UM, I DON'T WANT TO SAY THAT UTILITIES CAN'T MEET IT. IT'S JUST VERY GONNA BE VERY DIFFICULT. YEAH. IT JUST, FROM MY EXPERIENCE, IT SEEMS BASICALLY IMPOSSIBLE. SO IT, IT'D BE INTERESTING TO HEAR FROM UTILITIES THAT THINK THAT IT'S, IT'S [05:00:01] ACTUALLY POSSIBLE. UM, SO I HAVE TO DROP IT. THANKS FOR TAKING THE CALL. YEP, NO PROBLEM. CAN I JUST, SORRY, CAN I ASK YOU A QUICK QUESTION ABOUT THAT? SO JUST SO I UNDERSTAND, WHEN YOU'RE LOOKING AT THE INTERCONNECTION AGREEMENT, YOU'RE LOOKING AT KAYAK AND AS, AS ONE OF THE BUCKETS OF MONEY, AND WE'RE TALKING ABOUT BASE LOADS. SO IS IT, IS IT THAT A LOT OF THESE LOADS HAVEN'T PAID KAYAK YET OR THEY'VE PAID SOME OTHER FINANCIAL SECURITY? 'CAUSE THAT WAS MY, I MEAN, I THINK THAT WAS PART OF OUR THINKING WAS THAT THERE'S ALREADY BEEN MONEY DOWN FOR THAT, AND THAT'S WHAT WE'RE HEARING. SO IS THEY, THEY WOULD'VE ALREADY PUT 50 K PER MEGAWATT DOWN IF THAT'S WHAT THE AMOUNT STAYS, UH, PRESUMABLY THEY PUT DOWN, AND THAT IS, AND THAT IS SECURITY, RIGHT? AND WE'RE NOT, WE'RE UN WE HAVE NOT BEEN GIVEN DIRECTION AS TO WHAT THAT SECURITY IS TO DO GOES TOWARDS, RIGHT. GOES TOWARDS, RIGHT. SO THAT'S OPEN-ENDED. UTILITIES HAVE A VERY FINITE DEFINITION OF HOW FINANCIAL SECURITY IS HANDLED, AND WHAT IT'S GOING TOWARDS IS SOCIALIZED COSTS FOR THE WHOLE SYSTEM. SO YOU CAN'T, IT'S HARD TO, AND, AND, AND THIS, THIS, I'M, I'M NOT A LAWYER, UM, NEITHER AN ENGINEER. SO I'M, I'M, I'M A LIBERAL ARTS MAJOR HERE, SO I'M, BEAR WITH ME. YOU'RE DOING GOOD. SO I'M DOING GOOD. OKAY. SO YEAH, THANKS SHANNON. UM, SO, YOU KNOW, THE FINANCIAL SECURITY DOESN'T HAVE, IN THE INTERMEDIATE AGREEMENT DOESN'T HAVE ANYTHING TIED TO WHAT A UTILITY SHOULD BE DOING. THERE'S NOT AN EXCHANGE FOR A SERVICE IN THE INTER INTERMEDIATE AGREEMENT. IT'S JUST YOU ATTEST, ATTEST, ATTEST, DISCLOSE, GIVE ME 50,000 PER MEGAWATT. THAT'S ALL THE INTERMEDIATE AGREEMENT DOES. THEN WE MOVE INTO THE INTERCONNECTION AGREEMENT, THEN THAT HAS ALL THE TEETH, RIGHT? THEN IT HAS THE FINANCIAL SECURITY FOR NON-REFUNDABLE INTERCONNECTION FEE. UM, OR IS IT REFUNDABLE? RIGHT? LIKE RIGHT, I KNOW I I'M LIVING IN A WORLD AND THEN, AND THEN WE HAVE YEAH, NO, NO, NO, I KNOW I, WHERE WE'RE IN THE FUTURE AND ALL, LET'S SAY THAT'S SETTLED. CORRECT. AND SO THEN YOU HAVE KAYAK, WHICH IS DIRECTLY FOR DRIVEWAY COSTS, RIGHT? CUSTOMER DIRECTED COSTS, SO NOT SOCIALIZED. AND THEN YOU HAVE A THIRD SEC, A SECOND SECURITY OR THIRD FORM OF FINANCIAL, UM, COMMITMENT IN THE FORM OF LONG LEAD TIME. MM-HMM . EQUIPMENT OR SERVICES. RIGHT NOW WHAT'S NOT CLEAR IS 5 8 4 0 1 LINKS INTER INTERMEDIATE DOWN TO INTERCONNECTION, BUT PICKER 1 45 HAS THE, IT COMPLETELY SEPARATE. IT'S USING THE SAME WORDS, BUT THE WAY THE MECHANISM IS COMPLETELY DIFFERENT. SO YOU'RE NOT, YOU WE'RE, WE'RE NOT DRAWING DOWN ON, SO LET'S SAY WE GO INTO A BASE LOAD AND WE HAVE 9 7 2 INTER INTERCONNECTION AGREEMENT. 'CAUSE THEY DON'T NEED A 9 7 1 DOESN'T GET THEM INTO BASE LOAD, RIGHT? THE CURRENT LANGUAGE IN 9 7 2 HAS ALL THIS. YOU NEED, YOU NEED TO DRAW DOWN FROM AN INTERMEDIATE AGREEMENT. I DON'T HAVE AN INTERMEDIATE AGREEMENT. RIGHT. SO THAT'S ZERO. SO YOU WOULD, I MEAN, OTHER THAN THE 50 K, THEY WOULD'VE PUT DOWN WITH THE INTERMEDIATE AGREEMENT THE WEEKS EARLIER, THEY'VE PUT DOWN, I PRESUME SECURITY TO BE BASELOAD AT THIS POINT GETTING INTO THAT BUCKET. SO YOU WOULD, YOU, THERE'S SOME MONEY THERE AND YOU WOULD BE FIGURING OUT THE INCREMENTAL DIFFERENCES BETWEEN WHAT THEY PAID AND WHAT YOU NEED FOR AN INTERCONNECTION AGREEMENT. IT, AND I, I APPRECIATE IF IT'S NOT THAT, IF I'M THINKING ABOUT THAT TOO SIMPLY, THAT'S REALLY HELPFUL TO HEAR. I JUST, WHEN I WAS THINKING ABOUT, WE'RE TALKING ABOUT BASE LOADS AND WE KEEP HEARING, THEY PUT DOWN MONEY, THEY PUT DOWN MONEY, UM, AND THEN THEY WOULD'VE PUT DOWN THE 50 K. HOW MUCH MORE ARE WE TALKING ABOUT? WHAT IS THE BIG DIFFERENCE? AND IT SOUNDS LIKE THE BIG DIFFERENCE IS THE COMMITMENT THAT BOTH PARTIES ARE MAKING AT THAT POINT. THAT'S THE DIFFERENCE. YEAH. AND I THINK, AND I THINK THE FINANCIAL PIECE. IT, IT, IT VARIES FROM PROJECT TO PROJECT, FROM UTILITY TO UTILITY. UM, YEAH, I UNDERSTAND THAT AND HOW, AND HOW WE, HOW WE ENTER INTO YOUR LEGACY 9.5 IA VERSUS YOUR NOW NEW BUT UNFINALIZED, YOU KNOW, 5, 5, 8, 4, 1 STUFF. SO IT, IT'S HARD FOR US TO KNOW EXACTLY WHAT THE INTERCONNECTION AGREEMENT NEEDS TO LOOK LIKE BECAUSE THERE'S NO GUIDANCE, BUT WE'RE AFRAID THAT IT'S IN FIGURE 1 45, WHICH THEN NOW MEMORIALIZES ALL OF THESE ISSUES AND THEN NOBODY WILL BE ABLE TO CONFIDENTLY GET INTO BATCH ZERO BECAUSE THEY DON'T KNOW WHAT FIN WHAT AGREEMENTS AND FINANCIAL COMMITMENT THEY HAVE TO PUT UP THAT ERCOT WILL ACCEPT. BECAUSE RIGHT NOW IT'S FORKLIFT 5 8 4 0 1 LANGUAGE INTO A PIGGER, BUT DIDN'T CONNECT [05:05:01] ALSO THE SAME CONCEPTS THAT 5 8 4 0 1 IS CONNECTING INTER INTERMEDIATES TO INTERCONNECTION AND HOW ALL THAT FLOWS IN THE TIMELINE OF A, A PROJECT DEVELOPMENT. OKAY. SO, I MEAN, I THINK WE, YEAH, THAT'S, UM, AND, AND I'M HAPPY TO, HAPPY TO WORK OFF, I KNOW THAT WE HAVE OTHER FORUMS THAT WE CAN KIND OF LIKE FLESH THIS OUT, BUT YEAH, A LOT OF IT IS MORE OF LIKE TIMING AND LIKE JUST TALKING WITH CUSTOMERS ABOUT, OKAY, NOW THESE ARE PEGA 1 45 AND 5 8 4 8 1 RULES. WHAT, WHAT'S OUR, WHAT'S THE, WHAT'S THE, WHAT'S THE CASH FLOW? WHAT ARE WE LOOKING AT? HOW MUCH ARE WE SUPPOSED TO BE, BE PUTTING UP OR PUTTING DOWN? AND HOW MUCH DO WE HAVE TO GO ASK FOR? AND THEN ONCE WE HAND IT OVER TO YOU, WHAT ARE WE GONNA USE IT FOR? RIGHT? LIKE WE HAVEN'T, WE HAVEN'T EVEN FIGURED OUT THE WHOLE, UH, REFUND MECHANISM OR THE 80 20 OR THE ELEVATED DON'T KNOW. AND THE FEAR IS THAT IF WE DON'T ADDRESS IT IN P 1 45 AND IT SOMEHOW STAYS IN THERE, THEN THAT NOW IS MEMORIALIZED TO DRIVE WHAT HAPPENS IN 5 8 4 8 1, WHICH WE'RE TELLING YOU NOW THAT THIS IS UNWORKABLE THE WAY, YOU KNOW, IN P 1 45. OKAY. UM, THAT'S HELPFUL. SO I HESITATE TO PUT THIS OUT THERE, BUT YOU KNOW, AT ONE POINT WE HAD TWO DIFFERENT, WE HAD SLIDES WITH TWO DIFFERENT PATHS WHERE WE PUT THE LANGUAGE INTO BIGGER 1 45 AND WE CAN MOVE FASTER, WE CAN GO, UM, AND THERE'S CERTAIN, THERE'S, TO THE EXTENT WE CAN PROVIDE CERTAINTY BY PUTTING IT IN HERE AND NOT POINTING TO AN UNFINALIZED RULE, IT'S IN HERE. AND THE OTHER PATH WAS THAT WE WAIT UNTIL 58 41 IS, IS FINISHED. UM, AND SO I JUST, I ENCOURAGE PARTY EVERYBODY TO THINK ABOUT, THAT'S THE TRADE OFF THAT WE'RE WORKING WITH HERE IS TRYING TO MOVE THINGS FASTER, BUT ALSO RECOGNIZE THAT THERE ARE ADDITIONAL THING, YOU KNOW, POLICY DECISIONS BEING MADE AT THE PUC. YEAH. AND, AND I'M NOT, AND I THINK WHAT I'M ARGUING FOR IS THAT THE PLANNING GUYS SHOULD JUST BE MECHANICS, NUTS AND BOLTS ON HOW, BUT THE BATCH STUDIES SHOULD WORK AND, AND IT SHOULDN'T START TO BLEED INTO FINANCIALS AND REFUNDS AND KAYAK AND THINGS LIKE THAT. IT, IT JUST DOESN'T BELONG IN PLAIN VALUE. YEAH. AND HAPPY, YOU KNOW, HAPPY TO COME UP WITH IDEAS OF HOW, HOW TO POINT TO DIFFERENT PLACES WITHOUT NECESSARILY PITCHING HOLE US PITCHING HOLE US INTO SOMETHING THAT IS ANCHORING TO A RULE THAT'S NOT RULE THAT'S THAT THAT'S NOT FINALIZED. YEAH. SO I APPRECIATE THAT. YEAH. THE SPEED I WAS TRYING TO DO, I KNOW ALL THE THINGS THAT ONE, I THINK I TOLD AG THAT THE, THE WORD OF THE MONTH NEXT T SHOULD BE, IF WE ONLY HAD MORE TIME , WE'D WORK ON THIS FOREVER THEN. YEAH. YEAH. OKAY. SORRY ABOUT THAT. AND I KNOW I'M PAST MY TIME. UM, THE NEXT ONE, ILE COMMITMENT PERIOD. I THINK WE'VE HEARD THIS FROM ENCORE, LCRA, AND I'M JUST GOING TO TRIPLE DOWN ON IT. THE COMMITMENT PERIOD, 30 DAYS VERY SHORT. UH, WE WOULD, WE WOULD, UH, ADVOCATE FOR EXTENDING THAT TO 60 DAYS. UM, AND THEN THE NEXT PART, ASSESSING CONSTRUCTION FEASIBILITY. SO IN THIS SECTION, 9 2, 9 3 2 4, UM, REALLY, UM, APPRECIATIVE THAT ERCOT ADOPTED THESE SUGGESTED CHANGES. THIS REALLY DID HELP US, UH, UH, CATALOG AND UNDERSTAND, UH, THE REQUIREMENTS, UM, AND A LOT MORE CLARITY AND DETAIL. ONE THING IS ON FOUR C AND IS, IS, UM, FOR THE, SO THERE IN FOUR C IT'S ASKING FOR THE T DSPS TO PROVIDE A WRITTEN COMMENTS, UM, OF CONSTRUCTION, FEASIBILITY OF THE PROJECTS. AND, UM, WE WE'RE JUST ASKING FOR AN ADDITIONAL FIVE, FIVE, UH, BUSINESS DAYS TO COMPLETE THAT. RIGHT NOW IT'S WRITTEN AS 10, SO WE'RE JUST ASKING FOR 15 THERE. AND THEN NEXT, SORRY. ALRIGHT, THIS IS A, PERHAPS JUST ANOTHER INADVERTENT OMISSION JUST FROM ERCOT HAVING TO SIFT THROUGH ALL OF THE, UM, NEEDLES IN THE HAYSTACK. BUT IN, UM, THE BATCH ZERO REPORT AND IN THE REFINEMENT REPORT, CENTERPOINT JUST REALLY WANTS TO STRESS THAT IT'S, IT'S IMPORTANT TO US THAT THE REPORT IDENTIFIES THE INTERCONNECTING TDSP RESPONSIBLE FOR CONSTRUCTING THE PROPOSED TRANSMISSION FACILITY IMPROVEMENTS. I KNOW IT'S INFERRED, BUT JUST TO, TO, TO STATE, STATE IT CLEARLY THAT, YOU KNOW, IF IMPROVEMENT X THEN TELL ME WHICH ENTITIES ARE RESPONSIBLE FOR THAT. AND SO THE SAME THING IN THE REFINEMENT REPORT, JUST ADDING THAT, UM, PHRASE THERE, UM, IN RED. AND THEN LASTLY, UM, SHORT CIRCUIT ANALYSIS. WE AGAIN, JUST, I THINK PERHAPS JUST ANOTHER INVERT OMISSION, [05:10:01] BUT, UM, UH, WE HAD MADE THESE COMMENTS, UM, I THINK ENCORE ALSO ECHOED THESE COMMENTS, UM, ON THE 20TH BASICALLY TO REINSERT, UH, SOME OF THE RED LINES. I, I'M NOT SURE IF IT PICKS UP IN THE PIC. OH, THERE IT IS. UM, BUT YEAH, JUST, JUST THE RED, RED LANGUAGE THERE. UM, ONE OF THE MAIN THINGS WAS THAT, UH, TO RECOGNIZE THAT TSPS WILL USE THE SHORT CIRCUIT CASES THAT WERE DEVELOPED BY ERCOT. LIKE WE, I DON'T THINK TSPS HAD ENVISIONED, UH, DEVELOPING THOSE SHORT CIRCUIT CASES. SO THAT, THAT CONCLUDES. ALRIGHT. UM, MY COMMENTS, MATT, THANK YOU. THANK YOU, JIM. I LIKE THE SCREENSHOTS OF THE LANGUAGE RIGHT THERE. I, I FIGURED YOU DIDN'T HAVE THAT WAY. YOU'D HAVE TO GO BACK UP AND DOWN AND PART TO GO HELP BROTHER. YEAH. THANK Y'ALL . ALRIGHT, THANKS. SO NOW JIM, YOU'RE NOT OFF THE HOOK. SO WE DO HAVE FIVE COMMENTERS. I'LL REMIND, STILL HAVE FIVE COMMENTERS TO THE COMMENTER. THEN WE HAVE VISTRA AND THEN WE ALSO HAVE BARATH THAT DID HIS HOMEWORK ON THE 5 8 4 8 1 BREAKDOWN. SO BRIEF AND AMAZING IS PROBABLY THE WAY TO GO. AND SO WE'LL CALL RUN THE QUEUE BROTH. YEAH, I THINK MY COMMENT WAS ABOUT THE TWO WEEK TURNOVER PERIOD. I THINK IT'S EXTREMELY DIFFICULT. I THINK YOU, YOU KIND OF ALLUDED TO THAT. AND THEN CHRISTINA, THERE IS ALSO AN ELEMENT WHERE BASE LOAD MAY GET APPROVED WITHOUT ANY UPGRADES SAY, RIGHT? AND THERE WAS NO NEED FOR KAYAK BECAUSE, SO HOW WOULD YOU TRANSLATE THAT INTO INTERMEDIATE AGREEMENT PIECE? UH, SO, AND, AND ONE LAST POINT WAS OBVIOUSLY, AND I'VE MADE THIS MULTIPLE TIMES, THAT FIGHT 4 8 1 IS FOR NEW LOADS ONLY, AND PAD ZERO IS NOT NEW LOADS. SO THAT'S THE NEW ANSWER, THAT'S ALL. SO TO BRETT, CAN I ASK, UM, UM, YOU KNOW, IT'S NOT GONNA BE SIX MONTHS, HOW, HOW MANY WEEKS YOU THINK THAT YOU WOULD NEED TO CONVERT AN INTERMEDIATE TO INTERCONNECTION? THE BIGGEST ANSWER IS IT DEPENDS, RIGHT? BUT I THINK IT DEPENDS ON THE UTILITY. BUT MY EXPERIENCE HAS BEEN, IT'S ALWAYS AROUND AT LEAST 60 DAYS AT LEAST BECAUSE THE UTILITIES HAVE THEIR PROCESSES AND THEN WE GET THE INVOICE, WE NEED TO WORK IT THROUGH INTERNALLY FROM, YOU KNOW, PERSPECTIVE POST IT, THEN THEY VERIFY. SO THERE'S A WHOLE LOT OF PROCESS THAT GOES ON. SO YEAH, AT LEAST 60 DAYS. AND I'M SAYING THAT'S THE FASTEST, JEFF, I WOULDN'T BE, YOU MIGHT SEE COMMENTS SOON ON THAT FOR 5 8 4 8 1. YEAH. OKAY. I WOULDN'T, I WOULDN'T BE SURPRISED TO SEE SOMETHING ROD SAID IF NOT DOUBLE. YEAH. AND I THINK MY BIGGEST FEAR IS A BASE LOAD THAT IS ELIGIBLE TO BE A BASE LOAD IN BADGE ZERO DOESN'T MISS OUT BECAUSE OF THIS TIMELINE. EXACTLY. THIS ADMINISTRATIVE TIMELINE. THAT'S THE BIGGEST FEAR. OH, OH, SORRY. GO AHEAD. I'M SORRY, CHRISTINE. I DIDN'T MEAN TO GO, GO FOR IT. I JUST WANNA, SO YOU, IF THE, IF THE CHOICE IS, LET'S SAY EVERYTHING STAYS THE SAME, NO GUARANTEE THAT IT DOES, WELL, LET'S SAY IT STAYS THE SAME. UM, IT, YOU FALL INTO THAT, THAT SITUATION WHERE YOU MAY OR MAY NOT BE BASELOAD AND YOU MAY OR MAY NOT KNOW THAT BEFORE JULY 10TH, YOU, IT'S, IT'S, WHAT I'M HEARING IS IT WOULD BE BETTER TO GO AHEAD AND SIGN THE INTERCONNECTION AGREEMENT AND FOR US TO CONSIDER THAT AS SATISFYING AN INTERMEDIATE AGREEMENT RATHER THAN ENTERING AN INTERMEDIATE AGREEMENT AND HAVING TO CONVERT IT WITHIN SOME PERIOD AFTER. SO YOU'D RATHER PUT UP ALL THAT MONEY AHEAD OF TIME AND ENTER INTO THAT AGREEMENT BEFORE YOU KNOW WHETHER YOUR BASE LOAD OR NOT. BECAUSE THAT'S HOW I WAS THINKING ABOUT THAT. YOU WOULD PREFER THE OPPOSITE. YEAH. AND THAT, THAT WOULD BE BETTER FOR ALL PARTIES. BUT IF THAT DOESN'T WORK, THEN I, YOU KNOW, I THINK WE'RE BACK TO, YOU ENTER THE INTERCONNECTION AGREEMENT AND WE TREAT IT AS AN INTERMEDIATE AGREEMENT. IF YOUR LOAD IS NOT CONSIDERED BASE LOAD, YOU'RE, YOU'RE PUTTING THE TO BE STUDIED BUCKET. I'VE POSTED MY COMMENTS LIKE FEW WEEKS AGO, BUT I THINK MY THOUGHT PROCESS, AND YOU'LL PROBABLY HEAR FROM THE COMMISSION ON THE 17TH ABOUT WHAT THE NEXT STEPS ARE, BUT IF THERE IS A BASE LOAD THAT'S ALREADY, YOU KNOW, KIND OF PROVEN TO WITH OTHER CRITERIA, WHAT SHOULD THE FINANCIAL SECURITY BE FOR? RIGHT? I MEAN, WHAT IS IT'S, IT IS, WHAT IS IT PROVING ESSENTIALLY? SO MY APPROACH IS MORE NUANCED THAT LIKE, IF THERE IS A BASE LAW, IT AUTOMATICALLY GETS INTO BAD ZERO BECAUSE YOU HAVE CERTAIN CRITERIA ALREADY, RIGHT? IF IT'S A 27 LOAD, YOU HAVE TO SHOW LES AND OTHER THINGS. I MEAN, THE IDEA IS IT'S A, IT'S A GATING ITEM FOR YOU TO ELIMINATE SPECULATIVE LOADS. THAT'S HOW I UNDERSTAND. RIGHT. AND IF THEY ARE PROVIDING OTHER NUANCES FOR YOU TO SHOW THAT THEY'RE REAL LOAD, WHY DO THEY NEED TO GO AND DO ALL THIS AGAIN TO SIGN THE INTERCONNECT, INTERMEDIATE AGREEMENT INTERCONNECTION AGREEMENT AGAIN, RIGHT? THAT'S NUMBER ONE. AND THEN SECOND ONE IS THE KAYAK PIECE. IF THEY ALREADY WORKED WITH UTILITIES [05:15:01] AND POSTED KAYAKS AND POSTED SECURITIES, AGAIN, THIS IS JUST, IT'S GOING TO BE A HUMONGOUS TASK FOR ALL THE UTILITIES TO GO THROUGH THIS FOR ALL THE LOADS. RIGHT? THINK ABOUT THE STAFFING AND OTHER THINGS. SO THAT'S WHY I BELIEVE THAT YOU SHOULD GRANDFATHER WHAT YOU CAN GRANDFATHER AND RESPECT THE CURRENT AGREEMENTS, AND ONLY THOSE THAT HAVEN'T POSTED THESE AGREEMENTS THAT ARE BEING STUDIED IN BAD ZERO MAY NEED TO, UH, GO THROUGH THIS PROCESS THAT WILL REDUCE THE CONSTABLE AMOUNT OF LOADS THAT HAVE TO POST THESE AGREEMENTS AND THAT BECOME MUCH EASIER ON THE UTILITY SIDE AS WELL. THAT MAKES SENSE. THAT, YEAH, THAT MAKES SENSE. AND YOU KNOW, I, I HEAR YOU ON, UM, IF YOU'RE, IF YOU'RE AT A CERTAIN MILESTONE, A CERTAIN LEVEL OF MATURITY THAT SATISFIES THAT SORT OF REALNESS QUESTION, I DON'T KNOW, OR MAYBE YOU CAN ADDRESS THIS, HOW THAT SATISFIES THE RATE PAYER KIND OF PROTECTION EVERYBODY ELSE ON THIS SYSTEM. SO YOU, YOU MAY BE YEAH. REAL, BUT IF YOU COULD STILL WALK AWAY AT THAT POINT. YEAH, AND, AND I, YOU KNOW, WE HAVE NO VISIBILITY INTO THE FINANCIAL SECURITY THAT'S ALREADY BEEN PAID. UH, SO IT'S, IT'S, THAT'S WHERE I, LIKE, I I DON'T, AND, AND THIS IS, AND I WOULD BE, BUT THAT'S NOT A HUNDRED PERCENT CLEAR. THIS IS A COMMISSION, THIS IS THE PUC DOMAIN. I I RECOGNIZE THAT. UM, I DO THINK IT'S HELPFUL TO THINK ABOUT WHAT THE ALTERNATIVES COULD BE THOUGH AS WE THINK ABOUT WHAT GOES TO THE COMMISSION YEAH. AND WHAT, YOU KNOW, WE MIGHT HEAR YEAH. AND MAY MAYBE, LET, LET ME PUT IT THIS WAY. I, I THINK THERE IS A POSSIBILITY, I DON'T KNOW, I'M NOT GONNA PUT A PERCENTAGE CHANCE ON IT, BUT I THINK THERE'S A POSSIBILITY THE COMMISSION SAYS WE WANT THIS TO APPLY TO ALL LOADS, EVEN IF THEY HAD A PREVIOUS AGREEMENT. YEAH. WE, WE WANT THEM TO HAVE TO MEET THIS IN THAT WORLD. I THINK THE QUESTION THAT WE HAVE IS WHAT DO YOU WANT TO DO? IF YOU HAVE A, IF YOUR STUDY COMES IN ON JULY 9TH AND THERE IS SOME UNCERTAINTY AS TO WHETHER YOU WILL BE BASE LOAD OR NOT, WOULD YOU RATHER JULY 10TH HAVE TO JUST SAY, OKAY, WE, WE WILL MEET THE INTERCONNECTION AGREEMENT REQUIREMENTS AND THEN IF WE END UP BEING STUDIED LOAD, THEN OKAY, WE, WE'VE MET A HIGHER THRESHOLD AND, AND SO THAT'S OKAY. OR WOULD YOU RATHER ON JULY 10TH MEET THE INTERMEDIATE AGREEMENT REQUIREMENTS WITH A KIND OF CURE PERIOD LATER IF WE TELL YOU, OKAY, YOU ARE BASE, YOU, YOU ARE QUALIFIED FOR BASE LOAD WITH A CURE PERIOD OF SOME NUMBER OF WEEKS AFTER THAT TO, TO, SO TO INCREASE YOUR FROM INTERMEDIATE TO INTERCONNECTION AGREEMENT REQUIREMENTS. YEAH, I THINK IE PROBABLY MAY BE ABLE TO DO THAT. BUT AGAIN, I THINK I'M MOSTLY TALKING ABOUT THE PRACTICAL TIMELINES OF THIS. IF WE DO THIS IN JULY 10TH, TWO WEEKS MAY NOT BE POSSIBLE. AND MY SOLUTION IS PROBABLY YOU'LL GET GUIDANCE ON THE 17TH AND MAYBE AS YOU'RE DOING THIS RULING BASE BASE LOADS APPROVAL, PROBABLY THAT'S ALSO A TIME TO LET PEOPLE KNOW TO WORK ON THESE AGREEMENTS SO THAT YOU HAVE ENOUGH TIME RAMP TILL JULY, RIGHT? YEAH. BASED ON WHATEVER GUIDANCE YOU GET ON COMMISSION ON THAT. SO THAT WAY YOU'RE GIVING THEM FROM APRIL, MID-APRIL TO JULY, MID-JULY, SO 60 DAYS TO WORK ON DIFFERENT THINGS RATHER THAN COME JULY 9TH. I KNOW THERE MAY BE LOADS THAT GET APPROVED ON JULY 9TH, RIGHT. THAT STILL NEED TO GO THROUGH THIS, BUT AT LEAST YOU'RE REDUCING THE NUMBER OF LOADS THAT, UH, AT ONE GO TO UTILITIES VERSUS FROM APRIL 17TH. OKAY. ALL RIGHT. THANK YOU BOTH. UH, ANDREW? YEAH. HEY GUYS. ANDREW SHOPPER, SHOPPER ENERGY CONSULTANT. I JUST, I WANT TO ECHO SOME OF WHAT BARACK JUST SAID, WHICH IS THIS IS REALLY SORT OF JUST ADMINISTRATIVE TIMELINE BETWEEN THE TIME THE LOAD CUSTOMERS WILL UNDERSTAND WHAT THE FINAL INTERCONNECTION STANDARDS LOOK LIKE AND THE TIME THEY WILL BE NEEDING TO PERFORM ON THOSE STANDARDS. SO THE THING THAT'S MAKING US A LITTLE NERVOUS IS WE'RE, YOU KNOW, THIS MAY NOT BE ERCOT BOARD APPROVED UNTIL THE 1ST OF JUNE, AND THEN THE COMMISSION HAS 30 DAYS TO ACT ON IT. BUT IN THE INTERIM, YOU KNOW, REALLY THAT'S THE TIME PERIOD THE LOAD CUSTOMER WOULD HAVE TO, TO MODIFY THOSE INTERCONNECTION AGREEMENTS TO MEET THE STANDARDS PROVIDED THERE WAS NO CHANGE, RIGHT? SO I GUESS WHAT WE'RE REALLY SAYING IS WE WOULD NEED THE COMMISSION GUIDANCE IN A, ON A FIRM BASIS AND IT WOULD NEED TO HAVE BEEN ADOPTED BY ERCOT EFFECTIVELY NOW IN ORDER TO MAKE THOSE CHANGES IN TIME SO THAT WE DON'T, UH, YOU KNOW, LOSE STATUS AS WE'RE GOING INTO THE NEXT PART OF THIS PROCESS. UH, AND, AND I'LL JUST ECHO WHAT BARATH SAID AROUND TRYING TO MODIFY A BUNCH OF AGREEMENTS WITH UTILITIES IN THE SPAN OF TWO WEEKS. DOESN'T REALLY MAKE ANY SENSE. AND SO THIS IS BACK TO CHRISTINA'S COMMENT EARLIER, WHICH WAS, HEY, THERE WERE TWO PATHS. ONE PATH WAS WE'RE GONNA FORKLIFT EVERYTHING. THE [05:20:01] OTHER PATH IS THIS JUST GETS ALL DELAYED. WELL, THE MIDDLE PATH IS THE GRANDFATHERING PATH AS, AS I THINK BROTH HAS DESCRIBED, RIGHT? SO THERE'S A PATH THAT THAT HONORS THE EXISTING AGREEMENTS. AND THAT, THAT'S WHY I JUST, I'M, I'M STRUGGLING WITH LIKE HOW ADMINISTRATIVELY THIS IS ACTUALLY GONNA HAPPEN. I THINK THE THANKS ANDREW. ALRIGHT, SHANNON, IT'S NOT, MAY NOT SURPRISE ANYBODY. I AGREE WITH BARATH ON THIS AND WITH ALL WITH ANDY AND EACH OF THE COMMENTS THAT HAVE BEEN MADE, I'M LOOKING RIGHT HERE AT THE SENATE BILL SIX, LANGUAGE APPROVED LANGUAGE IN SECTION TWO, PARAGRAPH C. THE STANDARD MUST APPLY ONLY TO CUSTOMERS REQUESTING NEW OR EXPANDED INTERCONNECTION WHERE THE TOTAL LOAD AT SINGLE SITE WOULD EXCEED A DEMAND THRESHOLD, BLAH, BLAH, BLAH. UNDER THE EXAMPLE I GAVE WHILE AGO, WHICH ISN'T COMPLETELY HYPOTHETICAL, IT'S ONE OF OURS, WE HAVE AN INTERCONNECT AGREEMENT THAT PRECEDES THIS SENATE BILL SIX AND CERTAINLY PRECEDES 58 41. THAT'S STILL JUST A RULE MAKING. IT'S NOT EVEN A, A FINAL RULE IN THIS SENATE BILL SIX LANGUAGE THAT IT'S TRYING TO IMPLEMENT IS UNAMBIGUOUSLY CLEAR. IT ONLY APPLIES TO NEW AGREEMENTS THAT FALL OVER THAT THRESHOLD. WHAT ON EARTH, HOW DID WE GET OURSELF IN THIS POSITION WHERE, WHAT LEGALLY ARE WE WORKING OFF OF THAT MAKES US THAT MAKES US THINK, OTHER THAN SOMEBODY MAY HAVE A PRE A PREFERENCE FOR IT OR IT'LL PROTECT GRANDMA OR MOM AND DAD OR US. HECK, WE ALL PAY TSP RATES ON OUR BILLS EXISTING LAW THAT WAS IN PLACE AT THE TIME, AGREEMENTS THAT WERE IN PLACE AT THE TIME AND YOUR OWN ERCOT RULES THAT ARE IN PLACE TODAY. UM, IT'S, IT'S INCONSISTENT TO TRY TO DO WHAT YOU'RE TRYING TO DO. AND THEN SECONDLY, I AGREE ON THE TIMELINE THING MODIFYING EXIST. EVEN IF IT WERE A GOOD IDEA AND EVEN IF IT WERE LEGALLY PERMISSIBLE, IT'S PHYSICALLY IMPOSSIBLE TO GET DONE IN TWO WEEKS. IT'S JUST IMPRACTICAL. AND NO ONE IS TELLING YOU THEY THINK THEY CAN DO THAT. SO TO CONTINUE TO JUST HOLD THIS POSITION, YOU'RE JUST ARE CAUGHT AND AS A WHOLE, YOU'RE JUST, YOU'RE SETTING YOURSELF UP FOR A TRAIN WRECK THAT'S NOT GOING TO WORK OUT WELL. AND EVERYONE'S TELLING YOU THAT. AND IT'S NOT LEGAL, IT DOESN'T APPEAR I'M NOT A LAWYER EITHER, BUT, UH, IT DOESN'T APPEAR TO BE LEGALLY PERMISSIBLE IN THE FIRST PLACE. AND SEVERAL PEOPLE HAVE SAID APPRECIATE THE COMMENT. I THINK WE'VE HEARD AND THAT, AND I THINK THERE CAN BE DISAGREEMENT. I DON'T THINK IT'S UNAMBIGUOUS THE LANGUAGE IN SENATE BILL SIX, I THINK IT IS STILL A NEW REQUEST FOR INTERCONNECTION. THERE IS, YOU ARE NOT ENERGIZED YET. THERE IS STILL A NEW REQUEST FOR INTERCONNECTION THERE. AND I THINK IT CAN BE READ THAT WAY AND INTERPRETED THAT WAY. AND I KNOW THESE COMMENTS, THERE WERE LOTS OF COMMENTS FILED IN 58 41 BEFORE THE PFP THAT SUGGESTED THE SAME AND THAT ASKED ABOUT, WELL, HOW ABOUT WE TREAT INFLIGHT PROJECTS DIFFERENTLY? AND THAT HASN'T BEEN DONE TO DATE. AND SO I, THIS IS I THINK A, I THINK THE APPROACH WE'RE TAKING IS ONE THAT IS CONSISTENT WITH WHAT WE'VE HEARD FROM THE COMMISSION SO FAR. AND I THINK IT IS CONSISTENT WITH WHAT A, A READING OF OF SENATE BILL SIX THAT IS A DIRECTION TO PROTECT TEXAS CONSUMERS AS WELL AS, UH, ENCOURAGE BUSINESS DEVELOPMENT. I DON'T HAVE THE EXACT LANGUAGE IN FRONT OF ME, BUT, YOU KNOW, BALANCING THOSE TWO PIECES YEAH, AGREE FOR THE NEED TO BALANCE. BUT WHEN YOU HAVE A SIGNED INTERCONNECT AGREEMENT WITH THE UTILITY AND YOU TOOK A LONG TIME TO GET TO THERE, THEY, YOU DON'T JUST SHOW UP AND THEY WRITE UP THE AGREEMENT. WE WORKED YEARS TO GET TO THERE. IF THAT'S A SIGNED INTERCONNECT AGREEMENT AT THAT TIME FOR THIS EXPAND THIS NEW LOAD THAT'S OVER THAT THRESHOLD. IT'S VERY DIFFICULT TO TWIST THIS TO SAY THAT IT'S NEW AFTER YOU KNOW THAT IT DIDN'T PROCEED THIS RULE. IT'S JUST, I DON'T KNOW. I DON'T KNOW HOW ANYONE CAN SAY THAT. ALL RIGHT. THANK YOU. ALRIGHT, SO HARSH. KEVIN. KEVIN, AND THEN WE'RE GONNA GO TO VISTRA. COMMENTS HARSH. GO AHEAD. THE CURRENT DRAFT OF 5 8 4 8 1, [05:25:01] UH, REQUIRES THAT THE LOADS SECURITIZE THE TRANSMISSION UPGRADES. WAS ERCOT GOING TO WORK WITH THE TSPS IN IDENTIFYING THE COST OF THE PROJECT AND THEN ALLOCATE BETWEEN THE LOADS? TELL ME THE QUESTION AGAIN. ALLOCATION. YEAH, SO, UM, IT'S MY UNDERSTANDING THAT 5 8 4 8 1 REQUIRES LOADS TO SECURITIZE TRANSMISSION UPGRADES. I'M JUST TRYING TO UNDERSTAND WHAT'S THE MECHANISM OF ERCOT? IS IT ERCOT COMING UP WITH THE NUMBER FOR EACH LOAD THAT WAS IN THE STUDY OR IS IT TSP DOING SOMETHING, JUST TRYING TO UNDERSTAND HOW THEY'LL WORK OUT? YEAH, I THINK OUR INTENTION IS THAT, UM, ERCOT WOULD DETERMINE THAT AND THAT WOULD GO INTO THE BATCH ZERO STUDY REPORT. THANK YOU. EXCELLENT. UM, AND, AND I BELIEVE THAT WAS ADDED TO 9.4 PARAGRAPH ONE I THINK IN OUR LAST COMMENTS. AND IT IT, IF NOT, THEN THE, I THINK THE INTENTION WOULD BE TO CAPTURE THAT IN FUTURE PROMISE. THANK YOU. EXCELLENT. OKAY. KEVIN HANSON? YEAH, MY COMMENT IS WE'RE NOT CURRENTLY TALKING AT ALL ABOUT 5 8 4 8 4. THAT'S THE ONE WHERE, LET'S MAKE THE ASSUMPTION AGAIN, WE HAVING LOT THE DISCUSSION ARGUMENTS ABOUT DIFFERENT THINGS RIGHT NOW. LET'S JUST MAKE THE ASSUMPTION I'M ADDING A GIGAWATT LOAD ON THE SYSTEM. I WRITE MY $50 MILLION CHECK FOR THE SECURITIZATION. LET'S MAKE THE ASSUMPTION WE STILL HAVE THE ARGUMENT OVER THE KAYAK. LET'S ASSUME I WROTE ANOTHER $50 MILLION CHECK FOR THAT A HUNDRED MILLION DOLLARS. THE ISSUE IS WE STILL MADE ANY RPG PROJECT AND WE DON'T KNOW WHO PAYS FOR THAT YET. IT COULD GO TO TCOS, IT COULD GO TO DATA CENTERS. LET'S SAY THERE'S ASSUMPTION, LITTLE ASSUMPTION. I GOT TWO DATA CENTERS SHARING A RPG PROJECT, A BILLION DOLLAR PROJECT. SO RIGHT NOW I'M ASSUMING I'M GONNA HAVE TO WRITE A CHECK FOR HALF A BILLION DOLLARS FOR THAT PROJECT, ASSUMING NO VEHICLE IS A TCOS. THEN THERE'S THE QUESTION AGAIN, FROM A SOCIAL PERSPECTIVE, ONE OF THOSE DATA CENTERS FALLS OUT AND SAY, I DON'T HAVE THAT HALF A BILLION DOLLARS TO WRITE NOW, AM I RESPONSIBLE FOR THE ENTIRE BILLION DOLLARS AS A COMPANY OR BOTH OF THEM FALL OUT OR WE JUST LIFTING THAT BILLION DOLLARS TO COSTS AND WE BUILT IT FOR NOTHING. UM, SO I I I WOULD SAY THAT 5 8 4 8 4 IS, UM, IT, IT, IT IS RELEVANT TO THE CONVERSATION. UM, I DON'T THINK IT IS GONNA CHANGE ANY LANGUAGE IN THE PICKER. I COMPLETELY AGREE THE ISSUES, WE GOTTA THINK ABOUT IT. 'CAUSE WE MAY BE BILLING HUNDREDS OF BILLIONS OF DOLLARS OF TRANSMISSION THAT NOBODY CAN AFFORD TO PAY FOR. ALRIGHT, THANK YOU FOR THAT POINT. NEXT, UH, KEVIN BOUDREAUX, THANK YOU MATT. KEVIN BOUDREAUX WITH MONARCH ENERGY. UH, APPRECIATE ALL THE WORK EVERYBODY'S DOING HERE, ESPECIALLY, UH, THE STAKEHOLDERS. UH, I KNOW EVERYBODY'S PUT IN A LOT OF TIME AND EFFORT INTO THIS PROCESS. I KNOW WE HAVE, I'VE BEEN AT EVERY BATCH WORKSHOP AND READ ALL THE COMMENTS. AND THERE'S ONE THING THAT IS VERY CONSISTENT, UH, THEME ACROSS EVERY WORKSHOP AND COMMENTS THAT WE'VE HEARD, AND IT'S BEEN, UH, EXPLICITLY STATED HERE TODAY. AND WE WHOLEHEARTEDLY SUPPORT, UH, CRUSO AND, UM, SHOPPER CONSULTING AND EVERYBODY ELSE THAT HAS PUT THIS FORTH. I THINK ANDY DID IT BEST IN HIS COMMENTS. AND, UM, ON PAGE FOUR OF HIS COMMENTS, HE SAYS, IN FINDING NUMBER TWO, AT LEAST 18 OF THE APPROXIMATELY 26 UNIQUE COMMENTING, PARTIES EXPRESSED CONCERN IN THEIR RESPECTIVE FILINGS ABOUT THE RETROACTIVE DISRUPTION OF EXISTING CONTRACTS. LOOK AT THE COUNTERPARTIES THAT ARE LISTED THERE. THESE ARE COUNTERPARTIES THAT HAVE BEEN IN THIS MARKET SINCE THE START OF COMPETITION. I MEAN, THEY KNOW HOW THIS MARKET WORKS AS WELL AS YOU DO. SO YOU KEEP HEARING THE SAME THING OVER AND OVER AGAIN. YOU, YOU HAVE TO TAKE NOTE OF IT. AND I KNOW LIKE US, THESE COUNTERPARTIES HAVE BEEN TALKING WITH THE PUC, WITH THE LEGISLATORS, EVERYBODY IN THE MARKET BECAUSE THE DRIVING FORCE HERE IS NOT ABOUT JUST THE MONEY AROUND NETWORK UPGRADES AND PROTECTING RATE PAYERS, WHICH WE ALL AGREE THAT WE NEED TO DO. YOU HAVE MULTIPLE BILLIONS OF DOLLARS IN COMMERCIAL CONTRACTS AT RISK. AND THE TWO THINGS THAT KILLS THE DEALS HERE ARE TIME AND UNCERTAINTY. AND THAT'S WHAT'S HAPPENING. AND SO WE HAVE TO LISTEN TO WHAT'S BEING SAID HERE. THE CENTER POINT DID A GOOD JOB TRYING TO VERY DELICATELY SAY, WE CAN'T DO THIS. EVERYBODY KNOWS [05:30:01] WE CAN'T DO THIS. IT TOOK US TWO AND A HALF YEARS TO GET TO SIGNING OUR INTERCONNECTION AGREEMENT. THERE'S, THERE'S JUST NO WAY TO EFFECTIVELY DO IT. SO I JUST WANTED TO PUT THAT OUT AND AGAIN, APPRECIATE EVERYBODY'S TIME HERE TODAY. ALRIGHT, THANK YOU KEVIN. ALRIGHT, NED, YOU WANNA HIT YOUR COMMENTS HERE, SIR? SO, NED'S OF THE COMMENTS AND THEN BROTH, I TOLD YOU IT WOULDN'T BE RIGHT AT THE END OF THE DAY, BUT BOY WENT TO THE END OF THE DAY. SORRY MAN. ALRIGHT. UM, SO I TRIED TO UPDATE THE SLIDE THAT WE HAD, UH, PUT IN THERE LAST TIME. UM, ACTUALLY, UH, I'M GONNA ASK MATT IF WE CAN PULL THE COMMENTS UP. I'LL, I'LL COME BACK TO THIS. DO DO WANT TO HIGHLIGHT THAT IT'S HERE IN CASE YOU WANT TO CLIFF'S NOTES VERSION. UM, BUT SINCE I HAVE YOU ALL CAPTIVE AND THIS IS OUR FINAL BATCH WORKSHOP, I , I KNOW I JUST WANTED TO GET ALL THE ARROWS POINTED MY WAY. RIGHT? UM, OKAY, SO, UH, IT STARTED OFF ACTUALLY, UM, IF YOU CAN SCROLL DOWN TO, IS IT PAGE SIX? UM, FIRST OF ALL, APPRECIATE ERCOT GOING THROUGH ALL THE COMMENTS. I I WAS FLOORED WITH JUST THE SIZE OF THAT MATRIX. I KNOW HOW MUCH OF AN EXERCISE IT IS TO PUT THOSE KINDS OF MATRICES TOGETHER. SO, UM, REALLY APPRECIATED ERCOT DOING THAT. I DID TRY TO, UM, TAKE ALL OF ERCOT COMMENTS ON TROS ITEMS IN THERE AND PROVIDE SOME REPLIES. SOME OF THEM ARE, YOU KNOW, REFLECT, EVOLUTION AND THINKING BASED ON, ON FEEDBACK AND NEW INFORMATION. SOME OF 'EM REFLECT, UM, EVOLUTION AND THINKING BASED ON KOTS FEEDBACK. SOME OF THEM ARE TRYING TO CORRECT WHAT, UM, WE THINK WERE PROBABLY MISCOMMUNICATIONS OR MISUNDERSTANDINGS, UH, BASED ON HOW WE PRESENTED THINGS IN THE, IN OUR INITIAL COMMENTS. UM, I THINK PROBABLY THE, THE ONES THAT I WANT TO HIGHLIGHT IN HERE ARE, UM, LET'S SEE, THE SECOND ONE, IF YOU SCROLL DOWN A LITTLE BIT, UM, THIS FIRST ONE, UH, I THINK ERCOT HAD UNDERSTOOD OUR RECOMMENDATIONS REGARDING THE QSA TIMING IS BEING CONTINGENT UPON THE 39 1 6 9 NET METERING ARRANGEMENTS. UM, THAT ACTUALLY IS INDEPENDENT OF THAT ISSUE. AND SO, UM, WE WANTED TO CLARIFY THAT AND, AND WE'VE REITERATED THAT RECOMMENDATION, UM, IN A MORE STREAMLINED FASHION IN THE ACTUAL RED LINES THAT ARE THAT, THAT COME IN LATER. UM, AND THEN ON THE NEXT COUPLE OF ITEMS, YOU KNOW, ERCOT FEEDBACK WAS ABOUT, YOU KNOW, WHAT P 39 1 69 DOES AND DOES NOT DO. UM, WON'T READ ALL OF THESE, BUT BASICALLY, YOU KNOW, I CERTAINLY AGREE THAT THERE'S NOT AN ENTITLEMENT TO A DECISION WITHIN 120 DAYS OF FILING THE APPLICATION AND APOLOGIZE IF THAT WAS HOW IT CAME ACROSS. UM, WHAT WE WERE TRYING TO HIGHLIGHT IS THAT THERE IS A 120 DAY TIMELINE THAT EXISTS IN STATUTE THAT APPLIES TO ERCOT STUDIES. AND SO THAT'S BEEN THE CRUX OF WHAT WE'VE BEEN WRESTLING WITH, IS HOW DO YOU GIVE EFFECT TO THAT ALONG WITH THE BATCH PROCESS, CONSIDERING THAT THAT 120 DAY TIMELINE WAS MEANT TO START, UM, AS A, A LIMITED SUPPLEMENT TO THE TSP DRIVEN STUDIES. I THINK WE'RE, WE'RE KIND OF DANCING AROUND THE SIM SIMILAR ISSUES, BUT AT THE END OF THE DAY, THE, THE CORE ISSUE IS THAT THE LEGISLATURE DID PROVIDE, UM, SOME VERY SPECIFIC AND, UM, I'LL SAY PREFERENTIAL TREATMENT IN 39 1 6 9. IT'S NOT ALWAYS, YOU KNOW, POSITIVE LIKE IT'S ADDITIONAL BUREAUCRACY AND ADDITIONAL STEPS AND REVIEWS AND STUDIES, BUT IT'S STILL PREFERENTIAL TREATMENT. AND PART OF THE TRADE OFF THERE WAS, THAT WAS BALANCED WITH SAYING WE'RE GOING TO TAKE THAT PREFERENTIAL TREATMENT THAT MAY ADD ADDITIONAL BURDENS, BUT WE'RE GONNA PUT A VERY TIGHT TIME LIMIT ON IT AND IT'S IN STATUTE. AND SO, UM, THE, AGAIN, ALL THE DETAILS IN THERE, WE DON'T NEED TO DWELL ON IT. JUST WANTED TO HIGHLIGHT THAT IT'S THERE IN CASE IT'S HELPFUL. UM, AND THEN YOU CAN SCROLL UP MATT TO THE TOP BECAUSE THAT DID HELP US THINK THROUGH HOW CAN WE MAYBE BE MORE CONSTRUCTIVE IN, IN THE APPROACH VERSUS THE APPROACH THAT WE HAD IN OUR INITIAL COMMENTS WHERE WE HAD SAID, WELL, MAYBE WE CAN JUST SAY, TAKE ALL THE 39 1 6 9 NET METER ARRANGEMENTS AND SAY THEY CAN GO DOWN THE LEGACY PROCESS. AND RECOGNIZING OUR COT IS, IS REALLY LOOKING TO MAKE A CLEAN CUT AND TRY TO MAKE A, A FULL SHIFT OVER TO THE BATCH PROCESS. UM, BUT BIGGER 1 45 IS LIMITED TO BATCH ZERO AS I THINK WE WE ADDRESSED EARLIER TODAY. UM, IT SEEMS LIKE AN EASY THING TO DO IS JUST FOCUS ONLY ON WHAT HAPPENS IN BATCH ZERO AND SAY, ALL RIGHT, FOR BATCH ZERO, HERE'S HOW WE'RE GOING TO DEAL WITH THESE 39 1 6 9 NET METERING ARRANGEMENT PROJECTS WITHIN THE, THE TIMELINE TIMELINES THAT ARE UNDER CONSIDERATION FOR BATCH ZERO AND THE TRANSITION TO IT. THEN, YOU KNOW, IF HOPEFULLY THAT GIVES US OPPORTUNITY TO LEARN AND WE CAN GET A VERY EFFICIENT PROCESS IN PLACE THAT ABSOLVES ALL OF THOSE TIMING CONSIDERATIONS FOR BATCH ONE PLUS. OR WE CAN TALK ABOUT IT AGAIN WHEN THE BATCH ONE PLUS ISSUES COME UP. BUT I THINK WE CAN ADDRESS IT FOR BATCH ZERO [05:35:01] IN A, IN A WAY THAT, YOU KNOW, IF YOU SQUINT AT IT, IT LOOKS, LOOKS GOOD ENOUGH. SO, UM, THAT'S WHERE WE HAVE THIS ADDITIONAL DETAIL. YOU CAN KIND OF SCROLL TO THOSE, THE BULLETS, RIGHT? UM, RIGHT THERE. THANK YOU. SO THERE'S REALLY TWO BUCKETS THAT WE'RE LOOKING AT HERE. ONE ARE THE NET METERING ARRANGEMENTS, THIRD AND 1 6 9 NET METERING ARRANGEMENTS THAT, UH, ONE ERCOT KNOWS ABOUT. SO THEY'VE GOT A LARGE LOAD INTERCONNECTION NUMBER AS OF, YOU KNOW, JULY 10TH, WHICH SEEMS LIKE THAT'S THE, THE OPERATIVE DATE. UH, YOU TAKE THOSE AND IF THEY ARE GOING TO BE ENERGIZED BY THE END OF 2027 OR, UM, YOU KNOW, HAVE AN APPROVED OR PENDING NET METERING APPLICATION IN FRONT OF THE COMMISSION, THOSE CAN FINISH OUT UNDER THE PROCESS THAT THEY STARTED UNDER, WHICH IS THE LEGACY PROCESS. SO IT'S JUST SAYING, LET'S NOT STOP THINGS THAT ARE IN, IN MOTION OR, OR, YOU KNOW, FORCE THINGS TO BE DELAYED IN, UM, BY PUSHING THEM INTO BATCH ZERO IF THEY WERE ALREADY GOING TO BE ENERGIZED IN 2027 OR EARLIER. SECOND BULLET ADDRESSES WHAT HAPPENS AFTER 2027. SO IT'S THE 2028, UH, INITIAL ENERGIZATION. AND FOR THOSE, IF YOU'VE GOT A, A LARGE LOAD INTERCONNECTION, UH, ERCOT KNOWS ABOUT IT, IT'S GOT AN LLI NUMBER AND IT'S ASSOCIATED WITH ONE OF THE GENERATORS ON ERCOT LIST FROM LAST SEPTEMBER, THEN STUDY IT IN BATCH ZERO SO THAT THAT WAY IT IS, UM, THE, THE BATCH PROCESS DOESN'T BECOME A GATING ISSUE FOR THE TIMELINE, UM, RELATIVE TO WHAT THE, THE LEGACY PROCESS IS. AND, AND THAT WAS THE, YOU KNOW, THE TIMELINE THAT THE LEGISLATURE HAD IN MIND WHEN THEY, UH, WERE, WERE CONSIDERING SENATE BILL SIX. SO THAT'S THE, UH, THE REVISED APPROACH THERE. I THINK IT'S A LITTLE BIT MORE STREAMLINED, PROBABLY A LITTLE BIT EASIER TO DIGEST. UM, THERE ARE SOME MORE WORDS AROUND THAT, BUT UM, I WON'T READ THEM TO YOU, UH, IN THE INTEREST OF TIME. SO THAT GIVES US TO THE SECOND ITEM. UH, AND AGAIN, WE HAD MADE THE SAME COMMENT PREVIOUSLY. THIS IS A, A ADDRESSING, UM, YOU KNOW, MAKING SURE THAT AS WE WRITE THE RULES IN PICKER 1 45, AND THIS ALSO APPLIES IN PROJECT NUMBER 5 8 4 8 1, YOU KNOW, THE, THE INTERCONNECTING DSP INTERCONNECTING TSP DICHOTOMY WAS INTRODUCED IN THE LOAD FORECASTING RULEMAKING, WHICH MAKES SENSE 'CAUSE THAT'S FORECASTING NETWORK LOAD, BUT IT CAN CREATE SOME UNINTENDED CONSEQUENCES WHEN YOU APPLY IT TO THE LARGE LOAD INTERCONNECTION STANDARDS AND, AND BIGGER 1 45 AS WELL. UM, BECAUSE, YOU KNOW, FOR INSTANCE, EARLIER TODAY WE WERE TALKING ABOUT THE CONNECTED ISLAND OR NET GENERATION SITE OPTIONS FOR BYOG. IN THOSE INSTANCES, YOU'RE NOT GONNA HAVE ANY NET LOAD, ANY RETAIL DELIVERY SERVICE OF ELECTRICITY. IT'S ALWAYS GOING TO BE SERVED FROM, YOU KNOW, BEHIND THAT GENERATION SITE. SO IN THOSE INSTANCES, IT'S NOT APPROPRIATE TO REQUIRE THAT THE INTERCONNECTING DSP BE A PARTY TO SAY THE INTERCONNECTION AGREEMENT OR INTERMEDIATE AGREEMENT. UH, IN THAT CASE, IT'S REALLY JUST THE INTERCONNECTING TSP FOR THE GENERATION SITE THAT'S RELEVANT. SO, UM, WE PROPOSED SOME MORE STREAMLINED LANGUAGE IN THIS SET OF COMMENTS COMPARED TO OUR, OUR PRIOR COMMENTS. THIS ONE JUST FOCUSES ON WHETHER THE LARGE LOAD IS GOING TO TAKE RETAIL ELECTRIC DELIVERY SERVICE FROM A DSP. IF YES, THEN THAT THAT ENTITY IS A VERY REASONABLE AND YOU WOULD EXPECT THEM TO BE A PART OF THOSE CONTRACTS. IF NO, THEN IT'S JUST THE INTERCONNECTING TSP AND WE CAN PRETTY MUCH LEAVE EVERYTHING ELSE ALONE. I DID ADD BACK IN ALL OF THE AS APPLICABLES THAT WE HAD PREVIOUSLY, I, I DO RECOGNIZE SAID, YOU KNOW, YOU'LL CONSIDER THAT FOR A FUTURE REVISION REQUEST, BUT GIVEN THAT THIS HAS AN IMPACT ON THE BATCH ZERO PROCESS, WE WOULD RESPECTFULLY REQUEST THAT THAT BE TAKEN UP IN BIGGER 1 45 SO THAT THAT WAY THERE'S THAT FLEXIBILITY BUILT IN. UH, AGAIN, THIS SHOULDN'T IMPACT PROBABLY 99% OF, UH, OF THE LARGE LOAD INTERCONNECTIONS, BUT FOR THAT 1% JUST AVOIDS UNINTENDED CONSEQUENCES. THEN ON, UH, THE, THE PROJECT NUMBER 5 8 4 8 1 INCORPORATIONS. UM, CERTAINLY, UH, YOU KNOW, JIM, I I I SHARE SOME OF THE CONCERNS ABOUT MAKING SURE THAT WE'VE GOT THE RIGHT BALANCE. I DIDN'T, UH, GIVE THE SPECIFIC DETAILS THAT YOU DID, BUT, UH, RECOGNIZE THE PRINCIPLE THERE, UM, AND, AND SHARE THAT THAT SENTIMENT. UM, THE NEW ITEMS THAT WE INCLUDED IN HERE, UM, ONE IS, UH, YOU KNOW, AS WE THOUGHT ABOUT HOW TO, UM, YOU KNOW, KEVIN WAS JUST TALKING ABOUT, YOU KNOW, HOW DO YOU GET, HOW DO YOU MAKE SURE THAT WHEN THE LOADS COME ON, THEY'RE GOING TO BE ABLE TO BUILD, THEY'RE BE GONNA BE ABLE TO TAKE ON THE, THE COSTS THAT MIGHT BE INCURRED TO THE SYSTEM. AND ONE THING THAT, YOU KNOW, STOOD OUT TO US AS WE, YOU KNOW, KIND OF DIGESTED SOME OF THE DISCUSSION AT THE BUSINESS AND COMMERCE HEARING LAST WEEK AS, UH, AS WELL [05:40:01] AS SOME OF THE DISCUSSIONS ABOUT WHETHER THERE SHOULD BE MORE REFUNDABILITY OF THE INTERMEDIATE AGREEMENT, UH, FINANCIAL SECURITY, WAS THAT YOU COULD ACTUALLY BIFURCATE THE APPLICATION OF THAT FINANCIAL SECURITY SO THAT THERE'S A HIGHER DOLLAR PER MEGAWATT AMOUNT THAT APPLIES, SAY, AND WE CHOSE 250 MEGAWATTS BECAUSE THAT'S ALREADY IN THERE FOR THE STUDY FEE, UH, DIFFERENTIATION. YOU COULD CHOOSE A DIFFERENT NUMBER, UM, BUT YOU COULD SET A HIGHER DOLLAR PER MEGAWATT THRESHOLD FOR THOSE LARGER ONES THAT ARE PERHAPS MORE LIKELY TO, UM, CONTRIBUTE TO THE, THE NEED FOR NEW TRANSMISSION INFRASTRUCTURE. UH, REALLY AS A, AS A, UM, CALL IT A, UM, ACCESS TO CAPITAL SCREEN TO MAKE SURE THAT, YOU KNOW, IF YOU GET THROUGH, IF YOU GET AN INTERCONNECTION AGREEMENT, UH, DONE AND AN ALLOCATION, UH, AND YOU'RE OFF TO THE RACES TO, TO BUILD THAT, THAT YOU CAN ACTUALLY EXECUTE AND FINISH THAT. SO THAT WAY WE KNOW THAT LOAD IS MORE LIKELY TO COME ON AT THE SAME TIME THE TRANSMISSION FACILITIES COME ONLINE. AND, UM, THAT WAY THEY WILL BE CONTRIBUTING THEIR FAIR SHARE TO, UH, ABSORBING THOSE COSTS AND NOT, UH, NOT RESULTING IN THOSE COSTS BLEEDING OUT INTO OTHER, OTHER CUSTOMER CLASSES, WHICH, UM, I THINK KEVIN ALREADY ADDRESSED. SO, UH, VERY SIMILAR, UH, IN, UH, SIMILAR SENTIMENT THERE. UH, YOU KNOW, THE REASON I THINK THAT THE, THE, THE INITIAL AMOUNT WAS DROPPED FROM A HUNDRED THOUSAND TO 50,000, UH, SEEMED LIKE IT MIGHT'VE HAD TO DO WITH, UH, CONCERNS THAT YOU HAD, UH, ROPE IN SOME CALL IT TRADITIONAL, UH, LARGE LOAD SECTORS. AND SO WE THINK THAT IF YOU SET A, A HIGHER, UH, A HIGHER THRESHOLD, THEN, YOU KNOW, MAYBE THAT DOESN'T HAVE THAT SAME IMPACT. CERTAINLY OPEN TO FEEDBACK ON THAT AND, AND TAKING ARROWS. IT WAS JUST A, IT'S AN IDEA THAT WE WANTED TO THROW OUT SOME, SOME RECEPTIVITY TO. UM, BUT AN IMPORTANT PIECE THERE IS THAT YOU, YOU TIE THAT WITH HIGHER AMOUNTS OF REFUNDABILITY BECAUSE THAT SHOULDN'T BE THE PART THAT, THAT, THAT HIGHER AMOUNT SHOULDN'T FLOW THROUGH ALL THE WAY TO SAY HOW IT'S ALLOCATED ONCE IT'S, UH, BECOMES AN INTERCONNECTION STUDY FEE. WE DIDN'T SAY THAT, THAT THAT SAME VALUE SHOULD, UH, APPLY IN HERE. WE'RE JUST SAYING THAT THE INTERMEDIATE, UH, AGREEMENT SCREEN SHOULD, UH, HAVE THAT HIGHER ABILITY. UM, SO ASIDE FROM THAT, UM, WE ALSO RECOMMENDED IN THIS BULLET LIST RIGHT HERE, UH, SITE CONTROL PROVISIONS. UM, AS WRITTEN, IT SAYS THAT IT'S, UH, A PROPERTY INTEREST BEING PROVIDED TO THE INTERCONNECTING TSP OR DSP. UM, WE DON'T THINK THAT THE LARGE LOADS ARE GONNA BE, SAY, SIGNING A A LEASE OR, UH, YOU KNOW, GIVING SOME OWNERSHIP IN THE PROPERTY TO THE TSP OR DSP. SO WE JUST CHANGED THAT WITH EVIDENCE OF SUFFICIENT PROPERTY INTEREST. 'CAUSE I THINK THAT'S WHAT WE'RE REALLY TRYING TO GET AT THERE. UM, THERE WERE ALSO SOME, SOME OF THE PROVISIONS IN THERE, UH, TALKED ABOUT HAVING A TIME ELEMENT ON IT, LIKE FIVE YEARS OF, UH, A LEASE PERIOD. I REALIZE THAT, YOU KNOW, IF YOU OWN THE PROPERTY, IT MAY NOT, IT'S NOT LIKE YOU OWN IT FOR ONLY FIVE YEARS PAST YOUR, YOUR PEAK, BUT YOU PROBABLY WANT TO MAKE SURE YOU CAN STILL HAVE THAT SAME CONCEPT THERE TO MAKE SURE THAT THEY OWN ENOUGH PROPERTY TO GROW INTO IT OVER THE, THAT FIVE YEAR PERIOD. UM, SO WE JUST RECOMMENDED KINDA REPEATING THAT THROUGHOUT, UH, ON THE, UH, LET'S SEE THIS NEXT ONE ABOUT, UH, WHERE, YEAH, THE PROVISION WHERE IT SAYS ERCOT WILL, UH, REALLOCATE ANY WITHDRAWN PEAK DEMAND. UH, I THINK WE'VE HAD A COUPLE OF DISCUSSIONS WITHIN THIS FORUM BEFORE WHERE FOLKS HAVE SAID, WELL, OKAY, WELL IF THAT, IF THEY'RE REALLOCATING, IS THAT HAPPENING IN THE BATCH PROCESS OR IN THE BATCH REFINEMENT PROCESS? I THINK THE CONSISTENT ANSWER HAS BEEN NO, BECAUSE THAT COULD GET YOU IN A DO LOOP OF HAVING TO UDDY. SO WE, UH, PROPOSED SPECIFYING IN THERE THAT IT WOULD BE IN A FUTURE BATCH STUDY, OR YOU COULD CALL IT A FUTURE INTERCONNECTION STUDY IF YOU WANT TO BE GENERIC IN, IN TERMINOLOGY. UM, THAT SHOULDN'T BE CONTROVERSIAL, I DON'T THINK ANYMORE. UM, LET'S SEE, ON THE CLR PIECE, IT'S JUST SOME LANGUAGE ABOUT WHETHER IT WILL BE REGISTERED AND OPERATED AS A CLR VERSUS CAN BE MODELED AS ACL R. I THINK THAT THAT'S PROBABLY CONSISTENT WITH THE DISCUSSION WE HAD THIS MORNING. SO AGAIN, I, I HOPE THAT'S JUST SOME CLEANUP LANGUAGE AND NOT CONTROVERSIAL. UM, WE DID NOT RECOMMEND OFFER ANY RED LINES ON THIS NEXT BULLET ABOUT THE PERIOD AT WHICH THE FINANCIAL SECURITY IS RETURNED AND, AND CERTAINLY RECOGNIZE THE POINTS THAT JIM WAS MAKING ABOUT WHAT'S APPROPRIATE IN THE PLANNING GUIDES AND, AND NOT, UM, BUT WE DID WANT TO EXPRESS SOME, SOME SYMPATHY FOR THE SENTIMENT BEHIND IS FIVE YEARS ENOUGH TIME WHEN YOU'RE TALKING ABOUT AN ASSET, YOU KNOW, TRANSMISSION ASSETS THAT MIGHT HAVE A, YOU KNOW, 30, 40, MAYBE 50 YEAR LIFESPAN. UM, WHAT'S THE RIGHT AMOUNT OF TIME TO TO REFUND THAT? UM, [05:45:01] AND THEN, LET'S SEE, UH, THE LAST BULLET IS REALLY JUST A COROLLARY TO THAT. IT'S, IT'S JIM'S POINT, BUT WE DIDN'T, UH, WE DIDN'T RED LINE THERE. UH, THEN FINALLY DOWN IN THE, IN THE LAST SET OF MINOR REVISIONS, UM, I JUST CALL 'EM MINOR. THE FIRST ONE IS ACTUALLY IMPORTANT. THAT'S THE QSA TIMING ONE THAT I MENTIONED AT THE TOP. UM, HAPPY TO DIVE INTO THE DETAILS, BUT FOR IN THE INTEREST OF TIME, I'LL, I'LL JUST STIPULATE THAT, UH, BECAUSE MAY 1ST IS THE QSA DEADLINE. I THINK, FRED, YOU WERE JUST SAYING THIS MORNING, THAT'S FOR THE Q4 ENERGIZATION, RIGHT? AND SO IF THE BATCH ZERO IS ONLY APPLYING TO, UH, JANUARY 1ST, 2028 AND LATER, THEN THE APPROPRIATE, I THINK THE APPROPRIATE DEADLINE TO REFERENCE AND THERE WOULD BE AUGUST 1ST AS OPPOSED TO MAY 1ST, UM, FOR THAT, THAT CUTOFF. UM, LET'S SEE. ON THE DWG PROCEDURE MANUAL, UM, WE WANTED TO PUT AN ANCHOR DATE IN THERE FOR WHICH ONE YOU, WHICH VERSION WE'RE SHOOTING FOR. SO, UM, WE RECOMMENDED MARCH 4TH, UM, AS THE, THE ANCHOR DATE FOR THE, THE PIGGER LANGUAGE, UM, OR FOR THIS PIGGER I WOULD SAY. AND THEN, UH, THERE WAS IN 9.2 0.3 0.2, IT TALKS ABOUT PROVIDING AN UPDATE TO THE DYNAMIC MODEL UPON, UH, PROVIDING A NOTICE TO THE TSP THAT THERE'S BEEN A CHANGE, UM, WE JUST ADDED PROMPTLY, WHICH IS THE SAME TIMEFRAME AT WHICH THE TSP HAS TO LET ERCOT KNOW. AND I THINK THAT'S JUST TO RECOGNIZE THAT WE MIGHT NOTIFY THEM OF A CHANGE AND THEN QUICKLY GET THE UPDATED MODEL. BUT IT, IT, IT MAY NOT ALWAYS BE AT THE SAME EXACT, IN THE SAME EMAIL, SO TO SPEAK. RIGHT. UM, BUT NOT MEANT TO BE A SUBSTANTIVE, UH, DIFFERENCE, UH, REITERATING THE FLEXIBILITY THAT WE'VE RECOMMENDED BEFORE THAT ERCOT HAVE THE ABILITY TO OFFER THE BATCH FI ZERO FINAL REPORT TO RPG IN, IN A SINGLE PROJECT OR IN SUB REGIONS. UM, NOT, NOT A HILL TO DIE ON, BUT IT SEEMS LIKE IT, IT OFFERS FLEXIBILITY, SO WHY NOT HAVE IT? UM, AND THEN WE HAD SOME UPDATED REFERENCES ON THESE LAST THREE BULLETS. THOSE ARE PURELY MINISTERIAL, SO I WON'T WASTE Y'S TIME ON IT. UM, BUT I THINK THAT'S, THOSE ARE THE BIG ITEMS, SO, UM, APPRECIATE, APPRECIATE THE TIME. HAPPY TO TAKE ANY QUESTIONS. ALRIGHT, THANK YOU DAN. ANY QUESTIONS FROM THE AUDIENCE? MICHAEL JEWEL? YEAH, THANK YOU VERY MUCH. JUST TO BE SURE THAT I'M TRACKING ALL OF THIS AND I REALLY APPRECIATE, UH, THE DETAIL OF THESE COMMENTS. I'VE HAD A CHANCE TO GO THROUGH THEM YET, BUT JUST TO BE SURE THAT I'M TRACKING ON THIS FROM KO'S PERSPECTIVE, IF A LOAD AND AN EXISTING GENERATOR HAVE GONE THROUGH THE REVIEW PROCESS THAT THE COMMISSION IS SET UP, IS IT ERCOT PERSPECTIVE THAT THAT LOAD THEN HAS TO GO THROUGH THE BATCH STUDY PROCESS AS WELL? I CAN TAKE THAT ONE. YEAH. THANKS. UH, THE WAY, THE WAY WE HAVE, THE WAY THE RULE, THE NET METERING RULE WORKS, AND THE WAY THESE CASES HAVE PLAYED OUT SO FAR, THERE'S TWO OF THEM AT THE COMMISSION. UM, WE RELY ON THE, THE STUDY THAT'S DONE, THE INTERCONNECTION STUDY THAT'S DONE TO THEN DO THE ADDITIONAL REVIEW REQUIRED BY PIRA 39, 1 69. AND SO WHATEVER, UH, I FORGET THE EXACT LANGUAGE OF THE RULE, UH, BUT I THINK IT'S WHATEVER INTERCONNECTION PROCESS WAS IN EFFECT, UM, YEAH, WHICHEVER IS APPLICABLE AT THE TIME IS THE ONE THAT WE USED THE STUDIES FOR FOR OUR ADDITIONAL REVIEW. YEAH, MICHAEL, I CAN KIND OF OFFER SOME YEAH. CONTEXT FOR WHY I PUT THAT IN. IT'S FOR, TO SOME DEGREE IT'S BELT AND SUSPENDERS, RIGHT? WE'RE, WE'RE GOING THROUGH THIS PROCESS RIGHT NOW. THERE ARE LIVE PROJECTS THAT ARE AT THE COMMISSION AND WHILE YOU KNOW, IT, IT, IT MIGHT SEEM LIKE WE'VE GOT EVERY, UH, ANGLE CONSIDERED. WE JUST WANTED TO MAKE SURE THAT THERE IS COMPLETE REGULATORY CERTAINTY ONCE THE COMMISSION HAS TAKEN IT UP, UM, RATHER THAN ANY RISK THAT, YOU KNOW, WE ALWAYS FORGOT ABOUT THIS ONE LITTLE PIECE AND THEN IT COMES THROUGH. SO IT IS BELT AND SUSPENDERS TO MAKE SURE THAT THOSE DON'T, UH, END UP GOING BACK THROUGH AFTER THEY'VE ALREADY BEEN APPROVED. OKAY, GREAT. THAT'S, THAT'S VERY HELPFUL. AND THEN JUST, UM, ONE OTHER THING. THE IDEA ABOUT BUMPING UP THE, THE 250 MEGAWATT, UM, DEMARCATION, THERE'S SOME REALLY LARGE INDUSTRIAL PROJECTS THAT ARE IN DEVELOPMENT RIGHT NOW THAT WE'LL STILL GET CAUGHT. [05:50:05] UM, SORRY, CAN YOU ASK AGAIN? IT WAS JUST MORE OF A, I THINK WHEN YOU SET THE, WHEN YOU RAISED UP THE 250 MEGAWATT DEMARCATION, RIGHT? AND THE GOAL WAS TO TRY TO ELIMINATE A LOT OF THE TRADITIONAL INDUSTRIAL PROJECTS. THERE'S SOME REALLY LARGE ONES THAT ARE IN DEVELOPMENT RIGHT NOW THAT WILL STILL GET CAUGHT. GOTCHA. 'CAUSE THEY'RE BIGGER THAN TWO 50. OKAY. THAT'S HELPFUL FEEDBACK. WE, AGAIN, WE DIDN'T OFFER RED LINES ON THAT, BUT WE WANTED TO FLOAT THE CONCEPT, UM, TO THE EXTENT THAT THAT IS HELPFUL IN MAKING SURE THAT WE ARE, UM, WE'RE MAKING SURE THAT ONCE THE PROJECTS ARE, ARE APPROVED, THAT THEY HAVE THE FINANCIAL WHEREWITHAL TO ACTUALLY MOVE FORWARD AND START TO HELP PAY THEIR FAIR SHARE. YEAH. THANKS. ALL RIGHT. NEXT IN QUEUE IS JIM GALVIN. THANK YOU. UH, JIM GALVIN, UNITED COOPERATIVE SERVICES. UH, NED, THANKS FOR OUTLINING YOUR COMMENTS. I DO HAVE A CONCERN OVER THE COMMENTS MADE UNDER THE, UM, AS YOU HAVE IT SUMMARIZED FULL DIVERSITY OF LARGE LOAD CONFIGURATIONS REQUIRING DSP AND TSP AT VARIOUS STEPS. I I, I THINK WE HAVE TO BE CAREFUL THERE SO THAT WE DO NOT EXCLUDE, UM, YOU KNOW, MUNICIPALITIES AND COOPERATIVES WHO HAVE LOADS THAT ARE INTERESTED IN THAT AREA, WHO ARE, ARE GOING TO BE REQUIRED BY SOMEWHAT, EVEN IF IT IS A NET METERING SCENARIO OR EVEN A FULL ISLANDED, UH, GRID SCENARIO, WHERE AT SOME POINT IT MAY TRANSITION FROM THAT. I WANNA MAKE CERTAIN THAT THIS LANGUAGE IS NOT TOO, UM, STRICT TO EXCLUDE US FROM THOSE POTENTIAL OPPORTUNITIES, ESPECIALLY WHEN THEY'RE IN SINGLE CERTIFIED AREAS SERVED BY PUBLIC HOUSING. THANKS, JIM. AND, UH, WE, WE TRIED TO, ESPECIALLY WITH THIS NEW LANGUAGE, WE JUST TRIED TO MAKE IT A, UM, UH, MORE OF A FACTUAL, LIKE WHETHER THERE WILL BE A RETAIL ELECTRIC DELIVERY SERVICE TAKEN, UM, WHICH I, I THINK LEAVES SOME ROOM FOR, UH, YOU KNOW, FOR INDIVIDUAL SCENARIOS TO BE FLESH FLESHED OUT. UM, BUT WE, WE'VE BEEN, WE'VE TRIED TO BE BROAD ENOUGH IN THAT LANGUAGE TO NOT BE OVERLY PRESCRIPTIVE, RECOGNIZING THAT THERE ARE MANY, MANY DIFFERENT, UH, COLORS IN THE TAPESTRY OF THE, UH, THE ERCOT, UH, TDSP MAP. I, I APPRECIATE THAT NOW, BUT I, I, I THINK WE'RE, WE ARE GOING TO BE VERY ADAMANT 'CAUSE OF SOME OF THE PRO POTENTIAL PROJECTS THAT WE'VE SEEN, WHICH WHERE THEY MAY STA CLAIM THAT THEY'RE STARTING OUT THAT THERE WOULD BE NO RETAIL SERVICE THERE AND THEY ARE IN SINGLE CERTIFIED TERRITORIES, THAT WE REALLY STILL HAVE TO PROTECT OUR ABILITY TO SERVE AT SOME POINT IF THEY TRANSITION TO A DIFFERENT MODEL. UM, SO WE REALLY HAVE TO BE CAUTIOUS OF THAT. SO OUR, OUR ABILITY TO SERVE A LOAD IN OUR SECURE AREA IS PROTECTED, SIR. OKAY. HAPPY TO TALK ABOUT ANY, UH, ANY CLARIFICATIONS THAT MIGHT HELP THERE. APPRECIATE THAT. THANK YOU. ALRIGHT, THANK YOU. SO BROTH [7. Summary of PUC Project No. 58481 from Crusoe] YOU, WE FINALLY GOT TO YOU. SO THANK YOU AGAIN FOR BRINGING THIS, UH, YEAH, THANK YOU. I KNOW IT'S END OF THE DAY, SO I WILL PROBABLY TRY TO GO AS FAST AS I CAN. UH, BUT I FEEL LIKE THIS IS SUPER IMPORTANT GIVEN THE UNCERTAINTY AROUND, UH, HOW DO WE APPLY 5 8, 4 8 1 TO BAD ZERO. SO, UM, REALLY QUICK. SO OBJECTIVES, YOU KNOW, WALK THROUGH THE CASH FUNDING REQUIREMENTS OF, UH, ILE FOR BAD ZERO FIGURE 1 45, UH, AND HOW THIS IS INTERPRETING 5 8 4 8 1 LANGUAGE HERE AS I SEE THIS, THERE ARE, YOU KNOW, THREE PROPOSED FUNDING REQUIREMENTS FOR IIL E UH, WE CAN CALL IT THREE BUCKETS. UH, THE FIRST ONE IS THE FINANCIAL SECURITY OF $50,000 PER MEGAWATT, YOU KNOW, DUE AT INTERMEDIATE AGREEMENT. AND THEN THE SECOND ONE IS THE KAYAK PIECE. YOU KNOW, EVERY ILLE OR MOST OF THE ILES HAVE TO DO THIS. AND I UNDERSTAND THIS WOULD COME AT THE INTERCONNECTION AGREEMENT STAGE PROBABLY AROUND FEB 2027. AND THIS THIRD ONE, UH, IS A PARTIALLY REFUNDABLE UPGRADE SECURITY COVERING THE TRANSMISSION UPGRADES, UH, AGAIN DUE AT INTERCONNECTION AGREEMENT STAGE DUE, UM, AROUND FEB 2027. UM, THESE REPRESENT THE, YOU KNOW, SEPARATE MEANINGFUL COMMITMENTS FOR OLIS, UH, UNDER THE CURRENT PROPOSED RULES. SO I'M GONNA WALK THROUGH EACH OF THEM HERE, UH, AND KIND OF WALK, UH, GO THROUGH HOW THE REFUNDABILITY ASPECT OF EACH OF THEM AND THEN ALSO KIND OF TAKE AN EXAMPLE FOR A ONE GIGAWATT, UH, ONE GIGAWATT OF LOAD AND HOW THE MONEY KIND OF FLOWS THROUGH THIS PROCESS. SO THE FIRST ONE IS, UH, [05:55:01] STRAIGHTFORWARD. I LILLY POST $50,000 PER MEGAWATT TO TSP AT INTER INTERMEDIATE AGREEMENT SIGNING. AND I TRY TO CODE THE RULE IN FIGHT FOR IT ONE SO THAT, UH, IT IS CLEAR. BUT, UH, FEEL FREE TO CORRECT ME OR ADD ANY MORE DETAILS. UH, THIS IS MY UNDERSTANDING AGAIN. SO AT THIS STAGE, IF THERE ARE TWO OPTIONS FOR THE ILE, FIRST ONE IS THEY SIGN THE INTERCONNECTION AGREEMENT, THEN THAT $50,000 PER MEGAWATT FEE GOES TO OFFSET THE RATE BASE, UH, FOR THE TSP. IF THEY DON'T SIGN THE AGREEMENT, THEN I LILLY RECEIVES 20% BACK, UH, WHICH IS 10 K PER MEGAWATT, AND THE REST OF THE 80% GOES TO OFFSET THE RATE BASE ANYWAY. SO, UH, SUPER IMPORTANT DISTINCTION HERE. 80% OF THE 50 K PER MEGAWATT GOES TO OFFSET THE RATE BASE IN EITHER CASE. SO THAT'S BUCKET NUMBER ONE. BUCKET NUMBER TWO, KAYAK STRAIGHTFORWARD. YOU KNOW, YOU'RE PAYING FOR DIRECT COSTS. IT'S, IT'S, UH, SIMILAR TO TODAY'S REALM, UH, UH, AGAIN, UH, ACTUAL COST FOR, UH, YOU KNOW, PAYING YOUR ACCOMMODATING THE LOAD. SO THIS IS VERY STRAIGHTFORWARD. I DON'T WANT TO GO, YOU KNOW, EXPLAIN THIS ANYMORE HERE. THIRD ONE, AND THIS IS WHERE I THINK WE CAN PROBABLY HAVE MORE DISCUSSIONS OR I APPRECIATE THE INPUT AS WELL. THIS IS THE UPGRADE SECURITY, UH, FOR THE TRANSMISSION UPGRADES. SO THE WAY I LOOK AT THIS IS, YOU KNOW, TSP IDENTIFIES THE SECURITY. I REALLY POSES SECURITY FOR, UH, THE UPGRADES. BUT IN TODAY'S WORLD, WHEN THE LARGE LOAD ENERGIZATION HAPPENS, YOU GET THAT SECURITY BACK. BUT THE WAY I READ IT IN FIGHT FOR IT, ONE IS YOUR SECURITY IS NOW BEING APPLIED TO GENERAL COSTS, THE EQUIPMENT COSTS AND THE CONSTRUCTION AND COST OF SERVICES THAT THE TSP INCURS. SO THEY'RE GOING TO, YOU KNOW, DRAW DOWN UPON THE SECURITY THAT YOU POST AND THEY'RE GOING TO USE THAT TO PAY FOR THAT EQUIPMENT. AND THEN THE REFUND WOULD BE WHATEVER IS THE DIFFERENCE AMOUNT DIFFERENCE THAT IS LEFT OVER, RIGHT? AND THEN YOU WOULD GET THE 20% AT ENERGIZATION, UH, OF THAT REFUND OF THE LEFTOVER AMOUNT AND THE REST OF THE 80% WOULD BE OVER A PERIOD OF FIVE YEARS. SO I'M GONNA WALK THROUGH THIS IN AN EXAMPLE, SO THAT PROBABLY IT'S MUCH MORE CLEAR TO PEOPLE HERE. SO IMAGINE, UH, ONE GIGAWATT OF LOAD ENTERING INTO BAD ZERO PROCESS. SO THE FIRST ONE, FINANCIAL SECURITY, AS I MENTIONED, YOU KNOW, IF YOU WITHDRAW, YOU GET 20% BACK. IF YOU DON'T WITHDRAW YOU THE 50 MILLION, WHICH IS THE, YOU KNOW, TOTAL COST FOR ONE GIGAWATT WOULD GO TO OFFSET THE RATE BASE. THE SECOND AMOUNT, SECOND BUCKET IS THE KAYAK. STRAIGHTFORWARD. IF YOU ASSUME A HUNDRED MILLION FOR KAYAK, I'M, I'M ROUNDING OFF NUMBERS SO THAT IT'S VERY EASY TO TALK ABOUT IT. SO A HUNDRED MILLION GOES TOWARDS KAYAK, NO REFUND FOR THAT, WHICH IS TRUE IN TODAY'S SCENARIO AS WELL. THE THIRD PIECE IS A SYSTEM UPGRADES PIECE. SO ILLE SUBMITS A HUNDRED MILLIONS, A HUNDRED MILLION DOLLARS TO COVER SYSTEM UPGRADES, FOR EXAMPLE. NOW THE DEDUCTIONS ELIGIBLE COST DEDUCTIONS ARE 90 MILLION. IF YOU'RE RESUMING A 90 MILLION UPGRADE COST, THEN THE REFUND WOULD BE 10 MILLION THAT THE ILA WOULD GET BACK OUT OF THAT A HUNDRED MILLION THAT IS POSTED. AND THEN OUT OF THAT 10 MILLION, YOU WOULD GET 2 MILLION AT, WHICH IS 20% OF 20 10 MILLION AT ENERGIZATION. AND THE REST OF THE 8 MILLION YOU WOULD GET IN AN UH, YOU KNOW, UM, FIVE YEAR PERIOD. AND THERE ARE MORE NUANCES TO THIS. IF YOU DON'T ENERGIZE WITHIN SIX MONTHS, YOU WOULD LOSE THAT AMOUNT AS WELL. BUT THIS IS THE OVERALL BIG PICTURE ON HOW THE MONEY FLOWS FROM ENTERING INTO BAD ZERO AND HOW WOULD YOU GET IT BACK IF YOU GET IT BACK, AND WHAT WOULD BE THE DIFFERENT BUCKETS AND THE DIFFERENT ASPECTS OF REFUNDABILITY VERSUS NON REFUNDABILITY ASPECTS. SO IN THE FIRST CASE, IF YOU DROP OUT, YOU GET 10 MILLION BACK IN THE SECOND CASE, OBVIOUSLY YOU GOOD INTERCONNECTION STAGE, YOU WON'T GET ANY KAYAK BACK. IN THE THIRD CASE, IF YOU POST A HUNDRED MILLION DOLLARS OF MONEY, YOU WOULD PROBABLY GET 10 MILLION BACK DEPENDING ON THE DIRECTIONS IN THE COST OF SERVICES. SO, UH, AGAIN, UM, YOU KNOW, THESE ARE THE RULES THAT I KIND OF PUT TOGETHER, UH, FOR EACH OF THE BUCKETS AND WHAT I WAS TRYING TO, UM, EXPLAIN. SO YEAH, REALLY QUICK, HAPPY TO ANSWER ANY QUESTIONS YOU ALL MIGHT HAVE. YEAH, THANKS RALPH. PUTTING THIS TOGETHER. SO WE DID HAVE, OOPS, WE GOT BLOCKED HERE. BOB WHITMEYER, YOU'RE IN THE QUEUE. YEAH. SO ON THE, ON THE INTERMEDIATE AGREEMENT, MY UNDERSTANDING WAS THEY HAD TO POST FINANCIAL SECURITY, NOT MAKE A PAYMENT AS YOU HAVE THIS LAID OUT WHEN, [06:00:01] LET'S SAY THEY POST THE FINANCIAL SECURITY BUT WITHDRAW. RIGHT? WHEN DO THEY MAKE THE $40 MILLION PAYMENT AT THE INTERCONNECTION STAGE? OKAY, SO IF THEY, IF THEY WITHDRAW BEF AT THE END OF BATCH ZERO, SO YOU WOULD KNOW THE RESULTS IN FEB 2027 OR END OF JAN AT THAT STAGE, YOU WOULD SEE IF YOU WANT TO GO FORWARD, YOU ARE OKAY WITH THE AMOUNT THAT WAS ALLOCATED TO YOU OR NOT, AND THEN YOU DECIDE TO MOVE FORWARD WITH THAT, YOU WITHDRAW. RIGHT? RIGHT. SO I'M, I'M GONNA WITHDRAW. I POSTED THE SECURITY, BUT I HAVE NOT YET MADE A, SO I'VE NOT MADE A PAYMENT. I POSTED THE SECURITY. YEAH. I GET THE RESULTS FROM BATCH ZERO AND I'M GONNA GET 10 MEGAWATTS OUTTA MY GIGAWATT. I SAID, NO, I'M OUT. YEAH. I HAVEN'T MADE A PAYMENT YET. YEAH, BUT YOU WILL NOT GET THAT SECURITY BACK. YOU HAVEN'T MADE THE PAYMENT YET. GREAT POINT. BUT FOR AS FAR AS THE RULE IS WRITTEN RIGHT NOW, YOU'RE ONLY ELIGIBLE TO GET 20% OF THAT POSTING BACK. SO I DON'T KNOW THE MECHANICS DONE HOW WILL GREAT POINT, GREAT POINT. IF HOSTING WERE A LETTER OF CREDIT. YEAH. YEAH, I SEE YOUR POINT. OH, OKAY. SO THAT, THAT'S ALL I REALLY NEEDED FOR YOU TO SEE MY POINT. YES. I'M, I'M A LITTLE BIT CONFUSED ON HOW WE WENT FROM A LETTER OF CREDIT CORRECT. THAT I DIDN'T PAY TO. I ONLY GET SOMEWHERE I HAVE TO PAY THE 40 MILLION IS THIS IS LAID OUT. YES. AND THAT'S WHERE I'M A LITTLE BIT CONFUSED. THANKS. YEAH. SO AGAIN, I I THINK THE MECHANICS OF ON HOW WILL THAT WORK NEEDS TO BE IRONED OUT. EXACTLY RIGHT. ALRIGHT, NEXT. MICHAEL JEWEL. YEAH, THANK YOU SO MUCH. THIS IS A REALLY HELPFUL, UM, DECK. ONE QUICK QUESTION WITH REGARD TO KAYAK. THE WAY THAT I LOOK AT THE RULE, IT LOOKS LIKE IF YOU MOVE FORWARD WITH REGARD TO INTERCONNECTION, UM, THE AMOUNT THAT'S PAID IN KAYAK THAT YOU PAID UP FRONT WILL GET, UM, UH, TRUED UP SO THAT IF YOU OVERPAID YOU WOULD GET BACK WHAT, UH, WHAT YOU PAID. BUT IF YOU END UP WITHDRAWING, THEN YOU'RE NOT GONNA GET ANYTHING BACK, EVEN THOUGH NOTHING WAS SPENT WITH REGARD TO THAT INTERCONNECTION COST. BUT YOU OR IF THERE WERE A COST, THEY'D COVER THOSE. YEAH, THAT'S RIGHT. YEAH. SO TO BOB'S POINT, WE NEED TO FIGURE OUT, BUT SO WHAT YOU'RE SAYING IS YOU POST A SECURITY, RIGHT? AND, BUT THAT WILL NOT GO TOWARDS KAYAK, RIGHT? THAT WILL BE OFF GO TOWARDS OFFSETTING THE RATE BASE AT THIS POINT. SO KAYAK WILL BE A NEW TOTALLY NEW PAYMENT. DOES THAT EXPLAIN? SO, SO THE $50,000 PER MEGAWATT SECURITY IS NOT GOING TO GO TOWARDS KAYAK. RIGHT. BUT IF YOU MOVE FORWARD TO THE INTERCONNECTION PROCESS, IT COULD THAT IT DOES, DOES. I THOUGHT THAT THAT ROLLED OVER INTO KAYAK AS WELL. IT MAY NOT, IT MAY BE OTHER CHARGES ARE. YEAH. YEAH. OKAY. THANKS MICHAEL. MICHAEL, THIS IS JIM. UM, SENATOR BOY, JUST KEEP IN MIND KAYAK IS CUSTOMER SPECIFIC DRIVEWAY COSTS NOT UPLIFTED. SECURITY WILL LIKE, EVENTUALLY GETS UPLIFTED, RIGHT? YEAH. AND SO, AND THEREFORE TWO DISTINCT PURPOSES. SO CAN'T COLLECT SECURITY AND SAY IT APPLIES TO KAYAK. YEAH. AND ALSO KAYAK IS CASH. CASH. YEAH. THANKS SO MUCH. IT'S ALL THE DIFFERENT MOVING PARTS RIGHT NOW. THANK YOU. YEP. NO, CHRISTINA, THANK YOU FOR THIS. THIS WAS VERY HELPFUL. WHEN YOU LOOK AT THIS SLIDE WITH THE EXAMPLE, UM MM-HMM . WHEN YOU LOOK AT THE SYSTEM UPGRADES, THEY'RE DEDUCTIONS OF MM-HMM . 90 MILLION. AND I WAS TRYING TO UNDERSTAND WHERE IN THE RULE IT AUTHORIZES DEDUCTIONS. 'CAUSE WHEN I LOOK AT MM-HMM . UM, THE REFUND, LIKE IF YOU ENERGIZE, I THINK IT'S, I IF YOU ENERGIZE THE MONEY'S RETURNED I KNOW IT SAYS AMOUNTS OWED, BUT I WAS WONDERING WHERE IN THE PFP IT, IT CLARIFIES THAT THE AMOUNT OWED IS RE WHAT THOSE AMOUNTS OWED ARE. IF YOU LOOK AT, I THINK SUB 0.1, IT SAYS A, AFTER APPLYING FINANCIAL SECURITY TO ANY OUTSTANDING AMOUNTS OWED, THE INTERCONNECTING DSP OR TSP MUST REFUND 20% OF THE REMAINING BALANCE. WHEN THE LARGE LOAD CUSTOMER ENERGIZE IS ENERGIZES AND RATEABLY AS A LARGE LOAD CUSTOMER MEETS THE MILESTONES. SO, AND THEN I THINK THERE IS TEXT OUT THERE ABOUT WHAT IS ELIGIBLE FOR THESE, UH, YOU KNOW, INTERCONNECTING, UH, INTERCONNECTING, UH, WHAT ARE THE ELIGIBLE COSTS OUT THERE. SO THAT'S KIND OF WHAT I TRY TO LIST HERE. UM, BUT THAT'S, THAT'S THE TEXT THAT I'M REFERRING TO HERE. [06:05:01] SO GENERAL COSTS, EQUIPMENT COSTS, CONSTRUCTION COSTS, COST OF SERVICES. OKAY. I GUESS I DIDN'T, I DON'T SEE THAT IN THE PFP, I THINK IT COULD BE FULLY REFUNDABLE. UM, SO JUST PUTTING THAT IDEA OUT THERE THAT THERE MAY BE SOME AMBIGUITY IN HOW YOU READ THAT AND THAT MAY BE SOMETHING WORTH COMMENTING ON TO THE EXTENT THAT, UM, YOU KNOW, YOU THINK THAT THERE ARE DEDUCTIONS BEING MADE FROM THAT SYSTEM UPGRADE FINANCIAL SECURITY IF YOU ENERGIZE THAT. YEAH. IN, IN TODAY'S WORLD, THESE, THIS IS COMPLETELY REFUNDABLE, RIGHT. UH, AGAIN, THAT'S WHY I FEEL LIKE FIGHT FOR EIGHT ONE DEVIATES FROM TODAY'S WORLD BECAUSE WE NEED TO PAY FOR THE, THE ILE NEEDS TO PAY FOR THE UPGRADES AS WELL, IS MY UNDERSTANDING. BUT YEAH, I'M HAPPY TO BE PROVEN WRONG. . ALRIGHT, BOB. ALL RIGHT. NEW, NEW TOPIC. UM, IF YOU'RE CONNECTING IN A MUNICIPALITIES AREA MANY TIMES THEY HAVE UH, FRANCHISE FEES. HAS ANYBODY THOUGHT ABOUT HOW THAT PLAYS OUT IN THIS REFUNDABILITY PORTION? ANYTHING ELSE? OKAY. I DIDN'T THINK SO. I MEAN, THIS IS GREAT, RIGHT? I MEAN THIS, THE INTENT OF THIS PRESENTATION IS TO KIND OF START TAKING, BRING UP THOSE QUESTIONS. YEAH, EXACTLY. AND DON'T KNOW IF ANY OF I KNOW ANYBODY'S ON THE PHONE HAVE AN ANSWER TO THAT . THANKS. YEAH, I'LL JUST POINT TO 25 1 94 A, WHICH SAYS THAT NOTHING IN THIS RULE UM, LIMITS THE ABILITY OF IMMUNITY TO, OR COOPERATIVE TO IMPOSE ADDITIONAL REQUIREMENTS, BUT IT DOESN'T ADDRESS HOW THEY WOULD BE REFUNDED. YEAH. AND I, I CERTAINLY GET AND APPRECIATE THAT, BUT I'M A LITTLE CURIOUS AS TO, DOES THAT MEAN THAT IF YOU'RE GOING INTO A NO AREA, LET'S ASSUME IT'S 3%. IS THAT $50,000 PLUS 3% OR MAYBE THAT'S UP, I GUESS PROBABLY THAT'S UP TO THEM. MAYBE GET, I JUST WANTED A QUICK POINT TO MICHAEL'S QUESTION. UH, IF YOU SEE, UH, BULLET POINTS, SEE IN THE FIRST PARAGRAPH THAT'S, IT'S TALKING ABOUT TRUING UP KAYAK AND IF YOU HAVE CREDIT, IT'LL, IT'LL BE APPLIED TO YOUR BILL. YEAH. SO THAT'S WHAT YOU'RE REFERRING TO. BUT THAT DOESN'T, UH, IT'S COMPLETELY DETACHED FROM THE $50,000 SECURITY THOUGH. YEAH, NO, I APPRECIATE IT. I, I WENT BACK AND LOOKED AT THE RULE AND I WAS THINKING ABOUT THE SECURITY FOR LONG LEAD TIED EQUIPMENT. 'CAUSE THEY'RE THE FINANCIAL SECURITY YEAH. AND ROLLOVER TO HELP COVER THAT. OKAY, THANKS. THANK YOU. THANK YOU SO MUCH. THANK YOU AGAIN, BROTH. REALLY APPRECIATE THAT. ALRIGHT. RIGHT. SO IF YOU WANT TO GET YOUR CALENDARS OUT, I'M GONNA ROLL BACK TO A SLIDE VERY EARLY IN THE PROCESS, WHICH WAS THE CALENDAR, WHICH NEEDED AN I CHART AND MAYBE THERE'S A BETTER WAY TO COMMUNICATE IT. BUT IT WAS ON AROUND SLIDE EIGHT, UH FOUR, NOT EVEN CLOSE. UM, SO IF YOU'RE MARKING YOUR CALENDAR, LET ME JUST KIND OF WALK DOWN REGULAR, SORRY, ROS NEXT WEEK. SO NORE 2 82 WAS VOTED OUT. SO THE SPECIAL ROS IS A WEBEX ON TUESDAY, NOTHING BUT BATCH. SO WE HAVE AN ALL DAY AUDIENCE AS NEEDED FROM NINE 30 TO WHENEVER WE NEED IT. AGAIN, I I, I MAY HAVE UNDERSOLD THIS ERCOT WILL DO A PRIMER FOR THE ROSS MEMBERS THAT HAVE NOT KEPT UP TO SPEED AND TRY TO FRAME OUT THE MAIN ISSUES AND TALK ABOUT ANY CLR UPDATES AND OPEN IT UP TO ANY MARKET COMMENTS THAT WANT TO COMMENT. SO IT IS A FULL ON WORKSHOP AS NEEDED, UM, BUT ALSO RECOGNIZING IT'S ON THE EVE OF 58 41, THE COMMISSION AND EVERYTHING ELSE NEXT WEEK. SO I JUST WANTED TO SHOW IT'S AS DEEP AS WE WANT TO GO TO ADVOCATE POSITIONS TO CONTINUE MOVEMENT. AND AGAIN, GETTING THAT CLR, THIS IS PROBABLY YOUR WINDOW TO SOAK IN WHAT AG PRESENTED ON CLR AND SAY, HEY, WE FOUND A GAP OR A REAL BIG ISSUE. WE'D LOVE TO KNOW SOONER RATHER THAN LATER. NOW PRS IS A REGULAR PRS MEETING, WHICH MEANS THEY HAVE A FULL AGENDA AND WE'RE JUST GONNA FIT IN AT THE END AND GO AS FAR AS WE CAN. SO NUMBER ONE IS EDUCATE THEM, HIGHLIGHT THE TOPICS AND THEN SEE WHERE WE'RE AT. THEN THE FOLLOWING WEEK IS WHEN NOW WE'LL HAVE A SPECIAL PRS TO THEN DO THE DEEP DIVE THERE AND THEN WE'LL HAVE A SPECIAL ROS SO ANOTHER DOUBLE HEADER WEEK AFTER THAT. THINK OF TWO, TWO TIMES A WEEK TO BE TALKING ABOUT THIS FUN STUFF. UH, BUT BOTH OF THOSE WILL BE SPECIAL MEETINGS, MEANING THEY'RE FOR US. UM, PRSI, I DON'T KNOW IF THEY'VE CLEARED THE BOARDS ON EVERYTHING ELSE BUT JUST THAT PIECE. AND AT THE END OF THIS TWO WEEK SPRINT, WE'LL HAVE A LOT BETTER VIEW OF WHERE WE'RE AT ON BYOG, [06:10:01] THE DISPOSITION OF BATCH ZERO CLR AND THEN WE POSITION OURSELVES, WE KIND OF BRACE FOR MAY AND WHAT DOES THAT LOOK LIKE? SO WHETHER THERE'S EXTRA MEETINGS, BUT REALLY THE BIG VOTE IS LOOKING AT THAT FIRST. UM, YOU KNOW, PART OF MAY IS MAY 6TH AND MAY 7TH. THAT'S WHERE IT ALL COMES TO CALLING IF THINGS GET STUCK. T IS TALKING ABOUT PLAN B IF THEY NEED TO BECAUSE THERE IS A SPECIAL TACK. THERE'S EVEN A POSSIBLE TWO DAY TACK. SO THERE'S STILL ROOM TO GET THROUGH THIS, BUT UM, JUST KEEP YOUR CALENDAR, KEEP YOUR PEOPLE UPDATED AND THERE'S A LOT MORE GOING ON ON THIS. SO, UM, ANYTHING ELSE WE WANNA SHARE? SO NUMBER ONE, ERCOT WAS GONNA TRY TO GET THIS CLR COMMENTS FILED EARLY NEXT WEEK. AND THEN ALSO I THINK WHAT JEFF INDICATED WAS THE NEXT ROUND OF ERCOT COMMENTS THAT ARE MORE HOLISTIC IN NATURE TO BATCH ZERO WILL BE AP AFTER APRIL 17TH. SO IT'S PROBABLY THAT FOLLOWING WEEK. SO WITH THAT, IS THERE ANY OTHER BUSINESS OR QUESTIONS? THANKS FOR BEING ALONG FOR THE RIDE. APPRECIATE IT. WE SEE AN ADJOURNED. * This transcript was created by voice-to-text technology. The transcript has not been edited for errors or omissions, it is for reference only and is not the official minutes of the meeting.